IG S LEGAL
Ref. No.GSL/GS/0018/
BY HAND DELIVERy /R.P.A.D.
To:
1) Directorate of Prosecution Maharashtra State, Khetan Bhavan, Flat No.8, 5‘" Floor, J. Tata Road, Churchgate, Mumbai -400 020.
2) The Principal Secretary (Law & Judiciary), Govt of Maharashtra, Mantralaya Mumbai.
3) The BarGouncili Fligh Gourt Builc Mumbai.
4) Commissioner c Crawford Marke Dhobi Talao, Ch lat Fort, Mumbai, N ah; etrtarry; laa
5) Special Commi^^on^ Main Building, 1=' FW<nr, Commissioner of Police Office Compound, Crawford Market, Lokmanya Tilak Rd, Police Colony, Dhobi Talao, Chhatrapati Shivaji Terminus Area, Fort, Mumbai, Maharashtra - 400 001.
6) DCP Zone 3, Mumbai Police Worli Police Station Building, Second Floor, Dr. Annie Besant Road, Worli, Mumbai-400 030.
s + 91-22-45119915 gi office(agslegal.in
25 March 2025
lOA, P' Floor, Bahubali Building, Cawasji Patel Street, Fort, Mumbai - 400 001.
7) The Senior Inspector, Tardeo Officer Quarter B No.1, Ground Floor, M. P. Mill Compound, Tardeo, Mumbai-400 034.
8) Director General, Anti-Corruption Bureau of Maharashtra, 6'"' Floor, Sir Pochkhanwala Road, Worli Police Camp, Worli, Mumbai - 400 030, Maharashtra, India.
9) Chief Vigilance Officer Finance Department, Government of Maharashtra 5^^ Floor, New Administrative Building, 0pp. Mantralaya, Mumbai-400 032.
Sirs, i
Sub: Act^n aifi / Krinti^atwl) lar
d dppa|-tm^nt|l enqmrymfothe activities of (1) Ms. |\s s ecutor, Girgaon Mjbtrtfpjifita^ Mfegi^lrate Court, and 1(2) the Office of the Public Pro4ecitfl)r.
Re:
M{s©*J^3filMation No. 1015 of 2024 fi^ b^l^r^tne Qd u rt of Addition a I Chief Judicial Magistrate Co^, G^gaon, Mumbai to chaUpTrige the Closure Report fjj^ bytardeoTOTeii’SfafJ^fh in ptR No. 544 of 2023 (“FIR”).
We are concerned forydur client, Mr. Rajesh^Batf at We are addressing this letter to you on behalf of our client, in connection with the captioned Protest Petition, to place on record certain disturbing but pertinent facts which have a direct bearing on the captioned matter. Under instructions from our client, we state as under;
Our client is an accused in the FIR. The purpose of this letter is to draw your attention to dishonest and suspicious actions on the part of Ms Kranti Kambhar - Assistant Public Prosecutor (APP) in the Protest Petition filed by the original complainant, Mr. Puneet Bhatia. Our client believes that the APP has totally failed in her legal duties as a public prosecutor and has acted illegally, dishonestly and in a scandalous manner causing irreparable and serious prejudice and injury to our client. Our client further believes that this is a part of a larger conspiracy on the part of certain enforcement officials designed to unduly benefit the original complainant, Mr Puneet Bhatia, in the above matter and generally, in the matter of the FIR he has filed against our client. Page 2 of 6
we
These actions need to be investigated by your office and, if found true, your office needs to take appropriate action against the guilty government officials. Though various illegal and unethical influences seem to have been applied on behalf of Mr Puneet Bhatia at various stages of this matter (which we will deal with separately) limit ourselves in this letter only to the unethical, biased and illegal actions of the APP and the office of the Public Prosecutor in the Protest Petition.
Our client states that the original complainant, Mr. Puneet Bhatia, is a rich and influential individual and the Indian head of TPG- a large and reputable global fund. It is said of him that he is very well connected with public officials and politicians and the actions of which my client complains in this letter seem to be evidence of Puneet Bhatia’s influence and reach within the enforcement agencies.
Our client will also be drawing the attention of the High Court to these and other actions connected with this FIR in appropriate proceedings. !
