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Section 175 (3) of BNS

Advocate R.S

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950 views5 pages

Section 175 (3) of BNS

Advocate R.S

Uploaded by

ayushmtfe16
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© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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DIST: NORTH 24 PARGANAS.

IN THE COURT OF LD. CHIEF JUDICIAL MAGISTRATE AT BARASAT.

REF. C CASE NO……………./2024

Petition U/S Section 175(3) of the Bharatiya


Nagarik Suraksha Sanhita (BNSS), 2023.

In the matter of:

Shree Poritoshananda Giri Maharaj


S/O – Late Joytiswarananda Giri Maharaj
Residing at Sreekrishnapur
P.O – Kajipara, P.S – Barasat, Dist: North 24
Parganas, PIN - .
……………..Complainant
Versus
1. Dipali Dam @ Sita Dam
W/O – Pradip Dam
of
P.O- P.S –
Dist:
PIN- West Bengal

2. Pradip Dam
S/O –
of
P.O- P.S –
Dist:
PIN- West Bengal

3. Gopal Goswami
S/O -
of
P.O- P.S –
Dist:
PIN- West Bengal
…………... Accused

Ref: U/S – 318/ 316(2)/ 61(2)/ 336/ 331(4)/ 338/


336(2)/ 336(3)/339/131 and 3(5) of Bharatiya
Nyaya Sanhita 2023.

The humble petition on behalf of the complainant above named.


MOST RESPECTFULLY SHEWETH:

1. That the complainant as stated above herein in this petition are law
abiding and very peace loving Citizen of India and also a trustee of Sankar
Moth & Mission, had been residing at the above mention address
permanently.

2. That on the other hand the entire accused are very cunning in nature and
dangerous in character as stated above herein in this instant petition
connected with so much illegal activities.

3. That the accused persons as stated above herein in this instant petition
are extremely cheating in nature and dangerous in character and thereby
have no respect for the law of the land.

4. That to benefit financially either monetarily or with respect to any such


property of the complainant, the accused had been disturbed the peaceful
life of the complainant as well as all devotees who attached with
complainant herein of this instant petition and henceforth had being
trying beyond all meats and bounds to smashed the property and
reputation of the complainant hereby disobeying the law of land.

5. That Most venerable late Jyotiswarananda Giri Maharaj and late Yogiraj
Hariharananda Maharaj, Guru father of both Swargiya Swarupananda Giri
Maharaj together with stablished many service institutions for public
interest at own state and abroad also under the direction of the Guru
Maharaj and managed various Sevasrams. The main objective of those
Sevashrams is to provide shelter and services to the helpless people who
are oppressed in the society.

6. That after death of Yogiraj Hariharananda Maharaj in 2015, the


complainant was selected by the devotees of Shankar Math and Mission
Trust to manage these Sevashrams properly and he is in charge of the
management till date.

7. That in the present scenario witnessing the apparent incident of serious


conspiracy in the mentioned Sevaashrams, the uncle of complainant late
Guru Yogiraj Hariharananda Maharaj used to provide shelter to various
homeless people in his ashram before his Brahmalin. That among so
many homeless the accused Deepali Dam/Sita Dam/Sita Goswami was
one of them who sheltered in above said Ashram as an Ashrita.

8. Thereafter accused Deepali Dam lived in Harihar Sevashram as a


sheltered woman in Jalpaigudi, P.S -Ambari in Mehendiganj village but
suddenly one day she escape from the Ashram for being in love with
someone.
9. That after passing one year the accused Deepali Dam again came to
Jalpaiguri's “Nirasray Sevasram” and begged Hariharananda Maharaj for
further shelter and Guru Maharaj again accept her for her to see her poor
and distress condition.

10. That took advantage of inchoateness and


physical illness of Hariharananda Giri Maharaj she create emotional
stress in various ways and also create forge Voter ID, Aadhaar Card in
connection with as D/o Hariharananda Giri Maharaj for making the Sanyasi
Maharaj as her father, with a intention for the sale of 17 bigha furnished
tea garden of Nirasraya Sevashram by making almost a kind of fraud.

11. That the accused Deepali Dam become very


greedy and tried to transfer all the properties of the ashram by the power
of fake voter ID card in as showing her relationship with Guruji's
daughter.

12. That During Guruji's lifetime, when Complainant have in charge of that
Sevashram accused Deepali Dam and her present husband Pradip Dam
and Deepali’s previous son Gopal Goswami not create any disturbance
but after the abdication of Guru Maharaj, Deepali Dam @ Sita Dam, her
present husband Pradeep Dam and her son Gopal Goswami along with
some people from several different communities threatened Complainant
with life and bound to leave the ashram forcefully. After facing daily
physical and mental torture Complainant leave the said ashram and
presently Complainant staying at Barasat Shankar Math and Mission.

13. In absence of the complainant corruption


increase day by day and exposes all financial dealings of the said
Nirasraya sevashram by the accused and her hooligans. It does not end
here, they broke the window of Guruji's two-storied room of Manuaganj
Hari Har Ashram and possessed all the documents and financial deed.

14. That in absence of complainant the accused


lady and her hooligans falsified all financial transactions of the said
ashram, without stopping here, they stolen all financial deed and record
from Nirasraya Ashram and she is trying to take over all properties of
ashrams by showing a fake adoption school certificate claiming herself as
Guru Maharaj's adopted daughter.

15. That on 19/08/2024 all accused are reached


Barasat Sankar Moth ashram where the complainant presently lived.
Accused no.1 and her men whipped the complainant to leave the ashrams
immediately and escape from here but when Complainant did not agree
with this then some unknown persons grip his hand and lock in back and
the accused no. 2 put a gun in the mouth of the complainant for the
purpose to save life complainant agree with their condition and then the
accused persons leave from there with kicked in his chest and drove
away.
16. That the cause of action arose on 19/08/2024.
That the complainant visited Barasat P.S but not a single action done by
police. Thereafter complainant send the complaint copy by post to the
Barasat P.S on , there after lodged complaint before S,P
office, Barasat and on dated but after passing 10 days still
there is no solution arises.

17. That if there have not arisen any solution


against the occurred incident, then your petitioner will suffer so much
loses and injury in future that will never is repair by any cost.

18. That finding no other alternatives your


complainant filed this instant petition and henceforth there are no
intentional latches or delay in filing this petition before the Ld. Court.

Under all the above mention facts and


circumstances it is therefore most
humbly prayed that your Honor would
graciously be pleased to allow the
petition U/S 175(3) of the Bharatiya
Nagarik Suraksha Sanhita (BNSS), 2023
and directed to Barasat P.S to take this
complain as an F.I.R and pass an order or
orders to issue summons upon the
accused person for the interest of Justice
and pass any such order as your Honour
may deem fit and proper.
AND for this act of kindness your petitioner as in duty bound shall ever pray.

VERIFICATION

I, Shree Poritoshananda Giri Maharaj, S/O – Late Joytiswarananda Giri


Maharaj, Residing at Sreekrishnapur, P.O – Kajipara, P.S – Barasat, Dist:
North 24 Parganas, PIN - - .All the averments made true to the
best of my knowledge and belief.
AFFIDAVIT

I, I, Shree Poritoshananda Giri Maharaj, S/O – Late Joytiswarananda Giri


Maharaj, Residing at Sreekrishnapur, P.O – Kajipara, P.S – Barasat, Dist:
North 24 Parganas, PIN - - - ..Do hereby solemnly
affirm and declare as follows:

That I am the complainant of this Complaint.


……….this is true to the best of my knowledge.

That I am well conversant with the facts and circumstances with this instant
petition.
……….this is true to the best of my knowledge.

That the statement made in paragraph no. 01 to 18 of this petition are true
to the best of my knowledge and belief and rest my humble submission
before the Ld. Court.
……….this is true to the best of my knowledge.

That the above statement are true to


best of my knowledge and belief and I
put my signature at Court premises.

Signature of deponent
Signature identified by me

ADVOCATE

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