IN THE COURT OF CHIEF METROPOLITAN MAGISTRATE,

KARKARDOOMA COURT, NEW DELHI

COMPLAINT NO.________OF 2018

IN THE MATTER OF:-

ABDUL AHAD
S/O LATE ABDUL LATIF
R/O A-148, SHAHEEN BAGH,
AF ENCLAVE PART II, JAMIA NAGAR,
NEW DELHI - 110025, ...COMPLAINANT

VERSUS

1. MOHD. AYAN MALIK

S/O VALI MOHAMMAD
R/O I-98, FLAT NO. 14,
BATLA HOUSE, JAMIA NAGAR
NEW DELHI-110025
2. SMT. KRISHNA RANI
W/O SH.
R/O
3. ASI AMAR PAL
ATTACHED WITH PS GOKULPURI …ACCUSED

PS: GOKULPURI
NEW DELHI

COMPLAINT U/S 190 OF CRIMINAL PROCEDURE CODE R/W/S

156(3) Cr. P. C. SEEKING NECESSARY DIRECTIONS TO THE POLICE
OR ANY OTHER INVESTIGATING AGENCY FOR REGISTRATION OF
FIR AGAINST THE AFORESAID ACCUSED PERSONS FOR
COMMISSION OF OFFENCES U/S 341 / 403 / 409 / 506 PART II IPC
AND OTHER PROVISIONS OF LAW.

MOST RESPECTFULLY SHOWETH:-

1. That the complainant is a respected member of society and is a

teacher by profession for more than 35 years and is residing at A-
148, Shaheen Bagh, Abul Fazal Enclave Part II, Jamia Nagar,
Okhla, New Delhi – 110025.

2. That the complainant has been cheated and forcibly dispossessed

of his property bearing No. F-5, Gali 6, Bhagirathi Vihar, Karawal
 Nagar Road, Delhi and he is a victim of criminal conspiracy
planned and executed by one Mohd Ayan Malik & Smt. Krishna
Rani in connivance with one ASI Amar Pal of PS Gokulpuri.

3. That the complainant is the absolute owner of the property bearing

No. F-5, G 6, Bhagirathi Vihar, Karawal Nagar Road, Delhi. The
complainant has purchased the above said property in the year
1988, from Mrs. Punam Rani Sharma W/o Surendar and have the
papers containing entire chain of papers. Thereafter, he
surrounded the said property by making boundary on all 4 sides of
the property and have constructed Rooms, Latrine, Bathroom in
the said Property, and thereafter he started living in the said
Property with his family and since then the said Property is in full
use, occupation and possession. The complainant is having the
documentary evidence in his possession namely (1) General Power
of Attorney (2) Agreement to Sell (3) Receipt of payment (4) Ration
Card Date: 1st March, 1989, (5) Election ID Card.

4. That the son of the complainant, Mr. Abdul Basid, was visiting the
property for past few days as some work was being carried on as
the plot was full of garbage and other waste material thrown by the
neighbors over time. On 12th April, 2018 at 10.30 AM in the
morning the son of the complainant Abdul Basid routinely went to
the plot for the cleaning of the plot, where he saw that one
unknown person which the complainant later came to known as
Mohd. Ayan Malik entered the door of the plot along with the
police, on inquiry by the complainant son, it came to the
knowledge that allegedly Ayan Malik is the tenant of Krishna Rani,
thereafter, police, lodged the false complaint against the
complainant’s son. Police arrived and took both the persons to
Gokal Puri Police Station.

5. That the complainant showed all the documents of the property to

the concerned Officer, the said Police Officer namely ASI Amar Pal
gave the complainant assurance that after making enquiry, he will
take the legal action against the culprit but one of the accused,
Ayan Malik, did not show any kind of documents regarding the
Ownership of the said Property.
 6. The complainant was made to sit at Police Station till late night
and suddenly he was shocked and surprised to know that one
F.I.R. is registered against his son and friend Abdul Basid and
Abdul Wahab, respectively. His son and his friend were released
after signing the Bond from the Police Station.

