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From: August 28, 2019

Naresh Kadyan,

Volunteer of Wildlife Crime Control Bureau,

Master Trainer, Animal Welfare Board of India,

VPO Siwana, Tehsil Beri, District Jhajjar.

Jat by birth, cobbler by profession, activist by mission, fighter by spirit and humanitarian by choice.

To,

Chief Wildlife Warden, Haryana at Panchkula.

Notice under section 55 of the Wild Life (Protection) Act, 1972.

Whereas an offence under the Wild Life (Protection) Act, 1972 has been committed / is being
committed by:

1. Smt. Maneka Gandhi, Trustee of People for Animals, 14, Ashoka Road, New Delhi.
2. Ms. Gauri Mulekhi, Trustee of People for Animals, 14, Ashoka Road, New Delhi.
3. Owners of land.

And whereas the brief facts of the offence(s) are enclosed;

Complaint with contents at P-3 to 4.

I hereby give notice of 60 days under section 55 of the Wild Life (Protection) Act, 1972 my intention
to file a complaint the in court of Special Environment Court at Faridabad for violation of section
39 of the Wild Life (Protection) Act, 1972. I am enclosing the following documents as evidence of
proof of the violation of the said Act.

INDEX

1. DWLO constituted Committee to inquire as per WP Act 5

2. Trustee of PFA, bluffed CZA with wrong statement, all monkeys are 6
rehabilitated & no one left, which is not truth
3. Letter dated 16-3-2011 with wrong facts about operation over 20 years, spent 7-8
above 1 Crore, whereas land was purchased on 21-8-1998 vide No. 782 by
Puppy Farm, neither owner of on rent – lease, misguided CZA officials
4. DWLO letter dated 10-7-2019 confirmed 250 Monkeys, No report about their 9
treatment, care, feeding, whereas false information was given to CZA that
monkeys were released by Gauri Mulekhi
5. CZA order dated 2-12-2016 confirming recognition up to 31-10-2013 10
6. CZA letter dated 11-10-2018 about sanction - recovery 11
7. Land proof confirming purchase deed No. 782 on 21-8-1998 by Advocate 12
8. Land owner letter to Gautam Grover, confirming tenancy from 5-2-2001 13
9. Discontinue lease as on 16-10-2004, possession back with 28 monkeys 14
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10. Gautam Grover of PFA Delhi vacated the premises vide letter dated 18-10-2004 15
11. Cancellation of land agreement between Puppy Farm – Gautam Grover 16
12. Possession of Puppy Farm between Gautam Grover – owner of land 17
13. Communication of Ministry o Environment 18-19
14. Orders dated 30-10-2018, deciding appeal by CZA under RTI Act, 2005 20-21
15. Trustee of Maneka Gandi PFA: Legal Notice to Gautam Grover of PFA Delhi 22-23
16. MoU between Maneka Gandhi with CZA disclosing terms & conditions 24-25
17. CZA 57th Meeting of Technical Committee approving Grant in aid to Maneka 26-27

18. Utilization of release amount on 29-4-2011 communicated 6-5-2011, whereas 28

Recognition expired on 31-10-2013, claimed to utilized during 2016-17
19. CZA replied under RTI Act, 2005 29-30
20. Recovery Notice with penalty 31
21. Trustee asked CZA to calculate recovery amount 32
22. Rs. 15,62,747/- recovered with receipt of CZA 33-34
23. CZA Recognition of Krishna Ashram without land lease – rent agreement 35-38
24. Agenda of CZA discussing recovery from Maneka Gandi 39
25. Proceeding of 86th CZA Technical Committee 40-41
26. Ambulance HR05-G-7916 of Anuradha Sawhney, which was purchased with 42
Grant in aid but amount not returned to Animal Welfare Division
27. 1st Appellate order of Ministry of Home Affairs 43
28. Ministry of Home Affairs (FCRA Division) to PFA share their record 44-46

29. Delhi Police transfer complaint to Gurugram Police 47

30. AWBI confirming that double grant in aid to Maneka PFA 48-49
31. Maneka Gandi breach the trust of voters, violating Oath Act adopting 50-52
discrimination, conflict of interest. Election Commission of India slapped ban
Naresh Kadyan
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To, August 6, 2019

1. Chief Wildlife Warden of Haryana, Panchkula.

2. Divisional Wildlife Officer, Gurugram.

Subject: Legal Notice under section 55 of Wildlife Protection Act, 1972 to lodge FIR against Maneka Gandi
with Gauri Mulekhi of People for Animals, 14, Ashoka Road, New Delhi with others for the violation of
section 38 of the Wildlife Protection Act, 1972 read with 120-B, 153, 295, 405, 409, Breach of trust, cheating,
embezzlement, fraud along with terms & conditions of Memorandum of Understanding etc

Greetings, वसुधैव कुटु म्बकम - सवे भवन्तु सुखिनः सवे सन्तु ननरामया - सत्यमेव जयते

Kindly refer to complaint lodged, constituted committee on 19-7-2019 by DWLO read with the false report
submitted before CZA bluffing that all rescued Monkeys rehabilitated as per law, Memorandum of
Understanding executed between Smt. Maneka Gandi with Central Zoo Authority as on 4-4-2011 read with
the CZA F.No. 22-74/2004-CZA (459)(NA) dated 6-5-2011, Gauri Mulekhi letter dated 27-9-2016 along with
the certificate about utilizing Rs. 10,43,200/- during 2016-17 and F.No. 22-74/2004-CZA (459)(AK) 3130/2016
dated 2-12-2016 read with many others as attached here with as ready references as land was purchased on
21-8-1998 vide No. 782 by Puppy Farm.

