Status Est. Value(Rs.)(lJ_cr<J (~ lT)) SL.No. (sfi.~.) Property Type(Description)

9. Particulars of properties stolen/involved (attach separate sheet if necessary)(~~~ cfiT fucroir):

8. Reason for delay in reporting by the complainant/informant (~<hl<l11<h11 f I~~ &TU fttnt ?;ft~~~~ cfiRUT):

NO DELAY

- OTHER KNOWN AND UNKNOWN PERSONS

(R/0) UNKNOWN, NEW DELHI, DELHI, INDIA

7. Details of Known/Suspected/Unknown accused with full particulars(attach separate sheet if necessary)(~/ ~f?;ra /3w1T11" ~m cfiT qt fucroir $ c(Uf;:r ) :

- PRATAP BURMAN

(R/0) J-3/1, DLF QUTAB ENCLAVE, PHASE II, GURGAON, HARYANA, INDIA

Nationality(~): INDIA

Date of Issue ("llft m cffl" fi'!rfu ): Place of Issue ("llft m cfiT HIT;J):

(b)Date/Year of Birth (;;r,:JT ~ /crrf):

(c)Passport No.(~~-):

(d)Occupation (c21crnm):

(e)Address(tIBT): C-6/60, GROUND FLOOR, SAFDARJUNG DEVELOPMENT AREA, NEW DELHI, DELHI, 110016, INDIA

District(~): Name of P.S(l!THT cfiT ;m:J):

6. Complainant/ Informant (~i<hl<l11<h11f/~~ ): (a)Name(;m:J): RAJIV BURMAN (S/0) LATE SH. MR. L.N. BURMAN

Beat No(~~-): 895600100

Time Period (mm arcITTJ): Time From (mm~): 00:00 hrs Time To (mm i'fcfl): 00:00 hrs

(b)lnformation received at P.S.(l!THT ~ ~'cRT ID"!l ¢ ): Date(f?;;li<h): 06/09/2019 Time (mm): 15:20 hrs (c)General Diary Reference (<1"1Hl>lill ~~i): Entry No.(~~.): 003A Time (mm): 15:26 hrs

4. Type of Information (~'cRT cfiT UcfiR): WRITTEN

5. Place of Occurrence (m:-m=:!«ir ):

(a) Direction and Distance from P.S (l!THT ~ c;;:ft afn: f?;.m): N/A, 2 KM(s) (b) Address(trnl): DOA OFFICE, VIKAS SADAN NEW, DELHI

(c) In case, Outside the limit of the Police Station (<fl?; l!THT -dTm ~ ~ i ):

Date To(f?;;rt<h i'fcfl): 06/09/2019 3. Occurrence of offence ( 3fll"CT& cffl" ~):

(a)Day(f?;;{): INTERVENING DAY Date From(f?;;li<h~): 01/01/2002

Section( s )(muftf))

406/418/420/467/468/471/4 74/1208 1 IPC1860

2. Act(s)(~)

Year(crrf):2019 FIR No("Q".~.ft.~.):0178 Date (f?;;li<h):06/09/2019 P.S.(l!THT): ECONOMIC OFFENCES WING

1. District(~): EOW DELHI

FIRST INFORMATION REPORT (Under Section 154 Cr.P.C.)

10. Total value of property stolen (mfr¢~ cfiT ~ lJ_iYlr):

11.lnquest Report/ U.D. Case No., if any (JI:~ -mft~ft-crrt /<J_.it.~;:i-., -cl?; <ITTt 12. F .I.R. Contents (attach separate sheet, if required)("lrl!llf ~'qrff fttirt o:m):

Dated:11.03.2019 The Additional Commissioner of Police, Economic Offences Wing, Mandir Marg, New Delhi SUB: COMPLAINT REGARDING OFFENCES PUNISHABLE UNDER SECTION 403, SECTION 406, SECTION 417, SECTION 418, SECTION 420, SECTION 423, SECTION 466, SECTION 467, SECTION 468, SECTION 471 AND SECTION 474 READ WITH SECTION 1208 OF THE INDIAN PENAL CODE, 1860 PS: Economic Offences Wing COMPLAINANTS: 1. Mr. Rajiv Burman, S/o Late Mr. L.N. Burman, R/o C- 6/60 (Ground Floor), Safdarjung Development Area, New Delhi-110016 2. Dr. Ajit Burman, S/o Late Mr. L.N. Burman 33, Fair Haven Avenue, White Field, Manchester, M-457QG, United Kingdom ACCUSED: 1. Mr. Pratap Burman, S/o Late Mr. L.N. Burman, R/o J-3/1, DLF Qutab Enclave, Phase-II, Gurgaon 2. Other known and unknown persons. Sir, This complaint is being made to you by the complainants Rajiv Burman & Dr. Ajit Burman. The information relevant to the complaint is set out hereinafter: i Complainants Mr. Rajiv Burman & Dr. Ajit Burman are law abiding citizens and the complaint has been filed against the Accused Mr. Pratap Burman and other known and unknown persons for forging an Agreement to Sell dated 26.11.1987 purportedly between Pratap Burman and L.N. Burman (H.U.F) and fraudulently using the same with DOA to deceive them into executing a Conveyance Deed in Pratap Burman's individual name, thereby wrongfully gaining title to immoveable property bearing House No. C-6/60, Safdarjung Development Area, New Delhi admeasuring approx. 500 sq. yds. (hereinafter referred to as "Property"). ii. One Mr. Radhakishan Nagpal was the original owner/allottee of the said Property vide Perpetual Lease Deed dated 26.03.1966. In 17 .02.1979, an Agreement to Sell was entered into by Radhakishan Nagpal in favour of L.N. Burman (HUF) by which the said property was sold to L.N. Burman HUF. At the relevant time, members of L.N. Burman (HUF) were Sh. L.N. Burman (father of complainants and accused), mother Mrs. Jai Rani Burman along with Complainants Rajiv Burman and Dr. Ajit Burman, and Accused Pratap Burman, who are all real brothers. Iii. Alona with the above mentioned Aareement to Sell. A General Power of Attorney (hereinafter referred to as "GPA") dated 27.02.1979 was entered into by Radhakrishna Nagpal in favour of Accused Pratap Burman. However, no power of negotiating or conducting sale was given to Pratap Burman in the said GPA and it was only for the purpose of facilitating construction of the Property as Radhakishan Nagpal was aged at the time of execution of the Agreement to Sell and GPA. In addition to the above, Radhakrishan Nagpal also executed a registered Will dated 09.03.1979 whereby he bequeathed the said Property to Sh. L.N. Burman, and in case Sh. L.N. Burman predeceased him, then in equal shares to Complainants Rajiv Burman & Dr. Ajit Burman and Accused Pratap Burman. Thus, there was never any intention to transfer the same to only Pratap Burman. iiii. Although Complainants were not aware of this at the time, Accused Pratap Burman fraudulently created a Forged Agreement to Sell dated 26.11.1987 with L.N. Burman (H.U.F.) allegedly for a sale consideration of Rs. 1,42,000/- (Rupees One Lakh Forty Two Thousand Only) allegedly given in cash. When Complainants later discovered this forged document, they realised that the signatures of their father, Mr. L.N. Burman have been forged on this document. They engaged Handwriting Expert Mr. Suresh Chandra Gupta, Ex­ Director (Govt Examiner of Questioned Documents) to compare questioned signatures of Mr. L.N. Burman on forged Agreement to Sell dated 26.11.1987 with admitted signatures on earlier Agreement to Sell dated 17 .02.1979. In his Report dated 28.06.2010, handwriting exert has opined that signatures of Mr. L.N. Burman in forged Agreement to Sell dated 26.11.1987 do not match with the signatures in Agreement to Sell dated 17.02.1979. Copy of Expert Report is enclosed herewith. The fraud is further revealed from the fact that while the Agreement purports to be executed on 26.11 .1987, Pratap Burman is described as "S/o Late Shri L. N. Burman" even though Shri L. N. Burman passed away much later in 1989. V. Father of the parties herein, Mr. L.N. Burman, passed away on 11.08.1989. In accordance with Hindu law, there was a notional partition of the property and Complainants Rajiv Burman and Ajit Burman and Accused Pratap Burman became individual owners of their respective undivided shares in the Property. The share of Late Mr. L.N. Burman was distributed equally amongst his family members i.e. Wife Mrs. Jai Rani Burman, sons namely Rajiv Burman, Ajit Burman and Pratap Burman, and daughters namely Suman Mehra, Lata Khanna, Beena Dayal & Meena Berera. vi. From time to time, the brothers viz. Complainants would request the Accused Pratap Burman to take the required action to transfer the property in DOA records in names of all members of the HUF and he kept on saying that he would do the needful. At no time did Accused Pratap Burman ever claim that he was the sole owner of the Property nor was the forged Agreement to Sell dated 26.11.1987 ever revealed by Pratap Burman to Complainants or any other member of the family. In or around 06.12.1992, a Memorandum of Understanding was executed between Mr. Pratap Burman, Mr. Ajit Burman and Mr. Rajiv Burman where it is an admitted fact that the suit property is owned by L.N. Burman (H.U.F.). vii. Without informing the Complainants or any other member of the family, Accused Pratap Burman filed a series of applications with the DOA for conversion of Leasehold rights in the property (in the name of original owner Radha Kishan Nagpal) to eventually get the property converted to his sole name using forged documents. The existence of forged Agreement to Sell dated 26.11.1987 and execution of Conveyance Deed dated 15.07.2002 in name of Pratap Burman were discovered by Complainants only in December 2008 when they tried to amicably resolve matters, but Accused shocked them by revealing the above documents for the first time. Complainants were initially reluctant to initiate proceedings against pratap Burman veing their real brother. So they continued to try to amicably resolve the issur and filed a request under Right to Information Act dated 26.07.2010 to get the entire DOA file along with relevant Notings to discover precisely how the Accused had fraudulently obtained the Conveyance Deed. Viii.Detailed particulars of the fraudulent use of forged Agreement to Sell dated 26.11.1987 before DOA were obtained by Complainants when the entire file was provided under RTI on in September, 2010. In the civil suit for partition that was subsequently filed, DOA has supplied certified copy of the entire conversion file and proved the same in Court as well. ix. Based on the above chain of events and facts revealed by the DOA File, Complainants learnt how the Accused Pratap Burman changed his stand before the DOA with regard to conversion and used the forged document to fraudulently get Conveyance Deed of the property in his sole name thereby causing grievous loss to the Complainants. x. Accused Pratap Burman first filed Conversion Application No. 3037 40 dated 30.06.1994, acting as attorney of Radhakishan Nagpal, seeking conversion in favour of L. N. Burman (HUF). At this stage, the accused was not seeking conversion in his own name and following documents were submitted by the accused: * Perpetual Lease Deed dated 20.06.1966 of the Property in favour of Radhakishan Nagpal * Agreement to Sell dated 17.02.1979 entered into by Radha Kishan Nagpal in favour of L.N. Burman (HUF)* G.P.A. dated 27.02.1979 by Radhakishan Nagpal in

2

1.1.F.-1 /~ '1fl'q tnnf-1 Date:061os1201s FIR No: 0178 P.S: ECONOMIC OFFENCES Year: 2019 WING

District : EOW DELHI

3

favour of the Accused. Will dated 09.03.1979 of R.K. Nagpal was not disclosed. xi. On 18.12.2001, Accused Pratap Burman for the first time used the forged Agreement to Sell dated 26.11.1987 with the DOA by submitting the same along with letter for conversion of the property from leasehold to freehold in his individual name, contrary to his earlier application where he had asked for conversion in the name of LN Burman HUF. The following documents were enclosed therewith: * Forged Agreement to Sell dated 26.11.1987 purportedly between LN Burman (HUF) and Accused, bearing forged signatures of Late Mr. L.N. Burman and wrongly describing him as deceased in 1987; * Indemnity Bond dated 20.09.2001 by Accused relying on Forged Agreement to Sell dated 26.11.1987 * Affidavit dated 20.09.2001 by Accused relying on Forged Agreement to Sell dated 26.11.1987 * Agreement to Sell dated 17 .02.1979 by Rad ha Kishan Nag pal in favour of L.N. Burman (HUF) *General Power of Attorney dated 27.02.1979 by Radha Kishan Nagpal in favour of the Accused xii. Pursuant to the above letter, DOA requested for more documents vide communication dated 21.01.2002. In response to the above letter of ODA, the Accused issued another letter dated 13.02.2002 again enclosing forged Agreement to Sell dated 26.11.1987 and falsely claimed property was purchased by him from Late L.N. Burman HUF. Xiii. Accused Pratap Burman again issued letter dated 12/06/2002 to DOA enclosing the following documents in support of Conversion Application No. 303740: * Indemnity Bond dated 05.06.2002 by the Accused relying upon forged Agreement to Sell dated 26.11.1987 * Affidavit of the Accused dated 05.06.2002 relying upon forged Agreement to Sell dated 26.11.1987 xiiii. On account of submission and reliance on forged Agreement to Sell dated 26.11.1987, DOA allowed Conversion of the property in the sole name of Accused Pratap Burman. The fact that forged Agreement to Sell dated 26.11.1987 formed the basis of DDA's decision to convey property to Accused is clear from a perusal of ODA File Noting dated 18.06.2002 (obtained under RTI) approving Conversion in favour of the accused outlines which documents were relied upon by ODA, including "Attested copy of Agreement to Sell" at Page 242/C which is the forged Agreement To Sell dated 26.11.1987, and "Attested copy of G.P.A." at Page 239/C which is G.P.A. dated 27.02.1979 which did not authorise the accused to sell the property. Conveyance Deed, which is a valuable security, was executed by ODA in favour of the accused in his individual capacity on 15.07.2002 relying upon forged documents submitted by him. xv. When the Complainants discovered about the Conveyance Deed got fraudulently executed only in the name of Accused Pratap Burman, they filed a civil suit namely C.S. (O.S.) No. 1902/2010 titled "Dr. Ajit Burman v. Pratap Burman & Ors." presently pending in High Court of Delhi. Xvi. In the said civil suit, Accused Pratap Burman filed his Written Statement dated 18.02.2011 wherein contrary to his stand and submissions before DOA, no mention is made of the forged Agreement to Sell dated 26.11.1987 and the accused only relied upon Agreement to Sell dated and G.P.A. dated 17.02.1979. A false statement is made by him with regard to DOA Conversion process, namely "on 15th July 2002, answering defendant got the title of suit property transferred in his favour in performance of Agreement to Sell dated 27.02. 1979". This is contrary to his stand before the DOA where he got Conveyance Deed executed relying on forged Agreement to Sell dated 26.11.1987. xvii. Accused Pratap Burman further contradicted his stand and exposed his forgery and fraud, when in a letter by his lawyer dated 12.07.2012, Accused Pratap Burman attempted to disown the entire conversion process by falsely alleging that the entire matter of conversion was undertaken by Complainant Rajiv Burman, which is completely contradicted by DOA Record. DOA has confirmed vide its letter dated 21.01.2011 that the application for conversion and submission of documents was made by Accused Pratap Burman alone. Finally, in a reply dated 06.02.2012 to an application for discovery of documents, Accused Pratap Burman admits that forged and interpolated documents have been submitted to DOA for the purpose of conversion, but again falsely puts the blame on Complainant Rajiv Burman. Needless to say, Rajiv Burman would have no cause or incentive to file forged documents to benefit Accused Pratap Burman. Xviii. From the above narration of facts, it is clear that Accused Pratap Burman in conspiracy with unknown persons has forged signatures of L.N. Burman on a document purporting to be an Agreement to Sell dated 26.11.1987, and has further used the same with the DOA to cheat the DOA and Complainants thereby obtaining valuable security in the shape of Conveyance Deed dated 15.07.2002 by fraud. The Accused has thereby committed offences under Sections 403/406/417/418/420/423/465/467/468/471/474 read with 1208, Indian Penal Code, 1860. The Complainants request you to take appropriate action to protect our rights, and direct registration of FIR and investigation of the matter. xx. The value of the property obtained by the fraudulently obtained conveyance deed is above 2 crores. Yours sincerely, Sd/English (Rajiv Burman) S/o Late Mr. L.N. Burman, R/o C-6/60 (Ground Floor), Safdarjung Development Area New Delhi-110016 Ph: 9810121015 Sd/English (Dr. Ajit Burman)S/o Late Mr. L. N. Burman 33, Fair Haven Avenue, White Field, Manchester, M-457QG, United Kingdom ph: +44 1617663513 Do P.S. EOW, On receipt of the above mentioned complaint preliminary enquery was conducted . From the enquiery conducted and contents of the complaint prima facie offenses U/s 406/418/420/467/468/4 71/474/1208 IPC our made out. Hence register a case and handover investigation to me. Place of Occurrence: DOA Office, Vikas Sadan, New Delhi Date and Time of occurrence: Year 2002 Date & Time of handing our rukka: 6.9.2019 at 3.20 PM Sd/English INSP. GURMAIL SINGH NO. D-994, PIS NO.- 16950138 SEC-1/EOW Action taken at police station at this time INSP. GURMAIL SINGH NO. D-994, PIS NO.- 16950138 SEC-1/EOW New Delhi came in the police station and produced the above mentioned complaint for the registration of case. Case has been registered. Copy of FIR and original Rukka is being handed over time INSP. GURMAIL SINGH NO. D-994, PIS NO.- 16950138 SEC-1/EOW New Delhi for further investigation. Copy of FIR will be delivered to concerned officers through OAK. ASl/00

13.Action Taken Since the above information reveals commission of offence(s) u/s as mentioned at Item No. 2: (cfiT 1mT <ffi<fcrrtT: 'q_f<n 31fmfi ~ ~ t«'fT 'i:wlrtT 6 f<fi 3TlmU ffi <oT ~ ~ ~.2.ll ~<!I um~~ 6 ): (i) Registered the case and took up the investigation (WITTUT ~~nm~ ;;rjq ~ fc;ri:r fi;rm nm): or (m)

(ii) Directed (Name of 1.0.)(;;riq ~ <oT =m ): GURMAIL SINGH Rank (tR;): I (INSPECTOR)

No(~.): 16950138 to take up the Investigation (<fil ;;rjq arrtf.t lITTJ -it ~;) ~ fc;ri:r f.lt~r f?;m nm) ortzn)

(iii) Refused investigation due to(;;riq ~ fc;ri:r): or(~ <nRUT ~ ~ zn)

(iv) Transferred to P.S(name)(:!THT): District(~): on point of jurisdiction (<fil ~hITT&<of{ ~ <nRUT ~i'ffto)

1.1.F.-1 /~ si!l'cJ lfillf-1 Date:0610912019 FIR No: 011s P.S: ECONOMIC OFFENCES Year: 2019 WING

District : EOW DELHI

4

15. Date and Time of despatch to the court ( ~ ~ «l'fUf cln- ft:rrcn aitt mm):

Name(;mJ): KAMTA PRASAD PANDEY

Rank (Qc;): ASST. SI (ASSISTANT SUB-INSPECTOR)

No.(-e'.):

Signature of Officer (:!l"RT ~ ~ ~~) 14.Signature I Thumb impression of the complainant I informant. (~icfil<locfidf I~~~ ~~ I ailJ-3" cfiT f.r,m;:r):

R.O.A.C.(am:.air."Q".~.)

F.I.R read over to the complainant/informant,admitted to be correctly recorded and a copy given to the complainant/informant, free of cost: (~lcni<Hl<nof I~~ en) mmwlrr tr<;; cnt '!~ TT<ft, ~ c;-;f ¢ llR1 3ltt -qcn cnitft f.r.!{!;<'<h ~lcni<locnaf <ITT tl" TT<ft) :

1.1.F.-1 /~ '1fl'q tnnf-1 Date:061os1201s FIR No: 0178 P.S: ECONOMIC OFFENCES Year: 2019 WING

District : EOW DELHI

5

These fields will be entered only if complainant/informant gives any one or more particulars about the suspect/accused. (~ ~~ o~c;-;;f ~;;rn:t-it ~ ~qjl<l11qj11f I ~'cRT<mff ~f?;ra I ~m~iffi~ ~~ zrr ~ arn)"qj~ ?;oT~ I)

Deformities/ Peculiarities Teeth Hair Eyes Habit(s) Dress Habit(s) (~/~) (?;To) (~) (31T~) ( 3IT?;(f) (~)

8 9 10 11 12 13

Language /Dialect Place Of(cfil "fl!lR) Others ('IITTT/~) Burn Mark Leucoderma Mole Scar Tattoo (3Rr)

(~ ~cfil ( &qc;f TilT ) (lffm) ('tflq) (TJ_?; ~ cfil) f.r,m;r)

14 15 16 17 18 19 20

S.No. Sex Date/Year of Birth Build Height(cms.) Complexion Identification Mark(s) (so.~.) (TiiPT) ( ;;JrJJ fi!tfu I crrf) (ilrlTclc) (~(ibft)) (trr) (~~)

1 2 3 4 5 6 7 1 MALE 2 MALE

Attachment to item 7 of First Information Report (1JmT ~TRI ft"lllt ~ ~ 7 ~iil1T<fi):

Physical features, deformities and other details of the suspect/accused:(lf known/seen ) (~f?;ra t ~m <fiT ~ fcr~-iranr. ~ ~ aRr ~ :(~ ~ t tffl rrm))

1.1.F.-1 /~ si!l'cJ lfillf-1 Date:0610912019 FIR No: 011s P.S: ECONOMIC OFFENCES Year: 2019 WING

District : EOW DELHI