Kee Pharma fir against Braja Sundar Pradhan

1. FIRST INFORMATION (Under Section 154 Cr.P.C.) REPORT CIPA-R1.1100 Crime & ECO OMIC OFFENCES 1. District: Railway PS.: WING Year: 20 I5FIRNo.: Date: 10-02-2015 1 7 Act(s): (i) IPC 1860 (Ii) Section(s): 406/4201120B 2. (iii) (iv) Occurrence of Offence: {a)-Day:--Satur day 3. Date To: 10-02-2015 Date From: 07-04-2007 Time To: Time: 14:30 hrs Time: 14:30 hrs Time From: Date: 10-02-20 15 Entry No.: 6A Time Period: (b) Information received at P.S: (c)General Diary Reference: 4. WRITTEN Type of Information: Place of Occurrence: 5. Beat No.: (a)Direction and Distance from P.S: (b) Address: NOT KNOWN, NOT KNOWN (c)In case, Outside the limit of the Police Station: District: Nameof P.S: Complainant/Informant: (a)Name: ANIL MOTIHAR 6. MANAGING DIRECTOR INDIA (b) Date/Year of Birth: Nationality: (c)Passport No. Date of Issue: Place of Issue: (d) Occupation: (e)Address: MIS KEE PHARMA LTD.A- 1, COMMUNITY CENTRE, NARAINA IN"1)lj"STRIAL AREA PH Details of Known/Suspect/Unknown (i) DR BRAJA SUNDER PRADHAN (RIO) (ii) MRS RASHMI PRADHAN (RIO) (iii) accused with full particulars(attach separate sheet if necessary): (2) 7. 8. 9. NO DELAY Reason for delay in reporting Particulars of the properties stolen/involved(attach SLNo. Property Type(Descrlption) by the complainantlinformant: separate sheet if necessary): Est. Value(Rs.) Status (i) (ii) (ili) 10 . Toial value of property stolen: 11 . Inquest Report/U.D Case No., if any: -- 1 -- ,

2. P.5.: ECONOMIC WING OFFENCES Date: 10-02- 2015 Crime & District: Railway Year: 2015 FIR No.: I 7 12 . F.I.R Contents(aUach separate sheet,lf required): To, The Commissioner Braja Sunder the Managing registered Area Phase -I New Delhi 110028, India (in short Kee Pharma). We deal in Pharmaceutical and Diagnostic mis-representation, mis-appropriation, cy~na_ breac of trust, forgery, _=- --==:---- --.:..:;: =~::::-c::-:. t: -J_. 3::::-a-a _~s. ~s~~ ?raOhan and his associates national/international) have cheated us of amounts about Rs. 7.50 crores. Facts detailed sinister and insidious modus operendi. a scientist by profession. We met him, in or around February-March 2007, and he introduced himself as the Managing Helvetica Industries Pvt. Ltd. (in short Helvetica). confidence and represented to'us that he was a scientist and was researching and developing preparation of drugs and chemicals value. He was short of funds and wanted Company. We were misled by his representations this process we have been been induced crores (including eapito~, "bans and amounts paid business of Helvetica) in M/s Helvetica a period of time. e now find that we have been cheated by Dr. ?::::-a~, .. "0 nas been si g our •oney and our laboratory =a ~~~=~es ~- a="er co ~e-~on of research pa-:.e::..-:. a ~ca=~ons':' s oi name and not in the name of the "·;_-=-c.:: -~e 0 __ ezs ip of the patents =~s ~s ~e o~:: =rom ~s o' written ::s.-'-e a__yenena ~at he "as surreptitiously ~as c~~desti e~y retained its consideration c02Cea~eQ vita~ ~_=ormat':'onw~th respect _,: s C3Z C"emica s Ltd, England, a pharmaceutical ·ncorporated in Essex, England (in short CBZ). There undeniable conflict of interest which was deliberately dishonestly withheld from us. There is material shares of CBZ are held in a tax haven abroad with each of the three alphabets of CBZ being the first letter of its three colluding partners, namely Chris, Braja and Zac. For theoretical expositionl they have used the eminence Ti_..! ..! ~ .•.•.. _c •....L._ ..!_ -r-r __ "l __ ...:::I of Police, Delhi and his associates of M/s Kee pharma Ltd. which has its office at A- 1, Community Sub:- Complaint Sir, The undersigned against Dr. Pradhan Director is Centre, Naraina Industrial Products. fraud, embezzlement, interpolation :.:::.caY" ?radhan (both known/unknown Through cheating, and money and his wife and in excess of disclose Sundar Pradhan hereinafter Dr. Braja the is Director of M/s He gained our of repute for patentable which had great commercial us to invest in his and claims and In to part with aboQt Rs 7.50 processes to promote Pvt. Ltd. over the Industries and testing, filing rightly belong. available sold the patents amount. He has to his association company t; ••.• >J~c--.:., admissions with and with is an and to establish that of an academic 1.... in a .•......•.1 c ..: -- 2--

