ravi bhateja <ravibhateja1978@gmail.com>

Be informed that I ravi bhateja s/o baldev raj r/o 28/45 punjabi bagh

west new delhi -26 , hereby by the virtue of self motion undertaken

through self consciousness and realization , serve you with this

plaint which should be construed as a legal notice under section 80

cpc claiming damages for psychological distress and moral turpitude

and injury caused deliberately by you and your client .

2) That sh kesho dass(deceased) is the grandfather of the applicant

and father of the applicant's father . As such the subject

matter of the suit happens to be a dispute regarding the

partitioning, possession and rendition of the accounts of the

HUF property at H-10 , kirti nagar, Delhi which is in illegal

possession of thy client sh bhagwan dass bhateja or the

respondent no 1 , as he has managed to fabricate a forged will

of his father(kesho dass ) in connivance with some of his like

minded brothers for grabbing the whole HUF property .

3) That your client has got a fabricated forged will out of nowhere

and used the same to get the whole of the HUF property mutated

in the name of his wife Vimal by making through false pleas of

love and affection allegedly shared between his father and his

wife .That as such a presumption is unsustainable being contrary

Page 1 of 10

1) That yourself I.e advocate pramod ahuja have deliberately

violated the provisions of MODEL code of conduct as recommended

under Advocate act during the cross examination proceedings for

recording of evidence under order no …......and the same which

happened on 03/09/2015 in the court of JOINT registrar (a

.k.sisodia) at Delhi high court reference to civil suit The

applicant is a party to the aforesaid suit & along with his

father is arranged as defendant no 12 & 11.All the parties tothe suit are related to each other by birth & blood , being born

out of common father (kesho dass ) and mother .

5) That it is pertinent to mention here that during the course of

cross examination you had shown the attesting witness the

original copy of that very fabricated will which was allegedly

made by his father sh kesho dass & upon the basis of which your

client has clandestinely managed to get the mutation done in his

wife's name only .

to the actual reality as they used to fight among themselves and

were not in the good terms. That's why thy client had filed a suit u/s 10 HMA forjudicial separation againsthis wife/beneficiary

4) That a testimony was given by the applicant's father on

03/09/2015 in the court of joint registrar sh.A k sisodia

regarding the authenticity of the decree awarded in 1974 by the

court of sub judge sh ravi kumar securing H-10 as an HUFproperty . That on 03/09/2015 the attesting witness who is also

the father of the applicant , was cross examined by many

learned counsels of the parties to the suit including you

6) That during the cross examination proceedings on 03/09/2015

,the attesting witness, upon being asked by you regarding his

comments about the will , whether the signatures of sh kesho

dass on the will are authentic/genuine,the respondent no 11 replied in negative.Further that the witness insisted especially on this point and has repeatedly made the same answer to your

all such queries regarding the authenticity of thesignatures of his father or sh kesho dass on the will which is at present

on the record. As such all the individuals who happened to be present in the courtroom at that time including joint registrar sh.A.k sisodia along with the many learned counsels are a witness to such deposition by applicant's father and in noway such can be disputed. That the signatures present on

the will are not that of his father or that he identified and proved that the signatures present on the will are forged .

Page 2 of 10

9) That it is pertinent to mention that your client now has

realized that whatever the frauds that he has managed to

perpetrate throughout his entire life time, are now showing

signs of exhaustion and they are no longer aiding him in

achieving his ulterior motives. Your client foresees his decline

7) That after this you suggested him that his father (kesho dass )

the owner of the property personally accompanied his brother or

your client that is sh bhagwan dass & his wife vimal to the

registrar office the day when the will allegedly got registered

. To such a suggestion the witness again replied in negative as

his father had expired around 5 months prior to the date on

which registration was done . A dead person accompanying a

beneficiary to the sub-registrar's office is hilarious & out of

this world.

Page 3 of 10

8) That ever since the suit matter got invoked in 2007 , which

still awaits final adjudication , your client(bhagwan dass) has

changed a number of ld counsels for representing him in the suit

as such no learned counsel was capable of helping him win a lost

battle or the present suit . That the names of them are not

produced herewith for the sake of brevity . But it is quiet

evident that during the courseof proceedings till date ,the

situation has become very clear in everyone's mind including

your client that he shall be burned with criminal liability

instead of winning an award in the legal battle .The notion of

his defeat got affirmed by the order of sh v.k.jain dated in

which the honorable court was pleased to place an injuction over

the subject suit property and restrained your client bhagwan

dass from raising any third party interest . Hence quiet

understandably your client is infuriated by the said

deceleration .

