Final mangalore-812-complaint

IN THE COURT OF THE JUDICIAL MAGISTRATE FIRST CLASS II
AT MANGALORE
P.C NO. 35/2012
BETWEEN:
812 Foundation,
Bhagavathi Nagar, 1st Main Road,
Opp. Residence of the Commissioner of Police,
Kambla Cross Road, Mannagudda,
Mangalore 575003
(Represented by Ms.Nayana Pai,
Secretary, 812 Foundation) ……….COMPLAINANT
AND:
1. AIRPORT AUTHORITY OF INDIA
Rajiv Gandhi Bhawan,
Safdarjung Airport, New Delhi-110003
2. AIR INDIA LIMITED
Air India Express,
Air - India Building,
Nariman Point,
Mumbai - 400 021.
3. DIRECTORATE GENERAL OF CIVIL AVIATION
Aurbindo Marg, Opp. Safdarjung Airport,
New Delhi 110 003
4. Mr.Arvind Jadhav,
Ex-Chairman and Managing Director,
Air India Express,
Nariman Point,
Mumbai - 400 021.
5. Mr.A.J.D’Souza
Ex-Chief Operating Officer,
Air India Express,
Nariman Point,
Mumbai - 400 021
6. Mr.Rajeev Bajpai,
Ex-Chief of Operations,
Air India Express,
Nariman Point,
Mumbai - 400 021
7. Mr.V.P.Agarwal,
Chairman
Airports Authority of India,
8. Mr.K.Ramalingam,
Ex-Chairman,

Airports Authority of India,
9. Mr.Peter Abraham,
Ex-Airport Director (Presently Airport Director, Coimbatore)
Bajpe International Airport,
Bajpe, Mangalore – 574142
10. Mr.M.R.Vasudeva,
Airport Director
Bajpe International Airport,
Bajpe, Mangalore – 574142
11. Mr.E.K.Bharat Bhusan,
Director General
Directorate General of Civil Aviation
New Delhi 110 003
12. Mr.A.K.Sharan,
Director – Training & Licenses
New Delhi 110 003
13. Mr.Nasim Zaidi,
Ex-Director General (Presently Secretary, Ministry of Civil Aviation)
New Delhi 110 003
14. Mr.Kanu Gohain,
Ex-Director General
New Delhi 110 003
15. Mr.J.S.Rawat,
Director General
New Delhi 110 003
………………ACCUSED
COMPLAINT UNDER SECTION 200 OF CRIMINAL PROCEDURE CODE, 1973 FOR
OFFENSES PUNISHABLE UNDER SECTION 304(II), SECTION 304A, 337, 338 OF
IPC AND SECTIONS 6, 45, 161, PART V, SCHEDULE II, SECTION O, OF THE
AIRCRAFT RULES, 1937 R/W SECTION 34 OF IPC
The Complainant above named respectfully submits as under :
1. The addresses of the parties for the purpose of issuance of process, etc, are as stated in the
cause title above. The Complainant may also be served as care of its counsel Mr. Sagar
Rai, opp.residence of Commissioner of Police, Bhagawati Nagar, Mangalore.

