SlideShare a Scribd company logo

Writ Petition Criminal Diary Number 18546 of 2022 Part-I .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

International Sex Racket and Anti-Prostitution Petition before Supreme Court of India. These five are key people and will reveal all records in this sex racket to rescue my minor daughters. Register 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 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 New Delhi.

Writ Petition Criminal Diary Number 18546 of 2022 Part-I .pdf

1 of 125
Download to read offline
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
CRL. M.P. NO. OF 2022
APPLICATION FOR SEEKING EXEMPTION FROM FILING
ATTESTED COPY OF AFFIDAVIT
CRL. M.P. NO. OF 2022
APPLICATION FOR EARLY HEARING/URGENT
HEARING
PAPER BOOK
(FOR INDEX KINDLY SEE INSIDE)
VOLUM/PART-01
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 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-M
8. Writ Petition (Criminal) with
Affidavit
1-59
9. Annexure: P-1
True copy of order dated 09th
February, 2011 by Principle Judge,
Family Court, Dwarka Court at
New Delhi in HMA-700/2010 case
60
10. Annexure: P-2
True copy of photographs of minor
daughter Shriya Poddar dated 09th
February, 2011 at children’s room
at Family Court, Dwarka Court at
New Delhi in HMA-700/2010 case
61
11. Annexure: P-3
True copy of signed copy of police
complaint against sex abusers state
through email letter dated 07th
May
2022 by petitioner to all nodal
police officers of Bihar and NCT of
Delhi
62-63
12. Annexure: P-4
True copy of signed copy of police
complaint against sex abusers state
through email letter dated 08th
May
2022 by petitioner to all nodal
police officers of Bihar and NCT of
Delhi
64-64
13. Annexure: P-5
True copy of signed copy of police
complaint against sex abusers state
through email letter dated 10th
May
65-66
3
2022 by petitioner to all nodal
police officers of Bihar and NCT of
Delhi
14. Annexure: P-6
True copy of signed copy of police
complaint against sex abusers state
through email letter dated 11th
May
2022 by petitioner to all nodal
police officers of Bihar and NCT of
Delhi
67
15. Annexure: P-7
True copy of signed copy of police
complaint against sex abusers state
through email letter dated 12th
May
2022 by petitioner to all nodal
police officers of Bihar and NCT of
Delhi
68
16. Annexure: P-8
True copy of signed copy of police
complaint against sex abusers state
through email letter dated 13th
May
2022 by petitioner to all nodal
police officers of Bihar and NCT of
Delhi
69
17. Annexure: P-9
True copy of signed copy of police
complaint against sex abusers state
through email letter dated 14th
May
2022 by petitioner to all nodal
police officers of Bihar and NCT of
Delhi
70
18. Annexure: P-10
True copy of signed copy of police
complaint against sex abusers state
through email letter dated 15th
May
2022 by petitioner to all nodal
police officers of Bihar and NCT of
Delhi
71
19. Annexure: P-11
True copy of signed copy of police
complaint against sex abusers state
through email letter dated 16th
May
2022 by petitioner to all nodal
police officers of Bihar and NCT of
72-74
4
Delhi
20. Annexure: P-12
True copy of signed copy of police
complaint against sex abusers state
through email letter dated 17th
May
2022 by petitioner to all nodal
police officers of Bihar and NCT of
Delhi
75-76
21. Annexure: P-13
True copy of signed copy of police
complaint against sex abusers state
through email letter dated 18th
May
2022 by petitioner to all nodal
police officers of Bihar and NCT of
Delhi
77-78
22. Annexure: P-14
True copy of signed copy of police
complaint against sex abusers state
through email letter dated 19th
May
2022 by petitioner to all nodal
police officers of Bihar and NCT of
Delhi
79-81
23. Annexure: P-15
True copy of signed copy of police
complaint against sex abusers state
through email letter dated 20th
May
2022 by petitioner to all nodal
police officers of Bihar and NCT of
Delhi
82-83
24. Annexure: P-16
True copy of signed copy of police
complaint against sex abusers state
through email letter dated 22nd
May 2022 by petitioner to all nodal
police officers of Bihar and NCT of
Delhi
84-85
25. Annexure: P-17
True copy of signed copy of police
complaint against sex abusers state
through email letter dated 24th
May
2022 by petitioner to all nodal
police officers of Bihar and NCT of
Delhi
86-87
26. Annexure: P-18 88-89
5
True copy of signed copy of police
complaint against sex abusers state
through email letter dated 26th
May
2022 by petitioner to all nodal
police officers of Bihar and NCT of
Delhi
27. Annexure: P-19
True copy of signed copy of police
complaint against sex abusers state
through email letter dated 27th
May
2022 by petitioner to all nodal
police officers of Bihar and NCT of
Delhi
90-91
28. Annexure: P-20
True copy of signed copy of police
complaint against sex abusers state
through email letter dated 28th
May
2022 by petitioner to all nodal
police officers of Bihar and NCT of
Delhi
92-93
29. Annexure: P-21
True copy of signed copy of police
complaint against sex abusers state
through email letter dated 29th
May
2022 by petitioner to all nodal
police officers of Bihar and NCT of
Delhi
94-95
30. Annexure: P-22
True copy of signed copy of police
complaint against sex abusers state
through email letter dated 31st
May
2022 by petitioner to all nodal
police officers of Bihar and NCT of
Delhi
96-97
31. Annexure: P-23
True copy of signed copy of police
complaint against sex abusers state
through email letter dated 1st
June,
2022 by petitioner to all nodal
police officers of Bihar and NCT of
Delhi
98-99
32. Annexure: P-24
True copy of signed copy of police
complaint against sex abusers state
100-
101
6
through email letter dated 2nd
June,
2022 by petitioner to all nodal
police officers of Bihar and NCT of
Delhi
33. Annexure: P-25
True copy of signed copy of police
complaint against sex abusers state
through email letter dated 3rd
June,
2022 by petitioner to all nodal
police officers of Bihar and NCT of
Delhi
102-
103
34. Application for seeking
permission to appear and argue the
Writ Petition (Criminal) in person
along with supporting affidavit.
104-
108
35. Application for seeking exemption
from filing attested copy of
Affidavit along with supporting
affidavit.
109-
113
36. Application for early hearing along
with supporting affidavit.
114-
119
37. Filing Index
38. Memo of Appearance
39. I.D.Proof

Recommended

Petition against child sexual abuse and hidden prostitution before Supreme Co...
Petition against child sexual abuse and hidden prostitution before Supreme Co...Petition against child sexual abuse and hidden prostitution before Supreme Co...
Petition against child sexual abuse and hidden prostitution before Supreme Co...OmPrakashPoddar1
 
Writ Petition Criminal diary no. 18546 of 2022 Part-II .pdf
Writ Petition Criminal diary no. 18546 of 2022 Part-II .pdfWrit Petition Criminal diary no. 18546 of 2022 Part-II .pdf
Writ Petition Criminal diary no. 18546 of 2022 Part-II .pdfOm Prakash Poddar
 
Application for Written Arguments dated 05 06-2020 before Supreme Court of India
Application for Written Arguments dated 05 06-2020 before Supreme Court of IndiaApplication for Written Arguments dated 05 06-2020 before Supreme Court of India
Application for Written Arguments dated 05 06-2020 before Supreme Court of IndiaOm Prakash Poddar
 
IA for additional ground in 137 of 2021.pdf
IA for additional ground in  137 of 2021.pdfIA for additional ground in  137 of 2021.pdf
IA for additional ground in 137 of 2021.pdfOmPrakashPoddar1
 
Review Petition Criminal Diary No. 7153 of 2023.pdf
Review  Petition Criminal Diary No. 7153 of 2023.pdfReview  Petition Criminal Diary No. 7153 of 2023.pdf
Review Petition Criminal Diary No. 7153 of 2023.pdfOmPrakashPoddar1
 
Writ Petition Criminal D.NO. 2188 of 2017 dated 18.01.2017
Writ Petition Criminal D.NO. 2188 of 2017 dated 18.01.2017Writ Petition Criminal D.NO. 2188 of 2017 dated 18.01.2017
Writ Petition Criminal D.NO. 2188 of 2017 dated 18.01.2017Om Prakash Poddar
 
Criminal M.P. D.NO.22539 dated 18.06.2018 before SC
Criminal M.P. D.NO.22539 dated 18.06.2018 before SCCriminal M.P. D.NO.22539 dated 18.06.2018 before SC
Criminal M.P. D.NO.22539 dated 18.06.2018 before SCOm Prakash Poddar
 

More Related Content

Similar to Writ Petition Criminal Diary Number 18546 of 2022 Part-I .pdf

Madras hc bail caa mar 25 order
Madras hc bail caa mar 25 orderMadras hc bail caa mar 25 order
Madras hc bail caa mar 25 ordersabrangsabrang
 
Gauri lankesh case final slp regarding accused number 6 (1)
Gauri lankesh case   final slp regarding accused number 6 (1)Gauri lankesh case   final slp regarding accused number 6 (1)
Gauri lankesh case final slp regarding accused number 6 (1)ZahidManiyar
 
M.A. D.No.42652 of 2019 in W.P. (Crl) 136 of 2016 before Supreme Court of In...
M.A. D.No.42652 of 2019 in W.P. (Crl) 136 of 2016  before Supreme Court of In...M.A. D.No.42652 of 2019 in W.P. (Crl) 136 of 2016  before Supreme Court of In...
M.A. D.No.42652 of 2019 in W.P. (Crl) 136 of 2016 before Supreme Court of In...Om Prakash Poddar
 
Complaint against SHO Tilak Marg Police Station New Delhi to NHRC New Del...
Complaint  against SHO Tilak Marg Police Station  New  Delhi to  NHRC New Del...Complaint  against SHO Tilak Marg Police Station  New  Delhi to  NHRC New Del...
Complaint against SHO Tilak Marg Police Station New Delhi to NHRC New Del...Om Prakash Poddar
 
W.p.(c) 5653-2021(main)
W.p.(c) 5653-2021(main)W.p.(c) 5653-2021(main)
W.p.(c) 5653-2021(main)Vikrant Goyal
 
Bail petition dr zafarul islam khan v gnctd through special cell final ecopy
Bail petition dr zafarul islam khan v gnctd through special cell final ecopyBail petition dr zafarul islam khan v gnctd through special cell final ecopy
Bail petition dr zafarul islam khan v gnctd through special cell final ecopyZahidManiyar
 
Complaint dated 13.4.2023 against Shelter Homes of Bihar.pdf
Complaint dated 13.4.2023 against Shelter Homes of Bihar.pdfComplaint dated 13.4.2023 against Shelter Homes of Bihar.pdf
Complaint dated 13.4.2023 against Shelter Homes of Bihar.pdfOmPrakashPoddar1
 
Writ Petition Criminal NO.......of 2017 vide D.NO.3913 against Registrar Supr...
Writ Petition Criminal NO.......of 2017 vide D.NO.3913 against Registrar Supr...Writ Petition Criminal NO.......of 2017 vide D.NO.3913 against Registrar Supr...
Writ Petition Criminal NO.......of 2017 vide D.NO.3913 against Registrar Supr...Om Prakash Poddar
 
Writ Petition Criminal NO.......of 2017 vide D.NO.3913 against Registrar Supr...
Writ Petition Criminal NO.......of 2017 vide D.NO.3913 against Registrar Supr...Writ Petition Criminal NO.......of 2017 vide D.NO.3913 against Registrar Supr...
Writ Petition Criminal NO.......of 2017 vide D.NO.3913 against Registrar Supr...Om Prakash Poddar
 
Brinda karat and anr. v. state and anr. (defects cleared)
Brinda karat and anr. v. state and anr. (defects cleared)Brinda karat and anr. v. state and anr. (defects cleared)
Brinda karat and anr. v. state and anr. (defects cleared)sabrangsabrang
 
Umar Khalid RBR18102022CRLA1732022_143522.pdf
Umar Khalid RBR18102022CRLA1732022_143522.pdfUmar Khalid RBR18102022CRLA1732022_143522.pdf
Umar Khalid RBR18102022CRLA1732022_143522.pdfsabrangsabrang
 
bom HC judgment Kudale.pdf
bom HC judgment Kudale.pdfbom HC judgment Kudale.pdf
bom HC judgment Kudale.pdfsabrangsabrang
 
Vardarajan crlp(a) 8431 2021
Vardarajan crlp(a) 8431 2021Vardarajan crlp(a) 8431 2021
Vardarajan crlp(a) 8431 2021sabrangsabrang
 
Delhi hc order mohammed zubair
Delhi hc order mohammed zubairDelhi hc order mohammed zubair
Delhi hc order mohammed zubairZahidManiyar
 
Delhi hc judgment dalit man
Delhi hc judgment dalit manDelhi hc judgment dalit man
Delhi hc judgment dalit mansabrangsabrang
 
Cr.WJC No.1238 of 2019(Token no. 45078 of 2019) before Patna High Court dated...
Cr.WJC No.1238 of 2019(Token no. 45078 of 2019) before Patna High Court dated...Cr.WJC No.1238 of 2019(Token no. 45078 of 2019) before Patna High Court dated...
Cr.WJC No.1238 of 2019(Token no. 45078 of 2019) before Patna High Court dated...Om Prakash Poddar
 
Final writ petition_for_filing-pb singh vs. state of maharashtra
Final writ petition_for_filing-pb singh vs. state of maharashtraFinal writ petition_for_filing-pb singh vs. state of maharashtra
Final writ petition_for_filing-pb singh vs. state of maharashtrasabrangsabrang
 
Complaint aginst SHO Kadwa to SHRC Bihar dated 17.11.22.pdf
Complaint aginst SHO Kadwa to SHRC Bihar dated 17.11.22.pdfComplaint aginst SHO Kadwa to SHRC Bihar dated 17.11.22.pdf
Complaint aginst SHO Kadwa to SHRC Bihar dated 17.11.22.pdfOm Prakash Poddar
 

Similar to Writ Petition Criminal Diary Number 18546 of 2022 Part-I .pdf (20)

Madras hc bail caa mar 25 order
Madras hc bail caa mar 25 orderMadras hc bail caa mar 25 order
Madras hc bail caa mar 25 order
 
Gauri lankesh case final slp regarding accused number 6 (1)
Gauri lankesh case   final slp regarding accused number 6 (1)Gauri lankesh case   final slp regarding accused number 6 (1)
Gauri lankesh case final slp regarding accused number 6 (1)
 
Asif iqbal order
Asif iqbal orderAsif iqbal order
Asif iqbal order
 
M.A. D.No.42652 of 2019 in W.P. (Crl) 136 of 2016 before Supreme Court of In...
M.A. D.No.42652 of 2019 in W.P. (Crl) 136 of 2016  before Supreme Court of In...M.A. D.No.42652 of 2019 in W.P. (Crl) 136 of 2016  before Supreme Court of In...
M.A. D.No.42652 of 2019 in W.P. (Crl) 136 of 2016 before Supreme Court of In...
 
Complaint against SHO Tilak Marg Police Station New Delhi to NHRC New Del...
Complaint  against SHO Tilak Marg Police Station  New  Delhi to  NHRC New Del...Complaint  against SHO Tilak Marg Police Station  New  Delhi to  NHRC New Del...
Complaint against SHO Tilak Marg Police Station New Delhi to NHRC New Del...
 
W.p.(c) 5653-2021(main)
W.p.(c) 5653-2021(main)W.p.(c) 5653-2021(main)
W.p.(c) 5653-2021(main)
 
Bail petition dr zafarul islam khan v gnctd through special cell final ecopy
Bail petition dr zafarul islam khan v gnctd through special cell final ecopyBail petition dr zafarul islam khan v gnctd through special cell final ecopy
Bail petition dr zafarul islam khan v gnctd through special cell final ecopy
 
Complaint dated 13.4.2023 against Shelter Homes of Bihar.pdf
Complaint dated 13.4.2023 against Shelter Homes of Bihar.pdfComplaint dated 13.4.2023 against Shelter Homes of Bihar.pdf
Complaint dated 13.4.2023 against Shelter Homes of Bihar.pdf
 
Writ Petition Criminal NO.......of 2017 vide D.NO.3913 against Registrar Supr...
Writ Petition Criminal NO.......of 2017 vide D.NO.3913 against Registrar Supr...Writ Petition Criminal NO.......of 2017 vide D.NO.3913 against Registrar Supr...
Writ Petition Criminal NO.......of 2017 vide D.NO.3913 against Registrar Supr...
 
