AURO  UNIVERSITY  5TH 

NATIONAL  MOOT  COURT 
COMPETITION 
 

 
 

FACTS
Indie Land is a South Asian nation sharing borders with Pochinki, Rozok, Mylta, Lipovka
and Georgopol. Compared to its neighbours, Indie Land has always had a diverse social and
religious background. The Indie Land Constitution provides for secularism as one of the
basic tenets of Indie land and consequently, Indie Land is home to several Gods, beliefs and
Godmen. Though the Constitution of Indie Land provides for equality amongst all genders,
one can see the lack of equality for women in the country where oppression of women has
become quiet usual and to rectify the same various laws of the country provides for
protection of women. One such legislation is the Indie Land Penal Code governing the laws
related to substantive criminal activities. Recently, the Penal Code has been severely
criticized by various sections of the country for being too gender-biased. On the contrary, the
country has witnessed a mass upsurge in terms of women rights and feminist agitations.
Several oppressed women have come out in open to discuss their experiences of harassment
and molestation.

The State of Gujraj, has recently emerged as a major investment hub and has been regarded
as one of the safest states for women in the country. Gujraj is home to several Godmen and
one of them is Baba Neem Hakim Param Sachha (Guruji). He is the biggest motivational
Godmen in the state. The cult leader at his ashram at Palan Road, Khoobsurat teaches his
disciples the art of living which includes performance of several activities for cleansing of
their soul. Guruji is famous for his motivational lectures nationwide and many of the
followers stay with him at the Ashram to learn the values of living a peaceful life by
cleansing their souls. One of the interesting aspect of Guruji’s teachings were that prayers
were conducted at any time. There was no specific time for prayers and devotees were
allowed to pray at any time of the day. Guruji even personally went to his disciples in their
cottages to effectively cleanse their soul. Many devotees have also had their marriages fixed
by Guruji and have also had their children named by Guruji.

On 24th April, 2016, a First Information Report (FIR) was filed by Kusum Krantiveer
Paramsachhe against Guruji at the Palan Police Station, Khoobsurat, 3 kms southwest to the
Ashram. Chargesheet no. 012/2017 charged Guruji with Section 326, 354, 354A, 376, 377
 

under the Indie Land Penal Code. Guruji was arrested the very next day (Annexure B) and
placed under judicial custody.

It was alleged by Kusum that in 2010, after being sent to the Ashram by her family she was
repetitively raped by Guruji. She alleged that she could not complain to any authorities or her
family members because she was afraid no one would believe her as her family members
were blind followers of Guruji. Kusum as per her statement (Statement of Witness Kusum)
made good friends with several stray dogs in the Ashram and her favourite being Indu whom
she would feed rotis as night. One night, when she was feeding Indu, Guruji asked Kusum to
go to her cottage. On her resistance, Guruji forced her and Indu started barking at Guruji. In a
fit of anger, Guruji took a wooden stick lying in vicinity and rammed it in the vagina of Indu
pulling out her intestines causing instant death. Guruji threatened Kusum that if she
attempted to complain or disclose the reality, he would do the same with her and her ordeals
at the hands of Guruji continued.

On 26th March 2013, Kusum’s marriage had been solemnized with Krantiveer, another
devout disciple of Guruji’s teachings, at the directions of Guruji, and in 2015 the couple was
blessed with a baby daughter who was named Mokshi by Guruji. On 21st April 2016, Kusum
and her daughter visited Guruji’s Ashram to celebrate his birthday and seeing Kusum without
her husband, Guruji again tried to molest Kusum but left the room soon as other followers
were hovering around her room. Distressed, when she returned home, she told everything to
her husband, who at first didn’t believe her, but after listening to her they decided to file an
FIR against Guruji.

The matter came before the Hon’ble District and Sessions Court of Khoobsurat. The trial
stage was completed with chief and cross examination of the prosecution and defense
witnesses (See statements) and is due for further arguments.

Laws of Indie Land is pari-materia to laws of India.

  

First Information (FIR)

Of a Cognizable Offence (Under Section 154 of the Criminal Procedure Code)

General diary reference entry number: - 2109/2016

FIR no: - 108/2016

Date:- 24/4/2016
Time:- 10:13 am
Police Station:- Palan Police Station
District:- Khoobsurat 

1. Personal details of the Complainant / Informant:

a) Name :- Mrs. Kusum Krantiveer Paramsachhe
b) Father's / Husband's Name:- w/o Krantiveer Sajjuram Paramsachhe and D/o Brijmohan Raghuram
Paramsachhe.
c) Address:- 10/B, Ghata Village, Khoobsurat,Gujraj, Indie Land.
d) Phone number & Fax:- 0261-9230156
e) Email: paramsachheK@gmail.com

2. Place of Occurrence: Param Sachha Ashram, Palan Road, Khoobsurat, Gujraj, Indie Land.

a) Distance from the police station: - 3km

b) Direction from the police station: - South-west

3. Date and Hour of Occurrence: from 14/2/2011 to 25/3/2013

4. Offence:
a) Nature of the offence (e.g. murder, theft, rape, etc.):- rape, sexual harassment, unnatural sexual
intercourse, grievous hurt, outraging modesty.
b) Section:- 326, 354, 354A, 376, 377, 428 of the Indie Land Penal Code.
c) Particulars of the property (in case one has got stolen): NA
  

5. Description of the accused: Guruji Neem Hakim Param Sachha, Cult Leader, Param Sachha Ashram,
Palan Road, Khoobsurat, Gujraj, Indie Land.

6. Details of witnesses (if any) : Complainant herself

7. Brief Facts of the case: -

I, Mrs Kusum Paramsachhe d/o Mr Brijmohan Paramsachhe and w/o Mr. Krantiveer Paramsachhe. Our marriage was
solemnised on 26th March 2013 at Param Sachha Ashram in Khoobsurat. My father is a follower of Guruji Neem
Hakim Paramsacha. My father sent me at the ashram on my 18th birthday which falls on 31st December 2010, he had
sent me to the ashram so that I could live and learn under the guidance of Guruji. Guruji fixed my marriage with
Krantiveer and a baby girl named Mokshi was born on 27th May 2015.

