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Writ Petition Criminal diary no. 18546 of 2022 Part-II .pdf

Om Prakash Poddar
Om Prakash Poddar
Om Prakash PoddarUNEMPLOYED AT NEW DELHI DISMISSED UNDER WRIT CIVIL 90 OF 2016 BY SUPREME COURT OF INDIA at UNEMPLOYED

Register F.I.R against these five people to interrogate in this matter. Surender Narayan Poddar, Rajput advocate of Purnea Bihar, Advocate Gopal Prasad and his wife Veena Kumari Advocate Sunil Ojha is key person who will reveal all records of this sex racket to rescue my minor daughters. Register an F.I.R and interrogate Shri Surender Narayan Poddar Assitant Manager Marketing Division IOCL Barauni Refinery Begusarai Bihar, my advocate Shri Sunil Ojha in HMA-678/2010 case at Dwarka Court at New Delhi, my wife Rina Kumari’s advocate Shri Gopal Prasad and his wife Veena Kumari in 9P/2010 case at Begusarai Court Bihar and Rajput advocate of Purnea Bihar in HMA-678/2010 case Goshwara No. 83)H at Dwarka Court at New Delhi.

Writ Petition Criminal diary no. 18546 of 2022 Part-II .pdf

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1
IN THE SUPREME COURT OF INDIA
CRIMINAL ORIGINAL JURISDICTION
WRIT PETITION (CRIMINAL) D.NO.18546 OF 2022
Petition under Article 32 of the Constitution of India with
A Prayer to STOP persistent gang rapes, rescue &
rehabilitate the victims of illicit sex trade, hidden
prostitution, child prostitution and Enforcement of
Fundamental Rights.
IN THE MATTER OF:
OM PRAKASH …………..PETITIONER
VERSUS
UNION OF INDIA & ORS ….RESPONDENT
CRL. M.P. NO. OF 2022
APPLICATION FOR SEEKING PERMISSION TO APPEAR
AND ARGUE AS PETITIONER-IN-PERSON
PAPER BOOK
(FOR INDEX KINDLY SEE INSIDE)
PAGES FROM 01 TO 49
PETITIONER IN PERSON
OM PRAKASH
2
INDEX
S.N Particulars of the document Page No. of the
part to which it
belongs
Remarks
(i) (ii) (iii) (iv) (v)
1. Court Fees
2. Listing Proforma A-A2 A1
3. Cover Page of Paper Book A-2
4. Index of Record of Proceedings A-3
5. Defect List A-4
6. Note Sheet NS1-
7. List of Dates B-J
8. Writ Petition (Criminal) with
Affidavit
1-32
9. Annexure: P-1
True copy of the brief about the
grave situation of persistent gang
rapes and illicit sex trade through
affidavit no.4127/22 dated 8th
June,
2022 to Hon’ble Chief Justice of
India
33-37
10. Annexure: P-2
True copy of application for
appointment with Registrar of
Supreme Court of India dated
8.6.2022 for apprising the grave
situation of persistent gang rapes
and illicit sex trade of Petitioner
families through R&I counter no.
17 of Supreme Court of India
38-39
11. Annexure: P-3
True copy of police complaint
dated 9th
June, 2022 vide D.D.No.
23A at 12:26p.m. at Lahori Gate
Police Station Delhi-6
40-43
12. Application for seeking
permission to appear and argue the
Writ Petition (Criminal) in person
along with supporting affidavit.
44-50
13. Filing Index
14. Memo of Appearance
15. I.D.Proof of Delhi & Bihar
3
‘A’
No. F.5/Judl(I)/2018, dated: 29/10/2018
w.e.f. 29th October, 20183
ANNEXURE_ ‘X’
PROFORMA FOR FIRST LISTING
SECTION ____
The case pertains to (Please tick/check the correct box}:
√Central Act: (Title) INDIAN PENAL CODE
√Section: 154(1) and 157(1) Criminal
Procedure Code
Central Rule: (Title) N.A
Rule No(s} N.A
State Act: (Title) N.A
Section: N.A
State Rule: (Title) N.A
Rule No(s) N.A
Impugned Interim Order: (Date) N.A
Impugned Final Order/Decree: (Date) N.A
High Court: (Name) N.A
Names of Judges: N.A
Tribunal/Authority: (Name} N.A
1. Nature of matter: Civil √  Criminal
2. (a) Petitioner No. l : OM PRAKASH
(b) e-mail ID: om.poddar@gmail.com
(c) Mobile phone number: 9540389759
3. (a) Respondent No. l : UNION OF INDIA MINISTRY OF HOME
AFFAIRS
(b) e-mail ID: N.A
(c) Mobile phone number: N.A
4. (a) Main category classification: 1418 CRIMINAL MATTER-OTHERS
(b) Sub classification: N.A
5. Not to be listed before: All writs listed previously before Hon’ble Judges
not to be listed before them.
6. (a) Similar disposed of matter with citation, if any, & case details:
(i) Petition(s) for Special Leave to Appeal (Civil) No(s).9854/2012
entitled OM PRAKASH PODDAR VERSUS RINA KUMARI
dated 23.04.2012
(ii) Petition(s) for Special Leave to Appeal (Civil) No(s).9483/2013
entitled OM PRAKASH PODDAR VERSUS RINA KUMARI
dated 01.04.2013
(iii) Petition(s) for Special Leave to Appeal (Civil) No(s).19073/2013
entitled OM PRAKASH PODDAR VERSUS RINA KUMARI
dated 05.07.2013
4
(iv) Writ Petition(s)(Civil) No(s).90/2016 entitled OM PRAKASH
VERSUS INDIAN DRUGS AND PHARMACEUTICALS LTD
AND ORS dated 18.04.2016
(v) Writ Petition(s)(Criminal) No(s). 136/2016 entitled OM
PRAKASH & ANR VERSUS STATE OF BIHAR AND ORS
dated 21.10.2016
(vi) REVIEW PETITION (CRL.) NO. 825 OF 2016 IN WRIT
PETITION (CRL.) NO. 136 OF 2016 entitled OM PRAKASH &
ANR VERSUS STATE OF BIHAR AND ORS dated 01.12.2016
(vii) WRIT PETITION (CRL.) D.NO. 2188 of 2017 entitled OM
PRAKASH & ANR VERSUS UNION OF INDIA & ORS dated
28.01.2017
‘A1’
(viii) WRIT PETITION (CRL.) D.NO. 3913 of 2017 entitled OM
PRAKASH & ANR VERSUS REGISTRAR SUPREME COURT
OF INDIA AND ANR dated 16.02.2017
(ix) M.A. No(s). 84/2017 in WRIT PETITION(CRL.) D. NO.3913 OF
2017 entitled OM PRAKASH & ANR VERSUS REGISTRAR
SUPREME COURT OF INDIA AND ANR dated 14.07.2017
(x) CURATIVE PET(CRL.) D 41026 OF 2016 IN REVIEW
PETITION (CRL.) NO. 825 OF 2016 IN WRIT PETITION (CRL.)
NO. 136 OF 2016 entitled OM PRAKASH & ANR VERSUS
STATE OF BIHAR AND ORS dated 17.07.2017
(xi) Misc. Application D.NO. 22539 of 2018 in WRIT
PETITION(CRL.)D.NO. 2188 of 2017 entitled OM PRAKASH &
ANR VERSUS UNION OF INDIA & ORS dated 23.08.2018
(xii) M.A. NO. 2836 OF 2018 IN MISC. APPLN. D.NO. 22539 OF
2018 IN WRIT PETITION (CRL.) D.NO. 2188 OF 2017 entitled
OM PRAKASH & ANR VERSUS UNION OF INDIA & ORS
dated 07.12.2018
(xiii) Misc. Application D. No.42652/2019 in WRIT PETITION(CRL.)
No. 136/2016 entitled OM PRAKASH & ANR VERSUS STATE
OF BIHAR AND ORS dated 14.07.2020
(xiv) Miscellaneous Application No.1446/2020 in M.A.D
No.42652/2019 IN WRIT PETITION (CRL.) No. 136/2016
entitled OM PRAKASH & ANR VERSUS STATE OF BIHAR
AND ORS dated 14.09.2020
(xv) W.P.(Criminal)242/2021 entitled OM PRAKASH VS UNION OF
INDIA & ORS
(xvi) W.P.(Criminal)137/2021 entitled OM PRAKASH VS UNION OF
INDIA & ORS
(b) Similar pending matter with case details: NO
7. Criminal Matters:
(a) Whether accused/convict has su1rendered:  Yes √ No.
