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1. In this Public Interest Litigation (PIL), the petitioner, inter alia; is seeking an investigation by CBI or an SIT into the alleged fraud bank guarantees furnished by respondent No.3 - Megha Engineering Infrastructure Ltd. (MEIL) which has been accepted by respondent No.1 i.e. Mumbai Metropolitan Region Development Authority (MMRDA). The challenge to the bank guarantees is made on the ground that the same have been issued by the Euro Exim Bank, which is neither a scheduled bank nor a commercial bank, approved by the Reserve Bank of India. The petitioner also seeks a direction to the MMRDA to cancel the contract awarded to MEIL. The facts leading to filing of this PIL need mention, which are stated infra.

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(I)          FACTS:

2. A Request for Proposal (RFP) was issued on 12th May 2023 for construction of a twin tube road tunnel between Thane and Borivali in Mumbai. The MEIL, in the aforesaid RFP, was declared the preferred bidder and on 8th May 2023, a Letter of Acceptance (LoA) was issued to it. The MEIL furnished performance bank guarantee for a sum of Rs.92.67 crores and Rs.88.18 crores, issued by Canara Bank for the project in question. The MEIL has also furnished the performance bank guarantees issued by Euro Exim Bank.

12. It is also urged that in case, this Court comes to a conclusion that the petitioner is an inappropriate person to take forward the proceeding of this PIL, this Court must appoint an Amicus to forward this PIL, as it raises a genuine issue. It is submitted that the petitioner has complied with the mandate contained in Rule 5 and 7 of the Rules 2010 framed by this Court.

(IV) REJOINDER REPLY:

13. By way of rejoinder reply, learned Counsel for MEIL submitted that in the reply filed to the preliminary objection, it has not been stated that the petitioner had removed tweets from social media platform. It is contended that the defence of removal of tweets is an after-thought. Learned Solicitor General has pointed out that the tender was issued in which MEIL has been emerged as a highest bidder. It is contended that the MEIL has furnished performance bank guarantees which were issued by Canara Bank i.e. the scheduled bank and the bank guarantees furnished by the Euro Exim Bank have been authenticated by the Bank of Maharashtra and the Bank of India. It is submitted that filing of the instant writ petition, in the facts and circumstances of the case, amounts to gross abuse of process of law.


                                                                d) Impleadment
                                                                Petition has been
                                                                filed seeking to

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                                                                add RTV and the
                                                                Petitioner      as

                                                                and 22 in O.S. No.
                                                                510/2022. Notice
                                                                has been issued.

                                                                The       relevant
                                                                screenshots    are
                                                                annexed herewith
                                                                as Exhibits A-1
                                                                to    A-5.     The
                                                                Answering
                                                                Respondent
                                                                craves leave of
                                                                this Hon'ble Court
                                                                to refer to the
                                                                relevant    videos
                                                                when produced.

 3         CC No.501/2023 filed     The petitioner is not a     In the Criminal
           by MEIL in II Junior     party to the said           Complaint,     "Toli
           Civil Judge cum XIII     private complaint. As       velugu"    is    an
           MM Court, Kukatpally     per the case status         accused. As stated
           against Tolivelugu &     available on e-courts       above,         "Toli
           Gajjala     Narsimha     the petitioner is not a     velugu"     is    a
           Reddy             for    party to proceedings.       product of RTV.
           defamation.              Hence allegation of
                                    suppression           is
                                    unfounded           and
                                    baseless          since
                                    petitioner   has     no
                                    relation with the said
                                    matter.

 4         Criminal Defamation      The petitioner is not a
           CC       No.501/2023     party to the said
           titled    MEIL     V.    criminal defamation                    -----
           Tolivelugu & Gajjala     suit.           Hence,
           Narsimha Reddy filed     allegation           of
           before II Junior Civil   suppression           is
           Judge cum XIII MM        unfounded           and
           Court, Kukatpally.       baseless          since
                                    petitioner   has     no
                                    relation with the said
                                    matter.

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 5         Cyber       Complaint    MEIL is not a party to     Petitioner claims
           No.99/2019     under     the said proceedings.      that MEIL is not a
           sec 406 IPC and sec      Petitioner is initially    party to the said
           66D IT Act.              not     arrayed     as     proceedings.
                                    accused in the FIR 99      However,
                                    of 2019. Later on,         complaint       has
                                    the Petitioner was         been     filed   by
                                    arrayed as accused.        Associated
                                    The petitioner had         Broadcasting Co.
                                    filed quashing vide        Ltd. ("ABCL") in
                                    CRLP     No.6622     of    which           the
                                    2019               and     Answering
                                    investigation     was      Respondent has a
                                    stayed by the Hon'ble      substantial
                                    High     Court     and     interest as set out
                                    currently the matter       in Row 7 below
                                    is coming up for           and Exhibit-C of
                                    adjudication.      The     Interlocutory
                                    Complainant is one T.      Application.
                                    Krishna        Prasad,
                                    representative       of
                                    iVision Media India
                                    Private Limited.

