How to file petition of compensation

[Patel Ranchhodbhai B]

Please guide, How to file petition for compensation after clean Acquittal from false ACB criminal prosecution. “Sanction” given by authority for prosecution was with totally false facts and it is proved by evidences of departmental own.
My Facts are as under:…..
To
The Managing Director / The Chief Engineer,
PGVCL, Corporate Office,
Rajkot-4
Date: 20/12/2016
(Through my Bhavnagar Rural Division)
Sub: My submission with reference to misleading/Half truth facts submitted by
your HR officers in my service matter case ………
Facts on Pre-history of Complainant of ACB case:
(* Below facts was also submitted to GEB, Baroda office in 1987 & 1988, 3 times, by
regd. AD post, but ignored.)
(* Below facts was also submitted to Una Division office, on 22/12/1991 as my reply
to your Show Cases Notice, but ignored.)
(* Below facts are already recorded by Hon’ble Appeal High Court in my Clean Acquittal judgment dated 12/12/2006 in Criminal Appeal No:712/1991 & 711/1991.)
(* Below facts are also submitted in my SCA/4098/2008 in Para:4, Page:68/69 of
Affidavit in Rejoinder.)
(* Without looking the actual facts of case matter, on misleading facts by some one,
“Sanction” order dated 18/10/1988 was issued by GEB for court prosecution.)

1…… A complainant; Mr.Manilal Patel was owner of Shri Ram Industry, Mehsana, having 15 HP Power supply from GEB and doing business of fabrication of Gril-Jali for Doors & Windows of Houses from M.S. angle & patti. (Mr.Manilal Patel is habitual criminal man; details of this character are already submitted to you by me on 22/12/1991 in my reply to Show cause notice which is also laying at Page No: 33 as Annexure: “C” in my Petition No: 4098/2008).

1(a)…. Mr.B.I.Patel (Accused No:1), was working as Dy.Supdt. of Accounts in GEB city office, Mehsana and Mr.R.I.Patel(Accused No:3 as Private Person), both are actually real brothers, had placed order with above complainant for Gril-Jali work for windows for their common house (was under repairing at his village) with advance deposit amount paid to complainant. Due to dispute in materials, that order was not fulfilled and deposit amount was also not refunded by complainant. Frequently demanded refund by both the brothers during the year period.

1(b)….. During that said one year, 4 times, Power Supply connection of complainant was disconnected on ground of non-payment of Electric Bill in time. Power Supply Dis-Connection order was issued by Account section of GEB city office and signed by Mr.B.I.Patel as Head of Account section of GEB city office and reconnected after payment of Bill as well as Penalty charge with extra deposit paid.

1(c)…. Mr.R.B.Patel(Accused No:2), Jr.Engineer of GEB City office, Mehsana had
-2-
no any relation with that personal Gril-Jali work order and also no any duty relation for Power Supply Dis-connection order was issued. Issue of Dis-connections order was not duty of Technical Section of GEB City office, but it was duty of only of Account Section.

1(d)….. Meanwhile, a Government Electrical Sub-Inspector (ESI), Mr. Gurjar, had visited premise of that complainant for Electric duty verification on 15 HP Power Supply and noted some irregularity/malpractice in connected power load (using more power load instead of contracted load of 15HP). Government Electrical Sub-Inspector (ESI) had reported that matter to higher office of GEB. After moving to office to office, lastly, that said report came to Mr.J.B.Patel, Deputy Engineer as higher officer of City office, Mehsana and had handed over that report for detail verification work to Mr.R.B.Patel (Accused No:2), Jr.Engineer of GEB City office, Mehsana.
Accordingly, Mr.R.B.Patel (Accused No:2), had visited site on 17/11/1987 at about 12 Hrs and prepared detail checking sheet. During checking, it was found that said complainant consumer had given Power supply to another person by providing extra loose cable wires for running another Diamond Industry also. Mr.R.B.Patel (Accused No:2), Jr.Engineer had prepared Panch-Nama with list of all connected Electric Motors, Heaters, equipments with name of makes and power load of each machines and found total connected Power load of 23 HP instead of 15 HP contact agreement with GEB. That said checking sheet was submitted on 19/11/1987 in morning at 9.00 Hrs to Mr.J.B.Patel, Higher officer of City Office, Mehsana, before complaint was filed in ACB.

After submission of that said checking sheet to Higher Officer, there was no any duty remains pending from Mr.R.B.Patel (Accused No:2), as Jr.Enginer of that city office. Penalty Bill would be issued or not issued on said checking sheet was not duty of Mr.R.B.Patel (Accused No:2), as Jr.Enginer of that city office, it was duty of the Higher Officer connected with Account Section (Mr.B.I.Patel, Accused No:1) subject to approval from Division office. Later on, after approved from Division office, penalty Bill was issued to complainant consumer and Paid also by complainant without any objection.

1(e) ….. Due to continuous above events with that complainant have developed inimical feeling towards the staff of the GEB and keeping bias mind that “all staff are intentionally harassing him” and by advice of some one, by fabricating wrong story and using a tool of actual refund of deposit, complainant had planned to trap GEB staff in ACB case. Both separate incidents as shown above, (1) fabrication Gril-Jali order with deposit amount & refund to Mr.B.I.Patel and (2) official lawfully checking of site on 17/11/1987 by Mr.R.B.Patel, both incidents are correct on different dates.But, both incident stories were merged by sophisticated way- by adding some false facts in F.I.R. story (by Mr. Giri, Police Head Constable-writer at instance of Mr.Rana, PSI, ACB Police, Mehsana). Accordingly said plan, complainant had informed to Mr.B.I.Patel (Accused No:1) on 18/11/1987 to came to his Grocery Shop between 12 to 15 Hrs, mid-day on 19/11/1987 to get refund of his pervious disputed deposit amount. According to said plan, ACB trap was arranged and deposit amount (trap money) was accepted by Mr.R.I.Patel (Accused No:3 as Private Person) in presence of Mr.B.I.Patel (Accused No:1), both real brothers were present in trap at site. Defense fact of said disputed deposit amount & refund is accepted in trail court by Prosecution witness (PW-6) Mr. Rambhai Patel who is son of complainant and him self was running the said Shri Ram Industry for fabrication of Gril-Jali job work.

1(f)….. Mr.R.B.Patel(Accused No:2), Jr.Engineer of GEB City office, Mehsana was totally not involved in any one of above all events except only official checking sheet prepared on 17/11/1987. No any evidence or no any witness was produced by prosecution in trial court to establish demand of bribe or involvement in corrupt practice. So far as Mr.R.B.Patel(Accused No:2), Jr.Engineer of GEB City office concerned, has neither any connection with any fabrication of Gril-Jali work nor has any connection with respect to the refund of amount and a false case is registered by wrongly arranging Mr.R.B.Patel as Accused No:2.

1(g) …. The entire story of the prosecution case against Mr.R.B.Patel (Accused No:2) is found false. The facts mentioned in FIR are proved as wrong by documentary evidences. Also facts mentioned in Charge Frame para-1 and para-2 are proved as wrong and Hon’ble High Court has recorded in Para:5 of Clean Acquittal Judgment that facts mentioned in Charge Frame are misleading which are creating bad impression of Accused Persons. Actually facts are quite different in prosecution papers then Charge Framed. Means Charge Frame it self was misleading with wrong facts.

1(h) ….. In criminal Appeal No:712/1991, Hon’ble High Court, after examining every circumstances, with deep study of all relevant papers, has given Clean Acquittal Judgment on12/12/2006 to Mr.R.B.Patel(Accused No:2), Jr.Engineer of GEB City office, Mehsana.

During investigation, I have submitted all relevant GEB’s documents (as Exhibited No 54 to 60 in prosecution Court file) to Mr.Rana, PSI of ACB Police, Mehsana (unauthorized investigating officer), but all ignored by Mr.Rana.

And also, real true facts with these documents were also given (3 times in 1987 & 1988) to GEB authority before “sanction” was granted, but all ignored blindly. Without application of mind, “Sanction” was granted by GEB authority.

And in trial court, Mehsana also initially, this real facts was submitted by my application Exhibited No: 33, but trial court has also ignored totally. In Para: 20 of Clean Acquittal Judgment dated 12/12/2006 in Criminal Appeal No: 712 of 1991, Hon’ble High Court strongly criticized the conduct of unauthorized investigating officer, Mr.Rana, PSI of ACB Police, Mehsana and also strongly criticized the conduct of District Judge of trial court, Mehsana for not deciding at all the application Exhibit: 33 of R.B.Patel and also observed that the application of Exhibit No:33, if it could have been heard properly initially, entire prosecution could had been discharged at that time and hence, Hon’ble High Court has decided that “Judgment and Conviction order (dated 09/09/1991) was bad”.

