IN THE COURT OF CHIEF METROPOLITAN

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

PS:Adarsh Nagar
APPLICANT

VERSUS
VISHNU KUMAR BHARTYA

PROPOSED ACCUSED NO.1

VINITA BHARTYA

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 :SELF
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 BHARITYA

PROPOSED ACCUSED NO.1

VINITA BHARITYA

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
---------------------------------------------Most respectfully showeth the plaintiff begs
to submit as:
1.

That

the

complainant

is

resident

of

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

his

family .

2. The complainants father and mother are

retired government servants and they have
earned

high esteem and respect in the

society.
3

3.

That the complainant's father owns a house

at

24,

Vidalaya

Azadpur,Delhi-33.

Road,Kewal
Both

of

Park,

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 their social
status is concerned and 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 no 1 and 2 identify some
varnueable people and accused no 2 takes
advantage

of

her

gender

to

falsely

implicate anyone whom the accused no 1 2

and 3 find conservative and shy and that
who can be blackmailed by threats and acts
of humiliation/ridicule by lowering their
dignity 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
4

the

first

floor

of

house

owned

by

complainants father. The present address

of

accused

Vidalaya

no

Road

is

26,first

Kewal

floor

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.

It is submitted that the accused no 1 and

2 have cheated the complainants father by
taking his house on rent through 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 of
their common intentions conspired among
themselves
accusations

,leveled
on

the

and

alleged

complainant

false
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

children .The accused no

2 is a house wife and she used to roam on

5

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.

Unaware

conspiracy

the

of

their

complainant

real
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 day when the complainant and his

father

were

approached

at
the

shop,the

accused

complainants

no.1

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

father

employed
inducted

in
him

The

as

complainant
tenant

via

registered rent agreement/certificate no.

IN-DL025077290513891 dated 16/02/2010 &
IN-DL04422730180392J

dated

4/01/2011

in

the office of Sub-registrar, Pitampura

,Delhi for a period of 11 months and 24
months

respectively

.The

copies

registered rent agreement are

herewith as PW Ex. No.II

of

annexed
and PE Ex

III .For this purpose the

produced and showed

accused no 1

his election voter

identity card as an original document for

convincing

landlord

.After

that

accused no.1 himself provided

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 of PS Adarsh Nagar is
exhibit

no

complainant
aforesaid

P
has

voter

Ex.IV

.Later

come
id

is

to

know

the
that

actually

forged/false/fabricated document which 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 1 and 2 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 .
Near the
the

expiry

accused

no

of duration of lease
1

and

not

just

refused to vacate even after being served

with a legal notice one month in advance
7

but also

started harassing the landlord

and his

family. This conspiracy was put

into

action

as

approached the
inducting him

as

the

accused

complainants
as

no.1

father

tenant

on

for

basis

of

forged documents

but the most disgusting

events started

occurring

as

soon

as

the tenancy period

approached

and subsequently a

formal legal notice

to vacate was served

on

to

no 1 on date 24/12/2012
accused no 2

expiry

the

PEx.No.V

by the virtue

resident

mixing

with

tenant
them

.The

of

her

gender she promoted enmity among

other

accused

the

families
at

the

two
by

back

of

plaintiff

and systematically turned them

against

landlord

&

his

other

family

members

.Thereafter

the

other

tenant

families

stopped

paying

rent

bills(electricity

and

water)and

quarreling with

him

and

started

therefore

legal

proceedings had to

be initiated by the

complainant's father

against

them

thereby suffering severe

financial loss &

stress and strain .The

complainant

his family was made to

bear

without any fault .

Accused

no

worked in tend-um with accused

and

all

this

also

no 1 and

2 and in spite of being a neighbor and and

an officer of court

misrepresented

facts and promoted

falsehood

and

worked as a aide and a facilitator/abettor

8

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 whose
conduct is unbecoming of his profession.
In-spite of knowing in real-time that the
complainant

and

his

family

members

peaceful citizens all the accused

the

statements

written,in
spite

of

both

in

,derogatory

and

that

made

vernacular

police, public and

knowing

are

court in-

they

injurious

are

to

anyone against whom the same

and
false

virtually

would be if

alleged. Also in the complaint the date

mentioned

is

which is

two

months prior to the date at which it is

submitted

of DD No. of PS

Adarsh Nagar

.So a well conspired

plan was executed by accused persons.

