" . " .

"
";:,- . .

IN THE HIGH COURT OF DELHI A T NEW DELHI .

\VP (Crl .) No. _. _·/2023 .
. .
.
.". " .. "

(EXTRA ORDINARY CRL .\VRIT JURISDICTION UNDER ··

ARTICLE 226 OF CONSTITUTION OF INDIA READ WITH
. SECTION 482 OF Cr.P .C)
IN THE MATIER OF:
SMT. SATINDER KAURJUNEJA Petitioner
VERSUS
THE STATE NCT DELHI & Ors. .Respondents . ;.

INDEX

S.No Particulars Page

. No.
r. NOT ICE OF MOTION
l
2. URGENT APPLICATION :?--

3. LIST OF EVENTS AND DATE 3-..(

4. :MEMO OF PARTIES
'7
5. PETITION UNDER ARTICLE 226
8r-J)
CONSTITUTION OF INDIA READ \VITH 482 OF
CRPC WITH SUPPORTING AFFIDAVIT OF
PETITIONER
6. ANNEXURE P-l
COpy OF THE FIR No. 215/2018 UNDER rg--.2-/
SECTION 420,467,468,47 1 & 34 OF IPC PS
JAGATPURI REGD. ON 06/0812018 BY THE
PETTIONER AGAINST THE ACCUSED PERSON
KAMAL ARORA AND HIS WIFE SONIA ARORA

7. ANNEXURE P-2 :2-2--~

-
COpy OF THE ORDER DATED 07.07.2018
PASSED BY Ld. ACCM (SHD)I KKD DELHI IN
CCNo.1319/2018
8. ANNEXURE P-3
COpy OF THE STATUS REPORT 2' -2)

., .
 :' " ' . ', . , .' " " , r:':
,' _'.

, " "
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9. ANNEXURE P-4
COPY OF THE REQUEST LETTER OF THE
TRANSFER OF THE INVESTIGATION MADE BY ~g--~
THE PETITIONER DATED: 09.05 .2023 TO THE
RESPONDENT NO. 1 TO 3

10. VAKALATNAMA 3D
11. PROOF OF SERVICE 3~

NEW DELHI PETITIONER

DATE: 15.05.2023
THROUGH

A.K. TRIPATHI
~
Counsel for the Petitioner
Chamber no. 82 A .K. Sain Block
Supreme Court of India

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IN THE HIGH COURT OF DELHI AT NEW DELHI .' ':;'. :)' . ~.

. - ..
". : • • •• . c
\VP (Crl.) No. 12023
'. ~.

(EXTRA ORDINARY CRL.WRlT JURISDICTION UNDER

ARTICLE 226 OF CONSTITUTION OF INDIA READ WITH
SECTION 482 OF Cr.P.C)

IN THE MATIER OF:

SMT. SATINDER KAUR JUNEJA Petitioner

VERSUS

THE STATE NCT DEll-II & Ors. .Respondents

NOTICE OF MOTION

To
Govt. Standing Counsel (CRL) (R 1-3)
436-37 Lawyers Chamber
Delhi High Court, New Delhi

Sir,
The petitioner has filed the enclosed writ petition (CrL) on 16.05.2023
and the same is likely to be listed on 17.05.2023 or any date, thereafter.
Please take notice accordingly.

NEW DELHI PETITIONER

DATE: 15.05.2023
THROUGH

Counsel for the Petitioner

A.~
Chamber no. 82 A.K. Sain Block
Supreme Court of India
New Delhi-ll0001 >: '.'

.:' .
 2---:-:-

IN THE HIGH COURT OFDELIII AT NE~ DELHI

WP (Crl.) No. ._. _/2023

(EXTRA ORDINARY CRL.WRIT JURISDICTION UNDER
ARTICLE 226 OF CONSTITUTION OF INDIA READ WITH
SECTION 482 OF Cr.P.C)
IN THE MATTER OF:
SMT. SATINDER KAUR JUNEJA Petitioner

VERSUS

THE STATE NCT DELHI & Ors. .Respondents .

URGENT APPLICATION
To,
The Deputy Registrar,
High Court of Delhi,
New Delhi
Sir,
Kindly treat the accompanied writ petition (CrL) as urgent one in
accordance ~ith High Court Rules and Orders and the petitioner seeks ..
interim protection for life and property.
The grounds of urgency are : as prayed for.
New Delhi Petitioner
Date: 16.05.2023 Through /L .
A.K-t:nJip;;;hi .
Counsel for Petitioner
Office at : 82, (A.K Sen Block),
Supreme Court Of India, New Delhi
Email: advocateaktripathi100@gmail.com
Mobile No.: 9810154341
 the Court of : Hon 'blc . District hj (lge~ ,

Karkardoorn a Court, Delhi for Possession ....

tenanted premises 'and Recovery o f Rent from .:
July 2007@ Rs 8500/- . per month till May . ".:.\ ".

2010 and from June 2010@Rs. 20,000 pcr :

month in respect of entire second floor of
property bearing no. 40 I, Gagan ViharDelhi
I 10051 (hereinafter referred to as the "suit
property") against the Accused Person No. 4
and 5 / tenant
JULY 2010 That the Accused / tenant herein has also filed
a Civil Suit bearing no. 2843/2016 (old no.
1461/2010) in the High Court of Delhi for
Specific performance against Petitioner / land
lady / property owner in respect of entire
Second Floor of property bearing no. 401,
Gagan Vihar Delhi 110051 (hereinafter
referred to as the "suit property") on basis of
being self created false, forged and fabricated
Agreement to Sale dated 25.09.2006 without
giving any notice to Petitioner by the
Accused Person and barred by Law of
Limitation and latches of time in suspicious
condition.
06.08.2018 That Petitioner got Registered an FIR 215\2018
under Section 420/467/468/471 IPC against
Accused Person 06.04.2022 That prior to
the passing of the partial Decree dated
06.04.2022 was pleased to pass a Partial
 . .' '. . " ." ' . ' -, ..' .