(b) FIR No. N.A Date: N.A
(c) Police Station: N.A
(d) Sentence Awarded: N.A
5
(e) Period of sentence undergone including period of detention/ custody
undergone:
N.A
8. Land Acquisition Matters:
(a) Date of Section 4 notification: N.A
(b) Date of Section 6 notification: N.A
(c) Da te of Section 17 notification: N.A
9. Tax Matters: State the tax effect: N.A
10. Special Category (first petitioner/appellant only): N.A
 Senior Citizen>65 years  SC/ST  woman/child  Disabled  Legal aid
case  in custody
11. Vehicle Number (in case of Motor Accident Claim matters): N.A
Petitioner-in-Person
(Name) OM PRAKASH
Registration No………………
Date: 14-06-2022
6
SYNOPSIS AND LIST OF DATES
The present Writ Petition under Article 32 of the
Constitution of India is being filed by a Social
Worker cum husband cum father cum Guardian cum
Whistle Blower cum Petitioner-In-Person; aggrieved
by the deliberate hiding out of his all near about 50
family members including his kidnapped pregnant
wife and his minor daughter by the sex
racketeers/sex abusers State and subsequently
aggrieved by the deliberate obstruction in making
payment of Rs. 431/- against e-filed fresh Writ
Petition Criminal dated 7th
June, 2022 after
dismissal of Writ Petition (Criminal) No. 136/2016,
Writ Petition (Criminal) No. 137/2021 and Writ
Petition (Criminal) No. 242/2021 by this Hon’ble
Court and deliberate inertia to stop persistent gang
rapes and illicit sex trade of petitioner families and
their minor girl child by the nexus of state, NGOs,
gangsters, Mafias, Indian defense organizations and
general public since 18 years to till date across the
globe and deliberate bystander apathy by state to
rescue and rehabilitate them enforcing their Rights
under Article 21 of the Constitution of India.
02.05.2022 Writ Petition (Crl) No. 137/2021 dismissed by
this Hon’ble Court and directed the Petitioner to
come according to the Law.

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Writ Petition Criminal diary no. 18546 of 2022 Part-II .pdf

  • 1. 1 IN THE SUPREME COURT OF INDIA CRIMINAL ORIGINAL JURISDICTION WRIT PETITION (CRIMINAL) D.NO.18546 OF 2022 Petition under Article 32 of the Constitution of India with A Prayer to STOP persistent gang rapes, rescue & rehabilitate the victims of illicit sex trade, hidden prostitution, child prostitution and Enforcement of Fundamental Rights. IN THE MATTER OF: OM PRAKASH …………..PETITIONER VERSUS UNION OF INDIA & ORS ….RESPONDENT CRL. M.P. NO. OF 2022 APPLICATION FOR SEEKING PERMISSION TO APPEAR AND ARGUE AS PETITIONER-IN-PERSON PAPER BOOK (FOR INDEX KINDLY SEE INSIDE) PAGES FROM 01 TO 49 PETITIONER IN PERSON OM PRAKASH
  • 2. 2 INDEX S.N Particulars of the document Page No. of the part to which it belongs Remarks (i) (ii) (iii) (iv) (v) 1. Court Fees 2. Listing Proforma A-A2 A1 3. Cover Page of Paper Book A-2 4. Index of Record of Proceedings A-3 5. Defect List A-4 6. Note Sheet NS1- 7. List of Dates B-J 8. Writ Petition (Criminal) with Affidavit 1-32 9. Annexure: P-1 True copy of the brief about the grave situation of persistent gang rapes and illicit sex trade through affidavit no.4127/22 dated 8th June, 2022 to Hon’ble Chief Justice of India 33-37 10. Annexure: P-2 True copy of application for appointment with Registrar of Supreme Court of India dated 8.6.2022 for apprising the grave situation of persistent gang rapes and illicit sex trade of Petitioner families through R&I counter no. 17 of Supreme Court of India 38-39 11. Annexure: P-3 True copy of police complaint dated 9th June, 2022 vide D.D.No. 23A at 12:26p.m. at Lahori Gate Police Station Delhi-6 40-43 12. Application for seeking permission to appear and argue the Writ Petition (Criminal) in person along with supporting affidavit. 44-50 13. Filing Index 14. Memo of Appearance 15. I.D.Proof of Delhi & Bihar
  • 3. 3 ‘A’ No. F.5/Judl(I)/2018, dated: 29/10/2018 w.e.f. 29th October, 20183 ANNEXURE_ ‘X’ PROFORMA FOR FIRST LISTING SECTION ____ The case pertains to (Please tick/check the correct box}: √Central Act: (Title) INDIAN PENAL CODE √Section: 154(1) and 157(1) Criminal Procedure Code Central Rule: (Title) N.A Rule No(s} N.A State Act: (Title) N.A Section: N.A State Rule: (Title) N.A Rule No(s) N.A Impugned Interim Order: (Date) N.A Impugned Final Order/Decree: (Date) N.A High Court: (Name) N.A Names of Judges: N.A Tribunal/Authority: (Name} N.A 1. Nature of matter: Civil √  Criminal 2. (a) Petitioner No. l : OM PRAKASH (b) e-mail ID: om.poddar@gmail.com (c) Mobile phone number: 9540389759 3. (a) Respondent No. l : UNION OF INDIA MINISTRY OF HOME AFFAIRS (b) e-mail ID: N.A (c) Mobile phone number: N.A 4. (a) Main category classification: 1418 CRIMINAL MATTER-OTHERS (b) Sub classification: N.A 5. Not to be listed before: All writs listed previously before Hon’ble Judges not to be listed before them. 6. (a) Similar disposed of matter with citation, if any, & case details: (i) Petition(s) for Special Leave to Appeal (Civil) No(s).9854/2012 entitled OM PRAKASH PODDAR VERSUS RINA KUMARI dated 23.04.2012 (ii) Petition(s) for Special Leave to Appeal (Civil) No(s).9483/2013 entitled OM PRAKASH PODDAR VERSUS RINA KUMARI dated 01.04.2013 (iii) Petition(s) for Special Leave to Appeal (Civil) No(s).19073/2013 entitled OM PRAKASH PODDAR VERSUS RINA KUMARI dated 05.07.2013
  • 4. 4 (iv) Writ Petition(s)(Civil) No(s).90/2016 entitled OM PRAKASH VERSUS INDIAN DRUGS AND PHARMACEUTICALS LTD AND ORS dated 18.04.2016 (v) Writ Petition(s)(Criminal) No(s). 136/2016 entitled OM PRAKASH & ANR VERSUS STATE OF BIHAR AND ORS dated 21.10.2016 (vi) REVIEW PETITION (CRL.) NO. 825 OF 2016 IN WRIT PETITION (CRL.) NO. 136 OF 2016 entitled OM PRAKASH & ANR VERSUS STATE OF BIHAR AND ORS dated 01.12.2016 (vii) WRIT PETITION (CRL.) D.NO. 2188 of 2017 entitled OM PRAKASH & ANR VERSUS UNION OF INDIA & ORS dated 28.01.2017 ‘A1’ (viii) WRIT PETITION (CRL.) D.NO. 3913 of 2017 entitled OM PRAKASH & ANR VERSUS REGISTRAR SUPREME COURT OF INDIA AND ANR dated 16.02.2017 (ix) M.A. No(s). 84/2017 in WRIT PETITION(CRL.) D. NO.3913 OF 2017 entitled OM PRAKASH & ANR VERSUS REGISTRAR SUPREME COURT OF INDIA AND ANR dated 14.07.2017 (x) CURATIVE PET(CRL.) D 41026 OF 2016 IN REVIEW PETITION (CRL.) NO. 825 OF 2016 IN WRIT PETITION (CRL.) NO. 136 OF 2016 entitled OM PRAKASH & ANR VERSUS STATE OF BIHAR AND ORS dated 17.07.2017 (xi) Misc. Application D.NO. 22539 of 2018 in WRIT PETITION(CRL.)D.NO. 2188 of 2017 entitled OM PRAKASH & ANR VERSUS UNION OF INDIA & ORS dated 23.08.2018 (xii) M.A. NO. 2836 OF 2018 IN MISC. APPLN. D.NO. 22539 OF 2018 IN WRIT PETITION (CRL.) D.NO. 2188 OF 2017 entitled OM PRAKASH & ANR VERSUS UNION OF INDIA & ORS dated 07.12.2018 (xiii) Misc. Application D. No.42652/2019 in WRIT PETITION(CRL.) No. 136/2016 entitled OM PRAKASH & ANR VERSUS STATE OF BIHAR AND ORS dated 14.07.2020 (xiv) Miscellaneous Application No.1446/2020 in M.A.D No.42652/2019 IN WRIT PETITION (CRL.) No. 136/2016 entitled OM PRAKASH & ANR VERSUS STATE OF BIHAR AND ORS dated 14.09.2020 (xv) W.P.(Criminal)242/2021 entitled OM PRAKASH VS UNION OF INDIA & ORS (xvi) W.P.(Criminal)137/2021 entitled OM PRAKASH VS UNION OF INDIA & ORS (b) Similar pending matter with case details: NO 7. Criminal Matters: (a) Whether accused/convict has su1rendered:  Yes √ No. (b) FIR No. N.A Date: N.A (c) Police Station: N.A (d) Sentence Awarded: N.A
  • 5. 5 (e) Period of sentence undergone including period of detention/ custody undergone: N.A 8. Land Acquisition Matters: (a) Date of Section 4 notification: N.A (b) Date of Section 6 notification: N.A (c) Da te of Section 17 notification: N.A 9. Tax Matters: State the tax effect: N.A 10. Special Category (first petitioner/appellant only): N.A  Senior Citizen>65 years  SC/ST  woman/child  Disabled  Legal aid case  in custody 11. Vehicle Number (in case of Motor Accident Claim matters): N.A Petitioner-in-Person (Name) OM PRAKASH Registration No……………… Date: 14-06-2022
  • 6. 6 SYNOPSIS AND LIST OF DATES The present Writ Petition under Article 32 of the Constitution of India is being filed by a Social Worker cum husband cum father cum Guardian cum Whistle Blower cum Petitioner-In-Person; aggrieved by the deliberate hiding out of his all near about 50 family members including his kidnapped pregnant wife and his minor daughter by the sex racketeers/sex abusers State and subsequently aggrieved by the deliberate obstruction in making payment of Rs. 431/- against e-filed fresh Writ Petition Criminal dated 7th June, 2022 after dismissal of Writ Petition (Criminal) No. 136/2016, Writ Petition (Criminal) No. 137/2021 and Writ Petition (Criminal) No. 242/2021 by this Hon’ble Court and deliberate inertia to stop persistent gang rapes and illicit sex trade of petitioner families and their minor girl child by the nexus of state, NGOs, gangsters, Mafias, Indian defense organizations and general public since 18 years to till date across the globe and deliberate bystander apathy by state to rescue and rehabilitate them enforcing their Rights under Article 21 of the Constitution of India. 02.05.2022 Writ Petition (Crl) No. 137/2021 dismissed by this Hon’ble Court and directed the Petitioner to come according to the Law.
