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.

COMLAINANT

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 Honble 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 Honble 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

Honble 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/420/428/429/ 120 B 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 Honble 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