BEFORE THE HON’BLE ADDITIONAL CHIEF METROPOLITAIN

MAGISTRATE AT EGMORE
CRL M P No of 2024
in
FIR No 98 of 2023
(On the file of Inspector of Police, Cyber Crime Police Station, Chennai West,
CCD – 1, Chennai)
Prabhu, M/40 Years,
S/o Ganesan,
No.50, F3, Metro Nagar,
2nd Avenue, Alapakkam,
Chennai-600 116
Tamil Nadu. … Petitioner/Defacto Complainant
-Vs-
1) State Rep by Inspector of Police,
Cyber Crime Police Station,
Chennai West, CCD – 1,
Chennai. (FIR No 98 of 2023) … Respondent/Investigating Agency
2) Punjab National Bank Ltd,
Nizamudin West Branch
Main Road, Nizamudin West,
New Delhi-110013
State of Delhi
IFSC PUNB0016000
Email id:
3) Punjab National Bank Ltd,
Bilaspur Greater Noida Branch,
VPO Bilaspurteh, Kasna Dist,
Gautambudh Nagar- 203 202
State of Uttar Pradesh
IFSC PUNB0022710
Email id:
4) Yes Bank Ltd,
Sanat Nagar Srinagar Branch,
Ground Floor, Enigma Complex, Plot No.1, Housing Colony Rawalpura, Sanat
Nagar, Srinagar- 190 005
State of Jammu & Kashmir
IFSC YESB0000602
Email id: yestouch@yesbank.in
… Respondents 2 to 4/Banks

1
 AFFIDAVIT OF SRIRAM PRABHU

I, Prabhu, S/o Ganesan, Hindu, aged about 40 years, residing at, No.50, F3, Metro

Nagar, 2nd Avenue, Alapakkam, Chennai-600 116 Tamil Nadu, do hereby solemnly

affirm and sincerely states as follows:

1. I am the petitioner herein and de facto complainant in Crime No 130 of 2023

and as such well acquainted with the facts and circumstances of the case.

2. I most respectfully submit that on 12.06.2023, I received a text message

through Whatsapp No: +84587034697 regarding part time job for subscribing

Youtube Channel for which I received Rs 150/-. thereafter I was given some tasks

and I received some amount for completing my work. Later they started to give

investment task. Based on their inducement, I transferred the following sum

periodically. i.e.,

Transaction details:

S. Amount Payee Account Details Account maintained Freezed Amount

No transferred with
1. Rs 50,000/- A/c No 0160002100029203 2nd Respondent Rs 81,228.92/-
Rs 50,000
2. Rs 50,000/- A/c No 1112002100003737 3rd Respondent Rs 2,84,482.30/-

3. Rs 65,000/- A/c No 060278100004182 4th Respondent Rs 1,51,772.01/-

I have credited a sum of Rs 2,85,000/-, to the payee account stated supra, out

of which Rs 5,17,483.23/- (Rupees Five Lakh Seventeen Thousand Four Hundred

and Eighty Three Only) is laying with the respondents 2 to 4 In total I credited a

sum of Rs 2,15,000/. When I asked for repayment, there was no responds from their

2
end. Hence, I lodged complaint before the 1st respondent police and the same was

taken for investigation in Crime No 98 of 2023 for the offences punishable under

Sections 420 of IPC and section 66D of the Information Technology Act, 2008.

Based on my complaint, the 1strespondent/police have taken effective steps and

blocked payee’s accounts maintained with the 2 to 4 respondents bank. With great

pain and sufferings, I would like to submit that out of Rs 2,15,000/- (Rupees Two

Lakh Fifteen Thousand Only) i.e., the amount fraudulently usurped from my

account illegally were freeze by the 2nd respondent bank.

3. I most respectfully submit that this amount of 2,15,000/- (Rupees Two Lakh

Fifteen Thousand Only) which was cheated by the unknown person and freeze by

the 1strespondent police is my hard earned money and all the more significant to me.

Unless the said sum is returned to me, I will suffer huge monetary loss. In the said

circumstances, it is just and necessary that this Hon’ble Court may be pleased to

return a sum of 2,15,000/- (Rupees Two Lakh Fifteen Thousand Only) which was

fraudulently debited from my HDFC Bank, A/c No: 05741610000070,

Kodambakkam Branch, Chennai, IFSC Code- HDFC0000574, in the interest of

justice.

