The FIR lodged by Anil Motihar, managing director of Kee Pharma Ltd., alleges Dr. Braja Sundar Pradhan and his associates of cheating the company out of approximately Rs. 7.50 crores through misrepresentation, fraud, and breach of trust. The complaint details various fraudulent activities, including unauthorized patent filings and misappropriation of funds meant for research and development. Following the submission, a case has been registered under sections 406, 420, and 120B of the IPC for further investigation.

1. CIPA-R1.1100
FIRST INFORMATION REPORT
(Under Section 154 Cr.P.C.)
1. District: Crime &
Railway
PS.: ECO OMIC OFFENCES
WING
Year: 20 I 5 FIR No.:
1 7
Date: 10-02-2015
2. Act(s):
(i) IPC 1860
(Ii)
(ii i)
(iv)
Section(s):
406/4201120B
3. Occurrence of Offence:
{a)-Day:--Satur d ay Date From: 07-04-2007 Date To: 10-02-2015
Time To:
Time: 14:30 hrs
Time: 14:30 hrs
Time From:Time Period:
(b) Information received at P.S:
(c) General Diary Reference:
4. Type of Information: WRITTEN
5. Place of Occurrence:
(a) Direction and Distance from P.S:
(b) Address: NOT KNOWN, NOT KNOWN
(c) In case, Outside the limit of the Police Station:
Name of P.S:
Date: 10-02-20 15
Entry No.: 6A
Beat No.:
District:
6. Complainant/Informant:
(a) Name: ANIL MOTIHAR MANAGING DIRECTOR
(b) Date/Year of Birth: Nationality: INDIA
(c) Passport No. Date of Issue: Place of Issue:
(d) Occupation:
(e) Address: MIS KEE PHARMA LTD.A- 1, COMMUNITY CENTRE, NARAINA IN"1)lj"STRIAL AREA PH
7. Details of Known/Suspect/Unknown accused with full particulars(attach separate sheet if necessary): (2)
(i) DR BRAJA SUNDER PRADHAN
(RIO)
(ii) MRS RASHMI PRADHAN
(RIO)
(iii)
8. Reason for delay in reporting by the complainantlinformant: NO DELAY
9. Particulars of the properties stolen/involved(attach separate sheet if necessary):
SLNo. Property Type(Descrlption) Est. Value(Rs.) Status
(i)
(ii)
(ili)
10 . Toial value of property stolen:
11 . Inquest Report/U.D Case No., if any:
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,

2. District: Crime &
Railway
P.5.: ECONOMIC OFFENCES
WING
Year: 2015 FIR
No.: I 7
Date: 10-02-
2015
12 . F.I.R Contents(aUach separate sheet,lf required):
To, The Commissioner of Police, Delhi Sub:- Complaint against Dr.
Braja Sunder Pradhan and his associates Sir, The undersigned is
the Managing Director of M/s Kee pharma Ltd. which has its
registered office at A- 1, Community Centre, Naraina Industrial
Area Phase -I New Delhi 110028, India (in short Kee Pharma). We
deal in Pharmaceutical and Diagnostic Products. Through cheating,
mis-representation, mis-appropriation, fraud, embezzlement,
cy~na_ breac of trust, forgery, interpolation and money
_=- --==:---- --.:..:;:=~::::-c::-:. t: -J_. 3::::-a-a :.:::.caY" ?radhan and his wife
_~s. ~s~~ ?raOhan and his associates (both known/unknown and
national/international) have cheated us of amounts in excess of
about Rs. 7.50 crores. Facts detailed hereinafter disclose the
sinister and insidious modus operendi. Dr. Braja Sundar Pradhan is
a scientist by profession. We met him, in or around February-March
2007, and he introduced himself as the Managing Director of M/s
Helvetica Industries Pvt. Ltd. (in short Helvetica). He gained our
confidence and represented to'us that he was a scientist of repute
and was researching and developing patentable processes for
preparation of drugs and chemicals which had great commercial
value. He was short of funds and wanted us to invest in his
Company. We were misled by his representations and claims and In
this process we have been been induced to part with aboQt Rs 7.50
crores (including eapi to~, "bans and amounts paid to promote the
business of Helvetica) in M/s Helvetica Industries Pvt. Ltd. over
a period of time. e now find that we have been cheated by Dr.
?::::-a~, .."0 nas been si g our •oney and our laboratory
=a ~~~=~es ~- a="er co ~e-~on of research and testing, filing
pa-:.e::..-:.a ~ca=~ons':' s oi name and not in the name of the
••.•>J~c--.:., t; "·;_-=-c.::-~e 0 __ezs ip of the patents rightly belong.
