N.C.R.

B ëĂĒôäįĒą

I.I.F.-I äåäåëĄĦ

FIRST INFORMATION REPORT

(Under Section 154 Cr.P.C.)
ëöđĎđį
 ĘĄĝöĀđįēïđĈŪƟĒąĒāäåĂāđįđĦĪĩ

1. District ĒöĊđ C I D P.S. ÿđĂđ C I D PS Year ąČŪ 

FIR No. ĺćđáĂá  System Date and Time ĒôĘɳćįþđĒįðäįĔčćĠ hrs

Original Date and Time ƵïĖþþđĒįðäįĔčćĠ hrs

2. S.No. ƠĒćï Acts äåĂ Sections āđįđ

čáðƟđ
1 IPC 1860 120-B

2 IPC 1860 255

3 IPC 1860 256

4 IPC 1860 257

5 IPC 1860 259

6 IPC 1860 260

7 IPC 1860 406

8 IPC 1860 417

9 IPC 1860 419

10 IPC 1860 420

11 IPC 1860 463

12 IPC 1860 465

13 IPC 1860 466

14 IPC 1860 468

15 IPC 1860 471

16 IPC 1860 472

17 IPC 1860 474

18 IPC 1860 506

19 STATE EMBLEM OF INDIA 7(1)

(PROHIBITION OF IMPROPER USE) ACT,
2005
20 STATE EMBLEM OF INDIA 7(2)
(PROHIBITION OF IMPROPER USE) ACT,
2005

3. (a) Occurrence of offence òùĂđįãăįđā 

1 Day ĒĀĂđáï Intervening Days Date from ĘïđĂþđĒįðįăįđ  Date To ĺïđĂþđĒįðęĊ 

 

Time Period čćĠčēćđ  Time From ĘïđĂčćĠįăįđ hrs Time To ( ĺïđĂčćĠęĊ hrs

(b) Information received at P.S. ÿđĂđþþÿƟĺăđİđįčćĠ  Date ĒĀĂđáï  Time čćĠ hrs

(c) General Diary Reference ęĀĒĂïăǻēįƵčáñ  Entry No. ( ĻĀĒĂïăǻēĂá  Time čćĠ 
hrs

4. Type of Information þÿƟįƵïđį Written

5. Place of Occurrence òùĂđʆĊē 

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1. (a) Direction and distance from P.S. ÿđĂđįăįđĀĕįʲĒïćđĂäįĔĺïđĂĒĀċþ SOUTH-EAST, 7 Beat No. ĒąùĂá 
Km(s)
(b) Address LJïĂđ Delhi,Matak Automous Council, Dibrigarh, Spring Valley, Sonpur,Beltola,Guwahati,

(c) In case, outside the limit of this Police Station, then Name of P.S. ĈĒĀĘĎÿđĂđįăĒįčēćđįąđĒĎįþĎĠĺþĘȭäĂðĂÿđĂđį
ĂđćçĘɨðïįï 

District (State) ĒöĊđ įđöƟ 

6. Complainant / Informant ĘñđôįēĠđąđþŪđĒĀíàþđ 

(a) Name Ăđć Kamal Sabharwal

(b) Father's Name ͪ”ȡ s Name): Lt. Mahinder Sabharwal

(c) Date/Year of Birth öȶįĒĀĂąČŪ  (d) Nationality įđɲēĠþđ INDIA

(e) UID No. åçäåĒûĂá 

(f) Passport No. ăđõăùŪĂá 

Date of Issue ƵĀđĂïįđþđĒįð  Place of Issue ƵĀđĂïįđƓĎđĂ 

(g) Occupation öēĒİïđ 

(h) Address
LJïĂđ 

S.No. ƠĒćï Address Type LJïĂđįƵïđį Address LJïĂđ

čáðƟđ
1 Present Address 6779 JC-33 Shyamji Mal Lane,, Nabi Karim,Pahar Ganj Delhi, NEW DELHI,
DELHI-110055, INDIA
2 Permanent Address 6779 JC-33 Shyamji Mal Lane,, Nabi Karim,Pahar Ganj Delhi, NEW DELHI,
DELHI-110055, INDIA
(i) Phone number ĀĕįĆđČâį  Mobile ĘćđąđåĊĂá 

7. Details of known / suspected / unknown accused with full particulars ǷđþãǷđþäôđćēąđčĘȱĎĈĔǏöĂįčɑĕŪýþÿƟ 

S. No. ƠĒćï Name Ăđć Alias íįĘĄ Relative's Name č˘ȴēĠį Present Address(ąþŪćđĂLJïĂđ
čáðƟđ  Ăđć
1 Khushdeep Bansal Father's Name: Tej Paul 1. w5/27 western abenu,Sainik
Bansal Firm,Delhi,NEW DELHI,DELHI,INDIA
2 Shashwat singh Bundela Yadvendra Singh 1. 106,Ward No 3,Tal
Darwaja,Tikamgarh,TIKAMGARH,MADHY
A PRADESH,INDIA
3 Harish Bansal Father's Name: Tej Paul 1. W 10c 12,Sainik Firm,Delhi,NEW
Bansal DELHI,DELHI,INDIA
4 Dilip Singh Baghel Father's Name: Bhagwant 1. 468,Patna
Singh Baghel House,khutehi,Huzur,REWA,MADHYA
PRADESH,INDIA
5 Pallavi Thakuria Didi 1. Guwahati,GUWAHATI
CENTRAL,ASSAM,INDIA
6 partha Bhardwaj 1. Chandan
nagar,Beltola,DISPUR,GUWAHATI
EAST,ASSAM,INDIA

8. Reasons for delay in reporting by the complainant / informant ĺñđôįēĠđąđþŪđĒĀíþđöĘĂąđþŪđĒĀĠđþăĊćĺĎđİđįïđįý 

9. Particulars of properties of interest äĂĔčáĒñïčɑĒȑįĒąİįý 

S. No. ƠĒćï Propertty Category čɑĒȑįąñŪ Property Type čɑĒȑį Description Value(In Rs/-)
čáðƟđ Ƶïđį Ēąİįý ćĕĊƟ ùïđþ

10. Total value of property stolen (In Rs/-) ôĔĒįĺĎđİđčɑĒȑįćĕĊƟ ùïđþ 

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11. Inquest Report / U.D. case No., if any ôĔįƄĎđĊįƵĒþĘąĀĂã˰đĆđĒİïćĖþĔƟĺćđáĂá 

S. No. UIDB Number ãĒôĂđĒïćĖþĘĀĎįâį

€QƠĒćï
čáðƟđ

12. First Information contents ëöđĎđįþčĒȵĒąɳĒąİįý 

THE BRIEF OF THE CASE IS THAT COMPLAINT SRI KAMAL SABHARWAL, DIRECTOR & AUTHORISED REPRESENTATIVE
OF “SABHARWAL TRADING INDIA PVT. LTD.” OFFICE: 6779 JC-33 SHYAMJI MAL LANE NABI KARIM PAHAR GANJ,
DELHI-110055 ,MOB.: +91-7291969898 LODGED A FIR AT CID HQ. ASSAM, ULUBARI, GUWAHATI ADDRESSING TO THE
SUPERINTENDENT OF POLICE, CID, ASSAM, ULUBARI, GUWAHATI ON 09/10/2023 AT 6:30 PM, AGAINST 1. KHUSHDEEP
BANSAL, 2.PARTHA BHARDWAJ, 3. SHASHWAT SINGH BUNDELA, 4. HARISH BANSAL, 5.DILIP SINGH BHAGEL, 6.PALLAVI
THAKURIA AKA DIDI, AND 7. OTHER KNOWN AND UNKNOWN ACCUSED PERSONS INTER-ALIA, FOR THE COMMISSION
OF SERIOUS COGNIZABLE OFFENCES UNDER SECTIONS 255, 256, 257, 259, 260, 406, 417, 419, 420, 463, 465, 466, 468, 471, 472,
474, 506 & 120B OF THE INDIAN PENAL CODE, 1860, SECTION 7 OF THE STATE EMBLEM OF INDIA (PROHIBITION OF
IMPROPER USE) ACT, 2005 AND OTHER PENAL OFFENCES, FOR CHEATING BY PERSONATION AS A PUBLIC SERVANT,
FORGERY OF VALUABLE SECURITY AND COUNTERFEITING SEALS AND SUCH DOCUMENTS WITH THE DISHONEST
INTENTION TO MISAPPROPRIATE FUNDS IN COMPLETE CRIMINAL BREACH OF TRUST AND OTHER PENAL OFFENCES IN
CONSPIRACY AND COLLUSION WITH EACH OTHER.
I RESPECTFULLY REPORT AS UNDER:
1.THE PRESENT COMPLAINT IS BEING FILED BY M/S SABHARWAL TRADING INDIA PVT. LTD., A DULY REGISTERED
COMPANY UNDER THE COMPANIES ACT, 1956, HAVING ITS REGISTERED OFFICE AT 6779 JC-33 SHYAMJI MAL LANE, NABI
KARIM, PAHAR GANJ DELHI-110055 HAVING PAN NO. AAZCS2890J, THROUGH ITS AUTHORIZED REPRESENTATIVE, MR.
KAMAL SABHARWAL, BEFORE YOUR GOOD OFFICE SEEKING REGISTRATION OF FIR AGAINST THE ACCUSED PERSONS
NAMELY, (I) SHRI KHUSHDEEP BANSAL, (II) SHRI PARTHA BHARDWAJ, (III) HARISH BANSAL, (IV) SHRI SHASHWAT
SINGH BUNDELA, (V) SHRI DILIP SINGH BAGHEL, (VI) SMT. PALLAVI THAKURIA AND OTHER KNOWN AND UNKNOWN
ACCUSED PERSONS FOR THE COMMISSION OF SERIOUS COGNIZABLE OFFENCES UNDER SECTIONS 255, 256, 257, 259, 260,
406, 417, 419, 420, 463, 465, 466, 467, 468, 471, 472, 474, 506 AND 120B OF THE INDIAN PENAL CODE, 1860, SECTION 7 OF THE
STATE EMBLEM OF INDIA (PROHIBITION OF IMPROPER USE) ACT, 2005 AND OTHER PENAL OFFENCES.
1.BRIEF DESCRIPTION OF THE COMPLAINANT AND ITS ASSOCIATES,
THE COMPLAINANT IS A WELL KNOWN COMPANY DEALING IN MULTIPLE ACTIVITIES PRIMARILY OF TRADING OF
VARIOUS GOODS LIKE ZIPPER FASTENER, SLIDER FASTENER, POLYESTER FABRIC AND LUGGAGE RELATED
MATERIALS/ACCESSORIES AND IS A CLOSELY SHAREHOLDING PRIVATE LIMITED COMPANY. MR. RAJINDER SHARMA
AND MR. MOHIT KALRA BOTH ARE THE BUSINESS ENTREPRENEUR AND ASSOCIATE/BUSINESS PARTNERS OF THE
COMPLAINANT (ASSOCIATE), HAVE A LONG BUSINESS ASSOCIATION WITH THE COMPLAINANT AS THAT BOTH THE
COMPLAINANT AND THESE ASSOCIATES ARE INTO RELATED BUSINESS ACTIVITIES AND ARE INTERLINKED IN MANY
OF THE BUSINESS ACTIVITIES. LIKEWISE, ASSOCIATES/BUSINESS PARTNERS ARE ALSO INTO MANUFACTURING AND
BUSINESS OF MANUFACTURING AND DISTRIBUTION OF BAGS, FABRIC, ZIPPERS AND OTHER ALLIED PRODUCTS.
2.BRIEF DESCRIPTION OF ACCUSED:
THAT THE PRESENT COMPLAINT IS BEING FILED, INTER-ALI, FOR THE COMMISSION OF THE OFFENCES OF CHEATING,
CRIMINAL BREACH OF TRUST, FRAUD, FORGERY & USAGE OF FORGED DOCUMENTS. FALSIFICATION OF ACCOUNTS,
EMBEZZLEMENT OF FUNDS, CAUSING WRONGFUL LOSS TO THE COMPLAINANT, AND FOR WRONGFUL GAIN TO
THEMSELVES, CRIMINAL CONSPIRACY AND CRIMINAL INTIMIDATION AGAINST THE FOLLOWING PERSONS:
1.SH.KHUSHDEEP BANSAL, R/O W5/27, WESTERN AVENUE. SAINIK FARMS, DELHI 110062, PASSPORT NUMBER Z6805245,
2.PARTHA BHARDWAJ, R/O VILLA NO. 18, KUMARKUCHI, NEAR SPRING VALLEY RESORT, SONAPUR, GUWAHTI, ASSAM-
782402, AADHAR NUMBER- 673336099049 AND ADDRESS AS PER AADHAR - HOUSE NO 04, CHANDAN NAGAR, BELTOLA
SURVEY, KAMARPUR METRO, ASSAM, 781028
3.SHASHWAT SINGH BUNDELA S/O YADVENDRA SINGH, R/O HOUSE NO. 106/4, WARD NO. 3, TAL DARWAJA,
TIKAMGARGH, M.P 472001, AADHAR NUMBER 573748081043
4.HARISH BANSAL R/O W10C/12, SAINIK FARMS, DELHI 110062, PASSPORT NUMBER Z5532476,
5.DILIP SINGH BAGHEL, S/O BHAGWANT SINGH BAGHEL, R/O 468, WARD 7, PATNA HOUSE, KHUTEHI, REWA, M.P- 486001,
AADHAR NUMBER 818769265132
6.PALLAVI THAKURIYA AKA “DIDI” R/O JYOTINAGAR, GUWAHATI, ASSAM -781021.
7.OTHER KNOWN AND UNKNOWN PERSONS.(HEREIN COLLECTIVELY REFERRED AS ACCUSED)
1.THE SUBSEQUENT PARAGRAPHS WILL BROADLY OUTLINE THE MODUS OPERANDI AND THE BROAD SUB HEADS OF
THE ILLEGAL ACTS OF THE ACCUSED.
1.KHUSHDEEP BANSAL, HIS BROTHER HARISH BANSAL, PARTHA BHARDWAJ AND OTHER ACCUSED PERSONS INDUCED
THE COMPLAINANT AND HIS ASSOCIATES INTO BELIEVING THAT THE WORK ASSIGNED WAS A GOVERNMENT
CONTRACT. THEY ALSO ACTIVELY PARTICIPATED WITH EACH OTHER INTO ENTRAPPING THEM IN AN ELABORATE
SCHEME OF FRAUD CUM FORGERY AND AS A RESULT THE COMPLAINANT AND THEIR ASSOCIATES SUPPLIED HUGE
CONSIGNMENTS OF GOODS. IT NOW TRANSPIRES THAT THE ENTIRE TRANSACTION WAS AN ELABORATE SCHEME OF
FRAUD WHEREIN NAMES OF THE TOP FUNCTIONARY OF THE STATE GOVERNMENT OF ASSAM INCLUDING THE HONBLE
CM WAS USED. FORGED AND FABRICATED SEALS AND DOCUMENTS OF THE ASSAM GOVERNMENT WERE USED TO
GIVE AUTHENTICITY TO THE DECEPTION RESULTING IN DEFRAUDING OF THE COMPLAINANT VAST SUMS OF MONEY.
THEY CONSPIRED WITH EACH OTHER TO IMPERSONATE AND CREATE A FALSE IMPRESSION THAT THE ACCUSED NO. 2
IS A ASSAM GOVERNMENT FUNCTIONARY AND WAS ENTRUSTED BY THE HON’BLE CM ’S OFFICE TO EXECUTE SOCIAL
WELFARE PROJECTS. IN ORDER TO FURTHER THEIR OBJECTIVE OF CHEATING BY PERSONATION, THEY FABRICATED
AND PREPARED FORGED DOCUMENTS OF ASSAM GOVERNMENT. THEY ALSO COUNTERFEITED OFFICIALS STAMPS AND
SEALS WHICH THEY WERE AWARE TO BE FALSE.THE TRUE COPY OF VISITING CARD OF ACCUSED NO. 2 AND LETTER
HEAD OF MATAK AUTONOMOUS COUNCIL ARE ANNEXED AS ANNEXURE 2 AND ANNEXURE 3 RESPECTIVELY.

