Complaint against Ministry of Home Affairs, Union of India for suppressing the rescue of Gang Rape Victims & keeping them hostage for illicit sex trade

1. To
The Chairperson
National Human Rights Commission
New Delhi
Sub: Complaint against Ministry of Home Affairs, Union of
India for suppressing the rescue of Gang Rape Victims &
keeping them hostage for illicit sex trade-reg.
Sir/Madam,
1. That under signed is OM PRAKASH S/O Late Shri Deep
Narayan Poddar, Age about 48 years, R/O Asha Deep Niwas,
Shukkar Hatt, Sonaili Village, P.S. Kadwa, District Katihar,
Bihar-855114 and R/O RZF-893, Netaji Subhash Marg, Raj
Nagar Part-2, Palam Colony, New Delhi-110077 and Petitioner-
in-Person in the Prostitution matter in Writ Petition (Criminal)
No. 242/2021, Interlocutory Application No. 66686/2022 in
Writ Petition (Criminal) No. 137/2021 and Writ Petition
(Criminal) Diary No. 18546/2022 before Supreme Court of
India.
2. That after dismissal of anti-prostitution PIL Writ Petition
(Criminal) No. 242/2021 on 25.10.2021, individual Writ
Petition (Criminal) No.137/2021 on 02.05.2022 and filing of
fresh anti-prostitution Writ Petition (Criminal) D. No.
18546/2022 on 07.06.2022 and 14.06.2022, the petitioner has
been constantly and thoroughly attacked by the sex abusers of
his families. Sex abusers of his families has obstructed him in

2. doing rescue operation of victims and assaulted physically
several times causing him severe internal injury at Sonaili,
Katihar Bihar and Church Mission Road, Fatehpuri, Old Delhi.
Crime is reported, yet no FI.R by Police.
3. That Sex abusers of families of petitioner pelted stone,
planted bomb inside house, assaulted physically, tortured
mentally, stigmatized socially, boycotted socially, attacked
property, encroached and ploughed agricultural land, ransomed
crops, pressurized to sale families and unseen minor daughter
for illicit sex trade and hidden prostitution, pressurized to accept
child marriage for unseen abducted minor daughter, attempted
to infiltrate into house causing severe damage and loss to
property, asserted possessiveness on the petitioner on behalf of
his kidnapped, abducted, hostage, sexually abused families
including his minor daughter and wife. Events of physical
assault on petitioner by the Sex Abusers taken place on the
following day, date, time and place; yet NO F.I.R by police:
i) Petitioner is being physically assaulted by sex abuser
on 11.05.2022 at 02:00AM midnight in front of his house at
Bihar. Petitioner protested against the ill practices of
delinquent state and International mafia on 11th
May 2022
night at 2:00 AM at a Gang Rape venue in front of his house.
The stage show and Gang Rape events were organized in
front of his house behind a Mosque at Sonaili, Shukkar Hatt,
Katihar, Bihar. In retaliation of a protest against this ill
practice, petitioner is being thrashed by a violent crowd of
sex abusers (state& mafia) and being beaten badly with

3. shoes and frisk on head and mouth causing injury and severe
pain in his right ribs. Snatched his golden chain and money
worth Rs. 10,000/-. Broken his sleepers and shirts. Petitioner
approached Sadar Hospital Katihar for availing Medical
Emergency Services and being attended by the doctor vide
registration number 2529 dated 12/05/2022. However, the
Medico Legal Case (MLC) is being denied by the doctors
and medical prescription along with daily diary being stolen
by the sex abusers cum railway vendor Kedar Paswan at
Dandkhora Railway Station in Katihar rail division Bihar.
The matter has been reported to all nodal police officers of
Bihar as well as Delhi. Mr. Virender, an Inquiry officer has
been appointed by Delhi Police CCTNS Admin in this
matter. The complaint no. 50000046782203202 dated 12-05-
2022 PIS No.28820336 mobile no. 9013248152 is allotted
against it, yet no F.I.R by police.
ii) Petitioner is being physically assaulted by the sex
abuser of his unseen minor daughter on 23.05.2022 at
11:00AM in front of One India Family Mart Katihar Bihar.
A Bengali woman human trafficker and Mr. Sumit Kumar
Child Line Coordinator Katihar Bihar attacked him violently
while he was stopping trafficking of his minor daughter. He
is being thrashed, beaten with feast, shirt being torn into
pieces, caused him internal injury by a group of human
trafficker, sex abusers in a protest against trafficking and
gang raping of his minor daughter. The same is being
reported to Delhi as well as Bihar police in writing through
email, yet no F.I.R by police.