..Decree ofPossessionofthe·suit property in .

favor of Petitioner.' The Accused-Person. is
hereby directed to handover the Possession of
the suit property to the Petitioner under order
12 Rule 6 R1W 151 .of passed by Shri V.K. -
Jha, ADJ, East KKD, Courts, Delhi IN CS DJ
NO. 1266/2016
28.04.2022 That the Accused Person filed an Appeal
before this Hon'ble Court challenging the
above order dated 28.04.2022. The Appeal
preferred by the Respondent No.4 and 5 was
Dismissed passed byHMJ V. Kameswar Rao.
05.04.2023 That the Trial Court passed Impugned
Judgment Dated 05.04.2023 passed by Shri
Kishor Kumar, ADJ, East KKD, Courts, Delhi
IN CS NO. 1266/2016 thereby dismissed suit
of Petitioner. Another suit of the Accused got
decreed bythe Ld, ADJ KKD court Delhi.
01.05.2023 The Petitioner preferred the Appeals against
its both the Orders before the Hon'ble court of
Delhi Vide RFA no. 349/2023 & RFA
353/2023 and got stayed its implementation
now fix for 19.09.2023.
07.05.2023 The Petitioner sought status of said FIR and 10
concerned filed his status report before Ld. " ." .:~

ACMM KKD Delhi as nothing progress in the .

investigation and sleeping .over the
investigation in the influence of Accused
Person
 .-' :., ,: . ..
. . '." .... ;;

.09.05.2023 The Petitioricr.compellcd toseckthe trnnsfcr '.

of the iiwestigation and made a representation .
tothe respondents to any inve stigating agency ··
through its investigation not below the rank of .
ACP for fair and proper investigation and
proper charge sheet against the accu sed
person for committing fraud and forgery
manufactured its fake unregistered agreement
to sale with the forged signature of the
petition in order to g rab property of yhe
petitioner by hook and by crook

Since nothing progress in the investigation in

the FIR 215/2018 and about 5 years gone and
wasted the accused persons taking advantage
of verge of investigation despite
representation for transferof the Investigation
by the respondents and kept delaying the
investigation and sleeping over in the matter
since last about 5 years hence this writ
petition for necessary fair and proper
investigation and transfer to any investigation
authority and call for investigation report with
direction to monitor the investigation
warranted in the matter
 : : . . . -. . ". .

INTllEHIGH COURT OF))ELHI AT NEW DKLHi . : ..

WI> (Crl.)No. _/2023
.. ,'.
(EXTRA ORDINARY CRL. WRIT JURISDICTION·UNDER
ARTICLE 226 OF CONSTITUTION OF INDIA READ WITH
SECTION 482 OF Cr.P.C)

IN THE MATTER OF:

SMT. SATINDER KAUR JUNEJA Petitioner
VERSUS
THE STATE NeT DELHI & Ors. .Respondents

MEMO OF PARTIES

Smt. Satinder Kaur Juneja

Wlo Sh. Ani! Juneja
Rio 401 (Second Floor),
Gagan Vihal', Delhi-II 0051 Petitioner
Versus
1. The State NCT of Delhi
(Through its the Commissioner of Police,
Police Headquarter, Jai Singh Marg,
New Delhi-II 0001
2. The SHO
PS Jagatpuri
Delhi 110051
3. 10 Ins Jitender Singh
PS Jagatpuri
Delhi 110051

Respondents

New Delhi Petitioner

Date: 16.05.2023 Through s.>:
A.K?r'\i;athi
Counsel for Petitioner
M ~ C)8'/oJSL-j:::'41

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.:. '-'~'- " :-': .:

IN THE HIGH COURT OF DELHI AT NE\VDELHI

.. ":'
WP (Crl.) No. _/2023
(EXTRA ORDINARY CRL.WRIT mRISDICTION UNDER ARTICLE226 or
CONSTITUTION OF INDIA READ \VITH SECTION 482 OF Cr.P.C)

IN THE MATTER OF:

SMT. SATINDERKAURJUNEJA Petitioner

VERSUS

THE STATE NCT DELHI & Ors. .Respondents

WRIT PETIITON (Cd) UNDER ARTICLE 226 OF THE CONSTITUTION

OF INDIA Rf\V SECTION 482 OF Cr.PC FOR ISSUANCE OF WRIT OF
MANDAMUS OR ANY APPROPRIATE WRIT THEREBY DIRECTING
TO THE RESPONDENTS TO PROVIDE PROPER PROTECTION AND
SAFETY TO LIFE AND PROPERTY THE PETITIONER AND FURTHER
DIRECT TO THE RESPONDENTS TO TRANSFER THE
INVESTIGATION TO ANY INVESTAGATING AGENCY THROUGH 10
NOT BELOW THE RANK OF ACP FOR FAIR AND PROPER
INVESTIGATION FROM WITHDRAWING THE INVESTIGATION
FROM 10 RESPONDENT NO.3 AND CALL FORITS INVESTIGATION
PROGRESS REPORT AND MONITOR THE INVESTIGATION AND
PROCEED THE MATEER ACCORDANCE TO THE LAW ARRISING
OUT FIR NO. 215/2018 UNDR SECTION 420, 467, 468,471 & 34 OF IPC PS
JGATPURI BY ALLYING THE WRIT PETITION OF THE PETITIONER

