Mr. Mukund Pawar,

Sr. Inspector of police,

Cyber Crime Investigation Cell,

Crime Branch, CID, Mumbai-400001

Subject: Reply to your email dated 28/02/1014 vide letter noO.W. No. 970/BKG/CCIC/14

Dear Sir,

With reference to your above mentioned communication via email, I

wish to clarify the following:

1) That, the allegations mentioned in the complaint filed by Mr Dinesh Waghela,

Deputy General Manager of the New India Assurance Company Ltd, Mumbai are

completely false, baseless and vehemently denied at the very outset.

2) That, it is reiterated that my services were illegally transferred by the New India

Assurance Company in June 2007. Since then I have been fighting for my rights

in the Court of Law. I have filed various RTI’s and writ petitions to seek justice .

My matter with the New India Assurance Company (NIACL) is already pending in

the Diary No. 41357/2012 before Hon’ble Supreme Court and High Court of

Rajasthan vide Case No. 14838/2010 and 4007/2012 etc.

3) That, as a layman I do not possess the knowledge of law necessary to fight for

my rights in the competent Court of Justice. Hence I got myself registered on the

forum - Lawyers Club India in May 2009 where free advice is delivered by

lawyers, practising advocates, solicitors etc to people in need. As mentioned in

my earlier reply, I do not possess any source of income and finding myself

unable to hire legal services, I registered on this forum in the hope of getting

genuine advice from legal practitioners.

4) That, it is denied that I ever made allegations against Mr Sekar, Director and

General Manager of New India Assurance Company. A careful perusal of the

alleged comment mentioned in your letter, as complained by Mr Waghela, clearly

shows that the comment was directed towards the person accompanying Mr

Sekar in the official function, i.e Mr Kalyan Sahai,who enjoys promotional

opportunity even after one decade of recorded act of demanding bribe..

5) That, In this regard I wish to rely upon the letter of Mrs Kamlesh Vashist dated

7/12/2005 addressed to Anti Corruption Bureau which clearly mentions that Mr

Kalyan Sahai was caught red handed demanding bribe of Rs 1300, which was

finally settled at 1000, from the complainant who filed an FIR for theft of the

Suzuki Motor Cycle bearing number RJ 34M5868 registered in the name of the

brother of the complainant in Hindon Police Station when Mr. Kalyan was

contacted for the purpose of seeking claim from the insurance company.

6) That, it is on record that the investigation in this regard was conducted under

Section 7. 13(1) (d) 2 Prevention of Corruption Act 1988 by Mr. Lakshman Gaud,

Additional Police Superintendent during January 2003 and the finding arrived at

was that the accused in that matter (Mr Kalyan Sahai in the case at hand)

demanded bribe from complainant. It is also pertinent to mention that the

explanation of Mr Kalyan Sahai was not found satisfactory. A copy of the said

letter of Mrs. Kamlesh Vashist is attached herewith as Annexure A.

7) That, It is also pertinent to mention that I have the right to challenge the locus

standi of Mr Waghela to institute the present proceedings more so when there

has been no copy of the resolution of Board of Directors, passed in this regard,

annexed to the complaint filed by the above said person. In this regard I wish to

state that response is awaited in respect of RTI appeal preferred by me.

8) That, I am unable to open the link mentioned by Mr Waghela, i.e.

http://www/lawyersclubindia.com/forum/displaybymembers.asp?memberid=

28764#.UTRwtfJaQwo. On opening the same the message appears ‘page not

found’.

9) That, it is denied that I used derogatory and false statements against the

company and its official which tarnish the image of the company.

10)That, it is denied that I had any intentions to defame the goodwill and image of

the company and its officials. On the contrary my comments/statements, if any,

were aimed at seeking genuine advice for my concerns.

11)That, as a citizen of India, I am guaranteed the Fundamental Right of Freedom of

Speech and Expression under Article 19 of the Constitution and it is a violation of

the same if I am restricted in any manner to publish my true, genuine and

legitimate grievances against systematic corruption, more so when my intentions

were directed towards seeking legal advice.

12)That, Prevention of Corruption Act, 1988 was passed by the Legislature with the

Preamble ‘An Act to consolidate and amend the law relating to the prevention of

corruption and for matters connected therewith’. Acts of bribe taking and other

related activities were made offences under this Act with a view to prevent the

society from this rampant evil and accordingly offences like these, when

committed, no longer remain offences against the person who is affected by

them but constitute offences against the society at large. In such a scenario, it is

no crime to build awareness in the general public against them and also the

perpetrators who commit them. Public Forums like Lawyers Club India is one

such platform where people are, inter alia, free to express their views against

promotion of those involved in such shameful acts, which not only disrespect the

law of the land but also distort the procedure established by law.

13)In such a scenario, there is no violation of law of the land committed on my part.

