KHAITAN mera oe &CO “Soa 790 00 na Advocates since 191 19133 240 7000 Our Ref.» RR 16 January 2015, To The Secretary Hon'ble Chief Justice High court, Original Side, Calcutta Dear Sir, Re. : CANo.139 of 2013, CANo.491 of 2012 CP No.33 of 1988 In the High Court at Calcutta Hungerford Investment Trust Lt. Vs. ur Clients: Turner Morrison & Co. Lt, ‘This is to bring to your kind notice and to be placed before the Hon’ble Chief Justice with regard to an order dated 18" January, 2015 passed by the Hon'ble Justice Anirudcha Bose to seek clarification for assignment of three purported Company Applications being CA 1No.10 of 2015, C.A No.11 of 2015 and C.A No.12 of 2015 in connection with C.P No,33 of 41988 (since dismissed) taken out by way of three purported Judges’ Summons by one Mr Deepak Khosla, Advocate acting as a purported Advacate-on-Record in the Original side Jurisdiction of this Hon'ble Court for Hungerford Investment Trust Ltd., in view of the ‘objections raised by the Counsel appearing on behalf of Turner Morrison & Co. Ltd. The Counsels appearing on behalf of Turner Morrison & Co. Lid. raised objections on several grounds including not having jurisdiction on the ground of determination to hear the said purported company apalications and the purported power of Mr. Deepak Khosla to practice land act as an Advocate-on-Record in the Original side jurisciction of this Hon'ble High Court. ‘The said Mr. Khosla, Advocate is not even a resident of Kolkata, but is being allowed to act in the Original Side of this Hon’ble Court in total derogation of the Original Side Rules of this Hon'ble Court. So long as the said Mr. Khosla has not registered himself with the Registrar, Original Side of this Court he cannot file any vakaltnama nor can he be allowed to file ary application or any form of pleading In the Company Department of this Hon'ble Court Further, the address cited by him of Alipore is also outside the territorial jurisciction of this Hon'ble CourtKHAITAN &CO Advocates since 1911 ‘The main Company Petition being C.P No.33 of 1988 has been dismissed by an order dated June 21, 2007. However, Mr. Hoon the applicant through his Advocate the said Mr. Khosla is being allowed to file applications in the said dismissed company petition and to argue for more than a year. To substantiate the aforesaid objections we need to bring out the following facts before the Hon’ble Chief Justice 1) The main Company Petition being CP No.33 of 1988 filed by Hungerford Investment Trust Limited under Section 397 and 398 of the Companies Act, 1956 was dismissed by ‘an order dated June 22, 2007 passed by the Hon'ble Justice Jayanta Kumar Biswas, 2) The said order dated June 21, 2007 was upheld by the Hon’ble Division Bench by the order dated August 22, 2008 passed by the Hon‘ble Justice Amit Talukdar sitting with the Hon'ble Justice Prabhuddha Sankar Banerjee in an appeal filed by the Hungerford Investment Trust Ltd 3) The said Hungerford investment Trust Limited filed a Review Petition on July 2, 2009 ‘agzinst the order dated August 22, 2008 passed by the Hon'ble Division Bench. The said Review Petition is still pending before the Hon'ble Division Bench and now is due to be heard by the Hon'ble Justice Banerjee siting with the Hon’ble Justice Samapti Chatterjee on 5" of February, 2015. 4) In the meantime the said Mr. Nirmalieet Singh Hoon had also filed a Contempt application against the Hon'ble Justice Jayanta Kumar Biswas, the sitting Judge of this Hon'ble Court for passing an order dated June 21, 2007 and also against the Hon'ble Justice Kalyan Jyoti Sengupta sitting with the Hon'ble Justice A. K. Bhattacharjee for passing several orders against the said Hungerford Investment Trust Limite 5) The said contempt petition being C.C No. 227 of 2007 was ultimately heard and disposed of by an order dated August 22, 2008 passed by the Hon'ble Justice Amit Talukdar sitting with the Hon’ble Justice Prabhuddha Sankar Banerjee. 