Chq NI application

IN THE HON’BLE COURT OF THE CHIEF METROPOLITAN MAGISTRATE,
TIS-HAZARI COURT, NEW DELHI

COMPLAINT CASE NO. ________ OF 2024
IN THE MATTER OF:
1. MR. ALPESH LALWANI

AGE: 47 YEARS, OCC: SERVICE
R/O 19/7, SHANTI NAGAR
NEW DELHI - 110007 ) …COMPLAINANT
VERSUS
2. MR. ROHAN TIWARI

AGE : 45 YEARS, OCC : business
PROP. OF M/S ALT TECH
R/o 3rd Floor, 24 Bunglow Road,
Kamla Nagar, New Delhi - 110007 ) …ACCUSED PERSON
INDEX
S. NO. PARTICULARS PAGE NO.

1. MEMO OF PARTIES
2. COMPLAINT BY AND ON BEHALF OF THE
COMPLAINT UNDER SECTION 138 OF THE
NEGOTIABLE INSTRUMENT (N. I.) ACT, 1881
READ WITH OTHER APPLICABLE PROVISIONS
OF THE N. I. ACT, 1881
3. LIST OF DOCUMENTS ALONG WITH THE
DOCUMENTS
4. EVIDENCE BY WAY OF AFFIDAVIT OF THE
COMPLAINANT
5. VAKALATNAMA
COUNSEL THROUGH COMPLAINANT
1
IN THE MATTER OF:

VERSUS
2. MR. ROHAN TIWARI

COMPLAINANT THROUGH GAURAV RANE

(ADVOCATE FOR THE COMPLAINANT)
B-12, EAST OF KAILASH, NEW DELHI -110065
2
IN THE MATTER OF:

VERSUS
2. MR. ROHAN TIWARI

P.S - __________
COMPLAINT FOR TAKING COGNIZANCE OF THE OFFENSE COMMITTED
UNDER SECTIONS 138, 141 & 142 OF THE NEGOTIABLE INSTRUMENTS
ACT, 1881 AMENDED UPTO DATE.
MOST RESPECTFULLY SUBMITTED:-
1. That being aggrieved by the illegal and criminal act of the accused person
named above the complainant is filling the present complaint and seeking
justice before this Hon’ble Court.
2. That the complainant is the permanent resident of the above sated address,
having roots in society and having good friendly and business relations with
the accused person from last 10 years.
3. That the present complaint is being filed by the complainant regarding

dishonor of Cheque issued by Accused Person in favour of Complainant.
4. That th accused person approached the complainant to bail out from the
3
financial crisis and requested for financial assistance for sum of
Rs. 12,50,000/- (Rs. Twelve Lakh Fifty Thousand Only) in the month of
May, 2023.
5. That the accused person requested the complainant for the financial help on
several occasion but the complainant denied the same on each such occasion
however, after repeated request and on the assurance of the accused person,
the complainant in good faith and belief obliged the accused person by
providing his hard earned money as a friendly loan to the tune of
Rs. 12,50,000/- (Rs. Twelve Lakh Fifty Thousand Only) in installment on the
various occasion out of his pocket expenses which the accused person
promised to return with a short period of time.
6. That thereafter the accused person started avoiding the complainant and did
not answer any of his calls. The accused person was only making a fool of the
complainant and had no intention of paying back the hard earned money of
the complainant.
7. The accused person has committed serious offences involving grave acts of
fraud, embezzlement and misappropriation of funds of the complainant.
8. That when Complainant requested the Accused Person on multiple occasions

to return his hard earned money, at last after much hue and cry the accused
person handed over a cheque of Rs. 12,50,000/- (Rs. Twelve Lakh Fifty
Thousand Only) to the Complainant and assured that the said cheque shall be
honoured on presentation.
9. That the details of the cheque which issued by the accused in favour of the
complainant are as follows :
a) Cheque No. – 195725 drawn on Central Bank, Chandni Chowk Branch,

