To,
The Hon’ble Chief Minister and the Governor of U.P
And Other High Rank Administrative (PCS) and Police Officers (IPS)
State:- Uttar Pardesh
COMPLAINT UNDER ART. 350 of THE CONSTITUTION OF INDIA 1949
READ WITH
SEC 154(3) C.R.P.C
RESPECTED SIR!
Para 1. That I Mr. KK Agarwal Advocate a practicing lawyer of U.P And Delhi Region have personally suffering a major criminal problem of the local hooligan people of Saharanpur residents who daily thru Unlawful assembly, extortion, criminal trespass, Riot and House breaking in day and night time have been continuously grabbing our legal property premises area one by one in the property this “said property premises” whose “Complete address”:- Mr. KK Agarwal, Miss Kum Kum Goel, Mr. Pardeep Kumar Goel, Mr. Deepak Goel and Misses Aparana Goel, House No : 7/35, Kana Mal Lotiya Mandir, Gauushala Road, Near Iron Vardhman Store, Near Dr. AK Jain Clinic, Near Route of Agarwal Dharm Shala, Saharanpur -247001.
Para 2. That the Offenders, hooligans, criminals and Culprits and their perpetrated partner in Crime and accessory are very much large number of criminal mind people working conjointly as a gang of criminal nexus to each other supporting each other for daily entering one by one in our said property premises as mentioned above.
à Below are the Names of major Accuseds People and Rest Accuseds unknown but known thru Live Video Recording if watched of 15-June-2016 incident till as we know some names of them and giving to you which are as follows:-
1. Baldev Raj Chabbra S/o Channan Das, 6/1488, Maa dhev Nagar, Police Station (P.S) Kotwali, Saharanpur and also do occupied illegally shop at our said Property premises.
2. Satpal Chabbra S/o Channan Das, 6/1488, Maa dhev Nagar, Saharanpur and also do occupied illegally shop at our said Property premises.
3. Madni Chabbra S/o Channan Das, 6/1488, Maa dhev Nagar, Saharanpur and also do occupied illegally shop at our said Property premises.
4. Rani Devi Wife “deep living relation with” ‘Ram Mohan Sharma S/o Amar Nath, Area Morganj, Near Sharma Soda Wala, P.S Kotwali, Saharanpur.
5. Ram Mohan Sharma S/o Amar nath, Address- Madho Nagar, P.S Kotwali Nagar, Saharanpur
6. Anurag Singhal S/o Hari Charan Das, Area Morganj, Near Sharma Soda Wala, P.S Kotwali, Saharanpur.
7. Pranjal Garg, S/o Pardeep Garg, and also do occupied illegally shop at our said Property premises.
8. Sanjay Tyagi, S/o Ramesh Tyagi, and also do occupied illegally shop at our said Property premises.
9. Sagar Gupta S/o Vinod Kumar Gupta, Address Sawantra Nagri, Dhoobi Ghat, P.S Mandi, Saharanpur.
10. Purshotam and also known as “Bhagwanji” S/o BhushanLal and Chacha (Uncle) of Sagar Gutpa, Sahranpur.
11. Parveen Gupta S/o BhushanLal and Tau (Uncle) of Sagar Gutpa, Saharanpur.
12. Ranjendar Kumar S/o Daal Chand, Address:- Radha Swami Colony, P.S Kotwali nagar, Saharanpur
13. Nakli Singh S/o Harish Chand, Address:- Prempuri, P.S Dehat Kotwali, Saharanpur
14. Veeneet Kumar Mittal S/o Salek Chand, Address:- Gyan Vihar, P.S Thana Mandi, Saharanpur.
15. With 150-200 people bring unknown for the gang of attackers and as private hired army for injury to cause and take away said property illegally in day time and in night and have recording of it for evidence proof.
