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IN THE COURT OF CHIEF METROPOLITAN

MAGISTRATE(NORTHWEST)ROHINI
DELHI
C.C NO........../2015
PS:Adarsh Nagar
IN THE MATTER OF :
RAVI BHATEJA

APPLICANT

VERSUS
VISHNU KUMAR BHARTIYA

PROPOSED ACCUSED NO.1

VINITA BHARTIYA

PROPOSED ACCUSED NO.2

RAJESH KUMAR MISHRA

PROPOSED ACCUSED NO 3

INDEX OF PAPERS
................................................
SNo.

PARTICULARS

C.F

PAGE No.

...............................................
1.

MEMO OF PARTIES

2.

Application u/s 156(3)crpc


with affidavit.

3.

List of documents.

...............................................

APPLICANT

RAVI BHATEJA
28/45 PUNJABI BAGH
NEW DELHI-110026.
Delhi.
Dated:

THROUGH :PETITIONER IN PERSON


1

IN THE COURT OF CHIEF METROPOLITAN


MAGISTRATE(NORTHWEST)ROHINI
DELHI
C.C NO........../2015
PS:Adarsh Nagar
IN

THE

MATTER

OF

RAVI BHATEJA

APPLICANT

V/S
VISHNU KUMAR BHARTYA

PROPOSED ACCUSED NO.1

VINITA BHARTYA

PROPOSED ACCUSED NO.2

RAJESH KUMAR MISHRA

PROPOSED ACCUSED NO.3

MEMO OF PARTIES
RAVI

BHATEJA

APPLICANT

S/O BALDEV RAJ


R/O 28/45 PUNJABI BAGH
NEW DELHI-110026
VERSUS
1.VISHNU KUMAR BHARTIYA

PROPOSED ACCUSED NO 1

C/O :C-31/2,GROUP INDUSTRIAL AREA


WAZIRPUR,DELHI-52.

2.VINITA BHARTIYA

PROPOSED ACCUSED NO 2

W/O VISHNU KUMAR BHARTIYA

3.RAJESH KUMAR MISHRA

PROPOSED ACCUSED NO 3

R/O H.NO 26 FIRST FLOOR


VIDALAYA ROAD KEWAL PARK AZADPUR DELHI-33

APPLICANT

DATED:

RAVI BHATEJA

DELHI:

28/45 PUNJABI BAGH


NEW DELHI-110026.
2

IN THE COURT OF CHIEF METROPOLITAN


MAGISTRATE(NORTHWEST)ROHINI
DELHI
C.C NO........../2015

IN THE MATTER OF :
RAVI BHATEJA

APPLICANT

S/O BALDEV RAJ


R/O.28/45 PUNJABI BAGH
NEW DELHI-110026

VERSUS
1.VISHNU KUMAR BHARTIYA

PROPOSED ACCUSED NO 1

C/O :C-31/2,GROUP INDUSTRIAL AREA


WAZIRPUR,DELHI-52.

2.VINITA BHARTIYA

PROPOSED ACCUSED NO 2

W/O VISHNU KUMAR BHARTIYA

3.RAJESH KUMAR MISHRA

PROPOSED ACCUSED NO 3

R/O H.NO 26 FIRST FLOOR


VIDALAYA ROAD KEWAL PARK
AZADPUR DELHI-33

PS:ADARSH NAGAR
---------------------------------------------APPLICATION
directions

U/S
to

against the

156(3)
the

CrPc.

police

to

respondents and

for

issuing

register

commit them

FIR
to

trial and punishment according to the facts


and circumstances of this case.
Most respectfully showeth the plaintiff begs
to submit as:
1.

That

the

complainant

is

resident

of

28/45 Punjabi Bagh (west)Delhi-26 with


3

2.

his

family .

The

complainants

father

and

mother

are retired government servants and they have


earned

high

esteem

and

respect

in

the

society.
3.