Delhi – 110006 dated 04.11.2023 of Rs. 12,50,000/- (Rs. Twelve Lakh
Fifty Thousand Only) bearing Account No. 5265200052652 issued in
favour of Mr. Alpesh Lalwani (Complainant).
4
10. That at the time of the handing over the above said cheque bearing no.195725
the accused had assured the complainant that the said cheque will be
honoured/encashed on presentation. Taking the above
assurance/representation as true, the complainant had accepted the above said
cheque. That on the basis of assurance given by the accused the complainant
presented the above said cheque in their respective account in the State Bank
of India, New Delhi during the period of their validity on 05.11.2023 hoping
that the same would be enchased. However to the utter shock for the
complainant the said cheque were dishonoured. The aforesaid cheque were
returned upaid vide returning memo dated 20.12.2023 which stated the reason
for dishonor of the said cheque as “Payment Stop by Drawer”. The return
memo dated 20.12.2023 and the cheque bearing no. 195725 drawn on Central
Bank as issued by the accused person to the complainant are already filled
with the complaint herein.
11. That the stoppage of payment after issuance of aforementioned cheque by the
accused is a serious offence under the rigors of Negotiable Instrument and
therefore, the Hon’ble Court ought to take stern action against the Accused
Person and comply with the legislative intent in incorporating deterrent
provision under the said Act.
12. That after the bouncing of the above cheque the complainant contacted the
accused and requested the accused to honour the promise however, all the
assurances made by him nothing but a bundle of lies.
13. That the statutory notice under Section 138 was duly sent to the Accused
Person on 28.12.2023 which is well within time limit of 30 days from the date
of receipt of return memo from Bank. It is stated that the said notice was
received by Accused Person on 05.01.2024 and despite the service of the
Statutory Notice, the accused person has made any efforts to honour the
aforementioned Cheque. The legal demand notice dated 28.12.2023 and the
postal receipt along with the tracking report are filled with the complaint.
14. That the cause of action for filing of the present complaint arose after the
5
expiry of 15 days of the receipt of the aforesaid Legal Notice and due to non-
payment of the amount of the said cheque to the complainant.
15. That the Branch of the Bank in which the Cheque was deposited is situated at
Kamla Nagar and therefore it is situated within the jurisdiction of this Hon’ble
court and thus instant Complaint Case is triable by this Hon’ble Court.
16. That the accused person has thus committed the offence punishable under
Section 138 of the Negotiable Instrument Act read with other applicable
provision of law and thus liable to be tried and punished by this Hon’ble
court.
17. That no other such same or similar complaint is pending before any court in
India or outside.
PRAYER
In view of the above–mentioned facts and circumstances and settled legal

principles it is most humbly prayed that this Hon’ble court may graciously be
pleased to:
a) Take cognizance of the offence committed by the Accused person under

section 138 read with other applicable provision of the Negotiable
Instrument Act and summon, try and punish the accused person in
accordance with law both by way of imprisonment and fine equivalent to
twice the amount of the cheque for the offence committed.
b) Pass and order for the payment of compensation by the accused to the
complainant; and
c) Pass any such order/further order (s) which this Hon’ble court deems fit and
proper in the facts and circumstances of the case and in the interest of
justice in favour of the complainant and against the accused person.
COMPLAINANT
THROUGH
6
COUNSEL FOR THE COMPLAINANT
IN THE MATTER OF:

VERSUS
2. MR. ROHAN TIWARI

LIST OF DOCUMENTS FILED
1. Original cheque bearing no. 195725 drawn on Central Bank for an amount of
Rs. 12,50,000/- (Rs. Twelve Lakh Fifty Thousand Only) issued in the name of
complainant i.e. Mr. Alpesh Lalwani dated 04.11.2023.
2. Original return memo dated 20.12.2023 received on 22.12.2023 for the

dishonor of cheque bearing no. 195725.
3. Legal notice dated 28.12.2023 along with postal receipt and the tracking
report of the above legal notice.
COMPLAINANT
THROUGH
COUNSEL FOR THE COMPLAINANT
7
IN THE MATTER OF:

VERSUS
2. MR. ROHAN TIWARI

EVIDENCE OF COMPLAINT BY THE WAY OF AFFIDAVIT
I, Mr. Alpesh Lalwani, S/o Mr. Naresh Lalwani, R/O 19/7, SHANTI NAGAR
NEW DELHI – 110007 do hereby solemnly affirm declare as under that:-
1. I say that I am the complainant in the present complaint and competent to file
the present complaint before this Hon’ble Court and swear and affirm this
affidavit as my evidence.
2. I say that the complainant is the permanent resident of the above sated
address, having roots in society and having good friendly and business
relations with the accused person from last 10 years.
3. I say that the present complaint is being filed by the complainant regarding
dishonor of Cheque issued by Accused Person in favour of Complainant.
8
4. I say that the accused person approached the complainant to bail out from the
financial crisis and requested for financial assistance for sum of
Rs. 12,50,000/- (Rs. Twelve Lakh Fifty Thousand Only) in the month of
May, 2023.
5. I further say that That the accused person requested the complainant for the
financial help on several occasion but the complainant denied the same on
each such occasion however, after repeated request and on the assurance of
the accused person, the complainant in good faith and belief obliged the
accused person by providing his hard earned money as a friendly loan to the
tune of Rs. 12,50,000/- (Rs. Twelve Lakh Fifty Thousand Only) in installment
on the various occasion out of his pocket expenses which the accused person
promised to return with a short period of time.
6. I say that thereafter the accused person started avoiding the complainant and
did not answer any of his calls. The accused person was only making a fool of
the complainant and had no intention of paying back the hard earned money.
7. I further say that the accused person has committed serious offences involving
grave acts of fraud, embezzlement and misappropriation of funds of the
complainant.
8. I say that when Complainant requested the Accused Person on multiple

occasions to return his hard earned money, at last after much hue and cry the
accused person handed over a cheque of Rs. 12,50,000/- (Rs. Twelve Lakh
Fifty Thousand Only) to the Complainant and assured that the said cheque
shall be honoured on presentation.
9. That the details of the cheque which issued by the accused in favour of the
complainant are as follows :
b) Cheque No. – 195725 drawn on Central Bank, Chandni Chowk Branch,

Delhi – 110006 dated 04.11.2023 of Rs. 12,50,000/- (Rs. Twelve Lakh
Fifty Thousand Only) bearing Account No. 5265200052652 issued in
favour of Mr. Alpesh Lalwani (Complainant).
9
10. That at the time of the handing over the above said cheque bearing no.195725
the accused had assured the complainant that the said cheque will be
honoured/encashed on presentation. Taking the above
assurance/representation as true, the complainant had accepted the above said
cheque. That on the basis of assurance given by the accused the complainant
presented the above said cheque in their respective account in the State Bank
of India, New Delhi during the period of their validity on 05.11.2023 hoping
that the same would be enchased. However to the utter shock for the
complainant the said cheque were dishonoured. The aforesaid cheque were
returned upaid vide returning memo dated 20.12.2023 which stated the reason
for dishonor of the said cheque as “Payment Stop by Drawer”. The return
memo dated 20.12.2023 and the cheque bearing no. 195725 drawn on Central
Bank as issued by the accused person to the complainant are already filled
with the complaint herein.
11. That the stoppage of payment after issuance of aforementioned cheque by the
accused is a serious offence under the rigors of Negotiable Instrument and
therefore, the Hon’ble Court ought to take stern action against the Accused
Person and comply with the legislative intent in incorporating deterrent
provision under the said Act.
12. That after the bouncing of the above cheque the complainant contacted the
accused and requested the accused to honour the promise however, all the
assurances made by him nothing but a bundle of lies.
13. That the statutory notice under Section 138 was duly sent to the Accused
Person on 28.12.2023 which is well within time limit of 30 days from the date
of receipt of return memo from Bank. It is stated that the said notice was
received by Accused Person on 05.01.2024 and despite the service of the
Statutory Notice, the accused person has made any efforts to honour the
aforementioned Cheque. The legal demand notice dated 28.12.2023 and the
postal receipt along with the tracking report are filled with the complaint.
10
11
S.No. Particulars pages court fees
1. Notice of motion
2. Urgent petition 2.75
3. Memo of parties -
4. List of dates and synopsis
5. Petition under section 482 of

