in Re:-: 1. 2-3 2. 4 3. 5-8 4. 9 5. Annexure P-1

IN THE COURT OF CHIEF JUDICIAL MAGISTRATE,
DISTRICT COURT, DEHRADUN (UTTARAKHAND)

COMPLAINT CASE NO. _____ OF 2019
In re:-
Kumar Shantanu …………..Complainant
Versus
Akhilesh Yadav & Ors. .………Opposite Party(s)
INDEX
S. NO. PARTICULARS PAGES
1. Memo of Parties 2-3
2. List of Witnesses 4
3. Complaint Petition u/s 156 (3) of Cr. P. C. 5-8
4. Affidavit 9
5. ANNEXURE P-1
1st True English Translation of the Letter to the
Superintendent of Police, Dehradun dated
15.03.2019 by the Complainant.
6. ANNEXURE P-2
1st True English Translation of the MLC bearing
receipt no. ________ dated 26.03.2019 issued by
District Hospital, Dehradun.
7. Vakalatnama
Dehradun.
Dated: 25.03.2019
(MRIDUL YASH DWIVEDI)

ADVOCATE
COUNSEL FOR THE PETITIONER
CH. NO. 606,
DISTRICT COURT LAWYERS’ CHAMBERS,
DEHRADUN - 248001
(M): +91-8755016302; +91-7987035404
In re:-
Kumar Shantanu
…………..Complainant
Versus
Akhilesh Yadav & Ors.

.………Opposite Party(s)
MEMO OF PARTIES
1. Mr. Kumar Shantanu

Aged about 23 years,
S/o Sunil Kumar
R/o Kandoli (via Premnagar),
Dehradun – 248001
……….Complainant
Vs.
1. Mr. Akhilesh Yadav

S/o Mr. Mulayam Singh Yadav
R/o Vikas Nagar,
Dehradun – 248001
2. Mr. K. D. Pathak
S/o Mr. Mayank Pathak
R/o Prem Nagar,
Dehradun – 248001
3. Smt. Rani Devi

Aged about 38 years
W/o Mr. Laccha Singh
R/o Ulhas Nagar,
Haridwar – 249401
4. Smt. Rinku Devi
Aged about 29 years
W/o Mr. Mashoor Gulati
R/o Biwerley Heights, Near Survey Chowk
Dehradun – 248001
………Opposite Party(s)
Dehradun.
Dated: 25.03.2019

ADVOCATE
CH. NO. 606,
DEHRADUN - 248001
(M): +91-8755016302; +91-7987035404
In re:-
Versus
LIST OF WITNESSES
1. Mr. Nimish Patkar

S/o Mr. Shashi Patkar
R/o Doon Valley Residency,
Mussoorie Road, Dehradun – 248001
2. Mr. Tushar Ghodesawar

Aged about 29 years
S/o Bachcha Ghodesawar
R/o Prime Residency,
Har Ki Pauri, Haridwar – 249401
Dehradun.
Dated: 25.03.2019

ADVOCATE
CH. NO. 606,
DEHRADUN - 248001
(M): +91-8755016302; +91-7987035404
In re:-
Versus
Place of Occurrence Shikha NGO, Dehradun
Date & Time of Occurrence 28th February, 2019

@9.00AM
Offence U/s: 370, IPC 1860
MOST RESPECTFULLY SHOWETH:-
1. That the complainant is a law abiding and peace loving
citizen of India and is a permanent resident of Kandoli,
Distt.- Dehradun.
2. That the Complainant is an active member of the Legal
Aid Society (LAS), Dehradun.
3. That for the purpose of conducting an empirical study on
social conditions of the orphans, the Complainant
accompanied by Witness No. 1 and 2 visited an NGO
named Shikha NGO in Dehradun which is currently
being operated and managed by the Opposite Party No. 1,

which is being helped by his manager who is the Opposite
Party No. 2 and also the NGO is looked by two lady
workers, Opposite Party No. 3 & 4 of the present
complaint.
4. That the complainant wants to submit that they saw that
the children which were looked after by said NGO were
not in the proper state and their state of conditions was
dilapidated and not satisfactory as through their
empirical study, they found that the children there were
very much scared and were reluctant to answer the
questions being asked by the Complainant and others
and were also reluctant to talk for a while which created
a thought of suspicion in the minds of the Complainant
and the witnesses of this complaint.
5. That due to above stated observations made by the
complainant and others, they started to visit the NGO
frequently. During this period, the complainant
approached a child aged 9 years but interestingly, the
child was very much reluctant to say even a hello to him.
6. That after many unsuccessful attempts, the complainant
and that child became friends and that the child told each
and everything about the NGO and the ill practices which
had been taking place.

