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12/14/22, 10:24 AM Complaint Copy of HRCnet
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OM PRAKASH,
SON OF DEEP NARAYAN PODDAR, ASHA DEEP NIWAS, SHUKKAR HATT, SONAILI BAZAR, P.S. KADWAALL
OVER INDIA , ALL OVER INDIA
Dated: 14/12/2022
National Human Rights Commission
Manav Adhikar Bhawan Block-C, GPO Complex, INA,, DELHI -110023
Dear OM PRAKASH,
The Commission has recieved your complaint and it has assigned diary number as 20851/IN/2022 with the
following details:-
Complainant Details
Name: OM PRAKASH
Mobile: 9540389759 Email: om.poddar@gmail.com
Address:
SON OF DEEP NARAYAN PODDAR, ASHA DEEP NIWAS, SHUKKAR HATT, SONAILI BAZAR, P.S.
KADWA
District: ALL OVER INDIA State: ALL OVER INDIA
File Uploaded suceesfully ( complaint.pdf )
Victim Details
Complainant and victim are the same person.
Incident Details
Incident
Place:
BEGUSARAI BIHAR AND DELHI Incident Date: 09/02/2011
Incident
Category:
MISCELLENOUS
Incident
District:
ALL OVER INDIA Incident State: ALL OVER INDIA
Is it filed
before any
Court /
State HRC
No
Incident
Details:
To Chairperson National Human Rights Commission New Delhi Sub: Criminal Complaint against Advocates
Gopal Kumar, Sunil K. Ojha, Anil Kumar Bharti, Satya Prakash and Jai Bansal for concealing the material
facts, suppressing the rescue and sustaining the Gang Rapes, illicit sex trade and human trafficking of
kidnapped victim families since 2011-reg. Sir, 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 Anti-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 Petitioner has received a certified
copy of Vakalatnama of respondent wife Rina Kumari (Guddi) in divorce case HMA-678/2010, Goshwara No.
83)H from Family Court, Dwarka Court at New Delhi on 08.12.2022. 3. That thereafter, Inquiry Officer Mr.
Navin Kumar mobile 9990880578, Police Station Palam Village New Delhi has telephoned the Petitioner at
18:35pm dated 08.12.22 to inquire about the case. 4. That in response to inquiry officer Mr. Navin Kumar
mobile 9990880578, Police Station Palam Village New Delhi; Key person’s linkages with this sex racket since
2011 has been shared with him in connection with Kidnapping, Gang Rape and illicit sex trade of Petitioner’s
family and minor daughter. 5. That certified copy dated 08.12.2022 reveals the name of key persons accused in
this sex racket. The name of key person; Mr. Sunil K. Ojha is Advocate for the Petitioner in a divorce case
HMA-678/2010, Goshwara No. 83)H at Family Court, Dwarka Court at New Delhi, Enrolment No. D/879/98,
Chamber No. 610, Lawyers Chamber, Dwarka Court Complex, Sector-10, Dwarka, New Delhi-110075, mobile
no.9891481478 and 9968316567. 6. That another key person; Mr. Anil Kumar Bharti is Advocate for Mrs.
