THE POLICE COMMISSIONER OF DELHI,
AND SPECIAL C.P/ JOINT C.P/ Addl. CP OF DELHI,
AND CONCERNED D.C.P /ACP OF DELHI,
S.36 Cr.P.C JURISDICTION:-
THE Station House officer,
And Duty Police Officers,
THANA SHAKARPUR P.S, DELHI
Article 350 of The Constitution of India 1949.
FIR 154(1, 3) Cr.PC -Read With- Sec 7, 13, of IT ACT 2000.
Read with- Sec 29A IPC -Read with- Sec 88A Indian Evidence Act.
Delhi Police Act 1978 and S. 36 Cr.P.C
APPLIED ComMission of CONTINUING Offences SINCES Incident EVERY DAY Whole DECEMBER 2016 and Before DECEMBER 2016:-
Sections 34, 35, 37, 38, 109, 120B, 149, 294, 323, 339, 341, 384, 406, 427, 427, 500, 506, 507, 511 IPC and Sec 66, 66D of the I.T ACT 2000.
P.S:- SHAKARPUR, DELHI.
Tanver Ashraf SHO:- 8750870627.
Mr. KK Agarwal Advocate [C/o Smt Aparana Goel W/o Ghanshyam], WA 24B, First Floor, Near Modern Happy School, Mb:- 09910362303, 09319365499, 09675730306, Delhi …….Complainant/Aggrieved Person.
1 (One). Mahinder Kumar Sharma S/o C.R.SHARMA , WA-20, Shakarpur Khas, Near Anil Kumar Gutpa WA29 Property and Pani Wala, Near Rajesh Bhel WA26/B (twenty Six upon B)Property Dealer, Gali No.15 (hereinafter referred as everywhere fifteen) Gurdawra Road, Lakshminagar – 110092 , Delhi. Age 68 Age Approx. Mobile:- 9313105603
2 (Two). Manish Sharma(Alias Tinku) S/o Mahinder Kumar, WA-19, Shakarpur Khas, Near Anil Kumar Gutpa WA29 Property and Pani Wala, Near Rajesh Bhel WA26/B Property Dealer, Gali No.15 Gurdawra Road, Lakshminagar – 110092 , Delhi. Age 37 Approx. Mobile:- 9312135785
3 (Three). Sharmila Verma ‘Wife of’ Naresh Kumar Verma (both Accomplices), WA-25, Shakarpur Khas, Near Anil Kumar Gutpa WA29 Property and Pani Wala, Near Rajesh Bhel WA26/B Property Dealer, Gali No.15 Gurdawra Road, Lakshminagar – 110092, Delhi. Age 50 Approx. Mobile:- 8860196459
4 (Four). Samay Singh S/o Bhagwana, WA-24B, Shakarpur Khas, Near Anil Kumar Gutpa WA29 Property and Pani Wala, Near Rajesh Bhel WA26/B Property Dealer, Gali No.15 Gurdawra Road, Lakshminagar – 110092 , Delhi. Age 42 (forty two) -50 approx. Mobile:- 9999862466.
5 (Five). Umesh Singh S/o Samay Singh, WA-24B, Shakarpur Khas, Near Anil Kumar Gutpa WA29 Property and Pani Wala, Near Rajesh Bhel WA26/B Property Dealer, Gali No.15 Gurdawra Road, Lakshminagar – 110092 , Delhi. Age 26 Approx.
6 (Six). Satya Sharma ‘Wife of’ Mahinder Kumar, WA-20, Shakarpur Khas, Near Anil Kumar Gutpa WA29 Property and Pani Wala, Near Rajesh Bhel WA26/B Property Dealer, Gali No.15 Gurdawra Road, Lakshminagar – 110092 , Delhi. Age 60 Approx.
7 (Seven). Nirmal ‘Wife of’ Umesh Singh, WA-24B, Shakarpur Khas, Near Anil Kumar Gutpa WA29 Property and Pani Wala, Near Rajesh Bhel WA26/B Property Dealer, Gali No.15 Gurdawra Road, Lakshminagar – 110092 , Delhi. Age 20-25 Approx.
8 (Eight). Mangesh Thakur (Son of Sunil) ‘Husband of’ Aarti, WA-24B, Fourth Floor, Shakarpur Khas, Near Anil Kumar Gutpa WA29 Property and Pani Wala, Near Rajesh Bhel WA26/B Property Dealer, Gali No.15 Gurdawra Road, Lakshminagar – 110092, Delhi. Age 20-30 Approx.
