IN THE COURT OF CHIEF METROPOLITAN MAGISTRATE,

DWARKA COURTS, DELHI

COMPLAINT CASE NO. _________/2020

IN THE MATTER OF:-

DR.GAJENDRA SINGH RANGA COMPLAINANT

VERSUS

MR.PRADEEP SEHRAWAT
MR.SATENDRA MAAN
ANKUR PRASAD …ACCUSED PERSONS

INDEX

SL. PARTICULAR PAGE NO.

NO.

1. MEMO OF PARTIES

2. COMPLAINT U/S 200 Cr.P.C. ALONG WITH

SUPPORTING AFFIDAVIT.

3. APPLICATION U/S 156(3 ) Cr.P.C. ALONG

WITH SUPPORTING AFFIDAVIT.

4. AFFIDAVIT ACCORDING TO THE

JUDGMENT PASSED BY THE HON’’BLE
SUPREME COURT OF INDIA TITLED AS
PRIYANKA SRIVASTAVA AND ANR. VS.
STATE OF UP AND ORS

5. LIST OF WITNESSES

6. LIST OF DOCUMENTS

ALONGWITH DOCUMENTS

7. VAKALATNAMA

Delhi Complainant

Dated 05.10.2020 Through

MANISH BAIDWAN/ANKIT SHARMA

ADVOCATE FOR THE COMPLAINANT,
CH. NO. 169 CH. BLK. II,
HIGH COURT OF DELHI,
SHERSHAH ROAD,DELHI,
EMAIL:baidwanmanish@gmail.com
advankitsharma85@gmail.com
PH: 9728430911

IN THE COURT OF CHIEF METROPOLITAN MAGISTRATE,

 DWARKA COURTS, DELHI

COMPLAINT CASE NO. _________/2020

IN THE MATTER OF:-

DR.GAJENDRA SINGH RANGA COMPLAINANT

VERSUS

MR.PRADEEP SEHRAWAT
MR.SATENDRA MAAN
MR.ANKUR PRASAD …ACCUSED PERSONS

MEMO OF PARTIES

1. DR.GAJENDRA SINGH RANGA

S/O SH. PREHLAD SINGH RANGA
R/O B-38/S2 , BLOCK - B
DILSHAD GARDEN
DELHI - 110009 COMPLAINANT

VERSUS

1. MR.PRADEEP SEHRAWAT
2. MR.SATENDRA MAAN
3. MR.ANKUR PRASAD
R/O 16/14 , 17/2 MAJOR BHOLA RAM ENCLAVE
POCHANPUR , SECTOR - 23
DWARKA
DELHI - 110075 … ACCUSED PERSONS

P.S : DWARKA SEC 23

FILED BY

MANISH BAIDWAN/ANKIT SHARMA

ADVOCATE FOR THE COMPLAINANT,
CH. NO. 169 CH. BLK. II,
HIGH COURT OF DELHI,
SHERSHAH ROAD,DELHI,
EMAIL:baidwanmanish@gmail.com
advankitsharma85@gmail.com
PH: 9728430911
PLACE: NEW DELHI
DATED: 05.10.2020

IN THE COURT OF CHIEF METROPOLITAN MAGISTRATE,

 DWARKA COURTS, DELHI

COMPLAINT CASE NO. _________/2020

IN THE MATTER OF:-

DR.GAJENDRA SINGH RANGA COMPLAINANT

VERSUS

MR.PRADEEP SEHRAWAT
MR.SATENDRA MAAN
MR.ANKUR PRASAD …ACCUSED PERSONS

CRIMINAL COMPLAINT U/S 200 CR.P.C. FOR TAKING COGNIZANCE

OF THE OFFENCES PUNISHABLE UNDER SECTIONS 406,420, 463,
464, 465, 468, 471, 506, 34 AND 120B OF THE INDIAN PENAL CODE
OF 1860 COMMITTED BY THE ACCUSED PERSON.

MOST RESPECTFULLY SHOWETH:-

1. That the Complainant have faith in the administration of justice and

being aggrieved acts and actions on the part of the Accused person,

they are being compelled to approach this Hon’ble court by the virtue

of this present complaint.

2. That the Complainant Dr. Gajender Singh Ranga S/O Sh. Prehlad Singh

Ranga is a resident of B-38/S2 , Block – B , Dilshad Garden , Delhi -

110095 the Complainant is permanent resident of the

abovementioned address and is a law abiding citizens having full faith

in criminal justice system and are persons of high dignity and respect

in the society. The copy of ID proof of the complainant are exhibited as

(ANNEXURE – A1).

3. That the accused Mr. Pradeep Sehrawat ( Treasurer ) , Mr. Satender Maan

( President ) , Mr. Ankur Prasad ( Secretary ) Revanta Multi State CGHS

Ltd . having office at 16/14 , 17/2 Major Bhola Ram Enclave , Pochanpur ,
 Sector 23 , Dwarka , Delhi – 110075. (hereinafter referred as Accused

Person).

4. The brief facts necessitating the filing of the instant Complaint

are as follows:

A. That the complainant was looking to buy a flat by way of land

pooling policy in L Zone Dwarka. and through advertisement and a
property dealer at Dilshad garden, came to know about the
Revanta Multi State CGHS Ltd.

B. That in the month of March 2015

complainant visited their office at 16/14, 17/2 major Bhola ram
Enclave, Pochan Pur, Sector 23 Dwarka New Delhi-110077 .
Alleged persons with pre-planned conspiracy having fraudulent
and dishonest intension made a strong pitch about the project and
falsely told complainant that the project will be completed and
handed over by 2019.

C. That the property land was purchased from Revanta Multi State
CGHS Ltd. In the month of march 2015 through membership
number SR70016 and various payments were made for the
Accused amount on 22.03.2015 , 22.04.2015 , 24.05.2015 ,
30.05.2015 , 28.03.2019 respectively. (Copy of the Receipts are
ANNEXUED-A2.

D. That the Accused persons intentionally deceived the complainant

on the pretext of false promise of giving the possession of the
property by 2019 , as Accused persons from the very beginning
had false intention to cheat the complainant and thereby
dishonestly induced the complainant to advance the said amount
to the Accused persons.

E. That in order to gain confidence of complainant, the Accused in

connivance with other person sent various letters and demanded
money on one pretext or the other and had extorted the Accused
amount.
F. That it is congruous and germane to mention that the
accused persons are liable to be prosecuted and punished for
the said offences. That the Accused persons fraudulently made,
signed, sealed and executed documents with the intention of
causing it to be believed that such documents were from a legally
approved builder for land pooling policy.

G. That after gaining confidence of the Complainant the Accused

person had dishonestly induced them to pay the abovesaid amount
Rs.21,49,650/- ( Twenty one Lakh Forty Nine Thousand Six
Hundred fifty only ) through installments and thereby deceived the
complainant.

H. That the Accused persons are liable to be prosecuted and punished

for the said offences. as the Accused persons had caused an
offence of cheating with the complainant by inducing them to
advance the sum of Rs.21,49,650/- ( Twenty one Lakh Forty Nine
Thousand Six Hundred fifty only ) as the society was not register in
RERA.

I. Forgery and Fabrication of the documents were done by the

accused persons and thereby they succeed in duping the
complainant. It is needless to mention that wrongful gain is
received by the accused persons whereas wrongful loss is
caused to the complainant and complainant had entrusted
their hard earned money to the Accused in good faith but the
accused person had committed the offence of criminal breach
of trust by hatching a criminal conspiracy.

J. That the complainant had made several requests to the Accused

persons either to return the amount or to give the possession of
the property, to the utter shock and dismay, Accused started
giving evasive replies and threats. It is pertinent to mention here
that till now construction work has not started. Moreover, they are
unlikely to start as they are not registered.

K. That After the above said Act of the Accused persons the
complainant started enquiring from DDA and other agencies and
 came to know that the Revanta Multi state CGHS Ltd. Is involved
in scam and as such DDA and RERA has not approved them for
the said land pooling policy. Therefore the Accused persons have
cheated and are cheating public in the name of Land pooling.

L. That the Accused Persons have usurped huge amount from the
Complainant and several other innocent people and have diverted
their money to other uses, for their selfish gains. That it is
pertinent to mention here that the conduct of the Accused Person,
clearly reflects that since the beginning the intention of the
Accused Person was deceitful and malafide.

M. That being aggrieved by such blatant fraud being done by the

Accused Persons, the Complainant has made requests to the
Accused Person to return back their money but the Accused
Person have not paid any heed to the legal demands and requests
of the Complainant and have been evading their liability towards
the Complainant by giving evasive replies.

N. That the Complainant had advanced money to the Accused

persons hinging upon the false and fraudulent representation of
the Accused Persons and have consequently suffered loss,
inconvenience and harassment which is continuing.

O. That it is needless to say that wrong full gain is received to the

Accused persons and wrong full loss is caused to the complainant
and the complainant entrusted his hard earned money with the
Accused persons in good faith, but all the Accused committed the
offence of criminal breach trust by hatching criminal conspiracy.

On the basis of above said facts it is clear that:

1. That the Accused Persons have usurped huge amounts from the
Complainant and diverted their money to other uses, for their
selfish gains. That it is pertinent to mention here that the conduct
of the Accused Persons, clearly reflects that since the beginning the
intention of the Accused Persons was deceitful and malafide.
 2. That being aggrieved by such blatant fraud being done by the
Accused Persons, the Complainant have made numerous requests
to the Accused Persons to return back their money but the Accused
Persons have not paid any heed to the legal demands and requests
of the Complainant and have been evading their liability towards
the Complainant by giving evasive replies.

