Bengaluru: Here is the copy of complaint filed by social activist Abraham T.J, which was later issued to the media. The full text is reproduced below:
The Inspector of Police
Madivala Police Station,
(South Division),
Bangalore-560068
Apparently Conclusive Complaint for the registration of an FIR against deceased IAS Mr.Ravi’s wife Smt.Kusuma Residing flat (Number 903, E Bloch) on the ninth floor of Prestige St.Johns Wood Apartment on Tavarekere Main Road and her father Mr.Hanumantharayappa residing at Mallathahalli in Nagarabhavi, Under Section 306 and 201 of the Indian Penal Code.
If Mr.Ravi’s death on 16th March 2015 is caused by Murder, who could be the vengeful & unhappy suspects/accused of the crime? All those who were directly and indirectly effected by the Non-Corrupt, Upright, Honest and Courageous character of Mr.D.K.Ravi, without any dispute it would be people such as: The Champion Reef Golf County-Confident Group, who had encroached over 48 acres of government land in the Hanchala village near Kolar, with whom the local Congress legislator K M Narayanaswamy was associated. M/s. Nitish Estates (Pvt) Ltd, The Embassy Group, M/s.Asset Properties on Infantry Road, M/s.Golden Gate in Koramangala, Mantri Group of companies, M/s.Rajesh Exports, M/s.Pebble Bay Developers in Sanjaynagar and M/s.RMZ Corp Developers.
All the names mentioned herein above are those which have been made public by the MEDIA and available in public domain.
In normal circumstances all the above the Publicly known enemies should be treated as suspects/accused in the Murder of Mr.D.K.Ravi. I.A.S.
Constructing the events as published & available in the Media & public domain till date:
Why did Mr.Ravi go to his house at 11.00 am?
To get murdered or commit suicide?
1.On the day of occurrence of the death 16th March 2015, Mr.D.K.Ravi goes from his in-law’s residence in Nagarbhavi and reaches his office in Koramangala at 10.30 am. “Though clean shaven, he was not wearing his trademark crisp linen shirt to work; he held a 20 minutes meeting in his office but his mood was uncharacteristically somber and unusually lack-lustre”.
Annexure- ‘A’ Note: If it’s a Murder, Given the Character and proven track record of Mr.Ravi’s nature, none of the Publicly known enemies of Mr.Ravi could not have forced or threatened Mr.Ravi to go to his flat at that time. So one thing is clear that he has volunteered/agreed to go to his house, on being asked to come or asked to go, which he is bound to obey for personal or emotional reasons.
If Mr.Ravi was murdered in his house?
Did the murderer/s know that he would be in the flat?
2.According to news, “His wife, who was staying in her father’s house in Mallathalli, tried to contact him over phone. As he did not answer the calls, she contacted his office where she was told he had left the office in the morning”. Annexure-‘B’, Kusuma, Ravi’s wife of four years, tried to call him later. As there was no response, she called his office and was told he had left. She called Ravi’s driver, who told her he was at the apartment and had not come out. Annexure-‘C-2’. “His wife Kusuma’s two phone calls went unanswered. When she called his driver in the afternoon, she was told that Ravi left the office for home in the morning”. Annexure-‘B-1’. “When Kusuma failed to reach Mr.Ravi on his mobile phone, she called the driver around 4.30 p.m”. Annexure-‘D’.
Note: Three versions
First- Mr.Ravi’s wife called his office when there was no response from him, then she called his driver. Secondly- when two calls went unanswered Mr.Ravi’s wife called his driver in the afternoon, and
Thirdly-When Ravi’s wife failed to reach him on his mobile she called his driver around 4.30pm. One thing is common when there was no response his driver was contacted.
If Mr.Ravi was murdered by strangers in his house?
How did they know he was alone, his wife also absent?
3.“The incident came to light at around 6.30pm when Ravi’s wife, Kusuma, a lecturer in Ambedkar Institute of Technology, and her father came to the flat on the ninth floor of Prestige St.Johns wood apartment on Tavarekere Main Road. Worried over Ravi not responding to their calls, they used a duplicate key to enter the home, and found him hanging”. Annexure-‘C’. “Kusuma opened the door to their flat using a duplicate key around 6.30 pm. “His wife and father-in-law found him hanging from the bedroom ceiling fan by a cloth”. Annexure-‘E-1’.
“The dots probably connected around 6.30 pm when his wife and her parents walked into their ninth-floor 2BHK apartment in the residential complex. Ravi was found hanging from the ceiling fan in one of the bedrooms by an orange saree with a black border”. Annexure- ‘A-1’. “TV Channels broke the news of Ravi’s death around 6.45pm”. Annexure- ‘A-3’. Note: Undoubtedly the first entrants into the apartment/scene of occurrence of death were Mr.Ravi’s wife and her father. They opened the door using a duplicate key. No forceful opening of the door. Not a single mention anywhere of Mr.Ravi’s driver accompanying them into the flat(first entry). The driver who was waiting there itself for his boss to come out since morning.
