SYNOPSIS AND LIST OF DATES

The Petitioner is compelled to approach this Honble Court by way of Public Interest Litigation under Article 32 of the Constitution of India in the nature of mandamus regarding the PDS Scam, which has engulfed the State of Chhattisgarh casting a long and dark shadow over the credibility and integrity of the Chief Minister of Chhattisgarh itself, and therefore as a Resident of the State of Chhattisgarh the Petitioner wishes to ensure that proper investigation takes place in the present case. Recent developments have shown that the current investigation agency, ACB, has been carrying out investigation just in order to safeguard the main perpetrators of the crime who happen to be high dignitaries of the State of Chhattisgarh.

The Civil Supplies Corporation was the nodal agency in charge of implementing and ensuring smooth operation of the PDS in the State. Civil Supplies Corporation is under the control of Chhattisgarh government. It has the complete responsibility of Rice procurement, specified quality of rice procurement, storage, transportation, and to ensure the availability of rice to the shopkeepers through PDS in Chhattisgarh.

In the present case all the officials of Civil Supplies Corporation Raipur, Chhattisgarh from field level to senior officers are involved in the illegal act of procuring, transporting and storing of rice. These officers are misusing their authority to illegally recover money from the rice millers during procurement and transportation of rice and other food grains as well. It is in these circumstances that the Petitioner has approached this Honble Court by way of the present Writ Petition in the form of a Public Interest Litigation.

DateEvent

December 2004The Public Distribution System was made applicable in the State of Chhattisgarh in the year 2005 by way of Chhattisgarh Public Distribution System (Control) Order 2004. Public Distribution System means the system for distribution of essential commodities to the ration cardholders through the Fair Price Shops, such as rice, wheat, sugar, kerosene and salt and such other commodities as notified by the State Government.

12.02.2015FIR No.9/2015 was registered at Raipur by the State Economic Crimes Investigation Bureau to investigate various charges with regard to the PDS in Chhattisgarh.

12.02.2015Raids were conducted at the offices of the Civil Supplies Corporation of Chhattisgarh in Raipur where various diaries, prinrouts, pen drives, and other incriminating material was found which revealed the involvement of high dignitaries and officials of the State of Chhattisgarh including even the Chief Minister and his relatives.

06.06.2015Chargesheet was filed by the ACB against some persons. However, the ACB deliberately did not file all the material that was seized during the raids since it incriminated and implicated high dignitaries and officials of the State including the Chief Minister. Not only this, the ACB instead of prosecuting key persons who played a pivotal role in the scam of maintaining an account of transactions and who were in charge of ensuring that the money reached the various officials, were in fact protected by being made witnesses and not charged as accused(s).

15.07.2015Hence this Petition.