It is humbly submitted that:

1. On my complaint, a committee was constituted by the DWLO, committee might be submitted their
report, confirming that 250 Monkeys are very much present in the premises of Hanumanvitika, these
wild animals are not rehabilitated as per law, left abandoned in the premises trespassing in other
private land without any Authority – MoU and agreement, even Recognition of CZA withdrawan.
2. Maneka Gandi of the People for Animals, executed Memorandum of Understanding without any
legal custody on the plot 8 kanal of the Puppy Farm, situated at village Sultanpur in Gurgaon,
concealing facts with bad intention, adopting perjury techniques, trespassing the custody of others,
whereas Central Zoo Authority sanctioned and released Rs. 10.00 lacs to People for Animals with
certain terms and conditions, on 29-4-2011, utilizing in 12 months, whereas Maneka Gandi
misguided CZA with wrong information’s that she has spent over crore of rupees on Hanumanvatika
and functioning last 20 years, which was only to cheat, nothing on actual facts as neither she spent
nor she worked for 20 years.
3. Gauri Mulekhi submitted utilization vide her letter dated 27-9-2016, whereas People for Animals was
granted recognition under section 38-H of the Wildlife Protection Act, 1972 up to 31-10-2013 vide
CZA F. No. 22-74/2004-CZA (459)(M)764 dated 12-10-2011, manipulation of any expenditure against
funds disbursed as on 29-4-2011, without any recognition under section 38-H of the Wildlife
Protection Act, 1972, seems to be cheating and fraud, breaching trust along with terms and
conditions of the grant in aid.
It would be pertinent to mention here that keeping in view DWLO report that 250 monkey’s still left
abandoned without rehabilitations after de-recognition, whereas she again misguided CZA with
wrong information that all monkey’s were rehabilitated as per rules, vide letter dated 27-9-2016.
4. As per section 38-H of the Wildlife Protection Act, 1972, without recognition after 31-10-2013, People
for Animals was no legal rights to keep scheduled wild animals in their captivity, which was not legal,
violating of said legal provision, whereas they have No legal right to do so, besides it Krishna Ashram
was also recognized vide letter dated 20-8-2006 without tenancy.
5. The Central Zoo Authority slapped recovery Notice for Rs. 10.00 lacs with Interest on my complaint,
upon the People for Animals of Maneka Gandi, which were recovered as well, confirming that
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utilizations were bogus and public funds were embezzled with criminal conspiracy - concealing facts
before CZA.
6. As per my knowledge Ms. Anuradha Sawhney obtained Rs. 22.50 lacs as grant in aid to construct
shelter for animal is distress along with Ambulance services Rs. 4.00 lacs, both projects of AWD
(Govt. of India) were obtained on said land on which Hanumanvatika situated at village Sultanpur,
whereas Ambulance bearing No. HR05-G-7916 was purchased from Grant in aid from Animal
Welfare Division but same was sold out adopting unlawful method, handed over to Mr. Prem Lohia
on 21-10-2004, amount was not returned to the AWD, embezzlement of public funds.

Hence, legal Notice under section 55 of the Wildlife Protection Act, 1972 served upon you to lodge FIR:

1. Take custody of all abandoned Monkeys without any further delay for treatment, care and
shelter.
2. All abandoned 250 monkey’s immediately be rescues for further rehabilitation restoring five
freedoms of monkey’s along with protecting religious feelings and believes of Hindu
community.
3. XEN, PWD (B&R) be asked to assess the amount incurred on the structure situated at
Hanumanvatika.
4. FIR against Maneka Gandi with Gauri Mulekhi of People for Animals, 14, Ashoka Road,
New Delhi and others may kindly be lodged for the violation of section 38 of the Wildlife
Protection Act, 1972 read with 120-B, 153, 295, 405, 409, Breach of trust, cheating, fraud
along with terms & conditions of Memorandum of Understanding etc.

Yours in Scouting’s,

Naresh Kadyan,

Chief National Commissioner, S&G for Animals & Birds,

C-38, Rose Apartment, sector-14, Prashant Vihar, Rohini, Delhi – 110085.

Copy forwarded for necessary action as without land and verifying the documents, CZA sanctioned –
disbursed funds, Member Secretary of CZA failed to perform adopting corrupt practices, needs action,
Whereas Maneka Gandi misused her power and authority, breaching public trust with Oath Act:

Speaker, Lok Sabha / CZA / WCCB /Central Vigilance Commission / CAG

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