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APPLICATION U/S 156(3)
CR.PC ON BEHALF OF THE ABOVE APPLICANT TO DIRECT THE SHO CONCERNED FOR
REGISTERING FIR UNDER RELEVANT SECTIONS OF INDIAN PENAL CODE, 1860 AND OTHER
RELEVANT PROVISIONS OF THE SCHEDULED CASTES AND TRIBES (PREVENTION OF
ATROCITIES) ACT, 1989, THE DELHI PUBLIC GAMBLING ACT, 1955 AND THE
NARCOTIC DRUGS AND PSYCHOTROPIC SUBSTANCES ACT, 1985 AGAINST THE ACCUSED
PERSONS NAMELY () FOR
RUNNING AN ILLEGAL RACKET OF GAMBLING AND NARCOTIC SUBSTANCES FROM THEIR HOUSE
AND FOR CRIMINALLY INTIMIDATING BY BRANDISHING A REVOLVER AND THREATENING TO
KILL THE WHOLE FAMILY OF THE  COMPLAINANT
WHEN ASKED TO DISCONTINUE THEIR NEFARIOUS ACTIVITIES IN THE SAID LOCALITY AND
ALSO FOR COMMITTING CASTE- CENTRIC ATROCITIES ON THE COMPLAINANT AND HER FAMILY
MEMBERS VIZ. HURLING OF CASTE NAME ABUSES WITH AN INTENT TO INSULT, HUMILIATE
AND INTIMIDATE WITHIN PUBLIC VIEW, THE COMPLAINANT AND HER FAMILY MEMBERS BY
CALLING THEM SANSI, CHUDA, CHAMAR, KANJAR, ETC INFRONT OF THE ENTIRE
NEIGHBOURHOOD AND WITH AN INTENT TO CAUSE INJURY DUMPING EXCRETA, WASTE MATTER
AND OTHER OBNOXIOUS SUBSTANCES INFRONT OF COMPLAINANT’S HOUSE AND ALSO FOR
INSTITUTING FALSE, VEXATIOUS AND MALICIOUS CRIMINAL PROCEEDINGS AGAINST THE
COMPLAINANT, HER HUSBAND AND SON BY MEANS OF PROVIDING FALSE AND FRIVOLOUS
INFORMATION TO POLICE THROUGH ONE RAJINDER [email protected] WHICH LED TO
INCARCERATION OF COMPLAINANT’S HUSBAND. THE AFOREMENTIONED ACCUSED PERSONS
BELONGING TO A SUPERIOR CASTE IS WREAKING HAVOC IN THE SAID LOCALITY AS THEY
CLAIM TO HAVE GOOD CONNECTIONS WITH THE HIGHER ECHELONS OF THE POLICE
DEPARTMENT DUE TO WHICH THE COMPLAINANT IS UNABLE TO GET HER FIR REGISTERED
UNDER THE RELEVANT PROVISIONS OF IPC, GAMBLING ACT, NDPS ACT , SC AND ST ACT. THE
ENTIRE CONSPECTUS OF FACTS DENOTES COMMISSION OF SERIOUS COGNIZABLE OFFENCES.
RESULTANTLY, THE PRESENT APPLICATION FOR DIRECTING A THREADBARE  INVESTIGATION AGAINST THE AFORESAID ACCUSED
PERSONS TO UNFURL THEIR ALLEGED ROLE IN BRAZEN ILLEGALITY CULMINATING INTO
COMMISSION OF OFFENCES POSTULATED UNDER SECTION_427/441/323/324/ 506(2) OF INDIAN PENAL CODE, 1860
AND OTHER LAWS AND ALSO OTHER OFFENCES WHICH MAY UNFOLD DURING THE COURSE OF
INVESTIGATION.

 

MOST
RESPECTFULLY SHOWETH:-

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1.          
The present case frescoes a gloomy picture
and depicts a miserable scenario as to how the high and mighty of the society
can due to their caste superiority and in front of full public gaze, smashed in
their high-handedness having blatant disregard to the law of land can subject a
person belonging to a lower case to the worst form of human ignominy and rob
them of their dignity and esteem.

 

2.          
That, at the very outset, may it be
submitted that the applicant is a housewife and resides at D-1/439, Nand Nagri,
Delhi -110093 for almost 26 years now and her husband carries on business of Auto
Spare Parts at D.D.A. Market, Nand Nagri, Delhi.

 

3.          
That significantly, one Sunita
Sharma lives in the same locality as that of the complainant and along with her
family members and one Rajinder [email protected] (hereinafter referred as “Accused Persons”)
runs a battery of illicit activities which are operated from an illegal office
constructed at Sunita’s house located at D-1/514, Nand Nagri, Delhi.

   

4.          
That notably the accused persons
along with some unknown persons are the organizers and kingpins of an illegal
racket buried deep into nefarious activities like illegitimate gambling
comprising of satta, jua, etc and unlawful dealing of narcotic substances like
Charas, Ganja, Hash, etc. That all these despicable activities are stage-managed
and controlled from an illegal office constructed at Sunita’s house located at
D-1/514, Nand Nagri, Delhi.

 

5.          
That the accused persons being the cream
of the crop for such criminal activities in order to exercise their dominance
and control over the said locality have put up a board with their pictures on
it of “Shivsena”- Hindu Rashtra, etc outside the illegal office constructed at their
house. The accused persons state publicly that they are the members of such political
outfits and are having close proximity with politicians and advocates in Delhi.
Due to this political charade they are able to keep police authorities at bay
and even neighbours are under extreme dread to even report about them.

 

6.          
That the accused person’s house has
become a constant stopover for a number of unknown persons having treacherous
and evil features, who come there to obtain such illegal narcotic substances
and for gambling. Their illicit den has turned into a hub of criminal
activities and a wonderful hideaway for such criminals. The neighbourhood is
under tremendous trepidation due to their presence and incessant running of reprehensible
activities but no one gathers courage to speak against them as they employ unlawful
domineering authority in the said locality.

 

7.          
That on one such occasion when the
complainant refused to give in to their false supremacy and resisted the vehicle
parking of one such visitors to the accused persons house. The accused persons
came down heavily on her and her family members and abused them incessantly.
The accused persons brought lathis and dandas to beat the complainant’s family
and accused Rajinder [email protected] brandished an illegal revolver in the air and
all of them criminally intimidated the complainant and her family, that if they
resist to give in to their dominance they will end up dead lying in a ditch. The
accused persons also went to the debauched extent of giving caste-centric
abuses to the complainant and her family members.

 

8.          
That the accused persons incessantly
called caste names to the complainant and her family members and referred them
as CHUDA, CHAMAR, SANSI, KANJAR, etc in front of full public gaze and with an
intention to insult, humiliate and intimidate the complainant and her family
members and completely robbed them of their dignity and esteem in the eyes of
the neighbourhood. The accused persons belong to Sharma community and identify
themselves as Brahmins in the Hindu community and due their influential position
in the society threatened the complainant that if she doesn’t fall in line and
obey their scandalous commands, they will falsely implicate the complainant and
her family members into multiple criminal cases and they will rot in jail for
the rest of their lives.

 

9.          
That the accused persons and more
precisely Sunita Sharma made open threats that she on her account or by using
her daughter Neha will falsely implicate the complainant and her family members
for fallaciously outraging their modesty and in other offences having sexual
connotation as they belong to upper caste and have considerable influence in
the police department.    

 

10.      
That on 19-08-2017 the complainant
gave a detailed complaint to SHO, Nand Nagri P.S. delineating all the above
mentioned criminal acts and caste-centric atrocities committed on her and her
family members and more specifically stating that the complainant apprehends false
implication in some frivolous criminal case by the accused persons. However, this
compliant didn’t cut any ice with the police authorities and they failed to
lodge any FIR in the teeth of commission of such cognisable offences in broad
daylight.    

 

11.      
That the worst fear of the
complainant came to life when they got to

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