IN THE HIGH COURT AT DELHI

CRIMINAL

1
U/S

WRIT

PETITION

NO.

/2016

ORIGINAL JURISDICTION
UNDER Article 226 of the Constitution of India
And
32 of constitution of India.

IN THE MATTER of non Registration of FIR on complaint

DD 44B/2015 submitted by the plaintiff to Delhi Police as well as to the office of
Chief Electoral Officer , Delhi.(Annexe A is a copy of complaint filed ).
PS : Adarsh Nagar

BETWEEN

R AVI B H ATE J A
VERSUS

. . . . PETITIONER

Commissioner of Delhi Police

}..... .Respondent no. 1

CEO(Election) Delhi

} .Respondent no. 2

Vishnu Kr. Bhartia

}. ...Respondent no. 3

Vineeta Bhartia

Rajesh Kumar Misra

} .Respondent no. 4
}.....Respondent no. 5

INDEX OF PAPERS
S.No

P A R T I C U L A R S C.F PAGE NO1a

NOTE :ALL Attachments in .pdf format

SYNOPSIS

1b

OPENING SHEET 2Memo of Parties 3

Application for condonation of the delay

AFFIDAVIT

5Police verification form reciept:05/01/2010 submitted to PS

6Search Results of National Voter Portal

ADARSH NAGAR

for

S.No : RJ/04/027/0362617

Complaint to PS Adarsh Nagar

DD No. ..........Dated ............... 8a

8bComplaint to Delhi Police Dated

Commissioner

DD no.Acknowledgment received for 8a9a

9bComplaint made to CEO Delhi dated REPLY RECIEVED FOR 9a dated

R E J O I N D E R

TO 8a

10bR E J O I N D E R T O 8 b 12
Replication to 10 b13RTI Application DATED: 14 Reply Received to RTI dated 15a
10a

15b

RTI 1 st APPEAL

RTI 2nd APPEAL16Notice to DELHI POLICE COMMISSIONER 17aCopy of

Notification no.Copy of office order no.18ECI manual19Voter elector id card details
of respondent no.2 original
.

IN THE HIGH COURT AT DELHI

CRIMINAL

WRIT

PETITION

NO.

/2016

ORIGINAL JURISDICTION

UNDER Article 226 of the Constitution of India

U/S

And
32 of constitution of India.

PS : Adarsh Nagar
IN THE MATTER OF :

RAVI

VERSUS

BHATEJA

1Commissioner of Delhi Police

2CEO(Election) Delhi

PLAINTIFF
} ..Respondent NO.1

..Respondent NO.2

3VISHNU Kr. BHARTIA

} ..Respondent NO 3

4VINEETA BHARTIA

}.. Respondent No.4

5RAJESH Kr. MISHRA

}.. Respondent N0. 5

MEMO OF PARTIES

R AVI B H ATE J A
S/O BALDEV RAJ
R/O 28/45 PUNJABI BAGH
NEW DELHI-110026
VERSUS

}.......................PLAINTIFF

1. Respected Commissioner of Delhi Police

Police Headquarters ,5th Floor

MSO building IP Estate, Delhi.

}......Respondent no 1

2. Chief Elector Officer Delhi

Old St.Stephens college Building

Kashmiri Gate,Delhi -6
..........Respondent no 2
3.

Vishnu kumar bhartiya

C-31/2,GROUP INDUSTRIAL AREA
WAZIRPUR,DELHI-52.

4.

...........Respondent no 3

Vineeta bhartiya
W/O Respondent No 1.

Rajesh kumar mishra

R/O.26,F.F,VIDALAYA ROAD
KEWALPARK AZADPUR DELHI-33

....Respondent no 4

5.

.......Respondent no 5

APPLICANT

DATED:
DELHI:

RAVI BHATEJA
28/45PUNJABI BAGH
NEW DELHI-110026.
THROUGH : PARTY IN PERSON

IN THE HIGH COURT AT DELHI

UNDER Article 226 of constitution of india

(CRIMINAL WRIT PETITION NO.

OF 2016)

PS: Adarsh Nagar

IN THE MATTER OF :

RAVI
VERSUS

BHATEJA

PLAINTIFF

11. Commissioner of Delhi Police

} Respondent NO.1

22. CEO(Election) Delhi

} Respondent NO.2

33. VISHNU Kr. BHARTIA

44 VINEETA BHARTIA
MISHRA

}...Respondent NO 3
} .Respondent No.4. 5RAJESH

Kr.

