BEFORE THE HON'BLE HIGH COURT OF DELHI AT NEW DELHI

CRL.M.C. NO. OF 2021

IN THE MATTER OF:

HARVIR SINGH ...PETITIONER

Versus

Central Bureau of Investigation and Ors. ...RESPONDENTS

INDEX
S.No
1. NOTICE OF MOTION �
Particulars
fry079r .I
r krvi l�
Page No.

t- .2-
2. URGENT APPLICATION
3
3. MEMO OF PARTIES
Lf-
4. SYNOPSIS, LIST OF DATES & EVENTS
s-- Jo
s. CRIMINAL MISCELLANEOUS PETITION UNDER
SECTION 482 OF THE CODE OF CRIMINAL
/J r- 22-
PROCEDURE
6. AFFIDAVIT IN SUPPORT OF THE PETITIONER
33 r-39
3�-YLt
7. Annexure A-1
Copy of the FIR bearing FIR No.
RC0032020A0014 dated 13/03/2020 PS.CBI
ACS Delhi
8. Annexure A-2 (Colly)
Copy of the various letter of awards for the
�S:-/o/
year 2018-19 and the work completion
certificate for the work orders awarded to the
accused contractor in the year 2018-19 dated
10.05.2019

9. Annexure A-3
Copy
/Dj_-/of
of the various Letter of awards
awarding state wise tender in favour of the
accused contractor for the period September
2019 to September 2020
10. Annexure A-4
Copy of the Wages payment sheet (NEFT
details), attendance sheet of labourers of
Purana Quila Garden for the month of June
2020
11. Annexure A-5
/11-/J-2-
Copy of the Wages payment sheet NEFT
details, attendance sheet for Qutub Minar
Garden, New Delhi for the month of June
2020
12. Annexure A-6
Copy of the details of the government money
embezzled in the maintenance work in Purana
Quila Garden in one month (June 2020) by
making false attendance of 48 labourers

13. Annexure A-7 / lj/- JS)

Copy of wage payment sheets and
attendance sheet for the month of March
2020 of Qutub Minar Garden, New Delhi &
April 2020 of Nalanda, Bihar

14. Annexure A-8

Copy of wage payment sheets and
attendance sheet for the months of April &
May 2020 of Humayun Tomb Garden, New
Delhi & 2 other gardens in Bihar
15. Annexure A-9 /sB-/63
Copy of wage payment sheets and
attendance sheet of Qutub Minar Garden,
New Delhi & different gardens of Nalanda,
Bihar for comparison
16. Annexure A-10
Copy of wage payment sheets
attendance sheet f or the months of April &
May 2020 of Humayun Tomb Garden, New
Delhi
17. Annexure A-11
Copy of wage payment sheets and
attendance sheet for 2 other gardens in Bihar
for comparison
18. Annexure A-12
Copy of the details of the government money
/B?/'J.,{:3
embezzled in Safdarjung Tomb Garden, New
Delhi along with the attendance sheet and
wage payment sheets
19. Annexure A-13
Copy of the letter dated 21.07.2020 seeking
extension of work for the year 2020-21
20. Annexure A-14
Copy of the letter dated 21.08.2020
Je,fl-
approving the extension of work for the year
2020-21 in favour of the accused contractor
21. Annexure A-15
Copy of the incomplete diary dispatch register
maintained by the accused Naresh Chand
22. Annexure A-16
;2.J?--23f:}
Copy of the ITR of the accused contractor for
the years 2016-17 & 2017-18
23. Annexure A-17
Copy of the details of the properties owned
by the accused along with photos of the
properties
24. Annexure A-18
Copy of the details of the government money
embezzled while procuring materials
25. Annexure A-19
Copy of the complaint sent by the Petitioner
J-rl-2&1"
to the Respondent dated 22.01.2021

