Writ petition, under Article 32 of the Constitution, has been filed by the victim father of unseen minor daughter, viz., Shri Om Prakash for the issuance of appropriate writs or direction(s) of like nature against the respondents herein for the protection of his minor daughter who has been kidnapped on 15.04.2005 while she was inside the womb of her mother Reena Kumari (Guddi) age about 40 years from the rented house of Judge’s driver Mr. Pappu Yadav and Mr. Brajesh Yadav R/O Gali No. 12, Raj Nagar Part-2, Palam Colony, Palam Village Police Station, New Delhi-110077. The grievance in the said writ petition is that after kidnapping his pregnant wife, on the one hand Petitioner is being pulled in the abuse of court process at Dwarka Court, Patiala House Court, Delhi High Court, Supreme Court of India at New Delhi and Begusarai Court, Patna High Court at Bihar and on the other hand sexual abuse of his families continued secretly by the State. For the first time, Petitioner has caught his families into the mud of prostitution and illicit sex trade on 05.04.2021 at Shastri Park North East Delhi, 11.05.2022 under the jurisdiction of Kadwa Police Station Katihar Bihar, 19.06.2022 under the jurisdiction of Lahori Gate Police Station Delhi-6; which has resulted in W.P.(Criminal) No. 242/2021 and W.P.(Criminal) D. No. 18546/2022 before this Hon’ble Court. After identification of illicit sex trade of his families, Petitioner has submitted several written reports since then to till date every day before the officer in-charge of the police station concerned along with the concerned higher Police authorities of NCT of Delhi and State of Bihar who did not take any action on the same and did not register an FIR to recover the minor daughter. Moreover, steps were not taken either for apprehending the accused or for the recovery of the minor girl child.

1. IN THE SUPREME COURT OF INDIA
CRIMINAL ORIGINAL JURISDICTION
CRL.M.P.NO. 157294 OF 2022
IN
WRIT PETITION CRIMINAL D.NO. 18546 OF 2022
(UNDER ARTICLE 32 OF THE CONSTITUTION OF INDIA)
AND
IN THE MATTER OF SUPRESSION
OF RESCUE OF GANG RAPE,
ILLICIT SEX TRADE, CHILD
SEXUAL ABUSE VICTIMS AND
ABUSE OF POWER BY THE STATE,
NGOS, GANGSTERS AND INDIAN
DEFENSE ORGANIZATIONS
AND
IN THE MATTER OF:
OM PRAKASH ..PETITIONER
VERSUS
UNION OF INDIA & ORS …….RESPONDENT(S)
APPLICATION U/S 151 OF C.P.C ON BEHALF OF THE PETITIONER
FOR SEEKING LEAVE TO FILE WRITTEN ARGUMENTS IN WRIT
PETITION (CRIMINAL) D.NO. 18546/2022 FIXED ON 31.10.2022.
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.

2. MOST RESPECFULLY SHOWETH:
1. The present Writ Petition under Article 32 of the
Constitution of India is being filed by a Professional
Social Worker cum Petitioner-In-Person cum Whistle
Blower cum husband cum Father cum Guardian of Gang
Rapes, hidden prostitution, illicit sex trade, child sexual
abuse and international human trafficking victims whose
rescue has been suppressed by the dismissal of PIL Writ
Petition (Criminal) 242 of 2021 on 25.10.2021 and
individual Writ Petition (Criminal) 137 of 2021 on
02.05.2022 by this Hon’ble Court to continue Gang Rapes,
hidden prostitution, illicit sex trade, child sexual abuse and
international human trafficking and for the enforcement of
the Rights under Article 21 of the Constitution of India, the
contents of which are requested to be read as part of this
application, as the same are not being repeated here for the sake of
brevity.
2. That next date of hearing for WRIT PETITION
(CRIMINAL) D.NO. 18546/2022 has been fixed on 31.10.2022.
3. That matter is grave and comes under the category of rare of
the rarest case because Supreme Court of India is one of the main
accused in this Anti-Prostitution matter and Judicial Reform has
been prayed in this petition.
4. That I.A. for additional grounds, facts, cause of actions
prayers has been e-filed on 20.09.2022 in Writ Petition (Criminal)