21st April 2016, I had gone to the ashram with my daughter to celebrate Guruji’s birthday. Krantiveer decided to not
attend this year’s celebrations and hence didn’t travel with us.
On 22nd April when I returned from Ashram, I was depressed and when Krantiveer enquired, I couldn’t stop crying.
While crying I told Krantiveer about the horrors that I had to face during my stay at ashram. I outpoured my agony in
front of Krantiveer relaying that “when I was living in Ashram I was repeatedly raped by Guruji in the pretext of
cleansing my aura. When Indu (my pet stray dog) tried to protect me one night, Guruji took a wooden stick rammed it
into her (Indu’s) vagina pulling her intestine out. I saw the dog lying in the pool of blood with her intestines poured
out but was unable to help and immediately Guruji threatened me that if I ever protested to his cleansing mantra he
will do the same to me and consequently till the time I was in the ashram, I was repeatedly raped by Guruji. Infact,
Guruji also raped me a day before our wedding but I was unable to protect myself. I also kept quiet for so long
because I knew no one would believe me. I am telling you all this now because when I went for his birthday
celebrations on 21st April 2016, he tried to molest me again.”
After hearing this my husband could not believe the words I spoke, he gave me courage to file an FIR against him as
he might have spoilt many lives in past and might do the same in future. Hence, I am filing this complaint. 

8. Reason for delay in reporting:- -----------

9. Inquest report:- NA

FIR read over to the complainant/informant, admitted to be correctly recorded and a copy given to
the complainant/informant, free of cost. 

Kusum
 

Kusum Krantiveer Paramsachhe

Name and Thumb impression/ signature of the Complainant  

Kabir Khan

Kabir Bashir Khan

Name and Signature of the Officer In-charge of the Police Station
Rank:- Sub- Inspector 

 
 

CHARGE SHEET
(U/s 173 Cr.P.C)

BEFORE THE HON’BLE SESSIONS COURT, AT KHOOBSURAT

FIR No.  108/2016

Final Report/Charge Sheet 012/2017

No. 

Date  30/01/2017

Sections   326, 354, 354A, 376, 377, 428 of the Indie Land Penal
Code. 

Type of Final Report  Charge-Sheet

If Charge Sheeted: Original

original/Supplementary:  

Name of the Investigation Kabir Bashir Khan

officer 

Name of the Complainant  Mrs. Kusum Krantiveer Paramsachhe, w/o Krantiveer

Sajjuram Paramsachhe and D/o Brijmohan Raghuram
Paramsachhe.
Residing at:- 10/B, Ghata Village, Khoobsurat,Gujraj,
Indie Land.
Phone number & Fax:- 0261-9230156 

Particulars of accused a) Name of the Accused: Neem Hakim Paramsachhe

person against whom b) Whether Verified: Yes
present charge sheet is being c) Father’s Name: Sadhuyogi
filed:  d) Year/ Date of birth: 21/08/ 1954
e) Sex: Male
f) Nationality: Indian
g) Religion: Hindu
h) Occupation: Cult Leader
i) Address (present): Param Sachha Ashram, Palan
 

Road, Khoobsurat, Gujraj, Indie Land.

j) Date of Arrest: 25/04/2016
k) Date of release on Bail: Not Applicable.
l) Under Acts and Sections (Of Charge sheet): As
mentioned under sl. No. 4.
m) Status of Accused: Judicial Custody

Particulars of witnesses As per Annexure

examined:  

Brief facts:-  An oral complaint was received from Mrs. Kusum on

24/08/2016, regarding rape, sexual harassment, unnatural
sexual intercourse, grievous hurt, killing of pet dog,
outraging modesty against cult leader Neem Hakim
Paramsachha Guruji. Accordingly, the accused was
arrested and statements of the witnesses mentioned in the
annexure was taken. 

It is therefore, prayed that in the light of the averments herein, documents and materials filed with this
police report u/s 173 Cr.PC. this Hon’ble Court may kindly take cognizance of this offence.

Seal of the Court: Deemed to be affixed Signature of the Magistrate: Sd/-

ANNEXURE A- LIST OF WITNESS

a) Kusum Krantiveer Paramsachhe – Witness

b) Karntiveer Sajjuram Paramsachhe – Witness

c) Sajjuram Paramsachhe – Witness

d) Brijmohan Paramsachhe – Witness

e) Suhagwati Paramsachhe – Witness

 

f) Ramgopal Varma – Panch

g) Pankaj Ahuja – Panch

h) Roopali Dheya – Witness

i) Sunidhi Singh – Witness

j) Swati Trivedi – Witness

k) Dr. Arshi Vala – Expert Witness

l) Dr. Sanjay Chaudhri – Expert Witness

m) Kamlesh Kalra – Panch

n) Sajjuram Paramsachhe – Panch

o) Madhuri Rane – Panch

p) Inzimam Patel – Witness

q) Sunita Rajdev – Witness

 
 

ANNEXURE B- MEMORANDUM OF ARREST (under Section 41-

B of the Cr. PC)
1. Name of the person arrested [With father’s name]:- Guruji Neem Hakim Param Sachha

2. Sex: - Male

3. Age: - 62

4. Residential address: - Param Sachha Ashram, Khoobsurat

5. Name of relative / friend whom the person taken in custody intends to inform: Ranhgav Singh
Paramsachha

6. Date and time of arrest: - 25/4/2016 at 12:00 pm

7. Place of arrest: - Param Sachha Ashram

8. Notification of date and time of arrest and information about place of detention to the friend /
relative: - NA

9. Case reference with section of law: - 326, 354, 354A, 376, 377, 428 of the Indie Land Penal
Code.

10. G.D. Entry No. at the place of detention disclosing the name of next friend of arrestee
informed of the arrest and the particulars of the police official in whose custody the arrestee
is:- 1132/16

11. Name of the PS / Interrogation centre / place of detention:- Palan Police Station

12. Name of designation of the officer apprehending the suspect and taking the suspect in police
custody:- Kabir Khan

13. Registration no. of vehicle [if issued during arrest]:- NA

14. Form / Court where to be produced:- 2nd JMFC, Virle Point, Khoobsurat.

15. Date & time of production in the court:- 26/4/2016 at 11:00 am

16. Signature of the witness [Either a family member or a respectable local man]:-

a) Ram Gopal Varma:- Rvrma

b) Pankaj Ahuja:- Pankaj

17. Counter signature of the arrestee Certified that the person arrested has been Informed of this
right to have someone informed of his arrest or detention: -
 

Kabir Khan
Signature of the Memo issuing Officer (Range Officer)

With date & designation.

Copy forwarded to 2nd Judicial Magistrate First Class, District and Sessions Court, Khoobsurat for
favour of information.

 
 

Examination before the Court

Examination in chief on 13/7/2017

Ram Gopal Varma – Pw 7, Exhibit 36

Pw 8 Pankaj Ahuja – Pw 8, Exhibit 37

Examination of the witnesses Ram Gopal Varama and Pankaj Ahuja via exhibit 36 and 37
respectively. They stated that arrest was made in their presence.

Cross examination 13/7/2017

No cross examination.  
 

