Criminal Complaint AK

IN THE COURT OF ADDITIONAL CHIEF METROPOLITAN MAGISTRATE (NEW DELHI DISTT), PATIALA HOUSE COURTS, NEW DELHI

COMPLAINT CASE NO.________/2014

IN THE MATTER OF:
Sh. Neeraj Saxena & Sh. Anuj Kumar Agarwal
(Office Bearers of Maulik Bharat Trust)       .......Complainants

Versus

Sh. Arvind Kejriwal
S/o Gobind Ram Kejriwal
R/o Bunglow No. 41, Hanuman Road
New Delhi      .......Accused
PS: TILAK MARG

COMPLAINT UNDER SECTION 125 A OF REPRESENTATION OF PEOPLES ACT, 1951, UNDER SECTION 31 OF REPRESENTATION OF PEOPLES ACT, 1950 AND UNDER SECTION 177 OF THE INDIAN PENAL CODE, 1860 MOST RESPECTFULLY SHOWETH:

  1. That the complainants are the office bearers of Maulik Bharat Trust situated at 4852/24, Basement, Ansari Road, Darya Ganj, New Delhi 110002 are law abiding, peace loving and public spirited citizens of this nation. Maulik Bharat Trust is a registered body under the Indian Trusts Act, 1882 and through its office bearers it had organized multiple campaigns for voter awareness and electoral reforms throughout Delhi before the commencement of 2013, Delhi Assembly Elections besides holding and performing various social reforms and works in the NCR, and also undertake works and campaigns for general awareness irrespective of caste and creed and with the aim and object to serve humanity and not specific community. The complainants herein filed a Public Interest Litigation WP(C) 443/2014 in the Hon’ble High Court of Delhi, wherein the petition was disposed off with directions to pursue the grievances at an appropriate forum. Thereafter the complainants issued a notice to the ELECTION COMMISSION OF INDIA along with an R.T.I. application both dated 31.1.2014.

A copy of the trust deed is enclosed as ANNEXURE A/1. A copy of the order dated 22.1.2014 of the Hon’ble High Court is enclosed as ANNEXURE A/2. A copy of the notice dated 31.1.2014 and R.T.I. dated 31.12014 are enclosed as ANNEXURE A/3.

  1. That the complainants are compelled and constrained to prefer the present complaint U/s 190 (1) (c) and U/s 200 of the Criminal Procedure Code, 1973 against the accused for his prosecution and conviction on the grounds stated hereinafter. For the purpose of jurisdiction, Form 6 of Registrations of Electors Rules, 1960, Form 2(b) and Form 26 of the Conduct of Election Rules, 1961 by the accused were submitted in SDM’s office at 12/1, Jam Nagar House, Shah Jhan Road, New Delhi, well within the jurisdiction of Police Station Tilak Marg, the aforesaid forms were submitted for the following purposes: inclusion of name into the electoral roll of New Delhi Constituency and fulfilling the requirements of contesting from the New Delhi constituency in the recently held Delhi Assembly Elections 2013.
  2. The accused person in a very systematic manner became a political figure in the shortest span of time at the cost of violating the laws of land and spreading anarchy, accused also mislead the innocent citizenry of the nation on various subjects only to meet the ends of his anarchist ambitions, as recently stated by the accused himself during his protest at Rail Bhawan, New Delhi at 3 p.m. on 20.1.2014. The accused person abruptly left the Indian Revenue Services to form various NGOs, the same NGOs were used to collect funds from various sources thereafter, a political party by the name AAM AADMI PARTY was formed to contest in the recently held Delhi Assembly Elections 2013 and the accused finally became the Chief Minister of NCT of Delhi.
  3. That the complainants are aggrieved by the wrong full acts of the accused committed for the purpose of contesting the Delhi Assembly Elections 2013. The complainants are public spirited persons and have been relentlessly working on election reforms and organizing voters awareness campaigns with other team members and are not guided by any self-gain or profit and being citizens of this state are constraint to approach this Hon’ble Court for conviction of the accused person based on the facts and circumstances as narrated herein below:-
    • That the elections for Delhi assembly were declared and held on 4-12-2013. As a prerequisite each contesting candidate was required to file an affidavit before the Election Commission of India in compliance of section 33(1) of the R.P. Act-1951 and Conduct of Election Rules 1961. The Hon’ble Supreme Court of India, has also laid down guidelines there by making it mandatory to furnish true and correct information in the affidavit containing necessary information at the time of filing of nomination paper, else the same would attract the provisions of 125 A of The Representation of People Act, 1951. The name of accused is not at Sl. 600, AC 40, part no. 47 of the New Delhi Assembly Constituency.