That the complainant's father owns a

house

at

24,

Vidalaya

Road,Kewal

Park,

Azadpur,Delhi-33. Both of them were running 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 members of

a gang

of thugs and cheats which they 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 the social status is concerned
but there is a lot more than what that meets
the

eye.

Their

matrimonial

relationship

is

just only a viel/shroud by the virtue of which


they get entry into the society and thereafter
the

accused

varnueable

no

people

and

and

identify

accused

no

some
takes

advantage of her gender to falsely implicate


anyone whom the accused no 1 2 and 3 find
conservative
blackmailed

and
by

shy

and

threats

that
and

who

can

acts

be
of

humiliation/ridicule by lowering their dignity


4

through public shame.


5.

It is submitted that accused no 3 is a

practicing lawyer and for the last 2-3 years


or so lives in very next building on the first
floor of house owned by complainants father.
The

present

address

of

accused

no

is

26,first floor , Vidalaya Road , Kewal Park,


Azadpur ,Delhi-33 .The accused no 3 is also an
acquaintance, aide ,abettor and facilitator of
offenses committed by the accused no 1 and 2 .
6.
and

It is submitted that the accused no 1


2

had

cheated

taking

his

house

complainants
on

rent

father

through

by

forged

government identity documents(voter id card)


and cheated him with an intention to defraud
him of either his property and/or to get any
pecuniary

gains in whatever unfair and unjust

manner . Thereafter when the tenure of tenancy


neared expiry, the accused no 1 , 2 and 3 in
furtherance
conspired

of
among

their

common

themselves

intentions

,leveled

and

alleged false accusations on the complainant


by

fabricating

obscene

communication

which

they meant to be used in judicial proceedings


to bring legal injury upon complainant and his
family .
7.

Earlier the accused no 1 and 2 used to

visit the shop of complainant when he started


the business of stationery and books for their
5

children .The accused no 2 is a house wife and


she used to roam on the street . Around 2010
accused no 2 started frequenting the street
and

shop

more

often

and

she

used

her

cleverness to impress upon the complainant's


aged father and mother.
conspiracy

Unaware of their real

the complainant never suspected

their intentions and thus failed to understand


that in fact she was doing a recce e.This was
their modulus operandi to identify and target
unsuspecting citizens.
8.

One

father

day
were

when
at

the

complainant

shop,the

and

accused

his
no.1

approached the complainants father requesting


him for inducting him as tenant on first floor
of his

house .He

produced several

identity

documents to convince complainant's father and


gave the impression that he is just like a
normal

couple

family

.He

also

told

the

landlord about the details of the firm with


which he was employed in . The complainant
father inducted him as a tenant via registered
rent agreement/certificate no.
IN-DL025077290513891 dated 16/02/2010 &

IN-

DL04422730180392J

the

dated

4/01/2011

in

office of Sub-registrar, Pitampura ,Delhi for


a

period

of

11

months

and

24

months

respectively .The copies of registered rent


agreement
No.II

are

annexed

herewith

as

PW

Ex.

and PE Ex III .For this purpose the

accused no 1 produced and showed

his election
6

voter identity card as an original document


for

convincing

landlord

.After

accused no.1 himself provided

that

the

photocopy of

that voter id card to be submitted along with


the

police

verification

form

which

the

landlord did . Even the police verification


form was filled in the handwriting of accused
no 1 . The receipt of the submitted police
verification

form

bearing

the

seal

Adarsh Nagar is exhibit no P Ex.IV


the

complainant

aforesaid

has

voter

come

id

is

forged/false/fabricated

to

of

.Later

know

actually

document

PS

which

that
a
was

forged mischievously.
9.

It is submitted that accused no 3 had

also taken up the residence in the same manner


in the neighborhood nearly at the same time
when

the

accused

no

and

joined

the

locality. Mo rover the conduct of accused no 3


leaves no doubt that the accused no 1 , 2 & 3
are accomplices and they know about each other
for quiet a long time .
10.