Para 3. That the deadly incident in full daytime was occurred of house Breaking, Theft, 200 Hundred of Unlawful assembly people gathered for Wrongful Restraint, Wrongful Confinement, Extortion with Sec 34, 352, 404, 427, 447, 506 IPC with S.7 Criminal Act and had started off 2:15 PM (approx.) in afternoon time of 15-June-2016 and have immediately reported to the S.H.O named Raj Naryan Yadav Thana Mandi and SI “Dinesh Kumar Upadhaya I/C OP” Chowki In-charge and others on Thana mandi CUG so many times thru our mobile to them about dacoit incident and police assured to us for providing police backup with one word sending but intentionally not send and police force till 3:15 PM. That the road distance of Thana Mandi to the crime of scene was 1.0 (one) KM Only and take five minutes to cover thru Vehicle if police team backup was timely provided and rightfully took the custody of all the accuseds and perpetrator and their accessory of crime took all one by one in their police custody and applied all sections of IPC but would not happened as the all the hardcore criminal have already join hands and set the Thana Mandi major Police officers not to come in this crime of occurrence in daytime till the illegal work not get over and out. That when the criminal day housebreaking work has been done by the accuseds then the Police was come after 3:15 PM on the special order of the CO. First City, IPS and rest no other public servant or high Rank officer like D.M, ASP, SSP, DIG or any on various call of the Complainant have not send his or required police team to the Crime of Occurrence on dated 15-June-2016 quickly and that’s why our life were hanging on line for security, Safety and the immovable and movable property we lost and harmed by offenders which we possessed legally.
Para 4. That the above Accuseds and their partners in crime all are the dirty mens rea character, mostly are notorious illegal liquor and wine sellers, some murders, some hired henchman, habitual offenders, thug and criminal mind people of the Saharanpur locality and have been widely spreading criminal activities in various corners of the City Saharanpur and in past also grabbed the land of the various humble private residents of people in the similar way and same modus operandi as they did to us. That this time these hardcore criminals apply the same modus operandi on us and doing same land and property grabbing activities to us, which now onwards we have bringing to your concern & public notice that what are happening in your U.P State and how the high Rank Public Servant Officers are maintaining and tackling the District Saharanpur “law and order” and how the PCS administration and IPS police working in the City of Saharanpur except some one or two officers or public servants fulfilling their public duties on time and rest no further.
Para 5. That the Thana Mandi police had arrested only the three man in very nominal and simple sections 107/116 Crpc of disturbing public peace and not applied the Indian necessary Laws to its full extent as mentioned here sections 34, 109, 120B, 144, 147, 150, 154, 157, 158, 149,146, 207, 294, 311, 323, 327, 340, 341, 336, 347, 352, 355, 357, 379, 380, 385, 395, 400, 402, 403, 404, 419, 427, 447, 451, 452, 454 part ii, 457, 461, 468, 469, 504, 506, 507, 509, 511 IPC with Sec 7. Criminal Amendment Act, which falls the Thana Mandi Saharanpur police team guilty under sections 118, 119, 164, 165A, 166, 166A, 167, 176, 177, 179, 181, 201, 202, 203, 216A, 218, 219, 221, 336, 511 IPC from both police and offenders sides who breaks the law and who not saved the person thru lawful act done on time under the eyes of laws ought to be done. That the legal complaint which we addresses to the Thana Civil Lines at 4.00 PM on same day of incident was throw in the dustbin by the writer, munshi and the other local deputed police team at Thana Civil Lines and told that the three arrested accuseds were taken to City Magistrate of Saharanpur under charge 107/116 Crpc. That as we rush to the City Magistrate at Officers Colony of Saharanpur for telling the true crime of incident to him and opposing any kind of bail, we found that the several supporters of the three accuseds were there and again have dare stamina to do assault and battery to us but soon we tried to hide in commissioner residence where the P.A of Divisional Commissioner somehow save us with the help of commissioner police security available for Divisional commissioner. That the City Magistrate, Saharanpur not get listen matter of facts and anything from us and behave extreme roughly and unprofessional to us and then give bail easily to the three accuseds immediately on same moment and then after the three accuseds with their smiley face and their criminal supporters had gone from the Court of City Magistrate by making mockery to us while the bail papers already filled in advance and ready by them as surety to come out today from all sides.