1. pertaining tsr’th^cdptioned Protest P^titidj], wJiich are as follows: /
At the outset, it is np€essajy4;o'plabe oh report ceham pertinent background facts
a.
c.
The capjlon^ PrptestpetEtiori has beerilTtelJhy ftie original complainant Mr. Purpet ^haMa, y^fpra/ii'a, tb cha+teftge4he G-Summary Report dated 26 Novpm^’er i^i filpd by TardepX9iJce,Station (“Closure Report”) in conneltioil wiM a baseless and frivolous FIR (No.544 of 2023) filed by Mr. Puneet Bhptia aj^lnstbur pHenT
The Ta[de(>Polipe station has thorqu^^ Investigated the FIR and after a periodmf 12/hoiphs of investigation, came fo the conclusion that no criminal Qffence'could beThade out dgairrst our client in terms of the allegaliohs p4a4e--4o-tT^^e T Clpsure Report is a detailed and comprehehsive document totalling'about 400 pages which relies on exhaustive evidence in support of its conclusions. It is obvious that the Tardeo Police Station has diligently fulfilled its duty.
b. Further, it is reliably learnt that the said Closure Report adheres to the standard practice followed i.e. it is signed/approved by 5 senior officers (including the concerned AGP and DGP (Zone III) of the Tardeo Police Station), of the Mumbai Police Department.
d. The captioned Protest Petition was filed before the Girgaon Magistrate’s Court on 21 January 2025.
Cur client has been reliably informed by well-wishers in the Girgaon Court, that the APP has been heard to say aloud in the Girgaon Court on 14 February
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3.
4.
2025 that she is under tremendous pressure from the office of the public prosecutor to adopt a particular position. Since the APP’s submission in her reply to the protest petition, fully supports the original complainant Mr. Puneet Bhatia, and is, in fact, very similar to, relevant parts of Mr. Puneet Bhatia’s protest petition, it is obvious that, assuming these sources are accurate, the APP has been compromised and coerced into action by her superiors within the office of the public prosecutor in Mumbai to achieve a mala fide result, and to favour, Mr. Puneet Bhatia, the petitioner in the above protest petition. Our client has been informed that the persons involved in this scandalous scheme include (i) the APP, Ms. Kambhar, (ii) unknown officer or officers in the office of the public prosecutor who coerced/compelled/influenced the APP into supporting Puneet Bhatia’s interests; and (iii) a (now) retired high ranking member of the police authorities who has been actively advising, and manipulating procedures and exploiting his government contacts, on behalf of Mr. Puneet Bhatia, from the time of filing of the FIR till today.
It is also interesting^^ not§jtfvat within)2 of 3 clays^eWhe APP submitting her response to the pfrgaptT court, she we.ht op training leave. So on the date of the hearing tb^ Al^ w|is''riot;present inj court and the substitute public prosecutor did nqf‘kno\A/ the fa^ts pf the ca'sFarWwas absolutely silent. This is absolutely/shqckit/g apdfgross niiscef>4wet-en4h«-^art of the office of the PP. it almos|seemsihat by p comple^x_neparious_and J^^^^^^ scheme, the young APP was in|lue^ce(^fto^^brnff an illegal and unprecedented response and then go on ieavp. Thjs' ha§/Cau§€TrpaWTTciTTfTTO'my client. There is also a strong disci|ssi(i)n,,Mf theXjirg^n Qeuftthat.4Pe.4,aagUage of the reply filed by the APP has no^beqa' dra^ed b$Jh_e APP^ut rather drafted by some other person. If true, thi^s serious and criminal mi^donduct.
