BEFORE SHRI RAGHUBIR SINGH: LD.

SPECIAL EXECUTIVE
MAGISTRATE: WEST DISTRICT: POLICE STATION MOTI
NAGAR, NEW DELHI

Kalandra No.52AB/2023
Police Station Tilak Nagar,
D.D. No.172A dated 08.09.2023
Under sections 107/150 Cr.P.C.

REPLY ON BEHALF OF HARPREET KAUR AND HER

BROTHER BALVINDER SINGH, TO THE NOTICE ISSUED
UNDER SECTIONS 107/111 OF THE CODE OF CRIMINAL
PROCEDURE

RESPECTFULLY SHOWETH:

1. That the present kalandra has been initiated at the instance

of the local police. In fact, there is no apprehension of
breach of peace and as such the local police at the instance
of the opposite side has initiated the proceedings with the
object to blackmail the respondents and to extract money
from them and the fraudulent conduct of the complainant
is also clear from the fact that the present complaint has
been made only with the object to blackmail the
respondents and to extract money from them in the garb of
the present complaint knowing fully well that the
respondents are innocent persons and have been falsely
implicated in the said case. In fact, the true facts of the
matter are that the second and third floors of the property
 bearing No.WZ-3/2, Plot No.14, Vishnu Garden, New
Delhi, are owned by Amarjeet Kaur and Shri Ravinder
Singh (hereinafter referred to as the complainants) and
they are residing therein along with their family members
consisting of themselves and three children and their
respective family members namely Harjeet Singh (elder
son), Ranjeet Kaur (daughter – single mother) and Dhanna
(son). The brief facts are that Ms. Ranjeet Kaur, daughter
of Smt. Amarjeet Kaur and Shri Ravinder Singh prior to
her marriage, was living on the second and third floors of
the property bearing No.WZ-3/2, Plot No.14, Vishnu
Garden, New Delhi, and Shri Balvinder Singh was living
along with his parents on the ground floor and first floor of
the same property.

2. That the said Smt. Ranjeet Kaur before her marriage,

wanted to marry with said Shri Balvinder Singh, who was
already married and he showed his inability to marry with
her but unfortunately, she was persuading him that he
should obtain a divorce from his wife and marry with her
and the said Shri Balvinder Singh refused to accede the
illegitimate demands of the said Ranjeet Kaur.

3. That on several occasions, the said Ranjeet Kaur met Shri

Balvinder Singh in the stair cases which is a common stair
case from ground floor to the top floor of the said property
and on several occasions, she had touched him and
requested him for entering into matrimonial alliance
illegally and the said Shri Balvinder Singh openly told that
 it is not possible or feasible for him to marry with him and
ultimately, she was married to one Shri Raja Bodhi who
was living across the road of the said property and
neighbourer and were known to each other and after
marriage, a son was born from the wedlock of the parties
but ultimately, on account of her attitude and behaviour,
her husband was also forced her to leave her and
consequently, she is living with her parents and while
living with her parents, she again approached the said Shri
Balvinder Singh for marriage and further threatened that in
case he would not marry with her, in that event, she would
commit suicide and would implicate him in a false case
with the object to teach a lesson to him and would make
his live a miserable hell and he through-out the life would
remain in the jail and further threatened that in case her
demands are not fulfilled, then in that event, she would try
to implicate each and every family member and would
sent them to Tihar Jail for the purposes of teaching them a
lesson.

4. That the fraudulent conduct of the said Smt. Ranjeet Kaur

who has been harassing the said Shri Balvinder Singh and
his family members, as per the details mentioned below:-

(a) That the said Smt. Ranjeet Kaur with the collusion of her
parents, started raising illegal construction over the roof of
the third floor of the said property unauthorizedly and Shri
Balvinder Singh had made a complaint to the M.C.D. and
M.C.D. on the basis of the said complaint, initiated
 proceedings for demolition of the fourth floor which was
being constructed by the said Smt. Ranjeet Kaur with the
collusion of her parents and ultimately, the same was
demolished partly and further while proceeding with the
construction of the fourth floor, she had locked the stairs
and was not allowing the said Shri Balvinder Singh that in
case they would visit the roof for the purposes of
inspection of the water roof, in that event, they would
teach a lesson to them

