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Home | Letter 2 Hon'ble CJI Mr. R. C. Lahoti | PHOTO / TYPED COPIES OF DOCUMENTS | Volume-I (INDEX) | List of Dates | SYNOPSIS | PETIOTIONER/RESPONDENTS | Main Petition Para 1-15 | Main Petition Para 16-40 | Main Petition Para 41-60 | Main Petition Para 61-80 | Main Petition Para 81-100 | Main Petition Para 101-120 | MainPetition Para 121-155 | QUESTIONS OF LAW | Grounds | Prayers | Volume-II (INDEX OF ANNEXURES) | Letter of 9th September 2003 to President of India and Chief Justice of India | Press Statement | ANNEXURE-28-A (Forged Order Sheet) | Application 4 Prosecution 2 Justice Ahamadi | Application 2 Prosecute Registrar SC
Main Petition Para 81-100

81. That Suit filed by the Respondent No. 32 and her daughter was based on manipulation of the area of the Suit Land. But, Injunction Order against Petitioner was passed by Mr. J. C. Moulick, Learned Munsif, 5th Court at Alipore as such Petitioner filed Appeal. After hearing about such manipulations, 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, he withheld passing of the order for few days. When he passed the Order, he upheld the injunction order passed by the Court of the 5th Munsif, Alipore. As such Petitioner filed Revision Application before the Honble Kolkata High Court. At the 1st instance of hearing Honble Court 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 will plead satisfactory argument to pass a Rule to reject / return of the Plaint. Honble Court agreeing with the same fixed the matter for final hearing. Under development of such adverse situation against their blackmailing objects, Advocate of the said Mafiadom started to influence the Advocate-on-record of the Petitioner Mr. Gouri Shankar Gupta, Advocate. Initially Mr. Gouri Shankar Gupta, Advocate suggested to the Petitioner for some compromise with the Respondent No. 25. Petitioner refused it, immediately thereafter, Mr. Gupta, 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 for some time to hear Ld. Mr. Shakti Nath Mukherjee, Bar-at-law, who also send message for Passover of the matter, Mr. Gouri Shankar Gupta, Advocate even ignoring strong objections from the Petitioner, moved the matter through another Lawyer and submitted knowing fully weak pleadings. As a result, on 29th March 1990 same Order was passed by the Honble High Court, which Honble Court was ready to pass on the 1st day of hearing of Revision Petition. Mr. Gouri Shankar Gupta, Advocate allowed to record the presence of Ld. Mr. Shakti Nath Mukherjee, Bar-at-law, who was not present at the time of hearing of the matter. The order of the Munsif was set aside and matter was returned for further hearing. Photocopy of the plain copy of the said Order is annexed herewith and marked as ANNEXURE "A-29".

82. That in considerations of the forgery of the order sheet of Dispute case No. 43/RCS/87-88 as aforesaid, on 20th April 1990 Petitioner filed Application Under Section 340 Criminal Procedure Code before West Bengal Co-operative Tribunal, against Respondent No. 30 and other Accused / Respondents including said Mrs. Mira Pandey (Senior) I.A.S., the then Registrar of Respondent No. 12, Mr. N. Goswami, C.D.O., (who criminally proceeded and adjudicated the Dispute Case No. 43/RCS/87-88 without any appointment and authority), against forgery of the said Order Sheet, 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. Photocopy of 1st page of forged Order Sheet, one envelop, and one summon each one partly or completely fill-up / written by the hand and Pen of said Prabhu Dayal Sureka already annexed hereinbefore under marked ANNEXURE "A-28".

83. That on 13th July 1990 Petitioner wrote a Letter to West Bengal Minister Shri Bhakti Bhusan Mondal that in consideration of absurd experiences of 25th April 1990 this is clear that mind of the Minister is not competent to hold such important office, so in the larger public interest he should resign. After going through the said Letter, and under angriness, Minister sends a Memo Letter to Chief Secretary of West Bengal to withdraw Mrs. Mira Pandey from his Department. This is presumed that when this fact was placed in the notice of Shri Jyoti Basu, Minister withdrawn his Memo Letter and even admitted before the Pressmen that he might have sent said Memo Letter under mistake. His statement was published on 21st September 1990 in the Newspaper. Photocopies of Letter dated 9th March 1990, 27th March 1990, 13th July 1990 and News published on 21st September 1990 are annexed herewith and marked as ANNEXURE "A-30" Collectively.