  • 7. 7 05.05.2022 Victims of gang rapes, illicit sex trade and child sexual abuse rescued and departed by Mahananda Express from Old Delhi Railway Station to Katihar, Bihar but not being handed over to the petitioner rather re-pushed them into same business of flesh trade at the source point of human trafficking at Katihar Bihar and at the destination /transit point of Human Trafficking at Delhi/NCR. 17.05.2022 National Commission for Protection of Child Rights (NCPCR) accepted the case of victim minor daughter Shriya Poddar aged about 17 years and 50 others family members including minor girl child of petitioners family. 20.05.2022 SHO Kadwa Police Station Katihar, Bihar illegally detained Petitioner and gang raped the victims’ family inside his house at Sonaili Village along with Superintendent of Police Katihar and others. 07.06.2022 Laptop of petitioner is being damaged, password of Supreme Court e-filing hacked by the sex abusers state in Delhi. 08.06.2022 Gang Rapes and illicit sex trades of the victims identified inside the common toilet of Luxminarayan Dharamshala, Church Mission Road, P.S. Lahori Gate, Delhi-6. 112 call has been made with reference no. 5201138 and 5201158. Affidavit No. 4127/22 vide D.NO. 34979/22 dispatchedd through R&I to Hon’ble the Chief Justice of India and letter for
  • 8. 8 appointment with Registrar dispatched through R&I vide a diary no. 34978/2022 to Registrar of Supreme Court of India. 112 call has been made against biased police action at Luxmi Narayan Dharamshala, Church Mission Road, Police Station, Lahori Gate Delhi-6 against the victims of gang rapes and illicit sex trade vide reference no. 5206837. 09.06.2022 A written application vide D.D.No. 23A at 12:26p.m. has been filed with Police Station Lahori Gate Delhi-6. 112 call reference no. 5208740, 5208823, 5209010, 5209016, 5208990 and 5209461has been made against an attempt to mob lynch the petitioner, beating Petitioner with feast, evacuating Petitioner from Luxmi Narayan Dharamshala by Police and Dharamshala administration and illegal detention of petitioner taking his all belongings/items including mobile into the police custody by Police In charge Police post Church Mission Road Delhi-6 have done medical of petitioner from Aruna Asaf Ali Hospital, Delhi. 10.06.2022 112 call has been made against illegal detention of Petitioner for 24 hours inside the police post church mission road and gang rapes and illicit sex trade of victims inside police post in front of Petitioner’s own eyes. Police also invited Petitioner to participate in the gang rapes inside the AC rooms with all Luxary
  • 9. 9 at police post church mission road, Fatehpuri, Delhi-6 Thereafter police post Assistant Sub Inspector Ishwar Das Roy, Rajender Soni, Chander Kumar, Sunil Kumar, one drunk police men unnamed and Praveen Kumar, In charge thoroughly abused Petitioner with filthy language. The same has been reported to 112 call with reference No. 5215164. 11.06.2022 112 call has been made against gang rapes and illicit sex trade of victims inside Dharamshala and hotels of Church Mission Road P.S. Lahori Gate and inside the Old Delhi Railway Station property with reference No. 5220691 and 5221720. 112 call has been made against Delhi Police for persistent torture and harassment of Petitioner to leave Delhi and leave Supreme Court case. The same has been recorded by 112 reference no. 5217267 and statement recorded by Enquiry Officer Rajender Singh SI, Mobile no. 9910939878 old Delhi Railway Station at 5:30 a.m. 12.06.2022 112 call has been made against gang rapes and illicit sex trade, child sexual abuse and hidden prostitution by the sex abusers/sex racketeers State against the victim Petitioner’s families and their minor girl child, rescued on 05.05.2022 departed by Mahananda Express to
  • 10. 10 Katihar, Bihar but instead of handing over to the Petitioner again being re-pushed into the same business of flesh trade at the source point of human trafficking at Katihar Bihar and transit or destination point of human trafficking at Delhi/NCR. The same has been recorded with reference No. 5222761, 5222864 and 5222786. Thereafter enquiry officer Devender Singh 011-23961522 took the detail of Petitioner and his wife, minor daughter, sister in law and their minor daughters and father in law. Thereafter, he introduced Petitioner in front of SHO old Delhi Railway Station after 4 hours at 11:10 AM. SHO abused the petitioner with filthy language and threatened of dire consequences if any further 112 call is being made by the Petitioner from old Delhi Railway Station. He asked Petitioner to go to (Lal Qila) Red Fort and Kamla Market to make 112 call because his minor daughter and other family members and their minor children have gone there for illicit sex trade, gang rapes, child sexual abuse and hidden prostitution. He also warned the Petitioner to vacate the premises of old Delhi Railway Station immediately. 14.06.2022 Hence this Writ Petition Criminal is being filed.