Reena Kumari (Guddi), wife of Petitioner in the same divorce case HMA-678/2010, Goshwara No. 83)H at
Family Court, Dwarka Court at New Delhi, E.N.D-247R/98, Court Chamber behind Court No. 42, Tishazari
Court Delhi, R/O A-43, Sukhvir Nagar, Near Rohini Sector-22, Karala, Delhi-81, R/O Saharsha, Dhamdhah,
Purnea Bihar mobile no. 9312770383/8586850293. 7. That Advocate Anil Kumar Bharti is a political man and
12/14/22, 10:24 AM Complaint Copy of HRCnet
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presently working as president of Rashtriyavaadi Janta Party (RAJPA). He has contested the elections for
Member of Parliament. 8. That Advocate Sunil K. Ojha has served NOTICE to the respondent wife and
presented her along with the parents and minor daughter before Principal Judge Ms. Deepa Sharma on
09.02.2011. He was well versed with the facts and circumstances of respondent wife, yet he did not disclose the
facts with the Petitioner. Hence, he has misled the Petitioner with ulterior motive. Petitioner has noticed
Advocate’s abnormal activity with his minor daughter on 09.02.2011 inside the court’s children room in front of
his respondent wife. Advocate did not let the minor daughter to come close to Petitioner on 09.02.2011. He
grabbed her into his lap in an obscene manner. Thereafter he did not appear on the next date of hearing dated
30.05.2011 fixed for filing WS by opposite party and for replication and issues. In response to this abnormal
activity, Petitioner has removed him from this case and contested the case through Legal Aid Advocate Satya
Prakash. 9. That even after knowing all facts about the case and about the victims, Advocate Sunil K. Ojha has
misled the Petitioner by filing and sustaining divorce suit/case instead of filing and injecting into criminal case
u/s 200 Cr.Pc. and u/s 156(3) Cr.Pc. deliberately to sustain the sex racket and suppress the rescue of Gang Rape
victims. 10. That the counsel of respondent victim wife, Advocate Anil Kumar Bharti has also misled her by
filing only Vakalatnama on 09.02.2011 on behalf of respondent wife in divorce case HMA-678/2010 ,
Goshwara No. 83)H at Family Court, Dwarka Court at New Delhi and deliberately escaped from filing Written
Statement to sustain the sex racket and suppress the rescue of the client victims. Moreover, counsel of
respondent victim wife, Advocate Anil Kumar Bharti has recorded her signature in English on Vakalatnama
dated 09.02.2011 while she does not know English. Hence, fake Vakalatnama has been presented before the
court of Principal Judge, Family Court Ms. Deepa Sharma on 09.02.2011. Vakalatnama is signed by someone
else on behalf of victim respondent wife to sustain sex racket and suppress the rescue of victims. 11. That
another key person; Legal Aid Advocate Mr. Satya Prakash who concealed the material fact of sex racket and
sustained the divorce case to suppress the rescue of Gang Rape victims. 12. That the divorce case was Ex-Parte,
yet petitioner being aggrieved by the judgment of Family Court Dwarka Court at New Delhi had to challenge it
before High Court of Delhi in MAT.APPL. 7/2012. 13. That another key person; Advocate Mr. Jai Bansal of
Delhi High Court Legal Service Committee who has withdrawn his legal aid services in absence of petitioner
on 06.11.2012 before Hon’ble Justice Sanjay Kishan Kaul in MAT.APPL. 7/2012 to suppress the matter and
sustain the illicit sex trade of victims. Thereafter petitioner has contested this case on his own as Petitioner-In-
Person. 14. That matter remained Ex-Parte at High Court of Delhi in MAT.APPL. 7/2012, yet Petitioner had to
file three SLPs against High Court of Delhi before Supreme Court of India in 2012-13 before the bench of
Hon’ble Justice G.S Singhvi. 15. That after three SLPs at Supreme Court of India; High Court of Delhi has
passed Ex-Parte judgment in MAT.APPL. 7/2012 on 23.07.2013 in favor of Petitioner and against the
respondent wife with NO COST. 16. That on the one hand victim respondent wife Rina Kumari has filed fake
Valkalatnama in HMA-700/2010 renumbered as HMA-678/2010 at Family Court at Dwarka Court at New
Delhi on 09.02.2011 through her counsel Advocate Anil Kumar Bharti and escaped from filing Written
Statement till date. On the other hand she has filed two cases in CJM Court at Begusarai Bihar through her
Counsel Advocate, Shri Gopal Kumar Registration No. 836/91, Advocate code 232, Civil Court, Begausarai,
Bihar and expressed her willingness to stay along with her husband and demanded lump sum handsome amount
as compensations and monthly amount as maintenance. One 9P/2010 under domestic violence Act 2005 and
another Criminal Case Complaint (P) No. 397C/ 2011/ 5591/2013 under section 498A, section 323 of IPC and
u/s 3/4 of D.P Act in 2010 and 2011 along with two Non Bailable Warrants dated 25.08.2010 and 08.09.2011
u/s 82 and 83Cr.Pc respectively. 17. That ironically, respondent wife Rina Kumari has recorded her signature in
Hindi at Valkalatnama filed through her Counsel Advocate, Shri Gopal Kumar in 9P/2010 and Criminal Case
Complaint (P) No. 397C/ 2011/ 5591/2013 case before CJM Court Begusarai Bihar under the judicature of
Patna High Court. 18. That another key person in this sex racket is Mr. Gopal Kumar Advocate Civil Court
Begusarai Bihar under the judicature of Patna High Court. He and his wife Veena Kumari (Women Protection
Officer) are the counsel of victim respondent wife Reena Kumari (Guddi), who misled the victim respondent
wife and court both by concealing the material facts to sustain sex racket and to suppress rescue of the Gang
Rape victims. 19. That the motive of Sex Abuser State is to sustain sex racket and to suppress rescue of Gang
Rape victims by changing the legal status and changing the jurisdictions of the victims and usurping the
property of Petitioner by killing his whole families. Respondent wife Rina Kumari (Guddi) and her minor
daughter have been forcefully pushed into illicit sex trade, hidden prostitution, child sexual abuse, human
trafficking and International sex racket by converting her religion, by changing her husband, by changing her
father, by making her heroine, and item girl, by training her into professional singer and dancer, by doing her
plastic surgery by the sex abuser State to generate revenue out of illicit sex trade. PRAYER It is most
respectfully prayed that this Commission may be pleased to: (a) TAKE the cognizance of criminal offence
committed by Advocates below the court in this matter by concealing the material facts and misleading the
court and client both to sustain the International Sex Racket and to suppress the rescue of Victims with their
own vested interest. (b) Direct to concern SHOs to register an F.I.R against the accused Advocates under
relevant sections of IPC. (c) Pass such other order/orders as this Commission may deem just and proper in the
facts and circumstances of the case. PETITIONER-IN-PERSON PROFESSIONAL SOCIAL WORKER
12/14/22, 10:24 AM Complaint Copy of HRCnet
about:blank 3/3
(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
DURGAANDIR, KANTIYA PANCHAYAT, P.S. KADWA, KATIHAR, BIHAR-855114, MOB: 9540389759
E-mail: om.poddar@gmail.com PRESENT ADDRESS: NIGHT SHELTER HOME, DUSIB CODE: 214 NEAR
ANAND VIHAR ISBT, DELHI NEW DELHI: FILED ON : 14-12-2022

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Complaint dated 14.12.22 against Advocates to NHRC.pdf

  • 1. 12/14/22, 10:24 AM Complaint Copy of HRCnet about:blank 1/3 OM PRAKASH, SON OF DEEP NARAYAN PODDAR, ASHA DEEP NIWAS, SHUKKAR HATT, SONAILI BAZAR, P.S. KADWAALL OVER INDIA , ALL OVER INDIA Dated: 14/12/2022 National Human Rights Commission Manav Adhikar Bhawan Block-C, GPO Complex, INA,, DELHI -110023 Dear OM PRAKASH, The Commission has recieved your complaint and it has assigned diary number as 20851/IN/2022 with the following details:- Complainant Details Name: OM PRAKASH Mobile: 9540389759 Email: om.poddar@gmail.com Address: SON OF DEEP NARAYAN PODDAR, ASHA DEEP NIWAS, SHUKKAR HATT, SONAILI BAZAR, P.S. KADWA District: ALL OVER INDIA State: ALL OVER INDIA File Uploaded suceesfully ( complaint.pdf ) Victim Details Complainant and victim are the same person. Incident Details Incident Place: BEGUSARAI BIHAR AND DELHI Incident Date: 09/02/2011 Incident Category: MISCELLENOUS Incident District: ALL OVER INDIA Incident State: ALL OVER INDIA Is it filed before any Court / State HRC No Incident Details: To Chairperson National Human Rights Commission New Delhi Sub: Criminal Complaint against Advocates Gopal Kumar, Sunil K. Ojha, Anil Kumar Bharti, Satya Prakash and Jai Bansal for concealing the material facts, suppressing the rescue and sustaining the Gang Rapes, illicit sex trade and human trafficking of kidnapped victim families since 2011-reg. Sir, 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 Anti-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 Petitioner has received a certified copy of Vakalatnama of respondent wife Rina Kumari (Guddi) in divorce case HMA-678/2010, Goshwara No. 83)H from Family Court, Dwarka Court at New Delhi on 08.12.2022. 