Dairy Internship.....

DELHI INSTITUTE OF RURAL DEVELOPMENT
GURU GOBIND SINGH INDRAPRASTHA UNIVERSITY,
SCHOOL OF LAW AND LEGAL STUDIES
Internship Report
Submitted For:
Course Code – LLB 504 (Internship Law Firm)
VIPUL KUMAR
52222403517
Internship Report
2022
 A Brief Account of:
PLACE OF TRAINING
I have completed my Internship under the Advocate D. N. Chaturvedi having

office located at H 108, Asiatic Building, Connaught Place, New Delhi 110001.
I acquired immense Knowledge under his supervision and learned a lot about
the Court Procedures as how to file a case and how the defects are being
removed from the file as well as how much court fees are required to affix in the
case files, lawyers’ behavior in the court, how to deal with the clients, rule of
court and also the respect of the Court. He provided me with minutes details of
the case and helped me in understanding the complexities of the cases. During
the course of my internship, I appeared regularly in the district court of Delhi
(Saket Court, Patiala House Court, Tis Hazari Court, Karkardooma Court,
Rohini Court, Dwarka Court), and Faridabad District Court as well as Greater
Noida Court for the purpose of various cases. I also handled some work in filing
cases in the various Tribunal in Delhi such as CAT (Central Administrative
Tribunal), NCLT (National Company Law Tribunal), NCLAT (National
Company Law Appellate Tribunal) etc.
THE INTERNSHIP EXPERIENCE – Reasons for the choice of the Firm
I have finalized my internship under Advocate D N Chaturvedi from the month

of January 2022 and it was a great learning experience for me. The internship
gave me the opportunity to look inside the judicial system and its works. I dealt
with people directly and looked into their problems under the able guidance of
Advocate D N Chaturvedi. I visited different Courts in regard to different
matters fixed in courts in the daily routine where I got an opportunity to observe
their working. It was a valuable insight into the actual working of courts and
lawyers. Not all legal acts happen in courts, a lot of legal minds is applied
behind the canvas of court, inside a lawyer’s chamber. A great deal about
planning, counseling, legal drafting, brainstorming, and record maintenance is
taken up by a lawyer to make a good case. In the company of Advocate D N
Chaturvedi, I was able to get an insight into the nitty-gritty involved in
preparing a case. With his permission, I was able to observe the manner in
which client counseling is done. Besides this, I was able to learn about carrying
out legal research, the study of case files of running cases, and preparing draft
documents of real cases in hand. It was a rich experience working in courts and
our judicial system and the role of a lawyer in the delivery of justice.
I have reasons to choose this firm is that this firm named CORPORATE JUDIS
LLP has all the cases in their table whether it is related to the Civil Case,
Criminal Case, White Collar Crime like ED (Enforcement Directorate) cases,
NCLT & NCLAT Matter (Insolvency Case), etc. So, it’s a great opportunity for
me to work with this firm to enhance my knowledge in the Legal field.
RESULTS – What Could the Student Learn from the Internship
As I completed my internship under the guidance and supervision of Advocate

D N Chaturvedi. He is running a firm named as CORPORATE JUDIS LLP and
as I imparted earlier that in his firm there are mostly all the matter/cases present
to learn and enhance a knowledge in every aspect of the Legal Field. So, I tell
you, what I learn from the internship:
Thus, I am a new comer in the legal field and the first-generation lawyer, I don’t
have any basic knowledge in the legal field, after joining this internship or
working under the supervision of my Sir. Now I learned many things like filing
of new cases, drafting a complaint as well as suit and petition, how to manage a
client or how to do client counselling, management of number of cases in a
single day, reading of existing files, research works, filing of appropriate
application on the correct time to seek the justice from the hon’ble courts and
the main important thing which I learned during the period of my internship is
that how to appear confidently before the Hon’ble Court and also the one
important point I want to include in this which I learned during this tenure of my
internship is that never afraid of doing Revision/Appeal against the illegal or
irregular order of any judicial authority on their own cost if party is unable to
pay, it will helpful for own experience.
Accordingly, the above-mentioned thing which I learned during the period of

my internship.
How many hours per week the student spent with the Lawyer/ Firm?
As I worked during my internship period with the Full Time Litigation Firm. So,
there is no fixed time for an Advocate as well as intern but there is some
relaxation for the intern such as Me, was that I can leave the office whenever I
finished the work which is assigned to me but I never do this. I stay in office till
the sir and other advocate remain, I leave the office with them. So, I spent
approximately 9 hours to 10 hours in a day and the timing was 9:30 AM to 7:30
PM because in the morning I appeared with the Sir in the matter which was
listed in that day after that we moved to the office and do work in the matter
which is listed on the next date such as preparing appropriate application such as
Preponement application, exemption application, etc., which were required in
that matter and also attend the client with sir during these office hours and in the
remaining time when I don’t have any assigned work then I read the existing
case files. So, if I calculated the hours which I spent with the firm was in a
single day approximately 9 hours to 10 hours and if I calculated hours on the
weekly basis, it is near about 54 hours to 60 hours. These timing hours were not
fixed it may vary on the pendency of work sometime this time may increase or
sometimes this may decrease but the above- mentioned timing was the generally
daily spent hours.
Case – 1
IN THE COURT OF HON'BLE CHIEF METROPOLITAN

MAGISTRATE, SOUTH, SAKET COURT, NEW DELHI
CC No. of 2022
IN THE MATTER OF:
Smt Shally Vashisth … Complainant

VERSUS
M/s Bulland Realtors Pvt. Ltd. & Ors. …Accused(s)
Police Station: - EOW
CRIMINAL COMPLAINT UNDER SECTION 156(3) OF THE CODE OF

CRIMINAL PROCEDURE, 1973, FOR THE OFFENCE OF INTER ALIA,
CRIMINAL BREACH OF TRUST, CHEATING.
MOST RESPECTFULLY SHOWETH: -
1. That the Complainant i.e., Mrs Shally Vashisth wife of Yogesh Vashisth
having resident at A-626 Raghuvir Nagar, New Delhi -110027 have to
make following complainants against Accused mentioned above.
2. That sometimes in the month of January 2017, the Complainant receive
a phone call from one Shri Sunil Nagar, over her mobile from one Mr.
Sunil Nagar claiming himself to be the chief executive of the company
mentioned of the subject proposing an offer of sale of residential
property from the company/developer mentioned in the subject this call
was received by me when I was at my residence at Raghuvir Nagar.
3. That the said Sunil Nagar give me the detail of the property situated in
sector 10, GREATER NOIDA. In addition to the facts insisting that the
property was strategically located it was also emphasized that the
property
had added attraction of being in the same compound and was connected
as / annexed immediately to the famous chain of commercial mall and to
be called by the name “CALISTO” GREATER NOIDA and the project
sell residential and retail/commercial spaces. Prior arid after to be the
other sited conversation there were advertisement of the kind with the
intention of communicating that was intended be conveyed to me on
phone by Shri Sunil Nagar.
4. That the undersigned complainant would off and on get calls from Mr.
Sunil Nagar empathizing upon to make investment in their above project
as the project had a big potential of being high and customer-oriented
complex at as the same would attract not only the customers from the
residential sectors but also the commercial space. In addition to the
above, it was also empathized to lead the bonafide, that the company
would be given assured return of three present 3% per month for 24
month or the completion and handling over the project. Without sensing
the trap of the developer, the undersigned accepted to have a physical
look signed. the continued calls from the company chief executive
namely MR. SUNIL NAGAR were aimed at alluring me to fall prey to
their design. During conversation it was also stressed upon me that the
project was looked over Greater Noida and the company had the
credential of having built up side like “Bulland Height” “Bulland
Elevate” and had the background of having built up many projects.
5. That These telephonic conversation were also followed by information
literature and brochures from the company which were received at my
residence at Raghubir Nagar because of the luceration and salesman ship
,the undersigned believed upon the express and implied assurances and
explanation of the company representative ,ultimately landed into make
the investment in the project of the builder and the developer named in
the subject by the named called Bulland Calisto, Greater Noida and the
delivery of the project was assured to be March 2018, after completion
and the complainant thus subscribed to invest in a retail unit by the
number 905 in the Block C, measuring 850sq.ft. [super area ] .this
initiation of the investment was followed by payment of
RS.20,00,000 in cash
,subsequently followed by an agreement and paying of the total
Consideration . After the payment the mentioned above, the assured
return of 3% Pm, started to be received by the undersigned applicant till
December. 2018 when there was the receipt of a communication from
the developer at the residence of the complainant that the undersigned
could take the possession of the booked unit. In view of the
communication from the builder, the undersigned visited the site and to
the utter shock of the undersigned applicant .it was found that neither the
residential/commercial space centre was complete, nor the said
COMMERCIAL SPACE was there. The basic and primary consideration
of the undersigned applicant was the rosy picture of the RESIDENTIAL
CUM COMMERCIAL SPACE being annexed to the
residential/commercial space i.e., the Complex and mall concept and
there does not seem to be any possibilities in the near future of any
RESIDENTIAL/COMMERCIAL SPACE coming up as an annexed
building to the commercial/residential space. The facts that the builder
through its representative as well as on their own through verbal
communication, as per brochures, ads and written/visual representative
on web sites have all together represent the total unit on a single plot
consisting of residential space and commercial space as single unit
which was to allure gullible investor resulting into making their hard
earned investment into their project called ‘ Bulland Calisto’ had the
builder on their own or through their representative not misrepresent the
fact mentioned above . that the representation fake /untrue to the
knowledge to the accused person at the time when it was made. that
the complaint
parted with his property acting on the representation which was false to
the knowledge of the accused and that the accused had a dishonest
intention from the outset. That the accused had induced the complainant
to part with property and was case of unjust enrichment by accused
person by playing a deceit with the complainant.
6. That the circumstances show that fraudulently /dishonest intention was
right at the beginning of the transaction time. That the investment was
made on account of the fake representation to the complainant i.e., the
delivery of the cheques so in cash by the builder /developer which were
the consequence of the deception played upon the complainant. That the
intention and acts of the accused person were DISHONEST and done
with the intention of causing wrongful gains to themselves and wrongful
losses to the undersigned. In view of the fact mention above it is the
request that a criminal case under appropriate section of law be
registered against the promoters and his co-conspirators /associates in
the act mentioned in the aforesaid paras.
7. That when the complainant wants confirm of true status of his unit no,
accused person provide satisfactory reply thereafter complainant visited
accused company Noida site office find out the said project to be
abandoned no work at site since long time office because of finance
difficulties after discussed Mr Sunil Nagar they given a piece of paper
which was reflected my name as an investor, along with my payment
duly sign by Mr Sunil Nagar.
8. When the complainant discovery of Company Statutory Auditor Report
at ROC, site complainant outstanding was not reflected in the balance of
Company. However, the statutory auditor has misused his powers and
cheated Investors of company and misused his professional capacity as a
Chartered Accountant by misappropriating and by falsification of
accounts. The copy of the annual report for financial year ,2011-12,
2012-
2013, 2013-14, 2014-15,2015-16, 2016-17, 2017-18 are enclosed
herewith as Annexure.
9. That CA M K Jain collusion With Managing director Mr. Rajnish Nagar