4. I most respectfully submit that I have permanent roots in that locality. I

hereby undertake to abide any conditions imposed by this Hon’ble Court for

returning my hard earned money. I state that I am citizen of India from birth and

living in the above address for the past several years. Unless the above application

3
will be allowed, I will be put to irreparable hardship and loss, on the other hand no

prejudice will caused to the respondent herein.

5. I crave leave of this Hon’ble Court to reserve my rights to file additional

application if remaining sum have been freeze by the 1 st respondent during

investigation.

I therefore pray that this Hon’ble Court may be pleased to direct the

(i) 2nd respondent bank to return a sum of Rs 1,00,000 /- (Rupees One Lakh

Only)

(ii) 3rd respondent bank to return a sum of Rs 50,000/- (Rupees Fifty

Thousand Only)

(iii) 4th respondent bank to return a sum of Rs 65,000/- (Rupees Sixty Five

Thousand Only) which was fraudulently debited from petitioner’s bank

account i.e., HDFC Bank, A/c No: 05741610000070, Kodambakkam

Branch, Chennai, IFSC Code- HDFC0000574, pass such further order

or orders as this Hon’ble court made deem fit and proper in the

circumstances of the case and thus render justice.

Solemnly affirmed at Egmore, Chennai Before me

on this the 21st day of March, 2024
and signed his name in my presence Advocate :: Chennai

4
 BEFORE THE HON’BLE ADDITIONAL CHIEF METROPOLITAIN
MAGISTRATE AT EGMORE
CRL M P No of 2024
in
FIR No 98 of 2023
(On the file of Inspector of Police, Cyber Crime Police Station, Chennai West,
CCD – 1, Chennai)
Prabhu, M/40 Years,
S/o Ganesan,
No.50, F3, Metro Nagar,
2nd Avenue, Alapakkam,
Chennai-600 116
Tamil Nadu. … Petitioner/Defacto Complainant
-Vs-
1) State Rep by Inspector of Police,
Cyber Crime Police Station,
Chennai West, CCD – 1,
Chennai. (FIR No 98 of 2023) … Respondent/Investigating Agency
2) Punjab National Bank Ltd,
Nizamudin West Branch
Main Road, Nizamudin West,
New Delhi-110013
State of Delhi
IFSC PUNB0016000
Email id:
3) Punjab National Bank Ltd,
Bilaspur Greater Noida Branch,
VPO Bilaspurteh, Kasna Dist,
Gautambudh Nagar- 203 202
State of Uttar Pradesh
IFSC PUNB0022710
Email id:
4) Yes Bank Ltd,
Sanat Nagar Srinagar Branch,
Ground Floor, Enigma Complex, Plot No.1, Housing Colony Rawalpura, Sanat
Nagar, Srinagar- 190 005
State of Jammu & Kashmir
IFSC YESB0000602
Email id: yestouch@yesbank.in
5
 … Respondents 2 to 4/Banks

PETITION TO RETURN OF PROPERTY

(Under Section 451 R/W 457 of CRPC)
For the reasons stated in the accompanying affidavit, it is therefore pray that this

Hon’ble Court may be pleased to direct the

(i) 2nd respondent bank to return a sum of Rs 1,00,000 /- (Rupees One Lakh

Only)

(ii) 3rd respondent bank to return a sum of Rs 50,000/- (Rupees Fifty

Thousand Only)

(iii) 4th respondent bank to return a sum of Rs 65,000/- (Rupees Sixty Five

Thousand Only) which was fraudulently debited from petitioner’s bank

account i.e., HDFC Bank, A/c No: 05741610000070, Kodambakkam

Branch, Chennai, IFSC Code- HDFC0000574, pass such further order

or orders as this Hon’ble court made deem fit and proper in the

circumstances of the case and thus render justice.

Dated at Egmore, Chennai on this the 21st day of March 2024

COUNSEL FOR PETITIONER/DEFACTO COMPLAINANT

Documents:
1) Statement of Accounts
2) First Information Report

6
 BEFORE THE HON’BLE ADDITIONAL CHIEF METROPOLITAIN
MAGISTRATE AT EGMORE
CRL M P No of 2024
in
FIR No 98 of 2023
(On the file of Inspector of Police, Cyber Crime Police Station, Chennai West,
CCD – 1, Chennai)
Prabhu M/40Years,
S/o Ganesan … Petitioner/Defacto Complainant
-Vs-
State Rep byInspector of Police,
Cyber Crime Police Station,
Chennai West, CCD – 1,
Chennai. (FIR No 98 of 2023) & others …Respondent/Investigating Agency
VAKALATH

I, Prabhu, do hereby appoint and retain M/S A.M. AMUTHAGANESH MS

1953/2008, V. JAYAVIGNESHWARI MS 2110/2015, M. BALU MS 380/2018
& K.KEERTHI 5494/2022 Advocates to appear for us in the above case on our
behalf and to plead and we further empower them to accept on our behalf service of
notice of all proceedings in the above case until disposal of the case.

