1. That the complainant is residing of the 28/45 punjabi bagh address with his family .2. The complaintant's father and mother are retired government servants and they earned high esteem and respect from all .3.That the complainant's father owns a house at 24 vidalaya road kewal park azadpur delhi is also running a shop of stationery goods in the name of indu book mart and stationers on the ground floor and rest of the premises were given on rent .4.The accused no 1 and 2 are members of a gang of thugs and cheats which they have formed along with some of their acquaintances .5.It is submitted that accused no 3 is a practicing lawyer and lives in very next building on the first floor of house owned by complaintant's father .The accused no 3 is also an acuaintance , aide and facilitator of offences committed by the accused no 1 and 2 . 6. It is submitted that the accused no 1 and 2 cheated complaintant's father by taking his house on rent by forgery and cheating with an intention to defraud him of property or any pecuniary gains in unfair and unjust manner.Therafter when the tenure of tenancy expired the accused no 1 , 2 and 3 in furtherance of their common intentions levelled and alledged false accusations on the complaintant by fabricating obscene communication to bring legal injury upon complaintant and his family .7. That the accused no.1approached the complaintant's father requesting him for inducting him as tenant on first floor of his house and he produced several identity documents to convince and gave the impression that he is just like a normal couple .He also told the lamdlord about the details of the firm with which he was employed in . The compplaintant father inducted him as a tenant via registered rent agreements no. dated ...............in the office of ........... pitampurafor a period of 11 months and 24 months respectively duly through registered rent aggrement The copies of registered rent agreement are annexed herewith as PW Ex. No. and PE Ex. .The accused no 1 produced and showed his voter identity card as an original document for convincing landlord .After that the accused no1 himself provided photocpy of that voter id card to be submitted along side the police verification form which the landlord did . Even the police verification form was filled in the handwriting of accused . The reciept of the submitted police verification form is exibit no .8. It is submitted that accused no 3 had taken up the residence in the neighbourhood nearly at the same time as to when the accused no 1 and 2 joined .9.After the expiry of tenancy the accused no 1 and 2 refused to vacate even after a legal notice and thereafter started harassing the landlord and his family . The accused no 2 by the virtue of her gender promoted enmity among the two other resident families and turned them against landlord . Accused no 3 also worked in tendum with accused no 1 and 2 and inspite of being a neighbour and and an officer of court missrepresented facts and promoted falsehood and worked as a aide and a facilitator of the crimes committed by accused no 1 and 2 . 10. It is submitted that accused no 2 threatened complaintant who was running a business from shop to implicate him in false and fervolous criminal cases if they were asked to vacate .The accused no 2 being a women started making rumors and false objectionable statements in the neighbourhood and as a result of which the complaintant and his father had to close their shop.Since the complaintant sensed danger and evil intentions of the accused therefore to avoid any unnecessary controversy he stopped coming to his shop and stopped attending his business business . After filing civil suit against tenant the complaintant father opened up shop for the fear of being disposessed from the property . 11. It is submitted that accused no 2 in tendem with accused no 1 and facilitated by accused no 3 started mischief by damaging the property , restraining the landlord and also launched vicious attacks both in vernacular and physical against him . Exibit No. legal notice to stop doing mischief .The landlords complaints against these acts are exibit no ...................12.The absence of personal visit of landlord's son prevented them from hurling any direct allegation , the accused himself fabricated some offensive anonomyous communication and spread that to the locality thereby bringing their dishonest intentions into reality .Motive was just to implicate the accused to make him a leaverage tool upon which they would defame the landlord and his family to grab the property of complaintant father or to extort money thereby causing unjust gain to themselves and unjust loss to the complaintant and his family .The complaint application made by the accused no 1 to the SHO police station is annexed as PEx. no and reading of the plaint in the light of relevant documents submitted by the accused shows clearly that the information is misconcieved and missapproperiated and false and vexious contentions were submitted by the accused .In the complaint the accused states that he is a resident of this particular lane and locality from the past 10 years but in police varification form he submits that his previous address was ..............................also in the civil suit the accused on one hand side is alledging that the landlord and his son is a gunda element but on the other hand is also submitting that he wishes to continue with the same landlord in his house .Its quiet hilarious that a couple wants to stick to continue living with an adversary wheras they can take some other premises on rent somewhere else after all they are paying rent and no body is imused by paying money to continue to stick with an adversary .13.That since by looking at the previous conduct of accused i.e disseminating false and fabricated information aided by the fabrication of forged govt identity documents , conduct of harassment and intemidation , conduct in the court of law and conduct by the way of blackmailing to extort some kind of unjust material gain and that of accused previous attemps to implicate the complaintant and his familyon the basis of fabricated evedience and lame and filmsy excuses shows that the accused has taken laws for a ride without any respect for even the judiciary .14. It is also imperative to mention that That during civil litigation all false pleas and firvolous contentions were dismissed by ADJ and the suit of complaintant father was decreed in his favour on ...................On date ......................the accused made a submission to vacate by not later than and the submission is PEx no ...15. The reason of false implication of complaintant can be adjuged from the very fact that after aforesaid submission to the hon'ble court the accused no 1 and 2 starrted hectic and desperate attempts to bring a police action on the complaintant .Even the accused no 2 threatened police staff of extreme action if they don't accede to their demands because she is a lady . All this occured at the instance of accused no 3 because he being a lawyer and aware of new provisions of criminal amendment act wherein a conviction can be proved just on the oral testimony of a lady complaining of certain acts . Even on day ................... the accused no 2 threatened to slap the complaintant's mother even in front of SHO of PS adarsh nagar . Having being failed in their extorion bid and sensing the approaching deadline to vacate the house which they held illegally accused no 1 and 2 tempered and distroyed the seals of NDPL electricity meter installed within premises . 16. The action of extortion can also be inferred from the fact that the accused didn't vacate as he submitted to the court and instead claimed that he is keen on compromise .Therefore he is admitting to being a party to gain by committing certain acts by themselves by intending to implicate complaintant so that some settlement can be arrived at . 16. It is also submitted that the complaintant through his counsel came to know that accused no 1 and 2 had filed a criminal complaint in which accused no 3 is their lawyer against him u/s 156 3 and later changed that to u/s 200 crpc and submitting that he is interested in prosecuting complaintant for non cognizable offences which are compoundable .This shows that the accused no 3 has the aducity to paint a sorry and grieving image on the canvas of legislature just only to defraud and harass the authorities and complaintant for some unjust gain.17.The cause of action arose as on dated the accused no 1 again mischieviously filled a false police complaint against the complaintant . Since the complaint was false the police took the statement from the complaintant .18. The cause of action arises as the complaintant comes to know about another offending and incriminatory communication made to the police alledging falsehood for which his parents were summoned by vigilence department at ashok vihar .19. That the accused no 1 and 2 are continuin to harass the complaintant and his familly in one way or the another by provocation throuugh anonmyous communication . Any person who has the audocity to prepare forged government documents can also make false private evidences also to defraud and cheat innocent citizens and accused no 3 who inspite of being aware of the real situation is potraying something on reel and that is unbecoming the officer of the court .20.The accused no 1 and 2 and 3 may kindly be prosecuted under various provisions of law for forgery , cheating , distruction of property , criminal intemedation , criminal breach of trust , fabricating false documents and information to the police and for damaging the reputation , attempting to breach peace and attempt to extort .