2. The Complainant is a Trust registered under the Indian Trusts Act and works in the field
of Aviation Safety. The Complainant is represented by Mr.Yeshwanth Shenoy, President
and Ms.Nayana Pai, Secretary.
3. The Accused No.1 is the Airport Authority of India who built and operates the Mangalore
Airport. Accused No.7 & 8 are persons who held the post of Chairman between May
2006 – May 2010. Accused No.9 & 10 are persons who held the post of Airport Director,
Bajpe Airport between May 2006 – May 2010. The Complainant states that the
Commercial operations started on this (new) runway in May 2006.
4. The Accused No.2 is Air India Limited which owns Air India Express (AIE), the operator
of the Aircraft that met with an accident on 22 may 2010. Accused No.4 was the
Chairman of Accused No.2 company at the time of the accident. Accused No.5 was the
Chief Operating Officer of AIE at the time of the accident. Accused No.6 was the Chief
of Operations of AIE at the time of the accident.
5. The Accused No.3 is Directorate General of Civil Aviation which regulates all aspects
related to Air Transportation including issuing Air Operators Certification to Accused
No. 2 and Aerodrome License to Accused No.1 and also Licensing of Pilots. Accused
No.11 is the Director General of Accused No.3 and Accused No. 13 & 14 are Past
Director General who held the post between May 2006 and May 2010. Accused No.12
(presently under suspension)is the person who issued the FATA license to the Pilot in
Comand (PIC) Mr.Glusica. Accused No.15 is the person who signed the Aerodrome
License of the Bajpe Airport.
6. The Complainant submits that on 22 May 2010, Air India Express Flight 812 crashed at
the Mangalore airport and FIR No.0120 dated 22 May 2010 was registered with the Bajpe
Police Station and the same is being investigated by Mr.Valentine D’souza, Circle
Inspector, Panambur. Mr.Yeshwanth Shenoy, President of the 812 Foundation had visited
the Investigating Officer (IO) personally to give additional complaint and evidence
against several other accused that were not named in FIR No.0120/2010. However, he
orally refused to register the complaint. On 7th
February 2012, a written complaint was
sent by registered post to the IO and the same was copied to the Commissioner of Police,
Mangalore and the Presiding Officer, JMFC II Mangalore. A copy of the same is annexed
as ‘Annexure A’ to this Complaint. It is learnt by the Complainant that the IO has filed
the chargesheet on 13 February 2012 and this Hon’ble court has abated the matter as the
accused persons in the charge sheet are dead. From the papers filed in this Hon’ble Court,
it is clear that the IO has not even perused the most important evidence which is the
report of the Court of Inquiry. The IO received the report on 8 February 2012 and on 13
February 2012, he has filed a chargesheet and it is impossible for him to have examined
the voluminous final report. The Complainant submits that the expertise available with
the IO or the local police is insufficient to investigate air accidents and the investigation
done by the IO is akin to the investigation of a road accident.
7. The Complainant submits that this accident is a direct consequence of wilful and gross
negligence on part of the Airport Authority of India (AAI), Air India (AI) and Directorate
General of Civil Aviation (DGCA). The Ministry of Civil Aviation had constituted a
Court of Inquiry (CoI) and the final report of the accident has been accepted by the
Government of India. A copy of the same is annexed as ‘Annexure B’ to this Complaint.
8. The Complainant submits that one Mr.Arthur Pereira filed writ petitions W.P.No.
37681/97 and 20905/02 against AAI in the Karnataka High Court. AAI filed a detailed
statement of objections in W.P.No. 37681/97. Both the writ petitions were disposed off
by the Karnataka High Court directing the AAI and the Government to “comply with all
laws”. A SLP was filed in the Supreme Court (1172/2003) and the same direction was

given by the Supreme Court. A copy of the writ petitions, objection filed by AAI and the
judgments are annexed as ‘Annexure C Colly’ to this Complaint.
9. The Complainant states that Para 4.12 of the W.P.20905/02 clearly stated a possible
scenario at the Mangalore Airport and the accident that occurred on 22 May 2010 was
identically similar. Para 4.12 is reproduced below:
“4.12 Minimum Area for Stop-way: At page 155 of the said report, para 2-1 prescribes
standards for providing the minimum area for a stop way and/or a clear way in the event
an aircraft undershoots or over-runs the runway. For instance, if an aircraft has initiated
take off, and a technical flaw requires emergency stop, the standard prescribes the
minimum area that should be kept free to enable such a stop. In the instant case, the
runway distance itself is about 2400 metres, and even if the area left is most cautiously
utilised, what is left is only about 300 metres on each end of the runway. By the
prescribed standard, this is far below the required distance needed for an emergency
stop way. Therefore, the chances of an aircraft that has achieved the decision speed
forcing an emergency stop are critically minimised, and the inevitable consequence
could be that the plane would come crashing down the hillsides from a height of 80-100
metres on either side of the proposed runway.”
This makes it very clear that the AAI and its officers (Accused No.1, 7, 8, 9 &10) had
personal knowledge of the dangerous consequences of an accident. All officers working
in Air Operations are very well aware of the consequences of their acts. These officers
were aware, at all times, that their act can cause likely death of hundreds of people.
10. The cause of death for most of the 158 victims has been Burn injuries and the IO has to
investigate the ‘cause of death’ as opposed to the terms of reference of CoI which is to
investigate the ‘cause of the accident’. In Page 49 of the CoI report, it states:
“The first sign of fire damage was seen on the vegetation, at the edge of the airport
boundary, where the portion of the right wing was recovered. Apparently, the fire HAD
started after the aircraft wing impacted the localiser structure.”
11. The concrete structure on which the ILS was mounted was a non frangible structure and
in violation of International Civil Aviation Organisation (ICAO) norms (ICAO Annex 14,
4.2.18). In Page 97 of the CoI Report:
“2.8.5 Non-frangible ILS Mounting Structure
The ILS structure at Mangalore has a concrete mounting which is nonfrangible.
Since the structure is below the surface level of runway, it is not an obstacle within the
approach or takeoff funnel. However, the Captain on leaving the paved surface seemed
surprised that such a big structure was present in the overshoot area. As per CVR
recording, it was evident from his call, “A BIG ONE”. Once the downward slope is filled
up and brought to the same level as of the runway, this non-frangible ILS structure will
also get buried below the surface leaving only the frangible ILS Localiser Antenna, on
the top.”
Clause 4.2.18 of Annex 14 of ICAO (Aerodrome Design and Operations) states as under:
“4.2.18 Fixed objects shall not be permitted above the inner approach surface, the inner
transitional surface or the balked landing surface, except for frangible objects which
because of their function must be located on the strip. Mobile objects shall not be
permitted above these surfaces during the use of the runway for landing.”
12. It is quite obvious from the words of the CoI report that the inquiry officers of the CoI
were deliberately trying to justify the presence of a concrete structure which otherwise is
not permissible by the standards. The inquiry officers are probably not even aware that
the Airport Authority don’t allow people to build homes anywhere near airport even if it
is not on flight path. The heights of buildings are restricted around a specified area around
airports irrespective of whether the place is on the flight path or not. The conduct of
Accused No.1 after the accident makes it even more obvious wherein they raised the level

