Lakhs of cases are to filed across the country.
Complainant prays for prosecution of accused under section 420, 409, 166, 115, 167, 336, 337, 338, 341, 342, 153-A, 505, 120(B) & 34 of IPC and Section 4, 7 & 9 of Drug & Magic Remedies Act, 1954.
Other accused are Sh. Iqbal Chahal, Municipal Commissioner, Mumbai, Sitaram Kunte, Ex-Chief Secretary, MCGM, Dr. V.K. Paul, AIIMS, New Delhi, Dr. Randeep Guleria , Ex-Director, AIIMS, New Delhi. Dr. V.G. Somani, Drug Controller General of India, New Delhi, Shri Suresh Kakani, Ex- Additional Commissioner, MCGM, Smt. Kishori Pednekar Ex-Mayor, Mumbai, Dr. Sadhna Tayde Director of Health Services, Public Health Department, Smt. Amisha Bhoir Aasha Worker, R/C Apex Hospitals, Mumbai, Smt. Joslin Aasha Worker, Ambedkar Nagar, UPHC, Palghar
Complainant requests for issuance of non-bailable arrest warrant against all the accused.
The Complainant is represented by Advocate Ishwarlal Agarwal, Tanveer Nizam, Vijay Kurle, Abhishek Mishra, Hania Shaikh, Sohan Agate, Snehal Surve, Sourav Khanna, Vikas Pawar, Joy Sarkar, Aashish Ingle and around 100 advocates of Indian Lawyers Association are likely to attend the hearing before the court.
Leading Bar Associations like Indian Bar Association, Supreme Court Lawyers Association, extended their support to the victim law student.
The main grevience of the Complainant Ayush Tiwari is that all the accused have conspired with each other and compelled the citizen and him to get faulty covishield vaccine by bringing unlawful vaccine mandates against unvaccinated people and parallelly running the false narrative that covid vaccines are completely safe and if there is any side effect then there is definite treatment available for it.
In fact due to death causing side effects of covishield vaccine, it was banned in 21 European Countries since March 2021.
Government of India also admitted that Covishield and other vaccines are causing death . Many youngsters are dying due to heart attack, Myocarditis, Cardiac arrest and it is the side effect of covid vaccines.
Japan, Canada & other countries have issued advisory for it. But accused officials in India acted for the welfare of vaccine companies and instead of banning said vaccines had forced the people to get the vaccines and suppressed its side effects.
Already Supreme Court & Bombay High Court had declared that the vaccine mandates issued by the Maharashtra State through then Chief Secretary Sitaram Kunte are unlawful and violated the fundamental constitutional rights of the Citizen.
The Concluding paragraph & charge in the complaint & Prayer reads thus;
“54. CHARGE
54.1. The documentary proofs and public documents make it ex-facie clear that all the accused were well aware about the death causing side effects of the COVID-19 Vaccines.
54.2. As per Central Government’s guidelines for COVID-19 vaccination, and also as per the law of ‘informed consent’, as well as the specific law laid down in the case of Master Haridan Kumar Vs. Union of India 2019 SCC OnLine Del 11929, the accused were duty bound to publish information regarding all the possible side effects of vaccines.
Secondly, the person/ Doctors/ AASHA workers, etc. who were working at the vaccination centers were duty bound to give information about all possible side effects in simple and clear language understandable to the complainant at the vaccination center before vaccinating him. This was clearly mentioned in the guidelines issued in the case of Montgomery Vs. Lanarkshire Health Board [2015] UKSC 11.
But, the abovementioned rules and guidelines were not followed.
54.3. On the contrary, the accused ran the false narrative that the COVID-19 Vaccines are completely safe and if there was any side effect, then there is a definite treatment available for the same. The Frequently Asked Questions (FAQ) published and circulated by the state government (Exhibit___) and the accused No 3 Dr. Randeep Guleria, and Co accused, Dr. V.K. Paul (Exhibit___) are sufficient proofs of their malafides, falsity and dishonesty.
54.4. The above-mentioned public documents have ex-facie proved that the accused have conspired with each other, with a common intention of vaccinating the citizens, including complainant under deception and cheating. In order to fulfil their ulterior purposes, the accused had suppressed and concealed the death causing and other side effects of the COVID-19 vaccines and made false statements as assurance to public that the said vaccines are completely safe and if there is any side effect, then there is a definite treatment available for it.
This assurance was made with a malafide intention to persuade people to get vaccines and to put their lives in danger, and to give wrongful profit to vaccine companies. And also to cause a loss of thousands of crores to public exchequer. They misappropriated public money and property for unlawful purposes.
54.5. In furtherance of the said malafide intention, the accused No. 5: Iqbal Chahal, accused No.6: Sitaram Kunte, accused No. 7: Suresh Kakani ran a false narrative that the unvaccinated people are a threat to the society and they also brought unlawful vaccine mandates, so that unvaccinated people should not be allowed to move freely in Maharashtra and thereby not be able to earn their livelihood.
