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IN THE COURT OF HON'BLE ADDITIONAL CHIEF METROPOLITAN MAGISTRATE, ROHINI, DELHI IN RE: CR.COMPLAINT NO._______ OF 07

IN THE MATTER OF: ABDUL WAHAB S/O SH.HAFIZ MOHD.TASLIM R/O L-1157, MANGOLPURI, DELHI VERSUS 1. SH.RAJAN (OWNER OF RAJAN EXPORT) S/O NOT KNOWN 2. SH.OMI (TEALOR MASTER) 3. SH.DWARKA @ PANDIT JI 4. SON OF SH.RAJAN. ALL RESIDENT OF 1548, BAHADUR GARH, PART-B, RAJAN EXPORT, HARAYANA.

COMPLAINANT

ACCUSED PERSONS

P.S. SULTAN PURI U/S 506/327/352/323/34 IPC CRIMINAL COMPLAINT U/S 190(1)(a) CR.P.C. ON BEHALF OF COMPLAINANT AND FOR ISSUANCE DIRECTION TO REGISTAR A CASE U/S 156(3) CR.P.C. MOST RESPECTFULLY SHOWETH: 1. That the complainant is a peace loving and law abiding citizen of India. He is residing At L1157, Mangolpuri, Delhi.

2.

That the complainant was a contractor in the factory years of the the accused No.1 from last many the

accused

No.1

was

running

abovesaid factory at B-17,Phase-II, Mangolpuri, Delhi, which was presently sifted at the above said address on 20.08.06. 3. That the complainant was a fabricator of the accused No.1, who used to get the clothes from the factory of the accused No.1 and after

stitching returned the same to him and he used to get the stitching and finishing charges from the accused No.1. 4. That the accused No.1 continuously and properly made the payment of the charges of the

complainant upto one years, but the charges for the month of April and May, 2006 amounting to

Rs.80,000/- was not paid by the accused No.1 despite of the repeated demands and request and ultimately even without the knowledge of the complainant he sifted the factory from

Mangolpuri to Bahadur Garh.

5.

That when the complainant came to know that the accused No.1 has sifted his factory to Bahadur Garh, he immediately approached to the accused No.1 and demanded his arrears, but the accused No.1 neglected and avoided the request of the complainant at the one pretext or the other.

6.

That the complainant approached to the accused No.1 at Bahadur Garh on 20.02.07 and showed him necessity of money and requested for the

payment, but the accused No.1 instead of making the payment of arrears call the complainant to come at his previous address at Mangolpuri,

Delhi and assured him for the payment of the arrears on 01.03.07 at 1:00 P.M. 7. That as per the direction of the accused No.1 the complainant alongwith his son namely Munna reached in front of the address given by the accused No.1. The accused No.1 alongwith the accused No.2 to 4 were present there in their car. 8. That when the complainant reached to the

accused No.1 and asked him for the payment of

the

arrears

he

asked

the

complainant

to

handover the original documents bill etc. to him but when the complainant objected and asked him to make the payment first all of them by

using force snatched all the documents from the complainant and forcibly get in the Car, where some blank papers and have got signed was from the

complainant

one

document

got

return

from the son of the complainant stated that the complainant received the dues from the accused No.1 and the the accused No.1 has All no the liability abovesaid

against

complainant.

persons also give beatings to the complainant and his son and extended threats to finish the life, if they approached to the police or

demand the money in future. 9. That the complainant moved a complaint to the SHO, Mangolpuri immediately and the copy of the same was also referred to the Commissioner of Police on 03.03.07 despite of that no action was taken by the Police Officials against the

abvove said persons.

10. That

in

the

above

mentioned

facts

and

circumstances, the accused persons are liable to be prosecuted U/s 506/327/352/323/34 IPC. 11. That the accused persons has committed the

above said offence in the jurisdiction of the police station-Mangolpuri, hence this Hon'ble Court has got the jurisdiction to entertain try and decide the represent complaint. PRAYER: It is, therefore, most respectfully prayed that the Hon'ble and the Court punish may the be pleased to

summon,

try to

accused of law,

persons in the

according

provisions

interest of justice. It is further prayed that a direction to the police officials of P.S. Mangolpuri may be issued to register a case and investigate the same against the above said persons COMPLAINANT DELHI DATED: .03.2007. COUNSEL THROUGH

IN THE COURT OF HON'BLE ADDITIONAL CHIEF METROPOLITAN MAGISTRATE, ROHINI, DELHI IN RE: CR.COMPLAINT NO._______ OF 07

IN THE MATTER OF: ABDUL WAHAB VERSUS SH.RAJAN (OWNER OF RAJAN EXPORT) & ORS. ACCUSED PERSONS LIST OF WITNESSES 1. 2. 3. 4. COMPLAINANT SH.MUNNA S/O SH.ABDUL WAHAB R/O L-1157, MANGOLPURI, DELHI DOCUMENTARY EVIDENCE. ANY OTHER AND FURTHER WITNESS WITH THE PRIOR PERMISSION OF THIS HON'BLE COURT. COMPLAINANT

COMPLAINANT DELHI DATED: .03.2007. COUNSEL THROUGH