=~s ~s ~e o~:: =rom ~s o' written admissions available with
::s.-'-ea__yenena ~at he "as surreptitiously sold the patents and
~as c~~desti e~y retained its consideration amount. He has
c02Cea~eQ vita~ ~_=ormat':'onw~th respect to his association with
_,:s C3Z C"emica s Ltd, England, a pharmaceutical company
·ncorporated in Essex, England (in short CBZ). There is an
undeniable conflict of interest which was deliberately and
dishonestly withheld from us. There is material to establish that
shares of CBZ are held in a tax haven abroad with each of the
three alphabets of CBZ being the first letter of its three
colluding partners, namely Chris, Braja and Zac. For theoretical
expositionl they have used the eminence of an academic in a
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3. District:Crime & Railway P.S.:ECONOMIC OFFENCES WING Year:2015 FIR No.:20150017 Date:l0
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expertise and clandestine use of facilities in India through
another conspirator and the financial expertise of the third based
in England taking shelter in a tax haven in Guernsey Island for
money la dering. Investigations will establish that in the
process, 0- o_~y Kee Pharma and Helvetica have been cheated, but
e-.-e::-;"'egO--~"::;:e.!'!t0= =ndia has been defrauded of substantial
az;::::-s~J' '.0. r = --.;.-:'es,=ees and taxes. Despite categorical
ass~~:' :::0' =:IT. ?yadLaL t.at e had no fiduciary relations with
caz, records reveal that. land sold by Helvetica to CBZ in Gujarat
in 2010 was transferred by CBZ to Dr. Pradhan without ever having
baen transferred to CBZ by way of BQard ResGlution of CBZ_and nG -
money was paid by Dr. Pradhan for the same. CBZ had paid Helvetica
for the land through remittance in foreign exchange. There is a
s ro g possibi_'ty t at this land may have been given to him, as a
ar- 0= 'e pro=it d e to Dr Pradhan from the money received by
C3Z =or .e process sold to Kee Pharma. A patent was filed by CBZ
and Dr. Pradhan for Atorvastatin in 2008 assigning the same to
CBZ. Similarly, a patent was filed by CBZ and Dr. Pradhan in Oct
2010 assigning the same to CBZ . Dr. Pradhan has filed a patent in
his own name in which has not been assigned to any company. Even
though CBZ and Helvetica were formed around 2000, no patent
application was filed by either CBZ or Helvetica or Dr. Pradhan
till the year 2008. We have reasons to believe that all the
development work was done in Helvetica clandestinely, using the
fund that were given by Kee Pharm~ to Helvetica during the entire
period, for research projects for the benefit of the investors.
Instead it has benefited only the co-conspirators. Complicity of
Dr. Pradhan and CBZ is also established from the following
instances, which would be established through scientific
investigations:- (i) Developing technology to: a., make Furanose
Derivatives for the preparation of Atorvastatin and assign them to
CBZ in order to sell the same and generate revenues outside the
country; b. make a process for the synthesis of Silylferrocene
Compounds and assign them to CBZ in order to sell the same and
generate revenues outside the country. Since they do not have any
lab of their own, they would not be able to establish where the
research took place. Also since Dr Pradhan was the full time
Managing Director of Helvetica and till date continues to be so,
he could not have undertaken the scie?tific work which led to the
filing of the patent in any other Labo rat.or'yother than Helvetica.
II. In collusion with CBZ and using it as a front company, to sell
Helvetica the process for Pregabalin, developed using funds
invested in Helvetica by Kee Pharma. Existence of a laboratory
where the research has taken place and data has been collected is
a pre-requisite. In this case, the initial part of the technology
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4. District:Crime & Railway P.S.:ECONOMIC OFFENCES WING Year:2015 FIR No.:20150017 Date:l0
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technology sold to Helvetica was not patented was because it would
have been difficult to show where the lab work had been carried
out since they did not have any laboratory of their own. It could
also be that the initial information was generated through unfair
practices because it seems that one of the stakeholder is the Head
Technician in one of the labs in the Chemistry Department in a
University in England (probably the initial design work have been
developed using the students studying under him). (iii) He has
patented in his own name and without assigning to Helvetica a
r cess for e preparation of r-(-)-3- (Carbamoylmethyl)-5-
__=---=..-=--::'c:===-=.:.. = .- =.:..:: =..::.::' =e ~:::::~ee..:.a:CE:se--e::"e - Belvetica
~~:::g ~e =~6s ~nvesced by Kee Pharma in Helvetica as loans/
investment. He has done this inspite of the Board having decided
in the initial stages of research that the process was not viable
and so the research should not be carried forward. There is
material to establish that it was this very process which Dr.
