Cc:Enquiries Central London County,Enquiries Central London County,Nayantara Sriram
23 Jan at 18:45 Dear 38 Degrees
1. I have completed my investigations of Law and Order in the United Kingdom and in this respect attach my skeleton argument to be presented to the Judge at the above Hearing.
2. It would be useful if you would express your approval or objections accordingly.
Dr Shantanu Panigrahi
3 Hoath Lane
Kent ME8 0SL
17 March 2020 Update:
Claimant’s submission at Court Hearing on 3 April 2020, 2.00 pm, on E35YM660 at the Central London County Court
To The Circuit Judge
Updated Particulars of Claim:
1. I wished to do something positive for World Conservation in order to improve society and initiated the following petitions. Some were approved for hosting whereas others were inexplicably turned down and disabled by 38 Degrees and Liberty. This is what my Appeal is all about. Please refer to the following links in administering your decision on whether I am justified in voicing these concerns or not. If I am not, you may turn down my reconsideration of permission to Appeal the 14 January 2019 dated Order of the Court on E35YM660 (Dr Shantanu Panigrahi vs Mrs Theresa May; nay the present Prime Minister of the United Kingdom). The petitions in question were:
38 Degrees websites:
2. Further evidence for my petitions may be examined at the following websites which have stood the test of time in that they were beyond criticisms from the general public because they are factual representations of the investigations that I have conducted in arriving at the petitions:
3. The evidence in these websites support the Particulars of Claim in the Claim Form and the Appellants Notice of a concerted national and international conspiracy against me to obstruct justice and pervert the course of justice by the States concerned. The government is therefore obliged to take these petitions seriously or give its reasons for not considering them through the normal processes of Parliamentary scrutiny. As you are aware, I have only asked for a nominal £3000 in damages and compensation for what I have suffered over 22 years and which have led me to these petitions because am only progressing the Appeal proceedings because I believe it to be in the public interest nationally and globally.
4. I am happy to answer any questions that you may have for me in relation to these Particulars of Claim and the attached application for extension of time for the formal Appeal proceedings.
Application for extension of time of up to 6 months for E35YM660 Appeal proceedings: submission at an oral hearing to the Circuit Judge on 3 April 2020 at 2.00 pm at the Central London County Court
Court's Reference: Notice of Hearing dated 14 January 2020 on Claim Number E35YM660
Background: The Court Hearing on 3 April 2020, 2.00 pm is for a reconsideration of the Order of the Court dated 24 September 2019 by His Honour Judge Letham for his refusal of permission to Appeal the Order of Deputy District Judge (DDJ) Smith made on 14 January 2019; upon submission within 7 days of receipt of the Order for a reconsideration of permission to appeal, this application being executed on 3 October 2019, 09:21am with a progress report sought on 8 November 2019, 19.59 hours; and leave to submit orally against the Order dated 24 September 2019 at a Hearing for the reconsideration of permission to Appeal being granted by the Court on 14 January 2020.
Justification: The justification for an extension of time of 12-18 months for Appeal proceedings was submitted through an application dated 11 March 2020, 12.26 pm by email and reinforced by email on 16 March 2020 16.33 hours. Claimant’s arguments for the granting an indefinite extension of time submitted then were as follows:
1. His Honour DDJ Smith erred in law in three respects in the Court Order dated 14 January 2019:
(a) by not giving the Claimant the opportunity to seek an estimated extension of time implicit in his delays for the filing of amended Particulars of Claim. The 14 days allowed by DDJ Smith in the 14 January 2019 Order was woefully inadequate for the task of assembling the evidence in this civil litigation in such a manner that the perpetrators of criminal misdemeanours would not be able to defend against the particulars of Claim. It has taken the Claimant over one year from the date of the Order to prove beyond any doubt whatsoever that the National Health Service was grossly negligent or criminally-motivated with the correct diagnosis and treatment of his mental condition over the past 22 years as shown in the 9 January 2020 dated Care Plan from Dr Odesanya of Canada House where the Claimant has now been referred to the Autism Spectrum Diagnostic Services of Maudsley Hospital from initially being diagnosed as having persistent delusional disorder. Notwithstanding this continuing referral, the Claimant submits that he is autistic of a special kind that he describes as satya-advaitic or truth-accommodating behaviour which is not a mental disorder requiring medications of any kind whether of anti-psychotic or anti-depressant types that he hopes the final examination at Maudsley Hospital will reveal in due course. His contention is that satya-advaita condition of Autism Spectrum is a highly desirable behavioural trait that the Claimant has inherited as it aids survival of the human species in the most hostile environment that he has faced in the United Kingdom through the persecution organised intrinsically by Nature as defined under his conception of Brahman-Nature In the vyvaharika level of reality. This remains to be seen.