6) In view thereof there is no original proceeding is pending before the Company Court as fn date and therefor no Company Application can be taken out in connection with the said C.P No.33 of 1988. After the said C. P. No. 33 of 1988 was dismissed and the same ‘was upheld by the Hon'ble Division Court and also after filing the Revision Petition, Mr. Hoon tried to file several other applications in connection with C. P. No. 33 of 1988 whichKHAITAN &CO Advocates since 1911 were moved before the regular Company Court and were released on the ground that Judges were not willing to take up matters initiated by Mr. Hoon on behalf of Hungerford Investment Trust Limited, In view of the above the then Hon'ble Chief Justice vide an ‘administrative order dated January 6, 2012 assigned all the matters which were pening in respect of Hungerford Investment Trust Limited and/or in connection to Mr. Hoon to the Hon'ble Justice Aniruddha Bose, 7) However, Hungerford Investment Trust through the said Mr. Hoon took out an application in 2032 being C.A No.49I of 2012 in the dismissed company petition. 8) The said assignment was only in respect of the matters which were pending before the Hon'ble Court as on that date of assignment only. 9) Inspite of the aforesaid Mr. Nirmaljeet Singh Hoon appearing in person, showed no authority and/or any resolution from the said Hungerford Investment Trust Ltd, filed @ Company Application being C.A No.491 of 2012 affirmed on June 30, 2012. 10) The said C.A No.491 of 2012 was moved on July 17, 2012 before the Hon'ble Justice Aniruddha Bose. An order was passed on the instant date despite objections being raises about the maintainability of the said Company Application. 11) Thereafter the said matter was assigned to a number of Judges of this Hon'ble Court from time to time but however, the said Hon’ble Judges owing to the unruly and malicious behavior of Mr, Nirmaljeet Singh Hoon were compelled to release the said matter. 12) The said Mr. Nirmaljeet Singh Hoon inspite of several directions from the Hon’ble Court has failed to produce his authority to appear for and on behalf of Hungerford Investment Trust Limited purportedly claiming himself to be Chairman of the said Hungerford Investment Trust limited 13) tis pertinent to mention that Hungerford Investment Trust Limited is under voluntary liquidation wherein the said Mr. Nirmaljeet Singh Hoon is acting as the liquidator of the Hungerford Investment Trust Limited. fo”KHAITAN &CO Advocates since 1911 114) However, the Hon’ble Justice Aniruddha Bose inspite of all the objections taken for and on behalf of Turner Morrison & Co. Ltd, has continued to allow Mr. Nirmaljeet Singh Hoon to argue in person for more than 39 days and also indulged him in Judge bashing of all the present and past Judges of this Hon’ble Court including the Hon'ble retired Judges retired of the Hon‘ble Supreme Court of India and those who have passed orders against Hungerford Investment Trust Limited, Further, while arguing the said Mr. Hoon has shown no respect to the Senior Counsel appearing for Turner Morrison & Co. Ltd 15) In view of the above, we are compelled to bring on record all the aforesaid acts ane Unruly misbehaviour of Mr. Nirmaljeet Singh Hoon who was earlier appearing in person fon behalf of Hungerford Investment Trust Limited. Left with no option, our client had taken out an application on March 13, 2013 being C. No.139 of 2013 seeking dismissal ‘of the said company application being C.A No.491 of 2012. 116) However, inspite of several hearings and earnest prayers being made for and on behalf ‘of Turner Morrison & Co. Ltd, the said Company application being C.A No.491 of 201? is yet to be disposed of by the Hon'ble Justice Aniruddha Bose. 17) tis also to place on record that a letter dated 1" March 2013 which was addressed by four client Turner Mocriosn Ltd, to The secretary, Hon'ble Chief Justice seeking larifiation whether any proceeding arising out of CP 33 of 1988 can be entertained by Justice Aniruddha Bose particularly when CP 33 of 1988 was dismissed by both trial court and appeal court. A copy of such letter dated 1” March 3013 is enclosed 118) Sometime after May, 2013 Mr. Hoon disappeared from this Hon'ble Court and had not prayed for any hearing of the said application being C.A No.491 of 2012 19) On or about 12 December, 2014 Mr. Hoon again appeared before this Hon'ble court and mentioned the matter in the Court of the Hon'ble Justice Aniruddha Bose for listing, fof CA No.491 of 2012 along with CA No.139 of 2013. This time Mr. Hoon was represented by the said Mr. Khosla Advocate who is also purporting to act as an advocate on record on the Original Side of this Hon'ble Court. This would appear from a copy of the order dated December 12, 2014 passed by Hon'ble Justice Aniruddha Bose. 20) On or about 6" January, 2015 three purported Company Applications being C.A No.10 of, 2015, CA No.11 of 2015 and C.A No.12 of 2015 were served on the Advocate-on-Record (of Turner Morrison & Co. Ltd frKHAITAN &CO Advocates since 1911 21) From the said three applications, it would appear that one Mr. Deepak Khosla of No.1, Judges Court Road, Alipore, Kelkata-700027 which js also the residential address of Mr Nirmaljeet Singh Hoon situated outside the territorial jurisdiction of the Original Side of this Hon’ble Court, has been allowed to take out the aforesaid three applications by way of Judges’ Summons. 