In the court of metropolitian magistrate Sh.

in the matter of
ravi bhateja

complaintant

v/s
Vishnu Bharty

proposed accused

Saroj bharty
c/o

COMPLAINT UNDER SECTION 200 Cr.P.C. BEHALF OF COMPLAINANT

In The Court of Sh. Chief Metropolitan Magistrates, Delhi

In The Matter of

Ravi Bhateja
Versus

vishnu bharti

Memo of Parties

Ravi Bhateja
S/O sh baldev raj bhateja
r/o 28/45 punjabi bagh
new delhi -110026 .Complainant

F/F New Delhi

Versus

XYZ Defendant

Street No.5 Delhi

u/s 463 ,467,420,474 ,409, 182 read with section 34 ipc and section 499
punishable u/s 500 & u/s 506 crpc.
P.S. New Delhi

COMPLAINT UNDER SECTION 200 Cr.P.C. BEHALF OF COMPLAINANT

Most Respectfully Showeth :

1. That the complainant is residing of the 28/45 punjabi bagh address with
his family .

2. The accused are husband and wife and they are aborigins of the state of
rajasthan where and claim to be members of a decent and dignified family .
But the reality is far away from that .Even a lowest level of criminal would
desist from doing what that these accused have had done .Any person who
gets to know them would infer that accused no 1 and 2 are hard core
criminals and it is only either they by themselves or God knows how many
families they may have destroyed and how much fortune they have
accumulated .
3.It is also submitted that apart from committing offences in their personal
capacity ,the accused no 1 and 2 also have another partner and
accompalice who not only is in hands in glove with the accused no 1 and 2
acts as an facilitator & instigator of heinous offences in that way the blame
for which can be smeared on someone else face for his own material gains. It
is at the behest of adv. rajesh kumar mishra that tweaking ,exploitation ,
harassment of innocent citizens is being done .
4.It is also submitted most respectfully that complaintant doesn't intend to
cause any conflict with either the law or the law enforcement agencies. But
extreme harassment is being done by accused no 1 and 2 in collabration with
an officer of court (advocate ) by making false and fabricated offensive
communications by themselves and blame the complaintant . Patience out
fast and complaintant feels threatened as se and vaxious allegations are
being levied against for quiet a long time.Basically the accused want to bring
the complaintant under the ambit of malicious prosecution and therefore
causing injury by legal terror.

5.The complaintant resides at punjabi bagh west with his small family
consisting of self and father and mother . That the complainant's father owns
a house at 24 vidalaya road kewal park azadpur delhi and along with his son
is running a shop of stationery goods in the name of indu book mart and
stationers on the ground floor and rest of the premises were given on rent .

3. That a person named as vishnu bhartiya approached the complaintant's

father requesting him for inducting him as tenant on first floor of his house
and he produced several identity documents to convince and gave the
impression to the landlord that he is just like a normal couple but the reality

was far uglier than what vishnu bhartiya tried to potray .He also told the
lamdlord about the details of the firm with which he was employed in . The
compplaintant father inducted him as a tenant via registered rent
agreements no.
dated ...............in the office of ........... pitampurafor a
period of 11 months and 24 months respectively duly through registered rent
aggrement The copies of registered rent agreement are annexed herewith as
PW Ex. No. and PE Ex. .The accused produced and showed that voter
identity card as an original document for convincing landlord.After that the
accused no1 himself provided photocpy of that voter id card containing
personal details along with the photograph .
4. The voter id card whose photostate that the accused produced and
tendered as for varification for the police is a forged and fabricated document
.Furthermost the aforesaid forged document is a government identity card
and only a government officer under authority can issue such documents.
5.The serial number of thephotocopy of voter identity card that the accused
handed over to the complaintant father to be deposited along with filled form
of verification actually belongs not to the accused who is a male but to a
women with the name bearing .................. address
PEx. No. .....It is also pernient to mention that vishnu bharti himself filled in
the major portions of the aforesaid that police verification form in his
handwriting and signed it.
6 That the persual of the serial number/registration number , the forged
identification document shows that it belongs to the state rajasthan and
issued by rajsathan electoral office and the accused no 1 and 2 are aborigins
of rajasthan only . In this way the accused ensured that law wouldn't catch
them . This shows that the task of taking over the property was well
concieved and pre-planned in advance in order to grab the property of the
complaintant's father by illegal and unauthorised ways.Therefore the accused
dishonestly and fradulently decieved the complaintant's father and made him
transfer his property.The complaintant and his father suffered irrepairable
loss of property and reputation as the accused cheated them .The original
electoral voter is of vishnu bhartiya is enclosed as exibit no .....
7.That the registered rent agreement was due to expire on ..................... and
an oral communication was made to the accused to start searching for
accomodation elsewhere as the complaintant mother was suffering from
advanced stage of cancer which needed intensive care and it was becoming
difficult for the complaintant and his father to commute daily and take care of
both his business and family as the complaintant is the only child and there is
no one else apart him in the family to take care of both his elderly father and
sick mother .

8.First the oral request was made by the complaintant's father to the
accused so that adequate time may be available to the accused to shift
peacefully and without any kind of obstruction.As soon as the request was
made the accused no 1 and 2 who were by now pretending to be a civilised
next door normal couple family showed their true colours . The accused wife
openly threatened the complaintant that she would disrobe herself and would
implicate him in the false criminal case i.e outraging the modesty and other
charges .Apart from the open threats the accused no 1 and 2 started
instigating the other tenant families who were also living in the same
accomodation and upon their stance started a preplanned chain and
sequence of events to defame and harass so as to grab the property wherein
they were residing as tenants at sufferance . The complaintant and his father
requested them to not to interfare in their peaceful use and enjoyment of
property as their sole livelihood depended on that shop and their entire life
was spent upon building their home wherein they had expected to live the
fag end of their life with their son .

9.The complaintant consulted his counsel and a notice dated ....................

was served on accused no ..................... who by that time were leaving no
stones unturned to grab their property by harassment and intimidation and
virtually every trick was employed by them to take leaverage of their so
exibited normal couple family in disguise for executions of their nefarious
designs to defraud their landlord . As a result of this the complaintant
stopped coming to his shop for preventing any further controversy and to
save his ailing mother and father from this psycological torture and further to
be at a safe distance from the prospect of facing any legal injury that might
happen. The wife of vishnu bhartiya took the leaverage of her gender
knowingly under the sinister guidance of an advocate rajesh kumar mishra.
It is also submitted that such types of property forgery is committed by the
virtue of personal knowledge face these situations on daily basis.
10.That as the accused no. 1 and 2 living in the same building and the
absence of personal visit of landlord's son prevented them from hurling any
direct allegation , the accused no 1 himself fabricated some offensive and
incriminating written anonomyous communication and spread that to the
locality thereby pretending to be a victim of a crime that in real was non
existant.Motive was just to implicate the accused to make him a leaverage
tool upon which they would defame the landlord and his family to grab the
property of complaintant father or to extort money thereby causing unjust
gain to themselves and unjust loss to the complaintant and his family .The

complaint made by the accused to the SHO police station is annexed as PEx.
no
and reading of the plaint in the light of relevant documents
submitted by the accused shows clearly that the information is misconcieved
and missapproperiated and false and vexious contentions were submitted by
the accused .In the complaint the accused states that he is a resident of this
particular lane and locality from the past 10 years but in police varification
form he submits that his previous address was ..............................also in the
civil suit the accused on one hand side is alledging that the landlord and his
son is a gunda element but on the other hand is also submitting that he
wishes to continue with the same landlord in his house .Evidence is annexed
as PEx.
........................Its quiet hilarious that a couple wants
to stick to continue living with an adversary wheras they can take some
other premises on rent somewhere else after all they are paying rent and
and no honest and prudent indivdual would stay with any adversary who
according to them is a bad element .
11.That it would be imparitive to mention that the complaintant father owns
this house right from 1984 till date and thirty years have passed and in the
course of all these 30 years they have earned the respect in the society by
the virtue of their patience and preservance and does not have even an iota
of friction with anyone , anywhere.Suffice to say that when the accused filed
the fervolous complaints to the police no incriminating evidence against the
complaintant came up on record that otherwise would certainly have linked
the petitioner with the crimes/offense alledged. It would be imperetive to
mention here about a notification of delhi police no.
.....................................wherein the guidelines/standard operating procedures
were prescribed for the courier companies to operate .These procedures are
meant for prevention of criminal acts and for providing the proofs against
any offender who might committ offence by taking the services of third
party .
Noody except only a fool would retort to commission of offense as alledged
by the defendant through which he would jeoparadise not only his civil case
but his own life and career by bringing a criminal liability upon oneself . But
the unscrouplous opponents would employ these cheap tricks to bring the
opposite party to his knees and therafter can demand unjustified gains to
materially enrich himself and therefore inoccuring unjust loss to the other .
This conduct of the accused in itself clearly speaks volumes about intentions (
dishonesty ) and that only a professional cheater would have known such
tricks and dares to committ them .Anyone suppporting the endevour of the
accused cannot be absolved of being an aide of the accused and therefore
the plaintiff requests to the lordship to prosecute the accused no are also
attracted here wherein his wife is his active aide 1 and 2 u/s 340 crpc and
should be punished accordingly .

