I.A. No. 90171 of 2023 in Review Petition Criminal 107 of 2023 dated 01.05.2023.pdf

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IN THE SUPREME COURT OF INDIA
ORIGINAL APPELLATE CRIMINAL JURISDICTION
CRMINAL M.P. NO. 90171 OF 2023
IN
REVIEW PETITION (CRIMINAL) NO. 107 OF 2023
IN
WRIT PETITION (CRIMINAL) NO. 42 OF 2023
Interlocutory Application for adducing additional
evidence in Review Petition (Criminal) under Article 137
of the Constitution of India arising out of the final Order
dated 06.02.2023 passed by this Hon’ble Court in Writ
Petition (Criminal) No. 42 of 2023 with A Prayer for
review and reconsideration.
IN THE MATTER OF:
OM PRAKASH …………..PETITIONER
VERSUS
UNION OF INDIA & ORS ….RESPONDENT
PAPER BOOK
(FOR INDEX KINDLY SEE INSIDE)
PETITIONER IN PERSON
OM PRAKASH

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FILING INDEX
CRIMINAL ORIGINAL JURISDICTION
CRL.M.P.NO. 90171 OF 2023
IN
REVIEW PETITION CRIMINAL NO. 107 OF 2023
(UNDER ARTICLE 137 OF THE CONSTITUTION OF INDIA)
IN
WRIT PETITION CRIMINAL NO. 42 OF 2023
AND
IN THE MATTER OF SUPRESSION OF
RESCUE OF PERSISTENT GANG RAPES,
ILLICIT SEX TRADE, CHILD SEXUAL
ABUSE VICTIMS AT THE SOURCE POINT,
TRANSIT POINT, DESTINATION POINT OF
HUMAN TRAFFICKING AND ABUSE OF
POWER BY STATE, NGOS, GANGSTERS
AND INDIAN DEFENSE ORGANIZATIONS
AND
IN THE MATTER OF:
OM PRAKASH …………..PETITIONER
VERSUS
UNION OF INDIA & ORS ….RESPONDENT(S)
S.N Particulars Copies Pages
1. Application for adducing additional
evidences in Review Petition
Criminal 107/2023 in Writ Petition
(Criminal) No. 42/2023 along with
affidavit
1+3 1-43
2. Annexures P-01 to P- 39 1+3 44-194
DRAWN & FILED BY:
PETITIONER-IN-PERSON
PROFESSIONAL SOCIAL WORKER (MSW)
OM PRAKASH
S/O LATE SHRI DEEP NARAYAN PODDAR
S/O LATE SRIMATI ASHA RANI DEVI
PERMANENT RESIDENT: ASHA DEEP NIWAS,
SONALI, SHUKKAR HATT,
IN FRONT OF DURGA MANDIR,
KANTIYA PANCHAYAT,
P.S. KADWA, KATIHAR, BIHAR-855114
MOB: 9540389759
E-mail: om.poddar@gmail.com
NEW DELHI:
FILED ON : 01 -05 -2023
Diary No.:

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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 Application for adducing additional
evidences in Review Petition
Criminal 107/2023 in Writ Petition
(Criminal) No. 42/2023 along with
affidavit
1-43
3. Annexure: P-1
True copy of draft suit u/s 9 of
HMA dated 15.09.2007 by
Advocate Awadesh Kumar Jha,
Katihar Court in trafficking &
Prostitution matter
44-52
4. Annexure: P-2
True copy of translated copy of
order dated 31.03.2010 in Case No.
9P/2010 u/s 12 of DVAct 2005 by
Chief Judicial Magistrate of
Begusrai Court under the judicature
of Patna High Court in trafficking
& Prostitution matter
53
5. Annexure: P-3
True copy of Statement of State
Victim Ms. Rina Kumari (Guddi)
recorded by Shri Atul Kumar
Pathak, 1st
Class Judicial
Magistrate at Begusrai Court under
the judicature of Patna High Court
on 7.04.2010 in Case No. 9P/2010
u/s 12 of Domestic Violence Act
2005 in trafficking & Prostitution
matter
54-55
6. Annexure: P-4
Petition dated 2.6.2010 u/s 12 of
Domestic Violence Act 2005 in
Case No. 9P/2010 before Shri Atul
Kumar Pathak Court, 1st
Class
Judicial Magistrate at Begusrai
Court under the judicature of Patna
56-58

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High Court by State Victim Ms.
Rina Kumari (Guddi) in trafficking
7. Annexure: P-5
order dated 25.08.2010 in Case No.
9P/2010 with an issuance of Non
Bail able Warrant (NBW) through
SP Begusrai by Shri Atul Kumar
Pathak, 1st
Class Judicial
Magistrate at Begusrai Court under
the judicature of Patna High Court
against the Petitioner Om Prakash
and his Mother Asha Rani Devi in
trafficking & Prostitution matter
59
8. Annexure: P-6
True copy of Petition dated
7.02.2011 in Criminal Complaint
Case (P) No. 397/2011
computerized as 5591/2013 filed
by State Victim under Women
Protection Act at Begusrai Court
under the judicature of Patna High
Court in trafficking & Prostitution
matter
60-63
9. Annexure: P-7
True copy of Personal information
of State Victim sister-in-law Ms.
Rupam Kumari alias Dolly dated
31.01.2014 collected from the
matrimonial website
www.Shaadi.com in trafficking &
Prostitution matter
64-68
10. Annexure: P-8
ATR dated 7.5.2016 by Bihar
Police in Public Toilet and Gang
Rape by the State in trafficking &
Prostitution matter
69-73
11. Annexure: P-9
True copy of replication dated
17.5.2016 against ATR dated
7.5.2016 before Chief Minister
Office Government of Bihar in
Public Toilet and Gang Rape by the
74-76

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State in trafficking & Prostitution
matter
12. Annexure: P-10
True copy of ATR dated
10.02.2018 by ACP Uma Shankar,
Delhi Cantt. Delhi Police in
Suspicious death of mother Asha
Rani Devi of petitioner in
77-79
13. Annexure: P-11
Delhi Cantt. Delhi Police through
Ministry of Home Affairs in Gang
Rape of State Victims in trafficking
80-81
14. Annexure: P-12
Delhi Cantt. Delhi Police through
Government of NCT of Delhi in
Gang Rape of State Victims in
82-83
15. Annexure: P-13
ATR dated 16.05.2018 by Shri
Pankaj Kumar, Sub-Divisional
Police Officer (SDPO), Barsoi
Katihar Bihar in Public drinking
water & Public toilet inside the
house premises of petitioner at
Asha Deep Niwas at Sonaili in
84-85
16. Annexure: P-14
26.6.2018 against ATR dated
16.5.2018 before Chief Minister
Office Government of Bihar in
Public Toilet and Gang Rape by the
matter
86
17. Annexure: P-15
31.05.2019 by Shri Vikash Kumar
87-88

