Affidavit I am uneducated My 14 years research and actual experience with100% evidences

Al Rafa Police Station

Residing at apartment No. 302, Al Mansour Building, near Ramada Hotel, Bur Dubai.

Director, Al Rafa Police Station

Please permit us to furnish the following:

1. 
   The above complainant is a bank established in England and licensed to operate in Dubai (the Bank).
   

2. 
   The complainee is an Indian national, residing at the above-mentioned address.
   

3. 
   The bank has previously approved the cheque No. 404976, drawn to the account of Besco International at the bank, for the benefit of the
   
4. 
   above-mentioned complainee for an amount of Dirhams One Hundred Thousand (200,000) provided that the same is presented on a specified
   
5. 
   date, which is 15.06.1996. (Copy attached)
   

6. 
   On 15.10.1998, the complainee presented the cheque to the bank and requested the value of the same.
   
7. 
   Upon perusal, it appeared that there is a clear alteration on the due date specified on the cheque.
   
8. 
   Therefore, the bank refused to pay the value of the cheque (Original attached).
   

9. 
   In addition to the above-mentioned, the issuer of the cheque, Besco International, did not have a credit balance on the date when the
   
10. 
    cheque was presented, but was indebted to the bank for an amount that exceeds the value of the cheque.
    

7. 
   One of the persons, who signed the approval of the cheqe on behalf of the complainant bank, left the service at the bank since 1996, and the other one left the said branch since 1996 and has been transferred to the branch of the bank in Qatar since April 1997. The book from which the cheques were drawn has been given in 1995.
   

7. 
   The complainant bank sees that the act of the complainee in seeking taking over the bank’s money in the said manner is considered a violation to Articles 216 and 399 read with Article 34 of the punishment law.
   

Therefore, the matter requires taking the necessary procedures in pursuing the complainee and anyone proved to be involved in approving such fraud manner.

Thanks and regards.
Stewart Hamond

(Signed)

Case Type	Year	Serial Number

Mr. Esam Elhamedani pleas gave me justice my 13complaint with you

Mr. Esam Elhamedani pleas gave me justice my 13complaint with you

Mr Shri 0561700046, and 05042886453

Abdulla Abou-baker0509817297 and 0504221336
Mr. Shri Pal taking 50, 000 Dirhams. And he told me “You stop other lawyer, I control everything. Zhang & MR. RAJ BERNARD FINALIZED CHARGES WITH ME 150,000 DIRHAM’S.?
Dar Al Hekma Law firm Damage UAE Multi-Million Project Fame Device Check website www.fame.ae

If this duplicate project or this people run this project similar this lawfirm is responsible.

Dayal Mansukhani

Free Ad Media LLC

Atruim Center 3^rd Floor 306

Bank Street Bur Dubai

The  Chief Prosecutor

Dear Sir,

It is with profound respect and honour that I forward this present complaint and facts to your high office for your immediate reaction.

I wish to state that Mr. Zhang Guoyin use to be an employee in my establishment and he worked with me for some time until he breached the employment contract we had last year.

I had engaged his services in China from 2006 and later asked him to move to Dubai since the business was now located in Dubai. He was my main buyer and also assumed the role of main secretary and personal assistant. He therefore knew my banking information.

Mr. Zhang had illegally transferred money from my accounts in China and Australia to his account since he had my ATM card information. He obtained my ATM card information fraudulently and without my authorization cleared my accounts in Hong Kong, China and Australia. I made a complaint to the Chinese police but I later dropped the charges. He admitted the above facts in an email and I have evidence to prove the bank transfers he made to banks in China. It was not until late last year that I realized my ATM card that had gone missing in China was in his possession. He cleared my accounts in China and Australia such that I could handle my projects both countries. These are people who tarnish the reputation of China by duplicating goods belonging to others.I hag paid up to 70 000 rmb for patent registration but he did not register the patents rights before any Chinese authority.

From 2008 to July 2010, he received money from my wife but could not setup the project. Instead he used my idea and made duplicate products and sold in China.

Still I hired his services and for one month to work in my company in India before moving to Dubai.

.

I also gave him the sum of thirty thousand (AED 30 000) to book a container from China to Dubai but he failed to do so and till date I have not received the container.

I then engaged the services of Dar Al Mekma law Firm to represent me and protect my interest before the court and other authorities as the need may arise.

The labour suit was decided in Mr. Zhang’s favour and I was asked to pay the sum of Twenty Five(AED 25 000) to the count.

