To, Date:07/11/2015The SHO ,

PS ADARSH NAGAR

DELHI-110033.

SUBJECT : INFORMATION REGARDING A GANG OF ANTI-SOCIAL ELEMENTS INVOLVED IN FOREGING GOVT.DOCUMENTS AND CHEATING IN AZADPUR,DELHI-110033.

ProposedACCUSED NO.1 :Vishnu Kumar bhartia

S/O radhe shyamC/O. B 31/2 Wazirpur industrial area, Delhi & also(presently) resident of somewhere in Azadpur/AdarshNagar .

PurposedAccused no.2:vineeta bhartia

W/O Vishnu Kumar bhartiaPurposedAccused no.3:rajesh kumar misra R/O. H.No. 26 , 1st floor , vidyalaya road ,kewal park Azadpur Delhi-33.

The most respectfully showeth the plaintiff/complainant begs to submitas:

1. That the complainant is residing at address 28/45 Punjabi Bagh with his family .

2. The complainant's father and mother are retired government servants and they have earned high esteem and respect in the society.

3.That the complainant's father ownsa house at 24 vidalaya road kewal park azadpur delhi.Both of them wererunning a small 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 membersof a gang of thugs and cheats whichthey have formed among self and along with some of their acquaintances . Mo-rover it is also submitted that the accused no 1 and

2 are husband and wife as far as theordinary social status is concerned but there is a lot more than what that meets the eye. The matrimonial relationship is just only a shroud by the virtue of which the accused gets entry into the society and thereafter the accused no 1 and 2 identify some vulnerable people and accused no 2 takes advantage of her gender to implicate anyone whom the accused no 1 2 and 3 finds conservative and shy and can be blackmailed by threats and acts of humiliation by public shame.

5.It is submitted that accused no 3 is a practicing lawyer and lives invery next building on the first floor of house owned by complainant's father. The present address of accused no.3 is :house no26 , first floor , vidalaya road,kewal park , azadpur ,Delhi-33 .The accused no 3 is also an acquaintance , aide , abettor and facilitator of offences committed bythe accused no 1 and 2 .

6. It is submitted that the accused no 1 and 2 cheated complainant's father by taking his house on rent by forgery and cheating with an intention to defraud him of his property and to get any pecuniary gains in unfair and unjust manner. Their after when the tenure of tenancy expired the accused no 1 , 2and 3 in furtherance of their commonintentions started leveling false accusations on the complainant by themselves fabricating obscene communication to bring legal injury upon complainant and his family .

7. That the accused no.1 approachedthe complainant'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 landlord about thedetails of the past residences & firm with which he was employed in .The complainant father inducted him as a tenant via registered rent agreements no.IN-DL025077290513891

DATED 16/02/2010 & IN-DL04422730180392J dated 04/01/2011 in the office of .deputy. Registrar ,Pitampura , Delhi for a period of 11 months and 24 months respectively .The copies of registered rent agreement are annexed herewith as PW Ex. No. andPE 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 photocopy of that voter ID card to be submitted alongside the police verification form which the landlorddid. Even the police verification form was filled in the handwriting of accused. The receipt of the submitted police verification form is exhibit no. Later the complainanthas come to know that the voter card/ID is a forged document which has been forged using advanced computer program/editing software.

8. It is submitted that accused no 3had taken up the residence in the same manner in the neighborhood nearly at the same time when the accused no 1 and 2 joined the locality .Mo over the conduct of accused no 3 leaves no doubt that the accused no 1 , 2 & 3 are accomplices and they know about eachother for quite a long time .