3. That the Complainant had advanced the amount to the Accused

persons hinging upon the false and fraudulent representation of
the Accused Persons and have consequently suffered loss,
inconvenience and harassment which is continuing.

4. That the Complainant have made a complaint against the accused

Person to the SHO of P.S. Dwarka Sector - 23 on 09.03.2020,
however, till date no action has been taken by the police despite of
repeated requests made by the complainant, hence the present
petition. The copy of the said complaint dated 09.03.2020 made
to the SHO of P.S Dwarka Sector - 23, Delhi is annexed
herewith as ANNEXURE - A3.

5. That the Complainant had also sent complaint to D.C.P, Dwarka

District against the Accused Persons on 30.07.2020 however, till
date no intimation has been received by the Complainant with regard
to their complaint, hence the present petition.

6. That in the case titled as “Lalita Kumari V/s Govt. Of UP &Ors.” it

was categorically held by the Hon’ble Supreme Court of India that
the registration of FIR is mandatory in all the cognizable offences.

7. That from the facts and circumstances as mentioned herein above

it is clear that all the accused Person have committed the offences
i.e. sections 406,420, 463, 464, 465, 468,467, 471, 506, 34, AND
120B of IPC. It is congruous and germane to mention here that all
the offences committed by the accused persons are not only
cognizable but non bailable as well. Offences are committed in the
jurisdiction of P.S. Dwarka Sector - 23 since the accused person
showed the false and fabricated document and received the token
 amount and induced the complainant into membership of the
Revanta multi state CGHS Ltd.

8. The Complainant have not instituted any other case or proceeding

against the Accused Persons, either in this court or in any other
court in India.

9. That the cause of action has arisen in Delhi – Dwarka Sector - 23

as the Accused Persons induced the complainant in the jurisdiction
of P.S. Dwarka Sector - 23 Delhi. That Hon’ble Court has the
requisite territorial jurisdiction to entertain and try the present
case.

10. That the cause of action first arose when the Complainant made
the payment to the accused persons. That the cause of action arose
when receipts of payment was advanced by the accused persons to
the complainant. That the cause of action arose again when the
Accused Person started giving evasive replies to the demands of
money made by complainant. The cause of action is still subsisting
and continuing as the Accused Person has not returned the
amount Rs. 21,45,650/- (TWENTY ONE LAKH FORTY ONE
THOUSAND SIX HUNDRED FIFTY ONLY ). That the Accused Person
have till date failed to deliver the flat and did not even return the
money which accused persons extracted illegitimately from the
Complainant. The instant complaint is well within the period of
limitation.

11. That no other efficacious remedy is left but to approach the Hon’ble
Court.

PRAYER

In the conspectus of circumstances delineated hereinabove, it is

therefore, most respectfully and humbly prayed before this Hon’ble Court
to:

a) Take cognizance of the offences U/S 420, 406 ,463, 464, 465,
468 ,467, 471, 506, 34 , 120A , AND 120B OF THE INDIAN
 PENAL CODE OF 1860 committed by the aforesaid Accused
Person and to summon, try and penalize the accused person for the
offences mentioned in the title of the complaint in accordance with
law in the interest of justice.

b) Any other relief(s) that this Hon’ble Court may deem fit and proper.

COMPLAINANT

THROUGH

MANISH BAIDWAN/ANKIT SHARMA

ADVOCATE FOR THE COMPLAINANT,
CH. NO. 169 CH. BLK. II,
HIGH COURT OF DELHI,
SHERSHAH ROAD,DELHI,
EMAIL:baidwanmanish@gmail.com
advankitsharma85@gmail.com
PH: 9728430911
PLACE: NEW DELHI
DATED:05.10.2020

IN THE COURT OF CHIEF METROPOLITAN MAGISTRATE,

DWARKA COURTS, DELHI
 COMPLAINT CASE NO. _________/2020

IN THE MATTER OF:-

DR.GAJENDRA SINGH RANGA COMPLAINANT

VERSUS

MR.PRADEEP SEHRAWAT
MR.SATENDRA MAAN
ANKUR PRASAD …ACCUSED PERSONS
AFFIDAVIT

Affidavit of Dr. Gajendra Singh Ranga S/o sh. Prehlad Singh Ranga
R/o B38/S2, Block – B , Dilshad Garden, New Delhi - 110095. I, the
above named deponent do hereby solemnly affirm and declare as under:-

1. That the deponent is the Complainant in the above noted case and
well conversant with facts and circumstances of the case and as
such the Complainant competent to swear the affidavit.

