IN THE COURT OF HON’BLE CHIEF METROPOLITAN

MAGISTRATE, SOUTH EAST DISTRICT , SAKET

COURTS, NEW DELHI
Complaint No 2024

IN THE MATTER OF:

ALPHONSO JOHN
COMPLAINANT
VERSUS

MADAN LAL VERMA & ORS. ACCUSED

PERSONS
P.S. - PUL PRAHALAD
PUR

INDEX

S. N PARTICULARS C. FEES PAGE

1. Memo of Parties

2. Application along with affidavit under section

223 BNSS

3. Application along with affidavit under section

175(3) BNSS

4. List of Documents

5. Vakalatnama

APPLICANT/ PLAINTIFF

DATE : 07/10/24

PLACE : NEW DELHI THROUGH

COUNSEL

Pankaj Kumar Sharma & Associates

Chmaber 456, Saket Court Complex,
New Delhi - 110017
 Mob. No - 9811572309
Email -
[email protected]
IN THE COURT OF HON’BLE CHIEF METROPOLITAN
MAGISTRATE, SOUTH EAST DISTRICT , SAKET
COURTS, NEW DELHI
Complaint No 2024
IN THE MATTER OF:

ALPHONSO JOHN
COMPLAINANT
VERSUS

MADAN LAL VERMA & ORS. ACCUSED

PERSONS
P.S. - PUL PRAHALAD
PUR

MEMO OF PARTIES

ALPHONSO JOHN,
D/O LATE SHRI JOHN GEORGE,
R/O 5BMK, GIRINAGAR,
KALKAJI
NEW DELHI – 110019
COMPLAINANT

VERSUS

1. MADAN LAL VERMA

R/O 8/9, SECTOR- 21D
HOUSING BOARD COLONY,
OPPOSITE POST OFFICE,
FARIDABAD, HARYANA
MOB NO. 921380905,8383885131

2. K.S RAJU,
S/O K.S RAJU@ RAJU SHREE DLALA
R/O GANPATI PROPERTIES,
B – 100/1, VISHWAKARMA COLONY,
M.B. ROAD, NEW DELHI – 110044
MOB NO. 9810457130
EMAIL : [email protected]

3. RAJESH KUMAR (BAILIFF)CODE NO.90081,

NAZARAT BRANCH,NEW DELHI DISTRICT,
PATIALA HOUSE COURT NEW DELHI.

4. PURAN SINGH (RETIRED BAILIFF)

5. S.I GAJENDER PAL

6. AARTI LADY CONSTABLE

7. POLICE OFFICIAL WITH SOME UNKNOWN PERONS

ACCUSED PERSONS
P.S- PUL PRAHALAD PUR

APPLICANT/ PLAINTIFF

DATE : 07/10/24

PLACE : NEW DELHI THROUGH

COUNSEL

Pankaj Kumar Sharma & Associates

Chmaber 456, Saket Court Complex,
New Delhi - 110017
Mob. No - 9811572309
Email - [email protected]
 IN THE COURT OF HON’BLE CHIEF METROPOLITAN
MAGISTRATE, SOUTH EAST DISTRICT , SAKET
COURTS, NEW DELHI
Complaint No 2024
IN THE MATTER OF:

ALPHONSO JOHN
COMPLAINANT
VERSUS

MADAN LAL VERMA & ORS. ACCUSED

PERSONS
P.S. - PUL PRAHALAD
PUR

COMPLAINT UNDER SECTION 223 BNSS READ WITH

SECTION 175(3) BNSS FOR DIRECTION TO SHO/IO TO
REGISTER FIR U/S 318(4)/ 336(1),(4)/ 338/ 340(2)/ 316(2)/
351/ 3(5)/ 61(2) BNS.
MOST RESPECTFULLY SHOWETH:-
1. That the complainant is a peace loving and law abiding citizen
of the Country and has complete faith in the administration of justice
and being aggrieved from the unlawful and illegal actions of the above
named person/accused, the complainant is being compelled to file the
present complaint against the above named person before your good
office and for your kind indulgence.