Near the

expiry

of duration of lease

the accused no 1 and 2 not just refused to


vacate even after being served with a legal
notice one month in advance but also started
harassing the landlord and his family. This
conspiracy was put into action
accused

no.1

approached

the

as as the
complainants

father for inducting him as a tenant on basis


7

of forged documents but the most disgusting


events

started

tenancy

occurring

period

as

soon

approached

as

the

expiry

and

subsequently a formal legal notice to vacate


was served on to the accused no 1 on date
24/12/2012 PEx.No.V .The accused no 2

by the

virtue of her gender she promoted enmity among


the

two

other

resident

tenant

families

by

mixing with them at the back of plaintiff and


systematically turned them against landlord &
his other family members .Thereafter the other
tenant

families

stopped

paying

and

water)and

bills(electricity
quarreling

with

proceedings

had

complainant's

him
to

father

rent

started

therefore

be

initiated

against

and
legal

by

them

the

thereby

suffering severe financial loss & stress and


strain .The

complainant and

his family

was

made to bear all this without any fault .


Accused

no

also

worked

in

tend-um

with

accused no 1 and 2 and in spite of being a


neighbor

and

misrepresented

and
facts

an

officer

and

of

promoted

court

falsehood

and worked as a aide and a facilitator/abettor


of the crimes committed 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

unbecoming

of

his

whose conduct

profession.

In-spite

is
of

knowing in real-time that the complainant and


his family members are peaceful citizens all
the

accused

made

the

statements

both

in
8

vernacular and written,in


court

in-spite

of

police, public and

knowing

that

they

are

false ,derogatory and injurious to virtually


anyone against whom the same
alleged.

Also

mentioned

is

in

the

would be if

complaint

the

which is

date

two months

prior to the date at which it is submitted


of DD No. of PS Adarsh Nagar
conspired

plan

was

.So a well

executed

by

accused

persons.
11.

It

is

submitted

that

threatened

complainant

to

false and

frivolous criminal

accused

implicate

no
him

cases if

2
in

they

were ever asked to vacate .The accused no 2


being a women started making rumors and false,
objectionable,threatening

and

insulting

statements and along with the wife of Accused


No.3 who is also a house wife , used to make a
drama in the neighborhood and in front of the
shop and as a result of which the complainant
and his father were forced to close their shop
because of the fear of public

.The prominent

of false allegations alleged by accused no 2


were so distasteful that no prudent person can
even dare to think. One of such allegation
wasinhone meri beti ko girlfriend bola
& inki maa inse galat kaam kervati hai
to

persistent

accused

no.1

psychological

harassment
&
trauma

and

threats

2,complainant
and

he

had

Due
by

suffered
to

be

admitted in ICU MHA PEx no ..


9

Since that day the

applicant

was forced to

stop from coming to his own shop and

was

further

his

prevented

from

attending

to

normal course of business to make him suffer


financial loss and moral injury.

After filing

civil suit for eviction and second suit for


restraining the nefarious acts of accused no.1
the complainant's father opened up shop for
the

fear

of

being

dispossessed

from

the

property/third party .
12.

Since the absence of personal visit of

landlord's son prevented them from hurling any


direct

allegation

the

gang

of

accused

themselves fabricated some offensive anonymous


communication and spread that to the locality
thereby
into

bringing

reality

intention

was

plaintiff(only

their

dishonest

.The

underlying

just

only

child)so

to

as

intentions
motive

and

implicate

the

to

make

him

leverage tool upon which they would blackmail


the landlord and his family either to
the

property

extort money

of

complainant

or any

father

valuable favor

making themselves rich

grab
or

to

thereby

and cause unjust loss

to the complainant and his family .PEx.

