IN THE COURT OF LD. C.M.M.

, (S/W DISTRICT)
DWARKA DISTRICT COURTS, NEW DELHI
COMPLAINT CASE NO. OF 2022

IN THE MATTER OF:

ATISH …... COMPLAINANT
VERSUS
KANCHAN & ORS. ….. ACCUSED
PS: DABRI
INDEX

S.NO. PARTICULARS PAGES

Memo of Parties
1.
Complaint U/S 200 of Cr.P.C. along with
2. affidavit

Application U/S 156 (3) of Cr.P.C. along

3. with affidavit

List of Witnesses
4.
List of documents along with documents
5.
Vakalatnama
6.

FILED BY:

New Delhi
Dated:
KETAN KUMAR & ASSOCIATES
(ADVOCATES)
Off: A-596, Gali No.17, Mahavir Enclave,
Part-2, Dabri Dwarka Road, New Delhi-110059
e-mail: ketankumaradvocate@gmail.com
M:8384006676 & 8285404894
 IN THE COURT OF LD. C.M.M., (S/W DISTRICT)
DWARKA DISTRICT COURTS, NEW DELHI
COMPLAINT CASE NO. OF 2022

IN THE MATTER OF:

ATISH …... COMPLAINANT
VERSUS
KANCHAN & ORS. ….. ACCUSED
PS: DABRI
MEMO OF PARTIES

1. Atish Galhotra S/o Sh. Satpal Galhotra

2. Pooja Galhotra W/o Sh. Satpal Galhotra
3. Satpal Galhotra S/o Sh. Sohan Lal Galhotra

All Complainants R/o:

RZ- 171, Indra Park, Pankha Road,
Uttam Nagar, New Delhi-110059 …… Complainants
VERSUS
1. Kanchan @ Aanchal W/o Atish Galhotra
2. Shashi Grover W/o Sh. Shyam Lal Grover
3. Pardeep Grover S/o Sh. Shyam Lal Grover
4. Ishu Grover S/o Sh. Shyam Lal Grover
5. S.K. Mehta
6. Sunita Mehta W/o Sh. S.K. Mehta
7. Smt. Rano
8. Smt. Jeeti & Others …… Accused

Accused No. 1 to 4 R/o:

D- 331, Samta Enclave, Qutub Vihar,
Goyla Dairy, Dwarka, New Delhi-110071
Accused No. 5 & 6 R/o:
Flat No. 200, Rajouri Apartments, Rajouri Garden,
Near Mayapuri Metro Station,
New Delhi-110027 ……. Accused

Accused No. 7 & 8 R/o:

Not Known

Complainants
Through
New Delhi
Dated:

KETAN KUMAR & ASSOCIATES

(ADVOCATES)
Off: A-596, Gali No.17, Mahavir Enclave,
Part-2, Dabri Dwarka Road, New Delhi-110059
e-mail: ketankumaradvocate@gmail.com
M:8384006676 & 8285404894
 IN THE COURT OF LD. C.M.M., (S/W DISTRICT)
DWARKA DISTRICT COURTS, NEW DELHI
COMPLAINT CASE NO. OF 2022

IN THE MATTER OF:

ATISH …... COMPLAINANT
VERSUS
KANCHAN & ORS. ….. ACCUSED
PS: DABRI

COMPLAINT UNDER SECTION 200 OF CR.P.C., 1973 ON

BEHALF OF COMPLAINANTS

MOST RESPECTFULLY SHOWETH:

1. That the complainant no. 2 & 3 are mother and father of

complainant no. 1 while the accused no. 1 is his wife, and all
the other accused are relatives of accused no. 1.

2. That on 13.12.2020 the complainant no. 2 was contacted by

Smt. Jeeti (accused no. 8) regarding the marriage proposal of
accused no. 1 with complainant no. 1. The details of accused
no. 1 were sent on WhatsApp of complainant no. 2. The
complainant no. 2 forwarded the details to complainant no. 1
for matching Kundli but upon matching Kundli of complainant
no. 1 with that of accused no. 1 their “Goon” did not match.
Therefore, the complainants did not proceed further with the
marriage proposal. That on 13.12.2020 when the details of
accused no. 1 was sent to complainant no. 2 the timing of birth
 of accused no. 1 was mentioned as “12:15am” of 02.02.1997.
WhatsApp chat dated 13.12.2020 is annexed herewith.