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SP Katihar and Shri Pankaj Kumar,
Sub-Divisional Police Officer
(SDPO), Barsoi Katihar Bihar in
NBW & Kidnapping; abduction ,
Sexual Harassment, trafficking &
Prostitution matter
18. Annexure: P-16
Vikash Kumar SP Katihar and Shri
Pankaj Kumar, Sub-Divisional
Police Officer (SDPO), Barsoi
Katihar Bihar in Mob Violence,
Kidnapping; abduction, Sexual
Harassment, trafficking &
Prostitution matter
89-90
19. Annexure: P-17
29.11.2019 with Non-F.I.R No.
173/19 u/s 107Cr.Pc. dated
05.08.2019 registered by Shri Jai
Prakash Narayan SP Traffic,
Katihar and Shri Shiv Prassan
Singh, Police Inspector Kadwa
Police Station in Mob Violence,
Prostitution matter
91-93
20. Annexure: P-18
Vikash Kumar SP Katihar and Shri
Ranjay Kumar Singh, Station
House Officer (SHO) Kadwa,
Katihar Bihar in Mob Violence,
Prostitution matter
94-95
21. Annexure: P-19
Delhi Cantt. Delhi Police in
Suspicious death of mother Asha
Rani Devi of petitioner &
continuation of Trafficking and
Prostitution of Petitioner’s families
96-97

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22. Annexure: P-20
True copy of Statement of
Petitioner recorded dated
26.05.2021 by Inquiry Officer Ms.
Sushma Singh in trafficking &
Prostitution matter (Shastri Park
North East Delhi
98-
101
23. Annexure: P-21
True copy of reply dated
22.02.2023 by Assistant Electoral
Registration Officer (AERO), AC-
36 Bijwasan, Election Commission
of Delhi in trafficking &
Prostitution matter for fake
electoral Voter ID
102
24. Annexure: P-22
True copy of RTI dated 15.03.2023
against Delhi Police to seek a copy
of F.I.R against Child Prostitution
in Shastri Park North East Delhi
area in 2021
103-
104
25. Annexure: P-23
True copy of Replication dated
17.03.2023 in case no.
7290/4/16/2022 to Bihar Human
Rights Commission in trafficking
105-
112
26. Annexure: P-24
True copy of direction dated
23.03.2023 in Case No.
994/30/1/2023 by National Human
Rights Commission New Delhi to
DCP Daryagunj, Central Delhi in
113-
114
27. Annexure: P-25
27.03.2023 in Case No.
7517/4/16/2022-WC to Bihar
Human Rights Commission in
115-
122
28. Annexure: P-26
27.03.2023 by Electoral
Registration Officer Bihar in fake
voter ID of electoral case in
123-
125

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29. Annexure: P-27
True copy of translated copy of a
Complaint dated 28.03.2023 by the
State Victim against the human
traffickers before Professional
Social Worker and PIP SC in
126-
130
30. Annexure: P-28
28.03.2023 by Shri Rajinder
Singh PPS (RS), election
Office in trafficking & Prostitution
matter
131
31. Annexure: P-29
True copy of Grievances and
Complaint letter dated 7.04.2023 to
DRMR-EFICOR missionaries
NGO Banglore Karnataka,
Janakpuri New Delhi and
Sonaili Katihar Bihar UNIT in
132-
137
32. Annexure: P-30
Action Taken Report (ATR) dated
11.4.2023 by Director, Department
of Social Welfare, Government of
Bihar in Kidnapping; abduction,
Sexual Harassment, trafficking &
Prostitution mater
138-
148
33. Annexure: P-31
True copy of Complaint dated
12.4.2023 to Chairman Railway
Board New Delhi and GM (NFR)
in Kidnapping; abduction, Sexual
Prostitution mater
149-
153
34. Annexure: P-32
True copy of RTI dated 12.04.2023
against CBI to seek reply against
six questions related to suppression
of rescue of the Victims and further
Victimization of the Victims by the
matter
154-
155
35. Annexure: P-33 156

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True copy of email letter dated
12.04.2023 by Shri Randhir Singh,
GRP Delhi in trafficking &
Prostitution matter
36. Annexure: P-34
True copy of complaint dated
13.04.2023 against nodal
authorities of Shelter Home
Bihar under the Urban
Development &Housing
Department (UD&HD),
Government of Bihar in
157-
164
37. Annexure: P-35
True copy of Email dated
15.4.2023 by Cyber Police
Station Dwarka New Delhi in
165
38. Annexure: P-36
19.4.2023 against IAS IPS
Defense background human
traffickers in trafficking &
Prostitution matter to CBI
166-
181
39. Annexure: P-37
True copy of screen shot of fake
application ANR No.1235-2023
for Legal Aid made on behalf of
Petitioner collected from the
website of Supreme Court Legal
Service Committee (SLSC)
dated 20.4.2023 in trafficking &
Prostitution matter
182
40. Annexure: P-38
True copy of Complaint dated
23.4.2023 to nodal authorities
of DUSIB for Delhi Shelter
Home Management against the
misdeed caused by its partner
NGOs SPYM & RACHNA
employees in trafficking &
Prostitution matter to CBI
183-
189
41. Annexure: P-39
25.4.2023 against the Delhi Shelter
190-
194

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Home violent attack on Petitioner
in trafficking & Prostitution matter
to CBI

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CRL.M.P.NO. 90171 OF 2023
IN
IN
AND
IN THE MATTER OF
SUPRESSION OF RESCUE OF
GANG RAPE, ILLICIT SEX
TRADE, CHILD SEXUAL
ABUSE VICTIMS AND ABUSE
OF POWER BY THE STATE,
NGOS, GANGSTERS AND
INDIAN DEFENSE
ORGANIZATIONS
AND
IN THE MATTER OF:
OM PRAKASH ..PETITIONER
VERSUS
UNION OF INDIA & ORS …….RESPONDENT(S)
APPLICATION SEEKING PERMISSION TO ADDUCE
ADDITIONAL EVIDENCE IN REVIEW PETITION

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(CRIMINAL) NO. 107/2023.
To
Hon'ble the Chief Justice of India and His
Lordship's Companion Justices of the Supreme
Court of India. The Humble petition of the
Petitioner abovenamed.
MOST RESPECFULLY SHOWETH:
1. That the present review petition criminal under
Article 137 of the Constitution of India read with
Hon’ble Supreme Court Rules 1966 on the ground of an
error apparent on the face of record for review of the
final Order dated 06.02.2023 passed by this Hon’ble
Court in Writ Petition (Criminal) 42 of 2023 by which
this Hon’ble Court has dismissed the petition observing,
“Without prejudice to any of the remedies in any other
competent forum, the writ petition will stand dismissed”,
which offends the petitioner and his victim wife and
minor daughter and defends the rapists and perpetrator
in absence of clear direction with fixed timeline for the
recovery of minor daughter; which amounts to gross
miscarriage of justice and reflects devastating and

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disastrous effect having far reaching consequences
against the interest of public at large, as the same are not
being repeated here for the sake of brevity.
2. That after issuance of final order dated 6.2.23 in Writ
Petition (Criminal) 42 of 2023 by this Hon’ble Court;
all 41 respondents have been intimated by Names along
with certified copies of Order dated 6.2.23, Memo of
Parties and soft copies of Petitions/I.As through email.
3. That need for an application to adduce additional evidence in
review petition (criminal) no. 107/2023 has arisen to enable the
bench to reconsider the Final Order dated 6.2.23 in Writ
Petition (Criminal) 42 of 2023 to deliver the right
judgment/order in the yearlong derailed matter by the Judiciary,
executives and legislatures for its own vested interest benefiting
different stakeholders of Union of India.
ADDUCING EVIDENCE BELOW THE COURT:
4. That a petition under section 9 of HMA has been drafted by
Advocate Awadesh Kumar Jha (Court Fee Stamp indicating
Advocate’s name) under the leadership of ADJ CUM Advocate
Diwakar Jha a Senior Advocate cum Rtd. ADJ Khagaria Court

