Applications for intervention OR impleadments in W.P. Criminal 137 of 2021 before Supreme Court of India .pdf

IN THE SUPREME COURT OF INDIA
CRIMINAL ORIGINAL JURISDICTION
CRIMINAL M.P. NO. 66689 OF 2022
IN
WRIT PETITION (CRIMINAL) NO. 137 OF 2021
Petition under Article 32 of the Constitution of India with
A Prayer for rescue of minor girls from the clutches of
sex abuser and Enforcement of Fundamental Rights.
IN THE MATTER OF:
OM PRAKASH …………..PETITIONER
VERSUS
UNION OF INDIA & ORS ….RESPONDENT
I.A NO. 66689 OF 2022
Application for Additional Grounds
I.A NO. 66686 OF 2022
Application for Impleadments
I.A NO. 66695 OF 2022
Application for additional list of dates
I.A NO. 66697 OF 2022
Application for urgent hearing
PAPER BOOK
(FOR INDEX KINDLY SEE INSIDE)
PAGES FROM 01 TO 65
PETITIONER IN PERSON
OM PRAKASH

FILING INDEX
WRIT PETITION CRIMINAL NO. 137 OF 2021
(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)
S.N Particulars Copies Diary No.:
1. Application for Additional Grounds
along with Affidavit
1+3 66689/2022
2. Annexures P-01 to P-09 1+3
3. Application for urgent hearing along
with Affidavit
1+3 66697/2022
4. Application for impleadments along
with Affidavit
1+3 66686/2022
5. Application for additional synopsis
and list of dates along with Affidavit
1+3 66695/2022
PETITIONER-IN-PERSON
OM PRAKASH
S/O LATE DEEP NARAYAN PODDAR
ASHA DEEP NIWAS
SONALI, SHUKKAR HATT, NEAR
DURGA MANDIR, KANTIYA
PANCHAYAT, P.S. KADWA
KATIHAR, BIHAR-855114
MOB: 9540389759
E-mail: om.poddar@gmail.com
NEW DELHI:
FILED ON : 30-04-2022

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 O-Q
8. Application for Additional
Grounds in WP (Crl) 137/2021
with Affidavit
1-25
9. Annexure: P-1
True copy of order dated
25.10.2021 in W.P. (Crl) 242/2021
26-27
10. Annexure: P-2
True copy of Photograph of Mr.
Manish Raj a main perpetrator and
mastermind behind this matter
28
11. Annexure: P-3
True copy of translated copies of
application dated 18-01-2022 to
S.P. Katihar for registration of
F.I.R
29-32
12. Annexure: P-4
Station House Officer, Dandkhora,
Katihar for registration of F.I.R
33-36
13. Annexure: P-5
True copy of application dated 13-
10-2013 to Senior Executive
Engineer Electricity Department,
Katihar by the mother of petitioner
for reconnection of the electricity
of the house
37-39
14. Annexure: P-6
True copy of translated copy of
Junior Executive Engineer
40-41

Electricity Department, Sub Station
Sonaili, Katihar by the petitioner
for reconnection of the electricity
of the house
15. Annexure: P-7
DGP Bihar for registration of F.I.R
42-44
16. Annexure: P-8
True copy of email dated
30.03.2022 to Additional Chief
Secretary cum Food Safety
Commissioner Health Department
Bihar
45-46
17. Annexure: P-9
postal registry letter dated 23-04-
2022 to In-charge Medical Officer,
Kadwa Durgaganj Primary Health
Centre
47-49
18. Application for urgent hearing
50-56
19. Application for impleadments
57-61
20. Application for additional list of
dates along with Affidavit
62-65
21. Filing Index 66

SYNOPSIS AND LIST OF DATES
The present Writ Petition under Article 32 of
the Constitution of India is being filed by a
Social Worker and Petitioner-In-Person in Writ
Petition (Criminal) 137 of 2021 before this
Hon’ble Court aggrieved by the unlawful
detention of petitioner by Delhi Police for
blowing whistle against the forced hidden
prostitution of minor girls to rescue and
rehabilitate in the observation home of Delhi
and for the enforcement of the Rights under
Article 21 of the Constitution of India.
16.10.2021 Interlocutory Application No. 134091/2021 for Legal
Aid Services in W.P. (Crl.) No. 242/2021 has been
filed by the petitioner from Katihar district of Bihar
from the house of the victim minor girls Priya &
Diksha D/O Abhay Poddar, Argara Chowk, Katihar,
Bihar and another minor girl Anjali D/O Sweety
kumari with same address and used victim’s IP
address.
25.10.2021 W.P.(Crl) 242/202 is being dismissed by this Hon’ble
Court because of non-appearance of Legal Aid/
amicus curiae hence the court did not find reason to
exercise its power under Article 32 of Constitution.
18.01.2022 An application to SP Katihar disclosing cognizable
offence against the livelihood/agricultural lands of

petitioner for registration of an F.I.R against the
accused/sex abusers.
31.01.2022 An application to SHO Dandkhora Katihar disclosing
cognizable offence against the livelihood/agricultural
lands of petitioner for registration of an F.I.R against
the accused/sex abusers.
20.02.2022 Sex abuser and contractor Sunil Kumar from Sub-
Station Power House Sonaili, Electricity Department
Government of Bihar approached the petitioner’s
house and disclosed that he has disconnected the
electricity of petitioner’s house and directed to
approach JEE sub-station Sonaili power house
electricity department.
26.02.2022 Sex abuser, International sex racketeer cum
Pharmacist, Pappu Yadav’s Aid Sanjay Gupta along
with Rajnikant Gupta working with Primary Health
Centre Kadwa, Durgaganj, Katihar, Health
Department Government of Bihar approached the
petitioner’s house and disclosed that he along with
team has gang raped, sexually abused minor girls and
pushed petitioner’s whole families into International
market of Prostitution. Petitioner immediately took
the cognizance of this offence and used Snjay
Gupta’s mobile and WhatsApp to send an application
to DGP Bihar control room.
30.03.2022 An application for obtaining Medico Legal Case/Injury
report dated 30.07.2019 of shri Bechan Poddar

related to an attempt of mob lynching of petitioner on
30.07.2019 being emailed to Additional chief
secretary cum food safety commissioner, Health
Department, Government of Bihar to supply the same
for court purpose as Sanjay Gupta an employee of
PHC Kadwa, Durgaganj has disclosed that no injury
report, no entry in the name of Bechan Poddar is
available with the official record of PHC Kadwa,
Durgagunj.
.04.2022 Hence this application for additional grounds in Writ
Petition (Criminal) 137/2021

CRL.M.P.NO. 66689 OF 2022
IN
AND
IN THE MATTER OF
HIDDEN PROSTITUTION, ABUSE OF
LYNCHING.
AND
BETWEEN
1. Om Prakash ………PETITIONER
S/O Late Sh Deep Narayan Poddar
R/O ASHA DEEP NIWAS
Vill-Kantiya Panchayat,
Shukkar Haat Sonaili,
In front of Durga Mandir
P.S. Kadwa, Distt-Katihar
Bihar-855114
AND RENTED
R/O RZF-893, Netaji Sbhash Marg
Raj Nagar Part-2,
Palam Colony
New Delhi-110077
VERSUES
11.Station House Officer ….RESPONDENT No.11
Dandkhora Police Station,
District-Katihar,
Bihar
12.Secretary …….RESPONDENT No.12
Electricity Department
Government of Bihar
13.Chief Executive Engineer …..RESPONDENT No.13

