IN THE COURT OF SH. RAGHAV SHARMA LD.

MM, SOUTH-
EAST DISTRICT SAKET COURTS: NEW DELHI

MISC APPLICATION No. /2024

IN THE MATTER OF:

HARSHVARDHAN SHARMA VS KAPIL MOHAN & ANR.

MEMO OF PARTIES

HARSHVARDHAN SHARMA
S/O SHRI SATISH SHARMA
R/O FLAT No. 218, MIG FLATS,
SURAJ APARTMENTS,
PUL PEHLADPUR, NEW DELHI-110044 ...COMPLAINANT

VERSUS
1. KAPIL MOHAN BHARDWAJ S/O LATE SHRI
NARSI BHGAT

2. PREETI BHARDWAJ
W/O KAPIL MOHAN BHARDWAJ

BOTH R/O 512, CHIRAG DELHI,

NEW DELHI – 110017 ...RESPONDENTS

New Delhi Applicant/Complainant

Dated: 26.04.2024
Filed by

(Advocate Vinod Yadav)

IN THE COURT OF SH. RAGHAV SHARMA LD. MM, SOUTH-
EAST DISTRICT SAKET COURTS: NEW DELHI

MISC APPLICATION No. /2024

IN THE MATTER OF:

HARSHVARDHAN SHARMA --- COMPLAINANT

VERSUS

KAPIL MOHAN BHARDWAJ AND ANR --- RESPONDENTS

Police Station: Kalkaji

DD No. 59 dated 15.03.2024

APPLICATION FOR CALLING THE DETAILED STATUS

REPORT FROM POLICE STATION KALKAJI IN COMPLAINT
DATED 15.03.2024 VIDE DD. NO. 59.

MOST RESPECTFULLY SHOWETH:-

1) That on 15.03.2024, complainant/applicant lodged a

complaint vide DD No. 59 in the Police station Kalkaji
regarding assault, theft and criminal intimidation against the
above mentioned respondents. Annexed as Annexure 1.

2) That the brief facts of the case is as under –

“The applicant is one of the Pujaris of the Shri Kalkaji Mandir

situated at Kalkaji, New Delhi.

That starting midnight of 19/20.02.2024 till 19.03.2024 it was

turn of the applicant complainant and his family members to
perform Puja Seva and collect Teh-bazari. Around 7:30 p.m.
in the evening Shri Kapil Bhardwaj started arguing with
father of the applicant/complainant over handing over keys
of Dera room for giving him extra sarees to which father of
 the applicant/complainant Satish Sharma refused to him
politely and told him that he will not aid and abate
stealing/theft nor will help him in illegal activities. Upon
refusal he got agitated and started abusing
applicant/complainant when he tried to stop him from
abusing and threatening father of the applicant/complainant.
Thereafter respondents abused the father of the
applicant/complainant in front of other Pujaris as well as
publicly and went away. Thereafter 15 to 20 minutes later
respondent returned after preplanning with an intent to
assault applicant/complainant came at the Dera with a bottle
in his hand and with an intent to injure applicant/complainant
tried to throw the bottle but he was stopped by others as well
as father of the applicant/complainant before he could injure
applicant/complainant. There after he extended open threats
that he will get applicant/complainant and his father
eliminated if they stopped them from stealing in Mandir
premises he also threatened applicant/complainant that he
will implicate him in false cases. On 12.03.2024 Kapil Mohan
along with his wife Preeti at around 11:35 to 11:40 a.m. just
after Bhog stole two silver/ gold bangles from inside the
Bhawan which is clearly visible in CCTV installed inside the
premises. That applicant/complainant same day went to the
Kalkaji Mandir Police Chowki and gave a written complaint
which was kept overnight by one constable Gaurav
8923535885 and did not provide any receiving. Thereafter
on 15.03.2024 the very next day applicant complainant
lodged the present complaint with the Police Station Kalkaji”

3) That from last more than a month, applicant/complainant has

been pursuing Investigation officer deputed to register FIR
on his complaint. Repeated assurances have been given by
the IO that he is investigating the complaint and soon he will
register FIR against the respondents.

4) For the past few days investigation officers not giving

satisfactory answers about investigation and preservation of
 CCTV footage and now he has also stopped taking the calls
of the applicant/complainant.

5) That delay in registration of FIR and preservation of the

CCTV footage of the acts of the respondents is fatal to the
case of the applicant/complainant which is definitely against
the law and is causing grave injustice to the
applicant/complainant since CCTV footage is perishable in
nature.

6) That the silver/gold bangles are in possession of the

respondents and as per the knowledge of the
applicant/complainant same is not recovered by the police
and needs to recovered, if further delay is done by the IO the
evidence will be destroyed by the respondents.

Prayer:

a) It is therefore, most respectfully prayed that this Hon’ble

court may kindly be pleased to call detailed status report
from police station Kalkaji in complaint dated 15.03.2024
vide dd. no. 59 and direct the IO to preserve CCTV
footage dated 12.03.2024 and 14.03.2024.

b) Pass such other and further order/orders as this Hon'ble

Court may deem fit and proper in the facts and
circumstances of the present case.

New Delhi Applicant/Complainant

Dated: 26.04.2024
Filed by

(Vinod Yadav)
Advocate for the Complainant
Chamber No. 606,
Lawyers Block,
Saket District Court 110017
IN THE COURT OF SH. RAGHAV SHARMA LD. MM, SOUTH-
EAST DISTRICT SAKET COURTS: NEW DELHI

MISC APPLICATION No. /2024

IN THE MATTER OF:

HARSHVARDHAN SHARMA VS KAPIL MOHAN & ANR.

AFFIDAVIT

I,HARSHVARDHAN SHARMA S/O. SHRI SATISH SHARMA,

Aged About 35 years, R/O. FLAT No. 218, MIG FLATS, SURAJ
APARTMENTS, PUL PEHLADPUR, NEW DELHI-110044, do
hereby solemnly affirm and declare as under:-

1 That all the contents of the accompanying

application have been drafted by my counsel as per
my instruction and same have been read over me.

2 That all the contents of the accompanying

application are not repeated herein for the sake of
the brevity.

DEPONENT

VERIFICATION:-

Verified on___________ at New Delhi that all the

contents of this affidavit are true and correct to the best of
my knowledge and nothing material has been concealed
therein.

DEPONENT
IN THE COURT OF SH. RAGHAV SHARMA LD. MM, SOUTH-
EAST DISTRICT SAKET COURTS: NEW DELHI

MISC APPLICATION No. /2024

IN THE MATTER OF:

HARSHVARDHAN SHARMA VS KAPIL MOHAN & ANR.

INDEX
Sl. No. Particulars Page No.

1. Memo of the Parties 1

2. Application for calling Status Report 2-5

alongwith supporting Affidavit
3. Annexure-1
Copy of order complaint dated 15.03.2024
vide DD No. 59.
5. Copy of ID (Aadhaar) of Revisionist.

New Delhi
Dated: 26.04.2024 Filed By:-

Vinod Yadav
Advocate
Ch. No 606, Lawyers’ Chamber Block,
Saket District Court,
New Delhi 110017
M: 9999561580
Email: advocatevinodyadav@gmail.com