71. That till then said Raj Kumar Dhawan and his Son Chandra Sekhar Dhawan were not with the Shrawan Kumar
Bhatter and his father Shankar Lal Bhatter. But, as 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. Shrawan Kumar Bhatter and his father Shankar Lal
Bhatter after all efforts could not get support from more than 7 members. Out of said 7 Members three were sons of said Shankar
Lal Bhatter. Two were said Father Son duo, namely Raj Kumar Dhawan and Chandra Sekhar Dhawan, though originally they attended
the Special General Meeting of the Cooperative Society. One was Prabhu Dayal Sureka, who suppose to be friend of Mr. Kishan
Lal Bagaria, Partner of M/S. B. M. Bagaria & Co., 6, Old Post Office Street, Kolkata-700001. One was Sushil Kumar Tulsian.
So, with manipulations they obtained signature from one Dharam Chand Jain as if he is also amongst aforesaid 24 Members and
applied for order of enquiry. Since they were backing of Shri Jyoti Basu, the then Chief Minister of West Bengal, as such
Cooperation Directorate was in their full support. But, suddenly this was came to notice of the Petitioner that to comply
the condition of one third support for order of enquiry said Shankar Lal Bhatter obtained signature from said Dharam Chand
Jain, Petitioner send Lawyers Notice to the Cooperation Directorate.
72. That the object of 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 were not to protect their own interest, but under offer of big monetary
gains from said Sanjay Kumar Jhunjhunwala decided to blackmail the Petitioner, taking advantage of the Membership of the said
Cooperative Society, as such considering their changing behave Petitioner also took appropriate steps completely in accordance
with the law and Rules, though then he was not aware that Shri Jyoti Basu personally is involved in the matter and supporting
such blackmailing activities. When the Directorate of Cooperation received said letter from Advocate of the Petitioner, changed
the strategy. They decided to hold the enquiry in the name of Inspection, ignoring the specific legal provisions for the Housing
Cooperative Societies. Under the Law, Inspection purely is a Departmental matter and outsiders including the members of respective
Society cannot be allowed at the time of the Inspection, while at the time of enquiry complainants for enquiry are entitled
to present at the time of enquiry. As a result, said 7 persons were not allowed to participate in the garb of Inspection in
the arranged enquiry, besides other grounds, the Legal Operative Mandatory Grounds that Membership of aforesaid 7 persons
were automatically ceased in accordance with the law, which was intimated them in time.
73. That as the object of the aforesaid 7 persons was not interested in to protect their own interests, but
under connivance with the said Maifadom intended to harass the Petitioner, as such make a strategy. If such refusal at all
was any cause of action, than the said 7 persons should have been joined in single dispute case, but as the object of the
aforesaid group was to blackmail the Petitioner, as such 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 Deputy 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,
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 one Shri Arjun Mondal was appointed as the Arbitrator to adjudicate the matter in dispute.
74. 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 certain conditions laid down by the said Law. This might have been considered
subsequently, that object of blackmailing to the Petitioner might not served from said Arjun Mondal, as such after 66 days
from the registration of the said dispute as Dispute Case, on 5th August 1988, but under the instructions from
Mrs. Mira Pandey, IAS, the then Registrar of Co-operative Societies, (subsequently Petitioner understood
that she then was performing illegal activities in the matters under direct instructions from Shri Jyoti Basu to help the
said Mafiadom to grab the properties of the Petitioner) file of the said Dispute Case was handed over to one Mr. N.
Goswami, without any appointment or authority. Under illegal instructions from the said Registrar, Mr. N. Goswami proceeded
with the matter in most absurd and illegal manner. Each and every fact relates to such illegality were put on record by the
Petitioner. In considerations of such situations, on 9th January 1990 Petitioner lodged a Complaint before Probodh
Dinkarrao Desai, the then Hon’ble Chief Justice of Kolkata High Court, against Mr. N. Goswami.
75. Since, the said Mr. N. Goswami conducted the entire proceedings of the said Dispute case without having
any appointment or authority, and to hide such fact he withheld the supply of the certified copy for about Ten Months, till
he not complied illegal instructions form said Mrs. Mira Pandey. In fact Certified Copy of the entire Order Sheet was supplied
on 6th January 1990 when Mr. N. Goswami, complete his illegal job, assigned by the said Registrar. 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 the notice of the
Petitioner that Mr. Arjun Mondal, ARCS, was actually appointed as Arbitrator.not Mr. N. Goswami.
76. That at the time of supply of certified copy at left portion of the said certified copy the date was
corrected by the pen, but without having any initial of authority, as such Petitioner returned it to the West Bengal Co-operative
directorate for initial at such correction made by the pen. Thereafter, on 1st February 1990 the selfsame Certified
Copy was returned to the Petitioner after, noting on the left part of it that "Corrected on verification of record."
77. That from the order sheet this was become ample clear that Mr. N. Goswami adjudicated entire proceedings,
without having any appointment or authority. As such Petitioner filed Appeal, against illegal adjudication conducted by him.
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 by the Petitioner and its grounds. Than said Mira Pandey
the then Registrar of West Bengal Cooperative Societies 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 Mrs. Mira Pandey,
the then Registrar of West Bengal Co-operative Societies, and said Mr. Mihir Ranjan Choudhury, ARCS, forgery of the Order
Sheet was committed to insert the name of Mr. N. Goswami. The format of the Order Sheet was regularly used in the Office of
Registrar from the Order Sheets Printed from the Government Press. But the said forged Order Sheet was prepared on Electronic
Type Writer even at the material time 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 same. However, said Mihir Ranjan Choudhury, was also party to said forgery, as
he inserted at the just below right corner of the Order Sheet that "Shri N. Goswami is appointed as Arbitrator in place of
Shri Arjun Mondal" without referring any legal formality or provisions, as were referred at the time of Appointment of Shri
Arjun Mondal. In consideration of his participation and to directly cause impact on the matter concerned with the said forgery,
then pending before West Bengal Cooperative Tribunal, said Mr. Mihir Ranjan Chowdhury, ARCS, subsequently 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.
78. That said Mr. Mihir Ranjan Chowdhury ARCS, was noticed by Letter dated 10th April 1991 sent
by Registered Post that he was "one of the parties in forgery of the order sheet in Dispute Case No. 43/RCS OF 1987-88." Mr.
Chowdhury maintained complete silence, as he was nothing to say against his crime.
79. That after knew about the said forgery Petitioner send Letter Petition dated 2nd December
1989 before Chief Justice of Calcutta High Court against Contempt of His Own Court by Mr. N.Goswami, the then alleged Arbitrator,
as already explained, another Letter Petition before Chief Justice of Calcutta High Court dated 9th January 1990,
against Contempt of Court by Mr. N.Goswami, the then alleged Arbitrator, as already explained, Letter dated 14th
February 1990 Mrs. Mira Pandey, the then Registrar of West Bengal Cooperative Societies, placing on record that 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, Letter dated 18th February 1990 sent 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 (as aforesaid)
was interpolated in the order sheet (till then Petitioner was not aware about forgery of the entire Order Sheet).
80. That after committing the aforesaid forgery, Office of the Registrar, under the signature of the same
Officer, who corrected the said Certified Copy-, issued Memo Letter No. 1602 dated 19th February 1990, upon the
Petitioner, informing thereby that one order was omitted inadvertently at the time of supply of the Certified copy. Thereafter,
Petitioner send protest letter to said Mr. S. N. Dey, who issued the said Memo Letter after issuing aforesaid Certified copy,
by Registered Letter in his personal capacity as well in his Officiating capacity with the copies to other authorities and
CBI, for action.
81. That forgery of the Order Sheet was not only crime on the part of the aforesaid person, but said Shrawan
Kumar Bhatter wanted to show the payment to the Petitioner, much higher than what he actually paid. As such he got forged
one Slip as if same, was written by the Petitioner asking Shrawan Kumar Bhatter to arrange payment of Rs.19200/- as very urgent.
Petitioner obtained "Certified Photocopy" of the said forged slip.
82. That in considerations of blackmailing activities with the help of Cooperation Directorate of West Bengal,
Petitioner meet with one Shri Dilip Kumar Chakraborty, Ex-MP, who personally meet and also wrote Letter dated 9th
March 1990 to Shri Bhakti Bhusan Mandal, Minister of Cooperation, West Bengal. Thereafter Petitioner 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 the representation of the Petitioner 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 the Petitioner were present. Minister instructed to the Petitioner to open the Meeting submitting his
matter. At this stage said Mazumdar wanted to say something secretly, as such Petitioner moved for time being out of the Chamber.
Within 30 second said Mazumdar come out of the Chamber informing the personal assistant of the Minister that he had finished
his job and going back. After that when Petitioner entered in the Chamber, Minister failed to recognise the Petitioner as
well as Shri Dilip Kumar Chakraborty, Ex-MP and refused that he had called the Petitioner for any Joint Meeting. Petitioner,
with surprising experience, returned back and after coming back he wrote a Letter to Shri Bhakti Bhusan Mondal that in consideration
of that day’s incidence this is clear that his mind is not competent to hold such important Office of Minister of a
State, so he should resign from the same. After going through the said Letter, under angriness developed from the same, Minister
send a Letter to Chief Secretary of West Bengal to withdraw Mrs. Mira Pandey from his Department. When this fact came to the
notice of Shri Jyoti Basu, Minister withdrawn his letter and even admitted that he might have sent said Letter under mistake.
His statement was published in the Newspaper.
83. That Petioner filed Application Under Section 340 Criminal Procedure Code against Plaintiff of the said
Dispute Case and 32 others including said Mrs. Mira Pandey (Senior) I.A.S., Mr. N. Goswami, against forgery of the Order Sheet,
before the A. K. Bhattacharya, learned the then 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 minister’s quota.
84. That under the impact of sudden Allotment letter (Petitioner was informed about the same by staff of
the Tribunal) from the Chief Minister’s Quota, behaviour of A. K. Bhattacharyya, the then learned Member of West Bengal
Co-operative tribunal was changed against Petitioner, which was appeared from comments, he made on 6th September
1990. Considering severe impact of such comments Petitioner with intention to clarify his position, sent letter dated 6th
September 1990, by Registered Post to A. K. Bhattacharyya, the then learned Member of West Bengal Co-operative Tribunal.
85. That one day one Mr. Milon Banerjee, Advocate, the then Government Pleader as he was not known about
the face of the Petitioner, appeared in the said Misc. Case No. 3 of 1990 and in presence of the Petitioner and started to
influence the lawyer of the Petitioner Mr. Diwakar Pandey, Advocate. In considerations of such situation, Petitioner send
protest letter as well as informed the Government authority by his letters dated 25th October 1990, and 8th
November 1990 about his such criminal misconduct.
86. That after receipt of the said allotment, learned Mr. A. K. Bhattacharyya, the then learned Member of
West Bengal Co-operative tribunal decided to abuse his Judicial Powers in judicial process against the Petitioner, and passed
several orders in serious abuse of the Judicial process. For instance on 18th January 1991, when Petitioner and
his Advocate both were present in the Tribunal Court, Mr. A. K. Bhattacharyya, the then learned Member of West Bengal Co-operative
tribunal immediately after entering in the Tribunal Court Room, but before sitting on the Chair informed the Advocate of the
Petitioner 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, the then learned Member of West Bengal Co-operative tribunal 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."
87. That when said Order was dictated, the lawyer of the Petitioner raised strong objection against such
false recording that he and his client are present in the Court Room, how such order is dictated. Hearing such objection Mr.
A. K. Bhattacharyya, the then learned Member of West Bengal Co-operative tribunal replied "you go wherever
you likes, truth is only which is recorded by me in the Order". Thereafter, the Advocate of the petitioner having no
scope to say anything, kept silent, till order was dictated and typed and given to the Advocate of the Respondent / Accused
No.1 (Shrawan Kumar Bhatter) in the matter to sign it. At this stage Advocate of the Petitioner also wanted to sign the Order
Sheet. Mr. A. K. Bhattacharyya, the then learned Member of West Bengal Co-operative tribunal instructed the Advocate not to
mention any thing else except the signature. When the Advocate of the Petitioner 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 the
Advocate of the petitioner also put the time under his signature in the Order Sheet.
88. In fact after hearing about the Allotment from the Chief Minister’s Quota in favour of Mr. A. K.
Bhattacharyya, the then learned Member of West Bengal Co-operative tribunal, from Tribunal staff and in considerations of
the comments as was made on 6th September 1990 by Mr. A. K. Bhattacharyya, as aforesaid, Petitioner decided and
prepared a Petition to file on 18th January 1991 before the Tribunal, but under the aforesaid circumstances, he
was not allowed to file the same, as such was lying with the Petitioner. Therefore, immediately after coming down from the
Building, where the Tribunal is exists, Petitioner Posted the said Voluminous Petition by name to Mr. A. K. Bhattacharyya,
the then learned Member of West Bengal Co-operative tribunal by Registered Post, from the Post Office, exists in the selfsame
building, in which Office of the Tribunal is exists, mentioning in the left upper corner of the Petition about the aforesaid
false recording in the order Sheet and allowing the Petitioner’s Advocate to sign and put the time of the signature,
which were proof of the false recording of the order sheet. Thereafter, A. K. Bhattacharyya, the then learned Member of West
Bengal Co-operative tribunal dismissed several matters of the Petitioner knowing fully adopting abuse of judicial process
by misusing his judicial office.
89. That with respect to the judicial proceedings adopted by A. K. Bhattacharyya, the then learned Member
of West Bengal Co-operative tribunal Advocate of the Petitioner also warned in writing to the Petitioner by his letter dated
16th April 1991.
90. That the behaviour adopted by A. K. Bhattacharyya, the then learned Member of West Bengal Co-operative
tribunal was also referred by the Petitioner in his 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 to Mrs. Mira Pandey, the then Registrar of Cooperative Societies against her Criminal Misconduct, she adopted
under illegal influence from Shri Jyoti Basu, the then Chief Minister of West Bengal.
91. That under the same strategy to blackmail the Petitioner Two separate Dispute Cases were filed against
the Petitioner. All the seven persons could have filed Single Dispute Case, but said Shrawan Kumar Bhatter chosen to file
separate Dispute Case. Although all 7 said persons were in connivance with each other, but reason for filing two new Dispute
cases separately was that while said Raj Kumar Dhawan and Chandra Sekhar Dhawan attended the said Special General Meeting
and signed Allotment signed in their favour and signed Agreement Executed in favour of the Petitioner, besides the put their
signature at the Copies of the Resolution. As such, with created false story they have to challenge their own signature. First
of all Photocopy of the Summon Form prepared with regards to Dispute Case filed by said Raj Kumar Dhawan and Chandra Sekhar
Dhawan was prepared by said Prabhu Dayal Sureka, who fill-up the forged order Sheet in the said Dispute Case No. 43/RCS OF
1987-88, proving connivance between all those persons filed two separate Disputes, because said Prabhu Dayal Sureka was one
of the Plaintiff in another Dispute case filed by the said Two brothers of Shrawan Kumar Bhatter namely Sushil Kumar Bhatter
and Ashok Kumar Bhatter and Sushil Kumar Tulsian.
92. That this is submitted on oath and affirmation that if allegation of the said Raj Kumar Dhawan and Chandra
Sekhar Dhawan that the Petitioner had obtained signature on some blank papers, as they falsely alleged in their Dispute Case
before Registrar of Cooperative Societies, is proved as true after any type of scientific testing including forensic test
of any other kind or manner as signatures were made by said Raj Kumar Dhawan and Chandra Sekhar Dhawan contrary to their aforesaid
false claim, they attendance the said Special General Meeting, where allotments were made in favour of all the existing members
of the Cooperative Society including said Raj Kumar Dhawan and his Son Chandra Sekhar Dhawan and they also signed agreement
executed in favour of the Petitioner. In fact entire exercise by the aforesaid 7 person, including said Raj Kumar Dhawan and
his Son Chandra Sekhar Dhawan, starting from application for enquiry of the working of the Cooperative Society and unto get
arranged Judgments / Orders in the aforesaid matters, was a strong evidence to support the blackmailing objects of the said
Mafia Sanjay Kumar Jhunjhunwala.
93. That the exercise of the said 7 persons was criminal offence, as well as conduct on the part of all Administrative
and Judicial Officers from the Department of Cooperation, Directorate of Cooperation, West Bengal Cooperation Tribunal, were
criminal misconduct and act of the respective Advocates were against their professional conduct. Those 7 persons under criminal
connivance with said Mafia Sanjay Kumar Jhunjhunwala caused severe damage to the interests of the rest 16 Members of the Society
and of the Petitioner, because by their such conduct they caused heavy damaged to the entire project which was belongs to
those 16 Members too, and who were not joined hands with the said Mafiadom. But, under the Nexus between Shri Jyoti Basu,
the then Chief Minister of West Bengal and said Mafia Sanjay Kumar Jhunjhunwala the process of Administration of Justice was
94. That the Petitioner state and submit that the said Mafiadom have tried their best level to embraces a
large number of Judicial Officers to effect the Administration of Justice, which time-to-time Petitioner put on the record
submitting Letter Petitions to the Hon’ble Chief justice of India and / or Hon’ble Chief justice of Calcutta High
Court with prayers to ensure enforcement of his Fundamental Rights, few of such letter Petitions are referred herein below:
22nd October 1990 Letter Application Under Article 32 of the Constitution addressed to Rang Nath
Mishra, CJ, of this Hon’ble Court, as the His Lordship then was. Shri Rang Nath Mishra J. is now member of the Committee
23rd November 1990 Application before the Governor of West Bengal, Chief Secretary of West Bengal,
Secretary Judicial Department, and Secretary Cooperation Department, by Registered Post for according sanction to prosecute
Mrs. Mira Pandey and others who indulged in forgery of the Order Sheet as aforesaid in Dispute Case No. 43/RCS of 1987-88.
6th December 1990 Letter Petition by Registered Post to Hon’ble Mr. Justice Probodh Dinkar
Rao Desai, the then Chief Justice of Kolkata High Court in respect of criminal activities with reference to Administration
13th February 1991 Letter to Hon’ble District Judge, Alipore (Calcutta)
20th February 1991 Letter Petition to Rang Nath Mishra, CJ, of this Hon’ble Court, as the His Lordship
then was. Shri Rang Nath Mishra J. is now member of the Committee on Petitions.
26th April 1991 Complaint against Learned Mr. J.C.Moulick, the then Munsif of 5th Court
at Alipore (Kolkata), before N.P.Singh, CJ. Of Calcutta High Court, as His Lordship then was;
30th April 1991 Complaint against learned Mr. A.K. Bhattacharya, the then Member of West Bengal
Co-operative Tribunal, Kolkata, before N.P.Singh, CJ. Of Calcutta High Court, as His Lordship then was, with reference to
dangerous state of affairs in respect of some documents with the Tribunal, relates to forgery in Order Sheet of the Co-operative
95. That when said Mafia Sanjay Kumar Jhunjhunwala realised that all efforts to blackmail to the Petitioner
are going futile, one day send clear threats that he ‘is in a position to use Shri Jyoti Basu, the then Chief
Minister of West Bengal to harass the Petitioner". Thereafter Petitioner by his Letter Dated 11th December
1989 by Registered Post to said Mafia Sanjay Kumar Jhunjhunwala put his threats on record. At the same time by Letter dated
18th December 1989 Petitioner forwarded copy of his 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.
96. Thereafter in consideration of political influence and misuse of powers in person and / or under influence
or illegal instructions from Shri Jyoti Basu, by other authorities supporting by their acts and deeds to the activities of
blackmailing of the said Mafia Sanjay Kumar Jhunjhunwala and his associates, then Petitioner started to refer Sanjay Kumar
Jhunjhunwala as Mafia Leader, in his each and every representation. This has caused some troubles for the said Mafia Sanjay
Kumar Jhunjhunwala, as it 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 partner of said Mr. Prabhu Dayal Sureka, he started
making false representations before the Lawyers of the Petitioner and filed a Defamation Suit before Kolkata High Court against
the Petitioner. After ex-party hearing of the Injunction Application filed by the said Mafia Sanjay Kumar Jhunjhunwala in
the said Defamation Suit, Prabir Kumar Mazumdar, J. as then His Lordship was passed an Order, as if the Petitioner have no
right to lodge even an First Information Report or make any Complaint before any authority.
