121/ 2 5

Mr. Kalyan Kumar Ghosh Advocate

HIGH COURT CALCUTTA Bar Association Room No 7

Phones: 2248-3169/3190/2243-7363 Fax : (033) 2248-2313

E-mail: barassociation@adiffmaitcom Residence:

To Dated 4.2.16.

1. The Learned Government pleader, High Court, Calcutta.

2. Secretary, Ministry of Home (Police), Nabanna, 325, Sarat Shatterjee Street, Howrah — 711102.

3. Director General of police, nk riorm7/Tur

natet Police Head Quarter, Bhawarti Bhawan, mw3 out Alipore, Kolkata_ 700027.

4. Superintendent of Police, Bankura, P.O. & District — Bankura, pin — 722101.

5. Inspector—in—Charge, Indpur Police Station, P.O. and District t Bankura, Pin — 722136.

6. Swapan Mondal Son of Mathur Mondal

7. Asha Mondal, Wife of Mathur Mondal

8. Mathur Mondal Son of not known

9. Tapan Mondal Son of Mathur Mondal

All are residing at Village — Bhular Khap, P.O. Purosottempur, P.S. Indpur, District — Bankura, pin — 722136.

Gove,m.uant Pater High conile Mci Ina

Ref : W.P. No. IVO (W) of 2016

Tarapada Bag ... Petitioner.

Vs. The State of West Bengal & Ors.

... Respondents.

contd...2.

121726

Advocate HIGH COURT CALCUTTA

Bar Association Room No Phones: 2248-3169/3190/2243-7363

Fax : (033) 2248-2313 E-mail: barassociation@rediffmaitcom

Residence:

2 : —

Dear Sir/Madam,

Please find herewith a copy of Writ application with

all annexures which has been filed to—day and the matter

will appear in the list of the Hon'ble Justice Dipankar

Datta as 'Listed Motion' on 11-02-2016 or soon thereafter

as and when the business of the Court will permit.

This is for your information and necessary

action.

Yours faithfully,

Enclo As above. IWA7(9,i,\ cto

Advocate.

DISTRICT s BANKLEJA

IN THE HIGH CURT AT CALCUTTA

Constitutional Writ Jurisdiction

Appellate Side

No.~5V(W) of 2016

Subject Matter Relating To s.

Residuary Group—IX, Head — (

of the Classification List I

Cause Title

Tarapada Bag petitioner.

es Versus

State of West Benga-I & Others.

•• • Respondents •

Advocateran—Record

Mr. Kellen Kuria: Ghosh Advocate

Bar Association Room No. 7# High Court, Calcutta-700001.

21S TAICT s eAN IRA

IN THE HIGH C0U1T AT CALCUTTA

Constitutional Writ Jurisdiction

Appellate Side

W.P. r‘o . (W) of 2016

Tarapada Bag Petitioner.

vs.

State of West Bengal & Crs.... Respondents.

INDEX

Description

Writ petition.

Annexure Page

2. A photo copy of the order of the Ld. Khatra and the petition under 156(3) Cr. P.C. P.1

3. Representation to the ,DPO, SDO, SP and Main P.2

LIST OF DATES

16.2.2015 s Petitioner was informed that there

is an accident in his house.

18.2.2015 s Petitioner saw the mortal remains

or his beloved daughter at the Burning

What of Bhular Khap Village of

Indpur, P.S. District— Bankura.

26.3.2015 s Ld. A .C.J .M. Khatra par-sed an order

in 156 (3) of the Cr.P.C. petition

filed by Tarapada Bag.

1.9.2015 s Petitioner made representation to

Sub—DiAsional Police Officer, Khatra.

7.9.2015 Petitioner made representation to

Sub—Divisioi.ai Offices, Matra.

16.9. 15 Petitioner made .repressentaticr: to

Superintendent of Police, Bankura.

21.9.2015 s Petitioner made representation to

District Magistrate, Bankura.

POINTS OF IAW It'WOLVED

The petitioner load his daughter

who was murdered by private respondents according to

the petitioner filed 156(3) petition seeking proper

investigation and exemplary punishment of the murder

of his daughter is not satisfied with the advancement

of the investigation, hence the Hon'Ille Court under

Writ Jurisdiction is required to interfere to give

natural justice to the petitioner.

DIS s OASIKLBA

IN DIE HIGH 001.11I AT CALCUTTA

Constitutional Writ Jurisdiction

Appellate Side

W.P. No. NO (N.1 ) of 2016$

In the matter of

An application under Article 226 of

the Constitution of India ;

And

In the matter of

A writ or writs, order or orders,

direction or directions in the nature

of Mandamus and/or Certiorari. and/or

Prohibition

And

In the matter of se.