TO
. THE HON'BLE CHIEF mSTICE

.,
" . . ",
 AND HIS COMPANION JUDGES
OF DELHI HIGH COURT
NE\VDELHI

l\10ST RESPECTFULLY SUBMITS:

1. That the petitioner is law abide peaceful citizen residing at aforesaid address
at Delhi and also enjoying her fundamental right enshrined Constitution of
India.
2. That the Respondents come in purview of the state under article 12 of the
Constitution of India and duty bound to protect the life and property of the
petitioner guaranteed under Constitution of India.
3. That the Petitioner Letout her Flat bearing no. 401, second floor, Gagan
Vihar Delhi(herein as Suit Property) initially to the husband of Accused
Smt. Sonia Aroraon Rent @85001 per Month vide Rent Agreement Dated
01.08 .2005 thereafter Another Rent Agreement Dated 08.10.2005
executed on Rent to the Accused Sonia Arora.
4. That on 23.06.2010 the Petitioner served a Legal Demand Notice upon
Accused Person calling upon vacation of Tenanted Premises and Arrear of
Rents etc. and not compliance suit for Possession, Arrear of Rents etc forced
to filed.
5. That on in the Month of July 2010 the Petitioner herein has filed a Civil Suit
bearing no. 1266/2016 (old no. 91/2010) in the Court of Hon'ble District
Judge, Karkardooma Court, Delhi for Possession tenanted premises and
Recovery of Rent from July 2007@ Rs 85001- per month till May 2010 and
from June 2010@Rs. 20,000 per month in respect of entire second floor of
property bearing no. 401, Gagan Vihar Delhi 110051 (hereinafter referred to
as the "suit property") against the Accused Person No.4 and 5 1 tenant
',; ' . ,' .: , ' •.•••: . .:» ", ,; ' , , '.::' . ~
:.', '

· : ..

6; Thnt in the Month in Jl II", Y 20 I0 tho ACCIIHt:d 1 I tl'Hlllll)l~l'oltJ IWIl nillo Hied n ..
Civil Suit benring no. 2H/IJ!201(i (old /10. 'tl61/201O) III til e Iliglt Court or
Delhi 1'01' Specific pcrfornumce IIglliIlilt Pctlllou cr 1 lund Illdy 1 property ·
owner in respect 01' entire Second Floor or property hClIring 110. 40 I, Ollgll/l
Vihar Delhi 110051 (herelnuflcr referred 10 WI the hUlli! properly") Oil baHiu
of being self created false, forged und lubricatod Agnlcrncllt 10 Sale dated
25.09.2006 without giving nny notice to Petitioner by the Accused Person
and barred by Law of Llmluuion IIl1d IlIlchl.:1l of'timc ln nuspicious condition.
7. That on 06.0S.2018 the Petitioner got Rcglstcred lin I,'m 21 5\20IS under
Section 420/467/46S/47 I IPC ugulnst Accused l'crson.
8. That prior to the passing of the purtin] Decree duted O().04.2022 wag pleased
to pass a Partial Decree or Possession of the suit property in Javor of'
Petitioner. The Accused Person is hereby directed to handovcr the
Possession or the suit property to the Petitioner under order 12 Rule 6 R/W
151 of passed by Shri V.K. Jha, AD./, BaHt KKD, Courts, Delhi IN CS 1)J
NO. 1266/2016
9. That on 28.04.2022 the Accused Person filed an Appeal before this Hon'blc
Court challenging the above order dated 2~L04.2022. The Appeal preferred
by the Respondent No. 4 and 5 was Dismissed passed by HMJ V.
Kamcswar Rae,
10.That on 05.04.2023 the Trial Court passed Impugned Judgment Dated
05.04.2023 passed by Shri Kishor Kumar, AD./, Easl KKD, Courts, Delhi IN
CS NO. )266/2016 thereby dismissed suit of Petitioner. Another suit of the
Accused got decreed by the Ld, AD.I KKD court Delhi.
11.That on 01.05.2023 the Petitioner preferred the Appeals against its both
the Orders before the Hon'blc court of Delhi Vide RFA no. 349/2023 & .
RFA 353/2023 and got stayed its implementation now fix 101' 19.09.2023.
 . -', ' ;; ".
. ". ';.' ,'-

12.That on ' 07.05.2023 the Petitioner sought status .of said FIR ,and . 10
';'
~.: .

concerned filed his status report before Ld. ACMM K.KD Delhi as nothing .
progress in the investigation and sleeping over the investigation in the
influence of Accused Person
13.That on 09.05.2023 the Petitioner compelled to seek the transfer of the
investigation and made a representation to the respondents to any
investigating agency through its investigation not below the rank of ACP for
fair and proper investigation and proper charge sheet against the accused
person for committing fraud and forgery manufactured its fake unregistered
agreement to sale with the forged signature of the petition in order to grab
property of the petitioner by hook and by crook.
14.Since nothing progress in the investigation in the FIR 215/2018 and about 5
years gone and wasted the accused persons taking advantage of verge of
investigation despite representation for transfer of the Investigation by the
respondents and kept delaying the investigation and sleeping over in the
matter since last about 5 years hence this writ petition for necessary fair and
proper investigation and transfer to any investigation authority and call for
investigation report with direction to monitor the investigation warranted In

the matter.
15.Feeling aggrieved from in action of the Respondents despite complaints for
Transfer of the investigation to any investigating agency other than pocal
Police station Jagatpuri and ensure its fair and proper investigation since
kept pending about last 5 years as such nothing progress disturbing legal
criminal system which made out for cognizable offences in various
provisions of law and flouting the settled preposition of law and in violation
of the Supreme Court guidelines, the petitioner seeking indulgence to this
Hon'ble Court with the present writ petition amongst the other grounds
";.:-

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';:-
 .. .. . . .: . . ' , . ' . . : •.

inter-alia in as much for protection for life and property of the petitioner
guaranteed under Constitution of India:

GROUNDS:

1- Because, Respondents completely failed to discharge their duty / obligation

and flouting / not following up the certain guidelines formulated by the larger
constitutional bench of Hon'ble Supreme Court of India. Hence, necessary
directions required to be passed forthwith with mandate to follow up the settle
preposition of the law and ensure the guidelines laid down by the Apex Court.

