Writ Petition No of 2011-Waqf Estate and Mutualli

Dayemi Complex Bangladesh

(An International Organization for Religious, Social, Educational, Humanitarian & Voluntary Services in Bangladesh in Consultative status with the Economic and Social Council (ECOSOC) of the U.N., United Nations International Childrens Emergency Fund (UNICEF) and U.N. PEACE MESSENGER Organization designated by the U.N. Secretary General in 1986) Federal Tax I.D. # 13-3639905, and Exempt Organizations Certificate No. EX218067, Registered as Non-profit Organization # 6045 with the State of New York, United States of America)

Mailing Address: PO Box# 605, New York, NY-10163 USA, Website: www.dayemicomplexbangladesh.org

E-mail: AlamUnitedNations@yahoo.com, Phone: 212-545-4124, Fax: 212-591-6257

PRESS RLEASE Dated April 30th, 2010
United Nations New York

Rokeya Begum Died by Fire With Disgrace of MN Alam

PRESS RLEASE Dated May 1, 2010
United Nations New York

Dayemi Complex Bangladesh

(An International Organization for Religious, Social, Educational, Humanitarian & Voluntary Services in Bangladesh in Consultative status with the Economic and Social Council (ECOSOC) of the U.N., United Nations International Childrens Emergency Fund (UNICEF) and U.N. PEACE MESSENGER Organization designated by the U.N. Secretary General in 1986) Federal Tax I.D. # 13-3639905, and Exempt Organizations Certificate No. EX218067, Registered as Non-profit Organization # 6045 with the State of New York, United States of America)

Mailing Address: PO Box# 605, New York, NY-10163 USA, Website: www.dayemicomplexbangladesh.org

E-mail: AlamUnitedNations@yahoo.com, Phone: 212-545-4124, Fax: 212-591-6257

Cunning cheater a fanatic Jewish converted Muslim migrated from Germany To USA, proclaims himself, Sheikh Din Muhammad Abdullah So-Called al-Dayem has been working as a slow poison to destroy the Spiritual Sufi practice from All the projects of Dayemi Complex Bangladesh. This so-called Shaikh who claims to give basic Sufi teachings thru many websites which is based in Illinois. His former identity known as Din Greenburgh, he was converted Muslim with His Eminency in 1989 at the United Nations, New York with his girl friend Eleen. They had promised to work with Eminency but their main intention was to capture all Dayemi Complex Bangladesh’s projects, Which was build and established by His Eminency Dr. Hazrat Shah Sufi M N Alam since 1977 in the time of Sufi Dayemullah (RA). His ill-motive was already spotted by Eminency in the time of Sufi Dayemullah (RA) in 1993 also thrown out later he left Bangladesh. After Sufi Dayemullah’s (RA) eternal rest this so-called Shaikh Deen Mohammad Abdullah had went back to Bangladesh and met up with Eminency’s rival group of so-called Sayeda Saleha Khatun, Faize-Mohmmadi Ahmadullah and Rokeya Begum to capture the Sufi Nurullah Waqf properties along with many Dayemi complex’s projects. This person had been illegally using the Dayemi Complex Bangladesh’s projects as well as Dayemi Complex’s fame and name to ask for donations, which he eventually using for his own personal gain along with his associates.

A point should be noted, Deen Greenburgh worked with Eminency’s abandoned Son Ata-E-Nur Anwarullah in Illinois and made a long term conspiracy to capture all the orphanage projects in Bangladesh. Currently, this so called Shaikh Deen Mohammad Abdullah (Greenburgh) had started a camouflaging game in the name of asking for donations for His Eminency Dr. M N Alam’s established projects in Nabinagar B-Baria, Amairabad Chittagong, Satbaria Chittagong, Jagannatpur of B-Baria as well as many other educational institutes.

His Eminency Dr. Hazrat Shah Sufi M N Alam had started several cases at the court of New York, which he never took any reply action instead moved to Illinois and created several websites, which are listed below:

http://www.surrenderworks.com/community/salamaleikum/index.html

http://forkidssake.net

The Bangladesh map is being used illegally by Deen Greenburgh and his associates to raise funds for orphan children for their own personal gain. They have started a so-called Sufi Order named Dayemi Tariqat in Illinois as well as in Germany and Japan and misusing Dayemi Complex Bangladesh Projects along with 700 Years old Sufi Dynasty’s fame and name. His Eminency confirms that this individual is not a Jew nor a Converted Muslim Or Hindu but a GRAT Cunning Hypocrite cheating the innocent peoples of Bangladesh specially Syeda Rokeya Begum, which is why she had a horrible death by fire (Punished by Almighty Allah for her Husband His Eminency’s order Ignorance to cooperate with above cunning individual Deen Greenburgh). (Picture of Map given Below)

A Important Point should be noted this cunning individual has been using the following picture with Sufi Dayemullah (RA) in 1993 along with Justice Ruhul Islam of Bangladesh Supreme Court and misguided several family members of Sufi Dayemullah (RA) and convinced them he was good moral person but he was filled with ill motives and utilizing illegally Dayemi Complex Bangladesh’s projects along with 700 years old Sufi Dynasty’s Sufi Order and misrepresenting the Muslim Sufism around world. His prominent associates in this matter is Socalled religious leader Salah Uddin Ahmed Chisty of Rampura Dhaka, Bangladesh along with his close associate and terror suspect Mozammel Hoque (John) of Michigan, Nurul Islam of Adabor, Bangladesh.

Picutre Given Below So-called Deen Mohammad Abdullah on the Left in White with his associates and Govt. Pronounced Terror Suspect Annanda Dada of India on the Right in Orange in 1993 With Sufi Dayemullah (RA) and Justice Ruhul Islam (2nd Picutre)

In 1993, When Deen Greenburgh started his ill minded camouflaging game, he was also an associate with Annando Mark, who member is also a international terrorist from India possible member with Al-Qaida. The pictures of Deen Greenburgh along with Annando Mark are given below. His Eminency Dr. Alam urging to the Government of United States of America, Government of Bangladesh as well as Govt. India to curb down the immoral and terror activities of Deen Greenburgh and his associate Annando Mark here in USA, as well as in Bangladesh and India. Currently this notorious individual Deengreen Burgh living in Carbondale, Illinois, USA and in Ibrahimpur Sufi Azmatullah (RA) orphanage in Ibrahipur, Nabinar PS B-Baria, Bangladesh. Deen Greenburgh’s associate Shema Jamaluddin and Rahima-Regina Flocco are using the following address to illegally misrepresenting Dayemi Complex Bangladesh asking for funds for projects of Dayemi Complex Bangladesh but looting money in the name of asking for donations from USA, Germany, Japan and many other countries around the world.

(Picture Given Below of So-called Shaikh Din Mohammad Abdullah Al-Dayemi, He had been using the following address: 100 E. Jackson St., Suite C Carbondale, IL 62901.)

His Eminency Dr. Hazrat Shah Sufi M N Alam had already designated a International attorney of Law to curb down his all immoral illegal activities along with child trafficking and immediately bring to him to Court of Justice here in USA as well as in Bangladesh. If the Govt. of USA checks this individual’s background with Social Security since 1989 his source of Income you can determine that he was an illiterate and homeless person staying with his girlfriend Ms. Eleen 14^th St Union Square Manhattan, NY.

“Dada Annand” associate of Terror group “Annando Mark of India” in Bangladesh. This individual is pronounced Terror Suspect by Govt of India and Bangladesh. (Picture Given Below)

-:End of Press Release:-

Fanatic Jewish converted Muslim Deen Greenburgh using the above map and misusing the Dayemi Projects

Deen Greenburgh on left in white misusing this picture with Sufi Dayemullah to misguide innocents

"Dada Annand" pronounced terror suspect of India associate of Deen Greenburgh

PRESS RELEASE

WORLD HUMAN RIGHTS SERVICE COUNCIL (WHRSC)

An international Organization Working Worldwide for the Service of Humanity

Mailing Address: P.O. Box 605, New York, NY, 10163 USA,

President- Dr. Michael Wyman, Chief of the Mission – His Eminency Dr. Hazrat S.S. M N Alam

E-Mail: WHRSC7862002@yahoo.com Tel# 212-545-4124

Revised DATED: April 18^th, NEW YORK

Bureau of Democracy, Human Rights, and Labor

2009 Country Reports on Human Rights Practices

March 11, 2010

His Eminency Dr. Hazrat Shah Sufi Mohammad Nurul Alam victimized by the Bangladeshi Corrupt police officials along with Corrupt Judge Sk. M. Tofayel Hassan of CMM court Dhaka
on 11-11-09

According to the US Department of State’s Report on Bangladesh, which states, The violation of Human rights by the Corrupt Police Department’s corrupt officers like Nobo Bikrom Tripura additional IGP, Mokbul Hossain Bhuiyan Additional DIG of Chittagong range, Golam Rahman OC of Lalbagh DMP Dhaka, SI Sajjad Hossain of Lal Bagh, SI Safiqul Islam, SI Kala Chand Ghosh of Lalbagh PS, Inspector Fozlul Hoque and SI Abdul Hakim of DC DB also Kazi Habib SI of CID along with corrupt judicial official off CMM court Dhaka Senior Assistant Judge Sheikh Mohmmad Tofayel Hassan. Their corruption and immoral activities are the violation of Universal Declaration of Human Rights along Bangladesh High Court’s Justice Abdul Ohab Miah & Justice Tariqul Hakim’s orders. His Eminency Dr. Hazrat Shah Sufi Nurul Alam has been victimized by Bangladesh police and CMM judge. He submitted several allegations against them to the government of Bangladesh Ministry of Home and Ministry of Law & justice.

Below is the summary of US Department of State’s published Bangladesh Report

Bangladesh is a parliamentary democracy of 155 million citizens. On December 29, 2008, the Awami League (AL) alliance led by Sheikh Hasina Wazed won 263 of 299 parliamentary seats in elections international and domestic observers considered to be free and fair, with isolated irregularities and sporadic violence. The elections and the peaceful transfer of power ended two years of rule by a military-backed caretaker government. Civilian authorities generally maintained effective control of the security forces.

The government's human rights record improved somewhat due to the return of a democratically elected government and the repeal of the state of emergency. There was a slight increase in the number of extrajudicial killings by security forces; there remained cases of serious abuse, including extrajudicial killings, custodial deaths, arbitrary arrest and detention, and harassment of journalists. With the return of an elected government, reports of politically motivated violence increased 3.3 percent. The failure to investigate fully extrajudicial killings by security forces, including the deaths in custody of alleged mutineers from the Bangladesh Rifles (BDR) border force, remained a matter of serious concern. Some members of security forces acted with impunity and committed acts of physical and psychological torture. Violence against women and children remained a serious problem, as did trafficking in persons. Violence against religious and ethnic minorities still occurred, although many government and civil society leaders stated that these acts often had political or economic motivations and could not be attributed only to religious belief or affiliation.

On February 25-26, members of the BDR staged a mutiny, alleging poor pay and benefits, as well as corruption in the senior officer corps, which were drawn from the army. During the two-day mutiny, BDR soldiers killed 57 officers and 15 of their family members, including the director general and his wife. Security forces subsequently arrested more than 2,000 individuals allegedly involved in the uprising. The government announced plans to try them under the existing BDR Act, which carries a maximum prison term of seven years. Those charged with criminal acts were to be tried under the penal code in special tribunals. According to nongovernmental organizations (NGOs) and media reports, 59 BDR soldiers died while in police custody or in the BDR barracks. There were credible reports that many of the deceased had been tortured. To investigate these allegations, the government formed a committee, which concluded that only two members died as a result of torture. No other government action was taken.

RESPECT FOR HUMAN RIGHTS

Section 1 Respect for the Integrity of the Person, Including Freedom From:

a. Arbitrary or Unlawful Deprivation of Life

Members of the security forces committed numerous extrajudicial killings. The police, BDR, military, and the Rapid Action Battalion (RAB) occasionally used unwarranted lethal force.

According to government statistics, there was a 3 percent increase in the number of killings by all security personnel, and the government did not take comprehensive measures to investigate these cases despite public statements by high-ranking officials that the government would show "zero tolerance" and would fully investigate all extrajudicial killings by security forces. The number of killings by the police and combined security forces also increased. According to the media and local human rights organizations, no case resulted in criminal punishment, and in the few instances in which the government levied charges, those found guilty generally received administrative punishment.

According to media reports, local and international human rights organizations, and the government, the RAB killed 41 persons during the year, from 68 the year before, a nearly 40 percent drop. The average number of such deaths dropped from six per month in 2008 to three per month during the year. Combined security units consisting of RAB members and police, however, killed 25 persons during the year. The deaths, some under unusual circumstances, occurred during raids, arrests, and other law enforcement operations, or in some cases while the accused were in custody. The government often described these deaths as "crossfire killings," "gunfights," or "encounter killings," terms it used to characterize exchanges of gunfire between the RAB or police and criminal gangs.

According to media reports, local and international human rights organizations, and the government, law enforcement officials were responsible for 154 deaths, 129 of which were attributed to crossfire. According to reported figures, this total represented a 3 percent increase from the previous year. The RAB accounted for 38 crossfire killings; members of the police were responsible for 63; combined security units consisting of the RAB and police were responsible for 25; and the army committed three crossfire killings. Since 2004 when the minister for law, justice, and parliamentary affairs stated crossfire deaths under RAB or police custody could not be considered custodial death, the government has not disclosed publicly any prosecution of a RAB officer for a killing.

According to official government statistics, the police arrested 50,787 persons during the year. Of those arrested, 15,894 were detained without arrest warrants or convictions.

On March 21, police arrested former deputy speaker of parliament and opposition member Akhtar Hamid Siddiqui in the Naogaon district. The officer in charge of the Mohadebpur Police Station alleged Siddiqui had threatened him. Siddiqui was sentenced to one month's detention order under the Special Powers Act of 1974.

Role of the Police and Security Apparatus

Police are organized nationally under the Ministry of Home Affairs (MOHA) and have a mandate to maintain internal security and law and order. Under recent governments, police were generally ineffective and reluctant to investigate persons affiliated with the ruling party. The government ended its use of the joint forces security structure formed in 2007 under the state of emergency and composed of police, the RAB, members of the military, and other security agencies. Unlike the previous year, the military intelligence agency, the Directorate General Forces Intelligence (DGFI), did not take the lead in maintaining law and order as it had under the state of emergency.

The RAB received human rights training sponsored by foreign governments, the UN Development Program, and a local NGO, the Bangladesh Society for Enforcement of Human Rights (BSEHR). Although the RAB continued to commit serious human rights violations, the number of incidents involving the RAB dropped from the previous year.

The government took steps to address widespread police corruption and a severe lack of training and discipline. The inspector general of police continued to implement a new strategy, partially funded by international donors, for training police, addressing corruption, and creating a more responsive police force.

Plaintiffs rarely accused police in criminal cases due to lengthy trial procedures and the fear of retribution. Reluctance to confront police perpetuated a climate of impunity.

Arrest Procedures and Treatment While in Detention

The law provides for arrest without the use of warrants in certain cases. Section 54 of the Criminal Procedure Code and Section 100 of the Dhaka Metropolitan Police Ordinance authorize detention of persons on suspicion of criminal activity without an order from a magistrate or a warrant, and the government regularly used such provisions. The number of preventive and arbitrary arrests declined from the previous year when the state of emergency was in effect.

Unlike in previous years under the caretaker government, the new government did not carry out mass arrests. ASK, a domestic human rights organization, and media outlets estimated that authorities made more than 2,000 routine arrests daily. The majority of those arrested were released within one or two days, often on payment of a bribe.

Under the existing Special Powers Act, the government or a district magistrate may order a person detained for 30 days to prevent the commission of an act that could threaten national security; however, authorities held detainees for longer periods. The magistrate must inform the detainee of the grounds of detention, and an advisory board is required to examine the detainee's case after four months. Detainees had the right to appeal. Many detainees taken into custody during the caretaker government's anticorruption drive were held under this act, and the government sought and received numerous detention extensions from advisory boards consisting of two judges and a government official. Use of the provisions of the Special Powers Act declined during the year.

There was a functioning bail system in the regular courts. For example, the courts granted bail to many of the officials and former officials accused of corruption.

Most criminal detainees charged with crimes were granted access to attorneys. The government rarely provided detainees with state-funded defense attorneys, and there were few legal aid programs for detainees. Government-funded legal aid programs received little funding, and there were no efforts to expand those programs during the year.

The government generally permitted lawyers to meet with their clients only after formal charges had been filed in the courts, which in some cases occurred several weeks or months after the initial arrest. Arbitrary arrests were common, and the government held persons in detention without specific charges, often to collect information about other suspects.

Arbitrary and lengthy pretrial detention continued to be a problem. There were an estimated two million pending civil and criminal cases. A 2008 estimate from the International Centre for Prison Studies found nearly 70 percent of prison inmates were in pretrial detention.

e. Denial of Fair Public Trial

The law provides for an independent judiciary, but in practice a longstanding temporary provision of the constitution placed the executive in charge of the lower courts, judicial appointments, and compensation for judicial officials. In 2007 the caretaker government implemented legislation the previous government had developed separating the judiciary from the executive, and that legislation remained in effect throughout the year.

The court system has two levels: the lower courts and the Supreme Court. Both hear civil and criminal cases. After the separation of the judiciary from the executive, the government appointed judicial magistrates to replace the executive magistrates who had presided over the lower courts. Although executive magistrates still exist, their powers are restricted, and they are only appointed in specific circumstances; for example, executive magistrates were appointed to administer the mobile court system to look at issues of food adulteration and quality. The Supreme Court has two parts, the high court and the appellate divisions. The High Court Division hears some original cases mostly dealing with constitutional issues, and reviews cases from the lower courts. The Appellate Division hears appeals of judgments, decrees, orders, or sentences of the High Court. Rulings of the Appellate Division are binding on all other courts.

On July 15, the government appointed four new judges to the Appellate Division. Members of the legal community criticized the appointment of one of the judges, which superseded the appointment of a more senior judge of the High Court Division. According to government officials, the appointments were made because the additional judges were necessary to dispose of the large numbers of cases pending in the Appellate Division.

In September 2008 the Appellate Division resumed the practice of overturning politically charged decisions by the High Court Division, usually to the benefit of the current AL government. In at least two cases, the Appellate Division overturned decisions granting bail to high-level corruption suspects who were leaders of opposition parties. Additionally, corruption, judicial inefficiency, lack of resources, and a large case backlog remained serious problems with the judiciary.

The EPR authorized the government to create special speedy anticorruption courts to adjudicate cases prosecuted by the Anticorruption Commission (ACC). Sentences from these tribunals could also be appealed to the High Court. During the year, the repeal of the EPR led to the demise of these courts.

In 2005 a High Court panel judged unconstitutional an amendment to the constitution that legitimized martial law in the 1980s. The prime minister's office arranged for a stay of the ruling because of its ramifications for the legacy of former president Ziaur Rahman, the late husband of the then prime minister. The case remained in the Appellate Division at year's end.

Trial Procedures

The law provides accused persons with the right to be represented by counsel, to review accusatory material, to call or question witnesses, and to appeal verdicts. Cases are decided by judges rather than juries, and trials are public. In practice a public defender is rarely provided to defendants. Defendants are presumed innocent and have the right to appeal, to be present and to see the government's evidence.

Corruption and a substantial backlog of cases hindered the court system, and trials were typically marked by extended continuances, effectively preventing many from obtaining a fair trial due to witness tampering, victim intimidation, and missing evidence. Human rights observers contended magistrates, attorneys, and court officials demanded bribes from defendants in many cases filed under the Special Powers Act during the year.

Political Prisoners and Detainees

There were hundreds of daily and weekly independent publications. Although there were significant improvements over the previous year, newspapers critical of the government experienced some government pressure. Journalists perceived to be critical of the government and those aligned with the opposition alleged harassment from unspecified wings of the security forces and members of the ruling party. In addition to one official government-owned news service, there were two private news services.

Unlike in the previous year, the military's Inter-Service Public Relations (ISPR) office and the DGFI did not directly restrict newspaper ownership or content. However, journalists reported the military cautioned them against criticizing the government or the military, especially in the aftermath of the BDR mutiny. Matiur Rahman Chowdhury, editor of Manabzamin and host of two television talk shows, stated in the English language New Age that officials told him indirectly to refrain from inviting specified guests during the BDR incident. He also said tapes for a particular talk show were taken from station several hours before the show was scheduled to be broadcast.

The host of a popular Bengali-language current affairs talk show, Point of Order, alleged she received phone calls from individuals identifying themselves as DGFI officials who warned her against promoting "antigovernment and antistate propaganda." She also said sponsors of her program had been encouraged to stop their support of her show.

There were no developments in the March 2008 case of Rabiul Islam, a journalist for the Rajshahi-based Bengali language Daily Sunshine who was allegedly tortured by local police.

The government took no further action in the May 2008 assaults against Daily Star correspondents Mirza Shakil and Iasinur Rahman.

There were no new developments in the case of Jahangir Alam Akash, who reportedly was tortured by authorities in November 2008. Akash ran his own blog devoted to press freedoms and human rights during the year.

There were no developments in the case of the Jai Jai Din editor who was fired in July 2008 because he published a cartoon critical of then Army Chief General Moeen Uddin Ahmed.

The trial court dismissed charges against accused teachers and students in the 2007 attack on journalists at Dhaka University. Tasneem Khalil, former Daily Star journalist and researcher for Human Rights Watch, continued to live in exile in Sweden following his 2007 interrogation and torture by joint forces.

Unlike in previous years, the government did not subject foreign publications and films to stringent reviews and censorship. A government-managed film censor board reviewed local and foreign films and had the authority to censor or ban films on the grounds of state security, law and order, religious sentiment, obscenity, foreign relations, defamation, or plagiarism, but this was less strict than in the past. In practice video rental libraries and DVD shops stocked a wide variety of films, and government efforts to enforce censorship on rentals were sporadic and ineffective.

Unlike in the previous year, the government only rarely exercised censorship in cases of immodest or obscene photographs, perceived misrepresentation or defamation of Islam, or objectionable comments regarding national leaders.

There were no developments regarding the 2007 decision to ban Alpin, the satirical weekly magazine of the newspaper Prothom Alo, due to alleged blasphemy against Islam.

Unlike in previous years, the government did not use defamation charges to curb freedom of speech.

There were no developments in the 2007 defamation lawsuit filed by Mah Selim against Juganthor newspaper.

There were no developments in the case of Biman Chandra Bosak, who was allegedly beaten by RAB officers and police in April 2008 after he filed a case against a Muslim neighbor who tried to seize land dedicated to a Hindu deity.

There were also no developments in the April 2008 attack against two Christian men in Rangunia allegedly by members of an Islamist group

In contrast to previous years, there were no reports of the military attempting to evict Hindu families from land in the Mirpur area of Dhaka abutting the military cantonment.

According to human rights groups, harassment by forestry department officials persisted, although it decreased from previous years.

Religious minorities continued to be disadvantaged in seeking government jobs and political office, although reportedly less so than in the past following the election of a secular government. Selection boards for government services often lacked minority group representation.

There was no Jewish community in the country and there were no reports of anti-Semitic acts against locals, but some newspapers occasionally printed anti-Semitic articles and commentary.

For a more detailed discussion, see the 2009 International Religious Freedom Report at www.state.gov/g/drl/rls/irf/.

In accordance of the human rights report by the US department of State dated March 11, 2010, His Eminency Dr. Mohammad Nurul Alam, Chief of the Mission of World Human Rights Service Council New York USA, Custodian of 700 years old Sufi Dynasty, Azimpur Dayera Sharif and Joint Mutuwalli of Sufi NurUllah Waqf estate, President and UN permanent Representative of Dayemi Complex Bangladesh to UN Office New York, Geneva, Vienna & Adis Ababa. Eminency is Bangladeshi American Citizen 43^rd Direct Descendant from the Prophet of Islam had been harassed by the corrupt senior police officer of Bangladesh Police headed by Additional Inspector General of Police Mr. Nobo Bikrom Tripura, along with his near and dearest corrupt senior Police officer like Mokbul Hossain Bhuiya additional DIG of Police, Chittagong district, Mr. Golam Rahman Officer in charge of Lalbagh Police Station, Sajjad Hossain SI of Lalbagh PS DMP Dhaka, Fazlul Hoque Inspector of DC DB Dhaka, Kala Chand Ghosh, SI of Lalbagh P.S, Alamgir Hossain SI of Lalbagh Police Station, Shafiqul Islam SI of Lalbagh PS, Md. Kamal Hossain SI of Azimpur Police Fari Under Lalbagh PS DMP Dhaka, along with Kazi Habib SI of CID department, Abdul Hakim SI of DC DB, OC Noman & Jafor Ali SI of Model Romna Police Station DMP Dhaka. There are also Awaami Jubo league a terror group with the active cooperation of Eminency’s opposite party of Dayera Sharif headed by Deen Greenburgh a fanatic Jewish converted to Islam Din Mohammad Abdullah, there are several cases had been started against all the abovementioned individuals to the Ministry of Home, Government of Bangladesh and to the CMM court of Dhaka, Bangladesh, along with Honorable High Court Division of Bangladesh Supreme Court Dhaka. A demand of Justice Notice issued by His Eminency’s designated advocate Dr. Md. Aminul Hoque vide Reference# 0091/10/NDJ-01-16(1)2009 in support of Eminency’s writ petition# 1875/237 dated March 16^th of 2003. A rule Nishi order has been issued against the Bangladesh Police activities for not to harras, not to seize his passport, not to disturb him at all, but Bangladesh Police did not listen. Therefore a contempt of court’s case has been filed to the Supreme Court Contempt Petition# 142 of 2009 in reference of Attorney General of Bangladesh by his office memo# 11032/09 dated August 3^rd 2009 and Romna PS GD# 1321 dated April 17^th, 2009, Romna PS GD# 135 Dated November 4^th 2009, officer in charge for Romna PS Mr. Noman and his sub-inspector The investigation officer of the above GD and Mr. Jafor Ali is still not complying with the direction of Commander In charge RAB-3 Moghbazar Dhaka.

Sk. M. Tofayel Hassan, Assistant Judge of CMM court Dhaka had taken sustainable big amount of bribe from a prostitute women Nargis Sultana Daughter of Abdul Halim, girlfriend of Inspector Golam Rahman of DMP Dhaka, associated with SI Sajjad Hossain of Lalbagh PS completely disregarded the Supreme Court’s Most Influential Judge Justice Abdul Wahab Miah’s orders also disregarded the Supreme Court’s RULE NISHI order# 1875/2003 of Dr. Alam. When His Eminency Dr. Alam attended by the High Court Order for the False Case bell on Nov, 11, 2009 but corrupt Judge Sk. M. Tofayel Hassan intentionally and illegally disregarded the Supreme Court Justice Abdul Wahab Miah’s order and cancelled Eminency’s bail and illegally detained him in Jail. Same Day on Nov 11, 2010 Eminency’s Advocates led by Dr. Zamirul Akhter met and discussed with Learned CMM Judge Enamul Hoque and eventually Judge Enamul Hoque understood the matter as well as apologized for such misconduct with Eminency Dr. Alam of his junior staff and a corrupt judge Sk. M. Tofayel Hassan. Immediately Judge Enamul Hoque of CMM Dhaka designated another Judge (Abdur Rahim) to look over Eminency’s case Lalbagh PS case# 61/5(2009).

Accordingly, Judge Abdur Rahim reviewed the matter within 18 hours also understood the whole matter of his colleague Sk. M. Tofayel Hassan’s corruption and critized him verbally for disregarding the Supreme court’s Justice Order. He also granted the bail of in accordance of the law for His Eminency Dr. Hazrat Shah Sufi M N Alam. The current situation of Bangladesh’s law order is completely paralyzed by the corrupt police officials and corrupt judges. The abovementioned police individuals along with Judge Tofayel Hassan must be faced with exemplary punishment is urgently required in reference of the letter of World Human Rights Service Counsel UN office New York, USA Dated April 28^th, 2010.

His Eminency Dr. Alam also have informed the Ministry of Home Affairs Government of Bangladesh thru his designated Lawyer Mr. Md. Abdur Rouf in reference Ministry of Home Letter# 2/2003 (Immigration Section-1)237 & 238 both dated March 16^th 2003 in favor of His Eminency Dr. Alam writ petition# 1875 of 2003. Accordingly, Ministry of Home immigration section Letter# 1/2003 (Immigration Section-1)/1669 dated October 21^st, 2009 for the violation of High court order against all the abovementioned corrupt police officials to take appropriate administration action signed by Mr. Abu Syed Md. Khurshidul Alam, Deputy Secretary Ministry of Home Affairs Immigration section-1, Govt. of Bangladesh addressed to Inspector General of Police, Police Headquarter Dhaka, Bangladesh also a complain letter against Bangladesh Police, letter# 812 dated July 29^th 2009 to the Ministry of Home affairs Police branch-2 dated July 29^th, 2009

The following is the list of accused inhuman characters:

1. Sk. M. Tofayel Hassan, Assistant Judge of CMM court Dhaka along with his associates

2. Nargis Sultana, wife of Nurul Islam

3. Nurul Islam, Husband of Nargis Sultana

4. Abdul Halim, Father of Nargis Sultana

5. Enamul Hoque Shomrat

6. Kholilur Rahman

7. Md. Asadduzaman

8. S. M. Shamim

9. Faize Mohammadi Ahmadullah, Ata-e-Dayem Anwar Ullah sons of Erfan Uddin of Boro Moghbazar, Dhaka

10. Saleha Khatun, Ahmadul Khondokar, Mir Ofawul Hoque Khondokar, Shujon Khondokar, Monjurul Hoque Khondokar, Syed Basharut Ullah 42/2 Azimpur Chotto Dayera Sharif

11. Monir Ahmed, Enamul Hoque-Qutubi, Mollah Abdul Hannnan, Zomir Hossain, Mollah Fozlul Hoque & Others

Above is the list of information about the corrupt/accused persons of Government officials and individuals. Currently His Eminency Dr. Alam is residing in United States of America, pursuing the matter thru the United Nations, World Human Rights Service Council, New York USA, The White House, Washington D.C. Concerned US Senator of International Human Rights Committee for the legal protection, safety and security for the US Citizen in abroad.

All the above mentioned accused individuals are charged by the CID Department of Bangladesh Government Reference# Crime BG/14-98/2917 dated April 4^th, 1999 & Lalbagh PS Case# 48/2000 Charge Sheet issued by CID Department of Bangladesh Government signed by Assistant Superintendent of Police/CID Mr. Aminul Islam (This case is currently pending for hearing at the Bangladesh High Court Division of Supreme Court).

IN THE SUPREME COURT OF BANGLADESH HIGH COURT DIVISION

(SPECIAL ORIGINAL JURISDICTION)

WRIT PETITION: October OF 2009

IN THE MATTER OF:

An application under Article 102 of the Constitution of the People’s Republic of Bangladesh.

AND

IN THE MATTER OF:

Dr. Shah Sufi Hazrat Mohammad Nurul Alam, Son of Late Sirajul Islam of Holding No. 42/2, Azimpur Road (Holy Dayera Sharif), Police, Station-Lalbagh, District- Dhaka.

-------Petitioner

-VERSUS-

1. The Secretary,

Ministry of Home Affairs, Government of

the People’s Republic of Bangladesh,

Bangladesh Secretariat, Dhaka.

2. Mr. Nur Mohammad

The Inspector General of Police,

Government of the People’s Republic of

Bangladesh, Police Head Quarters, Dhaka.

3. Mr. Nabo Bikram Tripura

The Additional Inspector General of Police

(Admin), Government of the People’s

Republic of Bangladesh, Police Headquarters, Dhaka.

4. Additional Inspector General of Police

Special Branch, Malibagh, Dhaka.

5. Director General

Rapid Action Battalion (RAB)

(RAB Head Quarter’s) Uttara, Dhaka.

6. Additional Inspector General of Police

Criminal Investigation Department (CID)

Malibagh, Dhaka.

7. Director General

Notional Security Intelligence

Segunbagicha, Dhaka.

8. Sk. M. Tofayel Hassan, Assistant Judge

Currently Judicial Magistrate Under Chief Metropolitan Magistrate

CMM Court, Dhaka, Bangladesh

9. Mr. Mokbul Hossain Bhuiyan

The Additional Deputy Inspector General of

Police, Government of the People’s

Republic of Bangladesh, Chittagong Range, Chittagong

10. Mr. A K M Shaidul Haque

The Commissioner of Police,

Dhaka Metropolitan Police,

Metropolitan Police Head Quarters,

Mintu Road, Dhaka, Bangladesh.

11. Mr. Md. Monirul Islam

The Deputy Commissioner of Police,

Detective Branch, Dhaka South, Dhaka

Metropolitan Police, Mintu Road, Dhaka.

12. Md. Anowar Hossain

The Deputy Commissioner,

Lalbagh Division,

Dhaka Metropolitan Police,

Bangshal, Dhaka.

13. Md. Aminur Rahman

Assistant Commissioner of Police, Kotwali

Zone, Kotwali Police Station, Dhaka

Metropolitan Police, Dhaka.

14. Fazulul Haque

Inspector of Police,

Office of the Deputy Commissioner of

Police, Detective Branch Office, Dhaka

Metropolitan Police, Mintu Road, Dhaka.

15. Golam Rahman

Officer-In-Charge, Chalk Bazar Police Station, (Former

Officer-In-Charge, Lalbagh Police Station),

Dhaka Metropolitan Police, Dhaka.

16. Sazzad Hossain Sub-Inspector of Police,

Dhanmondi Police Station, Dhaka

Metropolitan Police, Dhaka.

17. Kala Chand Ghosh Sub-Inspector of Police,

Shahid Nagar Community Centre, Lalbagh

Police Station, Dhaka Metropolitan Police, Dhaka.

18. Alamgir Hossain Sub-Inspector of Police,

Shahid Nagar Community Centre,

Lalbagh Police Station,

Dhaka Metropolitan Police, Dhaka.

19. Md. Shariful Islam Sub-Inspector of Police,

Shahid Nagar Community Centre,

Lalbagh Police Station,

Dhaka Metropolitan Police, Dhaka.

20. Abdul Hakim Sub-Inspector of Police,

Office of the Deputy Commissioner,

Detective Branch,

Dhaka Metropolitan Police,

Mintu Road, Dhaka.

21. Md. Kamal Hossain Sub-Inspector,

Azimpur Police Fari,

Shahid Nagar Community Centre,

Lalbagh Police Station,

Dhaka Metropolitan Police, Dhaka.

22. Nargis Sultana Daughter of Abdul Halim

Wife of Md. Nurul Islam

Building No. 23, Plot No. 402

Japan Garden City,

Police Station-Adabor, Dhaka-1207.

23. Saleh Uddin Ahmed Chisty

Son of Late Ali Ahmed

Building No. 5/404, 52 Eastern Banasree

Apartment Project, Road No.7, Block No. B,

Banasree, East Rampura, Dhaka-1219.

24. Saleha Khatun

Wife of Late Sayed Dayem Ullah

42/2 Azimpur, Choto Daira Sharif,

Police Station-Lalbagh, Dhaka-1205.

25. Late Soyeda Rokeay Begum

So called Daughter of Late Soyed Dayem Ullah

42/2 Azimpur, Choto Dayera Sharif,

Police Station-Lalbagh, Dhaka-1205.

26. Foyezi Mohammadi Ahammadullah

Son of Shah Erfan Uddin,

Village and Post- Ebrahimpur Etimkhana,

Police Station-Nabinagar,

District-Brahman Baria.

27. A. D. Mahamud Ullah

Abundant son of Dr. M. N. Alam

42/2 Azimpur, Choto Dayera Sharif,

Police Station-Lalbagh, Dhaka-1205

28. Eng. Mosharaf Hossain Shajahan

Former State Minister,

Ministry of Religious Affairs,

Government of the People’s Republic of

Bangladesh. Dhaka.

29. Din Mohammad Abdullah (Din Green Bargh) Son of Green Bargh, Care of 42/2 Azimpur, Choto Dayera Sharif, Dhaka-1205.

30. Monir Ahmed @ Moinna Chora

Son of Late Minnot Ali,

Village and Post Office-Satbaria,

Police Station-Chandanish,

District-Chittagong.

31. Anowar Hossain

Former Member of Parliament,

Government of the People’s Republic of Bangladesh ,

Police Station-Nabinagar,

District-Brahman Baria.

32. Mollah Enamul Haque Kutubi

Son of Moulvi Mohammad Elius,

of Ibrahimpur Sufi Azmatullah Madrasha,

Village and Post Office- Ibrahimpur,

Police Station-Nabinagar,

District-Brahman Baria.

33. Motahar Hossain Sarkar

Son of Unknown, of Sarkarbai,

Village and Post Office-Ibrahimpur,

Police Station-Nabinagar,

District-Brahman Baria.

34. Mollah Fazlul Haque

Son of Md. Obayedul Haque

of Village-Garanghia

Police Station-Satkania,

District-Chittagong.

35. Ahamedul Haque Khandakar

Son of Hazi Offaul Haque Khandakar,

43/2 Azimpur Road,

Police Station-Lalbagh,

District-Dhaka.

36. Zamir Hossain (So called superintendent)

Son of Unknown, of Ibrahimpur Sufi

Azmatullah Eatim Khana,

Village and Post Office- Ibrahimpur,-

Police Station-Nabinagar,

District-Brahman Baria.

37. Ata-E-Noor Anowerullah

Son of Erfan Uddin Shah

of 42/2 Azimpur, Choto Dayera Sharif Dhaka-1205.

38. Md. Monjurul Haque Khondakar

Son of Offaul Haque Khandaker,

43/2 Azimpur Road, Police Station-Lalbagh,

District-Dhaka-1205.

39. Sayeda Noor-E-Sani

Daughter of Erfan Uddin,

42/2 Azimpur Choto Dayera Sharif,

Police Station-Lalbagh, Dhaka-1205.

40. Sayed Nurullah

Son of Late Kharullah of Natun Paltan Lane Line (near Azimpur

Kabarsthan Mosque inside the Mazar of Sufi

Abu Mohammad Obaidullah (R)

Police Station-Hajaribagh, Dhaka.

41. Asaduzzaman Shamrat

Special Correspondent

“Daily Amader Somoy”

65, Mymensingh Lane

Bangla Motor, Dhaka-1000

---Respondents

AND

IN THE MATTER OF:

Direction upon the Government to form an impartial investigating body to investigate the Criminal Cases as mentioned in Paragraph No. 6 of the Writ Petition in which the investigation has been done by the police with ulterior motive, illegally, fraudulently, collusively and on huge amount of illegal gratification.

AND

IN THE MATTER OF:

Enforcement of fundamental rights of the Petitioner, Holy Choto Dayera Sharif and Dayemi Complex Bangladesh(Sufi Nurullah WAQF Estate, E.C. No. 10355) to be secured under the Constitution of Bangladesh and to enjoy the protection of law as contained in the Constitution of the People’s Republic of Bangladesh.

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To,

Mr. Justice M. M. Ruhul Amin, the Chief Justice of Bangladesh and his companion Justices of the said Honorable Court, The humble petition on behalf of the petitioner above named most respectfully---

SHEWETH:

1. That the petitioner is a permanent citizen of Bangladesh and residing at the address given to the cause title of this petition; that the addresses of the petitioner and the Respondents as given to the cause title of this petition are their correct addresses for serving notice upon them and all other necessary purposes.

2. That the petitioner is the founder President of Dayemi Complex Bangladesh, Holy Choto Dayera Sharif, 42/2 Azimpur, Lalbagh Police Station, Dhaka and permanent representative of United Nations and Joint Motowalli of Sufi Nurullah WAQF Estate and he has been serving for mankind, Welfare and peace National and International level since 1969 and he has millions of followers in Bangladesh and abroad and he is the religious and spiritual leader and custodian of the Sufi Dynasty, Holy Dayera Sharif, President of the World Spiritual Assembly, New York, United States of America, World Peace Envoy, United Nations NGO permanent representative, founder of seven international orphanages in Bangladesh, Chief of the Mission of World Human Rights Service Council, New York, United States of America, Founding Member of London Diplomatic Academy and its United Nations representative. He is also Hon’ble Minister Plenipotentiary to United Nations of the International States of Parliament for safety and peace since 2001. The petitioner has been serving the cause of neglected humanity, established and looks after more then 100 Educational Institutions, High Schools, Colleges, Madrasas, Mosques and 15 Orphanages in different parts of the country; that Ex-President of United States of America namely Bill Clinton and George W. Bush and present President of the United States of America Mr. Barak Obama has good relation with petitioner and they several times wrote letters to the petitioner and praised him for his outstanding work to them for their personal matters and national issues for world peace; that Photocopies of the Biography of the petitioner and his vision home and abroad and letters of above Presidents of the United States of America such as George W. Bush, Bill Clinton and present president Barak Obama and petitioner’s United Nations Identity Cards alongwith UN press release and correspondence of Prime Minister’s Khaleda Zia and Sheik Hasina and foreign Minister alongwith Bangladesh Mission in abroad and Bangladesh Gazzattes Dated March 2nd, 1989 and June 25, 1987 are annexed herewith and marked as ANNEXURE- “A” Series.

3. That in the above facts and circumstances it is crystal clear that the petitioner is a Highly Spiritual and Philanthropic and World famous leader in which has created enmity enviousness in the mind of rival groups within the family in the society of

Bangladesh who with a view to destroying the above reputation and property of the petitioner’s Holy Dayera Sharif and Nurullah WAQF Estate formed a scandal with the police and giving them illegal gratification tried to entangle the petitioner in false cases and has started Lalbagh Police Station Case No. 46(3)09 and Lalbagh Police Station Case No. 61(5)09 on the similar false facts; that the Police specially Golam Rahman, Officer-In-Charge, Chalk Bazar Police Station (Former Officer- In-Charge, Lalbagh Police Station) Dhaka Metropolitan Police, Dhaka procured a women named Nargis Sultana who is a reputed prostitute and made her sleeping partner and through her lodged two false and fabricated FIR’s of the above two cases and above Golam Rahman with his most obedient colleague such as Sazzad Hossain, Sub-Inspector, Dhanmondi Police Station, Kalachand Ghosh, Sub-Inspector, Lalbagh Police Station and Md. Kamal Hossain, Sub-Inspector of Police, Azimpur Police Fari under the Lalbagh Police Station, Dhaka, showed them inquiry officer but no inquiry was held and false and fabricated charge-sheets were submitted by them in the above two cases to the Chief Metropolitan Magistrate, Dhaka against the petitioner and others.

4. That against the above two false criminal cases the Petitioner prayed for proper investigation and in one Writ Petition No. 1875 of 2003 and two Criminal Miscellaneous Case No. 13028 of 2009 arising out of Lalbagh Police Station Case No. 46(3)09 and Criminal Miscellaneous Case No. 22296 of 2009 arising out of Lalbagh Police Station Case No.61(5)09 before the Hon’ble High Court Division of the Supreme Court of Bangladesh and the Hon’ble Court has been pleased to issue Rule Nisi and not to arrest the petitioner without due process of law; that certified copy of the above Judgment and Order of the Writ Petition and Criminal Miscellaneous Case No. 22296 of 2009 are annexed herewith and marked as ANNEXURE-“B” Series.

5. That the Petitioner has started Lalbagh Police Station Case No. 48(10)99 and Lalbagh Police Station Case No. 54(9) 97 against the rival groups within the family members of the petitioner; that on 30-03-2009 Md. Enamul Haque Samrat, the Assistant Director (Admin) of the Petitioner’s Holy Dayemi Complex Bangladesh went to Lalbagh Police Station to lodge another FIR against the Police officials but he was refused and subsequently on 02-04-2009 a Criminal Case No. 2049 of 2009 was filed before the learned Chief Metropolitan Magistrate Court, Dhaka under sections 114/448/395/505/ 34 of the Penal Code against Sazzad Hossain, Former Sub-Inspector of Police, Lalbagh Police Station, Dhaka and Nargis Sultana, the kept of Golam Rahman, Former Officer-In-Charge, Lalbagh Police Station, Dhaka Metropolitan Police, Dhaka who looted the petitioner’s Private Car, Money and valuable Articles from Holy Dayemi Complex Bangladesh Office; that certified copies of the above Criminal Case No. 2049 of 2009 is annexed herewith and marked as ANNEXURE-“C” Series.

6. That in the above way there have arisen the following cases between the parties but no proper and impartial inquiry is so long held and the Police have kept those in abeyance and have been harassing the petitioners and misappropriated Taka 100 (one hundred) crores of the property of Holy Dayemi Complex Bangladesh -

(i) Lalbagh Police Station Case No. 46(3)09

(ii) Lalbagh Police Station Case No. 61(5)091-

(iii) Lalbagh Police Station Case No. 48(10)99

(iv) Lalbagh Police Station Case No. 54(9)97

(v) Criminal Case No. 2049 of 2009 in the Court of Chief

Metropolitan Magistrate, Dhaka.

(vi) Criminal Case No. 2280 of 2009 in the Court of Chief

Metropolitan Magistrate, Dhaka.

(vii) Criminal Case No. 1125 of 2009 in the Court of Chief

Metropolitan Magistrate, Dhaka.

(viii) Money Suit No. 50 of 1991 in the Court of 5th Joint

District Judge, Dhaka.

(ix) Civil Revision No. 3334 of 2004 in the Supreme Court of

Bangladesh, High Court Division, Dhaka.

(x) Civil Revision No. 2016 of 2007 in the Supreme Court of

Bangladesh, High Court Division, Dhaka.

7. That in the above facts and circumstances no proper and impartial investigation has been made to adjudicate the matter in controversy and so an order of the Hon’ble Court is necessary to direct the government to inquire the cases with impartial and competent person and to do justice to the cases.

8. That Mr. Justice Habibur Rahman Khan and the Mr. Fazlur Rahman Khan the, Joint Secretary (Retired), Ministry of Education, People’s Republic of Bangladesh and advisor of Holy Dayemi Complex Bangladesh inquired in the affairs of the Azimpur Holy Dayera Sharif and Dayemi Complex Bangladesh and prepared and submitted the report as recommendation in the form of proposal on 25th November, 1998 which is as follows:

Please find the proposal in above Bangeli Chapter of the book.

That Photocopy of the above recommendation in the form of proposal by Mr. Justice Habibur Rahman Khan and the Joint Secretary, Ministry of Education, Mr. Fazlur Rahman Khan, on 25th November, 1998 is annexed herewith and marked as

ANNEXURE-“D”.

9. That the Office of the Additional Inspector General of Police, the Criminal Investigation Department (CID), Bangladesh, Dhaka inquired in the affairs of the Azimpur Holy Dayera Sharif and Dayemi Complex Bangladesh and prepared and submitted a report to the Special Superintendent of Police (Central Offence), Criminal Investigating Department (CID), Bangladesh, Dhaka on 31-07-1999 by Mr. Mohammad Abul Kalam Azad, the Inspector of Police and Hand Writing Expert and Officer-In-Charge of Hand Writing Division, Office of the Inspector General of Police, Criminal Investigation Department (CID), Bangladesh, Dhaka as recommendation in the form of proposal which is follows:

Please find above in the Bengali section, the detailed information of CID investigation report.

That Photocopy the above investigation report inquired by Mr. Mohammad Abulm Kalam Azad, the Inspector of Police, Office of the Inspector General of Police, Criminal Investigation Department (CID), Bangladesh, Dhaka dated 31-07-1999 is annexed herewith and marked as ANNEXURE-“E”.

10. That it is submitted that Golam Rahman, Officer-In-Charge, Chalk Bazar Police Station (Former Officer-In-Charge, Lalbagh Police Station), Dhaka Metropolitan Police (DMP), Dhaka made a conspiracy against the Petitioner taking big amount of bribe from the Petitioner’s rival groups (1) Saleha Khatun (2) Rokeya Begum (3) Foyezi Mohammadi Ahammadullah (4) A.D. Mohammad Ullah those who occupied illegally and forcibly the land property of Sufi Nurullah WAQF Estate of Holy Dayera Sharif and land properties of Dayemi Complex Bangladesh, since 1996 and misappropriated Taka 100 (one hundred) Crores of the Holy Dayemi Complex Bangladesh and several Civil and Criminal Cases have been started against them in Chief Metropolitan Magistrate Court, Dhaka, District Judge’s Court, Dhaka and the Hon’ble High Court Division of the Supreme Court of Bangladesh, as stated in the forgoing Paragraph No. 6 of this Writ Petition.

11. That it is submitted that Golam Rahman, Respondent No. 10, the Officer-In-Charge, Chalk Bazar Police Station (Former Officer-In-Charge, Lalbagh Police Station) and his associates Sazzad Hossain, Respondent No. 11, the Sub-Inspector, Dhanmondi Police Station (Former Sub-Inspector, Lalbagh Police Station) and Kala Chand Ghosh, Respondent No. 12, and Md. Kamal Hossain, Respondent No. 16, Sub-Inspector of Lalbagh Police Station alongwith Fazlul Haque, Respondent No. 9 and Abdul Hakim, Respondent No. 15, Sub-Inspectors of Office of the Deputy Commissioner, Detective Branch, Dhaka Metropolitan Police, Dhaka referred the name of Mr. Nabo Bikram Tripura, Respondent No. 3, the Additional Inspector General of Police (Admin), Bangladesh, Dhaka to have instructions to lodge false cases against the petitioner Dr. Shah Sufi Hazrat Mohammad Nurul Alam to the Lalbagh Police Station, Dhaka Metropolitan Police, Dhaka and accordingly lodged following cases Lalbagh Police Station Case No. 46(3)09 and Lalbagh Police Station Case No. 61(5)09 and by hook or by crook, illegally misused the power of Police as Officer-In-Charge of Lalbagh Police Station submitted the charge-sheets in both the cases to the Chief Metropolitan Magistrate Court, Dhaka using one Nargis Sultana a girl friend of Officer-In-Charge, Golam Rahman as informants in both the cases; that Nargis Sultana alongwith Saleh Uddin Ahmed so called Chisty respondent No.18 who are internationally most wanted criminal and also wanted by Adabor Police Station and Rampura Police Station, Dhaka Metropolitan Police, Dhaka in Nari-O-Shishu Case No. 318 of 2009 in the Court of Nari-OShishu Nirjatan Daman Special Tribunal of Patuakhali; that the Photocopies of the most wanted Criminal by the International Web site of Nurul Islam and Saleh Uddin Ahmed so-called Chisty are annexed herewith and marked as ANNEXURE-“F” Series.

12. That it is submitted that Golam Rahman, Respondent No. 10, the Officer-In-Charge, Chalk Bazar Police Station (Former Officer-In-Charge, Lalbagh Police Station), Dhaka Metropolitan Police, Dhaka has been using his above Nargis Sultana, who has no legal address in Bangladesh; that now her false and fabricated address as Building No. 23, Plot No. 402, Japan Garden City, Police Station-Mohammadpur, Dhaka is being shown in the two FIR and charge-sheets of Lalbagh Police Station Case No. 46(3)09 and Lalbagh Police Station Case No. 61(5)09 against the petitioner; that the Petitioner challenges that above Nargis Sultana is the illegal sleeping partner of above Golam Rahman, Respondent No. 10 and Sazzad Hossain, Respondent No. 11 alongwith Md. Kamal Hossain respondent No. 16 showing her above mentioned manufactured address; that the address and Police Station of above Nargis Sultana is incorrect; that the Japan Garden City is situated inside of Adabor Police Station in accordance with Dhaka Municipal Corporation and Dhaka Metropolitan Police Official records; that Golam Rahman took a big amount of bribe from the Petitioner’s rival groups those who are the nearest family members and used the false address and false First Information Report’s (FIR) through above Nargis Sultana ignoring the Judgment and Order of the Hon’ble High Court Division of the Supreme Court of Bangladesh of the Writ Petition No. 1875 of 2003, not only that Golam Rahman for enmity, personal grudge, intentionally and illegally by hook or by crook prepared and forwarded the charge-sheets of both the false cases to the Chief Metropolitan Magistrate Court within a very short time; that for this reason Golam Rahman, Respondent No. 10 and his associates disregarded the Order of Hon’ble High Court Division in Writ Petition No. 1875 of 2003 and also his associates sazzad Hossain, Respondent No. 11 intentionally and illegally with personal grudge upon the petitioner Dr. Shah Sufi Hazrat Mohammad Nurul Alam; that Golam Rahman, Respondent No. 10, directed his associates Sazzad Hossain, Respondent No. 11 and Shariful Islam, Sub-Inspectors to lodge First Information Report (FIR) dated 29-03- 2009 at 9.25 P.M and at that night at 1.00 A.M. with one truck loaded Police forces under his direction and headed by him with respondent Nos. 9, 11 to 28 initiated and by force entered into the Holy Dayera Sharif, Mosque and Mazar area which are restricted by the Judgment and Order of the Hon’ble High Court Division of the Writ Petition No. 1875 of 2003, in absence of the Petitioner had broken the lock, the Petitioner’s Garage and took out the Petitioners personal car, Sign Board of Holy Dayemi Complex Bangladesh, Sufi Nurullah WAQF Estate and Historic Azimpur Holy Choto Dayera Sharif and destroying the Historic foundation stone where petitioner’s name was inserted and respondents Nos. 19-22 broken the key of the petitioner’s personal office and ‘Gadi Ghar’ at 42/2 Azimpur, Holy Dayera Sharif, ground floor, Room No.1, ‘Gadi Ghar’ and Room No.2 the office room and looted the valuable goods, materials and destroyed the official file and totally illegally by the active co-operation with the respondent Nos. 10-16 without any Court’s order and without any warrant of arrest and without any search warrant; that under such circumstances in accordance with Police Regulation of Begal (PRB) and Criminal Procedure Code it is illegal and violation of fundamental right which runs as follows:-

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“Illegal search of accused house. Its effect when conducted in an irregular manner. Respectively of a witness is of no importance when a search is not made in accordance with law. Search, recovery and seizure of alleged incriminating articles not by a Magistrate or Police Officer but by members of the Public are illegal.” and “No Police Officer shall investigate a non-cognizable case without the order of a Magistrate.”

13. That the Petitioner returned back from the United States of America on 29th day of June, 2009 he has submitted anticipatory bail petition and surrendered to the Hon’ble High Court Division of the Supreme Court of Bangladesh and Mr. Justice Md. Abdul Wahhab Miah and Mr. Justice Abdur Razzake passed two judgment and orders dated the 9th day of July, 2009 and dated 12th Day of October, 2009 as follows :- “It appears that the allegations made in the First Information Report (FIR) as quoted in the body of the application are of civil nature etc.” and “In the meantime the Police and the other law enforcing agencies are directed not to arrest and harass the Petitioner in any manner.” in Criminal Miscellaneous Case No. 13028 of 2009 arising out of Lalbagh Police Station Case No.46(3)09 and Criminal Miscellaneous Case No. 22296 of 2009 arising out of Lalbagh Police Station Case No.61(5)09; that Golam Rahman, the Former Officer-in-Charge, Lalbagh Police Station and his associate Sazzad Hossain, former Sub-Inspector of Lalbagh Police Station disregarded and dishonoured the order of Mr. Justice Md. Abdul Wahhab Miah and Mr. Justice Md. Abdur Razaque; that he and his associates (the respondent Nos. 9-28) illegally, unlawfully, forcibly entered into the premises/ Residence of the petitioner office alongwith prostitute girl friend Nargis Sultana several times and on several dates on enmity and personal grudge; that these are the gross violation of Police Regulation of Bengal (PRB) and Criminal Procedure Code alongwith the Hon’ble High Court’s three Judgments and Orders and as such the petitioner already filed petition of Contempt of Court numbered as Contempt Petition Case No.145 of 2009 against him and his associates before the Hon’ble High Court Division of the Supreme Court of Bangladesh but Mr. Justice Sayed Mahmud Hossain and Mr. Justice Kamrul Islam Siddiqee are disagreed to hear the matter; that Mr. Justice Sayed Mahmud Hossain expresses as “Petitioner bear high Level Personality as such I am unable to hear this matter” and another Justice Mr. Justice Kamrul Islam was sound sleeping on the Ejlas and as such the matter be made out of list. On the other hand at the time of hearing of the Petitioner’s Writ Petition No. 1875 of 2003 dated 07.07.2009 Mr. Justice Mohammad Anowarul Haque and Mr. Justice Naima Haider are also disagreed to hear the matter and as such Judgment and order was passed by them on 07.07.2009 is “Let this matter be made out of list.” Petitioner seems to think that the Hole Hudiciary has paralished and administration is also the same in Bangladesh ; that another Criminal Petition Case was started in the Court of Chief Metropolitan Magistrate Court, Dhaka against his associate Sazzad Hossain and his girl friend Nargis Sultana in Criminal Case No. 2049 of 2009 which is pending before the Chief Metropolitan Magistrate Court, Dhaka.

14. That it is most respectfully submitted that the Police has no lawful authority to raid and search of the petitioner’s house, office and Holy Dayera Sharif and they have no lawful authority to arrest the petitioner without due process of law.

15. That it is most respectfully submitted that such action of the Police is violative of the Fundamental Rights of the Petitioner as guaranteed by the Article 27/ 31/ 32/ 36/ 40 and 43 of the Constitution of Bangladesh and the Petitioner’s right to be secured at home and office as well as at the Holy Dayera Sharif of the Dayemi Complex Bangladesh against entry, search and seizure except in due process of law is also being violating of the petitioner’s fundamental rights as guaranteed under Article 36 and 43 of the Constitution.

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16. That it is most respectfully submitted that such action of raiding and searching the house and office of the petitioner and to arrest him without warrant is violative of his fundamental rights guaranteed by the Constitution of the People’s Republic of Bangladesh and as such the impugned action is illegal, without lawful authority and is of no legal effect.

17. That it is most respectfully submitted that under Article 44 of the Constitution it is within your Lordships jurisdiction to ensure that the petitioner can enforce his fundamental rights under Article 102 (i) of the Constitution of Bangladesh.

18. That it is most respectfully submitted that unless the respondents are restrained from raiding the Holy Dayera Sharif and residence of the petitioner and his office from arresting him without due process of law in connection with any allegation relating to specific case or without warrant, the petitioner shall suffer irreparable loss, injury, harassment and humiliation.

19. That Mr. Nabo Bikram Tripura, Additional Inspector General of Police (Admin.), Bangladesh and Mr. Mokbul Hossain Bhuiyan, Additional Deputy Inspector General, Chittagong Range, Chittagong intentionally, with enmity and personal grudge have been doing conspiracy with petitioner’s rival groups and the members of the family since 1997; that the petitioner filed a Money Suit No. 50 of 1999 before the Court of Learned 5th Sub-ordinate Judge, Dhaka and now the 5th Joint District Judge, Dhaka against him and his associates sum of Taka 55 corores for defamation and as such for this reason they are angry with the petitioner and lodged false First Information Report (FIR) in Lalbagh Police Station Case No. 46(3)09 and 61(5)09 which is gross violation of Police Regulation of Bengal (PRB) and Criminal Procedure Code and Articles 27, 31, 32, 36 and 44 of the Constitution of the People’s Republic of Bangladesh; that the certified copy of the plaint of above Money Suit No. 50 of 1999 is annexed herewith and marked as ANNEXURE-“H”

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20. That it is submitted that on behalf of the Petitioner to protect the property of Holy Dayera Sharif from the clutches of the greedy, notorious and envious persons of the society who are always in collusion with the Police to grab the WAQF property of others, applications after applications were placed before the Ministry of Home affairs since 1997 to till today and the Ministry accepted the grievances and sent the matter to the proper authority to ventilate the grievance by making a proper and impartial inquiry in the matter of the cases involved, but not authority has paid any heed to the orders and directions of the Ministry of Home affairs and the matter is crying in wilderness and under such circumstances the Hon’ble Court is a proper authority to direct proper and impartial inquiry upon the Government in the cases mentioned in the Writ Petition specifically and separately; that the office orders and directions of the Ministry of Home Affairs asking the authority concerned to take necessary action are annexed herewith and marked as ANNEXURE-“I” Series.

21. That it is submitted that charge-sheets have been filed in Lalbagh Police Station Case No. 46(3)09 and Lalbagh Police Station Case No. 61(5)09 by the investigating officer in violation of the order of the investigation made by the Mohammad Abul Kalam Azad, the Inspector of Police, Criminal Investigation Department (CID), Bangladesh which is annexed in this Writ Petition marked as Annexure-“F”.

22. That the Petitioner sent Notice of Demand of Justice calling upon the respondents to hold proper and impartial high level Judicial inquiry in connection with their misdeeds and not to do anything further which may cause harassment to the petitioner; that for their illegal and unlawful activities the petitioner has suffered a loss of Taka 100(One hundred) Crores which is liable to be compensated to the petitioner by the respondents but no reply thereto has yet been received by the petitioner; that copy of the said Notice of the Demand of Justice with postal receipts are annexed herewith and marked as ANNEXURE-“J” Series.

23. That the Petitioner having no other equally efficacious, adequate and speedy remedy provided by law other than filing this application begs to move the same before your Lordships on the following amongst other - G R O U N D S

I. For that in the facts and circumstances of the case it is crystal clear that the law enforcing authority is not discharging their duties properly and impartially and so the Government is liable to direct a competent and impartial high level Judicial inquiry or an inquiry by high level administrative officials in the matter of the cases of HolyDayera Sharif and Dayemi Complex Bangladesh against the Police officials.

II. For that Lalbagh Police Station Case No. 46(3)09 and Lalbagh Police Station Case No. 61(5)09 are brought through an immoral woman by the Police being highly interested with the misappropriated money of Holy Dayera Sharif and so to bring out and punish the immoral Police Officer and to save the property of Holy Dayera Sharif, a high level inquiry is to be ordered by the Government.

III. For that Lalbagh Police Station Case No. 48(10)99 and Lalbagh Police Station Case No. 54(9)97 have been brought by the petitioner against the illegal activities of the rival groups and immoral police officers against the making of fraudulent, forged and fabricated deeds with the property of the Holy Dayera Sharif and Sufi Nurullah WAQF Estate and so they should be brought to book and punished.

IV. For that it is the bounden duty of the Government of Bangladesh to ensure the fundamental rights of the Holy Dayera Sharif and Dayemi Complex Bangladesh, top most benevolent institution in Bangladesh to protect the right to property.

V. For that the concerned Police Officer such as Golam Rahman, Officer-In Charge, Chalk Bazar Police Station, Sazzad Hossain, Sub-Inspector of Police, Dhanmondi Police Station, Kala Chand Ghosh and Md. Kamal Hossain, Sub-Inspectors of Police, Lalbagh Police Station alongwith Fazlul Haque and Abdul Hakim, Sub-Inspectors of the Office of the Deputy Commissioner, Detective Branch, Dhaka Metropolitan Police, Dhaka and Mr. Nabo Bikram Tripura, the Additional Inspector General of Police (Admin), Bangladesh, Police Head Quarters, Dhaka and Mr. Mokbul Hossain Bhuiyan, the Additional Deputy Inspector General of Police, Bangladesh, Chittagong Range, Chittagong in collaboration with rival groups of Petitioner’s namely Nargis Sultana, Saleh Uddin Ahmed Chisty, Saleha Khatun, Rokeya Begum, Foyezi Mohammadi Ahammadullah, A. D. Mohammad Ullah, Eng. Mosharaf Hossain Shajahan, Din Mohammad Abdullah (Din Green Bargh), Monir Ahmed @ Moinna Chora,Anowar Hossain, Mollah Enamul Haque Kutubi, Mollah Fazlul Haque, Motahar Hossain Sarkar and Zamir Hossain and have caused a loss of Taka 100 (One hundred) Crores to the Holy Dayemi Complex Bangladesh and on proper and impartial inquiry they are to compensate the loss and they should be removed from their service for such heinous offence.

VI. For that the concerned Police Officer in connection with Lalbagh Police Station Case No. 46(3)09 and Lalbagh Police Station Case No. 61(5)09 are so notorious and adamant that they have violated the order of the investigation made by the Mohammad Abul Kalam Azad, the Inspector of Police, Criminal Investigation Department (CID), Bangladesh about the Holy Dayemi Complex Bangladesh.

VII. For that the inquiry and recommendation in the form of proposal by Mr. Justice Habibur Rahman Khan in connection with the Dayemi Complex Bangladesh against the culprits should be honoured and accepted by the Government and steps should be taken accordingly.

VIII. For that the concerned Respondent Police Officials have violated the Police Regulation of Bengal (PRB) and Criminal Procedure Code and the Articles 27, 31, 32, 36 and 44 of the Constitution of the People’s Republic of Bangladesh in the performance of their duties by abusing their official capacity.

IX. For that the Police have no lawful authority to raid and search the house, office and the Holy Dayera Sharif of the Petitioner nor they have any lawful authority without due process of law.

X. For that the impugned action of the Police force is violative of the fundamental rights of the petitioner as guaranteed by the Article 27/ 31/ 36/ 40 and 43 of the Constitution of Bangladesh.

XI. For that the Petitioner’s right to be endangered at home and office without entry, search and seizure except in due process of law is violative of the petitioner’s fundamental rights as guaranteed under Article 43 of the Constitution.

XII. For that since such action of raiding and searching the house of the petitioner and to arrest him without warrant is violative of his rights as guaranteed by the Constitution the impugned action is illegal, without lawful authority and is of no legal effect.

XIII. For that under Article 44 of the Constitution it is within your Lordships jurisdiction to ensure the petitioner’s fundamental rights under Article 102 (i) of the Constitution of Bangladesh.

XIV. For that unless the respondents are restrained from raiding the house and office of the petitioner and arresting him without any process of law in connection with only allegation relating to any specific case and or without any warrant the petitioner shall suffer irreparable loss, injury, harassment and humiliation. Wherefore, it is most humbly prayed that your Lordships would graciously be pleased to:

A) Issue a Rule Nisi calling upon the respondents to show cause as to why a proper and impartial high level Judicial inquiry or an inquiry by a high level administrative officials should not be ordered by the Government to be done against the respondents in connection with their misdeeds.

B) Why action of the respondents in raiding the house of the petitioner and attempting to arrest him without lawful authority or warrant shall not be declared to be illegal, without lawful authority and is of no legal effect;

C) Why the respondents shall not be directed to ensure that the petitioner is illegally harassed, arrested and secured at home and office against entry, search and seizure of his passport by the Police or any other person acting under their authority.

D) Why any entry and enquiry into the petitioner’s residence at the time of mid night again and again without any order of the Court of law should not be declared to have been made without any lawful authority and why they shall not be prevented from doing in future and be restrained from interfering in the privacy and sanctity of the house and office of the petitioner and why Taka 100 (one hundred) crores compensation should not be awarded to the petitioner for violation of his fundamental rights as guaranteed under Article 31 and 43 of the Constitution.

E) And after hearing the parties cause shown, if any and make the rule absolute and /or pass such other or further order or orders as to your Lordships may seem fit and proper to give relief to the petitioner and for ensuring the safety and security of the Nurullah WAQF properties of the Holy Dayera Sharif and Dayemi Complex Bangladesh and enforcing fundamental rights to property.

F) Pending hearing of the rule the respondents may be restrained from raiding the petitioner’s house, office and the aforesaid Holy Dayera Sharif and Dayemi Complex Bangladesh illegally and harassing and arresting the Petitioner without any warrant of arrest.

G) Award entire cost of the Petitioner. And for this act of kindness, your petitioner as in duty bound shall every pray.

AFFIDAVIT

I, Dr. Shah Sufi Hazrat Mohammad Nurul Alam, Son of Late Sirajul Islam of Holding No. 42/2, Azimpur Road (Holy Dayera Sharif), Police Station-Lalbagh, District-Dhaka, aged about 56 years, by faith- Muslim, by Profession-UN representative, by Nationality- Bangladeshi, do hereby solemnly affirm and say as follows:-

1. That I am Petitioner of this Writ petition and fully acquainted with the facts and circumstances of the case and as such I am competent to swear this affidavit.

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2. That the statements of facts made above are true to the best of my knowledge and matters of record which I verily believe to be true and rest are submission before this Hon’ble Court.

Prepared in my office.

________________________________________________

Advocate (Dr. Shah Sufi Hazrat

Mohammad Nurul Alam)

Deponent

The deponent is known to me and identified by me.

Solemnly affirm before me by

the said deponent on this the 5th

day of November, 2009 at.....

Advocate

COMMISSIONER OF AFFIDAVIT

SUPREME COURT OF BANGLADESH

HIGH COURT DIVISION

NOTICE

IN THE SUPREME COURT OF BANGLADESH

HIGH COURT DIVISION

(SPECIAL ORIGINAL JURISDICTION)

WRIT PETITION NO.: OF 2009

His Eminency Dr. Shah Sufi Hazrat Mohammad Nurul Alam.

-----Petitioner.

-VERSUS

The Secretary, Ministry of Home Affairs, Government of the People’s Republic of Bangladesh, Bangladesh Secretariat, Dhaka and others.

----Respondents.

To,

The Attorney General

Government of Bangladesh

Dear Sir,

Please take notice that an application under Article 102 of the Constitution of the People’s Republic of Bangladesh, will be file and moved before this Hon’ble Court (A copy enclosed herewith).

Advocate

For the Petitioner

IN THE SUPREME COURT OF BANGLADESH HIGH COURT DIVISION (SPECIAL ORIGINAL JURISDICTION)

WRIT PETITION NO.: OF 2009

Dr. Shah Sufi Hazrat Mohammad Nurul Alam.

-----Petitioner.

-VERSUS

The

Secretary, Ministry of Home Affairs, Government of the People’s Republic of Bangladesh, Bangladesh Secretariat, Dhaka and others

----Respondents.

SL NO:	ANNEXURES	Description of Paper	Dated	Page#
1. 1		Writ Pettition		01-55
2. 2	ANNEXURE – A Series	Photocopies of Biography and Vision of the Petitioner, Letter of Presidents of USA along with UN press release and UN ID Cards and correspondents of Prime Ministers of Bangladesh and Bangladesh Gazattes.
3. 3	ANNEXURE – B Series	Certified copy of the Judgment and Order of the Writ Petition No. 1875 of 2003 and Criminal Misc. Case No. 22296 of 2009.
4.	ANNEXURE ‘C’	Certified copy of Criminal Case No. 2049 of 2009.
5.	ANNEXURE ‘D’	Photocopy of the recommendation in the form of proposal by Mr. Justice Habibur Rahman Khan and Joint Secretary, Ministry of Education, Mr. Fazlur Rahman Khan.	25-09-1998
6.	ANNEXURE ‘E’	Photocopy of the report inquired by Mr. Mohammad Abul Kalam Azad, the Inspector of Police, Criminal Investigation Department (CID), Bangladesh	31-07-1999
7.	ANNEXURE ‘F’ Series	Photocopies of the most wanted Criminal Nurul Islam and Saleh Uddin Ahmed.
8.	ANNEXURE ‘G’	Certified copy of the Plaint of Money Suit No. 50 of 1999.
9.	ANNEXURE ‘H’ Series	Office orders and directions of the Ministry of Home Affairs.
10.	ANNEXURE ‘I’ Series.	Copy of the Notice of the Demand of Justice and Postal receipts

Advocate

For the Petitioner

ANNEXURE-“A” SERIES

as referred to paragraph No. 2 in this

Writ Petition is solemnly affirmed before me.

Commissioner of Affidavit

Supreme Court of Bangladesh

High Court Division

---------------------------------------------------------------------------------

ANNEXURE-“B” SERIES

as referred to paragraph No. 3 in this

Writ Petition is solemnly affirmed before me.

Commissioner of Affidavit

Supreme Court of Bangladesh

High Court Division

---------------------------------------------------------------------------------

ANNEXURE-“C” SERIES

as referred to paragraph No. 4 in this Writ

Petition is solemnly affirmed before me.

Commissioner of Affidavit

Supreme Court of Bangladesh

High Court Division

-6------------------------------------------------------------------------------

ANNEXURE-“D”

as referred to paragraph No. 5 in this Writ

Petition is solemnly affirmed before me.

Commissioner of Affidavit

Supreme Court of Bangladesh

High Court Division

---------------------------------------------------------------------------------

ANNEXURE-“E”

as referred to paragraph No. 8 in this Writ

Petition is solemnly affirmed before me.

Commissioner of Affidavit

Supreme Court of Bangladesh

High Court Division

-6------------------------------------------------------------------------------

ANNEXURE-“F”

as referred to paragraph No. 9 in this Writ

Petition is solemnly affirmed before me.

Commissioner of Affidavit

Supreme Court of Bangladesh

High Court Division

---------------------------------------------------------------------------------

ANNEXURE-“G” Series

as referred to paragraph No. 11 in this Writ

Petition is solemnly affirmed before me.

Commissioner of Affidavit

Supreme Court of Bangladesh

High Court Division

---------------------------------------------------------------------------------

ANNEXURE-“H”

as referred to paragraph No. 19 in this Writ

Petition is solemnly affirmed before me.

Commissioner of Affidavit

Supreme Court of Bangladesh

High Court Division

---------------------------------------------------------------------------------

ANNEXURE-“I” Series

as referred to paragraph No. 20 in this Writ

Petition is solemnly affirmed before me.

Commissioner of Affidavit

Supreme Court of Bangladesh

High Court Division

---------------------------------------------------------------------------------

ANNEXURE-“J” Series

as referred to paragraph No. 22 in this Writ

Petition is solemnly affirmed before me.

Commissioner of Affidavit

Supreme Court of Bangladesh

High Court Division

Press Release for Rokeya Begum Died With Fir of Pad - Dayemi Complex Bangladesh

Report for Sufi Nurullah Waqf Estate to Priminister