1

IN THE HIGH COURT OF JHARKHAND AT RANCHI

(CRIMINAL WRIT JURISDICTION)

W.P. (Cr.) No………… Of 2023

IN THE MATTER OF:

An application under Article

226 of the Constitution of In-

dia

AND

IN THE MATTER OF:

Aloke Majumdar, aged about 66 years, S/o Late Santosh Kumar Majum-

dar, Resident of –4th Street Anantpur, Doranda, P.O.- Doranda, P.S.-Do-

randa, District-Ranchi, Jharkhand-834002.

…….. PETITIONER

:VERSUS:

1. The State of Jharkhand,

2. The Director General of Police, Govt. of Jharkhand, At- Project Build-

ing, P.O. & P.S. Dhurwa, District- Ranchi

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3. The Deputy Inspector General of Police, Ramgarh Range, At, P.O. &

P.S.- Ramgarh, Dist.- Ramgarh, Jharkhand.

4. The Superintendent of Police, Ramgarh Range, AT, P.O. & P.S. -Ram-

garh, District-Ramgarh, Jharkhand.

5. The Deputy Superintendent of Police, Ramgarh, AT, P.O. & P.S.- Ram-

garh, District-Ramgarh, Jharkhand.

6. Officer-In-Charge, Ramgarh Police Station, Ramgarh, AT, P.O. & P.S.-

Ramgarh, District-Ramgarh, Jharkhand.

7. Investigating Officer, Ramgarh P.S. Case No. -361/2018, P.O. & P.S.-

Ramgarh, District-Ramgarh, Jharkhand.

8. Reader, The Superintendent of Police, Ramgarh Range, AT, P.O. & P.S.

-Ramgarh, District-Ramgarh, Jharkhand.

9. The Director, Central Bureau of Investigation.

…………….RESPONDENTS

To,

The Hon’ble Mr. Justice Sanjaya Kumar Mishra

the Chief Justice of the High Court of Jharkhand

at Ranchi and His other Companion Judges of the

said Hon’ble Court.

 3

The humble petition on behalf

of the petitioner above named.

MOST RESPECTFULLY SHEWETH

1. That, in the instant writ petition, the petitioner prays for following

reliefs by issuance of appropriate writ(s), Order(s) / Direction(s)

upon the respondents:

i. For a direction upon an independent authority (Central Bureau

of Investigation) to make proper, fair and impartial investiga-

tion in Chutia P.S. Case No. 176/2023 (Annexure-15) for the

offences under Section 306/34 of the Indian Penal Code, 1860

pending in the Court of Learned Sri Shambhu Mahto, JM,

Ranchi in right direction and in a fair manner for the suicide

committed by the son of the petitioner, Mr. Supriyo Mazumdar

(hereinafter referred to as the deceased).

ii. The petitioner prays for issuance of appropriate writ(s),

order(s) and direction(s) upon the Respondent Central Bureau

of Investigation to investigate into the matter of suicide com-

mitted by the son of the petitioner, Mr. Supriyo Mazumdar,

who had been threatened and intimidated by the police authori-

 4

ties of Ramgarh Police station with a fear to arrest him and to

further falsely implicate him in a false and frivolous case, be-

ing Ramgarh P.S. Case No. – 361/2018 dated 05.09.2018.

iii. For further direction to immediately make investigation against

the name accused / real culprits so that the real facts / truth

may be unveiled and the real culprits are booked for criminal

trial so that they should get punishment in accordance with

law.

iv. The petitioner prays for issuance of such other order or orders

as Your lordship may deem fit and proper in the interest of Jus-

tice.

2. That the petitioner has not moved before this Hon’ble Court for

same self relief as prayed in present writ petition or for any other

relief in connection with the present case.

3. That the petitioner is a citizen of India and the cause of action for

filing the instant writ application have also taken place within the

territorial jurisdiction of this Hon'ble Court.

