IN THE HIGH COURT OF JUDICATURE AT BOMBAY CIVIL APPELLATE JURISDICTION WRIT PETITION (C) NO. 12022 DIST: MUMBAI Shri. Dilip Lunawat Versus Serum Institute of India Pvt. Ltd. & Ors. ...Respondents INDEX Sr.No. Particulars Page No. 1. __| Synopsis FL 2. | Memo of Petition 1-464 3. | EXHIBIT—A 47-49 A copy of detailed news article dated 4" January, 2021. 4, | EXHIBIT—B 50-64 ‘A copy of the affidavit dated 15" December, 2021 filed before Hon’ble Bombay High Court. 5. EXHIBIT -—C 65 A copy of vaccination certificate of Dr. Snehal Lunawat.EXHIBIT—D A copy of communication dated 2" October, 2021 received from AEFI committee. 66-67 EXHIBIT—-E A copy of order dated 05" October, 2021 given by Ministry of Health & Family Welfare. 68-91 EXHIBIT—F A copy of mail dated 29 April, 2021 send by Petitioner's family to the Government Officials for obtaining the investigation reports. 92-103 EXHIBIT —G A copy of the news article dated 17" July, 2018 published in “metlaw”. 104-407 10. EXIBIT — 1 Colly A copy of AEFI Repott dated 07" December, 2021 & RTI reply by Ministry of Health & Family Welfare dated 17" December, 2021 108-116 il. EXHIBIT -1 A copy of article dated 2" July, 2012 published in the United States’ Department of Justice. 117-122 12. Vakalatanama 123-126) 13. Last Page LaeIN THE HIGH COURT OF JUDICATURE AT BOMBAY CIVIL APPELLATE JURISDICTION WRIT PETITION (C) NO. / 2022 Shri. Dilip Lunawat DIST: MUMBAI «+-Petitioner Versus Serum Institute of India Pvt. Ltd. & Ors, evel -Respondents SYNOPSIS (Sr.No. | Dates Particulars 1 The petitioner is father of deceased Dr. Snehal | Lunawat, who was a doctor and Senior lecturer at SMBT Dental College & Hospital at Dhamangaon near Igatpuri in Nashik, 2 ~~ nthe initial days of Corona Pandemic caused due to SARS-CoV-2 the health workers were asked to get corona vaccines. The petitioner’s daughter who was a doctor was also compelled to take vaccine at the college (she relied on the DCGI, AIMS AND WHO experts). ‘Through various authorities the petitioner’s daughter was assured that, the corona vaccines are completelyH safe and having no risk and threat to her body. 04.01.2021 Interview given to NDTV on 4" January, 2021 by Respondent No. 7, Dr. V.G. Somani, Drug Controller General of India, it is categorically mentioned that, the vaccine are 110% safe, 25.04.2021 Also interviews are given by Respondent No. 8, Dr. Randeep Guleria Director of AIIMS, Delhi and others. They were asking everyone to take vaccines stating that, the vaccines are completely safe. 6. 15.12.2021 | State of Maharashtra is also made clear in a recent affidavit dated 15.12.2021 filed before Hon’ble Bombay High Court. In the said affidavit by Dr. Sadhana Tayade, Director of Health Services, Public Health Depastment, they are relying on FAQ prepared by U.P. Government. ‘There it is mentioned that for any serious or severe side effects there is definite treatment for each such serious effects. | 28.01.2021 ‘Due to such false narrative about complete safety of |vaccine Petitioner's daughter took the vaccine. } 01.03.2021 Due to side effects of vaccine the Petitioner’s daughter died,8. 02.10.2021 [Central Government's AEFI Commitiee admitted that the death of Petitioner’s daughter was due to side effects of Covishield vaccine. 9. ‘The petitioner have filed this petition to give justice to his daughter, to save the life of many more people which are likely to be murdered due to such unlawful activities of the Respondent authorities and to get compensation from the state which later can be recovered from the guilty officers and vaccine manufacturing companies. 10. Hence this petition. Acts to be referred to: 1, Constitution of India. 2. Indian Penal Code 1860. 3. Disaster Management Act, 2005. yw pz Advoéate for Petitioner PétitionerIN THE HIGH COURT OF JUDICATURE AT BOMBAY CIVIL APPELLATE JURISDICTION WRIT PETITION (C) NO. #2022 pistRict:. NASHIK 3 Uader,fricle 22.6 oF cenehnaten In the matter of admission by the Government's AEFI Committee that the death of Petitioner's daughter Dr, Snebal Lunawat due to side effects of vaccines; And In the matter of giving directions from proper prosecutions to prevent further loss of lives: And eoIn the matter of directions for granting compensation to the petitioner and his family. Shri. Dilip Lumawat ) ) ) ) oe Petitioner 1. Serum Institute of India Pvt. Lid. ) Mr. Adar C. Poonawalla (CEO) ) 212/2, Soli Poonawalla Rd, JIC Colony, ) Suryalok Nagari, Hadapsar, ) Pune, Maharashtra 411 028. ) \. 2. Bul Gates fe > Partner of Serum Institute, ) For manufacturing Covishield, ) Having address at ) 2 1i Poonawalla Rd, JIC Colony. ) Suryalok Nagari, Hadapsar, ) Pune, Maharashtra 411 028. ) 3. Union of India ) Through Chief Secreta ) To the Government of India ) New Delhi 1100 01. ) *4, State of Maharashtra d Through Chief Secretary, ) Maharashtra State, ) Mantralaya, Mumbai — 400 023, ) inistry of Health & Family Welfare ) Government of India ) Room No, M8: "A" ) Nirman Bhavan, ) New Dethi-l10 011 ’ 6. Drug Controller General of India ) FDA Bhawan, Kotla Road, J New Delhi 110 002. ) 7. Dr. V.G. Somani ) Drug Controller General of India ) DA Bhawan, Kotla Road, ) New Dethi 110002, a 8. Dr. Randeep Guleria ) Director, AIMS, New Delhi. ) Director, AIMS, New Delhi ) All India Institute of Medical Sciences ) Ansari Nagar, New Delhi ~ 110 029. ) Respondents THE HON'BLE THE CHIEF JUSTICE AND OTHER HON’BLE PUISNE JUDGES OFHIGH COUR’ IDICATURE HIGH COURT OF JUDICATURE AT BOMBAY MOST RESPECTFULLY THE HUMBLE PETITION OF THE PETITIONER ABOVENAMED SHEWETH: 1. “That, the petitioner's daughter was 4 doctor and Senior lectures at SMBT Dental College & Hospital at Dhamangaon near Igatpuri in Nashik. ‘That, in the initial days of Corona Pandemic caused due to SARS-CoV-2 the health workers were asked to get corona vaccines. “That, the petitioner's daughter who was a doctor was also compelled to take vaccine at the college (she relied on the DCGI, AIIMS AND WHO experts). ‘Through various authorities the petitioner's daughter was assured thet, the corona vaccines are completely saf body. and having no risk and threat to her In the interview given to NDTV on 4" January, 2021 by Respondent No. 7, Dr. V.G. Somani, Drag Convroller General of India, it is yentioned that, the vaccine are 110% safe. categorically ‘The relevant portion published in the news reads thus; “Drug Controller General of India ¥G Somant said, "We'll never _approve anything if there is slightest of safety concern. The vaccines are 110 per cent safe", Link:- ot6. bhar: roval-by-drug-regulator-wili-be-indias- A copy of detailed news article is marked and annexed herewith at “Exhibit — A” Similar interviews are given by Respondent No. 8, Dr. Randeep Guleria Director of AIMS, Delhi and others. They were asking everyone to take vaceines by stating thal, the vaccines are completely safe. Interview given by the Dr. Randeep Guleria is available on YouTube. Link:- SCL! bups./7tb wate ‘That, on the basis of such false narratives and misrepresentation by the senior authority like Dr. V.G. Somani and others, and its implementation by the state authorities without any proper verification, the health workers like petitioner's daughter was compelled to get vaccine, ‘That, the stand of State of Maharashtra is also made clear in a recent affidavit dated 15.12.2021 filed before Hon'ble Bombay High Court. In the said affidavit by Dr. Sadhana Tayade, Director of Health Services, Public Health Department, they are relying on Frequently Asked Questions which are prepared by U.P, Government. There it is mentioned that for any serious or severe side effects there is definite treatment for each such serious effects, Said Question No. 16 reads thus: “What ave the common side effects that I can expect afier Vaccination?% 1. Fever, headaches, body aches, fatigne. injection site pain are the common side effects, and they are manageable by a short course of Paracetamol. Most resolve by 2-3 days. You are observed for 30 mimes after receiving the dose. for any serious or severe effects, and even though they are rare to ocour, there is definite treatment for each such serious A copy of the said affidavit dated 15.12.2021 is marked and annexed shibi BY. herewith at “ Due to such faise narrative about complete safety of vaccines, my daughter took Covishield vaccine on 28" January, 2021. A copy of the vaccination certificate of Dr. Snchal Lunawt is marked and annexed herewith at “Exhibit, ‘Thal, due to the side effects of vacetnes the comptainamt’s daughter died on I“Mareh, 2021, The Central Government's AEFI committee on 2” October, 2021 admitted that the death of complainant's daughter was due to side effects of Covishield vaccine. A copy of communication received trom AEFI committee is marked and annexed herewith at “Exhibit D*. Hence, this petition is being filed to give justice to my daughter and in order to save the life of many more people which are likely to be murdered due to such unlawful activities of the Respondent authorities wie13. 