Anti-Corruption Party Punjab

07. Complaint against Kejriwal and 5 0thers

Hon. SSP Chandigarh.

Sub; Complaint against Kejriwal and 5 0thers (1-6), for doing unlawful activities, including facts observed by the complainant, defaming sikhism, hinduism, and raising of religious feeling, and violation of the election laws. Also to investigate the mentioned matter, take necessary actions and send report to Governor Punjab, to send further to Central Govt, President of India and election Commission of India. For cancelation of registration of Aam Aadmi Party, and disqualify Shri Arvind Kejriwal to contest election and registration of any other political party in future. Persons 7 to 13 deserve to be called to explain the true facts and to explain what action they are taking, relating to concern matters mentioned in the complaint.

01. Shri Arvind Kejriwal CM, Govt. of NCT of Delhi cum

Chairman, Dialogue and Development Commission of Delhi.

02. Asish Khetan Vice Chairman, of

Dialogue and Development Commission of Delhi.

03. Manish Sisodia deputy chief minister cum

Member Dialogue and Development Commission of Delhi.

04. Sanjay Singh In charge (Parbhari) Punjab Party affairs. Cum

In charge Punjab Dialogue Committee.

05. Bhagwant Mann Member Parliament. Cum

Member National Council and Advisor relating to Punjab Affairs.

06. Kanwar Sandhu head of Punjab manifesto committee

Named as Bolda Punjab Dialogue.

07 Sucha Singh chhotepur

Convener of Punjab Unit of AAP.

08. Harvinder Singh Phoolka

Senior Advocate of Supreme Court of India

09. Editor Publisher India Today (Hindi Edition) Faridabad.

10. Election Commission of India. New Delhi

11. Controller of accounts, ministry of home New Delhi.

12. Punjab State Election Commission. Chandigarh.

13. Department of Excise and Taxation of Punjab at Chandigarh

Accused 1 to 6 invoked,

295A, 298, 120A, 34, and 171G, of IPC

Persons 1 to 5 also invoked,

Section 9 (1) of the Representation of the People Act 1951.

Read with

Section 123(3) of the Representation of the People Act, 1951.

And Sub Para 3 of Para 1 of the Code

Others omitted/committed offences as mentioned in the relevant Para’s of complainant

Respected Sir,

Complainant begs to submit as under:-

Note: The group 2-8 is called personal group of Kejriwal accused 1, generally called “Kitchen Cabinet”. They caused the opportunities, commited the offences, those are subject matter of this petition. No accusation is made against Res 7, to 13. Res 7-13 deserve to be summoned to explain, to the Inquiry officer that why they failed to perform their duty under them and to explain why they failed to perform their constitutional duty under 176 and 217 IPC, to take necessary action under the law, against persons out of Res 1 to 6. Resp 4 also deserve to be summoned being In charge of Punjab unit, to explain, that while Punjab unit of AAP has made investment in millions in Punjab, for political propaganda. While Punjab unit of AAP, has no cashier, no fund, no account. From which source such amount came, and through which channel.

On Jurisdiction Chd. Police, Complainant, and Reasons, to make this Petition.

1. That relating to jurisdiction Chd Police, complainant and some respondents also reside in Chandigarh ie: Punjab State Election Commission (Res. 10), Bhagwant Mann (Res. 05), Kanwar Sandhu (Res. 06). Sanjay Singh (Res. 04). Hence this has jurisdiction to hear this petition. Accused 1 to 4 are office bearers of Delhi Government, which is under control of Central Government, whereas Chandigarh is also union territory, Hence Jurisdiction lies in this court.

2. That all accused 1 to 8 belongs to Aam Aadmi Party. The origin of Aam Aadmi Party is from Anna Hazare movement. This petition is being made by the person that also belongs to Anna Hazare movement and also Aam Aadmi Party.

3. That complainant had been Member of Punjab Legislature, APC of India, and Director IARI Pusa New Delhi. Former Party of Complainant rules in Punjab. If Petition is made in Punjab, Govt of Punjab may affect neutral Justice by the court, or otherwise, some persons will consider it government move.

4. That Complainant resigned from Akalidal in 1977. Not joined any other party. When Kejriwal established Aam Aadmi Party, and asked the public to join the party, by making a miss call to a specific mobile number. I also made such miss call, also persuaded a lot of persons to join the party. Hence I believe that I am member of Aam Aadmi Party. But not verified by the party by providing any .

5. That Complainant, in the past, had challenged Smt Ambica Sony, President Youth Congress, during the regime of Giani Zail Singh. Her vote was registered unlawful way after her nomination. Complainant also challenged Election Commission of India, In Hon High Court and Hon Apex Court, for promulgating “Code of Conduct” much earlier to “Declaration of Election Process”, during the regime of Smt Rajinder Kour Bhathal. Complainant succeeded in getting demanded reliefs in both cases. It is to verify that complainant is a social activist, not committed to any party or any leader.

6. That Anti-Corruption Party is a split group of Aam Aadmi Party. Anti-Corruption-Party is not a registered political party. It means “a team to oppose corruption” within Aam Aadmi Party, as well as in governance of states of north India, ie. Punjab, Haryana, Himachal and Delhi.

7. That This Petition contains different issues those require different jurisdictions. But both issues belong to the same point unlawful activities of Aam Aadmi Party, its National Head Shri Arvind Kejriwal and other office bearers. One issue cannot be decided by different courts. This petition is being made under 156/3 of CrPC. This court has vided powers under this section.

8. That for the convenience of your Honor, respondent 7 to 10 is made party to the petition. Your Honor may decide itself, after considering the complex points, either try the case itself, or send it to Hon High court for opinion, or entrust any probe to investigate the allegations, made in the petition. Following points are also considerable.

9. That Police is not a position to directly register the case, being Election Commission of India and office Bearers of Delhi Govt. involved in this Petition. But make report, and submit it to Hon Governor.

10. That this complaint is also being made to verify whether SehajDhari Sikh has any right to get any relief from Indian Judiciary, under the constitution of India, While Parliament of India, SAD Government of Punjab, and Sikh Gurduara Board, jointly but under unlawful conspiracy, expelled the SehajDhari Sikhs from Sikhism. Whether we have any access to fundamental rights of the constitution?

11. That Complainant in the past had been member of Punjab Legislature, Member (APC) Agricultural Price Commission of India New Delhi, Director (IARI) Indian Agricultural Research Institute Pusa New Delhi. Etc. Hence I had to stay and frequently visit Delhi. Hence got some intimacy and familiarity, to the events of Delhi.

