Sir,
smt. anita sandu akate is a widow of ex-serviceman of defense.she is cultivating her agricultural land in paithan saza. the land adjacent to her land belongs to joint family of Rodi residence of katpur tq. paithan dist. aurangabad. the following are the members of rodi family:-
1) Dharmarj Sitaram Rodi
2) Harishchandra Sitaram Rodi
3) Krishna Sitram Rodi
4) Gokul Sitaram Rodi
5) Baliram Sitaram Rodi
6) Kaushlayabai Sitaram Rodi
7) Chayabai Dharamraj Rodi
8) Surekha Krishna Rodi
9) Rukhmini Harishchandra Rodi
10) Renuka Baliram Rodi
11) Sujata Gokul Rodi
12) Bhimrao Dadarao Rodi
13) Nirmal Dadarao Rodi
14) Arjun Dadarao Rodi
15) Yogesh Dharamraj Rodi
who are intentionally causing injury to an age old widow in person and property. she was attacked by all above people on dated 30-10 . she lodged FIR on same date against above all culprits but police having hand in gloves with Bhimrao Dadarao Rodi, Nirmal Dadarao Rodi, Arjun Dadarao Rodi and Yogesh Dharamraj Rodi as they all are having political support. and due to political interference police of paithan namely shri. R S Kadam (API) an investigation officer was not fair enough to carry out investigation as directed by law. the paithan police station is not functioning as per direction of law, which is an offence in itself, under the supervision of shri Chikale (DySP). the complaint in respect to the same was made by victim to SP, Aurangabad Rural Police, Aurangabad which proved to be futile and police having hand in gloves with culprits had filed false FIR and filed Flase Ploice Final Report, which again an offence under section 167 of IPC in itself.
on dated 13-11 the above said culprits have intentionally ablaze the sugarcane standing crop in her land. the old lady is looking after her agriculture farms from Aurangabad. she went to police station paithan to report FIR against above named people but police have not registered it against the culprits and on the contrary they threatened the old lady. Not to register FIR in respect to Offence under section 435 R/w 149 or 34 is a cognizable offence, is itself an offence.
as the old lady is looking after her farm activities from Aurangabad, she is needed to engage farming employee. the employee whoever used to be engaged are threatened at night by throwing/pelting stones on farm employee quarters, so they should leave their job under pressure and old lady be compelled to sale that land of 10acres to above culprits. these sort of things can only be done when culprits are having hand in gloves with police. can anybody look into matter so that justice can be done with old lady smt Anita Sanduji Akate.
the paithan police be directed to register FIR under section 154 of Cr. P.C. for commission of Offences under section 435 r/w 149 or 34 as all the above said culprits were present at the time of setting the standing sugarcane crop on fire while burning culprits' cut off sugarcane field on dated 13-11 on saturday.
the action be taken on culprit police officers for not acting in accordance with the direction of law and for preparing false documents for causing injury to old lady and her near relatives. hence it is requested that:-
1. to lodge FIR against police officer concern for not acting in accordance with law and for preparing false documentation under section 166 and 167 r/w 34 of IPC.
2. to lodge FIR against all Fifteen culprits for commission of offence under section 435 r/w 149 of IPC for giving justice to age-old widow of ex-serviceman.
3. to initiate departmental inquiry of above said culprits so the faith of people will remain in police by way of causing suspension.
4.justice is expected in India having Rule of Law
thanks in anticipation
regards
forum for justice,
Aurangabad.
copy of earlier complaint to SP, Aurangabad (Maharashtra)
Application-cum-Complaint
To,
The Superintendent of Police,
Aurangabad District Rural Police,
Head Quarters, Cidco, Aurangabad.
Applicants-Cum-Complainants: - 1) Smt Anita wd/o Sanduji Akate,
Age: 65 years, Occu: Agriculture,
R/o: - plot no 1046, Sainagar,
Cidco N-6, Aurangabad.
2) Kirankumar S/o Sanduji Akate,
Age: 31 years, Occu: Service,
R/o: As Above
SUBJECT:- False FIR under section 154 of CrPC bearing number I89/09 dated 30/10 is being lodged against the Applicant-Complainants by the Accused no.4 with Revengeful Attitude.
Respected Sir,
We the above named Applicant-Complainants are law abiding citizen of India having respect towards rule of Law. The Applicant-Complainants submits and states as under:-
1) That, the Applicant-Complainant no.1 has given the first Complaint against the Accused people on dated 24/2 to police station, Paithan pertaining to Removing the boundary-marks and disturbing the boundaries and restraining access road to her Agricultural land bearing gut no 43/2 & 44/2 under Paithan Saza. When the Applicant-Complainant no 1 has tried to stop the Accused, the Accused had used abusive language and threatened her to kill. Accordingly police station Paithan has taken the Action on the Accused people under sections 149 & 107 of the CrPC by filing chapter case no. 15/09 on dated 14/3 before the Hon’ble Executive Magistrate, Paithan. The copies of chapter case and letter of intimation supplied to the Applicant-Complainant no 1 in respect to the action taken are annexed here with for your kind perusal.
2) That, The Applicant-Complainant no. 1 had started the development of her Agricultural land by way of leveling. During the transit, the below named Accused:-
1) Dharmaraj S/o Sitaram Rodi age :45 years Occu: Agri. R/o: katpur tal Paithan, Dist Aurangabad
2) Haribhau S/o Sitaram Rodi, age :40 years, occu/R/o: as above
3) Krishna S/o Sitaram Rodi, age :35 years, occu/R/o: as above
4) Baliram S/o Sitaram Rodi, age :32 years, occu/R/o: as above
5) Gokul S/o Sitaram Rodi, age :25 years, occu/R/o: as above
6) Arjun S/o Dadarao Rodi, age :50 years, occu/R/o: as above
7) Bhimrao S/o Dadarao Rodi, age :45 years, occu/R/o: as above
had caused criminal trespass on her land and stopped the function of leveling by way of using abusive language, beating and criminal intimidation on dated 22/5, which was very much Cognizable Offences committed by the Accused people as provided under sections 447, 323, 504, 509, 506 r/w 34 of IPC against the Applicant-Complainant no. 1 in respect to which, though complaint was made to police station Paithan, the private Complaint was filed against the above named accused people on dated 31/7. The Hon’ble Court of JMFC, Paithan was pleased to direct under section 156 (3) of CrPC to the police station Paithan to investigate the above said offences and to submit the report. The copy of the private complaint is annexed here with for your kind perusal. The accused had taken the Siphon illegally from the land of Applicant-Complainant no.1 by way of dismantling the irrigation turners and channels. The Applicant-Complainant no.1 being lonely lady at her farm and became the victim at the hands of above named accused people has made written complaints to different police and revenue authorities, in respect to which your good self was in receipt of letter dated 11/6 from Divisional Commissioner, Aurangabad. The copy of the letter issued by the Divisional Commissioner in the name of your good self is annexed here with for your kind perusal.
3) That, In the month of October thrice the theft has being committed, firstly of 1 mono block water pump, 2nd of sub-mercible water pump of 5 HP both belongs to proton company and, thirdly 25 bags of Samrat fertilizers along with other Agricultural equipments, for which the Complaint was lodged by the Applicant-Complainant no.2 on dated 17/10 on the very day of Diwali festival, bearing FIR no I83. The Applicant-Complainants has expressed the suspicion that the same would have been done by the Accused people. The copy of FIR no. I83 dated 17/10 is annexed here with for your kind perusal.
4) That, the Applicant-Complainant no.1 had sought the stay to the order dated 16/10 of Tahsildar, Paithan granting illegal permission to the accused to take siphon from standing sugarcane crop in her land on dated 21/10. The Accused people having criminal antecedent didn’t show any respect to the orders of lawful Authority and caused criminal trespass in the land of Applicant-Complainant no 1 and caused mischievous act by damaging the standing sugarcane crop of the Applicant-Complainant no.1 at the night of 21/10 & 22/10. The complaint pertaining to the same in writing was made to the police inspector Paithan and copies of the same were supplied for information and necessary action to Hon’ble District magistrate and to your good self. The above said act done by the accused people very much falls under the category of cognizable offence under section 447, 427 r/w 34 of IPC. The copies of the written complaint along with the stay order passed by Tahsildar Paithan on dated 21/10 with photographs of the damage caused to standing sugarcane crop are annexed here with for your kind perusal.
5) That, the Applicant-Complainant no.1 had made an application to the Tahsildar for carrying out the panchanama for assessing the illegal act of the above named accused people and for assessing the damage caused to the standing sugarcane crops of the Applicant-Complainant no.1. Accordingly, The Tahsildar has issued notice to one of the accused namely viz Gokul s/o Sitaram Rodi and to the Applicant-Complainant no.1 to remain present on the site on dated 30/10. The Applicant-Complainant no.1 was not feeling secured due to the criminal nature and attitude of the above named accused, had given a call to Applicant-Complainant no. 2 & her son-in-law. The applicant no.1 & 2 are mother and son in relation. The Applicant-Complainants reached to the spot of panchanama at about 11.30 am on dated 30/10 and were waiting for the Circle Inspector Revenue, Talathi and Kotwal. The below said accused has reached to the spot along with revenue officials and somewhere present in there own land in cotton field. As soon as, the work of panchanama was started the below named accused got afraid of getting unearth the truth which has been alleged by the Applicant-Complainant no.1 in her complaint made to police inspector, police station Paithan and the copies of the same supplied to your good self and district magistrate. The accused below named were more then 15 in numbers who got indulged in the act of rioting and causing grievous hurt to the above named Applicant-Complainants by way of making criminal trespass on the land of Applicant-Complainant no.1. When the officials of revenue department has directed the servant of Applicant-Complainant no.1 to dig the place of siphon for measuring the depth of it. The below named were the members of unlawful assembly as known to us as follows:-
1) Dharmarj Sitaram Rodi
2) Harishchandra Sitaram Rodi
3) Krishna Sitram Rodi
4) Gokul Sitaram Rodi
5) Baliram Sitaram Rodi
6) Kaushlayabai Sitaram Rodi
7) Chayabai Dharamraj Rodi
8) Surekha Krishna Rodi
9) Rukhmini Harishchandra Rodi
10) Renuka Baliram Rodi
11) Sujata Gokul Rodi
12) Bhimrao Dadarao Rodi
13) Nirmal Dadarao Rodi
14) Arjun Dadarao Rodi
15) Yogesh Dharamraj Rodi and other Unknown Persons were present.
The above accused no. 4 has used Criminal force against the Applicant-Complainant no.1, due to which she felt down. The accused no 1 to 5 had directed the accused no.6 to 11 to make Applicant-Complainant no.1 naked and beat her till she dies. The Applicant-Complainant no.2 when rushed to rescue his mother, the accused no.1 to 5 and accused no.12 to 15 had catch hold and had started beating the Applicant-Complainant no.2 with lathis of babul tree. When the whole episode was going on the son-in-law of Applicant-Complainant no.1 namely Prakash Shesharao Deshmukh rushed to rescue Applicant-Complainants no.2 from the clutches of the accused. The accused no 2, 3, 4, & 13 has turned there Morcha to catch hold and beat the son-in-law of Applicant-Complainant no.1 and has given blows of lathis by which he sustained the fracture injury at his palm of the right hand. However, Applicant-Complainants no 1 & 2 along with the son-in-law of Applicant-Complainant no.1 have been rescued by the revenue officers and some other person along with them from the clutches of accused. Applicant-Complainant no.1 had also sustained the grievous hurt to her left hand palm in the nature of dislocation of joint of fifth finger at the fountain of the palm. The accused no 1 to 5 and 12 to 15 has made an attack with lathis on Applicant-Complainant no 2 has given the vertical blows of lathis in the stomach and on the back of Applicant-Complainant no.2, due to which, when the Applicant-Complainants along with son-in-law of Applicant-Complainant no.1 has succeeded to rescue from the clutches of accused people, has reached to police station, where at Applicant-Complainant no.2 had started vomiting before Thane-Amaldar, police station, Paithan. Subsequently, the Thane-Amaldar, police station, Paithan has referred the Applicant-Complainants no.1, 2 and the son-in-law of Applicant-Complainant no.1 to the government medical practitioner at rural hospital Paithan. At the same time, the accused no.2 who was very active to give the lathi blows on the victim Applicant-Complainants no 1, 2 and the son-in-law of Applicant-Complainant no.1 was also referred for medical examination. Although he didn’t had any severe injury in his shoulder shaft still the MO of rural hospital Paithan has alleged severe injury for falsely implicating Applicant-Complainants and the son-in-law of Applicant-Complainant no.1 in the crime for causing grievous hurt. As it has been alleged by the accused no.4 in his complaint that the Applicant-Complainant no 2 and his brother-in-law has given the blow of the lathi is totally false, on the contrary, the eye witness of the scene are mainly circle Inspector (revenue) Shri. Harne, the Talathi Shri. Joshi of Paithan saza and the kotwal Shri. Misal along with them some fourth person was also present, who are having the complete knowledge of the facts and circumstances at the scene of offence committed by accused people. The complaint which was given by the Applicant-Complainant no.1 is found to be mistaken when it has been received by her because Applicant-Complainant no.1 who had made a complaint to police station Paithan is crystal clear that one who has taken the complaint has intentionally dropped some of the names of the above named accused no 12 to 15 which it is clear from the copy of the FIR and statement recorded of the Applicant-Complainant no.1 in which accused are not being added beyond no.12. In respect to the same the Applicant-Complainant no.1 has already supplied the corrigendum to her statement. The above named accused no 1 to 5 and 12 to 15 were involved in the act of rioting which had taken place in the preceding year at the time of pola in katpur, Taluka Paithan dist Aurangabad with More’s. The accused no 13 is also booked for causing the dowry death of his wife along with his near relatives by MIDC police station Paithan. The trail pertaining to the same is pending before the Hon’ble Criminal Court. The Accused no 4 has intentionally given the false complaint and Applicant-Complainants no 1 & 2 and the son-in-law of Applicant-Complainant no.1 with a revengeful attitude after the compliant is being filed by Applicant-Complainant no 1. The complaint filed by Applicant-Complainant no.1 is earlier in nature, which is crystal clear from the number of the FIR registered which bears the number I88 dated 30/10 and the FIR registered by accused no.4 is I89 dated 30/10. The copies of FIRs bearing no I88 and I89 are annexed here with for your kind perusal. It is also crystal clear that Applicant-Complainants no.1 and 2 along with the son-in-law of Applicant-Complainant no.1 rescued themselves from the clutches of such accused peoples having criminal antecedents. Hence no question arise to use the criminal force by us. Because we were being rescued by revenue officials and the servant of Applicant-Complainant no.1.
HENCE IT IS PRAYED AND HUMBLY REQUESTED THAT:-
a) The criminal antecedents of the above named accused may kindly be taken into consideration while carrying out the investigation of criminal offences committed by accused people;
b) As the Applicant-Complainant no.1 and her son-in-law has sustained grievous hurt, due to use of deadly weapons, in the nature of fractures due to blows of lathis;
c) The babul lathis used by the accused for beating the Applicant-Complainants no.1, 2 and the son-in-law of Applicant-Complainant no 1 may kindly be directed to be recovered for taking the accused people and victims of the incident to justice;
d) The IO be directed to jot down the statements of impartial witnesses of the scene with an impartiality;
e) As and when, the IO is being conversant with the facts of false complaints filed by accused no.4 be directed to prosecute the accused no.4 for giving false first information to police for putting the criminal law into motion against the Applicant-Complainants no.1 & 2 and the son-in-law of Applicant-Complainant no 1.
f) The IO of the concern police station in the present offences be directed to arrest the above named accused people.
THE APPLICANT-COMPLAINANTS ARE DUTY BOUND BY CRIMINAL LAW TO GIVE THE INFORMATION PERTAINING TO COGNIZABLE OFFENCES, AS AND WHEN REQUIRED BY LAW. HENCE HUMBLE REQUEST TO PUT THE CRIMINAL LAW INTO MOTION AGAINST THE ABOVE NAMED ACCUSED AND OBLIGED.
Date :- Applicant-Complainants
1) Smt Anita wd/o Sanduji Akate
2) Kirankumar S/o Sanduji Akate
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