14
on behalf of father of Petitioner-In-Person Shri Deep Narayan
Poddar on 15.09.2007 (Hand Written Note on page 4 is
indicating date of drafting HMA petition) while Petitioner-In-
Person was in Palam Colony New Delhi. That record of draft
HMA petition by Katihar Court is evident of this fact that
Advocate has deliberately misled father-in law of victim by
instituting a civil suit u/s 9 of HMA to sustain trafficking and
Prostitution. Instead of registering an F.I.R u/s 154(1) of Cr.Pc.
with Police to rescue her from the brothel of Prostitution,
Advocate preferred to file Civil Suit under HMA.
True copy of draft suit u/s 9 of HMA dated
15.09.2007 by Advocate Awadesh Kumar Jha, Katihar
Court is annexed herein as Annexure P-1 (Page from
44 to 52).
5. That after the first misleading intervention by Advocate
Awadesh Kumar Jha, Katihar Court on behalf of Victim’s
Father-in-Law Shri Deep Narayan Poddar; Second intervention
has been misled by Bihar Women Protection Officer, Ms.
Veena Kumari wife of Advocate Gopal Prasad, Begusarai Court
with an active support of Women Commission Bihar dated
30.03.2010. Instead of approaching Police Station for
registering an F.I.R to rescue the victims from the brothels of
Prostitution; Women Commission of Bihar through its Women

15
Protection Officer has approached Chief Judicial Magistrate of
Begusrai Court under the judicature of Patna High Court for
instituting a Complaint Case before the Judiciary. State owned
Prostitution Victim Ms. Rina Kumari (Guddi) has appeared
before Shri Chandra Mohan Jha, Chief Judicial Magistrate of
Begusrai Court under the judicature of Patna High Court.
Subsequently, Shri Chandra Mohan Jha, Chief Judicial
Magistrate of Begusrai Court has passed an order dated
31.03.2010 in Case No. 9P/2010 under Section 12 of Domestic
Violence Act 2005.
True copy of order dated 31.03.2010 in Case No.
9P/2010 u/s 12 of DVAct 2005 by Chief Judicial
Magistrate of Begusrai Court under the judicature of
Patna High Court is annexed herein as Annexure P-2
(Page from 53 to 53). .
6. That thereafter State owned Prostitution Victim Ms. Rina
Kumari (Guddi) has appeared before the court of Shri Atul
Kumar Pathak, 1st
Class Judicial Magistrate, Begusrai Court
under the judicature of Patna High Court for recording her
statement on 7.4.2010.
True copy of Statement of State Victim Ms. Rina
Kumari (Guddi) recorded by Shri Atul Kumar Pathak,
1st
Class Judicial Magistrate at Begusrai Court under

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the judicature of Patna High Court on 7.04.2010 in
Case No. 9P/2010 u/s 12 of Domestic Violence Act
2005 in trafficking & Prostitution matter is annexed
herein as Annexure P-3 (Page from 54 to 55).
7. That State owned Prostitution Victim Ms. Rina Kumari
(Guddi) has filed a Domestic Violence Petition Case No.
9P/2010 u/s 18, 19, 20, 21, 22 of Domestic Violence Act 2005
through her counsel Advocate Gopal Prasad on 02.06.2010,
wherein the name of minor daughter has been disclosed as
Shriya Rajhansh and age disclosed about 5 years at para 9 of
petition.
True copy of Petition dated 2.6.2010 u/s 12 of
Domestic Violence Act 2005 in Case No. 9P/2010
before Shri Atul Kumar Pathak Court, 1st
Class
Judicial Magistrate at Begusrai Court under the
judicature of Patna High Court by State Victim Ms.
Rina Kumari (Guddi) in trafficking & Prostitution
matter is annexed herein as Annexure P-4 (Page
from 56 to 58).
8. That Court of Shri Atul Kumar Pathak Court, 1st
Class
Judicial Magistrate at Begusrai Court under the judicature of
Patna High Court has passed an order dated 25.08.2010 in Case
No. 9P/2010 with an issuance of Non Bail able Warrant (NBW)

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through SP Begusrai against the Petitioner Om Prakash and his
Mother Asha Rani Devi.
True copy of order dated 25.08.2010 in Case No.
9P/2010 with an issuance of Non Bail able Warrant
(NBW) through SP Begusrai by Shri Atul Kumar
Pathak, 1st
Class Judicial Magistrate at Begusrai Court
under the judicature of Patna High Court against the
Petitioner Om Prakash and his Mother Asha Rani
Devi is annexed herein as Annexure P-5 (Page from
59 to 59).
9. That State Victim Ms. Rina Kumari (Guddi) has filed a
Criminal Complaint Case (P) No. 397/2011 computerized as
5591/2013 dated 7.2.2011 u/s 323, 498A, ¾ Dowry Prohibition
Act under the Women Protection Act through her counsel
before CJM Court Begusarai, thereafter the case has been
marked to Sub Divisional Magistrate (SDJM) Court Begusrai
and the same has been kept secret by the court to sustain
trafficking and Prostitution of the Victims till 2016. Petitioner
has unearthed this case by filing RTI and Writs before Central
Information Commission and Supreme Court of India and Patna
High Court in late 2016-2019.
True copy of Petition dated 7.02.2011 in Criminal
Complaint Case (P) No. 397/2011 computerized as
5591/2013 filed by State Victim under Women

18
Protection Act at Begusrai Court under the judicature
of Patna High Court in trafficking & Prostitution
matter is annexed herein as Annexure P-6 (Page
from 60 to 63).
MAJOR BREAKTHROUH ACHIEVED BY
COLLECTING PRIMARY DATA FROM THE FIELD OF
HUMAN TRAFFICKING (2020-TILL DATE):
10. That a major breakthrough has been achieved by identifying
a victim as sister-in-law of petitioner as Ms. Rupam Kumari
alias Dolly inside the house of Shankar Sah (Public Distribution
System dealer fair shop) at Sonaili Katihar, subsequently
collecting her personal information from the matrimonial
website www.Shaadi.com.
True copy of Personal information of State Victim
sister-in-law Ms. Rupam Kumari alias Dolly dated
31.01.2014 collected from the matrimonial website
www.Shaadi.com in trafficking & Prostitution matter
is annexed herein as Annexure P-7 (Page from 64 to
68).
11. That Action Taken Report (ATR) dated 7.5.2016 by Shri
Chandrika Prasad, Sub-Divisional Police Officer (SDPO),
Barsoi Katihar Bihar is evident of this fact that Asha Deep
Niwas at Sonaili Katihar Bihar of Petitioner is being turned into
a Brothel/Red Light area by Gang raping his female family

19
members by the State (SP Katihar Sidharth Mohan Jain),
engraving printed material/posters for Public Toilet at the main
gate of the House in the absence of petitioner (w.e.f. 28.2.2016
to 6.3.2016).
True copy of ATR dated 7.5.2016 by Bihar Police in
Public Toilet and Gang Rape by the State in
trafficking & Prostitution matter is annexed herein as
Annexure P-8 (Page from 69 to 73).
12. That replication with dissatisfaction against ATR dated
7.5.2016 has been filed online on 17.5.2016 before Chief
Minister of Bihar’s Office; further an Additional I.A.
No.03/2016 dated 17.03.2016 in W.P. Civil 90/2016 and W.P.
Crl. 136/2016 before this Hon’ble Court and Criminal Writ
Jurisdiction Case No. 1238/2019 before Patna High Court has
been filed in protest against the Gang Rape by the State.
True copy of replication dated 17.5.2016 against ATR
dated 7.5.2016 before Chief Minister Office
Government of Bihar in Public Toilet and Gang Rape
by the State in trafficking & Prostitution matter is
annexed herein as Annexure P-9 (Page from 74 to
76).
13. That ATR dated 10.02.2018 by ACP Uma Shankar, Delhi

