FIRST INFORMATION REPORT

CIPA RI 1100 (Under section 154 Cr. P.C.)

1. District- SOUTH-WEST DELHI P.S.: Binda Pur Year- 2013 FIR

No.588 Dated- 22.11.2013

2. Act(s): Section (s)

(i) IPC 1860 323/354/509
(ii) PROTECTION OF CIVIL RIGHTS ACT, 1955 3
(iii)
(iv)

3. Occurrence of offence:

(a) Day: Wednesday Date from: 25.09.2013 Date to:25.09.2013

Time Period: Time from: 06:30 hrs. Time to:

(b) Information received at PS: Date-22.11.2013 Time- 10:35 hrs.

(c) General Diary Reference Entry No. 15A Time- 01.35 hrs.

4. Type of Information: WRITTEN

5. Place of Occurrence:

(a) Direction and distance from PS:North-West/3.0 Km. Beat No.9

(b) Address: SHIV MANDIR PH-3, SEC-3, J.J. COLONY,

DWARKA, NEW DELHI, BINDAPUR

(c) In case, outside the limit of this Police Station:

Name of P.S.

5. Complainant/informant
a. Name: SANGEETA (W/O) GYANANDER
b. Birth Year : Nationality: INDIAN
c. Passport No. Date of Issue: Place of Issue:
d. Occupation:
e. Address: B-118 SE-3, JJ COLONY, DWARKA, NEW DELHI
7 Detail of known/ suspected /unknown accused, with full

particulars: (attached separate sheet if necessary)

(i) RAJ KUMAR (S/O) LATE AMAN SINGH

R/O X H.No. 167, DHAKKA VILLAGE, DELHI
 (ii) RAJ RANI (W/O) RAJ KUMAR
R/O X H.No. 167, DHAKKA VILLAGE, DELHI
(iii)

8. Reasons for delay in reporting by the complainant/Informant. NO

DELAY
9. Particulars of properties stolen/involved (attach separate sheet if
necessary)
Sl. No. Property Type (Description) est. Values (Rs.)
status
(i)
(ii)
(iii)
10. Total value of property stolen
11. Inquest Report/U.D. case No., if any:
12.F.I.R. Contents (attach separate sheet, if

required): I, Sangeeta Verma W/o Gyanander

Verma R/o B-118, Sec-3, Phase-III, J.J.

Colony, Dwarka, New Delhi age 36 years old

M.No. 9971010508 stated that I am living

on above stated address with my family and

I am a house wife. When today early in the

morning want to Shiv Temple for worship

and started worship then Chander Prakash

who also lives in our colony came there at

the time and started using abusing

language for me and said that this temple

is out (Brahmins). You belongs to Chude

chamar community and said how dare you to

enter in the temple. C.P. Pandey hold my

 hair and evicted me in scrawling way from

the temple and he torn my suite and said

that she is prostitute and I will naked

her. C.P.Pandey threatened me that if you

will complain against them I will kill you

and your family. I am in fear that

C.P.Pandey and his relatives came any

threatened

13. Action taken since the above report

records commission of offence (s) U/s as
mentioned as item No.2.

i. Registered the case and took up the

investigation or.
ii. Directed/entrusted (Name of I.O.) Subhash
Chand Rank
No. 16080390 to take up the investigation
OR
iii. Refused investigation due to. OR
iv. Transferred to P.S. District
On point of jurisdiction.

F.I.R. Record over to the complainant/

informant, admitted to be correctly
records and copy given to this
complainant/informant free of cost.

R.O.A.C. Signature of officer

Name
Rank
14. Signature/Thumb impression of the
complainant/informant.

15. Date and time of dispatch to Court by DAK.

 Any other or further relief/directions

which this Hon’ble Court may deem fit and

proper in the facts and circumstances of

the case in favour of the petitioner, in

the interest of justice.

