1

IN THE COURT OF ADDITION AND SESSION COURT

KALYAN

INTEVENTION APPLICATION NO. OF 2025

IN
BAIL APPLICATION NO.------ OF 2025

DIST.: THANE

1. KAMLESH MALVANKAR ]
Age Adult, Occ; Business ]
Adult Indian inhabitants of Mumbai ]
Having their residence at:_____ ]
. ] … Accused
Versus
THE STATE OF MAHARASHTRA ]
(Through the Vishnu Nagar Police Station, ]
Dombivali west, Thane ] …Respondents
IN THE MATTER BETWEEN

KISHOR GAIKWAD ]
Being an adult Indian inhabitant of ]
NASIK, having his residence at: ]
______________ ]…Orig.
Complainant/Applicant/In
tervenor
TO,
 2
THE HON’BLE COURT
AND OTHER HON’BLE KALYAN COURT
AT KALYAN

THE HUMBLE
PETITION OF THE
PETITIONER ABOVE-
NAMED

APPLICATION U/s.301(2) OF THE CrPC

TO ALLOW THE FIRST INFORMANT TO
INTERVENE AND OPPOSE THE BAIL
APPLICATION OF THE ACCUSED /
ANTICIPATORY BAIL APPLICANT

MOST RESPECTFULLY SHWETH

1. That is the Original Complainant and the first

informant in the FIR bearing No. 0169 of 2023

registered at Vishnu Nagar Police station,

Dombivali West, Thane.

2. I say that I have learnt that the Accused in the FIR

bearing No. 0169 of 2023 registered with the

Vishnu Nagar Police station, Dombivali Wes,

Thane, has filed the Bail Application being

No..1589/2023 before this Hon’ble Court to

 3
anticipate his arrest in the said FIR No.0169 of

2023. Hereto annexed and marked Exhibit-“A” is

a copy of F.I.R dated 03/07/2023.

3. The Applicant humbly submits that he has filed the

present Intervention Application in the Bail

Application No. ________ of 2024 filed by the

Original Accused persons, Applicant humbly pray

to this Hon’ble Court for allowing the Intervener

Applicant to intervene in the said Bail Application

No._____/2024 and thereby hear the present

Intervener Applicant before deciding the said Bail

Application. The Intervener Applicant humbly

submits that he intends to oppose the said Bail

Application No.______/2024 filed by the accused.

The Intervener Applicant intends to bring the

various facts on record which will assist the

prosecution to decide the present Bail Application

No._______ /2024, in the interest of justice.

 4
4. At the outset, the Applicant humbly submits to this

Hon’ble Court that the present Intervener Applicant

has been heard by the Ld. Trial Court as well as the

Hon’ble Sessions Court in the present matter all

through-out and for that reason also, the present

Intervener Applicant is praying to this Hon’ble

Court to allow it to intervene in the present matter.

5. Before proceeding ahead, the Applicant states

that it is necessary to point out to the Hon’ble

Court a brief history of the present matter. The

same has been stated as under:

1. Applicant say that in the year 2015, Mr. Amol

Dongrikar along with his wife Mrs. Ananya Amol
Dongrikar floated a company named Mega India in
Dombivali at 108, Siddhi Vinayak Arcade, Beside
New Vishnu Nagar Police Station, Anand Nagar,
Dombivali (West), Thane - 421 202, wherein he
started contacting us to bring investment in his pilot
project of providing online services through an App
and for which Mr. Amol Dongrikar was in need of
funds. We state that Mr. Amol and Mrs. Ananya
were time and again, approaching us to provide
financial aid to fulfil their pilot project of coming
 5
with a mobile application for ancillary services such
as mobile recharge, air ticket booking, money
transfer and other allied services. We state that Mr.
Amol and Mrs. Ananya had also prepared a project
report showing huge profits and revenue if the App
would come in market.

2. Applicant state that to build trust upon us, he started

introducing us to some office investors who had
also invested in his pilot project of developing an
App for online services. We state that the investors
which were introduced by Mr. Amol and Mrs.
Ananya to win over our confidence has also
provided us with a financial report showing huge
profits so as to lure us into investing into his pilot
project of providing online services through his
App.