The accused tried to the best of their levels to implement the said unlawful mandates so that many citizens including the complainant were compelled to get the said COVID-19 vaccines against their wills and under the deception of its safety. The accused were well aware about the falsity, dishonest, malafides, illegality and unconstitutionality of the said mandates and narratives.
54.6. Under force and deception, the complainant took the said vaccines.
The first dose of vaccine was administered on 19th August, 2021 and the second on 11th November, 2021.
54.7. That all such mandates issued by the accused were declared unlawful, illegal and unconstitutional by the Hon’ble Supreme Court and the Hon’ble High courts. The Hon’ble Bombay High Court passed strong strictures against the accused Sitaram Kunte & Ors.:
(i) Feroze Mithiborwala v. State of Maharashtra, 2022 SCC OnLine Bom 356
(ii) Feroze Feroze Mithiborwala v. State of Maharashtra, 2022 SCC OnLine Bom 457
(iii) Madan Mili v. Union of India, 2021 SCC OnLine Gau 1503
(iv) Jacob Puliyel v. Union of India, 2022 SCC OnLine SC 533
54.8. Soon after taking the first dose of the vaccine, the complainant developed a severe head pain. He asked about it to the local doctor, but he did not get any relief. The said head pain had slightly increased after the second dose.
54.9. After making an inquiry at various levels, the complainant got to know that on 26th September, 2022, the Ministry of Health and Family Welfare had published new FAQs. Where it is mentioned that the continuous head pain is a side effect of the COVID-19 vaccine and that it can be considered to be a starting point of more severe side effects of TTS (Thrombosis with thrombocytopenia).
54.10. The complainant also got to know that, one doctor Snehal Lunawat died after taking the Covishield vaccine due to the side effects of TTS, and the Government of India also admitted that her death was due to the side effects of the Covishield vaccine.
54.11. It is also part of the record that due to death causing side effects the covishield (Astrazeneca) vaccine was banned in around 21 European countries since March 2021.
54.12. The surprising and shocking part for the complainant is that the accused have not adopted the same policy of banning and stopping said vaccines in our areas to safeguard the life and liberty of the citizen including complainant. On the contrary the accused have misused their position and public machinery, property and entire system to force the citizen to get said deadly vaccines. This is a worst kind of offence against entire humanity and requires severe punishment to the accused.
This is a clear offence of mass murders (genocide).
54.13. That Dr. Aseem Malhotra, UK had in his recent tweet also requested our Hon’ble Prime Minister to ban covishield vaccines. Said tweet reads thus;
“BREAKING:
700 million Indians currently are yet to take covid vaccine booster amid concerns of major harms
I call on the Indian prime minister @narendramodi to immediately halt Covishield jab (Astra Zeneca)
because we suspended it in the U.K. due to ‘’horrific side effects”
Link: https://twitter.com/draseemmalhotra/status/1610000507032018947
54.14. That the recent research had created further fear in the mind of complainat that because of possible side effects of vaccines the complainant’s life is indanger and he may die anytime due to cardiac arrests, myocarditis, heart attack, blood clotting, cancer etc.
54.15. The research from Harvard University had proved that the covid vaccines are 98 times worse than the covid disease. [Exhibit_____]
54.16. Research proved that the vaccine increases the chances of cancer by 10,000%. [Exhibit____]
54.17. That data and research had shown that every dose of vaccine increases chances of death. [Exhibit___]
Link:–https://expose-news.com/2022/09/30/5-months-to-kill-covid-vaccination/
54.18. That there is a tremendous increase of deaths amongst young vaccinated people due to heart attacks. The research had proved that it is due to side effects of covid vaccines.
Link: – https://expose-news.com/2022/05/17/covid-jabs-increase-risk-heart-attack-death-young-adults/
54.19. The Japan government made companies of Covid “vaccines” to warn of dangerous and potentially deadly side effects such as myocarditis. In addition, the country is reaffirming its commitment to adverse event reporting requirements to ensure all possible side effects are documented.
https://rairfoundation.com/alert-japan-places-myocarditis-warning-on-vaccines- requires-informed-consent/
Alert: Japan Places Myocarditis Warning on ‘Vaccines’ – Requires Informed Consent Amy Mek.
54.20. That on 9th November, 2021 Canada’s Health Department also warned about side effects on Covishield:
“Health Canada adds autoimmune disorder warning to AstraZeneca, J&J COVID-19 vaccines
Health Canada is updating the labels for the AstraZeneca and Johnson & Johnson COVID-19 vaccines to add immune thrombocytopenia (ITP), an autoimmune condition, as a potential side effect.”
54.21. That WHO on 26th July, 2021 also warned people about GBS caused due to Covishield.
Link:-https://www.who.int/news/item/26-07-2021-statement-of-the-who-gacvs-covid-19-subcommittee-on-gbs
54.22. But then also the accused are promoting booster doses of vaccines. It shows that the accused are having their loyalty and allegiance to the vaccine manufacturers and not to our nation and its citizens and for that purposes and also for some more ulterior purposes of killing people at mass level the accused are hell-bent upon vaccinating people with deadly vaccines by deception & force.
54.23. More surprising and shocking part of entire conspiracy is the callous criminal attitude of accused No. 1 Adad Poonawalla, CEO of Serum Institute and all its directors, office bearers etc. as can be seen from the very fact that despite all these proofs and research, they have filed an affidavit before Hon’ble Bombay High Court on 17.10.2022 stating that their vaccines are completely safe. This is a sufficient ground to prove their complicity in the entire conspiracy to kill people and put life of citizen in great trouble by vaccinating them by cheating, deception and force to serve their ulterior purposes.
54.24. Hence, the life of complainant is put in danger by all the accused and therefore, they are liable to be punished severely and they are also liable to pay compensation of Rs. 100 Crores to the complainant which is in tune with the compensation criteria and legal position as mentioned in preceding paragraphs.
54.25. Hence, all the accused are liable to be prosecuted and punished under section 166, 167, 52, 115, 109, 420, 336, 307, 302, 469, 120(b), 34 etc. of Indian Penal Code.
54.26. The offences committed by the accused are not the part of their official duty and infact it is a breach of trust and fraud with the nation. Hon’ble Supreme Court had ruled that in such cases no sanction is required to prosecute such accused officials. All the judgements and precedents of Hon’ble Supreme Court are mentioned in the preceding paras.
54.27. That as per constitutional mandate and our democratic set up every citizen is paying tax to pay huge salary to all public servant with only expectation that they should work as per law and for the welfare of the public. But the accused breached the said trust and by taking salary from citizen they worked for the welfare of vaccine companies and therefore they are liable to be punished more severely than any common accused.
54.28. That from the various research papers, sero survey conducted by the government it was proved that: –
(i) More than 90% of the Indian got natural immunity due to their coming in contact with the virus either due to infection or otherwise.
(ii) The said immunity is 13 to 27 times (1300 to 2700%) better and robust than the vaccines.
Link: – https://www.doublehelical.com/?p=5551
(iii) The protection by natural immunity is life long while covishield protection is only for three months.
(iv) Giving vaccines to persons with natural immunity is proved to be causing more harm to their body. It is providing no additional benefit.
Link: https://www.mdpi.com/20751729/11/3/249/html
(v) Hence recommending or giving covid vaccines to the people with natural immunity is misappropriation of thousands of crores of public money, property and machinery. It is also offence of intentionally causing grievous hurt or putting life of that person in to danger. It is a clear offence under section 409, 115, 420, 302, 336, 304-A, 420 (B), 34 etc. of IPC.
(vi) But then also accused officials were issuing circulars, orders, directions etc to ensure 100% vaccination and it is a sufficient proof of bigger conspiracy at higher level and involvement of officials up to highest level.
(vii) The conspiracy and nexus of officials of ICMR, DCGI and vaccine mafia is exposed by the Government of India in a Parliamentary committee in its 72nd report.
54.29. It is also shocking and surprising that when the vaccines were given only Emergency Use Authorization then how and why the accused were pressurizing for vaccination of all citizens. This is a clear case of putting the lives of the masses into danger by way of nonsensical acts.
54.30. The plan to vaccinate 100% of the population is an offence of destroying evidence and control groups required for medical research that, whether unvaccinated people are doing better or what is the actual efficacy of vaccines or if there are side effects then possible harm to majority population can be saved by banning further vaccination.
54.31. The research had proved that the countries/districts/areas with less or no vaccination were more safe than the vaccinated.
It shows that more vaccinated areas are having more corona waves and more deaths.
54.32. That is the reason that more than 77 Crore Indians refused to get their booster doses.
54.33. Hence, the offence committed by the accused is most heinous crime in the entire history and all the accused are liable to be punished for maximum punishment.
55. PRAYER: – It is therefore humbly requested that this Hon’ble Court may please to: –
(a) conduct enquiry under section 202 of Cr.P.C. and allow the complaint to produce witness, evidence etc.
(b) pass an order of issue of process under section 204 of Cr.P.C. against all the accused for offences under section 166, 167, 420, 115, 336, 120(B), 34 etc. of IPC.
(c) Issue warrant of arrest (Non-Bailable) against all the accused under section 204 (1) (b) of Cr.PC.
(d) try and punish all the accused for maximum punishment;
(e) grant compensation of Rs. 100 crores to the complainant under section 357(3) of Cr. P.C.
(f) grant any other relief to the complainant which this Hon’ble court deems fit and proper in the facts and circumstances of the case;”