Cr.P.C for quashing of
FIR No. 74/2023, under section 498-A/406/34
I.P.C. P.S. Rabale alongwith affidavit.
6. Application under section 482 of CPC

for exemption of certified copies of
annexures alongwith affidavit.
7 Affidavit of respondent No. 2
8. Statement of Non filing
9. Annexure P-1 (Colly)

Photocopy of the FIR and
its true typed copy.
10. Annexure P-2 (Colly)

Residential proof and duly attested Photographs
of the petitioners
11. Annexure P-3
Residential proof and duly attested Photographs

of the respondent No. 2
12. Court Fees
13. Vakalatnama
12
DATED: 06/09/2023
COUNSEL FOR THE PETITIONERS
13
IN THE HON’BLE HIGH COURT OF JUDICATURE AT BOMBAY
BENCH AT BOMBAY
CRIMINAL M.C. No. 304 OF 2023
IN THE MATTER OF:

1. AJIT DINESH PAWAR )
AGE: 31 YEARS, OCC: SERVICE ) …PETITIONER NO 1
2. SEEMA DINESH PAWAR )

AGE : 55 YEARS, OCC : SERVICE ) …PETITIONER NO 2
3. PRASHANT DINESH PAWAR )

ALL R/AT: C-403, ANJALI CHS. LTD., PLOT NO. 212

AND 213, SECTOR NO. 8, VASHI (E), NAVI MUMBAI - 400705
VERSUS
THE STATE OF MAHARASHTRA ) …RESPONDENT NO 1
MRS. BHARTI AJIT PAWAR ) …RESPONDENT NO 2
TO,
THE DEPUTY REGISTRAR, HIGH
COURT OF BOMBAY.
SUBJECT: URGENT APPLICATION

Sir,
Kindly treat the enclosed petition as an urgent one according to High Court
rules and orders. The ground of urgency is as under:-
“Necessary orders for quashing the FIR No. 74/2023, under section 498-
A/406/34 I.P.C. P.S. Rabale are prayed for.”
DATED: 06/09/2023
PETITIONERS THROUGH COUNSEL
14
BENCH AT BOMBAY
IN THE MATTER OF:




VERSUS
NOTICE OF MOTION
The Standing Counsel (Crl.),

High Court Bombay
Sir,
The accompanying petition is being preferred for quashing of FIR No.
74/2023 under section 498-A/406/34 I.P.C. P.S. Rabale is
annexed, which is likely to come up before the Hon'ble High Court on
06/09/2023 thereafter or any other date.
This is for your information and necessary action.
DATED: 06/09/2023
15
BENCH AT BOMBAY
IN THE MATTER OF:




AND 213, SECTOR NO. 8, VASHI (E), NAVI MUMBAI
VERSUS
PETITION UNDER SECTION 482 OF THE CODE OF CRIMINAL

PROCEDURE, 1973 PRAYING THIS HON’BLE COURT TO PASS
NECESSARY ORDERS AND DIRECTION THEREBY QUASHING
AND CANCELLING THE FIR NO.74/2023, UNDER SECTION 498-
A/406/34 I.P.C. P.S. Rabale
MEMO OF PARTIES




VERSUS
DATED: 06/09/2023

List of Dates and Events
Date Particulars of events
22/12/2021 The marriage between the petitioner No. 1 and

respondent No. 2 was solemnized according to Hindu
rites and ceremonies at Thane on 22/12/2021. The
marriage between the parties was duly consummated
and out of this wedlock no issue was born.
22/12/2021 That after the marriage, the petitioner No. 1 and

respondent No. 2 lived together as husband and wife in
the matrimonial home.
02/09/2023 A complaint filed in CAW Cell against the petitioners

by the respondent No. 2 on 02/09/2023
02/09/2023 In pursuant to the above complaint, a FIR No.74/2023,
under section 498-A/406/34 I.P.C. P.S. Rabale was
registered against the petitioner No. 1 and his family
members.
06/09/2023 That due to the intervention of the Mediation Centre,/

or Relatives, the matter between both the petitioners
have been amicably settled vide order dated
06/09/2023
Hence this petition
BENCH AT BOMBAY
IN THE MATTER OF:




VERSUS
PETITION UNDER SECTION 482 OF THE CODE OF CRIMINAL

PROCEDURE, 1973 PRAYING THIS HON’BLE COURT TO PASS
NECESSARY ORDERS AND DIRECTION THEREBY QUASHING
AND CANCELLING THE FIR NO.74/2023, UNDER SECTION
498-A/406/34 I.P.C. P.S. Rabale
AND ALSO
PRAYING THIS HON’BLE COURT TO PASS ANY OTHER

ORDER OR DIRECTION AS THIS HON’BLE COURT MAY DEEM
FIT AND PROPER IN THE FACTS AND CIRCUMSTANCES OF
THE CASE.
TO,
THE HON’BLE CHIEF JUSTICE AND

HIS HON’BLE COMPANION
JUSTICES OF THE HIGH COURT OF BOMBAY.
THE HUMBLE PETITION OF THE PETITIONERS ABOVE NAMED.

MOST RESPECTFULLY SHOWETH:
1. That the marriage between the petitioner No. 1 and respondent No. 2
was solemnized on 2 2 / 1 2 / 2 0 2 1 at Thane according to Hindu rites
and ceremonies. The marriage was duly consummated and out of this
wedlock no issue was born.
2. That the petitioner No. 1 is the husband, petitioner No. 2 is the

mother-in-law, Petitioner No. 3 is the sister-in-law and petitioner No. 4
is brother-in-law of the respondent No. 2 complainant.
3. That there is irretrievable break down of the marriage due to

incompatible behaviour, conduct and temperament of the parties.
Accordingly, the parties to the petition have been living separately
since 20/04/2023 and have not been able to live together or cohabited
since then.
4. That a complaint filed in CAW Cell against the petitioners by the

respondent No. 2 on 02/09/2023 and the said complaint converted into
FIR No. 74/2023, under section 498- A/406/34 I.P.C. P.S. Rabale. True
photocopy of the FIR and its true typed copy are annexed herewith as
Annexure P-1 (Colly).
5. That due to the intervention of the Mediation Centre/Relatives, both the

petitioner No. 1 and Respondent No. 2 have mutually agreed before the
Mediation Cell, HON’BLE HIGH COURT OF JUDICATURE AT
BOMBAY Court that their marriage may be dissolved and that there
shall be no claim whatsoever made out against any of the parties or
against each other and they shall be bound by the conditions settled
amongst them before the Mediation Cell, HON’BLE HIGH COURT OF
JUDICATURE AT BOMBAY Court.
6. That both the parties have agreed upon a settlement that the Petitioner
No. 1 will pay a total sum of Rs. 6,00,000/- on 23/08/2023 account of
full and final settlement of all past present and future claims of all kinds
in lieu of dowry articles, Stridhan, maintenance present past and future
and also includes all claims of permanent alimony.
7. That the said amount will be divided in 3 installments of Rs. 2,00,000/-
at the time of First motion to the petitioner No. 1, second installment
of Rs. 2,00,000/- was paid at the time of second motion and last and
final installment of Rs. 2,00,000/- being paid at the time of quashing of
the FIR No. 74/2023 u/s 498-A/406/34 I.P.C. P.S. Rabale.
8. That the respondents No.2 has no more grievance against the petitioner.
The respondent No.2 is not willing to support the imputations made in
the said FIR against the petitioners because the dispute in question has
already been settled/compromised between the parties. In these
circumstances, there are no chances of successful prosecution and
conviction of the petitioners. Therefore, no fruitful purpose will be
served while allowing the criminal proceedings in question to continue.
The very purpose of justice will be frustrated by allowing the criminal
proceeding in question to continue.
9. That the compromise between the parties has been arrived with their free
consent, without any threat or pressure or coercion or undue influence.
10. That the respondents no.2 has no objection if the FIR in question is
quashed qua the petitioners.
11. That the Petitioner crave leave of the Hon'ble Court to urge such
further additional ground (s), at the time of hearing of this petition,
which have not been specifically taken up in this petition.
12. That the Petitioners have not alternative and efficacious remedy except
to approach this Hon'ble Court for seeking relief claimed in the petition.
13. That the Petitioners have not filed any other similar petition seeking
quashing of complaint case in question either before this Hon'ble Court
or before the Hon'ble Supreme Court of India.
14. That the Annexures annexed with this petition are true copies of their
respective originals.
PRAYER
It is, therefore, most humbly and respectfully prayed that this Hon'ble
Court may kindly be pleased to quash the FIR No. 74/2023, under section
498-A/406/34 I.P.C. P.S. Rabale, in the interest of justice.
DATED: 06/09/2023

