Monty Khanna, son of RadheyShyam Khanna, is charged as follows: STATEMENT OF
OFFENCE
ASSAULT AND CRIMINAL FORCE WITH INTENT TO OUTRAGE AND INSULT
MODESTY OF WOMAN, contrary to Sections 354 and 509, Indian Penal Code, 1860
PARTICULARS OF OFFENCE
You, Monty Khanna, assaulted and used criminal force with the intention to outrage and
insult the modesty of Ms. Kashish, daughter of Mr. Zorawar Singh, and intruded upon her
privacy on 31 December Yr-1 at the Happy Hotel, New Delhi
STATEMENT OF KASHISH
1. My name is Kashish Singh. My father's name Zorawar Singh. I am 19 years old and my
residential address is Flat No. 5B, Janakpuri, Delhi.2. I have two sisters, both younger to me. One is aged 16 years and the other is aged 14 years.
My father died one year ago. My mother and my paternal grandmother stay with us. I am the
sole earning member of the family.
3. I have been working in a travel agency known as Honeymoon Travels Ltd. since December
15, Yr -1. I am the personal secretary to the Director of the company. I was given to
understand at the time of my appointment that in this line, we employees are expected to stay
back late at work if required.
4. I know Monty Khanna who is the personal secretary to the Managing Director of the
company. He is about 40 years old. He is married and has a daughter my age. He has been
with the company for the last 15 years. Monty Khanna was very friendly when he met me.
Rather, he was over friendly. He used to always compliment me when he saw me. He told me
how nice my hair looks and how smooth and fair my complexion was. He always wanted to
take me out for coffee. On my birthday on December 21, Yr- 1, he even tried to hug me. I
was surprised at such familiarity. He just laughed at my awkwardness and said that I should
consider myself lucky as it was not every girl who could get helped by an influential person
like him. I did not say anything or complain about him as I thought that maybe he is like that
by nature. Also, I had just joined the job and he could have me thrown out of job as he had
been there for 15 years. Nobody would believe me as he was married and had a good
reputation.
5. On December 31, Yr- 1, we all employees were asked to attend the office party organised
to celebrate New Year's eve at Happy Hotel. Monty Khanna told me in the afternoon that he
would pick me up by 7 pm so that we could reach the Hotel by 8 pm, as required. I was
hesitant to go with him but had no option as I do not have a car and did not want to travel
alone at night using public transport. Also, he had his driver with him.
6. As soon as I got in his car, Monty Khanna told me that I was looking gorgeous in my saree.
He had that funny look in his eye. I tried to maintain a normal conversation. We reached the
hotel at about 8.15 pm.
7. The party was organised in the Easy Life restaurant in the top floor of the hotel. As soon as
we got into the lift to go to the top floor, Monty Khanna tried to hold my hand. I pushed it
away and told him to control himself. He pulled me towards him and tried to kiss me. He said
we should enjoy ourselves and that nobody would find out. I started crying for my mother. I
told him that I would scream if he came near me. He then calmed down. l was too shocked
and upset at his conduct to say anything.
8. On reaching the top floor, I rushed out of the lift, scared and terrified. The manager of the
restaurant was surprised to see my fallen face. He asked me what the matter was but I kept
quiet as I was so embarrassed.
9. Throughout the party, Monty Khanna was eyeing me. I felt uneasy about it. I left the party
early and went home. I was too ashamed and worried to tell my mother about the incident.
What she might think. I could hardly concentrate at work. I wanted to kill myself because I
would have to see Monty Khanna at work every day.10. Next day at work, I did not meet Monty Khanna. I was tense the whole day and broke
down when my colleague, Poornima, asked me what was the problem? I told her about it. She
was very angry and told me to complain to the Managing Director immediately about Monty
Khanna.
11. After a week, I told my mother about it. After all, if I kept quiet, he would behave
like that with someone else. My mother talked to my uncle, with whom I went to the police
and lodged my complaint.
Signed ......................... Dated ........... . .............