played a very active role with common intention and connivance with
each other in a very pre-planned and well-designed manner having
dishonest intentions since beginning with criminal intent, hatched a deep
rooted criminal conspiracy and furtherance of such criminal conspiracy,
the CA M K Jain and Sunil Nagar ousted the complainant from the
company namely Ms Bulland Realtors Pvt. Ltd or M/s Bulland Builtech
Pvt. Ltd. and duped hardened money of the complainant and gulped the
allotment of Units causing wrongful loss to him and wrongful gain to
themselves.
10.That for the purpose of criminal breach of trust, cheating and

dishonestly inducing for the delivery of property, forgery of documents
and forgery for the purpose of cheating with a prior meetings in mind
with others having criminal conspiracy and other criminal acts done by
him along with others for running the business of money laundering and
speculative business for making easy money by befooling the public and
black mailing the people not only this he has shown him as Director in
the company of the applicant i.e. M/s Bulland Buildtech Pvt. Ltd as well
as M/s Bulland Realtors Pvt. Ltd. However, no consent was given by the
applicant while he being the promoter Director of the above-mentioned
company. The copies of the details of the Directorship reflecting the
name of the CA MK Jain along with other Directors are already
enclosed.
It is a serious multi corer fraud that requires fact finding investigation .in
the light of the above facts and circumstances.
11.That the Accused persons were acting in connivance and collusions
upon having their hand in glove with each other for their wrongful gain
and causing huge wrongful loss to the Complainant and was in
agreement with pre mediated mind to commit the said offences.
12.That the Accused person has committed the said offences and thus the
offences are involving mensrea/guilty intention. A thorough
investigation must be required to be conducted by the police which can
be done only after registration of the FIR to trace the trail of the money.
13.That the Accused persons in a very pre-planned, well-designed and
mercenary manner with dishonest intention since beginning with
criminal intent, hatched a deep-rooted criminal conspiracy and in
furtherance of such criminal conspiracy, the Accused persons planned to
oust the Complainant from its hard-earned money causing wrongful loss
to Complainant and wrongful gains to themselves.
14.That a complaint with respect to the aforesaid acts of the Accused
Persons has been made to the DCP, EOW however no action has taken
place till date. Copy of the said complaint is annexed herewith.
15.That the Accused person has committed offences under various sections
of Indian Penal Code and thus the offences are involving mensrea/guilty
intention. A thorough investigation is required to be conducted by the
police which can be done only after registration of complaint also to
deter the accused persons from committing further offences against the
Complainant.
16.That the Hon’ble court duly exercises its jurisdiction over the said acts
of the Accused person as the office of accused person is in Khanpur,
New Delhi is within the jurisdiction of this Hon’ble Court and therefore
this court is the appropriate forum to contest this complaint.
17.That the cause of action arose every time when the complainant paid
monies against the purchase of said property.
18.That the Complainant is left with no other alternative except to approach
this Hon’ble Court for the redressal of his grievance to bring the
Accused person to book for the offences committed by him resulting in
blatant violation of the law.
PRAYER
In the foregoing facts and circumstances of this case, it is most humbly
prayed before this Hon’ble Court that it may graciously be pleased:
a. To issue Directions under Section 156(3) of CrPC to the concerned
S.H.O. for the registration of an F.I.R. against the Accused Persons
under appropriate Sections;
b. To direct the concerned Police Authorities to make the consequent
investigation and submit the report;
c. Pass any such other or further order(s) as this Hon’ble Court may deem
fit and necessary.
COMPLAINANT
Through
(UDIT NAGAR) (DEEPAK SOMANI)

(Counsels for Complainant)
Chamber No. , Patiala House Courts
Place: New Delhi New Delhi-110001
Date: .02.2022 Ph-
Email:
CASE – 2
IN THE COURT OF HON’BLE CHIEF METROPOLITAN

MAGISTRATE, CENTRAL, TIS HAZARI COURTS, DELHI
CC NO. Of 2021
IN THE MATTER OF:
Manojit Bera …Complainant
Versus
M/s Bhunia Jewellers Pvt. Ltd & Ors …Accused(s)
COMPLAINT UNDER SECTION 138 READ WITH SECTION 142 OF

NEGOTIABLE INSTRUMENTS ACT, 1881 AS AMENDED UPTO
DATE
Most Respectfully Showeth: -
1. That the complainant is a law-abiding citizen who embodies humanism of its

highest nature.
2. That the complainant is a Jeweller and is serving in this niche for ample
period hence possess colossal experience along with fabled ancestry. Moreover,
complainant has maintained rapport and business relations with accused persons
for a significant period as both are in the field of jewellery and daily transactions
in regards to sale and purchase of raw gold used to occur and it goes without
saying the business happens on credit. Furthermore, accused persons purchased
850 gm gold worth Rs. 45,00,000/- on from complainant. Copy of the bill is
annexed herewith as ANNEUXRE A-1 .That complainant, as per the deal,
provided accused persons gold of robust quality and subsequently expected to
be paid for the gold after the delivery; however accused persons imparted
complainant about their financial instability at that time with an assurance to
pay the entire amount within a fortnight. Furthermore, complainant, under the
impression of being paid and on account of business rapport, granted accused
persons leave to pay the amount within two weeks.
3. However, after the elapsing of the assured period and owing to no intimation
from accused persons, complainant endeavored to communicate with accused
persons regarding the payment, which accused persons deliberately avoided
time and again. That since the payment is due, complainant has approached
accused persons sporadically for payment of his dues and to disrupt accused
persons vexatious fiscal comatose against his claims however, every time he
imparted his grievances to accused company and accused persons personally but
sadly they all castigated by nodding in negative to entertain his issues in a
healthy and bonafide manner, which is deplorably unprofessional on accused
personsr part.
4. That the complainant in the interrengum was in dire need of finances

furthermore he claimed her money from the accused persons to maintain her
accounts in those testing days however accused entrenched behavior was intact,
further demolishing her optimistic attitude.
5. It was only after a significant passage of time, accused persons paid heed to
complainant’s claim and issued three cheques, details of which are arrayed
below:-
DATED CHEQUE AMOUNT DRAWN ON DISHONORED

NOS. ON
06.07.2021 504608 15,00,000/- SYNDICATE 07.07.2021

BANK
08.07.2021 504607 15,00,000/- SYNDICATE 09.07.2021
BANK
08.07.2021 504609 15,00,000/- SYNDICATE 21.07.2021
BANK
TOTAL Rs.
45,00,000/-
Furthermore, on presentation, in the bank account maintained by

complainant in her bank i.e., Yes Bank, Plot No. 1085 C,No-T, Arya
Samaj Road, Karol Bagh, New Delhi – 110005 on 06.07.2021 all the said
cheques were dishonored by the clearance branch with remarks “Funds
Insufficient” & “Payment Stopped by Drawer”. Original Cheques are
annexed herewith as ANNEXURE A-2. CTS Return Memo is annexed
herewith as ANNEXURE A-3.
6. That the complainant was in dismay and witnessed a situation of a

conundrum after the intimation by the bank regarding dishonor of all the
cheques which he bonafidely presented to his bank opining to accused
persons false promises.
7. It is imperative to state, that the Accused had deliberately given the

cheques in question to the Complainant with criminal heed from the very
inception for not paying the debts which they owed to the Complainant
which is conspicuous from their actions/inactions.
8. That under compelling circumstances, the Complainant was

constrained and left with no other option but to take recourse of his legal
remedies to abate his inter alia, mental, financial sufferings exercising
which he served a legal notice dated 28.07.2021 to the Accused persons,
at his registered address hereinbefore mentioned to make the payment
within 15 days of the receipt of the said notice, failing which appropriate
criminal proceedings would be initiated against him. The True Copy of
the Legal notice dated
28.07.2021 is annexed herewith as ANNEXURE A-4. Moreover reply
against the said notice dated 23.08.2021 received on 25.08.2021
categorically focusing on belittling the claim of the complainant by
exonerating themselves from any liability against the said cheques. It is
pertinent to note that the Accused No. 2 and 3 resides within the same
property despite which the Accused No. 2 has been served and Accused
No. 3 service is deliberately avoided by her. Importantly, the tenuous
counter of the accused persons exhibiting misplacement of the cheque
book is hit by their own assertions as if at all that had been the case in no
manner the cheques would had possessed the signatures of the accused
person which crystallizes the discrepency in their primarily relied claim.
Furthermore the other claim of lodging NCR is a scripted attempt at
reciprocating the liability on the complainant which gets further
crystallized by non mentioning of the date of NCR in the reply, seemingly
the NCR was lodged after receiving of the complainant’s notice with
harbored malafide of indicting the complainant by conveniently abusing
the process of law. The copy of said reply is annexed herewith as
ANNEXURE A-5.
9. That the Accused persons have failed to pay the amount of the
dishonored cheque within the stipulated period of 15 days after receiving
the legal notice and even till date.
10. That the above-stated acts on the part of the Accused; were done with
a deep-rooted criminal intent and thereby have committed an offense
punishable under Section 138 of the Negotiable Instruments Act, 1881 as
amended up to date and shall be indicted for the same.
11. That the said complaint has been filed by the Complainant within the
stipulated period of limitation as provided under the act, hence, it is
maintainable before the Hon’ble Court.
12. That the complaint is within the jurisdiction of this Hon’ble Court as
the Cause of action has arisen when the cheque in question on the
assurance of the Accused Persons were presented by the Complainant in
the bank account maintained by the accused in Yes Bank, Plot No. 1085
C,No-T, Arya Samaj Road, Karol Bagh, New Delhi – 110005, they got
dishonored which is within the jurisdiction of this Hon’ble Court.
. PRAYER
In the foregoing circumstances, it is most humbly and respectfully prayed

that this Hon’ble Court may graciously be pleased to:
a) Pass a decree of Rs. 45,00,000/- with up to date future interest @18%
p.a. in favour of the Complainant and against the Accused in the
interest of justice;
b) Pass an order directing the accused person to be summoned, tried, and
be punished in accordance with the law for the offense committed
under the relevant provisions;
c) Pass an order under section 357 Cr.P.C directing the Accused to pay
compensation along with Rs.50,000/- as Litigation expenses;
d) Pass any other order/s which this Hon’ble Court may deem fit and
necessary in the interest of justice.
COMPLAINANT
Through
Date:
Place: New Delhi (Counsels for Complainant)
Chamber No. , Patiala House Courts,
New Delhi- 110 001
Ph-
Email:
CASE – 3
IN THE HON’BLE HIGH COURT OF DELHI, AT NEW DELHI

CRL. M.C OF 2022
(UNDER SECTION 482 OF CODE OF CRIMINAL PROCEDURE 1973)
IN THE MATTER OF:
Delhi Tamil Education Association …Petitioner
Versus
State of GNCT of Delhi & Anr. …Respondent(s)
PETITION UNDER SECTION 482 OF THE CODE OF CRIMINAL
PROCEDURE, 1973 IS BEING PREFERRED ON BEHALF OF THE
PETITIONER AGAINST THE IMPUGNED ORDER DATED 18.02.2022
PASSED BY MS. AMARDEEP KAUR, LD. METROPOLITAN
MAGISTRATE-06, NEW DELHI, PATIALA HOUSE COURT.
TO,
THE HON’BLE CHIEF JUSTICE AND

THE OTHER COMPANION JUDGES OF
THE HON’BLE HIGH COURT OF DELHI, AT NEW DELHI.
THE HUMBLE PETITION OF

THE PETITIONER ABOVE NAMED.
MOST RESPECTFULLY SHOWETH:
1. That the present petition under Section 482 of the Code of Criminal
Procedure is being filed against the order dated 18.02.2022 passed by
Smt. Amardeep Kaur, Ld. Metropolitan Magistrate-06, Patiala House
Court, New Delhi (Henceforth referred as “Magisterial Court”) in CC No.
40029 of 2016 titled as M/s Mallick Brother V. Delhi Tamil Education
Association wherein the Ld. Magisterial Court, has dismissed application
under section 311 of the Code of Criminal Procedure filed by the Accused
No.1/Petitioner.
2. The True Copy of the Impugned order dated 18.02.2022 passed by the
Hon’ble Magisterial Court is annexed herewith as Annexure No. P-1 to
this petition.
3. That no other petition has been filed by the Petitioner against the
Impugned order and, in any court of law.
4. That no caveat is received in this matter.
5. That the impugned order has been passed by the Hon’ble Metropolitan
Magistrate, Patiala House Court subordinate to this Hon’ble Court which
is within territorial jurisdiction of this Hon’ble Court, conjointly clothing
the requisite jurisdiction to entertain and adjudicate the present lis.