2. That the accompanying Complaint u/s 200Cr. P.C has been

drafted by the counsel under my instructions which are correct
and may be read as the part and parcel of this affidavit as same are
not being repeated herein for the sake of brevity

Deponent

Verification: -

Verified at Delhi on 5th day of October, 2020, that the contents of

this affidavit are true and correct to the best of my knowledge and belief
and nothing has been concealed therefrom.

Deponent

IN THE COURT OF CHIEF METROPOLITAN MAGISTRATE,

DWARKA COURTS, DELHI
 COMPLAINT CASE NO. _________/2020

IN THE MATTER OF:-

DR.GAJENDRA SINGH RANGA COMPLAINANT

VERSUS

MR.PRADEEP SEHRAWAT
MR.SATENDRA MAAN
ANKUR PRASAD …ACCUSED PERSONS

APPLICATION U/S 156(3) CODE OF CRIMINAL PROCEDURE, 1973,

FOR DIRECTIONS TO THE S.H.O. OF P.S. DWARKA SECTOR - 23 TO
REGISTER AN FIR AGAINST THE ACCUSED PERSONS FOR
COMMITTING THE OFFENCES PUNISHABLE UNDER SECTIONS
406,420, 463, 464, 465, 468 ,467, 471, 506, 34 AND 120B of IPC of
IPC COMMITTED BY THE ACCUSED PERSON.

MOST RESPECTFULY SHOWETH:

1. That the Complainant has filed the accompanying complaint u/s

200 Cr. P.C. and the same is pending before this Hon’ble court and
the contents of same may be read as part and parcel of this
application and have not been reproduced herein for the sake of
brevity seeking directions for registration of the FIR.

2. That finding no other option, the Complainant lodged a written

complaint dated 09.03.2020 before the SHO of PS. Dwarka Sector -
23 , New Delhi and also to the Higher Police Authorities but no
action has been taken against the Accused Persons by the police
officials.

3. That the complaint in itself discloses cognizable offences against

the accused persons under sections 406,420 ,463, 464, 465,
468 ,467, 471, 506, 34 , 120A , AND 120B of IPC, but the local
police, despite the best efforts of the complainant, has not
registered any FIR against the accused persons.

4. That the complainant have made a complaint against the Accused

Persons to the SHO of P.S. Dwarka Sector - 23 Delhi, however, till
 date no action has been taken by the police despite of repeated
requests made by the complainant.

5. That the Complainant had several times written to Police officials

with grievances and requested them to take legal action against the
Accused persons but all her pleas fallen in deaf ears and they failed
to register the FIR despite the commission of cognizable offences
hence, the Applicant have no other alternative but to seek the kind
intervention of this Hon’ble court to seek the justice.

6. That the complainant have also sent the complaint to the D.C.P
South District for their complaint against the Accused Persons but
till date no action has been taken by the D.C.P as well to the
request made by the Complainant.

7. That the police investigation is required in this case as evidences

are not within the reach of Complainant and further custodial
interrogation of the Accused persons is required to unearth the
conspiracy of Accused persons, to recover the forge and fabricated
documents, to identify the author and place of the forge and
fabricated documents, to identify the persons involved in the
Criminal Conspiracy against the complainant.

8. That the above said Accused persons committed various cognizable

offices within the jurisdiction of PS. Dwarka Sector - 23 ,New Delhi
and as such this Hon’ble court has the territorial jurisdiction to
entertain the present complaint of the Complainant

9. That the registration of FIR is necessary considering the following

grounds:

(i) For recovery of money of Rs.21,49,650/- (TWENTY ONE

LAKH FORTY ONE THOUSAND SIX HUNDRED FIFTY ONLY )
with interest of 24% Till date from the Accused Person.
 (ii) To investigate the role of Accused Persons and every person
involved in the above said matter specifically and
individually as well as to unearth the conspiracy hatched by
them against the Complainant.

(iii) To recover the cheated money.

(iv) Other grounds.

10. That finding no alternative the complainant had moved to this

Hon'ble Court for necessary action.

PRAYER

In view of the above facts and circumstances it is respectfully prayed

that the Hon’ble Court be pleased to issue necessary directions U/s
156(3) Cr.P.C. to the concerned SHO for registration of the FIR against
the accused persons under sections 420, 406, 463, 464, 465,
468 ,467, 471, 506, 34 , 120A , AND 120B of IPC and to submit the
report accordingly.

