IN THE COURT OF THE CHIEF METROPOLITAN MAGISTRATE, PATIALA HOUSE COURT , NEW DELHI
Complaint Case No.________of 2015
IN THE MATTER OF:
Mr. Ram Balak Singh …..Complainant
VERSUS
Mr. Sanjay Kumar Singh & Ors. ..…Accused
INDEX
S.NO. | Particulars | Pages | C. Fee |
1. | Memo of Parties | ||
2. | Complaint U/s 156(3) & 200, Cr.P.C.
alongwith Affidavit in support |
||
3. | ANNEXURE A: Copy of ID proof | ||
4. | ANNEXURE B:Receiving Copy of
Police Complaint dated 10.10.2014 |
||
5. | ANNEXURE C: Copy of Details of
the payments alongwith the receiving slips of the SBI , Receiving memo of ATM & Bank Statement |
||
6. | ANNEXURE D: Submission Letter
to the SHO. PS. Tilak Marg dated 16.1.15 |
||
8. | ANNEXURE F: News Paper
Advertisement copy |
||
9 | List of Witnesses | ||
10. | Vakalatnama |
Filed By
Avinash Nandan Sharma
Advocate
Chamber No. 671, Patiala House Courts,
New Delh-110001. Mob.
Dated:
Place:
IN THE COURT OF THE CHIEF METROPOLITAN MAGISTRATE, PATIALA HOUSE COURT, NEW DELHI
Complaint Case No.________of 2015
IN THE MATTER OF:
Mr. Ram Balak Singh …..Complainant
VERSUS
Mr. Sanjay Kumar Singh & Ors. ..…Accused
MEMO OF PARTIES
Mr. Ram Balak Singh
S/o. Chandrika Singh
R/o. DGICG Sectt.
Coast Guard Headquarters
National Stadium Complex
New Delhi -110001 ……. Complainant
VERSUS
- Sanjay Kumar Singh
- Suman Verma ……. Accused Persons
Filed By
Avinash Nandan Sharma
Advocate
Chamber No. 671, Patiala House Courts,
New Delh-110001. Mob. 8800794128
New Delhi
Date:
IN THE COURT OF THE CHIEF METROPOLITAN MAGISTRATE, PATIALA HOUSE COURT, NEW DELHI
Complaint Case No.________of 2015
IN THE MATTER OF:
Mr. Ram Balak Singh
S/o. Shiv Singh
R/o. DGICG .
Coast Guard Headquarters
National Stadium Complex
New Delhi -110001 ……. Complainant
VERSUS
- Sanjay Kumar Singh
- Suman Verma ……. Accused Persons
P.S. Tilak Marg
COMPLAINT UNDER SECTIONS 156(3) & 200 OF CRIMINAL PROCEDURE CODE R/W SECTION 420 OF INDIAN PENAL CODE AGAINST THE ACCUSED PERSONS
Sir,
MOST RESPECTFULLY SHOWETH:-
- That the complainant is a Govt. employee working with Service no. 154364-B as POTOP, at Coast Guard Headqrarters, National Stadium Complex, New Delhi for last 2 years. The ID Proof of the complainant is annexed herewith as ANNEXURE-A .
- That the accused persons have allegedly claimed to be representing the KBC TATA Motors and are holders of SBI accounts.
- That on 25.9.2014 at about 11 A.M, when the complainant was watching Music Express TV Channel , there was an advertisement – “Recognize the photo and Win Tata Safari or Cash.” The advertisement says that give a miss call at mob. No. 07764946611. The complainant gave a miss call from his mob. No. 9953729122 After one hour, a call came from accused no. 1 Sanjay Singh and he said – “I am calling from KBC Tata Motors and you have won Tata Safari as his first winner . You would prefer to receive Tata Safari or cash of Rs. 12,80,000/- ”
- That when the complainant said for the cash, accused no. 1 said that you have to deposit Rs. 7.550/- as Registration Charges in SBI A/C no. 33544462178. The accused no. 1 also gave another SBI account no. 34027857666 which was on the name of accused no.2, Suman Verma. Accuse persons kept demanding money from the complainant on the pretext of TV Show charges, Income Tax, Ticket booking etc. The Complainant deposited a total of Rs. 1,97,100/- ( Rupees One Lakh nitety senen Thousnad one hundred) by cash and account transfer through his SBI account no. 10709078854 into two accounts namely Sanjay Kumar Singh , SBI A/C . 33544462178 and Suman Verma SBI A/C 34027857666 towards handling charges etc.
