Legal Question in Criminal Law in India

IN THE COURT OF JUDICIAL MAGISTRATE IST CLASS, Panchkula

1. Satya Pal Chauhan

2. Yash Pal Chauhan

3. Ram Pal Chauhan, sons of SH. Hakam Singh

4. Naveen Kumar

5. Sanjeev Kumar

6. Ravi Kumar grand sons of Sh. Hakam Singh

All residents of H.No.402, 403, 404, Vashisht Nagar, Babyal Road, Ambala Cantt.

����Complainants.

Versus

1. Randeep Singh

2. Rakesh Kumar, sons of Late Sh. Collector Singh.

3. Phool Singh

4. Kuldeep Singh

All residents of Village Kakrali, Distt. Panchkula.

���Accused.

Complaint u/s 406/420/467/468/471/506/120-B IPC

Pertaining to P.S. Raipur Rani

Sir,

The complainants respectfully submit as under;

1) That the complainants are peaceful and law abiding citizen and are residing at Vashisht Nagar, Ambala Cantt.

2) That the accused No.1 and 2 are the close relatives/ cousins of the complainant. The complainants and accused no.1 and 2 are having ancestral land and houses at village Kakrali, Distt. Panchkula and the said land was given on contract by the complainants to their cousin brother.

3) That some litigations are going on regarding the ancestral property and the accused no.1 and 2 used to attend the proceedings before the court on behalf of all the complainant and the accused no.1 and 2 used to obtain the signatures of the complainant on the applications or other documents as per requirements of the court.

4) That the accused persons hatched a criminal conspiracy and in pursuance of that criminal conspiracy and with fraudulent intention the accused no.1 and 2 have obtained the signatures of the complainants on some blank papers by misrepresentation that the same are required for submitting the applications in the court as the litigation regarding the ancestral land were going on.

5) That later on the accused persons have forged and fabricated the above said blank papers and converted the above said documents into agreement to sell alleged to have been executed by the complainants and claims their self as the true owner of the agriculture land and other ancestral property on the basis of forged documents.

6) That the accused persons have forged and fabricated the agreement to sells and have used the same as genuine knowing fully well that they are forged and fabricated documents.( The copy of the false agreement to sells are also attached for the kind perusal of this ld. Court.)

7) That the complainants made various complaints to different authorities but no action was taken by the police, rather accused no. 4 is police officials and the local police is under their influence. It is very relevant to mentioned here that it is the influence of the accused no.4 that no enquiry has been initiated by the police on the complaint of the complainant. The police of PS Panchkula did not bothered to investigate the matter about the forged documents nor the police was bothered that by whom the documents were forged.(All the complaints are attached with the present complaint for the kind perusal of this ld. court)

8) That it is also important to mentioned here that on 25.06.2013 when the complainant no.1 and 2 went to the village in order to look after the houses and other property. In the meantime the police came there to stop their work and called the complainant no.1 and 2 to police station where they remained for two hours by the police officials. It is also pertinent to mentioned here that the accused no.4 was also present at Police station. At about 5 P.M the complainants came to know that they were arrested by the police of PS Raipurani in FIR no.82 dated 25.06.2013 under section 148,149,427,447,448,323,506 IPC. The accused have also threatened the complainants that they have high links with anti-social elements and they will murder the complainants if they again contacted them.

9) That it is the influence of the accused no.4 over the police officials of PS Raipurrani that without any scuffle the complainant no.1 and 2 along their other family members have falsely been implicated by the police in above mentioned false case.

10) That the accused persons trying to grab the whole property of the complainants by pressuries them. They also want that the complainant may not claim over the property and houses. This is the only reason that the FIR no.82 dated 25.06.2013 has been registered against the complainant. The copy of the FIR is also attached for the kind perusal of this ld. Court.

11) That the accused by hatching a criminal conspiracy have forged the false agreement to sells and by using these documents defraud the land and ancestral property in question, thereby committed grave criminal offences punishable under sections 406, 420, 467, 468, 471, 506, 120-B IPC and they deserves to be punished deterrently.

It is, therefore, respectfully prayed that the present complaint may kindly be sent to P.S. RaipurRani for registration of the FIR and investigation of the case u/s 156(3) Cr.P.C. or in the alternative the accused may kindly be summoned, tried and punished deterrently in the interest of justice.

Ambala City. ���.Complainants

Dated: 11.7.2013

Through Counsel,

SUMIT SHARMA, Advocate

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