To,

2 are husband and wife as far as the

ordinary social status is concerned
but there is a lot more than what
PS ADARSH NAGAR
that meets the eye. The matrimonial
relationship is just only a shroud
DELHI-110033.
by the virtue of which the accused
gets entry into the society and
SUBJECT : INFORMATION REGARDING A
thereafter the accused no 1 and 2
GANG OF ANTI-SOCIAL ELEMENTS
identify some vulnerable people and
INVOLVED IN FOREGING GOVT.DOCUMENTS accused no 2 takes advantage of her
AND CHEATING IN
gender to implicate anyone whom the
AZADPUR,DELHI-110033.
accused no 1 2 and 3 finds
conservative and shy and can be
Proposed
blackmailed by threats and acts of
ACCUSED NO.1 :Vishnu Kumar bhartia humiliation by public shame.
S/O radhe shyam
C/O. B 31/2 Wazirpur industrial area 5.It is submitted that accused no 3
, Delhi & also(presently) resident is a practicing lawyer and lives in
of somewhere in
very next building on the first
Azadpur/AdarshNagar .
floor of house owned by
complainant's father. The present
Purposed
address of accused no.3 is :house no
Accused no.2:vineeta bhartia
26 , first floor , vidalaya
W/O Vishnu Kumar bhartia road,kewal park , azadpur ,DelhiPurposed
33 .The accused no 3 is also an
Accused no.3:rajesh kumar misra
acquaintance , aide , abettor and
R/O. H.No. 26 , 1st floor , facilitator of offences committed by
vidyalaya road ,kewal park
the accused no 1 and 2 .
Azadpur Delhi-33.
6. It is submitted that the accused
The most respectfully showeth the
no 1 and 2 cheated complainant's
plaintiff/complainant begs to submit father by taking his house on rent
as:
by forgery and cheating with an
intention to defraud him of his
1. That the complainant is residing property and to get any pecuniary
at address 28/45 Punjabi Bagh with
gains in unfair and unjust manner.
his family .
Their after when the tenure of
tenancy expired the accused no 1 , 2
2. The complainant's father and
and 3 in furtherance of their common
mother are retired government
intentions started leveling false
servants and they have earned high accusations on the complainant by
esteem and respect in the society.
themselves fabricating obscene
communication to bring legal injury
3.That the complainant's father owns upon complainant and his family .
a house at 24 vidalaya road kewal
park azadpur delhi.Both of them were 7. That the accused no.1 approached
running a small shop of stationery
the complainant's father requesting
goods in the name of indu book mart him for inducting him as tenant on
and stationers on the ground floor
first floor of his house and he
and rest of the premises were given produced several identity documents
on rent .
to convince and gave the impression
that he is just like a normal couple
4.The accused no 1 and 2 are members .He also told the landlord about the
of a gang of thugs and cheats which details of the past residences &
they have formed among self and
firm with which he was employed in .
along with some of their
The complainant father inducted him
acquaintances . Mo-rover it is also as a tenant via registered rent
submitted that the accused no 1 and agreements no.IN-DL025077290513891
Date:07/11/2015

The SHO ,

DATED 16/02/2010 & INDL04422730180392J dated 04/01/2011

in the office of .deputy.
Registrar ,Pitampura , Delhi for a
period of 11 months and 24 months
respectively .The copies of
registered rent agreement are
annexed herewith as PW Ex. No.
and
PE Ex. .The accused no 1 produced
and showed his voter identity card
as an original document for
convincing landlord .After that the
accused no1 himself provided
photocopy of that voter ID card to
be submitted alongside the police
verification form which the landlord
did. Even the police verification
form was filled in the handwriting
of accused. The receipt of the
submitted police verification form
is exhibit no. Later the complainant
has come to know that the voter
card/ID is a forged document which
has been forged using advanced
computer program/editing software.
8. It is submitted that accused no 3
had taken up the residence in the
same manner in the neighborhood
nearly at the same time when the
accused no 1 and 2 joined the
locality .Mo over the conduct of
accused no 3 leaves no doubt that
the accused no 1 , 2 & 3 are
accomplices and they know about each
other for quite a long time .
9. After the expiry of tenancy the
accused no 1 and 2 refused to vacate
even after a legal notice and
thereafter started harassing the
landlord and his family .It is
pertinent to say that the conspiracy
was started to be implemented as
soon as the accused no 1 took up the
premises on the basis of forged
document. The accused no 2 by the
virtue of her gender promoted enmity
among the two other resident
families and turned them against
landlord .Therefore legal
proceedings had to be initiated and
landlord was dragged in lengthy and
expensive litigation's. Accused no
3 also worked in tandem with accused
no 1 and 2 and in spite of being a
neighbour and and an officer of
court misrepresented facts and