PETITIONER
THROUGH
DELHI
DATED:

COUNSEL
 PAWAN SHARMA & ASSOCIATES
ADVOCATES
CH. NO. 492A, WESTERN WING,
TIS HAZARI COURTS, DELHI-54

are accepted by me as true and correct

and the same are not being reproduced

here for the sake brevity and the same

may please be read as an integral part of

this affidavit.
3. That the petitioner has not filed any

other petition either before this Hon’ble

Court or before the Hon’ble Supreme Court

of India for grant of same or similar

relief.

DEPONENT

VERIFICATION:-
Verified at Delhi on 2016, that the

contents of my above affidavit are true

and correct to the best of my knowledge

and belief and nothing has been concealed

therefrom.

DEPONENT
 Any other or further relief/directions

which this Hon’ble Court may deem fit and

proper in the facts and circumstances of

the case in favour of the applicant/

petitioner, in the interest of justice.

APPLICANT/PETITIONER
DELHI
DATED:
THROUGH
PAWAN SHARMA & ASSOCIATES
ADVOCATES
CH. NO. 492A, WESTERN WING,
TIS HAZARI COURTS, DELHI-54
 are accepted by me as true and correct

and the same are not being reproduced

here for the sake brevity and the same

may please be read as an integral part of

this affidavit.

DEPONENT

VERIFICATION:-
Verified at Delhi on 2016, that the

contents of my above affidavit are true

and correct to the best of my knowledge

and belief and nothing has been concealed

therefrom.

DEPONENT
IN THE HON’BLE HIGH COURT OF DELHI AT NEW DELHI

BAIL APPLICATION NO.__________OF 2014

IN THE MATTER OF:

RAJ RANI ...PETITIONER

VERSUS
THE STATE ... RESPONDENT

MEMO OF PARTIES

RAJ RANI

W/o SH. RAJ KUMAR @ RAJU

R/O R/O H.NO. 375, PRITAM NAGAR,

NEAR TAGORE MODEL SCHOOL,

LUDHIANA, (PUNJAB)

...PETITIONER

VERSUS

THE STATE
GOVT. N.C.T. OF DELHI
...RESPONDENT

PETITIONER

DELHI
DATED: .01.2014
PAWAN SHARMA & ASSOCIATES
ADVOCATES
 CH. NO. 492A, WESTERN WING,
TIS HAZARI COURTS, DELHI-54

IN THE HON’BLE HIGH COURT OF DELHI AT NEW DELHI

BAIL APPLICATION NO.__________OF 2014

IN THE MATTER OF:

RAJ RANI ...PETITIONER

VERSUS
THE STATE ... RESPONDENT

URGENT APPLICATION
TO,
THE REGISTRAR,
DELHI HIGH COURT
NEW DELHI

Sir,

Would your honour may be pleased to

treat the accompanying petition as urgent

one, the ground of urgency are:-

“That the petitioner is apprehending

arrest at any moment by the police”.

PETITIONER

DELHI
DATED: .01.2014
PAWAN SHARMA & ASSOCIATES
ADVOCATES
CH. NO. 492A, WESTERN WING,
TIS HAZARI COURTS, DELHI-54
IN THE HON’BLE HIGH COURT OF DELHI AT NEW DELHI

BAIL APPLICATION NO.__________OF 2014

IN THE MATTER OF:-

RAJ RANI ...PETITIONER

VERSUS
THE STATE ... RESPONDENT

F.I.R.NO.378/2013
U/S 420/34 IPC
P.S.MUKHERJEE NAGAR

FIRST APPLICATION/PETITION UNDER

SECTION 438 CR.P.C. READ WITH
SECTION 482 CR.P.C. FOR GRANT OF
ANTICIPATORY BAIL TO THE
PETITIONER.

Hon’ble Chief Justice and

His Hon’ble companion Judges
Of Hon’ble Delhi High Court.

The humble petition of the

Petitioner above named.
1. That the petitioner has been falsely

implicated in the present FIR at the

behest of compliant.

