Complaint against Accused Persons for Fraud, Cheating and Criminal Breach Mrs. Shazia Farooq & Sajad Ahmad Wani

[dilip kumar bhat]

Dealer Name

Solor Solutions

Company Name

Solor Solutions

Product Name

Free Solar Panel

Customer Care Number

9796216216

Loss Amount

275000

Ratings

1.00 star(s)

Opposite Party Address

Al Quds Complex, near KFC Building, Housing Colony, Bemina, Srinagar, Jammu and Kashmir 190018

Respected Madam/Sir,

I, Dilip Kumar Bhat, S/o Bhushan Lal Bhat, R/o Lower Roopnagar, Contact No.7889322795, most respectfully beg to submit the following complaint against the above-named accused persons for committing fraud with me and my brother-in-law under the pretext of a free solar panel installation scheme, and for the negligent/complicit sanctioning of a loan without due diligence. The facts of the case are stated below for your kind perusal and necessary action.
Complaint against Accused Persons for Fraud, Cheating and Criminal Breach of Trust in the name of a "Free Solar Panel" Scheme, and Negligence/Complicity of Concerned Bank Officials in Sanctioning the Loan
Details of Accused Persons:
Accused No. 1: Smt. Shazia Farooq, W/o Sajad Ahmad Wani, R/o Bilal Colony, Bemina, Srinagar, Proprietor of "Solar Solutions" (Beneficiary account holder in whose name the loan amount was received).
Accused No. 2: Mr. Sajad Ahmad Wani, Tenant at Safa Valley (Mastermind who devised the fraudulent scheme and obtained the documents).
Accused No. 3: The concerned Bank Manager/Loan Sanctioning Official(s) of the bank branch(es) from which the loan was sanctioned and disbursed (Account No. 1205261250000059) and in which it was credited (Account No. 0002010100008573), for sanctioning the loan without proper verification.

