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Here's the full text of the letter written by Dilip Kumar Pandey:

To,
Pankaj Gupta,
National Secretary, Member (Disciplinary Committee)
Aam Aadmi Party.
Subject: Complaint regarding anti-Party Activities by Yogendra Yadav, Prashant
Bhushan and Shanti Bhushan
Sir, I would like to share the details of complaint against persons mentioned in subject:
1. Before General Elections, 2014, Mr Vijay Raman, who was personal assistant of Mr
Yogendra Yadav and was handling his election campaign, phoned Mr Satya, an
important party member and told him that Mr. Yadav wanted to interview him for a role in
his core team. When Mr Satya went to meet Raman, the latter told him that Mr Arvind
Kejriwal didn't have the required political acumen and it was imperative for Mr Yogendra
Yadav to take over as National Convenor of AAP after removing Kejriwal from the post.
Mr Satya was shocked to hear this. He informed senior members of the party of how Mr
Yadav's office was conspiring against Kejriwal and hatching conspiracies to take over as
the party convenor.
2. After the Lok Sabha debacle, this conspiracy against Kejriwal picked up pace. A
series of events ensued that show that Mr. Prashant Bhushan, his father Shanti
Bhushan and Yogendra Yadav entered into a conspiracy to weaken the party from within
and then use this to challenge Kerjirwal's leadership and perch Yadav as national
convenor. During a meeting of National Policy Committee in the month of July, in which
party member Mr Ashish Khetan was also present, Mr Shanti Bhushan tried to draft
Khetan into their conspiracy. Shanti ji told Khetan that the best possible way to remove
Kejriwal was to have a BJP government in Delhi state which would mean Kejriwal would
become the leader of opposition. Shanti ji told Khetan that once Kejriwal becomes the
LOP, they should get together to press the principle of one man one post and make him
resign. The way Shanti ji explained the whole plan in the presence of his son Prashant
and Yadav, it was amply evident that all three were acting in concert towards a singular
aim of weakening the party and then replacing Kejriwal with Yadav as party head. This
again shows malicious intentions towards party and its future and the unbridled ambition
of Yadav to become national convenor.

3. Shanti Bhushan followed up this scheme with an email to Arvind Kejriwal, issuing
him an ultimatum to step down from Party else he would give press interviews wherein
he would malign and defame Kejriwal. This shows how the trio had little respect for the
party constitution, internal democracy and the party institutions like NE and PAC and the
NC.

4. Soon the trio facilitated the formation of an anti party forum called AVAM. There is
substantial proof to show that Shanti ji and Prashant gave legal and all other kinds of
assistance to AVAM to carry out activities against the AAP. Regular meetings between
AVAM members and the trio were held at Bhushans' residence. When party members
like Khetan pleaded with the Bhushans' to sop supporting AVAM, they were told by
Prashant that for him AVAM was like a trade union within the party and he saw nothing
wrong in aiding and assisting AVAM. He publicly embarrassed everyone while being
accountable to no one in the party or outside. Prashant & Shanti Bhushan supported
anti-party elements like AVAM. AVAM is the group that did everything to demolish and
defame the party. Besides the Bhushans' the other big force behind AVAM was the BJP.
5. There was a negative story published in The Hindu in last week of August, 2014.
The story was negative and was clearly meant to tarnish the image of Party and its
convenor Arvind Kejriwal. The story was not only factually incorrect it seemed motivated
by vested interests. When the journalist who did the story was confronted as to why the
facts were misrepresented, she said it could not be so as she was briefed by Mr
Yogendra Yadav himself. This whole conversation was recorded and is available as
evidence. This incident further substantiates the factum of the larger conspiracy to
weaken the party.
6. During candidate selection process for Delhi Election 2015, honesty and freedom
(entrusted by NE) of DECG was always questioned, doubted. All kinds of allegations
without substantive proof were levelled against the party processes and individuals in
charge of picking candidates by Yogendra Yadav and Prashant Bhushan. And despite
the agreement of majority of PAC and DECG on candidates selection procedure,
Prashant Bhushan at several occasions threatened to demolish the party by doing a
Press Conference. This kind of black mail culture and disrespect to majority views is
again an anti-party activity and is against spirit of democracy. It is pertinent to add that
complaints against 12 candidates became matter of public discourse after publication in

major journals and newspapers and this was done to damage the electoral prospects of
these candidates. One journal wrote about some winning MLAs that they were on
Prashant Bhushan's list of suspicious candidates. This has never been denied by Mr.
Prashant Bhushan.
7. Worst part was when, a few weeks before elections, Mr Prashant Bhushan said in
presence of a senior Party Leader and a Mission Vistar member that he would rather
want the party to loose the elections so that Kejriwal could be removed and a major
overhaul of the party could be carried out. Bhushan refused to campaign for the party
and also planted several anti-party stories at a time when the party was going through
its most severe crisis.
Kindly take appropriate action as soon as possible.
Thanking you.
Dilip K. Pandey.
Aam Aadmi Party - Delhi State.
Copy To: Ashutosh (Convenor, AAP Delhi State)

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