16. That at the time of the purchase of the aforesaid property, in or about March 1982, Petitioner booked some flats of his friends and relations including Respondent No. 30 on certain terms and conditions to provide them residential accommodations after construction.

17. That at the time of purchase of the aforesaid properties there were 44 inhabitant families / Tenants, including the Respondent No. 31 under pendent Ejectment Suits. Since the Petitioner is a social-minded person since his childhood, immediately after purchase of properties, offered rehabilitation proposals to tenants under pendent Ejectment Suits. Knowing about such proposal, the Respondent No. 29 in the garb of leader of the tenants entered in the matter, to exploit personal benefits from behind the scene. As a result, under his abetments and instigations tenants started criminal blackmailing against Petitioner. Considering constant and regular such blackmailing activities, Petitioner sent Letter dated 29^th December 1982 by Registered Post to the Respondent No. 17 and Leaders of the tenants, informing thereby, his intention to offer rehabilitation to the then 43 tenants.

18. That on 9^th January 1983 in a joint meeting attended by Leaders of the Tenants including Respondent No. 29, Petitioner and representatives of the Tenants, held at Ajanta Cinema, proposal of Petitioner was appreciated and accepted by the Tenants and their Leaders except Respondent No. 29. But, subsequently, under ill advice from the Respondent No. 29 tenants including the Respondent No. 31 started to create more and more pressures upon Petitioner for payment of money.

19. That under ill-advise from his the then Lawyer Mr. Aloke Nath Ghosh, Advocate, Petitioner formed and in February 1983 get registered a Cooperative Society namely Nav-Surya Cooperative Housing Society and made all persons, who booked flats with Petitioner as promoters / members of the said Society, though the property was absolutely purchased by the Petitioner through his own nominees. On 4^th March 1983 Respondent No. 30 and his associate Mr. Prabhu Dayal Sureka attended Managing Committee meeting of the Cooperative Society as its members. Thereafter, they were never bothered about the Cooperative matters and affairs, till 18^th July 1986 attempt to kill the Petitioner not taken place under a Plot hatched by the Respondent No. 25 and his associates.

20. That under ill-advise from Ld. Mr. Aloke Nath Ghosh, Advocate, after registration of said Cooperative Society, between 25^th March 1983 and 31^st May 1983 under fiduciary relationship between the promoters of Nav-surya Cooperative Housing Society and the Petitioner, the Properties comprised in R.S. Plot No. 194, 205 and 207 as aforesaid was transferred in favour of the Cooperative Society just as name lenders without any payment of consideration money.
21. That on 4^th June 1983 Learned Munsif, Alipore 5^th Court, Mr. Jayanta Das Gupta passed an order in 36 Ejectment Suits (in the nature of analogous hearing) pending against Tenants including Respondent No. 31. But, under embracement from Ld. Mr. Timir Baran Banerjee, Advocate and his junior Ld. Mr. Kalyan Kumar Ghosh and under connivance with Ld. Mr. Aloke Nath Ghosh, Advocate, subsequently said order was not recorded, but when Petitioner taken steps against such anomaly, than even wrongly recorded orders were removed or changed. Such development was happened as thee Respondent No. 29, under malafide intentions, misused his contacts with said Mr. Timir Banerjee, Advocate of Alipore Court (Kolkata) to embrace the then Presiding Officer of the Learned Munsif, Alipore 5^th Court, Mr. Jayanta Das Gupta to cause severe damages in the Court proceedings of the Ejectment Suits pending against the aforesaid tenants. As such between 8^th June 1983 and 27^th July 1983 Mr. Jayanta Das Gupta misusing his position as Learned Munsif, Alipore 5^th Court, caused severe interpolations in order sheets of several suits. From the Certified Copy of two orders both No. 10 and both passed in Title Suit No. 265 it will appear that order passed on 04^th June 1983 was removed subsequently. Both Certified Copies were filed before Kolkata High Court with the Revision Petition. Photocopies of such Certified Copies are annexed herewith and marked as ANNEXURE "A-3" Collectively.

22. That after knew about such interpolation, between 13^th July 1983 and 26^th July 1983 Petitioner filed 19 Application under section 340 of Criminal Procedure Code, in respect of the Title Suit No. 266, 220, 226, 229, 249, 222, 258, 257, 227, 270, 265, 267, 277, 253, 268, 275, 252, 256 and 254 all of 1982 before the said Court of Munsif itself. Initially Mr. Jayanta Das Gupta, the then Learned Munsif, Alipore 5^th Court, withheld such applications, but, on 27.7.1983, applications were recorded as Misc.Case No.77 to 95 all of 1983. In September 1983 Petitioner filed 31 Revision Applications and placed detail facts of interpolations in Order Sheets before Honble Kolkata High Court.
23. That in consideration of his experiences, in the year of 1983 Petitioner developed a Model for a New Civil Procedure Code to ensure adjudication of any Civil Litigation maximum within 2 years. He sends said Model to the then Law Minister Shri Asok Sen, by Registered Post.
24. That on 16^th September 1983 aforesaid Tenants including the Respondent No. 31 filed Title Suit No.108 of 1983 before the Learned Court of 7^th Sub-Judge Alipore, against Petitioner and his Cooperative Society and obtained ex-parte Ad-interim Injunction Order. After knew about Injunction Order, Petitioner appeared in the Suit and admitted before the Ld. Court that he has no intentions to remove any Tenants without due process of Law. Thereafter on 4^th October 1993 Ad-interim Injunction Order was modified, but which was no way helpful for the blackmailing objects of the Tenants including Respondent 31 and Respondent No. 29.

25. That on 22^nd September 1983 tenants accepted another rehabilitation proposal, but once again under abetment from Respondent No. 29 not materialised. In between constant blackmailing activities were going on against the Petitioner, without any rest. After several negotiations and modification in the rehabilitation proposal each given by the Petitioner, an agreement was held on 10^th October 1983 that compromise Petitions for the Ejectment Suits would be approved by Shri Som Nath Chatterjee, M. P.

26. A Joint Meeting of the representatives of the Tenants including the Respondent No. 31, Local CPI (M) Leader (which with malafide intention was not attended by Respondent No. 29) and the Petitioner at the residence of Shri Som Nath Chatterjee, M.P., were held on 20.10.1983 in which one Learned Mr. Pranab Chatterjee, Solicitor was also present under instructions from Shri Som Nath Chatterjee, M.P. After discussions and acceptance of proposal of rehabilitation offered by the Petitioner, Shri Som Nath Chatterjee, M.P. instructed to Learned Mr. Pranab Chatterjee, Solicitor to check the Compromise Petitions prepared by the Petitioner and make necessary amendments in accordance with the discussions held in the meeting. Accordingly Learned Mr. Pranab Chatterjee, Solicitor by his own hand and pen, checked and corrected the draft of Compromise Petitions prepared by the Petitioner and delivered it back to the Petitioner. But once again under abetment and instigation from Respondent No. 29 compromise was not materialised.

27. That in one of the Affidavit Respondent No. 25 admitted that he purchased properties at Binoba Bhave Road, Ward No. 119 of Kolkata in November 1983, neighboring to the properties of the Petitioner.

28. That after knew about Revision Petitions filed by the Petitioner a plot was hatched under connivance between Ld. Mr. Timir Baran Banerjee, Advocate, his Junior Ld. Mr. Kalyan Kumar Ghosh, Advocate and the then Presiding Officer of the 5^th Court of Munsif, Alipore Ld. Mr. Jayanta Kumar Dasgupta and accordingly on 25^th November 1983, petitioner was lifted by force with the help of Court staff, from the Court compound in presence of about 500 litigants, Advocates and others. Under grace of the God when Petitioner was lifted by force, one senior reporter of the Telegraph was also present there who collected requisite informations and published the true story within a Box News item in the Telegraphs issue dated 29^th November 1983. After released on bail, from the said Criminal Case Petitioner wrote letters dated 14^th December 1983 to Chief Justice of India and other judicial authorities, than the Honble High Court at Kolkata enquired the matter. On 23^rd December 1983 Petitioner filed an application for according sanction to prosecute Shri Jayanta Kumar Dasgupta. The matter was also published in detail in renowned Bengali Newspaper: Ananda Bazaar Patrika dated 4^th January 1984. Photocopy of the News published on 29^th November 1983 is annexed herewith and marked as ANNEXURE "A-4. Since news published on 27^th November 1983, and 4^th January 1984 are in Bengali script, as such Petitioner craves leave to refer at the time of hearing of the Petition alongwith English Translation, if necessary.

29. That on 28^th December 1983 tenants with active participation of Respondent No. 31, and help of one anti-social Gopal Das stolen Generator set and Type Writer of the Petitioner from the site office and sold it at two different places. Police caught the purchaser of the Generator-Set, but under political influence subsequently taken no actions against criminals.

30. That on 17^th February 1984 Ld. Mr. Srikanta Bhattacharyya, Advocate, manipulated the impact of Order No. 10 dated 4.10.1983 passed in Title Suit No. 108 of 1983 of Ld. Court of 7^th Assistant District judge, Alipore, by issuing a Certificate under heading "TO WHOM IT MAY CONCER". After knowing the same Petitioner served Lawyers Notice dated 27^th February 1984 upon Ld. Mr. Srikanta Bhattacharyya, Advocate. After few correspondences, he left from the said Suit. However, Petitioner constructed boundary wall surrounding entire properties because of the aforesaid orders passed in the Said Title Suit. When tricks failed to restrain the construction of boundrywall by the Petitioner, on 29^th February 1984 tenants filed a Petition Under Section 144(2) of Cr. P. C. against Petitioner and hurled brickbats and Bombs upon the Labours of Petitioner. Photocopies of the said Certificate dated 17^th February 1984 and Lawyers Notice dated 27^th February 1984 are annexed herewith and marked as ANNEXURE "A-5" Collectively.

31. That on or about 2^nd March 1984, some of the Tenants including Respondent No. 31 and one anti-social Gopal Das were busy in manufacturing of the Bombs to kill the Petitioner. During the manufacturing process, Cigarette ash fallen on accumulated materials for manufacturing of the Bomb, and serious blast was taken place in which said anti-social Gopal Das and one Tenants were burnt seriously. A false story was created. Said Gopal Das was Bengali by birth while one lady Tenant by birth Oriya, but under abetment from Respondent No. 29 lodged a false First Information Report that some agents of the Petitioner thrown Acid Bomb upon the said Gopal Pal, claiming him as her own brother. Thereafter, Respondent No. 29, meets with Shri Snehangshu Acharya, the then Advocate-General of West Bengal, representing self-same false story. Resultantly, Shri Snehangshu Acharya telephoned to Director General of West Bengal Police to arrange arrest of the Petitioner. As such the then Superintendent of Police 24-Parganas Mr. K. K. Kalia, I.P.S., and the then area Deputy Superintendent of Police Shri Md. Nizam rushed to Behala Police Station and armed Police were deployed at the property of the Petitioner. That one honest C P I (M) Leader was present at Behala Police Station, when Senior Police Officers reached at the Police Station and discussed whole matter in his presence, as such he informed through some one to the Petitioner that Police is coming to arrest him. During the discussions, some doubts in the mind of Mr. K. K. Kalia were cropped up about the said false story, as such he instructed Shri Md. Nizam to go and see the burnt persons. After coming back said Police Officer reported that the burning of the both victims are not from the Acid Bomb, rather map of the burning is ample clear that they were engaged in manufacturing of the Bomb, when fire was caught. As a result, Superintendent of Police 24-Parganas Mr. K. K. Kalia, I.P.S. instructed to local Police Officers not to arrest the Petitioner. Since Petitioner was not aware about such subsequent developments, as such when on 5^th March 1984 Lawyer moved anti-cipatory bail application on behalf of the Petitioner, the then Presiding Judicial Officer of the Court of District Civil & Sessions Judge says in open Court that he was Telephoned by Shri Snehangshu Acharya, the then Advocate-General of West Bengal, not to grant anti-cipatory bail to the Petitioner. Ld. Judge further commented that during his enquiry with regards to the matter relates to said Mr. Jayanta Kumar Dasgupta, he find a different face of the Petitioner, but by this matter as referred by Shri Snehangshu Acharya, he was socked that the Petitioner might be a criminal. However, in spite of all such remarks, Honble District Judge granted temporary anti-cipatory bail for the Petitioner and directed the Police to present case Diary of the matter. When case Diary was presented before the District Judge, Police said that No case is pending against the Petitioner in the respective matter. After knew about Telephone from Advocate General to District Judge, on 7^th March 1984 Petitioner send his strong worded protest Letter by Registered Post to Respondent No. 29 with copies to District Judge, Alipore, Advocate-General of West Bengal Shri Snehangshu Acharya, Advocate General of Tripura Shri Dipak Kundu (who then were knows personally to Petitioner) Police Authorities and District Secretary C.P.I.(M). After receipt of the said Letter Shri Acharya directed Intelligence Branch, West Bengal Police to enquire the whole matter, which was done. Photocopy of the Orders Passed by District Civil and Sessions Judge Alipore on Petitioners Application for anticipatory-bail and Police report and said Letter dated 7^th March 1984 are annexed herewith and marked as ANNEXURE-"A-6" collectively.

32. That on 10^th April 1984, Petitioner filed one Writ Petition being No. C.O. 4044(W) of 1984 for Police help before the Honble Court of B. C. Basak, J as then was of the Calcutta High Court, and after hearing of the same appropriate order was passed. But, within few days, without filing any written Affidavit or petition, learned Mr. Dipankar Gupta, Bar-at-law, appeared in the matter on behalf of the Respondents therein including Respondent No. 31 and made sentimental pleadings before Honble Court that he is appearing on behalf of his poor driver, (according to him the Petitioner was intended to remove his driver, which was totally false and baseless) without taking any fees, as such under impact of such sentimental verbal pleadings Honble Court stayed its said earlier Order dated 10^th April 1984.

33. That in the mean time the Tenants including Respondent No. 31 with malafide object to paint the Petitioner as a dreaded Criminal distributed one Phumplate. In the said Phumplate alleged letter from Mr. Som Nath Chatterjee M.P. was referred quoting that "I had never myself recommended any settlement or finalized any draft for settlement of the case". After going through the said Phumplate Petitioner sent photocopy of the copy of the Compromise Petition draft, corrected by Ld. Mr. Pranab Chatterjee, Solicitor, through his Letter Dated 7^th May 1984 by Regd. Post, to Shri Som Nath Chatterjee, M.P. Reportedly thereafter, letter earlier written by Shri Som Nath Chatterjee, M.P. was withdrawn from the locality. Photocopy of said Letter Dated 7^th May 1984 is annexed herewith and marked as ANNEXURE-"A-7" collectively. Phumplate is in Bengali script, as such will be referred at the time of hearing of the Petition alongwith English translation.

34. That in the said Writ Petition being No. C.O. 4044(W) of 1984 subsequently, Respondents including Respondent No. 31 filed their Affidavit-in-opposition, based on total false statements. On 9^th May 1984, the Honble Court, without considering the matter on merit, withdrawn said earlier order dated 10^th April 1984. On 2^nd August 1984 Petitioner sends protest letter to Ld. Mr. Dipankar Gupta, Bar-at-Law, against his sentimental pleadings before Honble High Court. Photocopies of both the Orders dated 10^th October 1984 and 9^th May 1984 and letter dated 2^nd August 1984 are annexed herewith and marked as ANNEXURE "A-8" collectively.