District Katihar, Bihar
14.Junior Executive Engineer …..RESPONDENT No.14
Sub-Station Sonaili, Kadwa
15.Secretary …..RESPONDENT No.15
Health Department,
Patna,Government of Bihar
16.Civil Surgeon …..RESPONDENT No.16
Health Department
17.In-charge Medical Officer …..RESPONDENT No.17
Kadwa, Primary Health Centre,
Durgaganj, District Katihar,
Bihar-855105
APPLICATION U/S 151 OF C.P.C ON BEHALF OF THE PETITIONER
FOR SEEKING PERMISSION TO TAKE ADDITIONAL FACTS,
GROUNDS, ANNEXURES, RESPONDENTS AND PRAYER TO
ANSWER THE QUESTION OF LAW RAISED IN THIS PETITION FOR
CONSIDERATION OF THIS HON’BLE COURT.
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:
That the present petition under Article 32 of the
Constitution of India is being filed aggrieved by the
framed Police Action Taken Reports and the rampant abuse
of police power against the petitioner in Delhi as well as in Bihar
since 2010 to till date which has resulted in suspicious death of his
mother and rendered him homeless, 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.
1. ADDITIONAL FACTS OF THE CASSE:
(i) The Writ Petition (Criminal) 242/2021 vide D.NO.
12819 is being filed on 31.05.2021 by a Social
Worker and Petitioner-In-Person in Writ Petition
(Criminal) 137/2021 before this Hon’ble Court
aggrieved by the unlawful detention of petitioner by
Delhi Police for blowing whistle against the forced
hidden prostitution of minor girls to rescue and
rehabilitate in the observation home of Delhi and for
the enforcement of the Rights under Article 21 of the
Constitution of India.
(ii) That Social Worker-Cum-Petitioner-In-Person in
Writ Petition (Criminal) 242 of 2021 has filed an
Interlocutory Application No. 134091/2021 for Legal Aid
Services in W.P. (Crl.) No. 242/2021 on 16th
October, 2021
to pursue this matter further in the furtherance of justice.
(iii) That however, Legal Aid Services in W.P. (Crl.) No.
242/2021 has not been provided by this Hon’ble Court.
Hence, in absence of that court did not find reason to
exercise its power under Article 32 of the Constitution and
the same is being dismissed and disposed of on 25.10.2021.
True copy of order dated 25.10.2021 in W.P. (Crl)
242/2021 is annexed herein as Annexure P-1 (Page

from 26 to 27)
(iv) That when the petitioner was conducting rescue operation
of minor girls through W.P.(Crl) 242/2021 at C/O Shri Ram
Kumar, H.N. 128/5, C Block, Street No. 07, Shastri Park, In
front of Rameshwar Shop, P.S. Shastri Park, North-East
District Delhi-110053 then owner of this house Shri Ram
Kumar M/S R.K Fashion, Gandhi Nagar Delhi inquired
about the details of petitioner’s sister and took the
photographs of petitioner to circulate it amongst his sex
racketeers network for verification. Thereafter petitioner
received a phone call from crying scared Ms. Priya a minor
girl of his youngest sister that her mother’s hand is being
badly fractured and being hospitalized in katihar medical
college for treatment. Petitioner’s sister belongs to
vulnerable section of the society and has only two minor
daughters. She does not have any male members except her
ailing father. Lead generated, suspicion raised and therefore
moved from Delhi to Bihar for further investigation to
collect prima facie evidence against the perpetrators.
(v) That an attempt of mob lynching has been made against the
petitioner on 30.07.2019 by a group of sex abusers who
have indulgence in sexually abusing her sisters and her
minor daughters. An illegal detention of petitioner has been
made by Kadwa police in this relation. Thereafter petitioner
has submitted an application dated 09.08.2019 to SP
Katihar for registration of an F.I.R. Yet no F.I.R has been
registered by police. Thereafter petitioner has visited the

house of his youngest sister in Katihar on 15.08.2019 and
identified a POCSO case against Ms Anjali a minor girl of
his second sister’s daughter’s daughter residing in Katihar
adjacent to petitioner’s youngest sister’s house at Argara
chowk, Katihar. Petitioner noticed that minor girl Anjali is
being picked up by a Bengali boy on the eve of Muharram
at 10 pm whose mother is working as a domestic cook in
the house of District Judge Katihar. She was sexually
abused and left to her house at around 02:00 AM. Petitioner
asked to alarm the police but parents refused to go either to
police or to any other rescue agencies. Parents Abhay
Poddar and Sweety kumari were scared. Petitioner strongly
blasted on the sex abuser boy and her cook mother. Fierce
fighting took place between petitioner and the abuser
mother. Matter is being suppressed and sexual abuse is
being escalated.
(vi) That during the year long stay (14-06-2021 to 22-04-2022)
in his Bihar House -Asha Deep Niwas Sonaili, Shukkar Hat,
P.S. Kadwa, District Katihar-855114, petitioner has
identified cases of forced hidden prostitution of his own
sisters and cases of child sexual abuse of their minor girls
by the nexus of State and Mafia. It has been done in
retaliation of divorce judgement in favor of petitioner by
Delhi High Court in MAT. APP. 7/2012 with NO COST
and subsequent W.P. (Crl) 136/2016 against the SDJM of
Begusarai Court, Bihar for causing jurisdictional error,
Petitioner’s all three sisters and their minor girls have been
hijacked by different gangsters, mafia, sex abuser and sex

racketeers. There is a possibility of gang war, communal
violence for the sake of illicit sex trade, sex abuse and
usurpation of petitioner’s property with an unlawful means.
(vii) That interaction during rescue operation of minor girls in
Shastri Park area and subsequent inquiry with villagers and
interaction with Pappu Yadav’s aid Sanjay Gupta and
Rajnikant Gupta on 26.02.2022, it has been revealed that all
three sisters of petitioner and their children, the divorced
lady of petitioner and her female minor girl child who were
party in MAT.APPL. 7/2012 before Delhi High Court has
been raped and sexually abused by Sidharth Mohan Jain SP
Katihar amidst Bhagwat inside the house of petitioner on
28.02.2016. Thereafter the divorced lady and her minor girl
being shifted to Mumbai and pushed them into flesh trade.
Sex abuser and mafia are putting gun at the shoulder of her
sisters, divorced lady and their minor girls and holding
triggers in their own hands to achieve the property of
petitioner through an illegal means.
(viii) That during the course of interaction with Pappu Yadav’s
aid Sanjay Gupta and Rajnikant Gupta on 26.02.2022, it has
been revealed that the petitioner’s divorced lady and her
minor girls have been hijacked by a Marwari Jain
Community who have in turn link with trading community
of Purnea district’s Gulabbagh area of Bihar. He further
disclosed that Petitioner’s divorced lady and her minor
girls have been pushed into International prostitution
market. Whatever is happening with the petitioner and his
families along with his all siblings since 2004 is the

outcome of the curse inflicted by these sex racketeers
community. It is pertinent to mention here that petitioner
knew Snjay Gupta since 1989 when he was studying in
Patna. Sanjay came into contact of petitioner in B.N.
College Patna and being noticed by petitioner that Sanjay is
involved in illicit sex trade and Kabara business in Patna
junction area therefore petitioner delinked himself from him
since then. After 30 years of gap, petitioner first time saw
him on 26.02.2022 when Snajay approached his house.
(ix) Prima facie evidence shows that mafia and sex racketeers
have been misused and given false assurance by the State
issuing an order against confiscation of petitioner’s property
u/s 83 Cr.Pc. However, W.P.(Crl) 136/2016 before SC and
CRWJC NO. 1238/2019 before Patna High Court has
falsified state’s false assurance and unconstitutional action.
Now the mafia and sex racketeers are recovering their
money through pushing petitioner’s vulnerable sister’s and
divorced lady’s families into illicit sex trade, sexually
abusing their minor girls, trafficking them in different
locations, physically assaulting them, breaking hands of
younger sister, threatening for dire consequences, forcing
them into hidden prostitution. Apart from this, illicit sex
trade, human trafficking and child prostitution activities are
rampant in the vicinity of Sonaili village. The surrounding
vicinity/locations for illicit sex trade have been mapped and
identified by the petitioner.
(x) That the link between W.P. (Crl) 242/2021 and W.P. (Crl)
137/2021 has been identified and established in this matter.