84. That in consideration of atrocities caused by use of huge black money and based on blackmailing activities suffered by the Petitioner, caused by the Respondent No. 25 and his associates, Petitioner started to refer the Respondent No. 25 as Mafia Leader, in his each and every representation, as this was his real and true face. To escape from situation caused by exposure of his real and true face by such references, a criminal conspiracy was hatched with help from his Lawyer Mr. Kishan Lal Bagaria, Solicitor, under which he started making false representations before each and every Lawyer of the Petitioner and filed a Defamation Suit before Kolkata High Court against the Petitioner. In the said Defamation Suit, ex-party hearing of the Injunction Application filed by Respondent No. 25 order was passed by Prabir Kumar Mazumdar, J. as then He was, in such a language which restrained the Petitioner from his fundamental rights to lodge even a Complaint before any authority. Surprising part of the proceeding was that ex-parte application for injunction order was moved by the long time lawyer of the Petitioner, learned Mr. P. K. Ray, Bar-at-Law, who was fully conversant with the atrocities suffered by the Petitioner and Mafia activities runs by Respondent No.25. 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 M. P.) 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 neither was proper nor was consistent with his professional conduct, as such on 17th August 1990 Petitioner send a protest letter to Mr. P. K. Ray, Bar-at-law. Otherwise, Petitioner have very good relationship with Ld. Mr. P. K. Ray, Bar-at-Law, as it may appear from the Letter from Mr. Debal Banerjee, Bar-at-Law (Son of Ld. Mr. Milon Banerjee, Ex-Attorney-General of India), which he send after knew about attempt to murder against Petitioner from Ld. Mr. P. K. Ray, Bar-at-Law. A copy of the said Letter dated 17th August 1990 and Photocopy of Letter from Mr. Debal Banerjee are annexed herewith and marked as ANNEXURE "A-31" Collectively.

85. That in considerations of such constant and regular sufferings of atrocities having with severe intensity and magnitude Petitioner prepared a Voluminous Memorandum dated 5th September 1990, printed and published its 2000 copies under heading "A MATTER OF THE CALCUTTA MAFIA and challenges to ADMINISTRATION OF JUSTICE" and sent it to all Members of Parliament, all Members of West Bengal Legislative Assembly, all Councilor of Kolkata Municipal Corporation, Members of the Judiciary and various other authorities from the Central and the State Government. This Memorandum was acknowledged by Memo Letter No. 10666/SC/PILC/90 dated 17th November 1990 by the Supreme Court of India.

86. That on 25-26th July 1990 Petitioner filed four (4) Appeals as Unregistered Appeal Nos. 15, 16, 17, 18 all of 1990 before Respondent No.13, as certified copies of the impugned orders or Notification were due. After receipt on 17th August 1990 Certified copy of the Notification was filed on 29th August 1990 and by order dated 5th September 1990 it was registered as Regular Appeal No. 32 of 1990 as against Un-registered Appeal No.16 of 1990, after satisfying about the limitation point. But, before it in or about 3rd September 1990, Mr. A.K. Bhattacharya, the then learned Member of Respondent No.13 dismissed the Un-registered Appeal No. 15 of the 1990 on the alleged grounds that the certified copy is not filed, which in fact was withheld by the Respondent No. 12 with malafide intention to got obtain such order. In fact when Misc. Case No. 3 of 1990 filed against forgery of order sheet of dispute case No.43/RCS/87-88 Under Section 340 of Criminal Procedure Code reached at a crucial stage, Mr. A. K. Bhattacharya, the then learned Member of Respondent No.13, who was just at the verge of retirement, was granted allotment of the properties at Salt Lake from the Chief ministers quota. One staff member of the Tribunal informed about such allotment to Petitioner. Under the impact of such sudden Allotment letter from the Chief Ministers Quota, besides such order of dismissal dated 3rd September 1990, on 6th September 1990 under changed behaviour Mr. A. K. Bhattacharyya, made some unexpected comments. Considering severe impact of such comments Petitioner, sent his letter dated 6th September 1990, by Registered Post to Mr. A. K. Bhattacharyya, to clarify his position. In fact after aforesaid Allotment Mr. A. K. Bhattacharyya, the then learned Member of Respondent No.13 decided to abuse his Judicial Powers in judicial process against the Petitioner, and passed several orders in serious abuse of the Judicial process, but this was not clear that why order dated 5th September 1990, was passed judiciously by which Un-registered Appeal No. 16 of 1990 was registered as Appeal No. 32 of 1990, but subsequently it was also dismissed on 16.4.1991 on some pretext. Photocopies of the Order in Un-Registered Appeal No. 15 and said letter dated 6th September 1990 is annexed herewith and marked as ANNEXURE "A-32" collectively.

87. That on 8th November 1990 one Mr. Milon Chandra Bhattacharjee, Advocate, the then Government Pleader, appeared on behalf of Mrs. Mira Pande said Registrar and 3 other accused by filing Vakalatanama and in presence of the Petitioner, and others including Mr. Sudhir Kumar Dey, one Mr. Talwar, both from Cooperative Directorate, Lawyer of Respondent No. 30 Mr. N. Khaitan, Advocate Respondent No. 30 himself, started to influence the lawyer of the Petitioner Mr. Diwakar Pandey, Advocate. Such criminal misconduct of Mr. Milon Chandra Bhattacharjee, Advocate was referred in Letter 8th November 1990 sent by Registered post to him, Photocopy of which is annexed herewith and marked as ANNEXURE "A-33".

88. That it was already transpired that after aforesaid Allotment Mr. A. K. Bhattacharyya, the then learned Member of Respondent No.13 decided to abuse his Judicial Powers in judicial process against the Petitioner. For instance on 15th January 1991 he dismissed Un-Registered Appeal Nos. 17 and 18 of 1991 on complete flimsy grounds that "No separate petition for condonation of delay has been filed though it is palpably clear that the instant appeal was filed long after the expiry of the prescribed period." While fact remains and can be verified from the same order that "the date of application for the certified copy was made on 29.1.1990 and it was obtained by them not before 23.11.1990" The impugned Order was dated 17.1.1990 and certified copy was filed on 29.11.1990. Therefore, even if Appeal could have been filed upto 5th December 1990 no separate petition for condonation of delay was required under the Law. However, absurd proceeding was crossed its all limits on 18th January 1991, when Petitioner and his Advocate both were present in the Tribunal Court, Mr. A. K. Bhattacharyya, 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, started dictating of 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." at this stage lawyer of the Petitioner raised strong objection against such false recording, than Mr. A. K. Bhattacharyya, replied that "you go wherever you likes, truth is only which is recorded by me in the Order". After order was dictated and typed and given to the Advocate of the Respondent / Accused No.1 in the said (Respondent No. 30 herein) Misc. Case No. 3 of 1990 to sign it, lawyer of the Petitioner also wanted to sign the Order Sheet. At this stage Mr. A. K. Bhattacharyya, Tribunal Member instructed lawyer of the Petitioner not to mention any thing else except his signature. Lawyer of the Petitioner signed and put the time as 12.07 p.m. after verification from Mr. A. K. Bhattacharyya, just under his signature in the Order Sheet. In fact after hearing about the aforesaid allotment from the Chief Ministers Quota in favour of Mr. A. K. Bhattacharyya, and in considerations of the aforesaid comments made on 6th September 1990 by Mr. A. K. Bhattacharyya, 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 same was lying with the Petitioner. Immediately after coming down from the Building, Petitioner Posted the said Petition addressed by name to Mr. A. K. Bhattacharyya, Tribunal Member by Registered Post, from the Post Office, exists in the self-same building of the Tribunal, mentioning at the left upper corner of the Petition about the aforesaid false recording in the order Sheet and allowing the Petitioners Lawyer to sign and put the time, which was proof of the false recording of the order sheet. Thereafter, by misusing his judicial office, on 16th April 1991 Mr. A. K. Bhattacharyya, dismissed said Appeal No. 32 too and Misc. Case No.1 of 1991 on this or that pretext. Photocopy of certified copy of said orders in Unregistered Appeal No. 17, 18 and Appeal No.32 of 1990 and order dated 18th January 1991 in Misc. Case No. 3 of 1990, and subsequent Order in Appeal No. 32 of 1990 and Misc. Case No.1 of 1991 are annexed herewith and marked as ANNEXURE "A-34" Collectively.

89. That in the month of December 1990 former Punjab Governor and former Chief Minister of West Bengal and Senior Lawyer Shri Siddartha Shankar Ray demands probe into assets of Basus family, while the then M. L.A. and presently Trinamul Member of Parliament Mr. Sudip Bandopadhyay charged with that "Basu accepted kickbacks from builders". Photocopies of the aforesaid News items are annexed herewith and marked as ANNEXURE- "A-35" Collectively.

90. That Memorandum dated 5th September 1990 was written in English, Petitioner received reply in Bengali (Though till then Bengali was not declared as a Official Language by the West Bengal Government) by Memo Letter No. 329 Coop/H/3P/2/83(1) dated 24th January 1991, from Cooperation Department. The subject matter in the reply was adopted not from the heading of the Memorandum, but from its 7th Page, referring therein that Chief Minister of West Bengal received Memorandum. But, in spite of assurances given for appropriate action in the said reply letter, no action was taken.

91. That after going through Memorandum dated 5th September 1990, one M.L.A. of West Bengal Legislative Assembly Dr. Manash Bhuinya, agreed to raise the whole issue in West Bengal Assembly on 22nd February 1991. When on 22nd February 1991 Petitioner reached at the residence of Dr. Manash Bhuinya, M. L. A., at MLAs Hostel, at Kyed Street, Kolkata, Dr. Bhuinya under the changed behavior and attitude informed that plan of his statement in Assembly was changed. As such Petitioner return back to his residence. But, within few minutes from his returning to 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 son of the Petitioner, in which both the legs of the son of the Petitioner were severally damaged. He was able to stand on his own legs only after treatment for more than 30 Months and after 22 Major Operations, in Kolkata at Kolkata Medical Research Institute of Kolkata and Holy Family Hospital at Delhi. That with regards to staged truck accident caused with sole object and intention to kill son of the Petitioner. After personal enquiry this was reported that the said Truck was standing since 9.00 A. M., morning in a Compound situated in the Northern Side of the Road. In the said Compound there were several Almirah Factories, as such Almirahs were loaded over the Truck to create confusion amongst factory people. Since the truck accident was result of the conspiracy hatched to kill the son of the Petitioner, under Police Protection, as such in the said First Information Report Police knowing fully recorded false fact that truck was from the west to east, while Truck actually 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 Petitioner reached at the accident side, where till then his son was under the Tyre of the Truck, Petitioner seen that Truck came from the Northern side Compound with clear intention to kill son of the Petitioner. Therefore, false recording of direction of the truck was a part of the Plot hatched under connivance between the Respondent No. 25 to 32 and respective Police Officials. Photocopies of the Memorandum dated 5th September 1990, printed and published under heading "A MATTER OF THE CALCUTTA MAFIA and challenges to ADMINISTRATION OF JUSTICE" and First Information Report containing false direction of Truck are annexed herewith and marked as ANNEXURE "A-36" Collectively.

92. That Ld. Munsif Mr. J.C. Moulick on 26th March 1991 once again passed injunction Order against the Petitioner by overruling 16 different Rulings given by the different High Courts, and referred in writing by the Petitioner. Since the documents referred by the Plaintiffs of the Suit, total measurement with regards to R. S. Khatian No. 530 and 534 was just as 66 Cottas, against which under Schedule "A" of the Plaint property was falsely referred as 94 Cottahs. In the Plaint they admitted that they have sold 35 Cottahs of Land to the Petitioner, which was referred as Schedule "B". Plaintiffs suppressed the material facts that over 10 Cottahs of land they have lost their rights, titles and interests. Therefore, 59 Cottas of Suit Land was embarked as part of blackmailing strategy, and under criminal conspiracy and under open embracement Mr. J.C.Moulick, the then Presiding Officer of the Learned Court of 5th Munsif 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. In considerations of such criminal acts and deeds, Petitioner filed Complaints before Bar Council of West Bengal against Mr. Tapash Kumar Sarkar, Advocate of the Respondent No. 32 and her daughter 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, which never replied.

93. That in fact Mr. J. C. Moulick, the then Munsif, Alipore, 5th Court, when passed the Injunction order against the Petitioner, ignored the order of the Honble High Court in Revision Petition under Civil Order No. 845 of 1990 interalia observed that "Mr. Mukherjee (name of Mr. Mukherjee was wrongly but with permission from Ld. Mr. Gouri Shankar Gupta, Advocate was recorded) appearing for the petitioner submits that the properties alleged to have been sold away by the opposite parties to the petitioner have found place in the C Schedule to the plaint which, according to the opposite parties also have been sold to the petitioner. Mr. Raychoudhury appearing for the opposite parties submits that the plaint may have to be amended for acrutinising some plots in two different schedules." And further that "The impugned order is set aside. But, the parties will maintain status quo in respect of the all the properties involved in the suit excepting 33 cottahs of land which, according to the plaintiffs, have been sold out to the defendant until disposal of the injunction petition by the trial court". As stated hereinbefore that Two Surveys were conducted in the year of 1932 and 1956 respectively. In 1932 Properties in question were recorded as C. S. Plot Nos. 307, 308, 309, 310, 311, and 311/995 under C.S. Khatian No.530 and 534 which were converted in the year of 1956 as R. S. Plot No. 194, 195, 205, 206, 207 and 219 under R. S. Khatian Nos. 530 and 534. In the plaint under Schedule "A", and "C" all the aforesaid Six C.S. plots were mixed with all the Six R. S. Plots and were referred as 12 individual plots without describing them as C. S. Plot or R. S. Plot Nos. Area under Schedule "A" were referred as 94 cottahs as against 66 cottahs of the total land comprised in the aforesaid two Khatian. Under the schedule "B" the admitted sold land 33 cottahs of land were described out of R. S. Plot No. 194, 205 only. Properties sold in R. S. Plot No.207 were not referred. Properties comprised in R.S. Plot No.219 over which the plaintiff of the suit lost their claim in the aforesaid Suit were also not referred under schedule "B". In the schedule "C" the measurement of the landed properties even after alleged amendment maintained all 6 (six) R. S. Plots and 59 cottahs of land. Such thing was made only possible under embracement of Mr. J. C. Moulick. Copy of order passed by the Ld. Mr. J. C. Moulick on 26th March 1991 and details of properties of which Sale Deeds were executed are annexed herewith and marked as ANNEXURE "A-37" collectively.

94. That on 1st April 1991 Petitioner filed unregistered Appeal No. 4 and 5 of 1991 before West Bengal Cooperative Tribunal, but most surprisingly and under criminal connivance files of the aforesaid Appeals were missing or got stolen by Mr. Mihir Ranjan Choudhury, ARCS, Secretary of Tribunal, who was party in forgery of the aforesaid Order Sheet. During the same period going through the hand writing of the Mr. Mihir Ranjan Chowdhury, the then Secretary of Tribunal, Petitioner came to know about indulgence of Mr. Choudhury in the forgery of Order Sheet of Dispute Case No. 43/RCS/87-88, as such by his Letter dated 10th April 1991 placed the same on record. Photocopy of the said Letter is annexed herewith and marked as ANNEXURE-"38".

95. That with respect to the judicial proceedings adopted by Mr. A. K. Bhattacharyya, Advocate of the Petitioner also warned in writing by his letter dated 16th April 1991, as on this day Appeal o. 32 of 1990 filed by the Petitioner was dismissed on the alleged grounds that Petitioner filed Stay Petition without any Affidavit.

96. That proceedings in the said Suit filed by Respondent No. 32 and her daughter was result of their joining the hands with Respondent No. 25 and his associates including Respondent No. 27 to support their blackmailing activities. This fact was confirmed from letter dated 11th June 1991 received by Petitioner, through Registered Post from the Grand Daughter of Respondent No. 32 namely Mrs. Ratna Bhattacharjee. From the said letter of Mrs. Ratna Bhattacharjee, this was also confirmed that Respondent No. 27 was in regular touch with the Respondent No. 32 and her daughter, and was behind the filing of Suit against the Petitioner based on manipulations of the measurement of the properties comprised in R.S. Khatian No. 530 and 534 as aforesaid. Letter of Mrs. Ratna Bhattacharjee is in Bengali script, as such Petitioner craves leave to refer the same at the time of hearing of the Petition along with English translation, if necessary.

97. That Petitioner approached each and every authority starting from respective Local Police Station and up to the Honble President of India, and till date yet to get Justice, as under Politics-Crime-Nexus, made his life measurable 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. Petitioner forwarded numberless memorandums, representations, Applications, and Complaints before the President of India, Chief Justice of India, to the Government of India through its each and every authority including Prime Minister of India, Home Minister of India, Finance Minister of India, Cabinet Secretary, Home Secretary, Revenue Secretary, Director General Revenue Intelligence, Chairman, Central Board of Direct Taxes, Director-General of Inv. (Inspection), W.B., Aaykar Bhawan, Kolkata, Appropriate Authority, W.B., Income Tax Department, Aaykar Bhawan, Kolkata, Chief Commissioner of Income Tax, West Bengal Circle, the Office of the Chief Vigilance Commissioner, Office of the Central Bureau of Investigation, either under political pressure or influence or otherwise, as subsequently were admitted in the Report by the Vohra Committee, no actions were taken on the basis of his any of such memorandums, representations, Applications, and Complaints thus strengthen the blackmailing activities of the said Mafiadom based on huge black-money and muscle powers, against the Petitioner. In recent past, Petitioner also informed to Mr. S. Narayan, the then Union Finance Secretary, Mr. Ajay Vikram Singh, the then Union Revenue Secretary, Mr. D.C.Gupta, the then Additional Secretary to the Finance Department, Shri Kamal Pandey, the then Union Home Secretary, Shri Yashwant Raj, the then Joint Secretary (Admn & PG), Ministry of Home Affairs, Shri N. Vittal, the then Chief Vigilance Commissioner, Mr. P. C. Sharma, Director, Central Bureau of Investigation, Mr. P.K.Sarma, the then Chairman, Central Board of Direct Taxes, Shri Sishir Sinha, Additional Director of Income Tax (Investgaion), Unit-II, Kolkata Shri Rajesh Kumar Bhoot, Dy. Director of Income Tax (Investigation), Unit-II(4) about mafia activities based on huge black money causing severe infringement of the fundamental rights of the Petitioner. But situation remains the same as the each and every authority taken no steps. That the State of West Bengal and its subordinates including the Secretary, Department of Urban Development, Secretary Home (Police) Department, Director-General of Police, West Bengal, Secretary, Co-operation Department, the Commissioner of Police, Kolkata Police, Superintendent of Police, 24 Parganas (South), Superintendent of Police, Howrah District, the Officer-In-Charge, Behala Police Station, Kolkata-34, the Officer-In-Charge, New Alipore, Officer-in-Charge, Traffic Squad, Lal Bazar Head Quarter, Kolkata Police, Charge-in-Charge, Golabari Police Station, Howrah, Registrar of Co-operative Societies, West Bengal, The Secretary, West Bengal Co-operative Tribunal, not carried in accordance with the provision fixed under Article 355 of the Constitution, rather they directly and Kolkata Municipal Corporation, Deputy Municipal Commissioner (Buildings) Borrow Committee Chairman, S.S.Unit, being under the control of the State of West Bengal through the Municipal Commissioner, got misused their powers and abused their authority under criminal conspiracy with the Respondent No. 25 and his associates through various means and methods including causing of the help to the blackmailing activities including attempts to murder of the Petitioner and His Son, as were hatched and conducted by the said unscrupulous Businessman turned Mafia Respondent No. 25 and his associates, causing severe infringement of the fundamental rights of the petitioner. Time to time, Shri Har Kishan Singh Surjeet, General Secretary of C.P.I. (M), Shri Som Nath Chatterjee, M.P. and other CPI (M) leaders were also conveyed through due representations posted by Registered Post or delivered against acknowledgements about the facts relates to misuse of the powers and abuse of the authority causing infringement of fundamental rights of the Petitioner, but each and every one maintain silence, as if they are in support of such infringement of the fundamental rights of the Petitioner. Since 1982 Police was protecting criminal acts by criminal means caused by the private Respondents. But since the Petitioner understood that Mafiadom controlled and runs by the Respondent No.25 with the help of his associates including Respondent No. 26 to 32 wanted to grab the properties of the Petitioner and as such he started in 1987 counter actions against illegal activities of the Respondent No. 25, 27 and 29 they with the help, support and protections from Shri Jyoti Basu started a constant, running, regular conspiracy to cause each and every possible damage and injury to the Petitioner. Thereafter, they started to use all means and methods to embrace the Judicial Officers Lawyers of the Petitioner and at the same time use of the Muscle powers were enhanced with the help of the dreaded criminals. Since 1987, orders passed against the Petitioner in any of the litigation and attempt to murder of the Petitioners son were caused under such selfsame conspiracy. Situation was day by day deteriorated against the survival of the Petitioner, as were admitted in the Vohra Committee in its Report. This was result of the Politics-Crime-Bureaucratic-Nexus. In this respect News was published under heading that "I cant break politics-crime nexus, Indrajit". Another news was published that "Todi, Chandan raids stopped". Photocopy of both the news and one Letter dated 12th September 1991 sent by the Petitioner against atrocities suffered by him, by Registered post to Shri Har Kishan Singh Surjeet, General Secretary, CPI(M), Shri Som Nath Chatterjee, M. P., and Shri Biman Bose, West Bengal CPI(M) Leader and aforesaid two News are annexed herewith and marked as ANNEXURE "A-39" Collectively.