COMPLAINANT

THROUGH

MANISH BAIDWAN/ANKIT SHARMA

ADVOCATE FOR THE COMPLAINANT,
CH. NO. 169 CH. BLK. II,
HIGH COURT OF DELHI,
SHERSHAH ROAD,DELHI,
EMAIL:baidwanmanish@gmail.com
advankitsharma85@gmail.com
PH: 9728430911
PLACE: NEW DELHI
DATED: 05.10.2020

IN THE COURT OF CHIEF METROPOLITAN MAGISTRATE,

 DWARKA COURTS, DELHI

COMPLAINT CASE NO. _________/2020

IN THE MATTER OF:-

DR.GAJENDRA SINGH RANGA COMPLAINANT

VERSUS

MR.PRADEEP SEHRAWAT
MR.SATENDRA MAAN
ANKUR PRASAD …ACCUSED PERSONS
AFFIDAVIT

Affidavit of Dr. Gajendra Singh Ranga S/o sh. Prehlad Singh Ranga
R/o B38/S2, Block – B , Dilshad Garden, New Delhi - 110095. I, the
above named deponent do hereby solemnly affirm and declare as under:-

1. That the deponent is the Complainant in the above noted

case and well conversant with facts and circumstances of the
case and as such the Complainant competent to swear the
affidavit.
2. That the accompanying Complaint u/s 156(3) Cr. P.C has
been drafted by the counsel under my instructions which are
correct and may be read as the part and parcel of this
affidavit as same are not being repeated herein for the sake
of brevity

Deponent

Verification: -

Verified at Delhi on 5th day of October, 2020 that the contents of

this affidavit are true and correct to the best of my knowledge and belief
and nothing has been concealed therefrom.

Deponent

IN THE COURT OF CHIEF METROPOLITAN MAGISTRATE,

DWARKA COURTS, DELHI
 COMPLAINT CASE NO. _________/2020

IN THE MATTER OF:-

DR.GAJENDRA SINGH RANGA COMPLAINANT

VERSUS

MR.PRADEEP SEHRAWAT
MR.SATENDRA MAAN
ANKUR PRASAD …ACCUSED PERSONS

AFFIDAVIT ACCORDING TO THE JUDGMENT PASSED BY THE

HON’’BLE SUPREME COURT OF INDIA TITLED AS PRIYANKA
SRIVASTAVA AND ANR. VS. STATE OF UP AND ORS. IN CRL
APPEAL NO. 781/2012 IN AIR 2015 SUPREME COURT 1758

Affidavit of Dr. Gajendra Singh Ranga S/o sh. Prehlad Singh

Rang R/O – B38/S2, Block – B , Dilshad Garden , New Delhi - 10095 I,
the above named deponent do hereby solemnly affirm and declare as
under:-

1. That the deponent is the Complainant in the above noted case

and well conversant with the facts and circumstances of the case

and hence competent to swear the affidavit.

2. That the Deponent has faith in the administration of justice and

being aggrieved by acts and actions on the part of the Accused

persons, he is being compelled to approach this Hon’ble court by

the virtue of this present complaint. The copy of the id Proof of

the Deponent is exhibited as ANNEXURE - A1.

3. That the deponent was looking to buy a flat by way of land pooling policy

in L Zone Dwarka. and through advertisement and a property dealer at

Dilshad garden, came to know about the Revanta Multi State CGHS Ltd.
4. T hat in the month of March 2015

complainant visited their office at 16/14, 17/2 major Bhola ram Enclave,

Pochan Pur, Sector 23 Dwarka New Delhi-110077 . Alleged persons with

pre-planned conspiracy having fraudulent and dishonest intension made

a strong pitch about the project and falsely told complainant that the

project will be completed and handed over by 2019.

5. That the property land was purchased from Revanta Multi State CGHS

Ltd. In the month of march 2015 through membership number SR70016

and various payments were made for the Accused amount on 22.03.2015

, 22.04.2015 , 24.05.2015 , 30.05.2015 , 28.03.2019 respectively .

6. That the Accused persons intentionally deceived the deponent on the

pretext of false promise of giving the possession of the property by 2019 ,

as Accused persons from the very beginning had false intention to cheat

the deponent and thereby dishonestly induced the deponent to advance

the said amount to the Accused persons.

7. That in order to gain confidence of deponent, the Accused persons in

connivance with other person sent various letters and demanded money

on one pretext or the other and had extorted the Accused amount.

8. That it is congruous and germane to mention that the accused

persons are liable to be prosecuted and punished for the said

offences. That the Accused persons fraudulently made, signed, sealed

and executed documents with the intention of causing it to be believed

that such documents were from a legally approved builder for land

pooling policy.

9. That after gaining confidence of the deponent , the Accused person had

dishonestly induced them to pay the abovesaid amount Rs.21,49,650/-

 ( Twenty one Lakh Forty Nine Thousand Six Hundred fifty only ) through

installments and thereby deceived the deponent.