}.... Respondent N0. 5

Application under article 226 of constitution of india :

Plaintiff respectfully petitions for suitable directions in the nature of a writ of
mandamus or likewise to the various concerned offices of THE GOVT. OF INDIA
in relation to the facts and circumstances of this present case/petition :1To the officer in charge of theAdarsh Nagar police station to hold thorough

investigation of DD.44B/2015 with respect to the commission of cognizable

offences and take all such necessary steps that may be necessary for ensuring a
proper investigation including monitoring the same with reference to the nature
and circumstances of the plaint.
1For issuing directions to the Election Commission to conduct careful scrutiny of
the Electoral Rolls and take appropriate actions against individuals found possessing
multiple voter election cards / forged cards.
1In the nature of a

mandamus to the Delhi Police to conduct careful scrutiny of

Tenants along with their their identity proofs residing in the areas of their respective
jurisdiction to minimize the activities of unlawful elements at an earlier stage.

2
4.

For issuing appropriate directions to Delhi Police for the strict enforcement
of the provisions of Notification No. U-11036/(I)/ UTL , dated09/09/2010 by Ministry of Home Affairs, Govt. of India, New Delhi by
virtue of Section 144 of the Criminal Procedure Code, 1973(No. 2 of 1974),
so that the free run of private courier agencies be restricted in accordance
with the law so that they can't be used as a tool for facilitating transport of

objectionable / incriminatory articles .

For issuing appropriate directions to Delhi Police for the strict enforcement
of the provisions of STANDING ORDER NO. 411 OF 2012 & also 98
Dated 01/06/1989 issued by the respectable COMMISSIONER OF
DELHI POLICE under Police Act which is otherwise known as an ACT
FOR THE PREVENTION OF OBSCENE LITERATURE AND
HARAMFUL PUBLICATIONS as defined under S e c t i o n s 2 9 2 a n d
293 IPC .

6.

Directions to Delhi Police to check if the aforesaid information mentioned &

registered as DD.44B/2015 Dated 10/11/2015 & Reference no 20995 dated
09/11/2015 , attracts any lawful action to be taken in respect of the
notifications mentioned above in point 4 & 5 and do the needfull .

To Delhi Police to fulfill it's commitment as per it's own decleration with
reference to monetary rewards for authentic information if given about
cognizable offenses for the prevention of crimes & catching offenders.

8.

To the CEO Delhi and CEO Rajasthan to do appropriate action in

accordance with the law against respondent no 1 & 2 for misrepresentation
and forgery if found any.

9.

To quash the proceedings of cc: 45/1/2014 & 12/1/2014 ,presently under

process at rohini court,Delhi so as to prevent the abuse of the process of the
court .

10.Take appropriate action for identification & initiation of disciplinery

proceedings against reluctant & neglegient officials and ensure that such
mistakes won't get repeated in future.
11. Any other order that the HONORABLE LORDSHIP sir may please consider
to be fit and appropriate fulfilling the provisions of justice
according to the facts
and circumstances mentioned and relevant in this
case .
7

GROUNDS FOR RELIEF :1 The plaintiff is constrained to file the present writ petition on the account

of

being aggrieved that despite having given a very specific and precise complaint of

cognizable offence complete with documentary evidences (forged voter elector id

card) to the police proof of which is present in the
,no action is being taken by the respondent

police records from 2010

no.1&2 against respondent no

3&4. It is submitted that respondent no 2&3 are ex-tenants of the petitioner's father
and they harassed and cheated him through forged evidences and documents. Also
the respondents attempted to defraud the plaintiff's father by deliberately forging and
fabricating incriminating evidences by themselves which they meant to be used in a
judicial proceeding to prove themselves as true. In their endevour to cause
harassment,the respondents preferred many complaints against the petitioner and his
family . As such whenever the said false complaint was made against the petitioner
by the respondent no.2 or 3,police authorities acted just like a lightening bolt and
behaved and responded arbitrarily or in violation of rules of natural Justice/Service
Rules or prescribed protocol , as constables posted in Adarsh Nagar physically
approached the house of plaintiff in Punjabi Bagh((outside jurisdiction) and that too
accompanied with one of the acquaintances who work as a partner in the gang of
respondents no 3,4&5.That indivdual belongs to gali no 13,majlis park , adarsh
nagar where respondents no 3 & 4 lived before shifting to the plaintiff's father's
home .The petitioner very respectfully submits that as such negligence of our
respected authorities has not just alone injured him personally , but since the
subject matter pertains to the elements of forgery, fraud & cheating

through

election voter id card(govt. Provided identity document) , therefore it also has the
potential of injuring our national integrity & security particularly in the present
times when the whole world is reeling

under the threat of terrorism.