IN THE SUPREME COURT OF INDIA

CIVIL ORIGINAL JURISDICTION

WRIT PETITION (CIVIL) NO. OF 2015

IN THE MATTER OF:Virendra Pandey,

S/o Late Brijbihari Pandey

Aged about 65 years

R/o 31/666, New Shanti Nagar,

Raipur, Chhattisgarh 492007 ...Petitioner

Versus

1. State of Chhattisgarh,

Through Secretary,

Food, Civil Supplies and

Consumer Protection Department,

Mahanadi Bhavan, New Raipur,

District Raipur, Chhattisgarh

... Respondent No. 1

2. State of Chhattisgarh

Through Secretary,

Department of Home,

Mahanadi Bhavan, New Raipur,

District Raipur, Chhattisgarh

.... Respondent No. 2

3. Anti Corruption Bureau,

Through its Chief,

Near Teli Bandha Talab,

Teli Bandha G.E. Road,

Raipur, Chhattisgarh

.... Respondent No. 3

4. Central Bureau of Investigation,

Through Director,

Plot No. 5-B, CGO Complex,

Lodhi Road, New Delhi- 110003... Respondent No. 4

All are Contesting RespondentsAND IN THE MATTER OF WRIT PETITION UNDER ARTICLE 32 OF THE CONSTITUTION OF INDIA IN THE NATURE OF PUBLIC INTEREST LITIGATION SEEKING, INTER ALIA, ISSUANCE OF AN APPROPRIATE WRIT, ORDERS OR DIRECTIONS IN THE NATURE OF MANDAMUS DIRECTING THE RESPONDENT NO.3 TO PRODUCE THE RECORD OF THE ENTIRE INVESTIGATION CARRIED OUT BEFORE THIS HONBLE COURT, AND TO FURTHER INVESTIGATE FIR NO. 09/2015 REGISTERED BY THE STATE ECONOMIC CRIME INVESTIGATION BUREAU AT RAIPUR AND / OR ANY OTHER PDS RELATED SCAM FOR FAIR AND IMPARTIAL INVESTIGATION BY CBI OR ANY OTHER CENTRAL AGENCY, AND FURTHER AN ORDER TO SET UP A SPECIAL INVESTIGATION TEAM TO MONITOR THE INVESTIGATION.

To,

The Honble Chief Justice of India

and his Companion Judges of the Honble Supreme Court of India.The humble petition of the Petitioner above named.MOST RESPECTFULLY SHOWETH:-

1. That the Petitioner is compelled to approach this Honble Court by way of Public Interest Litigation under Article 32 of the Constitution of India in the nature of mandamus for issuance of an appropriate writ directing the respondent to transfer the investigation of the PDS Scam in the State of Chhattisgarh to the Central Bureau of Investigation. The present Petitioner has no personal interest in the litigation and the petition is not guided by self-gain or for gain of any other person/ institution/ body and there is no motive other than that of public interest in filing the present Writ Petition. The present Petitioner is a resident of India, and as such, is competent to file the present petition in public interest.

1A. That the present Petitioner has not approached the Green Tribunal or concerned authority at any point of time before or after filing of the present Writ Petition for any similar relief as the Petitioner does not have any personal stake in the matter2. That the Petitioner is a law abiding citizen of this country and a permanent resident Chhattisgarh at the above mentioned address. The Petitioner Shri Virendra Pandey is a social activist and an Ex-MLA from Chattisgarh and has been in political life in the past, having PAN No. AFCPP5100L, Aadhaar No.612972512458, Mobile No. 9425507296 and has filed an Income Tax Return of Rs. 5 Lakhs per annum. The Petitioner is the former Chairman of the Chhattisgarh State Finance Commission and has been vocally raising the issue of the present PDS scam in the past. The present Petition is solely being filed in public interest and the Petitioner has no personal interest in the present case. 3. That the sources of knowledge regarding the facts involved herein the writ are various newspaper articles and information available in public domain after the press conference held by senior congress leaders. 4. That Respondent No. 1 is the Food, Civil Supplies and Consumer Protection Department, which is concerned with ensuring that there is no irregularity in distribution of essential commodities in terms of the PDS Order of the State of Chattisgarh. 5. That Respondent No. 2 Department of Home of the State of Chattisgarh. The ACB (R-3) is under the control and supervision of the Home Department and therefore R-2 is a Necessary Party in the present case.

6. That Respondent No. 3 is the Anti-Corruption Bureau (ACB), which has been carrying out investigation so far in the PDS Scam. 7. Respondent No.4 is the Central Bureau of Investigation (CBI). In the present case the Petitioner has prayed for investigation by CBI and therefore CBI would be a necessary party in the present case. 8. That all the necessary information regarding the petitioners which is required to be disclosed under Order XXXVII Rule 12(2) is provided hereunder:-

FULL NAME OF PETITIONER:Virendra Pandey

COMPLETE POSTAL

ADDRESS:

31/666, NEW SHANTI NAGAR, RAIPUR, CHHATTISGARH

PINCODE - 492007

EMAIL ADDRESS: virendrapandey.raipur@gmail.com

PHONE NUMBER:+919425507296

PROOF REGARDING

Personal Identification: PAN Number AFCPP5100K

Occupation:

Social Activist

Annual Income:

Around 5,00,000/-

9.That the facts constituting the cause of action in the present Writ Petition are as follows:-The present public interest litigation is regarding the PDS Scam which has engulfed the State of Chhattisgarh casting a long and dark shadow over the credibility and integrity of the Chief Minister of Chhattisgarh itself and therefore as a Resident of the State of Chattisgarh the Petitioner wishes to ensure that proper investigation takes place in the present case. Recent developments have shown that the current investigation agency, ACB, has been carrying out investigation just in order to safeguard the main perpetrators of the crime. It is in these circumstances that the Petitioner has approached this Honble Court by way of the present Writ Petition in the form of a Public Interest Litigation. 10.Facts leading to filing of the Writ Petition are stated as under: 11.The Public Distribution System was made applicable in the State of Chhattisgarh in the year 2005 by way of Chhattisgarh Public Distribution System (Control) Order 2004. Public Distribution System means the system for distribution of essential commodities to the ration cardholders through the Fair Price Shops, such as rice, wheat, sugar, kerosene and salt and such other commodities as notified by the State Government.

12.To achieve the said purpose, a system was put in place to ensure that each household would receive basic rations to consume. The scheme was for the benefit of the citizens to curb the problem of malnutrition in the State and to provide good quality, nutritious food items to every household.

13.The Civil Supplies Corporation was the nodal agency in charge of implementing and ensuring smooth operation of the PDS in the State. Civil Supplies Corporation is under the control of Chhattisgarh government. It has the complete responsibility of Rice procurement, specified quality of rice procurement, storage, transportation, and to ensure the availability of rice to the shopkeepers through PDS in Chhattisgarh.

14.In the present case all the officials of Civil Supplies Corporation Raipur, Chhattisgarh from field level to senior officers are involved in the illegal act of procuring, transporting and storing of rice. These officers are misusing their authority to illegally recover money from the rice millers during procurement and transportation of rice.

15.During rice procurement due rules and regulations have to be followed in order to maintain the standard of rice being distributed through the PDS. The officials of the Civil Supplies Corporation have accepted monetary compensation and in return passed/cleared sub-standard quality rice to be distributed throughout the state of Chhattisgarh via PDS thereby causing a serious health hazard to the citizens apart from unjustly enriching themselves. An intricate web was put in place to ensure that money gained in this manner is distributed throughout the state to all the officials, with this trail leading right to the doorstep of the Chief Minister itself.

16.Also, movement of rice from one surplus district to another surplus district is banned and any rice miller has to submit the rice to the local area depot to avoid any unnecessary transportation charges. The Civil Supplies Corporation MD, Anil Tuteja had authorized unnecessary movement of rice in order to empty certain godowns so that the rice millers can submit extra rice in certain godowns and the Civil Supplies Corporation officials can earn kickbacks on the extra transportation charges.

17.An independent investigation was carried out and out of 252 samples tested, 111 samples turned out to be of inferior quality.

18.When the scam was brought to the notice of the Anti Corruption Bureau (hereinafter referred to as ACB, the State Economic Crime Investigation Bureau on the information received from the ACB, registered an FIR being No.9/2015 dated 12.02.2015. True translated copy of the FIR No.9/2015 dated 12.02.2015 is annexed herewith as Annexure - P/1. (Pgs ____ to ____) 19.Pursuant thereto, the ACB conducted various raids at the offices of the Civil Supplies Corporation throughout the state. During the raid, primarily the following was recovered: a) Rs.20 Lacs was recovered from one Mr.Girish Sharmas cabin, PA to Anil Tuteja, MD of Civil Supplies Corporation, along with a Pen Drive, and printouts in which details and accounts of transactions are recorded;

b) A Diary was recovered from Sh.Shiv Shankar Bhatt, District Manager Head Office of Civil Supplies Corporation containing 113 pages detailing accounts of ill-gotten money running into over Rs.3000 crore along with a sum of Rs.1,62,97,500/- in cash; c) A diary belonging to Sh.Arvind Dhruv, Steno to MD, Civil Supplies Corporation was recovered;

d) 127 pages of printouts and pen drives were recovered from K.K.Barik, Steno-cum-Courier of ill-gotten money.