12.That whereas the accused couple by their conduct i.e the offence of
fabricating false identity documents and filing false police complaints have
given rise to presumption which shows that they are adapt at forgery and
missappropriation and it is quiet sad he has cheated innocent and
unsuspecting citizens (like the plaintiff and his family) who in good faith
entrusted their property with the accused only to be stabbed at the back.

13. It is also submitted that on date ..............the complaintant was

summoned by the I/O at adarsh nagar police station and the plaintiff
explained to the officer all the relevant facts and circumstances and as a
proof he also submitted the photocopy of all the documents that were
available with him . He co-operated with the authorities to the maximum and
gave a written statement . The plaintiff was forced to shun his business by
the accused no 1 and 2 and was made to undergo unnecessary
hardship,strain and stress in addition to the suffering he was alerady
enduring as his own mother's life was in danger .

4. That in the early months of june the complaintant was again summoned
to the police and there by the complaintant came to know about another
anonomyous offensive communication that seemed to have appeared once
more again.The complaintant again gave handwriting samples and complied
with all the instructions told to in vertabim and having full faith in the laws
and it's enforcement authories left the matter upto them as they are
competetent enough with respect to their duties and powers.

5. That during civil litigation all false pleas and firvolous contentions were
dismissed by ADJ and the suit of complaintant father was decreed in his
favour on ...................On date ......................the accused made a submission
to vacate by not later than and the submission is PEx no ... in the first
week .After securing the period of 3 months to vacate , desperate and
intensive efforts were made by the accused for the registration of a criminal
case which would have certainly given them leaverage or a bargaining tool .

6.That on 03-11-10 at about 10 p.m. in the night the complaintant father

went to his house after closing his shop and when on the next day He come
to the shop at about 1.30 pm on 04/11/10,the complaintant father noticed
that the looks of the electricity meters and it's containment box are changed
and tempered with seals of the electricity meter of shop that exists within the
gate on the ground floor were broken and immediately the information to the
same was conveyed to the NDPL authorities PEx. . it is imerative to mention
that the two tenant families had already left the house and now only family
of the accused was residing there and therefore committed the offence of
criminal breach of trust .

7. it is submitted by the plaintiff that during the course of civil proceedings

going on between the two in the hearing on date the counsel of accused
unilaterally submitted before the hon'ble court that there is a possiblity of
some kinnd of settlement betweenthe parties in litigation . The submission of
the ld. counsel for the accused is PEx no..................
8.Now again by their conduct it would not be wrong to presume that this kind
of situation was purposefully created by the means of written offensive/
incriminatory documents by accused himself alledging outraging modesty of
womenhood thereafter as the means of using his wife as a tool to gain
sympathy of the officiating authorities and thereby using that sympathy as an
added weight to trick the compplaintant family to be forced to this barter and
ultimately the property and hard earned money of the landlord was intended
to be parted and to cause wrongful benefits to self and unjust loss which
was illegal and unauthorised as it purpose is blackmailing with the intention
of extortion .
9.Thus the accused tried every trick present in his mind's dirty basket . The
BIG QUESTION arises as to what mitigating and incriminating circumstances
are there for which the counsel of accused was proposing to solve/settle
mutually? who created them?the landlord was acting lawfully by the means of
civil process and only a fool wouldinvite a criminal liability by such actions .
The incriminating circumstances were created by the accused no 1 and
supported by accused no 2 therefore the accused has committed an offence
of creating false evidence and using that forged instrument in connivance
with accused no 2 to be used in judicial proceedings therefore their actions
also attract the provisions of section 34 crpc .
10..That the accused being a professional manipulator and an expert at fraud
is disrespectful of even the hon'ble court wherein he even played fraud upon
the court and didn't vacate inspite of his own submissions and an execution
application was directed to be filed by the hon'ble ADJ sh prashant kumar and

as soon asit was applied for the accused in the dead of night at 10:30 pm
called up the complaintant's father to collect the keys or else he would not be
responsible for any theft that might happen .

