Ref. No………… Dated: 14.03.
2024
LEGAL NOTICE (Reminder Notice)
To
SHO,
Varikuntapadu,
Nellore, Andhra Pradesh.
Subject:
Since the violations of below points has taken place at jurisdiction of Sitaram Puram Mandal Police
and Udayagiri Circle Inspector on 22nd September 2023 10 PM to 23rd September 2023 10 PM, this
Legal notice is being served under the instructions and on behalf of our client NGO named
Vivekananda youth, Udayagiri, Nellore.
The violations of below points are:
1. Article 21: No person shall be deprived of their life except according to the procedure
established by law.
2. Article 19(1)(a): All citizens shall have the right to freedom of speech and expression or press
3. Article 19(1)(b): All citizens shall have the right to assemble peaceably and without arms.
4. Article 19(1)(d): All citizens shall have the right to move freely throughout the territory of
India;
5. Article 19(1)(g): All citizens shall have the right to practise any profession, or to carry on any
occupation, trade or business.
6. Article 22(1): No person who is arrested shall be detained in custody without being
informed, as soon as may be, of the grounds for such arrest nor shall he be denied the right
to consult, and to be defended by, a legal practitioner of his choice.
7. Civil Rights violation
i. Excessive use of force
ii. Unreasonable use of force
8. Publicly Flogged the stick by the police personals before a crowd.
and Honourable Supreme court guidelines, NHRC guidelines by Police personals i.e C.I and
S.H.Os at Udayagiri circle inspector jurisdiction.
Respected Sir/Madam,
With a view to maintaining peace and harmony,
From 22nd September 2023 10 PM to 23rd September 2023 10 PM we have evidences that all
the above-mentioned human rights were completely violated under the jurisdiction of Sitaram
Puram Mandal Police and Udayagiri Circle Inspector. Since you are a SHO, Varikuntapadu and
directly or indirectly involved in that crime scene place/incident place is under
Seetharampuram jurisdiction. Therefore, we seek answers to the above questions from you.
Therefore, we are bringing this matter to your notice and my client is expecting some
information from you or your police department in public interest. We request you to answer
the following questions.
1. Are you fully aware of this matter? If so, what kind of understanding is do you have?
2. Did the police officers there give you full information about the incident that happened
that day?
3. Date of occurrence 22th September 2023, what information was given to you about the
event of that day? Who gave the information?
4. What are the orders you have given to the following officers under your jurisdiction?
5. How many policemen were there from your Police station, on that occasion/situation and
on that night, in that place?
6. How many policemen have reached there i.e total police personals from your station?
7. Who are those police personals went to the Seetharampuram incident place, specify the
names please?
8. When were civil policemen have reached there? Reached in what time?
9. Did they carry any weapons?
10. At what time did they start duty there?
11. How many hours did you do duty on that situation?
12. Why did so many police personals have been used force in Seetharampuram incident place
mandal?
13. How many people were taken into custody that night?
14. Why did Seetharampuram mandal roads block with police and special forces?
15. On whose orders the special force was called, do you know?
16. At what time the special force was called, do you know?
17. At what time the special force has been reached?
18. At what time the special force has been started their duties?
19. Are your superiors fully aware of this incident? Did you inform?
20. Did the policemen come from any other police stations apart from that circle?
21. How many people were in police custody that night?
Note:
Since you are a circle inspector you stayed at crime scene place and witnessed the incident that night.
1. If you are not the SHO, Varikuntapadu of the day i.e 22 september 2023, you will be able to
gather information from the person who worked as a show there before you. You will be able
to recognize that this information is in the public interest.
2. If you are not the SHO, Varikuntapadu today, you can share the answers of the above
questions to the person who is now working there as a SHO. You will be able to recognize that
this information is in the public interest.
Therefore, we seek answers to the above questions from you. Failing this, we hereby inform that these
actions will be challenged in Honourable court through a Public Interest Litigation against the Police
Department and concerned police personnel.
You can write reply to us by mail or through WhatsApp or by hand and take photos and send it to us
through any communication medium. Early response is very much appreciated. You can write reply to
us by mail to [email protected] or through WhatsApp to +916361773377 or by hand
and take photos and send it to us through any communication medium. Early response is very much
appreciated.
Copy to:
DIG, Guntur,
Superintend of police, Nellore,
DSP, Kavali.
Suresh
Advocate