There is a link between the incident of Sonaili, Katihar
Bihar and Shastri Park North East Delhi. Sonaili is working
as a source point while Shastri Park and Mumbai is working
as a transit or destination point in this sex racket matter.
Petitioner’s second sister’s husband Mr. Agam Poddar S/O
Vishun Deo Poddar is working with a Tourist Company at
Lal Qila Delhi, run by a Chartered Accountant and his wife,
a resident of Rajouri Garden, South Extension and Vasant
Vihar area of Delhi and has indulgence in this sex racket
business.
(xi) That the main perpetrator and mastermind behind this
game is Mr. Manish Raj son in law of Shri Surender
Narayan Poddar Rtd. Assistant Manager, Barauni Refinery,
Indian Oil Corporation and R/O Patna and Chicago
America with Toyota Camry Car registration no. V87 6250
GROSSINGER. Photograph of Mr. Manish Raj along with
car available at Facebook.
True copy of Photograph of Mr. Manish Raj a main
perpetrator and mastermind behind this matter is
annexed herein as Annexure P-2 (Page from 28 to 28).
(xii) That the main Mafia Pappu Yadav a notorious criminal
previous Member of Parliament, A.K. Chaudhary relative of
Nikhil Chaudhary previous BJP Member of Parliament and
Chirag Paswan S/O Late Rambilas Paswan, Minister with
GovernmFent of India, Shakeel Khan Member of legislative
assembly Kadwa, Dulalchand Goswami, Member of

Parliament Katihar, Mukesh Sahni, Welfare Minister with
Government of Bihar, Ashok Agarwal Member of
legislative Council, Government of Bihar, Tarkeshwar
Prasad, Sidharth Mohan Jain SP Katihar, Deputy Chief
Minister Government of Bihar, Veena Birbal Delhi High
Court justice have been identified who have direct or
indirect indulgence in this sex racket. Apart from them all
political parties and Rashtriya Svemn Sewak workers have
also been identified who have direct or indirect indulgence
in this sex racket.
(xiii) That an indulgence in illicit Sex trade and usurpation of
land does not distinguish any religion, caste, class, creed
and Nationality.
(xiv) That the local Sonaili village brokers, pimps, mafia have
been identified. Sunil Kumar Electricity Department
Government of Bihar, Sanjay Gupta pharmacist kadwa
Durgaganj primary Health Centre, defense personnel
Abhinandan Kumar Jha mobile no. 8411010793, Amarnath
Sinha, Thakur Digvijay Singh, Nanki singh, Lalit Singh,
Dilip Kumar R/O Salmari, Advocate Sunil Ojha, Vijay
Kumar postman, Sashi Yadav s/o Arun Yadav having link
with the hotel of siliguri and Palam Airport Delhi, Raju
Gupta, Sonu gupta, monu gupta, Manoj Agarwal, Mukesh
Agarwal, Banti Bubna, Gautam, Shyamal, Amit Ghosh,
Gaurang Ghosh, Jitender Singh, Himraj Singh, Manoj
Singh, Mukesh Singh, Raju Poddar, Gappu Bubna, Arun
Dokania/seth, Mantu seth s/o girdhari seth, Ramparvesh

Mahto, Deepak Mahto, Arvind Kumar Singh, Jata Shankar
Singh, Brajesh Singh, Arun Singh, Uday Singh, Ravinder
Singh, Kapil deo Mahto, Ram Karan Mahto, Narain Mahto,
Munna Paswan, kantiya panchayat mukhiya, Ashkand
Singh, Pintu Yadav, Vinod Sah, Ashok Thakur, Prashant
Thakur, Pappu Thakur, Ram Thakur, Shyam Thakur, Anil
Biswas, Naresh Gupta, Ravi Sah, Gopal Sah, Dinanath Sah
and his son, Rajender Yadav, Chandan Gupta. Ram Kalyan
Singh and his grandson, Avinash Singh, Birender Singh,
Bhola Singh, Ramesh Bind, Bihari Bubna, Ashok Yadav,
Amla Yadav, Sunil Bubna, Leela Nand Poddar, Md. Hasib,
Gultan Sahni, Supen Sahni, Rupak Razak and his son,
Dhruv Razak, Munni alias Saraswati Thakur police
personnel, Viveka Nand Jha, Ajay Pandey, Manju Pandey.
Rita Devi, Rajkumar Gupta, Ashni Mukhiya, Pappu Poddar,
Chand hotel, Milan Bhagat and his son, etc.
(xv) That hot spots for illicit sex trade and forced hidden
prostitution in Sonaili has been identified in Dhangarsi
Gosala in and around Panchayati Raj Institution leader’s
(Mukhiya) house, Sahni tola, Mill of Gappu Bubna near to
petitioners house and godown near to Bubna Board Middle
School of Gappu Bubna, Kapildev Mahto house, Makhana
Industry at Leelanand Poddar’s land occupied by Sahni of
Muzaffarpur, Balram’s common service Centre, Restaurant
of Dinanath Sah, surrounding area of Sonaili railway
station, paswan tola, chandan nagar, bangali tola, malang
sthan, mali tola, pahlagarh, hasona, dokhra, singalpur,
nungara etc.

(xvi) That elected Panchayati Raj Institution leader (Mukhiya) is
manufacturing country liquor very close to the petitioner’s
house and transacting alcohol business without any fear
while alcohol is banned in the state of Bihar.
(xvii) That Sanjay Gupta pharmacist kadwa Durgaganj primary
Health Centre and defense personnel Abhinandan Kumar
Jha mobile no. 8411010793 came to the petitioner’s house
and informed the petitioner that his all sisters and their
children, his divorced lady and her minor girl child have
been forced into hidden prostitution and forced into child
prostitution. Hence, leave this house and agricultural land
for us OR otherwise ready to face dire consequences.
(xviii) That right hand of Pappu Yadav Mr. Sanjay Gupta
pharmacist kadwa Durgaganj primary Health Centre came
along with Rvajnikant Gupta (8320869555) on 26.02.2022
and took a round of every secret nook and corner of the
house and confirmed that petitioner’s all sisters and their
minor girl children, his divorced lady and her girl children
have been sexually abused thoroughly by all dwellers of the
village. Petitioner’s sisters and their children, his divorced
lady and her minor female child have been professionally
trained in the profession of flesh trade. Now petitioner’s
sisters and their children has become professional prostitute.
Hence, leave this house and agricultural land for us OR
otherwise ready to face dire consequences.

(xix) That the petitioner took the cognizance of this offence and
sent an application against this cognizable offence to DGP
Bihar through the WhatsApp No. 9504722750 of Sanjay
Gupta’s on the same day and date 26-04-2022 from Asha
Deep Niwas, Sonaili. The same has been cross checked
telephonically over DGP Control room’s no. 9431602302
/9431602301 through Sanjay Gupta’s mobile no.
9504722750 on the same date and time. However, no F.I.R
being registered by the police till date.
(xx) That the petitioner randomly visited the house of his
youngest sister on 15.10.2021 residing at Argara chowk,
katihar, Bihar. He observed sexual activities and POCSO
related activities between neighbor Mr. Supen Sahni and Ms
Priya a minor daughters of petitioner’s sister. Mr. Supen
Sahni belongs to Pappu Yadav’s gang/group who has
murdered Rama Kant Singh in Katihar.
(xxi) Petitioner’s sisters and their minor daughters are badly
scared by the curse of state and mafia therefore hesitating
and not willing to approach Police or to approach
Magistrate or to give statement through Affidavit to the
petitioner.
(xxii) That petitioner’s livelihood is being attacked by the sex
abusers of his sister’s and divorced lady’s families. As a
result of that petitioner’s agricultural lands remained un-
ploughed. Petitioner’s livelihood is based on farming the
small piece of agricultural land and the same is being hit by
the sex abusers. An application dated 18-01-2022 against