20
Cantt. Delhi Police is evident of this fact that mother Asha Rani
Devi of petitioner is being killed to usurp her property in Bihar
and to sustain trafficking and Prostitution of her families by the
State.
True copy of ATR dated 10.02.2018 by ACP Uma
Shankar, Delhi Cantt. Delhi Police in Suspicious death
of mother Asha Rani Devi of petitioner in trafficking
& Prostitution matter is annexed herein as Annexure
P-10 (Page from 77 to 79).
14. That ATR dated 15.02.2018 against PCR Call vide DD No.
29B dated 19.10.2017 by ACP Uma Shankar, Delhi Cantt.
Delhi Police through Ministry of Home Affairs is evident of
this fact that Victims are being Gang Raped by Head Constable
MR. OM PRAKASH & Head Constable Mr. RAHUL, Palam
Village Police Station in the guise of Supreme Court’s
guidelines for bursting/firing the Crackers in Diwali festival and
by scaring petitioner‘s mother, Asha Rani Devi.
Shankar, Delhi Cantt. Delhi Police through Ministry
of Home Affairs in Gang Rape of State Victims is
81).

21
15. That ATR dated 24.02.2018 against PCR Call vide DD No.
29B dated 19.10.2017 by ACP Uma Shankar, Delhi Cantt.
Delhi Police through Government of NCT of Delhi is evident of
this fact that Victims are being Gang Raped by Head Constable
MR. OM PRAKASH & Head Constable Mr. RAHUL, Palam
Village Police Station by scaring petitioner‘s mother, Asha
Rani Devi in the guise of Supreme Court’s guidelines for
bursting/firing the Crackers in Diwali festival.
Shankar, Delhi Cantt. Delhi Police through
Government of NCT of Delhi in Gang Rape of State
Victims is annexed herein as Annexure P-12 (Page
from 82 to 83).
Pankaj Kumar, Sub-Divisional Police Officer (SDPO), Barsoi
Katihar Bihar has admitted this fact that installation of bore-
well for drinking water for Public has been installed inside the
house premises of Petitioner “Asha Deep Niwas” at Sonaili.
Ironically, bore-well for Public drinking water is an indicative
of illicit sex trade of families for revenue generation by the
State.
True copy of ATR dated 16.05.2018 by Shri Pankaj
Kumar, Sub-Divisional Police Officer (SDPO), Barsoi

22
Katihar Bihar in Public drinking water & Public toilet
inside the house premises of petitioner at Asha Deep
Niwas at Sonaili is annexed herein as Annexure P-13
(Page from 84 to 85).
17. That replication with dissatisfaction against ATR dated
16.5.2018 has been filed online on 26.6.2018 before Chief
Minister of Bihar’s Office, subsequently substantiated by filing
an M.A. No. 2836/2018 in W.P. Crl. Diary No. 2188/2017
against Union of India; thereafter an order dated 7.12.2018 has
been passed by this Hon’ble Court in this matter.
True copy of replication dated 26.6.2018 against ATR
dated 16.5.2018 before Chief Minister Office
Government of Bihar in Public Toilet and Gang Rape
by the State is annexed herein as Annexure P-14 (Page
from 86 to 86).
18. That Shockingly, trafficking and Prostitution is continued
by the State on the ground of prevailing misconceived notions
and slogans manifested by Amnesty International INGO that
“Sex Worker’s Right is Human Rights” in absence of Bare Act
on Prostitution. The set formula and vicious cycle of
Prostitution by the State is very cunning and violating the Rule
of Law. State pulls the vulnerable section of society from their

23
households and forcefully pushes them into the mud of
Prostitution thereafter designing a rehabilitation plan on the
distorted concept of Disaster Risk Management and Resilience
(DRMR) to sustain the vicious cycle of trafficking and
Prostitution instead of designing a Rescue and Rehabilitation
(R&R) plan on the ground of accepted concept by all for
eradicating the Leprosy of Prostitution. State is manufacturing,
maintaining and sustaining the Sex Workers; violating the Rule
of Law, concealing the material facts, framing the false cases,
issuing a fake Non Bail able Warrants, changing the
jurisdictions of the victims, changing the legal status of the
victims and delivering a wrong judgment to sustain
International Sex Racket. Presently, India is a victim of Man-
made National Disaster leading towards International disasters.
Vikash Kumar SP Katihar and Shri Pankaj Kumar, Sub-
Divisional Police Officer (SDPO), Barsoi Katihar Bihar has
admitted this fact that No Non Bail able (NBW) Warrant u/s 82
& 83 Cr.Pc. is pending against the Petitioner and his mother
Mrs. Asha Rani Devi to execute the Order; is an indicative of
sustenance of trafficking, Prostitution and illicit sex trade by
suspending and infringing the fundamental Rights of petitioner

24
under Article 21 of the Constitution of India for generating
revenue out of it.
True copy of ATR dated 31.05.2019 by Shri Vikash
Kumar SP Katihar and Shri Pankaj Kumar, Sub-
Divisional Police Officer (SDPO), Barsoi Katihar
Bihar in NBW & Kidnapping; abduction & Sexual
Harassment matter is annexed herein as Annexure P-
15 (Page from 87 to 88).
Vikash Kumar SP Katihar and Shri Pankaj Kumar, Sub-
Divisional Police Officer (SDPO), Barsoi Katihar Bihar in Mob
Violence and Prostitution matter; is an indicative of sustenance
of trafficking, Prostitution and illicit sex trade by declaring
petitioner as mentally ill and by causing state coercion,
inflicting barbaric state action, blocking the way of petitioner
through violent irritating crowds at every nook and corner
across India, causing noise, air and water pollutions and
suspending/infringing the fundamental Rights of petitioner
under Article 21 of the Constitution of India by issuing fake
NBW against him to generate revenue out of it.

25
Kumar SP Katihar and Shri Pankaj Kumar, Sub-
Divisional Police Officer (SDPO), Barsoi Katihar
Bihar in Mob Violence, Kidnapping; abduction &
Sexual Harassment matter is annexed herein as
Jai Prakash Narayan SP Traffic, Katihar and Shri Shiv Prassan
Singh, Police Inspector Kadwa Police Station in Mob Violence
and trafficking & Prostitution matter; is an indicative of
sustenance of trafficking, Prostitution and illicit sex trade by
declaring petitioner as mentally ill and by causing state coercion
against him, inflicting barbaric state action against him,
blocking his way through violent irritating crowds at every
nook and corner across the Country, causing noise, air and
water pollutions to disturb him and suspending/infringing his
fundamental Rights under Article 21 of the Constitution of
India by issuing two fake NBW u/s 82 & 83Cr.Pc. against him
to generate revenue out of it. This ATR also discloses the
evidence that a reverse case/Non-F.I.R No. 173/19 u/s
107Cr.Pc. dated 05.08.2019 has been registered against
neighbor (1) Shri Bechan Poddar S/O Sahdev Poddar (2)
Shusheel Poddar (3) Guddu Poddar and the same has been
forwarded to the SDM Court Barsoi by the State.

