IN THE HON’BLE SESSIONS COURT GREATER MUMBAI

CRIMINAL REVISION APPLN. No. 979 of 2022

SMT. ANITA ASHOK DOHIPHODE … APPLICANT

V/s

THE STATE OF MAHARASHTRA & ORS. … RESPONDENTS

REPLY ON BEHALF OF RESPONDENT NO. 2 TO 4.

We, Shri. Hiralal Gupta, age 65 years, Rameshchandra Gupta, age ___ &
Sunil Gupta, Age: __ years, being respondent no. 2 to 4 in the
abovementioned matter resident of A-3/369, besides Jyoti Tiles, 90 ft
road, Dharavi, Mumbai- 400 017, do hereby state on solemn affirmation
as under.

1. The respondents have read the copy of above Revision Application

filed by Applicant. They are enough competent to file reply to the
application and meanwhile opposing the admission and relief
sought in the prayer of this application. They deny the facts,
averments, contentions and submissions of the petitioner.

2. That the Applicant challenged the order dated 23.08.2022 u/s. 397
of the Cr. P. C. 1973 (hereinafter referred to as the said code)
against the order passed by the Ld. Metropolitan Magistrate at
Bandra in Summons Warrant No. 158 of 2014 filed by Applicant.

3. In reply to para 1 to 4 of Application, the respondent say that these

are the matter of facts, therefore makes no comments.

4. In reply to para no. 5 of application, the respondents vehemently

deny the statement / averments made by applicant in the
application. The applicant made false and made-up story just to
 harass the respondents. The applicant did not come with clear hand
before this Hon’ble court and she does not have any substantial
documents / evidence to prove her case.

5. Infact it’s the applicant and her family members are harassing her
the respondents since many years in term of extortion, threats,
racism, Hafta Vasuli for that the respondents timely made
complainant before the local police station. Some of the complaints
were heard and some of complaint were not lodged by Dharavi
police station as the applicant belongs from Political background
and having influence with politics and police personnels. The
respondent being poor man was fulfilling the extortions of
applicants and her son because he was selling Paanipur on BMC
land on road side which was near Sai Baba Mandir and opp. To
Sankalpana Building where the applicant is residing with her
family members.

6. The statement of para no. 5 (g) is totally false, in past the

respondents had never stated such word to the applicant. The
respondents being poor man are earning his daily wages through
the Paanipuri Stall and due to it they are leaving their life. They do
not have any supports infact none of hawkers have any guts and
power to threat her and her family members. Everybody knows the
applicant and her political supports.

7. In reply to para no. 5 (I) of application, the respondents’ states that

this is a true incident for that the respondents have filed complaint
before the police station against her son. Hereto annexed and
marked is the copy of complaint dated 05.02.2012 as Exhibit A.

8. In reply to para no. 5(j) of application, the respondents deny the

same and submits that the applicant husband has cheated the
respondents fooling them that they will provide one room in Dutt
Guru Society and for that the respondents made complaint written
 complaint to the Hon’ble Home ministry on 07.02.2012. The
respondents have never forged any documents in term of receipt of
Rs. 50,000/- infact the applicant and her husband who have cheated
the respondents fooling them that we will provide the room in the
society. Hereto annexed and marked is the copy of complaint dated
07.02.2012 and copy of receipt as Exhibit B colly.

9. In reply to the para no. 5(k), the statement is true, the respondents
even written complaint to Anti-corruption Bureau against the act of
applicant stating the true incident. The applicant and his family
members use to says to the respondent that You Bhaiya can’t do
anything of us go anywhere. Hereto annexed and marked is the
copy of complaint dated 07.02.2012 as Exhibit C which is a self-
explanatory.

10.In reply to the para no. 5 (n), the respondent states that to make
paper record the complaint filed false NC against us.

11.In reply to para no. 5(O) to (r), the applicant and her family
members use to ask donation in the name of Sai Baba Mandir but
they have never used total donation money for the development of
temple. The applicant have no audit records for the trust. In fact
they have encroached the land of BMC for that BMC authority
have taken action against the illegal act of applicant. We have filed
suit before the Hon’ble City civil court for specific relief sought in
the application and the Hon’ble court passed interim order in
favour of respondents hereto annexed and marked is the copy of
order dated _________ as Exhibit D.

GROUNDS:

i. For that, the Ld. MM court has rightly passed the reasoned and legal
order which does not need any interference.
 ii. For that, the order passed by the Ld. MM court is just, legal and were
passed after following the due process of law, with correct
appreciation of facts and law.

iii. For that the Ld. MM court rightly passed order with observation that
the matter is pertaining to civil in nature so far the case is pending in
the court.

iv. We say that the applicant has filed false and bogus case before Ld.
MM court having no stands, just to waste the time of court and harass
the respondent, the applicants is making complaint before the court.

v. In the aforesaid circumstance the present revision application may

reject with heavy cost.

Solemnly affirmed at Mumbai )

Dated this day of June, 2023 )
(DEPONENT)

(Advocate for the respondents) Before me