Additional Affidavit in respect of the Writ Petition against RBI in the first leasing scam

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S.B. Civil Wril Petition No. 1 190/2'014
Trideep RRnj Bhandari u. Reserue Bonk ofl~rtlir&: JO m
A/lnilio~~alA$dauitin S~ppnrot / Writ I-'e/iljo//
IN THE HIGH COURT OF JUDICATURE FOR RAJASTHAN
AT JODHPUR
S.B. CIVIL WRIT PETITION NO. 1190/2014
1
Petitioner:
Trideep Raj Bhandari
Respondents:
Reserve Bank of India & Ors.
1
ADDITIONAL AFFIDAVIT IN SUPPORT OF WRIT PETITION
I, Trideep Raj Bhandari s/o Shri Tribhuwan Raj Bhandari
I
aged - years, resident of "Gulab Vaatika", Paota 'By Road,
Jodhpur do hereby state on oath as under:
1) That I am .the Petitioner in the present Writ Petition and
completely well versed with the facts and circumstances of
the present case.
2) That it is humbly submitted that this affidavit may be
considered supplemental to and in addition to the
averments, whether factual or legal, already set out in the
writ petition.
3) That this affidavit is being filed while reserving the liberty
to file a detailed rejoinder to the reply submitted by the
Reserve Bank of India.
4) That the present writ petition has been filed with the intent
of seeking pin pointed relief in terms of Chapter V of the
Reserve Bank of India Act, 1934 as also with the clear

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'S.B. Ciud Wrif Pefition No. 1.190/20 14
Ttineep Raj Bbandari v. Re~erueB ank ofI~da& O~J.
AdlitiotzalA$;daM'f in Supporf of Wriic Petifion
averment that a financial scam of the magnitude of Rs.
1600 crore or more in a Non-Banking Financial Company
(hereinafter referred to as "NBFC") could not have taken
place without the involvement of the officials of supervising
regulator i.e. the Reserve Bank of India (hereinafter
referred to as "RBI") in the instant case. Accordingly, a
a
supplementary prayer of affixing responsibility on the
responsible officers of RBI has been made.
5) That furthermore, it is also clear and apparent from the
contents of the writ petition read along with annexures
thereto that financial irregularities in M/s. First Leasing
Company of India Ltd. were going on for years together for
reasons of inter alia negligence/involvement of the
responsible officers of the Reserve Bank of India, only for
which reason could M/s. First Leasing Company of India
Ltd. project a rosy picture all,.over the country and allure
me and other shareholders "and depositors etc. into
purchasing its equity shares and otherwise invest in
deposits etc. of the Company, which has went on for years.
6) That at the very outset and without getting into the niceties
of this writ petition, it would suffice to mention that I am a
resident of Jodhpur (Rajasthan). I was allured into
purchasing equity shares of M/s. First Leasing Company of
India Ltd. by the false rosy picture projected by the said
company all over the internet (and other mass media
instruments like financial newspapers etc.) and in its
annual reports, credit rating reports etc., all of which were
available to be read over the internet at various places
including the company's own website
www.firstleasingindia.com as also websites of stock
exchanges etc. and other public domains. These shares
were purchased by me at Jodhpur (Rajasthan) through the
branch office of M/s. Mehta Equities Ltd. situated at 108,