STATEMENTS OF THE WITNESS  

Statement as per Charge‐ Sheet 
Kusum Krantiveer Paramsachhe

Age: 26 Sex: Female Occupation: Housewife

Address: 10/B, Ghata Village, Khoobsurat, Gujraj, Indie Land

I am Kusum Paramsachhe daughter of Mr. Brijmohan Paramsachhe and wife of Mr. Krantiveer
Paramsachhe. My father Mr. Brijmohan Paramsachhe has been the follower of Guruji Neem Hakim
ParamSacha from past many years. I was sent to the Param Sacha Ashram in Khoobsurat when I
turned 18 so that I could learn values imparted by Guruji. Before being sent to the Ashram in 2010, I
had visited the Ashram a number of times to pay my homage to Guruji along with my parents. When I
was sent to live there in Ashram, I was given a small cottage room. The room was near the prayer hall
where all of us had to gather every morning and evening to pray to achieve the Param Sacha Gyan as
guided by our Guruji. There were few stray dogs near the Ashram and I used to feed and play a bit
with one of the dogs whom I had named fondly as Indu. Indu would regularly wait for me near my
cottage room so that I could feed her rotis.

Initially, my routine in the Ashram was to pray in the morning, help in the kitchen in the afternoon
and study the books provided by Guruji rest of the day. There were few more girls like me staying in
the Ashram full time and everyday there would be few new followers who’d come to stay for a few
days at the Ashram.

After staying in Ashram for three months, one evening Guruji asked me to meet him in his meditation
room. When I went there, I saw that I was alone with Guruji. Guruji asked me to fetch an assan for
myself and I sat near Guruji’s feet. Guruji said that he had been watching me from past three months
and he feels that my aura needed cleansing as I wasn’t able to receive all the positivity from his
teachings. He felt that this was due to some bad karma of mine in my previous life. This disturbed me
greatly and I asked him what I would have to do for cleansing my aura where-in he said that he will
come to my room the next night and discuss the same with me.

The next night he came to my room and sat on my bed where-in he proceeded to tell me that to
cleanse my previous life’s bad karma he will have to specifically perform an mantra. I was unclear as
to what he meant by that but he continued saying that it would be repeated till the time I am not
absolutely clear of every bad karma. When I enquired what exactly was this mantra he kissed me on
my forehead and fondled my breasts and said I would know that very soon. I did get uncomfortable
 

by his touch but because I did believe in him I did not protest. He then left my room saying that he
shall return tomorrow with all the necessities to perform the mantra.

From the very next night, he repeatedly raped me in pretext of cleansing my bad karma. In the
beginning he came to my room every night but after four months he started coming to me once a
week and later on he would come to my room once every month.

One night, while Guruji was forcing me to go in my room, Indu who was standing near my cottage
and started barking at Guruji and was going to attack him when Guruji took a wooden stick lying on
the road and rammed that stick inside Indu’s Vagina and pulled her intestines out. I shouted and
started crying when I saw Indu lying in pool of her blood with her intestines out. After this Guruji
barked at me saying that if I ever protest against his Mantra again and if I ever complained he will
proceed to do the same with me.

This threat and the knowledge that no would believe me kept me quiet of the ordeal that I had face in
that Ashram on a regular basis.

In Feb 2013, Guruji informed my parents that he had found an ideal match for me and then on 15th
Feb I meet my would-be husband Krantiveer. We were engaged and our marriage was solemnised in
the Ashram on 26th March 2013 in front of Guruji. Guruji blessed us and I left the Ashram to live
with my husband.

As Krantiveer’s family was also a believer of Guruji, I did not tell him of my ordeal just after our
marriage. To not raise any questions, I would regularly go with my family to pay homage to Guruji.

In 2016, I had to go to Ashram alone with my daughter Mokshi on 21st April to celebrate Guruji’s
birthday. There seeing me without my husband, Guruji came to my room at night and tried to molest
me again but because few of his followers were hovering around my room, he left my room.

When I returned back home, I could not stop crying and told Krantiveer everything. Krantiveer then
decided that we should make a police complaint against Guruji and hence I along-with Krantiveer
came to the police office to file a complaint against Guruji.

Date:- 25/4/2016

Place:- Khoobsurat

Kusum

Kabhir khan

Pw 1- Exhibit 21
 

Examination in chief on 2/2/2017 
The prosecutrix is examined as PW1. She in her statement before the court stated that “I had visited
the Ashram a number of times to pay my homage to Guruji along with my parents. When I was
sent to live there in Ashram, I was given a small cottage room. The room was near the prayer hall
where all of us had to gather every morning and evening to pray to achieve the Param Sacha Gyan
as guided by our Guruji. There were few stray dogs near the Ashram and I used to feed and play a
bit with one of the dogs whom I had named fondly as Indu. Indu would regularly wait for me near
my cottage room so that I could feed her rotis. After staying in Ashram for three months, one
evening Guruji asked me to meet him in his meditation room. When I went there, I saw that I was
alone with Guruji. Guruji asked me to fetch an assan for myself and I sat near Guruji’s feet.
Guruji said that he had been watching me from past three months and he feels that my aura
needed cleansing as I wasn’t able to receive all the positivity from his teachings. He felt that this
was due to some bad karma of mine in my previous life. This disturbed me greatly and I asked him
what I would have to do for cleansing my aura where-in he said that he will come to my room the
next night and discuss the same with me.

The next night he came to my room and sat on my bed where-in he proceeded to tell me that to
cleanse my previous life’s bad karma he will have to specifically perform an mantra. I was unclear
as to what he meant by that but he continued saying that it would be repeated till the time I am not
absolutely clear of every bad karma. When I enquired what exactly was this mantra he kissed me
on my forehead and fondled my breasts and said I would know that very soon. I did uncomfortable
by his touch but because I did believe in him I did not protest. He then left my room saying that he
shall return tomorrow with all the necessities to perform the mantra.

From the very next night, he repeatedly raped me in pretext of cleansing my bad karma. In the
beginning he came to my room every night but after four months he started coming to me once a
week and later on he would come to my room once every month.

One night, while Guruji was forcing me to go in my room Indu who was standing near my cottage
and started barking at Guruji and was going to attack him when Guruji took a wooden stick lying
on the road and rammed that stick inside Indu’s Vagina and pulled her intestines out. I shouted
and started crying when I saw Indu lying in pool of her blood with her intestines out. After this
Guruji barked at me saying that if I ever protest against his Mantra again and if I ever complained
he will proceed to do the same with me.

This threat and the knowledge that no would believe me kept me quiet of the ordeal that I had face
in that Ashram on a regular basis.
 

In Feb 2013, Guruji informed my parents that he had found an ideal match for me and then on
15th Feb I meet my would-be husband Krantiveer. We were engaged and our marriage was
solemnised in the Ashram on 26th March 2013 in front of Guruji. Guruji blessed us and I left the
Ashram to live with my husband.

As Krantiveer’s family was also a believer of Guruji, I did not tell him of my ordeal just after our
marriage. To not raise any questions, I would regularly go with my family to pay homage to Guruji.

In 2016, I had to go to Ashram alone with my daughter Mokshi on 21st April to celebrate Guruji’s
birthday. There seeing me without my husband, Guruji came to my room at night and tried to
molest me again but because few of his followers were waling towards my room, he left my room.

When I returned back home, I could not stop crying and told Krantiveer everything. Krantiveer
then decided that we should make a police complaint against Guruji and hence I along-with
Krantiveer came to the police office to file a complaint against Guruji.”

Cross examination on 2/3/2017: ‐ 
“Every girl in our family has to go to Guruji’s Ashram before their marriage, so I was also sent
there. My maternal sisters Roopali and Sunidhi had also gone to stay there. They are now married
and living with their in-laws. I did not discuss this with them. I had also not discussed this with my
parents. Since, my in-laws are also devotees of Guruji I kept on going to the ashram I have no
reason for not discussing this with them before. I have discussed this with my husband because
Guruji attempted to Rape me again. I don’t know what happened to indu after that, I have never
seen her body but she was my beloved pet and I miss her. The FIR is delayed because we were
having discussion in my family. Initially my family was hesitant but later they agreed. This is true
that my husband even confronted Guruji on 22/4/18, where Guruji denied all charges. This is not
true that I have filed a wrong complaint on the basis of fabricated evidences.”

 
 

Statement as per Chargesheet 
Krantiveer Sajjuram Paramsacche

Age: 27 Sex: Male Occupation: Business Man

Address: 10/B, Ghata Village, Khoobsurat, Gujraj, Indie Land

I am Krantiveer Paramsaccche son of Mr. Sajjuram Paramsacche. I am married to Kusum

Paramsacche. Our marriage was solemnised on 26th March 2013 in the Param Sacha Ashram with the
blessings of Guruji Neem Hakim Param Sacha. My father and me have been the follower of Guruji
from past many years. I always believed in his teachings and that all of us have to strive to reach
Param Sacha. I agreed to marry Kusum because Guruji believed that we would be an ideal match. I
have visited the Ashram many times but I always stayed only for a day or two there. I had never met
Kusum personally but had seen her in the Ashram a couple of times when I visited Guruji. Guruji
always guided me in all my endeavours. In 2016 due to certain issues in my business, I was unable to
go to the Ashram along-with Kusum and Mokshi to celebrate Guruji’s birthday. When Kusum
returned from Ashram the next day she seemed very depressed and when I enquired her about the
same, she started crying. I was alarmed and asked her what the matter was and then Kusum told me
about the ordeal that she had to face in the Ashram for so many years. At first I couldn’t believe but
when I repeatedly asked Kusum to be sure of the allegations that she was making against Guruji but
Kusum relentlessly told me of various instances that took place. Finally, I believed that she was
saying the truth and I was absolutely furious that Guruji could commit such crimes. I took the
decision that we should make a police complaint so that Guruji pays for his crime.

Date: 25/4/2016

Place:- Khoobsurat

Kabir khan

PW 2- Exhibit 22

Examination in Chief on 3/32017 
“We have been the follower of Guruji from past many years. I always believed in his teachings and
that all of us have to strive to reach Param Sacha. I agreed to marry Kusum because Guruji
believed that we would be an ideal match. I have visited the Ashram many times but I always stayed
only for a day or two there. I had never met Kusum personally but had seen her in the Ashram a
couple of times when I visited Guruji. Guruji always guided me in all my endeavours. In 2016 due
to certain issues in my business, I was unable to go to the Ashram along-with Kusum and Mokshi
to celebrate Guruji’s birthday. When Kusum returned from Ashram the next day she seemed very
 

depressed and when I enquired her about the same, she started crying. I was alarmed and asked
her what the matter was and then Kusum told me about the ordeal that she had to face in the
Ashram for so many years. At first I couldn’t believe but when I repeatedly asked Kusum to be sure
of the allegations that she was making against Guruji but Kusum relentlessly told me of various
instances that took place. Finally, I believed that she was saying the truth and I was absolutely
furious that Guruji could commit such crimes. I took the decision that we should make a police
complaint so that Guruji pays for his crime.”

Cross Examination on 3/3/2017 
“it is true that I don’t have any first-hand information about the incident, it is through kusum that
I came to know about it. If I had known earlier, we would have file the FIR earlier. It is true that
Guruji fixed our marriage at our marriage solemnized in the ashram and my wife looked happy
after marrying me. Yes, after I came to know about this I was very angry and went to confront
Guruji.”

Statement as per the Charge sheet 
Sajjuram Ram Paramsacche

Age: 52 Sex: Male Occupation: Business Man

Address: 10/B Ghata Village, Khoobsurat, Gujraj, Indie Land

I am Sajjuram Paramsachhe son of Mr. Govind Ram. Krantiveer Paramsacche is my son and Kusum
Paramsacche is my daughter-in-law. I started following Guruji Neem Hakim Param Sachha after I
accidentally attended one of his pravachans. I was deeply affected and moved by his teachings and
believed in the miracles that he could perform and hence became his ardent follower. I took Guruji’s
blessings for all my future endeavors and made my family follow him. My wife and children also
followed Guruji. Krantiveer always sought Guruji’s blessings and even agreed to marry Kusum
because Guruji believed that she would be an ideal match for her. I had no knowledge that Guruji had
assaulted Kusum. My wife never complained about Guruji’s behaviour and I personally never felt any
wrong vibes from Guruji. Krantiveer informed me about the Kusum’s ordeal and that they have filed
a FIR against Guruji. I was deeply shocked and could not believe that the man we trusted so much
turned out to be an abuser. I was going to send my younger daughter to Guruji’s ashram to reside but
now I have decided to never visit his ashram or follow him or send my daughter to his ashram.

Date:- 25/4/2016

Place:- Khoobsurat
 

Kabhir khan

PW-3 Exhibit 23

Examination in chief on 3/3/2017 
I am Sajjuram Paramsachhe son of Mr. Govind Ram. Krantiveer Paramsacche is my son and
Kusum Paramsacche is my daughter-in-law. I started following Guruji Neem Hakim Param
Sachha after I accidentally attended one of his pravachans. I was deeply affected and moved by his
teachings and believed in the miracles that he could perform and hence became his ardent
follower. I took Guruji’s blessings for all my future endeavours and made my family follow him.
My wife and children also followed Guruji. Krantiveer always sought Guruji’s blessings and even
agreed to marry Kusum because Guruji believed that she would be an ideal match for her. I had no
knowledge that Guruji had assaulted Kusum. My wife never complained about Guruji’s behaviour
and I personally never felt any wrong vibes from Guruji. Krantiveer informed me about the
Kusum’s ordeal and that they have filed a FIR against Guruji. I was deeply shocked and could not
believe that the man we trusted so much turned out to be an abuser. I was going to send my
younger daughter to Guruji’s ashram to reside but now I have decided to never visit his ashram or
follow him or send my daughter to his ashram.