The judgment of the Apex Court in “Resurgence India vs Election Commission of India and another W.P. (Civil) 121 of 2008 decided on September 13, 2013 (Copy enclosed as ANNEXURE A-4).

  1. That accused had filed his affidavit along with his nomination papers on 16th November 2013. It was the duty of the accused to swear by an affidavit which declares the true and correct address as well as the valuation of all his moveable and immoveable assets and also his spouse or his dependants. On the contrary the accused intently and deliberated stated the address of one of his property as plot No. 11/44 Indirapuram, Ghaziabad, Uttar Pradesh admeasuring 2400 sq. ft. and declared the approx. current market value for the aforesaid property at Rs. 55 Lakhs only, it is not only incorrect but a deliberate attempt towards concealment. The correct address of the aforementioned property is Abhay Khand - II, Indian Revenue Services Officer’s Co-operative Group Housing Society, Plot No. 44, Indirapuram, Ghaziabad, Uttar Pradesh and its current market value is at least Rs. 2.2 crores as the probable current market rate is Rs. 1,00,000/- per sq. metres for Non-Agricultural (Residential) land in Indirapuram, Ghaziabad. It is highly surprising that the value of the aforesaid property as per the government rates announced vide notification dated 31.7.2013 of District Magistrate Ghaziabad under Uttar Pradesh Stamp Valuation of Property (Second Amendment) Rules, 2013 (Valuation of Property Rules – Second Amendment, 2013) the valuation of Non-Agricultural Land would be Rs.63,000/- per square meter for Abhay Khand, Indirapuram, Ghaziabad, UP. Accordingly the value of the aforementioned property as per the government rates is not a dime less than Rs. 1,40,46,939.90 (222.96 sq.mts. X Rs. 63,000/-).

Copy of the AFFIDAVIT filed by accused is enclosed herewith as ANNEXURE A/5. Copy of the notification of District Magistrate, Ghaziabad under Uttar Pradesh Stamp Valuation of Property (Second Amendment) Rules, 2013 (showing the value of @ Rs. 63,000/- per sq.mt. as per the circle rates) are enclosed herewith as ANNEXURE A/6.

  1. That the accused has willfully mislead the Election Commission of India and its electors by concealing the correct address and the market value of the aforesaid property, the same was certainly done to keep his financial net worth under a figure of Rs. 1 crore and conceal his actual net worth running into crores. Willful concealment and suppression of the correct address and the value of the aforesaid property amounts to commission of a criminal offence under Section 125 A of the Representation of the People Act, 1951 punishable with 6 months of imprisonment and/or fine or both. It took many days for the complainants to search the property of the accused and to verify as to whether the postal authorities could reach to the address as disclosed by him or not i.e. 11/44 Indirapuram Ghaziabad the postal envelop was returned with remarks “address incomplete” copy of the postal envelop is enclosed”.
  2. Copy of the postal receipts, online consignment track result bearing no. EU069890213IN and a copy of the retuned envelope containing the letter along with its English translation are enclosed herewith as Annexure A/7 (colly).

  1. That the accused had stated to be earning Rs. 2,05,600/- per annum without disclosing his source of income, it is extremely surprising how could a social worker and/or a political activist be earning income whereas he wants to be perceived as the most modest politician, by choosing to travel by metro-rail, rejecting the offer of vehicle with a beacon, security and official house.
  2. That the accused had failed to state the facts of being a beneficiary or owner of the property bearing no. R-902, Girnar Apartments, Kaushambi, Ghaziabad, UP. A notice bearing no. 631 for disconnection of respondent’s electricity line (Book No. 2014, Connection No. 028342) dt. 27.6.2013 was served in the name of Arvind K. R R/o of R-902, Girnar as printed in Danik Jagran (Page 20 dated 29.6.2013). Sh. Arvind Kejriwal is the beneficiary or owner and; in use and occupation of the abovesaid premises, the details regarding the same have also been concealed and suppressed in his affidavit.

Copy of the postal receipts and online consignment track result bearing no. EU069890227IN along with its English translation are enclosed herewith as Annexure A/8 (colly). Copy of the issue of Danik Jagran dated 29.6.2013 along with its English translation are enclosed herewith as Annexure A/9.