10) That the cause of action arouse on 03/09/2015, when during

the cross examination , you specifically made the allegations of

incompetence or entitlement and took upon deliberate

obfuscation and/or used prohibited ambush defenses by mentioning

many narcissist comments and suggestions that prime facei

appears to be fabricated by you at the instance of your client

and the same was irrelevant to the existing adjudication

proceedings .In other words , during proceedings when you

happened to cross examine mr baldev raj you violated the very

soul of the judiciary upon which the temple of justice stands .

Allow me to quote those disgusting , objectionable

imputations/remarks , distasteful comments/ suggestions which

were made by you in front of the entire court including the

applicant, his mother who is also the wife of the attesting

witness along with astt registrar sh a k sisodia who was

presiding over the proceedings at that instance .

11) That the verbal sentences made by you at that point of

time are reproduced herein and are as follows:-

where he stands to loose the economic edge that he has managed

to gain and retain by advocating and practicing divide and rule

policy within the precincts of his joint family. Also it is

pertinent to mention that your client harnesses a sense of

acrimony and hatred towards his younger brother ( applicant's

father or defendant no 11) right from the day when he got

married to a working girl from a family of higher stature than

that of his own & hence he was unable to digest his progress

.That's why he specifically mentioned about the same in his

correspondences with his other brothers which is on court record in suit regarding HUF house at punjabi bagh and as such the same document is on the court record already.

Page 4 of 10

Counsel /advocate/yourself :-

" AAPKO KYA LAGTA KI HARISH KO PROPERTY KA SHARE MILNA

CHAHIYE, JAB TAK KI USKA BAAP ZINDA HAI " Reply of the

witness :-Blank or no reply.

That the witness remained silent and he avoided giving any

reply in relation to the first inquiry or the imputation made

by you.

• You :-

" AAP YEH BATAYEIN KI KYA HARISH KO KUCH PROPERTY KA SHARE

MILEGA kya JAB TAK KI USKA BAAP ZINDA HAY "?

14).Thereafter you dropped the last atom bomb on nagasaki by

13. As such both the lines convey more or less the same meaning

therefore as those sentences along with gestures one after the

another continuously being repeated by you without a

justification,can be adjudged as deliberate attempt to

distraught the witness so as to drop him in a feeling of sheer

helplessness .No wonder we all witnessed that very proceedings

including yourself and your client in which the witness looked

as if he has been insulted and pained but since as he was bound

by his oath , he nodded in affirmative .This reaction from him

is already present in the record of the court and is Exibit

No..as a certified copy of the deposition by respondent no 11.

Page 5 of 10

12). Then you repeated the same sentence but with a little rearranged

words but bearing the same imputation for the purpose of

prodding the witness to answer to you or for the purpose of

provoking him and making him angry .Therefore you repeated the

same gesture again and again and asked the same sentence in a

little different way by rearranging the words along with

intimidating facial expressions. Thereafter

looking in the eyes of the witness and saying the following

lines:-

“ HARISH KO ZAIYDAD KA HISSA TAB TAK NAHI MILEGA JAB TAK KI

USKA BAAP ZINDA HAI AUR USKE BAAP KE MARNE KE BAAD HI

HARISH KO USKA HISSA MILEGA "

16).But the very big question is how come it be justified that

Page 6 of 10

15) Respected sir we all are aware of the fact that all the

materialistic possessions of this world are a sort of an

illusion or a mirage . Every mortal being comes and goes all

alone from this world . That's why in HINDUS, for centuries some

lines are spoken in particular" RAM NAM SAT HAI “ during the

funeral procession when the mortal remains of a departed soul

are bound for pyre" .No offense that I am sure that the same

tradition shall be complied with by your own son in future if he

believes in Hinduism faith .But doesn't matter, even if he

practices faith of any other religion,then also you are bound to

be disposed off in a similar manner . Also we are aware of the

fact that from which place of the body a lady gives birth to

her child and by this process of reproduction ,you and we all

have come to an existence on this planet which is known as the

earth. Even the dead soil is regarded by intelligentsia either

as motherland or as fatherland .And you no doubt are one of

them.