10. That the Accused persons are liable to be prosecuted and punished for

the said offences. as the Accused persons had caused an offence of

cheating with the deponent by inducing them to advance the sum of

Rs.21,49,650/- ( Twenty one Lakh Forty Nine Thousand Six Hundred

fifty only ) as the society was not register in RERA.

11. Forgery and Fabrication of the documents were done by the

accused persons and thereby they succeed in duping the deponent.

It is needless to mention that wrongful gain is received by the

accused persons whereas wrongful loss is caused to the deponent

and deponent had entrusted their hard earned money to the

Accused in good faith but the accused person had committed the

offence of criminal breach of trust by hatching a criminal

conspiracy.

12. That the deponent had made several requests to the Accused persons

either to return the amount or to give the possession of the property, to

the utter shock and dismay, Accused started giving evasive replies and

threats. It is pertinent to mention here that till now construction work

has not started. Moreover, they are unlikely to start as they are not

registered.

13. That After the abovesaid Act of the Accused persons the deponent started

enquiring from DDA and other agencies and came to know that the

Revanta Multi state CGHS Ltd. Is involved in scam and as such DDA

and RERA has not approved them for the said land pooling policy.

Therefore the Accused persons have cheated and are cheating public in

the name of Land pooling.

14. That the Accused Persons have usurped huge amount from the

deponent and several other innocent people and have diverted their

money to other uses, for their selfish gains. That it is pertinent to

mention here that the conduct of the Accused Person, clearly reflects

that since the beginning the intention of the Accused Person was

deceitful and malafide.

15. That being aggrieved by such blatant fraud being done by the Accused

Persons, the deponent has made requests to the Accused Person to

return back their money but the Accused Person have not paid any heed

to the legal demands and requests of the deponent and have been

evading their liability towards the deponent by giving evasive replies.

16. That the deponent had advanced money to the Accused persons hinging

upon the false and fraudulent representation of the Accused Persons and

have consequently suffered loss, inconvenience and harassment which is

continuing.

17. That it is needless to say that wrong full gain is received to the Accused

persons and wrong full loss is caused to the deponent and the deponent

entrusted his hard earned money with the Accused persons in good faith,

but all the Accused committed the offence of criminal breach trust by

hatching criminal conspiracy. Hence the present complaint.

18. That finding no other option, the Deponent lodged a written

complaint dated 09.03.2020 before the SHO of PS. Dwarka

Sector - 23 , New Delhi and also to the Higher Police Authorities

but no action has been taken against the Accused Persons by the

police officials. The copies of the Complaint are exhibited as

ANNEXURE- A-3.

19. That the above statements of the deponent are true and correct.
 DEPONENT

VERIFICATION: -

Verified at Delhi on this 5th day of October 2020, that the

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

DEPONENT
 IN THE COURT OF CHIEF METROPOLITAN MAGISTRATE,
DWARKA COURTS, DELHI

COMPLAINT CASE NO. _________/2020

IN THE MATTER OF:-

DR.GAJENDRA SINGH RANGA COMPLAINANT

VERSUS

MR.PRADEEP SEHRAWAT
MR.SATENDRA MAAN
ANKUR PRASAD …ACCUSED PERSONS

list of witness

1. Complainant himself.

2. Any other witness with due permission of this Hon’ble Court.

COMPLAINANT

THROUGH

MANISH BAIDWAN/ANKIT SHARMA

ADVOCATE FOR THE COMPLAINANT,
CH. NO. 169 CH. BLK. II,
HIGH COURT OF DELHI,
SHERSHAH ROAD,DELHI,
EMAIL:baidwanmanish@gmail.com
advankitsharma85@gmail.com
PH: 9728430911
PLACE: NEW DELHI
DATED:05.10.2020
 IN THE COURT OF CHIEF METROPOLITAN MAGISTRATE,
DWARKA COURTS, DELHI

COMPLAINT CASE NO. _________/2020

IN THE MATTER OF:-

DR.GAJENDRA SINGH RANGA COMPLAINANT

VERSUS

MR.PRADEEP SEHRAWAT
MR.SATENDRA MAAN
ANKUR PRASAD …ACCUSED PERSONS

list of documents

1. The copy of the id Proof of the Complainant.

2. The copy of Receipts against the payment made by complainant.

3. The copie of the Complaint dated 09.03.2020.

COMPLAINANT

THROUGH

MANISH BAIDWAN/ANKIT SHARMA

ADVOCATE FOR THE COMPLAINANT,
CH. NO. 169 CH. BLK. II,
HIGH COURT OF DELHI,
SHERSHAH ROAD,DELHI,
EMAIL:baidwanmanish@gmail.com
advankitsharma85@gmail.com
PH: 9728430911
PLACE: NEW DELHI
DATED: 05.10.2020
ANNEXURE - A1 (Copy of ID Proof)
ANNEXURE - A2 (RECIEPTS)
 ANNEXURE - A3

