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Facts & proposed Prayers


Addresses | Facts & proposed Prayers

  1. That this notices is served upon the proposed State Defendants only, whom service of the Notice is mandatory. Though the word of th Private Defendants are rferred in prayer portion, but not referred in the body of the notice, will be inserted in the body of the Plaint. The names of the Private Defendants are referred in the facts referred in the Notice, and inserted accordingly. After expiry of the mandatory period of 60 days from the date of service of the notice, with the State defendants, if the State Defendants will not acts in accordance with their constitutiona and legal duties by taking appropriate actions in the matters referred and described in detail, hereinafter relates to growth and development of Mafiadom of the Private Defendants, and against illegal activities of the Private Defendants as well as criminal misconduct of the respective persons holding the then offices of the respective State Defendants, than after appropriate corrections and preparation of the Plaint, suit will be filed, before appropriate Court for appropriate reliefs, by me in my capacity as plaintiff.

    2. That this Notice is served upon the State Defendants in considerations of my constant, continuous, running, and prevailing till today which started in or about in the year of 1983, as described in detail, due to non-actions or support from the respective persons holding offices of the State Defendants, under gratification or political influence or otherwise, ignoring the States Constitutional and Legal responsibilities, obligations and duties, knowing fully allowed blackmailing activities against me, thus responsible for the growth and development of Mafiadom under the leadership of one unscrupulous businessmen turned mafia Mr. Sanjay Kumar Jhunjhunwala, one of the Director of M/S. Martin Burn Ltd., 1, R. N. Mukherjee Road, kolkata-700001, his associates including Chunilal Mukherjee, Chunilal Mukherjee, son of Late R. G. Mukherjee, 174/3/1, Dr. Akhoy Paul Road, Calcutta- 700 034, Mr. Manik Chand Sethia, his residential address not known, but one of his firm runs at care of Shri Bhikam Chand Bhansali, M/S. Arbind Enterprises, Room No.731, (Nand Ram Market), 4, New Howrah Bridge Approach Road, Calcutta-700001, adjudged Cheat Chittaranjan Ganguly, Village Tetulberia, P.O.Garia, Calcutta-700 088, Kamlesh Chandra Chattopadhyay alias Chatterjee, 13, J.K.Paul Road, Calcutta-700 038, Ava Rani Dey, Dipika Rani Bhattacharyya, both legal heir(s) of Late Nalini Mohan Dey, 10/10, Kalicharan Dutta Road, kolkatta-700 008, Shrawan Kumar Bhatter, his father Shankar Lal Bhatter, two brothers Sushil Kumar and Ashok Kumar Bhatter all 4 C/O, Shri Chandi Plastic Udyog, 53A, Futnani Chambers, Calcutta-700013, Raj Kumar Dhawan, his Son Chndra Sekhar Dhawan, C/O, Vinus Plastic Products, 25, Chhatawali Galli, Calcutta-700 012, Prabhu Dayal Sureka, 7C, Middleton Street, Calcutta-700 071, Sukumar Das, his all colleague tenants including Bishwa Nath Singh, Hemanta Kumar Patnayak all tenants residing at 21, Seal Thakur Bari Road, Kolkata-700038. I crave leave to refer the documents referred in the notice at the time of hearing of the Suit and place them as evidences in support of my pleadings, if necessary. Said Manik Chand Sethia claimimg himself as frontman of Shri Chandan Basu, and in support of his such claim he published one advertisement referring the name of one of the Company belongs to Shri Chandan Basu, in which he given his own Telephone Number for contact, with sole object to blackmail me.

    1. That from atrocities having with intensity suffered by me personally were caused by the said Sanjay Kumar Jhunjhunwala, his aforementioned associates under Politics-Bureaucratic-Crime-Nexus with Shri Jyoti Basu the then Chief Minister of West Bengal, residing now at Indira Bhawan, Salt Lake, kolkata-700 064, Shri Kamal Kumar Basu, the then Mayor of Kolkata Municipal Corporation, present address not known, Shri Chandan Basu, Son of Shri Jyoti Basu, residing in India at No. 28, C/F, 399, Salt Lake, kolkata-700 064, Shri Som Nath Chatterjee, Member of Parliament, P-514, R.B.Roy Road, Kolkata-700029, Dr. Manash Bhuinya, M. L. A., W. B., M.L.A.s Hostel, Kyed Street, Kolkata, Shri Hashim Abdul Halim, Speaker, West Bengal Assembly, Kolkata-700001, (hereinafter these politicians will be referred just by name) and other politicians and respective bureaucrats whose at the material time, holds respective offices of the State Defenandants, and others.

4. In the year of 1993-94 Government of India constituted and appointed a High Power Committee (Vohra Committee) headed by the then Union Home Secretary Shri N. N. Vohra. This is my strong belief that at the materials time documents available with the respective authorities relates to my sufferings of atrocities were examined by the said Vohra Committee, as the Report prepared by the Vohra Committee, which made public on 1st August 1995, corroborated with my sufferings of atrocities having intensity. Report interalia states : -

    • The nexus between the criminal gangs, police, bureaucracy and politicians has come out clearly in various parts of the country."

    • "Resultantly, such elements have acquired considerable political clout, seriously jeopardizing the smooth functioning of the administration and the safety of life and property of the common-man, causing a sense of despair and alienation among the people."

    • "These syndicates have acquired substantial financial and muscle power and social respectability and have successfully corrupted the government machinery at all levels and yield enough influence to make the task of investigating agencies extremely difficult; even the members of the judicial system have not escaped the embrace of the mafia."

5. That most danger part of the report was that "even the members of the judicial system have not escaped the embrace of the mafia". This part of the report was completely corroborating with my sufferings having with intensity in the respective matters as described hereinafter, which were caused with the support from their respective Advocates, thus severally damaged my right to justice which translated in to as infructuous and non-exists. They, with the help of their respective Advocates embraces several Judicial Officers including Mr. Jayanta Kumar Dasgupta, and Mr. J. C. Moulick, both of the then Munsif, Ld. 5th Court, at Alipore (Kolkata), Mr. A. K. Choudhury, the then Additional District Judge at Alipore, (Kolkata), Mr. A. K. Bhattacharyya, the then Member of West Bengal Cooperative Tribunal, Kolkata.

6. That the Union of India particularly Department of Revenue, Office of the Chairman of Central Board of Direct Taxes and its respective Sub-Ordinates particularly those were working at Kolkata under Income Tax Department, completely disobeying their duties protected tax-evaders and provided complete protections to black money of the said Sanjay Kumar Jhunjhunwala and Manik Chand Sethia and their aforementioned associates, thus encouraged their Mafia activities, against me. In most of cases they maintained silence, but if they responded, they done it under the consultations with the said Sanjay Kumar Jhunjhunwala as was appears from the Memo Letter No. ADIT (INV)/U-III(I)/CAL/97-98/2068 dated 15th October 1997 from Mr. M.W. Haque, Asst. Director of Income Tax (Inv), Unit III(I) in response to my Letter dated 21st October 1997 to the Finance Minister of India, and another Letter Dated 22nd October 2001 from Income Tax Department.

7. That the Union of India particularly Railway Ministry entered in illegal agreement in respect of Railway Land, situated under Shahapur Railway Officers Colony, New Alipore-Behala area, Kolkata, knowing fully for the monetary gain and benefit of the said Sanjay Kumar Jhunjhunwala, but without any public interests or considerations, thus encouraged his Mafia activities, against me.

8. That my suffering of severe atrocities having intensity was started in or after the year of 1982, when I purchased some properties, more fully described hereinafter. In the year of 1932 C. S. Survey was conducted in the then Bengal by the dominion Government of India. As per C. S. survey which is the public document known and called as the Records of Rights and in the respective Map the measurement of the properties comprised in C. S. Plot No. 307, 308 under C. S. Khatian No.530, and C. S. Plot No.309, 310, 311 and 311/995 under C. S. Khatian No.534, both Khatian within Mouza Shahapur, P. S. Behala, now within the ward No. 119 of the Kolkata Municipal Corporation Kolkata-700038, the total area of measurement were shown as 1.10 Acres which arrived equivalent to 66 Cottas (One Cottas = 720 Square Feet) . Subsequently in the year of 1956 R. S. Survey was conducted by the Government of West Bengal under the Land Acquisition Act 1953, and in the said R. S. survey area of measurement with reference R. S. Plots comprised in R. S. Plot No.194 and 195 under R. S. Khatian No.530, corresponding from C. S. Plot No. 307, 308 under R. S. Khatian No.530, and R. S. Plot No. 205, 206, 207 and 219 under R. S. Khatian No.534 corresponding from C. S. Plot No.309, 310, 311 and 311/995 under C. S. Khatian No.534, both Khatian within the Kolkata Municipal Corporation Ward No.119, Kolkata-700038, were also arrived more or less as 1.098 Acre which is more or less 1.10 Acres, equivalent to 66 Cottas, fully corroborating with the C. S. Survey held in 1932 as aforesaid.

9. That out of the aforesaid 1.10 Acre equivalent to 66 Cottas, land measuring 0.60 Acre equivalent to 36 Cottas comprised in C. S. Khatian No.530 was purchased in or about 1947, by one Nalini Mohan Dey from its the then Owners. Land measuring 0.50 Acre more or less equivalent to 30 cottas was comprised in C. S. Khatian No.530. One Balaram Pal, claiming himself as the owner of the said 30 Cottas of Land. During the period of 1947 and 1954 he executed Two / separate alleged Deeds in respect of the said selfsame properties comprised in the aforesaid R. S. Plot No. 205, 206, 207 and 219 under said R. S. Khatian No.534 corresponding from C. S. Plot No.309, 310, 311 and 311/995 under said C. S. Khatian No.534, within the Kolkata Municipal Corporation Ward No.119, Kolkata-700038. Out of two said alleged deeds one was executed in favour of one adjudged Cheat Chittaranjan Ganguly and another alleged deed were executed in favour of the said Nalini Mohan Dey since deceased, whose predecessors-in-interests are aforementioned Ava Rani Dey and Dipika Rani Bhattacharjee. Civil litigations were runs between the said Nalini Mohan Dey and said adjudged Cheat Chittaranjan Ganguly besides others. One administrative order was passed in 1955 by the Sub-Divisional Magistrate, Alipore, refusing application of said Chittaranjan Ganguly to deliver the said Deed allegedly executed by said Balaram Pal in his favour, after holding that the said alleged deed executed in favour of Chittaranjan Ganguly was benami and the Chittaranjan Ganguly was the Benamdar of said Balaram Pal. Since 1955, till date said Chittaranjan Ganguly never challenged the said administrative order. In a subsequent Civil Litigation, in which Nalini Mohan Dey and Chittaranjan Ganguly both were the parties, Judgment was pronounced, under which it was hold that the said Balaram Pal was not Owner of the said properties. As such deed executed by him whether in favour of Chittaranjan Ganguly or in favour of said Nalini Mohan Dey has "no legs to stand". However, in the said Judgment Court decided ownership of the Suit Khatian as well as Suit Properties on the basis of the "Records of Rights" prepared by the authorities of the State of West Bengal in the year of 1956 under R. S. Survey as aforesaid. All parties to the said Civil Litigation have relied upon the Records of Rights. Under the law too, said document is a valid evidence of the ownership, if not challenged by any party within the time limit subscribed by the law, from the date of knowledge. Therefore, Chittaranjan Ganguly was not any scope to challenge the same, since he aware about the same since 1956. As per the aforesaid "Records of Rights", Nalini Mohan Dey was forcible occupier of the Properties comprised in R. S. Plot No. 205, 206, and 207 within aforesaid R. S. Khatian No.534, since 1954, while one Rabindra Lal Chakraborty was forcible occupier of the properties measuring more or less 10 Cottas comprised in R. S. Plot No. 219 under said R. S. Khatian No.534, since 1951. Accordingly said Nalini Mohan Dey and after his demise, his legal heirs namely Ava Rani Dey and Dipika Rani Bhattacharjee were the owner of the properties measuring more or less 56 Cottas of Land out of aforesaid 66 Cottas, while said Rabindra Lal Chakraborty was owner of said rest more or less 10 cottas of land, as the claim of the Nalini Mohan Dey over the said properties was declared as "No legs to stand" on the basis of the Judgment of the trial Court, which was uphold unto the Honble Kolkata High Court.

10. Legal heirs of the said Nalini Mohan Dey namely Ava Rani Dey and Dipika Rani Bhattacharjee with malafide intentions, misguided me, beginning from 1982 with the help of their Lawyer Learned Mr. Swapan Kumar Chakraborty, Advocate. They falsely claimed in writing through their said Lawyer that they are owners of 70 Cottas of the land, and that out of 70 cottas of land one litigation is pending in respect of the properties measuring 3 Cottas 13 Chittakes 26 Square Feet only. Accordingly I entered in Agreement with the said Ava Rani Dey and Dipika Rani Bhattacharjee. But, subsequently, it was transpired that according to the Deeds in favour of said Nalini Mohan Dey (including the said Deed executed by said Balaram Paul) the Total area of the properties comprised within both R. S. Khatian No. 530 and 534 cannot go measured even a single Inch beyond 66 Cottas by any means or methods, which completely corroborated with the aforesaid C. S. Survey. Such 66 Cottas of land was inclusive the aforesaid 10 Cottas of the Land over which said Nalini Mohan Dey already lost his claim against said Rabindra Lal Chakraborty and his legal heirs That at the time of said agreement this was ample clear to said Ava Rani Dey and Dipika Rani Dey and their said Advocate that no litigation was pending as they falsely claimed in writing.

11. That accordingly, I purchased aforesaid 56 Cottas of the landed properties, from aforesaid Ava Rani Dey and Dipika Rani Bhattacharjee, through my nominees, comprised in R. S. Plot No.194 and 195 within R. S. Khatian No. 530, and R. S. Plot No. 205, 206 and 207 within R. S. Khatian No.534 within the Mouza Sahapur P. S. Behala within ward No.119 of the Kolkata Municipal Corporation, Kolkata-700038 and subsequently I also purchased the said rest portion measuring more or less 10 Cottas of the Land comprised in R. S. Plot No.219 from the legal heirs of said Rabindra Lal Chakraborty, through one of my Private Limited Company. Thus I had Purchased, entire aforesaid properties of 66 Cottas. However, out of the aforesaid 56 Cottas of the Land Ava Rani Dey and Dipika Rani Bhattacharjee admittedly executed Sale Deeds in respect of 35 Cottas of land, but for non compliance of some legal formalities, on thrir parts, they failed to execute the Deeds in respect of the properties measuring more or less 21 Cottas comprised in R. S. Plot No. 195 and 206, although full consideration money were paid by me and physical possession and power of Attorney for the same were delivered / executed along with other parts of the properties in my favour. As per the provisions of Income Tax Act I was owner of the aforesaid properties comprised in the R. S. Plot No.195 and 206 too. But, in the year of 1988 said Ava Rani Dey and Dipika Rani Bhattacharjee, under connivance with Sanjay Kumar Jhunjhunwala and his associates Chunilal Mukherjee and Kamlesh Chandra Chatterjee, intended to raise false and flimsy disputes against me, as such in the year of 1988, I filed Two Suits for Executions of Sales Deeds, in respect of the aforesaid properties comprised in the aforesaid R. S. Plot No.195 and 206.

12. That at the time of the purchase of the aforesaid property, I booked residential accommodations in the form of flats of the persons from my friend circle and relations including said Shrawan Kumar Bhatter. Subsequently I formed a Cooperative Society namely Nav-Surya Cooperative Housing Society and under my fiduciary relationship, with them, I made all those persons from friend circle and relations, who booked the flats with me as promoters / members of the said Society and under good faith and with good intentions I executed Sales Deeds in favour of the said Society without any payment of the consideration money. That at the time of purchase of the aforesaid properties there were 44 inhabitant families / Tenants under pendent Ejectment Suits, including aforesaid Sukumar Das and others. Since, I was a social-minded person since my childhood, as such immediately after purchase of the aforesaid properties I offered rehabilitation program for those tenants. After knowing about such rehabilitation program said Kamlesh Chandra Chattopadhyay entered in the matter behind the scene, with clear object to blackmail me, as he was very close political connections with Shri Som Nath Chatterjee, M. P. and Shri Jyoti Basu, the then Chief Minister of West Bengal.

13. That, however, I understood that my offer for rehabilitation of the tenants has given wrong signals to the wrong people who consider it as my weakness, as such they started constant and regular blackmailing activities against me, by various means and methods. Subsequently it was transpired that such blackmailing activities caused by the aforesaid Tenants, were results of abetment and criminal instigation from Kamlesh Chandra Chattopadhyay, as such I placed my said rehabilitation offer in writing by letter dated 29.12. 1982 by Registered Post to the Officer-in-Charge of Behala Police Station and all Leaders of the Tenants to make it clear that without prejudice the respective Ejectment Suits I have offered compromise with the then all Tenants for their rehabilitation. But, under complete ill advice from Kamlesh Chandra Chattopadhyay that if more pressure is created than they can get payment of large amount of money from me instead of said offer. In fact said Kamlesh Chandra Chattopadhyay acted to exploit monetary gains from me by using the alleged political ideology as political instrument in the garb of obstructions against the exploitations of the alleged weaker people.

14. That I made several negotiations with the then Tenants and made modification in my rehabilitation offers. One day Tenants entered in an agreement with me, under which both side agreed that compromise Petitions would be approved by Shri Som Nath Chatterjee, M. P. Since I had no bad intentions, as such a Meeting of the representatives of the Tenants, Local CPI (M) Leaders and myself was held at the residence of Shri Som Nath Chatterjee, M.P. But any of my negotiation has offered no advantage for the people behind the scene as such they worked only for failure of all negotiations.

15. That during the same period, Kamlesh Chandra Chattopadhyay successfully instigated the tenants, not to enter in any compromise. This is needless to place on the record that till then I have no intentions to eject or remove any of the then Tenants from the properties, though I was very strong evidence to eject those tenants through due Court proceedings. Even in Two of the Ejectment Suits Decrees were pronounced, but I ignore to file Execution Proceedings, till finally this was not proved that Compromise with Tenants were not Possible, and doors of Compromise were not closed. In fact, I was not aware that he has very strong political clouds and connections with Shri Jyoti Basu, and Shri Som Nath Chatterjee, M.P. under which he was competent to blackmail me. Actually said Kamlesh Chandra Chattopadhyay, misused his such political relations and stature, behind the scene, with sole intentions and objects to blackmail me, thus taken help from one Mr. Timir Baran Banerjee, Advocate and his Junior Mr. Kalyan Kumar Ghosh, Advocate, both from Alipore Judge Court of Kolkata, to embrace aforementioned Judicial Officer Mr. Jayanta Kumar Dasgupta. It was claimed in one of the Phumphlate published by the tenants that Mr. Som Nath Chatterjee M.P. claimed in writing that "I had never myself recommended any settlement or finalized any draft for settlement of the case.". This is needless to mention here that Mr. Som Nath Chatterjee M.P. on behalf of the Tenants, draft of compromise originally prepared by me, corrected through his assistant Learned Mr. Pranab Chatterjee, Solicitor. After knowing about alleged said letter written by Shri Som Nath Chatterjee, M.P., I sent photocopy of the corrected copy of the said draft, to Shri Som Nath Chatterjee, M.P, by Regd. Post, reportedly then the said earlier letter written by Shri Som Nath Chatterjee, M.P. was withdrawn from the respective locality.

16. That when this was become quite clear that in spite of all types of pressure tactics, I not bow down, then said Kamlesh Chandra Chattopadhyay used said Mr. Timir Banerjee, Advocate of Alipore Court of Kolkata to embrace the then Presiding Officer of the Learned Munsif, Alipore 5th Court, Mr. Jayanta Das Gupta to cause severe damages in the Court proceedings of the Ejectment Suits pending against the aforesaid tenants, which ultimately were caused by severe interpolations in several order sheets of respective suits. After knew about such interpolation, I filed 19 Application Under Section 340 of Criminal Procedure Code, before the Court itself and then placed detailed facts of such interpolations caused in the Order Sheets of the several Suits, by filing a Revision Application before Honble Kolkata High Court. Under my step, said Jayanta Kumar Dasgupta could have lost his judicial services. As such, on 25th November 1983, to blackmail me, I was lifted by force from the Court compound in presence of about 500 litigants, Advocates and others, with the help of Court staff. In fact Court Staff were used by Mr. Jayanta Das Gupta making false statement, that because of the me, their one of the colleague is going to loose his service. Said employee was physically disable to speak, and during the related period Mr. Jayanta Kumar Dasgupta kept him in captivity, as such till then fact was not known to the respective Court staff, as such they joined hands with the Peshkar of the said Court Mr. Narayan Babu to get arrested me in a fabricated case of theft of Court records. Actually their original plan was to call me in the Court Room then to get arrested me for alleged theft of Court records. But this strategy was failed, as I refused to comply the information given by the said Court Peshkar Narayan Babu that Learned Munsif had called me in Court Room, by replying that there no date is fixed for any Court matter relates to his Suits, nor I bound to go in the Court on verbal request of the Munsif. My this reply was in considerations of my steps against the Mr. Jayanta Das Gupta before Kolkata High Court, and subsequent threats given by him to my Advocates, that if they do not make me ready to withdraw my High Court proceedings, they will be get arrested. Under grace of the God when I was lifted by force, one senior reporter of the Telegraph was present at the scene, who collected requisite informations and published the true News story in the Telegraph within a Box in its issue dated 29th November 1983. After released on bail, from the said Criminal Case, I wrote letters to Chief Justice of India, Chief Justice of Calcutta High Court and other judicial authorities, and thereafter Honble High Court at Kolkata enquired the whole matter. The senior Police Officials enquired said Criminal Case against me. I was discharged from the said false case. Mr. Jayanta Das Gupta was dismissed from the judicial Services. The said dismissal order of Mr. Jayanta Das Gupta from the judicial service was the first such action in the judicial history of India. The matter of the lifting by force and get arresting me in a false case was also published in detail in the renowned Bengali Newspaper: Ananda Bazaar Patrika dated 4th January 1984, after a thorough enquiry.

17. Thereafter said Kamlesh Chandra Chattopadhyay got filed through the said Tenants one Title Suit being No.108 of 1983 before the Learned Court of 7th Sub-Judge Alipore, against me and my Cooperative Society. But, when I admitted before the Court that I have no intentions to remove any of my Tenant without due process of Law, then the Injunction Order passed against me was modified in such a manner, which actually become hurdles against blackmailing objects of Kamlesh Chandra Chattopadhyay. As a result, said Kamlesh Chandra Chattopadhyay, abetted one Lawyer in the said Suit for professional misconduct, thus Ld. Mr. Srikanta Bhattacharyya, Advocate, manipulated the impact of Order dated 19th September 1983, passed in the said Title suit No.108 of 1983 of 7th Sub-ordinate Judge, Alipore (Kolkata), and issued Certificate dated 17th February 1984 under heading "TO WHOM IT MAY CONCERN". After knowing about the same, I served Lawyers Notice dated 27th February 1984 upon Ld. Mr. Srikanta Bhattacharyya, Advocate. However, then he left from the Suit, as such I have no grievances against Ld. Mr. Srikanta Bhattacharyya, Advocate. However, because of the said order passed in the Said Title Suit filed by the Tenants I constructed boundary wall surrounding entire properties comprised in R. S. Plot No. 194, 195, 205, 206 ands 207 as aforesaid.

18. That, in fact in or about in the year of 1984 said Kamlesh Chandra Chattopadhyay joined hands with Chunilal Mukherjee, Sanjay Kumar Jhunjhunwala and adjudged Cheat Chittaranjan Ganguly. Thereafter, they formed Mafiadom, under black money powers and leadership of Sanjay Kumar Jhunjhunwala, with object to grab all properties from the locality, including my property, if required with the help from Shri Jyoti Basu. There were political connections between Shri Jyoti Basu and said Kamlesh Chandra Chattopadhyay, which were further developed when some underhand agreement between Shri Jyoti Basu and Directors of M/S. Martin Burn Limited including said Sanjay Kumar Jhunjhunwala were developed through one close friend of Shri Jyoti Basu, namely Mr. Shrawan Kumar Todi.

19. That after development of such Mafiadom said Kamlesh Chandra Chattopadhyay abetted and instigated those Tenants for some criminal acts against me, as such aforesaid Tenants with the help of one anti-social of locality namely Gopal Das, decided to manufacture BOMBS to kill me. On or about 2nd March 1984, some of the Tenants and said anti-social Gopal Das were busy in manufacturing of the Bomb. At this moment, one tenant was smoking Cigarette. Suddenly ash of the Cigarette fallen on the accumulated materials for manufacturing of the Bomb, thus blasted the fire. Resultantly, said anti-social Gopal Das and one of the Tenants were burnt seriously. When tenants were busy to take both of injured persons for the Hospital, Police caught them red handed, as such a false story was created. Said Gopal Das was Bengali by birth, while one Oriya lady-Tenant under the advice and abetment from said Kamlesh Chandra Chattopadhyay lodged First Information Report based on false story that my alleged agents thrown Acid Bomb upon his own brother Gopal Das, and referred his wrong cast as an Orriya. Kamlesh Chandra Chattopadhyay using his political connections meet with Shri Snehangshu Acharya, the then Advocate-General of West Bengal, and represented him the said false story. Shri Snehangshu Acharya, telephoned to Director General of West Bengal Police conveying the same false story and also Telephoned to the District Judge of Alipore that if Mr. Milap Choraria (myself), apply for anti-cipatory bail I should not be granted the bail and further Telephoned to Senior District Police Officers to arrest me. As such the then Superintendent of Police 24-Parganas Mr. K. K. Kalia, I.P.S., and the then Deputy Superintendent of Police Shri Md. Nizam rushed to Behala Police Station and armed Police were deployed at my property.

20. That when aforesaid Police Officers were in Behala Police Stations and were busy to discuss the incident, one honest C P I (M) Leader was also present in the said Office Room of the Police Station. When Mr. Kalia ordered for my arrest, said CPI (M) Leader considering my social mind-set, and also knows about the characters and connections of Kamlesh Chandra Chattopadhyay, telephoned me through another person, that Police is coming to arrest me, as a result I flead from my residence along with my family members, to save myself from arrest, till I does not know the reality behind the incidence. Subsequently, this was came to my notice that during the discussions, in the mind of Mr. Kalia some doubts were cropped up, about the story reported by Shri Snehangshu Acharya, as such he instructed Shri Md. Nizam Deputy Superintendent of Police to go and see personally to the burnt persons in Hospital. Shri Md. Nizam went in two different Hospitals, where Gopal Das and burnt Tenants were hospitalised. After coming back, said Police Officer reported that the map of burning of the both victims are not from the Acid Bomb, but clearly suggesting that they were engaged in manufacturing of the Bomb. As a result, Mr. Kalia, telephoned to Shri Snehangshu Acharya, that story conveyed by him is based on total lie, and instructed to the local Police Officers not to arrest me.

21. That since I was not aware about the aforesaid developments, as such I filed anti-cipatory bail application. When my Advocate moved anti-cipatory bail the then Presiding Judicial Officer of the Court of District Civil & Sessions Judge, Alipore, says in open Court that he received Telephone from Shri Snehangshu Acharya, not to grant bail to me. He further mentioned that during his enquiry with regards to the matter relates to said Mr. Jayanta Kumar Dasgupta, he was appreciated the conduct of Mr. Choraria (myself), but from this matter, he was socked that Mr. Choraria might be a criminal. However, Honble District Judge granted temporary anti-cipatory bail to me and directed the Police to present case Diary of the matter. When case Diary was presented before the District Judge, Police said that No case is pending against me in the respective matter.

22. That when said Gopal Das was released from the Hospital, he needed further treatment and valuable Ointments to be used in large areas of his burnt portions of the body. As such he meet with the Tenants for help. Since his use was no longer required to the tenants, as such they thrown him out of the Properties. Thereafter, said Gopal Das meet me for medical help on humanitarian grounds. Considering his enemy activities against me and his backgrounds, I taken him in the Police Station, where Police Officer ask him to reveal the real story behind his burning, which he revealed admitting his engagement along with the Tenants in manufacturing of the Bombs. Thereafter, I ask said Gopal Das, that he must put the matter on record, then only I can help him. Since Gopal Das was not aware writing as such he placed entire story on paper in Bengali script through the hand and pen of his wife, in presence of one of my person. I got translated and typed it on one stamp paper and with consent and signature from Gopal Das placed it before Executive Magistrate, 24-Parganasd in the form of Affidavit. In consideration of the materials of serious in nature said affidavit was rejected, but even then same was become a rejected but valid document of evidence, as document No. 5887 dated 14.5.1984. After going by the aforesaid handwritten noting and said rejected Affidavit Police advised the Gopal Das, that if he can show courage to admit the truth, Police will forward him before the Judicial Magistrate, after arresting him, but same can cause problem for him, because he may be punished for his involvement in manufacturing of the Bombs. Since under the rough behave adopted by the aforesaid Tenants Gopal Das was annoyed against the Tenants as such was ready to suffer every thing against admission of real story. Thereafter Police arrested and send him before Judicial Magistrate, where he revealed entire story in verbatim of incidence and further revealed the story related with the theft of my One Generator and Type Writer by the tenants with his help, which earlier he did not disclose before me. However, under the political influence or otherwise, ignoring its responsibility nothing was done by the Police against any of the accused in the aforesaid matters, which ultimately encouraged the said tenants for further crimes, including attempt to kill me.

23. That on 10th April 1984, I filed a Writ Petition being No. C.O. 4044(W) of 1984 for Police help before Calcutta High Court and moved it in the Honble Court of B. C. Basak, J as he then was, and after hearing the same His Lordship passed appropriate order. But, within few days, without filing any written Affidavit or petition, learned Mr. Dipankar Gupta, Bar-at-law, appeared in the said matter on behalf of the Respondents and against me and used sentimental pleadings submitting before the Honble Court that he is appearing on behalf of his poor driver, falsely submitting that I was intended to remove his driver, as such he is moving the matter without taking any fees. Under the embrace of his sentimental pleadings, Honble Court stayed its earlier Order dated 10th April 1984. Subsequently, Respondents in the said matter, filed their Affidavit-in-opposition, based on the total false statements. However, I send a protest letter to Learned Mr. Dipankar Gupta, Bar-at-law, against his, ill pleadings, based on such false statement, which helped the blackmailing activities, runs by the said Mafiadom. However, on 9th May 1984, the Honble Court, without considering the matter on merit, but under embracement from such pleadings forwarded by Learned Mr. Dipankar Gupta, Bar-at-law withdrew the said earlier order dated 10th April 1984.

24. That when modified order in Title Suit No. 108 of 1983 of the Learned 7th Sub-Judge, Alipore causes reverse impacts against the interests of the said Mafiadom, then under their direct connection and Nexus with Shri Jyoti Basu, issued one written order under his Pen, and hand, directing Mrs. Ranu Ghosh, I.A.S., (not Mrs. Ranu Ghosh, another I.A.S. Officer) the then District Magistrate 24-Parganas to remove Milap Chand Choraria (myself) from the (alleged properties of said adjudged Cheat) Chittaranjan Ganguly. After going by the said order Mrs. Ranu Ghosh, I.A.S., forwarded the said order to Shri Md. Nizam, the then Deputy Superintendent of Police, with instructions to comply the order of the Chief Minister. Shri Md. Nizam, till then though not meet me personally, but as he was investigated part of the said matter of burning of said Gopal Das, as such he knows about me, as such without complying the said Order, send a written message dated 23.1. 1985 through Officer-in-Charge Behala Police Station, asking me to meet him immediately. When on 30.1.1985 I meet with Shri Md. Nizam, he shown the order of the Chief Minister and subsequent order from Mrs. Ranu Ghosh. During the discussions he said that he dont want to do any thing illegal, as such if I have to say anything he will allow me. I submitted detail facts by letter dated 1st February 1985 addressed to Shri Md. Nizam, with copies to Shri Jyoti Basu and Mrs. Ranu Ghosh. After receipt of the aforesaid letter from me Mrs. Ranu Ghosh, IAS, issued fresh orders withdrawing her earlier order.

25. That after failure in said attempt, said Mafiadom decided to cause fresh pressures by encroaching my properties. After knew about the same I served Lawyers Notice upon said Chunilal Mukherjee. After receipt of the said Notice he under connivance with the respective Police Officer changed his strategy and lodged one false Criminal Case that Milap Chand Choraria (myself) demanded Rs.20,000/- from him. The object of the said false criminal case was to get arrested me, if I will try to restrain him from encroaching my property. But, I taken appropriate steps against him, as such for time being, he stopped his blackmailing activities against me, admitted in writing that the Criminal Case filed by him against me was untrue by his letter dated on 6th February 1986, addressed to Officer-in-charge, Behala Police Station, with copy to me.

26. Thereafter Sanjay Kumar Jhunjhunwala started to develop personal rapo with me, even some time fraudulently claimed that he is going to Golf Club, thus dropped me at my residence, with object to develop connections with the alleged other members of my Cooperative Society, who then were resident of the same building. He meets secretly with my Tenants and abetted them that they cannot win the Ejectment Suits run by me. If they want to live on the properties, they should send me to hell. A plot was hatched by Sanjay Kumar Jhunjhunwala with the help of his associates and tenants to kill me, thus on about 18th July 1986 a severe attempt to murder me was committed, by the family members of the Tenants in which I suffered 42 stabs in my body. This was reported by some one that the then Area Councilor Mr. Bhola Nath Mukherjee, 341/4, Diomond Harbour Road, Kolkata-700038 on behalf of Sanjay Kumar Jhunjhunwala gratified the Police Officials, and arranged to bail out one of person who attempted to murder me. As such on 8th October 1986 I send a protest Letter to said Shri Bhola Nath Mukherjee, the then area Councilor, with copy to Police.

27. That after attempt to kill me, when I was in Hospital, said Sanjay Kumar Jhunjhunwala came under alleged curtsey call to know about my health, though his real object was different. During the said visit he informed me that he has one friend in the Daily English Newspaper The Telegraph and already ask him to publish one story related to attempt to my murder. However, on those days one regular feature under the heading "CALCUTTA ROUNDUP" published in the said Newspaper. On 6th October 1986 one News Item was published in the Telegraphs said feature, with the specific heading for specific News item as "Antisocials terrorise slumdwellers". This News was come to my notice only on 22nd October 1986. After going by the said News I send a strong protest Letter to Mr. Aveek Sarkar, Chief Editor of Ananda Bazar Patrika Group of Newspapers (In the letter by mistake I referred him as Chief Reporter), Mr. M. J. Akbar, the then Editor of the Telegraph, Mr. Pabitra Kumar Mukherjee, the then Publisher and Publisher of the Telegraph, said Reporter Mr. Tapash Kumar Chakraborty, with a copy to the Officer-in-Charge, Behala Police Station all by Registered Post, describing the said news as "ULTA CHOR KOTWAL KO DANTEY", and after giving detail facts requested thereby that "So this is my humble request through the Telegraph to the Government, that for justice to all, allegations of the residents with regards to alleged incidents of 18th July 1986 and 29th August 1986 as published in the Telegraph and Behala P. S. Case Nos. 91(`12)83, 106(2)84, 4(3)84 and 67(7)86 and my allegations of blackmailing and criminal conspiracy against us should be handed over to C. B. I. for proper investigation and actions, so actual criminals would be punished." I dont know what actions were taken by the management of the Telegraph, but after receipt of the said letter for a long period name of respective Yellow Journalist Mr. Tapash Kumar Chakraborty disappeared from the Telegraph.

  1. That during my Hospitalisation, Sanjay Kumar Jhunjhunwala with object to create physclosical heavy pressure upon me got obtained a letter, allegedly have been written by my ejected Tenants. In fact those tenants themselves vacated the respective Rooms, when in the respective execution proceedings, order was passed for their evictions with the police help, with respect to respective decrees passed against them. They admitted before the Learned Court recording their written admission in Court proceedings that Police need not be deputed, as they will vacate the respective rooms voluntarily, within the Period of Order. All these tenants were the then inhabitants of the said R. S. Plot No. 206. In the said letter this was tried to described and establish through false story that I am a dreaded criminal and removed the aforesaid Tenants by force. After going through the letter I understood that the story referred therein is totally false and frivolous. Sanjay Kumar Jhunjhunwala forwarded said Letter along with his covering Letter dated 5th August 1986, after my return from the Hospital. I wanted to know that who was behind the letter, as such, I shown the said letter, to the Evicted Tenants, who not only surprised, but declared that the Thumb impression of them are forged and even spelling of the Name of tenants were not correct in the said letter. I also ask Sanjay Kumar Jhunjhunwala about authenticity of the Letter, which was never given. However, considering non-impact of the said created letter, Sanjay Kumar Jhunjhunwala created another concocted story and informed me. From such developments, doubt was started in my mind about the character and conduct of Sanjay Kumar Jhunjhunwala that he himself might be behind the scene and possibility he himself directly may be involved in the Plot to kill me, which subsequently was confirmed on private enquiry. As such I ask him that either he will not maintain any relationship with me in future, otherwise he should put the information given me in writing. As such he confirmed the said fake story in writing by his letter dated 5th November 1986. From the said fake story Sanjay Kumar Jhunjhunwala wanted to convey me his threats that he is in position to remove me from my Properties with the help of the then Commissioner of Kolkata Police Mr. Bikas Kali Basu, IPS. On the basis of the said Letter I requested Mr. Bikas Kali Basu, IPS that since his name is dragged in the story, he should find out the alleged Advocate, referred by Sanjay Kumar Jhunjhunwala in his letter, but Mr. Bikas Kali Basu, IPS, just acted to protect Sanjay Kumar Jhunjhunwala.
  2. That when attempt to my murder was failed then in the same year of 1986 Shri Jyoti Basu instructed to Shri Kamal Kumar Basu the then Mayor of the Kolkata Municipal Corporation to help Sanjay Kumar Jhunjhunwala. Accordingly, under his desirous, on 14th November 1986, Kolkata Municipal Corporation created a fake Municipal Holding Number as 161 Vinoba Bhave Road, Ward No.119 Kolkata-700038, in favour of said Chittaranjan Ganguly. This is matter of great concerns that much before creation of such fake Municipal Holding number, said Sanjay Kumar Jhunjhunwala informed me by his said Letter dated 5th November 1986 in writing that Municipal Holding No. 161 is exists in the name of said Chittaranjan Ganguly, which is evidence of his nexus and connivance in the matters against me.