Writ Petition Criminal NO.......of 2017 vide D.NO.3913 against Registrar Supr...
Writ Petition Criminal NO.......of 2017 vide D.NO.3913 against Registrar Supr...Writ Petition Criminal NO.......of 2017 vide D.NO.3913 against Registrar Supr...
Writ Petition Criminal NO.......of 2017 vide D.NO.3913 against Registrar Supr...
 
Brinda karat and anr. v. state and anr. (defects cleared)
Brinda karat and anr. v. state and anr. (defects cleared)Brinda karat and anr. v. state and anr. (defects cleared)
Brinda karat and anr. v. state and anr. (defects cleared)
 
Umar Khalid RBR18102022CRLA1732022_143522.pdf
Umar Khalid RBR18102022CRLA1732022_143522.pdfUmar Khalid RBR18102022CRLA1732022_143522.pdf
Umar Khalid RBR18102022CRLA1732022_143522.pdf
 
bom HC judgment Kudale.pdf
bom HC judgment Kudale.pdfbom HC judgment Kudale.pdf
bom HC judgment Kudale.pdf
 
Vardarajan crlp(a) 8431 2021
Vardarajan crlp(a) 8431 2021Vardarajan crlp(a) 8431 2021
Vardarajan crlp(a) 8431 2021
 
Delhi hc order mohammed zubair
Delhi hc order mohammed zubairDelhi hc order mohammed zubair
Delhi hc order mohammed zubair
 
Delhi hc judgment dalit man
Delhi hc judgment dalit manDelhi hc judgment dalit man
Delhi hc judgment dalit man
 
Cr.WJC No.1238 of 2019(Token no. 45078 of 2019) before Patna High Court dated...
Cr.WJC No.1238 of 2019(Token no. 45078 of 2019) before Patna High Court dated...Cr.WJC No.1238 of 2019(Token no. 45078 of 2019) before Patna High Court dated...
Cr.WJC No.1238 of 2019(Token no. 45078 of 2019) before Patna High Court dated...
 
Final writ petition_for_filing-pb singh vs. state of maharashtra
Final writ petition_for_filing-pb singh vs. state of maharashtraFinal writ petition_for_filing-pb singh vs. state of maharashtra
Final writ petition_for_filing-pb singh vs. state of maharashtra
 
Complaint aginst SHO Kadwa to SHRC Bihar dated 17.11.22.pdf
Complaint aginst SHO Kadwa to SHRC Bihar dated 17.11.22.pdfComplaint aginst SHO Kadwa to SHRC Bihar dated 17.11.22.pdf
Complaint aginst SHO Kadwa to SHRC Bihar dated 17.11.22.pdf
 
petition 14.6.22.pdf
petition 14.6.22.pdfpetition 14.6.22.pdf
petition 14.6.22.pdf
 

More from Om Prakash Poddar

Reply to Election Commission Delhi in NGS5322435639 dated 25.11.2022.pdf
Reply to Election Commission Delhi in NGS5322435639 dated 25.11.2022.pdfReply to Election Commission Delhi in NGS5322435639 dated 25.11.2022.pdf
Reply to Election Commission Delhi in NGS5322435639 dated 25.11.2022.pdfOm Prakash Poddar
 
Letter dated 27.11.2022 to CJI SC.pdf
Letter dated 27.11.2022  to CJI SC.pdfLetter dated 27.11.2022  to CJI SC.pdf
Letter dated 27.11.2022 to CJI SC.pdfOm Prakash Poddar
 
Office Report dated 26.11.2022 in International Sex Racket matter Writ Petit...
Office Report dated 26.11.2022 in International Sex Racket matter  Writ Petit...Office Report dated 26.11.2022 in International Sex Racket matter  Writ Petit...
Office Report dated 26.11.2022 in International Sex Racket matter Writ Petit...Om Prakash Poddar
 
Office Report dated 28.11.2022 in International Sex Racket matter Writ Petit...
Office Report dated 28.11.2022 in International Sex Racket matter  Writ Petit...Office Report dated 28.11.2022 in International Sex Racket matter  Writ Petit...
Office Report dated 28.11.2022 in International Sex Racket matter Writ Petit...Om Prakash Poddar
 
Complaint dated 26.11.22 against Election Officer Katihar Bihar.pdf
Complaint dated 26.11.22 against Election Officer Katihar Bihar.pdfComplaint dated 26.11.22 against Election Officer Katihar Bihar.pdf
Complaint dated 26.11.22 against Election Officer Katihar Bihar.pdfOm Prakash Poddar
 
Complaint dated 25.11.22 against Election Officer Sahadra Delhi.pdf
Complaint dated 25.11.22 against Election Officer Sahadra Delhi.pdfComplaint dated 25.11.22 against Election Officer Sahadra Delhi.pdf
Complaint dated 25.11.22 against Election Officer Sahadra Delhi.pdfOm Prakash Poddar
 
Additional e-Filed Petition dated 25.06.2022 on Anti-Prostitution before Sup...
Additional e-Filed Petition  dated 25.06.2022 on Anti-Prostitution before Sup...Additional e-Filed Petition  dated 25.06.2022 on Anti-Prostitution before Sup...
Additional e-Filed Petition dated 25.06.2022 on Anti-Prostitution before Sup...Om Prakash Poddar
 
Additional e-Filed Petition dated 07.06.2022 on Anti-Prostitution before Sup...
Additional e-Filed Petition  dated 07.06.2022 on Anti-Prostitution before Sup...Additional e-Filed Petition  dated 07.06.2022 on Anti-Prostitution before Sup...
Additional e-Filed Petition dated 07.06.2022 on Anti-Prostitution before Sup...Om Prakash Poddar
 
E-Filed Petition dated 07.06.2022 on Anti-Prostitution before Supreme Court ...
E-Filed Petition  dated 07.06.2022 on Anti-Prostitution before Supreme Court ...E-Filed Petition  dated 07.06.2022 on Anti-Prostitution before Supreme Court ...
E-Filed Petition dated 07.06.2022 on Anti-Prostitution before Supreme Court ...Om Prakash Poddar
 
Complaint dated 21.11.2022 against Bihar and Delhi police to NHRC.pdf
Complaint dated 21.11.2022 against Bihar and Delhi  police  to NHRC.pdfComplaint dated 21.11.2022 against Bihar and Delhi  police  to NHRC.pdf
Complaint dated 21.11.2022 against Bihar and Delhi police to NHRC.pdfOm Prakash Poddar
 
Complaint aginst Delhi Police to NHRC New Delhi dated 20.11.22.pdf
Complaint aginst  Delhi Police to NHRC New Delhi dated 20.11.22.pdfComplaint aginst  Delhi Police to NHRC New Delhi dated 20.11.22.pdf
Complaint aginst Delhi Police to NHRC New Delhi dated 20.11.22.pdfOm Prakash Poddar
 
Complaint aginst Kadwa Katihar Bihar Police to SHRC Bihar dated 20.11.22.pdf
Complaint aginst  Kadwa Katihar Bihar Police to SHRC Bihar dated 20.11.22.pdfComplaint aginst  Kadwa Katihar Bihar Police to SHRC Bihar dated 20.11.22.pdf
Complaint aginst Kadwa Katihar Bihar Police to SHRC Bihar dated 20.11.22.pdfOm Prakash Poddar
 
Complaint against SHO GRP Anand Vihar Railway Police Station Delhi to NHRC...
Complaint  against SHO GRP Anand Vihar  Railway Police Station Delhi to  NHRC...Complaint  against SHO GRP Anand Vihar  Railway Police Station Delhi to  NHRC...
Complaint against SHO GRP Anand Vihar Railway Police Station Delhi to NHRC...Om Prakash Poddar
 
Complaint against SHO GRP Old Delhi Railway Police Station to NHRC New Del...
Complaint  against SHO GRP Old Delhi Railway Police Station  to  NHRC New Del...Complaint  against SHO GRP Old Delhi Railway Police Station  to  NHRC New Del...
Complaint against SHO GRP Old Delhi Railway Police Station to NHRC New Del...Om Prakash Poddar
 
Complaint against SHO Lahori Gate Police Station Delhi to NHRC New Delhi d...
Complaint  against SHO Lahori Gate  Police Station Delhi to  NHRC New Delhi d...Complaint  against SHO Lahori Gate  Police Station Delhi to  NHRC New Delhi d...
Complaint against SHO Lahori Gate Police Station Delhi to NHRC New Delhi d...Om Prakash Poddar
 
Complaint against SHO Shastri Park Police Station NE Delhi to NHRC New Delh...
Complaint  against SHO Shastri Park Police Station NE Delhi to  NHRC New Delh...Complaint  against SHO Shastri Park Police Station NE Delhi to  NHRC New Delh...
Complaint against SHO Shastri Park Police Station NE Delhi to NHRC New Delh...Om Prakash Poddar
 
Complaint aginst SHO Palam Village New Delhi to NHRC New Delhi dated 17.11.22...
Complaint aginst SHO Palam Village New Delhi to NHRC New Delhi dated 17.11.22...Complaint aginst SHO Palam Village New Delhi to NHRC New Delhi dated 17.11.22...
Complaint aginst SHO Palam Village New Delhi to NHRC New Delhi dated 17.11.22...Om Prakash Poddar
 
Complaint aginst SHO Lahori Gate Delhi to NHRC New Delhi dated 15.11.22.pdf
Complaint aginst SHO Lahori  Gate Delhi to NHRC New Delhi dated 15.11.22.pdfComplaint aginst SHO Lahori  Gate Delhi to NHRC New Delhi dated 15.11.22.pdf
Complaint aginst SHO Lahori Gate Delhi to NHRC New Delhi dated 15.11.22.pdfOm Prakash Poddar
 

More from Om Prakash Poddar (20)

Reply to Election Commission Delhi in NGS5322435639 dated 25.11.2022.pdf
Reply to Election Commission Delhi in NGS5322435639 dated 25.11.2022.pdfReply to Election Commission Delhi in NGS5322435639 dated 25.11.2022.pdf
Reply to Election Commission Delhi in NGS5322435639 dated 25.11.2022.pdf
 
Letter dated 27.11.2022 to CJI SC.pdf
Letter dated 27.11.2022  to CJI SC.pdfLetter dated 27.11.2022  to CJI SC.pdf
Letter dated 27.11.2022 to CJI SC.pdf
 
Office Report dated 26.11.2022 in International Sex Racket matter Writ Petit...
Office Report dated 26.11.2022 in International Sex Racket matter  Writ Petit...Office Report dated 26.11.2022 in International Sex Racket matter  Writ Petit...
Office Report dated 26.11.2022 in International Sex Racket matter Writ Petit...
 
Office Report dated 28.11.2022 in International Sex Racket matter Writ Petit...
Office Report dated 28.11.2022 in International Sex Racket matter  Writ Petit...Office Report dated 28.11.2022 in International Sex Racket matter  Writ Petit...
Office Report dated 28.11.2022 in International Sex Racket matter Writ Petit...
 
Complaint dated 26.11.22 against Election Officer Katihar Bihar.pdf
Complaint dated 26.11.22 against Election Officer Katihar Bihar.pdfComplaint dated 26.11.22 against Election Officer Katihar Bihar.pdf
Complaint dated 26.11.22 against Election Officer Katihar Bihar.pdf
 
Complaint dated 25.11.22 against Election Officer Sahadra Delhi.pdf
Complaint dated 25.11.22 against Election Officer Sahadra Delhi.pdfComplaint dated 25.11.22 against Election Officer Sahadra Delhi.pdf
Complaint dated 25.11.22 against Election Officer Sahadra Delhi.pdf
 
Additional e-Filed Petition dated 25.06.2022 on Anti-Prostitution before Sup...
Additional e-Filed Petition  dated 25.06.2022 on Anti-Prostitution before Sup...Additional e-Filed Petition  dated 25.06.2022 on Anti-Prostitution before Sup...
Additional e-Filed Petition dated 25.06.2022 on Anti-Prostitution before Sup...
 
Additional e-Filed Petition dated 07.06.2022 on Anti-Prostitution before Sup...
Additional e-Filed Petition  dated 07.06.2022 on Anti-Prostitution before Sup...Additional e-Filed Petition  dated 07.06.2022 on Anti-Prostitution before Sup...
Additional e-Filed Petition dated 07.06.2022 on Anti-Prostitution before Sup...
 
E-Filed Petition dated 07.06.2022 on Anti-Prostitution before Supreme Court ...
E-Filed Petition  dated 07.06.2022 on Anti-Prostitution before Supreme Court ...E-Filed Petition  dated 07.06.2022 on Anti-Prostitution before Supreme Court ...
E-Filed Petition dated 07.06.2022 on Anti-Prostitution before Supreme Court ...
 
Complaint dated 21.11.2022 against Bihar and Delhi police to NHRC.pdf
Complaint dated 21.11.2022 against Bihar and Delhi  police  to NHRC.pdfComplaint dated 21.11.2022 against Bihar and Delhi  police  to NHRC.pdf
Complaint dated 21.11.2022 against Bihar and Delhi police to NHRC.pdf
 
Complaint aginst Delhi Police to NHRC New Delhi dated 20.11.22.pdf
Complaint aginst  Delhi Police to NHRC New Delhi dated 20.11.22.pdfComplaint aginst  Delhi Police to NHRC New Delhi dated 20.11.22.pdf
Complaint aginst Delhi Police to NHRC New Delhi dated 20.11.22.pdf
 
Complaint aginst Kadwa Katihar Bihar Police to SHRC Bihar dated 20.11.22.pdf
Complaint aginst  Kadwa Katihar Bihar Police to SHRC Bihar dated 20.11.22.pdfComplaint aginst  Kadwa Katihar Bihar Police to SHRC Bihar dated 20.11.22.pdf
Complaint aginst Kadwa Katihar Bihar Police to SHRC Bihar dated 20.11.22.pdf
 
NHRC cases-2.pdf
NHRC cases-2.pdfNHRC cases-2.pdf
NHRC cases-2.pdf
 
NHRC cases.pdf
NHRC cases.pdfNHRC cases.pdf
NHRC cases.pdf
 
Complaint against SHO GRP Anand Vihar Railway Police Station Delhi to NHRC...
Complaint  against SHO GRP Anand Vihar  Railway Police Station Delhi to  NHRC...Complaint  against SHO GRP Anand Vihar  Railway Police Station Delhi to  NHRC...
Complaint against SHO GRP Anand Vihar Railway Police Station Delhi to NHRC...
 
Complaint against SHO GRP Old Delhi Railway Police Station to NHRC New Del...
Complaint  against SHO GRP Old Delhi Railway Police Station  to  NHRC New Del...Complaint  against SHO GRP Old Delhi Railway Police Station  to  NHRC New Del...
Complaint against SHO GRP Old Delhi Railway Police Station to NHRC New Del...
 
Complaint against SHO Lahori Gate Police Station Delhi to NHRC New Delhi d...
Complaint  against SHO Lahori Gate  Police Station Delhi to  NHRC New Delhi d...Complaint  against SHO Lahori Gate  Police Station Delhi to  NHRC New Delhi d...
Complaint against SHO Lahori Gate Police Station Delhi to NHRC New Delhi d...
 
Complaint against SHO Shastri Park Police Station NE Delhi to NHRC New Delh...
Complaint  against SHO Shastri Park Police Station NE Delhi to  NHRC New Delh...Complaint  against SHO Shastri Park Police Station NE Delhi to  NHRC New Delh...
Complaint against SHO Shastri Park Police Station NE Delhi to NHRC New Delh...
 