promoted falsehood and worked as a

aide and a facilitator of the crimes
committed by accused no 1 and 2 .
The profession of accused no 3 is
just only a shroud behind which an
bad and defunct member of society
resides whose conduct is unbecoming
of his profession .In spite of
knowing that the complainant and his
family are peaceful citizens the
defendant made the statement both in
vernacular and written to police ,
public as well as to the court of
law in spite of knowing that they
are false,derogatory and bound to
cause injury to virtually anyone
against whom they are claimed.
10. It is submitted that accused no
2 threatened complainant who was
running a business from shop to
implicate him in false and frivolous
criminal cases if they were asked to
vacate .The accused no 2 being a
women started making rumors and
false objectionable statements in
the neighbourhood & caused affray
and as a result of which the
complainant and his father had to
close their shop. The most prominent
of the false allegations was 'inhone
meri beti ko girlfriend kaha' Due to
persistent harassment and threats
the complainant suffered nervous
attack. Since then the complainant
sensed danger and evil intentions of
the accused therefore to avoid any
unnecessary controversy he stopped
coming to his shop and stopped
attending his normal course of
business causing a huge financial
loss. After filing civil suit
against tenant the complainant
father opened up shop for the fear
of being disposed from the
property /third party.
11.Since the absence of personal
visit of landlord's son prevented
them from hurling any direct
allegation , the accused no 1
himself fabricated some offensive &
incriminating anonymous
communication and spread that to the
locality thereby bringing their
dishonest intentions into reality
.The underlying motive and intention
was just to implicate the

plaintiff(only child) so as to make

him a leverage tool upon which they
would defame the landlord and his
family to grab the property of
complainant father or to extort
money thereby causing unjust gain to
themselves and unjust loss to the
complainant and his family .The
complaint application made by the
accused no 1 addressed to the SHO PS
adarsh nagar is annexed as PEx....
no and reading of the plaint in the
light of relevant documents
submitted by the accused shows
clearly that the information is
misconceived and misappropriated
along with false and vexatious
contentions were submitted by the
accused in that complaint to lawful
authorities .In the complaint the
accused states that he is a resident
of this particular lane and locality
from the past 10 years but in police
verification form DATED
26/03/2010 , he submits that his
previous address was C-600,MAJLIS
PARK GALI NO.13.Also in the civil
suit the accused 1 on one hand side
is alleging that the landlord and
his son is a gunda element but on
the other hand is also submitting
that he wishes to continue with the
same landlord in his house .He also
changed his wife name from vineeta
to saroj without following the
lawful procedures. Its quiet
hilarious that a couple wants to
stick to continue living with an
adversary whereas they can take some
other premises on rent somewhere
else after all they are paying rent
and nobody can remain amused and
contented by paying money to
continue to stick with a person whom
he considers as an adversary .This
blow hot and blow cold statements
are also an evidence of
misrepresentation of facts .
11. It is submitted that accused no
2 in tandem with accused no 1 and
facilitated by accused no 3 started
mischief by damaging the property
,intimidation & restraining the
landlord and also launched vicious
attacks both in vernacular and
physical against him . Exhibit No
.is ......... legal notice to stop
doing mischief & notice to vacate

.The landlords complaints against

these acts are exhibit no
12.That since by looking at the
previous conduct of accused persons
i.e. deliberately disseminating
false and fabricated information
aided by the fabrication of forged
Govt. identity documents , conduct
of harassment and intimidation ,
conduct of disrespect shown to the
court of law and conduct by the way
of blackmailing to extort & garner
some kind of unjust material gain
and that of accused no.1 and 2
previous attempts to implicate the
complainant and his family on the
basis of fabricated evidence ,lame
and flimsy excuses shows that all
the accused have taken law for a
ride without any respect for even
the judiciary .
13. It is also imperative to mention
that during civil litigation which
was filed by the plaintiff father in
the court of ADJ Sh. Satish Kumar,
all false pleas and frivolous
contentions of the accused were
dismissed by ADJ and the suit of
complainant father was decreed in
his favour on .24/04/2014
decree/order annexed .On
date ......................the
accused made a submission to vacate
by 26/08/2014 not later than and the
submission is PEx no...
14. The reason of attempt for false
implication of complainant can be
adjudged from the very fact that
after aforesaid submission to the
honourable court the accused no 1
and 2 started hectic and desperate
attempts to bring a police action on
the complainant .At the instance of
accused no 1 and 2 , the complainant
was summoned to the police station
on 7/8/9/10/11 of July 2014.Even the
accused no 2 threatened police staff
of extreme action if they don't
accede to their demands because she
is a lady . All this occurred at the
instance of accused no 3 because he
being a lawyer and aware of new
provisions of criminal amendment act
wherein a conviction can be held on
the oral testimony of a lady