this cognizable offence has been sent to S.P. Katihar
through registered post RF646969821IN for registration of
F.I.R.
True copy of application dated 18-01-2022 to S.P.
Katihar for registration of F.I.R is annexed herein as
Annexure P-3 (Page from 29 to 32).
(xxiii)That looking by standard apathy and inertia of SP Katihar,
petitioner has again sent an application dated 31-01-2022
for this cognizable offence ((attack on the petitioner’s
agricultural land) to SHO Dandkhora Katihar through
registered post RF646969177IN for registration of F.I.R.
True copy of application dated 31-01-2022 to Station
House Officer, Dandkhora, Katihar for registration of
F.I.R is annexed herein as Annexure P-4 (Page from
33 to 36).
(xxiv) That sex abuser A.K. Chaudhry relative of Nikhil
Chaudhry, Ex- BJP MP and Sunil Kumar a contractor with
electricity department, Government of Bihar in sonaili
katihar region has disconnected the electricity of the house
of the petitioner since 12 years in retaliation of whistle
blown against the child sexual abuse and forceful sexual
abuse of his sisters and divorced lady inside the petitioner’s
house. Thereafter S.P. Katihar Sidharth Mohan Jain’s team
gang raped whole families of petitioner and their minor girls
by organizing Bhagwat in front of his house from
28.02.2016 to 06.03.2016. Fax dated 03.03.2016 disclosing
cognizable offence has been sent to SP Katihar from Delhi

by the petitioner for registration of an F.I.R. Yet no F.I.R. is
being registered by the police till date. Information
regarding installation of public toilet inside the house of
petitioner was given by the villagers to the petitioner in
Delhi through WhatsApp dated 28.03.2016 subsequently
Action Taken Report by Police has been annexed herewith
the main petition as Annexure P-2 (page from 75 to 76) and
Annexure P-3 (page from 77 to 81). However, the correct
information is being collected by the petitioner from the
villagers in 2022 and the same is being disclosed by Pappu
Yadav’s aid Sanjay Gupta on 26.02.2022. The petitioner’s
mother and petitioner have been kept in dark since 12 years
as a result of that petitioner’s mother has succumbed to
suspicious death on 11.11.2017 in Delhi.
True copy of application dated 13-10-2013 to Senior
Executive Engineer Electricity Department, Katihar
by the mother of petitioner for reconnection of the
electricity of the house is annexed herein as Annexure
P-5 (Page from 37 to 39).
True copy of application dated 21-02-2022 to Junior
Executive Engineer Electricity Department, Sub
Station Sonaili, Katihar by the petitioner for
reconnection of the electricity of the house is annexed
herein as Annexure P-6 (Page from 40 to 41).
(xxv) That looking by standard apathy and inertia of SP Katihar,
petitioner again sent an application dated 25-02-2022
against this cognizable offence (attack on the petitioner’s
agricultural land) to DGP Bihar through registered post
RF246493894IN dated 26-02-2022 for registration of F.I.R.

True copy of application dated 26-02-2022 to DGP
Bihar for registration of F.I.R is annexed herein as
(xxvi)That Pappu Yadav’s aid Sanjay Gupta, a pharmacist kadwa
Durgagunj Primary Health Centre has disclosed that there is
no record of Injury report in the name of Bechan Poddar
dated 30.07.2019 with the Primary Health Centre,
Durgagunj. On the contrary, Sub Divisional Police Officer
Barsoi claims Injury report in the name of Bechan Poddar
which has been annexed herewith the main petition as an
Annexure P-8 (page from 103-104). An application for
obtaining Injury report has been emailed to the secretary
health department on 30.03.2022 and the same has been
sent through registered post RF286501965IN dated 23-04-
2022 to In- charge Medical Officer, Kadwa Durgaganj
Primary Health Centre. Yet no injury report has been
supplied by the Primary Health Centre Kadwa Durgaganj.
True copy of email dated 30.03.2022 to Additional
Chief Secretary cum Food Safety Commissioner
Health Department Bihar is annexed herein as
True copy of postal registry letter dated 23-04-2022 to
In-charge Medical Officer, Kadwa Durgaganj Primary
Health Centre is annexed herein as Annexure P-9
(Page from 47 to 49).
2. QUESTION(S) OF LAW
That the main questions of Law to be decided in this petition
are:-

a) Whether or Not criminal trespass by SP Katihar Sidharth
Mohan Jain and his team members on 28.02.2016 into the
house of petitioner in the garb of Bhagwat for gang raping
his whole families and their minor girls and throwing them
amidst the public crowd for flesh trade is a cognizable
offence and attracts an F.I.R with severe penal provisions
against this delinquent police officer?
b) Whether or Not criminal trespass by Pappu Yadav’s aid
Sanjay Gupta and Rajnikant Gupta on 26.02.2022 into the
house of petitioner with an ulterior motive for usurping his
property and sexually abusing his whole families and their
minor girls, his divorced lady and her minor girls inside his
house is a cognizable offence?
c) Whether or Not after receiving information disclosing a
cognizable offence through the WhatsApp of Sanjay Gupta
dated 26-02-2022 subsequently no action taken by DGP
Bihar commissioning a cognizable offence under section 166
of Indian Penal Code 1860?
d) Whether or Not persistently commissioning cognizable
offences against the petitioner and his mother and forcing his
vulnerable families into the mud of prostitution and
persistently sexually abusing their girl child and not
registering any F.I. R against the perpetrators since 2011 is
violating Rule of Law, human rights and principles of
natural justice?

e) Whether or Not disconnecting the electricity of the
petitioner’s house since 2011 without any reason attracting
penal provisions against the perpetrators electricity
department and contractor?
f) Whether or Not non-availability of injury report of Bechan
Poddar with Primary Health Centre Durgagunj, Kadwa
establishes the fact of an ulterior motive of police to book
the petitioner behind the bar and sexually abuse his whole
families in front of his eyes to instigate him for committing
suicide or losing mental balance is violating Rule of Law,
human rights and principles of natural justice?
3. GROUNDS
That being aggrieved by the abuse of police power, violation of
provision under section 154(1) and 157(1) of Criminal
Procedure Code, non-registration of F.I.R for the cognizable
offence against the accused and for supply of framed incorrect
Police Action Taken Report (ATR) dated 07th
May, 2016, 10th
February, 2018, 15th
February 2018, 16th
May, 2018, 20th
September, 2019, 14th
March, 2020 and 31st
October, 2020 with
intent to cause injury to the petitioner, the petitioner is
challenging the same on the following amongst other grounds: -
A. BECAUSE the entry of Pappu Yadav’s man Sanjay
Gupta and Rajnikant Gupta into the house of petitioner
on 26.02.2022 and inspecting the every secret nook and
corner of his house, disclosing the facts of forced hidden
prostitution, illicit sex trade of petitioner’s whole

families and sexual abuse of their minor girls is evident
of this fact that the sexual abuse and usurpation of land
was the main reason for continuous criminal attack on
the petitioner and his mother thereafter no registration of
F.I.R by police.
B. BECAUSE minor girls Priya, Diksha and Anjali are
scared to record their statement against the sex abusers
therefore counselling technique to be used to remove her
fear.
C. BECAUSE there is an obvious link between Sonaili,
katihar Bihar and Shastri Park Delhi’s incident therefore
additional grounds are necessary to answer the main
questions of law related to this petition. There is a
substantive reason before court to exercise power under
Article 32 of the Constitution.
D. BECAUSE rescue of scared minor girls from the
clutches of sex abusers is the responsibility of State
therefore additional grounds demands for immediate
intervention by state.
E. BECAUSE petitioner’s sisters, his divorced lady and
her minor female girl child have been pushed into flesh
trade in retaliation of W.P.(Crl) 136/2016 against
Begusarai Judge and divorce judgment by Delhi High
Court in MAT. APPL. 7/2012 with NO COST.