Cross examination on 3/3/2017 
I agree that I don’t have first-hand information about the incident. My wife had also been to
ashran and stays there for month during Shravan maas. I would not send my wife if she ever
complaint about the same. He has never touched my daughter inappropriately.

 
 

Statement as per Chargesheet 
Brijmohan Raghuram Paramsacche

Age: 51 Sex: Male Occupation: Business Man

Address: 105, Block C, Ghatpore, Khoobsurat, Gujraj, Indie Land

I am Brijmohan Paramsacche son of Mr. Raghuram. Kusum Paramsacche is my daughter and

Krantiveer Paramsacche is my son-in-law. I became aware about Guruji Neem Hakim Param Sacha
from my maternal uncle who was a follower of Guruji and credited Guruji with the sudden gains in
his life. I went to one of Guruji’s pravachans and his words and his aura gave me such peace that even
I started following him and regularly went to his ashram and sought Guruji’s blessings. My family
also became Guruji’s follower. I have only one daughter Kusum. Roopali and Sunidhi are Kusum’s
maternal sisters and they used to live with us as our own daughters. All the three were sent to Guruji’s
ashram when they turned 18 to live there for few years to learn from Guruji. None of them ever
complained about Guruji’s behaviour to me. I had no knowledge that Guruji had abused my daughter
Kusum. Kusum informed me about the FIR that she had filed against Guruji and I was astonished to
find that Kusum had kept quiet for so long and never confided with me or her mother. I used to notice
that Kusum had become very withdrawn when she used to live in ashram but because she never told
me anything I dismissed it with changes in a person at certain age. She used to be very sad when she
had to return to ashram but I thought that was because of her leaving home. If I knew at that time
about the Guruji’s actions, I would never have sent my daughters to his ashram.

Date:- 24/4/2016

Place:- Khoobsurat

Kabir khan

PW-4, Exhibit 24

Examination in chief on 3/3/2017 
I am Brijmohan Paramsacche son of Mr. Kesri Lal. Kusum Paramsacche is my daughter and
Krantiveer Paramsacche is my son-in-law. I became aware about Guruji Neem Hakim Param
Sacha from my maternal uncle who was a follower of Guruji and credited Guruji with the sudden
gains in his life. I went to one of Guruji’s pravachans and his words and his aura gave me such
peace that even I started following him and regularly went to his ashram and sought Guruji’s
blessings. My family also became Guruji’s follower. I have only one daughter Kusum. Roopali and
Sunidhi are Kusum’s maternal sisters and they used to live with us as our own daughters. All the
three were sent to Guruji’s ashram when they turned 18 to live there for few years to learn from
 

Guruji. None of them ever complained about Guruji’s behaviour to me. I had no knowledge that
Guruji had abused my daughter Kusum. Kusum informed me about the FIR that she had filed
against Guruji and I was astonished to find that Kusum had kept quiet for so long and never
confided with me or her mother. I used to notice that Kusum had become very withdrawn when she
used to live in ashram but because she never told me anything I dismissed it with changes in a
person at certain age. She used to be very sad when she had to return to ashram but I thought that
was because of her leaving home. If I knew at that time about the Guruji’s actions, I would never
have sent my daughters to his ashram.

Cross examination on 3/3/2017 
Any father would get angry if he comes to know about such incident, I was shocked and angry
when I came to know about it. I wanted to kill him. I did not go with Krantiveer to confront Guruji.
I was informed about the incident on 21/4/2018. I have no explanation for delay in FIR. I agree
that we had meeting with other members of the cult regarding FIR. This is not true that the delay
in FIR is because we were involved in the meetings for compromise.

Statement as per Charge sheet 
Suhagwati Brijmohan Paramsacche

Age: 58 Sex: Female Occupation: House Wife

Address: 105, Block C, Ghatpore, Khoobsurat, Gujraj, Indie Land

I am Suhagwati Paramsachhe wife of Brijmohan Paramsacche and mother of Kusum Paramsacche.

My husband started following Guruji Neem Hakim Param Sacha and listening to him even I started
following Guruji. I have one daughter Kusum. Roopali and Sunidhi are my brother’s daughters and
they used to live with us as our daughters. We made our children also follow Guruji and when Guruji
informed us that he would be happy to teach our girls and that we can our daughters to his ashram we
sent all our daughters to the ashram when they turned 18. They stayed in ashram for a couple of years.
None of my girls even complained to me about Guruji’s behaviour and I had no knowledge that
Guruji had abused my daughter Kusum. Kusum used to be very depressed in those days but I
reasoned that she must be feeling homesick when she lived there. I only got aware of Kusum’s ordeal
when Kusum informed me that she had filed a FIR against Guruji. If I had any knowledge about these
incidents, I would never have let my daughter stay in his ashram.

Date:- 25/4/2016
 

Place:- Khoobsurat

Kabir khan

Pw 5, exhibit- 25

Examination in Chief on 3/3/2017 
I am Suhagwati Paramsachhe wife of Brijmohan Paramsacche and mother of Kusum
Paramsacche. My husband started following Guruji Neem Hakim Param Sacha and listening to
him even I started following Guruji. I have one daughter Kusum. Roopali and Sunidhi are my
brother’s daughters and they used to live with us as our daughters. We made our children also
follow Guruji and when Guruji informed us that he would be happy to teach our girls and that we
can our daughters to his ashram we sent all our daughters to the ashram when they turned 18.
They stayed in ashram for a couple of years. None of my girls even complained to me about
Guruji’s behaviour and I had no knowledge that Guruji had abused my daughter Kusum. Kusum
used to be very depressed in those days but I reasoned that she must be feeling homesick when she
lived there. I only got aware of Kusum’s ordeal when Kusum informed me that she had filed a FIR
against Guruji. If I had any knowledge about these incidents, I would never have let my daughter
stay in his ashram.

Cross examination on 3/3/2017 
This is true that if this had happened to me, I would not let my daughter go there. I have seen girls going 
to Gurji’s Ekantgruh at 4 in the morning. I was never called by him, neither my daughters ever shared 
anything with me. 

 
 

Statement as per the Chargesheet 
Roopali Sanjay Dheya

Age: 27 Sex: Female Occupation: House Wife

Residing at :-501, Roopam Appartment, Sardoli Chowk, Sardoli, Indie Land

I am Roopali Dheya, married to Sanjay Dheya. Kusum Paramsacche is my aunt’s daughter. My uncle
and aunt follow Guruji Neem Hakim Param Sacha and they made me also follow Guruji. In year 2007
when I turned 18, my uncle and aunt sent me to Guruji’s ashram to learn from Guruji. Initially
everything was very smooth and I felt at peace with myself at the ashram but after staying there for
six months, Guruji started raping me. I was raped for a couple of months by Guruji. When I turned 19,
my uncle found a match for me and I got married to Sanjay. I never complained about this to anyone.
I never told about these incidents to my uncle or aunt or my sisters. I did not even tell Sanjay about
this because I felt that this could break my marriage and I did not want my past to affect my present or
my future. I stopped going to ashram after my marriage but when I came to know that similar
incidents have happened with my sisters, I took the decision to tell the truth. Guruji would come to
my room at night to rape me and because everyone in my family followed Guruji, I never complained
against him to my family members.

Date:- 30/4/2016

Place:- Sardoli

Kabir khan

PW-6, Exhibit 32

Examination in Chief on 11/4/2017 
I am Roopali Dheya, married to Sanjay Dheya. Kusum Paramsacche is my aunt’s daughter. My
uncle and aunt follow Guruji Neem Hakim Param Sacha and they made me also follow Guruji. In
year 2007 when I turned 18, my uncle and aunt sent me to Guruji’s ashram to learn from Guruji.
Initially everything was very smooth and I felt at peace with myself at the ashram but after staying
there for six months, Guruji started raping me. I was raped for a couple of months by Guruji.
When I turned 19, my uncle found a match for me and I got married to Sanjay. I never complained
about this to anyone. I never told about these incidents to my uncle or aunt or my sisters. I did not
even tell Sanjay about this because I felt that this could break my marriage and I did not want my
past to affect my present or my future. I stopped going to ashram after my marriage but when I
came to know that similar incidents have happened with my sisters, I took the decision to tell the
 

truth. Guruji would come to my room at night to rape me and because everyone in my family
followed Guruji, I never complained against him to my family members

Cross Examination on 11/4/2017 
This is true that I have disclosed this only after Kusum has filed the complaint and I’m disclosing
this because my family has supported me. I never complained about this to anyone because I feared
that no one will ever believe me. I was unmarried then, therefore I was afraid that this fact could
ruin my life. Today I have no fear and I want to take revenge from him for his ill treatment.

7. Sunidhi Karan Singh

Age: 26 Sex: Female Occupation: House Wife

Address: Bungalow No 5, Prestige township, Maman, Indie Land

I am Sunidhi Singh, married to Karan Singh. Kusum Paramsacche is my aunt’s daughter. I was a
follower of Guruji Neem Hakim Param Sacha until I got married. In the year 2008, after my sister
Roopali’s marriage my uncle and aunt sent me to Guruji’s ashram to live and learn from him. I was
given the responsibility to handle out-station reach of ashram. Guruji never made any advancement in
the initial months but one day I was summoned to his room where I saw that I was to be alone with
Guruji. Guruji informed me that this session would help me attain greater peace. Then Guruji tried
assaulting me but I hit him with a plate which was kept nearby and ran to my room. Two days later I
was asked to go back home and was informed that my learning process was over. I left the ashram but
never told about this one incident to my family members as I thought that no good would come out of
it and that I had saved myself. I had no knowledge that Guruji had raped my sisters. When Kusum
filed the FIR, I was shocked that Guruji assaulted other women in his ashram. If I knew this was
happening with other women and particularly my own sisters, I would have complained about it to at
least my family.

Date:- 4/05/2016

Place:- Mmaman

Kabir khan

PW-9, Exhibit 40

Examination in Chief on 14/7/2017

 

I am Sunidhi Singh, married to Karan Singh. Kusum Paramsacche is my aunt’s daughter. I was a
follower of Guruji Neem Hakim Param Sacha until I got married. In the year 2008, after my sister
Roopali’s marriage my uncle and aunt sent me to Guruji’s ashram to live and learn from him. I
was given the responsibility to handle out-station reach of ashram. Guruji never made any
advancement in the initial months but one day I was summoned to his room where I saw that I was
to be alone with Guruji. Guruji informed me that this session would help me attain greater peace.
Then Guruji tried assaulting me but I hit him with a plate which was kept nearby and ran to my
room. Two days later I was asked to go back home and was informed that my learning process was
over. I left the ashram but never told about this one incident to my family members as I thought
that no good would come out of it and that I had saved myself. I had no knowledge that Guruji had
raped my sisters. When Kusum filed the FIR, I was shocked that Guruji assaulted other women in
his ashram. If I knew this was happening with other women and particularly my own sisters, I
would have complained about it to at least my family.

Cross Examination on 14/7/2017

I agree that our marriage is a love marriage but I did not tell me husband about it. This is not true
that I don’t trust my husband but the incident was not that grave to report. This is true that I have
disclosed this only after Kusum has filed the complaint.

8. Swati Trivedi

Age: 30 Sex: Female Occupation: Warden at Param Sacha Ashram

Address: Param Sachha Ashram, Palan Road, Khoobsurat, Gujraj, Indie Land.

I am Swati Trivedi and I have been the warden of women’s quarters in Param Sacha Ashram from
past seven years. I was made the warden when I was 23 years old. Not a single resident of ashram had
ever complained about any assault to me. In fact many women claimed that the ashram’s environment
provide them with utmost peace and that they have never felt this peaceful in their entire lives. I have
seen Guruji entering different rooms at different occasions but because no girl ever raised any alarm I
thought that Guruji must be helping them with their prayers. I have also seen many girls returning late
at night from Guruji’s quarters but have always presumed that these were prayer sessions with Guruji.
Kusum never complained to me about any of the instances. Infact when she was in ashram she was
one of the most ideal residents who never created any kind of problems. She was always on time for
her duties and always completed her tasks within the allotted time. When Kusum and Krantiveer were
 

married, I was very happy for their bright future. The FIR was a shock for me as Kusum never, not
even once complained to me about the assaults.

Date:- 5/05/2016

Place:- Khoobsurat

Kabir khan

PW-10, Exhibit 42

Examination in Chief on 14/7/2017

I am Swati Trivedi and I have been the warden of women’s quarters in Param Sacha Ashram from
past seven years. I was made the warden when I was 23 years old. Not a single resident of ashram
had ever complained about any assault to me. In fact many women claimed that the ashram’s
environment provide them with utmost peace and that they have never felt this peaceful in their
entire lives. I have seen Guruji entering different rooms at different occasions but because no girl
ever raised any alarm I thought that Guruji must be helping them with their prayers. I have also
seen many girls returning late at night from Guruji’s quarters but have always presumed that these
were prayer sessions with Guruji. Kusum never complained to me about any of the instances.
Infact when she was in ashram she was one of the most ideal residents who never created any kind
of problems. She was always on time for her duties and always completed her tasks within the
allotted time. When Kusum and Krantiveer were married, I was very happy for their bright future.
The FIR was a shock for me as Kusum never, not even once complained to me about the assaults.