complaining of certain acts. Even on

aforesaid day 10/07/2014 the
accused no 2 threatened to slap the
complainant's mother even in front
of SHO Sh praveen kumar ji of PS
adarsh nagar. Having being failed in
their extortion bid and sensing the
approaching deadline to vacate the
house which they held illegally
accused no 1 and 2 tempered and
destroyed the seals of NDPL
electricity meter installed within
premises Exhibit no ..........It is
imperative to mention that on
11/8/14 the accused no 2 gave a oral
complaint which was reduced into
written by ASI Sh.Raju Yadav ji.In
that complaint accused no 2 apart
from leveling/repeating same false
allegations levied that she usually
makes but also a new allegation of
false & malicious allegations of
tempering of meters allegedly by
landlord who was even not residing
there , thereafter 2-3 days the
complainant father noticed change in
the shape of his electricity meter
and it's box. As soon as the
landlord realized this he informed
NDPL
PEx.
Dated 23/07/2014
This very conduct of accused no 2
leaves no doubt that it is the
accused no 1 and 2 who destroyed
property deliberately so that they
can cause injury and loss to the
landlord who was neither interested
in extending their tenancy nor
submitting to their unlawful demands
. It is also submitted that at that
time of this incident apart from
accused no1 & 2 family no third
person was residing in the demised
premises.
15. The intention for extortion can
also be inferred from the fact that
the accused didn't vacate as he
submitted to the court and instead
claimed that he is keen on
compromise .At the time of clearing
bills in the court he demands
compromise .Ex no...... Therefore he
is admitting to being a perpetrator
to gain by committing certain acts
by themselves by intending to
implicate complainant so that some
settlement in the name of compromise
can be arrived at.

Dishonesty negates all lawful acts

and the dishonesty and evil
intentions are evident from the very
fact that the accused no 1 gave
fabricated identity documents to
take possession of property from
complainant's father & later on
tried to implicate his son by
himself fabricating some
incriminatory evidence to harass
eventually anyone & everyone who
came in their way lawfully.
16. It is also submitted that the
complainant through his counsel came
to know that accused no 1 and 2 had
filed a criminal complaint case
no.45/1/14 in the court of.ld. kapil
kumar MM north west rohini Delhi in
which accused no 3 is their lawyer
against him u/s 156 3 and later
changed that to u/s 200 CrPc and
submitted that he is interested in
prosecuting the complainant for non
cognizable offence
( compoundable ).Mo rover the
accused has failed to present even
an iota of pre-summoning evidence
against him in that criminal
complaint .Also the complainant have
reasons to believe that a criminal
case if also filed against the
former SHO adarsh nagar so as to
cause fear in the mind of that
officer.
This shows that the accused no 2
with the aide and encouragement of
accused no 1 and accused no 3 has
the audacity to paint a sorry and
grieving image on the canvas of
imagination aided by the frequent
media trials of crime against women
particularly after NIRBHAYA incident
and all three accused joined hands
just only to defraud and harass the
authorities and complainant for some
unjust gain. Through their conduct
they have seriously undermined the
value and importance of not only
executive & judiciary but also
womanhood as a whole. Mo rover it is
pertinent to mention that even NIA
during the investigation of bomb
blasts has admitted and proved that
desperate terrorists retort to the
acts of keeping forged identities
.Terrorists have no gender
.Therefore also it is a matter which

