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To Phagwara, 06th Sep 2021
The Station House Officer,
City Police Station,
Phagwara-144401 (Pb)
Sub: Request to lodge FIR against the Fraudster who cheated and defrauded the complainant by diverting funds from State bank of India’s account to Axis Bank Account to someone else’s account.
1. Axis Bank,
2. G-Pay, (Google Pay)
3. HDFC Bank,
4. Unknown Fraudster who cheated complainant in connivance with Axis Bank’s officials.
Sub: Offence of Cheating and fraud and credited amount in Rajneesh Madhok’s Account of Axis Bank, whereas the complainant Rajneesh Madhok has no account in Axis Bank. Whereas the Complainant is maintaining account No. xxxxxxx9618 with State Bank of India.
Google Transaction ID: CICAgODy2Z7LPg
UPI transaction:[protected]
HDFC BANK XXXXXX7961
AMOUNT : ₹320.00
To: RAJNEESH MADHOK madhok.[protected]@okaxis --Whereas the complaint has no account with Axis Bank and do not have this E-mail id with Axis Bank.
From: SAMIPTA (HDFC Bank): [protected]@okhdfcbank
Sir,
1. It is being brought to your kind notice that under Sections 420 (Cheating and dishonestly inducing delivery of property), 467 (Forgery of valuable security, will etc), 468 (Forgery for purpose of cheating, 471 (using as genuine a forged document), and 34( Acts done by several persons in furtherance of common intention).
2. That the said Fraudster has defrauded the complainant by transferring funds from Mobile Number : [protected] by fraudulently opening account in Axis Bank in connivance with the Bank officials without verification of the KYC documents. The reason of getting the funds transferred in Axis Bank is on the basis of fraudulent activities conducted by the frauduster who got the funds transferred in Axis Bank whereas Rajneesh Madhok complaiant has not having account with Axis Bank. The transfer of funds in another’s account can not be possible without the proximity of the bank’s staff and through Cyber crime these activities got accomplished.
3. That the amount has been credited in Axis Bank’s Account. Whereas the complainant has been maintaining the Account No. xxxxxxx9618 with State Bank of India.
4. That the funds can not be transferred to any other’s account without the proximity of Bank’s staff. The amount of ₹320/- has been credited in Axis Bank Account of someone else is a criminal conspiracy to commit and offence with Section 120B IPC: Punishment of criminal conspiracy.—
(1) Whoever is a party to a criminal conspiracy to commit an offence punishable with death, 2[imprisonment for life] or rigorous imprisonment for a term of two years or upwards, shall, where no express provision is made in this Code for the punishment of such a conspiracy, be punished in the same manner as if he had abetted such offence.
5. That police investigation is required in the matter that when the complainant has never operated the account in Axis Bank then how the funds got transferred in Axis Bank’s account and not in the name of Complainant whose Mobile Number [protected] has been linked to the account. How the said Mobile Number got attached with Axis Bank’s Account. The alleged Cash received by the Fraudster with the name of complainant without entrance of KYC documents in the AXIS Bank Account is a matter of debate due to the complicity of the Bank officials with the Fraudster and so the fraudster should be booked.
6. That the Complaint kindly be registered and challan kindly be presented and charges kindly be framed against the accused. The offence is triable by the Honourable Magistrate of Phagwara, so this complaint is being registered at City Police Station Phagwra to lodge FIR against the accused persons involving AXIS Bank, HDFC Bank, Google Pay with whose proximity the frauds are being conducted.
7. That the fraud got conduted without furnishing the Evidences like Aadhar Card which is mandatory to the link Bank account with the said bank. How Axis Bank got the said account linked with the account number of fraudster.
8. That the Faudster has played the fraud upon the complainant by forging documents of Aadhar card that is why that account got linked with Axis Bank account of Complaiant where the complainant has never operated the account. So on the basis of forged documents Axis Bank would have linked the Mobile Number of complainant [protected] in someone else’s account.
9. That Axis Bank is hereby guilty and would be summoned to produce the unimpeachable documents in the competent court regarding the identity of the account holder with name and Phone number by which the said Phone number had been linked with the Account of Axis bank by the Frauduster.
10. That Axis Bank is being requested with serving of this complaint to provide the copy of documents supplied by the Account holder who had opened in the account in your bank in the name of Rajneesh Madhok whose account got linked with Phone numner [protected] and the documentary evidences of the Aadhar Card or any other document supplied in the bank and the name and designation of the authority who verified those documents. On which date that account got opened, name of witness who submitted the introduction in that account with name and address of the introducer.
11. That list of witnesses those are involved in this fraudulent transaction kindly be submitted to the complainant and name and address of the persons in whose account the said amount got credited be provided so that the list of witnesses can be submitted in the Court for summoning the accused and witnesses.
12. That the complete documents on record kindly be submitted to the complainant so the nexus of fraudulent persons can be unearthed and recovery from the accused persons can be made and modus operendi of the accused can be brought in the knowledge of Administration.
Thanking you,
Yours sincerely,
Rajneesh Madhok,
M.Com, LL.B, DFS, LL.M. (Criminal Law)
Advocate, Punjab & Haryana High Court,
Railway Road, Phagwara-144401(Pb)
Ph:[protected]M),[protected], E-mail: [protected]@yahoo.com
Oct 25, 2021
Complaint marked as Resolved Axis Bank customer support has been notified about the posted complaint.
Verified Support
Sep 13, 2021
Axis Bank Customer Care's response Hi Rajneesh, we request you to liaise up with the account holding bank from where the amount has been debited for further assistance in the referred matter. Regards, Team Axis Bank