9. (Nine). Murari S/o Bhagwana, WA 24A, , Shakarpur Khas, Near Modern happy School – 110092 , Delhi. Age 20-25 Approx.
10. (Ten). Krishna Wife of Murari, WA 24A, Shakarpur Khas, Near Modern happy School – 110092 , Delhi. Age 45-55 Approx.
11. (Eleven). Rajwati Wife of Kishori, WA 24A, Shakarpur Khas, Near Modern happy School – 110092, Delhi. Age 40-45 Approx.
12 (Twelve). 50-60 henchman and Accomplices and various offenders and Agents supporting Crime perpetrated against the Victim lonely Lady Aparana Kansal.
-------Accuseds No. One to Twelve.
All are local resident of concerned Police Station Area Shakarpur, Delhi.
MOST RESPECTFULLY SHOWETH:- Resp. Sir
It is humbly submitted before the legal Authorities and person of NCT OF DELHI:-
PARA 1:- That I KK Agarwal Advocate a practicing lawyer of Delhi, Muzaffarnagar and Saharanpur and mostly do legal work in day to day Survival of life. That I KK Agarwal has been practicing since 2008 in various Courts of Delhi to Uttar Pardesh and for this I Self in life a dire need arises of separate Flat for peace and living separately without outside people and friends or temporary get stay in Hotel in Delhi State for Client Court work. That for this I purchased a Flat in Shakarpur Khas in Lakshminagar Delhi with my hard work savings and some old useful things and accessories of household and gathered money and for rest remaining I took help of my Mosiji Aparana to contribute and had transferred on her name the Delhi Flat at Rs 30 (thirty) Lakhs in 2013 (Two thousand and Thirteen) as she is alike mother to me. That after that the above accuseds have known in living locality in some month where I and mosiji spent there that they are notorious Hardcore Criminal Mind and offender and accomplice type of Accuseds reside everywhere and through this operating gang of local area want to take control on the purchased property premises of Delhi for various times on any unprecedented Fight and public and Private Nuisance created to us so many times in Delhi. That soon as I know it I myself in public announced in the Local property market to sell my Flat with all the personal expenditures I spent in Rs 35 (thirty Five) Lakhs fixed to sell property. That since before and after that I have only legal profession I use for my livelihood I mostly have to travel In Between Delhi to Uttar Pardesh for any Client cases come in between these regions. That For selling the Flat my Mosiji sometimes lives alone In Flat Delhi and contact to property Dealers for Sale but in Delhi there is so much uncertainty in market that some-times property market may get slow and dull, sometimes Delhi Elections came, some Registry closed and mostly times the above Defendants spread false rumors that the Flat is of Rs 25 (twenty) Lakhs etc and various others come and that why Flat was not sold till yet in confusion in between buyers to come.
PARA 2 (two):- That the main Cause of actions and continuing offences are that several times since in limine where Accuseds mostly have violated my legal rights and my mosiji here and that make a preplanned fight and Criminal activities against us that living here in Muzaffarnagar and in Delhi sometimes, make me and my mosiji very tough that I cannot do my legal practice for Clients daily and that why sometimes I ran to Delhi and Stay there for stopping their Criminal activities and sometimes I may ran here in Muzaffarnagar for the pending work of clients to start off and pending cases to be heard. That due to this in last Four years I suffered a heavy loss of Rs 25 (twenty Five) Lakhs in all expenditures and my legal and personal life get disturbed due to Public and private Nuisances by the Accuseds against me and my mosiji Aparana kansal. That every time when I or She addresses a complaint to police thru 100 Dialed came they say they have no power to arrest and prevent the Crime and both the party go to Shakarpur Police Station. That when I or She alone goes to Shakarpur Police Station the Accuseds take all the 50-60 people gathered in their support to Shakarpur Police Station and may pressurize to take against on her. That in this situation the One lady Voice Aparana was suppressed in the Voice of 50-60 people and the local police make an illegal case of Sec 107/150 Crpc directed towards SDM Krishanagar Delhi where after six months date the SDM says that they have no power to give punishment to Accuseds here and only take surety bond and discharge the above accuseds. That due to this the Accuseds again started off same and more aggressive Criminal activities against the lonely lady Aparana and make her tough to live alone in the Flat she has power to hold and live with dignity and proud. That due to that again the same Continuing Offences one after another will be perpetrated against the said lady Aparana and compel her to leave the Flat and not to stay with me or her alone. That for the legal lengthy process the man or woman has to take help of Court but it would not also be possible as when people not get stay rights with safety and security and Survival food, Sleep and peace then how I and she can fight legal battle by sitting inside Delhi.