2. That the petitioner is preferring the

present petition for grant of anticipatory

bail before this Hon’ble Court on

dismissal of the bail application U/s 438

Cr.P.C. by the court of Sh. Deepak Garg,

Ld. ASJ, (North) Rohini Court Delhi vide

order dated 20.01.2014. Copy of order

dated 20.01.2014 is annexed as Annexure P-

1.

3. That the petitioner craves leave of this

Hon’ble Court to prefer the brief facts

of the case which are as under:-

B R I E F F A C T S

i) That a FIR bearing No. 378/2013, U/s

420/34 IPC, P.S. Mukherjee Nagar, Delhi

has been registered against the petitioner

and his wife. Copy of the FIR along with

its typed copy and English translation are

collectively annexed as Annexure-P-2.

ii) That the petitioner again preferred to

file on anticipatory bail after having

expert opinion of the signature of husband

of the petitioner and her husband Raj

Kumar. Copy of expert opinion the annexed

as Annexure P-3.

iii) That the complainant had filed a Civil

suit before the Hon’ble Delhi High Court

and same is pending for adjudication. Copy

of Civil suit is annexed as Annexure P-4.

iv) That as a matter no concern with the

offence and the company has wrongly filed

the complaint against the present

petitioner. Hence, the petitioner is

preferring the present petition in the

light of the fact of changed circumstances

inter-alia amongst the following grounds:-

G R O U N D S:

a. Because the Ld. ASJ has failed to

appreciate the fact that complaint as

alleged upon which the FIR No. 378/2013 has

been registered, was filed after a lapse of

 a period of almost five months since the

date of the filing of the civil suit which

is pending before the Hon’ble Delhi High

Court.

b. Because the Ld. ASJ has failed to

appreciate the fact that the complainant had

not discloses the pendency of the Civil suit

which is pending against the petitioner

before Hon’ble Delhi High Court and thus the

complainant had concealed the material facts

in his compliant upon which the FIR is

registered.

c. Because the Ld. ASJ has failed to

appreciate that the expert opinion wherein

it has been opined by the expert that the

signature of the petitioner not matched with

the other signatures.

d. Because the Ld. ASJ has failed to

appreciate that the complainant has filed

forged and fabricated receipt.

e. Because the Ld. ASJ failed to

consider the fact that the complainant

allegedly stated that I got stop the payment

of cheque after seen the conduct of

 petitioner herein but factually he had not

handed over cheque amounting to Rs. 16 Lacs.

f. Because from the bare perusal of the

FIR it is crystal clear that the petitioner

herein is not at all required for custodial

interrogation, thus no purpose is to be

served by arresting the petitioner in the

above noted FIR.

g. Because the contents of the FIR are

crystal clear that the petitioner has

nothing to do in commission of the alleged

offence. Thus it is clear that the

petitioner is innocent and has no nexus or

hand in the commission of alleged offence.

h. Because the petitioner has been

falsely implicated by the complainant in

order to extort the money from the

petitioner.

i. Because Ld. ASJ failed to consider

the fact that the petitioner herein he is

regularly appearing through her Counsel

before Hon’ble High Court and perusing the

civil suit which is pending against the

present petitioner.
j. Because the Ld. ASJ failed to

appreciate the fact that the present

petitioner had filed a detailed written

statement in respect of the civil suit filed

by the complainant.

k. Because the petitioner undertakes

that he will join the investigation before

the IO/SHO/Arresting Officer, as and when

required and called upon to do so.

l. Because the police officials are

constantly attempting to arrest the

petitioner without any basis, hence the

petitioner apprehending his arrest.

m. Because the petitioner is having

clean antecedent and is having deep root in

the society and has never involved in any

case.

n. Because the petitioner further

undertakes that she will not misuse the

liberty of bail in any manner whatsoever.

2. That the petitioner has not filed any

other petitioner either before this Hon’ble

 court or before Supreme Court of India for

the same or similar relief.

P R A Y E R:

It is, therefore, most respectfully

prayed that:-

i) Your lordship may graciously be pleased to

pass an order for grant of anticipatory bail

to the petitioner, thereby, directing the

IO/SHO/arresting officer to release the

petitioner on bail in the event of his

arrest, in the interest of justice.

