Notice

DUBAI Notice
1. Last but not the least- with the great support and enthusiasm instilled in me by the Human
Rights activists in Mumbai, I have made up my mind and decided to return to Dubai. I
am not scared about arrest or any other actions. After depositing the amount and coming
with clean hands, it would be definitely expected from the judiciary in Dubai that I must
be given a fair hearing. Now since I am out of Dubai and I am in my own country in
India, there is no reason for me to place my money in jeopardy. Usually, people who
abscond after committing a crime do not return. I am not only returning and facing the
trial, but I am putting myself at stake by offering to deposit the amount. Thus my person
and my finances will be put to stake just for justice and for removing the stigma on me.
This gesture would per se convince the judiciary that I am innocent and I should be given
justice. The Human Rights group from Mumbai (India) who have given me courage,
would also be monitoring the whole case and one or two volunteer lawyers from this
group would be accompanying me. One Mr.Sanjeev G.Punalekar, is a Human Rights
activist and edits a newspaper named Civil Liberties. He has also fought various
litigations against Government of India. You may find his name and details by searching
internet through www.google.com. He was accompanying me and appearing for me even
in Australia. His contact details are furnished here below.
Mr. Sanjeev G.Punalekar, Advocate, High Court, 315, Birya House, 265, Perin Nariman
Street, Bazar Gate, Fort, Mumbai 400 001.(India). Mobile no. 0091-9820095814
Yours truly
Dayal Mansukhani
Dayal Mansukhani Vs- SCB (Criminal Case) 1246/1999,1174/1999, 145/1999
Dayal Vs- Besco International 183/2000,511/2003527/2003:
3.Dayal Vs- CBI:827/2001,467/2002,304/2003:
4.Besco Vs- Dayal:
557/1998,
454/2002,
491/2002:
5.Kavitha Arjandas Vs- Khaleej Times:157/2000,70/2003,351/2003

Notice A
Date: 26th July 2006
Standard Chartered Bank, Legal and Compliance, UK &Europe

Notice B
Date: 28th July, 2006
Keith international(Besco International)Mr. Raj Bernard
Notice C Date: 28th July, 2006
Ahmed ABDULLA MAHAMMD AL Mulla
P P NO A 851222
Notice D Date: 10th July, 2006
HARIS & ASSOCIATES Auditors & Business Consultants
Notice E
TO Dar AL- Adalah
Notice F
To:
Mr. K.K.Sarachandra Bose Dubai (U.A.E.) 10 Jul 2006
http://www.needjustice.net/
User Name: dubai
Password: uae
Plz re-open these Case nos. 1246/99, 557/98 (454/2002 appeal),

827/2001, 157/2000, 183/2001.
All these case details are with my lawyer Mr K. K. S. Bose Dar Al
Adallah. Please transfer the
cases to lower court in Duabi or if you cannot give justice to an Indian
citizen, transfer these
cases to India.
From :
"Bose Bose" <boselaw@hotmail.com>
Add boselaw@hotmail.com to My Messenger Contacts.

To :
CC :
Subject :
poojamans@hotmail.com
dayalm@hotmail.com
YOUR DUBAI CASES.
Date :
Sat, 06 Sep 2003 12:03:33 +0000
Reply Reply All Forward Delete
Put in Folder...
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We have checked in the computer and your name is in the

computer in respect to the execution made by Besco.
This means that the court has issed arrest order in
the execution filed by Besco arrest order
9/12/203 & 26/6/206

http://www.needjustice.net/ Notice
http://www.needjustice.net
First you read notices after you click this website.

User Name- Dubai
Password UAE
Before the year 1998 there was not a single case against me, its only after the
Bank Guarantee cheque return I ws challenged that Indian Citizens are slaves
and work for Foreigners. When Indian consulate is appointed they do not
support Indians and just keep watching Injustice.
I was earning per annum 3 lake and above, as Bank Interest, without tax, and
one thousand us $ was tax-free. I was challenged by the Standard Chartered
Bank that they will bankrupt me \. I am fighting for justice for last. I was told
that even Australia is a country of terrorists and mafia, they loot invertors and
make your life worst than hell, there was attempt to kill me, now when I
returned to Indian I sought legal opinions and sent legal notices.
Notice A
Standard Chartered Bank, Legal and Compliance, UK

&Europe
Sub: Complaint against your Dubai branch office about supporting and
shielding criminal activities against general public.
From:
Dayal Mansukhani
Ref#: 20060726105632GL5Z_GL5_49_0.dat) - Reply to your mail
The Managing Director,Standard Chartered Bank, Legal and Compliance,
UK &Europe 22 Billiter Street London EC3M2RY Telephone
+44(0)2072807477 Fax +44(0)2072807478
customer.feedback@hk.standardchartered.com
Dear Sirs,
Sub: Complaint against your Dubai branch office about
supporting and shielding criminal activities against
general public.
I am an Indian businessman who was in Dubai for 25 years and then shifted to Australia for 4
years. I was in the activity of transport business, mechanical works etc and in the course of my
business it was usual for me to accept cheques with bank guarantee on the cheque. In such cases
it was a practice to mark the cheque as Good for Payment. I was not a customer of your bank.
However I had dealing with your bank due to cheques received by me from your client. These
cheques were dishonored; there were serious allegations of fraud and crime. There has already
been some passage of time and it is likely that you may at the very beginning be inclined to treat
this communication as an effort to re-open a closed matter. However, please bear with me and
read on this communication.
I am writing to you today after having realized that this was not a single or isolated instance.
Thousands of innocent businessmen suffered losses running into millions of dollars due to a well
planned crime by certain criminal elements acting in collision with the insiders in your bank. The
top officials of your bank clearly understood the seriousness of the matter. However they wanted
either to save their face or to protect their skin and hence they did not report the matter to you.
The strength of your organization was misused by the top management in Dubai for thwarting
justice. This was also against your policy of Corporate Governance. Secondly I have my serious
doubts that these top officers were having prior knowledge of the crime and they were supporting
the same. Maybe what I discovered is only the tip of the iceberg. I do not know whether these
people had any role in money laundering or in channelising funds for terrorist activities.
As an Indian citizen I am duty bound to inform true facts to you, so that you can take steps even
today to set your house in order. After the terrorist attack on World Trade Centre the entire world
has adopted special laws to protect banking system from misuse. In the light of changed
4
circumstances, I would like to state that the previous conduct of your Dubai branch should be
looked into in a proper perspective. Dubai branch of your bank had deliberately and willfully
indulged into the practice of issuance of fraudulent bank guarantees and collecting income other
than through official channels. I was one of the victims of this practice. One of my own debtors
namely one Mr. Raj Bernard submitted to me cheques which were marked Good for Payment.
When I tried to encash these cheques in your Dubai branch, your Dubai branch did not make
payments.
Please note that this was not the case of the fraud committed by only a third party. It was clearly
admitted by your Dubai branch that your own officers had signed those cheques as Good for
Payment I was further informed that the concerned officers had left the services of your bank
and they were no more available in United Arab Emirates (UAE).
There were alterations in the cheques. These alterations were duly attested by your officers. A
stand was taken by your Dubai branch that the signatures of the officers with regard to attesting
of the alterations were not genuine signatures. Thus your Dubai branch merely disputed the
signatures on alterations. It did not dispute the signatures on the original guarantee. The matter
was investigated by the police authorities in Dubai. Unfortunately I was fighting the case singlehandedly. I did not have any legal assistance. Secondly I was not aware about the total volume of
the fraud .It was only at a later date that I came know that hundreds of people were similarly
cheated by your officers. The modus operandi was as follows:-
1) Your officers used to dishonestly and fraudulently issue confirmations of Good for
2)
3)
4)
5)
Payment without credit inquiries and without there being a clear balance in their
accounts. These officers might be doing so for their own benefits, but the fact remains
that hundreds of such cheques marked as Good for Payment were making rounds in
the market. Innocent parties were accepting these cheques in good faith.
The business community in Dubai was believing in such cheques and was lending funds
against such cheques on the belief that on due date your bank would make payment.
It appears that your officers were not deliberately keeping any internal records for these
types of cheques, in other words market credit was used under the stamp and seal of your
bank. However, legally there was no record with your bank.
This was a dangerous situation. As and when the cheques were likely to be dishonored, it
was bound to create havoc. This indeed happened when the cheques started bouncing.
When the top officers came to know about the fraud it was necessary for them to
immediately nab the culprits from your own bank and hand over them to the
investigating officers in Dubai. By doing so they could have interrogated the guilty and
found out the exact quantum of the fraud. Thereafter all victims could have been given
compensation by claiming the same from the insurance company.
I am aware of the fact that as per principals of Corporate Governance your bank is taking
insurance policy to cover itself against a fraud. You have to complete certain formalities for
this purpose such as filing a complaint with the police, cooperating with the police, setting
right your internal systems etc. This should have been done by you in fairness and keeping in
view your policy of corporate governance; however the top bosses in Dubai were hesitant to
5
take such straight forward actions. This is because they might have feared disciplinary action
against them. Either they were in collusion with the junior officers who had committed the
fraud or they were negligent in not controlling the junior officers. I would not hesitate even in
suspecting that the top officers might have very well shared the gains of such unethical
practice adopted by the junior level officers. Then the cheques given to me bounced back
with a reason Refer to Drawer, I was shocked. This is because the cheques were drawn
by your banks client and were marked Good for Payment by your own bank. Therefore
there was no question of returning of the cheques with a reason Refer to Drawer, I took
up the matter with drawer of the cheque as well as with your bank. Since it was not possible
for me to simply accept the dishonored cheque when I had in the first place accepted the
cheques only and only because your bank had given its guarantee that the cheque would be
honored.
Then your officers came and personally discussed with me. They in fact admitted that there
was something wrong within your bank and there appeared to be a fraud on the part of some
of your own officers. I was advised to once again represent the cheques. Accordingly I
represented the cheques but to my dismay the cheques were once again dishonored. At this
juncture the bank came out with a new theory that there was alteration in the cheque. (This
was a dishonest stand. If at all there were alterations, the bank should have pointed this out
in the first instance itself) The alteration was taken up with the police authorities. Then the
police authorities started the investigations. I placed forward the following facts before them:
1) The bank was not disputing its guarantee but was confining its allegation about forgery
only in respect of the alterations made in the cheque.
2) Throughout the investigations, the bank did not even whisper a word as to whether the
account had sufficient balance on the date on which the guarantee (i.e. Good for
Payment noting) was originally issued. If the noting was issued at a time when there
was no balance, this per se showed involvement and fraud on the part of the officers.
3) The bank also did not whisper a word throughout the investigations as to whether the
original noting/guarantee of Good for Payment was duly recorded in the banks internal
records. If this aspect was looked into, the fraud on the part of your junior officers would
have come to light. The investigations (both by police authorities as also by the internal
authorities) were bound to be incomplete unless the above aspects were duly disclosed
and looked into.
4) There was also a need to check and investigate into the cheques that were previously
honoured by the bank. There was a clear likelihood that a number of cheques with the
noting Good for Payment were presented to your bank and were honoured even though
the cheque-passing official must have noticed at the time of passing the cheque that the
Good for Payment noting is appearing without any internal records at the bank. In
other words, if the banks officers had passed cheques in past by overlooking the apparent
irregularity, this aspect per se showed that there was an involvement of the local
management.
5) It was ridiculous for your Dubai Branch to take a stand that the cheques were originally
issued with banks Good for Payment noting and were just lying with me. It was
undisputed that I was payee of the cheques. In this situation, there was no reason for me
as a businessman to withhold the cheques with me. When the cheques could have been
very much encashed by me even previously there was no reason for me to withhold the
cheques.
6) I also made complaints with various other authorities including the Central Bank of the
UAE. The Central Bank of the UAE informed me as per its letter dated 11 th may 2000
that the entire matter centers around with alterations in the dates on the cheques in
question. The refusal of your bank to honour the claims was based on such alterations and
I was further informed by Central Bank of the UAE that your bank is prepared to defend
any court proceedings which may be brought against it. Therefore I was advised by the
Central Bank of the UAE that I should take whatever action I deem fit to solve this issue.
Thereafter I approached your bank from time to time and even lodged a complaint against
your bank with the office of the banking ombudsmen. The matter was reviewed by your
office and I was informed by a letter dated 8th September 2000 that your banks position
had not changed from that setout in previous letter dated 28 th July 1998. Thereafter my
complaint was once again rejected. The office of banking ombudsmen in London took a
stand on the basis of submissions made by your bank that my complaint related to
banking activities in Dubai and has no relevance to banking services provide in the UK
(United Kingdom). Accordingly my complaint was rejected on grounds of jurisdiction; I
was left with no option of pursuing the matter in London. In this connection I was further
informed by the office of the banking ombudsmen as per letter dated 02 nd October 2000
that they would not deal with my complaint because my complaint related to a banking
service in Dubai which is outside the United Kingdom.
CHANGE OF CIRCUMSTANCES:
Prima facie it may appear that the present representation is belated. However you may
appreciate that during this period I was not able to pursue my case on account of a number of
circumstances beyond my control. Secondly there is also a change in circumstances during
this period as explained herein below:
I was in Australia for 4 years between 2002 to 2006 and I returned to India recently,
thereafter I consulted Legal firms as also certain NGOs in India who assist non- resident
Indians (NRIs). For the first time I came to know that my grievance and my complaint is not
an individual complaint but a complaint which is of a representative nature. Then I recalled
my experience in the light of the advice received by me I learnt that the offence was much
more serious than what I was thinking.
At this point of time, the relevance of the above referred aspects as per Sr. no. 1 to 6 above
was brought to my notice by some of the other victims of the crime.
The bouncing of the cheques had not occurred only in my case. Hundred of cheques had
bounced. Secondly in my case it was a straight forward transaction. In case of others there
were more complications. Thirdly I could sustain the burden due to my good financial
position as I was already a successful businessman. However a number of traders
market in Dubai became bankrupt and they had to run away from Dubai. They had huge
amount of sundry returns who had given them guarantee cheques from your bank. When
these traders realized that the guarantee cheques were fake in the opinion of your bank they
were shattered. Your bank disowned its responsibility and refused to pay, the individual
traders had no other option but to either to declare bankruptcy or to simply leave the country.
Hundreds of careers were shattered and hundreds of families were ruined.
If it was only relating to my case it could have been understood that it is a stray incident of
fraud or offence. However how this could happen in hundreds of instances? It was evident
that your officers had a role to play in the entire fraud. This generality of the fraud made it
clear that the adversarial position taken by your bank was unjustified and was unbecoming of
a banker. Your bank ought to have first investigated whether its officers had any role and
thereafter taken steps to file a police complain against its own officers. This could have
facilitated obtaining payment of insurance claims against fraud and to make payments to all
the victims of the fraud. Instead your bank decided to deny the very truth about fraud at the
cost of innocent victims of fraud who had believed your bank.
After a passage of time your bank might be under an impressions that the issues have become
infructuous and hence nobody can take any measures against your bank. However with the
recent campaign in the world against the use of banking channels particularly by criminals and
terrorists groups, there is a ray of hope for a person like me to reopen this case and seek justice.
If your bank had taken this position in the past and is not willing to reverse the position even
now, then your bank cannot be safe for general public today. If your bank had taken this position
in U.A.E there is no reason why it cannot take such a position in India. Therefore unless your
bank changes its stand and adopts a new position it would not be desirable for various countries
to continue with the banking licenses given to your branches.
As you aware in countries like India, an individual incident is differentiated from a general
phenomenon. In this particular instance there was a general phenomenon which affected the very
basis of the existence of your bank as a sound financial institution. However, you deliberately
pushed the matters below the carpet.
I am enclosing some of the vital documents by way of attachments. If you go through the
letter dated 5th August 1998 addressed by you to the police authorities, it would make clear
to you as to how your branch officers were dishonestly and fraudulently acting. When the
letter was issued in August, the bank was already aware about future dishonour in October! This
is ridiculous. This shows that the bank was playing a game. The real fact was as follows:
1. I had two cheques received from Mr. Raj Bernard. One cheque was dated 15 th July 1998 and
the other cheque was a postdated cheque bearing the date 15th October 1998.
2. On the cheque dated 15th July 1998 there was no alteration at all. It was also duly marked as
Good for Payment
3. The cheque dated 15th October 1998 was bearing an alteration in date. However, the alteration
appeared to have been authenticated by your officers. I had accepted this cheque in good faith. I
was not aware of any fraud.
4. When I presented the first cheque dated 15th July, it was dishonoured with the reason Refer to
Drawer. I was shocked and I contacted the bank. After telephonic discussion, the officers of
the bank came to me and informed me that there is some internal fraud due to which a number of
officers were shifted/terminated by the bank. They also informed that they had terminated credit
facility of a number of clients whom they suspected to be involved in the fraud alongwith the
officers. However, they agreed that I am entitled to encash the cheque. Accordingly, I presented
the cheque again. This time, the bank returned the same with the reason of Alteration.
5. This left me with the only alternative to issue a legal notice to the bank as I was convinced that
the bank was trying to refuse payment of a lawful obligation on some or the other pretext. When
I issued a legal notice, the bank realized its mistake of taking the matter lightly. The bank
realized that I would not leave the matter in the middle. If there was really an alteration, there
was no reason for bank to keep quiet between 15 th July to 18th July 1998. The bank must have
filed police complaint forthwith. Bank did not do so. Bank also did not file a police complaint
on second presentation. It is pertinent to note that only when I got a legal notice issued that the
bank decided to file a police complaint. This was afterthought to cover up their lapses.
6.When the bank became aware of the difficulty that they would face on account of their officers
misdeed, they first filed a police complaint thereafter based on the information that they had
received about the cheque dated 15th October 1998, they tried to paint a dark picture of mine as if
I was involved in the fraud. When the bank was in interaction with me, I myself had shown them
the cheque dated 15th October 1998 in good faith.
7. Your officers then made a strategy to take advantage of the probable deficiency in the cheque
dated 15th October. They did not give me a hint and in fact did not object to the second
presentment of the cheque. However, in their letter written to police authorities in August 1998,
they make a mention of the cheque dated 15 th October as if they were making a forecast of the
future. If they were going with clean hands, they should have narrated that they have found the
cheque in my possession which they suspect to have been fraudulently made out with a
guarantee. However, they did not aver so. On the contrary, they mentioned that the cheque was
presented on 15th October 1998.
6. As regards the cheque dated 15th July 1998, the bank did not allege of any fraud at the time of
first dishonour. They merely advised me to Refer to Drawer. They did not allege any
alteration. They did not allege any fraud. They in fact orally agreed that the cheque should be
once again represented. However, when I represented the same, they came out with the theory of
forgery or alteration. This they did only on the basis of the knowledge that they gained about
the cheque dated 15th October 1998 and after they realized that I am going the legal route.
7. Therefore it is crystal clear that whatever may be the position of cheque dated 15 th October
1998, the previous cheque dated 15th July was very much a bonafide cheque. Bank dishonoured
the same wrongly and routinely as the bank was dishonouring a number of cheques in defiance
of its obligations. When I lodged police complaint and when the bank officials came to know
that the deficiency in cheque dated 15th October could be utilized to tarnish my image, the bank
decided to falsely claim that even the previous cheque dated 15th July was altered.
8. With this fraudulent objective, the bank brought out chemical alterations in the cheque and
thereafter did not even return the cheque.
9. Dishonesty of the bank is clear from the fact that if at all the cheque dated 15 th July was really
a forgery the bank ought to have suo moto lodged a police complaint on first presentation of the
cheque on 15th July 1998. Why the bank did not do so? Why did the bank wait for two
presentments and thereafter filed a complaint only on receiving my legal notice.
Sir, Fraud has two definitions. One is internal fraud and another is fraud by a third party. If
there was an internal fraud, the bank could not dispute its liability. E.g. someone buys traveler
cheques and the bank officer had misappropriated the amount received from buyer of the cheque,
this is an internal fraud. If the buyer of the cheque delivers the cheque to a shop, the shop cannot
be denied reimbursement. My case falls under this category. I had received the cheques in good
faith. I was not a party to the fraud. If Mr. Raj Bernard had colluded with your officers, how I
can be punished?
When the cheque dated 15th July was presented, the bank ought to have realized that there is no
internal entry about the Good for Payment noting. However as the signature was genuine, the
bank had no defence. However as the bank was confident of its power and empire, it still tried
to return the cheque. When I issued legal notice, the bank officers were angry. In the meantime,
the bank officers had knowledge about the cheque dated 15th October 1998 and the bank officers
made a strategy to mix up various issues.
The Government examiner (i.e. Public Prosecution In-charge) had initially held (In terms of his
report no. 19/5412 dated 25th April 1999) that the cheque dated 15th October 1998 did not bear
alteration. However, subsequently in my absence (i.e. when I was in Australia), your bank
obtained a report dated 30th September 2003 on fresh examination of the cheques. If you desire,
I shall send this report to you. This report mentions about alteration but is not sure about the
same.
Thus there is some tampering with the cheque. However, who did this tampering is a matter of
mystery. In my clear view, your officers themselves had tampered with the cheque after 15 th July
1998. If the tampering took place before 15 th July1998, your officers should have filed a
complaint.
The bank first rejected the cheque on grounds of Refer to Drawer and then on grounds of
alteration. When Government prosecution upheld my side and when I presented the cheque, it
was returned on grounds of time-limitation.
Now in September 2003, the final report is still inconclusive. In the civil case too , your bank
did not take a fair stand and in fact adopted an adversarial stand
Every action of the bank was an afterthought as evident from the above.
Even now it is not late. I hereby call upon you to take following actions:
1. Call for all records of the case from your Dubai Branch. If you desire, I shall provide you
with all documents that are available with me.
2. Check up the record of the officers that were shunted out during 1997-99
3. Also check the accounts where the credit facilities were called off during this period
4. Also verify the records of all police complaints as also all cheques that were marked
Good for Payment and were bounced on presentation. Check the same with reference
to internal notings and correspondence of the Dubai Branch
5. Upon getting satisfied about the bonafide of my complaint, please take suo moto legal
action and also make reimbursement to me.
6. You may also do some introspection and find out through your own sources as to how
many businesses were destroyed during 1997-99 due to abrupt closure of facilities by
10
you, what was the reason for such abrupt actions, how many other banks and innocent
third parties were affected due to illegal return of cheques by you.
If you still fail to act in the matter, I shall take following measures against your bank:
1.
2.
3.
4.
I shall file fresh civil/criminal cases