Illegal and arbitrary action by the

Police authority by not taking proper

2

steps on the :atter p.

And

In the matter of s.

Illegal and wrongful and mo V ed

inaction of the police in exercise

of power and authority ;

And

In the matter of s.

Tarapada Bag

Fon of t/L4 A?i t

Villages Niyamatpur, P.O. POrosttanpur,

P.S. Indpur, District — Bankura,

Pin s 722136.

sow PO one/.

-.Venus -

1. State of West Bengal

Service through Chief Secretary,

Contd...3.

OffSo at :44)arina• 325. :'parat nhatterjoe

sYr .L1 - 7t 7::.-)24,

. -t`in Ca) )0

at a-70002n

..• ':. • 1 • .A

- • •

.a.:1-&1u i

t

Cr.; : • •ljn

0 ._) çj •

1

1• ,

.. :A.

—$ 4 2.

all are residing at Village..

Bhulax Khap, kicyamailmili P03. Purosottampur,

P.S. Indpur, District Bankuta

Pin 722136.

...Respondents.

To

The Henible Mrs. Manjula Chollur, Chief Justice and

Her Companion Justices of the said Honlble Court.

The humble petition of the

petitioner a boy Gnawed

Most Respectfully Shewet

your petitioner is a citizen of India.

2. That your petitioner's daughter Mamoni Mondal

was got married with one Tapan Morcial son of Mathur

Mondal of Bhular Khap, P.S. Indpur. District Bankura

according to the Hindu rites and customs and after

the solemnisation of the said marriage your petitioner's

contd...5.

6

Station or treating the same as First Zn±ormstion

Report and for commencement of investigation.

A photocopy of the order of the Ld. ACJ

Khatra and the petitioner under 156(3) Cr.P.C. is

avnexed herewith and marked with the letter P.1.

That thereafter your petitioner made repro,.

sentations co the : ub,.i%ivisionai Police Officer.

Khatra on 1.9.2015, the Sub—Divisional Officer, Khatra

on 7.9.2015, the Superintendent of Police, Bankuta on

16.9.2015 and the District Magistrate, Bankura on

21.9.2915 seeking their intervention and redxessal.

But the said authorities did nothing to protect the

interest of the petitioner and rather ignored the

natter for which the petitioner has been suffering

treaenc us mental shock and agony as he wishes

nurdarers of his daughter might get exemplary

punishment. Further the Police Authority is totally

in different and not taking steps against the

contd...7.

7

hooliganism of particularly respondent No. 6 4wapan

Mandel who is aided with the Local anti socialsby

biasing muscle power your petitioner is under

tremendous threatening of e and property.

Photocopiires of the said representations to the

SDK, SEC • SP and CM are annexed herewith and marked

with the letter

That being highly aggrieved and dissatisfied

with the illegal and ardtrary act of the police

authorities who are not taking steps against the Private

respondents particularly respondent no. 6 It Swapan

mondal, your petitioner begs to move this application

under Article 226 of the Constitution of India before

Your Lordships amongst others

GRO UN DS

For that the bereaued father has moved from

pillar to the post for prop3r investigation

8

of his daughters death the State respondents

are sitting tight over the same.

For that the acts of the rex State respondents

particularly the police authorities is against

the principles laid down in the police Rule

of Bengal as well as acts analogous thereto.

III. For that the respondent authorities by law

and statute are liable as well as entrusted

to maintain law and order and to take action

against the hooliganism.

1V. For that the impugned action of the respondents

is otherwise bad in law.

8. your petitioner submits that in the fitness

of thing your petiticwer is required to be protected

by the Honlble Court in th-a. interest of justice other.

wise your petitioner will suffer irreparable hardship

ane prejudice.

-1 9

That there is no efficacious legal remedy open

to your petitioner and the relief sought for herein, if

gra ted shall render complete and adequate remedy to

your petitioner.

10. In the facts and circumstances of the instant

case the balance of convenience is in favour of your

petitioner and for making the order as prayed for herein

are not made your petitioner will suffer irreparable

loss and injury.

11, That your petitioner subats that no writ

application was moved earlier on the same self ground

before this Honible Court,

t2 Dad metilicammx smtrits Mad sa

12. That the case record is lyinc: in the office

of the State respondalt which is within the appellate

side jurisdiction of the Hon'ble Court.

13. That this petition is made bonafide and for

the ends of justice.

contd.. 0.