IN THE HON’BLE HIGH COURT OF DELHI AT NEW DELHI

BAIL APPLICATION NO.__________OF 2010

IN THE MATTER OF:

RAJ RANI ...PETITIONER

VERSUS
THE STATE ... RESPONDENT

A F F I D A V I T

I, Raj Rani W/o Raj Kumar @ Raju aged

about 5 years R/o H.NO. 375, Pritam

Nagar, near Tagore Model School, Ludhiana,

(Punjab) presently at Delhi, do hereby

state and declare on solemn affirmation as

under:-

1. That the deponent is the petitioner in the

above noted matter and as is well

conversant with the facts and

 circumstances of the case and is competent

to swear this affidavit.

2. That the accompanying petition under

section 438 Cr.P.C. read with section 482

Cr.P.C. for grant of anticipatory bail has

been drafted by my counsel under my

instruction and the same have been

read over by me in vernacular and the same

are accepted by me as true and correct

IN THE HON’BLE HIGH COURT OF DELHI AT NEW DELHI

BAIL APPLICATION NO.__________OF 2010

IN THE MATTER OF:

RAJ RANI ...PETITIONER

VERSUS
THE STATE ... RESPONDENT

APPLICATION UNDER SECTION 482 CR.P.C. FOR

GRANT OF EXMEPTION FROM FILIG THE
CERTIFIED COPIES OF ANNEXURES ON BEHALF OF
THE PETITIONER.

MOST RESPECTFULLY SHOWETH:-

1. That the petitioner has filed the

accompanying petition under section 438
read with section 482 of the code of
criminal procedure for grant of
anticipatory bail, which is pending before
Hon’ble court for adjudication.
2. That the petitioner has filed the
annexures which are true and correct
copies of the originals. It is submitted
that the delivery of the certified copy
will take sufficient time, where as the
present matter is urgent one, hence this
application.

It is, therefore, most respectfully

prayed that this Hon’ble court may
graciously be please to exempt the
petitioners from filing the certified
copies of the annexure, in the interest of
justice.
IN THE HON’BLE HIGH COURT OF DELHI AT NEW DELHI

M.A. NO. OF 2014

IN

BAIL APPLICATION NO.__________OF 2014

IN THE MATTER OF:

RAJ RANI ...PETITIONER

VERSUS
THE STATE ... RESPONDENT

A F F I D A V I T

I, Raj Rani W/o Sh. Raj Kumar @ Raju

aged about 5 years R/o H.NO. 375, Pritam

Nagar, near Tagore Model School, Ludhiana,

(Punjab) presently at Delhi, do hereby

state and declare on solemn affirmation as

under :-
1. That the deponent is the petitioner in the

above noted matter and as such is well

conversant with the facts of the case and

is competent to swear this affidavit.

2. That the accompanying application under

section 482 Cr. P.C. has been drafted by

my counsel under my instruction and the

same have been read over by me in

vernacular and the same are accepted by me

IN THE HON’BLE HIGH COURT OF DELHI AT NEW DELHI

BAIL APPLICATION NO.__________OF 2014

IN THE MATTER OF:-

RAJ RANI ...PETITIONER
VERSUS
THE STATE ... RESPONDENT
I N D E X

Sl.No Particulars Pages C.Fee

1. Urgent Application

2. Memo of Parties.

3. Petition under Section Rs.3.00

438 Cr.P.C. read with
section 482 Cr.P.C.
alongwith Affidavit in
support.

4. Application U/s 482

Cr.P.C. for exemption
from filing certificate
copy of Annexures
alongwith affidavit in
support

5. Annexure P-1
 Attested copy of bail
order dt. 20.01.2014

6. Annexure P-2 -
Copy of FIR and fairy
copy and its English
version.

7. Annexure P-3
Copy of expert opinion.

8. Annexure P-4
Copy of civil suit.

9. Vakalatnama

FILED BY:
DELHI
DATED: .01.2014
PAWAN SHARMA & ASSOCIATES
ADVOCATES
FIRST INFORMATION REPORT

CIPA RI 1100 (Under section 154 Cr. P.C.)