of the runway to bring the concrete structure below the runway. A copy of the Pictures
before and after the accident is annexed as ‘Annexure D to this Complaint. The
Complainant states that it took 158 innocent lives for the officers to perform their duty
otherwise mandated by the statute.
13. The Complainant refers to the presentation made by a member of the Civil Aviation
Safety Advisory Council (CASAC) to the DGCA / Ministry of Civil Aviation / CASAC
and which is a part of Annexure A document. It may be further seen that the marking on
the runway is wrong and it may be seen that it is exactly at that point the pilot made the
decision of taking off again. The marking shows the availability of 2000 ft of runway
when there was virtually no runway available. The Accused No.1, 7, 8, 9 & 10 were duty
bound to maintain the airport in accordance with the ICAO standards and Accused No.3,
11, 13, 14 & 15 were duty bound to ensure no licenses were issued to airports that did not
meet the ICAO norms. The Accused No.2, 4, 5 & 6 were duty bound to conduct their
own risk assessment of the airport and have sufficient plans for risk mitigation.
14. The Complainant states that Para 4.16 & 4.17 of the W.P.20905/02 clearly stated the
difficulties in Fire Fighting efforts in the event of a possible air crash (overshooting the
runway) at the Mangalore Airport . Para 4.16 & 4.17 is reproduced below:
4.16 Fire fighting Preparedness: Per Recommendation No 9.2.19 on page 107 of Annex
14: “The operational objective of the rescue and fire fighting service should be to achieve
response times of two minutes, and not exceeding three minutes to the end of each
runway, as well as to any other part of the movement area, in optimum conditions of
visibility and surface conditions.” In the instant case, since all around the runway the
landform is a hillock drop, it is impossible to provide for such rescue operations. Further,
given that the valleys all around form an undulating terrain, the rescue team will have to
traverse several kilometres even to reach the point of accident. It may be recalled that in
the recent crash of the Alliance Airlines civilian aircraft in Lucknow, as in the case of the
crash of the AB-320 airplane in Bangalore, even lesser physical impediments caused a
very high response time resulting in unnecessary loss of life and property.
4.17 Emergency Access Roads: Per Recommendation No 9.2.22 on page 108 of Annex
14: “Emergency access roads should be provided for an aerodrome where terrain
conditions permit their construction, so as to facilitate achieving minimum response
times. Particular attention should be given to the provision of ready access to approach
areas up to 1,000 metres from the threshold or at least within the aerodrome boundary.
Where a fence is provided, the need of convenient access to outside areas should be
taken into account.” In the instant case, there is simply no surface to provide such
safeguards.”
15. The report of the COI clearly proved that the Airport Authority (Accused No.1, 7, 8, 9 &
10) did not have fire preparedness in accordance with the ICAO norms. The findings of
the COI on Rescue and Fire Fighting in Page 39 are reproduced below:
“1.10.11 Rescue and Fire Fighting (RFF) Capability at Mangalore Airport
At the time of accident, Mangalore airport maintained Rescue and Fire Fighting
Capability at level - 7 as laid down in CAR, Section-4, Series-B, and Part-I, dated 31st
July 2006. There were a total of 6 RFF vehicles, 4 of which were Rosenbauer, re-
christened as Panther 1 to 4 and 2 TATRA vehicles known as Agni Shatru and Agni
Vijay. There were 3 ambulances as part of the team.
The 4 Rosenbauer were procured centrally by AAI. These new RFF vehicles are heavy,
but have a good capability of Rescue and Fire Fighting within the airfield. Considering
the surrounding terrain of the Table Top runway at Mangalore, no terrain specific tests
were conducted prior to their allotment to Mangalore Airport. As such, when these RFF
vehicles were taken outside the airport, difficulty was experienced while negotiating the
narrow and curving roads. These vehicles had not been registered with Regional
Transport Authority at the time of accident. The RFF manpower was 31 and was well
trained.