F. BECAUSE petitioner’s sisters have been pushed into
prostitution for recovery of money by the state after
losing the case in MAT. APPL. 7/2012 before Delhi
High Court.
G. BECAUSE consent for sexual abuse of petitioner’s
sisters has either been taken by force or by intimidation
or by physical assault or by temptation or with false
assurance of property by the sex racketeers.
H. BECAUSE persistent abuse of police power and
subsequent W.P.(Crl) 137/2021 is the result of sexual
abuse of petitioner’s whole families and sexual abuse of
their minor girls by government officials, mafia, public
and sex racketeer.
I. BECAUSE electricity of the house of the petitioner
has been disconnected since 12 years for blowing whistle
against the prostitution inside the petitioner’s house.
J. BECAUSE non availability of injury report of Bechan
Poddar with Primary Health Centre Durgaganj, Kadwa is
evident of this fact that an attempt of mob lynching and
illegal detention by police was an organized act of state
and mafia.
K. BECAUSE criminal conspiracy against petitioner’s
family has been meticulously designed by the nexus of
state and mafia to wipe out the petitioner’s whole family.

PRAYER
It is most respectfully prayed that this Hon’ble Court may be
pleased to:
(a) Allow the petitioner to take additional
facts/grounds/Annexures/respondents/prayers to answer the
question of law raised in the Writ Petition (Criminal)
137/2021 or to make out grounds urged in the Writ Petition
(Criminal) 137/2021 for consideration of this Hon'ble Court
as the same is very necessary in the interest & furtherance of
justice.
(b)To set aside the order dated 25-10-2021 in W.P.(Crl)
242/2021 and tag this matter with W.P.(Crl) 137/2021 and
consider all prayers of W.P.(Crl) 242/2021 along with
W.P.(Crl) 137/2021 and Crl.M.P.NO……….OF 2022 for
additional grounds to bust a larger international sex racket.
(c) To issue a writ of mandamus or other appropriate writ order
or direction directing respondent No.02 in W.P.(Crl)
242/2021 Chief Secretary, Government of NCT of Delhi and
respondent No.02 in W.P.(Crl) 137/2021 Chief Secretary,
State of Bihar to rescue and rehabilitate the victim minor
girls immediately till the investigation team constituted by
this Hon’ble Court or the investigation process resumes and
completes.
(d)To issue a writ of mandamus or other appropriate writ order
or direction directing respondent No.02 Chief Secretary,
State of Bihar and respondent no. 04 Director General of

Police Bihar and respondent no.07 Superintendent of Police
Katihar to initiate cleanly drive for closing down hot spots of
widespread flourishing industry of prostitution, child sexual
abuse, illicit sex trade, manufacturing of country liquor,
illicit sale of liquor in Sonaili village and its surrounding
areas as it works as a source point for human trafficking,
illicit sex trade and for the betterment of just and equitable
society and in the interest of healthy India.
(e) Constitute a Commission of Enquiry under the supervision
of Hon’ble Supreme Court of India or refer this matter to the
expert committee and task force to study and recommend the
Government of India for formulating an effective policy, an
effective intervention strategy to remove the fear factor from
the mind of victims and whistle blowers to approach police,
Magistrate for recording statement, an effective institutional
arrangements to stop this bug at initial stage to check and
balance the rapidly flourishing illicit sex trade, child sexual
abuse, forced hidden prostitution in almost every households
across the country.
(f) To issue a writ of mandamus or other appropriate writ order
or direction directing respondent No. 2 and 4 to initiate
action against respondent no. 7 delinquent police official
Sidharth Mohan Jain SP Katihar for rape, sexual abuse of
minor girl child, illicit sex trade, human trafficking and
forcing petitioner’s whole families into hidden prostitution
in international market and issue a dismissal order against
the guilty Public authorities and delinquent police officials in
the larger interest of all children across country.

(g)To issue a writ of mandamus or other appropriate writ order
or direction directing respondent No. 2, 4, 7 and 8 to initiate
action against respondent no. 11 delinquent SHO Dandkhora
for hitting and attacking the livelihood/agricultural land of
petitioner and not registering an F.I.R even after receiving an
information disclosing cognizable offence against the
accused/sex abusers.
(h)To issue a writ of mandamus or other appropriate writ order
or direction directing respondent No.02, 12 and 13 to initiate
action and register an F.I.R under relevant penal provision
against respondent no. 14 Junior Executive Engineer Kadwa
and contractor Sunil Kumar, A.K. Chaudhry for rape, sexual
abuse of minor girl child, illicit sex trade, human trafficking
and forcing petitioners whole families into hidden
prostitution in international market and issue a dismissal
order against the guilty Public authorities and delinquent
officials in the larger interest of all children across country.
(i) To issue a writ of mandamus or other appropriate writ order
or direction directing respondent No.02, 12 and 13 to order
respondent no. 14 to resume the electricity service of the
petitioner’s house immediately.
(j) To issue a writ of mandamus or other appropriate writ order
or direction directing respondent No.02, 15 and 16 to
initiate action and register an F.I.R under relevant penal
provision against respondent no. 17 In charge Medical
Officer, Kadwa Durgaganj Primary Health Centre and his
pharmacist cum international sex racketeer Mr. Sanjay
Gupta for rape, sexual abuse of minor girl child, illicit sex

trade, human trafficking and forcing petitioner’s whole
families into hidden prostitution in an international market
and issue a dismissal order against the guilty Public
authorities and delinquent officials in the larger interest of all
children across country.
(k)To issue a writ of mandamus or other appropriate writ order
or direction directing respondent No.02, 15 and 16 to
respondent no. 17 to file an injury report dated 30.07.2019 of
Shri Bechan Podaar against the Mob lynching attempt of
petitioner dated 30.07.2019.
(l) 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:
OM PRAKASH
S/O LATE SHRI DEEP NARAYAN PODDAR
S/O LATE SRIMATI ASHA RANI DEVI
ASHA DEEP NIWAS, SONALI, SHUKKAR HATT,
IN FRONT OF DURGA MANDIR, KANTIYA PANCHAYAT,
P.S. KADWA, KATIHAR, BIHAR-855114
MOB: 9540389759
NEW DELHI:
FILED ON : 30-04-2022
Diary No.:

Annexure P-1
CRL. M.P.NO……………………….OF 2022
IN
WRIT PETITION CRIMINAL NO.137 OF 2021
AND
IN THE MATTER OF ABUSE OF
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 47
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.

2. That the contents of the accompanying Application for
Additional grounds in W.P. (Crl) 137/2021 under Article 32
of Constitution of India against the International sex racket
which has been drafted by me [para 01 to 03], [Page 01 to
49] and Synopsis and List of Dates (Page O to Q], 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 annexures P-01 to P-09 [Page 26 to 49] are true
copies of their respective original.
4. That the Application for additional grounds in W. P. (Crl)
137/2021 Paper Book contains total 49 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 29th
day of April, 2022.
DEPONENT

Annexure: P-1
True copy of order dated 25.10.2021 in W.P. (Crl) 242/2021by
SUPREME COURT OF INDIA AGAINST CHILD SEXUAL ABUSE OF
MINORS.

Annexure: P-2
True copy of Photograph of Mr. Manish Raj a main
perpetrator and mastermind behind this matter is
annexed herein as Annexure P-2 (Page from 28 to 28).

Annexure: P-3
18-01-2022
To,
Superintendent of Police
Katihar, Bihar
Subject: An application for F.I.R u/s 154(1) Cr.Pc.
Sir,
1. Applicant is Om Prakash S/O Late Deep Narayan Poddar,
mother Late Asha Rani Devi, age 47 years R/O Asha Deep
Niwas, Shukkar Hatt, Durga Sthan, Kantiya Panchayat,
Sonaili, P.S Kadwa, Katihar and rented R/O RZF-893, Netaji
Subhas Marg, Raj Nagar Part-2, Palam Colony, New Delhi-
77.
2. Applicant has filed W.P.(Crl) 137/2021 against Union of
India before Supreme Court of India and CRWJC NO.
1238/2019 against State of Bihar before Patna High Court
which is still pending before the court.
3. Parents of applicant have succumbed to suspicious death and
alone he is managing his property as well as his pending
matters in the court. Parents of applicant has left small piece
of agricultural land in Bhelai and Nijhra circle for his
livelihood.
4. That there is a hut of Shri Anil Thakur S/O Bangtu Thakur
R/O Tilas, P.S. Dandkhora in front of applicant’s agricultural

land in which he is residing along with his families and
designing criminal conspiracy against petitioner every day.
5. Accused No.01 Anil Thakur has taken land on lease from
Kanahiya Bhagat S/O Jibach Bhagat for agricultural
purposes adjacent to the land of petitioner. Taking benefit
out of it, he and his son Tun Tun Thakur has criminal
trespassed into the land of applicant and caused severe
damage and loss, illegally cut/mined the soil of applicant
land around 100x5 feet long and wide and lifted it for his
own purpose without the consent or permission of applicant.
6. Prior to that Anil Thakur with an active help of Banti Bubna,
petrol pump owner of sonaili has looted all crops of
applicant against whom police complaint is pending since
2011 and no F.I.R has been registered against the perpetrator
by the police yet.
7. Accused no.02 petrol pump mafia Banti Bubna R/O Sonaili
has sent his servant Kishandeo Mandal and his son Tinku
mandal R/O Tilas P.S. Dandkhora five times at the resident
of applicant with a proposal of oppressive contract farming.
Applicant has strongly protested against this.
8. As a result of that violent like situation has been created in
and around the agricultural land of applicant which has
resulted in loss of livelihood. Single source of livelihood has
been spoiled to kill the applicant in the garb of COVID-19
pandemic.

9. Due to Wrongful assembly of people and violent like
situation, applicant has compelled to leave his agricultural
land un-ploughed.
10.Accused no. 03 is Suresh Yadav and his wife and his tenant
R/O Tilas, P.S Dandkhora has criminal trespassed into the
agricultural land of applicant and has ploughed the 50 year
old demarcation of land and encroached 10 feet of land.
11.Accused no. 03 have caused wrongful assembly of people
and violent like situation against the applicant which has
resulted in loss of livelihood of applicant.
12. You should aware that an attempt of mob lynching has
taken place against the applicant at his residence and no
F.I.R has been registered by the police yet.
13. This is same group who wanted to purchase the land of
applicant forcefully. Morale of this group is very high and
slowly reaching near to the agricultural land of applicant.
14. This is a group of land mafia who are playing a tactics of
disputing the undisputed land to compel the applicant to sale
the land in the hand of land mafia.
-: Prayer:-
15. In the above premises register an F.I.R against the above
named accused u/s 154(1) Cr.Pc. to diffuse criminal
conspiracy to kill the applicant and usurp his agricultural
land.

Sonali Bazar Applicant
18-01-2022 Om Prakash
Father-Late Deep Narayan Poddar
Mother-Late Asha Rani Devi
Asha Deep Niwas
Shukkar Hatt, Durga Sthan
Sonaili Bazar, P.S. Kadwa
Barsoi Sub Division, Kantiya Panchayat
District-Katihar, Bihar-855114
Mobile- 9540389759

Annexure: P-4
31-01-2022
To,
Station House Officer
Dandkhora Katihar, Bihar
Subject: An application against instigating for physical violence,
criminal trespass into the agricultural land, looting crops, illegal
cutting/mining and lifting of soil, breaking and ploughing of 50
year old demarcation of land and criminal conspiracy to kill the
applicant.
Sir,
1. Applicant is Om Prakash S/O Late Deep Narayan Poddar,
mother Late Asha Rani Devi, age 47 years R/O Asha Deep
Niwas, Shukkar Hatt, Durga Sthan, Kantiya Panchayat,
Sonaili, P.S Kadwa, Katihar and rented R/O RZF-893, Netaji
Subhas Marg, Raj Nagar Part-2, Palam Colony, New Delhi-
77.
2. Applicant has given information disclosing a cognizable
offence to SP Katihar through India Post registry letter no
RF646969821IN dated 18-01-2022 and Bihar Police help
Line token no 202201220004 dated 22-01-2022.
3. After receiving information of cognizable offence, police has
not taken any action against the accused.
4. Accused no.01 is Banti Bubna R/O Sonaili, P.S. Kadwa,

Rani Sati petrol pump sonaili
Accused no.02 is Anil Thakur S/O Bangtu Thakur
Accused no.03 is Tuntun Thakur S/O Anil Thakur
Accused no.04 is Kishandev Mandal S/O Unknown
Accused no.05 is Tinku Mandal S/O Kishandev Mandal
Accused no.06 is Suresh Yadav S/O Govind Yadav
Accused no.07 is Susheela Devi W/O Suresh Yadav
Accused no.08 is Dhiren Sharma S/O unknown
Accused no.02 to 08 is R/O Tilas P.S Dandkhora
5. That Anil Thakur has done illegal mining/drilling of
100x5x2 feet land and lifted this soil for own purposes.
When protested then instigated for physical violence and
conspired to murder the applicant. This is an event of
17.01.2022.
6. Banti bubna is directly connected to applicant’s 17 year old
enemy Surender Narayan Poddar S/O unknown R/O
Begusarai ex manager Baruani Refinery IOCL whom
applicant has defeated in Delhi High Court and a case of
criminal conspiracy still pending against him. Kishandev
Mandal is servant of Banti Bubna and R/O Tilas. Tinku
Mandal is son of Kishandev Mandal and close to Anil
Thakur. Taking benefit out of it these people asked for the
land of applicant, after denial by the applicant looted his
crops, illegally mined cut the soil of the land and caused
huge damaged to the land, instigated for physical violence to
kill the applicant.
7. Since there is a judge in Surender Narayan’s family therefore
police is not taking any action against him since 2011. As a
result of that applicant has filed CRWJC NO. 1238/2019
against State of Bihar before Patna High Court and

W.P.(Crl) 137/2021 against Union of India before Supreme
Court of India.
8. Parents of applicant has succumbed to suspicious death and
now conspiring to kill the applicant.
9. Banti Bubna R/O Sonaili has sent his servant Kishandeo
Mandal and his son Tinku mandal R/O Tilas P.S. Dandkhora
five times at the resident of applicant with a proposal of
oppressive contract farming. Applicant has strongly
protested against this.
10.In retaliation of that looted crops of applicant, illegally
mined the soil and instigated for physical violence.
Applicant being compelled to keep his land un-ploughed.
Yet applicant has ploughed and sown wheat in ½ bigha of
land which is prone to be looted and prone to be caused
damaged and loss to the crops.
11. Suresh Yadav and his wife and his tenant R/O Tilas, P.S
Dandkhora has criminally trespassed into the agricultural
land of applicant and has ploughed the 50 year old
demarcation of land and encroached 10 feet area of land.
12.Anil Thakur and his family member has intentionally broken
the demarcation of land, caused severe damage and loss and
instigated for physical violence.
13.Intention of accused no 01 to 08 is crystal clear-dispute the
undisputed land, instigate for physical violence, cause huge
damage and loss to the land, stop ploughing of land and
conspire to kill the applicant.

14.All events come under the category of cognizable offence
which is punishable under different sections of IPC.
Hence, request to register an F.I.R against the accused no
01 to 08 under relevant sections of IPC.
Sonali Bazar Applicant
31-01-2022 Om Prakash
Father-Late Deep Narayan Poddar
Mother-Late Asha Rani Devi
Asha Deep Niwas
Shukkar Hatt, Durga Sthan
Sonaili Bazar, P.S. Kadwa
Barsoi Sub Division, Kantiya Panchayat
District-Katihar, Bihar-855114
Mobile- 9540389759

Annexure: P-5
True copy of application dated 13-10-2013 to Senior Executive
Engineer Electricity Department, Katihar by the mother of
petitioner for reconnection of the electricity of the house

Annexure: P-6
21-02-2022
To,
Junior Executive Engineer
Electricity Department Bihar
Sub-Station, Sonaili, Katihar
Subject: Application for Reconnection of consumer no. DS-356
(10230000226).
Sir,
1. Sub-station Sonaili, electricity Department has disconnected
the consumer no. DS-356 since May 2011 without any
information and without any prior NOTICE.
2. Applicant has registered an online complaint no.
CSPGC/BIH/00551 dated 16-10-2012 with Electricity
Department Bihar.
3. Thereafter the same information has been sent to Chief
Executive Engineer Katihar, Chairman and Managing
Director North Bihar Power Distribution Company Limited,
Patna Bihar through registry postal letter no.
EF549376643IN, EF549376626IN and EF549376630IN
dated 03-10-2013. (Copy enclosed).
4. There are no bills pending against the consumer. Applicant
has got payment receipt of electricity bills till March 2013.
(Copy enclosed).