concerns not just an

and that is unbecoming the officer
individual(applicant) but it is also of the court .Mo rover all these
concerned with national security .
offences are being perpetrated by
accused no 1 and 2 at the instance
17.The cause of action arose as on
of accused no 3 because only a legal
dated 02/03/2015, the accused no 1
mind is in the know of all these
again mischievously filled a false
procedures whereby something
police complaint against the
incriminatory and tangible is
complainant . Since the complaint
deliberately fabricated and tendered
was false the police took the
to police and the blame of which can
statement from the complainant and
be smeared on the opposite party to
no action was taken against him .
take an edge .It cannot be denied
that the act of posing themselves
18. The cause of action arises
as a normal family in society is
on ........ as the complainant comes just only a shroud under which
to know about another offending and accused gain entry into the society
incriminatory communication made to to commit offences against
the police in the name of his
unsuspecting citizens. It is
father(Baldev Raj) alleging
submitted that such incidents
falsehood for which his parents were happened only when the accused no
summoned by vigilance department at 1 ,2 and 3 took up residence in his
ashok vihar on dated.05/10/2015.It
lane .Nothing of such thing ever
is pertinent to mention that in this happened earlier here though the
communique a reference is also made complainant father is owing this
about HC (adarsh nagar) balkrishan
property from 1984 and virtually
malik because once when the accused each and every third person can
no 2 on dated 13/07/2013 physically vouch for their truthfulness and
restrained the complainant father
peaceful nature.
and locked him in , a call was made
at 100 and persuant to that call it 20.On enquiry the complainant comes
was balkrishan malik ji who rescued to know that the voter id card which
that SR.CTZN and admonished accused was shown in original to
no.2.Ex no....... Therefore the
complainant's father and whose
accused no 1 and 2 fostered jealousy photocopy given by accused no 1 for
against Sh.balkrishan malik ji also police verification is issued in
and so as to cause some injury to
the name of a women(ANITA DEVI) from
him are themselves writing and
the state of rajasthan of which the
posting the objectionable and false accused no 1 and 2 are natives/ab
complaints against anyone and
origins .This is corroborated by
everyone who came in their way
PEx................Also it is very
lawfully.
humbly submitted that according to
the settled proposition of law a
19. That the accused no 1 and 2 are person using forged documents will
continuing to harass the complainant be treated as if he himself has
and his family in one way or the
made/forged them .It is also humbly
another by provocation through
submitted that a person who has the
anonymous communication and trying
audacity to prepare forged
to cause affray.
government records/documents can
also make false private evidences
20.It is most respectfully submitted very easily against unsuspecting
that any person who has the audacity citizens and as such this is
to prepare forged government
happening in this case so as to
documents can also make false
implicate the complainant and to
private evidences very easily to
cause injury to him .It would be
defraud and cheat innocent citizens essential to bring to your notice of
and accused no 3 who in spite of
the fact that
being aware of the real situation is all this is occurring even in spite
portraying something else on reel
of the notification no U-

11036/i/2008 dated 09/09/2010 made

by ministry of home affairs and
declared by resp. ACP u/s 144 CrPc , 07/11/2015
1973.(NO.2 of 1974).
21.Also accused no 2 managed to get
signatures of complainant's father
on a application for voter id and
there also she has miss re-presented
her name as saroj. whereas in police
verification form which was filled
by accused 1 in his own handwriting
shows that her name is vineeta.
Hence deception played on government
authorities by the accused no 2
.None but only a habitual cheater
would tender multiple identities to
government authorities to escape
from the eyes of law enforcement
for achieving their nefarious
designs and ulterior motives. The
acts of the accused are synonymous
to those of the seasoned criminals.
22. These acts of accused are
abhorrent in any civilized society
and as a result of these acts
complainant and his family had to
spend numerous sleepless nights and
their respect and reputation in the
society has taken an irreversible
toll . Mo over it is also submitted
that the applicant & his family has
suffered heavy monetary loss and
also mental stress and agony .The
accused are guilty with their intent
and actions which are totally
unethical ,immoral & unlawful and
also such acts are prejudicial not
just to one individual(complainant)
but to the whole society.
The complainant hereby requests for
the kind attention of thyself so as
to do the needful in view of accused
persons having an evil eye on the
property of the applicant. Mo rover
not just against the complainant but
the accused had committed many
other objectionable things to public
at large which you will get to know
during investigation. Also the
physical well being of the applicant
is at risk.
Yours faithfully &Jai Hind,
Ravi Bhateja .

28/45 Punjabi Bagh west

New Delhi.-110026
Mobile : 9899293039

Attachments Enclosed :
== police verification receipt
== Forged document (voter card) of
accused no.1 having
S.No:RJ/04/027/036261 submitted to
PS adarsh nagar along with police
verification form.
==Details of S.No: RJ/04/027/036261
original voter id in original
according to ECI.
cc:

RESPECTED POLICE
COMMISSIONER
OF DELHI

bcc:

REPECTED DCP DELHI NORTH

WEST
& ACP NORTH WEST.