I shall inform the regulating authority in U.K.
I shall caution the regulating authorities all over the world where your bank has branches.
I shall take up the matter with anti-terror organizations with specific demand to check up
money-laundering and criminal nexus activities of your officers.
5. I shall file petitions in every possible court (including Dubai, London and Mumbai) to
cancel your banking license.
6. I shall issue appeals and public advertisements to call for full information from General
public in Dubai as to how many businessmen fled Dubai due to abrupt closure of
facilities, how many businesses were shut down due to pressures from your bank, how
the affairs of other banks were affected due to wrongful dishonours by your bank.
Sir, I have only one request. I might have suffered some setbacks in legal battles due to my own
shortcomings. However, I was on right path. Mere passage of time or mere delay would not
exonerate your bank from the fact that a crime has taken place. I have now presented a holistic
picture to you.
Please look into the matter and take up the matter for a full-fledged investigation. If your desire
any additional details or co-operation from me, I am every ready for the same.
11

Mr. Sanjeev G.Punalekar, Advocate, High Court, 315, Birya House, 265, Perin Nariman
Street, Bazar Gate, Fort, Mumbai 400 001.(India). Mobile no. 0091-9820095814
Yours truly
Dayal Mansukhani
This letter confirms that Bank issued Bank guarantee in my favour, therefore I must get payment
and this Bank Guarantee they prove the above mentioned.
12
13
Only Dubai Government can except that 15th October 1998 comes before 5th
August 1998.
14
15
16
17
18
19
This letter proves that Bank filed criminal case against me was wrong.
20
21
Nowadays name of Dubai and UAE is on the top of guineas book of world record like AlBurj - 7 Star Hotel, The longest
Gold Chain, the biggest Cake, the biggest Shawarma kebab and some more. Some of the
world records are broken by
22
Dubai and UAE. I am giving the proof of all these World Records to you but you have
censored it.
1)
Only In Dubai and UAE the bank returns the bank guarantee cheque refer to
drawer.
2)
Only in Dubai, Money and Power have more say than Law.
3)
Only Dubai Government can except that 15th October 1998 comes before 5th
August 1998.
4)
Only in Dubai a Crime is committed by a Person for its own loss.
5)
Only Dubai Government agrees to Photocopied Documents and not the Original
Documents.
6)
Only Dubai Government believes that a Bank Guarantee
cheque received by someone for 300,000 dirhams in 1996 and the person waits for 2
years for his own money, and recovers the money after doing a crime.
7)
If an Indian Citizens Bank Guarantee cheque in Dubai is
returned, then an Indian Citizen has no right to take the
matter to the court. If
this is done then a Case will be filed against the Indian Citizen. Pressure is being put on
him to make him sit down and not to appeal against this injustice
8)
Only in Dubai Hospital on 10th July 1999, Indian Citizens Heart Operation is
cancelled before 5 minutes it was supposed to be commenced.
9) 25 years Dubai Resident Indian Citizen does not get justice for 5 years from Dubai
Court.
10) All these points mentioned above have there proof on the website
http://www.ineedjustice.net
11) All these incidents are facts which have proof and nobody can buy these documents
with
money.
DAYAL H. MANSUKHANI
Notice A
Standard Chartered Bank, Legal and Compliance, UK

&Europe
23
Notice B
WITHOUT PREJUDICE
To,
Keith international(Besco International)
Mr. Raj Bernard
Phone 009714 3528282
keithintl@emirates.net.ae
Sir,
Sub.:
Legal cases between your concerns and my concerns.
3. I am addressing this communication to you with a view to notify you about certain
proposed actions so that you may be in a position to take timely steps for avoiding a
prolonged litigation and costs for you.
4. At the outset, I place on record that every order and decree passed by the Courts of Law
in Dubai by which I have been aggrieved shall be carried out in appeal at appropriate
forums.
5. As you are aware, I was out of Dubai for a long spell of time and I had my own
difficulties, these facts are a matter of record and so long as I approach in higher forums
with clean hands and properly justify the grounds for delay, I do not find any reason as to
why the cases already decided cannot be reopened. Therefore in the very beginning I
would like to make it very clear that if you are under a mistaken notion that any of these
judgements / decree/ order has reached finality, you ought to realize that I have not given
up the legal cases.
24
6. After recently coming to India, I have consulted not only various law firms but also a
number of Non-Governmental Organizations (NGO) who have guided and advised me
graciously and even volunteered to offer legal aid and assistance to me in my legal cases
in Dubai. Secondly, my close relatives and business circles have offered me immediate
aid for making a deposit of the amount of adverse judgement in the court to show my
bonafides so that the court may reopen the cases. Hence on two counts viz. proper legal
aid and financial capacity to get cases reopened by offering deposit of the amount, I do
not suffer any disqualification or incapability and please be rest assured that I shall be
taking steps to reopen the cases very shortly. However, as you are yourself a party and
witness to what has all along been happening for the last 5 years, I am duty bound to
inform you that a new phase of legal battle may keep both the parties indulged- may be
for another 3 to 4 years. This may not be desirable for either of the parties. Secondly, as
usual in any legal case, I would be exploring every possible legal means for the purpose
of getting justice.
7. It is imperative for me that
i)
every possible information and document is brought on record
ii)
every person and entity which has acted against my interest is properly and lawfully
penalized.
8. Accordingly, I have already issued appropriate notices not only to the court appointed
accountant but also to my own legal advisor. I have also addressed appropriate
communications to your previous local partner and I shall be marking a copy of the same
to your new partner. It would be my endeavour before the court of law to establish that
the court -appointed accountant acted in a manner prejudicial to justice and he was
negligent and prejudiced in his whole approach. The errors made be him in analyzing the
data are enormous. You are yourself aware that the accountants report is based on not
only inadequate information but also incorrect information supplied by you. Legally, this
is treated as perjury and contempt of court. Whatever may be the reasons for the
accountant to give adverse report against me, the consequence of reopening of cases
would have to be suffered by you not only in terms of legal cases but also in terms of
penal actions and punishments from courts of law. It is already on record that in criminal
25
proceedings initiated by me, you admitted your liability before the court of law in Dubai,
Sharjah and Ajman and you were making mainly two pleas viz. i) you needed time to
settle, ii) you wanted me to resort to civil remedy. The above two statements from you are
part of records and accountants report in any manner will not erase the past records.
Maybe because I was abroad and because of communication gap or maybe because of
errors on the part of my lawyer, a holistic picture was not available to the court of law.
However, if I now bring these facts on record and at the same time offer to deposit the
amount, the chances of getting cases reopened are bright.
9. Apart from your contradictory statements before different courts of law, records with
regard to cheques given by you from time to time speak for themselves. It is apparent
from the past record that you have not disclosed the entire gamut of transactions to the
court. You have indulged in exercise of intentional concealment of facts and therefore
once I bring these facts on record, you would be liable for additional perjury.
10. I also wish to inform you that the issues relating to Standard Chartered Bank are also
being reopened. In fact I have realized that the issue was too serious and was not my
individual issue alone. I have issued notice to Standard Chartered Bank. The draft of the
notice was provided by top law firm in Mumbai who has advised me that I must file
petition through their associates in London and in Dubai for withdrawal of licence of
Standard Chartered Bank. You are aware of the fact that the whole world is today fighting
war on terrorism and the role of banks in criminal activities and money laundering has
been focus of not only USA but entire world supporting war on terrorism. The manner in
which Standard Chartered Bank acted was so unethical and records are so clear that the
issue is bound to be reopened. The fact that these cheques were given by you is not
disputed at all. I was not a customer of Standard Chartered Bank at any point of time.
11. So far dispute with Standard Chartered Bank was limited to the extent of their liability to
me. Due to this your role was overlooked. Now when I reopen the matter, Standard
Chartered Banks top authorities are bound to utilize their entire energies and funds to
find out who is the real culprit who has put them into this difficulty. My initiative against
Standard Chartered Bank will ensure that they set their machinery into motion to nab the
real perpetrators of fraud. This will not stop at their own officers, but the clutches of law
26
will reach you one day. You are an Indian on foreign soil. You are already aware about
the fate of those who are in jail in Dubai for various crimes. So far you might have
temporarily succeeded in saving yourself. However, once the law takes its own course
particularly with reference to the seriousness for a financial giant like Standard Chartered
Bank you will have no escape route.
12. The action through Standard Chartered Bank, coupled with action through your local expartner, would create a situation for you wherein you will be facing only adverse actions
on foreign soil. So far as I am concerned, I will be in a safer position with a clear-cut and
straightforward case wherein I would be depositing the amount and seeking relief from
court of law. This itself would be sufficient testimony to my honesty and sincerity.
13. I would also like to add that as per the Indian law, it is permissible for me to prosecute
you even in India since the offences committed by you were against an Indian and
provisions of Indian Penal Code clearly provide that offences on foreign soil are also
covered so long as they are between two Indians. My law firm in India would move upto
the highest possible level to see that strict possible summons and warrants are issued
against you and if possible, properties in India (including in Kerala) are attached. If you
are declared a proclaimed offender in India it would be difficult for you even to leave
Dubai wherein you would already be under legal attack from those you have put in
jeopardy.
14. You may find from the language and tenor of my communications to your local expartner as well as my communication to Standard Chartered Bank, that I am serious about
the matter. I have also made up my mind that irrespective of costs that I have to incur, I
will chase the matter.
27
Mr. Sanjeev G.Punalekar,
Advocate, High Court,
315, Birya House,
265, Perin Nariman Street,
Bazar Gate, Fort,
Mumbai 400 001.(India). Mobile no. 0091-9820095814
16. In respect of exploitation of Indian labourers by you and your accomplices, I have alerted
the Human Rights activists in India, who advised me that after making a preliminary
assessment of the situation in Dubai, they would like to prepare a documentary film by
interviewing various workers who were duped in Dubai. One of the labourers had to
commit suicide due to harassment. When these facts are presented before the world, all
the pending cases filed by the workers will also be brought to limelight.
17. In view of the above, it is advisable for you even now to offer to settle the matter
amicably. As you may observe from the above, a number of actions that I have proposed
are irreversible and once I proceed further, it will be difficult for us to enter into any sort
of settlement or compromise. As a businessman, I wish to take commercial call in the
matter before a fresh phase of legal battle commences. Previously damage suit of Dirham
10 Mio. was filed against you and my present lawyer will be filing damage suit for
Dirham 20 Mio. When I would be filing such damage claim, my interest would be to
genuinely recover the amount and not to have paper decree. As on date judgements which
you have against me have no practical enforceability since I am in India. Still I am
28
venturing to enter Dubai and risk my person and my finances. This alone should make it
clear to you that your stakes too are very high now.
I call upon you to convey your response within 7 days failing which I shall proceed
further by concluding that every avenue for negotiation has failed.
Thereafter the
responsibility as to costs and consequences shall be yours.

Yours truly,
DAYAL H.MANSUKHANI
Bernard Raju's labourers complaint of slavery

Bernard Company's refusal to pay advance of Dhs.20 provokes worker to commit
suicide, Co Gulf based Labour Supply Companies Squeeze Expatriate
WorkersBernard Company's refusal to pay advance of Dhs.20 provokes worker to
commit suicide, Co
DUBAI -December 11, 2004 More than 300 workers of a labour supply
company are sad and anguish about the poor working conditions
highlighted by the death of a colleague apparently due to suicide
provoked by the nonpayment of salary. According to the agitated
workers, A Venkatesh, an electrician who hails from the South Indian
state of Tamil Nadu, was suffering
DUBAI - Labour supply is a lucrative business for

many prominent Malayalis who specialize in
rampant exploitation by squeezing out maximum
profit from it by giving marginal salary to workers
and pocketing major chunk of their daily earning.
While major companies give to labour companies'
upto Dhs. 13 per hour, the worker gets Dhs. 4
and sometimes Dhs.5. He came to Dubai on 27
November 2003 as an electrician, but was given
work as a helper and paid just Dhs.4 per hour.
Full Report
http://www.keralamonitor.com/suicidemedia.htm
29
Notice C
DAYAL H. MANSUKHANI
Flat No.19, Malkani Mahal, Self-Help Co-operative Housing Society, 261, Dr. Annie Besant
Road, Worli, Mumbai 400 030, India. (Phone/Fax- 0091-22-24384011)
To,
Ahmed ABDULLA MAHAMMD AL Mulla

P P NO A 851222
Sub.:
I, Mr. Dayal H. Mansukhani, residing at the above mentioned address hereby advise you and put
you on notice as follows:1) I am an Indian citizen and I was in Dubai for around 25 years till I left Dubai for
immigration to Australia in the year 2002. I have three children who are major now. They
studied in Dubai and completed education there. My one son is presently in USA, another
is in UK. I have highest regard and respect for UAE in general and Dubai in particular
since all my prosperity and well being of my family is owed to the support eceived by
me in UAE. In fact it will not be out of place to mention that in my business in Dubai, I
had a local partner from Ajman. He was my partner for around 20 years and we shared a
cordial and mutually beneficial relationship.
2) UAE has its own laws and systems as per which a foreign businessman has various
options to make use of his business capabilities with a proper involvement of local
partner. He has an option either to work under UAE citizen as his manager whereby the
entire business is essentially that of the local partner. In the second option, a foreign
businessman may adopt a corporate structure of business with majority stake for a local
partner. In the first option, the local partner being in the nature of a proprietory concernhas tremendous personal responsibilities and liabilities. If his manager commits any
irregularities thereby incurring civil or criminal liability, the local partner has to suffer.
This is the reason why local partner exercises utmost care in choosing their business
associate in the form of manager/ power of attorney holder. The other form of business is
corporate business i.e. LLC.
30
3) In so far as my dealings with my local partner were concerned, I had relationship

consisting of complete faith and confidence. We had family relationship and a bond
between us is unaffected even after I did not return to Dubai for the past 3 to 4 years.
4) In the corporate form i.e. LLC, the liability is limited. Nevertheless, the stake of UAE
citizen is a majority stake.
5) I am addressing this communication to you to give you a timely alert about number of
illegal, unethical and unscrupulous practices adopted by Mr. Raj Bernard whom you
trusted and relied upon in the past. The purpose of this communication is to convey you
the serious jeopardy in which Mr. Raj Bernard has placed you by virtue of his various
illegal actions as explained in the paragraphs herein below.
6) Till date you have not suffered any personal liability. However, things have already
reached a level wherein adverse consequences for you would become inevitable in near
future. Nevertheless, if you take timely measures, crisis can be avoided, hence I am
cautioning you in the matter.
7) First of all, you being a resident of Ajman and occupying a very important position in
Labour Department in Dubai, the labourers and workers coming over to Dubai from
Indian and other Asian countries already had a feeling of great respect for you. Generally,
in sensitive matters such as labour department, a resident other than of Dubai would get a
powerful position only when he is highly capable and trustworthy for the local
government of Dubai. Naturally, you had earned reputation and respect. However, you
may not be aware how Mr.Raj Bernard misused your name and position for his own
undue enrichment. Maybe you acted in good faith and trusted Mr.Raj Bernard. However,
you ought to be aware of the fact that hundreds of work permits were issued under your
authority and jurisdiction on the initiatives taken by Mr.Raj Bernard and Mr.Raj Bernard
made use of your clout to bully the workers and exploit them. There were serious
allegations against Mr.Raj Bernard as to how he terrorized the workers and deprived them
of their bare minimum subsistence salaries on some or the other pretext. The time period
of 1995 to 1997 which was crucial for you with regard to business partnership with
Mr.Raj Bernard, maximum number of cases were filed by hapless and helpless workers
against such malpractices. There was a whisper about suppressing those cases which
31
actually amounted to abuse of human rights, solely by the virtue of your good name in
the department. There was also an instance where a worker had to commit suicide. Thus
Mr.Raj Bernard fully exploited your name and position to deprive third parties of their
legitimate dues. Needless to add that such behaviour also was contrary to the basic
religious tenet of sweat money which is the most sacred principle in Islam. Even today
there are a number of disgruntled, hurt and aggrieved workers who are waiting for
redressal of their grievances.
8) I have explained this background to you so that you can take stock of things yourself and
in the light of such insight, you will be in a position to appreciate my grievances against
Mr.Raj Bernard properly. If I confine myself only to my individual grievance, it may
prejudice your analysis since after all myself and Mr.Raj Bernard engaged in a very fierce
legal battle. However, if you take a view of my dispute in the light of overall behaviour of
Mr.Raj Bernard, the truth would become clear to you. Mr.Raj was acting as your Local
Manager and managing the business on your behalf. Subsequently, he left you and
searched another local partner with whom he commenced his business activity in the
form of LLC which was named as Bresco International LLC. In the usual course, there is
nothing wrong if there is a change in the local partner (even though I myself had the same
local partner for two decades). What is important is the dishonest manner in which
Mr.Raj Bernard intermingled the various matters and deliberately created confusion to
cheat and defraud third parties. Though the local partner was changed, the line of
business of Mr.Raj Bernard was the same.
9) When he started business in the form of LLC and that too with another partner, he ought
to have first of all properly closed down all pending matters of his previous business
wherein you were involved in your personal capacity. This required Mr.Raj Bernard to
not only close the previous bank accounts, but to see to it that the cheques which were
issued from the previous accounts were properly obtained back. Wherever such cheques
could not be obtained back (for example:- due to misplacement by third parties), Mr.Raj
Bernard should have properly issued notice to such third parties and closed all financial
transactions with the third parties. In instances requiring further action, he ought to have
issued proper stop payment instructions to the bank. If he has not done so, it became
your responsibility to complete this task.
32
10) There were only two options. Firstly, Mr.Raj Bernard should have completed this paper
work and handed over things to you. In the second alternative, you should have yourself
done this job. Unfortunately, both these things were not done. Cheques issued on behalf
of your firm were making rounds in the market. Not only this, these cheques were
marked good for payment by your bank. In many cases, cheques were even revalidated
by the bank officers showing that the transactions were valid and were being renewed
from time to time. I enclose herewith a copy of notice that was sent to Standard Chartered
Banks London office recently. You will find from the same that there is a very serious
fraud in the matter of cheques marked as good for payment. In this fraud, the officers
working in Dubai Branch of Standard Chartered Bank were deeply involved and it was
Mr.Raj Bernard who appears to be the brain behind the fraud.
11) However, the fact remained that the whole episode has taken place in the name of your
firm. In other words, even though Mr.Raj Bernard left you and started his LLC with
another partner, the perpetration of fraud was in the name of your firm. If you make
necessary legal consultations, you would realize that even after passage of time it is not
too late for third parties to now fix up the liability on your shoulders. This is because
Mr.Raj Bernard was acting as your representative and the onus to prove that you had
taken proper steps for properly snapping ties with Mr.Raj Bernard and with third parties
who dealt with you through Mr.Raj Bernard is consequently on your shoulders. It appears
that taking advantage of your lenience and trust shown by you, Mr.Raj Bernard has
placed you in this predicament. Legally, the course of action against you arises now
when the true picture has emerged as above. Fortunately, it is not too late even now for
you. Mr.Raj Bernard is very much available on the soil of Dubai. Legally you are still
having rights to seek proper accounts from him and obtain and insist that every piece of
document and paper which he is holding should be handed over to you because he has no
right to hold the same. Wherever there are any gaps or missing links, you have the right
to get proper explanation and proper accounts from him. If creditworthiness of your firm
was misused for the purpose of fetching credit to his new company with a new partner,
then you are entitled to sue not only Mr.Raj Bernard, but also his new local partner. This
is because the funds that are in the kitty of LLC are raised by exposing you to various
33
liabilities and risks. Naturally, you are entitled to enforce your claims against the huge
contingent liabilities to which Mr.Raj Bernard has exposed yourself.
12) Needless to mention that if the burden and onus finally falls on your shoulders, it would
not only tarnish your image but would also expose you to wraths and penal action at the
hands of governmental authorities in Dubai. Despite being resident of Ajman, you were
successful in winning over the confidence and respect of the administration in Dubai. All
this is at stake today only due to the misdeeds of Mr.Raj Bernard. Once downfall begins,
the old cases of labourers and workers are also bound to surface and the whole episode
wherein Mr.Raj Bernard committed a number of irregularities and frauds would
ultimately boil down to fixation of liability and responsibility only on you. This can be
avoided if you take timely actions.
13) I am determined to reopen the case with Standard Chartered Bank and also take up the
matter with the authorities in UAE and even at the International forums. It is also my
concern that innocent persons should not be penalized unless they are given an
opportunity to take remedial measures. It is with this good intention that I have addressed
this communication to you. It is my request that you ought to take the following steps.
i)
Make Mr.Raj Bernard accountable and call upon him to settle all pending
disputes with third parties so as to safeguard your interest and keep you
protected/indemnified.
ii)
Initiate proper steps to issue notice to the present local partner of Mr.Raj
Bernard and also make use of proper methods including negotiation so that
damages are controlled and reversed. It is necessary to inform the local
partner of Mr. Raj Bernard in time so that if there is any damage to his
interest, he can protect himself. Obtain all previous accounts from Raj and try
to settle the matter with all third party disputants so that your future liability is
avoided.
iii)
Yourself and the present local partner being citizens of UAE, are entitled to
certain rights such as initiating criminal proceedings against miscreants such
as Mr.Raj Bernard. Time is the essence of action and if you act quickly, you
would be in a position not only to protect your interest and safeguard your
34
reputation but would also be in a position to safeguard UAE against disrepute

