IN THE COURT OF CHIEF METROPOLITAN MAGISTRATE,

DWARKA COURTS, NEW DELHI

IN THE MATTER OF:

SH. RAMANUJ SHARMA

S/O LATE SH. MEDNI SHARMA
R/O C/O WINDER SINGH,
E-5/597 (NEAR DADA BHAIYA CHOWK),
MAHIPALPUR VILLAGE,
NEW DELHI ….COMPLAINANT

VERSUS

1. SH. RANBIR SINGH

S/O SH UDAY SINGH
R/O RZ-19, PART-III,
JAIN COLONY, UTTAM NAGAR,
NEW DELHI-110059

2. SH. PREM SINGH

S/O SH. RAMPAL,
R/O A-121, BHAGWATI GARDEN EXTN.,
HASTSAL VILLAGE,
NEW DELHI-110059

ALSO AT:
SHIV GORAKHNATH PROPERTY,
MOHAN GARDEN,
NEAR ADITYA PUBLIC SCHOOL,
NEW DELHI-110059

3. SH. SHIV KUMAR YADAV

S/O SH. BHOLA YADAV
R/O C-181, PATEL GARDEN,
UTTAM NAGAR,
NEW DELHI-110059 …..ACCUSED PERSONS

P.S.: BABA HARIDAS NAGAR

COMPLAINT UNDER SECTION 200 Cr.P.C. FOR TAKING

COGNIZANCE AGAINST THE ABOVE SAID ACCUSED PERSONS
U/S 120B/403/406/420/423/477/506/34 IPC

MOST RESPECTFULLY SHOWETH:

1. That the complainant is a retired Army man and

residing on the above mentioned address i.e.

 C/o Winder Singh, E-5/597, (Near Dada Bhaiya

Chowk), Mahipalpur Village, New Delhi and is a

law abiding and peace loving citizen of India.

2. That the complainant was in possession of a

piece of land i.e. 50 Sq. Yards in Sainik

Enclave, Phase-III, Mohan Garden, New Delhi-

110059 which was got sold on the instigation

of Prem Singh and Shiv Kumar Yadav who are the

accused No.2 & 3 in the present case, in the

year 2008 for Rs.4,00,000/- (Rupees Four Lacs

Only), out of which complainant received only

Rs.3,00,000/- and balance of Rs.1,00,000/- was

assured by the accused No.2 to be paid within

one month. On the assurance of the accused

No.2, complainant signed all relevant papers

relating to the above mentioned property.

3. That when the complainant after one month

visited to the Office of the accused No.2 i.e.

Gorakhnath Property, Near Aditya Public

School, Sainik Enclave, Mohan Garden, New

Delhi-110059 then accused No.2 said that he

has no money and he requested for some more

time (i.e. another three months time) to

 arrange it. The complainant have no option

other than to agree on his request and to wait

for another three months.

4. That the accused No.2 called the complainant

in the month of January 2009 and informed him

that as the accused No.2 was unable to arrange

the amount of Rs.1,00,000/- but accused No.2

can get him a plot of 50 Sq. Yards i.e. a

Residential plot and the complainant balance

money will be adjusted in the same. Again the

complainant was called in the month of

February 2009 and shown a piece of land of 50

Sq. Yards in a big field and told that this

plot will also cost Rs.4 lacs only and this

field has been purchased by one builder to

develop a colony with all facilities i.e.

School, garden, market etc., seeing no other

option the complainant agreed to purchase the

said piece of land/plot.

5. That the accused No.2 asked the complainant to

bring Rs.3,00,000/- in Sub-Registrar Office,

Janakpuri, New Delhi on 06.04.2009 and

introduced the owner of the plot Mr. Ranbir

 Singh and in front of him the accused No.2 & 3

taken Rs.3,00,000/- in cash and on instruction

of the above accused, the accused No.1 i.e.

Mr. Ranbir Singh executed the papers of 50 Sq.

Yards of Plot bearing No.83, out of Khasra No.

