APPLICATIN AMENDMEND

1. IN THE COURT OF ILLAQA/DUTY MAGISTRATE LUDHIANA
Manjot Singh, proprietor of Sahil Trading
Company, Chandigarh Road, Main Jamalpur Chowk,
Ludhiana.
……..Applicant
VERSUS
1.Nitin (ASM)/Authorized Officer of Livfast
Batteries Pvt. Ltd., #Haider Enclave,
Ladian Kalan, Hussainpur Road, Ludhiana-
141008 C/o Grewal Electronic Point, Mobile
No.9888045365,
2.Sameer Sharma (National Head)/Authorized
Officer of Livfast Batteries Pvt. Ltd.,
#Haider Enclave, Ladian Kalan, Hussainpur
Road, Ludhiana-141008, C/o Grewal
Electronic Point,
3.Navneet (TSI)/Authorized Officer of Livfast
Batteries Pvt. Ltd., #Haider Enclave,
Ladian Kalan, Hussainpur Road, Ludhiana-
141008, C/o Grewal Electronic Point, Mobile
No.9627632376,
IInd Address:-Opposite New Bus Stand,
Ludhiana-148101,
4.Tata Capital Financial Services Ltd., 1-
Think Techno Campus, Building A, 4th Floor.
Off Pokharan Road 2, Subhash Nagar, Near
Yantra Park, Thane (W), 400607 through its
Chairman/ Managing Director/ authorised
signatory,

2. 5.Tata Capital Financial Services Ltd.,
Feroze Gandhi Market, Ludhaina through its
Branch Manager/ authorised signatory;
6.Arihant Collection, #Opposite Pal
Departmental Store, Haibowal, Ludhiana.
……..Accused
Application under section
156(3) Cr.P.C. for issuance
of direction to S.H.O. Police
Station Jamalpur, District
Ludhiana to register FIR
against the accused U/s 406,
420, 467, 468, 471, 499, 500,
120-B IPC and under the other
relevant sections of the law
of land.
Sir,
The applicant respectfully submits as
under:-
1.That the applicant is peace loving and law
abiding citizens of India.
2.That the applicant is the Proprietor of
Sahil Trading Company, and he is the
manufacturer of Batteries and Invertors and
accused no.1 to 3 are in the business
dealings and purchased batteries and
invertors on credit basis time to time from
the applicant. Lastly accused no.1 to 3 has
purchased batteries/invertors on credit

3. basis from the year 2013 to till date. The
applicant maintaining his account, in his
account books and as per account maintain
by the applicant a sum of Rs.45,43,770/- is
outstanding against you since 2018.
3.That the applicant doing the business with
accused no.1 to 3 from the last 13 years,
thereafter the intention of the accused
No.1 to 3 become dishonest and with their
pre-planned manner they in connivance with
accused No.4 and 5 to make my client’s firm
their authorized distributor and enticed
him to work on a large scale, on the basis
of which accused no.1 told the applicant
that he will give loan to him for his firm
from the accused no.4 and 5 Tata Company,
due to which the applicant believing on his
statement to be true, accused no.1 provide
him loan no.CED000006659 for an amount of
Rs.1,23,000/- on dated 28-09-2020 as
Channel Finance Loan from the accused no.4
and 5. Alongwith this, accused no.1 also
kept some blank cheques no.373820 to 373870
as security alongwith the above loan and
accused no.4 and 5 also kept them as
security and accused no.1 became himself as
a grantor in it. All the accused persons
have made the applicant’s financial
condition very serious by investing a lot
of money in market/business and the
applicant requested accused no.1 to 3
several times to give him some relief in
business, but accused no.1 to 3 always used

4. to put off the applicant by saying that you
should survive for a little more time. One
day again the applicant was told to accused
no.1 about his financial hardship, then
accused no.1 to 3 stopped their business
dealing with the applicant on 09-05-2023,
while the applicant has taken many other
loans from other banks to deposit the loan
amount taken from accused no.4 and 5, but
accused no.4 and 5 passed the security
cheques to the accused no.1 which were
given by the applicant at the time of loan,
with the intention to cheat him instead of
awarding him for his hard work, without
informing to my client and without his
consent, accused no.1 made new distributor
of accused no.6. Accused no.1 to 5 has
started doing the business with the accused
no.6 without getting any NOC from the
applicant.
4.That accused no.1 to 5 alongwith accused
no.6 are sharing all the personal
information of the applicant regarding the
business/trade of the applicant and
inciting the clients of the applicant
towards the applicant for the amounts which
the applicant supposed to collect from his
clients and forbidding them to pay the
amounts. Accused no.4 and 5 have incurred a
liability of Rs.1,17,85,744.69/- illegally,
forcibly and without due course of law
towards the applicant. While the applicant
has given a large scale business to accused