TO,

THE SHO

POLICE STATION DWARKA SECTOR - 23

NEW DELHI - 110091

SUBJECT : COMPLAINT AGAINST DIRECTORS AND PROMOTERS OF

REVANTA MULTI STATE CGHS LTD ( SMART RESIDENCY ) BY WAY OF
LAND POOLING IN L ZONE DWARKA. MR. PRADEEP SEHRAWAT
(TREASURER) , MR. SATENDER MAAN (PRESIDENT) , MR. ANKUR PRASAD
(SECRETARY) REVANTA MULTI STATE CGHS LTD. R/O 16/14 , 17/2 ,
MAJOR BHOLA RAM ENCLAVE , POCHANPUR SECTOR – 23 , DWARKA,
DELHI - 110075 AND OTHER PERSONS FOR CAUSING AN OFFENCE OF
CRIMINAL BREACH OF TRUST , CHEATING TO THE TUNE OF RS.
21,49,650/- (TWENTY ONE LAKH FORTY ONE THOUSAND SIX HUNDRED
FIFTY ONLY) FORGERY FOR THE PURPOSE OF CHEATING AND CRIMINAL
CONSPIRACY ETC. ON BEHALF OF THE COMPLAINANT DR. GAJENDER
SINGH RANGA RESIDENT OF B – 38/S2 , BLOCK – B , DILSHAD GARDEN
DELHI - 110095.

Sir.

5. That the Complainant Dr. Gajender Singh Ranga S/O Sh. Prehlad Singh

Ranga is a resident of B-38/S2 , Block – B , Dilshad Garden , Delhi -

110095.

6. That the alleged Mr. Pradeep Sehrawat ( Treasurer ) , Mr. Satender Maan

( President ) , Mr. Ankur Prasad ( Secretary ) Revanta Multi State CGHS

Ltd . having office at 16/14 , 17/2 Major Bhola Ram Enclave , Pochanpur ,

Sector 23 , Dwarka , Delhi – 110075. (hereinafter referred as Alleged

Persons).

7. That the complainant was looking to buy a flat by way of land pooling policy

in L Zone Dwarka. and through advertisement and a property dealer at

Dilshad garden, came to know about the Revanta Multi State CGHS Ltd.

8. That in the month of March 2015

complainant visited their office at 16/14, 17/2 major Bhola ram Enclave,

Pochan Pur, Sector 23 Dwarka New Delhi-110077 . Alleged persons with

 pre-planned conspiracy having fraudulent and dishonest intension made a

strong pitch about the project and falsely told complainant that the project

will be completed and handed over by 2019.

9. That the alleged persons with pre-planned conspiracy, fraudulent and

dishonest intension showed forged and fabricated documents related to

approvals and registrations and induced the complainant to buy a flat on

the pretext of false promises.

10. That the property land was purchased from Revanta Multi State CGHS

Ltd. In the month of march 2015 through membership number SR70016

and various payments were made for the alleged amount on 22.03.2015 ,

22.04.2015 , 24.05.2015 , 30.05.2015 , 28.03.2019 respectively.

11. That the alleged persons intentionally deceived the complainant on the

pretext of false promise of giving the possession of the property by 2019 , as

alleged persons from the very beginning had false intention to cheat the

complainant and thereby dishonestly induced the complainants to advance

the said amount to the alleged persons.

12. That in order to gain confidence of complainant, the alleged in

connivance with other person sent various letters and demanded money on

one pretext or the other and had extorted the alleged amount.

13. That the alleged persons fraudulently made, signed, sealed and executed

documents with the intention of causing it to be believed that such

documents were from a legally approved builder for land pooling policy.

14. That after gaining confidence of the Complainant the alleged person had

dishonestly induced them to pay the abovesaid amount Rs.21,49,650/-

( Twenty one Lakh Forty Nine Thousand Six Hundred fifty only ) through

installments and thereby deceived the complainant.

15. That the alleged persons are liable to be prosecuted and punished for the

said offences. as the alleged persons had caused an offence of cheating with

the complainants by inducing them to advance the sum of Rs.21,49,650/-

 ( Twenty one Lakh Forty Nine Thousand Six Hundred fifty only ) as the

society was not register in RERA.

16. Forgery was done by the alleged persons and thereby they succeed in

duping the complainants. It is needless to mention that wrongful gain is

received by the alleged person whereas wrongful loss is caused to the

complainants and complainants had entrusted their hard earned money to

the Alleged in good faith but the alleged persons had committed the offence

of criminal breach of trust by hatching a criminal conspiracy.

17. That the complainant had made several requests to the alleged persons

either to return the amount or to give the possession of the property, to the

utter shock and dismay, alleged started giving evasive replies and threats.

