IN THE COURT OF CHIEF JUDICIAL MAGISTRATE, (NORTH),
ROHINI, DELHI.
COMPLAINT CASE NO. OF 2024
IN RE :
SMT. PRIYANKA ARORA ….COMPLAINANT
VERSUS
SHRI . M.K SINGH ….ACCUSED PERSONS
INDEX
SL.NO. PARTICULARS PAGE NO. COURT FEE
1. Memo of Parties
2. Application U/s 175(3) BNSS
along with affidavit.
3. Complaint U/s 210(1) BNSS
along with affidavit.
4. List of Document
along with documents
5. Vakalatnama
DELHI
DATED : COMPLAINANT
THROUGH
COUNSEL
IN THE COURT OF CHIEF JUDICIAL MAGISTRATE, (NORTH),
ROHINI, DELHI.
COMPLAINT CASE NO. OF 2025
IN RE :
SMT. PRIYANKA ARORA ….COMPLAINANT
VERSUS
SHRI M.K . SINGH & ORS. ….ACCUSED PERSONS
MEMO OF PARTIES
SMT. PRIYANKA ARORRA
W/O SHRI YASH ARORA
R/O H – 4/13, 3RD FLOOR,
SECTOR 16 ROHINI,
DELHI-110089 ….COMPLAINANT
VERSUS
1. SHRI M.K SINGH
R/O H-4/13 SECOND FLOOR
SECTOR-16, ROHINI , ,
DELHI , 110089
MOB : 9818457457
2. SHRI KRISHAN SINGH
S/O SHRI M.K SINGH
R/O ,H-4/13 SECOND FLOR ,
SECTOR -16 , ROHINI
DELHI , 110089 ….ACCUSED
DELHI
DATED : COMPLAINANT
THROUGH
COUNSEL
IN THE COURT OF CHIEF JUDICIAL MAGISTRATE, (NORTH),
ROHINI, DELHI.
COMPLAINT CASE NO. OF 2025
IN RE :
SMT. PRIYANKA ARORA ….COMPLAINANT
VERSUS
SHRI M. K. SINGH AND ORS . ….ACCUSED
P.S.: K.N.KATJU MARG
APPLICATION U/S 175(3) OF BNSS, 2023 FOR TAKING THE
COGNIZANCE OF THE OFFENCES COMMITTED BY THE
ACCUSED PERSONS AS MENTIONED IN THE
ACCOMPANYING COMPLAINT THEREBY GIVING THE
DIRECTIONS TO THE S.H.O. OF P.S. K.N KATJU,MARG,
DELHI FOR REGISTRATION OF FIR AS PER PROVISIONS OF
LAW.
MOST RESPECTFULLY SHOWETH:
1. That the complainant has filed the complaint against the accused
persons U/s 210(1) BNSS read with Section 175(3) BNSS, for which
the copies of the documents and the other documents placed by the
complainant on the record are more than sufficient to show that the
accused has committed the offences as mentioned in the complaint
and hence, the cognizance of the complaint deserves to be taken by
this Hon'ble Court.
2. That the allegations alleged in the complaint are of such a nature
which needs an investigation. Hence, the present application.
3. That the S.H.O. of P.S. K.N KATJU, MARG Delhi, be directed U/s
175(3) BNSS, thereby lodging the F.I.R. against the accused persons
on the basis of the complaint and then to investigate the matter as per
provisions of law.
P R A Y E R:
It is, therefore, most respectfully prayed that the directions may
kindly be given to S.H.O. P.S. K.N KATJU, MARG , Delhi to register
the F.I.R. against the accused persons and submit the report through I.O.,
U/s 175(3) Cr.P.C., in the interest of justice.
DELHI
DATED : COMPLAINANT
THROUGH
COUNSEL
IN THE COURT OF CHIEF JUDICIAL MAGISTRATE, (NORTH),
ROHINI, DELHI.
COMPLAINT CASE NO. OF 2025
IN RE :
SMT. PRIYANKA ARORA ….COMPLAINANT
VERSUS
SHRI. M. K. SINGH AND ORS ….ACCUSED
AFFIDAVIT
I, Priyanka Arora, w/o Shri yash Arora , R/O H- 4/13 top
floor ,sector 16 Rohini , Delhi 110089.,do hereby solemnly affirm and
declare as under:
1. That the deponent is the complainant in the above complaint
and well conversant with the fact and circumstances of the case
and competent to swear this affidavit.
