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Rajesh Bhutoria 175

Rajesh Kumar Bhutoria has filed a petition under Section 175(3) of the Bharatiya Nagarik Suraksha Sanhita, 2023, against his neighbor Gaurab Kumar Bhadani, alleging illegal activities and threats to his life and property. The complainant claims to have audio evidence of the accused making threats and engaging in conspiracy against him, and he has sought police intervention which has not been adequately addressed. The petition requests the court to treat it as an FIR and direct an investigation into the matter.

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89 views6 pages

Rajesh Bhutoria 175

Rajesh Kumar Bhutoria has filed a petition under Section 175(3) of the Bharatiya Nagarik Suraksha Sanhita, 2023, against his neighbor Gaurab Kumar Bhadani, alleging illegal activities and threats to his life and property. The complainant claims to have audio evidence of the accused making threats and engaging in conspiracy against him, and he has sought police intervention which has not been adequately addressed. The petition requests the court to treat it as an FIR and direct an investigation into the matter.

Uploaded by

joseph
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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In The Court of Ld.

Additional Chief Judicial Magistrate


at Bidhannagar
Ref.- M.P. of 2025
An Application Under
Section 175 (3) of the
Bharatiya Nagarik
Suraksha Sanhita, 2023
In the matter of :
Rajesh Kumar Bhutoria
S/O
266, D.D Road, South Dum
Dum (M), North 24
Parganas, West Bengal-
700048.
.

.…..Complainant

-Vs-
Mr.Gaurab Kumar Bhadani,
son of Late Indra Chandra
Bhadani, residing at
Seema Apartment, Block
B, 4th Floor, Flat N. 4A,
266, Dakhindari Road,
PatharKal, LakeTown,
Sreeb humi, North 24
Parganas, West Bengal —
700048
…..Accused Person

The Humble Petition on


behalf of the Complainant
above named.
AN APPLICATION UNDER SECTION 175 (3) OF THE
BHARATIYA NAGARIK SURAKSHA SANHITA, 2023

1. That the complainant is a bonafide, law abiding and peace


loving citizen of India having his current and permanent
address mentioned at above cause title.

2. That the accused person is the neighbour of the


complainant and living at the same apartment as your
complainant since long time.

3. That quite some time ago to the utter shock and dismay of
the complainant , he came to know that the said accused
person has been involved in illegal activities and plaining a
conspiracy against the complainant.

4. That for some time the complainant came to know that the
accused person is in continuous contact with one of the
complainant’s friend's employees namely Indal Kumar Roy,
and is asking the complainant’s where abouts and details.

5. That to the effect, the complainant got the voice recording


of the accused person and Indal Kumar Roy in his custody
whereas the said accused person has accused the
complainant in hindi language which when translated to
English it means that the complainant is a two faced man
and making further allegations against the complainant
with regard to being involved in mal practice without any
basis and link whatsoever and also using provocative
terms in his mother lingo against the complainant.

6. That there are several audio recordings of the accused


persons dated 14.01.2025 at 18:06 p.m.,19.02.2025 at
14:35 a.m., 12.01.2025 at 10:54 am and also at 21:54 p.m,
from the accused person’s Mobile No.
9831677795/9831508549 to Indal Kumar Roy Mobile
No.9230668088 whereby the accused person has abused
the complainant in filthy language and having conspiracy
to injure the complainant of his life and property.

7. That after learning about this when the complainant


confronted the accused person, the accused person
became violent and started to abuse him using filthy
language against and gave death threats to the
complainant and his family members.

8. That the accused person also stated that he has vital and
confidential information about the complainant which he
will use to blackmail the complainant if he ever disclosed
this to anyone.

9. That having no alternative the complainant for safe


guarding him and his family’s life took the shelter of law
and subsequently the complainant has lodged written
letter of complaint to Lake Town Police Station which the
P.S. treated as G.D.E. no. 500/2025 dated 07.05.2025 but
no action was taken by the Police Station.

10. That the complainant repeatedly visited the Police


Station on several occasion for the matter but the every
time the Police Authority stated that they were making
enquiry over the issue, but when after long period of time
passed without any response from the Police Authority the
complainant then stated the matter via a letter of
complaint dated 08.05.2025 to the Commissioner of Police
Bidhanngar Commissionerate which the Commissioner
received on 08.05.2025

Photocopy of the Complaint Letter have been annexed.

11. That the accused person with the intention of causing


bodily harm and criminal intimidation to the complainant
mentally tortured and gave death threats to the
complainant, the accused has therefore committed inter
alia the offences of criminal intimidation and these illegal
acts of the accused person amounts to offences under
section 351(2) of BNS, the accused persons further
committed the acts of criminal conspiracy and these
illegal acts of the accused person amounts to offences
under section 61 of BNS , hence they are liable to be
prosecuted and punished by this Hon’ble court.

12. That the complainant resides at the above-


mentioned address and the accused had committed the
offences within the territorial jurisdiction of Lake Town P.S.
under the territorial jurisdiction of this Hon’ble court and
therefore this Hon’ble court has got the jurisdiction to
entertain and try the present complaint.
It is therefore humbly
prayed that Your Honor be
graciously pleased to allow
this petition U/S-175(3)
B.N.S.S. and treat it as F.I.R.
and direct the Investigating
Officer of Lake Town P.S. to
enquire into the matter and
file status report before
Your Honor and/or pass
any other necessary
order(s) as Your Honor may
deem fit and proper for the
ends of justice.

And for this Act of Kindness Your Petitioner as in duty bound


shall ever pray.

Enclosed:
i) Copy of Written Complaint
VERIFICATION

I, Rajesh Kumar Bhutoria S/O , aged about 52


years 266, D.D Road, South Dum Dum (M), North 24 Parganas,
West Bengal-700048, do hereby affirm and verify as follows:

i) That I am the complainant in this instant matter and am


well aware of the facts and circumstances of the instant
matter.

ii) That the statements made above are true to the best of
my knowledge and belief.

DEPONENT

Identified by me

Advocate
AFFIDAVIT

I, Rajesh Kumar Bhutoria S/O , aged about 52


years 266, D.D Road, South Dum Dum (M), North 24 Parganas,
West Bengal-700048., do hereby solemnly affirm and declare as
follows:

i) That I am the complainant in this instant matter and am


well aware of the facts and circumstances of the instant
matter.

ii) That the statements made above are true to the best of
my knowledge and belief.

DEPONENT

Identified by me

Advocate

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