10. It

is

submitted

that

accused

no

threatened complainant to implicate him in

false and frivolous criminal cases if 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

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
9

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
Due to persistent harassment and threats
by accused no.1 & 2,complainant suffered
psychological trauma

and he had to be

admitted in ICU MHA PEx no ..

Since that day the

applicant

was forced

to stop from coming to his own shop and

was

further

prevented

from attending to

his 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 .
Since the absence of personal visit of
landlord's son prevented them from hurling
any direct allegation , the
accused

themselves

offensive
spread

anonymous

that

to

the

gang of

fabricated

some

communication
locality

and

thereby

bringing their dishonest intentions into

reality

.The

underlying

motive

and

intention was just only to implicate the

10

plaintiff(only child)so as
leverage

tool

blackmail

upon

the

either to

to make him a

which

landlord

and

they

would

his

family

grab the property of complainant

father or to extort money or any valuable

favor thereby making themselves rich

and

cause unjust loss to the complainant and his

family .PEx.

is a photocopy of one such

application made by the accused no 1

SHO

police

dated
the

station

Adarsh

Nagar

to the
,

Delhi

/03/2014 .A reading of the plaint in

light

of

relevant

documents(police

verification form) submitted by the accused

no

shows

clearly

given by him was

misappropriated

that

the

information

false , misconceived and

.Further

more

false

and

vexatious contentions were submitted by the

accused no 1 in that complaint to lawful
authorities .In the complaint the accused
states

that

he

is

resident

of

this

particular lane and locality from the past

10

years

verification

form

dated ........ he himself had written

that

his

but

in

previous

police

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 in his house .Its quiet
hilarious that a couple wants to stick to
continue living

with an adversary whereas

11

they can take some other premises on rent

somewhere

else

after

rent

and

no

body

contented

by

paying

all

can

they

are

remain

money

to

paying

amused

and

continue

to

stick with a person whom he considers as an

adversary

.This

statements

blow

are

hot

also

and

an

blow

cold

evidence

of

deliberate misrepresentation of facts

with

dishonest intent.
It

is

submitted

that

accused

no

in

tandem with accused no 1 and facilitated

by

accused

damaging

no

the

restraining
(landlord)

started

property
the

and

mischief

,intimidation

Complainant's
also

by
&

father

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 ...................
The conduct of the accused persons
cooking up false and malicious
disseminating

false

and

i.e.

stories,
fabricated

information aided by the fabrication of

forged govt identity documents
of harassment and

, conduct

intimidation , conduct
12

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

submitted
persons

.It

that

is

the

show

also

acts

that

very

of

they

the

are

humbly
accused

seasoned

criminals.
It

is

also

imperative

to

mention

that

during civil litigation which was filed by

the

plaintiff

father

in

the

court

of

ADJ(NW-3),

Sh. Satish Kumar Rohini Courts

false

all

pleas

contentions of the accused

by

the

lordship

complainant

and

father

was

and

frivolous

were dismissed
the
decreed

suit

of

in

his

favor on 28/04/2014.On that very date of

judgment the accused deliberately remained
absent.In

insistence
23/05/2014

appearance

next

of
,

his

the

upon

lordship

accused

on

the
date

made

submission to vacate the demised premises

not

later

than

26/08/2014

and

the

submission is PEx no
The

reason of attempt to implicate the

complainant can also be adjudged from the

very fact that after aforesaid submission
13

to the honorable court the accused no 1

and

started

frustrated

hectic

and

attempts

to

desperate

bring

and

about

police action on the complainant . At the

instance

of

accused

complainant

was

station

7th

on

2014.There the

no

summoned
8th

9th

and
to

10th

the

11th

the

police
of

July

accused no 1 and 2 used to

say the following lines hum khali to kar

denge

magar

chitthiyon

ka

kya

hoga.Accused no 2 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 aware of new provisions of criminal
law

amendment

act

2014,

conviction can be held

wherein

on the account of

the oral testimony of a lady complaining

of certain acts .The exploitation of the
opportunity created because of unfortunate
NIRBHAYA

incident

also

pin

points

complicity of accused no.3. Also

on

to
day

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

within

the

gated
14

premises

Exibit

No.

