To,

__.08.2023
__________________________________

EMAIL:

SUBJECT: COMPLAINT FOR LODGING AN FIR

AGAINST THE BELOW NAMED ACCUSED PERSONS
FOR COMMISSION OF OFFENCES PUNISHABLE
UNDER INDIAN PENAL CODE FOR CHEATING, FRAUD
AND CRIMINAL BREACH OF TRUST.

The name and details of Accused Person are as under:

1. Ms. Supriya Rajpoot

Designation: Telecaller
Office Address: Collins India Pvt. Ltd.
Plot No. E-49, Sector-3, Nearby Metro Station
Noida Sector-16, Noida (U.P.)- 201301
Residence Address: Sanjay Vihar, Kuleshra,
Near Baba Mohan Ram Mandir &
The Heritage Public Schook,
Greater Noida- 201306
Email- pr906274@gmail.com
Mobile No.- +91 9389909243

Respected Sir,

The contents of the present complaint are as follows:

1. The Complainant is constrained to institute this

complaint against the above-named Accused for
having perpetrated the offenses of deceit,
fraudulence, and criminal breach of fiduciary duty.
The Accused is culpable for coercing and
manipulating the Complainant into procuring the
latest Apple iPhone 13 Pro model at a substantial
markdown from the Accused’s friend’s
 establishment, Mobile House, located in Sector-18,
Noida, where only Apple-sanctioned merchandise is
retailed, thereby defrauding the Complainant of Rs.
90,000/- (Rupees Ninety Thousand Only).
2. The Accused person meet with the Complainant
during their tenure of employment at the
aforementioned office and established a rapport with
the Complainant. Subsequently, the Accused
informed the Complainant that her friend was
employed at an establishment named Mobile House,
situated in Sector-18, Noida, where only Apple-
endorsed products were retailed, and exerted
pressure on the Complainant to acquire the latest
Apple iPhone 13 Pro model, as it was obtainable at a
considerable reduction in price and that this
proposition was only valid for one day. Enticed by
the offer and taking into account the fact that the
Complainant and Accused were colleagues, the
Complainant placed their trust in the Accused and
requested her to furnish him with the aforementioned
model of Apple iPhone 13 Pro.
3. The Accused persons then stipulated an advance
payment of Rs.10,000/- (Rupees Ten Thousand
Only) from the Complainant to reserve the pertinent
iPhone model to capitalize on the aforementioned
offer, thereby leaving the Complainant with no
alternative but to remit to the Accused Rs.10,000/-
(Rupees Ten Thousand Only) in legal tender on
15.12.2021 for the specified purpose. It is germane
 to note here that the Complainant gave the sum of
Rs. 10,000/- (Rupees Ten Thousand Only) to the
Accused during their operational hours at the above-
referenced office.
4. After obtaining the sum of Rs. 10,000/- (Rupees Ten
Thousand Only) from the Complainant, the Accused
person, in an attempt to gain the Complainant’s trust,
assured that she would retrieve the aforementioned
iPhone 13 Pro model from her friend’s
establishment, Mobile House, located in Sector-18,
Noida, and would deliver it to the Complainant
within a week. However, after a fortnight had
elapsed since the remittance of the initial reservation
fee of Rs. 10,000/- (Rupees Ten Thousand Only), the
Complainant inquired about the delivery of the said
phone, to which the Accused individual endeavored
to circumvent the Complainant’s inquiry and
informed him that if he harbored doubts about the
transaction, he could rescind it, but the
aforementioned reservation fee would not be
reimbursed as it had already been remitted to the
store. It is relevant to state here that the Complainant
did not receive any payment receipts from the
Accused person for the reservation of the above-
mentioned phone if the amount had indeed been
remitted to the store against the reservation of said
phone.
5. One month subsequent to the remittance of the
reservation fee of Rs. 10,000/- (Rupees Ten
 Thousand Only), the Accused person informed the
Complainant that the aforementioned phone was
once again available in stock and would be released
by the store Mobile House, located in Sector-18,
Noida, only upon receipt of the full and final
payment of the invoice amount, i.e., Rs.80,000/-
(Rupees Eighty Thousand Only). However, upon
hearing this, the Complainant inquired as to why this
was the market price and that there was no reduction
of Rs. 15,000/- as initially promised by the Accused.
In response, the Accused person assured the
Complainant that the aforementioned discounted
amount would be refunded to the Complainant’s
bank account only after receipt of the full and final
payment. Furthermore, the Accused person also
threatened the Complainant that if he now wished to
proceed with the aforementioned offer, his initial
reservation fee of Rs.10,000/- would be forfeited and
the Complainant would receive nothing in return.
6. Impelled by the malevolent intent and fraudulent
promises and assurances, the Complainant, bereft of
any other recourse, accompanied the Accused to
Mobile House, located in Sector-18, Noida, for the
remittance of Rs. 80,000/-, but to their utter dismay,
upon arriving at the store, the Complainant was
informed that the aforementioned phone was not
present in stock and could be collected the following
day. At this juncture, the Accused person instructed
the Complainant to remit the full payment and that
 she, the Accused Person, would collect the
aforementioned phone along with bills from the said
store the following day and deliver it to the
Complainant during their office hours at the office.
Left with no alternative, the Complainant proceeded
to remit the full invoice amount of Rs. 80,000/-
(Rupees Eighty Thousand Only) from their bank
account bearing no. 071901528804 on 28.12.2012 in
favor of ICICI Bank at Mobile House, located in
Sector-18, Noida.
7. The Complainant was taken aback and astounded
when the Accused person refused to relinquish
possession of the aforementioned phone to the
Complainant and also menaced the Complainant
with a spurious lawsuit and declined to refund the
money remitted by the Complainant.
8. It is pertinent to state that the Accused person
harbored malevolent and dishonest intentions from
the outset, under the false guise of extracting the
Complainant’s hard-earned money. The nefarious
and fraudulent actions of the Accused were
perpetrated for the sole purpose of deceit, fraud, and
criminal breach of trust, and are encompassed within
the purview of cognizable offenses under the Indian
Penal Code. It has been established in a plethora of
judgments by the Hon’ble Supreme Court, and
specifically in Lalita Kumar vs State of UP, that in
cognizable offenses, the registration of a First
 Information Report is mandatory under Section 154
of the Code of Criminal Procedure.
9. The infraction has been perpetrated within the
territorial jurisdiction of the Police Station, Noida
Sector-20, Gautam Budh Nagar, Uttar Pradesh,
wherein the aforementioned transaction between the
Complainant and the Accused individual transpired
within the jurisdiction of the Police Station, Noida
Sector-20, Gautam Budh Nagar, Uttar Pradesh.
10.It is therefore requested that an FIR in the instant
case be registered against the accused person and
investigation be undertaken forthwith. The
complainants herein undertake to cooperate with the
investigation at all times as and when required.

Yours Respectfully,

Complainant Name & Address