State of Maharashtra (CBI) v. Anushka Bajaj

ILS Law College
In the CBI Special Court, Mumbai, Maharashtra
CASE NO. 96 of 2024
State of Maharashtra …Prosecution

(Central Bureau of
Investigation)
v.
Anushka Bajaj …Accused
THE 13th INTRA-COLLEGE TRIAL ADVOCACY COMPETITION 2023-24

STATEMENT OF FACTS
Som Upadhye, 59, the Director of the Intelligence Bureau of India (IB) received intel from the Research and
Analysis Wing (R&AW) regarding unauthorised disclosure of highly confidential information. This information
was known only to the Intelligence Bureau Office, Mumbai. To address this espionage activity, Upadhye called
for a classified meeting with two high-ranking officials of the Mumbai IB office, Mohammad Burma, Deputy
Director of IB Mumbai, and Deb Chhabra, Assistant Central Intelligence Officer of IB Mumbai.He scheduled
the said meeting during his trip to Mumbai for an official conference on “Increasing Chemical Warfare with
Enemy countries”. Before departing for Mumbai, the Director's office dispatched certain confidential
documents, appointing these select individuals to form a special investigating task force. Subsequently,
accommodation arrangements were made for the Director and his section officer, Anushka Bajaj,at the Taj Mahal
Palace Hotel, Mumbai.
On the evening of 16th November 2023, the Director arrived in Mumbai and attended the classified meeting
scheduled with the Mumbai officials. Anushka Bajaj did not accompany the Director to this meeting. The
following morning, 17th November 2023, the Director, his section officer, and his bodyguards were scheduled
to leave for a training seminar. However, the section officer and the bodyguards observed that the Director had
not left his room and was unresponsive to multiple calls and texts. Anushka Bajaj, with the assistance of the
bodyguards and the manager of the hotel, gained access to the Director’s hotel room. Upon entering, they
discovered the Director dead in the bathroom, unclothed, with the shower still running. The police were
immediately called and an FIR was lodged initiating an investigation process by the Mumbai Police.
Meanwhile, on 17th November 2023, upon arrival at the Mumbai IB Office, Mohammad Burma and Deb
Chhabra received the confidential letters sent by the Director. Moments after perusing the contents of the said
letters, they were found dead in their respective cabins. Once again, the police were summoned, an FIR was
lodged, and an investigation process was initiated by the Mumbai Police.
On 18th November 2023, both investigations were assigned to the Central Bureau of Investigation (CBI). A gold
bracelet was found at the crimescene in the Director’s hotel room. Water samples from the bathroom and the
letters read by the IB Officials were sent for a forensic investigation.
Upon conducting a search and seizure of the Director's Office, it was discovered that the Director's computer
device was compromised. A Technical Surveillance Countermeasure (TSCM) conducted in the IB office, Delhi
further revealed that the Director’s Office and Anushka’s antechamber were bugged and compromised.
On 1st December, 2023, a panchnama of Anushka Bajaj’s chambers was conducted where certain incriminating
evidences were found against her. Thereafter, a search and seizure was conducted at the residence of Anushka
Bajaj where the CBI found more evidence that connected her with the crime and the espionage activities.
In a separate investigation conducted by the Enforcement Directorate (ED), one Chetan Kolte was arrested for
operating an illegal Hawala Scheme that had connections with other nations, including China, Nepal,
Bangladesh, etc. He reached a plea bargain admitting his guilt and providing a list of all his clients which
allegedly included Anushka Bajaj. Thereafter, the Investigating Officer, Aayush Trivedi approached Chetan

Kolte to question him about his involvement in the present case and thereby Kolte provided evidence linking
him to Anushka Bajaj.
Based on the evidence collected, the police arrested Anushka Bajaj on 25 th December 2023. Throughout the
questioning, the accused asserted her innocence and claimed that she was being framed by the actual spy within
the organization and that the investigators were involved in this conspiracy.
After completing the investigation, a charge sheet was filed before the CBI Special Court, Mumbai on 12th
January2024.
The matter is listed for final hearing.
*The above facts are undisputed and cannot be challenged.

CHARGESHEET
CENTRAL BUREAU OF INVESTIGATION

MINISTRY OF HOME AFFAIRS
GOVERNMENT OF INDIA
New Delhi
FINAL REPORT
(u/s 173(2) of CrPC)
BEFORE THE HON’BLE CBI SPECIAL COURT,
MUMBAI
State Of Maharashtra (CBI) … Prosecution
v.
Anushka Bajaj … Accused
1. 1. Name of the branch : Special Crimes Division, Central Bureau of

: Investigation, Mumbai
: RC90242023S0786 & RC90232023S7860
FIR No. :
Year 2023
Date 18/11/2023
2. Final Report / Charge Sheet No. : 96/2024
3. Date : 12/01/2024
4. Sections of Law : Section 3 of the Official Secrets Act, 1923.

Sections 7 & 13 of the Prevention of
Corruption Act, 1988, Section 302 of the
Indian Penal Code, 1860 and Section 41 of
the Convention on Chemical Weapons Act,
2000.
5. Type of Final Report Charge Sheet

6 If Final Report : No
Un-occurred- False/ Mistake of

Facts/ Mistake of Law/ Non-
Cognizable/ Civil Nature
7. If charge sheeted:
Original/Supplementary : Original
8. Investigating Officers : Aayush Trivedi, Superintendent of Police, CBI,

Mumbai
9. Complainant/ Source of : 1. Utkarsh Vyas, Manager at Taj Mahal Palace,

Information Mumbai
2.Khushi Gaikwad, Junior Intelligence Officer at
Intelligence Bureau, Mumbai
10. Details of Properties/ Articles/ : As per the Annexures.

Documents recovered/ Seized
during investigation and relied
upon
11. Particulars of accused person

charge sheeted:
(a) Name : Anushka Bajaj
(b) Father’s Name : Anish Bajaj
(c) Age/ Date of Birth : 51 years; 07.12.1972
(d) Sex : Female
(e) Nationality : Indian
(f) Religion : Hindu
(g) Occupation : Government Service
(h) Address (Present) : Flat No. 201, Krisha Apartments,

Connaught Place, New Delhi- 110001

(i) Address (Permanent) : Flat No. 201, Krisha Apartments,
Connaught Place, New Delhi- 110001
(j) Whether Arrested/On Bail/ : Arrested on 25.12.2023. Presently in judicial custody.

Absconding
11. Particulars of accused persons Not : N.A

charge sheeted
12. If FIR is false, action taken : N.A
13. Result of laboratory analysis : As per Annexures
14. Brief of the case:

The instant case RC90242023S0786 and RC90232023S7860 dated 18.11.2023, under Section 302
of Indian Penal Code, 1860; Section 3 of The Official Secrets Act, 1923; Section 7 and Section
13 of the Prevention of Corruption Act, 1988; Section 41 of the Chemical Weapons Convention
Act, 2000 was registered at PS CBI, Mumbai in compliance with the Ministry of Home Affairs,
Government of India, Special Offences division Order Numbers 1169/24/2023/CBI and
1170/24/2023/CBI, dated 18th November 2023 issued under Section 5 ofthe Delhi Special Police
Establishment Act, 1946, against one accused person namely:
1. Anushka Bajaj d/o Anish Bajaj, resident of Flat No. 201, Krisha Apartments, Connaught
Place, New Delhi- 110001
15. Facts disclosed during investigation:
i. The instant case was registered on 18.11.2023 at PS CBI, Mumbai under Section 302 of Indian Penal
Code, 1860. The CBI arrested accused person Anushka Bajaj (hereinafter referred to as A-1) from her
residence in Connaught Place for committing the murder of the then Director of the Intelligence Bureau,
New Delhi, Mr. Som Upadhye (hereinafter referred to as V-1) by planting cyanide pellets in the
Director’s bathroom during his stay at the Taj Mahal Palace, Mumbai.
ii. A-1 is also accused of assassinating two officials of IB Mumbai, Mohammad Burma (hereinafter
referred to as V-2) and Deb Chhabra (hereinafter referred to as V-3) through a nerve agent,
Cyclosarin, by sending letters laced with the same to their respective offices.
iii. V-1 and A-1 were both officials working in the Intelligence Bureau, Delhi (hereinafter referred
to as IB). A-1 was the section officer to the director. A-1 accompanied V-1 in all the work-related
meetings and conferences.

iv. On 16th November 2023, V-1 travelled to Mumbai for an official conference accompanied by A-
1. During his visit to Mumbai, a classified meeting was scheduled with two high-ranking officials
of the IB Mumbai office to address the issue of unauthorised disclosure of confidential
information, known only to the officials of the IB Mumbai office. After arriving in Mumbai, V-1
attended the classified meeting that was scheduled by him and was not accompanied by A-1. After
the meeting, V-1 went to his hotel room. The next day, 17th November 2023, he did not come out
of his room and was not responding to calls or text messages. A-1, with the help of V-1’s
bodyguards and the hotel manager, entered the hotel room. Upon entering, V-1 was found dead
on the bathroom floor unclothed with the shower running. The nearest police station was
immediately contacted to register an FIR and initiate the investigation. Thereafter, Inspector Harsh
Kikle along with a team of other police personnel conducted the panchnama of the spot andinquest
panchnama. The body was then sent to the nearest hospital for a post-mortem examination.
v. Meanwhile, on 17th November 2023, after reaching the Mumbai IB office, the two IB officials,
V-2 and V-3 who attended the confidential meeting the previous day, received letters, sent by V-
1. Moments after opening the letters they were suspiciously found dead in their respective cabins.
The police were called and Inspector Pratham Shete conducted the spot panchnama and inquest
of the two offices. The bodies were sent for post mortem examination to the nearest hospital. The
investigations were transferred to the CBI vide order numbers 1169/24/2023/CBI and
1170/24/2023/CBI to the Special Offences Division on 18th November 2023.
vi. At the crime scene, in Case No. RC90242023S0786, one piece of gold jewellery was recovered
near the hotel room’s door and was sent for forensic examination to Central Forensic Science
Laboratory, Pune (hereinafter referred to as CFSL) vide letter reference number 9231/2023.
Multiple swabs and water samples were also sent to CFSL for examination vide letter reference
number 9231/2023. In the later stages of the investigation, it was revealed that the gold jewellery
item recovered and sent to CFSL bore hallmark number MGM-420. Upon making inquiries with
the seller of the jewellery, it was found that it belonged to A-1. On examination of the swab
samples, traces of Sodium Cyanide were found on the swabs. After this discovery, another
panchnama was conducted of the crime scene, i.e. the Hotel Room. Two white pellets were
recovered each from the tap spout in the shower, the tap spout in the sink, the hand shower, and
the jet spray faucet. These were further sent for chemical examination to CFSL vide letter
reference number 5738/2023. The CFSL reports confirmed that the pellets were Sodium Cyanide.
vii. On inquiring with the hotel management, a report of the door activity of V-1’s hotel room was
obtained which revealed that in his absence, the door was unlocked. This indicates that someone
entered the room during the period when V-1 was not present.
viii. Following the search and seizure, the CCTV footage of the Taj Mahal Palace, Mumbai was sent
to CFSL for analysis vide letter reference no. 4297/2023. The report from the CFSL on the CCTV
footage revealed a vulnerability in the Network Video Recorder's (NVR) firmware. By exploiting
this vulnerability, the attacker gained full control over the device via the internet connection.
Subsequently, during the analysis of the NVR, it was determined that the remote code execution
on the NVR led to the overwriting of a portion of the hard disk, resulting in the loss of the original
video data file. This was the same video file of the time when the act of preparation for the crime
was committed in the hotel. Professional data recovery procedures ultimately resulted in the
retrieval of a pixelated version of the originally deleted video data file.

ix. At the same time, a USB flash drive and a hard disk were collected and sent to CFSL vide letter
reference number 5959/2023, during the search and seizure of the V-1’s office in New Delhi.
According to the report, it was concluded that the USB flash drive was the ingestion point of the
‘Sogu’ malware infecting V-1’s computer system. This malicious software led to the transfer of
sensitive information from the infected computer to a remote server in Pakistan.
x. During the later course of the investigation, on 27th November 2023, a Technical Surveillance
Counter Measures (hereinafter referred to as sweep) was conducted at the IB, Delhi. As a result
of the sweep, two bugs were detected from the offices of V-1 and A-1. The two items were sent
to CFSL, for examination vide letter reference no. 7893/2023. In the scrutiny of the first audio
bug, an “LOA A1 spy microphone” was identified with an almost full microSD card. This device
was linked to a Wi-Fi network, on which a hidden FTP server was established that was accessible
only through a Personal Computer in a Delhi cyber cafe.
xi. On 3rd December 2023, the Investigating Authorities visited the cyber cafe. The owner of the
cyber cafe informed the investigating authorities about the software Burstek that he used for
internet monitoring and history reports for the devices in his cyber cafe. Subsequently, the
investigating authorities procured a user-audit report of a user named “anshb”. The report revealed
that the FTP server with audio data of the IB Office, Delhi, was accessed several times.
Additionally, the Google Drive associated with the Google account- “patriot.ansh@gmail.com”,
contained a significant amount of information stored in it. Furthermore, there were certain links
about the purchase of a PPE kit from Amazon and a microphone bug.
xii. Simultaneously, at the crime scene in case no. RC90232023S7860 a few letters, two opened and
two unopened, were recovered. These letters were then sent for forensic examination to CFSL,
vide letter reference number- 4837/2023. After receiving the CFSL report of the same, it was
discovered that the letters and their envelopes carried a nerve agent 'Cyclosarin’ on them, which
was the same substance used in the assassination of V-2 and V-3. In one of the diaries seized from
the office of V-3, the minutes of the classified meeting conducted on 16 November 2023 were
found. The minutes of the meeting disclosed that V-1 suspected that there was a spy in the IB with
A-1 being one of the suspects.
xiii. Based on the evidence found, on 2nd December, a search warrant was obtained to conduct the
search and seizure of A-1’s office. Upon completion of the search, a few units of opened and
unopened gloves, an empty glass bottle and multiple cotton swabs were sent for examination to
CFSL vide letter reference number- 9234/2023. The results of the same showed that the items
sent for examination had traces of cyclosarin in them. Following this, the investigating authorities
obtained another warrant for the search and seizure of A-1’s house. During the search and seizure,
four units namely a hard disk of an Apple Macbook Pro, a Xiaomi Mi 10i, a transparent packet
found in a jewellery pouch and a packet of Humulin R U-100 were seized and sent to CFSL vide
letter reference number-9769/2023. Upon examination of A-1’s laptop hard disk, a confidential
document belonging to the IB was found. Additionally, A-1’s mobile device had an in-built
isolated space, which upon detailed decryption was found to be ‘Second Space’. In the second
space, one contact, “Chetan HWL” and cryptic conversations between an international number
and A-1 on the Viber app were found. The messages upon decoding were found to be an exchange
of sensitive information by Anushka to China. Furthermore, among the items recovered was a
jewellery pouch, inside which a transparent pouch containing a white substance was found.
According to the CFSL report the white substance found in the pouch was Sodium Cyanide.

xiv. Chetan Kolte was a hawala trader, convicted of a previous offence and was serving his sentence
in judicial custody. He was contacted by the investigating authorities. Kolte agreed to disclose
information regarding persons involved in the illegal transfer of money in exchange for a plea
bargain. During the inquiry, it was found that A-1 was his client. He testified that A-1 regularly
used to receive money from someone in China through him.
xv. Based on the evidence collected during the investigation, it was established that A-1 was
supplying sensitive intel to unknown persons in China for financial gains. After having known the
agenda of the confidential meeting held between V-1, V-2 and V-3 and to conceal the illegal acts
committed by her, A-1 committed the murders of the three officials by using poison and a nerve
agent. A-1 thereby committed offences punishable under Section 302 of the Indian Penal Code,
1860; Section 3 of The Official Secrets Act, 1923; Section 7 and Section 13 of the Prevention of
Corruption Act, 1988; Section 41 of the Chemical Weapons Convention Act, 2000
16. CHARGES:
1. The investigation has disclosed that A-1 has committed the offence of spying by leaking
confidential documents to China, thus attracting the provisions of section 3 of the Official
Secrets Act, 1923.
2. The investigation has disclosed that A-1 received money for performing her public duty
dishonestly, thereby attracting the provisions of section 7 & 13 of the Prevention of
Corruption Act, 1988.
3. The investigation has disclosed that A-1 has committed the offence of murdering 3 officials
working with the Intelligence Bureau with the help of a nerve agent and a poisonous
substance thereby committing the offence under section 302 of the Indian Penal Code, 1860.
4. The investigation has also disclosed that A-1 has procured and administered Cyclosarin a
prohibited nerve agent thereby committing the offence under section 41 of the Convention
on Chemical Weapons Act, 2000.
5. Therefore, it is respectfully prayed that this Hon’ble Court may be pleased to take cognizance
of this charge sheet filed under Section 173 (2) CrPC and issue due processes against A-1 per
law, to face trial
17. Dispatched on : 12.01.2024
18. No. of Annexures : 46
(Manva Kothari)
Director
Central Bureau of Investigation
Delhi
Forwarded by:
(Aayush Trivedi)
Deputy Superintendent of Police (IO)
Central Bureau of Investigation,
Mumbai
ANNEXURE I
FIRST INFORMATION REPORT
(u/s. 154 CrPC)
Serial No. 010/2023 Book No. 02
District : Mumbai Police Station : SCB Mumbai
YEAR : 2023
FIR No. : RC90242023S0786 Date : 18/11/2023
1. Acts & Section
Acts Sections R/W Section