That recently on dated 12-12-2016 (Twelve-Twelve- Two thousand Sixteen) the Accuseds make preplanned assault and battery, Criminal Intimidation, Abusive Torture language and Mischief on movable and immovable property that for this I have to again leave my legal client work and again gone to Delhi and stay there three days for this problem. Several Complaints made to 100(Hundred) Control Room Delhi Police and to the Concerned ShakarPur Police Station but none relief I get which may bring some relief to us. As I was come on 17 (Seventeen) -December-2016 (hereinafter referred as Two Thousand Sixteen) again in my absence the same Accuseds started off Assault and battery on my Mosiji and my Flat and again I have to make legal complaint addressed to Delhi Police and Registry Complaint from Muzaffarnagar sent to the SHO of Shakarpur Police Station for getting some relief but none preventive action were taken till today against the Said Defendants. That the Officials Complaint were also told to ACP and to DSP and SHO on WhatApp as they not patiently want to listen on phone, but non preventive action taken against the said Accuseds and Also Email the official Complaint to the Official Email Addresses of Commissioner of Delhi and to various Police Authorities of NCT of DELHI but no result I get till today. That due to this I have lost personal savings money and valuable earning time and number of days of precious time on these tort, mischief, hurt, Criminal Intimidation, Public and Private Nuisance and Defamation problems that why I get Rs 25(twenty Five Lakhs) Losses had suffered till today estimated in total. That I am living here and all the physical tort problems I am getting Suffered here and my money and my clients all are losing here and that why this NCT of DELHI has power and immense jurisdiction to provide all the legal remedies to me according to the Rules of law related to the Movable Property under above Rules of law grant against the Accuseds. That I have many Video recordings of the above Accuseds who they are behaving to me and my mosiji in public in the land of laws. That the accuseds gave thousand abuses to me of father and mother and to my mosiji on Phone that it is very hard to listen to them and may respond on this vulgarity against me and my mosiji. That the accuseds also day by day destroying my reputation my making online false status but before the electronic media on Internet and my phone numbers that which is a Crime under IT Act 2000. That the accuseds called my mosiji a prostitute and I have wrong relation with her which hurt and fired me so much inside that if I have power to severe punishment then I may do before the eyes of law for this dirty thinking and sick mind of my mother alike mosiji.
PARA 3 (Three):- That Accuseds have not afraid the Rules of enacted laws and the Court legal system and legal advocates and public servants that they openly challenged in Pubic that the Courts are blind, judges are fool, advocates are mental and the Police is eunuch of the Delhi. That this types of words and gestures in my entire living life at this age I never heard in any corner of India. That Accuseds are a black spot and free Criminal in the Indian Civilized Society that they all make my life and other life’s a living hell. That I several times complained of in Written to Delhi Police but non preventive action were taken by the State Officials till today. That the purpose of the complaint to seek legal remedies form the legal authorities which I has been bearing off since the Accuseds gave thousands of problems and tort activities to me as I am the Petitioner of this State NCT of Delhi and the resident and the legal Share holder of the Delhi property. That the Accuseds and their agents and relatives also several times comes to my Delhi Address and threatened me not to take any legal action against the Accuseds otherwise I will get killed by the local henchmen and supporters in any day. That the Accuseds also have many business and family links in East District Delhi and that why get daredevil and Stamina to lay hands on me and my Mosiji without any valid reason in between Complainant & Accuseds. The Main Objective of the Accuseds are to get encroach and forcibly take over the Delhi Property premises under their Control so that All the Accuseds get Undue Enrichment in their life and share all the illegal profits and Wrongful Gain among in between all the Defendants. That I also lost my mobile Balances Rs 20000/- (twenty thousand) since the various problems were given by the Culpable Accuseds to the Complainant and causing other inconvenience to me.
That again on dated 17 (Seventeen)-December-2016 the above Accuseds assault on my Mosiji Aparana Goel while she had addressed a complaint to SHO in evening two hours spent in Thana, Shakarpur Police Station against Accuseds and after that again in lawful assembly gathered of local 60-80 offenders preventing her to go at her Flat and ran before her to do assault and battery to her where she also ran pillar to post and after that I had dialed Hundred of Mobile calls made by me to ShakarPur Police Station and then in night on Sub- Inspector Kishanveer Bhati (8750870336) Comes and rescue her from the clutches of the Defendants at time 11 (Eleven):- 50 (fifty) PM late in night. That after that in somehow 12:00 AM in night in fear and heartbeat tickling she catches autorickshaw alone and come to Nizamudin Railway Station and may return back to another my city Muzaffarnagar in Uttar pardesh at 4:30 AM on dated 18-12-2016. The accuseds gave so much mental tension to me and to my Mosiji that for this a legal Punishment must be passed against all the said Accuseds so that some relief I get which I had lost in my life and my Mosiji. The Accuseds are habitual offenders and master in making assault and battery and Criminal Intimidations and hurt to do any one in the civilized society. That a Separate Criminal complaint also will be filed here in Muzaffarnagar to terrorize me and Mosiji while sitting at home in Muzaffarnagar and in Delhi and I get pain in my heart and in my all night and can’t sleep due to frightened incident and about my Mosiji. That the accuseds monthly on any time day to day when get time make terrorize calls to me and that why my legal work was much disturbed and my mind also get dull due to various tension I am suffering from the Side of the above accuseds. That my life and my mosiji are hanging on line and anytime the above accuseds in deep criminal conspiracy and preplanned incident kill both of us in City Muzaffarnagar or in Delhi or in between Delhi and Muzaffarnagar and that why this legal official complaint will be address to various legal fraternity brother of law and to the Higher State Authorities of State Delhi to take swift and necessary legal action may be taken against the said named accuseds. That we have Video recording also somehow took which all were prevented by the same accuseds and their agents to destroy the device of it and the local beat S.I and Staff of Shakarpur Police also restrict us to shoot the Crime Scene of Occurrence. That the Delhi Mostly Police officers of Shakarpur Police Station and Control Room Patrol Police are untrained and novice and have not police force stamina and power to prevent the Crime on Occurrence at our livings resident by the 50-60 people gathered for Vulgarity bad language to give and to do assault and battery to lady Aparana. The Local Delhi Police Public Servant like Naresh Tyagi ASI of Shakarpur Police Station also guide all the accuseds and their agents to gather your all local supports of Relatives and Friends of the Accuseds to Write many various Complaint against One Lady Aparana and arrange any two lady who can be taken with the lady Aparana and confide in the police custody of the Shakarpur. That Due to this the Accuseds and their many accomplices and agents make a more vicious deadly move carried out against one single lady my mosiji Aparana and make a full mockery and Criminal Intimidation to her till 12:00 AM in night 18-Dec-2016 at Shakarpur her Flat address. That her clothes were also taken away by the accuseds when she came on her Flat to take her belongings and the Police only two person cannot make a full control on the Crime of Occurrence on date 17-Dec-2016 since 12:00 PM to 12:00 AM in 12 hours called various police help again and again to rescue this deadly situation.
So kindly take swift legal action against above accuseds and register my official complaint in State Police records and arrest the Said offenders, agents, accomplices, accuseds and culprits and may aid in getting right justice from the legal system so that no person like me get victimized for this Criminal atrocities again in my lifetime or by any noble person in the human society get suffered due to these hardcore ciminals.
AND ALSO REQUEST:- The justice of god and messengers in this Stone heart World to take action on this complaint & may order to concerned ‘Station Officer’ of Area P.S:- “Shakarpur” to lodge/register an F.I.R U/s 154 Cr.P.C on police record, having specific FIR No in General Diary as the all above I.P.C sections explicitly mentioned and [provides a free copy of lodge FIR to complainant] provide full enquiry & investigation report of main commission of offences U/s 173 Crpc.
Dated 18-Dec-2016 Complainant:-
Mr. KK Agarwal Advocate, (First-Floor) and Aparana Kansal,
Mb:- 09910362303, 09319365499, 09675730306, 09457837919, 09917002956.
My Personal EMAIL used for Complaints Sending:- firstname.lastname@example.org
Postal Property Address:- WA-24B, Nearer to [ Anil Kumar Gupta S/o O.P Gupta (Pani & Property Wala & Rajesh Bhel Property Dealer WA26/B , Near Gali No.15 – Gurdwara Road], Shakarpur Khas,
Laxmi-nagar, East Delhi-110092. NCT OF DELHI.