The

plaintiff is continuing to suffer from such acts leading to a clear violation of his
fundamental right specifically right of liberty and right to earn a respectable
living. Also the actions of respondents poses a serious challenge to the
administration of justice as some indivduals are abusing the legal provisions of
our laws.Ironically, the people entrusted with the responsibilty of enforcement and
supervision of laws failed in detecting forgery of such documents which are
available within the police records for the last 5 years. Even upon being informed by
the petitionery by the virtue of his own efforts about the offences and their

offenders, respected officials are pretending in such a way as if either the subject
matter is false or that the same doesn't pertain to their office.That's why the
petitioner has been constrained to seek the intervention of this honorable court .As
such the sole delinquency/negligence , empathy of our respected authorities is
driving

to

situation

where

the

applicant

fears

or

his

life

and

property.Offenders/adversaries of applicant without any fear of law are becoming

so daring that they are now retorting to haressing & abusing the provisions of
law in broad day light within the full knowledge of our police to incriminate the
plaintiff .When the humanity was bifercated into gender ,GOD never intended to
creat such priorities. Laws are originally meant for safeguarding the interest of an
innocent . But in present times particularly by the virtue of the amandment of
criminal law act, gender is being used as a weapon of choice by some mischevious
overclever indivduals for the reasons of either achieving unjust enrichment or for
fulfilling personal grudges .Further the authorities who have a legal obligation
towards preventon of such illegal acts are watching helplessly.Since the offenders
have realised that police is not checking them or in fact is sympathetic to them by
the excuses/pretences of civil elements involved , then they start doing such things
shamelessly,frequently and that too in the front of the police with impunity.As such
the applicant is himself a victim to such a practice and since 2013 has been giving
numerous representations from time to time to PS Adarsh Nagar, but his such
serious efforts have failed to incite any suitable response from our relevant
authorities.It is very respectfully and humbly submitted that the plaintiff had endured
all this because he realizes this fact that the cofficient of ego of our govt. Officials
>1 and as such the applicant's any reasoning with them would certainly be going to
leave a bitter taste in their mouth .Therefore till the time when such attacks were
directed towards him alone on paper , he kept quiet.But now since the incriminating
documents are being sent in the name of his father therefore the applicant can no
longer ignore/bear them, as it has now become amatter involving family honor &
pride ,hence this petition .Moroever it is submitted that this subject matter involving
this particular petition prejudices not just only an indivdual (applicant), but
deception of such nature can be used at whims and fancies, to unleash political

unrest or legal terror or anything like that against anyone with whom any differences
of opinion exists. Therefore application or execution of such a trick without any
reasonable cause will definately lead to a clear violation of the provisions of charter
3 of INDIAN CONSTITUTION which otherwise are known as The
FUNDAMENTAL RIGHTS. Therefore this petition prays for kind consideration
and appropriate adjucation by our HONORABLE LORDSHIP here .
Most respectfully showeth the plaintiff begs to submit as:
1That

the complainant is a resident of 28/45 , Punjabi

Bagh (west), Delhi -

110026 with his family .

1The complainants father and mother are retired government servants and they have
earned high esteem and respect in the society.
2

3That the complainants father owns a house at 24, Vidalaya Road , Kewal

Park,

Azadpur , Delhi-33. Both of them were running a small 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 .
4The accused no 1 and 2 are members of a gang of thugs and cheats which they

have formed amongselves and along with some of their acquaintances .Mo rover
it is also submitted that the accused no 1 and 2 are husband and wife as far as the
social status is concerned but there is a lot more than what that meets the eye.
Their matrimonial relationship is just only a viel/shroud by the virtue of which
they get entry into the society and thereafter the accused no 1 and 2 identify some
varnueable people and accused no 2 takes advantage of her gender to falsely
implicate anyone whom the accused no 1 2 and 3 find conservative and shy and
that who can be blackmailed by threats and acts of humiliation/ridicule by
lowering their dignity through public shame.
5

