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IN THE HON’BLE SUPREME COURT OF INDIA

(Civil Writ Jurisdiction)

WRIT PETITION (CIVIL) No. 1163 OF 2017

(Under Article 32 of the Constitution of India)

I THE MATTER OF:

1 Atul Kumar
S/o- Late Sh. Om Prakash Mittal,
R/o-7C, Block-D, Ideal Towers,
57, Diamond Harbour Road,
Kolkata-700023, W.B. ………………. Petitioner No.1
2. Shantanu Guha Ray
S/o-Late Sh. Nripen Guha Ray
R/o-B-385, second Floor,
Chittaranjan Park, New Delhi ……………… Petitioner No.2
…
//Versus//

1. Union of India
Through Ministry of Home Affairs
Through its Secretary
North Block, Cabinet Secretariat, ……………….. Respondent No.1
Raisina Hill, New Delhi - 110 001
2. Ministry of Youth Affairs &
Sports
Through its Secretary
Shastri Bhawan, ……………….. Respondent No.2
Dr. Rajendra Prasad Road,
New Delhi-110001
3. The Board of Control for Cricket
in India (BCCI)
Through its President
Wankhede Stadium,
Church Gate, Mumbai
Maharashtra ……………….. Respondent No.3

A PUBLIC INTEREST LITIGATION UNDER ARTICLE 32 OF THE

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CONSTITUTION OF INDIA PRAYING FOR CONTROLLING ON-

GOING MASSIVE PUBLIC FRAUD AND CRIME THROUGH

INSTITUTIONALIZED FIXING IN CRICKET BY STAYING IPL AND

OTHER LEAGUES LIKE TNPL, KPL ETC AND OTHER

INTERNATIONAL CRICKET MATCHES IN THE COUNTRY, AND BY

APPOINTING A SUITABLE SPECIAL INVESTIGATING TEAM TO

UNEARTH THE ENTIRE MODUS OPERANDI AND TO BRING ALL

THE CULPRITS TO BOOK UNDER VIOLATION OF ARTICLE 21 OF

THE CONSTITUTION OF INDIA.

To,

The Hon’ble the Chief Justice of India and His Companion Justices of

the Supreme Court of India.

The Humble petition of the

petitioners above-named

MOST RESPECTFULLY SHOWETH:

1. That the Petitioners are filing the present writ petition in public

interest. The petitioners have no personal interest in the

litigation and the petition is not guided by self-gain or for the

gain of any other person/institution/body and that there is no

motive other than of public interest in filing the writ petition.

1A. That Details of Petitioner No.1: Name: Atul Kumar, S/o-Late

Sh. Late Sh. Om Prakash Mittal, Postal Address-7C, Block-D,

Ideal Towers, 57, Diamond Harbour Road, Kolkata-700023, West

Bengal, E-mail:-atulrailway@hotmail.com, Mob.

No.09433064810, Occupation-Retired Government Servant,

Annual Income:Rs.16,45,000/- (Rupees Sixteen Lakhs Forty Five

Thousand only), PAN No.AJIPK4507H, AADHAR

No.919120835957.
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Details of Petitioner No.2-Name: Shantanu Guha Ray S/o-Late

Sh. Nripen Guha Ray Postal Address-B-385, Second Floor,

Chittaranjan Park, New Delhi, E-mail:

shantanunewshound@gmail.com, Mob. No.9871096625,

Occupation-Journalist, Annual Income-Rs.25,00,000/- (Rupees

Twenty Five Lakhs only), PAN No.AEGPG6344H, Passport

No.Z2246087 dated 09.07.2014.

There is no civil, criminal or revenue litigation involving any of

the petitioners which has or could have a legal nexus with the

issues involved in this public interest litigation.

2. That the petition, if allowed, would benefit the citizens of this

country generally as rule of law is essential for democracy and

such brazen violation of law by the respondents can be stopped

by the orders of this Hon’ ble Court only.

3. That the persons affected by such acts of the State are

numerous and are not in a position to approach the Hon’ble

Court; hence, the Petitioners being aware and informed citizens

are filing the present Public Interest Litigation (PIL) on behalf of

such affected persons.

4. That this is a public interest petition that will bring to fore a

monstrous open day light public fraud, continuing for over a

decade and lying exposed and proven for years. And yet the

fraud continues with all the glory and all the shamelessness.

Because this is a fraud of proportions incomprehensible for

normal mind, and of magnitude unimaginable, nurtured by the

political power and facilitated by the media. Top industrialists,

celebrities and Haves of the society, some knowingly some

unknowingly, are its backbone. The masses, in their ignorance,

support this fraud and not only applaud the perpetrators but

treat them as heroes and super heroes. All the law enforcing
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agencies continue to look the other way. Yet, a fraud it

is–massive and highly injurious to the society with very grave

implications. The petitioners are talking about cricket.

5. That the Petitioner No.1-Atul Kumar has been crusading against

systemic corruption for last decade or so. A postgraduate in Civil

Engineering, while working in the Indian Railways at joint

secretary level, he was instrumental in exposing estimated

annual loss of Rs 5000 crores through procurement in this public

organization. This loss was later on seconded by the Metro Man

E. Sreedharan in a report on Railways. Consequent to aforesaid

exposure by Petitioner no. 1, his interview with Mr Shiv Karan

Singh, Principal Correspondent, was published in The Statesman

dated 12 August 2010 in the most prominent columns under the

heading ‘Bureaucrats are both running and ruining the country.’

He was awarded the national level award ‘S R Jindal Prize –

2011’ for 'Crusade against Corruption' for his efforts. He has

penned incisive poems and books. His interest in cricket and

subsequent knowledge about betting in cricket led him to pen an

extra-ordinary reality fiction ‘Inside the Boundary Line’ which for

the first time brought out the obscure and intricate relation

between betting and institutionalized fixing in the game of

cricket. Subsequent to publication of this book in November

2012, through a Press Conference in Kolkata on 28th Jan, 2013

and publication of his interview in Deccan Chronicle/Asian Age on

27th Jan, 2013, he told the world with absolute clarity that cricket

was institutionally fixed, even commentators being a part and

parcel of the fraudulent set up. He then went on to crusade

against this massive public fraud through books, press

conferences and communications with all the concerned

authorities and media, continuing the same till date. His other
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books on the subject are ‘Bettors Beware (match-fixing in cricket

decoded) (non-fiction)’, republished with the title ‘All Cricket

Matches are Fixed’, and ‘Cricket: The Massive Fraud.’ The latter

book has been translated and published in Hindi as well as some

regional languages. His latest book on the subject ‘Underworld

Cup (Media, Modis, Mudgals, Mamatas All dial Dawood)’ detailing

fixing in matches of T20 World Cup, 2016 was published last

year. He continues to share insights on fixing in cricket matches

across the world through his posts on facebook page

‘https://www.facebook.com/BettorsBeware/’ off and on.

6. That the Petitioner No.2-Shantanu Guha Ray is an internationally

awarded Wharton-trained journalist based in New Delhi. His

awards include Ramnath Goenka Award, 2014, Overseas Press

Club of America Award for best online investigation, 2011,

Columbia School of Journalism Award for investigative reporting

from India, 2011, World News Conference Award, Beijing, 2010,

Freedom of Expression Award, Oslo, April, 2010, Wash Award for

reporting on water, 2008, and John Sheenan Award, Wharton Biz

School, 2008. He is the India editor for Central European News,

one of the fastest growing wire agencies in Europe. For almost

three decades, he has served both print and the electronic

media. Some of his milestones include scooping the billion-dollar

coal scam, arguably India’s biggest scandal till date. He scooped

it in October 2011 – much before the Indian newspapers picked

up the CAG report – while working for India Today, where he

also scooped the Delhi airport scam. His cover for Tehelka on

lobbyists in New Delhi is still considered a yard stick in reporting

on a profession still not recognized by the Indian government.

His news report on India’s only female don in Varanasi for New

York Times was among the top trending stories of the daily
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across the world in 2014. He also scooped India’s cervical cancer

injection scandal, which was pushed by the previous UPA

government under a dubious program pushed by Bill and Melinda

Gates Foundation. The Supreme Court has now banned the

program, as a result of his report. He was awarded the Laadli

Media trophy for this expose. A crusader at heart, Shantanu had

also scooped a big one – during his days at Outlook – on how

Indian television channels were fudging TRP records by placing

extra television sets and people’s meters at homes of selected

people. His reporting on India’s tobacco racket, blood diamonds

earned him many global awards, so did his work on the dangers

of asbestos.

Briefly, he flirted with sports, and headed the news team of

ESPN in India, travelled across the world to cover cricket and

was instrumental in introducing Saurav Ganguly and Mahendra

Singh Dhoni to television as ESPN guest anchors. His first book,

Mahi, a biography of the Indian cricket captain did good sales in

2013. His next book ‘Fixed! Cash and Corruption in Cricket’ on

match-fixing and illegal betting, hit the stands in March, 2016.