(b) the Particulars of Claim in the Claim Form were outlined in sufficient detail to begin the process of identifying the responsible respondents who were party to the Claim given that over 30 (close to 40) law firms, solicitors and advocates were approached by the Claimant but were manipulated by the State of Brahman-Nature associated humanity not to cooperate with him in providing legal advice and legal representation by an organisation naming itself ‘Victims of Panigrahi Association’ (VOPA) under the protective umbrella of the Police, the Legal Ombudsman, the Solicitors Regulation Authority and the Financial Ombudsman Service of the United Kingdom; and hence his allegation that the Claimant has made of state-organised persecution by a secretive Big Brother Police State in the United Kingdom. The latest example of this lack of cooperation is the non-acknowledgment of these proceedings by Daker Marriot and Dugdale solicitors which has left me exposed to VOPA’s manipulations of justice. So I am without any form of legal representation today.
(c ) his failure to take account that the principle issue in the Claim was not that past and present Prime Ministers failed in his/her duties to the State (this they discharged) but that the Defendants obstructed justice in office against the Claimant and then repeated this by filing a pointless and malicious defence by stating that the Claim Form’s Particulars of Claim did not show a cause of action against the Defendant who abused his and her position of power to effectively manipulate the respondent institutions and VOPA to perpetrate persecution upon the Claimant and then disable his Blog at Wordpress.com which he had used as the final and ultimate level of justice attained by publicising the persecution that he had suffered. It is further argued that the Prime Minister abused his position of power as the Executive of the nation by not instructing the Lord Chancellor to examine the allegation reported to Her Majesty the Queen under petition that a lawful Hearing had never been implemented by the Ministry of Justice to hear the Claimant’s original complaint 20 years ago against the National Health Service that caused the dismantlement of his scientific career at the University of Greenwich as well as the loss of redundancy payment of around £55,000 or £10,000 per annum as medical retirement from a trumped up charge by the University that the Claimant had been blameworthy of gross misconduct at the workplace and therefore should be dismissed from service summarily without consideration of defence to his actions and conduct; an issue that also led unfairly to his loss of Shell Cashier’s job in the subsequent years following this employment.
(d) in the absence of an appointment from South London and Maudsley NHS Foundation Trust with reference to the email submission of 16 March 2020 16.33 hours copied to the Court to reconsider its rejection of a second-opinion outpatient’s appointment for its Autism Spectrum Diagnostic Services and the simultaneous arrangement made for the Claimant to have an appointment with Canada House on 15 April 2020 at 10.00 for continued assessments of this diagnosis and treatment, it is necessary for Appeal proceedings to be extended for an estimated 6 months pending the receipt of a report (Care Plan) from Canada House.
2. His Honour Judge Letham erred in law on four counts in the Court Order dated 24 September 2019:
(a) by not granting a Hearing there and then when DDJ Smith had also failed to do so considering that the Defendant had continued to keep silent to the repeated emails that the Claimant submitted to the Defendant as his evidence surfaced and permitted him to develop the updated Particulars of Claim that his single-handed investigations continued to generate and the state-persecution was unravelled and uncovered by him;
(b) in being presumptuous that the Appeal had no real prospect of success when the Claimant was still in the process of assembling the evidence of state-organised persecution;
(c) in failing to take account of the fact that the Appellant’s Notice was assembled at a time when the Claimant was being persecuted by VOPA and which continued right up to mid-March 2020;
(d) stating that the Claimant failed to plead a coherent case; this could not be correct if the Claim Form is revisited with these present updated Particulars of Case that the Court received timely and countless emailed documents on as evidence since the Order was issued and which should all now be on the Court File;
(e) the Order of 24 September 2019 was based upon consideration of the Claimants Appellant’s Notice dated the 27 August 2019 and the file of papers. The Claimant has not received full written reasons for the judgment and has yet seen the Court File for contents; and
(f) since no Defence to this updated Particulars of Claim has been filed by the Defendant the correct decision would have been to summarily issue the Orders that the Claimant requested, namely that:
(i) damages and compensation of £15 million to be paid to the Claimant by the UK Treasury; and
(ii) full restoration to be effected of the Claimant’s Wordpress Blog https://shantanup.wordpress.com.
Summary: In United Kingdom’s unwritten Constitution, civil proceedings are fluid and need to be continually updated with Particulars of Claim with one’s imminent circumstances; which I have done. The justification for now granting a 6-month extension of time for the Appeal proceedings to be heard and implemented with a Defence is based upon the aforementioned arguments of a total failure and collapse in Case Management by the above cited Judges concerned with the disposal of Claimant’s Claim; and the continuing appointment made upon the Claimant for another review of the diagnosis and treatment of his mental health by Canada House. Consequently, the appropriate decision would now be for the Circuit Judge to grant the Claimant’s permission to Appeal His Honour Judge Letham’s Order dated 24 September 2019 pending the full Appeal proceedings to come in which the above cited Orders will need to be considered.
Plea submitted in person by: Dr Shantanu Panigrahi (Claimant) 3 Hoath Lane, Wigmore, Gillingham, Kent ME8 0SL; Tel: 07967789619
Dated: 17 March 2020; 8.00 hours