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2. Act(s): Section(s):
(1)IPC 1860 420
(2)IPC 1860 120B
(3)IPC 1860 406
(a) Name: SUNIL ALAGH (S/O) LATE SH KEWAL KRISHAN ALAGH
(b) Date/Year of Birth: 0 Nationality: INDIAN
(c) Passport No: Date of Issue: Place of Issue:
(d) Occupation:
(e) Address: 12-C,IL PALAZZO,LITTLE GIBBS ROAD,MALABIR HILL,MUMBAI - 400006
(1) RAGHU RAJ PURI
(2) SHIV RAJ PURI
(3) MRS DEEKSHA PURI
Sl. Property Type(Description) Est Value(Rs.) Status
FIRST INFORMATION REPORT
(Under Section 154 Cr.P.C. )
( Internet Copy )
1. District: CRIME AND RAILWAYS P.S: E.O.W YEAR: 2014 FIR NO: 0098 DATE: 26/08/2014
3. Occurence of Offence:

(a) Day: Tuesday Date From: 29/06/2014 Date To: 29/06/2014
Time Period: Time From: hrs Time To: hrs
(b) Information received at P.S: Date: 26/08/2014 Time: 16:00 hrs
(c) Daily Diary Reference : Entry No: 6A Time: 16:00 hrs
4. Type of Information: WRITTEN
5. Place of Occurrence:
(a) Direction and Distance from P.S: 0.00KM Beat No:
(b) Address: 1109, INDRAPRAKASH, 21 BARAKHAMBA RD,NEW DELHI
(c) In case, Outside the limit of the Police Station:
Name of P.S: District:
6. Complainant / Informant :

7. Details of Known / Suspected / Unknown accused with full particulars(attach separate sheet if necessary).:

8. Reason for delay in reporting by the complainant informant:
9. Particulars of properties stolen/ involved(attach separate sheet if necessary):