12. That Complainant now is engaged in running his campaign against corruption and other social evils, under the name of “Anti-Corruption Party, which means a team to oppose corruption. It is a Anna Hazare Style social move against corruption. Anti-Corruption Party is not registered as a political party. Hence: this Complaint.

ON FACTS OBSERVED BY THE COMPLAINANT.

13. That complainant visited at the venue of the Anna Hazare hunger strike on 5 April 2011. The hunger strike was to eradicate corruption from India. Second demand was to bring back the black money, belonging to politicians, deposited in the foreign banks. Due to that I became follower of the Anna Hajare movement. I also heard there that this movement “India against corruption” organized by Anna Hazare was against congress, and is being backed by RSS. I was also told that Anna Hazare had been secretary of RSS chief Nana Ji Desmukh, for a long time. It made no effect on me and I continued to support Anna Hazare campaign. There I had the opportunity to know about the leaders of India against Corruption including Shri Kejriwal. Shri Kejriwal was the favorite person of Shri Anna Hazare, as he claims that he surrendered the post of Commissioner of Income, for Shri Anna Hazare view. Anna Hazare was criticized for depositing all the funds with Kejriwal, without any reference or record.

14. That earlier In 2006, Kejriwal was awarded the Ramon Magsaysay Award for Emergent Leadership recognizing his involvement in the grassroots movement Parivartan using right-to-information legislation in a campaign against corruption. Privartan was not registered as NGO. Someone said that later Mr Shashodia registered an NGO named Kabir, and amount of Magase Award was transferred to Kabir. Some persons said that it was also shown that he donated his Magsaysay award money as a corpus fund to found the Public Cause Research Foundation, a non-governmental organization (NGO). PCRF was registered under section 80G and 12A of Income tax Act. Public Cause Research Foundation was closed without doing any social activity. The same year, Kejriwal resigned from the IRS,

15. That Public Cause Research Foundation was established on 19 December 2006 by Arvind Kejriwal, Manish Shishodia and Abhinandan Sekhri. Kejriwal donated the prize money he had received from the Ramon Magsaysay Award as a seed fund. The organization is no longer listed as an NGO. Its last published accounts were for 2011-2012 (as reported in Wikipedia)

16. That Parivartan (Change) is a grass-roots activism organization of Kejriwal, based in the Sundar Nagari area of New Delhi, India. During the 2000s, Parivartan used Right to Information (RTI) to address citizens' grievances related to Public Distribution System (PDS), public works, social welfare schemes, income tax and electricity.

17. That In 2002, the group obtained official reports on 68 public works projects in the area, and performed a community-led audit on them by comparing the claimed work to the actual work done. The campaign exposed misappropriations worth ₹ 7 million in 64 of the projects. It is said that campaign did not advanced to get them punished, but spared them after some type of conciliation.

18. That In November 2004, Parivartan used RTI applications to access communication between government agencies and the World Bank, regarding a project for water supply by a private party with the aid of world bank. Kejriwal blamed that private party have spent ₹ 105 crore on annual salaries of 84 foreign experts. Kejriwal blamed that the project would hike water tariffs ten-fold. The World Bank denied Parivartan accusations, and criticized Kejriwal for "propagating serious mischaracterizations of the World Bank's actions and intention" Such acts show the modus-operandi and style of black mailing of Kejriwal and his Privartan. Privartan was not a registered NGO but only a letter head, and somewhat more.

19. That By 2012, Parivartan was largely inactive, and its main leaders Arvind Kejriwal and Manish Shishodia had launched a political party - the Aam Aadmi Party. Mr Parshant Bhusan an advocate gave donation of one Crore rupee to the party. It was said that this is Kejriwal money, earned by unlawful means.

20 That a girl named Santosh Koli was paid worker of Privatan. According to her mother, Koli served for 12 year. Kejriwal stayed at their home for weeks. She demanded party ticket from Kejriwal, on denial she became annoyed. She was ended on 7 august 2013, under suspicious circumstance.

21. That Kabir was Shishodia’s NGO, in Delhi's Pandav Nagar, to campaign for the right to information. This brought him in contact with Parivartan, where he met Kejriwal. Manish Shishodia, is alleged to have diverted foreign funds meant for his NGO, Kabir, for personal use. Kejriwal is a governing body member of this NGO that works in the right to information (RTI) sphere. The NGO had received more than Rs 2 crore in foreign contributions between 2005-06 and 2010-11. Kabir received 54931 US dollars from seven donors from abroad. All donors are not known. Kabir published two books on RTI worth 5 Rupee and 25 Rupee only. Used the major amount, for their personal use.

22. That PCRF is also a NGO of Kejriwal. Kejriwal founded Public Cause Research Foundation in 2006, along with Munish Shishodia and Abhinandan Sekhri, He was also a key figure in Kabir, a non-governmental organization.

ON LAW POINTS, RELATING TO DEFAMING SIKHISM, HINDUISM, AND RAISING OF RELIGIOUS FEELING.

23 That in last week of June 2016 Arvind Kejriwal CM of Delhi, who also head and organizer of Aam Aadmi Party (Known as AAP) announced that he will declare Election Manifesto of his party, at Amritsar on 3 July, after noon, which is specifically on consideration of youth matters. Kejriwal also declared that he will visit Golden Temple (Harmander Sahib) the holiest shrine of Sikhs, before making the declaration of election manifest of his party. This decision was very much flashed by Punjab leader of AAP.

24. That on 3 July Shri Kejriwal visited at Golden Temple, along with a number of Punjab leaders including Bhagwant Maan, the first favorite of Kejriwal. Sikhs present there opposed his politically motivated. Some Sikh thrown some pamphlets on Kejriwal, mentioning some injuries made to Sikh feelings by Kejriwal, as CM of Delhi.

25. That from Golden Temple Kejriwal went straight to release his manifest to press. On the front page of manifest, was a full page picture of Golden Temple (Harmander Sahib) and the picture of Golden Temple were a figure of Broom and snap of Kejriwal. Broom is the Party Symbol of AAP. In Punjab broom is used to clean home. Majority of Sikhs are not aware that broom is election of AAP.