2&g-),9'1/
26. CRL. MA. NO. OF 2021
Application Under Section 482 Crpc For
Exemption From Filing Certified/ Types/ Dim
Copies Of Annexures/ Documents along with
Affidavit
28. Court Fee 293
 BEFORE THE HON'BLE HIGH COURT OF DELHI AT NEW DELHI

CRL.M.C. NO. OF 2021

IN THE MATTER OF:

HARVIR SINGH ...PETITIONER

Versus

Central Bureau of Investigation and Ors. ...RESPONDENTS

NOTICE OF MOTION

To,

1. The Standing Counsel

Central Bureau of Investigation
New Delhi
2. The Standing Counsel
Union of India, Ministry of Home Affairs
3. The Standing Counsel
Govt. of NCT of Delhi
Sir,

This is to inform you that a Criminal Miscellaneous Petition is

being filed by myself in the registry of the Hon'ble High Court of

Delhi. Please receive a copy of the above said Petition for your

records. The petition will come-up for hearing on 23 ,C,2.-�_;}.f;Y.,l

on which date you may kindly be present in the court to assist this

Hon'ble Court.

MI�� J�:� &ANNANYA NAYYAR & AJIT

D/2311/2016 & D/2397/2020
t���"l-- !
'.19:,o

B-35, Lower Ground Floor,

Defence Colony, New Delhi-110024
#9916633966

PLACE: NEW DELHI

DATED: 1.02.2021
 Keshav saini <keshavsaini.law@gmail.com>

Proof of Service 293

ADVANCE SERVICE OF ALL RESPONDENTS
1 message

Keshav saini <keshavsaini.law@gmail.com> Tue, Feb 23, 2021 at 2:24 PM

To: delpol.service@delhipolice.gov.in, hozac@cbi.gov.in, hshso@nic.in

Sir,
Kindly please accept the advance service of the Fresh Crl.MC NO. OF 2021, titled as Harvir Singh Versus Central
Bureau of Invetigation and Ors.which was approved for urgent listing, likely to be listed on 24.02.2021.
Sincerely,

MISHAL JOHARI & AJIT JOHER

Advocates
B-35, LOWER GROUND FLOOR
DEFENCE COLONY
New Delhi-110024
Ph:9926633966

CRIMINAL MC HARVIR SINGH VERSUS CBI_0001.pdf

17564K
 //
BEFORE THE HON'BLE HIGH COURT OF DELHI AT NEW DELHI

CRL.M.C. NO. OF 2021

IN THE MATTER OF:

HARVIR SINGH ...PETITIONER

Versus

Central Bureau of Investigation and Ors. ...RESPONDENTS

CRIMIAL MISCELLANEOUS PETITION UNDER SECTION 482 OF

THE CODE OF CRIMINAL PROCEDURE PRAYING FOR
ISSUANCE OF DIRECTIONS TO THE RESPONDENT TO
CONDUCT A PROPER AND FAIR INVESTIGATION BY AN
OFFICER NOT BELOW THE RANK OF SUPERINTENDING OF
POLICE IN THE MATTER EXPOSING THE SCANDAL OF NEXUS
AMONG THE ACCUSED PERSONS AND SUCH OTHER OFFICIALS
OF CORRUPTION AND REGISTRATION OF FIR NO.
RC0032020A0014 PS. CBI ACB DELHI FOR THE OFFENCE
UNDER SECTION 1208 R/W 420 IPC AND SECTION 13(2)
R/W 13(1)(0) OF THE PREVENTION OF CORRUPTION OF ACT

MOST RESPECTFULLY SHOWETH:

1. That the Petitioner is a law abiding citizen of India is aggrieved

by the inaction of the respondent. The Petitioner is aggrieved by

the non-implementation of the statutory duty bestowed by law

upon the respondent of conducting a proper and fair investigation

in the matters of corruption.

2. The petitioner came to know and got some documents which

establish massive corrupt practices causing wrongful loss to ASI

and wrongful gain to accused persons and such other officials.

The documents and allegations need serious investigation to

Annexure A-9
293