brought by people like Mr.Raj Bernard.
In this process you will also
immensely benefit from the good wishes of third parties like me whose time,
money and energy in fighting a prolonged legal battle would be saved.
iv)
You ought to act quickly and take steps in the form of preventive measures.
Expecting you to act quickly. I look forward to your response within 7 days. Thereafter I shall
advise my lawyer to move forward on legal route.
Yours faithfully,
DAYAL H. MANSUKHANI
35
36
Notice D
HARIS & ASSOCIATES Auditors & Business Consultants
DAYAL H. MANSUKHANI
Flat No.19, Malkani Mahal, Self-Help Co-operative Housing Society, 261, Dr. Annie Besant Road,
Worli, Mumbai 400 030, India. (Phone/Fax- 0091-22-24384011)
To,
HARIS & ASSOCIATES
Auditors & Business Consultants
P.O.Box No. 31367,
Dubai, U.A.E.
Email: info@ harisaudit.com
Tel.: 00971-4-2959958.
Fax: 00971-4-2959945.
NOTICE
I, Mr. Dayal H. Mansukhani, residing at Flat No.19, Malkani Mahal, Self-Help Co-operative
Housing Society, 261, Dr. Annie Besant Road, Worli, Mumbai 400 030, India, hereby serve
upon you as follows:-
1) I say that in the litigation between Besco International and my firm, you were appointed
as Accountants by the court of law to conduct auditing of various accounts and other
documents and to arrive at conclusions about the amounts due between the litigants. On
the basis of final report submitted by you to the Honble court at Dubai, an adverse
judgement was passed against us. During the period from February, 2002 to February,
2006 our family was in Australia due to which we were unable to concentrate on final
aspects of the report and we were unable to pursue the litigation. Upon our obtaining
legal assistance from experts in India as also some of the Non-Government Organizations
(NGO) who assist Indians having business overseas, serious irregularities in your report
were brought to your notice. Therefore this notice is being issued to you.
37
2) As you were court appointed accountants, you were required to act in fair and transparent
manner with all clear, due diligence expected from the officers of the court. As the future
of the litigation heavily depended on your findings, it was crucial for you to exercise
utmost care not only in receiving various documents and data but also in properly
analyzing the same.
3) Apart from receiving and analyzing data, you were required to exercise extraordinary
care in matters where you were duty bound to expose and bring on record the correct
factual position in the interest of justice.
4) However to our dismay and shock, it is clearly observed that you have conducted the
entire job in a casual and non-serious manner. Instead of going into the roots of the
problem, you have merely added and subtracted various figures and arrived at some
amount for the sake of coming to conclusion.
5) In the conclusion of your report, incorrect statement about non-availability of proper
accounts is found. By your own admission, the appellant company did not have proper
records, however, so far as the respondent was concerned, all records including audit
reports have been listed. In this situation how such a sweeping statement was falsely
included is a matter of doubt.
6) The onus of proof was with the appellant. Surprisingly the appellant did not co-operate
with you and in fact created hurdles. Your own conclusion states that the appellant
company was not even functional. In contrast to such assertion, our lawyer in Dubai now
informs that the appellant has suddenly become active after judgement and is trying to
enforce its rights. Such type of selective persuasion of a case is against the basic rules of
justice. If the appellant was not functioning and if he was non-cooperating you ought to
have arrived at conclusion adverse to the appellant. Instead of doing so, you went on
exercising simple mathematical addition and subtraction. In doing so, vital information
was contracted or conclusion was overlooked. For example, in the criminal case,
involving the very same parties with regard to the cheque of bank guarantee wherein
forgery was initially alleged, Mr. Raj Bernard made payment over and above the figures
which are reflected in your calculation chart. The fact of such payment also appears in
your report. However, no further investigation is made as to what was the reason for
38
making payment if Mr. Raj was disputing the debt. If he was claiming surplus payment to
us, he should have insisted for refund of this amount as well. It is clear that he was
disinterested in referring to the transactions underlying the criminal proceedings only
and only because of his apprehensions that he would be opening a pandoras box. Thus
the appellant was not merely dysfunctional, he was intentionally suppressing a number of
vital information from you and on this ground alone, you should have recommended to
the Honble Court to dismiss the pleas of the appellant. There was a letter on letter head
of Besco International which is signed by Mr. Raj wherein amounts received by him to
the tune of DHM. 1.4 Mio. has been clearly acknowledged. These payments received
were in addition to the initial loan amount of DHM. 4, 00,000/- For reasons best known
to you, you ignored this letter which was placed before you. This amount should have
been added to the amount of DHM. 4, 00,000/-. Secondly, it was an admitted fact that the
transaction between parties was an interest bearing transaction. Nobody was doing
charity to each other. Initial loan of DHM. 4, 00,000/- was duly recorded in agreement
and tie-up arrangement with the port authorities was also duly documented. Subsequent
payments were proved on the basis of two documents viz. entries in the bank accounts
showing transfer and the letter from appellants acknowledging the amount. Once our case
was proved on these two grounds, and once the appellant failed to demolish these two
grounds, there was no option for you but to recognize this amount of Dirh.1.4 Mio. with
interest.
7) We say that on this amount of DHM. 1.4 Mio., you must have added interest as per the
previous contractual rate. Thus for the plain reason that the fact about transactions being
interest bearing transaction was an admitted position. It is also admitted that the
appellants did not have proper accounts and the respondents had all along co-operated by
furnishing every possible piece of paper. The data of respondents in Australia was very
clear and this acted as corroborative evidence to the above inferences.
8) You may observe that we are not making any fresh submissions. We are merely drawing
your attention to the documents that were in your possession and that in fact find place in
your report much before the judgement of the Honble Court. Unfortunately, your act of
arriving at patently wrong and incorrect conclusions resulted in misleading the court. The
court of law acts on the basis of documents and submissions made by the parties which
39
are appearing before the court. When you drew incorrect and wrong conclusions for the
reasons best known to you, the fault is not that of the court of law. The court heavily
relied upon your report. This was naturally because you were appointed as Accountants
by the court of law. The court of law places its trust in you and this made you trustee for
justice. However, we regret to place on record that you failed and neglected to perform
your duties. We suspect that the attitude on your part was not that of complacence but of
complicity and that you have colluded with the opposite party in a well planned
conspiracy to mislead the court of law. We have decided to initiate proceedings against
you in the matter. However, before things are escalated for the worse, we desire that an
effort should be made for amicable resolution. If you even now assist us in the matter by
approaching the court and inform the factual position to the court with an application to
reopen the matter, the justice that is denied to us can be restored. As on date we face a
number of penal actions thereby creating a number of legal handicaps for us to represent
the matter. However, please rest assures that we would not allow the matter to rest and we
are determined to wash off the stigma on our character and creditworthiness. NGOs in
India have assured us that on our behalf they will knock the doors of judiciary in Dubai.
They are ready to provide us necessary legal assistance and even involve Ministry of
Foreign Affairs of the Government of India. This matter does not involve any single
individual or firm. This is a matter of prestige of the judiciary of UAE. As you have
misbehaved in the capacity of officer of the court, the reputation of the judiciary is itself
at stake. The economy of UAE was built up by citizens of number of countries who made
their fortunes on the soil of UAE and who shall be ever grateful for their prosperity. The
best of the talent from the world and from countries such as India flows to UAE with the
fond hope and confidence that it is a safe heaven. UAE is not only a tax-free country but
is a country wherein the role of law prevails. For that matter I have no hesitation in
submitting that throughout my 2 decades in Dubai, I have always found it fair, just and
safe place. Unfortunately, I was back stabbed at a time when I was out of Dubai on
business mission to Australia. The conspiracy was so heinous that I was even denied the
avenues for reopening the case which would have been available to me if I was in UAE.
This is the sole reason which has aggrieved me.
40
9) It is due to your misbehavior and deliberate omissions that I am placed in this situation.
Therefore I shall have to knock the doors of the top authorities of UAE including top
government authorities. Unfortunately, for any reasons such as communication gap, if I
am compelled to take up the matter with International Human Rights forums, it would be
most unfortunate day of my life. I have enjoyed the prosperity and peace in Dubai and it
would be very painful and troublesome for me that the dirty linen is washed in public at
the international forums. I would like to avoid such situation due to my personal ties with
UAE. Therefore please be fully aware that before things reach such an impasse, I will
explore every possibility to expose your misdeeds before the top authorities of UAE and
if necessary knock the doors of all authorities in India so that the matter is taken up at the
highest diplomatic level.
10) I am fully aware of the fact that considerable time has passed and probably my advisors
would take advantage of this fact to highlight on my part. In this connection, you may
note that I am capable of adducing sufficient evidence in my support to convince the
authorities that I was really helpless on account of number of situations beyond my
control. I do not find it proper to elaborate these factors through this letter. However,
apart from these factors which I would like to explain in due course, is the single factor
that I am basically trying to wash the stigma by incurring further costs itself would per se
convince anyone that my intentions are honest and bonafide. I have been pushed to the
wall and I have no option but to fight. However, yours is a reputed firm having
extraordinary business and image. If some junior level employee has erred and put your
firm in the present predicament, it is for you to act with a wiser counsel and try to remedy
the situation. I am not suggesting what you ought to do and what you ought not to do.
You have number of options including taking up reopening of the case or using your good
office for arriving at an amicable settlement acceptable to all parties. May be as on date
there is no legal binding on you to explore these options. However, if in your own interest
you resort to amicable resolution of the problem, you may be saved from future trouble.
11) I would like to add here that once I initiate action against you, it would be irreversible.
Once the government authorities in India and UAE are ceased of the matter, my locus
will be weak. If these authorities find that your irregularities are not worth pardoned, then
41
I would hardly be in a position to assist you or to restore the loss to your prestige and
reputation which may be created during the course of these actions.
12) Therefore in your own interest you must act quickly. I am ready to co-operate with you
and I am also open for negotiations. I shall provide every documentary evidence and
assist you in every possible way. What is expected of you is positive gesture to come a
step forward and initiate a _____ to fix up the problem. You are free to contact me on the
abovementioned address / phone number / email address. You may even get in touch with
my Indian solicitor whose particulars are as follows:-
Mr. Sanjeev G.Punalekar,
Advocate, High Court,
315, Birya House,
265, Perin Nariman Street,
Bazar Gate, Fort,
42
If you do not reply back within 7 days making a concrete offer for resolving the issue, I
shall proceed further without any notice and responsibility as to costs and consequences shall be
fully yours.
DAYAL H. MANSUKHANI
NoticeE
To,
From,
Dar AL- Adalah
Dayal H Mansukhani
Advocates& legal Consultants
Flat No.19, Malkani Mahal
Al Maktoum Road,
261, Dr. Annie Besant Road
Al Qaz Bldg, 4th floor, Flat # 402
Worli,
Mumbai- 400 030.
P.O.Box 15878,Dubai -UAE.
Sirs,
Sub: - Notice
I am addressing this communication to you by way of notice regarding legal proceeding

to be taken against your firm and its local partners on account of serious loss and injury
caused to me by Mr. K.K.Sarachandra Bose -a lawyer from your firm.
At the outset I enclose herewith copies of the following papers for your perusal:1) A notice issued by me to Mr. K. K. Sarachandra Bose
2) A reply received from Mr. K.K. Sarachandra Bose
I repeat and reiterate what has been stated in my notice. I wish to state that Mr. Bose is
a lawyer and the final responsibility of his actions is that of your firm and its local
partners. If I finally win the damage suit against your firm it will bring disrepute to
your firm and its local partners.
So far I was dealing with Mr. Bose who has made various wrong promises and
misrepresentations to me. However the fact remains that the fees were received by Mr.
Bose on behalf of your law firm and Mr. Bose is responsible to me in his capacity as a
part of your law firm.
If I file a complaint for cancelling the license to practice, it will affect your law firm and
will not affect Mr. Bose. He joined your firm after leaving his earlier firm. In fact, he
43
sued his previous firm for damages. Now if your firm is in difficulty, he may leave your
firm and join elsewhere. Hence it is necessary for you to investigate and find out the
truth before it is too late.
If you take timely steps, the damage can be minimized if not avoided. However if you do
not take prompt steps, the available remedy will be lost. In that case any chances of
remedial measures or any compromise will also be lost. Hence it is my sincere request to
you that instead of taking the word of Mr. Bose as truth, you ought to call for the entire
e-mail correspondence exchanged between me and Mr. Bose and carefully go through
the same.
The documents speak for themselves. Mr. Bose has been making a number of claims
which include a statement that his refusal to hand over documents to me was based
upon the decision of senior attorneys from your firm. Thus for his own incorrect and
wrong and probably ill motivated decisions he is placing the blame on you and is
bringing disrepute to you.
I was in Dubai for 25 years. I enjoyed the life over there. I owe a lot to UAE. That is
why the whole approach of Mr. Bose hurts me. I am finding it difficult to digest a
situation where innocent local partners of your firm are exposed to losses due to actions
of Mr. Bose. I have already suffered when I trusted him. Your local partners have
placed much more trust in Mr. Bose; naturally the losses that you would suffer are
bound to be very high.
I am confident that if Mr. Bose had previously placed the truth before you the matter
would have been solved long back. He has either suppressed the truth or distorted the
fact that is why he seems to be defiant while replying to my notice as he is sure that you
may not act on my complaint.
I am a businessman and not a lawyer. Hence there might have been language defects in
my previous communications. However this would not change the substances of my
complaint. If some of the sentimental outbursts are ignored, the correspondence would
clearly show that:1) I was in constant touch with Mr. Bose. However instead of giving specific reply, he
was always giving me evasive answers.
2) I provided him with all documents. He also knew that any extra documents required
by him would be readily available on website.
3) There was no problem about prompt payments made to him.
4) I always dealt with him and never disturbed the local partners.
5) Mr. Bose did not inform the facts to me in time. He was negligent and insensitive for
the reasons best known to him.
6) As a client, I could have taken steps to protect my interest by coming over to Dubai.
I was in Australia during 2002 to 2006 and I had specifically asked Mr. Bose to
advise me whenever my presence was required. Way back in July 03, I wrote to him.
As Mr. Bose was hesitant to file criminal complaint against the accountant
appointed by the court, I expressed my willingness to complete the job myself.
44
However Mr. Bose discouraged me stating that there was a threat of arrest. This was
a lie. As an appeal was filed on my behalf against an adverse order, there was no
question of inclusion of my name on the websites of police authorities showing the
names of persons against whom there were pending arrest warrants. You may
yourself verify this factual position so that it will be known to you that Mr. Bose was
intentionally misguiding me.
7) When Mr. Bose misled me, discouraged me from coming to UAE, committed a
breach of trust, colluded with my opponent and finally destroyed all my legal cases,
he was all along keeping you in the dark.
Sir, millions of ex-patriates are working in UAE. They have faith in the legal system of
UAE. This faith will be shattered if this episode is known to people. This will tarnish the
image of the whole country and will bring disrepute to the whole system. In that case
your law firm will have to face action in the hands of the authorities of UAE as well.
Please note that I shall not leave the matter till it reaches a logical conclusion.
When I was trying to convince Mr. Bose that a case should be filed against the
Accountant, he demanded on-account/advance of Dirhams 50,000/-. I pointed out that I
am ready to pay the same and would in fact pay more than 1,00,000/- in due course, he
simply stopped responding to my pleas to file the case.
You may appreciate that this particular litigation was the outcome of a larger crime.
This matter is related to a big fraud that took place in Standard Chartered Bank in
Dubai involving million of Dirhams and ruining thousands of lives of innocent
businessmen in Dubai. I am attaching herewith a copy of the notice send by me to
Standard Chartered bank which is self explanatory. It will make my resolve clear to
you. I am very much determined to pursue the matter up to the highest possible Forums
including not only the courts and ministries in the UAE but also the International
Forums such UN Committee on Torture. If the things are stretched to such an extent,
there would be much larger damage which will be irreparable.
I am sure that senior partners of your firm will not allow the above eventualities and act
with quickness and alert.
I reiterate the demands that were made by me in the notice addressed to Mr. Bose. In
addition I call upon you to inform me the specific names and addresses of the local
lawyers who appeared on your behalf in my legal cases. Should a need arise for me to
initiate prosecution I shall implead every concerned party so that only those who are
guilty are punished. I look forward to your specific reply within 7 days from the date of
receipt of this notice failing which action envisaged in my previous notice shall be
initiated without any further intimation. These actions will be without prejudice to my
rights to claim exemplary damages from your firm and from individual local lawyers
and your partners. Your reply by e-mail/ fax is solicited.
45
Yours faithfully,
Dayal H. Mansukhani
Date:
Fri, 14 Jul 2006 13:07:32 +0530

"KK SARACHANDRA BOSE" <boselaw@gmail.com>
From:
To:
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mansukhani48@yahoo.com
Subject:
CC:
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Re: Notice: LAST & FINAL REPLY FROM KK BOSE.