IPC, 1860 302
Chemical Weapons Convention 41
Act,2000
2. Suspected Offence: Murder

(a) Occurrence of offence
Day: Friday Time Period: N.A
From Date: 17/11/2023 To Date: N.A
(b) Information received at P.S.: Letter
Date: 18/11/2023
(c) General Diary Reference Entry No.: 4 of 18th November
Date: 18/11/2023 Time: 11:15am
3. Type of Information: Written
4. Place of Occurrence: Mumbai
a) Direction and distance from P.S.:42 km (Approx)
b) Beat No.

c) Address: Taj Mahal Palace, Mumbai, Apollo Bandar, Colaba, Mumbai, Maharashtra 400001
d) In case outside the limit of Police Station, then name of P.S: N.A.
5. Complainant/Informant:
(a) Name: Utkarsh Vyas, Manager, The Taj Mahal Palace, Mumbai.
(b) Father’s Name: Mr. Raj Vyas
(c) Date of Birth: 28/08/1990
(d) Nationality: Indian
(e) Occupation: Manager
(f) Address: Flat No. 205, Priyanka Society, Fort, Mumbai.
(g) Telephone No.: 7000475533
6. Details of known/suspected/unknown accused with full particulars:
Name: unknown person(s)
7. Reasons for delay in reporting by the complainant/informant: No Delay
8. Particulars of the property stolen: N.A.
9. Total value of the property stolen: N.A.
10. Inquest Report/U.D. Case No., If any: B343T
11. F.I.R. Contents-
11.1. The Central Government, on receipt of information regarding the registration of an FIR no. 131/2023,
dated 17/11/2023, registered at Colaba PS, Mumbai city, Maharashtra u/s 302 of I.P.C, 1860, relating
to the death of the Director of Intelligence Bureau in the Taj Mahal Palace Mumbai, assigned the case
to the Central Bureau of Investigation.
11.2. The contents of FIR No.131/2023 are reproduced as under-
On 17th November, 2023 Utkarsh Vyas, Manager at Taj Mahal Palace, Mumbai found the body of Mr.
Som Upadhye, Director Intelligence Bureau, New Delhi on the floor of the bathroom of his hotel room.
Utkarsh Vyas who found the body filed an FIR shortly. Thus, an FIR has been filed against an unknown
accused u/s 302 of the Indian Penal Code.

12. Action taken: Since the above information reveals commission of offence(s) u/s as mentioned at item
no. 2:
1) Registered the Case and took up the investigation: Yes
OR
2) Directed the following IO to investigate the case
Name of IO: Aayush Trivedi
Rank: Superintendent of Police
No.: 133127
To take the investigation
OR
3) Refused inestigation due to:
OR
4) Transferred to PS: District:

On point of jurisdiction.
Attached documents:
Document name
F.I.R. is read over to the complainant/informant, admitted to be correctly recorded and copy given to
the complainant/informant, free of cost.
R.O.A.C.
13.

Signature/Thumb Impression of Signature of Officer In-charge
the complainant/ informant Police Station
Name: Aayush Trivedi
Rank: SUPDT. OF POLICE
SCB Mumbai
14. Date and time of dispatch to the court:
Digitally signed by AAYUSH TRIVEDI

Date:18/11/2023 11:05:23 IST
Enclosures:
1. Copy of FIR No. 131/2023 dated 17/11/2023 at Colaba PS, Mumbai, Maharashtra
2. Government of India, Ministry of Home Affairs, IS-I Division Order No.1169/24/2023/CBI dtd
18/11/23.

ENCLOSURE I
(u/s. 154 Cr.PC.)
District : Mumbai City Police Station : Colaba Police

Station
FIR No. : 131/2023 Date : 17/11/2023
1. Act: Indian Penal Code; Section 302
2. (a) Occurrence of offence
Date from: 17/11/2023 Date to: N.A
Time Period: N.A
(b) Information received at P.S.:
Date: 17/11/2023 Time: 8:22 A.M.
3. Type of Information: Oral
4. Place of Occurrence:
(a) Direction and distance from P.S.: 600 m, West
(b) Address: The Taj Mahal Palace, Apollo Bandar, Colaba, Mumbai, Maharashtra, 400001
(c) In case outside the limit of Police Station, then name of P.S: N.A.
(a) Name: Utkarsh Vyas, Manager, The Taj Mahal Palace, Mumbai.
(b) Father’s Name: Mr. Raj Vyas

(e) Occupation: Manager
(f) Address: Flat No. 205, Priyanka Society, Fort, Mumbai.
On 17th November, 2023 Utkarsh Vyas, Manager at Taj Mahal Palace, Mumbai found the body of Mr.
Som Upadhye, Director Intelligence Bureau, New Delhi on the floor of the bathroom of his hotel room.
Utkarsh Vyas who found the body filed an FIR shortly. Thus, an FIR has been filed against an unknown
accused u/s 302 of the Indian Penal Code.
11. Action taken:
Since the above report reveals commission of offence u/s. 302 of the Indian Penal Code, 1860
(a) Directed/Entrusted (Name of I.O.): Pratham Shete, Rank: Inspector, PIS No. 473 to take up
the investigation.
Sd/-
Name: Pratham Shete,
Inspector, Colaba Police Station
(b) Signature/Thumb impression of complainant/informant:
Sd/-
Name: Utkarsh Vyas
Manager, The Taj Mahal Palace, Mumbai.
Enclosures:

ENCLOSURE II
TRANSFER ORDER
No.1169/24/2023/CBI
Government of India
DG/CBI/MHA/Ministry of Home Affairs IS-I Division
*****
BKC, Mumbai
Dated 18th November of 2023
Whereas, the Central Government has received information about murder which claimed the life of the Director
of IB by an unknown accused. Accordingly, case FIR No. 131/2023 dated 17/11/2023 was registered at Colaba
police station, District Mumbai, Maharashtra under section 302 of Indian Penal Code, 1860 against unknown
accusedperson(s).
And whereas, the Central Government is of the opinion that a Scheduled offence under The Delhi Special Police
Establishment Act, 1946, has been committed and having regard to the gravity of the offence and its
ramifications on national security, it is required to be investigated by the Central Bureau of Investigation in
accordance with The Delhi Special Police Establishment Act, 1946.
Now, therefore, in the exercise of the powers conferred under Section 5 of The Delhi Special Police
Establishment Act, 1946, the Central Government hereby directs the Central Bureau of Investigation to take up
the investigation of the aforesaid case.
Sd/-
(Siddhesh Kant)
Under Secretary to the Government of India
To:-
1. The Director, Central Bureau of Investigation, 13th Floor, Plot No. C-35A, 'G' Block, Bandra Kurla
Complex, Bandra East, near MTNL Exchange, Mumbai
2. Chief Secretary to Government of Maharashtra
3. DGP, Maharashtra
Office of the Director/CBI

Diary no: 321/2023
Date: 18/11/2023

ANNEXURE II
(u/s. 154 CrPC)
District: Mumbai Police Station : SCB Mumbai
YEAR: 2023
FIR No.: RC90232023S7860 Date: 18/11/2023
1. Acts & Section
Acts Sections R/W Section

IPC,1860 302
Chemical Weapons Convention 41
Act, 2000
2. Suspected Offence: Murder
a) Occurrence of offence
Day: Friday Time Period: N.A
From Date: 17/11/2023 To Date: N.A
b) Information received at P.S.: Letter

Date: 18/11/2023
c) General Diary Reference Entry No.: 5
Date: 18/11/2023 Time: 11:20 AM
3. Type of Information: Written

4. Place of Occurrence: Mumbai
(a) Direction and distance from P.S.: 33 KM (Approx)
(b) Beat No.
(c) Address: Subsidiary Intelligence Bureau, Block – E, Plot- C, Bandra Kurla Complex,
Bandra (E), Mumbai 400051.
(d) In case outside the limit of Police Station, then name of P.S: N.A.
(a) Name: Khushi Gaikwad, Junior Intelligence Officer, Intelligence Bureau, Mumbai.
(b) Father’s/ Husband’s Name: Mr. Bhupendra Gaikwad
(e) Occupation: Government Service
(f) Address: Flat No. 303, Dheeraj Society, Bandra E, Mumbai.

10. Inquest Report/U.D. Case No., If any: G877T and G876T
a) The Central Government, on receipt of information regarding the registration of an FIR no. 947/2023
dated 17/11/2023 registered at BKC Police Station Mumbai city, Maharashtra u/s 302 of I.P.C. relating
to the death of two Intelligence Bureau Officers i.e. Deputy Director & Assistant Central Intelligence
Officer at Subsidiary Intelligence Bureau Office Mumbai assigned the case to Central Bureau of
Investigation.
b) The contents of FIR No. 947/2023 are reproduced as under-
On 17th November, 2023 Khushi Gaikwad, Junior Intelligence Officer at IB office Mumbai found
bodies of the Deputy Director & the Assistant Central Intelligence Officer of IB, Mumbai, in their
respective offices. Khushi Gaikwad who found the body filed an FIR shortly. Thus, an FIR has been
filed against an unknown accused u/s 302 of the Indian Penal Code, 1860.
12. Action taken: Since the above information reveals commission of offence(s) u/s as mentioned at
item no. 2:
1) Registered the Case and took up the investigation: Yes
OR
2) Directed the following IO to investigate the case
Name of IO: Aayush Trivedi
Rank: Superintendent of Police
No.: 133127
To take the investigation
OR
3) Refused investigation due to:
OR
4) Transferred to PS: District:

On point of jurisdiction.
Attached documents:
Document name
R.O.A.C.
13.
Signature/Thumb Impression of Signature of Officer In-charge
the complainant/ informant Police Station
Rank: SUPDT. OF POLICE
SCB Mumbai
14. Date and time of dispatch to the court:
Digitally signed by AAYUSH TRIVEDI

Date: 18/11/2023 11:21:35 IST
Enclosures:
1. Copy of FIR No. 947/2023 dated 17/11/2023 at BKC PS, Mumbai, Maharashtra
2. Government of India, Ministry of Home Affairs, IS-I Division Order No.1170/24/2023/CBI dtd
18/11/23.

ENCLOSURE I
(u/s. 154 Cr.PC.)
District : Mumbai City Police Station : BKC Police

Station
FIR No. : 947/2023 Date : 17/11/2023
1. Act: Indian Penal Code; Section 302
2. (a) Occurrence of offence
Date from: 17/11/2023 Date to: N.A
Time Period: N.A
(b) Information received at P.S.:
Date: 17/11/2023 Time: 8:35 A.M.
3. Type of Information: Oral
4. Place of Occurrence:
(a) Direction and distance from P.S.: 1.9 km, South-West
(b) Address: Subsidiary Intelligence Bureau, Block E, Plot C, Bandra Kurla Complex,
Bandra (E), Mumbai 400051
(c) In case outside the limit of Police Station, then name of P.S: N.A.

5.
(a) Name: Khushi Gaikwad, Junior Intelligence Officer, Intelligence Bureau, Mumbai.
(b) Father’s/ Husband’s Name: Mr. Bhupendra Gaikwad
(e) Occupation: Government Service
(f) Address: Flat No. 303, Dheeraj Society, Bandra E, Mumbai.
On 17th November, 2023 Khushi Gaikwad, Junior Intelligence Officer at IB office Mumbai found
bodies of the Deputy Director & the Assistant Central Intelligence Officer of IB, Mumbai, in their
respective offices. Khushi Gaikwad who found the body filed an FIR shortly. Thus, an FIR has
been filed against an unknown accused u/s 302 of the Indian Penal Code, 1860.
12. Action taken:
Since the above report reveals the commission of offence u/s. 302 of the Indian Penal Code, 1860.
(a) Directed/Entrusted (Name of I.O.): Harsh Kikle, Rank: Inspector, PIS No. 473 to take up the
investigation.

Sd/-
Name: Harsh Kikle ,
Inspector, BKC Police Station
(b) Signature/Thumb impression of complainant/informant:
Sd/-
Name: Khushi Gaikwad
Junior Intelligence officer,
Subsidiary Intelligence Bureau, Mumbai.
F.I.R. is read over to the complainant/informant, admitted to be correctly recorded and a copy
given to the complainant/informant, free of cost.

ENCLOSURE II
TRANSFER ORDER
No.1170/24/2023/CBI
Government of India
DG/CBI/MHA/Ministry of Home Affairs IS-I Division
*****
BKC, Mumbai
Dated 18th November of 2023
Whereas, the Central Government has received information about murders which claimed the lives of 2 people,
the Head of IB Office Mumbai and an Assistant Central Intelligence Officer by an unknown accused.
Accordingly,case FIR No. 947/2023 dated 17/11/2023 was registered at BKC police station, District Mumbai,
Maharashtra under section 302 of Indian Penal Code, 1860 against unknown accused person(s).
And whereas, the Central Government is of the opinion that a Scheduled Offence under The Delhi Special Police
Establishment Act, 1946, has been committed and having regard to the gravity of the offence and its
ramifications on national security, it is required to be investigated by the Central Bureau of Investigation in
accordance with The Delhi Special Police Establishment Act, 1946.
Now, therefore, in exercise of the powers conferred under Section 5 of The Delhi Special Police Establishment
Act, 1946, the Central Government hereby directs the Central Bureau of Investigation to take up investigation
of the aforesaid case.
Sd/-
(Siddhesh Kant)
Under Secretary to the Government of India
To:-
1. The Director, Central Bureau of Investigation, 13th Floor, Plot No. C-35A, 'G' Block, Bandra Kurla
Complex, Bandra East, near MTNL Exchange, Mumbai
2. Chief Secretary to Government of Maharashtra
3. DGP, Maharashtra
Office of the Director/CBI

Diary no: 322/2023
Date: 18/11/2023

ANNEXURE III
SANCTION ORDER
Government of India
Ministry of Home Affairs
Subject: Accord of sanction for prosecution of public servant namely, Ms. Anushka Bajaj D/o Anish Bajaj,
for commission of offences punishable u/s 302 of Indian Penal Code 1860, Section 3 of Official Secrets
Act 1923, Sections 7 and 13 of Prevention of Corruption Act and Section 41 of the Chemical Weapons
Convention Act, 2000 in case FIR Nos. RC90242023S0786 and RC90232023S7860 P/S CBI, Mumbai.
Reference: FIR Nos. RC90242023S0786 and RC90232023S7860
Government Order No.: 15-PW(MHA) of 2024
Dated: 10.01.2024
In terms of Section 197 of the Code of Criminal Procedure, 1973 & Sec 19 of Prevention of Corruption
Act, 1988 sanction is hereby accorded to the prosecution of the accused Section officer, Intelligence
Bureau, namely Ms. Anushka Bajaj, D/o Anish Bajaj and R/o Flat No. 201, Krisha Apartments, Connaught
Place, New Delhi- 110001 for commission of offences punishable u/s 302 of Indian Penal Code 1860,
Section 3 of Official Secrets Act 1923, Sections 7 and 13 of Prevention of Corruption Act and Section 41
of the Chemical Weapons Convention Act, 2000 in case FIR Nos. RC90242023S0786 and
RC90232023S7860 P/S CBI, Mumbai. By order of the Government of India.
Sd/-
(Chirayu Patni) IAS

Principal Secretary to the Government

ANNEXURE IV
INQUEST PANCHNAMA
District: Mumbai City PS: Colaba

Date: 17.11.2023
1. The substance of the information obtained by the magistrate and from whom.
The Magistrate received information about a case of unnatural death of 1 person at the Taj Mahal Palace
Hotel, Mumbai by Inspector Pratham Shete.
2. The place where the body of the deceased was found.
Room 406, Taj Mahal Palace Hotel, Colaba, Mumbai, Maharashtra.
3. Inquest
(a) Commenced at….09:00 AM........ on ......17/11/2023. (Date)
(b) Closed at ……..09:25 AM............ on ....17/11/2023. (Date)
Dead body identified by (their names and essential particulars), Relatives may Identify, if relatives are
not available those who had known the deceased may identify.
Ms. Anushka Bajaj, Section Officer to the deceased

Mr. Aaditya Jinde, personal security officer to the deceased.
Mr. Vedansh Khandelwal, personal security officer to the deceased.
4. Marks of identification, if any, such as moles, scars etc.
Mole on left forearm.
5. Name parentage, sex, age, caste and residence of the deceased.
Som Upadhye, Male, 59 Yrs, Caste: Unknown, Residence: Delhi
6. Relatives, if any, present at the inquest (their names, addresses and relationship with the
deceased)
None
7. Names and other necessary particulars of two local and respectable witnesses in whose
presence the inquest was held. (It is not mandatory but desirable)

Navnisha Bajpayee, 104, Gosar Heights, Colaba, Mumbai.
Vishank Surana, 121, Palekar Apartments, Colaba, Mumbai.
8. Description of the corpse (after close observation of all parts of the body in good light, generally
under sunlight during daytime), cavities such as those pertaining to nose, ear, mouth, etc. should
be closely examined.
Note down the following features:
a) Position and attitude of the body.