Para 6. That today the Indian Laws is of no use and the disrespect of the Indian Laws found everywhere in every corners of Uttar pardesh by those public servants who get legal authority and power to do justice to others and to the aggrieved complainants and victims. That the State Officers is working like a Britan people worked before Independence in India 1947 who thru their delegated powers have been crushing and suppressing the voice of the aggrieved complainant and victim in every corners of India. That the High Rank Public servants make a joke in the administration system correlated to the judiciary legal system and the right of the very common man has been infringed everywhere and not for saving his/her on sharp time, but in contrast to that the State Officers are enjoying the immunity & privileges that they getting thru various taxes applied by the State on Common People and then after getting enjoying other amenities thru unethical work being working for the suppressing voice of common people, losing their earned and inherited assets and breaching their legal born rights and violation of laws and Rules and Regulation thru their machinery and powers of the State Officers of U.P State. Today the law is completely blind for the common and poor people like we are tiny ants and the State officers are crushing and suppressing poor innocent people thru their large legs and whipped powerful hands granted by the authority of State.
Para 7. That now the Criminal Incident of Dated 15-06-2016 was personally through complaint copy reported to the SSP, ASP, DM, City Magistrate and Divisional Commissioner at their Offices and residence but none were helped on dated 16-06-2016, 17-06-2016 because their deputed Staff and their P.R.O and the Clerk and Steno took the opposite guilty party matter in their hand with ulterior motive on consideration and every time refused the major Complainant and Victim side not to make a direct approach to the High Rank Officers of the U.P State for any aggrieved matter of facts and get tiny relief against the culprits.
That the various deputed P.R.O of the SSP, DM, Divisional Commissioner were deputed since last 10(ten) years the same man mostly observing by local poor and common people on same cities everywhere in U.P and are not changed and transferred on their routine manner to other places in U.P and that’s why they make deep friendly contacts, Uncle judge syndrome with the offenders and the other influential people of the Society working as a Steel wall of barrier in between Complainant and the Administrative and Police authority not to address any matter to them daily by the common and poor people come to their sitting offices.
That the time generally for meeting the complainant was fixed in between 10:00 AM to 12 PM (except Sunday fully off) but the SSP, D.M, Divisional Commissioner may have not punctually thru state bounden duty sit and therefore in this very short meager time if sits the local MP and other influential people, local public servants of other areas and department and required Staff of various department may take all the fixed time of this two hours and no additional and extra period of time and other time generally was given to the common poor man and woman and to the local victims and complainants of the people of India.
That if after that time 12:00 PM any crime was occurred in any place of the District then the same local buttering Staff and PRO of the SSP, DM and Divisional Commissioner give direct reply that come tomorrow and said that there are other public servants in the same City and you may go there –OR- the High Rank Police Officers and Administrative were busy in any personal meeting.