3. Applicant state that believing on the representation

given by Mr. Amol and Mrs. Ananya and his so-
called investors and looking at the project report
and the financial report, we agreed to invest our
money into his pilot project. We state that
thereafter, we started investing in his pilot project
and have also brought several investors to invest in
his pilot project of providing online services. We
state that till date, we have invested a sum of
 6
Rs.2,56,25,000/- (Rupees Two Crores Fifty-Six
Lakhs Twenty-Five Thousand Only) since 2015
for which various receipts and investment bonds
have been provided. We are enclosing the list of
investments made along with the amounts.

4. Applicant state that after the receipt of the amount,

we were approaching Mr. Amol and Mrs.
Ananya for the copy of the receipts and the progress
of the online services as assured by them. We state
that time and again, Mr. Amol and Mrs. Ananya
used to portray us that as the online services will be
used worldwide, he needs further investments in the
said pilot project and he was ready and willing to
give investment bonds, receipts. We state that Mr.
Amol and Mrs. Ananya have also portrayed us that
they have received Entrepreneurs Award 2017 in
the category of Business Development Consultants
to win over our confidence that we are taking right
decision in investing various amount to the tune of
Rs.2,56,25,000/-. We are enclosing a copy of the
brochure given by Mr. Amol and Mrs. Ananya.

5. Applicant state that Inspite of making various

investments to the tune of Rs.2,56,25,000/- and the
assurances given by Mr. Amol and Mrs. Ananya till
date, they have not started the online services as
 7
assured and guaranteed by them. We have made
several enquiries with Mr. Amol and Mrs. Ananya
but till date, they have been avoiding to give any
progress report or status of the online services as
assured would start after receiving investment.

6. Applicant state that Mr. Amol and Mrs. Ananya and

her associates were having full knowledge and
intention that they were never going to develop any
such online software and therefore, they made false
and misleading representation to invest into their
Company which never stated the work and has
dupped us to the tune of Rs.2,56,25,000/-. We state
that we have made repeated follow ups with Mr.
Amol and Mrs. Ananya for refund of the said
investments of Rs.2,56,25,000/- but to my utter
despair, we have been just receiving dates and till
date, not a single amount has been refunded back to
us.

7. Applicant state that we have lost our hard-earned

money due to the abovementioned scam created by
the abovementioned person.

8. Applicant state that after making various enquiries

that he had dupped in the same format several
investors who are also struggling to get the refund
of the amounts paid to him. We state that (i) Mr.
 8
Amol Krishna Dongrikar, (ii) Mrs. Ananya Amol
Dongrikar, (iii) Mega India, (iv) Prajwal Ventures,
(v) MMV Consultants Pvt. Ltd. and (vi) MMV
Financial Advisory Pvt. Ltd. are a threat to the
society who are held bent upon creating such bogus
and fictitious schemes to usurp the money of the
common man. We are therefore requested to take
immediate action in the above matter.

9. Applicant state that when we made enquiries about

the licenses obtained by(i) Mr. Amol Krishna
Dongrikar, (ii) Mrs. Ananya Amol Dongrikar, (iii)
Mega India, (iv) Prajwal Ventures, (v) MMV
Consultants Pvt. Ltd. and (vi) MMV Financial
Advisory Pvt. Ltd. it has come to our knowledge
that they have looted innocent customers by
showing forge and fabricated NBFC license
obtained from the Reserve Bank of India. We
further state that Mr. Amol and Mrs. Ananya have
purchased various benami properties out of the loot
money which they have generated by defrauding
customers by making them invest in their company
without any appropriate license.

10. Applicant further state that Mr. Amol and Mrs.

Ananya have committed a conspiracy by using their
following shell companies (i) Mega India, (ii)
 9
Prajwal Ventures, (iii) MMV Consultants Pvt. Ltd.
and (iv) MMV Financial Advisory Pvt. Ltd. to
generate disproportionate asset by creating fake
schemes and by also filing fake income tax returns
thereby running fictitious schemes to usurp the
money of the citizens of India.

11. Applicant state that (i) Mr. Amol Krishna

Dongrikar, (ii) Mrs. Ananya Amol Dongrikar, (iii)
Mega India, (iv) Prajwal Ventures, (v) MMV
Consultants Pvt. Ltd. and (vi) MMV Financial
Advisory Pvt. Ltd., have committed cheating,
forgery, by preparing false and bogus documents to
misappropriate our investments by making fictitious
entries in the books of accounts maintained by (i)
Mr. Amol Krishna Dongrikar, (ii) Mrs. Ananya
Amol Dongrikar, (iii) Mega India, (iv) Prajwal
Ventures, (v) MMV Consultants Pvt. Ltd. and (vi)
MMV Financial Advisory Pvt. Ltd. and
misappropriating our funds to the tune of Rs.
2,56,25,000/-.