is

a photocopy of one such application made by


the accused no 1

to the SHO police station

Adarsh Nagar , Delhi

dated

03/2014 .A reading of the plaint in the light


of

relevant

form)

documents(police

submitted

by

the

accused

verification
no

shows
10

clearly that the information given by him was


false

misconceived

and

misappropriated

.Further more false and vexatious contentions


were submitted by the accused no 1 in that
complaint

to

lawful

authorities

.In

complaint

the

accused

states

he

that

the
is

resident of this particular lane and locality


from

the

past

10

years

but

in

police

verification form dated ........ he himself


had written

that his previous address was C-

600, Majlis Park , Gali No.13 Delhi. Also in


the civil suit the accused 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

hilarious

in

that

continue living
they

can

take

his

house

couple
with

some

wants

.Its
to

stick

an adversary

other

quiet

premises

to

whereas
on

rent

somewhere else after all they are paying rent


and no body can remain amused and contented by
paying

money

to

continue

to

stick

with

person whom he considers as an adversary .This


blow hot and blow cold statements are also an
evidence
facts
13.

of

deliberate

misrepresentation

of

with dishonest intent.


It is submitted that accused no 2 in

tandem with accused no 1 and facilitated by


accused no 3
property

started mischief by damaging the

,intimidation

Complainant's

father

&

restraining

(landlord)

and

the
also
11

launched vicious attacks both in vernacular


and physical against him . Whenever the police
was called the accused says that it is the
complainant's

father

who

started

first

.Exhibit PEx.No. is ......... legal notice to


stop doing mischief & notice to vacate .The
landlords complaints against these acts are
exhibit no ...................
14.

The

conduct

of

the

accused

persons

i.e. cooking up false and malicious stories,


disseminating false and fabricated information
aided

by

the

fabrication

identity documents
and

of

forged

govt

, conduct of harassment

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 contesting
the claim of landlord through lame and flimsy
excuses shows that all the accused have taken
law for a ride without any respect for even
the

judiciary

.It

is

also

very

humbly

submitted that the acts of the accused persons


show that they are seasoned criminals.
It is also imperative to mention that
civil

litigation

which

was

filed

during
by

the

plaintiff father in the court of ADJ(NW-3),


Sh. Satish Kumar Rohini Courts

all false

pleas and frivolous contentions of the accused


were dismissed by the lordship and the suit of
complainant father was decreed in his favor on
12

28/04/2014.On that very date of judgment the


accused deliberately remained absent .In next

appearance

upon

the

lordship

on

made

submission

premises

date

insistence

23/05/2014
to

vacate

of

his

the

accused

the

demised

not later than 26/08/2014 and the

submission is PEx no
15.

The reason of attempt to implicate the

complainant can also be adjudged from the very


fact that after aforesaid submission to the
honorable court the accused no 1 and 2 started
hectic and desperate and frustrated attempts
to

bring

about

police

action

on

the

complainant . At the instance of accused no 1


and 2 , the complainant was summoned to the
police station on 7th 8th 9th 10th 11th of July
2014.There the

accused no 1 and 2 used to say

the following lines hum khali to kar denge


magar chitthiyon

ka kya

hoga.Accused no

even threatened police staff also of extreme


action if they don't accede to their demands
because she is a lady . All this happened at
the instance of accused no 3 because he being
a

lawyer

and

criminal law

aware

of

new

amendment act

provisions

of

2014, wherein

conviction can be held

on the account of the

oral

lady

testimony

certain

acts

opportunity
NIRBHAYA

of
.The

created

incident

complaining

exploitation
because
also

of

pin

complicity of accused no.3. Also

of

of
the

unfortunate
points
on

to
day
13

10/07/2014 , the accused no 2 threatened to


slap the complainant mother(Sr.CTZN) even in
front of SHO of PS adarsh nagar . Having being
failed in their extortion bid and sensing the
approaching deadline to vacate the house which
they holding, accused no 1 and 2 tempered and
destroyed the seals of NDPL electricity meter
and

it's

box

installed

premises Exbit no

within

the

gated

..........It is imperative

to mention that on 10/07/14 the accused no 2


gave a oral complaint which was reduced into
writing by ASI Sh. Raju Yadav ji. In that
complaint accused no 2 made false & malicious
allegations that she was adapt at throwing at
the

complainants

family

but/also

allegation of tempering of electricity

new

meters

by landlord who was not residing there. After


2-3 days the complainant father noticed change
in the shape of his shop's electricity meter
and it's box
realized