26
True copy of ATR dated 29.11.2019 with Non-F.I.R
No. 173/19 u/s 107Cr.Pc. dated 05.08.2019 registered
by Shri Jai Prakash Narayan SP Traffic, Katihar and
Shri Shiv Prassan Singh, Police Inspector Kadwa
Police Station in Mob Violence, Kidnapping;
abduction & Sexual Harassment matter is annexed
Vikash Kumar SP Katihar and Shri Ranjay Kumar Singh,
Station House Officer (SHO) Kadwa Katihar Bihar in Mob
Violence and Prostitution matter; is an indicative of sustenance
of trafficking, Prostitution and illicit sex trade by declaring
petitioner as mentally ill, causing state coercion, inflicting
barbaric state action, blocking the way of petitioner through
violent irritating crowds at every nook and corner across India,
causing noise, air and water pollutions and
suspending/infringing the fundamental Rights of petitioner
under Article 21 of the Constitution of India by issuing fake
NBW against him to generate revenue out of it.
Kumar SP Katihar and Shri Ranjay Kumar Singh,
Station House Officer (SHO) Kadwa, Katihar Bihar in
Mob Violence, Kidnapping; abduction & Sexual
Harassment matter is annexed herein as Annexure P-

27
23. That ACP Uma Shankar, Delhi Cantt. Delhi Police has
submitted ATR dated 13.02.2021 (in between the rescue
operation conducted for sex racket victims at Shastri Park North
East Delhi) through Ministry of Home Affairs by reaffirming its
previous stands dated 10.02.2018.
Shankar, Delhi Cantt. Delhi Police in Suspicious death
of mother Asha Rani Devi of petitioner &
continuation of Trafficking and Prostitution of
Petitioner’s families is annexed herein as Annexure P-
24. That even after statement of Petitioner recorded by Ms.
Sushma Singh mobile: 8868535329, Inquiry Officer, DCP
Vigilance Seelampur North East Delhi on 26.05.2021; rescue of
State Victims is being suppressed by non-registering an F.I.R.
to sustain trafficking & Prostitution of the Victims.
True copy of Statement of Petitioner recorded dated
26.05.2021 by Inquiry Officer Ms. Sushma Singh in

28
25. That a reply dated 22.02.2023 by Assistant Electoral
Registration Officer (AERO), AC-36 Bijwasan, Election
Commission of Delhi in connection with an attempt by the
human trafficker/sex racketeers to make a fake voter ID for
kidnapped and abducted families of petitioner is evident of this
fact that instead of surrendering in Zero tolerance case/matter;
State is reinforcing and reaffirming its Stand on trafficking and
Prostitution of petitioner’s families in absence of Bare Act on
Prostitution.
True copy of reply dated 22.02.2023 by Assistant
Electoral Registration Officer (AERO), AC-36
Bijwasan, Election Commission of Delhi in trafficking
P-21 (Page from 102 to 102).
26. That RTI NO. DEPOL/R/E/23/02378 dated 15.03.2023 has
been filed against Delhi Police to seek a copy of F.I.R against
112 PCR call with unique reference no. 3135812 dated
26.4.2021 made against Child Prostitution at Shastri Park North
East Delhi coupled by illegal arrest of Petitioner by SI Narender
Singh for blowing a Whistle against Child Prostitution in
Shastri Park North East Delhi area on 26.4.21; which has
resulted in PIL W.P.Crl. 242/2021 before this Hon’ble Court. It
is pertinent to mention here that Delhi Police has not replied

29
back RTI dated 15.3.23; hence First Appeal No.
DEPOL/A/E/23/00610 dated 14.4.2023 has been filed against
Delhi Police.
True copy of RTI dated 15.03.2023 against Delhi
Police to seek a copy of F.I.R against Child
Prostitution in Shastri Park North East Delhi area in
2021 is annexed herein as Annexure P-22 (Page
from 103 to 104).
27. That Bihar Human Rights Commission has issued direction
dated 16.03.2023 to the petitioner in case no. 7290/4/16/2022 to
file replication on the next date of hearing dated 13.07.2023.
Replication has been filed by the petitioner on 17.3.2023 to
Bihar Human Rights Commission. SHRC Bihar’s move is
evident of this fact that it is trying to derail the Prostitution
matter into normal matrimonial matter to suppress the rescue of
the victims from the brothel of prostitution.
True copy of Replication dated 17.03.2023 in case no.
7290/4/16/2022 to Bihar Human Rights Commission
in trafficking & Prostitution matter is annexed herein
as Annexure P-23 (Page from 105 to 112).

30
28. That National Human Rights Commission New Delhi has
issued a direction dated 23.03.2023 in Case No. 994/30/1/2023
to Deputy Commissioner of Police, Dariyagunj, Central Delhi;
yet victim has not been rescued as on date; rather trafficking &
Prostitution of Victim is escalated by the State.
True copy of direction dated 23.03.2023 in Case No.
994/30/1/2023 by National Human Rights
Commission New Delhi to DCP Daryagunj, Central
Delhi in trafficking & Prostitution matter is annexed
29. That Bihar Human Rights Commission has issued
another direction to the petitioner in case no.
7517/4/16/2022-WC dated 20.11.2022 to file replication on the
next date of hearing dated 06.06.2023. However, the Petitioner
has filed replication on 27.03.2023 to Bihar Human Rights
Commission. Undoubtedly, SHRC Bihar’s move is evident of
this fact that HRC Bihar is trying to derail the matter from
Prostitution to normal matrimonial matter to suppress the rescue
of the victims to sustain illicit sex trade of the victim to
generate revenue out of it.
True copy of replication dated 27.03.2023 in Case No.
7517/4/16/2022-WC to Bihar Human Rights
Commission in trafficking & Prostitution matter is

31
122).
30. That Electoral Registration Officer Bihar has replied back
dated 27.03.2023 in fake voter ID of electoral; which is evident
of this fact that fake voter ID were maintained by the State of
Bihar to usurp the property of petitioner violating the Rule of
Law; indicating towards Land for Jobs Scam, IRCTC Scam,
fodder scam by former Railway Minister and Chief Minister of
Bihar Shri Lalu Prasad Yadav, Tejashwi Yadav, Chanda Yadav,
Nisha Yadav and others charge sheeted accused by CBI.
True copy of reply dated 27.03.2023 by Electoral
Registration Officer Bihar in fake voter ID of electoral
case in trafficking & Prostitution matter is annexed
31. That a major breakthrough has been achieved by receiving a
complaint by the State Victim (Ms. Shweta R/O Amritsar
Punjab & Bihar ) of trafficking and Prostitution on 28.03.2023
under the jurisdiction of Sonaili, Katihar Bihar; just after a
final order dated 6.2.23 passed in kidnapping, abduction and
sexual harassment matter in Writ Petition (Criminal) 42 of
2023 by this Hon’ble Court. Victim Ms. Shweta is being

32
trafficked from Amritsar Punjab to Begusarai to Katihar Bihar.
A Complaint against the human traffickers has been filed by the
Victim Ms. Shweta W/O Ajay Poddar R/O Singol Airport,
Baruni Refinery, Begusarai Bihar-853411 and D/O Ram
Chander C-180, LIG Flats, Housing Board Colony Amritsar
Punjab before petitioner cum professional Social Worker Om
Prakash on 28.03.2023 at his residence Sonaili, Katihar Bihar.
Ironically, in retaliation of a complaint given by the VICTIM to
the Social Worker, She is being thoroughly victimized by the
State further, causing unnecessary mental stress infusing fear
factor in her mind, torturing her mentally to instigate her to
provoke and offend petitioner with abusive filthy language. The
same has been informed by the crying victim to the petitioner
over telephone from the moving train on 29.03.2023.
True copy of a Complaint dated 28.03.2023 by the
State Victim against the human traffickers before
Professional Social Worker and PIP SC in trafficking
P-27 (Page from 126 to 130).
32. That Shri Rajinder Singh PPS (RS), election Office
has responded the petitioner with acknowledgement e-
mail letter dated 28.03.2023in this trafficking &
Prostitution matter.

33
True copy of reply dated 28.03.2023 by Shri
Rajinder Singh PPS (RS), election Office in
33. That Banglore based Missionaries NGO EFICOR
having office at Janakpuri New Delhi and Unit office at
Sonaili Katihar being identified as additional evidence
in promoting Sex racket in the garb of Disaster Risk
Management and Resilience approach. According to
primary data collected from the field; abducted minor
daughter has been converted into Christianity
forcefully, made as an item girl, made as professional
singer with an active help of Ms. Chaturvedi’s Sufi
Kathak NGO at Saket New Delhi and Bollywood Film
star Mumbai, backed by Judicial Community of
Drbhanga Bihar. This NGO has Bank loan approach in
disaster risk management at Sonaili which works as a
first point for trapping females into the vicious cycle of
sex racket due to non-payment of installment amount
for indebted loan. A strong protest and severe
grievances dated 7.4.2023 has been registered with
DRMR-EFICOR Banglore against the suppression of
rescue and sustenance of trafficking and Prostitution of

34
the State Victims at Sonaili Katihar Bihar.
True copy of Grievances and Complaint letter dated
7.04.2023 to DRMR-EFICOR missionaries NGO
Banglore Karnataka, Janakpuri New Delhi and
Sonaili Katihar Bihar UNIT in trafficking &
Prostitution matter is annexed herein as Annexure P-
29 (Page from 132 to 137).
34. That for the first time State of Bihar has submitted Action
Taken Report (ATR) dated 11.4.2023 in trafficking &
Prostitution matter through its Director, Department of Social
Welfare, after the final Order dated 06.02.2023 in W.P. Crl.
42/2023 in Kidnapping; abduction & Sexual Harassment matter
passed by Supreme Court of India. Action Taken Report (ATR)
dated 11.4.2023 by Director, Department of Social Welfare,
Government of Bihar has thoroughly denied from Kidnapping;
abduction, Sexual Harassment of the Petitioner’s families. ATR
further denies from trafficking & Prostitution of the Victims.
True copy of Action Taken Report (ATR) dated
11.4.2023 by Director, Department of Social Welfare,
Government of Bihar in Kidnapping; abduction,
Sexual Harassment, trafficking & Prostitution mater is
148).

35
35. That after denial of Sex Racket by the State Government of
Bihar and intimation along with Memo of Parties & certified
copy of order dated 6.2.23 in W.P.Crl. 42/2023 by Supreme
Court to Shri Anil Kumar Lahoti, Chairman Railway Board
New Delhi dated 22.03.2023 and 23.03.2023; indulgence of
Victims are being identified into illicit sex trade inside the
Siliguri-Katihar DMU Passenger train no.07544 under the
North Eastern Frontier Railway Zone (NEFR) of Indian
Railway Network on 11.4.2023. The same has been reported to
Shri Anil Kumar Lahoti, Chairman Railway Board New Delhi
and Shri Anshul Gupta, General Manager, NEFR on 12.04.2023
with a strong protest.
True copy of Complaint dated 12.4.2023 to Chairman
Railway Board New Delhi and GM (NFR) in
Kidnapping; abduction, Sexual Harassment,
trafficking & Prostitution mater is annexed herein as
36. That RTI No. CBIMH/R/E/23/00193 dated 12.04.2023 has
been filed against CBI to seek reply against the six questions
related to suppression of rescue of the Victims and further
Victimization of Victims by the State even after Final Order
passed by this Hon’ble Court on 06.02.2023 in W.P.Crl.
42/2023.

36
True copy of RTI dated 12.04.2023 against CBI to
seek reply against six questions related to suppression
of rescue of the Victims and further Victimization of
the Victims by the State in trafficking & Prostitution
mater is annexed herein as Annexure P-32 (Page
from 154 to 155).
37. That just after the drugging & Gang Raping of VICTIMS
dated 11.4.2023 by GRP Railway Sonaili under NEFR Zone;a
complaint dated 12.4.2023 has been filed by the petitioner to
Chairman and GM NFR. Thereafter, Shri Randhir Singh, GRP
Delhi has responded the petitioner through email dated
12.4.2023 to contact GRP Delhi rather than complying the Final
Order of this Hon’ble Court. This evidence is indicative of State
coercion in suppressing the rescue of the victims and continuing
the Gang Rape & illicit sex trade of the Victims.
True copy of email letter dated 12.04.2023 by Shri
Randhir Singh, GRP Delhi in trafficking &
33 (Page from 156 to 156).
38. That Victims are being trafficked to Katihar Bihar by the
same train Seemanchal Express train no. 12488 from Anand
Vihar Terminal Delhi (on which the petitioner was travelling on

37
waiting journey cum reservation ticket vide PNR No. 273-
7732398 dated 28.02.2023) by hiding them from the Petitioner.
Thereafter, victims being pushed into the same business of flesh
trade at the source point of human trafficking at Sonaili Katihar
Bihar and Siliguri, Bagdogra, Alipudwar, Raigunj, Maldah in
West Bengal. Shri Pramod Kumar Singh mobile no.
8987447313, SRP GRP Katihar called the petitioner on
1.4.2023 at 15:03pm at the SRP GRP office located behind plat
Farm No. 01 of Katihar Railway Station. Shri Kumar
Devender, DSP GRP HQ Katihar is being briefed about the case
by the petitioner along with a copy of Final order dated 6.2.23
in W.P. Crl. 42/2023 of this Hon’ble Court and Memo of
Parties. The involvement of GRP Katihar in trafficking and
Prostitution of Petitioner’s family members has also been
clarified to DSP. However, DSP denied from it. After denial by
DSP HQ GRP Katihar, Petitioner approached Ms. Mona Lisha
Sah mobile: 9123239085, Supervisor cum CRP at Shelter
Homes, New Bus Stand, Plot No. 656, Katihar Manihari Road,
Katihar Bihar funded by DAY-NULM to find out and to meet
the State Victims on 10.04.2023. However, the shocking
primary data have been collected by the statement of Ms. Mona
Lisha Sah substantiated by the secondary data collected from
the website of Urban Development & Housing Department

38
(UD&HD) Government of Bihar. The above said, only Shelter
Home existing in Katihar district and is functional with effect
from 31-12-2019 on paper but Non-functional on the ground in
Katihar Municipal Corporation. Another Shocking information
being shared by the nodal authorities of Shelter Home Katihar
that a shelter home is running inside the premises of District
Health Centre, Sadar Hospital Katihar under the supervision of
a Committee constituted by Supreme Court of India. This
ground zero evidence collected from worst and most
affected district of Bihar in connection with trafficking
& Prostitution is highlighted in the National Map. This
information made the Petitioner restless. Hence,
Petitioner has tried to establish communications with all
the Stakeholders of the State Shelter Home from Bottom
to Top. The names of different Stakeholders are as
follows:-
i) Ms. Mona Lisha Sah, Supervisor/CRP, Katihar
Shelter Home mob:9123239085
ii) Mr. Ajit Pandey, Manager Social Development &
Infrastructure, Purnea Katihar, Barsoi, Shelter
Home, mob: 9525156138
iii) Mr. Ved, Consultant mob:9113472147, Shelter

