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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
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

petitioner resulting in a travesty of justice.