3. That on 21.09.2021 around ten months later, Smt. Jeeti

(accused no. 8) again contacted complainant no. 2 regarding
marriage proposal of accused no. 1. But this time she has
fraudulently changed the birth timing of accused no. 1 from
“12:15am” to “12:15pm”. That as a long period of around ten
months had passed between the first communication and the
second communication between the parties therefore the
complainants failed to take notice of this fact at that time. The
complainant no. 2 again forwarded the details to complainant
no. 1 for matching their Kundli. As the birth timing of accused
no. 1 was fraudulently changed by the accused persons
therefore upon matching Kundli “Goon” matched and
complainants agreed for the marriage. WhatsApp chat dated
21.09.2021 is annexed herewith.

4. That the father of the accused no. 1 has expired few years ago.
Therefore, the accused no. 5 & 6 who are Mausa and Mausi of
accused no. 1, were acting as guardian of the accused no. 1 and
they insisted complainants for marriage to be solemnized
within few days as Sh. S.K. Mehta (accused no. 5) showcased
himself to be a very busy and influential person and stated that
he cannot spend much time on marriage ceremonies. Therefore,
the marriage date was fixed after 3 weeks i.e., 14.10. 2021. That
on 14.10.2021, the marriage of complainant no. 1 with accused
no.1 was solemnized as per Hindu Customs and Rites in a
simple manner. It is submitted that there is no child from the
said wedlock.
5. That after the marriage accused no.1 along with complainants
started residing at the complainant’s previous residence bearing
house no. RZ-A-22, Adarsh Nagar, Som Bazar Road, Jeevan
Park, Delhi-110059. That since the beginning of marriage the
behaviour of accused no. 1 was abusive and quarrelsome
towards the complainants.

6. That on 18.12.2021 the complainant no. 1 and accused no. 1

were in Kashmir on their honeymoon at around 9:00-9:30 pm
complainant no. 1 asked accused no. 1 the reason for her
abusive and quarrelsome behaviour, she replied with following
statement “tum na fattoo ho, tumhari gaand fat-ti hai”.

7. That the abusive and quarrelsome behaviour of accused no. 1

towards the complainants did not change and on the night of
09.01.2022 accused no. 1 again quarrelled with complainant
no. 1. The next morning i.e., on 10.01.2022 after talking with
her mother (accused no. 2) on phone she packed her clothes and
jewellery and without informing complainants booked a cab
and left her matrimonial home. That before leaving her
matrimonial home the accused no.1 threatened her husband
(complainant no. 1) with following statement “tujhe sabak
sikhaoongi jhoothe case me fasaaoongi” and left. Since then,
she is residing at her paternal home.

8. That on 10.01.2022 and 11.01.2022 complainants tried to

contact accused no. 1 and her family members but neither she
nor her family members answered the phone of complainants.
Therefore, the complainant no. 1 & 2 gave written complaints
at PS Dabri with respect to threats passed by accused no. 1 but
 police official did not act it. Copy of complaints dated
10.01.2022 & 11.01.2022 is annexed herewith.

9. That when the accused no. 1 did not return to matrimonial home
even after several days then accused no. 4 namely Sh. Ishu
Grover (brother-in-law/ saala of complainant no. 1) called the
complainant no. 1 and asked him to take back accused no. 1 to
her matrimonial home. The complainant no. 1 then told him that
since the beginning of the marriage the behaviour of accused
no. 1 was not good towards them and even before leaving her
matrimonial home on 10.01.2022 she has passed threats of
filing false and frivolous case against them. Therefore,
complainant no. 1 told him to meet first at some neutral location
and discuss regarding abusive and quarrelsome behaviour of
accused no. 1 and after that we will take accused no. 1 back to
her matrimonial home.