STATEMENT OF POORNIMA
1. I, Poornima, w/o Rajesh Roshan, r/o 565, Rohini, Delhi, work in Honeymoon Travels Pvt
Ltd as the receptionist. I have been working there for two years now.
2. I know Kashish and Monty Khanna as we work in the same company. Kashish joined the
company very recently, only in December Yr - 1. Monty Khanna was working years before I
joined the company.
3. I am friendly with Kashish, just like I am with other colleagues. We have often had lunch
together. Once, we went out shopping as well. Ever since Kashish joined the company, she
seemed disturbed about Monty Khanna's behaviour towards her. They had to often stay back
late in office for work. Monty Khanna was trying to be too friendly with her, and even flirt
with her. He often asked her out. One day, when he gave her lift home in her car, he even
tried to touch her cheek and held her hand. She did not tell anyone about Monty Khanna's
misconduct as she did not want to loose her job. Kashish also found out on Christmas Eve of
Yr - 1 that Monty Khanna was married and had children.
4. On January 1, Yr 0, Kashish came to the office, very nervous and tense. She obviously had
not slept the entire night. I tried to talk to her several times. Eventually, during coffee break at
about 4 pm, she started crying and told me, in a disjointed manner, that Monty Khanna had
tried to misbehave with her the previous evening in the lift of Happy Hotel. I did not go to
that party as I was celebrating with my husband. I consoled her and told herto report the
matter to the higher officials in writing. She did not want to tell her family as she felt too
embarrassed about it.
Signed .........................Dated . ......... ..... .. ........
STATEMENT OF RAJIV KAPOOR, MANAGER, HAPPY HOTEL
1. I, Rajiv Kapoor, son of. Ramesh Kapoor, resident of 55 Patel Nagar, Delhi, work as
Manager, Easy Life restaurant in Happy Hotel, New Delhi. I have been working there for
about 5 years now.2. I know Monty Khanna. He is personal secretary to the Managing Director of Honeymoon
Travels Pvt Ltd. Monty Khanna often comes to the restaurant. Each time he comes to the
restaurant, he is accompanied by a different young lady. He is a lively man and often gets
intimate with the lady accompanying him. Such behaviour is normally considered
objectionable by the hotel management but as Honeymoon Travels Pvt Ltd. is a good client
of the hotel, I don't think it is my business to intervene.
3. On New Year eve, a party was organised by Honeymoon Travels Ltd at the restaurant.
Monty Khanna came to the party accompanied by a young lady who I had not seen earlier.
She stepped out of the lift, nervous, harassed and upset. I asked her whether I could help her.
She looked away and joined the party. I saw her leave shortly. Monty Khanna left with her.1.I, Monty Khanna, son of RadheyShyam Khanna, resident of 44, Greater Kailash I, New
Delhi work in Honeymoon Travels Pvt Ltd for the past 15 years. I am the personal secretary
of the Managing Director of the company. I am of good character and reputation in the
community. My employers can vouch for me that I have been an exemplary employee and
enjoy a good professional relationship with all the staff.
2. That I am 40 years old and am married. I have a 20 year old daughter. I know Kashish who
just joined the company in December Yr - 1 as personal secretary of the Director of the
company. As she is so young and inexperienced, I tried to encourage her and help her. After
all, she is of the same age as my daughter. I have always had fatherly feelings for her. She too
always looked up to me for encouragement.
3. I became familiar with Kashish because I often used to invite her for a cup of coffee or a
cup of tea. Sometimes we have to stay late in the office but she never objected to anything.
Since she does not have a car, I usually gave her a lift home in my car. She was always
grateful for that. We had such a warm, affectionate relationship. In fact on her birthday on 21
December, she gave me a hug to express her attachment to me.
4. During my interaction with Kashish, I discovered that she was keen for promotion in the
company. She is an intelligent and able young lady. I encouraged her to improve her position
by showing willingness and doing extra work from time to time. That would impress her
managers and might even get attention of the Managing Director. She jokingly said to me that
she might even get promoted to my job soon. I replied that the company would have to fire
me first. Again I was joking with her but I realise now that she was not joking - she is a very
ambitious woman who will stop at nothing to achieve her goal.
