IN THE COURT OF LD.

ACMM, SAKET COURT,

NEW DELHI

IN THE MATTER OF: -

Mr. Chiraguddin Qureshi

R/o 318-A, Chirag Delhi.
New Delhi …complainant

Versus

1. Rais Ahmed
2. Sameer
3. Soaib
All R/o P-1, First Floor
Sujan Singh Park, Khan Market
New Delhi ….Accused(s)

U/s 420/468/471 IPC

P.S. Malviya Nagar

CRIMINAL COMPLAINT UNDER SECTION 156(3) AND

SECTION 200 OF CR.P.C. AGAINST THE ABOVE NAMED
ACCUSED PERSONS

MOST RESPECTFULLY SHOWETH:-

1. That the complainant is a law abiding

citizen of India and is living at above

mentioned address.

2. That the complainant was built a four

multistory building at the address E-12/1,

Hauz Rani, Malviya Nagar, New Delhi.

3. That the complainant was sold a basement and

ground floor with common parking measuring

 150 Sq. Yds of the said premises (Multistory

Building) to the accused.

4. That the complainant was cleared all dues

regarding the said premises i.e. Electricity

Bill and House Tax etc. and the parking was

common for all persons, who are living in

the said premises and the persons visit the

complainant again and again and complaint

regarding common parking therefore the

accused harassed mentally and physically to

the complainant.

5. That the accused has encroached the said

common parking and he has been constructed a

bathroom by illegal manner and without any

consent of the persons who are living at the

said premises and the persons are facing

very much problem for parking their

vehicles.

6. That the said accused has not been deposited

properly the electricity bill and he had

been used a electricity without deposit any

electricity bill, thereafter the huge amount

 of electricity bills has been issued in the

name of complainant by the BSES.

7. That the electricity meter was in the name

of the complainant at the time of sale of

the said premises and the accused namely

Rais Ahmed was not approach to change

electricity meter in his own name and the

accused was using the electricity without

payking and clearing previous electricity

dues.

8. That the complainant was informed to the

said accused through a legal notice by his

counsel regarding the pending electricity

dues and unauthorized constructed bathroom

in the above said premises on 22.11.2011.

The copy of the legal notice is annexed

herewith as mark as ANNEXURE A-1.

9. That the complainant came to know about the

huge electricity bill amount when the

complainant was got the electricity bills

total amounting of Rs. 3,12,000/- since

2006 from the day of sold out the said

premises. The copy of the electricity bills

 annexed herewith as ANNEXURE A-2 (Colly).

That the remaining dues of the electricity

bills are from 2006 till today.

10. That the complainant also came to know that

the accused without clearing the due

electricity bills, he installed a new meter

in his own name due to mentioned his wrong

address in his application which was given

to the DESU office. He has done with

malafide intention and concealment of this

fact.

11. That the complainant was approach to the

accused persons on 29.09.2011 and requested

to him regarding the said due bills and

remove the bathroom which is illegally

constructed by the accused person but the

accused person refused the same and gave

extended threats to the complainant and his

son namely Sameer and Soaib also were

extended threats for dire consequences. And

the said accused persons also stated that

(jo tujhey karna hai wo kar lena, tu hamara

kuch bhi nahi bigad payega or police bhi

 hamara kuch nahi bigad sakti). The

complainant was made a complaint to the

police station Malviya Nagar regarding the

said incident on 29.09.2011. The copy of the

complaint annexed herewith and mark as

Annexure A-3.

It is, therefore prayed that the accused may be

summoned tried and punished under the IPC for

the offence U/s 420/467/471/506 /34 IPC, in the

interest of justice.

Applicant

New Delhi through

Dated
Counsel
 IN THE COURT OF LD. ACMM, SAKET COURT,
NEW DELHI

IN THE MATTER OF: -

Mr. Chiraguddin Qureshi …..Complainant

Versus
Vs. Rais Ahmed & Ors ….Accused Persons

P.S. Malviya Nagar

Application under secmton 156(3) Cr.P.C. for

issue direction to the SHO, P.S. Malviya Nagar,
for registration of case and investigation

MOST RESPECTFULLY SHOWETH:-

1. That the applicant has filed a complaint

along with this application before this

Hon’ble Court. The contents of the said

complaint may be treated as part and

parcel of this application and the same

are not repeated here for the sake of

brevity.