10.That on 30.01.2022 the complainants and accused persons meet

at Royal Dreams Banquet Hall, Dashrath Puri, New Delhi but
the accused persons again started quarrelling with the
complainants and meeting ended without any conclusion. That
few more meetings also took place but accused persons always
quarrelled with complainants and the parties could not resolve
the issue. The accused no. 5 Sh. S.K. Mehta (Mausa of accused
no. 1) always tried to dominate the complainants.

11.That on 06.03.2022 the accused no. 5 asked complainant no. 1

to meet with him after which complainant no. 1 went to Rajouri
Garden where he was threatened by accused no. 5 with the
 following statement “tujhe pata hai ladki ne agar case kar diya
to teri zindagi barbad kar sakti hai woh”.

12.That on 08.03.2022 around 09.30 pm the accused no. 5

called on the phone of complainant no. 1 and again passed
threats and intimidated him by passing insulting remarks and
threats by saying “tu chaar bando me nahi baithega na to
savere itna kanjarkhana hoga, to abhi to shuruaat hogi, aur yeh
khatm kaha hoga to soch bhi nahi payega”. The accused no. 5
also called father of complainant no. 1and also passed threats
to him after which the complainants got frightened and on
11.03.2022 complainant no. 1 gave a written complaint against
accused no. 5 at PS Dabri but police did not act his complainant.
Copy of complaint dated 11.03.2022 is annexed herewith.

13.That on 13.03.2022 around 7:30-7:45 pm in furtherance to their

threats a total of 8 persons including accused no. 1 to 7 along
with son of accused no. 7 with an intent to cause harm and
injury to the complainants secretly and unlawfully entered the
building premises in which complainants were residing on the
First Floor. The accused no. 5 unlawfully entered the Flat of
complainant with an intent to harm and injure the complainants
but somehow complainant no. 2 & 3 managed to push away the
accused no. 5 from their flat and closed the door and saved
themselves from getting injured at hands of the accused
persons.

14.That when an occupant of the neighbouring flat namely

Smt. Binita Saini tried to intervene and asked accused no. 5 to
not use abusive and harsh language and asked him to stop
 shouting then accused no. 5 threatened her with following
remarks “tu beech me mat bol verna inse pehle tera hisab
karunga”, after which she secretly recorded accused person
shouting and passing threats to the complainants. The accused
no. 5 started banging the door of their flat and continued
passing threats to complainants. The complainant no. 2 & 3 told
the accused persons that the complainant no. 1 is not at home
but accused no. 5 continued passing threats by saying “tere me
dam ho na utar ke dikha diyo”. Photos and videos recorded by
Smt. Binita Saini is annexed herewith.

15.That after the intervention of other occupants of building the

accused persons were taken outside the building but the
accused persons continued passing threats, false and
defamatory allegations against the complainants.

16.That on 13.03.2022 the complainants called the police after

which PCR arrived at the spot where the accused persons were
abusing and passing threats to complainants openly and
publicly. The accused persons and the complainants were then
taken to the PS Dabri by the police officials. But Police did not
take any action against the accused persons.

17.That after the incident of 13.03.2022 the threats from the

accused persons continued and on 06.07.2022 the accused no.
1 along with one unknown person was spreading false rumours
in the neighbourhood of complainants. The complainant no. 1
again approached the PS Dabri but police again asked him to
file a written complaint. Therefore, on 06.07.2022 the
complainant no.1 again gave a written complaint against
 accused persons at PS Dabri. But police did not act on it. Copy
of complaint dated 06.07.2022 is annexed herewith.

18.That on 27.07.2022 in furtherance of her threats accused no. 1

filed a false and frivolous complaint against the complainants
at PS Chhawla and FIR bearing no. 351/2022 U/S 498A/406/34
IPC was registered against the complainants and she has also
filed an application U/S 12 of PWDV Act which is pending
before the Ld. Court of Ms. Deepika Goyal Shokeen, Ld. MM
(Mahila Court), Dwarka Courts, Delhi. Copy of FIR &
application U/S 12 of PWDV Act is annexed herewith.