1. District- NORTH-WEST DELHI P.S.: Mukherjee Nagar Year-

2013 FIR No.378 /2013 Dated-23.09.2013

2. Act(s): Section (s)

(i) IPC 1860 U/s 420/34 IPC
(ii)
(iii)
(iv)

3. Occurrence of offence:

(a) Day: Thursday Date from: 05.01.2012 Date to:23.09.2013

Time Period: Time from: . Time to:

(b) Information received at PS: Date-23.09.2013Time- 01:30 hrs.

(c) General Diary Reference Entry No. 4A Time- 01.30 hrs.

4. Type of Information: WRITTEN

5. Place of Occurrence:

(a) Direction and distance from PS: Beat No.

 (b) Address: H.No. 167, DHAKKA VILLAGE, DELHI

(c) In case, outside the limit of this Police Station:

Name of P.S.

5. Complainant/informant
a. Name: DR. NAVEEN CHAUHAN (D/O) RISHIPAL CHAUHAN
b. Birth Year : Nationality: INDIAN
c. Passport No. Date of Issue: Place of Issue:
d. Occupation:
e. Address: H.No. 166, DHAKKA VILLAGE, DELHI
7 Detail of known/ suspected /unknown accused, with full

particulars: (attached separate sheet if necessary)

(i) RAJ KUMAR (S/O) LATE AMAN SINGH

R/O X H.No. 167, DHAKKA VILLAGE, DELHI

(ii) RAJ RANI (W/O) RAJ KUMAR

R/O X H.No. 167, DHAKKA VILLAGE, DELHI
(iii)

8. Reasons for delay in reporting by the complainant/Informant. NO

DELAY
9. Particulars of properties stolen/involved (attach separate sheet if
necessary)
Sl. No. Property Type (Description) est. Values (Rs.)
status
(i)
(ii)
(iii)
10. Total value of property stolen
11. Inquest Report/U.D. case No., if any:
12.F.I.R. Contents (attach separate sheet, if

required): To, Thre S.H.O. P.S. Mukherjee

Nagar, Delhi dated 22.07.2013 Sir, I Dr.

Naveen Chauhan S/o Sh. Rishipal Chauhan

R/o H.No. 166, Dhakka Village lving with

my family. I agree to purchase H.No. 167,

Dhakka Village from Raj Kumar S/o Late

Aman Singh with consideration of Rs. 65

Lakhs and I gave Rs. 1 lakh cash and Rs. 2

Lakhs by cheque No. 598186 dated 3.05.2012

Bank of Baroda,, Model Town, Dehi to son

of Raj Kumar Gulshan because he said to me

that he did not have any account on his

name. So I give on the name of his son.

After that he got 2.60 Lakhs cash to me

dated on 08.05.2012 and an Agreement to

Sell & Purchase executed on my name dated

on 08.05.2012. It had decided that

remained balance of Rs. 50.40 Lakhs has to

paid on 01.05.2014 and he will execute

Sale deed on my name. Possession of 2

rooms was given to me and he promised to

me that possession of remained 3 rooms

will be given on payment. After that Raj

Kumar and his wife said to me for balance

payment and on Dec. 2012 and demanded Rs.