Complaint aginst SHO Palam Village New Delhi to NHRC New Delhi dated 17.11.22...
Complaint aginst SHO Palam Village New Delhi to NHRC New Delhi dated 17.11.22...Complaint aginst SHO Palam Village New Delhi to NHRC New Delhi dated 17.11.22...
Complaint aginst SHO Palam Village New Delhi to NHRC New Delhi dated 17.11.22...
 
Complaint aginst SHO Lahori Gate Delhi to NHRC New Delhi dated 15.11.22.pdf
Complaint aginst SHO Lahori  Gate Delhi to NHRC New Delhi dated 15.11.22.pdfComplaint aginst SHO Lahori  Gate Delhi to NHRC New Delhi dated 15.11.22.pdf
Complaint aginst SHO Lahori Gate Delhi to NHRC New Delhi dated 15.11.22.pdf
 

Recently uploaded

AI and Arbitration - Ethical considerations
AI and Arbitration - Ethical considerationsAI and Arbitration - Ethical considerations
AI and Arbitration - Ethical considerationsNino Sievi
 
Navigating the ADA: Case Studies on Reasonable Accommodation
Navigating the ADA: Case Studies on Reasonable AccommodationNavigating the ADA: Case Studies on Reasonable Accommodation
Navigating the ADA: Case Studies on Reasonable AccommodationParsons Behle & Latimer
 
petition against Uboh and new age solar.pdf
petition against Uboh and new age solar.pdfpetition against Uboh and new age solar.pdf
petition against Uboh and new age solar.pdfRikoTenten
 
John Hart in Haverford, PA is a Seasoned Professional
John Hart in Haverford, PA is a Seasoned ProfessionalJohn Hart in Haverford, PA is a Seasoned Professional
John Hart in Haverford, PA is a Seasoned Professionaljohnharthaverford
 
Legislation behind Introduction of Section 43B(h) of Income Tax Act.docx
Legislation behind Introduction of Section 43B(h) of Income Tax Act.docxLegislation behind Introduction of Section 43B(h) of Income Tax Act.docx
Legislation behind Introduction of Section 43B(h) of Income Tax Act.docxAnkurMathur74
 
John Halpern, a co founder of Bain & Company
John Halpern, a co founder of Bain & CompanyJohn Halpern, a co founder of Bain & Company
John Halpern, a co founder of Bain & CompanyJimmyGFlores
 
Types of Security in Industrial Security
Types of Security in Industrial SecurityTypes of Security in Industrial Security
Types of Security in Industrial SecurityRJCubillo
 
Petition against police(2).pdf
Petition against police(2).pdfPetition against police(2).pdf
Petition against police(2).pdfRikoTenten
 
USE OF DATA AND ANALYTICS IN HUMANITARIAN DECISION MAKING.pptx
USE OF DATA AND ANALYTICS IN HUMANITARIAN DECISION MAKING.pptxUSE OF DATA AND ANALYTICS IN HUMANITARIAN DECISION MAKING.pptx
USE OF DATA AND ANALYTICS IN HUMANITARIAN DECISION MAKING.pptxNilendra Kumar
 
The Transfer pricing agreements in the Cooperative Compliance Environment
The Transfer pricing agreements in the Cooperative Compliance EnvironmentThe Transfer pricing agreements in the Cooperative Compliance Environment
The Transfer pricing agreements in the Cooperative Compliance EnvironmentUniversity of Ferrara
 
Humanitarian Protection, Modern Technology amidst Global Threats
Humanitarian Protection, Modern Technology amidst Global ThreatsHumanitarian Protection, Modern Technology amidst Global Threats
Humanitarian Protection, Modern Technology amidst Global ThreatsNilendra Kumar
 
Patrick Kelly Hoboken's Dedication to Justice
Patrick Kelly Hoboken's Dedication to JusticePatrick Kelly Hoboken's Dedication to Justice
Patrick Kelly Hoboken's Dedication to JusticePatrick Kelly Hoboken
 

Recently uploaded (12)

AI and Arbitration - Ethical considerations
AI and Arbitration - Ethical considerationsAI and Arbitration - Ethical considerations
AI and Arbitration - Ethical considerations
 
Navigating the ADA: Case Studies on Reasonable Accommodation
Navigating the ADA: Case Studies on Reasonable AccommodationNavigating the ADA: Case Studies on Reasonable Accommodation
Navigating the ADA: Case Studies on Reasonable Accommodation
 
petition against Uboh and new age solar.pdf
petition against Uboh and new age solar.pdfpetition against Uboh and new age solar.pdf
petition against Uboh and new age solar.pdf
 
John Hart in Haverford, PA is a Seasoned Professional
John Hart in Haverford, PA is a Seasoned ProfessionalJohn Hart in Haverford, PA is a Seasoned Professional
John Hart in Haverford, PA is a Seasoned Professional
 
Legislation behind Introduction of Section 43B(h) of Income Tax Act.docx
Legislation behind Introduction of Section 43B(h) of Income Tax Act.docxLegislation behind Introduction of Section 43B(h) of Income Tax Act.docx
Legislation behind Introduction of Section 43B(h) of Income Tax Act.docx
 
John Halpern, a co founder of Bain & Company
John Halpern, a co founder of Bain & CompanyJohn Halpern, a co founder of Bain & Company
John Halpern, a co founder of Bain & Company
 
Types of Security in Industrial Security
Types of Security in Industrial SecurityTypes of Security in Industrial Security
Types of Security in Industrial Security
 
Petition against police(2).pdf
Petition against police(2).pdfPetition against police(2).pdf
Petition against police(2).pdf
 
USE OF DATA AND ANALYTICS IN HUMANITARIAN DECISION MAKING.pptx
USE OF DATA AND ANALYTICS IN HUMANITARIAN DECISION MAKING.pptxUSE OF DATA AND ANALYTICS IN HUMANITARIAN DECISION MAKING.pptx
USE OF DATA AND ANALYTICS IN HUMANITARIAN DECISION MAKING.pptx
 
The Transfer pricing agreements in the Cooperative Compliance Environment
The Transfer pricing agreements in the Cooperative Compliance EnvironmentThe Transfer pricing agreements in the Cooperative Compliance Environment
The Transfer pricing agreements in the Cooperative Compliance Environment
 
Humanitarian Protection, Modern Technology amidst Global Threats
Humanitarian Protection, Modern Technology amidst Global ThreatsHumanitarian Protection, Modern Technology amidst Global Threats
Humanitarian Protection, Modern Technology amidst Global Threats
 
Patrick Kelly Hoboken's Dedication to Justice
Patrick Kelly Hoboken's Dedication to JusticePatrick Kelly Hoboken's Dedication to Justice
Patrick Kelly Hoboken's Dedication to Justice
 

