Anil Kumar Sinha, J. – The petitioner has filed the present writ application for the following reliefs: –

(i) For direction to the Respondent No. 2 to appoint an independent agency i.e. C.B.I. in view of law laid down by Hon’ble Supreme Court in the case of 1995 Cri.L.J.3612 for the purpose of registration of prosecution against the Respondents No. 6 to 11 for the offences punishable under Section 188, 191, 193, 203, 204, 211, 219 of I.P.C. read with Sections 120B and 34 of the I.P.C. and to proceed against them in accordance with law.

(ii) For direction to the Respondent No. 2 for initiating enquiry against the Respondent No. 6 to 8 in the matter of violation of provisions of law, and to take action against them.

(iii) For direction to the Respondent No. 1 to file and initiate contempt proceedings against the respondents police officers for disobeying the law laid down by the Hon’ble Supreme Court of India and this Hon’ble Court from time to time in the matter.

(iv) For direction to the Respondent No. 2 to immediate suspend the Respondents No. 6 to 8 for not performing their duties in the manner required;

(v) Pass appropriate directions to the Home Ministry/Respondent No. 1 to frame rules so as to avoid such false implications of citizens at the hands of corrupt criminal minded police personnels.

2. The brief facts giving rise to the present writ application as brought by the petitioner is that on 09.12.2015 the petitioner was married as per Hindu rites and rituals to one Gaurav Kumar, who is the son of respondent nos. 9 & 10. The petitioner alleges that at the matrimonial home she was subjected to torture, humiliation and harassment mentally and physically at the hands of her husband, who was involved in gambling, drinking liquor and having illicit relation with other woman, which would be evident from the complaint filed by the respondent no. 9 against her son. In the hope of reform of the conduct and behaviour of her husband, the petitioner tried her best to stay in her matrimonial home and during the course of her stay she gave birth to a female child on 13.10.2017. After birth of female child torture, harassment and humiliation upon the petitioner by her in-laws aggravated and the life of the petitioner became hell. She stated that at the instance of the respondent no. 6 (Nandoi of the petitioner), who is posted as A.S.P. (Vigilance Department, Patna) some police personnel without any lady constable and without following the procedure of law on 03.09.2019 at about 11:00 P.M. broke open the door where the petitioner along with her minor daughter was residing (matrimonial home). The Kotwali Police forcibly took away one 09 year old boy namely, Dheeraj Kumar, who is the son of the maid working in the matrimonial home namely Shakuntala Devi. Accordingly, an F.I.R. bearing Kotwali P.S. Case No. 406 of 2019 under Sections 342/ 323/370/370 (a)/374/353 of the I.P.C., Section 75 / 79 of the J.J. Act and Section 14 (a) of the Child and Adolescent Labour Act was lodged against the petitioner.

3. The petitioner contends that in order to compel her to withdraw all cases filed by her against her in-laws, the respondent nos. 6 to 11 hatched a conspiracy and in execution of the same the boy Dheeraj was abducted by Kotwali Police so that petitioner and her family members can be dragged in a false and frivolous case. The petitioner relies upon Annexure P-4 i.e. conversation between local Kotwali Police and the respondent no. 6 in support of her allegation. The mother of the abducted child moved an application for custody of her son before the C.J.M., Gaya in Kotwali P.S. Case No. 406 of 2019 wherein the court on 04.10.2019 directed the I.O. to release the child in favour of the mother. The petitioner had made an application on 09.10.2019 regarding the said incident to S.S.P., Gaya. She filed several representations and complaints before various authorities which are annexed at Annexures-12 to 19 of this writ application. There are series of lit