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Article 19

"Everyone has the right to freedom of opinion and expression; this right includes freedom to hold opinions without interference

and to seek, receive and impart information and ideas through any media and regardless of frontiers"

Universal Declaration of Human Rights

Case Reference: Raja Imran Khan / 


by German authorities

 Constitutional Complaint against the administrative acts of the German Central Authorities 


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  Constitutional Complaint against the administrative acts of the German Central Authorities /German Courts/ Verfassungsbeschwerde gegen den Verwaltungsakt der Deutschen Zentralen Behörde  Bundesverfassungsgericht, Federal Constitutional Court, Schloßbezirk 3, 76131 Karlsruhe

 I request and invite your official attention to observe the proceedings and works of German family courts, authorities and institutions working in cases of International Child Abduction. Therefore I present to you for your information the following facts with request to please observe, how victimized children, parents and grandparents of national and international child abduction are treated by German authorities. Especially in regard to the proceedings of the German  Authorities in violations of : * the Universal Declaration of Human Rights * the UN-Convention of the Rights of the Child * the Hague Convention on Civil Aspects of International Child Abduction * the German Constitution * German national laws for the protection of the child and the family, i.e., the German civil code, the German criminal code. I request that a neutral panel of people aware and familiar with subject of Abductions, Kidnappings and German 
laws, with Basic Human Rights and Laws! should monitor this case immediately. I have not seen my new born son or the elder son ever since they were abducted from UK on September 15,2004 despite the fact that I had been granted the right to see my children by the German Family court. Instead my repeated requests to several Authorities for my rights to equality of contact have been denied. My wife resorting to lies that she has fears ! and the German courts without any reason or evidence is denying my right to see my children. No one seems to care for the welfare , or Justice for the children ! Is there any organization that really cares to see that these children are not kept apart just because German system wants to apply Nazi  like attitude and practices in its dealings with cases that has a foreign parent involved in particular as the left behind parent. This is not only shameful but it is Child Abuse ! at the hands of the German legal system. I have been told in writing and verbally clearly by my wife indicating the brain washing of my children , such as " I will never let you see your children again , Your son who loved you so much has forgotten you, and your new born and the elder son will not know you as the father " and much worse. I have not seen my children for a long time now and I am being denied contact only on the grounds that I openly expressed the German practices and related them as unfair Nazi like practices. Surely I have been wronged in so many ways by these Authorities that I cannot write here all of it but I must see my children and must have contact on regular basis. For God's sake help me , my children to have our contact.

I and my children are suffering immensely ! and these sufferings cannot be expressed in words , nor silent tears can wash away the pain ,the brain washing ,the Germanizing , Alienating and Estrangement  of these children is an open and sickliest form the most brutal and gross injustice by the German .  We need help ! We need Justice ! and we need it now ! It has already been over fifteen months of abuse at the hands of this system and things are getting worse! 

  "Parental Child Abduction is a Crime against Humanity which is aimed at destroying the basic roots and identity of a child. "Parental Child Abduction is an ongoing lifelong process that works primarily on the concerned child but as well on the left-behind environment and the abducting environment. The ongoing abuse of the child ranges from abduction via Stockholm-Syndrome, Hostile Parenting, Parental Alienation Syndrome to Cultural Alienation. "Violation of the rights of children of separation and divorce is child abuse. "Parental kidnapping is one of the worst forms of child abuse. "Parental Child abduction is Child Abuse. " The human rights of children and the standards to which all governments must aspire in realizing these rights for all children, are most concisely and fully articulated in one international human rights treaty: the Convention on the Rights of the Child.  "It spells out the basic human rights that children everywhere without discrimination have: the right to survival; to develop to the fullest; to protection from harmful influences, abuse and exploitation; and to participate fully in family, cultural and social life. Every right spelled out in the Convention is inherent to the human dignity and harmonious development of every child." 

The German Central Authority commits criminal offenses in their proceedings by * manipulating files and proceedings * by favoring its German born Abductor - Kidnapper ( in this particular case- my wife- Konstanze Gertrud Leuser ), in most unlawful ways, by accepting mere words, allegations and implying that as evidence without proper investigation to deliver Injustice to the other side on purpose. * Gender-biased and discriminatory proceedings*  Whereas the German Central Authority on the one hand are deliberately showing support for Human Rights Laws but on the other hand , fully disregarding these Laws and firmly establishing the child abusing environment in * child abduction * boycott * Divorce cases and more like denial of access being the most common and preferred killer instrument used by the German System ,delivering Injustice and literally Abusing all Rights*

