Friday, August 27, 2021

WHAT’S WRONG WITH HEERA GROUP’S COMPLIANCE REPORT | ANALYSIS OF THE 160-PAGES FOURTH AFFIDAVIT ALONG WITH EARLIER SUBMISSIONS

I – The Fourth Affidavit’s Title
II – The Index Section
III – Fifteen Pages Proving Settlement of 1300 Investors, Gold
IV – Forty Four Pages of Bank Statements, No Documents to Correlate.
V – Six Pages of Bank Statements (RTGS), No Documents to Correlate.
VI – Third Affidavit, 13 Pages of Settlement Letters.
VII – The Maths, 78 documents versus the claim to have settled 7000.
VIII – Compliance Summary

I - Title:  The title given to the Compliance Report - Fourth Affidavit of Compliance, is to suggest that the earlier three affidavits have proof of compliance in them as well.  Heera Group had deposited 6 crores, visited Kukatpally PS, etc, but with regards to paying/settling its investors, there is no proof submitted, no compliance in either of the earlier three affidavits.

II - Index:  The index section has 20 different types of documents submitted, out of which only three points mention some kind of proof of payment/compliance towards settlement of investors' dues (Index No. 4, 7, and 8).  Index No. 1 is the Affidavit describing compliance.  Index No. 2, 3, 5, and 6 are court orders and transaction documents that are necessary to establish context of the Affidavit describing compliance.  The remaining Index No. 9 to 20 are about some land and properties that the company expects the Supreme Court to handover to them.

III - Index No. 4 - Annexure P-3 | Page 33 to 47 | True Copy of Unit Purchase Receipts of Gold/Item showing physical transfer of gold/items by Petitioners to Investors dated from 29.1.2021 to 23.4.2021

Issues with Index No. 4:  Only 15 pages only, Page 33 to 47 | Despite the claim of having returned investments/settled 1300 investors in the form of gold, only 8 investors' name have been mentioned and only 15 documents provided, out of which three investors' documents are fabricated, mentioned below:

Page 33 & 34:
- Retail Invoice - Ayesha Zaheer
- Unit Purchase Receipt - Ayesha Zaheer
Signatures of investor does not match.

Page 35 & 36
- Retail Invoice - Shaik Afrin
- Unit Purchase Receipt - Shaik Afrin
Signatures of investor does not match.

Page 37 & 38:
- Retail Invoice - Syed Ayesha
- Unit Purchase Receipt - Syed Ayesha
Signatures of investor does not match.  Signature of Syed Ayesha on page 37 is same as signature of Shaik Afrin in page 35.

IV - Index No. 7 - Annexure P-6 | Page 52 to 95 | True Copy of the Bank Statement of Petitioners dated nil showing the payment of amount to Complainants through RTGS

Issues with Index No. 7:  Forty four pages of Bank Statements (Page 52 to 95) have no supporting documents that can be tallied with.  How would one know who the payment has been made to?  The correct way would have been establish identity and proof of investment and relate it to the transaction the investor has been paid through in the statement of account submitted.

V - Index No. 8 - Annexure P-7 | Page 96 to 101 | True Copy of the Bank Statement of Petitioner and copy of Cheques dated 20.6.2021 showing the payment of amount to Complainants through RTGS.

Issues in Index No. 8:  Only 6 pages of copies of cheques and bank statements with no supporting documents, similar to Annexure P-6, does not establish payment made to complainant.

VI - Third Affidavit (May 3, 2021) Analysis 

In her third affidavit submitted to the Supreme Court of India, Heera Group claims to have settled more than 2500 noncomplainants via the help of data retrieved by GoDaddy (Point No 15), as well as paying more than 1300 investors in the form of gold (Point No. 16).

Issues in Third Affidavit:  In support of these claims, Heera Group has annexed only 13 pages (Page No. 66 to Page No. 78), showing bank statement of accounts and copies of settlement letters that they claim to have supposedly paid to non-complainants to establish their claims of having paid 2500 noncomplainants and 1300 investors via bank transfers, cash, or gold.  These settlement letters have no original signatures or contact numbers of investors and neither do they have bank statements to prove genuineness.

Whatever they have submitted in the third affidavit as proof of payment is inconclusive and insufficient for any kind of verification by any authority/department.

VII – Number of documents submitted as proof of payment/settlement to investors

Third Affidavit:  (Page No. 66 to Page No. 78) – Index No. 6, 7, and 8:*  13 pages containing Settlement Letters and Bank Statements

Fourth Affidavit (Compliance Report):
*(Page No. 33 to Page No. 47) – Index No. 4:*  15 pages titled physical transfer of Gold by petitioner.
*(Page No. 52 to Page No. 95) – Index No. 7:*  44 pages titled bank statement of petitioner – No other documents to tally with.
*(Page No. 96 to Page No. 101) – Index No. 8:*  6 pages titled bank statement of petitioner and copy of cheques.

 A total of only 78 documents submitted as proof of payment of which the majority consists of unrelating bank statements against the petitioner’s claims of having settled more than 7000 investors through RTGS, bank transfers, cheques, and in the form of physical gold in “Page No. 9, Point No. 13” and Page No. 19, Point No. 20” of the Fourth Affidavit/Compliance report submitted on June 30, 2021.

VIII – Summary of Compliance, Third and Fourth Affidavits

The number of interventions filed post completion of the first 6 weeks of the interim bail granted by this court is a result of investors feeling insecure and wanting this court to know that the company has not complied with its January 19, 2021, order to pay/settle all complainants.

Given the way the company has been conducting itself for long, especially more recently, we no longer have faith in the company and have serious concerns of contempt of court and misappropriation of funds by the company in exchange for the trust bestowed upon it by the Hon’ble Apex court.

Investors believe that the company claiming to have settled/paid thousands of unknown entities is nothing but an attempt to find ways to siphon off the money secured by the investigating agencies of their respective states.


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Who is Nowhera Shaikh? Is Heera Gold real or fake? Nowhera Shaikh is a self-proclaimed Islamic Scholar who addresses herself as a doctor and is responsible for the luring more than 1,72,000 Muslims to invest in her Ponzi schemes floated under the banner Heera Gold.  There have been more than 30 FIRs registered against her and the promoters of Heera Gold, and authorities investigating her cases have stated her business modules to be on the lines of Ponzi.  She has spent more than 2 years in jail and is currently out on Interim Bail and the Supreme Court of India has ordered her to settle all dues or face jail again.  As of December 2021.

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