+ FOURTH COMPLAINT +
To,
The Chief Minister and Governor of U.P
And
The U.P Administrative Officials and Higher Rank Police Officials deputed,
State:- Uttar Pardesh, INDIA.
Article 350 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
Kindly take needful action on:-
Dinesh Uphadhay/SO, Mobile 08006405241, P.S THANA MANDI,
[Under Officers ASP/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 ancestral property inherited legal rights at Saharanpur Property whose complete postal address is – 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 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 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. 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 & 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 [various unknown people]
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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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 for this the one police officer named “Dinesh Uphadhay” mobile no. 08006405241 has phoned to me Mr KK Agarwal Advocate on my mobile no. 09319365499 at time 10:38AM on dated 24-july-2015 (check mobiles CDR) and threatened & intimidated to me up to six minutes twenty three seconds (06:23) that he will break my bones, implicate me in false bogus cases booked at Thana Mandi (Saharanpur), put me in prison behinds bars, destroy my reputation as an advocate, remove & displace our movable household items from said property premises, get raped all the available two ladies on the “said property” with the help of local hooligans and throw their feeble bodies in the municipality sewage & water canal at Saharanpur and all our relatives in last encountered by him like in Vicky Tyagi case at Muzaffarnagar. That initially hearing of these threatening words I get surprised and shocked that this is the crime prevention UP police unit –or- the some deputed hooligans who dressed in the stylish dress called “police” and getting salary from the Uttar Pardesh government for increasing the crime and finishing & killing the abiding law citizen of India. That the “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 three complaints before this fourth 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 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 fourth complaint which I send to you to take legal necessary prompt action on him and other liable Accuseds whose named are disclosed here in limine 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.
// That in *.PDF Format copies were attached with this fourth compliant and all the “three previous complaints” which had I sent also attached here for once again remind that where it get start and where it is reached now, Kindly download all and take action on it.
Thanking You!
Informants/Complainants
Dated- 26-July-2015
Time:- 10:00 AM
Mr. KK Agarwal Advocate
C/o Miss Kum Kum Goel, Miss Aparana,
Address:- 7/35, Kana Mal Lotiya Mandir, Nearer to Dr AK Jain,
Gaaushala Road, Thana Mandi, Saharanpur.
Mb:- 09319365499, 09997473484, 09997476919