Writ Petition Criminal Diary Number 18546 of 2022 Part-I .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 CRL. M.P. NO. OF 2022 APPLICATION FOR SEEKING EXEMPTION FROM FILING ATTESTED COPY OF AFFIDAVIT CRL. M.P. NO. OF 2022 APPLICATION FOR EARLY HEARING/URGENT HEARING PAPER BOOK (FOR INDEX KINDLY SEE INSIDE) VOLUM/PART-01 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 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-M 8. Writ Petition (Criminal) with Affidavit 1-59 9. Annexure: P-1 True copy of order dated 09th February, 2011 by Principle Judge, Family Court, Dwarka Court at New Delhi in HMA-700/2010 case 60 10. Annexure: P-2 True copy of photographs of minor daughter Shriya Poddar dated 09th February, 2011 at children’s room at Family Court, Dwarka Court at New Delhi in HMA-700/2010 case 61 11. Annexure: P-3 True copy of signed copy of police complaint against sex abusers state through email letter dated 07th May 2022 by petitioner to all nodal police officers of Bihar and NCT of Delhi 62-63 12. Annexure: P-4 True copy of signed copy of police complaint against sex abusers state through email letter dated 08th May 2022 by petitioner to all nodal police officers of Bihar and NCT of Delhi 64-64 13. Annexure: P-5 True copy of signed copy of police complaint against sex abusers state through email letter dated 10th May 65-66
  • 3. 3 2022 by petitioner to all nodal police officers of Bihar and NCT of Delhi 14. Annexure: P-6 True copy of signed copy of police complaint against sex abusers state through email letter dated 11th May 2022 by petitioner to all nodal police officers of Bihar and NCT of Delhi 67 15. Annexure: P-7 True copy of signed copy of police complaint against sex abusers state through email letter dated 12th May 2022 by petitioner to all nodal police officers of Bihar and NCT of Delhi 68 16. Annexure: P-8 True copy of signed copy of police complaint against sex abusers state through email letter dated 13th May 2022 by petitioner to all nodal police officers of Bihar and NCT of Delhi 69 17. Annexure: P-9 True copy of signed copy of police complaint against sex abusers state through email letter dated 14th May 2022 by petitioner to all nodal police officers of Bihar and NCT of Delhi 70 18. Annexure: P-10 True copy of signed copy of police complaint against sex abusers state through email letter dated 15th May 2022 by petitioner to all nodal police officers of Bihar and NCT of Delhi 71 19. Annexure: P-11 True copy of signed copy of police complaint against sex abusers state through email letter dated 16th May 2022 by petitioner to all nodal police officers of Bihar and NCT of 72-74
  • 4. 4 Delhi 20. Annexure: P-12 True copy of signed copy of police complaint against sex abusers state through email letter dated 17th May 2022 by petitioner to all nodal police officers of Bihar and NCT of Delhi 75-76 21. Annexure: P-13 True copy of signed copy of police complaint against sex abusers state through email letter dated 18th May 2022 by petitioner to all nodal police officers of Bihar and NCT of Delhi 77-78 22. Annexure: P-14 True copy of signed copy of police complaint against sex abusers state through email letter dated 19th May 2022 by petitioner to all nodal police officers of Bihar and NCT of Delhi 79-81 23. Annexure: P-15 True copy of signed copy of police complaint against sex abusers state through email letter dated 20th May 2022 by petitioner to all nodal police officers of Bihar and NCT of Delhi 82-83 24. Annexure: P-16 True copy of signed copy of police complaint against sex abusers state through email letter dated 22nd May 2022 by petitioner to all nodal police officers of Bihar and NCT of Delhi 84-85 25. Annexure: P-17 True copy of signed copy of police complaint against sex abusers state through email letter dated 24th May 2022 by petitioner to all nodal police officers of Bihar and NCT of Delhi 86-87 26. Annexure: P-18 88-89
  • 5. 5 True copy of signed copy of police complaint against sex abusers state through email letter dated 26th May 2022 by petitioner to all nodal police officers of Bihar and NCT of Delhi 27. Annexure: P-19 True copy of signed copy of police complaint against sex abusers state through email letter dated 27th May 2022 by petitioner to all nodal police officers of Bihar and NCT of Delhi 90-91 28. Annexure: P-20 True copy of signed copy of police complaint against sex abusers state through email letter dated 28th May 2022 by petitioner to all nodal police officers of Bihar and NCT of Delhi 92-93 29. Annexure: P-21 True copy of signed copy of police complaint against sex abusers state through email letter dated 29th May 2022 by petitioner to all nodal police officers of Bihar and NCT of Delhi 94-95 30. Annexure: P-22 True copy of signed copy of police complaint against sex abusers state through email letter dated 31st May 2022 by petitioner to all nodal police officers of Bihar and NCT of Delhi 96-97 31. Annexure: P-23 True copy of signed copy of police complaint against sex abusers state through email letter dated 1st June, 2022 by petitioner to all nodal police officers of Bihar and NCT of Delhi 98-99 32. Annexure: P-24 True copy of signed copy of police complaint against sex abusers state 100- 101
  • 6. 6 through email letter dated 2nd June, 2022 by petitioner to all nodal police officers of Bihar and NCT of Delhi 33. Annexure: P-25 True copy of signed copy of police complaint against sex abusers state through email letter dated 3rd June, 2022 by petitioner to all nodal police officers of Bihar and NCT of Delhi 102- 103 34. Application for seeking permission to appear and argue the Writ Petition (Criminal) in person along with supporting affidavit. 104- 108 35. Application for seeking exemption from filing attested copy of Affidavit along with supporting affidavit. 109- 113 36. Application for early hearing along with supporting affidavit. 114- 119 37. Filing Index 38. Memo of Appearance 39. I.D.Proof
  • 7. 7 ‘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: PREVIOUSLY LISTED BENCH NOT TO BE LISTED 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
  • 8. 8 (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
  • 9. 9 (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: 07-06-2022
  • 10. 10 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 Petitioner-In-Person cum Whistle Blower cum husband cum Father cum Guardian of rescued victims of Gang Rapes, flesh trade, hidden prostitution, illicit sex trade, child sexual abuse and international human trafficking rescued with an active help of this Hon’ble Court in Writ Petition (Criminal) 242 of 2021 and Writ Petition (Criminal) 137 of 2021 (victims rescued from the brothels of Varanasi, G.B. Road Delhi and Shastri Park North East Delhi boarded at Delhi in Mahananda Express Train on 05-05-2022 along with petitioner’s PNR No.260-2313501 and de-boarded at katihar railway station on 06-05-2022 along with near about 50 family members of petitioner and their minor children including his own wife, minor daughter. Sisters, sister-in-law and their minor children) but unfortunately not being placed before court of law, not being initiated rehabilitation process either within state’s institutions like women shelter house, children’s observation homes or within family or not being initiated handing over procss to the petitioner either by Magistrate Katihar or by Delhi Rail Police or by Katihar Rail Police or by the Child Line Kolkotta, Dhanbad, Patna, Samastipur, Begusarai, Purnea, Katihar etc and being re-pushed into the same business of flesh trade at the source point of human trafficking at Sonaili village, district Katihar
  • 11. 11 Bihar; aggrieved by this delinquent behavior, arbitrary action of the state, rampant unlawful detention of petitioner by Delhi and Bihar Police for blowing whistle against the persistent Gang Rapes and illicit sex trade of rescued victims w.e.f 06.05.2022 to till date by the nexus of State, NGOs, Gangsters, Mafias and Indian Defense organizations in front of his own house at Asha Deep Niwas, Sonaili, P.S. Kadwa, Katihar, Bihar and in front of his own eyes and for the enforcement of the Rights under Article 21 of the Constitution of India. 02.05.2022 Order passed by the bench of Hon’ble Sanjay Kishan Kaul in W.P.(Crl) 137/2021 by this Hon’ble Court, victims of illicit sex trade and child sexual abuse being rescued trafficked to Katihar Bihar but not handed over to the petitioner but being taken into the custody of sex abusers cum pimps accompanying lady magistrate of katihar. She re-pushed the victims into the same business of flesh trade at the source point of human trafficking at sonaili village at katihar Bihar and organized gang rapes of the victims persistently from 06.05.2022 to till date at various locations for generating revenue out of it. More than 50 female members, their children including petitioner’s minor daughter and his wife are in the list of victims.
  • 12. 12 06.05.2022 Victims of gang rapes and illicit sex trade (Petitioner’s near about 50 family members and their children) are being rescued from the different brothels of India like Shastri Park, North East Delhi, G.B.Road Delhi, Varanasi, Gulabbag Purnea, Sonagachhi Kolkatta and departed by Mahananda Express on 05.05.2022 from Old Delhi Railway Station to Katihar on 06.05.2022. But rescued victims not being handed over to the petitioner either by Delhi Rail Police or by Katihar Rail Police till date instead organizing the events of gang rapes and illicit sex trade every day and night at the source point of human trafficking at Sonaili Village P.S. Kadwa, at Katihar Bihar since then. 11.05.2022 That petitioner tried to stop this nonsense in one of the gang rape events of his wife and minor daughter in front of his house at sonaili p.s. kadwa on 11.05.2022 but being thrashed, beaten and injured by the group of sex abusers Shekhar Gupta R/O Sonaili P.S.Kadwa, Katihar. 12.05.2022 An attempt was taken to murder the petitioner in (W.P.(Crl.) 137/2021-PIL) by a team of Government Doctors and missionaries sisters (sex abusers and international sex racketeers) through administering inappropriate drugs and taking blood sample inappropriately on 12th
  • 13. 13 May vide registration no. 2529 at 12:30PM at Sadar Hospital Katihar, Bihar 16.05.2022 That petitioner has submitted 3 pages application along with phone numbers of the victims to Child Railway coordinator and Child coordinator katihar on 16.05.2022 at child line booth at plat farm no.02 Katihar Railway Station for rescue and hand over of victims to the petitioners. That the petitioner has submitted complaints along with photographs of the victims to Child Line India Foundation, NGO vide registration no. 20220516080001 dated 16.05.2022. 17.05.2022 That the petitioner has submitted complaints along with photographs of the victims to Chairperson of NCPCR vide complaint numbers 202200004880. 11:00am, petitioner has informed the katihar Child line Railway coordinator Praveen Kumar and child line district coordinator Pradeep Kumar that the victims are again being gang raped on 16.05.2022 night even after submitting 3 pages application to the Child line katihar on 16.05.2022 at 12.30 pm. Gang rapes organized in front of petitioner’s house at sonaili shukkar hatt p.s. kadwa. Gang Rapist are Bikesh Sahni son of Bisheshwar Sahni, Gyanchand Sah, Ramashish mahto ram karan
  • 14. 14 mahto and ex-Army man Kapil deo mahto, all are resident of sonaili p.s. kadwa katihar 18.05.2022 That the petitioner has submitted complaints along with photographs of the victims to Child Line India Foundation, NGO vide registration no. 20220518073646 dated 18.05.2022 20.05.2022 SHO Kadwa and SI Binod Singh called the petitioner to the police station Kadwa 5 km away from the house of petitioner in the pretext of handing over his family members to him. Misled petitioner and illegally detained him for three hours at Kadwa police station and gang raped his families breaking the lock of his house at sonaili situated 5 km away from Kadwa Police Station on at 7:30 pm to 11:00pm. 22.05.2022 That petitioner caught the victim at plat farm no.03 and shouted for help from child line katihar railway station over phone. Victim was in black burka led by Maulanas, Muslim women and children. Ironically instead of rescue, child line has given safe passage to the human traffickers. Petitioner’s house is being planted with a battery bomb by the sex racketeers, gang rapist and sex abusers.
  • 15. 15 23.05.2022 In spite of alarm to all nodal police officers and child line NGOs across country; petitioner is being attacked by a women human trafficker. She dragged and broke his shirt’s button and managed to escape the victims. Child line team member sumit kumar again has given safe passage to the human trafficker. The victim of child sexual abuse and Gang Rape is being again trafficked. Human Trafficker was able to do this job with an active help of a group of human trafficker in presence of Sumit Kumar, Team Member of Child Line Katihar in front of India Family Mart Mall Katihar at around 11:00 AM. The petitioner alarmed the same to all nodal police officers of NCT of Delhi and Bihar through SMS. 24.05.2022 at 19:00pm “victim not handed over, artificial rain caused for gang rapes and illicit sex trade at Mahmood Chowk D.S. College katihar, khatu shyam, argara chowk, hotels of katihar inside toilet, power engine, driver’s cabin of local trains, RPF room, RMS room, SSE LOCO Office at plat farm no.03, inside bed roll room, canteen room at plat farm no.03 katihar railway station. At 10:00pm “victims trafficked back by traffic rail Police from katihar to sonaili P.S. Kadwa through bullet bike or other vehicles near to kapil dev mahto’s house, Dhruv
  • 16. 16 Razak & other hot spot areas of sonaili” for gang rapes”. 25.05.2022 at around 11:00 AM a group of human traffickers and sex abusers like ravi rai s/o ambika rai, ram chander sahni, wife of lakhan sahni, gultan sahni neighbors from eastern side attacked the applicant with vulgar abuse and pelted stone at him and on his roof where he was standing to keep vigil on his victim minor daughter’s activities hidden inside the house of Dhruv Razak S/o Ram Narayan Razak VRS employee from railway katihar. He is northern end neighbor of applicant. That the applicant watched the event of gang rapes till 11:45AM. at 12:00pm “victim is inside Dhruv Razak, Rupak Raazak, Ravi Razak, Ritesh Razak, Sonu, Monu S/O Grand/S/O late Ram Narayan Razak house at shukkar hatt sonaili, P.S. Kadwa, traffic rail police dropped her here in the night for Gang Rape and illicit sex trade, watched till 11:45 AM, thereafter trafficked by human trafficker for further sexual abuse”. “victim’s new born baby’s body packed by Bechan Poddar and his family in white plastic bag to hide identities or keep her inside house”. 26.05.2022 aggrieved by the delinquent behavior of Pradeep Kumar child line coordinator katihar and persistent gang rapes illicit sex trade of victims
  • 17. 17 every day and night, the applicant has registered a fresh complaint with NCPCR vide 202200004897 and with child line vide 20220526122245. 27.05.2022 at 08:44 am “there is a plan to ignite katihar bihar for communal violence in the pretext of gang rapes and illicit sex trade of petitioner’s hindu families members by 46% muslims in this region. Wanted to make katihar bihar as seelampur north east delhi. The victim of gang rape and illicit sex trade herself approached the petitioner at plat farm no.02 katihar railway station at 02:00pm dated 27.05.2022 in the pretext of enquiring Araria district bound train at Katihar Railway Station. She was in black burka garment dresses along with two beggar women. petitioner immediately identified the victim and rang the Commissioner of Police Delhi Head Quarter to intervene into the matter of human trafficking at source point Katihar railway station, stop them from trafficking to Araria Nepal boarder, raid, rescue and hand over the victims to the applicant immediately. Instead of rescue, Commissioner Police Delhi along with DGP Bihar organized gang rapes of the victims. 28.05.2022 At 19:30 pm “Lock of the main gate of Asha Deep Niwas, Sonaili village, P.S. Kadwa is
  • 18. 18 being broken by the sex abusers and organized gang rapes of the victims inside the house premises of applicant. Hidden prostitution and illicit sex trade at neighbor Bechan Poddar’s house. He is doing so by opening window towards petitioner’s house premises. Situation is violent at Asha Deep Niwas, Sonaili village, P.S. Kadwa, Katihar Bihar. 29.05.2022 at 06:01am “illicit sex trade, hidden prostitution, child sexual abuse and human trafficking by the surrounding neighbors around petitioner’s house at Asha Deep Niwas, Sonaili village, P.S. Kadwa, Katihar Bihar since 18 years. Petitioner’s 50 siblings, sister in laws and their respective children including his wife, minor Daughter hijacked and pushed into this business. Raid, rescue, medical and charge sheet before court of law otherwise petitioner will move against Bihar Police and Delhi Police before Supreme Court of India with fresh Writ criminal case within one or two days, Om Prakash poddar, social worker to all the nodal police officers of Delhi and Bihar. 30.05.2022 DGP Bihar being informed at 19:00pm for the possibility of gang rape tonight yet sex abusers SHO Kadwa along with Indian Army approached the petitioner at his house at 21:20pm sonaili village katihar misbehaved and
  • 19. 19 gang raped his minor daughter and all family members disconnecting whole village electricity continuously throughout the night. 31.05.2022 despite of receiving information disclosing cognizable offence of gang rapes inside the katihar bound telta train from sonaili railway station to Dandkhora railway station to unnecessarily stopping at outer signal near to K.B.Jha college, SHO Katihar Rail, Jyoti Prakash and SP Katihar Rail Avinash Kumar did not bother to come at plat farm no. 01 of katihar railway station to raid and rescue the victims of gang rapes rather given safe passage to sex abuser, human trafficker, driver of Telta Passenger train at 11:45 AM on 31.05.2022. Petitioner is being attacked by sex abusers railway staff as well as by the general public at Dandkhora Railway station for monitoring the activities of sex abusers inside power engine of Telta passenger train at 11:00 AM on 31.05.2022. Protest events being organized by the petitioner in front of power engine of driver and driver of the train called on RPF security and Dandkhora Railway Station Master through his official wireless mobile set on the same day. 01.06.2022 State of Bihar and others attempted to murder the petitioner, looted his valuable assets like original property documents while petitioner was
  • 20. 20 sleeping inside his house ASHA DEEP NIWAS, shukkar hatt, sonaili, P.S.Kadwa, Katihar in order to generate revenue, are continued gang- rape of the families of the petitioner and conspired to murder him to convert his house into a brothel. 02.06.2022 Direction sought from Home Secretary Ministry of Home Affairs, Government of India to register an F.I.R against the cognizable offence commissioned by Child Line Kolkotta Regional Center, Child Line National center Mumbai, Child Line katihar, Child Line Samastipur, Chairperson NCPCR, SP Rail Katihar, SP Civil Katihar, DRM Katihar, District administration Katihar and State of Bihar and others for continuing Gang Rapes of applicant’s families for consecutively 28 days after rescue of the victims from Delhi at the source point of human trafficking at Sonaili Village, P.S. Kadwa, Katihar rescued by the order of Supreme Court of India in W.P.(Crl.) 137/2021-PIL & W.P.(Crl.) 242/2021 03.06.2022 Direction sought from Home Secretary Ministry of Home Affairs, Government of India to register an F.I.R against the cognizable offence commissioned by Ms. Indu Sinha, Justice S.B. Sinha of Supreme Court of India, Manoj Sinha
  • 21. 21 Governor of J&K, Jayan Sinha ex cabinet minister government of India, Praveen Kumar Indian Defense Account Service, Amarnath Sinha, NGO owner at Sonaili P.S. Kadwa and State of Bihar and others for continuing Gang Rapes of applicant’s families for consecutively 29 days after rescue of the victims from Delhi at the source point of human trafficking at Sonaili Village, P.S. Kadwa, Katihar rescued by the order of Supreme Court of India in W.P.(Crl.) 137/2021-PIL & W.P.(Crl.) 242/2021 - 04.06.2022 Gang Rapes and illicit sex trade of the victims minor girls/daughter (collecting revenue by selling symbolic “Lichhi” a seasonal fruit) continued at P.S Kadwa Katihar, Bihar after raping her at J.N.U New Delhi on 26.05.2022 and 27.05.2022 causing artificial rain, cloudy weather, performing vulgar DJ dance by the victims. Sonaili Railway station in P.S. Kadwa katihar district of Bihar is being identified as source point of human trafficking and the hub for illicit sex trade and Sunil Bubna’s house and its surrounding areas, households, shops are being identified as brothels. 05.06.2022 Katihar administration and state of Bihar and others have tried to obstruct the way of applicant from reaching Supreme Court of India
  • 22. 22 on 05.06.2022 at 5:45PM 06.06.2022 Delhi Police has given safe passage to Human trafficker to traffic minor daughter of petitioner on 06.06.2022 at 22:30pm from Anand Vihar Railway Station Delhi. 07.06.2022 Hence this Criminal Writ Petition.
  • 23. 23 IN THE SUPREME COURT OF INDIA CRIMINAL ORIGINAL JURISDICTION WRIT PETITION CRIMINAL NO. OF 2022 (UNDER ARTICLE 32 OF THE CONSTITUTION OF INDIA) AND IN THE MATTER OF RE-PUSHING THE RESCUED VICTIMS OF ILLICIT SEX TRADE AND CHILD SEXUAL ABUSE INTO THE SAME BUISNESS OF GANG RAPES GENERATING REVENUE OUT OF IT AT THE SOURCE POINT OF HUMAN TRAFFICKING AND ABUSE OF POWER BY STATES, NGOS, GANGSTERS AND INDIAN DEFENSE ORGANIZATIONS 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 C/O Inder Pal 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 Katihar, Bihar 5. District Judge ….RESPONDENT No.05
  • 24. 24 District Court Katihar Bihar 6. Public Prosecutor ….RESPONDENT No.06 District Court Katihar Bihar 7. Commissioner of Police Delhi ….RESPONDENT No.07 Police Headquarters, MSO Building, I.P. Estate, New Delhi-110002 8. Director General of Police ….RESPONDENT No.08 Bihar Police Headquarters, Sardar Patel Bhawan, Nehru Marg, Patna - 800023 9. Inspector General of Police, ….RESPONDENT No.09 Darbhanga, Bihar 10. Deputy Inspector General of Police ….RESPONDENT No.10 Purnia, Bihar 11. Superintendent of Police ….RESPONDENT No.11 District- Katihar, Bihar-854105 12.Deputy Commissioner of Police ….RESPONDENT No.12 North East District Delhi 13.Assistant Commissioner of Police ….RESPONDENT No.13 Seelampur, North East District Delhi 14.Assistant Commissioner of Police ….RESPONDENT No.14 Delhi Cantt. South West District Delhi New Delhi 15.Secretary ….RESPONDENT No.15 Electricity Department Government of Bihar 16.Chief Executive Engineer ….RESPONDENT No.16 Electricity Department District Katihar, Bihar 17.Junior Executive Engineer ….RESPONDENT No.17 Sub-Station Sonaili, Kadwa Electricity Department District Katihar, Bihar 18.Secretary Health Department ….RESPONDENT No.18
  • 25. 25 Patna, Government of Bihar 19.Civil Surgeon ….RESPONDENT No.19 Health Department District Katihar, Bihar 20.In-charge Medical Officer ….RESPONDENT No.20 Kadwa, Primary Health Centre Durgagunj, District Katihar 21.Sub Divisional Manager ….RESPONDENT No.21 Barsoi, Katihar 22. Sub-Divisional Police Officer ….RESPONDENT No.22 Head Quarter District-Katihar, Bihar- 854105 23. Sub-Divisional Police Officer ….RESPONDENT No.23 Barsoi, District Katihar, Bihar- 855102 24.Station House Officer ….RESPONDENT No.24 Palam Village Police Station, South West District New Delhi 25. Station House Officer ….RESPONDENT No.25 Kadwa Police Station, District-Katihar, Bihar-855114 26.Station House Officer ….RESPONDENT No.26 Shastri Park, North East District Delhi 27.Station House Officer ….RESPONDENT No.27 Dandkhora, Katihar Bihar 28. Chairperson ….RESPONDENT No.28 National Commission for Protection of Child Rights (NCPCR) 5th Floor, Chanderlok Building, 36 Janpath, New Delhi-110001 29. Nodal Coordinator ….RESPONDENT No.29 ChildLine India Foundation Eastern Regional Resource Centre Kolkotta 30. Nodal Coordinator ….RESPONDENT No.30
  • 26. 26 ChildLine India Foundation North Regional Resource Centre 1st Floor, H. No. 144/2, Hari Nagar Mathura Road, Ashram, New Delhi-14 31. Child line Railway Coordinator …..,.RESPONDENT No.31 Katihar, Plat Farm No.02, Katihar Railway Station, Bihar 32. SP Railway Delhi …..,.RESPONDENT No.32 Old Delhi Railway Station Delhi 33. SP Railway Katihar …..,.RESPONDENT No.33 Katihar Railway Station Bihar 34. SHO Railway Police, …..,.RESPONDENT No.34 Plat Farm No.02 Katihar Railway Station Bihar 35. Indian Defense Organizations …..,.RESPONDENT No.35 Army, Navy and Air Force Head Quarters at New Delhi 36. Divisional Rail Manager …..,.RESPONDENT No.36 Eastern Frontier Rail Division Katihar Railway Station District Katihar, Bihar 37. Director …..,.RESPONDENT No.37 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 38. Director …..,.RESPONDENT No.38 Child Line India Foundation B-1101, 11th Floor, Ratan Central Dr, Baba Saheb Ambedkar Road Parel East, Mumbai-400012 39. Child Line Coordinator …..,.RESPONDENT No.39 District Samastipur, Bihar 40. Chairman …..,.RESPONDENT No.40 Railway Board, Rail Bhawan
  • 27. 27 New Delhi-1 WRIT 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 Petitioner-In-Person cum Whistle Blower cum husband cum Father cum Guardian of rescued victims of Gang Rapes, flesh trade, hidden prostitution, illicit sex trade, child sexual abuse and international human trafficking rescued with an active help of this Hon’ble Court in Writ Petition (Criminal) 242 of 2021 and Writ Petition (Criminal) 137 of 2021 (victims rescued from the brothels of Varanasi, G.B. Road Delhi and Shastri Park North East Delhi boarded at Delhi in Mahananda Express Train on 05-05-2022 along with petitioner’s PNR No.260-2313501 and de-boarded at katihar railway
  • 28. 28 station on 06-05-2022 along with near about 50 family members of petitioner and their minor children including his own wife, minor daughter. Sisters, sister-in-law and their minor children) but unfortunately not being placed before court of law, not being initiated rehabilitation process either within state’s institutions like women shelter house, children’s observation homes or within family or not being initiated handing over procss to the petitioner either by Magistrate Katihar or by Delhi Rail Police or by Katihar Rail Police or by the Child Line Kolkotta, Dhanbad, Patna, Samastipur, Begusarai, Purnea, Katihar etc and being re-pushed into the same business of flesh trade at the source point of human trafficking at Sonaili village, district Katihar Bihar; aggrieved by this delinquent behavior, arbitrary action of the state, rampant unlawful detention of petitioner by Delhi and Bihar Police for blowing whistle against the persistent Gang Rapes and illicit sex trade of rescued victims w.e.f 06.05.2022 to till date by the nexus of State, NGOs, Gangsters, Mafias and Indian Defense organizations in front of his own house at Asha Deep Niwas, Sonaili, P.S. Kadwa, Katihar, Bihar and in front of his own eyes and for the enforcement of the Rights under Article 21 of the Constitution of India. (ii) That the petitioner has noticed that the International sex business/racket is prevailing in the source point of Human
  • 29. 29 Trafficking at Sonaili, Katihar Bihar since 1978. (iii) The petitioner is an eye witness of a child sexual abuse case by Guptaji, a teacher posted at Kadwa Middle School, P.S. Kadwa, katihar, Bihar while his father was posted as Head Master in that school in 1978. Father blown a Whistle against sex abuser teacher before District Magistrate Katihar but father was being thrashed, beaten and severely caused head injury by Bhola Viswash, then Member of Parliament and his associates like Vishwanath Das a sex abuser teacher posted at Kadwa Middle School, Mukti nath Jha, Amar Nat Jha, Krityanand Jha, Laddu Jha, Kamal nath Jha in the morning of severe cold at around 4:00 AM. Father, mother along with 5 year old petitioner approached the SHO Kadwa with a bleeding head of father but no F.I.R was being registerd by the then SHO, Kadwa. Matter being suppressed and sex business was being escalated in that vicinity. (iv) That the petitioner has noticed that his family members are victim of International sex business/racket since 1978. (v) That petitioner’s elder sister Sneh Lata is being picked up by human traffickers/sex racketeers from R.N.D.B High School Sonaili and being pushed into child sexual abuse, illicit sex trade, hidden prostitution by Kuber Bhagat, Rupak Razak, Vishwajeet Poddar, Naresh Gupta, Dhiren Gupta, Ram Jatan Singh, Ram Kalyan Singh, Birender Singh, Ramadhar Singh a teacher posted at R.N.D.B High
  • 30. 30 School Sonaili, SP Saroj Das, Army man Kapil Dev Mahto Army man R/O Sonaili, Katihar. She conceived a baby at the age of 15 years and baby was being aborted illegally by these sex abusers/sex racketeers. (vi) That Petitioner’s middle sister Pushp Lata is being picked up by human traffickers/sex racketeers from R.N.D.B High School Sonaili and being pushed into child sexual abuse, illicit sex trade, hidden prostitution by Rama Mahto S/O Sibu mahto R/O Sonaili, Katihar way back in 1986. (vii) That Petitioner’s younger sister Padmaja Kumari alis Likhiya is being picked up by human traffickers/sex racketeers from A.L.High School Sonaili and being pushed into child sexual abuse, illicit sex trade, hidden prostitution by a teacher Ramesh Sah, Sukhdev Sah, Son of Makhan Sah, Dilip Nunia S/O Jyotish Nunia , Bihari Lal Bubna S/O Vasudev Bubna, Akhilesh Vishwas S/O Chhedi Vishwas, Manish Singh S/O Ram Kalyan Singh, Dilip Chaudhry S/O Siwanan Chaudhry, Sanjay Gupta, Bablu Gupta S/O Ashwani Mukhiya, Naresh Gupta, all son of Baikunth Gupta, all son of Ram Narayan Razak R/O Sonaili, Katihar way back in 1988. (viii) That all four daughters and their kids of Leela Nand Poddar and Kalanand Poddar, maternal uncles of petitioner R/O Sonaili Katihar have been picked up by human traffickers/sex racketeers from school and being pushed into the business of flesh trade way back in 1980s.
  • 31. 31 (ix) That all daughters and their kids of Bindeswari Poddar, uncles of petitioner R/O Gandhi Nagar Purnea have been picked up by human traffickers/sex racketeers from school and being pushed into the business of flesh trade way back in 1980s. (x) That all daughters and their kids of Harish Chander Poddar, uncles of petitioner R/O Barauni, Begusarai have been picked up by human traffickers/sex racketeers from school and being pushed into the business of flesh trade way back in 1986. (xi) That all daughters of Surender Narayan Poddar, father in law of petitioner R/O Barauni Refinery Township IOCL, Begusarai viz. Rina Kumari, Anuja Kumari alias Annu, Rupam Kumari alias Dolly and their kids have been picked up by sex abusers, sex racketeers, mafia gangsters and being pushed into the business of flesh trade way back in 2005. (xii) That petitioner is eye witnessed of the naked dance of State, NGOs, Gangsters, Mafia and Indian Defense Organizations against the rescued victims of flesh trade from Delhi since 06.05.2022 to till date at the source point of human trafficking at Sonaili, P.S.Kadwa, Katihar with great pump and show added by vulgar DJ dance every day and night. (xiii) That the victim is own family members of petitioner viz Wife Rina Kumari age about 44 years and daughter Shriya
  • 32. 32 Poddar age about 17 years are being repeatedly sold in the market of flesh trade in front of his own eyes and in front of his own house Asha Deep Niwas, Sonaili, P.S. Kadwa, Katihar Bihar through the system of registry for short stay in the house of sex abuser, performing shots for oral sex, anal sex and vaginal sex, aborting babies, conceiving babies, performing sex during tours and travels, sex during picnics, celebrations, sex through hotels booking, organizing events of Gang Rape in the name of “marriage ceremony” and inviting sex abusers in the name of “Baaraati” with great pump and show by an erotic vulgar strong beat songs of DJ, collecting revenue by selling “Licchi” a seasonal fruits in the market and in the each households of vicinity, sex attending at SPA, sex in Wellness centers, sex with Massage center etc. (xiv) That child line complaint reference numbers are 20220516080001 dated 16th May 2022 and 20220518073646 dated 18th May 2022. (xv) That sex racketeer and human trafficker has been figured out on 06.05.2022 night itself yet specifically on 22.05.2022 at 10:00 AM again being identified by petitioner related to this case and the same has been informed with human traffickers new number 8586998355/8587938478 to Katihar Railway Child line coordinator Praveen Kumar, Pradeep Kumar Child Line Coordinator Katihar, Dharmendra Meena Enquiry officer appointed by Delhi Police, DGP Bihar, IG Darbhanga, DIG Purnea, SP Katihar, SHO Palam Village New Delhi, SHO Shastri Park North East Delhi and SHO
  • 33. 33 Kadwa through SMS on their respective official mobile numbers to organize police raid to rescue, medical, arrest, charge sheet and hand over the victims of Gang Rape travelling from Telta Passenger Train boarded at Sonaili railway station and de-boarded at Katihar railway station Plat Farm No.03. SMS has been sent from sonaili railway station itself at the time of departure of train. (xvi) That after the arrival of train at katihar railway station at 11:00 AM, petitioner followed the victim captured by a team of human traffickers and shouted for help from Child Line booth at Plat Farm No.02 that Gang Rape victim wife Rina Kumari age about 44 years and daughter Shriya Poddar age about 17 years have been kidnapped by human traffickers, international sex racketeers, sex abusers way back on 15.04.2005 from Brajesh Yadav (a driver of judge and Supreme Court Justice) house located at Raj Nagar Part-2, Street No.12 Palam Colony New Delhi-77 while daughter Shriya Poddar was inside the womb of her mother. Father in law Surender Narayan Poddar Assistant Manager (RC) Barauni Refinery, Township, IOCL Begusarai has taken away petitioner’s pregnant wife under the pressure of international human traffickers to IOCL Quarter Dhanbad by Poorva Express from New Delhi to Dhanbad IOCL Quarter. (xvii) That departed father of petitioner writes a mysterious note in his daily diary of 2005 that “Wife of Pappu has given birth to a female baby on 20.05.2005 at 6:00pm. The delivery of female baby has taken place in a hospital of
  • 34. 34 Dhanbad (Jharkhand). The same day I became unconscious in Delhi due to heat wave. As a result of that Pappu and Rahul were scared”. (xviii)That petitioner and his parents are not being allowed to see their daughter and granddaughter till 09.02.2011. Petitioner has seen his daughter first time on 09.02.2011 when she appeared before the Principle Judge Family Court Dwarka Court at New Delhi in HMA-700/2010 case. (xix) That wife and 6 year old daughter Shriya Poddar along with father in law and mother in law appeared before the family court Dwarka Court at New Delhi on 09.02.2011. True copy of order dated 09th February, 2011 by Principle Judge, Family Court, Dwarka Court at New Delhi in HMA- 700/2010 case is annexed herein as Annexure P-1 (Page from 60 to 60) True copy of photographs of minor daughter Shriya Poddar dated 09th February, 2011 at children’s room at Family Court, Dwarka Court at New Delhi in HMA- 700/2010 case is annexed herein as Annexure P-2 (Page from 61 to 61) (xx) That gang rape victim wife Rina Kumari has filed Vakalatnama in HMA-700/2010 case before Principal Judge Family Court Dwarka at New Delhi through her counsel/ Advocate from district Purnea Bihar who belongs to Rajput Caste. She did not file any Written Statement and
  • 35. 35 did not contest the case. However, she has filed two cases in CJM Court at Begusarai Bihar and expressed her willingness to stay along with her husband and demanded lump sum handsome amount as compensations and monthly amount as maintenance. One 9P/2010 under domestic violence Act 2005 and another Criminal Case Complaint (P) No. 397C/ 2011/ 5591/2013 under section 498A, section 323 of IPC and u/s 3/4 of D.P Act in 2010 and 2011 along with two N.B.Ws dated 25.08.2010 and 08.09.2011 u/s 82 and 83Cr.Pc respectively. (xxi) Thereafter she disappeared from this earth and petitioner is being subjected to face abuse of court process from lower court to Supreme Court of India from state of Bihar to NCT of Delhi till date on the one hand and sexual abuse of his wife and minor daughter on the other hand. (xxii) That petitioner has rescued the victims (his wife, minor daughter and 50 female members of his family and their children) of gang rape, hidden prostitution, illicit sex trade and child sexual abuse from the brothels of Gulabbagh Purnea Bihar, Sonagachhi Kolkotta, Varanasi, UP, G.B. Road New Delhi with an active help of Supreme Court of India through (W.P.(Crl.) 137/2021-PIL & W.P.(Crl.) 242/2021) cases on 05.05.2022 and brought them back at source point of human trafficking, Katihar railway station by Mahananda Express on 06.05.2022. (xxiii)However, the rescued victims of Gang Rapes, hidden