2. That the complainant is residing at above mentioned address at

presently and the complainant was residing in the rented premises
bearing no.B-90, Top/ 5th Floor Vishwakarma Colony
PulPrahaladpur, NEW DELHI-110044 and the complainant is
permanent resident of Kerala and has been serving Church Jesus Calls
at Connaught place and earn her livelihood.

3. That the Raju/Accused No.2 is Property Dealer in the area of the

Vishwakarma Colony and runs under the name and style as
"GANPATI PROPERTIES" engage in SALE, PURCHASE, RENTING,
COLLOBORATION and for rendering their services that they have
charged Two months commission towards rent amount.

4. That the Property Dealer Raju/Accused No.2 had provided a room

on rent to the applicant . B-90, Top floor, Vishwakarma Colony, N.D-44
for Rs. 5000/- p.m. rent and taken his One month commission and
One month advance. The dealer Raju/Accused No.2 had assured
the applicant that Owner M.L. Verma/Accused No.1 of the flat is not
living here and the Owner M.L. Verma/Accused No.1 is the custodian
of the flat, so you can live or stay as long as you needed. That the
condition of the flat was not good and Dealer Raju/Accused No.2 had
called the Owner M.L. Verma /Accused No.1 in front of the applicant
and at that time, the Owner M.L. Verma/Accused No.1 had given the
permission to repair the house and all the expenses incurred towards
the repair shall be adjusted in the rent and the Dealer Raju/Accused
No.2 had assured the complainant that all your expenses will be
adjusted in monthly rent and the complainant had install water
motor. gate and install iron-jaali and other repair the applicant
thought that the applicant will spend her rest of life peacefully here as
narrated and assured by the accused No.2. The applicant has
spend more than Rs.200000/- (Two lakh only) in the repairing of the
flat from roof to gate and the complainant had given all the repaired
bills to the dealer Raju/Accused No.2 and the dealer assured the
applicant that you had given all the repair bill to me Raju/Accused
No.2 and the owner M.L. Verma/Accused no.1 shall made the
payment when you vacated the premises or adjusted the repair
amount in regularly rent.

5. That It is pertinent to mention here that no rent agreement was

executed even the complainant was requested for rent agreement
but the accused No.2 always ignored the same one pretext or the
other, after Eleven months of tenancy the dealer Raju/Accused No.2
had come to the complainant and asked the applicant to sign the Rent
Agreement of the last year i.e. 2019 for the purpose of record and the
applicant was not aware with the intention of the dealer
Raju/Accused No.2 and Owner M.L.Verma/Accused No.1 signed the
agreement which was witnessed by the Dealer Raju/Accused No.2
itself and the Owner M.L. Verma/Accused No.1 had not signed the rent
agreement but the agreement was duly notarized prior to the
applicant signature and the rent agreement produced by the owner
in the eviction case against the applicant was duly singed by the
owner both the rent agreement are annexed herewith as
Annexure- A & B.

6. That it is pertinent to mention here that the dealer Raju/Accused

No.2 was collecting the monthly rent from the applicant and Owner
M.L. Verma/Accused no.I had never visited the flat and the applicant
was requesting the dealer Raju/Accused No.2 to start adjusting the
repair money from the rent but the dealer Raju/Accused No.2 kept
ignoring the same on one pretext or other. The dealer Raju/Accused
No.2 always assured the applicant that let the Owner M.L.
Verma/Accused No.1 come to Delhi and he shall pay your repaired
amount of Rs. 2 Lakhs. The complainant did not meet the Owner M.L.
Verma/Accused No.1 of the house.

7. That the applicant/complainant after expiring of the false,

fabricated and forged agreement asked the dealer Raju/Accused No.2
to renew the rent agreement and asked the dealer Raju/Accused No.2
to issue rent receipt for the sake of safety and further requested to
endorse the repair receipt too, but the dealer Raju/Accused No.2
again assured the applicant that you don't panic that the money will
be refunded as soon as the Owner M.L. Verma/Accused No. I come to
Delhi and the Dealer Raju/Accused No.2 for the satisfaction of the
applicant had made the entries by his own handwriting on blank
papers as receipt. The copy of the rent receipt given by the Accused
No.2 is annexed hereby as Annexure-C.