98. That when Shri Kishan Lal Bagaria, Solicitors, of Respondent No. 25 moved Contempt Proceeding before Shyamal Sen J. for issuance of the Rule nisi against the Petitioner, Honble High Court directed to serve the copy of the Application upon the Petitioner, through messenger as well as by Post. Shri Kishan Lal Bagaria, Solicitors, make a tricky plan to avoid service, but to cause false service of the copy of the Application upon the Petitioner. For the success of such tricky plan, on 13th September 1991 Shri Kishan Lal Bagaria, Solicitors knowing fully send his clerk at the residence of the Petitioner at noontime when there was no scope of availability of the Petitioner, where said person falsely claimed with the wife of the Petitioner that he is from Income Tax Department to serve a Notice upon the Petitioner. Wife of the Petitioner was not much aware of English, as such she said that it may be better if he note down his name and address on a Paper, so the Petitioner will collect the Notice from him on the next day. Accordingly said person note down his alleged name as "Jagneswar Sinha", and false address as "9th Floor, Bamboo Villa, 168, A. J. Chandra Bose Road, Calcutta-14" the actual address of Income Tax Department. When said person note down his alleged name and address, suddenly it was came in the mind of plaintiffs wife, that why she should not take delivery of the Notice, after showing it to the then Landlord of the Petitioner Shri Abdul Mannan Khan, who is also qualified Advocate. As such wife of the Petitioner 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 respective building, the said person fled from the scene. When in the evening Petitioner come back his residence, he note down such incident at the bottom part of the said Paper. However doubt about some of dubious act of the said person caused in the mind of the Petitioner, when he tried his best level to find out him at the given address of the Income Tax Department, but failed to trace him out. Subsequently when Petitioner wanted to know through his Advocate on Record that how Rule nisi in the Contempt Proceedings was issued without serving the Copy of the Petition, Shri Kishan Lal Bagaria, Solicitors refused to disclose related informations, which causes strong doubts. However, this was become clear that date and time given in the false Affidavit of Service was the same of the time and date of the said person come to the residence of the Petitioner with false claim that he is from Income Tax Department. Said false Affidavit of Service was filed to obtain Rule nisi in the Contempt Proceedings. On 15th April 1992 Petitioner filed application Under Section 340 of Criminal Procedure Code against Respondent No.25 in the Contempt Proceeding, which was recorded as Misc. Case No. 1 of 1992 of Kolkata High Court. Photocopy of the said paper, containing false information about name and address of the clerk of Solicitor of the Respondent No. 25 is annexed herewith and marked as ANNEXURE "A-40".

99. That as per direction of Honble High Court Learned Mr. Kishan Lal Bagaria, Solicitors prepared a Letter dated 13th September 1991 to sent it by Post to Petitioner, but withheld it till when it was posted on 18th September 1991. But, before posting it they obtained Rule nisi by filing false Affidavit of service containing completely false statement that Petitioner refused to receive the copy of the Petition. That during the last two years of

100. That in considerations of the said Defamation Suit when the Petitioner appointed learned Mr. Gouri Shankar Gupta, Advocate to conduct his case, Respondent No. 25 and his Lawyer Shri Kishan Lal Bagaria, Solicitors, started to influence the said Gouri Shankar Gupta, Advocate, to sabotage the Judicial Proceeding against the Petitioner. In considerations of regular sabotage of the judicial proceedings arranged by Respondent No. 25, 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 injunction application in the said Suit, and in the light of 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 Honble Chief Justice of India, against Prabir Kumar Mazumdar and Shyamal Kumar Sen, JJ., as the then their Lordships were. Said application for according sanction, was filed 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 Honble High Court that Shyamal Kumar Sen, J. as he then was, taken affidavits of the both side parties in the Matter No.3028 of 1991, at his residence, the Petitioner by his letter dated 25th June 1992 withdrawn his Application for according sanction, tendering his unconditional apology. Photocopy of the said Withdrawal Letter is annexed herewith and marked as ANNEXURE "A-41".

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