TO,

Station Head Officer,

Police Station Sector-20,
Gautam Buddh Nagar,
Noida-201301, UP.

Sub: Complaint under Section 420/406/468/469/470/34

read with section 129B, against Accused No.-1 Sh. Piyush
Jain S/o Sh. Arun Kumar Jain (Phone no. xxxxxxxxxx) R/o C-
194, Sector 20, Noida, Gautam Buddh Nagar, UP, Accused
No.2, Smt. Basant Wasan W/o Late sh. Vijay Wasan And
Accused no.-3, Sh. Harsh Wasan S/o Sh. Vijay Wasan, Both
resident of B-157, Sector-19, Noida-201301

Respected Sir,

I Harish Katyal, son of Late G. D. Katyal (Phone no.

9810256667), permanent resident of H-30, Sector-39, Noida
(UP) working as an professional. The accused person is in the
Business of Real Estate/ Investments and was introduced as
man of means by a common friend Sh. Rajiv Sachdeva (Lajpat
Nagar), the Accused No. 2 and 3 were never introduced or met
with the Complainant or even not known to the Complainant.

That, in the month of June-July 202, when, the complainant

was looking forward for some suitable property can be used for
the office cum residence purpose, a common friend Sh. Rajiv
Sachdeva, who owned several showrooms in Lajpat Nagar,
informed the Complainant that one of his friend namely Sh.
Piyush Jain who is also residing in Noida, had one property as
Plot Bearing no. 25, Block C, Sec 27, which he wants to
dispose of and is suitable for the purpose of the complainant.

That since the complainant during relevant period was having

good relationship with Sh. Rajiv Sachdeva, believed upon his
statements, agreed to purchase the property as Plot No. 25,
Block-C, Sector-27, Noida-201301, admeasuring 108 Sq. Mts.
The Accused no.-1 had also handed over the copy of the title
deeds of the property duly executed in his favor by one Sh.
Richarad Robertson S/o Sh. Edgar Robertson, on dated in the
year 2011, and duly registered with the office of the Registrar
as document no. 4082 and entered in additional book no.-1,
Volume / Zild no. 327 at pages 163 to 202 on dated
11.04.2011. The Accused no.-1 also handed over various other
documents related to the property, through Sh. Rajiv
Sachdeva. It was explained over phone and understood that
the accused no.-1 was not able to visit the Complainant hence
sent these documents through common friend only. Copy of
the sale deed of the property Plot No. 25, Block-C, Sector-27,
Noida-201301, admeasuring 108 Sq. Mts. In the name of he
Accused No.-1 is annexed herewith AS ANNEXURE C-1.

That in the first week of august 2021, the Complainant

believing upon the version of the accused persons and
representation made before the complainant agreed to
purchase the said plot for a total sum of rs. 1,00,00,000/-
(Rupees one crore only). And in furtherance of the intention to
show seriousness in purchasing the property as per request of
the Accused no.-1, had agreed to pay 10% of the total sale
consideration as Advance Money under the Buy-nama for
purchase of the property Plot No. 25, Block-C, Sector-27,
Noida-201301, admeasuring 108 Sq. Mts. With all the rights
and interest in the property, and issued a Cheque bearing no.
“000608” of Rs. 10,00,000/- (Rupees Ten Lakhs Only) in the
name of “Piyush Jain” (accused No.-1) drawn on HDFC
Bank, Branch New Friends colony, New Delhi, without
mentioning any date thereon, upon the request of the Accused
No.-1.