If Mr.Ravi was not murdered BUT committed suicide,
Did he leave a Death Note?
4.Bangalore police commissioner MN Reddi said a dog squad and a forensic team have been deployed. They will look into several aspects before reaching any conclusion. “As things stand, it appears to be a suicide. I cannot say anything more as investigation is still on,” Reddy told reporters outside the apartment. No death note was found. Annexure-‘C-1’. “Police Commissioner M N Reddi said: “Prima facie, it looks like a case of suicide. Until the inquest is conducted, we cannot come to a conclusive understanding.” Annexure-‘E’. Note: Firstly-a death note will surely be left behind with specific names of those who have pushed a person like Mr.Ravi to a point of ending his own life, to teach them a lesson. Secondly-if it is a suicide a person would surely leave a death note to avoid unnecessary trouble/complications to unconnected people. The character and life of Mr.D.K.Ravi demonstrates that he has genuine Humane and Public Interest and more specifically as he is an educated and literate person. Giving Trouble to those who meddle with him is in his blood and for those he likes he is really caring.
If Mr.Ravi committed suicide and he left a Death Note,
Where is the Death Note?
5.The first visitor/s to enter the scene of crime of the death were Mr.D.K.Ravi’s wife and his father-in-law, without the driver who allegedly has been in the parking area since morning. When Kusuma Mr.Ravi’s wife and her father reach the apartment along with the driver or was he called in later? The locked door was opened with the duplicate keys in the possession of Mr.Ravi’s wife. The door was not bolted from inside and there was no Death Note.
The front page news in Deccan Chronicle on 20th Friday reveals alarming details of Mr.Ravi and his Family which needs attention, which are divided as:
FIRSTLY – “A course mate of the IAS officer, Rohini Sindhuri scotched speculation that they were in a relationship and shared with chief secretary Kaushik Mukherjee, the chilling call details, text messages and emails sent to her by Mr. Ravi before his death, Mrs. Sindhuri, now serving as the Chief Executive officer of Zilla Panchayat, Mandya, rushed to Bengaluru after she learnt of Mr. Ravi’s death and came clean in the light of reports that she was romantically linked with him.
She told the chief secretary how her course mate repeatedly pleaded with her to “cooperate” with him and to end her marriage to her husband, a software engineer turned realty entrepreneur”.
Mr. Ravi called her several times on Monday and threatened to take the extreme step if she did not “cooperate” with him, but Mrs. Sindhuri said she remained steadfast in her decision to not break up her marriage.
During her meeting with the chief secretary, she also offered to cooperate with police officers during the probe into Mr.Ravi’s death, according to official sources. (Annexure- F-1)
SECONDLY: Sources said this case of a one-sided love affair gone wrong had its impact on Mr.Ravi’s marital life after his wife Kusuma learnt of it, resulting in frequent arguments.
At one point, Kusuma and her well-connected kin reportedly threatened the IAS officer that they would file a complaint of dowry harassment against him, a move which could have besmirched his record as an officer of integrity who dared to take on the rich and the powerful involved in illegal sand mining and evasion of taxes while executing real estate projects. (Annexure- F-2)
THIRDLY: On his part, Mr.Ravi was also upset that Kusuma had not revealed her own past – she had reportedly eloped and secretly married her beau while in college.
Perhaps, the prospect of facing the ignominy of being charged with dowry harassment, coupled with his course mate’s resolute rejection of his advances escalated levels of stress, sources said. (Annexure- F-3)
The Next day the Publication claims to stand by its earlier report of 20th March 2015 (Annexure- G)
If Mr.Ravi committed suicide, what are reasons that could have definitely led to his commission of the act?
If it was a Suicide it could have possibly been possible for THREE reasons.
a.According to the News Report Mr.Ravi’s personal one sided emotional attraction/relationship to/with another I.A.S lady batch mate, could have driven him to commit suicide. A person being strong in Public Life can be weak in Personal/Emotional situations, nothing unusual.
b.According to the News Report his wife and his father-in-law had threatened him of publicly maligning and destroying his image, by filing a complaint of dowry harassment against him, a move which could have besmirched his record as an officer of integrity. Being a bold & upright officer, who’s held in high esteem and seen as a person with high integrity in Public Life, the fear of facing public humiliation and disgrace, could have led him to decide that it would be better to die, than live after being publicly disgraced by his own wife, this is not at all unusual. Everyone would agree that the very MEDIA which has HAILED him and his character would have ASSAILED and literally Assassinated him on the basis of his wife’s false and fabricated story/allegation of Dowry Harassment. If it’s a choice between Truth and TRP the media would have gone for TRP. Even in that case the Media would have gone Hammer and tong against him for at least three continues days competing with each other. Because in India whatever is told by a women is considered as gospel truth.
If Mr.Ravi had left a Death Note, whose names should have been in the Death Note?
If the Death Note was there, being a strong person in Public Life, while dying he wouldn’t have spared the ones who pushed him to take such an extreme step. This is not just a possibility but sure behavior requirement, which would definitely have been done, given the I WILL NEVER LOOSE or BOW DOWN before anyone attitude he possessed. He would have won even in his death.
1.If this report is true, the Death Note would not have the names of the Publicly known enemies of Mr.Ravi, mentioned earlier herein above. For the daring personality that Mr.D.K.Ravi was he wouldn’t hang himself out of fear, he would rather have gone after them even more rigorously, to teach them a lesson which was his nature.
2.The name and details of A course mate the IAS officer, to whom calls were made, text messages and emails sent by Mr. Ravi before his death.
3.The name of his wife Kusuma and her well-connected kin who reportedly threatened the IAS officer that they would file a complaint of dowry harassment against him.
If the Death Note was removed, who could have removed it, AND who would benefit by removing it?
1.The Death Note could have been removed, (if removed) only by Mr.Ravi’s wife and father-in-law. They are the ONLY ones who entered the room first where M.Ravi was found hanging.
2.Just for argument sake, if the names of the Publicly known enemies of Mr.Ravi was mentioned in it, they (wife & Father-in-law) would have been very happy to allow the police to find or make it public.
3.If they have seen the death note, with the name and details of the lady course mate of the IAS officer was mentioned in it, they (wife & Father-in-law) would have been happy to give to the police and make it public.
4.BUT, if they had seen their own names (wife & Father-in-law) also in the Death Note, would they have allowed it to be seen by the police or the public?
It is ONLY Mr.Ravi’s wife Smt.Kusuma and her father Mr.Hanumantharayappa who would have benefited by destroying or removing the Death Note.
The probable conclusions that can be arrived at are:
1.It could not be a Murder, because he was found dead in his apartment at a time when he was supposed to be in his office.
2.For argument sake, if Mr.Ravi was made to come home, it could have been only by his wife or relative, who could lovingly or threatened or demanded of him to come home, because of some emergency/blackmail OR asked him to go to the flat for something on the same lines. No doubt so she should know the murderers, even if it is not her.
3.If it is a Suicide, it could have been for the reasons (a), (b) or (c) as stated herein above.
In any case the Investigating agency has to proceed to initiate proceedings against Mr.Ravi’s wife Smt.Kusuma Residing flat (Number 903, E Bloch) on the ninth floor of Prestige St.Johns Wood Apartment on Tavarekere Main Road and her father Mr.Hanumantharayappa residing at Mallathahalli in Nagarabhavi, Under Section 306 and 201 of the Indian Penal Code.
Kindly note that:
(1) In the first case viz. Poonam Chand Jain and another vs. Fazru, AIR 2010 SC 659, the Division Bench of the Apex Court has held that:
After dismissal of first complaint on merits, the second complaint, on almost identical facts, can be entertained only in exceptional circumstances.
An order of dismissal of first complaint under Section 203 is, however, no bar to the entertainment of a second complaint on the same facts but it can be entertained only in exceptional circumstances viz.
78. In Mahesh Chand’s case reported in (2003) 1 SCC 734 and Ranvir Singh’s case reported in (2009) 9 SCC 642, the Hon’ble Supreme Court of India has held that it is settled law that there is no statutory bar in filing a second complaint on the same set of facts. In Mahesh Chand’s case, in paragraph No.19 the Apex Court has held that;
“… In a case where a previous complaint is dismissed without assigning any reasons, the Magistrate under Sec. 204 Cr.P.C. may take cognizance of an offence and issue process if there is sufficient ground for proceeding. As held in Pramatha Nath Taluqdar’s case (1962) Supp.2 SC R 297 second complaint could be dismissed after a decision has been given against the complainant in previous matter upon a full consideration of his case. Further, second complaint on the same facts could be entertained only in exceptional circumstances, namely, where the previous order was passed on an incomplete record or on a misunderstanding of the nature of complaint or it was manifestly absurd, unjust or where new facts which could not, with reasonable diligence, have been brought on record in the previous proceedings, have been adduced.”
The decision in Smt.Nagawwa vs. Veeranna Shivalingappa Konjalgi and Others reported in (1976) 3 SCC 736 and Balraj Khanna and others v. Moti Ram reported in 1971 (3) SCC 399, the Apex Court has explained the scope and applications of Section 202 and 203 of Cr.P.C. In Smt.Nagawwa’s case it is held that;
“The scope of the inquiry under Section 202 of Code of Criminal Procedure is extremely limited, only to the ascertainment of the truth or falsehood of the allegations made in the complaint.-
(i) on the materials placed by the complainant before the Court;
(ii) for the limited purpose of finding out whether a prima facie case for issue of process has been made out; and
(iii) for deciding the question purely from the point of view of the complainant without at all adverting to any defence that the accused may have.
Wherefore it is requested of you to kindly receive my Apparently Conclusive Complaint and register an F.I.R to proceed legally against Mr.Ravi’s wife Smt.Kusuma Residing flat (Number 903, E Block) on the ninth floor of Prestige St.Johns Wood Apartment on Tavarekere Main Road and her father Mr.Hanumantharayappa residing at Mallathahalli in Nagarabhavi, Under Section 306 and 201 of the Indian Penal Code.