Cross Examination on 14/7/2017

I agree that I have never seen anyone in the compromising position. Kusum looked happy in the
ashram. I never thought she could file a complaint.

Mr. Inzimam Patel

Age: 30 Sex: Male Occupation: Business Man

Address: House No 15, Lalbazar Colony, Palan Road, Khoobsurat, Gujraj, Indie Land

I am a resident of House No. 15, Lal Bazar Colony, Palan, khoobsurat. I had shifted to this place on
11th January 2012. My house shares a common wall with that of Guruji’s Ashram. On the evening of
12th January 2012, I was standing in my lawn watching my children playing cricket. I suddenly heard
some loud voices coming from the other side of the wall and went to stand closer to the same. I
realised that it was Guruji talking loudly to some of his sevak about girls that come to his ashram. He
 

said he has not found any good girl in the ashram from many days, he also told him to get girls below
16 as he enjoys spending time with young girls. I was shocked seeing this. I have also seen him going
to girls’ cottage during odd hours and cries of girls are very frequent at nights.

Date:- 5/5/2016

Place:- Khoobsurat

Kabir khan

PW-11, Exhibit 45

Examination in Chief on 25/7/2017

I am a resident of House No. 15, Lal Bazar Colony, Palan, khoobsurat. I had shifted to this place
on 11th January 2012. My house shares a common wall with that of Guruji’s Ashram. On the
evening of 12th January 2012, I was standing in my lawn watching my children playing cricket. I
suddenly heard some loud voices coming from the other side of the wall and went to stand closer to
the same. I realized that it was Guruji talking loudly to some of his sevak about girls that come to
his ashram. He said he has not found any good girl in the ashram from many days, he also told
him to get girls below 16 as he enjoys spending time with young girls. I was shocked seeing this. I
have also seen him going to girls’ cottage during odd hours and cries of girls are very frequent at
nights.

Cross Examination on 25//2017

I agree that I have never seen anyone molesting the girls. I cannot identify Guruji’s voice as I have
never talked with him. I have only overheard two people talking.

Mrs Sunita Rajdev

Age: 40 Sex: Female Occupation: Gym Instructor

Address: House No. 10, LalBazar Colony, Palan, Khoobsurat, Gujraj, Indie Land

I am a resident of House No. 10, Lal Bazar Colony, Palan, khoobsurat. I had shifted to this place on
2008. My house shares a common wall with that of Guruji’s Ashram. I am atheist and have no belief
in god or godman thus never visited his ashram., but have seen many people visiting him every day.
Girls are often seen spending months at the ashram, doing guruji’s seva. I have never interacted with
any of the followers of Guruji but I feel that the place is a hub of many criminal activities.
 

Date:- 5/5/2016

Place:- Khoobsurat

Kabir khan

PW-12, Exhibit-46

Examination in Chief on 25/7/2017

I am a resident of House No. 10, Lal Bazar Colony, Palan, khoobsurat. I had shifted to this place
on 2008. My house shares a common wall with that of Guruji’s Ashram. I am atheist and have no
belief in god or godman thus never visited his ashram., but have seen many people visiting him
every day. Girls are often seen spending months at the ashram, doing guruji’s seva. I have never
interacted with any of the followers of Guruji but I feel that the place is a hub of many criminal
activities.

Cross Examination on 25/7/2017

It is only my belief that Guruji is capable of doing such an act. I don’t have any information other
than that.

Kabir Khan

 
 

MEDICAL EXAMINATION REPORT OF THE COMPLAINANT

Preliminary information and consent

1. Name of the hospital: - New Civil-lines Hospital

2. MLC No.:- 119/2016 Date:- 27/4/2016

3. Name of the alleged victim:- Kusum Krantiveer Paramsache

4. Age:- 26 Date of Birth:- 31-12- 1990 Religion:-Hindu

5. Married/Single/Divorced:-Married

6. Address: 10/B, Ghata Village, Khoobsurat,Gujraj, Indie Land

7. Contact Phone Nos. if any:-

8. Brought by :- Head constable Mayadevi of Palan Police Station, FIR no. U/s

9. Name & relation of the person………………NA………………………………. (If not

brought by Police)

10. CONSENT:- I Kusum Krantiveer Paramsache hereby voluntarily consent and agree to the
following- a) Medical examination and examination of genitals (including anus) and also
examination of other secondary sexual characters. b) Collection of samples for medical and
forensic examination and treatment. c) Photography/Videography for the purpose of criminal
investigation. d) Inform the police and provide them the copy of this examination report along
with samples collected for medical/forensic evidence for crime investigation. I have also
been informed that I can refuse the examination at any stage and also refuse information to be
given to the police. In this event I understand that I shall be responsible for any problem
arising in the process of crime investigation and court trial. All this has been explained to me
in my mother tongue i.e Hindi language which I can understand.

a) Signature &name &contact no of the witness Madhuri Rane

b) Signature & name of the victim/guardian in case of minor KUsum

c) Signature and name of female nurse/attendant. In presence of whom examination is

conducted. DIyani

d) Identification:

e) Right hand thumb impression:

 

11. Date and time of arrival of the victim at hospital: - 27/4/2016 at 12:00pm

12. Date, time duration and place of examination: - 27/4/2016 at 12:00pm to 2:00 pm, New Civil-
lines Hospital, Khoobsurat

13. Name/s of the doctor who has conducted examination:- Dr. Arshi Vala

14. History of alleged sexual assault as stated by victim.:-

From 14/2/2010 to 25/3/2013 regular sexual assault by Baba Neem Hakim Paramsachha

15. Personal History:-

a) History of alcohol / other drug abuse (voluntary / forceful):- No

b) History of menarche / menopause:- No

c) Was the patient menstruating at the time of assault:- NA

d) Is the patient menstruating at the time of examination: - No

e) Contraception:- Yes Method used- Condom

f) Was the victim pregnant at the time of assault? No

16. General physical examination:

a) Emotional / mental status:- Normal

b) BP 75/112; Pulse 80; Height 5feet 6inches; Weight 65 Kg

c) Nutrition- Moderate.

d) Signs of intoxication by drugs & / or alcohol:- No

e) Examination of clothes( if same as those worn at the time of assault). For evidence of
tears, loss of parts, stains, other foreign materials etc:- Na

f) Stains / foreign materials on body (including Pubic hairs & fingernails): NA

g) Gait of victim : NA

h) Abdominal Examination with Spl. Ref. to pregnancy. NA

i) Injuries on body :- ( With Spl. Reference to Signs of struggle & including age of
injuries. If there is history of buccal / anal penetration & bite marks, appropriate
swabs should be taken as indicated).

j) Physical Signs of S.T.D. : No

 

k) Any other findings:-

l) Provisional opinion regarding sexual assault :- * After examining Kusum bearing

above mentioned identification marks ,3 years after the incident, I am of the opinion
that there were no signs of rape or any kind of injuries on the body of the victim.