Brief Facts
6. Those brief facts, in whose backdrop the present petition, is being filed,
may be delineated thus:
6.1That the Petitioner is an association of Tamil people, whose object is to
disseminate education/knowledge to underprivileged Tamil students with
aid from the Government.
6.2That on 12.07.2010, the Respondent No. 2 had filed a complaint case
under section 138 of the Negotiable Instruments Act,1881, against the
Petitioner/Accused No. 1 which is pending before the Court of Ms.
Amardeep Kaur, Ld. Metropolitan Magistrate-06, Patiala House Court as
C.C No. 40029/2016 titled as M/s Mallick Brother V. Delhi Tamil
Education Association & Anr.
6.3 That the said complaint case was filed by the Respondent No 2 in
connivance of the other Accused Person(s) in order to siphon of
association’s fund. The then office bearers, had issued cheques to the
Respondent No. 2 sans any liability, evidently to obtain unlawful gains
out of the consolidated funds of the association by creating a win-win
situation for both the sides.

6.4 On account of jurisdictional segregation, the matter was transferred to
Patiala House Court from Saket Court on 12.10.2015. Moreover, on
30.10.2019 the Respondent No. 2 exhibited their wish to not lead any
further evidence therefore Complainant evidence was closed on the
said date.
6.5 On 17.12.2019, the accused persons severally filed their statements
under Section 313 of the Code of Criminal Procedure and the same
were taken on record. Thenceforth the erstwhile counsel for Petitioner
had not effectively briefed about the status of the matter till the
Petitioner engaged the present counsel on 02.12.2021.
6.6 On 03.12.2021, the present counsel for the Petitioner filed their
Vakalatnama before the Ld. Magisterial Court, and apprized the Ld.
Magistrate about their recent engagement and sought some time to
prepare their defence however the Ld. Court belittled the justifiable
request of the counsel and closed the right of Petitioner to lead any
evidence.
6.7Thereafter, the Petitioner moved an application under section 311 of the
Code, which was dismissed by the Ld. Magisterial Court vide order dated
18.02.2022. Notwithstanding sincere endeavours from the counsel for the
Petitioner to convince the Ld. M.M to look into the malice with which the
accused persons and the complainant had issued

the cheques however the Ld. Magisterial Court belittled the
submission and exhibited her disinclination to recall any witness
therefore dismissed the application.
7. The invocation of the jurisdiction has been occasioned in the present case
when the Ld. M.M has passed the impugned order dated 18.02.2022
having effect of dismissing the application under section 311 of the
Code.The said application under section 311 of the Code is Annexure
No. P-2 to this
petition.
8. That in the light of facts pleaded above, there is no other efficacious or
alternative remedy than to approach this Hon’ble Court.
9. That the petitioner urges following grounds, independent of and without
prejudice to one another, as under:
GROUNDS
a. Because the Impugned Order passed by the Ld. M.M, being in
violation of established principles of criminal procedure as well as
judicial discipline, is wholly illegal and deserves to be set aside on this
ground alone.
b. Because the impugned order is based on conjectures and surmises and
the same is against the valid and admitted principles of law.

c. Because the Ld. M.M has not bestowed her due consideration on the
material facts and evidence in the present case which clearly reflects
the inter alia malafide; connivance between the Complainant and
remaining Accused(s)/Respondent(s) barring Accused No. 1.
Therefore impugned order dismissing Section 311 application of the
Accused No. 1 is unjust and legally illogical.
d. Because The Ld. Magisterial Court belittled the purpose of section 311
of the Code which is to recall any witness who hold even remote
material in the case for the just decision.
e. Because The Ld. Magistrate over looked the connivance with which
the complainant and the other Accused Persons have endeavoured to
siphon of the funds of the Association by issuing cheque against no
liability.
f. Because Ld M.M has failed to appreciate the fact that the defence
evidence has begun on 17.12.2019 and the next date notified was
27.01.2020. On the said date the then Ld. M.M was with in occupied
board and therefore the matter was listed for 17.03.2020. On the said
date the list of witnesses were to be filed by the Counsel for the
Petitioner. Thereafter the deadly pandemic has intervened and
evidences before the court could not have effectively taken place
furthermore the peculiar feature of this case has been grossly
overlooked by the Ld. M.M in as much as the fact:

a. The report of fact finding committee clearly indicates that there
has been gross diversion/siphoning of fund by the Accused No 4
to 6 who were then in management of DTEA by adopting the
modus operandi wherein a vendor like the de facto complainant
raises bills without doing any work and the said bills are
approved by said Accused No. 4 to 6 without any authorization
or sanction by the governing body. The consequence of such
modus operandi was the fact that the accumulated funds of
DTEA were wiped out secretly by Accused No. 4 to 6 and in
doing so the persons like de facto complainants have acted in
concert with said accused(s) to cause unlawful loss to
DTEA/Petitioner and unlawful gain to accused no 4 to 6 and the
said de facto complainant.
b. In as a much as the fact that due to adoption of criminally
coloured methods the funds of DTEA in the financial year 2005-
06 was Rs 8765492.66 and within next four years the same is
reduced to Rs 238604.67 and further in the next year i.e. 2009-
10 it became negative with a loss of Rs. 3400833.69 for the
same no cogent reason has ever been given by Accused No 4 to
6 who were holding the purses of petitioner.
c. In such circumstances it is not far to overlook that in the instant
case, where there is no authorization from governing body or
there is no record available with the DTEA/Petitioner in relation

to alleged work done by the de facto complainant coupled with
the fact that the complaint itself is conspicuously silent on the
aspect of exactitude of work done, situs of said completion of
work, person (under whom/controlled) employed by DTEA
overseeing the work and any other document except the one
which was prepared in concert with Accused No 4 to 6. In such
circumstances in inescapable obvious conclusion is that the de
facto complainant and the accused no 4 to 6 and hand in glove
to fasten the unlawful liability upon the Petitioner.
d. The funds of petitioner are not private funds rather a public fund
in the sense that the same are ear marked for the purpose of
larger benefit to society by imparting education to particular
community and citizen at a large and where such manipulations
and fraud are apparent to judicial eye, the same must be
unearthed so as to disable the pernicious design to clog the
process of justice.
e. The observations contained in penultimate paragraph of
impugned order is clearly in teeth of settled law as the identity
with petitioner no. 1 and that of accused no 4 to 6 are clearly
misplaced. The logic attributable founded on article 20 (3) of
the Constitution is untenable in as much as the fact that if the
application under section 311 would have been allowed the
same would have not affronted the rights of any other accused.
To the
contrary this would have enabled the LD. M.M, in her voyage to
unearth the truth to form an opinion qua the conduct/
misconduct of accused no 4 to 6 and the same would have
essential bearing on the question of liability qua any debt or
otherwise under the cheque in question. With respect the Ld.
M.M has not appreciated the fact that petitioner/DTEA is a
society and is represented by an AR, who is neither signatory to
the cheque nor was a participant in the process of issuance of
cheque. The outcome of proceedings under section 138 of NI
Act, either way, would impose or mitigate the liability of
society/DTEA and would impair or save its funds which is ear
marked for community purpose. The management at present is
duty bound to protect the repletion arising out of misdeeds of
erstwhile management and therefore the application under
section 311 of the Code was to curb the mischief.
f: Because the Ld. M.M has failed to appreciate the fact the
purpose of application under section 311 was to recall the
witness for his evidence the case thereof was the further
enquiries/proceedings/developments undertaken after the report.
The detailed arguments were addressed in relation to import of
report of fact finding committee however none of those

arguments were adverted to by the LD. M.M despite the fact the
said report was in annexure to the application under section 311.
Only in the event of success of application the accused/de facto
complainant would have been confronted with the documents
found pursuant to report of fact finding committee. The
document sought to be confronted with were essentially a new
discovery. The erstwhile counsel for petitioner was not in
position to advice the petitioner on those aspects and it is
unreasonable to impute upon petitioner that it would be in
knowledge of the intricate judicial proceedings in relation to
purport import and comport of specific documentary evidence/
records.
g. Because the Ld. Magistrate took notice of the fact that the
Accused No. 1/Petitioner failed to lead evidence for two years,
however this lethal hiatus had happened because of the
lackadaisical approach exercised by the erstwhile counsel for
the Accused No. 1/Petitioner as he kept the Accused No.
1/Petitioner under impression that the proceedings are kept on
abeyance on account of pandemic and Accused No. 1/Petitioner
will be duly apprized if and when they are required to be present
before the Court however Accused No. 1/Petitioner were never
called on by their erstwhile counsel. It is writ large that the
Accused No.
1/Petitioner failed to put forth their defence because of their
earlier counsels therefore it will be terribly unfair if the Accused
No. 1/Petitioner be made scapegoat of their former counsel’s
non- diligent conduct.
h. Because the present matter emanates out of profound malice
exercised by the Complainant and the remaining Accused
Persons as, firstly the complainant was never engaged by the
Accused No. 1/Petitioner to undertake work as claimed by the
complainant in its complainant. And the fact that no tender
agreement/contract has been exhibited by the complainant
before the Ld. Magisterial Court further testifies to it. The only
reason these cheques were issued to the complainant was
because the other accused persons were apprehensive of their
imminent defenestration from the post of office bearers and in
order to siphon of association’s funds before they lose their
positions, they had issued the cheques to the complainant with
caveat that the amount will be enjoyed both by the complainant
and the remaining accused persons, which crystallizes the
strategic malafide behind the issuance of cheques in dispute.
i. Because the above narrated fact was sincerely apprized to the
Ld. Magisterial Court by the present counsel for Accused No.

