In his complaint against Inder Mohan, XEN, provisional division, PWD (B&R), Faridkot, and the Chief Engineer, Punjab PWD branch, Patiala, Naresh Tayal, partner, Shanti Builders and Consultants, stated that the accused allotted him the work of construction of two storeys of Guru Gobind Singh College, Sadar Garg, Gidderbaha, and the same was undertaken by him.

He stated that he completed the work to the satisfaction of the accused and on account of part construction he submitted bills to the department. It was added that in discharge of the liability of payment, the XEN issued a cheque dated August 5, 1999, under his signatures. The cheque, he stated, amounted to about Rs 3.23 lakh drawn on the State Bank of Patiala, Faridkot, and this cheque was issued in payment of the bill passed on July 14 for work done up to January, 1999.

The complainant, however, alleged that despite assurances of encashment, the cheque was dishonoured on August 26 with remarks "payment stopped" and the memo to this effect was received by bankers of the complainant, namely State Bank of India. It was added that a notice dated September 2 was served upon him and also on Superintending Engineer, Faridkot. Later, a legal notice was served upon Mohan and Chief Secretary, Punjab. It was alleged that payment was still not made.