IN THE COURT OF HON’BLE CHIEF JUDICIAL
MAGISTRATE, DISTRICT EAST, KARKARDOOMA
COURT, DELHI
COMPLAINT CASE NO. _____OF 2025
IN THE MATTER OF:
RAHUL GUPTA ...COMPLAINANT
VERSUS
STATE OF NCT OF DELHI & ANR …RESPONDENTS
PS: LAXMI NAGAR, DELHI
INDEX
S.NO PARTICULARS PAGE NO.
.
1. MEMO OF PARTIES
2. COMPLAINT ON BEHALF OF
APPLICANT NAMELY SH. RAHUL
GUPTA UNDER SECTION 156(3) THE
CODE OF CRIMINAL PROCEDURE,
1973/175(3) OF THE BHARATIYA
NAGARIK SURAKSHA SANHITA,
2023 R/W SECTION 200 OF CRPC /
SECTION 223 OF BNSS AGAINST
THE ACCUSED PERSONS ALONG
WITH AFFIDAVIT.
3. LIST OF DOCUMENTS ALONG
WITH DOCUMENTS
4. LIST OF WITNESSES
5. VAKALATNAMA
COMPLAINANT
FILED THROUGH
DEEPAK SHARMA & ASSOCIATES
COUNSEL FOR THE COMPLAINANT
Office at: D-29, Vikas Complex, Vikas Marg,
Laxmi Nagar, Delhi-110092
M.: 8920980462,8130401918,011-41811883
Email: sharmaadvdeepak@gmail.com
Place: Delhi
Date: 26.06.2025
IN THE COURT OF HON’BLE CHIEF JUDICIAL
MAGISTRATE, DISTRICT EAST, KARKARDOOMA COURT,
DELHI
COMPLAINT CASE NO. _____OF 2025
IN THE MATTER OF:
RAHUL GUPTA ...COMPLAINANT
VERSUS
STATE OF NCT OF DELHI & ANR …RESPONDENTS
PS: LAXMI NAGAR, DELHI
MEMO OF PARTIES
RAHUL GUPTA
S/O SHRI G.K. GUPTA
R/O J-218, SARAFA BAZAR,
LAXMI NAGAR, DELHI – 110092
M: +91-8178236087 …COMPLAINANT
VERSUS
1. STATE OF NCT OF DELHI
THROUGH SHO PS LAXMI NAGAR
2. LEELADHAR GUPTA
S/O NOT KNOWN
R/O LAXMI NAGAR, DELHI
3. OM VEER YADAV
S/O NOT KNOWN
R/O LAXMI NAGAR, DELHI
4. SMT. MAMTA SHARMA
S/O NOT KNOWN
R/O LAXMI NAGAR, DELHI
5. VIPUL SHARMA
S/O NOT KNOWN
R/O LAXMI NAGAR, DELHI …RESPONDENTS
COMPLAINANT
FILED THROUGH
DEEPAK SHARMA & ASSOCIATES
COUNSEL FOR THE COMPLAINANT
Office at: D-29, Vikas Complex, Vikas Marg,
Laxmi Nagar, Delhi-110092
M.: 8920980462, 8130401918, 011-41811883
Email: sharmaadvdeepak@gmail.com
Place: Delhi
Date: 26.06.2025
IN THE COURT OF HON’BLE CHIEF JUDICIAL
MAGISTRATE, DISTRICT EAST, KARKARDOOMA
COURT, DELHI
COMPLAINT CASE NO. _____OF 2025
IN THE MATTER OF:
RAHUL GUPTA ...COMPLAINANT
VERSUS
STATE OF NCT OF DELHI & ANR …RESPONDENTS
PS: LAXMI NAGAR, DELHI
COMPLAINT ON BEHALF OF APPLICANT NAMELY
SH. RAHUL GUPTA UNDER SECTION 156(3) THE CODE
OF CRIMINAL PROCEDURE, 1973/175(3) OF THE
BHARATIYA NAGARIK SURAKSHA SANHITA, 2023
R/W SECTION 200 OF CRPC / SECTION 223 OF BNSS
AGAINST THE ACCUSED PERSONS.
MOST RESPECTFULLY SHOWETH:
1. That the Complainant is a law-abiding citizen of this Country
and residing at the above-mentioned address more particularly
mentioned in Memo of Parties.
2. That the Complainant entered into a lawful collaboration
agreement with one Mr. Amit Chaudhary for construction of a
house at property bearing address G-1, Vijay Chowk, Laxmi
Nagar, Delhi.
3. That during the course of construction, one Mr. Leeladhar
Gupta got a false complaint filed by a woman named Preet,
falsely claiming to be a resident of the said premises. Upon
inquiry by the Complainant, it was discovered that no such
person resided there and the address used was bogus and
falsely linked to the property in question.
4. That thereafter, accused Leeladhar Gupta demanded a sum of
₹15,00,000/- (Rupees Fifteen Lakhs) from the Complainant
for getting the fabricated complaint withdrawn. When the
Complainant refused to succumb to this illegal demand,
accused persons Leeladhar Gupta, Om Veer Yadav, and Smt.
Mamta Sharma began threatening the Complainant with dire
consequences.
5. That the accused persons openly stated that in order to carry
out any construction activity in the Laxmi Nagar area, the
Complainant would have to pay them ‘RANGAARI’ (extortion
money), failing which they would get the construction
demolished or initiate more false criminal complaints.
6. That the said threats and extortion demand were part of a well-
organized criminal conspiracy, wherein the accused persons
were running a racket of creating false parties, filing fake
cases, and thereby extorting large sums of money from
innocent persons engaged in lawful construction.
7. That the Complainant, aggrieved by such criminal conduct,
submitted a written complaint dated 26.04.2025 to the Station
House Officer, Police Station Laxmi Nagar, Delhi, detailing
the entire incident and requesting immediate action. However,
no FIR was registered, and no investigation was initiated.
8. That the Complainant on same day i.e. 26.04.2025 has also
submitted a written complaint to the Station House Officer,
Police Station Laxmi Nagar, Delhi vide DD no. XXXX,
detailing the incident of the accused persons malicious intent.
However, no appropriate action has been taken by the police
authorities till date, forcing the Complainant to approach this
Hon’ble Court for urgent relief. Copy of Complaint has been
annexed here.
9. That even after repeated verbal follow-ups, the SHO
concerned failed to take any steps to investigate or register an
FIR, thereby compelling the Complainant to approach higher
authorities.
10.That thereafter, on 13.06.2025, the Complainant submitted a
detailed written complaint to the Deputy Commissioner of
Police (East District), Delhi, reiterating the facts and the earlier
complaint made to SHO PS Laxmi Nagar. A copy of the
original complaint was also annexed thereto. Copy of
Complaint along with tracking has been annexed here.
11.That despite the lapse of several weeks, no action has been
taken by the police authorities on either of the complaints
submitted by the Complainant. The accused persons continue
to threaten the Complainant and roam freely, which has caused
mental agony, fear, and insecurity to the Complainant and his
family.
12.That additionally, the Complainant submits that two months
prior to the first complaint, the accused Leeladhar Gupta,
along with one Mr. Vipul Sharma, again demanded
₹15,00,000/- from the Complainant. It has now become
evident that Vipul Sharma is actively involved in the extortion
racket run by these accused persons and is a key conspirator
and witness to these unlawful activities.
13.That the acts of the accused persons amount to commission of
cognizable offences, including but not limited to Extortion;
Criminal Intimidation; Criminal Conspiracy; False Information
with Intent to Cause Injury; False Charge of Offence to Injure;
Common Intention.
14.That the Complainant has exhausted all remedies available at
the police level, and the inaction of police authorities in
registering the FIR, despite disclosure of cognizable offences,
is in violation of the law laid down by the Hon’ble Supreme
Court in Lalita Kumari v. Govt. of U.P., (2014) 2 SCC 1.
15.That in view of the above facts and circumstances, the
intervention of this Hon’ble Court is necessary to direct the
registration of an FIR and a fair investigation into the matter to
bring the culprits to justice.