5. A day before Christmas, we got late at work. Kashish asked me to give her a lift home. On
the way in my car she began to talk to me about her private life. She started talking to me
about her intimate thoughts. She was depressed because she had no man in her life. She was
emotional and had tears on her cheeks. I reached across and wiped them from her face. I
felt sorry for her and my actions were instinctive in a fatherly fashion. She held my hand for a
long while and said how she would like to have a man like me and she had dreamt of being
with me. I was taken aback by this. I told her that I was married and had a daughter. She got
very upset and disturbed on learning this.
6. Since that day I have tried to be kind to her. I realise that she is going through a difficult
emotional time. I have spent time with her and encouraged her. Her behaviour towards me,
however, has become very odd. She often sits and day dreams at her desk. She looks at me
differently.
7. The office organised a New Year Eve party at Happy Hotel on 31 December Yr - 1. I
offered Kashish that I would pick her up as I knew she had no car. She happily agreed. We
had lighthearted exchanges in the car. My driver, Sanjay, was driving the car. We reached the
hotel about 8.15 pm and took the lift to Easy Life restaurant on the top floor of the hotel.
Suddenly in the lift, Kashish came into my arms and tried to kiss me. I firmly pushed her away saying that I do not appreciate such conduct. Kashish got very upset at my firm stand.
She began crying saying I was uncaring for her feelings. She threatened me by saying that I
would regret my actions and then stormed out of the lift. I followed her.
8. Kashish was quiet and subdued in the party. Though I had rebuked her, I was keeping a
watch on her as I did not want her to do anything drastic. I tried to calm her by telling her that
I did have feelings for her, she was an attractive woman, sometimes one has to be patient -
the future would bring emotional satisfaction and we could continue our good relationship.
She was still upset and angry when she left the party. I followed her and suggested that I
would drop her somewhere near to her house. She did not say anything but walked in the
direction of my car. My driver, Sanjay, opened the door for her and I joined her on the back
seat. During the journey back she had calmed down and we spoke about our day and the work
in a normal manner. We said our goodbyes in our normal familiar way.
9. I only found out about her allegations about 10 days later when the Managing Director
called me in and introduced me to the police officers. I said straightaway that there was a
mistake here - and the Managing Director agreed. He said he would be speaking to the
company's lawyers to sort this out.
10. The allegations against me are false. Although I accept that there were some mutual warm
feelings of affection between us I deny that I molested Kashish or intruded upon her privacy.
I believe Kashish has her own personal emotional problems and, being ambitious, she is after
my job. This is one way in which she can get me out of the way.
STATEMENT OF SANJIV BHATIA, MANAGING DIRECTOR
1. I, Sanjiv Bhatia, S/o Sunil Bhatia, R/o 1/8, Karol Bagh, Delhi - 5, am the Managing
Director of H6neymoon Travels Pvt. Ltd. for past ten years. I know both Ms. Kashish and
Mr. Monty who are working in my company.
2. I state that the working environment in my company is very good and no complaint about
s*xual harassment has been received in this company before the incident under dispute.
3. That on receiving the complaint, I decided to try to resolve the matter amicably. As
Ms.Kashish was very agitated and disturbed at the time of making complaint against Mr.
Monty, we decided to talk to her after some time and sort out the matter.
4. On making further enquiries in the company it seems that Ms. Kashish had a soft spot for
Mr. Monty. The two had got on very well. Ms. Kashish seems to have made her intentions
clear to fellow staff that she would like to know Mr. Monty better as she felt he was the ideal
man for her. I too had noticed that whenever I needed someone to stay back late in office, Mr.
Monty used to suggest Ms. Kashish. As far as I was concerned the two worked very well
together. I always saw them together at one or other's desk often sitting side by side. I have
noticed when leaving the office late at night that they were often the last of my employees to
leave.away saying that I do not appreciate such conduct. Kashish got very upset at my firm stand.