  1. That Sh. Arvind Kejriwal also gave a wrong and incorrect residential address in his affidavit as 41 Bunglow, Hunaman Road, New Delhi-110001. The accused in reality has never been the resident of the aforementioned address, the same has been given to superficially substantiate his domicile for the purpose of contesting from the New Delhi constituency whereas he continued to reside at Ghaziabad, Uttar Pradesh before and after the Delhi Assemble Elections 2013. Inclusion of the aforementioned address in the electoral rolls as an ‘ordinarily resident’ of the New Delhi Constituency was a deliberate and motivated attempt to eye wash the public authorities and the electors. If the aforementioned address was the residence of the accused then why would be residing at Ghaziabad, U.P., the same was to gain public sympathy and mislead the innocent public who were carried away by the deliberate motivated, intentional emotional speeches of not claiming or availing residence, car and security beside other usual benefits which are attached to the office of Chief Minister. Declaring false residential address in the Form 6 of The Registration of Electors Rules, 1960 is a punishable offence U/s 31 of The Representation of the People Act, 1950 punishable with one year imprisonment and/or fine or with both.

A copy of letter issued by the Delhi Police to the accused along with his reply is enclosed as ANNEXURE A/10.

  1. That incorrect, wrong and misleading information makes it difficult for the electors to verify the credentials of Sh. Arvind Kejriwal’s affidavit filed before the Election Commission of India since he has never been a domicile of the constituency he contested from, hence the electors of that constituency would find it extremely difficult to verify any of his declarations, of which the accused seems to have been taking advantage of. The above facts has seriously violated the fundamental rights of the complainants and the electors at large as available to them under article 19 (1) (a) of the Constitution of India.
  2. That it is also understood and reliably learnt that Sh. Arvind Kejriwal formed a trust as its “settlor” on 19.12.2006 vide trust deed bearing no. 14265 in the name of Public Cause Research Foundation, wherein he gave his residential address as 403-L, Girnar, Kaushambi, Ghaziabad, UP and registered the said trust deed at another address of 5/7, basement, Sarvapriya Vihar, New Delhi-110022. Ownership of both these properties and the donations made to the trust and the value of the same, have also not been declared in his affidavit filed before the Election Commission of India. In the year 2012 an auditor’s report of the aforesaid trust in schedule 10 under the heading of “notes on accounts” clause no. 4 reads as follows “the trust has refunded Rs. 25,44,074.00 to 468 persons due to lack of information of donor”. Non – disclosure regarding the use and occupation of these properties and the investments/donations made into aforesaid trust of which the accused is the settler, in the affidavit filed before the Election Commission of India is highly questionable and illegal. Also the collection and refund of donation amounts to someone whose identity is not clear is also extremely suspicious and qualifies to be a serious financial fraud. It has also been learnt through sources that purpose of research for which the trust was formed was never accomplished, since the same was only used as a financial arm to collect funds on behalf of India Against Corruption and later the funds were used for the formation of a Political Party.

Copy of the trust deed of PCRF along with a typed copy is enclosed herewith as Annexure A/11. Copy of the audit report dt. 3.7.2012 along with a typed copy is enclosed herewith as Annexure P/12.

  1. That accused has concealed and suppressed his, his wife’s and his childrens’ Insurance Policies, Investment, Fixed Deposits, etc. which he ought to have declared in his affidavit. It is highly improbable for any prudent person not to invest in a Life Insurance Policy, Fixed Deposits or any futuristic investments for themselves, their spouse or their dependents. The non-disclosure of the same raises an extreme amount of suspicion on the intention of the accused to keep his net worth below a certain level and create an impression of an extremely austere personality at the cost of misleading the accusedno.1 and its electors.
  2. That besides the afore said the accused has over and over again demonstrated his ill will to break the laws and challenge the authorities for instance, by breaching the mandate of his bond while serving the Indian Revenue Services to serve for a period no less than 3 years after returning from the long study leave at the expenses of the tax-payers money, accused again went on the long leave instead of complying with the terms and conditions of his earlier granted leave. Instead of serving the department as per the mandate of the bond, he filed a protest letter before the Hon’ble Prime Minister of India when asked to clear the dues rose by the department in lieu of the salary he usurped during the second long leave that he took. The act of accused towards non-submission of electricity bills and further encouraging the electricity users to stop paying for their individual connections is also highly condemnable. Both the acts clearly indicate the extent of accused to blatantly act against the laws of the land, to encourage anarchy and irreverence to the Constitution of India. Moreover the accused deliberately had in past at an international forum of Ramon Magsaysay Award Foundation, defamed and maligned the reputation of the nation’s highest and esteemed civil services i.e. IAS, IRS, IPS and IFS to the knowledge of the petitioners. Accused had also mentioned his immediate boss’s advice to be corrupt, without naming him. It is the contention of the petitioners that the awardees of any international reward/award should be officially condemned by the state as traitors, if they attack the pride of the nation to gain accolades from foreign establishments. Below is what the accused stated at the international forum of Ramon Magsaysay Award Foundation.