61/11/12, situated in the area of Village

Jharoda Kalan, colony known as Jharoda Kalan

Extn, New Delhi i.e. residential plot in the

Office of Sub-Registrar Office, Janakpuri, New

Delhi and the accused No.2 & 3 become witness

in the above deal.

6. That the accused No.2 again asked the

complainant to give Rs.15,000/- in the month

of August 2009 for the boundary of the

complainant plot, so it can be clearly

identified by the complainant in big field.

The amount of Rs.15,000/- was paid by the

complainant in the month of October 2009. But

when the complainant visited on his plot in

the month of December 2009, the complainant

could not find any boundary of his plot i.e.

50 Sq. Yards in that field. When same was

informed to the accused No.2 and asked for

boundary, the accused No.2 replied that due to

 busy schedule he was unable to complete the

same but will be done in next two months.

7. That when the complainant visited the office

of the accused No.2 in the month of March 2010

and asked for original papers of the said

plot/property as well as about the

construction of boundary wall, the accused

No.2 again asked for Rs.25,000/- from the

complainant to provide him original papers of

the above said plot and also informed that

without the payment of Rs.25,000/- boundary

cannot be done over the said plot. The

complainant paid Rs.25,000/- and taken the

original papers of the said plot in the month

of October 2010 and again it was assured by

the accused No.2 that the construction of the

boundary of plot will be made very soon.

8. That the accused No.2 called the complainant

suddenly in the month of November 2010 and

informed that the accused No.1 i.e. the owner

of the said plot Mr. Ranbir Singh is not

allowing the accused No.2 to construct

boundary over the said plot as there is some

 dispute arises between them, but the accused

No.2 same time assured the complainant that

either he will get another good residential

plot very soon or he will be compensated for

that. One day the accused No.2 informed the

complainant that he has booked a plot in

Haryana and very soon all the relevant papers

of the above said plot will be executed on the

name of the complainant or anyone else as per

the desire of the complainant.

9. That when the complainant ever tried to

contact and meet to the accused No.2 in his

office or telephonically, he could not succeed

to contact him as always replied by accused

was out of station or either in his village.

When the complainant tried to meet the accused

No.3, he replied that the complainant matter

will be solved by the accused No.1 to 3 so he

should wait for the accused No.2 to return

back.

10. That the complainant lastly met to the accused

persons No.2 & 3 in the month of April 2011

and requested them either to return back his

 money or to give possession of a plot as

assured by them but the accused No.2 informed

the complainant that the mother of the owner

of the plot suddenly expired therefore, need

time till the end of June 2011.

11. That one day the accused No.2 & 3 visited the

house of the complainant in the month of July

2011 and asked two photographs of his younger

daughter in law Ms Usha Sharma W/o Nirbhay

Kumar Sharma and asked further Rs.10,000/- to

purchase stamp papers for the plot and

photographs required to transfer the property

on the name of Ms. Usha Sharma. The

complainant had given two photographs of his

daughter-in-law alongwith Rs.10,000/- to the

accused No.2 and the accused No.2 take

guarantee that all the relevant papers will be

executed on 3rd November 2011.

12. That when the complainant gone to the office

of the accused No.2 on the given date, the

complainant was unable to find the accused

No.2 and on telephonic all the complainant was

informed that this deal is also cancelled by

 the owner of the plot so this plot cannot be

arranged for the complainant and both the

accused persons i.e. the accused No.2 & 3

assured that they will get him 50 Sq. Yards

plot in Mohan Garden itself or compensate the

complainant with his entire money within 3

months.

13. That the complainant had gone several times to

the accused No.2 & 3 and asked about his plot

or money, they always avoided the complainant

on one pretext or the other and given new

dates to the complainant. On 16.06.2012 when

the complainant visited to the office of the

accused No.2 and asked for his money or plot,

the complainant was clearly refused to give

anything and told that if the complainant

again will be seen near to his office, he will

be no more and if complainant tried to report

this matter to police or anyone else, then

complainant’s whole family will be kidnapped

and thrown after murder to some isolated place

from where no one can trace them.