3. That thereafter, Inquiry Officer Mr. Navin Kumar mobile 9990880578, Police Station Palam Village New Delhi has telephoned the Petitioner at 18:35pm dated 08.12.22 to inquire about the case. 4. That in response to inquiry officer Mr. Navin Kumar mobile 9990880578, Police Station Palam Village New Delhi; Key person’s linkages with this sex racket since 2011 has been shared with him in connection with Kidnapping, Gang Rape and illicit sex trade of Petitioner’s family and minor daughter. 5. That certified copy dated 08.12.2022 reveals the name of key persons accused in this sex racket. The name of key person; Mr. Sunil K. Ojha is Advocate for the Petitioner in a divorce case HMA-678/2010, Goshwara No. 83)H at Family Court, Dwarka Court at New Delhi, Enrolment No. D/879/98, Chamber No. 610, Lawyers Chamber, Dwarka Court Complex, Sector-10, Dwarka, New Delhi-110075, mobile no.9891481478 and 9968316567. 6. That another key person; Mr. Anil Kumar Bharti is Advocate for Mrs. Reena Kumari (Guddi), wife of Petitioner in the same divorce case HMA-678/2010, Goshwara No. 83)H at Family Court, Dwarka Court at New Delhi, E.N.D-247R/98, Court Chamber behind Court No. 42, Tishazari Court Delhi, R/O A-43, Sukhvir Nagar, Near Rohini Sector-22, Karala, Delhi-81, R/O Saharsha, Dhamdhah, Purnea Bihar mobile no. 9312770383/8586850293. 7. That Advocate Anil Kumar Bharti is a political man and
  • 2. 12/14/22, 10:24 AM Complaint Copy of HRCnet about:blank 2/3 presently working as president of Rashtriyavaadi Janta Party (RAJPA). He has contested the elections for Member of Parliament. 8. That Advocate Sunil K. Ojha has served NOTICE to the respondent wife and presented her along with the parents and minor daughter before Principal Judge Ms. Deepa Sharma on 09.02.2011. He was well versed with the facts and circumstances of respondent wife, yet he did not disclose the facts with the Petitioner. Hence, he has misled the Petitioner with ulterior motive. Petitioner has noticed Advocate’s abnormal activity with his minor daughter on 09.02.2011 inside the court’s children room in front of his respondent wife. Advocate did not let the minor daughter to come close to Petitioner on 09.02.2011. He grabbed her into his lap in an obscene manner. Thereafter he did not appear on the next date of hearing dated 30.05.2011 fixed for filing WS by opposite party and for replication and issues. In response to this abnormal activity, Petitioner has removed him from this case and contested the case through Legal Aid Advocate Satya Prakash. 9. That even after knowing all facts about the case and about the victims, Advocate Sunil K. Ojha has misled the Petitioner by filing and sustaining divorce suit/case instead of filing and injecting into criminal case u/s 200 Cr.Pc. and u/s 156(3) Cr.Pc. deliberately to sustain the sex racket and suppress the rescue of Gang Rape victims. 10. That the counsel of respondent victim wife, Advocate Anil Kumar Bharti has also misled her by filing only Vakalatnama on 09.02.2011 on behalf of respondent wife in divorce case HMA-678/2010 , Goshwara No. 83)H at Family Court, Dwarka Court at New Delhi and deliberately escaped from filing Written Statement to sustain the sex racket and suppress the rescue of the client victims. Moreover, counsel of respondent victim wife, Advocate Anil Kumar Bharti has recorded her signature in English on Vakalatnama dated 09.02.2011 while she does not know English. Hence, fake Vakalatnama has been presented before the court of Principal Judge, Family Court Ms. Deepa Sharma on 09.02.2011. Vakalatnama is signed by someone else on behalf of victim respondent wife to sustain sex racket and suppress the rescue of victims. 11. That another key person; Legal Aid Advocate Mr. Satya Prakash who concealed the material fact of sex racket and sustained the divorce case to suppress the rescue of Gang Rape victims. 