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6. It is further submitted that Respondent No.1 stated in the plaint in suit C. S. (OS) No. 1877/2011 that all the aforesaid original documents were in possession of Respondent No. 2. It is stated that Power of Attorney alleged to have been registered as Document No.7, Book No.I, Volume No.4, pages 13­18 registered on 16.04.1983 by one Sh. Purshottam Nagesh Oak in favour of Sh. Balbir Gambhir reveals that the said document was registered at Pingla, District Medinipur Paschim, West Bengal and another Deed of Power of Attorney is registered as Document No.13, Book No.IV, Volume No.41, pages 27­31 registered on 16.02.2002 by Sh. Balbir Gambhir in favour of Sh. Naresh Kumar is also registered from the same place. It is submitted that on verification complainant learnt that the Sub­Registrar Office at Paschim Medinipur was established in August, 2001 only and as such the documents which are alleged to be registered at the Sub­Registrar Office at Paschim Medinipur in the year 1983 were forged and fabricated documents and consequently, the GPA dated 16.02.2002 is also forged and fabricated. It is learnt by the complainant that the division of District Medinipur as Paschim and Purva (West and East) took place only in January, 2001 and prior to that it was only Medinipur and not East or West Medinipur as stated in the plaint of C. S. (OS) No. 1877/2011 and therefore, on the face of it, document procured and filed by the accused persons therein are forged, false, fabricated and unauthentic.

7. It is stated that signatures of Sh.Purshotam Nagesh Oak and Sh.Balbir Ram Avtar Vs. Naresh Kumar & Ors. ­ CR No. 30 of 2012 3/5 ID No. 02406R0102152012 Gambhir on all the alleged documents fabricated by the accused persons are forged in order to procure title documents and to doubt the right or tittle of the Complainant in the property in question. It is further stated that no seal or stamp of alleged registration of the document was affixed on any of the documents fabricated by the accused persons except the alleged sale deed dated 02.07.2011, which shows the existing multi­storey building of complainant as a vacant plot. It is stated that Respondent No.1 & Respondent No.2 in furtherance of their common intention and conspiracy among themselves, falsely created a Memorandum of Understanding (MOU) dated 29.06.2001 after execution of sale deed between them on 28.06.2001. It is stated that Respondent No. 2 to Respondent No. 5 in collusion and in conspiracy with each other have helped and assisted the Respondent no. 1 to create the forged and fabricated document and have counterfeited the official seal of the Sub­Registrar, Pingla, West Bengal so that they can fraudulently and dishonestly use the forged documents as genuine.