26. That on the stage Shri Ashish Ketan in the presence of Kejriwal and Bhagwant Mann during his speech said, by take the manifesto in his hand, and waving the manifesto again and again, “It is our karar (Agreement), it is Guru Granth for us, it is geeta for us”. Mr Khaitan during his speech never clarified, that we respect our manifesto like these wholly shrines.

27. That style of Shri Ashish Khaitan was also very irritative, raising the feelings of some Sikhs and Hindus, how a manifesto of political party, that is considered a bundle of lies (until implementation) can be above the religious faith of any religion person, replacing his wholly scripture. Mr. Kejriwal was listening very cautiously with smiling face.

28. That actions of Kejriwal and Ashish Khaitan made turbulence in the minds of Sikhs and some Hindus throughout the world. Thousands of individual persons, societies, organizations, and congregations in gurudwaras and out, felt injury to their feelings, and some of them made their expression to the press, throughout world.

29. That common concept among the sikhs is that Kejriwal and his group is defaming the sikh shrines and wholly Sikh scriptures motivatedly. Sikh Intelligentsia, percept two concepts behind this motivation.

30. That one concept is that mail rival of AAP in coming assembly election 2017 is Shromany Akali Dal, a ruling party in Punjab. SAD is a Sikh religion based party, controlling also Sikh Gurduara Board. SAD frequently uses all powers and facilities for political purposes. Head office of Sikh Gurduara Board is in premises adjoining the Golden Temple. Kejriwal and his group is of this view that by lowering the reputation of Sikh shrines and Sikh scriptures SAD will be political affiliation and popularity will be defamed and lowered. It will be a major gain for AAP.

31. That one another concept is that background of Kejriwal is from Anna Hazare Movement between, 2011 to 2015. It is said that movement of Anna Hazare, against congress government, was backed up by the RSS. Shri Anna Hazare was also belonged to RSS. It is said that Anna Hazare worked as secretary for a long time, under RSS chief Nana Ji Desmukh. Chief Minister Ship of Delhi was blessed to Kejriwal, by RSS, by efforts and understanding with BJP. After coming into power Kejriwal lost the love of RSS, due to his Chankia tactics and un-logical hostility towards Mr Modi, PM of India.

32. That now under the lust of gaining power in other states of India, specifically of Punjab, he needs blessings of RSS again, so that the vote devoted to Modi and BJP, may be migrated to AAP. Kejriwal planes that by doing this Chankia Tactics of putting picture of Golden Temple on the full page of his manifest, and putting figure of broom (Jharu that is also election of AAP) on the picture, he will be winner by both sides of the coin. This way, he will be able to plead before the RSS, that by this tactic, he has defamed the ruling SAD, as well as Sikh Shrine and Sikh Scripture. On the other side he will pray to innocent rural Sikh vote that he printed the picture of Golden Temple on his manifest, he respect the Sikhs and Sikh shrines. Hence his party deserve to be favored, to get Sikh votes.

33. That there is no doubt that this act is preplanned. Planned motivatedly, for unlawful, political gain. It is not an error, or mistake, occurred by innocence of any person, or mere slept of tongue. The said manifesto was considered, discussed in about ten meetings, held at big halls in Punjab, attended by workers in hundreds. These meetings were held in different parts of Punjab and attended by different audience, belonging to that area. After that it was considered and discussed before the “Bolda Punjab Dialogue” committee presided by Kanwar Sandhu. That “Bolda Punjab Dialogue” committee is directly under the Dialogue and Development Commission of Delhi.

34. That after passed by Bolda Punjab, manifesto was sent to DDCD (Dialogue and Development Commission of Delhi). DDCD considered the manifesto, passed, published and printed it. Mr. Kejriwal Chairman of the DDCD released the manifest at Amritsar, only being the wholly shrine of Amritsar, ignoring Chandigarh, that is the capital of Punjab, and core media of north India. AAP held all her press meetings, may be in thousands, at Press Club of Chandigarh. Hence this act of respondents 1- 6 invokes sections 295, 295A, 298, 120A and 34 of IPC. Precedents and history of Kejriwal government, also invokes section 171G of IPC. (Res 7 publicly declared that he was neither considered in process of issuing manifesto, nor manifesto was shown to him)

35. That Shoe and broom are symbol of un-cleanliness and dirt. Showing symbol of Shoe and broom with a man, shrine or any object is considered as a symbol to defame him and an abuse to him.

36. That as Muslim community does not allow making picture or portrait of Hazrat Mohamad. Same Sikh community do not allow picture of gurus to be used for any non sikh non-religious purpose. Sikhs do not allow Sikh shrines to be used for any non-sikh non-religious purposes. It is the customary and religious law of Sikhs. Customary is well settled in Indian law. Offences committed by accused persons may be challenged on the plea that broom is election symbol of the persons, but ancient hereditary customary law of any state, community, religious body, always supersedes the lateral framed law. Customary law and traditions of Sikhism proves the commitment of offences beyond any doubt.

37. That Kejriwal dismantled the SiKh shrine in Gurdwara Shisganj at Delhi, without any logical reason, but by causing the court order some month ago. Circumstances explained in annexure attached, expressly prove that Kejriwal did it motivated to injure the Sikh feelings, through Alka Lamba, and NDMC. Hence this act of respondents 1 to 4 invokes sections 295, 295A, 298, and 120A of IPC.

38. That Kejriwal is habitual law breaker relating to injuring the religious feeling of others. He visited Goa and declared Goa state as “Sex Tourism State”. These words of Kejriwal injured the feeling of residents of Goa, as well as tourists, who visit Goa. It seems that he is a masochist type politician, who feels pleasure by injuring others. A city-based advocate has also filed a complaint against Delhi Chief Minister Arvind Kejriwal, accusing him of hurting religious sentiments of Hindus by posting a cartoon over JNU row on Twitter. Shri Hindu Takhat also summoned Shri Kejriwal and Ashish Khaitan, to appear before him on 17 July, at Kali Mai Temple at Patiala, but they ignored the summons of “Shri Hindu Takhat”.