  • 11. 11 IN THE SUPREME COURT OF INDIA CRIMINAL ORIGINAL JURISDICTION WRIT PETITION CRIMINAL D.NO. 18546 OF 2022 (UNDER ARTICLE 32 OF THE CONSTITUTION OF INDIA) AND IN THE MATTER OF PERSISTENT GANG RAPES, ILLICIT SEX TRADE AND CHILD SEXUAL ABUSE, HIDDEN PROSTITUTION, INTERNATIONAL HUMAN TRAFFICKING/SEX RACKET, ABUSE OF POLICE POWER, SUSPICIOUS DEATH AND MOB VIOLENCE/MOB LYNCHING. AND BETWEEN 1. Om Prakash ………PETITIONER S/O Late Sh Deep Narayan Poddar R/O ASHA DEEP NIWAS Vill-Kantiya Panchayat, Shukkar Haat Sonaili, In front of Durga Mandir P.S. Kadwa, Distt-Katihar Bihar-855114 AND RENTED R/O RZF-893, Netaji Subhash Marg Raj Nagar Part-2, Palam Colony New Delhi-110077 VERSUES 1. Union of India ….RESPONDENT No.01 Ministry of Home Affairs Through Secretary North Block, Central Secretariat, New Delhi 2. Government of NCT of Delhi ….RESPONDENT No.02 Through Chief Secretary Delhi Secretariat, I.P. Estate New Delhi-110002 3. State of Bihar ….RESPONDENT No.03 Through Chief Secretary, Old Secretariat, Patna-800015 4. District Magistrate ….RESPONDENT No.04
  • 12. 12 Katihar, Bihar 5. District Judge ….RESPONDENT No.05 District Court Katihar Bihar 6. Commissioner of Police Delhi ….RESPONDENT No.06 Police Headquarters, MSO Building, I.P. Estate, New Delhi-110002 7. Director General of Police ….RESPONDENT No.07 Bihar Police Headquarters, Sardar Patel Bhawan, Nehru Marg, Patna - 800023 8. Inspector General of Police, ….RESPONDENT No.08 Darbhanga, Bihar 9. Deputy Inspector General of Police ….RESPONDENT No.09 Purnia, Bihar 10. Superintendent of Police ….RESPONDENT No.10 District- Katihar, Bihar-854105 11.Deputy Commissioner of Police ….RESPONDENT No.11 North East District Delhi 12.Assistant Commissioner of Police ….RESPONDENT No.12 Seelampur, North East District Delhi 13.Assistant Commissioner of Police ….RESPONDENT No.13 Delhi Cantt. South West District Delhi New Delhi 14.Secretary ….RESPONDENT No.14 Electricity Department Government of Bihar 15.Chief Executive Engineer ….RESPONDENT No.15 Electricity Department District Katihar, Bihar 16.Junior Executive Engineer ….RESPONDENT No.16 Sub-Station Sonaili, Kadwa Electricity Department District Katihar, Bihar 17.Secretary Health Department ….RESPONDENT No.17
  • 13. 13 Patna, Government of Bihar 18.Civil Surgeon ….RESPONDENT No.18 Health Department District Katihar, Bihar 19.In-charge Medical Officer ….RESPONDENT No.19 Kadwa, Primary Health Centre Durgagunj, District Katihar 20.Sub Divisional Manager ….RESPONDENT No.20 Barsoi, Katihar 21. Sub-Divisional Police Officer ….RESPONDENT No.21 Head Quarter District-Katihar, Bihar- 854105 22. Sub-Divisional Police Officer ….RESPONDENT No.22 Barsoi, District Katihar, Bihar- 855102 23.Station House Officer ….RESPONDENT No.23 Palam Village Police Station, South West District New Delhi 24. Station House Officer ….RESPONDENT No.24 Kadwa Police Station, District-Katihar, Bihar-855114 25.Station House Officer ….RESPONDENT No.25 Shastri Park, North East District Delhi 26.Station House Officer ….RESPONDENT No.26 Dandkhora, Katihar Bihar 27. Chairperson ….RESPONDENT No.27 National Commission for Protection of Child Rights (NCPCR) 5th Floor, Chanderlok Building, 36 Janpath, New Delhi-110001 28. Nodal Coordinator ….RESPONDENT No.28 ChildLine India Foundation Eastern Regional Resource Centre Kolkotta 29. Nodal Coordinator ….RESPONDENT No.29
  • 14. 14 ChildLine India Foundation North Regional Resource Centre 1st Floor, H. No. 144/2, Hari Nagar Mathura Road, Ashram, New Delhi-14 30. District Coordinator …..,.RESPONDENT No.30 Child Line India Foundation Katihar, Bihar 31. Superintendent of Police …..,.RESPONDENT No.31 Railway Old Delhi Railway Station Delhi 32. Station House Officer, …..,.RESPONDENT No.32 Railway Old Delhi Railway Station Delhi 33. Superintendent of Police …..,.RESPONDENT No.33 Railway Katihar, Bihar 34. Station House Officer, …..,.RESPONDENT No.34 Katihar Railway Station Police Station, Bihar . 35. Indian Defense Organizations …..,.RESPONDENT No.35 Sena Bhawan Head Quarters at New Delhi 36. Chairman Railway Board …..,.RESPONDENT No.36 New Delhi 37. Divisional Railway Manager …..,.RESPONDENT No.37 District Katihar, Bihar 38. Director …..,.RESPONDENT No.38 Trustee and Governing Bodies Asha Deep Foundation Shalimar Garden Main B-block, Block A, Shaheed Nagar, Ghaziabad, Uttar Pradesh 201005 0120- 262 6309 D-81, Shahid Nagar, Delhi NCR, Ghaziabad, U. P., India 39. National Coordinator …..,.RESPONDENT No.39 Child Line India Foundation B-1101, 11th Floor, Ratan Central Dr, Baba Saheb Ambedkar Road Parel East, Mumbai-400012 40. District Coordinator …..,.RESPONDENT No.40 Child Line India Foundation
  • 15. 15 District Samastipur, Bihar 41. Chairperson …..,.RESPONDENT No.41 National Commission for Women New Delhi PETITION UNDER ARTICLE 32 OF THE CONSTITUTION OF INDIA FOR ISSUANCE OF A WRIT IN THE NATURE OF MANDAMUS OR ANY OTHER APPROPRIATE WRIT FOR ENFORCEMENT OF ARTICLE 21 OF THE CONSTITUTIION OF INDIA. To Hon'ble the Chief Justice of India and His Lordship's Companion Justices of the Supreme Court of India. The Humble petition of the Petitioner abovenamed. MOST RESPECFULLY SHOWETH: 1. FACTS OF THE CASSE: (i) That the present Writ Petition under Article 32 of the Constitution of India is being filed by a Social Worker cum husband cum father cum Guardian cum Whistle Blower cum Petitioner-In-Person; aggrieved by the deliberate hiding out of his all near about 50 family members including his kidnapped pregnant wife and his minor daughter by the sex racketeers/sex abusers State and subsequently aggrieved by the deliberate obstruction in making payment of Rs. 431/- against e-filed fresh Writ Petition Criminal dated 7th June, 2022 after dismissal of Writ Petition (Criminal) No. 136/2016,
  • 16. 16 Writ Petition (Criminal) No. 137/2021 and Writ Petition (Criminal) No. 242/2021 by this Hon’ble Court and deliberate inertia to stop persistent gang rapes and illicit sex trade of petitioner families and their minor girl child by the nexus of state, NGOs, gangsters, Mafias, Indian defense organizations and general public since 18 years to till date across the globe and deliberate bystander apathy by state to rescue and rehabilitate them enforcing their Rights under Article 21 of the Constitution of India. (ii) That the petitioner has apprised and briefed the grave situation of persistent gang rapes and illicit sex trade through affidavit no. 4127/22 dated 8th June, 2022 and dispatched the same to Hon’ble the Chief Justice of India through R & I Section Counter No. 17 of Supreme Court of India dated 8.6.2022 vide D. NO. 34979/2022 is annexed herewith as Annexure P-1 (Page from 33 to 37) (iii) That Petitioner has been denied to get photo entry pass issued by counter No.41 of this Hon’ble Court to meet Registrar J-I and apprised the grave situation of persistent gang rapes and illicit sex trade of his families by the State since 18 years. The petitioner has dispatched an application for appointment with Registrar of Supreme Court of India dated 8.6.2022 through R&I Counter No. 17 of Supreme Court of India is annexed herewith and marked as Annexure P-2 (page from 38 to 39) (iv) That Petitioner’s wife Rina Kumari aged about 44 years and minor daughter Shriya Poddar aged about 17 years have
  • 17. 17 been kidnapped on 15.04.2005 while wife was pregnant, with an active help of her father Surender Narayan Poddar, Assistant Manager (RC), Brauni Refinery, Indian Oil Corporation, Begusarai, Bihar from the house of Brajesh Yadav a driver of Judge, resident of Gali No. 12, Raj Nagar Part-2, Palam Colony New Delhi 77 under the pressure/tactics of sex racketeers and pushed her into illicit sex trade, hidden prostitution, child sexual abuse and International Human trafficking. Petitioner came to know this fact for the first time while he was rescuing other’s minor girl child ‘Nikki’ from the clutches of human traffickers in Shastri Park, North East Delhi through Writ Petition (Criminal) 242/2021. Several police complaints have been filed with Bihar and Delhi Police for registration of an F.I.R, rescue, arrest, medical, charge sheet, placing before court of Law and initiating rehabilitation process of the victims. But no F.I.R has been registered either Delhi Police or by Bihar Police as on date. (v) That petitioner has seen his minor daughter Shriya Poddar only once on 9.2.2011 at family court, Dwarka Court at New Delhi before Principal Judge Ms. Deepa Sharma. (vi) That 112 call has been made against the persistent Gang Rapes and illicit sex trade of petitioner’s families inside the common toilet of Luxmi Naraan Dharamshala, Church Mission Road, Fatehpuri, Delhi-6 on 8.6.2022 with Ref. No. 5201138 and 5201158 dated 8.6.2022 and subsequent 112 call with Reference No. 5206837 dated 9.6.2022 against Assistant Sub Inspector Bijendra Singh, police post Church Mission Road, Fatehpuri, Delhi-6 under Police Station
  • 18. 18 Lahori Gate, Delhi-6 for his biased police action against the victims and Complainant and for escalating gang rapes and illicit sex trade of Petitioner’s families. An application for registration of an F.I.R has been filed with Police Station Lahori Gate, Delhi-6 on 9th June 2022 vide D.D. No. 23A at 12:26p.m. The same illicit sex trade of Petitioner’s families happened with effect from 25th April, 2022 to 4th May 2022 by the son of gangsters Sahabuddin inside the same common toilet of Luxmi Narayan Dharamshala, Church Mission Road, Fatehpuri, Delhi-6 is annexed herewith and marked as Annexure P-3 (Page from 40 to 43) (vii) That 112 call has been made against an attempt of mob lynching of petitioner by sex abusers in front of Luxmi Narayan Dharamshala at Church Mission Road, Fatehpuri, Delhi-6 on 9th June 2022 with reference No. 5208740, 5208823, 5209010, 5209016, 5208990 and 5209461. The call also has been recorded for forcing the Petitioner to vacate Luxmi Narayan Dharamshala, Church Mission Road, Fatehpuri, Delhi-6 by the same police post policemen. (viii) That 112 call has been made by the petitioner on 10.06.2022 with reference no. 5215164 against police post Church Mission Road, Fatehpuri, Delhi-6 in charge Praveen Kumar for illegally arresting/detaining him for 24 hours at police post and gang raping, transacting illicit sex trade of his families in front of his own eyes at police post. Same act has been done by SHO Kadwa Katihar, Bihar along with Superintendent of Police Katihar on 20th May 2022 inside his house at Sonaili Village Police Station Kadwa, Katihar, Bihar.
