Sir,

MOST RESPECTFULLY SHOWETH:-

1. That the complainant is a bonafide resident of Villa No. 53, Metropolis City, Rudrapur
Udham Singh Nagar, Uttarakhand.
2. That the accused persons are also bonafide residents of Metropolis City, Rudrapur
Udham Singh Nagar, Uttarakhand. Furthermore, the collectively constitute members
of the Metropolis Residents Welfare Association (hereinafter referred to as “MRWA”),
bearing Regn No. 051/08-06-2012 MRWA, Situated at Metropolis City, Rudrapur,
Udham Singh Nagar, Uttarakhand
3. That MRWA has forcefully sold the lottery tickets to poor guards, shopkeepers,
staller, their employees and the residents of Metropolis City. The results of the lottery
have been declared without following due process and illegally drawn the results due
to the earned money of the poor guards, shopkeepers, staller, and their employees.
The residents of Metropolis City have been vanishing and MRWA embezzled the
entire funds collected through the sale of lottery tickets.
4. That these activities by MRWA are causing significant financial harm to unsuspecting
individuals who are coerced into investing their hard-earned money into the lottery.
Such actions not only violate the law but also exploit innocent people and significant
financial loss of the innocent person. MRWA has floated the said lottery scheme to
dumb the hard-earned money of the residents and financial embezzlement of the
amount received from innocent residents.
5. That the Dy. Registrar has recommended the cancellation of the Registration of the
MRWA, but MRWA is not stopping to cheat the residents to cheat the residents of
Metropolis City.
6. That MRWA has been conducting activities that are in direct violation of Section 3 of
The Prize Chits and Money Circulation Schemes (Banning) Act, 1978. This Act
expressly prohibits chit-fund schemes of any nature and money circulation schemes
where money is promised to investors as the complainant diligently filed an FIR on
1.11.23, outlining the unlawful sale of lottery tickets orchestrated by the MRWA.
7. That this operation has led to the exploitation and deception of approximately 25,000
individuals, in clear violation of the Prize Chits and Money Circulation Schemes
(Banning) Act, 1978, the Lotteries (Regulation) Act, 1998, and the Lotteries
(Regulation) Rules, 2010.
 8. That, regrettably, the local police station and the Superintendent of Police have
displayed a disconcerting lack of action on the filed FIR, despite its grave
implications. This inaction goes against the very essence of their duty to investigate
and maintain law and order.
9. That, the legal foundation for this application is comprehensive:
1. Statutory Violations: MRWA's activities unequivocally violate the Prize Chits and
Money Circulation Schemes (Banning) Act, 1978, the Lotteries (Regulation) Act,
1998, and the Lotteries (Regulation) Rules, 2010, designed to safeguard public
interests.
2. Breach of The Prize Chits and Money Circulation Schemes (Banning) Act, 1978:
Section 3 of this Act expressly prohibits individuals from encouraging, organizing,
or participating in banned schemes, with potential penalties outlined in Section 4.
3. GST Non-Compliance: MRWA has failed to remit the 28% GST on the sale of
lottery tickets, constituting an additional breach under the GST Act.
4. Persistent Unlawful Activities: Despite a recommendation for the cancellation of
MRWA's registration, they persist in fraudulent practices, causing financial harm
to unsuspecting residents.

Prayer:
It is, therefore, most respectfully that this hon’ble court, in its wisdom and discretion, may be
pleased to:
1. Direct the police authorities to initiate a comprehensive investigation into the alleged
fraudulent activities of the Metropolis Residents Welfare Association (MRWA) as
outlined in the filed FIR.
2. Safeguard the rights and interests of the innocent residents of Metropolis City who
have fallen victim to the illicit schemes orchestrated by MRWA.

Complaint through