On his first day with the Indian Revenue Service, Arvind Kejriwal had a heart-to-heart talk with his boss. “In the first few years of your service, you should make sufficient money for yourself so that you can appear to be honest for the rest of your life,” the young man was advised. Kejriwal’s superior said he hated that period of bribery and corruption. “But now,” the man said, “I am honest because I have made sufficient money for myself, and I have made several investments.”

“That early, though, Kejriwal was already feeling disillusioned about the civil service. “I had very strong reservations about the kind of bureaucrats they were selecting,” he says. In the exams, applicants were asked to choose two subjects on which they would be tested. In his case, Kejriwal chose physics and geography. “I bought books from the market, sat in the house and mugged them up. I just vomited that out in the exam and I got through.” What does being good in physics and geography have to do with being a good civil servant? He adds: “The kind of people who reach the academy, they [tend to be] the people who have great cramming power. But they are not [necessarily] the best brains.”
Copy of the biography from the Ramon Magsaysay Award Foundation is enclosed as ANNEXURE A/13. A copy of Annexure –X (Chapter V, Para 5.13) from the notification dated 1.8.2012 of Ministry of Law and Justice along with a copy of relevant laws and forms are enclosed as ANNEXURE A/14 (Colly).

  1. The afore said facts and circumstances clearly makes out a case of blatant violation suppression, misleading facts and information not only from the electors but also from the election commission of India and this leads to no other conclusion except being suspicious of the character and creating a feeling of distress and loss of complete faith in the extremely sensitive post being held by the accused thus causing harm to the reputation and sanctity to the office of Chief Minister of Delhi.
  2. The quote from the biography of the accused also reveals that he has not only demeaned but also lowered the reputation of our country at an international forum by calling the entire Indian system as corrupt. Arvind Kejriwal is also of guilty of contempt of Delhi high court for having made the following remarks the income tax department filed an affidavit in the Delhi high court saying that they had issued orders for implementation of all the suggestions made by Parivartan recalls Kejriwal I was in the department. I knew there were no such orders and the department was filing false affidavit before the court. The group informed the judges of this but met with little sympathy. The court, says Kejriwal, believed that the department was making an honest effort and closed the case. That the officials of ECI are fully and completely in conspiracy with the accused and his team in not scrutinizing and verifying the contents of affidavits which on the face of it contains falls fabricated, manipulated information besides suppressing facts and figures which are mandatory to furnished and thus violating not only the provisions of Representation of Peoples Act, 1950; Representation of Peoples Act, 1951 and the Indian Penal Code beside violating the law aid down in 13 September 2013 which petition was argued by non-other but the activist of AAP.
  3. That the aforesaid facts and circumstances reveal commission of offences by the accused U/s 125 A of Representation of People Act, 1951, U/s 31 of the Representation of People Act, 1950 and U/s 177 Indian Penal Code, 1860 besides any other offences that may attract other penal provisions as an outcome of any additional investigation.
  4. That the offences have been committed within the jurisdiction of this Hon’ble Court since the Form 6 of Registrations of Electors Rules, 1960, Form 2(b) and Form 26 of the Conduct of Election Rules, 1961 by the accused were submitted in SDM’s office at 12/1, Jam Nagar House, Shah Jhan Road, New Delhi, well within the jurisdiction of Police Station Tilak Marg, and hence this Hon’ble Court has the jurisdiction to entertain, try, summon the accused person and punish him for the offences committed by him in violation of laws referred to above

PRAYER
It is therefore most respectfully prayed that this Hon’ble may proceed against the accused person and be further pleased to summon, convict and sentence the accused person, in the interest of justice to the complainants and the also the public at large. And/or pass any other order or direction which may serve the ends of justice.