17. That as such those tactics have been advanced(it is

speculation) to try and get the witness discharged by invoking a

sense of hopeless inside the the individual who unfortunately

happened to be pitted against the members of his own clan and

that includes those who are elderly and deserve unconditional

respect. Mahabharta is a classic example of such a scenario when

Lord Krishna enlightened the helpless Arjuna. That you used your

closing speech to imply bias on the part of the living members

of the applicant and his family and the same can be said to have

invoked a sense of deliberate insult and ridicule .

18.The applicant hoped that you as a gentleman upon being

informed , may admit mistakes which in reality was more than

just that and further extend tender an apology . Therefore the

applicant made an E- mail to you on date 17/12/2015. But as such nothing of that sort happened and instead you started

bombardment of vexatious notices and suits Page No.14 Therefore again the applicant made an E-mail to you on date

Page 7 of 10

we the so called learned officers of the honorable court of law

under an express oath blazingly at the top of our voice make

imputations like the ones involving blood relations or involving

that for which I have just given an example . How can we justify

the same in the color of executing the proceedings of the court

or under the pretenses of fulfilling our duty and discharging

our functions .That the cross-examination which got conducted by

you of his father was no doubt at some instance offensive and

without clear purpose or significance and same sentences were

repeated many times without any logical justification by you

.Hence ,such remarks during the cross examination were prolix,

extensive , offending and uncalled for and as such they violate

the model code of conduct for the advocates u/s 35 Of advocate'sact.

19. That it is very respectfully submitted that your such acts

are completely against the principles of natural justice and

further are fatal to it's administration . Such acts are meant

by you and your client to cause prejudice to their opponents and

unjust advantage to your own client who are arranged as parties

to the suit .It is pertinent to mention that your client gets

the same respect as that of his own father by the applicant and

they are arranged to be contesting for a common cause in a

second suit which is concerned with the partition of another HUF

property at Punjabi Bagh west, Delhi-26 .Unfortunately not even

an iota of good faith OR a notion of privileged communication

can be derived from the very conduct of rendering imputations by

you during judicial proceedings. Hence, your such actions had

been a cause of severe mental agony and anguish to the

applicant who is respondent no D 11 & his father who is D12 insuit CS(OS)1114/2008.

Page 8 of 10

on 29/12/2015. Thereafter he wished you a very happy new yearon date 01/01/2016 PAGE NO. That you chose not to reply appropriately or directly within the four walls of the Delhihigh court which you are aware of the need of a mutual

dialog as per the universal accepted norms of nobility and

civility.But instead on the date when next hearing of the case

was scheduled to be held , you approached the chamber of

advocate Geeta Dhingra (at Delhi High Court) , who is also the

learned counsel to the applicant and his father .There in her

chamber you verbally dropped names at a loud pitch of your voice

,inquired about the applicant and threatened her with dire

consequences thereby invoking an emergency alarm type of

distress in her mind .Again after committing the abhorrent act

of insult against the applicant's father ,the same was committed

deliberately by you as you know that she is also a close

relative of the applicant .Then the applicant got to know what

that transpired at his back.

Deponent

Ravi Bhateja

28/45 , Punjabi Bagh west

New Delhi-26.

E-mail :ravibhateja1978@gmail.com

Enclosure: 1. True copy of the judgement by his lordship on

06/07/2011

thereby leading to their reduction in health ,weight and well

being .As such the liability for compensating such loss of their

health lies upon your shoulders . Hence a written unconditional

apology is the need of the hour and is being demanded at an

earliest from you , along with a monetary compensation of Rs 25

Lakhs in Indian currency, failing which the applicant shall be

at his liberty to approach the competent court of law for

invoking appropriate criminal or civic legal proceedings under

the law of torts against you or your client or both entirely at

your cost and risk without causing any prejudice to anyone.

AFTER ALL THY MUST REAP WHAT THAT YOU SOW.

Page 9 of 10

20. That the period of this notice starts from today dated

03/02/2016 or THE THIRD OF FEBURARY TWO THOUSAND AND SIXTEEN of

the english calander and shall be for a period of 31 days &

destined to expire on 07/03/2016 as 6th OF march being a sunday.

Therefore it is requested to comply with the terms of this

notice at the earliest .If in case no response is received from

you with reference to this subject matter , it shall be regarded

as a denial thereby rendering the applicant the required

eligibility for proceeding further.

