Background Information
The Siri Singh Sahib was the Chief Religious and Administrative Authority of Sikh Dharma of the Western
Hemisphere. In that capacity he oversaw the whole network of non‐profit and for profit corporations which
make up what will be referred to below as the Sikh Dharma community(not because Sikh Dharma owns or
controls all of them, but as a convenient shorthand from the Siri Singh Sahib’s lifetime when all these
organizations were referred to as “the Dharma.”). An organizational chart of the structure in early 2003 is
attached as Attachment 1.
When the Siri Singh Sahib planned the structure that would exist after his passing, he created a number of new
organizations and modified some existing organizations. The most significant change was made in May, 2003
when the Siri Singh Sahib created Unto Infinity, LLC (“UI”) (an Oregon Limited Liability Company) to serve as
the Chief Administrative Authority and he vested the Chief Religious Authority in the Siri Sikdar Sahiba and the
Bhai Sahiba of Sikh Dharma International (“SDI”).
The Board of Directors of UI (“UIB”) initially consisted of a Panj of five people and now is comprised of the
following four individuals, Kartar Singh Khalsa, Sopurkh Kaur Khalsa, Peraim Kaur Khalsa and Siri Karm Kaur
Khalsa.
When UI was initially formed, it became the Member of SDI (essentially the “owner” of SDI), and as such
played a governance role with respect to SDI’s Board of Directors. UI also became the Member of most of the
other organizations created by the Siri Singh Sahib. However, UI was not formed as the uppermost
organization in the structure. Above UI the Siri Singh Sahib placed the Siri Singh Sahib Corporation (“SSSC”) (an
Oregon non‐profit religious corporation) he had created in 1997. The SSSC is the Member of UI (essentially the
“owner” of UI). An organizational chart of the structure in 2003 after the creation of UI is attached as
Attachment 2.
The Siri Singh Sahib planned that, upon his death, the SSSC would have a board that included the UIB members
as well as the Siri Sikdar Sahiba and the Bhai Sahiba of SDI, and other devout members of the community. This
way, the ultimate parent entity (and thus the whole community) would be governed by a balanced body that
combined the Chief Administrative Authority and the Chief Religious Authority together – the way the Siri
Singh Sahib had been before his passing. However, it is believed that the UIB members manipulated the early
formation of the SSSC board shortly after the Siri Singh Sahib’s death, so that they became the only board
members of SSSC. In this way, the check and balance the Siri Singh Sahib had established over UI was
eliminated.
Over the past five years, the UI has created more corporations, changing the structure the Siri Singh Sahib
established. Most recently, in January 2009, the UIB formed a new entity, Sikh Dharma Stewardship, LLC
(“SDS”) (an Oregon Limited Liability Company), and appointed a five member Board of Directors. UI is the
Member of SDS (essentially the “owner” of SDS) and as such plays an oversight and approval role regarding
actions taken by SDS. The UI delegated to SDS, as a management committee of UI, the responsibility of the
Chief Administrative Authority of SDI and its Affiliates, SDEI and SikhNet, although UI is still SDI’s legal Member
of record. An organizational chart of the current structure in 2009 is attached as Attachment 3.
In April, 2009, the four UIB members wrote a letter to the Khalsa Council disclosing that they are no longer
practicing the Sikh teachings and lifestyle taught by the Siri Singh Sahib. The Khalsa Council’s letter to the UIB
inviting them to attend the Khalsa Council meeting and UIB’s answer are included as Attachment 4. At the
April, 2009 Khalsa Council meetings (which the UIB declined to attend), in a Straw Poll (with the vote tally
certified by Amrit Kaur (of Alaska), SDI’s Chancellor), the Khalsa Council strongly expressed that Khalsa Sikhs
(those living in accordance with the Siri Singh Sahib’s teachings about Sikh Dharma) should be in the highest
leadership positions and a majority voted no confidence in the UIB and that they should resign. In the same
straw poll, the Council strongly voted that the SDS should be declared not valid and that its directors should
resign. The Straw Poll results are attached as Attachment 5.