boselaw@hotmail.com
July 14, 2006
(By email: mansukhani48@yahoo.com),

Dear Mr. Dayal Mansukhani,
Reference is made to your notice dated 10 July 2006 sent to me via email. First of
all, I deny your entire allegations as all the allegations are totally baseless, criminal
and blackmailing in nature. All the allegations, except that of migrating to
Australia, were all raised by you and answered by me several times earlier and I
have all the proof with me.
In respect to migrating to Australia, let me tell you that I am a patriot, I am the son
of a Patriotic father and in my whole family, there is no history of migrating to any
country as we are always proud of our Mother India. Among visiting over 20
countries like the USA, Canada, United Kingdom, Finland, Switzerland, Japan,
Hong Kong, Holland, Singapore etc., either for representing my international
clients or for site seeing, I have once visited Australia also. So please mind your
thoughts.
Your rude and blackmailing mentality is known to me, not only to me, but several
other individuals and several lawyers in Dubai with whom you dealt with earlier. I
am contacting and collecting proof from all the lawyers and all the lawyers told me
that you have a habit of blaming the lawyers in order to avoid paying them their
legitimate fees.
46
In respect to your Indian bounced cheques, all the cheques were time barred for
both criminal and civil actions as told to me by the Indian lawyer. The Indian
lawyer was initially hesitant to issue notice as all the cheques were not worth the
papers as were time barred. But you insisted us to send notice so that you had some
NGO friends in Mumbai and they will help you in recovering your funds. Anyhow,
later when you visited the Indian lawyer and established direct contact with her by
telling me that she is from your community and speaks your language and you felt
more comfortable to deal with her, I left the matter to both of you and then I never
pursued the matter with her. All these are well evidenced in our earlier
communications.
When I left Galadari due to partnership disputes and joined Dar Al-Adalah as a
partner, you hesitated to withdraw your cases from the office of Galadari saying
that Galadaris are well known and reputed and since I could not practice in the
court, you decided to continue all your cases with Galadari. Thereafter when you
doubted that Galadari was not paying any
-2attention to your cases and your cases were being mishandled by them, you wrote
several letters to Galadari blaming them, fought with them and then you withdrew
the cases from them and came to me almost in a helpless situation and requested
me to accept your cases saying that you had absolute faith in me and that you were
leaving for Australia etc. I have the entire proof for all that are stated above.
When you got a criminal lab report on the Standard Chartered Bank cheques
against you and the Dubai Courts upto the Supreme Court convicted you for
forgery of the cheques, which case was fought by your previous lawyers and not by
us, and only after you lost the case at all the stages you approached me to see if we
could reopen the criminal case, I was the one who took you to a private forensic
lab in Dubai and got the report made and pursued to reopen the criminal case.
When you failed again, you alleged the Dubai Government and the UAE
Government and put their names on the internet and then you approached the
Ombudsman in London and filed complaint against the SCB and others etc. How
can you now blame me for negligence?. Is it that since you failed against the SCB,
Raj Bernard and the Government of Dubai, you are turning against us ?. Is it for
money ?. Do you spend your whole life in blackmailing others ?.
In respect to Besco/Raj Bernard cases, it was they who filed case against you at
Dubai court and that case was handled by your previous lawyers and not by us.
47
You withdrew the said case from the previous lawyers and gave to us for the
reasons best known to you, and I advised you to file counter case and that was how
you filed the counter case against Besco/Raj Bernard. But the counter case had a
direct bearing on the main case filed by them and the SCB cheques as well. And
that was why you lost the case and not because of our negligence.
I have never solicited clients and cases in my total practice duration of 29 years in
Dubai. I did not solicit your cases as ill-stated by you; on the contrary you
approached me on the strength of my reputation and high standing in the society.
Lawyers may win or lose a case. A client has every right to go against the lawyer if
he finds that the lawyer has committed professional negligence. I am one among
the category of such lawyers who will fight injustice and you have very clearly
seen it.
-3In respect to your several other cases that we won in the court, when the matter
came to the execution stage and the judgment debtor was compelled to pay the
amount, you or your wife with your power of attorney used to interfere in all such
cases, blame us saying that we delayed the case, and then got settled directly with
the parties with the specific intention to avoid lawyers fees and then we had to
struggle to recover our fees. You have demonstrated such cheap behaviors in
almost all your cases.
In respect to your Bahrain case, which you have not mentioned in your mail, when
the case took time due to appeals filed by the opposite parties both in the main suit
as well as in the execution suit, you raised the same allegations against me and my
Bahrain associate lawyers stating that we are supporting the opposite parties. When
we won the case at the final stage and executed the judgment (over AED
400,000/-), you reached settlement with the opposite parties and ordered us to
agree to it in order to avoid paying our agreed fees. You even wrote to the Bahrain
lawyer stating that you paid me the lawyers fee whereas what you paid was the
court fee which was paid to the court. All these facts are well evidenced in your
own letters.
When you left for Australia, you had given authorization to my office to inform
your father-in-law Mr. Mohan in Dubai about the progress in all your cases and we
were doing so in all the cases. You had given power of attorney to your wife also
and she was also involving in the cases. Your father in law and your wife came
several times to our office and collected photocopies numbering hundreds of pages,
48
over four times, of all your files, and when my secretarial staff got disturbed by
your repeated trouble causing, they might have told you to go to court and get all
the copies.
Anyhow, now you can take all the copies from the court file as and when you
desire. Moreover, any paper or document lying in our file does not matter, but what
matters is the documents submitted in the court file and you better have them
properly.
Your cases were never mishandled. All the documents were submitted to the expert
and to the court on time. My attention was always given to all the cases handled by
me, including your cases, and that is how I do my duties. Your cases are no
exception to this my general principle. You are well aware that I have established a
decent practice in Dubai, I am a partner of a highly
-4reputed law firm in Dubai, all my partners are highly qualified lawyers with clean
records and background and they are all competent to represent in the courts and
handling several reputed clients. As you know, I am advising several banks and
corporate bodies including Government of India Concerns and no body other than
you can even for a second think ill about me.
I do not want to go in further detail and spoil your spirit. If you are looking to sue
me for negligence or for anything, first thing you have to do is to copy the entire
court files from Dubai Court and see if any documents were not submitted, any
negligence is made by my partners while representing you in the court etc.
The threats, blackmailing methods etc., by using NGOs, writing letters to the
Government, Ministries etc., as evidenced in your said email will not work with
me. Take it from me that you will not send any more mail to me, nor your advisors
will send, and any mail coming from you or your advisors will go to the junk mail.
Yes, you may prosecute me, file civil, criminal and whatever legally accepted
methods you want to do, I shall properly reply and resist as per the laws and
procedures. But in doing so, you will be doing at your sole risk and responsibility
and I will certainly claim adequate damages from you and counter you in every
action. (This reply is sent not as a duty nor that I am afraid of your threats, but
only as a matter of courtesy so that good sense and reason may prevail in you and
your advisors and you and your family travel on the right path).
49
Mr. Dayal, I have a better suggestion for you, spend your money for some good
charitable causes so that you will clean your heart for the sins you committed on
me and other innocent people.
With Best Regards,
KK Sarachandra Bose
Corporate, Commercial & Contract Lawyer
Dar Al-Adalah
Advocates & Legal Consultants
P.O. Box. 15878, Dubai, UAE
Tel: (00971-4) 3355577/ Fax: 3354000/ Mobile: (00971-50) 6245087
www.daraladalah.com
Notice F
From: dayal
mansukhani
To: boselaw@hotmail.com
Subject: Notice
<mansukhani48@yahoo.com>
Date: Mon, 10 Jul 2006 03:15:41 -0700 (PDT)

DAYAL H. MANSUKHANIFlat No.19, Malkani Mahal, Self-Help CooperativeHousing Society, 261, Dr. Annie Besant Road,
Worli,Mumbai
400
030,
India. (Phone/Fax-0091-2224384011)Date: 10th
July,
2006
To:
Mr.
K.K.Sarachandra
Bose
Dear
Sub.:
Dubai
(U.A.E.)
Sir,
Final
Notice.
I am serving this notice upon you as final notice which shall be

read in continuation with previous notices given to you and
without prejudice to all my rights. Through this notice I call upon
you
as
follows:50
1) You are an Indian citizen who has been in the legal profession
in United Arab Emirates for more than two decades. Since last six
years
you
were
attending
to
various legal cases which are associated with my business
concerns in Dubai. Previously you were a part of another firm viz.
Galadari Associates. When you left the said firm and joined
another firm our legal cases were shifted to your new firm. Thus
the
primary
responsibility to look after our cases was personally yours and we
were basically dealing with you. We always trusted you and cooperated with you.
2) As I hail from India and as I have certain difficulty in written
Arabic, I had to seek advice in legal matters in view of the fact
that legal proceedings in UAE are conducted in Arabic. In your
firm, you have a local partner and you also have,necessary
translating facility between Arabic and English. As you hail from
India which facilitated easy communication with you in Hindi, we
had been trusting you and confiding in you from very beginning.
3) As regards fee structure, we have always readily complied with
your requests. Various correspondences and emails exchanged
between us bear testimony to the fact that on our part there was
no lacunae due to which your service to us should have been
affected. Unfortunately, confidence placed by us and the cooperation extended by us were not reciprocated by you. Instead,
you have indulged into various practices which amount to not
only dereliction of duty but also to breach of trust and criminal
negligence.
4) We have realized that you have absolutely no knowledge about
written Arabic and you are fully dependent on paid employees
doing this job for you. Hence you had to engage outside
employees and this must have created serious communication
gaps thereby impairing our legal cases. Therefore while
canvassing our client account you have clearly misrepresented to
us and have given us tall promises which you could not and did
not
keep
up.
5) So long as we were in Dubai till 2002, we were in a position to
keep in touch with you and exercise some check and control in
respect of our cases. However as you know, we left for Australia in
51
the year 2002 and thereafter in the next four years period, we
were busy with our business activities in Australia. During this
period, we had to fully rely upon you with the belief and
confidence that you would take care of our interest. You are aware
of the fact that as per law relating to legal profession and code of
ethics
applicable to lawyers, a lawyer is expected to exercise every due
diligence even in the absence of his client and to ensure that the
litigation does not suffer due to any communication gap. A lawyer
is duty bound to properly represent his client and to see that
every submission and argument is properly tendered and every
correspondence is properly made so as to maximize the chances
of success. When a lawyer confronts any difficulty, he is required
to specifically and clearly advice his client so that the client can
take remedial measures. Secondly, a lawyer is expected to carry
out every lawful instruction from the client honestly and truthfully.
A lawyer is required to act with ordinary diligence and it is
expected of him that he must take timely decision with
regard to various matters by making optimum use of his own
conscience and judgement. A lawyer is also duty bound that he
should
not
defy
the
clients
instructions particularly when such instructions are of material
relevance
to
the
evidence
in
led
any
case.
6) Whenever you sent us any e-mail, we replied the same by
return e-mail. However, you kept us in dark. Even in instances
where there were adverse developments, you failed to inform us
on the same day. Only when we contacted you, we were given
intimation
about
the
happening.
7) Unfortunately, in the litigation relating to Mr. Raj Bernard and of
his firm Besco, we find that the litigation was completely mishandled by you. You had acted in a reckless and careless manner
and have failed and neglected to protect my interest. A favorable
judgement obtained by me was reversed at my back and by
taking advantage of various deficiencies at the appellate stage
proceedings which occurred only and only because of your
criminal negligence and probably your collusion with the opposite
party.
8) Mr. Raj owed huge dues to me. Financial irregularities were
committed by him and in fact when litigation was going on in my
52
presence, Mr. Raj was evading the same and he did not even
participate in the proceedings. The court at Dubai however, went
on giving opportunities to him for a long period of 3 years.
However, while deciding the litigation in my absence, the matters
were extraordinarily expedited which was not even opposed by
you.
9) You were also aware that this legal case had a background
history connected with the episode of Standard Chartered Bank
and final outcome of this case was closely linked to every step to
be taken by you with regard to my dispute with Standard
Chartered Bank. Therefore when a favorable judgement was
received by me against Mr. Raj, I was very happy that I would be
in a position to take up pending issues against Standard
Chartered Bank. However my hopes were shattered. In my
absence when Mr. Raj sought to reopen the case, you did not
even resist the same properly. Subsequent case filed against me
by Mr. Raj succeeded and decree was awarded against me.
10) When Mr. Raj attempted to reopen the previous case, the
same should have been forcefully opposed. In this connection you
may know that I had made available to you every evidence with
particular reference to the episode relating to Standard Chartered
Bank. I had properly kept all my accounts and chronology of all
events were available with you personally. It was only a matter of
properly
explaining
the
true
facts
to
the
court of law. I had also entrusted complete and full authority in
you and empowered you to represent myself any all these
litigations so that my presence would not be required. I had
furnished to you the fact of all cheques, correspondences,
auditors report, previous complaints, correspondences with
Standard Chartered Bank and supplied you with detailed notes
made
by
me
in
the
matter.
11) On my personal website all documentary evidence was
displayed and you were personally aware of the same. You could
have referred to any evidence any time, if at all at any particular
point of time you found any difficulty. Secondly, I had been
communicating with you over email and it was not difficult for you
to get in touch with me over email or on phone.
12) Last but not the least, our contract was very much clear
wherein you were assured a very good return for your work and
53
this incentive per se was sufficient for you to independently

conduct the matter in an effective way. Any single payment of
your charges in the past was not delayed by me. In addition, fee
structure was incentive based so far as you were entitled to share
of recovery from out of the decree to be obtained. In this
background, it was not unusual for me to expect that you would
fight out litigation vehemently and forcefully by representing my
interest properly. Unfortunately, you did not do so. The case was
successfully reopened by Mr. Raj. The matter did not stop here.
Mr. Raj succeeded in quashing the decree within a short period. In
addition a decree was awarded against me. This was shocking.
The
whole
episode looked like a stage managed drama. For any person with
ordinary wisdom it is very difficult to find out as to how reopening
of judicial decision was done with such quickness when decision
was made in the first place after a very long indulgence given to
Mr.
Raj.
13) I was in Australia and due to my business problems I was
unable to return to Dubai. Taking advantage of this position,
various adverse rulings were obtained against me. On my part I
expressed myself and spoke out my mind very clearly. With
particular reference to the auditors report about various
transactions, you may recall that I had time and again reiterated
the vital importance of documentary evidence. It was necessary
for you to rely upon such substantial issues such as auditors
report and ensure that attention is attracted only to genuine
issues of substance. You should have ensured that Mr. Raj did not
succeed in misleading the court only on technical grounds. I had
past business relation with Mr. Raj and the entire gamut of
transactions was routed through bank accounts. Every transaction
was reflected in bank account and there was hardly any scope for
oral submissions. It is a cardinal principle of law that
written word has more weight than a word of mouth. The
documents speak for themselves. When I was absent on the
scene
and
when there
was
already
a
ruling
from
the court of law in my favour, it was your duty to stress the
documentary part of evidence properly. This consisted of two
parts.
Firstly,
you
should
have
properly invited courts attention to the documents on record.
54
Secondly, if there was need to bring fresh documents on record,

you
should
have
obtained
leave
of
the
court
for
the
same.
14) The criminal negligence on your part assumes importance on
account of your omission to take proper benefit of the courts
directives of appointing accountant to submit report. When the
court appoints its agency/ officer for the purpose of fact finding,
both the sides get an equal opportunity to bring proper
documents before the court. It was your duty to submit every
piece
of
paper
to
the
accountant
and
thereafter see to it that every vital piece of paper is duly
incorporated in the financial report submitted by the auditor to
the court. Even though I am a layman, I am aware of the practices
in the court and about principles of natural justice whereby
documents
and written submissions made by one party are invariably made
available to the opposite party. The submission of accountants
report is not one days job. It is a long drawn process wherein
both the parties are given due opportunity to examine each
others documents and arguments and to make further arguments,
rejoinder and supplementary submissions. Therefore you ought to
have
properly
checked
that
every document from our side is taken on record. Simultaneously
you should have also thoroughly checked the documents
tendered by Mr. Raj to ensured that any concocted or manipulated
documents are not allowed to be taken on record.
15) With regard to documentary evidence, we had an upper hand
and there was every likelihood that the opposite side would try to
mislead the court by submitting either concocted documents or
by tendering incorrect interpretation of evidence. You should have
been extremely alert and vigilant on this front. However, you have
adopted a very casual and non-serious attitude. While the
opposite side and its lawyers were fighting litigation with
vehemence and vigor and were not leaving any stone unturned to
get
better judgement, you have adopted an attitude of complacence.
In fact I clearly apprehend that this not an attitude of
complacence but an attitude of complicity. You did not defend our
interest at all. You failed to point out the lacunae of the opposite
55
side, documentary evidence as well as interpretation of such

evidence.
16) It is also extremely doubtful whether you really submitted
documentary evidence that I had furnished to you. Throughout
this period you did not even try seriously to involve me in any of
the processes. If at all there were any genuine difficulties, you
should have got in touch with me. The damages caused to me
were known to me only later. When the court pronounced its
judgement
you
ought
to
have
raised
certain
basic
issues in relation to the accountants report. You failed on this
front as well. When I took up the issues with you, you tried to
defend yourself by stating that you had recorded your objections
verbally. As a lawyer, you are well aware of the fact that in any
court proceedings there is always a scope to submit written
arguments. Secondly, while on the date of pronouncement of
judgement, the heat and anxiety in the court may create
difficulties in properly recording the oral argument we fail to
understand as to why your written arguments were not submitted
to
the
accountant.
Secondly,
if
at
all
written arguments were not accepted at the time of pronouncing
judgement and if you really observed various lacunae in the
accountants report, you could have submitted a review
application forthwith through which certain written arguments
could
have
been
brought on record. When I was totally disillusioned about the role
played by the accountant, I insisted that there is something fishy
about the his role and insisted initiation of proceedings against
the accountant. You did not take any steps. I made it
clear to you that we need to take further steps to repudiate the
report of the accountant and to bring out its non-acceptability as
evidence before the court of law. When the report very much
adversely affected us, there was no option but to challenge the
same and to demand action against the accountants if there were
any malafides. However for the reasons best known to you, you
chose to defend the accountants. It is still not clear to me as to
how you chose to defend the accountants when the
accountants report was the basis of our setback in the legal
case. Unless and until we legitimately reverse this report, it was
not possible for us to reverse the verdict to the court of law.
56
Repudiating the report required that the deficiency in the report

should be first highlighted so that fresh evidence and fresh
interpretations would be brought on record. Unfortunately, you
adopted a very dogmatic and negative approach towards my
suggestion. As I was your client, you were duty bound to properly
consider my suggestion and instructions. If you differed with my
suggestions,
you
ought
to
have
explained the same in writing and given me an option to engage
another lawyer. Instead you adopted various techniques to evade
action
against
the
accountants.
This was unbecoming of a lawyer. Already we were in Australia
and we had our own business difficulties due to which time at our
disposal
was
too
short.
We
were
struggling to consolidate our various matters. In this situation,
when time was running out, you should have stuck to your
professional locus and facilitated prompt and quick action in our
litigation / dispute.
17) The accountants report had many irregularities. The letter
from Besco on record acknowledged the receipts of
payments. Bank statements were also on record. It was an
admitted position that in Criminal Proceedings initiated by me, Raj
had accepted the debt and has in fact sought lenience by offering
to make payment over a period of time. He had never claimed
that any amounts are owed by me. If these facts were properly
explained to the accountant, there was no question of accountant
giving any erroneous report. Even in the likely event of any
intentional lapses on the part of the accountant, your timely and
vigilant action would have created apprehensions for the
Accountant.
18) You had not handled the matter with due diligence. Instead
you went on tossing back our queries and when we demanded
papers
and
proceedings
from
you,
you
did
not even make the same available. As per laws applicable to
lawyers, a lawyer is required to return all proofs and papers to his
clients so that the client can seek relief from alternate sources. If
a lawyer does not implement or execute his clients instructions
and at the same time holds up papers with him, thereby making it
impossible for the client to go to another lawyer as well, it is an
offence
punishable
57
under law. Throughout this period, your intentions were to stop

legal remedies against Mr. Raj on some or the other pretext. Even
till recently, when we requested you to make available to us soft
copies of the various documents that are available in your
computer, you declined our request without satisfactory
explanation.
It
is
an
admitted
position
that you are not having any Arabic knowledge and you are relying
on the papers translated from Arabic to English. Therefore in an
era of technology, it is ridiculous that you claim non-availability of
soft copies of the papers. Since you were actively involved
in getting papers translated from Arabic to English and from
English to Arabic, it would have been readily possible for you to
forward soft copies of papers to us. If all soft copies were not
available at least all available soft copies should have been given
to
us
with list of those specific papers where soft copies are not
available. Even in such cases, hard copies should have been
provided to us. You did not provide us with any copies. Instead
you went on giving evasive replies and at one point of time you
stated
that
we
should obtain the papers from the court of law.
19) During these communications, when you informed us orally
that hard copies in Arabic could be collected, we clarified to you
that as you had got these papers translated into English, the soft
copies could be forwarded to us so that we can properly study the
matter and give instructions to the counsel conducting the matter
in Australia. We pointed out that you must be having soft copies
in your computer. However, you still did not provide us with the
soft copies. This non-cooperative attitude on your part has
convinced us that the judgement obtained at our back against our
interest was obtained by collusion and conspiracy between you
and Mr. Raj. Therefore, we have decided to initiate stringent legal
action
against
you.
20) We are envisaging filing of criminal proceedings against you
before the Indian courts. As you have said in India, you are aware
of Indian Penal Code which entitles an Indian citizen to initiate
criminal proceedings in India whenever offence under IPC is
committed on foreign soil against Indian citizen. You may check
up this position and be rest assured that we shall prosecute you in
58
India and bring you to books. Secondly, though you have obtained
law degree from India, you had been a Non-Resident Indian (NRI)
and have been abroad for last more than two decades. Naturally,
you are not entitled to protection applicable to Indian lawyers
under the rules of Bar Council of India under which a lawyer
cannot be prosecuted unless and until a complaint is made
against him to the Bar Council of India in so far as matters
involving his professional misconduct are concerned. In your case,
since you are a NRI and you not member of the Bar Council of
India, it shall be admitted that a criminal complaint to be filed by
us
against you before the Indian court is complaint arising out of
your private conduct abroad and the same would not entitle you
for the protection available to the practicing lawyers in India. In
other words, we are legally entitled to prosecute you in India and
seek your extradition in India by cancellation of your passport. We
are aware of the fact that you are trying to migrate to Australia
and your family members are also in Australia. We shall take
steps to inform your conduct to the Criminal courts in India and to
get appropriate summons/ warrants issued against you. We shall
inform
these
facts to every authority in U.A.E and Australia. You are aware that
grave injustice has been committed against us. As a lawyer, you
ought to have co-operated with us in properly fighting out the
matter. Even today it is not late. If you chose to submit all
available hard copies and soft copies of the said documents to us
honestly, in both English and Arabic language, and you cooperate with us in the case, we may consider lenient view of the
matter. However, we need concrete co-operation and support. A
hollow lip service would not deter us from taking action against
you. Please rest assured that we shall leave no stone unturned
against
those
persons
who
have
harmed
our
interest.
21) You had yourself initiated damage case against Galadari
Associates. You are aware of the provisions of law relating to
damage claim. In our case, we have concrete evidences to prove
damage caused to us. You are free to make your independent
assessment and take a call whether you would like the issues to
be
settled
amicably.
59
22) In addition to the above referred negligence, you also

