Writ Petition Criminal Diary Number 18546 of 2022 Part-I .pdf

1
IN THE SUPREME COURT OF INDIA
CRIMINAL ORIGINAL JURISDICTION
WRIT PETITION (CRIMINAL) D.NO.18546 OF 2022
Petition under Article 32 of the Constitution of India with
A Prayer to STOP persistent gang rapes, rescue &
rehabilitate the victims of illicit sex trade, hidden
prostitution, child prostitution and Enforcement of
Fundamental Rights.
IN THE MATTER OF:
OM PRAKASH …………..PETITIONER
VERSUS
UNION OF INDIA & ORS ….RESPONDENT
CRL. M.P. NO. OF 2022
APPLICATION FOR SEEKING PERMISSION TO APPEAR
AND ARGUE AS PETITIONER-IN-PERSON
APPLICATION FOR SEEKING EXEMPTION FROM FILING
ATTESTED COPY OF AFFIDAVIT
APPLICATION FOR EARLY HEARING/URGENT
HEARING
PAPER BOOK
(FOR INDEX KINDLY SEE INSIDE)
VOLUM/PART-01
PETITIONER IN PERSON
OM PRAKASH

2
INDEX
S.N Particulars of the document Page No. of the
part to which it
belongs
Remarks
(i) (ii) (iii) (iv) (v)
1. Court Fees
2. Listing Proforma A A1
3. Cover Page of Paper Book A-2
4. Index of Record of Proceedings A-3
5. Defect List A-4
6. Note Sheet NS1-
7. List of Dates B-M
8. Writ Petition (Criminal) with
Affidavit
1-59
9. Annexure: P-1
True copy of order dated 09th
February, 2011 by Principle Judge,
Family Court, Dwarka Court at
New Delhi in HMA-700/2010 case
60
10. Annexure: P-2
True copy of photographs of minor
daughter Shriya Poddar dated 09th
February, 2011 at children’s room
at Family Court, Dwarka Court at
New Delhi in HMA-700/2010 case
61
11. Annexure: P-3
True copy of signed copy of police
complaint against sex abusers state
through email letter dated 07th
May
2022 by petitioner to all nodal
police officers of Bihar and NCT of
Delhi
62-63
12. Annexure: P-4
May
Delhi
64-64
13. Annexure: P-5
May
65-66

3
Delhi
14. Annexure: P-6
May
Delhi
67
15. Annexure: P-7
May
Delhi
68
16. Annexure: P-8
May
Delhi
69
17. Annexure: P-9
May
Delhi
70
18. Annexure: P-10
May
Delhi
71
19. Annexure: P-11
May
72-74

4
Delhi
20. Annexure: P-12
May
Delhi
75-76
21. Annexure: P-13
May
Delhi
77-78
22. Annexure: P-14
May
Delhi
79-81
23. Annexure: P-15
May
Delhi
82-83
24. Annexure: P-16
through email letter dated 22nd
May 2022 by petitioner to all nodal
Delhi
84-85
25. Annexure: P-17
May
Delhi
86-87
26. Annexure: P-18 88-89

5
May
Delhi
27. Annexure: P-19
May
Delhi
90-91
28. Annexure: P-20
May
Delhi
92-93
29. Annexure: P-21
May
Delhi
94-95
30. Annexure: P-22
through email letter dated 31st
May
Delhi
96-97
31. Annexure: P-23
through email letter dated 1st
June,
Delhi
98-99
32. Annexure: P-24
100-
101

6
through email letter dated 2nd
June,
Delhi
33. Annexure: P-25
through email letter dated 3rd
June,
Delhi
102-
103
34. Application for seeking
permission to appear and argue the
Writ Petition (Criminal) in person
along with supporting affidavit.
104-
108
35. Application for seeking exemption
from filing attested copy of
Affidavit along with supporting
affidavit.
109-
113
36. Application for early hearing along
with supporting affidavit.
114-
119
37. Filing Index
38. Memo of Appearance
39. I.D.Proof

7
‘A’
No. F.5/Judl(I)/2018, dated: 29/10/2018
w.e.f. 29th October, 20183
ANNEXURE_ ‘X’
PROFORMA FOR FIRST LISTING
SECTION ____
The case pertains to (Please tick/check the correct box}:
√Central Act: (Title) INDIAN PENAL CODE
√Section: 154(1) and 157(1) Criminal
Procedure Code
Central Rule: (Title) N.A
Rule No(s} N.A
State Act: (Title) N.A
Section: N.A
State Rule: (Title) N.A
Rule No(s) N.A
Impugned Interim Order: (Date) N.A
Impugned Final Order/Decree: (Date) N.A
High Court: (Name) N.A
Names of Judges: N.A
Tribunal/Authority: (Name} N.A
1. Nature of matter: Civil √  Criminal
2. (a) Petitioner No. l : OM PRAKASH
(b) e-mail ID: om.poddar@gmail.com
(c) Mobile phone number: 9540389759
3. (a) Respondent No. l : UNION OF INDIA MINISTRY OF HOME
AFFAIRS
(b) e-mail ID: N.A
(c) Mobile phone number: N.A
4. (a) Main category classification: 1418 CRIMINAL MATTER-OTHERS
(b) Sub classification: N.A
5. Not to be listed before: PREVIOUSLY LISTED BENCH NOT TO BE
LISTED
6. (a) Similar disposed of matter with citation, if any, & case details:
(i) Petition(s) for Special Leave to Appeal (Civil) No(s).9854/2012
entitled OM PRAKASH PODDAR VERSUS RINA KUMARI
dated 23.04.2012
(ii) Petition(s) for Special Leave to Appeal (Civil) No(s).9483/2013
dated 01.04.2013
(iii) Petition(s) for Special Leave to Appeal (Civil) No(s).19073/2013
dated 05.07.2013

8
(iv) Writ Petition(s)(Civil) No(s).90/2016 entitled OM PRAKASH
VERSUS INDIAN DRUGS AND PHARMACEUTICALS LTD
AND ORS dated 18.04.2016
(v) Writ Petition(s)(Criminal) No(s). 136/2016 entitled OM
PRAKASH & ANR VERSUS STATE OF BIHAR AND ORS
dated 21.10.2016
(vi) REVIEW PETITION (CRL.) NO. 825 OF 2016 IN WRIT
PETITION (CRL.) NO. 136 OF 2016 entitled OM PRAKASH &
ANR VERSUS STATE OF BIHAR AND ORS dated 01.12.2016
(vii) WRIT PETITION (CRL.) D.NO. 2188 of 2017 entitled OM
PRAKASH & ANR VERSUS UNION OF INDIA & ORS dated
28.01.2017
‘A1’
(viii) WRIT PETITION (CRL.) D.NO. 3913 of 2017 entitled OM
PRAKASH & ANR VERSUS REGISTRAR SUPREME COURT
OF INDIA AND ANR dated 16.02.2017
(ix) M.A. No(s). 84/2017 in WRIT PETITION(CRL.) D. NO.3913 OF
2017 entitled OM PRAKASH & ANR VERSUS REGISTRAR
SUPREME COURT OF INDIA AND ANR dated 14.07.2017
(x) CURATIVE PET(CRL.) D 41026 OF 2016 IN REVIEW
PETITION (CRL.) NO. 825 OF 2016 IN WRIT PETITION (CRL.)
NO. 136 OF 2016 entitled OM PRAKASH & ANR VERSUS
STATE OF BIHAR AND ORS dated 17.07.2017
(xi) Misc. Application D.NO. 22539 of 2018 in WRIT
PETITION(CRL.)D.NO. 2188 of 2017 entitled OM PRAKASH &
ANR VERSUS UNION OF INDIA & ORS dated 23.08.2018
(xii) M.A. NO. 2836 OF 2018 IN MISC. APPLN. D.NO. 22539 OF
2018 IN WRIT PETITION (CRL.) D.NO. 2188 OF 2017 entitled
OM PRAKASH & ANR VERSUS UNION OF INDIA & ORS
dated 07.12.2018
(xiii) Misc. Application D. No.42652/2019 in WRIT PETITION(CRL.)
No. 136/2016 entitled OM PRAKASH & ANR VERSUS STATE
OF BIHAR AND ORS dated 14.07.2020
(xiv) Miscellaneous Application No.1446/2020 in M.A.D
No.42652/2019 IN WRIT PETITION (CRL.) No. 136/2016
entitled OM PRAKASH & ANR VERSUS STATE OF BIHAR
AND ORS dated 14.09.2020
(xv) W.P.(Criminal)242/2021 entitled OM PRAKASH VS UNION OF
INDIA & ORS
(xvi) W.P.(Criminal)137/2021 entitled OM PRAKASH VS UNION OF
INDIA & ORS
(b) Similar pending matter with case details: NO
7. Criminal Matters:
(a) Whether accused/convict has su1rendered:  Yes √ No.
(b) FIR No. N.A Date: N.A
(c) Police Station: N.A
(d) Sentence Awarded: N.A

9
(e) Period of sentence undergone including period of detention/ custody
undergone:
N.A
8. Land Acquisition Matters:
(a) Date of Section 4 notification: N.A
(b) Date of Section 6 notification: N.A
(c) Da te of Section 17 notification: N.A
9. Tax Matters: State the tax effect: N.A
10. Special Category (first petitioner/appellant only): N.A
 Senior Citizen>65 years  SC/ST  woman/child  Disabled  Legal aid
case  in custody
11. Vehicle Number (in case of Motor Accident Claim matters): N.A
Petitioner-in-Person
(Name) OM PRAKASH
Registration No………………
Date: 07-06-2022

10
SYNOPSIS AND LIST OF DATES
The present Writ Petition under Article 32 of the
Constitution of India is being filed by a Social
Worker cum Petitioner-In-Person cum Whistle
Blower cum husband cum Father cum Guardian of
rescued victims of Gang Rapes, flesh trade, hidden
prostitution, illicit sex trade, child sexual abuse and
international human trafficking rescued with an
active help of this Hon’ble Court in Writ Petition
(Criminal) 242 of 2021 and Writ Petition (Criminal)
137 of 2021 (victims rescued from the brothels of
Varanasi, G.B. Road Delhi and Shastri Park North
East Delhi boarded at Delhi in Mahananda Express
Train on 05-05-2022 along with petitioner’s PNR
No.260-2313501 and de-boarded at katihar railway
station on 06-05-2022 along with near about 50
family members of petitioner and their minor
children including his own wife, minor daughter.
Sisters, sister-in-law and their minor children) but
unfortunately not being placed before court of law,
not being initiated rehabilitation process either
within state’s institutions like women shelter house,
children’s observation homes or within family or not
being initiated handing over procss to the petitioner
either by Magistrate Katihar or by Delhi Rail Police
or by Katihar Rail Police or by the Child Line
Kolkotta, Dhanbad, Patna, Samastipur, Begusarai,
Purnea, Katihar etc and being re-pushed into the
same business of flesh trade at the source point of
human trafficking at Sonaili village, district Katihar

11
Bihar; aggrieved by this delinquent behavior,
arbitrary action of the state, rampant unlawful
detention of petitioner by Delhi and Bihar Police for
blowing whistle against the persistent Gang Rapes
and illicit sex trade of rescued victims w.e.f
06.05.2022 to till date by the nexus of State, NGOs,
Gangsters, Mafias and Indian Defense organizations
in front of his own house at Asha Deep Niwas,
Sonaili, P.S. Kadwa, Katihar, Bihar and in front of
his own eyes and for the enforcement of the Rights
under Article 21 of the Constitution of India.
02.05.2022 Order passed by the bench of Hon’ble Sanjay
Kishan Kaul in W.P.(Crl) 137/2021 by this
Hon’ble Court, victims of illicit sex trade and
child sexual abuse being rescued trafficked to
Katihar Bihar but not handed over to the
petitioner but being taken into the custody of
sex abusers cum pimps accompanying lady
magistrate of katihar. She re-pushed the victims
into the same business of flesh trade at the
source point of human trafficking at sonaili
village at katihar Bihar and organized gang
rapes of the victims persistently from
06.05.2022 to till date at various locations for
generating revenue out of it. More than 50
female members, their children including
petitioner’s minor daughter and his wife are in
the list of victims.