  • 36. 36 prostitution and child sexual abuse have not been handed over to the petitioner either by Delhi Rail Police or by Katihar Rail Police till date rather continuing gang rapes and generating revenue out of it. The accompanying Lady Magistrate of Katihar has taken them out by producing illegal, false and wrong documents to Katihar rail police and re-pushed them into the same business of flesh trade at the source point of human trafficking at sonaili village P.S. Kadwa and the surrounding areas of katihar districts. (xxiv)That petitioner cum social worker cum whistle blower cum father cum guardian of victims has been approaching all the government and Non-Government institutions/ authorities for rescue and hand over of the rescued victims but none are paying any heed to the request of petitioner till date. (xxv) That instead of handing over the rescued victims, administration is organizing Gang Rape of rescued victims in the name of Marriage ceremony and inviting sex abusers/customers in the name of Baarati every night in front of petitioner’s house at Asha Deep Niwas, Shukkar Hatt, Sonaili, P.S. Kadwa, katihar, Bihar-855114 and in front of his own eyes. True copy of signed copy of police complaint against sex abusers state through email letter dated 07th May 2022 by petitioner to all nodal police officers of Bihar and NCT of Delhi is annexed herein as Annexure P-3 (Page from 62 to 63)
  • 37. 37 (xxvi)That the victim Wife Rina Kumari age about 44 years and daughter Shriya Poddar age about 17 years are being repeatedly sold in the market of flesh trade in front of his own eyes and in front of his own house Asha Deep Niwas, Sonaili, P.S. Kadwa, Katihar Bihar through the system of registry for short stay in the house of sex abuser, performing shots for oral sex, anal sex and vaginal sex, aborting babies, conceiving babies, performing sex during tours and travels, sex during picnics, celebrations, sex through hotels booking, organizing events of Gang Rape in the name of “marriage ceremony” and inviting sex abusers in the name of “Baaraati” with great pump and show by an erotic vulgar strong beat songs of DJ, sex attending at SPA, sex in Wellness centers, sex with Massage center etc. True copy of signed copy of police complaint against sex abusers state through email letter dated 08th May 2022 by petitioner to all nodal police officers of Bihar and NCT of Delhi is annexed herein as Annexure P-4 (Page from 64 to 64) True copy of signed copy of police complaint against sex abusers state through email letter dated 10th May 2022 by petitioner to all nodal police officers of Bihar and NCT of Delhi is annexed herein as Annexure P-5 (Page from 65 to 66) (xxvii) That petitioner tried to stop this nonsense in one of the
  • 38. 38 gang rape events on 11.05.2022 but being thrashed, beaten and injured by the group of sex abusers Shekhar Gupta. True copy of signed copy of police complaint against sex abusers state through email letter dated 11th May 2022 by petitioner to all nodal police officers of Bihar and NCT of Delhi is annexed herein as Annexure P-6 (Page from 67 to 67) (xxviii) That Sadar Hospital Katihar has given medical services to the petitioner on 12.05.2022. An attempt was taken to murder the petitioner in (W.P.(Crl.) 137/2021-PIL) by a team of Government Doctors and missionaries sisters (sex abusers and international sex racketeers) through administering inappropriate drugs and taking blood sample inappropriately on 12th May vide registration no. 2529 at 12:30PM at Sadar Hospital Katihar, Bihar (xxix)That however, the doctor’s prescription is being snatched by Vendor Kedar Paswan spraying intoxicated drugs over to the petitioner at Dandkhora railway station on 12.05.2022. The same has been informed to all nodal police officers of Bihar and Delhi through SMS on the same day. True copy of signed copy of police complaint against sex abusers state through email letter dated 12th May 2022 by petitioner to all nodal police officers of Bihar and NCT of Delhi is annexed herein as Annexure P-7 (Page from 68 to 68)
  • 39. 39 True copy of signed copy of police complaint against sex abusers state through email letter dated 13th May 2022 by petitioner to all nodal police officers of Bihar and NCT of Delhi is annexed herein as Annexure P-8 (Page from 69 to 69) True copy of signed copy of police complaint against sex abusers state through email letter dated 14th May 2022 by petitioner to all nodal police officers of Bihar and NCT of Delhi is annexed herein as Annexure P-9 (Page from 70 to 70) True copy of signed copy of police complaint against sex abusers state through email letter dated 15th May 2022 by petitioner to all nodal police officers of Bihar and NCT of Delhi is annexed herein as Annexure P-10 (Page from 71 to 71) (xxx) That petitioner has submitted 3 pages application along with phone numbers of the victims to Child Railway coordinator and Child coordinator katihar on 16.05.2022 at child line booth at plat farm no.02 Katihar Railway Station. True copy of signed copy of police complaint against sex abusers state through email letter dated 16th May 2022 by petitioner to all nodal police officers of Bihar and NCT of Delhi is annexed herein as Annexure P-11 (Page from 72 to 74)
  • 40. 40 (xxxi)That the petitioner has submitted complaints along with photographs of the victims to Child Line India Foundation, NGO vide registration no. 20220516080001 dated 16.05.2022 (xxxii) That the petitioner has submitted complaints along with photographs of the victims to Chairperson of NCPCR vide complaint numbers 202200004880 dated 17.05.2022. True copy of signed copy of police complaint against sex abusers state through email letter dated 17th May 2022 by petitioner to all nodal police officers of Bihar and NCT of Delhi is annexed herein as Annexure P-12 (Page from 75 to 76) (xxxiii) That the petitioner has submitted complaints along with photographs of the victims to Child Line India Foundation, NGO vide registration no. 20220518073646 dated 18.05.2022 True copy of signed copy of police complaint against sex abusers state through email letter dated 18th May 2022 by petitioner to all nodal police officers of Bihar and NCT of Delhi is annexed herein as Annexure P-13 (Page from 77 to 78 ) (xxxiv) That petitioner approached Child Line booth at plat farm no.02 and registered his grievances against this heinous act
  • 41. 41 of child line coordinator katihar Bihar. (xxxv) That horribly, Coordinators asked for Aadhar Card of victims for handing over process while victim has been kidnapped by the human trafficker way back on 15.04.2005 while she was inside the womb of her mother thereafter never met the petitioner father except on 09.02.2011 at Dwarka Court at New Delhi. Petitioner has informed the same to the coordinator to coordinate with regional or national office because all relevant documents like court orders, snaps of victims have been submitted online to NCPCR & Child Line India Foundation on 16th and 17th May 2022 and the case has been accepted by them. (xxxvi) That petitioner understood the game plan of Child Line coordinators. They are basically sex abusers and income generator from the victims. (xxxvii) That petitioner asked from on duty volunteer Raj Kumar Jha to supply the snaps of attendance sheet maintained by the petitioner at the booth of Child Line plat farm no.02 katihar railway station since 16.05.2022. (xxxviii) That surprisingly, Sex abuser Pradeep Kumar coordinator Child Line Katihar monitored the events through online CCTV camera and scolded on duty Volunteer Raj Kumar Jha for supplying the offline attendance sheet of petitioner to the petitioner’s email id:om.poddar@gmail.com. Thereafter volunteer refused to
  • 42. 42 supply the attendance sheet of petitioner. (xxxix) That the first point person who sexually abused and pushed petitioner’s wife into prostitution is Justice S.B. Sinha of Supreme Court of India through driver of Judges Mr. Brajesh Yadav & Pappu Yadav R/O Raj Nagar Part-2, Gali No.12, Palam Colony, New Delhi-110077, thereafter picked by Praveen Kumar, Indian Defense Account Services R/O Patna, SP Deepak Sah, Lohapatti Bhagalpur, SP Katihar Sidharth Mohan Jain, SP Katihar Vikas Kumar, SP Katihar Jitender Kumar, SP Katihar rail Avinash Kumar, A.K.Chaudhry R/O Begnabari Katihar, Bihari Lal Bubna R/O Sonaili P.S. Kadwa, Mukesh Sinha R/O Bhagalpur, Santosh Kumar, Pharmacist, Sultangunj, Bhagalpur, Talib Khan R/O Gaya, Digvijay Singh S/O R.K. Singh, R/O Patna Bihar and Gola Dairy Dwarka at New Delhi, Inder pal S/O Hira Lal R/O RZF-893, Netaji Subhash Marg, Raj Nagar Part-2, Palam Colony, New Delhi-110077, Agam Poddar S/O Vishundeo Poddar R/O Khagaria and Shastri Park North East Delhi, Kedar Paswan, railway vendor R/O Khagaria and Sonaili, P.S. Kadwa, Katihar, Thakur Digvijay Singh S/O Lalit Singh R/O Sonaili Goshala, P.S. Kadwa, Nanki Singh Army man, R/O S/O Lalit Singh R/O Sonaili Goshala, P.S. Kadwa & Vasant Kunj New Delhi, Bobin Banerjee R/O Mirchaibari Katihar & Gurgaon Delhi NCR, Dilip Jha R/O Kishangarh vasant kunj new delhi and dwarka new delhi, Dilip Kumar S/O Jyotish Nunia R/O Salmari, Santosh Gupta RSS & Nextagen coaching Institute R/O Katihar, Sunil Poddar S/O Late Siwanan Poddar R/O Sonaili & Katihar, CNF agent Sharoff at
  • 43. 43 Gulabbagh Purnea, Shalender Prasad deo R/O Sonaili Khagaria & N.R. Public School Raj Nagar Part-2 Palam Colony at New Delhi, Agam Poddar S/O Vishundeo Poddar R/O Khagaria & Shastri Park, North East Delhi, Abhay Poddar S/O Kameshwar Poddar R/O Argara Chowk, Katihar, Ram Chander Poddar S/O Late Varon Poddar R/O Teghra Begusarai Bihar & C-180 LIG Flat, Housing Board Colony, Amritsar Punjab, Dr. R.Sinha R/O Vinodpur, Katihar, SP Deepak Sah R/O Lohapatti, BhagalPur, Arun Dokania, Manthu Dokania, Gappu Bubna, Sanjay Bairwa Jain, R/O Sonaili, Jain of Gulabbagh Purnea, Sanjay Chandra, Abhay Poddar R/O Argara Chowk, Katihar, Shyamal Sah, Gopal Sah, Mahender Sah, Ravi Sah R/O Sonaili, Gangsters Suraj Bhan Singh, Pappu Yadav, son of Sahabuddin, Ashok Agaral Member of Legislative Council Kadwa, Ram Prakash Mahto, Sanjay Purve R/O Katihar, Ram Karan Mahto, Ramashish Mahto, Kapil deo Mahto, Dr. Shakeel Ahmed Khan, Member of Legislative Assembly Kadwa, Dulal Chand Goshwami Member of Parliament Katihar, Nikhil Chaudhry Former Member of Parliament BJP, Giriraj Singh Member of Parliament BJP, Chirag Paswan s/o Ram Vilas Paswan, Mukesh Sahni welfare Minister Govt. of Bihar, Tarkeshwar Prasad Deputy Chief Minister Bihar, A.K. Chaudhry R/O Begnabari Katihar, Sunil Kumar R/O Bhogaon, Rakesh Sinha, R/O Begusarai MP&RSS leader, Jayant Sinha, Ajit Kumar IAS R/O Freedom fighter colony IGNOU New Delhi, Sunita W/O Vinod Karn pimp R/O Darbhanga and phoolwaria Katihar, Babita Devi R/o Rajgir Gaya and C/O Abhay Poddar Argara Chowk Katihar, all elected representatives
  • 44. 44 of Panchayati Raj Institutions, all political parties, youth wing, cultural organizations of all political parties, Justice U.U. Lalit, Pinaki Chandra Ghosh, Ranjan Gogoi, Snjay Kishan Kaul, G.S. Singhvi, Kurien Josheph, Ajay Rastogi, Hement Gupta of Supreme Court of India, Justice Veena Birabal of Delhi High Court, Principle Judge Family Court, Deepa Sharma, Advocate Sunil Ojha, SP Sidharth Mohan Jain, present SP Railway katihar Avinash Kumar, SP Civil Jitender Kumar, DIG Purnea Vikas kumar, Pappu poddar niece of Surender Narayan Poddar R/O Rohini, coaching Institute in Munirka at New Delhi, Digvijay Singh S/O R.K. Singh R/O Siswachack, sonpur and Gola dairy New Delhi, Thakur Digvijay Singh S/O Lalit Singh R/O Sonaili Goshala Road, Asabuddin Obesi, MP, Shyamar Bubna, Rakesh Bubna, Banti Bubna, Kanahiya Banka, Sunil Bubna, Pappu Bubna, Adhin lal and sons, Gulab Indane R/O Sonaili, Indian defense organizations, executives, judiciary, legislatures, media, different gangsters, mafia for generating own incomes and consuming own sexual gratifications. Victim is eing thrown into different brothels across Globe. (xl) That Judicial Magistrate of Katihar has submitted wrong documents on 06.05.2022 at katihar railway station and took the victims in her own custody and thereafter re- pushed them into the same business of flesh trade at the source point of human trafficking in front of petitioner’s house at Asha Deep Niwas, Sonaili P.S. Kadwa Katihar and in front of his own eyes.
  • 45. 45 (xli) That the international sex racketeers are creating total chaos in the well-established caste system of Indian society which has resulted in total anarchy in the social system. From Director General of Police Bihar to Station House Officers of police stations have become sex abusers of victims. From Ministers to watchmen are sex abusers of victims. DGP Bihar shared the information over telephone that petitioner’s family members prefer to stay at the neighbor’s house rather than petitioner’s house. Sex abuser DGP Bihar became judge and court instead of rescuing and handing over the victims to the petitioner. (xlii) That chairperson of NCPCR vide complaint numbers 202200004880 dated 17.05.2022, Child line 20220516080001 dated 16.05.2022, 20220518073646 dated 18.05.2022 and telephone numbers of Kolkotta office 033- 23416130 for Child Line Eastern Regional Centers , Child Line Northern Regional Centers, Gurgaon Delhi NCR telephone numbers 0124-2862900, Child line Coordinator Katihar, Pradeep Kumar 9471679934 have been figured out as a sex abusers of petitioner’s family members and their minor children. (xliii) That SP Railway Delhi and Katihar, SHO Railway Police Katihar Plat Farm No.02 have also been identified as sex abusers of petitioner’s family members and their minor children for not handing over rescued victims to the petitioner and re-pushing them into the same business of flesh trade in front of his house Asha Deep Niwas Sonaili and in front of his own eyes since 2005.
  • 46. 46 (xliv) That SP Katihar and SHO Kadwa have also been identified as sex abusers of petitioner’s family members and their minor children for not handing over rescued victims to the petitioner and re-pushing them into the same business of flesh trade in front of his house Asha Deep Niwas Sonaili and in front of his own eyes since 2005. True copy of signed copy of police complaint against sex abusers state through email letter dated 19th May 2022 by petitioner to all nodal police officers of Bihar and NCT of Delhi is annexed herein as Annexure P-14 (Page from 79 to 81) (xlv) That SHO Kadwa and SI Binod Singh called petitioner to the police station Kadwa 5 km from the house petitioner in the garb of handing over family members to the petitioner. Misled petitioner and illegally detained him for three hours at Kadwa police station and gang raped his families breaking the lock of his house at sonaili situated at 5 km away from Kadwa Police Station on 20.05.2022 at 7:30 pm to 11:00pm. True copy of signed copy of police complaint against sex abusers state through email letter dated 20th May 2022 by petitioner to all nodal police officers of Bihar and NCT of Delhi is annexed herein as Annexure P-15 (Page from 82 to 83) (xlvi) That every day petitioner catches the victims in the event of
  • 47. 47 gang rapes but Child Railway coordinator and Child coordinator katihar gives safe passage to them every day for organizing gang rape. (xlvii)That petitioner caught the victim at plat farm no.03 and shouted for help from child line katihar railway station over phone. Victim was in black burka led by Maulanas, Muslim women and children. Ironically instead of rescue, child line has given safe passage to the human traffickers on 22.05.2022. True copy of signed copy of police complaint against sex abusers state through email letter dated 22nd May 2022 by petitioner to all nodal police officers of Bihar and NCT of Delhi is annexed herein as Annexure P-16 (Page from 84 to 85) (xlviii) That petitioner’s house has been planted with a battery bomb on 22.05.2022 by the sex racketeers, gang rapist, sex abusers Sunil Poddar S/O Siwanand Poddar, R/O Sonaili and Katihar, CNF agent Sharoff R/O Gulabbagh Purnea, Santosh Gupta, Nextagen Coaching Institute R/O Katihar, Pawan Singh alias Thakur Digvijay Singh, Tax Accountant consultant with Rajasthan Hotel Katihar R/O Sonaili, Digvijay Singh S/O R.K. Singh R/O Siswachak, sonpur & patna & gola dairy new delhi, Mukesh Sinha R/O Bhagalpur, SP Deepak Sah R/O Lohapatti, Bhagalpur, SP Sidharth Mohan Jain Gang Rapist, Talib Khan R/O Gaya & Aurangabad, Mustak Khan, Sajid Khan R/O Siwan, Dr. Shakeel Ahmad Khan, MLA Kadwa, SP Vikas Kumar,
  • 48. 48 Shyamar Bubna, Arun Dokania, Manthu Dokania, Banti Bubana, Gulab Indane, SDM Barsoi, Rakesh Bubna, Sunil Bubna, Sanjay Bairwa Jain and the same has been informed to the all nodal police officers of Bihar and Delhi to diffuse. (xlix) That District Magistrate, SDM Barsoi, District Judge District court Katihar and Public prosecutor District court katihar have also been identified as sex abusers of petitioner’s family members and their minor children, not handing over rescued victims to the petitioner and re- pushing them into the same business of flesh trade in front of his house Asha Deep Niwas Sonaili and in front of his own eyes since 2005, organizing gang rapes of victims every night with great pump and show, murder of gang rape victims, cremating dead bodies of gang rape victims evading Rule of Law without executing Panchnama and postmortem. (l) That after receiving information disclosing cognizable offence of persistent gang rape of rescued victims at the source point of Human Trafficking by the Secretary Ministry of Home Affairs and all nodal police officers of Bihar and NCT of Delhi, victims are being gang raped by Sunil Poddar, Santosh Gupta RSS leader, Katihar in his house at nextagen coaching center thereafter inside the local siliguri passenger train thereafter whole night performing DJ dance and gang rape at the tune of gun firing by the nexus of State, Gangsters, Mafia, NGOs and Indian Defense Organizations in Goshala, Bishanpur, Pradeep Yadav’s hen farm, Nijhra, Chand Hotel’s house, Himraj Singh House,