II- Because, the Respondents are duty bound to provide proper protection and

safety to the petitioner for their life and property despite written complaints

lodged by the petitioner dated 09.05.2023 and personal visits but all effort got

futile and no action is yet taken so far in the cognizable offences made out and

nothing progress· in the investigation till date despite best effort made by the

petitioner against the accused person all efforts got futile even otherwise FIR

has been registered in compliance of Order dated 07.07.2018 passed by Ld.

ACCM KKD Court dated 06.08.2018 vide FIR no. 215/2018 V/S

420/467/468/471/34 IPCPS Jagatpuri, Delhi against at accused person who

committed Fraud and forgery Manufactured a fake Agreement to Sale dated

25.09.2016 with forge signature of petitioner on their own in order to grab the

valuable Property its worth value more than 2 core by hook and by crook as

. '. '
." ~: ',' '> ."" + .. r '

such nothing happened at any point of time lind nothin g transaction took place .: .:: ..:::r.

single penny.

" ~':.

III- Because, that the Respondents completely failed to take any cognizance in the
cognizable offences made out in the complaint prima facie and nothing
investigation being carry out, hence appropriate direction is required forthwith.

IV- Because nothing progress in the investigation in the said FIR as the 10 concern

Respondent no. 3 is sleeping over in the influence of the Accused Person

which self explanatory from the Records having good nexus each other and

God knows the IOlRespondcnt no. 3 not responding properly and also not

cooperating the Petitioner and kept delaying the investigation about 5 years

and time elapsed unnecessary hence Petitioner compelled to seek its transfer

for fair and proper investigation despite reorientation dated 09.05.2023 to the

various authority concern and Autority concern keep mum in the influence of

the Accused Person as such immediate necessary direction for Transfer of the

investigation to any investigating Authority other than Police station Jagatpuri

for fair investigation and the book the Accused Person hence proceed the

matter accordance with the Law against them.

'. ~ '.
:: "
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16.That the no such similar writ petition IS filed or pending either

beforeSupreme Court of India or in this Hon' ble court for the same relief.

PRAYER:
In view of the above facts and circumstances of the case it is therefore

kindly this Hon'ble court may be pleased to:

I. Direct to the Respondents to Provide Proper Protection and Safety to

Life and Property to the Petitioner at the hands of the Accused Person;

II. Direct the Respondents to transfer the investigation to any investigating

agency under supervision not the below of the rank of ACP from

withdrawing the investigation from 10 Inspector litender Singh!

Respondent no. 3 PS lagatpuri Delhi arising out the FIR No. 215/2018

under section 420/467/468/471 and 34 of IPC with direction to the

Respondents to investigate the matter and file its charge sheet forthwith

and proceed the matter in accordance with the law against the Accused

Person and their associates accused persons involved in the matter By

Allying the Writ Petition of the Petitioner,

. ~ .:'
 '-."':: .

"-. .> .:

- .,.

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Any other relief/ direction which this Hon'blc Court .may deem fit and-proper also , ··
be passed in the favour of the pctltionerngainst the respondent as fact of
circumstances of the case to meet ends of'justice

-,. .

~ t~I .e1k ;. ~
"

NEW DELHI ~ lpETITIONER

DATE: 15.05.2023 THROUGH

A.K.~·
Counsel for the Petitioner
Chamber no. 82 A.K. Sain Block
Supreme Court of India
New Delhi-II 0001

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IN THE HIGH COURT OF DELHI AT NEW DELHI

WP (Crl.) No. _/2023

IN TH E MAlTER OF:
Smt. Satinder Kaur ....Petitioner
VERSUS

The State NeT Delhi & Ors. . .. .Respondents

AFFIDAVIT

I, Satinde,r Kaur Juneja Wlo Ani! Kumar Juneja aged about 45 Years
Rio 401 II Floor, Gagan Vihar Delhi 92, do hereby solemnly affirm and
declare as under:-

I. That 1 am the Petitioner in the above noted case and am fully

conversant with the facts and circumstances of the case, hence
competent to swear this affidavit.

k - - -........ hat the contents of accompanying Petition rejoinder affidavit has been
'~\ssi o ne
,., CJa~ . t d by my counsel under my instructions, contents of the same have
~ ~ \ ~ .
Of?) ..;v"-
~ rf~(;&!b ad ,over and explained to me in my vernacular, I have understood
~ ~ ~.~ ~~' ~ (~ .....
~ ~\r:f':<&~h~'': e, I state the same to be true and correct, the same be read as
-- 0 ' ~~ R;' 0'V <b
m ~:p-.f;;)~y~ and parcel of this affidavit as the same are not being repeated
(f) fJ.~ ' ~ <§i
~ cf ~~ ~rein for the sake of brevity.
It- Km\\a~~()C'i

3. That versions stated in the least of event and date of the petition based
on personal Knowledge and information based on material on record
1 I ' .

and its ground paras based on legal information received believed to be

true and correct there to.