COMPLAINANTS
NEW DELHI
Dated:

Through Counsel

V.K. Malik and Rahul Raj Malik,
C/o Malik Raj & Co.
438, Lawyers’ Chambers
High Court of Delhi
New Delhi
9810705405

IN THE COURT OF ADDITIONAL CHIEF METROPOLITAN MAGISTRATE (NEW DELHI DISTT), PATIALA HOUSE COURTS, NEW DELHI

COMPLAINT CASE NO.________/2014

IN THE MATTER OF:

Sh. Neeraj Saxena & Shri. Anuj Kumar Agarwal
(office bearers of Maulik Bharat Trust)       .......Complainants
Versus
Sh. Arvind Kejriwal       ........Accused

MEMO OF PARTIES
Sh. Neeraj Saxena S/o Shri O. P. Saxena
Shri. Anuj Kumar Agarwal S/o Dr. M.M. Agarwal
Both office bearers of Maulik Bharat Trust
4852/24, Basement, Ansari Road,
Darya Ganj, New Delhi 110002       ........Complainants

Versus

Sh. Arvind Kejriwal
S/o Sh. Gobind Ram Kejriwal
R/o Bunglow No. 41, Hanuman Road
New Delhi       ........Accused

COMPLAINANTS

Dated: 1 February 2014
V.K. Malik, Rahul Raj Malik & Rajeev Chauhan ( Advocates )

C/o Malik Raj & Co.
438, Lawyers’ Chambers
Sher Shah Suri Marg
High Court of Delhi
New Delhi.
9810705405

IN THE COURT OF ADDITIONAL CHIEF METROPOLITAN MAGISTRATE (NEW DELHI DISTT), PATIALA HOUSE COURTS, NEW DELHI

COMPLAINT CASE NO.________/2014
IN THE MATTER OF:
Sh. Neeraj Saxena & Shri. Anuj Kumar Agarwal
(Office Bearers of Maulik Bharat Trust)      ........Accused

Versus

Sh. Arvind Kejriwal       ........Accused Accused

Index

Sl. No. Particulars Page No. Court Fees
1. - Memo of Parties - -
1. - COMPLAINT UNDER SECTION 125 A OF REPRESENTATION OF PEOPLES ACT, 1951 AND UNDER SECTION 31 OF REPRESENTATION OF PEOPLES ACT, 1950 alongwith Supporting Affidavit. - -
1. - List of Witnesses - -
1. - List of Documents - -
1. - Vakalatnama - -

DATE:
COMPLAINANTS

V.K. Malik, Rahul Raj Malik
& Rajeev Chauhan
C/o Malik Raj & Co.
438, Lawyers’ Chambers
Sher Shah Suri Marg
High Court of Delhi
New Delhi.
9810705405

IN THE COURT OF ADDITIONAL CHIEF METROPOLITAN MAGISTRATE (NEW DELHI DISTT), PATIALA HOUSE COURTS, NEW DELHI

COMPLAINT CASE NO.________/2014
IN THE MATTER OF:
Sh. Neeraj Saxena & Shri. Anuj Kumar Agarwal
(office bearers of Maulik Bharat Trust)      ........Complainants
Versus
Sh. Arvind Kejriwal       ........ .Accused

AFFIDAVIT
I, Neeraj Saxena, S/o Sh. Om Prakash Saxena, aged about 50 years, office bearers of Maulik Bharat Trust, 4852/24, Basement, Ansari Road,Darya Ganj, New Delhi 110002, do hereby solemnly affirm and state as under:

  1. That I am one of the complainants and the office bearer of Maulik Bharat Trust in the above noted case and am fully conversant with and competent to depose to the facts and circumstances of the case.
  2. That the accompanying Complaint Under Section 125 A of Representation of Peoples Act, 1951 and Under Section 31 of Representation of Peoples Act, 1950 has been drafted under my instructions and the contents of the same have been read over by me and the contents thereof are not repeated herein for the sake of brevity.
  3. That the contents of the accompanying complaint may be read as part of this affidavit.
  4. That the contents of the accompanying complaint are true and correct to my knowledge.

DEPONENT
VERIFICATION:
      Verified at New Delhi on the ___ day of Jan, 2014, that the contents of my above affidavit are true and correct to my knowledge, no part of it is false and nothing material has been concealed therefrom

.