3.BRIEF FACTS REGARDING THE ACQUITTANCE AND INTERACTION OF THE COMPLAINANT AND ITS ASSOCIATES WITH
THE ACCUSED(S):
1.MR. KHUSHDEEP BANSAL IS A PROFESSIONAL FORTUNE TELLER (JYOTISH). MR. MOHIT KALRA AND MR. RAJINDER
SHARMA ALSO CONSULTED MR. KHUSHDEEP BANSAL. THESE INTERACTIONS OVER A PERIOD OF TIME RESULTED IN
FRIENDLY RELATIONS. DUE TO THE PROXIMITY WHICH DEVELOPED OVER A PERIOD OF TIME, MR. KHUSHDEEP
BANSAL BECAME AWARE OF THE BUSINESS BEING DEALT BY THEM. MR BANSAL WAS ALSO AWARE THAT ALL OF
THEM HAVE CONSIDERABLE FINANCIAL AND PROFESSIONAL CAPABILITY TO EXECUTE BIG PROJECTS AND KNOWING
THEIR CAPABILITIES OVER A PERIOD OF TIME STARTED CLAIMING HIS PROXIMITY TO SEVERAL GOVERNMENT
FUNCTIONARIES WITH WHOM HE CAN GET THEM INTRODUCED. MR. BANSAL ALSO GOT TO KNOW ABOUT THE
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COMPLAINANT AND AFTER GETTING CONSIDERABLE INFORMATION STARTED TO ENTICING THEM WITH PROPOSAL
FOR GOVERNMENT PROJECTS.
2.ON 17.09.2022 SH. KHUSHDEEP BANSAL INDUCED MR. MOHIT KALRA, MR. RAJINDER SHARMA AND SH. KAMAL
SABHARWAL THAT THE GOVERNMENT OF ASSAM IS LOOKING FOR SUPPLIER, IN BULK, GOODS WHICH INCLUDES
SCHOOL BAGS, BLANKETS ETC. FOR A PROJECT OVERSEEN BY THE CM FOR THE WELFARE OF THE PEOPLE IN VARIOUS
DISTRICTS IN ASSAM. SH. KUSHDEEP BANSAL CLAIMED THAT HE HAS GOOD CONTACTS WITH EXTREMELY
RESOURCEFUL OFFICIALS AT THE TOP ECHELONS OF THE GOVERNMENT OF ASSAM AND CAN BE INSTRUMENTAL IN
GETTING THE PROJECT FOR THEM. HE CLAIMED THAT THE CONTRACT VALUE FOR THE AFORESAID COMMODITIES IS
RS. 260,66,40,000/- [RUPEES TWO HUNDRED AND SIXTY CRORES SIXTY-SIX LAKHS AND FORTY THOUSAND ONLY]. HE
THROUGH WHATSAPP ALSO FORWARDED A SNAPSHOT OF THE REQUIREMENT OF THE AFORESAID PRODUCTS AND
IMAGES OF APPROVED PRODUCTS, PREVIOUSLY SOURCED BY THE GOVERNMENT OF ASSAM THROUGH MATAK
AUTONOMOUS COUNCIL, THROUGH OTHER VENDORS. A SCREENSHOT OF THE WHATSAPP MESSAGE RECEIVED BY SHRI
MOHIT KALRA FROM SHRI KHUSHDEEP BANSAL (SAVED IN HIS PHONE AS KHUSHDEEP UNCLE) SHARING THE
AFORESAID INFORMATION IS EXTRACTED HEREIN BELOW FOR READY REFERENCE AS FOLLOWS:
3.SH.KHUSHDEEP BANSAL IN ORDER TO GIVE FURTHER SUPPORT TO HIS ASSURANCES INDUCTED HIS BROTHER
SH.HARISH BANSAL. MR. KHUSDEEP BANSAL ASSURED THAT HIS BROTHER SH.HARISH BANSAL WILL MANAGE THE
TRANSACTION FROM DELHI AND WILL ACT AS GO BETWEEN ALL THE OTHER ACCUSED PERSONS SO THAT NO
GLITCHES OR HICCUPS HAPPENS IN IMPLEMENTATION OF THE PROJECT. IN ORDER TO HAVE A SEAMLESS
TRANSACTION AND FURTHER PAYMENTS ARE RECEIVED WITHOUT ANY DEMUR HE CLAIMED THAT HIS BROTHER
WILL WORK IN THAT REGARD. HE ALSO SOUGHT THAT HIS BROTHER MAY BE GIVEN SOME COMPENSATION FOR HIS
SERVICES RENDERED.
4.SHRI KUSHDEEP BANSAL, ON 17 SEPTEMBER 2022, FURTHER CLAIMED THAT HE AND HIS BROTHER, SHRI HARISH
BANSAL, PERSONALLY KNOWS THE PRINCIPAL SECRETARY AND MANAGING DIRECTOR OF MATAK AUTONOMOUS
COUNCIL, SHRI PARTHA BHARDWAJ. IT IS NOW EVIDENT THAT, SHRI KHUSHDEEP BANSAL WAS THE MASTERMIND
BEHIND THE ENTIRE CONSPIRACY AS IT WAS HIM WHO WAS LOOKING FOR VICTIMS TO BE DEFRAUDED WITH AID AND
ASSISTANCE OF THE OTHER ACCUSED PERSONS. EVIDENTLY, IT WAS SHRI KHUSHDEEP BANSAL AND SHRI HARISH
BANSAL, WHO CLAIMED TO PERSONALLY KNOW SHRI PARTHA BHARDWAJ AND ALSO VOUCHED FOR HIS POSITION IN
THE MATAK AUTONOMOUS COUNCIL. SHRI KHUSHDEEP BANSAL AND HIS BROTHER SHRI HARISH BANSAL FURTHER
REPRESENTED TO THE COMPLAINANT COMPANY THAT HE HAS WORKED WITH MANY GOVERNMENT DEPARTMENTS IN
THE PAST AND HAD PERSONALLY INVESTED IN SIMILAR PROJECTS WHICH WERE HANDLED BY THE OTHER ACCUSED
PERSON, I.E., SHRI PARTHA BHARDWAJ AND HIS TEAMS.
5.IN ORDER TO FURTHER GAIN TRUST AND DECEIVE THE COMPLAINANT COMPANY, SHRI KHUSHDEEP BANSAL, AFTER
HAVING THE CONVERSATION IN THE MORNING, ASKED THE UNDERSIGNED AND OTHER ASSOCIATES OF THE
COMPLAINANT COMPANY TO ATTEND A MEETING AT HIS OFFICE IN DEFENCE COLONY, NEW DELHI IN THE EVENING
OF 18 SEPTEMBER 2022.
6.ON 18.09.2022, THE “ASSOCIATE” OF THE COMPLAINANT WERE CALLED BY SH. KHUSHDEEP BANSAL AT HIS OFFICE AT
DEFENCE COLONY. DURING THE SAID MEETING SH. BANSAL EXPLAINED AND ELABORATED ABOUT THE WORK
INVOLVED. SH. KHUSHDEEP BANSAL ALSO GAVE A ROUGH IDEA AS TO THE TOTAL VALUATION, QUALITY OF GOODS
REQUIRED, TIMELINES ETC. IN RESPECT OF THE WORK WHICH WAS TO BE UNDERTAKEN.
7.THE COMPLAINANT AND ITS ASSOCIATES/ BUSINESS PARTNERS NAMELY ALONG WITH HIS ASSOCIATES, SH.MOHIT
KALRA, AND RAJINDER SHARMA WERE INTRODUCED TO SH.DILIP SINGH BAGHEL AND SH. SANJEEV MEHROTRA BY
MR. KHUSHDEEP BANSAL AND HIS BROTHER. IT WAS GIVEN TO BELIEVE THAT SH. DILIP SINGH BHAGEL AND
SH.SANJEEV MEHROTRA WERE REPRESENTATIVES OF ONE MATAK AUTONOMOUS COUNCIL, A GOVERNMENT OF
ASSAM CONCERN. THAT ACCUSED NO.2 WAS HELD OUT AS THE OVERALL IN-CHARGE OF THE PROJECT AND THE
POINTS MAN. SH.KHUSHDEEP BANSAL AND HIS BROTHER ASSURED THAT THEY SHALL BE PERSONALLY
COORDINATED THE ENTIRE TRANSACTION FROM DELHI. MEANWHILE, AS A PART OF THE LARGER CONSPIRACY,
ACCUSED SHRI DILIP SINGH BAGHEL ALSO PROVIDED SHRI MOHIT KALRA A SAMPLE OF MOU ISSUED BY MATAK
AUTONOMOUS COUNCIL IN FAVOUR OF A THIRD PARTY. AS DIRECTED, SHRI MOHIT KALRA PROVIDED ALL THE
AFORESTATED DOCUMENTS OF THE COMPLAINANT COMPANY TO DILIP SINGH BAGHEL THROUGH WHATSAPP.
8.DURING THE MEETING HELD ON 18.09.2022 AT HIS OFFICE, SH.KHUSHDEEP BANSAL INDUCED THE ASSOCIATES OF THE
COMPLAINANT INTO BELIEVING THAT THE ENTIRE PROJECT IS AN INITIATIVE OF THE HON’BLE CM OF ASSAM AND
WILL BE DIRECTLY MONITORED BY HIS OFFICE. THE GOODS WERE CLAIMED TO BE DISTRIBUTED TO THE CHILDREN OF
HOLDERS OF BPL CARD.
9.IN THE SAID MEETING, SHRI KHUSHDEEP BANSAL, EXPLAINED IN DETAIL, THE COMPLETE DETAILS OF ALL THE
WORKS TO BE DONE BY THE COMPLAINANT COMPANY UNDER THE PROJECT AND PROVIDED 22 SEPTEMBER 2022 AS
THE DATE OF TRAVEL FOR THE REPRESENTATIVES OF THE COMPLAINANT COMPANY TO DIBRUGARH, ASSAM TO MEET
ACCUSED SHRI PARTHA BHARDWAJ AND OTHER OFFICIALS OF THE GOVERNMENT OF ASSAM. SHRI KHUSHDEEP
BANSAL FURTHER INFORMED US THAT SHRI PARTHA BHARDWAJ WAS THE PRINCIPAL SECRETARY AND MANAGING
DIRECTOR OF MATAK AUTONOMOUS COUNCIL AND HE HAD A LONGSTANDING RELATIONSHIP WITH HIM.
10.MEANWHILE, ON 20 SEPTEMBER 2022, PURSUANT TO THE MEETING DATED 18 SEPTEMBER 2022, ACCUSED SHRI DILIP
SINGH BAGHEL, SHARED WITH SHRI MOHIT KALRA THROUGH WHATSAPP, THE BOARDING PASSES ISSUED IN FAVOUR
OF SHRI DILIP SINGH BAGHEL, SANJEEV MEHROTRA AND SHASHWAT SINGH BHUNDELA FOR TRAVEL TO DIBRUGARH,
ASSAM FROM NEW DELHI ON 21 SEPTEMBER 2022.
4.BRIEF FACTS ABOUT THE ENTRY OF THE ACCUSED IN THE ALLEGED TRANSACTION OF PURCHASE OF THE ITEMS BY
WAY OF MEMORANDUM OF UNDERSTANDING DATED 23.09.2022 BEARING NO. MAC-73/DSW(ME)/MOU/2022-23/301 AND
MAC-73/DSW(ME)/MOU/2022-23/304.
1.IN PURSUANCE THERETO THE MEMORANDUM OF UNDERSTANDING, BEARING NO. MAC-73/DSW(ME)/MOU/2022-23/301
TWO AWARDS WERE ISSUED IN FLAVOR OF COMPLAINANT VIDE AWARD DATED 22. BEARING AWARD NO. MAC/DSW
(ME)/WPT/2022-23/270 AND AWARD DATED 23.09.2022 BEARING NO. MAC/DSW(ME)/WPT/2022-23/274. THE TRUE COPIES OF
MOUS AND AWARDS ARE ANNEXED HEREWITH AS ANNEXURE 4 AND ANNEXURE AS 5 COLLECTIVELY AND
RESPECTIVELY.
2.IN ORDER TO COMPLETE THE FORMALITIES WHICH INCLUDES FORMAL APPROVALS, SINGING OF THE NECESSARY
DOCUMENTS ETC., THE ACCUSED DIRECTED THE COMPLAINANT’S AR MR. KAMAL SABHARWAL, MR. MOHIT KALRA
AND MR. RAJINDER SHARMA LEFT FOR DIBRUGARH, ASSAM AND UPON REACHING THERE, CHECKED INTO HOTEL TREE
FIRM, DIBRUGARH. SOMETIME AFTER REACHING THE HOTEL, TWO PERSONS, NAMELY, SHRI SHASHWAT SINGH
BUNDELA AND SMT. PALLAVI THAKURIYA @ DIDI CAME TO THE HOTEL AND REPRESENTED THAT THEY ARE THE
OFFICIALS OF THE GOVERNMENT OF ASSAM. THEY FURTHER INFORMED THE UNDERSIGNED AND OTHERS THAT, SHRI
PARTHA BHARDWAJ IS AWAITING THE PRESENCE OF THE UNDERSIGNED AND OTHERS AT HIS OFFICE SITUATED IN THE
OFFICIAL COMPLEX OF MATAK AUTONOMOUS COUNCIL, DIBRUGARH, ASSAM. THE MEETING WAS FIXED AT THE
INSTANCE OF SH. PARTHA BHARDWAJ. THE SAID MEETING WAS FACILITATED BY SH. KHUSHDEEP BANSAL, SH. DILIP
SINGH BHAGEL AND SH. SANJEEV MEHROTRA.
3.AT HOTEL TREE FIRM, DIBRUGARH, DILIP SINGH BAGHEL & PALLAVI THAKURIA ASKED THEM TO ACCOMPANY THEM
TO THE ALLEGED HEAD OFFICE OF MATAK AUTONOMOUS COUNCIL. THE SAID ACCUSED PERSONS FURTHER CLAIMED
THAT SINCE ALL PAPER WORK AND DOCUMENTATION SHALL BE HANDLED AND PROCESSED FROM THE OFFICE AT
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CHIRING GAON, DIBRUGARH, ASSAM SINCE, IT IS NECESSARY TO FURTHER ALL TRANSACTIONAL REQUIREMENTS
FROM THE SAID OFFICE.
4.ON REACHING THE SAID OFFICE AT CHIRING GAON, SH.KAMAL SABHARWAL, SH.MOHIT KALRA AND SH.RAJINDER
SHARMA WERE ASKED TO WAIT IN ONE ROOM WHICH IS CLAIMED TO BE A CONFERENCE ROOM. ACCUSED NO.3 & 6
THEREAFTER, LEFT THEM IN THE SAID ROOM ON THE PRETEXT THAT THEY ARE REQUIRED TO INFORM ACCUSED NO.2
AND OTHER OFFICIALS ABOUT THE ARRIVAL OF THE ABOVE PERSONS.