6It is submitted that accused no 3 is a practicing lawyer and for the last 2-3 years

living as a tenant in the very next building on the first floor of the house owned
by complainants father. The present address of accused no 3 is 26,first
floor,Vidalaya Road ,Kewal Park, Azadpur ,Delhi-33 .The accused no 3 is also an
acquaintance, aide ,abettor and facilitator of offenses committed by the accused
no 1 and 2 .
1It is submitted that the accused no 1 and 2 had cheated complainants father by
taking his house on rent through forged government identity documents(election
voter id card) and cheated him with an intention to defraud him of either his
property and/or to get any pecuniary gains in whatever unfair and unjust manner.
Thereafter when the tenure of tenancy neared expiry, the accused no 1 , 2 and 3 in
furtherance of their common intentions conspired among themselves,leveled and
alleged false accusations on the complainant by fabricating obscene communication
which they meant to be used in judicial proceedings to bring legal injury upon
complainant and his family .
1Earlier the accused no 1 and 2 used to visit the shop of the complainant when
he started the business of stationery and books for small children .The accused no
2 is a house wife and she used to roam on thestreet . Around 2010 accused no 2
started frequenting the street and shop more often and she used her cleverness to
impress upon the complainant's aged father and mother.Unaware of their real
conspiracy the complainant never suspected their intentions and thus failed to
understand that in fact she was doing a recce e. This was their modulus operandi
to identify and target unsuspecting citizens.
1One

day when the complainant and his father were at shop,the accused no.1

approached the complainants father requesting him for inducting him as tenant on
first floor of his house .He produced several identity documents to convince
complainants father and gave the impression that he is just like a normal couple
family .He also told the landlord about

the details of the firm with which he was

employed in . The complainant father inducted him as a tenant via registered rent

agreement /certificate

No.IN-DL025077290513891 dated 16/02/2010 & IN-

DL04422730180392J dated 4/01/2011 in the office of Sub- registrar,

Pitampura ,Delhi for a period of 11 months and 24 months respectively .The
copies of registered rent agreement are annexed herewith as PW Ex. No.II and PE
Ex III .For this purpose the accused no 1 produced and showed his election voter
card as an original document for convincing landlord .After that the accused no.1
himself provided photocopy of that voter id card to be submitted along with the
police verification form which the landlord did . Even the police verification form
was filled in the handwriting of accused no 1 .The receipt of the submitted police
verification form bearing the seal of PS Adarsh Nagar is Exibit no P

Ex.IV

Later the complainant has come to know that aforesaid voter

Election id is

actually a genuine/working document allotted to a lady but has

been

forged

mischievously forged using some computer/digital software.

1It is submitted that accused no 3 had taken up the residence in the same manner
in the neighborhood nearly at the same time when the accused no 1 and 2 joined
the locality.Mo rover the conduct of accused no 3 leaves no doubt that the accused
no 1 , 2 & 3 are accomplices and they know about each other for quiet a long
time .
1Near the expiry of duration of lease the accused no 1 and 2 not just only refused
to vacate even after being served with a legal notice one month in advance but
also started harassing the landlord and his family. This conspiracy was put into
action as as the accused no.1 approached the complainants father for inducting
him as a tenant on basis of forged documents but the most disgusting events
started occurring as soon as the tenancy period approached expiry and
subsequently a formal legal notice to vacate was served on to the accused no 1 on
date 24/12/2012 Pex.No.V .The accused no 2 by the virtue of her gender she
promoted enmity among the two other resident tenant families by mixing with
them at the back of plaintiff and systematically turned them against landlord & his
other family members .Thereafter the other tenant families stopped paying rent

and bills(electricity and water)and started quarreling with him , therefore legal
proceedings had to be initiated by the complainants father against them thereby
suffering severe financial loss & stress and strain. The complainant and his family
was made to bear all this without any fault . Accused no 3 also worked in tendum with accused no 1 and 2 and in spite of being a neighbor and and an officer of
court misrepresented facts and promoted falsehood and worked as a aide and a
facilitator/abettor of the crimes committed by accused no 1 and 2 . The profession
of accused no 3 is just only a shroud behind which an bad and defunct member of
society resides whose conduct is unbecoming of his profession. In-spite of
knowing in real-time that the complainant and his family members are peaceful
citizens all the accused made the statements both in vernacular and written,in
police, public and court in-spite of knowing that they are false ,derogatory and
injurious to virtually anyone against whom the same would be if alleged. Also in
the complaint the date mentioned is which is two months prior to the date at
which it is submitted of DD No. of PS Adarsh Nagar . So a well conspired plan
was executed by accused persons.
1Since that day the applicant was forced to stop from coming to his own shop
and was further prevented from attending to his normal course of business

