IN THE MATTER OF SURESH KHENDELWAL COMPLAINANT VERSUS KIRAN BEDI ACCUSED…

IN THE HON’BLE COURT OF CHIEF METROPOLITAN MAGISTRATE,(EAST) KARKARDOOMA COURTS, NEW DELHI

COMPLAINT NO. OF 2015

IN THE MATTER OF :

SH. SURESH KHENDELWAL               
COMPLAINANT
VERSUS
MS. KIRAN BEDI                           
ACCUSED

THROUGH
LEGUM LAW FIRM
HIMAL AKHTAR
ADVOCATE
O-24-A, JUNG PURA EXTENSION,
NEW DEHI.
himalakhtarg@gmail.com

P.S. KRISHNA NAGAR

COMPLAINT UNDER SECTION 200 Cr.P.C INITIATING CRIMINAL PROCEEDING AGAINST THE  ACCUSED UNDER SECTION 153 A & 153 B OF I. P.C, U/S 125 OF THE REPRESENTION OF THE PEOPLE ACT 1951 AND  U/S 3 OF THE DELHI PREVENTION OF DEFACEMENT OF   PROPERTY ACT 2007

MOST RESPECTFULLY SHOWETH: That the complainant is a permanent resident/social worker of Krishna Nagar vicinity and law abiding patriotic citizen of India and respects the freedom fighters and leaders of the National Pride from the bottom of his heart. It is a paramount duty of the complainant to raise the voice against the illegality and immorality to strengthen the largest democracy of world and to save the pride of the Nation. That on 21/01/2015, during the election campaign being a Chief Minister candidate of Bhartiya Janta Party, the above mention Ms. Kiran Bedi along with her associates and party members had visited at Sh. Lala Lajpat Rai Chowk, Krishna Nagar, Delhi, where the idol of Late Sh. Lala Lajpat Rai is placed.

That Ms. Kiran Bedi with the collusion and connivance and consent with Sh. Mahesh Giri Member of Parliament, Dr. Sh. Harsh Wardhan Union Minister, Sh. Vijay Goel Member of Rajya Sabha, Sh. Satish Upadhya President Delhi B.J.P and Ms. Kalpana Jain Municipal Counselor, put the saffron clothe with mark of BJP on the idol of Punjab Kesri Late Sh. Lala Lajpat Rai in order to saffronize the image of the great freedom fighter  for  her political gain and  to influence her vote bank by depicting that the great freedom fighter was having ideology of B.J.P and R.S.S only. It is further clarified that he was a great freedom fighter who belongs to whole of the Nation but not to a particular section of the society.

That the sole intention of above mentioned persons is to ruin, disparage and defame the hard built reputation of Punjab Kesri Late Sh. Lala Lajpat Rai in order to hurt the sentiments of his followers and admirers including complainant by representing him from a particular political party. The act of Ms. Kiran Bedi was pre-determine and with the collusion and connivance of the above mention associates. The above mention Ms Kiran Bedi along with her associates hurt the sentiments and feelings of the complainant as well as other secular and patriotic citizens of the entire country who respect their freedom fighters and love their country above anything else by visible representation to promote disharmony, feeling of hatred and ill will among the residents of Krishna Nagar vicinity. The act of the above mentioned persons are prejudicial to the maintenance of harmony between communities and which likely to disturb the public tranquility at large. the public tranquility at large.

That the complaint has already sent a legal Notice dated 22/01/2015 to the accused wherein call upon the accused to tender unconditional apology in public for hurting the sentiments, emotions and feeling of the complainant along with the secular and  patriotic citizens of country and further clarify to the general public that Late Sh. Lala Lajpat Rai does not belong to the B.J.P or R.S.S ideology only rather belongs to the Nation as a whole, but the accused neither tender apology nor reply to  the said  legal notice till date. That complainant filed a written complaint dated 23/01/2015 to the Commissioner of Police, Deputy Commissioner of Police office (East) and S.H.O Krishna Nagar, Delhi, but No action has been taken as the accused is a very influential personality and she used to server the police department for long year on higher position.

That above mention accused has therefore, committed the offence of promoting enmity between the residents, committed illegal act prejudicial to the  maintenance of harmony among the residents of Krishna Nagar vicinity and prejudicial to the national integration.  She committed the offence of promoting enmity between different classes of the citizens of India  in connection with election. She also committed the offence of defacement of the state property by ornamenting the statue of Punjab Kesri Late Sh. Lala Lajpat Rai during her election campaign for the benefit for political party.

That the above mention offence have been committed by the accused within the local limit and jurisdiction of Police Station Krishna Nagar, Delhi and therefore, this Hon’ble Court has got the jurisdiction try, entertain and decide the present complaint.

NON FILLING

That the complainant has not filed any other similar complaint before the court of law pertaining to the present offence expect present complainant.  

P R A Y E R

It is therefore, most respectfully prayed that this Hon’ble Court may kindly be pleased to summon the accused persons and punish her as per section 153 A & 153 B of I.P.C, Section 125 of The Representation of the People Act 1951 and Section 3 of The Delhi Prevention of Defacement of Property Act, 2007, in the interest of Justice.       
DELHI :                               
COMPLAINANT
DATED :    
THROUGH
LEGUM LAW FIRM
(HIMAL AKHTAR)
ADVOCATE
O-24-A, JUNG PURA EXTENSION,
NEW DEHI.
himalakhtarg@gmail.com

AFFIDAVIT
I, Suresh Khandelwal S/o Sh. Gainda Lal R/o A-7/37, Krishna Nagar, Delhi-110051, do hereby solemnly affirm and declare as under :-

That the deponent is the complainant in the present complaint and well aware with the facts of the case. Hence competent to swear this affidavit.

That the accompanying complainant has been drafted by my counsel as per my instructions and the contents of the have been read over to me in vernacular and understood by me, which are true and correct.

That the contents of the accompanying complainant may kindly be read as part and parcel of affidavit which are not being repeated herein for the sake of brevity and the complainant has not field any similar complaint before court of law.

DEPONENT
VERIFICATION :-
Verified at Delhi on this day of January, 2015 that the contents of above affidavit are true and correct to my knowledge. No part of it is false and nothing material has been concealed therefrom.

इस प्रकरण में आगे क्या हुआ, जानने के लिए नीचे दिए गए शीर्षक पर क्लिक करें….

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