Thirugnanasambandham K
New member
- Dealer Name
- M.Manikandan
- Company Name
- M/s Tejas City Developers, Tejas City Developers and Builders, 5, Trichy Road, Sarathy Nagar,Singanallur, Coimbatore – 641005, Tamil Nadu. Phone: +91-9788088880, +91-8428828882 Email:tejascitydevelopers@gmail.com
- Customer Care Number
- +91-9788088880
- Loss Amount
- 850000
- Ratings
- Opposite Party Address
- M/s Tejas City Developers, Tejas City Developers and Builders, 5, Trichy Road, Sarathy Nagar,Singanallur, Coimbatore – 641005, Tamil Nadu.
Phone: +91-9788088880, +91-8428828882
Email:tejascitydevelopers@gmail.com
Subject: Petition to register an FIR against M/s Tejas City Developers for Criminal Cheating, Statutory Violations under RERA, and Unfair Trade Practices.
Accused: Partners/Directors of M/s Tejas City Developers, Tejas City Developers and Builders, 5, Trichy Road, Sarathy Nagar,Singanallur, Coimbatore – 641005, Tamil Nadu.
Phone: +91-9788088880, +91-8428828882
Email:tejascitydevelopers@gmail.com
Respected Sir,
I am writing to formally lodge a criminal complaint against the aforementioned Accused for a pre-planned conspiracy to cheat and defraud me of ₹1,00,000/- (One Lakh Rupees) under the guise of a real estate allotment in the project "Dhanalakshmi Avenue," Negamam.
The Accused has committed the following non-bailable offenses:
1. Criminal Cheating & Dishonesty (Section 318(4) BNS / Sec 420 IPC)
The Accused induced me to pay a booking advance on June 11, 2024, for Plot No. 11. I have recently discovered via the official layout map that the Accused had either already registered or intended to sell this same plot to third parties while holding my funds. This proves criminal intent (Mens Rea) to deceive from the inception, a classic offense under Section 318(4) of the Bharatiya Nyaya Sanhita (formerly IPC 420).
2. Illegal Collection of Advance (Section 13 of RERA Act, 2016)
The total value of the plot was agreed at ₹8,50,000/-. As per Section 13(1) of the RERA Act, a promoter is strictly prohibited from accepting more than 10% (i.e., ₹85,000/-) without a registered Agreement for Sale. The Accused illegally extracted ₹1,00,000/- from me, violating statutory law to use my money as an interest-free loan for two years.
3. Unfair Trade Practice (Consumer Protection Act, 2019)
By withholding my money for two years and refusing to register the plot and not give sale agreement, the Accused has committed a gross "Deficiency in Service" and "Unfair Trade Practice." Their refusal to pay interest or provide the asset has caused me immense mental agony and a permanent loss of real estate opportunity in the escalating Coimbatore market.
PRAYER
I previously filed a complaint at the local police station (Complaint Reference Number OLC5852600011361), where the management of Tejas City Developers explicitly promised to execute the registration of Plot No. 11 by May 18, 2026. However, the Accused has will fully defaulted on this commitment, demonstrating a complete lack of obedience to police intervention and a clear, ongoing intent to cheat. This breach of promise further confirms the criminal intent required for an FIR under Section 318(4) of the BNS.
I submit that as per the ruling in Jyoti K. Narang v. CCI Projects, a booking document identifying the plot and consideration is a binding contract. Furthermore, by accepting ₹1,00,000—which exceeds the 10% statutory limit under Section 13 of the RERA Act—the Accused has legally moved this transaction beyond a mere 'inquiry' into a Final Allotment Order. Under the Doctrine of Promissory Estoppel, the Accused is now duty-bound to register the property as per their official undertaking at the police enquiry.
Accused: Partners/Directors of M/s Tejas City Developers, Tejas City Developers and Builders, 5, Trichy Road, Sarathy Nagar,Singanallur, Coimbatore – 641005, Tamil Nadu.