I issued two checks to Mr. Shri Pal Jain,that is one a check of Twenty Five thousand (25000)  to deposit at the court registry and one of Ten thousand(10 000) to establish a civil or criminal case against Mr. Zhang. Copies of both checks are herein attached. It is to my understanding that he failed to do both and to and was left to wonder whether or not he even bothered to represent my interest in court.

Mr Shri Pal told me he had registered a compliant with Rafa Police station and that he has filed an appeal of the labour suit.It therefore seems to me that some expatriate legal consultants use the name of local law firm to deceive foreign investors.

Since then he has not bothered to keep me informed and has been out of my reach. I honestly believe he is misrepresenting the reputation of the firm he works for as both his telephone numbers are unreachable that is 0561700046 and 05042886453.Also Mr. Abdulla Abou-baker has neither called nor brief me on the proceeding. His mobile numbers are 0509817297 and 0504221336.

It seems there have relocated to Fish Roundabout, Snow White Shop Building,2^nd floor, suit number 212.

At this juncture, I have been asked to bring the passport of Mr Zhang that has been in my custody and I have deposited the passport in Dubai court on the 17^th day of July 2011.I pray this passport should not be released as it will hold him back in the UAE until this case against him be decided.

Sir, I wish to crave your indulgence to use your high office to register this complaint if my above mentioned legal advisers have failed to establish one.

I also pray that you use your high office to bring this people to order. I am a 63 years old cardiac patient who has suffered a lot in the hand s of law breakers.I am willing to have an amicable settlement should they reply me with 24 hours and I will withdraw the compliant failing which, the complaint stands.

 While waiting and hoping that this complaint be taken into consideration, I wish you all the best in your endeavours. I will also send the mail to all lawyers in UAE seeking their assistance. I am willing to pay any fees to a lawyer who will provide his services.

In anticipation thereof I remain your humble complainant

من : ديال منسوخانى - هندى الجنسيه

الى سعادة مدير مركز شرطة الرفاعة

دبي ، الإمارات العربية المتحدة

يرجى زيارة http://www.needjustice.net/file24.docx تصل إلى فهم ظلم لي وتنزيل أدلة ضد السيد عبد المجيد.

أبلغ هنا كنت أشك أن الملازم عبد المجيد فاضل من شرطة الرفاعة ساعد بنك ستاندرد تشارترد في دبي إلى اعتراض لي في قضية كاذبة ، حيث لم يهتم للشيك الأصلي. أنا يقدم تفاصيل بضع شيكات مصدقة من بنك ستاندرد تشارترد.

1. شيك رقم : 404977

2. شيك رقم : 404976

وكان السيد عبد المجيد قدم لى التعذيب النفسى منذ عام 1998 وحتى الإمارات العربية المتحدة فقدت عدة ملايين من مشاريع حتى الآن. قد يكون قتل منذ ذلك الحين وصلتني رسائل بريدية وتعذيب العديد من السود. كان لي شكوى في محطة الشرطة في رفح شخص في نوفمبر 2011 وطلب السيد عبد المجيد. التقيت 3 التخصصات في شخص ولكن لم أتلق أي رد منهم. بعد أن سجلت المحامي بلدي شكواي مرتين مع الأدلة والصور. شكوى واحدة لا تزال غير موجودة في السجلات. وقد تسبب هذا بسبب سوء قصده.

 وأود أن تسجيل قضية جنائية في اسمه الذي كان سوء السلوك في المحكمة وبالتالي افساد سمعة الشرطة في العالم.الآن أطلب إلى هذه المحطة الرئيسية لمكافحة سوء السلوك من السيد عبد المجيد وأرسله إلى المدعي العام في محكمة دبي. سوف أحارب نفسي بما أنني الأب للقانون وانا سجلت شكوى ضد راج برنار. إذا كان الذباب بعيدا عن دولة الإمارات العربية المتحدة ، فإنه قد يسبب المليارات من الأضرار الناجمة عن المحطة.

وتفضلوا بقبول فائق الاحترام

ديال منسوخان

050 7570737

THE HUMBLE PETITION ON BEHALF OF THE PETITIONER ABOVENAMED
1 The petitioner is a Citizen of India having his address at as stated above in the cause title of the petition. The respondent NO. 1 is a Scheduled Bank, having its Head Office at United Kingdom. The respondent NO. 2 is a company duly registered under the company law of UAE.