1/Petitioner while arguing his application under section 311 of
the Code of Criminal Procedure. However, the Ld. Magisterial
Court belittled all that and exercised profound haste in deciding
the application sans unfolding the indispensable facts which
were being put forth by the counsel for Accused No. 1/Petitioner
which is per se inexplicably deplorable.
g. Because the purpose of the application under section 311 of the Code
of Criminal Procedure was to crystallize the factual truth by recalling
the remaining complainant/accused persons/witnesses for examination
and cross examination which were never effectuated earlier because of
the reasons mentioned above in extenso. It is writ large that without
recalling these concerned persons, the Accused No. 1/Petitioner cannot
exonerate itself from the pawned off liability. Therefore the prayer
under the application was bona fide but unfortunately failed to satisfy
the legal acumen of the Ld. Magisterial Court.
h. Because the Accused No. 1/Petitioner is a government aided trust
which disseminate education and empower poor Tamil students’ to
establish them as ideal citizens of the society. Moreover, if undue
liability is fastened upon it by the complainant/other accused persons
in this manner, it will exacerbate its fiscal equilibrium and make no
mistake
will certainly going to cause impediments in pursuing their noble
objectives.
i. That the enormous judgments/orders of the Hon’ble Court across the
country have held that Section 311 of the Code of Criminal Procedure
cast a duty upon the Magistrate to call upon the concerned parties
whose examination/cross examination is indispensable in the interest
of justice.
Also, In Rajendra Mishra V. Pramod Nischal 2018 SCC OnLine
Del 10567
6. Undoubtedly, the statutory provision contained in Section

139 of the Negotiable Instruments Act, 1881 gives rise to a
presumption, “unless contrary is proved” that the holder of
the cheque had received the cheque of the nature mentioned
in Section 138 “for discharge, in whole or in part of any
debt or other liability”. It has to be borne in mind that in
order to maintain and bring home a case for offence Under
Section 138 of the Negotiable Instruments Act, 1881, aside
from proving other facts like failure of the cheque upon
presentation and default in payment destitute demand notice,
it is the onus on the complainant to also prove that the
cheque was issued for the discharge, in whole or in part, of
any debt or other liability.
J. Because in Raja Ram Prasad Yadav V. State of Bihar & Anr. 2013
(14) SCC 461, the Hon’ble Apex Court has held that:
“power under section 311 casts a duty upon the court to
summon, re-examine or recall a witness at any stage, if
his/her evidence appears to be essential for just decision of
the case.
Also in Iddar & Ors. V. Aabida & Ors. AIR 2007 SC 3029, The Hon’ble
Apex Court observed that:
12. “As indicated above, the Section is wholly discretionary.

The second part of it imposes upon the Magistrate an
obligation: it is, that the Court shall summon and examine
all persons whose evidence appears to be essential to the
just decision of the case. It is a cardinal rule in the law of
evidence that the best available evidence should be brought
before the Court. Sections 60, 64 and 91 of the Indian
Evidence Act, 1872 (in short, 'Evidence Act') are based on
this rule. The Court is not empowered under the provisions
of the Code to compel either the prosecution or the defence
to examine any particular witness or witnesses on their side.
This must be left to the parties. But in weighing the evidence,
the Court can take note of the fact that the best available
evidence has not been given, and can draw an adverse
inference. The Court will often have to depend on
intercepted allegations made by the parties, or on
inconclusive inference from facts elicited in the evidence. In
such cases, the Court has to act under the second part of the
section. Sometimes the examination of witnesses as directed
by the Court may result in what is thought to be "filling of
loopholes". That is purely a subsidiary factor and cannot be
taken into account. Whether the new evidence is
essential or not, must of course depend on the facts of each
case, and has to be determined by the Presiding Judge.
Going by the decisions of the Hon’ble Supreme Court of India in the

hereinbefore mentioned case laws, the examination/cross-examination of
the complainant along with Accused Nos. 4 to 6 are highly
essential/material in order to unfold the truth and crystallize the
manipulated liability for utilizing funds of poor parents for personal gains.
K: The Petitioner seeks permission of this Hon’ble Court to urge any
additional grounds which would be available to the Petitioner at the time
of hearing this Petition
L: That the present Petition is preferred bonafide and in the interest of
justice.
PRAYER
In the facts and circumstances stated herein above, it is most respectfully
prayed that this Hon’ble Court may graciously be pleased to:
a. Allow the present petition, by Setting Aside the Order dated
18.02.2022 passed in CC No. 40029/2016 titled as M/s Mallick
Brother V. Delhi Tamil Education Association & Ors. before
Ms. Amandeep Kaur, Metropolitan Magistrate-06, New Delhi,
Patiala House Court and consequently allow the application
under section 311 of the Code of Criminal Procedure 1973.

b. Pass such other order/s as this Hon’ble Court may deem fit in the
facts and circumstances of the case.
AND FOR THIS ACT OF KINDNESS THE PETITIONER AS IN DUTY

BOUND SHALL EVER PRAY
Filed by
Petitioner
Through
(Anurag Ojha) (Deepak Somani)

Advocates, Counsels
for Petitioner
Chamber No., Lawyers’ Chamber-I,
Delhi High Court-New Delhi
Date: 04.03.2021
(M) +91
Place: New Delhi Email:
Case 4
IN THE COURT OF HON’BLE CHIEF METROPOLITAN

MAGISTRATE, TIS HAZARI WEST, NEW DELHI
CC No. 2832/ 2018
IN THE MATTER OF:
Gaurav Mohan …Complainant
VERSUS
Anand Singh Verma … Accused
APPLICATION UNDER SECTION 315 OF THE CRIMINAL

PROCEDURE CODE
1. That the present matter is pending before this Hon’ble Court and is listed
on 25.01.2021
2. That the Complaint has been filed against the Accused under Section 138
of the Negotiable Instruments Act, 1881 in respect of a Cheque bearing
No.000187 of Rs.10,00,000/- dated 15.01.2018.
3. That it is imperative to mention that the present matter is an attempt of the
complainant at evading the criminal liability by reciprocating the same
upon the accused by abusing the Negotiable Instrument legislation
enacted for the betterment of victim of fiscal greed however the present
case is one blunt example of its misuse beautifully conducted by the
complainant.
4. That the complainant company is a Chartered Accountant Firm involved
in unlawful advancements of monies as loan by charging exorbitant
interest rates to illegally procure gains. Pertinent to note that the accused
is an erstwhile Partner of the said firm who introduced one namely Sh.
Abhishek Agrawal to the complainant’s and his brother namely Sh. Rajat
Mohan for advancement of loan to said Sh. Abhishek Agrawal.
Imperative to state Sh. Rajat Mohan approached accused and implored to
aggravate their investment of surplus funds, subsequently accused
introduced Abhishek Agrawal to him mere as a coordinator in all the
advancements/lending of loans and was never a beneficiary other than the
remote sum earned as commission being a guarantor. The complainant
and his brother Sh. Rajat Mohan used to advance loan amount to
Abhishek Agrawal to earn higher interest i.e 6% per month. In the event
of cash loan amount was directly paid to Abhishek Agrawal and Bank
transactions were routed through accused, keeping him privy as a
guarantor, who further advanced them to the said Sh. Abhishek Agrawal,
as per the instructions of the complainant and his brother Sh. Rajat
Mohan. The screenshot of the e-mails, copy of emails and email
attachments showing the advancement of loan amount in cash/cheques at
high interest rate is annexed herewith as ANNEXURE A-
1. To give these transactions a legal color i.e., the advancement to
Abhishek Agrawal through accused, complainant used to execute a false
loan agreement showing interest rate @1% PM however in the email, in
which
loan agreement were used to send, interest rate mentioned are different,
varies from 3.5% to 6% per month, then mentioned in agreement. That
crystallizes the fraudulent behavior of the complainant to procure
wrongful/illegal gains by falsely framing the transactions within the four
corners of law. Furthermore, Section 23 of the Indian Contracts says
23. The consideration or object of an agreement is lawful, unless—" it is
forbidden by law; 14
or is of such a nature that, if permitted, it would
defeat the provisions of any law; or is fraudulent; or involves or implies,
injury to the person or property of another; or the Court regards it as
immoral, or opposed to public policy. In each of these cases, the
consideration or object of an agreement is said to be unlawful. Every
agreement of which the object or consideration is unlawful is void.
In the present case the complainant sans any valid license for money
lending constantly advanced monies as loan to the said Sh. Abhishek
Agrawal at exorbitant interest rates; framing it as an illegal contract and in
the light of the hereinbefore stated section makes it void ab initio.
Moreover, the complainant has falsely shown it as a friendly loan in the
present matter conscious of the fact that the loan was personal loan as
admitted by the complainant in the annexed e-mails as well.
5. That the Accused person have the record of conversation regarding the
transaction which he forward, the e-mails are as following: -

S.no Sender’s Email Recipient E-mail Date Attachment
1 rajatAgrawal anandsinghverma@gmail.com 06.06.2016 Copy of
008@gmail.com Mail
008@gmail.com Mail
008@gmail.com Mail
008@gmail.com Mail
6. That it is imperative for the accused person to be a witness in the present

matter to confront this Hon’ble Court with true and correct facts sans any
concealment unlike the complainant.
PRAYER
 In the foregoing, it is most humbly prayed before this Hon’ble Court that
it may graciously be pleased to allow the present Application in order to
grant opportunity to the accused to be a competent witness in this present
matter, as his evidence is indispensable for this Hon’ble Court to arrive at
ends of Justice.
 Pass any other order which the Hon’ble Court deems fit.
Applicant/ Accused
Through
(Counsels for Accused)

New Delhi- 110 001
Ph- 011- 230702
Email:
Date: 25.01.2022
Place: Delhi
VERIFICATION
Verified at Delhi on this day of January, 2022 that the contents of the above
Application are true and correct to the best of my knowledge and no part of it is
false and nothing material is concealed therefrom.
Deponent
IN THE COURT OF HON’BLE CHIEF METROPOLITAIN
MAGISTRATE, TIS HAZARI WEST, NEW DELHI
CC No. 2832/ 2018
IN THE MATTER OF:
Gaurav Mohan …Complainant
VERSUS
Anand Singh Verma … Accused
CERTIFICATE UNDER SECTION 65 B OF THE EVIDENCE ACT
I, Anand Singh Verma S/o Anand Singh Verma R/o 2602-A, Ground Floor,
Front Side, Gate No 17, Greenfield Colony, Faridabad 121003 aged about 40
years, do hereby solemnly affirm and sates as follows:
1. I state that I am producing the Summary of Transactions between

Complainant, Sh. Rajat Mohan (brother of Gaurav Mohan) and Abhishek
Agrawal through me. My account was used as intermediatory account
only. In substance transactions were between Rajat Mohan and Abhishek
Agrawal. Rajat used to invest his and his relatives/friend’s money with
Abhishek Agrawal to earn profit. Summary of Transactions, between
Complainant, Rajat Mohan & Abhishek Agrawal through accused, are
given below
Refer Annexure-A
2. I am also producing emails of Gaurav Mohan and Rajat Mohan

demanding interest @ 3.5% to 6% per month (i.e., 43.2 % to 72% per
annum). Abhishek used to give this interest directly to Rajat Mohan. My
role in these transactions was only that I introduced Abhishek Agrawal
to Rajat
Mohan. The sender and recipient email ID and computer system from
which emails have been downloaded are given below
Computer System
Device Specification
System Manufacturer: Lenovo
Model Number: E460, Think Pad
Serial Number: PF-0JW383 16/06
Device name DESKTOP-NTSDPV8

Processor Intel(R) Core (TM) i7-6500U CPU @ 2.50GHz 2.60
GHz
Installed RAM 8.00 GB (7.87 GB usable)
Device ID DA853708-2C21-414B-BC09-B8854AA81BEA
Product ID 00330-50088-14174-AAOEM
System type 64-bit operating system, x64-based processor
Pen and touch No pen or touch input is available for this display
Windows Specification
Edition Windows 10 Pro
Version 20H2
Installed on 3/18/2021
OS build 19042.1165
Experience Windows Feature Experience Pack 120.2212.3530.0
Email Details
S.n Sender’s Recipient E-mail Date Attachme
o Email nt
1 rajatAgrawal anandsinghverma@gmail. 06.06.20 Copy of
008@gmail.c com 16 Mail
om
om
om
om
Printer
Manufacturer: Kyocera
Model No.: ECOSYS M8124cidn
DEPONENT
VERIFICATION
I, Anand Singh Verma, the deponent does hereby verify that the contents of this
affidavit are true and correct to my knowledge, no part of it is false and nothing
material has been concealed there from.
Verified at Delhi on this day of January, 2022.

