BEFORE THE HON’BLE SUB DIVISIONAL MAGISTRATE,
IN THE MATTER OF:-
W/o A (First husband),& Late B
D/o Late K
Both Permanent resident of –
Tehsil and P.S. Dindori,
Distt. Nashik, Maharashtra.
House No. XX, Prem Nagar,
New Delhi-110003 ….PETITIONERS
- The State
- Arjun Laxman
- Ramchandra Laxman Bagul
All are resident of :
House No.XX, Subhas Plaza ,
Panchvati, Nashik, Maharashtra. ….RESPONDENTS
MOST RESPECTFULLY SHOWETH:-
- The petitioners are women at their age of 65 and 25 years respectively who are mother and daughter in relation and are a law abiding citizen and resident of above mentioned address. The ID proof of the petitioners are annexed herewith.
- That the respondent no.2 is the son of the petitioner no.1 and step brother of petitioner no.2, whose father was the first husband of the petitioner no.1 and the respondent no. 3 &4 are own brothers of petitioner no.1 and maternal uncles (Mama) of petitioner no.2. The respondent no.5 is the wife of respondent no.2 and daughter in law of petitioner no.1.
- That the petitioner no.2 is the daughter of the petitioner no.1, whose father was the second husband of the petitioner no.1 who passed away.
- That the repondent no.1 is the State
- That the life of the petitioner no.1 and 2 are constantly under threat and fear due to the connivance of respondent no. 2 to 5 with the police representing as the State, respondent no1. The respondents are greedy in nature and respondent no.2 to 4 are of criminal background who are trying to grab the property of Sh. Dundiram, the first husband of the petitioner no.1 in which the petitioners are having shares. The said property is situated at Village X , Tehsil- Trimbakeshwar, Distt. Nasik, Maharashtra and the petitioner no.1 and 2 are the co-sharer of that ancestral property which is agricultural land.
- That the respondent no. 2 as a son is the share- holder of that property, however, the respondent no.3 & 4 are provoking and assisting him to eliminate the life of Petitioners in connivance with the police so that they all can capture the petitioners’shrares of the property. It is pertinent to mention here that the father, Dundiram is very gentle person who considers very fairly and positively the shares of all who are natural heirs, including his daughter and wife.
- That the respondents are having illegal and criminal intention by aggressively creating property disputes for last 8 years and the cases of physical and mental tortures of petitioners by respondents reached to the police station Panchavti, Nashik , Maharashtra, however police did not register any case against respondents and on the contrary petitioners were oppressed by the police and respondents by getting the matter compromised under pressure, fear and threat and even many blank papers were got signed by the petitioners.
- That the respondent no.2 repeatedly states that he is the male person, he is the sole heir of his father property and if mother and sister comes to claim on the said property , they will be killed and no one could even trace out their dead bodies. His wife, the respondent no.5 is always abusing the petitioners. Surprisingly enough, the Mamas, respondent no.3 &4 are indulged in this matter without even being a party to the said property or a part to the said family, they are just trying to get benefit of the situation because they are goonda elements of society and have no consideration even for his family relations.
- That the respondent no.2 called the petitioners to come at his home at Nasik to settle the said property matters and when on 19.04.2022 the petitioners reached their, they were criminally attacked and heavily hurt by the respondents, anyhow they escaped their lives receiving injuries on their body. The police of the concerned police station did not take notice of this situation despite repeated requests by the petitioners because of the influence of respondent no.2 to 4 in the circle of police and local anti social elements. Eventually, the petitioner returned to Delhi and remained fearful due to the threat calls coming on mobile phones from respondents openly declaring that police and legal system could do nothing against them and they are inclined to eliminate the existence of the petitioners.
- That on 21.04.2022 the respondents came to Delhi and threatened the petitioners to kill them and were ready to attack on them and their property. In a state of fear and danger, the petitioners on 24.04.2022 had given a written complaint regarding the threat to kill and repeated attacks on them to the SHO, Kotala Mubarkpur Police Station, New Delhi, however, no case was registered against the culprits. The copy of the complaint bearing D. No. 21A, Mark to R/ SHO dated 24.04.2022 is enclosed herewith.
- That these incidents have caused a great mental and physical torture to the petitioners who are constantly in the state of insecurity and fear and the normal life of the petitioners are adversely affected. Police are reluctant in taking any action against the culprits who are freely moving abusing and threatening the petitioners.
- That the petitioners are women without the support of any male members who have been placed under the helpless and pitiable condition by the respondents.
In consideration of all the facts and circumstances mentioned hereinabove it is graciously prayed that you may kindly look into the matter and take appropriate legal actions against the respondents so that the life and property of the petitioners could be saved and the faith of the petitioners in the law enforcing agencies remain intact.
It is further prayed to save the petitioners from the unjust and illegal acts of the respondents and their wrong and criminal intention of capturing the shares of the petitioners in the ancestral family property i.e. agricultural land situated at above mentioned address.
It is prayed accordingly.
(Avinash Nandan Sharma)
Chamber No. 671, Patiala House Court, New Delhi,
Copy to :
- DCP, South Delhi.
- The SHO, Police Station, Kotala Mubarakpur, New Delhi.