To,
The Chief Minister and Governor of U.P State
And The U.P Administrative Officials and High Rank concerned officers, Police
State:- Uttar Pardesh, INDIA.
Article 350, 300A of the Constitution of India.
FIR 154/150 Cr.p.c -Read With- crimes defined in IPC
Invoked powers Sec 10, 17, 22, 23, 24 & 25, 29 OF POLICE ACT
Read with- Sec 29A IPC -Read with- Sec 88A Indian Evidence Act
S.4, 9, 11, 15, 28 of - U.P GOvernment Servants CONDUCT RULES 1956
PUBLIC SERVANTS INQURIES ACT 1850
S. 7, 10, 11, 12 13, OF - the PREVENTION OF CORRUPTION ACT 1988.
S.34, 109, 119, 120B, 166, 167, 177, 182, 193, 196, 199, 203, 211,213, 217, 218, 219, 384, 404, 406, 420, 427, 447, 500, 506, 511 - Indian Penal Code 1860.
Kindly Take needful action of accomplice crime accessory perpetrated by Public Servants in color of their post and breach of their duty:-
City Magistrate of the District Saharanpur.
[Under Rank Officers Principal Secretary of U.P Govt./ Divisional Commissioner /D.M of Saharanpur]
Sushil Kumar Dubey, SHO of Thana Mandi
Accessory in Crime by Dinesh Uphadhay/SO, Mobile 08006405241,
P.S THANA MANDI, [Under Officers SSP/DIG/IG/ADGP/DGP]
DISTT. Saharanpur.
Resp. Sir,
1. That I KK Agarwal Adv. has been a practicing lawyer since 2009 and has been contesting various client cases in the cities of Delhi, Muzaffarnagar, Ghaziabad and Saharanpur. That I am registered member of Saharanpur Adhivakta Civil Bar Association & District Bar Association Muzaffarnagar and registered with Supreme Court entrance practicing advocate since 2009. That I have my mother personal ancestral property inherited legal rights at Saharanpur Property whose complete postal address is – KK Agarwal Advocate and Kum Kum and Aparna D/o PremChand, 7/35, Kana Mal Lotiya, Gauushala Road, Near Dr. AK Jain Clinic, Ram Leela Bhawan, Thana Mandi, Saharanpur (herein after referred as ‘said property’). That with this property my mother real younger sisters named Aparna and Kum Kum Goel live completely alone in this said property and also have legal property joint rights with me in this said property premises.
2. That some local hooligans and notorious people of the said property locality want to enter in the ‘said property’ with the help of the local some police officers deputed in Thana Mandi (Saharanpur) including the inner shared common knowledge of SHO/SO’s at Thana Mandi help, informed City Magistrate wrongfully and used his powers unlawfully to us and made a criminal conspiracy to enter illegally into the said property premises so that they undue take advantage of the situation and grab & extort all the said property premises with in their control for undue enrichment. That this said property belongs to five person and whose lawsuit Civil Suit No. 713/11 titled as “Aparana -Vs- Pernita Devi & Ors” has been contesting by us against our real brothers Pardeep & Deepak before the Ld court of Additional Civil Judge [Senior Division] - First at Saharanpur District court. That in the meanwhile some local land grabber Agarwal Samiti & dirty local shopkeepers and other henchmen notorious persons named whose names such as:-
à[
Accused No.1
Surendar Kumar Gupta, S/o Om Parkash
R/o:-Om Parkash, Gun Mohalla, Area Morganj, Near City Kotwali, Saharanpur.
Accused No.2
Anuj Kumar Gupta, [S/o Surendar Kumar Gupta],
R/o:-Om Parkash, Gun Mohalla, Area Morganj, Near City Kotwali, Saharanpur.
Accused No.3
Gyannadar Mohan Goyal, S/o Om Parkash
Office-1:- Saharanpur Electric Press, Chowk Fuwaha-raha, Sabzi Mandi, Saharanpur.
AND
R/o-:- Mandir Wali Gali, Near D.M Bungalow, Area:-New Bhagat Singh Colony, Saharanpur.
Accused No.4
Sanjay Goyal, [S/o Gyannadar Mohan Goyal]
R/o:-Mandir Wali Gali, Near D.M Bungalow, Area:-New Bhagat Singh Colony, Saharanpur
Accused No.5 [President of Vaishya Agarwal Samanviya Samiti, Agarwal Dharmshala, Gauushala Road, Thana Mandi, Saharanpur]
Local accomplices who working on Behalf of Accused No.1 to 4 “Notorious as Vaishya Agarwal group” Money extortion and land extortion group of local unknown people of Saharanpur locality taking part aggressively with accused No.1 to No.4 as white collar crime doing in Saharanpur for property extortion.
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Above all Taking part and supporting each other creating unlawful assembly working as one unlawful group to grab & extort our parents ancestral said property premises and pressurizing us, fighting us, tormenting us and take part in daily preplanned criminal conspiracy so that our said property premises with criminal threat and intimidation putting day to day fear and do assault and battery to us at our said property premises extort our property premises and illegally trying to eat & grab all our said property premises for their undue unjust enrichment and desire of minting the money from our said property premises to sell to other buyers.