5. no.1 by doing business in every village,
street, mohalla, city, district to raise
the name of the company by which he giving
profit to accused persons in crores, but
due to their illegal behavior, the
applicant is mentally disturbed and he have
been physically and financially very
disturbed, due to which the applicant has
requested many times to the accused no.1
that the applicant is not in a position to
deposit the due amount but accused no.1 to
3 have been delaying him for the last one
year. Due to the behavior of all accused
persons, the applicant is facing a lot of
problems and whatever advance has been
taken from the clients has also reached the
point of turning it back, due to which the
applicant’s reputation and status is
getting damaged a lot. It is pertinent to
mention here that on 30-03-2023 a written
Representation/Memorandum was sent by the
applicant’s firm to accused no.1 to 5 that
the applicant has worked very hard and he
have made his name very difficult in the
eyes of public and your company. Due to
which his understanding and distress,
accused no.1 believed in getting him out of
this economic crisis, but accused no.1 did
not give any answer to the applicant in
this regard.
5.That it is further mention here that the
applicant’s company has a very good CIBIL
score, which clearly shows that its record

6. in the market is very good and not only
that, the applicant has also filing his
business tax returns time to time as per
instructions given by the Government of
India and the Government of Punjab, due to
which the applicant has never allowed to
anyone to be tarnished the image of his
firm/company in terms of transactions.
6.That now accused no.1 to 3 blackmail the
applicant by threatening to make full
payment and try to misappropriate his
cheques, his respect among some of the
applicant’s clients and old acquaintances
nearby. All accused are trying to defame
his reputation among the people and by
giving threats to defame his respect
through advertise in social media and
newspapers and threatened to implicate the
applicant in a false case and try to abuse
him and threaten to kill him. If the
applicant suffers any loss of life or
property then all of accused will be
responsible because they have caused the
applicant a great mental, physical and
financial damage, which is impossible to
bear.
7.That now all the accused persons have
failed to make the loan payment of the
aforesaid amount and as such the applicant
has become entitled to claim interest from

7. all accused persons at the rate of 18% per
annum as mentioned in the invoice.
8.That the applicant requested the accused
several times to pay the aforesaid amount
alongwith interest accrued thereon at the
rate of 18% per annum, but accused have
turned a deaf ear to towards the request of
the applicant.
It is pertinent to mention here
that the said amount is also invested by
the applicant by taking Limits from bank,
friends and other institutions etc.
9.That now the accused No.1 to 6 in
connivance with each other threatening the
applicant that in case he do not release
authorized dealer then the applicant will
be done to death and as such the applicant
is every apprehension that the accused No.1
to 3 in connivance with each other kill the
applicant for their benefit. It is
pertinent to mention here that when the
applicant start his other business then the
accused No.1 to 3 interfere in doing the
business and threatening the applicant that
he will not do any business to the
applicant.
10. That on 24.05.2023, the applicant moved
an application no.169776 before the
Commissioner of Police, Ludhiana by way of

8. registered post, copy of the said receipt
is enclosed herewith, but the police did
not take any action against the accused as
the accused are having influential
approach.
11. That the said application is required
to be forwarded to the S.H.O. P.S.Jamalpur,
District Ludhiana for registration of case
against the accused under section 156(3)
Cr.P.C. in the interest of justice.
12. That the norms of law, justice and
equity, forwarding of complaint to the
S.H.O. P.S.Jamalpur District Ludhiana
It is, therefore, prayed that the
application of the applicant may kindly be
forwarded to the S.H.O. P.S.Jamalpur
District Ludhiana for registration of FIR
U/s 406, 420, 467, 468, 471, 499, 500, 120-
B IPC and under the other relevant sections
of the law of land against the accused
persons, in the interest of justice.
Applicant
Through Counsel
Dated:-
Mohit Nagrath, Advocate