30. To help blackmailing object of the said Sanjay Kumar Jhunjhunwala Kolkata Municipal Corporation on the basis of said created fake Municipal Holding Number revoked my two sanctioned plans on the false grounds that I obtained sanctions of the Building Plans under misrepresentations about the ownership. I moved before Honble Kolkata High Court, the said Order of Kolkata Municipal Corporation was set-aside, by Judgment dated 31.3.1988. Since, Kolkata Municipal Corporation was working under instructions from Shri Jyoti Basu, through Shri Kamal Kumar Basu, as such by any means Corporation was determined to obstruct my constructional activities to damage my reputation in the respective field as such once again revoked the said two Plans on the further false interalia grounds that respective land has no passage for igress or ingress. Before passing the said Order by the Kolkata Municipal Corporation, Shri Kamal Basu called me through one Councilor Shri Shanti Lal Jain and conveyed me that if I want to live in Kolkata, I should transfer the property to the Sanjay Kumar Jhunjhunwala. In respect of the said subsequent Order of Revocation of the Plans, Honble Kolkata High Court directed to Kolkata Municipal Corporation to withdraw its illegal Order of revocation of plan.

31. That as the said Sanjay Kumar Jhunjhunwala and his associates including Chunilal Mukherjee made long strategy to blackmail me through various flimsy litigations, as such they attracted and entangled my Vendors namely Ava Rani Dey and Dipika Rani Bhattacharyjee in their blackmailing activities. This fact was confirmed when I received a letter from the Grand Daughter of Ava Rani Dey and Daughter of Dipika Rani Bhattacharjee namely Mrs. Ratna Bhattacharjee, of 10/10, Kali Charan Dutta Road, Kolkata-700061. From the said letter, this was further confirmed that said Chunilal Mukherjee, being associate of said Sanjay Kumar Jhunjhunwala was in regular touch with Ava Rani Dey and Dipika Rani Bhattacharyjee and got filed a Civil Suit against me. This was already explained in detail that total measurement of the respective properties comprised in Khatian No. 530 and 534 was and by any means and methods cannot go beyond 66 Cottas, including the properties over which they have lost their claim over properties comprised at R. S. Plot No.219 measuring more or less 10 Cottas, because Civil Court held that Deed Executed by the Balaram Pal was "no legs to stand" as he was not the Owner of the Properties referred in Suit Khatian as well as the Suit Land of the said Suit, and Court decided ownership on the basis of the document admitted by all parties to the Suit, i.e. "Records of Rights", being a valid document under the prevailing Law also, if not challenged within limited prescribed period from the date of knowledge or its publication, by the authority. According to the Records of Rights said properties measuring more or less 10 Cottas of land was in forcible possession of the legal heirs of one Rabindra Lal Chakraborty. Since the object of the said Mafiadom behind filing of the said suit through Ava Rani Dey and Dipika Rani Bhattacharjee was to blackmail me, as such said Ava Rani Dey and Dipika Rani Bhattacharjee who not comes to Court with clean hands, under arithmetical manipulations of the measurement of land against actual and physical area of 56 Cottas, referred the Suit Properties as 94 Cottas thus misused platform of the "Administration of Justice", and further referred aforesaid 6 C. S. Plots and 6 Corresponding R. S. plots as 12 individual Plots, without referring their identification as C.S. or R. S. Plots. This was a punishable Crime under Section 340 of the Criminal Procedure Code.

32. That in consideration of such manipulations, Plaint of the Suit should have been returned (rejected) in limini. But from the subsequent developments, this was become quite clear that suit was filed under embracement of the respective Judicial Officer Mr. J.C. Moulick as such he passed Injunction Order against me. I filed Appeal against the said Injunction Order. After hearing of the Appeal, Learned Additional District Judge Mr. A.K. Chowdhury, made comment in open Court that in considerations of such criminal manipulations he will return (reject) the Plaint of the Suit at limini and going to pass order to that effect. But, the reasons best known to him he withheld passing of the order for few days. When he passed the Order, under most surprisingly he upheld the said injunction order passed by the Court of the 5th Munsif, Alipore. As such I filed Revision Application before the Honble Kolkata High Court. At the 1st instance of hearing Honble Court satisfied that the Order of the Munsif was unjustified, and was ready to set-aside the same. At this stage my Senior Lawyer Learned Mr. Shakti Nath Mukherjee, Bar-at-law argued that in considerations of the open manipulations in the plaint he wants to make complete argument in the matter to enable Honble Court to pass a Rule to reject / return of the Plaint. Honble Court agreed with the aforesaid argument and fixed the matter for final hearing. Under development of such adverse situation against the blackmailing objects, the Advocate of the said Mafiadom started to influence my Advocate-on-record Mr. Gouri Shankar Gupta, Advocate. As such initially Mr. Gouri Shankar Gupta, Advocate suggested me for some compromise. When I refused to accept his proposal, he entered in some underhand criminal agreement with the opposite Party, as such one day when matter was called for hearing, and even Honble Judge was ready to passover the matter to hear the arguments from Ld. Mr. Shakti Nath Mukherjee, Bar-at-law, who also send the message for Passover of the matter for some time, as he was busy in another Court with other matter, but Mr. Gouri Shankar Gupta, Advocate even ignoring strong objections from me in open Court, moved the matter through another Lawyer and submitted knowing fully incompetent arguments. As a result, the same Order was passed by the Honble High Court, which Honble Court was ready to pass earlier after initial hearing of the Revision Petition. The order of the Munsif was set aside and matter was returned for further hearing. As the matter of the fact that the area of the suit properties was manipulated from the actual physical area of 55 Cottas to 94 Cottas just to obtain Injunction Order which was not due under the law, even against admittedly sold properties of 35 Cottas sold me and said 10 Cottas of Land, over which said Ava Rani Dey and Dipika Rani finally lost their claims.

33. That Learned Mr. J.C. Moulick, again passed injunction Order against me overruling 16 different Rulings given by the different High Courts and further over ruling the principles laid down by the Supreme Court for granting of the Injunction Orders, which I pleaded in writing through my Advocate. I further argued in writing that since I am defendant in the Suit, so my argument may not be considered as bonafide, but the documents filed by the Plaintiffs of the said Suit namely Ava Rani Dey and Dipika Rani must be taken into consideration for the passing the Order of Injunction. Since the documents referred therein by the said Plaintiffs have shown the measurement of the aforesaid 6 Plots just as 66 Cottas, including aforesaid 10 Cottas of Land over which Ava Rani Dey and Dipika Rani Bhattacharjee lost their claims. But, Mr. J. C. Moulick, ignoring all those 16 Rulings of different High Courts, evidences relied upon by the Plaintiff themselves, and directions passed by the Honble Mr. Justice A. K. Nandi, of Kolkata High Court, just giving flimsy grounds that "court cannot embark upon at this stage" for not relying upon the documents filed by the Plaintiff / Petitioner of said Suit, i.e. Ava Rani Dey and Dipika Rani Bhattacharjee, thus openly misused his judicial powers under clear connivance with the aforesaid Mafiadom to support their blackmailing activities thus passed injunction order against me. In considerations of such acts and Deeds I filed Complaints before Bar Council of West Bengal against Mr. Tapash Kumar Sarkar, Advocate of the said Ava Rani Dey and Dipika Rani Bhattacharjee and filed Applications for Prosecution Permission against Learned Mr. J.C. Moulick, the then Presiding Officer of the Learned Court of Munsif and Learned Mr. A. K. Choudhury, the then Presiding Officer of the Additional District Judge, Alipore.

34. That after said Attempt to murder me Sanjay Kumar Jhunjhunwala comes several times to Hospital allegedly to know about my health, where he developed connections with one Shrawan Kumar Bhatter and his father Shankar Lal Bhatter, who also booked the flat with me. When I was discharged from Hospital and came to residence, said Shrawan Kumar Bhatter along with his father Shankar Lal Bhatter meet me and says that when Sanjay Kumar Jhunjhunwala interested to purchase the property and ready to give me good money, why I am not selling it to him. When I refused to accept such proposal said Shrawan Kumar Bhatter and his father Shankar Lal Bhatter started to meet each person, who booked flats with me and made promoters / members in my Cooperative Society, to create pressure upon me taking advantage of their Membership in my said Cooperative Society. This is matter of fact that till then, starting from 1982, said Shrawan Kumar Bhatter or his father Shankar Lal Bhatter never go to the property, as they have to do nothing with it as it was absolutely belongs to me, except they have booked their respective Flats thus were entitled to get their respective flats, on the terms and conditions agreed upon between both side. But, when the said Mafia gratified them offering huge amount, against misuse the card of membership of the Cooperative Society to create pressure upon me to compelled to sell the properties to him.

35. That in the meantime, I got sanction of Plan for the constructions of Buildings from Kolkata Municipal Corporation, thus I called a Special general meeting of the my Cooperative Society to confirm the Allotment of the proposed flats as per sanction Plan. Such meeting was held on 6th September 1986 in accordance with the agenda and Allotments were made for the proposed flats from the northern side proposed Building in favour of 15 persons considering the required area of each person and proposed flats of Southern side building were allotted in favour of 8 Members in considerations of their requirements. In those two building each and every proposed Flats were allotted in favour of all 23 existing (except me) Members. None were deprived in allotment. Said two proposed Building has to be constructed at the properties comprised at said R. S. Plot No. 206. In accordance with the agenda and proposal, the tenanted properties comprised in R. S. Plot No. 194 were allotted and transferred in my favour and delivered physical possession thereof through Execution of Agreement. 17 Members, including Raj Kumar Dhawan and his Son Chandra Sekhar Dhawan, attended the said Special General Meeting. Out of rest 7 Members 2 Members telephoned me informing the reason of not coming in the meeting, while Five Persons namely Sushil Kumar Bhatter, Shrawan Kumar Bhatter, Ashok Kumar Bhatter (Three brothers from the single joint family), Prabhu Dayal Sureka and Sushil Kumar Tulsian informed me that they are not interested in Allotments, but to see the sale of the property to said Sanjay Kumar Jhunjhunwala. As such with malafide intentions they not attended the said Meeting.

36. That under the Cooperative Law enquiry of working of any Cooperative Society can be sought, with the strength of one third of total members. At that time, total number of Members of the Society were 24 as such one third could have been achieved by support of eight members. Said Shrawan Kumar Bhatter and his father Shankar Lal Bhatter even after all efforts could not get support from more than 5 members, so they criminally abetted to said Raj Kumar Dhawan and his Son Chandra Sekhar Dhawan to join with them ignoring their attendance and signatures on Acceptance of the Allotment Letters and witness on the execution of said agreement in my favour. So total strength becomes 7 persons including said Raj Kumar Dhawan and Chandra Sekhar Dhawan. To comply terms of support of one thirds of the member strength, the said Group of Five persons plus said two newly joined persons, they got obtained signature from one Non-Member Dharam Chand Jain as if he is also amongst aforesaid 24 Members of the Cooperative Society and applied for order of enquiry. Since they were having backing from Shri Jyoti Basu, as such Cooperation Directorate was in their full support. But, suddenly this came to my notice about signature from said Dharam Chand Jain as such I served Lawyers Notice upon the Cooperation Directorate.