4. That, moot points of law involved in present writ petition are

as follows–
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i. Whether the respondents are bound by their statutory and con-

stitutional duty of providing justice to the petitioner by making

proper investigation in the matter?

ii. Whether respondents are duty bound to consider and take

appropriate action in accordance of law as state power can

be only used to save the life, liberty and dignity of each and

every citizen enshrined under article 21 of the constitution of

India?

iii. Whether the fact being that the son of the petitioner was sub-

jected to threatening by local police authorities at Ramgarh

P.S. because he was the prime witness in two CBI cases that

have been instituted on the information provided by the Bank

of India, Ramgarh Branch, regarding a huge bank fraud?

iv. Whether the fact being that the sudden act of suicide commit-

ted by the deceased just after 3 (three) days of meeting the po-

lice officials at Ramgarh Police Station casts a serious doubt

over the conduct and approach of the police officials towards

the citizens of this country?

v. Whether the fact being that the deceased received a notice u/s

41A of the CrPC after lapse of 5 years from the date of regis-
 6

tration of FIR (Ramgarh P.S. Case No.-361/2018), in itself in-

dicates the malafide of the state police authorities?

vi. Whether the fact being that the Police officials of the Ramgarh

Police Station in connivance with the highly influential ac-

cused persons of the ongoing two CBI cases have threatened

the prime witness (deceased) in that matter to such an extent

that he has been compelled to commit suicide?

vii. Whether the fact being that the sudden death of the deceased

would jeopardize the entire proceedings initiated against the

high ranking officials of the bank as the deceased was the

prime witness in both the cases?

viii. Whether the respondent state authorities have miserably failed

to accord necessary protection to the prime witness (deceased)

in the two ongoing CBI cases?

ix. Whether the action of threatening the deceased to the extent of

implicating him in a false case and by extending fear of arrest

by the police officials of the Ramgarh Police Station is against

the mandate of article 21 of the constitution of India?

x. Whether in facts and circumstances of the present case and

considering the fact that the petitioner’s son has committed

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suicide because of the threat inflicted to him by police officials

of the Ramgarh Police Station, present case is a fit case for

handing over the matter to an independent agency for proper

investigation in the matter?

xi. Whether the inaction of the respondent authorities amounts to

violation of fundamental right of petitioner and is negation of

rights enshrined in part – III of constitution of India?

xii. Whether an independent agency can make better investigation

if there is chance of biasness in making investigation?

xiii. Whether speedy and fair investigation is a species of Article 21

of the Constitution of India?

5. That the brief fact giving rise to the present case is that the de-

ceased joined the Bank of India as a Probationary Officer at Ram-

garh Cantt Branch, Ramgarh (Jharkhand) on 11/08/2015, the ser-

vices of the deceased was confirmed on 16/03/2018.

6. That during the period of August 2015 to June 2017, Mr Bongra

Kumar Singh was functioning as Credit Head in the capacity of Se-

nior Manager - Credit whereas Mr Prafulla Kumar Behera was the

Chief Manager of Ramgarh Cantt branch and also the Branch Head

of Bank of India. During the above period, the deceased was func-
 8

tioning as Probationary Officer in the said branch and was assigned

duties related to credit (loan) section by his superior authorities.

7. That between the period January 2016 to June 2017, multiple

tankers along with it’s chasis were financed to multiple borrowers

by the Sanctioning Authorities of Ramgarh Cantt Branch of Bank

of India. Later on as part of internal investigation initiated by the

bank, it was revealed that fraud was committed against the bank by

one Mr Sanjay Shah, his brother Mr Mukesh Shah, Mr Ravikant in

connivance with then Senior Manager - Credit of the branch Mr

Bongra Kumar Singh and with then Chief Manager of Ramgarh

Cantt branch- Mr Prafulla Kumar Behera.

8. That it is pertinent to mention herein that the Bank of India had is-

sued guidelines on 12/08/2016 regarding processing of Loans by

Junior untrained Staff on probation and their misuse by the senior

employees of the Bank. In the aforesaid circular, it was advised that

newly recruited officers in Junior Management Cadre who are on

probation or having service less than 2 years, may not be asked to

recommend and process the loans, unless it forms part of their

training Process
 9

Photocopy of the Circular dated

12/08/2016 issued by Bank of India

has been annexed herewith and

marked as Annexure-1, which forms

part of this instant writ application.