  • 19. 19 (ix) That 112 call also have been made against Delhi Police for harassing and not letting the Petitioner to stay at Delhi anywhere to transact Court business at Supreme Court, New Delhi. The 112 call recorded with reference No. 5217267 dated 11.6.2022 and statement recorded by Enquiry Officer Old Delhi Railway Station Police Station on the same day at 5:30 a.m. (x) That Petitioner’s sisters, sister in laws, wife and minor daughters have been repeatedly gang raped by Superintendent of Police Sidharth Mohan Jain Superintendent of Police Deepak Sah, Superintendent of Police Vikas Kumar, Superintendent of Police Jitender Kumar, Superintendent of Railway Police, Avinash Kumar, of Katihar and Bhagalpur. (xi) That sex racketeers and sex abusers are taking undue benefit of jurisdictions while in this matter, International jurisdiction is applicable for organizing gang rapes and illicit sex trade of victims. Sex racketeers are using Air base of Air Force for fast movement of human trafficking from one place to another place, using intoxicating drugs to trap victims, using biological weapon to sustain the sex racket, within few hours changing jurisdiction for gang rapes and illicit sex trade of victims, getting exact information form Government Machineries against the complaint of Petitioner. For example 10th June, 2022 night, victim gang raped under the jurisdiction of Police Station Lahori Gate, Delhi-6 and trafficked by rail at 8:00pm on 10th June, 2022 to Katihar, Bihar and will be gang raped throughout the journey inside the toilet of train and thereafter by
  • 20. 20 Superintendent of Police Rail Katihar Avinash Kumar and General Public for generating Revenue out of it. (xii) That Magistrate of Katihar has supplied false and fabricated documents before this Hon’ble Court and did not hand over the victims to the Petitioner rather re-pushed the rescued victims into the same business of flesh trade at the source point of human trafficking at Katihar Bihar and at the transit or destination point of human trafficking at Delhi/NCR. (xiii) That Petitioner is not being allowed to know the whereabouts of victims till date, not being allowed to meet the victims till date. The State has not initiated the rehabilitation process of victims either within the State owned institutions like Women shelter homes, observation homes for children or within the family so far. (xiv) That situation is alarming because Life and Liberty of Petitioner is at stake and he has been thrown out on the street of Delhi by the sex abusers State Center NGOs Gangsters Mafias Indian Defense Organizations and General Public. (xv) That Petitioner has filed Criminal Writ Jurisdiction Case No. 1238/2019 before Patna High Court against the abuse of Court process; which is still pending. (xvi) That Petitioner has been engaged in abuse of Court process on the one hand and sexual abuse, illicit sex trade of his families by the sex abusers center and state on the other hand. (xvii) That both the parents of Petitioner have been killed by the
  • 21. 21 sex abusers in 2007 and 2017 respectively in Bihar and Delhi jurisdiction. (xviii)That abuse of court process misled towards the wrong cause of action like divorce, domestic violence and 498A, dowry prohibition matter while the actual matter was International sex racket, hidden prostitution, Child Sexual Abuse, illicit sex trade of the families of Petitioner by the State and Central Government since 2005 for generating Revenue out of it. (xix) That 112 call has been made with reference No. 5220691 dated 11.6.2022 to stop gang rapes of victims in the Hotel and Dharamshala under the jurisdiction of P.S. Lahori Gate, Church Mission Road, Fatehpuri, Delhi-6. But police did not take any action and escalated illicit sex trade of victims. No police raid and rescue of the victim is being made by the police as on date. (xx) That 112 call again has been made by the Petitioner with reference No. 5221720 dated 11.6.22 to stop gang rape and illicit sex trade of victims inside the premises of old Delhi Railway Satation. As usual police did not take any action rather escalated gang rapes, illicit sex trade of victims. Victims are under the police custody illegally, yet police pretend to show unawareness against the whereabouts of the victims till date. (xxi) Police are playing tactics of handing over the victims to human traffickers cutting across caste, creed and Nationality to sustain persistent gang rapes and illicit sex trade of victims across the globe.
  • 22. 22 (xxii) That fresh cause of action arose in both the state Bihar as well as in Delhi with effect from 6th May 2022 to till date. 2. QUESTIONS OF LAW: i) Whether or not despite of receiving information disclosing cognizable offence of gang rapes and illicit sex trade of victims; F.I.R has not been registered by Delhi Police under Section 154(1) or Section 157(1) of Cr.Pc. while the victim pregnant wife of Petitioner kidnapped from Police Station Palam Village New Delhi jurisdiction on 15.04.2005 is arbitrary, illegal and void action by Police? ii) Whether or not non registration of an F.I.R and not placing the victims before the court of law by the police indicates their own vested interest of sustaining gang rapes and illicit sex trade of victims frequently changing their jurisdiction by human traffickers is arbitrary, illegal and void? iii) Whether or not hiding out of the whereabouts of victims, re pushing them into flesh trade, illicit sex trade and not allowing the Petitoner to meet the victims is violating Rule of Law and Principles of Natural Justice and Principles of Social Work? 3. GROUNDS: Aggrieved by the biased police action dated 20th May 2022 by Bihar Police and 8th June 2022 to 12th June 2022 by Delhi Police, the same is being challenged on these following amongst other grounds:
  • 23. 23 A. BECAUSE persistent Gang Rapes and illicit sex trade of victims, changing jurisdiction frequently need to be stopped immediately. B. BECAUSE rehabilitation process of victims to be initiated immediately to begin a dignified life for the victims. C. BECAUSE e-filed Writ Criminal Petition dated 7th June 2022 contains all details with complete evidence to be made part of this petition in the furtherance of justice. D. BECAUSE hidden status of victims encouraging illicit sex trade and persistent gang rapes by the state and General Public and discouraging rescue and rehabilitation of victims. E. BECAUSE Center and State are bidding and selling the victim’s Body to the General Public for generating Revenue out of it. F. BECAUSE technologies like Jammer Mobile services, artificial rain supporting gang rapes and illicit sex trade, hidden cameras and chip inside the body of animals and birds for surveillance of gang rapes and illicit sex trade, use of Air Force Air base for fast moving of victims from one place to another place, electricity disconnection by the State for organizing gang rapes and illicit sex trade, use of defense, Police, judiciary, advocates, executives, legislatures, media to sustain this technology based sex Industry. G. BECAUSE hidden status of victims are creating anxiety, suspicion and mental imbalances in the mind of Petitioner. H. BECAUSE State & General Public are snatching,