8. That at the time of taken the flat, the Dealer Raju/Accused No.2
and the Owner M.L. Verma/Accused No.1 had smartly fooled the
applicant in their sweet words and assurances and the repair of
the flat was conducted through tenant and condition of the
Property bearing No. B-90, Top Floor, Vishwakarma Colony. New Delhi-
110044, was not so good condition and there was a leakage/seepage
from the ceiling of the house and there is no main front gate at 5th
Floor stairs so, the bad persons/local goons used to comes to the
roof property and where they are play cards and drink alcohol and
chew Gutka, tobacco and spit here and there which blocked the pipe
and water had come into the room of the applicant, due to this
condition, the applicant had narrated all the story to the property
dealer i.e. Accused no.2 and thereby the applicant had also installed
gate at Stair on the 5th floor for stoping the illegal activities at the
roof. The photograph of the house is hereby annexed as Annexure-D
& E (colly).

9. That the applicant had enquired from the accused No.2 that you
have given the bills to the Accused no.1, the Dealer Raju/Accused
no.2 said that he had shown the bills of the repairing of the house to
Owner M.L.Verma/Accused No.1 and the Owner M.L.
Verma/Accused No.1 of the house is not agree with the bills and
Owner M.L. Verma/Accused No.1 of the house is totally denied
regarding the money invested by the applicant some of Rs.200000/-.

10. That After this, the Dealer Raju/Accused No.2 are deliberately
and intentionally avoiding the applicant for her repair money and
giving time on one pretext or the other to the applicant and the
applicant had already invested her hard earned money in the property
of the Owner M.L. Verma/Accused No.1 on the words of his agent
Raju/Accused No.2 with assurance of the Owner M.L.Verma/Accused
No.1.
11. That this is the clear case of cheating and conspiracy hatched
by the Owner M.L. Verma/Accused No.1 and dealer Raju/Accused
No.2 to dupped and grabbed the applicant hard earned money. The
applicant had moved a complaint in this regard vide DD No. 102K
dated 19.04.2021.

12. That After all this happen, the applicant came to shock and
surprise that he received a notice from the Owner
M.L.Verma/Accused No.1 of the house for not receiving the rent of the
house from the period of March, 2020 to October, 2020.

13. That the applicant then apprised the same to the dealer and the
dealer Raju/Accused No.2 didn't reply to the enquiry of the
applicant and Raju/Accused No.2 changes his character and start
abusing the applicant and threatened the applicant to kill and asked
the applicant never come to me again. The applicant requested the
dealer Raju/Accused No.2 that to clear the misunderstanding
between the applicant and the Owner M.L.Verma/Accused No.1 but
the Owner M.L.Verma /Accused No.1 sending the legal notice to the
applicant and when the applicant asked dealer Raju/Accused No.2
that the dealer Raju/Accused No.2 talked the Owner M.L
Verma/Accused No. 1 clear his doubts about the Rent and adjusted
my repair money from the rent by the Owner M.L.Verma/Accused
No.1. That after pressurizing a lot. Raju/Accused No.2 assured the
applicant that he will disclose all the facts and stand with you
wherever the applicant wants. further the Owner M.L.Verma/Accused
No.1 also assured that he had words with him and solve the issue of
rent and repaying payment the house and seeks time for the same.

14. That the applicant receives summons from the court and
appeared before narrated the whole story to the Court where the
Accused No.2/Raju didn't appear before this Hon'ble Court and the
Hon'ble Court has been passed an order of eviction for non payment of
rent and for the same, the applicant has been evicted by the court
order through its warrant of attachments. And the applicant had
invested her hard earned money for the repair of the house only for
the Owner has given me assurances that the rent will be adjusted
after repairing the house and the applicant has been duped by the
Owner M.L.Verma/Accused No.1 of the house and Raju/Accused No.2
for which the applicant has been lost of Rs.2,00,000/-.

15. That the applicant has narrated the whole story and the
unethical approach and conduct of the above said persons who misuse
my trust, cheated the applicant by their conduct and further the above
name person had in connivance with Owner M.L.Verma/Accused No.1
had caused huge loss to the applicant. The applicant has usurped my
hard earned money. amounting of Rs.2,00,000/-(Rs. Two Lakh Only).
The Accused persons pursuant to their ill intentions and motives have
not only cheated and criminally breached my trust and usurping my
hard earned money but has caused wrongful gain to themselves and
wrongful loss and injury to me.