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4. ~Thut the ~~~~cxurc are true copies of their respective originals. . .', .

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\\\--\ '\?wfication:
l'>\' .:>
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....' Verified at New Delhi on this ljlhday of August, 2022, that the contents
of my above affidavit are true and correct to the best of my knowledge and
belief and nothing has been concealed there from.

. .: .. '

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FIRST INFORMATION REPORT

(Undor Socllon 1~4 Cr.P.C.)

yo",il1 ~I : :lllll FIR No(ll.tL.n-.ll.):021S Dole (It=rttO):06l08l2018

2. !lotUll·lllil!·"",): 50C1 101I1Ill"IIII'1II

• II' C wno

3. Occurronco 01Orronco ( ~I'l\IIIl/il Ilc.n) :

(0) Duy(f't-l) : Dole Frorn(!01 '1111) : 0010 To(~ O<li):
TlnlO Purlod (lTl11loTtlfU): Timo From ({"nnlf: Tlmo To (lTl11l filii) :
(blillformalion r"colvod nf P.S.(:Jl'TT .r~ 1 lj.tr." tTT/1 ~) : DOIO(R'" l11): 0610012010 Tlmo (lTl11l): 13:50 hrs
(c)Gonorol Diary Roloronc. (If;lrFIIIIUl «<,;,1): l!lllry No.(lIl?1fe II .): 023A Tlmo (lTl11l): 13:50 nrs
4. Typo 0' lntonn atlon (l),tr.ll 'liI Q ~!H)'
5. Ptucn 0'
oeeurruneo (tR'UfUIH I:
(0) Dlrocl/on ond Distonco from P.S (:1'·11 il ~fl on, R ~I1I : [JOOI No(z/r.! n.) : 01
(b) Addross!Q,'I) : am liND FLO,)I, GAGIIN \(IHIIR. DELHI·f,1
(clln coso . Outsldo tho limit ol tho Polico Siol/on (Ill?; IIRTlnmi); i!lT{:t ~ ):
Namo 0' p.Slm:lI llH ~III\ : D lstrlct(~r") :
6. Complol.,olll I Informant (t~rrr.l~;'IO'I:f/l~;~llf.'i'I'( ):
(o)N.me('mT): SATINDER I<AUR JUNEJA (VI', O ) SH IINIL JUNEJA
(b)Dole/Yenr of Birth (=r mfOl mIl): Notlonnllty (U!flIfiTl): INDIA
(c)Passport No.(lllwil€ u .) Dolo ollssuo ("11ft'lir.1 til) flIfOl): Place of Issue ("Ollf\ m lHT 'Ill'!):

(d)Occupolion (l"lmml) :
(oIAddrous (trrTl) : ~()1 . GAGAN VIH,\lt (lUI u-s r. EAST. DELHI. IN DIA

7. DOlolis oll<lownISuspocUUnkno ,, " ac cus ed with lull portlculors(oltoch s eparate she et II ne cessory)(;;lTilll{~ 13WlTn ~'Iil
'ii I '1\ filll P '1 1l1~ 11 <lOr~ ):'::.
• KAMAL ARORA

• SONIAARORA (WIO) KAMAL ARORA

8. Rooson lor delay In reporting by the complolnanlllnlormanqfil'lir-rn<1ii'ff1lj,'RlijiOf j;ITf ftri\t ~ it ~ 'Iitf.l ill'1il'{Ur):
NO DELAY
9. Rartlculars ollho prop erties siolen/involved (attach sepa rate shoal II necessary]:
SI.No. (lli.lI .) Prope rty Typo(Doscl'lption) Slotus

. . ... . '

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 . .. .:
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19 --
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OISlnc' EAST OELM YB3r :,:{lI~ FIR ND :II~Ir.

13.Action Taken Since the above infollniltiofl tcveals cornmlsslon or otlenco(n) ute al mantlonnd At 110m1'10. 2:
(;fir mll umfmtl; 'l'f.!; 3Qlhli :.;,,(:>;,11" '"'' .'H al to lin JTQ11l1 a;T-I:m ~thr.t r-r. n .VI :1.';.1 ", 'Urn iIlllll" eI:
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(I) Registered the case t,nd took liP f!lu IIh'C"Sh!Flf1on: OR (111)
(lrilff11J <:of f1I;>TI mn ai'n -llil ib fefllli'l 'lT II'll):
lii)Directed "(Name of the I.O.ll"llil J,frIililft ilil:rm I: M' /I\E~H '( ADAV Ih ll1k (q'':) :
SIISUD·INSP£:CTORI
Nolll .): 16090018 10 tako up Iho Invosllgatlon Ill!) \;Jjil 8111f'1 11m ir T~il i'r. fl:l q r.r~~1 f1:'zI( T('Uf ) OR(711)
(iii)Relused fnvesllgallon due 10("fIiT ~i fi"I-q): OR (m IlTfllll ltllTTl flr;((I 71"1)
(ivlTranslerred to P.S(namo)(l!IT-lI): Dlalrlcl(f....n):
on point of jur lsdicllon (<m a'.lTiU'liTl" 1); llffi1lT tm'Iii1ful)

F.I.R read over to the complalnant/inrormont,odmillod 10 ba corractly racordod and a copy alvan 10 lha complalnant/lnrormant,
Iree 01 cost : (~ I , ~tl'lT'mff 1Il)m::rlir.lrr ~ iJi{ q;rr~ mil, uft l:"f!J1f JlAl al'rt Q"lT mN\ f.r{tmll ~lllllIf Ir;) t} mil) :

R.O.A.c.(afT{.ait~.<fl .) :

14.Slgnaluro I Thumb Impres stnn Signalure or Orl,cor

ollhe Complalnant r Intorrnant:
(fiJ'lillJrlilli1f /lJu.rr<l1<li ih ffiIlm : llll/) tlill'lt'r.J): Narna('TlTl): JAI KUMAR
RD"k (If':) : ASST SIIASSISTANT ::;Ua·INSPECTOHI
No.(d .l: 2BU:?31 16

15.Date and Time of despatcn to the court:

(3lC;lM<T if i1llllT ili\ ~'ll JhT "lfI1'1T):

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TRUE TRANSLATED VERSION 'OF TIlE FIR DATED

06/08/2018 .. . I , .