4. iii) Petitioner is being physically assaulted by a group of
sex abuser on 09.06.2022 at 17:06:26PM in front of Luxmi
Narayan Dharamshala at Church Mission Road, Fatehpuri,
Delhi-6. Physical injury has been caused to the petitioner in
a protest against illicit sex trade of his families inside the
toilet of Luxmi Narayan Dharamshala. The same has been
reported to Delhi Police by 112 call registered with reference
No. 5208740, 5208823, 5209010, 5209016, 5208990 and
5209461 dated 09.06.2022. An application for registration of
an F.I.R has been filed with Police Station Lahori Gate,
Delhi-6 dated 9th
June 2022 vide D.D. No. 23A at 12:26p.m.
Medical of petitioner has been conducted at Aruna Asaf Ali
Hospital, Delhi at 9:30pm dated 9.06.2022 by Head
Constable Ajay Kumar and Om Prakash, Police Post Church
Mission Road under Lahori Gate Police Station Delhi, yet no
F.I.R by police.
iv) Petitioner is being physically assaulted by a group of
sex abuser on 07.08.2022 at 11:45AM in front of his house
at Bihar. This has been done in retaliation of a protest by the
petitioner against the illicit sex trade of his families by the
sex abusers. The same has been reported to police, yet no
F.I.R by police. Around 12:33:02PM dated 07.08.2022,
petitioner informed the Bihar as well as Delhi Police through
mobile SMS, “two sex abusers rapists of my prostitute
families attempted to kill me, hit on my head, face, mouth by
feast, broken mobile charger, torn shirts,
snatched/pickpocketed 1000/-bucks on behalf of
Superintendents of Police Katihar Sidharth Mohan Jain,
Vikash Kumar, Jitender Kumar, Avinash Kumar,

5. businessman Sunil Bubna, Sanjay Birwa (Jain), Manthu
Dokania, Arun Dokania, Advocate Birender Singh and all
Marwari, Jain, Rajput, Sah, Muslims and other communities
of Sonaili Salmari Katihar Bihar at 11:45am dated
07.08.2022 in front of my Asha Deep Niwas, Shukkar Hatt.
SHO Kadwa being informed over mobile for MLC case. No
action by Police so far”.
4. That Petitioner has intervened, seen and verified his
kidnapped pregnant wife Rina Kumari (Guddi) in the course of
rescue operation after the dismissal of PIL Writ Petition
(Criminal) No. 242/2021 dated 25.10.2021 and during the pending
sub-judice matter W.P. (Criminal) D.No. 18546/2022 w.e.f
14.06.2022 before Supreme Court India. Petitioner has seen her on
the stage show held at Sonaili Katihar Bihar dated 11.05.2022,
intervened by climbing the stage to stop ongoing events but being
thrashed by her human traffickers and sex abusers. The same has
been reported to Delhi as well as Bihar Police by written signed
complaint sent through E-mail dated 12.05.2022.
5. That thereafter Petitioner has seen and verified his
kidnapped pregnant wife Rina Kumari (Guddi) and on 19.06.2022
in front of Old Delhi Railway Station at the bus stop in a black
burka. The same has been reported to Delhi Police through 112
call reference no. 5260340 dated 19.06.2022 at 17:08pm
mentioning human trafficker’s mobile number 8830993916. Wife
Rina Kumari sat beside the petitioner at the bus stop opposite to
old Delhi Railway Station at around 3:00pm to 4:00pm along with
her 25 year old Rajput boy sex abuser, 3 year old new born male