9. That both the senior officials of the bank, namely Mr. Bongra Ku-

mar Singh and Mr. Prafulla Kumar Behera misused their high posi-

tions and in violation of the above mentioned circular, compelled

the deceased to process the loans during the probation(training) pe-

riod. Moreover, the deceased was put under the fear of certainty of

his job if he would have denied processing the loans as directed by

his seniors.

10.That upon detection of fraud the Sanctioning Authorities of the

branch, namely Mr Bongra Kumar Singh (then Senior Manager -

Credit) and Mr Prafulla Kumar Behera (then Chief Manager and

branch head) were placed under suspension with immediate effect.

Further Bank of India lodged two FIRS with Central Bureau of in-

vestigation, Ranchi mentioned as below:-

i. Case No RC093201850010 (RC-10 (S) / 2018 / CBI / EOW R)

dated 19-12-2018, and

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ii. Case No RC0932018S0011(RC-11(S)/2018/CBI/EOW-R) dated

19-12-2018.

11.That the contents of the FIR dated 19-12-2018, being Case No

RC093201850010 (RC-10 (S) / 2018 / CBI / EOW R) was regis-

tered u/s 120B r/w Section 420,467,468 & 471 of the Indian Penal

Code,1860 against the below named accused persons.:

i. Sanjay Shah, (Propreitor) of M/s Siddhivinayak Enterprises.

ii. Mukesh Shah, (Propreitor) of M/s Bharat Logistics & M/s

Shiva Transport.

iii. Ravikant Prasad, Branch Mnager, M/s Enar Industrial Enter-

prise (authorized dealer of Tata Motors)

iv. Unkown others.

Photocopy of the FIR dated

19/12/2018 has been annexed here-

with and marked as Annexure-2,

which forms part of this instant writ

application.

12.That on completion of investigation in Case No RC093201850010

(RC-10 (S) / 2018 / CBI / EOW R) , the Central Bureau of Investi-

gation submitted it’s chargesheet in the instant matter on

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23/03/2020 u/s 120B r/w Section 420 of the Indian Penal Code ,

1860 and Section 13(2) r/w Section 13(1)(c) (d) of the Prevention

of Corruption Act, 1988 against the below named:

i. Sanjay Shah, (Propreitor) of M/s Siddhivinayak Enterprises.

ii. Mukesh Shah, (Propreitor) of M/s Bharat Logistics & M/s

Shiva Transport.

iii. Bongra Kumar Singh, Senior Manager – Credit (Bank of India,

Ramgarh Cantt. Branch)

Photocopy of the chargesheet dated

23/03/2020 has been annexed here-

with and marked as Annexure-3,

which forms part of this instant writ

application.

13.That it is noteworthy to mention herein that the deceased (Mr.

Supriyo Mazumdar) had been mentioned as a witness in the

chargesheet submitted by the CBI in Case No. RC093201850010

(RC-10 (S) / 2018 / CBI / EOW R) at Sl. No. 62.

14. That on completion of further investigation in Case No

RC093201850010 (RC-10 (S) / 2018 / CBI / EOW R) , the Central

Bureau of Investigation submitted it’s supplementary chargesheet

 12

in the instant matter on 25/10/2021 u/s 120B r/w Section 420 of

the Indian Penal Code, 1860 8 against the below named:

i. Ravikant Prasad, Branch Mnager, M/s Enar Industrial Enter-

prise (authorized dealer of Tata Motors)

Photocopy of the supplementary

chargesheet dated 25/10/2021 has

been annexed herewith and marked

as Annexure-4 which forms part of

this instant writ application.

15.That the second FIR dated 19-12-2018, being Case Case No.

RC0932018S0011(RC-11(S)/2018/CBI/EOW-R) was registered u/s

120B r/w Section 420,467,468 & 471 of the Indian Penal

Code,1860 against the below named accused persons.:

i. Sanjay Shah, (Propreitor) of M/s Siddhivinayak Enterprises.

ii. Mukesh Shah, (Propreitor) of M/s Bharat Logistics & M/s

Shiva Transport.

iii. Ravikant Prasad, Branch Mnager, M/s Enar Industrial Enter-

prise (authorized dealer of Tata Motors).

iv. Bhim Rana, (Propreitor) of M/s Bhim Body Builders.

v. Unknown Others
 13

Photocopy of the FIR dated

19/12/2018 has been annexed here-

with and marked as Annexure-5,

which forms part of this instant writ

application.

16.That on completion of investigation in Case No.

RC0932018S0011(RC-11(S)/2018/CBI/EOW-R), the Central Bu-

reau of Investigation submitted it’s chargesheet in the instant mat-

ter on 17/12/2020 u/s 120B and Section 13(1)(c)&(d) of the Pre-

vention of Corruption Act, 1988 against the below named:

i. Sanjay Shah, (Propreitor) of M/s Siddhivinayak Enterprises.

ii. Mukesh Shah, (Propreitor) of M/s Bharat Logistics & M/s Shiva

Transport.

iii. Ravikant Prasad, Branch Mnager, M/s Enar Industrial Enterprise

(authorized dealer of Tata Motors).

iv. Bhim Rana, (Propreitor) of M/s Bhim Body Builders.

v. Basant Mahto.

vi. Bongra Kumar Singh, Senior Manager – Credit (Bank of India,

Ramgarh Cantt. Branch)

vii. Rajesh Shah (Brother of Sanjay Shah)

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Photocopy of the chargesheet dated

17/20/2020 has been annexed here-

with and marked as Annexure-6

which forms part of this instant writ

application.

17.That it is noteworthy to mention herein that the deceased (Mr.

Supriyo Mazumdar) had been mentioned as a witness in the

chargesheet submitted by the CBI in Case No.

RC0932018S0011(RC-11(S)/2018/CBI/EOW-R) at Sl. No. 45.

18.That it is to further state that the deceased had been given a ‘clean

chit’ in both of the cases by CBI as on the basis of the statements

made by the deceased, CBI was able to conclude the investigation

in both the matters and had submitted the Chargesheet.

19.That it is to further state that with respect to one of the loan which

was a subject matter of investigation by CBI, during pendency of

the investigation by CBI, one Mr. Anil Mathur, who was also a wit-

ness in CBI Case, had instituted an FIR, being Ramgarh P.S. Case

No.-361/2018 on 05.09.2018 . The informant in this case was one

of the ‘loanee’ whose name has already been mentioned in the

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chargesheet submitted by the CBI on 23/03/2020 in. Case No.

RC093201850010 (RC-10 (S) / 2018 / CBI / EOW R).

Photocopy of the FIR dated

05/09/2018 has been annexed here-

with and marked as Annexure-7

which forms part of this instant writ

application.

20.The contents of the aforementioned FIR mention regarding the

fraud committed by one, Mr. Sanjay Shah, who got a loan sanc-

tioned in informant’s name. Thereafter, the informant further al-

leged that Mr. Sanajy Shah received the delivery of two chasis on

behalf of the informant and got it registered in the name of his

brother, i.e. Mr. Mukesh Shah. Further, the loan amount sanctioned

by the bank was also received by Sanjay Shah.

Photocopy of the written complaint

given by Anil Mathur to Superinten-

dent of Police, Ramgarh has been an-

nexed herewith and marked as An-

nexure-8 which forms part of this in-

stant writ application.

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21.That it is now noteworthy to mention herein that on 12/08/2023, i.e.

after a lapse of around 5(five) years, the deceased received a notice

u/s 41 A of the Code of Criminal Procedure, 1973 from the Ram-

garh P.S. in the matter related to Ramgarh P.S. Case No. 361/2018,

wherein he was asked to be physically present on 17/08/2023 at

11.00 A.M. in the police station.

Photocopy of the 41-a CrPC notice

issued by the Ramgarh P.S. has been

annexed herewith and marked as An-

nexure-9 which forms part of this in-

stant writ application.

22.That after receiving the notice u/s 41 A of the Code of Criminal

Procedure, 1973 from the Ramgarh P.S., the deceased wrote and

sent a detailed letter to Superintendent of Police of the Ramgarh

Zone on 16/08/2023 and explained him the entire matter.

Photocopy of the letter written by de-

ceased to the Superintendent of Po-

lice of the Ramgarh Zone has been

annexed herewith and marked as An-

 17

nexure-10 which forms part of this

instant writ application.

23.That the deceased on 17/08/2023 personally visited the Ramgarh

P.S. and explained the entire case the I.O. of the Ramgarh P.S. Case

No. 361/2018, wherein in detail he elucidated the happening of the

entire incident, along with the fact that CBI had already investi-

gated the matter and had submitted two chargesheets in the case,

wherein he is the ‘prime witness’.

Photocopy of the reply to the 41-a

CrPC notice issued by the Ramgarh

P.S. has been annexed herewith and

marked as Annexure-11 which

forms part of this instant writ appli-

cation.

24.That it further pertinent to mention herein that the deceased was ha-

rassed and threatened by the police officials of the Ramgarh P.S.,

that he would be arrested in the said matter, despite the fact being

that the deceased met the police officials of the Ramgarh P.S. on
 18

17/08/2023 and explained the entire matter in detail. Such harass-

ment was apparently at the behest the persons who had been made

an accused by CBI. The son of the petitioner was threatened by the

police of dire consequences for giving statement to CBI.

25. That the petitioner along with his son under such circumstances,

the deceased, went to meet the Deputy Superintendent of Police

and Superintendent of Police of the Ramgarh Zone, but they could

not meet them. In the meantime, when the deceased was unable to

meet the S.P., the reader of the Superintendent of Police of the

Ramgarh Zone further gave him a life threat and further threatened

him with the fear of arrest in the said matter.

26.That after returning from Ramgarh P.S. on 17/08/2023, the de-

ceased was under great depression and anxiety as his life as well as

his family member’s life was at threat. The deceased was continu-

ously being bothered by the police officials of the Ramgarh P.S.

wherein he was subjected to utmost mental cruelty and torture, left

with no other option the petitioner’s son therefore committed sui-

cide on 20/08/2023.

Photos depicting the suicide commit-

ted by the deceased has been annexed

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herewith and marked as Annexure-

12 series which forms part of this in-

stant writ application.

27.The deceased before committing suicide has written a detailed sui-

cide note wherein he has explained the happening of the entire

event starting from 2015- till date. The contents of the said suicide

note clearly name the below mentioned people responsible for his

death:

i. Bongra Kumar Singh, Senior Manager – Credit (Bank of In-

dia, Ramgarh Cantt. Branch)

ii. Prafulla Kumar Behera Chief Manager & Branch Head

(Bank of India, Ramgarh Cantt. Branch)

iii. Police officials of Ramgarh.

Photocopy of the deceased’s suicide

note has been annexed herewith and

marked as Annexure-13 which

forms part of this instant writ appli-

cation.
 20

28. That a post-mortem examination was conducted over the deceased

by Dr. Ruth Chand, Department of Forensic, Medicine & Toxicol-

ogy on 20/08/2023. The main reason behind the death of the de-

ceased has been detected to be due to asphyxia as a result of hang-

ing. The main point of highlight in the aforesaid post mortem report

is that the doctor has found 2 ligature marks on the neck of de-

ceased. There are two ligature marks, one is measuring 2cm to

2.5cm in width situated over the middle part of neck and its all

around the neck. The 2nd ligature marking is measuring 2cm to

2.5cm arises from the first ligature mark on the anterior aspect of

middle part of neck and is oblique and continuous all around the

upper part of neck.

Photocopy of the deceased’s post-

mortem report has been annexed

herewith and marked as Annexure-

14 which forms part of this instant

writ application.

29.That thereafter the petitioner lodged an FIR with the Chutia P.S.

being Chutia P.S. Case No. 176/2023 for the offences under Sec-
 21

tion 306/34 of the Indian Penal Code, 1860 against the below

named:

i. Bongra Kumar Singh, Senior Manager – Credit (Bank of India,

Ramgarh Cantt. Branch)

ii. Prafulla Kumar Behera Chief Manager & Branch Head (Bank of

India, Ramgarh Cantt. Branch)

iii. Current I.O. of Ramgarh P.S. in Ramgarh P.S. Case no.

361/2018

iv. Current Reader of the Superintendent of Police, Ramgarh P.S.

Photocopy of the FIR dated

22/08/2023 has been annexed here-

with and marked as Annexure-15,

which forms part of this instant writ

application.

30.That on 25/08/2023 the petitioner wrote a letter to the Assistant Su-

perintendent of Police, CBI to investigate and take action against

the named persons who have been the reason for the death of the

deceased, under the consideration that his son was the prime wit-

ness in 2(two) CBI matters.

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Photocopy of the letter dated

25/08/2023 has been annexed here-

with and marked as Annexure-16,

which forms part of this instant writ

application.

31.That by letter dated 30/08/2023 bearing Ref. No. 566/CC-

140/2023-R, the DIG/Head of Branch, CBI replied to the aforemen-

tioned letter sent by the petitioner on 25/08/2023 and stated that

CBI lacks jurisdiction to act suo-moto the subject and hence the

complaint is closed.

Photocopy of the letter dated

30/08/2023, sent by CBI has been an-

nexed herewith and marked as An-

nexure-17, which forms part of this

instant writ application.

32.The fact that needs due consideration in the said matter is that in a

mere span of 7 (seven) days, i.e. from the date on which the de-

ceased received the notice u/s 41 A (12/08/2023) to the date when

 23

he committed suicide (20/08/2023), he was subjected to such

threatening and mental pressure that he could not withstand the

same and with no other option left he committed suicide.

33.That it is submitted that the main reason behind the threatening and

torture so subjected to the deceased was because he was the prime

witness in 2 (two) CBI cases which involved investigation pertain-

ing to a big bank fraud committed by some highly influential peo-

ple in connivance with high ranking bank officials.

34.That it is submitted that the local police are not investigating fairly

into the matter of death of the son of the petitioner and the real cul-

prits, who are moving scott free and are treating themselves to be

above law and are creating a reign of terror for the family of the pe-

titioner.

35.That it is submitted that if the state police would not thoroughly en-

quire and investigate into the matter, as the real culprits in this mat-

ter are itself the police officials of the Ramgarh Police Station .

36. That it is submitted that because of the biased and perfunctory

investigation by the state police, the petitioner had lost all faith in

the Administrative machinery of the state, which had been acting

 24

under the influence of the powerful people, who are behind the sui-

cide of the son of the petitioner, Supriyo Mazumdar.

37. That it is submitted that the petitioner have been demanding for fair

and impartial investigation into the matter so that the real culprits

may be caught hold of and several letters to this effect has been

submitted by him to the police and other officials.

38. That it is submitted that the state police is sitting tight over this

matter and showing very lackadaisical approach and hence it is in

the interest of justice that the main reason and people responsible

for the suicide committed by the son of the petitioner be referred to

any independent investigating body/ Central Bureau of Investiga-

tion so that public faith be restored in administration.

39. That it is submitted that there is a great resentment and the faith of

the local people over the police authorities had also shaken because

of unfair and partial investigation.

40. That it is submitted that because of the police authorities not dis-

charging their duties and maintaining Rule of Law, the petitioner

and his family are under huge fear and threat.

 25

41.That it is stated that the accused has been running from pillar to

post praying simply for proper and fair investigation of the case but

nothing is being done regarding the same.

42.That, that the petitioner has got no other efficacious and alternative

remedy, except by filing this writ application for redressal of his

genuine and bona fide grievances.

43.That, this application is being made bona fide and in the interest of

justice.

It is, therefore, humbly prayed that Your

Lordships may graciously be pleased to is-

sue RULE NISI commanding upon respon-

dents to show cause as to why the relief

prayed in paragraph-1 of this writ applica-

tion be not allowed to the petitioner and

upon return of the RULE and cause shown

if any as well as after hearing the Learned

counsel of the parties, be further pleased to

grant following reliefs to the petitioner:-

i. For a direction upon an independent

authority to make proper, fair and im-

 26

partial investigation in Chutia P.S.

Case No. 176/2023 for the offences un-

der Section 306/34 of the Indian Penal

Code, 1860 pending in the Court of

Learned Sri Shambhu Mahto, JM,

Ranchi in right direction and in a fair

manner for the suicide committed by

the son of the petitioner, Mr. Supriyo

Mazumdar (hereinafter referred to as

the deceased).

ii. For issuance of appropriate writ(s), or-

der(s) and direction(s) upon the Re-

spondent Central Bureau of Investiga-

tion to investigate into the matter of

suicide committed by the son of the pe-

titioner, Mr. Supriyo Mazumdar, who

had been threatened and intimidated by

the police authorities of Ramgarh Po-

lice station with a fear to arrest him

and to further falsely implicate him in

 27

a false and frivolous case, being Ram-

garh P.S. Case No. – 361/2018 dated

05.09.2018.

iii. For further direction too immediately

make investigation against the name

accused / real culprits so that the real

facts / truth may be unveiled and the

real culprits are booked for criminal

trial so that they should get punishment

in accordance with law.

iv. The petitioner prays for issuance of

such other order or orders as Your

Lordships may deem fit and proper in

the interest of Justice.

And for this the petitioner shall ever pray.

 28

AFFIDAVIT

I, Aloke Majumdar, aged about 66 years, S/o Late Santosh Kumar, Majumdar,

Resident of –4th Street Anantpur, Doranda, P.O.- Doranda, P.S.-Doranda, Dis-

trict-Ranchi, Jharkhand-834002., do hereby solemnly affirm and state as fol-

lows:-

1. That I am Petitioner and Informant of the concerned criminal case and as

such, am well acquainted with the facts and circumstances of the case.
2. That I have gone through the contents of this application and have fully under-
stood the same.
3. That the statements made in para nos.
are true to my knowledge, those made in para nos. are
based upon information derived from the records of the case and rest are by
way of submissions before this Hon’ble Court.
4. That the annexure is photo copy/true copy/certified copy of its original.
5. That I do hereby verify, swear and sign on _________________ before this
Hon’ble Court at Ranchi.
29
 30

IN THE HIGH COURT OF JHARKHAND AT RANCHI

(CRIMINAL WRIT JURISDICTION)

W.P. (Cr.) No………… of 2023

Aloke Mazumdar … … … Petitioner

Versus

The State of Jharkhand& Anr. … … … Respondent

Sub: - Police Inaction

INDEX

Sl. Nos. Particular of papers Page

Nos.

Writ Application with affidavit. 1-

1. Annexure-1 Photocopy of the Circular dated

12/08/2016 issued by Bank of India.

2. Annexure -2 Photocopy of FIR dated 19-12-2018,

in Case No RC093201850010 (RC-10

(S) / 2018 / CBI / EOW R).

3. Annexure -3 Photocopy of the chargesheet dated

23/03/2020 in Case No
 31

RC093201850010 (RC-10 (S) / 2018 /

CBI / EOW R).

4. Annexure -4 Photocopy of the supplementary

chargesheet dated 25/10/2021 in Case

No RC093201850010 (RC-10 (S) /

2018 / CBI / EOW R).

5. Annexure-5 Photocopy of the FIR dated 19-12-

2018, in Case Case No.

RC0932018S0011(RC-11(S)/2018/

CBI/EOW-R).

6. Annexure-6 Photocopy of the chargesheet dated

17/20/2020 in Case Case No.

RC0932018S0011(RC-11(S)/2018/

CBI/EOW-R).

7. Annexure-7 Photocopy of FIR, dated 05.09.2018

in Ramgarh P.S. Case No.-361/2018.

8. Annexure-8 Photocopy of the written complaint

given by Anil Mathur to Superinten-

 32

dent of Police, Ramgarh.

9. Annexure-9 Photocopy of the 41-a CrPC notice is-

sued by the Ramgarh P.S.

10.Annexure-10 Photocopy of the letter written by de-

ceased to the Superintendent of Police

of the Ramgarh Zone.

11. Annexure-11 Photocopy of the reply to the 41-a

CrPC notice issued by the Ramgarh

P.S.

12.Annexure-12 Photos depicting the suicide commit-

series ted by the deceased.

13.Annexure-13 Photocopy of the deceased’s suicide

note.

14. Annexure-14 Photocopy of the deceased’s post-

mortem report.

15. Annexure-15 Photocopy of the FIR dated

22/08/2023 in Chutia P.S. Case No.

176/2023.
 33

16. Annexure-16 Photocopy of the letter dated

25/08/2023 sent by the petitioner to

CBI.

17.Annexure-17 Photocopy of the reply dated

30/08/2023 sent by CBI to the peti-

tioner.

VAKALATNAMA