2. That the accompanying complaint U/s 175(3) BNSS has been
drafted by my Counsel under my instructions. Contents of the
same have been read over and explained to me in my vernacular
language. The same are true and correct.
3. That the contents of the same may kindly be read as part and
parcel of this affidavit and have not been repeated here for the
sake of brevity.
DEPONENT
VERIFICATION:
Verified at Delhi on this day of August, 2024 that the contents of
above affidavit are true and correct to the best of my knowledge and
belief and nothing has been concealed therefrom.
DEPONENT
IN THE COURT OF CHIEF JUDICIAL MAGISTRATE, (NORTH),
ROHINI, DELHI.
COMPLAINT CASE NO. OF 2025
IN RE :
SMT. PRIYANKA ARORA
W/O SHRI YASH ARORA
R/O H – 4/13 , 3RD FLOOR ,SECTOR 16
ROHINI, DELHI-110042 ….COMPLAINANT
VERSUS
1. SHRI M. K. SINGH
R/O H-4/13 SECOND FLOOR ,
SECTOR- 16,ROHINI,
DELHI ,110089
MOB.: 9818457457
2 SHRI KRISHAN SINGH
R/O H-4/13 SECOND FLOOR ,
SECTOR- 16,ROHINI,
DELHI 110089
MOB.: 9718457457 . ….ACCUSED
P.S.: K.N .KATJU
COMPLAINT UNDER SECTION 210(1) OF BHARTIYA NAGRIK
SURAKSHA SANHITA, 2023 AGAINST THE ACCUSED
PERSONS FOR THEIR ILLEGAL ACTS AND HAVING
COMMITTED OFFENCES UNDER SECTION 126/127/351/324 OF
BHARTIYA NYAY SANHITA, 2023 ON BEHALF OF
COMPLAINANT.
MOST RESPECTFULLY SHOWETH:
1. The complainant Smt. Priyanka Arora w/o shri Yash Arora , R/o
H.No. H- 4/13 top floor sector 16 Rohini Delhi 110089, is law
abiding and peace loving citizen of India.
2. That the complainant is the owner and in possession of H.No.
H- 4/13 top floor sector 16 Rohini Delhi 110089.
3. That the accused, Dr, M. K Singh, residing in the
neighboring flat, has been pressuring me to sell my flat to
him for a substantially lower price than its market value.
Despite my repeated refusal, the accused, along with his
hired goons (who are unknown to me at present but are
often seen with him), has been continuously harassing me
and my family..
4. That On multiple occasions, the accused has threatened me and my
family with physical harm and has verbally abused us in front of
witnesses. On 24/02/2025, a group of goons hired by the accused
visited my flat and threatened to use force if I did not agree to sell
the flat to him. They made it clear that their objective was to
pressure me into selling the property against my will. Video
recordings of the above said incidents are enclosed with complaint
5. That these goons have not only threatened us but have also
obstructed our basic access to amenities. They have deliberately cut
off the water and electricity supply to my flat on several occasions,
causing significant distress and inconvenience. This obstruction has
been a deliberate attempt to force my family into complying with
the accused’s demands.
6. That The accused’s goons have also been seen loitering near our
flat, intimidating us by their mere presence and preventing us from
leading a peaceful and normal life. Despite several complaints made
to the building society and local authorities, no action has been
taken to resolve the issue.
7. That the complainant and her husband had made a written
complaint to police station wide DD no. 87 on 01/08/2024
regarding This obstruction which has been a deliberate attempt to
force my family into complying with the accused’s demands. (copy
annexed ).
8. That it was a shock and pain to me and Family that no action had
been taken by concern police officials on the contrary accused
person stared abusing and scolding me openly by saying “TU
MERA KUCH NAHI BIGAD PAYOGE AS POLICE WALE TO
MERE JAEB HAIN .YE MAKAN TO TUCHJE BECHNA HI
PADEGA OR WO BHI MUJHE HI .”
9. That after this incident and act of Delhi police official forced me to
inform higher official, to inform about the incidents and
irresponsible behavior as well as dereliction of duties through my
written application on 12/11/24 wide DD no. 5801 to DCP office .
Copy annexed.
10. That constrained by the repeated illegal acts of the accused
persons, the complainant had made another written complaint to the
S.H.O.K.N.KATJU MARG, Delhi vide DD No.49A dated
25.02.2025, and the copy of the same was also sent to the office of
concerned Deputy Commissioner of Police and other senior
officers, through Speed Post dated 18.07.2024, which was also duly
received. However, no action has been taken on the complaint filed
by the complainant before the SHO concerned and higher police
authorities and the police officials are not taking any action, as they
are in connivance with the accused persons
11. The actions of the accused and his hired goons fall within
the definition of criminal intimidation under Section 351
of the Bharatiya Nayaya Sanhita (BNS), as they have
made threats of harm and violence to force us into selling
our property.
12. The obstruction of basic amenities like water and
electricity falls under the offense of wrongful restraint
and criminal intimidation, as defined under Sections
126and 351(1) of BNS.
13. The actions of the accused and his associates also amount
to harassment, which is covered under Section 351 of
BNS (Punishment for criminal intimidation)..
14. That the accused persons and their accomplices had committed the
said criminal offences, punishable under Sections
126/127/324/351(1)/ 351 read with 3 (5) of BhartiyaNyaySanhita,
2023.
15. That the duty of the S.H.O. P.S . K.N.KATJU MARG , Delhi is to
maintain law and order in the area under his jurisdiction, who has
failed to take any action against the accused despite several visits of
the complainant to the police station in question, however, no action
has been taken in the matter till date.
16. That the police officials of P.S. K.N.KATJU ,MARG, Delhi did not
conduct a fair investigation of the case and also did not register any
case against the accused and ignored the seriousness of the offences
and no enquiry has been conducted on the complaint of the
complainant. Even the police officials are hand in gloves with the
accused persons and no investigation has been done till date, despite
receipt of the complaint, however, the police officials are assisting
the accused persons, in their illegal acts.
17. That the property in question is situated at Rohini Sector 16 ,
Delhi, , the cause of action also arose within the jurisdiction of P.S.
K.N. KATJU , Delhi, hence this Hon’ble Court has territorial
jurisdiction to try and entertain the present complaint.
PRAYER:
Under the facts and circumstances mentioned herein above, it is,
therefore, most respectfully prayed to this Hon’ble Court that the accused
persons may kindly be summoned, tried and punished for committing the
offence under Section of 126/127/351/324 ,BhartiyaNyaySanhita, 2023
and other related provisions of law, in the interest of justice.
Any other and such further order(s)/ direction(s) as this Hon'ble
Court may deem fit and proper under the facts and circumstances of the
case may also be granted in favour of the complainant and against the
accused.
DELHI
DATED : COMPLAINANT
THROUGH
COUNSEL
IN THE COURT OF CHIEF JUDICIAL MAGISTRATE, (NORTH),
ROHINI, DELHI.
COMPLAINT CASE NO. OF 2025
IN RE :
SMT. PRIYANKA ARORA ….COMPLAINANT
VERSUS
SHRI. M. K. SINGH AND ORS ….ACCUSED
AFFIDAVIT
I, Priyanka Arora, w/o Shri yash Arora , R/oH.No 3/13 top
floor ,sector 16 Rohini , Delhi 110089.,do hereby solemnly affirm and
declare as under:
1. That the deponent is the complainant in the above complaint
and well conversant with the fact and circumstances of the case
and competent to swear this affidavit.
2. That the accompanying complaint U/s 210(1) BNSS has been
drafted by my Counsel under my instructions. Contents of the
same have been read over and explained to me in my vernacular
language. The same are true and correct.
3. That the contents of the same may kindly be read as part and
parcel of this affidavit and have not been repeated here for the
sake of brevity.
DEPONENT
VERIFICATION:
Verified at Delhi on this day of August, 2024 that the contents of
above affidavit are true and correct to the best of my knowledge and
belief and nothing has been concealed therefrom.
DEPONENT