This book chillingly lays bare the murky world of cricket betting

and fixing over the years that lies hidden from the public eye

under the glare of 4’s and 6’s by its idols. The book brings out

through plethora of known and unknown real events and hard

facts how fixing and corruption in cricket have been prospering

with the blessings of all who matter. His other books ‘Target’ and

‘Found Dead’ are other milestones in investigative journalism.

7. That the brief facts leading to the filing of the present petition

are detailed herein below:

8. That in July 2015, in C.A. No. 1155/2015 the Hon’ble Supreme

Court-appointed Justice Lodha Committee decided to suspend

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Chennai Super Kings and Rajasthan Royals franchise of the IPL

for two years in its verdict on the 2013 betting and spot fixing

scandal. The committee also banned former Indian cricket board

president N Srinivasan's son-in-law Gurunath Meiyappan and the

co-founder of Rajasthan Royals Raj Kundra for life. Prior to

findings of Lodha Committee, Mudgal Committee is known to

have also submitted a sealed envelope to Hon’ble Supreme Court

in February, 2014 containing names of 13 individuals including

some IPL players suspected of being involved in fixing of

matches for further investigations. As per media

reports/rumours that time, names of star players M S Dhoni and

Suresh Raina were among those 13 names. While the public

remains unaware as to identity of all those names and what

happened further with regard to those names, it is now known

from the matter brought out in this petition that those few

names are immaterial, everyone being involved. Fixing of

matches in IPL has continued till last IPL–IPL 10. Betting on

cricket matches is as rampant as it could be and match fixing in

cricket is not sporadic but total. Though the following reported

tweet by veteran cricketer Bishen Singh Bedi after above

decision by Lodha Committee did not exactly sum it up but said

a lot: "Justice Lodha Committee after Justice Mudgal findings

comes as breath of fresh air, but only just! There's more muck fr

Crkt 2 breathe afresh!" The cricket has continued to be as

impure as ever, if not more, though Justice Lodha is on record

having said that purity of game was the theme of Committee’s

report. Banning two IPL teams for two years and two team

owners/team executives for life was nothing more than taking a

few muddy drops out of an ocean full of mud and muddy water,,

leaving the stinking ocean as such.

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9. That Petitioner No.2 has also expressed thus about the Mudgal

and Lodha Committees in his book ‘Fixed! Cash and Corruption

in Cricket’:

“I almost fell from the chair. The thought had not struck me

earlier. Two high level probes, yet investigations had revealed

little, skimming just the surface and nabbing the small fry.”

10. That it will not be wrong to say that today cricketing legends,

cricket experts, cricket broadcasters, cricket commentators and

cricket journalists are acting akin to drug peddlers selling fake

cricket for the benefit of the betting syndicates to the gullible

masses hooked on to it. One will know this for sure after one has

gone through the contents of this petition. But there is a marked

difference. While drug peddlers are looked down upon by the

society, many of those selling fake cricket are media and social

media darlings and heroes and super heroes for the masses and

intelligentsia alike. While the government and the establishment

punish the drug peddlers and send them to the prisons, those

manufacturing and selling fake cricket are honoured with

country’s highest awards. All this is substantiated from what

already lies in public domain and will get crystal clear to any

open and intelligent mind that goes through this petition.

11. That many may tend to say what is so big if cricket, after all

just a game, is fixed, especially if it continues to entertain people

and cricket viewers no end. What if punters lose money and

become paupers because of fixed matches? They are the sinners

and what if they suffer? Why should they bet? People would be

thinking as they do because they are ignorant. They are ignorant

of various implications of this continuing massive fraud. And a

few who are not that ignorant, feel happy to ignore the

implications. As it will be seen, most of the implications are very

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serious, some serious beyond normal imagination. The whole

country is adversely affected by this continuing massive fraud.

12. That years ago, Rashid Latif, the ex Pakistani wicket keeper

batsman and also the captain later on, brought out the link and

correlation between session betting and fixing in an article dated

24/7/2010 and titled ‘How cricket matches are scripted’

published on website espncricinfo.com. The world in general and

those concerned with cricket in particular appear to have

conveniently ignored and forgotten all that was brought out

through this article.

A true copy of the article dated 24/7/2010 by Rashid Latif is

annexed herewith along with true typed copy and marked as

ANNEXURE-P/1.

13. That years ago in November, 2011 and years after the match,

Vinod Kambli, a famous cricketer and a member of the Indian

team, had alleged through media that the 1996 World Cup

semifinal between India and Sri Lanka was fixed. The news item

titled ‘Team-mates deny Kambli allegation’ dated 18/11/2011

published by same website espncricinfo brings this out. All

others, his team mates, BCCI, and even some cricket journalists

combined to condemn Kambli. That was it. Days or hours after

such a sensational revelation, no one ever talked about or heard

of this matter. No investigations took place.

A true copy of the article ‘Team-mates deny Kambli allegation’

dated 18/11/2011 is annexed herewith along with true typed

copy and marked as ANNEXURE-P/2.

14. That in due course of his life Petitioner No.1 very well

understood the correlation between session betting and play in

field in the cricket matches being broadcast and bet upon.

Application of common sense made him understand that fixing in

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cricket was not sporadic but continuous and total and that

cricket being played and telecast was institutionally fixed and

only a drama. The world was largely unaware about that truth.

This motivated him to write a reality fiction ‘Inside the Boundary

Line’ to make the world aware. The book dealt with all the

intricacies that arose out of this explosive truth. He was being

considered mad by his nears and dears but had full confidence in

his common sense and rational thinking. Subsequent to

publication of the book, he held a press-meet at Kolkata on

28/1/2013 to share the truth with the world. Before that he was

successful in contacting a cricket journalist Mr Bipin Dani through

twitter. His interview to Mr Bipin Dani breaking the truth about

institutionalized fixing of cricket to the world was published in

Deccan Chronicle and Asian Age dated 27/1/2013. The same is

self explanatory.

A true copy of Interview of Petitioner No.1 published in Deccan

Chronicle and Asian Age dated 27/1/2013 is annexed herewith

along with true typed copy and marked as ANNEXURE-P/3.

15. That here the petitioners shall try to summarize how cricket

betting and fixing go hand in hand as briefly as possible. It is as

simple as it is amazing. First of all it is to be understood and

appreciated that it is same cricket whether one is betting on it or

not. If bettors find cricket fixed, it is so for rest of the viewers

who aren’t betting on cricket and know nothing about betting.

16. That in cricket, on other than outcome of a match, large scale

betting is also going on, both in legal and illegal betting markets,

on number of runs to be scored in a set of overs, in all the

formats. This set of overs is called session. This is known as

session betting or bracket betting. The betting is dynamic as for

match result, i.e. odds are changing or may change after every
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ball depending on the outcome of that ball. Existence of

session/bracket betting has been reported in the media from

time to time and is borne out by number of tweets by various

twitter accounts as brought out subsequently in this petition.

Session betting as in illegal betting markets is now taking place

in on online betting sites also along with bracket betting. So no

one can question its existence.

17. That the very existence of session or bracket betting in a cricket

match should suffice to tell that the cricket was institutionally

fixed, if one understood the basics of session betting and applied

mind a bit. Even the awarded British journalist Edward Hawkins,

considered as an expert on cricket betting internationally

understood this and agreed to it when this was explained to him

by Petitioner No.1 through email in the year 2013. Since public

at large doesn’t know anything about session betting or even its

existence, it remains ignorant of the continuous fixing associated

with it while enjoying the thrills of 4’s and 6’s or of tumbling

wickets. People feel elated when their team wins and feel

depressed when it loses, oblivious of the fact that the result was

already fixed between the two teams. They just enjoy the thrills

of the game, some matches specifically being scripted to make

cricket look very thrilling, ignorant of what all goes behind the

scenes. They don’t know that there was a fixed match behind

headlines such as ‘India thrash Pakistan’ or ‘Zimbabwe shock

Australia’.

A true copy of email interaction of Petitioner No. 1 with Edward

Hawkins in May 2013 on session betting is annexed herewith

along with true typed copy and marked as ANNEXURE-P/4.

18. That the very existence of session betting in cricket makes

continuous institutionalized fixing in cricket necessary. Simply

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put, both in legal and illegal betting markets, betting on runs to

be scored in a set of overs so proceeds that if players were

playing competitive cricket oblivious of the betting going on as

they are supposed to be, the bookies and betting syndicates

could and would lose big money match after match, session after

session, and bettors could mostly make money simply by betting

on sessions or brackets. If it happened so, betting syndicates

and bookies would have gone bankrupt long ago and session

betting would have ceased to exist. Petitioner No.1 has proved it

mathematically or scientifically with the most objective

application of basic principles of probability in his book ‘Bettors

Beware’. The petitioners are sure that the Hon’ble Court would

agree that mathematical and hence scientific proof does not

require any Court to declare it as ‘proved’. It could be contested

by anyone mathematically or logically and proved wrong, but no

one has done so till date though its existence has been

repeatedly brought to the notice of the world, BCCI and ICC, and

the government agencies for last three long years through press,

social media and directly by Petitioner No.1. On the contrary,

those who examined it/got it examined found it to be correct, as

would be seen subsequently. The concept of this

scientific/mathematical proof was brought out in short in an

article titled ‘Cricket in Massive Fix?’ published in The Statesman

dated 10/07/2013. There is no reason why BCCI and ICC should

have not acted on or reacted to this article published in one of

the most prestigious newspapers of the country or the book

Bettors Beware even after coverage by PTI regarding the

contents of that book. It was not a case of vague or

unsubstantiated allegations but of scientifically proven gross

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public impropriety going on. Therefore their silence all these

years in this case amounts to admission of their guilt.