3. District:Crime & Railway P.S.:ECONOMIC OFFENCES WING Year:2015 FIR No.:20150017 Date:l0 LUL L~::;~clLCll, UILLV~L::;.1.Ly expertise another in England money process, e-.-e:: az;::::-s ~J' ass~~:' :::0' =:IT. caz, records in 2010 was transferred baen transferred money was paid by Dr. Pradhan for the land through s ro g possibi_'ty ar- 0= 'e pro=it C3Z =or .e process and Dr. Pradhan CBZ. Similarly, 2010 assigning his own name in which has not been assigned though CBZ and Helvetica application was filed by either CBZ or Helvetica till the year 2008. We have reasons development work was done in Helvetica fund that were given by Kee Pharm~ to Helvetica period, for research projects Instead it has benefited Dr. Pradhan and CBZ is also established instances, which would be established investigations:- (i) Developing Derivatives for the preparation CBZ in order to sell the same and generate country; b. make a process Compounds and assign them to CBZ in order to sell the same and generate revenues outside the country. lab of their own, they would not be able to establish research took place. Also since Dr Pradhan was the full time Managing Director of Helvetica he could not have undertaken the scie?tific filing of the patent in any other Laborat.o r'yother than Helvetica. II. In collusion with CBZ and using Helvetica the process for Pregabalin, invested in Helvetica by Kee Pharma. Existence where the research has taken place and data has been collected a pre-requisite. In this case, the initial part ~'Thi rh Wrl~ T1()t- nrlt-I"'T1t-l"'n hv t-hl"'m hrl~ .1.11 .C.11\d.1.CU1U, use of facilities and the financial shelter in a tax haven Investigations 0- o_~y Kee Pharma and Helvetica -;"'e gO--~"::;:e.!'!t 0= =ndia has been defrauded = --.;.-:'es, ?yadLaL t.at reveal that. land sold by Helvetica by CBZ to Dr. Pradhan without to CBZ by way of UL L~1JUL~ ~X1J~L.1.lll~11Lcl.1. in India through expertise of the third based in Guernsey will establish that in the have been cheated, but of substantial =ees and taxes. Despite e had no fiduciary and clandestine conspirator taking dering. Island for la categorical relations to CBZ in Gujarat ever having of CBZ_and '.0. r with BQard ResGlution for the same. CBZ had paid Helvetica remittance in foreign exchange. t at this land may have been given d e to Dr Pradhan from the money sold to Kee Pharma. A patent for Atorvastatin in 2008 assigning a patent was filed by CBZ and Dr. Pradhan the same to CBZ . Dr. Pradhan has filed a patent nG - There to him, as a received was filed by CBZ the same to is a by in Oct in to any company. 2000, no patent or Dr. Pradhan to believe that all the clandestinely, during for the benefit of the investors. only the co-conspirators. from the following through technology to: a., make Furanose of Atorvastatin revenues for the synthesis Even were formed around using the entire the Complicity of scientific and assign outside of Silylferrocene them to the Since they do not have any where the and till date continues to be so, led to the work which it as a front company, developed to sell using of a laboratory funds is of the technology 'T'hl'" rl"'rl~()T1 hl"'l"'T1 n ~'Thv t-hi.c:: ~()1 -- 3--