 The German Central Authority in its proceedings has applied: * political ideologies and discriminating processes in regard to the abolition of the core family by disrespecting the natural basic rights of the child to both his/her left behind parent and grandparents and vice versa * child traffic for the profit of the own judicial business is also a fact as Germany is running short on meeting its goal for the shortage of new born birth rate , the required younger generation to fulfill the missing gap for required future generation. A fact it is in Germany's official statistics * While the German Central Authority applies on one hand, the legalization of child abuse in the form of : * use of taking law into one's own hands * international parental child abduction * various forms of alienation undeniably set in as the logical consequence of parental abduction * discrimination of the abducted child and the left-behind environment whereas, on the other hand the legally acting left-behind parent  * is deprived of his basic rights together with the abducted child * is charged with the costs for the legal efforts to prevent child abduction and the infinite forms of alienation as the logical consequence in its wake while violating at the same time > The Universal Declaration of Human Rights < the UN-CRC * the European Convention for the protection of Fundamental Freedoms and human Rights * the Hague Convention on Civil Aspects of International Child Abduction * the German Constitution * the German existing laws for the protection of the child and the family , i.e., civil code and criminal code * highest German jurisdiction.

My brief list of Constitutional Complaint against several kinds of serious violations

I hereby request separate, comprehensive, detailed stances and answers to the individual reports of the reporting project to the UN-CRC and the Hague Conference on International Law within the decision taking of the German Courts and Authorities dealing with my cases unconstitutionally. My written complaints to Human Rights offices in France brought no results either.

All this and many more serious violations ! that took place against me and now my children and we are being kept apart most unfairly because of an unfair Justice system. I am being repeatedly denied all possible contact with my children, I fear for my Life and my well being while I am here in Germany. I also fear for the well being of my children but I am not going to leave Germany , I will stay where ever my children are and I want to establish my rightful contact immediately without any further delays. Can anyone help ? I have a great Lawyer but the German system is a one way street that only leads to a most unfair and most Unjust end. I and my children cannot afford to be victims of the Nazi integrated Justice System. These are not just my views but also of countless Germans I met and heard from.   

  ! The "FACT" of incorrect proceedings in cases of child abduction and boycott of access at German family courts and German authorities are known for a long time on the national and on the international level. Within the democratic and constitutional state of German authorities apply the "Two Phase German Violation model" in all proceedings and cases where there is a Foreign National as the other party , whether its parental child abduction or any other case. I strongly believe that the "Two Phase German Violation Model" is applied to the benefit of the "German Article 13 formula" which is composed of "arbitrary proceedings + undue delay of proceedings = arbitrary decisions" 

The German Article 13 formula works efficiently to : * legalize child abduction by refusing the return of abducted children (The name of this formula is derived from the Article 13 exception of the HC, which is applied in overuse by Germany.) * legalize the Stockholm-Syndrome, boycott of access, hostile parenting, parental alienation, cultural alienation, destruction of the child's identity and roots by manipulating access proceedings. 

I find all this no different the practices of what the Nazi regime did , only that we are not being sent to Gas chambers for a shower but left to deal with it and die trying for our rights or get killed by the brutal and un-educated German Police force and its Justice system. Germany calls itself a civilized Nation wearing a friendly mask but in reality , more of its official courts and offices are an example of Nazi Laws and Practices in process ! as well as it is the case in its Civil offices. What price do we have to pay to for our children? With my American Passport in hand the Judge at the Divorce hearing says " Have you filed for Asylum" While he is fully aware of the case ! and in German language the Judge tells my wife that if I went back to USA it would be good for her, but if I stayed in Germany it would be bad ( schwer ) for her. And he says to her that he is becoming emotional and sympathizes with her !  all that without any evidence but on a preliminary hearing in Tettnang court. The translator provided by the court , she translated twenty minutes of talking by my wife in less than one minute with sympathetic words like " Gott ! Oh my Gott  " while my wife was telling lies . What kind of fairness or Justice is that I ask ? And when I said she spoke for twenty minutes and you translated not even a minute of it ! the translator replied , she was repeating herself ! which was a lie I was being told . Then I was not given half that time to say anything but always interrupted. Then I had asked to see my children, and for my belongings and defense materials my wife is holding onto illegaly, I was told., not now. When my wife was leaving she says, she has Angst ! and the judge bars me from places I have friends and witnesses to go to, while my wife stood about half an hour within ten inches from me laughing at me , telling me that she is brain washing my children before the preliminary hearings, telling me she will never let me see my kids and attacking me and my heritage, my family and uttering racial remarks while smiling outside and then ! literally laughing at me inside the court which the Judge took no notice of during the proceddings , but I had to tell her to have some shame because it was not anything funny that we sit in the court for. These are some of the facts.

 A German Law Professor, Dr. Salgo, said that the sooner the German family justice system was reformed, the less likelihood of some parents wanting to take the law in their hands. How does it come that the Child Abuse of child abduction and boycott of access is tolerated, accepted and encouraged for such a long time in Germany ?

 "The Federal Constitutional Court (Bundesverfassungsgericht, or BVerfG) is Germany's Supreme Court, and its role is essentially "Guardian of the Constitution". The Court's principal areas of jurisdiction are laid down in Article 93 I of the Constitution (Grundgesetz). These areas are also detailed, along with all the Court's procedures, in the Statute of the Court (Bundesverfassungsgerichtgesetz, or BVerfGG). [...] A complaint of unconstitutionality can be brought by any person believing his or her fundamental rights to have been infringed by the act of a public authority, and who has exhausted other routes to a legal remedy. For the purposes of this jurisdiction, Article 93 I not only refers to the fundamental rights listed in Arts 1-19 of the Constitution, but also Arts. 20, 33, 38, 101, 103, and 104. (Verfassungsbeschwerde)1" On 18-20 May 1997 the ANGLO-GERMAN JUDICIAL CONFERENCE, took place in Darlington I think !.There,  Great Britain came up with the following outcome : The Federal Republic of Germany has very obviously and in contrast to other countries more cases in which a child is held in Germany than returns of the child according to the Hague Convention are executed. The court proceedings take multiple times longer than in Great Britain. German judges have little or nearly no experience in the application of international conventions and laws, which is reflected in the processing of international child abductions. This corresponds to the German self-image, that every judge is completely independant. 1 The Federal Constitutional Court, David Thorneloe, 25.10.96

Further reports as reference material for integration into the decision taking of the German Federal Constitutional Courts are below , so I am not looked upon at , as if I had nothing better to do but to make German system look ugly ! but Ugly it is !  I Love people ! but I have no respect for violators of Human Rights and Child abductors or those  a part of it in any way, hiddenly or openly. What kind of civilized nations or people are we ? if we are bent on hurting children ! people and families. That gives birth to Evil and Hate only. Have we not enough problems already, where innocent children and people are being blown up by Terrorists ? where famine and disasters are separating and killing families ! Isn't all that enough that the ,German system must also terrorize , hurt and separate families ?  Enough is enough , do not change good people into bad ones by taking away their children from them. ! I want to see my children now , and live our lives together. I want to see an end of the German horror courts ! violating our rights. Below are some factual cases of abuse ! that somehow got documented .

  Judgments by the European Court of Human Rights due to violations of the European Convention on Fundamental Freedoms and Human Rights by Germany : 

( A small glimpse-I can add plenty more factual data here )


 13 July 2000, Elsholz v. Germany 25735/94, Violation of Art. 6, Art. 8 

 20 September 2001, Suess v. Germany 40324/98, Violation of Art. 6, Art. 8, admissibility decision 

 11 October 2001, Sahin v. Germany 30943/96, Violation of Art. 6, Art. 14 

 11 October 2001, Sommerfeld v. Germany 31871/96, Violation of Art. 6, Art. 8, Art. 14 

 11 October 2001, Hoffmann v. Germany 34045/96, Violation of Art. 6, Art. 8, Art. 14 


 CASE OF KÖNIG v. GERMANY, 28/06/1978, 6232/73 

 CASE OF BOCK v. GERMANY, 29/03/1989, 11118/84 

 CASE OF DEUMELAND v. GERMANY, 29/05/1986, 9384/81 

 CASE OF NIEMIETZ v. GERMANY, 16/12/1992, 13710/88 

 CASE OF PAMMEL v. GERMANY, 01/07/1997, 17820/91 

 CASE OF PROBSTMEIER v. GERMANY, 01/07/1997, 20950/92 

 CASE OF ELSHOLZ v. GERMANY, 13/07/2000, 25735/94 

 CASE OF KLEIN v. GERMANY, 27/07/2000, 33379/96 

 CASE OF METZGER v. GERMANY, 31/05/2001, 37591/97 

 CASE OF SOMMERFELD v. GERMANY, 11/10/2001, 31871/96 

 CASE OF HOFFMAN v. GERMANY, 11/10/2001, 34045/96 

 CASE OF SUESS v. GERMANY, 20/11/2001, 40324/98 

 CASE OF JANSSEN v. GERMANY 20/12/2001, 23959/94 

 UN-Complaint against the Youth Office Aurich, East Frisia, Lower Saxony, Germany (G/SO 215/51 GERM. GEN, 11 January 1999) 

 UN-Complaint against the Youth Office, Wilhelmshaven, East Frisia, Lower Saxony, Germany (G / SO 215 / 51 GERM GEN; 10 September 2001)