. As soon as the landlord

this

he

informed

NDPL

PEx. .............The accused are guilty of


criminal breach of trust .It is noteworthy to
mention that at the time of this incident no
other person was residing in that house except
1 and 2 as the last remaining tenant family
vacated on
16.

This very conduct of accused no 2 leaves

no doubt that it is the accused no 1 and 2 who


destroyed

property

and

made

circumstantial

evidences deliberately so as to cause legal


14

injury

and

otherwise

loss

to

neither

the

landlord

interested

in

who

was

extending

their tenancy nor submitting to their unlawful


demands and threats . It is also submitted
that at that time of this incident apart from
accused no 1 & 2 no third person was residing
in the demised premises.
17.

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


PEx.No........Therefore
knew

what

that

they

are

the accused persons


up-to

and

clearly

intend to take benefit of their dishonesty.


18.

At the time of payments of dues also

he said that he wants compromise .Therefore he


is

admitting

to

being

perpetrator

to

gain(compromise) by committing certain acts by


himself

thereafter

intending

to

implicate

complainant so that some settlement through


barter system can be arrived at . Dishonesty
negates all lawful acts and the dishonesty and
evil intentions are evident from the very fact
that the accused no 1 gave fabricated identity
documents to take possession of property from
complainants

father

&

later

on

tried

to

implicate his son by himself fabricating some


incriminatory evidence to harass him and/or
virtually anyone & everyone who came in their
way lawfully.
15

19.

It

is

also

submitted

that

the

complainant through his counsel has come to


know that accused no 1 and 2 had also filed
against

him

criminal

complaint

case

no.45/1/14 in the court of.hon'ble Sh. kapil


kumar MM north west Rohini court Delhi where
accused

no

is

their

lawyer

against

him

first u/s 156 3 and later changed that to u/s


200 CrPc and submitting that he is interested
in

prosecuting

non

ravi

cognizable

(complainant

here)

offenses(compoundable

for
).Mo

rover the accused has failed to present even


an iota of per-summoning evidence against him
in that criminal complaint .
Also the complainant have reasons to believe
that these accused have also made a criminal
complaints against SHO PS Adarsh Nagar just to
invoke fear in his heart that if he doesn't
cause

any

injury

through

his

legal

powers

against the complainant might be he has to


loose his government job also.
20.

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 of self on the canvas of
imagination

aided

by

the

environment

of

sympathy towards female gender owing to the


frequent media trials of crimes against women
and all three accused joined hands just only
to

defraud

and

harass

the

authorities

and
16

complainant for

some unjust

gain. They

had

deliberately tried to show the complainant and


his family in poor light by perpetrating and
planting false evidences
to be
acts

which

they intend

used in judicial proceedings and such


are

Through

being
their

continued
conduct

undermined the

till

they

value and

this

have

date.

seriously

importance of

not

only executive & judiciary but also womanhood


as

whole.

Moreover

it

is

pertinent

to

mention that even NIA during the investigation


of

bomb

blasts

and

terror

activities

has

admitted and proved that desperate terrorists


retort to keeping forged identities to escape
from the scrutiny of law enforcement agencies.
Terrorists have no gender. Therefore also it
is a matter which concerns and cause prejudice
not just an individual(applicant) but it is
also concerned with national security .
21.

The cause of action arose as on dated

02/03/2015,

the

accused

no

has

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 .
22.