39. That Shri Kejriwal and Harinder Singh Phooka arranged a cheating full drama (Pseudo Act to deceive people) to make Fool of Sikhs. It is learned that HS Phoolka was trying his best, to make him agree, to go to Darbar Sahib at Amritsar, and perform some formality to pacify the Sikhs. Mr Kejriwal was so arrogant, not to agree to such formalities i.e. cleaning of used utensils at langer, Cleansing of shoes of devotees, or cleansing of parkarma floor with broom, etc. It is said that Mr Kejriwal argued that since from childhood, he remained on higher elevations. He never did such dirty things; hence it is not possible for him to do such acts. It is known that Mr Phooka disclosed a proposal to him. Under which he has not to clean the used utensils. He will make arrangements for new or clean utensils, only you have to just wash them once. Nothing else will be done there. We will enter Darbar Sahib too early in the morning at 3 AM, and then usually no much congregation gathered there. At that time all utensils will be kept cleaned there. On such proposal Mr Kejriwal agreed to come to Shri Amritsar.

40. That under Fear that Punjab office bearers of AAP may object this treachery. Phulka Shared it with Mann, Chhotepur and some others. Under greed and discipline they had to agree, to this plan.

41. That under this conspiracy of treachery Mr Phoolka went to Darbar Sahib and stayed there to access the situation, and make their treachery feasible and implementable. However press was not informed about the time and schedule of doing Karseva by Kjriwlal. Al was kept a complete secrecy. Such treachery was implemented early in the morning of 18 July 2016. Even then such treachery became viral on Facebook, shortly after two hours. Next day it was on the print media.

42. That the tradition of Sikhism is that, if any Sikh, Amritdhari, Sehajdhari or any Non-sikh, who feels that he has injured the trust and feelings of Sikhs, he applies to head-priests, of Akal Takhat. Apear before them, on the prescribed date and time. “Tankhah” is blessed on him by the priests. Such Tankhah is performed at relevant time. For example if Tankhah is of cleansing of langar utinsils, it should be performed between 12 to 2 pm, when sangat is taking food in langer of the shrine. Not at early moments, when there is no sangat, no utensil in which food was taken. If don so motivated, it is clear cheating, dishonesty, as an attack on Sikh traditions. Motivatedly, braking of Sikh traditions.

43. That this conspired treachery is the act of violating the Maryada of Sikh Shrines. It is not only violation of Sikh traditions, but it is an act of creating of pseudo tradition, also creating a pseudo precedent, in the Sikh history, contrary to Sikhism. It injured the feelings of mine, along with Sikhs in Punjab, India, and abroad. Such wrong traditions are not only injurious to Sikh devotees but may be fatal for Sikh-Dharam.

ON LAW POINTS. VIOLATION OF THE ELECTION LAWS.

44. That Kejriwal is in process to contest coming assembly elections of 2017. He claimed again and again that his party will be winner and rule Punjab. Kejriwal and his Aam Aadmi Party failed to provide proper governance to Delhi state. Kejriwal and his party deserve to be treated under Section 9 (1) of the Representation of the People Act 1951. Read with Section 123(3) of the Representation of the People Act, 1951, and Sub Para 3 of Para 1 of the Code. Following issues prove beyond doubt, that Kejriwal Govt deserves to be dismissed and registration of his Aam Aadmi Party, deserve to be declared null and void, under above said law. Such acts of Kejriwal and his government are corrupt practice that is disloyalty to the state as well as residents of the state.

45. That Kejriwal registered aam aadmi party as a political party. My relatives are settled at Delhi. Being legislator of Punjab, Member APC of India and Director IARI Pusa New Delhi, I had to go to Delhi frequently. Hence I got good intimacy there. In the assembly election of 2013, I supported Shri Kejriwal Aam Admi Party candidate of Rajori Garden. Support to the Rajori Garden constituency candidate, was withdrawn by Kejriwal, at the last moment, on the plea that there was a dispute in his family. But internally there was any other reason. When papers of any candidate are accepted, candidate comes under the control of EC. No person is authorized to damage the carrier of candidate. It is the violation of election laws, as well as cheating and deceit. Such acts of Kejriwal and his government are corrupt practice that is disloyalty to the state as well as residents of the state.

46. That Kejriwal registered aam aadmi party as a political party. That during assembly election of delhi in 2013, Shri kejriwal made separate appeals to Hindus, Sikhs, and Muslms, declaring his different election manifesto to different communities. Sub para 3 of Para 1 of the Code provides that, "There shall be no appeal to caste or communal feelings for securing votes. "Mosques, churches, temples or other places of worship shall not be used as a forum for election propaganda." Kejriwal violated the election law. Such acts of Kejriwal and his government are corrupt practice that is disloyalty to the state as well as residents of the state.

47. That Election Commission took notice of such activities or appeals under guise of religions. The Election Commission (EC) on Thursday November 20, 2013, issued a notice to Aam Aadmi Party (AAP) convener Arvind Kejriwal for an alleged violation of the Model Code of Conduct by way of an appeal on grounds of religion to Muslim voters to support his party in the upcoming Delhi Assembly polls. The EC has given Kejriwal time till 11 am on November 25 to file a reply as to why action should not be initiated against him for prima facie violation of the Model Code, which prohibits appeals to voters on grounds of religion. It is not known to me whether Kejriwal appeared before EC or not. Such acts of Kejriwal and his government are corrupt practice that is disloyalty to the state as well as residents of the state.

48. That Kejriwal registered aam aadmi party as a political party and submitted its constitution to EC with the provision of Om Buds Man. Om-Buds-Man was established as supreme power, according to the party constitution. When Shri Kejriwal Ji became Chief Minister of Delhi, he called the meeting, but Om Buds Man and majority of deserving members were not called and not allowed to enter the meeting hall. Om Buds man was expelled from party. It is clear violation of constitution of the party submitted to EC., Constitution of India and the representation of the people act 1951,( These will be called “Election Laws” in further paras). It is unlawful use of power as CM. Such acts of Kejriwal and his government are corrupt practice that is disloyalty to the state as well as residents of the state.

49. That Delhi Dialogue Commission was the supreme policy maker wing of the AAP. A year after setting up the Delhi Dialogue Commission, the AAP government has renamed its think-tank as the Dialogue & Development Commission of Delhi and armed it with more powers. The AAP government has decided to bring in all its advisory bodies, including the recently-constituted Delhi Entrepreneurship Council, under the ambit of the newly-renamed commission. Hence DDCD became a department of Delhi Government. Unlimited amount of Delhi tax payers is being utilized in Punjab as well as in whole India, by this DDCD. It is un-constitutional, as Delhi Government has no right to interfering in the matters / elections of Punjab. It is interference of Delhi Govt in the religious affairs of Sikhs of Punjab. Such acts of Kejriwal and his government are corrupt practice that is disloyalty to the state as well as residents of the state.

