To,

The Director General of Police, Date 22/11/2017

Home Department, Govt. of Bihar,
Patna (Bihar) 800015

Ref: - Please refer to Bihta P.S. Case No. 872/17– Copy of the FIR enclosed for your
kind perusal.

Sub:- With regard to making request for (1) saving our modesty from being outraged
as the local police barging into my house in the night (2) Supervising the
above referred police case and (3) taking action against the erring local police.

Respected Sir,
With regard to above mentioned subject and reference I have to state that I have
been left with my mother in law, sister in law and children as all the male members
have been fled away from home apprehending their arrest and subsequent torture by
the local police in the false & fabricated above referred case.

Some startling facts of the above said case

1. Informant of the above said case is no way related to us but witness no. 1 of
this case is the eldest brother of my father in law –Please see the copy of
enclosed FIR. Sir, did you not sense something fishy in this case.

In fact, we have a land dispute with Sri Rajeshwar Rai –although not in any
court and he wants to grab that piece of land by the hook or by the crook.
Therefore, he is using informant and local police as instrument for coercing us
to leave our legal right over that piece of land.

2. Sir, even if you presume all information given in the FIR is prima facie true.
You will not find any ingredient related to sec. 354 IPC in this case.
 The sole objective of the insertion of sec.354 IPC is to make this case non-
bailable.– Please peruse the copy of FIR enclosed with this application.

Sir, anyone can sense the power of money and influence of informant and
their men involved for insertion of this section in above said case.

3. Although there is not any injury caused to any in this case –It may be very
simple in nature even if any as there was a minor scuffle I admit it,

Sec. 307 IPC was inserted solely with purpose to misuse the process of law
against my family & to pressurize us to give our land to Sri Rajeshwar Rai.

Sadly I don’t have any evidence with regard to this at present but I request
your good self to ask for the injury report from the local police and supervise
the case according to that.

4. Sir, this case was very well planed in advance well before registration of FIR
on dated 31/10/2017. The men behind informant had apprehension that if any
grievous injury caused to my family member the local police shall be bound to
register the counter case.

To mitigate such eventuality and to misguide the police & court, the men behind
informant have sent apprehension petition of such incident in the name of
informant to the senior police official on dated 07/10/2017 via post.

Sir, I also got injured in that incident and at first I went to the Neora O.P. under
Bihta P.S. for registration of the FIR of this incident. The officer there kept my
application and said that the case has been lodged.

But he lodged false & fabricated case against my father in law, my husband and
brother in law on the influence of money provided by the eldest brother of my
father in law.
Atrocities of local police personnel
1. After registration of the said FIR on 31/10/17, police personnel of Neora O.P.
under Bihta P.S. has barged into my house a dozen times at wee hours, seat
on bed of female members for hours, use abusive language without having
any valid search warrant only at instance of Sri Rajeshwar Rai & Informant of
the above said case.

2. Also on dated 20/11/2017 a at 4:00 AM, officer in charge of Neora O.P. along
with case I.O. and other police personnel has barged into my house after
breaking open the lock of gate.

They searched the home, used abusive language, snatch the quilts and
blankets which I & my sister in law and children were draping while
sleeping– only to disturb, oppress and pressurize at the instance of Mr.
Rajeshwar Rai & informant of the above referred case.

3. Sir, local police is also threatening my relatives and family friends that they will
have the same fate as of mine if they provide any help for securing bail to my
husband and my sons from the court of law.

4. Sir, I am living under virtual house arrest– even worse than that, in the day men
(anti social aliment) of Mr. Rajeshwar Rai and the informant of the above
referred case abuse us using filthy language and in the night police personnel of
Neora O.P. often barge into my house and use same filthy language in front of
female members and children. Sir, life became hell for our family.

Prayers, Reliefs and action Sought

1. Sir, I pray to you with folded hands that please restrain the police personnel
of Neora O.P. from barging into my house– especially in the wee hours as I
have every apprehension that someday the modesty of the female members of
my family would be outraged by their hands. That’s why I have decided to take
 the atrocities of police personnel of Neora O.P. into the cognizance of the senior
police officials.

2. As there is not any ingredients of sec. 354 IPC in the FIR, only inserted to make
the case non-bailable, this may also be true with sec 307 IPC. Therefore, I pray
you to kindly ask for injury report from the case I.O. of the above referred case
and kindly supervise the investigation of the case yourself under section 36 of
Cr.P.C. as I have reasons to believe that the local police will not investigate the
case in fair manner.

3. As there is not any ingredient of sec. 354 IPC in the FIR even if you assume
every word of FIR is true– Copy enclosed for your kind perusal. Only inserted
for making the referred case non-bailable whereby causing injury to my
husband, father in law and brother in law by the police officer responsible for
lodging the said FIR, You may order the registration of FIR against responsible
police officer for framing the incorrect FIR under sec. 167 of IPC immediately
without any delay.

4. Sir, I am quite sure that police personnel of my local police station will
apprehend, abuse, torture or implicate my family members, relatives and family
friends in false and fabricated cases after knowing I have informed the senior
police officials of their unlawful activities. Therefore I pray you to kindly keep
this letter on record and do the needful to mitigate such eventuality.

Therefore, you are requested, in all seriousness and with due care and attention, make
an inquiry into facts of the above referred case and other submissions made
hereinbefore and take the effective action at earliest in this regard.
Enclosures: - With Due Respect
As above

Soni Devi
W/o Sri Seshnath Rai,
R/o Purainiya Goriyadera,P.O. Neora, P.S. Bihta, Distt Patna
.
Copy to: - The Deputy Inspector General, Patna for information and for necessary action.
With Due Respect

Soni Devi
To,
The Deputy Inspector General
(Central Range),
Police Headquarters, Gandhi Maidan,
Patna (Bihar) 800001.

Ref: - Please refer to Bihta P.S. Case No. 872/17– Enclosure I.

Sub: - With regard to submission of my second written representation in the above

referred case.

Respected Sir,
With regard to above mentioned subject and reference, I have to state that Sir,
you are also the victim of trickery resorted by the informant of the above
said case –apart from me and my family.

Sir, I have raise the above proposition with due care, and taking full
responsibility that if I proved otherwise I shall be liable to be penalized under
suitable sections of Indian Penal Code.

Coming to the point, you have suspended the first I.O. of the above referred
case vide your official notification No. 7270 on dated 08/11/2017, citing reason
“Accused of the above said case has assaulted and broken the leg of the son
of informant but the case I.O. has been unsuccessful in arresting the accused.”

But, Sir, on dated 31/10/12, the medical officer of the Bihta referral hospital, in
his injury report, has reserved his opinion for left elbow of the son (not for
leg) of informant and found simple injury on legs, please see the injury report of
the Bihta referral hospital –Enclosure II.

On dated 17/12/2017, medical officer of the Bihta referral hospital in his

supplementary injury report prepared on the basis of report of PMCH bearing
No. 21215 dated 23/11/17, has declared nature of left elbow injury simple in
nature, please see injury report of PMCH and supplementary injury report of
the Bihta referral hospital –Enclosure III and IV respectively.
 Sir, I don’t blame you for taking immediate stern action after seeing the
false POP boot casting on the leg of the son of informant and presuming the leg
was broken by the accused of said case. Anyone could have been befooled
seeing that false POP boot casting. But citizenry do expect from the senior IPS
official like you to act smart and responsible way rather be fooled by tricksters.
Sorry to say, but, you were so prejudiced that you had returned my first
representation in original through local police station submitted by my wife –
Simply unimaginable.

Repercussions of your unjustified and prejudiced actions:-

1) Reinforced by your orders, policemen of my local police station had resorted
excessive oppression by way of invading my home in the dead of night,
slapped, misbehaved, threatened women and children of my family on
regular basis –please call the case diary from the I.O. of the said case and
peruse yourself.

2) Showing your suspension order of the first I.O. to the learned A.C.J.M. of
Danapur Civil Court, the current I.O. of case had been able to procure NBW
against us on the day of application itself and initiated coercive steps
bypassing major procedures of section 82/83 of Cr.P.C.

3) I had been arrested, handcuffed, fettered and paraded barefooted in lungi

from my village to the Neora O.P. on dated 29/11/2017 even after the order
of learned Additional Session Judge VI of Danapur civil court to not to take
coercive steps on dated 27/11/2017, on the pretext that they were unaware of
such orders which is very unlikely as local policemen were working hand in
gloves with the conspirators of the above said case – Photographs of my
handcuffing and fettering is enclosed as Enclosure V.

4) Buoyed by your order obtained on falsification, conspirators of above said

case wreck havoc on me and the members of my family. They are
incessantly abusing, manhandling and chasing me and my family members.
All our hard earned reputation of my family has bitten the dust.
Prayers/Reliefs Sought:-
1) Be pleased to supervise this case yourself and do the needful to file final
report or remove unsuitable sections of IPC as the above said case is the
best example of falsification and fabrication of evidence. You are, also,
the victim of fabrication of evidence by informant. The said FIR was
lodged in retaliation to the Criminal complaint case no. 1096/2017 –
enclosed as Annexure 6, which I have instituted against the husband and
son of informant including others in the Court of ACJM Danapur on
dated 09/10/2017. You won’t find any ingredients of sec. 354 and 307 of
IPC in the FIR, only inserted with a view to make the case non-bailable.
Only general and omnibus allegations of assault have been leveled
against us as no such incident happened and injuries were intentionally
inflicted by conspirators of the said case.

2) The informant of the said case has resorted trickery to obtain favorable
orders for oppression of me and my family. Her deception caused you to
suspend the first I.O. of the case on baseless reason. On the strength of
your unjustified order, the local policemen invaded several times my
home in the dead of night. Therefore apart from me and my family, first
I.O. of the case and you yourself is also the victim of fabrication of
evidence by informant of the said case. So, be pleased to conclude and
initiate action against the informant of the said case u/s 193 and other
suitable sections of IPC. Apart from that, in the light of above settings,
the valid reason for punishing delinquency is not to avenge injury caused,
but to prevent future injury to someone else. And, therefore, if it is true
that, “if one is to be hanged so that others may not steal”, then I appeal
you to punish the informant of the said case not only to get justice for
self but also for the good of the society.

Enclosures: - As above With Due Respect

Sheshnath Kumar
To, Date 29/01/2018
R/o Purainiya Goriyadera,P.O. Neora,
P.S. Bihta, Distt Patna
The Deputy Inspector General
(Central Range),
Police Headquarters, Gandhi Maidan,
Patna (Bihar) 800001.

Ref: - Please refer to Bihta P.S. Case No. 872/17– Enclosure I.

Sub: - With regard to making request to stop process of attachment warrant till the
finalization of anticipatory bail bearing Cr. Misc. no. 4960/18 and 3845/18
pending before Hon’ able Patna High Court– Web copy enclosed.

Respected Sir,
With regard to above mentioned subject and reference, I have to state that my
male members of the family were made accused in the above referred false and
fabricated case.

Sir, you are also the victim of trickery resorted by the informant of the above
said case as you have suspended the First I.O. of the case on false submission of
informant that accused has broken leg of her son. But subsequently it is found in
medical report that all the injuries were simple in nature–Copy of letter notification no.
7692/अप० शशा० enclosed for your kind perusal.

Sir, My male members of family are not absconder in the eye of law, rather they
submitted themselves to authority of Hon’ able Patna High Court and taking remedy
provided by constitution of India.

Therefore, I request, with folded hands, you to kindly give order to stop attachment
process with immediate effect otherwise our family would be inflicted serious injustice
in above said false and fabricated case.
Sincerely Yours

Soni Devi
w/o Seshnath Rai, R/o Goriya Dera, P.S. Bihta (Neora), Patna