7. That, thereafter, the complainant came to know that Ayan Malik in

connivance with Krishna Rani, filed a civil suit against Krishna
Rani wrongfully stating and misleading the court by submitting
false and forged documents stating that Krishna Rani is the owner
of the aforesaid property and for getting a meter but soon after few
dates in the case, both of them settled the matter before the court.
Ayan Malik used those court orders to show to the police as
documents in support of his claim and no other evidence from his
side was shown to the police.

8. That the complainant had purchased the said Property with his
hard earned money and since last 3 decades no hurdles or
controversy arose. Since last 15 Days, the complainant has started
some work on his property to put iron-gate on the Property’s
entrance and for cleaning the Property. The complainant is also
having the Photographs in his mobile of the above said facts.

9. That, thereafter, the complainant wrote a complaint on 13th April,

2018 to Thana Gokal Puri, ACP and DCP as mentioned above
about making an attempt to take forcible possession of the above
said Property by the above said persons, but it came to the
knowledge of the complainant as a shock that after making of such
complaint the above said persons have taken the forcible
possession with the help of and in connivance with ASI Amar Pal of
the above said Property on 15th April, 2018, and on the contrary
the Police Have Registered the False and fabricated Case against
the son of the complainant.

10. That the complainant is still receiving calls from the Police Station,
this is nothing but mental torture and harassment because he has
been forcibly dispossessed, and the above said persons have taken
the illegal and forcible possession of the above said Property with
connivance of one A.S.I. Amar Pal and Police is not taking any
 cognizance against the above said persons, the whole incidents
clearly speaks about the role played by the Police in this Scenario,
the A.S.I. Mr. Amar Pal attached to Gokal Puri Police Station is
constantly calling the complainant and terrorizing and torturing
him mentally.

11. That the complainant is severely affected by the above said

incident and cannot eat and sleep properly, he is living under
constant fear, his life has become miserable, also he has been fully
dispossessed from the above said Property, his rights have been
violated openly which is provided by the Constitution of India, and
being an heart patient the complainant is also having fear of
suffering from another heart attack because of the mentioned
incident.

12. That the complainant also prays this Hon’ble Court to further
investigate the matter and unveil the people responsible for forcibly
dispossessing the complainant of his property as this is the work of
land mafia, who has been grabbing lands of innocent people
through proper and well thought criminal conspiracy.

13. That the complainant registered a complaint regarding the

aforesaid incident in PS Jamia Nagar on 01.05.2017 vide DD Entry
No. ____, to which no action has been taken till date and the
complainant was advised to lodge a complaint in PS Kalkaji as he
resides there.

14. That thereafter the complainant also registered a complaint with

PS Kalkaji on 00.00.2017 vide DD Entry No. ___, and also sent a
copy of the complaint by speed post to ACP, South East Delhi, on
22.08.2017 which was duly received on 23.08.2017.

15. That inspite of receiving a complaint of commission of cognizable

offences u/s 341 / 403 / 409 / 506 Part II IPC the police failed to
take any action and till date no FIR has been registered nor any
action has been taken.

16. That the complainant has no other remedy but to approach the
Hon’ble court for directions to the police to register a formal FIR
and take necessary investigation/steps as per law.
 PRAYER:

In view of the facts mentioned above it is most respectfully

prayed that this Hon’ble court may be pleased to exercise powers
U/s 341 / 403 / 409 / 506 Part II IPC and 156(3) Cr. P.C. by
directing the SHO of Police Station P.S. Kalkaji, New Delhi to register
a FIR against the accused persons U/s 341 / 403 / 409 / 506 Part
II IPC on the complaint of the complainant dated 00.08.2017 to
investigate the same and take appropriate further action as per law.

Pass any other or further order(s) as this Hon’ble court may

deem fit and proper in the facts and circumstances of the case.

Complainant
Through

(F.A. Khan)
New Delhi (Counsel for Complainant)
Dated:
 IN THE COURT OF DISTRICT AND SESSION JUDGE,
ROHINI COURTS, DELHI
Bail Application No. Of 2018

IN THE MATTER OF:-

PRANSHU CHOPRA ..PETITIONER/ACCUSED

VERSUS

STATE

AFFIDAVIT

I, Sh. Pranshu Chopra, S/o Late Sh. Narender Chopra , R/O B-

2/57, Ramesh Nagar, New Delhi, do hereby solemnly affirm and state as
under:-

1. That I am the petitioner in the present petition and well

conversant with the facts of the accompanying petition and
hence competent to swear this affidavit.