2 The petitioner is a Businessmen and he was running his business from Dubai, UAE for around 25 years. The petitioner has traded and carried out business in Transportation, Textile trading, Finance etc. the petitioner has financed many individual and organization in Dubai. The petitioner has a good reputation in Dubai trade circle as he is very successful businessman. Though the petitioner has many friends in Dubai business class he has also attracted some enemies due to business competition.

3 The petitioner has financed respondents NO. 2 around 3 million Dhr. For different years, this finance was spread upto 2 years. All this financial transaction was by cheque payment. The respondent NO. 2 for discharging his legal debt issued some post dated Cheques in favour of the petitioner, a few Cheques were drawn on respondent NO. 1 Bank. Interestingly some Cheques were having endorsement from the respondent NO. 1 Bank “we guarantee that this cheque is good for payment on 15.10.98” believing the endorsement the petitioner agreed to accept post dated Cheques. Hereto annexed and Marked Exhibit A and B are the cheque dated __________ and ____________ respectively.

4 To the shock and surprise of the petitioner these bank guarantee cheque were dishonored by the respondent NO. 1 Bank. Initially the bank gave vague reasons for dishonoring the cheque but subsequently they stated in their memo that there are alteration in the Cheques as far as date are concerned. The petitioner challenged that contention the matter was highly contested and ultimately it was held that the bank officers were responsible for the alteration if any and they have endorsed their signature at the place of alteration. Hereto annexed and marked Exhibit C is the copy of the Forensic Lab report dated ___________.

5 The petitioner submits that once it was made clear that I was not responsible for the alteration in the cheques I should be given the cheque amount but surprisingly the bank and public prosecutor delayed that matter and when ultimately when the cheque was handed over to me the time for presenting the same lapsed. This way the public prosecutor and Dubai police is also responsible for causing delay under the guise of investigation. I reserve my right to sue them as and when situation permits.

6 The brief facts about the lis between the petitioner and the respondents is as under:-

a the petitioner went to dubai in around may 1977. he is a bussinesman his bussiness in dubai includes-Transportation, Cars selling and buying, Man Power supply- Whole sale Textile, and Financial support/Investor.

B BESCO- the respondent no. 2 It’s a Dubai Govt. Undertaking run by Dubai Labor Ministry. One Al Mullah is the Owner, who is in Business of Supplying Manpower from Asia and particularly from India.

C Dubai Dry Dock is another such company managed by the Dubai Government.

D One RAJ BERNARD is an Employee of BESCO holding a Managerial Capacity in BESCO.

E I financed BESCO since 1995 to 1997 Dec. I financed around 3 Million Dhm. To this company. Out of which I recovered around 1.8 Million and the outstanding is around 1.2 Millions.

F In December 1997 we have entered into New Agreement and BESCO issued me through Mr. Raj Bernard New Cheques for Balance amount. The balance amount was divided into 12 different Cheques, payable in installment.

G All these 12 Cheques were returned dishonored at different time and period. Besides these 12 Cheques 2 other Cheques were issued drawn at ----- Bank with Bank guarantee, these two Cheques were also returned dishonored. ( all during the 8 months period)

H All these Cheques were signed by Mr. Raj Bernard on behalf of BESCO.

I initially when the Cheques were returned dishonored I warn Mr. Raj Bernard on telephone.

J I filed a criminal case in Feb 1998 in Dubai Court. For 2.23. Lakhs Dhm. The amount being of two Cheques. ( pending this case my other Cheques were also returned dishonored)

K (I believe In UAE according to its law the place of issuance consideration is the place of filing of criminal complaint irrespective of the place of issuance of Cheques)

L Accordingly I filed complained in Dubai, Sharjah, and Ajman. Against Mr. Raj Bernard.

M All these cases proceeded simultaneously in different courts.

N The Dubai Court case concluded in July 1998. The court ordered and directed Mr. Bernard to pay me Cheques amount and he was fined for 2000 Dhm. This money was deposited in court which was afterward on given to me.

O In sharjah court the court directed the case to be transferred to Dubai court.

P Similarly the Ajman court also taken similar view.

Q In mean time the accused was put in police custody for around 10 days.

R Finally the Dubai court decided the cases so transferred to it and dismissed the case holding that I should file civil case.

S I filed civil case in 2000, being case No. 183 of 2000 the civil court ordered in my favour around 6 lakhs dhr. Aggrieved by this ordered we both went in to appeal.

T The appellate court dismissed my appeal and allowed the appeal of Mr. Raj Bernard.