14. So far as the prosecution of accused are concerned, it is made clear that the Awaken India Movement has taken the cause for punishing the guilty and therefore the petitioner is not making the said prayers in the petition. That, the chronology and details of the death of the petitioner's daughter from vaccination and the hardship suffered by the petitioner's Family are mentioned in the letter written by my son Shri, Shubham Dilip Lunawat on 13" April, 2021 10 Ms, Malini Aisola, the Co-convenor, All India Drug Action Network (AIDAN). Suid letter reads thus: “To Ms. Malini Aisota Co-Convenor All India Drug Action Nerwork (AIDAN) 43 April 2021 fam Shubham Lunawai. brother of deceased Dr. Snehat Limawat who was working in SMBT College, Nasik as a lecturer, My sister took her first dose of Covishield on 28th January 2021 in Nasik. On Sth of February she had a headache. She showed it 10 the doctors who diagnosed a mild migraine for which she took medicines and felt better. On 5" Feb evening, she came to Aurangabad from where she traveled to Delhi Jor attending a workshop in Gurgaon. She reached Gurgaon on 6th February afternoon and on the midnight of 7th Feb at 2am, she had multiple episodes of vomiting till morning Sam with fatigue.She was rushed to nearby Aryan hospital, Gurgaon where they said there might be bleeding in the brain and suspected venous sinus thrombosis. As there was no neurosurgeon available there, we rushed her to the Paras hospital, Gurgaon, She was hospitalised there for 14 days. She had bleeding, clot formation with low platelets which are all signs of the same condition linked to Astra Zeneca and Covishield vaccine in foreign countries and few in India now, Doctors detected venous sinus thrombosis which was followed by intracranial brain hemorrhage. They performed craniotomy and clot removal surgery. Thereafter she was on a ventilator for 14 days in Gurgaon but her condition did not improve. She had been tested several times for COVID-L9 from the date of adinission till the Ith day of her admission to hospital, The results were negative. We brought her through an cir ambulance to United Ciima hospital in Aurangabad. She continued to be on the ventilator for 8 days but condition did not improve, She passed away on Ist March. We would like your help in bringing our case to the notice of the cuthorities as my sister has been the victan of fatal side effects of the Covishield vaccine. We want 10 save future lives. 1 have earlier written to several offices including DHO Aurangabad, FDA Haryana and District Immunization ede earsanbnn Bande VAIO er a eee Ba ereOfficer. Gurgaon and Drug Controller General of India (DEGI. 1 even tried to inform the highest authorities by writing 10 the Health Minister of Maharashtra and the Union Health Minister and alsa making a request through the PMO grievance portal. Today, 1 received a reply from the Haryana FDA that conveyed that because notification of an adverse event afier vaccination is the responsibility of the district where vaccination took place, the Civil Surgeon in Guragram will be writing to the District officials in Nasik to report the case. This means that in spite of so many days passing nce my sister's condition first deteriorated, weeks of her being hospitalived and more than a month since her demise, her case has not been reported 10 the government? My other sister, Samruddhi, had spoken to the incharge of the vaccination drive, Dr. Nobel Gomez, SMBT institute, Nasik over the phone in March. At that time, he immediately Said that the issue was not due to vaccination. When she said that this was in fact a matter of discussion, and that we wanted to report it to the Government Medical Authorities and requested for his help, he did not reply to our concern My father (the petitioner) hud even corresponded with the = Serum Instinite of India, the manufacturer of Covishield Vaceine asking for help and research in my sister's cas e, as the doctors had expressed a doubt about the side effect of body on %" February, 2021 such vaccination in my siste immediately the next day after the second operation ‘BEFORE ME s ES\ lee GANGADHAS PARA AIO carried out, But the company completely denied helping us and dismissed our message saying that my sister's condition was a coincidence and was not due to the vaveine. The full conversation with the Serum Institute of liedia is produced in Para No. 15.4. Therefore, I have til! date not received any confirmation that my sister's case has been duly reported to she authorities that are looking into adverse events of vaccines, 1 learned from newspaper reports that a governmental committee is looking into vaccine adverse effects. 1 feel itis important that it can take a look at my sister's case which can also provide guidance and safety measures on vaccination to save sivailar further deaths of others. Please see below i am attaching her case summary and some of the lesters that I have sent. Request you to help us urgently Regar Shubhamn Dilip Lunawat ‘Saubhagya”, Tirupati garden Tapadiya Nagar Darga Road Aurangabad, Maharashtra Phone: 8668606224/ 9325620758 Email: shubhantlunawat98@ gmail.com”45. That, the complicity of Serum Institute and its officers is ex-facie clear from the very fact that, they gave a false response to the email that there is no such side effect found in clinical wials of the Covishield. 15.1, First E-mail was sent by Dilip Lunawat to Serum Institute on 9! February, 2021 reads thus; : Subject: Covishield vaccination and impact. Dear sir, my daughter Dr. Snekat Dilip Lunawat ~ have taken the vaccination on 27/01/2021 at SMBT College Nasik and thereafter there was minor headache and fever on next day but on 4th of February she had again severe headache, vomiting hence after checking in college medical departments on Sth, she has been given medicine. She came fo Aurangabad on Sth night and further for her certificate conference she came to Delhi by flight reached @3.30 pm, but in the same tete night she hed severe headache and unstoppable vomiting and due to weakness, she has to pickup by avo/three people and send for hospitalisation in Gurgaon. | am enclosing the ease summary in pdf for your research department.I would like to study by your research department and diagnosis the caseSimilar cases has been observed in USA. T hope you will do the needful for betterment of the society ct large. If any further information required you can contact me. Please note this is not a complaint but whatever corrective actions required should : be taken. With regards. Dilip k Lunawat 9225752831 Sent from RediffinaiiNG on Android ee@ 15.2, ‘The reply dated 10" February, 2021 given by Dr. Chetanraj Bhamare Pune reads thus; of Serum Institute, ear Mr. Lunawat, We acknowledge the receipt of your report of adverse event. For the assessment of the case kindly provide the barch details of vaccine administered. Kindly note that, Covishield does not cause transverse sinus thrombosis or infarcts Pleaxe refer the details of COVISHIELD available online at hitps:/Avww.seruminstitute. com/praduct_ covishield php. Regards. Dr, Chetanraj Bhamare, MBBS MD Safety Phy Clinical Research and Pharmacovigiiance Dept, ‘ian, Serum Institute of India Pvt. Lul., Pune (india). 15.3. The email dated 13" February, 2021 sent by Dilip K. Lunawat reads thus! “Dear sirs, this has reference te our earlier emails, we are enclosing the medical case stommary of my daughter Dr Snehal Diliy Lunawat and given below the cases links around india, which ave similar to our case huips./Avww.cnbetv18.con/healiheare/I6-deaths-reported= among-vaccine-recipients-govt-savs-not-linked-to-vaccine- patient-groups-demane -more-daia-819949}.him ont ee FORE ME. ’ Ze\\\~ GANGADHAR Rann Vaimya Revacnte, Notary one ef Mok No Steceaus Soe Ne 1ss08htps:/timesofindia.indiatimes.com/eity/bengalurwkarnatak a-asha-worker-dies- 12-days-after-vaccination-in- belagavifarticteshowy/807 12499,cms we again request you to find out by your research team to stop further deaths due to vaccination. If you have any research done on thrombosis due to covishield please share. Qur patient is critical and suffering. It might help us. Thanks” 15.4, The reply dated 15 February, 2021 given by Dr. Chetanraj Bhamare of Serum Institute, Pune reads thus: “Dear Mr. Limawat, Thank you for sharing medical case summary of Dr. Snekal. As we could find in the news reports, you have shared, the deaths were not caused by vaccine and were the coincidental events with vaccination. The