DEPONENT
Case - 5
IN THE HON’BLE COURT OF SH. RAKESH PANDIT, ADDITIONAL
DISTRICT JUDGE, CENTRAL DISTRICT, TIS HAZARI COURT,
DELHI
CS NO 11396 OF 2016
IN THE MATTER OF
R. S. Batra ….. Plaintiff
Versus
Burmah Shell Cooperative Society & Ors ……Defendant
APPLICATION FOR SETTING ASIDE OF ORDER OF DISMISSAL
UNDER ORDER IX RULE 9 OF THE CODE OF CIVIL
PROCEDURE,1908
MOST RESPECTIFULLY SHOWTH:
1. That the present matter was listed on 25.11.2021 and this Hon’ble Court
was pleased to dismiss the present case as “Dismissed for non-
prosecution”.
2. That the present suit for declaration has been filed by the plaintiff for the
possession and mesne profit against the defendants. It is pertinent to
mention herein that the counsel for Plaintiff Sh. D N Chaturvedi has filed
the proposed issue on 07.09.2021 before this Hon’ble Court and the same
is on record, he has also appeared, however, the presence of counsel for

Plaintiff is not on record in the order sheet dated 07.09.2021
inadvertently. Subsequently, thereafter that two dates have been passed,
unfortunately, one date was missed by the Learned counsel of Plaintiff
due to some personal difficulty (Medical Emergency). Therefore, he was
unable to attend the court proceeding on 25.11.2021.
3. That the main counsel of the present matter was stuck in the hospital, his
mother was admitted in the hospital due to which he was unable to attend
the court proceeding on the said date and has informed the Applicant for
the same.
4. That the Plaintiff’s Counsel instructed the applicant that takes
adjournment for the non-availability of counsel. However, the applicant
also do not appear on 25.11.2021 before this hon’ble court because she
was suffering from cough and cold, as per doctor instructions applicant
had isolated herself at home.
5. That it is pertinent to note that when the applicant appears before this
hon’ble court on the next day and enquired the next date of hearing of the
present matter from the reader and hence, the Applicant matter was
dismissed as “Dismissed in default” due to the non-appearance.
6. That the Applicant hence, moves the present application for setting aside
of the Dismissal order dated 25.11.2021
7. That the present application is made bona fie and in the interest of justice
not prejudice the right of the Applicant.

PRAYER
In the view of the foregoing facts and circumstances, it is most
respectfully and humbly prayed before this Hon’ble Court that it may
graciously be pleased to:
a. Allow the Present application
b. Set Aside the order of dismissal passed against the Applicant
c. Pass any such order or further order as this hon’ble court may deem
fit and necessary in the interest of justice.
Applicant
Through
CORPORATE JUDIS LLP

Date: 25.01.2022 New Delhi- 110 001
Place: Delhi Ph-
Email:
Case 6
CC No. of 2022
IN THE MATTER OF:
Sh Tushar Kanti Biswas … Complainant

VERSUS

CRIMINAL BREACH OF TRUST, AND MISREPRESENTATION OF
FACTS, CHEATING, DISHONEST MISAPPROPRIATION.

1. That the Complainant i.e. Tushar Kanti Biswas S/o Shri Naresh ch.
Biswas R/o III-F/547, Vaishali, Sector-3, Ghaziabad Uttar Pradesh-
201010 have to make following complaint against accused mentioned
above .
2. That sometimes in the month of January 2015 , I receive a phone call
from one Shri Sunil Nagar , over my mobile from one Mr Sunil Nagar
claiming himself to be the chief executive of company mentioned of the
subject proposing and offer of sale of residential property from the
company / developer mentioned in the subject this call was received my
me when I was at my residence.
3. That the said Sunil Nagar give me the detail of the property situated at
sector 10, GREATOR NOIDA . In addition to the facts of insisting that
property was strategically located it was also emphasised that the property
had added attraction of being in the same compound and was connected
as
/ annexed immediately to the famous chain of commercial mall and to be
called by the name “Bulland Calisto” GREATER NOIDA and the project
sell residential and retail/commercial spaces . Prior arid after to be the
other sited conversation there were advertisement of the kind with the
intention of communicating that was intended be conveyed to me on
phone by Shri Sunil Nagar .
4. That the undersigned complainant would off and on get calls from Mr
Sunil Nagar empathising upon to make investment in their above project
as the project had a big potential of being high and customer oriented
complex at as the same would attract not only the customers from the
residential sectors but also the commercial space . In addition to the
above, it was also empathise to lead the bonafide, that the company would
be given assured return of three present 3% per month for 24 month or the
completion and handling over the project .without sensing the trap of the
developer the undersigned accepted to have a physical look signed . the
continued calls from the company chief executive namely MR.SUNIL
NAGAR were aimed at alluring me to fall prey to their design. During
conversation it was also stressed upon me that the project was looked over
Greater Noida and the company had the credential of having built up side
like “Bulland Height” “Bulland Elevate” and had the background of
having built up many projects.
5. That These telephonic conversation were also followed by information
literature and brochures from the company which were received at my
residence at Raghubir Nagar .because of the luceration and salesman ship
,the undersigned believed upon the express and implied assurances and
explanation of the company representative ,ultimately landed into make
the investment in the project of the builder and the developer named in
the
subject by the named called Bulland Calisto, Greater Noida and the
delivery of the project was assured to be March 2018, after completion
and the complainant thus subscribed to invest in a retail unit by the Flat
No. 1404, 14th Floor in Block –D, measuring 1230 sq. ft(Super Area) in
Bulland Calisto in Plot No. GH-02B-1, Sector-10, Greater Noida West,
Uttar Pradesh at a cost of Rs 28,00,000/- the said amount was paid by the
complainant in the form of Cash, subsequently followed by an agreement
and paying of the total Consideration. After the payment the mentioned
above ,the assured return of 3% Pm, started to be received by the
undersigned applicant till December 2018 when there was the receipt of a
communication from the developer at the residence of the complainant
that the undersigned could taken the possession of the booked unit . In
view of the communication from the builder, the undersigned visited the
site and to the utter shock of the undersigned applicant .it was found that
neither the residential/commercial space centre was complete ,nor the said
COMMERCIAL SPACE was there. The basic and primary consideration
of the undersigned applicant was the rosy picture of the RESIDENTIAL
CUM COMMERCIAL SPACE being annexed to the
residential/commercial space i.e. the Complex and mall concept and there
does not seem to be any possibilities in the near future of any
RESIDENTIAL/COMMERCIAL SPACE coming up as an annexed
building to the commercial/residential space. The facts that the builder
through its representative as well as on their own through verbal
communication ,ass per brochures ,ads and written/visual representative
on web sites have all together represent the total unit on a single plot
consisting of residential space and commercial space as single unit which
was to allure gullible investor resulting into making their hard earned
investment into their project called ‘ Bulland Calisto’ had the builder on
their own or through their representative not misrepresent the fact
mentioned above .
that the representation fake /untrue to the knowledge to the accused
person at the time when it was made . that the complaint parted with his
property acting on the representation which was false to the knowledge of
the accused and that the accused had a dishonest intention from the out
set. That the accused had induced the complainant to part with property
and was case of unjust enrichment by accused person by playing a deceit
with the complainant.
6. That the circumstances show that fraudulently /dishonest intention was
right at the beginning of the transaction time. That the investment was
made on account of the fake representation to the complainant i.e. the
delivery of the cheques so in cash by the builder /developer which were
the consequence of the deception played upon the complainant. That the
intention and acts of the accused person were DISHONEST and done
with the intention of causing wrongful gains to themselves and wrongful
losses to the undersigned. In view of the fact mention above it is the
request that a criminal case under appropriate section of law be registered
against the promoters and his co-conspirators /associates in the act
mentioned in the aforesaid paras.
7. That when the complainant wants confirm of true status of his unit no,
accused person provide satisfactory reply thereafter complainant visited
accused company Noida site office find out the said project to be
abandoned no work at site since long time office because of finance
difficulties after discussed Mr Sunil Nagar they given a piece of paper
which was reflected my name as a investor, along with my payment duly
sign by Mr Sunil Nagar.
8. That When the complainant discovery of Company Statutory Auditor

Report at ROC, site complainant outstanding was not reflected in the
balance of Company . However, the statutory auditor has misused his
powers and cheated Investors of company and misused his professional
capacity as a Chartered Accountant by misappropriating and by
falsification of accounts. The copy of the annual report for financial year
,2011-12, 2012-2013, 2013-14, 2014-15,2015-16, 2016-17, 2017-18 are
enclosed herewith as Annexure .
9. That CA Srivastav Kumar & Company in collusion With Managing

director Mr. Rajnish Nagar played a very active role with common
intention and connivance with each other in a very pre-planned and well
designed manner having dishonest intentions since beginning with
criminal intent, hatched a deep rooted criminal conspiracy and furtherance
of such criminal conspiracy, the CA Srivastav Kumar & Company and
Sunil Nagar ousted the complainant from the company namely Ms
Bulland Realtors Pvt. Ltd or M/s Bulland Builtech Pvt. Ltd. and duped
hardened money of the complainant and gulped the allotment of Units
causing wrongful loss to him and wrongful gain to themselves.
10.That for the purpose of criminal breach of trust, cheating and dishonestly
inducing for the delivery of property, forgery of documents and forgery
for the purpose of cheating with a prior meetings in mind with others
having criminal conspiracy and other criminal acts done by him along
with others for running the business of money laundering and speculative
business for making easy money by befooling the public and black
mailing the people not only this he has shown him as Director in the
company of the applicant
i.e. M/s Bulland Buildtech Pvt. Ltd as well as M/s Bulland Realtors Pvt.
Ltd. However, no consent was given by the applicant while he being the
promoter Director of the above mentioned company. The copies of the
details of the Directorship reflecting the name of the CA Srivastav Kumar
& Company along with other Directors are already enclosed.
11. It is a serious multi corer fraud that requires fact finding investigation
.in the light of the above facts and circumstancesThat the acts of the
alleged person were done voluntarily which were criminal by reason of its
being done with a criminal knowledge and intention and caused the effect
of wrongful losses to the Complainant which was intended by the accused
with the knowledge of end result being wrongful gains.
12.That the Accused persons were acting in connivance and collusions upon
having their hand in glove with each other for their wrongful gain and
causing huge wrongful loss to the Complainant and was in agreement
with pre mediated mind to commit the said offences.
offences are involving mensrea/guilty intention. A thorough investigation
must be required to be conducted by the police which can be done only
after registration of the FIR to trace the trail of the money.
mercenary manner with dishonest intention since beginning with criminal
intent, hatched a deep-rooted criminal conspiracy and in furtherance of
such criminal conspiracy, the Accused persons planned to oust the
Complainant from its hard-earned money causing wrongful loss to
Complainant and wrongful gains to themselves.
15.That a complaint with respect to the aforesaid acts of the Accused Persons
has been made to the DCP, EOW however no action has taken place till
date. Copy of the said complaint is annexed herewith as ANNEXURE
police which can be done only after registration of complaint also to deter
the accused persons from committing further offences against the
Complainant.
17.That the Hon’ble court duly exercises its jurisdiction over the said acts of
the Accused person as the office of accused person is in Khanpur, New
Delhi is within the jurisdiction of this Hon’ble Court and therefore this
court is the appropriate forum to contest this complaint.
this Hon’ble Court for the redressal of his grievance to bring the Accused
person to book for the offences committed by him resulting in blatant
violation of the law.
PRAYER


fit and necessary.
COMPLAINANT
Through
Chamber No., Patiala House Courts
New Delhi-110001
Ph-
Email:
Place: New Delhi

