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Published by OutlookMagazine
Pradeep Sharma's affidavit
Pradeep Sharma's affidavit

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Published by: OutlookMagazine on Nov 24, 2013
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11/29/2013

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 1
IN THE SUPREME COURT OF INDIA
 
CRIMINAL ORIGINAL JURISDICTION
 
CRL MP NO. ______ OF 2013
 
IN
 
WRIT PETITION (CRIMINAL) NO. 171 of 2011
 
IN THE MATTER OF:
 
PRADEEP N. SHARMA …Petitioner/Applicant
VERSUS
 
STATE OF GUJARAT &
OTHERS …Respondents
APPLICATION FOR DIRECTIONS
 
TO
THE HON’BLE CHIEF JUSTICE OF INDIA
AND HIS COMPANION JUSTICES OF
THE HON’BLE SUPREME COURT OF INDIA
THE HUMBLE APPLICATION OF THE PETITIONER ABOVE NAMED. MOST RESPECTFULLY SHOWETH:
 
1.
That the Petitioner/Applicant has filed the accompanying writ petition seeking the transfer of the One FIR lodged against him, from the Gujarat State Police Crime Branch to an independent investigative agency, i.e. the Central Burea
u of Investigation (“CBI”). This Hon‟ble Court has
 
 2
been pleased to issue notice and the instant case is now ripe for disposal.
 
2.
It has been the consistent submission of the Applicant herein since the last several years, that he has been victimized and implicated in the said FIRs due to the personal animosity, malice and mala fide of the State
Government at the behest of the Hon‟ble Chief Minister of
the State of Gujarat
 –
 Shri Narendra Modi- Respondent No. 3 herein. The reasons for this victimization are twofold
 –
firstly since the Applicant herein is the younger brother of Shri Kuldip Sharma IPS (Retd.) who incurred the wrath of the Respondent no.3 herein due to his refusal to follow the illegal diktats of Shri Narendra Modi and Shri  Amit Shah (the then Minister of State, Home, of the State of Gujarat) during the tenure of Shri Kuldip Sharma as the  Additional Director General of Police (ADGP) CID-Crime, State of Gujarat, as clearly enumerated in Paras 8 to 14 of the accompanying writ petition, contents of which are not reproduced herein to avoid prolixity.
3.
Secondly-
the Applicant‟s knowledge of the intimacy
shared by Shri Narendra Modi with a young lady architect, aged 27 years, from Bangalore, but originally from Bhuj in Gujarat, who was introduced to Shri Modi by the Applicant himself in the year 2004.
 
 3
4.
That the Applicant herein joined the State Administrative Services in the year 1981 and was promoted to the IAS cadre in the year 1994. The Applicant has enjoyed impeccable service record and has not faced even a Departmental proceeding against him let alone registration of an FIR till the Respondent No. 3 assumed charge as the Chief Minister of the State of Gujarat, and an upright officer, who never faced even a departmental proceeding in his entire career from 1981 to 2010, was suddenly implicated in 6 (six) FIRs from 2010 to 2012.
5.
That the Applicant herein was the District Magistrate of Kutch (with Bhuj City as the District HQ) during the period of 2003-2006. During this tenure, he commissioned a series of projects towards the beautification of Bhuj City which was devastated by an earthquake in the year 2001. One of the beautification projects was development of a Hill Garden in the year 2005 for which the said female architect was hired as the landscape architect. The said female architect was introduced to Shri Narendra Modi by the Applicant during the inaugural function of the said Hill Garden by Shri Modi in the year 2004.
6.
The Applicant herein verily believes that the Respondent no. 3 and the said female architect remained in touch with

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