To:

1. The Joint Secretary (NE),
Ministry of Home Affairs,
North Block, New Delhi.
2. The Joint Secretary,
Ministry of External Affairs,
South Block, New Delhi.

Dear Sirs,

Subject: Notice under section 80 of the Code of Civil Procedure

Please take notice that my client (Lama) Shree Narayan Singh, s/o late Raghubar Narayan Singh, r/o 'Uddiyana', Dalip Mahal, Mo Purabsarai, PS Kotwali, Town, PO & Distt. Munger, Bihar, 811 201, will institute a suit against the Union of India, owning and administering the aforesaid departments in a court of competent jurisdiction, after expiry of two months after the service of this notice unless the reliefs claimed hereinbelow are granted to my client within the said period of two months. The relevant facts constituting the cause of action and reliefs claimed are as follows:

1. That my client is a loyal, patriotic and law abiding Indian -- a follower of Buddhism and a direct disciple of 16th Karmapa.
2. That the 16th Karmapa died Oct 1981 in the USA and the process to find and install the 17th Karmapa began subsequently.
3. That the Karmapa is the Head of the Karma Kagyu School or 'panth' of Himalayan Buddhism.
4. That the Dalai Lama is the Head of the Gelugpa School or 'panth' of Himalayan Buddhism.
5. That the two 'panths', viz. the Karma Kagyu and the Gelugpa, are mutually exclusive and totally independent of each other.
6. That the inordinate interest by the Dalai Lama in the selection of the 17th Karmapa is an alarming situation for the country and has given rise to a piquant situation known as the Karmapa Controversy.
7. That after the death of 16th Karmapa in 1981, a child recognized by Indian sadhakas to be the 17th and Indian incarnation of the Karmapa was born amidst various wonderful events on January 6, 1983 in Darjeeling. Ven Drinchen Rinpoche of Mungpo, Darjeeling Distt. West Bengal, officially enthroned this boy as the 17th Gyalwang Karmaa at a simple ceremony at '6 mile basti' in a Mani Lhakhang or Temple near Darjeeling, WB, summer 1986 and the news flashed throughout Darjeeling.
8. That this boy continues to be ignored by the Tibetan leadership for the simple reason that he is not Tibetan and will not play into their hands.
9. That moreover the Govt of the Peoples' Republic of China has also taken an inordinately keen interest in the installation of the 17th Karmapa. In fact Urgyen Trinlay Dorje was the first person to be recognised by the Chinese govt as the first Living Buddha in the history of Communist China in spite of its communist ideology.
10. That moreover the Govt of the PRC above, has categorically stated that Urgyen Trinlay Dorje is its official representative amongst the Tibetan peoples. This is recorded in the video Karmapa - The Two Ways of Divinity.
11. That the Chinese have a long term game plan of annexing the various Himalayan regions in the name of Buddhism.
12. That they have also decided that to establish a base in Sikkim and the easiest method available to them was to install their own candidate as the Karmapa.
13. That therefore, in 1992, the Chinese Government declared a young boy Urgyen Trinlay Dorje as the 17th Karmapa with the support of Tai Situ Rinpoche, a Tibetan Refugee resident in India, who also holds a diplomatic passport issued by the Royal Govt of Bhutan.
14. That the Government of India has been fully aware of these Chinese intentions and has thus refused permission to have the 17th Karmapa brought to India and ritually installed at the Seat of the Karmapa at Rumtek Monastery, Dharma Chakra Centre, Rumtek, PS Ranipool, Dist Gagntok, East Sikkim.
15. That in August 1994, the Ministry of Home Affairs had issued a warning circular No. 28/94 dated 2.8.1994 stating therein that Tai Situ Rinpoche should not be allowed to enter in India from abroad, on the basis of his pro Chinese and anti Indian activities. This ban held good for four years until it was lifted Aug 98 under the most peculiar of circumstances.
16. That despite the opposition of Intelligence Bureau and CBI, the ban on entry of Tai Situ Rinpoche into India was lifted and even though he was restrained from visiting Darjeeling district, he had done so summer 1999 under the pretext of attending the requiem of his purported cousin Lama Gyaltsen, General Secretary of Kalu Rinopche's monastery in Sonada, Darjeeling, for which the GOI had granted permission!
17. That in May 1997 the then Chief Secretary of Sikkim having deeply analyzed various aspects of the Karmapa Controversy, had submitted a confidential report to the Govt. of India, GOI, and various intelligence agencies. In this he refers to the existence of a Chinese long term game plan to annex the Buddhist Himalayan regions of India. He warned that through the selection of Urgyen Trinlay Dorje as the 17th Karmapa, the Govt. of the People's Republic of China was targeting the soft underbelly of the country, using religion to bring about the secession of Sikkim from India.
18. That the aforementioned Urgyen Trinlay Dorje, a resident of the Tibetan Autonomous Region of the Peoples' Republic of China, had made headlines on January 5, 2000 when he emerged in Dharamsala, HP. It is maintained that he had entered India having supposedly made a miraculous and grueling escape from his monastery in Tshurphu, near Lhasa, the capital of the Tibetan Autonomous Region in the middle of winter, successfully evading the ever watchful eyes of the Chinese Army and intelligence agencies!
19. That the Govt of the Peoples' Republic of China, after a protracted silence, had issued a statement to the effect that the Karmapa had gone to India to collect the Black Vajra Crown of the Karmapa and other religious objet d'art from Rumtek Monastery.
20. That the Govt. of India, completely ignoring earlier reports of the Intelligence Bureau, CBI, the report of Chief Secretary of Sikkim, took no steps to verify the issue rather pampered the escapee at the behest of Dalai Lama and on 2nd February 2001, granted the refugee status to the Urgyen Trinlay Dorje.
21. That Andrew Whitehead, the BBC correspondent who had covered the arrival of the said Urgyen Trinlay Dorje in Dharmasala, HP Jan 5 - 8, 2000 had in two reports stated that Urgyen Trinlay Dorje appeared more mature than the 14 ½ he was supposed to be.
22. That the Indian media has also carried detailed reports questioning the authenticity of Urgyen Trinlay Dorje as 17th Karmapa.
23. That in April 2000, the said Urgyen Trinlay Dorje was sent for a thorough medical checkup to the Post Graduate Institute of Medical Research, Chandigarh where a panel of doctors under its then Director Dr. S. K. Sharma, after keeping him in the institute for nearly three weeks and conducting extensive tests, arrived at the conclusion that the person they had examined was a fully grown adult 24-26 years old rather than the 15 year old boy he is claimed by the Dalai Lama.
24. That ironically, the Government of India suppressed these reports and has since taken no action against this conspiracy, which is a national threat.