3. That the local UP Police some deputed officers of “Thana Mandi” Saharanpur has joined business hands illicit with the above Accuseds no.1 to 5 and now all the said named “Acusseds” and the local deputed police of Thana Mandi (Saharanpur) and others persons working as a “one team” to forcefully grab our said property premises. That the Sushil Kumar Dubey and “Dinesh Uphadhay” or similar type of thinking known as UP Police officers are a black spot in the human society and due to that the crime ration graph has been increasing in the Uttar Pardesh. That I already sent various complaints in past before this fifth complaint but no action were taken till yet and that why this another dreadful situation was aroused by above accuseds & some police officers which was put before you to think about what the hell is going on at Saharanpur surrounded areas.
4. That the legal papers of the property made by the Civil Judge [Junior Division], Saharanpur in Suit no. 99/1997 are attached here for veracity of the proof that this property belong to us and into which directed to the parties not to interfere in our legal rights and no one can disentitle from our fathers property without due process of law.
5. That the another legal papers of the property partition is pending before the Addl.Civil Judge [Senior Division]-First, Saharanpur in Suit no. 713/2011 titled as “Aparana Goel Vs Pernita Devi & Ors” are attached here for veracity of the proof that this property belong to us and into which all the legal necessary parties for property partition are pending before court and contesting date by date since last four years.
6. That the current City magistrate of Saharanpur is working against the Indian Laws and misuse and abuse his color of Office and task in intruding in the Civil Matter of the District Courts into which he has “no jurisdiction and no power” under said property matters to may close the said property or locked the said property of the ostensible owner while the civil matter are pending before the Civil Judge Senior Division of Saharanpur and in the past matter the Civil Judge [Junior Division] directed not to interfere into our said property rights to live forever till eternity and not disentitle without due process of law.
7. That as this is the first incident in my human life I faced with these type of dirty people so it is my legal duty to “truly report” every major or petty crime which I get think to address all the good people of the UP State and the other Rank officers who are sitting on the high post and now aware about what are happening in the local areas of the land & district whose in-charge and jurisdiction are they carried to make a better and safe place in the society. I have no fear of life as I am not afraid of death as every man also have to face death one day for his sins and morality. That the main objective & purpose of this fifth complaint which I send to you to take legal necessary prompt action on them and other liable Accuseds whose named are disclosed here in limine and your Public servants so that no type of crime defined in IPC may occurred in the UP state which make a better place in the world for us to live peacefully in the free world with dignity and pride as others and you are living with your parents and children. That kindly register our complaint in police dairy sec 44 under Police Act 1861 and taking needful prompt action on the named accuseds including guilty some deputed officers who in the color of their office and duty, misuse of police powers provoking & spreading crime in the said property & human society and minting the money for unjust enrichment purpose getting from local hooligans.
8. That the Property court papers are attached here and the Property partition matter in between real owners whom is attached as another here kindly see read and then take necessary action and unlocked the doors of our house at 7/35 Kana Mal Lotiya, Gaushala Road, Thana Mandi, Saharanpur. That of the doors of our house not get unlocked then I have to file a one new case against the U.P State and the SHO Mandi and the City Magistrate of Saharanpur who are encroaching the legal rights of the said property owner in desire of said property extortion may pass the local outsider people of Saharanpur. The City Magistrate have no right in to encroached in the private property matter of the property owners on behalf of outside land grabbing type of peoples.
++ PRAYER ++
A.) That as this is the matter put forward to you to take necessary swift departmental action kindly remove and suspension of the current City Magistrate of Saharanpur and its impugned unjust order and the other accessory police Officers as SHO Thana Mandi Sushil Kumar Dubey and the Chowki incharge Dinesh Uphadhay from the place of Saharanpur and conduct a wide enquiry under the Public Servant Act and the other provisions of the IPC mentioned in the first page of the complaint so that in future these kind of people not to harm and damage other people of India in their breach of duty and violation of Indian laws into their color of their post.
B). Kindly get the house doors entrance unlocked and remove all inside barriers and others new locks affixed at 7/35 Kana Mal Lotiya, Gauushala Road, Saharanpur immediately and provide Rs One Lakhs legal damages to the Complainant for doing unlawful action in the color of his office against the property owners of this house to suppress us and take advantage of us for the undue enrichment thru property extortion against us.
Thanking You!
Informants/Complainants
Dated-01-October-2015
Time:- 10:00AM
Mr. KK Agarwal Advocate
C/o Miss Kum Kum Goel, Miss Aparana,
‘Said Property’ Address:- 7/35, Kana Mal Lotiya, Nearer to Dr AK Jain clinic,
Gaaushala Road, Thana Mandi, Saharanpur.
Mb:- 09319365499, 09997473484, 09997476919