10. Total value of property stolen:
11. Inquest Report / U.D. Case No., if any:
12. F.I.R Contents(attach separate sheet,if required):
New Delhi Dated 25.08.2014. To, The DCP, PS Economic Offences Wing, Mandir Marg. SUBJECT: Criminal Complaint against Mr. Raghu Raj Puri.
Mr. Shiv Raj Puri and Mrs. Deeksha Puri and other unknown persons for the offences punishable under Section 120-B, 406, 420, and r/w 120-B of the
Indian Penal Code 1860. Dear Sir, 1. I, Sunil Alagh, S/o Late Sh. Kewal Krishan Alagh, R/o 12-C, IL Palazzo, Little Gibbs Road, Malabir Hill, Mumbai -
400006 am filing the present complaint against Mr. Raghu Raj Puri who is the managing director of Normans Martin Brokers Pvt. Ltd. having its C/o at
1109, Indraprakash, 21 Barakhamba Road, New Delhi -110001 and he alongwith his son Mr. Shiv Raj Puri and wife Mrs. Deeksha Puri are all resident of
Flat 5A, Building 10, Magnolia Complex, DLF, Phase V, Guragon. 2. I have known Mr. Raghu Raj Puri for the past several years now and have always
had very good family relations with him, his son Mr. Shiv Raj Puri and wife Mrs. Deeksha Puri. 3.On 30.06.2014, I had received a call from the cell
phone of Mr. Shiv Raj Puri, however it was Mr. Raghu Raj Puri who was on the line when I had picked up the said call and I believe Mr. Raghu Raj Puri
was in his office at Barakhamba Road at the time along with his son Mr. Shiv Raj Puri standing with him. Mr. Raghu Raj Puri sounded extremely worried
and informed me that it was regarding the residential plot at DLF that I and my wife Mrs. Maya Alagh own jointly and were planning to sell. He informed
me that the property dealer Mr. Rajan Grover, who we had contacted for the purpose of selling the said plot, was in fact a crook and had fraudulently sold
the said plot to 5 different persons at the same time and has further done some manipulation regarding the stamp duty to be paid, as a result of which
certain criminal cases have been registered and are pending in Gurgaon District court against me and my wife for cheating and fraud and we are likely to
be arrested at any given moment. 4. Subsequently, when I went home my wife informed me that she had received a call from a person a day before i.e.
29.6.2014 who told her that he is calling from the Gurgaon District Court and told her that she and I have to appear before the Court on 30.6.2014 as he
had visited our DLF house on 3 occasions to serve some papers, however no one was ever available. He further said that if we do not appear then he will
have to arrest us and bring us to Court.He also told her to call 9810952408 for details which she did not do. My wife also told me that she had requested
Mr.Shiv Raj Puri to send someone to our DLF house to collect any mail if it was delivered there. 5. On hearing the same I got extremely scared about my
and my wife's safety and called Mr. Shiv Raj Puri seeking more information and help. Mr. Raghu Raj Puri assured me that his son Mr. Shiv Raj Pun has
already been looking into the matter and has found a way to get me and wife out of this mess and avoid from getting arrested but for the same an amount
of Rs. 8,50,00,000/- [eight crores and fifty lakhs] is required immediately. 6. He told methat out of the said amount of Rs. 8,50,00,000/- a sum of Rs.
6,50,00,000/- [six crores and fifty lakhs] is required for depositing the same in the Gurgaon Court towards the Stamp Duty charges including penalty
equivalent to 5 times being levied by the Gurgaon Court. Further. the remaining amount was required towards the surety/bail bonds of Rs. 1,00,00,000/-
[one crore] each for me and my wife for getting anticipatory bail from Gurgaon Court. 7. Therefore, under the aforesaid facts and circumstances, I
believed the fraudulent and dishonest representations made bythe said personsto be true and immediately started collecting all the money I had which
included all my life savings and started sending them to Mr. Raghu Raj Purithrough RTGS in his bank account maintained at ING Vysya Bank, Karol
Bagh, New Delhi. I was categorically told by Mr. Raghu Raj Puri to deposit all the money in his Delhi Bank Account. 8. Thereafter, the said persons had
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(i) Registered the case and took up the investigation OR
(ii) Directed (Name of the I.O): Rank:
PIS Number: to take up the investigation ,OR
(iii)Refuse investigation due to: OR
(iv)Transferred to P.S(name): District:

called me again in the 2nd week of july and told me that there was a way for us to apply to the Court and inform the Court of how we have been
fraudulently trapped into the said case and that we had not done anything wrong. They had thereafter come discuss this further at myMaurya Hotel, New
Delhi where I was staying during my visit to Delhi. The said persons told me that by doing so we can seek compensation from the Court and will be able
to get my money back alongwith a compensation which could go upto several crores. However, he told me that for the said purpose I will have to pay
Court fees of an amount of Rs. 65,00,000/-[sixty five lakhs] each for me and my wife, but also assured that I will get it back in no time. He also issued two
reverse cheques dated 21.7.2014 in my favour for Rs. 65,00,000/-[sixty five lakhs] each as his guarantee of the afore-said happening and for indemnifying
me from suffering any loss. The said action on his part made me believe that he was genuinely looking after my well being and believing his further
fraudulent and dishonest representations to be true, I started collecting more money to give it to the said persons. 9. Subsequently, my wife and I had
received another call from Mr. Shiv Raj Puri on 27.07.2014 and he informed me that the criminal case pending at Gurgaon Court had been transferred to
the Tis Hazari Court in New Delhi as the Enforcement Directorate has got involved and it was extremely important for us to take Bail from the said court
as soon as possible. He told me that the Court has asked for surety/bail bonds for both me and wife for an amount of Rs. 2,00,00,000/- [two crores] each
and it has to be paid at the earliest as otherwise we will be arrested. 10. Believing his further fraudulent and dishonest representations to be true, I started
collecting more money to somehow match up for the said demand. I after completely running out of my life savings and having no other choice left, had
taken a loan of Rs. 75,00,000/- [seventy five lakhs] from my going to be Samdhi [son in law's father] Mr. Ashok Goel and an amount of Rs. 1,25,00,000/-
[one crore twenty five lakhs] from my son in law Mr. Sameer Nair. However, even after taking the aforesaid loan the total amount that I could arrange was
to the tune of Rs. 13,15,00,000/- [Thirteen crores and fifteen lakhs]. Although I was still short of Rs.65,00,000/-, Mr. Shiv Raj Puri told me that I was like
a father to him and I need not worry about it and that he will arrange the said amount from his own sources. The details of all the transactions alongwith
the RTGS details made in favour of Mr. Raghu Raj Puriat ING Vyasya Bank, Karolbagh, New Delhi, have been annexed herewith and marked as
ANNEXURE 1. 11. On 30th July. 2014 morning Mr. ShivrajPuricame to ITC Maurya hotel where I was staying and took me with him to meet Mr.
Vinod Kumar of the Enforcement and Police Inspector Jagdish at Hotel Acura opposite the Gurgaon Court. Mr. Raghu Raj Puri also joined us at Hotel
Acura where I was made to meet Mr. Vinod Kumarwho simply shook my hand and simply told me not to worry. Mr Vinod Kumar did not discuss
anything about the case as Mr. Sine' Raj Puri and Mr. Raghu Raj Puri had some conversation with him in private. Thereafter, Mr. Raghu Raj Puri had
called my wife and conveyed that the matter had been taken care off and all money will be returned within a weeks time. He also mentioned that Mr. Shiv
Raj Purihad taken me to sign my presence in Court and to meet the ED in Delhi. After that Mr. Shiv Raj Puri and Inspector Jagdish made me sign my
presence in the court on a blank sheet of paper when the court Reader was present but the Judge was not. Thereafter, Mr. Shiv Raj Puri took me to meet
the Deputy Director Enforcements in Delhi. Mr. R.B. Singh. Mr. Shiv Raj Puri made me wait outside while he went inside to meet Mr. Singh alone saying
that he will discuss the Tis Hazari matter with him. Then after sometime Mr. Shiv Raj Puri came outside and took me inside with him to meet Mr. Singh.
Mr. Singh did not ask me any questions but said he was glad to meet me. After that Mr. Shiv Raj Puritold me that Mr. Singh was happy with the case and
he was going to give a positive report stating that we were not involved in the offences committed by Mr. Rajan Grover and we were in fact completely
innocent. 12. By this time, I had asked RaghurajPuri and ShivrajPuri several times to give me the papers for the said criminal cases and details thereof.
Despite the number of assurances being given to me, the aforesaid persons did not provide me with even a single document till the first week of August
2014. I. therefore tried to find out the details of the said cases myself, but to my utter shock and surprise, I was informed that there was no such criminal
case ever pending against me or my wife in either Gurgaon District Court or the Tis Hazari Court. I was further shocked to learn that Mr. Shiv Raj Puri
was a habitual criminal and had been convicted in the Citibank fraud case and had cheated the said bank for an amount more than 300 crores. 13. It is at
this point that I realized that the said persons in conspiracy with eachother and other unknown personsand in furtherance of a well thought of `criminal
conspiracy have cheated me and misappropriated the sum of Rs. 13,15,00,000/- [Thirteen crores and fifteen lakhs]. 14. Therefore, I alongwith my wife
went to the house of the accused persons in DLF on 16.08.2014 and without disclosing to them that I was now aware of the fraud they had played on me, I
only inquired from them about the money given to them and told them I needed it back urgently as I am in a lot of debt and that my house would be
attached by the bank if I am not able to arrange for the funds as soon as possible. Falling into the trap and without realizing that I was recording the entire
conversation, Mr. Shiv Raj Puri stated and re-affirmed that the entire money has been paid in the Court in the afore-stated manner and will be able to get it
back from the Courts shortly, as the said cases were now over. Moreover, the said persons in order to further keep me in the dark and keep believing their
false representations to be true, issued several current dated and post-dated cheques in my favour towards discharge of their liability to return the entire
amount of Rs. 13,15,00,000/- [Thirteen crores and fifteen lakhsl paid by me. The details of all the ehequesalongwith copies of all the said cheques issued
in my favour have been annexed herewith and marked as ANNEXURE 2 to this complaint. 15. Thereafter, I alongwith my wife had gone to their house
again on 17.8.2014 and 18.8.2014 and had recorded the said conversations, wherein Mr. Raghu Raj Puri and Mr. Shiv Raj Purihave clearly admitted their
liability to pay me the said amount in its entirety and had assured me that they would honour it completely. I have transferred the said audio recordings
from my phone on to a computer and from there onto two 4 different CD's.A copy of all the 4 CD's have been annexed herewith and marked as
ANNEXURE 3 to this complaint. 16. I although was certain about the fact that the said cheques would be returned by the bank for one reason or the
other. I had still put them for clearing in the bank and as expected, all the cheques were returned unpaid by my bank. As such, I have not received even a
single penny of my money back from the said persons till date. A copy of the bounced cheques alongwith the letter issued by the Bank have been annexed
herewith and marked as ANNEXURE 4 to this complaint. 17. Out of all the cheques issued by RaghurajPuri and ShivrajPuri, two cheques are for
31.08.2014 and I will depositthem in the bank only after that, however I am certain that the said cheques would also be returned by the bank as unpaid and
would be of no consequence. 18. It is thus extremely clear that the said persons acting in conspiracy with each other had entered into a criminal conspiracy
with eachother and other unknown persons, the purpose of which was to cheat me, and thereby. cause wrongful gain to themselves and wrongful loss to
me to the tune of Rs. 13,15,00,000-[Thirteen crores and fifteen lakhs]. 19. The said persons acting in conspiracy with each other and with dishonest and
fraudulent intentions have misappropriated the said money for their own use and benefit and have cheated me of the said amount of approximately Rs.
13,15,00,000/- [Thirteen crores and fifteen lakhs]. The said persons have together committed various offences of conspiracy, misappropriation, criminal
breach of trust and cheating within the jurisdiction of your Police Station, the same being cognizable offences. 20. I, therefore, on behalf of our company
your goodself to register an FIR against the aforesaid accused persons and proceed according to law. Yours faithfully Sunil Alagh Sd/- English.To, The
Duty officer, PS Economic Offences Wing, Crime Branch, Mandir Marg, New Delhi. Since contents of the complaint and material placed on record,
prima facie disclosures the commission of cognizable offences punishable under section 406/420/120-B IPC. Hence, a case under above sections of law
may please be registered and investigation of the be handed over to the undersigned. It has the approval of senior officers. Date and time of occurrence
29 June 2014. Place of occurrence -1109, Indraprakash, 21 Barakhamba Road, New Delhi. Date and time of departure of rukka- 26.08.2014 at 1600 hrs.
Sd/- English 26.8.14 SI Bhagwan Singh, No. D-966, PIS No.- 16970094, Section-V/EOW, Delhi.Action taken at police station at this time iSI Bhagwan
Singh, No. D-966, PIS No.- 16970094, Section-V/EOWcame in the police station and produced the above mention complaint for registration of case. Case
has been registered and original rukka along with copy of FIR has been handed over to time iSI Bhagwan Singh, No. D-966, PIS No.- 16970094, Section-
V/EOW, for further investigation. Copy of FIR will be sent to concerned officer through DAK.SI/DO
13. Action Taken (Since the above information reveals commission of offence(s) u/s as mentioned at item no.2 :

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on point of jurisdiction.
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
:
R.O.A.C:
14.

Signature / Thumb Impression of The Complainant / Informant : Signature of Officer
NAME BABU KHAN
RANK SI
PIS NUMBER 28760146
15. Date and Time of despatch to the court: