Delhi- A formal complaint has been filed with the Station House Officer of Greater Kailash-1 police station in New Delhi seeking registration of an FIR against several unknown persons claiming to be YouTubers, journalists and content creators, as well as named individuals, for criminal house-trespass, criminal intimidation, defamation, invasion of privacy and related offences under the Bharatiya Nyaya Sanhita, 2023. The complaint, dated 5 August, has been submitted on behalf of CJP spokesperson Saurav Das, a resident of Greater Kailash-I who is currently not in Delhi. It states that Das has authorised his counsel to file the complaint and has also conveyed the same to the police on WhatsApp.
According to the complaint, over the past several days and continuing till the date of filing, various unknown persons have repeatedly assembled outside Das’s residential premises and unlawfully entered the house without any authority, permission or consent. These individuals are alleged to have deliberately trespassed into the residence and continuously recorded videos and photographs, extensively zooming into the interiors, the entrance and the surrounding areas, with the intention of publishing the material on social media platforms to generate sensational content.
The complaint further states that the same persons illegally questioned and interrogated the caretaker and security personnel at the residence, as well as neighbouring residents and passers-by in the locality, about Das’s personal life, residence, finances and other private affairs. Such conduct, the complaint says, constitutes a deliberate invasion of the private affairs of the complainant and his family members. It emphasises that a residential house is the most sacrosanct space in which every citizen is entitled to privacy, dignity and security, and that the unlawful intrusion and recording of interiors amount to a gross violation of these rights.
The complaint specifically invokes Section 329 of the Bharatiya Nyaya Sanhita, which criminalises house-trespass committed with the intention to intimidate, insult or annoy the person in possession of the property. It notes that several individuals operating through platforms including X and Instagram, particularly the handles @Pamphlet_in and @Jaipur Dialogues, have been actively circulating and disclosing Das’s complete residential address, thereby encouraging members of the public to visit the premises. This circulation, the complaint alleges, has directly facilitated and instigated the repeated unlawful trespass.
Links to specific videos posted by @Pamphlet_in have been enclosed with the complaint, along with a Google Drive folder containing the same videos.
The complaint names Abhijit Iyer Mitra as one individual who has repeatedly and publicly disclosed Das’s residential address on social media, thereby drawing public attention to the residence and materially contributing to the continued invasion of privacy and interference with peaceful possession of the premises. It further states that Deepak Sharma, a YouTuber associated with the handle @Pamphlet_in, has himself featured in videos uploaded on that handle in which he is seen entering the premises and recording and publishing material on social media.
The publication and dissemination of these videos, the complaint argues, has exposed the exact residential address, layout and security arrangements of the house to the public at large, creating a grave and imminent threat to the safety and security of Das, his family members and the premises. There exists a genuine apprehension, it says, that anti-social elements or other miscreants may misuse this information to target the residence, endangering life and property.
Several of the videos are also alleged to contain false, malicious and baseless statements concerning Das’s financial capacity, insinuating that he possesses unexplained resources and seeking to associate him with suspicious and unknown sources of income despite the absence of any supporting material. These statements, according to the complaint, have been made only to sensationalise the matter and to lower Das’s reputation in the estimation of society, exposing him to public hatred, ridicule and contempt. Such conduct, it states, prima facie constitutes the offence of defamation under Section 356 of the Bharatiya Nyaya Sanhita.
The complaint describes the acts as forming part of a coordinated and sustained campaign carried out across multiple social media platforms with the common intention of invading Das’s privacy, subjecting him to public ridicule, exposing his residence to the public and causing continuous harassment and intimidation. It asserts that the acts collectively disclose offences under the Bharatiya Nyaya Sanhita including house-trespass under Section 329, criminal intimidation under Section 351 and defamation under Section 356, besides offences of criminal conspiracy and acts done in furtherance of common intention, and such other offences as may be disclosed during investigation.
The complaint warns that unless immediate intervention is undertaken by the police, there is every likelihood that these unlawful acts will continue, causing further irreparable prejudice to the safety, privacy and reputation of Das and his family members. It therefore requests the registration of an FIR against the above-named persons and all other unknown persons involved under Sections 329, 351 and 356 of the Bharatiya Nyaya Sanhita and all other applicable provisions of law, and further seeks immediate steps to prevent the continuance of the acts and to secure the safety and security of the complainant, his family members and the residential premises.
The complaint has been filed through advocates Ayush Shrivastava, Krishnesh Bapat and Samyak Gangwal of Atarya Partners, counsel for Saurav Das.