19.That on 21.09.2021 the accused persons cheated and played

fraud upon the complainants by changing the birth timing of the
accused no. 1 from “12:15 am” to “12:15 pm” when the
accused no. 6 namely Smt. Jeeti sent the details of accused no.1
to WhatsApp of complainant no. 2. Therefore, they have
committed an offence of cheating and criminal breach of trust
with complainants.

20.That on 10.01.2022 when accused no. 1 was leaving her

matrimonial home, she passed threats to complainant no. 1 that
she will file a false complaint against him and in furtherance of
that on 27.07.2022 she has registered an FIR against the
complainants based on false information provided to police.

21.That in furtherance of threats passed by accused no. 5, on

13.03.2022 8 persons unlawfully entered the building of
complainant and accused no. 5 unlawfully entered their flat
with an intent to injure the complainants and all accused
 persons defamed the respect and social devoir of the
complainants publicly and openly with malafide intention thus
committed an act of criminal intimidation, criminal trespass
and defamation.

22.That all the accused persons intentionally insulted

complainants and thereby gives provocation to the
complainants intending or knowing it to be likely that such
provocation will cause them to break the public peace or the
commit any offence.

23.That the accused no. 1 & 5 had spread false and baseless
rumours of impotency of complainant no. 1 among near relative
and society. Therefore, they have committed an act of
defamation.

24.That the aforesaid incidents attract Section 420/ 406/ 427/ 182/
389/ 500/ 506/ 451/ 120B/ 34 I.P.C. 1860, up to amendments
according to nature and ingredients of offences.

25.That on 03.10.2022 complainants sent a written complaint to

DCP, S/W District Dwarka, after few days the complainants
received call from PS Dabri, and they assured complainant that
they are going to act on their complaint but till date no action is
taken against the accused persons. Complaint dated 03.10.2022
along with original Postal receipts and online delivery report is
annexed herewith.
26.That based on above said facts and circumstances a strong and
prima facie case is made out against the accused persons. Hence
this complaint.

27.That this Hon’ble Court has jurisdiction to try the case as the
offences were committed within the territorial limits of this
Hon’ble Court.

28.That the cause of action first arose on 21.09.2021 when the

accused no. 6 deliberately sent the wrong birth timing of
accused no. 1 to the complainants. That cause of action further
arose on 10.01.2022 when accused no. 1 passed threats to
complainant no. 1 and on 11.01.2022 when the complainant no.
1 & 2 filed written complaint regarding the threats of false
implication passed by the accused no. 1. The cause of action
further arose on 08.03.2022 when the accused no. 5 passed
threats to complainant no. 1 & 3 and on 11.03.2022 when
complainants filed a complaint against accused no. 5. The cause
of action again arose on 13.03.2022 when 8 accused persons
unlawfully entered the building premises of complainants and
accused no. 5 unlawfully entered the flat of complainant and
tried to injure complainants, but police did not take any action
against the accused persons. The cause of action further arose
on 06.07.2022 when complainant filed a written complaint at
PS Dabri. The cause of action further arose on 27.07.2022 when
the accused no. 1 in furtherance of her threats registered an FIR
against complainants based on false information. The cause of
further arose on 03.10.2022 when complainant sent a written
complaint to DCP, South-West, District Dwarka. The cause of
action still arising and continuing as the complainants are being
 defamed and falsely implicated by the accused persons. Hence,
this Hon’ble Court has jurisdiction to entertain the present
complaint case. The complaint is on time.

PRAYER
It is, therefore, most respectfully prayed that the Hon’ble Court
may in the interest of justice, be pleased:

a) To register the case.

b) To take cognizance of above said offences, try and

punish the accused persons.

c) To pass any other/ further orders that may deem fit and
proper in the facts and circumstances of the case.

Complainants
New Delhi Through
Dated:
KETAN KUMAR
(ADVOCATE)
VERIFICATION:

Verified at New Delhi on ____day of_____ 2022. That the

contents of above noted complaint are true and correct to the best
of my knowledge and information received and nothing material
has been concealed therefrom.

Complainants
 IN THE COURT OF LD. C.M.M., (S/W DISTRICT)
DWARKA DISTRICT COURTS, NEW DELHI
COMPLAINT CASE NO. OF 2022

IN THE MATTER OF:

ATISH …... COMPLAINANT
VERSUS
KANCHAN & ORS. ….. ACCUSED
AFFIDAVIT

I, Atish Galhotra S/o Sh. Satpal Galhotra aged____ yrs R/o

RZ- 171, Indra Park, Pankha Road, Uttam Nagar, New Delhi-
110059, do hereby solemnly affirm and declare as under:

1. That the deponent is the complainant in the present case and

well conversant with facts and circumstances of the case as
such competent to swear this affidavit.
2. That the contents of accompanying complaint have been
drafted by my counsel under my instructions and contents of
the same has been read over to me in vernacular to be true and
correct. The same may be read as part and parcel of this
affidavit and the same have not been reproduced herein for the
sake of brevity.

DEPONENT
VERIFICATION:
Verified at New Delhi on ____day of_____ 2022. That the
contents of my affidavit are true and correct to the best of my
knowledge and belief and nothing material has been concealed
therefrom.
DEPONENT
 IN THE COURT OF LD. C.M.M., (S/W DISTRICT)
DWARKA DISTRICT COURTS, NEW DELHI
COMPLAINT CASE NO. OF 2022

IN THE MATTER OF:

ATISH …... COMPLAINANT
VERSUS
KANCHAN & ORS. ….. ACCUSED
AFFIDAVIT

I, Pooja Galhotra W/o Sh. Satpal Galhotra aged____ yrs R/o

RZ- 171, Indra Park, Pankha Road, Uttam Nagar, New Delhi-
110059, do hereby solemnly affirm and declare as under:

1. That the deponent is the complainant in the present case and

well conversant with facts and circumstances of the case as
such competent to swear this affidavit.
2. That the contents of accompanying complaint have been
drafted by my counsel under my instructions and contents of
the same has been read over to me in vernacular to be true and
correct. The same may be read as part and parcel of this
affidavit and the same have not been reproduced herein for the
sake of brevity.

DEPONENT
VERIFICATION:
Verified at New Delhi on ____day of_____ 2022. That the
contents of my affidavit are true and correct to the best of my
knowledge and belief and nothing material has been concealed
therefrom.
DEPONENT
 IN THE COURT OF LD. C.M.M., (S/W DISTRICT)
DWARKA DISTRICT COURTS, NEW DELHI
COMPLAINT CASE NO. OF 2022

IN THE MATTER OF:

ATISH …... COMPLAINANT
VERSUS
KANCHAN & ORS. ….. ACCUSED
AFFIDAVIT

I, Satpal Galhotra S/o Sh. Sohan Lal Galhotra aged____ yrs

R/o RZ- 171, Indra Park, Pankha Road, Uttam Nagar, New Delhi-
110059, do hereby solemnly affirm and declare as under:

1. That the deponent is the complainant in the present case and

well conversant with facts and circumstances of the case as
such competent to swear this affidavit.
2. That the contents of accompanying complaint have been
drafted by my counsel under my instructions and contents of
the same has been read over to me in vernacular to be true and
correct. The same may be read as part and parcel of this
affidavit and the same have not been reproduced herein for the
sake of brevity.

DEPONENT
VERIFICATION:
Verified at New Delhi on ____day of_____ 2022. That the
contents of my affidavit are true and correct to the best of my
knowledge and belief and nothing material has been concealed
therefrom.
DEPONENT
 IN THE COURT OF LD. C.M.M., (S/W DISTRICT)
DWARKA DISTRICT COURTS, NEW DELHI
COMPLAINT CASE NO. OF 2022

IN THE MATTER OF:

ATISH …... COMPLAINANT
VERSUS
KANCHAN & ORS. ….. ACCUSED
PS: DABRI

APPLICATION ON BEHALF OF COMPLAINANTS TO

REGISTER THE F.I.R. AGAINST ALL THE ABOVE SAID
ACCUSED PERSONS UNDER SECTIONS 420/ 406/ 427/
182/ 389/ 500/ 506/ 451/ 120B/ 34 I.P.C., 1860 AS PER
PROVISIONS UNDER SECTION 156 (3) OF CR.P.C. 1973

MOST RESPECTFULLY SHOWETH:

1. The complainants have filed the accompanying complaint case

against the accused persons and same is pending before this
Hon’ble Court.

2. The police have failed to register the case against the accused
persons. Hence, there is no option left with complainant except
to file the present complaint against the accused persons as
mentioned above.

3. That on the basis of facts and circumstances given in the

accompanying complaint a strong and prima facie/ cognizable
case has been made out against the accused persons. Further,
 police investigation is must and necessary in the present case
being serious and heinous offences committed by the accused
persons.

4. That the police investigation is must and necessary in the

present case to:

a) Obtain the address of accused no. 8 Smt. Jeeti and inquire

from her about the details of conspiracy committed against
the complainants related to changing birth timing of accused
no. 1 when she sent her details to complainant no. 2 on
21.09.2021 for marriage proposal and thereby committed an
act of cheating and criminal breach of trust and to trace other
victims if any.

b) Obtain the address of accused no. 7 Smt. Rano and her son
and inquire from them on whose instructions/ orders they
came along with accused persons to the residence of
complainant on 13.03.2022 where they forcefully and
unlawfully tried to enter the flat of complainant with an
intent to cause injury to life and limb of complainants.

c) Conduct the investigation with respect to individual role of

each accused persons in the conspiracy committed against
the complainants and record their statements.

5. That the complainants seek kind permission of this Hon’ble

Court to raise such other or further grounds as may be available
to them at the time of hearing of the present complaint.
 PRAYER
It is, therefore, most respectfully and humbly prayed that
this Hon’ble Court may in the interest of justice, be pleased:

a) To send complaint to the SHO concerned for

investigation and issue directions for registration of FIR.
b) To take cognizance of above said offence and punish the
accused persons.

c) To pass any other appropriate order/ relief and directions

that may be deemed fit and proper in favour of
complainant and against all the accused persons upon
facts and circumstances of the case.

Complainants
Through
New Delhi
Dated:
KETAN KUMAR & ASSOCIATES
(ADVOCATES)
Off: A-596, Gali No.17, Mahavir Enclave,
Part-2, Dabri Dwarka Road, New Delhi-110059
e-mail: ketankumaradvocate@gmail.com
M:8384006676 & 8285404894
 IN THE COURT OF LD. C.M.M., (S/W DISTRICT)
DWARKA DISTRICT COURTS, NEW DELHI
COMPLAINT CASE NO. OF 2022

IN THE MATTER OF:

ATISH …... COMPLAINANT
VERSUS
KANCHAN & ORS. ….. ACCUSED
AFFIDAVIT

I, Atish Galhotra S/o Sh. Satpal Galhotra aged____ yrs R/o

RZ- 171, Indra Park, Pankha Road, Uttam Nagar, New Delhi-
110059, do hereby solemnly affirm and declare as under:

1. That the deponent is the complainant in the present case and

well conversant with facts and circumstances of the case as
such competent to swear this affidavit.
2. That the contents of accompanying application have been
drafted by my counsel under my instructions and contents of
the same has been read over to me in vernacular to be true and
correct. The same may be read as part and parcel of this
affidavit and the same have not been reproduced herein for the
sake of brevity.

