Thursday, June 16, 2016

Notice to initiate legal (Criminal) and disciplinary action

Ashok S. Verma
(Social & RTI Activist)
Manavata foundation
C/o. Leagas Law Associates
S-2, New Veena C. H. S. Ltd.
Veer Savarkar Nagar,
 Vasai Road (West) – 401202
Mobile: 9320475000


1.  The Director General of Police,
        Maharashtra State,
        Police Head Quarter,
        Colaba, Mumbai – 400001

2.  The Secretary Home,
Department of Home,
Home Ministry, Govt. Of Maharashtra,
Mantralay, Mumbai – 400032

3.  The Chief Secretary,
Government of Maharashtra,
Mantralay, Mumbai – 400032.

Reference:  a) Application dated 01/06/2016 for registration of   
                       F.I.R. addressed to Sr. P.I. Manikpur Police  
                       Station, Taluka Vasai, District Palghar;

                            b) Email dated 02/06/2016 complaint for 
                                Incomplete registration of F.I.R. No. 142 / 2016
                                   Manikpur Police Station District Palghar addressed 
                                   to various Police officers and others;

                                c)  Application dated 11/06/2016 for registration of  
                                     F.I.R. by Mr. Aaditya V. Dongre (Victim) 
                                     addressed to Sr. P.I. Manikur Police Station and 
                                  Sr. P.I. Tulinj Police Station, Taluka Vasai, District

                                 d) Agitation before additional Superintendent of
                                     police, Vasai from 14/06/2016 onwards by Dr. 
                                     Vinayak Dongre against injustice and inhumanity 
                                     with his Son Mr. Aditya Dongre (Victim).

Sub.: Notice to initiate legal (Criminal) and disciplinary action against (1)   
          Mr. Ranjeet Pawar the Sr. P.I. Manikpur Police Station, (2) Mr.
          Anil Patil Sr. P.I. Manikpur Police Station, (3) Mr. Prakash Birajdar
          Sr. P.I. Tulinj Police Station, (4) Mr. Anil Aakad S.D.P.O. Vasai, (5)
          Mr. Yogesh Kumar (I.P.S.) Additional Superintendent of Police
          Vasai, (6) Smt. Sharda Raut (I.P.S.), Superintendent of Police
          Palghar & others Unknown…..

Dear Sir/Madam,

Kindly refer above cited letters and complaints and go through the facts and circumstances of two cases which are as follows:

A)  Facts of the application given by Ashok S. Verma as informant of F.I.R. number 142/2016 Manikpur Police Station:

 “After struggling for a day I partially succeeded in registering F.I.R. against officers, Engineers, contractors of Vasai Virar City Municipal Corporation and Officers of Western Railway those who are responsible for the incident that occurred on 31/05/2016 under section 337 and 338 of I.P.C.. Whereas, my complaint is disclosing cognizable offences punishable under Section 337, 338, 406, 420, 34 of Indian Penal Code 1860 and Section 13 of the Prevention of Corruption Act, 1988.

I say that Sr. P.I. Manikpur is duty bound by the Law and by the departmental rules to take cognizance of a cognizable offence if it comes in his knowledge. Accordingly by not registering or not taking
cognizance of my complaint in its entirety he has violated and disobeyed law and departmental rules in this regard, and not only this the Sr. P.I. Mr. Ranjeet Pawar and Mr. Anil Patil have violated  the provisions of the Criminal Procedure Code and committed offence under section 166, 217, 218 of I.P.C.

B)  Facts of Application given by Mr. Aditya V. Dongre as Victim:

On 10th June 2016 around 1.00 A.M. while I was returning from Sector 2 to come back to my home, as I approached the first gate of sector 2 located in Vasant Nagri, Vasai Road East, a random car Maruti Suzuki Swift Sports, colour possibly white and blue graphics approached towards me with a life threatening speed and halted just inches away. A man in casual clothes approached towards me shouting all foul and insulting words (abusive & filthy language) and charged a blow towards my face. I somehow managed to duck it and in self-defence pushed the man away from my body.

Then after this incident on a sudden, a person in police uniform got down of the car and caught my neck with strangulating power and pushed me inside the car. While I tried to resist this action the unknown person hit me with a rod on my head. They then took me to Tulinj Police Station while giving all bad words and life threating language and took me at the first floor which I later discovered to be called as a detection room of the building and he is police officer P.S.I. Shivde Tulinj Police Station. Shivde pushed me inside the room and ordered the unknown men to start beating me and tried to kill me.

All the men including the persons who were inside the car started beating me with rods and belts and caused me physical and mental wounds. They thrashed me for around 3 hours and then offered me a place to sleep on the ground beside them and also applied an ointment on my body to possibly hide the wound marks. They woke me up in the morning around 7 A.M. and thrashed me again and forcefully asked me to sign an unidentified blank paper and register. After requesting them in fever, they released me. I realized that I was robbed of rupees 5000 and they also damaged my phone. I was left with 300 rupees in my wallet. I somehow managed to board an auto rickshaw and managed to come home. All the above mentioned things were ordered and monitored by P.S.I. Shivde. I am ready and willing to handover mobile phone, Torn T-shirt with ointment stains damaged by Shivde and others as well as said wallet.

This incident has broken me mentally and I have lost all my confidence as capable person to achieve normal academic challenges in the future.

I fear this could happen again and another attempt would be made on my life by the same accused.

Therefore, I hereby request you to kindly register my complaint as First Information Report for offence of Kidnapping, Robbery, Assaulting and Grievous Hurt, Attempt to Murder, Threatening for life with dire consequences and Criminal Conspiracy, Fraud, Fabrication of false Evidence and take action against the P.S.I. Shivde and 8 Unknowns accused as per law for the want of justice.”

Now please investigate the History of Accused P.S.I. Shivde as I have received some information from my reliable sources which I am ready to disclose during investigation if F.I.R. registered in this case, as Criminal Shivde is habitual to apply third degree on innocent people where as he is not empowered to apply the same on any one.

i)            In a case pertaining to the old jurisdiction of Nalasopara west police station, Shivde has tortured an innocent Father (known as Thakur) of a young pair who was major in age. All this happened for black money by way of corruption and contract to do illegal tasks in police uniform.

ii)          Criminal Shivde is an agent for local Mafiya and goons and helps them in grabbing the lands of poor.

iii)        Criminal Shivde has helped an accused of Murder, taken place on a highway in Nalasopara East and the Dead body was found in Car…..

iv)         Criminal Shivde was transferred twice in response to the complaints by and then Victims and by giving black money to his seniors he was again brought back to Vasai Taluka……

v)           Criminal Shivde once was put on suspension but suspension was revoked by then S.P. Thane and for this Rs. 7, 00,000/ was paid through his driver…

vi)         A contempt petition no. 555/2013 is pending before Hon’ble Bombay High Court against Criminal Shivde…..

Now my following issues to be considered and may be answered accordingly;

a)   Whether the Police officers who are having information about occurrence of cognizable offence are not duty bound to take cognizance of such crime? thus are they not guilty of violation of Section 154 Cr. P.C.  and departmental circular issued in this regard?

b)  Whether the above mentioned police officers have not committed offences under section 166, 217 & 218 of Indian Penal Code 1860?

c)   Whether the above mentioned Police officers are not guilty of the contempt of the Court as per judgement passed by Hon,ble Supreme Court in the matter of Lalita Kumari Vs. Government of Uttar Pradesh in year 2008?

Therefore it is my humble request to all of you to ensure registration of my complete F.I.R. and register F.I.R. of Mr. Aditya V. Dongre followed by fair and impartial proper investigation. And also take legal criminal & departmental disciplinary action against (1) Mr. Ranjeet Pawar the Sr. P.I. Manikpur Police Station, (2) Mr. Anil Patil Sr. P. I. Manikpur Police Station, (3) Mr. Prakash Birajdar Sr. P.I. Tulinj Police Station, (4) Mr. Anil Aakad S.D.P.O. Vasai, (5) Mr. Yogesh Kumar (I.P.S.) Additional Superintendent of Police Vasai, (6) Smt. Sharda Raut (I.P.S.), Superintendent of Police Palghar & others immediately.

I hope your good office will do the needful in time bound manner & oblige.

Thanking You,

Yours faithfully,

Ashok S. Verma

Place: Vasai

Copy to with request to take necessary action in the matter:

1.  The Hon’ble Home Minister of Government of Maharashtra, Mantralay, Mumbai -400032.

2.   The Hon’ble Chief Minister of Government of Maharashtra, Mantralay, Mumbai -400032.

3.  The Hon’ble Home Minister government of India, North block, Parliament House, New Delhi – 110001.

4.  The Hon’ble Prime Minister, Government of India, South Block, Parliament House, New Delhi – 110001.

5.  The Hon’ble State Human Right Commission, Maharashtra, Mumbai

6.  The Hon’ble National Human Right Commission of India, New Delhi – 110001.

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