suspicion as the same lacks materials facts regarding the actual transaction. No reasons whatsoever have been offered by P.W-1 regarding the non-disclosure of such crucial and relevant aspects in Ext.P-3, complaint and in the proof affidavit. It has been held by this Court in K.K.Divakaran v. State of Kerala, reported in 2016 (4) KLT 233, that the accused in a criminal trial is essentially called upon to answer the gravamen of the charges and allegations in the complaint and that the complaint should contain the relevant and material facts of the alleged transaction, which led to the liability as well as regarding the execution of the cheque, etc., as otherwise the accused will not be properly equipped to defend himself in the criminal trial. This would amount the deprivation of the precious right of free trial. Suppression of material facts relating to the alleged transaction in the complaint, statutory demand notice, etc. has been held to be artifices used by dishonest litigants, with the intention to enable them develop a story after knowing the version that may be put up by the defence. This Court has clearly held that the doors of criminal courts should be closed to such fortune seekers, etc. it will be profitable to refer to paras 18 and 20 of the decision in K.K.Divakaran's case supra, which read as follows:
