Parties in this Criminal Matter are CORRUPT, CRIMINAL, CROOK JUDGES, ADVOCATES POLICE and BANK OFFICIALS in M.A NO. 583 of 2020 in W.P.(Criminal) 136 of 2016 wherein rights under Article 21 of Constitution of India has been suspended through N.B.W u/s 83 Cr.Pc. causing jurisdictional error deliberately and secretly since 2011 by the State of Bihar and others and wherein Order dated 21.10.2016 in W.P.(Criminal) 136 of 2016 of Supreme Court of India has stood in breach of Article 21 of Constitution of India as a result of that the petitioner no.02 has succumbed to suspicious death on 11.11.2017 and petitioner no.01 is likely to succumb to suspicious death soon because the nexus of state and mafia has organized mob lynching and illegal detention of petitioner and has been compelled to remain underground by these corrupt, criminal, crook and goon’s organs of the state.

1. IN THE SUPREME COURT OF INDIA
ORIGINAL JURISDICTION
CRL.M.P.NO…………….OF 2020
IN
M.A. NO.583 OF 2020
IN
WRIT PETITION CRIMINAL NO. 136 OF 2016
IN THE MATTER OF:
OM PRAKASH & ANR …………..PETITIONER(S)
VERSUS
STATE OF BIHAR & ORS ….RESPONDENT(S)
I.A. NO. OF 2020
APPLICATION FOR WRITTEN ARGUMENTS
PAPER BOOK
(FOR INDEX KINDLY SEE INSIDE)
PETITIONER IN PERSON
OM PRAKASH
ON BEHALF OF PETITIONER NO.02
LATE SMT. ASHA RANI DEVI

2. INDEX
S.N Particulars Page No.
1. Application for Written 1-16
Arguments in M.A.No.583/2020
in W.P.(Crl.)No.136 of 2016
along with Affidavit
2. Annexure: P-1 17
True copy of Order dated 23.04.2012
in SLP(C) No.9854/2012 passed by
Supreme Court of India
3.Annexure:P-2 18-20
True copy of Order dated 01.04.2013
in SLP(C) No.9483/2013 passed by
Supreme Court of India
4. Annexure: P-3 21
True copy of Order dated 05.07.2013
in SLP(C) No. 19073/2013 passed
by Supreme Court of India
5. Annexure: P-4 22
True copy of Order dated 18.04.2016
in Writ (C) 90 of 2016 passed by
Supreme Court of India
6. Annexure: P-5 23-24

3. True copy of false Police inquiry
report dated 07.05.2016 by S.P.
Katihar to In-charge, Janta Darbar,
Police HQ, DGP Bihar against
turning the petitioners’ house
into public toilet
7. Annexure: P-6 25-27
True copy of material evidence as
photographs of public toilet dated
05.03.2016 against the false police
inquiry report dated 07.05.2016 by
the petitioner to the Chief
Minister Secretariat Bihar through
99999-0303160113 dated 17.05.2016
8. Annexure: P-7 28
True copy of Order dated 21.10.2016
in Writ Petition (Criminal) 136 of
2016 passed by Supreme Court of
India
9. Annexure: P-8 29-31
True copy of Order dated 01.12.2016
in Review Petition (Criminal) 825
of 2016 passed by Supreme Court of
India
10. Annexure: P-9 32-34

4. True copy of Order dated 28.01.2017
in Writ Petition (Criminal)
D.NO.2188 of 2017 passed by
Supreme Court of India
11. Annexure: P-10 35-37
True copy of Order dated 16.02.2017
in Writ Petition (Criminal)
D.NO.3913 of 2017 passed by
Supreme Court of India
12. Annexure: P-11 38
True copy of Order dated 14.07.2017
in M.A. 84 of 2017 passed by
Supreme Court of India
13. Annexure: P-12 39-41
True copy of Order dated 17.07.2017
in Curative Petition (Criminal)
D.NO.41026 of 2016 passed by
Supreme Court of India
14. Annexure: P-13 42
True copy of false Police inquiry
report dated 16.05.2018 by S.P.
Katihar to Chief Minister
Secretariat Bihar against turning
the petitioners’ house into
public toilet