DEPONENT
VERIFICATION:
Verified at New Delhi on ____day of_____ 2022. That the
contents of my affidavit are true and correct to the best of my
knowledge and belief and nothing material has been concealed
therefrom.
DEPONENT
 IN THE COURT OF LD. C.M.M., (S/W DISTRICT)
DWARKA DISTRICT COURTS, NEW DELHI
COMPLAINT CASE NO. OF 2022

IN THE MATTER OF:

ATISH …... COMPLAINANT
VERSUS
KANCHAN & ORS. ….. ACCUSED
AFFIDAVIT

I, Pooja Galhotra W/o Sh. Satpal Galhotra aged____ yrs R/o

RZ- 171, Indra Park, Pankha Road, Uttam Nagar, New Delhi-
110059, do hereby solemnly affirm and declare as under:

1. That the deponent is the complainant in the present case and

well conversant with facts and circumstances of the case as
such competent to swear this affidavit.
2. That the contents of accompanying application have been
drafted by my counsel under my instructions and contents of
the same has been read over to me in vernacular to be true and
correct. The same may be read as part and parcel of this
affidavit and the same have not been reproduced herein for the
sake of brevity.

DEPONENT
VERIFICATION:
Verified at New Delhi on ____day of_____ 2022. That the
contents of my affidavit are true and correct to the best of my
knowledge and belief and nothing material has been concealed
therefrom.
DEPONENT
 IN THE COURT OF LD. C.M.M., (S/W DISTRICT)
DWARKA DISTRICT COURTS, NEW DELHI
COMPLAINT CASE NO. OF 2022

IN THE MATTER OF:

ATISH …... COMPLAINANT
VERSUS
KANCHAN & ORS. ….. ACCUSED
AFFIDAVIT

I, Satpal Galhotra S/o Sh. Sohan Lal Galhotra aged____ yrs

R/o RZ- 171, Indra Park, Pankha Road, Uttam Nagar, New Delhi-
110059, do hereby solemnly affirm and declare as under:

1. That the deponent is the complainant in the present case and

well conversant with facts and circumstances of the case as
such competent to swear this affidavit.
2. That the contents of accompanying application have been
drafted by my counsel under my instructions and contents of
the same has been read over to me in vernacular to be true and
correct. The same may be read as part and parcel of this
affidavit and the same have not been reproduced herein for the
sake of brevity.

DEPONENT
VERIFICATION:
Verified at New Delhi on ____day of_____ 2022. That the
contents of my affidavit are true and correct to the best of my
knowledge and belief and nothing material has been concealed
therefrom.
DEPONENT
 IN THE COURT OF LD. C.M.M., (S/W DISTRICT)
DWARKA DISTRICT COURTS, NEW DELHI
COMPLAINT CASE NO. OF 2022

IN THE MATTER OF:

ATISH …... COMPLAINANT
VERSUS
KANCHAN & ORS. ….. ACCUSED

LIST OF WITNESSES

1. Complainant no. 1, 2 & 3, themselves.

2. Smt. Binita Saini W/o Sh. Dinesh Saini

R/o: RZ-A-22, Adarsh Nagar, Jeevan Park,
Uttam Nagar, New Delhi-110059

3. Any other witnesses (s) with the permission of this Hon’ble

Court, if required.

Complainants
Through
New Delhi
Dated:

KETAN KUMAR & ASSOCIATES

(ADVOCATES)
Off: A-596, Gali No.17, Mahavir Enclave,
Part-2, Dabri Dwarka Road, New Delhi-110059
e-mail: ketankumaradvocate@gmail.com
M:8384006676 & 8285404894
 IN THE COURT OF LD. C.M.M., (S/W DISTRICT)
DWARKA DISTRICT COURTS, NEW DELHI
COMPLAINT CASE NO. OF 2022
IN THE MATTER OF:
ATISH …... COMPLAINANT
VERSUS
KANCHAN & ORS. ….. ACCUSED

LIST OF DOCUMENTS
S.NO. PARTICULARS PAGES

KETAN KUMAR
(ADVOCATE)
 LIST OF DOCUMENTS
S.NO. PARTICULARS PAGES

KETAN KUMAR
(ADVOCATE)
IN
 THE COURT OF LD. C.M.M., (S/W DISTRICT)
DWARKA DISTRICT COURTS, NEW DELHI
COMPLAINT CASE NO. OF 2022
IN THE MATTER OF:
ATISH …... COMPLAINANT
VERSUS
KANCHAN & ORS. ….. ACCUSED

