1. That since his childhood Petitioner was and still is a social-minded person and worked for combating the corruption and for improvement of the public system. When he was of about 14 years of age, he with the help of his school friends started a library in his native village. Time to time he made suggestions on the national issues like Language, Hindi, and educations, besides other issues. With his suggestions he made correspondence with several important Persons and in response thereof received several Letters. Out of such few are referred including No. C.P.64 dated February 1964, from Shri J. P. Naik, Advisor to Primary Education, Ministry of Education, Government of India, with reference to his suggestions on Education Letter No. 664-TM/65 dated 4^th February 1964 from Shri Raj Bahadur, Union Minister, informing thereby that his letter have been forwarded to Rajasthan Government, Letter dated 12/01/1965 from Seth Govind Das, M. P., with reference to suggestion on Hindi, Letter No. 61/RJ/65/10690 dated 10/06/1965 from Election Commission of India, Letter No. D3506/67-EM dated 30/05/1967 from Shri Triguna Sen, Union Education Minister, with reference to suggestions on language issue, Letter 04/01/1968 from Shri Prakash Veer, M. P., inviting for discussions on some national issue, Letter No. 4/69(2)/2478 dated 20/01/1968 from Election Commission of India with reference to suggestions to remove corruption from Election System, Letter dated 22/01/1968 from Shri Hansmukh Saha, Personal Secretary, of Shri Morarji Bhai Desai, the then Deputy Prime Minister of India with reference to suggestion on language issue, Letter No. 468/69(1)/15448 dated 11/03/1969, No. 4/69(2)/26961 dated 17/05/1969 and No. 485/68/States/37521 dated 13/08/1969 all three from Election Commission of India with reference to suggestions to remove corruption from Election System. In 1977 Petitioner as first Indian in his individual capacity was invited to record his evidence on a very important National Issue Letter dated 8/9/199 and Letter No. F16/1/MSA/77/3 thereby a Cheque of Rs.474.25 was sent by the Lok Sabha secretariat, for his evidence before Parliamentary Public Undertaking Committee. Letter dated 25/05/1981 from Shri M. S. Swaminathan, Member Planning Commission with reference to Petitioners Note on "Industrial Policy and Aluminium Industry". Petitioner craves leave all such related documents at the time of hearing of the Petition.

2. That some of the facts relates to backgrounds and reasons behind the atrocities suffered by the Petitioner having with intensity under Nexus between the Mafiadom of Respondent No. 25 and his associates including Respondent Nos. 26 to 32 and Shri Jyoti Basu the then Chief Minister of West Bengal are referred under the following paragraphs. For the pecuniary benefit and advantage of the said Mafiadom Shri Jyoti Basu misused his powers and abused his authority to support blackmailing and criminal activities runs by the said Mafiadom with the help of and using the muscle and money powers. Dates referred herein not covering all incidents relates to atrocity suffered by the Petitioner. Petitioner craves leave to submit more comprehensive List of Dates covering maximum dates relates to and with reference to atrocities suffered by Petitioner along with necessary documents at the time of hearing of the Petition, if necessary. The facts referred herein were relied upon by respective documents, Photocopies of some of such documents (without annexing annexures therewith) are annexed herewith and Petitioner craves leave to refer the rest at the time of hearing of the Petition. Some of the Photocopies annexed herewith are reduced up to 84% of the original Documents.

3. In the year of 1932 C. S. Survey was conducted in the then Bengal by the dominion Government of India. As per C. S. survey Records of Rights and related Map published by the dominion Government the measurement of the entire properties comprised (in C. S. Plot No. 307, 308) under C. S. Khatian No.530, and (C. S. Plot No.309, 310, 311 and 311/995) under C.S.Khatian No.534, both Khatian within Mouza Sahapur, P. S. Behala ward No. 119 of the Kolkata Municipal Corporation, Kolkata-700038, were 0.60 acre and 0.50 acre respectively totaling 1.10 Acres equivalent to 66 Cottas (One Cottar = 720 Square Feet). Since the records of the rights are in Bengali script, as such will referred its translation in English at the time of hearing of the Petition, if necessary. The detail of the aforesaid C. S. Khatian Nos. 530 and 534 with respective C. S. Plot Nos. are referred in a Plain sheet and marked as ANNEXURE "A-1"

4. That on 23^rd December 1947 one Balaram Paul claiming him-self as legal heir of Gopal Das, thus owner of the Properties measuring 0.50 Acre equivalent to 30 Cottas, comprised in aforesaid C.S. Khatian No. 534 within aforesaid Mouza Sahapur, under some false representations or otherwise executed one alleged deed in favour of Respondent No. 28. But, subsequently in or about May 1948 Police seized said document in connections with one criminal case from Clerk of Advocate of Balaram Paul. More or less at the same time he entered in Agreement for sale of the same property to one Nalini Mohan Dey. Between 1948 and 1954 several Court cases runs between Balaram Paul, and said Nalini Mohan Dey and in each such case respondent No. 28 was a party.

5. That the husband of the Respondent No. 32 Nalini Mohan Dey purchased Landed properties comprised in entire C. S. Khatian No.530, measuring 0.60 Acre equivalent to 36 Cottas from its the then Owner one Sk. Abdul Rahman, son of Late Manu Sarong through Sale Deed No.3109 of the year 1948, dated 16^th September 1948, executed and registered in Book No. I, Volume No.62 Pages 80 to 82 of Sub-Registrar at Alipore (Kolkata).

6. That from the various record it appear that the Respondent No. 28 is a habitual Cheater and caused frauds upon various people. From two such examples it appears that in one such matter he got registered Sale Agreement, though he was a college student, in respect of a property comprises under C.S.Plot No.366 under C.S.Khatian No.473, situated in the aforesaid Mouza Sahapur, kolkata-700 038, to sell it to a third party on the alleged strength of so-called Sale agreement with the owner of the said land. The owner of the Land, who refutes that he has executed any Sale agreement in favour of Respondent No. 28, filed a Civil Suit. During his deposition, Respondent No. 28 admitted that being a Student 1947-48, he was not in a position to pay the consideration money referred in the Sale Agreement. Learned Court of 1^st Munsif, Alipore, (Kolkata) in his Judgment in respective Title Suit No.193 of 1950 interalia held: "I therefore, come to conclusions that agreement of purchase relied upon by the defendant is only a piece of paper which was never acted upon. It contains false, fraudulent entries in its endorsements relating to receipt of consideration, Chittaranjan never possessed the land in question." Similarly, Respondent No. 28 cheated one Kishori Mohan Bose, who lodged an F.I.R. In the matter Criminal Court of Learned Mr. D. Moitra, 1^st Class Judicial Magistrate, held Respondent No. 28, guilty under Section 406 of the Indian Penal Code and awarded fine of Rs.2,000/- or ID to RI for one year. This fact was published in Newspaper too.

7. That in the year 1948 Balaram Paul, entered in Registered agreement to sale his entire properties lying and situated under C.S.Khatian No.534, measuring 0.50 Acre equivalent to 30 Cottas, to said Nalini Mohan Dey and finally executed registered Sale Deed (Kobala) on 8^th May 1954, vide Sale Deed No.851 for the year of 1954, Book No. I, Volume No.12, page 286 to 297 of Sub-Registrar at Alipore in favour of Nalini Mohan Dey.

8. That on 10^th July 1954 Respondent No. 28 made an application before Sub-Divisional Magistrate to deliver the alleged Deed Seized in 1948 in connections with one Criminal Case to him, as referred under Para-4, claiming himself owner of the Deed. On 18^th January 1955, Shri R.N.Banerjee, Magistrate, 1^st Class, Alipore after holding the enquiry and recording of witnesses, passed following order: "Held an enquiry with the matter. It appears that Shri Shyama Charan Choudhury, Muketeer, took out the exhibits along with the Sale-deed in question on behalf of the complainant and accused in that case but he did not take any receipt from either party to show that he actually made over the document to Jagabandhu Chakravorty or any body else. It also appears from evidence before that the document was seized by Police from the Clerk of Sri Bhupen Bose, Pleader, who was also been examined by me. It is also in evidence of that clerk that Balaram Pal made over that document to him for inspection by Bhupen Babu and it also appears from evidence that it is a benami deed purported to be executed by Balaram Pal in favour of (Respondent No. 28 herein) Chittaranjan Ganguly simply for rectification of his title. It is, therefore, clear that (Respondent No. 28 herein) Chitta Ganguly cannot be real claimant as it was not seized from his custody and also because he seems to be the benamdar of Balaram Pal".

9. That on 7^th February 1955 Respondent No. 28 by his own hand and pen admitted in a letter written in Bengali script to Late Shri Rabindra lal Charaborty that he is not a possession holder of the properties referred in the Deed Executed by Balaram Paul and requested him to support financially so he can acquire the properties. In case if he get the property, he will give large part of the property to him.

10. That in the year of 1956 Government of West Bengal, under Land Acquisition Act, 1953, conducted R. S. Survey. Under said R. S. survey measurement of the entire properties comprised in (R. S. Plot No.194 and 195) under R. S. Khatian No.530, corresponding from aforesaid (C. S. Plot No. 307, 308) under R. S. Khatian No.530, and (R. S. Plot No. 205, 206, 207 and 219) under R. S. Khatian No.534 corresponding from (C. S. Plot No.309, 310, 311 and 311/995) under C. S. Khatian No.534 were arrived more or less same, corroborating with the said C. S. Survey, but in respect of individual Khatian area was changed in respect of R. S. Khatian No. 530 as 0.554 Acre and in respect of R. S. Khatian No. 534 as 0.544 Acre, but grand total of both Khatian was corroborated more or less with 1932 survey and arises as 1.098 Acre says 1.10 Acre equivalent to 66 Cottas. Since the records of the rights are in Bengali script, as such will be referred its translation in English at the time of hearing of the Petition, if necessary. However, the details of the aforesaid C. S. as well as R. S. Khatian Nos. 530 and 534 with respective C. S. as well as corresponding R. S. Plot Nos. are referred in a Plain sheet and marked as ANNEXURE "A-1"

11. That in the year of 1963 Nalini Mohan Dey filed Title Suit No. 301 of 1963 of 4^th Court of Munsif, Alipore (Kolkata) in respect of properties comprised in said R. S. Plot No. 219 within said R. S. Khatian No. 534 against Legal heirs of one Rabindra Lal Chakraborty. Subsequently in the said Suit Respondent No. 28 was added as defendant No 14. In the said Suit Judgment was pronounced on 28^th September 1977 by which decided interalia against the Plaintiff that "Plff. Traces his title from Balaram pal son of Gopal Ch.Pal stating him to be raiyat in respect of land recorded in suit Khatian no.534" and that "C. S. Khatian 534 (ext.3 (a) reveals that Tincouri Sheikh and another were accorded therein as raiyat and Gopal was in possession of the Suit plot No.311 as a licensee.Ext.3 is the R.S.Khatian 534 showing Sheikh Ghulam Mohammed and other as raiyats and R.S.Plot 219 has been shown to be in forcible possession of defendant Ext.15, Information slip prove as that R. S. Plot No.219 is old C. S. Plot 311 of Suit. From their records of right I find that neither Balaram nor Gopal nor Abdul Latif was even shown as Raiyat in respect of suit Khatian or for that matter the suit land, Gopals possession was therefore his possession of a licensee as per the record of rights, the entries in the record of rights have presumption of their correctness. There is no satisfactory documentary evidence to prove that Gopal was even a raiyat in respect of Suit Khatian, except some registered deeds wherein admission by the vendors themselves which cannot prove raiyati right of Gopal, in that event, Plffs case of Abdul Latif staking settlement of tenancy from Gopal Ch. Pal has no leg to stand". (Gopal Chandra Paul was father and predecessor-in-interest of Balaram Paul).

12. That in considerations of the said Judgment and in considerations of harassment caused y the Respondent No. 28 this is needless to mention here that when Ld.Court held that entries in the records of rights have presumption of their correctness, and that neither Balaram nor Gopal nor Abdul Latif was even shown as Raiyat (Owner) in respect of Suit Khatian, the same finding of the Ld.Court have clear implications that Deeds executed by Balaram Pal, in respect of aforesaid suit Khatian i.e. C.S./ R.S.Khatian No.534 as aforesaid (whether it was executed in favour of Respondent No. 28 or in favour of said Nalini Mohan Dey,) "has no leg to stand". However, plaintiff of the Suit Nalini Mohan Dey preferred Title Appeal No.1179 of 1979 of the 11^th Addl.District Judge at Alipore (Kolkata). The Appeal was also dismissed by the Judgment pronounced on 7^th August 1979. The Operating part of the Judgment was as follows: - "So though not agreeing with the findings of the learned Court below I hold that the Judgment and decree passed by it should be affirmed and should not interfered with" and "The Judgment and decree passed by the learned Munsif be hereby affirmed". Therefore, on the basis of the Judgment by trial court entries recorded in the document exhibited i.e. the Records of Rights relate to Suit Khatian No.534, have presumption of their correctness, thus undisputedly and admittedly was binding upon all parties in the suit which was recorded in the following manner:-

R.S.Plot No.205 0.168 Acre recorded against column for owner that it in

,, 206 0.187 ,, ,, ,, ,,

,, 207 0.031 ,, ,, ,, ,,

,, 219 0.158 ,, recorded under column for owner as in

forcible occupation of Rabindra Lal

Chakraborty since 1951.

Since the records of the rights are in Bengali script, as such will be referred its translation in English at the time of hearing of the Petition, if necessary. However, the details of the aforesaid C. S. as well as R. S. Khatian Nos. 530 and 534 with respective C. S. as well as corresponding R. S. Plot Nos. are referred in a Plain sheet and marked as ANNEXURE "A-1"

13. That in the year 1980-1981 Respondent No. 25 has a property at 9/1, Lower Rowdon Street Kolkata-700020 belonged to his mother Smt. Savitri Devi Jhunjhunwala wife of Sri Chandi Prasad Jhunjhunwala. Initially during the period of 1986 when Respondent No. 25 tried to develop good relationship with the petitioner, reported about his past, that his father Sri Chandi Prasad Jhunjhunwala was earning nothing and he was employee in one Rajgarhia Company against monthly salary of Rs.300/- and living along with his father and mother in one Room belongs to his uncle. However, his mothers said property was under Litigation. Respondent No. 25 for the purpose of his employers, regularly going to Kedar Nath Fatehpuria, who then was the employee in one Company of Sahu Jain Group. During such visits Respondent No. 25 discussed with Kedar Nath Fatehpuria, about his said property, and Mr. Fatehpuria suggested for settlement in the matter with his opposite party by making lumps sum payment. Respondent No. 25 had no monetary sources, while Fatehpuria was. After negotiations Respondent No. 25 make payment of black money of Rs.22 Lakhs to said Tenant to get vacated said Land under settlement. Thereafter, under agreement between Respondent No. 25 and Kedar Nath Fatehpuria a Joint Venture multistoried complex of three buildings called as Block "A" Block "B" and Block "C" of "Mani Mansions" were constructed as the first project for both of them. Thereafter Respondent No. 25 married with the sister of Kedar Nath Fatehpuria. Such relationship and subsequent business relationship will appear from one page of Balance Sheet of M/S. Martin Burn Limited for the year ended 31^st March 1989 and one Advertisement published on 16-18^th June 1989 in the Telegraph with reference to death of Shri Sham Sunder Fatehpuria, photocopies of both are annexed herewith and marked as ANNEXURE-"A-2" Collectively.

14. That in the year of 1981-82 Respondent No. 32 and her daughter as legal heirs of Nalini Mohan Dey since deceased claimed before Petitioner in writing through their Lawyer Learned Mr. Swapan Kumar Chakraborty, Advocate, that they are owner of 70 Cottas of the land, out of which one litigation is pending in respect of the properties measuring 3 Cottas 13 Chittaks 26 Square Feet. Relying upon such claims initially on 9^th December 1981 and finally on 5^th February 1982 Petitioner entered in the Agreement with the Respondent No. 32 and her daughter to purchase the aforesaid properties comprised in C. S. / R. S. Khatian Nos. 530 and 534 as aforesaid. Before entering in the agreement correspondence between the then Lawyer of Petitioner Ld. Mr. Aloke Nath Ghosh, Advocate and Lawyer of the Respondent No. 32 and her daughter Ld. Mr. Swapan Kumar Chakraborty were held.

15. That subsequently, it was transpired that according to the aforesaid Two Deeds in favour of said Nalini Mohan Dey, including one executed by said Balaram Paul, and on the basis of the C. S. Survey as well as R. S. Survey total area of the properties comprised in Two Khatian No. 530 and 534 was just 1.10 Acre equivalent or 66 Cottas, out of which Respondent No. 32 and her daughter lost their claims over the properties comprised at R.S.Plot No.219 measuring more or less 10 Cottas. Therefore, Respondent No. 32 and her daughter were owners of more or less 56 cottas of land, against their false claim of 70 cottas of land. Between 31^st May 1983 and 28^th June 1983, out of 56 Cottas land Respondent No. 32 and her daughter executed Registered Sale Deeds in respect of 35 cottas of land in favour of nominees of the petitioner, but failed to execute Sale deed in respect of properties comprised in R. S. Plot No. 195 and 206 measuring more or less 21 cottas, for non-compliance of some mandatory legal provisions. However Respondent No. 32 and her daughter delivered physical possession of the aforesaid two plots along with other parts of the property on 5^th February 1982 to Petitioner. They received full consideration money from the Petitioner, in respect of the entire properties measured 56 cottas of land. Petitioner admit that his the then Lawyer Aloke Nath Ghosh, Advocate, not given proper advices with some malafide intention, which Petitioner released in June 1983, as such said Aloke Nath Ghosh, Advocate was released by the Petitioner.