1(i)… Without looking the actual facts of case matter & Papers, even my request applications (3 times) was given in the year 1987 & 1988 to GEB, Baroda and on base of misleading facts of your GEB HR Department, “Sanction” order dated 18/10/1988 with untrue facts was issued by Mr. O.M. Shah, Chief Engineer, GEB, Baroda for my ACB prosecution to Court, Mehsana and ultimately resulted in to Clean Acquittal on 12/12/2006. Means it is proved that “Sanction” order was bad & base-less for Mr.R.B.Patel. Means, all my request applications were given in 1987 & 1988 to GEB became proved as correct. Who is responsible for this wrong act in GEB? Who is responsible for this “Economic death & Maansik/Social murder” of whole my family up to 28 years as I dismissed from Service on this ground?

1(j)…In my Petition No: SCA/4098/2008 (for back wages/benefits of absent period), judgment decided on 03/08/2016 by Hon’ble Gujarat High Court has also accepted all above facts and allowed my petition with all pray outright and in toto in my favour. It is proved that a false case was registered by wrongly arraigning Mr.R.B.Patel as Accused No:2 without any evidence and without any witness.

The above facts are already recorded in Clean Acquittal Judgment dated 12/12/2006 of Hon’ble Gujarat High Court and also all above related documents are lying in office File of PGVCL Bhavnagar/Rajkot (Intentionally ignored by your officers).

Please grant me Rs.100.00 crore as compensation for harassment to me and my family for such too long period by mis-act of GEB (now PGVCL). Please look in to matter and take necessary action accordingly.

(R.B.Patel)
Retired Deputy Engineer,
Rural Division, PGVCL(GEB), Bhavnagar.
Mob: 09979878165 / 166.
Adress: 37, Maheshwari Society, Opp: College,
High Way Road, Mehsana -384002.

[Patel Ranchhodbhai B]

In which act/rule or article, I can file petition for compensation after clean Acquittal from false ACB criminal prosecution. “Sanction” given by authority for prosecution was with totally false facts and it is proved as false by evidences of departmental own.
My case facts are as under,

To
The Managing Director / The Chief Engineer,
PGVCL, Corporate Office,
Rajkot-4
Date: 20/12/2016
(Through my Bhavnagar Rural Division)
Sub: My submission with reference to misleading/Half truth facts submitted by your HR officers in my service matter case ………

Facts on Pre-history of Complainant of ACB case:
(* Below facts was also submitted to GEB, Baroda office in 1987 & 1988, 3 times, by regd. AD post, but ignored.)
(* Below facts was also submitted to Una Division office, on 22/12/1991 as my reply to your Show Cases Notice, but ignored.)
(* Below facts are already recorded by Hon’ble Appeal High Court in my Clean Acquittal judgment dated 12/12/2006 in Criminal Appeal No:712/1991 & 711/1991.)
(* Below facts are also submitted in my SCA/4098/2008 in Para:4, Page:68/69 of
Affidavit in Rejoinder.)
(* Without looking the actual facts of case matter, on misleading facts by some one, “Sanction” order dated 18/10/1988 was issued by GEB for court prosecution.)

1…… A complainant; Mr.Manilal Patel was owner of Shri Ram Industry, Mehsana, having 15 HP Power supply from GEB and doing business of fabrication of Gril-Jali for Doors & Windows of Houses from M.S. angle & patti. (Mr.Manilal Patel is habitual criminal man; details of this character are already submitted to you by me on 22/12/1991 in my reply to Show cause notice which is also laying at Page No: 33 as Annexure: “C” in my Petition No: 4098/2008).
1(a)…. Mr.B.I.Patel (Accused No:1), was working as Dy.Supdt. of Accounts in GEB city office, Mehsana and Mr.R.I.Patel(Accused No:3 as Private Person), both are actually real brothers, had placed order with above complainant for Gril-Jali work for windows for their common house (was under repairing at his village) with advance deposit amount paid to complainant. Due to dispute in materials, that order was not fulfilled and deposit amount was also not refunded by complainant. Frequently demanded refund by both the brothers during the year period.

1(b)….. During that said one year, 4 times, Power Supply connection of complainant was disconnected on ground of non-payment of Electric Bill in time. Power Supply Dis-Connection order was issued by Account section of GEB city office and signed by Mr.B.I.Patel as Head of Account section of GEB city office and reconnected after payment of Bill as well as Penalty charge with extra deposit paid.

1(c)…. Mr.R.B.Patel(Accused No:2), Jr.Engineer of GEB City office, Mehsana had
no any relation with that personal Gril-Jali work order and also no any duty relation for Power Supply Dis-connection order was issued. Issue of Dis-connections order was not duty of Technical Section of GEB City office, but it was duty of only of Account Section.

1(d)….. Meanwhile, a Government Electrical Sub-Inspector (ESI), Mr. Gurjar, had visited premise of that complainant for Electric duty verification on 15 HP Power Supply and noted some irregularity/malpractice in connected power load (using more power load instead of contracted load of 15HP). Government Electrical Sub-Inspector (ESI) had reported that matter to higher office of GEB. After moving to office to office, lastly, that said report came to Mr.J.B.Patel, Deputy Engineer as higher officer of City office, Mehsana and had handed over that report for detail verification work to Mr.R.B.Patel (Accused No:2), Jr.Engineer of GEB City office, Mehsana.

Accordingly, Mr.R.B.Patel (Accused No:2), had visited site on 17/11/1987 at about 12 Hrs and prepared detail checking sheet. During checking, it was found that said complainant consumer had given Power supply to another person by providing extra loose cable wires for running another Diamond Industry also. Mr.R.B.Patel (Accused No:2), Jr.Engineer had prepared Panch-Nama with list of all connected Electric Motors, Heaters, equipments with name of makes and power load of each machines and found total connected Power load of 23 HP instead of 15 HP contact agreement with GEB. That said checking sheet was submitted on 19/11/1987 in morning at 9.00 Hrs to Mr.J.B.Patel, Higher officer of City Office, Mehsana, before complaint was filed in ACB.

After submission of that said checking sheet to Higher Officer, there was no any duty remains pending from Mr.R.B.Patel (Accused No:2), as Jr.Enginer of that city office. Penalty Bill would be issued or not issued on said checking sheet was not duty of Mr.R.B.Patel (Accused No:2), as Jr.Enginer of that city office, it was duty of the Higher Officer connected with Account Section (Mr.B.I.Patel, Accused No:1) subject to approval from Division office. Later on, after approved from Division office, penalty Bill was issued to complainant consumer and Paid also by complainant without any objection.

1(e) ….. Due to continuous above events with that complainant have developed inimical feeling towards the staff of the GEB and keeping bias mind that “all staff are intentionally harassing him” and by advice of some one, by fabricating wrong story and using a tool of actual refund of deposit, complainant had planned to trap GEB staff in ACB case. Both separate incidents as shown above, (1) fabrication Gril-Jali order with deposit amount & refund to Mr.B.I.Patel and (2) official lawfully checking of site on 17/11/1987 by Mr.R.B.Patel, both incidents are correct on different dates.But, both incident stories were merged by sophisticated way- by adding some false facts in F.I.R. story (by Mr. Giri, Police Head Constable-writer at instance of Mr.Rana, PSI, ACB Police, Mehsana). Accordingly said plan, complainant had informed to Mr.B.I.Patel (Accused No:1) on 18/11/1987 to came to his Grocery Shop between 12 to 15 Hrs, mid-day on 19/11/1987 to get refund of his pervious disputed deposit amount. According to said plan, ACB trap was arranged and deposit amount (trap money) was accepted by Mr.R.I.Patel (Accused No:3 as Private Person) in presence of Mr.B.I.Patel (Accused No:1), both real brothers were present in trap at site. Defense fact of said disputed deposit amount & refund is accepted in trail court by Prosecution witness (PW-6) Mr. Rambhai Patel who is son of complainant and him self was running the said Shri Ram Industry for fabrication of Gril-Jali job work.

1(f)….. Mr.R.B.Patel(Accused No:2), Jr.Engineer of GEB City office, Mehsana was totally not involved in any one of above all events except only official checking sheet prepared on 17/11/1987. No any evidence or no any witness was produced by prosecution in trial court to establish demand of bribe or involvement in corrupt practice. So far as Mr.R.B.Patel(Accused No:2), Jr.Engineer of GEB City office concerned, has neither any connection with any fabrication of Gril-Jali work nor has any connection with respect to the refund of amount and a false case is registered by wrongly arranging Mr.R.B.Patel as Accused No:2.

1(g) …. The entire story of the prosecution case against Mr.R.B.Patel (Accused No:2) is found false. The facts mentioned in FIR are proved as wrong by documentary evidences. Also facts mentioned in Charge Frame para-1 and para-2 are proved as wrong and Hon’ble High Court has recorded in Para:5 of Clean Acquittal Judgment that facts mentioned in Charge Frame are misleading which are creating bad impression of Accused Persons. Actually facts are quite different in prosecution papers then Charge Framed. Means Charge Frame it self was misleading with wrong facts.

1(h) ….. In criminal Appeal No:712/1991, Hon’ble High Court, after examining every circumstances, with deep study of all relevant papers, has given Clean Acquittal Judgment on12/12/2006 to Mr.R.B.Patel(Accused No:2), Jr.Engineer of GEB City office, Mehsana.

During investigation, I have submitted all relevant GEB’s documents (as Exhibited No 54 to 60 in prosecution Court file) to Mr.Rana, PSI of ACB Police, Mehsana (unauthorized investigating officer), but all ignored by Mr.Rana.

And also, real true facts with these documents were also given (3 times in 1987 & 1988) to GEB authority before “sanction” was granted, but all ignored blindly. Without application of mind, “Sanction” was granted by GEB authority.

And in trial court, Mehsana also initially, this real facts was submitted by my application Exhibited No: 33, but trial court has also ignored totally.

In Para: 20 of Clean Acquittal Judgment dated 12/12/2006 in Criminal Appeal No: 712 of 1991, Hon’ble High Court strongly criticized the conduct of unauthorized investigating officer, Mr.Rana, PSI of ACB Police, Mehsana and also strongly criticized the conduct of District Judge of trial court, Mehsana for not deciding at all the application Exhibit: 33 of R.B.Patel and also observed that the application of Exhibit No:33, if it could have been heard properly initially, entire prosecution could had been discharged at that time and hence, Hon’ble High Court has decided that “Judgment and Conviction order (dated 09/09/1991) was bad”.

1(i)… Without looking the actual facts of case matter & Papers, even my request applications (3 times) was given in the year 1987 & 1988 to GEB, Baroda and on base of misleading facts of your GEB HR Department, “Sanction” order dated 18/10/1988 with untrue facts was issued by Mr. O.M. Shah, Chief Engineer, GEB, Baroda for my ACB prosecution to Court, Mehsana and ultimately resulted in to Clean Acquittal on 12/12/2006. Means it is proved that “Sanction” order was bad & base-less for Mr.R.B.Patel. Means, all my request applications were given in 1987 & 1988 to GEB became proved as correct. Who is responsible for this wrong act in GEB? Who is responsible for this “Economic death & Maansik/Social murder” of whole my family up to 28 years as I dismissed from Service on this ground?

1(j)…In my Petition No: SCA/4098/2008 (for back wages/benefits of absent period), judgment decided on 03/08/2016 by Hon’ble Gujarat High Court has also accepted all above facts and allowed my petition with all pray outright and in toto in my favour. It is proved that a false case was registered by wrongly arraigning Mr.R.B.Patel as Accused No:2 without any evidence and without any witness.

The above facts are already recorded in Clean Acquittal Judgment dated 12/12/2006 of Hon’ble Gujarat High Court and also all above related documents are lying in office File of PGVCL Bhavnagar/Rajkot (Intentionally ignored by your officers).

Please grant me Rs.100.00 crore as compensation for harassment to me and my family for such too long period by mis-act of GEB (now PGVCL). Please look in to matter and take necessary action accordingly.

(R.B.Patel)
Retired Deputy Engineer,
Rural Division, PGVCL(GEB), Bhavnagar.
Mob: 09979878165 / 166.
Adress: 37, Maheshwari Society, Opp: College,
High Way Road, Mehsana -384002.

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