5.AFTER ABOUT AN HOUR SH.KAMAL SABHARWAL, SH.MOHIT KALRA AND SH.RAJINDER SHARMA WERE ASKED TO
JOIN THE REMAINING ACCUSED NO. 5 AND 6 IN ANOTHER ROOM WHERE THEY WERE INTRODUCED TO ACCUSED NO. 2-
PARTHA BHARDWAJ FOR THE FIRST TIME. SH.PARTHA BHARDWAJ PERSONATED HIMSELF AS AN OFFICER OF THE
RANK OF PRINCIPAL SECRETARY AND HEAD OF MATAK AUTONOMOUS COUNCIL, GOVERNMENT OF ASSAM. HE
CLAIMED THAT HE IS AN ASSAM CIVIL SERVICES OFFICER. HE ALSO HANDED OVER HIS VISITING CARD, WHICH
REFLECTED HIM TO BE THE MANAGING DIRECTOR OF MATAK AUTONOMOUS COUNCIL. THE SAID CARD ALSO BORE
THE OFFICIAL STATE EMBLEM OF INDIA, I.E., SARNATH LION CAPITAL OF ASOKA IMPRINTED IN GOLD. HE GAVE A
BRIEF INTRODUCTION ABOUT THE PROJECT AND THE VISION STATEMENT OF THE CM’S PROJECT. HE FURTHER
EXPLAINED THAT 4,25,000 BLANKETS, 4,25,000 MOSQUITO NETS AND 2,00,000 SCHOOL BAGS WERE REQUIRED TO BE
SUPPLIED TO MATAK AUTONOMOUS COUNCIL FOR DISTRIBUTION TO CHILDREN OF HOLDERS OF BPL CARD.
HOWEVER, AFTER ABOUT 10 TO 15 MINUTES INTO THE MEETING HE SUDDENLY RECUSED HIMSELF ON THE PRETEXT
THAT DUE TO OFFICIAL WORK HE NEEDS TO PROCEED TO GUWAHATI. HE ALSO SAID THAT FURTHER TRANSACTIONS
WILL BE DONE AT GUWAHATI SINCE IT WAS RISKY TO GRANT ORDERS IN DIBRUGARH TO OUTSIDERS. THEY CLAIMED
THAT THERE IS AN EMINENT THREAT FROM THE LOCAL BUSINESSMEN AND MAFIA HENCE, ALL ORDERS AND
FURTHER PAPERWORK SHALL BE DEALT FROM GUWAHATI. THIS WAS CONFIRMED BY SH.KHUSHDEEP BANSAL AND
HIS BROTHER AS WELL. ACCUSED NO.2 & 3 CLAIMED THAT LOCALS DO NOT LIKE OUTSIDERS ESPECIALLY NORTH
INDIANS. THEY ALSO CLAIMED THAT SINCE IT IS A VERY BIG AND PRESTIGIOUS PROJECT OF THE HON’BLE CM HENCE,
SEAMLESS SUPPLIES WERE REQUIRED WHICH LOCAL SUPPLIERS MAY NOT BE CAPABLE TO EXECUTE. AT THAT POINT
IN TIME NOTHING SUSPICIOUS WAS OBSERVED. HE ALSO INFORMED SH.KAMAL SABHARWAL, SH.MOHIT KALRA AND
SH.RAJINDER SHARMA THAT THE NEXT LEG OF THE MEETINGS WILL BE HELD AT GUWAHATI THE NEXT MORNING. HE
DIRECTED HIS STAFF TO HANDOVER A PURCHASE ORDER TO SH.KAMAL SABHARWAL.
6.IT IS PERTINENT TO MENTION HEREIN THAT IN ORDER TO CREATE A PERFECT FAÇADE, AN ELABORATE SETUP WAS
SHOWN TO BE OPERATED FROM THE SAID PREMISES. THE FAÇADE INCLUDED OFFICE PARAPHERNALIA, NAME PLATES,
INSIGNIA OF THE GOVERNMENT OF ASSAM, SIGNAGE ETC. THE ACCUSED PERSONS WERE USING GOVERNMENT
STATIONARY, WHICH INCLUDED LETTER HEADS, SEAL, STAMPS, FILE COVERS ETC. TO NAME A FEW.
7.IT NOW TRANSPIRES THAT EVERYTHING WAS FALSE, FABRICATED AND TOTALLY FAKE. IT WAS A WELL-
ORCHESTRATED MOVE ON THE PART THE ACCUSED PERSONS TO CREATE AN IMPRESSION OF AUTHENTICITY WITH
THE SOLE INTENTION TO CHEAT BY INDULGING IN IMPERSONATION WHICH ENTRAPPED THE COMPLAINANT AND ITS
ASSOCIATES WHO AS UNSUSPECTING PARTIES BELIEVED THE SAID SET UP AS REAL AND GENUINE.
8.SH.PARTHA BHARADWAJ CLAIMED THAT DUE TO POLITICAL EXIGENCY OF THE CM’S OFFICE IT WOULD KEEP ITS
DISTANCE FROM SUCH LOCAL POLITICS OF DIBRUGARH. THEREFORE, THE CONCERNED MINISTRY IS NOT DIRECTLY
DEALING WITH THE PROJECT BUT CHANNELED IT THROUGH MATAK AUTONOMOUS COUNCIL OF THE GOVERNMENT
OF ASSAM. IN THE MEANTIME, ACCUSED NO.2 DIRECTED ACCUSED NO.3 TO COLLECT ALL THE NECESSARY RECORDS
OF COMPLAINANT COMPANY SUCH AS MOA, PAN, COPY OF AADHAR CARD OF ALL DIRECTORS, BOARD RESOLUTION
ETC. FOR VERIFICATION.
9.IN THE MORNING OF 23.09.2022, SH.SHASHWAT SINGH BUNDELA INFORMED SH.KAMAL SABHARWAL AND HIS
ACCOMPANYING ASSOCIATES SH.MOHIT KALRA AND SH.RAJINDER SHARMA TO REACH THE HOUSE OF THE ACCUSED
NO.2 AT HOUSE/VILLA NO.18, KUMARKUCHI, NEAR SPRING VALLEY RESORT, SONPUR, GUWAHATI, ASSAM-782402. HE
CLAIMED THAT SINCE SH.PARTHA IS AN OFFICER OF THE RANK OF PRINCIPAL SECRETARY AND HOLDING SENSITIVE
PORTFOLIO WHICH REQUIRES HIS 24X7 ATTENTION THEREFORE, THE GOVERNMENT HAS PROVIDED A FULLY
OPERATIONAL OFFICE AT HIS RESIDENCE. FURTHER, IT WAS ALSO GIVEN TO BELIEVE THAT AS THE ACCUSED NO.1 IS
EXTREMELY CLOSE TO THE CM SO ALL SENSITIVE MEETINGS ARE HELD AT HIS RESIDENCE SO MEDIA GLARE CAN BE
DEFLECTED.
10.ACCORDINGLY, ALL OF US LEFT BY TRAIN IN THE NIGHT OF 22 SEPTEMBER 2022 FROM DIBRUGARH, ASSAM AND
PROCEEDED TO GUWAHATI FOR FURTHER NEGOTIATIONS AND DISCUSSIONS TO BE CARRIED OUT WITH SHRI PARTHA
BHARDWAJ AND OTHER ACCUSED PERSONS. IN GUWAHATI, WE WERE DIRECTED TO REACH THE LOCATION, I.E.,
HOUSE/VILLA NO.18, KUMARKUCHI, NEAR SPRING VALLEY RESORT, SONPUR, GUWAHATI, ASSAM-782402. N THE
MEETING HELD AT THE AFORESAID PLACE, SHRI PARTHA BHARDWAJ, SHRI SHASHWAT SINGH BUNDELA AND SMT.
PALLAVI THAKURIYA @ DIDI WERE PRESENT ALONG WITH OTHER STAFF. IN THE MEETING, THE REQUIREMENT OF THE
GOVERNMENT OF ASSAM THROUGH MATAK AUTONOMOUS COUNCIL ALONG WITH THE ENTIRE PROCESS OF SUPPLY
WAS EXPLAINED IN DETAIL TO US. SHRI PARTHA BHARDWAJ FURTHER CLAIMED THAT IN ORDER TO START THE
PROCESS, THE ACCUSED PERSONS FIRST WANTED SUPPLIES OF 4,25,000 BLANKETS, 4,25,000 MOSQUITO NETS AND
2,00,000 SCHOOL BAGS OF PARTICULAR SPECIFICATIONS.
11.AT THIS POINT, SHRI PARTHA BHARDWAJ CALLED UP SHRI KHUSHDEEP BANSAL AND INFORMED HIM THAT AS
SUGGESTED, MATAK AUTONOMOUS COUNCIL IS PROVIDING MEMORANDUM OF UNDERSTANDING [HEREINAFTER
REFERRED TO AS “MOU”] AND LETTERS OF AWARDS IN FAVOUR OF THE COMPLAINANT COMPANY FOR THE
AFORESAID THREE PRODUCTS. ACCORDINGLY, SHRI PARTHA BHARDWAJ, SHRI SHASHWAT SINGH BUNDELA AND SMT.
PALLAVI THAKURIYA @ DIDI HANDED OVER THE FOLLOWING DOCUMENTS TO THE ASSOCIATES OF THE
COMPLAINANT COMPANY-
1.MEMORANDUM OF UNDERSTANDING NO. MAC-66/DSW(ME)/MOU/2022-23/304 DATED 23 SEPTEMBER 2022 FOR SUPPLY
OF 4,25,000 DOUBLE QUOTED BLANKETS, OF SPECIFICATIONS MENTIONED THEREIN @ RS. 950/- PER BLANKET AND
4,25,000/- MOSQUITO NETS @ RS. 1,650/- EACH. THE CONTRACT VALUE FOR THE SAID MOU WAS STATED TO RS.
110,05,00,000/- [RUPEES ONE HUNDRED AND TEN CRORES AND FIVE LAKHS ONLY]. THE SAID MOU WAS ISSUED ON THE
PURPORTED LETTERHEAD OF GOVERNMENT OF ASSAM WITH THE OFFICIAL STATE EMBLEM OF INDIA. THE MOU WAS
SIGNED BY THE UNDERSIGNED AND PRINCIPAL SECRETARY, MATAK AUTONOMOUS COUNCIL. THE SAID MOU ALSO
BORE THE SEAL OF MATAK AUTONOMOUS COUNCIL WHICH ALSO HAD THE OFFICIAL STATE EMBLEM OF INDIA IN IT.
2.ALONG WITH THE MOU, THE UNDERSIGNED WAS ALSO HANDED OVER A LETTER OF AWARD NO. MAC-73/DSW
(ME)/MOU/2022-23/301 DATED 23 SEPTEMBER 2022 FOR SUPPLY OF 4,25,000 DOUBLE QUOTED BLANKETS, OF
SPECIFICATIONS MENTIONED THEREIN @ RS. 950/- PER BLANKET AND 4,25,000/- MOSQUITO NETS @ RS. 1,650/- EACH
WHICH ALSO WAS ISSUED ON THE PURPORTED LETTERHEAD OF MATAK AUTONOMOUS COUNCIL, BEARING THE
OFFICIAL STATE EMBLEM OF INDIA. IT BORE THE SEAL OF MATAK AUTONOMOUS COUNCIL WHICH ALSO HAD THE
OFFICIAL STATE EMBLEM OF INDIA IN IT. THE SAID LETTER OF AWARD WAS SIGNED BY THE PRINCIPAL SECRETARY,
MATAK AUTONOMOUS COUNCIL. THE TOTAL VALUE OF THE LETTER OF AWARD WAS STATED TO BE RS. 110,05,00,000/-
[RUPEES ONE HUNDRED AND TEN CRORES AND FIVE LAKHS ONLY]. THE AFORESAID LETTER OF AWARD WAS ALSO
COPIED TO (A) P.A. TO THE HON’BLE CHIEF EXECUTIVE MEMBER OF MATAK AUTONOMOUS COUNCIL, DIRBUGARH, (B)
THE COMMISSIONER & SECRETARY TO THE GOVERNMENT OF ASSAM, ADMINISTRATIVE REFORMS & DSW, (C) P.S. TO
THE HON’BLE CHIEF SECRETARY TO THE GOVT. OF ASSAM AND (D) THE STATE PROJECT DIRECTOR, DSW, ASSAM.
1.MEMORANDUM OF UNDERSTANDING NO. MAC-73/DSW(ME)/MOU/2022-23/301 DATED 23 SEPTEMBER 2022 FOR SUPPLY
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OF 2,00,000/- SCHOOL BAGS OF PARTICULAR SPECIFICATIONS @ RS. 1,560/- EACH. THE TOTAL CONTRACT VALUE WAS
STATED TO BE RS. 31,20,00,000/- [RUPEES THIRTY-ONE CRORES AND TWENTY LAKHS ONLY]. THE SAID MOU WAS ISSUED
ON THE PURPORTED LETTERHEAD OF GOVERNMENT OF ASSAM WITH THE OFFICIAL STATE EMBLEM OF INDIA. THE
MOU WAS SIGNED BY THE UNDERSIGNED AND PRINCIPAL SECRETARY, MATAK AUTONOMOUS COUNCIL. THE SAID
MOU ALSO BORE THE SEAL OF MATAK AUTONOMOUS COUNCIL WHICH ALSO HAD THE OFFICIAL STATE EMBLEM OF
INDIA IN IT.
3.ALONG WITH THE MOU, THE UNDERSIGNED WAS ALSO HANDED OVER A LETTER OF AWARD NO. MAC-73/DSW
(ME)/MOU/2022-23/304 DATED 23 SEPTEMBER 2022 FOR SUPPLY OF 2,00,000 SCHOOL BAGS OF SPECIFIC SPECIFICATIONS
@ RS. 1,560/- EACH, WHICH ALSO WAS ISSUED ON THE PURPORTED LETTERHEAD OF MATAK AUTONOMOUS COUNCIL,
BEARING THE OFFICIAL STATE EMBLEM OF INDIA. THE TOTAL CONTRACT VALUE WAS STATED TO BE RS. 31,20,00,000/-
[RUPEES THIRTY-ONE CRORES AND TWENTY LAKHS ONLY]. IT BORE THE SEAL OF MATAK AUTONOMOUS COUNCIL
WHICH ALSO HAD THE OFFICIAL STATE EMBLEM OF INDIA IN IT. THE SAID LETTER OF AWARD WAS SIGNED BY THE
PRINCIPAL SECRETARY, MATAK AUTONOMOUS COUNCIL. THE AFORESAID LETTER OF AWARD WAS ALSO COPIED TO
(A) P.A. TO THE HON’BLE CHIEF EXECUTIVE MEMBER OF MATAK AUTONOMOUS COUNCIL, DIRBUGARH, (B) THE
COMMISSIONER & SECRETARY TO THE GOVERNMENT OF ASSAM, ADMINISTRATIVE REFORMS & DSW, (C) P.S. TO THE
HON’BLE CHIEF SECRETARY TO THE GOVT. OF ASSAM AND (D) THE STATE PROJECT DIRECTOR, DSW, ASSAM.
1.WE WERE ASKED TO PROVIDE GOODS UNDER A COMPLETELY DIFFERENT PURCHASE ORDER. AS PER THE NEW
PURCHASE ORDER THEY WERE DIRECTED TO SUPPLY AROUND 23,000 SEWING MACHINES. SINCE IT WAS NOT WITHIN
THE AMBIT OF THE COMPLAINANT’S BUSINESS PROFILE HENCE, THE SH.KAMAL SABHARWAL REFUSED TO ACCEPT
THE SAID PURCHASE ORDER. SH.KAMAL SABHARWAL, SH.MOHIT KALRA AND SH.RAJINDER SHARMA CATEGORICALLY
CONVEYED THAT THEY WERE COMPETENT TO FULFILL OBLIGATIONS UNDER THE EARLIER PURCHASE ORDER WHICH
WAS GIVEN TO THEM AT THE DIBRUGARH OFFICE OF MATAK AUTONOMOUS COUNCIL WHICH WAS FOR THE DELIVERY
OF SCHOOL BAGS, BLANKETS AND MOSQUITO NETS ETC.
12.IN ORDER TO MAKE THE COMPLAINANT AGREE TO THE PURCHASE ORDER FOR SUPPLY OF SEWING MACHINES, THE
ACCUSED NO.2 & 3 PATCHED ACCUSED NO.1 TO IMPRESS UPON THEM THAT THEY MUST EXECUTE THE SECOND
PURCHASE ORDER. IT WAS ALSO CONVEYED THAT THE SECOND PURCHASE ORDER FOR THE SEWING MACHINE IS
MUCH MORE LUCRATIVE AND HAVING HIGHER MARGINS. COMPLAINANT DID NOT AGREE. ACCUSED NO.2 IN ORDER
TO FURTHER INDUCE CONVEYED THAT HAS ADDITIONAL POWERS TO CHANGE THE PRICING. IN FACT WHEN SH.MOHIT
KALRA INFORMED ABOUT THE CHANGE IN THE PO TO SH.KHUSHDEEP BANSAL, HE ALSO ASSURED THAT SINCE THE
ACCUSED NO.2 IS A TOP OFFICIAL AND IS CLOSE TO THE CM HENCE, NO DIFFICULTIES WILL ARISE IN EXECUTION OF
THE NEW PO.
13.IT IS PERTINENT TO MENTION HEREIN THAT SH.KAMAL SABHARWAL, SH.MOHIT KALRA AND SH.RAJINDER SHARMA
WAITED THE ENTIRE DAY TO COLLECT THE ORIGINAL PURCHASE ORDER. HOWEVER, AT THE FAG-END OF THE DAY IT
WAS INFORMED THAT THE PURCHASE ORDER NEEDS SOME CLARIFICATION AND THUS THE SAME SHALL BE HANDED
OVER, BY HAND, BY THE ACCUSED NO.3 AT NEW DELHI WITHIN A WEEK THEREOF. IT WAS FURTHER INFORMED THAT
THE ACCUSED NO.3 SHALL REMAIN IN DELHI TO FACILITATE THE FORMALITIES OF THE CONTRACT AS A TOP
PRIORITY.
1.ACCUSED(S) HAVE CHEATED THE COMPLAINANT AND HAVE COMMITTED THE OFFENCE OF CRIMINAL INTIMIDATION:
1.DURING THE DISCUSSION THE ACCUSED NO.2 & 3 CLAIMED ASSAM IS LAGGING IN TECHNOLOGICAL ADVANCEMENTS
AND DUE TO POOR OFFICE AUTOMATION, POS CANNOT BE PREPARED AND PROCESSED IN DUE EARNEST. THEY
CLAIMED THAT THE COUNCIL IS NOT EQUIPPED WITH ANY TECH SUPPORT FROM THE STATE GOVERNMENT AND
COMPUTERIZATION IS LAGGING. RECORDS ARE STILL BEING MAINTAINED MANUALLY. FOR THIS REASON, THAT
REFUSED TO ACCEPT COMPUTERIZED COPY OF INVOICES, E-WAY BILLS OR ANY OTHER SUPPORTING DOCUMENT.
ACCUSED NO.2 & 3 ASKED THE COMPLAINANT TO SUBMIT BLANK TAX INVOICES. IT WAS CONVEYED THAT SINCE
THERE ARE SEVERAL DEPARTMENTS WITHIN THE COUNCIL, INCLUDING BUT NOT LIMITED TO ACCOUNTS
DEPARTMENT, PURCHASE DEPARTMENT, RECORD DEPARTMENT, ADMINISTRATIVE DEPARTMENT, INVENTORY
SUPERVISORY TEAMS, ETC. HENCE, IT WAS NECESSARY THAT BLANK COPIES OF ALL THE ABOVE DOCUMENTS BE
HANDED OVER TO THEM SO THAT THEY CAN MAINTAIN SEPARATE FILES AT EACH DEPARTMENT. ALL THESE SEEMED
VERY ARCHAIC. BUT DUE TO ELABORATE PARAPHERNALIA CREATED BY THE ACCUSED PERSONS, THE COMPLAINANT
BELIEVED ON ALL SUCH REPRESENTATION AND AGREED TO PROVIDE MANUAL INVOICES. HOWEVER, IT WAS MADE
ABSOLUTELY CERTAIN BY THE COMPLAINANT THAT ONLY THE ELECTRONIC INVOICES AND E-WAY BILLS WILL BE
THE ONES WHICH WILL BE REFERRED AND RELIED FOR ALL TRANSACTIONAL PURPOSES.
2.ON 24 SEPTEMBER 2022, WHILE WE WERE STILL PRESENT THERE, ACCUSED SHRI SHASHWAT SINGH BUNDELA
CONTACTED SHRI RAJINDAR SHARMA AND AGAIN ASKED FOR A COPY OF THE BLANK TAX INVOICE AND PACKING
LIST OF THE COMPLAINANT COMPANY, TO BE SUBMITTED FOR THE PURPOSES OF APPROVAL.
3.ON 24 SEPTEMBER 2022 ITSELF, THE UNDERSIGNED AND OTHER ASSOCIATES OF THE COMPLAINANT COMPANY,
AFTER COLLECTING COPIES OF THE ABOVE STATED MOUS AND LETTERS OF AWARD, CAME BACK TO NEW DELHI.
4.IMMEDIATELY, ON COMING BACK TO NEW DELHI, IN LIGHT OF THE LARGE VOLUME OF THE MATERIALS TO BE
SUPPLIED UNDER THE CONTRACTS AND THAT THE SAME WAS REQUIRED BY THE GOVERNMENT OF ASSAM ON
URGENT BASIS, THE COMPLAINANT COMPANY STARTED INVESTING LARGE SUMS OF MONEY FOR PROCUREMENT AND
MANUFACTURING OF THE MATERIALS TO BE SUPPLIED UNDER THE MOUS AND LETTERS OF AWARDS DATED 23
SEPTEMBER 2022 IN A TIME BOUND MANNER.
5.EVEN AFTER COMING BACK TO DELHI, ALL THE ACCUSED PERSONS INCLUDING SH.KHUSHDEEP BANSAL, HIS
BROTHER AND ACCUSED NO, 2 & 3 STARTED EXERTING UNDUE PRESSURE TO COMPLETE THE DELIVERIES. THEY WERE
FURTHER PRESSURIZED TO HANDOVER 6 COPIES OF BLANK TAX INVOICE, BLANK DELIVERY CHALLANS, ETC. SINCE
HUGE INVESTMENTS HAD BEEN MADE BY THE COMPLAINANT, THEREFORE, IT WAS FORCED TO ADHERE TO THEIR
DEMANDS.
6.DURING THE MONTH OF OCTOBER 2022, THE OFFICIALS OF THE COMPLAINANT COMPANY HAD VISITED GUWAHATI,
ASSAM AT DIFFERENT TIMES IN ORDER TO UNDERSTAND THE EXACT NATURE OF REQUIREMENTS OF PRODUCTS AND
HAD ALSO GONE TO GET THE SAMPLES OF SCHOOL BAGS, MOSQUITO NETS AND BLANKETS APPROVED.
SUBSEQUENTLY, AFTER VARIOUS MEETINGS WITH SHRI SHASHWAT SINGH BUNDELA AND SMT. PALLAVI THAKURIYA
@ DIDI THE SAMPLES WERE FINALLY APPROVED. THE SAMPLES WERE APPROVED VIDE TWO SAMPLE APPROVAL
LETTERS DATED 22 OCTOBER 2022. IN THE SAID LETTER OF SAMPLE APPROVAL THAT THE DELIVERY OF THE GOODS
HAD TO BE AT “WPCRC/MAC WAREHOUSE, JOHRAT, EAST ASSAM.” IT WAS ALSO INFORMED THAT THE WAREHOUSE IN
CHARGE WAS ON SHRI JAYANTA BORAH. THE SAID LETTERS OF APPROVAL WERE ISSUED ON THE PURPORTED
LETTERHEAD OF GOVERNMENT OF ASSAM WITH THE OFFICIAL STATE EMBLEM OF INDIA, WERE SIGNED PRINCIPAL
SECRETARY, MATAK AUTONOMOUS COUNCIL AND ALSO BORE THE SEAL OF MATAK AUTONOMOUS COUNCIL WHICH
ALSO HAD THE OFFICIAL STATE EMBLEM OF INDIA IN IT.
7.IMMEDIATELY, AFTER APPROVAL OF THE SAMPLES VIDE LETTER OF APPROVAL DATED 22 OCTOBER 2022, THE
COMPLAINANT COMPANY STARTED MAKING DELIVERIES OF THE MATERIALS TO MATAK AUTONOMOUS COUNCIL.
THE FIRST DELIVERY OF THE SCHOOL BAG WAS MADE ON 29 OCTOBER 2022, THE FIRST DELIVERY OF THE BLANKETS
WAS MADE ON 2 NOVEMBER 2022 AND THE FIRST DELIVERY OF THE MOSQUITO NETS WAS MADE ON 11 DECEMBER
2022. WHILST THE ORIGINAL INSTRUCTIONS WERE TO SEND THE GOODS TO WPCRC/MAC WAREHOUSE, JOHRAT, EAST
ASSAM HOWEVER, WE WERE ORALLY INSTRUCTED TO DELIVER ALL THE GOODS AT A NEW ADDRESS SITUATED AT
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WPCRCMAC/RTRO PLOT NO. 27, VIP ROAD, NALAPARA, SAUKUCHI, BEHARBARI, GUWAHATI- 781029.”
2.THE MODUS OPERANDI OF THE ACCUSED IN MANIPULATING AND MANURING THE FORGED DOCUMENT AS GENUINE
WITH THE SOLE INTENT TO MISREPRESENT, MISLEAD AND TO ORCHESTRATE THE VARIOUS CRIMES:
1.FROM OCTOBER 2022 TO DECEMBER 2022, THE COMPLAINANT COMPANY MADE SUPPLY OF A TOTAL VALUE OF RS.
63,59,88,000/-. A TOTAL OF 1,82,800 BLANKETS VIDE 88 DIFFERENT TAX INVOICES, 1,77,800 SCHOOL BAGS VIDE 68
DIFFERENT TAX INVOICES AND 60,000 MOSQUITO NETS VIDE 12 DIFFERENT TAX INVOICES WERE SUPPLIED BY THE
COMPLAINANT COMPANY TO MATAK AUTONOMOUS COUNCIL, GOVERNMENT OF ASSAM. A TABULATION OF THE
VARIOUS DELIVERIES CORRESPONDING WITH THE E-WAY BILL NUMBERS AND TAX INVOICES IS ENCLOSED HEREWITH
AS ANNEXURE 6 AND ANNEXURE 7(COLLY).
1.SOMETIME DURING THE END OF OCTOBER AND NOVEMBER 2022, THE ACCUSED NO.3 AT THE INSTANCE OF THE
ACCUSED NO.1 & 2 APPROACHED THE COMPLAINANT TO SUPPLY TO THEM NEW PHYSICAL BILL BOOK FOR BOTH TAX
INVOICES AS WELL AS DELIVERY CHALLAN WITH IMPRINTED CARBON PAPER ON IT OR USING SUCH PRINTING
MATERIAL WHEREBY SELF-CARBON COPIES CAN BE MADE WITHOUT PHYSICALLY USING SEPARATE CARON PAPERS
FOR COPING. SINCE TIME WAS THE ESSENCE OF THE DELIVERY AND HUGE INVESTMENTS HAD ALREADY BEEN MADE
BY THE COMPLAINANT AND SOME OF THE ASSOCIATES WHO HAD ALSO REQUIRED TO SUPPLY THE GOODS, LEFT WITH
NO OTHER ALTERNATIVE THE COMPLAINANT GOT FRESHLY PRINTED PHYSICAL BILL BOOK WHICH WERE PHYSICALLY
HANDED OVER TO THE ACCUSED NO. 2. HOWEVER, DESPITE SEVERAL REMINDERS AND REQUESTS THE ACCUSED
PERSONS FAILED TO RETURN THE EARLIER UN-USED DELIVERY CHALLANS AND TAX INVOICES. SUCH CONDUCT
INDEED RAISED DOUBTS HOWEVER, SINCE IT WAS GIVEN TO BELIEVE THAT THE PROJECT WAS MONITORED BY A
HIGH-RANKING OFFICER LIKE THE ACCUSED NO.2, THEREFORE, COMPLAINANT CONTINUED TO BELIEVE IN THEIR
REQUESTS AND REPRESENTATIONS.
2.ACCUSED NO.2 INSISTED ON PRINTED COPIES, EVEN THOUGH GOODS WERE SENT VIA E-WAY BILLS AS PER
GOVERNMENT DIRECTIVES AND INDUSTRY NORMS. HOWEVER, IT NOW TRANSPIRES THAT THE ACCUSED PERSONS
CREATED HAND WRITTEN COPIES OF E-WAY BILLS ON THE PHYSICAL BILL BOOKS. THE ACCUSED PERSONS, IN CLEAR
VIOLATIONS OF THE GST RULES DELIBERATELY IGNORED THE ELECTRONIC DELIVERY CHALLANS. IT IS NOW CLEAR
THAT THEY JOINTLY IN COLLUSION WITH EACH OTHER INDULGED IN CREATING FABRICATED DELIVERY CHALLANS.
HOWEVER, THE COMPLAINANT WAS KEPT IN DARK. IT IS NOW APPREHENDED THAT THE ACCUSED PERSONS MAY
HAVE FABRICATED DOCUMENTS AND THEREBY MISUSED THE SAME TO THE DETRIMENTAL INTEREST OF THE
COMPLAINANT.
3.ALL THE RECORDS AT THE COMPLAINANT’S END ARE MAINTAINED ELECTRONICALLY AS IT IS THE MANDATE UNDER
THE PRESENT GST AND INCOME TAX REGIME. THUS, THE COMPLAINANT WILL ONLY REFER AND RELY ON SUCH
DOCUMENTS. IT IS PERTINENT TO MENTION THAT THE RECORDS OF THE COMPLAINANT CANNOT BE FABRICATED AND
IS PROOF ENOUGH TO SHOW AND SUGGEST THAT GOODS WERE GENUINELY SUPPLIED FOR WHICH PAYMENTS WERE
NOT MADE AND THE COMPLAINANT APPREHENDS THAT THE ACCUSED PERSONS MAY HAVE MISUSE THE BLANK
DOCUMENTS HANDED OVER TO THEM.
4.AT THE TIME OF HANDING OVER THE BLANK PHYSICAL BILL BOOK THE ACCUSED NO. 1, 2, 3 & 4 HAD ASSURED AND
UNDERTOOK THAT ALL THE BLANK BILL BOOKS AND THE BLANK DELIVERY CHALLAN BOOKS SHALL NOT BE
MISUSED FOR ANY OTHER PURPOSE EXCEPT FOR COLLABORATIVE PURPOSE FOR HAVING TO MAINTAIN SEPARATE
RECORDS UNDER VARIOUS HEADS IN THE OFFICE OF THE NGO. THEY CLAIMED THAT THE ENTRIES WILL ONLY
REFLECT THE SAME DATA AS THAT ON THE ELECTRONIC DATA USED IN THE E-WAY BILLS OF THE COMPLAINANT.
HOWEVER, THE COMPLAINANT APPREHENDS THAT THE ACCUSED MAY HAVE MISUSED THE SAID DOCUMENTS TO THE
DETRIMENTAL INTEREST OF THE COMPLAINANT WHICH MAY RESULT IN FURTHER LOSSES.
5.THAT THE COMPLAINANT UNDER THE ASSURED PURCHASE ORDER WAS REQUIRED TO SUPPLY UNDER THE NEW
WORK ORDER OF 4,25,000 BLANKETS THE PRICE FIXED FOR SUCH SUPPLY WAS FIXED AT RS. 1650/- PIECE OF BLANKET.
THE TOTAL VALUE OF THE SAID ORDER WAS OF RS 70,12,50,000/-.
6.THE COMPLAINANT WAS ALSO REQUIRED TO SUPPLY 4,25,000 NUMBER OF MOSQUITO NETS AT THE RATE OF RS. 950/-
PER PIECE AT AN AGGREGATING VALUE OF RS. 40,37,50,000/- AND 2,00,000 NUMBER OF SCHOOL BAGS @ RS.1560/- PER
BAG AT AN AGGREGATED VALUE OF RS.31,20,00,000/-.
7.THE TOTAL AMOUNT OF THE ENTIRE ORDER CUMULATIVELY CAME TO BE HAVING A VALUE OF RS. 1,41,70,00,000.
8.SINCE THE ACCUSED PERSONS CLAIMED THAT THEIR SYSTEMS WERE STILL NOT TECHNICALLY STRONG AND THEY
GOT SIGNATURE OF THE COMPLAINANT ON A REGISTER WHICH THEY CLAIMED TO HAVE DETAILS OF THE ORDER. IT
WAS ASSURED BY ACCUSED NO.1, 3 AND 4 THAT THE SAID REGISTER WAS COUNTER SIGNED BY THE ACCUSED NO.2
THEREBY AUTHENTICATING AND FORMALIZING THE ORDER FOR SUPPLY.
9.MR. KHUSHDEEP BANSAL AND HIS BROTHER INFORMED THE COMPLAINANT THAT HE CANNOT DIRECTLY CONTACT
ACCUSED NO. 2 AND MEDIUM OF COMMUNICATION WOULD BE ONLY THROUGH ACCUSED NO. 3.
1.ACCUSED(S) HAVE ALSO COMMITTED THE OFFENCES OF MONEY LAUNDERING. SIPHONING OFF FUNDS,
FALSIFICATION OF BOOKS OF ACCOUNTS AND ALSO NON-PAYMENT OF VENDORS:
8.ON THE SPECIFIC REPRESENTATION MADE BY THE ACCUSED PERSONS, THE COMPLAINANT STARTED
MANUFACTURING, SAMPLING AND SUPPLYING GOODS. THE PROCESS OF ACTUAL DELIVERY WAS INITIATED FROM
07.10.2022. THE GOODS WERE DULY RECEIVED BY THE ACCUSED WHICH WAS ACCEPTED AND CONFIRMED BY
ACCUSED NO.4 SH.HARISH BANSAL. THE COMPLAINANT APPOINTED ONE SH. SANJEEV SHARMA AND SH. RAJESH
KHANNA AS THEIR REPRESENTATIVE SO AS TO ENSURE SMOOTH TRANSITS AND QUALITY CHECKS.
9.THE ACCUSED PERSONS AFFIRMED THAT THE PAYMENT SHALL BE MADE WITHIN 45 DAYS OF THE RECEIPT OF THE
GOODS. IT IS OF UTMOST IMPORTANCE TO MENTION HEREIN, THAT AS ON DATE GOODS WORTH RS. 63,59,88,000 (RS.
SIXTY THREE CRORES FIFTY NINE LACS EIGHTY EIGHT THOUSAND ONLY) HAS BEEN ALREADY DELIVERED TO THE
DESIGNATED LOCATIONS AS INTIMATED BY THE ACCUSED PERSONS. THE PRIMARY LOCATION BEING WAREHOUSE
LOCATED AT WPCRCMA/RTRO, PLOT NO. 27, VIP ROAD, NALAPARA, SAUKUCHI, BEHARWARI-781029. THIS IS
CONFIRMED BY ACCUSED NO.2, 3 & 4. ALL THE DELIVERIES WERE PERSONALLY MADE BY THE REPRESENTATIVES OF
THE COMPLAINANT WITH PROPER DOCUMENTATION.
10.IN THE MEANTIME, COMPLAINANT COMPANY PROVIDED SIGNED PHYSICAL BILL BOOKS TO ACCUSED NO.3 IN
DELHI, IN PRESENCE OF ACCUSED NO.4. THE COMPLAINANT WAS INFORMED THAT PAYMENT WOULD BE MADE WITHIN
45 DAYS AS THE PROCESS IS TO BE VERIFIED BY THE OFFICE OF THE CM. ALL THESE FALSE ASSURANCES WERE
NOTHING BUT ANY ELABORATE FAÇADE TO COMMIT FRAUD AND CHEATING.
11.ON 17.11.22, THE COMPLAINANT WAS INFORMED BY ACCUSED NO.2 THAT HE HAS STARTED SUBMITTING THE
PHYSICAL BILL BOOK ACCORDING TO ORIGINAL E-WAY BILLS TO THE TREASURY AND SOON PAYMENTS WILL BE
RELEASED. MORE ORDERS IN THE NAME OF THE COUNCIL WERE MADE AND SINCE THE GOODS WERE SUPPLIED AS PER
SCHEDULE HENCE, THE ACCUSED CLAIMED MARGINS OFFERED WERE REVISED. ALL THESE ACTS MADE THE
COMPLAINANT CONVINCED ABOUT THE GENUINENESS OF THE TRANSACTION.
12.ACCUSED NO.1,2 & 3 COLLECTIVELY CONVINCED THE COMPLAINANT ON TAKING ADDITIONAL ORDERS. HOWEVER,
SINCE THE AMOUNT PAYABLE WAS VERY HIGH, THE COMPLAINANT INSISTED THAT ONCE THE EARLIER PAYMENTS
ARE RELEASED, THEY BE ABLE TO TAKE A DECISION IN REGARD TO FURTHER DELIVERIES. AT THIS JUNCTURE THE
COMPLAINANT GAVE ITS CATEGORICAL INABILITY TO UNDERTAKE FURTHER OBLIGATION. ACCEPTANCE OF NEW
ORDERS WERE SUBJECT TO CLEARANCE OF PENDING PAYMENTS OF THE INVOICES FOR THE GOODS ALREADY DULY
DELIVERED AND ACCEPTED BY THEM.
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13.IT IS PERTINENT TO MENTION THAT ON 17 NOVEMBER 2022, THE COMPLAINANT WAS INFORMED BY SHRI PARTHA
BHARDWAJ THAT HE HAS STARTED SUBMITTING THE BILLS IN TERMS OF THE E-WAY BILLS TO THE TREASURY OF THE
GOVERNMENT OF ASSAM AND SOON, PAYMENTS WILL BE RELEASED TO THE COMPLAINANT COMPANY. HOWEVER, NO
PAYMENTS WERE RECEIVED WITHIN THE TIMELINES AS ASSURED BY THE ACCUSED PERSONS.
14.AT THIS STAGE, IT IS RELEVANT TO POINT OUT THAT IT WAS SHRI SHASHWAT SINGH BUNDELA AND SHRI HARISH
BANSAL, WHO IN TERMS OF THEIR ROLE IN THE CRIMINAL DESIGN, WERE COMMUNICATING WITH SHRI MOHIT KALRA
AND OTHER ASSOCIATES OF THE COMPLAINANT COMPANY IN ORDER TO FIND OUT THE STATUS OF DELIVERIES. THEY
ALSO WERE THE PERSONS MAKING FALSE ASSURANCES TO THE ASSOCIATES OF THE COMPLAINANT COMPANY
REGARDING THE PAYMENT TIMELINES IN TERMS OF THE INSTRUCTIONS ISSUED BY SHRI KHUSHDEEP BANSAL AND
SHRI PARTHA BHARDWAJ.
15.THE ACCUSED HARISH BANSAL USED TO BE REGULARLY CONTACT SHRI MOHIT KALRA AND ASK HIM ABOUT THE
STATUS OF THE DELIVERIES BEING MADE BY THE COMPLAINANT COMPANY FROM NOVEMBER 2022 ONWARDS, UNDER
INSTRUCTIONS OF HIS BROTHER, SHRI KHUSHDEEP BANSAL. THUS, SHRI MOHIT KALRA USED TO REGULARLY UPDATE
ACCUSED HARISH BANSAL, THROUGH WHATSAPP, ABOUT ALL DELIVERIES BEING MADE BY THE COMPLAINANT
COMPANY. DURING THE COURSE OF THE AFORESAID COMMUNICATION WITH REGARDS TO DELIVERIES, SHRI HARISH
BANSAL STARTED LURING SHRI MOHIT KALRA AND OTHER ASSOCIATES OF THE COMPLAINANT COMPANY VIDE HIS
WHATSAPP MESSAGES DATED 16 NOVEMBER 2022, 20 NOVEMBER 2022, 28 NOVEMBER 2022 AND 1 DECEMBER 2022 INTO
TAKING UP FURTHER ORDERS FROM THE ACCUSED PERSONS FOR SUPPLY OF SEWING MACHINES, SOLAR LIGHTS, ETC.
INITIALLY, THE REPRESENTATIVES OF THE COMPLAINANT COMPANY RECIPROCATED TO THE SAID OFFERS AND
SHARED OPTIONS WHICH COULD BE PROCURED, HOWEVER, LATER, WHEN THE OUTSTANDING PAYMENTS FOR THE
EXISTING SUPPLIES WERE DELAYED BY THE ACCUSED PERSONS, THE REPRESENTATIVES OF THE COMPLAINANT
COMPANY DEMONSTRATED THEIR INABILITY TO SUPPLY FURTHER MATERIALS, UNTIL AND UNLESS THE
OUTSTANDING PAYMENTS WERE RELEASED.
16.FURTHER, WHEN SHRI MOHIT KALRA ASKED ACCUSED SHRI HARISH BANSAL TO CHECK THE STATUS OF THE
OUTSTANDING PAYMENTS OF THE COMPLAINANT COMPANY ON 22 NOVEMBER 2022, BY WHICH TIME APPROXIMATELY
25 CRORES WORTH OF MATERIAL HAD ALREADY BEEN DELIVERED. SHRI HARISH BANSAL, VIDE WHATSAPP, AT THIS
TIME SOUGHT FROM SHRI MOHIT KALRA, PHOTOCOPY OF ALL THE BILLS SUBMITTED BY THE COMPLAINANT
COMPANY TO MATAK AUTONOMOUS COUNCIL. THE COMPLETE FILE CONTAINING ALL PHOTOCOPIES OF THE BILLS
ALONG WITH A LEDGER ACCOUNT OF MATAK AUTONOMOUS COUNCIL, MAINTAINED BY THE COMPLAINANT
COMPANY, WAS SUBMITTED TO SHRI HARISH BANSAL, ALONG WITH A LEDGER ACCOUNT ON 25 NOVEMBER 2022.
17.FURTHER, ON 1 DECEMBER 2022, SHRI HARISH BANSAL ASKED SHRI MOHIT KALRA TO BOOK A TICKET FOR
ACCUSED SHRI SHASHWAT SINGH BUNDELA TO GUWAHATI SO THAT HE CAN STREAMLINE ENTIRE PROCESS OF
DELIVERY AND PAYMENTS. MEANWHILE, A SMALL AMOUNT OF RS. 23.10 LAKHS WAS RELEASED BY THE WPCRCMAC
IN FAVOUR OF THE COMPLAINANT COMPANY. AFTER THE AFORESAID PAYMENT, THE SAME WAS SEPARATELY
INTIMATED BY SHRI MOHIT KALRA TO SHRI HARISH BANSAL AND SHRI SHASHWAT SINGH BUNDELA, AFTER THEIR
FOLLOW UP.
18.THEN ON 7 DECEMBER 2022, SHRI HARISH BANSAL STATED TO SHRI MOHIT KALRA THAT HE WILL GET A TENTATIVE
SCHEDULE OF PAYMENTS OF THE COMPLAINANT COMPANY FROM MATAK AUTONOMOUS COUNCIL AND SHARE THE
SAME WITH HIM. FURTHER, HE INFORMED SHRI MOHIT KALRA THAT MATAK AUTONOMOUS COUNCIL FOLLOWS THE
SYSTEM OF RELEASING PAYMENTS ON TUESDAY, THURSDAY AND SATURDAY AND THAT HE IS CONSTANTLY
FOLLOWING UP FOR OUTSTANDING PAYMENTS OF THE COMPLAINANT COMPANY. THEN, ON 10 JANUARY 2023, HE
SENT THE FOLLOWING MESSAGE TO SHRI MOHIT KALRA REGARDING OUTSTANDING PAYMENTS-[10/01/23, 6:39:16 PM]
HARISH BANSAL JI: BHAI- EK BAAR LATEST UPDATE AAP VI SHASHWAT SE LEY LO. LET ME ALSO HAVE IT FROM
BHAIYA.
1.THEREAFTER, SHRI HARISH BANSAL ARRANGED A MEETING AT MAHAGURUKUL SITUATED AT KHASRA NO. 112,
DERA VILLAGE, DERA MANDI, NEW DELHI- 110074 BETWEEN THE REPRESENTATIVES OF THE COMPLAINANT COMPANY
AND THE ACCUSED PERSONS.
19.FURTHER, THE INVOLVEMENT OF ACCUSED SHRI SHASHWAT SINGH BUNDELA IS ALSO EVIDENT FROM THE
VARIOUS WHATSAPP COMMUNICATIONS EXCHANGED BETWEEN HIM AND SHRI MOHIT KALRA VIDE WHICH HE AT THE
TIME OF EACH DELIVERY BEING MADE BY THE COMPLAINANT COMPANY, SOUGHT INFORMATION WITH REGARDS TO
THE STATUS OF THE DELIVERY AND A COPY OF THE TAX INVOICE BEING ISSUED BY THE COMPLAINANT COMPANY.
FURTHER, VIDE WHATSAPP MESSAGE DATED 3 NOVEMBER 2022, THE ADDRESS FOR DELIVERY OF THE MATERIALS
WAS CHANGED BY ACCUSED SHRI SHASHWAT SINGH BUNDELA AND SHRI MOHIT KALRA WAS DIRECTED TO GET THE
DELIVERIES DONE AT WPCRCMAC/RTRO PLOT NO. 27, VIP ROAD, NALAPARA, SAUKUCHI, BEHARBARI, GUWAHATI-
781029.
20.FURTHER, ACCUSED SHRI SHASHWAT SINGH BUNDELA ALSO USED TO SEEK COPY OF ALL INVOICES FROM SHRI
MOHIT KALRA ON THE PRETEXT OF GETTING THE SAME CLEARED. FURTHER, VARIOUS REQUESTS WERE MADE BY
SHRI MOHIT KALRA TO SHRI SHASHWAT SINGH BUNDELA TO GET THE OUTSTANDING PAYMENTS CLEARED AS THE
COMPLAINANT COMPANY WAS FACING A LOT OF FINANCIAL PRESSURE AND SHRI SHASHWAT SINGH BUNDELA VIDE
HIS MESSAGES REPLIED TO SHRI MOHIT KALRA ON 12 JANUARY 2023, 13 JANUARY 2023 AND 14 FEBRUARY 2023 STATED
THAT HE WILL SPEAK WITH ACCUSED SHRI PARTHA BHARDWAJ REGARDING THE SAME.
5.FAKING THE BANK ACCOUNT/ DISHONESTLY AND FRAUDULENTLY OPENED/ CAUSED TO OPEN FICTITIOUS BANK
ACCOUNTS.
1.ON 06.12.2022, AFTER LOTS OF INSISTENCES AND FOLLOW-UPS A SMALL AMOUNT OF RS. 23.10 LACS WAS RELEASED.
TIME AND AGAIN THE COMPLAINANT MADE NUMEROUS REQUESTS TO THE ACCUSED PERSONS FOR RELEASING THE
REMAINING PAYMENTS. HOWEVER, NO SATISFACTORY RESPONSE WAS FOR THE COMING. IN FACT, THE COMPLAINANT
ALONG WITH HIS ASSOCIATES UNDER TOOK MULTIPLE VISITS TO GUWAHATI TO MEET THE ACCUSED PERSONS
PERSONALLY HOWEVER, ON ONE PRETEXT OR THE OTHER WOULD SHY AWAY FROM MEETING THEM. THEREAFTER,
THE COMPLAINANT COULD MANAGE A FURTHER RELEASE OF RS. 43,68,000/- (RUPEES FORTY THREE LAKHS AND SIXTY
EIGHT THOUSAND ONLY) WHICH THEY RECEIVED ON 11.01.2023.
2.ON 14.02.2023, A PALTRY SUM OF RS. 46,80,000/- (RUPEES FORTY SIX LAKHS AND EIGHTY THOUSAND ONLY) WAS
RECEIVED BY THE COMPLAINANT. ALL THESE SMALL BITS AND PIECES WERE COMPLETELY INSUFFICIENT.
COMPLAINANT IS LEFT WITH NO OTHER SOURCE TO RUN THEIR BUSINESS EFFECTIVELY AND THE DAILY OPERATIONS
IS SEVERELY HAMPERED.
3.TO THEIR UTTER SHOCK AND DIS-BELIEF THEY WERE HORRIFIED TO KNOW THAT THE BANK ACCOUNT FROM WHERE
THE PAYMENTS WERE RELEASED DOES NOT BELONG TO THE COUNCIL AT ALL. IN FACT, THE ACCOUNT WAS NOT
EVEN DESIGNATED TO BE A GOVERNMENT ACCOUNT. THE ACCOUNT SEEMED TO HAVE BEEN OPENED ON FAKE NAME
AND CREDENTIALS. FALSE IMPRESSION WAS GIVEN TO THE COMPLAINANT THAT THE ACCOUNT BELONGED TO
MATAK AUTONOMOUS COUNCIL, A GOVERNMENT OF ASSAM CONCERN.
4.THE FALSEHOOD WAS FURTHER ESTABLISHED WHEN IT WAS REVEALED THAT ALLEGED ACCOUNT IS BEING
OPERATED AND MANAGED BY AN INDIVIDUAL NAMED MR. MRINAL KUMAR SAIKA CLAIMING TO BE THE PROPRIETOR
OF A FAKE FIRM BEING OPERATED UNDER THE NAME AND STYLE OF WORLD PEB COMMODITY RECEIVING CENTRE
FOR MARKETING ACCESS CONTROL (WPCRCMAC). THE SAID ACCOUNT WAS BEING OPERATED FROM NORTH EASTERN
SMALL FINANCE BANK. ON FURTHER INQUIRIES SAID WAS REVEALED THAT THE SAID FIRM USUALLY TOOK UP SOME
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SMALL INFRASTRUCTURE PROJECTS OF MATAK AUTONOMOUS COUNCIL FOR DEVELOPMENT OF WASHROOMS, ROADS
MANAGEMENTS ETC. IN RURAL AREAS OF ASSAM. HOWEVER, NO BIG PROJECTS ARE HANDLED AND IS NOT A PART OF
MATAK AUTONOMOUS COUNCIL AT ALL.
6.BRIEF FACTS AS REGARD TO CASE OR IMPERSONATION BY FAKING AS IAS OFFICER & HEAD OF MATAK
AUTONOMOUS COUNCIL AND ALSO WILLFUL VIOLATION OF STATE EMBLEM OF INDIA (PROHIBITION OF IMPROPER
USE) ACT, 2005.
1.ON 19.04.2023 ACCUSED NO. 2 CONTACTED THE COMPLAINANT AND HIS ASSOCIATE MR. MOHIT KALRA AND
INFORMED THAT HE HAS BEEN GRANTED IAS CADRE AND IS IN DELHI FOR TRAINING. ON THE INSISTENCE OF ACCUSED
NO.1, SH. MOHIT KALRA AND SH.RAJENDER SHARMA WENT TO HOTEL ROSEATE, NEW DELHI TO MEET THE ACCUSED
NO.2 OVER DINNER. AT AROUND 10:30 PM, THE ACCUSED NO.2 INFORMED THAT HE WAS GETTING LATE SINCE HE BEEN
CALLED FOR AN URGENT MEETING WITH THE UNION LAW MINISTER KIRAN RIJJU AT HIS RESIDENCE. HE INSISTED
THAT THEY SHOULD WAIT. AFTER ABOUT TWO HOURS THE ACCUSED NO.2 ARRIVED AND ASKED THEM TO
ACCOMPANY HIM TO HIS PRESIDENTIAL SUIT. HE CLAIMED THAT SINCE HE IS A DECORATED OFFICER OF THE
GOVERNMENT OF ASSAM AND BEING THE POINT MAN FOR THE CM HENCE, HE IS ENTITLED TO THESE SPECIAL
PRIVILEGES. THE COMPLAINANT ONCE AGAIN REQUESTED THE ACCUSED NO. 2 TO EXPEDITE THE RELEASE OF THE
BALANCE AMOUNT AND CONVEYED THAT THE COMPLAINANT IS FACING SERIOUS DIFFICULTIES IN SUSTAINING THE
BUSINESS AS MAJORITY OF THE CAPITAL HAS BEEN INVESTED IN THE EXECUTION OF THE WORK ORDERS OF MATAK
AUTONOMOUS COUNCIL. AFTER MUCH INSISTENCE, A FURTHER PAYMENT OF RS. 33,00,000/- WAS RELEASED.
2.ACCUSED NO.2 THOUGH WAS UNAPOLOGETIC FOR THE DELAYED PAYMENTS CLAIMED THAT HE HAS GOT AN
APPROVAL OF RS. 2,50,00,000/- (RUPEES TWO CRORES AND FIFTY LAKH ONLY) FROM THE CM’S OFFICE. ON RECEIPT IT
SHALL BE CREDITED TO THE COMPLAINANT BY END OF THE FOLLOWING WEEK. THE COMPLAINANT WAS FURTHER
ASSURED THAT BY THE END OF APRIL, 2023, A TOTAL SUM OF RS. 25,00,00,000/- (RUPEES TWENTY FIVE CRORES ONLY)
SHALL BE CLEARED.
3.THE ACCUSED NO. 2 NAMELY PARTHA BHARDWAJ FORGED AND FABRICATED THE LETTER HEADS OF THE MATAK
AUTONOMOUS COUNCIL, SEAL OF THE GOVERNMENT, VISITING CARDS SHOWING AS THE MANAGING DIRECTOR AND
ALSO FAKED HIS ID CARDS TO PROVE HIS IDENTITY AS AN IAS OFFICER THE SAID ACCUSED ALSO USED THE FAKE ID
CARD OF THE MATAK AUTONOMOUS BODY TO CHEAT THE COMPLAINANT WHO HAD BELIEVED HIM AND SUPPLIED
GOODS OF CRORES OF RUPEES. HE ALSO USED THE FAKE LETTER HEAD OF THE MATAK AUTONOMOUS BODY AS
MANAGING DIRECTOR AND COMPETENT PERSON TO ISSUE PURCHASE ORDER OF TO THE TUNE OF RS.63,00,00,000/- (
RUPEES SIXTY THREE CRORES ONLY).
7.REVELATION AND EMERGENCE OF THE EVENTS OF SUSPICION AND DOUBTS AS REGARD TO THE ROLE OF THE
ACCUSED AND THE TRANSACTION.
1.ON 26.04.2023, SH. MOHIT KALRA & SH.RAJENDER SHARMA CONTACTED THE ACCUSED NO.2 & 3 AND INFORMED THEM
ABOUT THEIR PRESENCE IN GUWAHATI AND WANTED TO MEET THEM TO DISCUSS THE PAYMENT SCHEDULE. RATHER
THAN COOPERATING THE ACCUSED PERSONS OUT RIGHTLY REFUSED TO MEET. THIS SUDDEN BEHAVIORAL CHANGE
RAISED FURTHER DOUBTS. SH. MOHIT KALRA & SH. RAJENDER SHARMA DECIDED TO MAKE INDEPENDENT ENQUIRIES
ABOUT THE WHEREABOUTS OF THE ACCUSED PERSONS.
2.TO THEIR UTTER SHOCK AND DIS-BELIEF THEY WERE HORRIFIED TO KNOW THAT THE BANK ACCOUNT FROM WHERE
THE PAYMENTS WERE RELEASED DOES NOT BELONG TO THE COUNCIL AT ALL. IN FACT, THE ACCOUNT WAS NOT
EVEN DESIGNATED TO BE A GOVERNMENT ACCOUNT. THE ACCOUNT SEEMED TO HAVE BEEN OPENED ON FAKE NAME
AND CREDENTIALS.
3.THE FALSEHOOD WAS FURTHER ESTABLISHED WHEN IT WAS REVEALED THAT ALLEGED ACCOUNT IS BEING
OPERATED AND MANAGED BY AN INDIVIDUAL NAMED MR. MRINAL KUMAR SAIKA CLAIMING TO BE THE PROPRIETOR
OF A FAKE FIRM BEING OPERATED UNDER THE NAME AND STYLE OF WORLD PEB COMMODITY RECEIVING CENTRE
FOR MARKETING ACCESS CONTROL (WPCRCMAC). THE SAID ACCOUNT WAS BEING OPERATED FROM NORTH EASTERN
SMALL FINANCE BANK. ON FURTHER INQUIRIES SAID WAS REVEALED THAT THE SAID FIRM USUALLY TOOK UP SOME
SMALL INFRASTRUCTURE PROJECTS OF MATAK AUTONOMOUS COUNCIL FOR DEVELOPMENT OF WASHROOMS, ROADS
MANAGEMENTS ETC. IN RURAL AREAS OF ASSAM. HOWEVER, NO BIG PROJECTS ARE HANDLED AND IS NOT A PART OF
MATAK AUTONOMOUS COUNCIL AT ALL.
8.BRIEF FACTS PERTAINING TO THE FABRICATION, TEMPERING, INTERPOLATION AND PURGING OF THE DOCUMENTS
WITH AN INTENT TO CHEAT AND DEFRAUD THE COMPLAINANT.
1.ACCUSED SHRI KHUSHDEEP BANSAL AND SHRI SHASHWAT SINGH BUNDELA TOOK US TO THE OFFICE OF MATAK
AUTONOMOUS COUNCIL, WHICH WAS A RED BUILDING CARRYING THE NAME PLATE OF MATAK AUTONOMOUS
COUNCIL. THE SAID MEETING OCCURRED ON 23 MAY 2023. INITIALLY, SHRI KHUSHDEEP BANSAL MET WITH SHRI
PARTHA BHARDWAJ ALONE TO TAKE UP OUR CONCERNS INDEPENDENTLY. WE WAITED AT THE OFFICE OF MATAK
AUTONOMOUS COUNCIL. AFTER HAVING A LONG MEETING, SHRI KHUSHDEEP BANSAL CAME OUT OF THE OFFICE OF
SHRI PARTHA BHARDWAJ AND INFORMED US THAT ALL OUR ISSUES HAVE BEEN SORTED OUT. AT THIS STAGE, HE
TOOK US TO THE OFFICE OF SHRI PARTHA BHARDWAJ IN MATAK AUTONOMOUS COUNCIL WHEREIN, ALL THREE
ACCUSED PERSONS CLARIFIED THAT THE TRANSACTION IS LEGITIMATE AND FORTHWITH SOME PAYMENTS WILL BE
MADE TO THE COMPLAINANT COMPANY. FURTHER, IN ORDER TO DECEIVE US, VARIOUS PURPORTED FILES OF MATAK
AUTONOMOUS COUNCIL WITH OTHER VENDORS WERE ALSO SHOWN TO US. FALSE IMPRESSION WAS GIVEN TO THE
COMPLAINANT THAT THE ACCOUNT BELONGED TO MATAK AUTONOMOUS COUNCIL, A GOVERNMENT OF ASSAM
CONCERN. THAT DESPITE THE WRITTEN ASSURANCE AND COMMITMENT, ON 25TH MAY 2023 VIDE LETTER
NO.MAC/AA(ME)/270/274/47/007 AN AMOUNT OF RS 61,14,00,300/- HAS BEEN ADMITTED WHILST INDICATING THE CAUSE
OF THE DELAY BEING ON TECHNICAL GROUNDS AND FURTHER ASSURED THAT THE SAID PAYMENT WILL BE
RELEASED BY 31ST MAY 2023. HOWEVER, ONLY A MERE SUM OF RS. 1,32,00,000/- WAS RECEIVED TILL 31ST MAY 2023
AND A SUM OF RS. 66,00,000/- WAS RECEIVED ON 1ST JUNE 2023. NO PAYMENT WAS FURTHER EVER MADE TO THE
COMPLAINANT. THUS THE ACT OF ACCUSED PERSONS CAUSED GRAVE MENTAL AGONY AND HARASSMENT TO THE
COMPLAINANT. THE TRUE COPY OF THE LETTER DATED 25.05.2023 IS ANNEXED AS ANNEXURE 8
2.A LETTER BEARING NO. MAC/AA(ME)/270/274/47/003 DATED 24 MAY 2023 VIDE WHICH MATAK AUTONOMOUS COUNCIL
EXTENDED THE TERM OF THE MOU(S) AND LETTERS OF AWARDS DATED 23 SEPTEMBER 2022 FOR A PERIOD OF 180
DAYS, WITH EFFECT FROM 24 MAY 2023. THE SAID LETTER WAS ISSUED ON THE PURPORTED LETTERHEAD OF
GOVERNMENT OF ASSAM WITH THE OFFICIAL STATE EMBLEM OF INDIA. THE LETTER WAS SIGNED BY THE PRINCIPAL
SECRETARY, MATAK AUTONOMOUS COUNCIL. THE SAID LETTER ALSO BORE THE SEAL OF MATAK AUTONOMOUS
COUNCIL WHICH ALSO HAD THE OFFICIAL STATE EMBLEM OF INDIA IN IT. THE TRUE COPY OF THE LETTER DATED
24.05.2023 IS ANNEXED AS ANNEXURE 9
3.A LETTER BEARING NO. MAC/AA(ME)/270/274/47/005 DATED 25 MAY 2023 VIDE WHICH MATAK AUTONOMOUS COUNCIL
ACKNOWLEDGED ALL 168 TAX INVOICES ISSUED BY THE COMPLAINANT COMPANY IN RESPECT OF EACH DELIVERY OF
MATERIAL MADE FROM OCTOBER 2022 TO DECEMBER 2022. THE SAID LETTER WAS ISSUED ON THE PURPORTED
LETTERHEAD OF GOVERNMENT OF ASSAM WITH THE OFFICIAL STATE EMBLEM OF INDIA. THE LETTER WAS SIGNED BY
THE PRINCIPAL SECRETARY, MATAK AUTONOMOUS COUNCIL. THE SAID LETTER ALSO BORE THE SEAL OF MATAK
AUTONOMOUS COUNCIL WHICH ALSO HAD THE OFFICIAL STATE EMBLEM OF INDIA IN IT. THE TRUE COPY OF THE
LETTER DATED 25.05.2023 IS ANNEXED AS ANNEXURE 10
1.BRIEF FACTS IN REGARD TO INTIMIDATION:
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1.ALL THESE INFORMATION CAME AS A SHOCK. BEING ARMED WITH THE SAID INFORMATION THE ASSOCIATES OF
COMPLAINANT CONFRONTED SH.KHUSHDEEP BANSAL, HIS BROTHER AND SH.PARTHA BHARADWAJ. ON SUSTAINED
ENQUIRY AND FACED WITH SUCH CREDIBLE INFORMATION. ALL OF THEM FINALLY ADMITTED THAT THEY DO NOT
HOLD ANY GOVERNMENT POSITIONS. THEY HAVE NOTHING TO DO WITH THE GOVERNMENT OF ASSAM. THEY
FURTHER ADMITTED THAT ALLEGED IMPLEMENTING PROJECT IS NOT EVEN APPROVED BY THE OFFICE OF THE CM.
THE NAME OF ACCUSED NO.2 WAS NOT MENTIONED IN LIST OF ASSAM STATE GOVERNMENT OFFICERS. THAT THE
ACCUSED NO.2 IS NOW CLEARLY IMPERSONATING HIMSELF AS A PRINCIPAL SECRETARY TO THE GOVERNMENT OF
ASSAM. IT IS FURTHER REVEALED THAT THE ACCUSED NO.2 ESTABLISH HIS FALSE IDENTITY ONLY TO GARNER
ILLEGAL BENEFITS. IN FACT HE, IN ORDER TO GIVEN CREDIBILITY TO HIS FALSE IDENTITY, FORGED OFFICIAL
DOCUMENTS AND SEALS BY USING GOVERNMENT STATIONARY.
2.DURING THE IN-DEPTH ENQUIRY, IT WAS ALSO REVEALED THAT THE LETTERHEADS, INVOICES, ORDER SHEETS, SEAL
AND OTHER IMPORTANT GOVERNMENT DOCUMENTS WERE ALL FORGED AND FABRICATED. THE FORGERY WAS TO
SUCH AN EXTENT THAT NAME AND OTHER DOCUMENTS OF MATAK AUTONOMOUS COUNCIL OF GOVERNMENT OF
ASSAM WERE FREELY AND RANDOMLY USED THUS COMMITTING SERIOUS FORGERY, FRAUD, CHEATING BY
IMPERSONATION AND CRIMINAL BREACH OF TRUST. THE COMPLAINANT AND HIS ASSOCIATES WERE CHEATED TO AN
AMOUNT OF A LITTLE OVER RS. 58 CRORES. IT IS PERTINENT TO MENTION HEREIN THAT COMPLAINANT HAS ALREADY
PAID, IN ADVANCE, TAX DUES LIKE GST AND ADVANCE INCOME TAX ON THE GOODS SO SUPPLIED. THE COMPLAINANT
HAS AS PER THE LAW RAISED INVOICES, E-WAY BILLS, LORRY BILLS. THE FEW OF THOSE INVOICES, E-WAY BILLS AND
LORRY BILLS ARE ANNEXED AS ANNEXURE 11, ANNEXURE 12 AND ANNEXURE 13(COLLY/RESPECTIVELY )
3.AS SOON AS THE ACCUSED BECAME AWARE THAT THE COMPLAINANT AND THEIR ASSOCIATES HAVE GOT WIND OF
THE FALSEHOOD, THE ACCUSED PERSONS COVERTLY STARTED SENDING FEELERS TO SH.MOHIT KALRA AND SH.
RAJENDER SHARMA THAT THEY SHOULD NOT MAKE ANY FURTHER ENQUIRIES. THEY MUST LEAVE THE STATE OF
ASSAM OR ELSE THEY MAY SUFFER SUCH BODILY INJURIES WHICH MAY RESULT IN HARM OF IRREPARABLE NATURE.
BEING FEARFUL OF SUCH POTENT THREATS SH.MOHIT KALRA AND SH.RAJENDER SHARMA IMMEDIATELY LEFT. ON
REACHING DELHI THEY IMMEDIATELY CONTACTED SH. KHUSHDEEP BANSAL AND LAID BARE THE TRUE NATURE AND
EXTENT OF THE DECEITFUL ACT COMMITTED BY ALL OF THEM WHICH HAS RESULTED IN HUGE LOSSES AT THE
INSTANCE OF THE COLLECTIVE ILLEGAL ACT OF THE ACCUSED PERSONS.
4.BEING FACED WITH THE UNIMPEACHABLE EVIDENCE, SH.KHUSHDEEP BANSAL FAILED TO DO ANY ACT TO SECURE
THE RELEASE OF THE PAYMENTS. RATHER HE ASSURED THAT THERE IS SOME MISCOMMUNICATION OF FACTS AND
ASSURED THAT HE WILL PERSONALLY LOOK INTO THE GRIEVANCES OF THE COMPLAINANT AND IF NEED BE WILL
ALSO GET INVOLVED IN THE MATTER IN ORDER TO PROTECT THE INTEREST OF THE COMPLAINANT AND GET THEIR
PAYMENTS AT THE EARLIEST. HOWEVER, NOW SH.BANSAL OR HIS BROTHER HAVE STOPPED ALL CONCILIATION
EFFORTS AND WASHED HIS HANDS OFF. WHICH ONLY PROVES HIS ACTIVE INVOLVEMENT. HE IS THE ONE WHO GOT
THE COMPLAINANT TO ACCEPT THE FIRST ORDERS EVEN THOUGH HE WAS FULLY CONVERSANT THAT THE ACCUSED
NO. 2, 3, 5 TO 7 ARE IMPERSONATING AS GOVERNMENT FUNCTIONARY WERE AS IN REALITY THEY ARE NOT EVEN
REMOTELY ASSOCIATED OR CONNECTED WITH THE GOVERNMENT OF ASSAM.
5.AS ON DATE OUT OF THE TOTAL INVOICED GOODS OF RS.63.00 CRORES, THE ACCUSED PERSONS HAVE RELEASED,
ONLY RS. 4,43,58,000/-. THEREFORE, TILL DATED, AN AMOUNT TO THE TUNE OF RS. 58.00 CRORES ARE STILL DUE AND
PAYABLE TO THE COMPLAINANT.
6.THAT THE ACCUSED PERSONS WITH MALA-FIDE INTENTION CONCOCTED, FALSIFIED AND FABRICATED THE ENTIRE
TRANSACTION BY CREATING A FALSE NARRATIVE WITH THE INTENTION TO DEFRAUD THE COMPLAINANT BY
REPRESENTING THEMSELVES AS GOVERNMENT OFFICIALS AND DIRECTLY ASSOCIATED WITH THE OFFICE OF THE
CHIEF MINISTER OF ASSAM. THAT THE ACCUSED PERSONS WITH THEIR DISHONEST, MISCHIEVOUS AND ILLEGAL ACTS
HAVE MISAPPROPRIATED HARD-EARNED MONEY OF THE COMPLAINANT AND THEREFORE, THEY SHOULD BE DEALT
WITH STERNLY AND SEVERELY. THAT BY THE CLEAR ACTS OF IMPERSONATION THE ACCUSED PERSONS HAVE
COMMITTED THE ACT OF CHEATING BY FORGING SUCH GOVERNMENT DOCUMENTS AND SEALS WITH THE SOLE
INTENTION TO WRONGFULLY GAIN VALUABLE GOODS AND MONEY AND THUS A THOROUGH AND DETAILED
INVESTIGATION MUST BE CONDUCTED BY A SPECIAL TEAM SO AS TO PREVENT SUCH CRIME AND PUT TO JUSTICE THE
CRIMINALS WHO ARE SPREADING TENTACLES IN THE SOCIETY AND ENSURE THAT THE MONEY IS RECOVERED FROM
THEM.
7.IT HAS BEEN FURTHER CONFIRMED BY THE REAL OFFICIALS OF MATAK AUTONOMOUS COUNCIL, THAT NO SUCH
SUPPLY ORDERS WERE EVER ISSUED/GIVEN FROM THEIR OFFICE AND THAT THE DOCUMENTS INCLUDING MOU,
PURCHASE ORDERS, BILLS, RECEIVING ETC. ISSUED TO THE COMPLAINANT ARE NOT OF THE COUNCIL. NONE OF THE
ACCUSED PERSONS ARE DIRECTLY OR IN DIRECTLY RELATED TO MATAK AUTONOMOUS COUNCIL IN ANY CAPACITY.
THAT IT IS A SCAM WHICH NEEDS TO BE INVESTIGATED IN DETAILS SO THAT THE ABOVE NAMED ACCUSED PERSONS
ARE BROUGHT TO JUSTICE IMMEDIATELY.
9.THAT THE ENTIRE NARRATION OF THE UNDISPUTED FACTS REVEALS A PRIMA FACIE FRAUDULENT ACT COMMITTED
BY THE ABOVE NAMED ACCUSED PERSONS IN COLLUSION AND CONNIVENCE WITH EACH OTHER WITH THE SOLE
INTENTION TO COMMIT THE FRAUD BY COMMITTING THE OFFENCE OF CHEATING, FORGERY, IMPERSONATION,
CRIMINAL BREACH OF TRUST AND VARIOUS OTHER OFFENCES AND OR ANY OTHER LAW APPLICABLE FOR THE TIME
BEING
10.THE ACCUSED PERSONS ARE JOINTLY AND SEVERALLY COMMIT THE OFFENCES PUNISHABLE UNDER SECTIONS
–120B, 170, 403, 405, 409, 415, 416, 420, 463, 464, 467, 468, 470, 471, 472 , 473 & 506 OF INDIAN PENAL CODE, 1860 AND SECTION
7 OF THE STATE EMBLEM OF INDIA (PROHIBITION OF IMPROPER USE) ACT, 2005 & OTHER PENAL OFFENCES.
11.THAT IN THESE FACTS AND CIRCUMSTANCES, THE COMPLAINANT SEEKS THE KIND INTERVENTION AND PRAY THAT
THE MATTER BE INVESTIGATED IN DETAIL AND THE PERPETRATORS OF THE ELABORATE CRIME BE BROUGHT TO
BOOKS AND COMPLAINANT’S MONEY IS RECOVERED.
12.THAT THE COMPLAINANT BELIEVES THAT IF THE ACCUSED PERSONS ARE NOT TAKEN INTO CUSTODY AND
INTERROGATED IN DETAIL THE ENTIRE CHAIN OF CRIMINALLY CONSPIRACY WILL NOT BE UNEARTHED AND THIS
WILL RESULT IN DESTRUCTION OF VALUABLE EVIDENCE RELATING TO THE COMMISSION OF AFOREMENTIONED
OFFENCES AND AS A RESULT THE ACCUSED PERSONS MAY FLEE AWAY.
13.THAT IN VIEW OF THE ABOVE MENTIONED FACTS AND CIRCUMSTANCES, IT IS REQUESTED THAT THE MATTER MAY
BE INVESTIGATED AND A FIR BE REGISTERED AGAINST THE ACCUSED(S) FOR THE OFFENCES OF CHEATING, CRIMINAL
BREACH OF TRUST, FALSIFICATION OF ACCOUNTS, FRAUD, FORGERY, EMBEZZLEMENT OF FUNDS AND WRONGFUL
GAIN TO THEMSELVES, CREATING FORGED DOCUMENTS, CRIMINAL CONSPIRACY, CRIMINAL MISAPPROPRIATION AND
SIPHONING OFF OF FUNDS, CRIMINAL INTIMIDATION, IMPROPER USE OF STATE EMBLEM OF INDIA AND FOR SUCH
OTHER OFFENCES WHICH ARE FOUND TO HAVE BEEN COMMITTED BY THE ACCUSED(S) DURING THE INVESTIGATION.
HENCE THE CASE.

13. Action taken: Since the above information reveals commission of offence(s) u/s as mentioned at Item No. 2.
 ąƟİƓĎđƣĎýĒĈĘĎþĔíăįþçĘɨĒðþþÿƟĒðĒĂĘĠƠĒćïĂáħįāđįđćĘþòùĂđĺĎđİđĘþđƵïđċïĘį 

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 N.C.R.B ëĂĒôäįĒą

I.I.F.-I äåäåëĄĦ

(1) Registered the case and took up the investigation ĘćđáįĔöĔïĒįþĀȭįĆđįƣĎýïĘįđ or ( ãÿąđ 

(2) Directed (Name of I.O.) þĀȭïđįēįĂđć Nirmal Chandra Biswas Rank ăĀąē Dy. SP (Deputy Superintendant
of Police)

No. âį NA to take up the Investigation ĀđĜĒĈʲĻĊþĀȭïįđ or ãÿąđ

(3) Refused investigation due to þĀȭćđĒĂĺĂđĘĊđİđįïđįý or ãÿąđ

(4) Transferred to P.S. ÿđĂđęĊąĀĒĊïįđ  District ĒöĊđ 

on point of jurisdiction ĒĂĒĀŪɳëĘĊïđ 

F.I.R. read over to the complainant / informant, admitted to be correctly recorded and a copy given to the complainant
/informant, free of cost. ëöđĎđįðĂĺñđôįēĠđïăĒğ˝ĘĂđİđþĺþíà˝ȝęïĒĊĒăąȝĺĎđİđąĔĒĊ˰ēïđįïĒįĘõãĒĆĘĈđñįëùđ
ƵĒþĒĊĒăĺñđôįēĠđïĒąĂđćĕĘĊƟƵĀđĂïįđĎ ĊÞ

R.O.A.C. äįíëĒô

Signature of Officer in charge, Police Station ÿđĂđį

ĆđįƵđȼĒąČĠđį˰đǘį

Name Ăđć HARI CHARAN PATHAK

14. Signature / Thumb impression
of the complainant / informant Rank ăĀąē Dy. SP (Deputy Superintendant of Police)
ĘñđôįēĠđąđþŪđĒĀíàþđį˰đǘįąĔğđ
No. âį NA
äóĔĒĊįõđă

15. Date and time of dispatch to the court äĀđĊþęĊĺƵįýïįđįþđĒįðíčćĠ 

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 N.C.R.B ëĂĒôäįĒą

I.I.F.-I äåäåëĄĦ

Attachment to item 7 of First Information Report ëöđĎđįįĬćĀĄđãĂĔčĒįčáĘĈđĒöþĂĒÿ čćĕĎ 

Physical features, deformities and other details of the suspect/accused: ( If known / seen )
čĘȱĎöĂïäôđćē–įĺĀĎįñúĂĒąïĖĒþþÿđãĂƟđĂƟĒąİįý ĈĒĀĘĎǷđþčđǘđƄƵđȼ 

S. No. Sex ĒĊáñ Date / Year Of Build ñúĂ Height Complexion ñđįąįý Identification Mark(s) ĒôĂđǏïįýįĒôʐ
ƠĒćï Birth þđĒįðąČŪ (cms)
čáðƟđ çǮþđ

1 2 3 4 5 6 7

1 Male 1972 -

2 Male 28/04/1987 -

3 Male 1977 -

4 Male 14/02/1970 -

5 Female 1983 -

6 Male 1986 -

Deformities / Peculiarities Teeth Āđàþ Hair ôĔĒĊ Eye ôʛ Habit(s)(ãĆƟđč Dress Habit (s)
ĒąïĖĒþôđĒįĒƯïĻąĒċɳƟ čćĕĎ ĺăđôđïăĒįDZĀį
ãĆƟđč čćĕĎ
8 9 10 11 12 13

Language/Dialect Place of ʆđĂ Others ãĂƟđĂƟ

ĆđČđçăĆđČđ
Burn Mark ʪĊđ Leucoderma ñđį Mole ĒþĊ Scar ǘþĒôʐ Tattoo ċįēįþ
Āđñ õđĊąñđăįđ ãáĒïþĒôƯ
ĺįđñ
14 15 16 17 18 19 20

These fields will be entered only if complainant/informant gives any one or more particulars about the suspect/accused.
ëåþÿƟĒðĒĂčĒȵĒİɳïįđĎ ąĈĒĀĘĎãĒĆĘĈđñïđįēĘĠčĘȱĎöĂïąƟĒǏãăįđāēįĒąČĘĠëïąđþđĘþđĒāïþÿƟĒĀĘĠ

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