20.The petitioner submits that the above diaries that were recovered during the raids not only conclusively show the compliance and involvement of high dignitaries and officials of the state of Chhattisgarh, but also the key role played by high dignitaries in orchestrating the entire scam, without which the scam could not have reached the magnitude that it has today.

21.The diaries record all the transactions and all the payments that were made to the dignitaries and officials of the state of Chhattisgarh. The case therefore becomes somewhat similar to the Jain Hawala Diary Case of the year 1996.

22.Pursuant to the raids, the ACB filed a challan charging a number of accused persons with offences committed under section 13(1) D r/w section 13(2) and 11 of the PC Act, 1988 and 109,120B, 409, and 420 of the IPC. True translated copy of the Final Report/Charge Sheet No. 26 of 2015 dated 06.06.2015 is annexed herewith as Annexure - P/2. (Pgs ____ to ____) 23.The ACB however has chosen selectively to file only some parts of the diary along with the challan with the sole oblique motive of protecting the high dignitaries by withholding those pages which are implicating them. The ACB is clearly acting hand-in-glove with the accused so as to ensure that no investigation is carried out against the higher dignitaries despite there being glaring evidence of the involvement of none other but the Chief Minister himself.

24.It is submitted that in the challan, the ACB has filed only 3 pages of the diary recovered from Sh. Girish Sharma when in fact the diary contained more pages. True translated copy of the 3 pages of the diary of Girish Sharma filed along with the challan dated nil is annexed herewith as Annexure P/3. (Pgs ___ to ___)

However, even a perusal of the said 3 pages clearly, unmistakably, and unambiguously shows the involvement of the wife of the Chief Minister, and the sister-in-law of the Chief Minister. Despite the same, the ACB has conducted no investigation in this regard. The diary reveals that an amount of Rs.3,00,000/- has been paid to Aishwarya Residency, coincidentally the place at which the Sister-in-Law of the Chief Minister resides. The diary also contains an entry-dated 03.12.2014, which states that a part of the amount, which one Mr. Chandrakar had given to C M Madam, has been given to K.K.Barik. Despite such incriminating evidence surfacing during the raid, the ACB in their wisdom has not thought it fit to conduct any investigation in that regard.

25.Further the ACB has once again only filed 6 pages of the diary of Sh. Shiv Shankar Bhatt when admittedly it contains 113 pages. True translated copy of the 6 pages of the diary dated nil is annexed herewith as Annexure P/4. (Pgs ___ to ___)

It is shocking that even these 6 pages reveal that payments have been made directly to the Chief Minister by the name of Dr. Sahib and his wife by the name of CMM (Chief Minister Madam). However, once again the ACB has chosen not to pursue any leads in this regard. 26.The ACB has deliberately chosen not to file the remaining portions of the diaries since they directly implicate the CM and his close relatives. However, the petitioner is annexing some portions of the diaries, which are available with him that clearly and unmistakably show the involvement and undoubted implication of the Chief Minister and his relatives. Copies of the said pages shall be handed over to the Honble Court at the time of hearing. The Petitioner has come in possession of these incriminating documents proving complicity of high dignitaries of the State by way of a press conference recently conducted by senior leaders of the Congress party. The said documents were released and also passed on to the media and therefore are in the public domain. For facility of reference, some portions of the diary is being reproduced hereunder which directly implicate the Chief Minister and his relatives.

