IN THE COURT OF LD.

MM,____________

CRIMINAL COMPLAINT NO ______2021

IN THE MATTER OF:

ITPL INFRASTRUCTURES PRIVATE LIMITED COMPLAINANT

V/S

M/S SHANTI ASSOCIATES & Anr. ACCUSED

PS:_________

INDEX

Sl. No Particulars Page No

1. Index

2. Opening Sheet for Section 138 case

containing details in brief.

3. Memo of Parties
4. Complaint under section 138 of Negotiable
Instrument Act with list of witness and list
of documents.

5. List of witnesses along with list of

documents.

6. ORIGINAL Power of Attorney in favour of

authorized representative of Complaint.
7 Tax Invoices and E-Way Bills
8. ORIGINAL ledger account of the accused
as maintained in the books of account of
complainant.

9. Original cheque bearing No 6058885

dated 17.03.2021 issued by accused to
complainant company.
10. Original returning memo dated
 17.05.2021 for cheque bearing no.
000495.

11. Original Bank Statement of complainant

bank account evidencing dishonor of
cheque on dated

12. Original legal notice dated 07.06.2021

sent by complainant company to accused.

13. Original speed post receipts for sending

legal notice dated 07.06.2021 to accused
persons along with delivery report.

14. Original 65 B certificate under Indian

Evidence Act.

15. Vakalatnama

Through Counsel

__________________________________
(Praveen Mahajan, Advocate D/3225/A/1999)
Equi Law Partners, Advocates & Legal Consultants
Duplex No 200, Ashirwad Apartments,
Plot No 99, IP Extn, Patparganj, Delhi-92
Mob 09810620827
Email: [email protected]

Date:

Place:
 IN THE COURT OF LD. MM,____________

CRIMINAL COMPLAINT NO ______2021

IN THE MATTER OF:

ITPL INFRASTRUCTURES PRIVATE LIMITED COMPLAINANT

V/S

M/S SHANTI ASSOCIATES & Anr. ACCUSED

OPENING SHEET IN SECTION 138 OF NI ACT

SL. No. Particulars Details
1 Name and Address ITPL INFRASTRUCTURES
of Complainant PRIVATE LIMITED

516 Asian Games Village

Complex, New Delhi, 110049
2 Name and address 1. Vimal Bajaj
of Accused C/O Shanti Associates,
313P/1P, Harminder Public
School, Trikuta Nagar,
Jammu and Kashmir-
180004
2. Chirag Dogra,
S/O Surjeet Dogra,
C/O Shanti Associates,
Plot No 54, Ward No. 3B,
Behind PWD Guest House,
Adipur, Gandhi Dham,
Kachchh, Gujarat, 370205
3. Surjeet Kamallal Dogra
S/O Surjeet Dogra,
C/O Shanti Associates,
Plot No 54, Ward No. 3B,
Behind PWD Guest House,
Adipur, Gandhi Dham,
Kachchh, Gujarat, 370205
4. M/S Shanti Associates
313P/1P, Harminder Public
School, Trikuta Nagar,
Jammu and Kashmir-
180004
3 Name of Police
 Station

4 Total Cheque Amount Rs.10,00,000 /-

5 Details regarding NA
any other cases U/s
138 NI Act
pending against
same accused (s)

A) Name of the NA
Court(s) where such
case is pending

B) Complaint case NA
number

C) Next of hearing NA
before such Court(s)

6 Name of the drawer ICICI Bank, New Friends Colony,

bank, its location New Delhi

7 Name of the drawee J&K Bank, I/C Bari Brahamna,

bank, its location Jammu And Kashmir.

8 Cheque No. /Nos. Cheque bearing No 605885 dated

17.03.2021 of amount Rs.
10,00,000/-

9 Signatory of Vimal Bajaj

the cheque/cheques

Reasons due to which

10 the cheque/cheques Funds INSUFFICIENT
were dishonored;

11 Name of the persons 1. Vimal Bajaj

sought to be liable 2. Chirag Dogra,
for commission of the 3. Surjeet Kamallal Dogra
offence. 4. M/S Shanti Associates

12 Particulars of the Legal Notice dated

 legal notice and 07/06/2021 duly served to
status accused No. 1 as per the
of its service; exhibited postal receipt.

The notice was served at

the ADIPUR, GUJARAT
Address of the accused and
the same was delivered on
10.06.2021 as per the
delivery report of the postal
department.

13 Particulars of reply to No Reply despite receipt of

the legal notice, if Notice.
any.

Through Counsel

__________________________________
(Praveen Mahajan, Advocate D/3225/A/1999)
Equi Law Partners, Advocates & Legal Consultants
Duplex No 200, Ashirwad Apartments,
Plot No 99, IP Extn, Patparganj, Delhi-92
Mob 09810620827
Email: [email protected]
Place: Delhi
Date:
 IN THE COURT OF _____

CRIMINAL COMPLAINT NO ______2021

Memo Of Parties

IN THE MATTER OF:

ITPL INFRASTRUCTURES PRIVATE LIMITED

Through its Authorized Representative
516 Asian Games Village Complex,
New Delhi, 110049 COMPLAINANT

V/S

1. Vimal Bajaj
C/O Shanti Associates,
313P/1P, Harminder Public School,
Trikuta Nagar, Jammu and Kashmir.
180004. ACCUSED No. 1

2. Chirag Dogra,
S/O Surjeet Dogra,

C/O Shanti Associates,

Plot No 54, Ward No. 3B,
Behind PWD Guest House,
Adipur, Gandhi Dham, Kachchh,
Gujarat, 370205 ACCUSED NO. 2

3. Surjeet Kamallal Dogra

S/O Surjeet Dogra,
C/O Shanti Associates,
Plot No 54, Ward No. 3B,
Behind PWD Guest House,
Adipur, Gandhi Dham, Kachchh,
Gujarat, 370205. ACCUSED NO. 3
4. M/S Shanti Associates
313P/1P, Harminder Public School,
Trikuta Nagar, Jammu and Kashmir
180004 ACCUSED NO. 4

PS: HAZARAT NIZAMUDIN

Through Counsel

__________________________________
(Praveen Mahajan, Advocate D/3225/A/1999)
Equi Law Partners, Advocates & Legal Consultants
Duplex No 200, Ashirwad Apartments,
Plot No 99, IP Extn, Patparganj, Delhi-92
Mob 09810620827
Email: [email protected]
Place: Delhi
Date:
 IN THE COURT OF _____

CRIMINAL COMPLAINT NO ______2021

IN THE MATTER OF:

ITPL INFRASTRUCTURES PRIVATE LIMITED

Through its Authorized Representative
516 Asian Games Village Complex,
New Delhi, 110049 COMPLAINANT

V/S

5. Vimal Bajaj
C/O Shanti Associates,
313P/1P, Harminder Public School,
Trikuta Nagar, Jammu and Kashmir.
180004. ACCUSED No. 1

6. Chirag Dogra,
S/O Surjeet Dogra,

C/O Shanti Associates,

Plot No 54, Ward No. 3B,
Behind PWD Guest House,
Adipur, Gandhi Dham, Kachchh,
Gujarat, 370205 ACCUSED NO. 2

7. Surjeet Kamallal Dogra

S/O Surjeet Dogra,
C/O Shanti Associates,
Plot No 54, Ward No. 3B,
Behind PWD Guest House,
Adipur, Gandhi Dham, Kachchh,
Gujarat, 370205. ACCUSED NO. 3
8. M/S Shanti Associates
313P/1P, Harminder Public School,
Trikuta Nagar, Jammu and Kashmir
180004 ACCUSED NO. 4

PS: ___________

COMPLAINT UNDER SECTION 138 OF THE NEGOTIABLE

INSTRUMENTS ACT, 1881.

MOST RESPECTFULLY SHOWETH:-

The Complainant most Respectfully submits as under:-
1. That, the signatory of present complaint is Authorized

Representative of Complainant who is at presently working

with complainant for gain and fully conversant with facts of

the complaint. The said Authorized Representative is duly

authorized by the Complainant to file and institute the criminal

complaint for and behalf of the Complainant by way of Special

Power of Attorney executed by the complainant. Therefore,

the Authorized Representative is competent person to file and

prosecute the present complaint and lead the evidence in the

case and to perform all such action as may be necessary for

the due prosecution of the case for and on behalf of the

Complainant.

2. That ITPL Infrastructures Private Limited (hereinafter referred

to as "Complainant") is a private company undertaking the

business of building complete constructions and parts thereof

 and also in supplying raw materials used in the construction

business.

3. That, The Accused No. 4 (M/s Shanti Associates) is the

assumed business name identity of Accused No 1 to 3 thus

the said business identity while acting through Accused

Persons No 1 to 3 represented to the complainant that the

Accused No 4 ((M/s Shanti Associates) is the joint business of

aforesaid Accused No 1 to 3 and through said Accused No 4

the Accused Persons No 1 to 3 are engaged in business of

buying bitumen for their business purposes and whereas

Accused Persons No 1 to 3 have represented themselves to be

person who are in actual control of the business of Accused No

4, hereinafter jointly referred to as "Accused Persons" in

present complaint.

4. That the aforesaid Accused Persons contacted the complainant

and showed their interest to enter into a business transaction

with the complainant for purchasing BITUMEN, which is used

for the construction purposes (hereinafter referred to as "said

Goods") and further instructed the complainant from time to

time to supply the said goods. That the said instructions of

supply issued by the Accused Persons were duly accepted by

the complainant and therefore the complainant raised the

 invoices bearing number 2020-21/262 for the total

consideration of Rupees 10,45,131/- (Rupees Ten Lacs Forty-

Five Thousand, One Hundred and Thirty-One only) and 2020-

21/263 for the total consideration of Rupees 10,79,869/-dated

07.02.2021 and the "said Goods" were delivered to the

designated place within the stipulated time and receipt

whereof was duly acknowledged and admitted by the Accused

Persons herein. That as per the instructions of the Accused

Persons, the complainant had supplied the goods under

earnest believe and understanding that payment in respect of

said goods shall be made by the Accused Persons on the

respective due dates.

5. That the Complainant further states that a running ledger

account is maintained between the Complainant and the

Accused Persons, which reflects that the Complainant raised

the above mentioned Invoices on 07.02.2021. That after

adjusting the part payments amounting to Rs 3,50,000/-

(Rupees Three Lacs Fifty Thousand only) and Rs 1,00,000/- an

amount of Rs 16,75,000/- (Rs Sixteen Lac Seventy-Five

Thousand Only) is still pending and outstanding.

6. That, in view of above said outstanding dues and in part

discharge of legally payable debt arising out of supplies of the

 said goods made by the Complainant, the Accused Persons

issued the Cheque bearing number 6058885 dated 17.03.2021

amounting Rs 10,00,000/- (Rupees Ten Lac only) (hereinafter

referred to as the "said Cheque") towards the part payment.

7. That the said cheque drawn in favor of the Complainant for the

part payment of aforesaid legally payable debt on assurance

that same would be honored on presentation, accordingly said

cheque was duly presented by the Complainant to their

bankers i,e., ICICI Bank, New Delhi for encashment, but to the

utter surprise and dismay of my client said cheques was

dishonored for the reasons "INSUFFICIENT FUNDS" vide

returning memo dated 17/05/2021.

8. That, the Accused Persons being the actual persons behind the

ownership, control and day to day management of the Accused

No. 4 and are also the persons who are responsible for

managing day to day affairs of the Accused No. 4 and further

Accused No 1 to 3 being the person responsible for day to day

affairs of business of Accused No. 4 and are the persons who

are in charge of, and are responsible to the Accused No. 4 for

the conduct of the business of the Accused No. 4, and also the

persons who are directly instrumental in entering into said

agreement for supply of the said goods and also for issuing
 aforesaid cheque to the Complainant thus the aforesaid

Accused No. 1 to 4 have mischievously, intentionally,

deliberately and malafidely issued aforesaid Cheque and

further instructed the Complainant to present the same for

encashment knowing full well that said cheque on presentation

would never be honored.

9. The intimation of said dishonor of cheque was given to the

complainant vide returning memo as listed hereinabove for the

said cheque which ultimately referable to reasons falling within

the purview of section 138 of Negotiable Instruments Act.

10. That the Accused Persons 1 to 3 being the person directly

involved with the business activities of the Accused No. 4. Thus,

the Accused Persons have mischievously, deliberately and

malafidely issued the aforesaid cheques and further instructed

the complainant to present the same for the encashment knowing

full well that said cheque on presentation would never be

honoured.

11. That, in the manner aforesaid Accused Persons have at the

first instance have induced the complainant to deliver the said

goods on the false pretext of paying and thereafter intentionally

defaulted in honoring the aforesaid cheque and then further

 convinced the complainant to accept aforesaid cheques for the

part payment of the said amount.

12. Thus, the accused persons intentionally caused to allow to

dishonor the said cheques which was under the full knowledge of

the accused. Further the accused persons exercised no due

diligence to prevent the commission of offence, and accordingly

the accused have committed an offence by dishonoring the said

cheques. Hence the accused is liable to be prosecuted being

directly involved in the commission of offence as stated under

section 138 of The Negotiable Instruments Act.

13. That, on account of dishonor of said cheques the

complainant through its advocate, sent legal notice dated

07.06.2021 to the accused by way of Speed post under Section

138 of The Negotiable Instrument Act, 1881, calling upon the

accused to pay the amount of dishonored Cheques, within 15

days as envisaged under Negotiable Instruments Act, 1881. That,

it is pertinent to mention that notice sent through the speed post

and on the last known address of the accused which is not sent

unserved by the Postal Department hence the accused shall

deemed to be duly served, thus present complaint is filed within

 the prescribed limitation period and full compliance of the

Negotiable Instruments Act.

14. That said cheques having been dishonored and further upon

the failure of the Accused to make full payment against the

same, the Accused Persons are deemed to have committed an

offence under Section 138 of The Negotiable Instruments Act,

1881 and is liable to be punished accordingly.

15. That the said cheques had been issued by the accused

persons against the legally payable debt due towards the

Complainant and the Complainant has duly presented the said

cheques within the validity period of the cheques. The

Complainant has received the returned cheque along with bank

return memos on 17.05.2021 for said cheques and legal notice

for dishonor of the said cheque U/s 138 of the Negotiable

Instruments Act was duly sent on 07.06.2021 thus present

complaint is not time barred as per section 142(b) of the NI Act.

16. That the said cheque in question was presented for

payment and encashment at the banker of the complainant i.e.

 ICICI Bank, New Friends Colony, New Delhi, where the bank

account of the complainant is maintained, hence the cause of

action for dishonor of the aforesaid cheque has inter alia arisen

____________________________________________________

___________________________________________________

PRAYER

It is, therefore, humbly prayed that accused persons may kindly be

summoned and punished under section 138 of The Negotiable

Instrument Act, 1881 and may please be given the punishment of

imprisonment for 2 years as well as penalty of amount equivalent to

double the amount of the Cheques or such other amount as this

Hon’ble court may deem just, Further under facts and circumstances

of the case, the compensation/fine may please be directed to be

paid to the Complainant in lieu of the dishonored cheques and the

accused be tried and punished as per the provisions of law and/or to

pass any such order as may be deem fit by the Hon’ble Court in the

fact and circumstances of the case

_____________________

(For and behalf of the Complainant)

Through Counsel
___________________________________
(Praveen Mahajan, Advocate D/3225/A/1999)
 Equi Law Partners, Advocates & Legal Consultants
Duplex No 200, Ashirwad Apartments,
Flat No 99, IP Extn, Patparganj, Delhi-92
Mob 09810620827
Email: [email protected]

PLACE: DELHI
DATE:
 IN THE COURT OF ___________________

CRIMINAL COMPLAINT NO ______2021

IN THE MATTER OF:

ITPL INFRASTRUCTURES PRIVATE LIMITED COMPLAINANT

V/S

M/S SHANTI ASSOCIATES & Anr. ACCUSED

PS: ___________

LIST OF WITNESS BY THE COMPLAINANT

1. Authorized Representative of the Complainant Company.

2. Bank Officer/Accountant/employee of ICICI Bank, New Friends

Colony, New Delhi.

3. Any other witness with permission of Hon’ble Court.

Through Counsel

___________________________________
(Praveen Mahajan, Advocate D/3225/A/1999)
Equi Law Partners, Advocates & Legal Consultants
Duplex No 200, Ashirwad Apartments,
Plot No 99, IP Extn, Patparganj, Delhi-92
Mob 09810620827
Email: [email protected]
Place: Delhi
Date:
 IN THE COURT OF ___________________

CRIMINAL COMPLAINT NO ______2021

IN THE MATTER OF:

ITPL INFRASTRUCTURES PRIVATE LIMITED COMPLAINANT

V/S

M/S SHANTI ASSOCIATES & Anr. ACCUSED

PS: _____________

LIST OF DOCUMENTS OF THE COMPLAINANT

1. ORIGINAL Power of Attorney in favour of

authorized representative of Complaint.
2 Tax Invoices and E-Way Bills
3. ORIGINAL ledger account of the accused
as maintained in the books of account of
complainant.

4. Original cheque bearing No 6058885

dated 17.03.2021 issued by accused to
complainant company.
5. Original returning memo dated
17.05.2021 for cheque bearing no.
000495.

6. Original Bank Statement of complainant

bank account evidencing dishonor of
cheque on dated

7. Original legal notice dated 07.06.2021

sent by complainant company to accused.
8. Original speed post receipts for sending
legal notice dated 07.06.2021 to accused
 persons along with delivery report.

9. Original 65 B certificate under Indian

Evidence Act.

10. Vakalatnama

Through Counsel

___________________________________
(Praveen Mahajan, Advocate D/3225/A/1999)
Equi Law Partners, Advocates & Legal Consultants
Duplex No 200, Ashirwad Apartments,
Plot No 99, IP Extn, Patparganj, Delhi-92
Mob 09810620827
Email: [email protected]

Place: Delhi
Date:
 IN THE COURT OF ___________________

CRIMINAL COMPLAINT NO ______2021

IN THE MATTER OF:

ITPL INFRASTRUCTURES PRIVATE LIMITED COMPLAINANT

V/S

M/S SHANTI ASSOCIATES & Anr. ACCUSED

AFFIDAVIT OF SH. PRASHANT KUMAR NATH S/O SH. PRANAB

KUMAR NANDA, AGED ABOUT 27 YEARS WORKING AS LEGAL

HEAD IN ITPL INFRASTRUCTURES PRIVATE LIMITED HAVING

ITS OFFICE AT 516 Asian Games Village Complex, New Delhi,

110049.

I, the above named deponent, do hereby state on solemn affirmation

and declare as under:-

1. That, the signatory of present complaint is Authorized

Representative of Complainant who is at presently working

with complainant for gain and fully conversant with facts of

the complaint. The said Authorized Representative is duly

authorized by the Complainant to file and institute the criminal

complaint for and behalf of the Complainant by way of Special

Power of Attorney executed by the complainant. Therefore,

the Authorized Representative is competent person to file and

prosecute the present complaint and lead the evidence in the

 case and to perform all such action as may be necessary for

the due prosecution of the case for and on behalf of the

Complainant.

2. That ITPL Infrastructures Private Limited (hereinafter referred

to as "Complainant") is a private company undertaking the

business of building complete constructions and parts thereof

and also in supplying raw materials used in the construction

business.

3. That, The Accused No. 4 (M/s Shanti Associates) is the

assumed business name identity of Accused No 1 to 3 thus

the said business identity while acting through Accused

Persons No 1 to 3 represented to the complainant that the

Accused No 4 ((M/s Shanti Associates) is the joint business of

aforesaid Accused No 1 to 3 and through said Accused No 4

the Accused Persons No 1 to 3 are engaged in business of

buying bitumen for their business purposes and whereas

Accused Persons No 1 to 3 have represented themselves to be

person who are in actual control of the business of Accused No

4, hereinafter jointly referred to as "Accused Persons" in

present complaint.

4. That the aforesaid Accused Persons contacted the complainant

and showed their interest to enter into a business transaction

 with the complainant for purchasing BITUMEN, which is used

for the construction purposes (hereinafter referred to as "said

Goods") and further instructed the complainant from time to

time to supply the said goods. That the said instructions of

supply issued by the Accused Persons were duly accepted by

the complainant and therefore the complainant raised the

invoices bearing number 2020-21/262 for the total

consideration of Rupees 10,45,131/- (Rupees Ten Lacs Forty-

Five Thousand, One Hundred and Thirty-One only) and 2020-

21/263 for the total consideration of Rupees 10,79,869/-dated

07.02.2021 and the "said Goods" were delivered to the

designated place within the stipulated time and receipt

whereof was duly acknowledged and admitted by the Accused

Persons herein. That as per the instructions of the Accused

Persons, the complainant had supplied the goods under

earnest believe and understanding that payment in respect of

said goods shall be made by the Accused Persons on the

respective due dates.

5. That the Complainant further states that a running ledger

account is maintained between the Complainant and the

Accused Persons, which reflects that the Complainant raised

the above mentioned Invoices on 07.02.2021. That after

 adjusting the part payments amounting to Rs 3,50,000/-

(Rupees Three Lacs Fifty Thousand only) and Rs 1,00,000/- an

amount of Rs 16,75,000/- (Rs Sixteen Lac Seventy-Five

Thousand Only) is still pending and outstanding.

6. That, in view of above said outstanding dues and in part

discharge of legally payable debt arising out of supplies of the

said goods made by the Complainant, the Accused Persons

issued the Cheque bearing number 6058885 dated 17.03.2021

amounting Rs 10,00,000/- (Rupees Ten Lac only) (hereinafter

referred to as the "said Cheque") towards the part payment.

7. That the said cheque drawn in favor of the Complainant for the

part payment of aforesaid legally payable debt on assurance

that same would be honored on presentation, accordingly said

cheque was duly presented by the Complainant to their

bankers i,e., ICICI Bank, New Delhi for encashment, but to the

utter surprise and dismay of my client said cheques was

dishonored for the reasons "INSUFFICIENT FUNDS" vide

returning memo dated 17/05/2021.

8. That, the Accused Persons being the actual persons behind the

ownership, control and day to day management of the Accused

No. 4 and are also the persons who are responsible for

managing day to day affairs of the Accused No. 4 and further

 Accused No 1 to 3 being the person responsible for day to day

affairs of business of Accused No. 4 and are the persons who

are in charge of, and are responsible to the Accused No. 4 for

the conduct of the business of the Accused No. 4, and also the

persons who are directly instrumental in entering into said

agreement for supply of the said goods and also for issuing

aforesaid cheque to the Complainant thus the aforesaid

Accused No. 1 to 4 have mischievously, intentionally,

deliberately and malafidely issued aforesaid Cheque and

further instructed the Complainant to present the same for

encashment knowing full well that said cheque on presentation

would never be honored.

9. The intimation of said dishonor of cheque was given to the

complainant vide returning memo as listed hereinabove for the

said cheque which ultimately referable to reasons falling within

the purview of section 138 of Negotiable Instruments Act.

10. That the Accused Persons 1 to 3 being the person directly

involved with the business activities of the Accused No. 4. Thus,

the Accused Persons have mischievously, deliberately and

malafidely issued the aforesaid cheques and further instructed

the complainant to present the same for the encashment knowing

 full well that said cheque on presentation would never be

honoured.

11. That, in the manner aforesaid Accused Persons have at the

first instance have induced the complainant to deliver the said

goods on the false pretext of paying and thereafter intentionally

defaulted in honoring the aforesaid cheque and then further

convinced the complainant to accept aforesaid cheques for the

part payment of the said amount.

12. Thus, the accused persons intentionally caused to allow to

dishonor the said cheques which was under the full knowledge of

the accused. Further the accused persons exercised no due

diligence to prevent the commission of offence, and accordingly

the accused have committed an offence by dishonoring the said

cheques. Hence the accused is liable to be prosecuted being

directly involved in the commission of offence as stated under

section 138 of The Negotiable Instruments Act.

13. That, on account of dishonor of said cheques the

complainant through its advocate, sent legal notice dated

07.06.2021 to the accused by way of Speed post under Section

138 of The Negotiable Instrument Act, 1881, calling upon the

 accused to pay the amount of dishonored Cheques, within 15

days as envisaged under Negotiable Instruments Act, 1881. That,

it is pertinent to mention that notice sent through the speed post

and on the last known address of the accused which is not sent

unserved by the Postal Department hence the accused shall

deemed to be duly served, thus present complaint is filed within

the prescribed limitation period and full compliance of the

Negotiable Instruments Act.

14. That said cheques having been dishonored and further upon

the failure of the Accused to make full payment against the

same, the Accused Persons are deemed to have committed an

offence under Section 138 of The Negotiable Instruments Act,

1881 and is liable to be punished accordingly.

15. That the said cheques had been issued by the accused

persons against the legally payable debt due towards the

Complainant and the Complainant has duly presented the said

cheques within the validity period of the cheques. The

Complainant has received the returned cheque along with bank

return memos on 17.05.2021 for said cheques and legal notice

for dishonor of the said cheque U/s 138 of the Negotiable

 Instruments Act was duly sent on 07.06.2021 thus present

complaint is not time barred as per section 142(b) of the NI Act.

16. That the said cheque in question was presented for

payment and encashment at the banker of the complainant i.e.

ICICI Bank, New Friends Colony, New Delhi, where the bank

account of the complainant is maintained, hence the cause of

action for dishonor of the aforesaid cheque has inter alia arisen

____________________________________________________

___________________________________________________

DEPONENT

VERIFICATION

I, the above named deponent, do hereby verify that the contents

of my affidavit are true and correct to my knowledge which I

derive from the official records of the complainant company and

no part of it is false and nothing material has been concealed there

from. Verified at Delhi on this ____ day of ________2021.

DEPONENT