I, G. Karunairaj S/O Gnanamuthu, aged 52, residing at 108A, First Floor, Ananda Nilayam, Vivekandar Street, Balaji Nagar, Ponneri 601204, Tamil Nadu, hereby solemnly and sincerely affirm as follows:

1. I am The Petitioner herein and am well acquainted with The Fact and Circumstances of The Case, hence competent to file this Representation.
2. I humbly state brief of The Case that under section 51 of CRPC on search of arrested person was violated when I was arrested by Inspector Chandrasekharan of CCB Coimbatore along with my family on 21.08.2010 in Hotel Aravind Residency, Chennai. Under section 51 (1) clearly stipulates that A Receipt showing The Articles taken in possession by The Police Officer shall be given to such person. It is humbly submitted that my possessions was neither accounted in my presence or receipt given to me as mandated by The Code of Criminal Procedure, 1973. The Laptops and Mobiles seized from me on 21.08.2010 consist of incriminating evidence against Mr. Sylendra Babu and his wife, Mrs. Sofia. I cried in vain for Serial Numbers of Laptops and Mobiles etc to be recorded in my presence.
3. There is Possibility of Items Substitution due to Criminal Involvement of 3 IPS Officers in Cheyyur Murder Crime No.609/2004 which stands exposed via seized Mobiles and Laptops as well as evidence kept at The Petitioner’s residence. I further state that u/s 100 (6) CRPC clearly stipulates that The Occupant of The Place searched or someone in his behalf shall in every instance be permitted to attend The Search and A Copy of The List prepared under this section signed by The Said Witness shall be delivered to such occupant or person.
4. My cry to be present or at least depute someone during search at my residence G1 Iyanabathini Emerald Gupta Apartments, Mangamaru Donka, Ongole – 1, Andhra Pradesh was in vain. Valuables and incriminating evidence implicating Mr. Sylendra Babu and his wife, Mrs. Sofia in Cheyyur Murder vide Crime No. 609/2004 was in The Residence. Till date, list prepared under section 100 (6) including The Residence Keys seized from me on 21.08.2010 has not been delivered to me.
5. On 18.11.2010, Police Superintendent of Prakasam District wrote to Andhra Pradesh Director General Police (DGP) vide Ref.C.No.104/C2-DCRB/2010 pursuant to DGP Memo vide Rc.No.5182/Compts-2/2010 dated 26.10.2010. On 23.11.2010, Additional Superintendent of Coimbatore Central Prison received An Intimation from Andhra Pradesh Police Department pertaining to my representation vide Ref.C.No.19255/WO/2010 dated 08.10.2010.
6. The Petitioner humbly submits that The Honorable Supreme Court decree is binding under Article 141 and non-adherence is punishable under Article 121 of The Constitution of India. The Honorable Justice S. B. Sinha and The Honorable Justice M. K. Sharma decreed in Bhavesh Lakhani versus State of Maharashtra that: “The State may exercise some extraterritorial jurisdiction only if a part of The Offence is committed in The State and The Other Part in another State or some other States. In such an event, The State before an investigation to that part of The Offence which has been committed in any other State may have to proceed with The Consent of The State concerned or must work with The Police of The Other State.” {2010 (1) SCC (Cri) 47 Para 95}. Hence, I am amazed that CCB Coimbatore could enter another State – Andhra Pradesh to steal and destroy incriminating evidence pertaining to Cheyyur Murder Crime No.609/2004 as The Andhra Pradesh Police was kept in The Dark to facilitate easier theft. The Act of Disregarding Supreme Court Decrees by Public Servants is A Dangerous Trend.
7. Among robbed items are:
i. 3 CDs recording involving Mr. Sylendra Babu.
ii. 2 Albums of Photographs with Family Members, Prime Minister of Nepal, Chief Minister of Goa and IPS Officers etc.
iii. Currencies and Gold kept in Rice Container including United States Dollars Five Thousand Only, 10 Gold Bars of 100gms each, Lord Jesus Christ Small Gold Statue and Family Jewels.
iv. In Residence Hall Wall, Goddess Mahalaxmi Gold Frame, God Vinayaga Silver Frame and 2 Expensive Paintings.
v. Expenses Receipts spent on Senior I.P.S. Officers at various Five Star Hotels etc.
8. The Andhra Police Department memo clearly proves violation of The Directive Principles of The Constitution, Inter-State Laws and Supreme Court decrees including one cited in Para 6 above as it remarked that: “Nothing-is-Known to Local Police of Ongole Town”. The Petitioner prays that The State register F.I.R. and arrest criminals who committed day-light robbery.
9. My steadfast struggle has resulted in A Land Mark Decree reported in Law Journals including Chennai Law Times {2012 (1) C.L.T. 940} G. Karunairaj versus State of Tamil Nadu. The Honorable Justice V. Ramasubramanian observed in Para 40 of W.P. No.27221/2011: “… This shows that there was some anxiety on The Part of Respondents not to allow The Petitioner to enjoy The Freedom that he gained on 8.11.2011 on account of The Bail Orders”
10. I submits that u/s 51 (1) r/w 100 (6) CRPC and numerous Supreme Court decrees stands brutally violated under Mr. Sylendra Babu’s order. The involvement of Mr. Sylendra Babu as well as his wife and colleagues was stated in detail before The Utheremerur Judicial Magistrate u/s 164 CRPC on 23/11/2010 as well as The Honorable Madras High Court under Article 226 of The Constitution vide HCP 177/2011 on 28.01.2011.

I pray as follows:
1. Investigation into mala-fide illegal entry into The into my residence at G1 Iyanabathini Emerald Gupta Apartment, Mangamaru Donka, Ongole 1, Andhra Pradesh in violation of provisions under CRPC as well as The Honorable Supreme Court Decrees.
2. The Properties seized from The Petitioner’s residence as stated in Para 7 above be secured and released to me.
3. My representation vide Ref.C.No.19255/WO/2010 dated 08.10.2010 sent via Coimbatore Central Prison Superintendent to The Andhra Pradesh Director General of Police be termed as First Information Report (FIR).

G. Karunairaj S/O Gnanamuthu


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