5. 15. Annexure: P-14 43
True copy of Dissatisfaction
against the false police inquiry
report dated 16.05.2018 by the
petitioner to the Chief Minister
Secretariat Bihar through 99999-
1705160125 dated 26.06.2018
16. Annexure: P-15 44-47
True copy of Order dated 23.08.2018
in M.A. D.NO. 22539 of 2018 passed
by Supreme Court of India
17. Annexure: P-16 48
True copy of Order dated 07.12.2018
in M.A. 2836 of 2018 passed by
Supreme Court of India
18. Annexure: P-17 49-50
True copy of Police inquiry report
dated 31.05.2019 by S.P. Katihar to
DGP Bihar against the execution of
N.B.W order dated 08.09.2011 u/s 83
Cr.Pc. against the petitioners
19. Annexure: P-18 51-52
True copy of Police inquiry report
dated 01.06.2019 by S.P. Begusarai

6. to Prime Minister Office against
the execution of N.B.W order dated
08.09.2011 u/s 83 Cr.Pc. against
the petitioners.
20. Annexure: P-19 53-54
True copy of Certified copy of
court order dated 01.06.2019 in
Criminal case Complaint (P) No.
5591 of 2013 by Begusarai court to
S.P. Begusarai against the
execution of N.B.W order dated
08.09.2011 u/s 83 Cr.Pc. against
the petitioners.
21. Annexure: P-20 55-58
True copy of reply dated 17-06-2019
by Shri Sandeep Tiwari Chief
General Manager, Local Head Office,
SBI, Patna through
DEAPR/E/2019/00559 on CPGRAMS
portal
22. Annexure: P-21 59
True copy of Court entry pass
issued for mentioning officer dated
17.03.2020 in M.A.No.583/2020 by
Supreme Court of India

7. IN THE SUPREME COURT OF INDIA
ORIGINAL JURISDICTION
CRL.M.P.NO………………………….OF 2020
IN
M.A.NO.583 OF 2020
IN
WRIT PETITON CRIMINAL NO. 136 OF 2016
AND
IN THE MATTER OF ARTICLE 32
OF THE CONSTITUTION OF INDIA;
AND
IN THE MATTER OF THE
SUSPICIOUS DEATH OF SMT. ASHA
RANI DEVI PETITIONER NO.02;
AND
IN THE MATTER OF:
OM PRAKASH & ANR …………..PETITIONER
VERSUS
STATE OF BIHAR & ORS ….RESPONDENT
NDOH: 08-06-2020
APPLICATION FOR WRITTEN ARGUMENTS
To
Hon'ble the Chief Justice of India of
the Supreme Court of India. The
Humble petition of the Petitioner
abovenamed.
MOST RESPECFULLY SHOWETH:
1. That all legal remedies have been

8. exhausted yet there is no relief in this
criminal matter because the parties are
CORRUPT, CRIMINAL, CROOK JUDGES, ADVOCATES
POLICE and BANK OFFICIALS in M.A NO. 583 of
2020 in W.P.(Criminal) 136 of 2016 wherein
rights under Article 21 of Constitution of
India has been suspended through N.B.W u/s 83
Cr.Pc. causing jurisdictional error
deliberately and secretly since 2011 by the
State of Bihar and others and wherein Order
dated 21.10.2016 in W.P.(Criminal) 136 of
2016 of Supreme Court of India has stood in
breach of Article 21 of Constitution of India
as a result of that the petitioner no.02 has
succumbed to suspicious death on 11.11.2017
and petitioner no.01 is likely to succumb to
suspicious death soon because the nexus of
state and mafia has organized mob lynching
and illegal detention of petitioner and has
been compelled to remain underground by these
corrupt, criminal, crook and goon’s organs of
the state.
2. That due to COVID-19, Supreme court hearing
dated 16.03.2020 in M.A. 583/2020 in
W.P.(Crl.) 136/2016 has been cancelled till
further NOTICE as a result of that petitioner

