To,

The Hon’ble Tribunal for Senior Citizens,

Jabalpur, MP

Plaintiff: Smt. Shashi Kiran Vishwakarma, w/o Late Dr. B D Vishwakarma,

aged 77 years, Caste: Carpenter (OBC) r/o House no. 820 Dening Road, Civil
Lines, Jabalpur, Pin Code:482001 (MP)

V/s

Defendant 1: (main accused): Dr. Amita Gupta, d/o Satya Narayan Prasad,
Caste: Hindu Baniya R/o Flat F – 5, Paras Kunj Apartment, Mahewa Gate, Opp
Agriculture College, Cheoki, Allahabad, Pin Code:211007 (UP)

Defendant 2: Sri Ravi Prakash Gupta, S/o Satya Narayan Prasad, R/o Varanasi

Defendant 3: Sri Narsingh Nath, S/o Ram Prasad Viswakarma, R/o H – 372,
Ayodhya Nagar, Bhopal, Pin Code: 462023 (MP)

Abstract: The gist of the contentious issue is that my daughter-in-law Dr. Amita
Gupta, wife of late Navneet Vishwakarma, who is serving in UP State Govt. as a
Veterinary doctor has all along been harassing me for converting my late
husband’s self aquired/ earned properties to her name. Amita Gupta has adopted
all unethical, cruel and illegal means to achieve her selfish ends. Pray for
tribunal’s kind intervention under major civil and criminal acts including
Maintenance and Welfare of Parents and Senior Citizens Act, 2007

With a heavy heart, anguish and extreme feelings of anxiety and insecurity, I
wish to humbly place on record the following averments and pray to the
Hon’ble Tribunal for my protection, maintenance and succour.
That, I am a widow of 77 years of fragile age and suffering from various age-
related ailments including severe high blood pressure that hospitalizes me very
often. My two sons have passed away. My married daughter is 55 years of age,
otherwise very helpful and non-interfering, mostly stays peacefully with her
family in faraway Jaipur. As such, I am solely taking care of Vinayak
Vishwakarma, my grandson (son of my deceased older son) as his only legal
guardian since my husband’s demise around six years back.

My younger son, Dr. Navneet Vishwakarma, who was serving as a veterinary

doctor in MP Government, recently passed away on 08/08/2023 at the age of 51
years. He was suffering from severe depression and other related medical
conditions.

Citing one of the recent ugly incidents in that regard, on 27/06/2023, while my
son Navneet was admitted in the ICU at Shalby Hospital in Jabalpur, Dr. Amita
Gupta, accompanied by her siblings, viz. Ravi Prakash Gupta, Rajneesh Gupta
and Sushma Gupta entered unannounced in my home at house no. 820, Denning
Road, South Civil Lines, Jabalpur and misbehaved, coerced and threatened me
with dire consequences. My grandson Vinayak was present during that
aggression by the Gupta family. While it is well known that I am a high BP
patient and that their high decibel and pitched shouting traumatised me severely,
they did not relent. The matter relating to Navneet’s hospitalization was only
limited to forcing me to pay the hospital bills. They did not bother to address the
issue of Navneet’s medical recovery even once.

While my son Navneet was very depressed and sick in the ICU at Shalby
hospital, Jabalpur for over 2 months, from mid-April until June 27 th, 2023, I
nursed him single-handedly and paid 90% of the hospital bills. Amita Gupta
came to Jabalpur only sparingly for only a few hours. It may kindly be noted
that even as my son (now deceased) was, and my daughter-in-law was/is a
government employee and earning decent salaries, Amita Gupta refused to pay
for the hospital bills leaving me with no option but to pay the huge bills for my
ailing son from my finite and fast depleting savings left behind by my late
husband.

When Amita realised that Navneet may not live too long, she took my son
forcefully to Prayagraj. Instead of admitting him to a hospital, Amita Gupta kept
him locked in their flat from 9am until 4pm, while she went to work. Navneet
was very depressed and sick and unable to go to the bathroom all by himself or
even drink a glass of water. Under those circumstances, I offered to pay for a
nurse to take care of Navneet in order to feed him, bathe him etc, but Amita
refused. She continued to lock him up all alone in her Paras Kunj Apartment in
Prayagraj.

After around 10 days of keeping Navneet confined in a locked-up condition, his

condition deteriorated so much that he had to be hospitalised in the ICU, from
where my son never returned home. I rushed to Prayagraj on July 18, 2023 and
nursed my son as much as I could in the hospital till his dying days. Here too
Amita and her elder brother would taunt and misbehave with me.

After Navneet passed away on 08/08/2023, he was cremated in Prayagraj even

as it was Navneet’s last wish that he be brought to his birthplace Jabalpur for the
last rites. Amita refused to honour his last wishes even when I agreed to pay all
expenses to transfer his body from Prayagraj to Jabalpur.

While he was being cremated at Prayagraj, Navneet’s body was exposed till the
shoulders due to grossly inadequate cremation wood bought for the purpose
(photo attached). Thereafter, Amita refused to perform the basic rituals like
Phool Visarjan (i.e., immersing the bones in sacred Ganga). Navneet’s mortal
remains were subsequently unceremoniously brushed away the next day with a
broom by the crematorium workers. Amita Gupta did not do the Thervi, which
is the 13th day puja and havan for the deceased to pray for the departed soul on
their onward journey to the next realm. All these rituals were not performed
solely because Amita did not want to spend money for these basic ceremonies.

From the above para, the learned court can well visualize the abyss that Dr
Amita Gupta stooped for money. It also reflects her attitude towards not only
me but her erstwhile (late) husband.

While Amita did not perform any of these Hindu rituals, she is being
unnaturally rushed in asking for her undue share in the property of my late
husband. Within a month of Navneet’s demise, she has lost no time in harassing
and threatening me for the property.

Soon after the death of Navneet, Amita Gupta has been busy securing the family
pension of Navneet solely for herself even as she is getting her full government
salary and staying in a flat acquired through my late son’s income and saving. In
directing the family pension of Navneet, she has selfishly precluded my share
even as I am bearing the responsibility including monetary for me and my
orphan grandson’s inter-alia living, education and medical expenses etc. She has
also grabbed the fixed deposit certificates and other assets of her late husband
with complete disregard to norms of civilised human societies.

It may be mentioned that we belong to OBC Carpenter caste whereas she is

from a higher caste, i.e., Gupta Baniya caste. This gave her reason to torture my
son, and misbehave with him. Living with a avaricious and casteist lady that she
has proven to be, my son lost all motivation and will to live.

Ever since the demise of my husband almost six years back, Amita Gupta has
never come to assist me or my grandson. Even during recent months when I had
been hospitalised, Amita Gupta has abandoned me from rendering any
assistance.

I have a flat in Dwarka, Delhi which served as my source of income for the
upkeep, education etc for my orphaned grandson Vinayak. Meanwhile, even
before I could recover from the mourning of the untimely death of my younger
son on 8/8/2023, Amita Gupta sent a mischievous email on 5/10/2023 (copy
attached) to the Society Secretary of Airforce Naval Officers’ Enclave to
prevent me from renting out the flat, thus pre-empting the source of income of
an aged widowed lady who is single handedly taking care of Vinayak
Vishwakarma, an orphaned child since he was an infant.

I am residing in my house in South Civil lines. Following the unfortunate

incident of misbehaviour, aggression and coercion on June 27, 2023, I fear for
my mental and physical safety. Seeing her insatiable greedy nature, where she
began demanding for her undue share in the property within a month of the
demise of her husband Navneet’s death, she will definitely follow the same
course as she has in Dwarka, New Delhi flat above and prevent me from living
in peace and protecting my own dwelling in Civil Lines.

Meanwhile, Amita Gupta has been garnering support from unscrupulous

persons for grabbing my property. In another incident, Amita visited the
residence of Narsingh Nath in Bhopal on 3/10/2023 to conspire further towards
weeding me out from my own property. She night halted at Nath residence and
on the morning 4 am of 4/10/2023, Narsingh Nath dropped her at the railway
station to board the 5 am train for Jabalpur. Despite my exhortation in the past,
Narsingh Nath continues to support Amita covertly in all her unethical
activities.

On 4/10/2023 Amita Gupta post her conspiratorial discussions with Narsingh

Nath, came to my Civil Lines house at Jabalpur to pressurise me for the
properties. During that visit, she again harassed and threatened me to hand over
all property to her at the earliest. Amita Gupta left for Prayagraj on 5/10/2023
morning and soon thereafter, sent an email dated 5/10/2023 to Wg Cdr (Retd)
KGR Menon, Society Secretary, Airforce & Naval Officers’ Enclave (AFNOE)
CGHS Ltd. Sector 7, Dwarka, New Delhi, (copy attached). Thereby, she again
displayed her extremely insensitive and vulgar avarice to grab my property.

Kindly note that Amita has all along harboured a superiority attitude with
respect to her caste status vis-à-vis our family. In that regard, she has since her
marriage to Navneet maintained her legal name as Dr. Amita Gupta, due to her
feeling of caste superiority. This was done to suppress the fact that she, a higher
caste baniya is married to Navneet, a lower caste OBC. However, now as she is
quickly demanding her share in the property, all her documentation mentions
the surname as Amita Gupta Vishwakarma for mere convenience. Similarly, she
has always maintained her son’s name as Prasenjeet Vishwakarma so as to take
advantage of the OBC status for admissions/job application etc. All these facts
speak of her cunning manipulative nature.

If anything, un-to-ward happens to me due to all this unjustified aggression and

harassment, Amita Gupta and her supporting cronies should be held responsible.

Prayer for Cause of Action:

Due to above mentioned conduct of cruelty and illegal avarice towards a hapless
senior citizen still smarting under the multiple aggression and trauma meted out
to me on umpteen occasions, I pray to the Hon’ble Tribunal to:

1. Prohibit physical access to her and her cronies from my house at 820
Denning Road, Civil Lines, Jabalpur.
2. Direct Amita Gupta that if she has any issues pertaining to mine or my
late husband’s bequeathed property/ies, she may like to avail legal
 recourse rather than aggressively harassing and/or coercing me into
handing over property and monies to her unethical and cruel self.
3. Direct the Secretary of Airforce & Naval Officers’ Enclave (AFNOE)
CGHS Ltd. Sector 7, Dwarka, New Delhi that in the absence of any court
order or injunction, the resident society should refrain from restraining
renting of my Flat no 138 from being rented out by self to bonafide
tenants. As such, they may like to not act on the instant email sent by
Amita Gupta till such time there are no court orders in that regard and
status quo ante may be maintained with respect to the de facto and
rightful owner i.e., self. The letter sent by me to the Secretary of AFNOE
is attached herewith as exhibit.
4. Counsel cronies like Amita Gupta’s elder brother Sri Ravi Prakash Gupta
and Sri Narsingh Nath to not play an adversarial role in instigating Amita
Gupta to grab property of mine and my late husband and refrain from
interfering in personal issues and privileges that perhaps need to be
resolved through due process of law.
5. Advice the Head of Department of Directorate of Animal Husbandry and
Dairying, MP Government that the family pension of my late son
Navneet Vishwakarma should be equitably shared between Amita Gupta
and me in the spirit of The Maintenance and Welfare of Parents and
Senior Citizens Act, 2007. The fact that I have to maintain the properties
of my late husband till the rightful heirs assume possession of the same
through due process of law and that I continuing to bear all maintenance
of Vinayak, my orphaned grandson who is still pursuing academics, may
please be considered as my additional responsibilities and financial
burden in the family.
6. Advise Amita Gupta from treating me and my orphaned grandson with
motivated casteist disdain.