37. That in fact whatever working of the said Cooperative Society was going on, whether it was wrong or right, it was within full knowledge of and with full consent from the said group comprised of 7 person (Sushil Kumar Bhatter, Shrawan Kumar Bhatter, Ashok Kumar Bhatter (Three brothers from single joint family), said father son duo Raj Kumar Dhawan and his Son Chandra Sekhar Dhawan, Prabhu Dayal Sureka and Sushil Kumar Tulsian. But, after said Attempt to murder me, their behave were changed, and they taken actions for enquiry with clear object to blackmail and compelled me to sell the property to said Mafiadom. Since, they knowing fully not taking appropriate steps if any in time, they relinquished their grievances. As such they have no grievances against whatsoever was going on by the working and affairs of the Cooperative Society. Any thing new was happens, was the attempt to murder me, being caused under a plot hatched by Sanjay Kumar Jhunjhunwala and his associates. However, my Cooperative also took appropriate steps considering their such changed behave, but completely in accordance with the Cooperative law and Rules. However, then I was not aware that Shri Jyoti Basu personally is involved in the matter and supporting such blackmailing activities. Directorate of Cooperation after receipt of Notice from my lawyer changed its strategy, and decided to hold the enquiry in the garb of Inspection, ignoring the specific legal provisions for the Housing Cooperative Societies. Such decision was taken in serious violation of the law. It is needless to be mention that Membership of aforesaid 7 persons were also ceased automatically in accordance with the law, which was intimated them in time.

38. That as stated above the pure object of the aforesaid 7 persons were not to protect their own interests, but to blackmail me as such they make a strategy. For instance, if such refusal of enquiry in the garb of inspection could have been any cause of action, the aforesaid 7 persons should have joined in a single dispute case, but under the aforesaid object to blackmail me, one Dispute Case was filed in or about January 1988, by single person out of aforesaid 7 persons namely Shrawan Kumar Bhatter. But, as there were various anomalies in the Plaint, including relates to limitation point, Mr. Mihir Ranjan Choudhury, the then Assistant Registrar of Cooperative Society was not satisfied with the alleged Dispute, as such, till 30th May 1988, said matter was not registered as a Dispute case. However, subsequently, on 30th May 1988, under -behind the scene-, pressure said matter was recorded as Dispute Case No. RCS/43 of 1987-88 of the Registrar of Cooperative Societies and Shri Arjun Mondal, ARCS, was appointed as the Arbitrator to adjudicate the alleged matter in dispute.

39. That under the West Bengal Co-operative Law, once a person is appointed as Arbitrator in any Dispute Case, he cannot be replaced without compliance of conditions laid down by the said Law. Subsequently this might have been presumed that object of blackmailing to me might not be served from said Arjun Mondal, as such after 66 days from the registration of the said Dispute Case, under instructions from Mrs. Mira Pandey, IAS, the then Registrar of Co-operative Societies, on 5th August 1988, file of the said Dispute Case was handed over to one Mr. N. Goswami, CDO, without his appointment or any authority as Arbitrator. Since said Mr. N. Goswami was not an apponted arbitrator as such he knowingfully conducted the matter in most absurd and illegal manner, and intentionally withheld the supply of the certified copy of entire order sheet for about Ten Months, which was supplied on 6th January 1990 when Mr. N. Goswami, completes his illegal job, assigned by the said Registrar to pronounce predetermined but illegal Award, with sole object to help blackmailing activities of the said Mafiadom. After receipt of the certified copy of the entire Order Sheet of the said Dispute Case No.43/RCS/88-89 fact was came to my notice that Mr. Arjun Mondal, ARCS, was appointed the Arbitrator in the matter, while Mr. N. Goswami, adjudicated the whole matter without any appointment or authority.

40. That after going through the certified copy it appears that at the left portion of the first page of the Certified copy date was corrected by the pen, but without any initial of concerned authority, as such I returned it to the West Bengal Co-operative directorate for initial at said correction. On 1st February 1990 the said selfsame Certified Copy was returned to me, after noting at the said corrected left part of it that "Corrected on verification of record."

41. That I filed Appeal, against such illegal adjudication conducted by said Mr. N. Goswami, without having any appointment and authority. After receipt of the Order from the West Bengal Cooperative Tribunal to send the records of the said Dispute Case, the then Registrar Mrs. Mira Pandey came to know about the filing of the Appeal and its grounds. Than said Mira Pandey and said Mafiadom, understood that their aforesaid illegal and criminal labour through Mr. N. Goswami may become futile, as such under a criminal conspiracy and with the help of said Mr. Mihir Ranjan Choudhury, ARCS, forgery of the 1st and 2nd page of the Order Sheet was committed to insert the name of Mr. N. Goswami. The Office of Registrar regularly used the format of the 1st page of the Order Sheet from the printed forms printed at the Government Press, containing print order numbers. But the said forged Order Sheet was prepared on Electronic Type Writer, though at the material time the office of Registrar was not the facility of the Electronic Type Writer. Secondly in the said forged Order Sheet, the name of Plaintiff and the Defendants were recorded by the said Prabhu Dayal Sureka, being one amongst aforesaid 7 persons, whose Membership was ceased by operation of Law and who was not the Government Employee, as such he was not entitled to fill-up the Order Sheet. However, Mihir Ranjan Choudhury, ARCS was also party to said forgery, as he inserted that "Shri N. Goswami is appointed as Arbitrator in place of Shri Arjun Mondal" at the just below right corner of the Order Sheet, without referring any legal formality or provisions, as were referred in the matter of Appointment of Shri Arjun Mondal. In consideration of his participation and to cause impact on the matter concerned with the said forgery, then pending before West Bengal Cooperative Tribunal, said Mr. Mihir Ranjan Chowdhury, ARCS, was appointed as Secretary of the West Bengal Cooperative Tribunal, which was an evidence of interference by Mrs. Mira Pandey, the then Registrar of Cooperative Society, in the Administration of Justice. I send a Letter Notice to Mr. Mihir Ranjan Chowdhury ARCS, by Letter dated 10th April 1991 by Registered Post putting on record that he was "one of the parties in forgery of the said order sheet in Dispute Case No. 43/RCS OF 1987-88." Mr. Chowdhury maintained complete silence, as he was nothing to say against his own crime of forgery. However, after committing the aforesaid forgery of the Order Sheet, the Office of the Registrar, under the signature of the same Officer, Mr. S. N. Dey, who corrected the said Certified Copy-, issued Memo Letter No. 1602 dated 19th February 1990, informing thereby that one order was omitted inadvertently at the time of supply of the Certified copy. After receipt of the said Memo letter, which created under after thought, I send protest letter to said Mr. S. N. Dey, by Registered Post in his personal capacity as well in his Officiating capacity with the copies to other authorities and CBI, for action, against such criminal misconduct by the Public servants.

42. That after knew about the said forgery I also send Letter Petitions dated 2nd December 1989 and 9th January 1990 before Chief Justice of Calcutta High Court against Mr. N. Goswami, the then alleged Arbitrator, and Letter dated 18th February 1990 to Mrs. Mira Pandey, the then Registrar of West Bengal Cooperative Societies, placing on record that between 2nd February 1990 and 16th February 1990 alleged order sheet (as aforesaid) was forged and interpolated inserting the name of Mr. N. Goswami. By another Letter dated 14th February 1990 to Mrs. Mira Pandey, the then Registrar of West Bengal Cooperative Societies, this was conveyed her that the Membership of the said seven person were ceased by operation of law, and cannot be revived by any means, until the said law is operative and not reversed. Besides the said forgery of the Order Sheet Shrawan Kumar Bhatter also got forged one Slip, to submit false claim that it was written by me asking said Shrawan Kumar Bhatter to arrange payment of Rs.19200/- as very urgent.

43. That in considerations of blackmailing activities with the help of Cooperation Directorate of West Bengal, I meet with one Ex-Member of Parliament Shri Dilip Kumar Chakraborty, who personally meet and wrote Letter dated 9th March 1990 to Shri Bhakti Bhusan Mondal, Minister of Cooperation, West Bengal. Thereafter I meet several times with Shri Bhakti Bhusan Mondal, who finally directed to Mr. A. M. Mazumdar, Joint Registrar of Cooperative Societies (Housing) CMAH, to arrange a Joint Meeting in his Chamber and instructed on one of my representation asking Mr. Mazumdar to "look into the matter". However, a joint meeting was fixed and started at the Chamber of the Minister at Writers Building where Mr. Mazumdar and I was present. Minister instructed me to open the Meeting submitting my matter. At this stage Mr. Mazumdar wanted to say something secretly, as such I moved for time being out of the Chamber of the Minister. Within about 30-40 seconds said Mazumdar come out of the Ministers Chamber informed personal assistant to the Minister that he had finished his job and going back. Thereafter, when I entered in the Chamber, Minister refused to recognise me as well as Shri Dilip Kumar Chakraborty, Ex-MP and further says that he had not called any Joint Meeting. With my utter surprising experiences I returned back and wrote a Letter to Mrs. Mira Pandey with copy to Shri Bhakti Bhusan Mondal asking the Minister that in consideration of that days incidence this is clear that his mind is not competent to hold such important post of a Minister, so in the larger public interest he should resign from the Office. After going through the said Letter, Minister under his angriness send a Memo Letter to Chief Secretary of West Bengal asking him to withdraw Mrs. Mira Pandey immediately from his Department. When this fact came to the notice of Shri Jyoti Basu, Shri Bhakti Bhusan Mondal withdrawn his said Memo letter and even admitted that he might have sent said Memo Letter under mistake, or that he is ill. His statement was published in The Telegraph Newspaper.

44. That in consideration of the aforesaid forgery, I also filed Application Under Section 340 Criminal Procedure Code against Plaintiff of the said Dispute Case Shrawan Kumar Bhatter and 32 others including said Mrs. Mira Pandey (Senior) I.A.S., and Mr. N. Goswami, before Mr. A. K. Bhattacharya, the then learned Member of West Bengal Co-operative Tribunal, with prayers to Hold preliminary enquiry in to offences committed under 120-B, 194, 196, 199, 200, 205, 209, 463 and 471 of Indian Penal Code and after recording a finding send a complaint to the Learned Chief Metropolitan Magistrate, at Calcutta. The said application was registered as Misc. Case No. 3 of 1990. But, when the said Criminal case reached at a crucial stage, Mr. A.K. Bhattacharya, the then learned Member of West Bengal Co-operative Tribunal, who was just at the verge of retirement, was granted allotment of the properties at Salt Lake from the Chief ministers quota. This was reported me by staff of the Tribunal. Under the embracement of sudden Allotment letter from the Chief Ministers Quota, behaviour of A. K. Bhattacharyya was changed against me, which was appeared from comments, suddenly made on 6th September 1990. Considering severe impact of such comments, I sent letter dated 6th September 1990, by Registered Post to A. K. Bhattacharyya, to clarify my position.

45. That one Mr. Milon Banerjee, Advocate, and the then Government Pleader as then he was not known seen me, came to Court to appear in the said Misc. Case No. 3 of 1990 on behalf of Mrs. Mira Pandey, and in my presence started to influence my lawyer Mr. Diwakar Pandey, Advocate. In considerations of such peculiar situation, I send him a protest letter and also informed about his such criminal misconduct to the Government authority including the Advocate General of West Bengal and others.

46. That under the ebracement, caused by such allotment, learned Mr. A. K. Bhattacharyya, decided to abuse his Judicial Powers in judicial process against me, and passed several orders in serious abuse of the judicial process. For instance on 18th January 1991, when I and my Advocate were present in the Tribunal Court, Mr. A. K. Bhattacharyya, immediately after entering in the Court Room, but before sitting on the Chair, informed my Advocate that his case of the day (i.e. the said Misc. Case No.3 of 1990 against aforesaid forgery of Order Sheet) is dismissed. After sitting on the Chair Mr. A. K. Bhattacharyya started dictating the order interalia that:

"None appears for the petitioner / appellant. No steps taken till 12.05 p.m. The learned Advocate on record is also absent on repeated calls. It shows that the petitioner is not interested to proceed further with the hearing of the Misc. case." and "ORDERED That the Misc. Case No.3/90 stands dismissed for default without any cost."

