District
: South 24 Parganas.
In
the Court of the Learned Additional Chief Judicial Magistrate, at Alipore,
South 24 Parganas.
Complaint
Case no. ________of 2013.
In
the matter of :
An application under Section
200 of Criminal Procedure Code’ 1973;
A N D
In the matter of :
Shri Swapan Kumar Ghorai, Son
of Late Annidya Prosad Ghorai, residing at Village – Gangarampur, Post vOffice
– Dakshin Alipore, Police Station – Bishnupur, District – South 24 Parganas.
____Complainant.
-
Versus
–
Shri Rintu Mitra, Son of Shri Pradip Mitra, residing at Village –
Dukrijhara, Police Station – Ramnagar, District – South 24 Parganas.
_________Accused.
The humble petition of the
above named Complainant Shri Swapan Kumar Gharai, most respectfully;
Offence
committed to be punishable under Section 182, and 500, of the Indian Penal
Code’ 1860.
Sheweth
as under :
1.
That
the Complainant is a peace loving and law abiding Citizen, used to reside at
the address as given in the cause title of this application, which well fall
under the jurisdiction of the
2.
That
the Complainant is an eminent researcher in the field of medical science, who
invent the medicines and the procedure of treatment about CANCER and
successfully reached his object to cure CANCER
and whereas his such achievements has been published in several Journal
of Medicine as well as in the daily news papers.
3.
That
the Complainant is a Doctor by profession and has done for society in many ways
and thus the Complainant is a morally strong and prevail the moral values and
devoted to the society for the welfare.
4.
That
the accused person Shri Rintu Mitra, Son of Shri Pradip Mitra, residing at
Village – Dukhrijhara, Police Station – Ramnagar, District – Soputh 24
Parganas, is a Son in Law and husband of your petitioner’s daughter Smt. Rupsa
Mitra.
5.
That
on 15-09-2012, the accused person lodged distorted facts with the Ramnagar
Police Station, and thereby the said Police Station started One Criminal Case
being Ramnagar Police Station Case no. 96 of 2012, dated 15-09-2012, under
Section 365, 367, 368, 324, 325, and 379 of the Indian Penal Code’ 1860,
against your petitioner and his driver Bapi @ Sk. Rafik.
6.
That
the said Ramnagar Police Station Case no. 96 of 2012, dated 15-09-2012, has
been started before the Learned Additional Chief Judicial Magistrate, at Diamond Harbour, South 24 Parganas, and
whereas your petitioner and his driver, surrendered before the Learned Court
and released on bail.
7.
That
during the investigation one 164 of CR.P.C. statement has been recorded of the
daughter of your Petitioner Smt. Rupsa Mitra, and one affidavit of the accused
person has been filed before the Learned Court, whereby it has been established
that the allegations made by the accused person in the said Ramnagar Police
Station case no. 96 of 2012, are frivolous and vexious.
8.
That
the Police of the Ramnagar Police Station investigated the said case of the
accused person and finally submitted FRT as the allegations of the accused
person did not corroborate with the actual facts, vide FRT no. 85 of 2012,
dated 30-09-2012, and whereas subsequently, the Learned Court accepted the said
FRT and discharged your petitioner from the said case matter, on 27-12-2012.
9.
That
during investigation of the said case matter, vehicle of your petitioner was
taken into custody by the Police, and subsequently released upon the due
intervention of the
10.
That
the accused person given false information, with intent to cause police to use
his lawful power to the injury of your petitioner and for such reasons alone
your petitioner was harassed at the instances of complaint lodged by the
accused person against your petitioner.
11.
That
the accused person defame your petitioner intending to harm, and or knowing or
having strong reason to believe that such imputation will harm, the reputation
of your petitioner, and whereas your petitioner is a victim of the purported
act of lodging false complaint by the accused person, upon which the Police
started case and investigated and during investigation police visited on
several occasion at the house and working place of your petitioner and also
taken the custody of vehicle of your petitioner and further more the driver of
your petitioner was also implicated in false allegations by the accused person,
and whereas more particularly the allegations made by the accused petitioner
was related to very heinous crime, and related to moral turpitude, and for the
said reasons alone, your petitioner is a victim of purported purposive activities
of the accused persons and suffer with irreparable loss and injury.
12.
That
thus the accused person committed offences punishable under Section 182 and 500
of the Indian Penal Code’ 1860.
13.
That
your petitioner crave leave to produce all the relevant documents and or papers
at the time of hearing of the case matter before the
14.
That
this application is made bonafide in the interest of justice.
It is therefore prayed that
your Honour would be graciously pleased to allow this application under Section
200 of Cr. P. C. and issue process upon the accused person, try and punish him
for the offence committed to be punishable under Section 182 and 500 of the
Indian Penal Code’ 1860, and / or to pass such other necessary order or orders
as your Honour may deem, fit, and proper, for the end of justice.
And
for this act of kindness, your petitioner as in duty bound shall ever pray.
Witnesses
:
a.
Complainant,
b.
Bapi
@ Sk. Rafick,
c.
Smt.
Rupsa Mitra,
d.
Certified
copy of FIR no. 96 of 2012.
e.
Certified
copy of Written Complaint dated 15-09-2012.
f.
Certified
copy of the order sheet of the Ramnagar Police Station Case no. 96 of 2012.
g.
Certified
Copy of FRT no. 85 of 2012, dated 30-09-2012.
h.
Certified
copy of 164 statement of Smt. Rupsa Mitra.
i.
Certified
copy of Affidavit of Sri Rintu Mitra.
j.
Police
personnel and others.
k.
Other
person and persons.
l.
Other
documents and or papers.
Verification
I,
Shri Swapan Kumar Ghorai, being the complainant herein made this application
under Section 200 of Cr.P.C. and I am well conversant with the material facts
as stated in the forgoing paragraphs of this application, and I duly verify
this application as on _________2013, at Alipore, Kolkata.
Shri Swapan Kumar Ghorai.
Identified by me,
Advocate.
Prepared
in my Chamber,
Advocate.
Date
: ____________2013.
Place
: Alipore, Kolkata.
VAKALATNAMA
District : South 24-Parganas.
In the Court of the Learned Additional
Chief Judicial Magistrate, at Alipore, South 24-Parganas.
Case no.
______________of 2013.
Shri Swapan Kumar Ghorai, ___________Complainant.
- Versus –
Shri Rintu Mitra. ____________Accused.
KNOW ALL MEN by these presents that I / We Shri Swapan Kumar Ghorai, Son
of Late Annidya Prosad Ghorai, residing at Village – Gangarampur, Post vOffice
– Dakshin Alipore, Police Station – Bishnupur, District – South 24 Parganas,
do hereby constitute and appoint the under mentioned
Advocate, Pleader, Vakils, jointly and each of them severally to be pleader of
take such steps and proceedings as may be necessary on my / our behalf and for
that purpose to make sign, verify and present all necessary petitions, plaints,
written statements and other documents and do nominate and appoint or retain
senior counsels, vakil, advocates and other persons, lodge and deposits moneys
and documents and other papers in the Ld. Court and the same again withdraw and
to take out of Court and to obtain or grant as the case may be effectual
receipts and discharge for the same and for all moneys which may be payable to
me / us in the premises. To enter into compromise with my / our approval and
withdraw, all moneys from the court AND GENERALLY to act in the premises and proceedings
arising there out whether by way of execution, review, appeal, or otherwise or
in any manner contested there with as effectually and to all intents and
purpose as I / We could act if personally present and such substitution and as
pleasure to revoke I / We hereby ratifying and agreeing to confirm whatever may
be lawfully done by virtue hereof.
In
witness whereof this Vakalatnama has been executed by me / us.
This the …………………day of ………………2013.
Sri Ashok Kumar Singh, Advocate.
Sri Manoj Halder, Advocate.
Sri Sandip Roy Chowdhury, Advocate.
Sri Rabindra Nath Das, Advocate.
Sri Saheb Halder, Advocate.
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