9. After the expiry of tenancy the accused no 1 and 2 refused to vacateeven after a legal notice and thereafter started harassing the landlord and his family .It is pertinent to say that the conspiracywas started to be implemented as soon as the accused no 1 took up thepremises on the basis of forged document. The accused no 2 by the virtue of her gender promoted enmityamong the two other resident families and turned them against landlord .Therefore legal proceedings had to be initiated and landlord was dragged in lengthy and expensive litigation's. Accused no 3 also worked in tandem with accusedno 1 and 2 and in spite of being a neighbour and and an officer of court misrepresented facts and

promoted falsehood and worked as a aide and a facilitator of the crimescommitted by accused no 1 and 2 . The profession of accused no 3 is just only a shroud behind which an bad and defunct member of society resides whose conduct is unbecoming of his profession .In spite of knowing that the complainant and hisfamily are peaceful citizens the defendant made the statement both invernacular and written to police , public as well as to the court of law in spite of knowing that they are false,derogatory and bound to cause injury to virtually anyone against whom they are claimed.

10. It is submitted that accused no 2 threatened complainant who was running a business from shop to implicate him in false and frivolouscriminal cases if they were asked tovacate .The accused no 2 being a women started making rumors and false objectionable statements in the neighbourhood & caused affray and as a result of which the complainant and his father had to close their shop. The most prominentof the false allegations was 'inhonemeri beti ko girlfriend kaha' Due topersistent harassment and threats the complainant suffered nervous attack. Since then the complainant sensed danger and evil intentions ofthe accused therefore to avoid any unnecessary controversy he stopped coming to his shop and stopped attending his normal course of business causing a huge financial loss. After filing civil suit against tenant the complainant father opened up shop for the fear of being disposed from the property /third party.

11.Since the absence of personal visit of landlord's son prevented them from hurling any direct allegation , the accused no 1 himself fabricated some offensive & incriminating anonymous communication and spread that to thelocality thereby bringing their dishonest intentions into reality .The underlying motive and intentionwas just to implicate the

plaintiff(only child) so as to make him a leverage tool upon which they would defame the landlord and his family to grab the property of complainant father or to extort money thereby causing unjust gain tothemselves and unjust loss to the complainant and his family .The complaint application made by the accused no 1 addressed to the SHO PSadarsh nagar 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 misconceived and misappropriated along with false and vexatious contentions were submitted by the accused in that complaint to lawful authorities .In the complaint the accused states that he is a residentof this particular lane and localityfrom the past 10 years but in policeverification form DATED 26/03/2010 , he submits that his previous address was C-600,MAJLIS PARK GALI NO.13.Also in the civil suit the accused 1 on one hand side is alleging 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 .He also changed his wife name from vineeta to saroj without following the lawful procedures. Its quiet hilarious that a couple wants to stick to continue living with an adversary whereas they can take someother premises on rent somewhere else after all they are paying rent and nobody can remain amused and contented by paying money to continue to stick with a person whomhe considers as an adversary .This blow hot and blow cold statements are also an evidence of misrepresentation of facts .11. It is submitted that accused no 2 in tandem with accused no 1 and facilitated by accused no 3 startedmischief by damaging the property ,intimidation & restraining the landlord and also launched vicious attacks both in vernacular and physical against him . Exhibit No .is ......... legal notice to stop doing mischief & notice to vacate

.The landlords complaints against these acts are exhibit no

12.That since by looking at the previous conduct of accused persons i.e. deliberately disseminating false and fabricated information aided by the fabrication of forged Govt. identity documents , conduct of harassment and intimidation , conduct of disrespect shown to the court of law and conduct by the way of blackmailing to extort & garner some kind of unjust material gain and that of accused no.1 and 2 previous attempts to implicate the complainant and his family on the basis of fabricated evidence ,lame and flimsy excuses shows that all the accused have taken law for a ride without any respect for even the judiciary .

13. It is also imperative to mentionthat during civil litigation which was filed by the plaintiff father inthe court of ADJ Sh. Satish Kumar, all false pleas and frivolous contentions of the accused were dismissed by ADJ and the suit of complainant father was decreed in his favour on .24/04/2014 decree/order annexed .On date ......................the accused made a submission to vacate by 26/08/2014 not later than and thesubmission is PEx no...