Lying face up with no other injuries.
b) Number, position, length, breadth and direction of wound(s) (not depth)
There are no wounds visible on the body.
c) Nature of wounds-incised, lacerated, bruises, fractures (so far they are visible on the
external examination and could be ascertained by a non-medical person).
None.
d) Signs of ligature marks if any.
None.
e) Signs of inflammatory reaction (swelling etc.) if any.
Body has turned cherry red
f) Position of limbs, eyes and mouth.
Palms open, one eye rolled upwards, mouth open.
g) Presence of blood (liquid or clotted), saliva, froth, vomit, semen, swabs etc. (if any)
None
h) Condition of clothes/ornaments.
No clothes found on spot.
9. Is the body well-nourished and vigorous or emancipated and weak?
Well-nourished and vigorous.
10. Viewing of the surroundings in their totality with the dead body lying therein.
Note down the following:

a) Marks of violence or struggle.
None
b) Articles such as rope, weapon, ammunition, phial, used cartridge, chemicals etc.
None
c) Suicide note, if any.
None
d) Foreign matters such as weeds, straws etc. in the hair or clenched to the hands of the
deceased or attached to part of the body.
None.
e) Are there circumstances available in the scene to show that the deceased killed
himself/herself?
No
f) Do you notice anything in the surroundings to suspect foul play?
Yes, bitter almond odour present in the bathroom.
11. Number and Names of the witnesses examined by the Magistrate and substance and weight of
their evidence (the evidence to be recorded on separate sheet of paper)
To be done by the police.
12. Opinion of the Magistrate as to the cause of death as could be ascertained by him, based on his
inspection of the scene, close examination of the dead body and evidence adduced by the witnesses.
Death due to unknown reasons.
13. Whenever there are wounds, fractures, bruises and other marks of injury as may be found on the
body the Magistrate should state in what manner or by what weapon or instrument, if any, such
injuries/marks appear to have been caused.
None
14. Sketch plan of the place where the dead body is found & photograph taken, if any.
Attached.
15. Has the Magistrate held the inquest in addition to or in lieu of the Police investigation
u/s 174/175 CrPC?
In addition to the police investigation.

16. Upon consideration of the totality of the material including the examination of the dead body,
inspection of the scene & testimony of the witnesses, are there grounds for suspecting foul play?
There are grounds to believe that this could be a case of murder.
17. Is it a case where the person died in police custody?

No
18. Action proposed to be taken, if any, in pursuance of the Magisterial inquest.
The body is to be sent for autopsy. Evidence collected during spot panchnama is to be sent for
forensic analysis. Statements of witnesses are to be recorded by the police.
Signatures of the persons present as mentioned in item 8.
Sd/- Sd/-
Navnisha Bajpayee Vishank Surana
Name of the Magistrate-:Ved Khatwani
Signature of the Magistrate with date & seal-:

Sd/-
MEMO NO ...................B343T.....................................DATE ...... 17/11/2023
Copy to:
Executive Magistrate: Akash Shrivastav

SITE MAP
KEY
Spot of Death -X
Doors- 1
Tables- 2
Shower- 3
Toilet- 4
Sink- 5
Coffee Table- 6
Closet- 7
Bed- 8
Window- 9

ANNEXURE V
INQUEST PANCHNAMA
District: Mumbai City PS: BKC
Date: 17.11.2023
The Magistrate received information about a case of unnatural death of 2 persons at Subsidiary
Intelligence Bureau, Ministry of Home Affairs, Government of India, Block-E, Plot-C, Bandra-Kurla
Complex, Bandra (E), Mumbai by Inspector Harsh Kikle.
Subsidiary Intelligence Bureau, Ministry of Home Affairs, Government of India, Block-E, Plot-C,
Bandra-Kurla Complex, Bandra (E), Mumbai.
3. Inquest
(a) Commenced at 9:23 AM on 17/11/2023.
(b) Closed at 9:58 AM on 17/11/2023.
4. Dead body identified by (their names and essential particulars), Relatives may Identify, if
relatives are not available those who had known the deceased may identify.
Aafreen Basu, Assistant Section Officer
Two thumbs on the left hand.
6. Name, parentage, sex, age, caste and residence of the deceased.
Mohammad Burma, Male, 57, Caste: Unknown, Address: Mumbai
7. Relatives, if any, present at the inquest (their names, addresses and relationship with the deceased)
None
8. Names and other necessary particulars of two local and respectable witnesses in whose
presence the inquest was held. (It is not mandatory but desirable)
Asmita Vaishnav, 111, Blue Bells Park, Shastri Colony, Bandra Kurla Complex, Mumbai.

Neha Karnatak,777, Green Woods Society, Bandra-Kurla Complex
9. Description of the corpse (after close observation of all parts of the body in good light, generally
The deceased was found sitting in his chair, with his head on the table
None
c) Nature of wounds-incised, lacerated, bruises, fractures (so far they are visible on the
external examination and could be ascertained by a non-medical person).
None
None
None.

Palms clenched, both eyes rolled upwards, mouth open
Vomit on the table.
h) Condition of clothes/ornaments
Shirt soiled with vomit
Well-nourished and vigorous

None
None
None
d) Foreign matters such as weeds, straws etc in the hair or clenched to the hands of the
deceased or attached to part of the body.
Crumpled letter in his hand
e) Are there circumstances available in the scene to show that the deceased killed
himself/herself?
No
Yes
12. Number and Names of the witnesses examined by the Magistrate and substance and weight of
their evidence (the evidence to be recorded on separate sheet of paper)
Death due to unknown reasons
None
Attached.
16. Has the Magistrate held the inquest in addition to or in lieu of the Police investigation
u/s 174/175 CrPC?

Yes, foul play is suspected and there is a possibility of murder

No
Body is to be sent for autopsy. Evidence collected during the spot is to be sent for forensic analysis.
Statements of witnesses are to be recorded by the police.
Sd/- Sd/-
Asmita Vaishnav Neha Karnatak
Name of the Magistrate-: Sanya Bansod
Signature of the Magistrate with date & seal-: Sd/-
MEMO NO ...................G877T.....................................DATE ...... 17/11/2023
Copy to:
Executive Magistrate: Koonjal Agarwal

SITE MAP

ANNEXURE VI
INQUEST PANCHNAMA
District: Mumbai City PS: BKC
Date: 17.11.2023
The Magistrate received information about a case of unnatural death of 2 persons at Subsidiary
Intelligence Bureau, Ministry of Home Affairs, Government of India, Block-E, Plot-C, Bandra Kurla
Complex, Bandra (E), Mumbai by Inspector Harsh Kikle.
Subsidiary Intelligence Bureau, Ministry of Home Affairs, Government of India, Block-E, Plot-C, Bandra
Kurla Complex, Bandra (E), Mumbai.
3. Inquest
(a) Commenced at….10:10AM........ on ...... 17/11/2023.
(b) Closed at ……..10:43 AM............ on .... 17/11/2023.
4. Dead body identified by (their names and essential particulars), Relatives may Identify, if relatives
are not available those who had known the deceased may identify.
Vansh Kothari, Security Assistant.
Birthmark on the right of the forehead.
6. Name parentage, sex, age, caste and residence of the deceased.
Deb Chhabra, Male, 58 Yrs, Caste: Unknown, Residence: Mumbai
7. Relatives, if any, present at the inquest (their names, addresses and relationship with the deceased)
None
8. Names and other necessary particulars of two local and respectable witnesses in whose presence the
inquest was held. (It is not mandatory but desirable)

Ved Singh, 102 Green Park, BKC, Mumbai.
Divya Nagre, 304 Ring Garden, BKC, Mumbai.
9. Description of the corpse (after close observation of all parts of body in good light, generally

Lying sideways on the floor.

None.
c) Nature of wounds-incised, lacerated, bruises, fractures (so far they are visible on the external
examination and could be ascertained by a non-medical person).
Bruise on the left side of the forehead.

None.

None.

Palms open, both eyes open, blood clot in left eye, mouth open.
Slight frothing near the corner of the deceased’s mouth.
h) Condition of clothes/ornaments.
Soiled trousers with urinal and faecal matter.
Well-nourished and vigorous.

None
None
None
d) Foreign matters such as weeds, straws etc in the hair or clenched to the hands of the deceased or
attached to part of the body.
No
e) Are there circumstances available in the scene to show that the deceased killed himself/herself?
No
Yes
12. Number and Names of the witnesses examined by the Magistrate and substance and weight of their
evidence (the evidence to be recorded on separate sheet of paper)
Death due to unknown reasons.
Bruise on the head caused due to falling from the chair.
Attached.
16. Has the Magistrate held the inquest in addition to or in lieu of the Police investigation u/s 174/175
CrPC?

There are grounds to believe that this is a case of murder.
No
The body is to be sent for autopsy. Evidence collected during the spot is to be sent for forensic analysis.
Statements of witnesses are to be recorded by the police.

Sd/- Sd/-
Ved Singh Divya Nagre
Name of the Magistrate: Sanya Bansod
Signature of the Magistrate with date & seal-: Sd/-
MEMO NO ............................G876T………….......................................DATE ........................... 17/11/2023
Copy to:
Executive Magistrate: Koonjal Agarwal

SITE MAP

ANNEXURE VII
SPOT PANCHNAMA
Date, hour and minute of beginning the Panchnama: 17/11/23 9:40 AM

Date, hour and minute of ending the Panchnama: 17/11/23 10:43 AM
Pancha No. 1
Mr. Keyur Mishra, Age 40
Occupation: Business
Residing at: Flat 202, Marvel apartments, Battery St., Colaba, Mumbai, 400001.
Pancha No. 2
Ms. Mrudula Solanki, Age 25
Occupation: Engineer
Residing at: Flat 301, DC Apartments, Battery St., Colaba, Mumbai, 400001.
We, the above-named panchas were called by Inspector Pratham Shete at about 9:20 AM on 17th November
2023, to Taj Mahal Palace, Apollo Bandar, Colaba, Mumbai- 400001. He informed us that the Deputy
Director of the Intelligence Bureau was found dead and requested us to act as panchas for conducting the spot
panchnama. We agreed to act as panchas. When we reached there, Inspector Pratham Shete along with
Constable Parulekar and his team were present at the spot.
The room is numbered 406 and is approximately 323 sq. ft. in dimension. It has a bedroom and a bathroom.
As you enter the room, the entrance to the bathroom is on the left. The bathroom has a shower and a wash
basin. As you enter the bathroom, you will see the shower cubicle.
The Director was found on the floor of the shower cubicle. There were no signs of struggle or force. One
iPhone 14 smartphone was also found in the room. A piece of gold jewellery was found near the entrance of
the bathroom.
Inspector Shete seized, sealed and marked all the following items in our presence and in the presence of
Constable Parulekar:
1. 1 X iPhone 14 (smartphone)
2. 1 X piece of gold jewellery
3. 1 X Bottle of Body Soap
4. Water sample
5. Sink swab
6. Shower Swab
We, along with Inspector Shete signed on the labels of the six seized items. Except for the above articles
nothing else was seized by the police in our presence.

The panchnama was conducted in a peaceful manner and it was completed at about 10:43 AM, on 17th
November 2023. The items seized were entrusted to Inspector Pratham Shete who recorded the details of the
above-mentioned articles in the Malkhana Sub Module. Both of us, Panchas have read the contents of the
panchnama. The same is correctly recorded.
Sd/-
Pratham Shete
Investigating Officer
Colaba P.S., Mumbai.
Witnesses-
Sd/- Sd/-
Mr. Raaj Mishra Mrs. Mrudula Solanki
Flat 202, Marvel Apartment Flat 301, DC Apartment
Battery St., Colaba Battery St., Colaba
Mumbai 400001 Mumbai 400001

ANNEXURE VIII
SPOT PANCHNAMA

Pancha No. 1
Mr Keshav Nanda., age 37 years
Occupation: Businessman
Residing at: Flat 230, Anandmayee Apartments, G block, BKC, Valmiki Nagar, Bandra (E), Mumbai, 400051
Pancha No. 2
Mr. Aaryan Chohan, age 47 years
Occupation: Lawyer
Residing at: 10 BKC, near MIG Cricket Club, Kala Nagar, Bandra (E), Mumbai, 400051.
We the above-named panchas were called by Inspector Harsh Kikle at about 09:48 AM on 17th November
2023. He informed us that the Deputy Director of Intelligence Bureau, Mumbai was found dead in his office
chamber and requested us to act as panchas for conducting the spot panchnama. We agreed to act as panchas.
When we reached there, Inspector Harsh Kikle along with Constable Manoharan and his team were present at
the spot.
The cabin is approximately 275 sq. ft. in dimension. There is one entrance to the cabin and four windows. As
you enter the chamber through the lobby, there is a desk in the center of the room with four chairs—three in
front of the desk and one behind the desk. Two windows are situated towards the left side of the desk while the
other two are situated behind the desk. There is a table and a chair on the left corner of the room, with respect
to the entrance. On the desk, there is a computer, a keyboard, a day planner and an opened envelope. Inspector
Harsh Kikle took us to the spot where the Deputy Director was found dead.
Inspector Harsh Kikle seized, sealed and marked all the following items in our presence and in the presence of
Constable Manoharan:
1. 1 opened envelope
2. 1 letter marked confidential
3. 1 day-planner
4. 1 CPU
We, along with Inspector Harsh Kikle signed on the labels of the four seized items. Except
for the above articles, nothing else was seized by the police in our presence.
November, 2023. The items seized were entrusted to Inspector Harsh Kikle who
recorded the details of the above-mentioned articles in the Malkhana Sub Module. Both of us
panchas have read the contents of the panchnama. The same is correctly recorded

Sd/-
Harsh Kikle
Witnesses:
Sd/- Sd/-
Mr. Keshav Nanda Mr. Aaryan Chohan
Flat 230, Anandmayee Apartments, G block, BKC, 10 BKC, near MIG Cricket Club, Kala Nagar,
Valmiki Nagar, Bandra (E), Mumbai, 400051 Bandra (E), Mumbai, 400051

ANNEXURE IX
SPOT PANCHNAMA

Pancha No. 1
Mrs. Rutuja Dalvi, age 58 years
Occupation: Teacher
Residing at: Flat 420, Khinvasara Paradise, ND Road Mumbai, 400051.
Pancha No. 2
Ms Aastha Shinde, age 44 years
Occupation: Stockbroker
Residing at: Flat 110, Annapurna Society, ND Road, BKC, Mumbai, 400051.
We the above-named panchas were called by Inspector Harsh Kikle at about 10:45 AM on 17th November
2023. He informed us that the Assistant Central Intelligence Officer, Mumbai was found dead in his office
chamber and requested us to act as panchas for conducting the spot panchnama. We agreed to act as panchas.
When we reached there, Inspector Harsh Kikle along with Constable Manoharan and his team was present at
the spot.
The cabin is approximately 275 sq. ft. in dimension. There is one entrance to the cabin and one window. As you
enter the chamber through the front lobby, straight ahead at the center, there is a desk with three chairs – two in
the front and one behind the desk. To the left side of the entrance, there is a smaller desk with a computer on it
and a chair in front of it. On the desk, there is a computer, a keyboard, and two unopened letters. There is a desk
plant on the table, three diaries, and multiple files alongside a pen stand.
Inspector Harsh Kikle took us to the spot where the Assistant Central Intelligence Officer was found dead. He
was found lying sideways on the floor.
Inspector Harsh Kikle seized, sealed and marked all the following items in our presence and in the presence of
Constable Manoharan:
1. 2 X unopened envelopes with letters still inside them
2. 1 X opened envelope
3. 1 X letter marked confidential
4. 1 X CPU
5. 3 X Dairies
We, along with Inspector Harsh Kikle signed the labels of the five seized items. Except
for the above articles, nothing else was seized by the police in our presence.
November, 2023. The items seized were entrusted to Inspector Harsh Kikle who
recorded the details of the above-mentioned articles in the Malkhana Sub Module. Both of us

panchas have read the contents of the panchnama. The same is correctly recorded.
Sd/-
Harsh Kikle
Witnesses:
Sd/- Sd/-
Rutuja Dalvi Aastha Sarda
Flat 420, Khinvasara Paradise, Flat 110, Annapurna Society,
ND Road,Fort, Mumbai, 400051 ND Road, Colaba, Mumbai 400051

ANNEXURE X
PANCHNAMA
FIR Nos.: RC90242023S0786

RC90232023S7860
General Diary No.: N.A.
Date, hour and minute of beginning the Panchnama: 11:25 AM; 21st November, 2023
Date, hour and minute of ending the Panchnama: 12:45 AM; 21st November, 2023
On 21/11/2023, at 11:25 AM, Superintendent of Police, Aayush Trivedi along with Head Constable Mr. Pranav
Vinayan conducted search and seizure of Room no. 406, Taj Mahal Palace, Apollo Bandar, Colaba, Mumbai-
400001, where the following items were seized, sealed and marked in the presence of the witnesses:
1. 2 X white pellets from the tap spout in the shower.
2. 2 X partially dissolved white pellets from the tap spout in the sink.
3. 2 X white pellets from the jet spray faucet
Mr. Drishey Patil, 42 y/o, r/o 606 Krishnanjali Apartments and Ms. Rudrani Wadkar, 33 y/o, r/o 36 Rajmayur
Apartments, consented to be the Panchas to the Panchnama proceedings and have attested the same. The
witnesses have signed on the marked articles. The items were entrusted to Superintendent of Police, Aayush
Trivedi who recorded the details of the above-mentioned articles in the Malkhana Sub Module.
Sd/-
Aayush Trivedi
Witnesses:
Sd/- Sd/-
Drishey Patil Rudrani Wadkar
606 Krishnanjali Apartments, 36 Rajmayur Apartments,
Tulloch Road, Colaba, Nawroji Furdunji St., Colaba,
Mumbai 400039. Mumbai 400039.