12. That the divorce case was Ex-Parte, yet petitioner being aggrieved by the judgment of Family Court Dwarka Court at New Delhi had to challenge it before High Court of Delhi in MAT.APPL. 7/2012. 13. That another key person; Advocate Mr. Jai Bansal of Delhi High Court Legal Service Committee who has withdrawn his legal aid services in absence of petitioner on 06.11.2012 before Hon’ble Justice Sanjay Kishan Kaul in MAT.APPL. 7/2012 to suppress the matter and sustain the illicit sex trade of victims. Thereafter petitioner has contested this case on his own as Petitioner-In- Person. 14. That matter remained Ex-Parte at High Court of Delhi in MAT.APPL. 7/2012, yet Petitioner had to file three SLPs against High Court of Delhi before Supreme Court of India in 2012-13 before the bench of Hon’ble Justice G.S Singhvi. 15. That after three SLPs at Supreme Court of India; High Court of Delhi has passed Ex-Parte judgment in MAT.APPL. 7/2012 on 23.07.2013 in favor of Petitioner and against the respondent wife with NO COST. 16. That on the one hand victim respondent wife Rina Kumari has filed fake Valkalatnama in HMA-700/2010 renumbered as HMA-678/2010 at Family Court at Dwarka Court at New Delhi on 09.02.2011 through her counsel Advocate Anil Kumar Bharti and escaped from filing Written Statement till date. On the other hand she has filed two cases in CJM Court at Begusarai Bihar through her Counsel Advocate, Shri Gopal Kumar Registration No. 836/91, Advocate code 232, Civil Court, Begausarai, Bihar and expressed her willingness to stay along with her husband and demanded lump sum handsome amount as compensations and monthly amount as maintenance. One 9P/2010 under domestic violence Act 2005 and another Criminal Case Complaint (P) No. 397C/ 2011/ 5591/2013 under section 498A, section 323 of IPC and u/s 3/4 of D.P Act in 2010 and 2011 along with two Non Bailable Warrants dated 25.08.2010 and 08.09.2011 u/s 82 and 83Cr.Pc respectively. 17. That ironically, respondent wife Rina Kumari has recorded her signature in Hindi at Valkalatnama filed through her Counsel Advocate, Shri Gopal Kumar in 9P/2010 and Criminal Case Complaint (P) No. 397C/ 2011/ 5591/2013 case before CJM Court Begusarai Bihar under the judicature of Patna High Court. 18. That another key person in this sex racket is Mr. Gopal Kumar Advocate Civil Court Begusarai Bihar under the judicature of Patna High Court. He and his wife Veena Kumari (Women Protection Officer) are the counsel of victim respondent wife Reena Kumari (Guddi), who misled the victim respondent wife and court both by concealing the material facts to sustain sex racket and to suppress rescue of the Gang Rape victims. 19. That the motive of Sex Abuser State is to sustain sex racket and to suppress rescue of Gang Rape victims by changing the legal status and changing the jurisdictions of the victims and usurping the property of Petitioner by killing his whole families. Respondent wife Rina Kumari (Guddi) and her minor daughter have been forcefully pushed into illicit sex trade, hidden prostitution, child sexual abuse, human trafficking and International sex racket by converting her religion, by changing her husband, by changing her father, by making her heroine, and item girl, by training her into professional singer and dancer, by doing her plastic surgery by the sex abuser State to generate revenue out of illicit sex trade. PRAYER It is most respectfully prayed that this Commission may be pleased to: (a) TAKE the cognizance of criminal offence committed by Advocates below the court in this matter by concealing the material facts and misleading the court and client both to sustain the International Sex Racket and to suppress the rescue of Victims with their own vested interest. (b) Direct to concern SHOs to register an F.I.R against the accused Advocates under relevant sections of IPC. (c) Pass such other order/orders as this Commission may deem just and proper in the facts and circumstances of the case. PETITIONER-IN-PERSON PROFESSIONAL SOCIAL WORKER
  • 3. 12/14/22, 10:24 AM Complaint Copy of HRCnet about:blank 3/3 (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 DURGAANDIR, KANTIYA PANCHAYAT, P.S. KADWA, KATIHAR, BIHAR-855114, MOB: 9540389759 E-mail: om.poddar@gmail.com PRESENT ADDRESS: NIGHT SHELTER HOME, DUSIB CODE: 214 NEAR ANAND VIHAR ISBT, DELHI NEW DELHI: FILED ON : 14-12-2022