After reading this Application you will realise, how highly educated Architects, Engineers commit criminal acts and work hand in glove with Corrupt Bank Managers, by providing false valuation reports.

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BEFORE THE HONOURABLE RECOVERY OFFICER –1
AT DRT1 MUMBAI

Misc. Application No. : of 2009
IN
R. P. NO. 07 of 2006



The Bharat Overseas Bank …….Applicant


VERSUS


Rekha Indur Chhugani .….. Intervener
Age : Adult, Occ. : Housewife,
R/o. : No.501, Pinky Panaroma,
Plot No.215, 6th Road,
Khar (W), Mumbai – 400 052.


Objection about incorrect reports of Recovery Inspector and of Valuer Vastukala Design Build Solutions for valuation of flat 501 after visit on 21.10.2009 recorded as Exhibit No 41, and Exhibit No 43 respectively.

On behalf of the abovenamed Intervener it is most respectfully submitted that:


1. The Recovery Inspector had on 21.10.2009 visited the composite flat 501/502 Pinky Panorama Co-operative Society, 6th Road, Khar, to value the flat 501, which includes a covered garage on the ground floor. This garage is in the physical possession of the Applicant Bank (Bharat Overseas Bank Ltd / Indian Overseas Bank) since 28.7.2004 and remains sealed since 12.10.2004 on which date the Applicant Bank had taken possession of the full (flat plus garage) property through the Chief Metropolitan Magistrates Court under the SARFAESI Act.

2. The keys of this above referred Garage are with Bharat Overseas Bank Ltd,. till today. The possession of this part of the flat was never given to us on 27.2.2005, on which date, the Applicant Banks Chief Manager Mr Mihir Datta, who was Authorised Officer under the SARFAESI Act., gave the possession of the 5th floor composite flat 501/502 to us, after the Joint Committee for sale, comprising of Punjab National Bank and Applicant Bank, took full payment by Bankers Cheques, for composite flat 501/502. The flat 502 which is also falsely valued in 1998 at Rs 2.04 crores, was mortgaged with Punjab National Bank, against loan of Rs 11.5 crores. This is recorded in various cases at the MPID Court and numerous petitions at the Bombay High Court.

3. The Applicant Banks Manager had deliberately not brought the keys of the garage, this fact was pointed out to the Recovery Inspector at the outset and the locked garage door was inspected by the Recovery Inspector along with the Manager of the Applicant Bank, before coming to the composite flat 501/502 on the fifth floor.


4. The 2 valuers from M/s Vastukala Design Build Solutions, who had come about 30 minutes later, were also apprised of the above facts and while leaving, I came down to the ground floor and showed them the locked and sealed garage, with seal of the Applicant Bank, which is considered as part and parcel of flat 501 Pinky Panorama Co-operative Society.


5. It is most shocking that both the Recovery Inspector and the Valuer have not mentioned a single word about the above referred locked and sealed garage in their reports, their reports are in record as Exhibit 41 and Exhibit 43.

6. The Applicant Bank did not came with a copy of the plan for flat 501, which they must have received, when they sanctioned a loan of 6 Crores in 1998, after the borrower mortgaged this flat 501 as the only security. They must have the plan in their records, because Mortgage could not have been taken without copy of the Plan. But they chose not to bring that Plan Copy as they have fraudulently shown the area of this flat 501 as 2000 sq. ft and valued at Rs 2.04 crores in 1998.


7. This false valuation report for flat 501 in 1998 has been obtained by the Applicant Bank from another Valuer M/s Anmol Sekhri and associates. They are now attempting to get a second false valuation report in 2009 with help from Recovery Inspector, by making the valuer M/s Vastukala Design Build Solutions measure the full composite flat 501 / 502 and declare it as a single flat 501.


8. The actions of the Recovery Inspector and the Valuers in not giving an honest report, omitting all facts about the locked and sealed Garage, are an effort to help the applicant Bank keep a close lid on all the frauds that they have conspired and committed with the borrower Soundcraft Industries Ltd., since 1998.

9. The Recovery Inspector and the Valuer are making a deliberate attempt to help the applicant bank escape from the consequences of all the criminal acts that they have committed so far.


10. Earlier this Intervener has filed M A no 24 on 29.6.2007, which contains more details how the Applicant Bank has obtained the warrant of Attachment, by concealing numerous relevant facts of the case, which were within their own and also in the knowledge of their lawyers from Consulta juris, who have appeared for them at the MPID and High Court in cases connected with this property. No reply has been received from the Applicant Bank till today, to this Miscellaneous Application.

11. I therefore humbly request this court to kindly look in to the matter and maintain status quo till some appropriate order is passed in the appeal no 220 filed by me, with the Debt Recovery Appellate Tribunal.

I repeat, reiterate and confirm whatever stated herein is true and correct and to the best of my knowledge and belief.

AFFIRMATION

I Rekha Indur Chhugani, the Appellant abovenamed, R/o. : Mumbai, do hereby state that I have read the contents of the foregoing paragraphs and whatever stated therein is true and correct to the best of my knowledge and belief, for which I affirm and sign as below.


Mumbai : 9/11/2009 Rekha Indur Chhugani
(Appellant)

Identified by me


Naveen Chomal
Advocate for Appellant

CC:1. Hon’ble Mr Justice K G Balakrishnan, CJI Supreme Court.
2. Mr S. B. Biswas,Director ( HC& J),Department of Justice.
New Delhi.

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