The document is a letter requesting that an FIR be registered regarding the gang rape and human trafficking of the applicant's minor daughter. It provides background details on the daughter being kidnapped as an unborn child in 2005. It states the daughter was seen by the applicant at the Katihar railway station on May 31, 2022 interacting with an unknown man, and is believed to have been trafficked to other places that day. It requests the FIR be filed and immediate medical assistance, arrest, and presentation before a juvenile court.
1. To
Secretary
Ministry of Home Affairs
Government of India
Sub: Direct to register an F.I.R against the cognizable offence
commissioned by child line katihar against applicant’s minor
victim daughter Shriya Poddar age 17 years of gang rapes and
illicit sex trade at source point of human trafficking at Sonaili
Village, P.S. Kadwa, Katihar rescued by the order of Supreme
Court of India in W.P.(Crl.) 137/2021-PIL & W.P.(Crl.) 242/2021 -
reg.
.
Sir/Madam,
1. That petitioner is om Prakash S/O Late Deep Narayan
Poddar, age about 48 years, husband of Gang rape and illicit sex
trade victim Rina Kumari age about 44 years and father of Gang
rape and illicit sex trade victim Shriya Poddar age about 17 years
R/O RZF-893, Netaji Subhash Marg, Raj Nagar Part-2, Palam
Colony, New Delhi-110077 and R/O Asha Deep Niwas, Shukkar
Hat, Sonaili, P.S. Kadwa, Katihar, Bihar-855114
2. That matter pertains to juvenile court and crime branch
because she has been kidnapped while she was inside the womb of
her mother on 15.04.2005
3. That wife Rina has been kidnapped on 15.04.2005 with an
active help of her father Surender Narayan Poddar Assistant
Manager RC, Barauni Refinery, IOCL, Begusarai and taken to
IOCL Quarter Dhanbad from the house of Brajesh Yadav and
Pppu Yadav, driver of Judges R/O Gali No.12, Raj Nagar Part-2,
Palam Colony New Delhi-110077 near to dwarka sector-08
national malaria institute/medical council of India.
4. That wife Rina gave birth to a female baby on 20.05.2005 in
a hospital of Dhanbad at 6:00pm in the absence of father. Father,
grandfather and grandmother are not being allowed to see their
daughter or granddaughter.
5. That father saw her for the first time in the court hearing of
case HMA-700/2010 at Family Court at Dwarka Court at New
Delhi on 09.02.2011 and being allowed to meet his 6 year old
daughter for 3 hour by Principal Judge Family Court, Dwarka
2. Court at New Delhi. The order for the same is passed (enclosed
herewith).
6. That wife Rina filed Valkalatnama in HMA-700/2010 at
Family Court at Dwarka Court at New Delhi on 09.02.2011
through her Rajput caste counsel from Purnea Bihar but not filed
Written Statement till date. However, she has filed two cases in
CJM Court at Begusarai 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 N.B.Ws dated
25.08.2010 and 08.09.2011 u/s 82 and 83Cr.Pc respectively.
7. That the victim minor daughter Shriya Poddar age about 17
years along with some Mohan Kumar R/O Patna just around 1:30
pm on 31.2022 sat beside me for half an hour at waiting room of
Plat Farm No. 01 at Katihar Railway Station. Interacted with me
seen some child hood photographs taken at the court room of
family court dwarka court at New Delhi in HMA-700/2010 case
on 09.02.2011.
8. That victim is being trafficked to other places like Begusarai
or PATNA at around 2:00pm on 31.05.2022
9. Wife Rina Kumari age 44 years also being seen on
31.05.2022 at around 12:00pm in the same waiting room along
with two police men of Bihar.
10. STOP HUMAN TRAFFICKER, MEDICAL, ARREST,
CAHRGESHEET AND PLACE BEFORE JUVENILE COURT
IMMIDIATELY.
11. Direct to Register an F.I.R against the accused under relevant
sections of IPC.
APPLICANT/PETITIONER-IN-PERSON
OM PRAKASH
S/O LATE SHRI DEEP NARAYAN PODDAR
3. S/O LATE SRIMATI ASHA RANI DEVI
ASHA DEEP NIWAS,
SONALI, SHUKKAR HATT,
IN FRONT OF DURGA MANDIR,
KANTIYA PANCHAYAT, P.S. KADWA, KATIHAR,
BIHAR-855114, MOB: 9540389759
KATIHAR
FILED ON :31-05-2022