12
06.05.2022 Victims of gang rapes and illicit sex trade
(Petitioner’s near about 50 family members and
their children) are being rescued from the
different brothels of India like Shastri Park,
North East Delhi, G.B.Road Delhi, Varanasi,
Gulabbag Purnea, Sonagachhi Kolkatta and
departed by Mahananda Express on 05.05.2022
from Old Delhi Railway Station to Katihar on
06.05.2022. But rescued victims not being
handed over to the petitioner either by Delhi
Rail Police or by Katihar Rail Police till date
instead organizing the events of gang rapes and
illicit sex trade every day and night at the
source point of human trafficking at Sonaili
Village P.S. Kadwa, at Katihar Bihar since then.
11.05.2022 That petitioner tried to stop this nonsense in one
of the gang rape events of his wife and minor
daughter in front of his house at sonaili p.s.
kadwa on 11.05.2022 but being thrashed, beaten
and injured by the group of sex abusers Shekhar
Gupta R/O Sonaili P.S.Kadwa, Katihar.
12.05.2022 An attempt was taken to murder the petitioner
in (W.P.(Crl.) 137/2021-PIL) by a team of
Government Doctors and missionaries sisters
(sex abusers and international sex racketeers)
through administering inappropriate drugs and
taking blood sample inappropriately on 12th

13
May vide registration no. 2529 at 12:30PM at
Sadar Hospital Katihar, Bihar
16.05.2022 That petitioner has submitted 3 pages application
along with phone numbers of the victims to
Child Railway coordinator and Child
coordinator katihar on 16.05.2022 at child line
booth at plat farm no.02 Katihar Railway
Station for rescue and hand over of victims to
the petitioners. That the petitioner has submitted
complaints along with photographs of the
victims to Child Line India Foundation, NGO
vide registration no. 20220516080001 dated
16.05.2022.
17.05.2022 That the petitioner has submitted complaints
along with photographs of the victims to
Chairperson of NCPCR vide complaint
numbers 202200004880. 11:00am, petitioner
has informed the katihar Child line Railway
coordinator Praveen Kumar and child line
district coordinator Pradeep Kumar that the
victims are again being gang raped on
16.05.2022 night even after submitting 3 pages
application to the Child line katihar on
16.05.2022 at 12.30 pm. Gang rapes organized
in front of petitioner’s house at sonaili
shukkar hatt p.s. kadwa. Gang Rapist are
Bikesh Sahni son of Bisheshwar Sahni,
Gyanchand Sah, Ramashish mahto ram karan

14
mahto and ex-Army man Kapil deo mahto, all
are resident of sonaili p.s. kadwa katihar
18.05.2022 That the petitioner has submitted complaints
along with photographs of the victims to Child
Line India Foundation, NGO vide registration
no. 20220518073646 dated 18.05.2022
20.05.2022 SHO Kadwa and SI Binod Singh called the
petitioner to the police station Kadwa 5 km
away from the house of petitioner in the pretext
of handing over his family members to him.
Misled petitioner and illegally detained him for
three hours at Kadwa police station and gang
raped his families breaking the lock of his
house at sonaili situated 5 km away from
Kadwa Police Station on at 7:30 pm to
11:00pm.
22.05.2022 That petitioner caught the victim at plat farm
no.03 and shouted for help from child line
katihar railway station over phone. Victim was
in black burka led by Maulanas, Muslim
women and children. Ironically instead of
rescue, child line has given safe passage to the
human traffickers. Petitioner’s house is being
planted with a battery bomb by the sex
racketeers, gang rapist and sex abusers.

15
23.05.2022 In spite of alarm to all nodal police officers and
child line NGOs across country; petitioner is
being attacked by a women human trafficker.
She dragged and broke his shirt’s button and
managed to escape the victims. Child line team
member sumit kumar again has given safe
passage to the human trafficker. The victim of
child sexual abuse and Gang Rape is being
again trafficked. Human Trafficker was able to
do this job with an active help of a group of
human trafficker in presence of Sumit Kumar,
Team Member of Child Line Katihar in front of
India Family Mart Mall Katihar at around 11:00
AM. The petitioner alarmed the same to all
nodal police officers of NCT of Delhi and Bihar
through SMS.
24.05.2022 at 19:00pm “victim not handed over, artificial
rain caused for gang rapes and illicit sex trade at
Mahmood Chowk D.S. College katihar, khatu
shyam, argara chowk, hotels of katihar inside
toilet, power engine, driver’s cabin of local
trains, RPF room, RMS room, SSE LOCO
Office at plat farm no.03, inside bed roll room,
canteen room at plat farm no.03 katihar railway
station. At 10:00pm “victims trafficked back
by traffic rail Police from katihar to sonaili
P.S. Kadwa through bullet bike or other
vehicles near to kapil dev mahto’s house, Dhruv

16
Razak & other hot spot areas of sonaili” for
gang rapes”.
25.05.2022 at around 11:00 AM a group of human traffickers
and sex abusers like ravi rai s/o ambika rai, ram
chander sahni, wife of lakhan sahni, gultan
sahni neighbors from eastern side attacked the
applicant with vulgar abuse and pelted stone at
him and on his roof where he was standing to
keep vigil on his victim minor daughter’s
activities hidden inside the house of Dhruv
Razak S/o Ram Narayan Razak VRS employee
from railway katihar. He is northern end
neighbor of applicant. That the applicant
watched the event of gang rapes till 11:45AM.
at 12:00pm “victim is inside Dhruv Razak,
Rupak Raazak, Ravi Razak, Ritesh Razak,
Sonu, Monu S/O Grand/S/O late Ram Narayan
Razak house at shukkar hatt sonaili, P.S.
Kadwa, traffic rail police dropped her here in
the night for Gang Rape and illicit sex trade,
watched till 11:45 AM, thereafter trafficked by
human trafficker for further sexual abuse”.
“victim’s new born baby’s body packed by
Bechan Poddar and his family in white plastic
bag to hide identities or keep her inside house”.
26.05.2022 aggrieved by the delinquent behavior of Pradeep
Kumar child line coordinator katihar and
persistent gang rapes illicit sex trade of victims

17
every day and night, the applicant has registered
a fresh complaint with NCPCR vide
202200004897 and with child line vide
20220526122245.
27.05.2022 at 08:44 am “there is a plan to ignite katihar
bihar for communal violence in the pretext of
gang rapes and illicit sex trade of petitioner’s
hindu families members by 46% muslims in this
region. Wanted to make katihar bihar as
seelampur north east delhi. The victim of gang
rape and illicit sex trade herself approached the
petitioner at plat farm no.02 katihar railway
station at 02:00pm dated 27.05.2022 in the
pretext of enquiring Araria district bound train
at Katihar Railway Station. She was in black
burka garment dresses along with two beggar
women. petitioner immediately identified the
victim and rang the Commissioner of Police
Delhi Head Quarter to intervene into the matter
of human trafficking at source point Katihar
railway station, stop them from trafficking to
Araria Nepal boarder, raid, rescue and hand
over the victims to the applicant immediately.
Instead of rescue, Commissioner Police Delhi
along with DGP Bihar organized gang rapes of
the victims.
28.05.2022 At 19:30 pm “Lock of the main gate of Asha
Deep Niwas, Sonaili village, P.S. Kadwa is

18
being broken by the sex abusers and organized
gang rapes of the victims inside the house
premises of applicant. Hidden prostitution and
illicit sex trade at neighbor Bechan Poddar’s
house. He is doing so by opening window
towards petitioner’s house premises. Situation
is violent at Asha Deep Niwas, Sonaili village,
P.S. Kadwa, Katihar Bihar.
29.05.2022 at 06:01am “illicit sex trade, hidden prostitution,
child sexual abuse and human trafficking by the
surrounding neighbors around petitioner’s
house at Asha Deep Niwas, Sonaili village,
P.S. Kadwa, Katihar Bihar since 18 years.
Petitioner’s 50 siblings, sister in laws and their
respective children including his wife, minor
Daughter hijacked and pushed into this
business. Raid, rescue, medical and charge
sheet before court of law otherwise petitioner
will move against Bihar Police and Delhi
Police before Supreme Court of India with fresh
Writ criminal case within one or two days, Om
Prakash poddar, social worker to all the nodal
police officers of Delhi and Bihar.
30.05.2022 DGP Bihar being informed at 19:00pm for the
possibility of gang rape tonight yet sex abusers
SHO Kadwa along with Indian Army
approached the petitioner at his house at
21:20pm sonaili village katihar misbehaved and

19
gang raped his minor daughter and all family
members disconnecting whole village electricity
continuously throughout the night.
31.05.2022 despite of receiving information disclosing
cognizable offence of gang rapes inside the
katihar bound telta train from sonaili railway
station to Dandkhora railway station to
unnecessarily stopping at outer signal near to
K.B.Jha college, SHO Katihar Rail, Jyoti
Prakash and SP Katihar Rail Avinash Kumar did
not bother to come at plat farm no. 01 of katihar
railway station to raid and rescue the victims of
gang rapes rather given safe passage to sex
abuser, human trafficker, driver of Telta
Passenger train at 11:45 AM on 31.05.2022.
Petitioner is being attacked by sex abusers
railway staff as well as by the general public at
Dandkhora Railway station for monitoring the
activities of sex abusers inside power engine of
Telta passenger train at 11:00 AM on
31.05.2022. Protest events being organized by
the petitioner in front of power engine of driver
and driver of the train called on RPF security
and Dandkhora Railway Station Master through
his official wireless mobile set on the same day.
01.06.2022 State of Bihar and others attempted to murder the
petitioner, looted his valuable assets like original
property documents while petitioner was

20
sleeping inside his house ASHA DEEP NIWAS,
shukkar hatt, sonaili, P.S.Kadwa, Katihar in
order to generate revenue, are continued gang-
rape of the families of the petitioner and
conspired to murder him to convert his house
into a brothel.
02.06.2022 Direction sought from Home Secretary Ministry
of Home Affairs, Government of India to
register an F.I.R against the cognizable offence
commissioned by Child Line Kolkotta Regional
Center, Child Line National center Mumbai,
Child Line katihar, Child Line Samastipur,
Chairperson NCPCR, SP Rail Katihar, SP Civil
Katihar, DRM Katihar, District administration
Katihar and State of Bihar and others for
continuing Gang Rapes of applicant’s families
for consecutively 28 days after rescue of the
victims from Delhi at the source point of human
trafficking at Sonaili Village, P.S. Kadwa,
Katihar rescued by the order of Supreme Court
of India in W.P.(Crl.) 137/2021-PIL &
W.P.(Crl.) 242/2021
03.06.2022 Direction sought from Home Secretary Ministry
of Home Affairs, Government of India to
register an F.I.R against the cognizable offence
commissioned by Ms. Indu Sinha, Justice S.B.
Sinha of Supreme Court of India, Manoj Sinha

21
Governor of J&K, Jayan Sinha ex cabinet
minister government of India, Praveen Kumar
Indian Defense Account Service, Amarnath
Sinha, NGO owner at Sonaili P.S. Kadwa and
State of Bihar and others for continuing Gang
Rapes of applicant’s families for consecutively
29 days after rescue of the victims from Delhi at
the source point of human trafficking at Sonaili
Village, P.S. Kadwa, Katihar rescued by the
order of Supreme Court of India in W.P.(Crl.)
137/2021-PIL & W.P.(Crl.) 242/2021 -
04.06.2022 Gang Rapes and illicit sex trade of the victims
minor girls/daughter (collecting revenue by
selling symbolic “Lichhi” a seasonal fruit)
continued at P.S Kadwa Katihar, Bihar after
raping her at J.N.U New Delhi on 26.05.2022
and 27.05.2022 causing artificial rain, cloudy
weather, performing vulgar DJ dance by the
victims. Sonaili Railway station in P.S. Kadwa
katihar district of Bihar is being identified as
source point of human trafficking and the hub
for illicit sex trade and Sunil Bubna’s house and
its surrounding areas, households, shops are
being identified as brothels.
05.06.2022 Katihar administration and state of Bihar and
others have tried to obstruct the way of
applicant from reaching Supreme Court of India

22
on 05.06.2022 at 5:45PM
06.06.2022 Delhi Police has given safe passage to Human
trafficker to traffic minor daughter of petitioner
on 06.06.2022 at 22:30pm from Anand Vihar
Railway Station Delhi.
07.06.2022 Hence this Criminal Writ Petition.