9. has been stranded in the lock down at the
night shelter of Delhi with the help of Delhi
Police helpline no. 100/112 and through 112
call registration no.1364532 dated 03-05-2020.
Petitioner has also registered himself for
inter State movement of stranded migrants in
distress with Delhi disaster management
Authority vide registration no. 2005102 dated
05.05.2020.
3. That there is a well-designed plan of these
corrupt, criminal, crook and goon’s organs of
the state to finish off the whole family of
petitioner no.01 to usurp all his property as
he happens to be the only survivor in this 16
years old of bloodshed.
4. That after the settlement of the same
matter by High Court of Delhi in 2013
jurisdictional error has been caused by
the state of Bihar and others
deliberately with an ulterior motive to
usurp petitioners’ property and has
maintained two N.B.Ws. N.B.W dated
25.08.2010 under D.V. Act and N.B.W dated
08.09.2011 u/s 83 Cr.Pc under 498A/323
IPC and ¾ of D.P. Act against the

10. petitioner no.01 and petitioner no.02
secretly.
5. That instead of quashing of false and
fabricated case, Patna High Court has
raised Constitutional issues to add
Article 227 for registration and
admission of Criminal Writ Jurisdiction
Case Token No.45078 of 2019 (CRWJC
NO.1238 of 2019) while Writ of Certiorari
is Original jurisdiction of High Court under
Article 226.
6. That instead of quashing of false and
fabricated case the nexus of State and
Mafia has turned the petitioners’ house
into public toilet in 2016, organized mob
lynching and illegal detention of
petitioners’ in 2019, forced the
petitioner to sign the white plain paper
at police station Kadwa, declared the
petitioner as mentally ill by the police
inquiry report dated 20.09.2019 without
any medical certificate by the
psychiatrist and continuing mental
torture of petitioner by the police; yet
no F.I.R by Bihar Police.

11. 7. That M.A.583 of 2020 in Writ Petition
(Criminal) 136 of 2016 has been filed after
the disposal of SLP (Civil) 9854 of 2012,
SLP (Civil) 9483 of 2013, SLP (Civil) 19073
of 2013, Writ Petition (Civil) 90 of 2016,
Writ Petition (Criminal) 136 of 2016, Review
Petition (Criminal) 825 of 2016, Writ
Petition (Criminal) D.NO.2188 of 2017, Writ
Petition (Criminal) D.NO.3913 of 2017, M.A.
84 of 2017, Curative Petition (Criminal)
D.NO.41026 of 2016, M.A. D.NO. 22539 of 2018
and M.A. 2836 of 2018.
True copy of Order dated 23.04.2012 in
SLP(C)No.9854/2012 passed by this
Hon’ble Court is annexed herein as
Annexure P-1 (Page from 17 to 17)
True copy of Order dated 01.04.2013 in
SLP(C)No.9483/2013 passed by this
Hon’ble Court is annexed herein as
Annexure P-2 (Page from 18 to 20)
True copy of Order dated 05.07.2013 in
SLP(C)No. 19073/2013 passed by this
Hon’ble Court is annexed herein as
Annexure P-3 (Page from 21 to 21)

12. True copy of Order dated 18.04.2016 in
Writ (C) 90 of 2016 passed by this
Hon’ble Court is annexed herein as
Annexure P-4 (Page from 22 to 22)
True copy of False Police inquiry
report dated 07.05.2016 by S.P.
Katihar to In charge, Janta Darbar,
Police HQ, DGP Bihar against turning
the petitioners’ house into public
toilet is annexed herein as Annexure
P-5 (Page from 23 to 24)
True copy of material evidence as
photographs of public toilet dated
05.03.2016 against the false police
inquiry report dated 07.05.2016 by the
petitioner to the Chief Minister
Secretariat Bihar 99999-0303160113
dated 17.05.2016 is annexed herein as
Annexure P-6 (Page from 25 to 27)
True copy of Order dated 21.10.2016 in
Writ Petition (Criminal) 136 of 2016
passed by this Hon’ble Court is

