1. The legal notice demands that the inquiry into the Kheda flogging incident be handed over to a retired High Court judge of Gujarat instead of the Ahmedabad Range IG conducting the inquiry. 2. The notice argues that having the police itself look into atrocities committed by its own officers does not inspire confidence and risks bias. 3. It further states that any right thinking citizen would apprehend a futile inquiry unless it is conducted impartially, fairly, and transparently by a retired High Court judge.

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ANANDVARDHAN J. YAGNIK
Advocate
ADVOCATE CODE NO. 1372
3rd Floor, Panchani Chambers, Opp. Asia School, Drive in Road, Thaltej,
Ahmedabad-380054
Phone: (O) 079 27480034, Mobile: 98250 68179 Email: ajyagnik@gmail.com
07th
October, 2022
LEGAL NOTICE
By REGISTERED POST A.D./ EMAIL
To,
1. The Chief Secretary
State of Gujarat,
Address: 1st
Block, 5th
Floor,
Sachivalaya, Gandhinagar – 382010.
2. The Additional Chief Secretary
Department of Home,
State of Gujarat,
Address: 2nd
Block, 1st
Floor,
Sachivalaya, Gandhinagar – 382010.
3. The Director General of Police
State of Gujarat
Shri Ashish Bhatia,
Address: Office of the DGP, Police Bhavan,
Sector 18, Gandhinagar - 382021
4. The Superintendent of Police

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Kheda District,
Address: Office of the SP,
Near Railway Over Bridge, Ashram Road,
Nadiad – 387001.
Reference: Newspaper Report dated 06.10.2022 titled “Gujarat Police
to take action against those found guilty in Kheda Flogging
Incident.”
Subject: Legal Notice for demanding and handing over the inquiry
into the Kheda Flogging Incident to a Retired Judge of the
Hon’ble High Court Judge of Gujarat.
Sir/ Mam,
Under the instructions of my client, Mr. Mujahid Nafees, Aged 39 Years,
Residing at D-404, Hateem 1, Next to Bagh-e-nishat Society, Sonal Road,
Juhapura, Ahmedabad – 380055, I issue this notice as under:
1. My client who is the Convenor of Minority Co-ordination Committee
[hereinafter “MCC”], Gujarat State which is working for the rights and
welfare of the citizens of all the minorities of the State of Gujarat had
issued legal notice dated 06.10.2022 for the initiating suitable action
against erring police officials responsible for Flogging in Undhela Village
of Matar Taluka of Kheda District for an incident that occurred on 3rd
/
4th
October, 2022.

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2. That, as per the information available to my client from the newspaper
reports, it has come to his knowledge that the inquiry with regard to
the flogging incident has been order and the Ahmedabad Range IG has
been asked to conduct an inquiry into the same.
3. Apropos the same my client has been constrained to issue the notice
demanding that police itself looking into the atrocities committed by
their very own brethren does not inspire any confidence at all and
hence the inquiry, for it to be unbiased and fair, has to be undertaken
by a Retired Judge of the Hon’ble High Court of Gujarat. My client puts
on record and expresses his serious objections of the futility of asking
the Ahmedabad Range IG to inquiry into the atrocious incident.
4. It is stated and submitted that despite of their substantive evidence
available in public domain about the flogging incident to reveal the
police atrocities no action at all was initiated by your good offices until
the public outrage and hence that in itself stands a testimony to the fact
that all your good offices and entire police force has institutionalized
this authoritarian rule and the colonial legacy of taking law’s into one’s
own hands and the rest of the force including all higher ups standing as
mute spectators and indirectly approving the atrocities.
5. It is stated and submitted that though never spoken about but police
officers covering up crimes of their colleagues is not unknown to our
system. The whole flogging incident of which no cognizance was taken
despite of wide reporting and outcry itself shows that the informal code
of silence among police officers not to report on a colleague’s

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misconduct, crimes and brutality persists deeply within the entire
system.
6. It is thus stated and submitted that owing to the same the inquiry which
would be conducted by the Ahmedabad Range IG would always hover
under the clouds of biasness and the same gives rise to justifiable
doubts as to the independence and impartiality of the one conducting
the inquiry.
7. It is stated and submitted that any right thinking citizen would rightly
apprehend for the entire inquiry to be futile and hence in the interest
of justice and the constitutional ideals, for the inquiry to be impartial,
fair and transparent, it is incumbent that the same be done by a retired
judge of the Hon’ble High Court of Gujarat.
8. In view of the above, it is humbly prayed that the inquiry into the
atrocities by the police officers qua the Kheda Flogging Incident may
kindly be handed over to a Retired Judge of the Hon’ble High Court of
Gujarat so as to instil faith of the citizenry in the inquiry that may be
held, failing which, my client shall be constrained to initiate any and all
suitable legal action/ recourse before appropriate forum/s, as may be
advised, in accordance with law, , of which your goodself may take note
of. All of this will be entirely at your risk, costs and consequences
thereof. It is further stated and submitted that no appropriate action
against the erring officers as yet has been taken which shall be initiated
forthwith pending inquiry, otherwise the same is likely to put all crucial
evidence and witness who are privy to the incident at risk, failing which

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too, my client shall be constrained to initiate any and all suitable legal
action/ recourse before appropriate forum/s, as may be advised, in
accordance with law, of which your goodself may take note of. All of
this too will be entirely at your risk, costs and consequences thereof.
Sincerely,
Advocate Anandvardhan Yagnik