It was given to understand that the responsibility of Rescue and Fire Fighting operations
outside the Mangalore Airport area lies with the civil administration. However, within 5
km of the airport especially in view of an accident on overshoot or undershoot area, the
RFF for the airport needed to be deployed at the earliest to carry out RFF operations.”
16. The callousness with which the Accused No.1, 7, 8, 9 & 10 acted is clearly recorded in
the COI report when under the ICAO guidelines, they were duty bound to be prepared for
such eventualities. ICAO Doc 9137 Part 1 (Airport Services Manual – Rescue and Fire
Fighting) provides international standards in Aircraft crash rescue and firefighting. The
document requires that “suitable rescue equipment and services should be available at
airports where the area to be covered by the service includes water, swamp or other
difficult environments that cannot be fully served by conventional wheeled vehicles. This
is particularly important where a significant portion of approach/departure operations
takes place over this area.” Further it requires that “Emergency access roads should be
provided on an airport where terrain conditions permit their construction so as to
facilitate the achievement of minimum response times. Particular attention should be
given to the provision of ready access to approach areas up to 1000 m from the
threshold.” The accident site is merely 500 mts from the airport perimeter. It may be seen
that the access road were widened after the accident. The Airport Authority clearly
breached its statutory duty as well as failed to follow the directions of the Karnataka High
Court and the Supreme Court of India and once 158 innocent lives were lost, they woke
up from the slumber to follow the rulebook. The Complainant also brings the attention of
this court that even DGCA missed or ignored this during their licensing audits, Safety
Management Systems (SMS) audits and license renewal audits. Since no action to correct
this has yet been taken, there is every possibility of this accident repeating itself with
many more lives to be lost. All the accused named herein are responsible for violation of
the provisions of the Aircraft Rules 1937.
17. The Complainant states that DGCA is the regulator and is in charge of aviation safety.
The DGCA has conducted several audits of the AI Express and had repeatedly found
deficiencies in the audit. It failed in its statutory duty to ensure that the operator remove
the deficiency. The DGCA is also responsible to ensure that the airport meets all
requirements in accordance with the Aircraft rules, 1937 and the ICAO Guidelines which
are adopted therein. The DGCA was duty bound to suspend the Air Operator Certificate
(AOC) of AIE and the Aerodrome license of Bajpe Airport as and when these agencies
were not in compliance with the law. The Accused No.3 and the Accused No.11 to 15
failed in their statutory and legal duty to enforce the law as a result of which 158 persons
lost their lives.
18. The DGCA is primarily responsible for clearing/issuing the FATA (Foreign Air Crew
Temporary Authorisation) license to the Pilot in Command (PIC) Mr.Glusica. It failed to
verify the ATPL license and Log book of the PIC before issuing the FATA license. The
issue of FATA License is governed by Civil Aviation Requirement (CAR) Sec.7, Series
‘G’, Part II, Issue II. This was recently amended on 15 November 2010 and effective
from 1 December 2010. The FATA license has been issued in violation of section 2.1,
2.2, 2.4 and 2.5 of the CAR. The CAR prior to this amendment was identical. Capt.
Glusica obtained his B-737-800/900 endorsement only on 22 May 2008 and joined AIR
INDIA Express (AIE) on 15 December 2008 during which period he did not fly this type
of Aircraft. When AIE applied for his FATA, he did not have the 100hrs on type (B-737-
800). The DGCA approved the FATA without confirming that he had the minimum
experience level on the type. The FATA License was issued by DGCA against the
provisions of the Section 6, Part V & Schedule II of Aircraft Rules, 1937. It is also
brought to the notice of this Hon’ble Court that the DGCA is in the midst of a scam
relating to the licensing of pilots and this license may be one of the scam tainted