(b) That the said Smt. Ranjeet Kaur had broken the water pipe
of the second floor as a result whereof, the water started
dripping from the second floor to the walls of the first
floor and ground floor of the said property as a result
whereof, the walls have been badly damaged and seepage
has been caused in the building as a result whereof, the
foundation of the building has also become weak and there
was an apprehension that the walls may not collapse at any
moment due to seepage of the water into the walls. A
complaint in this regard was also made to the M.C.D.
along with photographs.

(c) That the parking area on the ground floor exclusively used
and enjoyed by the owner of the ground floor and first
floor of the said property and the owner of the second and
third floor have no right to use the said parking area and
the said Smt. Ranjeet Kaur with the collusion of her father,
brother and other family members had illegally broke open
the locks and tried to trespass therein with the object to
 grab the said common parking and further threatened that
in case any one has any temerity or courage, he should
come forward and claim any right in the said parking
space and consequently, the matter was reported to the
local police in this regard but no action was taken because
of the influence of the said Smt. Ranjeet Kaur.

(d) That the said Smt. Ranjeet Kaur had illegally erected a
gate in the common stairs on the second floor and a
complaint in this regard was made because the stair case is
common and no body can put any gate on the common
stairs and on the basis of the report made to the M.C.D.,
the M.C.D. was pleased to take action regarding the
removal of the gate so affixed in the common stairs at the
second floor.

(e) That the motor as well as the water meter of the first floor
portion was got stolen by Smt. Ranjeet Kaur along with
her brother Shri Harjeet Singh for which a police
complaint was also made to the local police.

(f) That the said Shri Balvinder Singh along with his family
members had kept their goods and articles in the parking
space on account of renovation work going on in the
ground floor and first floor portions of the said property,
the said Smt. Ranjeet Kaur and her brother had badly
damaged the said goods and articles on two different
occasions i.e. initially by her brother and subsequently by
Smt. Ranjeet Kaur wherein the goods worth lacs of rupees
 including laptop worth Rs.26000/- was badly damaged.
The police complaints in this regard were also lodged
along with the photographs to the local police but no
action was taken on the basis of the said complaints.

5. That every now and then the said Smt. Ranjeet Kaur and
her brother are threatening that in case the respondents
would not settle the matter, in that event, they would mix
the poisonous substance in the over head water tank as a
result whereof, they would see that all the family members
may die due to inhaling of the poisonous substance. They
also threatened that they would also put the car parked
outside the property to fire and would see that the flames
of the said car would go from ground floor to the top floor
and further threatened that the female ladies members
would be kidnapped and abducted to some unknown place
and there would be killed and the entire police station is in
his pocket and no body can take any action against any
one without the consent and knowledge of the said Smt.
Ranjeet Kaur notwithstanding the fact that he is not having
sufficient funds to pay the electricity charges what to
speak of purchasing the entire police force of the police
station, Tilak Nagar, New Delhi.

6. That the said Smt. Ranjeet Kaur has also made various
complaints against her husband and being a lady, she is
misusing the law because some protection has been given
to the women and she is misusing those protection with
 the object to blackmail the innocent persons and to extract
money from them.

In view of the above circumstances, I request you to withdraw

the notice under reply as there is no apprehension of breach of
peace. In fact, the said complaint has been made at the behest of
the local police with whom she is having hands in glove. As the
kalandra against other two persons i.e. one against the daughter
of Smt. Harpreet Kaur and another against the elder brother of
Smt. Harpreet Kaur, the names of those persons have been
wrongly mentioned in the kalandra and they have been falsely
implicated with oblique motives behind and as such necessary
compensation of Rs.1 lac be also awarded to the respondents.

Thanking you,
Yours faithfully

(Hapreet Kaur)

(Balvinder Singh)
WZ-3/2, Plot No.14, Ground Floor,
Vishnu Garden, New Delhi