16. Court appointed Rajesh but Puran singh also came in

connivance with Shri Madan lal Verma i.e, Puran singh is retired
court person and did all the work of eviction and prepared a wrong
and incomplete list.

17. Rajesh, the bailiff taken the articles of my house including the
utensils and jewellery and thrown away the article from the 5th
floor to the ground and almost all articles were broken and
jewellery are taken in his possession. The labourers of the decree
holder who has brought with him for eviction of said house all the
articles taken and left by police officials and bailiff and decree
holder.

18. Kavita and Vishal also taken all the cloths, utensils and took
ration and 350 kg rice, 62 kg kali Mirch and left from my house by
the kavita and Vishal. And also by her kavita's relatives i.e,
(husband, husband's brother, mother in law, father in law).

19. The police staff taken the mobile phone forcibly taken the
phone by police official Naresh, from the beat, he belongs to my
police beat area. P.S pul prahaladpur. That the private guard of B
Block Vishwakarma colony, pulprahaladpur, New Delhi did not
perform his duty properly and come to influence of the decree
holder. Regarding the conduct of the bailiff and police official,
complainant went to the police station P.S Prahaldpur with
complaint but duty officer refused to take the same there after
complainant want to meet S.H.O/P.S Prahaladpur and S.H.O also
threatened the complainant. there after complainant went to D.C.P
S.E and gave her complaint dated 15/12/22 and the same is
hereby is annexed as Annexure - F

20. That the complainant has filed the complaint under section
156 (3) of Cr.P.C. at P.S. Govind puri in the Sh. Ashwini Pawar, Ld.
MM. South East, New Delhi and again filed at PS kalkaji in the Ld. Sh.
Raghav Sharma Id. MM. Delhi wherein the Id. Court granted the
permission to withdraw the complaint from this Court because of the
lack of jurisdiction and the Id. Court has allowed the complainant
with liberty to file a fresh complaint before the competent court
vide order dated 19.09.2023. The complainant there after gave the
complaint to the police officilas from S.H.O, Commissioner of Police,
D.C.P Viggilence Branch, Ministry of Home and Station House Officer.
And the complaint and the postal receipt and tracking report of the
complaint hereby annexed as Annexure - G&H

21. That one Madan Lal Verma had filed one civil suit for recovery of
possession as well as recovery of rent amount against complainant
which suit was decreed against complainant and after obtaining a
decree of possession and recovery of money against complainant,
the said Shri Madan Lal Verma, filed one execution petition for the
issuance of the warrants of possession as well as warrants of
attachment in respect of the said decree therefore obtained by accused
no.1 against complainant.

22. That being aggrieved by the said judgment and decree

obtained by Madan Lal Verma against complainant , I had already
preferred an appeal against the same which appeal is still pending
befor the Honb’le Court of Delhi.
23. That notwithstanding the pendency of the said appeal, the
said Madan Lal Verma approached the Hon'ble Court for issuance
of warrants of possession as well as warrants of attachment for
executing the said judgment and decree and on the affidavit being
filed by him that there is no stay order in operation in respect of the
appeal filed by the complainant against the said judgment and
decree, the Ld. Court vide its orders dated 16.09.2022 was pleased
to direct the said Madan Lal Verma (land lord) to appear before the
Ld. A.C.J., South East District, Saket Courts, New Delhi, on
26.09.2022 for appointment of the bailiff and for the report before
the said Court on 09.12.2022. Further on the request of the said
Madan Lal Verma, it was also directed that the said bailiff shall be
competent to obtain the police aid (both male and female) for the due
execution of the said warrants of possession as well as warrants of
attachment.