39
Home, UD&HD, Patna Bihar
iv) Mr. Vinay Kumar, City Manager Katihar Shelter
Home, mob: 9122534026
v) Mr. Kumar Mangalam, Municipal
Commissioner/Executive Officer, Katihar Nagar
Nigam, mobile: 7488579960/9471691945
vi) Mr. Dharmendra Singh, MD BUIDCO Shelter
Home, UD&HD, Patna Bihar 0612-
2506208/2217992
vii) Mr. Arunish Chawla, Additional Chief Secretary,
Shelter Home, UD&HD, Patna Bihar 0612-
2215550
viii) Mr. Dhananjay Kumar, PS to Principal Secretary,
Shelter Home, UD&HD, HQ, Patna Bihar, mob:
8544101705
ix) Mr. Lalit Vijay PS to Principal Secretary, Shelter
Home, UD&HD, HQ, Patna Bihar, mob:
7488874053
x) Mr. Tejashwi Yadav, Deputy Chief Minister of Bihar
and Minister of Urban Development &Housing
Department (UD&HD) HQ, Shelter Home Bihar

40
0612-2233099/2222079.
None of them responded except (i), (ii), (iii) and
(iv) serial numbers noted above. Looking by
standard apathy of nodal authorities from bottom
to top at the Shelter Home Bihar under the Urban
Development &Housing Department (UD&HD),
Government of Bihar, Petitioner has filed a
complaint against the nodal authorities of Shelter
Home Bihar along with Memo of Parties and
certified copies of Final Order by this Hon’ble
Court on 13.04.2023.
True copy of complaint dated 13.04.2023 against
nodal authorities of Shelter Home Bihar under the
Urban Development &Housing Department
(UD&HD), Government of Bihar in trafficking &
34 (Page from 157 to 164).
39. That instead of complying the final order of this
Hon’ble Court, executives are engaged in diverting,
derailing, misleading and delaying the matter by its
consistent efforts to arise a fresh cause of action to
defend their heinous work/misdeeds. Email dated
15.4.2023 by Cyber Police Station Dwarka New Delhi is

41
evident of the above said fact.
True copy of Email dated 15.4.2023 by Cyber
Police Station Dwarka New Delhi in trafficking &
35 (Page from 165 to 165).
40. That Crucial breakthrough has been achieved by
identifying obvious linkages of this trafficking &
Prostitution matter with petitioner’s previous work
associates from IAS, IPS and defense background. Main
accused is Mr. Ajit Kumar IAS, worked as district
magistrate of hotspots Red Light Area in Bihar viz.
Purnea, Khagaria and Muzaffarpur districts, later came
to Delhi as Joint Secretary with Govt. of India. He is
the most corrupt district magistrate who protected
Gangster, Mafia turned Politician Mr. Pappu Yadav by
evading his criminal records and evidences in CPI
leader murder case at Purnea district of Bihar. Another
key human trafficker and coworker of petitioner is Mr.
Dr. U.N.B Rao IPS, member in Police Reform
Committee with Government of India and running an
NGO Urvi Vikram Charitable Trust for adolescents
across the country and promoting trafficking &

42
Prostitution of the minors across the country. Some of
the key names of seller and buyer of minor girls,
prostitutes have been identified at source point of
trafficking at Sonaili Katihar Bihar having links with
seller and buyer of transit and destination point of
human trafficking. 161 seller and buyer’s names have
been recorded in Annexure. Apart from these names;
Key names of buyer & seller for minor girls and
prostitutes from source point at Sonaili are given
below:-
a) Mr. Manish Saboo, brothel no. 62 GB Road New
Delhi, mobile: 9871123393
b) Mr. Sunil Bubna, Sonaili Katihar Bihar, Mob:
9431096389
c) Mr. Vishnu Sharma, driver of under human trafficker
Mr. Ranjan Singh R/O Mirchaibari, Katihar, mobile:
8521286830
d) Mr. Chunuwa Poddar, (working for Banti Bubna,
Rkesh Bubna, Manoj Aggarwal, Pappu Bubna, Arun
Dokania, Manthu Dokania) Sonaili Katihar Bihar,
Mob:
8586998177/9999667967/7562010398/7042295533

43
e) Advocate Rintu Gupta alias Rupesh Kumar Katihar
Court, mob: 9931696331
f) Advocate Shankar Prasad Sonaili, Katihar Court,
mob: 9570544651
g) Advocate Shravan and Naresh Kanti Katihar Court,
mob: 7004704492
h) Mr. Virat Kishor Nanda DRMR-EFICOR Sonaili,
Katihar, mob: 7651993648
i) Mr. Anupam/Ratnakar, DRMR-EFICOR Sonaili,
Katihar, mob: 9507558227
A strong protest has been registered through a
complaint dated 19.04.2023 to CBI against these IAS
IPS Defense background human traffickers having
nexus with Buyer & Sellers of minor girls, sex worker
and prostitutes at source, transit and destination point
of human trafficking across world.
True copy of complaint dated 19.4.2023 against
IAS IPS Defense background human traffickers
to CBI in trafficking & Prostitution matter is annexed

44
41. That surprisingly, petitioner has received a mobile
SMS dated 20.04.2023 at 11:32am by Supreme Court
Legal Service Committee (SLSC) with a text “Your
application for Legal Aid has been received. Your
Application ANR No.1235-2023. visit SCLSC Website
for checking status”. Details at SLSC website discloses
Mode: as District Legal Services Authority along with
applicant’s address as R/o Asha Deep, Niwas, Sonaili,
shukkar Hatt, In Front of Durga Andir, Kantiya
Panchayat, PS. Kadwa. This misdeed/heinous work has
been done out of frustration by the sex abuser Supreme
Court Legal Service Committee (SLSC) because they
had transferred this case from Delhi to Bihar without
the knowledge and intimation to the Petitioner to
sustain sex racket. Moreover, the petitioner has neither
approached Supreme Court Legal Service Committee
(SLSC) nor applied for any Legal Aid services in this
matter. It is pertinent to mention here that I.A. No.
134091/2021 dated 16.10.2021 in PIL on Child
Prostitution W.P. Crl. 242/2021 for allocation of
Advocates through Legal Aid services in Writ Petition
has been denied by this Hon’ble Court to dismiss and
sustain the trafficking & Prostitution of the Victims.

45
This cause of action arose in Katihar district of Bihar
when the Victims were being identified by the
petitioner in Black Burka inside the Jharkhand
registered Car in front of Ansari Medical shop, Bata
Chowk under the jurisdiction of Katihar on 20.04.2023.
The same has been reported to SHO Tilak Marg New
Delhi (with reference to D.D.NO. 40 dated 18.06.2022)
and CBI, DCP North, DCP North East on 20.4.23.
Moreover, the role of Legal Aid is over now. Now the
role of Public Prosecutor, Judicial Magistrate at district
level and Niyaymitra at Panchayat level is in the
forefront to rescue the State Victims from Prostitution.
Public Prosecutor and Judicial Magistrate is one of the
parties in this writ petition criminal 42/2023; on the
contrary, instead of rescue of the victims, Public
Prosecutors are sustaining the illicit sex trade of
Victims. Proactively, Petitioner has contacted the
Public Prosecutors of Katihar district for rescue of the
victims but they have denied their role in this matter.
Names of Public Prosecutors & Judicial Magistrate
Katihar Bihar along with mobile numbers are given
below:-
i) Advocate Jai Prakash Singh (PP Katihar