The

cause

of

action

also

arises

in

October 2015 as the complainant comes to know


about

another

offending

and

incriminatory

communication made to the police in the name


17

of his father(Baldev Raj) alleging falsehood


for

which

his

parents

were

summoned

by

vigilance department at Ashok Vihar,Delhi on


date 05/10/2015 . It is pertinent to mention
that

in

this

specific

communication

reference was also made about HC Adarsh nagar


Sh.balkrishan malik
no

on

because once when accused

dated13/07/2014

restrained

complainant's father and locked him inside his


shop and locked the way to the toilet which
was is in exclusive possession

then made

call at no 100 pursuant to this call it was


the HC Balkrishan malik ji who rescued that
senior citizen

and admonished accused no.2

.Since that incident the accused no 1 and 2


started

fostering

jealousy

towards

HC

Sh.balkrishan malik and so as to cause injury


to

him

are

themselves

writing

and

posting

objectionable communications/rumors about him


to cause affray.
23.

That the accused no 1 , 2 & 3

are

continuing to harass the complainant and his


family

in

provocation

one

way

through

or

the

anonymous

another

by

communication

and thereby causing affray.


Ever since the accused no 1 and 2 had vacated
they

haven't

causing
peaceful

given

hindrances
enjoyment

up
and
of

on

their

efforts

disturbances
the

property

of

in

the

by

the

complainant and in conducting his business, so


as to compel his family to sell off their
18

property
accused

and
no

provoke

the

get

settled

and

his

elsewhere

wife

complainant

always

by

The

try

to

making

some

nuisance or other so that they can augment the


weight of their previous false allegations and
this behavior

is totally

unbecoming of

his

profession as an officer of the court .


24.

It is most respectfully submitted that

it is a settled proposition of law that if


anyone uses any forged document which he knows
is forged for executing a transaction then it
will be punished in the same manner as if he
has made it .Therefore it is

humbly submitted

that a person who has the audacity to prepare


forged

government

documents

having

security

features like holograms ,then he can also make


false private evidences very easily to defraud
and cheat innocent unsuspecting citizens and
accused no 3 who in spite of being aware of
the

real

else

on

situation
reel

and

is

portraying

that

is

something

unbecoming

the

officer of the court .


25.

Mo

perpetrated

rover
by

all

accused

these
no

offenses
and

were

at

the

instance of accused no 3 because only a legal


mind is in the know of all these procedures
whereby something incriminatory and tangible
is

deliberately

fabricated

and

tendered

to

police and the blame of which can be smeared


on the face of the

opposite party to take an


19

edge. The activities of accused 1 ,2 and 3 are


interconnected so

it can

be easily

derived

that they have been knowing each other even


before taking up residences in this particular
lane of complainant house .Also it cannot be
denied that the act of
normal

family

in

shroud

under

which

offenses

against

state. It

posing themselves as a

society

is

accused

both

the

is submitted

just

only

persons

commit

citizens

&

that such

the

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

right from 1978 and virtually each and every


third person can vouch for his truthfulness
and peaceful nature.
26.

On inquiry the complainant comes to know

that the voter id card which was shown in


original to the complainant & his
whose

photocopy

given

by

accused

father and
no

for

police verification at time of taking tenancy


duly submitted to PS Adarsh Nagar on date
26/03/2010

is

registration

forged/false

number

of

the

document

above

.The

mentioned

voter id card is actually issued in the name


of a women namely ANITA DEVI from the state of
district
accused

Navalgarh
no

and

Rajasthan
2

are

of

which

the

natives/aborigines.

This corroborated by Pex.......(ECI database


internet).The correct registered voter id card
20

of

accused

no

name/identity.

is

Ex.No.

also

in

.......

different
voter

list

Delhi assembly elections 2015 Page no... .


27.

