IN THE COURT OF MS. MEENA CHAUHAN LD.

JMFC, CENTRAL DISTRCIT, TIS HAZARI COURTS,

DELHI
CC No. 9544/2022

IN THE MATTER OF:-

Sanjeev Kumar …Complainant

VERSUS
Ravi …Accused

REPLY OF APLLICATION UNDER SECTION 143-A

OF THE NEGOTIABLE INSTRUMENT ACT FOR
ISSUANCE OF NECESSARY DIRECTIONS TO THE
ACCUSED TO PAY 20% OF THE CHEQUE AMOUNT
AS INTERIM COMPENSATION TO THE
COMPLAINANAT

MOST RESPECTFULLY SHOWETH:-

1. That the submissions made in the application of the

complainant are false, frivolous and incorrect, there was no
such liability that was to be discharged by the accused
towards the complainant and the complainant has misused
the cheques of the accused which is punishable offence
2. That the accused owes no liability against the complainant
and it is submitted that no case U/S 138 N.I Act is made but
as there is proper justification (no liability of the accused
towards complainant) for not honouring the cheque of the
complainant.
3. That the brief facts and corrects facts of the case are
that accused and complainant are known to each other as
the complainant is the friend of the accused’s elder brother
namely Sunny, who passed away in year 2012. The
Complainant being known to the accused and his family
used to visit the residence of the accused. That post the
death of the accused elder brother the financial condition of
the accused became unstable and because the complainant
used to visit the residence of the accused he too became
aware of it. The complaint then offered that a friend of his
by the name of Deepak who will is a loan facilitator and
helps individuals in providing loan. Then following to it
Deepak and the complainant visited by residence and in the
lure of providing us loan took my, my sister Anshu and my
monther’s aadhaar card, pan card and passport size photo
along with 10 blank cheaues all in the name of
documentation for availing of loan. The accused is not
educated so he trusting the complainant and Deepak signed
over a few blank and a few written documents the contents
of which were not known to the accused. Accused after
passing of enough time asked Deepak and complainant
about the loan but up until now no loan has been given.
4. That it is submitted that the application under Section 143-
A of the Negotiable Instruments Act, along with the
accompanying memo of parties, index, bears the date of
07.08.2025 filed by the complainant. This date is evidently
in the future and is therefore erroneous and cannot be
 considered valid. Such an application cannot be deemed
correct or admissible due to the apparent discrepancy in the
date. The submission of documents with future dates is
impermissible and leads to doubts about the authenticity
and legality of the application.
5. That it is pertinent to mention that the accused was already
lodged an official complaint against the complainant and
Deepak for misusing of the cheques in question the
complaint is registered bearing complaint No. 64-A dated:
06,-02.2024. That the copy of the said complaint has been
enclosed herewith as “Annexure D-1”.
6. That it is submitted that the complainant and Deepak when
performed misdeed with the sister of the accused then a
complaint dated May, 2022 and another complaint dated
23.09.2022 Pertaining DD No. 40-A and wherein the F.I.R
against the Complaint has also been registered on direction
of the Hon’ble Court vide Order dated________ , in
Gandhi Nagar Police Station bearing F.I.R no. 444 of 2024
under Section 376(2) and Section 504 of the Indian Penal
Code (IPC), which is currently pending before the Hon'ble
Session Court, East District, Karkardooma Courts, Delhi
titled as xxx v/s Sanjeev Kumar bearing SC 30/2025. The
charges were framed against the complainant on
07.02.2025, reflecting the complainant’s involvement in
wrongful acts, thereby implicating them in the case. Given
the gravity of the charges and the ongoing proceedings, the
complainant's role in the alleged offenses is yet to be
 determined. The copy of the said F.I.R has been enclosed
herewith as “Annexure D-2”.
7. That the accused has never taken any loan from the
complainant and, therefore, he is under no liability to repay
any loan to the complainant.
8. That it is submitted that the complainant should not be
granted any interim compensation under Section 143-A of
the Negotiable Instruments Act (NI Act) until the
complainant is acquitted or a formal order is passed in the
matter by the Court. Granting such compensation at this
stage would be premature, as the complainant's
involvement is still under judicial examination.
9. That it is submitted that the object of section 143A of NI
Act can never be extended to providing any undue benefit
to the complainant at the stage when charges against the
accused have not been substantiated, and the accused has
not even got the opportunity to cross examine the
complainant's witnesses, much less entering upon his
defence.
10.That the application filed by the applicant/complainant is
gross misuse of process of law and shall be missed.
 Prayer
It is, therefore most respectfully prayed that this
Hon’ble court may be pleased to dismiss complainant’s
application, in the interest of justice.

APPLICANT

DELHI
THORUGH
DATE__________ S.P. YADAV & DEEPAK
KUMAR
Advocates
CHAMBER NO.F-608,
LAWYERS CHAMBER
BLOCK,
KARKARDOOMA COURTS, DELHI-110032
Email:- avighnalaw@gmail.com,
Mob:9990180433
 IN THE COURT OF MS. MEENA CHAUHAN LD.
JMFC, CENTRAL DISTRCIT, TIS HAZARI COURTS,
DELHI
CC No. 9544/2022
IN THE MATTER OF:-

Sanjeev Kumar …Complainant

VERSUS
Ravi …Accused
AFFIDAVIT
I, Ravi, S/o Sh. Ramesh, R/o 283, Jhuggi, Opposite Gali
No.16, Old Seelampur, Ajit Nagar, Gandhi Nagar, Delhi-110053
do hereby solemnly affirm and state as under:
1. That am the Accused in the present case and as such I
am well aware of the facts and circumstances of the case.
I am competent to swear this affidavit in reply to the
application filed by the Complainant under Section 143-
A of the Negotiable Instruments Act.
2. The contents of the accompanying reply have been
prepared by my counsel under my instruction and have
been explained to me in my vernacular may be treated as
part and capable to file the present affidavit it as the
same have not been reproduced herein for the sake of
brevity.
 DEPONENT

VERIFICATION: I, Ravi, the above-named deponent, do hereby declare that the contents of the
above affidavit are true and correct to the best of my knowledge and belief. No part of it is false
and nothing material has been concealed therein. Verified at Delhi on this_______.

DEPONENT

IN THE COURT OF MS. MEENA CHAUHAN LD.

JMFC, CENTRAL DISTRCIT, TIS HAZARI COURTS,
DELHI
CC No. 9544/2022
IN THE MATTER OF:-

Sanjeev Kumar …Complainant

VERSUS
Ravi …Accused

LIST OF DOCUMENTS

S.No. Particulars Page No.

APPLICANT
DELHI
THORUGH
DATE__________ S.P. YADAV & DEEPAK
KUMAR
Advocates
CHAMBER NO.F-608,
LAWYERS CHAMBER
BLOCK,
KARKARDOOMA COURTS, DELHI-110032
Email:- avighnalaw@gmail.com,
Mob:9990180433