6. baby and a 22 year old woman helper. The moment petitioner
made 112 call against the mobile number of human trafficker
8830993916, she moved towards Church Mission Road,
Fatehpuri, Old Delhi-6 by a Toto battery rickshaw.
6. That State sponsored Gang Rape victims are more than
50 women and minor girls from Petitioner’s families including his
18 years ago kidnapped pregnant wife Rina Kumari alias Guddi,
age about 40 years D/O Surender Narayan Poddar, Rtd. Assistant
Manager (RC), Marketing Division, Brauni Refinery, Begusarai,
Bihar and never seen 17 years old minor daughter. Pregnant wife
Rina Kumari alias Guddi, age about 40 years was kidnapped on
15.04.2005 by the State from Gali No.12, Raj Nagar Part-2, Palam
Colony, New Delhi and being pushed into prostitution. She has
been caught into prostitution along with her minor daughter on
05.04.2021 at C-128/5, Gali No.07, Shastri Park, North East Delhi
by the petitioner.
Original photograph of Gang Rape Victim Rina Kumari
(Guddi) supplied by her father on 24th
June 2004

9. Plastic Surgery Photograph of Gang Rape Victim Rina Kumari
(Guddi) along with sex abuser collected by the Petitioner
during her Gang Rape event at Sonaili, Katihar Bihar dated
11th
May 2022.
7. That some of the victim’s name are Shri Surendra Narayan
Poddar, Assistant Manager (RC), IOC, Baruni Refinary, Ms.
Anita Poddar wife of Surendra Narayan Poddar, Rina
Kumari, Anuja Kumari, Rupam kumari alias Dolly daughters

10. of Surendra Narayan Poddar and Anupam Kumar son of
Surendra Narayan Poddar R/O R.H. 5/6, Baruni Refinary,
Township, Begusarai and Jagdish Path, Bailey Road Apartment
206, Malti Bihari, Patna, Bihar, Har Har Mahadev Chowk,
Begusarai, Bihar, IOCL Quarter, Bank More, Dhanbad
Jharkhand.
8. That suspected cases of Child Sexual Abuse (CSA) and
persistent Gang Rapes have been identified at Ram Kumar’s
house, C-128/5, Gali No.07, Shastri Park, North East Delhi a
owner of M/S R.K Fashion at Gandhi Nagar, Delhi on 05th
April
2021. Case of sexual abuse and forced hidden prostitution of
minor girls have been reported to NCPCR Government of India
vide POCSO E-Box hit No. 2290 dated 12.04.2021. Dastagir
Qumar Nodal coordinator ChildLine Delhi has intervened into
the case along with Delhi Police and confirmed the same
through email dated 17.04.2021 at 7:44 PM to the petitioner.
However, the rescues of the victims have been suppressed with
handsome bribe and recording false police statement.
Thereafter, victims have been re-pushed into the clutches of
prostitution with greater magnitude. That PIL Writ Petition
(Criminal) No.242/2021 for direction of registration of an F.I.R
has also been dismissed by the Supreme Court of India on
25.10.2021 due to non-appearance of Legal Aid Advocate in
this matter. Hence, rescue of victims is being suppressed
permanently.
9. That another Suspected case of Child Sexual Abuse (CSA)
has been identified on 12.09.2022 inside the house of Mr.

11. Vivekanand Jha, an astrologer and superstitious man, R/O
Shukkar Hatt, behind Goddess Durga Temple at Sonaili Village,
Kantiya Panchayat, P.S. Kadwa, Katihar, Bihar. Victim is tall,
strong build, Delhi breed, minor 17 years old but looking major
girl frequently disappears from Sonaili Katihar Bihar for
outdoor sex. She has been seen today dated 12.09.2022 at
Sonaili Rilway Station under DRM katihar, eastern railway
Zone along with a fatty, bulky sex abuser Rajput caste girl to
catch Siliguri-Katihar bound local train at 9.30am. Suspected
CSA case has been reported to Bihar as well as Delhi Police for
intervention and scrutiny through SMS.
VICTIM’S PHOTO ATTCHED FOR VERIFICATION AND
SCRUTINY.

