Application for Additional documents.pdf

APPLICATION U/S 151 OF C.P.C ON BEHALF OF THE PETITIONER FOR SEEKING PERMISSION TO TAKE ADDITIONAL DOCUMENTS, FACTS, GROUNDS AND PRAYER TO ANSWER THE QUESTION OF LAW RAISED IN THIS PETITION FOR CONSIDERATION OF THIS HON’BLE COURT.

1. IN THE SUPREME COURT OF INDIA
CRIMINAL ORIGINAL JURISDICTION

CRL.M.P.NO. OF 2022

IN
WRIT PETITION CRIMINAL D.NO.18546 OF 2022
(UNDER ARTICLE 32 OF THE CONSTITUTION OF INDIA)
AND
IN THE MATTER OF SUPRESSION
OF RESCUE OF GANG RAPE ,
ILLICIT SEX TR ADE, CHILD
SEXUAL ABUSE VICTIMS AND
ABUSE OF POWER BY THE STATE,
NGOS, GANGSTERS AND INDIAN
DEFENSE ORGANIZATIONS
AND

IN THE MATTER OF:

OM PRAKASH ..PETITIONER

VERSUS

UNION OF INDIA & ORS …….RESPONDENT(S)


APPLICATION U/S 151 OF C.P.C ON BEHALF OF THE PETITIONER
FOR SEEKING PERMISSION TO TAKE ADDITIONAL DOCUMENTS,
FACTS, GROUNDS AND PRAYER TO ANSWER THE Q UESTION OF
LAW RAISED IN THIS PETITION FOR CONSIDERATION OF THIS
HON’BLE COURT.

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:

2. 1. The present Writ Petition under Article 32 of the
Constitution of India is being filed by a Professional
Social Worker cum Petitioner-In-Person cum Whistle
Blower cum husband cum Father cum Guardian of Gang
Rapes, hidden prostitution, illicit sex trade, child sexual
abuse and international human trafficking victims whose
rescue has been suppressed by the dismissal of PIL Writ
Petition (Criminal) 242 of 2021 on 25.10.2021 and
individual Writ Petition (Criminal) 137 of 2021 on
02.05.2022 by this Hon’ble Court to continue Gang Rapes,
hidden prostitution, illicit sex trade, child sexual abuse and
international human trafficking and for the enforcement of
the 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. That Victims brought to Bihar on 06.05.2022, not being
kept in State Women Shelter homes, Observation homes for
Children, not being informed about the Victims, not being allowed
to meet the victims and continued the Gang Rape and illicit sex
trade of the victims during the course of matter Sub-judies before
the Supreme Court of India.

3. That Sex abusers are trying their best to infuse the message
of female feticide in the mind of every father by doing all kind of
non-sense. If this case is not being addressed properly then it may
encourage the female feticide in the society and may have serious
impact on the sex ratio issue of the Country.

3. 4. That cause of actions arising every day in the midst of Sub
Judies anti-prostitution matter before the Supreme Court of India.
Sex abusers are taking frequent attempt to break the petitioner
down, crush him down to earth and threaten him to withdraw the
case. However, Petitioner has reported all the cause of actions
arose between 06.05.2022 to 26.08.2022 to all the Nodal
authorities of State and Central Government including Supreme
Court of India on day to day basis through email and Court e-filing
systems.

5. That after dismissal of anti-prostitution PIL Writ Petition
(Criminal) No. 242/2021 on 25.10.2021, individual Writ Petition
(Criminal) No.137/2021 on 02.05.2022 and pending Sub Judies
anti-prostitution Writ Petition (Criminal) D. No. 18546/2022 since
14.06.2022, the petitioner has been constantly and thoroughly
abused by the sex abusers. Sex abusers has continued and persisted
the Gang Rape of families of petitioner during the Sub Judies
matter before Supreme Court of India, obstructed him in rescue
operation, assaulted him physically causing him severe pain
internal injury at Sonaili, Katihar Bihar and Church Mission Road,
Fatehpuri, Old Delhi for number of times, yet no FI.R by Police.

6. That Sex abusers disconnected the electricity of House
since 2011 to till date to Gang Rape families, compelled to leave
house and walk down on the street at the midnight keeping fast for
whole night, forced to withdraw the case, shown forceful religious
conversion, infused and inculcated message of female feticide in
the mind, manifested number of arbitrary actions by causing
jurisdictional error, infringed “Life and Liberty” by issuing two

4. Non-Bail able Warrants and keeping it secret for decades,
confiscated property by declaring a Proclaimed Absconder (PO),
detained illegally to Gang Rape families number of times, attacked
Livelihood, attacked SBI Bank, attacked Pension account, attacked
Salary account, attacked on health and caused artificial diabetes
disease, made enemy of all relatives, families, friends, circles,
thrown Cobra Snakes inside house, thrown garbage inside house,
sown seeds of thorny fast growing painful grass plants inside
house, created hoax situations to mesh everything, spread out
myths and suppressed truth, distorted basic social fabrics, reversed
all fundamentals, concepts, theories and practices, diluted facts,
confused the state of mind, diverted attention, misdirected
Behavior Change Communication (BCC), misled in wrong
direction, pushed and increased blood pressures high through
manifesting irritating behaviors, activities and presenting indecent
proposals, spread out hatred amongst each other, tempered the
evidences, evaded the rule of law, pelted stone, planted bomb
inside house, assaulted physically, tortured mentally, stigmatized
socially, boycotted socially, attacked property, encroached and
ploughed agricultural land, ransomed crops, pressurized to sale
families, minor daughter for illicit sex trade and hidden
prostitution, pressurized to accept child marriage for unseen
abducted minor daughter, attempted to infiltrate into house causing
severe damage and loss to the Property, asserted possessiveness on
the petitioner on behalf of his kidnapped, abducted, hostage,
sexually abused families including his minor daughter and wife,
indiscriminate gun fired in front of house, penetrated into the
privacy through sex technologies, gang raped families in front of
eyes, trespassed house breaking the lock of the main gate to kill,
insulted, abused, spitted on the face and passed filthy remarks on

5. the street, instigated for violence, Gang Raped families roping in
front of family, misused technologies indiscriminately, obstructed
ground zero reporting through technological attack on Lap Top and
internet, created blood boiling situations and instigated to commit
suicide, obstructed the way to the Supreme Court, team of
professionals and paid workers being hired to harass, torture,
malign, obstruct, defeat and discourage the anti-prostitution drive
and reinforced the pro-prostitution drive of State. Events of
physical assault on petitioner by the Sex Abusers taken place on
the following day, date, time and place; yet NO F.I.R by police:

i) Petitioner is being physically assaulted by sex abuser
on 11.05.2022 at 02:00AM midnight in front of his house at
Bihar. Petitioner protested against the ill practices of
delinquent state and International mafia on 11
th
May 2022
night at 2:00 AM at a Gang Rape Stage Show in Bihar. The
stage show and Gang Rape events were organized in front of
his Sonaili, Shukkar Hatt, Katihar, Bihar house behind a
Mosque. In retaliation of protest, petitioner is being thrashed
by the crowd of the sex abusers (state& mafia) and beaten
badly with shoes and frisk on head and mouth causing injury
and severe pain in his right ribs. Snatched his golden chain
and money worth Rs. 10,000/-. Broken his sleepers and
shirts. Petitioner approached Sadar Hospital Katihar for
availing emergency medical services, Sadar Hospital Katihar
attended the petitioner vide registration number 2529 dated
12/05/2022. However, the Medico Legal Case (MLC) is
being denied by the doctors and medical prescription along
with daily diary being stolen by the sex abusers cum railway

6. vendor Kedar Paswan at Dandkhora Railway Station in
Katihar Bihar. The same has been informed to all the nodal
officers of Bihar as well as Delhi Police. Mr. Virender, an
Inquiry officer has been appointed by Delhi Police CCTNS
Admin in this case. The complaint no. 50000046782203202
dated 12-05-2022 PIS No.28820336 mobile no. 9013248152
is allotted against it, yet no F.I.R.

ii) Petitioner is being physically assaulted by sex abuser
on 23.05.2022 at 11:00AM in front of One India Family
Mart Katihar. A Bengali woman human trafficker and Mr.
Sumit Kumar Child Line Coordinator Katihar Bihar attacked
him violently while he was stopping trafficking of minor
girl. He is being thrashed, beaten with feast, shirt being torn
and caused him internal injury by a group of human
trafficker, sex abusers in a protest against trafficking and
gang raping of minor girl. The same is being informed to
Delhi as well as Bihar police in writing, yet no F.I.R.

iii) Petitioner is being physically assaulted by a group of
sex abuser on 09.06.2022 at 17:06:26PM in front of Luxmi
Narayan Dharamshala at Church Mission Road, Fatehpuri,
Delhi-6. Physical injury has been caused to the petitioner in
a protest against illicit sex trade of his families inside the
toilet of Luxmi Narayan Dharamshala. The same has been
reported to Delhi Police by 112 call registered with reference
No. 5208740, 5208823, 5209010, 5209016, 5208990 and
5209461 dated 09.06.2022. An application for registration of
an F.I.R has been filed with Police Station Lahori Gate,

7. Delhi-6 dated 9
th
June 2022 vide D.D. No. 23A at 12:26p.m.
112 call at 19:19pm ref.no. 5260904 at 19:23:31pm PCR
Patrol Vehicle ZBR20 Mobile no. 9311923220, I.O. Name:
Mukesh Kumar, mobile no. 9868365047, SHO Palam
Village New Delhi mobile no. 7065036227. Medical of
petitioner has been conducted at Aruna Asaf Ali Hospital,
Delhi at 9:30pm dated 9.06.2022 by Head Constable Ajay
Kumar and Om Prakash, Police Post Church Mission Road
under Lahori Gate Police Station Delhi.

iv) Superintendent of Police Katihar has again Gang
Raped the families of petitioner on 02.07.2022 inside his
house Asha Deep Niwas, Shukkar Hatt, Sonaili, Katihar
Bihar which has resulted in 112 call with reference no. 8206
at 21:19:28pm dated 02.07.2022. Same thing happened
earlier between 28.02.2016 to 06.03.2016. The same has
been reported and culminated in W.P.(Civil) 90/2016,
W.P.(Criminal) 136/2016 and W.P.(Criminal) 137/2021. In
retaliation of 112 call, Superintendent of Police has
organized a grand Gang Rape, Vulgar DJ dance with
indiscriminate gun firing and illicit sex trade events
throughout the district which has compelled the petitioner to
leave his house in the midnight of 3
rd
July 2022. He has
protested by walking down on the street for about 12
kilometers keeping fast for whole night.

v) Petitioner is being physically assaulted by a group of
sex abuser on 07.08.2022 at 11:45AM in front of his house
at Bihar. This has been done in a protest by the petitioner
against the illicit sex trade of his families by the sex abusers.