- That during entire transaction period from 25th 2014 to present day , complainant has been receiving phone calls from the accused persons assuring him that the prize money of Rs. 12,80,000/- will be deposited in his account at the earliest. However , despite depositing Rs. 1,97,000/- the complainant did not receive any prize money. Then the complainant approached his senior officer Commander P Sasi Kumar who instructed him to immediately desist from depositing any more money and on 10.10.2014 forwarded a complaint letter on his Official Letter Head along with the copy of the written complaint of the complainant to the Assistant Commissioner of Police, New Delhi Distt. and the matter was refered to P.S . Tilak Marg. The receiving coppy of the complaint is annexed herewith as ANNEXURE – B
- That the complainant inquired about the address of the said account holders from the SBI Bank and was informed that accused Sanjay Singh’s address is Patel Nagar, Nawada Bihar and the address of accused Suman Verma is Jagjivan Nagar, Dhanbad, Jharkhand. Copy of Details of the payments alongwith the receiving slips of the SBI , Receiving memo of ATM & Bank Statement of the complaint delivered by complainant to the accused persons through their accounts are annexed herewith as ANNEXURE – C (Colly).
- That the accuse no. 1 Sanjay Kumar Singh is using Mob. No. 9162541349 & 9162581760 and accused no. 2 Suman Verma is using mob. No. 7759830663 , 7764946611 , 9162581760 & 9958434601 through which they have talked to the complainant many times and demanded
- That 16.1.2015 a Submission Copy was also given to the PS. Tilak Marg by the Complainant stating some clue of this case.Copy of this Submission Letter was also served to the Additional Commissioner of Police, New Delhi. The receiving copy of the Submission Letter is annexed herewith as ANNEXURE-D.
- That the accused persons have also advertized this quiz contest on B4U and Sahara One Channels and in Nav Bharat Times , Hindi Daily newspaper. The newspaper cutting dated is annexed herewith as ANNEXURE- E.
- That as the accused persons have intentionally and with well planned strategy cheated the complainant by illegally receiving Rs. 1, 97,000/- they have committed the offence of Cheating U/s 420 of IPC within the jurisdiction of this Hon’ble Court. The direction of this Hon’ble Court for police investigation may also reveal crime of forgery as the accused persons might be operating forged bank account in this matter.
- That this case prima facie shows the involvement of a racketeers who are threat to the society as whole as the complainant would certainly not be the only victim of these accused prsons. This is a case in which the proper police investigation is required. However police have not taken any action nor registered the FIR in this matter because of the reasons best known to them.
- The complainant and his family are shocked at this act of cheating and forgery by the accused persons and have undergone metal agony on this account and facing financial hardship facing present situation.
- That the case has been filed within the period of limitation and on proper stamps.
- That applicant submits that in the given facts and circumstances, the applicant/complainant being a victim is left with no alternative but to approach this Hon’ble Court for justice as the police have failed to act in the matter of complaint.
PRAYER
It is, therefore, most respectfully prayed that the adequate action be taken in the interest of justice. And the accused persons may be tried and punished for the said offence according to law.
Complainant
Through
( Avinash Nandan Sharma)
Advocate
Chamber No. 671, Patiala House Courts,
New Delh-110001. Mob.
Date:
Place:
IN THE COURT OF THE CHIEF METROPOLITAN MAGISTRATE, PATIALA HOUSE COURT, NEW DELHI
Complaint Case No.________of 2015
IN THE MATTER OF:
Mr. Ram Balak Singh …..Complainant
VERSUS
Mr. Sanjay Kumar Singh & Ors. ..…Accused
AFFIDAVIT
I, Mr. Ram Balak Singh S/o. Sh.Chandrika Singh aged about Yrs. R/o. . DGICG Sectt. Coast Guard Headquarters, National Stadium Complex, , New Delhi -11000 do hereby solemnly affirm and declare as under:-
- That I am the complainant in the said complaint and am well conversant with the facts and circumstances of the case and am competent to swear this affidavit.
- That accompanying complaint U/S 156(3) & 200, Cr.P.C. R/W 420 of IPC has been drafted by my counsel under my instructions and contents of the same have been explained to me in vernacular and understood by me and the same are not being repeated herein for the same of brevity and may be read as part and parcel of this affidavit.
- This is my true and correct statement.
DEPONENT
VERIFICATION
Verified at New Delhi on this day of May 2015 , that the contents of my above affidavit are true and correct to the best of my knowledge and belief and nothing material has been concealed therefrom
DEPONENT
IN THE COURT OF THE CHIEF METROPOLITAN MAGISTRATE, PATIALA HOUSE COURT, NEW DELHI
Complaint Case No.________of 2015
IN THE MATTER OF:
Mr. Ram Balak Singh …..Complainant
VERSUS
Mr. Sanjay Kumar Singh & Ors. ..…Accused
LIST OF WITNESSES
- Complainant , Ram Balak Singh
- Any other witnesses with the permission of the Hon’ble Court.
.
Filed By
Avinash Nandan Sharma
Advocate
Chamber No. 671, Patiala House Courts,
New Delh-110001. Mob.
Date
Place
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