24. That on 26.09.2022, some bailiff was appointed by the Ld.

A.C.J., South East District, Saket Courts, New Delhi, and immediately
on the very next day, the said bailiff, in collusion and connivance with
the said Madan Lal Verma(DH) along with various police officials from
the local police station, headed by A.S.I. Gajender Pal, came to my
premises at about 10.30 p.m. and forcibly entered into my house and
started throwing my goods and articles lying in the said premises from
the fifth floor to the ground floor in order to cause damage to the said
goods and articles. Not only this, they also took forcible possession
of various valuable articles lying in the said house belonging to me as
well as jewellery of my friends lying in the house which were entrusted
to me by my friends while leaving for Saudi Arab in connection with
the job. Not only this, the said A.S.I. Gajender Pal in collusion and
connivance with the said i Madan Lal Verma, started hurling filthy
abuses me and held out threats that in case any obstruction or
hindrance is being created by me in the aforesaid unlawful and illegal
acts and actions on the part of the bailiff and the police officials in
collusion and connivance with Madan Lal Verma, in that event, the
said police officials would involve me and my other family members in
false and frivolous criminal cases. Not only this, when I was preparing
a video of their unlawful and illegal acts from my mobile phone,
the lady constable namely Aarti has twisted my hand and caught hold
of me by my hairs and started slapping me furiously for making the
video where they were destroying the articles and one of the said
police officials namely Suresh snatched my mobile phone and keep
it in their hand so that I may not be able to capture their unlawful and
illegal acts and the video already recorded by me, must have been
destroyed by them to save their skin. However till today, I haven't got
my phone from the police officials and if any-thing happen wrong with
my phone, the erring police official will be responsible for this and
A.S.I Sh. Gajender Pal has said when I requested him to save my other
article but the ASI said that if you give me Rs. 30,000/-, no one will
harm you and your articles but i showed by incompetency for the
same and they didn't stop their foul play.

25. That thereafter, the said police officials in collusion and

connivance with the bailiff so appointed by the Ld. Court as well as
Madan Lal Verma, damaged my goods and articles lying in the said
premises and after damaging my goods and articles, left the said
premises while taking away valuable goods and articles including
jewellery and 350 k.g. of rice, 62 k.g. of Kali Mirch lying in the said
premises and further locked the said premises from the outside and
thrown me from the said house. Most of my goods and articles
worth more than Rs.2,00,000/- (Rs. Two lakh) are still lying in the said
house but I was not allowed to take out my goods and articles
including my wearing apparels lying in the said premises and the said
Shri Madan Lal Verma in collusion and connivance with the local police
as well as bailiff so appointed by the competent Court of jurisdiction,
held out threats of my life and property while throwing me out from
the said premises. Due to fear of threat of falsely implicated in the
case by one of the police official SHO Sanjay Dahiya, PulPrahaladPur, I
am so feared and restlessness and traumatized by the conduct and
behaviour of appointed bailiff and erring police officials but today I
have come to the court on my date and write this complaint.
26. That the most important thing, I have placed you that All the
aforesaid unlawful and illegal acts and actions on the part of the
bailiff and the erring police officials in collusion and connivance with
Madan Lal Verma recorded in the four camera and this was recorded
by camera of the Delhi government which was on the pole of the
street and this was the proof of my said statement and save and
preserve the CCTV footage for your future reference and two witness
namely Jeevan and Rajesh both are working there for proving my
statement. And Two photograph wherein the Bailiff namely Rajesh
and a lady constable namely Aarti is annexed as Annexure - I

27. That the applicant had visited the concerned Police Station,
Prahlad Pur, New Delhi but all in futile as police official did not allow
the applicant to meet the higher police officials but on 28.09.2022, the
applicant met with the SHO Sanjay Dahiya and narrated him the entire
incident happened on 27.09.2022 and requested the SHO for
providing the articles and mobile phone seized by the errant Police
Officials but the applicant came to utter surprise when SHO rebuked
the applicant and said don't utter lie before me and never narrate your
story to anyone else, otherwise the applicant will face dire
consequences and further threatens the applicant not to come again
with your complaint.

28. That from the aforesaid facts and circumstances, it is crystal

clear that the said bailiff so appointed by the Hon'ble Court as well as
the local police had not performed their official duties properly and
had acted in collusion and connivance with Shri Madan Lal Verma and
hence appropriate legal action in accordance with law is required to be
taken against the bailiff as well as the erring officials of Delhi Police PS
Pulprahladpur and they be ordered to be prosecuted and punished for
the serious offences so committed by them and my goods and articles
forcibly taken possession by the bailiff preparing wrongly mentioned
article list, be ordered to be restored back to me and further I may be
allowed to take out my goods and articles lying in the said premises
which were not allowed to be taken out by the bailiff while taking
the possession of the said premises in execution of the warrants
of possession and attachment so issued by the Hon'ble Court, hence
the present application.