Date: .02.2022
VERIFICATION
Verified at New Delhi on this day of February, 2022 that the contents of this
Complaint are true and correct to the best of my knowledge. No part of it is false
and nothing material has been concealed therefrom.
DEPONENT
Case 7
IN THE COURT OF HON’BLE MS. MANIKA, ADDITIONAL CHIEF
METROPOLITAN MAGISTRATE, SOUTH DISTRICT, SAKET
COURTS, DELHI
IN THE MATTER OF:
Surpreet Singh Suri & Ors. … Complainant
Versus
M/s Juristica Legal Service LLP … Accused
P.S.- Saket, New Delhi
APPLICATION UNDER SECTION 340 OF THE CODE OF CRIMINAL

PROCEDURE,1973 AGAINST THE RESPONDENT UNDER SECTONS
191, 199 AND 200 OF THE INDIAN PENAL CODE AGAINST THE
RESPONDENT.
MOST RESPECTFULLY SHOWETH AS UNDER:
1. That the present application under section 340 of Code of Criminal
Procedure 1973 is being filed against M/s Juristica Legal Service LLP,
who has filed a complaint under Section 156(3) of the Code of
Criminal Procedure, 1973 before this Hon’ble court. Furthermore, the
Respondent has abused the process of law in preferring this
application
and has consciously made false assertion before this Hon’ble court
knowing fully about the same, that those statements are false.
2. That the Applicant to this application is the alleged Accused No. 1 in
the Case being Ct No. 29146 of 2019 filed before this Hon’ble Court.
The Petitioner/Applicant is grieved, against the false statements
adopted by the Respondent in his aforementioned complaint. It is
pristine to note that the Respondent has chosen to mislead this Hon’ble
Court by filing false and frivolous Complaint and has molded the facts
in such a way, that on the basis of which he was able to satisfy this
Hon’ble court to entertain the aforementioned complaint. The
Respondent has never missed a single chance to harass the Petitioner
which includes spreading wild allegations against the Petitioner which
are not only defamatory, untrue, malicious, vicious but are calculated
to harm irreparably the inviolable reputation of the
Petitioner/Applicant.
“His strategy is - whosoever fails to succumb to his wishes will be
forced to be a prey of him, by devising one or the other technique”
3. It is appropriate that certain facts may be taken note of:
a. That the Petitioners/Accused(s) are all associated with the 3 C
Group of Companies and are in business relations with each other
for 20 long years.
b. Pristine to note that the Respondent is a legal firm having their
registered address at A-247, Lower Ground Floor, New Friends

Colony, New Delhi – 110025, and the Respondent namely Tanweer
Alam, who is also one Designated Partner of the said legal firm,
was introduced by the Petitioner No. 2 and 3 to Petitioner No. 1
Surpreet Singh Suri.
c. The respondent being acquainted with the inclining business chart of
the Petitioner was hankering to be engaged as their counsel, in quest of
which, he approached the Petitioner imploring to engage his firm as
their legal advisors with an assurance of abbreviated fees, opining
which the Petitioner nodded for the offer and engaged them as their
legal advisors.
d. After the engagement, the Respondent exhibited their dire need of a
financial loan for establishing their office at New Friends Colony,
Delhi which is also their present office, to the Petitioner, believing
them to provide the fiscal help to the Respondent, Petitioner on
good terms nodded for the said loan of Rs 25 Lacs. And transferred
the amount via NEFT on 19.11.2018 which conspicuous in the
ledger account maintained by VISTAR INTERIOR LLP herein
annexed as ANNEXURE .
e. Since the engagement, the Respondent has appeared for the Petitioner
on few hearings for which the Respondent raised bills and was paid
accordingly by the Petitioners on two different occasions which
amount to Rs 3,00,000/- in toto.

Cheque No. Dated Amount (Rs.)
a. 000226 06.12.2018 2,00,000/-
b. 249341 18.01.2019 1,00,000/-
Thereafter, the Petitioner has never sought legal assistance from the
Respondent and their fabricated claim of paying Rs 25 Lacs to
Senior Advocate Mr. Vikas Pahwa out of their own pocket is the
falsity of the first order as Mr. Pahwa argued the bail applications
as pro bono in regards to the brotherly relations between him and
Accused No. 3 in the complaint namely Sh. Dinesh Kumar Pahwa,
which crystallizes the untrue assertions of the Respondent
regarding payment of Rs 25 Lacs to Mr. Vikas Pahwa making this a
pretext for usurping the hard-earned money of the Petitioners by
withholding the loan amount and overlooking their liability.
4. That the application under section 156(3) Code of Criminal Procedure
was filed by the Respondent with utter malifide and dishonest
intentions by abusing the legal machinery in dodging their duty and to
seek wrongful gain on the expense of wrongful loss to the Petitioner
by withholding the money lent as loan moreover, to give it a color of
fees against legal services.

5. That the Respondent devised a new technique which it was in habit of;
considering the previous conduct, it was done to harass the Petitioner
when a complaint was filed under section 156(3) based on false and
frivolous grounds just in order to mislead this Hon’ble Court.
6. That the said Respondent in his alleged complaint -has made
knowingly false statements to support his contentions. Otherwise also,
if a detailed report is called upon, it will show the misleading
entrenched behavior of the Respondent.
PRAYER
It is, therefore, most humbly prayed that this Hon’ble Court may kindly be
pleased to grant the following among other reliefs in favour of the
Applicant:
(A) A preliminary inquiry should be made into the offence and record
the same for the offence as committed by the Respondent under section 191,
199 and 200 of the Indian Penal Code and,
(B) issuance of appropriate directions by the Hon’ble Court against
said Respondent in accordance with the law under the provisions of Sections
191, 199, 200 of the Indian Penal Code, 1860; and

(C) pass any further or other order as deemed fit in the facts and
circumstances of the case.
COMPLAINANT
FILED BY:
New Delhi-110001
Ph-
Email:
Place: New Delhi
Date: .04.2021
Case 8
IN THE HON’BLE COURT OF SH. ARUN VARMA, SPECIAL JUDGE TIS
HAZARI COURTS, CENTRAL, NEW DELHI
Bail Application No. /2022
IN THE MATTER OF:
Mithu Rani …..Applicant/Accused No. 3
VERSUS
BSES Yamuna Power Limited … Respondents
APPLICATION FOR GRANT OF BAIL UNDER SECTION 439 OF THE

CODE OF CRIMINAL PROCEDURE ON BEHALF OF THE
APPLICANT/ACCUSED NO. 3 MITHU RANI
1. That the above-mentioned case is pending before this Hon’ble Court and
the same is fixed for the adjudication on 23.02.2022.
2. That this Hon’ble Court vide order dated 21.02.2022, issued non-
bailable warrant against the accused no. 3. Subsequently the applicant
was arrested on 23.02.2022 vide order dated 21.02.2022.
GROUNDS:
Present Application seeking bail is made inter alia on the following grounds
which are taken and pressed without prejudice to each other

1.1. Because the applicant is innocent person in the present case and he has
been falsely implicated in a criminal case.
1.2. That the Applicant / accused is a law-abiding citizen of India and a
responsible member of the society which has unfortunately led him into
being incarcerated.
1.3. Because the connected matter is pending before Ld. ADJ-03, Central, Tis
Hazari Court bearing case number 1029/19. In the said proceedings the
applicant has already submitted Rupees 1,00,000/- as against the interim
deposit. Thus, the conduct of the applicant is bonafide in the present
matter and has shown no lackadaisical behavior/criminal intent.
1.4. Because the Applicant has fully co-operated with the investigation and
undertakes to continue the same approach if and whenever required.
1.5.Because the applicant is not a flight risk because he is having deep roots
in the Society.
1.6. Because the applicant/accused undertakes not to influence any witnesses
or destroy or tamper any evidence and he further avers that he does not
occupy any position which could place him in such a controlling position
to influence the investigation.
1.7.Because the presumption of the innocence at this stage is in favour of the
applicant and the fact is yet to be tested by way of trial which is likely to
take long time due unprecedented wave of COVID-19 pandemic.

1.8. Because that the applicant is not a previous convict and no criminal case
is pending against the applicant accused and have clean antecedents and
record.
1.9. Because the applicant/ accused is a female and mother of a minor child,
who is dependent upon her mother for his ideal upbringing.
1.10. Because the applicant undertake to appear at each and every date during
the course of trial and face the outcome of the present case and further
undertake to abide any terms and conditions imposed by this Hon’ble
court in lieu of grant of bail.
1.11. Because the applicant undertake to furnish the sound surety to the
satisfaction of the Hon’ble court.
1.12. The Triple Test for grant of bail is satisfied and the dictum that the bail
is the norm and jail is the exception squarely applies in the present case.
2. That the present Application is being filed in the most bonafide manner, as
advised under law.
3. That the Applicant seeks liberty to urge any other or future grounds as may
be available to the Applicant at the time of argument with the leave of this
Hon’ble Court.
4. That the Applicant has not filed any other similar Application before any
other Court for the same or similar relief.

PRAYER
It is therefore, keeping in view the said facts and circumstances stated herein
above in the interest of justice and fair trial it is most respectfully prayed that
this Hon’ble court may graciously be pleased to:
a. Admit the Applicant on bail in the interest of justice.
b. Impose such conditions as this Hon’ble Court may deem fit and
proper to impose in the facts and the circumstances of the case.
c. Pass such other order may deem fit in the facts and circumstances
of the case.
AND FOR THIS ACT OF KINDNESS THE APPLICANT AS
IN DUTY BOUND SHALL EVER PRAY.
Applicant/ Accused
Through
(D.N CHATURVEDI)
New Delhi- 110 001
Ph- 011- 23070268
Email:
Date: 23 .02.2022
Place: New Delhi
Case 9:
To Dated: 01.02.2022
The Station House Officer
Police Station: Uttam Nagar
COMPLAINT AGAINST M/S RADHE KRISHNA OFFICE AT 903,
GROUND FLOOR NEAR DASHMESH HOSPITAL, SHIV NAGAR
EXTENSION, WEST DELHI, DELHI-110018 FOR THE COMMISSION
OF OFFENCE INCLUDING INTER ALIA, CRIMINAL BREACH OF
TRUST, CHEATING, STOLEN PROPERTY
Sir,
That the Complainant Shri Rajesh kumar Gupta R/o S-65, Street No-12,
parampuri Near Shiv Mandir, Uttam Nagar West Delhi, Delhi – 110059 is
present before your good self with the complaint against the Accused person, the
details of which are delineated below-:
1. That the Complainant is a law-abiding citizen of India and his honesty
and integrity bespeak for himself who embodies humanism of its
highest nature, coming from a humble background.
2. That the Complainant is a businessman carrying his business at R/o S-
65, Street No-12, parampuri Near Shiv Mandir, Uttam Nagar West
Delhi, Delhi – 110059.