13. annexed herein as Annexure P-7 (Page
from 28 to 28)
True copy of Order dated 01.12.2016 in
Review Petition (Criminal) 825 of
2016 passed by this Hon’ble Court is
annexed herein as Annexure P-8 (Page
from 29 to 31)
True copy of Order dated 28.01.2017 in
Writ Petition (Criminal) D.NO.2188 of
2017 passed by this Hon’ble Court is
annexed herein as Annexure P-9 (Page
from 32 to 34)
True copy of Order dated 16.02.2017 in
Writ Petition (Criminal) D.NO.3913 of
2017 passed by this Hon’ble Court is
annexed herein as Annexure P-10 (Page
from 35 to 37)
True copy of Order dated 14.07.2017 in
M.A. 84 of 2017 passed by this
Hon’ble Court is annexed herein as
Annexure P-11 (Page from 38 to 38)

14. True copy of Order dated 17.07.2017 in
Curative Petition (Criminal)
D.NO.41026 of 2016 passed by this
Hon’ble Court is annexed herein as
Annexure P-12 (Page from 39 to 41)
True copy of false Police inquiry
report dated 16.05.2018 by S.P.
Katihar to Chief Minister Secretariat
Bihar against turning the
petitioners’ house into public
toilet is annexed herein as Annexure
P-13 (Page from 42 to 42)
True copy of Dissatisfaction against
the false police inquiry report dated
16.05.2018 by the petitioner to the
Chief Minister Secretariat Bihar
99999-1705160125 dated 26.06.2018 is
annexed herein as Annexure P-14 (Page
from 43 to 43)
True copy of Order dated 23.08.2018 in
M.A. D.NO. 22539 of 2018 passed by

15. this Hon’ble Court is annexed herein
as Annexure P-15 (Page from 44 to 47)
True copy of Order dated 07.12.2018 in
M.A. 2836 of 2018 passed by this
Hon’ble Court is annexed herein as
Annexure P-16 (Page from 48 to 48)
8. That in response to the police complaint
made by the petitioner for execution of
N.B.W order dated 08.09.2011 u/s 83
Cr.Pc. pending against him, S.P. Katihar
has replied back to the DGP Bihar vide
letter no.1951 dated 31.05.2019 that no
N.B.W is pending against the petitioner.
True copy of Police inquiry report
dated 31.05.2019 by S.P. Katihar to
DGP Bihar against the execution of
N.B.W order dated 08.09.2011 u/s 83
Cr.Pc. is annexed herein as Annexure
P-17 (Page from 49 to 50)
9. That in response to the police complaint
made by the petitioner for execution of
N.B.W order dated 08.09.2011 u/s 83 Cr.Pc.

16. pending against him, S.P. Begusarai has
replied back along with the certified
copy of Begusarai Court order dated
01.06.2019 in Criminal case Complaint (P)
No. 5591 of 2013 to the Prime Minister
Office through complaint registration no.
PMOPG/E/2019/0212709 dated 01.06.2019
that execution of N.B.W order not
received back against the petitioner.
True copy of Police inquiry report
dated 01.06.2019 by S.P. Begusarai to
Prime Minister Office against the
execution of N.B.W order dated
08.09.2011 u/s 83 Cr.Pc. is annexed
herein as Annexure P-18 (Page from 51
to 52)
True copy of certified copy of court
order dated 01.06.2019 in Criminal
case Complaint (P) No. 5591 of
2013 by Begusarai court to S.P.
Begusarai against the execution of
N.B.W order dated 08.09.2011 u/s 83
Cr.Pc. is annexed herein as Annexure
P-19 (Page from 53 to 54)