Para 8:- That now how the Indian laws applied by the State police Officers in INDA, Suppose if any Complainant is addresses to the SSP or D.M or Divisional Commissioner thru Speed Post then after one month time it may come to that Area Thana where the Complainant and Victim may reside and then the Biased and lethargy Thana duty officer note it in the Order Book which is somewhat important and rest others complainants throw in Thana dustbin and not taken any legal action on it. The every complainant as FIR registered or not is not a guarantee and surety still in U.P and if registered then the appointed Thana I.O make mostly in cases false report for the benefit and ulterior motive of the other guilty side and make a Non-Bailable section into Bailable sections, remove required strict sections of IPC and S.7 Criminal Act himself and make Non-Compoundable offence into Compoundable sections, Remove himself necessary accuseds person list and other partner and accessory in crime named in that FIR registered against all of them, and not record and collect any material evidences for the justifying that FIR before the case commit on trial before Magistrate court of law as his investigation report make the case feeble & weak. That what the benefit finally the Complainant and victim may get from the Taluka Court of law when case come commit on real trial. That also if the Thana police matter think to may register any complaint for complainant and victim person satisfaction, then make a Simple 107/116 and 151 Cr.p,c matter for both sides or one side person and present before the City Magistrate or the SDM court of law and then some may get freed on same day on simple bail bonds or some may go to District Jail if no bail bonds and sureties available before Taluk Magistrate Court available. That my this lackluster and fooling around approach for the people of India we learnt that Area Thana is the main center part like a kingdom comes and if the Area Thana is against you then living peacefully in the District is very much impossible by the Complainant and the Victim who suffered thru that incident happened to him/her. That due to that the same Criminal and Guilty party and offender may kill to the Complainant and Victim one day and loot all his/her assets in just one shot of crime once more. Is this the Independence of India may come to existence in India for the welfare for the People of India.?
Para 9. That the law and order and machinery of the U.P State is on the daily gambling game of stake and that’s why we the people of India in the State has been living with their own fate and destiny in the extreme fear of daily Human Violence, Theft, burglary, Extortion, Criminal Intimidation, Criminal Trespass, Abusive language, Cheating, Murder, Wrongful Confinement and Restraint, Hurt and grievous hurt, land grabbing and encroachment, etc spread in all the corners of the U.P State and since 70 years of Independence it won’t stooped till now and still going everywhere in the U.P State.
Para 10. That in the Past and bygone time I myself Complained of so many times various issues and criminal complaint addresses to the U.P State like this issue and Complaint but every complaint was ordered to the SSP or DM Saharanpur directed from Top to bottom in one month time and then after the SSP and DM or Divisional Commissioner Office not take necessary required steps on that complaint and throw in dustbin since last two years to three years I truly observed myself personally OR directed to the same biased Thana where nothing was lawful done for complainant. Hope this complaint may meet or may not in same walking line which the U.P State officers fooling around the people of India.
Para 11:- That the learned advocate like me facing this problem of this lethargy and dirty drastic approach and rough and silent kind of authority system then what will may happened to the other person who are not educated and not know the system loopholes in the Nation of India. That the Live incident of dated 15-06-2016 was put in DVD video File and will be soon handed over to the Co. City First (IPS) of City Saharanpur for the veracity of my complaint and the criminal incident of dated 15-june-2016 in day time occurred to us in daytime at city Saharanpur.
++ PRAYER ++
Hence I humbly request to the State Officers of the U.P and Central State Officers Government of India to take requisite necessary swift steps for making required changes under the machinery of the legal system and their designated officers who applied the Indian laws and report to the designated court of law everywhere for very petty to major crime taking place in India in every corners of India and its people of India.
That in my case kindly take necessary urgent steps for its registration of FIR and legally arrest all the above named necessary person and others immediately and apply all the legal sections of IPC as I mentioned here with S.7 Criminal amendment Act so that the legal system and its machinery make revive and set right from the dead soul for the saving and assets and life and dignity for myself as the people of India get power to live under the Constitution of India. Any other kind of relief and logical approach may also apply for the additional benefit of me for this incident occurred on dated 15-June-2016. That any further contact and its interrogation kindly may contact to me on the below addresses and mobile of me.
That kindly don’t send this complaint to the Thana Mandi, Saharanpur as I lost complete faith and believe on the Thana system in the U.P as I bore so many times same walking of Thana police as I told in this complaint and know what they do or not to do for the resolving of this complaint and get rid of it in what way.
Thanking You!
Complainant/Aggrieved person
Dated:- 17-June-2016 Mr KK Agarwal Advocate,
Address:- 7/35, Kana Mal Lotiya Gauushala Road,
Near Agarwal Dharm Shala Route, Near Vardhan Iron Store,
District Saharanpur -247001, U.P.
MB: - 09319365499, 09457837917.
