Complaint against Zonal Manager Eastern Railway and Divisional Railway Manager Katihar Bihar for organizing Gang Rapes and illicit sex trade of Women and Children at Sonaili Railway Station which requires registration of an F.I.R against the delinquent officers-

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To
The Chairman
Railway Board
Government of India
New Delhi
Sub: Complaint against Zonal Manager Eastern Railway and
Divisional Railway Manager Katihar Bihar for organizing
Gang Rapes and illicit sex trade of Women and Children at
Sonaili Railway Station which requires registration of an F.I.R
against the delinquent officers-reg.
Sir/Madam,
1. That under signed is OM PRAKASH S/O Late Shri Deep
Narayan Poddar, Age about 48 years, R/O Asha Deep Niwas,
Shukkar Hatt, Sonaili Village, P.S. Kadwa, District Katihar,
Bihar-855114 and R/O RZF-893, Netaji Subhash Marg, Raj
Nagar Part-2, Palam Colony, New Delhi-110077 and Petitioner-
in-Person in the Prostitution matter in Writ Petition (Criminal)
No. 242/2021, Interlocutory Application No. 66686/2022 in
Writ Petition (Criminal) No. 137/2021 and Writ Petition
(Criminal) Diary No. 18546/2022 before Supreme Court of
India.
2. That State sponsored Gang Rape victims are more than 50
women and minor girls from Petitioner’s families including his
18 years ago kidnapped pregnant wife Rina Kumari alias Guddi
D/O Surender Narayan Poddar, Rtd. Assistant Manager (RC),
Marketing Division, Brauni Refinery, Begusarai, Bihar and
never seen 17 years old minor daughter. Pregnant wife Rina

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Kumari alias Guddi was kidnapped on 15.04.2005 by the State
from Gali No.12, Raj Nagar Part-2, Palam Colony, New Delhi
and being pushed into prostitution. She has been caught into
prostitution along with her minor daughter on 05.04.2021 at C-
128/5, Gali No.07, Shastri Park, North East Delhi by the
petitioner.
Original photograph of Gang Rape Victim Rina Kumari
(Guddi) supplied by her father on 24th
June 2004

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Plastic Surgery Photograph of Gang Rape Victim Rina Kumari
(Guddi) along with sex abuser collected by the Petitioner
during her Gang Rape event at Sonaili, Katihar Bihar dated
11th
May 2022.
3. That some of the victim’s name are Shri Surendra Narayan
Poddar, Assistant Manager (RC), IOC, Baruni Refinary, Ms.
Anita Poddar wife of Surendra Narayan Poddar, Rina
Kumari, Anuja Kumari, Rupam kumari alias Dolly daughters

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of Surendra Narayan Poddar and Anupam Kumar son of
Surendra Narayan Poddar R/O R.H. 5/6, Baruni Refinary,
Township, Begusarai and Jagdish Path, Bailey Road Apartment
206, Malti Bihari, Patna, Bihar, Har Har Mahadev Chowk,
Begusarai, Bihar, IOCL Quarter, Bank More, Dhanbad
Jharkhand.
4. That suspected cases of Child Sexual Abuse (CSA) and
persistent Gang Rapes have been identified at Ram Kumar’s
house, C-128/5, Gali No.07, Shastri Park, North East Delhi a
owner of M/S R.K Fashion at Gandhi Nagar, Delhi on 05th
April
2021. Case of sexual abuse and forced hidden prostitution of
minor girls have been reported to NCPCR Government of India
vide POCSO E-Box hit No. 2290 dated 12.04.2021. Dastagir
Qumar Nodal coordinator ChildLine Delhi has intervened into
the case along with Delhi Police and confirmed the same
through email dated 17.04.2021 at 7:44 PM to the petitioner.
However, the rescues of the victims have been suppressed with
handsome bribe and recording false police statement.
Thereafter, victims have been re-pushed into the clutches of
prostitution with greater magnitude. That PIL Writ Petition
(Criminal) No.242/2021 for direction of registration of an F.I.R
has also been dismissed by the Supreme Court of India on
25.10.2021 due to non-appearance of Legal Aid Advocate in
this matter. Hence, rescue of victims is being suppressed
permanently.
5. That another Suspected case of Child Sexual Abuse (CSA)
has been identified on 12.09.2022 inside the house of Mr.
Vivekanand Jha, an astrologer and superstitious man, R/O

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Shukkar Hatt, behind Goddess Durga Temple at Sonaili Village,
Kantiya Panchayat, P.S. Kadwa, Katihar, Bihar. Victim is tall,
strong build, Delhi breed, minor 17 years old but looking major
girl frequently disappears from Sonaili Katihar Bihar for
outdoor sex. She has been seen today dated 12.09.2022 at
Sonaili Rilway Station under DRM katihar, eastern railway
Zone along with a fatty, bulky sex abuser Rajput caste girl to
catch Siliguri-Katihar bound local train at 9.30am. Suspected
CSA case has been reported to Bihar as well as Delhi Police for
intervention and scrutiny through SMS.
VICTIM’S PHOTO ATTCHED FOR VERIFICATION AND
SCRUTINY.

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6. That Police complaint against persistent Gang Rape of
victims have been made to Delhi Police as well as to Bihar
Police and Delhi administration as well as to Bihar
administration on 07.05.2022, 09.05.2022, 10.05.2022,
11.05.2022, 12.05.2022, 13.05.2022, 14.05.2022, 14.05.2022,
15.05.2022, 16.05.2022 (Child Line Katihar Rilway, Bihar,
NCPCR, New Delhi and ChildLine Kolkotta) 17.05.2022,
18.05.2022, 19.05.2022, 20.05.2022, 22.05.2022, 23.05.2022,
24.05.2022, 25.05.2022, 26.05.2022, 27.05.2022, 28.05.2022,
31.05.2022, 01.06.2022, 02.06.2022, 03.06.2022, 05.06.2022,
07.06.2022, 08.06.2022, 09.06.2022, 10.06.2022, 11.06.2022,
12.06.2022, 13.06.2022, 15.06.2022, 16.06.2022, 18.06.2022,
19.06.2022, 20.06.2022, 21.06.2022, 22.06.2022, 23.06.2022,
24.06.2022, 25.06.2022, 26.06.2022, 27.06.2022, 28.06.2022,
29.06.2022, 30.06.2022, 01.07.2022, 02.07.2022, 03.07.2022,
04.07.2022, 05.07.2022, 06.07.2022, 07.07.2022, 08.07.2022,
09.07.2022, 10.07.2022, 11.07.2022, 12.07.2022, 13.07.2022,
14.07.2022, 15.07.2022, 16.07.2022, 19.07.2022, 20.07.2022,
21.07.2022, 22.07.2022, 23.07.2022, 24.07.2022, 25.07.2022
(Bandhan Kolkotta), 26.07.2022, 27.07.2022, 28.07.2022,
29.07.2022, 30.07.2022, 31.07.2022, 01.08.2022, 02.08.2022,
03.08.2022, 04.08.2022, 05.08.2022, 06.08.2022, 07.08.2022,
08.08.2022, 09.08.2022, 10.08.2022, 11.08.2022, 12.08.2022,
13.08.2022, 14.08.2022, 15.08.2022, 16.08.2022, 17.08.2022,
18.08.2022, 19.08.2022, 20.08.2022, 21.08.2022, 22.08.2022,
23.08.2022, 24.08.2022, 25.08.2022, 26.08.2022, 01.09.2022
(NHRC), 05.09.2022(Everyone). Yet no F.I.R & no rescue till
date.
7. That Diary No. 155282/CR/2016 dated 14.09.2016, Case No.
3537/4/4/2016 has been rejected on 18.10.16, Case No.

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5480/30/0/2022 and Case No. 4751/90/0/2022 has been rejected
on 30.08.2022 and 31.08.2022 respectively by the National
Human Rights Commission, New Delhi on the same
International Sex Matter.
8. That however, Diary No. 134093/CR/2022 dated 1.9.2022
and Diary No.134631/CR/2022 dated 2.9.2022 has been
registered by the National Human Rights Commission,
(NHRC), New Delhi on the same sex matter, which is still
pending before the commission.
9. That Central Vigilance Commission, New Delhi has received
complaint case no. 205126/2022/vigilance-B on 29.06.2022
against its corrupt All India Services Employees.
10. That Police complaint dated 07.04.2011 is still pending
before Kadwa Police Station Katihar Bihar for registration of an
F.I.R.
11. That Police complaint dated 30.05.2016 vide D.D.No. 37B
and Post Mortem Report No. 1904/2017 vide D.D.NO. 12B
dated 11.11.2017 of deceased mother Asha Rani Devi age 70
years, W/O Deep Narayan Poddar is still pending before Palam
Village Police Station, New Delhi for registration of an F.I.R.
Postmortem has been conducted by ASI Shyam Sunder, Palam
Village Police Station, New Delhi and Deen Dayal Upadhyay
Hospital, Government of N.C.T of Delhi, Hari Nagar, New
Delhi.
12. That Non-F.I.R No. 173/2019 dated 05.08.2019 under
section 107 of CrPc. has been registered by SHO Kadwa Police
Station, Katihar Bihar against the violent mob attack on
petitioner dated 30.07.2019 by the sex abusers and the same has

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been forwarded to the court of Sub-divisional Magistrate,
Barsoi, Katihar Bihar for further action which is still pending
without any action.
13. That Police Action Taken Report dated 29.11.2019 by
Superintendent of Police Traffic Katihar Bihar reveals that
Police has taken negative action against the violent mob
attackers on petitioner dated 30.07.2019 at Sonaili Katihar
Bihar. The main accused in this case is neighbor (1) Shri
Bechan Poddar S/O Sahdev Poddar, (2) Shusheel Poddar S/O
Bechan Poddar, (3) Guddu Poddar S/O Bechan Poddar R/O
Shukkar Hatt, Sonaili, Kadwa Police Station, Katihar Bihar.
14. That Police complaint against Gang Rape of victims dated
09.06.2022 vide D.D.No. 23A at Lahori Gate Police Station,
Delhi-6 has been filed by the petitioner.
15.That Police complaint against Gang Rape of victims dated
15.06.2022 to DCP/Inspector Vigilance Vasant Vihar Police
Station New Delhi has been filed by the petitioner.
16.That Police complaint against Gang Rape of victims dated
18.06.2022 vide D.D.No. 40 at Tilak Marg, Police Station, New
Delhi has been filed by the petitioner.
17. That in the midst of the above noted activities; barbaric act
of State is continued against the Gang Rape Victims. State has s
kept them hostage for persistent Gang Rapes and illicit sex
trade since 2005 to till date.
18. That Indian Army is showing barbaric act by stopping army
train and gang raping victims. The army has stopped its train
twice at Gang Rape Zone Sonaili Village in Katihar district of

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Bihar, a source point of human trafficking. Indian Army train
has stopped at 12:28pm dated 28.08.2022 and at 19:00pm dated
04-09-2022 for 4-5 hours for cooking and Gag Raping of the
victims at Sonaili Railway Station under Katihar Divisional
Railway Manager. It is pertinent to mention here that Indian
Defense Organization is one of the parties in pending persistent
Gang Rape matter Writ Petition (Criminal) Diary No.
18546/2022 before Supreme Court of India.
19. That Ms. Hemlata, mobile-8800326349, counsellor, Delhi
Commission for Women and Delhi Police has been informed
against the barbaric act of Indian Army through mobile SMS at
20:11:15pm dated 04.09.2022, “My ID
Facebook.com/omprakash.poddar/7587/. You will get authentic
court details. Indian Army train at Gang Rape victim Zone
Sonaili Railway Station under katihar divisional railway
manager at 19:00pm dated 4.9.22 for cooking and gang rapes.
Second time this delinquent activity has been identified within
month. Indian defense organization is party before supreme
court of India in W.P.CRL.D.NO.18546/2022”. DCW & DP has
been informed with a hope to provide care and support to the
victims at the source point of human trafficking Katihar Bihar
in coordination with Bihar Commission for Women and Bihar
Police.
20. That another example of lawlessness and barbaric act of state
against state sponsored gang rape victims has been identified on
11.09.2022 at Sonaili, Katihar, Bihar. Without route, Hamsafar
express Katihar-Champaran–Delhi bound train brought and
stopped at Sonaili Railway station under DRM Katihar Bihar at
19:00pm for couple of hours to gang rape and traffick the

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victims. This is happening while DRM Katihar and Chairman
Railway Board is party before Supreme Court of India in an
Anti-Prostitution matter Writ Petition Criminal Diary
No.18546/2022.
21. The barbaric act of Indian Railway has been reported to
Delhi as well as Bihar Police including Ms. Hemlata, counsellor
of Delhi Commission for women dated 12.09.2022 through
SMS.
22. That Indian army is repeating its barbaric act by stopping its
train at Sonaili Railway Station under DRM Katihar dated
12.09.2022 at 9:00am for couple of hours for gang raping the
victims. Gang Rape Victim has identified inside the coach no.
M-10086/SR15135 AC-3 Tier of Indian Army Military train
dated 12.09.2022.
23. The barbaric act of Indian army dated 12.09.2022 has been
reported to Delhi as well as Bihar Police including Ms.
Hemlata, counsellor of Delhi Commission for women on the
same day and date through SMS.
24. That the focal point of fight is between Professional Social
Worker Versus Professional Legal Workers. Both are defending
the same clients by their own professional acumen, training,
skills, body of knowledge, vision, practice, procedure,
methodology, ethics, morale, principles, objectives, goals and
style of functioning. Herein, Petitioner is a Professional Social
Worker while Advocates and Judges are Professional Legal
Workers. Details of petitioner’s professionalism have been
placed on court records in the main petition of this case.

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25. That Professional Legal Workers are obstructing the rescue
operation of Gang Rape Victims from the clutches of human
Traffickers State while Professional Social Worker is dying
hard to rescue the Gang Rape Victims from the clutches of
human Traffickers State.
26. First Anti-Prostitution matter, Petition(s) for Special Leave
to Appeal (Civil) No(s).9854/2012 has been dismissed by
Supreme Court of India on 23.04.2012.
27. Second Anti-Prostitution matter, Petition(s) for Special
Leave to Appeal (Civil) No(s). 9483/2013 has been dismissed
by Supreme Court of India on 01.04.2013.
28. Third Anti-Prostitution matter, Petition(s) for Special Leave
to Appeal (Civil) No(s). 19073/2013 has been dismissed by
Supreme Court of India on 05.07.2013.
29. Fourth Anti-Prostitution matter, Writ Petition (Civil)
90/2016 has been dismissed by Supreme Court of India on
18.04.2016.
30. Fifth Anti-Prostitution matter, Writ Petition (Criminal)
136/2016 has been dismissed by Supreme Court of India on
21.10.2016.
31. Sixth Anti-Prostitution matter, Writ Petition (Criminal)
242/2021 has been dismissed by Supreme Court of India on
25.10.2021.
32. Seventh Anti-Prostitution matter, Writ Petition (Criminal)
137/2021 has been dismissed by Supreme Court of India on
02.05.2022.

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33. Eighth Anti-Prostitution matter, Writ Petition (Criminal)
Diary No. 18546/2022 is still pending before Supreme Court of
India. It is the outcome of dismissal of 17 Anti-Prostitution
dismissed matter by Supreme Court of India.
34. That brain mapping of victims, rolling back of Sex
technologies, clubbing of F.I.Rs and requisitioning of lower
court records across the country is required in rescuing the state
sponsored gang rape/illicit sex trade victims from the clutches
of human Traffickers State.
35. That on the contrary, State is suppressing and obstructing the
rescue operation of Gang Rape Victims since 5th
April, 2021.
State coercion has reached its peak crossing all limits.
36. That under the above circumstances, Petitioner has been left
to rescue them from Supreme Court of India through Writ
Petition (Criminal) Diary No.18546/2022.
37. That in the above premises; register an F.I.R against the
accused Public authorities for commissioning cognizable
offence against the victims which is punishable under relevant
sections of IPC.
PETITIONER-IN-PERSON
Professional Social Worker (MSW)
Writ Petition (Criminal) D. No. 18546/2022
SUPREME COURT OF INDIA
OM PRAKASH
S/O LATE SHRI DEEP NARAYAN PODDAR
S/O LATE SRIMATI ASHA RANI DEVI
PERMANENT RESIDENT: ASHA DEEP NIWAS,
SONAILI, SHUKKAR HATT,
IN FRONT OF DURGA MANDIR,
KANTIYA PANCHAYAT,
P.S. KADWA, KATIHAR, BIHAR-855114, MOB: 9540389759
E-mail: om.poddar@gmail.com
KATIHAR BIHAR:
FILED ON : 12-09-2022