To, 04.08.

2024
SHO concern,
Shahdara, Delhi

Subject:- Criminal compliant to register FIR under the

provision of Bharatiya Nyaya Sanhita against M/s Ambey
Bearing & Mill Store through its proprietor, Mr. Yogesh
Sharma and Kavita Sonar and Rajeev Sharma for cheating
and defrauding the Complainant of an amount of Rs
53,20,000/- and making false documents and committing
forgery for purpose of cheating.

Sir,

1. The Complainant i.e. M/s Anand Rathi Global Finance is a

private limited company registered under Companies Act,
1956 and has been a prominent Non-Banking Financial
Institution since 1994, engaged in providing services like loan
against Property (SME Funding), Loan against securities
(including Shares, Commodities, Mutual Funds, Bonds,
ESOPs and other liquid collaterals), construction finance and
Project Financing.

2. The Accused M/s Ambey Bearing & Mill Store is a

proprietorship firm bearing GST no. 07BFWPS4438A1Z4 and
Accused Yogesh Sharma is the sole proprietor of the said firm.
The firm operates from Ground floor, 27,137,3 Gali No. 2
Jwala Nagar Shahdara, Delhi-110032 Mob. 9718665441. The
Accused Kavita sonar is the wife of accused Yogesh Sharma
and both are the resident of H.No. 1576, First floor, Shah Bagh
 Colony, Naveen Shahdara, Delhi-110032. The Accused Rajeev
Sharma resident S/o Vishnu Dutt Sharma R/o House no. 211,
Karkardooma, Laxmi nagar (East Delhi), East Delhi-110092.

3. It is pertinent to mention that the Accused Rajeev Sharma

purchased Ground Floor upto roof of the top floor along
with roof rights, part of property bearing no. 863, adm. 250
sq. yds., out of Khasra No. 10 Situated at Village – Uldhanpur
in the abadi of Near Kali Mata Mandir, Subhash Gas Agency
G.T. Road, Illaqa Shahdara Delhi – 110032 vide sale deed
registered under Regd. No.6837, in Book No.1, Volume
No.3203, on Page No.62-73 dated 29.11.2019 SR-IVA,
Shahdara, New Delhi executed by Rajan Mallah S/o Rattan
Lal Mallah and Shri Bake Lal S/o Naitram in favour of
Accused Rajeev Sharma.

4. The accused individuals are alleged to have conspired to

commit fraud and deception by attempting to resell a
previously sold portion of the property, using different
property and registration numbers. In furtherance of this
scheme, they allegedly fabricated a sales agreement between
the accused, Rajeev Sharma (purported seller), and other co-
accused, regarding the purchase of a built-up property
comprising the entire first and second floors, with roof rights,
located at Village Uldhanpur, near Kali Mata Mandir, Subhash
Gas Agency, G.T. Road, Illaqa Shahdara, Delhi – 110032

5. That in May, 2023 the Accused person approached my good

office to avail the service of loan against the property to
purchase the above-mentioned property for a consideration of
 Rs. 70,00,000/- and further shown their willingness to avail the
loan facility of Rs. 53,20,000/- (Fifty-three thousand twenty
thousand only). My good office requested the Accused person
to submit the requisite documents to start the procedure.

6. Once the Accused person submitted the required documents, I

initiated the loan sanction and loan disbursement procedure.
On 29.05.2023 the loan of Rs. 53,20,000/- was sanctioned in
favour of the accused person. That vide loan application no.
APPL00006099 on 29.05.2023 the loan amount of Rs.
53,20,000/- (Fifty-three thousand twenty thousand only) was
transferred to Rajeev Sharma ICICI bank account, copy of the
ledger account attached with the compliant for reference.
Accordingly, as per their criminal conspiracy the said property
got registered in the name of the Accused person on
18.07.2023 bearing Property no. 863, out of Khasra No. 10,
Reg. No. 5655, Book No.1, Volume No.4697, on Page No.112-
121 SR-IVA, Shahdara, New Delhi and charge were created
against the Complainant over the said Property by depositing
of aforesaid original Registered Sale Deed dated 18.07.2023.

7. The Accused person was supposed to repay the loan amount in

instalment of Rs. 69,071/- in 180 monthly instalments from
their bank account of Indian bank bearing account no.
6968711954 on 10th day of every month at rate of interest
13.50 %. That the Accused person had some other ulterior
motives and to succeed in the same, since from the very
beginning the Accused person became default in paying the
monthly instalment. My office tried to approach the Accused
person through phone calls and emails but the Accused person
 based on one false pretext or other kept on prolonging the
issue and till now have not paid single monthly instalment.

8. That in the month of January, 2024 the loan account of the

Accused person was declared NPA due to default in paying the
monthly instalment as agreed in the contract. Hence, the
Accused person since inception had the motive of cheating and
defrauding me by not paying the loan taken of Rs. 53,20,000/-
against the property and thereafter not paying the monthly
instalment as promised in the contract.

9. This is to further inform that while initiating the legal

proceeding against all accused person I further inquired and
got to know that, all Accused person including Rajeev Sharma
has taken multiple loans from different financial institution,
by misrepresentation and with intention to defraud. All
accused person in accomplice with each other allegedly
fabricated numerous sales agreement, have registered different
floors of the same property vide different registration number
and house number and based on that all accused person have
collectively secured lakhs of loan from different financial
institution which amounts to more than one crore.

Based on the above-mentioned facts and documents annexed

with this complaint, all accused person has committed fraud by
securing loans by fabricating forged sale agreement and further
not paying the monthly instalments, hereby I request your
urgent intervention to register a FIR against the accused person
and punish the accused person under various provision of the
Bharatiya Nyaya Sanhita.

Thanking You
Complainant
Thorough Authorized Signatory