U I went to Supreme Court in 2005 my appeal in Supreme Court was also dismissed.*

W I instructed my lawyer Mr. Bose to file civil case who following my instruction transferred theses cases to local lawyer.

X Thus I filed civil case against Raj Bernard.*

Y In the mean time out of the two Cheques drawn at --- Bank one Cheque returned dishonored, despite Bank assurance to Good Cheques. The Cheques returned with the remark refer to drawer. When I confronted with the officers of the --- bank they told me that bank Guarantee Cheques have been discontinued, and there is some fraud in issuance of this Cheques some Bank Officers might be involved.

Z Subsequently the --- bank dismissed its employee who has made endorsement on the Cheques.

Za I again represented the Cheques with the Bank this time the remark was alteration in Cheques.

Zb On the third time of my presenting the Cheques the Bank remarked alteration in date.

Zc I instructed my lawyer to issue notice to --- Bank, he accordingly sent notice on 2/8/98 ( Lawyer All Kaleen )

Zd On 5/8/98 the --- Bank filed complaint against me with Dubai Police regarding Cheques No. 404976 ironically this Cheques was never presented with the Bank)

Ze The police sent the said Cheques with the Forensic lab Dubai for investigation. Even in this matter thee is no reference o Cheques No. 4049776.

Zf The lab submitted the report that the Cheques looks as of 1996, there were three dated on the Cheques put by Mr. Raj Bernard and two Bank officers.

Zg The Dubai Police sent the matter to court.

Zh The court fined me 2000 Dhm. I paid the penalty and demanded the Cheques back.

Zi Since the Cheques was not returned to me I went to appeal court, the appeal court dismissed my appeal on fine part but directed to return the Cheques to me.

Zj Against this order both myself and Mr. Raj Bernard went to Supreme Court where the humble court continued my fine but ordered to return the Cheques back to me.

Zk In the mean time the other Cheques being chq No. 4049776 dated Oct 15 1998 matured and I presented the Cheques in --- Bank, surprisingly the --- bank without returning the Cheques to my Banker sent the Cheques to Dubai Police, which was informed to me by -- Bank.

Zl The Dubai Police ordered me o furnish bail Bond. And Cheques was sent to Forensic Lab.

Zm In Feb 1999 the Forensic lab sent its report that there is no illegal alteration on the said Cheques.

Zn The public prosecutor again sent the said Cheques for reexamination to the laboratory.

Zo The second report of the Forensic lab again concluded that thee is no illegal alteration on the Cheques.

Zp The public prosecutor directed the police to drop the case against me and return the Cheques to me. The Cheques was returned to me on 28/4/1999.

Zq I presented the Cheques with the Banker on 29/4/99 the same returned dishonored on the ground that the cheque was out of limitation.

Zr Thereafter I went to London before the Banking Ombudsman of == bank. I registered the complaint in around 2000 Sept. in Oct 2000 the Ombudsman rejected my complaint saying they do not have jurisdiction over the Dubai Bank.

Zs I have not filed any legal proceedings for the recovery of the cheque amount.

Zt In Jan 1999 Mr. Raj Bernard filed one case against me for recovery of 1 Million Dhm. The court ordered Mr. Raj Bernard to submit account with the court. He could not submit the account for nearly two years and as such the case was dismissed with costs.
Zu Raj Bernard went to appeal against the dismissal order, the appeal court appointed 3rd auditor for taking account, incidentally I was also in Dubai during that period so I requested my lawyer to produce account from my side to the auditor, I also personally visited the office of the auditor but he did not entertain me saying he do not have time.

Zv Since Aug 2002 I did not went to Dubai again.

Zw The appeal was allowed and court directed me to pay Mr. Raj Bernard 1.1 Million Dhm. My lawyer could not produce counter account form my side.

Zx As the audit done by the courts auditor was incorrect I directed my lawyer to file case against the auditor for submitting wrong account/audit.

Zy My lawyer did not file the case nor did he return me the case papers so I could file a case personally.

Zz There are many email correspondence between me and my lawyer.

Zaa I did not pay the 1.1 million and went to appeal in Supreme Court, the appeal was dismissed.

7 I have already issued appropriate notices not only to the court appointed accountant who is also an culprit in the matter for not submitting the correct and unbiased report but also to my own legal advisor. I have also addressed appropriate communications to your previous local partner and I shall be marking a copy of the same to his new partner. It would be petitioners endeavour before the court of law to establish that the court -appointed accountant acted in a manner prejudicial to justice and he was negligent and prejudiced in his whole approach. The errors made be him in analysing the data are enormous. The petitioner submits that the accountant’s report is based on not only inadequate information but also incorrect information supplied by my lawyer. Legally, this is treated as perjury and contempt of court. Whatever may be the reasons for the accountant to give adverse report against the petitioner, the consequence of reopening of cases would have to be suffered by the respondents not only in terms of legal cases but also in terms of penal actions and punishments from courts of law. It is already on record that in criminal proceedings initiated by the petitioner, the respondents NO. 2 officer MR. Raj Bernard has admitted his liability before the court of law in Dubai, Sharjah and Ajman and he was making mainly two pleas viz. i) he needed time to settle, ii) he wanted me to resort to civil remedy. The above two statements from him are part of records and accountant’s report in any manner will not erase the past records. Maybe because the petitioner was abroad and because of communication gap or maybe because of errors on the part of petitioners previous lawyer, a holistic picture was not available to the court of law. However, if now the petitioner bring these facts on record and at the same time offer to deposit the amount, the chances of getting cases reopened are bright. The petitioner feels that he has good case on merits and in the interest of justice this curative petition or as the case may be the revision petition may be allowed and the matter may be remanded for further detail enquiry and investigation to the trial court.

8 The petitioner submits that Apart from contradictory statements before different courts of law, records with regard to cheques given by Mr. Raj Bernard on behalf of respondent NO. 2 from time to time speak for themselves. It is apparent from the past record that MR. Raj Bernard have not disclosed the entire gamut of transactions to the court. He have indulged in exercise of intentional concealment of facts and therefore once the petitioner bring these facts on record, he would be liable for additional perjury.

9 The petitioner wish wish to bring on record that the issues relating to --- Bank if being reopened. In fact the petitioner have realized that the issue was too serious and was not his individual issue alone. It contains substancial question of law which if decided would benefit people in general. The petitioner have issued notice to ---- Bank. The draft of the notice was provided by top law firm in Mumbai who has advised the petitioner that he must file petition through their associates in London and in Dubai for withdrawal of licence of ===Bank for their unholy, biased, arbitrary, unethical role in banking.

10 The petitioner submits that the fact that the whole world is today fighting war on terrorism and the role of banks in criminal activities and money laundering has been focus of not only USA but entire world supporting war on terrorism. The manner in which --- Bank acted was so unethical and records are so clear that the issue is bound to be reopened. The fact that these cheques were given by respondent NO. 2 is not disputed at all. The petitioner was not a customer of --- Bank at any point of time.

11 the petitioner further submits that he would also like to add that as per the Indian law, it is permissible for the petitioner to prosecute the respondents even in India since the offences committed by respondents were against an Indian and provisions of Indian Penal Code clearly provide that offences on foreign soil are also covered so long as they are between two Indians. But the petitioner feels that as he has prosper in dubai in his business he has full faith in Dubai courts, if justice is meted in Dubai many other people would reimpose their faith in UAE law and its courts. As the petitioner feels he is seen as an example of victim of wrong justice system by his nationals in Dubai and if ultimately justice is done in the matter even they would repose faith in UAE judicial system.

12 The petitioner is making the above petition praying that the issue involved in the above matter be ordered to reopen. That pending the hearing and final dispute of the parties the Hon’ble court be pleased to direct the respondent to deposit the sum involved in the matter as and by way of security deposit as the respondents are foreigner and there is possibilities of flying the country and go beyond the jurisdiction of this Hon’ble court. The petitioner is ready and willing to deposit the appropriate sum of money in the Court as and by way of security as the courts pleased.

13 The petitioner has not filed any other petition or challenged the orders in any other court of law.

14 The delay in taking out this petition be condoned as the petitioner being held up in Australia for his Business purpose and presently residing in India, he could not due to legal knowledge file this petition earlier.

15 The petitioner is paying the court fees of DHR.___________ as fixed court fees.

16 The petitioner has no alternate and efficacious alternate remedy available and reliefs sought in the present petition will be suffice to do full and final justice between the parties.

17 The petitioner submits that there is substantial and crucial issues regarding law is involved in the above matter.

18 The petitioner craves leave to refer and rely upon the compilation of documents in support of this petition.

19 The petitioner therefore prays that-

b) That after going through the records and proceedings in the above matter and hearing the parties this Hon’ble court be pleased to remand the matter for fresh trail

c) That pending the hearing and final disposal of this petition this Hon’ble court be p