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MEMORANDUM OF GROUNDS OF CRIMINAL ORIGINAL PETITION (Under Section 482 of Cr.P.C.) IN THE HIGH COURT OF JUDICATURE AT MADRAS In Crl.O.P. /15. P.Chandira, M.E,(M.B.A)(BGL)., Assistant Engineer,Highways, Nabard and Rural Roads, Panruti, Cuddalore District. ----- Petitioner. -Vs- 1) The Director, Vigilance &Anti-Corruption Department, Aryapuram, Chennai &Fifteen others ------Respondents. TYPED SET S.No Date Description of Documents P.No 1 04.03. 02 The Hon’ble High Court Division bench order in W.P.No:26463/01 Dated:23.04.2003 1-2 2 14.03. 02 The Hon’ble High Court Division bench order in W.P.No:26463/01 Dated:23.04.2003. 3-4 3 23.04. 03 The Hon’ble High Court Division bench order in W.P.No:26463/01 Dated:23.04.2003 5-6 4 24.06. 03 The Hon’ble High Court Division bench order in W.P.No:26463/01 Dated:23.04.2003 7-8 5 28.06. 08 The eighth respondent letter to District Collector,Cuddalore in RC255/2003/HD/CL 9 6 02.07. Telegram by Traffic Ramasamy 10-11 1

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Page 1: reply to counter in Crl.O.P.No6002

MEMORANDUM OF GROUNDS OF CRIMINAL ORIGINAL PETITION

(Under Section 482 of Cr.P.C.)

IN THE HIGH COURT OF JUDICATURE AT MADRAS

In

Crl.O.P. /15.

P.Chandira, M.E,(M.B.A)(BGL).,Assistant Engineer,Highways, Nabard and Rural Roads,Panruti, Cuddalore District. ----- Petitioner.

-Vs-

1) The Director, Vigilance &Anti-Corruption Department, Aryapuram, Chennai &Fifteen others ------Respondents.

TYPED SET

S.No Date Description of Documents P.No

1 04.03.02 The Hon’ble High Court Division bench order in W.P.No:26463/01 Dated:23.04.2003

1-2

2 14.03.02 The Hon’ble High Court Division bench order in W.P.No:26463/01 Dated:23.04.2003.

3-4

3 23.04.03 The Hon’ble High Court Division bench order in W.P.No:26463/01 Dated:23.04.2003

5-6

4 24.06.03 The Hon’ble High Court Division bench order in W.P.No:26463/01 Dated:23.04.2003

7-8

5 28.06.08 The eighth respondent letter to District Collector,Cuddalore in RC255/2003/HD/CL

9

6 02.07.09 Telegram by Traffic Ramasamy to 1) Hon’ble Deputy Chief Minister Thiru.Stalin,2) The Secretary,Highways &Minor Ports Department,Secretariat,Chennai-9 3)The C.E redesignated as Director, Highways, Chepauk,Chennai-5 4)I.G.P, V&AC,Chennai

10-11

7 03.11.09 GO(D)No:203 Dated:03.11.09 passed by the fourth respondent.

12

8 17.02.14 Director,V&AC,Aryapuram Chennai Lr to second respondent based upon my compliant dated:15.01.14.

13

9 03.09.14 The compliant submitted to the first respondent to investigate the corruption in Awarding Kalpana Chawla Awards

14

10 24.02.15 Public Information officer of DGP,Chennai, the second respondent in RCNo:023503/869/RTI-1(2)/2015-2

15

Dated at Chennai on 07.04.2015 Petitioner-Party-in-Person

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Page 2: reply to counter in Crl.O.P.No6002

MEMORANDUM OF GROUNDS OF CRIMINAL ORIGINAL PETITION

(Under Section 482 of Cr.P.C.)

IN THE HIGH COURT OF JUDICATURE AT MADRAS

(CRIMINAL ORIGINAL JURISDICTION)

In

Crl.O.P. /15.

( The objections submitted by the petitioner to the counter filed first

respondent,the Director,Vigilance and Anti-Corruption Department,

Aryapuram,Chennai in Crl.O.P.No:6002/15 and by the eight

respondent,the Inspector of Police, Vigilance and Anti-Corruption

Department, Cuddalore and humbly prayed to direct the fourth

respondent,State Represented by the Secretary,Highways and Minor

Ports Department, Secretariat, Chennai-9 to recover the loss to

Government money from the Partners of Sridevi Enterprises,

Contractor,Chennai and from Thiru.Haribabu,the Junior

Engineer,Highways,Nabard Section, KattumannarKovil and the first

respondent has to verify the departmental action taken by the

Director(General)of Police,Chennai based upon the

Director,V&AC,Chennai Lr No:936/2014/POL/ ER Dt:17.02.2014

based upon the compliant of the petitioner dated:15.01.2014 and to

verify departmental proceedings of the Highways Department as

directed on 11.02.2015 based upon the compliant of the petitioner

dated:01.02.2015 and the Vigilance Department has to investigate

the case in F.I.R.No:969/12 Dated:09.06.12 u/s 420,409,465,468,469

IPC r/w 13(1)©Prevention of Corruption Act 1988 Dated:07.06.2012

and the Director,V&AC has to investigate the case the Corruption in

Awarding Kalpana Chawla Awards in Tamilnadu based upon the

representation of the petitioner dated:03.09.2014 and the

CSRNo:261/14 filed by the Inspector of Police,Kadampuliyur and

the necessary action taken by S.P.Cuddalore and Erode based upon

my representations dated:20.05.2014 and by the representation

2

Page 3: reply to counter in Crl.O.P.No6002

submitted to Deputy Superintendent,V&AC,Cuddalore for

Departmental Execution of Special Repairs to Keelirruppu

Kattuppalayam Road submitted to the Secretary,Highways and

Minor Ports Department,Chennai dated:16.07.2014 to call for the

records on the file of the respondents).

P.Chandira, M.E,(M.B.A)(BGL).,

Assistant Engineer,Highways,Nabard and Rural Roads,

Panruti, Cuddalore District. ----- Petitioner.

-Vs-

1) The Director, Vigilance &Anti-Corruption Department, Aryapuram,Chennai.

2) The Director General of Police,Chennai.

3) The State Represented by the Chief Secretary

to Chief Minister, Secretariat,Chennai-9.

4) The State Represented by the Secretary

Highways and Minor Ports Department,

Secretariat,Chennai-9.

5) The Director (General),Highways,

Chepauk,Chennai-5.

6) The State represented by the Secretary (General)

Secretariat, Chennai-9.

7) The District Collector,Cuddalore.

8) The Inspector of Police,V&AC,Cuddalore.

9) The Inspector of Police, District Crime, Nagercoil.

10) Thiru.Vijaya Kumar,the Sub-Inspector of Police,

Bhavani.

11) The Superintendent of Police, Erode District.

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Page 4: reply to counter in Crl.O.P.No6002

12) The Inspector of Police,

Danvantri Nager,Pondicherry.

13)The Chief Vigilance officer,

Neyveli Lignite Corporation,Neyveli.

14) The Chairman-Cum-Managing Director,

Neyveli Lignite Corporation,

Neyveli --------Respondents

PETITION UNDER 482 CRPC.

The objections submitted by the petitioner to the counter

filed first respondent,the Director,Vigilance and Anti-Corruption

Department, Aryapuram,Chennai in Crl.O.P.No:6002/15 and by the

eight respondent,the Inspector of Police, Vigilance and Anti-

Corruption Department, Cuddalore and humbly prayed to direct the

fourth respondent,State Represented by the Secretary,Highways and

Minor Ports Department, Secretariat, Chennai-9 to recover the loss to

Government money from the Partners of Sridevi Enterprises,

Contractor,Chennai and from Thiru.Haribabu,the Junior Engineer,

Highways,Nabard Section, KattumannarKovil and the first

respondent has to verify the departmental action taken by the

Director(General)of Police,Chennai based upon the Director, V&AC,

Chennai Lr No:936/2014/POL/ ER Dt:17.02.2014 based upon the

compliant of the petitioner dated:15.01.2014 and to verify

departmental proceedings of the Highways Department as directed

on 11.02.2015 based upon the compliant of the petitioner

dated:01.02.2015 and the Vigilance Department has to investigate

the case in F.I.R.No:969/12 Dated:09.06.12 u/s 420,409,465,468,469

IPC r/w 13(1)©Prevention of Corruption Act 1988 Dated:07.06.2012

4

Page 5: reply to counter in Crl.O.P.No6002

and the Director,V&AC has to investigate the case the Corruption in

Awarding Kalpana Chawla Awards in Tamilnadu based upon the

representation of the petitioner dated:03.09.2014 and the

CSRNo:261/14 filed by the Inspector of Police,Kadampuliyur and

the necessary action taken by S.P.Cuddalore and Erode based upon

my representations dated:20.05.2014 and by the representation

submitted to Deputy Superintendent,V&AC,Cuddalore for

Departmental Execution of Special Repairs to Keelirruppu

Kattuppalayam Road submitted to the Secretary, Highways and

Minor Ports Department, Chennai dated:16.07.2014 and the

compliant submitted by the petitioner to the Inspector of Police,

Pondicherry on 15.01.2014,CSRNo:55/14 filed by the Inspector of

Police, First Thermal, Neyveli Township to call for the records on

the file of the respondents and thereby render justice.

I perused the counter filed by the eighth respondent on behalf

of first and eight respondent. The eighth respondent may please to

provide the copy of the order of the first respondent to file counter on

behalf of the first respondent. The first respondent is in a top most

position to avoid corruption all over Tamilnadu. The petitioner

submitted complaints in three district namely Cuddalore,

Kanniyakumari, Erode District. In this situation the first respondent

may please to submit separate counter considering the above cases

forthwith and should be role model to eradicate corruption and to

recover loss to the Government money from the contractors.

The petitioner submits the reply with additional documents

before this Hon’ble High Court to the counter filed by the eighth

respondent on 30.03.2015 liable to be missed in the limine. The first

respondent wants to escape from his official duty and failed to permit

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Page 6: reply to counter in Crl.O.P.No6002

the other officials in the Vigilance Department to do their duty in

accordance with law.

I denied the statement of the eighth respondent in Para No:1

is false that the eighth respondent aware of the facts and

circumstances of the case from the records against sixteen

respondents case. The eighth respondent can know the status of the

case in F.I.R.No:10/03 filed by the former Inspector of Police,

V&AC,Cuddalore. The eighth respondent may please to produce the

related documents in F.I.R.No:10/03 on the file of the Vigilance

Department, Cuddalore and Chennai ,the departmental enquiry

proceedings on the file of the fifth respondent,the Director(General)

Highways, Chepauk,Chennai-5 and the fourth respondent,the state

represented by the Secretary,Highways and Minor Ports Department,

Secretariat, Chennai-9. The petitioner submitted fifty eight pages of

documents before this Hon’ble High Court at the time of filing the

Crl.O.P.No:6002/15. The petitioner further submits the additional

documents 1) the Hon’ble High Court Division bench order in

W.P.No:26463/01 Dated:23.04.2003 2) The Hon’ble High Court

Division bench order in W.P.No:26463/01 Dated:23.04.2003 3) The

Hon’ble High Court Division bench order in W.P.No:26463/01

Dated:23.04.2003 4) The Hon’ble High Court Division bench order

in W.P.No:26463/01 Dated:23.04.2003 5) The eighth respondent

letter to District Collector,Cuddalore in RC255/2003/HD/CL

Dated:28.06.08 6) Telegram by Traffic Ramasamy to 1) Hon’ble

Deputy Chief Minister Thiru.Stalin,2) The Secretary,Highways

&Minor Ports Department,Secretariat,Chennai-9 3)The C.E

redesignated as Director, Highways, Chepauk,Chennai-5 4)I.G.P,

V&AC,Chennai 7) GO(D)No:203 Dated:03.11.09 passed by the

fourth respondent. 8) The compliant submitted to the first respondent

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to investigate the corruption in Awarding Kalpana Chawla Awards

9) The letter submitted received from the second respondent’s office.

I denied the statement of the eighth respondent in Para No:2

is false that the eighth respondent statement of vexatious, devoid of

merits and deserves to be dismissed in the limine. The petitioner

humbly submits that the eighth respondent failed to arrest the

accused in F.I.R.No:10/03 and to produce the accused before the

Chief Judicial Magistrate Court, Cuddalore from 10.11.2003 which

is submitted in typed set page No: one to seven and caused extreme

torture to the petitioner and her family members. The Govt.

Secretary, Highways, the fourth respondent herein passed a

Proceeding No: 11477/HL-1/2004-22 Dated: 13.10.2008 which is

submitted in Typed set P.No: Nineteen to Twenty one. The

department has permitted sanction in No:7058/Con.II/2003

Dated:26.02.2007 for prosecution against the accused

T.M.D.Haribabu,the formerly Junior Engineer(H) and M.Mohammed

John,the formerly Divisional Accountant-Cum-Manager. The

Secretary to the Government passed a G.O.No:192.Highways&

Minor Ports Department Dated: 13.10.08 and permitted the accused

Thiru.Tamilselvan to permit to escape from the departmental

Proceedings and the Criminal Proceedings. The respondent failed to

take action against the Partner of Sridevi Enterprises, Chennai to

recover the loss to the Govt.Money in several Lakhs. The eight

respondent cannot deny the statements in my petition as the petition

is against sixteen respondent. The remaining respondents has to file

counter and the cases has to be investigated by the Vigilance

Department against the remaining cases in Erode, Cuddalore and

Kanniyakumari against Police department officials and

staff ,Highways Department officials, Staff and contractors,the

District Collectors,Secretaries to the Government and others.

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Page 8: reply to counter in Crl.O.P.No6002

I denied the statement of the eighth respondent in Para No:3

is false that the eighth respondent only permitted the accused to

escape from clutches of law linked with fourth and fifth respondent

without recovering the loss to the Government. The eight

respondents failed to peruse the orders of Hon’ble High Court

Division bench in W.P.No:26463/01 Dated: 04.03.02, 14.03.02,

23.04.03 and 24.06.03.

I denied the statement of the eighth respondent in Para No:4

is false that the eighth respondent failed to note that the

GO(d)No:203 dated:03.11.2009 is the departmental action taken by

the fourth respondent against 1) Thiru.R.Shanmugham,the Formerly

Divisional Engineer(H)Cuddalore (Now Superintending

Engineer(U/S) 2) Thiru.A.Theerthagiri,the Formerly Assistant

Divisional Engineer(H) Chidambaram 3) Thiru.M.Mohammed

John,the Formerly Divisional Accountant-Cum-Manager,O/O the

Divisional Engineer (H) Cuddalore 4) Thiru.M.Kamaraj,the

Formerly Assistant Engineer(H) Chidambaram

5)Thiru.D.Haribabu,the Formerly Junior Engineer (H) Nabard

Section,KattumannarKovil. The eighth respondent failed to note that

there is several lakes of loss to the Government and has to be

recovered from the Partners of Sridevi Enterprises, Chennai and from

Thiru.Haribabu, the Formerly Junior Engineer (H) Nabard

Section,KattumannarKovil.

I denied the statement of the eighth respondent in Para No:5

is false that the eighth respondent failed to note GO(d)No:203

dated:03.11.2009 does not contains the accused the partners of

Sridevi Enterprises,Chennai. The Hon’ble High Court Division

bench in W.P.No:26463/01 issued the Vigilance Department to

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Page 9: reply to counter in Crl.O.P.No6002

conduct an enquiry not less than Deputy Superintendent of Police on

04.03.2002. The Deputy Superintendent of Police,V&AC,Cuddalore

filed the preliminary prima facie report against three officials initially

on 14.03.2002. The Hon’ble High Court directed the Vigilance

Department to submit detailed report within four weeks from

14.03.2002 in W.P.No:26463/01. Even though the Vigilance

Department, eighth respondent completed enquiry on 17.06.2002 and

found that there is loss to the Government, they have delayed and

submitted the report before the Hon’ble High Court on 23.04.2003 in

W.P.No:26463/01.Instead of producing the accused before the Chief

Judicial Magistrate, the eighth respondent submitted final draft report

to the Govt.on 19.10.2006 only. When there is loss to the

Government money it is the case to recover the loss from the

Contractor by revenue recovery process and from the Junior

Engineer who return back the 10.50M.T of Emulsion bitumen

fictitiously. The road has been executed without utilising proper

emulsion bitumen and loss occurred to the Government. During the

detailed investigation of the Vigilance Department there is also loss

to the Government due to sub-Standard bitumen which is stated in

W.P.No:26463/01 Dated: 23.04.2003. Being the investigating officer

arrived the value of the loss to the Government and submitted report

to the Highways department. It is the duty of the fourth respondent to

recover the loss to the Government from the contractor and the

Junior Engineer. The investigating officer must have submitted final

report before the Chief Judicial Magistrate Court,Cuddalore with the

value of the loss to government with the statement of the accused has

been arrested or not. While at the time filing his final report before

the eighth respondent found mistake that the accused has not

arrested. In the situation he must have seeked the help from the

accused in F.I.R.No:10/03. The final draft report was sent to the

fourth respondent by the eighth respondent on 19.10.2006. The

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Page 10: reply to counter in Crl.O.P.No6002

Telegram by Traffic Ramasamy to 1) Hon’ble Deputy Chief Minister

Thiru.Stalin,2) The Secretary,Highways &Minor Ports

Department,Secretariat,Chennai-9 3)The Chief Engineer

redesignated as Director, Highways, Chepauk,Chennai-5 4)I.G.P,

V&AC,Chennai on 02.07.09 is submitted before this Hon’ble High

Court. The eighth respondent influenced the fourth respondent to

pass Govt.Lr.No:11477/HL-1/04-22 Dated: 13.10.08 for desanction

of Prosecution against Highways Department Engineers and the

Divisional Accountant and not against the Partners of M/S Sri Devi

Enterprises, Contractors, Chennai, contractor.The departmental

enquiry has been conducted by the departmental enquiry officer with

the final report of the eigth respondent not against the contractor. The

G.O (d) No: 203 Dated: 03.11.2009 against disciplinary proceedings

against departmental employees. It is the case to recover the loss to

the Government from the Contractor in several lakhs. The eighth

respondent misdirected the Chief Judicial Magistrate Court,

Cuddalore and others linked with the contractors.

I denied the statement of the eighth respondent in Para No:6

that the eighth respondent is false and failed to note that I have not

disowned my statement I have submitted statements with my

signature. That documents and the statement has to be annexed in

173 final draft reports. Being the investigating officer inordinately

delayed the case from 2002 and permitted the partners of Sridevi

Enterprises to escape from clutches of law without submitting bail

application before the Hon’ble High Court. The eighth respondent

has to produce the departmental enquiry proceedings before this

Hon’ble High Court to find out the veracity of the departmental

enquiry proceedings. The eighth respondent in order to permit the

accused to escape from clutches of law transferred my husbnd

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Page 11: reply to counter in Crl.O.P.No6002

Shri.R.Thangavel,the Chief Mnager,Neyveli Lignite Corporation to

Barshingsar Project, Rajasthan inconnivance with Thiu.A.R.Ansari,

the former CMD, NLC,Neyveli,Thiru.Alaudin,the former Secretary,

Highways and Minor Ports Department and Thiru.Rajendra

Ratnoo,the former District Collector,Cuddalore. The eighth

respondent has not provided the copy of the 161 statement of the

petitioner and failed to permit the related documents and other details

and the petitioner represented the cases in W.P.No:26463/01 and

everything is my recorded statement and the petitioner cannot

disown my own statement. When the eighth respondent the

compliant failed to provide the details and suppressed the vital facts

and permitted the accused to escape from clutches of law. When

there is the necessity of recovering the loss to the Government

money from the contractors, without the contractor in the enquiry

will not provide a solution for recovery of loss to Government

money.

I denied the statement of the eighth respondent in Para No:7

that the eighth respondent is false and misdirecting the Hon’ble High

Court in Crl.O.P.No:22241/11 when the contractor has not faced

departmental enquiry where is the “Double Jeopardy Condition”?

and the case is to submit final report. In order to permit the accused

the partners of Sridevi Enterprises, the eighth respondent has not

produced the copy of the final draft report before the Hon’ble High

Court. In this situation the eighth respondent has to serve the copy of

my 161 statement of the petitioner and permit to peruse the

documents of first, fourth, fifth and eighth respondents.

I denied the statement of the eighth respondent in Para No:8

is misleading and clearly proves that the eighth respondent wants to

permit the accused to escape from clutches of law and the eighth

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Page 12: reply to counter in Crl.O.P.No6002

respondent submitted false report before the Hon’ble High Court.The

Crl.O.P.No:22241/11 is to submit the final report before the Chief

Judicial Magistrate Court, Cuddalore. Being the investigating officer

must act to recover the loss to the Government money from the

contractors. In this situation it is necessary to produce the related

documents of first, fourth, fifth and eighth respondents with

Crl.O.P.No:22241/11. The above Criminal Original Petition is filed

against the First Information Report No: 10/03 filed by the first

respondent Department on 10.11.2003 on the file of the Chief

Judicial Magistrate Court, Cuddalore and the consequential

proceedings of the respondents to permit the accused to escape from

clutches of law without taking any action to recover the loss to the

Government and causing undue harassment to the petitioner and

thereby this Criminal Original Petitioner filed to call for the records

on the file of the respondents and thereby render justice to the

petitioner with damaged relief and justice.

I denied the statement of the eighth respondent in Para No: 9

is false that the eighth respondent permitted the accused to escape

from clutches of law. The eighth respondent only submitted wrong

report before the Chief Judicial Magistrate Court, Cuddalore, the

Hon’ble High Court in Crl.O.P.No:22241/11. When the Division

bench has clearly passed an order in W.P.No:26463/01 Dated:

23.04.03. The eight respondent failed to note that this

Crl.O.P.No:6002/15 is against sixteen respondents who permitted the

accused to escape from clutches of law and failed to act based upon

my compliant in accordance with law and the Crl.O.P.No:22241/11

is against the eight respondent. The statement of the eighth

respondent is that because of the fourth respondent’s proceeding

dated: 13.10.08 he was unable to procede further.

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Page 13: reply to counter in Crl.O.P.No6002

I denied the statement of the eighth respondent in Para No: 10

that the Para no one and two are essential to prove that first and

eighth respondent inordinately delayed to take action against the

accused in accordance with law and caused undue harassment to the

petitioner and her family members. The Govt Letter Dated: 13.10.08

clearly proves that even though the fifth respondent given sanction

for prosecution against the accused the eight respondent failed to

take action against them and caused undue harassment to the

petitioner.

I denied the statement of the eighth respondent in Para No:

11 that the eighth respondent misleaded the Chief Judicial Magistrate

Court,Cuddalore and the Hon’ble High Court and permitted the

accused the Partners of Sridevi Enterprises and Thiru.Haribabu to

escape from the clutches of law.

I denied the statement of the eighth respondent in Para No: 12

is false that the fifth respondent already granted sanction for

prosecution against the accused, instead of taking action against them

the eighth respondent submitted the false report before this Hon’ble

High Court. The respondent must have submitted final report before

the Chief Judicial Magistrate Court,Cuddalore and must have

permitted the Chief Judicial Magistrate Court,Cuddalore to pass an

order based upon the final draft report. The eighth respondent failed

to submit the report and failed to serve the copy to the compliant and

closed the case without the knowledge of the Petitioner. In

Government service it is necessary to take action against the accused

to recover the loss to the Government. The statement of the eighth

respondent that if there is loss to the Government money if any

proves that the eighth respondent unaware of the facts and

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Page 14: reply to counter in Crl.O.P.No6002

circumstances of the case. In this situation the fourth respondent has

to permit the eight respondent to act in accordance with law to

recover the loss to the Government money.

I denied the statement of the eighth respondent in Para No:13

is denied as false as the eighth respondent is filing counter for him as

well as to the first respondent and the action of the first respondent is

very much essential. The statement in Para No 5 is related to the

Inspector of Police,Vadasery has registered a case F.I.R.No:969/12

u/s 420,409,465,468,469IPC r/w 13(1)(c)Prevention of Corruption

Act1988 Dated:07.06.2012 which is transferred to District Crime

branch by the S.P.Nagercoil in his proceeding C1/29669/2012

Dated:29.06.2012.The Inspector of Police, District Crime,Nagercoil

has not conducted forensic investigation for comparation and has not

transferred the case to the Vigilance Department for further

investigation.The Inspector of Police,District Crime,Nagercoil failed

to call for the records from 1)The Divisional

Engineer(NH)Tirunelveli 2)The Divisional Engineer,C&M,

Nagercoil 3) The Assistant Divisional Engineer, (NH), Nagercoil 4)

The Deputy Superintendent of Police, V&AC,Tirunelveli 5) The

Deputy Superintendent of Police, V&AC,Nagercoil 6)The Project

Director,NHAI,Tirunelveli and 7)the Superintending Engineer,

National Highways,Tirunelveli.The petitioner requested the

Superintendent of Police,Kanniyakumari District to change the

investigation to CBCID. But the Inspector of Police,District

Crime,Nagercoil without conducting a proper enquiry and the

DSP,V&AC,Nagercoil has not conducted investigation and closed

the case a mistake of fact without the knowledge of the petitioner.

When the case registered under section Prevention of Anti-

Corruption Act,the case has to be investigated by the Vigilance

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Page 15: reply to counter in Crl.O.P.No6002

Department. Hence the first respondent has to file counter and to

produce related records in F.I.R.No:969/12.

The statement of Para No 6 is relates to the corruption of

Erode District Police officials and the statement and the action of

first respondent is very much essential. The first respondent stated in

his Lr.Dated:17.02.2014 that the first respondent forwarded my

compliant dated: 15.01.14 against corruption of Erode District Police

officials to the second respondent for the departmental action.The

Public Information officer of DGP, Chennai, the second respondent

in RCNo: 023503/869/RTI-1(2)/2015-2 is denied that the second

respondent has not received the letter from the first respondent.The

first respondent failed to order the Vigilance Department to conduct

an enquiry to find out the petition comes under Vigilance Angle.

Even though he has forwarded my compliant for departmental action

of DGP,Chennai and has to verified by the Director,V&AC,

Chennai. The sub-Inspector of Police,Thiru.Vijayakumar enquiry

Thiru.Purushothamman in my presence and with my father

P.P.Pattappan on 25.11.13.Thiru.Purushothamman accepted his

offence and the copy is permitted for perusal to note down. The copy

of the letter is removed and Thiru.Shanmugham,the Inspector of

Police,Bhavani forced Thiru.Purushothamman to submit false

statement to permit the accused to escape from clutches of law. The

CSRNo: 477/13 has to registered and the accused has to be

arrested .The Erode District Police officials up to SP,Erode by

getting money permitting the accused to escape from clutches of law.

The first respondent has to investigate the case.

I denied the statement of the eighth respondent in Para No:14

is false that the eighth respondent permitted the accused the Partners

of Sridevi Enterprises to escape from clutches of law and caused

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Page 16: reply to counter in Crl.O.P.No6002

undue harassment from 17.06.2002,the day on which loss to

Government money is Proved in W.P.No:26463/01.The copy of the

Divisional bench order is submitted before this Hon’ble High Court.

The petitioner ready to prove the loss to the Government money and

malafide act of the eighth respondent. The eighth respondent has not

produced all the records before this Hon’ble High Court in

Crl.O.P.No:22241/11. The eighth failed to arrest the accused and

failed to recover the loss to the Government from the contractors and

the officials. Any case should not be delayed on delay in getting

sanction as per Supreme Court Judgements. The first respondent

should not get confused with remaining respondents. So many

records are necessary from the remaining respondents and they have

failed to file counter.

I denied the statement of the eighth respondent in Para No: 15

is false the statement are sustainable in F.I.R.No:10/03 .In addition to

that so many accused are not arrested by the Erode District Police,

Cuddalore District Police and Kanniyakumari District.

I denied the statement of the eighth respondent in Para No:16

is false that the eighth respondent may please to note that the Public

Information officer of DGP,Chennai, the second respondent in

RCNo:023503/869/RTI-1(2)/2015-2 is refused that he has not

received letter dated:17.02.2014 based upon my compliant

dated:15.01.14 carrying the corruption charges against Erode District

Police officials. The second respondent failed to take action against

Erode,Cuddalore and Kanniyakumari District Police officials who

failed to take action against the accused in accordance with law and

direct them to arrest the accused.

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Page 17: reply to counter in Crl.O.P.No6002

The eight respondent failed to not that my compliant dated:

01.02.15 is against Highways Department officials and Police

Department officials in three District Cuddalore,Kanniyakumari and

Nagercoil and granting Kalpana Chawla award. The corruption

charges have to be investigated by the first respondent and eighth

respondent. Hence the first respondent has to file separate counter.

It is therefore prayed that this Hon’ble Court directed all the

respondents to file counter on or before 07.04.2015. The petitioner

humbly prayed that this court may please to direct the first

respondent to file separate counter. The Hon’ble High Court may

please to take action against the eighth respondent who permitted the

Partners of Sridevi Constructions, Chennai and Thiru.Haribabu,the

Junior Engineer(H) Nabard Section,Kattumannarkovil to escape

from clutches of law without recovering the loss to the Government

money.

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