IN THE COURT OF THE CMM
TIS HAZARI COURT,WEST DISTRICT, NEW DELHI
COMPLAINT CASE NO. __________ OF 2024
IN THE MATTER OF:
SANDEEP GROVER COMPLAINANT
VS
KAWAL PREET SINGH ACCUSED
INDEX
I N D E X
S.No Particulars Pages C.Fee
Delhi.
1. MEMO OF PARTIES Complainant
Dated:25.06.2024 Through
2. COMPLAINT
Advocate
3. LIST OF WITNESS
KANAV HURRIA
4. AFFIDAVIT
24/62, second floor west
punjabi bagh new delhi.
5. VAKALATNAMA
9953803808
IN THE COURT OF THE CMM
TIS HAZARI COURT,WEST DISTRICT, NEW DELHI
COMPLAINT CASE NO. __________ OF 2024
(Affix Court Fee stamp of Rs. ___)
IN THE MATTER OF:
SANDEEP GROVER COMPLAINANT
VS
KAWAL PREET SINGH ACCUSED
MEMO OF PARTIES
SANDEEP GROVER COMPLAINANT
S/o S.C GROVER
ADDRESS- B 2/174, PASHIM VIHAR, New Delhi 110063
VS
KAWAL PREET SINGH ACCUSED
S/o Sh. R.P. SINGH
R/o H. No. 65/74, KAROL BAGH, New Delhi-110005
ALSO AT E-90,SECOND FLOOR LIC COLONY, JEVAN
NIKETAN, PASCHIM VIHAR NEW DELHI - 110087
Office at: 60/26,RAMJAS ROAD KAROL BAGH, NEW
DELHI- 110005
IN THE COURT OF THE CMM
TIS HAZARI COURT,WEST DISTRICT, NEW DELHI
COMPLAINT CASE NO. __________ OF 2024
IN THE MATTER OF:
SANDEEP GROVER COMPLAINANT
VS
KAWAL PREET SINGH ACCUSED
Police Station: Paschim vihar east
COMPLAINT UNDER SECTION 200 READ WITH
SECTION 156(3) OF THE CODE OF CRIMINAL
PROCEDURE FOR REGISTRATION OF FIR UNDER
SECTION 420 AND 405 OF INDIAN PENAL CODE
THE COMPLAINANT ABOVE NAMED MOST
RESPECTFULLY SHOWETH:
1. That the complainant is the permanent resident of B-2 /174
Paschim Vihar, New Delhi 110063.
2. That the acussed was is in friendly terms with the
complainant.
3. That Janak rani gupta was the complete owner of property
bearing No.E-90, LIC Colony, Jeevan Niketan, Paschim
Vihar, New Delhi-110087.
4. That accused number one is in the business of construction.
5. That the accused number 2 and accused number 1 and has
entered into a construction/ collaboration agreement.
6. That the construction/collaboration agreement states that
the accused will construct the property and the owner
namely Janak rani gupta will transfer the second floor of E-
90, LIC Colony, Jeevan Niketan, Paschim Vihar, New Delhi-
110087, to accused. Agreement is annexed as P1
7. That on account of the said construction/ collaboration
agreement. the accused number one approached the
complainant and proposed that if the complainant grant
accused a loan of Rs 10,00,000 (ten lakh rupees) to
construct the property and in exchange the accused will
transfer in favour of the complainant 10% ownership
/partnership in the second floor of E-90,measuring 197
Sq. Yds, LIC Colony, Jeevan Niketan, Paschim Vihar, New
Delhi-110087 (hereafter called the suit property).
8. That the complainant initially refused to take the proposal .
9. That on the constant request of the accused that he direly
needs the money to construct the property the complainant
agreed to grant him loan and same will be paid back either
by selling the property or renting the property owned . In the
later case it was proposed 10 % of the rent will come to the
complainant.
10. That the complainant and the accused entered into an
partnership agreement deed dated 12 august 2020 regarding
the property which makes the complainant 10% absolute
owner of the suit property
11. That the agreement was signed in front of a witness
namely randeep singh.The partnership agreement is
annexed as P-2.
12. That the complainant has transferred the amount of ten
lakh to the accused via a cheque/RTGS as stated in the
agreement.The bank statement of the complaiant is
annexed as P-3.
13. That the accused was not able to construct the building in
time and again was in need of money. Then he again
approached complainant for money as loan to complete the
construction of property.
14. That the complainant hard earned money was already
stuck with the accuseds construction work. And to get out
the money the complainant agreed to grant the accused
another loan which was advanced to the accused time and
again.