35. That said Gopal Das was released from the Hospital, and he needed subsequent treatment with valuable Ointments, as such he met with the Tenants, including Respondent No. 31. Since his use was no longer required by the Tenants as such they thrown him out. Thereafter, under advice from some one, said Gopal Das met with the Petitioner for medical help on humanitarian grounds. Considering his activities and backgrounds, Petitioner taken him in the Police Station, where the concerned Police Officer ask him to reveal the real story behind his burning, then he revealed real story related to his engagement along with Tenants including Respondent No. 31 in manufacturing of the Bombs. Thereafter, Petitioner ask said Gopal Das, that without any pressure first of all he must put the matter on record, then only Petitioner can help him. Gopal Das placed entire story on paper in Bengali script through the hand and pen of his wife, which was translated in English and placed before One Executive Magistrate, 24-Parganasd as an Affidavit. In consideration of the serious nature of material, said affidavit was rejected, but numbered as document No. 5887 dated 14.5.1984. After going by the aforesaid handwritten noting and said rejected Affidavit concerned Police Officer advised the said Gopal Das, that if he can show courage to admit the truth, he will be forwarded before the Judicial Magistrate, for his confessional statement, but same can cause problem for him, because he may be punished for his involvement in manufacturing of the Bombs. Gopal Das was ready to confess the real story, as such Police arrested him and send before Judicial Magistrate, where he revealed entire story in real verbatim in which he further revealed the story related to theft of Generator Set and Type Writer of the Petitioner on 28^th December 1982. On the basis such confession Kolkata Police recovered Generator-Set, but Behala Police taken no further actions in the matter with clear object to protect the accused persons in the aforesaid matters, particularly Respondent No. 31. Photocopy of said rejected Affidavit is annexed herewith and marked as ANNEXURE-"A-9.

36. That after enquiry Petitioner was discharged on 30^th August 1984 from the said false Criminal Case lodged at the behest of Mr. Jayanta Kumar Dasgupta, on 25^th November 1983 after lifting by force to the Petitioner, while reportedly on 6^th September 1984 Honble Kolkata High Court dismissed Mr. Jayanta Kumar Dasgupta, from Judicial Service, as first such case in Indian Judicial history.

37. That between 19^th September 1984 and 14^th January 1985 Tenants filed three Applications under section 144(2) of Criminal Procedure Code with false representations, and when in each one Petitioner filed Application Under section 144(5) of the Criminal Procedure Code, the Petitioners of such cases become absentee of respective matters and each one was filed Under section 144(5) of the Criminal Procedure Code.

38. That on 18^th December 1984, Petitioner sends a circular Letter to all person who booked the Flats with the Petitioner, including Respondent No. 30 to make payment of Rs.5/- per square feet against their respective booking areas to meet pre-construction expenditures. But, in response of the said Letter Respondent No. 30 and his group verbally refused to make any payment in considerations of troubles prevailed in the property. Photocopy of letter sent to and received by Respondent No. 30 is annexed herewith and marked as ANNEXURE-"A-10".

39. That on 23^rd January 1985 Petitioner received a written message from Deputy Superintendent of Police of the Jadavpur to meet him immediately. When on 30^th January 1985 Petitioner met with Shri Md. Nizam, the then Deputy Superintendent of Police, he understood that Md. Nizam was aware about the Petitioner since he enquired the matter of injury of said Gopal Das and one tenants caused by manufacturing of the Bombs, as such he shaw the Petitioner one written order issued by Shri Jyoti Basu, upon District Magistrate 24-Parganas to remove the Petitioner from his absolute properties on false claim that properties is belonged to Respondent No. 28. After going through the said order Mrs. Ranu Ghosh, I.A.S., forwarded it to Shri Md. Nizam, the then Deputy Superintendent of Police of the respective area, with instructions to comply the order of the Chief Minister. After going through the aforesaid Order from Shri Jyoti Basu and instructions from District Magistrate Petitioner offered Mr. Md. Nizam to hand over the keys of the properties against the appropriate receipt, but, Mr. Md. Nizam replied that he dont want to do any thing illegal, if Petitioner have to say anything he will be allowed to say. Thereafter, Petitioner submitted his letter dated 1^st February 1985 to Shri Md. Nizam, with copies to Shri Jyoti Basu and Mrs. Ranu Ghosh, against misuse of the Powers under false representations.

40. That during the same period Respondent No. 27 on behalf of the Respondent No. 25 decided to encroach the properties of the Petitioner. After knew about his such intentions Petitioner send Lawyers Notice dated 13^th February 1985 by Registered Post to Respondent No. 27 against his such intentions. After receipt of the Lawyers Notice Respondent No.27 under connivance with Police changed his strategy and lodged one false Criminal Case No. 54(2)85 dated 19^th February 1985 that Milap Chand Choraria (the Petitioner herein) demanded Rs.20,000/- from him. The object of such false case was to get arrested the Petitioner, when he comes to restrain Respondent No.27 from encroaching the property.