10

In the circumstances aforesaid your

petitioner most humbly prays that

Your Lordship would be graciously

plec4Sed to pass the following orders I..

a) A writ of and/or in the nature of

Mandamus commanding the respondent

authorities to take appropriate action

against the respondent no.

by initiating proceeding against them

according to law by making proper

investifation of the case, by treating

the 156(3) application as an FIR and

also arresting the private respondents

for the interest of proper invests.

$

b) A writ of and/or in the nature of

Mandamus commanding the respondent

authorities to secure the safety of

contd.„11.

$

life and property of the petitioner;

writ in the nature of Certiorari

commanding the respondents more

,art:.cularly the respondent no. 5 to

trans;:it the records or: the case

forthwith so that the conscionable

justice may be done after looking to

tha same;

d) Rule NISI in ter me of prayers

), (b) and (c) above;

e) An interim orders directing the

respondent authorities for proper

investigation of the case ;

I) Ad-interim order in term, of prayer

of incidental cost to this application

to be paid to the petitioner by the

respondents;

Contd...12.

—s 12 s

g) Such further order ox other

order or orders be pased and/or

direction be given as to Your

Lordship may deem fit and proper.

And your petitionin as in duty bound shall ever

Pray

contd,..43,

13

A F F I DAVI

Tarapada Bag, son of IAA: 2 r aged

about J, years, by faith Hindu, by occupation c--,

residing at Visla,e tliyaraatpur„ P.O.

Purosottaropuz, P.S. indpur„ District — Bankura, Pin

722136, do hereby solermiy affirm and say as follows f.

1. That I am the petitioner in the instant petition

and as such I am well convarsant with the facts and

circumstances of the case.

2. That the statements made in paragraphs 1 to

are true to my kroviledge and

those made in the paragraphs are my

respectful submissions before t s H01111616 Court.

Prepared in my office The deponent is known to M3

K, R. CL,,n) Clerk to Mr.

Advocate. Advocate.

Soler;n.Ly at b:foce me on

this the day of February,

2016.

Ali annexures are legible

Advocate.

Commissioner.

CO,Inpated by 47-L 2. ACY-r9

lJ - Comparing Clerk

h,C1,24'S Court. Khatra

LitA—op.

)9k .11, 1

eet ed to be true cop)

Certifying Officer .2-(-11---/

Addi. ChiefJudichil Court, Kinn *authorised U/S. 76 of Act. i. ihr

Is.-?

2r{fl 6—cc t ( ,%r

IN THE COURT OF LD. A.C.J.M. KHATRA.

tit

M.P .Case no. 13/201:5

Al A

,0 l-OCis

Tarapada Bag Complainant

Vs.

Tapan Kr. Mondal & 4 ors. Accused

26 03.15

An application in the form of complaint has been filed by one. Tarapada Bag against

the accd. persons Tapan Kr. Mondal & 4 ors. under section 498A/302/201/109/120B/34 IPC.

praying for sending the same to I.C. Indpur P.S. treating as FIR U/S 156(3) Cr.P.C. and to

investigate the case and submit a report before the court in due course.

Heard. Perused the said application.

Considered. In view of the grave allegations contained in the application prayer is

allowed.

Let the complaint be sent to the I.C.' Indpur P.S. for treating the same as first

information report and commencement of investigatioh.

- ,

ClIke‘ 341e1/4:;r34

In the Court of Ld. A.C.J.M. at Khatra Case No. t3 /2015

T44

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92 1

pcii-e On _dr,

ieis for yoeic kind infatuation and necessary &ctlon , maaani Mondal was married with one Tapen Moeda' 6/0, Mi.thar (;(.‘a Fibular Khap, P.S. Indpur, Dist. Benkura according ato the Hinds. and customs dna after the. solasniseeVion of the sairiage my said daughter was started to live An her matrimonial house with her -d and in-laws. My son-in-last to earn his breaa and butter tgavc: to Tri,iverse outside Bengal and often :stayed there for a lone. perion. A son was born due to this wed-lock. -

I also to earn rsy bare necessaries have to go outside hengal st.oa on 12 th February, 201$-1 left for Singrouli, Msnya Predesa

On loth February,2015 I was inns:cued that there i* an accident in my houseand I-rushed to Dt hiymsatpur , Indpur from Sigrouli, There-&titer I went.ta - my son-in-law house in village fibular ;Chap ann I

rvsains was infonaed that ny daughter°simortal are not lying in tee Loci*" Burning that of the village.

After overcoming the shock, I went to the Indpur Police Station and_ requested the Duty Officer to receive ray complaint, but he refused and told me that there is already an F.I.R. 'edge ror the same. As there was no action taken on behalf of the Police autao-rity I have been Compelled to file a petition before the Lea.A.C,j‘H. Khatra and the Ld.a.C.J.M. Khatra was pleased to pars an orcer direction the officer,-in-Charge, Indpur, P.S. to invesigate the case under section 498A/ 302/;kA/ 109/120a/3e I.P.C.

But till date the principeL accused Swapan Mondal, Asslus Mono4A.1, Mathur Handal has not been arrested and perticularly Swapan Moma,J is threatening as by staying that if me do not withdraw the we w-444ARO,APjfaost dlr. consequences.

r••••awl • -

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044.4.0o

request you as your nounel to take Proper

04,4011 with law,

Dated s •

YoWtss

maAPADA ava Viii. - Niyamatpur, P.O, - Parosottampur,

Inapur, Dist. 6ankur,G, West Bengal. Pin a 722136,

0

rhe Sub- Dividionai• Officer

Khatra, Dist- Bankura

Respected Sir,

humbly pray before your good office that my daughter Mamoni Mondal was married

one Tapan Mondal, sio Mathur Mondal of Bhular Khap, P.S - Indpur, Dist - Bankura, according to

•-ndu rites and customs and after the solemisation of the said marriage, my daughter started to

In her matrimonial house with her husband and in-laws. My son-in-law have to travel to and fro

. , Laide Bengal to earn his bread and butter and often stayed there for a long period. A son was born

lue to this wedlock.

I also have to go outside of Bengal to earn my bare necessaries and on 12 th February, 2015, I

left for Singduli, Madhya Pradesh. On 16 th February, 2015, I was informed that there is an accident in

my house and I rushed to Niyamatpur, Indpur from Singrouli on 18 th February, 2015. Thereafter, I

cent to my son-in-law's house in village Bhular Khap and I was informed that my daughter's mortal

,, mains are lying in the local Burning Ghat of the village.

After overcoming the shock, I went to the Indpur Police Station and requested the duty officer

Padve my complain, but he refused and told me that there is an F.I.R. already lodged for the same.

._ there was no action taken on behalf of the Police Authorities, I have been compelled to file a

petition before the Ld. A.C.J.M., Khatra and Ld. A.C.J.M. was pleased to pass an order directing the

Officer-in-Charge, Indpur Police Station to investigate the case under Section 498A / 302 / 201 / 109 /

120B / 34 of Indian Ben?) Code. •

But as-stilt, no action was taken on the same and particularly Swapan Mondal, Asha Mondal and

Mondal was not arrested and Swapan Mondal is threatening us by saying if we do not

the F.I.R., we will have to face dire consequences, I made an representation to the Sub-

)nal Police Officer, Khatra, seeking his intervention on the 1 st day of September, 2015.

But even then no action was taken on behalf of the Police Authorities. „Under the abovesaid

His, I would like to. request your good sense -s your honour may be pleased to kindly [2w-sue , .

same as the complaint of my beloved daughte.'5 murder may be punished in accordance with Law.

Thanking you,

„Ctkit4v,LA2 o S—

FR

Sincerely Yours,

‘,*,y -4', -71

TARAPADA BAG

Vill-Niyamatpur

P.O. - Purosottampur

P.S. - Indpur, Dist - Bankura

West Bengal, PIN-722136

TO

PcV Superintendent of Police

ist- Etanlcura

Respected Sir,

May I humbly .pray before your good office that.my datlIghterMarnoni Mondal was married

with one Tapan Mondal, s/o Mathur Mondal of Bhular Khap, P.S - Indpur; DiSt —3ankura, according to

the Hindu rites and customs and after the solemisation of the said marriage, my daughter started to

live in her matrimonial house with her husband and in-laws. My son-in-law have to travel to and fro

outside Bengal to earn his bread and butter and often stayed there for a long period. A son was born

th}S wedlock.

I also have to go outside of Bengal to earn my bare necessaries and on 12 th February, 2015,

!eft for Singrouli, Madhya Pradesh. On 16 th February, 2015, I was informed that there is an accident in

••, -,y louse and I rushed to Niyamatpur, lndpur from Singrouli on 18 th February, 2015. Thereafter, I

„o,,t to my son-in-law's house in village Bhular Kl-ap and I was informed that my daughter's mortal

remains are lying in the local Burning Ghat of the village.

After overcoming the shock,I went to the thdpur - PoliceStation,and requested the duty officer

to receive my complain, but he refused and told me that there already lodged for the same.

there was no action taken on behalf of the Tahoe Authorities, I have been compelled to fie a

petition before the Ld. A.C.J.M., Khatra and Ld. AC.).M. was pleased to pass an order directing the

Officer-in-Charge, Indpur Police Station to investigate the case under Section 498A / 302 / 201 / 109 /

1203 / 34 of Indian Penal Code.

But till date, no action was taken on the same and particularly Swapan Mondal, Asha Mondal and

Mathur Mondal was not arrested and Swapan Mondal is threatening us by saying if we do not

wit.` draw the H.R., we will have to face dire cor>equences, I made an representation to the Sub-

Divisional Police Officer, Khatra, seeking his intervertion on the 1 st day of September, 2015.

But even then no action was taken on behalf of the Police Authorities.

Thereafter on the 7th day of September, 2015, I made an representation to the Sub-divisional

Officer, Khatra, seeking his intervention. But, even then the main accused and the other culprits were not arrested.

tin der the above noted conditions, I would like to rogues/ before your good office as yours

honour may be pleased to direct your personnel to take quick srteps:.aa the prime accused Swapan

Mondal and other culprits are arrested and punished in accordance with Law.

Thanking you,

Sincerely Yours,

The 16th• September, 2015

Bankura

TARAPADA BAG

Viii- Niyarnatpur

P.O. — Purosottarnpur

P.S. IndtThr, Dist — Beni-tura

We Bengal, IPIN-722136

To

The District Magistrate

Dist- Bankura

Respected Sir,

The followingjare my submissions before your good office that my daughter Marnoni Mondal

was married with one Tapan Mondal, s/o Mathur Mondal of Bhular Khap, P.S - Indpur, Dist — Bankura,

according to the Hindu rites and customs and after the solemisation of the said marriage, my daughter

started to live in her matrimonial house with Hi husband and in-laws. My son-in-law have to travel to

and fro outside Bengal to earn his bread and butter and often stayed there for a long period. A son was born due to this wedlock.

I also have to go outside of Bengal to earn my bare necessaries and on 12 th February, 2015, I

left for Singouli, Madhya Prao,...:h. On 16 th February, 2015, I was informed that there is an accident in

my house and I rushed to Niyamatpur, Indpur from Singrouli on 18 th February, 2015. Thereafter, I went to my son-in-law's house in village Bhular Khap. and I was informed that my daughter's mortal remains are lying in the local Burning Ghat of the village.

After overcoming the shock, I went to the Indpur Police Station and requested the duty officer to receive my complain, but he refused and told me that there Is an F.I.R. already lodged for the same.

As there was no action taken on behalf of the Police Authorities, I have been compelled to file a

petition before the Ld. A.C.j.M., Khatra and Ld. A.C.J.M. was pleased to pass an order directing the

Officer-in-Charge, Indpur Police Station to investigate the case under Section 498A / 302 / 201 / 109 / 12013/ 34 of Indian Penal Code..

But as still, no action was taken on the same and particularly Swapan Mondal, Asha Mondal and

Mathur Mondel was not arrested and Swapan Mondal is threatening us by saying if we do not withdraw the F.LB., we will have to face dire consequences, I made an representation to the Sub-Divisional Police Officer, Khatra, seeking his intervention on the 1st day of September, 2015.

Thereafter or, the 7 to day of September, 2015, I made an representation to the Sub-Divisional

Officer, Khatra, seeking his intervention and on the 16 th day of September, 2015, I made another

representation on to the Superintendent of Police, Bankura, but even then the main accused and other culprits were not arrested.

Under the abovesaid conditions, I would like to request your good sense as your honour may be

pleased to direct your personnel to take quick steps as the prime accused Swapan Mondal and other culprits are arrested and punished in accordance with Law,

Thanking you,

Sincerely Yours,

Q.,--ny tile( —d-irsi

21 st September, 2015

Bankura

TARAPADA BAG

Vill- Niyamatpur

P.O. — Purosottampur

P.S. — Indpur, Dist — Bankura

West Bengal, PIN-722136

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CT s. SAMOSA

IN THE HIGH COLE' AT CALCUTTA

Constitutional Writ Jurisdiction

Appellate Side

IN.P. r750 (V) of 2016

In the matter of 1..

An application under Article 226 of

the Constitution of India ;

And

In the matter of

Tarapada Bag Petitioner.

vs.

State of West Bengal g Ors.

Respondents.

pETIT l 0 N

Mr. Kasyan Kumar &lash. Advocate

Bar Association Room No. 7, High Court, Coicutta-700001.