15. That the complainant in hope to get out his stuck money
in the construction of the suit property continued to advance
loan to the accused in the period of September 2020 to
October, 2022 and by that time the total additional amount
which was advanced to the accused reach the amount of Rs
10,00,000 . which the accused told he will return very soon
with profit
16. That the total amount owed after the additional loan was
of Rs 20,00,000 (twenty lakh rupees) plus profit of Rs
20,00,000
17. That the accused number 1 promised to pay back the
total amount of Rs 40,00,000 to the complainant as soon as
possible.
18. That on 4.01.2023 the defendant issued a cheque of
Rs 20,00,000 drawn on yes bank in favour of the
plaintiff to pay back the loan amount owned by him and
requested for time to pay the rest amount of profit of Rs
20,00,000 .
19. That the cheque was dishonoured with the remarks
Drawer Signature Differs. The copy of cheque along with
the return memo is annexed as P-4
20. That the complainant tried approaching the accused on
multiple occasions asking the accused to pay back the loan
amount granted to him by the complainant. The accused
neither pick up the calls nor had called back the
complainant.
21. That the accused had from the start intended to cheat,
and with the attend to deceive has gained undue advantage
and should be punished with Section 420,447 of IPC
22. That the Complainant went to the Police station at
14.06.2024 to report the matter, and no such action has
been taken by the police and are refusing to file the F.I.R
23. That the Complainant had Complaint to the deputy
commissioner of police on 14.06.2024. Even then, no action
has so far been taken against the accused. Copy of
Complaint annexed as P-4
24. Under this Circumstances, the Complainant Prays for
legal action against the Accused.
PRAYER
1. In view of the aforesaid submission made here in and in
the interest of the justice, it is therefore most respectfully
prayed that this Hon'ble Court may graciously be pleased
to:
1) register the present complaint
2) Take cognizance of the offence, as the contents per-se
amount to commission of offences, as indicated above,
without anything more.
3) Summon try and punish the accused person for
committing the offences under section 420,405 AND 447
of the IPC.
Pass such other or further orders as this Hon'ble Court may
deem fit and proper in the facts and circumstances of the case.
AND FOR THIS ACT OF KINDNESS, THE HUMBLE
APPLICANT AS IN DUTY BOUND, SHALL EVER PRAY.
COMPLAINANT
THROUGH
KANAV HURRIA
24/62, SECOND FLOOR
WEST PUNJABI BAGH
NEW DELHI
Place : Delhi
Date : 25.06.2024
Annexures to be attached with the Complaint
1) construction/collaboration agreement between kawal preet
singh and janak rani gupta.
2) Copy of loan agreement
3) Copy of the bank statement of Complainant for the term
5/04/2021 to 7/02/2021
4) Copy of cheque
5) Copy of return memo dated 1 March , 2024.
IN THE COURT OF THE CMM
TIS HAZARI COURT,WEST DISTRICT, NEW DELHI
COMPLAINT CASE NO. __________ OF 2024
IN THE MATTER OF:
SANDEEP GROVER COMPLAINANT
VS
RANDEEP SINGH AND OTHERS ACCUSED
LIST OF WITNESS
1. Complainant himself
2. BANK CLERK OF ACCUSED ACCOUNT / ANY OTHER
BANK OFFICIAL
3. BANK CLERK OF COMPLAINANT ACCOUNT/ ANY
OTHER BANK OFFICIAL
4. ANY OTHER WITNESS WITH THE PERMISSION OF THE
COURT
IN THE COURT OF THE CMM
TIS HAZARI COURT,WEST DISTRICT, NEW DELHI
COMPLAINT CASE NO. __________ OF 2024
IN THE MATTER OF:
SANDEEP GROVER COMPLAINANT
VS
RANDEEP SINGH AND OTHERS ACCUSED
AFFIDAVIT
I,SANDEEP GROVER , aged about 40 years S/o S. C GROVER ,
R/o B- 2/174, PASHIM VIHAR, Delhi, do hereby solemnly
affirm and declare as under:
1. That I am the complainant in the above noted complaint
and well conversant with the facts of the case, hence
competent to swear this affidavit.
2. That accompanying complaint under sec 156(3)has been
drafted by my counsel under my instruction, which has
been explained to me in vernacular and the same be read
as part of this affidavit as the same are not being repeated
herein for the sake of brevity.
DEPONENT
VERIFICATION:
Verified at Delhi on this 25 day June 2024 that the
contents of my above affidavit from para 1 & 2 are true and
correct to my knowledge and belief and nothing material has
been concealed therefrom.
DEPONENT
