Writ Petition Criminal diary no. 18546 of 2022 Part-II .pdf

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IN THE SUPREME COURT OF INDIA
CRIMINAL ORIGINAL JURISDICTION
WRIT PETITION (CRIMINAL) D.NO.18546 OF 2022
Petition under Article 32 of the Constitution of India with
A Prayer to STOP persistent gang rapes, rescue &
rehabilitate the victims of illicit sex trade, hidden
prostitution, child prostitution and Enforcement of
Fundamental Rights.
IN THE MATTER OF:
OM PRAKASH …………..PETITIONER
VERSUS
UNION OF INDIA & ORS ….RESPONDENT
CRL. M.P. NO. OF 2022
APPLICATION FOR SEEKING PERMISSION TO APPEAR
AND ARGUE AS PETITIONER-IN-PERSON
PAPER BOOK
(FOR INDEX KINDLY SEE INSIDE)
PAGES FROM 01 TO 49
PETITIONER IN PERSON
OM PRAKASH

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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. Listing Proforma A-A2 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-J
8. Writ Petition (Criminal) with
Affidavit
1-32
9. Annexure: P-1
True copy of the brief about the
grave situation of persistent gang
rapes and illicit sex trade through
affidavit no.4127/22 dated 8th
June,
2022 to Hon’ble Chief Justice of
India
33-37
10. Annexure: P-2
True copy of application for
appointment with Registrar of
Supreme Court of India dated
8.6.2022 for apprising the grave
situation of persistent gang rapes
and illicit sex trade of Petitioner
families through R&I counter no.
17 of Supreme Court of India
38-39
11. Annexure: P-3
True copy of police complaint
dated 9th
June, 2022 vide D.D.No.
23A at 12:26p.m. at Lahori Gate
Police Station Delhi-6
40-43
12. Application for seeking
permission to appear and argue the
Writ Petition (Criminal) in person
along with supporting affidavit.
44-50
13. Filing Index
14. Memo of Appearance
15. I.D.Proof of Delhi & Bihar

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‘A’
No. F.5/Judl(I)/2018, dated: 29/10/2018
w.e.f. 29th October, 20183
ANNEXURE_ ‘X’
PROFORMA FOR FIRST LISTING
SECTION ____
The case pertains to (Please tick/check the correct box}:
√Central Act: (Title) INDIAN PENAL CODE
√Section: 154(1) and 157(1) Criminal
Procedure Code
Central Rule: (Title) N.A
Rule No(s} N.A
State Act: (Title) N.A
Section: N.A
State Rule: (Title) N.A
Rule No(s) N.A
Impugned Interim Order: (Date) N.A
Impugned Final Order/Decree: (Date) N.A
High Court: (Name) N.A
Names of Judges: N.A
Tribunal/Authority: (Name} N.A
1. Nature of matter: Civil √  Criminal
2. (a) Petitioner No. l : OM PRAKASH
(b) e-mail ID: om.poddar@gmail.com
(c) Mobile phone number: 9540389759
3. (a) Respondent No. l : UNION OF INDIA MINISTRY OF HOME
AFFAIRS
(b) e-mail ID: N.A
(c) Mobile phone number: N.A
4. (a) Main category classification: 1418 CRIMINAL MATTER-OTHERS
(b) Sub classification: N.A
5. Not to be listed before: All writs listed previously before Hon’ble Judges
not to be listed before them.
6. (a) Similar disposed of matter with citation, if any, & case details:
(i) Petition(s) for Special Leave to Appeal (Civil) No(s).9854/2012
entitled OM PRAKASH PODDAR VERSUS RINA KUMARI
dated 23.04.2012
(ii) Petition(s) for Special Leave to Appeal (Civil) No(s).9483/2013
dated 01.04.2013
(iii) Petition(s) for Special Leave to Appeal (Civil) No(s).19073/2013
dated 05.07.2013

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(iv) Writ Petition(s)(Civil) No(s).90/2016 entitled OM PRAKASH
VERSUS INDIAN DRUGS AND PHARMACEUTICALS LTD
AND ORS dated 18.04.2016
(v) Writ Petition(s)(Criminal) No(s). 136/2016 entitled OM
PRAKASH & ANR VERSUS STATE OF BIHAR AND ORS
dated 21.10.2016
(vi) REVIEW PETITION (CRL.) NO. 825 OF 2016 IN WRIT
PETITION (CRL.) NO. 136 OF 2016 entitled OM PRAKASH &
ANR VERSUS STATE OF BIHAR AND ORS dated 01.12.2016
(vii) WRIT PETITION (CRL.) D.NO. 2188 of 2017 entitled OM
PRAKASH & ANR VERSUS UNION OF INDIA & ORS dated
28.01.2017
‘A1’
(viii) WRIT PETITION (CRL.) D.NO. 3913 of 2017 entitled OM
PRAKASH & ANR VERSUS REGISTRAR SUPREME COURT
OF INDIA AND ANR dated 16.02.2017
(ix) M.A. No(s). 84/2017 in WRIT PETITION(CRL.) D. NO.3913 OF
2017 entitled OM PRAKASH & ANR VERSUS REGISTRAR
SUPREME COURT OF INDIA AND ANR dated 14.07.2017
(x) CURATIVE PET(CRL.) D 41026 OF 2016 IN REVIEW
PETITION (CRL.) NO. 825 OF 2016 IN WRIT PETITION (CRL.)
NO. 136 OF 2016 entitled OM PRAKASH & ANR VERSUS
STATE OF BIHAR AND ORS dated 17.07.2017
(xi) Misc. Application D.NO. 22539 of 2018 in WRIT
PETITION(CRL.)D.NO. 2188 of 2017 entitled OM PRAKASH &
ANR VERSUS UNION OF INDIA & ORS dated 23.08.2018
(xii) M.A. NO. 2836 OF 2018 IN MISC. APPLN. D.NO. 22539 OF
2018 IN WRIT PETITION (CRL.) D.NO. 2188 OF 2017 entitled
OM PRAKASH & ANR VERSUS UNION OF INDIA & ORS
dated 07.12.2018
(xiii) Misc. Application D. No.42652/2019 in WRIT PETITION(CRL.)
No. 136/2016 entitled OM PRAKASH & ANR VERSUS STATE
OF BIHAR AND ORS dated 14.07.2020
(xiv) Miscellaneous Application No.1446/2020 in M.A.D
No.42652/2019 IN WRIT PETITION (CRL.) No. 136/2016
entitled OM PRAKASH & ANR VERSUS STATE OF BIHAR
AND ORS dated 14.09.2020
(xv) W.P.(Criminal)242/2021 entitled OM PRAKASH VS UNION OF
INDIA & ORS
(xvi) W.P.(Criminal)137/2021 entitled OM PRAKASH VS UNION OF
INDIA & ORS
(b) Similar pending matter with case details: NO
7. Criminal Matters:
(a) Whether accused/convict has su1rendered:  Yes √ No.
(b) FIR No. N.A Date: N.A
(c) Police Station: N.A
(d) Sentence Awarded: N.A

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(e) Period of sentence undergone including period of detention/ custody
undergone:
N.A
8. Land Acquisition Matters:
(a) Date of Section 4 notification: N.A
(b) Date of Section 6 notification: N.A
(c) Da te of Section 17 notification: N.A
9. Tax Matters: State the tax effect: N.A
10. Special Category (first petitioner/appellant only): N.A
 Senior Citizen>65 years  SC/ST  woman/child  Disabled  Legal aid
case  in custody
11. Vehicle Number (in case of Motor Accident Claim matters): N.A
Petitioner-in-Person
(Name) OM PRAKASH
Registration No………………
Date: 14-06-2022

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SYNOPSIS AND LIST OF DATES
The present Writ Petition under Article 32 of the
Constitution of India is being filed by a Social
Worker cum husband cum father cum Guardian cum
Whistle Blower cum Petitioner-In-Person; aggrieved
by the deliberate hiding out of his all near about 50
family members including his kidnapped pregnant
wife and his minor daughter by the sex
racketeers/sex abusers State and subsequently
aggrieved by the deliberate obstruction in making
payment of Rs. 431/- against e-filed fresh Writ
Petition Criminal dated 7th
June, 2022 after
dismissal of Writ Petition (Criminal) No. 136/2016,
Writ Petition (Criminal) No. 137/2021 and Writ
Petition (Criminal) No. 242/2021 by this Hon’ble
Court and deliberate inertia to stop persistent gang
rapes and illicit sex trade of petitioner families and
their minor girl child by the nexus of state, NGOs,
gangsters, Mafias, Indian defense organizations and
general public since 18 years to till date across the
globe and deliberate bystander apathy by state to
rescue and rehabilitate them enforcing their Rights
under Article 21 of the Constitution of India.
02.05.2022 Writ Petition (Crl) No. 137/2021 dismissed by
this Hon’ble Court and directed the Petitioner to
come according to the Law.

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05.05.2022 Victims of gang rapes, illicit sex trade and child
sexual abuse rescued and departed by
Mahananda Express from Old Delhi Railway
Station to Katihar, Bihar but not being handed
over to the petitioner rather re-pushed them into
same business of flesh trade at the source point
of human trafficking at Katihar Bihar and at the
destination /transit point of Human Trafficking
at Delhi/NCR.
17.05.2022 National Commission for Protection of Child
Rights (NCPCR) accepted the case of victim
minor daughter Shriya Poddar aged about 17
years and 50 others family members including
minor girl child of petitioners family.
20.05.2022 SHO Kadwa Police Station Katihar, Bihar
illegally detained Petitioner and gang raped the
victims’ family inside his house at Sonaili
Village along with Superintendent of Police
Katihar and others.
07.06.2022 Laptop of petitioner is being damaged, password
of Supreme Court e-filing hacked by the sex
abusers state in Delhi.
08.06.2022 Gang Rapes and illicit sex trades of the victims
identified inside the common toilet of
Luxminarayan Dharamshala, Church Mission
Road, P.S. Lahori Gate, Delhi-6. 112 call has
been made with reference no. 5201138 and
5201158. Affidavit No. 4127/22 vide D.NO.
34979/22 dispatchedd through R&I to Hon’ble
the Chief Justice of India and letter for

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appointment with Registrar dispatched through
R&I vide a diary no. 34978/2022 to Registrar of
Supreme Court of India. 112 call has been made
against biased police action at Luxmi Narayan
Dharamshala, Church Mission Road, Police
Station, Lahori Gate Delhi-6 against the victims
of gang rapes and illicit sex trade vide reference
no. 5206837.
09.06.2022 A written application vide D.D.No. 23A at
12:26p.m. has been filed with Police Station
Lahori Gate Delhi-6. 112 call reference no.
5208740, 5208823, 5209010, 5209016,
5208990 and 5209461has been made against an
attempt to mob lynch the petitioner, beating
Petitioner with feast, evacuating Petitioner from
Luxmi Narayan Dharamshala by Police and
Dharamshala administration and illegal
detention of petitioner taking his all
belongings/items including mobile into the
police custody by Police In charge Police post
Church Mission Road Delhi-6 have done
medical of petitioner from Aruna Asaf Ali
Hospital, Delhi.
10.06.2022 112 call has been made against illegal detention
of Petitioner for 24 hours inside the police post
church mission road and gang rapes and illicit
sex trade of victims inside police post in front
of Petitioner’s own eyes.
Police also invited Petitioner to participate in the
gang rapes inside the AC rooms with all Luxary

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at police post church mission road, Fatehpuri,
Delhi-6
Thereafter police post Assistant Sub Inspector
Ishwar Das Roy, Rajender Soni, Chander
Kumar, Sunil Kumar, one drunk police men
unnamed and Praveen Kumar, In charge
thoroughly abused Petitioner with filthy
language.
The same has been reported to 112 call with
reference No. 5215164.
11.06.2022 112 call has been made against gang rapes and
illicit sex trade of victims inside Dharamshala
and hotels of Church Mission Road P.S. Lahori
Gate and inside the Old Delhi Railway Station
property with reference No. 5220691 and
5221720.
112 call has been made against Delhi Police for
persistent torture and harassment of Petitioner
to leave Delhi and leave Supreme Court case.
The same has been recorded by 112 reference
no. 5217267 and statement recorded by Enquiry
Officer Rajender Singh SI, Mobile no.
9910939878 old Delhi Railway Station at 5:30
a.m.
12.06.2022 112 call has been made against gang rapes and
illicit sex trade, child sexual abuse and hidden
prostitution by the sex abusers/sex racketeers
State against the victim Petitioner’s families
and their minor girl child, rescued on
05.05.2022 departed by Mahananda Express to

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Katihar, Bihar but instead of handing over to
the Petitioner again being re-pushed into the
same business of flesh trade at the source point
of human trafficking at Katihar Bihar and
transit or destination point of human trafficking
at Delhi/NCR.
The same has been recorded with reference No.
5222761, 5222864 and 5222786. Thereafter
enquiry officer Devender Singh 011-23961522
took the detail of Petitioner and his wife, minor
daughter, sister in law and their minor
daughters and father in law.
Thereafter, he introduced Petitioner in front of
SHO old Delhi Railway Station after 4 hours at
11:10 AM. SHO abused the petitioner with
filthy language and threatened of dire
consequences if any further 112 call is being
made by the Petitioner from old Delhi Railway
Station. He asked Petitioner to go to (Lal Qila)
Red Fort and Kamla Market to make 112 call
because his minor daughter and other family
members and their minor children have gone
there for illicit sex trade, gang rapes, child
sexual abuse and hidden prostitution.
He also warned the Petitioner to vacate the
premises of old Delhi Railway Station
immediately.
14.06.2022 Hence this Writ Petition Criminal is being filed.

