12. That when all pressure tricks of said Kamlesh Chandra Chattopadhyay were failed to cause any monetary benefit for him, he got filed through the said Tenants Title Suit No.108 of 1983 before the Learned Court of 7^th Sub-Judge Alipore, against the Petitioner and his Cooperative Society. But, when the petitioner admitted before the Court that he has at all not intentions to remove any Tenants without due process of Law, then the Injunction Order passed on the Injunction Application of the Petitioner was modified in such a manner, which no way was against the Petitioner, but actually caused hurdled for the blackmailing objects of the aforesaid Tenants, thus actually of the said Kamlesh Chandra Chattopadhyay. As a result, said Kamlesh Chandra Chattopadhyay, abetted one Lawyer for professional misconduct, thus Ld. Mr. Srikanta Bhattacharyya, Advocate, P-203, C.I.T. Road, Scheme No. VI(M) Kolkata-700054 manipulated the impact of Order No. 10 dated 4.10.1983 passed in Title suit No.108 of 1983 of 7^th Sub-ordinate Judge, Alipore (Kolkata), by manipulating the language of order dated 19^th September 1983 issued Certificate dated 17^th February 1984 under heading "TO WHOM IT MAY CONCER". As such, after knowing the same Lawyers Notice dated 27^th February 1984 was served upon Ld. Mr. Srikanta Bhattacharyya, Advocate, Photocopies of said Certificate dated 17^th February 1984 and said Lawyers Notice dated 27^th February 1984 are annexed herewith and marked as "Annexure K-1 & K-2 respectively". Possibly, Ld. Mr. Srikanta Bhattacharyya, Advocate might have issued such certificate under some false representations or otherwise, as such when he realised the same, he left from the Suit. Since, thereafter, Petitioner has no grievances against Ld. Mr. Srikanta Bhattacharyya, Advocate. However, Petitioner constructed boundary wall surrounding entire properties because of the order passed in the Said Title Suit filed by the Tenants with intention to blackmail the Petitioner.
13. That, in fact in or about the year of 1984 said Kamlesh Chandra Chattopadhyay joined hands with Chuni Lal Mukherjee, Sanjay Kumar Jhunjhunwala and adjudged Cheat Chittaranjan Ganguly. Thereafter, they formed Mafiadom, under black money powers and leadership of Sanjay Kumar Jhunjhunwala to grab all properties from the Locality, including the property of the Petitioner, if required with the help from Shri Jyoti Basu, the then Chief Minister of West Bengal. One reason for such help was connections between Shri Jyoti Basu and said Kamlesh Chandra Chattopadhyay, while more concrete reason was developed subsequently some underhand agreement between Shri Jyoti Basu and Directors of M/S. Martin Burn Limited were developed through one close friend of Shri Jyoti Basu, namely Mr. Shrawan Kumar Todi. The facts relates to other favours in favor of the said Mafiadom were referred under Part-IV hereinafter.
14. That after evolvement of such Mafiadom said Kamlesh Chandra Chattopadhyay abetted and instigated those Tenants for some criminal acts against the Petitioner, as such aforesaid Tenants with the help of one anti-social of locality Gopal Das, decided to manufacturing of the BOMBS to use them against the Petitioner. On or about 2^nd March 1984, some of the Tenants and said anti-social Gopal Das were busy in manufacturing of the Bomb, one tenant was smoking Cigarette. Suddenly ash of the said Cigarette fallen on the accumulated materials for manufacturing of the Bomb, fire taken place and said anti-social and Gopal Das and one of the Tenants were burnt seriously. When tenants taking them for Hospital, Police caught red handed them, as such a false story was created. Said Gopal Das was Bengali while one Oriya lady Tenant under the advice from said Kamlesh Chandra Chattopadhyay lodged First Information Report based on such false story that the agents of the Petitioner thrown Acid Bomb upon the said Gopal Pal, (allegedly brother of said Oriya Lady), and said Kamlesh Chandra Chattopadhyay using his political connections meet with Shri Snehangshu Acharya, the then Advocate-General of West Bengal, representing with the self-same false story. Resultantly, Shri Snehangshu Acharya, the then Advocate-General of West Bengal telephoned to Director General of West Bengal with the same story and Telephones District Judge of Alipore that if Mr. Milap Choraria, the Petitioner apply for anti-cipatory bail he should not be granted the bail and further Telephoned to Senior District Police Officers to arrest the Petitioner. As such the then Superintendent of Police 24-Parganas Mr. K. K. Kalia, I.P.S., and the then local Deputy Superintendent of Police Shri Md. Nizam rushed to Behala Police Station and armed Police were deployed at the property of the Petitioner.
15. That one honest C P I (M) Leader who were heartingly supported the Petitioner, considering his social mind set-up, and also knows about the characters and about connections of Kamlesh Chandra Chattopadhyay, was present in the Office of Officer-in-Charge of Behala Police Station, when Senior Police Officers reached and discussed whole matter in his presence, telephoned the Petitioner through some other person, that Police is coming to arrest, as a result Petitioner flea from his residence along with his family members for some other areas, to save him till he does not know the real matter. During the discussions, in the mind of Mr. K. K. Kalia some doubts raised in his mind and he instructed Shri Md. Nizam Deputy Superintendent of Police to go and see the burnt persons, who went in two different Hospitals as the Gopal Das was placed in one Government Hospital while the burnt Tenants was in one Nursing Home. After coming back said Police Officer reported that the burning of the both victims are not of the Acid Bomb, rather map of the burning is suggesting that they were engaged in manufacturing of the Bomb, when fire was caught. As a result, Superintendent of Police 24-Parganas Mr. K. K. Kalia, I.P.S. telephoned to Shri Snehangshu Acharya, that story as he had conveyed is based on total lie while real incident otherwise is totally different, and instructed to the local Police Officers not to arrest the Petitioner.
16. That thereafter, Petitioner filed anti-cipatory bail application, as he till then not aware about such enquiry conducted by Shri Md. Nizam, the Deputy Superintendent of Police and instructions given by Shri Superintendent of Police 24-Parganas Mr. K. K. Kalia, I.P.S. not to arrest the Petitioner. When the Advocate of the Petitioner moved anti-cipatory bail the then Presiding Judicial Officer of the Court of District Civil & Sessions Judge says in open Court that he was Telephoned by Shri Snehangshu Acharya, Advocate General of West Bengal not to grant the bail to the Petitioner. He further mentioned that during his enquiry with regards to the matter relates to said Mr. Jayanta Kumar Dasgupta, the then Munsif, 5^th Court, he find different face of strong moral of the Petitioner, but by this matter referred by Shri Snehangshu Acharya, he was socked that the Petitioner might be a criminal However, in spite of all such remarks, Honble District Judge ordered for temporary bail on anti-cipatory bail application of the Petitioner and directed the Police to present case Diary of the matter. When case Diary was presented before the District Judge, Police said that No case is pending against the Petitioner in the respective matter. The Photocopies of Courts Orders are annexed herewith and Marked as "Annexures-L-1 & L-2".
17. That when said Gopal Das was released from the Hospital, he needed treatment after the Hospital Treatment and valuable Ointments to be used in large areas of his bodys burnt portion, as such when he meet with the Tenants, since his use was finished-, Tenants thrown him out of the Properties. Thereafter, said Gopal Das under advice from some Local CPI(M) leader meet with the Petitioner appealed for medical help on humanitarian grounds. Considering his enemy activities and background, first of all he taken him in the Police Station, where the concerned Police Officer ask him to reveal the real story behind his burning, then he revealed real story related to his engagement along with Tenants in manufacturing of the Bombs. Thereafter, Petitioner ask said Gopal Das, that without any pressure first of all he must put the matter on record, then only the Petitioner can help him. Gopal Das replied that he can write any thing, but his wife can write the story in Bengali. Thereafter, he went to his residence and placed the entire story on paper in Bengali script through the hand and pen of his wife. For the authencity of the same Petitioner send some one along with the Gopal Das. Since the story was in Bengali, as such Petitioner cannot read it, as such he got translated the same and get typed it on one stamp paper and after signature from Gopal Das placed it before Executive Magistrate, 24-Parganasd as an Affidavit. Since the said affidavit was rejected in consideration of the materials referred therein, but become a valid document, as it was numbered as document No. 5887 dated 14.5.1984. After going by the aforesaid handwritten noting and said rejected Affidavit concerned Police Officer advised the said Gopal Das, that if he can show courage to admit the truth, he will forward him before the Judicial Magistrate, by arresting him, but same can cause problem for him, because he may be punished for his involvement in manufacturing of the Bombs. Since under the rough behave adopted by the aforesaid Tenants Gopal Das was annoyed against them and was ready to suffer every thing against admission of real story. Thereafter Police arrested him and send him before Judicial Magistrate, where he revealed entire story in real verbatim and further revealed the story related with the theft of One Generator and Type Writer of the Petitioner. However, under the political influence nothing was done by the Police against any of the accused in the aforesaid matters. The Photocopy of said handwritten admission paper written by the wife of Gopal Das and thumb impression given by the said Gopal Das and said rejected Affidavit being document No. 5887 dated 14.5.1984 are annexed herewith and Marked as "Annexure L-3 & L-4" respectively.

18. That on 10^th April 1984, Petitioner filed one Writ Petition being No. C.O. 4044(W) of 1984 for Police help before the Honble Court of B. C. Basak, J of the Calcutta High Court as His Lordship then was, and after hearing the same His Lordship passed appropriate order. But, within few days, but without filing any written Affidavit or petition, learned Mr. Dipankar Gupta, Bar-at-law, wrongfully appeared in the said matter on behalf of the Respondent against the Petitioner and used sentimental pleadings submitting before the Honble Court that he is appearing on behalf of his poor driver, (according to him the Petitioner was intended to remove his driver, which was totally false and baseless) without taking any fees, as such under such verbal pleading Honble Court stayed its earlier Order dated 10^th April 1984. Subsequently, Respondents in the said matter, filed their Affidavit-in-opposition, based on the total false statement. Petitioner wrote a protest letter to Learned Mr. Dipankar Gupta, Bar-at-law, against his conduct virtually has helped the blackmailing activities run by the said Mafiadom. The Petitioner say and submit on the affirmations that if the said Affidavit filed by the Respondents, could have been tried and adjudicated Under Section 340 of Criminal Procedure Code the respective Respondent of the matter who affirmed the affidavit was liable to suffer consequences thereof. This is firm statement of the Petitioner that the Petitioner, if failed to prove affidavit filed by the Respondents in the said matter as based on false statement, then the Petitioner should be liable to contempt of Honble Court. However, on 9^th May 1984, the Honble Court, without considering the matter on merit, but under embracement from Learned Mr. Dipankar Gupta, Bar-at-law withdrew the said earlier order dated 10^th April 1984. However, after strong objections from the Lawyer of the Petitioner Honble Court also passed some directions upon respective Lower Court, which ultimately benefited to the Petitioner, on merit. Photocopies of the Order dated 10^th April 1984 and 9^th May 1984 and protest Letter dated 2^nd August 1984 sent to Learned Mr. Dipankar Gupta, Bar-at-law are annexed herewith and marked as "Annexure M-1, M-2 & M-3" respectively.

19. That when modified order in Title Suit No. 108 of 1983 of the Learned 7^th Sub-Judge, Alipore causes reverse impacts against the interests of the said Mafiadom, then under their direct connection and Nexus with Shri Jyoti Basu, the then Chief Minister of West Bengal, got issued one written order under the Pen, and hand of Shri Jyoti Basu himself, upon Mrs. Ranu Ghosh, I.A.S., (not Mrs. Ranu Ghosh, another I.A.S. Officer) the then District Magistrate 24-Parganas to remove Milap Chand Choraria (the Petitioner herein) from the (alleged properties of one adjudged Cheat) Chittaranjan Ganguly. After going by the said order from Shri Jyoti Basu, in his capacity as the then Chief Minister of West Bengal, Mrs. Ranu Ghosh, I.A.S., the then District Magistrate 24-Parganas, forwarded the said order to Shri Md. Nizam, the then Deputy Superintendent of Police of the respective area, with instructions to comply the order of the Chief Minister. Shri Md. Nizam, the then Deputy Superintendent of Police of the respective area, till then though not meet personally with the Petitioner, but by going through the aforesaid matter of burning of Gopal Das, during manufacturing of Bombs, he known about the Petitioner and his moral standard, as such without directly complying the said Order, send a written message dated 23.1. 1985 through Officer-in-Charge, Behala Police Station to the Petitioner to meet him immediately with reference to Chief Ministers order. When Petitioner met on 30.1.1985 with Shri Md. Nizam, the then Deputy Superintendent of Police of the respective area, he shown the order of the Chief Minister and subsequent order from Mrs. Ranu Ghosh. When Petitioner offer him to hand over the keys of the properties against the appropriate receipt, he said that he dont want to do any thing illegal, as such if the Petitioner have to say anything he will be allowed to say. Thereafter, Petitioner by his letter dated 1^st February 1985 addressed to Shri Md. Nizam, the then Deputy Superintendent of Police of the respective area, with copies to Shri Jyoti Basu and Mrs. Ranu Ghosh. After receipt of the aforesaid letter of the Petitioner Mrs. Ranu Ghosh, IAS, District Magistrate, 24-Parganas, issued fresh orders withdrawing her earlier order. Photocopy of the said letter dated 1^st February 1985 addressed to Shri Md. Nizam, the then Deputy Superintendent of Police of the respective area, with copies to Shri Jyoti Basu and Mrs. Ranu Ghosh are annexed herewith and marked as "Annexure: N-1"

20. That after failure in said attempt, said Chuni Lal Mukherjee the member of said Mafiadom, decided to cause some pressure by encroaching the properties of the Petitioner, as Petitioner send Lawyers Notice to said Chuni Lal Mukherjee, son of Late R. G. Mukherjee, the then resident of 11, Banmali Naskar Road, Kolkata-700034, against his intentions to encroach the properties of the Petitioner. After receipt of the said Notice he under connivance with the concerned Police Officer changed strategy and lodged one Criminal Case that Milap Chand Choraria (the Petitioner herein) demanded Rs.20,000/- from him, with object to get arrested him, when the Petitioner come to restrain him from encroaching the property of the Petitioner. But, when Petitioner taken appropriate steps against him, for time being, under advice from the said Mafia Sanjay Kumar Jhunjhunwala he decided to stop such activities against the Petitioner, and on 6^th February 1986, admitted in writing that the Criminal Case filed by him was untrue. Photocopy of the said Advocates Notice and Letter written by the said Chuni Lal Mukherjee to the Officer-in-Charge, Behala P.S. is annexed herewith and marked as "Annexure: O-1 & O-2" respectively.