50. Kejriwal suspended two members of Parliament of his party. More than a year has been passed, they are still under suspension. Constitution has no such provision of suspension. It is the violation of election laws. It is the rejection of verdict of Punjab voters. No person has such right except EC. Kejriwal violated election law. Such acts of Kejriwal and his government are corrupt practice that is disloyalty to the state as well as residents of the state.

51. That Aam Aadmi Party (AAP) is planning to contest assembly elections in Punjab. No separate state unit of the party was established. Kejriwal group has invested crores of rupees in Punjab on rallies, conferences, large hall meetings and other way. Money flown out is of Delhi tax payers. That is dispersed in Punjab, on the name of party. There is not a single penny in the treasury of Punjab state unit of AAP. There is no unit of Punjab Aam Aadmi Party. There is no cashier of Punjab State unit of party. No constitutional privilege of Punjab unit. Unconstitutional activities are in process since 15 June 2015. These activities are violation of election law, even deceit with election commission. These activities are also deceit and cheating with voters of Punjab. Such acts of Kejriwal and his government are corrupt practice that is disloyalty to the state as well as residents of the state.

52. That Kejriwal enrolled primary member of his party by accepting miss calls. Party claims that membership, is in millions. Party never called any general meeting of members of neither Punjab unit, nor of National body. It is clear violation of election law. Such acts of Kejriwal and his government are corrupt practice, which is disloyalty to the state as well as residents of the state. This act of Kejriwal is a corrupt practice that is disloyalty to the state as well as residents of the state.

53. That Shri Kejriwal Ji has quarrelsome nature. He never conciled even with neibour states. Hence apex court advised him to settle the issues with himself and amicably. He always made undeserving hostile attacks on PM of India. Whereas, Delhi state is under direct subordination of central government. PM represents hundred time voters than the representation of Delhi voters. Hence administration and development of delhi state is at lower level, that proved disloyalty to the state. Such acts of Kejriwal and his government are corrupt practice that is disloyalty to the state as well as residents of the state.

54. That Kejriwal appointed as many as 21 AAP MLAs with additional perks to work as parliamentary secretaries. He also provided posts of profit just as chairman of hospitals. Perks include decent bungalow on rent up to 3 lakhs per month. Such acts of Kejriwal and his government are corrupt practice, which is disloyalty to the state as well as residents of the state.

55. That in the opinion of people every project by the Kejriwal Govt was a planning for a scandal. For example Govt introduced od-even formula for relief from pollution. Residents of Delhi suffered a lot. But Govt made some scandals by hiring 6000 buses from a private concern on very unreasonable and unjustifiable rent and conditions. Govt directed to keep more 6000 buses ready for next requirement. Uber, Ola owned private taxies allowed fleecing Delhi residents by many time hikes in rent. Govt shut her eyes. Such acts of Kejriwal and his government are corrupt practice, which is disloyalty to the state as well as residents of the state.

56. Delhi Govt passed the budget to establish 1000 unit of Mohalla clinics. It came to know that only one unit was established, even on the much more cost, than the actual cost. About 70 units were established in the houses of aap leaders or their relatives or nears and dears. Such acts of Kejriwal and his government are corrupt practice, which is disloyalty to the state as well as residents of the state.

57. That Kejriwal is not in fighting morcha with PM only, he is also in same position with the governor of Delhi. Constitutionally Governor is the head of state and administrator. Chief Minister or ministers are his subordinate. Meaning of minister is person deputed to provide specific service to people. Due to this un-logical fight, bureaucracy is in confusion, whom to obey. Any office who obey the LG, Kejriwal threaten him even made complaints against them. Once Kejriwal made complaint to ACB (Anti Corruption Branch), against LG. Once Kejriwal made complaint to ACB, against chief of Anti corruption branch. Arvind Kejriwal ordered a probe against Anti-Corruption Branch (ACB) chief MK Meena for allegedly intimidating his juniors. This act of Kejriwal is a corrupt practice that is disloyalty to the state as well as residents of the state.

58. That some bureaucrats met CM and LG, with the request to consider their pity position. Kejriwal instead of giving any relief, threaten them, on the eve of service day, that he is here for 10-15 years, and asked them to resign if they not satisfied with me. Hence administrative work and progress of projects in on stand still. No officer is capable and dare to take any action. Such acts of Kejriwal and his government are corrupt practice that is disloyalty to the state as well as residents of the state.

58A. That at the time of odd-even Kejriwal pasted big poster on with his face on the whole poster with a small line below his snap as “Odd-Even from such to such date”. BJP told that Kejriwal wasted 100 crore of poor tax payers of Delhi on failed odd-even advertisements. Such acts of Kejriwal and his government are corrupt practice, which is disloyalty to the state as well as residents of the state.

59. Kejriwal is chairman of Punjabi Academy of Delhi. Last year academy employed about three dozen girls on pay scale Rs 5000 to Rs 7500, to provide kindergarten type education to small children. These girls mostly work in gurudwaras. One girl sits in a Mandar and one in a church. Kejriwal made many time full-page or double-full-page advertisements in all Punjab papers, for very mere points, such as Delhi Govrnment will raise salary of Punjabi teachers of the academy. Kejriwal wasted the about whole amount of Punjab academy on the pretext, by giving contract in millions to private firm to arrange stage for a single time children show in the academy or any unit situated in Gurduwara or Mander. Such acts of Kejriwal and his government are corrupt practice, which is disloyalty to the state as well as residents of the state.

60. Kejriwal is inclined to finish the minorities of Delhi, by debarring their coming generation from education. In Delhi about 1800 schools are private. Exempting few dozens, others are run my sikh organisations or muslim communities. Big number is controlled by Delhi Gurduara committee or other gurdwara etc. Generalyy these are run in the property of Gurdwarwas. Mostly all are based on donations and Charity. They freely provide free education to poor and deserted children. Kejriwal banned the donations to those schools, by imposing “Delhi school education amendment bill”. He also with the motive to harass the minorities imposed another bill named “Verification of Accounts and refund of excess fee Bill”. Such acts of Kejriwal and his government are corrupt practice, which is disloyalty to the state as well as residents of the state.