  • 24. 24 scratching and eating the body of victims like dogs and birds. I. BECAUSE pregnant wife Reena Kumari kidnapped on 15th April 2005 by the sex abusers and never came back till date, caught with illicit sex trade, hidden prostitution in 2021 at Sonaili, Katihar, Bihar at brothel of Gulab Bagh and Varanasi, Uttar Pradesh. J. BECAUSE Petitioner cannot see persistent gang rape and illicit sex trade of his own families in front of his own eyes rather will prefer to finish him. K. BECAUSE Petitioner is looking for his own end, not the end of sex racket run by Government of India. L. BECAUSE wife Rina Kumari of Petitioner has not filed written statement in HMA 700 of 2010 case before family court, Dwarka Court, at New Delhi under the pressure of Human traffickers and sex abusers. M. BECAUSE it was the sex abusers and sex racketeers who created Hoax, engaged Petitioner into abuse of court process, taken hostage the Petitioner and his whole family to ruin the married life of Petitioner for their own vested interest. N. BECAUSE jurisdiction is the root cause of escalating human trafficking from one place to another place. O. BECAUSE jurisdiction is safety belt for human traffickers. P. BECAUSE Petitioner father have seen his minor daughter Shriya Poddar for the first time on 9th February, 2011 at
  • 25. 25 family court Dwarka Court at New Delhi. Thereafter, he has caught his daughter with child sexual abuse in 2021 at Shastri Park, North East Delhi and Sonaili Police Station: Kadwa, Katihar Bihar. 4. AVERMENT i) That the present petitioner has not filed any other petitions in any High Court or the Supreme Court of India on this subject matter of the present petition. ii) That the Petitioner does not have any alternative and efficacious remedy for enforcement of fundamental rights of victims of gang rapes, illicit sex trade and child sexual abuse. iii)However, the petitioner has filed Writ Petition (Civil) 90 of 2016, Writ Petition (Criminal) 136/2016, Writ Petition (Criminal) 136/2016, Writ Petition (Criminal) 137/2021 and Writ Petition (Criminal) 242/2021 before this Hon’ble Court in different interlinked subject matter. PRAYER In the above premises, it is prayed that this Hon'ble Court may be pleased:
  • 26. 26 (i) To issue a writ of mandamus or other appropriate writ order or direction directing respondent No.01 to 08 to direct to concern SHOs of Delhi and Bihar Police to register an F.I.R against the complaints of petitioner made since 2011 to till date. (ii)To issue a Writ of mandamus or other appropriate writ order or direction directing respondent No.01 to 41 to direct to concern authorities to rescue, arrest, medical, charge sheet, place before the court of law and initiate the rehabilitation process of victims immediately. (iii) To issue a writ of mandamus or other appropriate writ order or direction directing respondent No. 01 to 41 to allow the Petitioner to know whereabouts of the victims and allow him to meet the victims for Social Work intervention, counselling and data collection. (iv) To allow the Petitioner to make payment of Rs. 431/- against e-filed Writ Petition (Crl) D.No. 18546 of 2022 dated 7th June, 2022. (v)To list this matter urgently before the Vacation Bench to stop persistent gang rapes and illicit sex trade of families and minor girls of Petitioner and rescue and rehabilitate the victims immediately.
  • 27. 27 (vi) To issue death Warrants against guilty public authorities to hang to death, whatsoever, indulged in this matter. (vii) To order for medical examination of DNA testing for matching blood relationships with Petitioner father, HIV, STI, reproductive health status of victims, uterus status of victims, sexual health status of victims by multiple medical health Institute across country to avoid falsehood. (viii) To set aside divorce Judgment passed in MAT.APPEAL NO. 7/2012 by Delhi High Court and correct the misleading error and abuse of court process for derailing the actual matter from prostitution, illicit sex trade, child sexual abuse to divorce, domestic violence, and 498A Dowry Prohibition by the sex abusers State and Central Government. (ix) To Constitute a Committee to recommend Government of India for judicial reform, police reform, defense reform and bureaucratic reform to combat the menace of International Human trafficking and illicit sex trade in the garb of fast changing jurisdiction of victims with an active help of misusing Government machinery. (x)To remove the jurisdictional barrier in the case of Human Trafficking and illicit sex trade to wipe out it from the earth
  • 28. 28 and save other innocent families from ruining like the Petitioner. Pass such other order/orders as this Hon'ble Court may deem just and proper in the facts and circumstances of the case. PETITIONER-IN-PERSON OM PRAKASH S/O LATE SHRI DEEP NARAYAN PODDAR S/O LATE SRIMATI ASHA RANI DEVI PERMANENT RESIDENT: ASHA DEEP NIWAS, SONAILI, SHUKKAR HATT, IN FRONT OF DURGA MANDIR, KANTIYA PANCHAYAT, P.S. KADWA, KATIHAR, BIHAR-855114 MOB: 9540389759 E-mail: om.poddar@gmail.com NEW DELHI: FILED ON : 14-06-2022
  • 29. 29 IN THE SUPREME COURT OF INDIA CRIMINAL ORIGINAL JURISDICTION WRIT PETITION CRIMINAL D. NO.18546 OF 2022 (UNDER ARTICLE 32 OF THE CONSTITUTION OF INDIA) AND IN THE MATTER OF PERSISTENT GANG RAPES, ILLICIT SEX TRADE AND CHILD SEXUAL ABUSE, HIDDEN PROSTITUTION, INTERNATIONAL HUMAN TRAFFICKING/SEX RACKET, ABUSE OF POLICE POWER, SUSPICIOUS DEATH AND MOB VIOLENCE/MOB LYNCHING. AND IN THE MATTER OF: OM PRAKASH ..PETITIONER VERSUS UNION OF INDIA & ORS …….RESPONDENT(S) AFFIDAVIT I, Om Prakash S/o Late Shri Deep Narayan Poddar, age about 48 years, R/o Asha Deep Niwas, Vill-Kantiya Panchayat, Shukkar Haatt, P.S. Kadwa, Distt-Katihar, Bihar-855114 and Rented R/O RZF-893, Netaji Subhash Marg, Raj Nagar Part-2, Palam Colony, New Delhi-110077 do hereby solemnly affirm and state on oath as under:- 1. That I am the Petitioner in the above matter and well conversant with the facts of the case as such competent to swear this affidavit.
  • 30. 30 2. That the contents of the accompanying Criminal Writ Petition under Article 32 of Constitution of India against the persistent gang rapes, illicit sex trade and International human trafficking/Sex Rackets which has been drafted by me [para 01 to 04], [Page 01 to 30 ] and Synopsis and List of Dates (Page B to J ], and I, As. And application for seeking permission to appear and arguing in-person having understood the contents thereof I say that the facts state therein are correct which are based on the official record. 3. That the annexures P-01 to P- 03 [Page 33 to 43] are true copies of their respective original. 4. That the Criminal Petition Paper Book contains total pages 50’ DEPONENT VERIFICATION: I, the above-named deponent do hereby verify that the facts stated in the above affidavit are true to my knowledge and belief. No part of the same is false and nothing material has been concealed therefrom. Verified at New Delhi on this the 14th day of June, 2022. DEPONENT
  • 31. 31 Annexure P-1 IN THE SUPREME COURT OF INDIA CRIMINAL ORIGINAL JURISDICTION WRIT PETITION CRIMINAL NO. OF 2022 (UNDER ARTICLE 32 OF THE CONSTITUTION OF INDIA) WITH WRIT PETITION CRIMINAL NO. 136 OF 2016 WITH WRIT PETITION CRIMINAL NO. 137 OF 2021 WITH WRIT PETITION CRIMINAL NO. 242 OF 2021 AND IN THE MATTER OF PERSISTENT GANG RAPES, AND ILLICIT SEX TRADE OF FAMILIES AND CHILDREN OF PETITIONER SINCE 18 YEARS. AND IN THE MATTER OF: OM PRAKASH ..PETITIONER VERSUS UNION OF INDIA & ORS …….RESPONDENT(S) To Hon'ble the Chief Justice of India and His Lordship's Companion Justices of the Supreme Court of India. AFFIDAVIT MOST RESPECFULLY SHOWETH THROUGH AFFIDAVIT: I do hereby solemnly showeth that:-