29. That the complainant after seeing the behavior of the

accused no.1 got shocked and surprised and went to PS
PulPrahladpur police officials to register a complaint against the
accused No.1 and No.2.

30. That it is clear from the facts and circumstances that since
the beginning all the accused persons have intention to cheat the
complainant with conspiracy with each other.

31. That all the accused persons with their common intention and
by hatching a conspiracy have committed the offences, for which
they are liable to be punished according to law.

32. That when no alternatives was found by the complainant, accept

he came to this Hon'ble Court to get justice.

33. That the Complainant is residing in Delhi at the above noted

address and the offences are also committed by the accused persons
within the local limits of this Hon'ble Court and hence the Hon'ble
Court has got the jurisdiction to entertain, try and adjudicate the
present matter under the appropriate provisions of law.

34. That it is settled law laid down by the Hon'ble Supreme Court in
the catena of cases that where a verbal or written complaint discloses
a cognizable offence, the police official are duty bound to register the
case and investigate the matter thereafter. Inspite of the settled
preposition of law, the police official did not take action against the
accused persons a for reasons best known to them.

35. That the copy of the said order is hereby annexed as

Annexure - K

PRAYER

In light of the above-mentioned facts and circumstances, it is most

respectfully prayed that this Hon'ble Court may kindly be pleased
to:

a) Summon, try, and punish the above-named accused persons

under Sections 318(4)/ 336(30/ 338/ 340(2)/ 316(2)/ 351(2)/
3(5)/ 61(2) BNS, in the interest of justice.

b) Conduct an investigation into the unlawful actions of the bailiff

and Delhi Police officials who acted in collusion with the
accused. Appropriate legal action should be taken for the
offenses committed. The Court is requested to order the return
of my goods, including my mobile phone, which were seized
without inventory, and allow me to retrieve the remaining items
from the premises during the execution of the possession and
attachment warrants.

c) Pass any other or further order(s) and grant any other relief(s) that
this Hon'ble Court may deem fit and proper in favor of the
complainant and against the accused persons, in the interest of
justice.

APPLICANT/ PLAINTIFF

DATE : 07/10/24

PLACE : NEW DELHI THROUGH

COUNSEL

Pankaj Kumar Sharma & Associates

Chmaber 456, Saket Court Complex,
New Delhi - 110017
Mob. No - 9811572309
Email - [email protected]
IN THE COURT OF CIVIL JUDGE, (JUNIOR DIVISION), SOUTH
EAST SAKET NEW DELHI.

COMPLAINT NO. of 2024

IN THE MATTER OF:

ALPHONSO JOHN
COMPLAINANT
VERSUS

MADAN LAL VERMA & ORS. ACCUSED

PERSONS
P.S. - PUL PRAHALAD
PUR

AFFIDAVIT
I, Alphonso John aged about 50 yrs D/O John George, H/O 5
B.M.K, Girinagar, Govindpuri, Kalka ji, New Delhi- 110019, do
hereby solemnly affirm and declare as under:-

1. That I am the plaintiff in the above mentioned suit and I am

well conversant with the facts and circumstances of the
case and am competent to swear the present affidavit.

2. That the accompanying application for complaint under

section 175(3) has been drafted by my counsel under my
instructions and the contents of the same have read over to
me in my vernacular language and the same is true and
correct. The contents of accompanying application may
kindly be read as part and parcel of this affidavit and same
are not reproduced herein for the sake of brevity.

DEPONEN
T

VERIFICATION
Verified at New Delhi on this day of October, 2024 that the
contents of the above affidavit are true and correct to the best of
my knowledge and nothing material has been concealed
therefrom.

DEPONENT
 IN THE COURT OF HON’BLE CHIEF METROPOLITAN
MAGISTRATE, SOUTH EAST DISTRICT , SAKET
COURTS, NEW DELHI
Complaint No 2024

IN THE MATTER OF:

ALPHONSO JOHN,
D/O LATE SHRI JOHN GEORGE,
R/O 5BMK, GIRINAGAR,
GOVINDPURI, KALKAJI
NEW DELHI – 110019 COMPLAINANT

VERSUS

1. MADAN LAL VERMA

R/O 8/9, SECTOR- 21D
HOUSING BOARD COLONY,
OPPOSITE POST OFFICE,
FARIDABAD, HARYANA
MOB NO. 921380905,8383885131

2. K.S RAJU,
S/O K.S RAJU@ RAJU SHREE DLALA
R/O GANPATI PROPERTIES,
B – 100/1, VISHWAKARMA COLONY,
M.B. ROAD, NEW DELHI – 110044
N.MOB NO. 9810457130
EMAIL : [email protected]

3. RAJESH KUMAR (BAILIFF)CODE NO.90081,

NAZARAT BRANCH,NEW DELHI DISTRICT,
PATIALA HOUSE COURT NEW DELHI.

4. PURAN SINGH (RETIRED BAILIFF)

5. A.S.I GAJENDER PAL

6. AARTI LADY CONSTABLE

7. POLICE OFFICIAL WITH SOME UNKNOWN PERONS

ACCUSED PERSONS
P.S- PUL PRAHALAD PUR
COMPLAINT UNDER SECTION 175(3) BNSS FOR TAKING
COGNIZANCE U/S 318(4)/ 336(1),(4)/ 338/ 340(2)/ 316(2)/
351/ 3(5)/ 61(2) BNS.

MOST RESPECTFULLY SHOWETH:

1. That the complainant is peace loving and law abiding citizen of

India and residing at the above noted address.
2. That the complainant resides at the address mentioned and
previously rented the premises at B-90, Top/5th Floor,
Vishwakarma Colony, New Delhi, and is a permanent resident of
Kerala, earning a livelihood from the Church Jesus Calls at
Connaught Place.
3. That the complainant rented a room from property dealer Raju
(Accused No. 2) at B-90, Top Floor for ₹5,000 per month, with
assurances that the owner, M.L. Verma (Accused No. 1), was
not living there. The complainant spent over ₹200,000 on
repairs, which Raju promised to adjust against rent.
4. That after despite requests, no formal rent agreement was
executed initially. After eleven months, Raju asked the
complainant to sign a backdated agreement, which was
notarized without M.L Verma's signature. Raju collected rent but
ignored requests for repair cost adjustments and misled the
complainant about M.L Verma's willingness to reimburse the
repair expenses.
5. That when the complainant sought to renew the agreement and
obtain receipts for repairs, Raju provided handwritten notes
instead. The flat had significant issues like ceiling leaks and
security vulnerabilities, which the complainant addressed
independently.
6. That after the false agreement expired, the complainant
received a notice from M.L Verma for unpaid rent. Raju became
abusive when informed and failed to resolve the issue. The
complainant later received a court summons and was evicted
 due to non-payment of rent, despite having invested in repairs
based on assurances from both accused.
7. That the situation reflects a clear case of cheating and
conspiracy between Raju and M.L Verma, resulting in a loss of
₹200,000 for the complainant. Complaints were filed with
authorities regarding this misconduct.
8. That additionally, during the eviction process, bailiff Rajesh
mishandled the complainant's belongings. Police officer Naresh
confiscated the complainant's mobile phone unlawfully. The
complainant has filed multiple complaints under Section 175(3)
of BNSS, with ongoing legal proceedings against M.L Verma for
recovery of possession and rent. An appeal against M.L Verma's
decree is pending in court.
9. That on 26.09.2022, a bailiff appointed by the A.C.J. at Saket
Courts, in collusion with Madan Lal Verma and police officials
led by A.S.I. Gajender Pal, forcibly entered the complainant's
home at around 10:30 p.m. They threw the complainant's
belongings from the fifth floor, damaging many items, and took
valuable goods, including jewelry entrusted to the complainant
by friends. A.S.I. Gajender Pal verbally abused the complainant
and threatened legal repercussions if they resisted.
10. That after while attempting to record these illegal actions on
video, police constable Aarti assaulted the complainant and
another officer snatched their phone, likely destroying any
evidence. The complainant was offered protection for ₹30,000
but refused. The police officials left after damaging property
and taking away items worth over ₹200,000, locking the
premises and preventing the complainant from retrieving
personal belongings.
11. That the complainant reported these events to the
Pulprahaladpur Police Station but faced obstruction when trying
to meet higher officials. On 28.09.2022, they met with SHO
Sanjay Dahiya, who dismissed their claims and threatened them
against further complaints.
12. That after these actions indicate a clear conspiracy among
the bailiff, police, and M.L Verma to unlawfully dispossess the
complainant. The complainant seeks legal action against these
officials for their misconduct and demands the return of their
property and access to their belongings left in the premises.
13. That additionally, CCTV footage recorded by a government
camera may serve as evidence of these unlawful acts, with
witnesses available to corroborate the complainant's account.
The complainant emphasizes that despite attempts to report
these offenses, police inaction suggests collusion among the
accused parties.
14. That the complaint under section 223 BNSS read as a part
and parcel of the present application.