14. The reason of attempt for falseimplication of complainant can be adjudged from the very fact that after aforesaid submission to the honourable court the accused no 1 and 2 started hectic and desperate attempts to bring a police action onthe complainant .At the instance of accused no 1 and 2 , the complainantwas summoned to the police station on 7/8/9/10/11 of July 2014.Even theaccused no 2 threatened police staffof extreme action if they don't accede to their demands because she is a lady . All this occurred at theinstance of accused no 3 because he being a lawyer and aware of new provisions of criminal amendment actwherein a conviction can be held on the oral testimony of a lady

complaining of certain acts. Even onaforesaid day 10/07/2014 the accused no 2 threatened to slap the complainant's mother even in front of SHO Sh praveen kumar ji of PS adarsh nagar. Having being failed intheir extortion bid and sensing the approaching deadline to vacate the house which they held illegally accused no 1 and 2 tempered and destroyed the seals of NDPL electricity meter installed within premises Exhibit no ..........It isimperative to mention that on 11/8/14 the accused no 2 gave a oralcomplaint which was reduced into written by ASI Sh.Raju Yadav ji.In that complaint accused no 2 apart from leveling/repeating same false allegations levied that she usually makes but also a new allegation of false & malicious allegations of tempering of meters allegedly by landlord who was even not residing there , thereafter 2-3 days the complainant father noticed change inthe shape of his electricity meter and it's box. As soon as the landlord realized this he informed NDPL PEx. Dated 23/07/2014This very conduct of accused no 2 leaves no doubt that it is the accused no 1 and 2 who destroyed property deliberately so that they can cause injury and loss to the landlord who was neither interested in extending their tenancy nor submitting to their unlawful demands. It is also submitted that at that time of this incident apart from accused no1 & 2 family no third person was residing in the demised premises.

15. The intention for 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 .At the time of clearing bills in the court he demands compromise .Ex no...... Therefore heis admitting to being a perpetrator to gain by committing certain acts by themselves by intending to implicate complainant so that some settlement in the name of compromisecan be arrived at.

Dishonesty negates all lawful acts and the dishonesty and evil intentions are evident from the veryfact that the accused no 1 gave fabricated identity documents to take possession of property from complainant's father & later on tried to implicate his son by himself fabricating some incriminatory evidence to harass eventually anyone & everyone who came in their way lawfully.

16. It is also submitted that the complainant through his counsel cameto know that accused no 1 and 2 had filed a criminal complaint case no.45/1/14 in the court of.ld. kapilkumar MM north west rohini Delhi in which accused no 3 is their lawyer against him u/s 156 3 and later changed that to u/s 200 CrPc and submitted that he is interested in prosecuting the complainant for non cognizable offence ( compoundable ).Mo rover the accused has failed to present even an iota of pre-summoning evidence against him in that criminal complaint .Also the complainant havereasons to believe that a criminal case if also filed against the former SHO adarsh nagar so as to cause fear in the mind of that officer.This shows that the accused no 2 with the aide and encouragement of accused no 1 and accused no 3 has the audacity to paint a sorry and grieving image on the canvas of imagination aided by the frequent media trials of crime against women particularly after NIRBHAYA incidentand all three accused joined hands just only to defraud and harass the authorities and complainant for someunjust gain. Through their conduct they have seriously undermined the value and importance of not only executive & judiciary but also womanhood as a whole. Mo rover it ispertinent to mention that even NIA during the investigation of bomb blasts has admitted and proved that desperate terrorists retort to the acts of keeping forged identities .Terrorists have no gender .Therefore also it is a matter which

concerns not just an individual(applicant) but it is alsoconcerned with national security .

17.The cause of action arose as on dated 02/03/2015, the accused no 1 again mischievously filled a false police complaint against the complainant . Since the complaint was false the police took the statement from the complainant and no action was taken against him .

18. The cause of action arises on ........ as the complainant comesto know about another offending and incriminatory communication made to the police in the name of his father(Baldev Raj) alleging falsehood for which his parents weresummoned by vigilance department at ashok vihar on dated.05/10/2015.It is pertinent to mention that in thiscommunique a reference is also made about HC (adarsh nagar) balkrishan malik because once when the accused no 2 on dated 13/07/2013 physically restrained the complainant father and locked him in , a call was made at 100 and persuant to that call it was balkrishan malik ji who rescued that SR.CTZN and admonished accused no.2.Ex no....... Therefore the accused no 1 and 2 fostered jealousyagainst Sh.balkrishan malik ji also and so as to cause some injury to him are themselves writing and posting the objectionable and false complaints against anyone and everyone who came in their way lawfully.