4. District:Crime & Railway P.S.:ECONOMIC OFFENCES WING Year:2015 FIR No.:20150017 Date:l0 ..z •......•..•...•...•....• .............. technology have been difficult out since they did not have any laboratory also be that the initial information was generated practices because it seems that one of the stakeholder Technician in one of the labs in the Chemistry University in England (probably the initial design work have been developed using the students studying under him). patented in his own name and without r cess for e preparation of r-(-)-3- _ ........•........•........... _ sold to Helvetica was not patented to show where the lab work had been carried 1::'---- --.ioJJ •••••••••.•. -.." ••••••••••••••••••• iooJ __ •••••• -_................ .•••• ••••••- was because ••••• - •••••••. __ •••••••••••••• it would of their own. It could through unfair is the Head in a Department (iii) He has to Helvetica (Carbamoylmethyl)-5- e--e::" e assigning a __=---=..-=--::'c:===-=.:.. = .-=.:..:: =..::.::' =e ~:::::~ee..:.a:CE:s ~~:::g ~e =~6s ~nvesced by Kee Pharma in Helvetica investment. He has done this inspite of the Board having decided in the initial stages of research and so the research should not be carried material to establish that it was this very process which Dr. Pradhan had claimed unviable and hence he was not pursuing This process is an alternative process suspect that Dr. Pradhan has sold technology Pregabalin. This could have been done either directly another company and its consideration retai oed by him. (v) He has patented assigning to Helvetica a process Pregabalin using Mandelic Acid as a resolving Helvetica using the funds invest-ed by Kee pharma in Helvetica loans/ investment. On being asked during a board meeting November 2012 how he had filed the patent ::2::e :.c::o' '::"edoe and concurrence of the Board, he reluctantly -~- ~eC ::2::e 3o~d at even though he had filed it by himself, he ~~ =~::"e- ::2::e a_9::"~ca ion and assigned ~~~5e~:: S~- a copy 0= tee application :~5~:--e:::::eed ··-~~c· remai_s X awaited till date despite repeated ~e:=.::::,~s everi t.aouq_ ore t an two months have elapsed. This es=~=-:"s:::es :_2.Scr .nal i cent. es=ab:~s~-~a -echnolog~esfor Ethambutol ... '~~ ca a or; 0= :ad 0 be abandoned in 2009 due to Dr. Pradhan conveying Board that he was not able to proceed because he was unable to solve some issues, may have been further developed laboratory using funds received from Kee pharma. This could have been similarly sold or patented by him through another company and its consideration/benefit has been unauthorisedly I he circumstances, we would request you to kindly register a case, investigate the matter ,?-"nd take appropriate :Jr.Braja Sundar Pradhan and his'accomplices.If a so approach the University and the Serious Frauds Office in UK - as loans/ Belvetica that the process was not viable forward. There is it. (iv) We of to make Pregabalin. for preparation or through has been unauthorisedly in his own name and without for the 'Resolution agent' developed of Racemic in as on 8th in his own name without the same to Helvetica. and a copy of the He (vi) There is material and Pyrazinamide to on 0 ey has been invested and work had been done but to the in the retained by him. action against required, we could -- 4--

5. District:Crime & Railway P.S.:ECONOMIC OFFENCES WING Year:2015 FIR No.:20150017 Date:l0 for initiating co conspirators. Kee Pharma Director, From the contents prima facie a case u/s 406/420/120B case and hand over the investigation directions of the senior officers. 07.04.2007 onwards. Time of rukka :- 10.02.15 Chandra No. D-2982 police station-At _ _ •• .,....,........ -a- 1'"6900020 See-II EOW came in the police above mentioned complaint registered and original to Insp. Deepak Chandra further investigation. through DAK. SI/DO. appropriate Sd/- English Helvetica of the complaint proceedings ( Anil Motihar) Industries and enquiry IPC is made out. Register of the case to me, as per the Date and Time of offence Place of occurrence :- Not known. at 2.30PM Sd/- English PIS NO 16900020 Sec-II EOW. Action this time Insp. Deepak Chandra "-10 _ • •. _ •.••••.•• station for registration rukka along with copy of FIR handed No. D-2982 PIS NO 16900020 Copy of FIR will be sent to Senior against Dr. Pradhan Managing Pvt. Ltd.Do. conducted and his Director, P.S. EOW, so far a :- Date and Insp. Deepak taken at No. D-2982 L ,~., and produced of case. Case has been PIS NO the _ --- ----- over Sec-II EOW for officer 13 . Action Taken(Since the above information reveals commission of offence(s)u/s as mentioned at item No.2: (i) Registered the case and took up the investigation OR (ii) Dlrected(Name of the 1.0): DEEPAK CHANDRA Rank: INS to take up the investigation, OR No.: 16900020 (iii) Refused investigation due to: OR (iv) Transferred to P.S(name): District: on point of jurisdiction. F.I.R read over to the complainant/informant, complainantlinformant, admitted to be correctly recorded and a copy given to the free of cost: R.O.A.C: 14 . Signature I Thumb Impression Signature of Officer Name: MOHAN , Rank: SI ~vht SINGH 1 1~0.: of The Complainant/lnformant: • 28760518 Dl IT,( 'JFFICER PC'tice Station Economic New Oelhi - 1 CT\f- t t1' ~ 15 . Date and Time of despatch to the court: Offences Wing ( C-- . ~ -- 5--