13. 10. That Ram Kumar’s house, C-128/5, Gali No.07, Shastri
Park, North East has been identified as a replica of
Muzaffarpur, shelter homes of Bihar.
11. That professional help of Mushkan, Pune based NGO and
Arambh India Mumbai based NGO has been taken for the
rescue of the Gang Rape victims. These NGOs are working in
the area of human trafficking and child sexual abuse.
12. That apart from help from these NGOs, help from Mr. Ajay
Kumar Bhalla, Secretary, Ministry of Home Affairs,
Government of India, Mr. Srivastava, Commissioner of Police
Delhi, Mr. Dastgir Qumar, Nodal coordinator, Child Line India
Foundation, North Regional Centre, New Delhi, Mr. Yashwant
Jain, National Commission for Protection of Child Rights
(NCPCR), Mr. Anurag Kundu, Delhi Commission for
Protection of Child Rights (DCPCR), Ms. Rekha Sharma,
Chairperson, National Commission for Women, Ms. Shwati
Maliwal, Chairperson, Delhi Commission for Women has been
taken for the rescue of the victims, yet rescue of the victims
have been suppressed to sustain illicit sex trade to gain political
mileage and generate revenue out of it .
13. That Government of NCT of Delhi, Union of India and
Supreme Court of India is responsible for this kind of
delinquent act. In absence of proper rescue and rehabilitation,
Gang Rape/ illicit sex trade is continued across the country and
globe.
14. That in the course of rescue operation of Ms. Nikki, a child
sexual abuse case at Shashtri Park, North East Delhi in April-

14. May, 2021, Petitioner is being contacted by the following
contractual women employees of Delhi Commission for
Women (DCW) and Delhi Police(DP):
i) Ms. Sushma, (DCW) mobile-8929412576 at 10:43am dated
10.05.2021 at C-128/5, Gali No.07, Shastri Park, North
East Delhi.
ii) Ms. Meena Thakur, (DCW) mobile-7678337704 at 12:07pm
dated 10.05.2021 at C-128/5, Gali No.07, Shastri Park,
North East Delhi.
iii)Ms. Arpita, (DCW) mobile-9310577614 at 01:00pm dated
12.05.2021 at C-128/5, Gali No.07, Shastri Park, North
East Delhi.
iv)Ms. Pooja, (DCW) mobile-9899080621 at 10:22am dated
12.05.2021 at C-128/5, Gali No.07, Shastri Park, North
East Delhi.
v) Ms. Arupa, (DCW) mobile-9873241660 at 11:16am dated
13.05.2021 at C-128/5, Gali No.07, Shastri Park, North
East Delhi.
vi)Mr. Sachin, (DP), Sub-Inspector, P.S. Shastri Park, North
East Delhi, mobile-9540486321 at 18:27pm dated
16.05.2021
vii) Ms. Sushma Singh, (DP) I.O. Delhi Police, mobile-
8868535329.
15. That above noted State employees made all efforts to

15. suppress the matter by hook and crook.
16. That being aggrieved by the delinquent act of State
employees, Petitioner moved to Supreme Court of India for
seeking direction for registration of an F.I.R against this Public
Interest Litigation (PIL) on prostitution matter Writ Petition
(Criminal) 242/2021 but the same is also being dismissed by
Supreme Court of India on the ground of Non-appearance of
Legal Aid Advocate on 25.10.2021.
17. That being aggrieved by this barbaric act of Supreme Court
of India, petitioner again moved to Supreme Court of India with
fresh Anti-Prostitution Writ Petition (Criminal) Diary No.
18546/2022 dated 14.06.2022 to restore the wrongly dismissed
PIL on prostitution matter Writ Petition (Criminal) 242/2021;
which is still pending before the court.
18. That Police complaint against persistent Gang Rape of
victims have been made to Delhi Police as well as to Bihar
Police and Delhi administration as well as to Bihar
administration on 07.05.2022, 09.05.2022, 10.05.2022,
11.05.2022, 12.05.2022, 13.05.2022, 14.05.2022, 14.05.2022,
15.05.2022, 16.05.2022 (Child Line Katihar Rilway, Bihar,
NCPCR, New Delhi and ChildLine Kolkotta) 17.05.2022,
18.05.2022, 19.05.2022, 20.05.2022, 22.05.2022, 23.05.2022,
24.05.2022, 25.05.2022, 26.05.2022, 27.05.2022, 28.05.2022,
31.05.2022, 01.06.2022, 02.06.2022, 03.06.2022, 05.06.2022,
07.06.2022, 08.06.2022, 09.06.2022, 10.06.2022, 11.06.2022,
12.06.2022, 13.06.2022, 15.06.2022, 16.06.2022, 18.06.2022,
19.06.2022, 20.06.2022, 21.06.2022, 22.06.2022, 23.06.2022,