16.The cause of action arose on 26.04.2025, when the Accused
committed the aforementioned offences. Its again arose on
13.06.2025 when the complaint send a complaint to DCP,
East, Delhi and continues due to the persistent threat to the
Complainant’s life and safety. The inaction of the Laxmi
Nagar Police Station has compelled the Complainant to seek
redressal through this Hon’ble Court.
17.This Hon’ble Court has jurisdiction to entertain this complaint
as the incident occurred within the territorial limits of this
Hon’ble Court.
18.That the complainant is ready and willing to fully cooperate in
the inquiry and investigation and is also ready to appear in
person or submit any additional evidence or witness testimony,
as required.
PRAYER
In view of the above facts and circumstances, the Complainant
most respectfully prays before this Hon’ble Court to:
a) Pass directions under Section 156(3) CrPC / Section 175(3)
BNSS to the Station House Officer, PS Laxmi Nagar, to
register an FIR on the basis of the complaints dated
26.04.2025 and 13.06.2025 and investigate the matter in
accordance with law.
b) Direct appropriate protection to the Complainant, in view of
ongoing threats by the accused persons; and
c) Direct the police authorities to conduct a thorough and
expeditious investigation into the matter and submit a
detailed Action Taken Report (ATR) to this Hon’ble Court.
d) Pass any other or further orders as this Hon’ble Court may
deem fit and proper in the interest of justice.
COMPLAINANT
FILED THROUGH
DEEPAK SHARMA & ASSOCIATES
COUNSEL FOR THE COMPLAINANT
Office at: D-29, Vikas Complex, Vikas Marg,
Laxmi Nagar, Delhi-110092
M.: 8920980462, 8130401918, 011-41811883
Email: sharmaadvdeepak@gmail.com
Place: Delhi
Date: 26.06.2025
IN THE COURT OF HON’BLE CHIEF JUDICIAL
MAGISTRATE, DISTRICT EAST, KARKARDOOMA
COURT, DELHI
COMPLAINT CASE NO. _____OF 2025
IN THE MATTER OF:
RAHUL GUPTA ...COMPLAINANT
VERSUS
STATE OF NCT OF DELHI & ANR …RESPONDENTS
PS: LAXMI NAGAR, DELHI
AFFIDAVIT
I, Rahul Gupta S/o Sh. G.K. Gupta Age About 38 Yrs R/o J-218,
Sarafa Bazar, Laxmi Nagar, East Delhi, Delhi-110092, do hereby
solemnly affirm and state on oath as under: -
1. That I am the Complainant in the present application and
being well conversant with the facts and circumstances of the
present case, I am competent to swear this affidavit.
2. That the accompanying application/complaint has been
drafted by my counsel and the contents of the same have been
read over and explained to me in my vernacular language. I
have understood the same, and they are true and correct to the
best of my knowledge and belief.
3. That the contents of the said application may be read as part
and parcel of this affidavit, and are not being repeated herein
for the sake of brevity.
DEPONENT
VERIFICATION:
Verified at Delhi on this day of _____June, 2025 that the
contents of the above affidavit are true and correct to my
knowledge and belief and nothing material has been concealed
there from.
DEPONENT
IN THE COURT OF HON’BLE CHIEF JUDICIAL
MAGISTRATE, DISTRICT EAST, KARKARDOOMA
COURT, DELHI
COMPLAINT CASE NO. _____OF 2025
IN THE MATTER OF:
RAHUL GUPTA ...COMPLAINANT
VERSUS
STATE OF NCT OF DELHI & ANR …RESPONDENTS
PS: LAXMI NAGAR, DELHI
LIST OF DOCUMENTS
S. NO. PARTICULARS PAGE NO.
1. Copy of Complaint dated 26.04.2025.
2. Copy of Complaint dated 13.06.2025
along with its postal receipt & tracking
reports.
3. Copy of Aadhar card of Complainant.
COMPLAINANT
FILED THROUGH
DEEPAK SHARMA & ASSOCIATES
COUNSEL FOR THE COMPLAINANT
Office at: D-29, Vikas Complex, Vikas Marg,
Laxmi Nagar, Delhi-110092
M.: 8920980462, 8130401918, 011-41811883
Email: sharmaadvdeepak@gmail.com
Place: Delhi
Date: 26.06.2025