PRAYER

The complaint therefore prays that the Hon’ble Court may be

pleased to give order to SHO/IO/P.S Pulprahaladpur to register the
FIR against the accused persons in the interest of justice.

APPLICANT/ PLAINTIFF

DATE : 07/10/24

PLACE : NEW DELHI THROUGH

COUNSEL

Pankaj Kumar Sharma & Associates

Chmaber 456, Saket Court Complex,
New Delhi - 110017
Mob. No - 9811572309
Email - [email protected]
IN THE COURT OF CIVIL JUDGE, (JUNIOR DIVISION), SOUTH
EAST SAKET NEW DELHI

COMPLAINT NO. of 2024

IN THE MATTER OF:

ALPHONSO JOHN
COMPLAINANT
VERSUS

MADAN LAL VERMA & ORS. ACCUSED

PERSONS
P.S. - PUL PRAHALAD
PUR

AFFIDAVIT

I, Alphonso John aged about 50 yrs D/O John George, H/O 5

B.M.K, Girinagar, Govindpuri, Kalka ji, New Delhi- 110019, do
hereby solemnly affirm and declare as under:-
 3. That I am the plaintiff in the above mentioned suit and I am
well conversant with the facts and circumstances of the
case and am competent to swear the present affidavit.

4. That the accompanying application for complaint under

section 175(3) has been drafted by my counsel under my
instructions and the contents of the same have read over to
me in my vernacular language and the same is true and
correct. The contents of accompanying application may
kindly be read as part and parcel of this affidavit and same
are not reproduced herein for the sake of brevity.

DEPONEN
T

VERIFICATION
Verified at New Delhi on this day of October, 2024 that the
contents of the above affidavit are true and correct to the best of
my knowledge and nothing material has been concealed
therefrom.

DEPONENT
IN THE COURT OF CIVIL JUDGE, (JUNIOR DIVISION), SOUTH
EAST SAKET NEW DELHI.

COMPLAINT NO. of 2024

ALPHONSO JOHN
COMPLAINANT
VERSUS

MADAN LAL VERMA & ORS. ACCUSED

PERSONS
P. S. - PUL PRAHALAD
PUR

LIST OF DOCUMENTS

S. NO PARTICULARS PAGES

1. The copy of the Rent Agreement between the complainant

and the Accused persons as without singing of the owner
of the house as Annexure - A

2. The copy of the Rent Agreement between the Complainant

and the Accused persons as singing of the owner of the
house as Annexure - B

3. The copy of the Rent Receipt as Annexure - C

4. The photograph of the household article of the

Complainant and photocopy of the condition of the house
as Annexure - D&E

5. The copy of the complaint given to D.C.P South East dt.

15/12/22 as Annexure - F

6. The complaint and the postal receipt and tracking report of

the complaint as Annexure - G&H

7. The photograph of the Bailiff namely Rajesh and a lady

constable namely Aarti as Annexure - I

8. The copy of the said order as Annexure - K

 APPLICANT/ PLAINTIFF

DATE : 07/10/24

PLACE : NEW DELHI THROUGH

COUNSEL

Pankaj Kumar Sharma & Associates

Chmaber 456, Saket Court Complex,
New Delhi - 110017
Mob. No - 9811572309
Email - [email protected]