  • 49. 49 Sahni Tola’s house, Pahlagarh, Kumhari, Kadwa at Sonaili Shivpuri Bihar Military Police premises, Raj Kumar Gupta’s House, Sanjay Chandra’s House at Katihar, Khattu shyam hall argara chowk katihar, hotels of katihar, CNF agent Sharoff’s Gulabbagh brothels, Falka, Khagaria, Bhagalpur, Purnea, Supol, Dhamdhaha, Rupoli, Viratnagar Nepal, Saharsa, Gaya, Siwan, Kishan ganj, Barsoi, Maldah, Kolkotta, Orissa, Assam, Siliguri, Sikkim, Jharkhand, Patna, Varanasi and many other locations from 06.05.2022 to till date. (li) That the gang rape is organized with the help of artificial rain, intoxicating drugs, alcohol, medical team, technology based equipment, hidden camera inside the bodies of human as well as animals, birds, use of biological weapons like COVID-19 virus, use of jammer communications/mobile services, use of Air Base for trafficking the gang rape victims from one place to another place, use of own relatives, kith, kin and closest friends of victims etc. (lii) That the socio economic dynamics of this sex business is technology based, non-banking financial centers based, corporate social responsibility based, geo-politics based, Cristian missionaries adoption based, youth, cultural wings, students wings polarization based, social conflict, communal violence, social chaos, social anarchy based, social disequilibrium based sex industry. (liii) That the bitter truth of rescue operation team in the human
  • 50. 50 trafficking area is bribe and making maximum money out of it by the team members ignoring the basic principles of social work and principles of Natural Justice, which spoils the possibility of combating the menace of human trafficking. Rescue team involves in the event of gang rapes and sexual abuse of the victims, encourages the human trafficking and discourages rehabilitation and reform of the victims. (liv) That the technologies used in this sex racket is unique and unavailable with common mass. This technology is used either by Defense organizations or by International terrorist organizations. (lv) That the main sex racketeers for running this technology based illicit sex trade, hidden prostitution, child sexual abuse, have been figured out by the petitioner as Mr. Om Birla, Chairperson and Speaker of Lok Sabha, Indian Parliament and Capitalist business man Mr. Mukesh Ambani R/O Zam Nagar district Gujrat. (lvi) That sex abusers political parties and leaders have been figured out by the petitioner who have deliberately exploited and ruined this region for their own vested political interests. The names are like Bhola Bishwas R/O Kadwa, Advocate Asabuddin Obessi R/O Haydrabad, Tariqe Anwar R/O Munger, Sahnabaj Hussain R/O Kishanganj, Dr. Shakeel Ahmad Khan R/O Semapur Katihar, Dulal Chand Goswami R/O Barsoi, Nikhil
  • 51. 51 Chaudhry R/O Katihar, Himraj Singh R/O Sonaili, Bhola Rai R/O Sonaili, Giriraj Singh R/O Begusarai, Pappu Yadav R/O Purnea, Suraj Bhan Singh R/O Mokama, Tarkeshwar Prasad R/O Katihar, Jayant Sinha R/O Patna, Rakesh Sinha (RSS) R/O Begusarai, Chirag Paswan R/O New Delhi and Bakhri Khagaria, Bihar, Sibu Shoren R/O Jharkhand, son of Sahabuddin R/O Siwan Ashok Agarwal R/O Katihar etc. (lvii) That petitioner has emailed signed copies of complaint along with daily SMS alarm for gang rape locations w.e.f. 06.05.2022 to till date to all nodal police officers of Bihar, NCT of Delhi and Secretary Ministry of Home Affairs, Prime Minister Office, Hon’ble Chief Justice of India office at Supreme Court of India at New Delhi. In spite of that Gang Rape, DJ Dance, illicit sex trade, hidden prostitution, child sexual abuse continued by the rescued victims of gang rape, hidden prostitution and child sexual abuse at the source point of human trafficking at the tune of gun fire by muscle man every day and night w.e.f. 06.05.2022 to till date. (lviii) That in spite alarm to all nodal police officers and child line NGOs across country; petitioner is being attacked by a women human trafficker. She dragged and broke his shirt’s button and managed to escape the victims. Child line team member sumit kumar again has given safe passage to the human trafficker. The victim of child sexual abuse and Gang Rape is being again trafficked. Human Trafficker was able to do this job with an active help of a group of human trafficker in presence of Sumit Kumar, Team Member of
  • 52. 52 Child Line Katihar in front of India Family Mart Mall Katihar on 23.05.2022 at around 11:00 AM. The petitioner alarmed the same to all nodal police officers of NCT of Delhi and Bihar through SMS. True copy of signed copy of police complaint against sex abusers state through email letter dated 24th May 2022 by petitioner to all nodal police officers of Bihar and NCT of Delhi is annexed herein as Annexure P-17 (Page from 86 to 87) (lix) That on 24.05.2022 at 19:00pm “victim not handed over, artificial rain caused for gang rapes and illicit sex trade at Mahmood Chowk D.S. College katihar, khatu shyam, argara chowk, hotels of katihar inside toilet, power engine, driver’s cabin of local trains, RPF room, RMS room, SSE LOCO Office at plat farm no.03, inside bed roll room, canteen room at plat farm no.03 katihar railway station. At 10:00pm “victims trafficked back by traffic rail Police from katihar to sonaili P.S. Kadwa through bullet bike or other vehicles near to kapil dev mahto’s house, Dhruv Razak & other hot spot areas of sonaili” for gang rapes”. (lx) That on 25.05.2022 at around 11:00 AM a group of human traffickers and sex abusers like ravi rai s/o ambika rai, ram chander sahni, wife of lakhan sahni, gultan sahni neighbors from eastern side attacked the applicant with vulgar abuse and pelted stone at him and on his roof where he was standing to keep vigil on his victim minor daughter’s
  • 53. 53 activities hidden inside the house of Dhruv Razak S/o Ram Narayan Razak VRS employee from railway katihar. He is northern end neighbor of applicant. That the applicant watched the event of gang rapes till 11:45AM. At 12:00pm “victim is inside Dhruv Razak, Rupak Raazak, Ravi Razak, Ritesh Razak, Sonu, Monu S/O Grand/S/O late Ram Narayan Razak house at shukkar hatt sonaili, P.S. Kadwa, traffic rail police dropped her here in the night for Gang Rape and illicit sex trade, watched till 11:45 AM, thereafter trafficked by human trafficker for further sexual abuse”. “victim’s new born baby’s body packed by Bechan Poddar and his family in white plastic bag to hide identities or keep her inside house”. True copy of signed copy of police complaint against sex abusers state through email letter dated 26th May 2022 by petitioner to all nodal police officers of Bihar and NCT of Delhi is annexed herein as Annexure P-18 (Page from 88 to 89) (lxi) That on 26.05.2022, aggrieved by the delinquent behavior of Pradeep Kumar child line coordinator katihar and persistent gang rapes illicit sex trade of victims every day and night, the applicant has registered a fresh complaint with NCPCR vide 202200004897 and with child line vide 20220526122245 dated 26.05.2022 True copy of signed copy of police complaint against sex abusers state through email letter dated 27th May
  • 54. 54 2022 by petitioner to all nodal police officers of Bihar and NCT of Delhi is annexed herein as Annexure P-19 (Page from 90 to 91) (lxii) That on 27.05.2022 at 08:44 am “there is a plan to ignite katihar bihar for communal violence in the pretext of gang rapes and illicit sex trade of petitioner’s hindu families members by 46% muslims in this region. Wanted to make katihar bihar as seelampur north east delhi. The victim of gang rape and illicit sex trade herself approached the petitioner at plat farm no.02 katihar railway station at 02:00pm dated 27.05.2022 in the pretext of enquiring Araria district bound train at Katihar Railway Station. She was in black burka garment dresses along with two beggar women. petitioner immediately identified the victim and rang the Commissioner of Police Delhi Head Quarter to intervene into the matter of human trafficking at source point Katihar railway station, stop them from trafficking to Araria Nepal boarder, raid, rescue and hand over the victims to the applicant immediately. Instead of rescue, Commissioner Police Delhi along with DGP Bihar organized gang rapes of the victims. True copy of signed copy of police complaint against sex abusers state through email letter dated 28th May 2022 by petitioner to all nodal police officers of Bihar and NCT of Delhi is annexed herein as Annexure P- 20 (Page from 92 to 93)
  • 55. 55 (lxiii) That on 28.05.2022 at 19:30 pm “Lock of the main gate of Asha Deep Niwas, Sonaili village, P.S. Kadwa is being broken by the sex abusers and organized gang rapes of the victims inside the house premises of applicant. Hidden prostitution and illicit sex trade at neighbor Bechan Poddar’s house. He is doing so by opening window towards petitioner’s house premises. Situation is violent at Asha Deep Niwas, Sonaili village, P.S. Kadwa, Katihar Bihar. True copy of signed copy of police complaint against sex abusers state through email letter dated 29th May 2022 by petitioner to all nodal police officers of Bihar and NCT of Delhi is annexed herein as Annexure P- 21 (Page from 94 to 95) (lxiv) That on 29.05.2022 at 06:01am “illicit sex trade, hidden prostitution, child sexual abuse and human trafficking by the surrounding neighbors around petitioner’s house at Asha Deep Niwas, Sonaili village, P.S. Kadwa, Katihar Bihar since 18 years. Petitioner’s 50 siblings, sister in laws and their respective children including his wife, minor daughter hijacked and pushed into this business. Raid, rescue, medical and charge sheet before court of law otherwise petitioner will move against Bihar Police and Delhi Police before Supreme Court of India with fresh Writ criminal case within one or two days, Om Prakash poddar, social worker to all the nodal police officers of Delhi and
  • 56. 56 Bihar. (lxv) That on 30.05.2022 control room 9431602302 and DGP Bihar 9431602301 being informed at 19:00pm for the possibility of gang rape tonight yet sex abusers SHO Kadwa along with Indian Army approached the petitioner at his house at around 21:20pm at Asha Deep Niwas, Sonaili village Katihar misbehaved and gang raped his minor daughter and all his family members disconnecting whole village electricity continuously throughout the night. (lxvi) That on 30.05.2022 at 08:09am, petitioner has sent an SMS to all nodal police officers of Bihar and Delhi, “Stop persistent gang rapes of victims because gang rape is continued presenting illegal/false documents by magistrate of katihar Rail police. RPF, DRM Katihar, Katihar administration, Katihar police, NGOs, INGOs, women commission, social workers, general public and indian defense organizations misusing government resources for trafficking and organizing gang rapes, illicit sex trade, child sexual abuse, and human trafficking” (lxvii) That on 31.05.2022 at 05:30am, petitioner has sent an SMS to all nodal police officers of Bihar and Delhi, ”communicate through petitioner’s email id: om.poddar@gmail.com only/No phone calls in connection with any queries related with victims re-pushed into the same business of flesh trade at the source point of human trafficking at sonaili katihar, Bihar. Rescued by the order of
  • 57. 57 supreme court of india dated 02.05.2022 in W.P. (Criminal) 137/2021 and W.P. (Criminal) 242/2021. Om Prakash Poddar, Social Worker. (lxviii) That on 31.05.2022 at 08:30am, petitioner has sent an SMS to all nodal police officers of Bihar and Delhi, “if state will kill victims of gang rapes and save gang rapists then I will ensure capital punishment for the corrupt organs of state till my death”. (lxix) That on 31.05.2022 at 09:02am, petitioner has sent an SMS to all nodal police officers of Bihar and Delhi, “planning to kill victims today to save rapists by state of Bihar. Stop foul play of state. If single victim killed then ready to face capital punishment. Om Prakash, social worker ”. (lxx) That on 31.05.2022 at 10:53am, petitioner has sent an SMS to all nodal police officers of Bihar and Delhi, “victim sexually abused inside power engine of telta passenger train to katihar at sonaili railway station by station master and others”. (lxxi) That despite of receiving information disclosing cognizable offence of gang rapes inside the katihar bound telta train from sonaili railway station to Dandkhora railway station to unnecessarily stopping at outer signal near to K.B.Jha college, SHO Katihar Rail, Jyoti Prakash and SP Katihar Rail Avinash Kumar did not bother to come at plat farm no. 01 of katihar railway station to raid and rescue the victims
  • 58. 58 of gang rapes rather given safe passage to sex abuser, human trafficker, driver of Telta Passenger train at 11:45 AM on 31.05.2022. Petitioner is being attacked by sex abusers railway staff as well as by the general public at Dandkhora Railway station for monitoring the activities of sex abusers inside power engine of Telta passenger train at 11:00 AM on 31.05.2022. Protest events being organized by the petitioner in front of power engine of driver and driver of the train called on RPF security and Dandkhora Railway Station Master through his official wireless mobile set on the same day. (lxxii) That despite of receiving information disclosing cognizable offence of possibility of gang rapes on 31st May 2022 night, Gang Rapes of his families continued for consecutively 27 days after their rescue from Delhi at the source point of human trafficking at Sonaili Village, P.S. Kadwa, Katihar, disconnecting the electricity of the whole village in the night of 31st May 2022. True copy of signed copy of police complaint against sex abusers state through email letter dated 31st May 2022 by petitioner to all nodal police officers of Bihar and NCT of Delhi is annexed herein as Annexure P- 22 (Page from 96 to 97) (lxxiii) That applicant has noticed in the morning of 1st June 2022 that the locker/Almira of his bed rooms containing valuable
  • 59. 59 assets like original property papers, jewelries, ornaments being looted unlocking the same. That wife and minor daughter do not have any interest in his material items because the applicant himself offered them all movable and immovable assets of Bihar in 2004-2005 but she denied taking even a single paisa/Penney from him. That this heinous work is done by the sex abusers, human traffickers, State+NGOs+Gangsters+Mafia+Indian Defense Organizations and +general public who have made the victims of gang rapes as their hostage and kept them in their custody for sexually abusing them and generating revenue out of it. That the life of applicant has been saved yesterday night either by some honest agencies or by his abducted wife (in 2005 by sex racketeers) and minor daughter. Delhi police and Bihar Police have been informed to register an F.I.R True copy of signed copy of police complaint against sex abusers state through email letter dated 1st June, 2022 by petitioner to all nodal police officers of Bihar and NCT of Delhi is annexed herein as Annexure P- 23 (Page from 98 to 99) (lxxiv) That victim herself called on the applicant from the mobile number of Child Line Samastipur, Bihar 9523911098 and enquired/confirmed about the address of applicant for help to avoid planned gang rapes, child sexual abuse and illicit sex trade in the night of 01.06.2022 at
  • 60. 60 3.10 PM on the eve of International Children’s Day repeatedly while he was busy in e-filing a case before Supreme Court of India from Katihar Railway Station. (lxxv)That the applicant noticed that in retaliation of e-filing of case on 01-06-2022 victims are being tortured and trafficked by local passenger train from katihar and dropped and sold at different places from katihar to Siliguri by Child Line Kolkotta, katihar, Samastipur, SP Rail Katihar, SP civil Katihar, DRM Katihar and district administration Katihar. Applicant noticed in the evening 7:30pm of 01-06- 2022 at sonaili railway station that imported car, auto, toto riksaws, bike, traffic police bullet and other vehicles are being used for carry out and selling out the victims at Sonaili, P.S. Kadwa. One auto carrying victims came in front of the main gate of the house of the applicant for illicit sex trade. Applicant blasted on pimps and brokers of victims on 01-06-2022 at around 9:00pm. (lxxvi) That applicant has sent an SMS alert on 01.06.2022 at 22:02 pm “Will you not STOP gang rapes of victims? Will you not keep them in women’s shelter homes till the matter listed and heard by Supreme Court of India?” to all the nodal police officers of Delhi and Bihar. (lxxvii) That thereafter the gang rapes organized by the child line Samastipur with an active help of state administration in the vicinity/household of neighboring dwellers of applicant at Sonaili P.S. Kadwa like Chand Hotel, Zoren Sah Begali house, Surender Singh’s house etc. The
  • 61. 61 applicant has sent an SMS alert on 01.06.2022 at 23:36 pm “victim called by 9523911098 at around 2pm and being gang raped in sonaili p.s. kadwa tonight. Register F.I.R against human trafficker and sex abusers child line samastipur” to all the nodal police officers of Delhi and Bihar. (lxxviii) That thereafter applicant has called DGP Bihar Control room at 23:22pm and SHO Kadwa at 23:37pm on 01-06-2022 night and informed the same for registration of an F.I.R because neither Delhi Police nor Bihar Police is registering an F.I.R against the numerous complaint made by the applicant since 2005 to till date. (lxxix) That applicant has identified more than 100 hotspots in the State of Bihar, State of West Bengal and neighboring border countries of Nepal and Bangladesh. (lxxx)That applicant has sent an SMS alert on 02.06.2022 at 10:21 am “I will ensure capital punishment for you for continuing gang rapes of rescued victims presenting false and fabricated documents consecutively 28 days and generating revenue out of it ” to all the nodal police officers of Delhi and Bihar. (lxxxi) That applicant has sent an SMS alert from the local passenger train on 02.06.2022 at 11:18 am “gang rapes, child sexual abuse and illicit sex trade in the pretext of jurisdictions is over. Siliguri passenger from katihar and telta passenger from telta to katihar have been identified as