61. Kejriwal is making robbery by legislation, with Delhi business and Delhi fund resources. Major Field of this robbery is health sector. Kejriwal announced that his govt will establish 1000 Mohala health units. About 70 of them were opened in private houses generally of AAP workers. Kejriwal made a list of medicines to be present on hospitals and given free. The snap of the only Mohala unit, that Delhi govt constructed, for the purpose of inauguration by the Kejriwal shows, about two three dozens of medicines called Essential Drug List. Same look and same size of packs clearly show that all these medicines are supplied by one and small manufacturer. This act of Kejriwal is a corrupt practice that is disloyalty to the state as well as residents of the state.

62. That Kejriwal directed all doctors of Delhi to not to make prescription of any medicines, to be purchased from chemists. If doctor did it, he will be penalized. For thousands type of diseases doctors of AIMS and PGIMER recommends latest medicines even more than one lakh brands. How few dozen medicines will treat all ailments of human beings? Secretary of Municipal Corporation Doctor's Association said, "Due to non-payment of salaries, doctors, nursing staff and paramedical staff are in a state of starvation and paucity of life saving drugs in hospitals has brought the Delhites to a state of helplessness and they were being forced to avail treatment at private hospitals." Such acts of Kejriwal and his government are corrupt practice that is disloyalty to the state as well as residents of the state.

63. That people frustrated by Kejriwal policy of outdoor treatment, have to go to big private hospitals. Annoyed by this Kejriwal imposed penalty of six crores on five hospitals, on the excuse that they are not giving free treatment to required number of poor patients. Chemist shops are to close. Private hospitals are to close. Reality that seems behind this anti health policy is that Manufacturers give discounts up to 50% or more. Kejriwal wants that all medicines to be consumed in Delhi be purchased by him from any specific manufacturer, to get whole commission of Delhi medicine consumption, that may be not in millions but billions. This robbing policy of Kejriwal is dangerous for the health of Delhi People, An epidemic attack of any dangerous disease, may be prove fatal for Delhi, because no chemist and needed medicine will be available there. No private hospital or doctor will be available at Delhi. Such acts of Kejriwal and his government are corrupt practice, which is disloyalty to the state as well as residents of the state.

64. That condition for administration in Delhi has deteriorated to the extreme down. Around 300 doctors, nurses and paramedical staff working in the city's hospitals, run by the three municipal corporations, on Wednesday protested against the non- payment of salaries for past three months. Sanitary employees also had gone on long strike. Due to that street and houses became heaps of sludge. Youth is committing suicide at the residence of CM. The Central Information Commission has chided the office of Delhi Chief Minister Arvind Kejriwal for "not applying its mind" before transferring complaint of a senior citizen, seeking to know status of pension, to 29 departments. Kejriwal never heard the public grievances. He is after his lust to win other states and to become PM. Such acts of Kejriwal and his government are corrupt practice, which is disloyalty to the state as well as residents of the state.

65. That few months back Delhi faces the worst dengue outbreak, which has killed 15 people and sent thousands to hospitals. NDTV found that little or no prevention program has been carried out for the disease in the slums of south Delhi. The local mayor, a BJP man, claims they had received no fund for the purpose, even though money is separately earmarked in budget to contain waterborne diseases. New Delhi Municipal Corporation has said that Arvind Kejriwal government has released only Rs. 29 crore of the Rs. 117 crores yearly allocation. This act of Kejriwal is a corrupt practice that is disloyalty to the state as well as residents of the state.

66. That In the slum cluster, there is no tap water in the area and every family has stored water in large and small open containers - an invitation to the mosquitoes that breed in the water and spread the disease. Why Kejriwal is not taking care of such slum dwellers. May be he want that more and more people may become sick and take medicine only from alleged Mohalla Clinics. Every patient who takes free medicine from mohalla clinics offers gain of hundreds for Kejriwal. Such acts of Kejriwal and his government are corrupt practice, which is disloyalty to the state as well as residents of the state.

67. That Arvind told the election commission that about three dozen cases has been registered against him. Now some new cases have been registered against him. Some of them belong to the different courts much away from Delhi such as Bombay, Hyderabad, and Amritsar etc. Most of time of Kejriwal is consumed to attend the courts. Remaining time is consumed for preparing defense for the cases. If any time spared, Kejriwal consume that time to visit other states of india, under the dreams to become PM of India. Kejriwal neither spare time to administrate the state nor does he have the capacity to make good administration. Hence Kejriwal kept no department with him. Delhi is being run by Deputy CM Sri Shishodia. Voter expressed his trust in Kejriwal, now some feel deceived. Such acts of Kejriwal and his government are corrupt practice, which is disloyalty to the state as well as residents of the state. This act of Kejriwal is a corrupt practice that is disloyalty to the state as well as residents of the state.

68. That Leader of the Opposition in the Delhi Assembly Vijender Gupta said Kejriwal government hired a private PR agency spending crores despite having an army of media advisors, own advertising agency -- Shabdarth and Directorate Information and Publicity. Some TV channels are saying the AAP government has spent Rs 200 crore to hire a PR agency. It is the talk of town that Kejriwal is spreading naxalism. It is proved from the inclination of Kejriwal towards JNU leader Kanahya. Kejriwal who do not allow to Mayer of NDMC or anyone else to enter his house, but he invited Kanahya for dinner. Kejriwal also called a naxalite leader from Bihar at this occasion, to empress Kanahya. Hiring of private agency to preach his views in Delhi and other states, started a new controversy, that Kejriwal is making arrangement to start Naxal movement in Delhi. Delhi is the capital of India. It must be secular and social. If it becomes a hub of naxalism or any type of other radicalism, democratic structure of India will be in danger. Such acts of Kejriwal and his government are corrupt practice, which is disloyalty to the state as well as residents of the state.

69. That last year congress was demanding from Modi, resignations of some office bearers, those were in controversy of bribe. With the motive to play Chankia tactic, Kejriwal called his Mohamadan Minister Asim Ahmed Khan and asked him to resign, on the false blame that I have received a complaint, that you were asking bribe from any builder. Even name of builder and informer was not mentioned. Kejriwal thought that modi will follow his suit and ask resignations of both office holders. Hence he will gain a lead over Modi. After the dramatic announcement, Mr Kejriwal dared the PM to do the same with its office bearers i.e. Sushma Swaraj, Vasundhara Raje, Pankaja Munde, Smriti Irani, who are caught in controversies. He challenged Modi to follow him. Such incidents prove the mental capability of Kejriwal, to administration and rule the capital of India. Such acts of Kejriwal and his government are corrupt practice, which is disloyalty to the state as well as residents of the state.