5. This is an unmetered house.
Hence, praying to reconnect the connection immediately.
Sonaili, Katihar Applicant
21-02-2022 S/O Late Deep Narayan Poddar
Asha Deep Niwas
Shukkar Hat Sonaili, Katihar
Mobile: 9540389759

Annexure: P-7
26-02-2022
To,
DGP, Bihar
Confidential Branch
Bihar Police Head Qurater
Patna, Bihar
Subject: Application for Direction for registration of an F.I.R.
Sir,
1. That the information disclosing cognizable offence has been
given to SP Katihar, SHO Kadawa and Dandkhora Katihar
through Indian postal registry letter, e-mail, fax, police
helpline and by hand since 2011. After receiving information
disclosing cognizable offence, no F.I.R has been registered
by police yet.
2. Father of applicant has succumbed to suspicious death on
15.11.2007 and Mother of applicant has succumbed to
suspicious death on 11.11.2017. Now, applicant is surviving
alone and facing life threat continuously.
3. Persistent life staking attack, persistent attempt to murder,
persistent criminal conspiracy for murder, persistent attempt
for mob lynching to usurp property illegally, instigating for
physical violence causing damage and loss to the property,
illegal detention by police, assault or criminal force with
intent to dishonor, defamation, Intentional insult with intent

to provoke breach of the peace, criminal intimidation, house-
trespass and criminal trespass on the house and agricultural
land, Printing or engraving defamatory matter like public
toilet on the wall of the house of entry gate, Police
disobeying law, Police framing an incorrect document with
intent to cause injury, House-trespass in order to commit
death of mother, wrongful confinement of petitioner,
Causing grievous hurt by act endangering life or personal
safety of applicant and infringement of Article 21 are main
attraction of this application.
4. An application through Police Helpline token no.
201907300045 dated 30-07-2019, 20210313009 dated 13
march 2021 and token no. 202202090016 dated 09 February
2022 is gathering dust with I.G Darbhanga since 2019.
5. An application dated 7th
April 2011 sent through Indian
registry letter no. B3388 to SHO Kadwa is gathering dust
since then.
6. An application through email dated 7th
April 2011, 16th
July
2011, 3rd
August 2011, 29th
September 2011 and 31st
December 2012 is gathering dust with SP Katihar.
7. An application through Fax Job No-0543 dated 3rd
march
2016 is gathering dust with SP Katihar.
8. An application has been delivered by hand to SP Katihar
office on 09.08.2019.

9. An application sent through Indian registry letter no.
RF646969821IN dated 18th
January 2022 gathering dust with
SP Katihar.
10. An application sent through Indian registry letter no.
RF646969177IN dated 31st
January 2022 gathering dust with
SHO Dandkhora, Katihar.
11.If no F.I.R is registered even after two suspicious deaths then
suspicious death of applicant is certain.
12.Above mentioned all pending application comes under the
category of cognizable offence which is punishable under
relevant provisions of IPC.
Hence, praying to direct to register an F.I.R against main
accused Surender Narayan Poddar and others u/s 120B, 307,
355, 500,504,506,448,447,338,427,501,166,167,34,449 and
342.
Asha Deep Niwas
Shukkar Hat Sonaili, Katihar
Mobile: 9540389759

Annexure: P-8
True copy of email dated 30.03.2022 to Additional Chief Secretary
cum Food Safety Commissioner Health Department Bihar

Annexure: P-9
23-04-2022
To,
The In charge
Medical Officer, Kadwa
Primary Health Centre (PHC)
Durgaganj, Katihar, Bihar
Subject: Application for obtaining MLC/Injury Report dated 30th
July 2019 of Shri Bechan Poddar for Court purposes-reg.
Sir,
6. That the undersigned applicant is petitioner-in-person in
W.P.(Crl) 137/2021 before Supreme Court of India as well
as an accused in this medico legal case dated 30th
July 2019
held at primary health center (PHC) Durgagunj, Kadwa,
Katihar, Bihar. The same can be verified through the official
website of Supreme Court of India viz. www.sci.gov.in and
further can be verified through the Action Taken Report
dated 20th
September 2019 by Sub-Divisional Police officer,
Barsoi, Katihar, Bihar (copy enclosed).
7. That the said police Action Taken Report dated 20.09.2019
has been framed against the applicant therefore it has been
challenged before the Supreme Court of India in W.P.(Crl)
137/2021.

8. As per the police Action Taken Report (ATR) dated
20.09.2019, MLC/Injury report dated 30th
July 2019 of Shri
Bechan Poddar S/O Late Sahdev Poddar, R/O Shukkar Hatt,
Sonaili, Katihar has been attended and prepared by the
Primary Health Centre (PHC) Durgagunj, Kadwa, Katihar,
Bihar.
9. However, upon telephonic (8877776511) inquiry dated 28-
03-2022 with Mr. Vikas kumar, on duty in charge in the
night of 30th
July 2019 at PHC Durgagunj, Kadwa, Katihar,
Bihar, it has been revealed that no Medico-Legal-Case in the
name of Shri Bechan Poddar has been attended and
registered at the PHC Durgagunj, kadwa in the night of 30th
July 2019 therefore no Injury report is available for the same
with the PHC Kadwa.
10.Since the police ATR dated 20.09.2019 is false and
fabricated therefore MLC/Injury report dated 30-07-2019 if
prepared by PHC Durgagunj Kadwa, requires to be placed
before the court of law for cross examination.
11.Applicant therefore is seeking following information from
PIO-Cum-In charge medical officer, PHC Durgagunj
Kadwa, Katihar, Bihar:-
a) Whether or NOT injured Bechan Poddar has been
brought by Kadwa Police and attended by the PHC
Durgagunj, Kadwa in the night of 30th
July 2019?
b) If yes, then details thereof, and supply the Injury Report
dated 30th
July 2019 of Shri Bechan Poddar?

c) If no, then details thereof, and supply the non-availability
of official record for MLC/Injury report dated 30th
July
2019 of Shri Bechan Poddar?
12.If the sought information in para 06 is not supplied by the
PIO-Cum-In charge medical officer, PHC Durgagunj Kadwa
to the applicant then applicant will be bound to seek help
from the court to acquire the same in the furtherance of
justice.
Asha Deep Niwas
Shukkar Hat Sonaili, Katihar, Bihar
Mobile: 9540389759
Copy to: CS Katihar, Bihar

