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Corewip Limited Cyprus Vs. Abhishek Verma & Ors
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IN THE COURT OF SPECIAL JUDGE CBI COURT, TIS HAZAR!COURTS, NEW DELHI.
COMPLAINT NO /2013
IN THE MATTER OF :
M/s Corewip Cyprus Pvt. Ltd.,
Registered Office at 77, Strovolos Ave,
Strovolos Nicosia, Cyprus,
Through its Authorized Signatory
Mr. Joseph Rubinstein,
Also at B-lO, 3rd Floor,
Friend's Colony (West)
New Delhi-110065
Through its Authorised Representative Vikki Choudhry
..... COMPLAINANT
•
VERSUS
1. Mr. Abhishek Verma,
Son of Late Shri Shrikant
Verma, Residing at Church
Road, Vasant Kunj,
New Delhi- 110070.
Presently at Tihar Jail,
NEW DELHI
2. Ramprakash Singh, ,Son of Shri
not known
C/o G.T. Telecom Private
Limited, Paharpur Business
Centre, 21, Nehru Place,
NewDelhi-ll0019
3. Mr. Jitendar Garg, Son of Shri
not known
Resident of J-363, Sarojini
Nagar, New De1hi- 110023.
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4. Mr. Sanjiv Kapoor,
Son of Shri not known
R/o not known
7. Mrs. Anca Neacsu, Wife of Shri
Abhishek Verma resident of
Church Road, New Delhi- 110
070.
Presently at Tihar Jail,
New Delhi
•
...... Accused
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COMPLAINT ON BEHALF OF THE COMPLAINANT
MOST RESPECTFULLY SHOWETH:
. 1. That the present complaint has been filed by Mis
Corewip Limited, a company incorporated under the laws
of Cyprus having its registered office at 77 Strovolos Ave,
Strovolos Nicosia, Cyprus through its Authorised
•
Signatory Mr. Joseph Rubinstein for registration of F.I.R
Uls 415, 420,464,465, 467, 468,470,47t & 120-B of
Indian Penal Code and under various offences under
Prevention of corruption Act, & Information Technology
Act 2000, as applicable in the facts and circumstances of
the present case against Mr. Abhishek Verma, Ms. Anca
Neacsu, Mr. RP Singh, Mr. Dinesh Khurana, Mr. Sanjiv
Kapoor, Mr. Jitendar Garg, Ravi Chauhan & Unknown
Others and for detailed investigation into cheating and
fraud of US $1. 1 million (Approximately Rupees 5 crores)
committed on Corewip Limited, the Complainant by the
accused persons who conspired criminally with the intent
to cheat the complainant, company and in pursuance of
their criminal objective forged documents and cheated an
amount of approximately Rs. 5 Crore from the
complainant's company, as made out by the Complainant
in his Letter No. TCM-Verma-10-CBI dated 25.10.2012
addressed to Special Director CBI, V.K Gupta whom he
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met officially m New York. (Enclosed herewith as
Annexure-A). Fresh evidence has also' been collected
recently by CBI from one Edmund Allen to show that
these funds were then used to provide, gifts, bribe
Ministry Of Defence & Min,istry of Home Mfairs Officials
for Arms contract and a part of money also laundered
overseas via Hawala. •
2. The brief facts leading to the filing of the present
complaint is given as under:-
(a) That the complainant is a Cyprus based Investment
Company. The Chairman of M/s Corewip Limited is Mr.
Joseph Rubinstein. That Mr. Joseph Rubinstein
(hereinafter referred to as JR for short) and Mr. Haim
Yashar (hereinafter referred to as HY for short and the
then Authorized Representative of the complainant) were
approached by Abhishek Verma (hereinafter referred to as
AV for short), on or around May-June, 2009 with a
proposal to enter into a joint venture agreement for
providing services in India under ISP License with voice,
including mobile and/or fixed line voice (the "Project"). AV
indicated via email that since his company Ganton
Limited USA was in the process of incorporating a 100%
subsidiary Ganton India Pvt. Limited (hereinafter referred
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to as GIPL for short) and given the urgency Mr. Gian
Chand Arora (hereinafter referred to asGCA for short)
would be holding his shares in the joint venture company,
".,"
GTT; till such time as GIPL would be incorporated or some
legal cases (including the Scorpene Casel Naval War
Room Leak Case) he was involved in were settled and that
Mr. Arjun Arora and Mr. Vikki Choudhary would be their •
nominees on board the JVC (Joint Venture Company). AV
further projected that he was politically resourceful and
that sons and relatives of powerful ministers and leaders
were his partners and that Mr. Siddharth Tytler
(hereinafter referred to as ST for short) who belongs to a
well known political family, would be a shareholder in the
Joint Venture. In this regard, he in various
correspondences dropped the names of senior politicians
also. JR was introduced to Mr. Jagdish Tytler by AV at his
residence on 04.08.2009. AV claimed that Mr. Tytler was a
powerful Congress MP and also a Gen Secretary of the
Congress Party. As favor 25% shares were to be given to
his son S. Tytler and 25 % would be given to AV's proxy
Arjun Arora's father until GIPL received permission, from
ROC (Registrar of Companies, New Delhi) to commence
operations in India. The balance would be held by Corewip
the foreign collaborator. Email evidence of this exists with
•
Edmond Allen, (hereinafter referred to as EA for short)
who has provided es<;:row services to AV for the last 10
years and also administers Ganton Limited USA, a
company incorporated in the US at AV's request and is
AV's holding company. The CBI has obtained evidence of
this on their Visit to New York in 2012 as this company
has also figured in other cases of Fraud. Forgery. PMLA •
and OSA cases being invel'tigated presently by the CBI.
TCM Mobile LLC (hereinafter referred to as TCM for short)
the patent holder of VOIP Technologies signed a MOU on
25.08.2009 with Ganton USA on behalf of its fully owned
subsidiary Ganton 'India Pvt. Limited (GIPL) whose
Managing Director was Anca Neacsu (hereinafter referred
to as AN for short), AV's live in partner for providing VOIP
Technologies in India as ROC permission for GIPL was yet
to be received.
(b) Thus AV induced the complainant with promises about
the success and profitability of the project in India and
dishonestly induced the Complainant to execute the joint
venture Agreement dated 18 November, 2009 ("JV
Agreement") (enclosed herewith along with the
photographs of the signing ceremony as Annexure-B).
although he and his accomplices had no intention to
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execute the project but only to cheat and misappropriate
the investment made by the complainant.
(c) That on 18th November, 2009, the J.V. Agreement was
" .. entered into between:
JV signed between Corewip as the foreign JV Partner and
-'.' ST & son of Jagdish Tytler MP, GCA & father of Arjun
Arora and GIPL as Indian JV Partners. Both AV and his
lawyer Rajneesh Chopra (hereinafter referred to as RC for
short) were present and guided the proceedings. The JV
Agreement specified that the shareholding in the Joint
Venture Company (hereinafter referred to as JVC for
short) would be (Art 2.3,c)
GCA- 25.5%
ST - 25.5%
Corewip - 49%
Final share holding after FIPB Approval would be (Art 2.6)
GCA- 13%
ST - 13%
GIPL- 24 %
Corewip - 50%
GIPL is a wholly owned subsidiary of Ganton Limited, a
company incorporated under the laws of U.S.A. and
having its principal place of business inNew York, U.S.A.
(d) That since both G�ton Limited USA. & its sUbsidiary
GIPL were front companies of AV, the Complainant
herein insisted that AV execute a side letter dated 19 •
November, 2009 (Pg 40-41of Annexure-A). Vide this side
letter, AV committed that in the event further funding
Was required by JVC (GT Telecom hereinafter referred to
as GTT for short) it shal� be his personal responsibility
to fund the joint Venture Company up to US $ 4 Million.
(e) That as per the terms of the JV Agreement it was agreed
upon between the; parties that both the Indian JV
Partner and the Complainant would contribute towards
the initial paid up share capital of the JVC which shall
be Indian Rupees 100,000,000 (Rupees Ten Crores). In
furtherance of the said JV Agreement, a total sum of US
$ 1.1 million (Approximately rupees 5 Crores) was,
remitted by the Complainant to the GTT's Bank
Account No. 1617056 with ABN Amro Bank, (Now Royal
Bank of Scotland) ("Bank Account" ), New Delhi, against
which 49% shareholding of the JV Company was issued
to the complainant. However, as revealed now, contrary
to the promlses and the agreement, GIPL, ST, GCA
having a 51% shareholdingjn GTT dishonestly did not
remit any money to GTT's bank Account towards their
contribution to the paid up share capital, since their
intention was not to do business or make any
investment but to defraud and cheat the Complainant of
its US $1.1 million. Furthermore AV via an email dated. •
03.03.2010 fraudulently informed JR and HY that GIPL
had remitted the share capital on behalf of the above
shareholders knowing that to be fully false. (Pg 55 of
Annexure-A)
(f) That AV used fake email ids to communicate and share
forged documents with the complainant. In furtherance
of his strategy to escape any investigation into his
wrongdoings, AV deleted his other email ids viz.
[email protected], [email protected],i
[email protected], [email protected],
[email protected] among others. It is submitted that AV using
the email id [email protected], emailed .all his proxies and
EA on 20.12.2009 stating that GIPL headed by AN had
signed an agreement with ZTE to provide low cost
handsets for the JVC to be rename GTT. He attached
photos of the signing ceremony as well as the
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agreement. All evidence regarding AV & AN's dealing
with ZTE were handed over._to the CBI Team when they
visited EA in NY as they were investigatin� another case
in which AV & AN received and passed on bribes to
unknown GOI Officials for extension of the cancelled
visa's of ZTE employees in India. This evidence remains
in the exclusive domain of the CBI. •
(g) AV now using the email id [email protected] sent
an email to EA, his escrow Agent and President of
Ganton USA on 09.01.2010 informing him that the JVC,
GN Infotech would be renamed as GTT. He also informed
EA that TCM (Corewip) would be investing USD 1.1
million and he would be investing USD 1.1 million from
internal Resources in In<ilia namely GlPL. The CBI has
obtained evidence of AV using this email id on their
Visit to New York while investigating an OSA case
against AV & AN in which both have been charge
sheeted and are in judicial custody. Further they have
requested EA not to share this evidence with any other
investigation agency (CBI email dated 15.06.2012,
enclosed herewith as Annexure-C). AV now using the
email id [email protected] sent email to JR and
HY of Corewip/TCM on 15.01.2010 agreeing that any
expenditure more than USD 5000/- from the JV will
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require two signatures Le. one from each party namely
Corewip and the other from the Indian JV partners
authorized signatory (Pg 55 of Annexure-A). The CBI has
obtained evidence of AV using this email id on their Visit
to New York while investigating an Official Secrets Act
case against AV & AN in which both have been charge
sheeted and are in judicial custody. Further they have •
requested EA not to share this evidence with any other
agency. CBr has also obtained evidence from EA & the
FBr that the domain name www.vermafoundation.com
linked to this email idwas owned by AN, AV'slive in
partner. This evidence continues to. remain in the
exclusive custody of the CBr till date.
(h) _AV again using the email [email protected]
also sent email on 16.01.2010 to JR and HY of
Corewip/TCM & others, the draft of the MOU to be
signed between GTT and ZTE for low cost handsets. All
evidence regarding AV & AN's dealing with ZTE were
handed over to the CBI Team when they visited EA in
New York as they were investigating another case in
which AV & AN received and passed on bribes to
unknown Gar Officials for extension of the cancelled
visa's of ZTE employees in India. This evidence remains
in the exclusive domain of the CBI._AV- using the email
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id [email protected] also sent another email on
09.02.2010, to emails JR.and HY of CorewipjTCM,
attaching a forged Monthly Bank statement of GN
Infotech (now called GTT) to show them that GIPL was
depositing funds towards its half of the share capital in
the JV as well as on behalf of GCA & ST lieing the other
Indian shareholders (Pg 42-44 of Annexure-A). It is •
pertinent to mention that G.N. Infotech Pvt. Ltd., a
company incorporated on 29.04.2005 was acquired by
. G.C.A. and EST. on 30.11.2009. G.N. Infotech Private
Limited was renamed G.T. Telecom Pvt. Ltd. (GTT) on
01.02.2010. The JV Company was headed by Sanjiv
Kapoor (hereinafter called SK for short) a close associate
of AV._AV, AN, SK & RP Singh (hereinafter called RPS for
short) then conspired and SK fraudulently' signed a
Lease Agreement on 15.02.2010 behalf of GTT with
Gupta Brothers the landlords for a farmhouse in Delhi
(Pg 35-37 of Annexure-A). This farmhouse had since
then served solely as the residence of AV & AN till it was
raided by the CBI on 07.05.2012, even though on paper
AN and AV have nothing to do with GTT, thereby
willfully becoming a party to defrauding the
Complainant. To achieve the above SK on behalf of GTT
fraudulently and without Board approval, agreed to and
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later did pay the landlord a deposit of USD 20,000/- and
monthly rent of USD 6-000 1 - without informing the
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Foreign JV Shareholder Corewip about this or obtaining
his signatures on the monthly Cheques. All the
documents in this regard were seized by the CEI when
they raided the s�d premises and are still in their
custody till date. AV using the email [email protected] •
forwarded the GTT Business plan to AN & Others but
bcc to EA. The plan was sent to AV by Prakash Idnani a
business consultant personally known to AV who
nominated him on the Board of Directors of GTI on 18
February 2010, which shows AV was the mastermind of
this fraud (Pg 29-34 of Annexure-A). AV using the email
id [email protected] sent email on 26.02.2010 to JR and
HY of Corewip/TCM and on the Board of Directors of
GTI and attached forged'ABN Amro, Demand Draft &
Deposit Slip for a value INR 2.5 Crores to fraudulently
convince them that GIPL had deposited a part of its
share capital in GTI (Pg 47-49 of Annexure-A). This
email was CC EA and the CBl has Obtained the original
email from EA when they visited him New York and no
other agency has access to it._AV using the email id
[email protected] sent another email on 02.03.2010 to
>.: JR and HY and attached another forged ABN Amro DD
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& Deposit Slip for a further value INR 2.5 Crores (Pg 50-
54 of Annexure-A). This email is CC EA and again the
CEI has obtained the original email from EA when they
visited him New York and no other agency has access to
it.
(i) AV using the email [email protected]
informed HY & JR that on 15.03.2010, GTT will remit •
USD 300,0001- to TCM as Royalty for the VOIP
Technology (Pg 61-62 of Annexure-A). The CBI has
obtained evidence of AV using this email id on their Visit
to NY while investigating an OSA case against AV & AN
in which both have been charge sheeted and are in
judicial custody. Further they have requested EA not to
share this evidence- with any other investigation agency.
AV using the email id [email protected] also sent email
to JR & HY on 24.03.2010 of Corewip/TCM and
attached forged ABN Amro Monthly Bank Statement for
the period 01 Feb - 22 March 2010 falsely showing GIPL
has deposited 5.5 crores as its share capital (Pg 56-57 of
Annexure-A). AV furthet using the email id office@gt-
tel.com sent emails to JR and HY on 26.03.3010 and
attached forged ABN Amro Debit Advice showing USD
300,0001- had been remitted from GTT to TCM (Pg 65-
66 of Annexure-A).
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til That in response to the._ constant queries of the
complainant about contribution towards the paid up
capital from GIPL, ST and GCA, AV fn conspiracy with
SK, and AN circulated forged Bank statements, Demand
Drafts and Deposit slips, indicting payment by GIPL on
their behalf. These forged bank statements and deposit •
slips had been provided to the complainant with the
intent to commit fr�ud on the complainant by inducing
them to believe that the India JV Partner had
contributed their share to the JVC and that all was in
order in the JVC. However, no such money was ever
transferred to the Bank Account. All the drafts, deposit
slips and bank statements were forged. After several
telephonic requests by JR & HY to AV, AN & SK for
producing all financial records of GTT, AV agreed to pay
back the money of Corewip but requested them on
19.04.2010 to accept the same from his overseas
accounts as the Indian regulations did not allow the
same. AV using the email [email protected]
sent email to JR sending forged documents showing that
LGT Bank in Liechtenstein had remitted Euro 696300/-
from his account held with them on 12 April 2010 which
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off course was never received as it was fake (Pg 70-71 &
80-84 of Annexure-A).
(k) As agreed upon between the parties, BY as nominee for
the complainant was to be an Authorized signatory to
the GTI Bank Account. In furtherance of the said
decision, a bank application was brought personally by •
RPS to HY who had duly completed/ executed the bank
application and returned to RPS the close confidant of
AV for submission to the bank. Thereafter, the
complainant and HY were fraudulently and dishonestly
made to believe that HY had been made the authorized
signatory to the Bank Account and for all payments
above USD 5,000/- his signatures would be needed
along with the nominee of the Indian Shareholders. Fed
up with AV's and SK's excuses about the financial state
of GTI, HY along with JR came to Delhi on 21.04.2010
unannounced to meet Dinesh Khurana the Relationship
Manager of GTI at ABN Amro Ltd., now known as Royal
Bank of Scotland (R.B.S.). Mr. Dinesh Khurana who is
also the Relationship Manager of other proxy companies
of AV & AN like GIPL, Sig Sauer India etc. immediately
switched of his mobile 'phone and left the building in
haste and HY and JR were met by a lady who informed
"
them that HY was not an authorized signatory to the
Bank Account. The Bank officials refused to share any
information with HY or JR because as per the bank
".,.
records HY was not the authorized signatory to the Bank
account but instead one RPS, AN and Mr. Jitendar Garg,
were the authorized signatories. This was never the
understanding the complainant had reached. This was •
the first time HY realized that the documents showing
him as Joint signatory of account and signed by him
and handed over to RPS and AV had been substituted
by forged ones which showed authorized signatories as
RPS, AN & J Garg and later Surendra Singh all of whom
were employees of GIPL and not GTT.
(1) That pursuant to the abovementioned revelation that HY
was not an authorized signatory to the Bank Account,
HY immediately called upon AV and informed him about
the same. AV despite being aware of the true factual
position, dishonestly concealed that HY was not an
authorized signatory to the Bank Account and instead
with the intent to commit further fraud on the
complainant assured HY that the same will be checked
with the Company Secretary of the JV Company and the
Relationship Manager at the Bank and.a letter from the
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Lawyer of the JVC confirming that HY was an authorized
signatory to the Bank Account shall be sent to him.
However, till date no such confirmation was sent (Pg 72-
79 of Annexure-A).
(m) That AV and his associates have mastered the art of
forgery and have used it to dupe investors and •
businessmen. Along with the JV Agreement, a Service
and consultancy Agreement dated 15th December, 2009,
was executed between GTT and TCM Mobile LLC
("TCM"), whereby it was agreed that TCM would provide
services required to carry on the business of GTT
(Enclosed herewith as Annexure-D). Under the terms
of this Service and Consultancy Agreement, TCM was
entitled to USD 300,000 as an advance amount, As AV
and his associates had no intention to do business but
to only squander US $ 1.1 million, Abhishek AV
circulated a forged Debt Advice to TCM indicating that
US $ 300,000 has been wired to them from ABN Amro
Bank. However, no such wire was received by TCM and
the said fact was confirmed by the First Republic Bank
to which the money was remitted to as per the forgede- ".,-.' /
Debt Advice (Enclosed herewith is an. . from
the First Republic Bank conflrming that no wire was
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received from GTT as Annexure-E). After the lapse of
a week's time from the date�rovided on Debt Advice, AV
acknowledged that no money was wired to TCM under
the Debt Advice and therefore, he promised to pay the
money out of his personal accounts abroad (Pg 67-68 of
Annexure-A). Mr. AV thereafter sent an email using a
fake email id reflecting transfer of Euro 696,300 from •
his Lichtenstein bank account which he held in LGT
Bank to the complainant. Even these funds were not
received.
(n) That in order to conceal the wrongaoings and fraud
perpetuated upon the complainant, on 28.04.2010, AV
informed the complainant and the Board of Directors of
the JVC that pursuant to a notification passed by
Department of Telecom (DoT) (attached herewith as
Annexure-F) the Project has become unviable in India
and therefore, they should drop the Project.(attached
herewith the said email as Annexure-G)
(0) That contrary to his intention AV informed the
complainant that the JV agreement allows both parties
to exit with mutual consent and the JVC can be
dissolved and the investment/ capital can be repatriated
back to both the parties immediately. Further, the
complainant was informed by AVon 06.05.2010 that the
:.:
Clause 3.3 of the JV Agreement can be used to
terminate the JV agreement when there is
restriction/impediment to the business of GTI and that
the Indian JV Partners can .. buyout the
complainant.(attached herewith the said email as
Annexure-H)
(p) That AV vide his email dated 29.04.2010 (attached
herewith as Annexure-I), informed the complainant
and the board members of the JVC that after lengthy
discussions, it was decided by the Indian and Israeli
promoters that the JV agreement and the JVC be
dissolved and henceforth the dissolution of the JVC has
commenced. Further, relying on the false
representations of AV, the complainant executed a
Rights Transfer Agreement and mailed it to GIPL for
execution by the authorized representatives of GIPL, ST
and GC. However, till date the said Itghts Transfer
Agreement has not been signed by the Indian Party,
while the complainant's investment in GTI has been
fraudulently withdrawn and squandered.
(q) That further to the'surprise of the complainant, an email
dated 22.05.2010, was allegedly received from Mr. AIjun
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Arora (enclosed herewith as Annexure-J), wherein it
was stated that the complainant was misinformed that
clause 3.3 of the JV Agreement has been triggered and
that GTT IS headed towards 'dissolution. But
immediately thereafter, the complainant was informed
by AV that efforts are being made to' peacefully resolve
the matter. Mr. Arjun Arora has now informed the CBl •
Team, who took his statement in NY recently, while
investigating another case that this like many emails
were fraudulently sent in his name by AV & SK who had
complete access to the servers which were located at
AV's residence (enclosed herewith as Annexure-K). He
also stated that AV had fraudulently misrepresented
facts to him and his father on matters of GTT and had
confirmed that GIPL had indeed deposited the share
capital on behalf of itself as well as GCA & ST in GTT.
The above submissions of Arjun Arora were found to be
true when the CBI investigated the leakage of TOP
Secret documents of the MOD (Ministry of Defence) in
2012 which lead to AV & AN being charge sheeted under
Sec 3 of the OS Act 1923. This was largely possible due
to the electronic and email records provided by EA and
are in the sole custody of the CBI till date.
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(r) That the complainant kept waiting anxiously for the
execution of the Rights Transfer Agreement and to get
back their investment but till date neither the agreement
has been executed nor has the money been repatriated
to the complainant. That the accused above named had
made fraudulent promises and representations to the
complainant and never had the intention to return the •
money of the complainant.
(s) That being continuously harassed by AV and his
associates, HY and JR tendered their resignation from
the Board of GTT with effect from 01.09.2011, but till
date the same has not been taken on record nor have
the regulatory authorities been informed of the same.
The complainant has reason to believe that the
resignation of the Corewip representatives have
deliberately and malafidely not been taken on record so
that any legal action based on fraud and cheating
committed by AV along with his associates as the
authorized representative of GTT, would be misdirected
on other directors of GTT who are innocent and not
aware of the criminal acts of AV along with his
associates in the name of GTT. HY and JR have already
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filed complaints with various Authorities but no action
has been taken .
(t) That AV has also resorted to other unlawful means to
dissuade the complainant from initiating any action
against him and his associates. HY and JR were
threatened on phone and via text messages by AV •
wherein he had stated that: "Do what u feel like doing
and be prepared for a bloodbath" and "Indian customs
and Immigrations would be definitely looking forward to
welcoming you during your and Haim's next trip to India".
2 In the facts and circumstances mentioned herein above
and below, the Complainant made a complaint dated
16.11.2011, disclosing the cognizable offences committed
by the accused persons before the Additional Dy.
Commissioner of Police, Economic Offence Wing, P.S.,
Mandir Marg, New Delhi for registration of the F.I.R.
against accused persons above and bring guilty to books.
After dragging its feet the complaint was finally
acknowledged by them on 27.02.2012 but NO FIR has
been registered till date, even though complaint disclosed
commission of cognizable offence. (Enclosed herewith
Copy of the Complaint dated 16.11.2011 filed by the
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complainant with the DCP Economic Offences Wing,
Crime Branch, Qutab Institutional Area, Delhi Police, New
Delhi acknowledged by them along with the annexure as
Annexure-L)
3. That after having received a complaint in the police
station, the complainant requested the police officials to •
lodge the FIR against the accused persons but FIR has not
yet been lodged despite the fact that complaint discloses
commission of cognizable offence by accused persons in
connivance and in conspiracy with each other to defraud
and cheat the complainant. Instead the 10 Inspector Sher
Singh verbally asked the complainant to provide further
evidence and documents that the email id's used by AV for
sending the forged bank documents were indeed his as
well as the original Bank Statements to establish those
attached to the email by AV were indeed forged. The
complainant's plea that this was a matter to be
established by E.O Wing after registration of the FIR fell
on deaf ears of the 10.
4. It is submitted that the officers of the Economic Offences
Wing Delhi Police as well as the CBI, are duty bound to
register an FIR and start investigation as per the law
...
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"7
deClared by the Hon'hIe Apex Court and Delhi High Court
in the following landmark cases, viz.
1. Ramesh Kumari Vs. State (NCT of Delhi) & Ors.
2006 (2) SCC 677
11. State of Haryana Vs Bhajan Lal
1992 Supp (1) SCC 335
iii. Kuldeep Singh Vs. State •
1994 (54) DLT 380
iv. Priya Gupta Vs. State
2007 (5) AD (Delhi) 707
(Enclosed herewith the copies of the judgments relied
upon and are marked as Annexure-M (colly)
5. In backdrop of the above given legal position, the
Authorities are duty bound to register the FIR in view of
the specific individual role played by the accused. However
due to the long delay in the D�lhi Police not registering an
FIR in November 2011 or seizing the Documentary
evidence from GTT, GIPL and RBS Bank, the complaint
made to them by Corewip seems to have been taken over•
by the CBI which has now seized this very evidence in
June 2012 after raiding 10 establishments of AV & his
associates. This evidence continues to remain in the sole
custody of the CBr and the Delhi Police now have
. themselves requested the CEI to take over the
investigation given the fact that all the evidence already
lies in the sole custody of the Agency and is a part of the
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several ongoing International Investigations of CBI against
AV and his associates.
6. It has now come to the Complainant's notice that this was •
not simple case of Fraud but that the proceeds. of this
Fraud had been used to bribe Govt. officials, sell state
secrets internationally which would hence come under
the purview of the CEI because of lntemational
Ramifications and not the Delhi police. The complainant
has now been told by EA that in March 2012, EA had
brought to the notice of the US Tax Authorities and the
FBI, that he had discovered large scale FCPA (Foreign
Corruption Prevention Act) violations in the business of
GIPL and other subsidiaries of Ganton Limited USA which
he was administering on behalf of AV. This evidence was
forwarded by the FBI and by other Indian authorities like
CVC (Central Vigilance Commission) to whom EA had also
written to, to the CBl. The CBI & ED (Enforcement
Directorate) after studying the evidence registered 5 cases
against AV, AN & Others. The details of the cases are as
follows
.. ;.:
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a. Case under PC Act against RAD (Rheinmetall Air
Defence), AV, AN & Others for bribing Officials to
avoid RAD being blacklisted by MOD.
b. Case under PMLA wherein AV & AN laundered
proceeds of crime received from.,RAD via Ganton
USA Limited using foreign debit cards in India and
via transfers to GIPL whose Managing Director was •
AN. It were these very same debit cards which were
used to purchase the domain names linked to the
id's used by AV & AN to defraud GTI in the present
case and this evidence is in the sole custody of the
CBI.
c. Case under OS Act against AV, AN & Others for
selling Defence Secrets to foreign Nationals and
companies.
d. Case for forging a letter of Minister A Maken for
extension of vis!;'l's for employees of ZTE.
e. Case for forging a letter of CBI Officials giving him a
clean chit in the Scorpene case.
7. It is submitted that AV, who has a notorious past of being
a. fraud and a cheat and is involved in the Scorpene Case
and the Naval War Room, leak case, is running a huge
international financial fraud syndicate. He is also an
accused in several criminal cases in addition to the above.
The instant fraud has been committed by AV while out on
bail and has misused and abused the liberty granted to
',"
him by the Court. He along with his. associates named
above dishonestly induced the complainant to make an
investment of US $ 1.1 million (Approximately Rs. 5
crores) in a JVC called GTT. Thereafter using fake email •
ids, AV corresponded with the Complainant, and kept
consistently sending forged 'bank statements to induce the
Complainant to believe that their investment is safe in
GTT bank account. However, contrary to what was
represented to the Complainant, money was fraudulently
withdrawn from the GTT's bank account by AV and his
associates named above without the consent and
knowledge of the Complainant. The entire investment of
US $ 1.1 million (Approximately Rupees 5 crores) made by
the complainant has been squandered by AV and his
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associates for their personal gratification. The accused
have entered into criminal conspiracy in order to cheat the
complainant.
8. In all the cases presently being investigated by the CBI &
ED it was found that the criminal activities were carried
out with the full connivance of AN, AV's live in partner and
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the Managing Director of GIPL. The role of SK & AN
colluding with AV is well exposed by the fact that GTT
funds were illegally used to hire a farmhouse in the name
of GTT but was exclusively used as a residence of AV &
AN, even when they claim they had nothing to do With the
affairs of GTT.
9. As part of the well-plotted strategy to defraud the
complainant, RPS and Mr. Jitendar Garg were made
signatories to the bank account of GTT although they had
no business tie-up with or equity particiwation in GTT.
RPS and Mr. Jitendar Garg have conspired and helped AV
and the others named above to illegally withdraw US $1.1
million invested by the complainant for their personal gain
and to defraud a foreign investor who came to India to do
business.
8. . That the Royal Bank of Scotland, through its relationship
manager, Mr. Dinesh Khurana despite being aware of the
fact that HY of Corewip Ltd. was to be a signatory
returned the signature form of HY to AV and RPS at their
behest and allowed them tp withdraw the entire amount of
USD 1.1 million from the account. Despite bringing the
fraud to light, pursuant to several meetings, the Royal
"
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Bank of Scotland have deliberately refused to cooperate
with the Complainant; despite-the clear evidence on record
that HY and JR were the directors, of GTT. EA has
"."
confirmed he has rendered evidence to the CBI Team
which contains email exchang'es between AV & Dinesh
Khurana to show that the two were close accomplices and
this evidence is in the sole custody of the CBI who has •
directed him not to share the same with any other
Investigative Agency. He has agreed to collate this
evidence once again if he gets a formal request from the
CBI to do so.
9, It is clear from the facts stated above that AV and others
in connivance and collusion with each other have
conspired with each other and committed forgery and
have used the forged documents for the purpose of
cheating the complainant to fulfill their evil designs'
individually and/ or collectively. It is also clear from email
dated Tuesday January 12, 2012 titled Re: GT Corporate
sent by AV that he had agreed that money will be spent on
50/50 basis and that if more than US $ 5000.00 has to be
withdrawn from the bank one signature on the cheque will
be his nominee and the other will be that the complainant
(Pg 39 of Annexure-A). Further Email dated Sunday,
January 24, 2010 titled Side letter signed by JR, sent by
:.;
AV showed that AV himself signed the letter in which he
admitted that GTT is his Joint Venture with the
complainant (Pg 40-41 of Annexure-A).
(a) Email dated Tuesday, February 09;2010 titled: Fw:
statement of GTT, sent by AV, whlch has as an
attachment to the GTT, ABN Amro Bank statement for the
period December 01,2009 to Jan. 31, 2010. This is forge
GIPL on January 04,2010 into the GTT account (Pg 42-4
statement as no deposit of INR 18 lakhs was made b
of Annexure-A).
(b) CTC copy of Email dated Tue, June
RE" Homeland Defence, written by AV using the email i
[email protected] wherein he invited a forei
Defence company to tie up with this company Ganto
Limited USA (Pg 12-14 of Annexure-A).
(c) CTC copy of Email dated, Wed, 13 April, 2011, title
Fwd: Past due payment confirmation, written by AV to h'
associates Anca Neacsu & Ravi Chauhan regarding h
Paypal account. Furthermore Yahoo website wrote back
him on this email andaddressedhimasAV.This prov
beyond any doubt that AV used the email 1
[email protected], This email also reveals that
... ;
oWns the yahoo domain [email protected]
(Pg 23-28 of Annexure-A)
(d) CTC copy of Email dated 26 Feb 2010 titled FW First
Draft of Business plan of GTT, wherein Av used the email
id [email protected] to address all on the business plan
produced by the consultant Prakash Idnani (Mob.
+9198200887960) (Pg 29-34 of Annexure-A). •
(e) Abbreviated copy of the lease agreement dated 15th
February, 2010 (only three pages of the 11 pages of the
,
lease agreement of the farm house known as Gupta Farm
House where AV and his partner in crime AN are staying,
signed fraudulently by CEO GTT SK, without informing
the complainant. This shows that SK who was introduced
to the complainant as a professional executive was all
along with AV in the conspiracy to defraud the
complainant (Pg 35-37 of Annexure-A).
(f) Email dated: Thursday, February 18,2010 titled FW
Our account with your bank wherein AV replies using the
email id [email protected] to complainant's earlier email
addressed to him asking the complainant to forward the
details of the Swift sent regarding half of the share capital.
." ... _.----_..... -......-� ..---'-----------
This further confirms that Mr. AV used the above i.d (Pg
38, 45-46 of Annexure-A).
(g) Email dated: Friday, February 26, 2010 titled
FW:DD and Deposit slip of Rs. 2.50 Crore-26th February,
2010 wherein using the email [email protected] sent
a fake bankers cheque of INR 2.5 crores and a bank
deposit slip showing that the same had been deposited in •
the account of GTT as share capital on behalf of GIPL (Pg
47-49 of Annexure-A). To make it authentic, AV made it
CC to his escrow agent EA, who actually had no access to
the GIPL Account. The Managing Director of GIPL was
AV's life partner AN and later complainant learnt that the
authorized signatory was RPS and Ravi Chauhan among
others whereas only one signatory should have been from
GIPL and other should have been from Corewip or
complainant/ s nominee.
(h) Email dated Tuesday, March 02,2010 titled FW
Second deposits of Rs. 25 million (Rs. 2.5 crores) today by
Ganton India-2nd March, 2010, wherein once again AV
forwarded to the complainant forged bankers and bank
deposit slips showing GIPL had deposited a further INR
2.5 crores as its share capital in. GTT (Pg 50-54 of
Annexure-A)
(i) Email dated Wednesday, March, 03, 2010, titled :
Upkeep of shareholding in QT, wherein AV claimed his
company GIPL had deposited his side of the share of INR 5
crores whereas there was US $ 100,718.00 due from the
complainant. This clearly shows that all along AV was
planning to defraud the complainant (Pg 55 of Annexure-
A). •
(j) Email dated, Wednesday, March, 24, 2010 titled:
STATEMENT OF BANK ACCOUNT 1st February, 2010 to
22 March 2010 wherein AV sent the Complainant a forged
bank statement of the GTT account held with ABN Amro
(Pg 56-57 of Annexure-A).
10. It is pertinent to mention that EA, escrow agent of AV for,
11 years at New York, has provided the complainant some
evidence to show AV and others were directly involved in
defrauding the complainant. The evidence provided by EA,
who also ran Ganton' USA on behalf of AV of which GIPL is
a 100% subsidiary, is as follows:-
a. CTC COPY OF Email dated: Sun, 17 Jan 2010,
titled Re: re: ISP License, written by the head of
C&C Associates RC who is representing him in
his personal criminal cases and was also the
lawyer for GTT to AV's email id
[email protected]. This proves that AV used this
, :I Ilf
17
email to conduct the affairs of GTI (Pg 7-11 of
Annexure-A).
11. It is stated that AV and his accomplices forged outward
remittance advice to the tune of US $ 300,000.00 �N Amro
(renamed as RBS Bank) to show that GTI had remitted the said
Amount to the TCM Mobile LLC as per their agreement dated
15th December, 2009. This cannot be possible without the
complicity of officers of ABN Amro. The following evidence is
submitted in this regard.
•
(i) Email dated: Wednesday, February 24,2010 titled FW:
Outward Remittance, wherein now using the email id
[email protected] (the very same email id which AV
used to correspond with his lawyer as AV) and sent the
complainant forms to sign to allow the GTI account to
be debited to remit the money to TCM. AV did this
deliberately to keep up the pretence since the
complainant was one of the legal joint signatories of the
account and the other would be AV's nominee and
since for all amounts more than US $ 500,00 both
signatories were supposed to sign as agreed earlier (Pg
58-60 of Annexure-A).
(ii) Email dated: Wednesday, Monday 15, 2010, titled Re:
Uni for gt, wherein this time using the email id
.:.",
[email protected] confirmed to the
complainant that US $.3.00,000.00 was going to be
wired by ABN Amro Bank. This conclusively proves
that not only AV directly controlled OTT but Was also
the mastermind of the scam (Pg 61-62.of Annexure-A).
(iii) Email dated Thursday March 18, 2010 titled RE :
•
Remittance, wherein now usmg the email id
[email protected], AV forwarded the complainant a
communication from Dinesh Khurana, the relationship
Manager of 011. (and his various other proxy
companies) at the bank confirming the remittance was
being made (Pg 63-64 of Annexure-A).
(iv) Email dated Friday, March, 26, 2010 titled Bank
. transaction document wherein now using the email id.
[email protected], AV sent the complainant a forged
debit advice dated 25.03.2010 of ABN Amro showing
US $ 300,000.00, showing that the said amount had
been debited from OTT account for as a remittance to
TCM(Pg 65-66 of Annexure-A).
(v) Email dated Friday April 25, 2010 titled: Statement,
wherein used the email idnow AV
[email protected] and sent a forged
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bank statement of RBS Bank (formerly called ABN
Amro Bank until 30 March, 2010) for the period 01
April, 2010 to 21 April, 2010 (Pg 67-68 of Annexure-A).
The forged bank statement was 'to convince the
complainant that AV had indeed rem:itted the money
but due to banking reasons the same was returned
back to the account due to no fault of his. The CBI has •
obtained full evidence of AV using this email id and the
domain name www.intercompanymail.com was owned
by AN, on their recent Visit to NY while investigating an
OSA case against AV & AN in which both have been
charge sheeted and are in judicial custody.
Furthermore they have requested EA not to share this
evidence with any other investigation agency.
12, Another criminal act committed by AV and his associates
was in duping the complainant by passing a board resolution'
making HY as one of the Joint Signatory of the GTT on behalf of
Corewip for withdrawal of amounts more than US $ 5,000.00
and then failing to deposit the bank documents signed by him
and handed over to RPS at the RBS Bank. This criminal
conduct is further exposed by the fact that the GTT account was
a joint signatory account and with one signatory being from
Corewip and the other from GIPL. This fraud could not have
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been committed without the connivance of SK, the CEO of GTI
& Dinesh Khurana the relationship Manager at RBS.
ii) Email dated April 21, 2010: 9.5TAM titled Joseph
Rubinstein/Hashim Yashar arrival in Delhi
wherein AV using the email id
[email protected], sent the
•
complainant a string of messages and tried to act
confused as to why HY was not the joint signatory
to the account and in the background of the email
chain above suddenly both RPS and Dinesh
Khurana of RBS (FORMERLY CALLED ABN
AMRO Bank) mysteriously switched off their
mobiles and .were unavailable when the associate
of the complainant visited the bank and the bank
managers became uncommunicative. The bank
junior manageress (who was probably coerced by
Dinesh Khurana) checked the records and
informed the associate of the complainant that
two long time employees of AV i.e. R.P. Singh and
Jitendra Garg (spelled wrongly) are the authorized
signatories of the account and there is no
mention of HY in the bank records. It is obvious
this could not have happened without RPS and
Dinesh Khurana colluding together to help AV
ltl
given the strict standards of KYC (Know Your
Client) Rules that bapks like RBS follows. Mr.
Dinesh Khurana grossly neglected his fmancial
duties by providing AV illegal access to the Bank
records even though AVon paper has nothing to, .
with GIPL or GTT (Pg 72-79 of Annexure-A) .
iii) AV also boasted that on 215t April, 20 lO he was. •
attending a rally with Varun Gandhi.
iv) The forging of board resolution authorizing first
J.Garg and RPS to be the authorized signatories
and later Ravi Chauhan and AN to be the
authorized signatories of the GTT, when none of
them were authorized by the complainant to
::"..
represent Corewip, also proves that all along AV
colluded to defraud the complainant with his
various changing associates. This scam by AV
which can only be unearthed / SOlved, if the CBl
contacts all the accused who. are already well
known to them at the earliest and investigates the
matter properly without being influenced by the
big names involved.
13. After claiming to be unable to repay the complainant for
its investments in the share capital in GTT from India, AV sent
forged documents from the Aubar Trust (which AV claimed was
owned by him and having an account with LGT Bank located in
Liechtenstein), stating that money had been sent to the
complainant which shows that AV was/is a serial
fraud/conman and forger of International fimmciaI documents
amongst others. The below evidence is submitted in this regard:
i) Email dated April 15, 2010 10.58 AM, titled FW:
SWIFT AMENDMENT wherein AV states that George
Keiber who runs his Aubar Trust and whose
accounts are with LGT Bank in Liechtenstein
advising the payment was made. (Pg 80-82 of
Annexure-A).
ii) Email dated April 19, 20104.39 AM, titled RE: Wire
wherein he furnishes a fake bank transfer document
from LGT Bank stating they had transferred Euro
696.300 (Pg 83-84 of Annexure-A).
14. It is respectfully submitted that the accused persons have
deceived the complainant fraudulently and dishonestly and
. have induced the complainant to part with .. the sum of Rs. 5
crores which the complainant would not have done had he not
been deceived. Complainant wa� also intentionally deceived and
led to believe that the transaction entered were genuine
transaction entered with AV by the complainant. AV had further
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committed forgery by making false documents in connivance
with its accomplice in crime ,and bank officials with the intent to
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commit fraud and forgery and cheat the complainant and have
used forged documents as genuine. AV and his accomplices
have entered into a criminal conspir.acy by agreeing to do an
unlawful and illegal act by illegal means. Thus the offence
under Sections 415, 420, 463, 464, 467, 468, 470, 471 read •
with Section 120-B is clearly IItade out. It is pertinent to
mention that AV and his wife cum live in partner AN have
criminal record/history and are regularly in and out of jail. The
money defrauded from innocent and law abiding persons are
used to finance their lavish and extravagant life style in
connivance with self serving politicians and government
officials/bureaucrats who regularly visit AV's farmhouse.
15. It is submitted that AV has defrauded the complainant in
conmvance with the other accused persons. That the
Complainant has narrated all the facts and incidents as
mentioned herein below, which was duly acknowledged by the
Police. However despite this and being legally bound to register
a F.I.R. on the written Complaint filed by the Complainant, the
Delhi Police for their ulterior motive have failed to discharge its
legal duty to register a F.I.R against the accused persons, for
the reasons best known to them. The Delhi Police however now
just like Complainant also feel that his initial complaint to the
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E.O Wing of the Delhi Police can only be properly investigated
by C.B.I, given the new evidence submitted by EA to the CBI as
well as EA's confirmation that this evidence is common to the
Complainant's present case and that the money defrauded from
Corewip was used to bribe Central Govt. Officials and hence
also coming under the PC Act which is under the jurisdiction of
the CBI.
16. It is pertinent to mention that based on complaints and
, evidence supplied by EA to the CBI, ED & FBI,the CBI and ED
have registered 5 FIR's against AV, AN & others. These FIR's are
for crimes under PMLA, Fraud, Forgery, PC Act and Official
Secrets Act. These criminal acts were committed using the very
same email ids used to defraud Corewip. CBI thus raided the
offices of GIPL & the Residence of AV & AN, on 0i7.06.2012. CBI
has arrested AV & AN on 09.06.2012 who till date are in
Judicial custody. CBI also raided a relative of RPS a close
associate of AV in June, 2012 and recovered 4 trunk loads of
documentary Evidence of GTT, GIPL as well Financial and Bank
Records. These are till date in the sole custody of the CBI and
hence only CBI is in position to carryout meaningful
Investigations in the present matter. Combined CBI & ED team
lead by CBI Special Director VK Gupta and consisting of Addn
. Director R. Dutta (EOW-CBI), SP AK Chand (10 - CBI), Special
Director R. Upadhaya (ED) and Asst. Dir pK Khanna (ED) visit
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EA in NY and recorded his statement and collected
documentary evidence as well cyber.forensic evidence consisting
of emailsetc.This evidence collected by them is common to this
case too and now is in the sole custody of the CBI. The CBI
team also met Jeffery Kirsch from CorewipjTCM and directed
him to write a fresh complaint to them which he duly did. EA
also conveyed that he is unable to travel to India and hence .•
Delhi Police would have to either travel to USA to collect the
evidence but only after EA gets approval from the CBI to render
the same. It would be in the interest of justice to direct the CBI
to further investigate the matter and lodge an FIR to unearth
the fra�d. It is submitted that CBI should be entrusted with the
investigation because of international ramifications. Moreover,
CBI has collected substantial evidence against the accused
which it might not like to share with Delhi Police because of the
sensitive nature of the case.
17. EA further submits in an email dated 22.01.2013 to the
Complainant which is copy to the CBI (Enclosed herewith as
Annexure-N) that he has handed over more than 3000 emails
and documents to the CBI Team which visited him in NY and is
ready to help CBI in its investigation in this matter too but not
the Delhi Policeas:
.;�,--------�..:
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------------_.__._._ _---------_•.. _-----_._ .. _ .. -
a. The funds misappropriated from GTI were used to gift
serving Politicians items like Cars (Ene!. 2 of Annexure-
N).
b. The funds misappropriated from GTT were used to
entertain as well as bribe serving MOD and Army officers
to lobby for Defence Deals at the very farmhouse rented .•
illegally in the name of GTT (Ene!. 3 of Annexure- N).
_--_0
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c. AV fraudulently hired a senior Air Marshal Masand (Retd.)
(hereinafter referred to as HM for short), ,as a Director of
GTT whereas he was in reality working for a foreign Arms
Company to enable him and AV to get this company a
contract with the Indian Air Force. EA has provided
photographic evidence which shows AV and HM,
entertaining serving Air Force officers. with foreign
prostitutes in the very farmhouse rented illegally by SK on
behalf of GTT. This is a matter of Nation Security and
must be investigated by the car only (Encl. 4 of Annexure-
d. AV has sent EA several emails in which he claimed as well
as provided him documents to show that he is close to
\1!�ral top Police officers of the Delhi Police, who may
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impede a full and free investigation into this matter and
hence the same should be inve.stigated by CBI only (Enc!.
6 of Annexure- N).
e. AV sent EA emails and photos of AN attending 'private
clandestine dinner with senior MHA (Ministry of Home
Affairs) Officials for sales of Arms to MHA. The emails talk
of FCPA Violations and hence come under PC Act of India
as well as Official Secrets Act Violations and must be
investigated by the CBI only. This is more so because
Delhi Poli,ce comes directly under the Ministry of Home
Affairs (Enc!. 7 of Annexure- N).
�.. - ------.. . -.------
very same id's used to perpetrate the very crimes being
presently investigated by the CBI for which they had
visited New York to collect this evidence. Furthermore a
part of the misappropriated funds were sent by Hawala to
a company called Kamal Exchange UK from where it was
wired to Ganton Limited USA a benami company of AV.
(Enc!. 5 of Annexure- N).
18. That the Delhi Police vide letter dated 5.2.2013 which was
received by the complainant on 22.02.2013 in the evening
specifically states that the CBI should investigate the matter
since all the evidence is already with the CBI.(Enclosed as
Annexure-O )
19. That the Spl. CEl Judge, Central Delhi vide order dt.
18.02.2013 was pleased to direct SP (CBl) to investigate the
matter titled R.K. Yadav Vs. A.K. Verma. Atrue copy of the
order dated 18.2.2013 of the Spl. CBI Judge, Central Delhi
•
alongwith Paper cutting dated 20.02.2013 is annexed herewith
and the same is marked as ANNEXURE-P.
20. That the complaint was filed by the complainant before
the CBI Court, Tis Hazari Court, on 22.02.2013. The Hon'ble
Court, after hearing arguments, on behalf of the Advocate for
the. Complainant directed that the complainant should
withdraw the complaint in view of the fact that the Hon'ble
Court does not have jurisdiction to issue direction to CBl to
investigate the matter.
21. That it is most respectfully. submitted that due to the
subsequent developments i.e. Delhi Police letter to CBI dt
5.2.13, which was received by complainant on 22.02.13 in the
evening and also order dt.18.02.2013 passed by Spl. Judge,
CBI, Central Delhi, this Hon'ble Court may be pleased to direct
CBl to investigate the matter as the Delhi Police has already
indicated the same to the CBI.
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22. Thus, in view of the aforesaid it is submitted that the case
in hand is clearly a case of forgery, inducement, using forged
documents as genuine to part with money, criminal conspiracy,
cheating, and FIR must be registered in the aforesaid matter in
order to meet out the end of justice. Furthermore the proceeds
of this crime were used to bribe MHA, MOD .. officials, which
make it a matter under the purview of the PC Act. It is also seen .
that the team which collected the evidence from EA also had
Special Director RK Dutta who heads the EO Wing of CBl.
Chapter 4 of the CBI Cri�e Manual IEnclosed herewith as
Annexure-Q) shows that CBI can investigate Arms Dealers like
AV when they commit Banking Frauds which have International
and National Security Implications as in this case.
23. That the present application is being made bonafidely and
in the interest ofjustice by the complainant.
24. In View of the facts and circumstances stated above, it
would be in the interest of justice, equity and fair play that this
Hon'ble Court directs the E.O Wing of theCBIto take over the
investigation in this case and register a case of cognizable
I.
crimes under Indian Penal Code, Sections 415- cheating Section
,420, Section 464, 465, 467 Forgery, Sec-468-Forgery for the
purpose of cheating, Section 470, 471- Using a forged
document as genuine, Section 120-B -conspiracy to commit the
\,
above cnmes as well as under the relevant sections of
Prevention of Corruption Act ,and Information Technology Act
and to register an FIR immediately against Abhishek Verma,
Anca Neacsu, Sanjiv Kapoor, RP Singh, Dinesh Khurana of
RBS, Ravi Chauhan and other unknow!1 persons in the cause
title, The complicity of other persons can only be known after
proper investigation is carried out.
PRAYER
It is, therefore, most respectfully prayed that this Hon'ble
Court may be pleased to:
(a) Issue the direction to the Economic Offence Wing of the
Central Bureau of Investigation through its Director to
register an F.LR. under Sections 415, 420, 464,
465,467,468,470,471 & 120-B of I.P.C. and or any other
relevant provisions of law under PC Act and IT Act 2001 to
meet the ends of justice.
(b) Issue Directions to the E.O Wing of the CBI through its
Director to direct their source of information Le. EA, in the
5 cases already under investigation by them for which
they have registered FIR's, to collate and provide evidence
in this matter too as agreed by EA via his email dated 22
January 2013.
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((j Pass such other and further order as this Hon'ble Court
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may deem fit and proper in the facts and circumstances of
the present case.
. :r�PLMNANTThrough : (lV;:",��
(H�J;��J lAdvocate for the CampI . ant
NEW DELHI:
DATED: 05.03.2013
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:';. • 52
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IN THE COURT OF SPECIAL JUDGE CBI COURT, PATIALA
HOUSE COURTS, NEW DELHI.
COMPLAINT NO /2013
IN THE MATTER OF :
Mis Corewip Cyprus
Versus
Mr. Abhishek Verma & Ors.
......... Complainant
..... Accused
AFFIDAVIT
I, Vikki Choudhry, son of Shri Raghuraj Singh aged About
44 years, resident of B-I0, 3rd Floor, Friends Colony (West ),
New Delhi- 110 065 do hereby solemnly affIrm and state as
under:-
1. That I am the authorized SignatoryIRepresentative of the
Complainant and being conversant with the facts and
circumstances of the case, competent to swear this affIdavit.
2, That I have read and understood the contents of the
accompanying Complaint for registration of FIR and the same
are true and correct to the best of my knowledge and belief.
3. That the annexures filed herewith are the true copies of
their respective originals.
�DEPO�ENT.
VERIFICATION:
Verified at New Delhi on this the 05th day of March, 2013
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 or has
been concealed therefrom.
WDEPONENT.