IN THE COURT OF ADDITIONAL CHIEF METROPOLITAN MAGISTRATE (NEW DELHI DISTT), PATIALA HOUSE COURTS, NEW DELHI

COMPLAINT CASE NO.________/2014
IN THE MATTER OF:
Sh. Neeraj Saxena & Shri. Anuj Kumar Agarwal
(Office Bearers of Maulik Bharat Trust) ……..…..Complainants
Versus
Sh. Arvind Kejriwal …….……...Accused

LIST OF DOCUMENTS

Sr. No Particulars Pages
1. ANNEXURE A/1: A copy of the trust deed  
2. ANNEXURE A/2: A copy of the order dated 22.1.2014 of the Hon’ble High Court  
3. ANNEXURE A/3: A copy of the notice dated 31.1.2014 and R.T.I. dated 31.12014  
4. ANNEXURE A/4: A copy of The judgment of the Apex Court in “Resurgence India vs Election Commission of India and another W.P. (Civil) 121 of 2008  
5. ANNEXURE A/5 (COLLY): A Copy of the AFFIDAVIT filed by accused  
6. ANNEXURE A/6 (COLLY): A Copy of the notification of District Magistrate, Ghaziabad under Uttar Pradesh Stamp Valuation of Property (Second Amendment) Rules, 2013  
7. ANNEXURE A/7: A Copy of the postal receipts, online consignment track result bearing no. EU069890213IN and a copy of the retuned envelope containing  
8. ANNEXURE A/8: A copy of the postal receipts and online consignment track result bearing no. EU069890227IN  
9. ANNEXURE A/9: A Copy of the issue of Danik Jagran dated 29.6.2013  
10. ANNEXURE A/10: A copy of letter issued by the Delhi Police to the accused along with his reply  
11. ANNEXURE A/11: A copy of the trust deed of PCRF  
12. ANNEXURE A/12: A Copy of the audit report dt. 3.7.2012 along with a typed copy  
13. ANNEXURE A/13: A Copy of the biography from the Ramon Magsaysay Award Foundation  
14. ANNEXURE A/14: A copy of Annexure –X (Chapter V, Para 5.13) from the notification dated 1.8.2012 of Ministry of Law and Justice along with a copy of relevant laws and forms  

COMPLAINANTS

Dated: 31 January 2014
V.K. Malik, Rahul Raj Malik
Advocates

C/o Malik Raj & Co.
438, Lawyers’ Chambers
Sher Shah Suri Marg
High Court of Delhi
New Delhi.
9810705405

IN THE COURT OF ADDITIONAL CHIEF METROPOLITAN MAGISTRATE (NEW DELHI DISTT), PATIALA HOUSE COURTS, NEW DELHI COMPLAINT CASE NO.________/2014

IN THE MATTER OF:
Sh. Neeraj Saxena & Shri. Anuj Kumar Agarwal
(Office Bearers of Maulik Bharat Trust) ……..…..Complainants
Versus
Sh. Arvind Kejriwal …….……...Accused

LIST OF WITNESSES ON BEHALF OF THE COMPLAINANTS

  1. Sh. Neeraj Saxena i.e. One of The complainant
  2. Sh. Anuj Kunmar Agarwal i.e. One of The complainant
  3. Ms. Gargi Mishra D/o Sh. S. K . Mishra R/o 8/262, Rajindra Nagar, Sector 3, Shahibabad, Ghaziabad, U.P.
  4. Sh. V. Renganathan, Addl. Commissioner of Police, Security, New Delhi, along with records of correspondence regarding provision of Z category security to Sh. Arvind Kejriwal.
  5. Office clerk/record keeper District Magistrate, Ghaziabad, with Records of Circle rates of Indirapuram, Ghaziabad.
  6. Office clerck/record keeper of Senior Superintendent of post offices of Ghaziabad with record of service/delivery/return in respect of postal receipt no. EU069890213IN & EU069890227IN.
  7. Record Keeper, Election Office of CEO-Delhi, Election Commission of India New Delhi Assembly Constituency, with records of Form 6 of Sh. Arvind Kejriwal.
  8. Returning Officer of New Delhi Assembly Constituency along with Nomination papers and form 26 of Sh. Arvind Kejriwal
  9. Any other witness at the own responsibility of the complainants and with the permission of this Hon’ble Court.

Trustees of Maulik Bharat
  • Rajesh Goyal
  • Vikas Gupta
  • Anuj Agarwal
  • Pawan Sinha
  • Ishwar Dayal
  • Dr. Amarnath
  • Dr Sunil Maggu
  • Gajender
  • Susajjit Kumar
  • Sh.Rakesh
  • Col. Devender
  • Smt. Usha
  • Umesh Gour
  • Anant Trivedi
  • Neeraj Saxena
  • Sudesh
  • Prashant
  • Pradeep
  • Ranveer
  • Kamal Tawari

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