(i)Diary Entry of 04.01.2014

Rajnandgaon -2.00 cr

Along with AT Jagdalpur- 1.65 cr to RM Dr House

Bilaspur

- 2.85 cr

Durg

- 3.00 cr

Notes:- (a) AT stands for Anil Tuteja, MD of State Civil Supplies Corporation.

(b) RM stands for Shri Rajesh Mudat, PWD Minister.(c) Dr House stands for Dr. Raman Singhs House.

(ii)Diary Entry of 08.04.2014

Satna A/c 22 cr A/P

Notes:- (a) Satna A/c stands for the account of in-laws of Chief Minister.

(b)A/P stands for all paid.

(iii)Diary Entry of 10.04.2014CM. House A/c A/P 333.00 cr

Stores Ass.125 x 2.10 = 262.5

(iv)Diary Entry of 02.05.2014

DM-27 x 4.80 = 129.6

P to House

Store Ass. M x 125 1.8 = 225.00

P to House

Thapa A/c all paid to CM House A/c350

Note:- P to House stands for paid to house of Chief Minister.

(v)Diary Entry of 07.06.2014

BJK-For CM House A/c

-42.65

Satna A/c Behan Ji wala

-33.30

DM x 27 x 4-95 = 3608)

7733 Month end May

AS M 125 x 330 = 4125) AT by - (CM House)

Rice Millers Ass. All -Dr CM House 37.00

Notes:-(a) BJK stands for Shri Baijendra Kumar, Additional Chief Secretary.

(b) Satna A/c Behan Ji stands for Account of sister-in-law of CM(c) AT stands for Shri Anil Tuteja, MD of Civil Supplies Corporation.

(vi)Diary Entry of 13.07.201410 Satna A/c

3.38

11Thapa A/c House for (Mam only) 38 cr/on demand

by Reddy

Notes:- (a)Satna A/c stands for Account of in-laws of Chief Minister.

(b) Thapa stands for Shri Bahadur Thapa, Courier-cum-Cook of Chief Minister.

(c)Mam stands for wife of Chief Minister.

(vii)Diary Entry 07.09.2014

VVS for CM House

-495 to/695 A/c

Note:- VVS stands for Shri Vivek Saxena, OSD to Chief Minister.

(viii)Diary Entry 11.10.2014

BJK CM House 400.00 A/P

Note:- BJK stands for Shri Baijendra Kumar, Additional Chief Secretary.

(ix)Diary Entry 12.10.2014

Rice Mill Ass. All 15 cr CM House

VVS CM House 167.00 cr month end

Note:- VVS stands for Shri Vivek Saxena, OSD to Chief Minister.

(x)Diary Entry 01.11.2014

Satna A/c

6.00

BJK CM House 16.40

Notes:- (a) Satna A/c stands for account of in-laws of Chief Minister.

(b)BJK stands for Shri Baijendra Kumar, Additional Chief

Secretary.

(xi)Diary Entry 02.11.2014

1Lucknow Trf

16)

2Nagpur Trf

16)48 cr

3Delhi D/R/F/Trf/by Dr. 16 )

Notes:- (a) It is clear that ill-gotten money was being transferred to Lucknow and Nagpur to the extent of Rs.16 crore each i.e. 32 crore.

(b) It is also clear Dr. Raman Singh (ref. to Dr.) was transferring funds for BJP in Delhi to the extent of Rs.16 crore.

27.The above clearly shows that the CM was not only involved in the entire scam, but was orchestrating the entire scam and was a major beneficiary of the same. All the money that was accepted in bribes for allowing sub-standard quality of rice to enter the market has been distributed among all the state officials through an intricate web which clearly leads to the doorstep of the Chief Minister himself. An independent and uninfluenced probe and investigation into the scam would bring everything to light.

28.Not only this, the ACB has gone a step further, and made persons like Girish Sharma, Arvind Singh Dhruv, K.K. Barik, Jeet Ram Yadav, and Sandeep Aggarwal witnesses in their case, whereas they were the so-called kingpins of the entire operation. The details of the role that each one played are given below:

(a)Shri Arvind Singh Dhruv was among the main kingpins responsible for maintaining the entire record of ill-gotten money.

(b)Shri Girish Sharma who also maintains record of ill-gotten money on laptop, pendrive and separate sheets. Even Rs.20 lakh were recovered in cash from him by ACB.

(c)Shri K.K. Barik. He also maintains record of ill-gotten and is courier of money. Even pen drive was recovered from him out of which he has deleted the record. It is pertinent to mention that even in the pages of the diary which has been filed by the ACB, it is clearly revealed that a part of the amount which one Mr.Chandrakar had paid to C M Madam was paid to this Mr.Barik. Yet, no investigation into this has been made, rather, startlingly Mr.Barik has been made a witness.

(d)Shri Jeet Ram Yadav, another kingpin. Even a sum of Rs.36,06,000/- was recovered from him by ACB.

(e)Shri Sandeep Aggarwal, Company Secretary of NAN. A sum of Rs. 34,99,500/- was recovered from him.

29.Despite the above persons playing key-roles in the scam, they have not been made charged with any offence; rather, an all out effort is being made by the ACB to protect these people.

30.It is further submitted that officers of the ACB have interrogated Sh. Girish Sharma so as to enable them to decode the diaries that were maintained by him. True copy of the transcript of the conversation between the ACB Officer and Girish Sharma dated nil is annexed herewith as Annexure - P/5. (Pgs____ to ____)

There is a clear indication of large scale bungling of the PDS system and it also reflects that every official of the State Administration including the Chief Minister are involved in the scam.

31.All of the above material has been conveniently ignored by the ACB and not an iota of anything even resembling an investigation has been conducted in this regard. Rather, the persons with whose help the involvement of the CM and other officials has been unearthed are being made witnesses in the matter rather than prosecuting them. It is therefore imperative that an independent and impartial investigative agency like the CBI be directed to carry out a fair investigation into the scam.

32.That the petitioner is not involved in any civil, criminal, or revenue litigation which could have a legal nexus with the issue involved in the PIL.

33.That the present petition is being filed in the larger public interest and the petitioner has no personal gain, private motive, or oblique reason in filing the present public interest litigation.

34.That the Petitioner has not filed any other or similar petition before this Honble Court of any other Courts of India against the same relief.

35.The present Petition has been preferred on the following amongst various other grounds-

GROUNDS:A. BECAUSE the source of corruption in the biggest Public Distribution System Corruption Scam leads directly to the door step of Chief Minister Dr. Raman Singh.

B. BECAUSE a bare perusal of the three pages of the diary of Shri Girish Sharma clearly shows that money was paid to the wife of the Chief Minister on 03.12.2014.

C. BECAUSE Sh. Girish Sharma, whose diary clearly shows an entry showing the money being paid to the wife of the Chief Minister, has not been made an accused.

D. BECAUSE the same three pages of the diary of Sh. Girish Sharma also shows that money was paid to the sister-in-law of the Chief Minister (sister of Smt. Veena Singh, wife of Dr. Raman Singh). The said entry is marked as Aishvarya Residency.

E. BECAUSE the six pages of diary of Shri Shiv Shankar Bhatt attached to the Challan shows a payment made to Chief Minister and his family/staff.

F. BECAUSE a bare perusal of the page marked as Q4 shows a payment made to Doctor Sahib i.e. Dr. Raman Singh. Perusal of page marked Q5 again shows payment made to Doctor Sahib i.e. Dr. Raman Singh. A perusal of page marked Q6 reflects made to CMM i.e. Chief Minister Madam. Same page reflects payment made to CMC i.e. Chief Ministers Cook, Shri Bahadur Thapa.

G. BECAUSE a cover-up operation to cover the tracks of all such payments and save the Chief Minister Dr. Raman Singh and others is writ large. The same can be established from the following:-

(i) Diary of Shri Shiv Shankar Bhatt admittedly contains 113 pages. Only six pages were presented along with the challan and remaining 107 pages containing details of ill-gotten money paid upto the highest levels were deliberately omitted.

(ii) A second diary was admittedly recovered from Shri Arvind Dhruv containing record of ill-gotten money. However, only three pages have been attached to the challan and rest of the diary containing record of the ill-gotten money has been conveniently omitted.

(iii) The main kingpins of the entire scam, who were owners-in-possession of the entire record, have not been challaned at all. Shockingly, they have, in fact, been made witnesses to prove the crime by others. They are:-

(a) Shri Arvind Singh Dhruv was among the main kingpins responsible for maintaining the entire record of ill-gotten money.

(b) Shri Girish Sharma who also maintains record of ill-gotten money on laptop, pen-drive and separate sheets. Even Rs.20 lakhs were recovered in cash from him by ACB.

(c) Shri K.K. Barik. He also maintains record of ill-gotten and is courier of money. Even pen drive was recovered from him out of which he has deleted the record.

(d) Shri Jeet Ram Yadav, another kingpin. Even a sum of Rs.36,06,000/- was recovered from him by ACB.

(e) Shri Sandeep Aggarwal, Company Secretary of NAN. A sum of Rs.34,99,500/- was recovered from him.

H. BECAUSE the ACB has not only done a shoddy investigation, but rather no investigation has been conducted into the roles played by the CM despite the fact that his name has consistently featured in all the diaries that were recovered.

I. BECAUSE the ACB is protecting the main culprits in the scam rather than prosecuting them.

J. BECAUSE the ACB has time and again shown that it is not interested in carrying out a fair and impartial investigation into the scam since it leads right up to the feet of the Chief Minister itself.

K. BECAUSE the CBI is an independent investigating agency capable of investigating scams of this magnitude involving high dignitaries and officials of the state. Being an independent investigating agency, it is viewed by the citizens of this country as holding a position of trust and therefore capable of discharging the functions entrusted to them in an impartial and fair manner.

L. BECAUSE of the involvement of high dignitaries and officials of the state, the ACB is unable to conduct any investigation which might implicate the said dignitaries and officials and hence, an all out effort is being made to cover up the links leading to those dignitaries and officials. Therefore, an agency like the CBI ought to be brought in to investigate the scam before the evidence in this regard completely vanishes.

M. BECAUSE the present investigating agency viz. ACB, reports to the Home Ministry of the State, thereby indirectly reporting to the Chief Minister, who according to the petitioner is the main beneficiary of the present scam.

P R A Y E R

In the aforesaid facts and circumstances it is most respectfully prayed that this Honble Court may be pleased to:

a) Issue an appropriate writ, order, or direction, in the form of mandamus or any other appropriate writ directing Respondent No. 3 to produce the record of the entire investigation carried out in FIR No. 09 of 2015 before this Honble Court;

b) Issue or pass any writ, direction or order in the nature of mandamus or any other writ to further investigate FIR No. 09/2015 registered by the State Economic Crime Investigation Bureau at Raipur and any other PDS scam cases for fair and impartial investigation by CBI or any other central agency;

c) Issue or pass any writ, direction or order in the nature of mandamus or any other writ to set up a Special Investigation Team (SIT) to monitor the investigation;d) Itself monitor the entire investigation conducted by the CBI or any other central agency;e) Issue or pass any writ, direction or order that this Honble Court may deem fit and proper under the facts and circumstances of the case.

AND FOR THIS ACT OF KINDNESS THE PETITIONER AS IN DUTY BOUND SHALL EVER PRAY

DRAWN BY:

FILED BY

VSA LEGAL Advocates

(T. MAHIPAl)Advocate for the petitioner

Drawn on: 13.07.2015

Filed on: 15.07.2015