22) itis also pertinent to mention that the said Mr, Khosla is neither registered with State Bar Council of West Bengal nor is registered with the Registrar, Original Side of this Hon'ble High Court as per the Original Side Rules of this Court, 23) nspite of the aforesaid, he had been allowed to take out the purported Judges’ Summons by the company department and the same were also moved before the Hon'ble Justice Aniruddha Bose on January 9, 2015. When in course of the hearing ‘objection was taken by the Counsel appearing for Turner Morrison & Co. itd. regarding his capacity and authority to take out Judges’ Summons and act as an Advocate-on Record in the Original Side Jurisdiction of this Hon'ble Court, it was submitted by the said Mr. Khosla that although Judges’ Summons in connection to the said Company Applications were taken out by him, but M/s. L. P. Mannot & Co. Advocates 's acting as ‘an Advocate-on-Record for Hungerford Investment Trust Limited. Upon hearing the Hon'ble Justice Aniruddha Bose directed Mrs. Manju Agarwal who was present in the Court to file a valid Vakalatnama of M/s. L. P. Mannot & Co. for and on behalf of Hungerford investment Trust Limited. However, we understand that till date Mr. Deepak Khosla and/or Mrs. Manju Agarwal has failed and/or neglected to file and/or produce such Vakalatnama in the matter. 24) In view of the above, it appears that Mr. Khosla is practicing fraud on this Hon'ble Court by misrepresenting himself to be an Advocate on Record registered on the Original Side of this Hon’ble Court 25) In course of moving the purported applications, Mr. Khosla has been abusing the sitting Judges of this Hon’ble Court including few of the Judges who have retired as well as the Judges of the Hon'ble Supreme Court of India including the Counsels, Advocate on Record appearing on behalf of Turner Morrison & Co. Lt 26) During the Course of the hearing Mr. Khosla also abused all the Judges who, according to him, passed orders by allegedly receiving gratification and/or who have been given sexval favour by Turner Morrison & Co. Ltd. and has also abused one of the Judges who had heard matters filed by Hungerford Investment Trust Limited by saying that he was fooKHAITAN &CO Advocates since 1911 6 beaten up by Mr. Hoon in his early days and he took all glory and pride in making such submissions before the Hon'ble Court. He has also abused the Senior Advocate Mr. Utoa Bose who is appearing on behalf of Turner Morison & Co. Lid. and has also threatened to file proceedings to have the Bar Library Club, High Court Calcutta scrapped and is continuing to abuse the entire members of the Bar of the Calcutta High Court. He has also threatened Advocate on Record as well as other Counsels of Turner Morrison & Co Ltd. to meet them outside the Court as he would meet a dacott or a thief outside the Court implying that he can even physically abuse the Counsels and Advocates of Turner Morrison & Co, The way Mr. Khosla has conducted himself before the Court it is absolutely obnoxious, abusive, malicious and vexatious as such remarks are directed ‘against all the sitting and retired Judges of this Court as well. 27) Despite best efforts the Counsel appearing on behalf of Turner Morrison & Co, Ltd. have been unable to control/prevent Mr. Deepak Khosla from misbehaving, abusing and calling the Hon'ble Judges by their first names. Even the Hon'ble Justice Aniruddha Bose has been unable to control the said Mr. Khosla, Advocate and was allowed to make such submissions on 9", 13", 14°” as well as 15" January, 2015, 28) However when strong objection was raised by the Counsel appesring on behalf of Turner Morrison & Co. Ltd. regarding the jurisdiction of this Hon'ble court on