14. That finding no other way out at last the

complainant gone to Police Station Najafgarh

to file his complaint but the police officials

of P.S. Najafgarh refused to take the

complaint and advised the complainant to file

the said complaint in P.S. Vasant Kunj and

after that the complainant gave a written

complaint to the police station Vasant Kunj on

18.07.2012 and other various police

authorities against the fraud committed by the

above said accused persons but after visiting

so many times to the police authorities, no

action was initiated against the accused

persons till date and now the complainant

would left with no other alternative except to

approach the Hon’ble court.

15. That the complainant filed another complaint

in the Hon’ble court of Dwarka under P.S.

Najafgarh but complainant came to know through

status report submitted by SHO, Najafgarh that

the suit property of the complainant falls

under P.S. Baba Haridas Nagar, therefore,

complainant has withdrawn his complaint to

file under the jurisdiction of the competent

 court. The complainant has filed another

complaint within the jurisdiction of P.S. Baba

Haridas Nagar but the same premature and was

dismissed as withdrawn.

16. That the complainant has given a complaint to

S.H.O. Baba Haridas Nagar on 05.10.2012

regarding above said matter but after several

visits of complainant no action was initiated

by P.S. Baba Haridas Nagar. Complainant filed

an application to the various police officials

on 25.10.2012 for issuing a direction to SHO,

P.S. Baba Haridas Nagar to lodge an FIR

against the above mentioned accused but after

that also no action is initiated till date.

Complainant left with no other option except

to approach the Hon’ble court.

17. That the complainant has not filed any

same/similar complaint against the accused

persons in any court of law in India except

the present complaint.

PRAYER:

It is, therefore, most humbly prayed that

this Hon’ble court may kindly be pleased to

 direct the police of P.S. Baba Haridas Nagar,

New Delhi to register an FIR against the

accused persons, investigate the matter, book

the culprits and provide necessary protection

to the complainant and his family, in the

interest of justice.

Any further relief (s)/direction(s) which

this Hon’ble court deem fit and proper to the

facts and circumstances of the present

complaint, in the interest of justice.

COMPLAINANT

DELHI
DATED:05.12.2012 THROUGH

(SUNIL SINGH)
ADVOCATE
CH NO.850, LAWYER’S CHAMBER,
DWARKA DISTRICT COURTS,
NEW DELHI
 IN THE COURT OF CHIEF METROPOLITAN MAGISTRATE,
DWARKA COURTS, NEW DELHI

IN THE MATTER OF:

SH. RAMANUJ SHARMA ….COMPLAINANT

VERSUS

SH. RANBIR SINGH & ORS. …..ACCUSED PERSONS

AFFIDAVIT

I, RAMANUJ SHARMA S/O LATE SH. MEDNI

SHARMA R/O C/O WINDER SINGH, E-5/597 (NEAR

DADA BHAIYA CHOWK), MAHIPALPUR VILLAGE, NEW

DELHI, do hereby solemnly affirm and declare

as under:

1. That I am the complainant in the complaint and

well conversant with the facts and

circumstances of the present complaint and as

such fully competent to swear this affidavit.

2. That the accompanying complaint U/s 200

Cr.P.C. has been drafted by my counsel under

my instructions and the contents of the

accompanying complaint are read over to me and

the same are understood by me which are true

and correct to the best of my knowledge. The

 contents of the same are part and parcel of

this affidavit and are not being reproduced

herein for the sake of brevity.