to

make him suffer financial loss and moral injury. After filing

civil suit for

eviction and second suit for restraining the nefarious acts of

accused

the complainants father opened up shop for the fear of being

dispossessed

no.1

from the property/third party .

1Since the absence of personal visit of landlords son prevented them from hurling
any direct allegation , the gang of accused themselves fabricated some offensive
anonymous communication and spread that to the locality thereby bringing their
dishonest intentions into reality.The underlying motive and intention was just only
to implicate the plaintiff(only child)so as to make him a leverage tool

upon

which they would blackmail the landlord and his family either to grab the

property of complainant father or to extort money or any valuable favor thereby

making themselves rich and cause unjust loss to the complainant and his
family.Pex. is a photocopy of one such application made by the accused no 1
to the SHO police station Adarsh Nagar , Delhi dated /03/2014 .A reading of the
plaint in the light of relevant documents(police verification form) submitted by the
accused no 1 shows clearly that the information given by him was false ,
misconceived and misappropriated .Further more false and vexatious contentions
were submitted by the accused no 1 in that complaint to lawful authorities .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 verification form dated himself had
written that his previous address was C-600, Majlis Park , GaliNo.13 Delhi. Also
in the civil suit the accused on one hand side is alleging 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 . Its quiet hilarious that a couple
wants to stick to continue living with an adversary whereas they can take some
other premises on rent somewhere else after all they are paying rent and no body
can remain amused and contented by paying money to continue to stick with a
person whom he considers as an adversary .This blow hot and blow

cold

statements are also an evidence of deliberate misrepresentation of facts with

dishonest intent.
1 It is submitted that accused no 2 in tandem with accused no 1 and facilitated by
accused no 3

started mischief by damaging the property ,intimidation &

restraining the Complainants father (landlord) and also launched vicious attacks
both in vernacular and physical against him .Whenever the police was called the
accused says that it is the complainants father who started first .Exhibit Pex.No.
Is ......... legal notice to stop doing mischief & notice to vacate .The landlords
complaints against these acts are exhibit no ...................
1The conduct of the accused persons I.e. cooking up false and malicious stories,
disseminating false and fabricated information aided by the fabrication of forged

govt identity documents , conduct of harassment and intimidation , conduct of

disrespect shown to the court of law and conduct by the way of blackmailing to
extort & garner some kind of unjust material gain and contesting the claim of
landlord through lame and flimsy excuses shows that all the accused have taken
law for a ride without any respect for even the judiciary .It is also very humbly
submitted that the acts of the accused persons show that they are seasoned
criminals.
1It is also imperative to mention that during civil litigation which was filed by the
plaintiff father in the court of ADJ(NW-3), Sh. Satish Kumar Rohini Courts ,all
false pleas and frivolous contentions of the accused were dismissed by the
lordship and the suit of complainant father was decreed in his favor on
28/04/2014.On that very date of judgment the accused deliberately remained
absent .In next appearance upon the insistence

of his lordship on date

23/05/2014 , the accused made a submission to vacate the demised premises not
later than 26/08/2014 and the submission is Pex no
1The reason of attempt to implicate the complainant can also be adjudged from the

very fact that after aforesaid submission to the honorable court the accused no 1
and 2 started hectic and desperate and frustrated attempts to bring about a police
action on the complainant. At the instance of accused no 1 and 2 , the
complainant was summoned to the police station on 7th 8th 9th 10th 11th of July
2014.There the accused no 1 and 2 used to say the following lines hum khali to
kar denge magar chitthiyon ka kya hoga.Accused no 2 even threatened police
staff also of extreme action if they don't accede to their demands because she is a
lady . All this happened at the instance of accused no 3 because he being a lawyer
and aware of new provisions of criminal law amendment act 2014, wherein a
conviction can be held on the account of the oral testimony of a lady complaining
of certain acts .The exploitation of the opportunity created because of unfortunate
NIRBHAYA incident also pin points to complicity of accused no.3. Also on day
10/07/2014,

