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19. It is further submitted that as per the terms of Section 177 CrPC., every offence shall ordinarily be inquired into and tried by a Court within whose local jurisdiction it was committed. The Crime Branch, Delhi Police lacks territorial jurisdiction to investigate the present case, as the alleged offences of manufacturing, repackaging, labelling, and storage of spurious medicines, took place entirely outside Delhi, specifically in Gannaur Sonepat, Haryana and Loni, Ghaziabad, U.P., Noida, and parts of Gurugram and West Bengal. Moreover, as per the allegations, the money earned from the criminal activities, has also not travelled to Delhi. It has been used to purchase property in Gurugram, Durgapur West Bengal. Pertinently, the Chargesheet cites 16 victims, out of the which14 victims do not belong to Delhi.

48. Thereafter, the Applicant along with his other associates, allegedly started manufacturing spurious medicines used in treatment of Cancer. In the beginning, for packaging of the spurious medicines, they allegedly used the house of one co-accused Aakash Tomar at Krishna Vihar, Loni. Further, the accused persons procured the raw material from different sources and got the Tablets and Capsules prepared from co-accused Harbir who was resident of Murthal, Sonepat, Haryana.

49. At the instance of the arrested accused persons, a further recovery of huge quantity of spurious medicines, worth approximately Rs. 4.78 crores, was effected from their godown situated at 314, Sector-8, Tronica City, Loni Ghaziabad. On 12.11.2022, co-accused Harbir was arrested, who used to run a Manufacturing Unit in the name of M/s RMD Biotech at Ganaur, Sonepat. During interrogation, co-accused Ram Kumar @ Harbir disclosed that for manufacturing of spurious medicines, he used Maize Starch Powder & Calcium Carbonate and procured the strips & foil for printing from Dehradun. He disclosed, that as per the direction and demand of the Applicant, he collected 1 Lakh Incepta Company capsules shells from one Aekansh Verma, Zirakpur, Punjab, out of which he filled 13,500 Tablets of Incepta Company in his Manufacturing Unit.

50. He further disclosed that for manufacturing the spurious medicines, he used Tablet Compressor Making Machine, capsule filling machine & Alu- Alu Packing Machine. He used to procure the raw material, foil paper, etc. from Sonepat and Ambala in Haryana. A recovery of empty capsules shells of Incepta Company, approximately worth Rs. 80,000/- and Tablet Compressor Making Machine, capsule filling machine and Alu-Alu packing machine, was made from the Manufacturing Unit of co-accused Harbir.