IN THE COURT OF THE JUDICIAL

MAGISTRATE No:4 OF
COIMBATORE

C.M.P.No: OF 2024.
In
Crime.No: 113 OF 2024.

SelvaKumar.E
S/o.Eswaran,
No.64/1, Sri Lakshmi nagar,
Thaneerpandal, Peelamedu,
Coimbatore
- Petitioner/
Defacto complainant
-Vs-
Inspector of Police,
Cyber Crime Branch,
Crime No:113/2024
-Respondent/Respondent

AFFIDAVIT

Presented on: .05.2024

 IN THE COURT OF THE JUDICIAL MAGISTRATE No:4
OF COIMBATORE

C.M.P.No: OF 2024.
In
Crime.No: 113 OF 2024.

SelvaKumar.E
S/o.Eswaran,
No.64/1, Sri Lakshmi nagar,
Thaneerpandal, Peelamedu,
Coimbatore - Petitioner/
Defacto complainant
-Vs-
Inspector of Police,
Cyber Crime Branch,
Crime No: 113/2024 -Respondent/Respondent

AFFIDAVIT

I, SelvaKumar.E , S/o.Eswaran, currently residing at No.64/1, Sri

Lakshmi nagar, Thaneerpandal, Peelamedu, Coimbatore &
permanent address in No.96 Poothottam, Vengittipalayam,
Dharapuram, Tiruppur-638657 hereby solemnly affirm and
sincerely state as follows:

1. I am the petitioner herein

2. I respectfully submits I have filed complaint before National

Cyber Crime reporting portal acknowledgement
No.22904240024588 and FIR has been lodged against the accused
for the offence under the section 419 & 420 of IPC along with 66D
of IT Act (Amended 2008) on 26.04.2024.

3. I am working as a team lead in a private organisation at Tidel

Park, Coimbatore. The Complaint is lodged regarding part time
work through Whatsapp /Telegram and cheated me an amount of
Rs.26,54,929/-

4. I state that the Accused team in the name of Blackstone

Advertising & branding department, (Item 1 in FIR) they
approached me through my WhatsApp Number and asked to do
Work from Home freelance work by subscribing Youtube videos &
Google review task, for completion of each task I was paid between
Rs.50/- to Rs.600/- Initially.

5. After preliminary sample work done through whatsapp, I was

asked to connect with the receptionist through telegram in the
name of Airani Recptionists and to proceed with further task, The
receptionist created one account for me and asked me to continue
the task of Youtube Subscription & Google review.

6. I was advised by the Admin to participate in welfare tasks by

paying some initial money which he was compelled to pay it by
stating that it mandatory procedure to proceed where the earning
will be more than ever. Then the teacher of the group created a new
group for executing the group task & provided lot of Instructions to
reach me the task.
7. I further states Since all the my money is locked from their
end where I have paid them by taking personal loan and
temporarily left from regular original job at that time. I was
completely manipulated by them and there was only one thought in
mind to get my money back.

8. I state that welfare task for each order was handled by the
teacher. The Welfare task group member details and the chat
history was submitted by me before the cyber crime branch,
Coimbatore.

9. I submits that in that time I got doubt regarding the welfare

task, so that I checked with the group members where the genuinity
and that was confirmed by the group members.

10. I submits that I paid all the amount as per the receptionist
telegram chat where the withdrawal is handled by the Finance
customer service persons.

11. I further state that when I asked for the withdrawal of my

amount they insisted me for the payment each time with some
reasons at each stage then I was unable to handle the worst
situation and asked for my money at all the times the accused
convinced me saying that this is the final order & withdrawal
charge, where the accused started to blame me by stating that I
have done additional order than what they asked to so.

12. I further state that I have Invested of Rs.26,54,929/- when I

asked to return the amount the accused team is asking for more
amount as repair order if I pay the repair order amount then all
amount will be returned to me.

13. I state that I am very well known that they are cheating me &
Fraudulently got all my hard earned money with an intention to
grab it from me.

Hence I have filed this complaint & some of my amount is freezed in

the account of the accused. I am paying all my salary as an interest
to my personal loan. if the freezed amount is not returned to me i
will be put to unrepairable loss.

In the above circumstances I therefore humbly pray to this

Honourable Court may be pleased to order the petition mentioned
Rs.26,54,929/- freezed from the accused account, pass orders &
thus render justice.

Solemnly affirmed and Deponent

Signed before me at
Coimbatore on .05.2024.

Advocate,Coimbatore
 IN THE COURT OF THE JUDICIAL MAGISTRATE No:4
OF COIMBATORE

C.M.P.No: OF 2024.
In
Crime.No: 113 OF 2024.

SelvaKumar.E
S/o.Eswaran,
No.64/1, Sri Lakshmi nagar,
Thaneerpandal, Peelamedu,
Coimbatore - Petitioner/
Defacto complainant
-Vs-
Inspector of Police,
Cyber Crime Branch,
Crime No: 113/2024 -Respondent/Respondent

PETITION FILED UNDER SECTION 451 R/W 457 Cr.P.C.

For the reason stated in the accompanying affidavit, it is

therefore prayed that this Hon’ble Court may be pleased to order
the below mentioned order the petition mentioned of
Rs.26,54,929/- which was freezed from the accused account to pass
orders & thus render justice.

Advocate for Petitioner/

Defacto complainant
 LIST OF DOCUMENTS
S.NO DATE NATURE OF TYPE
DOCUMENT

1. 26.04.2024 FIR Xerox

2. 24.02.2024 Complaint before Xerox

National Cyber Crime
reporting portal
3. Transaction screen Xerox
shots
4. WhatsApp ,Telegram
chats
5. Aadhar Card of the Xerox
complainant

ADVOCATE FOR PETITIONER

 IN THE COURT OF THE
JUDICIAL MAGISTRATE No:4
OF COIMBATORE
C.M.P.No: OF 2024.
In
Crime.No: 113 OF 2024.

SelvaKumar.E
S/o.Eswaran,
No.64/1, Sri Lakshmi nagar,
Thaneerpandal, Peelamedu,
Coimbatore
- Petitioner/
Defacto complainant
-Vs-
Inspector of Police,
Cyber Crime Branch,
Crime No:113/2024
-Respondent/Respondent

PETITION FILED UNDER SECTION

451 R/W 457 Cr.P.C.

Presented on:

Address for Service:-

M/S.SABAPATHY LAW ASSOCIATES
R.THENMOZHI BA.,BL
MS No.1090/1991
V.VANMATHI BCA.,LLB(Hons.)LLM
MS NO.409/2021,
No.18/123, Bharathi Park Road
No:2, Coimbatore - 641 043.
Cell: 9944169386.
 IN THE COURT OF THE JUDICIAL MAGISTRATE No:4
OF COIMBATORE

C.M.P.No: OF 2024.
In
Crime.No: 113 OF 2024.

SelvaKumar.E
S/o.Eswaran,
No.64/1, Sri Lakshmi nagar,
Thaneerpandal, Peelamedu,
Coimbatore - Petitioner/
Defacto complainant
-Vs-
Inspector of Police,
Cyber Crime Branch,
Crime No: 113/2024 -Respondent/Respondent

Notice to Additional Public Prosecutor.

Sir,

Please take notice that the petitioner has filed a petition for
the Return of Property and the same is posted on

Counsel Petitioner/ Defacto

complainant

.
 IN THE COURT OF THE JUDICIAL
MAGISTRATE No:4 OF
COIMBATORE

C.M.P.No: OF 2023.
In
Crime.No: 113 OF 2024.

SelvaKumar.E
S/o.Eswaran,
No.64/1, Sri Lakshmi nagar,
Thaneerpandal, Peelamedu,
Coimbatore
- Petitioner/
Defacto complainant
-Vs-
Inspector of Police,
Cyber Crime Branch,
Crime No:113/2024
-Respondent/Respondent

NOTICE TO THE ADDITIONAL PUBLIC

PROSECUTOR

Presented on: .05.2024

Address for Service:-

M/S.SABAPATHY LAW ASSOCIATES

R.THENMOZHI BA.,BL
MS No.1090/1991
V.VANMATHI BCA.,LLB(Hons.)LLM
MS NO.409/2021,
No.18/123, Bharathi Park Road
No:2, Coimbatore - 641 043.
Cell: 9944169386.
 IN THE COURT OF THE JUDICIAL
MAGISTRATE No:4 OF
COIMBATORE

C.M.P.No: OF 2023.
In
Crime.No: 113 OF 2024.

SelvaKumar.E
S/o.Eswaran,
No.64/1, Sri Lakshmi nagar,
Thaneerpandal, Peelamedu,
Coimbatore
- Petitioner/
Defacto complainant
-Vs-
Inspector of Police,
Cyber Crime Branch,
Crime No:113/2024
-Respondent/Respondent

VAKALATNAMA

Presented on: .05.2024

Address for Service:-

M/S.SABAPATHY LAW ASSOCIATES
R.THENMOZHI BA.,BL
MS No.1090/1991
V.VANMATHI BCA.,LLB(Hons.)LLM
MS NO.409/2021,
No.18/123, Bharathi Park Road
No:2, Coimbatore - 641 043.
Cell: 9944169386.