It is pertinent to mention here that till now construction work has not

started. Moreover, they are unlikely to start as they are not registered.

18. That After the abovesaid Act of the alleged persons the complainant

started enquiring from DDA and other agencies and came to know that the

Revanta Multi state CGHS Ltd. Is involved in scam and as such DDA and

RERA has not approved them for the said land pooling policy. Therefore

the alleged persons have cheated and are cheating public in the name of

Land pooling .

19. That the Alleged Persons have usurped huge amount from the Complainant

and several other innocent people and have diverted their money to other

uses, for their selfish gains. That it is pertinent to mention here that the

conduct of the Alleged Person, clearly reflects that since the beginning the

intention of the Alleged Person was deceitful and malafide.

20. That being aggrieved by such blatant fraud being done by the Alleged

Persons, the Complainant has made requests to the Alleged Person to

return back their money but the Alleged Person have not paid any heed to

the legal demands and requests of the Complainants and have been

evading their liability towards the Complainant by giving evasive replies.

21. That the Complainant had advanced money to the Alleged persons hinging

upon the false and fraudulent representation of the Alleged Persons and
 have consequently suffered loss, inconvenience and harassment which is

continuing.

22. That it is needless to say that wrong full gain is received to the alleged

persons and wrong full loss is caused to the complainant and the

complainant entrusted his hard earned money with the alleged persons in

good faith, but all the alleged committed the offence of criminal breach

trust by hatching criminal conspiracy.

Sir you are requested to kindly register a FIR , investigate and booked the

culprits as per law.

Dr. Gajender Singh Ranga ( Reg No. SR70016) S/O Mr. Prehlad Singh Ranga
R/O – B38/S2, Block – B , Dilshad Garden

New Delhi – 110095

Phone no. 9625900608

 IN THE COURT OF CMM DWARKA COURTS DELHI

In re:

DR.GAJENDER SINGH RANGA APPLICANT

VERSUS

PRADEEP SEHRAWAT & OTHER RESPONDENT

KNOW ALL to whom these present shall come that I, Dr.Gajender singh ranga ,,R/o B-38/S2 , B Block
Dilshad Garden, Delhi - 110095 do hereby appoint:

MANISH BAIDWAN & ANKIT SHARMA,

ADVOCATES
ENRL.NO. P/1285/17; D/7253/2018
PH: 9728430911; 9810248241
CH. NO.169, BLOCK II, HIGH COURT OF DELHI, NEW DELHI - 110503
(hereinafter called the advocate/s) to be my/our Advocate in the above noted case authorized him :-

To act, appear and plead in the above-noted case in this Court or in any other Court in which the same
may be tried or heard and also in the appellate Court including High Court subject to payment of fees
separately for each Court by me/ us.

To sign, file verify and present pleadings, appeals cross objections or petitions for execution review,
revision, withdrawal, compromise or other petitions or affidavits or other documents as may be deemed
necessary or proper for the prosecution of the said case in all its stages.

To file and take back documents to admit and/or deny the documents of opposite party.

To withdraw or compromise the said case or submit to arbitration any differences or disputes that may
arise touching or in any manner relating to the said case.

To take execution proceedings.

The deposit, draw and receive money, cheques, cash and grant receipts thereof and to do all other acts
and things which may be necessary to be done for the progress and in the course of the prosecution of
the said case.

To appoint and instruct any other Legal Practitioner, authorizing him to exercise the power and
authority hereby conferred upon the Advocate whenever he may think it to do so and to sign the Power
of Attorney on our behalf.

And I/We the undersigned do hereby agree to ratify and confirm all acts done by the Advocate or his
substitute in the matter as my/our own acts, as if done by me/us to all intents and purposes.

And I/We undertake that I / we or my /our duly authorized agent would appear in the Court on all
hearings and will inform the Advocates for appearance when the case is called.

And I /we undersigned do hereby agree not to hold the advocate or his substitute responsible for the
result of the said case. The adjournment costs whenever ordered by the Court shall be of the Advocate
which he shall receive and retain himself.

And I /we the undersigned do hereby agree that in the event of the whole or part of the fee agreed by
me/us to be paid to the Advocate remaining unpaid he shall be entitled to withdraw from the
prosecution of the said case until the same is paid up. The fee settled is only for the above case and
above Court. I/We hereby agree that once the fee is paid. I /we will not be entitled for the refund of the
same in any case whatsoever. If the case lasts for more than three years, the advocate shall be entitled
for additional fee equivalent to half of the agreed fee for every addition three years or part thereof.
IN WITNESS WHEREOF I/We do hereunto set my /our hand to these presents the contents of which have
been understood by me/us on this 05th day of October, 2020.

Accepted subject to the terms of fees.

ADVOCATE CLIENT