23
IN THE SUPREME COURT OF INDIA
CRIMINAL ORIGINAL JURISDICTION
WRIT PETITION CRIMINAL NO. OF 2022
(UNDER ARTICLE 32 OF THE CONSTITUTION OF INDIA)
AND
IN THE MATTER OF RE-PUSHING THE RESCUED
VICTIMS OF ILLICIT SEX TRADE AND CHILD
SEXUAL ABUSE INTO THE SAME BUISNESS OF
GANG RAPES GENERATING REVENUE OUT OF IT AT
THE SOURCE POINT OF HUMAN TRAFFICKING AND
ABUSE OF POWER BY STATES, NGOS, GANGSTERS
AND INDIAN DEFENSE ORGANIZATIONS
AND
BETWEEN
1. Om Prakash ………PETITIONER
S/O Late Sh Deep Narayan Poddar
R/O ASHA DEEP NIWAS
Vill-Kantiya Panchayat,
Shukkar Haat Sonaili,
In front of Durga Mandir
P.S. Kadwa, Distt-Katihar
Bihar-855114
AND RENTED
R/O C/O Inder Pal
RZF-893, Netaji Subhash Marg
Raj Nagar Part-2, Palam Colony
New Delhi-110077
VERSUES
1. Union of India ….RESPONDENT No.01
Ministry of Home Affairs
Through
Secretary North Block,
Central Secretariat, New Delhi
2. Government of NCT of Delhi ….RESPONDENT No.02
Through
Chief Secretary
Delhi Secretariat, I.P. Estate
New Delhi-110002
3. State of Bihar ….RESPONDENT No.03
Through Chief Secretary,
Old Secretariat, Patna-800015
4. District Magistrate ….RESPONDENT No.04
Katihar, Bihar
5. District Judge ….RESPONDENT No.05

24
District Court Katihar
Bihar
6. Public Prosecutor ….RESPONDENT No.06
District Court Katihar
Bihar
7. Commissioner of Police Delhi ….RESPONDENT No.07
Police Headquarters,
MSO Building, I.P. Estate,
New Delhi-110002
8. Director General of Police ….RESPONDENT No.08
Bihar Police Headquarters,
Sardar Patel Bhawan,
Nehru Marg, Patna - 800023
9. Inspector General of Police, ….RESPONDENT No.09
Darbhanga, Bihar
10. Deputy Inspector General of Police ….RESPONDENT No.10
Purnia, Bihar
11. Superintendent of Police ….RESPONDENT No.11
District- Katihar,
Bihar-854105
12.Deputy Commissioner of Police ….RESPONDENT No.12
North East District Delhi
13.Assistant Commissioner of Police ….RESPONDENT No.13
Seelampur,
14.Assistant Commissioner of Police ….RESPONDENT No.14
Delhi Cantt.
South West District Delhi
New Delhi
15.Secretary ….RESPONDENT No.15
Electricity Department
Government of Bihar
16.Chief Executive Engineer ….RESPONDENT No.16
District Katihar, Bihar
17.Junior Executive Engineer ….RESPONDENT No.17
Sub-Station Sonaili, Kadwa
18.Secretary Health Department ….RESPONDENT No.18

25
Patna, Government of Bihar
19.Civil Surgeon ….RESPONDENT No.19
Health Department
20.In-charge Medical Officer ….RESPONDENT No.20
Kadwa, Primary Health Centre
Durgagunj, District Katihar
21.Sub Divisional Manager ….RESPONDENT No.21
Barsoi, Katihar
22. Sub-Divisional Police Officer ….RESPONDENT No.22
Head Quarter
District-Katihar,
Bihar- 854105
23. Sub-Divisional Police Officer ….RESPONDENT No.23
Barsoi, District Katihar,
Bihar- 855102
24.Station House Officer ….RESPONDENT No.24
Palam Village Police Station,
South West District
New Delhi
25. Station House Officer ….RESPONDENT No.25
Kadwa Police Station,
District-Katihar,
Bihar-855114
Shastri Park,
Dandkhora, Katihar
Bihar
28. Chairperson ….RESPONDENT No.28
National Commission for Protection
of Child Rights (NCPCR)
5th
Floor, Chanderlok Building,
36 Janpath, New Delhi-110001
29. Nodal Coordinator ….RESPONDENT No.29
ChildLine India Foundation
Eastern Regional Resource Centre
Kolkotta
30. Nodal Coordinator ….RESPONDENT No.30

26
ChildLine India Foundation
North Regional Resource Centre
1st Floor, H. No. 144/2, Hari Nagar
Mathura Road, Ashram, New Delhi-14
31. Child line Railway Coordinator …..,.RESPONDENT No.31
Katihar, Plat Farm No.02, Katihar Railway
Station, Bihar
32. SP Railway Delhi …..,.RESPONDENT No.32
Old Delhi Railway Station
Delhi
33. SP Railway Katihar …..,.RESPONDENT No.33
Katihar Railway Station
Bihar
34. SHO Railway Police, …..,.RESPONDENT No.34
Plat Farm No.02
Bihar
35. Indian Defense Organizations …..,.RESPONDENT No.35
Army, Navy and Air Force
Head Quarters at New Delhi
36. Divisional Rail Manager …..,.RESPONDENT No.36
Eastern Frontier Rail Division
37. Director …..,.RESPONDENT No.37
Trustee and Governing Bodies
Asha Deep Foundation
Shalimar Garden Main B-block, Block A,
Shaheed Nagar, Ghaziabad,
Uttar Pradesh 201005
0120- 262 6309
D-81, Shahid Nagar, Delhi NCR, Ghaziabad,
U. P., India
38. Director …..,.RESPONDENT No.38
Child Line India Foundation
B-1101, 11th
Floor, Ratan Central
Dr, Baba Saheb Ambedkar Road
Parel East, Mumbai-400012
39. Child Line Coordinator …..,.RESPONDENT No.39
District Samastipur, Bihar
40. Chairman …..,.RESPONDENT No.40
Railway Board, Rail Bhawan

27
New Delhi-1
WRIT PETITION UNDER ARTICLE 32 OF
THE CONSTITUTION OF INDIA FOR
ISSUANCE OF A WRIT IN THE NATURE OF
MANDAMUS OR ANY OTHER
APPROPRIATE WRIT FOR ENFORCEMENT
OF ARTICLE 21 OF THE CONSTITUTIION
OF INDIA.
To
Hon'ble the Chief Justice of India and His
Lordship's Companion Justices of the Supreme
Court of India. The Humble petition of the
Petitioner abovenamed.
MOST RESPECFULLY SHOWETH:
1. FACTS OF THE CASSE:
(i) That the present Writ Petition under Article 32 of
the Constitution of India is being filed by a Social
Worker cum Petitioner-In-Person cum Whistle
Blower cum husband cum Father cum Guardian of
rescued victims of Gang Rapes, flesh trade, hidden
prostitution, illicit sex trade, child sexual abuse and
international human trafficking rescued with an
active help of this Hon’ble Court in Writ Petition
(Criminal) 242 of 2021 and Writ Petition (Criminal)
137 of 2021 (victims rescued from the brothels of
Varanasi, G.B. Road Delhi and Shastri Park North
East Delhi boarded at Delhi in Mahananda Express
Train on 05-05-2022 along with petitioner’s PNR
No.260-2313501 and de-boarded at katihar railway

28
station on 06-05-2022 along with near about 50
family members of petitioner and their minor
children including his own wife, minor daughter.
Sisters, sister-in-law and their minor children) but
unfortunately not being placed before court of law,
not being initiated rehabilitation process either
within state’s institutions like women shelter house,
children’s observation homes or within family or not
being initiated handing over procss to the petitioner
either by Magistrate Katihar or by Delhi Rail Police
or by Katihar Rail Police or by the Child Line
Kolkotta, Dhanbad, Patna, Samastipur, Begusarai,
Purnea, Katihar etc and being re-pushed into the
same business of flesh trade at the source point of
human trafficking at Sonaili village, district Katihar
Bihar; aggrieved by this delinquent behavior,
arbitrary action of the state, rampant unlawful
detention of petitioner by Delhi and Bihar Police for
blowing whistle against the persistent Gang Rapes
and illicit sex trade of rescued victims w.e.f
06.05.2022 to till date by the nexus of State, NGOs,
Gangsters, Mafias and Indian Defense organizations
in front of his own house at Asha Deep Niwas,
Sonaili, P.S. Kadwa, Katihar, Bihar and in front of
his own eyes and for the enforcement of the Rights
under Article 21 of the Constitution of India.
(ii) That the petitioner has noticed that the International sex
business/racket is prevailing in the source point of Human

29
Trafficking at Sonaili, Katihar Bihar since 1978.
(iii) The petitioner is an eye witness of a child sexual abuse case
by Guptaji, a teacher posted at Kadwa Middle School, P.S.
Kadwa, katihar, Bihar while his father was posted as Head
Master in that school in 1978. Father blown a Whistle
against sex abuser teacher before District Magistrate
Katihar but father was being thrashed, beaten and severely
caused head injury by Bhola Viswash, then Member of
Parliament and his associates like Vishwanath Das a sex
abuser teacher posted at Kadwa Middle School, Mukti nath
Jha, Amar Nat Jha, Krityanand Jha, Laddu Jha, Kamal nath
Jha in the morning of severe cold at around 4:00 AM.
Father, mother along with 5 year old petitioner approached
the SHO Kadwa with a bleeding head of father but no F.I.R
was being registerd by the then SHO, Kadwa. Matter being
suppressed and sex business was being escalated in that
vicinity.
(iv) That the petitioner has noticed that his family members are
victim of International sex business/racket since 1978.
(v) That petitioner’s elder sister Sneh Lata is being picked up
by human traffickers/sex racketeers from R.N.D.B High
School Sonaili and being pushed into child sexual abuse,
illicit sex trade, hidden prostitution by Kuber Bhagat,
Rupak Razak, Vishwajeet Poddar, Naresh Gupta, Dhiren
Gupta, Ram Jatan Singh, Ram Kalyan Singh, Birender
Singh, Ramadhar Singh a teacher posted at R.N.D.B High

30
School Sonaili, SP Saroj Das, Army man Kapil Dev Mahto
Army man R/O Sonaili, Katihar. She conceived a baby at
the age of 15 years and baby was being aborted illegally by
these sex abusers/sex racketeers.
(vi) That Petitioner’s middle sister Pushp Lata is being picked
up by human traffickers/sex racketeers from R.N.D.B High
School Sonaili and being pushed into child sexual abuse,
illicit sex trade, hidden prostitution by Rama Mahto S/O
Sibu mahto R/O Sonaili, Katihar way back in 1986.
(vii) That Petitioner’s younger sister Padmaja Kumari alis
Likhiya is being picked up by human traffickers/sex
racketeers from A.L.High School Sonaili and being pushed
into child sexual abuse, illicit sex trade, hidden prostitution
by a teacher Ramesh Sah, Sukhdev Sah, Son of Makhan
Sah, Dilip Nunia S/O Jyotish Nunia , Bihari Lal Bubna S/O
Vasudev Bubna, Akhilesh Vishwas S/O Chhedi Vishwas,
Manish Singh S/O Ram Kalyan Singh, Dilip Chaudhry S/O
Siwanan Chaudhry, Sanjay Gupta, Bablu Gupta S/O
Ashwani Mukhiya, Naresh Gupta, all son of Baikunth
Gupta, all son of Ram Narayan Razak R/O Sonaili, Katihar
way back in 1988.
(viii) That all four daughters and their kids of Leela Nand Poddar
and Kalanand Poddar, maternal uncles of petitioner R/O
Sonaili Katihar have been picked up by human
traffickers/sex racketeers from school and being pushed into
the business of flesh trade way back in 1980s.

31
(ix) That all daughters and their kids of Bindeswari Poddar,
uncles of petitioner R/O Gandhi Nagar Purnea have been
picked up by human traffickers/sex racketeers from school
and being pushed into the business of flesh trade way back
in 1980s.
(x) That all daughters and their kids of Harish Chander Poddar,
uncles of petitioner R/O Barauni, Begusarai have been
picked up by human traffickers/sex racketeers from school
and being pushed into the business of flesh trade way back
in 1986.
(xi) That all daughters of Surender Narayan Poddar, father in
law of petitioner R/O Barauni Refinery Township IOCL,
Begusarai viz. Rina Kumari, Anuja Kumari alias Annu,
Rupam Kumari alias Dolly and their kids have been picked
up by sex abusers, sex racketeers, mafia gangsters and
being pushed into the business of flesh trade way back in
2005.
(xii) That petitioner is eye witnessed of the naked dance of State,
NGOs, Gangsters, Mafia and Indian Defense Organizations
against the rescued victims of flesh trade from Delhi since
06.05.2022 to till date at the source point of human
trafficking at Sonaili, P.S.Kadwa, Katihar with great pump
and show added by vulgar DJ dance every day and night.
(xiii) That the victim is own family members of petitioner viz
Wife Rina Kumari age about 44 years and daughter Shriya

32
Poddar age about 17 years are being repeatedly sold in the
market of flesh trade in front of his own eyes and in front of
his own house Asha Deep Niwas, Sonaili, P.S. Kadwa,
Katihar Bihar through the system of registry for short stay
in the house of sex abuser, performing shots for oral sex,
anal sex and vaginal sex, aborting babies, conceiving
babies, performing sex during tours and travels, sex during
picnics, celebrations, sex through hotels booking,
organizing events of Gang Rape in the name of “marriage
ceremony” and inviting sex abusers in the name of
“Baaraati” with great pump and show by an erotic vulgar
strong beat songs of DJ, collecting revenue by selling
“Licchi” a seasonal fruits in the market and in the each
households of vicinity, sex attending at SPA, sex in
Wellness centers, sex with Massage center etc.
(xiv) That child line complaint reference numbers are
20220516080001 dated 16th May 2022 and
20220518073646 dated 18th May 2022.
(xv) That sex racketeer and human trafficker has been figured
out on 06.05.2022 night itself yet specifically on 22.05.2022
at 10:00 AM again being identified by petitioner related to
this case and the same has been informed with human
traffickers new number 8586998355/8587938478 to Katihar
Railway Child line coordinator Praveen Kumar, Pradeep
Kumar Child Line Coordinator Katihar, Dharmendra Meena
Enquiry officer appointed by Delhi Police, DGP Bihar, IG
Darbhanga, DIG Purnea, SP Katihar, SHO Palam Village
New Delhi, SHO Shastri Park North East Delhi and SHO

33
Kadwa through SMS on their respective official mobile
numbers to organize police raid to rescue, medical, arrest,
charge sheet and hand over the victims of Gang Rape
travelling from Telta Passenger Train boarded at Sonaili
railway station and de-boarded at Katihar railway station
Plat Farm No.03. SMS has been sent from sonaili railway
station itself at the time of departure of train.
(xvi) That after the arrival of train at katihar railway station at
11:00 AM, petitioner followed the victim captured by a
team of human traffickers and shouted for help from Child
Line booth at Plat Farm No.02 that Gang Rape victim wife
Rina Kumari age about 44 years and daughter Shriya
Poddar age about 17 years have been kidnapped by human
traffickers, international sex racketeers, sex abusers way
back on 15.04.2005 from Brajesh Yadav (a driver of judge
and Supreme Court Justice) house located at Raj Nagar
Part-2, Street No.12 Palam Colony New Delhi-77 while
daughter Shriya Poddar was inside the womb of her mother.
Father in law Surender Narayan Poddar Assistant Manager
(RC) Barauni Refinery, Township, IOCL Begusarai has
taken away petitioner’s pregnant wife under the pressure of
international human traffickers to IOCL Quarter Dhanbad
by Poorva Express from New Delhi to Dhanbad IOCL
Quarter.
(xvii) That departed father of petitioner writes a mysterious note
in his daily diary of 2005 that “Wife of Pappu has given
birth to a female baby on 20.05.2005 at 6:00pm. The
delivery of female baby has taken place in a hospital of

34
Dhanbad (Jharkhand). The same day I became unconscious
in Delhi due to heat wave. As a result of that Pappu and
Rahul were scared”.
(xviii)That petitioner and his parents are not being allowed to see
their daughter and granddaughter till 09.02.2011. Petitioner
has seen his daughter first time on 09.02.2011 when she
appeared before the Principle Judge Family Court Dwarka
Court at New Delhi in HMA-700/2010 case.
(xix) That wife and 6 year old daughter Shriya Poddar along with
father in law and mother in law appeared before the family
court Dwarka Court at New Delhi on 09.02.2011.
True copy of order dated 09th
February, 2011 by Principle
Judge, Family Court, Dwarka Court at New Delhi in HMA-
700/2010 case is annexed herein as Annexure P-1 (Page
from 60 to 60)
True copy of photographs of minor daughter Shriya
Poddar dated 09th
February, 2011 at children’s room at
Family Court, Dwarka Court at New Delhi in HMA-
700/2010 case is annexed herein as Annexure P-2
(Page from 61 to 61)
(xx) That gang rape victim wife Rina Kumari has filed
Vakalatnama in HMA-700/2010 case before Principal
Judge Family Court Dwarka at New Delhi through her
counsel/ Advocate from district Purnea Bihar who belongs
to Rajput Caste. She did not file any Written Statement and

35
did not contest the case. However, she has filed two cases in
CJM Court at Begusarai Bihar and expressed her
willingness to stay along with her husband and demanded
lump sum handsome amount as compensations and monthly
amount as maintenance. One 9P/2010 under domestic
violence Act 2005 and another Criminal Case Complaint
(P) No. 397C/ 2011/ 5591/2013 under section 498A,
section 323 of IPC and u/s 3/4 of D.P Act in
2010 and 2011 along with two N.B.Ws dated 25.08.2010
and 08.09.2011 u/s 82 and 83Cr.Pc respectively.
(xxi) Thereafter she disappeared from this earth and petitioner is
being subjected to face abuse of court process from lower
court to Supreme Court of India from state of Bihar to NCT
of Delhi till date on the one hand and sexual abuse of his
wife and minor daughter on the other hand.
(xxii) That petitioner has rescued the victims (his wife, minor
daughter and 50 female members of his family and their
children) of gang rape, hidden prostitution, illicit sex trade
and child sexual abuse from the brothels of Gulabbagh
Purnea Bihar, Sonagachhi Kolkotta, Varanasi, UP, G.B.
Road New Delhi with an active help of Supreme Court of
India through (W.P.(Crl.) 137/2021-PIL & W.P.(Crl.)
242/2021) cases on 05.05.2022 and brought them back at
source point of human trafficking, Katihar railway station
by Mahananda Express on 06.05.2022.
(xxiii)However, the rescued victims of Gang Rapes, hidden

36
prostitution and child sexual abuse have not been handed
over to the petitioner either by Delhi Rail Police or by
Katihar Rail Police till date rather continuing gang rapes
and generating revenue out of it. The accompanying Lady
Magistrate of Katihar has taken them out by producing
illegal, false and wrong documents to Katihar rail police
and re-pushed them into the same business of flesh trade at
the source point of human trafficking at sonaili village P.S.
Kadwa and the surrounding areas of katihar districts.
(xxiv)That petitioner cum social worker cum whistle blower cum
father cum guardian of victims has been approaching all the
government and Non-Government institutions/ authorities
for rescue and hand over of the rescued victims but none are
paying any heed to the request of petitioner till date.
(xxv) That instead of handing over the rescued victims,
administration is organizing Gang Rape of rescued victims
in the name of Marriage ceremony and inviting sex
abusers/customers in the name of Baarati every night in
front of petitioner’s house at Asha Deep Niwas, Shukkar
Hatt, Sonaili, P.S. Kadwa, katihar, Bihar-855114 and in
front of his own eyes.
True copy of signed copy of police complaint against
sex abusers state through email letter dated 07th
May
2022 by petitioner to all nodal police officers of Bihar
and NCT of Delhi is annexed herein as Annexure P-3

37
(xxvi)That the victim Wife Rina Kumari age about 44 years and
daughter Shriya Poddar age about 17 years are being
repeatedly sold in the market of flesh trade in front of his
own eyes and in front of his own house Asha Deep Niwas,
Sonaili, P.S. Kadwa, Katihar Bihar through the system of
registry for short stay in the house of sex abuser, performing
shots for oral sex, anal sex and vaginal sex, aborting babies,
conceiving babies, performing sex during tours and travels,
sex during picnics, celebrations, sex through hotels
booking, organizing events of Gang Rape in the name of
“marriage ceremony” and inviting sex abusers in the name
of “Baaraati” with great pump and show by an erotic vulgar
strong beat songs of DJ, sex attending at SPA, sex in
Wellness centers, sex with Massage center etc.
May
May
(xxvii) That petitioner tried to stop this nonsense in one of the

38
gang rape events on 11.05.2022 but being thrashed, beaten
and injured by the group of sex abusers Shekhar Gupta.
May
(xxviii) That Sadar Hospital Katihar has given medical services
to the petitioner on 12.05.2022. An attempt was taken to
murder the petitioner in (W.P.(Crl.) 137/2021-PIL) by a
team of Government Doctors and missionaries sisters (sex
abusers and international sex racketeers) through
administering inappropriate drugs and taking blood sample
inappropriately on 12th
May vide registration no. 2529 at
12:30PM at Sadar Hospital Katihar, Bihar
(xxix)That however, the doctor’s prescription is being snatched by
Vendor Kedar Paswan spraying intoxicated drugs over to
the petitioner at Dandkhora railway station on 12.05.2022.
The same has been informed to all nodal police officers of
Bihar and Delhi through SMS on the same day.
May

39
May
May
May
(xxx) That petitioner has submitted 3 pages application along with
phone numbers of the victims to Child Railway coordinator
and Child coordinator katihar on 16.05.2022 at child line
booth at plat farm no.02 Katihar Railway Station.
May

40
(xxxi)That the petitioner has submitted complaints along with
photographs of the victims to Child Line India Foundation,
NGO vide registration no. 20220516080001 dated
16.05.2022
(xxxii) That the petitioner has submitted complaints along with
photographs of the victims to Chairperson of NCPCR vide
complaint numbers 202200004880 dated 17.05.2022.
May
(xxxiii) That the petitioner has submitted complaints along with
photographs of the victims to Child Line India Foundation,
NGO vide registration no. 20220518073646 dated
18.05.2022
May
(Page from 77 to 78 )
(xxxiv) That petitioner approached Child Line booth at plat farm
no.02 and registered his grievances against this heinous act

41
of child line coordinator katihar Bihar.
(xxxv) That horribly, Coordinators asked for Aadhar Card of
victims for handing over process while victim has been
kidnapped by the human trafficker way back on 15.04.2005
while she was inside the womb of her mother thereafter
never met the petitioner father except on 09.02.2011 at
Dwarka Court at New Delhi. Petitioner has informed the
same to the coordinator to coordinate with regional or
national office because all relevant documents like court
orders, snaps of victims have been submitted online to
NCPCR & Child Line India Foundation on 16th
and 17th
May 2022 and the case has been accepted by them.
(xxxvi) That petitioner understood the game plan of Child Line
coordinators. They are basically sex abusers and income
generator from the victims.
(xxxvii) That petitioner asked from on duty volunteer Raj Kumar
Jha to supply the snaps of attendance sheet maintained by
the petitioner at the booth of Child Line plat farm no.02
katihar railway station since 16.05.2022.
(xxxviii) That surprisingly, Sex abuser Pradeep Kumar
coordinator Child Line Katihar monitored the events
through online CCTV camera and scolded on duty
Volunteer Raj Kumar Jha for supplying the offline
attendance sheet of petitioner to the petitioner’s email
id:om.poddar@gmail.com. Thereafter volunteer refused to

42
supply the attendance sheet of petitioner.
(xxxix) That the first point person who sexually abused and
pushed petitioner’s wife into prostitution is Justice S.B.
Sinha of Supreme Court of India through driver of Judges
Mr. Brajesh Yadav & Pappu Yadav R/O Raj Nagar Part-2,
Gali No.12, Palam Colony, New Delhi-110077, thereafter
picked by Praveen Kumar, Indian Defense Account
Services R/O Patna, SP Deepak Sah, Lohapatti Bhagalpur,
SP Katihar Sidharth Mohan Jain, SP Katihar Vikas Kumar,
SP Katihar Jitender Kumar, SP Katihar rail Avinash Kumar,
A.K.Chaudhry R/O Begnabari Katihar, Bihari Lal Bubna
R/O Sonaili P.S. Kadwa, Mukesh Sinha R/O Bhagalpur,
Santosh Kumar, Pharmacist, Sultangunj, Bhagalpur, Talib
Khan R/O Gaya, Digvijay Singh S/O R.K. Singh, R/O Patna
Bihar and Gola Dairy Dwarka at New Delhi, Inder pal S/O
Hira Lal R/O RZF-893, Netaji Subhash Marg, Raj Nagar
Part-2, Palam Colony, New Delhi-110077, Agam Poddar
S/O Vishundeo Poddar R/O Khagaria and Shastri Park
North East Delhi, Kedar Paswan, railway vendor R/O
Khagaria and Sonaili, P.S. Kadwa, Katihar, Thakur
Digvijay Singh S/O Lalit Singh R/O Sonaili Goshala, P.S.
Kadwa, Nanki Singh Army man, R/O S/O Lalit Singh R/O
Sonaili Goshala, P.S. Kadwa & Vasant Kunj New Delhi,
Bobin Banerjee R/O Mirchaibari Katihar & Gurgaon Delhi
NCR, Dilip Jha R/O Kishangarh vasant kunj new delhi and
dwarka new delhi, Dilip Kumar S/O Jyotish Nunia R/O
Salmari, Santosh Gupta RSS & Nextagen coaching
Institute R/O Katihar, Sunil Poddar S/O Late Siwanan
Poddar R/O Sonaili & Katihar, CNF agent Sharoff at

43
Gulabbagh Purnea, Shalender Prasad deo R/O Sonaili
Khagaria & N.R. Public School Raj Nagar Part-2 Palam
Colony at New Delhi, Agam Poddar S/O Vishundeo Poddar
R/O Khagaria & Shastri Park, North East Delhi, Abhay
Poddar S/O Kameshwar Poddar R/O Argara Chowk,
Katihar, Ram Chander Poddar S/O Late Varon Poddar R/O
Teghra Begusarai Bihar & C-180 LIG Flat, Housing Board
Colony, Amritsar Punjab, Dr. R.Sinha R/O Vinodpur,
Katihar, SP Deepak Sah R/O Lohapatti, BhagalPur, Arun
Dokania, Manthu Dokania, Gappu Bubna, Sanjay Bairwa
Jain, R/O Sonaili, Jain of Gulabbagh Purnea, Sanjay
Chandra, Abhay Poddar R/O Argara Chowk, Katihar,
Shyamal Sah, Gopal Sah, Mahender Sah, Ravi Sah R/O
Sonaili, Gangsters Suraj Bhan Singh, Pappu Yadav, son of
Sahabuddin, Ashok Agaral Member of Legislative Council
Kadwa, Ram Prakash Mahto, Sanjay Purve R/O Katihar,
Ram Karan Mahto, Ramashish Mahto, Kapil deo Mahto,
Dr. Shakeel Ahmed Khan, Member of Legislative
Assembly Kadwa, Dulal Chand Goshwami Member of
Parliament Katihar, Nikhil Chaudhry Former Member of
Parliament BJP, Giriraj Singh Member of Parliament BJP,
Chirag Paswan s/o Ram Vilas Paswan, Mukesh Sahni
welfare Minister Govt. of Bihar, Tarkeshwar Prasad Deputy
Chief Minister Bihar, A.K. Chaudhry R/O Begnabari
Katihar, Sunil Kumar R/O Bhogaon, Rakesh Sinha, R/O
Begusarai MP&RSS leader, Jayant Sinha, Ajit Kumar IAS
R/O Freedom fighter colony IGNOU New Delhi, Sunita
W/O Vinod Karn pimp R/O Darbhanga and phoolwaria
Katihar, Babita Devi R/o Rajgir Gaya and C/O Abhay
Poddar Argara Chowk Katihar, all elected representatives

44
of Panchayati Raj Institutions, all political parties, youth
wing, cultural organizations of all political parties, Justice
U.U. Lalit, Pinaki Chandra Ghosh, Ranjan Gogoi, Snjay
Kishan Kaul, G.S. Singhvi, Kurien Josheph, Ajay Rastogi,
Hement Gupta of Supreme Court of India, Justice Veena
Birabal of Delhi High Court, Principle Judge Family Court,
Deepa Sharma, Advocate Sunil Ojha, SP Sidharth Mohan
Jain, present SP Railway katihar Avinash Kumar, SP Civil
Jitender Kumar, DIG Purnea Vikas kumar, Pappu poddar
niece of Surender Narayan Poddar R/O Rohini, coaching
Institute in Munirka at New Delhi, Digvijay Singh S/O R.K.
Singh R/O Siswachack, sonpur and Gola dairy New Delhi,
Thakur Digvijay Singh S/O Lalit Singh R/O Sonaili
Goshala Road, Asabuddin Obesi, MP, Shyamar Bubna,
Rakesh Bubna, Banti Bubna, Kanahiya Banka, Sunil Bubna,
Pappu Bubna, Adhin lal and sons, Gulab Indane R/O
Sonaili, Indian defense organizations, executives, judiciary,
legislatures, media, different gangsters, mafia for generating
own incomes and consuming own sexual gratifications.
Victim is eing thrown into different brothels across Globe.
(xl) That Judicial Magistrate of Katihar has submitted wrong
documents on 06.05.2022 at katihar railway station and
took the victims in her own custody and thereafter re-
pushed them into the same business of flesh trade at the
source point of human trafficking in front of petitioner’s
house at Asha Deep Niwas, Sonaili P.S. Kadwa Katihar and
in front of his own eyes.

45
(xli) That the international sex racketeers are creating total chaos
in the well-established caste system of Indian society which
has resulted in total anarchy in the social system. From
Director General of Police Bihar to Station House Officers
of police stations have become sex abusers of victims. From
Ministers to watchmen are sex abusers of victims. DGP
Bihar shared the information over telephone that
petitioner’s family members prefer to stay at the neighbor’s
house rather than petitioner’s house. Sex abuser DGP Bihar
became judge and court instead of rescuing and handing
over the victims to the petitioner.
(xlii) That chairperson of NCPCR vide complaint numbers
202200004880 dated 17.05.2022, Child line
20220516080001 dated 16.05.2022, 20220518073646 dated
18.05.2022 and telephone numbers of Kolkotta office 033-
23416130 for Child Line Eastern Regional Centers , Child
Line Northern Regional Centers, Gurgaon Delhi NCR
telephone numbers 0124-2862900, Child line Coordinator
Katihar, Pradeep Kumar 9471679934 have been figured out
as a sex abusers of petitioner’s family members and their
minor children.
(xliii) That SP Railway Delhi and Katihar, SHO Railway Police
Katihar Plat Farm No.02 have also been identified as sex
abusers of petitioner’s family members and their minor
children for not handing over rescued victims to the
petitioner and re-pushing them into the same business of
flesh trade in front of his house Asha Deep Niwas Sonaili
and in front of his own eyes since 2005.

46
(xliv) That SP Katihar and SHO Kadwa have also been identified
as sex abusers of petitioner’s family members and their
minor children for not handing over rescued victims to the
petitioner and re-pushing them into the same business of
flesh trade in front of his house Asha Deep Niwas Sonaili
and in front of his own eyes since 2005.
May
(xlv) That SHO Kadwa and SI Binod Singh called petitioner to
the police station Kadwa 5 km from the house petitioner in
the garb of handing over family members to the petitioner.
Misled petitioner and illegally detained him for three hours
at Kadwa police station and gang raped his families
breaking the lock of his house at sonaili situated at 5 km
away from Kadwa Police Station on 20.05.2022 at 7:30 pm
to 11:00pm.
May
(xlvi) That every day petitioner catches the victims in the event of

47
gang rapes but Child Railway coordinator and Child
coordinator katihar gives safe passage to them every day for
organizing gang rape.
(xlvii)That petitioner caught the victim at plat farm no.03 and
shouted for help from child line katihar railway station over
phone. Victim was in black burka led by Maulanas, Muslim
women and children. Ironically instead of rescue, child line
has given safe passage to the human traffickers on
22.05.2022.
sex abusers state through email letter dated 22nd
May
(xlviii) That petitioner’s house has been planted with a battery
bomb on 22.05.2022 by the sex racketeers, gang rapist, sex
abusers Sunil Poddar S/O Siwanand Poddar, R/O Sonaili
and Katihar, CNF agent Sharoff R/O Gulabbagh Purnea,
Santosh Gupta, Nextagen Coaching Institute R/O Katihar,
Pawan Singh alias Thakur Digvijay Singh, Tax Accountant
consultant with Rajasthan Hotel Katihar R/O Sonaili,
Digvijay Singh S/O R.K. Singh R/O Siswachak, sonpur &
patna & gola dairy new delhi, Mukesh Sinha R/O
Bhagalpur, SP Deepak Sah R/O Lohapatti, Bhagalpur, SP
Sidharth Mohan Jain Gang Rapist, Talib Khan R/O Gaya &
Aurangabad, Mustak Khan, Sajid Khan R/O Siwan, Dr.
Shakeel Ahmad Khan, MLA Kadwa, SP Vikas Kumar,

48
Shyamar Bubna, Arun Dokania, Manthu Dokania, Banti
Bubana, Gulab Indane, SDM Barsoi, Rakesh Bubna, Sunil
Bubna, Sanjay Bairwa Jain and the same has been informed
to the all nodal police officers of Bihar and Delhi to diffuse.
(xlix) That District Magistrate, SDM Barsoi, District Judge
District court Katihar and Public prosecutor District court
katihar have also been identified as sex abusers of
petitioner’s family members and their minor children, not
handing over rescued victims to the petitioner and re-
pushing them into the same business of flesh trade in front
of his house Asha Deep Niwas Sonaili and in front of his
own eyes since 2005, organizing gang rapes of victims
every night with great pump and show, murder of gang rape
victims, cremating dead bodies of gang rape victims
evading Rule of Law without executing Panchnama and
postmortem.
(l) That after receiving information disclosing cognizable
offence of persistent gang rape of rescued victims at the
source point of Human Trafficking by the Secretary
Ministry of Home Affairs and all nodal police officers of
Bihar and NCT of Delhi, victims are being gang raped by
Sunil Poddar, Santosh Gupta RSS leader, Katihar in his
house at nextagen coaching center thereafter inside the local
siliguri passenger train thereafter whole night performing
DJ dance and gang rape at the tune of gun firing by the
nexus of State, Gangsters, Mafia, NGOs and Indian Defense
Organizations in Goshala, Bishanpur, Pradeep Yadav’s hen
farm, Nijhra, Chand Hotel’s house, Himraj Singh House,