12. F.I.R. Contents (attach separate sheet, if required) (FIRST

INFORMATION REPORT FACTS): Date :- 09/1/18 To Dear
Commissioner of Police, Police Headquarters, ITO New Delhi-2
Subject :- Kamal Arora by his wife Sonia Arora In connection
with encroachment of my propelty No. 401 Gagan Bihar 2nd
Floor by making fake documents, Mr. Satinder Kaur Juneja wlo
Sh. Ani! Juncja is a resident of rIo 401, lind Floor, Gagan Vihar,
Delhi-51 and presently rIo 2529, East, 13S. T, Appt. I live at 2
RR Brookline, New York - 11235. Mister. I had given my above
mentioned flat (401, lInd Floor) on rent to a person named Kamal
Arora in the year 2005 at the rate of Rs. Rent Agreement in the
name of Sonia Arora (wife) which was made on Kamal Arora
non-judicial stamp paper of Rs 101- and then went to America on
September 26, 2006 at 2.00 am, at the time of leaving it was due
to me for nine months. I had given rent and some money to get
my goods from USA, but I could not come back immediately, so
he told me to return the money if you come. When it came to
know that I am not coming back immediately then it stopped
paying my flat rent to my mother after about 8 months, now on
date - 13/12/17 when I came back to India it is saying Kamal
Arora and wife Sonia Kamal Arora and wife Sonia Arora has also
used it with the intention to mislead the Hon'ble COUlt as well as
to mislead the COUlt by forging and forging my signature on two
ICICI Bank checks (125411 and 125412 dated - 12/06/2006).
Only one of this check is the original of the cash paid check
which is the property of the bank and has been filed in the COUlt. I
do not know how these two checks came to him. I did not give
any such check to him. Sir, this person along with some hooligan
elements has been threatening and harassing my mother and my
daughter and had gone to the police station on 24/7/17 because
the incident took place on 22/7/17 in which my mother And there
has been an 'att empt to kill my daughter, about which my mother
informed the Delhi Police, but I have received information that
no action has been taken due to the tussle with the police of the
area. Finally, my mother got upset and filed a c~se .in
Karkardooma Court, now this person Kamal Arora and hIS WIfe
Sonia Arora and his goons have come to know that I have come
to India. That's why he has put a goon behind me so that he may
go to America out of fear and he may take possession of my flat.
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Sir, he is not ullowing me to enter 111Y flat and has forcibly

captured it by mnking Iuko documents. Finally being upset, I am
sending this complnlnt to IVh·. ji, please take appropriate legal
action ngnlnst tho guilty persons and got 111C my flat and get
justice. I will ulwnys be grntefu l 1:0 sir for this.

Yours faithfully (Sutindcr Knur) Sd/-

401 Gngnn Vihnr Delhi-llOOSl 8130301827
Dnte r- 09.01.18. Place :- Delhi
Copy To :- To The S.HO. Police Station, Jagatpuri Delhi 51
DO PS Jagntpuri, As per the ordered dated 7.7.18 in the matter of
Satinder Kaur Vs Kamal Arora & Ors, CC No. 1319/18 PS
Jagatpuri of.Sh. V.K.Jha Ld ACMM, KKD Court, Kindly register
a case u/s 420/467/468/471/34 IPC on above said complaint of
Snit. Sntinder Kaur and handed over investigation to me.
Sd/-
SllVIllkcsh Yadav PS Jagatpuri.
Proceedings Police filed a case on the complaint of Tahrir in Aj
police station, after getting it registered and computerized, the
original Tahrir was handed over to the sr.
Digur Nnkulnt Bajrie will be Arsal in the service of postal officer
Baln,
Bnklnm ASI/DO.

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9ATINDI11l I(AUIl vll.I<AMAL ArtOrtA &. Arm.

CC Nci.tH9/1H
)IS - .'lH"tpUl'l
07.07.201H nt 4.(101•• 11I.

QIUlUR

Present: Counsel for the complnlunut.

Put up 1'01' order at 4.00p.lll.

ACMM(SIID)/KKU/J)clhi
AT 4.00p.1Il.
Present: None

~. The case of the complninnnt is thut the complainant had

given her flut 110.401, 21111 Floor, Gngun Vihill', Delhi on rent at
Rs.S,OOO/- per month excluding UlC electricity to tho accused no.l
Kamal Arora in the year 2005, A rent agreement was executed
between the complninunt and the accused, Kamal Arora,
subsequently at the request of Kamal Arora a rent deed was
executed between HIe complainnnt and wife of Kamal Arora i.c,
Sonin Arora.

3. It is the case of the complainant that on 26.09.2006, H10

complainant had to leave to US and the accused Kamal Arora had
given advance rent of nine months and some extra amount (which

CC No.131912018, PS- JAGATPURI Pnge 1/4

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SATINDER KAUR vs. KAMAL ARORA & ANR.

has not been specified by the complainant) .and when both the
accused came to know that the complainant would not be returning
after the lapse of 8-9 months, the accused fabricated a false sale
agreement dated 25.09.06 and forged the signature of the
complainant with the intention to grab the tenanted property of the
complainant. The complainant has also averred regarding misuse
of two of the cheques of the complainant pertaining to ICICI Bank.