16. 24.06.2022, 25.06.2022, 26.06.2022, 27.06.2022, 28.06.2022,
29.06.2022, 30.06.2022, 01.07.2022, 02.07.2022, 03.07.2022,
04.07.2022, 05.07.2022, 06.07.2022, 07.07.2022, 08.07.2022,
09.07.2022, 10.07.2022, 11.07.2022, 12.07.2022, 13.07.2022,
14.07.2022, 15.07.2022, 16.07.2022, 19.07.2022, 20.07.2022,
21.07.2022, 22.07.2022, 23.07.2022, 24.07.2022, 25.07.2022
(Bandhan Kolkotta), 26.07.2022, 27.07.2022, 28.07.2022,
29.07.2022, 30.07.2022, 31.07.2022, 01.08.2022, 02.08.2022,
03.08.2022, 04.08.2022, 05.08.2022, 06.08.2022, 07.08.2022,
08.08.2022, 09.08.2022, 10.08.2022, 11.08.2022, 12.08.2022,
13.08.2022, 14.08.2022, 15.08.2022, 16.08.2022, 17.08.2022,
18.08.2022, 19.08.2022, 20.08.2022, 21.08.2022, 22.08.2022,
23.08.2022, 24.08.2022, 25.08.2022, 26.08.2022, 01.09.2022
(National Human Rights Commission), 05.09.2022(National
Commission for Women & Delhi Commission for Women),
10.09.2022(Department of Social Work, TISS, Mumnai and
Delhi University, CINI West Bengal, Save the Children J&K,
Children International US, Social Development Sector
Consultancy), 12.09.2022 (Chairman Railway Board)
13.09.2022(NHRC). Yet no F.I.R by police & no rescue till
date.
19. That Diary No. 155282/CR/2016 dated 14.09.2016, Case No.
3537/4/4/2016 has been rejected on 18.10.16, Case No.
5480/30/0/2022 and Case No. 4751/90/0/2022 has been rejected
on 30.08.2022 and 31.08.2022 respectively by the National
Human Rights Commission, New Delhi on the same
International Sex Matter.
20. That however, Diary No. 134093/CR/2022 dated 1.9.2022,

17. Diary No.134631/CR/2022 dated 2.9.2022, Case No.
4977/90/0/2022 dated 12.09.2022 regarding Children and Case
No. 4876/4/16/2022 dated 12.09.2022 has been registered by
the National Human Rights Commission, (NHRC), New Delhi
on the same sex matter, which is still pending before the
commission.
21. That Central Vigilance Commission, New Delhi has received
complaint case no. 205126/2022/vigilance-B on 29.06.2022
against its corrupt All India Services Employees.
22. That Police complaint dated 07.04.2011 is still pending
before Kadwa Police Station Katihar Bihar for registration of an
F.I.R.
23. That Police complaint dated 30.05.2016 vide D.D.No. 37B
and Post Mortem Report No. 1904/2017 vide D.D.NO. 12B
dated 11.11.2017 of deceased mother Asha Rani Devi age 70
years, W/O Deep Narayan Poddar is still pending before Palam
Village Police Station, New Delhi for registration of an F.I.R.
Postmortem has been conducted by ASI Shyam Sunder, Palam
Village Police Station, New Delhi and Deen Dayal Upadhyay
Hospital, Government of N.C.T of Delhi, Hari Nagar, New
Delhi.
24. That Non-F.I.R No. 173/2019 dated 05.08.2019 under
section 107 of CrPc. has been registered by SHO Kadwa Police
Station, Katihar Bihar against the violent mob attack on
petitioner dated 30.07.2019 by the sex abusers and the same has
been forwarded to the court of Sub-divisional Magistrate,
Barsoi, Katihar Bihar for further action which is still pending