A true copy of the article titled ‘Cricket in Massive Fix?’ published

in The Statesman dated 10/07/2013 is annexed herewith along

with true typed copy and marked as ANNEXURE-P/5.

19. That the mathematical evidence mentioned above of

institutionalized fixing of cricket is something quite out of the

ordinary, not something that would come to mind ordinarily. But

that didn’t mean that world should have ignored it, as it seems

to have done. There is a quote by famous astronomer and

science popularizer Carl Sagan:

“Extraordinary claims require extraordinary evidence.”

Going through a short power point presentation prepared years

ago around same time by Petitioner No.1 may help in

understanding the whole concept and things even better. The

mathematical proof has withstood the biggest test, the test of

time. Moreover, some recent events as would be brought out

further down in this petition have confirmed continuation of

institutionalized fixing of cricket that the mathematical proof

signified.

A true copy of the Power Point Presentation is annexed herewith

and marked as ANNEXURE-P/6.

20. That applying mind a little more, how do bookies offer odds for

various brackets? How do they guess the scoring patterns in

advance for a session? No past data or present parameters can

make one predict how scoring will proceed in next few overs or

next few balls in an ongoing match. In on line betting sites, the

odds for same brackets in different sessions in different innings

or matches vary vastly. For example, situation arises many

times a match or a day in limited overs cricket when one run is

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required to be scored of the last ball of the session to achieve a

bracket (30 runs or 50 runs or 65 runs or so on). Sometimes

return (additional) of 50 paisa (against one rupee wagered) is

offered in online betting and at other times it could be as high as

Rs.3. This is just one crude example. It just cannot be possible

for the bookies/betting sites/syndicates to engage in

session/bracket betting and offer the odds they do during the

course of such betting if they did not know beforehand how

scoring was going to proceed ball by ball.

21. That an innocuous looking revelation by Petitioner No.2 in the

book ‘Fixed! Cash and Corruption in Cricket’ further seals any

doubts that one may have about institutionalized fixing of

cricket. It is extremely strange that everyone has failed to see

the import of such a revelation. The book brings out that Justice

Mudgal’s report included this:

“…Chutani would routinely convey opening rates to key bookies

in India, Pakistan, Singapore, and Kuala Lumpur. He was sure

about what would happen in a match and rates were fixed

accordingly. No one dared argue with him.…”.

22. That Javed Chutani has been mentioned to be one of the close

aides of Dawood Ibrahim, maintaining direct contact with the

underworld lord. The matter in the italics has very grave

implications, yet no one, neither Justice Mudgal nor anyone else

appears to have given any heed to it. Chutani, or any one, could

not be sure about what would happen in a match until and

unless matches were pre-scripted, something impossible without

fixing being institutionalized. It also confirms petitioners’

deliberation earlier,

‘how do bookies offer odds for various brackets? How do they

guess the scoring patterns in advance for a session? …….. It just

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cannot be possible for the bookies/betting sites to engage in

such session/bracket betting if they didn’t know beforehand how

scoring was going to proceed ball by ball.’

To illustrate this, a latest post dated 14/10/2017 is reproduced

from the facebook page

https://www.facebook.com/BettorsBeware/:

“Without going into session scoring and applying maths to it and

mind to session betting, from the movement of match odds itself
one can say with ease and absolute certainty that the first ODI
between Pakistan and Sri Lanka held at Dubai on 13/10/2017
was fixed and script was known well in advance to the betting
syndicates.

The odds opened with Pakistan as strong favourites with odds of

around 1.53 in their favour, even though they had been beaten
by Sri Lanka in the last two Test matches very recently. For a
moment one can justify it saying that the team compositions had
much changed compared to Test teams of the two countries. But
what followed had no explanation other than what is said above

Even though Pakistan lost one of their main batsmen Ahmed

Shehjad early, the odds didn't change much. Even with Pakistan
struggling at 36/1 after 10 overs. 75/2 after 17 overs, and 124/3
after 28 overs, the odds remained below 1.5 and below 1.4 in
Pakistan's favour. With Pakistan posting just a modest score of
292 in 50 overs, the odds in their favour were below 1.2.

While chasing even when Sri Lanka were a promising 30/0 in the
beginning of the 4th over, the odds remained below 1.3 in favour
of Pakistan..

Sure enough, Sri Lanka started losing wickets from there on like
nine pins and were soon out of contest.

It was a sure trap for the bettors. Given match position vis-a-vis
the match odds, the bettors would have been led to bet against
Pakistan to lose all the money put into bets.”

23. That examining Times of India dated 27/7/2013 news report

titled ‘IPL betting rates set by Dawood, says charge sheet’, how

could D Company know of winning teams for its announcements

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to be true or willfully misleading without total fixing involving all

concerned? A question no one has bothered to ask and answer.

Petitioner no. 1 had brought it out in the chapter ‘Mental

Bankruptcy’ in book ‘Bettors Beware’ published three and a half

years ago.

A true copy of Times of India news report dated 27/7/2013 titled

‘IPL betting rates set by Dawood, says charge sheet’ is annexed

herewith along with true typed copy and marked as

ANNEXURE-P/7.

24. That totally fixed cricket manifests itself in the plays in the field

also as it must. Plays in the field, match after match, especially

in tournaments like IPL, BPL, BBL. PSL. CPL, across the world are

too evident at times to make one see that scripted cricket was

being acted out. When a batsman like Pollard taps a ball for a

single when boundary is required for his team to win, that one

ball reveals all. When Gayle gives a tame catch to mid-off or

mid-on of a ball he can hit rows behind over the boundary 10 out

of 10 times, it must be appearing too odd to those who

understand cricket. When RCB, on paper the best batting team

of IPL 10 led by larger than life Virat Kohli fails repeatedly and

even gets all out for 49 runs in an innings, fixed and scripted

cricket becomes too obvious. Set batsmen hitting out a ball in

the lap of lone fielder in the deep and getting out so often when

they could have hit it easily in the gaps has no other

explanation. These are only a few examples to illustrate the

point. One can see hundreds and thousands of such examples in

recordings of matches across the globe. And this is what Mr

Sampat Kumar, the IPS officer who at one time was

investigating Gurunath Meyappan with regard to betting and

fixing in IPL 6, must have meant when he said for the 61st match
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of that IPL that he had been a cricketer himself and by seeing

the match one could easily know that it was fixed. This was in

news recently since CB-CID of Tamilnadu was rapped for shoddy

investigations in that matter and match by a Court. Today even

girls and house-wives who watch cricket only casually and don’t

know anything about session betting tell that fixing in cricket

appeared too obvious, though Gavaskars, Shastris, and

Gangulys continue to sell it as a great competitive sport.

25. That Cricket could be a funny game, but players have certain

capabilities. When they bat, bowl, or field defying those

capabilities very frequently, blundering again and again and yet

continuing to play for the team, there is only one explanation for

their performance –they were acting out as per a given

script/role. Cricket is such a game (each ball being a distinct

event) that a player misbehaving/underperforming on purpose

can be easily seen if one had eyes and an open mind. For

example, thrilled and overawed by a flurry of sixes and/or fours,

viewers often fail to see that such an act had been facilitated by

the bowler/s. Fixed and scripted cricket manifests itself day in

and day out in conspicuous and inexplicable underperformance

by players and teams. It also gets indicated through

diametrically opposite performances by teams in a matter of a

day or two. The latest example at the time of drafting this

petition was the first two T 20 matches between India and

Australia held on 7/10/2017 and 10/10/2017. In the first

Australia were beaten comprehensively and in the next India got

beaten comprehensively. Other than fixing getting proved

mathematically based on scoring patterns in these matches,

scripted play was too conspicuous to a discernible eye.

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26. That once all above is known and understood, the rest follows.

It is not that some odd fixing is taking place in some odd match.

Continuous scripted cricket cannot be a result of cheating by

some players at the behest of some bookies, unknown to other

players in the field, coaches, and team management. Game is

being played in the open. A little application of mind tells that

fixing to the extent of how many runs would be scored of which

ball cannot be without full knowledge of all the players, coaches,

and team management, and team owners in case of leagues like

IPL, KPL, and TNPL. That is institutionalized fixing of cricket.

Media has enormous commercial and financial stakes in

continuance of cricket as it is. This has been told point blank to

Petitioner No.1 by journalists attending his press meets. Star TV

very recently contracted for $2.55 billion record investment for a

five year-long, worldwide television and digital rights for the

Indian Premier League (IPL). That amounts to Rs 25 lakhs for

telecast of one ball of IPL, as per rough calculations by a cricket

maverick, as reported.

