Dated 19th May 2019

From:-
Mr. Surendra G Gowda
404, Namaskar CHS,
Plot no-191,Sector-3,
Airoli, Navi Mumbai – 400705
Mob No. 9742223035

To,
1) The Commissioner of Police Navi Mumbai
Opposite RBI, Sector – 10 CBD- Belapur,
Navi – Mumbai 400 614.

2) The Deputy Commissioner of Police

Plot No. 180, Sector 19C, APMC Market Vashi
Near Y J Petrol Pump Zone 1
Vashi, Navi Mumbai

3) The Assistant Commissioner of Police (Vashi Div)

Plot No. 180, Sector 19C, APMC Market Vashi
Near Y J Petrol Pump Zone 1
Vashi, Navi Mumbai

Sub :- Complaint to lodge F.I.R U/s. 154 Crpc for offences U/s. 420, & 403 of I.P.C.
Accused -
1. Mr. Narayan S Aadakar
2. Mr. Ramesh M. Paradkar
3. Mr. Manoj S.Parulekar
4. Mr. Amar S.Khot
5 Mr. Ankush R. Kashid
6. Mr. Sanjay B. Pansare
7. Mr. Tushar B. Ugomuge
8. Mr. Kanifanya S.Tambe
9. Mr. Gosavi
10. Mr.Jayshri J. Chougule
11. Mr. Nitin Arun Takke
12. Mr. Chandrakant A. Malakar
13. Mr. Vijay S. Jain
14. Mr. Rakesh S. Jain
15. Mr. Vinod M.Jain
16. Mr. Premlata V.Jain

All having address at :-

Namaskar CHS,
Plot no-191,Sector-3,
Aroli, Navi Mumbai – 400705
 Respected Sir,
Dear Sir
I, the undersigned Mr. Surendra G Gowda do hereby state the facts of the offence
committed by the aforesaid accused as under:-

1. I say that I am working in a private company at the manager level, and is permanent
resident of Navi Mumbai having residential address at: 404, Namaskar CHS,
Sector-3, Plot no-191, Aroli, Navi Mumbai-400705.

2. I say that I have huge support of people and earned a great reputation due to my
involvement in providing social services. Due to the social activities, and also
enjoys a lot of goodwill and reputation in the society.

3. I say that the accused are the resident and members of the Namaskar CHS Ltd.

4. I say that in the month of June 2016 after the sad demise of my father Mr. Gopal
Gowda I along with my family shifted from Bangalore to Airoli to take care of my
Widow Mother. .

5. I say that in the year 1999 when the my father had purchased the flat no.404,
Namaskar CHS Plot no-191,Sector-3, Airoli, Navi Mumbai -400705 (herein
referred as the said property) at that time my father along with the Flat had
purchased the slit parking space from the builder i.e. M/s Jaykaybee Construction. I
say that my father had duly paid for the slit parking space which is clearly stated in
the Statement of Accounts dated 24th February 1999 issued by M/s Jaykaybee
Construction in the favour of my father.

6. I say that even after making all the payment related to the slit parking space for the
said property till date the builder has not handed over the peaceful possession of the
slit parking space to me.

7. I say that being the co-owner in the said property I had made few complainants and
notices to Managing Committee of the society to handover the peaceful possession
of the slit parking space but till date there is no outcome of the said notices and
complainants made towards the said issue.

8. I say that being aggrieved by the builder I had no other option but to file a case
against M/s Jaykaybee Construction in the month of January 2019 and FIR has been
successfully logged against the builder M/s Jaykaybee Construction filed with
Rabale Police station FIR bearing no.0072 dated 22/01/2019 under section 420 for
not allotting the slit parking space for the said property. .

9. I say that in the year 2016 I came to stay in the Namaskar CHS and my legal slit
parking space was illegally used and given to other member of the society. I say that
after that I made several complaints to the Managing Committee of the Society but
 the Society did not have any heed to my request, I then started inquiry about the
day-to-day affairs of the Managing committee of the society, the complainant after
going to the society documents found irregularities in the funds and accounts of the
society.

10. I say that after going through the society records the complainant found that the
society funds where been misappropriated for personal gain by the society members
for their own benefits, which I highlighted in front of the managing committee but
the managing committee was least bother about the issued raised by me.

11. I say that after knowing the fact that the society funds where been misused by the
society managing committee, I wrote an letter to Shri Sanjay Kumar, IPS,
Commissioner of Police Navi Mumbai and Shri Tushar Doshi IPS Dy.
Commissioner of Police of Crime and EOW for investigation of the Audit report of
Namaskar CHS and misappropriation of funds.

12. I say that 11.01.2019 around 10.05 pm my mother Smt Mugdha G Gowda, senior
citizen aged 66 years was abused and called out from the flat door steps to society
premises on ground floor and one Mr. Pravin J Chougule pulled the plastic chair
and threw on the my mother but it missed her and then slapped and abused her in
filthy language and in mean time Mr. Ankush Kashid pushed behind my mother on
floor because of which she got hurt and was weeping and calling for help. After the
above said incident Police constables arrived and rescued to Rabale Police station
and an NCR was noted and my mother was sent back to home, the moment my
mother reached society's back gate mob started threatening to wipe my family and
was shouting "KILL TMY MADARASAI AND CHOP OFF, CHOP OFF".