the ground of not having determination to hear the purported company applications without the same being assigned before the Hon’ble Justice Aniruddha Bose, His Lordship was pleased to pass the order on 15" January, 2015 seeking clarification with regard to the assignment of the said purported Company Applications being C.A No.10 of 2015, C.A No.1 of 2015 and C.A No.12 of 2035, 29) tis also pertinent to mention that the said Mr. Deepak Khosla who got himself recentiy enrolled with the Bar Council of Karnataka on July 30, 2023 at the age of 54 years has been debarred from appearing by the Hon'ble High Court of Delhi vide an order dated January 13, 2015 passed by the Hon’ble Justice Sanjeev Sachdeva [CONT. CAS (C ) 165/ 2008 (MONTREAUX RESORTS P. LTD & ORS -VS- SONIA KHOSLA & ORS)} for his unruly, ‘malicious and abusing behavior. A Newspaper clipping published in Times of India, Delhi edition dated January 15, 2015 was also placed before the Hon’ble Justice Aniruddha Bose on 15" January, 2015. Thereafter a copy of the order dated January 13, 2015 has been obtained by Turner Morrison & Co. Ltd. A copy of the Newspaper Clipoing and copy of the order dated January 13, 2015 are enclosed herewith for your ready reference to ‘enable you to take steps for deciding the assignment of this matter. f~*KHAITAN &CO Advocates since 1911 view of the above, we pray before the Hon‘ble Chief Justice that before assigning the said purported applications: ’ 1 possible to call upon a report from Registrar (Company) Original side in respect the leave which was given to the said Mr. Deepak Khosia the purported Advocate- onRecord of Hungerford Investment Trust Limited to take out three Judges Summons in support of the said purported Company applications being C.A No.10 of 2015; CA No.11 of 2015 and C.ANo.12 of 2035 contrary to the Original Side Rules of this Court ji) Her Ladyship may if it deems fit, also call upon for a report from Registrar (Listing) Original Side High Court, Calcutta that inspite of violation of Original Side Rules as to how and why numbers were allotted to the said purported Company Applications, ‘asthe Mr. Khosla is not registered with the Registrar, Original Side nor resides or has his office within the territorial jurisdiction of this Court, ii] Her Ladyship if It deems ft, may also give us a personal hearing to elaborate on the objections raised before deciding the assignment of the said purported Company Applications, iv) May also call upon for an investigation into the conduct and authority of Mr. Khosla It to act as an Advocate-on-Record in the Original Side Jurisdiction of this Hon'ble Court and also to represent and/or appear before the Court. is also most humbly prayed that Your Ladyship, the Hon’ble Chief Justice would consider four objections to such abusing, malicious, vexatious and derogatory conduct of Mr Ni gi irmaljaet Singh Hoon and His Advocate Mr. Deepak Khosla who are in a habit of showing Isrespect to Hor’ble Judges, Courts of law and should not be permitted to behave in such manner before this Hon'ble Court. The dignity and majesty of this institution has to be protected, Yo urs faithfully For KHAITAN & CO fo (Ratnesh ke. Rat) Advocate Enclo. : As aboveKHAITAN &CO Advocates since 1911 Copy to on Original 1 ‘The Registrar Original Side, High Court Caleutta ‘The Registrar, Company Original Side, High Court caleutta ‘The Registrar (Listing) Original Side, High Court Caleutta The Secretary ar Council of india Near Bal Bhawan, New Delhi ~ 110002. The Secretary Bar Council of West Bengal 283,K.S. Roy Road City Civil Court Building 7° Floor, Kolkata ~ 700 001. The Secretary Bar Council of Karnataka Old K.G. 1D. Building Dr. Ambedkar Veedhi Bangalore ~ $60 001 ‘The Secretary Bar Council of Delhi Head Office at 2/6, Siri Fort institutional Area hel Gaon Marg, New Delhi ~ 49, And Branch Office at The Secretary Bar Council of Delhi LF, Lawyers Chamber High Court of Delhi Sher Shah Suri Road New Delhi -03. Mr. Jayanta Kumar Mitra Advocate General, Govt. of West Bengal High Cour, Calcutta.KHAITAN &CO Advocates since 1911 9. The Reghstrar High Court at Delhi, New Delhi. 10, Mr. Deepak Khosia Advocate 18, Judges Court Road Aipore, Kolkata - 7000027, {2+ ir tralieet Singh Hoon sivoomne 18, Judges Court Road ‘ipore, Kolkata 700 027 12, M/s. Turner Morrison & Co. Ut. 6, lyons Range, Kolkata-700 003, eae whe