3. That the Complainant had maintained rapport with one Shri Anil Jain
and who referred the accused person by citing his business of
supplying medical equipment including oxygen concentrators midst
pandemic.
4. That during this pandemic, In the month of April 2021, the
Complainant and his family was inflicted with COVID-19 on account
of which he was in desperate need of oxygen concentrator(s).
5. That the complainant exhibited his need of oxygen concentrator(s) to
Shri Anil Jain who shared the contact number of the accused person
with an assurance that he supplies equipment of robust quality and he
is the only one who can resolve your conundrum.
6. Subsequently, the complainant telephoned the accused person and
imparted him the emergent need of an oxygen concentrator who asked
for the payment prior to the delivery and shared his bank account
number.
7. That the complainant exonerating his part of the deal by instantly
transferring the amount of Rupees 4,00,000/- via online payment,
apprized the accused person of the payment which was duly
acknowledged by the accused person however despite the transfer the
accused person failed to obey/discharge his part of the deal by
effectuating delivery much less timely delivery as promised.
8. That the complainant has paid the amount of Rupees 4,00,000/- (Four
Lakhs Rupees Only) to the Accused Person for the delivery of oxygen
Concentrator. But after receiving payment accused person didn’t
deliver even a single oxygen concentrator.
9. That after this the complainant endeavoured to contact the
consignment agent Shri Anil Jain however being incarcerated in FIR
No 249/2021, he was not approachable.
10.Thereafter the complainant made attempts to contact the accused
person in absence of his consignment agent however the accused
person endeavoured to preclude any communication with the
complainant as evidently he never intended to return the payment. And
that suspicion was emboldened when the complainant was confronted
with the fact that the accused person has cheated several people and
this is his style of functioning to dupe the people in need and extort
monies by manipulating them.
11.That the accused person has malifidely caused wrongful loss to the
complainant by withholding his legitimate monies and ultimately
procuring wrongful gain to himself.
12.That it would not be out of the place to mention herein that the
intentions of the accused was dishonest from the beginning and his
only aim was to knock out the money from the complainant by illegal
means of the above stated fraudulent and dishonest misrepresentation.
13.That as such it is possible that the accused persons may have also
committed other similar incidents. That there is a strong possibility
that
the accused person was a part of a larger criminal conspiracy with
other individuals to defraud the complainant and as such a police
investigation is necessary to uncover this crime as said offences have
been perpetrated within the jurisdiction of this police station.
14.That it is once again reiterated that accused had malafide intentions
from the very inception, that is why they initially induced and allured
the complainant to trust them and thereafter, breached the same and
caused immense financial losses to the complainant, for which they
have played a calculated fraud upon the complainant.
15.That the Accused person has committed various offences under the
Indian Penal Code and thus the offences are involving mensrea/guilty
intention.
It is, therefore, requested from you, that kindly take immediate actions
against the accused person in order to preclude him from committing
any further offences against the complainant. Moreover, to trace out
the money trail and unearth identical offences perpetuated by the
accused person.
COMPLAINANT
Rajesh kumar Gupta
R/o , Street No-12, param puri
Near Shiv Mandir, Uttam Nagar
west Delhi, Delhi - 110059
Case 10:

CC No. of 2022
IN THE MATTER OF:
Sh Ranbir Singh … Complainant

VERSUS

CRIMINAL BREACH OF TRUST, AND MISREPRESENTATION OF
FACTS, CHEATING, DISHONEST MISAPPROPRIATION.
1. That the complainant i.e., Sh Ranbir Singh is the law-abiding citizen of

this country and his integrity bespeak for himself and the complainant
writing the present complaint as an exasperated citizen like many others
who have been cheated with their life saving by the promoters and
directors of the “ Bulland Realtor Private Limited” a Company
incorporated, registered and existing under the Companies Act, 1956,
having its registered office at A-2, Bulland House, Khanpur Extension,
New Delhi -110080 the project Bulland Calisto Plot no. GH-02B-1,
Sector-10, Greater Noida West, Uttar Pradesh was owned and marked by
“ Bulland Realtor Private Limited”.
The complaint is being made in respect of booking of unit no. i.e., Flat
No.- 206 of total 1180 sq.ft. in Bulland Cristo in Greater Noida West,
project.
2. That In the year 2016, “ Bulland Realtor Private Limited”(Hereinafter
referred as “the Company”), had launched a project called Bulland Calisto
situated at Plot no. GH-02B-1, Sector-10, Greater Noida West, Uttar
Pradesh (Hereinafter referred as the Project”) The complainant had
booked apartment flat No. 206-E measuring 1180 Sq. Ft. (Super Area) in
the project on 4.07.2016 and made a payment by RTGS date 04.07.2016
drawn on Indian bank to the company.
3. That The Company through its “Receipt” (part of the application form)
had promised to hand over the possession of the unit to the complainant
with in specific period of time from the date of booking. The copy of
receipt is annexed herewith this complainant as Annexure-A.
4. That The provisional booking letter was issued by the company to the
complainant on 01.08.2016. After that complainant many times request
from the director of the company regarding to execute the agreement
against the flat booking of the said project. The company failed to
complete the project and till date company has only managed to erect bare
shell of the building. Furthermore, since last 3 years not an iota of
construction activity has taken place on the structure.
5. That Complainant had several meetings with the Directors/Accounts
Executive of the company between 2018-2019, wherein he has informed
by them that construction activity is on hold due to paucity of funds and
efforts are being made to arrange the funds. After many persuasions and
tremendous efforts, somehow, complainant managed to had couple of
meetings with the Directors, along with other investors. It is shocking to
note that company, completely failing to fulfill its legal/business
obligations towards the Complainant of delivering the designated
apartment which is above mentioned in the complaint till today, that too
after receiving the booking amount (Rs. 10 lacs) out of the total cost of
apartment 28 lacs. Since last 3 years the staff as well as the Directors of
the Company are only giving false assurance to the complainant and other
investors that construction will start soon, possession will be offered
shortly. However, complainant recently visited to the site of present
apartment and no hope from the directors of company that they are able to
provide the possession soon.
6. That The Complainant would like to submit that the promises, assurance
and acts of company towards its customers are highly misleading and
inviting the innocent customers to get themselves cheated and
hoodwinked by promising to deliver the apartment in its Project, and
there is prima facie case of cheating and criminal breach of trust. It is
evident from the conduct of directors/promoters/executives of the
company that the company had never intended to construct and deliver
the apartments to its customers, and all that the Company desired was to
defraud and cheat the innocent people in order to collect money from
them under the guise of constructing Bulland Realtor Pvt Ltd. The
Company misappropriated the money entrusted with them for
construction of the Bulland Realtor for their own use.
7. That It is submitted by the complainant that the directors of the company
has conspired together and in furtherance of their common intent to cheat
the peoples to collect money under the name of the company made
representation and issued false assurances, and after collecting the
booking amounts under the guise of construction of apartment in Bulland
Calisto, they never bother to provide any update to the peoples or
entertain the queries related either recommencement of construction after
4 years. The dishonest and fraudulent intent of directors of the company is
also evident from their act of providing inconsistent statements and
thereafter responding to the queries of the complainant. There is a strong
case against
the directors and the company, particularly in the light of the fact that
innocent customers whose hard-earned money was looted away by
dishonest inducement, allurement and misrepresentation. It is further
clarified that the said company had knowingly cheated the customer by
collecting the money for a purpose which it knew it could not complete
and sitting happily thereon without paying any interest not refunding back
the paid amount even after innumerable requests/demands (Oral) by the
Complainant to the Company.
8. That the acts of the alleged person were done voluntarily which were
criminal by reason of its being done with a criminal knowledge and
intention and caused the effect of wrongful losses to the Complainant
which was intended by the accused with the knowledge of end result
being wrongful gains.
9. That the Accused persons were acting in connivance and collusions upon
having their hand in glove with each other for their wrongful gain and
causing huge wrongful loss to the Complainant and was in agreement
with pre mediated mind to commit the said offences.
offences are involving mensrea/guilty intention. A thorough investigation
must be required to be conducted by the police which can be done only
after registration of the FIR to trace the trail of the money.
mercenary manner with dishonest intention since beginning with criminal
intent, hatched a deep-rooted criminal conspiracy and in furtherance of
such criminal conspiracy, the Accused persons planned to oust the
Complainant from its hard-earned money causing wrongful loss to
Complainant and wrongful gains to themselves.
12.That a complaint with respect to the aforesaid acts of the Accused Persons
has been made to the DCP, EOW however no action has taken place till
date. Copy of the said complaint is annexed herewith as ANNEXURE
police which can be done only after registration of complaint also to deter
the accused persons from committing further offences against the
Complainant.
14.That the Hon’ble court duly exercises its jurisdiction over the said acts of
the Accused person as the office of accused person is in Khanpur, New
Delhi is within the jurisdiction of this Hon’ble Court and therefore this
court is the appropriate forum to contest this complaint.
this Hon’ble Court for the redressal of his grievance to bring the Accused
person to book for the offences committed by him resulting in blatant
violation of the law.
PRAYER
fit and necessary.
COMPLAINANT
Through

New Delhi-110001
Ph-
Email:
Place: New Delhi

Date: .02.2022
VERIFICATION
Verified at New Delhi on this day of February, 2022 that the contents of this
Complaint are true and correct to the best of my knowledge. No part of it is false
DEPONENT
Case 11
IN THE COURT OF HON’BLE DISTRICT AND SESSION JUDGE,

CENTRAL, TIS HAZARI COURT, DELHI
CS DJ No. of 2022
IN THE MATTER OF:

Praveen Kumar …Plaintiff
Versus
Chand Kishore …Defendant
SUIT FOR PERMANENT AND MANDATORY INJUNCTION AND

SUIT FOR RECOVERY OF RS. 34,60,000/- (RUPEES THIRTY-FOUR
LACS SIXTY THOUSAND ONLY) ALONG WITH FUTURE INTEREST
@18% PER ANNUM.

