written submission for hearing dated 03.01.2018
TRANSCRIPT
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FILING INDEX
IN THE CENTRAL INFORMATION COMMISSION
ROOM NO.402, 4TH FLOOR, CIC BHAWAN, BABA GANG NATH
MARG, MUNIRKA, NEW DELHI-110067
(WRITTEN SUBMISSION FOR HEARING OF
F.NO.CIC/SCOFI/A/2017/122864 ON 16.01.2018 BEFORE
CHIEF INFORMATION COMMISSIONER, CIC, NEW DELHI)
IN THE MATTER OF:
ASHA RANI DEVI & ANR ……….APPELLANT
VERSUS
CPIO, ADL. REGISTRAR …… RESPONDENT
SUPREME COURT OF INDIA
S.N Particulars Pages
1. Written submission for hearing of
F.NO.CIC/SCOFI/A/2017/122864 on
16.01.2018
1-5
2. Postmortem report of Appellant,
Asha Rani Devi dated 11.11.2017
6-9
3. Emergency (AIIMS) case sheet
dated 09.11.2017
10-24
4. Police Report & Police statement
recorded by Son of Asha Rani Devi
dated 11.11.2017 along with
Acknowledgement by Commissioner
of Police Delhi dated
15.12.2017; 20.12.2017;
21.12.2017; 28.12.2017 and
01.01.2018
25-32
Appellant no.01 in Person
Filed on: 03.01.2018 on behalf of Appellant No.02
Om Prakash
Diary No. 100707 RZF-893, Netaji Subhash Marg Raj Nagar, Part-2, Palam Colony
New Delhi-110077, Dwarka Sector-08
Mob:9968337815 Email:[email protected]
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WRITTEN SUBMISSION BEFORE HON’BLE THE CHIEF
INFORMATION COMMISSIONER MR. RADHA KRISHNA MATHUR
AGAINST F.NO.CIC/SCOFI/A/2017/122864 FOR THE DATE
OF HEARING ON 16.01.2018
IN THE MATTER OF:
ASHA RANI DEVI & ANR ……….APPELLANT
VERSUS
CPIO, ADL. REGISTRAR …… RESPONDENT
SUPREME COURT OF INDIA
To
Hon'ble the Chief information
Commissioner, CIC, New Delhi, India
MOST RESPECFULLY SHOWETH:
1. That the denial of access to
justice; abuse of vested power under Order XV,
Rule 5 of the Supreme Court Rule 2013 by the
Registrar (J-I) in the garb of no reasonable
cause to be received for registration of case
led to planned murder of Appellant Asha Rani
Devi under illegal judicial custody under house
arrest dated 11.11.2017.
2. That the appellant, Asha Rani Devi
took her last breath on 11.11.2017 at New Delhi
fighting with corrupt Indian judicial system.
3. That Postmortem report dated
11.11.2017 of Appellant Asha Rani Devi reveals
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that cause of death is cardiac shock due to
cardiac temponade and myocarditis. Postmortem
report dated 11.11.2017 of Appellant Asha Rani
Devi is annexed herein as Annexure P-1 (Page
from 06 to 09).
4. That nexus of judges with doctors
at AIIMS at New Delhi is responsible for the
cardiac shock as Asha Rani Devi was forced to
sign (LAMA)and sent her back home at midnight
with 47000 WBC count; low Oxygen (o2) high
Carbon-dioxide(co2) as per blood ABG report.
5. That movement of Asha Rani Devi at
AIIMS at New Delhi was tracked by some big shots
on 09.11.2017. Asha Rani Devi was denied access
to emergency by emergency screening room of AIIMS
at 11.30 A.M. in the garb of no oxygen bed
available; again at 2:00 P.M. allowed access to
emergency; again at midnight she was forced to
sign (LAMA) and sent her back home in the garb of
no oxygen bed available with 47000 WBC count; low
oxygen (o2) high carbon-dioxide (co2) as per
blood ABG report.
6. That in case of (LAMA) medical
papers is not returned back to the patient.
Papers are kept with hospital (AIIMS) authority.
This material evidence was collected by the
patient due to misconduct or suspicious
activities of the doctors on 09.11.2017.
Emergency case sheet dated 09.11.2017 is annexed
herein as Annexure P-2 (page from 10 to 24).
7. That son of Asha Rani Devi has
recorded the name of big shots Rtd. Justice S.B.