70. That in October 2014 central government decided to compensate the families of 1984 anti sikh roits. Government has estimated expenditure of around Rs. 130 crore on compensation. Compensation to Rs. 5 lakh was announced by the central government, five months after the BJP had formed its government at the Centre. Chief Minister announced that he will distribute compensation cheques to kin of 1984 anti-Sikh riot victims on November 1. All families of the riot victims will be given compensation cheques within two or three days begnining from Sunday," Official of Delhi Govt said that Centre will later refund the compensation amount to the Delhi Government as it was their scheme. Union Home Minister Rajnath Singh had, in December 2014, distributed compensation cheques of Rs. 5 lakh each to the 17 kin of riot victims in West Delhi's Tilak Vihar area. Now aap leaders of Punjab claim that compensation was given by Kejriwal, whereas supports of Modi claim that compensation was given by Modi Govt. Kejriwal visited many times to Punjab but did not clarify about the compensations to Sikh victims. It seems that Kejriwal is misguiding or keeping in confusion Punjab voters, for his election gain in 2017. Such acts of Kejriwal and his government are corrupt practice, which is disloyalty to the state as well as residents of the state.

71. That during killing of Sikhs in 1984, 2700 persons were killed mostly in Delhi. Kesriwal told the Sikhs that during his first short term regime he was planning to make SIT (Special Investigating Team). But when I came to power next time, the central Govt made SIT even a day before formation of my government. That SIT did nothing. If central Govt dissolve his SIT, then I will make the SIT to provide Justice to Sikhs. It is purely a deceit with Sikhs. Constitution divided powers between center and state, by making union list and state list. Whether killing of Sikhs is in union list, so Kejriwal Govt is not authorized to make SIT? If center made SIT, State can also make its own SIT. Court will consider both reports, if both made some investigation and submit to the court. If any difference arises, higher court will decide. Kejriwal is misguiding the Sikhs for election gain. Kejriwal says he is examining the legality of SIT. 18 months has elapsed, he failed to get any decision. Actually he is deceiving and cheating the Sikhs. Such acts of Kejriwal and his government are corrupt practice, which is disloyalty to the state as well as residents of the state.

72. That Delhi Legislative Assembly Deputy Speaker and Aam Aadmi Party leader Bandana Kumari was forced to submit her resignation to Chief Minister Arvind Kejriwal. Kumari was elected from the Shalimar Bagh constituency in Delhi after defeating three-time sitting MLA. She is also the president of women's wing of the party, Aam Aadmi Party Mahila Shakti. It is said that only fault with her was that she asked Kejriwal to make some amendment in his style of working. Election law bans prohibition of monopoly of any person on party. Such acts of Kejriwal and his government are corrupt practice, which is disloyalty to the state as well as residents of the state.

73. That Delhi Govt has decided to redesign Delhi Roads, and allotted a big amount of 5000 crores for it. Such redesigning is dividing roads in six parts, left side will include specific lanes for buses, pedestrians and public vehicles. Same three parts, on right side. It is said that big amount is being invested foreign consultancy. Delhi has no road with limited movement, which may be divided in six parts. This project is not implementable, and only a style of mining the Delhi funds. Such acts of Kejriwal and his government are corrupt practice, which is disloyalty to the state as well as residents of the state.

74. That some schools belonging specifically Jain and other Hindu organization decided that the children whose parents smoke, eat non-veg or drink will not get admission. Some schools decided that children whose parents paint or know music will get extra points. The criteria are so arbitrary and," Mr. Kejriwal discriminated such admission and imposed penalty by imposing scrapping discretionary quota. Painters and musicians provide extra quality to their child. What is bad if such student is preferred from an ordinary student? Painters and musicians not belongs to higher classes, they general belong to poor class. Rejection of admission to children of smoker, drinker and non-veg family will upgrade the society by redemption from evils. Whether Kejriwal want that such students should be preferred, and there parent should indulge to such evils to get admission? Such acts of Kejriwal and his government are corrupt practice, which is disloyalty to the state as well as residents of the state.

75. That ‘AAP 21’ controversy and the water scam, the AAP government, since 2014, has not lifted a finger to cancel contracts with a vendor who has been found guilty of irregularities in connection with the manufacture of high security number plates. Supreme Court has also upheld the findings of the committee and after the top court's observations even the Madhya Pradesh and Sikkim government snapped the contracts it had entered into with this particular vendor but not the Kejriwal government. This ambivalence is now forcing the civilians to question the intent of the AAP government and its reluctance to act in the face of a racket that purportedly is running into 300 crores. Such acts of Kejriwal and his government are corrupt practice, which is disloyalty to the state as well as residents of the state.

76. That newsX Bureau published its report on 23 June 2016, in which they said “Despite spending over 500 crores on advertisements, Delhi Chief Minister Arvind Kejriwal feels he needs an image revamp. So the Delhi Govt has contracted a PR firm, aptly called perfect relations, to give it a boost after scam allegations and numerous controversies rocked the national capital and threatened to dim the luster of Arvind Kejriwal credentials. Major part of these 500 crores was used in Punjab to blow the storm of disinformation to youth of Punjab. Citizens of Punjab have the right to know that: For what lawful purpose such a big amount was used? Such acts of Kejriwal and his government are corrupt practice, which is disloyalty to the state as well as residents of the state.

77. That On March 13, 2015 Chief Minister Arvind Kejriwal had passed an order appointing the 21 MLAs, including Alka Lamba, Jarnail Singh, Adarsh Shastri and Rajesh Gupta, as Parliamentary Secretaries. Attempting to save from disqualification provisions for holding two offices of profit at one time, the Delhi Government then sought to amend the Delhi Members of Legislative Assembly (Removal of the Disqualification) Act, 1997. The Bill was forwarded by Lieutenant Governor to the Centre, which in turn sent it to the President with its comments. Hon President Shri Pranab Mukherjee withheld the assent to a Bill. The Election commission on Monday decided to hear the plea of 21 Aam Aadmi Party (AAP) legislators, who were appointed as Parliamentary Secretaries by the Delhi Government. Kejriwal not removed them from posts of profit. Such acts of Kejriwal and his government are corrupt practice, which is disloyalty to the state as well as residents of the state.