the

accused

no

threatened

to

slap

the

complainant

mother(Sr.CTZN) even in front of SHO of PS adarsh nagar . Having being failed

in their extortion bid and sensing the approaching deadline to vacate the house
which they holding, accused no 1 and 2 tempered and destroyed the seals of
NDPL electricity meter and it's box installed within the gated premises Exbit no
.It is imperative to mention that on 10/07/14 the accused no 2 gave a oral
complaint which was reduced into writing by ASI Sh. Raju Yadav ji. In that
complaint accused no 2 made false & malicious allegations that she was adapt at
throwing at the complainants family but/also a new allegation of tempering of
electricity meters by landlord who was not residing there. After 2-3 days the
complainant father noticed change in the shape of his shop's electricity meter and
it's box .As soon as the landlord realized this he informed NDPL PEx. .The
accused are guilty of criminal breach of trust .It is noteworthy to mention that at
the time of this incident no other person was residing in that house except 1 and 2
as the last remaining tenant family vacated on
1This very conduct of accused no 2 leaves no doubt that it is the accused no 1 and 2
who destroyed property and made circumstantial evidences deliberately so as to
cause legal injury and loss to the landlord who was otherwise neither interested in
extending their tenancy nor submitting to their unlawful demands and threats . It
is also submitted that at that time of this incident apart from accused no 1 & 2 no
third person was residing in the demised premises.
1The intention for extortion can also be inferred from the fact that the accused
didnt vacate as he submitted to the court and instead claimed that he is keen on
compromise Pex.No........Therefore the accused persons knew what that they are
up-to and clearly intend to take benefit of their dishonesty.
1

At the time of

payments of dues also he said that he wants

compromise Therefore he is admitting to being a perpetrator to

gain(compromise) by committing certain acts by himself thereafter
intending to implicate complainant so that some settlement through

barter system can be arrived at .Dishonesty negates all lawful acts and
the dishonesty and evil intentions are evident from the very fact that
the accused no 1 gave fabricated identity documents to take
possession of property from complainants father & later on tried to
implicate his son by himself fabricating some incriminatory evidence
to harass him and/or virtually anyone & everyone who came in their
way lawfully.
It is also submitted that the complainant through his counsel has come to

know that accused no 1 and 2 had also filed against him a criminal complaint case no.
45/1/14 in the court of.hon'ble Sh. kapil kumar MM north west Rohini court Delhi
where accused no 3 is their lawyer

against him first u/s 156 3 and later changed

that to u/s 200 CrPc and submitting that he interested in prosecuting ravi (complainant
here) for non cognizable offenses(compoundable Mo rover the accused has failed to
present even an iota of per-summoning evidence against him in that criminal complaint
.
1

Also the complainant have reasons to believe that these accused have also

made a criminal complaints against SHO PS Adarsh Nagar just to invoke fear in his
heart that if he doesnt cause any injury through his legal powers against the
complainant might be he has to loose his government job also.
1

This shows that the accused no 2 with the aide and encouragement of

accused no 1 and accused no 3 has the audacity to paint a sorry and grieving image
of self on the canvas of imagination aided by the environment of sympathy towards
female gender owing to the frequent media trials

of crimes against women

and all three accused joined hands just only to defraud and harass the authorities
and complainant for some unjust gain. They had deliberately tried to show the
complainant and his family in poor light by perpetrating and planting false evidences
which they intend to be used in judicial proceedings and such acts are being
continued till this date. Through their conduct they have seriously undermined lue

and importance of not only executive & judiciary but also womanhood as a whole.
Moreover it is pertinent to mention that even NIA during the investigation of bomb
blasts and terror activities has admitted and proved that desperate terrorists retort to
keeping forged identities to escape from the scrutiny of law enforcement agencies.
Terrorists have no gender. Therefore also it is a matter which concerns and cause
prejudice not just an individual(applicant) but it is also concerned with national
security .
1

The cause of action arose as on dated 02/03/2015, the accused no 1 has again
mischievously filled a false police complaint against the complainant .Since the
complaint was false, the police took the statement from the complainant and no
action was taken against him .