Pradhan had claimed unviable and hence he was not pursuing it.
This process is an alternative process to make Pregabalin. (iv) We
suspect that Dr. Pradhan has sold technology for preparation of
Pregabalin. This could have been done either directly or through
another company and its consideration has been unauthorisedly
retai oed by him. (v) He has patented in his own name and without
assigning to Helvetica a process for the 'Resolution of Racemic
Pregabalin using Mandelic Acid as a resolving agent' developed in
Helvetica using the funds invest-ed by Kee pharma in Helvetica as
loans/ investment. On being asked during a board meeting on 8th
November 2012 how he had filed the patent in his own name without
::2::e:.c::o''::"edoeand concurrence of the Board, he reluctantly
-~- ~eC ::2::e3o~d at even though he had filed it by himself, he
~~ =~::"e-::2::ea_9::"~caion and assigned the same to Helvetica. He
~~~5e~:: S~- a copy 0= tee application and a copy of the
:~5~:--e:::::eed ··-~~c·remai_s X awaited till date despite repeated
~e:=.::::,~s everi t.aouq_ ore t an two months have elapsed. This
es=~=-:"s:::es :_2.Scr .nal i cent. (vi) There is material to
es=ab:~s~-~a -echnolog~esfor Ethambutol and Pyrazinamide on
...'~~ca a or; 0= 0 ey has been invested and work had been done but
:ad 0 be abandoned in 2009 due to Dr. Pradhan conveying to the
Board that he was not able to proceed because he was unable to
solve some issues, may have been further developed in the
laboratory using funds received from Kee pharma. This could have
been similarly sold or patented by him through another company and
its consideration/benefit has been unauthorisedly retained by him.
I he circumstances, we would request you to kindly register a
case, investigate the matter ,?-"ndtake appropriate action against
:Jr. Braja Sundar Pradhan and his'accomplices.If required, we could
a so approach the University and the Serious Frauds Office in UK
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5. District:Crime & Railway P.S.:ECONOMIC OFFENCES WING Year:2015 FIR No.:20150017 Date:l0
for initiating appropriate proceedings against Dr. Pradhan and his
co conspirators. Sd/- English ( Anil Motihar) Managing Director,
Kee Pharma Director, Helvetica Industries Pvt. Ltd.Do. P.S. EOW,
From the contents of the complaint and enquiry conducted so far
prima facie a case u/s 406/420/120B IPC is made out. Register a
case and hand over the investigation of the case to me, as per the
directions of the senior officers. Date and Time of offence :-
07.04.2007 onwards. Place of occurrence :- Not known. Date and
Time of rukka :- 10.02.15 at 2.30PM Sd/- English Insp. Deepak
Chandra No. D-2982 PIS NO 16900020 Sec-II EOW. Action taken at
police station-At this time Insp. Deepak Chandra No. D-2982 PIS NO __ _ •• .,....,........ "-10 _ • •. _ •.••••.•• L ,~., ---
----- -a-1'"6900020See-II EOW came in the police station and produced the
above mentioned complaint for registration of case. Case has been
registered and original rukka along with copy of FIR handed over
to Insp. Deepak Chandra No. D-2982 PIS NO 16900020 Sec-II EOW for
further investigation. Copy of FIR will be sent to Senior officer
through DAK. SI/DO.
13 . Action Taken(Since the above information reveals commission of offence(s)u/s as mentioned at item No.2:
(i) Registered the case and took up the investigation OR
(ii) Dlrected(Name of the 1.0): DEEPAK CHANDRA
No.: 16900020
Rank: INS
to take up the investigation,
OR
(iii) Refused investigation due to:
OR
(iv) Transferred to P.S(name):
on point of jurisdiction.
District:
F.I.R read over to the complainant/informant, admitted to be correctly recorded and a copy given to the
complainantlinformant, free of cost:
R.O.A.C:
14 .
Signature I Thumb Impression
of The Complainant/lnformant:
Signature of Officer
Name: MOHAN SINGH
, • 1
Rank: SI ~vht 1~0.:
Dl IT,( 'JFFICER
PC'tice Station
Economic Offences Wing
New Oelhi - 1 .
CTf- t t1' ~ ~ ( C--
28760518
15 . Date and Time of despatch to the court:
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