18. without any action.
25. That Police Action Taken Report dated 29.11.2019 by
Superintendent of Police Traffic Katihar Bihar reveals that
Police has taken negative action against the violent mob
attackers on petitioner dated 30.07.2019 at Sonaili Katihar
Bihar. The main accused in this case is neighbor (1) Shri
Bechan Poddar S/O Sahdev Poddar, (2) Shusheel Poddar S/O
Bechan Poddar, (3) Guddu Poddar S/O Bechan Poddar R/O
Shukkar Hatt, Sonaili, Kadwa Police Station, Katihar Bihar.
26. That Police complaint against Gang Rape of victims dated
09.06.2022 vide D.D.No. 23A at Lahori Gate Police Station,
Delhi-6 has been filed by the petitioner.
27.That Police complaint against Gang Rape of victims dated
15.06.2022 to DCP/Inspector Vigilance Vasant Vihar Police
Station New Delhi has been filed by the petitioner.
28.That Police complaint against Gang Rape of victims dated
18.06.2022 vide D.D.No. 40 at Tilak Marg, Police Station, New
Delhi has been filed by the petitioner.
29. That in the midst of the above noted activities; barbaric act
of State is continued against the Gang Rape Victims. State has s
kept them hostage for persistent Gang Rapes and illicit sex
trade since 2005 to till date.
30. That Indian Army is showing barbaric act by stopping army
train and gang raping victims. The army has stopped its train

19. twice at Gang Rape Zone Sonaili Village in Katihar district of
Bihar, a source point of human trafficking. Indian Army train
has stopped at 12:28pm dated 28.08.2022 and at 19:00pm dated
04-09-2022 for 4-5 hours for cooking and Gag Raping of the
victims at Sonaili Railway Station under Katihar Divisional
Railway Manager. It is pertinent to mention here that Indian
Defense Organization is one of the parties in pending persistent
Gang Rape matter Writ Petition (Criminal) Diary No.
18546/2022 before Supreme Court of India.
31. That Ms. Hemlata, mobile-8800326349, counsellor, Delhi
Commission for Women and Delhi Police has been informed
against the barbaric act of Indian Army through mobile SMS at
20:11:15pm dated 04.09.2022, “My ID
Facebook.com/omprakash.poddar/7587/. You will get authentic
court details. Indian Army train at Gang Rape victim Zone
Sonaili Railway Station under katihar divisional railway
manager at 19:00pm dated 4.9.22 for cooking and gang rapes.
Second time this delinquent activity has been identified within
month. Indian defense organization is party before supreme
court of India in W.P.CRL.D.NO.18546/2022”. DCW & DP has
been informed with a hope to provide care and support to the
victims at the source point of human trafficking Katihar Bihar
in coordination with Bihar Commission for Women and Bihar
Police.
32. That another example of lawlessness and barbaric act of state
against state sponsored gang rape victims has been identified on
11.09.2022 at Sonaili, Katihar, Bihar. Without route, Hamsafar
express Katihar-Champaran–Delhi bound train brought and

20. stopped at Sonaili Railway station under DRM Katihar Bihar at
19:00pm for couple of hours to gang rape and traffick the
victims. This is happening while DRM Katihar and Chairman
Railway Board is party before Supreme Court of India in an
Anti-Prostitution matter Writ Petition Criminal Diary
No.18546/2022.
33. The barbaric act of Indian Railway has been reported to
Delhi as well as Bihar Police including Ms. Hemlata, counsellor
of Delhi Commission for women dated 12.09.2022 through
SMS.
34. That Indian army is repeating its barbaric act by stopping its
train at Sonaili Railway Station under DRM Katihar dated
12.09.2022 at 9:00am for couple of hours for gang raping the
victims. Gang Rape Victim has identified inside the coach no.
M-10086/SR15135 AC-3 Tier of Indian Army Military train
dated 12.09.2022.
35. The barbaric act of Indian army dated 12.09.2022 has been
reported to Delhi as well as Bihar Police including Ms.
Hemlata, counsellor of Delhi Commission for women on the
same day and date through SMS.
36. First Anti-Prostitution matter, Petition(s) for Special Leave
to Appeal (Civil) No(s).9854/2012 has been dismissed by
Supreme Court of India on 23.04.2012.
37. Second Anti-Prostitution matter, Petition(s) for Special
Leave to Appeal (Civil) No(s). 9483/2013 has been dismissed
by Supreme Court of India on 01.04.2013.