Deponent
Verification:

Verified at New Delhi on this 5 th day of

December 2012, 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 CHIEF METROPOLITAN MAGISTRATE,
DWARKA COURTS, NEW DELHI

IN THE MATTER OF:

SH. RAMANUJ SHARMA ….COMPLAINANT

VERSUS

SH. RANBIR SINGH & ORS. …..ACCUSED PERSONS

AFFIDAVIT

I, RAMANUJ SHARMA S/O LATE SH. MEDNI

SHARMA R/O C/O WINDER SINGH, E-5/597 (NEAR

DADA BHAIYA CHOWK), MAHIPALPUR VILLAGE, NEW

DELHI, do hereby solemnly affirm and declare

as under:

1. That I am the complainant in the complaint and

well conversant with the facts and

circumstances of the present complaint and as

such fully competent to swear this affidavit.

2. That the accompanying Application U/s 156(3)

Cr.P.C. has been drafted by my counsel under

my instructions and the contents of the

accompanying complaint are read over to me and

the same are understood by me which are true

and correct to the best of my knowledge. The

 contents of the same are part and parcel of

this affidavit and are not being reproduced

herein for the sake of brevity.

Deponent
Verification:

Verified at New Delhi on this 5 th day of

December 2012, 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 CHIEF METROPOLITAN MAGISTRATE, DWARKA
COURTS, NEW DELHI

IN THE MATTER OF:

SH. RAMANUJ SHARMA ….COMPLAINANT

VERSUS

SH. RANBIR SINGH & ORS. …..ACCUSED PERSONS

MEMO OF PARTIES

SH. RAMANUJ SHARMA

S/O LATE SH. MEDNI SHARMA
R/O C/O WINDER SINGH,
E-5/597 (NEAR DADA BHAIYA CHOWK),
MAHIPALPUR VILLAGE,
NEW DELHI ….COMPLAINANT

VERSUS

1. SH. RANBIR SINGH

S/O SH UDAY SINGH
R/O RZ-19, PART-III,
JAIN COLONY, UTTAM NAGAR,
NEW DELHI-110059

2. SH. PREM SINGH

S/O SH. RAMPAL,
R/O A-121, BHAGWATI GARDEN EXTN.,
HASTSAL VILLAGE,
NEW DELHI-110059

ALSO AT:
SHIV GORAKHNATH PROPERTY,
MOHAN GARDEN,
NEAR ADITYA PUBLIC SCHOOL,
NEW DELHI-110059

3. SH. SHIV KUMAR YADAV

S/O SH. BHOLA YADAV
R/O C-181, PATEL GARDEN,
UTTAM NAGAR,
NEW DELHI-110059 …..ACCUSED PERSONS

..COMPLAINANT
DELHI
DATED:05.12.2012 THROUGH
(SUNIL SINGH)
ADVOCATE
CH NO.850, LAWYER’S CHAMBER,
DWARKA DISTRICT COURTS,
NEW DELHI
 IN THE COURT OF CHIEF METROPOLITAN MAGISTRATE,
DWARKA COURTS, NEW DELHI

IN THE MATTER OF:

SH. RAMANUJ SHARMA ….COMPLAINANT

VERSUS

SH. RANBIR SINGH & ORS. …..ACCUSED PERSONS

INDEX

S.NO. PARTICULARS PAGES C.FEE

1. MEMO OF PARTIES

2. COMPLAINT U/S 200 Cr.P.C.

ALONGWITH AFFIDAVIT.

3. APPLICATION U/S 156(3) Cr.P.C.

ALONGWITH AFFIDAVIT.

4. LIST OF DOCUMENTS
ALONGWITH DOCUMENTS.

5. VAKALATNAMA.

COMPLAINANT

DELHI
DATED:05.12.2012 THROUGH

(SUNIL SINGH)
ADVOCATE
CH NO.850, LAWYER’S CHAMBER,
DWARKA DISTRICT COURTS,
NEW DELHI
 IN THE COURT OF CHIEF METROPOLITAN MAGISTRATE,
DWARKA COURTS, NEW DELHI

IN THE MATTER OF:

SH. RAMANUJ SHARMA ….COMPLAINANT

VERSUS

SH. RANBIR SINGH & ORS. …..ACCUSED PERSONS

APPLICATION UNDER SECTION 156(3) Cr.P.C. FOR

DIRECTION TO THE SHO TO REGISTER THE CASE
AGAINST THE ACCUSED PERSONS U/S
120B/403/406/420/423/477/506/34 IPC OR ANY
OTHER RELEVANT SECTIONS AS PER LAW

MOST RESPECTFULLY SHOWETH:

1. That the complainant has filed the complaint

case under Section 200 Cr.P.C. against the
accused persons for commission of offence U/S
120B/403/406/420/423/477/506/34 IPC or any
other relevant sections as per law, the
contents of which may be read as part and
parcel of this application as the same are not
being repeated herein for the sake of brevity.

2. That the accused persons have illegally and

unlawfully grab the hard earned money of the
complainant fraudulently and are now
continuously giving threats to the complainant
as the complainant is living under the
apprehension and fear at the hands of the
accused persons and are continuously giving
threats to the complainant and his family
members for dire consequences.
3. That when the complainant visited and inform
through complaint to the various police
authorities, they have failed and neglected to
take any action against the accused persons so
far.

PRAYER:

In view of the above facts and

circumstances, it is, therefore prayed that
this Hon’ble Court may graciously be pleased
to direct the concerned SHO of P.S. Baba
Haridas Nagar, New Delhi to investigate the
matter properly and thereafter book the
accused persons under the appropriate
provisions of law by registering the case
against the accused person, resulting in
peaceful living of the applicant as well as to
return his plot or compensate him in lieu of
money.

Any such other order which this Hon’ble

court may deem fit and proper be passed in
favour of the complainant and against the
accused persons.

COMPLAINANT

DELHI
DATED:05.12.2012 THROUGH

(SUNIL SINGH)
ADVOCATE
CH NO.850, LAWYER’S CHAMBER,
DWARKA DISTRICT COURTS,
NEW DELHI
 IN THE COURT OF CHIEF METROPOLITAN MAGISTRATE,
DWARKA COURTS, NEW DELHI

IN THE MATTER OF:

SMT. SUSHMA RANI ….COMPLAINANT

VERSUS

SMT POONAM & ANR. …..ACCUSED PERSONS

MEMO OF PARTIES

SMT. SUSHMA RANI

W/O SH. JEEWAN PRAKASH
R/O H.NO.2085, KATRA GOKUL SHAH
SITA RAM BAZAR,
DELHI-110006 ….COMPLAINANT

VERSUS

1. SMT. POONAM
W/O SH. DEVENDER KUMAR

2. SH. DEVENDER KUMAR

S/O SH. BRAHAM SINGH

BOTH R/O A-89, JEEWAN PARK,

BLOCK-A, UTTAM NAGAR,
NEW DELHI-110059 …..ACCUSED PERSONS

COMPLAINANT

DELHI
DATED:21.03.2015 THROUGH

(SUNIL SINGH)
ADVOCATE
CH NO.850, LAWYER’S CHAMBER,
DWARKA DISTRICT COURTS,
NEW DELHI
 IN THE COURT OF CHIEF METROPOLITAN MAGISTRATE,
DWARKA COURTS, NEW DELHI

IN THE MATTER OF:

SMT. SUSHMA RANI ….COMPLAINANT

VERSUS

SMT POONAM & ANR. …..ACCUSED PERSONS

INDEX

S.NO. PARTICULARS PAGES C.FEE

1. MEMO OF PARTIES

2. COMPLAINT U/S 200 Cr.P.C.

ALONGWITH AFFIDAVIT.

3. APPLICATION U/S 156(3) Cr.P.C.

ALONGWITH AFFIDAVIT.

4. LIST OF DOCUMENTS
ALONGWITH DOCUMENTS.

5. VAKALATNAMA.

COMPLAINANT

DELHI
DATED:21.03.2015 THROUGH

(SUNIL SINGH)
ADVOCATE
CH NO.850, LAWYER’S CHAMBER,
DWARKA DISTRICT COURTS,
NEW DELHI