25. That reports of the medical examinations had by then been leaked out to the press published in many leading newspapers like Amar Ujala, Chandigarh, Nabharat Times, New Delhi and so on etc.
26. That it needs to be explained here that since the 16th Karmapa passed away in October 1981 his incarnation traditionally would have been born only subsequently. Hence by no stretch of imagination could his incarnation have been medically more than 18 years of age in 2000.
27. That thus the attempts to foist the 24 plus year Uurgyen Trinlay Dorje on this country as being the 17th Karmapa surely indicates the existence of a deep-seated conspiracy against this country.
28. That the Dalai Lama has also issued a birth certificate to Urgyen Trinlay Dorje's giving his date of birth as 26-6-1985. This certainly raises questions concerning the purported sanctity of the Dalai Lama and his loyalty towards India.
29. That at the root of this controversy is the supposed 'Prediction Letter' left behind by the late 16th Karmapa and found by Tai Situpa on his own person. It has emerged that the printing on the personal stationery, handwriting and signature on the said Prediction Letter are certainly not those of the late 16th Karmapa, neither is the idiom in accord with any other writings of the 16th Karmapa.
30. That the Government of India, content to obfuscate the issue, and pamper the Dalai Lama, cannot muster the courage to demand that this letter be handed over for a proper forensic analysis. The Government of India is clearly overly anxious to appease the Dalai Lama even at the expense of national security.
31. That a video documentary titled 'Karmapa – Two Ways of Divinity', shot in Beijing, parts of the Tibetan Autonomous Region and New Delhi, produced in the Czech Republic 1996 and currently in the possession of my client, clearly shows the original Urgyen Trinlay Dorje of the appropriate age.
32. That it is the bounden duty of the Government of India, in the interests of national security, to compare the images of Urgyen Trinlay Dorje in this video, with the person it is acclaiming currently to be Urgyen Trinlay Dorje.
33. That even a perfunctory analysis by an untrained person will show that the two are completely different individuals.
34. That a DVD titled ' The Flight of a Karmapa' prepared by Nacht Vision 2001, also in the possession of my client, is in three parts.
35. That the first part shows how Urgyen Trinlay Dorje escaped from Tibet and clandestinely entered into India through Nepal, is an eye opener, highlighting the conspiracy of China to install its own candidate as the Karmapa in India so as to annex the Buddhist Himalayan regions of India and to bring about the secession of Sikkim from India.
36. That the second part shows the manner in which the original boy Urgyen Trinlay Dorje had been replaced by the present individual during a purported meditation retreat.
37. That the third part of this VCD contains a report on the PGI, Chandigarh evaluation of Urgyen Trinlay Dorje.
38. That in spite of such compelling evidence, the Govt of India continues to distance itself from the Karmapa Affair even though it directly impinges on the national security interests of this country.
39. That after the recognition of Urgyen Trinlay Dorje by the Dalai Lama 1992, the law and order situation in Rumtek Monastery, Dharma Chakra Centre, Rumtek, as mentioned above, deteriorated considerably as Tai Situpa and his followers attempted to wrest control of the Seat of the Karmapa by force.
40. That all the residents of the monastery were compelled to sign an oath of allegiance to the Dalai Lama as their sovereign accepting that Urgyen Trinlay Dorje is the genuine Karmapa. Those who did not do so were forced to leave the monastery in one way or another.
41. That in 1993 anarchy prevailed and Tai Situpa and his followers humiliated, beat up and forcibly evicted some 50 or 60 monks of the 16th Karmapa who had been living there peacefully for decades and managing the affairs of the monastery. Their belongings were also confiscated. These monks have subsequently moved down about 2 kms from the monastery and are living in miserable conditions there.
42. That this and other incidents have been reported in Hindustan Times under the heading 'Chinese Coup in Sikkim Monastery'.
43. That yet again Mar 24, 1996 followers of the Dalai Lama and Tai Situpa had attacked the Karmapa International Buddhist Institute, B-19 Qutab Institutional Area, New Delhi 110 019 in broad daylight shouting and pelting stones and so on. They tried to force their entry into the institute but were prevented from doing so by those legitimately inside. A video recording of this episode is also with my client.
44. That thus it is clear that the followers of the Dalai Lama and Tai Situpa have scant respect for the laws of this country and wish to impose their own decisions on the rest of the country irrespective of any other consideration.
45. That my client has repeatedly raised his voice against the Dalai Lama and the fake 17th Karmapa Urgyen Trinlay Dorje by making several representations to Government.
46. That my client was assaulted by a group of about 20 Tibetans at 1230 hrs in Patna in front of the High Court, where he and two other unarmed Indians were demonstrating peacefully, having placed banners proclaiming that the Dalai Lama is a refugee in India, not a king, the Chinese Karmapa is a fake and that Tai Situ is a Chinese agent.
47. That subsequently during a peaceful visit on 25-5-2002, Saga Dawa, the holy day observed by Himalayan Buddhists as the day the historical Buddha gained enlightenment et al, to Dharma Chakra Centre, Rumtek, Sikkim, my client and his 8 yr old son, both dressed as Lamas, were accosted by a group of Dalai Lama loyalists. One lay person named Karma Dradul threatened my client and his family to face dire consequences if my client did not sign document accepting Dalai Lama as his sovereign and his selection of Urgyen Trinlay Dorje as 17th Karmapa as being absolutely correct. My client was compelled to leave the monastery in great humiliation. My client has already made complaint to Director General of Police, Government of Sikkim, Gangtok, but to no avail.
48. That April 26, 03, the Dalai Lama in collusion with various locals, started a fire in the tent of The Great Bombay Circus, then showing in Munger at about 2030 hrs even as my client was inside watching the show. Newspapers later reported that two bombs had been found barely 80' from where my client had been seated.
49. That it is now clear as daylight that Urgyen Trinlay Dorje is being used as a political ploy under the cover of religion to destabilise the country and bring about a degenration in the quality of life.
50. That the govt is empowered by the Constitution of India to take action against the misuse and subversion of religion for political and other purposes.
51. That my client is still receiving the threats for not bowing down before Dalai Lama and is apprehensive about his safety and that of his family's life and property.

You are therefore requested to kindly investigate into the matter as to:-

1. The authenticity of the purported Prediction Letter said to be written by the 16th Karmapa.
2. The manner in which Urgyen Trinlay Dorje, a Tibetan national and a high profile functionary of the Govt of the Peoples' Republic of China, surreptitiously entered India near Gorakhpur, UP, early Jan 2000, without having a proper refugee status and without relevant travel documents.
3. The circumstances behind the grant of refugee status to Urgyen Trinlay Dorje 13 months after his surreptitious entry into India.
4. The medical report of PGI, Chandigarh relating to the age of Urgeyn Trinlay Dorje and the reasons for it being suppressed by the Government of India.
5. Why no effort has been made by the Government of India to ascertain the authenticity of the person claiming to be Urgyen Trinlay Dorje, the 17th Karmapa, with reference to his biological age and other issues mentioned above?
6. Why the Govt of India has been unwilling to acknowledge the role of the Govt of the Peoples' Republic of China in the Karmapa Affair and grant top priority in the interests of the national security of the country to solving this issue?
7. Why, even though the GOI has consistently been informed of the duplicity being perpetrated concerning the said Urgyen Trinlay Dorje portrayed as the 17th Karmapa, it has taken no action until now in this matter? This is with specific reference to the video documentary titled 'Karmapa – Two Ways of Divinity' produced in the Czech Republic 1996 and the DVD titled 'The Flight of a Karmapa' showing how Urgyen Trinlay Dorje escaped from Tibet and entered into India, the replacement by the Chinese of the original Urgyen Thrinlay Dorjee by the person currently maintained as being so, and so on, prepared by Nacht Vision Productions 2001 both of which have been handed over to various intelligence agencies by various persons.
8. Why the Govt of India is lax in dealing with the followers of Urgyen Trinlay Dorje even though they have brazenly broken the law on various occasions?

and declare the Urgyen Trinlay Dorje, the 17th Karmapa declared by Dalai Lama is an impostor and order his expulsion under article 32 of The International Convention on Refugees 1951 on the grounds of National Security and public order for the reasons stated above.

The particulars required under section 80 of the Code of Civil Procedure are as follows:

Name of client:

a] Shree Narayan Singh, Buddhist Lama,
s/o late Raghubar Narayan Singh,
r/o 'Uddiyana', Dalip Mahal,
Mo Purabsarai, PS Kotwali, Town, PO & Distt. Munger, Bihar 811 201. … Plaintiff
Names of OPs: b] 1] The Joint Secretary (NE),
Ministry of Home Affairs, Govt of India,
North Block, New Delhi.

2] The Joint Secretary,
Ministry of External Affairs, Govt of India,
South Block, New Delhi. .... Defendants

c) Cause of Action :

1. The cause of action arose in Aug / Sep 1992 when at the instance of Tai Situpa, the Dalia Lama officially recognised Urgyen Trinlay Dorje as the 17th Karmapa by faxing his approval from the Earth Summit in Rio de Janeiro and which was ratified a few days later by the Govt of the Peoples' Republic of China.

2. The cause of action arose on various dates since Sep 92 and May 1997 during the course of which various law and order problems and about 50 legitimate monks were forcibly thrown out of Rumtek Monastery, by Tai Situpa and his followers, instigated by the Dalai Lama in Rumtek, Sikkim.

3. The cause of action arose on Mar 24, 1996 when the followers of the Dalai Lama under Tai Situpa launched an attack on the Karmapa International Institute, B-19 Qutab Institutional Area, New Delhi 110 019 and elsewhere.

4. The cause of action arose In May 1997 when the then Chief Secretary of Sikkim having deeply analyze various aspects of the Karmapa Controversy had submitted a confidential report to the Govt. of India, GOI, and various intelligence agencies. In this he refers to the existence of a Chinese long term game plan to annex the Buddhist Himalayan regions of India. He warned that through the selection of Urgyen Trinlay Dorje as the 17th Karmapa, the Govt. of the People's Republic of China was targeting the soft underbelly of the country, using religion to bring about the secession of Sikkim from India.

5. The cause of action again arose in January 5, 2000 when the above mentioned Urgyen Trinlay Dorje, a resident of the Tibetan Autonomous Region of the People's Republic of China appeared in Dharamsala, H.P. India in an illegal manner and Government of India overlooked the national security threat.

6. The cause of action arose yet again in Jan 2000 when the Govt of the Peoples' Republic of China issued statements to the effect that Urgyen Trinlay Dorje had gone to India to collect the personal belongings of the Karmapas.

7. The cause of action again arose on 2nd February 2001 when at the behest of Dalai Lama, the same Urgyen Trinlay Dorje was granted a refugee status.

8. The cause of action again arose in 1997 when the video documentary titled 'Karmapa - Two Ways of Divinity', prepared in the Czech Republic was released.

9. The cause of action again arose in 2001 when NACHT Vision Production 2001 released a DVD titled 'The Flight of a Karmapa' showing how Urgyen Trinlay Dorje escaped from Tibet and entered into India. The DVD also highlighted the conspiracy of China to install its own candidate as the Karmapa in India so as to annex the Buddhist Himalayan regions of India and to bring about the secession of Sikkim from India.

d) Reliefs claimed:

The Government of India, particularly the Ministry of External Affairs and Ministry of Home Affairs should enquire into the whole matter regarding the so called declaration Urgyen Trinlay Dorje as 17th Karmapa, declared by Dalai Lama to see whether there is any conspiracy by China to secede Sikkim from India. The enquiry should focus particularly on the authenticity of the purported Predication Letter as also the biological age through appropriate medical tests on the said Urgyen Trinlay Dorje.

And to also order the expulsion of Urgyen Trinlay Dorje under article 32 of The International Convention on Refugee 1951, which provides that a contracting States can expel a refugee on the ground of National Security or Public Order, misrepresentation of facts such as age, and so on.

Yours faithfully,

Dr. Surat Singh
Advocate, Supreme Court & Delhi High Court