That the said Cheque No. 000608 issued as Crossed Cheque

in favor of Accused No.-1 got encahsed form the Bank of the
Complainant on dated 19.08.2021, and paid in the account of
Accused No.-1 only. The complainant since after the issuance
of the said cheque in the first week of August, waiting to
receive the signed Agreement to sell / Buy-nama form the
accused No.-1, and called him and Sh. Rajiv Sachdeva, several
times. But the Accused No.-1 only in Sept. 2021, had send the
agreement to sell duly executed by the accused No.-2 and 3 as
owner of the property Plot No. 25, Block-C, Sector-27, Noida-
201301, admeasuring 108 Sq Mts. When the complainant
enquired form the accused no.-1 about this all the Accused
No.-1, no.-1 with the request of confidentiality explained that
since he had taken finance from the accused No.2 and 3 and
in turn had kept the original title deeds of the property under
their custody, and all the money whatever he will receive will
be utilized to repay the said debt, and thereafter only he will
be able to execute the sale deed of the property ( this story was
explained to the Complainant by Sh. Rajiv Sachdeva and put
Accused No.-1 on call from his mobile). That in proof of their
statement he pointed out the portion in the agreement to sell
dated 21.09.2021, wherein it was mentioned that the Accused
No.-1 had transfer the entire amount of Rs. 10,00,000/-
(Rupees ten lacs only) in account of Accused 2 and 3, Vide
RTGS under UTR no. KKBKR520802100759626.
Simultaneously the Accused No.-1 assured the complainant
that he only will execute the sale deed of the property Plot No.
25, Block-C, Sector-27, Noida-201301, admeasuring 108 Sq
Mts. The complainant had no other option except to believe
upon the statement and assurance of the Accused No.-1. Copy
of the Agreement to sell dated 21.09.2021 is annexed herewith
AS ANNEXURE C-2. And copy of the Cheque issued in the
name of the accused NO.-1 ND PROOF OF PAYMENT OF THE
SAME IS ANNEXED HEREWITH AS ANNEXURE C-3.

That later on the Complainant come to know, that there is

nothing such had happened and the accused no.-1 made a
story concocted by him in order to avoid execution of the
Agreement to sell of the property Plot No. 25, Block-C, Sector-
27, Noida-201301, admeasuring 108 Sq Mts. In fvaor of the
Complainant, so that he should not got impleaded in any case
in future (since was having malafide intention to make
wrongful loss to the Complainant for his wrongful gain).

That the When the complainant form the ATS had come to
know that there is some case is pending which need to be
decided, he enquired form the Accused No.-1, who in turn
disclosed that there was small dispute going on between the
previous owner ( his seller) and his family members, and
though the same will not effect the tile of the property,
complainant need not to bothered, but the sale deed will only
be executed after the final decision in the said case.

That the Complainant upon the assurance of the accused No.-

1 waited for the substantial period, and when even two years
were passed nothing has bene heard from the accused
persons, the complainant served legal notice upon the accused
persons, but surprisingly the Notice sent to the Accused
persons, received back unserved with the remarks form he
postal department that “no such person” for Accused persons.
Copy of the sealed envelop received back in the office of the
Advocate is annexed herewith AS ANNEXURE C-4 & 6.

That in view thereof it is understood that the Accused persons

in active connivance with each other with the malafide
intention had planned and induced the Complainant to part
with the huge amount, believing upon their wrong and
manipulated statements and documents, to cause wrongful
loss to the Complainant for their wrongful gain.

That the accused persons not only made wrong/ manipulated

and false statement but also appropriated huge amount of rs.
10,00,000/- and neither come forward to execute/ registered
the sale deed of the property, nor returned the same together
with the interest and penalty/ damages etc. And whenever the
Complainant asked form the accused No.1, regarding
execution/ registration of sale deed of the property Plot No. 25,
Block-C, Sector-27, Noida-201301, admeasuring 108 Sq Mts.
He made false commitment and start explaining excuses for
the delay. The Accused persons never informed the
Complainant about the cases pending as per them, nor they
informed about the progress in the case or about any order
passed in the case as admittedly pending in Court of Law. The
accused persons as stated before the Complainant that there
is no dispute or issue pending in court of law related to the
title or ownership of the property, therefore there was no
reason to delay the execution / registration of the sale deed.

The Accused hereby jointly and in active connivance with each

other had cheated the Complainant and appropriated the hard
earned money of the Complainant and handed over to him
forged and fabricated documents, and caused offence
punishable under the provisions of Section420/406/468/
470/34/120B IPC. You are requested to investigate and find
the where about of the Accused Persons and registered FIR
against them under appropriate provisions of law (as
mentioned herein above) and prosecute them accordingly.

Place: Noida -201301 COMPLAINANT

Date:

Harish katyal S/o Late Sh. G.D. Katyal

(9810256667)