21. 38. Third Anti-Prostitution matter, Petition(s) for Special Leave
to Appeal (Civil) No(s). 19073/2013 has been dismissed by
Supreme Court of India on 05.07.2013.
39. Fourth Anti-Prostitution matter, Writ Petition (Civil)
90/2016 has been dismissed by Supreme Court of India on
18.04.2016.
40. Fifth Anti-Prostitution matter, Writ Petition (Criminal)
136/2016 has been dismissed by Supreme Court of India on
21.10.2016.
41. Sixth Anti-Prostitution matter, Writ Petition (Criminal)
242/2021 has been dismissed by Supreme Court of India on
25.10.2021.
42. Seventh Anti-Prostitution matter, Writ Petition (Criminal)
137/2021 has been dismissed by Supreme Court of India on
02.05.2022.
43. Eighth Anti-Prostitution matter, Writ Petition (Criminal)
Diary No. 18546/2022 is still pending before Supreme Court of
India. It is the outcome of dismissal of 17 Anti-Prostitution
dismissed matter by Supreme Court of India.
44. That the rights of the petitioner has been destroyed through
his illegal detention in an unlawful manner by the Kadwa Police
in Bihar on 30th
July, 2019 and 20th
May, 2022 while by the
Church Mission Road Police Post Fatehpuri, old Delhi under
Lahori Gate Police Station Delhi-6 on 10.06.2022 whereas the
law provides a procedure for arrest and equally for investigation

22. and the consequential trial. That is what has been interpreted by
this Court while dealing with Article 21 of the Constitution.
45. That lynching or any kind of mob violence has to be curbed
and crippled by the executive and no excuse can ever be
tolerated has been observed by the Supreme Court of India and
laid down preventive, remedial and punitive measures in
“Tehseen S. Poonawalla VS. Union of India and others” (2018)
and Shakti Vahini v. Union of India & others. 2018 (5) SCALE
51
46. The Committee on Reforms of Criminal Justice System
headed by Dr. Justice V.S. Malimath also noticed the plight
faced by several people due to non-registration of FIRs and
recommended that action should be taken against police
officers who refuse to register such information. The
Committee observed:-
"7.19.1 According to the Section 154 of the Code
of Criminal Procedure, the office in charge of a police
station is mandated to register every information oral
or written relating to the commission of a cognizable
offence. Non-registration of cases is a serious complaint
against the police. The National Police Commission in its
4th report lamented that the police "evade registering
cases for taking up investigation where specific
complaints are lodged at the police stations". It referred
to a study conducted by the Indian Institute of Public
Opinion, New Delhi regarding "Image of the Police in
India" which observed that over 50% of the respondents

23. mention non-registration of complaints as a common
practice in police stations.
7.19.2 The Committee recommends that all complaints
should be registered promptly, failing which appropriate
action should be taken. This would necessitate change in
the mind -set of the political executive and that of senior
officers.
7.19.4 There are two more aspects relating to
registration. The first is minimization of offences by the
police by way of not invoking appropriate sections of
law. We disapprove of this tendency. Appropriate
sections of law should be invoked in each case
unmindfull of the gravity of offences involved. The
second issue is relating to the registration of written
complaints. There is an increasing tendency amongst the
police station officers to advise the informants, who
come to give oral complaints, to bring written
complaints. This is wrong. Registration is delayed
resulting in valuable loss of time in launching the
investigation and apprehension of criminals. Besides, the
complainant gets an opportunity to consult his friends,
relatives and sometimes even lawyers and often tends to
exaggerate the crime and implicate innocent persons.
This eventually has adverse effect at the trial. The
information should be reduced in writing by the SH, if
given orally, without any loss of time so that the first
version of the alleged crime comes on record.
7.20.11 It has come to the notice of the Committee that
even in cognizable cases quite often the Police officers