3. D.NO. 18546/2022.
5. That Interlocutory Application No. 143346/2022 seeking
leave to file written arguments has been filed on 23.09.2022 for the
date of hearing on 26.09.2022.
6. That certified copy of proceedings of the case record in
Case No. 9-P/2010, Criminal Case Complaint (P) No. 5591/2013
and RTI reply No. 438 dated 27.08.2016, RTI reply No. 4036 dated
20.09.2017 by Mr. Chandra Mohan Jha, Chief Judicial Magistrate,
Mr. Gangotri Ram Tripathi, District and Session Judge, Begusarai
Court under the judicature of Patna High Court disclosing Non Bail
able Warrant dated 25.08.2010 and dated 08.09.2011 u/s 82 and 83
Cr.Pc against petitioner Om Prakash and his mother Asha Rani
Devi has been e-filed as miscellaneous documents in W.P.
(Criminal) D.NO. 18546/2022 on 07.10.2022 and 08.10.2022 but
OTP has not been supplied to make payment against it either by the
State Bank of India or by the Supreme Court of India till date.
7. That Interlocutory Application for Recall of Order of Non-
bail able Warrant dated 25.08.2010 and 08.09.2011 u/s 82 and 83
Cr.Pc. issued by Mr. Atul Kumar Pathak, 1st
Class Judicial
Magistrate and Mr. Sarju Ram, Sub-Divisional Judicial Magistrate
and maintained by Begusarai Court under the judicature of Patna
High Court till date has been e-filed on 09.10.2022 but OTP has
not been supplied to make payment against it either by the State
Bank of India or by the Supreme Court of India till date.

4. 8. That National Commission for Women has suppressed the
prostitution matter thrice. Ms. Neelam Bharti case in 2014 at
Gurgaon, Haryana, Ms. Nikki Case in 2021 at Shastri Park North
East Delhi and Ms. Reena Kumari (Guddi) case in 2022 at
Begusarai Bihar. Reports by National Commission for Women
against all three cases have been e-filed as miscellaneous
documents in W.P. (Criminal) D.NO. 18546/2022 on 11.10.2022
but OTP has not been supplied to make payment against it either
by the State Bank of India or by the Supreme Court of India till
date.
9. That a letter no. 151627/2022 along with requisite
documents complying the Order dated 26.09.2022 and curing the
defects raised in the office report dated 24.09.2022 in W.P.
(Criminal) D.NO. 18546/2022 has been filed on 10.10.2022.
10. That letter dated 11.10.2022, 12.10.2022, 13.10.2022 and
14.10.2022 has been e-filed addressing to Branch Officers and
Secretary General of Supreme Court of India against the delinquent
and criminal act of Branch Officers and Assistant Registrar
Section 1B, Section X of Registry of Supreme Court for
unnecessarily delaying and not allotting the case number since six
months and designing innovative strategies to dismiss this last
Anti-Prostitution to suppress the rescue of victims (petitioner’s
never seen 17 year old minor daughter, converted into Christianity
forcefully by Tamils, made as an item girl, Professional Singer,
Professional dancer with the help of Bollywood movie world,
misused by Political Parties including BJP/RSS for vote banks and
revenue generation out of illicit sex trade, whose pregnant mother

