Private complaint to the criminal Court
The Court of Ili District of Almaty region
Private prosecutor:
(Victim):
S T A IIN:
full name: Askar Tokpanov, A X STR., 26
mobile network: +7....
Representative by power of attorney:
The accused:
(Defendants)
B. N. A.
mobile network: +7 747...1
El.mail: ...
1.date of Birth of 06.06.1986
phone: 125/48 I. STR., Almaty
mobile network: +7 707...
2. D. T. G. born on 01.07.1988
full name: Sh., IP. 189 . 29/1
mobile network: +7 777...
Complaint
on the order of private prosecution
A private prosecution complaint was submitted to the court in accordance with the requirements of Article 408 of the CPC.
1. on 08.07.2025, at 11:03 am, the private prosecutor S. T. A. was present at the address: 26 A. H. Street, A. T. Village, Ili district, to his messenger watzap 8 747. . the accused belongs to T. E. K. G. dated 06.06.1986 8 707. from the messenger watzap comes the following words that insult honor, indecently belittle the honor and dignity of another person, belittle:-it turns out that you do not have a wow tarbie!!! In Ake-Chechnya, there are people who are neither wise, nor educated, who do not dance respectfully!!!! In the beginning there was no brain!!! If you don't have brains and tarbien, what are you going to do?!! At the beginning of the year, Menin aitkan sozderim Durys was!!! "I don't know," I said.!!! "I don't know," she said.!! Kettinbe Endi kozimizge korinbe!!! The white shawl ursyn Seni tarbiesiz left on Earth!!! God will give you the punishment! "I'm sorry," I said. "No," he said.!! "I don't know," he said.!!!
Thus, the accused fully realizes the unlawful intent of T. E. K. G. on 06.06.1986, and the private prosecutor Sadakhbaeva Tolkyn Akhmetovna heard (received) the insult addressed to her, the composition of The Insult was completed.
That is, the fact of indecent discrimination, undermining the Honor, Honor and dignity, reputation of the direct victim, is confirmed by a message on the watzap network.
After these words, the private prosecutor felt bad and took a heavy heart and blocked the defendant's watzap line.
2. on 08.07.2025, at 15:57 hours, the private prosecutor S. T. A. was present at the address: 26 A. H. Street, A. T. Village, Ili district, his watzap Messenger 8 747. the accused belongs to T. D. T. G. As of 01.07.1988 8 777. . the following words are written from the watzap Messenger, which humiliate honor, indecently belittle the honor and dignity of another person:-Ye cattle. And you kimsins 3 zhalmauz that will be closed to my mother, hats that I did not see, now my mother's jaw will rise and call skoryly zafixirovali we all, now The Swallow will write to you that you are the most noble person with pure morality, let the upbringing of your daughters be created! Let the white handkerchief hit you where you threw it! You are an animal that cannot be compared to the most intelligent person who has either not been educated or has no morals! "I don't know," he said. Build your daughter ahead and now there is another one! I'll show you what I've got to do." "I don't know," he said. You don't live on my mother's nails you and your daughter! Please.
Thus, the accused D. T. G. fully realized the unlawful intent, and the private prosecutor S. T. A., Having heard (received) the insult addressed to him, the composition of The Insult was completed.
That is, the fact of indecent discrimination, undermining the Honor, Honor and dignity, reputation of the direct victim, is confirmed by a message on the watzap network.
After these words, the private prosecutor felt bad and took a heavy heart and blocked the defendant's watzap line.
Thus, in two cases, a criminal offense was committed at the address: Ili district, Askar Tokpanov village, A. Kh. street, 26, that is, the complaint is subject to consideration in court at the place of commission of the criminal offense, which is specified in Article 314 of the criminal code.
At the time of the commission of this criminal offense, the private prosecutor S. T. A. was with him on 17.04.1987, that is, the two were together in the village of A. T., Ili district, at 26 A. H. street.
Paragraph 1 of Article 17 of the Constitution of the Republic of Kazakhstan clearly establishes the "inviolability of human dignity".
As specified in Part 2 of Article 131 of the Criminal Code of the Republic of Kazakhstan, the accused, using telecommunications, watzap networks, deliberately committed obscene words in the form of written messages that defame the victim in an indecent form, damaging his honor, dignity, reputation and aimed at undermining it, namely, insulting, that is, it is characterized by indecent discrimination of another person, damaging his honor, honor and dignity, reputation.
In accordance with paragraph 1 of Article 18 of the Constitution of the Republic of Kazakhstan, "everyone has the right to privacy, personal and family secrets, protection of honor and honor".
In accordance with Part 3 of Article 23 of the Criminal Procedure Code of the Republic of Kazakhstan, "the task of proving the guilt of a person in committing a criminal offense and refuting his arguments in defense is assigned to the criminal prosecution authorities, and in court proceedings-to public and private prosecutors."
According to Part 4 of Article 19 of the Criminal Procedure Code of the Republic of Kazakhstan, "the guilty verdict cannot be based on assumptions and must be confirmed by a sufficient set of admissible and clear evidence".
At the same time, the prosecution proves that the words offensive to honor, honor, and reputation in the watzap networks are aimed at undermining it by the protocol of verification of evidence made on 10.07.2025, through a notary.
In accordance with paragraph 3 of the normative resolution of the Supreme Court of the Republic of Kazakhstan dated April 20, 2006 No. 4 on some issues of evaluation of evidence in criminal cases, a judge evaluates evidence, based on their totality, based on his internal convictions, guided by the law and conscience.
Part 2 of Article 131 of the Criminal Code of the Republic of Kazakhstan indicates signs of a criminal offense using telecommunications networks-insult, that is, the place of indecent discrimination of the dignity and dignity of another person as evidence of 10.07.2025, confirmed by the protocol of verification of evidence through a notary.
Considering that in Articles 7, 8 and 10 of the UN Universal Declaration of human rights, Article 14 of the International Covenant on Civil and Political Rights, Article 6 of the Convention on the protection of fundamental human rights and freedoms and Article 14 of the Constitution of the Republic of Kazakhstan, everyone is equal before the law and the court, and everyone has the right to consider the case in a competent, independent and impartial court established on the basis of law in a fair and public manner in determining their civil rights and obligations, at the same time, based on the requirements of Article 24 of the Criminal Procedure Code of the Republic of Kazakhstan, it is necessary to comprehensively, fully and objectively identify, examine, investigate the circumstances of this private prosecution complaint and adopt an appropriate fair sentence.
The above-mentioned grounds and paragraphs 1 of Articles 17, 18 of the Constitution of the Republic of Kazakhstan, Article 12 of the Universal Declaration of human rights within the framework of the United Nations, paragraph 1 of Article 17 of the International Covenant on Civil and political rights, the CPC of the Republic of Kazakhstan 19, 23, 72, 76, 407, 408, 409, 410-Article 2 of Article 131 of the Criminal Code of the Republic of Kazakhstan, as well as normative resolution of the Supreme Court of the Republic of Kazakhstan dated December 25, 2006 No. 13 on judicial practice in private prosecution cases,
Please the court:
- In respect of the accused, born 06.06.1986, E. K. G., born 01.07.1988, D. Tolkyn G., victim S. T. A. Please accept for proceedings the complaint of private prosecution,
Appendix: - minutes of verification of evidence through a notary, receipts of paid checks,a copy of the contract, a copy of the letter of trust, an extract from the chamber,
26.09.2025
With respect!
Representative of the trust letter:_______ _ N. B.
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