She began crying saying I was uncaring for her feelings. She threatened me by saying that I
would regret my actions and then stormed out of the lift. I followed her.
8. Kashish was quiet and subdued in the party. Though I had rebuked her, I was keeping a
watch on her as I did not want her to do anything drastic. I tried to calm her by telling her that
I did have feelings for her, she was an attractive woman, sometimes one has to be patient -
the future would bring emotional satisfaction and we could continue our good relationship.
She was still upset and angry when she left the party. I followed her and suggested that I
would drop her somewhere near to her house. She did not say anything but walked in the
direction of my car. My driver, Sanjay, opened the door for her and I joined her on the back
seat. During the journey back she had calmed down and we spoke about our day and the work
in a normal manner. We said our goodbyes in our normal familiar way.
9. I only found out about her allegations about 10 days later when the Managing Director
called me in and introduced me to the police officers. I said straightaway that there was a
mistake here - and the Managing Director agreed. He said he would be speaking to the
company's lawyers to sort this out.
10. The allegations against me are false. Although I accept that there were some mutual warm
feelings of affection between us I deny that I molested Kashish or intruded upon her privacy.
I believe Kashish has her own personal emotional problems and, being ambitious, she is after
my job. This is one way in which she can get me out of the way.
STATEMENT OF SANJIV BHATIA, MANAGING DIRECTOR
1. I, Sanjiv Bhatia, S/o Sunil Bhatia, R/o 1/8, Karol Bagh, Delhi - 5, am the Managing
Director of H6neymoon Travels Pvt. Ltd. for past ten years. I know both Ms. Kashish and
Mr. Monty who are working in my company.
2. I state that the working environment in my company is very good and no complaint about
s*xual harassment has been received in this company before the incident under dispute.
3. That on receiving the complaint, I decided to try to resolve the matter amicably. As
Ms.Kashish was very agitated and disturbed at the time of making complaint against Mr.
Monty, we decided to talk to her after some time and sort out the matter.
4. On making further enquiries in the company it seems that Ms. Kashish had a soft spot for
Mr. Monty. The two had got on very well. Ms. Kashish seems to have made her intentions
clear to fellow staff that she would like to know Mr. Monty better as she felt he was the ideal
man for her. I too had noticed that whenever I needed someone to stay back late in office, Mr.
Monty used to suggest Ms. Kashish. As far as I was concerned the two worked very well
together. I always saw them together at one or other's desk often sitting side by side. I have
noticed when leaving the office late at night that they were often the last of my employees to
leave.5. That I have never received any complaint of this nature against Mr. Monty, who has been
with the company for the last 15 years. He has very good relations with other employees of
the company.
STATEMENT OF SANJAY, DRIVER
1. I, Sanjay, S/o Ajay Singh, R/o 21, Pitampura, Delhi, am driver of Mr. Monty Khanna for
the last two years.
2. On 31 December Yr -1, I had taken Mr. Monty Khanna to the Happy Hotel. Before going
to the Happy Hotel, we drove first to Ms. Kashish's house to pick her up. During the journey
to Happy Hotel, they were talking to each other in the pleasant manner. After they went
inside the Hotel, I waited for them in the parking.
3. Mr. Monty and Ms. Kashish came out of the Hotel around 11 p.m. I was waiting for them.
Ms. Kashish came straight to the car. I opened the door for her. She looked tired and did not
acknowledge or smile at me as she normally does when Mr. Monty Khanna gives her a lift
home. She is a very attractive lady and was looking very pretty that night.
4. Mr. Monty Khanna got into the back with her. And the conversation between them was the
usual chirpy talk. I hear that kind of talk between them but it is not my business to listen in
and so I cannot say what they talk about. I just notice that they are always very happy
together. They often joke that they should live with each other since they spend so much time
together and it would mean I could finish my driving in the evening.
