That at the very outset a complete, in-depth, meticulously
exhaustive and comprehensively detailed account covering
each and every aspect of the impugned order dated
13/02/2017 which is being annexed herewith as Annexure
P 1 to this instant Special Leave Petition.
Further at this onset Petitioner states that, upon
becoming a victim of humiliation, mental torture, loss of dignity, character assassination, misbehavior, loss of repute, and abject discrimination and despite exercising all self- restraint and endeavoring to secure an amicable resolution to the gross injustice meted out to him by the delinquent EXECUTIVE machinery the petitioner holds on to the only ray of hope he has by way of an extraordinary remedy as is expected from an impartial JUDICIARY. While as few as 8 Writ Petitions (owing to different cause of actions) continue to play hide and seek with the determined and resolute petitioner, the instant Special Leave Petition is merely a cog in the wheel in the overall context, and by itself does not per se represent the Petitioners overall suffering.
Whereas on the one hand, the petitioner hails from a
humble farmers family that struggles to make ends meet, and not being able to afford the cost of litigation, has petitioned all his Writs as well as this instant petition in person despite not being qualified and properly experienced in the field of law, on the other hand the delinquent bureaucracy represented herein by the opposite parties and their learned Counsel, have mastered the art of subterfuge and bluff, sparing no opportunity to obfuscate and deflect the due process of law with all the resources at their command. The petitioner found himself grossly disadvantaged during the courtroom verbal proceedings where he found that the Contemnors represented by their Counsel literally got away with all kinds of falsehood peddled before the Honble Allahabad High Court; however, having eventually secured conclusive evidence of fraud on part of the Contemnors, the petitioner invoked the provisions of Section 2 (c) of the Contempt of Courts Act 1971 by filing Criminal Contempt Petition No. 1302(C) of 2016.
Whereas during the various proceedings that took
place before the Honble Allahabad High Court (Lucknow Bench), the astute manipulations and falsehood of the Contemnors had succeeded in portraying the petitioner as a habitual litigant; on occasions more often than not, the Honble Bench began to observe the petitioner with circumspection and at the same time also developed sympathy for the embattled bureaucracy. Nonetheless, in view of the unretractable and incriminating evidence by way of a document fraudulently produced by the Contemnors on a sworn affidavit, the aforesaid Honble High Court vide its Order Dated 08/08/2016 [1302(C) of 2016] decreed the document as forged, but when it came to meting out a punishment, the Honble High Court perhaps developed cold feet as one of the Contemnors happened to be a high ranking Government Official of the rank and stature of the Secretary, Civil Aviation himself. In other words the decree was passed but the sentence was not pronounced; the concerned Bench had perhaps developed cold feet and passed the buck. The jurisdiction of the Judges subsequently was re-rostered and the case after much pursuance by the petitioner came up for hearing on 24/10/2016, before the co-ordinate bench. Ironically, the aforementioned Criminal Contempt No. 1302 (C) of 2016 was tied up with Writ Petition WP 4919 MB of 2016, also represented in person by the petitioner himself, and therefore enabled the Contemnors Counsel to legitimately (albeit frivolously) put forth his arguments that related almost exclusively to the aforementioned writ, instead of focusing on the merits of the instant Criminal Contempt. In a shocking turn out of the courtroom proceedings, the petitioner was stunned beyond disbelief when the final disposal order was passed; the petitioner who was expecting a punishment/sentence to be pronounced (as the document was already decreed as forged) on the guilty, was shocked by the incomprehensible U-turn made by the Honble High Court, which sub-silentio overruled its own earlier Order dated 08/08/2016 by observing that the fraudulent document is not forged.
Contemnors, despite being in the know that this
Honble Court has on 08/08/2016 decreed the fraudulently produced said document to be forged, showed no remorse whatsoever, and in an utter and blatant disregard to this Honble Court, daringly produced the same very forged document before same very Honble High Court in 556 (C) of 2016 on the very next day i.e. on 09/08/2016. Not only the above, apart from fraudulently producing the forged document the deponent craves leave of this Honble Court and solicits its kind and gracious attention to para 4 of the Counter Affidavit [556 (C) of 2016] filed by Contemnor No. 3 whereby he has mischievously and falsely averred under oath that ..petitioner has not been able to pass examination till date.. Because of the said forged document and false averment contemnors succeeded to get favorable order as Honble high Court dismissed contempt Petition 556 (c) of 2017 by recording false averment & relying upon forged document of Contemnors. Contempt Petition 556 (c) of 2016 was dismissed even without rejoinder affidavit. The petitioner above named respectfully submits
this petition seeking special leave to appeal against the
impugned judgment/order of the Honble Allahabad High
Court dated 24/10/2016 passed in Criminal Contempt 1302
(C) of 2016; Anupam Verma Versus Rajeev Nayan Choubey
and 2 others. The instant matter pertains to the unlawful
actions by the contemnors amounting to criminal contempt
that gave rise to the petition i.e.- 1302 (C) of 2016 as well as
the un-retractable act of deceit and gross misrepresentations
by the Contemnors Counsel during the courtroom
proceedings which eventually culminated in the disposal of
the said case by way of the impugned Oder dated
24/10/2016 passed by the Honble Allahabad High Court;
while the Honble High court on the one hand have virtually
relied on the verbal submissions of the Contemnors, on the
other hand the said Honble Court has not considered the
facts and averments made on a sworn affidavit by the