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the 400 pages dossier needs to be reviewed to advice you in this case
Subject:Engagement Inquiry — Multi-Track Civil & Criminal Matter I, **Hiren Dilipbhai Gandhi** (DOB 5 July 1970; PAN ABEPG4987F), of 1470 New Madhupura, Ahmedabad — 380 004, write to inquire about your availability to be engaged in a complex matter in which I am the affected party. I am a Class-I heir of my late grandfather **Shri Babubhai Manilal Gandhi** (intestate) and my late father **Shri Dilipbhai Babubhai Gandhi** (deceased 22 March 2026). I am the Founder Director and Secretary of the InGlobal Business Foundation (IBF). I seek concurrent representation across six reliefs: 1. **Partition** of the ancestral immovable and movable estate, including gold, silver and bank-locker contents of the late grandfather; 2. **Breach of trust and cheating under the notarised MOU dated 17 August 2000** — civil enforcement of contractual indemnity (approximately Rs. 4 crore expended on MMCB-related litigation) and criminal action under BNS §§ 316 and 318 against the indemnitors; 3. **Criminal prosecution** for forgery, conspiracy and cheating against named accused; 4. **Defamation — civil and criminal** — against Shri Biren D. Gandhi, the Madhavpura Market Co-Op Society and Madhavpura Mercantile Co-operative Bank Ltd.; 5. **Recovery of possession of Shop E/8**, Madhavpura Market; 6. **Hathising Vadi Trust** — 41E application under the Gujarat Public Trusts Act, 1950. A **398-page Legal Dossier** with documentary annexures is available for your review under a signed engagement letter. I would welcome an initial consultation at your earliest convenience. Yours faithfully, **Hiren Dilipbhai Gandhi** +[deleted] · [deleted] Note on the MOU clause.** I have framed Relief 2 with both prongs — civil enforcement of the contractual indemnity (recovery of the ~Rs. 4 crore you spent over 17 years on MMCB litigation, which the indemnitors were contractually bound to bear) and the criminal charges (BNS § 316 criminal breach of trust and § 318 cheating). This signals to the advocate that the MOU is not just background to the family fraud — it is a stand-alone enforceable instrument with its own civil and criminal teeth, which is exactly what it is.
You can contact any lawyer on this website for consultation
the 400 pages dossier needs to be reviewed to advice you in this case
Your query is spread out to various subjects, i.e.civil and criminal topics,
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LEGAL ISSUES — SUMMARY **1. Criminal** Quashing of FIR 266/2004 (Madhavpura P.S.) *qua* the Client — minor on the impugned 1987 document; State Home Ministry directive of 17.12.2005 already records this. Prosecution of forgery, cheating, criminal breach of trust, and conspiracy against named family, Society, bank and corporate accused. **BNS, 2023 §§ 316, 318, 336, 338, 340, 61, 3(5); § 528 BNSS quashing in the Hon'ble Gujarat High Court.** **2. MoU Breach (Notarised MoU dated 17 August 2000)** Family indemnitors undertook to bear all MMCB-related claims at their cost. Breach: Client has expended ~Rs. 4 crore over 17 years. Civil enforcement of indemnity + criminal action (BNS §§ 316, 318). **3. Fake / Forged Signatures** Q1–Q5 forged signatures on Own Merchant Shroff Pvt. Ltd. corporate filings (marked by Examiner J.J. Patel, 14.06.2010) against the Client's ten notarised specimens (S-1 to S-10) of 26.05.2010. Suspected forgeries on the alleged Will of the late grandfather and on the Shop E/8 transfer documents. Forensic examination by Truth Labs / FSL Gandhinagar. **4. Property Rights** (i) 19 Navyug Society bungalow, Ambawadi; (ii) 1470 New Madhupura; (iii) Survey 8/48, Dariyapur–Kazipura; (iv) **Shop E/8, Madhavpura Market — recovery of possession under § 96 GCS Act, 1961** against the Society and Laxmi Alloys Pvt Ltd; (v) Hathising Vadi Trust — § 41E GPT Act, 1950 application; (vi) **movable estate of late Shri Babubhai Manilal Gandhi — gold, silver, bank-locker contents; Order 38 R. 5 CPC attachment.** **5. Family Partition** Class-I heir of (i) late grandfather Shri Babubhai Manilal Gandhi (intestate) and (ii) late father Shri Dilipbhai Babubhai Gandhi (d. 22.03.2026). Partition Suit + Caveat under § 148A ISA, 1925 + Order 39 injunction. Hindu Succession Act, 1956 § 8 read with Class-I Schedu
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SERIOUS CRIMINAL OFFENCES — BULLET POINTS **Forgery of valuable security** — Q1 to Q5 signatures on statutory corporate filings of Own Merchant Shroff Pvt. Ltd. (Annual Returns, Balance Sheet, Directors' Report) — marked by Examiner of Questioned Documents Shri J.J. Patel, 14 June 2010. **BNS § 338 / IPC § 467 — up to life imprisonment.** - **Fabrication of a Will** — alleged forged Will of late Shri Babubhai Manilal Gandhi propounded in favour of Smt. Swetal Biren Gandhi. **BNS § 338 / IPC § 467.** - **Forged Vakalatnamas** in proceedings 506, 522 and 527 of 2000 — proceedings disposed of without the Client's knowledge. **BNS §§ 336, 338, 340 / IPC §§ 463, 467, 471.** - **Cheating and false induction of a minor as "partner"** — Ganesh Chemicals Pedhi document dated 23 June 1987 used to obtain MMCB credit; Client was aged 16 yrs 11 months 18 days. **BNS § 318 / IPC § 420 — up to 7 years' imprisonment.** - **Criminal breach of trust under the notarised MoU of 17 August 2000** — family indemnitors retained the ancestral properties and passed the entire 17-year MMCB litigation burden (~Rs. 4 crore) onto the Client. **BNS § 316 / IPC §§ 405–409 — up to 7 years (or life if as a trustee).** - **Criminal conspiracy and common intention** — sustained concert of action across family, Society office-bearers, Laxmi Alloys Pvt Ltd directors, MMCB officials and Hathising Vadi trustees. **BNS §§ 61 and 3(5) / IPC §§ 120-B and 34.** - **Criminal trespass and dispossession of Shop E/8**, Madhavpura Market — wrongful induction of Laxmi Alloys Pvt Ltd into the Client's allotted premises without a registered conveyance. **BNS § 329 / IPC §§ 441, 447.** - **Criminal intimidation and midnight expulsion** — Client expelled from 19 Navyug Society in August 2000 with wife and infant son. **BNS § 351 / IPC § 506.** - **Defamation — false public imputations** through FIR 266/2004
Quashing is to be done only in exceptional circumstances
if allegations made in FIR disclose commission of offence HC is reluctant to quash FIR