BEFORE THE HON’BLE COURT OF JUDICIAL MAGISTRATE

FIRST CLASS PUNE, AT PUNE

Criminal M. A. No. /2024

VED PRAKASH VERMA

Age about 33 years. Service – IT Professional
Address : Survey No. 16/1 Near New COMPLAINANT
Durga Hotel, Vadgaon Shide Road,
Narayan Park, Lane No. 3 Lohgaon, Pune.
Mobile No. 7706535136
Verses

1) STATE OF MAHARASTRA
(Summons to be served on
The Public Prosecuter
Shivajinagar Court Compound,
Shivajinagar, Pune – 411005)

2) THE POLICE INSPECTOR RESPONDANTS

___________________________
(Summons to be served on
The Public Prosecuter
Shivajinagar Court Compound,
Shivajinagar, Pune – 411005)

APPLICATION UNDER SECTION 457 OF THE CODE OF CRIMINAL

PROCEDURE, 1973

THE COMPLAINANT ABOVE MENTIONED, MOST RESPECTFULLY SHOWETH:

1. That, the Complainant is about the age of 33 years and resides on the Survey No.
16/1 Near New Durga Hotel, Vadgaon Shide Road, Narayan Park, Lane No. 3
Lohgaon, Pune, along with his family, having Aadhar Number 2603-2060-0998.
That, the complainant is an IT Professional working in Trayan Corporatioon.
That, on 22/11/2023, the complainant received a whatsapp message from the
Mobile No. +916901389976 displaying from the Inthira HR Manager from
Influencer Marketing Hub and under it there was an online job which offered
Rs.4000. That, the complainant replied “OK” for the above said message. That,
the complainant was then asked to go to https://t.me/Soniya658 on Telegram,
thereafter verifying the bank account for which the complainant received an
 award of Rs.160. Later the complainant was added to A1105 KINNECT PART-
TME JOB on Telegram app and was paid Rs.1,000/- on completion on the task.

2. That, the complainant then received a message offering 30 to 40 percent

commission on investment of Rs.5000 in Bit-coin and the complainant paid
Rs.5000 and Rs.5100 through different transaction through his ICICI bank
account number 055801577466 to Radhe Radhe Enterprises. The receipt of the
said transaction is herein marked and annexed as ANNEXURE NO. A1 and A2
to this application.

3. That, on 23/11/2023 the complainant asked for the return of money and he was
told to become a permanent member by transferring Rs. 10000 to Swapnil’s
Account 054605005375, which the complainant paid. .Then 47,000/- to Tumhas
Olini's Bank Account 020202204902 to complete task and Rs.1,37,000/- back to
Onilini's bank account to complete it and later then told me on the same day
Rs.5,40,000 in Olineb's bank account no.745105500798. That, the complainant
was told that, he will get all his money back. The receipt of the said transaction is
herein marked and annexed as ANNEXURE NO. B1,B2,B3 and B4 to this
application.

4. That, on 24/11/2023 the complainant received a message That, the money

couldn’t get refunded due to some problem for which he need to pay Rs.5,40,000
in bank account no. 370505500207, the amount was promptly by the complainant.
The receipt of the said transaction is herein marked and annexed as ANNEXURE
NO. C1 to this application.

5. That, On 25/11/2023 the complainant was told That, he is going to get all the
money till date but for That, he needs to deposit Rs.9,10,000 in bank account no.
751105000086. Rs.9,10,000 and later Rs. 10,00,000 in bank account no.
624005501744, which was deposited by the complainant. After That, he was told
to transfer Rs.50,000 to Devaragoli's UPI bank account, 8105404516axis@ybl, to
complete the task. He was further asked to send money to Muskan Surana to
complete the task again UPI IK transaction no. 332908869460 told to deposit
Rs.25,000, and transfer Rs. 25,000 to bank account no. 196501507923 to
complete the task of Olinesh. Then Rs.3,000/- through UPI Transaction ID No.
3332055020201 has deposited in the account of Soni Sharma. Later Rs.4580 in
bank account no. 773605500003 on 28/11/2023.That, all the above said amount
was transferred by the complainant. The receipt of the said transaction is herein
marked and annexed as ANNEXURE NO. D1,D2,D3,D4,D5,D6 and D7 to this
application.

6. That, on 29/11/2023 the complainant was again told to transfer Rs.3000 and
Rs.2000 to Dream Stay Hotel’ Punjab National Bank account 0319 to complete
your task. That, now the complainant was told to complete the last step to get his
money back is to transfer Rs. 14,00,000 to bank account no. 658205603139 which
 the complainant paid. After a while the complainant was axed to transfer
Rs.25,800 in bank account no. 131805001690 and then Rs.74980 on account
number 726705500060. That, later the complainant was asked to deposit
Rs.200,000 on bank account 777705700679 and after depositing the money the
complainant will get the full amount in his bank account. The series of amounts
were paid by the complainant. The receipt of the said transaction is herein marked
and annexed as ANNEXURE NO. E1,E2,E3,E4,E5 and E6 to this application.

7. That, despite multiple assurances of repayment and compensation, the

complainant did not received any refund or compensation for the losses incurred
due to this deceitful scheme. That, the complainant then went to the Pune City
Cyber Police Station and filed an FIR against the fraudsters. The copy of the FIR
is herein marked and annexed as ANNEXURE NO. F to this application.

8. That, the police, during the investigation, has frozen the bank accounts in which
the transaction was made.

9. That, given the circumstances of the case it has become just, fair, necessary in the
interest of justice and equity that, the amount of money present in the accounts
frozen by the police during the investigation must be given to the complainant.
Although the restitution of the misappropriated funds to the complainant cannot
fully restore them to their preexisting state, it undeniably serves to ameliorate
their circumstances to some extent. Hence, the present application for the reliefs,
as prayed for.

PRAYER

The complainant therefore humbly prays for the following reliefs:

1. That the investigating officer may kindly be directed to defreeze the account and
transfer the amount of money to the complainant.

2. Ordering the restitution of the entire amount mentioned above, along with suitable
compensation for the mental agony and financial losses suffered due to the
fraudulent activities of the accused.

3. For any other just and reasonable order to meet the end of justice.

Pune COMPLAINANT
Date-