49
Sahni Tola’s house, Pahlagarh, Kumhari, Kadwa at Sonaili
Shivpuri Bihar Military Police premises, Raj Kumar
Gupta’s House, Sanjay Chandra’s House at Katihar, Khattu
shyam hall argara chowk katihar, hotels of katihar, CNF
agent Sharoff’s Gulabbagh brothels, Falka, Khagaria,
Bhagalpur, Purnea, Supol, Dhamdhaha, Rupoli, Viratnagar
Nepal, Saharsa, Gaya, Siwan, Kishan ganj, Barsoi, Maldah,
Kolkotta, Orissa, Assam, Siliguri, Sikkim, Jharkhand,
Patna, Varanasi and many other locations from 06.05.2022
to till date.
(li) That the gang rape is organized with the help of artificial
rain, intoxicating drugs, alcohol, medical team, technology
based equipment, hidden camera inside the bodies of human
as well as animals, birds, use of biological weapons like
COVID-19 virus, use of jammer communications/mobile
services, use of Air Base for trafficking the gang rape
victims from one place to another place, use of own
relatives, kith, kin and closest friends of victims etc.
(lii) That the socio economic dynamics of this sex business is
technology based, non-banking financial centers based,
corporate social responsibility based, geo-politics based,
Cristian missionaries adoption based, youth, cultural wings,
students wings polarization based, social conflict,
communal violence, social chaos, social anarchy based,
social disequilibrium based sex industry.
(liii) That the bitter truth of rescue operation team in the human

50
trafficking area is bribe and making maximum money out of
it by the team members ignoring the basic principles of
social work and principles of Natural Justice, which spoils
the possibility of combating the menace of human
trafficking. Rescue team involves in the event of gang rapes
and sexual abuse of the victims, encourages the human
trafficking and discourages rehabilitation and reform of the
victims.
(liv) That the technologies used in this sex racket is unique and
unavailable with common mass. This technology is used
either by Defense organizations or by International terrorist
organizations.
(lv) That the main sex racketeers for running this technology
based illicit sex trade, hidden prostitution, child sexual
abuse, have been figured out by the petitioner as Mr. Om
Birla, Chairperson and Speaker of Lok Sabha, Indian
Parliament and Capitalist business man Mr. Mukesh
Ambani R/O Zam Nagar district Gujrat.
(lvi) That sex abusers political parties and leaders have been
figured out by the petitioner who have deliberately
exploited and ruined this region for their own vested
political interests. The names are like Bhola Bishwas R/O
Kadwa, Advocate Asabuddin Obessi R/O Haydrabad,
Tariqe Anwar R/O Munger, Sahnabaj Hussain R/O
Kishanganj, Dr. Shakeel Ahmad Khan R/O Semapur
Katihar, Dulal Chand Goswami R/O Barsoi, Nikhil

51
Chaudhry R/O Katihar, Himraj Singh R/O Sonaili, Bhola
Rai R/O Sonaili, Giriraj Singh R/O Begusarai, Pappu Yadav
R/O Purnea, Suraj Bhan Singh R/O Mokama, Tarkeshwar
Prasad R/O Katihar, Jayant Sinha R/O Patna, Rakesh Sinha
(RSS) R/O Begusarai, Chirag Paswan R/O New Delhi and
Bakhri Khagaria, Bihar, Sibu Shoren R/O Jharkhand, son of
Sahabuddin R/O Siwan Ashok Agarwal R/O Katihar etc.
(lvii) That petitioner has emailed signed copies of complaint
along with daily SMS alarm for gang rape locations w.e.f.
06.05.2022 to till date to all nodal police officers of Bihar,
NCT of Delhi and Secretary Ministry of Home Affairs,
Prime Minister Office, Hon’ble Chief Justice of India office
at Supreme Court of India at New Delhi. In spite of that
Gang Rape, DJ Dance, illicit sex trade, hidden prostitution,
child sexual abuse continued by the rescued victims of gang
rape, hidden prostitution and child sexual abuse at the
source point of human trafficking at the tune of gun fire by
muscle man every day and night w.e.f. 06.05.2022 to till
date.
(lviii) That in spite alarm to all nodal police officers and child line
NGOs across country; petitioner is being attacked by a
women human trafficker. She dragged and broke his shirt’s
button and managed to escape the victims. Child line team
member sumit kumar again has given safe passage to the
human trafficker. The victim of child sexual abuse and
Gang Rape is being again trafficked. Human Trafficker was
able to do this job with an active help of a group of human
trafficker in presence of Sumit Kumar, Team Member of

52
Child Line Katihar in front of India Family Mart Mall
Katihar on 23.05.2022 at around 11:00 AM. The petitioner
alarmed the same to all nodal police officers of NCT of
Delhi and Bihar through SMS.
May
(lix) That on 24.05.2022 at 19:00pm “victim
not handed over, artificial rain caused for gang rapes and
illicit sex trade at Mahmood Chowk D.S. College katihar,
khatu shyam, argara chowk, hotels of katihar inside toilet,
power engine, driver’s cabin of local trains, RPF room,
RMS room, SSE LOCO Office at plat farm no.03, inside
bed roll room, canteen room at plat farm no.03 katihar
railway station. At 10:00pm “victims trafficked back by
traffic rail Police from katihar to sonaili P.S. Kadwa
through bullet bike or other vehicles near to kapil dev
mahto’s house, Dhruv Razak & other hot spot areas of
sonaili” for gang rapes”.
(lx) That on 25.05.2022 at around 11:00 AM a group of human
traffickers and sex abusers like ravi rai s/o ambika rai, ram
chander sahni, wife of lakhan sahni, gultan sahni neighbors
from eastern side attacked the applicant with vulgar abuse
and pelted stone at him and on his roof where he was
standing to keep vigil on his victim minor daughter’s

53
activities hidden inside the house of Dhruv Razak S/o Ram
Narayan Razak VRS employee from railway katihar. He is
northern end neighbor of applicant. That the applicant
watched the event of gang rapes till 11:45AM. At 12:00pm
“victim is inside Dhruv Razak, Rupak Raazak, Ravi Razak,
Ritesh Razak, Sonu, Monu S/O Grand/S/O late Ram
Narayan Razak house at shukkar hatt sonaili, P.S. Kadwa,
traffic rail police dropped her here in the night for Gang
Rape and illicit sex trade, watched till 11:45 AM, thereafter
trafficked by human trafficker for further sexual abuse”.
“victim’s new born baby’s body packed by Bechan Poddar
and his family in white plastic bag to hide identities or keep
her inside house”.
May
(lxi) That on 26.05.2022, aggrieved by the delinquent behavior
of Pradeep Kumar child line coordinator katihar and
persistent gang rapes illicit sex trade of victims
every day and night, the applicant has registered a fresh
complaint with NCPCR vide 202200004897 and with child
line vide 20220526122245 dated 26.05.2022
May

54
(lxii) That on 27.05.2022 at 08:44 am “there is a plan to ignite
katihar bihar for communal violence in the pretext of gang
rapes and illicit sex trade of petitioner’s hindu families
members by 46% muslims in this region. Wanted to make
katihar bihar as seelampur north east delhi. The victim of
gang rape and illicit sex trade herself approached the
petitioner at plat farm no.02 katihar railway station at
02:00pm dated 27.05.2022 in the pretext of enquiring
Araria district bound train at Katihar Railway Station. She
was in black burka garment dresses along with two beggar
women. petitioner immediately identified the victim and
rang the Commissioner of Police Delhi Head Quarter to
intervene into the matter of human trafficking at source
point Katihar railway station, stop them from trafficking to
Araria Nepal boarder, raid, rescue and hand over the
victims to the applicant immediately. Instead of rescue,
Commissioner Police Delhi along with DGP Bihar
organized gang rapes of the victims.
complaint against sex abusers state through
email letter dated 28th
May 2022 by
petitioner to all nodal police officers of
Bihar and NCT of Delhi is annexed herein
as Annexure P- 20 (Page from 92 to 93)

55
(lxiii) That on 28.05.2022 at 19:30 pm “Lock
of the main gate of Asha Deep Niwas, Sonaili village, P.S.
Kadwa is being broken by the sex abusers and organized
gang rapes of the victims inside the house premises of
applicant. Hidden prostitution and illicit sex trade at
neighbor Bechan Poddar’s house. He is doing so by opening
window towards petitioner’s house premises. Situation is
violent at Asha Deep Niwas, Sonaili village, P.S. Kadwa,
Katihar Bihar.
email letter dated 29th
May 2022 by
(lxiv) That on 29.05.2022 at 06:01am “illicit sex trade, hidden
prostitution, child sexual abuse and human trafficking by
the surrounding neighbors around petitioner’s house at
Asha Deep Niwas, Sonaili village, P.S. Kadwa, Katihar
Bihar since 18 years. Petitioner’s 50 siblings, sister in laws
and their respective children including his wife, minor
daughter hijacked and pushed into this business. Raid,
rescue, medical and charge sheet before court of law
otherwise petitioner will move against Bihar Police and
Delhi Police before Supreme Court of India with fresh Writ
criminal case within one or two days, Om Prakash poddar,
social worker to all the nodal police officers of Delhi and

56
Bihar.
(lxv) That on 30.05.2022 control room 9431602302 and DGP
Bihar 9431602301 being informed at 19:00pm for the
possibility of gang rape tonight yet sex abusers SHO Kadwa
along with Indian Army approached the petitioner at his
house at around 21:20pm at Asha Deep Niwas, Sonaili
village Katihar misbehaved and gang raped his minor
daughter and all his family members disconnecting whole
village electricity continuously throughout the night.
(lxvi) That on 30.05.2022 at 08:09am, petitioner has sent an SMS
to all nodal police officers of Bihar and Delhi, “Stop
persistent gang rapes of victims because gang rape is
continued presenting illegal/false documents by magistrate
of katihar Rail police. RPF, DRM Katihar, Katihar
administration, Katihar police, NGOs, INGOs, women
commission, social workers, general public and indian
defense organizations misusing government resources for
trafficking and organizing gang rapes, illicit sex trade, child
sexual abuse, and human trafficking”
(lxvii) That on 31.05.2022 at 05:30am, petitioner has sent an SMS
to all nodal police officers of Bihar and Delhi,
”communicate through petitioner’s email id:
om.poddar@gmail.com only/No phone calls in connection
with any queries related with victims re-pushed into the
same business of flesh trade at the source point of human
trafficking at sonaili katihar, Bihar. Rescued by the order of

57
supreme court of india dated 02.05.2022 in W.P. (Criminal)
137/2021 and W.P. (Criminal) 242/2021. Om Prakash
Poddar, Social Worker.
(lxviii) That on 31.05.2022 at 08:30am, petitioner has sent an SMS
to all nodal police officers of Bihar and Delhi, “if state will
kill victims of gang rapes and save gang rapists then I will
ensure capital punishment for the corrupt organs of state till
my death”.
(lxix) That on 31.05.2022 at 09:02am, petitioner has sent an SMS
to all nodal police officers of Bihar and Delhi, “planning to
kill victims today to save rapists by state of Bihar. Stop foul
play of state. If single victim killed then ready to face
capital punishment. Om Prakash, social worker ”.
(lxx) That on 31.05.2022 at 10:53am, petitioner has sent an SMS
to all nodal police officers of Bihar and Delhi, “victim
sexually abused inside power engine of telta passenger train
to katihar at sonaili railway station by station master and
others”.
(lxxi) That despite of receiving information disclosing cognizable
offence of gang rapes inside the katihar bound telta train
from sonaili railway station to Dandkhora railway station to
unnecessarily stopping at outer signal near to K.B.Jha
college, SHO Katihar Rail, Jyoti Prakash and SP Katihar
Rail Avinash Kumar did not bother to come at plat farm no.
01 of katihar railway station to raid and rescue the victims