The above i4f&rrri^r©f^at.^ag4:aqh'2'and Sjattove) is evident from the below conduct of the,APP on 14 February 2J)2^-cfuring the course of the hearing that took place before the Learned Metropolitan Magistrate’s Court at Girgaon;
(a) The APP filed a reply in court which exactly approved the points made by Mr. Puneet Bhatia. This is totally ludicrous and absurd in the facts of the case and absolutely unprecedented. All senior criminal counsel we have spoken to confirm that this attitude of the APP is totally unprecedented. The reply filed by the APP seems to be a copy and paste of relevant parts of Mr. Puneet Bhatia’s protest petition. The Closure Report (consisting of about 400 pages) contains vast amounts of evidence and took almost 12 months to investigate and prepare. Flowever, the APP has made no attempt to give reasons or understand the facts of the case or the law, which is highly suspicious. Our client has been reliably informed that the police had specifically instructed the Public Prosecutor to defend the Page 4 of 6
Closure Report before the Learned Magistrate. Despite these instructions, the APR filed a reply that, astonishingly, supports Mr. Puneet Bhatia’s grounds, recommends rejecting the Closure Report, and advocates for further investigation. Thus, it is evident no approval was ever taken from the Investigation officer to file such a reply.
(b) What is even more concerning is that the contents of the protest petition, including the frivolous points raised by Mr. Puneet Bhatia, have been reproduced verbatim in the APP’s reply. Additionally, our client has been reliably informed by well-wishers that the concerned APP was overheard stating that she is under tremendous pressure in this matter and that she was instructed by her superiors in the Public Prosecutor’s office to file this reply. This sequence of events raises serious questions regarding the motives behind the APP’s actions and warrants further investigation,
(c) Under Indian la\A^^ap€h^a"pu^liciDro|eci|l^^^^ in order for an APP to do her job, sh^.n^dslO'-tefe tofellyifarr ilia| witlrthfe facts of the case and the investigd’tiom^d n^edsj to get delailed input from the police authoriti^ It fj-orrl thq co tduct of th| APP in court and the state ofAn^lesfge ^he (display3d in~"operPcourt, that she had no understendmg dr f^ffi liarfty vyith We-fa'Cts-of-thp case. This is grossly illegal andp hi|^'lTiisj3oncjuct[ftQjJh£.^^LLflJJiisJ\PP which has caused seriouq in ustrce accused and the police authorities who conducted an e^ellejafanj^4ilHoratFmve^tTpit^
^fori^htteEKfier sfatutorv obligations. Among others, she has ithical, impartial, unbias^M, honest and to assist the o r“f?relTiTtTfTFrf
(d) The APP h the legal dut\^ be court ill tb« search of confWctfiled in cow^bythe APP this AP act^f the case. With the nature d the^,€f^ngerously biased statements laS’abandoned her duty.
(e) We Strongly believe that the APP’s biased and illegal approach to this matter has influenced the outcome in the matter. Our client has been seriously prejudiced by the conduct of the APP. Justice and fairness has not been done to our client in this matter by the office of the Public Prosecutor.
(f) Our client states that it was APP Ms. Kambhar’s responsibility to argue the stand taken by the police in the Closure Report before the court, unless instructed otherwise. Our client states that his advocates present in court on the date on 14 February 2025, reported that the Investigating Officer stepped in the witness box and fully supported his closure report and requested the court to dismiss the protest petition as there is no
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merit in the protest petition. However, contrary to the Investigating Officer s submissions, the APP, on her own initiative, filed a reply requesting the court to direct further investigation. This is shocking and a gross violation of law and practice and totally unethical,
(g) This entire episode casts serious doubt not only on the professional integrity of the concerned APP but also shows how the legal and enforcement system of Mumbai can be manipulated. Such is the extent of this influence that the APP was compelled to act against her brief and file a suo moto submission supporting the protest petition.
5. or conspiracy
The conduct of the APP Ms. Kambhar and the motivations behind it warrant a thorough investigation. As a law-abiding citizen who has fully cooperated with the authorities thus far, our client’s faith in the criminal justice system has been deeply shakeri___^ the above events and the implications they have.^*^" ) si f f I
In view of the aforesaigK ou interest of integrity of p^lient^C^uqsts yoL| to into the above in the ici^^^oc^ss |nd :he fjublic’s fail|h in justice.
“Tonra faithfully, G S LEGAL roprietor
C.C.:
1. The Principal S Chief Minister of 6th Floor, Mantralaya, Mumbai.
2. Shri Amit Singh Negi
Additional Secretary
Prime Minister’s Office South Block, Raisina Hill, New Delhi -110 011.
3. Shri Govind Mohan
Home Secretary
Ministry of Home Affairs North Block, Raisina Hill, New Delhi -110 001.
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