24. do not entertain the complaint and send the complainant
away saying that the offence is not cognizable.
Sometimes the police twist facts to bring the case within
the cognizable category even though it is non-
cognizable, due to political or other pressures or
corruption. This menace can be stopped by making it
obligatory on the police officer to register every
complaint received by him. Breach of this duty should
become an offence punishable in law to prevent misuse
of the power by the police officer."
47. That there is a sheer violation of the direction of Supreme
Court of India by the State as laid down in Lalita Kumari vs.
Government of Uttar Pradesh & Ors. (W.P. (Crl.) No. 68/2008)
for registration of an F.I.R against receiving of an information
disclosing cognizable offence related to kidnapping of minor
girl and pregnant women, immoral trafficking, State Sponsored
Gang Rapes, illicit sex trade and human trafficking, Child
sexual abuse, suppression of rescue of gang rape victims,
unauthorized hostages of the victims by the State and child
marriages of the victims etc.
48. That there is a sheer violation of the direction of Supreme
Court of India by a police officer in-charge of a police station as
laid down in various cases for registration of an F.I.R. Supreme
Court of India has categorically stated in its catena of
judgments that upon receipt of information by a police officer
in-charge of a police station disclosing a cognizable offence, it
is imperative for him to register a case under Section 154 of

25. the Code as laid down by Supreme Court of India in State of
Haryana vs. Bhajan Lal 1992 Supp. (1) SCC 335, Ramesh
Kumari vs. State (NCT of Delhi) (2006) 2 SCC 677, Parkash
Singh Badal vs. State of Punjab (2007) 1 SCC 1, B. Premanand
and Ors. vs. Mohan Koikal and Others (2011) 4 SCC 266,
M/s Hiralal Rattanlal Etc. Etc. vs. State of U.P. and Anr. Etc.
Etc. (1973) 1 SCC 216, Govindlal Chhaganlal Patel vs.
Agricultural Produce Market Committee, Godhra and Ors.
(1975) 2 SCC 482, Ganesh Bhavan Patel and Another vs. State
of Maharashtra (1978) 4 SCC 371, Aleque Padamsee and
Others vs. Union of India and Others (2007) 6 SCC 171, Ram
Lal Narang vs. State (Delhi Administration) (1979) 2 SCC
322 and Lallan Chaudhary and Others vs. State of Bihar and
Another (2006) 12 SCC 229.
49. That the focal point of fight is between Professional Social
Worker Versus Professional Legal Workers. Both are defending
the same clients by their own professional acumen, training,
skills, body of knowledge, vision, practice, procedure,
methodology, ethics, morale, principles, objectives, goals and
style of functioning. Herein, Petitioner is a Professional Social
Worker while Advocates and Judges are Professional Legal
Workers. Details of petitioner’s professionalism have been
placed on court records in the main petition of this case.
50. That Professional Legal Workers are obstructing the rescue
operation of Gang Rape Victims from the clutches of human
Traffickers State while Professional Social Worker is dying
hard to rescue the Gang Rape Victims from the clutches of
human Traffickers State.

26. 51. That brain mapping of victims, rolling back of Sex
technologies, clubbing of F.I.Rs and requisitioning of lower
court records across the country is required in rescuing the state
sponsored gang rape/illicit sex trade victims from the clutches
of human Traffickers State.
52. That on the contrary, State is suppressing and obstructing the
rescue operation of Gang Rape Victims since 5th
April, 2021.
State coercion has reached its peak crossing all limits.
53. That under the above circumstances, Petitioner has been left
to rescue them from Supreme Court of India through Writ
Petition (Criminal) Diary No.18546/2022.
54. That in the above premises; register an F.I.R against the
accused Public authorities for commissioning cognizable
offence against the victims which is punishable under relevant
sections of IPC.
PETITIONER-IN-PERSON
Professional Social Worker (MSW)
Writ Petition (Criminal) D. No. 18546/2022
SUPREME COURT OF INDIA
OM PRAKASH
S/O LATE SHRI DEEP NARAYAN PODDAR
S/O LATE SRIMATI ASHA RANI DEVI
PERMANENT RESIDENT: ASHA DEEP NIWAS,
SONAILI, SHUKKAR HATT,
IN FRONT OF DURGA MANDIR,
KANTIYA PANCHAYAT,
P.S. KADWA, KATIHAR, BIHAR-855114, MOB: 9540389759
E-mail: om.poddar@gmail.com
KATIHAR BIHAR:
FILED ON : 13-09-2022