58
of gang rapes rather given safe passage to sex abuser,
human trafficker, driver of Telta Passenger train at 11:45
AM on 31.05.2022. Petitioner is being attacked by sex
abusers railway staff as well as by the general public at
Dandkhora Railway station for monitoring the activities of
sex abusers inside power engine of Telta passenger train at
11:00 AM on 31.05.2022. Protest events being organized
by the petitioner in front of power engine of driver and
driver of the train called on RPF security and Dandkhora
Railway Station Master through his official wireless mobile
set on the same day.
(lxxii) That despite of receiving information disclosing cognizable
offence of possibility of gang rapes on 31st
May 2022 night,
Gang Rapes of his families continued for consecutively 27
days after their rescue from Delhi at the source point of
human trafficking at Sonaili Village, P.S. Kadwa, Katihar,
disconnecting the electricity of the whole village in the
night of 31st
May 2022.
email letter dated 31st
May 2022 by
(lxxiii) That applicant has noticed in the morning of 1st
June 2022
that the locker/Almira of his bed rooms containing valuable

59
assets like original property papers, jewelries, ornaments
being looted unlocking the same. That wife and minor
daughter do not have any interest in his material items
because the applicant himself offered them all movable and
immovable assets of Bihar in 2004-2005 but she denied
taking even a single paisa/Penney from him. That this
heinous work is done by the sex abusers, human traffickers,
State+NGOs+Gangsters+Mafia+Indian Defense
Organizations and +general public who have made the
victims of gang rapes as their hostage and kept them in their
custody for sexually abusing them and generating revenue
out of it. That the life of applicant has been saved yesterday
night either by some honest agencies or by his abducted
wife (in 2005 by sex racketeers) and minor daughter. Delhi
police and Bihar Police have been informed to register an
F.I.R
email letter dated 1st
June, 2022 by
(lxxiv) That victim herself called on the applicant from the
mobile number of Child Line Samastipur, Bihar
9523911098 and enquired/confirmed about the address of
applicant for help to avoid planned gang rapes, child sexual
abuse and illicit sex trade in the night of 01.06.2022 at

60
3.10 PM on the eve of International Children’s Day
repeatedly while he was busy in e-filing a case before
Supreme Court of India from Katihar Railway Station.
(lxxv)That the applicant noticed that in retaliation of e-filing of
case on 01-06-2022 victims are being tortured and
trafficked by local passenger train from katihar and dropped
and sold at different places from katihar to Siliguri by Child
Line Kolkotta, katihar, Samastipur, SP Rail Katihar, SP
civil Katihar, DRM Katihar and district administration
Katihar. Applicant noticed in the evening 7:30pm of 01-06-
2022 at sonaili railway station that imported car, auto, toto
riksaws, bike, traffic police bullet and other vehicles are
being used for carry out and selling out the victims at
Sonaili, P.S. Kadwa. One auto carrying victims came in
front of the main gate of the house of the applicant for illicit
sex trade. Applicant blasted on pimps and brokers of
victims on 01-06-2022 at around 9:00pm.
(lxxvi) That applicant has sent an SMS alert on 01.06.2022 at
22:02 pm “Will you not STOP gang rapes of victims? Will
you not keep them in women’s shelter homes till the matter
listed and heard by Supreme Court of India?” to all the
nodal police officers of Delhi and Bihar.
(lxxvii) That thereafter the gang rapes organized by the child
line Samastipur with an active help of state administration
in the vicinity/household of neighboring dwellers of
applicant at Sonaili P.S. Kadwa like Chand Hotel, Zoren
Sah Begali house, Surender Singh’s house etc. The

61
applicant has sent an SMS alert on 01.06.2022 at 23:36 pm
“victim called by 9523911098 at around 2pm and being
gang raped in sonaili p.s. kadwa tonight. Register F.I.R
against human trafficker and sex abusers child line
samastipur” to all the nodal police officers of Delhi and
Bihar.
(lxxviii) That thereafter applicant has called DGP Bihar
Control room at 23:22pm and SHO Kadwa at 23:37pm on
01-06-2022 night and informed the same for registration of
an F.I.R because neither Delhi Police nor Bihar Police is
registering an F.I.R against the numerous complaint made
by the applicant since 2005 to till date.
(lxxix) That applicant has identified more than 100 hotspots
in the State of Bihar, State of West Bengal and neighboring
border countries of Nepal and Bangladesh.
(lxxx)That applicant has sent an SMS alert on 02.06.2022 at 10:21
am “I will ensure capital punishment for you for continuing
gang rapes of rescued victims presenting false and
fabricated documents consecutively 28 days and generating
revenue out of it ” to all the nodal police officers of Delhi
and Bihar.
(lxxxi) That applicant has sent an SMS alert from the local
passenger train on 02.06.2022 at 11:18 am “gang rapes,
child sexual abuse and illicit sex trade in the pretext of
jurisdictions is over. Siliguri passenger from katihar and
telta passenger from telta to katihar have been identified as

62
carrier of human trafficking and illicit sex trade for
dropping and picking up victims at several places and
collecting money out of it. Stop or become party before
Supreme Court of India ” to all the nodal police officers of
Delhi and Bihar.
(lxxxii) Stop foul play by child line kolkotta regional centers,
director national child line indian foundation mumbai,
chairperson ncpcr, the state of bihar and others, raid, rescue,
medical, arrest, cahrgesheet and place before the court of
law/juvenile court under relevant sections of relevant acts
like pocso or any other relevant acts immidiately. provide
night shelter homes for women victims and observation
homes for children victims and allow applicant to meet the
victims.
True copy of signed copy of police complaint
against sex abusers state through email letter
dated 2nd
June, 2022 by petitioner to all nodal
police officers of Bihar and NCT of Delhi is
annexed herein as Annexure P- 24 (Page
from 100 to 101)
(lxxxiii) That Justice S.B. Sinha of Supreme Court of India is
the first point to spoil the wife of applicant thereafter by
others. Applicant is F.I.R against him since 2011, number of
petitions have been filed against him before Supreme Court
of India since then by applicant and his deceased mother but
no action taken against him.

63
(lxxxiv) That applicant’s minor daughter has been gang raped
at J.N.U New Delhi on 26.05.2022 and 27.05.2022; the
same has been informed by J.N.U administration New Delhi
with a public notification at Facebook.
(lxxxv) That Magistrate of Katihar has done mischief by
transferring the case from Delhi to Bihar with an active help
of Supreme Court of India deliberately with an ulterior
motive for sustaining gang rapes, child sexual abuse and
illicit sex trade of the rescued victim at the source point of
human trafficking at Katihar district in Bihar.
(lxxxvi) That applicant had prior information about planned
gang rapes of the rescued victims in the night of 02.06.2022
at sonaili and different places. He got this information by
sex abusers and human trafficker’s mobile no. 9953017092
at 03:41PM on 02.06.2022.
(lxxxvii) That thereafter Ms. Indu Sinha R/O Binodpur, Katihar
a pimp and head of sex racket in katihar district has been
seen at Katihar Railway Station for arranging, directing and
running illicit sex trade at Katihar railway station inside the
toilet, compartment, and power engine of train and inside
other hide outs of Katihar Railway property.
(lxxxviii) That thereafter applicant has noticed a suspected case
of sexual abuse of female, part of rescue team by Bihar
Police inside the Siliguri passenger just close to DMU
power engine.

64
(lxxxix) That applicant has sent an SMS alert on 02.06.2022 at
07:00 pm “sex abuser, human trafficker called by
9953017092 at 3pm to inform about planned gang rapes of
victims tonight” to all the nodal police officers of Delhi and
Bihar.
(xc) That applicant has sent an SMS alert on 03.06.2022 at 06:00
am “sex abuser, Ms Indu Sinha R/O Binodpur, Katihar and
others have organized yesterday (2.6.22) night gang rapes
of victims. Register F.I.R” to all the nodal police officers of
Delhi and Bihar.
(xci)That applicant has sent an SMS alert on 03.06.2022 at 08:03
am “sex abuser, Tinku Mandal S/O Kishandev Mandal R/O
Tilas P.S. Dandkhora just at 7:15 am came after complaint
against Ms Indu Sinha R/O Binodpur, Katihar and others to
attacked and tried to kill me at my residence Asha Deep
Niwas, Sonaili, Katihar, Bihar-855114. Rang phone of SHO
Kadwa, SP Katihar, DIG Purnea, IG Darbhanga, Control
Room DGP Bihar but no one picked up and responded for
help ” to all the nodal police officers of Delhi and Bihar.
(xcii)That applicant has sent an SMS alert on 03.06.2022 at 10:17
am “victim of gang rapes dropped at Dandkhora station
master’s cabin by siliguri passenger in the morning;
trafficked by road to sonaili or katihar ” to all the nodal
police officers of Delhi and Bihar.

65
(xciii)That the applicant is eye witnessed of the heinous act of
Sinha families in dormitory of Laxmi Narayan Dharmshala,
Church Road, Fatehpuri, Old Delhi Railway Station from
25.04.2022 to 04.05.2022. Mukesh Sinha and his female
family members, Dr. Shakkel Ahmad Khan, MLA Kadwa,
Talib Khan ranged the applicant number of times to
withdraw or to transfer the case from Delhi to Bihar.
Gangster, Son of Sahabuddin, wife and his minor daughter
R/O Siwan Bihar stayed at Laxmi Narayan Dharmshala just
close to applicant bed in dormitory from 25th
April to 4th
May 2022 and monitored, kept surveillance on the activities
of applicant, invited sex abusers, human traffickers for
applicant’s families from different parts of country like
surat, ahmadabad, Mumbai, Orissa, Punjab, Varanasi, bihar
etc. Gang raped his families in front of his own eyes inside
the toilet and other rooms of Dharamshala thereafter killed
some of them by exchanging a deal with RSS workers of
Varanasi, shooter and killers invited. Team of expert
doctors also invited for killing. CCTV footage, if not
deleted till date, will be testimony of his act.
(xciv) That Sinha family is a big threat to the National Security
and National progress. Indian history is witnessed of this
fact that this community has hijacked all the constitutional
institutions of the country for their own vested interest since
independence.
(xcv)That it is pertinent to mention here for your information that
Commissioner of Police Delhi has diaries 13 complaint
against out of 29 complaints made so far. Applicant has

66
filed Interlocutory application for impleadments or
interventions on 30.04.2022 before Supreme Court of India
in W.P. (Criminal) 137/2021 to make it National
jurisdictions.
(xcvi) It is submitted for your information that Affidavit for
International Sex Racket has been filed before Supreme
Court of India in W.P. (Criminal) 137/2021 and the same
has been tagged with W.P. (Criminal) 242/2021. Violence
against Women, Gang Rapes of women and children are not
restricted to the nitty gritty of jurisdictional technicalities.
(xcvii) Stop this criminal crook sinha bugs from ruining the
basic fabric of the country, raid, rescue, medical, arrest,
cahrgesheet and place before the court of law/juvenile court
under relevant sections of relevant acts like pocso or any
other relevant acts immidiately. provide night shelter homes
for women victims and observation homes for children
victims and allow applicant to meet the victims.
True copy of signed copy of police complaint
against sex abusers state through email letter
dated 3rd
June, 2022 by petitioner to all nodal
police officers of Bihar and NCT of Delhi is
annexed herein as Annexure P- 25 (Page
from 102 to 103)
(xcviii) That Katihar administration and state of Bihar and others
have tried to obstruct the way of applicant from reaching

67
Supreme Court of India on 05.06.2022 at 5:45PM
(xcix) That on 06.06.2022 at 17:14 pm “human trafficker/sex
abuser Mofidul Islam R/O Morigaon, Assam mobile no.
7356008554 in S-1 Coach of North East Superfast express
train caught trafficking petitioner’s minor daughter and
planned to organize gang rape at Leela Hotel New
Delhi/Anand Vihar Railway Station or any other places in
Delhi/NCR along with “Safe Shop company” Janakpuri,
New Delhi team. Informed to SHO Palam Village New
Delhi and SHO Shastri Park North East Delhi. She has been
seen with a male baby at her lap. However, Delhi Police has
given safe passage to Human trafficker to traffic minor
daughter of petitioner on 06.06.2022 at 22:30pm from
Anand Vihar Railway Station Delhi.
(c) That commissioner of police Delhi has allocated an enquiry
officer Ms. Pratima against the petitioner’s email complaint
no. 817104012203108 dated 25.05.2022, 801012232364
dated 17.05.2022, 801012232732 dated 19.05.2022,
801012233608 dated 23.05.2022, 801012232268 dated
17.05.2022, 817104012203159 dated 26.05.2022.
(ci) That Commissioner of Police, Delhi has supplied telephone
number 011-23746100 extension no. 69504, 69505, 69804
and 69805 with following diary numbers diaried against the
complaint of petitioner w.e.f 07.05.2022 to till date

68
a) D.NO. 33113 email dated 11.05.2022,
b) D.NO.33104 email dated 11.05.2022,
c) D.NO.33340 email dated 12.05.2022,
d) D.NO.33808 email dated 13.05.2022,
e) D.NO.34461 email dated 17.05.2022,
f) D.NO.34301 email dated 17.05.2022,
g) D.NO.34964 email dated 17.05.2022,
h) D.NO.35276 email dated 18.05.2022,
i) D.NO.35441 email dated 19.05.2022,
j) D.NO. 35479 email dated 19.05.2022,
k) D.NO.35598 email dated 19.05.2022,
l) D.NO.35603 email dated 19.05.2022
m) D.NO.36354 email dated 23.05.2022
All the above 13 complaints out of 29 complaints made by
the petitioner w.e.f 07.05.2022 to till date have been diaried
by Commissioner of Police Delhi against the grievances of
persistent Gang Rapes of rescued petitioner’s families at the
source point of human trafficking at Katihar district of
Bihar.
(cii) That Home Secretary, Shri Ajay Kumar Bhalla forwarded
petitioner’s email to Joint Secretary Ms. Saheli Ghosh Rooy
on 31.05.2022 and she in turn forwarded the same to

69
Additional Chief Secretary Home Department Government
of Bihar Shri Arun Kumar Dhyani on 31.05.2022 and he in
turn forwarded the same to the Chief Secretary Bihar on
01.06.2022 and Chief Secretary Bihar diaried the
petitioner’s email with reference number 3191 dated
03.06.2022 and forwarded the same again to Additional
Chief Secretary Home Department Government of Bihar
Shri Arun Kumar Dhyani for necessary action please. This
email of petitioner contains Order dated 09.02.2011 in
HMA-700/2010 of Family Court, Dwarka Court at New
Delhi; case related to victim wife Rina Kumari and snaps
related to victim minor daughter Shriya Poddar
(i) That ironically this all are happening within the knowledge
of Prime Minister Office, Ministry of Home Affairs,
President of India House and Hon’ble the Chief Justice of
India, Supreme Court of India.
2. QUESTION(S) OF LAW:
a) Whether or not Police Complaint along with daily SMS alert
of location of Gang Rapes, illicit sex trade, hidden
prostitution, child sexual abuse made against the rescued
victims w.e.f. 06.05.2022 to till date to all nodal police
officers of Bihar and NCT of Delhi is a cognizable offence
and attracts an F.I.R including arrest of the accused?

70
b) Whether or not the malfunctioning of NCPCR and doubtful
intervening strategy of ChildLine India Foundation Delhi is
questionable in this case of child prostitution also?
c) Whether or not NCPCR and ChildLine India Foundation,
Kolkotta have deliberately ignored the inputs, facts,
circumstances, apprehensions, observations, analysis,
recommendations, nature and dynamics of the case
illustrated by the petitioner in the complaint with an ulterior
motive to suppress the matter and spoil the minor girls for
their own vested interest?
d) Whether or not consent for sexual abuse and hidden
prostitution in minor case is immaterial in the eyes of law?
e) Whether or not NCPCR, ChildLine India Foundation Delhi,
North East Delhi Police and Special Juvenile Police Unit
(SJPU) have violated the provisions under section 30(xiii) of
Juvenile Justice Act 2015, Rule 4(2) (c), Rule 4(3), Rule
4(4), Rule 4(5), Rule 5 & section 19(5), section 19(6) and
section 25 of the POCSO Act 2012?
f) Whether or not NCPCR and ChildLine India Foundation
Delhi should submit a complete road map of intervention
process adopted in this case including methodology,
procedure, selection of intervening team, location of
intervening team, quality of intervening team members,
steps taken and action taken report before this Hon’ble Court
in the larger interest of children across the country?

71
g) Whether or not NCPCR has shown it’s by standard apathy
and inertia to intervene in this case and deliberately
continued the gang rape, illicit sex trade, hidden prostitution
and child sexual abuse of rescued victims persistently at the
source point of Human Trafficking.
h) Whether or not rampant unlawful detention of whistle
blower petitioner by the Bihar Police as well as Delhi Police
is an evident of this fact that the matter of hidden prostitution
and child sexual abuse has been suppressed for their own
vested interest?
i) Whether or not it is the matter of grave concern for all
children across the country?
j) Whether or not the matter is absolutely interlinked with
source point at Sonaili P.S. Kadwa Katihar and transit or
destination point at Shastri Park, North East Delhi in the area
of International Human Trafficking?
k) Whether or not victim minor girls and daughter of petitioner
to be rescued, rehabilitated and initiated handing over
process to the petitioner till the investigation team
constituted by this Hon’ble Court or the investigation/court
process resumes and completes?
3. GROUNDS:
That being aggrieved by the abuse of Bihar and Delhi police
power, no F.I.R or ATR against the unlawful detention of
whistle blower petitioner at the midnight of 25th
April, 2021 in

72
Shastri Park Delhi and night of 20th
May 2022 by SHO and SI
Binod Singh Kadwa, Katihar violation of provisions under
section 30(xiii) of Juvenile Justice Act 2015, Rule 4(2) (c),
Rule 4(3), Rule 4(4), Rule 4(5), Rule 5 & section 19(5), section
19(6) , section 25 of the POCSO Act 2012 and malfunctioning,
doubtful intervening strategy dated 13.04.2021 and 17.04.2021
by NCPCR and ChildLine India Foundation Delhi and
Kolkotta, the petitioner is challenging the same on the
following amongst other grounds: -
A. BECAUSE this business is run by the nexus of States,
NGO, Gangsters, Mafia and Indian Defense
Organizations therefore re-pushed the victims of gang
rape, illicit sex trade, hidden prostitution, child sexual
abuse, human trafficking at the source point of human
trafficking and not handed over them to the petitioner for
reform.
B. BECAUSE re-pushing the victims into the same flesh
trade goes against the principle of Social Work and Rule
of Law/Human Rights.
C. BECAUSE petitioner has not been allowed to know
where about of the victims and to meet the victims w.e.f
06.05.2022 to till date by the state, human traffickers,
sex racketeers and sex abusers.
D. BECAUSE Victims have not been rehabilitated by the
state rather re-pushed into the same business of flesh

73
trade and not initiated the handing over process by the
state to the petitioner till date.
E. BECAUSE no F.I.R has been registered either by
Bihar Police or by Delhi Police since 2004 and
particularly since 06.05.2022 after their rescue from
different brothels of India.
F. BECAUSE matter pertains in the larger public
interest.
4. AVERMENT
i) That the present petitioner has not filed any other
petitions in any High Court but filed W.P. (Crl.)
137/2021 and W.P. (Crl.) 242/2021 before the
Supreme Court of India on this subject matter of
the present petition.
ii) That the Petitioner does not have any alternative
and efficacious remedy for enforcement of his and
victims fundamental rights.
PRAYER
In the above premises, it is prayed that this Hon'ble Court may be
pleased:
(i) To issue a writ of mandamus or other appropriate writ order
or direction directing respondent No.01, 02, 03, 05, 06, 07,
and 08 to register an F.I.R against the complaints of
petitioner made since 2011 to till date and to investigate into

74
the persistent gang rapes of the victims at the source point of
human trafficking at Sonaili Katihar Bihar, rescued from
illicit sex trade and child sexual abuse from
destination/transit point of human trafficking at Sashtri Park
North East Delhi and the rampant abuse of police power
against the petitioner as well as against the victims and direct
to register an F.I.R under relevant sections of IPC against the
accused rapists of persistent gang rapes, illicit sex trade,
hidden prostitution, child sexual abuse, human trafficking of
rescued victims by the nexus of states, NGOs, Gangsters,
Mafia and Indian Defense Organizations and to be
monitored by issuing a necessary direction to the District
Judge and SHO to investigate the matter impartially, fairly
and properly including the arrest of the accused, after the
registration of F.I.R.
(ii)To issue a writ of mandamus or other appropriate writ order
or direction directing respondent No.01, 02, 03, 05, 06, 07,
and 08 to pass a dismissal order against the lady magistrate
Katihar, accompanying with the petitioner in W.P.(Crl)
242/2021 and W.P.(Crl) 137/2021 for placing illegal, false
and fabricated documents to this Hon’ble Court to transfer
the case from Delhi to Bihar and taking unauthorized
custody of the rescued victims with an ulterior motive of re-
pushing them into the same business of flesh trade for
generating revenue out of it.
(iii) To tag all petitions W.P.(Crl) 136/2016, W.P.(Crl)
137/2021 and W.P.(Crl) 242/2021 together with this petition
in the furtherance of justice.

75
(iv) To issue a writ of mandamus or other appropriate
writ order or direction directing respondent No. 03 and 15 to
direct respondent no. 16 and 17 to resume the electricity
services of the house of the petitioner immediately.
(v)To issue a writ of mandamus or other appropriate writ order
or direction directing respondent No. 03 to direct respondent
no. 04, 18, 19, 20 and 21 to investigate into the lapse of
medical services by Primary Health Centre Kadwa
Durgaganj and Sadar Hospital Katihar, for injecting
inappropriate injections into the body of petitioner, taking
unauthorized blood sample of petitioner on 12.05.2022
injuring internally and snatching his medical prescription
and daily diary from his hand on the same day and date to
evade the evidence.
(vi) To issue a writ of mandamus or other appropriate
writ order or direction directing respondent No. 01 to direct
respondent no. 32, 33 and 34 to investigate into the matter of
not handing over the victims to the petitioner and re-pushing
the rescued victims into the same business of flesh trade,
gang rapes, illicit sex trade, hidden prostitution, child sexual
abuse and human trafficking at the source point of human
trafficking at Sonaili Katihar, Bihar.
(vii) To issue a writ of mandamus or other appropriate
writ order or direction directing respondent No. 01 to direct
respondent no. 35 to investigate into the matter of misuse of
defense telecommunication technologies, misuse of Air base
for human trafficking, the victims of gang rape from one

Writ Petition Criminal Diary Number 18546 of 2022 Part-I .pdf

Writ Petition Criminal Diary Number 18546 of 2022 Part-I .pdf

Writ Petition Criminal Diary Number 18546 of 2022 Part-I .pdf

Writ Petition Criminal Diary Number 18546 of 2022 Part-I .pdf

Recomendados

Más contenido relacionado

Similar a Writ Petition Criminal Diary Number 18546 of 2022 Part-I .pdf

Similar a Writ Petition Criminal Diary Number 18546 of 2022 Part-I .pdf(20)

Más de Om Prakash Poddar

Más de Om Prakash Poddar(20)

Último

Último(9)

Writ Petition Criminal Diary Number 18546 of 2022 Part-I .pdf