clearance given. A copy of Capt.Glusica’s license and log book is annexed as Annexure
E colly to this Complaint.
19. The Complainant states that Captain Glusica (Pilot in Command) did not have a valid
Instrument Rating (IR) Check. In page 9 of the CoI report it is stated that the date of last
instrument check is 14 may 2009. The validity of an Instrument Rating Check is one year
and this means it expired on 13 May 2010. The CoI wrongly records the validity of the IR
Check as 7 June 2011. Clause 2 of Section O, Instrument Rating (Aeroplanes) states “2.
Validity— The period of validity shall commence from the date of issue or renewal of the
instrument rating. The rating shall be valid for a period of twelve months from the date of
the satisfactory completion of the instrument rating test as laid down in clause (e) of
paragraph 1.” The Operator (Air India) is responsible for ensuring that the pilots have all
valid licences before they are allowed to fly. Schedule VI of the Aircraft Rules, 1937
imposes penalties for offences. The offence is a Category 1 offence punishable with
imprisonment for a period not exceeding two years or with fine not exceeding Rupees
Ten Lakhs or with both.
20. The Complainant states that the CoI in Page 108 stated “After any accident, the ATC tape
is required to be sealed. However, due to some unexplained reasons, the media had
reported about the First Officer having given a call to the Captain to ‘GO AROUND’.”
The law requires the ATC tapes to be sealed and the same was not done. Schedule VI of
the Aircraft Rules, 1937 imposes penalties for offences. The offence is a Category IV
offence punishable with imprisonment for a period not exceeding three months or with
fine not exceeding Rupees One Lakh or with both.
21. The Complainant states that the CoI report has clearly pointed out that the Hard landing
circular and the counselling given to the pilot as having a role to play in him persisting
with the ‘unstabilised approach”. The Hard Landing Circular of AI is even against the
standards given by the manufacturer of the Aircraft. It was a contributing factor to the Air
Crash and the action of AI cannot be ignored under the circumstances. The Circular
issued by AI is in violation of Aircraft Act, 1934 and Aircraft Rules, 1937.
22. The Complainant states that there were no medical tests done on the captain and the co-
pilot in breach of the regulations. The CoI has clearly recorded that there were medicines
in the room of the captain. Though medical tests were carried out to rule out the
possibility of use of certain banned medicines, it still couldn’t establish what medicines
were found. It is stated that the same were sent to the wife of the Captain and it has to be
understood as to who sent these back even when the inquiry was going on. This act
amounts with tampering of evidence and punishable under Section 201 of the Indian
Penal Code. During the last moments of the flight there is overwhelming evidence of the
captain being very active and very sharp decision taken by the captain to avert the
disaster and the conclusion of the CoI stating that the captain was incapacitated by
Window of Circardian Low is a False Statement.
23. The Complainant states that the Captain undertaking a flight has to be given ample notice
of his duty schedule. The Captain was not rostered as per the original roster made
available to the pilots. A copy of the original roster is annexed to this complaint as
Annexure F to this Complaint.
24. The Complainant states that it is the responsibility of the Air Carrier/operator to conduct
a proper risk assessment of the landing airport before scheduling a flight. Air India
Express was operating a scheduled passenger service to Mangalore Airport and therefore
it is its responsibility to have conducted a proper risk assessment of the airport and take
appropriate actions to eliminate or mitigate to Approach and Landing Accident Reduction
Procedure (ALARP) the risks identified. This is one of the tasks of an Air Carriers