2. That I have gone through the contents of the accompanying

petition, which has been drafted by counsel for the petitioner
under my instructions and have been explained to me in
vernacular. Contents thereof are true and correct and the
same may be read as part and parcel of this affidavit which
are not being repeated for the sake of brevity.

DEPONENT

VERIFICATION:
 Verified at New Delhi on this the day of January 2018 that the
contents of the above affidavit are true and correct. No part of it is false
and nothing material has been concealed therefrom.

DEPONENT

IN THE COURT OF CHIEF METROPOLITAN MAGISTRATE,

SAKET COURT, NEW DELHI
COMPLAINT NO.________OF 2017

MEMO OF PARTIES

IN THE MATTER OF:-

ARSHAD KHAN
S/O MOHD AWAIS KHAN
R/O G-23A 3RD FLOOR,
KALKAJI, NEW DELHI ...COMPLAINANT

VERSUS

MOHD AZAM KHAN

S/O MOHD ANIS KHAN
R/O I-98, FLAT NO. 14,
BATLA HOUSE, JAMIA NAGAR
NEW DELHI-110025 …ACCUSED

PS: KALKAJI
NEW DELHI
 Complainant
Through

(F.A. Khan)
New Delhi (Counsel for Complainant)
Dated:

IN THE COURT OF CHIEF METROPOLITAN MAGISTRATE,

SAKET COURT, NEW DELHI
COMPLAINT NO.________OF 2017

IN THE MATTER OF:-

ARSHAD KHAN ...COMPLAINANT

VERSUS

MOHD AZAM KHAN …ACCUSED

LIST OF DOCUMENTS

S.NO DOCUMENTS PAGE NO.

1. COPY OF COMPUTER GENERATED
MASTER DATA OF EASTERN BUILWELL
PVT. LTD FROM MCA.GOV.IN.
2. COPY OF ACCOUNT STATEMENT OF M/S
EASTERN BUILDWELL PVT. LTD.
BEARING ACCOUNT NO.
13452320001393, HDFC BANK, GREEN
PARK BRANCH NEW DELHI
3. ORIGINAL COMPLAINT TO THE SHO P.S.
JAMIA NAGAR VIDE DD ENTRY NO. ___,
DATED 01.05.2017.
4. ORIGINAL COMPLAINT TO THE SHO P.S.
KALKAJI VIDE DD ENTRY NO. ___, DATED
00.07.2017
5. ORIGINAL POSTAL RECEIPTS DATED
 22.08.2017
6. ORIGINAL TRACKING REPORT FROM THE
WEBSITE OF INDIA POST

Complainant
Through

(F.A. Khan)
New Delhi (Counsel for Complainant)
Dated:

IN THE COURT OF CHIEF METROPOLITAN MAGISTRATE,

SAKET COURT, NEW DELHI
COMPLAINT NO.________OF 2017

IN THE MATTER OF:-

ARSHAD KHAN ...COMPLAINANT

VERSUS

MOHD AZAM KHAN …ACCUSED

INDEX

S. PARTICULARS PAGE
NO. NO.
1. MEMO OF PARTIES.
2. COMPLAINT U/S 190 OF CRIMINAL PROCEDURE
CODE READ WITH SECTION 156(3) Cr. P. C.
SEEKING NECESSARY DIRECTIONS TO THE
POLICE OR ANY OTHER INVESTIGATING AGENCY
FOR REGISTRATION OF FIR AGAINST THE
AFORESAID ACCUSED PERSONS FOR
COMMISSION OF OFFENCES U/S 341 / 403 / 409
/ 506 Part II IPC AND OTHER PROVISIONS OF LAW
ALONGWITH SUPPORTING AFFIDAVIT.
3. LIST OF DOCUMENTS WITH DOCUMENTS.
4. VAKALATNAMA.
 Complainant
Through

(F.A. Khan)
New Delhi (Counsel for Complainant)
Dated: