Review Petition Criminal Diary No. 7153 of 2023.pdf

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IN THE SUPREME COURT OF INDIA
ORIGINAL APPELLATE CRIMINAL JURISDICTION
REVIEW PETITION (CRIMINAL) NO. 7153 OF 2023
IN
WRIT PETITION (CRIMINAL) NO. 42 OF 2023
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
ORIGINAL CRIMINAL APPELLATE JURISDICTION
REVIEW PETITION CRIMINAL NO. 7153 OF 2023
IN
WRIT PETITION CRIMINAL NO. 42 OF 2023
(UNDER ARTICLE 32 OF THE CONSTITUTION OF INDIA)
AND
IN THE MATTER OF KIDNAPPING, ABDUCTION.
NON BAILABLE WARRANT, GANG RAPE,
LLICIT SEX TRADE, CHILD SEXUAL ABUSE,
HUMAN TRAFFICKING, INTERNATIONAL SEX
RACKET, MOB VIOLENCE, SUSPICIOUS DEATH
AND ABUSE OF POWER BY STATES, NGOS,
GANGSTERS AND INDIAN DEFENSE
ORGANIZATIONS
AND
IN THE MATTER OF:
VERSUS
UNION OF INDIA & ORS ….RESPONDENT(S)
S.N Particulars Copies Pages
1. Office Report on Limitation 1
2. Memo of Appearance 1
3. ID Proof duly signed 1
4. Order dated 06.02.2023 under Challenge 1+3
5. Synopsis and list of dates 1+3
6. Review Petition Criminal Under Article 137
of the Constitution of India along with
Affidavit
1+3
7. Annexure P-1 1+3
DRAWN & FILED BY:
PETITIONER-IN-PERSON
OM PRAKASH
S/O LATE SHRI DEEP NARAYAN PODDAR
S/O LATE SRIMATI ASHA RANI DEVI
TEMPORARY RESIDENT: C/O RAM KUMAR
H.N. 128/5, C BLOCK, STREET NO.07,
SHASTRI PARK, P.S. SHASTRI PARK
NORTH EAST DISTRICT DELHI-110053
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 : 17-02-2023
Diary No.:

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REVIEW PETITION CRIMINAL NO.7153 OF 2023
IN
AND
IN THE MATTER OF KIDNAPPING,
ABDUCTION. NON BAILABLE WARRANT,
GANG RAPE, LLICIT SEX TRADE, CHILD
SEXUAL ABUSE, HUMAN TRAFFICKING,
INTERNATIONAL SEX RACKET MOB
VIOLENCE, SUSPICIOUS DEATH AND
ABUSE OF POWER BY STATES, NGOS,
ORGANIZATIONS
AND
VERSUS
OFFICE REPORT ON LIMITATION
1. The petition is/are within time.
2. The petition is barred by time and there is a delay of
……days in filing special leave petition and petition
for condonation of …….days delay has been filed.
3. There is delay of …….days in re-filing the petition
and petition for condonation of ……days delay in re-
filing has been filed.
BRANCH OFFICER
Dated 17.02.2023

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IN
AND
IN THE MATTER OF KIDNAPPING, ABDUCTION.
NON BAILABLE WARRANT, GANG RAPE,
LLICIT SEX TRADE, CHILD SEXUAL ABUSE,
HUMAN TRAFFICKING, INTERNATIONAL SEX
RACKET MOB VIOLENCE, SUSPICIOUS DEATH
AND ABUSE OF POWER BY STATES, NGOS,
ORGANIZATIONS
AND
IN THE MATTER OF:
OM PRAKASH …….. PETITIONER(S)
VERSUS
MEMO OF APPEARANCE
To
The Registrar
Supreme Court of India
New Delhi
Sir,
Please enter my appearance Petitioner-in-Person in the above
mentioned matter:
New Delhi
Dated this the day of 2023
Yours faithfully,
New Delhi (OM PRAKASH)
Date: 17-02 -2023 Petitioner-in-Person

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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. Office Report on Limitation A A1
3. Cover Page of Paper Book A-2
4. Index of Record of Proceedings A-3
5. Defect List A-4
6. Note Sheet NS1-
7. List of Dates B-GG
8. Review Petition (Criminal) with
Affidavit
1-29
9. Annexure: P-1
True copy of impugned order dated
06.02.2023 under Challenge in
Writ Petition Criminal No. 42/2023
30-35
10. Application for seeking
permission to appear and argue the
Review Petition (Criminal) in
person along with supporting
affidavit.
36-40
11. Application for seeking exemption
from filing attested copy of
Affidavit along with supporting
affidavit.
41-45
12. Filing Index
13. Memo of Appearance
14. I.D.Proof

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SYNOPSIS AND LIST OF DATES
The present review Petition is being preferred by the
Review Petitioner against the common final order
dated 06.02.2023passed by this Hon’ble Court in
Writ Petition Criminal No. 42 of 2023 which offends
the petitioner and defends the perpetrator and rapists
in absence of clear direction with fixed time line for
recovery of minor daughter which has resulted in
miscarriage of justice. Order dated 06.02.2023
deliberately ignored the fact that petitioner and his
family is the victim of State coercion evading the
rule of law to sustain forced prostitution. Writ
Petition Criminal No. 42 of 2023 had been filed,
aggrieved by the State coercion since 18 years at all
levels. After disposal of Twenty two cases in Delhi
and Bihar below the court, this Hon’ble Court has
refused to entertain this case. Writ Petition Criminal
No. 42 of 2023 arose out of refusal of F.I.R by Police
violating direction of this Hon’ble Court laid down in Lalita
Kumari vs. Government of Uttar Pradesh & Ors. (W.P.
(Crl.) No. 68/2008), Dismissal of Writs by this Hon’ble
Court, sheer violation of Practice, Procedure, Rule of Law
by the Registry of this Hon’ble Court and Continuation of
Sexual Abuse of petitioner’s families and minor daughters
by the State since 2005. This is a kidnapping, abduction,
Non- Bail able Warrant, Gang Rape, Illicit Sex trade and
human trafficking by the State.
15.04.2005 Pregnant wife Rina Kumari (Guddi) kidnapped

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with an active help of her father Surender
Narayan Poddar with a tactics under the
influence of sex racketeers from the rented
house of Judge’s driver at Palam Colony New
Delhi, just after nine months of fraudulent
marriage.
20.05.2005 Kidnapped Pregnant wife Rina Kumari (Guddi)
gave birth to a girl child in a hospital at Dhanbad,
Jharkhand and the same being informed over
telephone to the petitioner and his parents.
15.11.2007 Handicapped father of petitioner, Deep
Narayan Poddar succumbed to suspicious death
under the persistent curse of sex abusers.
25.08.2010 Non Bailable Warrant in Case 9P/2010 against
Petitioner and his mother Srmt. Asha Rani Devi
issued by Civil Court Begusarai under the
Judicature of Patna High Court and supplied by
respondent wife in HMA-678/2010 at Family
Court Dwarka Court at New Delhi on 09.02.2011.
08.09.2011 Non Bailable Warrant in Criminal Case
Complaint (P) No. 397C/ 2011/ 5591/2013 u/s

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82 and 83Cr.Pc against Petitioner and his
mother Srmt. Asha Rani Devi by Civil Court
Begusarai under the Judicature of Patna High
Court and unearthed by RTI reply dated
20.09.2017 by Mr. Gangotri Ram Tripathi,
District & Session Judge Begusarai Bihar to
Registrar Admin Patna High Court.
07.04.2011 Police complaint to SHO Kadwa, Katihar Bihar
against physical attack by Surender Narayan
Poddar and his associates.
30.05.2011 Police complaint to Chawki in charge, P.P.
Dwarka Court New Delhi against physical attack
by Surender Narayan Poddar and his associates.
06.06.2011 Police complaint to SHO, P.S. Dwarka Sector-23
at New Delhi against physical attack by Surender
Narayan Poddar and his associates.
09.02.2011 Respondent wife appeared before Family Court,
Dwarka Court at New Delhi along with 6 year old
Girl child in HMA-678/2010 Goshwara No. 83H;
Filed Vakalatnama but not filed Written Statement
(WS) and did not contest the case.

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23.04.2012 Special Leave to Appeal (Civil) 9854/2012
against High Court of Delhi being dismissed by
this Hon’ble Court.
23.07.2013 High Court of Delhi announced Ex-Parte
Judgment with NO COST in MAT.APPL.
7/2012 after three SLPs noted above.
05.06.2014 Sexual harassment of subordinate personnel
executive Ms. Kamna Saini by Mr. Praveen
Kumar, Indian Defense Account Service and
CMD of Indian Drugs and pharmaceuticals Ltd,
New Delhi has been identified and reported by
petitioner to PMO; which has resulted in CS-
201/2015 before Patiala House Court and
W.P.(Crl.) 90 of 2016 before Supreme Court of
India.

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22.11.2014 Sexual harassment of subordinate receptionist
Ms. Neelam Bharti by Korian MNC company
Cash Weighing India Pvt. Ltd at Gurgaon
Haryana factory is being identified in the
capacity of Human Resource Manager of the
Company and being reported to National
Commission for Women vide file no.
8/C140030905/2014/NCW/SS/IM dated
25.11.2014 under trafficking/prostitution of
women but being closed on 07.09.2017 on the
ground of allegations made by the complainant
found false after investigations.
09.12.2014 112 call made against Sex abusers of Korian
Company Cash Weighing India Pvt. Ltd.
Gurgaon Haryana. PCR in charge picked up
petitioner to police station Udyog Vihar Phase-
V Gurgaon but did not record his statement.
Sexual Abuse Case is being suppressed by
Haryana Police.
14.03.2015 ACP Udyog Vihar Gurgaon Haryana called on
petitioner at his office in response to NCW

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Complaint no.2014110100627 and refused to
record statement rather advised to shut mouth
otherwise ready to face dire consequences.
28.02.2016 Gang Rape organized by Mr. Sidharth Mohan
Jain SP katihar and his team converting the
house of petitioner into public toilet and
organizing religious gathering “Bhagwat” in
front of his house w.e.f. 28.02.2016 to
06.03.2016 at Asha Deep Niwas at Sonaili.
03.03.2016 Petitioner Faxed a complaint to SP katihar for
registration of an F.I.R against Gang Rape.
17.03.2016 I.A. 3 of 2016 as additional facts, annexures,
grounds, parties and prayers being filed in
W.P.(C) 90/2016 for no action by police in
Gang Rape matter along with photographs of
public toilet before this Hon’ble Court.
18.04.2016 W.P.(C) 90/2016 against illegal termination of
service by CMD Indian Drugs Pharmaceutical
Ltd New Delhi and Gang Rape by SP Katihar
being dismissed by this Hon’ble
Court.
07.05.2016 Action Taken Report by Katihar Police in Public
Toilet and Gang Rape matter.
17.05.2016 Reply by petitioner to the secretariat of Chief
Minister Bihar through online complaint
number 99999-0303160113 & 99999-
1705160125 against Public toilet report.

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30.05.2016 Police complaint D.D.No. 37B to SHO Palam
Village Police Station New Delhi against
criminal conspiracy by Surender Narayan
Poddar and his associates to kill mother of the
Petitioner.
21.10.2016 W.P.(Crl) 136/2016 a writ of certiorari against
SDJM Begusarai Civil Court and Registrar
Patna High Court under the judicature of Patna
High Court dismissed by this Hon’ble Court.
01.12.2016 Review Petition (Crl.) 825 of 2016 in W.P.(Crl)
136/2016 dismissed by this Hon’ble Court.
28.01.2017 W.P.(Crl) D.NO. 2188/2017 against violation of
practice, procedure, rule of law and suppression
of records by the Registry of Supreme Court of
India dismissed by this Hon’ble Court.
16.02.2017 W.P.(Crl) D.NO. 3913 of 2017 against the
Registrar of Supreme Court of India for
violating practice, procedure, rule of law and
suppression of records dismissed by this
Hon’ble Court.
17.07.2017 Curative Pet (Crl.) D 41026 of 2016 in Review
Petition (Crl.) 825 of 2016 in W.P.(Crl)
136/2016 has withdrawn by the Petitioner.
11.11.2017 Srmt. Asha Rani Devi Mother of Petitioner
succumbed to suspicious death at New Delhi.
10.02.2018 Action Taken Report by ACP Uma Shnkar,
Delhi Cantt. New Delhi in Suspicious death of
petitioner’s mother Srmt. Asha Rani Devi.

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18.04.2018 Action Taken Report by Katihar Police in
Suspicious death of petitioner’s mother Srmt.
Asha Rani Devi.
16.05.2018 Action Taken Report by Katihar Police in
Public Toilet and Gang Rape matter.
26.06.2018 Reply by petitioner to the secretariat of Chief
Minister Bihar through online complaint
number 99999-0303160113 & 99999-
1705160125 against the Public toilet report.
31.05.2019 Action Taken Report by SP Katihar for
execution of Non bailable Warrant against
petitioner and his mother Srmt. Asha Rani Devi.
19.06.2019 Criminal Writ Jurisdiction Case 1238/2019
being filed before Patna High Court by the
petitioner complying the order of this Hon’ble
Court in W.P.(Crl) No. 136/2016.
30.07.2019 Violent mob attack, stone pelting, mob lynching
and illegal arrest of petitioner by Kadwa Police
Katihar Bihar.
09.08.2019 Police complaint to SP Katihar against organized
mob lynching and illegal detention of petitioner.
27.08.2019 I.A. 1 of 2019 against mob violence dated
30.07.2019 being filed in Criminal Writ
Jurisdiction Case 1238/2019 before Patna High
Court.
20.09.2019 Action Taken Report (ATR) against mob
violence/mob lynching and illegal detention of
petitioner by SP Katihar, Bihar

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petitioner by SP Traffic Katihar, Bihar
14.12.2019 Action Taken Report (ATR) against land
encroachment of petitioner by SHO Kadwa
Katihar, Bihar
23.04.2021 Ms Nikki has been identified as a suspected case
of Child Sexual Abuse at Shastri Park at North
East Delhi and being reported to National
Commission for Women and the same being
rejected on the ground of minor girl.
26.04.2021 First time, petitioner identified his families and
minor daughter cum item girl into the mud of
prostitution at Shastri Park North East Delhi.
16.10.2021 I.A. No. 134091/2021 for Legal Aid Services in
PIL W.P. (Crl.) No. 242/2021 on child
prostitution before this Hon’ble Court has been
filed by the petitioner.
25.10.2021 PIL W.P.(Crl) 242/2021 on child prostitution
dismissed by this Hon’ble Court on the ground
of non-appearance of Legal Aid Advocate.
18.01.2022 An application to SP Katihar disclosing
cognizable offence against the sex abusers for

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attacking the livelihood encroaching the
agricultural lands of petitioner.
31.01.2022 An application to SHO Dandkhora Katihar
for registration of an F.I.R disclosing cognizable
offence against the sex abusers for attacking the
livelihood/agricultural lands of petitioner..
20.02.2022 Sex abuser and contractor Sunil Kumar from
Sub-Station Power House Sonaili, Electricity
Department Government of Bihar approached
the petitioner and disclosed that he has
disconnected the electricity of petitioner’s house
and directed to approach JEE sub-station Sonaili
power house electricity department for re-
connection of electricity.
26.02.2022 Sex abuser, International sex racketeer cum
Pharmacist, gangster Pappu Yadav’s Aid Sanjay
Gupta along with Rajnikant Gupta working with
Primary Health Centre Kadwa, Durgaganj,
Katihar, Health Department Government of
Bihar approached the petitioner’s house and
disclosed that he along with team has gang
raped, sexually abused minor girls and pushed
petitioner’s whole families into International
market for Prostitution. Petitioner
immediately took the cognizance of this
offence and used Snjay Gupta’s mobile and
WhatsApp to send an application to DGP
Bihar control room.
30.03.2022 An application for obtaining Medico Legal
Case/Injury report dated 30.07.2019 of shri

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Bechan Poddar related to an attempt of mob
lynching of petitioner on 30.07.2019 being
emailed to Additional chief secretary cum
food safety commissioner, Health
Department, Government of Bihar to supply
the same for court purpose as Sanjay Gupta
an employee of PHC Kadwa, Durgaganj has
disclosed that no injury report, no entry in
the name of Bechan Poddar is available
with the official record of PHC Kadwa,
Durgagunj.
30.04.2022 I.A. No. 66686/2022 for
intervention/impleadments filed in Writ Petition
(Criminal) No. 137/2021 to rescue Gang Rape
victims and petitioner’s families and minor
girls.
02.05.2022 W.P.(Crl) 137/2021 against abuse of Police
power and continuation of illicit sex trade of
petitioner’s families being dismissed by this
Hon’ble Court.
07.05.2022 Rescued Victims re-pushed into the business of
flesh trade by the State. Police complaint
against sex abusers state through email letter
dated 07th
May 2022 by petitioner to all nodal
police officers of Bihar and NCT of Delhi
08.05.2022 Police complaint against sex abusers state
through email letter dated 08th
May 2022 by
petitioner to all nodal police officers of Bihar
and NCT of Delhi.

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May 2022 by
and NCT of Delhi.
11.05.2022 That victims being identified at in a Gang Rape
stage show at Sonaili Bazar P.S. Kadwa,
Katihar Bihar and reported for rescue. Police
complaint against sex abusers state through
email letter dated 11th
May 2022 by petitioner
to all nodal police officers of Bihar and NCT of
Delhi
12.05.2022 Petitioner being mob lynched by sex abusers and
Bihar Police refused to register a Medico Legal
Case (MLC). Police complaint against sex
abusers state through email letter dated 12th
May 2022 by petitioner to all nodal police
officers of Bihar and NCT of Delhi
May 2022 by
and NCT of Delhi
May 2022 by
and NCT of Delhi
May 2022 by
and NCT of Delhi

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16.05.2022 That petitioner filed application before Child
Line Railway Katihar, Bihar for rescue. Police
Delhi
17.05.2022 That petitioner filed online application before
National Commission for Protection of Child
Rights (NCPCR) for rescue. Police complaint
dated 17th
18.05.2022 That the petitioner refiled online application
before Child Line India Foundation. Police
Delhi.
May 2022 by
and NCT of Delhi
20.05.2022 SHO Kadwa and SI Binod Singh gang raped
victims inside the residence of petitioner. Police
Delhi
22.05.2022 That Petitioner’s house is being planted with a
battery bomb by the sex abusers. Police

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email letter dated 22nd
Delhi
23.05.2022 Petitioner is being attacked by a women human
trafficker along with Child Line Katihar.
24.05.2022 Gang rape and illicit sex trade being identified
within the premises of Divisional Railway
Management Katihar Bihar and reported for
rescue. Police complaint against sex abusers
state through email letter dated 24th
May 2022
by petitioner to all nodal police officers of
Bihar and NCT of Delhi
25.05.2022 Gang rapes and illicit sex trade being identified
within the jurisdiction of Kadwa Police Station
Katihar Bihar and reported for rescue.
26.05.2022 That the petitioner refiled online application
before National Commission for Protection of
Child Rights (NCPCR) for rescue. Police
Delhi
within the jurisdiction of Katihar district Bihar
and reported for rescue. Police complaint
dated 27th

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inside the house of petitioner and reported for
rescue. Police complaint against sex abusers
state through email letter dated 28th
May 2022
by petitioner to all nodal police officers of
Bihar and NCT of Delhi
29.05.2022 Gang rape and illicit sex trade of Petitioner’s
more than 50 female members including minor
daughters being identified within the
jurisdiction of Katihar district Bihar and
reported the same for rescue. Police complaint
dated 29th
30.05.2022 Gang rape and illicit sex trade by Indian Army
being identified within the jurisdiction of
Kadwa Police Station at Katihar district of
Bihar and reported the same for rescue.
31.05.2022 Despite of receiving information disclosing
cognizable offence of gang rape, police refused
to register F.I.R and continued illicit sex trade of
victims. Police complaint against sex abusers
state through email letter dated 31st
May 2022 by
and NCT of Delhi
01.06.2022 At midnight, robbery and attempt to murder
Petitioner by sex abusers. Police complaint
dated 1st
June, 2022 by petitioner to all nodal

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02.06.2022 Secretary Ministry of Home Affairs, Government
of India has been approached to intervene or to
issue direction for registration an F.I.R. Police
email letter dated 2nd
June, 2022 by petitioner to
all nodal police officers of Bihar and NCT of
Delhi
03.06.2022 Direction sought from Home Secretary Ministry
of Home Affairs, Government of India to
register an F.I.R against the cognizable offence
commissioned by Ms. Indu Sinha, Justice S.B.
Sinha of Supreme Court of India, Manoj Sinha
Governor of J&K, Prateek Sinha Advocate,
Jayant Sinha ex-cabinet minister government of
India, Praveen Kumar Indian Defense Account
Service, Amarnath Sinha, NGO owner at
Sonaili P.S. Kadwa and State of Bihar and
others for continuing Gang Rape of petitioner’s
families for consecutively 29 days; after rescue
of the victims from Delhi by the order of
Supreme Court of India in W.P.(Crl.) 137/2021
& W.P.(Crl.) 242/2021-PIL. Police complaint
dated 3rd
June, 2022 by petitioner to all nodal
04.06.2022 Gang Rape and illicit sex trade of the victims
continued within the knowledge of all state and
central agencies and the same being reported.
05.06.2022 Katihar administration and state of Bihar and

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others have tried to obstruct the way of
applicant to reach Supreme Court of India on
05.06.2022 at 5:45PM
06.06.2022 Delhi Police has given safe passage to Human
trafficker to traffic minor daughter of petitioner
on 06.06.2022 at 22:30pm from Anand Vihar
Railway Station Delhi.
07.06.2022 Instant Criminal Writ Petition along with I.A.
for early hearing being e-filed on 7.6.22 but the
same is being suppressed by obstructing online
payment for printing charges. Thereafter,
petitioner being thoroughly tortured and
physically assaulted by sex abusers, lap top
being damaged, all communications being
stopped, all shops of Delhi are being polarized
to obstruct petitioner in discharging his court
work from 7.6.22 to 23.6.22. Petitioner became
handicapped in absence of case record. More
than twenty five 112 call has been made from
Old Delhi Railway Station and Church Mission
Road under Lahori Gate police station but all
went in vain.
08.06.2022 Petitioner filed hand written Affidavit before
Hon’ble the Chief Justice of India to end this
artificial deadlock.
09.06.2022 Police complaint vide D.D.No. 23A at
12:26p.m. before Lahori Gate Police Station
Delhi against persistent Gang Rape and illicit
sex trade of petitioner’s families.

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10.06.2022 petitioner is being illegally detained for 24 hours
by Church Mission Road Police Post under
Lahori Gate Police Station Delhi in retaliation
of 112 call made against Gang Rape and illicit
sex trade by the petitioner.
11.06.2022 112 call against gang rape inside old Delhi
railway station property under GRP Old Delhi
Railway Police Station and hotels under Lahori
Gate Police Station. 112 call against Delhi
Police for Gang Rape and illicit sex trade of
petitioner’s families. The same has been
recorded by unique reference no. 5217267 dated
11.06.2022 and subsequently statement has
been recorded by Enquiry Officer Rajender
Singh SI, Mobile no. 9910939878 GRP old
Delhi Railway Police Station at 5:30 a.m.
12.06.2022 112 call against gang rape inside old Delhi
railway station property under GRP Old Delhi
Railway Station and subsequent filthy abuse
and threatening for dire consequences by SHO.
14.06.2022 Petitioner managed to file instant Writ criminal
diary no. 18546/2022 physically to revive e-
filed writ dated 7.6.22 to agitate before the
Vacation bench.
15.06.2022 Nine Defects have been notified by Ms. Rajni
Sharma, dealing assistant Section 1B.
15.06.2022 DCP/Inspector Vigilance Vasant Vihar Police
Station New Delhi recorded statement of

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petitioner against Gang Rape of his family
members.
16.06.2022 All defects being removed with clarification.
However, clarifications being rejected and
directed to remove prayer IV ( allow payment
of e-filed Writ dated 7.6.22) and prayer V & VI
(consider all prayers of e-filed writ no…..dated
7.6.22 and physically filed writ no……. dated
14.6.22)
18.06.2022 Police complaint at Tilak Marg Police Station
Delhi vide D.D.No. 40 against persistent Gang
Rape and illicit sex trade of families and minor
daughter of petitioner inside the Supreme Court
of India premises.
19.06.2022 Petitioner identified and verified his kidnapped
pregnant wife Rina Kumari (Guddi) on
19.06.2022 at Delhi in front of Old Delhi
Railway Station at the bus stop in black burka.
The same has been reported to Delhi Police
along with human traffickers mobile number
8830993916 through 112 call reference no.
5260340 dated 19.06.2022 at 17:08pm.
21.06.2022 Petitioner complied the direction of registry and
removed prayer V and VI from the instant writ
and refiled the same. Dealing assistant has
allowed the prayer IV (allow payment of e-filed
Writ dated 7.6.22) therefore prayer IV is not
being removed by the petitioner.

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21.06.2022 112 call with reference no. 5268830 at
09:24:27AM dated 21.06.2022 has been made
against the persistent Gang Rape, child sexual
abuse and illicit sex trade of petitioner’s
families inside the toilet of old Delhi Railway
Station close to RPF office. E.O. Satya Mohan
recorded the statement of petitioner at 13:32pm.
22.06.2022 Shockingly instead of listing the Gang Rape
matter before Vacation bench, Petitioner is
being again directed to remove Prayer VII
(consider all prayers prayed in dismissed writs)
which had automatically taken the place of
Prayer V due to removal of prayer V & VI
(consider all prayers of e-filed writ no…..dated
7.6.22 and physically filed writ no……. dated
14.6.22). Petitioner refused to succumb to the
foul play of registry; hence matter is being
pushed into defective list for 90 days under the
influence of Adaani & Ambani’s company
touts.
24.06.2022 112 call with unique reference no.
R24062200034 is being made between
Firozabad and Etawa, Railway station at Uttar
Pradesh against the human traffickers of minor
daughter.
29.06.2022 Matter is being pushed into defective list by
Registry deliberately therefore miserable
Petitioner left with no other legal remedy but to
report to Hon’ble the Chief Justice of India in

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LETTER form to apprise the situations of Gang
Rapes and illicit sex trade of victims at ground
zero level. E-filed Gang Rape report to Hon’ble
the Chief Justice of India in LETTER form to
apprise the foul play and delaying tactics of
Registry of Supreme Court of India.
02.07.2022 112 call with reference no. 8206 at 21:19:28pm
has been made in Bihar against the
Superintendent of Police Katihar for raping
petitioner’s families inside his house at Bihar.
03.07.2022 e-filed Gang Rape report to Hon’ble the Chief
Justice of India in LETTER form to apprise the
indulgence of Judiciary, Executive, Legislature,
Indian defense organization, general public and
NGOs in continuation of Gang Rapes and illicit
sex trade of victims at ground zero level.
Justice of India in LETTER form comparing the
act of Hitlar (against Jews community by
stripping off their women and children and
throwing them in front of troops/defense
personnel to Gang Rape in the open ground)
with the act of prime minister Narender Modi.
Justice of India in LETTER form depicting the
monumental disaster and praying for change of
leadership in the National interest.

27
Justice of India in LETTER form depicting the
anti-National institutional arrangement made by
Government of India to sustain the business of
flesh trade to generate revenue and to achieve
its own political mileage.
16.07.2022 e-filed LETTER to Branch Officer Section X to
list the matter urgently before Chamber Judge
for direction as grave the situation demands for
permission to social work intervention into this
matter.
Justice of India in LETTER form with a prayer
to allow the petitioner to meet the victims of
Gang Rape to bring their mind and body back
from the clutches of human traffickers and sex
racketeers.
for direction to avoid Gang Rapes and illicit
sex trade of victims at ground zero level.
involvement of Christian Missionaries NGOs in
anti-national activities to disintegrate the Indian
territory by social invasion.
19.07.2022 e-filed Gang Rape report in LETTER form to
Branch Officer Section X to list the matter
urgently before Chamber Judge for direction to

28
avoid Gang Rapes and illicit sex trade of
victims at ground zero level.
sustenance of Gang Rapes and illicit sex trade
of victims by distorting the concept of pious
‘LOVE’ of God Lord Krishna and Goddess
Radha Rani at ground zero level.
for direction to avoid Gang Rapes and illicit sex
trade of victims at ground zero level.
strategy of Government of India to portray the
victims as delinquent and to create a hoax
situation to suppress their rescue; which
requires permission to social work intervention
into this matter at this juncture.
violation of rule of law, dismissal of writs,
violation of direction of this Hon’ble Court by
police as laid down in “Lalita Kumari VS.
Government of Uttar Pradesh & Ors” to
continue the Gang Rapes and illicit sex trade of
victims at ground zero level.

29
Anti-Youth - National policy of Union of India
for continuation of Gang Rapes and illicit sex
trade of victims at ground zero level.
intolerable situation of Gang Rapes and illicit
sex trade of victims at ground zero level; which
is degrading the dignity of Supreme Court of
India.
obvious linkages of Gang Rape and illicit sex
trade with dismissal of PIL Writ criminal
242/2021 on the ground of non-appearance.
syndicate of Rahul Gandhi’s Congress and Lalu
Yadav’s Rashtriya Janta Dal Political parties for
sustenance of Gang Rape and illicit sex trade.
indulgence of Registry of Supreme Court of
India in this sex racket matter.
for permission to professional social workers in
rescue operation.

30
10.08.2022 e-filed LETTER to Branch Officer, Section X to
serve NOTICE of hearing to the petitioner-in
person to appear before Chamber Judge.
nexus of Registry of Supreme Court of India
with the human traffickers across the country
including Bihar for transacting the illicit sex
trade of the victims.
strategy of state to engage the victims in gainful
employment to hide or suppress the rescue of
the victims to sustain the illicit sex trade and
hidden prostitution.
concept of illegal sex trade in legal way
benefiting the Law and enforcement agencies
prevailing at ground zero level.
to take suo moto cognizance against the grave
offence committed by legal aid
advocates/amicus curie in PIL W.P. (Crl)
242/2021 on child prostitution before this
Hon’ble Court.

31
Justice of India in LETTER form to apprise
against non-existence of bare Act on
Prostitution in Legal World, yet act of
prostitution is prevailing with an active help of
Law and enforcement agencies at ground zero
level across the country.
to strike down the Judgment in W.P. (Civil)
576/2016 or to overshadow the Judgment by
expanding Article 21 in W.P.(Crl.) diary no.
18546/2022 in the National interest.
indulgence of Indian Railway Network in
sustaining illicit sex trade for revenue
generation and fulfilling the mandate for double
engine Governance model in India.
08.09.2022 Out of frustration, Petitioner has e-filed a Gang
Rape report addressing all concerned public
authorities in LETTER form to help the
petitioner in rescuing his families out of state
coercion.
12.09.2022 Indian army has been identified for gang raping
the victims by stopping its army special train at
Sonaili Railway Station under Divisional
Railway Manager Katihar and under North
Eastern Frontier Zone dated 12.09.2022 at
9:00am. The same has been reported to police

32
and Delhi Commission for Women.
20.09.2022 I.A No. 15405/23 dated 20.09.2022 for
additional documents, facts, grounds and
prayers being e-filed from Katihar Bihar. Cause
of action arose for additional grounds due to
foul play and delaying tactics by the Registry.
22.09.2022 e-filed LETTER to Registrar Section X and 1B
requesting for a NOTICE to the petitioner in
person to appear before the Chamber Judge on
26.09.2022 but refused in absence of interaction
with Registrar.
23.09.2022 I.A No. 143346 dated 23.09.2022 for seeking
leave to file written Arguments for the hearing
dated 26.09.2022.
09.10.2022 I.A No. 164340 dated 09.10.2022 for recall of
order of Non Bail able Warrant has been filed.
Cause of action arose due to preemptory order
dated 26.09.2022 for removal of prayer V. I.A.
No. 164340 is a substitute for prayer V.
10.10.2022 Petitioner reported Trafficking/Prostitution case
of his wife Rina Kumari alias Guddi to National
Commission for Women but being rejected as
the matter is sub-judice/adjudicated by the
court/pending before other commission.
11.10.2022 e-filed LETTER to Branch Officer Section 1B
informing the compliance of order dated
26.09.2022 done by petitioner and the instant
writ has been refiled on 10.10.2022 within the

33
time limit set by the order.
12.10.2022 e-filed reminder LETTER to Branch Officer
Section 1B informing the order dated
26.09.2022 has been complied and the instant
writ has been refiled on 10.10.2022 curing
defects by the petitioner.
12.10.2022 e-filed complaint LETTER against Branch
Officer Section 1B & Section X before
Secretary General for designing innovative
strategy to dismiss the instant writ to suppress
the rescue of minor daughter.
13.10.2022 e-filed reminder LETTER to Branch Officer
Section 1B informing the order dated
26.09.2022 has been complied and the instant
writ has been refiled on 10.10.2022 &
13.10.2022 curing defects by the petitioner.
13.10.2022 e-filed complaint LETTER against Mr.
Jagmohan Singh, Assistant Registrar Section
1B before Secretary General for deliberately
avoiding petitioner and keeping him waits for
hours in front of the filing counter.
14.10.2022 e-filed grievance LETTER to Branch Officer
Section 1B explaining the foul play by registry
for notifying new defect on 14.10.2022 with
back date of notification (15.6.22) to file an I.A.
for condonation of delay in refiling the instant
writ.
17.10.2022 I.A No. 157294 dated 17.10.2022 for seeking

34
leave to file Written Arguments for the hearing
dated 31.10.2022 has been filed.
17.10.2022 e-filed LETTER of urgency to Registrar Section
1B to avoid delay in listing, allot writ number,
arrange interaction with Registrar to end the
barbaric act of state in the furtherance of justice.
20.10.2022 112 call has been made with reference
no.5984283 at 12:31:26pm against SHO
L.P.Singh, SI Maharaj Singh GRP Anand Vihar
Police Station Delhi for suppressing F.I.R and
sustaining Gang Rape and illicit sex trade of
Petitioner’s families.
avoid delay in listing before Chamber judge for
direction.
07.11.2022 e-filed LETTER to Hon’ble the Chief Justice of
India to apprise the foul play and delaying
tactics by Registry
09.11.2022 e-filed complaint LETTER to Hon’ble the Chief
Justice of India against Shri Sahender Kumar,
party in person counter clerk to apprise the foul
play and suppression of case record by him.
09.11.2022 112 call has been made with a unique reference
number 6089680 at 15:43:51pm against Chawki
In Charge Shri Praveen Sharma and SHO
Lahori Gate Police Station Delhi for organizing
mob attack, suppressing F.I.R and sustaining
Gang Rape and illicit sex trade of Petitioner’s

35
families.
13.11.2022 e-filed complaint LETTER to Hon’ble the Chief
Justice of India with a prayer to prioritize the
Gang Rape and life and liberty matter
tactics by Registry.
22.11.2022 e-filed LETTER to Branch Officer Section X
against foul play and suppression of records by
Registry.
tactics by Registry.
India with a prayer to exercise the inherent
power of court to avoid the delaying tactics by
perpetrator.
24.11.2022 112 call has been made with a unique reference
number 6161038 at 19.32.34pm and subsequent
Complaint dated 25.11.2022 and dated
27.11.2022 to the Commissioner of Police
Delhi against ERO 59-Vishwas Nagar Delhi
and ERO-64 Kadwa Bihar, Election
Commission of India for making fake voter
identity card of minor girl under the legal
guardianship of petitioner.

36
indulgence of Election Commission of India in
illicit sex trade.
India against the suppression of records by the
Registry.
29.11.2022 e-filed Report to Registrar summarizing the
events/cause of actions arose during 90 days
due to delaying tactics and its obvious impact.
01.12.2022 I.A No. 187397 dated 01.12.2022 for objection
to office report dated 26.11.2022 has been filed.
05.12.2022 e-filed LETTER to PPS to Hon’ble the Chief
Justice of India for an appointment to apprise
the plight of NBW and Gang Rape matter.
Appointment being refused.
07.12.2022 Upon refusal of appointment with Hon’ble the
Chief Justice of India RTI application no.
10162/RTI/22-23/SCI dated 7.12.22 has been
filed to apprise the plight of NBW and Gang
Rape matter.
12.12.2022 e-filed and physically filed Complaint against
Hon’ble Justice M.M. Sundaresh along with
Affidavit before Hon’ble the Chief Justice of
India for deferring an adverse order on the
ground of non-representation on 09.12.2022;
While Petitioner in person cannot appear
without interaction with Registrar as per the
office report dated 8.12.22.
12.12.2022 I.A No. 196275 dated 12.12.2022 for

37
permission to place on record subsequent facts
against the Advocates and Judges below the
courts associated with this case are accountable
for sustenance of illicit sex trade of victims for
their own vested interest.
15.12.2022 DCP public grievance cell Civil Line, North
Delhi has recorded the statement of petitioner at
Night Shelter Home, DUSIB Code No. 214 near
ISBT Anand Vihar at Delhi.
20.12.2022 ACP Crime Branch Rohini Delhi has also
recorded the statement of petitioner through
email.
09.01.2023 112 call with reference no. R09012300038 is
being made at Kanpur Railway Station in Uttar
Pradesh against the poisonous food served by
railway vendor in Seemanchal Express Train
with an ulterior motive to kill the petitioner.
11.01.2023 I.A No. 8023 dated 11.01.2023 for condonation
of delay in refiling/curing the defects has been
filed complying the order dated 06.01.2023.
21.01.2023 I.A No. 15979 dated 21.1.2023 for amendment
and clubbing of e-filed writ dated 7.6.22 with
physically filed Writ dated 14.6.22 has been
filed for proper adjudication.
28.01.2023 SHO Patparganj Industrial Area Delhi has also
recorded the statement of petitioner at Night
Shelter Home, DUSIB Code No. 214 near ISBT
Anand Vihar at Delhi.

38
04.02.2023 Once again, Aadhar Card/Number, mobile
number, voter ID of petitioner is being misused
by election commission to make fake voter Id
for abducted, gang raped and trafficked wife
and minor daughter. Even after recording the
statement of petitioner against election
commission by Delhi Police Inquiry officer
Balveer Singh Patparganj Industrial Area dated
28.1.23; Petitioner received a message from
Election Commission of India at his mobile no.
9540389759 at 14.30 pm dated 4.2.23 "thank
you for submitting form on NVSP. Your form
reference ID is S04064D700402231000001"
just after a GAIL trainee from Jaipur Rajasthan
Mr. Arjun or Ajay Singh mobile no.
8111100133 poked the petitioner at night
Shelter Home DUSIB, Code 214, ISBT Anand
Vihar Delhi. Petitioner immediately reported it
to Commissioner of Police Delhi and Chief
Election Commissioner of India.
06.02.2023 Just after dismissal of W.P. (Crl.) 42/2023
several criminal physical attack by rapist State
inside the moving Delhi bus and at Night
Shelter Home DUSIB, Code 214, near ISBT
Anand Vihar Delhi. Two 112 calls have been
made after dismissal of writ with reference no.
8935617 and 6523947 dated 06.02.2023 against
rapists.
14.02.2023 RTI application no. 11049/RTI/22-33/SCI has

39
been filed to obtain certified copies of order
dated 06.02.2023 and I.A. No. 164340/2022
recall of order of Non Bail able Warrant in W.P.
(Crl.) 42/2023 before this Hon’ble Court.
15.02.2023 112 call with reference no. 6566492 dated
15.02.2023 has been made against the rapists
for doing robbery during night sleep to scare the
petitioner.

40
REVIEW PETITION CRIMINAL D.NO.7153 OF 2023
IN
AND
ABDUCTION. NON BAILABLE
WARRANT, GANG RAPE, LLICIT
SEX TRADE, CHILD SEXUAL
ABUSE, HUMAN TRAFFICKING,
INTERNATIONAL SEX RACKET
MOB VIOLENCE, SUSPICIOUS
DEATH AND ABUSE OF POWER BY
STATES, NGOS, GANGSTERS AND
INDIAN DEFENSE ORGANIZATIONS
AND
BETWEEN
1. Om Prakash ………PETITIONER
S/O Late Sh Deep Narayan Poddar
R/O ASHA DEEP NIWAS
Vill-Kantiya Panchayat,
Shukkar Haat Sonaili,
In front of Durga Mandir
P.S. Kadwa, Distt-Katihar
Bihar-855114
AND RENTED
R/O C/O Inder Pal
RZF-893, Netaji Subhash Marg
Raj Nagar Part-2, Palam Colony
New Delhi-110077
VERSUES
1. Union of India ….RESPONDENT No.01
Ministry of Home Affairs
Through
Secretary North Block,
Central Secretariat, New Delhi
2. Government of NCT of Delhi ….RESPONDENT No.02
Through
Chief SecFretary

41
Delhi Secretariat, I.P. Estate
New Delhi-110002
3. State of Bihar ….RESPONDENT No.03
Through Chief Secretary,
Old Secretariat, Patna-800015
4. District Magistrate ….RESPONDENT No.04
Katihar, Bihar
5. District Judge ….RESPONDENT No.05
District Court Katihar
Bihar
6. Public Prosecutor ….RESPONDENT No.06
District Court Katihar
Bihar
7. Commissioner of Police Delhi ….RESPONDENT No.07
Police Headquarters,
MSO Building, I.P. Estate,
New Delhi-110002
8. Director General of Police ….RESPONDENT No.08
Bihar Police Headquarters,
Sardar Patel Bhawan,
Nehru Marg, Patna - 800023
9. Inspector General of Police, ….RESPONDENT No.09
Darbhanga, Bihar
10. Deputy Inspector General of Police ….RESPONDENT No.10
Purnia, Bihar
11. Superintendent of Police ….RESPONDENT No.11
District- Katihar,
Bihar-854105
12.Deputy Commissioner of Police ….RESPONDENT No.12
North East District Delhi
13.Assistant Commissioner of Police ….RESPONDENT No.13
Seelampur,
14.Assistant Commissioner of Police ….RESPONDENT No.14
Delhi Cantt.
South West District Delhi
New Delhi
15.Secretary ….RESPONDENT No.15
Electricity Department

42
Government of Bihar
16.Chief Executive Engineer ….RESPONDENT No.16
District Katihar, Bihar
17.Junior Executive Engineer ….RESPONDENT No.17
Sub-Station Sonaili, Kadwa
18.Secretary Health Department ….RESPONDENT No.18
Patna, Government of Bihar
19.Civil Surgeon ….RESPONDENT No.19
Health Department
20.In-charge Medical Officer ….RESPONDENT No.20
Kadwa, Primary Health Centre
Durgagunj, District Katihar
21.Sub Divisional Manager ….RESPONDENT No.21
Barsoi, Katihar
22. Sub-Divisional Police Officer ….RESPONDENT No.22
Head Quarter
District-Katihar,
Bihar- 854105
23. Sub-Divisional Police Officer ….RESPONDENT No.23
Barsoi, District Katihar,
Bihar- 855102
24.Station House Officer ….RESPONDENT No.24
Palam Village Police Station,
South West District
New Delhi
25. Station House Officer ….RESPONDENT No.25
Kadwa Police Station,
District-Katihar,
Bihar-855114
Shastri Park,
Dandkhora, Katihar
Bihar
28. Chairperson ….RESPONDENT No.28

43
National Commission for Protection
of Child Rights (NCPCR)
5th
Floor, Chanderlok Building,
36 Janpath, New Delhi-110001
29. Nodal Coordinator ….RESPONDENT No.29
ChildLine India Foundation
Eastern Regional Resource Centre
Kolkotta
30. Nodal Coordinator ….RESPONDENT No.30
ChildLine India Foundation
North Regional Resource Centre
1st Floor, H. No. 144/2, Hari Nagar
Mathura Road, Ashram, New Delhi-14
31. Child line Railway Coordinator …..,.RESPONDENT No.31
Katihar, Plat Farm No.02, Katihar Railway
Station, Bihar
32. SP Railway Delhi …..,.RESPONDENT No.32
Old Delhi Railway Station
Delhi
33. SP Railway Katihar …..,.RESPONDENT No.33
Katihar Railway Station
Bihar
34. SHO Railway Police, …..,.RESPONDENT No.34
Plat Farm No.02
Bihar
35. Indian Defense Organizations …..,.RESPONDENT No.35
Army, Navy and Air Force
Head Quarters at New Delhi
36. Divisional Rail Manager …..,.RESPONDENT No.36
Eastern Frontier Rail Division
37. Director …..,.RESPONDENT No.37
Trustee and Governing Bodies
Asha Deep Foundation
Shalimar Garden Main B-block, Block A,
Shaheed Nagar, Ghaziabad,
Uttar Pradesh 201005
0120- 262 6309
D-81, Shahid Nagar, Delhi NCR, Ghaziabad,
U. P., India

44
38. Director …..,.RESPONDENT No.38
Child Line India Foundation
B-1101, 11th
Floor, Ratan Central
Dr, Baba Saheb Ambedkar Road
Parel East, Mumbai-400012
39. Child Line Coordinator …..,.RESPONDENT No.39
District Samastipur, Bihar
40. Chairman …..,.RESPONDENT No.40
Railway Board, Rail Bhawan
New Delhi-1
41. Chairperson …..,.RESPONDENT No.41
National Commission for Women
New Delhi
PETITION UNDER ARTICLE 137 OF THE
CONSTITUTION OF INDIA READ WITH
ORDER XL OF THE SUPREME COURT
RULES 1966, FOR REVIEW OF THE FINAL
ORDER DATED 06.02.2023 PASSED BY THIS
HON’BLE COURT IN THE WRIT PETITION
(CRIMINAL) NO. 42 OF 2023 ON THE
GROUND OF AN ERROR APPARENT ON
THE FACE OF RECORD.
To
Hon'ble the Chief Justice of India and His
Lordship's Companion Justices of the Supreme
Court of India. The Humble Review Petition
Criminal of the Petitioner abovenamed.
MOST RESPECFULLY SHOWETH:

45
1. FACTS OF THE CASSE:
(i) 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 disastrous effect
having far reaching consequences against the
interest of public at large.
(ii) That final order dated 06.02.2023 says, “We have heard the
petitioner who appears as petitioner-in-person. The
petitioner has referred to a sex racket. He has also stated
that the petitioner wanted to get custody, recovery and
rescue of his minor daughter. Without prejudice to any of
the remedies in any other competent forum, the writ petition
will stand dismissed”.
True Copy of Order dated 06.02.2023 in W.P.(Crl.) No.

46
42/2023 is annexed as Annexure P-1 (Page from 30 to 35).
(iii) That final order dated 06.02.2023 offends the petitioner
and his victim wife & minor daughter and defends
the rapists & perpetrator in absence of clear
direction with fixed timeline for recovery of minor
daughter; which has resulted in repeat of case of Ms.
Nupur Sharma who is untraceable by the competent forum
down the line deliberately due to state coercion and lumpen-
ism inflicted by the radical outfits like RSS, BJP and
Bajrang Dal; which has also diluted the basic fabric and
objectives of the 18 year old case, compelled the
petitioner to start this case afresh at zero level; which has
also resulted in gross of miscarriage of justice.
(iv) That final order has been passed either ignoring I.A. No.
164340/2022 for recall of Order of Non Bailable Warrant
u/s 82 and 83 Cr.Pc. or not taking this “Life and liberty”
fact into consideration. Assistant Public Prosecutor (APP)
has pressed to execute 83 Cr.Pc. on 03.10.2018 (evident
from certified copy of order at page no. 360 of Part-II
volume of Writ Petition containing Letters, Report &
Miscellaneous Documents). The 83 Cr.Pc. has been
executed even after W.P. (Crl.) 136/2016 before this
Hon’ble Court, RTI reply dated 20.09.2017 by District and
session Judge Mr. Gangotri Ram Tripathi to Registrar
Administration Patna High Court, suspicious death of
petitioner no. 02 Srmt. Asha Rani Devi in W.P. (Crl.)

47
136/2016 before this Hon’ble Court at New Delhi on
11.11.2017 and even after surrender of petitioner before SP
Katihar Bihar dated 31.05.2019 for his arrest.
(v) That petitioner and his wife is the victim of Law and
enforcement agencies. Law and enforcement agencies have
misused the great tool of women 498A to sustain the sex
racket in the society and to push the Women into the mud of
Prostitution. There is a big Conspiracy by Law &
Enforcement agencies for weakening 498A by misusing it
for their own vested interest.
(vi) That victim respondent wife has filed Vakalatnama in
HMA-678/2010 at Family Court Dwarka Court at New
Delhi but not filed Written Statement (WS) and prefer not
to contest the case.
(vii) That final order has been passed without considering the
fact that Victim wife has recorded her statement before 1st
Class Judicial Magistrate Mr. Atul Kumar Pathak on
07.04.2010; wherein Victim wife has expressed her
willingness to stay along with her husband but due to evil
design of Advocates she has been pushed into the brothels
of prostitution forcefully.
(viii) That petitioner was totally unaware of the actual fact of
prostitution.
(ix) That petitioner came to know the actual fact of prostitution

48
on 26.04.2021 at Shastri Park North East Delhi and
approached this Hon’ble Court with W.P. (Crl.) No.
242/2021.
(x) That order dated 06.02.2023 has not recorded the prayer of
physically filed Writ petition dated 14.06.2022 and prayers
of all nine Interlocutory Applications. Shockingly,
impugned order has only recorded the prayer of e-filed writ
petition dated 7.6.2022.
(xi) That final order dated 06.02.2023 does not fix timeline and
direction to any competent forum to recover the minor
daughter immediately.
(xii) That the main purpose of the case is lost in absence of fixed
timeline and direction to rescue and recover the victim wife
and minor daughter.
(xiii) That the final order has been passed either ignoring all the
twenty three case records related to this case HMA-
678/2010 at Family Court Dwarka Court at New Delhi, case
no. 9P/2010 at Civil Court Begusarai under the judicature of
Patna High Court, Criminal Case Complaint (P) No.
397C/ 2011/ 5591/2013 at Civil Court Begusarai under the
judicature of Patna High Court, Civil Suit CS.No. 201/2015
at Patiala House Court at New Delhi, MAT.APPL. No.
7/2012 at High Court of Delhi, CRWJC No. 1238/2019 at
Patna High Court and seventeen cases before this Hon’ble

49
Court. Out of twenty three cases all have been disposed of,
except Criminal Writ Jurisdiction Case No. 1238/2019
before Patna High Court; which has been kept under
objection since 13.11.2019 coercively.
(xiv) That the final order is just an eye wash which leverages
discretion, whims and fancy to competent forums to
suppress the rescue and recovery of the victims till the death
of the petitioner. Final order is promoting illicit sex trade
and suppressing the rescue operation of victims.
(xv) That final order has been passed without considering the
lower court records in case no. 9P/2010 under domestic
violence Act 2005 and 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 filed by victim wife at Civil
Court Begusarai under the judicature of Patna High Court;
which has been disposed of declaring the petitioner and his
mother as a proclaimed absconder.
(xvi) That crux of 18 years of disastrous case is the product of
evil design by Advocates and legal professionals below the
court by way of misleading, derailing, concealing the
material fact to sustain the illicit sex trade; which have been
recorded through I.A. No.196275/2022 for subsequent facts
against Advocates below the court in Writ (Criminal)
No. 42 of 2023. That record of subsequent facts against
Advocates below the court has been either ignored or
not taken into consideration before passing final

50
order dated 06.02.2023.
(xvii) That final order dated 06.02.2023 has been passed without
considering prayer no. (a) in the I.A. No. 164340/2022 for
recall of order of Non Bail able Warrant at page no. 342 of
Writ Petition; which says, “Recall the order dated
25.08.2010 and 08.09.2011, whereby Non-Bailaible
Warrants were issued against the petitioner Om Prakash
and his mother Asha Rani Devi by Begusarai Court under
the judicature of Patna High Court in 9-P/2010 and
397c/2011 (Criminal Case Complaint (P) no. 5591/2013)
case and Cancel the Non-Bailaible Warrants issued against
the Petitioner and his mother to eradicate Prostitution and
International Sex Racket”.
(xviii)That order dated 06.02.2023 has thoroughly ignored the evil
design of Advocates. Evil design of Advocates has
converted the kidnapped pregnant wife into Muslims and
abducted minor daughter into Christianity forcefully, made
them as an item girl with an active help of Bollywood
movie world, performed child marriage forcefully to sustain
illicit sex trade and to grab the movable and immovable
property of petitioner.
(xix) That Final order dated 06.02.2023 paves the way to

51
competent forum down the line to consume time, dilute the
basic fabric and basic purpose of the case to suppress the
rescue and recovery of minor daughter to sustain her sexual
abuse till she attains the age of 18 years or 21 years.
(xx) That stage of intervention by any other competent forum is
over now, because the age factor of minor daughter has
become the main contention of this case. Petitioner will
never succumb to the evil design of Advocates and never
accept his unseen and unidentified 17 year old minor
daughter and never give her any legal rights of movable and
immovable property during his lifetime and after his death;
rather he will STOP pursuing the rescue operation, if she
attains the age of 21 years. She will no more be daughter of
petitioner after the age of 21 years.
(xxi) That Petitioner has approached this Hon’ble Court being
aggrieved by the foul play, adoption of wrong intervention
strategy and closure of all cases by the competent forum
down the line. Some of the names of competent forum is
Women Commission, ChildLine, National Commission for
Protection of Child Rights, Human Rights Commission,
Central and State Grievance Redressal Mechanisms, Social
Welfare Department, Non-Governmental Organizations,
Police station, tribunal, Trial Court, High Courts. Ironically,
instead of enforcement of fundamental rights, this Hon’ble
Court has infringed the fundamental rights of petitioner and
his families and his parents; which has resulted in
suspicious death of his father in Bihar and suspicious death
of his mother at New Delhi.

52
(xxii) That jurisdiction of this Hon’ble Court is maintainable in
this human trafficking case which attracts jurisdiction of
multiple States. It is pertinent to mention here that Article
226 has been invoked before Patna High Court through
Criminal Writ Jurisdiction Case No. 1238/2019 but the
enforcement of fundamental rights have been denied by
pushing this case into defective list vide order dated
13.11.2019 to “List in usual Course” to sustain illicit sex
trade of victim family.
(xxiii)That final order dated 06.02.2023 has been passed without
requisition of records below the court and without perusal
of lower court records.
(xxiv)That first cause of action arose in Delhi thereafter in all
states across the country and across the globe which have
been recorded through I.A. No. 15405/2023 for additional
grounds in W.P.(Crl.) No. 42/2023; which have been either
ignored or not taken into consideration before passing final
order dated 06.02.2023.
(xxv) That final order dated 06.02.2023 has been passed without
considering the disastrous and devastating effect and impact
of Pro-Prostitution judgment on “INDIAN HOTEL AND
RESTAURANT ASSOCIATION (AHAR) & ANR. VS. THE
STATE OF MAHARASHTRA & ORS in Writ Petition (Civil)
No. 576/2016 with Writ Petition (Civil) No. 24/2017 with
Writ Petition (Civil) No. 119/2017; which is interlinked
with Writ Petition (Criminal) 136/2016 and M.A. No(s).

53
84/2017 in WRIT PETITION (CRL.) D. NO.3913 of 2017
entitled OM PRAKASH & ANR VERSUS REGISTRAR
SUPREME COURT OF INDIA AND ANR filed by
Petitioner before Supreme Court of India. Petitioner’s wife
and minor daughter is the victim of this Pro-Prostitution
judgment delivered by this Hon’ble Court in Writ Petition
(Civil) No. 576/2016. Striking down of this Judgment and
overshadowing of this Judgment by reviewing and
reconsidering the final order dated 06.02.2023 is inevitable
and in the public interest at large and in the furtherance of
justice.
(xxvi) That final order dated 06.02.2023 has been passed without
considering para (74) in the I.A. No. 15405/2023 for
additional ground at page no. 319 of writ petition; which
states, “That present Writ petition under Article 32 of the
Constitution of India has been filed challenging misuse of
following Acts to sustain the International Sex Racket, which
violates the Fundamental Rights of the Petitioners and Gang
Rape Victims guaranteed under Article 14, 15, 19 and 21 of
the Constitution of India. F.I.R/Cases registered under these
Acts are connected with the sex racket of Gang Rape Victims
in Bihar, Bengal, Orissa, Uttar Pradesh, Haryana, Delhi,
Punjab, Jammu and Kashmir, Gujrat, Maharashtra, Tamil
Nadu, Andhra Pradesh, Assam and across the country
required to be requisitioned to review, expand and enforce
the Rights of the Petitioners and Gang Rape Victims under
Article 14, 15, 19 and 21 of Constitution of India”.
(xxvii) That final order dated 06.02.2023 has been passed without

54
considering prayer no. (d) in the I.A. No. 15405/2023 for
states, “Requisition the below Court records to establish the
evidences against Abuse of Court Process and Sexual Abuse
of Gang Rape Victims by the State”.
(xxviii)That final order dated 06.02.2023 has been passed without
considering prayer no. (e) in the I.A. No. 15405/2023 for
states, “Club all F.I.Rs/Cases across Country misusing
certain Acts listed in para 72 of this application to establish
evidences and reasons against sustenance of International
Sex Racket, human trafficking, illicit sex trade and forced
hidden prostitution, which violates the Fundamental Rights
of the Petitioners and Gang Rape Victims guaranteed under
Article 14, 15, 19 and 21 of the Constitution of India”.
(xxix) That final order dated 06.02.2023 has been passed without
considering prayer no. (f) in the I.A. No. 15405/2023 for
additional ground at page no. 322-323 of writ petition; which
states, “Set aside framed Police Action Taken Report dated
07.05.2016 and 16.05.2018 by Bihar Police suppressing the
events of Gang Rape by Mr. Sidharth Mohan Jain,
Superintendent of Police Katihar and direct to register an
F.I.R to rescue the Victims from the clutches of prostitution
and human trafficking”.
(xxx) That final order dated 06.02.2023 has been passed without
considering prayer no. (g) in the I.A. No. 15405/2023 for

55
states, “Set aside framed Police Action Taken Report dated
10.02.2018 by Delhi Police and dated 20.09.2019,
29.11.2019, 14.03.2020, 31.10.2020 by Bihar Police
suppressing the events of mob violence to kill the petitioner
and his deceased mother Asha Rani Devi to sustain the
business of International Sex Racket and direct to register an
F.I.R to rescue the Victims from the clutches of prostitution
and human trafficking”.
(xxxi) That final order dated 06.02.2023 has been passed without
considering prayer no. (h) in the I.A. No. 15405/2023 for
states, “Interpret the misuse of certain Acts listed in para 72
of this application to sustain the business of illicit sex trade
and expand the horizon of Article 14, 15, 19 and 21 of the
Constitution of India to eradicate the leprosy of Prostitution,
human trafficking and International sex racket”.
(xxxii) That final order dated 06.02.2023 has been passed without
considering the Short Synopsis and List of Dates from
(15.04.2005 to 04.02.2023) supplied by the petitioner to both
the Hon’ble My Lords on the date of hearing dated
06.02.2023.
(xxxiii)That final order dated 06.02.2023 has been passed without
considering prayer no. (b) in the I.A. No. 196275/2022 for
subsequent facts against the Advocates and Judges at page
no. 412 of Writ Petition; which states, “TAKE the
cognizance of criminal offence committed by Advocates

56
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”.
(xxxiv) That final order dated 06.02.2023 has been passed
without considering prayer no. (c) in the I.A. No.
196275/2022 for subsequent facts against the Advocates
and Judges at page no. 412 of Writ Petition; which states,
“Direct to concern SHOs to register an F.I.R against the
accused Advocates under relevant sections of IPC”.
(xxxv) That final order dated 06.02.2023 has been passed without
considering the prayer no. (viii) in Physically filed Writ
Petition dated 14.06.2022 at page no. 234 of Writ Petition;
which states, “To set aside divorce Judgment passed in
MAT.APPEAL NO. 7/2012 by Delhi High Court and correct
the misleading error and abuse of court process for
derailing the actual matter from prostitution, illicit sex
trade, child sexual abuse to divorce, domestic violence, and
498A Dowry Prohibition by the sex abusers State and
Central Government”.
(xxxvi) That final order dated 06.02.2023 has been passed without
considering the prayer no. (ix) in Physically filed Writ

57
Petition dated 14.06.2022 at page no. 234-235 of Writ
Petition; which states, “To Constitute a Committee to
recommend Government of India for judicial reform, police
reform, defense reform and bureaucratic reform to combat
the menace of International Human trafficking and illicit sex
trade in the garb of fast changing jurisdiction of victims with
an active help of misusing Government machinery”.
(xxxvii) That final order dated 06.02.2023 has been passed
without considering the prayer no. (x) in Physically filed
Writ Petition dated 14.06.2022 at page no. 235 of Writ
Petition; which states, “To remove the jurisdictional barrier
in the case of Human Trafficking and illicit sex trade to wipe
out it from the earth and save other innocent families from
ruining like the Petitioner”.
(xxxviii) That at the outset it is respectfully submitted that the
Petitioner by means of the present Review Petition is seeking
review of:-
(a)Perusal and Examination of factual records on merits
placed before this Hon’ble Court in Writ Petition Part-I
(Page from 1 to 441) and Part-II (Page from 1 to 381)
(b) Perusal and Examination of factual records on merits
placed before this Hon’ble Court in the form of “Short
Synopsis and List of Dates (from 15.04.2005 to
04.02.2023” at the time of hearing dated 06.02.2023,
which covers the major events occurred during the span
of 18 years.
(c) Requisition of twenty three case records related to this
case and its Examination on merits, “case HMA-678/2010
at Family Court Dwarka Court at New Delhi, case no.

58
9P/2010 at Civil Court Begusarai under the judicature of
Patna High Court, Criminal Case Complaint (P) No.
397C/ 2011/ 5591/2013 at Civil Court Begusarai under
the judicature of Patna High Court, Civil Suit CS.No.
201/2015 at Patiala House Court at New Delhi,
MAT.APPL. No. 7/2012 at High Court of Delhi, CRWJC
No. 1238/2019 at Patna High Court and seventeen cases
before this Hon’ble Court. Out of twenty three cases all
have been disposed of, except Criminal Writ Jurisdiction
Case No. 1238/2019 before Patna High Court; which has
been kept under objection since 13.11.2019 coercively”.
(d)Examination on merits the interlinkages between pro-
prostitution Writ Petition (Civil) No. 576/2016 with anti-
prostitution petition Writ Petition (Criminal) 136/2016
and M.A. No(s). 84/2017 in Writ Petition (Crl.) D.
NO.3913 of 2017 filed by petitioner before this Hon’ble
Court; with a prayer either to Strike down or to
overshadow the judgement of Writ Petition (Civil) No.
576/2016 by reviewing and reconsidering impugned
order dated 06.02.2023 in Writ Petition Criminal
42/2023.
2. QUESTION(S) OF LAW:
Main questions of Law to be decided in the present Review
Petition are:
a) Whether or not evil design of Advocates to be
considered to rescue and recover the victims?
b) Whether or not twenty three case records under

59
different case categories related to the victims in two states
to be considered to review and figure out the actual case
category of victims to rescue and recover them
immediately?
c) Whether or not age factor to be considered as a key
factor to exercise the original appellate criminal jurisdiction
of this Hon’ble Court to issue direction with fix time line to
competent forum to rescue and recover the victims
immediately?
d) Whether or not interlinkages between pro-prostitution
Writ Petition (Civil) No. 576/2016 with anti-prostitution
petition of petitioner, Writ Petition (Criminal) 136/2016
and M.A. No(s). 84/2017 in Writ Petition (Crl.) D. NO.3913
of 2017 to be considered to rescue and recover the victims
by this Hon’ble Court immediately?
e) Whether or not striking down or overshadowing the
judgment in Writ Petition (Civil) No. 576/2016 to be
considered for review and recover the abducted minor
daughter by this Hon’ble Court immediately?
3. AVERMENT

60
i) That the impugned Order dated
06.02.2023 is liable to be reviewed since there are
errors which are apparent on the face record as
detailed in the grounds below and further there are
other sufficient reasons for reviewing the said
impugned Order as set out hereinafter.
ii) That the Petitioner states that he has not filed any
other Review Petition in this Hon’ble Court
seeking review of the Order dated 06.02.2023
passed by this Hon’ble Court in Writ Petition
(Criminal) No. 42 of 2023.
4. GROUNDS:
Thus it is respectfully and humbly prayed that this Hon’ble
Court may be pleased to review its order dated 06.02.2023 to
the limited extent as detailed hereinabove; on the following
amongst other grounds which are in the alternative and without
prejudice to each other:
A. For that the impugned order suffers from errors that are
apparent on the face of the record.
B. For that impugned order failed to appreciate that evil
design by Advocate is the key factor to rescue and
recover the victims immediately.
C. For that impugned order failed to appreciate that
petitioner was totally unaware of the actual fact of

61
prostitution and he came to know the actual fact of
prostitution on 26.04.2021 at Shastri Park North East
Delhi and approached this Hon’ble Court with W.P.
(Crl.) No. 242/2021
D. For that impugned order failed to appreciate that
petitioner has approached this Hon’ble Court for
Cancellation of two Non-Bailaible Warrants u/s 82 & 83
Cr.Pc. issued against the Petitioner and his mother by 1st
Class judicial Magistrate and Sub Divisional Judicial
Magistrate, Civil Court Begusarai under the judicature of
Patna High Court.
E. For that impugned order failed to appreciate that the
victim wife has already recorded her statement before
the Magistrate on 07.04.2010 at Civil Court Begusarai
under the judicature of Patna High Court and expressed
her willingness to stay along with her husband; but due
to evil design by Advocates she is being pushed into
prostitution forcefully.
F. For that impugned order failed to appreciate that victim
wife has not filed Written Statement in divorce case at
New Delhi. Ex-parte judgment has been passed by the
lower court at New Delhi.
G. For that impugned order failed to appreciate that Ex-
parte judgment has been passed by High Court of Delhi.
H. For that impugned order failed to appreciate that order
without direction with fixed time line will repeat the case

62
of Ms. Nupur Sharma who is untraceable by the
competent forum down the line deliberately due to
lumpen-ism inflicted by the radical outfits like RSS, BJP
and Bajrang Dal.
I. For that impugned order failed to appreciate that
requisition of records below the court is inevitable to
rescue and recover the victims immediately.
J. For that impugned order failed to appreciate that there is
big conspiracy by Law and enforcement agencies for
weakening the great tool of women 498A; either to push
the women into prostitution forcefully or to sustain the
sex racket in the society.
K. For that impugned order failed to appreciate that it
compels the petitioner either to leave the victims or to
act harsh against them.
L. For that impugned order failed to appreciate that
Petitioner will lose her families forever due to non-
speaking order dated 06.02.2023.
M.For that impugned order failed to appreciate that it
compels the petitioner to start the finished case from
afresh at zero level; which has resulted in miscarriage of
justice.
N. For that impugned order failed to appreciate that age
factor is the key factor in this case.

63
O. For that impugned order failed to appreciate that this is
an evil design by Advocates to obtain the legal rights of
the movable and immovable property of petitioner
infringing his fundamental rights.
P. For that impugned order failed to appreciate that
fundamental rights have been infringed by issuing Non
Bail able Warrants, refusing F.I.R, dismissing Writs and
continuing sexual abuse and illicit sex trade of the victim
families.
Q. For that impugned order failed to appreciate that it is a
brutal State coercion and barbaric act of State against
petitioner and his families.
R. For that impugned order failed to appreciate that
petitioner has approached this Hon’ble Court to
challenge the Action Taken Reports (ATR) of Bihar and
Delhi Police for enforcement of his rights under Article
21 of Constitution of India.
S. For that impugned order failed to appreciate that
petitioner has approached this Hon’ble Court for the
advocacy of striking down or over shadowing the
judgement of Writ Petition (Civil) No. 576/2016 to
eradicate the leprosy of Prostitution, human trafficking
and International sex racket from the society.
T. For that impugned order failed to appreciate that
petitioner’s wife and minor daughter is the victim of
forceful religious conversion, forcefully turned into item

64
girl, forcefully pushed into prostitution and forcefully
pushed into human trafficking changing their legal
status, jurisdictions, personality, dresses, clothes,
garments, attire, languages and life styles.
U. For that impugned order failed to appreciate that pro-
prostitution Writ Petition (Civil) No. 576/2016 is
inerlinked with anti-prostitution petition by petitioner,
Writ Petition (Criminal) 136/2016 and M.A. No(s).
84/2017 in Writ Petition (Crl.) D. NO.3913 of 2017
before this Hon’ble Court.
V. For that impugned order failed to appreciate that
jurisdiction of this Hon’ble Court is maintainable in this
International human trafficking case; which is attracting
jurisdiction of multiple States and several Countries.
Petitioner suffers from denial of enforcement of
fundamental rights under Article 226 by Patna High
Court.
W.For that impugned order failed to appreciate that present
Writ petition under Article 32 of the Constitution of
India has been filed challenging misuse of certain Acts
to sustain the International Sex Racket, which violates
the Fundamental Rights of the Petitioners and his Gang
Rape Victim families guaranteed under Article 14, 15,
19 and 21 of the Constitution of India and for its
interpretation, expansion and enforcement.
X. For that impugned order failed to appreciate that
petitioner has approached this Hon’ble Court for

65
Clubbing of all F.I.Rs/Cases to establish evidences and
reasons against sustenance of International Sex Racket,
human trafficking, illicit sex trade and forced hidden
prostitution across the country.
Y. For that impugned order failed to appreciate that short
synopsis and List of Dates portrays the complete glimpse
of major events occurred in the past 18 years in
connection with this case.
Z. For that impugned order failed to appreciate that sexual
harassment and sexual abuse cases cannot be understood
in isolation. Sexual harassment and sexual abuse cases
are figured out under different Acts in absence of Bare
Act on Prostitution.
AA. For that impugned order failed to appreciate that
petitioner has approached this Hon’ble Court to set aside
divorce Judgment passed in MAT.APPEAL NO. 7/2012
by Delhi High Court to rescue his innocent wife from the
mud of forced prostitution and to correct the misleading
error and abuse of court process for derailing the actual
matter from prostitution, illicit sex trade, child sexual
abuse to divorce, domestic violence, and 498A, Dowry
Prohibition by the sex abusers State and Central
Government for its own vested interest.
BB. For that impugned order failed to appreciate that
petitioner has approached this Hon’ble Court for an
advocacy of judicial reform, police reform, defense
reform and bureaucratic reform to combat the menace of

66
International Human trafficking and illicit sex trade in
the garb of fast changing jurisdiction of victims with an
active help of misusing Government machinery.
CC. For that impugned order failed to appreciate that
petitioner has approached this Hon’ble Court for an
advocacy of removal of jurisdictional barrier in the case
of Human Trafficking and illicit sex trade to wipe out it
from the earth and save other innocent families from
ruining like the Petitioner.
PRAYER
It is, therefore, most respectfully and humbly prayed that Your
Lordships may graciously be pleased to:
(i) Review the impugned Order dated 06.02.2023 passed by this
Hon’ble Court in Writ Petition (Criminal) No. 42 of 2023 to
the extent detailed hereinabove; and/or
(ii)Pass such other order/orders as this Hon'ble Court may deem
just and proper in the facts and circumstances of the case.
OM PRAKASH
SONAILI, SHUKKAR HATT,
KANTIYA PANCHAYAT,
MOB: 9540389759 , E-mail: om.poddar@gmail.com
NEW DELHI:
FILED ON : 17 -02-2023

67
CRIMINAL ORIGINAL JURISDICTION
IN
AND
ABDUCTION. NON BAILABLE WARRANT,
GANG RAPE, LLICIT SEX TRADE, CHILD
SEXUAL ABUSE, HUMAN TRAFFICKING,
INTERNATIONAL SEX RACKET MOB
VIOLENCE, SUSPICIOUS DEATH AND
ABUSE OF POWER BY STATES, NGOS,
ORGANIZATIONS
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 Subhash Marg, Raj Nagar Part-2, Palam Colony,
New Delhi-110077 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.

68
2. That the contents of the accompanying Review Petition
Criminal in Writ Petition Criminal No. 42/2023 under
Article 137 of Constitution of India against the impugned
order dated 06.02.2023 which has been drafted by me [para
01 to 04], [Page 01 to 27 ] and Synopsis and List of Dates
(Page B to GG], and I, As. and application for seeking
permission to appear and arguing in-person having
understood the contents thereof I say that the facts state
therein are correct which are based on the official record.
3. That the annexures P-01 [Page 30 to 35] are true copies of
their respective original.
4. That the Review Petition Criminal Petition Paper Book
contains total pages 45.’
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 17th
day of February, 2023.
DEPONENT

69
Annexure P-1
ITEM NO.25 COURT NO.3 SECTION X
S U P R E M E C O U R T O F I N D I A
RECORD OF PROCEEDINGS
WRIT PETITION(CRIMINAL) Diary No. 18546/2022
OM PRAKASH Petitioner(s)
VERSUS
UNION OF INDIA & ORS. Respondent(s)
(FOR ADMISSION and IA No.8023/2023-CONDONATION OF DELAY IN
REFILING/ CURING THE DEFECTS and IA No.196275/2022-
PERMISSION TO PLACE ON RECORD SUBSEQUENT FACTS and IA
No.11921/2023-PERMISSION TO APPEAR AND ARGUE IN PERSON and
IA No.143346/2022-SEEKING LEAVE TO FILE WRITTEN ARGUMENTS
and IA No.157294/2022-SEEKING LEAVE TO FILE WRITTEN
ARGUMENTS and IA No.15979/2023-CLUBBING OF SIMILAR SLPS
FOR PROPER ADJUDICATION and IA No.164340/2022-UNDER
SECTION 151 OF CPC and IA No.187397/2022-UNDER SECTION 151 OF
CPC and IA No.15405/2023-PERMISSION TO FILE ADDITIONAL
DOCUMENTS/FACTS/ANNEXURES)
Date : 06-02-2023 This matter was called on for hearing today.
CORAM :
HON'BLE MR. JUSTICE K.M. JOSEPH
HON'BLE MRS. JUSTICE B.V. NAGARATHNA
For Petitioner(s)
Petitioner-in-person
For Respondent(s)
UPON hearing the petitioner-in-person
the Court made the following
O R D E R
Delay in refiling is condoned.
The petitioner has approached this Court seeking the following reliefs:
“
(i) To issue a writ of mandamus or other appropriate writ order
or direction directing respondent No.01, 02, 03, 05, 06, 07,
and 08 to register an F.I.R against the complaints of

70
petitioner made since 2011 to till date and to investigate into
the persistent gang rapes of the victims at the source point of
human trafficking at Sonaili Katihar Bihar, rescued from
illicit sex trade and child sexual abuse from
destination/transit point of human trafficking at Sashtri Park
North East Delhi and the rampant abuse of police power
against the petitioner as well as against the victims and direct
to register an F.I.R under relevant sections of IPC against the
accused rapists of persistent gang rapes, illicit sex trade,
hidden prostitution, child sexual abuse, human trafficking of
rescued victims by the nexus of states, NGOs, Gangsters,
Mafia and Indian Defense Organizations and to be
monitored by issuing a necessary direction to the District
Judge and SHO to investigate the matter impartially, fairly
and properly including the arrest of the accused, after the
registration of F.I.R.
(ii)To issue a writ of mandamus or other appropriate writ order
or direction directing respondent No.01, 02, 03, 05, 06, 07,
and 08 to pass a dismissal order against the lady magistrate
Katihar, accompanying with the petitioner in W.P.(Crl)
242/2021 and W.P.(Crl) 137/2021 for placing illegal, false
and fabricated documents to this Hon’ble Court to transfer
the case from Delhi to Bihar and taking unauthorized
custody of the rescued victims with an ulterior motive of re-
pushing them into the same business of flesh trade for
generating revenue out of it.