1. Background of Acquaintance
Accused No. 1: Smt. Shazia Farooq, W/o Sajad Ahmad Wani, R/o Bilal Colony, Bemina, Srinagar, Proprietor of "Solar Solutions" (Beneficiary account holder in whose name the loan amount was received).
Accused No. 2, Mr. Sajad Ahmad Wani, has been residing as a tenant in a flat in Safa Valley for several years. I have also been working in the same locality, and during this period, I used to interact with him regularly regarding the monthly maintenance and utility payments of the flat in which he resides as a tenant.
2. The Fraudulent Offer
During the course of this acquaintance, Accused No. 2 offered to install a solar plant on the rooftop of my house, claiming that the offer was completely free of cost and was being extended to only one customer under a scheme of the company "Luminous". He stated that I would not have to pay a single penny for the installation.
He further informed me that the only condition attached to this offer was that the documents of a government employee were required for "approval purposes" from the company. I informed him that I am employed in the private sector and could not fulfil this condition. He then requested that I provide the documents of any relative of mine who is a government employee, purely for approval purposes.
3. Documents Provided in Good Faith
Believing his representations to be genuine, I provided the documents of my brother-in-law, Mr. Vicky Kumar Bhat, who is a Government employee working with the JKAS/Jal Shakti (JJM) Department, Government of Jammu & Kashmir, posted at Srinagar. Accused No. 2 sent a person to my brother-in-law's office, where he signed certain papers and handed over the required documents, believing this to be a mere formality for approval of the "free" scheme.
4. Unauthorized Loan Sanctioned Without Proper Verification
Subsequently, it came to light that Accused No. 2, using the documents obtained from my brother-in-law, got a loan sanctioned and disbursed in the sum of Rs. 2,75,000/- (Rupees Two Lakh Seventy-Five Thousand only) on 14-09-2023, from my brother-in-law's bank account bearing Account No. 1205261250000059, transferred to Account No. 0002010100008573, held in the name of "Solar Solutions", Proprietor Accused No. 1, Smt. Shazia Farooq W/o Sajad Ahmad Wani, R/o Bilal Colony, Bemina, Srinagar. This loan was taken without proper, informed consent as to its true nature and consequences, on the false pretext that it was merely a formality for a free scheme.
It is submitted that the concerned bank/branch officials (Accused No. 3), who processed and sanctioned this loan, failed to carry out proper verification of my brother-in-law as the actual applicant/borrower, and failed to independently confirm his informed consent, intent, and understanding of the loan liability being created in his name before disbursing such a substantial amount. Such sanctioning of the loan without adequate KYC/verification process raises serious doubt as to whether the concerned bank official(s) acted negligently or in connivance with Accused No. 1 and Accused No. 2, thereby facilitating the commission of this fraud. It is requested that the role of the concerned bank official(s) involved in sanctioning and disbursing this loan be thoroughly investigated.
5. Non-Installation of the Solar Plant
After the loan amount was transferred, I repeatedly contacted Accused No. 2 on a weekly basis enquiring about the installation of the solar plant. He kept giving false excuses such as "documentation is under process" and "the solar panel has not been dispatched yet." To date, no solar plant has been installed at my premises.
6. Burden of EMI Payments Shifted to Me
In the meantime, the EMI against the said loan started getting debited from my brother-in-law's account. On being questioned, Accused No. 2 assured me that the company would bear the EMI, which never happened. He himself started paying the EMI irregularly through different accounts via UPI/mobile payment applications. Although the EMI is auto-debited from the account on the last working day of every month, he would make the payment only around the 25th of the following month, and only after repeated reminders made on an hourly and daily basis by me. To avoid default and protect my brother-in-law's account and credit standing, I personally started transferring the EMI amount before the 20th of every month from my own account.
7. Default in EMI Payments Since June 2026
For the last two months, i.e., from June 2026 onwards, Accused No. 2 has completely stopped paying the EMI against the loan taken for a solar plant that has still not been installed. When confronted, he has given the excuse that he purchased a house in Srinagar from a Kashmiri Pandit family, which he later sold to another person, and that the said property has now been sealed by the Police, due to which he claims he is unable to pay the EMI.
8. Present Position and Request
I have already informed Accused No. 2 that he may go ahead and install the solar plant at my premises, and that I myself would bear the EMI thereafter — I am not asking him to pay it. Alternatively, I have requested him to repay the entire outstanding loan amount in one instalment so that the loan account can be closed permanently. Despite this, he has neither installed the solar plant nor cleared the outstanding loan amount, causing continuous financial loss and mental harassment to me and my brother-in-law, Mr. Vicky Kumar Bhat, in whose name the loan stands.
It is submitted that the entire scheme was a pretext devised by Accused No. 2, in furtherance of common intention with Accused No. 1 (in whose account the loan proceeds were received), to fraudulently obtain a loan in the name of my brother-in-law and misappropriate the loan amount, without any intention of ever installing the promised solar plant. It is further submitted that this fraud could not have been executed without lapses on the part of Accused No. 3, whose role in sanctioning the loan without proper verification requires thorough investigation.
Prayer
It is, therefore, most respectfully prayed that this Hon'ble authority may kindly:
a) Register an FIR against Accused No. 1 (Smt. Shazia Farooq), Accused No. 2 (Mr. Sajad Ahmad Wani), and the concerned Bank Official(s) (Accused No. 3) under the relevant provisions of law relating to cheating, criminal breach of trust, fraud and criminal conspiracy;
b) Investigate the loan transaction dated 14-09-2023 for Rs. 2,75,000/- from Account No. 1205261250000059 to Account No. 0002010100008573, including the internal loan-processing/verification records and the identity of the bank official(s) who sanctioned and disbursed the said loan;
c) Ascertain whether due KYC/verification norms were followed by the bank before sanctioning the loan, and fix accountability of the concerned official(s) if found negligent or complicit;
d) Direct recovery of the outstanding loan amount from the accused persons and closure of the said loan account;
e) Take strict legal action against all the accused persons so that no other person falls victim to such fraudulent schemes in future.
I shall remain highly obliged for this act of kindness. I am enclosing herewith copies of relevant documents, including bank transaction details, in support of this complaint. I am ready to cooperate fully with the investigation and provide any further information/documents as may be required.
Pls below the mentioned attached Documents.
Thanking you,
Yours faithfully,
Name: Dilip Kumar Bhat
Address: H.No-129/A Lower Roopnagar Jammu
Contact No.: 7889322795