CRL.M.P.NO. 66697 OF 2022
IN
AND
IN THE MATTER OF
LYNCHING.
AND
IN THE MATTER OF:
VERSUS
APPLICATION FOR URGENT HEARING IN WRIT
PETITION (CRIMINAL) 137/2021
To
1. That the jurisdiction of matter pertains to two states
viz. Bihar and Delhi, hence Article 32 has been invoked
because the victim mother Srmt. Asha Rani Devi,
Petitioner no.02 in W.P. (Crl.) 136/2016 before Supreme
Court of India belongs to Bihar jurisdiction and has been
declared Proclaimed Absconder by the state of Bihar and

has succumbed to suspicious death in Delhi jurisdiction in
2017. Petitioner himself has been declared Proclaimed
Absconder by the state of Bihar and belongs to Delhi
jurisdiction. As a result of that her property in Bihar is
continuously offended by the nexus of state, mafia and sex
abusers for sale. No F.I.R has been registered either by
Delhi or by Bihar jurisdiction till date and her property has
become no man’s land now.
2. That a fresh cause of action like forced hidden prostitution,
child sexual abuse, illicit sex trade, human trafficking of his whole
families by the nexus of State, Mafia and international sex
racketeers have arisen in the state of Bihar which has attracted for
urgent hearing of the matter.
3. That since the matter is against the judicial family of Bihar
therefore the nexus of state, mafia and sex abusers are consistently
infringing Article 21 of petitioner evading the Rule of Law, hitting
his livelihood in Delhi as well as in Bihar, making his life
miserable, disconnecting the electricity of his house since 2011,
planning to kill him, looting his agricultural crops worth Rs. 2.5
lakh which was the only source of his livelihood, offending his
farm land with illegal soil lifting causing a huge damage and loss
to his farm land, instigating villagers against him, creating a violent
like situation against him in and around his agricultural farm land,
as a result of that his farm land remained without ploughing; which
has resulted in Police complaint before S.P. Katihar under section
154(1) Cr.Pc. through a registered India post consignment no.
RF646969821IN dated 18-01-2022 and Bihar Police helpline

complaint Token no. 202201220004 dated 22-01-2022. Yet, no
F.I.R has been registered against the accused so far.
4. That after the final order dated 14-09-2020 passed in M.A
1446/2020 in W.P. (Crl.) no.136/2016 by Supreme Court of India;
a fresh petition W.P. (Crl.) no.137/2021 and W.P. (Crl.)
no.242/2021 have arisen for rescue of minor girls from the clutches
of sex abusers and enforcement of rights under Article 21 of the
petitioner.
5. That in W.P. (Crl.) no.136/2016, Patna High Court was
given responsibility to enforce Article 21 of the petitioner but
Patna High Court failed to do so in CRWJC NO. 1238/2019.
6. That instead of enforcing Article 21, the nexus of State,
mafia and sex racketeers have sexually abused and pushed his
whole families into prostitution and flesh trade, organized mob
lynching of the petitioner in 2019, as a result of that M.A.
1446/2020 in W.P. (Crl.) no.136/2016 has arisen before Supreme
Court of India.
7. That Patna High Court and state police are more interested in
securing land registration deed and legal heir from the petitioner
rather than enforcing his Article 21 therefore continuously engaged
in forcing him to sale the land, continuously engaged in making it a
civil dispute and converting it into land dispute.
8. That the main accused Shri Surendra Narayan Poddar
annexed as Annexure P-1 with the main petition belongs to judicial
family of Bihar therefore he is continuously engaged in suspending
Article 21 of the petitioner through flexing muscles, evading the

Rule of Law with the active support of local police, local leaders,
local mafia, local advocates and local judges.
9. That the extreme of muscle flexing has been manifested
through movement of vehicles of local police and judges in and
around the agricultural farm land of petitioner, instigating local
villagers against the petitioner and creating a violent like situation
for him.
10. That petrol pump mafia Shri Banti Bubna, owner of Rani
Sati Petrol pump Sonaili, R/O sonaili, P.S Kadwa annexed as
Annexure P-2 with the main petition is the right hand of main
accused Shri Surendra Narayan Poddar. Shri Banti Bubna has sent
his servant shri Kishandev Mandal and Tinku Mandal R/O Tilas,
P.S. Dandkhora, a local villagers residing near to the agricultural
farm land of petitioner with an oppressive proposal of contract
farming at the residence of petitioner five times. Petitioner strongly
protested against it and refused to accept it.
11. That in retaliation of refusal by the petitioner, state and
petrol pump mafia Shri Banti bubna looted and ransomed the
agricultural crops of petitioner worth Rs. 2.5 lakh in 2021, which
was the only source of his livelihood. As a result of that petitioner
compelled to leave his agricultural land without ploughing this
year. Now petitioner has been left to starve to death or to cow
down before oppressive contract farming proposal or to leave his
land without ploughing or to sale it out in the hands of land mafia.
12. After looting the crops worth Rs. 2.5 Lakh, state and mafia
instigated local villagers, sex abusers against the petitioner and

created violent like situation in and around his agricultural farm
land. As a result of that he lost his livelihood.
13. That state, mafia and sex abuser are planning to kill the
petitioner as they have hijacked his whole families by pushing
them into flesh trade and forced hidden prostitution to make this
case defunct and meaningless forever.
14. That under the above facts and circumstances, urgent hearing
is necessary in the furtherance of justice to make this case
meaningful.
PRAYER
pleased to:
(m) Allow this application for urgent hearing in Writ
Petition (Criminal) 137/2021.
(n) Pass such other order/orders as this Hon'ble Court may deem
DRAWN & FILED BY:
OM PRAKASH
MOB: 9540389759
NEW DELHI:
FILED ON : 30-04-2022
Diary No.:

CRL.M.P.NO. 66697 OF 2022
IN
AND
IN THE MATTER OF
LYNCHING.
AND
IN THE MATTER OF:
VERSUS
AFFIDAVIT
under:-

2. That the contents of the accompanying application Under
Section 151 C.P.C. for urgent hearing in Writ Petition
(Criminal) 137/2021, which has been drafted by me [para 01
to 14], [Page 50 to 54] 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 7 pages.’
DEPONENT
VERIFICATION:
therefrom.
day of April, 2022.
DEPONENT

CRL.M.P.NO. 66686 OF 2022
IN
AND
IN THE MATTER OF
LYNCHING.
AND
IN THE MATTER OF:
VERSUS
AFFIDAVIT
under:-

Section 151 C.P.C. for impleadments in Writ Petition
DEPONENT
VERIFICATION:
therefrom.
day of April, 2022.
DEPONENT

CRL.M.P.NO. 66695 OF 2022
IN
AND
IN THE MATTER OF
LYNCHING.
AND
IN THE MATTER OF:
VERSUS
APPLICATION FOR SEEKING PERMISSION TO ADD
ADDITIONAL LIST OF DATES IN WRIT PETITION
(CRIMINAL) 137/2021
To
1. That the jurisdiction of matter pertains
to two states viz. Bihar and Delhi, hence Article 32
has been invoked because the victim mother Srmt.
Asha Rani Devi, Petitioner no.02 in W.P. (Crl.)
136/2016 before Supreme Court of India belongs to
Bihar jurisdiction and has been declared Proclaimed
Absconder by the state of Bihar and has succumbed
to suspicious death in Delhi jurisdiction in 2017.
Petitioner himself has been declared Proclaimed

Absconder by the state of Bihar and belongs to Delhi
jurisdiction. As a result of that her property in Bihar
is continuously offended by the nexus of state, mafia
and sex abusers for sale. No F.I.R has been registered
either by Delhi or by Bihar jurisdiction till date and
her property has become no man’s land now.
2. That a fresh cause of action like forced hidden prostitution,
child sexual abuse, illicit sex trade, human trafficking of
petitioner’s whole families by the nexus of State, Mafia and
international sex racketeers have arisen in the state of Bihar
which has resulted in adding additional List of Dates from O
to Q numbered in the application for additional grounds.
PRAYER
pleased to:
(o) Allow this application and permit the petitioner to add
additional list of dates from page no. O to Q in Writ Petition
(Criminal) 137/2021 to answer the main question of law.
(p) Pass such other order/orders as this Hon'ble Court may deem
DRAWN & FILED BY:
OM PRAKASH
MOB: 9540389759
NEW DELHI:
FILED ON : 29-04- 2022
Diary No.:

CRL.M.P.NO. 66695 OF 2022
IN
AND
IN THE MATTER OF
LYNCHING.
AND
IN THE MATTER OF:
VERSUS
AFFIDAVIT
under:-

Section 151 C.P.C. for list of dates in Writ Petition
DEPONENT
VERIFICATION:
therefrom.
day of April, 2022.
DEPONENT

Applications for intervention OR impleadments in W.P. Criminal 137 of 2021 before Supreme Court of India .pdf

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Applications for intervention OR impleadments in W.P. Criminal 137 of 2021 before Supreme Court of India .pdf