Phone: +91-9788088880, +91-8428828882
Email:tejascitydevelopers@gmail.com
Respected Sir,
I am writing to formally lodge a criminal complaint against the aforementioned Accused for a pre-planned conspiracy to cheat and defraud me of ₹1,00,000/- (One Lakh Rupees) under the guise of a real estate allotment in the project "Dhanalakshmi Avenue," Negamam.
The Accused has committed the following non-bailable offenses:
1. Criminal Cheating & Dishonesty (Section 318(4) BNS / Sec 420 IPC)
The Accused induced me to pay a booking advance on June 11, 2024, for Plot No. 11. I have recently discovered via the official layout map that the Accused had either already registered or intended to sell this same plot to third parties while holding my funds. This proves criminal intent (Mens Rea) to deceive from the inception, a classic offense under Section 318(4) of the Bharatiya Nyaya Sanhita (formerly IPC 420).
2. Illegal Collection of Advance (Section 13 of RERA Act, 2016)
The total value of the plot was agreed at ₹8,50,000/-. As per Section 13(1) of the RERA Act, a promoter is strictly prohibited from accepting more than 10% (i.e., ₹85,000/-) without a registered Agreement for Sale. The Accused illegally extracted ₹1,00,000/- from me, violating statutory law to use my money as an interest-free loan for two years.
3. Unfair Trade Practice (Consumer Protection Act, 2019)
By withholding my money for two years and refusing to register the plot and not give sale agreement, the Accused has committed a gross "Deficiency in Service" and "Unfair Trade Practice." Their refusal to pay interest or provide the asset has caused me immense mental agony and a permanent loss of real estate opportunity in the escalating Coimbatore market.
PRAYER
I previously filed a complaint at the local police station (Complaint Reference Number OLC5852600011361), where the management of Tejas City Developers explicitly promised to execute the registration of Plot No. 11 by May 18, 2026. However, the Accused has will fully defaulted on this commitment, demonstrating a complete lack of obedience to police intervention and a clear, ongoing intent to cheat. This breach of promise further confirms the criminal intent required for an FIR under Section 318(4) of the BNS.
I submit that as per the ruling in Jyoti K. Narang v. CCI Projects, a booking document identifying the plot and consideration is a binding contract. Furthermore, by accepting ₹1,00,000—which exceeds the 10% statutory limit under Section 13 of the RERA Act—the Accused has legally moved this transaction beyond a mere 'inquiry' into a Final Allotment Order. Under the Doctrine of Promissory Estoppel, the Accused is now duty-bound to register the property as per their official undertaking at the police enquiry.
Law/Judgment | What it says |
Section 13 RERA | Taking >10% advance without an agreement is illegal; it confirms a sale intent. |
Jyoti K. Narang Case | A booking letter with terms is a binding Agreement for Sale. |
Consumer Act 2019 | Failure to register after promising is a "Deficiency in Service." |
BNS 318(4) / IPC 420 | Making a promise (registration by 18.05.2026) and breaking it is Criminal Deception. |
I humbly request your office to:
1. Register a formal FIR under Section 318(4) (Cheating) and Section 316 (Criminal Breach of Trust) of the BNS.
2. Investigate the "Double Allotment" of Plot No. 11.
3.
4. Tejas city developers must provide sale agreement.
I am ready to produce all original receipts and layout maps for your perusal.
Sincerely,1. Register a formal FIR under Section 318(4) (Cheating) and Section 316 (Criminal Breach of Trust) of the BNS.
2. Investigate the "Double Allotment" of Plot No. 11.
3.
4. Tejas city developers must provide sale agreement.
I am ready to produce all original receipts and layout maps for your perusal.
பெயர்: திரு. K. திருஞானசம்பந்தம்
முகவரி: 1/108A, புங்கமுத்தூர் – 642207, உடுமலைப்பேட்டை, தமிழ்நாடு
மொபைல்: 9843086090; மின்னஞ்சல்:kthiru123@yahoo.com