 6         ED Proceedings under MEIL is not a party to These proceedings
           PMLA    qua     ECIR the said proceedings. are also initiated
           No.17/HYZO of 2020.                         by ABCL.
                                The Complainant in
                                FIR 900 of 2019
                                (predicate offence) is
                                Associated
                                Broadcasting
                                Company        Private
                                Limited          (TV9
                                Company) and not
                                MEIL.     FIR No.900
                                has been closed by
                                the police.

                                    Petitioner's quashing
                                    petition for quashing
                                    of ECIR No.17/HYZO
                                    is currently pending
                                    adjudication.



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 7         FIR/Crime                The petitioner is not      FIR was filed by a
           No.373/2022 filed by     an accused in this FIR     Director         of
           Mr.     Ch     Pedda     and no summons has         Answering
           Subbaiah                 been issued to him.        Respondent
           u/s.505(1)(b)(c),        Hence allegation of        against        "Toli
           505(2), 506, 504,        suppression          is    velugu" and the
           120B of IPC with PS      unfounded          and     PIL Petitioner.
           Balanagar.               baseless         since
                                    petitioner   has    no     The     said   FIRs
                                    relation with the said     specifically states
                                    matter.                    that Petitioner is
                                                               promoter of "Toli
                                                               velugu."

                                                               The      Answering
                                                               Respondent        on
                                                               24.02.2025
                                                               received
                                                               knowledge       that
                                                               the investigating
                                                               officer has filed a
                                                               closure report.

 8         FIR/Crime                The petitioner is not      PIL      Petitioner
           No.371/2022 filed by     an accused in this FIR     again     misleads
           MEIL                     and no summons has         that he is not
           u/s.505(1)(b)(c),        been issued to him.        aware of this case.
           505(2), 506, 504,        Hence allegation of
           120B of IPC with PS      suppression          is    The said case is
           Balanagar.               unfounded          and     filed against "Toli
                                    baseless         since     Velugu" and PIL
                                    petitioner   has    no     Petitioner,   who
                                    relation with the said     are Accused Nos.
                                    matter.                    1 and 2.

                                                               In the said FIR,
                                                               Chargesheet was
                                                               filed  and     the
                                                               concerned    court
                                                               had         taken
                                                               cognizance of the
                                                               same.

 9         CP No. 310/24/HBD/ MEIL is not party in The PIL Petitioner
           2019 before NCLT, the    said  dispute. mischievously
           Hyderabad          Hence allegation of claims that there

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                                    suppression          is     is no suppression
                                    unfounded          and      of this litigation.
                                    baseless         since      The said Petition
                                    respondent has no           was filed in NCLT
                                    relation with the said      by the Petitioner
                                    dispute.                    against     Alanda
                                                                Media.
                                    Respondent No.3 is
                                    not a party to the          Answering
                                    litigation in NCLT or       Respondent, holds
                                    NCLAT and is not an         through its wholly
                                    owner      of   Alanda      owned subsidiary
                                    Media, therefore, it        (MEIL Holdings), a
                                    cannot be said that         substantial
                                    the      dispute      is    interest in Alanda
                                    between       petitioner    Media,     wherein
                                    and MEIL.                   Answering
                                                                Respondents

                                    debentures,       debt      Optionally
                                    instruments,         in     Convertible
                                    Alanda Media and has        Debentures worth
                                    no equity shares. As        INR 259 Crores.
                                    such MEIL cannot
                                    claim ownership in
                                    Alanda Media or in
                                    TV9 as both are
                                    corporate      entities
                                    especially basing on
                                    the        debentures
                                    purchased by them.

                                    Respondent No.3 is
                                    only using it as a
                                    ground to question
                                    maintainability of the
                                    instant petition, since
                                    it has no argument on
                                    merit with regard to
                                    fraud             bank
                                    guarantees furnished
                                    by it. Disclosure of
                                    this information has
                                    no legal nexus with
                                    the issue involved in
                                    the instant public

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                                         interest litigation and
                                         hence the petitioner
                                         is not duty-bound to
                                         divulge           every
                                         litigation he is party
                                         to.


           Delhi High Court                                         admits that there
                                                                    is          ongoing
                                                                    litigation between
                                                                    MEIL      and     the
                                                                    petitioner. In the
                                                                    said     suit,    the
                                                                    answering
                                                                    Respondent        has
                                                                    sued      the     PIL
                                                                    petitioner on the
                                                                    issuing         bank
                                                                    guarantees from
                                                                    Euro Exim Bank.
                                                                    However,
                                                                    admittedly, does
                                                                    not disclose the
                                                                    required details of
                                                                    the said litigation
                                                                    in his purported
                                                                    PIL.