CERTIFICATE U/S 65-B OF INDIAN EVIDENCE ACT

I, Pooja Galhotra W/o Sh. Satpal Galhotra aged____ yrs R/o
RZ- 171, Indra Park, Pankha Road, Uttam Nagar, New Delhi-
110059, do hereby solemnly affirm and declare as under:

That I am the complainant in the above noted matter. And I have

filed before this Ld. Court printout of:
1. Whatsapp chat dated 21.09.2021
2. Acknowledgement of complaint no. 81760022200082
which is obtained from my mobile and same has not altered/
tempered with.
That I certify that information mentioned above are derived
from my mobile during the period over which my mobile was used
regularly to store information.
That I confirm that throughout the material part of the said
period, the mobile was operating properly. Therefore, it can be
treated and admitted as genuine evidence.
That the statements made above are true to best of my
knowledge and belief.

New Delhi
Dated: Pooja Galhotra
 IN THE COURT OF LD. C.M.M., (S/W DISTRICT)
DWARKA DISTRICT COURTS, NEW DELHI
COMPLAINT CASE NO. OF 2022
IN THE MATTER OF:
ATISH …... COMPLAINANT
VERSUS
KANCHAN & ORS. ….. ACCUSED
CERTIFICATE U/S 65-B OF INDIAN EVIDENCE ACT
I, Atish Galhotra S/o Sh. Satpal Galhotra aged____ yrs R/o RZ-
171, Indra Park, Pankha Road, Uttam Nagar, New Delhi-110059,
do hereby solemnly affirm and declare as under:

That I am the complainant in the above noted matter. And I have

filed before this Ld. Court printout of:
1. Whatsapp chat dated 13.12.2020
2. Acknowledgement of complaint no. 81760022200075
3. Delivery report of SpeedPost no. ED653811599IN
which are obtained from my computer and mobile and same
has not altered/ tempered with.
That I certify that information mentioned above are derived
from my computer and mobile during the period over which my
computer and mobile were used regularly to store information.
That I confirm that throughout the material part of the said
period, the computer and mobile were operating properly.
Therefore, it can be treated and admitted as genuine evidence.
That the statements made above are true to best of my
knowledge and belief.

New Delhi
Dated: Atish Galhotra
 IN THE COURT OF LD. C.M.M., (S/W DISTRICT)
DWARKA DISTRICT COURTS, NEW DELHI
COMPLAINT CASE NO. OF 2022
IN THE MATTER OF:
ATISH …... COMPLAINANT
VERSUS
KANCHAN & ORS. ….. ACCUSED

CERTIFICATE U/S 65-B OF INDIAN EVIDENCE ACT

I, Smt. Binita Saini W/o Sh. Dinesh Saini aged ___ yrs
R/o RZ A-22, Adarsh Nagar, Jeevan Park, Uttam Nagar, New
Delhi-110059, do hereby solemnly affirm and declare as under: -

That I am a witness in the above noted matter. And I have filed

before this Ld. Court:

1. 2 videos and 2 photographs of incident dated 13.03.2022

which is obtained from my mobile phone and same has not

altered/ tempered with.
That I certify that information mentioned above are derived
from my mobile phone during the period over which my mobile
phone was used regularly to store information.
That I confirm that throughout the material part of the said
period, the mobile phone was operating properly. Therefore, it can
be treated and admitted as genuine evidence.
That the statements made above are true to best of my
knowledge and belief.
New Delhi
Dated: Binita Saini
 IN THE COURT OF LD. C.M.M., (S/W DISTRICT)
DWARKA DISTRICT COURTS, NEW DELHI
COMPLAINT CASE NO. OF 2022
IN THE MATTER OF:
ATISH …... COMPLAINANT
VERSUS
KANCHAN & ORS. ….. ACCUSED
 IN THE COURT OF LD. C.M.M., (S/W DISTRICT)
DWARKA DISTRICT COURTS, NEW DELHI
COMPLAINT CASE NO. OF 2022
IN THE MATTER OF:
ATISH …... COMPLAINANT
VERSUS
KANCHAN & ORS. ….. ACCUSED