Page 1 of 16 S.B. Civil Wril Petition No. 1 190/2'014 Trideep RRnj Bhandari u. Reserue Bonk ofl~rtlir: &J Om A/lnilio~~alA$dauit in S~ppnrt o/ Writ I-'e/iljo//

IN THE HIGH COURT OF JUDICATURE FOR RAJASTHAN

AT JODHPUR

S.B. CIVIL WRIT PETITION NO. 1190/2014 1

Petitioner:

Trideep Raj Bhandari

Respondents:

Reserve Bank of India & Ors.

1

ADDITIONAL AFFIDAVIT IN SUPPORT OF WRIT PETITION

I, Trideep Raj Bhandari s / o Shri Tribhuwan Raj Bhandari I

aged - years, resident of "Gulab Vaatika", Paota 'By Road,

Jodhpur do hereby state on oath as under:

1) That I am .the Petitioner in the present Writ Petition and

completely well versed with the facts and circumstances of

the present case.

2) That it is humbly submitted that this affidavit may be

considered supplemental to and in addition to the

averments, whether factual or legal, already set out in the

writ petition.

3) That this affidavit is being filed while reserving the liberty

to file a detailed rejoinder to the reply submitted by the

Reserve Bank of India.

4) That the present writ petition has been filed with the intent

of seeking pin pointed relief in terms of Chapter V of the

Reserve Bank of India Act, 1934 as also with the clear

Page 2 of 16 'S.B. Ciud Wrif Pefition No. 1.190/20 14 Ttineep Raj Bbandari v. Re~erue Bank o f I ~ d a & O ~ J . AdlitiotzalA$;daM'f in Supporf o f Wriic Petifion

averment that a financial scam of the magnitude of Rs.

1600 crore or more in a Non-Banking Financial Company

(hereinafter referred to as "NBFC") could not have taken

place without the involvement of the officials of supervising

regulator i.e. the Reserve Bank of India (hereinafter

referred to as "RBI") in the instant case. Accordingly, a a

supplementary prayer of affixing responsibility on the

responsible officers of RBI has been made.

5) That furthermore, it is also clear and apparent from the

contents of the writ petition read along with annexures

thereto that financial irregularities in M/s. First Leasing

Company of India Ltd. were going on for years together for

reasons of inter alia negligence/involvement of the

responsible officers of the Reserve Bank of India, only for

which reason could M / s . First Leasing Company of India

Ltd. project a rosy picture all,.over the country and allure

me and other shareholders "and depositors etc. into

purchasing its equity shares and otherwise invest in

deposits etc. of the Company, which has went on for years.

6) That at the very outset and without getting into the niceties

of this writ petition, it would suffice to mention that I am a

resident of Jodhpur (Rajasthan). I was allured into

purchasing equity shares of M/s. First Leasing Company of

India Ltd. by the false rosy picture projected by the said

company all over the internet (and other mass media

instruments like financial newspapers etc.) and in its

annual reports, credit rating reports etc., all of which were

available to be read over the internet at various places

including the company's own website

www.firstleasingindia.com as also websites of stock

exchanges etc. and other public domains. These shares

were purchased by me at Jodhpur (Rajasthan) through the i branch office of M/s. Mehta Equities Ltd. situated at 108,