IN THE HON'BLE COURT OF SPECIAL JUDGE (CBI)SHRI V.K. MAHESHW ARI, TIS HAZARI COURTS, DELHI

CBI VIS ASHOK AGGARWAL AND OTHERS

FIR: RC-SIU-8-E-000lu/s 467, 471 r/w 120B IPCNDOH: 14thJanuary 2013

APPLICATION SEEKING DIRECTIONS TO THE CBI FORINVESTIGATION AND REGISTRATION OF A FIR UNDER

APPROPRIATE SECTIONS & FOR CANCELATION OF ASHOKAGGARWAL'S BAIL

Most respectfully showeth,

1. That, the Applicant was granted tender of pardon by the court

of ASJ Shri S.L. Khanna Tis Hazari Courts in the aforementioned

case as an Approver of the CBI on ih September 2001, against a

corrupt, disgraced and dishonest IRS officer Ashok Aggarwal

(former Deputy Director of Enforcement Directorate - Delhi Zone).

2. That, the Applicant deposed against Ashok Aggarwal u/s 164

IPC on 2nd December 1999 in the aforesaid case of CBI. The trial in

the said case is presently stayed by the Hon 'ble Supreme Court of

India since Applicant's status as an Approver was challenged by

accused Ashok Aggarwal in Delhi High Court who had passed an

order in August 2007 and against this order of the High Court the

CBI filed an SLP in the Hon'ble Apex Court.

3. That, one Virendra Singh Rawat was the advocate for the

Applicant in the abovementioned case from July 1999 till September

2008. The Applicant removed V.S.Rawat from all of his cases

including the present one in September 2008 due to professional

misconduct, consistent extortion and blackmail by V.S.Rawat.

Complete facts of Rawat's unethical behavior are contained In

Applicant's complaint of January 18, 2011 addressed to the Bar

Council of India attached as Annexure-A colly.

4. That, accused Ashok Aggarwal filed an additional affidavit in

Hon'ble Supreme Court of India in November 2012 in the

aforementioned SLP. To utter shock and surprise of the Applicant

pages 63 to 67 of the additional affidavit of Ashok Aggarwal

contained a photocopy of an affidavit executed by Virendra Singh

Rawat in the matter of CBI vis Ashok Aggarwal (SLP 7266 of 2007)

copy of which is duly flagged as Annexure-B colly with this

application.

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The contents of the affidavit are in favor of Ashok Aggarwal. The

language and the chain of events mentioned therein are false and

baseless and have been narrated at accused Ashok Aggarwal's

instructions in order to spoil the case of the CBI and to mislead

Hori'ble Court(s) and to frustrate the trial.

Page 71 of the said Affidavit flagged as Annexure-C colly filed by

V.S.Rawat is the copy of the vakalatnama executed in his favour by

the Applicant authorizing Rawat as his counsel.

Page 72 of the said Affidavit flagged as Annexure-D colly filed by

Rawat is a forged document that V.S. Rawat has claimed in his

Affidavit that Applicant purportedly issued October iz", 2007 in

favour of Ashok Aggarwal.

5. That, the Applicant brought the aforementioned matter to the

knowledge of the CBI vide his letter dated zs" December 2012

attached with this application.

6. That, the conspIracy hatched between accused Ashok

Aggarwal, IRS and Virendra Singh Raw at, advocate by usmg a

forged affidavit of the Applicant is highly deplorable and they have

committed cognizable crimes of forgery, breach of trust, using forged

documents as genuine ones and conspiracy - committed by an officer

of the Indian Revenue Service and a practicing Advocate of the Bar

who had earlier represented the Applicant as his counsel.

7. That, accused Ashok Aggarwal has violated conditions of his

bail by tampering with evidence and influencing the trial, therefore

his bail is liable to be cancelled and accused Ashok Aggarwal should

be remanded to judicial custody.

PRAYER

a) .CBI be directed to investigate into the aforementioned

complaint of the Applicant and register a case of forgery, breach of

trust and conspiracy against Ashok Aggarwal and Virendra Singh

Rawat and unknown others.

b) Hon'ble Court may pass an order for cancelation of Ashok

Aggarwal's bail.

c) . Pass any other directions as the Hon'ble Court may deem fit.

Applicant

Abhishek Vermas/o Late Shrikant Verma

(in Judicial Custody)Jail 4, Tihar Prisons

New Delhi

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