47. That when said Order was dictated, my lawyer raised voice with strong objection against such false recording. At this moment Mr. A. K. Bhattacharyya, replied "you go wherever you likes, truth is only which is recorded by me in the Order". Thereafter, my Advocate having no scope to say anything, kept silent till order was dictated, typed and signed by Learned Member of the Tribunal, but when it was given to the Advocate of the Respondent / Accused No.1 (Shrawan Kumar Bhatter) in the matter to sign it, then my Advocate also wanted to sign the Order Sheet. At this stage Mr. A. K. Bhattacharyya, ask him not to mention any thing else except his signature. When my Advocate ask Mr. A. K. Bhattacharyya, about the prevailing time, as then in the Clock of the Tribunal, time was 12.07 p.m., so Mr. A. K. Bhattacharyya responded accordingly and my Advocate also put the said time just below his signature in the Order Sheet.

48. In fact in considerations of aforesaid sudden comments made on 6th September 1990 after the said Allotment I decided and prepared a Petition to file on 18th January 1991 before the Tribunal, but under the aforesaid circumstances, I was not allowed to file it. So said petition was lying with me. Immediately after coming down from the Building, where the Tribunal is exists, I Posted the said Voluminous Petition by name to Mr. A. K. Bhattacharyya, by Registered Post, from the Post Office exists in the selfsame building of the Tribunal, mentioning in the left upper corner of the Petition about the aforesaid false recording in the order Sheet and allowing my Advocate to sign and put the time below his signature. Thereafter, A. K. Bhattacharyya dismissed my several matters knowing fully adopting abuse of judicial process by misusing his judicial office. The judicial proceedings, as adopted by A. K. Bhattacharyya, were completely beyond the scope of principles of the jurisprudence. My Advocate also warned me in writing by his letter dated 16th April 1991. I also referred all such facts in my letter dated 5th July 1991 sent by Registered Post to the learned Mr. N. K. Khaitan, Advocate of the Respondent No.1 in the said Misc. Case No.3 of 1990 and in Notice dated 23rd November 1990 against her Criminal Misconduct, sent to Mrs. Mira Pandey, the then Registrar of Cooperative Societies.

49. That said Raj Kumar Dhawan and Chandra Sekhar Dhawan who attended the said Special General Meeting and signed Allotment Letter in their own favour and Agreement Executed transferring the properties comprised in R. S. Plot No. 194 as aforesaid in my favour, created a false story to challenge their own signatures, under connivance with said other 5 persons including Shrawan Kumar Bhatter. Connivance between aforesaid seven persons further appears from the Summon form with regards to Dispute Case filed by said Raj Kumar Dhawan and Chandra Sekhar Dhawan, prepared and filled-up by said Prabhu Dayal Sureka, who also fill-up the forged order Sheet in the said Dispute Case No. 43/RCS of 1987-88. This is a matter of absurd surprise that said Raj Kumar Dhawan and Chandra Sekhar Dhawan on the very same day of filing of their Dispute case falsely claimed in their Injunction Application in support of the grounds for Injunction against me that I am avoiding the service of summons.

50. That I state and submit that the said Mafiadom have tried their best level to embraces Judicial Officers to effect the Administration of Justice, which time-to-time I put on the record submitting Letter Petitions to the Honble Chief justice of India and / or Honble Chief justice of Calcutta High Court with prayers to ensure enforcement of my Fundamental Rights, or filing Applications for according sanctions. I crave leave to refer them at the time of hearing of the Suit, if necessary.

51. That when Sanjay Kumar Jhunjhunwala realised that his all efforts to blackmail me are going to futile, one day he send me threats that he "is in a position to use Shri Jyoti Basu, the then Chief Minister of West Bengal to harass me" which I put on record in my Letter Dated 11th December 1989 by Registered Post to him. By my Letter dated 18th December 1989 I also forwarded copy of my said Letter dated 11th December 1989 to various authorities, politicians, all by Registered Post including to Shri Buddha Dev Bhattacharyya, the then Minister of West Bengal for Urban Development, Shri Nar Narayan Gooptu, the Advocate-General of West Bengal, Shri Har Kishan Singh Surjeet, General Secretary of CPI (M), Shri Biman Bose, West Bengal CPI (M) Leader.

52. That in consideration of constant blackmailing I started to refer said Sanjay Kumar Jhunjhunwala as Mafia Leader, in my each and every representation. Certainly this have exposes his real and true face, as such under criminal conspiracy with his Lawyer Mr. Kishan Lal Bagaria, Solicitor Partner of M/S. B. M. Bagaria & Co., Solicitors, and friend of said Mr. Prabhu Dayal Sureka, started making false representations before my Lawyers and filed a Defamation Suit against me, before Kolkata High Court. After ex-party hearing of the Injunction Application in the said Defamation Suit, Prabir Kumar Mazumdar, J. as then he was, passed an Order, as if I have no right to lodge a First Information Report or make any Complaint before any authority. The surprising part of the proceeding was that such ex-parte Petition was moved by my long time lawyer, learned Mr. P. K. Ray, Bar-at-Law. Subsequently it was reported me by one of the Junior to learned Mr. P. K. Ray, Bar-at-Law, that learned Mr. Pratap Chandra Chatterjee, Bar-at-Law (son of learned Mr. Som Nath Chatterjee, Bar-at-Law and Member of Parliament) influenced learned Mr. P. K. Ray, Bar-at-Law to appear against me. Appearance of Learned Mr. P. K. Ray, Bar-at-law, in the said particular matter against me was professional misconduct, as he was fully conversant with the Mafia activities run by the said Sanjay Kumar Jhunjhunwala, as such on 17th August 1990 I send a protest letter to Mr. P. K. Ray, Bar-at-law. In fact in similar manner said Sanjay Kumar Jhunjhunwala, directly himself or through some one else, made false representations before several Lawyers who were appeared for me in different matters, to change them against me. In this respect I can refer some of the names including Learned Mr. M. R. Chowdhury, Advocate, 12, Old Post Office Street, Kolkata-700001, Smt. Maity Ghosh, Advocate, 12/1, Old Post Office Street, Kolkata-700001, Ld. Mr. Bhaskar Sen, Bar-at-law, 147, Shyama Prasad Mukherjee Road, Kolkata-700026, Mr. Pradeep Kumar Ghosh, Bar-at-law, 25, Harish Mukherjee Road, Kolkata-700020, Ld. Mr. Bankim Chandra Dutta, Advocate, and several others. Resultantly, I was compelled to send each of them Letter by Registered Post to clarify my position.

53. That in considerations of the said Defamation Suit when I appointed learned Mr. Gouri Shankar Gupta, Advocate to conduct my case, Sanjay Kumar Jhunjhunwala and his Lawyer Shri Kishan Lal Bagaria, Solicitors, started to influence the said Gouri Shankar Gupta, Advocate as referred hereinbefore, to sabotage the Judicial Proceeding against me. In considerations of regular sabotage of the judicial proceedings arranged by Sanjay Kumar Jhunjhunwala I find that there is no scope to get justice if I would not oppose the gross abuse of the judicial Proceedings. As such in considerations of the orders passed in the said Suit, and in considerations of the majority Judgment, in five Judge Constitutional Bench, in K. Veeraswami V. Union of India case (SCC (1991) 3 SCC Pages 654-755), I filed an application for according sanction, jointly before the President Of India and Honble Chief Justice of India, against Prabir Kumar Mazumdar and Shyamal Kumar Sen, JJ., as then they were. At the same time a joint complaint was lodged against learned Mr. Gouri Shankar Gupta, Advocate and Mr. Kishan Lal Bagaria, Solicitors, and another complaint was lodged against Mr. Tapash Kumar Sarkar, Advocate (Lawyer of the said Ava Rani Dey and Dipika Rani Bhattacharjee), before the Bar Council of West Bengal. No reply or objections, at all were filed by those Advocates, nor were served upon me, nor any date was fixed to hear the aforesaid matters. But, under gross abuse of the judicial process, and against the important principle of the Jurisprudence that "Justice Must be Above all", and under severe bias and in highly irregular manner both complaints were disposed off by Bar Council of West Bengal, in serious violations of the said core principle just by passing Resolutions, to save the skin of the brethren Advocates. As such I filed Appeals before the Bar Council of India, which after elapse of about ten years never come up for hearing even after repeated reminders.

54. That object, behind submitting such application for prosecution permission was just to break the sabotage caused by the said Mafiadom, in the Administration of Justice, as such when I was reported by the Court Peshkar of the Honble High Court that Shyamal Kumar Sen, J. as he was, taken affidavits of the both side parties in the matter No.3028 of 1991, at his residence, I withdraw my aforesaid Application for according sanction, by my letter dated 25th June 1992 tendering my unconditional apology. I sent the said letter in the same manner as was forwarded Application for according sanction.

55. That when Contempt Proceeding was moved by the Advocates of Sanjay Kumar Jhunjhunwala, for Order of Rule against me, Honble High Court directed to serve the copy of the Application upon me. To avoid the service of the Application he and his Solicitors Shri Kishan Lal Bagaria, Solicitors, made a tricky plan to create fake service of the Application upon me. For the success of such tricky plan, Shri Kishan Lal Bagaria, Solicitors knowing fully send clerk from his firm at noon, when there were no scope of my availability at my residence. Accordingly, on 13.9.1991 one person claiming his name as Jagneswar Sinha, allegedly from the Income Tax Department came at my residence allegedly to serve a Notice upon me. My wife was not fully conversant with English, as such she said that it may be better if he note down his name and address on a Paper, so said Notice can be collect from him. Accordingly said clerk of Shri Kishan Lal Bagaria, Solicitors note down his alleged name as Jagneswar Sinha, along with his false address as 9th Floor, Bamboo Villa, 168, A. J. Chandra Bose Road, Calcutta-14. When said person note down his alleged name and address, suddenly it was came in the mind of my wife, that why she should not take delivery of the Notice from the Income Tax Department, after showing it to our the then Landlord Shri Abdul Mannan Khan, who is also a qualified Advocate. As such my wife go down along with the said person, but when both of them reached at the out side of the Office of the Abdul Mannan Khan, which was situated at Ground Floor of the same building, the said clerk of Shri Kishan Lal Bagaria, Solicitors fled from the scene. This was caused some doubt about some dubious act of the said person. However, after knew about the whole incidence, subsequently, I tried to find out the said person at the given address of the Income Tax Department, but find no such person in the said entire building. IN any case, with reference to said Contempt proceeding, when I wanted to know that how Rule was issued without serving the Copy of the Petition, from Shri Kishan Lal Bagaria, Solicitors through my Solicitors, he refused to disclose related informations, which causes strong doubts. Upon enquiry this was found that date and time given in the Affidavit of Service, filed to obtain Rule in the Contempt Proceedings was the same i.e. 13.9.1991 when said person with his alleged name as Jagneswar Sinha, came to my the then residence. This was become clear that the said Affidavit of Service knowing fully made with false claim that I refused to receive the Copy of the Application with sole object to obtain the Rule by manipulation, from the Honble High Court, Kolkata.

56. That in fact, under ill advice from Shri Kishan Lal Bagaria, Solicitors intention of Sanjay Kumar Jhunjhunwala was to make bias the Shyamal Kumar Sen J., as then he was, against me, as such he knowing fully made false allegation against me that I am a habitual criminal and convicted in a Criminal Case, referring the said matter in which in fact Mr. Jayanta Kumar Das Gupta, lost his Judicial service, as a first such dismissal in the Judicial History of Indian Judiciary.

57. That in considerations of such criminal acts with regards to the Administration of Justice I filed an Application Under Section 340 Criminal Procedure Code, before Honble Kolkata High Court interalia citing the evidences of such false statement as well as said false Affidavit of Service. When Honble High Court passed an order for hearing of both the matters (Contempt Proceedings and Application Under Section 340 Criminal Procedure Code) analogously, this was become quite clear to Sanjay Kumar Jhunjhunwala and his Solicitors that they are in real trouble, as such on the one hand they managed that hearing of the said matter should not take place at any cost, and on the other hand they taken help from dreaded criminals / miscreants with the help of said Manik Chand Sethia, being the front man of Shri Chandan Basu, besides Police support, with sole purpose to compel me to flea from Kolkata along with my family, if I want to survive at all. They managed with the staff of the Kolkata High Court, thus with utter surprise said Contempt proceeding was started going down in the cause list of respective Bench of Honble High Court, than started to listed as Last matter of the List, which runs for several days and finally matter gone out of the List.