8. The same has been reported to police, yet no F.I.R by police.
Around 12:33:02PM dated 07.08.2022, petitioner informed
the Bihar as well as Delhi Police through mobile SMS, “two
sex abusers rapists of my prostitute families attempted to kill
me, hit on my head, face, mouth by feast, broken mobile
charger, torn shirts, snatched/pickpocketed 1000/-bucks on
behalf of Superintendents of Police Katihar Sidharth Mohan
Jain, Vikash Kumar, Jitender Kumar, Avinash Kumar,
businessman Sunil Bubna, Sanjay Birwa (Jain), Manthu
Dokania, Arun Dokania, Advocate Birender Singh and all
Marwari, Jain, Rajput, Sah, Muslims and other communities
of Sonaili Salmari Katihar Bihar at 11:45am dated
07.08.2022 in front of my Asha Deep Niwas, Shukkar Hatt.
SHO Kadwa being informed over mobile for MLC case. No
action by Police so far”.

7. That the cause of actions arose from 27.08.2022 to till date
are as follows:-
i) Sex abusers infused and inculcated the message of female
feticide and the importance of “Sex Determination Test”
in the mind of petitioner and society,

ii) Suspected case of Child Sexual abuse/Child Marriage
being identified in the neighbor misusing a tool of
Eloping a girl child with an active help of administration.
Victim is a daughter of Mr. Shukra Rai R/O Shukkar Hat,
Sonaili, Katihar Bihar working in a shop of sex abuser
land lord at Sonaili.

9. iii) Stone pelted by sex abuser of his families at 16:45pm
dated 24.08.2022 while he was inside his house.

iv) Sex abuser Vijay kumar Sinha, Bihar legislative council
is being identified on 27.08.2022.

v) Sex abuser ND Care Nirogam Doctor, Guru Gobind
Singh Nagar, near Bata Showroom, Majitha Road,
Amritsar, Punjab mobile: [phone] is being identified
on 27.08.2022.

vi) Sex abuser Sanjeev Jha S/O Nand Kishore Jha R/O
Sonaili, Katihar Bihar mobile: [phone] is being
identified on 27.08.2022.

vii) Sex abuser Faiz Ahmad and Ashfaq Qarim convicted in
corruption cases exchange of land for employment scam
case in Bihar is being identified on 27.08.2022.

viii) Sex abuser Mr. Ashok Sah R/O Nehru place linked with
sonaili katihar mobile [phone] is being identified on
27.08.2022.

ix) Sex abuser Subodh Kumar S/O Narayan Sah R/O Sonaili,
Katihar Bihar is being identified on 27.08.2022.

x) Pimp and Sex abuser Tara Devi W/O Hari Sah R/O Rani
Ganj, Araria, Bihar mobile [phone] relative of
another Sex abuser Vinod Sah S/O Narayan Sah R/O
Sonaili, Katihar Bihar is being identified on 27.08.2022.

10. xi) Sex abuser Mr. Pappu Thakur S/O Bishu Thakur, R/O
Kantiya, Sonaili, Katihar, Bihar mobile: [phone] is
being identified on 27.08.2022. He is an associate of,
Deepak Bubna, Rajasthan Marwari, having plastic plant
in Vijayvara Andhra Pradesh and link with Pappu Thakur
Sonaili for human trafficking and sex racket. He is being
noticed by passing remarks against abducted minor
daughter by state for child prostitution. He passed
remarks by singing vulgar hindi songs, “dilwa le ga eele
piyarki fork wali”. Sex abuser Mr. Pappu Thakur wanted
to say that sexy abducted minor daughter has stolen his
heart wearing yellow skirt. He also reinforced that he
abusing her sexually frequently.

xii) Sex abuser Advocate Pratik Sinha, New Delhi is being
identified on 27.08.2022.

xiii) Sex abuser Mr. Giriraj Singh, Union Minister is being
identified on 27.08.2022 linked with human trafficker
Nanhki Singh S/O Lalit Singh R/O Goshala Road,
Sonaili, Katihar, Bihar, a convict under Juvenile Justice
Act and retired Army man Nanki Singh is working as a
physiotherapist of Mr. Giriraj Singh. He has hide outs in
many places across the country.

xiv) Sex abuser Indian Army train stopped at 12:28pm dated
28.08.2022 and dated 04-09-2022 at 19:00pm for 4-5
hours at Sonaili Railway Station under Katihar Divisional
Railway Manager for cooking and Gag Raping of the
victims.

11. xv) Sex abuser started pelting stone on petitioner at 17:00pm
at his residence at Sonaili, Katihar Bihar.

xvi) “Garib Kalyan Yojna” scheme of Prime Minster of India
is being identified connected with Sex abusers/sex
racketeers on 27.08.2022.

xvii) Sex abuser Mr. Rahul Gandhi, Congress political leader
S/O Sonia Gandhi and Chirag Paswan S/O Ram Vilas
Paswan is being identified on 28.08.2022 linked with
human traffickers of Marwari traders and land lords of
Salmari , Sonaili Katihar Bihar, linked with retired Army
man and a convict under Juvenile Justice Act Nanhki
Singh S/O Lalit Singh R/O Goshala Road, Sonaili,
Katihar, Bihar, worked as an ANM with R.R. Hospital,
New Delhi mobile number 9473133036
/6201100510/8083114751 and frequently contacted with
Rahul Gandhi at Tennis Court at R.R. Hospital, New
Delhi. He has hide outs in many places across the
country.

xviii) Sex abusers Manthu Dokania is being identified on
28.08.2022. Attacked by instigating violent group with
tractors and blasting huge noise under the garb of cricket
match at 19:00pm and 22:45pm.

xix) Sex abusers Mr. Digvijay Singh S/O R.K. Singh (Air
Force) R/O Patna Bihar and Goila Dairy, Dwarka, New
Delhi mobile: [phone] is being

12. identified on 29.08.2022. He is one of the witnesses in
Post Mortem Report No. 1904/2017 vide D.D.NO. 12B
dated 11.11.2017 of deceased mother Asha Rani Devi age
70 years, W/O Deep Narayan Poddar Palam Village
Police Station, New Delhi case connected with this sex
racket case. He has been booked under relevant sections
of IPC by Pun Pun Police Station under Patna Bihar vide
F.I.R No. 213/2021 and Bail Petition No. 254/2021.

xx) Sex abusers Advocates of Katihar district is being
identified on 29.08.2022 with the help of Gang Rape
victims at Katihar. Advocate Kulbhushan Poddar,
Advocate Janardan Poddar, Advocate Prabhakar Poddar,
Advocate Shusheel Deshwal and Advocate Pramod
Bhagat.

xxi) Sex abusers of JNU Classmates are being identified on
30.08.2022. Mr. Dilip Jha R/O Kishangarh, Vasant Kunj,
New Delhi and Bihar Sharif Bihar mobile no.
9818025843 working as a LIC agent, Md. Mustaque khan
R/O Siwan Bihar mobile no. 9931161075, Prof Md.
Rashid ali R/O Patna Bihar and Srinagar University,
Jammu and Kashmir mobile no.
7006459426/9419249310, Md. Talib Khan R/O
Aurangabad and Patna Bihar mobile no. 9304440215,
Md. Mohsin R/O Bihar mobile no. 9313883533, Md.
Sajid khan R/O Siwan Bihar mobile no. 8084970735,
Mukesh Kumar Sinha mobile R/O Bhagalpur Bihar no.
8825214365, Army man Coronal Md. Shahid Khan
mobile no. 7023722228, Mr. Bobin Banerjee, R/O

13. Mirchaibari Katihar, Siliguri West Bengal and Gurgaon
Haryana mobile no. 9910190728, Prof. Ganga Prasad
Poddar (Buchhu) R/O Kantiya, Sonaili, Katihar P.S.
Kadwa, Katihar Bihar, mobile no. 9939296360, Md.
Shadat Noor, R/O Gaya Bihar product of St. Stephens
College, University of Delhi and classmate of Delhi
School of Social Work University of Delhi.
xxii) Sex abusers are being identified on 30.08.2022. Md. Irfan
Khan, Delhi School of Social Work University of Delhi
Classmates working with Unicef and worked with Dr.
Shankar Chaudhry AIIMS New Delhi. Mr. Anil Sahni,
RJD MP kutni Bihar, Firoz Alam, engineer Bihar
Bhawan, New Delhi, Nupur Sharma, BJP, I.O. Uttam
Singh, Tilak Marg New Delhi,

xxiii) Sex abuser political leader Ravi Sah R/O Sonaili Katihar
Bihar is being identified on 31.08.2022 at 2:30pm along
with victim.