Following the April, 2009 meetings, a grassroots group of Sangat members began looking into legal remedies
available for the fiduciary and other breaches that have caused harm to the community (that had come to light
in late 2008 and early 2009). Over the following months, the SDI Board brought serious governance concerns
to the attention of UI and in response was threatened with being removed. Also during that time, the SDI
Board learned of actions by the UIB that appeared to breach their fiduciary duties to the Sikh Dharma
community (including for example, that Kartar Singh’s annual compensation increased from about $127,000 in
2002 to over $850,000 in 2008). A fiduciary is someone in whom faith and trust has been placed to act on
behalf of another. The UIB has fiduciary duties to the Sikh Dharma community it oversees. One of the most
important fiduciary duties is that the directors of UI (the UIB) must act in the best interest of the organizations,
not for the directors’ personal interest or on the directors’ own behalf. As discussed below, the four current
members of the UIB have harmed the Sikh Dharma community by breaching their fiduciary duties, among
other legal wrongs, and thus must be removed.
The Complaint Summary
I. Introduction:
A Complaint is a document filed in court to start a legal action between two or more parties. A Complaint sets
forth the basic facts and legal reasons that the persons filing the Complaint (the Plaintiffs) believe are sufficient
to entitle them to a court order against the opposing persons (the Defendants). The Defendants will file an
Answer to the Complaint, where they will admit or deny each of the statements made in the Complaint.1 The
statements (allegations) in the Complaint are made “on information and belief” which means the Plaintiffs
think the statements are true but do not necessarily have the documents or other evidence to prove the truth
of the statements at the time of filing the Complaint. Part of the lawsuit process is “Discovery” where each
side asks the other for documents and answers to questions in order to determine whether the statements in
the Complaint are true or not. The Complaint can be amended to add or delete claims against the Defendants,
if necessary, as Discovery proceeds and more information is gathered.
On September 21, 2009, Sikh Dharma International (“SDI”) filed a Complaint in the Oregon Circuit Court in
Portland, Oregon, against the four individual members of UI basically asking the court to remove them and to
order them to repay the monies that they have wrongfully taken from the Sikh Dharma community. There are
six individual Plaintiffs named in the Complaint. Five Plaintiffs are members of the SDI Board of Directors: MSS
Sardarni Guru Amrit Kaur Khalsa, SS Avtar Hari Singh Khalsa and MSS Hari Dharam Kaur Khalsa (all of
Española), MSS Guru Raj Kaur Khalsa (of Vancouver, Canada), and SS Guru Sangat Kaur Khalsa (of Belo
Horizonte, Brazil)) and the sixth Plaintiff is SS Gurutej Singh Khalsa (of Española), the founder of Akal Security
(who is filing as an individual). The SDI Board filed the Complaint on behalf of themselves individually, on
behalf of SDI and on behalf of all members of the Sikh Dharma community (defined in the Complaint to include
all of the for‐profit and nonprofit entities inspired and nurtured by the Siri Singh Sahib). The Defendants are
the four individual current members of the UIB: Kartar Singh Khalsa, Sopurkh Kaur Khalsa, Peraim Kaur Khalsa,
and Siri Karm Kaur Khalsa. The three corporations they control are also named: Unto Infinity, LLC (“UI), Sikh
Dharma Stewardship, LLC (“SDS”), and the Siri Singh Sahib Corporation (“SSSC”) are nominal defendants, since
these are the entities which the Defendants are acting through. The five individual members of the SDS are not Defendants.
Before that, we anticipate that the Defendants will file motions asking the court to dismiss the Complaint,
which we believe the court will deny.
Structure of the Complaint:
The Complaint is 69 pages long, plus another 77 pages of Exhibits. The first 38 pages (paragraphs 1‐82) set out
the basic facts as currently understood by the Plaintiffs; these are subject to change as Discovery reveals more
information.