Aviation Safety Department. In this case, it is painfully evident that Air India Express
never undertook any kind of Risk assessment survey of the airport. There was no hazard
identification (lack of RESA, Ravine just 300 m from end of runway, non frangible ILS
structure) and therefore no exercise into risk mitigation. The DGCA continued to issue
the Air Operators Certificate (AOC) with such glaring deficiencies in Safety Risk
Management in violation of Aircraft Act, 1934 and Aircraft Rules 1937.
25. The Complainant states that the Second Runway at the Mangalore Airport was
operational in May 2006. Accused No.6, 7, 8 & 9 are all those officers who held the post
between the period May 2006 to May 2010 as all these officers had knowledge of the
breach of the statute and did not take any steps to prevent the breach of law. They always
had full knowledge that if an accident occurs due to the non compliance with Laws, it is
likely to cause death of passengers. Accused No.10 is the officer who was responsible for
having issued the License to Capt.Glusica who did not qualify to meet the eligibility
requirement for an issue of the FATA License. He would certainly have the knowledge of
the disastrous consequences of allowing a pilot to fly a commercial aircraft when the pilot
did not meet the eligibility criteria. The Accused Nos.1-15 are highly experienced
organizations and persons working in Air Transportation always had the knowledge of
the consequences of their act and omission to act. The act of these accused is within the
meaning of Sec.300 (4) of the Indian Penal Code (IPC) even punishable under Sec.302 of
the IPC.
26. The Complainant states that the Accused No.2 did not provide mandatory cockpit training
to most of its international flight crew for over two years, violating regulatory norms.
DGCA Circular No. 8 of 2009 and Civil Aviation Requirement mandate Crew Resource
Management (CRM) training to the crew every year. The CoI report clearly points out the
inadequate CRM as having played a significant role in the accident. An e-mail dated 3
June 2011 written by Mr.A.S.Soman, Executive Director, Operations and Customer
Service and addressed to Accused No. 4 clearly acknowledges this fact. A copy of the
said e-mail is annexed as Annexure G to this Complaint. This e-mail also states that
there were indications that records were potentially fudged to portray better results. “Use
of registers with no control over entries show instances of mismatching signatures
(especially for training captains and senior executives), overwritten dates, altered entries
and logging of navigation classes as CRM classes”. “No CRM manuals were issued to
crew. One manual with (outdated) first generation CRM material (was) maintained only
for audit purposes.” This clearly points out the fact that Accused No.2, 4, 5 & 6 clearly
had knowledge of irregularities and tried to cover up their acts by maintaining a separate
register for audit purpose.
27. The Complainant states that Mr.Yeshwanth Shenoy has been trying to get the documents
from the Accused No.1, 2 & 3 under the Right to Information Act, 2005. However, these
organizations stonewalled the request under one pretext or another. Mr.Yeshwanth
Shenoy wrote to the Minister for Civil Aviation an e-mail dated 24 January 2011 as a last
resort informing the Minister of the serious irregularities in the CoI Report and the denial
of information by organizations under his control. A copy of the Said e-mail and the
various RTI Applications are annexed as Annexure G colly to this Complaint.
28. The Complainant herein submits that the offences under Section 304(II), Section 304A,
337, 338 of IPC and Sections 6, 45, 161, Part V, Schedule II, Section O, of the Aircraft
Rules, 1937 r/w Section 34 of IPC have been committed by the Accused herein and the
same are cognizable and non-bailable. The offence has been committed by the Accused
within jurisdiction of this Hon’ble Court. Accordingly, this Hon’ble Court has the
jurisdiction to try the Accused for the offences committed by them.

29. Accused No.1, 2, 3 are Government Agencies and Accused No.4-15 are officials of these
agencies. It is the specific case of the Complainant that the acts committed by Accused 4-
15 are not in discharge of their official duties requiring sanction from the Central
Government under Sec.197 of the Cr.P.C. However, the Complainant submits that the
Complainant has requested for the sanction of the Central Government on 6 March 2012.
In the event of the Hon’ble Court asserting the requirement of the sanction from the
Central Government, this Court may take cognizance of the Complaint as against
Accused No.1to 3 and keep in abeyance the complaint as against Accused 4-15 pending
the sanction from the Central Government.
Wherefore the Complainant in the above case most humbly prays that this Hon’ble Court
may be pleased to take cognizance of the offences punishable under the Indian Penal Code and
Aircraft Rules 1937 proceed against the Accused in accordance with law and punish the Accused
persons after trial to meet the ends of justice. The Complainant prays the Hon’ble court to issue
non bailable warrants against each of the Accused.
Advocate for Complainant Complainant
VERIFICATION
WE, Yeshwanth Shenoy, S/o V.L.Shenoy aged about 33 years and B.Nayana Pai, W/o
Mr. Yogish Prabhu aged about 33 years, President and Secretary respectively of 812 Foundation
and having office at Bhagavathi Nagar, 1st Main Road, Opp. Residence of the Commissioner of
Police, Kambla Cross Road, Mannagudda, Mangalore 575003, do hereby verify and state that the
averments made above are true and correct to the best of my knowledge, information and belief.
Mangalore
Date : 6 March 2012 COMPLAINANTS

Final mangalore-812-complaint

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