..........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

complainants

family

allegation

tempering

of

but/also
of

at

the

new

electricity

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

As soon as the landlord realized 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
This very conduct of accused no 2 leaves
no doubt that it is the accused no 1 and 2
who

destroyed

circumstantial

property

evidences

and

made

deliberately

so

as to cause legal injury and loss to the

landlord

who

was

otherwise

neither

interested in extending their tenancy nor

submitting to their unlawful demands and
threats . It is also submitted that at
that

time

of

this

incident

apart

from
15

accused

no

&

no

third

person

was

residing in the demised premises.

16.

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

the

accused persons knew what that they are

up-to and clearly intend to take benefit
of their dishonesty.
17.

At the time of payments of dues also he

said that he wants compromise .Therefore
he is admitting to being a perpetrator to
gain(compromise)

by

acts

thereafter

by

himself

committing

implicate

complainant

settlement

through

intending

so

barter

certain

that

system

to

some
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

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.

18. It is also submitted that the
complainant

through

his

counsel
16

has

come to know

accused no 1

that
and 2

had

also filed against him a

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 3 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 ravi (complainant here)
for non cognizable
offenses(compoundable ).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.
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

17

of crimes against women and all three

accused joined hands just only to defraud
and harass the authorities and 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
which

they intend to be

used in judicial

proceedings and such acts are being

continued till this date. Through their
conduct they have seriously undermined the
value and importance of not only executive
& judiciary but also womanhood as a 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 .

The cause of action arose as on dated

02/03/2015, the accused no 1 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 .
18

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 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 a reference was also made
about HC Adarsh nagar Sh.balkrishan malik
because

once

dated13/07/2014

when

accused

restrained

no

on

complainant's

father and locked him inside his shop and

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

then made

a 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.
That

the

accused

no

&

are

continuing to harass the complainant and

his family in one way or the another by
provocation

through

anonymous
19

communication and thereby causing affray.

Ever since the accused no 1 and 2 had
vacated

they

efforts

of

haven't

given

causing

up

on

their

hindrances

and

disturbances in the peaceful enjoyment of

the property by the

complainant and in

conducting his business, so as to compel

his family to sell off their property and
get settled elsewhere . The accused no 3
and his wife always try to provoke the
complainant

by

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 .
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

transaction then it will be punished in

the same manner as if he
.Therefore it is
person

who

forged

has

has made it

humbly submitted that a

the

government

audacity

to

prepare

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

situation is portraying something else on

reel and

that is unbecoming the officer

20

of the court .
Mo

rover

all

these

offenses

were

perpetrated by accused no 1 and 2 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

activities

of

to

take

accused

an

edge.

,2

and

The

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
zeal

with

which

pursuing

their

supported

by

imagined

evidences

applicant

clearly

respondents

that

or

it

fabricating

in

his

is

are

grievances

delibrately

incriminatory
either

the

obsessive

the

name

father
a

of

shows

preconspired

tactical ploy to blackmail the applicant's

family

for

some

unjust

materialistic

gain . It is submitted that such 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
this

the

complainant

property

right

father
from

is
1978

owing
and

virtually each and every third person can

21

vouch for his truthfulness and peaceful

nature. Time and again the applicant and
his father echoed their grievances but the
police

instead

of

defaulters/offenders
discourage

them

or

booking

tend

to

sometimes

the
either

intimidate

them as it is the general perception of

the society

to blame landlord in such

situations.
On inquiry the complainant comes to know
that the voter id card which was shown in
original to the complainant & his

father

and whose photocopy given by accused no 1

for police verification at time of taking
tenancy duly submitted to PS Adarsh Nagar
on

date

26/03/2010

is

forged/false

document .The registration number of the

above mentioned voter id card is actually
issued in the name of a women namely ANITA
DEVI from the state of district Navalgarh
Rajasthan of which the accused no 1 and 2
are natives/aborigines. This corroborated
by