xxiv) Sex abuser Amit and Kailash, Palam Colony New Delhi
converted into Christianity is being identified on
31.08.2022.

xxv) Sex abuser Phuleshwar Uron right hand of Mukhiya
Kantiya Panchayat, R/O Goshala, Sonaili Katihar Bihar
and S/O Ramu Uraon a railway employee is being
identified on 01.09.2022 at 8:15am.

xxvi) Sex abuser Mr. Sudhakar Gupta brother of Diwakar
Gupta R/O Goshala, Sonaili Katihar Bihar is being

14. identified on 01.09.2022 at 8:25am.

xxvii) Sex abuser Md. Anwar Aalam R/O Sudhani, Barsoi
Katihar Bihar a Railway train Guard at Kharagpur West
Bengal mobile no. 9002086561 is being identified on
01.09.2022 at 8:39am.

xxviii) Sex abuser Suresh Mandal R/O Manihari, Katihar
Bihar mobile no. 9939017790 is being identified on
01.09.2022 at 4:00pm along with political leaders.

xxix) Sex abuser telephone no. 011-23961522 is being
identified on 01.09.2022 at 19:28pm.

xxx) Sex abuser Naxalite Mr. Vijay Arya is being identified
on 01.09.2022.

xxxi) Sex abuser Mr. Dadu Pahalwan R/O Baxur, Bihar is
being identified on 01.09.2022

xxxii) Sex abuser working with Planning Commission of India
New Delhi renamed as Niti Ayog in 2009 is being
identified on 02.09.2022. Mr. Aijo Jacob, Ms. Firoza
Mehrotra, Ms. Sayeeda Hameed, Ms. Rupa Dutta, Ms.
Sudha P. Rao, Mr. Lalit Kumar, Mr. Alok kumar Rai
9871949592, Mr. Raj Kumar Khoshla 7827451458, Md.
Shadab Khan 9868085649, Mr. Sachin Sharma.

xxxiii) Sex abuser Mr. Lachhu Sah R/O Shukkar Hatt, Kantiya
Pnchayat, P.S. Kadwa, Sonaili, Katihar, Bihar is being

15. identified on 03.09.2022.

xxxiv) Sex abuser Indian Army is being identified on
04.09.2022. Indian Army train has stopped at 19:00pm
dated 04-09-2022 for 4-5 hours for cooking and Gag
raping of the victims at Sonaili Railway Station under
Katihar Divisional Railway Manager causing artificial
rain.

xxxv) Sex abuser BDO Rai R/O Samastipur Bihar a liquor
mafia is being identified on 06.09.2022.

xxxvi) Sex abuser Dr. Saumitra Mohan IAS, R/O Bazar Samiti,
Patna, worked as ADM Dinajpur district, Vardhman
district of West Bengal and presently working as School
Commissioner at Kolkotta West Bengal mobile no.
9434242283 is being identified on 06.09.2022.

xxxvii) Sex abuser Mr. Rajeev Pandey from Delhi School of
Social Work, University of Delhi worked with New
Concept Information System Pvt. Ltd, Sarita Vihar, New
Delhi mobile no. 9910077168 is being identified on
06.09.2022.

xxxviii) Sex abuser Ramashish Yadav’s families R/O
Kantakosh, Manihari Katihar Bihar is being identified on
06.09.2022.

xxxix) Pimps cum Sex abuser Ms. Madhubala Paathak D/O
Bindeshwari Pathak, R/O Patna and Raajouri Garden

16. New Delhi is being identified on 06.09.2022.

xl) Sex abuser Mr. Keshav and his son Aman relative of MP
Bholla Vishwas R/O Kadwa Katihar Bihar mobile no.
9471627846 is being identified on 06.09.2022.

xli) Sex abuser Mr. Manish Saboo mobile no. 9871123393
owner of Ball bearing shop at G.B. Road, P.S. Lahori
Gate, Delhi-6 R/O Modal Town, Delhi factory at
Shahadra Delhi having link with human trafficker
Marwari trader of Bhagalpur at Bihar is being identified
on 06.09.2022 at 1:23am midnight.

xlii) Sex abuser Mr. Surender Poddar, R/O Bhelai, Vamreli
Panchayat, P.S. Dandkhora, Katihar, Mr. Mukti Nath
Singh retired Head Master R.N.D.B High School Sonaili
R/O Pahlagarh Panchayat Sonaili, Sukhdev Sah Math
Teacher A.L.High School Sonaili, Ramesh Sah PT
teacher Sonaili, Jagdish Poddar, Science teacher
A.L.High School Sonaili is being identified on
09.09.2022.

xliii) A victim is being identified inside Press Car at around
16:35pm dated 9-9-2022 at Sonaili Katihar Bihar.

xliv) Sex abuser Mr. Manish Jha, Assistant Professor with
Department of Social Work, Tata Institute of Social
Sciences, Mumbai, Mohd. Sharif Bhatt, General
Manager, Save the Children, Jammu and Kashmir, Mr.
Rajan Khosla, Country Director Mayanmar, Oxfam

17. International, Ms. Manisha Rekhi, Placement
Consultancy for Gulf at Dwarka New Delhi, Ms. Pamela
Singla, Head Delhi School of Social Work University of
Delhi, Mr. Ajay S. Mehta, President Sewa Mandir,
Udaypur Rajasthan, Mr. Deepak Sah, Mahila Bal Vikas
NGO Lohapatti, Bhagalpur, Bihar, Md. Irfan Khan,
Unicef, Ms. Jyothi Chetti, Director, Asha Deep
Foundation, Shahid Nagar Gaziabad, Delhi/NCR boarder,
Ms. Shivani Bhatnagar, Mr. Aijo Jacob, Father of Church
R/O Kerala & Australia, Mr. Ajeet Singh, Guria NGO at
red light area of Varanasi UP, Ms. Saraswati Gopala Rao,
HDRN, Hauz Khas New Delhi, Mr. Rishi, Shaktivahani
NGO at Faridabad, Ms. Smiriti Irani, Cabinet Minister,
MWCD, Government of India, Mr. Manoj Thakur R/O
Shukkar Hat, Sonaili, Katihar, Bihar, Mr. Ganga Prasad
Poddar (Buchhu) mobile no. 9939296360 Asst. Professor
B.D.College Barsoi, Katihar, Mr. Sanjeev Poddar S/O
Siwanan Poddar, Pradeep Poddar, Phoolkumar Poddar
R/O Sonaili, Katihar Bihar are being identified on
10.09.2022.

xlv) Sex abuser Mr. Jha, Station Master, Sonaili Railway
station, under Katihar division and North East Frontier
Railway Zone is being identified on 11.09.2022. He
permitted Delhi bound train Champaran Hasafar express
to enter and stand at Sonaili Railway Station without its
defined route at Sonaili for Gang Rape and traffic the
victims in the night.

18. xlvi) Sex abuser Mr. Rahul Singh, mobile no. 9250111110
R/O CRPF Flats, Dwarka, New Delhi and Jaunpur
Varanasi Uttar Pradesh close associate of Mr. Digvijay
Singh R/O Gola Dairy and Patna Bihar, Mr. Anshul
Gupta, General Manager, North East Frontier Railway
Zone, Mr. S.K. Chaudhry Divisional Railway Manager
Katihar is being identified on 12.09.2022.

xlvii) Sex abuser Indian Army Military train at Sonaili
Railway Station at 9:10am is being identified for Gang
Rape. Victim is being dragged into Coach No. M-
10086/SR15135 AC-3Tier of the train for Gang Rape.

xlviii) Sex abuser Mr. Jha, Station Master, Sonaili Railway
station, under Katihar division and North East Frontier
Railway Zone is being again identified on 13.09.2022 and
14.09.2022 for poking the petitioner for violence and
switching off the electricity of the mobile charging point
to stop the petitioner from charging mobile.

xlix) Sex abuser Mr. Sita Ram Uraon, Mukhiya, Kantiya
Pnchayat, P.S. Kadwa, Sonaili, Katihar, Bihar mobile no.
7762845438 and Mr. Deepak Banjara, Sarpanch Kantiya
Pnchayat, P.S. Kadwa, Sonaili, Katihar, Bihar mobile no.
7903992304 is being identified on 16.09.2022 and
17.09.2022. Shri Sita Ram Uraon Mukhiya Kantiya,
Manrega Panchayat Bhawan, Shukar Hat, Sonaili,
Katihar Bihar has refused to receive an application of
Gang Rape & illicit sex trade Victims of his jurisdiction

19. on 17.09.2022. He kept on waiting the
applicant/complainant for the whole day even after prior
appointment with him.

l) Sex abuser Son of Mr. Ashok Yadav, S/O Satya Narayan
Yadav R/O Kantiya, Sonaili, Kadwa, Katihar Bihar is
being identified on 18.09.2022 trafficking the reported
CSA case (Reported to Police on 12.09.2022, A
Suspected Child Sexual Abuse case) to katihar at
10:23am through Siliguri-Katihar DMU local passenger
train for illicit sex trade and Performing vulgar DJ Dance
amidst persistent Gun firing.

vi) Petitioner has intervened, seen and verified his
kidnapped pregnant wife Rina Kumari (Guddi) on
11.05.2022 at Bihar after the dismissal of PIL Writ Petition
(Criminal) No. 242/2021 on 25.10.2021 and during the Sub-
Judies pending matter W.P. (Criminal) D.No. 18546/2022
dated 14.06.2022 before Supreme Court India. Petitioner has
caught her wife on the stage show dated 11.05.2022 at
Sonaili Katihar Bihar behind a mosque situated at Shukkar
Hatt in front of his house, climbed at the stage to intervene
and stop the ongoing Gang Rape events but being thrashed
by a group of human traffickers and sex abusers. The same
has been reported to Delhi Police and Bihar Police through
written signed copy of complaint emailed dated 12.05.2022.
Medical has been done by Sadar Hospital Katihar vide
registration number 2529 dated 12/05/2022. However, the
Medico Legal Case (MLC) is being denied and medical
prescription along with daily diary has been stolen. The

20. same has been informed to all the nodal officers of Bihar as
well as Delhi Police. Mr. Virender, an Inquiry officer has
been appointed by Delhi Police CCTNS Admin in this case.
The complaint no. 50000046782203202 dated 12-05-2022
PIS No.28820336 mobile no. 9013248152 is allotted against
it, yet no F.I.R.

8. That thereafter Petitioner has seen 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 through 112 call
reference no. 5260340 dated 19.06.2022 at 17:08pm against human
trafficker mobile number 8830993916. Wife Rina Kumari sat
beside the petitioner at the bus stop opposite to old Delhi Railway
Station at around 3:00pm to 4:00pm along with her 25 year old
Rajput sex abuser boy and 3 year old new born baby boy along
with a 22 year old woman helper. The moment petitioner made 112
call ref. no. 5260340 at 17:08pm PCR Patrol Vehicle ZBR33,
Mobile: [phone] at 17:14pm, I.O. Mukesh Kumar SI, P.S.
Palam Village, New Delhi mobile: [phone] at 17:35pm against
Tamil Nadu and Mumbai human trafficker mobile number
8830993916 (by which victim had called the petitioner on
01.10.2019 for her rescue from the clutches of human traffickers
and sex racketeers and informed about persistent torture and
indiscriminate cruelty inflicted upon her by the inhumane, cruel
and demon like human traffickers), she is being pushed by the
human traffickers towards Church Mission Road, Fatehpuri, Old
Delhi-6 by a battery driven Toto rickshaw.

21. 9. That however, Petitioner is capturing and reporting all cause
of actions to the concerned authorities for necessary actions. Police
complaint against persistent Gang Rape of victims has been
reported to Delhi as well as Bihar Police including administrative
authorities of both the places. Petitioner has reported the cause of
actions on 07.05.2022, 09.05.2022, 10.05.2022, 11.05.2022,
12.05.2022, 13.05.2022, 14.05.2022, 14.05.2022, 15.05.2022,
16.05.2022 (Child Line Katihar Rilway, Bihar, NCPCR, New
Delhi and ChildLine Kolkotta) 17.05.2022, 18.05.2022,
19.05.2022, 20.05.2022, 22.05.2022, 23.05.2022, 24.05.2022,
25.05.2022, 26.05.2022, 27.05.2022, 28.05.2022, 31.05.2022,
01.06.2022, 02.06.2022, 03.06.2022, 05.06.2022, 07.06.2022,
08.06.2022, 09.06.2022, 10.06.2022, 11.06.2022, 12.06.2022,
13.06.2022, 15.06.2022, 16.06.2022, 18.06.2022, 19.06.2022,
20.06.2022, 21.06.2022, 22.06.2022, 23.06.2022, 24.06.2022,
25.06.2022, 26.06.2022, 27.06.2022, 28.06.2022, 29.06.2022,
30.06.2022, 01.07.2022, 02.07.2022, 03.07.2022, 04.07.2022,
05.07.2022, 06.07.2022, 07.07.2022, 08.07.2022, 09.07.2022,
10.07.2022, 11.07.2022, 12.07.2022, 13.07.2022, 14.07.2022,
15.07.2022, 16.07.2022, 19.07.2022, 20.07.2022, 21.07.2022,
22.07.2022, 23.07.2022, 24.07.2022, 25.07.2022 (Bandhan
Kolkotta), 26.07.2022, 27.07.2022, 28.07.2022, 29.07.2022,
30.07.2022, 31.07.2022, 01.08.2022, 02.08.2022, 03.08.2022,
04.08.2022, 05.08.2022, 06.08.2022, 07.08.2022, 08.08.2022,
09.08.2022, 10.08.2022, 11.08.2022, 12.08.2022, 13.08.2022,
14.08.2022, 15.08.2022, 16.08.2022, 17.08.2022, 18.08.2022,
19.08.2022, 20.08.2022, 21.08.2022, 22.08.2022, 23.08.2022,
24.08.2022, 25.08.2022, 26.08.2022, 01.09.2022 (National Human
Rights Commission and Speaker Lok Sabha & Rajya Sabha for
impeachment of Chief Justice of India and other Justices of

22. Supreme Court of India), 05.09.2022(National Commission for
Women & Delhi Commission for Women),
10.09.2022(Department of Social Work, TISS, Mumnai and Delhi
University, CINI West Bengal, Save the Children J&K, Children
International US, Social Development Sector Consultancy),
12.09.2022 (Chairman Railway Board) 13.09.2022(NHRC),
15.09.2022(NHRC), 18.09.2022 (Chief Minister of Bihar, Prime
Minister office). Yet no F.I.R by police & no rescue till date.

10. That Diary No. 155282/CR/2016 dated 14.09.2016, Case
No. 3537/4/4/2016 has been rejected on 18.10.16, Case No.
5480/30/0/2022 and Case No. 4751/90/0/2022 has been rejected on
30.08.2022 and 31.08.2022 respectively by the National Human
Rights Commission, New Delhi on the same International Sex
Matter.

11. That however, Diary No. 134093/CR/2022 dated 1.9.2022,
Diary No.134631/CR/2022 dated 2.9.2022, Case No.
4977/90/0/2022 dated 12.09.2022 regarding Children, Case No.
4876/4/16/2022 dated 12.09.2022, Diary No. 141497/CR/2022
dated 14.9.2022, Diary No. 134093/CR/2022 dated 15.9.2022,
Case No. 4977/4/16/2022 dated 16.09.2022, Case No.
5046/4/16/2022 dated 19.09.2022, Diary No. 136577/CR/2022
dated 19.9.2022, Diary No. 144151/CR/2022 dated 19.9.2022 has
been registered by the National Human Rights Commission,
(NHRC), New Delhi on the same sex matter, which is still pending
before the commission.

12. That Central Vigilance Commission, New Delhi has

23. received complaint case no. 205126/2022/vigilance-B on
29.06.2022 against its corrupt All India Services Employees.

13. That two N.B.Ws dated 25.08.2010 and 08.09.2011 u/s 82
and 83 CrPc. issued and maintained by Begusarai Court against
Petitioner and his deceased mother Asha Rani Devi. Record of
N.B.Ws dated 25.08.2010 under DV Act placed before Dwarka
Court at New Delhi on 09.02.2011 while the record of N.B.W
dated 08.09.2011 u/s 82 and 83 CrPc. in 498A, section 323 of IPC
and u/s 3/4 of D.P Act is being kept secret. The Record of N.B.W
dated 08.09.2011 is being unearthed by the petitioner through
Right to Information Act in 2016-17 in the wake of Gang Rape of
his families by Mr. Sidharth Mohan Jain, Superintendent of Police
Katihar inside his Sonaili Katihar Bihar house on 28.02.2016-
06.03.2016. Wife Rina Kumari (Guddi) has filed Valkalatnama in
HMA-700/2010 at Family Court at Dwarka Court at New Delhi on
09.02.2011 through her Rajput caste counsel from Purnea Bihar
but has not filed Written Statement (WS) till date. However, she
has filed two cases in CJM Court at Begusarai Bihar and
expressed her willingness to stay along with her husband and
demanded lump sum handsome amount as compensations and
monthly amount as maintenance. Case No. 9P/2010 under
domestic violence Act 2005 on 31.03.2010 and another Criminal
Case Complaint (P) No. 397C/ 2011/ 5591/2013 under section
498A, section 323 of IPC and u/s 3/4 of D.P Act on 07.02.2011
along with two N.B.Ws dated 25.08.2010 and 08.09.2011 u/s 82
and 83Cr.Pc. This arbitrary action of State and abuse of court
process causing jurisdictional error has been culminated as
W.P.(C) No. 90/2016, W.P.(Crl.) No. 136/2016, R.P. No.
825/2016 and W.P.(Crl.) No. 137/2021 before Supreme Court of

24. India and CRWJC NO. 1238/2019 before Patna High Court.

14. That Police complaint dated 07.04.2011 is still pending
before Kadwa Police Station Katihar Bihar for registration of an
F.I.R.
15. That Police complaint dated 30.05.2016 vide D.D.No. 37B
and Post Mortem Report No. 1904/2017 vide D.D.NO. 12B dated
11.11.2017 of deceased mother Asha Rani Devi age 70 years, W/O
Deep Narayan Poddar is still pending before Palam Village Police
Station, New Delhi for registration of an F.I.R. Postmortem has
been conducted by ASI Shyam Sunder, Palam Village Police
Station, New Delhi and Deen Dayal Upadhyay Hospital,
Government of N.C.T of Delhi, Hari Nagar, New Delhi.

16. That Non-F.I.R No. 173/2019 dated 05.08.2019 under
section 107 of CrPc. has been registered by SHO Kadwa Police
Station, Katihar Bihar against the violent mob attack on petitioner
dated 30.07.2019 by the sex abusers and the same has been
forwarded to the court of Sub-divisional Magistrate, Barsoi,
Katihar Bihar for further action which is still pending without any
action.

17. That Police Action Taken Report dated 29.11.2019 by
Superintendent of Police Traffic Katihar Bihar reveals that Police
has taken negative action against the violent mob attackers on
petitioner dated 30.07.2019 at Sonaili Katihar Bihar. The main
accused in this case is neighbor (1) Shri Bechan Poddar S/O
Sahdev Poddar, (2) Shusheel Poddar S/O Bechan Poddar, (3)
Guddu Poddar S/O Bechan Poddar R/O Shukkar Hatt, Sonaili,

25. Kadwa Police Station, Katihar Bihar.

Police Action Taken Report dated 29.11.2019 by
Superintendent of Police Traffic Katihar Bihar is annexed
herewith as Annexure P-1 (Page from to ).

18. That Police complaint against Gang Rape of victims dated
09.06.2022 vide D.D.No. 23A at Lahori Gate Police Station, Delhi-
6 is still pending before Lahori Gate Police Station for registration
of an F.I.R.

19. That Police complaint against Gang Rape of victims dated
15.06.2022 to DCP/Inspector Vigilance Vasant Vihar Police
Station New Delhi is still pending before DCP Vigilance for
direction to SHO Palam Village Police Station New Delhi to
register an F.I.R.

20. That Police complaint against Gang Rape of victims dated
18.06.2022 vide D.D.No. 40 at Tilak Marg, Police Station, New
Delhi is still pending before Tilak Marg Police Station for
registration of an F.I.R.
Police Complaint dated 18.06.2022 vide D.D.No. 40 by
Petitioner to the SHO, Tilak Marg Police Station, New Delhi is
annexed herewith as Annexure P-2 (Page from to ).

21. That 112 call with reference no. 8206 at 21:19:28pm dated
02.07.2022 against Gang Rape of victims by Superintendent of
Police inside the house of petitioner Asha Deep Niwas, Shukkar
Hatt, Sonaili, Katihar Bihar. In retaliation of this complaint,
Superintendent of Police organized a grand Gang Rape, Vulgar DJ

26. dance with indiscriminate gun firing and illicit sex trade events
throughout the district which compelled the petitioner to leave his
house in the midnight of 3
rd
July 2022. He has protested by
walking down on the street for about 12 kilometers keeping fast for
whole night.
22. That Bihar Police Action Taken Reports against Gang Rape
Victims (Gang Raped by Mr. Sidharth Mohan Jain, Superintendent
of Police Katihar inside the house of petitioner at Asha Depp
Niwas Sonaili Katihar Bihar from 28.02.2016 to 06.03.20216)
annexed with W.P.(Crl.) 137/2021 as Annexure P-3 dated
07.05.2016 pages from 77-81 and Annexure P-6 dated 16.05.2018
pages from 89-90.

23. That Delhi and Bihar Police Action Taken Reports against
attempt to murder of petitioner and his ailing old age mother Asha
Rani Devi by Sex abuser of his Prostitute families annexed as
Annexure P-5 dated 10.02.2018 (Delhi Police ATR against
suspicious death of mother Asha Rani Devi) pages from 87-88,
Annexure P-8 dated 20.09.2019 pages from 103-104, Annexure P-
9 dated 14.03.2020 pages from 105-106 and Annexure P-10 dated
31.10.2020 pages from 107-108.

24. That DGP Bihar control room mobile no. 9431602301 and
9431602302 has informed the petitioner on 26.05.2022 that his
family prefers to stay at his neighbor’s house rather than his own
house. DGP Bihar acted beyond his jurisdiction and acted as court
and became a judge. He refused to raid the locations of Gang Rape
and rescue the victim in the night at Sonaili Katihar Bihar.

27. 25. That petitioner is an eye witnessed of indiscriminate gun
firing by a group of sex abusers of his families Mr. Ankush Pandey
S/O Vijay Pandey, Niece of Mr. Ajay Pandey, Grandson of Kapil
Dev Pandey and Mr. Chandan Kumar Gupta S/O Ms. Kiran Gupta
R/O Shukkar hatt, Sonaili, Katihar in front his house at Shukkar
Hatt, Sonaili, Katihar, Bihar in the month of June 2021 (Friday
night). All daily newspaper and local TV Channel of Bihar
published and highlighted this news claiming F.I.R against 128
accused and the same has been circulated through WhatsApp group
showing arrest of some accused along with photographs. All hoax
created by Police and media to pacify the petitioner that Police is
active and sensitive against the sex racket issue. The NCRB portal
and Bihar Police HQ portal does not show any record of F.I.R
against the main accused Mr. Chandan Kumar Gupta and Mr.
Ankush Pandey of under P.S. Kadwa.

26. That another hoax created by Police and media to justify the
wrong action of police to sustain the illicit sex trade of the victims.
All daily newspaper and local TV Channel of Bihar published and
highlighted the indiscriminate gun firing by the unidentified gunner
or shooter on the house of human trafficker Mr. Sunil Bubna, a
Marwari community from Rajasthan having large network across
Country and Globe. State provided Police protection to human
trafficker and sex racketeer Mr. Sunil Bubna to sustain the business
of illicit sex trade at Sonaili, Katihar. Petitioner is an eye witness of
this kind of biased action by Katihar Bihar Police in the month of
July 2021 at Sonaili Katihar Bihar.

27. That the nexus of Supreme Court of India and Union of
India has hid out the innocent Gang Rape victim families of

28. petitioner with an active help of barbaric act of State through
technology based sex racket, slaving the minds and bodies of the
victims, restricting their rescue and rehabilitation by infusing
glamorous ideology of Human Trafficking into their minds.
Victims have been thoroughly misused by the State for violent
attack on petitioner in the name of patriotism by propagating the
Hippocratic idea of “Aazadi ka Amrit Mahotsav” and campaigning
of “Har Ghar Tiranga Abhiyan” abusing the National tricolor Flag
through the nasty Gang Rape events of women and children,
keeping them hostage for illicit sex trade to generate revenue out of
it by marking the 75
th
year of India’s Independence.

28. That it is a deliberate attempt of radical wing of Political
parties to malign the glory of Indian National Flag by suppressing
the Gang Rape F.I.Rs, illicit sex trade Court records and outraging
the modesty of Women in India.

29. That previous case records of Petitioner from 2012 to till
date at Supreme Court of India reveals the severe barbaric act of
Justices of Supreme Court of India against the petitioner and his
ailing mother. The list of Similar disposed of matter with citation
and case details have been given in the para 6(a) of PROFORMA
FOR FIRST LISTING with this main petition.

30. That in view of the above stated fact; Petitioner is
specifically placing relevant material records against the barbaric
act of Justice Uday Umesh Lalit who is the sitting Hon’ble Chief
Justice of India and will remain in the office of Chief Justice of
India till 08.11.2022.

29. 31. That Material Evidence of barbaric act against Petitioner
and his deceased mother Asha Rani Devi by sitting Hon’ble Chief
Justice of India Mr. Uday Umesh Lalit of Supreme Court of India
are given below:-

a) Bench of Justice Uday Umesh Lalit and Pinaki Chandra
Ghosh has deliberately evaded the Rule of Law and
dismissed Anti-Prostitution Writ Petition (Criminal)
136/2016 on 21.10.2016 and sustained the International sex
racket kidnapping and pushing petitioner’s pregnant wife
Rina Kumari (Guddi), his never seen 17 year old minor
daughter and 50 other family members into illicit sex trade
and hidden prostitution since 18 years.

b) Unlawful dismissal of Anti-Prostitution Writ Petition
(Criminal) 136/2016 on 21.10.2016 has given rise to as
many as 17 other Writ Petitions Criminal before Supreme
Court of India on the same issues, bifurcating from the main
issue of wrongful dismissal Writs by Justices without
granting any relief to the petitioner Om Prakash Poddar and
his ailing mother Asha Rani Devi. However, all Criminal
Petitions have been dismissed supplying the lame excuse of
Supreme Court Rule 2013. Registry of Supreme Court of
India says that Supreme Court Rule does not allow any
petitioners to invoke Article 32 twice for the Same Cause of
Action.

c) Pro-Prostitution judgment on “INDIAN HOTEL AND
RESTAURANT ASSOCIATION (AHAR) & ANR. VS. THE

30. 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 is interlinked with
individual Writ Petitions of Petitioner and outcome of
wrongful and unlawful dismissal of Anti-Prostitution Writ
Petition (Criminal) 136/2016 before Supreme Court of India.

d) WRIT PETITION (CRIMINAL) DIARY NO.3913 OF 2017
entitled “OM PRAKASH & ANR. VS. REGISTRAR,
SUPREME COURT OF INDIA & ANR is also the outcome
of wrongful and unlawful dismissal of Anti-Prostitution Writ
Petition (Criminal) 136/2016.

e) M.A. 583/2020 in Writ Petition (Criminal) 136/2016 for
Constitution Bench, listed before the bench of Justice Uday
Umesh Lalit, NOTICE of hearing dated 16.03.2020 being
served in this matter, petitioner responded on the date of
hearing of the matter on 16.03.2020 but the same being de-
registered dramatically furnishing lame excuse of
inadvertently registered by Registry. Registrar has supplied
his explanation that Registry has inadvertently registered this
application as M.A. 583/2020.

f) Complaint through Affidavit dated 21.09.2020 against
Justice Uday Umesh Lalit of Supreme Court of India to the
Department of Justice, Government of India and Chief
Justice of India, Supreme Court of India apprising the
barbaric act of Justice Uday Umesh Lalit against the
petitioner on 14.09.2020 in the hearing of Constitution
Bench matter through video conferencing inside the
Supreme Court Premises is pending for necessary action

31. against him. He unnecessarily suppressed the Anti-
Prostitution matter M.A.NO. 1446 of 2020 in Writ Petition
(Criminal) 136/2016 with an oblique motive. He carried out
unlawful abnormal activities against the petitioner to
unstable him mentally by bogging down, muting down his
video conferencing equipment in the course of hearing of the
matter. He has suppressed the Constitution Bench
application M.A.NO. 1446 of 2020 in Anti-Prostitution Writ
Petition (Criminal) 136/2016 without any substantial reason
and ground.

g) Another Anti-Prostitution Writ Petition (Criminal) 137/2021
has been arisen out of unlawful dismissal of previous Anti-
Prostitution Writ Petition (Criminal) 136/2016 before
Supreme Court of India. It is pertinent to mention here that
Writ Petition (Criminal) 136/2016 has been dismissed by
Justice Pinaki Chandra Ghosh and Justice Uday Umesh Lalit
on 21.10.2016.

h) Another PIL Anti-Prostitution Writ Petition (Criminal)
242/2021 has arisen out of unlawful dismissal of previous
Anti-Prostitution Writ Petition (Criminal) 136/2016 before
Supreme Court of India.

i) Justice Uday Umesh Lalit is a pupil and associate of Justice
S.B.Sinha who is one of the main accused in this case. Uday
Umesh Lalit was also a defense lawyer in Monica case
before the bench of Justice S.B.Sinha of Supreme Court of
India. Monica case is linked with this case. Monica case has
been deliberately complicated by Justice S.B.Sinha and
Advocate Uday Umesh Lalit for the sake of money and extra

32. marital sex with her.

j) Above all, Justice Uday Umesh Lalit is aid of Amit Sah
(presently Home Minister with Government of India). He
was associated with Amit Sah as defense lawyer in Md.
Sohrabuddin fake encounter case in Gujrat. Moreover, Amit
Sah is one of the main accused in this case. Justice Uday
Umesh Lalit has been elevated to Supreme Court of India
directly from Advocate on the mercy of Amit Sah, This
source of information has been taken from the media report
available in the public domain.

k) Present Anti-Prostitution Writ Petition (Criminal) Diary No.
18546/2022 is also an offshoot or an outcome of previously
dismissed 17 petitions by the Supreme Court of India.
Allocation of benches and Listing of Petitions before
particular benches is the power of Chief Justice of India,
therefore there is a genuine apprehension in the mind of
petitioner that Justice Uday Umesh Lalit, present Hon’ble
Chief Justice of India may do bias. He may spoil the pending
Writ Petition (Criminal) D.NO. 18646/2022 for his own
vested interest.

32. That First Anti-Prostitution matter, Petition(s) for Special
Leave to Appeal (Civil) No(s).9854/2012 has been dismissed by
Supreme Court of India on 23.04.2012.

33. Second Anti-Prostitution matter, Petition(s) for Special
Leave to Appeal (Civil) No(s). 9483/2013 has been dismissed by
Supreme Court of India on 01.04.2013.

33. 34. Third Anti-Prostitution matter, Petition(s) for Special Leave
to Appeal (Civil) No(s). 19073/2013 has been dismissed by
Supreme Court of India on 05.07.2013.

35. Fourth Anti-Prostitution matter, Writ Petition (Civil)
90/2016 has been dismissed by Supreme Court of India on
18.04.2016.

36. Fifth Anti-Prostitution matter, Writ Petition (Criminal)
136/2016 has been dismissed by Supreme Court of India on
21.10.2016.

37. Sixth Anti-Prostitution matter, Writ Petition (Criminal)
242/2021 has been dismissed by Supreme Court of India on
25.10.2021.

38. Seventh Anti-Prostitution matter, Writ Petition (Criminal)
137/2021 has been dismissed by Supreme Court of India on
02.05.2022.

39. Eighth Anti-Prostitution matter, Writ Petition (Criminal)
Diary No. 18546/2022 is still pending before Supreme Court of
India. It is the outcome of dismissal of 17 Anti-Prostitution
dismissed matter by Supreme Court of India.

40. State sponsored Gang Rape victims are more than 50
women and minor girls from Petitioner’s families including his 18
years ago kidnapped pregnant wife Rina Kumari alias Guddi D/O
Surender Narayan Poddar, Rtd. Assistant Manager (RC),

34. Marketing Division, Brauni Refinery, Begusarai, Bihar and never
seen 17 years old minor daughter. Pregnant wife Rina Kumari alias
Guddi was kidnapped on 15.04.2005 by the State from Gali No.12,
Raj Nagar Part-2, Palam Colony, New Delhi and being pushed into
prostitution. She has been caught into prostitution along with her
minor daughter on 05.04.2021 at C-128/5, Gali No.07, Shastri
Park, North East Delhi by the petitioner.

Original photograph of Gang Rape Victim Rina Kumari
(Guddi) supplied by her father on 24
th
June 2004

37. Plastic Surgery Photograph of Gang Rape Victim Rina Kumari
(Guddi) along with sex abuser collected by the Petitioner
during her Gang Rape event at Sonaili, Katihar Bihar dated
11
th
May 2022.



41. That some of the victim’s name are Shri Surendra Narayan
Poddar, Assistant Manager (RC), IOC, Baruni Refinary, Ms. Anita
Poddar wife of Surendra Narayan Poddar, Rina Kumari,

38. Anuja Kumari, Rupam kumari alias Dolly daughters of Surendra
Narayan Poddar and Anupam Kumar son of Surendra Narayan
Poddar R/O R.H. 5/6, Baruni Refinary, Township, Begusarai
and Jagdish Path, Bailey Road Apartment 206, Malti Bihari, Patna,
Bihar, Har Har Mahadev Chowk, Begusarai, Bihar, IOCL Quarter,
Bank More, Dhanbad Jharkhand.

42. That suspected cases of Child Sexual Abuse (CSA) and
persistent Gang Rapes have been identified at Ram Kumar’s house,
C-128/5, Gali No.07, Shastri Park, North East Delhi an owner of
M/S R.K Fashion at Gandhi Nagar, Delhi on 05
th
April 2021. This
case has link with Muzaffarpur Bihar and Sonaili Katihar Bihar.
Case of sexual abuse and forced hidden prostitution of minor girls
have been reported to NCPCR Government of India vide POCSO
E-Box hit No. 2290 dated 12.04.2021. Dastagir Qumar Nodal
coordinator ChildLine Delhi has intervened into the case along
with Delhi Police and confirmed the same through email dated
17.04.2021 at 7:44 PM to the petitioner. However, the rescues of
the victims have been suppressed with handsome bribe and
recording false police statement. Thereafter, victims have been re-
pushed into the clutches of prostitution with greater magnitude.
That PIL Writ Petition (Criminal) No.242/2021 for direction of
registration of an F.I.R has also been dismissed by the Supreme
Court of India on 25.10.2021 due to non-appearance of Legal Aid
Advocate in this matter. Hence, rescue of victims is being
suppressed permanently.

43. That another Suspected case of Child Sexual Abuse (CSA)
has been identified on 12.09.2022 inside the house of Mr.

39. Vivekanand Jha, an astrologer and superstitious man, R/O Shukkar
Hatt, behind Goddess Durga Temple at Sonaili Village, Kantiya
Panchayat, P.S. Kadwa, Katihar, Bihar. Victim is tall, strong build,
Delhi breed, minor 17 years old but looking major girl frequently
disappears from Sonaili Katihar Bihar for outdoor sex. She has
been seen today dated 12.09.2022 at Sonaili Rilway Station under
DRM katihar, eastern railway Zone along with a fatty, bulky sex
abuser Rajput caste girl to catch Siliguri-Katihar bound local train
at 9.30am. Suspected CSA case has been reported to Bihar as well
as Delhi Police for intervention and scrutiny through SMS.

VICTIM’S PHOTO ATTCHED FOR VERIFICATION AND
SCRUTINY.

41. 44. That Ram Kumar’s house, C-128/5, Gali No.07, Shastri
Park, North East has been identified as a replica of Muzaffarpur,
shelter homes of Bihar.

45. That professional help of Mushkan, Pune based NGO and
Arambh India Mumbai based NGO has been taken for the rescue of
the Gang Rape victims. These NGOs are working in the area of
human trafficking and child sexual abuse.

46. That apart from help from these NGOs, help from Mr. Ajay
Kumar Bhalla, Secretary, Ministry of Home Affairs, Government
of India, Mr. Srivastava, Commissioner of Police Delhi, Mr.
Dastgir Qumar, Nodal coordinator, Child Line India Foundation,
North Regional Centre, New Delhi, Mr. Yashwant Jain, National
Commission for Protection of Child Rights (NCPCR), Mr. Anurag
Kundu, Delhi Commission for Protection of Child Rights
(DCPCR), Ms. Rekha Sharma, Chairperson, National Commission
for Women, Ms. Shwati Maliwal, Chairperson, Delhi Commission
for Women has been taken for the rescue of the victims, yet rescue
of the victims have been suppressed to sustain illicit sex trade to
gain political mileage and generate revenue out of it.

47. That Government of NCT of Delhi, Union of India and
Supreme Court of India is responsible for this kind of delinquent
act. In absence of proper rescue and rehabilitation, Gang Rape/
illicit sex trade is continued across the country and globe.

48. That in the course of rescue operation of Ms. Nikki, a child
sexual abuse case at Shashtri Park, North East Delhi in April-May,

42. 2021, Petitioner is being contacted by the following contractual
women employees of Delhi Commission for Women (DCW) and
Delhi Police(DP):

i) Ms. Sushma, (DCW) mobile-8929412576 at 10:43am dated
10.05.2021 at C-128/5, Gali No.07, Shastri Park, North
East Delhi.

ii) Ms. Meena Thakur, (DCW) mobile-7678337704 at 12:07pm
dated 10.05.2021 at C-128/5, Gali No.07, Shastri Park,
North East Delhi.

iii) Ms. Arpita, (DCW) mobile-9310577614 at 01:00pm dated
12.05.2021 at C-128/5, Gali No.07, Shastri Park, North
East Delhi.

iv) Ms. Pooja, (DCW) mobile-9899080621 at 10:22am dated
12.05.2021 at C-128/5, Gali No.07, Shastri Park, North
East Delhi.

v) Ms. Arupa, (DCW) mobile-9873241660 at 11:16am dated
13.05.2021 at C-128/5, Gali No.07, Shastri Park, North
East Delhi.

vi) Mr. Sachin, (DP), Sub-Inspector, P.S. Shastri Park, North
East Delhi, mobile-9540486321 at 18:27pm dated
16.05.2021

vii) Ms. Sushma Singh, (DP) I.O. Delhi Police, mobile-
8868535329.

49. That above noted State employees made all efforts to

43. suppress the matter by hook and crook.

50. That being aggrieved by the delinquent act of Government
of NCT of Delhi State employees, Petitioner moved to Supreme
Court of India for seeking direction for registration of an F.I.R
against this Public Interest Litigation (PIL) on prostitution matter
Writ Petition (Criminal) 242/2021 but the same is also being
dismissed by Supreme Court of India on the ground of Non-
appearance of Legal Aid Advocate on 25.10.2021.

51. That being aggrieved by this barbaric act of Supreme Court
of India, petitioner again moved to Supreme Court of India with
fresh Anti-Prostitution Writ Petition (Criminal) Diary No.
18546/2022 dated 14.06.2022 to restore the wrongly dismissed PIL
on prostitution matter Writ Petition (Criminal) 242/2021; which is
still pending before the court, yet Gang Rape and illicit sex trade of
Victims is continued in front of petitioner’s eyes.

52. That in the midst of the above noted activities; barbaric act
of State is continued against the Gang Rape Victims. State has s
kept them hostage for persistent Gang Rapes and illicit sex trade
since 2005 to till date.

53. That Indian Army is showing barbaric act by stopping army
train and gang raping victims. The army has stopped its train twice
at Gang Rape Zone Sonaili Village in Katihar district of Bihar, a
source point of human trafficking. Indian Army train has stopped at
12:28pm dated 28.08.2022 and at 19:00pm dated 04-09-2022 for 4-
5 hours for cooking and Gag Raping of the victims at Sonaili

44. Railway Station under Katihar Divisional Railway Manager. It is
pertinent to mention here that Indian Defense Organization is one
of the parties in pending persistent Gang Rape matter Writ Petition
(Criminal) Diary No. 18546/2022 before Supreme Court of India.

54. That Ms. Hemlata, mobile-8800326349, counsellor, Delhi
Commission for Women and Delhi Police has been informed
against the barbaric act of Indian Army through mobile SMS at
20:11:15pm dated 04.09.2022, “My ID
Facebook.com/omprakash.poddar/7587/. You will get authentic
court details. Indian Army train at Gang Rape victim Zone Sonaili
Railway Station under katihar divisional railway manager at
19:00pm dated 4.9.22 for cooking and gang rapes. Second time
this delinquent activity has been identified within month. Indian
defense organization is party before supreme court of India in
W.P.CRL.D.NO.18546/2022”. DCW & DP has been informed with
a hope to provide care and support to the victims at the source
point of human trafficking Katihar Bihar in coordination with
Bihar Commission for Women and Bihar Police.

55. That another example of lawlessness and barbaric act of
state against state sponsored gang rape victims has been identified
on 11.09.2022 at Sonaili, Katihar, Bihar. Without route, Hamsafar
express Katihar-Champaran–Delhi bound train brought and
stopped at Sonaili Railway station under DRM Katihar Bihar at
19:00pm for couple of hours to gang rape and traffick the victims.
This is happening while DRM Katihar and Chairman Railway
Board is party before Supreme Court of India in an Anti-
Prostitution matter Writ Petition Criminal Diary No.18546/2022.

45. 56. The barbaric act of Indian Railway has been reported to
Delhi as well as Bihar Police including Ms. Hemlata, counsellor of
Delhi Commission for women dated 12.09.2022 through SMS.

57. That Indian army is repeating its barbaric act by stopping its
train at Sonaili Railway Station under DRM Katihar dated
12.09.2022 at 9:00am for couple of hours for gang raping the
victims. Gang Rape Victim has identified inside the coach no. M-
10086/SR15135 AC-3 Tier of Indian Army Military train dated
12.09.2022.

58. The barbaric act of Indian army dated 12.09.2022 has been
reported to Delhi as well as Bihar Police including Ms. Hemlata,
counsellor of Delhi Commission for women on the same day and
date through SMS.

59. That there is a sheer violation of the direction of Supreme
Court of India by the State as laid down in Lalita Kumari vs.
Government of Uttar Pradesh & Ors. (W.P. (Crl.) No. 68/2008) for
registration of an F.I.R against receiving of an information
disclosing cognizable offence related to kidnapping of minor girl
and pregnant women, immoral trafficking, State Sponsored Gang
Rapes, illicit sex trade and human trafficking, Child sexual abuse,
suppression of rescue of gang rape victims, unauthorized hostages
of the victims by the State and child marriages of the victims etc.

60. That there is a sheer violation of preventive, remedial and
punitive guidelines of Supreme Court of India by the State laid
down in a case “Tehseen S. Poonawalla VS. Union of India and

46. others” (SC 2018).

61. That there is a sheer violation of the direction of Supreme
Court of India by a police officer in-charge of a police station as
laid down in various cases for registration of an F.I.R. Supreme
Court of India has categorically stated in its catena of judgments
that upon receipt of information by a police officer in-charge of a
police station disclosing a cognizable offence, it is imperative for
him to register a case under Section 154 of the Code as laid down
by Supreme Court of India in State of Haryana vs. Bhajan Lal
1992 Supp. (1) SCC 335, Ramesh Kumari vs. State (NCT of
Delhi) (2006) 2 SCC 677, Parkash Singh Badal vs. State of Punjab
(2007) 1 SCC 1, B. Premanand and Ors. vs. Mohan Koikal and
Others (2011) 4 SCC 266, M/s Hiralal Rattanlal Etc. Etc. vs.
State of U.P. and Anr. Etc. Etc. (1973) 1 SCC 216, Govindlal
Chhaganlal Patel vs. Agricultural Produce Market Committee,
Godhra and Ors. (1975) 2 SCC 482, Ganesh Bhavan Patel and
Another vs. State of Maharashtra (1978) 4 SCC 371, Aleque
Padamsee and Others vs. Union of India and Others (2007) 6 SCC
171, Ram Lal Narang vs. State (Delhi Administration) (1979) 2
SCC 322 and Lallan Chaudhary and Others vs. State of Bihar and
Another (2006) 12 SCC 229.

62. That there is a sheer violation of the direction of Supreme
Court of India by the State as laid down in “Archbishop Raphael
Cheenath S.V.D. v. State of Orissa and another, (2016) 9 SCC
682”, wherein it is asserted categorically if any officer responsible
for maintaining law and order is found negligent, he/she should be
brought within the ambit of law.

47. 63. That there is a sheer violation of the direction of Supreme
Court of India by the State against the petitioner as laid down in
D.K. Basu v. State of West Bengal (1997) 1 SCC 416, after
referring to the authorities in Joginder Kumar v. State of U.P. and
others (1994) 4 SCC 260 , Nilabati Behera v. State of Orissa and
others (1993) 2 SCC 746 and State of M.P. v. Shyamsunder
Trivedi and others (1995) 4 SCC 262 , laid down certain
guidelines to be followed in cases of arrest and detention. In
Arnesh Kumar v. State of Bihar and another (2014) 8 SCC 273,
this Court referred to Section 41-A of the Code of Criminal
Procedure and ruled thus:-
“7.3. In pith and core, the police officer before arrest must put a
question to himself, why arrest? Is it really required? What
purpose it will serve? What object it will achieve? It is only
after these questions are addressed and one or the other
conditions as enumerated above is satisfied, the power of arrest
needs to be exercised. In fine, before arrest first the police
officers should have reason to believe on the basis of
information and material that the accused has committed the
offence. Apart from this, the police officer has to be satisfied
further that the arrest is necessary for one or the more purposes
envisaged by sub-clauses (a) to (e) of clause (1) of Section 41
CrPC.”

64. That the rights of the petitioner has been destroyed through
his illegal detention in an unlawful manner by the Kadwa Police in
Bihar on 30
th
July, 2019, 20
th
May, 2022 and by the Church
Mission Road Police Post Fatehpuri, old Delhi under Lahori Gate
Police Station Delhi-6 on 10.06.2022 whereas the law provides a

48. procedure for arrest and equally for investigation and the
consequential trial. That is what has been interpreted by this Court
while dealing with Article 21 of the Constitution.

65. That lynching or any kind of mob violence has to be curbed
and crippled by the executive and no excuse can ever be tolerated
has been observed by the Supreme Court of India and laid down
preventive, remedial and punitive measures in “Tehseen S.
Poonawalla VS. Union of India and others” (2018) and Shakti
Vahini v. Union of India & others. 2018 (5) SCALE 51

66. The Committee on Reforms of Criminal Justice System
headed by Dr. Justice V.S. Malimath also noticed the plight faced
by several people due to non-registration of FIRs and
recommended that action should be taken against police officers
who refuse to register such information. The Committee
observed:-

67. That there is a sheer violation and deliberate overlooking of
certain provisions of Act to sustain the International Sex racket,
illicit sex trade, child sexual abuse, human trafficking and hidden
prostitution of Women and Children by the State which violates the
Fundamental Rights of Petitioner as well as Gang Rape Victims
guaranteed under Article 14, 15, 19(1)(a), 19(1)(g) and 21 of the
Constitution of India. Present Writ has been preferred under
Article 32 of the Constitution of India challenging violation of
provisions of :-

49. "7.19.1 According to the Section 154 of the Code
of Criminal Procedure, the office in charge of a police
station is mandated to register every information oral
or written relating to the commission of a cognizable
offence. Non-registration of cases is a serious complaint
against the police. The National Police Commission in its
4th report lamented that the police "evade registering
cases for taking up investigation where specific
complaints are lodged at the police stations". It referred
to a study conducted by the Indian Institute of Public
Opinion, New Delhi regarding "Image of the Police in
India" which observed that over 50% of the respondents
mention non-registration of complaints as a common
practice in police stations.
7.19.2 The Committee recommends that all complaints
should be registered promptly, failing which appropriate
action should be taken. This would necessitate change in
the mind -set of the political executive and that of senior
officers.
7.19.4 There are two more aspects relating to
registration. The first is minimization of offences by the
police by way of not invoking appropriate sections of
law. We disapprove of this tendency. Appropriate
sections of law should be invoked in each case
unmindfull of the gravity of offences involved. The
second issue is relating to the registration of written
complaints. There is an increasing tendency amongst the
police station officers to advise the informants, who
come to give oral complaints, to bring written

50. complaints. This is wrong. Registration is delayed
resulting in valuable loss of time in launching the
investigation and apprehension of criminals. Besides, the
complainant gets an opportunity to consult his friends,
relatives and sometimes even lawyers and often tends to
exaggerate the crime and implicate innocent persons.
This eventually has adverse effect at the trial. The
information should be reduced in writing by the SH, if
given orally, without any loss of time so that the first
version of the alleged crime comes on record.
7.20.11 It has come to the notice of the Committee that
even in cognizable cases quite often the Police officers
do not entertain the complaint and send the complainant
away saying that the offence is not cognizable.
Sometimes the police twist facts to bring the case within
the cognizable category even though it is non-
cognizable, due to political or other pressures or
corruption. This menace can be stopped by making it
obligatory on the police officer to register every
complaint received by him. Breach of this duty should
become an offence punishable in law to prevent misuse
of the power by the police officer."

68. That the focal point of fight is between Professional Social
Worker Versus Professional Legal Workers. Both are defending
the same clients by their own professional acumen, training, skills,
body of knowledge, vision, practice, procedure, methodology,
ethics, morale, principles, objectives, goals and style of
functioning. Herein, Petitioner is a Professional Social Worker

51. while Advocates and Judges are Professional Legal Workers.
Details of petitioner’s professionalism have been placed on court
records in the main petition of this case.

69. That Professional Legal Workers are obstructing the rescue
operation of Gang Rape Victims from the clutches of human
Traffickers State while Professional Social Worker is dying hard to
rescue the Gang Rape Victims from the clutches of human
Traffickers State.

70. That State is suppressing and obstructing the rescue
operation of Gang Rape Victims since 5
th
April, 2021. State
coercion has reached its peak crossing all limits.

71. That under the above circumstances, Petitioner has been
left to rescue them from Supreme Court of India through Writ
Petition (Criminal) Diary No.18546/2022.

72. That brain mapping of victims, rolling back of Sex
technologies, clubbing of F.I.Rs and requisitioning of lower court
records across the country is required in rescuing the state
sponsored gang rape/illicit sex trade victims from the clutches of
human Traffickers State.

73. That all Action Taken Reports supplied by Bihar and Delhi
Police annexed with dismissed Writ Petition (Criminal) No.
137/2021 to be taken into record in this case at the time of hearing
of this case.

52. 74. 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 Constitution of India.


i) FAMILY COURT ACT

ii) THE PROTECTION OF CHILDREN FROM SEXUAL
OFFENCES ACT, 2012

iii) THE JUVENILE JUSTICE (CARE AND PROTECTION
OF CHILDREN) ACT, 2015

iv) THE HINDU ADOPTIONS AND MAINTENAN CE ACT,
1956

v) DOMESTIC VIOLENCE AC 2005

vi) DOWRY PROHIBITION ACT, (SECTION 498A, ¾)

vii) HINDU MARRIAGE ACT 1955,

53. viii) THE INDIAN CONTRACT ACT, 1872

ix) THE INDECENT REPRESENTATION OF WOMEN
(PROHIBITION ACT), 1986

x) MAHARASHTRA PROHIBITION OF OBSCENE DANCE
IN HOTELS, RESTAURANT AND BAR ROOMS AND
PROTECTION OF DIGNITY OF WOMEN (WORKING
THEREIN) ACT, 2016

xi) THE INDIAN EVIDENCE ACT, 1872

xii) KIDNAPPING FROM LAWFUL GUARDIANSHIP

xiii) IMMORAL TRAFFIC PREVENTION ACT, 1986

xiv) THE PROHIBITION OF CHILD MARRIAGE ACT, 2006

xv) THE PREVENTION OF CORRUPTION ACT, 2006 (1949
A. D.)

xvi) THE BONDED LABOUR SYSTEM (ABOLITION) ACT,
1976

xvii) THE REPRESENTATION OF THE PEOPLE ACT, 1951

xviii) THE LAND ACQUISITION ACT, 1894

xix) THE PREVENTION OF MONEY -LAUNDERING ACT,

54. 2002

xx) THE ARMED FORCES (SPECIAL POWERS) ACT, 1958

xxi) THE ARMY ACT, 1950

xxii) THE ARMS ACT, 1959

xxiii) THE POLICE ACT, 1861

xxiv) THE BIHAR PROHIBITION AND EXCISE ACT, 2016

xxv) THE DRUGS AND COSMETICS ACT, 1940

xxvi) THE NARCOTIC DRUGS AND PSYCHOTROPIC
SUBSTANCES ACT, 1985

xxvii) THE INDIAN BAR COUNCILS ACT, 1926

xxviii) ADVOCATES ACT, 1961

xxix) INDIAN BAR ASSOCIATION ACT



PRAYER
It is most respectfully prayed that this Hon’ble Court may be
pleased to:

55. (a) Allow the petitioner to take additional facts/grounds/prayers
to answer the question of law raised in the Writ Petition
Criminal or to make out grounds urged in the Writ Petition
Criminal for consideration of this Hon'ble Court as the same
is very necessary in the interest & furtherance of justice.

(b) Not to list the present Writ Petition Criminal No. of 2022
during the tenure of Justice Mr. Uday Umesh Lalit, Hon’ble
Chief Justice of India to avoid bias.

(c) Consider all the cause of actions arose between 05.04.2021
to till date, reported through email and e-filing systems to all
Nodal authorities of Central and State Governments
including Supreme Court of India to establish the evidences
against the Gang Rape Victims by the State.

(d) Requisition the below Court records to establish the
evidences against Abuse of Court Process and Sexual Abuse
of Gang Rape Victims by the State.

(e) 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.

(f) 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,

56. Superintendent of Police Katihar and direct to register an
F.I.R to rescue the Victims from the clutches of prostitution
and human trafficking.

(g) 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.

(h) 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.

(i) Issue hang to death order against the guilty Public authorities
for suppressing the rescue of Gang Rape Victims, sustaining
the illicit sex trade of victims, violating the directions of
Supreme Court of India for registration of an F.I.R during
the course of matter Sub-Judies before the Hon’ble Supreme
Court of India.

b) Pass such other order/orders as this Hon'ble Court may deem
just and proper in the facts and circumstances of the case.

57. 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: [phone]
E-mail: [email protected]
NEW DELHI:
FILED ON : 20 -09 -2022

58. IN THE SUPREME COURT OF INDIA
CRIMINAL ORIGINAL JURISDICTION

CRL.M.P.NO. OF 2022
IN
WRIT PETITION CRIMINAL D.NO. 18546 OF 2022
(UNDER ARTICLE 32 OF THE CONSTITUTION OF INDIA)

AND

IN THE MATTER OF
INTERNATIONAL SEX RACKET,
CHILD SEXUAL ABUSE, FORCED
HIDDEN PROSTITUTION ABUSE OF
POLICE POWER, SUSPICIOUS
DEATH, AND MOB VIOLENCE/MOB
LYNCHING.

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 Subash Marg, Raj Nagar Part-II, Palam Colony,
New Delhi - 77, 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.

59. 2. That the contents of the accompanying application Under
Section 151 C.P.C. for additional documents, facts, grounds,
prayer in Writ Petition (Criminal) D.No.18546/2022, which
has been drafted by me [para 01 to 74], [Page 01 to 57 ] 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.

3. That the accompanying application Under Section 151
C.P.C. for urgent hearing total 59 pages.’


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 20 day of September , 2022.

DEPONENT