4. It is further stated by the complainant when the complainant

in the year 2017 returned back from USA, accused informed the
complainant regarding the purchase of the property of the
complainant by the accused. The complainant gave a complaint to
the concerned SHO and to senior officers of the police and when
no action was taken, present application along with complaint uls
200 Cr.P.C was filed.

5. On the application status report was called from the

concerned SHOo It is stated in the status report that during the
enquiry it was revealed that the accused, Kamal Arora has filed a
suit for specific performance on the allegation that after receiving
the advance amount and executing the agreement to sell, the
.complainant failed to execute the sale deed. Accused deposited
Rs.23.5Lakh i.e, balance of the total sale consideration before the

CC No.131912018, PS- JAGATPURI Page 2/4

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SATINDER KAUR vs. KAMAL ARORA &ANR. . .' .'
: -.,; . " '.

has not been specified by the complainant) and when both the .
accused came to know that the complainant would not be returning
after the lapse of 8-9 months, the accused fabricated a false sale
agreement dated 25.09.06 and forged the signature of the
complainant with the intention to grab the tenanted property of the
complainant The complainant has also averred regarding misuse
of two of the cheques of the complainant pertaining to lCICI Bank.

4. It is further stated by the complainant when the complainant

in the year 2017 returned back from USA, accused informed the
complainant regarding the purchase of the property of the
complainant by the accused. The complainant gave a complaint to
the concerned SHO and to senior officers of the police and when
no action was taken, present application along with complaint uls
200 Cr.P.C was filed.

5. On the application status report was called from the

concerned SHOo It is stated in the status report that during the
enquiry it was revealed that the accused, Kamal Arora has filed a
suit for specific performance on the allegation that after receiving
the advance amount and executing the agreement to sell, the
complainant failed to execute the sale deed. Accused deposited
Rs.23.5Lakh i.e. balance of the total sale consideration before the

CC No.131912018, PS- JAGATPURI Page 2/4

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SATINDER KAUR vs. KAMAL ARORA & ANR.

registrar as per order of Hon'ble Delhi High Court.

6. It is also stated in the status report that no case was

registered on the complaint of the complainant as the matter
between the complainant and the accused was already sub-judice
before different courts.

7. I have heard the arguments and perused the record.

8. The bare glance of the signature of the complainant in the

present complaint, on the lease deed dated 01.08.05 and the rent
deed dated 08.10.05 reveal that the alleged signature of the
complainant on agreement for sale dated 25.09.06 is not similar
and at the first instance doubt is raised as to the genuineness of the
agreement for sale allegedly executed by the complainant in favour
of the accused. Merely the fact that any matter is pending in any
court does not preclude the SHO from registering an FIR if the
information discloses a cognizable offence, if the commission of
the alleged offnce has no connection with the trial of the case. In
the present case also alleged offence appears to have been
committed before the commencement of the proceeding in the
concerned court. The reason as given in the status report dated
12.03.18 is not convincing as far as the non-registration of FIR is

CC No.13191201B, PS- JAGATPURI Page 3/4

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INTHE HON'BLE COURT OF SIl. BHARAT AGGARWAL LD. MM,sHD. KKD. ·
, COURT NEW DELI-II.
. .:- ."::
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Cnse FJR NO; 215/2018. Dated 06/08/2018, U/ S 420/467/468/471/34 Ire,
PS .Iagnt Puri, Delhi - .

Subject: Status Report.

I Iori'ble Sir,
"' Most respectfully it is submitted the complainant Ms. Sutindcr Kaur .
); -Juneja \V /0 Sh. Anil .June]a RIO 40 I, 2 nrl Fluor Gagan Vihar Delhi 110051
~ alleged that she gave her Ilat no 401 2 nd Floor Gagan Vihar N. Delhi, to the
alleged persons namely Kamal Arora and Sonia Arora on rent for Rs 8500 per
month in the year 2005. After giving her Oat on rent she left to America in the
intervening night of 25-26/09/2006, and returned to India on 13/12/2017.
During the mean time the alleged refused to pay tile rent to the mother of the
complainant. Later on the complainant get information that the alleged persons
filed an application before Ld Civil Court KKD, alleging that there is an
Agreement to Sell between Sntinder Kaur and Sonia Arora. Thus the property
should be get registered in their name . After it the mother of the complainant
collected the documents from the court and the same were shown to the
complainant. After scrutiny of the documents the complainant found that the
alleged persons prepared n forged Agreement to Sale dated 25/09/2006, by
making her forged signatures, The complainant u150 alleged that the alleged
persons somehow get her two cheques of IClel Bank nee Cheque no 125411 &
125412 and forged her signatures on the said cheques. The complainant
informed that the said original Agreement to Sell and the said original Cheques
were submitted by the alleged persons before Ld Civil Court KKD for their
defense.
After it, a case FIR No. 215/2018 Dated 06/08/2018, VIS
420/467/468/471/34 IrC PS .Jagat Puri, Delhi was registered on the directions
of the Horr'ble Court of Sh Vijay Kr Jha Ld ACMM KKD Court Delhi vide order
dated 07/07/2018 in CC no 1319/2018,
During the course of investigation the complainant was exnrmncd and
later on the following documents were collected from the Hon'ble Court of Sh.
Vijay Kumar Jha, Ld ASJ (East] KKD Court Delhi from civil suit no CS
2843/2016 in the matter of Sonia Area V /S Satinder Kaur,

1. Original Agreement to Sell dated 25/09/2016 on the stamp paper of Rs

50 s tnrnp paper no 0-264672.
2. Original Cheque no 125411 nee no 002901042821 of rcrci Bank.