ANNEXURE XI
PANCHNAMA
FIR No.: 131/2023

Date, hour and minute of beginning the Panchnama: 07:08 pm, 17 November 2023
Date, hour and minute of ending the Panchnama: 07:47 pm, 17 November 2023
On 17/11/2023, at 7:08 pm, Inspector Pratham Shete along with Constable Parulekar and Technician Shubham
Pungale conducted search and seizure of the surveillance room of The Taj Mahal Palace, Apollo Bandar,
Colaba, Mumbai- 400001, where the following items were seized, sealed and marked in the presence of the
witnesses:
1. 1 x Network Video Recorder
2. 1 x Hard Disk
Mr. Vandev Dhage, 37 y/o, r/o Adhyatma Bhavan and Ms. Aarya Dhupar, 31 y/o, r/o 36 Indira Heights,
consented to be the Panchas to the Panchnama proceedings and have attested the same. The witnesses have
signed on the marked articles. The items were entrusted to Inspector Pratham Shete who recorded the details of
the above-mentioned articles in the Malkhana Sub Module.
Sd/-
Pratham Shete
Colaba P.S., Mumbai
Witnesses:
Sd/- Sd/-
Vandev Dhage Aarya Dhupar
16, Adhyatma Bhavan 8/211,Indira Heights,
Colaba Causeway, Colaba, Cusrow Baug Colony, Colaba,
Mumbai 400005. Mumbai 400005.

ANNEXURE XII
PANCHNAMA
FIR Nos.:RC90232023S7860
RC90242023S0786
Date, hour and minute of beginning the Panchnama:1:20 PM, 23rd November 2023
Date, hour and minute of ending the Panchnama: 2:45 PM, 23rd November 2023
On 23/11/2023, at 1:20 PM, Superintendent of Police, Aayush Trivedi along with Head Constable Mr. Atharva
Thakur conducted search and seizure at Intelligence Bureau Headquarters 35, Sardar Patel Marg, Bapu dham,
Chanakyapuri, New Delhi, Delhi 110021, where the following items were seized, sealed and marked in the
presence of the witnesses:
1. Hard disk of Director’s Computer.
2. USB Flash Drive attached to the Director’s CPU.
3.A black diary.
4.Shredded documents.
Mr. Shrey Patel , 47 y/o, r/o 405, Green Meadows Apartments and Mr Shantanu Shinde 33 y/o, r/o 105, Red
Meadows Apartments, consented to be Panchas to the Panchnama proceedings and have attested the same. The
Sd/-
Aayush Trivedi
Witnesses
Sd/- Sd/-
Mr. Rohan Deshpande Mr. Shantanu Shinde
55, Solomon Heights Apartment 105, Red Meadows Apartments
Diplomatic Enclave Road Bureaucratic Enclave Road, New Delhi
Chanakyapuri, New Delhi - 110021. Chanakyaprui, New Delhi 110021

ANNEXURE XIII
PANCHNAMA
FIR Nos.: RC90242023S0786
RC90232023S7860
Date, hour and minute of beginning the Panchnama: 10:30 AM; 2nd December 2023
Date, hour and minute of ending the Panchnama: 11:50 AM; 2nd December 2023
On 02/12/2023 at 10:30AM, Superintendent of Police, Aayush Trivedi along with Head

Constable Aditi Bhatt conducted search and seizure at Intelligence Bureau Headquarters 35, Sardar Patel
Marg, Bapu dham, Chanakyapuri, New Delhi, Delhi 110021 where the following items were seized, sealed
and marked in the presence of the witnesses:
1.1 x Unit of opened Glovemeds Examination Latex Gloves
2.2 x Units of unopened Glovemeds Examination Latex Gloves
3.1 x Portable Insulin kit
4.1 x Insulin vial (100mL)
5.Multiple cotton swabs
6.1 x Pocket makeup kit
7.1 x Bottle of sanitizer
Ms. Saee Vaidya, 69 y/o, r/o 501 Neel Tarang Apartments and Ms. Janhavi Agarwal, 58 y/o, r/o B-18
Asawari Apartment, consented to be Panchas to the Panchnama proceedings and have attested the same. The
Sd/-
Aayush Trivedi
Witnesses:
Sd/-
Sd/-
Ms. Janhavi Agarwal
Ms. Saee Vaidya
B-18, Asawari Apartment
501 Neel Tarang Apartments
Chanakyapuri,
Chanakyapuri,
New Delhi, Delhi 110021
New Delhi, Delhi 110021

ANNEXURE XIV
PANCHNAMA
FIR Nos.: RC90242023S0786

RC90232023S7860
Date, hour and minute of beginning the Panchnama: 9:30 AM; 8th December 2023
Date, hour and minute of ending the Panchnama: 9:40 AM; 8th December 2023
On 08/12/2023, at 9:30 AM, Superintendent of Police, Aayush Trivedi along with Head
Constable, Aditi Bhatt conducted search and seizure at Flat No. 201, Krisha Apartments,
Connaught Place, New Delhi- 110001, where the following items were seized, sealed and marked in the
presence of the witnesses:
1. 1 x Hard disk of Apple Macbook Pro Laptop
2. 1 x Xiaomi Mi 10i
3. 1 x Transparent packet found in a jewellery pouch.
4. 1 x Accusure Diabetic checking machine
5. 1 x Packet of Humulin R U-100
Mr. Keshav Mahajan, 44 y/o, r/o 704 Adhyatm Bhawan and Mrs. Anoushka Date, 25 y/o, r/o
666 Priyanka Apartment, consented to be Panchas to the Panchnama proceedings and have
attested the same. The witnesses have signed on the marked articles. The items were entrusted to Superintendent
of Police, Aayush Trivedi who recorded the details of the above-mentioned articles in the Malkhana Sub
Module.
Sd/-
Aayush Trivedi
Witnesses:
Sd/ Sd/-
Mr. Keshav Mahajan Mrs. Anoushka Date
704 Adhyatm Bhawan 666 Priyanka Apartment
Connaught Place, New Delhi- 110001 Connaught Place, New Delhi 110001

ANNEXURE XV
POST MORTEM REPORT
Memorandum of Post-Mortem Examination held at St. George Hospital on the dead body of
Som Upadhye by Dr. Krishna Purwar.
General Particulars-
1. Particulars of the spot
(a) By whom was the corpse sent? : Inspector Pratham Shete

(b) Name of the place (from which sent.) : The Taj Mahal Hotel, Colaba,
Mumbai
(c) Distance of place from which sent. : 2.4 kms
2. By whom was the corpse brought? : Hospital Ambulance
3. By whom identified? : Ms. Anushka Bajaj
4. The date, hour and minute of its receipt :
(a) The date, hour and minute of beginning of post : 11:30 AM, 17th September 2023
mortem examination.
(b) The date, hour and minute of ending post mortem : 1:11 PM, 17th September 2023
Examination.
5. Substance of accompanying report from Police : N/A
officer or Magistrate, together with the date of
death, if known. Supposed cause of death or
reason, for examination.
6. If not examined at Dispensary or Hospital :
(a) Name of place where examined : N/A
b) Distance from Dispensary or Hospital : N/A
(c) Reason why the body was not sent to the : N/A
Dispensary or Hospital.
External Examination:
7. Sex, apparent age, race or caste description of : Sex: Male, Age: 59 Race: Indian Caste:
clothes and of ornaments Unknown
The body is received unclothed.
8. Condition of the clothes-
Whether wet with water stained or soiled with vomit : N/A
or faecal matter
9. Special marks on the skin such as scars, : Mole on left forearm.
tattooing etc., any malformations, peculiarities or No Malformations, peculiarities.
other marks of identification, State of teeth Teeth intact.
In newly-born infants, the length and (if possible), : N/A
the weight of the body to be recorded together with
the state of the hair, nails and umbilical cord, its
length whether placenta is attached or not, if present,
its size and condition.
10. Condition of Body- Whether well- : Well-built and nourished.

nourished/Lean thin or emaciated, warm or cold Height: 178cms, Weight: 80kgs.
Body Cold at the time of post-
mortem.
11. Rigor mortis – well marked, slight or absent, : Rigor mortis is 12eneralized and
whether present in the whole body or part only. partially present.
12. Extent, and signs of decomposition, presence : No signs of decomposition.

of post-mortem lividity of buttocks, joints, back Fixed lividity present
and thighs or any other part buttocks, joins, back on back Bullae present.
and thighs or any other part.
Whether bullae are present and the nature of

their contained fluid. Condition of that cuticle
13. Features – Whether natural or swollen, state : Body is swollen, milky cornea,
of eyes, position of tongue; nature of fluid (if any) glossitis on tongue with one eye
Position of tongue oozing from mouth, nostrils or rolled upwards
ears.
14. Condition of skin – Marks of blood, etc. : Cherry red discolouration of the skin.
In suspected drowning the presence or absence of : N/A

cutis anserine to be noted.
15. Injuries to external genitals. Indication of : N/A

purging
16. Position of limbs especially of arms and by : Palms partially open.

fingers. In suspected drowning the presence or
absence of sand or earth within the nails or on,
the skin of hands and feet.
17. Surface wounds and injuries

Their nature, position, dimensions (measured) and : N/A
directions to be accurately stated (probable age) and
caused to be noted.
If bruises are present what is the condition of the : N/A
Areas blisters, subcutaneous tissues? (N.B.- When
injuries are numerous and cannot be mentioned
within the space available, they should be mentioned
on a separate paper which should be signed).
[
18. Other injuries discovered by external : N/A

examination or palpation as fractures etc.
Can you say that the injuries shown against serial : N/A
Nos. 17 and 18 are ante-mortem injuries
Internal Examination –
19. Head – : N/A
i. injuries under the scalp, their
nature
ii. Skull – Vault and base describe : N/A
features, their sites, dimensions,
Directions, etc.
iii. Brain – The appearance of its : N/A

coverings, size, weight and
general condition of the organ
itself and any abnormality found
in its examination to be carefully recorded.
20. Thorax –
(a) Walls, ribs, cartilages : N/A
(b) Pleura : Pinpoint Hemorrhages
(c) Larynx, Trachea and Bronchi : Centrally placed
(d) Right Lung : Pulmonary Edema present
(e) Left Lung : Pulmonary Edema present
(f) Pericardium : Haemorrhages present
(g) Heart with weight : Normal range
(h) Large vessels : Adequate volume of blood is
present.
(i) Additional remarks : Bitter almond smell emanating from
the body and cavities
21. Spine and Spinal Cord : N/A
22. Abdomen :
(a) Spleen : N/A
(b) Stomach : Mucosa eroded and haemorrhages
present.
(c) Liver : Cirrhosis surfaces showing
haemorrhages
(d) Left Kidney :
(e) Right Kidney :
(f) Additional features :
22.Blood/Urine/Bile examination if warranted:
Why and mention the main findings : Red blood cell cyanide
concentration is 2.7μg/Ml
Opinion as to cause/probable cause of death:

The victim, Som Upadhye, shows traces of cyanide poisoning. It can be concluded that the victim died from
hypertensive heart failure due to cyanide poisoning.
Dated: 17th September, 2023

Sd/-
Dr. Krishna Purwar
ANNEXURE XVI
POST MORTEM REPORT

Memorandum of Post-Mortem Examination held at Lokmanya Tilak Municipal General Hospital on the dead
body of Mohammad Burma by Dr. Viraj Chate.
(a) By whom was the corpse sent? : Harsh Kikle
(b) Name of the place (from which sent.) : Subsidiary Intelligence Bureau, Ministry of
Home Affairs, Government of India, Block-E,
lot-C, Bandra Kurla Complex, Bandra (E),
Mumbai.
(c) Distance of place from which sent. : 5.5km
3. By whom identified? : Aafreen Basu, Assistant Section Officer
4. The date, hour and minute of its receipt
(a) The date, hour and minute of beginning of : 02:10 PM, 17th November 2023
post-mortem examination.
(b) The date, hour and minute of ending post- : 04:11 PM, 17th November 2023
mortem examination
5. Substance of accompanying report from Police : N.A

officer or Magistrate, together with the date of
death, if known. Supposed cause of death or
reason, for examination.
6. If not examined at Dispensary or Hospital
(a) Name of place were examined : N.A
(b) Distance from Dispensary or Hospital : N.A

(c) Reason why the body was not sent to the : N.A
Dispensary or Hospital
7. Sex, apparent age, race or caste description of Sex: Male, Age: 57 Race: Indian, Caste:
clothes and of ornament Unknown
8. Condition of the clothes- The body is received in a Blue Shirt and Black
pants
Whether wet with water stained or soiled with vomit Clothes were stained with Vomit, trousers
or faecal matter stained with urine.
9. Special marks on the skin such as scars, Scar on the lower abdomen. No Malformations,
tattooing etc., any malformations peculiarities or peculiarities. Teeth intact
other marks of identification, State of teeth.
In newly-born infants, the length and (if possible), the N/A

weight of the body to be recorded together with the
state of the hair, nails and umbilical cord, its length
whether placenta is attached or not, if present, its size
and condition.
10. Condition of Body- Whether well- Well-built and nourished. Height: 186cms,
nourished/Lean thin or emaciated, warm or cold Weight: 79kgs. Body Cold at the time of Post-
Mortem
11. Rigor mortis – well marked, slight or absent, Rigor mortis is absent.
whether present in the whole body or part only.
12. Extent, and signs of decomposition, presence of No signs of decomposition, fixed lividity on
post-mortem lividity of buttocks, joints, back and back and hands, no bullae present
thighs or any other part. Whether bullae present
and the nature of their contained fluid. Condition
of that cuticle.
13. Features – Whether natural or swollen, state of Swollen, pinpoint pupils, serous/mucinous fluid
eyes, position of tongue; nature of fluid (if any) flowing from eyes, nose, and mouth
Position of tongue, fluid oozing from mouth,
nostrils or ears.
14. Condition of skin – Marks of blood, etc. Cyanos extremities, fingers cyanosed
In suspected drowning the presence or absence of NA.

cutis anserine to be noted
15. Injuries to external genitals. Indication of No injuries to external Genitals

purging.
16. Position of limbs especially of arms and by Palms clenched

absence of sand or earth within the nails or on, the
skin of hands and feet
17. Surface wounds and injuries- N. A

Their nature, position, dimensions (measured) and
directions to be accurately stated (probable age) and
cause to be noted. If bruises are present what is the
condition of the area's blisters, subcutaneous tissues?
(N.B.- When injuries are numerous and cannot be
mentioned within the space available, they should be
mentioned on a separate paper which should be
signed).
18. Other injuries discovered by External N. A

examination or palpation as fractures etc.
Can you say that the injuries shown against serial Nos. N. A
17 and 18 are ante-mortem injuries
19. Head-
i. Injuries under the scalp, their nature. N. A
ii. Skull – Vault and base describe features, their sites, N. A

dimensions, directions, etc.
iii. Brain – The appearance of its coverings, size, Edema present

weight and general condition of the organ itself and
any abnormality found in its examination to be
carefully noted
20.Thorax –
(a) Walls, ribs, cartilages N. A
(b) Pleura Congested and hemorrhage is seen
(c) Larynx, Trachea and Bronchi Increased secretions and edema
(d) Right Lung Pulmonary edema is present, constriction of

bronchioles and collapsed alveoli can be
observed
(e) Left Lung Pulmonary edema is present, constriction of

Bronchioles and collapsed alveoli can be
observed
(f) Pericardium N. A
(g) Heart with weight Mild Inflammation present, on HPE fatty

infiltration of myocardium, hemosiderin-laden
macrophages.
(h) Large vessels Adequate volume of blood present
(i) Additional remarks Mucosa is eroded and congested, musky,

peachy smell traceable from the body
21. Spine and Spinal Cord N. A
22. Abdomen
(a) Spleen N. A
(b) Stomach Excess volume of acid present in the stomach

Mucosa is eroded and congested
(c) Liver Hepatic Failure
(d) Left Kidney Acute tubular necrosis followed by renal failure
(e) Right Kidney Acute tubular necrosis followed by renal failure

22. Blood/Urine/Bile examination if warranted: Upon Conducting Liquid Chromatography and
why and mention the main findings mass spectrometry of dried blood sample,
metabolites of cyclosarin named
cyclohexylmethlphosphonic acid found.

