51. That after failure in said attempt, said Chuni Lal Mukherjee the member of said Mafiadom, decided to cause some pressure by encroaching the properties of the Petitioner, as Petitioner send Lawyers Notice to said Chuni Lal Mukherjee, son of Late R. G. Mukherjee, the then resident of 11, Banmali Naskar Road, Kolkata-700034, against his intentions to encroach the properties of the Petitioner. After receipt of the said Notice he under connivance with the concerned Police Officer changed strategy and lodged one Criminal Case that Milap Chand Choraria (the Petitioner herein) demanded Rs.20,000/- from him, with object to get arrested him, when the Petitioner come to restrain him from encroaching the property of the Petitioner. But, when Petitioner taken appropriate steps against him, for time being, under advice from the said Mafia Sanjay Kumar Jhunjhunwala he decided to stop such activities against the Petitioner, and on 6^th February 1986, admitted in writing that the Criminal Case filed by him was untrue.

52. That thereafter said Sanjay Kumar Jhunjhunwala tried to develop personal rapo with the Petitioner, even some time with fraudulently claiming that he is going to Golf Club, dropped the Petitioner at his residence. But object of such action were to develop connections with the alleged other members of the Petitioner’s Cooperative Society, who were living in the same building. Thereafter, he meets secretly with the Tenants of the Petitioner and said them that they cannot win the Court cases against the Petitioner. So, if they want to live on the properties, they should send to the Petitioner, in the hell. Thereafter, a plot was hatched by the said Mafiadom to kill the Petitioner and accordingly on about 18^th July 1986 a severe attempt to murder of the Petitioner was committed, in which Petitioner suffered 42 stabs in his body. Thereafter, 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 Said Mafia Sanjay Kumar Jhunjhunwala gratified the Police Official, and arranged bail of one of such person attempted to murder the Petitioner. As such on 8^th October 1986 the Petitioner send his protest Letter to said Shri Bhola Nath Mukherjee, the then area Councilor, with copy to Police against his support to murderer.

53. That when the petitioner was in Hospital, said Mafia leader Sanjay Kumar Jhunjhunwala came to Hospital claiming as a curtsey call to know about the health of the Petitioner, but his object was different, which at that moment Petitioner not realised. During the said visit he informed that he has one friend in the Telegraph and ask him to publish one story related to attempt to murder of the Petitioner. However, on those days one regular feature under the heading "CALCUTTA ROUNDUP" was published. In the said feature one Tapash Kumar Chakraborty published several stories relates to crime matters. On 6^th October 1986 one News Item was published in the Telegraph’s said fixed Feature under heading "CALCUTTA ROUNDUP", with the specific heading for specific News item "Antisocials terrorise slumdwellers".

54. That the Petitioner was not reader of any English Newspaper, as such the said News was come to his notice only on 22^nd October 1986. After going by the said News Petitioner send a strong protest Letter to Mr. Aveek Sarkar, Chief Editor of Ananda Bazar Patrika Group of Newspapers (In the letter by mistake Petitioner 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 18^th July 1986 and 29^th 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." After receipt of the said letter Petitioner does not know what actions were taken by the management of the Telegraph, but for a long period the name of said Yellow Journalist Mr. Tapash Kumar Chakraborty were disappear from the Telegraph.

55. Thereafter, under further criminal conspiracy to blackmail and to cause heavy pressure upon the Petitioner, under a long term blackmailing strategy the said Mafiadom got obtained a letter, allegedly have been written by the Petitioner’s Ejected Tenants (Who vacated the respective Rooms, when in Execution proceedings, the Order was Passed for Execution of Decreed passed against respective Tenants, then the aforesaid themselves admitted before the Learned Court recording their admission in Court proceedings Police is not required to depute and they will vacate the respective Rooms, within the Period of Order) the then inhabitants of the said R. S. Plot No. 206. But, in the said letter this was described that the Petitioner is a dreaded criminal and removed the aforesaid Tenants by force. After going through the said created letter Petitioner understood that the story referred therein is totally false and frivolous as such he taken no care. This is needless to mentioned here that the said Letter was forwarded by said Mafia Leader Sanjay Kumar Jhunjhunwala send Letter by his covering Letter dated 5^th August 1986, immediately after returning of the Petitioner from the Hospital on 31^st July 1986.

56. However, Petitioner through his Advocate on records, wanted to know that who was behind the letter, as such when, aforesaid Tenants as a good gesture come to residence of the Petitioner to know about his health after attempt to murder, he shown the said letter, those (ejected) Tenants not only surprised, but declared that the Thumb impression of them are forged and even spelling of the Name of some tenants are not correct. As such Petitioner ask the said Mafia Sanjay Kumar Jhunjhunwala about authenticity of the Letter, which was never given. However, considering non-impact of the said created and false letter said Mafia Sanjay Kumar Jhunjhunwala developed and created another false and concocted story and informed the same to the Petitioner. From such developments, in the mind of the Petitioner doubt was started about the said Mafia Sanjay Kumar Jhunjhunwala that he himself might be behind the scene and possibility he himself directly may be involved in the Plot to kill the Petitioner, which subsequently was confirmed on private enquiry. However, as such Petitioner created a Pressure upon said Sanjay Kumar Jhunjhunwala that either he will disconnect his connections with him, or otherwise he should put the information he said to him which contained threats with the name of the Police Commissioner of Kolkata. As such said Mafia Sanjay Kumar Jhunjhunwala confirmed the said new but fake story in writing by his letter dated 5^th November 1986.

57. In fact by the said fake story said Mafia Sanjay Kumar Jhunjhunwala wanted to convey his threats that the Petitioner will be removed from the Properties with the help of the then Commissioner of Kolkata Police Mr. B. K. Basu. This is needless to be mentioned here that respective property was not within the area of the Kolkata Police rather within the area of West Bengal Police. On the basis of the said Letter Petitioner requested the then Police Commissioner of Kolkata Mr. Bikas Kali Basu, IPS that since his name is dragged in the story, he should find out the alleged Advocate, but action was not taken in the matter by the then Police Commissioner of Kolkata Mr. Bikas Kali Basu, IPS. Upon the enquiries the alleged Mahamadan advocate never surfaced in four corners of any Court in Kolkata, or neighboring Courts, as the story was completely fake and created by the said Mafia Sanjay Kumar Jhunjhunwala. But, from the said letter, this was become crystal clear that said Mafia Sanjay Kumar Jhunjhunwala has close connections with very powerful politicians and bureaucrats.

58. That in the said year of 1986, when attempt to murder of the Petitioner failed Shri Jyoti Basu the then Chief Minister of West Bengal instructed to Shri Kamal Kumar Basu the then Mayor of the Kolkata Municipal Corporation to help one adjudged and habitual Cheat Chittaranjan Ganguly and his pattern said Mafia Sanjay Kumar Jhunjhunwala. Accordingly, under a long strategy to blackmail the Petitioner, on 14^th 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 adjudged Cheat Chittaranjan Ganguly. This is matter of great concerns that much before creation of such fake Municipal Holding number, said Mafia Sanjay Kumar Jhunjhunwala informed by his said Letter dated 5^th November 1986 to the Petitioner in writing that Municipal Holding is exists in the name of said adjudged Cheat Chittaranjan Ganguly, which is evidence of the crime that said Mafia Sanjay Kumar Jhunjhunwala was behind the scene in the matter and his strong Nexus in the matter.

59. Thereafter, under the aforesaid long strategy to blackmail to the Petitioner, Kolkata Municipal Corporation revoked two sanctioned plans of the Petitioner on the false grounds that he obtained sanctions of the Building Plans under misrepresentations about the ownership. When Petitioner moved before Hon’ble Kolkata High Court, the said Order of Kolkata Municipal Corporation was set-aside.

60. That under the said long strategy to blackmail the Petitioner, Kolkata Municipal Corporation 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 the then Mayor of Kolkata Municipal Corporation called the Petitioner through one Councilor Shri Shanti Lal Jain and informed and conveyed the Petitioner that if he wants to live in Kolkata, he should transfer the property to the Sanjay Kumar Jhunjhunwala. In respect of the subsequent Order of Revocation of the Plans, Hon’ble Kolkata High Court directed to Kolkata Municipal Corporation to withdraw its illegal Second Order of revocation of plan.

61. That as the said Mafia Sanjay Kumar Jhunjhunwala and his associates including Chuni Lal Mukherjee made long strategy to blackmail the Petitioner through various flimsy litigations, they attracted the Vendors of the Petitioners to join with them. This fact is confirmed from one letter received by the Petitioner from the Grand Daughter of said Vendor Ava Rani Dey and Daughter of Dipika Rani Bhattacharjee namely Mrs. Ratna Bhattacharjee, of 10/10, Kali Charan Dutta Road, Kolkata-700061.

62. That from the said letter of Mrs. Ratna Bhattacharjee, this was also confirmed that said Chuni Lal Mukherjee, as associate of said Mafia Leader was in regular touch with the Vendors of the Petitioner and under their strategy to blackmail the Petitioner got filed a Civil Suit against the Petitioner through his aforesaid Vendors namely Ava Rani Dey and Dipika Rani Bhattacharjee, completely based on false claim. As it was already explained in detailed that total area measurement of the respective properties was 66 Cottas, including 10 cottas, over which said Ava Rani Dey and Dipaika rani Bhattacharyya lost their claim.

63. That Ava Rani Dey and Dipika Rani Bhattacharjee 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 not "legs to stand" as he was not the Owner of the Properties referred in Suit Khatian as well as of the Suit Land of the said Suit, i.e. R.S. Plot No.219 as aforesaid and Court decided ownership of the said Suit Land 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, if not challenged within limited prescribed period from the date of its publication, by the authority. According to the respective 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. Said Ava Rani Dey and Dipika Rani Bhattacharjee admitted in their plaint that they sold 35 cottas of land to the Petitioner. Without admitting and prejuding his rights, just for arguement sake, Petitioner submit that therefore, out of 56 Cottas of land if any dispute was pending, that cannot go beyond the landed properties measuring more or less 21 cottas, comprised in R. S. Plot No. 195 and 206 as aforesaid. But, in the Suit, with clear objectives to blackmail the Petitioner by misusing the platform of the "Administration of Justice", the area of the properties by manipulating 6 C. S. Plots with 6 Corresponding R. S. Plots, but without clarifying them as C. S. Plots or R. S. Plots referred as 12 individual Plots, and virtually Injunction was sought over entire properties including sold properties and properties covered by the law of ResJudicata, as they lost their Suit finally up to Kolkata High Court, and referred aforesaid properties under manipulations as 94 cottas. This was a severe Crime under Section 340 of the Criminal Procedure Code, provided respective Judicial Officer could have acted judiciously, since this was a strong and open evidence of the blackmailing by misusing the Administration of Justice.

64. That Learned Presiding Officer of the Court of the 5^th Munsif, Alipore Mr. J. C. Moulick, was under embracement of the said Mafiadom, as such passed Injunction Order against the Petitioner, in a matter which admittedly was based on clear manipulations. As such the Petitioner filed Appeal against the Injunction Order of the Learned Court of the Munsif. At the first instance of hearing of Appeal, Learned Additional District Judge Mr. A.K. Chowdhury, made comment in open Court that in considerations of such 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 5^th Munsif, Alipore. As such Petitioner filed Revision Application before the Hon’ble Kolkata High Court. At the 1^st instance of hearing Hon’ble Court satisfied that the Order of the Munsif was unjustified as such agreed to set-aside the same. At this stage the Senior Lawyer of the Petitioner Learned Mr. Shakti Nath Mukherjee, Bar-at-law argued that in considerations of the manipulations contained in the plaint he wants to place complete argument in the matter enable to Hon’ble Court to pass a Rule to reject / return of the Plaint. Hon’ble 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 the Advocate-on-record of the Petitioner Mr. Gouri Shankar Gupta, Advocate.

65. That initially Mr. Gouri Shankar Gupta, Advocate suggested the Petitioner for some compromise. When Mr. Gupta received negative response from the Petitioner, he entered in underhand criminal agreement with the opposite Party, as such one day when matter was called for hearing, and even Hon’ble Judge was ready to Passover the matter to hear the matter from Ld. Mr. Shakti Nath Mukherjee, Bar-at-law, who also send message for Passover of the matter, as he was busy in another Court with other matter, but, under the aforesaid underhand criminal agreement Mr. Gouri Shankar Gupta, Advocate even ignoring strong objections from the Petitioner, moved the matter through another Lawyer and submitted knowing fully incompetent arguments. As a result, the same Order was passed by the Hon’ble High Court, which Hon’ble Court was ready to pass earlier after initial hearing of the Petition. The order of the Munsif was set aside and matter was returned for further hearing.

66. That earlier Order was passed under the embracement of influence, by the self-same presiding Officer of the Learned Court of the Munsif Mr. J.C. Moulick who once again passed injunction Order against the Petitioner 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. At the time of hearing of the Injunction Order Petitioner pleaded in writing that since he is defendant in the Suit, so his argument may not be considered as bonafide, but the documents filed by the Plaintiffs of the said Suit Ava Rani Dey and Dipika Rani should be taken into consideration for the passing the Order of Injunction Application. Since the documents referred therein by the said Plaintiff have shown the complete area with regards to 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 all rights, claim and 35 cottas of land which they themselves admitted as sold to the Petitioner. But, the Presiding Officer of the Learned Court of 5^th Munsif Mr. J.C.Moulick, was under embracement, as such ignoring all 16 Rulings of different High Courts, documents referred and filed by the Plaintiff themselves, passed injunction order against the Petitioner giving flimsy grounds that "court cannot embark upon at this stage" for not relying upon the documents filed by the Plaintiff.

67. That in considerations of such acts and Deeds Petitioner 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 lodged Prosecution Permission Petitions 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.

68. That in any case, without admitting and prejudice his rights, just for argument sake this is the submission of the Petitioner that, as per the document admitted by the aforesaid plaintiffs and their admission about 35 cottas of land and under law of Resjudicata in respect of 10 Copttas of land over which those plaintiff lost their Suit, even if there were any dispute that could have been with regards to payment in respect of properties more or less 21 Cottas comprised in R. S. Plot No. 195 and 206. Therefore, the plaintiff if could have filed a suit against the Petitioner, i.e. could have been limited to payment of the properties measuring 21 Cottas of aforesaid R. S. Plots. But as stated hereinbefore the object of the said Suit was to blackmail the Petitioner and Learned Mr. J. C. Moulick, the then Presiding Officer of the Court of 5^th Munsif, Alipore, was under complete embracement to help the aforesaid blackmailing activities, thus committed Contempt of his own Court by Over Ruling 16 Rulings of different High Courts and ignoring the evidence relied upon by the Plaintiff themselves of the suit, and further ignoring the directions passed by the Hon’ble 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, and passed order of injunction order against the Petitioner.

69. That as stated hereinbefore, said Mafiadom intended to open different fronts of litigations to cause heavy pressure upon the petitioner, as such when Attempt to murder took place said Mafia Leader Sanjay Kumar Jhunjhunwala went several times at the Hospital to know about the health of the Petitioner, where he succeed to develop connections with one Shrawan Kumar Bhatter, who also booked the Flat with the Petitioner. When Petitioner after release from the Hospital come to residence, said Shrawan Kumar Bhatter along with his father Shankar Lal Bhatter meet with the Petitioner and said that when Sanjay Kumar Jhunjhunwala interested to purchase the property, why he is not selling it to him, when he is ready to give good money. When Petitioner refused to accept such proposal, said Shrawan Kumar Bhatter and his father Shankar Lal Bhatter started to meet each person, who booked flats with the Petitioner and made promoters in his Cooperative Society, so he can create pressure upon the Petitioner taking advantage of the Membership of the said Cooperative Society. This is matter of fact that till then, starting from 1982, said Shrawan Kumar Bhatter or Shankar Lal Bhatter never go to the property, as they have to do nothing with it as it was belongs to the Petitioner, they have just booked the Flats and then were entitled to get their respective flats, on the terms and conditions agreed upon between both side. But, when the said Mafia advice them to took advantage of the Membership to create pressure upon the Petitioner to compel him to sell the properties to him, they under some huge amount of offer, decided to misuse the card of membership.

70. That in the meantime, Petitioner got sanction of Plan and called a Special general meeting of the society to confirm the Allotment of the plan’s Flats and comprehensive plan with regards to properties, as such a Special General Meeting of the Cooperative Society was held on 6^th September 1986 in accordance with the agenda of the said Meeting and Allotments were made from northern side proposed Building in favour of 15 persons considering the required area of each person and 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 (except the Petitioner) Members. The said two Building has to be constructed at the Properties comprised at said R. S. Plot No. 205. In accordance with the agenda and proposal, the tenanted properties comprised in R. S. Plot No. 194 were allotted in favour of the Petitioner. 17 Members, including Raj Kumar Dhawan and his Son Chandra Sekhar Dhawan, attended the Special General Meeting. Out of rest 7 Members 2 Members telephoned to the Petitioner informing the reason of not coming to 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 the Petitioner that they are interested in Allotment, but are interested to see the sale of the property to said Mafia Sanjay Kumar Jhunjhunwala, as such decisively not attended the said Meeting.