19. That the accused no 1 and 2 are continuing to harass the complainantand his family in one way or the another by provocation through anonymous communication and trying to cause affray.

20.It is most respectfully submittedthat any person who has the audacityto prepare forged government documents can also make false private evidences very easily to defraud and cheat innocent citizens and accused no 3 who in spite of being aware of the real situation isportraying something else on reel

and that is unbecoming the officer of the court .Mo rover all these offences are being perpetrated by accused no 1 and 2 at the instance of accused no 3 because only a legalmind is in the know of all these procedures whereby something incriminatory and tangible is deliberately fabricated and tenderedto police and the blame of which canbe smeared on the opposite party to take an edge .It cannot be denied that the act of posing themselves as a normal family in society is just only a shroud under which accused gain entry into the society to commit offences against unsuspecting citizens. It is submitted that such incidents happened only when the accused no 1 ,2 and 3 took up residence in his lane .Nothing of such thing ever happened earlier here though the complainant father is owing this property from 1984 and virtually each and every third person can vouch for their truthfulness and peaceful nature.

20.On enquiry the complainant comes to know that the voter id card whichwas shown in original to complainant's father and whose photocopy given by accused no 1 for police verification is issued in the name of a women(ANITA DEVI) fromthe state of rajasthan of which the accused no 1 and 2 are natives/ab origins .This is corroborated by PEx................Also it is very humbly submitted that according to the settled proposition of law a person using forged documents will be treated as if he himself has made/forged them .It is also humbly submitted that a person who has the audacity to prepare forged government records/documents can also make false private evidences very easily against unsuspecting citizens and as such this is happening in this case so as to implicate the complainant and to cause injury to him .It would be essential to bring to your notice ofthe fact that all this is occurring even in spite of the notification no U-

11036/i/2008 dated 09/09/2010 made by ministry of home affairs and declared by resp. ACP u/s 144 CrPc ,1973.(NO.2 of 1974).

21.Also accused no 2 managed to get signatures of complainant's father on a application for voter id and there also she has miss re-presentedher name as saroj. whereas in policeverification form which was filled by accused 1 in his own handwriting shows that her name is vineeta. Hence deception played on governmentauthorities by the accused no 2 .None but only a habitual cheater would tender multiple identities to government authorities to escape from the eyes of law enforcement for achieving their nefarious designs and ulterior motives. The acts of the accused are synonymous to those of the seasoned criminals.

22. These acts of accused are abhorrent in any civilized society and as a result of these acts complainant and his family had to spend numerous sleepless nights and their respect and reputation in the society has taken an irreversible toll . Mo over it is also submitted that the applicant & his family has suffered heavy monetary loss and also mental stress and agony .The accused are guilty with their intentand actions which are totally unethical ,immoral & unlawful and also such acts are prejudicial not just to one individual(complainant) but to the whole society. The complainant hereby requests for the kind attention of thyself so as to do the needful in view of accusedpersons having an evil eye on the property of the applicant. Mo rover not just against the complainant butthe accused had committed many other objectionable things to publicat large which you will get to know during investigation. Also the physical well being of the applicantis at risk.

Your’s faithfully &Jai Hind,

Ravi Bhateja .

28/45 Punjabi Bagh west

07/11/2015 New Delhi.-110026 Mobile : 9899293039

Attachments Enclosed :

== police verification receipt

== Forged document (voter card) of accused no.1 having S.No:RJ/04/027/036261 submitted to PS adarsh nagar along with police verification form.

==Details of S.No: RJ/04/027/036261 original voter id in original according to ECI.

cc: RESPECTED POLICE COMMISSIONER OF DELHI

bcc: REPECTED DCP DELHI NORTH WEST& ACP NORTH WEST.