ॐ नमः शिवाय

Plaint done
Written statement done
Legal notice done
Reply to legal notice done
Anticipatory bail partialy
Temprorary injuction
Sec 138
Sale deed
Contract
Writ
Divorce done

1. That the brief fact of the prosecution case revels from F.I.R. are as under:
The complainant Rajan Majumdar, aged 29 years, D/o Mahesh Majumdar R/o Deevan
Colony has lodged F.I.R. against the applicant on the 15th day of January 2022 at 5.00.
P.M. in respect of the incident that took place on the 15th day of January 2023 at 10.00
A.M.
The complainant has alleged that he has been an employee at Yashee's Veggie online
store, where he has shown himself to be an exceptionally hard-working worker.
It is alleged that during the last several months, the employees have been confronted
with a number of critical difficulties, including women's safety at the job, the serving
of unhygienic food in the office canteen, a lack of workers' compensation funds, and
many more. The complainant brought these concerns to the attention of his superiors
via an application dated the 16th day of December 2021 that was not reviewed.

The complainant further alleged that on behalf of all other employees, he sent an
email dated 30 December 2021 to Mr. Jayleela Bakshi, the senior executive of
Yashee's Veggie Online Store, regarding the issues at hand. However, he denied even
contemplating the matter in the first place and stated that they are not authorized to
investigate these matters.
 The complainant further alleged that he had obtained no response from the relevant
authorities despite sending many follow-up emails on the 2 nd day of January 2022, the
7th day of January 2022, and the 10th day of January.

It is alleged that the employees refused to show up to work for three days in protest of
the company's lack of responsiveness and the growing absence of safety measures for
women's safety and other issues.

It is alleged that when the complainant went out of his home for some household
work, a van came from behind and he has given blown by a sharp-edged weapon on
his head and back, and thereafter he fell and was assaulted by fist blows and at that
time he saw the faces of the assailants. After he slipped and fell, several nearby
residents allegedly stole his phone and chains. The complainant has alleged that 1)
Mr. Jayleela Bakshi, 2) Mr. Satish Pathak and some others were the person who
assaulted him.
The complainant further alleged that the accused thereafter took him near the house of
Applicant and he was thrown there thereafter Police came to the spot and he was
taken to the Rural Hospital. The statement of the complainant was recorded and the
offense was registered against the Applicant and others vide Lakhimpur Police Station
C. R. No. I – 123 / 2022 under Section 307, 392, 323, 405, 143, 144, 147 of IPC and
Section 54 of the Employee Rights Act, Section 13, 11, 12 of the Employee
Compensation Act and Minimum Wages Act.
Here to annexed and marked as “Exhibit – A” is the Copy of the said F.I.R. in
Lakhimpur Police Station C. R. No. I – 123 / 2022.

2. The Applicant states that the FIR lodged by the complainant is false and on the
contrary the complainant tried to outrage the modesty of Mr. Jayleela Bakshi and Mr.
Satish Pathak i.e., the senior executive and sales director of the company. They
contended that the complainant demanded high values of salary on behalf of other
employees which was not in benefit of the company and hence they rejected the plea
of the complainant. They further contended that they ignored to reply to the
complainant’s mail because they specifically mentioned their concern and reasoning
for not increasing salary in the reply to first application itself but yet again the
complainant kept texting mails replying which could have consumed a lot of time of
the company.
3. The Applicant stated that the complainant attempted and manipulated other
employees with the intention of making his demand more influential, and when
company officials rejected their frivolous application, the Applicant further tricked
the employees for a strike, which resulted in huge losses to the company's revenue
and profits.
 Applicant is the senior executive of yashes veggie online store
 One of the employees there wanted a hike in salary and approached the senior
executive multiple times but the applicant couldn’t do so because of the company’s is
not producing profit that much and the applicant has clearly stated the reason for not
increasing the salary then also the employee generated a lot of mails regarding the
same.
 The employee threatened the senior executive that in case he did not make the employee
requirement the employee will implicate the Applicant in some false criminal case.
 The employee started manipulating other employees and went on a strike of not
attending the office for about 3 days which resulted in huge loss to the company.
 On this date when the applicant went out for some household work he was suddenly
attacked by the employees as a result of which he fell down and sustained abrasion/injuries.
The local people of the market came to the rescue of the Applicant and with great difficulty,
the Applicant was saved from the clutches of employees by other passersby.
 That the police have registered a false FIR against the Applicant. A bare on perusal of the
said FIR reveals that the applicant attacked the employee and not viceversa. As a mater of
fact, the aggressor has manipulated with the police and has falsely implicated the Applicant.
The Applicant is in fact the victim at the hands of the Complainants who have conspired with
the police and got this case registered against them.
 That the FIR registered against the Applicant is absolutely false and incorrect. The Applicant
is not at all involved in the alleged offence and has been falsely implicated by the police.
That the Applicant apprehends that he may be arrested in pursuance of the aforesaid false
and fictitious complaint. 9. That the police officials have visited the premises of the Applicant
in his absence and there is every likelihood of his being arrested in the instant case. 10. That
the Applicant undertakes to join the investigation as and when directed to do so. 11. That
the Applicant is a permanent resident of Delhi and there is no chance of his absconding in
case he is granted anticipatory bail. 12. That the Applicant has never been involved in any
criminal case except the present one.