Narazi Petition

1
District South 24 Parganas
In the Court of the Ld. Addl. Chief Judicial Magistrate at Alipore
REF:- Survey Park P.S. Case No. 44/

2021 .
In the matter of :
An application u/s 173(8) of Cr.P.C.
In the matter of :
The Govt. of West Bengal

….Complainant
Swapna Chowdhury
...Defacto Complainant
/ Petitioner
NARAZI PETTITION -VS-
1.Sankar Chowdhury
2.Sandhya Chowdhury
3. Ruma Guha
4. Sarit Ghosh
……. Accused
u/s 498A, 406, 34 I.P.C & 3,4 of D.P. Act
Date :-
The humble “Narazi “Petition on behalf of the

above referred defacto complainant namely
Swapna Chowdhury.
Most Respectfully Showeth:-
1. That the written complaint on 02.03.2021 and on behalf of the

above refereed petitioner police, Survey Park Police Station started
the instant case against four accused person namely 1) Sankar
Chowdhury 2) Sandhya Chowdhury 3)Ruma Guha 4) Sarit Ghosh @
Bapi u/s 498A, 406, 34 I.P.C. & 3,4 of D.P. Act. (Xerox copy of the
written complaint and formal F.I.R. is attached with this application
and marked as Annexure-A)
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2. That the instant case was endorsed fro investigation by the Officer in
Charge, Survey Park police station to a Sub Inspector (S.I.) namely
A.K. Sarkar. The said Investigation Officer (I.O.) took up the task of
investigation of the instant case and after completion of the
investigation filed a Charge Sheet vide no. 62 of 2021 dated
30.04.2021 against accused Sankar Chowdhury and Ruma Guha
but the said I.O did not submit Charge Sheet against accused
Sandhya Chowdhury and Sarit Ghosh and I.O. also prayed for
discharge of the said accused of the instant case. (Xerox copy of the
above referred charge sheet is attached with this application and
marked as Annexure-B)
3. That there is a specific charge against the above referred accused

namely Sandhya Chowdhury who happens to be mother in law of
the petitioner, who cause immense physical and mental torture
upon the petitioner on the grounds of demanding more dowry
articles & cash. It is also stated in the written complaint that the
said mother-in-law along with other co-accused persons used to
cause physical & mental torture including abused the petitioner
with most filthy language.
4. That the facts remain that the mother-in-law is the principal

conspirator and at her instant all the accused cause inhuman
torture both in physical and mental form upon the petitioner and
threw her out of the in-laws house as such the report submitted by
the I.O. with a prayer for discharge of the principal conspirator/
accused has highly aggrieved the petitioner and the petitioner was
not satisfied with the investigation conducted by the present
investigation officer (I.O.).
5. That the accused namely Sarit Ghosh @ Bapi is also highly involved
in the commission of offence as in the written complaint submitted
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by the petitioner its is already stated that said accused used to come
at the in-laws house of the petitioner almost every day and arrange
party to consume liquors with all the accused, he also actively
participated in those party and to create trouble at the family life of
the petitioner by instigating the husband, mother in law and sister
in law of the petitioner against the petitioner.
6. That the husband of the petitioner is a habitual drunker and her

often with the instigation of other co-accused cause inhuman
torture in every form upon the petitioner.
7. That the case was instituted the said Investigation Officer (I.O.)
never call up the petitioner at her paternal family member to record
their statement or to take information for the petitioner to examine
the witness of the occurrence who are residing in and around the in-
law’s house of the petitioner on the other hand the Investigation
Officer (I.O.) sighted the persons as witness of the case are not
known to the petitioner and never came to his in laws house during
her stay, they may are the well wishers of the accused persons as
such petitioner dissatisfy with the report and the investigation
conducted by the present Investigation Officer (I.O.).
8. That the petitioner is astonished aggrieved and dissatisfied with the

investigation and the report in form of Charge Sheet submitted by
the Investigating Officer (I.O.) filing this instant “Narazi” petition or
proper adjudication of the matter.
9. That the defacto complainant/ petitioner states and submit that the
investigating officer (I.O.) was not acting impartially and in obidence
to law is clear from the fact which has been brought up in this
application before the Learned Court.
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10. That the defacto complainant / states that these facts are not mere
lapses or ignorance in conducting Investigation, rather these facts
make out a case of foul play and deliberate manipulation of
investigation by the Investigating Officer.
11. That the defacto complainant/ petitioner states and submit that the
admitted facts as indicated above, clearly made out a clear case of
unfair and manipulated investigation by the investigating officer of
this case.
12. That the defacto complainant/ petitioner states and submitted that
the present Investigating Officer (I.O.) submitted the Charge Sheet in
such a manner as he can save the above referred accused no. 2
Sandhya Chowdhury and accused no. no. 4 Sarit Ghosh @ Bapi
from the punishment of offence committed to be punishable u/s
498A, 406, 34 of I.P.C. and 3 & 4 of D.P. Act
13.That the defacto complainant / petitioner state and submit that

unless the re-investigation directed by the Learned Court in the
above referred case matter, the petitioner will highly prejudiced fare
justice and suffered with highly irreparable loss and injury.
14.That this application is made bonafide in the interest of

administration of justice.
In the above stated facts and

circumstances it is prays that Your
Honour would be graciously pleased to
pass the following orders;-
a) To allow the instant “Narazi”

Petition filed by the defacto
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complainant/ petitioner, in the interest

of Justice
b) To direct the Officer in Charge,
Survey Park Police Station to further
investigate the above referred case being
Survey Park P.S. Case no. 44 of 2021,
u/s 173(8) Cr.P.C. and to submit report
for the ends of justice by any competent
officer.
c) And/or to pass such other

necessary order or orders or further
order or orders as Your Honour may
deem fit and proper, for the ends of
justice.
And for this act of kindness your petitioner as in duty bound shall ever
pray.
VERIFICATION
I, Smt. Swapna Chowdhury nee Paul, wife of Sri Sankar Chowdhury,

aged about 47 years, presently compelled to reside at 44/1F, Hind Road,
P.O.- Santoshpur, P.S.- Survey Park, Kolkata-700075, the Petitioner do
hereby verify this petition and state that the statements made in the
foregoing petition are true to the best of my knowledge and belief and I
sign this Verification on this day of ………………, 2022 at my Ld.
Advocate Chamber
DEPONENT
Identified by me
Nirupam Dewanji
Advocate
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BEFORE THE NOTARY PUBLIC AT ALIPORE, 24-PARGANAS

(SOUTH)
AFFIDAVIT
I, Smt. Swapna Chowdhury nee Paul, wife of Sri Sankar Chowdhury,

aged about 47 years, presently residing at 44/1F, Hind Road, P.O.-
Santoshpur, P.S.- Survey Park, Kolkata-700075, do hereby solemnly
affirm and declare as follows:
1. That I am the Petitioner of the annexed Narazi petition Under

Section 173(8) Cr.P.C.
2. That the contents stated therein are true to the best of my
knowledge and belief and nothing is concealed therein are true to
the best of my knowledge and belief and nothing is concealed
therein.
3. That I am an Indian National.
DEPONENT
Identified by me
Nirupam Dewanji
Advocate

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1

District South 24 Parganas

In the Court of the Ld. Addl. Chief Judicial Magistrate at Alipore

REF:- Survey Park P.S. Case No. 44/

The Govt. of West Bengal

u/s 498A, 406, 34 I.P.C & 3,4 of D.P. Act

The humble “Narazi “Petition on behalf of the

Most Respectfully Showeth:-

1. That the written complaint on 02.03.2021 and on behalf of the

3. That there is a specific charge against the above referred accused

4. That the facts remain that the mother-in-law is the principal

6. That the husband of the petitioner is a habitual drunker and her

8. That the petitioner is astonished aggrieved and dissatisfied with the

13.That the defacto complainant / petitioner state and submit that

14.That this application is made bonafide in the interest of

In the above stated facts and

a) To allow the instant “Narazi”

complainant/ petitioner, in the interest

c) And/or to pass such other

I, Smt. Swapna Chowdhury nee Paul, wife of Sri Sankar Chowdhury,

BEFORE THE NOTARY PUBLIC AT ALIPORE, 24-PARGANAS

I, Smt. Swapna Chowdhury nee Paul, wife of Sri Sankar Chowdhury,

1. That I am the Petitioner of the annexed Narazi petition Under

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