Date-04.12.

2020

To,

The DCP,

PS……

Delhi

Sub: Complaint on behalf of complainant Sh. Manish Jain

against Sh. Rajneesh Kumar, Ms. Aditi Aggarwal and others
for committing fraud, forgery, fabrication of documents
against the complainant pertaining to property bearing (also
New Delhi-110002).

Respected sir,

I, Manish Jain S/o (late) Sh. Vijender jain, Delhi- the

complainant and would like to bring to your kind knowledge the
crime committed against him by the above mentioned accused
persons-

That the brief facts of the present case are as under:

1. That the complainant is the co-owner of the property

No.4466, Illaqa No.7 situated at, New Delhi as the said
property).
2. That the said property was purchased by the real
grandfather of the complainant, namely Sh. Shagun
Chand Jain in the year 1961 vide registered sale deed
bearing Doc No.5732, Book No. I, Vol. No.3240, pages
 211 to 218 and dated 28.10.1961. the copy of the said
registered sale deed is annexed herewith as annexure-P1
for your kind perusal.
3. That the said Sh. Shagun Chand Jain died intestate
(without writing any will) on 20.12.1988 and thus, the
suit property along with other joint family properties or
self-acquired properties or self-acquired properties of
said Sh. Shagun Chand Jain was inherited by his legal
representatives which includes father of the complainant
namely Sh. Vijender Jain being the real son of said Sh.
Shagun Chand Jain.
4. That the father of the complainant died interstate on
17.01.2013 and thus complainant inherited share in the
said property.
5. That the (late) Sh. Vijender Jain, father of the
complainant, during his lifetime had filed the suit for
partition before the Hon’ble court of Delhi against the
other legal representative of (late) Sh. Shagun Chand
Jain bearing suit No.199/2009 titled as Vijender Jain
Vs. Kanti Jain & Ors in which the Hon’ble high court of
Delhi was pleased to grant a stay order on the aid
property till the pendency of suit. The copy of the stay
order is annexed herewith as Annexure-P2 for your kind
perusal.
6. That one Sh. Rajneesh Kumar S/o (late) Sh. Suresh
Kumar on the basis of false and fabricated documents
claimed himself to be the owner of the said property and
fraudulently sold the said property to one Ms. Syed
 Neelam Akhtar. The copy of the GPA, WILL and the
receipt executed in favor of Ms. Syed Neelam Akhtar is
annexed herewith as Annexure-P3 for your kind perusal.
7. That when the complainant became aware of the said
crime the complainant made a complaint to concern
SHO, police station and on te complainant an FIR was
registered vide FIR No.178/2018 u/s 380/448/120B/34
IPC against said Sh. Rajneesh Kumar, Ms. Syed Neelam
Akhtar and others who are involved in the crime. It is
pertinent to mention here that thereafter, the police have
added sections 468/471 IPC in the said FIR on
30.05.2019. The copy of the said FIR and order whereby
Sections 468/471 IPC were added in the said FIR is
annexed herewith as Annexure – P4 (Colly) for your
kind perusal.
8. That now it has come to the knowledge of the
complainant that the abovementioned Sh. Rajneesh
Kumar have once again conspired with one Ms. Aditi
Aggarwal Delhi and have sold the said property to her
even after knowing the fact that an FIR had already been
registered against him and further violated the stay
orders passed by the Hon’ble Delhi high court as
mentioned above. It is pertinent to mention here that
Ms. Aditi Aggarwal is one of the associate and front
women of Sh. Rajneesh Kumar and i.e., why Ms. Aditi
had bought the said property without inquiring about
the said property which had already been illegal sold to
Ms. Syed Neelam Akhtar. The copy of the sale deed
 dated 20.05.2019 vide registration no.4428 in book
no.1, vol. no. 17920, page 49-55 is annexed herewith as
Annexure-P5.
9. It is pertinent to mention here that after the registration
of FIR no.178/2018 PS Darya Ganj, Sh. Rajneesh
Kumar absconded and was declared proclaimed
offender. That as Mr. Rajneesh could not come forward
so he in conspiracy with Ms. Aditi Aggarwal entered into
a sham transaction and sold the said property vide sale
deed dated 20.05.2019. further Sh. Rajneesh Kumar,
Ms. Syed Neelam Akhtar and Ms. Aditi Aggarwal and
hand in gloves to usurp the property of the complainant
as till date neither Ms. Syed Neelam Akhtar nor Ms.
Aditi Aggarwal have complained against Sh. Rajneesh
Kumar and the said intention shows that they brewed
the conspiracy together and acted together in
furtherance of their illegal.
10. That now it has further come to the knowledge of the
complainant that the above stated accused persons i.e.,
Sh. Rajneesh Kumar and Ms. Aditi Aggarwal in
conspiracy and connivance with each other once again
are attempting to sale the said property situated at New
Delhi-
11. That the complainant has also instituted a civil suit
against Sh. Rajneesh Kumar, Ms. Syed Neelam Akhtar
and Ms. Aditi Aggarwal in which the Hon’ble high court
of Delhi was pleased to pass an ex-parte stay order
 dated 25.08.2020. the copy of the same is annexed
herewith as Annexure-P6.
12. That the Hon’ble high court of Delhi has already
passed a stay order qua the said property and already
an FIR No.178/2019 is registered for fraudulent
transactions happened in regard to the said property.
But without fear of law Sh. Rajneesh Kumar again, on
the basis of false, forged and fabricated documents, sold
the said property to Ms. Aditi Aggarwal who is nothing
bit the front women of Sh. Rajneesh Kumar and once
again committed crime u/s420/464/467/471/120B of
IPC.

Thus, the complainant herein requests you to kindly lodge an FIR

against the above mentioned accused persons under section
420/464/467/471/120B of IPC and take strict action against the
above accused persons.

Thanking you,

Truly yours,

(Manish Jain)

New Delhi