1The cause of action also arises in October 2015 as the complainant comes to
know about another offending and incriminatory communication made to the police
in the name of his father( Baldev Raj ) al leging falsehood for which his parents
were summoned by vigilance department at Ashok Vihar ,Delhi on date
05/10/2015 . It is pertinent to mention that in this specific communication a
reference was also made about HC Adarsh nagar Sh.balkrishan malik because once
when accused no 2 on dated13/07/2014 restrained complainants father and locked
him inside his shop and locked the way to the toilet which was is in exclusive
possession then made a call at no 100 pur suant to this call it was the HC
Balkrishan malik ji who rescued that senior citizen and admonished accused no.2
.Since that incident the accused no 1 and 2 started fostering jealousy towards HC
Sh. Balkrishan Malik and so as to cause injury to him are

themselves writing

and posting objectionable communications /rumors about him to cause affray.

1That the accused no 1 , 2 & 3 are continuing to harass the applicant and his family
either

in one way or the another by provocation through anonymous

communication and thereby causing affray . Ever since the accused no 1 and 2
had vacated they havent given up on their efforts of causing hindrances and

disturbances in the peaceful enjoyment of the property by the complainant and in

conducting his business, so as to compel his family to sell off their property and
get settled elsewhere . The accused no 3 and his wife always try to provoke the
complainant by making some nuisance or other so that they can augment the
weight of their previous false allegations and this behavior is totally unbecoming
of his profession as an officer of the court .
2
3 It is most respectfully submitted that it is a settled proposition of law that if
anyone uses any forged document which he knows is forged for executing a
transaction then it will be punished in the same manner as if hehas made it
.Therefore it is humbly submitted that a person who has the audacity to prepare
forged government documents having security features like holograms ,then he
can also make false private evidences very easily to defraud and cheat innocent
unsuspecting citizens and accused no 3 who in spite of being aware of the real
situation is portraying something else on reel and that is unbecoming the officer
of the court .
1Mo rover all these offenses were perpetrated by accused no 1 and 2 at the instance
of accused no 3 because only a legal mind is in the know of all these procedures
whereby something incriminatory and tangible is deliberately fabricated and
tendered to police and the blame of which can be smeared on the face of the
opposite party to take an edge. The activities of accused 1 ,2 and 3 are
interconnected so it can be easily derived that they have been knowing each other
even before taking up residences in this particular lane of complainant house .Also it
cannot be denied that the act of posing themselves as a normal family in society is
just only a shroud under which accused persons commit offenses against both the
citizens & the state. It is submitted that such incidents happened only when the
accused no 1 ,2 and 3 took up residence in his lane. Nothing of such thing ever
happened earlier here though the complainant father is owing this property right
from 1978 and virtually each and every third person can vouch for his truthfulness
and peaceful nature.

1On inquiry the complainant comes to know that the voter id card which was shown
in original to the complainant & his father and whose photocopy given by
accused no 1 for police verification at time of taking tenancy duly submitted to
PS Adarsh Nagar on date 26/03/2010 is a forged/false document .The
registration number of the above mentioned voter id card is actually issued in the
name of a women namely ANITA DEVI from the state of district Navalgarh
Rajasthan of which the accused no 1 and 2 are natives/aborigines. This
corroborated by Pex.......(ECI database internet).The correct registered voter id
card of accused no 1 is also in different name/identity. Ex.No.

Voter list Delhi

assembly elections 2015 Page no... .

1 Also accused no 2 managed to get signatures of complainant father on a

application for voter id and there she has misrepresented her name as saroj
whereas in police verification form which was filled by accused 1 in his own
handwriting he gave her name as vineeta. Hence deception played on government
authorities by both the accused no 1& 2 .None but only a habitual cheater would
tender multiple identities to government authorities to escape from the eyes of
law enforcement authorities for achieving their nefarious designs and ulterior
motives. The acts of the accused are synonymous to those of the seasoned
criminals. Even the NIA has proved during the investigations of terror attacks
that terrorists retort to acquire multiple identities to escape from the eyes of law
enforcement agencies for perpetrating heinous crimes like bomb blasts & hawala
activities.
1These acts of accused are abhorrent in any civilized society and as a result of these
acts complainant and his family had to spend numerous sleepless nights and their
respect and reputation in the society has taken an irreversible toll . Mo rover it is
also submitted that the applicant & his family has suffered heavy monetary loss
and also mental stress and agony by the actions of accused. The family which
always keeps distance from the Police was forced to make rounds and rounds of