97. The surprising part of the proceeding was that such ex-parte Petition was moved by the long time lawyer
of the Petitioner, learned Mr. P. K. Ray, Bar-at-Law. Subsequently Petitioner was Reported 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 the Petitioner. Appearance
of Learned Mr. P. K. Ray, Bar-at-law, in the said particular matter against the Petitioner was also not proper and justified
and was professional misconduct, as he was fully conversant with the Mafia activities run by the said Mafia Sanjay Kumar Jhunjhunwala,
as such on 17th August 1990 Petitioner 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 Lawyers who were
working for the Petitioner to make them against the Petitioner. In this respect Petitioner referring the name of 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,
Petitioner was compelled to send them Letter by Registered Post to clarify his position. This way said Sanjay Kumar Jhunjhunwala
tried his best level to damage efficacy of Administration of Justice.
98. That in considerations of the said Defamation Suit when the Petitioner appointed learned Mr. Gouri Shankar
Gupta, Advocate to conduct his case, the said Mafia Sanjay Kumar Jhunjhunwala and his Lawyer Shri Kishan Lal Bagaria, Solicitors
of M/S. B.M. Bagaria & Company, Solicitors, started to influence the said Gouri Shankar Gupta, Advocate as referred hereinbefore,
to sabotage the Judicial Proceeding against the Petitioner. In considerations of regular sabotage of the judicial proceedings
arranged by the said Mafia Sanjay Kumar Jhunjhunwala, the Petitioner find that he has no scope to get justice if he 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), Petitioner filed an application for according sanction, jointly before the President Of India
and Hon’ble Chief Justice of India, against Prabir kumar Mazumdar and Shyamal Kumar sen, JJ., as the then their Lordships
were. At the same time a joint complaint was lodged against learned Mr. Gouri Shankar Gupta, Advocate and Mr. Kishan Lal Bagaria,
Advocate from M/S. B.M.Bagaria & Co., Solicitors, and another complaint was lodged against Mr. Tapash Kumar Sarkar, Advocate
(being the Lawyer of the said Ava Rani Dey and Dipika Rani Bhattacharjee in the said Suit filed who was a party in manipulation
of the area of 6 Plots to blackmail the Petitioner), before the Bar Council of West Bengal. No reply or objections, at all
were filed by those Advocates, nor were served upon the Petitioner, nor any date was fixed to hear the aforesaid matters.
But, in gross abuse of the judicial process, and against the important principle of the Jurisprudence that "Justice must be
above all", but 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 the Petitioner filed Appeals before the Bar Council of India, which have been disposed off by the Bar Council of India
in the back of the Petitioner.
99. That the object of the Petitioner was just to break the sabotage caused by the said Mafiadom, in the
Administration of Justice, as such when he reported by the Court Peshkar of the Hon’ble High Court that Shyamal Kumar
Sen, J. as his Lordship then was, taken affidavits of the both side parties in the matter No.3028 of 1991, at his residence
to study the actual facts in the matter, the Petitioner decided to withdraw his aforesaid Application for according sanction,
as such on 25th June 1992 he tender his unconditional apology withdrawing his application for according sanction,
and sent letter in the same manner as was forwarded Application for according sanction.
100. That when Contempt Proceeding was moved against the Petitioner for Rule, by the Advocates of the said
Mafia Leader Sanjay Kumar Jhunjhunwala Hon’ble High Court directed to serve the copy of the Application upon the Petitioner.
This was well known to the said Mafia Sanjay Kumar Jhunjhunwala that if the copy of the application is served upon the Petitioner,
than obtaining of the Rule may not be so easy. As such he and his Solicitors Shri Kishan Lal Bagaria, Solicitors of M/S. B.M.
Bagaria & Company, Solicitors, made a tricky plan to show the service of the copy of the Application upon the Petitioner.
For the success of such tricky plan, Shri Kishan Lal Bagaria, Solicitors of M/S. B.M. Bagaria & Company, Solicitors knowing
fully send clerk from his firm at the noon time, when there were no scope of availability of the Petitioner at his residence.
Accordingly, on 13.9.1991 one person claiming his name as Jagneswar Sinha, allegedly from 9th Floor, Bamboo Villa,
168, A. J. Chandra Bose Road, Calcutta-14 being the Office of the Income Tax Department came at the residence of the Petitioner
with claim that he is from Income Tax Department and to serve a Notice upon the Petitioner.