SDJM ordered FIR in Beef biryani matter of Mewat







IN THE COURT OF SDJM FP JHIRKA

NARESH KADYAN
COMMISSIONER, BHARAT SCOUTS AND GUIDES, HARYANA,
MASTER TRAINER, ANIMAL WELFARE BOARD OF INDIA,
R/O C-38, ROSE APARTMENT, PARSHANT VIHAR,
SECTOR-14, ROHINI, DELHI – 110085.


          COMPLAINANT


VERSUS

  1. VIKIL S/O SALIM ( QUARSHI ) R/O DOHA  PS FEROZEPUR JHIRKA  NUH
  2. SAJID  S/O JAFRU  R/O  VILL. DOHA  PS FEROZEPUR JHIRKA  NUH
  3. HAKIM S/O JAKIR R/O VILL.  DOHA  PS FEROZEPUR JHIRKA NUH  
  4. JAMSHED  S/O TALAM  R/O VILL. DOHA  PS FEROZEPUR JHIRKA NUH
  5. ISRAIL S/O GANNI  R/O VILL.  RAWLI,  F.P. JHRIKA  NUH
  6. MOHAUI S/O  FARRUKH , R/O  VILL. DOHA  PS FEROZEPUR JHIRKA NUH
  7. IRSHAD   S/O JUBER R/O  VILL. DOHA  PS FEROZEPUR JHIRKA   TEHSIL FP JHIRKA DISTT NUH.

  …    ACCUSED  


P.S.  FEROZEPUR JHIRKA  


COMPLAINAT U/S  188/153A/268/ 295A/428/429 IPC READ WITH  3/11/38 OF PREVENTION OF CRUELITY TO ANIMAL ACT 1960 AND 3, 5, 8 WITH  13 OF HARYANA GAUVANSH SARKSHAN AND  GAUSANVARDHAN ACT 2015


Sir                                                    
                    The complainant respectfully submits as under-                
MOST RESPECTFULLY SHOWETH: -
1.            That the complainant is law abiding citizen of India and is permanent resident of C-38, ROSE APARTMENT, PARSHANT VIHAR,  SECTOR-14, ROHINI, DELHI .  The complainant is commissioner Head Quarter of Bharat Scouts and Guides Haryana, besides it he is a Master Trainer of the Animal Welfare Board of India (Ministry of Environment, Forest and Climate Change (Govt. of India).  He is fully competent to file the present complaint before this Hon’ble court.
2.            That  in the year  2015  the  new act Haryana Gauvansh Sarkshan and Gau Samvardhan Act  2015 enforced  for the prevention of Cow slaughtering  and a secret  information  was received  at the office of  Smt.Bharti Arora, IPS,  the then DIG  of Haryana Police  that cow slaughtering at full swing around Mewat region of Haryana and she informed the Director General of Police under intimation to the Chairman of Haryana Gau Seva Ayog,, copy of that letter also attached as ready reference, it is further alleged that calf and cattle meats were being supplied after mixing  in  Biryani by some persons  at village Mundaka Tehsil around FP Jhirka  
3.            That after receiving  of secrete information the concern Police  officer approached the Deputy Director of Animals Husbandry    and Dairing at Nuh in Mewat   requesting him to appoint – depute Veterinary  Surgeon  to  lift / collect the sample of  objectionable meat Biryani, keeping in Police request in writing  said Deputy Director deputed Dr Amir Singh Solanki, Veterinary Surgeon  to collect / lift the sample  of objectionable meat Biryani  in the presence of local Police, they lifted seven meat biryani samples, which were collected from the  possession of above said accused  no 1 to  7, these objectionable samples were  sent to Lala Lajpat Rai University  of Veterinary and Animal Sciences Hissar (Luvas )  which is recognized by the Govt of Haryana vide letter No.  2269-9567 dt 22-8-2016, Copy  attached  with the complaint
4.            That the said competent University, after testing / Diagnosis   all seven meat samples, gave their finding results - report that all seven meat samples are from cattle species, which were  taken from the possession of accused no 1  to  7, in the presence of Police by the Veterinary Surgeon.
5.            That after the said report of LUVAS, the Veterinary Surgeon again asked clarification of terms “Cattle” from Luvas, which were clarified and confirmation was given by the Professor and Head of Department of Luvas  that the cattle means cow  /oxen, after getting this confirmation report, SDO  Animal Husbandry and Diary Department, FP Jhirka Mewat sent the same clarification report on dated 2-6-2017 and received by  SHO of PS FP Jhirka.
6.            That  said SDO also sent similar clarification report  to the In charge  Anti Cow slaughtering staff Nuh for further necessary action .
7.            That complainant   moved a complaint in this regard, to lodge FIR before Chief Minister Haryana under intimation to SHO of FP Jhirka and SP Nuh as well, besides it CM Window mechanism was also used, bearing no.  047794 dt 2-5-2017 but no action has been taken by police Department till now and it was shocking that local Police misguided their top Officers that nothing was happen, likewise wrong facts were recorded that matter under trial without lodging any FIR of the cognizable and non bailable crime against cow progeny.
8.            That  the complainant is the  active and social  citizen of India  and he is also fully  devoted his Hindu religion  and their emotional and sentiments – believes were heart for the said type of unlawful cow slaughtering and trading of beef biryani, he has moved illegal slaughtering of cow and beef biryani matter with many Authorities but  all in vain hence moving present complaint
9.            That the present occurrence taken place within the territorial jurisdiction of this Hon’ble court hence this Honble court has fully jurisdiction to try and decide the present complaint.
10.       That a fixed court fee of Rs  10/- has been  paid on the  complaint
 It is therefore prayed that the present complaint may   kindly be sent to PS  FP Jhirka  u/s 156(3 ) CrPC for registration of the FIR against the accused persons, and they may be punished according to law.
                              It is further prayed that any other relief which this Hon’ble Court may deem fit and proper, also  may kindly be granted to the  complainant.
Date October 13, 2017                                         complainant 
                      NARESH KADYAN


IN THE COURT OF SDJM FP JHIRKA

NARESH KADYAN                                     VERSUS                    VIKIL

COMPLAINAT U/S  188/153A/268/ 295A/428/429 IPC AND 3/11/38 OF PREVENTION OF CRUELITY TO ANIMAL ACT 1960
AND 3, 5, 8  13 OF HARYANA GAUVANSH SARKSHAN AND
 GAUSANVARDHAN ACT 2015
Affidavit
 I NARESH KADYAN, COMMISSIONER, BHARAT SCOUTS AND GUIDES,  HARYANA, R/O C-38, ROSE APARTMENT, PARSHANT VIHAR, SECTOR-14, ROHINI, DELHI  do hereby solemnly affirm and declare as under –

1        That I  am filing the present complaint before this Hon’ble court
2        That  I am fully conversation with the facts and circumstances of the complaint
3        That I a active and social  citizen of India  and I am fully  devoted Hindu religion  and our sentiments, believes and emotions were heart for the said type of unlawful cow slaughtering and acts.

Deponent


Verification- verified that the contents of the  complaint are true and correct to the best of my knowledge and belief    verified at
Date October 13, 2017
Deponent

S.NO
PARTICULARS
PAGE NO
COURT FEE
1
Memo of parties


2.
Application u/s 156(3) Cr.PC with affidavit


3
List of documents along with documents










FEROJEPUR JHIRKA                                                  APPLICANT
DATED: October 13, 2017                                   





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