17. 10. That in response to the consistent bank
harassment in the garb of KYC updation by
the corrupt, criminal and crook bank
officials of SBI, which has resulted in
suspicious death of petitioner no.02;
Shri Sandeep Tiwari Chief General Manager,
Local Head Office, State Bank of India, Patna
has replied back the complaint under
financial services pension reforms vide
DEAPR/E/2019/00559 dated 01-06-2019 and
uploaded the copy of reply dated 17-06-2019
on CPGRAMS. It is pertinent to mention here
that the criminal activities by SBI, Bihar
bank officials are still continued against
the petitioner no.01 during the lock down and
COVID-19 outbreak even after the reply dated
17-06-2019 by CGM, SBI, LHO, Patna and
service of NOTICE dated 19.06.2019 to Shri
Rakesh Kumar Singh, AOR 03278, Advocate
General, SBI in Criminal Writ Jurisdiction
Case No.1238/2019 (Token No.45078/2019) at
Patna High Court. ADB Sonaili Bazar, SBI
Bihar branch has carried out another criminal
activity through unauthorized access into the
Delhi bank account of petitioner no.01 and
locked down his account in the garb of KYC
updation while he is not a customer of SBI

18. Bihar amid Lock down and COVID-19 outbreak.
True copy of reply dated 17-06-2019 by
Chief General Manager, LHO, SBI, Patna
through DEAPR/E/2019/00559 on CPGRAMS
portal is annexed herein as Annexure
P-20 (Page from 55 to 58)
11. That the Mentioning officer of Supreme
Court of India has refused to allow the
petitioner to mention the matter related
to extreme urgency pertaining to imminent
danger to “Life and liberty” before
Hon’ble the Chief Justice of India’s
court on 17.03.2020. However, petitioner
has submitted a letter of urgency along
with affidavit vide entry pass-
v5e7068452e82b dated 17.03.2020 before
the mentioning officer but the same has
been turned down by the mentioning
officer as a result of that petitioner
has stuck in the night shelter of Delhi
due to nationwide lockdown to combat
COVID-19. Petitioner has again submitted
synopsis of extreme urgency through email
mention.sc@sci.nic.in during the lockdown
period on 28.03.2020 but this also has

19. been turned down by the mentioning
officer. It is pertinent to mention here
that the similar activity was conducted
in the same matter W.P.(Criminal)No.136
of 2016 by the then mentioning officer of
Supreme Court of India in 2016 as a
result of that petitioner no.02 has
succumbed to suspicious death on
11.11.2017.
True copy of Court entry pass issued
for mentioning officer dated
17.03.2020 in M.A.No.583/2020 by
this Hon’ble Court is annexed herein
as Annexure P-21 (Page from 59 to 59)
12. In view of the above circumstances,
petitioner no.01 cannot resume his normal
life, get a new job, earn his livelihood, and
settle down his new married life.
-:PRAYER:-
In the above premises, it is prayed that
Hon’ble the Chief Justice of India may be
pleased:

20. (i) To consider all para from 01 to 12 in this
application for written arguments in M.A. No.
583 of 2020 in W.P. (Criminal) 136 of 2016 for
direction of listing this matter before the
Constitution bench of Hon’ble Supreme Court of
India in Hon’ble the Chief Justice Court.
(ii) To direct the DGP Bihar to register F.I.R
against turning the petitioners’ house into
public toilet, organizing mob lynching and
illegal detention of petitioner by the nexus
of State and Mafia.
(iii) Pass such other order/orders as this Hon'ble
Court may deem just and proper in the facts and
circumstances of the case.
DRAWN & FILED BY:
PETITIONER-IN-PERSON
OM PRAKASH
S/O LATE SHRI DEEP NARAYAN PODDAR
S/O LATE SRMT. ASHA RANI DEVI
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 : 05-06-2020
Diary No.: 52123/2020