13. I say that he and my whole family was defamed and insulted in front of the whole
Namaskar CHS which is very depressing for their family. I say that my children are
afraid to go downstairs or to roam freely in the society. The members of the
Namaskar CHS are defaming the my family in every possible way.

14. I say that due to above act on the part of the accused, the complainant necessitated
legal Complaint dated 12th January,2019 to Shri Sudhakar Pathare Deputy
Commissioner of Police , Zone -1 Vashi against Ex Managing Committee of
Namaskar CHS for Manhandling Smt Mugdha G. Gowda aged 66 years on
11.01.2019 at 10.05 pm Police Protection under Wmytle Blower Act. Hereto
annexed and marked as Exhibit "E" is the copy of the Compliant dated 12.01.2019
filed by the Complainant.

15. I say that motive of the Namaskar CHS members behind not allotting the slit
parking space is that they have illegal allotted the slit parking space to some other
members for their personal gains and has extorted money out of the illegal slit
parking space. The complainant further states that their motive is not to allot the slit
 parking space so the Namaskar CHS members are finding one or the other way to
defame the Complainant and harass him.

16. The Complainant submits that the Accused on dated 11.11.2018 wrote a letter to
Sub Registrar Co-operative society CIDCO falsely alleging that the complainant is
harassing all the society members. That in the said letter on page no.2 the Accused
person in para No.4 specifically made a libel defamatory statement against the
Complainant that "SURENDRA GOWDA TEYNCHYA SOBAT ANAKHI DON
MANASE AHET [SHRI AMAR G AGARWAL VA SHRI ANARJIT
CHAUHAN]" VA TEYNCHYA SOCIETYCHYA PADADHIKARYANA
BLACKMAIL KARUN PAISE MILAVNYACHA DHANDA AHE”, in the said
statement the Accused is alleging that the complainant is a blackmailer and that
blacking is my business. No only tmy they have falsely alleged and defame the
Complainant in the letter further stating that “SHRI GOWDA YHENI 25
LAKHACHI MAGANI KELI AHE”, that Complainant has demanded Rs.
25,00,000/- from the society through Mr. Vivek Tehera (Society Member). The
Accused further also has alleged and defamed the complainant in the letter that the
Complainant is ruining a racket of blackmailing people and that blackmailing
people is the business of the Complainant. Hereto annexed and marked as Exhibit
"F" is the copy of the written letter dated 11.11.2018 written by Accused against
compliant.

17. I say that the Written statement made by the Accused in front of the government
body is defamatory statement and without any documentary proof and thus
tarnishing my image.

18. The sole motive of the accused is to tarnish my name o by stating defamatory
words and to spoil my reputation in the society.

19. I say that the accused deliberately tarnished my image by stating false allegation
against me. Further, the statement made by the accused is without any documentary
proof / evidence and also no verification was done with me before stating the false
news.

20. I say that the accused has made such a baseless allegations against me only to spoil
my image and reputation in the eyes of the Society and Public.

21. I say that the above mentioned written statement made by the accused they have
succeeded in painting me black in the eyes of Public and the Society and has
affected the tremendous amount of goodwill which I had earned after a lot of hard
work.

22. I say that, the accused has deliberately tarnished my image by making false
allegation against me. Further, the statement made by the accused is without any
documentary proof / evidence. The accused has made such baseless allegations and
 statement in front of a Government body and has spoiled my standing and
reputation in the eyes of the Public.

23. I say that the present Complaint is filed against the Accused for the offence which
is punishable under S.499 and S.500 of the Indian Penal Code.

24. I say that, the above acts clearly show the mens rea on the part of the accused to
defame me by giving false statement in front of the government body and thus has
committed defamation. I say from the above act, the accused has made himself
liable for the punishment for the offence S.499 and S.500 of the Indian Penal Code.

25. I say that the Complainant is law abiding citizen, and did not want to create any
law & order problem by going for legal battle but at the same time is not in a
position to bear any more of the mental agony and torture caused by the Accused
on me and my office staff or my family members.

26. I say that the Complainant had no other recourse but to approach and file the
present complaint with you against the Accused under S.499 and 500 of the Indian
Penal Code and be tried and punished as per the Mandate of Law.

27. I state that all the Accused in furtherance of their common intention with criminal
conspiracy committed offence u/s 499 and 500 of IPC.

Therefore, I request you on behalf of the innocent workers to kindly give directions to
the concerned crime Branch to investigate the matter and take appropriate action and to
give us justice by recovering the hard earned money of the workers, in the interest of
Justice. I and my family are also apprehending threat to their life and property ever
since.

I hereby request you to kindly enquire, investigate the matter and take appropriate
action in the interest of Justice. Tmy is for your kind information and appropriate action.
We humbly request you to look into the incident with utmost priority.

Yours Truly,

Surendra G Gowda