2. Certified copy of the cross examination of Defendant no 11 dated 03/09/20163. True copy of the e-mail dated 17/12/2015

4. True copy of the E-mail dated 27/12/2015

CS(OS)No.1114/2008 Page 1 of 6

THE HIGH COURT OF DELHI AT NEW DELHI

% Judgment Pronounced on: 06.07.2011

+ CS(OS) No. 1114/2008

SHRI HARISH KUMAR BHATEJA ..... Plaintiff

Through: Mr. Rajeev Saxena, Adv. versus

SHRI BHAGWAN DASS & ORS. ..... Defendant Through: Mr. S.P. Pandey, Adv. for D-1 to

10. Ms. Gita Dhingra, Adv. for D-11 & 12.

Mr. R.K. Bedi, Adv. for D-13 & 14.

CORAM:- HON’BLE MR JUSTICE V.K. JAIN

1. Whether Reporters of local papers may

be allowed to see the judgment? No.

2. To be referred to the Reporter or not? No.

3. Whether the judgment should be reported No. in Digest?

V.K. JAIN, J. (ORAL)

IA 7014/2008 (u/O 39 R 1 & 2 CPC)

1. This is a suit for partition of property No.H-10,

Kirti Nagar, New Delhi. The case of the plaintiff is that the

aforesaid property was owned by an HUF of which he is a

member, along with his father, brother, uncles and cousins.

The case of the plaintiff is that the sale consideration for the

CS(OS)No.1114/2008 Page 2 of 6

aforesaid property was paid from the funds of the HUF,

though the Title Deed was executed in the sole name of his

grandfather. The HUF, according to the plaintiff, was

headed by his grandfather late Sh. Kesho Dass. In the

lifetime of Sh. Kesho Dass, defendant No.11 Baldev Raj filed

a civil suit being 607/1973 seeking a declaration that the

aforesaid property which had been acquired in the name of

late Sh. Kesho Dass was an HUF property. Vide judgment

and decree dated 18th November 1974 Sh. Ravi Kumar, then

Civil Judge, Delhi passed a decree for declaration declaring

the aforesaid property as HUF property. The plaintiff, who

claims to be a member of the aforesaid HUF, is seeking

1/18th share in the aforesaid property. IA 7014/2008 has

been filed seeking injunction against sale, transfer,

assignment and parting with possession of the suit property

during pendency of the suit.

2. The suit has been contested by defendants No.1 to

10. Their plea is that the aforesaid property was the self

acquired property of late Sh. Kesho Dass, who had

bequeathed it to his daughter-in-law Smt. Vimal Bhateja,

wife of Sh. Bhagwan Dass and the plaintiff has no right, title

or interest in the aforesaid property. Defendants No.13 and

CS(OS)No.1114/2008 Page 3 of 6

14, on the other hand, are supporting the plaintiff and claim

that the aforesaid property was an HUF property and was

declared as such by the Court of Sh. Ravi Kumar, then Civil

Judge, Delhi.

3. Defendants No.13 and 14 have placed on record a

certified copy of the judgment dated 18th November 1974

passed by Sh. Ravi Kumar, then Sub-Judge 1st Class, Delhi

declaring therein that property No.10, Block H, Kirti Nagar,

New Delhi was an HUF property and Sh. Kesho Dass, who

was defendant No.1 in the suit, had no exclusive right, title

or interest in that property to alienate it to anyone to the

exclusion of other members of the HUF. A certified copy of

the decree passed by the Court pursuant to the aforesaid

judgment has also been placed on record.

4. The contention of the learned counsel for

defendants No.1 to 10 is that the documents filed by

defendants No.13 and 14 are forged documents and no such

decree was ever passed by the Court. He also states that

this suit is a counter blast to the suit already filed by his

clients, which is pending before the learned Additional

District Judge, Delhi.

5. At this stage, there is no material on record on the

CS(OS)No.1114/2008 Page 4 of 6

basis of which it can be said that the documents filed by

defendants No.13 and 14 are forged documents. It was

contended by the learned counsel for defendants No.1 to 10

that the copies of the judgment and decree sheet filed by the

plaintiff are different from the copies filed by defendants

No.13 and 14. I have compared the photocopies filed by the

plaintiff with the certified copies filed by defendants No.13

and 14 and I have not been able to notice any discrepancy

in the two sets of copies. Prima facie, these documents

appear to be genuine certified copies of the judgment and

decree dated 18th November 1974, passed by Sh. Ravi

Kumar, then Sub-Judge 1st Class, Delhi. If the suit

property is an HUF property in terms of the aforesaid

judgment and decree, obviously late Sh. Kesho Dass had no

right to bequeath whole of it to his daughter-in-law and he

could have bequeathed only his share in the aforesaid

property.

6. Since plaintiff has made out a prima facie case,

showing the suit property to be an HUF property and he

claims to be a member of the HUF having 1/18th share in

the property, it would only be appropriate that the suit

property is preserved during pendency of the suit and no

CS(OS)No.1114/2008 Page 5 of 6

third party interest is created therein. It is settled

proposition of law that in a suit for partition, the property

subject matter of the suit needs to be preserved during

pendency of the suit, if a prima facie case is made out in

favour of the plaintiff. If the injunction is not granted and

consequently the contesting defendants are able to sell,

transfer or alienate the suit property either wholly and in

part or part with its possession, that may negate the decree

which may be passed in favour of the plaintiff and it may be

difficult for the plaintiff to execute such a decree in view of

creation of third party interest and delivery of possession to

a third party. The parties to the suit are, therefore, directed

to maintain status quo with respect to title and possession

of the suit property during pendency of the suit.

The application stands disposed of.

IA 7443/2009 (u/S. 151 CPC)

Dismissed as not pressed.

IA 13920/2009 (u/S. 151 CPC)

Heard. Since certified copy of the judgment and

decree dated 18th November 1974 has already been filed by

defendants No.13 and 14, the purpose of passing the order

dated 30th May 2008 requiring the plaintiff to file the

CS(OS)No.1114/2008 Page 6 of 6

original/certified copy of the order has been fulfilled.

Mr. Pandey states that the record of the suit is not

available in District Court being old record. The question

whether the record is available or not, has no relevance at

this stage, since the authenticity or otherwise of the certified

copies filed by defendants No.13 and 14 has to be finally

decided only after recording of evidence.

The application stands disposed of.

(V.K. JAIN)

JUDGE

JULY 06, 2011

Ag

CI\IIL NA.ZTRJS.H.CI.

NA*{H $S pRSCHi$ SSRVHR..

NOTTCE TS S$$W CAUSS/CS$RT NSTTCE{$aNERAL FSRM}

{N rHH SQUR} O.S:SI+. S,mfr$q Tisl*ni kskh$npqh, FC,trI {"T,{M S,$"S-iq S*s$ri $q||rt" Rslhi

Cornputer ldentificatian No. S?4S l C0S6S$420 t 5

Filing Nu, fr$$941 2015

R*rlrn N*.

suit Nr. RcAl4ll3$15

rir'* :-K*$HgH*ff$ iilgcgesss) y",r. ##gX g*J

TOBALDEV RAJ

S/u I-ATS SH. KESHO DASS

R/{} ?{*/45, FUNJABI BA{iH {WE$T}NEW DELHI\.Y*AST DELIfl. DELI{I-|i...-rDIA

RACH NA TilA,/iTd! LAKH'qNPAL8gn ic.r" tlil,'i I,..! I I ::ir:; ?-*tllTl-Ret tt Cr:i'l::'i." iirr {i,ffsgO

Roerm \io. 3SOTls t-laaarl Deltil

WI{EREAS thc above-narncd Kffm0 DASS ($3C, ASXD) hrc m& ap,plic*ion to this Coutt dutYnu *r* her*by \s&rnsd tu, eppssr in thi* Cnurt in p*nncn sr by n ple*d,er $uty

instru$sd on the l$ttr dny *f Feb* l$t6 nt l$ AIlt causs ngninst the applicafion,

lril$g heurcl and defermined dl*t*p$rfs.

{:}IVEN undr:r rnv hanct and the seal nf the Cnurt this l4th $ay nf Secn ?$}5.

failixg whereino the ssid *pplication

n I l,rlrtor Civil Sudge'cut[*(t ilAtient@ftftroller {uf*t} -

Y ' tit -dtari coruts, Dclhl

tA r-lcllAl-): ,${rd4&01, icnflil D*id),n i{ocrr i\kr. 347, frd FlIrf'b ffiErt Cerrf, Dil

Date of order : 20.01.16Date of filing of PF : 25.01.16Date of Issue : 29.01.16Next Date of Hearing: 04.02.16AT 2PM

M NO. 01/16BALDEV RAJ

VS.KESHO DASS (DECEASED)

To.

COURT NOTICE

SH. BALDEV RAJS/O LT. SHRI KESHO DASS28/45, PUNJABI BAGH, (WEST)NEW DEI,HI

Whereas applicant has moved an application U/o 9 Rule L3 (copy enclosed). You are

.l

required to appear in person or through pleader in this court on the next date of hearing i.e.

04.02.2016 at zPM to give reply of the said application.

Given under my hand and seal of this court on 29.01.l-6.

C |\rli- i UDGP$ENrR,'{I L \

D[!-i-il

YV

ROOM NO. 347, TIS HAZARI COURTS. DELHI

ravi bhateja <ravibhateja1978@gmail.com>

Refer to your communication on the behalf of thy client.1 message

ravi bhateja <ravibhateja1978@gmail.com> Thu, Dec 17, 2015 at 6:59 PMTo: pramodahuja.adv4@gmail.com

saadar pranam dear ,                                First of all i would like to appreciate your endever your efforts your family . After all a person earns money for the sake of one's family ,no matter how one earns it.No wonder humans aresuperstitious but lawyers are rational and practical. Also a lawyer may never commit to any emotion as they are not emotional fools unlike the rest of us . No wonder even a butcherer would blame general publicas an excuse for his own abhorrent crimes committed with such an impunity that a prudent man is bound to blame himself that why  did  he questioned him in the very first place .The very first instance when isaw you within the premises of del high court i had thought that you have an impeccable quality . i  had never anticipated it but now i regret to say that you have failed me totally .Looking at your conduct in thecourt when you were cross examining my father , my nerves got filled with lava when you suggested and asked my father that harish won't be getting a share till his father is alive and it is upon his expiry blah blah!!! I was bound by law and  took your grey hairs in consideration otherwise you would have got a new client to defend / prosecute for sure right there. Any way i know the entire blood line of yours and pleaserealize that your BIG B is no longer a Presiding officer and your are no longer entitled to immunity or privilages.  you are not faithful to your blood line that i know but it would be better if you also get to know that i am unlike you . I do feel sad and pained to see you sucking the blood of my tau like a leech. and that AGEDperson who thinks himself to be more than intelligent ,  is being made a chutiya by u even inspite of being fully  aware that he stands no chance in this litigation . How interesting that seemed to me when i readyour notice just a short while ago and i am still confused whether to laugh on it or scratch my head . Lower judiciary is being invoked to give  orders to hon'ble  high court lozzz. Well it now appears to me as if youalso are a brother of tomar i.e Ex law minister . ANYWAYS THY SHALL REAP AS YOU SOW.

Asking for your blessings as i know you haven't grown your hair grey because of sunlight , ­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­ tau ka wafadaar munda jai mata di & jai hind 

ravi bhateja <ravibhateja1978@gmail.com>

In Reference to your communication on the behalf of B.D.Bhateja1 message

ravi bhateja <ravibhateja1978@gmail.com> Tue, Dec 29, 2015 at 10:08 AMTo: "pramodahuja.adv4@gmail.com" <pramodahuja.adv4@gmail.com>

Dear sir ,                I would like to take another oppertunity  out of your very precious time to enlighten you on the subject which is at present represent the cause of action of your client i.e sh b.D.Bhateja . Dishonestyonly fruitifies dishonesty . And all the efforts of either you or your client shall see the judgement day much ahead of time . Well i thought  about sharing a topic with you which i am sure will invoke your interest asthe subject matter is related to the interest of thy client . Kindly see and show to your client also . As far as the suit is concerned plz tell mr b.d.bhateja that i alone am sufficient to deal with the vexatious suitsthat you are now retorting to. Whether the suit is bad in law , barred by the principles of res­judicia & estoppel or if it is a fraud on the court u/s 340 crpc .Well respected sir i would like you to tell him that in thiscase also the bar contained u/s 195 crpc is not attracted as the forgery was committed much earlier so you are also going to get a case where you client will be impleaded as a fraud/defendant .happy skimmingthe cream ......

dpa.pdf2296K

ravi bhateja <ravibhateja1978@gmail.com>

HAPPY NEW YEAR1 message

ravi bhateja <ravibhateja1978@gmail.com> Fri, Jan 1, 2016 at 3:10 PMTo: "pramodahuja.adv4@gmail.com" <pramodahuja.adv4@gmail.com>

Ravi Bhateja 

respected sir ,                            wishing you and your family HAPPY NEW YEAR 2016. Your's own ,