1. That the petitioner is a man of the principle, as such he is unfit to do that type of business, which are done by the unscrupulous businessmen or Mafia elements with their connections or Nexus with the powerful politicians. As such Petitioner is suffering constant and regular atrocities, harassments, torcherings, attempt to murders, and various other blackmailing activities caused under Politics-Bureaucratic-Crime-Nexus, since he purchased some properties in the year of 1982 to develop multistoried building complex, presently within the area of ward No. 119 of Kolkata Municipal Corporation, within Behala Police Station, of South 24-Pargana, within the Jurisdiction of the West Bengal Police, within Kokata-700038.

2. That in the year of 1994, reports were published in the Newspapers, that the then State Minister for Home Late Shri Rajesh pilot, directed to enquire the Politics-Crime-Nexus, as such the Government of India appointed one High Power Committee namely Vohra Committee to examine the Nexus between the Politicians, bureaucrats and organised mafia. The then Union Home Secretary Shri N.N. Vohra, was made Chairman of the Committee. The other members of the Committee were the then Revenue Secretary, Director Intelligence Bureau, Director, Central Bureau of Investigation, Secretary, Research and Analysis Wing (RAW), and Joint Secretary of Home Ministry. The Committee submitted its Report in the early part of 1995. Knowing about the order for examine the Politics-Crime-Nexus, Petitioner send his representation dated 30^th March 1994 by Registered Post to Shri Rajesh Pilot, the then State Minister for Home Affairs, mentioning detail facts relates to his suffering from Politics-Crime-Nexus. Photocopy of the said representation along with all annexures therewith, are annexed herewith and marked as follows:

4. Letter dated 12^th September 1991 sent by Regd. Post to CPI (M) Leaders Shri Har Kishan Singh Surjeet, Som Nath Chatterjee, M. P., Shri Biman Bose, against atrrocities adopted by said Mafia Leader Mr. Sanjay Kumar Jhunjhunwala, with full support from Shri Jyoti Basu and his Machinery. But, CPI(M) Leaders maintained silence as if they are in support of such Mafiadom. The same is annexed herewith and Marked as "AnnexureB-6".
5. Letters Dated 27.3.1992 from Shri Vijay Kumar Chopra, Chief Editor of Hind Samachar group of Newspapers, Jallandhar, addressed to Shri Har Kishan Singh Surjeet and Shri Jyoti Basu himself, but they maintained silence. The same is annexed herewith and Marked as "AnnexureB-7".

(6) Letter dated 6^th April 1992 from Shri George Fernandes, the then M.P. (Presently Defence Minister of India) to Shri S. B. Chavan, the then Home Minister of India. The same is annexed herewith and Marked as "AnnexureB-8".

6. Letter dated 24^th July 1993 to Mr. Hashim Abdul Halim, the Speaker of West Bengal Assembly, with request to place the same before the Assembly the said Letter together with Letter dated 20^th April 1993 (Ref: Annexure "N" to the said application being Photocopy of the Letter dated 20^th April 1993 to Shri Jyoti Basu, the then Chief Minister of West Bengal.), but Mr. Halim show no courage to place the same before Assembly. The same is annexed herewith and Marked as "AnnexureB-9".

3. That after going through the documents of the Petitioner available to its Members, and other similar matters Vohra Committee clearly admitted that crime syndicates and mafia organisations have established themselves in various parts of the country. The mafia organisations have developed significant muscle and money power and established linkages with the governmental functionaries, with the political leaders and others to be able to operate their illegal activities with complete impunity. Since 1987 Petitioner stated the same thing on the basis of his sufferings in various Memorandums, Representations, Applications and Complaints submitted by the Petitioner before the President, Prime Minister, Honble Chief Justices of India, Home Minister, Finance Minister of India and other authorities, as some of them already referred under Paragraph 3 above and some of the rest will be referred in subsequent paragraphs to explain his matters of sufferings with supporting facts. As a result the then Home Secretary in his capacity as the Chairman of the Committee and Revenue Secretary as Member, besides other Members used the material facts referred in Memorandums, Representations, Applications and Complaints submitted by the Petitioner to prepare its report refers, besides other similar matters. In the present matter Politics-Bureaucratic-Crime-Nexus was based not less than a powerful politician in India Shri Jyoti Basu, the then Chief Minister of West Bengal, as a result severe atrocities were suffered by the Petitioner, for long 20 years or so. Photocopy of one of his Memorandum published under heading "A MATTER OF THE CALCUTTA MAFIA and challenges to ADMINISTRATION OF JUSTICE" dated 5^th September 1990, is annexed herewith and marked as "ANNEXURE-C-1". This memorandum was sent to all Members of Parliament, all Members of West Bengal Legislative Assembly, all Councilor of Kolkata Municipal Corporation, Members of the Judiciary and various other authorities. To escape from the actions against wrong doings said Mafia Leader Sanjay Kumar Jhunjhunwala his associates including Mr. Chuni Lal Mukherjee, adjudged Cheat Chittaranjan Ganguly, Kamlesh Chandra Chattopadhyay, Ava Rani Dey, Sukumar Das and others, under support from Shri Jyoti Basu, within few months from the despatch of the said Memorandum, particularly one M.L.A. of West Bengal Assembly Dr. Manash Bhuinya, decided to raise the said matter in West Bengal Assembly, a plot was hatched to kill son of the Petitioner, thus on 22^nd February 1991 a Truck accident was staged under Police protection. This is needless to be placed on record that in most surprising manner Memorandum dated 5^th September 1990 which was written in English was replied in Bengali by the Cooperation Department with reference to said Memorandum received by Chief Minister of West Bengal. Most surprising subject matter in the reply was referred from Page 7^th of the said Memorandum. But, thereafter they not replied that what action they have taken on the Memorandum. Photocopy of the said Reply Letter No. 329 Coop/H/3P/2/83(1) dated 24^th January 1991, (about one month before the Truck accident staged under Police protection to kill son of the Petitioner), is annexed herewith and marked as "ANNEXURE-C-2"
4. That this is open fact that the respective authorities not taken appropriate actions, against illegal and criminal activities as well as against use of black-money and muscle powers, as were requested by the Petitioner through his various Memorandums, Representations, Applications and Complaints, certainly under influence and / or misuse of the powers and abuse of the authorities, thus unscrupulous Businessman Sanjay Kumar Jhunjhunwala was turned as Mafia leader and developed a strong Mafiadom with the support of his associates, under his clear Nexus with and support from Shri Jyoti Basu and his Government Machinery. The respective authorities of Government of India is also not performed their respective obligations and duties in required appropriate manner, thus caused full protections to black-money and muscle powers of said Mafiadom, and virtually become instrumental to strengthen such Mafiadom. However, the atrocities suffered by the Petitioner was affirmed in the Report of Vohra Committee, and copy of the same as was available to the Petitioner is annexed herewith and marked as "ANNEXURE-D-1".
5. That Vohra Committee clearly admitted that in running of the mafia activities, black money have played a very effective but dangerous role to put the life and liberties of individuals (like the Petitioner) at complete stack. The Petitioner experienced same situation referred by the Vohra Committee in its Report, and he too realized that if the black money powers of the said Mafiadom can be checked, then only infringement of fundamental right of the Petitioner could be checked effectively. In such a considerations, petitioner approached each and every concerned authority requesting thereby to check the huge black money powers of the said Mafiadom even submitting detail facts relates to some of the transactions based on huge black-money, through representations. But, under most surprisingly, the Government of India through its each and every authority or subordinates including Revenue Secretary, Director General Revenue Intelligence, Chairman, Central Board of Direct Taxes, Director-General of Inv. (Inspection), W.B., Aaykar Bhawan, Kolkata, Appropriate Authority, W.B., Income Tax Department, Aaykar Bhawan, Kolkata Chief Commissioner of Income Tax, West Bengal Circle, besides the Chief Vigilance Commissioner, Director, Central Bureau of Investigation, maintained total silence, either under political pressure or influence or otherwise, thus strengthen the blackmailing activities of the said Mafiadom based on huge black-money and muscle powers, against the Petitioner. However, recently, Petitioner also informed to Mr. S. Narayan, the then Union Finance Secretary, Mr. Ajay Vikram Singh, the then Union Revenue Secretary, Mr. D.C.Gupta, the then Additional Secretary to the Finance Department, Shri Kamal Pandey, the then Union Home Secretary, Shri Yashwant Raj, the then Joint Secretary (Admn & PG), Ministry of Home Affairs, Shri N.Vittal, the then Chief Vigilance Commissioner, Mr. P.C.Sharma, Director, Central Bureau of Investigation, Mr. P.K.Sarma, the then Chairman, Central Board of Direct Taxes, Shri Sishir Sinha, Additional Director of Income Tax (Investgaion), Unit-II, Kolkata Shri Rajesh Kumar Bhoot, Dy. Director of Income Tax (Investigation), Unit-II(4) in respect of mafia activities based on huge black money causing severe infringement of the fundamental rights of the Petitioner. But, facts remains that respective aforesaid each and every authority and personnel either maintain silence or not taken appropriate actions to curb Mafiadom based black money and muscle powers of the said Mafiadom.

(Milap Choraria)