46
Jurisdiction), mobile: 9431640405
ii) Advocate Sanjeev Aggarwal (PP Kadwa Jurisdiction),
mobile: 8797131441
iii) Ms. Neha Singh, 1st
Class Judicial Magistrate,
Katihar & Barsoi Mobile: 9051880342
iv) Advocate Viplav Kanti (Niyay Mitra Kantiya,
Sonaili, Kadwa Panchayat Jurisdiction), mobile:
7992255110
v) Advocate Shankar Prasad (Niyay Mitra Salmari
Panchayat Jurisdiction), mobile: 9570544651
True copy of screen shot of fake application ANR
No.1235-2023 for Legal Aid made on behalf of
Petitioner collected from the website of Supreme
Court Legal Service Committee (SLSC) dated
20.4.2023 in trafficking & Prostitution matter is
182).
42. That Dr. Rajesh owner of Delhi based SPYM NGO
partnering with DUSIB for Delhi Shelter Home
Management is being informed about the insensitive
style of working by his HOD/Coordinator Mr. Nitish
mobile 9990387222, deputed in the Red Light area of

47
Central district at Delhi. Director and In Charge of
DUSIB for Delhi Shelter Home Management along with
copy to more than 150 stakeholders of state and central
Government has been informed against the insensitive
style of working by its partner NGO, RACHNA’s
employee Ms. Sheepa Sharma, Coordinator RACHNA
mobile: 8510084441, deputed in the Red Light area of
Central district at Mori Gate Delhi.
True copy of Complaint dated 23.4.2023 to nodal
authorities of DUSIB for Delhi Shelter Home
Management against the misdeed caused by its
partner NGOs SPYM & RACHNA employees in
43. That Delhi Shelter Home Violent Attack is being
organized by the joint collaboration of Director, In
charge, Head of the Department/Coordinator and
Supervisors of Delhi Shelter Homes on 24.4.2023
evening, just after the arrival of Petitioner from Katihar
Bihar to Delhi for Court hearing purpose at Supreme
Court of India with prior intimation to the above said
nodal authorities of Shelter Home Delhi. Nodal

48
Authorities of Delhi Shelter Home has been informed
from moving train no. 15483 Sikkim-Mahananda
Express dated 23-4-2023, PNR No. 631-8609715 coach
no. 03 and berth no. 24. The same has been reported to
CBI, DCP North and DCP North East on 25.4.2023 after
the incident.
True copy of complaint dated 25.4.2023 against the
Delhi Shelter Home violent attack on Petitioner in
44. That apart from Dr. Rajesh’s SPYM NGO at New
Delhi, Mr. Ajit Singh’s (05422504253) Guria NGO at
Varanasi, Uttar Pradesh has been identified for
promoting illicit sex trade, trafficking and Prostitution
of minor girls across the Country. It is pertinent to
mention here that both the NGOs are working for the
welfare of the prostitutes at brothels in the Red Light
areas in their respective regions. Petitioner has
conducted a social audit for Guria NGO at Varanasi in
the capacity of BTI Coordinator under UNDP-TAHA
Project in 2006. Petitioner has strongly agitated before
Ajit Singh’s Guria NGO through email one year ago to

49
rescue the families of petitioner (State Victims) from
the brothel of Varanasi; yet he did not pay any heed to
the request of the Petitioner as on date.
45. That evidence against the prevailing practices in
POCSO cases in Katihar district is astonishing,
shocking and thrilling. A case of minor girl Nidhi
younger sister of Chanda R/O Argara Chowk, Katihar
Bihar mobile no.7257955586 has been identified as
thrilling case. This case has been suppressed by the
State Public Prosecutor by taking handsome bribe from
the rapists and compelled the victim to compromise by
cracking money deal with the perpetrators. The Victim
is being scared and inflicted stigma on her by the Public
Prosecutor. This tactics of suppressing POCSO cases by
the State is alarming for grave situation and promoting
illicit sex trade, trafficking and prostitution in the
region.
46. That another shocking evidence has been collected
from the Salmari Katihar district of Bihar. A wrong,
unethical, illegal child adoption practices in public and

50
private health institutions are prevailing at Salmari to
sustain illicit sex trade, trafficking and prostitution.
Crucial information has been disclosed by the daughter
of Shri Ram Dev Poddar R/O Salmari Katihar that her
brother has bought a two hours old baby in Rs. 50,000/-
from a local clinic or hospital at Salmari without
disclosing the identity of buyer and seller. This
evidence is indicative of grave situation in that area.
47. That on 25.4.2023 at 12:38pm, ACP Crime Branch
took the brief about the case from the petitioner by his
mobile no. 9871232232. BUT NO RESCUE YET.
PRAYER
It is most respectfully prayed that this Hon’ble Court may be
pleased to:
(a) Allow to adduce additional evidences recorded from para 01
to 47 along with Annexure P-1 to Annexure P-39,
proliferating and substantiating original evidences, recorded
in Writ Petition Criminal No. 42/2023 and enabling the
jurist to review and reconsider the Final Order dated
6.2.2023 passed by this Hon’ble Court.

51
(b) Exempt to file the untranslated copies of evidences from
Hindi to English.
(c) Pass such other order/orders as this Hon'ble Court may deem
just and proper in the facts and circumstances of the case.
PETITIONER-IN-PERSON
PROFESSIONAL SOCIAL WORKER (MSW)
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 ANDIR,
KANTIYA PANCHAYAT, P.S. KADWA,
KATIHAR, BIHAR-855114,
MOB: 9540389759
E-mail: om.poddar@gmail.com
NEW DELHI:
FILED ON : 01-05-2023

52
CRL.M.P.NO. 90171 OF 2023
IN
IN
AND
IN THE MATTER OF
INTERNATIONAL SEX RACKET,
CHILD SEXUAL ABUSE, FORCED
HIDDEN PROSTITUTION ABUSE OF
POLICE POWER, SUSPICIOUS
DEATH, AND MOB VIOLENCE/MOB
LYNCHING.
AND
IN THE MATTER OF:
OM PRAKASH ..PETITIONER
VERSUS
UNION OF INDIA & ORS …….RESPONDENT(S)
AFFIDAVIT
I, Om Prakash S/o Late Shri Deep Narayan Poddar, age about 48
years, R/o Asha Deep Niwas, Vill-Kantiya Panchayat, Shukkar
Haatt, P.S. Kadwa, Distt-Katihar, Bihar-855114 and Rented R/O
RZF/893, Netaji Subash Marg, Raj Nagar Part-II, Palam Colony,
New Delhi - 77, do hereby solemnly affirm and state on oath as
under:-
1. That I am the Petitioner in the above matter and well
conversant with the facts of the case as such competent to
swear this affidavit.

53
2. That the contents of the accompanying application Under for
adducing additional evidence in Review Petition Criminal
No. 107/2023 in Writ Petition (Criminal) No.42/2023 with
exemption from untranslated copies of evidences from Hindi
to English, which has been drafted by me [para 01 to 47],
[Page 01 to 41] 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 annexure P-01 to P-39 [Page 44 to 194] are true
copies of their respective original.
4. That the accompanying application for adducing additional
evidences is total 194 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 1st
day of May, 2023.
DEPONENT
Affidavit notarized by Ms. K.Bandana, Reg.No.19718, date of
expiry: 26.02.2025, mobile no. 9654768498, Notary Public
Government of India dated 01-05-2023 at Supreme Court.

I.A. No. 90171 of 2023 in Review Petition Criminal 107 of 2023 dated 01.05.2023.pdf

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I.A. No. 90171 of 2023 in Review Petition Criminal 107 of 2023 dated 01.05.2023.pdf