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WRIT PETITION CRIMINAL D.NO. 18546 OF 2022
(UNDER ARTICLE 32 OF THE CONSTITUTION OF INDIA)
AND
IN THE MATTER OF PERSISTENT
GANG RAPES, ILLICIT SEX TRADE
AND CHILD SEXUAL ABUSE,
HIDDEN PROSTITUTION,
INTERNATIONAL HUMAN
TRAFFICKING/SEX RACKET,
ABUSE OF POLICE POWER,
SUSPICIOUS DEATH AND MOB
VIOLENCE/MOB LYNCHING.
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 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 Secretary
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

12
Katihar, Bihar
5. District Judge ….RESPONDENT No.05
District Court Katihar
Bihar
6. Commissioner of Police Delhi ….RESPONDENT No.06
Police Headquarters,
MSO Building, I.P. Estate,
New Delhi-110002
7. Director General of Police ….RESPONDENT No.07
Bihar Police Headquarters,
Sardar Patel Bhawan,
Nehru Marg, Patna - 800023
8. Inspector General of Police, ….RESPONDENT No.08
Darbhanga, Bihar
9. Deputy Inspector General of Police ….RESPONDENT No.09
Purnia, Bihar
10. Superintendent of Police ….RESPONDENT No.10
District- Katihar,
Bihar-854105
11.Deputy Commissioner of Police ….RESPONDENT No.11
North East District Delhi
12.Assistant Commissioner of Police ….RESPONDENT No.12
Seelampur,
13.Assistant Commissioner of Police ….RESPONDENT No.13
Delhi Cantt.
South West District Delhi
New Delhi
14.Secretary ….RESPONDENT No.14
Electricity Department
Government of Bihar
15.Chief Executive Engineer ….RESPONDENT No.15
District Katihar, Bihar
16.Junior Executive Engineer ….RESPONDENT No.16
Sub-Station Sonaili, Kadwa
17.Secretary Health Department ….RESPONDENT No.17

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Patna, Government of Bihar
18.Civil Surgeon ….RESPONDENT No.18
Health Department
19.In-charge Medical Officer ….RESPONDENT No.19
Kadwa, Primary Health Centre
Durgagunj, District Katihar
20.Sub Divisional Manager ….RESPONDENT No.20
Barsoi, Katihar
21. Sub-Divisional Police Officer ….RESPONDENT No.21
Head Quarter
District-Katihar,
Bihar- 854105
22. Sub-Divisional Police Officer ….RESPONDENT No.22
Barsoi, District Katihar,
Bihar- 855102
23.Station House Officer ….RESPONDENT No.23
Palam Village Police Station,
South West District
New Delhi
24. Station House Officer ….RESPONDENT No.24
Kadwa Police Station,
District-Katihar,
Bihar-855114
Shastri Park,
Dandkhora, Katihar
Bihar
27. Chairperson ….RESPONDENT No.27
National Commission for Protection
of Child Rights (NCPCR)
5th
Floor, Chanderlok Building,
36 Janpath, New Delhi-110001
28. Nodal Coordinator ….RESPONDENT No.28
ChildLine India Foundation
Eastern Regional Resource Centre
Kolkotta
29. Nodal Coordinator ….RESPONDENT No.29

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ChildLine India Foundation
North Regional Resource Centre
1st Floor, H. No. 144/2, Hari Nagar
Mathura Road, Ashram, New Delhi-14
30. District Coordinator …..,.RESPONDENT No.30
Child Line India Foundation
Katihar, Bihar
31. Superintendent of Police …..,.RESPONDENT No.31
Railway Old Delhi Railway Station
Delhi
32. Station House Officer, …..,.RESPONDENT No.32
Railway Old Delhi Railway Station
Delhi
33. Superintendent of Police …..,.RESPONDENT No.33
Railway Katihar, Bihar
34. Station House Officer, …..,.RESPONDENT No.34
Katihar Railway Station
Police Station, Bihar
. 35. Indian Defense Organizations …..,.RESPONDENT No.35
Sena Bhawan
Head Quarters at New Delhi
36. Chairman Railway Board …..,.RESPONDENT No.36
New Delhi
37. Divisional Railway Manager …..,.RESPONDENT No.37
38. Director …..,.RESPONDENT No.38
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
39. National Coordinator …..,.RESPONDENT No.39
B-1101, 11th
Floor, Ratan Central
Dr, Baba Saheb Ambedkar Road
Parel East, Mumbai-400012
40. District Coordinator …..,.RESPONDENT No.40

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District Samastipur, Bihar
41. Chairperson …..,.RESPONDENT No.41
National Commission for Women
New Delhi
PETITION UNDER ARTICLE 32 OF THE
CONSTITUTION OF INDIA FOR ISSUANCE
OF A WRIT IN THE NATURE OF
MANDAMUS OR ANY OTHER
APPROPRIATE WRIT FOR ENFORCEMENT
OF ARTICLE 21 OF THE CONSTITUTIION
OF INDIA.
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. FACTS OF THE CASSE:
(i) That the present Writ Petition under Article 32 of
the Constitution of India is being filed by a Social
Worker cum husband cum father cum Guardian cum
Whistle Blower cum Petitioner-In-Person; aggrieved
by the deliberate hiding out of his all near about 50
family members including his kidnapped pregnant
wife and his minor daughter by the sex
racketeers/sex abusers State and subsequently
aggrieved by the deliberate obstruction in making
payment of Rs. 431/- against e-filed fresh Writ
June, 2022 after
dismissal of Writ Petition (Criminal) No. 136/2016,

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Writ Petition (Criminal) No. 137/2021 and Writ
Petition (Criminal) No. 242/2021 by this Hon’ble
Court and deliberate inertia to stop persistent gang
rapes and illicit sex trade of petitioner families and
their minor girl child by the nexus of state, NGOs,
gangsters, Mafias, Indian defense organizations and
general public since 18 years to till date across the
globe and deliberate bystander apathy by state to
rescue and rehabilitate them enforcing their Rights
under Article 21 of the Constitution of India.
(ii) That the petitioner has apprised and briefed the grave
situation of persistent gang rapes and illicit sex trade
through affidavit no. 4127/22 dated 8th
June, 2022 and
dispatched the same to Hon’ble the Chief Justice of India
through R & I Section Counter No. 17 of Supreme Court of
India dated 8.6.2022 vide D. NO. 34979/2022 is annexed
herewith as Annexure P-1 (Page from 33 to 37)
(iii) That Petitioner has been denied to get photo entry pass
issued by counter No.41 of this Hon’ble Court to meet
Registrar J-I and apprised the grave situation of persistent
gang rapes and illicit sex trade of his families by the State
since 18 years. The petitioner has dispatched an application
for appointment with Registrar of Supreme Court of India
dated 8.6.2022 through R&I Counter No. 17 of Supreme
Court of India is annexed herewith and marked as Annexure
P-2 (page from 38 to 39)
(iv) That Petitioner’s wife Rina Kumari aged about 44 years and
minor daughter Shriya Poddar aged about 17 years have

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been kidnapped on 15.04.2005 while wife was pregnant,
with an active help of her father Surender Narayan Poddar,
Assistant Manager (RC), Brauni Refinery, Indian Oil
Corporation, Begusarai, Bihar from the house of Brajesh
Yadav a driver of Judge, resident of Gali No. 12, Raj Nagar
Part-2, Palam Colony New Delhi 77 under the
pressure/tactics of sex racketeers and pushed her into illicit
sex trade, hidden prostitution, child sexual abuse and
International Human trafficking. Petitioner came to know
this fact for the first time while he was rescuing other’s
minor girl child ‘Nikki’ from the clutches of human
traffickers in Shastri Park, North East Delhi through Writ
Petition (Criminal) 242/2021. Several police complaints
have been filed with Bihar and Delhi Police for registration
of an F.I.R, rescue, arrest, medical, charge sheet, placing
before court of Law and initiating rehabilitation process of
the victims. But no F.I.R has been registered either Delhi
Police or by Bihar Police as on date.
(v) That petitioner has seen his minor daughter Shriya Poddar
only once on 9.2.2011 at family court, Dwarka Court at
New Delhi before Principal Judge Ms. Deepa Sharma.
(vi) That 112 call has been made against the persistent Gang
Rapes and illicit sex trade of petitioner’s families inside the
common toilet of Luxmi Naraan Dharamshala, Church
Mission Road, Fatehpuri, Delhi-6 on 8.6.2022 with Ref. No.
5201138 and 5201158 dated 8.6.2022 and subsequent 112
call with Reference No. 5206837 dated 9.6.2022 against
Assistant Sub Inspector Bijendra Singh, police post Church
Mission Road, Fatehpuri, Delhi-6 under Police Station

18
Lahori Gate, Delhi-6 for his biased police action against the
victims and Complainant and for escalating gang rapes and
illicit sex trade of Petitioner’s families. An application for
registration of an F.I.R has been filed with Police Station
Lahori Gate, Delhi-6 on 9th
June 2022 vide D.D. No. 23A at
12:26p.m. The same illicit sex trade of Petitioner’s families
happened with effect from 25th
April, 2022 to 4th
May 2022
by the son of gangsters Sahabuddin inside the same
common toilet of Luxmi Narayan Dharamshala, Church
Mission Road, Fatehpuri, Delhi-6 is annexed herewith and
marked as Annexure P-3 (Page from 40 to 43)
(vii) That 112 call has been made against an attempt of mob
lynching of petitioner by sex abusers in front of Luxmi
Narayan Dharamshala at Church Mission Road, Fatehpuri,
Delhi-6 on 9th
June 2022 with reference No. 5208740,
5208823, 5209010, 5209016, 5208990 and 5209461. The
call also has been recorded for forcing the Petitioner to
vacate Luxmi Narayan Dharamshala, Church Mission Road,
Fatehpuri, Delhi-6 by the same police post policemen.
(viii) That 112 call has been made by the petitioner on
10.06.2022 with reference no. 5215164 against police post
Church Mission Road, Fatehpuri, Delhi-6 in charge Praveen
Kumar for illegally arresting/detaining him for 24 hours at
police post and gang raping, transacting illicit sex trade of
his families in front of his own eyes at police post. Same act
has been done by SHO Kadwa Katihar, Bihar along with
Superintendent of Police Katihar on 20th
May 2022 inside
his house at Sonaili Village Police Station Kadwa, Katihar,
Bihar.

19
(ix) That 112 call also have been made against Delhi Police for
harassing and not letting the Petitioner to stay at Delhi
anywhere to transact Court business at Supreme Court, New
Delhi. The 112 call recorded with reference No. 5217267
dated 11.6.2022 and statement recorded by Enquiry Officer
Old Delhi Railway Station Police Station on the same day at
5:30 a.m.
(x) That Petitioner’s sisters, sister in laws, wife and minor
daughters have been repeatedly gang raped by
Superintendent of Police Sidharth Mohan Jain
Superintendent of Police Deepak Sah, Superintendent of
Police Vikas Kumar, Superintendent of Police Jitender
Kumar, Superintendent of Railway Police, Avinash Kumar,
of Katihar and Bhagalpur.
(xi) That sex racketeers and sex abusers are taking undue benefit
of jurisdictions while in this matter, International
jurisdiction is applicable for organizing gang rapes and
illicit sex trade of victims. Sex racketeers are using Air base
of Air Force for fast movement of human trafficking from
one place to another place, using intoxicating drugs to trap
victims, using biological weapon to sustain the sex racket,
within few hours changing jurisdiction for gang rapes and
illicit sex trade of victims, getting exact information form
Government Machineries against the complaint of
Petitioner. For example 10th
June, 2022 night, victim gang
raped under the jurisdiction of Police Station Lahori Gate,
Delhi-6 and trafficked by rail at 8:00pm on 10th
June, 2022
to Katihar, Bihar and will be gang raped throughout the
journey inside the toilet of train and thereafter by

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Superintendent of Police Rail Katihar Avinash Kumar and
General Public for generating Revenue out of it.
(xii) That Magistrate of Katihar has supplied false and fabricated
documents before this Hon’ble Court and did not hand over
the victims to the Petitioner rather re-pushed the rescued
victims into the same business of flesh trade at the source
point of human trafficking at Katihar Bihar and at the transit
or destination point of human trafficking at Delhi/NCR.
(xiii) That Petitioner is not being allowed to know the
whereabouts of victims till date, not being allowed to meet
the victims till date. The State has not initiated the
rehabilitation process of victims either within the State
owned institutions like Women shelter homes, observation
homes for children or within the family so far.
(xiv) That situation is alarming because Life and Liberty of
Petitioner is at stake and he has been thrown out on the
street of Delhi by the sex abusers State Center NGOs
Gangsters Mafias Indian Defense Organizations and
General Public.
(xv) That Petitioner has filed Criminal Writ Jurisdiction Case
No. 1238/2019 before Patna High Court against the abuse
of Court process; which is still pending.
(xvi) That Petitioner has been engaged in abuse of Court process
on the one hand and sexual abuse, illicit sex trade of his
families by the sex abusers center and state on the other
hand.
(xvii) That both the parents of Petitioner have been killed by the

21
sex abusers in 2007 and 2017 respectively in Bihar and
Delhi jurisdiction.
(xviii)That abuse of court process misled towards the wrong cause
of action like divorce, domestic violence and 498A, dowry
prohibition matter while the actual matter was International
sex racket, hidden prostitution, Child Sexual Abuse, illicit
sex trade of the families of Petitioner by the State and
Central Government since 2005 for generating Revenue out
of it.
(xix) That 112 call has been made with reference No. 5220691
dated 11.6.2022 to stop gang rapes of victims in the Hotel
and Dharamshala under the jurisdiction of P.S. Lahori Gate,
Church Mission Road, Fatehpuri, Delhi-6. But police did
not take any action and escalated illicit sex trade of victims.
No police raid and rescue of the victim is being made by the
police as on date.
(xx) That 112 call again has been made by the Petitioner with
reference No. 5221720 dated 11.6.22 to stop gang rape and
illicit sex trade of victims inside the premises of old Delhi
Railway Satation. As usual police did not take any action
rather escalated gang rapes, illicit sex trade of victims.
Victims are under the police custody illegally, yet police
pretend to show unawareness against the whereabouts of the
victims till date.
(xxi) Police are playing tactics of handing over the victims to
human traffickers cutting across caste, creed and
Nationality to sustain persistent gang rapes and illicit sex
trade of victims across the globe.

22
(xxii) That fresh cause of action arose in both the state Bihar as
well as in Delhi with effect from 6th
May 2022 to till date.
2. QUESTIONS OF LAW:
i) Whether or not despite of receiving information disclosing
cognizable offence of gang rapes and illicit sex trade of
victims; F.I.R has not been registered by Delhi Police
under Section 154(1) or Section 157(1) of Cr.Pc. while
the victim pregnant wife of Petitioner kidnapped from
Police Station Palam Village New Delhi jurisdiction on
15.04.2005 is arbitrary, illegal and void action by Police?
ii) Whether or not non registration of an F.I.R and not placing
the victims before the court of law by the police indicates
their own vested interest of sustaining gang rapes and
illicit sex trade of victims frequently changing their
jurisdiction by human traffickers is arbitrary, illegal and
void?
iii) Whether or not hiding out of the whereabouts of victims, re
pushing them into flesh trade, illicit sex trade and not
allowing the Petitoner to meet the victims is violating
Rule of Law and Principles of Natural Justice and
Principles of Social Work?
3. GROUNDS:
Aggrieved by the biased police action dated 20th
May 2022 by
Bihar Police and 8th
June 2022 to 12th
June 2022 by Delhi
Police, the same is being challenged on these following
amongst other grounds:

23
A. BECAUSE persistent Gang Rapes and illicit sex trade of
victims, changing jurisdiction frequently need to be stopped
immediately.
B. BECAUSE rehabilitation process of victims to be initiated
immediately to begin a dignified life for the victims.
C. BECAUSE e-filed Writ Criminal Petition dated 7th
June
2022 contains all details with complete evidence to be made
part of this petition in the furtherance of justice.
D. BECAUSE hidden status of victims encouraging illicit sex
trade and persistent gang rapes by the state and General
Public and discouraging rescue and rehabilitation of victims.
E. BECAUSE Center and State are bidding and selling the
victim’s Body to the General Public for generating Revenue
out of it.
F. BECAUSE technologies like Jammer Mobile services,
artificial rain supporting gang rapes and illicit sex trade,
hidden cameras and chip inside the body of animals and
birds for surveillance of gang rapes and illicit sex trade, use
of Air Force Air base for fast moving of victims from one
place to another place, electricity disconnection by the State
for organizing gang rapes and illicit sex trade, use of
defense, Police, judiciary, advocates, executives,
legislatures, media to sustain this technology based sex
Industry.
G. BECAUSE hidden status of victims are creating anxiety,
suspicion and mental imbalances in the mind of Petitioner.
H. BECAUSE State & General Public are snatching,

24
scratching and eating the body of victims like dogs and
birds.
I. BECAUSE pregnant wife Reena Kumari kidnapped on 15th
April 2005 by the sex abusers and never came back till date,
caught with illicit sex trade, hidden prostitution in 2021 at
Sonaili, Katihar, Bihar at brothel of Gulab Bagh and
Varanasi, Uttar Pradesh.
J. BECAUSE Petitioner cannot see persistent gang rape and
illicit sex trade of his own families in front of his own eyes
rather will prefer to finish him.
K. BECAUSE Petitioner is looking for his own end, not the
end of sex racket run by Government of India.
L. BECAUSE wife Rina Kumari of Petitioner has not filed
written statement in HMA 700 of 2010 case before family
court, Dwarka Court, at New Delhi under the pressure of
Human traffickers and sex abusers.
M. BECAUSE it was the sex abusers and sex racketeers who
created Hoax, engaged Petitioner into abuse of court
process, taken hostage the Petitioner and his whole family to
ruin the married life of Petitioner for their own vested
interest.
N. BECAUSE jurisdiction is the root cause of escalating
human trafficking from one place to another place.
O. BECAUSE jurisdiction is safety belt for human traffickers.
P. BECAUSE Petitioner father have seen his minor daughter
Shriya Poddar for the first time on 9th
February, 2011 at

25
family court Dwarka Court at New Delhi. Thereafter, he has
caught his daughter with child sexual abuse in 2021 at
Shastri Park, North East Delhi and Sonaili Police Station:
Kadwa, Katihar Bihar.
4. AVERMENT
i) That the present petitioner has not filed any other
petitions in any High Court or the Supreme Court
of India on this subject matter of the present
petition.
ii) That the Petitioner does not have any alternative
and efficacious remedy for enforcement of
fundamental rights of victims of gang rapes, illicit
sex trade and child sexual abuse.
iii)However, the petitioner has filed Writ Petition (Civil)
90 of 2016, Writ Petition (Criminal) 136/2016, Writ
Petition (Criminal) 136/2016, Writ Petition (Criminal)
137/2021 and Writ Petition (Criminal) 242/2021 before
this Hon’ble Court in different interlinked subject
matter.
PRAYER
In the above premises, it is prayed that this Hon'ble Court may be
pleased:

26
(i) To issue a writ of mandamus or other appropriate writ order
or direction directing respondent No.01 to 08 to direct to
concern SHOs of Delhi and Bihar Police to register an F.I.R
against the complaints of petitioner made since 2011 to till
date.
(ii)To issue a Writ of mandamus or other appropriate writ
order or direction directing respondent No.01 to 41 to direct
to concern authorities to rescue, arrest, medical, charge
sheet, place before the court of law and initiate the
rehabilitation process of victims immediately.
(iii) To issue a writ of mandamus or other appropriate
writ order or direction directing respondent No. 01 to 41 to
allow the Petitioner to know whereabouts of the victims and
allow him to meet the victims for Social Work intervention,
counselling and data collection.
(iv) To allow the Petitioner to make payment of Rs. 431/-
against e-filed Writ Petition (Crl) D.No. 18546 of 2022 dated
7th
June, 2022.
(v)To list this matter urgently before the Vacation Bench to
stop persistent gang rapes and illicit sex trade of families and
minor girls of Petitioner and rescue and rehabilitate the
victims immediately.

27
(vi) To issue death Warrants against guilty public
authorities to hang to death, whatsoever, indulged in this
matter.
(vii) To order for medical examination of DNA testing for
matching blood relationships with Petitioner father, HIV,
STI, reproductive health status of victims, uterus status of
victims, sexual health status of victims by multiple medical
health Institute across country to avoid falsehood.
(viii) 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.
(ix) 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.
(x)To remove the jurisdictional barrier in the case of Human
Trafficking and illicit sex trade to wipe out it from the earth

28
and save other innocent families from ruining like the
Petitioner.
Pass such other order/orders as this Hon'ble Court may deem
just and proper in the facts and circumstances of the case.
PETITIONER-IN-PERSON
OM PRAKASH
S/O LATE SHRI DEEP NARAYAN PODDAR
S/O LATE SRIMATI ASHA RANI DEVI
PERMANENT RESIDENT: ASHA DEEP NIWAS,
SONAILI, SHUKKAR HATT,
IN FRONT OF DURGA MANDIR,
KANTIYA PANCHAYAT,
P.S. KADWA, KATIHAR, BIHAR-855114
MOB: 9540389759
E-mail: om.poddar@gmail.com
NEW DELHI:
FILED ON : 14-06-2022

29
WRIT PETITION CRIMINAL D. NO.18546 OF 2022
AND
INTERNATIONAL HUMAN
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.

30
2. That the contents of the accompanying Criminal Writ
Petition under Article 32 of Constitution of India against the
persistent gang rapes, illicit sex trade and International
human trafficking/Sex Rackets which has been drafted by
me [para 01 to 04], [Page 01 to 30 ] and Synopsis and List of
Dates (Page B to J ], 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 to P- 03 [Page 33 to 43] are true
copies of their respective original.
4. That the Criminal Petition Paper Book contains total pages
50’
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 14th
day of June, 2022.
DEPONENT

31
Annexure P-1
WRIT PETITION CRIMINAL NO. OF 2022
WITH
WRIT PETITION CRIMINAL NO. 136 OF 2016
WITH
WITH
AND
GANG RAPES, AND ILLICIT SEX
TRADE OF FAMILIES AND
CHILDREN OF PETITIONER SINCE
18 YEARS.
AND
IN THE MATTER OF:
VERSUS
To
Hon'ble the Chief Justice of India and His
Lordship's Companion Justices of the Supreme
Court of India.
AFFIDAVIT
MOST RESPECFULLY SHOWETH THROUGH AFFIDAVIT:
I do hereby solemnly showeth that:-

32
1. That Petitioner has filed W.P (Crl.) 136/2016, W.P (Crl.)
137/2021 and W.P (Crl.) 242/2021 against the criminal act
of Judges, Advocates, Police, NGOs, Government officials,
defense personnel, and legislatures but all have been
dismissed.
2. That Petitioner’s wife Rina Kumari age 44 years has been
kidnapped with an active help of his father on 15.04.2005
from the house of Mr. Brajesh Yadav, a driver of Judge R/O
Gali No. 12, Raj Nagar Part-2, Palam Colony, New Delhi-
77.
3. That petitioner’s (OM PRAKASH) Present address is Asha
Deep Niwas, Shukkar Hatt, Sonaili, P.S.Kadwa, district
Katihar, Bihar-855114 and R/O RZF-893, Netaji Subhash
Marg, Raj Nagar Part-2, Palam Colony, New Delhi-77, S/O
Late Deep Narayan Poddar, ageabout 48 years.
4. That Magistrate of Katihar has placed false and fabricated
documents before this Hon’ble Court and re-pushed the
victims of Gang Rapes and illicit sex trade into the same
business of flesh trade w.e.f. 06.05.2022 to till date at the
source point of human trafficking at Sonaili, Katihar, Bihar

33
and the destination/transit point of human trafficking
Delhi/NCR.
5. That petitioner father has been killed by sex abusers in 2007
at Sonaili Katihar Bihar and mother has been killed in 2017
in Palam Colony New Delhi.
6. That Petitioner has been thrown out of Delhi and Bihar
House and has become homeless on the road.
7. That electricity of House of petitioner has been disconnected
since 2011 for gang rapes and illicit sex trade of his families
and children by the nexus of State, NGOs, Mafias,
Gangsters, Indian defense organizations and general public.
8. That petitioner has filed number of cases (Writ Criminal)
before this Hon’ble Court and number of police complaints
with Bihat as well as Delhi Police since 2011 to till date. Yet
no F.I.R and no action against the powerful accused so far.
9. That petitioner is trying to e-file the fresh Criminal Writ
from Katihar Bihar dated 4.6.22 but sex abusers putting off
the electricity, extracting data from the charging point of Lap
Top, damaging Lap Top, hacking password , stealing daily
diary and hence putting several obstruction on the way of

34
petitioner, Supreme Court filing counter did not allow to
meet Registrar or Branch officer E-filing on 7.6.22. Branch
Officer E-filing phone No. 011-23115949 and 1881 are not
functioning and not responding the Petitioner since 7.6.22 to
till date.
10.That Petitioner has filed a fresh Writ Petition Criminal
against the persistent Gang Rapes and illicit sex trade of his
families and children on 7.6.22 (7th
June 2022) at 05:00 AM
from Anand Vihar Railway Station Delhi/NCR but OTP for
Rs. 431/- against the petition has not been supplied to the
petitioner thereafter his Lap Top been damaged, password
hacked by the sex abusers. However, transaction ID with
error has been supplied to the petitioner. Matter may be
investigated by registering an F.I.R against this event.
11.That aggrieved by the Criminal Act of Center, State &
Government of India, Petitioner has called 112 again on 8th
June, 2022 at 7:04 AM from “Luxmi Narayan Dharamshala,
Church Mission Road, Fatehpuri, Delhi 110006”.
Followings are reference numbers of 112 call:-

35
a) Ref. NO. 5201138 (police women) dated 8th
June 2022 at
7:04:23 AM
b) Ref. NO. 5201138 (Petrol Vehicle SGR66 Mob
9311923466)
c) Ref. NO. 5201158 (Police PCR Patrol Vehicle ZBR20
Mob 9311923220)
12.That thereafter ASI Bijendra Singh is being deputed by PCR
at Luxmi Narayan Dharmshala, Church Mission Road,
Fatehpuri Delhi-6
13.That thereafter ASI Bijendra Singh took the Petitioner at
Police Post Church Mission Road, Police Station Lahori
Gate Delhi-6, 011-23830880, 011-23953776, 011-23958234
at 8:00 AM on 8th
June 2022. He took the details from the
Petitioner and Gang Rapes continued inside “Luxmi Narayan
Dharamshala Church Mission Road, Fatehpuri Delhi-6
14. That Petitioner is praying from you either to kill him or
otherwise Petitioner will continue his fight against illicit sex
trade till his death.

36
15.That allow the Petitioner to make payment Rs. 431/- against
the e-filed fresh Criminal Writ Petition dated 7th
June 2022
at 5:00 AM from Anand Vihar Railway Station IP address.
16.That Petitioner will wait at Luxmi Narayan Dharmshala for
your response NOTICE over telephone only till you send the
information/ response/NOTICE.
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.
day of June, 2022.
DEPONENT
True Copy

37
Annexure P-2
To
The Registrar
Supreme Court of India
New Delhi
Sub: Appointment to apprised/brief against Persistent Gang Rapes
and illicit sex trade of near about 50 female members and their
Children of Petitioner after dismissal of W.P.(Crl.)136/2016,
137/2021 and 242/2021 by this Hon’ble Court-reg.
Sir/Madam,
1. That Petitioner-in-Person is OM PRAKASH S/O Late Deep
Narayan Poddar, R/O Asha Deep Niwas, Shukkar Hatt,
Sonaili, P.S.Kadwa, district Katihar, Bihar-855114 and R/O
RZF-893, Netaji Subhash Marg, Raj Nagar Part-2, Palam
Colony, New Delhi-77, age about 48 years, presently putting
up at Luxmi Narayan Dharamshala, Church Mission Road,
Fatehpuri, Delhi-110006 since 7.6.2022
2. That petitioner is seeking appointment with Hon’ble the
Chief Justice of India through Registrar J-1 of Supreme
Court of India to apprise facts against persistent Gang Rapes
and illicit sex trade of his 50 family members by the nexus
of State, Gangsters, NGOs, Indian Defense Organizations
and general public since 18 years.

38
3. That Petitioner has filed W.P. (Crl.)No…….. of 2022 with
W.P. (Crl.)No. 136/2016 with W.P. (Crl.)No. 137/2021 with
W.P. (Crl.)No. 242/2021 through e-filing system of this
Hon’ble Court on 7th
June 2022 at Anand vihar Railway
Station’s IP address at 5:00AM but OTP for payment of Rs.
431/- has not been sent to the petitioner, thereafter damaged
his Lap Top, hacked password, disconnected electricity of
his house since 12 years, closed the door of Supreme Court
of India, closed the door of Bihar Police as well as Delhi
Police by the sex abusers.
4. That Petitioner has become handicapped and compelled
either to accept Gang Rapes or to die hard.
5. That under this circumstances, Petitioner wants to hand over
Affidavit No.4127/22 dated 8th
June 2022to Hon’ble the
Chief Justice of India through Registrar J-1 of Supreme
Court of India, New Delhi. Photo entry pass denied by this
Hon’ble Court on 8th
June 2022 at counter no. 41.
6. Affidavit dispatched through R&I counter no. 17 of
Supreme Court of India on 8.6.2022.

39
7. That Affidavit contains the details of 112 PCR Call to Delhi
Police dated 8.6.22 by the Petitioner.
NEW DELHI OM PRAKASH
DATE:8.6.22 S/O Late Deep Narayan Poddar
Luxmi Narayan Dharamshala
Church Mission Road
Fatehpuri Delhi-110006
True Copy

40
Annexure P-3
To, D.D.NO.23A AT 12:26PM
The SHO Dated: 09.06.2022
Lahori Gate
Police Station
Delhi-110006
Sub: Complaint against biased Police action with reference to 112
call dated 9.6.22 ref. no. 5206837 against persistent Gang Rapes
and illicit sex trade of applicant’s near about 50 families and their
children-reg.
Sir/Madam,
1. That applicant is OM PRAKASH S/O Late Deep Narayan
Poddar, R/O Asha Deep Niwas, Shukkar Hatt, Sonaili,
P.S.Kadwa, district Katihar, Bihar-855114 and R/O RZF-
893, Netaji Subhash Marg, Raj Nagar Part-2, Palam Colony,
New Delhi-77, age about 48 years, presently putting up at
Luxmi Narayan Dharamshala, Church Mission Road,
Fatehpuri, Delhi-110006 P.S. Lahori Gate Police Post
Church Mission Road, Delhi-6 for e-filing W.P.
(Crl.)No…….. of 2022 with W.P. (Crl.)No. 136/2016 with
W.P. (Crl.)No. 137/2021 with W.P. (Crl.)No. 242/2021
before Supreme Court of India.
2. That W.P. (Crl.)No…….. of 2022 against persistent Gang
Rapes and illicit sex trade of families of applicant has been
filed on 7th
June 2022 at 5:00AM from Anand Vihar Railway
Station’s IP address. However, OTP for payment of Rs.

41
431/- has not been supplied by the Supreme Court of India
thereafter Lap Top being damaged, password being hijacked,
applicant put on surveillance by sex abusers, door of
Supreme Court of India being closed, door of Home
Ministry being closed and door of Delhi as well as Bihar
Police being closed by the sex abusers.
3. That applicant has called 112 on 11.11.2017 thereafter on
8.6.2022 and 9.6.2022 ref. no. 5201138 and 5201158 dated
8.6.22 and ref no. 5206837 dated 9.6.22 has been recorded
by Delhi Police.
4. That applicant has dispatched Affidavit No. 4127/2022 vide
D.No. 34979/2022 to Hon’ble the Chief Justice of India
through R&I Section counter no. 17of Supreme Court of
India.
5. That applicant has also dispatched a letter for an
appointment to meet Registrar J-1 and Hon’ble and Hon’ble
the Chief Justice of India vide D.NO. 34978/2022 dated
8.6.22 through R&I section counter no.17 of Supreme Court
of India.
6. That E.O. Shri Bijendra Singh, Police Post Church Mission
Road, Fatehpuri, Delhi-6 illegally detained at Police Post,
took details but escalated Gang Rapes and illicit sex trade of

42
families of applicant. No F.I.R registered, No copy of F.I.R
supplied.
7. That Magistrate of Katihar Bihar has re-pushed the rescued
victims of Gang Rapes and illicit sex trade from Delhi into
the same business of flesh trade at the source point of human
trafficking at Katihar Bihar & transit/destination point of
human trafficking at Delhi/NCR.
8. That aggrieved by this Criminal Act of State, NGOs,
Mafias, Gangsters, Indian Defense organizations and general
public, applicant has approached to Supreme Court of India
with fresh Criminal Writ making 40 Government officials as
parties including Delhi and Bihar.
9. That however, applicant has been shown the naked dance of
Judiciary, Executives, legislatures and Media at New Delhi
w.e.f. 6.6.2022 to till date by the sex abusers.
10.That Justice S.B.Sinha of Supreme Court of India and
Praveen Kumar from Indian Defense Account Services are
the main accused for pushing applicant’s families into illicit
sex trade since 18 years.
11.That Justice S.B.Sinha kidnapped applicant’s wife while she
was pregnant from Shri Brajesh Yadav’s house at Gali

43
No.12, Raj Nagar Part-2 Palam Colony New Delhi-110077
on 15.04.2005.
12.That applicant’s wife Rina Kumari age 44 years has been
kidnapped on 15.04.2005 with an active help of her father
Surender Narayan Poddar, Assistant Manager (RC), Barauni
Refinery, IOCL, Begusarai Bihar.
13.That Justice S.B.Sinha is the first point to sexually abuse
applicant’s wife thereafter by others sex abusers in India.
14.That applicant father has met his 6 years old daughter Shriya
Poddar for the first time at Principal Judge Ms. Deepa
Sharma, Family Court, Dwarka Court at New Delhi on 9th
February 2011. Judge allowed to meet minor daughter in
children room for 3 hours. Applicant has taken snaps of his
minor daughter which have been submitted online to Child
Line and NCPCR on 16.05.2022. The Order dated 9.2.2011
is also attached with child line and NCPCR.
15.That the same order dated 9.2.2011 of Family Court Dwarka
Court at New Delhi and minor daughter’s snaps have been
diaried by Chief Secretary Bihar vide ref. no.3191 dated
3.6.22
16.That under the above circumstances take stern action against
the concerned guilty Public authorities for escalating Gang

44
Rapes & illicit sex trade of applicant’s families & their
children.
Delhi OM PRAKASH
Date: 9.6.2022 S/O Late Deep Narayan Poddar
Luxmi Narayan Dharamshala
Church Mission Road
Fatehpuri Delhi-6
Mob: 9540389759
True Copy

45
CRL.M.P.NO. OF 2022
IN
AND
INTERNATIONAL HUMAN
AND
IN THE MATTER OF:
VERSUS
APPLICATION FOR SEEKING PERMISSION TO APPEAR
AND ARGUE THE WRIT 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. The the present Writ Petition under Article 32 of the
Constitution of India is being filed by a Social Worker
cum husband cum father cum Guardian cum Whistle
Blower cum Petitioner-In-Person; aggrieved by the
deliberate hiding out of his all near about 50 family
members including his kidnapped pregnant wife and his

46
minor daughter by the sex racketeers/sex abusers State and
subsequently aggrieved by the deliberate obstruction in
making payment of Rs. 431/- against e-filed fresh Writ
June, 2022 after dismissal of
Writ Petition (Criminal) No. 136/2016, Writ Petition
(Criminal) No. 137/2021 and Writ Petition (Criminal) No.
242/2021 by this Hon’ble Court and deliberate inertia to
stop persistent gang rapes and illicit sex trade of petitioner
families and their minor girl child by the nexus of state,
NGOs, gangsters, Mafias, Indian defense organizations and
general public since 18 years to till date across the globe
and deliberate bystander apathy by state to rescue and
rehabilitate them enforcing their Rights under Article 21 of
the Constitution of India, 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 any Advocate against this
Writ Petition (Criminal) No. ………of 2022 even if so provided
by this Hon’ble Court because he is victim of malpractices by
Advocates and abuse of court process by Judges which has resulted
in Writ Petition (Criminal) 136/2016 before this court and Criminal
Writ Jurisdiction Case No. 1238/2019 before Patna High 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

47
It is most respectfully prayed that this Hon’ble Court may be
pleased to:
(a) Kindly permit the Petitioner to appear and argue the Writ
Petition (Criminal) in-person.
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:
PETITIONER-IN-PERSON
OM PRAKASH
S/O LATE SHRI DEEP NARAYAN PODDAR
S/O LATE SRIMATI ASHA RANI DEVI
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 : 14-06-2021
Diary No.:

48
AND
INTERNATIONAL HUMAN
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, P.S. Kadwa, Distt-Katihar, Bihar-855114 and Rented R/O
RZF-893, Netaji Subhas Park, Raj Nagar Part-2, Palam Colony
New Delhi-77, 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.

49
6. That the contents of the accompanying application Under
Section 151 C.P.C. for seeking permission to appear and
argue the Writ Petition (Criminal) in person, which has been
drafted by me [para 01 to 03], [Page 44 to 48] 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 Under Section 151
C.P.C. for permission in person total pages 08 .’
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.
day of June, 2022.
DEPONENT

Writ Petition Criminal diary no. 18546 of 2022 Part-II .pdf

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Writ Petition Criminal diary no. 18546 of 2022 Part-II .pdf