Pages 39 and 40 (paragraphs 83‐88) allege that there is a class of persons in the Sikh Dharma community who
have been injured by the Defendants’ actions. Later in the litigation, there will be a process for the court to
determine whether there should be such a class and if so, who is in the class. At that time, individual Sikh
Dharma community members will be given the option to be excluded from the class. The Plaintiffs’ attorneys
will notify all potential members of the class when the time comes.
Pages 41 and 42 (paragraphs 89‐92) contain allegations that the Defendants engaged in a conspiracy to
mislead the Siri Singh Sahib and the Sikh Dharma community and to benefit personally from monies from the
businesses which were intended to benefit the Sikh Dharma community as a whole. Under Oregon law, there
is a conspiracy even if only one Defendant knew that he or she was engaging in the wrongful act as long as the
others agree to participate in that act.
The next section of the Complaint contains the Claims for Relief. This is where the Plaintiffs tell the Court the
specific legal theories for relief that are being asserted against the Defendants. Pages 43‐67 (paragraphs 93‐
166) set out nine (9) claims for relief against the Defendants which are discussed in the next section. Page 67
also contains a demand for a Jury Trial on all the claims in the Complaint.
The last two pages of the Complaint contain the Prayer for Relief, that is, what the Plaintiffs are asking the
Court to order. The Prayer for Relief is set out in full in section IV below.
The Complaint is signed by the Plaintiffs’ attorney and by Sardarni Guru Amrit Kaur who verifies (confirms) that
the Complaint is accurate based on her knowledge, information, and belief.
III. Allegations in Complaint and Claims for Relief
The Complaint alleges that the Defendants have increased their salaries and otherwise diverted assets and
funds that should have been used for the benefit of the entire Sikh Dharma community. The Plaintiffs allege
that: “For example, on information and belief, Defendant Kartar Singh Khalsa has grossly inflated his total
compensation (in rounded numbers) from approximately $127,000 in 2002, to $155,000 in 2004, to $250,000
in 2005, to $300,000 in 2006, to $484,000 in 2007, to $871,000 in 2008.”
During the same time that they were increasing their salaries, the Defendants (1) cut funding to the non‐
profits, and orchestrated extensive layoffs in 2006 and did not provide sufficient funds to fully fund the non‐
profit needs (2008 grant requests exceeded the funds made available by the UIB), (2) removed the Siri Singh
Sahib’s image and quotes from Golden Temple products, cutting off the royalties intended for his family and
long time staff members, (3) dismantled the Amsterdam community, resulting in financial losses, (4)
transferred assets that were held in trust for SDI to other entities that UIB controls, and (5) altered legal
documents relating to some of the corporations in order to carry out their plans.
These actions are part of the basis for six of the nine Claims for Relief: breach of fiduciary duty, breach of
contract, breach of covenant of good faith and fair dealing, conversion (taking property that belongs to
another), tortious interference (with the plan the Siri Singh Sahib set up), and unjust enrichment. Not knowing
the exact amount of damages to the Sikh Dharma community and the exact amount that the Defendants have
been unjustly enriched, the Complaint alleges that the amount is at least $2 million.
The Complaint also alleges that at least Defendant Peraim Kaur Khalsa knew that she was no longer a Sikh prior
to the Siri Singh Sahib’s death, but that she represented to him that she was so that he did not remove her
from the UIB and other corporate boards prior to his death. As discussed above, because she knew she was
misleading the Siri Singh Sahib, and because all of the Defendants are co‐conspirators with her, her actions are
binding on the other three. These actions, namely, the representation that the Defendants were devout Sikhs
when they were not in order to obtain or retain positions of power and authority, is the basis for two of the
nine Claims for Relief: fraud(an intentional deception made for personal gain) and negligent misrepresentation
(a careless misstatement that the other person reasonably relies on).
The final Claim for Relief asks the Court to create a Constructive Trust for the property and funds the
Defendants wrongfully took from the Sikh Dharma community. A constructive trust is a legal device to require
the Defendants to return property that they have wrongfully taken or which would cause them to be unjustly
enriched and then oversee the return of those funds to the rightful owners in the Sikh Dharma community.
Mukhtiarsingh's Blog 