  • 32. 32 1. That Petitioner has filed W.P (Crl.) 136/2016, W.P (Crl.) 137/2021 and W.P (Crl.) 242/2021 against the criminal act of Judges, Advocates, Police, NGOs, Government officials, defense personnel, and legislatures but all have been dismissed. 2. That Petitioner’s wife Rina Kumari age 44 years has been kidnapped with an active help of his father on 15.04.2005 from the house of Mr. Brajesh Yadav, a driver of Judge R/O Gali No. 12, Raj Nagar Part-2, Palam Colony, New Delhi- 77. 3. That petitioner’s (OM PRAKASH) Present address is Asha Deep Niwas, Shukkar Hatt, Sonaili, P.S.Kadwa, district Katihar, Bihar-855114 and R/O RZF-893, Netaji Subhash Marg, Raj Nagar Part-2, Palam Colony, New Delhi-77, S/O Late Deep Narayan Poddar, ageabout 48 years. 4. That Magistrate of Katihar has placed false and fabricated documents before this Hon’ble Court and re-pushed the victims of Gang Rapes and illicit sex trade into the same business of flesh trade w.e.f. 06.05.2022 to till date at the source point of human trafficking at Sonaili, Katihar, Bihar
  • 33. 33 and the destination/transit point of human trafficking Delhi/NCR. 5. That petitioner father has been killed by sex abusers in 2007 at Sonaili Katihar Bihar and mother has been killed in 2017 in Palam Colony New Delhi. 6. That Petitioner has been thrown out of Delhi and Bihar House and has become homeless on the road. 7. That electricity of House of petitioner has been disconnected since 2011 for gang rapes and illicit sex trade of his families and children by the nexus of State, NGOs, Mafias, Gangsters, Indian defense organizations and general public. 8. That petitioner has filed number of cases (Writ Criminal) before this Hon’ble Court and number of police complaints with Bihat as well as Delhi Police since 2011 to till date. Yet no F.I.R and no action against the powerful accused so far. 9. That petitioner is trying to e-file the fresh Criminal Writ from Katihar Bihar dated 4.6.22 but sex abusers putting off the electricity, extracting data from the charging point of Lap Top, damaging Lap Top, hacking password , stealing daily diary and hence putting several obstruction on the way of
  • 34. 34 petitioner, Supreme Court filing counter did not allow to meet Registrar or Branch officer E-filing on 7.6.22. Branch Officer E-filing phone No. 011-23115949 and 1881 are not functioning and not responding the Petitioner since 7.6.22 to till date. 10.That Petitioner has filed a fresh Writ Petition Criminal against the persistent Gang Rapes and illicit sex trade of his families and children on 7.6.22 (7th June 2022) at 05:00 AM from Anand Vihar Railway Station Delhi/NCR but OTP for Rs. 431/- against the petition has not been supplied to the petitioner thereafter his Lap Top been damaged, password hacked by the sex abusers. However, transaction ID with error has been supplied to the petitioner. Matter may be investigated by registering an F.I.R against this event. 11.That aggrieved by the Criminal Act of Center, State & Government of India, Petitioner has called 112 again on 8th June, 2022 at 7:04 AM from “Luxmi Narayan Dharamshala, Church Mission Road, Fatehpuri, Delhi 110006”. Followings are reference numbers of 112 call:-
  • 35. 35 a) Ref. NO. 5201138 (police women) dated 8th June 2022 at 7:04:23 AM b) Ref. NO. 5201138 (Petrol Vehicle SGR66 Mob 9311923466) c) Ref. NO. 5201158 (Police PCR Patrol Vehicle ZBR20 Mob 9311923220) 12.That thereafter ASI Bijendra Singh is being deputed by PCR at Luxmi Narayan Dharmshala, Church Mission Road, Fatehpuri Delhi-6 13.That thereafter ASI Bijendra Singh took the Petitioner at Police Post Church Mission Road, Police Station Lahori Gate Delhi-6, 011-23830880, 011-23953776, 011-23958234 at 8:00 AM on 8th June 2022. He took the details from the Petitioner and Gang Rapes continued inside “Luxmi Narayan Dharamshala Church Mission Road, Fatehpuri Delhi-6 14. That Petitioner is praying from you either to kill him or otherwise Petitioner will continue his fight against illicit sex trade till his death.
  • 36. 36 15.That allow the Petitioner to make payment Rs. 431/- against the e-filed fresh Criminal Writ Petition dated 7th June 2022 at 5:00 AM from Anand Vihar Railway Station IP address. 16.That Petitioner will wait at Luxmi Narayan Dharmshala for your response NOTICE over telephone only till you send the information/ response/NOTICE. DEPONENT VERIFICATION: I, the above-named deponent do hereby verify that the facts stated in the above affidavit are true to my knowledge and belief. No part of the same is false and nothing material has been concealed therefrom. Verified at New Delhi on this the 8th day of June, 2022. DEPONENT True Copy
  • 37. 37 Annexure P-2 To The Registrar Supreme Court of India New Delhi Sub: Appointment to apprised/brief against Persistent Gang Rapes and illicit sex trade of near about 50 female members and their Children of Petitioner after dismissal of W.P.(Crl.)136/2016, 137/2021 and 242/2021 by this Hon’ble Court-reg. Sir/Madam, 1. That Petitioner-in-Person is OM PRAKASH S/O Late Deep Narayan Poddar, R/O Asha Deep Niwas, Shukkar Hatt, Sonaili, P.S.Kadwa, district Katihar, Bihar-855114 and R/O RZF-893, Netaji Subhash Marg, Raj Nagar Part-2, Palam Colony, New Delhi-77, age about 48 years, presently putting up at Luxmi Narayan Dharamshala, Church Mission Road, Fatehpuri, Delhi-110006 since 7.6.2022 2. That petitioner is seeking appointment with Hon’ble the Chief Justice of India through Registrar J-1 of Supreme Court of India to apprise facts against persistent Gang Rapes and illicit sex trade of his 50 family members by the nexus of State, Gangsters, NGOs, Indian Defense Organizations and general public since 18 years.
  • 38. 38 3. That Petitioner has filed W.P. (Crl.)No…….. of 2022 with W.P. (Crl.)No. 136/2016 with W.P. (Crl.)No. 137/2021 with W.P. (Crl.)No. 242/2021 through e-filing system of this Hon’ble Court on 7th June 2022 at Anand vihar Railway Station’s IP address at 5:00AM but OTP for payment of Rs. 431/- has not been sent to the petitioner, thereafter damaged his Lap Top, hacked password, disconnected electricity of his house since 12 years, closed the door of Supreme Court of India, closed the door of Bihar Police as well as Delhi Police by the sex abusers. 4. That Petitioner has become handicapped and compelled either to accept Gang Rapes or to die hard. 5. That under this circumstances, Petitioner wants to hand over Affidavit No.4127/22 dated 8th June 2022to Hon’ble the Chief Justice of India through Registrar J-1 of Supreme Court of India, New Delhi. Photo entry pass denied by this Hon’ble Court on 8th June 2022 at counter no. 41. 6. Affidavit dispatched through R&I counter no. 17 of Supreme Court of India on 8.6.2022.
  • 39. 39 7. That Affidavit contains the details of 112 PCR Call to Delhi Police dated 8.6.22 by the Petitioner. NEW DELHI OM PRAKASH DATE:8.6.22 S/O Late Deep Narayan Poddar Luxmi Narayan Dharamshala Church Mission Road Fatehpuri Delhi-110006 True Copy
  • 40. 40 Annexure P-3 To, D.D.NO.23A AT 12:26PM The SHO Dated: 09.06.2022 Lahori Gate Police Station Delhi-110006 Sub: Complaint against biased Police action with reference to 112 call dated 9.6.22 ref. no. 5206837 against persistent Gang Rapes and illicit sex trade of applicant’s near about 50 families and their children-reg. Sir/Madam, 1. That applicant is OM PRAKASH S/O Late Deep Narayan Poddar, R/O Asha Deep Niwas, Shukkar Hatt, Sonaili, P.S.Kadwa, district Katihar, Bihar-855114 and R/O RZF- 893, Netaji Subhash Marg, Raj Nagar Part-2, Palam Colony, New Delhi-77, age about 48 years, presently putting up at Luxmi Narayan Dharamshala, Church Mission Road, Fatehpuri, Delhi-110006 P.S. Lahori Gate Police Post Church Mission Road, Delhi-6 for e-filing W.P. (Crl.)No…….. of 2022 with W.P. (Crl.)No. 136/2016 with W.P. (Crl.)No. 137/2021 with W.P. (Crl.)No. 242/2021 before Supreme Court of India. 2. That W.P. (Crl.)No…….. of 2022 against persistent Gang Rapes and illicit sex trade of families of applicant has been filed on 7th June 2022 at 5:00AM from Anand Vihar Railway Station’s IP address. However, OTP for payment of Rs.