SIGNATURE OF PETITIONER
I certify that the contents of this Vakalatnama were read over and explained in
English in my presence to the Executants who appeared perfectly to understand the
same and made their signature in my presence.
Executed before this the 21st day of March 2024
Before Me
Advocate :: Chennai
We accept the Vakalathnama COUNSEL FOR PETITIONER

Address for Service; No 155 Thambu Chetty Street, IV Floor, Chennai - 600 001
CellNo:9094790987,amuthaganeshadvocate@gmail.com

7
BEFORE THE HON’BLE ADDITIONAL
CHIEF METROPOLITAIN
MAGISTRATE AT EGMORE
CRL M P No of 2024
in
FIR No 130 of 2023
(On the file of Inspector of Police, Cyber
Crime Police Station, Chennai West,
CCD – 1, Chennai)
Sriram Rangarajan,
… Petitioner/Defacto Complainant
-Vs-
State Rep by Inspector of Police,
Cyber Crime Police Station,
Chennai West, CCD – 1,
Chennai. (FIR No 130 of 2023) & others
…Respondent/Investigating Agency

PETITION TO RETURN OF PROPERTY

(Under Section 451 R/W 457 of CRPC

M/S A.M. AMUTHA GANESH MS 1953/08

V. JAYAVIGNESHWARI MS 2110/15
M/S M. BALU MS 380/2018
K. KEERTHI MS 5494/2022
COUNSEL FOR PETITIONER
Cell No 9094790987

8
BEFORE THE HON’BLE ADDITIONAL
CHIEF METROPOLITAIN
MAGISTRATE AT EGMORE
CRL M P No of 2024
in
FIR No 130 of 2023
(On the file of Inspector of Police, Cyber
Crime Police Station, Chennai West,
CCD – 1, Chennai)
Sriram Rangarajan,
… Petitioner/Defacto Complainant
-Vs-
State Rep by Inspector of Police,
Cyber Crime Police Station,
Chennai West, CCD – 1,
Chennai. (FIR No 130 of 2023) & others
…Respondent/Investigating Agency

VAKALATH

M/S A.M. AMUTHA GANESH MS 1953/08

V. JAYAVIGNESHWARI MS 2110/15
M. BALU MS 380/2018
K. KEERTHI MS 5494/2022
COUNSEL FOR PETITIONER
Cell No 9094790987

9
BEFORE THE HON’BLE ADDITIONAL
CHIEF METROPOLITAIN
MAGISTRATE AT EGMORE
CRL M P No of 2024
in
FIR No 130 of 2023
(On the file of Inspector of Police, Cyber
Crime Police Station, Chennai West,
CCD – 1, Chennai)
Sriram Rangarajan,
… Petitioner/Defacto Complainant
-Vs-
State Rep by Inspector of Police,
Cyber Crime Police Station,
Chennai West, CCD – 1,
Chennai. (FIR No 130 of 2023) & others
…Respondent/Investigating Agency

DOC No: 1

DESCRIPTION:

M/S A.M. AMUTHA GANESH MS 1953/08

V. JAYAVIGNESHWARI MS 2110/15
M/S M. BALU MS 380/2018
K. KEERTHI MS 5494/2022
COUNSEL FOR PETITIONER
Cell No 9094790987

10
BEFORE THE HON’BLE ADDITIONAL
CHIEF METROPOLITAIN
MAGISTRATE AT EGMORE
CRL M P No of 2024
in
FIR No 130 of 2023
(On the file of Inspector of Police, Cyber
Crime Police Station, Chennai West,
CCD – 1, Chennai)
Sriram Rangarajan,
… Petitioner/Defacto Complainant
-Vs-
State Rep by Inspector of Police,
Cyber Crime Police Station,
Chennai West, CCD – 1,
Chennai. (FIR No 130 of 2023) & others
…Respondent/Investigating Agency

DOC No: 2

DESCRIPTION:

M/S A.M. AMUTHA GANESH MS 1953/08

V. JAYAVIGNESHWARI MS 2110/15
M. BALU MS 380/2018
K. KEERTHI MS 5494/2022
COUNSEL FOR PETITIONER
Cell No 9094790987

11
12