11.. That even after cessation of the suit and vacation of the possession the
complaintant thought to start again wiith his business with peace and was
working hard but the accused again made the mockery of the system made
a false and fervolous complaint against the complaintant to the police even
after 6 months since he has left this conduct is a deliberate act and an
attempt to harass the complaintant and unleash the power of police to the
injury of the complaintant and his family .A cheat who has guts to forge and
use government documents can very convinently fabricate an evidence to
realise money or property or to defame and cheat by intent , words & action.

12..That time and again during pendency of civil proceedings and even after
the abatement of suit and delivering posession the accused in furtherance of
common intention with accused no 2 are continuing harassing the
complaintant and his family as a whole .The information regarding these acts
of accused were timely communicated to the police and tendered in evidence
before this court as PEx no .
after enduring such annoyance and
damages of property that when plaintiff sees no respite therefore the plaintiff
decided to take the bull by it's horns Thereafter the complaintant started
joining the pieces of the entire chain of sequence of events and made some
investigations by whatever the means he has at his disposal i.e internet etc .

13.The cause of action with respect to this application arose again on when
again on ............. complaintant comes to know from his father that some
offensive communication alledging false and fictitious information and certain
allegations wherein highly objectionable and offensive asperations against
dignity of women were made. Ironically the complaintant was shocked to
learnt that the communication was made in the name of complaintant's
father and he was summoned by the vigilance department of delhi police PEx
no .
at ashok vihar and both the father and mother in compliance
presented themselves in front of the respective investigation officers and
gave an undertaking to them that the so called false complaint made in the
name of baldev raj who is complaintant's father is bogus and no such
communication was made from their side ever against anyone .

14.That since by looking at the previous conduct of accused i.e

disseminating false and fabricated information aided by the fabrication of
forged govt identity documents , conduct of harassment and intemidation ,
conduct in the court of law and conduct by the way of blackmailing to extort
some kind of unjust material gain and that of accused previous attemps to
implicate the complaintant's and his familyon the basis of false and
fabricated evedience and lame and filmsy excuses as to the landlord had
orally promised them and their accent to extending tenacy irrespective of
how much bad and gunda element that the accused alledged against the
complaintant and his father shows that the accused has taken laws for a ride
without any respect for even the judiciary .

15. The cause of action to prefer this complaint arises by the plaintiff as the
plaintiff submits that the very fact that even after about 12 months the
attempts to defame and harass the plaintiff and his family by the accused no
1 and 2 continues unabated and disturbances are being made against the
peaceful existance and survival of the complaintant by the accused .

16. The plaintiff also submits that the accused no 2 maintains different
fabricated profiles in more than one name without following the due process
of law and it can be averred from the police varification form wherein the field
of the name and details of family members which were represented by the
accused no 1in his handwriting clearly stating that his wife name to be
vineeta but in reality she represents herself as with name of Saroj. May be
only the accused and GOD knows how many more names they might have
adopted at different places . PEx. No.......... is exibited as a proof .An indivdual
keeping two identities in official records of the state show the dishonest
intention to cheat .

17.That the accused no 1 and 2 are professional cheaters and just to

acheve their sinister designs and to escape coming in the attention of law
enforcement authorities are representing and showing themselves as a
normal next door couple but behind this representative shroud is a cheat and
fraudester who keep an evil eye on the unsuspecting inhabitants who consent
to provide a shelter over to them in good faith. Therefore the accused are
also guilty of criminal breach of trust punishable u/s 409 IPC wherein they
concieved and executed an attempt to grab the property which was entrusted
over to them for their own use and benefit in good faith but the conduct of
accused was exactly contrary to it.

18.The complaintant submits that therefore in view of the accused past

conduct and circumstancial evidences there remain no doubt towards the
presumption that the incriminating and offending communication was not
made by someone other than the accused himself and therefore the accused
is guilty of offense u/s 463 ,467,420,474 ,409, 182 and along wirh section 34
ipc , and along with offences u/s 499 punishable u/s 500 &506 Crpc.

Prayer :

It is, therefore, most respectfully prayed that the authorities may kindly be
pleased to do the needfull in the light of the facts and circumstances
mentioned above and save him from extreme mental torture which by now
seems to have become eternal.
Further it is prayed that the plaintiff have always practiced morally . ethically
and in good faith and he has never intend to burden already strained
authorities and never ever attempted to involve any person in legal
complications , but here since in this case the complaintant has already
suffered loss of money and reputation by the accused past acts . But now the
complaintant is compelled to file this application to save his parents from any
prejudice.
Thanking You ,

A
Humble Citizen under you ,
RAVI Bhateja