govt. has also investigated and concluded the cases as not related to the vaccination. In any icidental events and large immunization compaign such co deaths do occur. they are not caused by the vaccine but are actually a part of background rate of events As informed to you earlier, Covishield do not cause thrombosis or any other cardiovascular events The known adverse reactions are injection site reactions, fever, headache, malaise, fatigue, ete. The majority of adverse reactions are mild to moderate in severity and Vee usually resolved within a few days of vaccination.Please refer the details of COVISHIELD available online at hitps:fivww. seruminstitute. com/product ld php. Kindly consult your physician for the management of the case Dr. Chetanraj Bhamare, MBBS MD Safety Physician Clinical Research and Pharmacovigitance Dept, Serum Institute of India Pvt, Lid., Pune (India). ” 15.8, Shri, Elangbam Robert Singh, Director (RCH). Ministry of Health & Family Welfare vide his order dated 05.10.2021 provided the information. The Question No. 1 proves the dishonesty and matafides of Serum Institute of India, ‘The Question No. | in reply given by Health Ministry reads tinus; aint 1: Details of all the Cases of specific embolic and thrombotic events in combination with low levels of blood platelets (thrombocytopenia) found in the patients all over India reported with you post Covishield vaccination, Details should contain Name, Age, Gender, Place, Hospital name. Information: Two suspected cases of embolic and thrombotic events in combination with low levels of blood platelets (thrombocytopenia) following Covishield vaccination were identified in 498 cases rapidly reviewed aud assessed by mediced experts, Both these cases were in females above $0 years of age. Personal details the reported cases are not shared under Section 8(1\j) of the RTI Act, 2005." aa GE Re ME Oe SANGADHAR RAMU! VAIDYA, Baob Nolseaegease SS boA copy of order dated 05.10.2021 given by Ministry of Health & Family Welfare is marked and annexed herewith at “Exhibit-E” 16. In the Economics Times dated 29.04.2021 and Times of India dated 23.04.2021 Dr. Snehal Lunawat’s case was published quoting headlines “WHO to look into death of Indian Doctor pust Jab". WHO had ordered investigation which was camied out by the AEFI Committee. For obtaining the investigation reports, Petitioner's family contacted the government officials through various forums such as INGRAMs, DHO- Aurangabad and the other mentioned authorities as specified in the detailed mail is marked and annexed herewith at “Exhibit —F”, But no information was shared with us by any of the Government Officials even after repeated calls, mails and messages, Hence, we filed an RTI on 12.05,2021 asking the government officials to share the investigation reparts of Dr, Snehal with us. The RTI was initially rejected by the CPIO und then finally information was shared with us alter filing the case with the Ficst Appellate Authority on 03.10.2021. A copy of such RTI reply received is marked and annexed herewith at 17. That on 9" November, 2021 Canada’s Health Department also warmed about side effects on Covishield: Link:- hups://globatnews.ca/news/8362363/astrazeneen- autoimmune-diyornder-healih-canada-updatef oe id-vaccine- BSESORE ME FE gancannes nana vatnvaHealth Canada is updating the label for the AstraZeneca and Johnson & — Johnson COVID- 9 vaccines to add immune thrombocytopenia (ITP), an autoimmune condition, as a potential side effect.” 18. That, in March 2021, around 18 European countries banned Astrazeneca (Covishield) vaccine due to death caused because of side effects of blood clotting due to vaccination Link:- 19. That WHO on 26" July, 2021 also warned people about GBS caused due to Covishield. Link e-who-gaevs- 20, State authority was duty-bound to publish the side effects of vaccines and also to publish that there cannot be any force or mandate for taking vaceine as done by the Japan Government. But Respondent No, 4 adopted unlawful, unconstitutional approach. 