involved in criminal negligence with regard to various cheques
that
were
payable
to
us
in
India.
In
this connection, we are holding emails exchanged between us,
you and your Indian associate lawyer about dishonor of various
cheques
drawn
on
banks
in
India.
The stand taken by your associate lawyer in India and the stand
taken by you are contradictory to each other. While your Indian
associate
is
taking
the
stand
that only photocopies of cheques were sent to you, you maintain
that original cheques were forwarded by you. In this process we
are
deprived
of
original
cheques.
This matter would be viewed seriously by law enforcing
authorities in India. You are aware that in recent past the laws on
financial offence have become more and more rigorous and in a
number of cases, the accused persons were declared proclaimed
offenders and their properties were attached when they failed to
submit themselves before the jurisdiction of Indian criminal
courts.
With
regard
to
the
failure
of
you
and
your associate lawyer to return the original cheques, emails
exchanged would speak for itself and would be sufficient to
establish the court that there is definitely a preplan to cheat us
and at the same time deprive us of our legal remedies.
23) If you do not take a positive stand of reconciling the issues,
we shall also have to alert the Indian community in U.A.E. so that
they
are
not
cheated
in
similar
fashion.
24) We suspect foul play and also apprehend that you have
played at the hands of certain third party elements in a process of
abusing law to obtain adverse judgement against us at our back.
Therefore we once again call upon you to supply as follows:a. Hard copies and soft copies of every paper in Arabic and
English
be
provided
to
us.
b. Take inspection of the court records and wherever there are
gaps, please submit us certified copies of those documents which
are not available in (a) above. c. Documents forwarded by you
should include every bit of paper that you supplied to the
ccountants. In other words it would not suffice if you just furnish
accountants report. We would like to go into specific papers that
you provided to the auditors. This alone will show whether you
60
had actually submitted material data or whether your failure to

provide material documents to the accountant was the reason for
our failure of the case. Therefore please ensure that copies of
every
letter
and
document
addressed
by
you
to the accountant is included in the proof to be returned to us. d.
Please offer honest, straightforward and sincere assistance to us
to
resurrect
the
case
and
reverse
the
verdict. e. Please ensure that the original cheques of Standard
Chartered Bank are duly delivered to us. In addition, you are also
required
to
furnish
to
us
all
documents
in English and Arabic (soft copies as well as hard copies of all our
other costs, including costs relating to Standard Chartered Bank).
f. Please return to us the original cheques in respect of the cases
with regard to Indian parties. g. Please forward to us copies of all
papers and proceedings of all other cases handled by you on our
behalf
25) Irreparable damage and harm is already caused to us.
However, we have not lost hope. We still desire to fight out the
case and come out with clean hands. We had association with you
for more than past six years and on our part we tried our best to
make
relationship
work
smoothly.
26) Unfortunately, actions on your part have brought us to the
present position. Still we deem it fit to provide you an opportunity
to take remedial measures. In case you have any suggestions of
your resolving the matter through negotiations with the opposite
party, we are also open to consider such suggestions so long as
the same is made honestly and you genuinely take efforts to
resolve
the
matter
in
the
interest
of
all.
Please note that litigation was resorted to us by only a last
remedy. It is painful for us to address such a communication to
you. However, we are pushed to the wall and we are compelled to
write this since we are kept in total dark and our silence would
completely
ruin us. However, before initiating any prosecution against you,
we thought it fit that in the interest of natural justice we should
afford you an opportunity to resolve the matter in the best
interest of all concerned. Please note that this is our final notice
and
any
further
notice
will
not
be
issued.
27) Also note that apart from initiating criminal prosecution in
61
India, including actions to impound your passport and to attach all

your properties in India, we shall also send intimation to the
Government of UAE as well as various authorities (including
immigration authorities in Australia) about your conduct and
about our envisaged prosecution against you. This would be
without prejudice to our rights to file civil suit against you in the
Indian Court as also in the Courts in U.A.E.
28) We may have to first take up the issues with the authorities in
U.A.E. and thereafter even at the international Human Rights
Bodies. We shall also get assistance of NGOs in India as also the
department of Foreign Affairs of India. We are indebted to UAE for
the prosperity and success given to us. It would be painful for us
to raise any issues at international forums. However, if we are
compelled to do so due to your adamancy it would be an
unfortunate
day
for
us.
29) Please note that time is the essence of this notice. We require
your time bound reply and the same should reach us within 7
days from the date of receipt of this notice by you. If your reply is
negative or no reply reaches us within 7 days, we shall take every
action against you without any further notice to you and the
responsibility as to costs and consequences shall fully be yours.
DAYAL
H.MANSUKHANI
P.S.: For the present I have refrained from sending

this message by fax. However, if you do not respond,
I shall send the same by fax for good orders sake.
Notice G
To,
MR. K.K.SARADCHANDRA BOSE
62
Under the instructions and on behalf of our clients Mr. Dayal Mansukhani, of Mumbai we
have to address you as under:1
That this Notice is been issued to you and your law firm in Dubai for
initiating civil and criminal proceedings against you for deliberately
spoiling the carrier of our client. And committing the following torts,
wrong, offence, breach of trust, misdemeanors.
That when our client was in Australia, you deliberately spoilt his legal
cases. In the case between our clients and Mr. Raj Bernard, as when the
Court had appointed Accountant to go through the accounts and give a
report to the Court so that the Court would come to know about who owes
how much amount to the other party. At that point of time our client had a
decree against opposite party Mr.Raj Bernard. However due to the
erroneous records given by you to the Court appointed Accountant, not
only his decree was reversed but a decree was slapped on him. I went on
asking particulars from Mr.Bose to know as to what records he had given
to the Court appointed Accountant. However, he did not respond. This is
because he probably knew that once he provides me all the papers, I would
surely know that because of his concealment of documents from the Court
I lost the case. Hence he has deliberately not responded to me.
The misconduct of Mr.Bose does not stop merely at spoiling my legal cases but he also
discouraged me deliberately from entering into Dubai. He sent me a message falsely claiming
that a warrant has been issued against me in Dubai. This message was sent to create a fear in my
mind that I will be arrested if I came over to Dubai. However in reality, he was trying to keep me
away so that he could spoil my legal cases without giving opportunity to me to protect my
interest. A copy of the message sent by him to me is attached herewith.
OFFENCES / CRIME OF MR.BOSE
63
He sent me false message to create fear that I will be arrested. His intention was that I would
not come to Dubai and I would not know about his conspiracy.
Mr. Bose deliberately misled the Court appointed Accountant and he did not properly submit the
documents to him thereby resulting in adverse report by the Accountant to the Court.
MY PROPOSED ACTION
Once I establish the above two propositions, I will be in a position to obtain orders from
Criminal Court in Mumbai to register criminal complaint against Mr.Bose and to seek personal
attendance of Mr.Bose before the Court. However by filing this complaint I need the following
documents:-
i)
Documentary proof that no warrant was issued against me.
ii)
Documentary proof that Mr.Bose indeed did not submit the required documents to the
Court appointed Accountant in Dubai.
iii)
As regards (i) above, it may be noted that Dubai Police have their own website on
which names of persons against whom warrants are pending are displayed. Therefore
it is necessary for me to first obtain certificate from Dubai Police which shows that
during the relevant period when I received email from Mr.Bose, my name was not
appearing on their website and that the communication from Mr.Bose was a false
communication.
iv)
Secondly, I need the letters addressed by Mr.Bose to the Accountant enclosing various
documents in support of my case. These communications may be either in the form of
applications/ affidavits or in the form of even forwarding letters. This can be obtained
by conducting a search of the Court records and by taking certified copies. I enclose
herewith the soft copies of communications sent by me to Mr.Bose as well as the law
firm. From the same, nature of papers that I have handed over to Mr.Bose will be
clear. I am also enclosing soft copy of email sent by me to Standard Chartered Bank
(SCB) which will reveal that the deal between me and Mr.Raj Bernard extended to
the transactions that took place with SCB. If papers submitted by Mr.Bose to the
64
Court -appointed Accountant did not cover these transactions, then I would be in a
position to show to the Criminal Court in India that Mr.Bose deliberately suppressed
vital data from the Court appointed Accountant. It may be observed from the notice
sent by me that Mr.Bose was also appearing for me in various criminal cases filed
against Mr.Raj Bernard and in these criminal cases, Mr.Raj Bernard had clearly
admitted his liability and had sought for only more time and also pleaded that these
cases should be tried in a civil court. Mr.Raj Bernard never disputed his liability and
infact admitted his liability. This is a matter of record before those respective courts.
It is necessary to inspect the Court records to see whether Mr.Bose submitted the
papers and proceedings of those Courts to the Court appointed Accountant. In other
words, Mr.Bose was required to give entire picture to the Accountant appointed by
the Court in Dubai covering dealings with SCB, papers and proceedings before the
criminal court, statement of account sent by me to Mr.Bose wherein the transactions
with Mr.Raj Bernard were reflected, etc. Therefore someone should conduct proper
search of the records of Dubai Court to make an assessment as to what exactly
Mr.Bose submitted to the Court appointed Accountant. Thereafter certified copies of
the relevant application/ forwarding letters should be obtained.
Certified copies of the above documents showing that Mr.Bose actually submitted inadequate
date to the Accountant appointed by the Court, coupled with documentary proof from Dubai
police that there was no warrant against me when Mr.Bose threatened me about the warrant
would be a sufficient evidence for me to apply to the Criminal Court in India and obtain orders
against Mr.Bose. I need some competent person who will first obtain a certificate from Dubai
Police at a reasonable cost. After reading this communication let such person give me a very
reasonable estimate of his cost for obtaining certificate from Dubai Police. I am ready to pay
25% to 50% of the amount as advance. Once he gets certificate from Dubai Police, both of us
will have mutual confidence. Thereafter I may ask for estimate of cost for obtaining certified
copy of the forwarding letters/ applications with regard to the papers that were produced by
Mr.Bose to the Accountant. Here again I am ready to pay 25% to 50% of the amount of quotation
as advance. Incase any forwarding letter is not available in the court, then I should be advised
about alternate course. For example, if the Accountants report lists out the particulars given to
65
him by Mr.Bose, then the report itself will be a prima facie evidence about what documents
Mr.Bose handed over to the Accountant. In that case, I may be forwarded a copy of the
Accountants report so that the same can be relied upon before the Indian Court.
Last but not the least, as I will be submitting the documents before the Indian Court, I will be
required to submit English translation from the original Arabic version. Therefore apart from
giving me fee quote for about two jobs, I should also be given a reasonable estimate of per page
translation cost. Needless to mention that the translation should be proper and authentic since the
Indian Court will be heavily depending on the same. Please forward me the estimate for the
above alongwith the time frame within which the work can be done. Please note that time is the
essence of the matter. I need certificate from Dubai Police atleast within next 2-3 days.
Thereafter atleast within 3-4 days I should get the remaining requirements establishing what
documents Mr.Bose produced before the Court appointed Accountant.
In addition, one important aspect on which I would be implicating Mr.Bose is the delay factor. It
is my action against him that he deliberately kept me in dark. I suspect that even when he was
aware of adverse report from the Accountant, he deliberately did not inform me in time.
Therefore while conducting the above search, the following should also be verified:-
1) On which date the Accountant submitted the report to the Court ?

2) On which date Mr.Bose became aware of the report ? (For example in the hearing held
immediately after submission of the report). There may be mention about the report and
in such hearing that Mr.Bose or his associate lawyer may be present.
3) Alternatively, acknowledgement of law firm of Mr.Bose may be available in the court
records. I also need investigation into this aspect alongwith documentary proof so that I
can confidently go before the Criminal Court in India with an allegation that time gap
between submission of report to the Dubai Court and reporting of factual finding of the
Auditor to me was so much long that it completely damaged my remedy.
66
Dayal Mansukhani
My lawyer Mr.Bose arranged private auditing report but court did not give him time for more
than 1.4 million case against the wrong case filed. But BESCO did not submit its auditing report
in the lower court. But court gave him 3 years time. And after that the case is dismissed by the
court. But the appeal court has given me the judgment against me and did not give me even one
months time. Why ? Appeal 454/2001.
My lawyers email From: "Bose Bose" <boselaw@hotmail.com 27 Mar 2003

confirmation- The court refused to give us time on the grounds that the case itself has
taken long time. (Dayal comment) Why did Lower Court give him time 3 years
and why did I not get time, for more than one million case? (one month only)
Mr Bose,
fax: 3354000. email add: boselaw@hotmail.com
March 29, 2003.
You gave a suggestion that due to the auditors - wrong report which was one sided we lost
the case and that I will have to pay 1 million, and now there is only one option left to file a
criminal case against him.
And now you are saying that I will not file a criminal case against the auditor, why?
While you said you had given all the documents to the auditor and with these documents he
prepared the auditing report.
I had given you 1998 original audit report, original bank statement and all the cheques photo
copies - that I had issued for Besco. Raj and / or his staff had withdrawn all these funds
periodically which were more than 2 millions. And in the Besco letterhead was stated all the
PDCs details. And you are saying that you had provided all these evidences to the auditor. Even
after this the auditor in his audit report has clearly mentioned that both the parties had no
books of account. Even after we, presenting all our documents and evidences still the audit
report was made in favor of Besco.
You should have then only, immediately filed a criminal case, against auditor. As all my
evidences no one could ever prove wrong or falsely obtained. Still the court also did not give you
time. The case getting this worse, still you did not inform me about my case. I could had the
same time flown from Australia and filed criminal case against the auditor and would also take
time from the court.
Now that you lost the case I still dint worry much but against this wrong case I have to pay
1 million and my coming to Dubai is banned. You know that I cannot come to Dubai, so you are
taking advantage.
67
You got prepared private audit report at my expense, and all the evidences with you, are as good
as Gold, which you might have given to the auditor, that time the auditor might have received
and signed for it on this base you can file a 2 million case against him. And you are saying you
wont file the case. All the documents were with you and you had given it to him, and I cannot
come. You know that only you can file case against him, and still you are saying you wont do.
All my cases are given to you, and for this case also you told me to stop the other lawyer. The
other lawyer has not submitted any useless documents, nor me.
I want all these documents from you: (if you are not filing the case)
1)
2)
3)
4)
5)
Okay if you are not going to file this case then give me in writing with reason why
you would not file this criminal case against the auditor?
All the documents which you had given to the auditor to prepare the report- he
definitely must have given you sign for receiving all these documents from you, I
want this received sign proof,
and all the documents which you had given him to prepare the audit report.
The private audit report which was prepared, that also I want.
And the verbal objection that you had taken which would be in records of the courts
you must be having a copy of it also, if you dont have then please get me one copy
from the court.
Also you had asked time from the court but court gave you reason that the case has
taken time and the audit report is very big - so they dint give you time I want this
proof also.
I will fight the case and challenge, even if I have to go behind bars I will, but I will challenge my
case.
I am giving you in writing all this by email and fax I am expecting your reply if you are not
filing the case hand over all these documents, to my father in law, and if you want you may
even inform Besco Raj and his lawyer that Dayal is coming to file the case to challenge it.
They can put me behind bars.
I want the reply in 48 hours if you are filing the case or not, and if not then kindly give my
father in law all the above mentioned documents(within 7 days)
Thanks
Mansukhani.
Dayal
Dear Mr. Dayal,

The execution and arrest warrant is in the case of Besco-Dayal. In Dayal-Besco
case, even though we got a judgment of Dh.600,000/- in your favour from the
lower court, the judgment is appealed by both Dayal and Besco and is pending
at
the appeal court. Besco has submitted the Expert report and judgment in the
case of Besco-Dayal in Dayal-Besco appeal and requested the court to dismiss
68
the case stating that both are one matter. We are fighting the case in the
appeal court.
Therefore, if you come now, you will be required to pay to Besco the full
amount of execution. My suggestion to you is that, if you can wait until the
appeal case is decided, and if the appeal comes out in your favour, then we
can execute
the judgment against Besco also. You have to take my suggestin positively.
Best Regards,
Bose.
Boselaw
Dear Mr. Bose, 28/3/03

NOTE: Yes, you should have appealed by now, still you are asking me? You should had
done this before itself, you know its a genuine case with all the criminal case and my
heart attacks and my losses that I have suffered 10 million case was given a judgment of
only Dhs 600,000/ you also had advance payment. If you dont appeal then we will lose
this amount also (above - Half a million).
1)
If you appeal why against 10 million only dhs 600,000/?
2)
Against auditor criminal case for our office was not closed cheques & bank
statements were available and audit report submitted.
3)
Challenge the court 4 years time was given to Besco why did they not give us
time for more than one million case?
If you prepare a criminal case on the auditor and the below mentioned - challenge then
ofcourse we will win get back our cases.
( to hide one truth or to prove one truth one has to use thousands of different ways / or
speak lies to do so. ) I had the entire cheques photo copies and bank statements and audit
reports which is supposedly like pure gold pure evidence for the case, I had submitted
them all these evidences LONG before, in 1999 (not fake). NO auditor could give wrong
report, thats why all the previous auditors did not give report in their favour. I have not
even submitted any more other than those previous ones to the court on this ground you
can file a criminal case on the auditor and you have private audit report and the old my
audit report too and bank statement if you file this case then he will not even be able to
appeal for the Dhs 600,000/ - if you dont do this then all the efforts we have put in will
be lost, and may lose that also.
Dear Mr. Bose,
Besco filed against me on 31/1/99 the same time without lawyer I requested the court - I
want judgment. The court same time asked him to submit the audit report. It took 4 years
for Besco to submit its auditors report till then the court had dismissed the case. Their
lawyer re opened the case and submitted a new audit report.
And you took - verbal objection, only. And was the audit report so big that we could not get
time for one month or so when their lawyer could take 4 years to submit the report to the
court, he can get time and why not we Was it a small amount? (more than a million)
Can you give me the case copy of the verbal objection, I am sure you can get a copy from
the court. And if you have taken a verbal objection then you can still, on these grounds challenge this case.
69
Mr. Bose, if someone files a wrong case he will by all means try all the vague ways or
documents to prove the court. My case was genuine I had submitted the audit report and
cheques photocopy and bank statements, which were enough to show the court how much
payment I had given him after dry docks payments. This simple case you could not do.
When I was in Dubai, I did not submit any more documents in the court only these few
documents which I have mentioned above nor did my other lawyer submit any other
documents to the court, you may check the court. On this base you can file a criminal case
on the auditor how has he given this statement to the court, that I have no documents and
no reports, you have private auditing report, too, and bank statement and all the other
originals. You should had at the same time filed a criminal case on the auditor before
the court could give judgment.
What are you talking about I made you agree for free, were you a small child? Didnt you
see it / or study it was a false case filed on me? Why did I give you this case, because all
the other cases of mine were with you? Other lawyer was charging me dhs 5,000/ - only.
You check in your records I have paid more than dhs 300,000/ - above dhs 200,000/ for
the court fees and balance your advance fees. Because this case was for free you lost this
winning case of mine?
Still if you believe you are a clever or better lawyer - than others, still you can file a
criminal case and take this case back to the lower court. If you do not do this and / or dont
take steps then you will lose all the cases, this is my word.
His lawyer is so clever that he will appeal for the other case which is in my favour and
get the dhs 600,000/- also in their favour. Then you will know how much you lost, your
reputation and fees
CBI what was the lower court judgment? Means what I lost this case also and the
private audit report also what are you trying to convey does it mean that I have lost this
case also? Was it dismissed?
Auditor had given report in our favour in the court will it be of any help to us or not, for
SCB? Please - Let me know.
Thanks
Regards
Dayal Mansukhani.
70
From: "Bose Bose" <boselaw@hotmail.com>