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The: above: said three original c!!"/"<.ll':}~t.'!i 7.·~e ~ . f!'..-. t::.~ 7"":=-:fP....e cl .
,,.'
in\'cstigation from the AhL71ad of Lr.L Cit!! OJ'!.:;"! i'Y...D. '.'

After it the specimen and Ecm:!:l::C h.~:,~_.:±-~ c;f &..e' co·..::;:l,;G: ·~ .v~
SatindC'r Kaur were collected and ~t to FSL ?..-:.h:.:-": .. ::h C:.~C7~ -zc :3
questioned documents for opinion. T:"l~ ?SL ?..es-...:i: is =-ecr..:.~.;. :~c-.ice ~C:S ;-e:...
to the alleged of the case to C1j7'J:o:1~ L7..~ ~:'x'-::s ans:c ?'5L re:-:;:-' ;- 7"~
representation of alleged has been ~T:;e.d ~ 0.is :~~-c.
The investigation is almost CJJ.llp~ete::! al""-:i ?"::lZl ?~y~ ~;"z.i1 C:r-- E:6:: ~
soon in this Han "ole Court.
Submitted please.

?s.. .J~'F . ?"..=:.

071 C6 i 2::"23

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DATE: 09.05.2023
The Commissioner of Delhi Police
PHQ, Jay Singh Mnrg,
New Delhi 11000I

SUB.JECT: A REQUEST FOR TRANSFER OF TilE

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FRAUD/CHEATING AND FORGERY FIR NO. 215/201H REGISTRED ... ..

ON 06.10.2018 UNDER SECTION 420/4671468/471/34 IPC PS-

.JAGATPURI, DELHI IIOOn TO ANY INVESTIGATING AGENCY
AND ASSIGN TilE INVESTIGATION NOT BELOW TilE RANK OF
ACP FROM 'W IT H DRAW ING ITS INVESTIGATION 10 SI SIIRI
.JITENDER KUMAR PS- .JAGATPURI AND TAKE APPROPRIATE
LEGAL ACTION AGAINST TilE ACCUSED PERSON BY
MONITORING THE INVESTIGATION BEING SENSITIVE AND
SERIOUS IN NATURE AS NOTIIING PROGRESS IN THE
INVESTIGATION DUE TO ILLEGAL GRATIFICATION

Sir,
With due respect , I any how could registered said FIR against my Tenant and
her Husband for committing fraud and forgery with the forge my Signature to
grab the my Property bearing no. 40 I, second Floor Gagan Vihar, Delhi 5 Iby
hook and crook on basis of forged documents of fake agreement to sell dated
25.09.2006 and its CFSL Report detected forgery in the Documents. However,
the said my Tenant namely Snit. Sonia Arora and her Husband namely Sh.
Kamal Arora never paid its Rent having its heavy Arrears of Rents which
comes more than Rs. 35 Laces up till its vacation 31.07.2022 in compliance of
partial decree passed by Hon'blc High Court of Delhi. Needless to mention that
accused obtained a favorable order from the KKD Court Delhi and duly
Challenged separately RFA No. 349/2023 and RFA no. 353/2023and got stayed
its implementation in both the Appeal by the Han'ble High Court of Delhi now
matter is seized on 01.05.2023 and 02.05.2023 respectively.

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Since nothing progress in the said FIR no. 215/20 18 reglstered on

06./0.20/8 PS 'Jugarpurl as such forgery detected in e FSL Report despite
.forgery and fraud comrniucd by the sa id Accu sed Person, the concern fO and
Accused Person having good nexus each other apparent face on record bein g
saved from the clutches of Law and charge sheet has not yet been filed before
the Ld. MM KKD Court Delhi . Hence the matter is required to be tran sferred itt; .
investigation forthwith to any investigating Auth ority and the Sup ervi sion not
below the Rank of ACP on withdrawal of the investigati on from .10 Sf Sh.
Jitender Kumar PS Jagatpuri and conduct a dep artm ental enquiry and legal
action against the erred official responsible

. -'.:,.~
It is requested your good self kindly look into the matter being serio us in
nature and take, appropriate legal action warranted in the matter against th e
culprit and call for its investigation progress report by ensuring my proper
protection and safety at their hands

Thanking you
Copy to : SATI NDER KA URJ UNEJA
The SHO Wlo Sh. ANIL JUNEJA
nd
PS Jagatpuri Rio 40 I, 2 Floor Gagan Vihar
Delhi 51
Mob No. :9289046787
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IN WITNESS WHERE OF IIWe do hereunto set my/our hand to
understood by me/us on this .. ./ . day of M~/25
e-pr.es~e contents of which have been

Accepted subject to the terms of the fees. ~} ~

AdV~

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 17:151919 a · ..;::::.
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PROOF OF SERVICE 31
••
•

Advance notice to
Respondents state inthe
matter Writ petition criminal
of satinder Kaur juneja vs The
State NCT of Delhi and ors
Add label

Advocate Rajendra Trip... 17:13 ~ ••

•
to dhcprosecutiondelhipolice A

From Advocate Rajendra Tripathi •

rajendra.tripath iadv@gmail.com
To dhcprosecutiondelhipolice@gmail.com
Date 16 May 202 3, 17:13
See security details

Kindly t ake Advance noti ce to Respond ent s st ate

int he matter of said matt er and find attached
A K Trlpath i
Counse l for Pet iti oner
Mo 9810154341

1m Writ pet iti...t inder .pdf .. 1.1

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