14)Having regard to the aforementioned facts, it is humbly submitted that the

complaint filed by Mr Waghela is not only vague as it does not mention the

sections of the relevant Act which are alleged to have been violated by me but is

also liable to be rejected as being frivolous merely a tactic to stop me writing RTI

applications in the matter of prevailing cover up to corruption in the company.

15)It is requested that the requirement of my personal presence may kindly be

waived off and my reply to your email may be considered as my prima facie reply

in the matter. I also wish to reiterate that I shall be defending the matter on my

own as I am unable to afford a lawyer to defend the charges, if any, in this matter

as the issue of my employment is pending before the competent

Tribunal/Court(s) and no subsistence Allowance has been fixed in the matter. In

such a scenario, I would request you to allow me to put forward my defence

through video conferencing/ emails or other means.

16)I also request for leave to add/alter my reply according to documents placed by

on record before you by Mr Waghela.

17)It is also reiterated that the email account used by me

in the regular course is.revribhav@gmail.com or revribhav2@gmail.com and not

revribhav@yahoo.com which is seldom used after it being hacked. I request you

to send me your response and other intimations on revribhav@gmail.com so

that I can access them timely and respond to them as well.

18)I reserve my right to claim damages against New India Assurance Company

and/or Mr. Waghela, for causing me harassment and mental anguish in

defending frivolous complaint(s), should I choose to do so anytime in future.

. Thanking you,

Shri Gopal Soni

C231,Panchsheel Nagar,AJMER-305004 Tel. 0145-2644106

♦iSa

Cyber Crime Investigation CellCrime Branch, Mumbai.office of Commissioner Of Police,

Annex-Ill Building, Floor, Mahatma Phule Market , Sir. D.N.Road,Mumbai - 400001 , INDIA® 022 -22653714Email to: cvbercell.mumbai©mahaDolice.Qov.in .

Website: -www.cybercellmumbai.gov.ln

O.W. No. 970/BKG/CCIC/14, Date:- 28'� Feb, 2014.

To,Gopal Soni,C-231 Panchsheel Nagar,Makarwall Road,Ajmer, Saradhana,Rajasthan - 305001,

Sub To remain present for enquiry a t CCIC, Mumbai.

We have received your le t ter dated 27�*� Jan, 2014 in response to our let terO.W. No. 220/BK(5/CCIC/14, dated 15�*� Jan, 2014. As per your request, weattached herewith the scan copy of the complaint lodged by Mr. Dinesh Waghela,DGM of the New India Assurance Company Ltd, Mumbai for your information

please.

You are now again informed to be present for an enquiry before the

undersigned on 10/03/2014 at 12:00 hrs.

(Mukund Pawar),Sr. Inspector of Police,

Cyber Crime Investigation Cell,Crime Branch, C.I.D., Mumbai,• Ph. No. 022-22653714.

THE NEW INDIA ASSURANCE COMPANY LTD.87,3�?Tc9�I3M��p�, 400001

Read. & Head Office : New India Assurance BIdg., 87, M.G. Road, Fort, Mumbai- 400001

CORPORATE HRM IDD: CC: 2013

2Fax : 022-2

Telegram ; NIASlWebsite : www.n

2*h March 2013

Mr. Mukund Pawar,Asst. Commissioner of PoliceCrime Branch, Cyber Crime Cell,Mumbai.

Dear Sir,

Re: Frivolous and Defamatory mails and postings in 'Lawyers Club India Forum"

We are in receipt of letter from our Director and General Manager, Mr. A.R. Sekar whereby, itwas informed that he has received mail dated 5.2.2013 from reyribhay@yahoo.com, whichwas actually a forwarded mail dated 4.2.2013 from the Lawyers Club India Forumdonotreply@lawyersclubindia.com. to Mr. Shri Gopal Soni.

On perusal of the contents of the said mail, it is found that there are allegations against Mr.Sekar, which are derogatory, defamatory and devoid of truth.

The undersigned have checked the website of the said Lawyers Club India and found outthat one Mr. Shri Gopal Soni, ex-employee of our Company, who was terminated throughDisciplinary Action, has posted a photo of Mr. Sekar, with some of our employees attendingan official function and captioned it as "the blessings of A.R. Sekar and his associates work infavour of well known bribe taker of salary No. 260/9. He has been declared successful inwritten exam held during first week of December 2012. If all goes well he may any day bepromoted."

On examination of the entire website, thereafter, it is found that Mr. Shri Gopal Soni haspublished various posts containing derogatory and defamatory statements against theCompany and our various officials, which appears to tarnish the image of the Company atpage:

http://www.lawyersclubindia.com/forum/displav by members.asp?member id=28764#.UTRwtfJaQwo.

The Management is aggrieved by the derogatory and false statements against Mr. Sekar,being our Company's Director and General Manager and its other officials, which is ordainedto defame the good-will and image.

This is to request your good self to kindly take necessary action against ttre culprits behind thesaid acts under the relevant laws.

Regards,

(Dinj�sh Waghela)Deputy General Manager