7. That the child when being questioned by the Complainant
told that the children in that NGO were beaten by NGO
officials specially by Opposite Party No. 1 and 2.
8. That the child further disclosed that some girls were
taken out by the NGO officials in the name of having
medical checkups and getting them admitted into some
good schools for their education but in reality none of
them ever returned to the NGO.
9. That after analysing the situation and gravity of the
conditions prevailing in the NGO, the complainant went
to the PS Premnagar to file an FIR against the Opposite
Parties of this case but unfortunately the police were
uninterested in filing the FIR.
10. That after this, the complainant on 15th March 2019,
wrote down a letter to the Superintendent of Police,
Dehradun mentioning the behaviour being showed by the
Prem Nagar Police but to no avail as no investigation was
done by them. True copy of the letter posted by the
Complainant to the SP of Dehradun District dated
15.03.2019 is annexed herein as Annexure P-1 at page
no. __ .
11. That the complainant also wants to submit that on 25th
March 2019, he was beaten by some goons who were sent
by Opposite Party No. 1. True Copy of the MLC bearing

receipt no. ___ dated 26.03.2019 issued by Dehradun
District Hospital is annexed herein as Annexure P-2 at
page no. __ .
12. That the complainant wants to submit that the acts,
omissions and misdeeds committed by the Opposite
Parties clearly attract the provisions of Law laid u/s 370
of Indian Penal Code, 1860.
13. That the Hon’ble Court has pecuniary as well as territorial
jurisdiction to entertain this complainant and also to
summon, try and punish the opposite parties.
14. Prayer –
1. It is therefore most respectfully prayed that your
honour be pleased to order police to start the investigation
proceedings in the aforesaid case, or
2. Pass such other orders this Hon’ble court may deem
fit and proper in the facts and circumstances of this case.
And for this, the complainant shall ever pray.
Dehradun
Dated: 25.03.2019
Complainant
Through

ADVOCATE
COUNSEL FOR THE COMPLAINANT
BEFORE,
The Notary Public

Dehradun (UTTARAKHAND)
(TO BE FILED BEFORE THE LEARNED COURT OF CHIEF

JUDICIAL MAGISTRATE, DEHRADUN IN CONNECTION WITH
COMPLAINT CASE NO. ____ OF 2019)
I, Kumar Shantanu, aged about

23 years, S/o Mr. Sunil Kumar,
R/o Kandoli (via Premnagar),
District Dehradun, do solemnly
affirm & declare as.
FOLLOWS:-
1. That I am the Complainant in the case under reference

and well conversant with the facts and the circumstances
of the case, thus am competent to swear this affidavit.
2. That the accompanying application u/s 156 (3) of Code of

Criminal Procedure, 1972 moved on behalf of the
complainant is the first complaint petition & beside the
accompanying petition, no similar petition has been filed
or is pending before this court or any other higher court,
till date.
DEPONENT
VERIFICATION
Verified at Dehradun on 29th day of March, 2019, that the

contents of my above affidavit are true and correct to my
knowledge and belief.
DEPONENT

in Re:-: 1. 2-3 2. 4 3. 5-8 4. 9 5. Annexure P-1

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IN THE COURT OF CHIEF JUDICIAL MAGISTRATE,

DISTRICT COURT, DEHRADUN (UTTARAKHAND)

Akhilesh Yadav & Ors. .………Opposite Party(s)

S. NO. PARTICULARS PAGES

1. Memo of Parties 2-3

3. Complaint Petition u/s 156 (3) of Cr. P. C. 5-8

(MRIDUL YASH DWIVEDI)

Akhilesh Yadav & Ors.

1. Mr. Kumar Shantanu

1. Mr. Akhilesh Yadav

3. Smt. Rani Devi

(MRIDUL YASH DWIVEDI)

Akhilesh Yadav & Ors. .………Opposite Party(s)

1. Mr. Nimish Patkar

2. Mr. Tushar Ghodesawar

(MRIDUL YASH DWIVEDI)

Akhilesh Yadav & Ors. .………Opposite Party(s)

Place of Occurrence Shikha NGO, Dehradun

Date & Time of Occurrence 28th February, 2019

Offence U/s: 370, IPC 1860

MOST RESPECTFULLY SHOWETH:-

1. That the complainant is a law abiding and peace loving

citizen of India and is a permanent resident of Kandoli,

2. That the Complainant is an active member of the Legal

Aid Society (LAS), Dehradun.

3. That for the purpose of conducting an empirical study on

social conditions of the orphans, the Complainant

accompanied by Witness No. 1 and 2 visited an NGO

named Shikha NGO in Dehradun which is currently

being operated and managed by the Opposite Party No. 1,

Party No. 2 and also the NGO is looked by two lady

workers, Opposite Party No. 3 & 4 of the present

4. That the complainant wants to submit that they saw that

the children which were looked after by said NGO were

not in the proper state and their state of conditions was

dilapidated and not satisfactory as through their

empirical study, they found that the children there were

very much scared and were reluctant to answer the

questions being asked by the Complainant and others

and were also reluctant to talk for a while which created

a thought of suspicion in the minds of the Complainant

and the witnesses of this complaint.

5. That due to above stated observations made by the

complainant and others, they started to visit the NGO

frequently. During this period, the complainant

approached a child aged 9 years but interestingly, the

child was very much reluctant to say even a hello to him.

6. That after many unsuccessful attempts, the complainant

had been taking place.

told that the children in that NGO were beaten by NGO

officials specially by Opposite Party No. 1 and 2.

8. That the child further disclosed that some girls were

taken out by the NGO officials in the name of having

medical checkups and getting them admitted into some