  • 41. 41 431/- has not been supplied by the Supreme Court of India thereafter Lap Top being damaged, password being hijacked, applicant put on surveillance by sex abusers, door of Supreme Court of India being closed, door of Home Ministry being closed and door of Delhi as well as Bihar Police being closed by the sex abusers. 3. That applicant has called 112 on 11.11.2017 thereafter on 8.6.2022 and 9.6.2022 ref. no. 5201138 and 5201158 dated 8.6.22 and ref no. 5206837 dated 9.6.22 has been recorded by Delhi Police. 4. That applicant has dispatched Affidavit No. 4127/2022 vide D.No. 34979/2022 to Hon’ble the Chief Justice of India through R&I Section counter no. 17of Supreme Court of India. 5. That applicant has also dispatched a letter for an appointment to meet Registrar J-1 and Hon’ble and Hon’ble the Chief Justice of India vide D.NO. 34978/2022 dated 8.6.22 through R&I section counter no.17 of Supreme Court of India. 6. That E.O. Shri Bijendra Singh, Police Post Church Mission Road, Fatehpuri, Delhi-6 illegally detained at Police Post, took details but escalated Gang Rapes and illicit sex trade of
  • 42. 42 families of applicant. No F.I.R registered, No copy of F.I.R supplied. 7. That Magistrate of Katihar Bihar has re-pushed the rescued victims of Gang Rapes and illicit sex trade from Delhi into the same business of flesh trade at the source point of human trafficking at Katihar Bihar & transit/destination point of human trafficking at Delhi/NCR. 8. That aggrieved by this Criminal Act of State, NGOs, Mafias, Gangsters, Indian Defense organizations and general public, applicant has approached to Supreme Court of India with fresh Criminal Writ making 40 Government officials as parties including Delhi and Bihar. 9. That however, applicant has been shown the naked dance of Judiciary, Executives, legislatures and Media at New Delhi w.e.f. 6.6.2022 to till date by the sex abusers. 10.That Justice S.B.Sinha of Supreme Court of India and Praveen Kumar from Indian Defense Account Services are the main accused for pushing applicant’s families into illicit sex trade since 18 years. 11.That Justice S.B.Sinha kidnapped applicant’s wife while she was pregnant from Shri Brajesh Yadav’s house at Gali
  • 43. 43 No.12, Raj Nagar Part-2 Palam Colony New Delhi-110077 on 15.04.2005. 12.That applicant’s wife Rina Kumari age 44 years has been kidnapped on 15.04.2005 with an active help of her father Surender Narayan Poddar, Assistant Manager (RC), Barauni Refinery, IOCL, Begusarai Bihar. 13.That Justice S.B.Sinha is the first point to sexually abuse applicant’s wife thereafter by others sex abusers in India. 14.That applicant father has met his 6 years old daughter Shriya Poddar for the first time at Principal Judge Ms. Deepa Sharma, Family Court, Dwarka Court at New Delhi on 9th February 2011. Judge allowed to meet minor daughter in children room for 3 hours. Applicant has taken snaps of his minor daughter which have been submitted online to Child Line and NCPCR on 16.05.2022. The Order dated 9.2.2011 is also attached with child line and NCPCR. 15.That the same order dated 9.2.2011 of Family Court Dwarka Court at New Delhi and minor daughter’s snaps have been diaried by Chief Secretary Bihar vide ref. no.3191 dated 3.6.22 16.That under the above circumstances take stern action against the concerned guilty Public authorities for escalating Gang
  • 44. 44 Rapes & illicit sex trade of applicant’s families & their children. Delhi OM PRAKASH Date: 9.6.2022 S/O Late Deep Narayan Poddar Luxmi Narayan Dharamshala Church Mission Road Fatehpuri Delhi-6 Mob: 9540389759 True Copy
  • 45. 45 IN THE SUPREME COURT OF INDIA CRIMINAL ORIGINAL JURISDICTION CRL.M.P.NO. OF 2022 IN WRIT PETITION CRIMINAL D.NO. 18546 OF 2022 (UNDER ARTICLE 32 OF THE CONSTITUTION OF INDIA) AND IN THE MATTER OF PERSISTENT GANG RAPES, ILLICIT SEX TRADE AND CHILD SEXUAL ABUSE, HIDDEN PROSTITUTION, INTERNATIONAL HUMAN TRAFFICKING/SEX RACKET, ABUSE OF POLICE POWER, SUSPICIOUS DEATH AND MOB VIOLENCE/MOB LYNCHING. AND IN THE MATTER OF: OM PRAKASH ..PETITIONER VERSUS UNION OF INDIA & ORS …….RESPONDENT(S) APPLICATION FOR SEEKING PERMISSION TO APPEAR AND ARGUE THE WRIT PETITION (CRIMINAL) IN- PERSON To Hon'ble the Chief Justice of India and His Lordship's Companion Justices of the Supreme Court of India. The Humble petition of the Petitioner abovenamed. MOST RESPECFULLY SHOWETH: 1. The the present Writ Petition under Article 32 of the Constitution of India is being filed by a Social Worker cum husband cum father cum Guardian cum Whistle Blower cum Petitioner-In-Person; aggrieved by the deliberate hiding out of his all near about 50 family members including his kidnapped pregnant wife and his
  • 46. 46 minor daughter by the sex racketeers/sex abusers State and subsequently aggrieved by the deliberate obstruction in making payment of Rs. 431/- against e-filed fresh Writ Petition Criminal dated 7th June, 2022 after dismissal of Writ Petition (Criminal) No. 136/2016, Writ Petition (Criminal) No. 137/2021 and Writ Petition (Criminal) No. 242/2021 by this Hon’ble Court and deliberate inertia to stop persistent gang rapes and illicit sex trade of petitioner families and their minor girl child by the nexus of state, NGOs, gangsters, Mafias, Indian defense organizations and general public since 18 years to till date across the globe and deliberate bystander apathy by state to rescue and rehabilitate them enforcing their Rights under Article 21 of the Constitution of India, the contents of which are requested to be read as part of this application, as the same are not being repeated here for the sake of brevity. 2. Petitioner does not want to engage any Advocate against this Writ Petition (Criminal) No. ………of 2022 even if so provided by this Hon’ble Court because he is victim of malpractices by Advocates and abuse of court process by Judges which has resulted in Writ Petition (Criminal) 136/2016 before this court and Criminal Writ Jurisdiction Case No. 1238/2019 before Patna High Court. 3. That the Petitioner is well conversant with the facts of the case and competent enough to argue the case before this Hon’ble Court. PRAYER
  • 47. 47 It is most respectfully prayed that this Hon’ble Court may be pleased to: (a) Kindly permit the Petitioner to appear and argue the Writ Petition (Criminal) in-person. b) Pass such other order/orders as this Hon'ble Court may deem just and proper in the facts and circumstances of the case. DRAWN & FILED BY: PETITIONER-IN-PERSON OM PRAKASH S/O LATE SHRI DEEP NARAYAN PODDAR S/O LATE SRIMATI ASHA RANI DEVI PERMANENT RESIDENT: ASHA DEEP NIWAS, SONALI, SHUKKAR HATT, IN FRONT OF DURGA MANDIR, KANTIYA PANCHAYAT, P.S. KADWA, KATIHAR, BIHAR-855114 MOB: 9540389759 E-mail: om.poddar@gmail.com NEW DELHI: FILED ON : 14-06-2021 Diary No.:
  • 48. 48 IN THE SUPREME COURT OF INDIA CRIMINAL ORIGINAL JURISDICTION WRIT PETITION CRIMINAL D.NO. 18546 OF 2022 (UNDER ARTICLE 32 OF THE CONSTITUTION OF INDIA) AND IN THE MATTER OF PERSISTENT GANG RAPES, ILLICIT SEX TRADE AND CHILD SEXUAL ABUSE, HIDDEN PROSTITUTION, INTERNATIONAL HUMAN TRAFFICKING/SEX RACKET, ABUSE OF POLICE POWER, SUSPICIOUS DEATH AND MOB VIOLENCE/MOB LYNCHING. AND IN THE MATTER OF: OM PRAKASH ..PETITIONER VERSUS UNION OF INDIA & ORS …….RESPONDENT(S) AFFIDAVIT I, Om Prakash S/o Late Shri Deep Narayan Poddar, age about 48 years, R/o Asha Deep Niwas, Vill-Kantiya Panchayat, Shukkar Haatt, P.S. Kadwa, Distt-Katihar, Bihar-855114 and Rented R/O RZF-893, Netaji Subhas Park, Raj Nagar Part-2, Palam Colony New Delhi-77, do hereby solemnly affirm and state on oath as under:- 5. That I am the Petitioner in the above matter and well conversant with the facts of the case as such competent to swear this affidavit.
  • 49. 49 6. That the contents of the accompanying application Under Section 151 C.P.C. for seeking permission to appear and argue the Writ Petition (Criminal) in person, which has been drafted by me [para 01 to 03], [Page 44 to 48] and I, As. and having understood the contents thereof I say that the facts state therein are correct which are based on the official record. 7. That the accompanying application Under Section 151 C.P.C. for permission in person total pages 08 .’ DEPONENT VERIFICATION: I, the above-named deponent do hereby verify that the facts stated in the above affidavit are true to my knowledge and belief. No part of the same is false and nothing material has been concealed therefrom. Verified at New Delhi on this the 14th day of June, 2022. DEPONENT