5. Reena Kumari (Guddi) age about 40 years was kidnapped on
15.04.2005 with the help of her father Mr. Surender Narayan
Poddaar, Assistant Manager (RC), Barauni Refinery, Indian Oil
Corporation, Begusarai Bihar from the rented house of Judge’s
driver Mr. Pappu Yadav and Mr. Brajesh Yadav R/O Gali No. 12,
Raj Nagar Part-2, Palam Village Police Station, Palam Colony,
New Delhi-110077,pushed into prostitution, done Plastic Surgery
of her face to look younger to raise funds for construction of God
Ram Temple at Uttar Pradesh by Political Party BJP including
RSS ) from the mud of prostitution forever.
11. That Registry of Supreme Court of India has arisen several
cause of actions to sustain the illicit sex trade of petitioner’s
families and his minor daughters; which has resulted in disputed
office report dated 20.10.2016 in W.P.(Criminal) No. 136/2016,
office report dated 28.04.2017 in Curative Criminal D.NO.
41026/2016 in Review Petition Criminal No. 825/2016 in
W.P.(Criminal) No. 136/2016, office report dated 06.12.2018 in
M.A No. 2836/2018 in M.A. No. 22539/2018 in W.P.(Criminal) D.
No. 2188/2017, office report dated 24.09.2022 in W.P.(Criminal)
D. No. 18546/2022 and thereafter passed subsequent Judicial
Orders for dismissal of writs by this Hon’ble Court.
12. That “Complaint against Branch Officers of Section 1B &
Section X of Supreme Court India for designing strategy to dismiss
Last Anti-Prostitution and Gang Rape matter Writ Petition
(Criminal) Diary No. 18546/2022 to sustain illicit sex trade of
Petitioner’s families including his 17 year old minor daughter
whom he has never seen” has been filed on 12.10.2022 before

6. Secretary General of Supreme Court of India.
13. That Complaint “against Mr. Jagmohan Singh, Assistant
Registrar Section 1B of Supreme Court of India” has been filed on
13.10.2022 before Secretary General of Supreme Court of India.
14. That letter from 10.10.2022 to 14.10.2022 has been e-
mailed to Registry of Supreme Court of India categorically stating,
“Order dated 26.09.2022 Complied on the ground of defects raised
in Office Report dated 24.09.2022, Defects cured and refiled on
10.10.2022 and 13.10.2022; register this Anti-Prostitution and
Gang Rape case urgently because timeline has been ordered by
Chamber Judge and allot the Case Number to file necessary
Interlocutory Applications in this petition” has been filed before
the Branch Officers of Section 1B and Section X of Supreme Court
of India; Yet new objection has been notified on 14.10.2022 with
back notification dated 15.06.2022 by the Registry at the website
of Supreme Court of India stating “Kindly file application for
condonation of delay in refiling writ petition along with notarized
affidavit” to defend their criminal act of sexual abuse and to offend
the whistle blower petitioner for blowing whistle against the hidden
prostitution, child sexual abuse and illicit sex trade of his families
and minor daughters since 18 years by the State.
15. That petitioner has not delayed in reporting the Gang Rape
Case to Supreme Court of India rather Supreme Court of India has
shown its insensitiveness towards the matter for its own vested
interest by wrongly dismissing PIL on Child Prostitution
W.P.(Criminal) No.242/2021 due to non-appearance by Legal Aid

7. Advocates/Amicus Curries and imposing unnecessary
objections/defects to sustain Gang Rapes and illicit sex trade of
petitioner’s families and his minor daughters since 14.06.2022 to
till date.
16. That instead of taking prompt actions to recover the
kidnapped minor daughter; Apex Court has trapped Gang Rapes
and illicit sex trade matter into the vicious cycles of legal
technicalities, legal loopholes and legal Paper works. Paper work
can wait but the recovery of kidnapped 17 year old minor daughter
to STOP her persistent sexual abuse cannot wait. Every passing
night is killing the victim father of kidnapped minor daughter.
Police is violating the directions of “Lalita Kumari” case of this
Hon’ble Court to register an F.I.R and Court is infringing the
fundamental rights of petitioner by dismissing his writ petitions to
suppress the prostitution matter of his families forever to defend
the criminal and illegal act of Justice S.B.Sinha of Supreme Court
of India. Therefore question of filing interlocutory application for
condonation of delay by the petitioner does not arise.
17. That Judiciary and Executives are blackmailing each other
in this sex racket and Legislatures are taking benefit out of it. On
the contrary, Petitioner’s families have been crushed absolutely and
rolling on in between.
18. That petitioner has complied the order dated 26.09.2022 of
this Hon’ble Court in anti-prostitution matter Writ Petition
(Criminal) Diary NO.18546/2022 on 10.10.2022 and removed the
Prayer V from the petition and re-filed the same on 10.10.2022

8. vide letter no.151627/2022.
19. That Petitioner has again filed two paper books of this
petition on 13.10.2022 after curing defects on 10.10.2022
complying the order dated 26.09.2022 on the ground of defects
raised in office report dated 24.09.2022.
20. That order dated 26.09.2022 in anti-prostitution matter Writ
Petition (Criminal) Diary NO.18546/2022 categorically states that
“Last opportunity of four weeks time to cure the defects is granted.
On non-compliance to cure the defects within a period of four
weeks, the matter(s) will be deemed to be dismissed on default
without reference to the Court”.
21. That office report dated 24.09.2022 in anti-prostitution
matter Writ Petition (Criminal) Diary NO.18546/2022
categorically states that “The Petitioner-in-Person has cured all
defects but the following defect remained uncured: the Prayer V of
the Writ Petition- to consider all prayers prayed in Writ Petition
(Crl) D.NO. 18546 of 2022, Writ Petition (Civil) NO. 90 of 2016,
Writ Petition (Crl) NO. 136 of 2016, Writ Petition (Crl) NO. 137 of
2021 and Writ Petition (Crl) NO. 242 of 2021 along with the
Prayer of this Writ Petition. Instead of curing the defects, the
Petitioner-in-Person has written a note which is quoted inter alia
as follows: “Petitioner will not remove the said prayer V which
have been explained in detail at para 1 of letter dated 21.06.2022
to the Registrar. However, the Petitioner will remove the said
defect after judicial order passed by Chamber Judge against Office
Order to Registrar”.

9. 22. That Soft copy of Writ Petition (Criminal) in Diary
No.18546 has been filed on 14.06.2022 and 11.10.2022 for
verification of the Petition by the Hon’ble Judges.
23. That petitioner has given several reminders to the Section
1B and X of this Hon’ble Court that petitioner is putting up at the
footpath of Delhi since 21.09.2022 and Supreme Court will be
closed from 23.10.2022 and the next date of hearing of this matter
has been fixed on 31.10.2022 for dismissal; therefore allot the case
number and arrange the interaction with Ld. Registrar urgently, but
registry did not pay any heed to the petitioner’s reminders.
24. That Assistant Registrar Mr. Jagmohan Singh, Section 1B
of Supreme Court of India has deliberately refused to meet the
petitioner on 13.10.2022 and kept the petitioner waiting from
12:00pm to 1:00pm.
25. That Registry has sustained the persistent Gang Rapes and
illicit sex trade of petitioner’s families since six months by
imposing unnecessary defects and now trying to transfer all onuses
of Gang Rapes on the petitioner by forcing him to file an
application for condonation of delay. This is absolutely disgusting
and condemnable.
26. That Petitioner has applied for urgent certified copies of
office report dated 06.12.2018 in M.A. 2836/2018 vide application
No. A1-16047/2022 dated 14.10.2022 and office report dated
24.09.2022 in W.P.(Criminal) D. No. 18546/2022 vide application

10. No. A1-16066/2022 dated 14.10.2022 to substantiate the criminal
act of delinquent Registry officials of Supreme Court of India
before the Chamber Judges on the next date of hearing fixed on
31.10.2022 for his ready reference.
27. That the present writ petition, under Article 32 of the
Constitution, has been filed by the victim father of unseen minor
daughter, viz., Shri Om Prakash for the issuance of appropriate
writs or direction(s) of like nature against the respondents herein
for the protection of his minor daughter who has been kidnapped
on 15.04.2005 while she was inside the womb of her mother
Reena Kumari (Guddi) age about 40 years from the rented house of
Judge’s driver Mr. Pappu Yadav and Mr. Brajesh Yadav R/O Gali
No. 12, Raj Nagar Part-2, Palam Colony, Palam Village Police
Station, New Delhi-110077. The grievance in the said writ petition
is that after kidnapping his pregnant wife, on the one hand
Petitioner is being pulled in the abuse of court process at Dwarka
Court, Patiala House Court, Delhi High Court, Supreme Court of
India at New Delhi and Begusarai Court, Patna High Court at Bihar
and on the other hand sexual abuse of his families continued
secretly by the State. For the first time, Petitioner has caught his
families into the mud of prostitution and illicit sex trade on
05.04.2021 at Shastri Park North East Delhi, 11.05.2022 under the
jurisdiction of Kadwa Police Station Katihar Bihar, 19.06.2022
under the jurisdiction of Lahori Gate Police Station Delhi-6; which
has resulted in W.P.(Criminal) No. 242/2021 and W.P.(Criminal)
D. No. 18546/2022 before this Hon’ble Court. After identification
of illicit sex trade of his families, Petitioner has submitted several
written reports since then to till date every day before the officer
in-charge of the police station concerned along with the concerned

11. higher Police authorities of NCT of Delhi and State of Bihar who
did not take any action on the same and did not register an FIR to
recover the minor daughter. Moreover, steps were not taken either
for apprehending the accused or for the recovery of the minor girl
child.
PRAYER
It is most respectfully prayed that this Hon’ble Court may be
pleased to:
(a) Grant Leave to file Written Arguments in W.P.(Criminal)
D.NO. 18546/2022 fixed on 31.10.2022 to initiate necessary
action against the delinquent Registry officials whosoever
involved in suppressing this last Anti-Prostitution matter, not
allotting the case number, not arranging the interaction of
Petitioner with Ld. Registrar and not ending the Barbaric act
of State in the furtherance of Justice.
b) Pass such other order/orders as this Hon'ble Court may deem
just and proper in the facts and circumstances of the case.
DRAWN & FILED BY:
PETITIONER-IN-PERSON
OM PRAKASH
S/O LATE SHRI DEEP NARAYAN PODDAR
S/O LATE SRIMATI ASHA RANI DEVI
PERMANENT RESIDENT: ASHA DEEP NIWAS,
SONALI, SHUKKAR HATT, IN FRONT OF DURGA MANDIR,
KANTIYA PANCHAYAT, P.S. KADWA, KATIHAR, BIHAR-855114
MOB: 9540389759
E-mail: om.poddar@gmail.com
NEW DELHI:
FILED ON : 17 -10 -2022

12. N THE SUPREME COURT OF INDIA
CRIMINAL ORIGINAL JURISDICTION
CRL.M.P.NO. 157294 OF 2022
IN
WRIT PETITION CRIMINALD.NO. 18546 OF 2022
(UNDER ARTICLE 32 OF THE CONSTITUTION OF INDIA)
AND
IN THE MATTER OF
INTERNATIONAL SEX RACKET,
CHILD SEXUAL ABUSE, FORCED
HIDDEN PROSTITUTION ABUSE OF
POLICE POWER, SUSPICIOUS
DEATH, AND MOB VIOLENCE/MOB
LYNCHING.
AND
IN THE MATTER OF:
OM PRAKASH ..PETITIONER
VERSUS
UNION OF INDIA & ORS …….RESPONDENT(S)
AFFIDAVIT
I, Om Prakash S/o Late Shri Deep Narayan Poddar, age about 48
years, R/o Asha Deep Niwas, Vill-Kantiya Panchayat, Shukkar
Haatt, P.S. Kadwa, Distt-Katihar, Bihar-855114 and Rented R/O
RZF/893, Netaji Subash Marg, Raj Nagar Part-II, Palam Colony,
New Delhi - 77, do hereby solemnly affirm and state on oath as
under:-
1. That I am the Petitioner in the above matter and well
conversant with the facts of the case as such competent to
swear this affidavit.

13. 2. That the contents of the accompanying application Under
Section 151 C.P.C. for leave to file written arguments in
Writ Petition (Criminal) D.No.18546/2022 fixed on
31.10.2022, which has been drafted by me [para 01 to 27],
[Page 01 to 11] and I, As. and having understood the
contents thereof I say that the facts state therein are correct
which are based on the official record.
3. That the accompanying application Under Section 151
C.P.C. for urgent hearing total 13 pages.’
DEPONENT
VERIFICATION:
I, the above-named deponent do hereby verify that the facts stated
in the above affidavit are true to my knowledge and belief. No part
of the same is false and nothing material has been concealed
therefrom.
Verified at New Delhi on this the 17th
day of October, 2022.
DEPONENT
Affidavit no. 1725