  • 62. 62 carrier of human trafficking and illicit sex trade for dropping and picking up victims at several places and collecting money out of it. Stop or become party before Supreme Court of India ” to all the nodal police officers of Delhi and Bihar. (lxxxii) Stop foul play by child line kolkotta regional centers, director national child line indian foundation mumbai, chairperson ncpcr, the state of bihar and others, raid, rescue, medical, arrest, cahrgesheet and place before the court of law/juvenile court under relevant sections of relevant acts like pocso or any other relevant acts immidiately. provide night shelter homes for women victims and observation homes for children victims and allow applicant to meet the victims. True copy of signed copy of police complaint against sex abusers state through email letter dated 2nd June, 2022 by petitioner to all nodal police officers of Bihar and NCT of Delhi is annexed herein as Annexure P- 24 (Page from 100 to 101) (lxxxiii) That Justice S.B. Sinha of Supreme Court of India is the first point to spoil the wife of applicant thereafter by others. Applicant is F.I.R against him since 2011, number of petitions have been filed against him before Supreme Court of India since then by applicant and his deceased mother but no action taken against him.
  • 63. 63 (lxxxiv) That applicant’s minor daughter has been gang raped at J.N.U New Delhi on 26.05.2022 and 27.05.2022; the same has been informed by J.N.U administration New Delhi with a public notification at Facebook. (lxxxv) That Magistrate of Katihar has done mischief by transferring the case from Delhi to Bihar with an active help of Supreme Court of India deliberately with an ulterior motive for sustaining gang rapes, child sexual abuse and illicit sex trade of the rescued victim at the source point of human trafficking at Katihar district in Bihar. (lxxxvi) That applicant had prior information about planned gang rapes of the rescued victims in the night of 02.06.2022 at sonaili and different places. He got this information by sex abusers and human trafficker’s mobile no. 9953017092 at 03:41PM on 02.06.2022. (lxxxvii) That thereafter Ms. Indu Sinha R/O Binodpur, Katihar a pimp and head of sex racket in katihar district has been seen at Katihar Railway Station for arranging, directing and running illicit sex trade at Katihar railway station inside the toilet, compartment, and power engine of train and inside other hide outs of Katihar Railway property. (lxxxviii) That thereafter applicant has noticed a suspected case of sexual abuse of female, part of rescue team by Bihar Police inside the Siliguri passenger just close to DMU power engine.
  • 64. 64 (lxxxix) That applicant has sent an SMS alert on 02.06.2022 at 07:00 pm “sex abuser, human trafficker called by 9953017092 at 3pm to inform about planned gang rapes of victims tonight” to all the nodal police officers of Delhi and Bihar. (xc) That applicant has sent an SMS alert on 03.06.2022 at 06:00 am “sex abuser, Ms Indu Sinha R/O Binodpur, Katihar and others have organized yesterday (2.6.22) night gang rapes of victims. Register F.I.R” to all the nodal police officers of Delhi and Bihar. (xci)That applicant has sent an SMS alert on 03.06.2022 at 08:03 am “sex abuser, Tinku Mandal S/O Kishandev Mandal R/O Tilas P.S. Dandkhora just at 7:15 am came after complaint against Ms Indu Sinha R/O Binodpur, Katihar and others to attacked and tried to kill me at my residence Asha Deep Niwas, Sonaili, Katihar, Bihar-855114. Rang phone of SHO Kadwa, SP Katihar, DIG Purnea, IG Darbhanga, Control Room DGP Bihar but no one picked up and responded for help ” to all the nodal police officers of Delhi and Bihar. (xcii)That applicant has sent an SMS alert on 03.06.2022 at 10:17 am “victim of gang rapes dropped at Dandkhora station master’s cabin by siliguri passenger in the morning; trafficked by road to sonaili or katihar ” to all the nodal police officers of Delhi and Bihar.
  • 65. 65 (xciii)That the applicant is eye witnessed of the heinous act of Sinha families in dormitory of Laxmi Narayan Dharmshala, Church Road, Fatehpuri, Old Delhi Railway Station from 25.04.2022 to 04.05.2022. Mukesh Sinha and his female family members, Dr. Shakkel Ahmad Khan, MLA Kadwa, Talib Khan ranged the applicant number of times to withdraw or to transfer the case from Delhi to Bihar. Gangster, Son of Sahabuddin, wife and his minor daughter R/O Siwan Bihar stayed at Laxmi Narayan Dharmshala just close to applicant bed in dormitory from 25th April to 4th May 2022 and monitored, kept surveillance on the activities of applicant, invited sex abusers, human traffickers for applicant’s families from different parts of country like surat, ahmadabad, Mumbai, Orissa, Punjab, Varanasi, bihar etc. Gang raped his families in front of his own eyes inside the toilet and other rooms of Dharamshala thereafter killed some of them by exchanging a deal with RSS workers of Varanasi, shooter and killers invited. Team of expert doctors also invited for killing. CCTV footage, if not deleted till date, will be testimony of his act. (xciv) That Sinha family is a big threat to the National Security and National progress. Indian history is witnessed of this fact that this community has hijacked all the constitutional institutions of the country for their own vested interest since independence. (xcv)That it is pertinent to mention here for your information that Commissioner of Police Delhi has diaries 13 complaint against out of 29 complaints made so far. Applicant has
  • 66. 66 filed Interlocutory application for impleadments or interventions on 30.04.2022 before Supreme Court of India in W.P. (Criminal) 137/2021 to make it National jurisdictions. (xcvi) It is submitted for your information that Affidavit for International Sex Racket has been filed before Supreme Court of India in W.P. (Criminal) 137/2021 and the same has been tagged with W.P. (Criminal) 242/2021. Violence against Women, Gang Rapes of women and children are not restricted to the nitty gritty of jurisdictional technicalities. (xcvii) Stop this criminal crook sinha bugs from ruining the basic fabric of the country, raid, rescue, medical, arrest, cahrgesheet and place before the court of law/juvenile court under relevant sections of relevant acts like pocso or any other relevant acts immidiately. provide night shelter homes for women victims and observation homes for children victims and allow applicant to meet the victims. True copy of signed copy of police complaint against sex abusers state through email letter dated 3rd June, 2022 by petitioner to all nodal police officers of Bihar and NCT of Delhi is annexed herein as Annexure P- 25 (Page from 102 to 103) (xcviii) That Katihar administration and state of Bihar and others have tried to obstruct the way of applicant from reaching
  • 67. 67 Supreme Court of India on 05.06.2022 at 5:45PM (xcix) That on 06.06.2022 at 17:14 pm “human trafficker/sex abuser Mofidul Islam R/O Morigaon, Assam mobile no. 7356008554 in S-1 Coach of North East Superfast express train caught trafficking petitioner’s minor daughter and planned to organize gang rape at Leela Hotel New Delhi/Anand Vihar Railway Station or any other places in Delhi/NCR along with “Safe Shop company” Janakpuri, New Delhi team. Informed to SHO Palam Village New Delhi and SHO Shastri Park North East Delhi. She has been seen with a male baby at her lap. However, Delhi Police has given safe passage to Human trafficker to traffic minor daughter of petitioner on 06.06.2022 at 22:30pm from Anand Vihar Railway Station Delhi. (c) That commissioner of police Delhi has allocated an enquiry officer Ms. Pratima against the petitioner’s email complaint no. 817104012203108 dated 25.05.2022, 801012232364 dated 17.05.2022, 801012232732 dated 19.05.2022, 801012233608 dated 23.05.2022, 801012232268 dated 17.05.2022, 817104012203159 dated 26.05.2022. (ci) That Commissioner of Police, Delhi has supplied telephone number 011-23746100 extension no. 69504, 69505, 69804 and 69805 with following diary numbers diaried against the complaint of petitioner w.e.f 07.05.2022 to till date
  • 68. 68 a) D.NO. 33113 email dated 11.05.2022, b) D.NO.33104 email dated 11.05.2022, c) D.NO.33340 email dated 12.05.2022, d) D.NO.33808 email dated 13.05.2022, e) D.NO.34461 email dated 17.05.2022, f) D.NO.34301 email dated 17.05.2022, g) D.NO.34964 email dated 17.05.2022, h) D.NO.35276 email dated 18.05.2022, i) D.NO.35441 email dated 19.05.2022, j) D.NO. 35479 email dated 19.05.2022, k) D.NO.35598 email dated 19.05.2022, l) D.NO.35603 email dated 19.05.2022 m) D.NO.36354 email dated 23.05.2022 All the above 13 complaints out of 29 complaints made by the petitioner w.e.f 07.05.2022 to till date have been diaried by Commissioner of Police Delhi against the grievances of persistent Gang Rapes of rescued petitioner’s families at the source point of human trafficking at Katihar district of Bihar. (cii) That Home Secretary, Shri Ajay Kumar Bhalla forwarded petitioner’s email to Joint Secretary Ms. Saheli Ghosh Rooy on 31.05.2022 and she in turn forwarded the same to
  • 69. 69 Additional Chief Secretary Home Department Government of Bihar Shri Arun Kumar Dhyani on 31.05.2022 and he in turn forwarded the same to the Chief Secretary Bihar on 01.06.2022 and Chief Secretary Bihar diaried the petitioner’s email with reference number 3191 dated 03.06.2022 and forwarded the same again to Additional Chief Secretary Home Department Government of Bihar Shri Arun Kumar Dhyani for necessary action please. This email of petitioner contains Order dated 09.02.2011 in HMA-700/2010 of Family Court, Dwarka Court at New Delhi; case related to victim wife Rina Kumari and snaps related to victim minor daughter Shriya Poddar (i) That ironically this all are happening within the knowledge of Prime Minister Office, Ministry of Home Affairs, President of India House and Hon’ble the Chief Justice of India, Supreme Court of India. 2. QUESTION(S) OF LAW: a) Whether or not Police Complaint along with daily SMS alert of location of Gang Rapes, illicit sex trade, hidden prostitution, child sexual abuse made against the rescued victims w.e.f. 06.05.2022 to till date to all nodal police officers of Bihar and NCT of Delhi is a cognizable offence and attracts an F.I.R including arrest of the accused?
  • 70. 70 b) Whether or not the malfunctioning of NCPCR and doubtful intervening strategy of ChildLine India Foundation Delhi is questionable in this case of child prostitution also? c) Whether or not NCPCR and ChildLine India Foundation, Kolkotta have deliberately ignored the inputs, facts, circumstances, apprehensions, observations, analysis, recommendations, nature and dynamics of the case illustrated by the petitioner in the complaint with an ulterior motive to suppress the matter and spoil the minor girls for their own vested interest? d) Whether or not consent for sexual abuse and hidden prostitution in minor case is immaterial in the eyes of law? e) Whether or not NCPCR, ChildLine India Foundation Delhi, North East Delhi Police and Special Juvenile Police Unit (SJPU) have violated the provisions under section 30(xiii) of Juvenile Justice Act 2015, Rule 4(2) (c), Rule 4(3), Rule 4(4), Rule 4(5), Rule 5 & section 19(5), section 19(6) and section 25 of the POCSO Act 2012? f) Whether or not NCPCR and ChildLine India Foundation Delhi should submit a complete road map of intervention process adopted in this case including methodology, procedure, selection of intervening team, location of intervening team, quality of intervening team members, steps taken and action taken report before this Hon’ble Court in the larger interest of children across the country?
  • 71. 71 g) Whether or not NCPCR has shown it’s by standard apathy and inertia to intervene in this case and deliberately continued the gang rape, illicit sex trade, hidden prostitution and child sexual abuse of rescued victims persistently at the source point of Human Trafficking. h) Whether or not rampant unlawful detention of whistle blower petitioner by the Bihar Police as well as Delhi Police is an evident of this fact that the matter of hidden prostitution and child sexual abuse has been suppressed for their own vested interest? i) Whether or not it is the matter of grave concern for all children across the country? j) Whether or not the matter is absolutely interlinked with source point at Sonaili P.S. Kadwa Katihar and transit or destination point at Shastri Park, North East Delhi in the area of International Human Trafficking? k) Whether or not victim minor girls and daughter of petitioner to be rescued, rehabilitated and initiated handing over process to the petitioner till the investigation team constituted by this Hon’ble Court or the investigation/court process resumes and completes? 3. GROUNDS: That being aggrieved by the abuse of Bihar and Delhi police power, no F.I.R or ATR against the unlawful detention of whistle blower petitioner at the midnight of 25th April, 2021 in
  • 72. 72 Shastri Park Delhi and night of 20th May 2022 by SHO and SI Binod Singh Kadwa, Katihar violation of provisions under section 30(xiii) of Juvenile Justice Act 2015, Rule 4(2) (c), Rule 4(3), Rule 4(4), Rule 4(5), Rule 5 & section 19(5), section 19(6) , section 25 of the POCSO Act 2012 and malfunctioning, doubtful intervening strategy dated 13.04.2021 and 17.04.2021 by NCPCR and ChildLine India Foundation Delhi and Kolkotta, the petitioner is challenging the same on the following amongst other grounds: - A. BECAUSE this business is run by the nexus of States, NGO, Gangsters, Mafia and Indian Defense Organizations therefore re-pushed the victims of gang rape, illicit sex trade, hidden prostitution, child sexual abuse, human trafficking at the source point of human trafficking and not handed over them to the petitioner for reform. B. BECAUSE re-pushing the victims into the same flesh trade goes against the principle of Social Work and Rule of Law/Human Rights. C. BECAUSE petitioner has not been allowed to know where about of the victims and to meet the victims w.e.f 06.05.2022 to till date by the state, human traffickers, sex racketeers and sex abusers. D. BECAUSE Victims have not been rehabilitated by the state rather re-pushed into the same business of flesh
  • 73. 73 trade and not initiated the handing over process by the state to the petitioner till date. E. BECAUSE no F.I.R has been registered either by Bihar Police or by Delhi Police since 2004 and particularly since 06.05.2022 after their rescue from different brothels of India. F. BECAUSE matter pertains in the larger public interest. 4. AVERMENT i) That the present petitioner has not filed any other petitions in any High Court but filed W.P. (Crl.) 137/2021 and W.P. (Crl.) 242/2021 before 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 his and victims fundamental rights. PRAYER In the above premises, it is prayed that this Hon'ble Court may be pleased: (i) To issue a writ of mandamus or other appropriate writ order or direction directing respondent No.01, 02, 03, 05, 06, 07, and 08 to register an F.I.R against the complaints of petitioner made since 2011 to till date and to investigate into
  • 74. 74 the persistent gang rapes of the victims at the source point of human trafficking at Sonaili Katihar Bihar, rescued from illicit sex trade and child sexual abuse from destination/transit point of human trafficking at Sashtri Park North East Delhi and the rampant abuse of police power against the petitioner as well as against the victims and direct to register an F.I.R under relevant sections of IPC against the accused rapists of persistent gang rapes, illicit sex trade, hidden prostitution, child sexual abuse, human trafficking of rescued victims by the nexus of states, NGOs, Gangsters, Mafia and Indian Defense Organizations and to be monitored by issuing a necessary direction to the District Judge and SHO to investigate the matter impartially, fairly and properly including the arrest of the accused, after the registration of F.I.R. (ii)To issue a writ of mandamus or other appropriate writ order or direction directing respondent No.01, 02, 03, 05, 06, 07, and 08 to pass a dismissal order against the lady magistrate Katihar, accompanying with the petitioner in W.P.(Crl) 242/2021 and W.P.(Crl) 137/2021 for placing illegal, false and fabricated documents to this Hon’ble Court to transfer the case from Delhi to Bihar and taking unauthorized custody of the rescued victims with an ulterior motive of re- pushing them into the same business of flesh trade for generating revenue out of it. (iii) To tag all petitions W.P.(Crl) 136/2016, W.P.(Crl) 137/2021 and W.P.(Crl) 242/2021 together with this petition in the furtherance of justice.
  • 75. 75 (iv) To issue a writ of mandamus or other appropriate writ order or direction directing respondent No. 03 and 15 to direct respondent no. 16 and 17 to resume the electricity services of the house of the petitioner immediately. (v)To issue a writ of mandamus or other appropriate writ order or direction directing respondent No. 03 to direct respondent no. 04, 18, 19, 20 and 21 to investigate into the lapse of medical services by Primary Health Centre Kadwa Durgaganj and Sadar Hospital Katihar, for injecting inappropriate injections into the body of petitioner, taking unauthorized blood sample of petitioner on 12.05.2022 injuring internally and snatching his medical prescription and daily diary from his hand on the same day and date to evade the evidence. (vi) To issue a writ of mandamus or other appropriate writ order or direction directing respondent No. 01 to direct respondent no. 32, 33 and 34 to investigate into the matter of not handing over the victims to the petitioner and re-pushing the rescued victims into the same business of flesh trade, gang rapes, illicit sex trade, hidden prostitution, child sexual abuse and human trafficking at the source point of human trafficking at Sonaili Katihar, Bihar. (vii) To issue a writ of mandamus or other appropriate writ order or direction directing respondent No. 01 to direct respondent no. 35 to investigate into the matter of misuse of defense telecommunication technologies, misuse of Air base for human trafficking, the victims of gang rape from one