Complainant M/s Atul auto and tractors

Through prop Atul V shah

Resi of plot no R 3/8, duplex no 6
Srinagar colony, Addl MIDC,
Satara 415004
9850750899
To,

Manager
Sainik Sahkari Bank ltd.,
Satara

Sub: Sainik Sahkari Bank ltd., has presented two cheques of Dena Bank
ltd., having its Sr number 37382 and 37383 on dated 13/03/2016 to Dena
Bank satara received for clearing from the bearer of this two cheque such
were presented by Sainik Sahkari bank ltd., satara for clearing before
Dena Bank Ltd., satara while identifying bearer as Jeetendra Jadhav in
some Jai Hind chicken shop for Rs 1,00,000/- (one lakh each ) such
cheques never issued to bearer of this two cheque

Dear Banker,

Hence prop Atul shah hereinafter will be called as for sake of brevity The
Complainant who showeth its written complaint as follows:

1) That the Complainant is an individual and is a consistent consumer

of the Saini Bank ltd., The Sainik Sahkari Bank Ltd., is a banking company
incorporated under the society act and having its registered office at
Powai naka satara. The Bank is Opposite Party is carrying on banking
business within the meaning of Banking Regulation Act, 1949,

2) That the Complainant is maintaining a current Bank Account

bearing No 485 and several loan account with effect from year 2000
account opening day,
3) That this Complainant has never issued cheque bearing no. 37381
to 37390 of Dena Bank Ltd., to barer of the cheque,

4) That these Complainant got one notice in name of Atul

Vijaychandra Shah on dated 21/11/2018 from Jeetendra Jaganath Jadhav
and Govind Sambhaji Bhosale stating two cheques were returned by Atul
Vijaychandra Shah from its account of Dena bank stating account is closed
or insufficient balance in current account number for Rs 1,00,000/- each
bearing serial number of cheques 37382 and 37383 hence complainant
was surprised by notice,

5) As the said cheques which were stolen from the complainant

address on 2012 itself for that complaint is filed before satara city police
station by gahal register number 60/2012 a/w two more fir for robbery
and theft,

6) Hence as soon as notice was served immediately a complaint was

lodged before satara city police station that lost robbed cheques are used
by Jeetendra J Jadhav, Govind Sambhaji Bhosale, such came in knowledge
by service of notice that a robbed cheque No 37382 and 37383 Never
drawn in favour of Shri Jeetendra J Jadhav has been debited from the
current account by Dena bank as you have identified before Dena Bank.
Further even came in knowledge they were forged with some other
signature as signee on cheques.

7) As the said cheque was not issued by these Complainant, he

approached the Branch Manager of Dena Bank Ltd., on 10/12/2018 and
asked the details of the said cheque by placing a an application, such as
refused to receive by hand hence by registered a/d it served on Dena
bank who had denied to accept the complaint letter,
8) That the then Branch Manager of the Dena bank was showed the
said cheque by the Complainant and after seeing the said cheque, the
Complainant informed the Branch Manager that the said cheque is forged
half name of bearer is their such is not signed by this complainant and has
not been issued by the Complainant.

9) The said cheques have also not been issued by this Complainant,
from the cheque book issued to him by the Dena bank. For the presented
cheque, it is found that the signature of the drawer of the said cheque
does not tally with the signature of the Complainant,

10) Therefore the officers of the Dena bank has not verified the
signature of cheques carefully because Sainik Bank has presented and
identified it before Dena Bank, Sainik Bank should have come to know for
signature sample availed from me while opening my current account with
you on 2000, hence Sainik bank had to inform police about such
manipulated cheques presented before Sainik and Dena Bank from
clearance along with about the forgery of the cheque,

11) Hence Complainant on personal visit had requested the Sainik

bank to file a complaint before satara city police for forgery of such singed
cheque presented by Jeetendra Jadhav and Sainik Bank who has identified
Jeetendra Jadhav for the credit the amount of Rs. 1, 00,000/- to Sainik
Bank account, such has been unauthorized way illegally debited in form of
account closed from complainant account,

12) That Jeetendra Jadhav and Govind Sambhaji Bhosale on base of

such forged cheque has filed a civil suit, before satara civil court by RCS
555/2018, and prayed to get decreed,
13) Such suit summons was served to Atul Vijaychandra Shah ,
thereafter on knowing that this complainant is Atul Vinaychandra Shah,
suit was amended and to this complainant name, was asked to answer
the suit, such is pending before civil court satara,

14) Therefore all of you as Dena Bank, Sainik Bank and Jeetendra
Jadhav and Govind Bhosale has worked in tandem with each other and
achieved monetary gains; Complainant has sent a notice dated
10/12/2018 to the Opposite Party through his sign duly served on you.

15) Therefore the Complainant has to incurred a heavy loss of Rs.50,

00, 000/- (fifty lakh ) due to negligent and careless act of the Opposite
Party Dena Bank , Sainik Bank, Jeetendra Jadhav and Govind Sambhaji
Bhosale for your monetary gains, such is deficiency in service in terms of
section 2(l)(g), Consumer Protection Act, 1986.

16) That the cause of action has arose to file this complaint on dated
10/12/2018 and cheques were debited by you on 13/03/2016 when the
forged cheque of Rs. 1,00,000/- each was debited illegally to the account
of Complainant,

17) That the Complainant has incurred a loss of Rs. 50, 00,000/- due
to deficiency in service on the part of the Dena Bank and Sainik Bank. The
complainant has to undergo mental torture, harassment and mental
strain due to debit of the said cheque from his account.

18) The Complainant submits his claim as under:

(i) Loss suffered due to unauthorised debit of the cheque from the
complainant's account Rs. 200,000/-

(ii) Compensation for mental torture, harassment and mental torture, etc.
Rs. 10,000

(iii) Expenses incurred in correspondence, postal, legal expenses and

miscellaneous charges Rs.5,000/-

( iv ) Complainant has incurred a loss of Rs. 50, 00,000/- of defamation

due to deficiency in service on the part of the Dena Bank and Sainik Bank.
The complainant has to undergo mental torture, harassment and mental
strain due to debit of the said cheque from his account,

(V) in all total claim comes to a) 50,00,000/- + 2,00,000/- + Rs 10000/- + Rs

5000/- = Rs 52,15,000/= ( fifty two lakhs fifteen thousand only) to jointly
and severally liable to pay.

19) That this complainant wants to request before that Sainik Bank,
please file criminal complaint before satara city police crime on Jeetendra
J Jadhav Govind Sambhaji Bhosale. Make me witness to it.

20) This complaint has filed complaint before Director General of

Police and others who as directed to register the crime on therein alleged
persons and institutions hence if Sainik Bank really wants to abide the rule
of Banking act then file immediately one complaint before satara city
police station as jurisdiction police station immediately without any
further lapse of time immediately as soon as you get this complaint in
your hand. Failing such I will be constrained to take necessary legal
criminal as well as civil action on your institution.

Complainant M/s Atul auto and tractors

Through prop Atul V shah

Resi of plot no R 3/8, duplex no 6

Srinagar colony, Addl MIDC,

Satara 415004

9850750899

Enclosed copy of evidences