To: poojamans@hotmail.com
CC: boselaw@hotmail.com
Subject: RE:YOUR CASES IN DUBAI
Date: Fri, 10 Mar 2006 20:58:38 +0000
Dear Mr. Dayal,
Attached please find the details of the hearing dates of your cases as
required by you. You may note that since all the dates are in Arabic, I needed
the help of the Arab lawyer to take all the files and get the dates and hence
the delay.
In respect to SCB original cheques, we have filed application to the court to
bring the file from the archives and get us the original cheques and till date
the file has not come to the judge. We are following the matter and gat back
to you in due course.
For releasing all the files to you, I had discussed with Mr. Abdulla Muzaina
who is our managing attorney and he said as per the law we cannot release
the files of the clients, but you can get copy of all your files from the court,
which is more authentic for you as you can verify all the submissions made
by us in the court, and hence I suggest that you obtain the attested copies
of all the documents from the court. Since your wife has a power of attorney,
she can get it from the court directly or through a lawyer. If you want us to
get you the copies, you will have to pay for the expenses at the court as well
as for the time spent by our staff. For your information, we do not
maintain copy in the computer of all the submissions that we made to the
court as we are retaining hard copies and hence we do not require to keep
soft copies.
In respect to your Bombay cases, I had handed over all the original
cheques to the Bombay lawyer and she served notice to all the parties.
She had at that time informed me that all the cases were time barred as per
the laws applicable in India. Later, you had yourself met the lawyer and
started dealing directly with her telling me that you felt dealing with her
directly as she speaks your language and hence I stopped communicating
with her.
In case you need my personal assistance whereever I can be of help, please
do not hesitate to email me.
With Best Regards & Best Wishes,
KK Sarachandra Bose.
71
Boselaw
Dear Mr. Dayal,

I have seen your fax message as well as this mail. To file a
criminal case against the auditor is not a joke. You need
sufficient proof and it is time consuming as well. More over, if
you want me to file the case, I will charge a fee not less than
Dh.50,000/- and there is no guarantee that you will win the case.
What I told you is my opinion. I told you that I will not file
criminal
case against the expert for two reasons: (i) you blame me when you lost the
Besco Vs. Dayal, which in fact was not my case, in the sense, not filed by me.
To
April
5, 2003.
Mr. K. K. Sarachandra Bose.
Dar Al Adalah
Dubai UAE.
Tele no. 3340303 mobile 6245087 fax: 3354000.
Email Add: boselaw@hotmail.com
I am declaring I shall pay you dhs 100,000/ - if you win the

case according to the below statement.
Dear Mr. Bose,
I had given you all my cases about 8 -10, of which I have paid you fees 2.5% balance when
you win you will take from me 7.5% or else your efforts go waste. Even your company who is
putting all the efforts and time will not earn anything if you lose the case. Any criminal case if
someone files against me or you file against them then you we charge your fee only dhs 3,000/
and if any case goes on for more than 3 years then you will charge more dhs 3,000/. And any
damaging or sue I shall pay you 25 %. This is your agreement. Now I am giving you in writing
through email and fax.
You are demanding me against dhs 3000/ - dhs 50,000/ to file a criminal case I shall pay you
dhs 100,000/, this dhs 100,000/ is only for this criminal case if you win this case then you will
win all the cases against Besco and you will earn more 2- 3 lakhs added to all this you and your
company will earn so much reputation. And you will be able to sue on SCB easily. I am replying
your email and faxing too.
I am declaring again I shall pay you dhs 100,000/ against your demand of dhs 50,000/, if you file
a criminal case against the auditor for dhs 2 million. By doing this the auditor will help us to
72
win the case and even reopen this case. You can then negotiate with the auditor that if I lose
he will pay the 2 million or if we win then he will be free from this case which is filed on him.
Even the SCB case will turn in our favor. Either the auditor will pay the 2 millions or will help to
re open this case. If it will be my loss means it is your loss and my benefit will mean the same.
If you lose this case you will still get the fees according to your agreement i.e. dhs 3,000/. Why
cant you take a chance? Why cant we file this case?
If you do not agree then I have as on 29th mar 2003 demanded some documents, you please
arrange these documents and send me or handover to my father in law, I shall file the
criminal case or give it to some other lawyer to do so or I will come there.
Thanks Regards
Dayal Mansukhani.
++61755275640 /
61415942650.
er 28th July 2003, if you have then kindly forward me again.
All below mentioend cases please send me detail andjudgment, in english and arabic - you must have
got them translated in english for your reference. Either fax me or email me by today.
I had sent you an urgent message yesterday to check my name in

computer - you cannot send em case details and you do not even
have time to gvie me important information - whether my name is
appearing in teh computer or not, this shows that you wish me to
be caught and suffer, when I am calling you being an international
phone you are not attending your client with excuse given that
you dont have time and you are busy.
If I get caught in Dubai then also My Website will be going around throughout the world. I will
definately get all the cases re-opened.
Please reply immediately and also send me the details for all the cases down below:
5
Besco Vs- Dayal 557/1998, 454/2002, 491/2002 opposite party has filed Execution.
1
Dayal Vs- CBI 827/2001, 467/2002, 304/2003 we filed Cassation on 17th June 2003,
waiting for Judgment.
2
Dayal Vs- SCB 658/2001, 9th September 2003 - The case is referred to the
criminal lab to investigate about the 2 cheques.
3
Dayal Vs- Sunder (Silky Star) 1132/2001, 769/2002, 1671/2003, 369/2003, 27th July
2003 to serve to Silky Star. Please note that you will have to arrange a person to serve the
summons to Silky Star. Mr. Mohan informed us that he is unable to go with the court
73
people to show the place. Once Mr. Kamal, Kavithas son in law wnet to the court, but the
work was not done.
4
Dayal Vs- Besco International 183/2000 511/2003527/2003 3rd September 2003 to

serve notice to the 2nd Respondent by Paper Publication.
Kavitha Arjandas Vs- Khaleej Times 157/2000 70/2003 351/2003 16th June
2003 - Filed Cassation waiting for the Judgment.
Dayal -Vs- Prabha Nair 175/2002 Paper Publication done. The matter is
pending with the Court of Execution.
8.
Dayal Mansukhani Vs- SCB (Criminal Case ) 1246/1999

1174/1999, 145/1999 Waiting for the orders from the prosecution.
Thank you,
Yours truly,
From :
To :
Subject :
Date :
Reply
Reply All
Forward
Delete
Dayal Mansukhani

Re: Reminder:
Thu, 10 Apr 2003 06:01:15 +0000
Put in Folder...
Dear Mr. Dayal,

I have seen your mail as well as the fax message on the same subject. I had
answered all your questions in my earlier mail which you replied as well. It
won't add anything to you or to me in repeating the same.
I am not supposed to file a criminal case against the Expert if I think that
the report is biased. I told you that it is my opinion. (Other lawyers differ
74
on this and say that since there is one loan agreement between you and Besco,
i.e., the one signed on 23/06/1996 for Dh.400,000/-,)- if
and there is evidence that you received an amount of Dhs. 1,463,175/- from
Dubai Dry Docks on behalf of Besco, the report of the Expert may stand good
and unquestionable.
The private reports that you prepared does not have legal value as agianst the
court appointed expert's report.
Your statement that I did not inform you about the report submitted by the
expert is not correct. Those days you used to call me from Australia every now
and then, and I told you several times that the expert has submitted his
report against you and you told me to fight against it.
I have no advantage in you statying away, in fact it is very disadvantageous
to me if you are not in Dubai, because as and when I need any clarification, I
have to contact you overseas, or wait for your comments.
For you to come back to Dubai, no body will

stop you provided you remit the amount to
the execution court. And I am sure, this is
not a big deal for you, as you told me
earlier.
To file a criminal case against the expert needs lots of preparations, lots of
supporting documents to be submitted, lots of visits to police and prosecution
are to be made, and after all, it is not sure that the prosecution will accept
the case, and thereafter if referred to the court, who knows what would be the
outcome.
I do not want to file or defend any further case for you simply because you
always blamed me only, you told me several times that there are cleverar
lawyers in Dubai, and they can win your loosing cases.
If you are quoting the agreement signed between us, the agreement came to an
end on 14/2/2003, and the fee of Dh.3,000/-, as quoted by you for criminal
case, is only for defending any other criminal case "filed against you" till
14/2/2003, and not for filing criminal case "for or on your behalf" (please
see Clause (vi) of the agreement).
All the documents as required by you are available and your father in law had
taken the full file and photocopied everything when your wife was in Dubai
last time. From that file, you will see all docuemnts submitted to the court
and to the expert, because that file itself was copied from the court file. If
you again want the copies, you may do so. You may stop using your language of
75
threat against me and my firm, and I will not have any hesitation to file a
case against you in Australia for using threats and defamation, if necessary,
and I have enough evidence with me for the same.
Rest of the cases handled be me are handled in the strict professional basis,
and winning or loosing will depend on the merits of the evidences that you
have produced in the cases.
With Best Regards,

KK Sarachandra Bose
Dear Bose,
2003.
Boselaw
14th
April
The Besco x Dayal - had not become bad against me but was bad against Besco and was in my
favor - before you entered the case. the rejected case got re - opened, the first 2 auditors could
not give report against me - and this third auditor - the documents you had given to our auditor
and I had that time only atleast 5 - 6 times asked you to give me full details what all documents
you had given to our auditor to prepare the report. & the verbal objection which you had taken
you have no proof for that also - and against the auditor you cannot file a criminal case - why? I
have fully and very systematically made the webiste and no auditor against my report can prove
my report wrong / false / bad. you are saying you have worked alot for my case - and you have
no interest in fees - but I have asked you so many times to give me full details - but are you
giving me any details or proofs' I am even willing to come to Dubai to challenge this case - and I
am for this reason building the website for it. Even all the emails which between you and me we
have passed to each other I have placed in the website - so it will be helpful to you to even sue
me, in Australia.
Why every time are you telling me - that because of you or your advice i filed a case of dhs
600,000/ civil case against Becso - why would I not do this - why do you think so? Why is my
relation or something - yeah but I would not had sued him for 10,000,000/ how you did I
would had done for 1 - 2 million maybe. Thats why I didnt even file any case on SCB also any
sue case - in the website you will also get SCB details. You already have the CD - but now I have
also added the private crime report also. Whenever you have my case, even your lawyers who
are attending my cases - tell them to refer my website - as it will be very convenient to refer my
cases.
76
Now also I am saying the case is good and you can file a criminal case against the auditor and
if my this case time is also gone - and if I will have to pay 1 million aslo then your emails and
my emails will all prove - how you have wasted the time - if you will not get time for me to file
the case then Iwill have only one way then I will file a criminal case against the auditor and if
you wont do Ishall get it done by some one elz, under the same terms - if he wins he will earn
dhs 100,000/ or maybe how much ever he will help me to get back I may offer him 10 or 20 %
of it. Even Bahrain case details are in the site.
Thanks
Regards
Dayal
From :
To :
CC :
Subject :
Date :

boselaw@hotmail.com
Re:
Mon, 14 Apr 2003 07:18:15 +0000

Dear
Mr.
Put in Folder...

Dayal,
In the case of Dayal-Besco, we have yet to receive a copy of the judgment from
the court. Sometimes it takes 15 to 20 days or more to get copy of the
judgment, and this is normal. Normally, if we do not get the copy of the
judgment before 30 days, we file a provisional appeal in order to be within
the time frame, and we are aware of it. Our provisional appeal in the said
case is ready and we will file it in this week, if we do not get the copy of
the
judgment
in
a
day
or
two.
I repeat that I will not file criminal case against the expert even if you
promise to pay me Dh.100,000/-, simply because I do not want to work for a
client who does not have faith in me, who does not appreciate the efforts that
I put in his cases. Fees is not the only criteria for a lawyer,lawyers need
satisfaction also. I told you from the very beginning that you may loose
Besco-Dayal case and on my insistence you filed Dayal-Besco case when Besco-
77
Dayal case was in the appeal stage. You never said a good word about it,
instead you are accusing me for loosing Besco-Dayal case, even though BescoDayal case was not filed by me, and I entered in the case at the last stage of
the appeal, and I told you that nothing more could be done in this case at
this stage. Just because you do not have proper documents or agreements to
support your claim, you want to put the blame on somebodyelse.
With
Bose.
Best
Regards,
Boselaw
Dear Mr. Bose

You are handling all my cases. You know my end of the story. I have not committed any crime in
Dubai, and neither do I owe anyone any amount of money. You had filed my case against Raj
Benaud : Dayal Vs- Besco International 183/2000 511/2003527/2003 3rd September 2003 to
serve notice to the 2nd Respondent by Paper Publication.
We have already got its judgment that he has to pay me Dhs 600,000.
I have not received any papers concerning my cases since July 28, 2003. I had requested you
on 30.8.03 to check my name in the computer whether my name is on the wanted list. I had
called you twice, telling you that I am returning to Dubai on an urgent matter. You received
the email and call early in the morning. When I spoke to you, you hadnt checked the list yet.
Besco Vs- Dayal 557/1998, 454/2002, 491/2002 opposite party has filed Execution
I had asked you about this case. Raj had filed this case against me, and this case was rejected
then. When I left Dubai in August 2002, everything was under control. Since then, all my cases
have turned around against me. I had asked you for the judgment on this case and also check my
name on the computer, but I did not receive that from you. I had asked you to check my listing
urgently, since I am coming to Dubai very soon. I will come and ask the court myself, whether
they are going to reopen my cases or not
Why is there so much delay in letting me know about my status in Dubai?
I want full inquiry, about my status in dubai. Why am I wanted, who filed a case against me, how
much money am I supposed to pay, and how I can get rid of this matter? What if I give a bank
guarantee and if so, how much? I want a way so that my passport is not blocked and I can still
travel freely in Dubai, and also leave Dubai when I want to.
Please respond to me as soon as possible.
Besco Vs- Dayal 557/1998, 454/2002, 491/2002
From :
"Pooja Mansukhani" <poojamans@hotmail.com>
78
To :
Date :
boselaw@hotmail.com
Wed, 03 Sep 2003 00:25:19 +0000
Dear Bose
You have not sent me any email aftI cannot use the hotmail as you are sending
repeated bulk mails. Please limit sending your messages without repetition.
Bose.
Boselaw
Dear Mr. Dayal, 10/9/03
I totally disagree with you in you blaming the entire system in a country just
because you failed a case. You are going too much in your accusations. What
you have to do is to appoint another lawyer, if you wish, and let him see if
there was a mistake in presenting your case, or in passing the judgment. Then
you have to make representations to the appropriate authorities. You cannot go
on publishing tarnishing remarks against a system in which I am also working.
BDear Mr. Dayal,
I have just tried to open the attachment, but it shows "infected with virous"
and there is no cure for it.
Can you send it without attachment.
Best Regards,
Bose. Boselaw est Regards,
Bose.
Boselaw
Dear Mr. Dayal,

The execution and arrest warrant is in the case of Besco-Dayal. In Dayal-Besco
case, even though we got a judgment of Dh.600,000/- in your favour from the
lower court, the judgment is appealed by both Dayal and Besco and is pending
at
the appeal court. Besco has submitted the Expert report and judgment in the
case
of Besco-Dayal in Dayal-Besco appeal and requested the court to dismiss the
case
stating that both are one matter. We are fighting the case in the appeal
court.
if you come now, you will be required to

pay to Besco the full amount
of execution. My suggestion to you is that, if
you can wait until the appeal
case is decided, and if the appeal comes out in
your favour, then we can execute
the judgment against Besco also. You have to
take my suggestin positively.
Therefore,
79
In respect to your other cases, the matter with Sunder and Dileep was delayed
as
there was no person from your side to go with the court clerk to show their
place. I sent my man twice and he came back and said that he could not find
out
the office. In respect to Prabha Nair, it seems she has changed her address.
Anyhow, arrest warrants are issued against all of them.
Best Regards,
Bose.
Boselaw
From :

To :
CC :
Subject :
Date :
dayalm@hotmail.com
YOUR DUBAI CASES.
Sat, 06 Sep 2003 12:03:33 +0000
Put in Folder...
Dear Mr. Dayal,
We have checked in the computer and your name is in the

computer in respect to
the execution made by Besco. This means that the court has
issed arrest order in
the execution filed by Besco.
9/12/203 &
26/6/206
arrest order
4676/2002,4787/2002 (557/98,454/02,491/02
Details of your other cases are as follows:-
5909 ,
Dayal Mansukhani Cases as on 06th September 2003

Sl.No
Dayal's Cases Court of Ist Instance Appeal No Execution No Cassation No
Remarks
1
Dayal Vs- CBI 827/2001 467/2002 304/2003 We filed Cassation on 17th June
2003 waiting for Judgment.
2
Dayal Vs- SCB 658/2001 9th September 2003 - The case is referred to the
criminal lab to investigate about the 2 cheques.
80
3
Dayal Vs- Sunder (Silky Star) 1132/2001 769/2002 1671/2003 369/2003 We
have
already made an arrest order for Dilip & Sunder.
4
Dayal Vs- Besco International
183/2000
511/2003527/2003
01st October 2003
to re-summon the 2nd Respondent by Paper Publication and for our reply.
5
Besco Vs- Dayal
557/1998 454/2002
is made against
2002 Arrest order
491/
you.
6
Kavitha Arjandas Vs- Khaleej Times 157/2000 70/2003 351/2003 16th June
2003 - Filed Cassation, waiting for the Judgment.
7
Dayal -Vs- Prabha Nair 175/2002 1092/2003 We have already made an arrest
order for Ms. Prabha Nair
8.
Dayal Mansukhani Vs- SCB (Criminal
Case ) 1246/1999 1174/1999 145/1999 Waiting for the orders from the prosecution.
Best Regards,
Bose.
Boselaw
Rom Bose Bose <boselaw@hotmail.com

Rom Saturday, January 3, 2004 1:00 PM
To dayalm@hotmail.com, poojamans@hotmail.com,
Subject : YOUR CASES IN DUBAI
boselaw@hotmail.com
Dear Mr. Dayal,

Dayal Mansukhani Cases:
1.Dayal Vs- SCB: 658/2001-The Dubai Court of First Instance dismissed the
case
on 24/12/2003. We haven't received copy of the judgment. You have 30 days to
appeal against the said judgment and we advise you to appeal against the said
judgment. This was informed to you by telephone.
2.Dayal Vs- Besco International
183/2000,
511/2003527/2003:The
Court of Appeal
pronounced the judgment and dismissed the appeal filed by us and the judgment
was on 17/12/2003. We have not received copy of the judgment and we advise you
to file cassation against the said appeal court's judgment. This was informed
to
you by telephone.
3.Dayal Vs- CBI:827/2001,467/2002,304/2003:
2003 and we are waiting for Judgment.
4.Besco Vs- Dayal:
557/1998,
We filed Cassation on 17th June
454/2002,
491/2002:
Arrest order is issued in your name.