12. The Intervener Applicant thereon, on 3/7/2023,

lodged a complaint vide C. R. No.0169/23 with the
Vishnu Nagar Police Station, Thane, u/s.420,406 &
r/w.34 of the IPC.
 10
13. The Intervener Applicant states that Amol
Dongrikar and Ananya Amol Dongrikar (the Orig.
Accused No.1 & 2) Amol Dongrikar is in custody.
The Intervener Applicant states that, Amol
Dongrikar (the Orig. Accused No.1, have filed a
Bail Application No ---/2024 before the Hon’ble
Session Court Kalyan, at Kalyan.

14. The Intervener Applicant states that being

aggrieved by the inquiry and investigation
conducted by the Senior Inspector of Police, Vishnu
Nagar Police station, Dombivali Wes, Thane.

15. The Intervener Applicant state that, accused persons

moved a Criminal Bail Application No.--------/2024
before the Hon’ble Session Court of Kalyan, on
--------. The Intervener Applicant craves leave of
this Hon’ble Court to refer and rely upon the said
Order as and when produced.

16. The Intervener Applicant states that the Bail

Application filed by the Accused persons contains

false and frivolous grounds and the same are

deserves to be rejected.

17. The Hon'ble Andhra Pradesh High Court in the

matter of Delta Car Pvt. Ltd. V/s. Sanjiv Shah

 11
reported in 2014 LAWS (APH) (7) 167, allowed the

defacto-complainant in assisting the prosecution to

come on record in bail petitions, in assisting the

prosecution and in bringing to the notice of the

court any relevant facts that fall for consideration in

deciding the bail applications on merits to sub serve

the ends of justice.

18. The Intervener Applicant also states that he has not

be supplied with a copy of the said Bail Application

No.____ /2024 and therefore humbly requests this

Hon’ble session Court to direct the Applicant to

supply a copy of the said Bail Application

No._____/2023 to the Intervener Applicant, in the

interests of justice and fair-play.

19. The Intervener Applicant humbly submits that in

the presence of the voluminous direct evidence and

materials in the present matter, and looking at the

history of the present matter, the present Intervener

 12
Applicant needs to be heard by this Hon’ble Court

to bring the true facts on record.

20. The Intervener Applicant states that there is no

question of Bail given the voluminous direct

evidence against the present Accused persons to

prove their crime. The Intervener Applicant further

humbly submits that at this stage of Bail

Application without testing the veracity of the

evidence of the prosecution and the investigation

agency, by holding a full-fledged Trial, it would not

be in the interests of justice to Bail Application the

Accused persons.

In the circumstances above, the Intervener Applicant

humbly PRAYS:

a. That this Hon’ble Court be pleased to allow the

present Intervener Applicant to intervene in the said

Bail Application No._____ of 2024;

 13
b. That this Hon’ble Court be pleased to hear the

present Intervener Applicant before deciding the

said Bail Application No.________ of 2024;

c. That the hearing of the main Bail Application

No.______ of 2024 be stayed till the decision of the

present Intervention Application of the present

Intervener Applicant;

d. That interim and ad-interim reliefs be granted in

terms of prayer clauses (a) to (c);

e. That such other and further reliefs be granted by

this Hon’ble Court as it may deem fit and proper in

the interests of justice and fair-play;

Solemnly affirmed at )
Mumbai this --th day )
of December, 2024. ) [ O.P.Saroiya]
Intervener Applicant

Identified & explained by me;

Before me;

[Shivkumar Mishra & Asha Bansode]

Advocate for the
Intervener Applicant
 14

VERIFICATION

I, Om Prakash Saroiya, an Indian Inhabitant, age

about 68 years, residing at: 305, Seth Heights, Opp.
Ashish Cinema, Chembur, Mumbai----- being the
Intervener Applicant above-named, solemnly declare that
what is stated in paragraphs 1 to --- is true to my own
knowledge, and that what is stated in the remaining
paragraphs -- and --of the Application is stated on
information, belief and legal advice and I believe the same
to be true.

Solemnly declared at )
Mumbai this --th day )
of December 2024. ) [ Omprakash Saroiya]
Intervener Applicant

Identified & explained by me;

Before me;

[ Shivkumar Mishra & Asha Bansode]

Advocate for the
Intervener Applicant