2. That the said complaint disclose the

cognizable offence Under Section

420/468/471 IPC against the respondent/

accused person.

3. That the complaint was made to the police

of P.S. Malviya Nagar, New Delhi but till

today the police has not registered the

 case nor taken any action against the

accused person.

4. That the applicant would suffer

irreparable loss if the FIR is not

registered against the accused.

PRAYER:

It is, therefore, prayed that the SHO of the

P.S. Malviya Nagar, New Delhi may kindly be

directed to register the case and investigate

under Section 156(3) Cr.P.C. in the interest

of justice.

Applicant/Complainant

New Delhi
Dated:
Through
{RASHID KHAN]
ADVOCATE
 IN THE COURT OF LD. ACMM, SAKET COURT,
NEW DELHI

IN THE MATTER OF: -

Mr. Chiraguddin Qureshi …..Complainant

Versus
Vs. Rais Ahmed & Ors ….Accused Persons

P.S. Malviya Nagar

AFFIDAVIT

I, Chiraguddin Qureshi S/o Namekhan R/o 318-A,

Chirag Delhi, New Delhi do hereby solemnly

affirm and declare as under:-

1. That I am complainant in the above mentioned

case and am well conversant with the facts

and circumstances of the case so competent

to swear this affidavit.

2. That the contents of the accompanying

complaint as well as application U/s 156(3)

Cr.P.C. has been drafted by my counsel under

my instruction and the contents of the same

has been read over and explained to me in my

vernacular and the contents of the same are

true and correct to the best of my knowledge

and belief and the same have not been

repeated here for the sake of brevity and

 same may be read as part and parcel of this

affidavit.

DEPONENT
VERIFICATION:-

Verified at New Delhi on ____ day of March, 2012

that the contents of the above affidavit are

true and correct to the best of my knowledge and

belief and noting material has been concealed

therefrom.

DEPONENT
 IN THE COURT OF LD. ACMM, SAKET COURT,
NEW DELHI

IN THE MATTER OF: -

Mr. Chiraguddin Qureshi …..Complainant

Versus

Vs. Rais Ahmed & Ors ….Accused Persons

P.S. Malviya Nagar

LIST OF WITNESSES

1. Ahmad S/o Sh. Abdul Hafiz R/o E-12/1, Hauz

Rani, Malviya Nagar, New Delhi.

2. Norjaha Yashmeen /o Samim Akhtar R/o E-

12/1, Hauz Rani, Malviya Nagar, New Delhi.

3. Any other witnesses with the prior

permission of the Hon’ble Court.

Applicant/Complainant

New Delhi
Dated:
Through
{RASHID KHAN]
ADVOCATE
Off: 89, Ist Floor,
Khirki, Opp. Select City Walk (Mall),
Near Distt. Court Saket,
New Delhi-110017
 IN THE COURT OF LD. ACMM, SAKET COURT,
NEW DELHI

IN THE MATTER OF: -

Mr. Chiraguddin Qureshi …..Complainant

Versus
Vs. Rais Ahmed & Ors ….Accused Persons

P.S. Malviya Nagar

INDEX

SI PARTICULAR PAGES C. FEE

NO.
1. Complaint under section
200 Cr.P.C
2. Application U/s 156 (3)
Cr.P.C. alongwith
affidavit
3. The copy of the legal
notice is annexed
herewith as mark as
ANNEXURE A-1.
4. The copy of the
electricity bills
annexed herewith as
ANNEXURE A-2 (Colly).
5. List of Witnesses
6. Vakalatnama

Through
{RASHID KHAN]
New Delhi ADVOCATE
Dated: Off: 89, Ist Floor,
Khirki, Opp. Select City Walk (Mall),
Near Distt. Court Saket,
New Delhi-110017