The victim, Mohammad Burma, died as a result of asphyxiation induced by a chemical belonging to the
Organophosphorus class of chemicals. Cause of death can be concluded as multi organ failure due to nerve
agent belonging to the Organophosphorus class of chemicals.
Dated: 17th November, 2023

Sd/-
Dr. Viraj Chate
ANNEXURE XVII
POST MORTEM REPORT
Memorandum of Post-Mortem Examination held at Lokmanya Tilak Hospital on the dead body
of Deb Chhabra by Dr. Viraj Chate.
General Particulars-
(a) By whom was the corpse sent? : Inspector Harsh Kikle
(b) Name of the place (from which sent.) : Subsidiary Intelligence Bureau, Block- E, Plot-
C, BandraKurla Complex, Bandra (E), Mumbai,
400051.
(c) Distance of place from which sent. : 5.5 kms
3. By whom identified? : Mr. Vansh Kothari
4. The date, hour and minute of its receipt
a) The date, hour and minute of beginning of post : 12:10 PM, 17 November, 2023
mortem examination.
(b) The date, hour and minute : 02:07 PM, 17 November, 2023
of ending post mortem examination.
5. Substance of accompanying report from : N/A

Police officer or Magistrate, together with the
date of death, if known. Supposed cause of
death or reason, for examination.
6. If not examined at Dispensary or Hospital : N/A
(a) Name of place where examined :

(b) Distance from Dispensary or Hospital :
(c) Reason why the body was not sent to the :

Dispensary or Hospital.
7. Sex, apparent age, race or caste description : Male, 58 Yrs, Race: Indian Caste:Unknown
of clothes and of ornaments : The body is received in pink shirt and khaki
trousers
8. Condition of the clothes-
Whether wet with water stained or : Pants soiled with faecal matter and slightly wet
soiled with vomit or faecal matter. with urine.
In newly-born infants, the length and (if possible), : N/A

the weight of the body to be recorded together
with the state of the hair, nails and umbilical cord,
its length whether placenta is attached or not, if
present, its size and condition
9. Special marks on the skin such as scars, : Birthmark on the right side of the forehead.
tattooing etc., any malformations peculiarities No Malformations, peculiarities. Teeth intact
or other marks of identification, State of teeth
10. Condition of Body- Whether well- : Well-built and nourished. Height: 175 cms,
nourished/Lean thin or emaciated, warm or Weight: 78kgs. Body Cold at the time of post-
cold mortem.
11. Rigor mortis – well marked, slight or : Rigor mortis is absent.

absent, whether present in the whole body or
part only.
12. Extent, and signs of decomposition, : No signs of decomposition.
presence of post-mortem lividity of buttocks, Slight lividity present on back.
joints, back and thighs or any other part
buttocks, joins, back and thighs or any other
part.
Whether bullae present and the nature of their No bullae present.
contained fluid. Condition of that cuticle.
13. Features – Whether natural or swollen, : Swollen, visible frothing seen perioral,
state of eyes, position of tongue; nature of fluid serous/mucinous fluid flowing from nose, eyes
(if any) Position of tongue oozing from mouth, and mouth. Pinpoint pupils.
nostrils or ears.
14. Condition of skin – Marks of blood, etc. : Cyanos extremities, fingers cyanosed.
In suspected drowning the presence or absence of N/A
cutis anserine to be noted
15. Injuries to external genitals. Indication of : No injuries to external genitals.
purging.
16. Position of limbs especially of arms and by : Palms completely open.

absence of sand or earth within the nails or on,
the skin of hands and feet.
17. Surface wounds and injuries- : A bruise on the right side of the forehead above
Their nature, position, dimensions (measured) the left eyebrow.
and directions to be accurately stated (probable N/A
age) and caused to be noted.
If bruises be present what is the condition of the
Areas blisters, subcutaneous tissues? (N.B.-
When injuries are numerous and cannot be
mentioned within the space available, they should
be mentioned on a separate paper which should be
signed).
18. Other injuries discovered by external : N/A
examination or palpation as fractures etc. Can
you say that the injuries shown against serial Nos.
17 and 18 are ante-mortem injuries
19. Head
i. injuries under the scalp, their : N/A

nature
ii. Skull – Vault and base describe : N/A
features, their sites, dimensions,
directions, etc.
iii. Brain – The appearance of its : Edema present.
coverings, size, weight and
general condition of the organ
itself and any abnormality found
in its examination to be carefully recorded.
20. Thorax – : N/A

(a) Walls, ribs, cartilages : N/A
(b) Pleura : Congested and Hemorrhages are present.

(c) Larynx, Trachea and Bronchi : Edema present.
(f) Pericardium : N/A
(d) Right Lung : Pulmonary edema is present, constriction of

bronchioles and alveoli
(e) Left Lung : Pulmonary edema is present, constriction of
bronchioles and alveoli
(g) Heart with weight : Mild inflammation of heart, on HPE fatty
infiltration of myocardium is found,
Hemosiderin laden macrophages
(h) Large vessels : Adequate volume of blood is present.
(i) Additional remarks: : Mucosa is eroded and congested. Musky, peachy

smell traceable from the body.
21. Spine and Spinal Cord : N/A
22. Abdomen
(a) Spleen : N/A
(b) Stomach : Excess volumes of acid present in the stomach,

mucosa is erroded and congested.
(c) Liver : Signs of Hepatic Failure
(d) Left Kidney : Acute tubular necrosis followed by renal failure.
(e) Right Kidney : Acute tubular necrosis followed by renal failure.
22. Blood/Urine/Bile examination if warranted : Upon Conducting Liquid Chromatography and

why and mention the main findings. mass spectrometry of dried blood sample,
metabolites of cyclosarin named
cyclohexylmethlphosphonic acid found.
The victim, Deb Chhabra, died as a result of asphyxiation induced by a chemical belonging to the
Organophosphorus class of chemicals. Cause of death can be concluded as multi-organ failure due to nerve
agent, Cyclosarin belonging to the Organophosphorus class of chemicals.
Dated: 17th November, 2023
Sd/-
Dr.Viraj Chate
ANNEXURE XVIII
ARREST MEMO
No.: 1011/2023
1. *District: New Delhi *P.S.: Connaught Place *Year: 2023 *FIR No. / Proceeding No.:
RC90242023S0786 & RC90232023S7860
*Date: 25th December 2023
* Alphanumeric code of the Accused ………A1…. (Write A1 to A9 for the first 9 persons, B1 for 10th
persona and so on)
2. Date & Time of Arrest / Surrender: *Date: 25th December, 2023 *Time: 4:20 P.M.
3. Name of the Court (if surrendered): N.A.
4. *Acts and Sections: Section 302 of the Indian Penal Code 1860, Section 3 of the Official Secrets Act
1923,Section 41 of the Chemical Weapons Convention Act, 2000 & Section 7 and Section 13 Prevention of
Corruption Act, 1988.
✔
5. *Arrested and sent up / Arrested and released on bail / Surrendered in court and bailed out /
Surrendered in court and sent to judicial custody / Surrendered in court and remanded to Police custody
(tick ‘✔’ applicable portion).
6. Particulars of the Accused:
i. *Name: Anushka Bajaj
ii. *Father’s / Husband’s name: Anish Bajaj
iii. First alias: Ansh
iv. *Nationality: Indian
v. *Religion: Hindu
vi. *Caste / Tribe. ………………………….
vii. *SC/ST …………NO…………….
viii. *Occupation: Government Service
ix. *Permanent address: Flat No. 201, Krisha Apartments, Connaught Place, New Delhi- 110001.
x. *Present address: Flat No. 201, Krisha Apartments, Connaught Place, New Delhi- 110001.
xi. *Blood group: O+ve
7. Injuries, cause of injuries and physical condition of the accused person (Indicate if medically
examined): …………………N.A……………………………
8. The accused, after being informed of the grounds of arrest and his legal rights, was duly taken into
custody on ………25th December 2023……. (Date) at …04:20 PM.… (Hours) at Flat No. 201, Krisha
Apartments, Connaught Place, New Delhi- 110001
The following article(s) was/were found on physical search, conducted on the person of the accused, and
were taken into possession for which a receipt was given to the accused. **
Necessary wearing apparels were left on the accused for the sake of human dignity and body protection.
The accused was cautioned to keep himself/herself covered for the purpose of identification.
Intimation given to: Anish Bajaj, father of the accused
** If no article found, ‘Nil’ may be indicated in the blank space provided below:
1. Black kurta and denim pants
2. A watch
9. Physical features, deformities and other details of the accused:

*Date / Year
*Sex *Build *Height *Complexion *Identification Marks
of Birth
1 2 3 4 5 6
7th 5ft 3 inches Birthmark on the right
Female December Medium Wheatish
(approx.) elbow
1972
(For Modus Operandi offences only)

*Deformities / *Teeth *Hair *Eye *Habit(s) *Dress habits
peculiarities
7 8 9 10 11 12
NA NA NA NA NA NA
*Languages PLACE OF
/ Dialect *Burn Mark *Leucoderma *Mole *Scar *Tattoo
13 14 POST 16 17 18
Hindi/Englis
- - - - -
h/Bengali
*Other features (19) ……………………………………….

10. Whether fingerprint taken or not? : ….YES.…
11. Socio-economic profile of the accused showing:

✔ ✔
(a). *Living Status: Living alone or with Family / Relation / Associate in Pucca House / Hotel / Hostel /
Kachcha House / Thatched House / Slum or is homeless.
(b). *Educational qualification(s): B.Tech - Chemical.
(c). *Occupation: Government Service
(d). *Income Group:
Lower Income (Below Rs. 500/P.M.)
Lower middle Income (From Rs. 501 to Rs. 1000)
Middle Income (From Rs. 1001 to Rs. 2000)
Upper Middle Income (From Rs. 2001 to 3000)
Upper Income (above Rs. 3000) .................... YES
Signature of the witness

[Either a family member or a respectable local man]:
Sd/-
Anish Bajaj
Countersignature of the arrestee:

Sd/-
Anushka Bajaj
Certified that the person arrested has been informed of this right to have someone informed of her
arrest or detention
Signature of Arresting Officer

Name: Shrushti Kinikar
Signature of the Investigating officer with:

Name: Aayush Trivedi Rank: Superintendent of Police
Date: 25th December 2023

Place: New Delhi
ANNEXURE XIX
FORWARDING NOTE
ANNEXURE XX
CENTRAL FORENSIC SCIENCE LABORATORY REPORT
Central Forensic Science Laboratory Pune,

Maharashtra
Tel: 020-25654762 Fax: 020-25654763
Report No.: QM/115 Date: 19th November 2023

Form No.: CFSL/PNQ/L/C/4211/22/5022
To,
Aayush Trivedi
Inspector
Mumbai Police
Your forwarding note no 4827/2023 dated 17th November 2023 regarding three parcels in connection
with case FIR No.947/2023 u/s 302 of the Indian Penal Code duly received in this office on 18th
November 2023 through Nipun Maheshwari, Head Constable. Mumbai.
EXAMINATION REPORT:
FSL Receipt 4853, Date:18/11/2023, Mode of receipt: by hand vide forwarding memo number
4827/2023.
The packet has been received as per the description mentioned in the forwarding memo numbers 4827/2023.
Description of Parcels:
Sealed parcel: 01 (One)

Total parcels: 04 (Four)
1. The parcel in Polyethylene zip-top bag marked A: Labelled and Sealed; Seal was intact and tallied
with specimen seal impression, forwarded for chemical examination.
2. The parcel in Polyethylene zip-top bag marked B: Labelled and Sealed; Seal was intact and tallied
3. The parcel in Polyethylene zip-top bag marked C: Labelled and Sealed; Seal was intact and tallied
4. The parcel in Polyethylene zip-top bag marked D: Labelled and Sealed; Seal was intact and tallied
Description of Articles contained:
1. Sample in Parcel marked A containing one letter, were marked as Exhibit A1. Sample was properly
sealed bearing impression, which tallied with the specimen seal impression.
2. Sample in Parcel marked B containing one letter, was marked as Exhibit B1. Sample was properly
3. Sample in Parcel marked C containing one opened envelope, was marked as Exhibit C1. Sample was
properly sealed bearing impression, which tallied with the specimen seal impression.
4. Sample in Parcel marked D containing one opened envelope, was marked as Exhibit D1. Sample was
Result of the Examination:
1. On examination of Exhibit A1 and B1, it was found that a nerve agent belonging to the G-series
family of nerve agents named Cyclohexyl methylphosphonofluoridate or Cyclosarin was found
on the surface of both letters.
2. On examination of C1 and D1, no anomalous substance was found.
Hence it can be conclusively stated that,
i. Exhibits A1 and B1, had traces of a nerve agent named Cyclosarin.
NOTE: Case exhibits sent to this division for examination have been sealed with the seal of Dr.Akshata
Dhiwani-CFSL-PUNE.
Examined by:
Sd/-
Dr. Akshata Dhirwani
Note: This report is per se admissible U/s. 293 of Criminal Procedure Code
ANNEXURE XXI
FORWARDING NOTE
ANNEXURE XXII
Central Forensic Science Laboratory

Pune, Maharashtra
Tel: 020-25654762 Fax: 020-25654763
Report No.: GH/009 Date: 19 November, 2023

Form No.: CFSL/PNQ/P/R/6587/03/7856
To,
Pratham Shete,
Inspector,
Mumbai Police.
Your forwarding note number 4297/2023 dated 17th November 2023 regarding two parcels in connection with
case FIR No. 131/2023 u/s 302 of the Indian Penal Code, 1860 duly received in this office on 18 November
2023 through Esha Lalwani, Head Constable Mumbai.
EXAMINATION REPORT:
FSL Receipt 666, Date: 18/11/2023, Mode of receipt: by hand vide forwarding memo number
PS/Colaba/4297/2023.
The packet has been received as per the description mentioned in the forwarding memo numbers
PS/Colaba/4297/2023.

Total parcels: 02 (Two)
1. The parcel in Faraday bag marked A: Labelled and Sealed; Seal was intact and tallied with specimen seal
impression, forwarded for digital forensic examination.
2. The parcel in Faraday bag marked B: Labelled and Sealed; Seal was intact and tallied with specimen seal

1. Sample in Parcel marked A containing one Network Video Recorder, was marked as Exhibit A1. Sample
was properly sealed bearing impression, which tallied with the specimen seal impression.
2. Sample in Parcel marked B containing one hard disk, was marked as Exhibit B1. Sample was properly
1. Upon examination of Exhibit A1, it was noted that a vulnerability, identified as CVE-2021-36260, had
an impact on the firmware of the Network Video Recorder (NVR). This vulnerability allowed for
unauthenticated remote code execution, primarily attributed to the Hikvision Camera Version DS-
2CD1x23, connected to the NVR.
2. Upon analysis of Exhibit B1, it was determined that the remote code execution on the NVR resulted in
the overwriting of a specific portion of the hard disk. However, by utilizing Stellar Photo Recovery
software and professional data recovery procedures, a pixelated version of the initially deleted original
video data file was recovered.
Hence it can be conclusively stated that:

i. The Digital Video Recorder had an unauthenticated remote code executed for the specific
purpose of overwriting data.
ii. The hard disk was put on a loop for the overwritten part and the recovery of the original deleted
data file yielded a pixelated version.
NOTE: Case exhibits sent to this division for examination have been sealed with the seal of Dr.
Ananya Joshi-CFSL-PUNE.
Examined by:
Sd/-
Dr. Ananya Joshi
ANNEXURE XXIII
FORWARDING NOTE
ANNEXURE XXIV

Pune, Maharashtra
Tel: 020-25654762 Fax: 020-25654763
Report No.: AT/301 Date: 20th November 2023
Form No.: CFSL/PNQ/F/O/9851/25/7895
To,
Pratham Shete
Inspector, Mumbai Police
Your forwarding note number 9321/2023 dated 17th November 2023 regarding five parcels in connection with
case FIR No. 131/2023 u/s 302 of the Indian Penal Code duly received in this office on 18/11/2023 through
Esha Lalwani, Head Constable, Mumbai.
EXAMINATION REPORT:
PS/Colaba/9230/2023. The packet has been received as per the description mentioned in the forwarding memo
number PS/Colaba/9230/2023.