1. That the Plaintiff is a law-abiding citizen of India and his honesty and
integrity bespeak for himself who embodies humanism of its highest
nature. Furthermore, the plaintiff and the defendant are blood brothers.
2. That the Plaintiff is the sole proprietor of M/s Delhi Syndicate and
deals in spare parts(tractor) and has by his hard work built good-
will in his field.
3. That the defendant is the sole proprietor of M/s Kishore Transport
India registered at the hereinbefore mentioned address, office(s) of
the plaintiff and the Defendant are adjoined.
4. That the defendant was beloved to the plaintiff until his malafide
actions/in-actions have been brought to the notice of the plaintiff
lately. The actions/omissions of the defendant are stated
hereinafter:
A: That the plaintiff is the proprietor of Delhi Syndicate

since 1984 and was running his business of motor spare parts
on his own sans support from any quarter. After 2011 the
health of the plaintiff started deteriorating therefore the
defendant volunteered to manage the daily affairs of the
plaintiff’s company without hindering with his own. The
plaintiff at the first instance was disinclined to hand over the
daily affairs of his company to anyone but on account of
incessant implores from the defendant and certainly, the
affection of the plaintiff with his brother played its part to
make the plaintiff ultimately nod for it. Imperatively
thereafter the defendant started helping his beloved brother
for managing affairs of Delhi Syndicate merely as an agent
with a caveat that the banking transactions will only be
conducted with prior approval from the plaintiff.
B: That the bank accounts of both the defendant and the

plaintiff were with the Tamilnad Mercantile Bank
Limited, at Chandni Chowk, Delhi-110006 “hereinafter
mentioned as the bank” therefore the defendant was
acquainted with the officials of the bank.
C: One of the clients of M/s Delhi Syndicate namely M/s

Dozer World Private Limited “hereinafter mentioned as
Dozer World” owed Rupees 31,60,646/- to the plaintiff
against
supply of motor spare parts. Moreover, the accountant of the
plaintiff advised him to settle his accounts in order for him to
file the Income Tax Returns acting upon which the plaintiff
wrote a letter dated 30.11.2021 to its client Dozer World
requesting them to clear the pending dues. That after the
receipt of said letter, the official of Dozer World telephoned
the plaintiff with a surprising submission, that the dues have
been already been paid on 22.03.2018 through NEFT in the
account of M/s Delhi Syndicate. This clarification brought a
conundrum to the plaintiff who was completely oblivious of
said credit. Subsequently, the plaintiff enquired with the
defendant as to whether any payment had come from Dozer
World, to which the defendant turned anxious and his
demeanor was conspicuously suspicious therefore the
plaintiff wrote a letter dated 17.12.2021 to the bank
requesting them to furnish the bank statements of each
transaction effectuated around 22.03.2018. The plaintiff was
taken aback by the transaction reflected in the statement on
22.03.2018 as it showed that the payment of Rupees
31,60,646/- was credited in the account however on the same
day a sum of Rupees 34,60,000/- was withdrawn from the
account by the defendant sans any knowledge/approval from
the plaintiff.
A copy of the letter dated 30.11.2021 is annexed
and marked hereto as Annexure -1.
A copy of the bank statement is annexed and
marked hereto as Annexure -2.
D: That the above-mentioned fact left the plaintiff high and

dry and hence he expected a fair and reasonable answer from
the defendant in relation to the said withdrawal conducted by
him as reflected in the bank statement, however, the
defendant failed to satiate the plaintiff with an appropriate
justification in spite of the fact that he was handling and
therefore responsible for every banking transaction as an
agent of the plaintiff.
E: The plaintiff on further inquiry realized that his cheque-

book which was kept in the drawer of his desk was also
missing and evidently, the said cheque-book was stolen by
the defendant in order to withdraw the said amount and to
perpetuate same in the future.
F: The surprising fact is that the bank in the regular course of

business used to intimate the plaintiff even the smallest
withdrawal effectuated in his bank account, but interestingly
in this transaction where the amount was far more handsome
as against regular withdrawals, the bank failed to intimate the
plaintiff through any mode (text, telephone call) much less
seeking leave of the plaintiff before effectuating the
withdrawal. The consideration of aforesaid fact constrains
the plaintiff to smell some connivance between the defendant
and bank officials.
G: That the plaintiff wrote a letter dated 20.12.2021 to the

bank requesting them to debar the defendant from
conducting any transaction in his current bank account
number 100150050801029 along with intimation of the said
withdrawal without the knowledge of the plaintiff.
A copy of the letter dated 20.12.2021 forwarded to the bank
is annexed and marked hereto as Annexure -3.
5. That the cause of action arose in March 2018 when the defendant
withdrew the amount from the bank account of the plaintiff. The
cause of action is, thus, a continuing one and it had been arising
repeatedly over a course of duration.
6. That the offices of both the plaintiff and the defendant are
adjoining property no.s being Registered at 3688/3, Chowk Mori
Gate, Delhi- 110002 and Registered At 3682/5, Chowk Mori Gate,
Delhi-11000 as shown in the map annexed as Annexure A-4. The
defendant has wrecked the adjoining wall to gain access to the
plaintiff’s office, which invite extreme suspicion that the defendant
will dispossess the plaintiff from his office property in order to
obtain unlawful possession and create third party interest.
Imperatively he has already captured important documents
belonging to the plaintiff.
7. That such events in true of its meaning left no choice with the
Plaintiff but to question the integrity of Defendant even after
solemn attempts to trust the Defendant based on previous good
relations.
8. That the Plaintiff herein felt constrained and aggrieved on account of the
aforesaid acts of omissions/commissions on the part of the

Defendant herein, the Plaintiff herein is filing the present Suit,
thereby, inter alia, praying, that this Hon’ble Court be pleased to
direct the Defendant to pay to the Plaintiff herein a sum of Rs.
34,60,000/- (Rupees Thirty-Four Lacs Sixty Thousand Only) along
with Past, Pendente Lite interest from the date when the amount
was withdrawn and payable until the realization of the said amount.
9. That the Plaintiff herein is merely seeking to recover a liquidated
sum of Rs. 34,60,000/- (Rupees Thirty-Four Lacs Sixty Thousand
Only) and therefore, the present Suit is clearly and categorically
covered under the provisions of law.
10.That the Defendant works for gains within the territorial
jurisdiction of this Hon’ble Court, hence, this Hon’ble Court has
appropriate the jurisdiction to try and entertain the present suit.
11.That for the purpose of the Court fees and jurisdiction, the Suit is
valued at 34,60,000/- (Rupees Thirty-Four Lacs Sixty Thousands
Only) along with future interest on which requisite Court Fees of
approx. Rs. 36100/- (Rupees Thirty-Five Thousand Five Hundred
Only) has been paid and affixed herein and also includes Rs.200/-
(Rupees Two Hundred) for Injunction of the said suit.

12.That the present Suit is being filed well within the prescribed
period of limitation as provided for under the relevant law for the
time being in force governing the limitation of Suits.
PRAYER
It is most respectfully prayed that this Hon’ble Court may kindly be pleased to:
a. Pass a decree of Rs. 34,60,000/- (Rupees Thirty Four Lacs Sixty
Thousands Only) with up to date future interest @ 18% p.a. in favour of
the Plaintiff and against the Defendant in the interest of justice;
b. Pass an order directing the defendant not to obtain unlawful possession or
create third party interest in the office property of the plaintiff.
c. Pass order for grant of Litigation Expenses of Rs. 50,000/- in favor of the
Plaintiff;
d. Pass any order or further order(s) or relief as this Hon’ble Court may deem
fit and necessary in the interest of justice.
PLAINTIFF
Through

Advocates, Counsels for Petitioners
Chamber No. , Patiala House Court
New Delhi - 110001
Date: 01.02.2022 (M) +91
Place: New Delhi Email:
VERIFICATION
Verified at Delhi on this 1st day of February 2022 that the contents of above Suit
are true and correct to the best of my knowledge and that no part of it is false
DEPONENT

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DELHI INSTITUTE OF RURAL DEVELOPMENT

GURU GOBIND SINGH INDRAPRASTHA UNIVERSITY,

SCHOOL OF LAW AND LEGAL STUDIES

Course Code – LLB 504 (Internship Law Firm)

I have completed my Internship under the Advocate D. N. Chaturvedi having

I have finalized my internship under Advocate D N Chaturvedi from the month

As I completed my internship under the guidance and supervision of Advocate

Accordingly, the above-mentioned thing which I learned during the period of

IN THE COURT OF HON'BLE CHIEF METROPOLITAN

IN THE MATTER OF:

Smt Shally Vashisth … Complainant

CRIMINAL COMPLAINT UNDER SECTION 156(3) OF THE CODE OF

MOST RESPECTFULLY SHOWETH: -

9. That CA M K Jain collusion With Managing director Mr. Rajnish Nagar

10.That for the purpose of criminal breach of trust, cheating and

(UDIT NAGAR) (DEEPAK SOMANI)

IN THE COURT OF HON’BLE CHIEF METROPOLITAN

IN THE MATTER OF:

Manojit Bera …Complainant

M/s Bhunia Jewellers Pvt. Ltd & Ors …Accused(s)

COMPLAINT UNDER SECTION 138 READ WITH SECTION 142 OF

Most Respectfully Showeth: -

1. That the complainant is a law-abiding citizen who embodies humanism of its

4. That the complainant in the interrengum was in dire need of finances

DATED CHEQUE AMOUNT DRAWN ON DISHONORED

06.07.2021 504608 15,00,000/- SYNDICATE 07.07.2021

Furthermore, on presentation, in the bank account maintained by

6. That the complainant was in dismay and witnessed a situation of a

7. It is imperative to state, that the Accused had deliberately given the

8. That under compelling circumstances, the Complainant was

In the foregoing circumstances, it is most humbly and respectfully prayed

IN THE HON’BLE HIGH COURT OF DELHI, AT NEW DELHI

(UNDER SECTION 482 OF CODE OF CRIMINAL PROCEDURE 1973)

IN THE MATTER OF:

Delhi Tamil Education Association …Petitioner

State of GNCT of Delhi & Anr. …Respondent(s)

PETITION UNDER SECTION 482 OF THE CODE OF CRIMINAL

PROCEDURE, 1973 IS BEING PREFERRED ON BEHALF OF THE

PETITIONER AGAINST THE IMPUGNED ORDER DATED 18.02.2022

PASSED BY MS. AMARDEEP KAUR, LD. METROPOLITAN

MAGISTRATE-06, NEW DELHI, PATIALA HOUSE COURT.

THE HON’BLE CHIEF JUSTICE AND

THE HUMBLE PETITION OF

Procedure is being filed against the order dated 18.02.2022 passed by

Smt. Amardeep Kaur, Ld. Metropolitan Magistrate-06, Patiala House

Court, New Delhi (Henceforth referred as “Magisterial Court”) in CC No.

40029 of 2016 titled as M/s Mallick Brother V. Delhi Tamil Education

Association wherein the Ld. Magisterial Court, has dismissed application

Hon’ble Magisterial Court is annexed herewith as Annexure No. P-1 to

Impugned order and, in any court of law.

4. That no caveat is received in this matter.

Magistrate, Patiala House Court subordinate to this Hon’ble Court which

is within territorial jurisdiction of this Hon’ble Court, conjointly clothing

the requisite jurisdiction to entertain and adjudicate the present lis.

may be delineated thus:

6.1That the Petitioner is an association of Tamil people, whose object is to

disseminate education/knowledge to underprivileged Tamil students with

aid from the Government.

6.2That on 12.07.2010, the Respondent No. 2 had filed a complaint case

under section 138 of the Negotiable Instruments Act,1881, against the

Petitioner/Accused No. 1 which is pending before the Court of Ms.

Amardeep Kaur, Ld. Metropolitan Magistrate-06, Patiala House Court as

C.C No. 40029/2016 titled as M/s Mallick Brother V. Delhi Tamil

Education Association & Anr.