30 Lakhs was part payment because his son

Gulshan had to purchase house and shop at

Punjab. The I gave Rs. 15 Lakhs to Raj

Kumar and Raj Rani at their house after

arrange Rs. 12 Lakhs from my relations

with very difficulties. When I gave Rs. 27

Lakhs at that time Sumit Kumar and Titu

were present and Raj Kumar and Raj Rani

gave to receipt to me of Rs. 27 Lakhs and

they said to their tenants that you have

pay rent to Dr. Naveen Chauhan. Because I

have sold this house to Dr. Naveen Chauhan

and possession of this house has been

given to Dr. Naveen Chauhan. Aforesaid Raj

Kumar said to me for remained payment by

cheque and they will execute Sale deed on

your name. Then on his demand, I gave a

cheque No. 601396 Bank of Baroda, Model

Town, Delhi of Rs. 1 lakh on the name of

his son Gulshan and said that cheque of

Rs. 16 Lakhs has to present in the bank at

the time of Sale deed. And I will give you

7.40 Lakhs cheque by the way time is fixed

till 01.05.2014. After taking aforesaid

cheque of Rs. 27 Lakhs and Rs. 16 Lakhs

cash, Raj Kumar and his wife did not meet

me and when I tried to talk on phone to

them said for registry then they did not

give me any satisfactory answer. And after

that they stopped to receive my call on

phone. The it creates doubt in my mind and

I stopped the payment of Rs. 16 Lakhs

cheque in Bank. And after that I did not

got my information about Raj Kumar and Raj

Rani. Prem Singh jij and his friends

attacked on me, my family members and

friends with the intention for taking

possession of aforesaid House No. 167 and

after this attack I got information that

Raj Kumar and Raj Rani have transferred

the documents on the name of other after

taking Rs. 32.60 Lakhs from me and I am

cheated and they have run after taking

saving amount of me and my family members.

I have filed complaint in this regard

earlier. So strongest action may be taken

against aforesaid Raj Kumar and Raj Rani

and case of cheating may be filed against

them. I and my family will be obliged. Dr.

Naveen Chauhan S/o Sh. Rishipal Chauhan,

Chamber H.no. 166, Dhakka Villlage near

Kingsway Camp, Delhi-8, Ph: 9811106609,

9968979762.
13. Action taken since the above report
records commission of offence (s) U/s as
mentioned as item No.2.

ii. Registered the case and took up the

investigation or.
ii. Directed/entrusted (Name of I.O.) Subhash
Chand Rank
No. 16080390 to take up the investigation
OR
iii. Refused investigation due to. OR
iv. Transferred to P.S. District
On point of jurisdiction.

F.I.R. Record over to the complainant/

informant, admitted to be correctly
records and copy given to this
complainant/informant free of cost.

R.O.A.C. Signature of officer

Name
Rank
14. Signature/Thumb impression of the
complainant/informant.

15. Date and time of dispatch to Court by DAK.

IN THE COURT OF SHRI RAJNEESH KUMAR GUPTA, ASJ-
01/WEST: DELHI

Bail Application No. 7992

State Vs. Ajay Kumar
FIR : 155/13
U/s : 498-A/406/34 IPC
PS : Punjabi Bagh
04.10.2013
Pr. : Ld. APP for the state.
Sh. Ishant Kumar advocate for the
accused.
Complainant in person with Ld. Counsel
Sh. Baljeet Kumar.
Heard on the application for
anticipatory bail. File perused.

In brief the case of the police is

that the accused along with co-accused used to
harass the complainant in connection with the
demands of dowry. The FIR has been registered
U/s 498-A/406/34 IPC.

Ld. Counsel for the accused has argued

that the accused has married with the
complainant on 12.11.2003. The accused has not
made any demands of dowry and has not harassed
the complainant in any way. The accused is
ready to join the investigation as and when
required by the IO. on these grounds, it is
prayed that the accused be granted to
anticipatory bail.
 On the other hand, Ld. APP for the state
has argued that the allegations against the
accused are serious in nature and so he is not
entitled to anticipatory bail.

Report of IO perused. As per report, the

accused has never joined the investigation in
this case. The accused is the husband of the
complainant. Keeping in view the seriousness of
the allegations against the accused, I am of
the opinion that the release of accused Ajay
Kumar on anticipatory bail would affect the
investigation of the case and so he is not
entitled to anticipatory bail. Accordingly,
application of Ajay Kumar for anticipatory
bail.

Sd/-
(Rajneesh Kumar Gupta)
ASJ-01(West)
04.10.13