58. That in the meantime one Politician Congress MLA Dr. Manash Bhuinya agreed to raise the whole issue in West Bengal Legislative Assembly on 22nd February 1991. But it is assumed that under double dealership said Mr. Manash Bhuinya, M. L. A., informed his intentions to any person belongs to said Mafiadom. As a result said Sanjay Kumar Jhunjhunwala arranged some settlement with Dr. Manash Bhuinya on the one hand and hatched a Plot to kill my 18 years son under Police protection. As a result, when on 22nd February 1991, I reached at the residence of Dr. Manash Bhuinya he informed me that his plan of statement in Assembly was changed. As such I return my home. But, within few minutes from my return at home, at about 11.00 AM of the same day i.e. 22nd February 1991, under a hatched plot a Truck Accident under Police protection was staged, to kill my son, in which both the legs of my son were severally damaged. My son was able to stand on his legs only after treatment for more than 30 Months and after 22 Major Operations, at Kolkata Medical Research Institute of Kolkata and Holy Family Hospital of Delhi. That considering the connivance of Dr. Manash Bhuinya, M. L. A., I send him Letter dated 5th April 1993 by Registered Post asking him "can he explain with regards to his changed attitude and behave and reasons for postponement of the program to raise the issue in West Bengal Assembly on 22nd February 1991". The involvement of the Police is further evident from the First Information Report, for the said accident, in which Police recorded false direction of moving of the Truck. Upon enquiry this was revealed that the said Truck was standing since 9.00 morning, in a Compound situated just in the Northern Side of the Road and accident spot. In the said Compound there were several Almirah Factories, as such under the hatched plot and to create confusions amongst all those factories, Alimirahs were loaded. Truck was moved from North to South and damaged a Pan Shop and Shutter of another Shop both situated just in the South of the Road. Immediately after the accident, when I reached at the accident side, where till then my son was under the Tyre of the Truck, I seen that Truck came from the North side Compound. In considerations of such developments of miserable situation caused by the said Mafiadom with the help of the Government machinery, Police, muscle powers, embracement of the judicial officers, against me, I was compelled to left from the Court proceedings, and flees from Kolkata along with my family Members to survive.

59. That in considerations of aforesaid miserable situation of severe magnitude being the rarest of rare of the infringement of the fundamental rights, including blockage of the rights to Justice, I decided to file a Writ Petition under Article 32 of the Constitution. For this purpose, after a long initiation I met with Senior Lawyer of the Supreme Court and Ex-Solicitor General of India learned. Mr. A. D. Giri, Sinior Lawyer at his residence at Allahabad. After going through the facts learned Mr. A. D. Giri, Senior Lawyer was satisfied and suggested me to appoint one Delhi based Senior Lawyer like learned Mr. Gopal Subramanium. With this purpose, learned Mr. A. D. Giri Senior Lawyer personally came to Delhi and discusses the issue in detail in Kanishka Hotel, where learned Mr. Gopal Subramanium, Senior Advocate was also present. Thereafter learned Mr. Gopal Subramanium, Senior Advocate studied the merits of the matter and decided to prepare a letter to be sent by me to the Governor of West Bengal, before filing such Writ Petition. Accordingly under the supervision of learned Mr. Gopal Subramanium, Senior Advocate, his one of the Junior Advocate prepared draft of such representations to be sent and was sent by me to the Governor of West Bengal.

60. That, as per advice from the learned Mr. Gopal Subramanium, Senior Advocate, after elapse of about three months time from the said letter to the Governor of West Bengal, I tried to meet him, but under most surprisingly every time he declined to meet me for the reasons best known to him. But, after several attempts, one day learned Mr. Gopal Subramanium, Senior Advocate suddenly appear on telephone and says that he had ask the learned Mr. S. Murlidhar, Advocate to prepare a Writ Petition in that effect. But, when I meet with learned Mr. S. Murlidhar, Advocate, at his Mayur Vihar Chamber, learned Mr. Murlidhar, Advocate, said that he is convinced that on the merit my matter is very strong, but now a days Supreme Court declined to accept any Writ Petition under Article 32 of the Constitution. Such development shows that learned Mr. Gopal Subramanium, Senior Advocate, instead of direct refusal, arranged refusal through the learned Mr. S. Murlidhar, Advocate, and under some influence or otherwise decided not to file such Writ Petition, thus himself become a party in my such infringement. In fact before such development, as stated hereinbefore, said Mafiadom using their criminal strategy influenced my several lawyers, either on some false representation or otherwise, so I was not surprised. Subsequently, in search of one Senior Lawyer, I wrote a stereo typed letter to about Hundred Senior Advocates of the Supreme Court, including learned Mr. Gopal Subramanium, Senior Advocate. No one except learned. Mr. Gopal Subramanium, Senior Advocate replied me, that if I can convince that I am a genuine litigant, than he can take up my case. Receiving such letter with such surprising contentions just after few month from the said Draft forwarded by him, I was socked and wrote back that I have apprehensions that my opposite parties must have approached him, otherwise after knowing the matters on merit relates to infringement of my fundamental rights he should not have questioned my genuinity. In reply thereof learned Mr. Gopal Subramanium, Senior Advocate, admitted that "As far as the merit your matter is concerned I am prima facie satisfied that there is a cause of action at least to file a Writ Petition under Article 32 of the Constitution of India for appropriate reliefs." In his said reply letter he also wrote that if I offer him a written apology and withdraw the sentence referred in paragraph 4 of my said letter, he would be in a position to advise me appropriately further in the matter. But, I not tendered any apology, since failed to justify his said language.

61. That under the close Nexus with Shri Jyoti Basu, and other powerful politicians from West Bengal, said Sanjay Kumar Jhunjhunwala established himself so powerful, that once I negotiated with one Promoter for development of my properties. Said Promoter claimed that he had very good relations with Shri Hashim Abdul Halim, the Speaker of West Bengal Legislative Assembly. This was my pre-condition before the said Promoter that he never can ask me for any compromise with Sanjay Kumar Jhunjhunwala, and my condition was accepted and agreed upon by the said Promoter. But, with the most surprisingly, when I along with said promoter and two other persons meet with Shri Hashim Abdul Halim, Shri Halim offered that he will mediate the matter and arranged settlement calling Mr. Fatehpuria, the relation, Partner and brother-in-law of Mr. Jhunjhunwala. I sent my protest letter dated 24th July 1993 to Shri Hashim Abdul Halim, the Speaker of West Bengal Legislative Assembly by Registered Post. The said offer made by Shri Hashim Abdul Halim was an evidence that how Sanjay Kumar Jhunjhunwala so powerful in the political circle, where his wrong doings were covered under immunity.

62. That I wrote several letters to the Central Vigilance Commission, in respect of Criminal misconduct adopted by the Income Tax Department and the Railway Authority for the gain and benefit of the said Sanjay Kumar Jhunjhunwala and his associates. In response of one such letter the then Secretary of the Commission Mr. Bhure Lal through his Private Secretary called me by Memo letter Secy/Com/96 dated 6th November 1996. I met with Shri Bhure lal and placed more than hundred pages of the documents to him. After going through the documents and satisfying with arguments forwarded by me, Mr. Bhure Lal called one of his subordinate and dictated order in my presence, for appropriate actions. But thereafter in the matter Commission became mum, for the reasons best known to it.

63. That the said Mafiadom is still using black money powers against me and authorities are not taking appropriate actions to curb their black money powers. The members of said Mafiadom under connivance with each other spending black money in big way against me. This was reported me that they entered in an agreement with antisocial to kill me. This cannot be proved unless concerned antisocial were nabbed by the Police. But, another associate of the Sanjay Kumar Jhunjhunwala namely Manik Chand Sethia conveyed his threats to me admitting before one Mina Lal Bhansali, that "he has paid Rs.5,00,000/- (Rupees five Lakhs) to one Chittaranjan Ganguly and Rs.3,00,000/- (Rupees Three Lakhs) to one local anti-socials out of total agreed payment of Rs.10,00,000/- (Rupees ten lakhs), fixed for total object to grab my properties." Shri Mina Lal Bhansali advised me to compromise with the said Mafiadom. As such I put such information on record by sending the Letter dated 17th February 2001 by Registered Post to Shri Mina Lal Bhansali, with copy to said Manik Chand Sethia.

64. That till now, I submitted number-less representations against growth of the said Mafiadom under its Nexus with Powerful politicians and threats to my lives, liberties and properties. I approached each and every authority starting from respective Local Police Station and up to the Honble President of India and till date justice is totally denied to me under Politics-Crime-Nexus, made my life miserable with severe magnitude. At one point of time, the then Home Minister Shri Inderjit Gupta admitted that he cant break politics-crime-nexus, which clearly giving impressions that the Mafia elements are so powerful than the hands of Law.

65. That the Office of the Revenue Secretary and Chairman of Central Board of Direct Taxes ignored to take any action against Income Tax Evaders even ignoring the directions issued by the Prime Ministers Office viz. Memo Letter No.11/3/94/PM PII/517988 dated 31st May 1994, ensuring that Private Defendants are much powerful than the law, thus protected black money of Sanjay Kumar Jhunjhunwala and his associates, thus given enough strength to their criminal activities and caused heavy damages to my entrepreneurship. In my representations I repeatedly referred in detail, about illegal activities of Sanjay Kumar Jhunjhunwala, but no actions were taken, giving scope of strengthen his criminal attitude and activities and growth of the Mafiadom. For instance one such matter relates to open "Violation of Income Tax Act in one of the transaction of the Property purchased by Sanjay Kumar Jhunjhunwala through two of his Companies" is referred below, on which Revenue Secretary, Central Board of Direct Tax, and other related authorities of Income Tax Department knowing fully taken no actions to protect said transactions executed based on huge black money.

66. That Mr. Sanjay Kumar Jhunjhunwala and his relatives are Directors and control over the management over a number of Companies including M/S. Martin Burn Ltd., M/S. Mahanagar Properties Ltd., and/or M/S. Ranisati Commercial Co. P. Ltd., and/or Teage and Tools Constructions P. Ltd., and/or Maurya Properties Ltd., Hirjee Warehouse and Properties P. Ltd., Surabhi Properties P. Ltd., and Tripti Properties P.Ltd., and several other Companies. That according to reports from the some reliable sources, from within the Sanjay Kumar Jhunjhunwala, which I can't be disclose, all Companies of Mr. Jhunjhunwala and his relatives made transactions based on huge BLACK-MONEY for more than few Hundred Crores of Rupees, under open criminal misconduct of the concerned authorities the then worked under the control of Central Board of Direct taxes. I can refer at least few names of such officials including Mr. Devi Dayal, the then Director of Investigation (Inspection), W.B. and Dr. N.R. Sivaswamy, the then Chief Commissioner (Technical), West Bengal who subsequently promoted as the Chairman of CBDT and then made accused in Bihars Fodder Scam.

67. That on 25.8.1989, a Notice in the English Daily Newspaper from Kolkata namely The Telegraph was published by Messers Pankaj Shroff & Co, Advocates, having their address at 7B, Kiran Sankar Roy Road, Kolkata-700 001 interalia that his clients "Surabhi Properties Pvt. Ltd., and Tripti Properties Ltd., both having their Registered Office at No. 9/1, Lower Rawdon Street, Kolkata have agreed to purchase premises No. 53, Ramtanu Lahiri Sarani (formerly 24A, Diomond Harbour Road and originally Plot No.42 of Block "C' New Alipore), Kolkata measuring 10 Cottas 02 Chittacks 38 Sft. from Mr. Pranab Dutta Chowdhury, Smt. Purabi Dutta Chowdhury and Dr. (Miss) Shyamali Dutta Chowdhury all of 53, Ramtanu Lahiri Sarani, Calcutta."

68. That on or about 23.2.1990 the Income Tax Department, West Bengal, also published its Notification on several Newspapers for GRAND AUCTION SALE under the signature of Mr. N.R. Sivaswamy, the then Chief Commissioner (Technical), West Begal, with reference to several properties, including one "Vacant land measuring 5 cottas more or less 12" wide common passage from the main road, forming part of plot no.386A Block "C', New Alipore, Calcutta and renumbered 23A, 386A, Diomond Harbour Road, Calcutta." In the notification "Reserve Price for the said property was referred as Rs.18,27,000/-". According to such reserve prices fixed by the Income Tax department, prices for such property arises Rs.3, 65,400/- for per cottah. Said Mr. N.R. Sivaswamy, the then Chief Commissioner (Technical) Income Tax Department, West Bengal, was promoted as the Chairman of the Central Board of Direct Taxes, under the Ministry of Finance. In fact either the concerned officers from the Income Tax Department not acted on any of my representations, otherwise if at all responded, the were under the advice, consultations and connivance with the Private Defendants.