Pex.......(ECI

database

correct

registered

voter

accused

no

also

is

internet).The
id
in

card

of

different

name/identity. Ex.No. ....... voter list

Delhi assembly elections 2015 Page no... .
Also

accused

signatures

of

no

managed

complainant

to

father

get
on

application for voter id and there she has

22

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
proved

criminals.
during

the

Even

the

NIA

has

investigations

of

terror attacks that terrorists retort to

acquire multiple identities to escape from
the eyes of law enforcement agencies for
perpetrating

heinous

crimes

like

bomb

blasts & hawala activities.

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 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
23

moreover

such

acts

are

prejudicial

not

just to one individual(complainant) but to

the whole society.
It is submitted that the complainant has
already

given

his

complaint

to

the

Adarsh Nagar dated :

PS

(Copy

enclosed as Pex.No. Also 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.
reply was received
reminder

initially

reply

to

the

No
and after
same

was

received on date ...... PEx.No. Which was

non satisfactory so

a rejoinder to the

same was sent on ..PEx.No. (copy enclosed

) .From that day onwards the complainant
is yet to see/hear a suitable reply w.r.t
his complaint either from the CEO Delhi
office or from Delhi Police. Also it is
pertinent to mention here that as per the
notification

no

......................issued

by

ministry

mandatory

of

home

affairs

the

SOP's were recommended to be complied with

for

the

agencies

transactions

of

the

courier

.These guidelines are meant to

be a fool-proof mechanism for identifying

and authenticating the identities of all
the individuals

who seek to use their

24

services for sending their communications

&

parcels

&

destinations

goods
and

to

as

different

such

if

these

mandatory SOP's are followed religiously

in letter and spirit , no offender would
be

able

to

unlawful
for

post

such

articles

by

facilitating

activities

incriminatory
staying

his/her

Since

the

and

anonymous
anti-social

incriminatory

messages are continuing to be sent to the

society & police with impunity until this
day

shows

clearly

that

these

courier

agencies are not complying with the terms

of

the

guidelines

of

MHA

as

per

notification
no................................Such

conduct of these service providers and law

enforcement agencies is bound to create a
wide

lacuna

terrorists

which

for

can

be

anti-national

used

by

activities

and that will prove to be fatal to the

interest

of

integrity

of

Therefore
remedy

the

society

our

the

and

nation

applicant

but to seek

has

to

at

the

large.

no

other

intervention of

the

Hon'ble Lordship so as to get justice .

PRAYER :
It is, therefore, most respectfully prayed
that this Honorable court may kindly be
pleased to direct the police to register
FIR

against

the

accused

persons

and
25

initiate proceedings before sessions court

to try and

punish them according to 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
28/45 , Punjabi Bagh
New Delhi-26

26

IN THE COURT OF CHIEF METROPOLITAN

MAGISTRATE (NORTHWEST)ROHINI COURTS
DELHI
C.C NO........../2015
IN THE MATTER OF :

PS: Adarsh Nagar

RAVI BHATEJA

APPLICANT

V/S
1.VISHNU KUMAR BHARTYA

Respondents/

2.VINITA BHARTYA

proposed accused

3.RAJESH KUMAR MISHRA

AFFIDAVIATE
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:1.That I am the applicant/complainant in

the

above

and

matter

aware

of

the

facts

competent to depose the present affidavit.

2.I

have drafted the plaint by myself taking

references

from

whatever

legal

resources/information that are accessible to

me.
3.That

have

read

the

accompanying
27

application

and

the

same

have

also

been

understood by me.
4.That

the

contents

of

accompanying

application and documents attached along with

are true to my knowledge.
5.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

28

29