Sinha of Supreme Court of India & Praveen Kumar
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from Indian defense account service in the police
statement with his own handwriting on 11.11.2017.
Police statement & police report dated 11.11.2017
along with acknowledgement by commissioner of
police Delhi dated 15.12.2017; 20.12.2017;
21.12.2017; 28.12.2017 and 01.01.2018 is annexed
herein as Annexure P-3 (Page from 25 to 32).
8. That it was a planned murder by the
nexus of doctors at AIIMS at New Delhi and Rtd.
Justice S.B. Sinha of supreme court of India &
Praveen Kumar from Indian defense account service
as we had filed 10 cases civil as well as
criminal both before Hon’ble supreme court of
India against them since 2012 to 2017.
9. That the Appellant approached the
Hon’ble Supreme Court of India against the State
of Bihar and invoked Article 32 for enforcement
of her Article 21 but she was denied access to
justice and not being allowed to agitate the
matter before Hon’ble the Chief Justice of India
on 03.10.2016 by way of suppressing her
application dated 03.10.2016 by the Registry.
10. That she was not allowed even a
single time to agitate the matter under Article
32 properly even though the jurisdictions of
matter was completely falling under Article 32
of Constitution as two states jurisdictions were
involved into it for the same cause of actions
and for the same relief.
11. That the fresh cause of actions
arose at Hon’ble Supreme Court of India because
of denial of access to justice by the Hon’ble
Supreme Court of India therefore a fresh case
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was filed against the Union of India.
12. That the Registrar (J-I) in his
false reply dated 28.01.2017 stated that the
petition revolves around same subject matter;
same findings; re-agitating the same petition
etc. He further stated, “The matter having been
finally set at rest by this Hon’ble Court the
petitioner cannot now be allowed to take resort
to the provisions of Article 32 of Constitution
to impeach the same findings”.
13. That the Appellant’s only contention
is that matter has not been finally set at rest
by this Hon’ble Court. It has been made to set
at rest at its finality wrongly. Appellant’s
petitions have been manipulated by the Registry
and been made it liable to be set at rest at its
finality. Appellant’s full petitions with all
applications filed so far have never been placed
before the Hon’ble Judges under Article 32.
Hence, Appellants were denied access to justice
under Article 32. In other words, Appellants
were not allowed to invoke Article 32 of
Constitution properly.
14. That the petition attracted fresh
reasonable cause of actions; attracted new
findings, attracted different cause title. The
fresh reasonable cause of actions; new findings
are:- violation of set practice, procedure and
rules; denial of access to justice; evasion of
Order XXXVIII of Supreme Court Rules 2013;
likelihood of bias by two judges bench; two
states jurisdictions for the same cause of
actions and same relief; imposition of liberty
to approach High Court; nine relief from two
states; not allowing to invoke Article 32 even a
single time properly.
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PRAYER
In the above premises, it is prayed that Hon’ble
the Chief Information Commissioner of CIC India
may be pleased:
(i) To pass an order to register the Writ Petition (Crl.) D.NO. 2188 of 2017
entitled “Om Prakash & Another Vs.
Union of India & Others” after the
planned murder of Appellant Asha Rani
Devi.
DRAWN & FILED BY:
Om Prakash
Appellant No.01
On behalf of Appellant No.02
S/O Late Shri Deep Narayan Poddar
Rented R/O RZF-893, Netaji Subhash Marg
Raj Nagar, Part-2, Palam Colony,
New Delhi-110077 Mob: 9968337815
Email: [email protected]
NEW DELHI:
Filed on: 03.01.2018
Diary No: 100707
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Annexure P-
1
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Annexure P-
2
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Om Prakash Poddar <[email protected]>
DHLTH/E/2017/07152, Dt. 10.11.2017
Admin Officer Grievance <[email protected]> Fri, Dec 8, 2017 at
4:20 PM To: [email protected], [email protected]
Sir,
In regard of above mentioned grievance, it is informed that your matter has been examined by the Emergency Medicine Department and replied that "as per policy of the hospital, patient are stabilized in the emergency. After that depending upon availability of beds, the stable patients may be referred to other hospital depending upon a bed is available or not. The emergency cannot admit all follows up cases in emergency beds due to scarring of vacant beds."
Asstt. Admin Officer Grievance Cell
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Annexure P-3
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POLICE STATEMENT BY SON OF WIDOW ASHA RANI DEVI DATED 11.11.2017
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Om Prakash Poddar <[email protected]>
REGISTRATION OF F.I.R & ISSUANCE OF DEATH CERTIFICATE-REGARDING
Amulya Patnaik <[email protected]> Fri, Dec 15, 2017 at
10:48 AM To: Om Prakash Poddar <[email protected]> Cc: [email protected], [email protected]
Respected Sir/Madam
Thanks for your E-mail. Your E-mail has been acknowledged by Commissioner of Police, Delhi and the same has been referred to the Joint Commissioner of Police/New Delhi Range (his office telephone No. 23762616 Extn 30024 and E-mail ID is [email protected]) for further necessary action vide Dy. No. is 27994/E-mail dated 11/12/2017
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Om Prakash Poddar <[email protected]>
Registration of F.I.R & issuance of Death Certificate
Amulya Patnaik <[email protected]> Fri, Dec 15, 2017
at 4:28 PM To: Om Prakash Poddar <[email protected]> Cc: [email protected], [email protected]
Respected Sir/Madam
Thanks for your E-mail. Your E-mail has been acknowledged by Commissioner of Police, Delhi and the same has been referred to the Joint Commissioner of Police/New Delhi Range (his office telephone No. 23762616 Extn 30024 and E-mail ID is [email protected]) for further necessary action vide Dy. No. is 28027/E-mail dated 11/12/2017
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Om Prakash Poddar <[email protected]>
POSTMORTEM REPORT & POLICE REPORT OF ASHA RANI DEVI
Amulya Patnaik <[email protected]> Wed, Dec 20, 2017
at 7:39 PM To: Om Prakash Poddar <[email protected]> Cc: [email protected], [email protected]
Respected Sir/Madam
Thanks for your E-mail. Your E-mail has been acknowledged by Commissioner of Police, Delhi and the same has been referred to the Joint Commissioner of Police/New Delhi Range (his office telephone No. 23762616 Extn 30024 and E-mail ID is [email protected]) for further necessary action vide Dy. No. is 28337/E-mail dated 13/12/2017
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Om Prakash Poddar <[email protected]>
ATTN: THE POLICE COMMISSIONER OF DELHI (POLICE STATEMENT BY SON OF WIDOW ASHA RANI DEVI DATED 11.11.2017)
Amulya Patnaik <[email protected]> Thu, Dec 21, 2017 at
10:23 AM To: Om Prakash Poddar <[email protected]> Cc: [email protected], [email protected]
Respected Sir/Madam
Thanks for your E-mail. Your E-mail has been acknowledged by Commissioner of Police, Delhi and the same has been referred to the Joint Commissioner of Police/New Delhi Range (his office telephone No. 23762616 Extn 30024 and E-mail ID is [email protected]) for further necessary action vide Dy. No. is 28566/E-mail dated 15/12/2017
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Om Prakash Poddar <[email protected]>
Seeking Status of Dy. No. is 27994/E-mail dated 11/12/2017;Dy. No. is 28027/E-mail dated 11/12/2017;Dy. No. is 28337/E-mail dated 13/12/2017 & Dy. No. is 28566/E-mail dated 15/12/2017
Amulya Patnaik <[email protected]> Thu, Dec 28, 2017
at 2:57 PM To: Om Prakash Poddar <[email protected]> Cc: [email protected], [email protected]
Respected Sir/Madam
Thanks for your E-mail. Your E-mail has been acknowledged by Commissioner of Police, Delhi and the same has been referred to the Joint Commissioner of Police/New Delhi Range (his office telephone No. 23762616 Extn 30024 and E-mail ID is [email protected]) for further necessary action vide Dy. No. is 29452/E-mail dated 26/12/2017
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Om Prakash Poddar <[email protected]>
Attn: Commissioner of Police Delhi (Material Evidence against Planned Murder of Widow Asha Rani Devi & No F.I.R by Delhi Police)
Amulya Patnaik <[email protected]> Mon, Jan 1, 2018 at
4:45 PM To: Om Prakash Poddar <[email protected]> Cc: [email protected], [email protected]
Respected Sir/Madam
Thanks for your E-mail. Your E-mail has been acknowledged by Commissioner of Police, Delhi and the same has been referred to the Joint Commissioner of Police/New Delhi Range (his office telephone No. 23762616 Extn 30024 and E-mail ID is [email protected]) for further necessary action vide Dy. No. is 29834/E-mail dated 29/12/2017