69. That the properties referred in the Notice of Messers Pankaj Shroff & Co, Advocates, and the said property referred in the said Notification published by Income Tax Department, West Bengal, are situated in the selfsame locality. In fact the properties referred in the Notice of Messers Pankaj Shroff & Co, Advocates was abuts upon a wide road of more than 25", while the properties referred in the Notification published by Income Tax Department, West Bengal, admittedly was abuts upon a wide road of just 12" road. Therefore, under the Municipal Law the FAR for the properties referred in the Notice of Messers Pankaj Shroff & Co, Advocates, was entitled to get sanction for the construction of double floor area ratio, per Cottas, from the floor area ratio could have been available for the properties referred in the Notification of the Income Tax Department. Therefore the market value of this properties referred in the Notice of Messers Pankaj Shroff & Co, Advocates, should have been double from the aforesaid Rs.3,65,400/-per cottah, which arises more or less Rs.7,30,000/- per cottah which means according to Income Tax Department Price of the properties referred in the Notice of Messers Pankaj Shroff & Co, Advocates Rs.73,00,000/- (Rupees Seventy three lakhs). But as per my report Sanjay Kumar Jhunjhunwala purchased property against payment of Rs.45,00,000/-.

70. That even this was a fact that the Sanjay Kumar Jhunjhunwala purchased aforesaid properties as referred in Notice of Messers Pankaj Shroff & Co, Advocates, through his two Companies namely Surabhi Properties Pvt. Ltd., and Tripti Properties Ltd., both having their Registered Office at no.9/1, Lower Rawdon Street, Calcutta. The entire transaction was based on knowing fully manipulations / serious violations of the Section 269UC of Income Tax Act. Director of the one of the aforesaid Company was Accountant of Mr. Sanjay Kumar Jhunjhunwala.

71. That under such manipulations the transactions were divided in six deeds and purchasers were divided into two. Under the manipulations on records payment by alleged two purchasers were maintained below Rs.10,00,000/-, being the then Limit under the then prevailed provisions Under Section 269UC of the Income Tax Act. Since Vendors were three and alleged purchasers were two the amounts of the payments shown in the deeds as under: -

Payments shown in three deeds by M/S. Surabhi Properties Pvt. Ltd., having its Registered Office at no.9/1, Lower Rawdon Street, Calcutta, in the following manner: -

1.Pranab Dutta Choudhury Rs. 4,75,000/-

2.Smt. Purabi Dutta Chowdhury and Rs. 2,37,500/-

3.Dr. (Miss) Shyamali Dutta Chowdhury Rs. 2,37,500/-

Total payment shown by one Purchaser Rs. 9,50,000/-

Payments shown in another three deeds by Tripti Properties Ltd., having its Registered Office at no.9/1, Lower Rawdon Street, Calcutta, in the following manner: -

1.Mr. Pranab Dutta Chowdhury, Rs. 4,75,000/-

2. Smt. Purabi Dutta Chowdhury and Rs. 2,37,500/-

3. Dr. (Miss) Shyamali Dutta Chowdhury Rs. 2,37,500/-

Total payment shown by another Purchaser Rs.9,50,000/-

72. These facts were also referred by me in my Application Under Section 340 Cr.P.C. filed in the said Contempt Proceedings initiated by said Mr. Sanjay Kumar Jhunjhunwala before Kolkata High Court in the Matter No.3028 of 1991 just to escape from heavy penalties and other consequences in respect of transactions of the properties purchased in severe violations of the Income Tax Act, 1961 and by using huge Black-Money. The afoesaid particular transaction was one exemple of the Modus operandi used by Sanjay Kumar Jhunjhunwala, his relations and associates to use huge blackmoney in their transanctions.

73. That under Political-Crime-Nexus, the Railway Ministry acted to protect illegal and criminal agreement and understandings between Mr. Sanjay Kumar Jhunjhunwala and Railway Officials in respect of illegal encroachment of Valuable Public Property belongs to Railway. In fact under gratifications or otherwise concerned Railway Officials entered in an illegal agreement without any considerations or public interests, thus allowed Mr. Sanjay Kumar Jhunjhunwala to make constructions of front portions of two of his buildings, (now called and known as Mani Towers), at the Railway Land, at James Long Sarani, Kolkata700038, near to the Railway Officers Colony at New Alipore, Kolkata. Under gratification or otherwise, the same officials acted for beatification of the said multistoried complex by developing a Garden in front of the aforesaid Two Buildings. Such development was made just for the benefit and monetary gains to Mr. Sanjay Kumar Jhunjhunwala, at the cost of Railway.

74. That State Defendants particularly Office of the Central Vigilance Commission and Central Bureau of Investigation taken no appropriate actions in respect of the matters relates to criminal misconduct of the concerned public servants, translated in severe violations of the Law, as a result silence on the part of these defendants, considered by Mr. Sanjay Kumar Jhunjhunwala and his associates, particularly Chunilal Mukherjee, adjudged Cheat Chitta Ranjan Ganguly, Kamlesh Chandra Chattopadhyay, Shrawan Kumar Bhatter etc. as most uncourageous, for their wrong doings.

75. That under Political-Crime-Nexus or otherwise the State Defendants particularly Office of the Kolkata Municipal Corporation granted various favour in severe violations of the respective Building Rules and granted illegal sanction of the building plans and permitted to construct buildings in severe violations of the Law and Building Rules.

76. That this is a material fact that the respective Public Sevants of the State Defendants acted under influence or otherwise, thus willfully and knowing fully violated Constitutional, Statutory and Legal duty, and protected wrong doings based on the Black-Money of the Private Defendants, provided them illegal favours, acted as if Private Defendants have complete immunity before the Law for their every wrong doings, thus encouraged their mafia activities, thus ensured severe infringement of my Fundamental, Statutory and Legal Rights.

77. That the then Chief Minister of West Bengal Shri Jyoti Basu, knowing fully misused his position and Government Machinery of the State of West Bengal as well as of the Kolkata Municipal Corporation to protect wrong doings of the Private Defendants, and visibly acted to ensure success of blackmailing activities of the Private Defendants, particularly of Mr. Sanjay Kumar Jhunjhunwala and his associates Chunilal Mukherjee, adjudged Cheat Chittaranjan Ganguly, Kamlesh Chandra Chattopadhyay, front man of Shri Chandan Basu namely Manik Chand Sethia Shrawan Kumar Bhatter etc. I crave leave to refer more details in the plaint of the suit relates to the blackmailing activities against me, causing huge damages to my rights, titles, interests and claims.

78. That time-to-time each violation of Law, caused under criminal act by criminal means were referred and intimated by me in respective Memorandums, Representations, Applications, and Complaints submitted to respective authorities of the State. But, no action were taken by any of the authority, causing my life miserable and fully insecure as were also reported and admitted in general terms by the Vohra Committee in its Report, thus acted in severe violation of the Principal of Rule of Law, allowed infringement of my various Fundamental Rights, which are under severe threats till date and compelled me to live under hiding. I filed an application before Dr. Shankar Dayal Sharma, the then President of India, for according sanction to prosecute Shri Jyoti Basu. Dr. Shankar Dayal Sharma, after preliminary satisfying with the same forwarded it for enquiry. This was came to my notice from Memo Letter No.406/3/93-AVD.IV dated 1st November 1993 from the Government of India, Ministry of Personnel, Public Grievances and Pensions, Department of Personnel & Training in response to my said Application. But, since thereafter, till today this Department is sat on the said application thus given ample scope to cause miserable situation against me by Shri Jyoti Basu with the help of other defendants or otherwise. If each and every State Defendant could have been acted just in accordance with the Rule of Law, thus would have allowed me to work with honesty and sincerity, then today I may have my own assets of much more than Few Hundred Crores of Rupees, which opportunities were damaged due to non-actions by the State Defendants, against mafia activities runs by the private Defendants. I crave leave to submit a List of Memorandums, Representations, Applications and Complaints submitted to the State Defendants time to time, till date, if so directed. Therefore, this Notice is served upon the State Defendants in compliance of Section 80 of Civil Procedure Code.

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79. That the first cause of actions was arosed in the year of 1982 and thereafter arising and running every day till date, without any rest, and arises at various parts of the country, including Kolkata and several other places. Therefore, after expiry of the mandatory period of 60 days, with appropriate amendments in the Notice for a plaint, a Civil Suit will be filed and moved before appropriate Court for appropriate reliefs, interalia as follows:

    1. for decree of declaration that the State Defendants failed to take
    2. appropriate actions in accordance with their Constituional, Statutory and Legal Duties against illegal acts, activities and deeds of the Private Defendants (Names of the Private Defenadants are referred in the instant notice);

    3. for decree of declaration that the StateDefendants failed to act in
    4. accordance with their Constituional, Statutory and Legal Duties, obligations and responsibilties to provide appropriate protections against infringement of Constitutional, Statutory and Legal rights of justice, lives and liberties of the plinitff, infringed by the Private Defendants (Names of the Private Defenadants are referred in the instant notice) starting from 1983, and till date, runs under constant, continues infringements, caused by various means and method, compelling the plaintiff to flea from Kolkata and live under hiding, with his family members

    5. for decree of declaration that time to time Public Servants holding
    6. respective offices of the State Defendants entered in illegal agreements with the Private Defendants (Names of the Private Defenadants are referred in the instant notice) in serious violations of their Constituional, Statutory and Legal Duties, obligations and responsibilties to support balckmailing acts, activities and deeds to cause infringement of Constitutional, Statutory and Legal rights of the plinitff;

    7. for decree of declaration that defendants are liable to pay the
    8. plaintiff, the amount of damages in the manner described and amount fixed by the Court against damage caused under violations of Constituional, Statutory and Legal Duties by the respective State Defendants under agreements with the Private Defendants (Names of the Private Defenadants are referred in the instant notice);

    9. for deed of declaration that State Defendants particularly Police, in
    10. respect of the Criminal complaints time to time lodged by the Plaintiff with the Police Defendants, including Behala P.S. case No. 38(7)83 dated 14.7.1983, 91(12)83 dated 29.12.1983, 106(2)84 dated 29.2.1984, 4(3)84 dated 2.3.1984, 54(2)85 dated 19.2.1985, 67(7)86 dated 18.7.1986 and New Alipore P.S. sec. Vz. C/No.30 dated 22.2.1991, and Golabari Police Station, in respect of crimes committed against Plaintiff by the private defendants and their associates, including Crimes committed to murder the plaintiff and further attempt to murder son of the plaintiff;

    11. for decree of declaration that State Defendants particularly
    12. Police, knowing fully and under connivance with private defendant Chunilal Mukherjee, lodged a false complaint vide Behala P.S. Case No.54(2)85 dated 19.2.1985, against Plaintiff, acting under criminal misconduct disobeying their duty and mandatory obligations thus encouraged Mafia activities of the said defendant;

    13. for decree of declaration that Private Defendants particularly
    14. Shrawan Kumar Bhatter and his Group of seven persons; Ava Rani Dey and Dipika Rani Bhattacharjee filed their respective Suits knowing fully, on the basis of their false claim to obtain the orders or Judgments which under the law were not due, but to got obtain by embracing the respective Judicial Officers;

    15. for decree of declaration that private defendant particularly Sanjay
    16. Kumar Jhunjhunwala obtained Rule in the Contempt Proceeding filed in the Defamation Suit filed against the plaintiff, before Kolkata High Court, on the basis of false Service of Summons;

    17. for liberty to file further Suit or Suits, if required or necessary;
    18. for directions to publish advertisement under Order 10 Rule (1) of

the Civil Procedure Code;

k) for directions upon the defendants to submit all documents, necessary for proper adjudication of the suit;

    1. for direction to obtain legal opinion, on issues relates to law, if

necessary, from the Superior Court or otherwise in respect of extra ordinary issues raised under extra ordinary situation and circumstances referred in the matter, to ensure the justice to the plaintiff;

m) for appointment of a Commission of enquiry to be held by the Central Bureau of Investigation under direct supervision of Central Vigilance Commissioner, to enquire the Nexus between the Political Powers, State Defendants, Private Defendants, Advocate Defendants, and Ex-Members of the Judicial Service, which caused adverse impacts upon the plaintiffs rights;

n) for appointment of a Commission of enquiry to be held by the Central Bureau of Investigation under direct supervision of its Director to collect, enquire and submit action taken reports or non-actions by the State Defendants in respect of the Memorandums. Representations, Applications, Complaints time to time served upon them by the Plaintiff;

o) for appointment of an expert to assess the amount of damage caused under the situations caused by the defendants, against the plaintiff;

p) for Injunctions to provide appropriate security to ensure safety and

security of life and liberties of family members and plaintiff himself;

    1. for Injunction, if necessary in respect of any of the Prayer;

r) for any further or other order or orders as may be deemed fit and proper for the proper adjudication of the matter, and for ends of the justice.



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