Date:- 27/4/2016

Place:- Khoobsurat

Arshi Vala
Dr. Arshi Vala

Sr. Doctor

New Civil-Lines Hospital

Pw -13 Madhuri Rane exhibit 47

Examination in chief on 25/7/2017

She stated that the medical examination was conducted in her presence.

No cross-examination.

Pw-14 Dr. Arshi wala exhibit 48

Examination in chief on 25/7/2017

Dr. Arshi reaffirmed the facts mentioned in his medical report.

Cross examination on 25/7/2017: - when the time gap is this long it is difficult to establish,
sexual assault.

 
 

MEDICAL EXAMINATION REPORT OF THE ACCUSED (exhibit 51)

Ref. No. ML/MASO 1891/16 Date : 28/4/2016

Report of examination of a male accused in sexual offence (including Potency)

1. Requisition dated 28/4/2016 was received on 11:00am, from the Palan P.S. IPS
for examination including potency of Guruji Neem Hakim Param Sachha aged 62 years
involved in crime under section 326, 354, 354A, 376, 377, 428 of the Indie Land Penal Code
of Palan Police station.

2. Name & Address of the subject :Neem Hakim Param Sachha Param Sachha Ashram,
Khubsoorat, Gujraj, Indie Land. Age: 62 years. Accompanied by P.S. Chotulal Gadhvi
Consent: Yes.Date and time of commencement of examination: 28/04/2016 11.00 a.m. Marks
of identification : (1)Cut mark on face (2) Birth Mark on Left wrist

3. Clinical history: History of any diseases or trauma which may affect potency: Not present.

4. History of sexual development: Fully developed Adult

5. Marital history: Unmarried.

6. Physical examination: A. General:- Height: 5’10 inch. Weight 90 kg. Build: Good Hair :
Normal Adolescent male / Adult male type of hair growth on face & body Present. B. Local
:- (a) Penis : Present Length 10cm Circumference 8.5.cm (both flaccid state) Disease
/Deformity / Injury (if any): Absent. Fore skin : Non retractable. Smegma deposits on
corona: Present Sensations : Normal Urethral discharge or tenderness on palpation:
Present (b) Scrotum : Pendulous Right testis :present Left testis : Present
Development of testis : Adult size. Sensations & Reflexes: Normal. Disease /
Deformity / Injury (if any)N/A C. Systemic examination : Pulse: 72/min.
BP 85/125 mm of Hg. Other findings ( CVS, CNS, RS, GIS )N/A D. Injuries on the
body if any :N/A

7. The examination concluded at 4pm on28/4/2016

8. Material objects preserved** : NONE

9. OPINION: * There is nothing to suggest that the above person is incapable of performing
the sexual act. * There is no evidence of Recent Sexual Act ( Based on results of Laboratory
examinations) * Opinion as to cause of injury : Could not be as alleged
 

Signature :Sanjay Chaudhri

Date :28/4/2016 Name :Dr Sanjay Chaudhri
Place :Civil Lines Hospital Designation: Head of Department

Name of institution : Civil Lines Hospital, Khoobsurat

Received the certificate : 28/7/2016

Kabir Khan

Kabir Bashir Khan

Name and Signature of the Officer In-charge of the Police Station
Rank:- Sub- Inspector

Dr. Sanjay Chaudhrai Pw 15, exhibit 50

Dr. Sanjay Chadhari reaffirmed the facts mentioned in the medical examination and there was no
cross examination from the side of the defence.
 

HOUSE  SEARCH  PANCHNAMA  ON  THE  BASIS  OF  CONFESSION  OF  THE 
ACCUSED (exhibit 54) 
 

Pancha No. 1

Name: Mr. Kamlesh Kalra

Address: Flat No. 36, Vasanti Complex, Palan, Khoobsurat, Gujraj.

Pancha No. 2

Name: Mr. Sajjuram Paramsachhe

Address: 10/B, Ghata Village, Khoobsurat,Gujraj, Indie Land.

Today, we were called at Palan Police Station. We saw Baba Neem Hakim Param Sachha there, he
confessed before us that he has frequently raped many girls in ekant-gruh his ashram and Kusum is
one of them and he is ready to show us all the place where he raped her. We, the above named
Panchas were asked by Police Inspector Mr. Kabir Khan, the investigating officer, to accompany him
to search Prasamsachha Ashram, at around 12:15 p.m. on 15th May 2016. When we reached around
1:00 p.m., with Mr. Kabir Khan and two other constables, they asked us to act as panchas, to which
we agreed.

When we reached the pace, Sevak Hanuman opened the door of ekant-gruh upon knocking , the
police began with the search of the house by 1:45 p.m. The ekant-gruh consisted of a mediation room,
bedroom and a bathroom. A black bag was recovered from the almirah kept in the bedroom. It
contained Rs. 1,50,000 cash, gold jewelry and a couple of clothes and all of which were ceased.

The search continued for some time without recovery of any further evidence.

Kabir khan

Mr. Kabir Khan, Inspector

Signed by Pancha No. 1: KK

Signed by Pancha No. 2: SJRam

Kamlesh kalra pw. 16, exhibit 56, turned hostile. No cross-examination

Sajjuram Paramsachhe pw. 17 exhibit 57 stated all the facts mentioned in the panchanama but could
not identify mudamal. Cross examination: - He stated that “police had asked me to be a part of the
 

search operation as I am aware about the place and sevaks. I signed a ready panchanama, the things
were shown to him in police station.

FRAMING OF CHARGES AND FURTHER STATEMENT 
The charges were framed under section 216 of Cr.P.C. by exhibit 15, the accused plead not guilty.

Further statement under Section 313 Cr. P.C 
The accused stated that the evidence presented by the prosecution are fabricated, the prosecution has
concocted the facts in order to trap him in the false case. He has never raped anyone. He treated all his
devotees as his own children. He never confessed anything before the police, and hereby deny all the
evidences presented in the court.

Kabir Bashir Khan, pw 18 exhibit 65

Examination in chief:- The Investigating officers stated the facts mentioned in his case diary
regarding the investigation undertaken by him, he affirmed all the facts mentioned in the charge sheet.

Cross examination:- I have no idea why the pancha turned hostile, we have conducted our
investigation properly.

Moot Problem drafted by-

Dr. Vrushti Patel, Assistant Professor- School of Law, AURO University

Ms. Sejal Chandak, Assistant Professor-School of Law, AURO University