78. That Kejriwal planned to fleece health sector to oblige his members of legislative assembly. Kejriwal percepts dethrone by their MLA’s, he is forced to fleece the state and put into the pocket of Legislators. 27 MLAs have been appointed as the chairman of 38 hospitals, whereas the guidelines given by the Central Government in 2015 are highly categorical in nature. It states that only the district magistrate or the local MP or the health minister can be appointed as the chairman. Local MLAs can only become a member of the committee. Coming down heavily on Delhi Chief Minister Arvind Kejriwal, Vibhor Anand, a final year law student on Friday demanded the disentitlement of the 27 Aam Aadmi Party (AAP) MLAs over the office of profit issue after filing a fresh application with the Election Commission. The 27 MLAs include seven legislators against whom the Election Commission is already considering a similar plea. The list includes Delhi Assembly Speaker Ram Niwas Goel, his deputy Rakhi Birla, former deputy speaker Bandana Kumari and estranged AAP MLA and Swaraj Abhiyan leader Pankaj Pushkar. Such acts of Kejriwal and his government are corrupt practice, which is disloyalty to the state as well as residents of the state.

79. That Kejriwal "suppressed" for 11 months the report of a fact-finding team that probed the alleged irregularities in hiring some 385 stainless steel water tankers by the Delhi Jal Board in 2012 during the tenure of the Congress government headed by Shiela Dikshit. Water Minister Kapil Mishra gave report of the fact-finding committee to Kejriwal, but Kejriwal made delay intentionally in sending the report to Lt. Governor. Payments to the private company were carried on for 17 months, instead of cancelling it. Keshav Chandra, who was earlier private secretary to Dikshit, was made Chief Executive Officer of Jal Board. AAP government in June 2015 set up a five-member fact-finding committee to probe the alleged irregularities in hiring some 385 stainless steel water tankers by the Delhi Jal Board in 2012 during Dikshit's tenure. Report was submitted to Kejriwal in August 2015, highlighted an alleged corruption of Rs 400 crore, in the process of awarding tenders for hiring water tankers, and recommended FIR against Dikshit and a further probe by the CBI or the ACB. Such acts of Kejriwal and his government are corrupt practice, which is disloyalty to the state as well as residents of the state.

80. That in 1999 state government of Delhi implemented significant reforms to the power sector. It separated the Delhi Vidyut Board, (the state electricity board), into two power generation companies, one transmission company, and three distribution companies. State government sold 51 % share to private investors, two controlled by Reliance Infrastructure and one by Tata Power Company, and retained a 49% stake in each company. Area under the New Delhi Municipal Council, home to a large number of politicians and top-level bureaucrats, where power supply is still entirely controlled by the Delhi government. During election, Kejriwal allured voters that after forming Govt, he will get audited all three electricity companies that will lead to 50% reduction in electricity bills. But after election Kejriwal settled the issue and put a very hug amount of Delhi tax payers, equal to half of the present electricity bill, at the disposal of those companies. This act of Kejriwal is a corrupt practice that is disloyalty to the state as well as residents of the state.

81. That, to befool the public Kejriwal went to court, get permission to audit the three companies, but not contested the case seriously. Voter feel obliged to Kejriwal for 50% discount in bill, but in reality that is being cheated as he is paying full amount, even with his own money. Kejriwal never think about the cancellation of agreements with the distribution companies. Nor made any effort to amend the agreements, while both generation companies and Transmission Company, is still under him. Such acts of Kejriwal and his government are corrupt practice that is disloyalty to the state as well as residents of the state. This act of Kejriwal is a corrupt practice, which is disloyalty to the state as well as residents of the state.

82. That CBI on Monday arrested Rajendra Kumar, Delhi Chief Minister Arvind Kejriwal's principal secretary, on corruption charges. FIR 16 Dec 2015, registered by the CBI said that Mr. Kumar favoured Endeavours Systems Private Limited in 2006 for a total sum of Rs. 50 crores when he was in charge of the education department in Delhi. This front company was to provide Information Technology solutions and software to Delhi government schools. Arvind Kejriwal's Deputy Secretary Tarun Sharma was also arrested in this case. Delhi BJP president Satish Upadhyay said. “Be it in Kejriwal’s first 49 days stint or the present regime, Rajendra Kumar has manipulated funds worth over Rs 200 crores…Kumar seems to be the parrot in whom Kejriwal’s soul is stuck and with him in CBI net, the entire Kejriwal gang now fears the outbreak of their corrupt sagas,” Overall, contracts worth about Rs 57 crore were awarded to these companies. This act of Kejriwal is a corrupt practice that is disloyalty to the state as well as residents of the state.

83. That CBI’s investigation was launched in response to a complaint filed by former Delhi Dialogue Commission member, Ashish Joshi. Joshi was one of the first bureaucrats Kejriwal had an issue with, which led to him resigning from the commission. Kumar was also a secretary in Sheila Dikshit’s administration, the term during which he is being accused of corruption. Sheila Dikshit’s expelled him after corruption charges. When Kejriwal became CM, he appointed Mr. Kumar as his Principal Secretary. Last June he was given additional charge as home secretary. Jung not approved it, and appointed Dharam Pal as home secretary. It further led to a peculiar situation where both Kumar and Pal were functioning from the Delhi secretariat. Kejriwal is promoting corruption by defending criminal elements. Such acts of Kejriwal are corrupt practice that is disloyalty to the state as well as residents of the state. This act of Kejriwal is a corrupt practice that is disloyalty to the state as well as residents of the state.

84. That Kejriwal promoted acts of Des-Dharoh. Example is Afjal support at JNU. Kejriwal invited Kanahya, for dinner. Kejriwal waited Kanaya for long time. Kanaya avoided this dinner for any important task. Kejriwal is also promoting Naxalism in India. This act of Kejriwal is a corrupt practice that is disloyalty to the state as well as residents of the state.

It is requested that accused 1 to 7 be summoned for inquiry against them, and made report to Governor Chandigarh. Persons 8 to 13 be summoned to clarify the true facts, and their failure to take needed action.

Submitted by

Harbans Singh Jalal

s/o S Mehar Singh

R/o 86 Sigma City, Lohgarh Chowk

Zirakpur (Mohali) Punjab. 140603

Telephone: 9872020400. E-Mail: harbansjalal@gmail.com

ANNEXED:-

Print media cuttings, numbered 50, of a newspaper Jagbani, to prove that there was e vide confrontation to the above mentioned acts of accused persons. There is wide spread controversy in dozens of Punjab and Delhi, in Print Media, TV Media, and social media i.e. Facebook, Twitter, etc.