Total parcels: 05 (Five)
1. The parcel in Polyethylene zip-top bag marked A: Labelled and Sealed; Seal was intact and tallied with
specimen seal impression, forwarded for physical examination.
2. The parcel in Polyethylene zip-top bag marked B: Labelled and Sealed; Seal was intact and tallied with
specimen seal impression, forwarded for chemical examination.
3. The parcel in Polyethylene zip-top bag marked C: Labelled and Sealed; Seal was intact and tallied with
4. The parcel in Polyethylene zip-top bag marked D: Labelled and Sealed; Seal was intact and tallied with
5. The parcel in Polyethylene zip-top bag marked E: Labelled and Sealed; Seal was intact and tallied with

1. Sample in Parcel marked A containing one piece of gold jewellery, was marked as Exhibit A1. Sample
2. Sample in Parcel marked B containing one sink swab sample, was marked as Exhibit B1. Sample was
3. Sample in Parcel marked C containing one shower swab sample, was marked as Exhibit C1. Sample
was properly sealed bearing impression, which tallied with the specimen seal impression
4. Sample in Parcel marked D containing one water sample, was marked as Exhibit D1. Sample was
5. Sample in Parcel marked E containing one body soap sample, was marked as Exhibit E1. Sample was

1. On examination of Exhibit A1, the hallmark of the said jewellery was found to be MGM-420.
2. On examination of Exhibit B1, C1 and D1, it was found that traces of mitochondrial toxin named
Sodium Cyanide was found in the samples.
3. On examination of Exhibit E1, no anomalous substance was found during the analysis.
i. Exhibit A1 containing the gold jewellery had a hallmark of MGM-420.
ii. Exhibits B1, C1 and D1 of the said bathroom surfaces had traces of a mitochondrial toxin
named Sodium Cyanide.
NOTE: Case exhibits sent to this division for examination have been sealed with the seal of
Dr.Akshata Dhirwani-CFSL-PUNE.
Examined by:
Sd/-
ANNEXURE XXV
FORWARDING NOTE
ANNEXURE XXVI

Pune, Maharashtra
Tel: 020-25654762 Fax: 020-25654763
Report No.: QM/117 Date: 23 November 2023

Form No.: CFSL/PNQ/S/M/0717/10/5207
To,
Aayush Trivedi,
Superintendent of Police,
Central Bureau of Investigation, Mumbai.
Your forwarding note number 5738/2023 dated 21st November 2023 regarding four parcels in connection with
case FIR No. RC90242023S0786 u/s 302 of the Indian Penal Code, 1860 and Section 41 of the Chemical
Weapons Convention Act, 2000, duly received in this office on 22/11/2023 through Omkar Aher, Head
Constable, CBI Mumbai.
EXAMINATION REPORT:
SCB/Mumbai/5738/2023 The packet has been received as per the description mentioned in the forwarding
memo numbers SCB/Mumbai/5738/2023.

1. The parcel in Polyethylene zip-top bag marked A: Labeled and Sealed; Seal was intact and tallied with
2. The parcel in Polyethylene zip top bag marked B: Labeled and Sealed; Seal was intact and tallied with
3. The parcel in Polyethylene zip top bag marked C: Labeled and Sealed; Seal was intact and tallied with
4. The parcel in Polyethylene zip top bag marked D: Labeled and Sealed; Seal was intact and tallied with
1. Sample in Parcel marked A containing two white pellets, was marked as Exhibit A1. Sample was properly
2. Sample in Parcel marked B containing two partially dissolved white pellets, was marked as Exhibit B1.
Sample was properly sealed bearing impression, which tallied with the specimen seal impression
3. Sample in Parcel marked C containing two white pellets, was marked as Exhibit C1. Sample was
4. Sample in Parcel marked D containing two white pellets, was marked as Exhibit D1. Sample was
1. On examination of the pellets found in Exhibit A1, B1, CI and D1, a mitochondrial toxin named Sodium
Cyanide was found containing a quantity of approximately ten grams in each pellet.

i. The pellets found from Exhibits A1, B1, C1 and D1, each contain ten grams of Sodium Cyanide.
NOTE: Case exhibits sent to this division for examination have been sealed with the seal of Dr.Akshata
Dhriwani-CFSL-PUNE.
Examined by:
Sd/-
ANNEXURE XXVII
FORWARDING NOTE
ANNEXURE XXVIII

Pune, Maharashtra
Tel: 020-25654762 Fax: 020-25654763
Report No.: JE/525 Date: 26th November 2023

Form No.: CFSL/PNQ/A/B/0202/11/2000
To,
Aayush Trivedi,
Central Bureau of Investigation, Mumbai.
Your forwarding note number 5959/2023 dated 23rd November 2023 regarding two parcels in connection with
case FIR No. RC90242023S0786 u/s 302 of the Indian Penal Code, 1860 and Section 41 of the Chemical
Weapons Convention Act, 2000 duly received in this office on 24th November 2023 through Chinmay
Kimothi, Head constable, CBI Mumbai.
EXAMINATION REPORT:
SCB/Mumbai/5959/2023. The packet has been received as per the description mentioned in the forwarding
memo number SCB/Mumbai/5959/2023.

Total parcels: 02 (Two)
1. Sample in Parcel marked A containing Hard Disk of Generic Intel Core i5 Desktop, was marked as
Exhibit A1. Sample was properly sealed bearing impression, which tallied with the specimen seal
impression.
2. Sample in Parcel marked B containing USB SanDisk Cruzer Blade, was marked as Exhibit B1. Sample
1. On examination of Exhibit A1, the analysis revealed the infiltration of the Hard Disk by the malware
"PlugX", alias "Sogu." The point of infection was traced back to three distinct files. A file labelled
"Symantec" was identified as the agent responsible for loading a malicious file termed
"GeneralReport.dll." an incriminating payload designed for the transmission of this malware was
discerned within the system's memory. The malware exfiltrated data, to a remote command-and-control
server which can be traced to infinite IP addresses bouncing in the entire territory of Pakistan.
2. On examination of Exhibit B1, the USB SanDisk Cruzer Blade- 516 GB was found to be the primary
ingress point for the installation of the malware “Sogu”. The infection was found to be transmitted to the
memory of the computer from the three files found in this USB Flash Drive. Deeper analysis uncovered
that the USB drive also functioned as a repository for the exfiltrated data, which was stored alongside its
remote server counterpart.
i. Data from the computer infected with the “PlugX” malware has been transmitted to a remote server
in Pakistan.
ii. The USB flash drive was identified as the external device responsible for introducing the "Sogu"
malware to the computer system.
NOTE: Case exhibits sent to this division for examination have been sealed with the seal of
Dr.Ananya Joshi-CFSL-PUNE.
Examined by:
Sd/-
Dr. Ananya Joshi
ANNEXURE XXIX
FORWARDING NOTE
ANNEXURE XXX

Pune, Maharashtra
Tel: 020-25654762 Fax:020-25654763
Report No.: YV/864 Date: 30/11/2023

Form No.: CFSL/PNQ/Q/T/1910/02/2708
To,
Aayush Trivedi,
Central Bureau of Investigation, Mumbai
Your forwarding note number 7893/2023 dated 28th November 2023 regarding three parcels in connection
with case RC90242023S0786 and RC90232023S7860 u/s 302 the Indian Penal Code,1860 and Section 41 of
the Chemical Weapons Convention Act, 2000 duly received in this office on 29 November 2023 through Purva
Khojare, CBI, Mumbai.
EXAMINATION REPORT:

Total parcels: 03 (Three)
1. The parcel in Faraday bag marked A: Labelled and Sealed; Seal was intact and tallied with specimen
seal impression, forwarded for digital forensic examination.
2. The parcel in Faraday bag marked B: Labelled and Sealed; Seal was intact and tallied with specimen
3. The parcel in Faraday bag marked C: Labelled and Sealed; Seal was intact and tallied with specimen

1. Sample in Parcel marked A containing a microphone bug, was marked as Exhibit A1. Sample was
2. Sample in Parcel marked B containing a microphone bug, was marked as Exhibit B1. Sample was
3. Sample in Parcel marked C containing a hard disk of a CPU of a computer, was marked as Exhibit C1.
Sample was properly sealed bearing impression, which tallied with the specimen seal impression.

1. On examination of Exhibit A1, it was found the microphone bug was a LOA A1 spy microphone. The
microSD memory card occupied 62 GB of 64 GB. The audio data was stored on the bug device's SD
card, which established a connection to a Wi-Fi network that was hosting a concealed FTP server. This
FTP server was configured with exclusive access rights given to an IP address, 82.129.73.111, which
was traced to a local PC within a cyber cafe situated in Delhi.
2. On examination of Exhibit B1, it was found the microphone bug was LOA A1 spy microphone. The
microSD memory card occupied 4 GB out of 64 GB. This bug was connected to a Wifi network. There
was no FTP server that was made.
3. On examination of Exhibit C1, the hard disk was infected with the “PlugX” alias “Sogu” malware. There
was a backdoor created to infiltrate the information to a command-and-control server.
i. The microphone bug marked as Exhibit A1 was active and has recorded 62 GB audio data.
ii. The microphone bug marked as Exhibit B1 was active and has recorded 8 GB audio data and thus no
audio transmission took place.
iii. The “Sogu” malware disseminated itself on the present hard disk. The infection has taken place
through connection over Server Message Block.
NOTE: Case exhibits sent to this division for examination have been sealed with the seal of Dr. Ananya
Joshi -CFSL-PUNE.
Examined by:
Sd/-
Dr. Ananya Joshi
ANNEXURE XXXI
FORWARDING NOTE
ANNEXURE XXXII

Pune, Maharashtra
Tel: 020-25654762 Fax: 020-25654763
Report No.: QM/185 Date: 5th December 2023

Form No.: CFSL/PNQ/L/O/8514/09/4200
To,
Aayush Trivedi,
Central Bureau of Investigation, Mumbai
Your forwarding number 9234/2023 dated 2nd December 2023 regarding four parcels in connection with case
RC90242023S0786 and RC90232023S7860 u/s Section 302 of the Indian Penal Code 1860, Section 3 of the
Official Secrets Act 1923, Section 41 of the Chemical Weapons Convention Act, 2000, and Section 7 and
Section 13 Prevention of Corruption Act, 1988 duly received in this office on 03 December 2023 through
Siddhesh Vyas, Head Constable, CBI Mumbai.
EXAMINATION REPORT:
1. The parcel in Polyethylene zip-top bag marked A: Labelled and Sealed; Seal was intact and tallied with
2. The parcel in Polyethylene zip top bag marked B: Labelled and Sealed; Seal was intact and tallied with
3. The parcel in Polyethylene zip top bag marked C: Labelled and Sealed; Seal was intact and tallied with
4. The parcel in Nylon zip-top bag marked D: Labelled and Sealed; Seal was intact and tallied with

1. Sample in Parcel marked A containing a box of opened latex gloves, was marked as Exhibit A1. Sample
2. Sample in Parcel marked B containing a box of unopened latex gloves, was marked as Exhibit B1. Sample
3. Sample in Parcel marked C containing one bottle of Humulin R U-100, was marked as Exhibit C1. Sample
4. Sample in Parcel marked D containing multiple cotton swabs, was marked as Exhibit D1, D2, D3, D4.
Sample was properly sealed bearing impression, which tallied with the specimen seal impression.

1. On examination of Exhibit A1, it was found that in the box of opened latex gloves, one pair of gloves
had indications of a nerve agent belonging to the G-series family of Nerve Agent named Cyclohexyl
methylphosphonofluoridate.
2. On examination of Exhibit B1, it was found that in the box of unopened latex gloves, no anomalous
substances were found.
3. On examination of Exhibit C1, it was found that a nerve agent belonging to the G-series family of Nerve
Agent named Cyclohexyl methylphosphonofluoridate was found in the bottle of Humulin R U-100.
4. On examination of Exhibit D1, D2, D3, D4, and D5 it was found that traces of human insulin (rDNA
origin), glycerin, metacresol, endogenous zinc and water were present on Exhibit D1, D2 and D3
whereas slight traces of nerve agent belonging to the G- series family of Nerve Agent named
Cyclohexyl methylphosphonofluoridate was found in Exhibit D4 and D5.
i. A pair of gloves in Exhibit A1 were laced with Cyclosarin.

ii. Nothing unusual was observed in Exhibit B1.
iii. Cyclosarin was found in Exhibit C1.
iv. Exhibits D1, D2 and D3 contained traces of Humulin R U-100.
v. Exhibits D4 and D5 contained traces of Cyclosarin.
NOTE: Case exhibits sent to this division for examination have been sealed with the seal of Dr. Akshata
Dhirwani-CFSL-PUNE.
Examined by:
Sd/-
ANNEXURE XXXIII
FORWARDING NOTE
ANNEXURE XXXIV

Pune, Maharashtra
Tel: 020-25654762 Fax: 020-25654763
Report No.: WP/007 Date: 12th December 2023

Form No.: CFSL/PNQ/S/C/5251/08/4022
To,
Aayush Trivedi,
Central Bureau Of Investigation,Delhi
Your forwarding note number. 9769/2023 dated 8th December 2023 regarding four parcels in connection
with case RC90242023S0786 and RC90232023S7860 u/s Section 302 of the Indian Penal Code 1860,
Section 3 of the Official Secrets Act 1923, Section 41 of the Chemical Weapons Convention Act, 2000, and
Section 7 and Section 13 Prevention of Corruption Act, 1988 duly received in this office on 9th December
2023 through Drishey Chugh, Head Constable CBI Mumbai.
EXAMINATION REPORT:
FSL Receipt 2222, Date: 09/12/2023, Mode of receipt: by hand vide forwarding memo number SCB/
Mumbai/9769/2023.
The packet has been received as per the description mentioned in the forwarding memo numbers SCB/
Mumbai/9769/2023.
3. The parcel in Polyethylene zip top bag marked C: Labelled and Sealed; Seal was not intact and did not
tally with specimen seal impression, forwarded for chemical examination.
4. The parcel in Polyethylene zip bag marked D: Labelled and Sealed; Seal was intact and tallied with

1. Sample in Parcel marked A containing Hard Disk of Apple Macbook Pro Laptop, was marked as
Exhibit A1. Sample was properly sealed bearing impression, which tallied with the specimen seal
impression.
2. Sample in Parcel marked B containing Xiaomi Mi 10i, was marked as Exhibit B1. Sample was properly
sealed bearing impression, which tallied with the specimen seal impression
3. Sample in Parcel marked C containing transparent packet, was marked as Exhibit C1. Sample was not
sealed properly, which did not tally with the specimen seal impression.
4. Sample in Parcel marked D containing a packet of Humulin R U-100, was marked as Exhibit D1. Sample
was properly sealed bearing impression, which tallied with the specimen seal impression

1. On examination of Exhibit A1, the hard disk was successfully decrypted and a folder titled
“Confidential” contained one file named “Sino Movements in India”.
2. On examination of Exhibit B1, the Xiaomi phone memory storage showcased an application named
“Go Keyboard- Emoji Keyboard, Swipe Inputs, GIFs”. Upon further examination, a separate isolated
space was found, named “Second Space”. It was password protected, which upon decryption, contained
a lot of information and applications including Viber, Contact list and Notes, etc.
3. On examination of Exhibit C1, the powder present in the transparent packet found inside the
jewellerypouch was identified to be mitochondrial toxin named Sodium Cyanide (NACN)
4. On examination of Exhibit D1, the liquid found inside the packet of Humulin R U-100 was identified to
be regular insulin.
1. Information was stored in the memory of the hard disk.

2. An application named Go Keyboard was found downloaded from the Play Store on the mobile device
along with hidden space called Second Space was put to use.
3. The powder found inside the transparent packet was Sodium Cyanide (NACN).
4. Regular Insulin was to be found inside the packet of Humulin R U-100.
NOTE: Case exhibits sent to this division for examination have been sealed with the seal of Dr.
Akshata Dhirwani and Dr.Ananya Joshi -CFSL-PUNE.
Examined by:
Sd/-
Dr. Ananya Joshi
ANNEXURE XXXV
CALL DETAIL REPORT

ANNEXURE XXXVI
CUSTOMER APPLICATION FORM
ANNEXURE XXXVII
RECOVERED CCTV FOOTAGE
*DULY CERTIFIED UNDER SECTION 65B OF THE INDIAN EVIDENCE ACT, 1872*
ANNEXURE XXXVIII
SCREENSHOT FROM A 1’s DEVICE
ANNEXURE XXXIX
CHATS RECOVEREDFROM A1’S SECOND SPACE
ANNEXURE XL
PHOTOGRAPHS OF PW-4’S DIARY
ANNEXURE XLI
INTERNET HISTORY OF CYBER CAFÉ’S COMPUTER

ANNEXURE XLII
ROOM NO. 406 DOOR CLOSING HISTORY
ROOM NO. 406

DATE
FROM:16/11/2023
DATE TO: 17/11/2023
Sr. No Timestamp Activity RFID No.
1. 7:27 pm Door opened 000 74 764 39 114,053 35
2. 7:28 pm Door closed
3. 7:58 pm Door opened 000 74 764 39 114,053 35
5. 9:35 pm Door opened 000 75 239 26 114,528 22
7. 10:24 pm Door opened 000 74 764 39 114,053 35
9. 11:47 pm Door opened 000 74 764 39 114,053 35
11. 8:19 am Door opened 000 17 987 00 027,292 28
ANNEXURE XLIII
A1’S AMAZON PURCHASE BILL
ANNEXURE XLIV
SALE RECORDS RETRIEVED FROM JEWELLERY STORE

ANNEXURE XLV
INVOICE OF THE LOA A1 SPY MICROPHONE
ANNEXURE XLVI
DOCUMENT RETRIEVED FROM D2 DIARY
MINUTES OF THE CBI MEETING HELD ON 16/11/2023
AT 12:30PM IN THE OFFICE OF IB, MUMBAI
PRESENT
Mr. Som Upadhye Director of the Intelligence Bureau of India
Mr. Mohammad Burma Deputy Director, IB Mumbai
Mr. Deb Chhabra Assistant Central Intelligence Officer, IB Mumbai
A classified meeting was convened on November 16, 2023, under the chairmanship of Mr. Som Upadhye.
During this session, three high-ranking officials from the Intelligence Bureau (IB) gathered to review the
situation and establish a specialized task force. The purpose of this task force is to investigate the leaked highly
confidential information from the IB office in Mumbai to China thoroughly.
In his opening remarks, Mr. Som Upadhye informed the other officials that:
He received information from the Research and Analysis Wing (R&AW) regarding the unauthorised disclosure
of highly confidential information. This information, previously known only to the Mumbai Intelligence Bureau
Office, pertained to strategic placements of submarines in the Bay of Bengal Sea, deployment of additional
troops in Arunachal Pradesh, and routes taken by the army in the patrolling area around Pangong Lake.
Mr. Som Upadhye highlighted three specific instances of leaked information intercepted by the Research and
Analysis Wing (R&AW):
1. Confidential details about the strategic placement and movements of submarines and warships were
leaked to China.
2. Information regarding the deployment of additional troops in Arunachal Pradesh was compromised.
3. Details concerning the routes and timing of patrols conducted by the Indian army near Pangong Lake
were disclosed.
According to the investigation, three suspects were identified:
1. Ms Anushka Bajaj, Section officer to the Director of the Intelligence Bureau of India, called the Mumbai
office, requesting a briefing on confirming the posting of additional troops in Arunachal Pradesh,
allegedly on behalf of the director.
2. Mr Anshuman Bhutia, a junior intelligence officer from IB Delhi, reportedly contacted the Mumbai
office inquiring about the routes and timing of army patrols near the Pangong Lake area. The purpose
of his call was to coordinate with the local police.
3. Mr Karanraj Jadhav, Assistant Intelligence officer, IB office Kolkata contacted the IB office Mumbai
confirming the placements of submarines and warships in the Bay of Bengal.

After the suspects were identified, Mr Som Upadhye directed Mr Mohammad Burma and Mr Deb Chhabra to
discreetly investigate each suspect without their knowledge. They were tasked with tracking and documenting
the suspects' movements to identify any suspicious behaviour or activities.
Lastly, Mr. Som Upadhye informed the other officials present at the meeting about the establishment of a task
force to investigate the leaked information. The special task force will be headed by Mr. Som Upadhye, and
letters regarding their appointments will be sent to them the following day.
The meeting ended with a vote of thanks to the Chairperson.

STATEMENT OF WITNESSES
PROSECUTION WITNESS 1
(u/s 164 of the CrPC)
Age: 43
Occupation: Superintendent of Police, CBI Mumbai.
General Description: Aayush Trivedi is posted with CBI Mumbai. He has 11 years of experience in
investigation and had been appointed as the Investigating Officer for the present case on 18/11/2023.
Statement: On 17th November 2023 at 8:20 a.m. Som Upadhye, the Director of the IB, was found dead in his
hotel room. At around the same time, Mr. Deb Chabra, Assistant Central Intelligence Officer at IB Mumbai and
Mr. Mohammad Burma, Deputy Director at IB Mumbai were also found dead in their respective offices. 2 FIRs
in connection with these deaths were filed at Colaba Police Station and BKC Police Station respectively. An
inquest panchnama and a spot panchnama of Som Upadhye’s hotel room was conducted by Mr. Ved Khatwani
and Inspector Pratham Shete respectively. The inquest and spot panchnamas of Deb Chabra and Mohammad
Burma’s offices were conducted by Sanya Bansod and Inspector Harsh Kikle. Inspector Pratham Shete later
conducted another panchnama wherein the CCTV footage of the lobby outside the Director’s hotel room was
procured. The evidences procured from the spot panchnamas were sent to CFSL, Pune for forensic examination.
On 18th November both the cases were transferred to the CBI and I was intimated by Ms. Manva Kothari, the
Director of CBI that I had been appointed as the investigating officer for both the cases since they seemed to be
part of a single conspiracy. All the relevant files, materials and documents regarding the cases were handedover
to me after 2 FIRs for both the incidents were filed by the CBI.
The post-mortem reports revealed that Som Upadhye’s death was caused due to cyanide poisoning and Deb
Chabra and Mohammed Burma died of multi-organ failure caused by Cyclosarin. The forensic reports of Som
Upadhye’s hotel room showed traces of cyanide in the water. We therefore conducted another panchnama of
the hotel room where we found cyanide pellets hidden in various spots in the bathroom. The forensic
examination of the items collected from Deb Chabra and Mohammad Burma’s offices showed that the letters
seized were laced with Cyclosarin. The last file accessed in Deb Chabra’s laptop was the minutes of a meeting
held on 16th November 2023, with the two other deceased where the possibility of Anushka Bajaj being a spy
was discussed.
The forensic report of Som Upadhye’s hotel room revealed the hallmark number on the piece of jewellery found
at the crime scene. We traced the hallmark to Dhanlakshmi Jewellers who told us that the jewellery was
purchased by Anushka Bajaj. Upon conducting the panchnama of Som Upadhye’s office on 23rd November, it
was discovered after forensic examination that his computer had been infected by a malware, Sogu. Thus, we
conducted an extensive electronic sweep of the IB Delhi Office where we found 2 bugs in the Director’s office
and his Section officer, Anushka Bajaj’s office. However, the bug found in Anushka’s office had very little data
stored in its SD Card which hinted at the possibility of it having been installed recently.

At this point, I was suspicious of Anushka Bajaj given that there were many evidences pointing towards her.
We therefore on 2nd December conducted a panchnama of her office where we found an insulin bottle
containing Cyclosarin and a pair of gloves and cotton swabs laced with Cyclosarin. Meanwhile, the IP address
from wherethe data on the bugs was accessed was traced to a cyber cafe. On 3rd December I visited the cyber
cafe and procured the internet history of the device bearing the IP address which we had traced. The device
history showed the email ID of one patriot.ansh@gmail.com being accessed on multiple occasions. When we
accessed this account after getting the required permission, we found e-receipts for a bug and a Chemical Safety
Suit.
Since the evidences collected from Anushka’s office further indicated her involvement in the case, we
conducted a panchnama of her house where we seized her phone, laptop and a jewellery pouch containing a
white powder which was later found to be sodium cyanide. In her laptop, we found confidential IB
information.We also found, on her phone, encoded chats between her and another person who we suspect was
her Chinesehandler. The messages upon decoding were found to be an exchange of sensitive information by
Anushka to China. After obtaining the Call Data Records for her number, we noticed that she was in the vicinity
of the cyber cafe at the same time as the spy, according to the cyber cafe computer’s history.
In her phone’s Second Space, only one contact ‘Chetan HWL’ was saved. We tried contacting the number but
it was switched off. The number was registered to one Chetan Kolte. A couple of days later while having my
morningtea, I read a newspaper article about Chetan Kolte, a Hawala Trader being tried by the Enforcement
Directorate for the offence of Money Laundering. That is when I realised and made the connection. I met Chetan
Kolte on17th December and on 22nd December through his statement he told me that Anushka Bajaj was one
of the clients for whom he used to launder money from China. He also gave us his diary entries for the
transactions he made for Anushka.
Therefore, from the investigation, it was clear that in order to protect her identity as a spy, Anushka Bajaj
orchestrated and carried out the murders of Som Upadhye, Deb Chabra and Mohammed Burma. She was
arrested on 25th December 2023 and a chargesheet was filed on 12th January 2024 against Anushka Bajaj u/s
302 of IPC; sec. 7 and Sec. 13 of the Prevention of Corruption Act, 1988; Sec. 3 of the Official Secrets Act,
1923; and Sec. 41 of the Chemical Weapons Convention Act 2000.

(u/s 293 CrPC)
Name – Ananya Joshi
Age- 47 Years
Occupation- Scientific Officer at Central Forensics Sciences Laboratory, Pune.
Experience- Completed masters in Cybersecurity from IIT Kanpur and working as a Scientific Officer at
Central Forensics Sciences Laboratory, Pune.
Statement:
I am Ananya Joshi and I work at the Central Forensics Sciences Laboratory in Pune as a Technical and Cyber
Forensics expert. I have almost 14 years of experience working at the Central Forensics Sciences Laboratory.
In my 14 years of service, I have examined various technical components, completed cyber security analysis,
and provided expert opinion in multiple cases.
I was contacted by the investigating authority to conduct a digital forensic examination in the case of Som
Upadhye. On 17th November 2023, I received the samples collected by the police for the CFSL reports.
Out of the two samples received from the Director’s Delhi Office, the Hard Disk was infected with a remote
access trojan named as “PlugX” alias “Sogu”. It has the ability to execute commands on the affected machine
to retrieve: machine information, capture the screen, send keyboard and mouse events, keylogging, reboot the
system, manage processes, manage services, manage Windows, file transfer, file execution, remote desktop,
screenshot capture, reverse shell, etc. Sogu is a China-linked actor which infects initially through a USB Flash
Drive. All the three files to infect the computer with this malware were found on the hard disk namely a
legitimate executable, a malicious DLL loader, and an encrypted payload. The malware’s operation was
characterised by a systematic search of the C drive for files bearing extensions like .doc, .docx, .pdf, etc. At the
last stage of the attack lifecycle, the malware exfiltrated the data that has been staged and transmitted it to
communicate with its command-and-control server. It also mirrored applications including but not limited to
Gmail and Google Drive to this command-and-control server. I was not able to trace a specific IP address of the
command-and-control server of this malware because the IP address constantly bounced through a convoluted
chain of thousands of intermediary addresses, making it nearly impossible to pinpoint the original source.
However, all the IP addresses were confined to the territory of Pakistan. On examination of the USB flash drive,
it was the primary ingress point for the installation of the malware “Sogu”. The flash drive contained multiple
malicious software that loaded payload in memory through DLL hijacking. It also stored the exfiltrated
information in its memory, which included numerous files. I can easily say that this is an espionage attack
whichis rarely used but is used with a very grave intention and for a specific purpose.
On analysis of another FSL Copy dated 17/11/2023(Re: CCTV), I instantly was reminded of the Security
Notification by Hikvision Company, where the vulnerability of some versions of the Hikvision Closed-Circuit
Television had come to light. This is the same in the present case. The Hikvision Camera Version DS-2CD1x23,
connected to the NVR had an unauthenticated remote code execution run on it. The attacker’s code was run to
overwrite a certain portion of the hard drive of the Network Video Recorder it was connected to. Consequently,
in simpler terms, the original video was deleted and then replaced with a new video which was a video of an

earlier time put on loop. Overwritten data is almost impossible to recover in its original quality as it depends on
various factors like how it is deleted, extent of damaged hard disk, time of recovery, etc. Thus, I followed a
professional data recovery procedure using the Stellar Photo Recovery and was still able to recover a pixelated
blur version of the video footage.
On examination of the FSL dated 28/11/2023, the two microphone bugs were the same LOA A1 spy microphone
manufactured by Law Abiding Technology. The first bug was used for a very long time whereas the second was
recently put to use. The same can be seen in the memory usage of the both. The first one had recorded a lotof
audio data. The unique feature of this bug is that the audio transmission takes place through an FTP server. With
respect to the first bug, the wifi network hosted a hidden FTP server. I was able to locate this FTP url on the
hidden Wifi network. This FTP server had a specific IP address configured in its data which was traced backto a
local cyber cafe PC in Delhi. With respect to the second bug, it was connected to a Wifi network however there
was no FTP server created and no audio transmission had taken place.
In my professional opinion, this is a clear cyber espionage attack on the Intelligence Bureau of India done with
the aim to illegally transmit sensitive information to China, an enemy country of India. It can be clearly seen
with the high technology devices and physical access required to do the same, a mole in the IB is present and
on the move.

(u/s 293 CrPC)
Name – Dr. Akshata Dhirwani
Age- 45 Years
Occupation- Scientific Officer at Central Forensics Sciences Laboratory, Pune.
Experience- Ph.D Toxicology from University of Maryland, M.Sc. in Forensic Science from Dr.Harisingh Gaur
Vishwavidyalaya, Sagar(MP) and a Scientific Officer at Central Forensics Sciences Laboratory, Pune.
Statement: I am Akshata Dhirwani and I work at the Central Forensics Sciences Laboratory in Pune as a
Chemical and Toxicology expert. I have almost 18 years of experience working at the Central Forensics
Sciences Laboratory. In my 18 years of service, I have examined various chemical components and provided
expert opinion in multiple cases.
I was contacted by the CBI to conduct a forensic toxicology examination in the case of Som Upadhye,
Mohammad Burma and Deb Chhabra’s deaths. On 17th November 2023, I received the samples collected by
the police for the CFSL report from multiple locations.
I have gone through all the samples received in the CFSL Report dated 20/11/2023 and in my considered opinion
there were significant proportions of Sodium Cyanide present in the form of pellets. Each of the pellets found
contained 10 grams of Sodium Cyanide, which is a very high and unnatural quantity to be found. The swabs
sentalso had sodium cyanide traces on them. Sodium cyanide is water-reactive and decomposes on contact with
acids, acid salts, water, moisture, and carbon dioxide, producing highly toxic, flammable hydrogen cyanide gas.
Hydrogen Cyanide has a very distinctive bitter almond smell. Though Sodium Cyanide is a commonly used
medium to kill, I was absolutely shocked to see this amount of Sodium Cyanide from a crime scene. The fatal
dosage of cyanide varies from person to person; however, 10 grams of cyanide is more than enough to kill a
well-nourished adult.
I also received three samples for forensic examination on 17/11/2023 and after careful examination of the
samples, it was found that a nerve agent called Cyclohexyl methylphosphonofluoridate, commonly known as
Cyclosarin, was present on the surfaces of those letters and envelopes. The Chemical Weapons Convention bans
chemical weapons including G-series nerve agents like cyclosarin.
Cyclosarin is readily absorbed through the skin, eyes, and respiratory tract, through inhalation and dermal routes
of exposure. It has a musky smell similar to peaches. Due to the volatility exhibited by cyclosarin, the most
likely exposure route and source of primary hazard is via direct vapor exposure to the eyes, upper respiratory
tract tissues and vapor inhalation. Toxic manifestations of exposure to cyclosarin vapor or aerosols occur within
seconds to minutes of inhalation. In my opinion, this is the most gruesome way of killing another human being.
All these findings indicate that the occurrence of cyclosarin on the surface of the letters and those envelopes is
highly unnatural and seems to be meticulously planned.
On 2nd December, 2023 I received 4 packages for examination. The first package had a box of opened latex
gloves, in which one pair of gloves, upon examination, had traces of the nerve agent, Cyclosarin. The second
package had an almost empty bottle of Humulin R U-100. This vial also contained traces of Cyclosarin instead

of the insulin medication. I was alarmed when I saw this. It would have been a catastrophe if a person hadtaken
Cyclosarin instead of the insulin dosage. Another package had multiple cotton swabs. Out of these some cotton
swabs had traces of human insulin (rDNA origin), glycerin, metacresol, endogenous zinc and water whereas 2
swabs had slight traces of Cyclosarin.
On 8th December, 2023, I examined 2 packages. In this one sample was a transparent packet with white powder
inside a jewellery pouch. I tested the white powder, and it was found to be Sodium Cyanide. I was horrified at
this. In my 18 years of experience, I have never examined so many samples having traces of Sodium Cyanide
or Cyclosarin. The person who planned these murders has to have a very strong motive and a lot of malice.
These are two of the deadliest chemicals and I cannot emphasise more on how big of an ordeal finding these
chemicals is.
Cyanide is a highly toxic substance, and Cyclosarin is a nerve agent so finding them under these circumstances
is very concerning and alarming.

(u/s 161 of the CrPC)
Name- Chetan Kolte

Age- 47
Occupation- Import-Export Trader
General description: Chetan Kolte is an Import-Export Trader based in Mumbai who is in Judicial Custody
for the offence of Hawala.
Statement: I have been in the business of Import-Export for the past 17 years and due to some financial
constraints, I was compelled to enter into the business of Hawala trading. I have been operating through the
Greater Mumbai area and people contact me by putting their phone no. on a piece of paper in the electric box
in front of my office. That is how I came in contact with Anushka Bajaj somewhere around late 2018. After
every new client, I make a diary entry which contains the first three letters of their name and the last three digits
of their phone number for maintaining records.
I never met Anushka personally but had conversations on call every time money was dropped for Anushka. I
would tell her the drop location after she deposited a half-torn note with a matching serial number in the
aforementioned electric box. The money was sent to her from Hong Kong and my source from Hong Kong told
me that the money came to Hong Kong from someone in China
I also provided assistance for setting up offshore accounts and I offered the same service to Anushka which she
blatantly refused since for the same I needed some identification proof.
I remember this particular incident quite a while back when Anushka called me in a state of panic asking me
“kya kabhi aisa ho sakta hai ki ye paisa mujh tak track ho paaye?” to which I replied “iss dhande me ek hi
cheez ki keemat hoti hai aur wo hai zubaan ki. Aur mai aapko zubaan deta hu ki aapka naam kahin nahi ayega”.
All this while I had no idea which business she was involved in and where she was getting the money from
since it is a practice in our business that we do not enquire about personal details of the clients.

DOCUMENTS RELIED UPON BY THE DEFENSE
FLIGHT TICKET OF ANSHUMAN BHUTIA

ROOM SERVICE RECEIPT

STATEMENT OF WITNESSES
DEFENSE WITNESS-1
Name – Varad Tasgaonkar
Occupation- Businessman
Age- 46
General Description – Varad Tasgaonkar is a businessman who owns Sunrise cyber cafe at Connaught
Place, New Delhi since 2000.
Statement: I have been running a cyber cafe in Connaught Place for around 23 years and have a huge footfall
on a daily basis because it is at a very prime location. On an average I deal with approximately 250 customers.
On 3rd December 2023 CBI officer, Aayush Trivedi came to my cyber cafe and asked some questions
regarding customers who come to my cafe. I showed him the customer register and after going through it, he
checked one of my computers and asked me for the device history of that computer. I told him that he canget
the exact device history from a company named Burstek. He then asked me if I can recognise my regular
customers to which I said yes.
On 27th December, I received a call from Aayush Trivedi, who asked me to come to the police station with
regards to the investigation. I was informed that my cooperation was needed at the police station to identify
some individuals. Upon reaching there I was asked to wait. Later, a police officer came and escorted me to
another room where 6 people were standing in a queue on one side. Apart from the officer who escorted me,
another police officer along with the executive magistrate was present. The magistrate acquainted himself
with me and very briefly explained to me what the investigation was about. The magistrate then asked if I
had ever been approached by any of the police officers for identification or if I was told about the person to
be identified. To this I answered no. Finally, the Magistrate asked me to identify if anyone amongst the
people standing in the queue were my regular customers at the cafe. After observing the 6 individuals
standing before me, I informed the magistrate that none of them were my regular customers at my cafe. The
magistrate then asked me if I was sure about my answer to which I replied yes. I was brought out of the room
and the officers thanked me for my cooperation and told me that I might be called again if required to help
with the investigation.
After a few days, the defense counsel approached me and showed me a picture of Anushka Bajaj. He asked
me whether I identified her at the time of the TIP which was conducted on the 27 th of December to which I
replied no. The defense counsel then asked me if I could testify the same before the court and I agreed to it.

DEFENSE WITNESS-2
Name – Priyam Charitra
Occupation- Senior Cyber Security Analyst at Network Intelligence
Age- 47
General Description – Priyam Charitra has done her M.Sc. in Cyber Security from the University of London.
She has worked as the Senior Cyber Security Analyst at Network Intelligence for the past 14 years. She is a
Computer Science graduate from IIT Kharagpur.
Statement: I am Priyam Charita and I have worked as the Senior Cyber Security Analyst at Network
Intelligence, Mumbai Branch for the past 14 years. As a part of my job, I work in sectors like security
monitoring, incident response, brand monitoring, site takedown, vulnerability management, and threat
intelligence. In my 14 years of service, I have examined malware of different kinds and have been contacted
to give my expert opinion in various other cases.
I was contacted by the defence counsel to give my expert opinion with regard to the malware found on
Anushka Bajaj’s office computer and her phone. On 15/01/2024 I received copies of the FSL reports dated
06/12/2023 and 13/12/2023.
I have gone through the report and in my considered opinion, the FSL Report dated 06/12/2023 is prepared by
one Ananya Joshi and deals with the Hard Disk of Anushka's office computer. It mentions explicitly that the
hard disk was infected with the “PlugX” alias “Sogu” malware. The infection was found to be infiltrated into
this hard disk through an SMB protocol. On further examination, it was found that there was a backdoor created
in this memory of the hard disk which opened its access to a command-and-control server. Therefore, it
concludes that the accused’s computer, being connected to the same SMB connection as the initial infection
device of “Sogu”, was susceptible and open to a command-and-control server. This in simpler terms, means
that the computer had unauthorised access and the accused was not the only one with access to her computer.
In my professional opinion and the given history of the usage of this malware, it has never been operated and
executed by a sole individual nor can it be possible for a sole individual to operate and execute it. Rather, it is
the work of a group of hackers. A layman, who is not known to the world of technology, is not capable of
beingon the end of this command-and-control server.
With respect to the other FSL Report dated 13/12/2023, the Xiaomi Mobile Device has an application named
Go Keyboard- Emoji Keyboard, Swipe Inputs, GIFs installed on it. As per my knowledge, in 2017, security
researchers discovered that this application was collecting user data and transmitting it to a remote server
based in China. The apps also communicate with tracking networks and execute code from a remote server.
Consequently, from my technical acumen, a seemingly straightforward application like Go Keyboard, which
serves as a keyboard, should not require the extensive set of 27 permissions it requests from users. This, in
turn, strongly suggests the possibility of unauthorised access and remote monitoring.
In summary, the FSL reports provide compelling technical evidence that the accused's computer and mobile
device were compromised, leading to unauthorised access and surveillance, and this assessment is based on
sound technical principles and knowledge.
I have known Ananya Joshi since my college days at IIT Kharagpur. We recently reconnected during the 19th

Alumni Meet of our alma mater in early January. I vaguely remember her bragging to our batchmates about
how she had in the past easily worked around the rules because of her illicit relationship with the Regional
Director of CFSL Pune. She recounted a few incidents where she received lenient treatment from her
supervisors and how her inefficiencies were brushed under the carpet. In this light, I won’t completely rely on
every report made by her.

DEFENCE WITNESS 3
Name- Ankit Ramachandaran
Age- 29
Occupation- Hotel staff
General Description- Ankit Ramachandaran is a room service attendant at The Taj Mahal Palace, Mumbai.
Statement- On the night of 16th November, 2023, I was working the night shift at the hotel when Anushka
Bajaj called the reception to place an order for Chicken Bunny Chow and a glass of dog point pinot noir. at around
9:00 pm. It took a while for the order to get ready, after which at around 9:15 pm I went up to deliver the order
to her room. After ringing the bell for 2-3 times, she opened the door. She was freshly out of the shower and
looked really agitated and panicked. I enquired if everything was okay, to which she replied that there was a
lizard in her bathroom and asked me to help her out to which I gladly obliged.
As I entered the room, the room was in complete disarray. We went to the bathroom and I searched for the lizard
for about a while but couldn’t find the lizard anywhere in the bathroom. She then requested that I search the
bedroom. After diligently looking for approximately 20-25 minutes I finally located the lizard hiding under the
bed. As I was about to swat and kill the lizard, she was scandalized and begged me “No no no, please don’t kill
it, please don’t kill it”. Hence, I proceeded to take the lizard outside and discarded it in the bin, and then I exited.
She graciously thanked me for my assistance.
I remember this encounter quite clearly because as I was going back, I was jokingly thinking to myself as to
how a woman of such a high stature and a mature age could get so worked up by just a tiny lizard.
Then at around 10:15 pm as I was on my way to deliver another order, I bumped into Anushka Bajaj in the
hallway and coincidentally, she was looking for me as she forgot to give me a tip for my help. I thanked her and
went on to deliver the order.
The next day, as I was just about to begin my shift, I was informed by my colleagues about what had happened
and I curiously went to the spot where I saw Anushka Bajaj, who was inconsolably crying. Upon seeing her
state, I offered her water, stayed there for a while and I left after the police officers asked to vacate the area. It
is hardto digest the fact that a person who couldn’t fathom killing a lizard and was inconsolable and frantically
crying,can take the life of another human being.

DEFENSE WITNESS-4
Name – Siddhant Malegaonkar
Age- 28 years
Occupation- Security Assistant, Intelligence Bureau, New Delhi
General Description- Siddhant Malegaonkar is a Security Assistant in the Intelligence Bureau, New Delhi.
Statement- I have been the Security Assistant in the Intelligence Bureau, New Delhi for the past three years
now. Ms. Anushka Bajaj is my senior colleague in the IB office and my interactions with her have always
been more than just office work. Over the past three years and after working with her so closely, I have come
to know who Anushka Bajaj is and I cannot believe that the Investigating agency could be so wrong in its
conclusions.
Those who know her, know that she is a wonderful person who has very little to no technical know-how and
therefore I know that she could not have been involved in high-tech spying. I can never understand how
everyone can think that a person who needs help operating her cell phone could hack the entire office system.
Ma’am is committed to her work, hardly makes any mistakes, and shows the highest level of integrity and
loyalty. She is transparent and open in her communication and has been a mentor and a role model to many of
us, sharing her experience and helping us grow in our professional journey. I have always seen her as a loyal,
trustworthy and honest co-worker and everything that I have learnt in this profession is from ma’am and I shall
be forever grateful for that.
I remember once when I was assigned a task by Anushka ma’am and I made multiple mistakes which got me
into a very big trouble with my seniors. I will never forget that Anushka ma’am stood up for me that day in
front of our seniors where she came in and took ownership of the mistakes I made.
She has always loved and respected this country and I can never question her patriotism. I personally saw her
integrity towards the nation a year ago, when, because of some maintenance work, the Indian flag hoisted
outside of the IB Office had fallen down. Not one person had bothered to pick up the flag, until several hours
later when Anushka ma’am saw it and quickly ran to pick up the flag. A spy who betrays her country would
never do that.
I am one hundred percent sure that Anushka ma’am is not a spy and that she has been made to look like one.In
fact it was she who had suspected for the first time that things were going wrong within the IB. She once had
a conversation with me about how every time when she dealt with something confidential with the Director,
a few days later others in the office would also get to know about the contents of the confidential work. She
said that she had a suspicion on someone but she wouldn’t reveal the name unless she had concreteevidence
regarding the same.
Anushka ma’am is innocent and I feel that because she came to know who really did it, she is now being
framed.

INSTRUCTIONS
1. The 13th Trial Advocacy Competition will be conducted in a set of two Hearings- Hearing1
and Final Hearing. Hearing 1 will be performed by the organizers.
2. The accused, Anushka Bajaj, shall be examined by the organizers in accordance with the
procedure laid down in S.313 of the Criminal Procedure Code, 1973.
3. The transcript of the proceedings of Hearing – 1 will be released.
4. The following witnesses shall be examined in the final hearing, which shall be conducted by
the teams on the day of the competition:
PROSECUTION WITNESSES DEFENCE WITNESSES

PW 1: Aayush Trivedi DW 1: Varad Tasgaonkar
PW 2: Dr. Ananya Joshi DW 2: Priyam Charitra
PW 3: Dr. Akshata Dhirwani DW 3: Ankit Ramachandaran
PW 4: Chetan Kolte DW 4: Siddhant Malegaonkar
This imaginary problem has been drafted for the purpose of the 13th ILS Intra-College Trial
Advocacy Competition, 2023-24, by Anushka Tasgaonkar, Siddhant Chhabra, Aayush
Ramachandaran, Ankit Trivedi (V BA LLB); Chetan Charitra, Priyam Bajaj, Som Dhirwani,
Ananya Upadhye (IV BA LLB); Varad Joshi and Akshata Kolte (III BA LLB).

State of Maharashtra (CBI) v. Anushka Bajaj

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State of Maharashtra (CBI) v. Anushka Bajaj

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ILS Law College

In the CBI Special Court, Mumbai, Maharashtra

CASE NO. 96 of 2024

State of Maharashtra …Prosecution

THE 13th INTRA-COLLEGE TRIAL ADVOCACY COMPETITION 2023-24

THE 13th INTRA-COLLEGE TRIAL ADVOCACY COMPETITION 2023-24

THE 13th INTRA-COLLEGE TRIAL ADVOCACY COMPETITION 2023-24

*The above facts are undisputed and cannot be challenged.

THE 13th INTRA-COLLEGE TRIAL ADVOCACY COMPETITION 2023-24

CENTRAL BUREAU OF INVESTIGATION

State Of Maharashtra (CBI) … Prosecution

Anushka Bajaj … Accused

1. 1. Name of the branch : Special Crimes Division, Central Bureau of

2. Final Report / Charge Sheet No. : 96/2024

4. Sections of Law : Section 3 of the Official Secrets Act, 1923.

5. Type of Final Report Charge Sheet

Un-occurred- False/ Mistake of

8. Investigating Officers : Aayush Trivedi, Superintendent of Police, CBI,

9. Complainant/ Source of : 1. Utkarsh Vyas, Manager at Taj Mahal Palace,

10. Details of Properties/ Articles/ : As per the Annexures.

11. Particulars of accused person

(a) Name : Anushka Bajaj

(b) Father’s Name : Anish Bajaj

(c) Age/ Date of Birth : 51 years; 07.12.1972

(d) Sex : Female

(e) Nationality : Indian

(f) Religion : Hindu

(g) Occupation : Government Service

(h) Address (Present) : Flat No. 201, Krisha Apartments,

THE 13th INTRA-COLLEGE TRIAL ADVOCACY COMPETITION 2023-24

(j) Whether Arrested/On Bail/ : Arrested on 25.12.2023. Presently in judicial custody.

11. Particulars of accused persons Not : N.A

12. If FIR is false, action taken : N.A

13. Result of laboratory analysis : As per Annexures

14. Brief of the case:

15. Facts disclosed during investigation:

THE 13th INTRA-COLLEGE TRIAL ADVOCACY COMPETITION 2023-24

THE 13th INTRA-COLLEGE TRIAL ADVOCACY COMPETITION 2023-24

THE 13th INTRA-COLLEGE TRIAL ADVOCACY COMPETITION 2023-24

17. Dispatched on : 12.01.2024

18. No. of Annexures : 46

FIRST INFORMATION REPORT

(u/s. 154 CrPC)

Serial No. 010/2023 Book No. 02

District : Mumbai Police Station : SCB Mumbai

FIR No. : RC90242023S0786 Date : 18/11/2023

1. Acts & Section

Acts Sections R/W Section

2. Suspected Offence: Murder

Day: Friday Time Period: N.A

From Date: 17/11/2023 To Date: N.A

(b) Information received at P.S.: Letter

(c) General Diary Reference Entry No.: 4 of 18th November

Date: 18/11/2023 Time: 11:15am

3. Type of Information: Written

4. Place of Occurrence: Mumbai

a) Direction and distance from P.S.:42 km (Approx)

THE 13th INTRA-COLLEGE TRIAL ADVOCACY COMPETITION 2023-24

(b) Father’s Name: Mr. Raj Vyas

(c) Date of Birth: 28/08/1990

(d) Nationality: Indian

(e) Occupation: Manager

(f) Address: Flat No. 205, Priyanka Society, Fort, Mumbai.