Also

accused

signatures

of

no

managed

complainant

to

father

get

on

application for voter id and there she has


misrepresented her name as saroj whereas in
police verification form which was filled by
accused 1 in his own handwriting he gave her
name as

vineeta. Hence

deception played

on

government authorities by both the accused no


1& 2 .None but only a habitual cheater would
tender

multiple

identities

to

government

authorities to escape from the eyes of law


enforcement

authorities

for

achieving

their

nefarious designs and ulterior motives. The


acts of the accused are synonymous to those of
the

seasoned

criminals.

Even

the

proved during the investigations


attacks

that

terrorists

NIA

has

of terror

retort

to

acquire

multiple identities to escape from the eyes of


law

enforcement

heinous

crimes

agencies
like

bomb

for

perpetrating

blasts

&

hawala

activities.
28.

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

rover

it

is

also
21

submitted that the applicant & his family has


suffered heavy monetary loss and also mental
stress and agony by the actions of accused.
The accused are guilty with their intent and
actions which are totally unethical,immoral &
unlawful

and

moreover

prejudicial

not

such
just

individual(complainant)

but

acts

are

to
to

one

the

whole

society.
29.

It is submitted that the complainant has

already given his complaint to the PS Adarsh


Nagar dated :
Pex.No.

Also

(Copy enclosed as
an

E-mail

of

the

same

was

communicated to the respected commissioner of


delhi police on date ...
copy enclosed Exibit No. ..........
Also the same matter was communicated to the
office of CEO Delhi Pex.No.
was received
a

reply

......

to

initially
the

same

and after reminder ,


was

PEx.No.

satisfactory so

No reply
received
Which

on

date

was

non

a rejoinder to the same was

sent on ..PEx.No.

(copy enclosed ) and

from that day on wards the complainant is yet


to see/hear from the CEO Delhi office or from
Delhi

Police.

other remedy
the

Therefore
but to seek

applicant

has

no

intervention of

Hon'ble Lordship so as to get justice .

22

PRAYER:

It
prayed

is,

that

therefore,

Honorable

most

court

respectfully

may

kindly

be

pleased to direct the police to register FIR


against the accused persons and investigate
as per the

law in view of the facts and

circumstances mentioned above in the interest


of justice.
Any other order that lordship may please
consider fit and appropriate in this case
.
------------------------------------

Applicant/complainant
Delhi:
Dated:
Ravi Bhateja

23

IN THE COURT OF CHIEF METROPOLITAN


MAGISTRATE (NORTHWEST)ROHINI COURTS
DELHI
C.C NO........../2015
PS: Adarsh Nagar
IN THE MATTER OF :
RAVI BHATEJA

APPLICANT

V/S
1.VISHNU KUMAR BHARTYA

PROPOSED ACCUSED 1

2.VINITA BHARTYA

PROPOSED ACCUSED 2

3.RAJESH KUMAR MISHRA

PROPOSED ACCUSED 3

AFFIDAVIATE
1.I

, Ravi Bhateja S/O Baldev Raj age about

38yrs R/O.28/45 Punjabi

Bagh

,New

Delhi-

110026, do hereby solemnly affirm and state as


under:2.That I am the applicant/complainant in

the

above

and

matter

aware

of

the

facts

competent to depose the present affidavit.


3.I

have drafted the plaint by myself taking

references

from

whatever

legal

resources/information that are accessible to


me.

24

4.That

have

application

and

read
the

the

same

accompanying

have

also

been

understood by me.
5.That

the

contents

of

accompanying

application and documents attached along with


are true to my knowledge.
6.That

the

contents

of

accompanying

application may be read as a part of this


affidavit.

APPLICANT

RAVI BHATEJA
VERIFICATION :Verified

that

the

contents

of

affidavit from no. 1 to 5 are true to my


knowledge

and

nothing

material

has

been

concealed therefrom.

APPLICANT
Verified at Delhi

DELHI:
DATED:

RAVI BHATEJA
25

26

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