27. That a lot other people connected with conducting of game in

the field and its marketing including broadcast of the matches

with live commentary have to be involved. This has been

detailed in Petitioner No.1’s books. Exact details of the

involvement of various people can be known only after the

clearly implicated perpetrators are duly questioned and total

modus operandi is unearthed through a thorough meaningful

investigation.

28. That having elaborated upon existence and continuation of

institutionalized fixing in cricket, it may be pertinent to

reproduce below some excerpt from Preface in Petitioner No.1’s

book ‘Cricket: The Massive Fraud’ published years ago:

 WWW.LIVELAW.IN 19

“…..Fraud that is cricket is not perpetrated in dingy or five star offices

in some obscure or secret files away from public eyes through

collusion of a few. It is committed in front of thousands of viewers in

open grounds and stares us in the face from our TV sets 24x7. And all

those matter are in it—actively or passively. That makes it simply

amazing. More amazing is the fact that with this fraud publicly

proved, everyone is quiet, happy to pretend as if it isn’t there, and the

fraud—the massive organized public crime committed by the

celebrities of the society—continues. ...”.

There is another quote by Carl Sagan:

‘“One of the saddest lessons of history is this: If we’ve been

bamboozled long enough, we tend to reject any evidence of the

bamboozle. We’re no longer interested in finding out the truth.

The bamboozle has captured us. It’s simply too painful to

acknowledge, even to ourselves, that we’ve been taken. Once

you give a charlatan power over you, you almost never get it

back.”

Exactly this human behaviour applies in respect of match-fixing

in cricket. But that cannot justify the massive fraud and justify

allowing it to continue.

29. That with institutionalized fixing of cricket becoming clear, many

questions arise. Petitioner No.1 has dealt with all such questions

in his books. No questions, answered or unanswered, can change

a hard fact that otherwise lies established irrefutably. Unknown

answers need to be found out through honest and hard

investigations. A few questions that come readily to the mind will

be dealt with now.

 WWW.LIVELAW.IN 20

30. That one pertinent question that arises is whether it is possible

to control and manipulate scoring and if so, how? Answer to this

was provided by none other than Ex-Australian Captain Steve

Waugh, a few years ago. Here are the excerpts from Petitioner

No.1’s book ‘Bettors Beware’ that answers this question.

“…If anyone still has any doubt about possibility of existence of

fixing in international cricket, here is a news item published in

The Statesman on the 13th August, 2013, that is after

compilation of the first draft of the manuscript of this book.

‘Former Australian captain Steve Waugh was yesterday quoted

as saying that bracket-fixing was the latest threat to cricket,

along with spot-fixing, and that bookmakers were making a lot

of money out of it.

“With bracket-fixing, a segment of a 50-over game or a

Twenty20 contest is manipulated,” said Waugh in an interview to

news.com.au.

According to Waugh, “In a five-over period, for example, the

corrupt players ensure a certain amount of runs are scored, and

if a captain is involved, the whole process can be achieved

discreetly and effectively ... opportunities to put such schemes

into action are widespread, especially in second-tier tournaments

such as domestic Twenty20 competitions and other events away

from the prying eyes of the global media and more stringent

match officials.”

The former player said that these matters, apart from wider

areas of corruption, had been discussed when Waugh, a member

of the Marylebone Cricket Club's world cricket committee, met in

Perth in 2010.

Around the turn of the century, after some prominent players,

including Test captains, were found guilty of corruption, a

 WWW.LIVELAW.IN 21

number of national cricket boards chose not to have certain

leads fully investigated, for fear that more star players might be

implicated, he said. The danger now lurks as Twenty 20 leagues

sprout up all over the cricket world.’ ”.

Waugh mentioned that it could be done discreetly if the captains

were involved. We know not only captains, but coaches and

others also to be involved. So it is very much possible. What is

so possible for a domestic T 20 league, will also be possible for

other matches. Once a while, it could be that end outcome of a

ball wasn’t as had been designed or intended. Such randomness

will always be there and has to be borne with by the fixers. That

has to be taken care of in subsequent play and is taken. For

example if a catch that had been scripted to be taken gets

dropped, batsman may get out in next ball or next few balls.

31. Another big question that arises is that if the scripted matches

continued at the behest of the cricket authorities, then how is it

that some players like Sreesanth, Chavan, Chandila in IPL 6 or

Kaneria in England, or Sharjeel Khan, Khalid Latif, Mohammad

Irfan, Shahzaib Hasan and Nasir Jamshed of Pakistan in PSL

2017 have been taken up for cheating and fixing/attempt to

fixing from time to time by the same authorities? The answer to

this puzzling question lies hidden in the question itself. They are

taken up for cheating within cheating. They are taken up for

cheating or attempting to cheat the authorities by leaking

information to or having tie ups with the bookies, outside their

brief, tempted to make extra bucks. Spot fixing case involving

Pakistani cricketers Mohammad Amir, Mohammad Asif and

Salman Butt was clearly so. At times, such incidents as reporting

 WWW.LIVELAW.IN 22

about bookies by players could also be shams to hoodwink the

public.

32. That many won’t have forgotten the scandal concerning

Sreesanth and others in IPL 6 in 2013. Though everyone stands

acquitted by the lower court, the Police have gone for appeal in

the High Court. At the time of arrest of Sreesanth then, the Delhi

Police Commissioner Mr. Neeraj Kumar publicly claimed it to be a

water tight case and also the players were reported to have

confessed. The dissection of the facts of Sreesanth episode

under the chapter ‘Large Scale Fixing Gets Established but All

look the Other Way,’ in the book ‘Bettors Beware’ clearly brought

out how session fixing and hence match fixing did take place and

how many other players than the three arrested had to be

involved. Three players S Sreesanth, Ajit Chandila, and Ankit

Chavan were arrested for fixing in three different matches

involving their team Rajasthan Royals.

A true copy of Wikipedia report on IPL 6 fixing scandal is

annexed herewith along with true typed copyand marked as

ANNEXURE-P/.

33. That as per TNN news report dated 12/2/2014 another match

number 61 of same IPL 6 between CSK and RR also was under

probe and raised many eye-brows. From a very healthy 83/0 in

the 12th over, CSK in spite of having a very strong batting line-up

ended at meager 141/4 in 20 overs. The report tells further

about it. No logical conclusion of the probe is known to the

public. The players under scanner and suspicion continued to

play for India and even captain Indian Team. MS Dhoni is also

known to have lied under oath about Gurunath Meyappan and

still continued as Indian captain. There have been numerable

 WWW.LIVELAW.IN 23

other reports on match fixing and bribing of players from time to

time. Such reports have been appearing and disappearing.

A true copy of TNN news report dated 12/02/2014 is annexed

herewith along with true typed copy and marked as

ANNEXURE-P/9.

34. That those were the days when IPL 6 scandal and Mudgal

Committee investigating some aspects of it continued to be in

news. A scathing article ‘The IPL scam and 2014!’ written by

renowned journalist late Rajinder Puri dated 18/2/2014 and

published in The Statesman brought out how leading politicians

of the country could not be absolved of their responsibility for

the cricket muck and how with Dawood Ibrahim being behind

that muck country’s security was compromised. But no one

bothered a bit.

A true copy of the article ‘The IPL scam and 2014!’ by late

Rajinder Puri dated 18/2/2014 published in The Statesman

isannexed herewith along with true typed copy and marked as

ANNEXURE-P/10.

35. That it was during this scandal three and half years ago that

Vindu Dara Singh, considered to be an insider, told that IPL was

100% fixed as brought out in Zee News report dated 25/2/2014.

That time in 2013 even the present ICC chairman Mr Shashank

Manohar had demanded probe into all matches of IPL 6 and even

CBI investigation. He forgot all about that after becoming

President of BCCI and then chairman of ICC.

A true copy of Zee News report dated 25/2/2014 on Vindu Dara

Singh is annexed herewith along with true typed copy and

marked as ANNEXURE-P/11.

36. That a significant coverage titled ‘Almost All International

Cricket Matches Are Fixed, Alleges Whistleblower’ was made by

 WWW.LIVELAW.IN 24

PTI consequent to publication of Petitioner no. 1’s book ‘Bettors

Beware’ and his press meet in New Delhi in end February, 2014.

Surprisingly, there were no reactions from the cricketing world to

this explosive coverage, everyone maintaining ostrich like

silence. The text of the coverage is self explanatory.

A true copy of Press coverage dated 28/2/2014 titled ‘Almost All

International Cricket Matches Are Fixed, Alleges Whistleblower’ is

annexed herewith along with true typed copy and marked as

ANNEXURE-P/12.

37. That the Petitioner No.1 even made a detailed submission to the

Hon’ble Supreme Court of India in April, 2014, enclosing a copy

of the book Bettors Beware as well. Somehow even then nothing

happened.

A true copy of acknowledgement no. 34 dated 24th April, 2014 by

the Hon’ble Supreme Court on Petitioner no. 1’s submission

dated 23/4/2014 is annexed herewith and marked as

ANNEXURE-P/13.

38. That a review of the book ‘Bettors Beware’ by the sports editor

of The Statesman, Mr. Pulakesh Mukhopadhyay, was published

in The Statesman dated 27/04/2014. The same is self

explanatory. As per this review, the mathematical proof of

continuous fixing in cricket given in the book was got examined

by the reviewer by more than one persons and was found to be

satisfactory. This is what the review says in this regard:

“and even if the chapter titled “Wonders of Mathematics” isn’t

exactly as easy as ABC, and the prose isn’t always crystal

clear,several people familiar with both cricket and arithmetical

complications, consulted on this, endorse it as quite all right.

“Wow!” was the consensual judgment, delivered separately in

miles-apart places.”
 WWW.LIVELAW.IN 25

A true copy of review of the book ‘Bettors Beware’ by the sports

editor of The Statesman, Mr Pulakesh Mukhopadhyay, published

in The Statesman dated 27/04/2014 is annexed herewith along

with true typed copy and marked as ANNEXURE-P/14.

39. That the institutionalized fixing in cricket was further brought to

notice of the cricket world and cricket lovers through publication

of interview of Petitioner No. 1 in April 2014 edition of the cricket

magazine Cricket Today. The cricketing world continued with its

deafening silence, the fixed cricket is continuing as it was.

A true copy of the interview published in April 2014 edition of

Cricket Today is annexed herewith along with true typed copy

and marked as ANNEXURE-P/15.

40. That Justice Mudgal Committee to cleanse cricket was in place

those days. Petitioner no. 1 communicated with it through email

and sent the copies of his two books Inside the Boundary Line

and Bettors Beware to it. He also requested to depose before the

committee to enlighten it about fixing in cricket. Unfortunately,

even such a high profile committee considered the books and the

Petitioner no. 1 to be of no consequence to its scheme of things.

A true copy of the email interaction in this regard between

Petitioner No. 1 and Mudgal Committee held between December

2013 and May 2014 is annexed herewith and marked as

ANNEXURE-P/16.

41. That not resting in his crusade since his first press conference

on the subject in Kolkata in January 2013, Petitioner No.1 did

communicate with Lodha Committee also after its formation to

deal with matters of corruption, betting, and fixing in cricket,

especially IPL. His letter dated 14/6/2015 addressed to Justice R

M Lodha was submitted along with the enclosed books in person

and acknowledgment received.

 WWW.LIVELAW.IN 26

A true copy of the letter dated 14/6/2015 is annexed herewith

along with true typed copy and marked as ANNEXURE-P/17.

42. That the public is mostly unaware of the money and number of

people involved in cricket betting. It was reported in media that

referring to a FICCI report on cricket betting SIT on black money

had told Hon’ble Supreme Court that more than Rs 3 lakh crore

of black money was transacted every year resulting from cricket

betting in India. According to another report by Doha-based

International Centre for Sport Security as mentioned in a The

Indian Express report dated 16/7/2017, the illegal betting

market in India is worth $ 150 billion or roughly Rs 9.6 lakh

crore a year. Most of it would be on cricket betting. Thus, cricket

betting market in India can safely be estimated to be above Rs 5

lakh crore per year, and in all likelihood in the range of Rs 7-8

lakh crore per year. As per another media report, Hindustan

Times report dated 27/6/2015, the Enforcement Directorate had

found that just one UK-based betting website, www.betfair.com,

had seen remittances amounting to at least $3,000 crore (about

Rs 1.9 lakh crore)—almost five times the size of Delhi

budget—through 10 million login IDs that originated in India. ED

investigators, who stumbled upon the information during the

spot-fixing probe, said it could just be the tip of the iceberg. The

actual amounts could be much higher. So at least one crore

educated Indians were betting on cricket through one online

betting site alone. One could well imagine that the number of

bettors in the country would be a few crores since majority of

betting takes place through phone through bookies. Even

Government of India is well aware of the enormity of cricket

betting in India. Vide an Appeal dated 30/5/2017 Law

Commission of India invited views and suggestions from all

 WWW.LIVELAW.IN 27

concerned with regard to legalizing betting and gambling in

India. It did mention so in the Appeal:

‘..It is understood that a lot of money is involved in illegal

gambling business, creating almost a parallel economy,

converting legally earned money into black money that is

drained to gambling operators in other countries online…”

An incident narrated by an Inspector General of Police to Mr

Shantanu Guha Ray as recorded in his book further illustrates

and explains this aspect very well as to how masses are

adversely affected by fixed cricket and betting. People have

interacted with Petitioner no. 1 on facebook page of Bettors

Beware lamenting about heavy losses in cricket betting.

A true copy of Hindustan Times report dated 27/6/2015 titled

‘UK website got Rs 1.9 lakh crore in cricket bets from India: ED’

is annexed herewith along with true typed copy and marked as

ANNEXURE-P/18.

A true copy of page xiv of book “Fixed! Cash and Corruption in

Cricket” bringing out above mentioned incident narrated by an

Inspector General of Policeis annexed herewith along with true

typed copy and marked as ANNEXURE-P/19.

43. That having a sense of proportion and understanding very well

the enormity of the issue, the Petitioner no. 1 wrote to President

of India in July, 2015 requesting his office to do the needful. The

letter was duly acknowledged by President’s Secretariat and

forwarded to Secretary, MHA for action in end July, 2015 vide Sl.

No.: P1/A/3007150252 dated 30/7/2015. Again the concerned

Ministry found it most convenient not to do anything, the

massive fraud continuing unbridled. Petitioner no. 1 also wrote

to Prime Minister and Home Minister and got acknowledgments

 WWW.LIVELAW.IN 28

from their offices. His representations have been kicked from

one office to another with no action whatsoever for years. As per

last communication received by him, the matter of this grave

magnitude lied referred to one Sh. A.K. Patro, US (SP-I & III) by

(Ms) Lalita Sharma, Section Officer in the Ministry of Youth

Affairs & Sports vide F.No.2/1/2016-PG/RTI dated 30/11/2016.

That sums up Indian bureaucracy and its working. It is not only

about bureaucracy. The Prime Minister of India and Union

Cabinet have publicly been proclaiming from house tops that

their government had zero tolerance against corruption. It is not

understood what their definition of zero tolerance or of

corruption is. They and their government have been maintaining

deafening silence over the biggest ever fraud continuing in India

despite matter having been brought to their notice repeatedly

and also having been reported in some quarters of media at

times. The above covers due representation having been made to

respondents no.1 and 2.

A true copy of the letter dated 25/7/2015 addressed to the

President of India by Petitioner No.1 is annexed herewith along

with true typed copy and marked as ANNEXURE-P/20.

44. That the Petitioner No.1 continued with email interaction with

the Lodha committee. Lodha Committee also didn’t consider it

worthwhile to give any value to sincere efforts of Petitioner No.1.

The massive fraud continued and continues unfettered.

A true copy of the text of the email interaction between

Petitioner No.1 and Lodha Committee held between July and

September 2015 is annexed herewith and marked as

ANNEXURE-P/21.

45. That thus, sadder and more demoralizing than continuation of

fixed and fraudulent cricket for at least a decade as established

 WWW.LIVELAW.IN 29

through book Bettors Beware is the fact that no one has been

bothering about it even though it gets exposed repeatedly. The

books by the petitioners as mentioned do not make vague and

unfounded allegations as anyone can do, but deal with the

subject of match fixing most comprehensively, logically, and

scientifically. Petitioner No.1 has left no stone unturned and has

run from pillar to post in highlighting the existence and evils of

fixing in cricket with a hope that some responsible authority will

take note and act one day, but unfortunately all ears have been

deaf till date. His email interactions with the Delhi Police

Commissioner on the subject were also duly acknowledged and

allotted reference numbers 14091/E-mail dated 20/09/2013 and

948/E-mail dated 19/01/2015, but no action has ever taken. An

article by Petitioner No.1 bringing out above in a compact and

comprehensive manner was published on internet by Youth Ki

Awaaz on 21/4/2016.

A true copy of the article titled ‘The Betting Mafia Is Active In

Indian Cricket, But Why Is No One Crying Foul?’ published by

Youth Ki Awaaz on 21/4/2016 is annexed herewith along with

true typed copy and marked as ANNEXURE-P/22.

46. That for last few years India and Pakistan have been playing

cricket against each other only in international tournaments. In

one such World Cup match in 2011, the script of the match got

leaked and became a common knowledge before the start of the

match. The match went on more or less as per the leaked script.

It is a matter of journalistic record. A British journalist, Edward

Hawkins, felt so overwhelmed by it that he went on to write a

book ‘Bookie Gambler Fixer Spy: A Journey to the Heart of

Cricket's Underworld’ highlighting this very fact. A complete

chapter ‘What a Match!’ has been devoted to the leaked script

 WWW.LIVELAW.IN 30

before the match in the Petitioner No.2-Shantanu Guha Ray’s

book ‘Fixed! Cash and Corruption in Cricket’. Petitioner No.1 has

also shown in his book ‘Underworld Cup’ how India –Pakistan

match in 2016 T 20 World Cup was fixed along with other

matches. The final between the two countries in the recently

concluded Champions Trophy that India lost is popularly believed

to have been fixed. Fixing of cricket matches between India and

Pakistan, the two nations at loggerheads, with top politicians

controlling cricket is a very grave matter with astonishing

national and international political and other implications. A

letter on the subject by Petitioner No.1 to NSA Mr Ajit Doval

dated 21/9/2016 sums this up.

A true copy of the letter dated 21/9/2016 addressed to NSA by

Petitioner No.1 is annexed herewith along with true typed copy

and marked as ANNEXURE-P/23.

47. That fixing in cricket has never been limited to IPL or other

such leagues. It won’t be, as same players play in and same

Boards govern these leagues as other international matches.

Not long ago, there was another big expose in London by

arrested bookie Sanjeev Chawla. In September 2016, he told

his interrogators how international cricket was institutionally

fixed, citing inexplicable batting by West Indies in the third and

final T20 match against Pakistan at Abu Dhabi that month. It

was a strange and interesting, yet very revealing coincidence

that what was being recorded and posted by Petitioner No.1 on

facebook page https://www.facebook.com/BettorsBeware/ was

being told to his interrogators in London by famous bookie

Sanjeev Chawla. This was brought out in a report by Petitioner

no. 2 published by the news portal Firstpost.

 WWW.LIVELAW.IN 31

A true copy of Firstpost report dated 29/9/2016 bringing out

above is annexed herewith along with true typed copy and

marked as ANNEXURE-P/24.

48. That the Petitioner No.1 had been interacting with ICC and

BCCI also along with others through email without any result.

When a new panel of administrators was appointed for BCCI and

Mr Vinod Rai was appointed as Head of the panel, Petitioner no.1

had a fresh ray of hope. In February, 2017, he wrote to all the

members of the panel of administrators of BCCI to do the

needful sending them copy of his latest book ‘Underworld Cup’

for necessary comprehension along with the letter, but still not a

leaf stirred anywhere. He has sent his books to some of the

cricketers involved and tweeted to many others. He has sent

letters and book/s to number of Members of Indian Parliament.

No one, no one has countered his findings and assertions till

date. Probably, because no one ever could do so logically. He

has been posting about how matches are scripted to rob the

bettors from time to time for a few years now on facebook page

https://www.facebook.com/BettorsBeware/. People from world

over have been responding, questioning at times. They could

include representatives of betting syndicates as well since the

page is open to public. No one has been able to counter his logic

till date, while many have found it all totally correct.

A true copy of letter by Petitioner No.1 to Mr. Vinod Rai, Head,

Panel of administrators of BCCI dated 28/2/2017 is annexed

herewith and marked as ANNEXURE-P/25.

49. That the Petitioner No.1 has held many press conferences over

the years, the last being held on 1st April, 2017 in Kolkata

wherein he emphasized on the link between fixed cricket and

terror funding. It was covered and reported upon by leading

 WWW.LIVELAW.IN 32

newspapers of the country. But unfortunately, the country

continued to sleep over such a grave issue detrimental to its

security as well.

True copies of coverage of Press Conference of 1st April, 2017 of

Petitioner No.1 published in the country’s two leading

newspapers The Hindu, report dated 1/4/2017, and The

Statesman dated 2/4/2017 are annexed herewith along with true

typed copies and marked as ANNEXURE-P/26 and

ANNEXURE-P/27 respectively.

50. That the Petitioner No.1 organized press meets taking pains in

the hope that media, that at times makes a lot of noise on

matters of relatively much less impropriety, would have a sense

of proportion and would do the needful to make masses aware of

this ongoing massive fraud. But probably media has its own

priorities, compulsions and motives. To be fair to them, some of

them did cover his assertions, some of that coverage has been

brought out in this petition, albeit in relatively obscure columns,

but did nothing worthwhile to make masses aware. Electronic

media continued to maintain a deathly silence. On the contrary,

media continues to report on cricket matches and related

matters as if cricket was a competitive sport, thus continuing to

facilitate this fraud. With BCCI and Union of India failing, even if

media, especially electronic media, had not failed in its duty to

the nation, probably there would not have been any need to file

this petition.

51. That Law enforcing agencies are sleeping as they are known to

have slept or failed over the years as far as corrupt and fixed

cricket is concerned. The facts brought out earlier do indicate

that acquittal of Sreesanth and others from lower court has in all

likelihood been a case of botched up investigations and

 WWW.LIVELAW.IN 33

prosecution. Very recently CB-CID of Tamilnadu was rapped by a

Court for shoddy investigations in the matter of betting by

Gurunath Meyappan and his links with bookies. This came out in

a Timesnow report dated 11/5/2017. Delivering a judgment in a

case of two persons organizing a betting syndicate in 2010,

Justice Dharmesh Sharma also had made these scathing

remarks:

“The half hearted and lackadaisical approach of the police in

nabbing the perpetrators of organized crime leaves the

impression that the police are not only ill-equipped to deal with

such cases but probably they have higher stakes in continuance

of the same under their patronage.”

As mentioned earlier, a number of reports about fixing of

matches go on appearing and disappearing. Nothing is known to

have been investigated thoroughly to a logical conclusion. Even

if a single fixed match was ever investigated meaningfully to a

logical conclusion with necessary application of mind, a lot would

have got revealed by now to the public.

A true copy of Timesnow report dated 11/5/2017 on rapping of

CB-CID of Tamilnadu by a Court is annexed herewith and

marked as ANNEXURE-P/28.

A true copy of excerpts from book ‘Fixed! Cash and Corruption in

Cricket’ bringing out Justice Dharmesh Sharma’s remarks

mentioned above is annexed herewith and marked as

ANNEXURE-P/29.

52. That while scattered past developments and hard facts do

indicate institutionalized fixing of cricket, some recent

developments leave no doubt about it whatsoever.

 WWW.LIVELAW.IN 34

53. That in a recent incident, on 10th May, 2017, three men,

bookies/businessmen, were arrested from a Kanpur Hotel after

the 50th match of IPL 10 between Gujarat Lions and Delhi

Daredevils. They were staying on same floor/hotel as the two

teams. One of the arrested men, Ramesh Nayan Shah, is

reported to have spilled the beans telling that the match was

fixed. In this regard Indiatimes report dated

12/5/2017mentioned that ‘An dated WhatsApp message on his

phone revealed that Gujarat Lions would lose the match

despite scoring nearly 200 runs. And that is what exactly

happened’.

A true copy of Indiatimes report dated 12/5/2017 bringing out

above is annexed herewith along with true typed copy and

marked as ANNEXURE-P/30.

54. That quite recently it was reported in media and was all

over social media that a twitter handle under the name of

Cricket Insider (@theDcricket) had made some peculiar

predictions about the final of IPL 10 held on 21/5/2017, 8 out of

9 being bang on target. The nature of predictions was such that

it could be nothing but script of the match being leaked

beforehand. There cannot be any other rational explanation.

Any mind even slightly rational will instantly realize so after

going through those prophetical tweets, even though the cricket

insider is reported to have told that match was not fixed. There

were predictions as specific and peculiar as Mumbai will bat first

and make 120 to 130 run and will win, Parthiv Patel will hit

under 10, Polard will hit 1 six. None of such predictions could be

a guess work that somehow came true. Other predictions were

also similarly peculiar. Interestingly, media at large just

mentioned in passing or totally skipped over this irrefutable

 WWW.LIVELAW.IN 35

evidence of IPL 10 final having been a pre scripted match. Even

the annexed reports of Zee News and NDTV bringing this fact

out beat about the bush and did not say that it was a clear case

of IPL 10 final being a fixed match.

A true copy of Zee News report dated 22/5/2017 bringing out

above mentioned prophetic tweets of Cricket Insider is annexed

herewith along with true typed copy and marked as

ANNEXURE-P/31.

A true copy of NDTV report dated 23/5/2017 bringing out above

mentioned prophetic tweets of Cricket Insider is annexed

herewith along with true typed copy and marked as

ANNEXURE-P/32.

55. That since there was no official complaint about this match and

none of the cricket authorities bothered, that clearly implies that

scripting was with full knowledge of the authorities concerned

and that fixing was not at the behest of any outside bookies.

Australian captain Steven Smith, ex Indian captain M S Dhoni

and many star cricketers from different countries participated in

this match. Bharat Ratna Sachin Tendulkar was a mentor of one

of the teams, Mumbai Indians. If final of IPL 10 is known to be

institutionally fixed without any murmurs or reactions from the

cricketing world, star cricketers, cricket journalists, and cricket

authorities, by implication it becomes rather easy for one to

understand each and every word of submissions made in this

petition and see that there is no room for any debate on

existence of institutionalized fixing of cricket left.

56. That in one swift move, all those were silenced for good who led

by mental blocks and without going through and applying their

minds to what was said in Petitioners’ books thought and

 WWW.LIVELAW.IN 36

declared that it was impossible for Dravids and Tendulkars to be

involved in fixing and that all could not combine to fix. One

cannot be blamed for having a mental block that institutionalized

fixing was impossible. But the aforesaid tweets by Cricket Insider

established the same even to those who do not understand

anything about betting or session betting. The maxim that

‘people may lie but circumstances don’t’ applied. Institutionalized

fixing of cricket had become too evident overnight, whatever

arguments one could be forwarding against it. From further

developments brought out subsequently it also gets explained

why such a self goal was scored by the betting mafia. Anyone

knowing the script of a match and revealing it beforehand

without coming to any harm was more likely to be a part and

parcel of the betting mafia.

57. That close on the heels of cricket insider proving to the world

that cricket was fixed, the ex Pakistani cricketer and captain

Aamir Sohail also corroborated the existence of institutionalized

fixing of cricket when he blurted out (it could be an emotional

burst of a hurt ego) on a Pakistani TV channel after Pakistan had

reached the final of CT 2017,

“Sarfraz needs to be told that you have not done anything great.

Someone has helped you win the game. There is no reason for

you (Sarfraz) to be so happy. We all know what happens behind

the scenes. Don’t wish to get into the details on who won them

the games. If asked, I will say that the prayers of the fans and

God has won them the games. They have been brought to the

final due to external factors and not based on on-field

performance. The boys now need to be level-headed and focus

on playing good cricket…..”.

 WWW.LIVELAW.IN 37

Sarfraz Ahmed was the Pakistani captain. These are quite

meaningful words for many reasons. If Sohail knows about

behind the scene machinations, better connected experts like

our own Gavaskars, Shastris, and Srikants or well connected

cricket journalists are also likely to know about those? Sohail did

say ‘we all know.’ Secondly it couldn’t be something out of

frustration on loss by his national team, since words were

spoken after Pakistan had won. He did not mention that this or

that match was fixed, he mentioned about continuous behind the

scene machinations. Question arises as to what has ICC been

doing if behind the scene machinations were going on without its

approval.

A true copy of hindustantimes report dated 16/6/2017 reporting

above outburst of Aameer Sohail is annexed herewith along with

true typed copy and marked as ANNEXURE-P/33.

58. That a whatsapp message purported to have been circulated

before the CT final between India and Pakistan played on

18/6/2017 (Petitioner No.1 got it on whatsapp on the 19th June,

2017 FN. The time shown on the message indicated it had been

initiated at least a day before, i.e. before the start of the match

on the 18th June, 2017) making some peculiar prophecies that

came good similar to what was done by Cricket Insider for IPL

10 final deserved and deserves to be a matter of investigations.

A true copy of the content of the whatsapp message initiated by

one Dk dated 18/6/2017 in all probability is annexed herewith

along with true typed copy and marked as ANNEXURE-P/34.

59. That the petitioners are sure that anyone would be shocked to

learn how brazen and open the whole business of fixing in cricket

and befooling the gullible bettors has become after the prophetic

tweets by Cricket Insider. Now numbers of twitter accounts by

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the name of cricket insider with different identifications and

other names have mushroomed that are claiming many matches

to be fixed, announcing the outcome of matches and sessions

beforehand, many times correct, some astonishingly so and

announcing their charges for giving such information directly to

those interested through whatsapp messages. Then they feed in

wrong information along with right information and bettors are

trapped. A modus operandi exactly similar to one in operation

surreptitiously earlier as brought out in a news item of Times of

India marked as ANNEXURE-P/7 has now become brazenly open.

Some such twitter accounts are @theDcricket, @theDcricket2,

@theDcricketx_, @theDcricketOffi, @theDcrickett,

@Cricketinsider9, @cricketinsider4, @theDcrickettt. It would be

quite revealing to go through only a handful of tweets from one

such account @theDcricket2 dating between 4/6/2017 and

25/6/2017 that amply demonstrate the above. To cite some

instances, the exact target for Pakistan in India vs Pakistan

match on June 4, 2017 was correctly predicted. Correct scores

for some sessions and correct match result were predicted for 3rd

T 20 between South Africa and England at Cardiff on 25th June,

2017. If one goes through hundreds of tweets on the twitter

accounts mentioned, one would be shocked to see the muck

going on in the name of cricket. Probably this tweet by Cricket

Insider @theDcricketOffi on 18/9/19 night will take the cake;

‘Anyone wants CONVERSATION B RECORDING BETWEEN

PLAYERS TO ME?!! NO worries it's all MONEY’. The fraud and the

crime are being flaunted openly as if there is no governance left

in cricket and in the country. More than the muck itself, one

should be feeling shocked at the silence of the media and the

world about this muck even now.

 WWW.LIVELAW.IN 39

A true copy of some tweets from twitter account @theDcricket2

dating between 4/6/2017 and 25/6/2017 are annexed here with

and marked as ANNEXURE-P/35.

60. That against this background, Petitioner No.1 has been

continuing with his efforts. To further expose this massive

fraudulent set up openly in operation for a few months now,

Petitioner No.1 entered into whatsaap communication with

@theDcricket2 regarding CT 2017 final between India and

Pakistan held on 18/6/2017 and with @theDcricketOffi regarding

T 20 series held in October, 2017 between India and Australia.

The whatsapp number for communication on both occasions

remained same +919100544879. After charging money,

purposefully wrong information was fed by @theDcricket2 to

prospective bettors for the high profile CT final to serve the

interests of betting syndicates. Match result as well as session

scores predicted by him all went way off.

A true copy of the transcript of communication regarding CT

2017 final between Petitioner No.1 and @theDcricket2

(whatsapp no. +919100544879) dated 16th to 18th June, 2017

showing as stated above is annexed herewith along with true

typed copy and marked as ANNEXURE-P/36.

61. That in the meantime, the muck continued to increase with

mushrooming of local leagues indulging in fixed cricket, taking

cue from the more prestigious ones.

A true copy of hindustantimes report dated 24/7/2017 on one

Rajputana Premier League to show above is annexed herewith

along with true typed copy and marked as ANNEXURE-P/37.

62. That as mentioned earlier, Petitioner No.1 entered into

whatsaap communication with @theDcricketOffi regarding T 20

series held in October, 2017 between India and Australia for

 WWW.LIVELAW.IN 40

getting prior information about match outcomes and session

scorings against payment of money. He had guaranteed 3 times

return if any information given by him was wrong. For the first T

20 held on 7/10/2017, he gave part right and part wrong

information. The match result was rightly predicted but the

Australian scoring was wrongly predicted. When Petitioner no. 1

questioned him for the wrong information given by him with

respect to Australian innings score through twitter to expose

him, he blocked Petitioner no. 1 and also didn’t furnish him with

any information/report for 2nd T 20 held on 10/10/2017, failing

on his promise. Thus it gets well established that open cheating

and befooling of bettors is going on by a big mafia set up in the

interest of betting syndicates that is aware about the script of

the matches in advance. That explains why prophetic tweets by

one of the mafia were first recorded for IPL 10 final and then

were publicized. That action established Cricket Insider among

prospective bettors as someone who knew. Establishing himself

thus, he and/or others connected with him started openly

befooling and robbing bettors two ways, by charging money and

then slipping in wrong information. @theDcricket2 and

@theDcricketOffi are clearly one and same. In all probability, the

original Cricket Insider @theDcricket is also same. To

purposefully slip in wrong information also one has to know what

the right information was.

Question arises that did the betting mafia or people on their own

have no fear in doing all this so brazenly? Firstly, of media noise

or action by the cricket administrators and law enforcing

agencies for making institutionalized fixing so obvious through

leaking the script of IPL 10 final? Secondly, of similar action for

subsequently openly showing fixing of matches and befooling

 WWW.LIVELAW.IN 41

and looting prospective bettors? Clearly it did not have fear and

it was dead right. Cricket Insiders have been tweeting and

messaging with impunity for months now and everyone in cricket

administration as well as government has been sleeping. That is

the scariest part of the whole scenario.

A true copy of the transcript of communication regarding T 20

series between India and Australia between Petitioner no. 1 and

@theDcricketOffi (whatsapp no. +919100544879) dated October

2017 is annexed herewith along with true typed copy and

marked as ANNEXURE-P/38.

63. That turning of almost a blind eye by media at large to

institutionalized total fixing of cricket even though it throws up

sporadic news on fixing now and then, and inaction by the

highest authorities of the country, both executive and judicial, so

far on all that is in public domain for years and on the repeated

pleadings by Petitioner No.1, who has been acting as a

responsible member of the society exposing for years this

massive fraud with very grave national and international

implications at great personal cost and risk with no protection

(acting against the interests of a big mafia) and without much

support from any quarter in the society, has brought the things

to such a pass that people are today openly telling and showing

using social media (twitter and whatsapp) that matches were

fixed and charging money for giving inside information,

purposefully giving wrong information at times, to rob the

addicted and trapped bettors. Matches are so scripted that

addiction continues reinforced. Through institutionally fixed

cricket millions of bettors in India alone are robbed of lakhs of

crores of rupees for the benefit of betting syndicates linked to

 WWW.LIVELAW.IN 42

terror funding. All the authorities, multitude of them in India

alone, seem to have been taking pride in acting blind.

64. Thatwhile some celebrity cricketers as Vinod Kambli and Aamir

Sohail made shocking revelations at the spur of the moment at

times; there are also celebrities, cricketers or otherwise, who are

suspected and believed to have been silenced before they could

make any revelations. Either they had given indications that they

were going to reveal or it was feared that they could and would

reveal. They were those whose word would have carried a lot of

weight. The names that readily come to mind are Hansie Cronje

and Bob Woolmer. (refer heading Death in Wikipedia write-up on

Hansie Cronje). The latest name is Sunanda Pushkar who is

suspected to have been murdered at the behest of cricket mafia.

(reference: the link http://postcard.news/sunanda-pushkar-

shashi-tharoor-ipl-isi-link-untold-

story/?utm_medium=onsignal&utm_source=onsignal&utm_camp

aign=onesignal&utm_content=onesignal)

A true copy of Wikipedia write-up on Hansie Cronje is annexed

herewith along with true typed copy and marked as

ANNEXURE-P/39.

65. That in addition, names of many big and celebrated

international players across countries have surfaced from time to

time in incidents of match-fixing and passing on information to

bookies, the list being seemingly endless. Same very people

have continued to contribute to this massive fraud called cricket

in various capacities as players, coaches, commentators and

experts etc.

Nothing but existence of institutionalized fixing in cricket

explains all the instances of fixing and revelations that go on

surfacing from time to time without any action being taken by

 WWW.LIVELAW.IN 43

the cricket administrators. Cricket history is full of such

instances. If players had been misbehaving on their own, all of

them would have been taken up and thrown out long back by

respective Boards and ICC, as is done with the few when they

act on their own, or when Boards are forced to act.

66. That it is hoped that sufficient facts and material have been

brought out above to conclusively establish that institutionalized

fixing in cricket has been taking place, howsoever extraordinary

that may appear to one. A lot more lies in the public domain

through the books of the petitioners.

Two books, Bettors Beware by Petitioner No.1 in original and

true copy of Fixed! Cash and Corruption in Cricket by Petitioner

No.2, are annexed herewith and marked as ANNEXURE-P/40

and ANNEXURE-P/41 respectively.

67. That as mentioned in the beginning, subject of fixed cricket is

like an ocean since thousands of fixed sessions and hundreds of

fixed matches are taking place around the globe in a year. The

big crime is taking place as these matches are played. The

petitioners are sure that they have been able to bring out

enough material in this petition for one to be aware and sure of

existence of such an ocean. If need be, the petitioners can show

and explain from recordings and scorecards of almost every

match for last decade or more to the Hon’ble Court or any jury

how the play in the field defied competitive cricket, defied

probability for natural scoring, trapped the bettors, was scripted

for the benefit of betting syndicates, and how script of a match

was inter-connected with that of another match or other

matches to befool the bettors.

68. That by now, the Hon’ble Court must have appreciated the pains

taken and efforts made by the petitioners, especially Petitioner

 WWW.LIVELAW.IN 44

No.1, in exposing and crusading against the massive fraud

taking place through cricket. Mr Pulakesh Mukhopadhyay while

reviewing the book Bettors Beware could gauge it correctly. Yes,

it has taken years for Petitioner No. 1 to perfect the process. To

continue with the crusade without much support has not been

easy. Yet they have been doing so since they realize it is not

about cricket alone. It is about society as a whole. Being

seasoned citizens they are aware how society is degrading.

They, especially Petitioner no. 2, have scooped many scams and

improprieties. Yet their sense of proportion tells them that this is

a scam unparalleled in terms of money involved, people

involved, and people affected. Taking it head on will send a

strong message all around and will help substantially in

controlling degradation in the society for the benefit of the

coming generations.

69. That in the context of this petition, it may not be out of place to

conclude the submission with following poetic words, and a

quote from the great philosopher Plato:

Andhera gehraaya hai aaj is kadr

Jhooth nahin hai jhooth, sach nahin hai sach

Sach hai jhhoth aur jhooth hai sach

Koi to hoga kahin e khuda!

Jo kare chiraag ek roshan

Dekh paaye mehfil saari

Jhooth ko jhooth, sach ko sach

"We can easily forgive a child who is afraid of the dark; the real

tragedy of life is when men are afraid of the light."

---- PLATO
 WWW.LIVELAW.IN 45

70. That thus, the Petitioners being responsible citizens of this

country feel it their duty to bring the aforesaid facts to the notice

of this Hon’ble Court and to request this Hon’ble Court to appoint

an independent investigating agency to inquire into the

matter/issue for stoppage of massive ongoing public fraud

through and in the name of cricket.

71. That the petitioners are preferring the present writ petition on

inter-alia the following amongst other:

GROUNDS

(a) Because continuous fixed cricket marketed as a

competitive sport is a big fraud on all the honest

cricket lovers, hundreds or tens of millions of them,

across the length and breadth of India, and the world

outside, who pay to watch matches in ground or on

TV, given to understand and believe that competitive

cricket would be played.

(b) Because betting may be illegal in India. So is the

consumption of drugs (banned narcotics). Society

does care for drug addicts, and government acts

against supply of narcotics to protect the vast

population from drug abuse. The fixed cricket

through manipulated matches tempts a vast

population to indulge in betting and then loots them.

Many go bankrupt and many commit suicide,

unknown to the common public. Crores of Indians

are adversely affected.

 WWW.LIVELAW.IN 46

(c) Because as seen earlier mind boggling astronomical

sums that will dwarf any other past or future scam

are transacted through cricket betting. It is a matter

of police records and media reports as brought out in

this petition that the underworld don Dawood

Ibrahim, considered to be India’s enemy number

one, has been controlling cricket betting. It has been

repeatedly brought into light through books of the

petitioners and Petitioner no. 1’s posts on

https://www.facebook.com/BettorsBeware/ how

betting syndicates earn most of the money

transacted on cricket betting day after day and hour

after hour through fixed cricket and scripted

matches. A large portion of this enormous dirty

money is supposed to be continuously being used for

terrorist activities. It has repeatedly been brought

out so in the media and also was mentioned so in a

judgment by Justice Dharmesh Sharma years back in

2010 as revealed from ANNEXURE-P/28.

(d) Because one wrong leads to another. It should not

be difficult for one to visualize how continuation of

fixed and scripted cricket for over a decade in a

country and society where cricket is considered as a

religion would be corrupting the conscience of its

people. Today petitioners feel totally demoralized.

They are sure there would be many like them

suffering silently. Many on social media share their

concern. Many of thousands of those losing big

amounts in betting as a result of fixed and

manipulated cricket would turn to criminal activities

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and loot to make good their losses. Society at large

gets immensely harmed. As brought out earlier,

murders of celebrities have been attributed to cricket

mafia to tell us that cricket fixing was not a small

matter.

(e) Because Match fixing has surfaced numerable times

over the years, but investigations have mostly been

tardy and meaningless. Public remains unaware of

what all goes behind the scenes. That necessitates a

comprehensive meaningful investigation.

(f) Because this is a fraud of proportions

incomprehensible for normal mind, and of magnitude

unimaginable, nurtured by the political power and

facilitated by the media. Top industrialists, celebrities

and Haves of the society, some knowingly some

unknowingly, are its backbone. The masses, in their

ignorance, support this fraud and not only applaud

the perpetrators but treat them as heroes and super

heroes. All the law enforcing agencies continue to

look the other way. Yet, a fraud it is–massive and

highly injurious to the society with grave

implications.

(g) Because big crime is openly and continuously taking

place through fixed cricket matches being played,

telecast, and bet upon on Indian soil.

72. That the Petitioners have not filed any other petition before this

Hon’ble Court or any High Court, seeking the same or similar

relief.
 WWW.LIVELAW.IN 48

73. That the Petitioners have no other equally efficacious alternative

remedy than to approach this Hon’ble Court by way of this

petition.

PRAYER

In the interest of justice and for the facts and circumstances

stated herein above it is most respectfully prayed that this

Hon’ble Court may graciously be pleased to:

1. Allow the instant Writ Petition (Civil) in favour of the petitioners

and against the Respondents; and

2. Issue appropriate writ, order or direction in the nature of

mandamus, appointing/forming a SIT (Special Investigating

Team) to investigate and comprehensively deal with the massive

ongoing public fraud through and in the name of cricket to

unearth the modus operandi of the on-going fraud & crime and

to bring the culprits to book as per law; and

3. Issue appropriate writ, order or direction in the nature of

mandamus to Union of India and/or the authorities concerned to

take appropriate and strict action under the law against all the

perpetrators who have been indulging in this public fraud in the

name of cricket directly or have been facilitating it indirectly or

through inaction when they should have acted, based on the

findings and recommendations of the above mentioned SIT; and

4. Issue appropriate writ, order or direction in the nature of

mandamus for staying IPL matches or any other such leagues

like KPL, TNPL etc. and other international matches too from

taking place in the country till culprits are brought to book or the

SIT formed decides and recommends lifting such a stay.

 WWW.LIVELAW.IN 49

5. Pass any other further order(s) as deemed proper in the light of

the facts and the circumstances of the present case in the larger

interest of the public.

AND FOR THIS ACT OF KINDNESS AND JUSTICE, YOUR

PETITIONERS, AS IS DUTY BOUND, SHALL EVER PRAY.

Filed by

Drawn by: Atul Kumar

Drawn on: (Atul Kumar & Shantanu Guha Ray)
Petitioners-in-person

Filed on : -10-2017