71
(iii) To tag all petitions W.P.(Crl) 136/2016, W.P.(Crl)
137/2021 and W.P.(Crl) 242/2021 together with this petition
in the furtherance of justice.
(iv) To issue a writ of mandamus or other appropriate
writ order or direction directing respondent No. 03 and 15 to
direct respondent no. 16 and 17 to resume the electricity
services of the house of the petitioner immediately.
(v)To issue a writ of mandamus or other appropriate writ order
or direction directing respondent No. 03 to direct respondent
no. 04, 18, 19, 20 and 21 to investigate into the lapse of
medical services by Primary Health Centre Kadwa
Durgaganj and Sadar Hospital Katihar, for injecting
inappropriate injections into the body of petitioner, taking
unauthorized blood sample of petitioner on 12.05.2022
injuring internally and snatching his medical prescription
and daily diary from his hand on the same day and date to
evade the evidence.
(vi) To issue a writ of mandamus or other appropriate
writ order or direction directing respondent No. 01 to direct
respondent no. 32, 33 and 34 to investigate into the matter of
not handing over the victims to the petitioner and re-pushing
the rescued victims into the same business of flesh trade,
gang rapes, illicit sex trade, hidden prostitution, child sexual
abuse and human trafficking at the source point of human
trafficking at Sonaili Katihar, Bihar.
(vii) To issue a writ of mandamus or other appropriate
writ order or direction directing respondent No. 01 to direct

72
respondent no. 35 to investigate into the matter of misuse of
defense telecommunication technologies, misuse of Air base
for human trafficking, the victims of gang rape from one
place to another place, misuse of intelligence services to
sustain the business of illicit sex trade and child sexual
abuse, misuse of high technologies devices and chips for
scanning, imaging, monitoring the activities and targeting
the locations of whistle blower, misuse of geo-space scientist
and meteorological department services for causing artificial
rain endangering National Security to sustain the business of
gang rapes, illicit sex trade, hidden prostitution, child sexual
abuse and International human trafficking to create an
absolute social anarchy in the civil society.
(viii) To issue a writ of mandamus or other appropriate
writ order or direction directing respondent No.01, 02, 03,
05, 06, 07 and 08 to initiate rehabilitation process of the
rescued victims and to initiate handing over process of the
rescued victims after doing medical, arrest, charge sheet and
presenting before the court of law either within the family or
within the state institutions like women shelter homes,
children observation homes, counselling for preparing them
mentally and enabling them to choose rehabilitation options
democratically, institutional arrangements for security of the
victims to avoid further gang rapes and sexual abuse of the
victims by human traffickers and to pass an order to allow
the petitioner to know the whereabouts of the victims and to
allow to meet and supervise the victims of gang rapes.

73
(ix) To issue a writ of mandamus or other appropriate
05, 06, 07 and 08 to make necessary arrangements for
impartial medical examinations of the gang rapes victims
from multiple nodal health institutions across country and
ensure cross examination of the medical reports to avoid
falsehood and bias.
(x) To issue a writ of mandamus or other appropriate writ order
or direction directing respondent No.01, 02, 03, 05, 06, 07
and 08 to provide necessary security to the petitioner and the
victims of gang rapes and allow the petitioner to supervise,
evaluate, monitor and report the security services provided
by the Centre or State.
(xi) To issue a writ of mandamus or other appropriate
writ order or direction to respondent no.01 and 7 to direct
concern SHO to register an F.I.R against respondent no. 28
the Chairperson, National Commission for Protection of
Child Rights (NCPCR), Government of India for
commissioning cognizable offence against the victim of
gang rapes deliberately delaying the rescue of child sexual
abuse cases and indulging, sustaining the gang rapes of the
victims for generating revenue out of it till date.
(xii) To issue a writ of mandamus or other appropriate
writ order or direction to the respondent no.01, 02, 03, 04,
05, 06, 07 and 08 to register an F.I.R against no. 29, 30, 31,
37, 38, 39 and 40 Child Line India Foundation for
commissioning cognizable offence against the victim of

74
gang rapes deliberately delaying the rescue of child sexual
abuse cases and indulging, sustaining into the gang rapes of
the victims for generating revenue out of it till date and
initiate actions to dismiss the concerned officials who are
indulged in doing human trafficking, illicit sex trade and
organizing the events of gang rapes of the victims.
(xiii) To issue a writ of mandamus or other appropriate
writ order or direction directing respondent 01, 02, 03, 05,
06, 07 and 08 to rescue, arrest, medical with HIV,
Reproductive health damage and loss, sexually transmitted
infections, uterus status, DNA testing with minor daughter’s
blood, charge sheet and place before the Fast track Court
under POCSO Act or juvenile court or any other court and
initiate the rehabilitation process and handing over process
of the victim wife, minor daughter and 50 other family
members and their respective children of petitioner
immediately till the investigation team constituted by this
Hon’ble Court or the investigation process resumes and
completes.
(xiv) Constitute a competent team under the supervision of
Hon’ble Supreme Court of India to reinvestigate the matter
as this matter is connected to International sex racket.
(xv) To issue a writ of mandamus or other appropriate
05, 07 and 08 to issue a death warrant or hanged to death
order against the guilty Public and non-governmental
authorities and delinquent officials involved into this matter

75
of persistent gang rapes of victims for more than 18 years in
the larger interest of all children across country.
(xvi) To issue a writ of mandamus or other appropriate
writ order or direction directing respondent No.01, 03, 04, 05
and 08 to register an F.I.R against the criminal act of
respondent no. 41 and 36 for making railway property as a
hotspots of illicit sex trade, child sexual abuse and gang
rapes of the rescued victims persistently in the larger interest
of all children across country.
(xvii) To issue a writ of mandamus or other appropriate
writ order or direction directing respondent No.01, 02 and 07
to initiate appropriate action against respondent no. 37
Director, trustee and governing bodies of Delhi/NCR based
NGO Asha Deep Foundation for its wrongful association
with the victim’s minor daughter of the petitioner and
pushing her into the business of flesh trade, child sexual
abuse, illicit sex trade and Gang rapes for generating revenue
out of it.
(xviii) Pass such other order/orders as this Hon'ble Court
may deem just and proper in the facts and circumstances of
the case”.
We have heard the petitioner who appears as petitioner-in-
person. The petitioner has referred to a sex racket. He has
also stated that the petitioner wanted to get custody, recovery
and rescue of his minor daughter. Without prejudice to any
of the remedies in any other competent forum, the writ
petition will stand dismissed.

76
Pending applications stand disposed of.
(NIDHI AHUJA) (RENU KAPOOR)
AR-cum-PS ASSISTANT REGISTRAR
True Copy

77
CRL.M.P.NO. 36541 OF 2023
IN
IN
AND
AND
IN THE MATTER OF:
VERSUS
APPLICATION FOR SEEKING PERMISSION TO APPEAR
AND ARGUE THE REVIEW PETITION (CRIMINAL) IN-
PERSON
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

78
Hon’ble Court in Writ (Criminal) 42 of 2023 by
which this Hon’ble Court has dismissed the petition
to 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 disastrous effect having far reaching
consequences against the interest of public at large,
the contents of which are requested to be read as part of this
application, as the same are not being repeated here for the
sake of brevity.
2. Petitioner does not want to engage Advocate against this
Review Petition (Criminal) No. ………of 2023 even if so
provided by this Hon’ble Court.
3. That the Petitioner is well conversant with the facts of
the case and competent enough to argue the case before this
Hon’ble Court.
PRAYER
It is most respectfully prayed that this Hon’ble Court may be
pleased to:
(a) Kindly permit the Petitioner to appear and argue the Review
Petition (Criminal) in-person.

79
b) 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:
OM PRAKASH
S/O LATE SRIMATI ASHA RANI DEVI
SONALI, SHUKKAR HATT, IN FRONT OF
DURGA MANDIR, KANTIYA PANCHAYAT,
MOB: 9540389759
E-mail: om.poddar@gmail.com
NEW DELHI:
FILED ON : 17-02-2023
Diary No.:

80
IN
AND
AND
IN THE MATTER OF:
VERSUS
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, Sonaili P.S. Kadwa, Distt-Katihar, Bihar-855114 and Rented
R/O RZF-893, Netaji Subhash Marg, Raj Nagar Part-2, Palam
Colony, New Delhi-110077, do hereby solemnly affirm and state
on oath as under:-
5. 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.

81
6. That the contents of the accompanying application for
seeking permission to appear and argue the review Petition
(Criminal) in person, which has been drafted by me [para 01
to 03], [Page 36 to 38] 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.
7. That the accompanying application for permission in person
total pages 05.’
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 17th
day of February, 2023.
DEPONENT

82
CRL.M.P.NO. 36553 OF 2023
IN
IN
AND
AND
IN THE MATTER OF:
VERSUS
APPLICATION FOR SEEKING EXEPTION FROM FILING
ATTESTED COPY OF AFFIDAVIT DUE TO
UNAVOIDABLE REASON
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 RESPECTFULLY SHOWETH:
4. That the present review petition criminal under

83
Hon’ble Court in Writ (Criminal) 42 of 2023 by
which this Hon’ble Court has dismissed the petition
to 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 disastrous effect having far reaching
consequences against the interest of public at large,
the contents of which are requested to be read as part of this
application, as the same are not being repeated here for the
sake of brevity.
5. Due to unavoidable reason, Petitioner is seeking exemption
from filing attested copy of affidavit along with this Review
Petition Criminal.
PRAYER
It is most respectfully prayed that this Hon’ble Court may be
pleased to:

Review Petition Criminal Diary No. 7153 of 2023.pdf

Review Petition Criminal Diary No. 7153 of 2023.pdf

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