BENCH AT BOMBAY
IN THE MATTER OF:




VERSUS
AFFIDAVIT
I, AJIT DINESH PAWAR S/O DINESH RAMESH PAWAR, AGED

about 31 YEARS R/O C-403, ANJALI CHS. LTD, PLOT NO. 212 AND
213, SECTOR NO. 8, VASHI (E), NAVI MUMBAI – 400 705 do hereby
solemnly affirm and declare as under:
1. That the deponent is petitioner No. 1 in this petition and is fully

conversant with the facts and circumstances of this case. The deponent
is competent to swear this affidavit.
2. That the accompanying petition has been drafted and filed under my
instructions by my counsel. I have read the same in between the lines
and the same is true and correct to the best of my knowledge and belief
and nothing has been concealed therein.
3. That the deponent has not filed any other similar petition seeking
quashing of FIR in question either before this Hon'ble Court or before
the Hon'ble Supreme Court of India.
VERIFICATION:
Verified at Mumbai on this 06 day of September, 2023 that the contents
of the above affidavit are true and correct to the best of my knowledge
and belief and nothing material has been concealed therein.
DEPONENT
BENCH AT BOMBAY
IN THE MATTER OF:




VERSUS
STATEMENT OF NON FILING
That the Petitioners have not filed any other similar petition seeking
quashing of FIR in question either before this Hon'ble Court or before the
Hon'ble Supreme Court of India.
DATED: 06/09/2023

BENCH AT BOMBAY
IN THE MATTER OF:




VERSUS
APPLICATION UNDER SECTION 482 Cr.P.C. FOR EXEMPTION

FROM THE FILING CERTIFIED COPY OF THE ANNEXURES.
MOST RESPECTFULLY SHOWETH:
1. That the petitioners have filed the above said petition before this
Hon'ble Court seeking quashing of FIR No. 74/2023, under section
498-A/406/34 I.P.C. P.S. Rabale , the contents whereof are not being
repeated herein for the sake of brevity and may be read as part and
parcel of the present application.
2. That the petitioners are unable to furnish the certified copy of the
aforesaid annexures at this stage and will submit the same before this
Hon’ble Court after their receipt.
It is, therefore, most humbly and respectfully prayed that filing of the
certified copies of the annexures may kindly be exempted, in the interest of
justice.
DATED: 06/09/2023

BENCH AT BOMBAY
IN THE MATTER OF:




VERSUS
AFFIDAVIT
I, AJIT DINESH PAWAR S/O DINESH RAMESH PAWAR, AGED

about 31 YEARS R/O C-403, ANJALI CHS. LTD, PLOT NO. 212 AND
213, SECTOR NO. 8, VASHI (E), NAVI MUMBAI – 400 705 do hereby
solemnly affirm and declare as under:
1. That the deponent is petitioner No. 1 in this petition and is fully

conversant with the facts and circumstances of this case. The deponent
is competent to swear this affidavit.
2. That the contents of the petition u/s 482 Cr.P.C. for exemption from
filing the certified copy of annexures has been drafted by my counsel
as per my instruction and the contents of the same have been duly read
over and understood by me and after fully understanding the contents
of the same, I hereby state that the facts stated therein are all true and
correct to the best of my knowledge. The contents of petition may
kindly be read as part and parcel of this affidavit also as the contents of
the same have not been repeated herein for the sake of brevity.
VERIFICATION:
Verified at Mumbai on this 06 day of September, 2023 that the contents
of the above affidavit are true and correct to the best of my knowledge
and belief and nothing material has been concealed therein.
DEPONENT
BENCH AT BOMBAY
IN THE MATTER OF:




VERSUS
COURT FEES
DATED: 06/09/2023

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IN THE HON’BLE COURT OF THE CHIEF METROPOLITAN MAGISTRATE,

TIS-HAZARI COURT, NEW DELHI

IN THE MATTER OF:

1. MR. ALPESH LALWANI

2. MR. ROHAN TIWARI

S. NO. PARTICULARS PAGE NO.

COUNSEL THROUGH COMPLAINANT

IN THE MATTER OF:

1. MR. ALPESH LALWANI

2. MR. ROHAN TIWARI

COMPLAINANT THROUGH GAURAV RANE

IN THE MATTER OF:

1. MR. ALPESH LALWANI

2. MR. ROHAN TIWARI

MOST RESPECTFULLY SUBMITTED:-

3. That the present complaint is being filed by the complainant regarding

8. That when Complainant requested the Accused Person on multiple occasions

a) Cheque No. – 195725 drawn on Central Bank, Chandni Chowk Branch,

In view of the above–mentioned facts and circumstances and settled legal

a) Take cognizance of the offence committed by the Accused person under

IN THE MATTER OF:

1. MR. ALPESH LALWANI

2. MR. ROHAN TIWARI

LIST OF DOCUMENTS FILED

2. Original return memo dated 20.12.2023 received on 22.12.2023 for the

IN THE MATTER OF:

1. MR. ALPESH LALWANI

2. MR. ROHAN TIWARI

EVIDENCE OF COMPLAINT BY THE WAY OF AFFIDAVIT

NEW DELHI – 110007 do hereby solemnly affirm declare as under that:-

8. I say that when Complainant requested the Accused Person on multiple

b) Cheque No. – 195725 drawn on Central Bank, Chandni Chowk Branch,

2. Urgent petition 2.75

4. List of dates and synopsis

5. Petition under section 482 of

6. Application under section 482 of CPC

7 Affidavit of respondent No. 2

8. Statement of Non filing

9. Annexure P-1 (Colly)

10. Annexure P-2 (Colly)

11. Annexure P-3

Residential proof and duly attested Photographs

COUNSEL FOR THE PETITIONERS

CRIMINAL M.C. No. 304 OF 2023

IN THE MATTER OF:

2. SEEMA DINESH PAWAR )

3. PRASHANT DINESH PAWAR )

ALL R/AT: C-403, ANJALI CHS. LTD., PLOT NO. 212

THE STATE OF MAHARASHTRA ) …RESPONDENT NO 1

MRS. BHARTI AJIT PAWAR ) …RESPONDENT NO 2

SUBJECT: URGENT APPLICATION

PETITIONERS THROUGH COUNSEL

CRIMINAL M.C. No. 304 OF 2023

IN THE MATTER OF:

2. SEEMA DINESH PAWAR )

3. PRASHANT DINESH PAWAR )

ALL R/AT: C-403, ANJALI CHS. LTD., PLOT NO. 212

THE STATE OF MAHARASHTRA ) …RESPONDENT NO 1

MRS. BHARTI AJIT PAWAR ) …RESPONDENT NO 2

The Standing Counsel (Crl.),

This is for your information and necessary action.

PETITIONERS THROUGH COUNSEL

CRIMINAL M.C. No. 304 OF 2023

IN THE MATTER OF: