25th November 2023
The SHO
Kalka Ji .Police Station
New Delhi
Subject - Formal Complaint regarding cheating, criminal breach of
trust, criminal misappropriation of property, making forged documents
against accused Mr. Pallav Mishra Manager of IDBI Bank Kalkaji
Branch and directors and representative of IDBI BANK Kalkaji Branch
and builder Vinay Jain
Respected Sir,
I, Naveen Kumar, residing at Flat No. B-4 AF/F Left Side, Flat No-201,
Vishwakarma Colony, Badarpur, South Delhi, Delhi-110044, am
submitting this formal complaint to bring to your attention an alleged
commission of criminal offenses, including cheating, criminal breach of
trust, criminal misappropriation of property, and the forgery of
documents committed by Mr. Pallav Mishra, the Manager of IDBI Bank
Kalkaji Branch, in collusion with Vinay Jain and other bank employee of
IDBI Bank, Kalkaji Branch.
The detailed narrative of the events is outlined herewith:
(1)That in March of 2016, while I was employed by IDBI Bank, my
Branch Manager, Mr. Pallav Mishra, informed me of a real estate
deal in AVJ Heights, Greater Noida. He stated that one of the
bank's customers had taken out a loan, but due to personal
reasons, he was unable to repay the amount due towards loan.
Pallav assured me that he could handle the loan transfer and
property transfer on my behalf if I would be willing to purchase the
said property, and he also enticed me with the property's price,
citing his good relationship with builder Vinay Jain. He added that
the flat's cost is approximately Rs 35,000,00/- (Rupees Thirty-Five
Lakh Only). He also represented me that if I am willing to purchase
the property, Vinay Jain will contribute Rs 500000/- (Rupees Five
Lakhs Only).
(2)That since Pallav was my senior at the time, I trusted his words as
the deal appeared extremely profitable. Consequently, I agreed to
purchase the property, l.e. flat number 1806, Tower-A, 18th Floor At
Group Housing Complex namely "AVJ HEIGHTSS," which has an
approximate super area of 1150 square feet and one parking
space.
(3)That thereafter Pallav Mishra in collusion with Vinay Jain and other
Jr*
Bank employee's created forged document builder 'buyer
agreement and allotment letter and under misrepresentation of
fact that the said flat is free from any charge or mortgage got my
signature on the agreement. I was handed over photocopy of the
said documents and they retained the original documents. They
also availed housing loan on my name after using the forged
documents and initially I paid seven lakhs seventy-two thousand
nine hundred forty-seven rupee.
(4)That after that, from April 2016 to February 2023, I was paying
roughly Rs 23734/-per month as EMI. However, I stopped paying
my loan EMI for personal reasons and because of my financial
situation.
(5)That at some point in September 2023, I was shocked and
surprised to learn that the aforementioned property had already
been given to a man named Pankaj Kumar by the Builder and had
been financed by HDFC Bank in 2011. Mr. Pankaj Kumar had
defaulted on the loan, and HDFC Bank had started legal
proceedings to attach the property.
(6)That according to CREDIT INFORMATION BUREAU (INDIA)
LIMITED, each property has a unique credit score since people are
rated based on their financial activity and conduct. For example, a
property's CIBIL score will reflect any existing mortgages it has
with banks or other financial institutions. Therefore, it would not
be incorrect to argue that the resale of the sold apartment to a
third party and the subsequent loan to a third party made in
collusion with the bank and builder constitute a clear instance of
fraud, criminal misappropriation of property, criminal breach of
trust, and forgery of documents.
(7)That is from above it is clear that I have been deceived,
fraudulently and dishonestly by Mr. Pallav Mishra Manager of IDBI
Bank Kalkaji Branch and directors and representative of IDBI BANK
in collusion with Vinay Jain.
(8) That the accused also created forged document and used the
same to induce me to enter into agreement and caused me
unlawful loss.
Therefore, I hereby request you to take strict action the above mentioned
person for offence of forgery of document, cheating, criminal breach of
trust, criminal misappropriation of property.
X
Yours sincerely
Naveen Kumar
Contact No- 9654678388