5.Kavitha Arjandas Vs- Khaleej Times:157/2000,70/2003,351/2003: On 16th June
2003 - Filed Cassation. We are waiting for the Judgment.
6.Dayal -Vs- Prabha Nair:175/2002,
already issued
1092/2003
: Arrest order is
81
against Mrs. Prabha Nair. Her present address is not known and if you know
the
address, please let us know.
7.Dayal Vs- Sunder (Silky Star):1132/2001,769/2002,1671/2003,369/2003: Arrest
order is already issued against Mr. Dilip & Sunder. If you know the location
of
them, please let us know.
In respect to your tlephone call made to me yesterday and the accusations made
by you, please note that we will not entertain your such accusations just
because you lost your cases. You may at any time verify the court records and
you will find all that we have done in your cases.
With Best Regards & Best Wishes for a Happy & Prosperous New Year.
Bose.
Boselaw
Original Message Follows---From: "Pooja Mansukhani" <poojamans@hotmail.com>
To: boselaw@hotmail.com, aladalah@emirates.net.ae
Subject: urgent - reply me soon Date: Thu, 13 Feb 2003 13:58:23 +0000
My lawyer is very clever he saw the SCB certified bank guaranteed chq
returned not one but 2 if this case is won then we can sue the bank where
the lawyer will share his benefit of 25% - Besco intl damages 10 million case
lawyer shares his benefit of 25% and other 4 5 cases of big amounts of
more than 2 million approx. Lawyer fees 10%. All cases very genuine and
with all documents winning points and good evidences, after checking all
this agreed for a small down payment as he was convinced with the cases
any lawyer would agree to it - after seeing all the evidences provided.
Case No. 1 2 bank guaranteed cheques return amount dhs 300,000/ - civil
case.
Case No. 2 Bank guarantee private laboratory report Arab Lab For Technical
Inspection with this private lab report criminal case challenge. Can win
this case easily and also can file a case for damages on the bank for more
than 10,000,000/ million.
Case No. 3 Above dhs 700,000/ PDC cheques returned of Besco Intl. Plus damages
dhs 10,000,000/ - civil case.
Case No. 4 CBI bank dhs 425,000/ civil case
Case No 5
Dhs 150,000/ Khaleej Times Alliance Insurance
Case No. 6 Dhs 50,000/ Alliance Insurance

Case No. 7 Above dhs 500,000/ Alphonse Dhas Bharain case.
82
Case No. 8 Dhs 125,000/ Silky star and sunder civil case.
Case No. 9 Dhs 14,000/ - Prabha Nair.
Case No. 10 Besco filed case against me a wrong case civil case. After 2
years case was dismissed, because he did not send the auditing report
opposite party appealed and easily won the case and claims more than dhs
1,000,000/ and my lawyer taking objection not in writing but verbally. Now
case is waiting for appeal. All the cases are running in the court case no
10 and case no 5 lost gone for appeal.
If in appeal good way someone will handle then guaranteed will win the case.
Note: if any case on date requires reply from my side or wants any help to
any lawyer I can give him all the points so that he can in legal way fight
the
case and will win all the cases, accordingly.
If any lawyer fights the cases with good understanding then we can file for
damaging also 10- 15 millions and 20% damaging share for the lawyer. Only
down payment if agreed to take less if someone fights the case with only
those
grounds which I mention and I have those evidences in the file with the
lawyer then we can win all the cases. All the cases are real no case is
bogus. Besco intl. 100% local company in name of Almullah Dubai Labour dept
officer,
established company for the man power supply in 1995. from 1995 took financial
support from me.
Dayal Mansukhani issued cheques to Raj Bernard Besco Intl. Some cheques were
cashed by Mr. Hari Kumar Besco manager and some by Mr. Leslie Nunez and M.
Stanley and some by Mr. Raj himself.
I paid money more than dhs 3, 000,000 from 27th nov. 1995 till 20th dec.
1997,some were in cash also but all the details that I am giving you, I have
collected from bank and given to my lawyer the cheques photocopies which I
have received from the bank 100% proves that this money which I have
photocopies from the bank - has been received by Besco Intl. From 1995 to 1997
every dealing was done smoothly Dubai dry docks was transferring the money
and
paying me and I was also against these payments after deducting my amount
would return back the excess payments and I also was financing him more to
increase his business as everything was going smoothly, Besco. 1997 December,
20th, Raj was leaving for Bombay he asked me to return the old PDC cheques
and for the balancing amount which was more than 900,000 he issued new 12 PDC
cheques, and new agreement from dry docks for the installments from dubai dry
docks but I recd only installment from Dubai dry docks and rest all the
chqs were bounced.
Besco international 100% locals company local Mr. Ahmed Abdullah Mohammed
Almullah. All these cheques PDC were in 100%
Almullah company name and Almullah gave Raj the power to sign. Almullah gave
the guarantee to the bank also so if the cheques are bounced it is Mr.
Almullahs responsibility to pay the amount. Habib Bank Ltd. Cheques, Mr.
AlMullah had given guarantee to the bank.
Note: 20th july 1997 he collected from me dhs 300,000 loan chq nos. 539 and
deposited in bank and took bank guarantee and changed company into LLc, when
83
the license was prepared within one month on 20th aug. the bank guarantee
fixed deposit expired and was credited to my account he arranged a new local
partner from some Sheikh family. He issued a letter on 7th February 1998 to
dubai dry docks to stop transferring money to dayals account and after this
all the PDC
were bounced. Here the problem starts. Above 900,000 cheques were bounced.
I filed 3 criminal cases against Raj in Dubai and 2 in Sharjah and 2 in Ajman.
Every case he has agreed that - he has to pay Dayal the said amount.
My
cheque details
27/11/95
CBI bank
Mr. Raj
9/12/95
Mashreq bank
---------------------23/07/96
mashreq bank
-----------9 / 9/ 96
mashreq bank
K
5/11/96
-- ----------10/3/97
------ ----26/5/97
----------N------20/7/97
---- -------23/7/97
-- --------11/8/97
-----------24/8/97
------ -----20/10/97
- -------total
2,281,210/_________________
chq no 115877
400,000/
cashed by
chq. No 109
100,000/
chq. No 259
364,000/
chq. No 307
98,360/ cashed by Hari
--------
342
100,000/
----
395
456
160,345/
205,000/
-Leslie
539
545
552
-561
628
300,000/
204,000/
149,519/
190,000/
9,986/
Raj BescoLLc.
leslei nunez
Leslie Nunez
M. Stanley
Hari K.
these cheques amount to 2281210/ - dubai dry docks transferred to my account

1,463,157/ remaining dhs 818035/ - sometimes I have paid him cash too by
withdrawing cash from my account in sharjah, ajman, dubai.
______________________________________________________________________________
______
In 1998 I filed a criminal case for 3 chqs 223796 and this amount is paid
to me in via court, by Raj.And other criminal cases were transferred to civil
on these grounds but he agreed in every criminal case that he has to pay me.
After 1998 after paying me money after al this he filed wrong civil case in
1999 that I have blocked his money from 1996 and that I am not paying him if
in 1996 I had blocked his money then why in 1998 he paid me and not take any
action? After all this
documents and evidences given to my lawyer, my LAWYER LOST the case.
Mr.Raj on his own letter head sent me fax very clearly mentions he
received a cheque from me in which he has given the entire details from 1/3/97
to 20/1/98 he has collected cash cheques of total amount of 1,408,124.00 this
money he has
recd all this in the 1998 auditing report, from Al Rubbiae and company,
which is with my lawyer. All the documents are with the lawyer and still I
lose the case. Raj owes me still dhs 900,000 but he has filed against me a
wrong case in
which he says he wants from Dayal Mansukhani more than dhs 1,000,000/.
84
Note: the opposition lawyer who gave the audit report was totally wrong all
the time he has only shown the dry docks payment but mine all the cheques and
audit report of which all the copies were with him, he has never mentioned
about
my audit report and cheques details and my lawyer has never taken any
objection to this point if that time only my lawyer would had taken
objection and would had shown all the cheques photocopies then the court would
had never given
judgment against me.
He collected loan from me in 1996 dhs 400,000/ and he has paid me till 1998
through dry docks dhs 1,463,157/ and that I have not paid him anything. And he
has issued me new PDC chqs, why did he issue me these new chqs? and now
instead he is demanding me dhs. 1,000,000/ My lawyer has all these evidences which I had submitted him, against the case
still he lost my case and did not take objection in writing when the court
submitted an audit report.
Note: I lost a wrong case which was filed against me still he did not take
any objection, in writing only verbal objection was taken for the audit report
when I asked my lawyer for the written objection taken, if any he says it
was
taken but verbally. If this case is not accepted then it will mean I lost 2
millions I had to take from this Raj 1,000,000 approx now I have to pay him
this figure.
Another case my lawyer has filed against Besco Intl local company 100% Almullah. All chqs are bounced. 10,000,000 case is filed above 700,000 is
the capital, and also the damaging caused which is about 10 million.
Almullahs one
statement that Raj changed the company partner and all the responsibility of
Almullah is gone / finished.
No one is asking Al mullah if he had sold the company why he did not close the
account and the power of attorney? It is Almullahs responsibility to pay me
the amount due and then collect from Raj.
My lawyer has asked me to bring 2 witnesses for this Rajs LLc case but
for what reason and why would this be required I have not got a proper
answer to it, from my lawyer.
I have given my bank details and also bank power for you to collect any
documents if needed for this case, to my lawyer. This way it can prove when
the llc. was made and temporary 300,000 was arranged by Raj and after the LLc
cancelled the fixed deposit amount this means no capital and no locals
money involved all the responsibility involved is of Raj. This can be proved
by the bank and I had sent all this to my lawyer for case help purpose
If my lawyer can fight this case in good way by putting the full
responsibility over to Almullah then we can win the case Rajs lawyer can
even make us lose this case on behalf of the lost case if my lawyer will not
handle
this case well, then I can lose this case also. My weakness is that my lawyer
cannot go to court as he is an Indian, he cannot fight.
85
Important point: court judgment point no 10 (1) raj has mentioned in the
court that goods for payment due on 1998 was handed over to dayal.
Also prove this in the judgment copy in criminal case it will help us.
Details for case no 1
Standard Chartered bank guaranteed 2 cheques, returned.SCB guarantee cheque
right due date deposited returned reason given -refer to drawer Amt dhs
100,000/- Second cheque also deposited on the right due date bank filed
against me
criminal case public prosecutor cancelled the case gave judgment that
alteration was legal, still did not received the payment till today.
Important point: court judgment point no 10 (1) raj has mentioned in the
court that goods for payment due on 1998 was handed over to dayal.
Raj had filed this case against me and he himself has confirmed in the court
that he gave these Good for payment cheques in 1998 to Dayal.
Any bank guarantee cheque if issued in my name it is banks responsibility
to make this payment, to me.
The 2 cheques are not of small amount it is clearly seen due date is 1998
every one will say it is due on 1998. while bank said this guarantee was given
in 1996. I had given payment in 1997 dec. then bank will give me PDC gaurantee
cheque after the deal or 2 years before? Definitely I will be given after 1997
not before 1996. my bank statement is in the file Even the private auditing
report proves both cheques are written on the same day. In one cheque there is
legal alteration and rubber stamp also available and signature of 2 bank
officers. And both cheques are in the serial order chq. No 404977 and 404976.
means both are issued in 1998.
All this proofs in civil case the bank has to pay the amount, in court
guaranteed. If the lawyer is not smart then this would mean relation is more
powerful than law. He will lose his profit along with mine.
Case No 2
Criminal case challenge: 15/7/98 chq no 404977 I deposited on the right date
and chq was returned with reason given refer to drawer. Bank SCB memo is
proof and Mashreq bank too. This confirmation I have. When 2nd and 3rd time
cheque
is deposited reason was given alteration. This means - bank confirmation
- that alteration was made after 15/7/98. Who would do this? My signature in
not there cheque is in my favor. If cheque was honored on the right due date
there
would had been no problem it was bank guarantee cheque bank was bound to
pay this proves bank crime is confirmed.
Bank is a british bank powerful and big influence this reason can do
anything.
Other cheque no 404976 this cheque has an alteration clearly visible but
has all the necessary signatures on both the sides and rubber stamp also
available which means LEGAL ALTERATION. After this also bank had filed
against me a
86
criminal case and twice laboratory checking both time resulted Legal alter
is made. And public prosecutor dismissed against me the case and police gave
me cheque back after 6 months, and asked me to deposit the cheque.
I deposited the cheque on 15/10/98 which was the due date but bank filed
against me a case and they were proved wrong when I deposited the cheque
after proving myself right again I was not paid reason given OUT of
DATE.Any lawyer can fight this case and claim from bank for the
damages,intelligently.
Case No. 3.
According to these above mentioned points damages claim for 10,000,000/
civil case and more than 700,000/ PDC cheques returned and my business loss
and my name and I suffered 2 heart attacks in that period of time and also a
bypass
surgery and my 2 brothers lost, and my peace gone, my family also suffered the
trauma, in this period of time. I had filed 4 5 criminal case against Raj
and in every case he confirmed he had collected the money and had to pay those
amounts. He asked for the transfer of cases to civil, as he had already been
penalized for one criminal case. Any lawyer can fight this case and make big
profit lawyer fees and 25% damaging fees.
Case No. 4
Bank debited dhs 425,000/ - of high rose guarantee in Pooja Mansukhani
term deposit no 3702020225.
This deposit in the name of Pooja Mansukhanis name singular Main point
lein letter not signed by Pooja.
High Rose PDC chq discount facility applied on 19/10/2000. I want from
High Rose dhs 850,000/ - high rose transferred to my account dhs 400,000/ on
28/10/2002. means it is confirmed that the facility was passed before 28th
October 2002. My more fixed deposits were there with them in the name of Dayal
Mansukhani, and I had taken many loan facility against my fixed deposits for
which I had signed blank Lien letters.High Rose in my account transferred
dhs 400,000/ on 28/10/00 which he owed me and bank took advantage of this
and using my old Lein Letter which was with
them and with this documents help they used it for the guarantee of high
rose for dhs 425,750/ and they dint have my fixed deposit that time with the
bank so they put Poojas term deposit number and dint even take poojas
signature for
verifications. Why & how without poojas signature they could do this?
This fixed deposit I broke on 31/10/00 and I had withdrawn dhs 60,000/ from
this if this was under Lein then how could this break no fixed deposit
can be broken so easily or quickly this also proves that this fixed
deposit was
not under lein.
Another document the bank showed me 0n 30/10/2000 when I spoke to bank I
asked them for withdrawal of dhs 60,000/ from this fixed deposit but I went
on 31/10/2000 and I signed a paper as I was in a hurry and my English is
also
not very functional and at the place of signature I put the date 31/10/00
in which they had written that the balance from the fixed deposit to be lein
against the LBD chq for dhs 425,750/-.If any bank gives Lein it keeps a
87
guarantee then in joint account usually one signature is required but when
giving Lein 2 signatures are necessary. And
this fixed deposit was in Poojas name Poojas signature is not available,
anywhere.
High Rose issued bank favor dhs 400,000/ chq for banks guarantee to take loan
facility. Its own PDC cheque also its personal documents. All high roses
discounting cheques got bounced and the cheque which high rose had issued in
the
banks favor for guarantee was bounced. Bank had more than dhs 850,000/ in its
possession, bounced. I came to know from the market that high rose was going
to escape and cuz I had good old relations with the bank I informed them
about
this. And I asked them to take action on him as soon as possible that time
the bank told me that my lein letter for guarantee was with them. I instructed
them to take criminal action on him and that he would not go behind bars
as he had enough money to pay but bank did not take any action against
him.Why did the bank not taek action? I asked the bank to give me the
documents if it was my guarantee but the bank did not give me the letter
to file a
complaint against him - they did not do that too. High Rose all PDC cheques
and personal cheque were bounced before 15th
January 2001 if it was my guarantee then why did not the bank debit from my
account the amount if they would had done so (debited my account) then I
could had taken action on High Rose. He fled from Dubai on 20nd feb 2001.
after he fled
bank debited Poojas fixed deposit all these points plz make note --- all
evidences with me. I also sent 4,5 letters alerting them that he was planning
to run away from here bank did not bother did not debit my account with
the
amount did not issue any letter to me so I could take any action and
waited for him to run away and after he ran away debited my account. If any
lawyer will study this case and present with acumen it is a winning case.
Case no 5.
January 1999 Ramdan month on Wednesday even. KT newsboy came to office to
collect the payment. My brother paid on 27th jan. in the office working in
my firm. I issued chq on 27/1/99. my brother asked him to start the paper from
next
day and also take signature from his wife from home. Arjun singed the
document on 27th jan. 99 which means the insurance is covered form 27th.- if
the wife signs on 27th or 29th I dont know about that. For this reason the
case was
filed as they did not rec. the claim Arjun suffered a heart failure on 29th
afternoon.Khaleej Times newspaperboy collected chq no 42 dated as on 27th
Jan.1999 drawn on Mashreq bank Rec. voucher no. 30475 shows clearly 27/1/99
chq recd.on 27/1/99. paper starting from 28/1/99 27/1/00. Here at one place
there is alteration this is in the khaleej times rec. voucher. Alliance
insurance document shows - dxb 25864, clearly insurance cover from
28/1/99 27/1/00. Policy is in the name of late Arjun. Mansukhani, second
coverage of Kavita M. At the place of witness kavita has signed and there is
an alteration at witness place either 27 or 29. Both are main documents and
at 3 places dates are clearly mentioned. 2 places it is very clear while at
the 3rd place an alteration is seen. If witness is taken
anytime then will 2 would be right or one witness would be okay definatley
2.My lawyer lost this case because of one place alteration. And at the 2
places where the dates are clear this case is not in the appeal.
88
Case no 6.
This case Alliance ins. My lawyer won, but due to the case no 5 maybe this
case maybe lost. If clever lawyer then with the help of 6 no. case can win
the case no 5 also in the appeal court.
Case no. 7
This case is very simple any civil case wants confirmed documents I filed
the case in Bahrain court and Bahrain court registered - written agreement on
24/5/99 very clearly mentions Abba Intl has to pay me US $ 300,000/ - in 20
installments agreement is done between Dayal Mansukhani Indian PPno. S
598011 and Abba Intl. ( C.R.No. 25251) Managing Director Alphonse Dhas. All
chqs PDC issued in favor of Dayal Mansukhani and all cheques bounced.
Dayal Mansukhani filed case against Abba intl. As the cheques were in Dayal
Mansukhanis favor so only he could file the case against Abba and the Bahrain
agreement is done registered between Dayal Mansukhani and Abba intl. NOTE:
nowhere is it mentioned Dayal Mechnical Works Llc. If it is Dayal Mansukhanis
claim - then dayal will give the power of attorney and he has given this
power to Mr. Bose. Is it right or wrong? Myside I have given my lawyer the
power of
attorney. I have done everything in a legal way. The opposition lawyer is very
intelligent. He has submitted in court the LLc documents of Dayal Mechanical
works in which it shows 3 partners Dayal Mansukhani and Pooja Mansukhani
and the third is a local partner. My lawyers cannot fight this case as he
is an Indian so another lawyer has been appointed
for this case in Bahrain on our behalf. Bahrain court is demanding him Dayal
Mechanical works llc. All partners power of attorney. There is no
interference / no claim of any of the partners or Dayal mechanical work
companys in this
case. All claim is only of Dayal Mansukhani. But my lawyer is not checking
this point and is asking me to arrange the power of Dayal mechanical works
LLc why should I give this power?
Case no 8
The judgment is in our favor to pay the interest and traveling ban. But
relation is more than law- my man showed the shop but silky star shop was
closed. He gave mr. Sunder K mobile number also. But there is no response.
This case what will happen I dont know.
Case no 9.
I gave my lawyer all the contact numbers and her mobile number her companys
name. Now I dont live in dubai so I cannot provide more informations about
this person. I dont have any souce to find our moe about this person. All the
photocopies of passport of the husband and wife my lawyer can arrange for
her travel ban.
Case no 10.
Besco filed against me wrong case he says - he collected from me dhs
400,000/ only whereas I have paid him dhs 1.4 million approx. and after 2
years he is demanding me. In 2 years he did not say anything after 3 years
he is filing
89
against me civil case. 3 years he has kept paying me without any word and
all of a sudden after 3 years he says he has been paying me excess. Who asked
him not to claim from me for 3 years? The entire case is stated above. On the
2nd
page it is detailed briefly about this case. All these are my cases in short
tried to explain, in Dubai.
Mr. Bose
All these cases are with you if you can fight these cases in good way and
seriously then let it be with you
If you cannot and your lawyers firm is not happy with these cases then
kindly take from court 3 months time and tell them that you are returning all
the cases back to client and ask them for 3 months post poned date & whatever
advance
payments you have please return it back to me so I can arrange a new lawyer.
Please reply me in 7 days time if you are interested to fight these cases if
not let me know asap. if any loss it iwll be uer responsibility.
Email confirmations are legal these days. I am faxing to you as well as
emailing. Fax no: 3340303 - 3354000 -
Rom Bose Bose <boselaw@hotmail.com

Rom Saturday, January 3, 2004 1:00 PM
To dayalm@hotmail.com, poojamans@hotmail.com,
boselaw@hotmail.com
Subject : YOUR CASES IN DUBAI
Dear Mr. Dayal,
Dayal Mansukhani Cases:
1.Dayal Vs- SCB: 658/2001-The Dubai Court of First Instance dismissed the
case on 24/12/2003. We haven't received copy of the judgment. You have 30 days
toappeal against the said judgment and we advise you to appeal against the
said judgment. This was informed to you by telephone.
2.Dayal Vs- Besco International 183/2000,511/2003527/2003:The Court of Appeal
pronounced the judgment and dismissed the appeal filed by us and the judgment
was on 17/12/2003. We have not received copy of the judgment and we advise you
to file cassation against the said appeal court's judgment. This was informed
to you by telephone.
3.Dayal Vs- CBI:827/2001,467/2002,304/2003: We filed Cassation on 17th June
2003 and we are waiting for Judgment.
4.Besco Vs- Dayal:
557/1998,
454/2002,
491/2002:
order is issued in your name.
3.Dayal Vs- CBI:827/2001,467/2002,304/2003:
Arrest
90
4.Besco Vs- Dayal:

557/1998,
454/2002,
491/2002:
5.Kavitha Arjandas Vs- Khaleej Times:157/2000,70/2003,351/2003: On 16th June
2003 - Filed Cassation. We are waiting for the Judgment.
6.Dayal -Vs- Prabha Nair:175/2002,
1092/2003: Arrest order is already
issued against Mrs. Prabha Nair. Her present address is not known and if you
know the address, please let us know.
7.Dayal Vs- Sunder (Silky Star):1132/2001,769/2002,1671/2003,369/2003: Arrest
order is already issued against Mr. Dilip & Sunder. If you know the location
of them, please let us know.
In respect to your tlephone call made to me yesterday and the accusations made
by you, please note that we will not entertain your such accusations just
because you lost your cases. You may at any time verify the court records and
you will find all that we have done in your cases. With Best Regards & Best
Wishes for a Happy & Prosperous New Year.
Bose.
Boselaw
Dear Mr. Dayal,
I have seen your fax message as well as this mail. To file a criminal case
against the auditor is not a joke. You need sufficient proof and it is time
consuming as well. More over, if you want me to file the case, I will charge a
fee not less than Dh.50,000/- and there is no guarantee that you will win the
case. What I told you is my opinion. I told you that I will not file criminal
case against the expert for two reasons: (i) you blame me when you lost the
Besco Vs. Dayal, which in fact was not my case, in the sense, not filed by me.
To
5, 2003.
Mr. K. K. Sarachandra Bose.
Dar Al Adalah
Dubai UAE.
Tele no. 3340303 mobile 6245087 fax: 3354000.
Email Add: boselaw@hotmail.com
April
I am declaring I shall pay you dhs 100,000/ - if you win the

case according to the below statement.
Dear Mr. Bose,
I had given you all my cases about 8 -10, of which I have paid you fees 2.5% balance when
you win you will take from me 7.5% or else your efforts go waste. Even your company who is
putting all the efforts and time will not earn anything if you lose the case. Any criminal case if
someone files against me or you file against them then you we charge your fee only dhs 3,000/
and if any case goes on for more than 3 years then you will charge more dhs 3,000/. And any
damaging or sue I shall pay you 25 %. This is your agreement. Now I am giving you in writing
through email and fax.
91
You are demanding me against dhs 3000/ - dhs 50,000/ to file a criminal case I shall pay you
dhs 100,000/, this dhs 100,000/ is only for this criminal case if you win this case then you will
win all the cases against Besco and you will earn more 2- 3 lakhs added to all this you and your
company will earn so much reputation. And you will be able to sue on SCB easily. I am replying
your email and faxing too.
I am declaring again I shall pay you dhs 100,000/ against your demand of dhs 50,000/, if you file
a criminal case against the auditor for dhs 2 million. By doing this the auditor will help us to
win the case and even reopen this case. You can then negotiate with the auditor that if I lose
he will pay the 2 million or if we win then he will be free from this case which is filed on him.
Even the SCB case will turn in our favor. Either the auditor will pay the 2 millions or will help to
re open this case. If it will be my loss means it is your loss and my benefit will mean the same.
If you lose this case you will still get the fees according to your agreement i.e. dhs 3,000/. Why
cant you take a chance? Why cant we file this case?
If you do not agree then I have as on 29th mar 2003 demanded some documents, you please
arrange these documents and send me or handover to my father in law, I shall file the
criminal case or give it to some other lawyer to do so or I will come there.
Thanks Regards
Dayal Mansukhani.
92
93
94
95
File 14:
Case 557/98.
This case started on 31 January 1999 with out a lawyer. I had received more than
100 pages of documents from the court. But without lawyer, I had submitted a 2
page Arabic translation of my request and my auditing report and demanded the
judgment.
The court had asked BESCO the auditing report. And within 2 years BESCO had
appointed 2 auditors and took a lot of time. These 2 auditors were met by Mt
Haashim and Mr.Hashim had given all the photocopies of the cheques and my
auditing report. The 2 auditors received my documents. The auditors did not make
any report against me and even the Bescos lawyers could not prove that my
documents are faulty. Court has given BESCO 3 year time and to submit the
auditing report. But since BESCO could not submit any report with in the period
the case was dismissed
One month before the case was going to be dismissed ,Bose was working with
GALADARI firm. And Bose had told me to stop Hashim to handle the case and
that GALADARI would handle the case from then onwards as one of the
GALADARI lawyers was also attending the same case. He told me that if Hashim
is handling the case then GALADARI would not handle the case. In the mean
time no documents were handed to any of the lawyers to show in the court as there
was no requirement for it.
I had given all my cases to Mr Bose as I cannot speak English he could speak
Hindi. So I handed all my cases to him along with all other cases. I had requested
Mr Hashim to stop handing this case from then on. After words this case has been
dismissed.
After the case had been reopened only Mr.Bose was handling the case not any
more Mr. Hashim. All my documents of my bank accounts. Bank statements were
with Mr.Bose. Mr.Bose or Mr.Boses assistant Mr. Felix would have attended the
third auditor. Mr.Bose email proves that he did not attend this auditor. I was in
Dubai the last July and I met Mr. felix. We both met the auditor but the auditor had
given appointment at some other time. At that time Mr.Bose was working with
DAR-AL ADALAH.
96
Please check files from file9- file14. all the documents are attached. All the
account details are attached. Raj had told me that he know many staff in the
standard charted bank and that he can get bank guaranty in illegal way. He told me
that he has to help the bank and that he filed file a wrong case against me. So in
December 1998 he has filed a wrong case against me. he claimed that instead of
paying 400,000 he paid me 14,00000 to me and that he will make me pay more
than 1 million from me . now check my account statement. I have all the proves
that I had paid more than 1 million from March 1997 to January 1998. proof below.
the below are the details of the money transferred by Dubai Drydock into my account in English
The above statement are the details of the cheques in Arabic.

The below mentioned agreement proves that BESCO was supplying man
power to dubai drydock. And BESCO gets the payment after 60 days.
Since the labor should be paid every one month , Mr Raj took 400,000
cash from me and gave me PDC cheques and said that Dubai Dry docks
would transfer the money in to my account every month and I was
deducting my installment amount and was paying the remaining amount.
All the details of the cheques and cash that I had given to him are
mentioned below.
To, THE POLICE HEADQUARTERS DUBAI POLICE U.A.E.

mail@dubaipolice.gov.ae mail@dubaipolice.gov.ae
Sub.: Request for assistance in providing information about warrant issued by Dubai
Police.
Dear Sirs,
I am an Indian citizen who was in Dubai for more than 25 years. I left for Australia in the year
2002 and after staying for four years in Australia I have now come to India.
When I left Dubai there was absolutely no warrant or decree/ judgement against me. I had certain
civil and criminal proceedings against one Mr.Raj Bernard who was previously having business
transactions with me. After I left Dubai, I was monitoring my legal cases through
Mr.K.K.Saradchandra Bose (An Indian Lawyer in Dubai). However later I discovered that
Mr.Bose did not handle my cases properly and infact misled me by sending me wrong
information from April, 2003 onwards while at the same time spoiling all my legal cases in
Dubai. In April, 2003, Mr. Bose sent me a message that there was an arrest warrant against me.
97
He thus discouraged me to come over to Dubai. This created difficulties for me in coming over
to Dubai and assisting in my legal cases.
Today I have discovered that in my absence, Mr.Bose spoilt my legal cases and in fact he did not
submit various documents and records which were required to be submitted to the Court
appointed Accountant and as a result, in place of decree/ judgement earlier obtained by me, an
adverse decree and judgement has been obtained by Mr.Raj Bernard against me. I now propose
to return to Dubai. I have highest regard and respect for UAE in general and Dubai in particular.
Any person who is absconding would generally not stake his life and money when he learns
about pending warrant. However, I have made up my mind that in respect of court disputes, I
shall offer to the court full amount of dispute claim by obtaining finance from my friends, well
wishers and relatives. Thus I am risking my person as well as my funds that I would be
depositing. I believe in the legal system of UAE and I am confident that I will get justice.
However, I need your assistance to get the correct information. I enclose herewith a copy of the
email received by me from Mr. Bose wherein he clearly mentions that there is an arrest warrant
against me and my name appears on the website of Dubai Police.
I need the following information from you:1) Whether any warrant was issued against me ? If so, when was the same issued ?
2) Whether any warrant is pending against me as on date ? If so, please give details of the
Court cases.
3) Whether any warrant was really issued against me in the period between April, 2003 to
December, 2003 ? If so, the details of such warrant.
4) If the answer to Question No.4 above is in affirmative, then whether my name appeared
on the website of Dubai Police and if so, the details of entries on the website. (I do not
find my name on the website as on date. Hence this question.)
If there are any prescribed fees for the above enquiries, please let me know.
I rest assure that I shall forthwith make payment through internet by using my master card. If you
require payment either in cash or by cheque, I will instruct one of the persons in Dubai (who are
close to me) to personally come to your office and deliver cash or cheque.
However, please treat this matter as urgent and reply me by return email.
Sir, I would like you to appreciate that I am fighting only for justice. It is necessary for me to
wash off the stigma on my character and I need your assistance for this noble cause. It is
necessary for me to reopen the case as early as possible by proving my bonafide to the Court. For
this purpose I am seeking this lawful assistance from you with all sincerity.
98
Apart from replying to the above queries, if you could issue me a certificate that during the
period from April, 2003 to December, 2003 my name did not appear on the website of Dubai
Police and no warrant was pending or issued against me, it will be of great help to me in filing
truthful and correct affidavit before the Court of Law to explore the conspiracy against me by my
opponent alongwith my lawyer.
Thanking you,
Yours truly,
DAYAL H.MANSUKHANI
Encl.: a/a.
SANJIV G. PUNALEKAR
Advocate, High Court
315, Birya House, 265, Perin Nariman Street , Bazar Gate, Fort,
Mumbai 400 001.( India ). Mobile no. 0091-9820095814
Date : 3rd October, 2006
To,
Abu-Anil Gen.Trdg.Co.
Pearl Apartment, Flat No.702,
Swami Samarth Nagar,
Mumbai 400 058.
Attn.: Mr. VASHU Awtaney.
Sirs,
We are concerned for our client Mr. Dayal H.Mansukhani presently residing at Flat No.19,
Malkani Mahal, Self-Help Co-operative Housing Society, 261, Dr.Annie Besant Road, Worli,
Mumbai 400 030 (India) on whose behalf we serve upon you addressees as follows:1. Our client had been in Dubai for 25 years as Non-Resident Indian (NRI) businessman and
he had dealings with you addressees during the period between 1999 to 2001 during
which you addressees too were NRIs and conducting business in Dubai .
99
2. You addressees were conducting your business in the name and style of Anil Trading
Company wherein you addressees were partners. You approached our client to extend
finance to you for your business requirements. In view of your business relationship with
our client and his concerns, our client extended credit to you on various occasions.
3. To secure the repayment of monies due by you to our client, you issued him a number of
cheques, a list of which is as follows:-
26)
27)
28)
29)
30)
31)
Abu-Anil
Gen.Trdg.Co.
762457
762459
762461
762466
762497
762460
15.09.2000
15.10.2000
15.12.2000
05.09.2000
12.09.2000
15.11.2000
1,00,000/1,00,000/1,00,000/50,000/50,000/1,00,000/-
Middle East Bank

Middle East Bank
Middle East Bank
Middle East Bank
Middle East Bank
Middle East Bank
4. As and when you our client desired to negotiate these cheques, you were requesting him
to bear with you for sometime due to your temporary liquidity problems and in fact you
had assured that the cheques would be duly honoured, though with some delay.
5. However, when you ceased to communicate with our client or to inform him specific
programme for repayment of his dues, there was anxiety and panic on the part of our
client. In the absence of any communication, he had no option but he had to present these
cheques. However with his surprise your banker returned all the cheques presented from
time to time on the grounds of Account Closed. Our client received intimation from
respective drawee banks with regard to dishonour of cheques.
6. When our client tried to personally contact you addressees, he was informed that you
have left Dubai and in fact there were similar complaints from a number of local
businessmen against you. As such our client had no option but to lodge a complaint with
the Dubai Police authorities. As you had already left Dubai , the Dubai Police authorities
were unable to trace you out or personally pursue complaint to logical end.
7. In this background, the criminal proceedings could not further be pursued against you.
Recently, when our client returned to India and commenced his enquiries about your
100
present whereabouts, he was informed that from Dubai , you had shifted to some other
country and now you have again returned to India . He gathered information that you
addresses are now residing in India and you are conducting business in India .
8. In this background, it is imperative that you repay and clear the dues that you addressees
owe to our client. We hereby call upon you to make payment of Dhs.________
amounting to INR____________ with further interest of Dhs._________ amounting to
INR _____________, within 7 days from the date of receipt of this Notice.
9. If you fail and neglect to honour this payment as above, our client shall have to initiate
criminal proceedings against you in India . Needless to add, that as you are an Indian
citizen and as the time gap in initiating proceedings against you is solely on account of
your disappearance from Dubai and lack of your whereabouts.
10. Should you fail to make payment within 7 days, we shall proceed with the criminal
complaint of charges of cheating, misrepresentation and indulging in conspiracy to
defraud our clients. This would be without prejudice to our rights to initiate civil
proceedings against you for recovery of the amount due. We shall also be concerned to
inform the facts of the present proceedings to the Passport authorities with a request to
impound your passport and we shall send intimations to various Immigration authorities
in various countries (including Dubai ) so that other hapless victims, if any, would be in a
position to protect their interest.
Yours faithfully,
Sanjiv G.Punalekar
Advocate
SANJIV G. PUNALEKAR
315, Birya House, 265, Perin Nariman Street, Bazar Gate, Fort,
101
To,
ANIL TRADING CO. LLC
Mumbai 400 058.
Attn.: Mr. Gordhan Awtaney.
Sirs,
Mumbai 400 030 (India) on whose behalf we serve upon you addressees as follows:-
1. Our client had been in Dubai for 25 years as Non-Resident Indian (NRI) businessman and
which you addressees too were NRIs and conducting business in Dubai.
Sr.No.
Cheque No.
Date
Amount
Drawn on
(in Dirhams)
4.
1)
613251
15.07.2000
125,000/-
Middle East Bank
2)
613250
30.06.2000
125,000/-
Middle East Bank
As and when you our client desired to negotiate these cheques, you were requesting him to
bear with you for sometime due to your temporary liquidity problems and in fact you had
assured that the cheques would be duly honoured, though with some delay.
102
the Dubai Police authorities. As you had already left Dubai, the Dubai Police authorities
present whereabouts, he was informed that from Dubai, you had shifted to some other
country and now you have again returned to India. He gathered information that you
addresses are now residing in India and you are conducting business in India.
criminal proceedings against you in India. Needless to add, that as you are an Indian
103
in various countries (including Dubai) so that other hapless victims, if any, would be in a
Yours faithfully,
Sanjiv G.Punalekar
Advocate
SANJIV G. PUNALEKAR
To,
GOVERDHAN DAS AWTANEY
Mumbai 400 058.
Attn.: Mr. Gordhan Awtaney.
Sirs,
which you addressees too were NRIs and conducting business in Dubai.
104
Sr.No.
Cheque No.
Date
Amount
Drawn on
(in Dirhams)
1)
652110
23.09.2000
50,000/-
Middle East Bank
2)
652109
09.12.2000
50,000/-
Middle East Bank
3)
652108
25.11.2000
50,000/-
Middle East Bank
4)
652107
10.11.2000
50,000/-
Middle East Bank
5)
652106
18.11.2000
50,000/-
Middle East Bank
6)
652105
28.10.2000
50,000/-
Middle East Bank
7)
652104
02.10.2000
50,000/-
Middle East Bank
8)
652103
11.09.2000
50,000/-
Middle East Bank
105
the Dubai Police authorities. As you had already left Dubai, the Dubai Police authorities
present whereabouts, he was informed that from Dubai, you had shifted to some other
country and now you have again returned to India. He gathered information that you
addresses are now residing in India and you are conducting business in India.
criminal proceedings against you in India. Needless to add, that as you are an Indian
Yours faithfully,
106
Sanjiv G.Punalekar
Advocate
SANJIV G. PUNALEKAR
Mumbai 400 001.(India). Phone 022-22634828
Mobile no. 0091-9820095814
To,
1. Mr. Keeshood Bujraj Jabeldas
2. Vasumati Bhojraj Adwani
Address: Flat No. 406, Vasu Bhavan
Khar (W), 11th Road, Mumbai-400 052
Mobile9819082188, R 56945257
Sir/Madam
107
he had dealings with you addressees during the period between 1998-2000 during which
you addressees too were conducting business in Dubai.
22. You approached our client to extend finance to you for your business requirements. In
view of your business relationship with our client and his concerns, our client extended
credit to you on various occasions.
cheques drawn on your accounts in United Arab Emirates.
client. In the absence of any communication, he had no option but to present the cheques
through his bank. To his shock and surprise, the cheques were returned unpaid by your
bankers. When our client tried to contact you, you had left Dubai and your whereabouts
were not known. Our client is still holding a large number of cheques which were
dishonoured in Dubai and the amount due and payable to our client on account of these
cheques plus interest due thereon works out to UAE Dirhams 3,90,000/-.
26. Our client was unable to initiate proceedings due to your absence from Dubai. In
November 2005 when our client returned to India, he discovered that both of you are well
settled in Mumbai. He contacted you somewhere during the month of February 2006 and
108
sought recovery of the abovesaid amount. He informed you that if you failed to repay his
dues of UAE Dirhams 3,90,000/- he would have to initiate civil and criminal proceedings
against you. He also pointed out that as you had left UAE after creating huge debt to a
number of third parties in UAE, he would take up the matter with those parties and coordinate a concerted legal action against you. At this juncture you assured our client that
you had no intention to defraud him and that you were in genuine difficulties. You
thereafter handed over to our client the following cheques:
Mr.Keeshood Bujraj Jabeldas
Sr.No.
Cheque No.
Date
Amount
Drawn on
(in Dirhams)
1)
000015
13.03.2006
2,10,000/-
AbuDhabiCommercial Bank
2)
000007
13.06.2006
30,000/-
AbuDhabi Commercial Bank
Ms.Vasumati Bhojraj Adwani
Sr.No.
Cheque
No.
Date
1)
000001
13.03.2006
50,000/-
2)
000002
13.06.2006
50,000/-
3)
000003
13.06.2006
50,000/-
27.
Amount
Drawn on
(in Dirhams)
had to re
You requested our clients to withhold any civil or criminal action with particular reference to
any action against the properties owned by you in India and assured our client that the above
cheques would be honoured on due dates.
However, when the due date of the cheque approached and our client contacted you, you
went on seeking further time and requested for postponement in presentment of the cheques.
Our client patiently waited for more than 5 months. However, when the time was running
out and when you started avoiding telephone calls from our client, he finally presented the
109
cheques. To his shock and surprise, all the cheques were dishonoured with the reason
Account Closed
28. It has therefore become clear that you have intentionally defrauded our client and have
merely bought time by issuing the abovesaid cheques though you had no real intention to
repay to our client.
29. Therefore, you are hereby called upon to make payment of Rs. 46,80,000/- (equivalent to
UAE Dirhams 3,90,000/-) within 7 days from the date of receipt of this notiece. If you
fail and neglect to honour this payment as above, our client shall have to initiate criminal
proceedings against you in India.
Yours faithfully,
Sanjiv G.Punalekar
Advocate
110

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DUBAI Notice

5.Kavitha Arjandas Vs- Khaleej Times:157/2000,70/2003,351/2003

Standard Chartered Bank, Legal and Compliance, UK &Europe

User Name: dubai

Plz re-open these Case nos. 1246/99, 557/98 (454/2002 appeal),

Add boselaw@hotmail.com to My Messenger Contacts.

Sat, 06 Sep 2003 12:03:33 +0000

Reply Reply All Forward Delete

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We have checked in the computer and your name is in the

9/12/203 & 26/6/206

First you read notices after you click this website.

Standard Chartered Bank, Legal and Compliance, UK

I shall file fresh civil/criminal cases

internet through www.google.com. He was accompanying me and appearing for me even

Standard Chartered Bank, Legal and Compliance, UK

Legal cases between your concerns and my concerns.

every possible information and document is brought on record

responsibility as to costs and consequences shall be yours.

Bernard Raju's labourers complaint of slavery

DUBAI - Labour supply is a lucrative business for

Ahmed ABDULLA MAHAMMD AL Mulla

3) In so far as my dealings with my local partner were concerned, I had relationship

reputation but would also be in a position to safeguard UAE against disrepute

In this process you will also

I am addressing this communication to you by way of notice regarding legal proceeding

Fri, 14 Jul 2006 13:07:32 +0530

Add Mobile Alert

Add to Address Book

Re: Notice: LAST & FINAL REPLY FROM KK BOSE.

July 14, 2006

(By email: mansukhani48@yahoo.com),

Date: Mon, 10 Jul 2006 03:15:41 -0700 (PDT)

I am serving this notice upon you as final notice which shall be

this incentive per se was sufficient for you to independently

Secondly, if there was need to bring fresh documents on record,

side, documentary evidence as well as interpretation of such

Repudiating the report required that the deficiency in the report

under law. Throughout this period, your intentions were to stop

22) In addition to the above referred negligence, you also

had actually submitted material data or whether your failure to

India, including actions to impound your passport and to attach all

P.S.: For the present I have refrained from sending

Documentary proof that no warrant was issued against me.

1) On which date the Accountant submitted the report to the Court ?

My lawyers email From: "Bose Bose" <boselaw@hotmail.com 27 Mar 2003

Dear Mr. Dayal,

Dear Mr. Bose, 28/3/03

From: "Bose Bose" <boselaw@hotmail.com>

Dear Mr. Dayal,

I am declaring I shall pay you dhs 100,000/ - if you win the

I had sent you an urgent message yesterday to check my name in

Dayal Vs- Besco International 183/2000 511/2003527/2003 3rd September 2003 to

Dayal Mansukhani Vs- SCB (Criminal Case ) 1246/1999

"Bose Bose" <boselaw@hotmail.com>

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Dear Mr. Dayal,

For you to come back to Dubai, no body will

With Best Regards,

"Bose Bose" <boselaw@hotmail.com>

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Dear Mr. Bose