the Police Station particularly when the mother of petitioner was on heavy
chemotherapy dosage regime which she was administered everyday from AIIMS
for answering such questions which were made just only to harass them .The
petitioner was pained to observe that inspite of being aware with regards to the
knowledge and duties of the Police theaccused were never challenged and by not
stopping

such acts further

the accused felt as if they are above the law

therefore they are harassing the petitioner even 7 months after they vacated and
the petitioner just never wanted to see their faces let alone interacting with
them .The accused are guilty with their intent and actions which are totally
unethical,immoral & unlawful and moreover such acts are prejudicial not just to
one individual(complainant) but to the whole society.
1It is submitted that the complainant has already given his complaint to the PS
Adarsh Nagar dated (Copy enclosed as Pex.No. Also an E-mail of the same was
communicated to the respected commissioner of delhi police on date ...copy
enclosed Exibit No. ..........
1Also the same matter was communicated to the office of CEO Delhi Pex.No. No
reply was received initially and after reminder , a reply to the same was received
on date ...... Pex.No. Which was non satisfactory so a rejoinder to the same was
sent on ..Pex.No. (copy enclosed) and from that day on wards the complainant is
yet to see/hear from the CEO Delhi office or from Delhi Police. When the petitioner
saw no remedy is coming , he presented himself to the district court for submitting
an application in this regard u/s 156 3 , and when he asked the the reader in a
hushed tone to allow him submission of this complaint he was straightaway told to
leave the room immediately.As the petitioner feels threatened day by day regarding
his life and property more so after seeing the present affairs of our respected
executive and lower judicial system I. E . getting no support from anyone , also
because of the empathy of responsible authorities, being conservatively introvert
in nature ,as the family imbibed the thinking of staying away from police & courts ,
therefore the applicant has no other remedy but to seek intervention of HIS Honble

Lordship so as to get justice .Mo rover also the applicant feels that the Honorable
High Court would understand the worry of the applicant as the incidents and
circumstances that unfortunately he was subjected to can adversarial prejudice not
just him alone but can injure a large section of our society .

1PRAYER:
2

3It is, therefore, most respectfully prayed that Honorable court may kindly be
pleased to award the above mentioned requests in the form of writ/directions to the
respective authorities so that such kind of unlawful acts can be curbed in peoples
interests.
1

Any other order that lordship may please consider fit and appropriate in

this case .
APPLICANT
RAVI BHATEJA
Dated:
DELHI:

4.
5.
1

6).

6
7
8
8.

9.

11.
12.
13.
14.

14
16 .

16

17.

1
2
3

20.
21.
22.
23.
24
25.
26.
27.
28
29.

------------------------

IN THE HIGH COURT AT DELHI

WP.NO........../2015
PS:Adarsh Nagar
IN THE MATTER OF :
R AVI B H ATE J A
VERSUS

} . . . . petitioner

Commissioner of Delhi Police

CEO(Election) Delhi

Vishnu Kr. Bhartia

Vineeta Bhartia

Rajesh Kumar Misra

} respondent no. 1
} respondent no. 2

respondent no.3
}

respondent no. 4

} respondent no. 5
AFFIDAVIATE

1.1

I , Ravi Bhateja S/O Baldev Raj age about 38yrs R/O.28/45 Punjabi

,New Delhi-110026, do hereby solemnly affirm

and state as under:-

Bagh

1.2
1.

That I am the applicant/complainant in the above matter , aware of

and competent to depose the present affidavit.

1.12. I have drafted the plaint by myself taking references from whatever

resources/information that are accessible to me. The petitioner

the facts

legal

has tried his level

best to relate his complaint in accordance with the law and if case any error has crept
in it,the applicant offers serious apologies
innermost debts of his

to the Honorable Lordship from the

heart and undertakes to rectify em in future.

1.2
3.

That I have read the accompanying application and the same have
been understood by me.

4.

That the contents of accompanying application and documents

with are true to my knowledge.

5.

That the contents of accompanying application may be read as a part

affidavit.

also

attached along

of

this

APPLICANT
RAVI BHATEJA
VERIFICATION :Verified that the contents of affidavit from no. 1 to 5 are true to my knowledge
and nothing material has been concealed therefrom.

Verified at Delhi
DATE:24/12/2015.

APPLICANT

RAVI BHATEJA