20.4, That, Hon’ble High Court in Master Haridaan Kumar Vs. Union of India 2019 SCC OnLine Del 11929, it is ruled as under; onl14, aitentio: indication of the side effects and contraindications in the advertisement would discourage varents or guardians from consenting to the MR campaign and, therefore, the same should be avoided, is unmerited. The entire object of issuing advertisements is to ensure that necessary information is available to all parents/guardians in_order that they can take _an informed decision. The respondents are not only required to indicate the benefits of the MR vaccine but also indicate the side effects or contraindications so that the parents/guardians can take an informed decision whether the vaccine is to be administered to their wards/children 45. In view of the above, it is directed as under: (A) MR vaccines will not be administered to those students whose parents/guardians have declined 10 give their consent. The said vaccination will be administered onty to those students whose parents have given their consent either by returning the consent forms or by conforming the same directly to the class teacher/nodal teacher and also to students whose parents/guardians cannot be contacted despite best efforts by the class teacheriodal teacher and who have otherwise not indicated to the contrary (1) Directorate of Family Welfare shall issue quarter page advisements in various newspapers as indicated by the respondents, namely, The Hindustan Times, The Times of Andia, The Hindi, The Pioneer, The Indian Express, Dethi Tribune, Mail Today, The Asian Age, Navbharat Times, OsaDainik Jagran, Punjab Kesari, Hindustan, Amar Ujala, Navodaya Times, Hamara Samaj, Pratap, Dour-e-Jadeed, Jathedar, Jon Ekta, The advertisements shall also indicate that the vaccination shall be administered with Auto Disable Syringes to the eligible children by Auxitiary Nurse Midwifery. The advertisement shall also clearly indicate the side effects and contraindications as may be finalised by the Department of Preventive Medicine, All India Institute of Medical Sciences.” 20.1.1. That the WHO has warned the people getting CoviShield (AstraZeneca) vaccines to be careful as it is causing a serious paralytic disease GBS (Guillain Barre Syndrome). Link:- hups:/Avww.who int/news/item/26-07-2021 -staiement-of-the-who-gaevs- covid-19-subcommitiee-on-gbs 20.1.2, That, in India, there are Lacs of such cases and around 12,000 vaccine deaths are reported in media. But AEFI committee is not working fairly and properly. Link: INJRIOD_Y hups:/drive google, vfilevdéwikela6 KDeUis THNE tw: Péview!uspssharing pentd/ILZJDp-ubGBIVI- ifdows google com/doc! nhkRieQG/edit?usp=shuringse ouid= 10385662769594452559 eee caer20.2, That the provisions of Universal Declaration on Bioethics and Human Rights. 2005 also mandate for giving detailed information to public for getting informed consent. Relevant Articles reads thu: “Article 3 — Human dignity and human rights 1. Hunan dignity, human rights and fimdamental freedoms are to be fully respected, 2. The interests and welfare of the individual should have priority over the sole interest of science or society. Article 6 — Consent intervention is only to be carried out with the prior, free and informed consent of the person concerned, based on adequate information. The consent should, where appropriate, be express and may be withdrawn by the person concerned at any time and far any reason without disadvantage or prejudice, : 2. Scientific research should only be carried out with the prior, free, express and informed consent of the person concerned. The information should be adequate, provided in 4 comprehensible form and should include modalities for withdrawal of consent. Consent may be withdrawn by the person concemed at any time and for any reason without le any disadvamage or f rejudice. Exceptions to this pri should be made only in accordance with ethical and fegal standards adopted by States, consistent with the principlesand provisions set out in this Declaration, in particular in Article 27, and international human rights lav, 3. In appropriate cases of research carried out on a group of persons or a community, additional agreement of the legal representatives of the group or community concerned may be sought. it no case should @ collective commuity agreement or the consent of a community leader or other authority substitute for an individual's informed consent. Article 7 - Persons without the capacity to consent In accordance with domestic law, special protection is 10 be given 10 persons who do not have the capacity to consent: (a) authorisetion for research and medical practice should be obtained in accordance with the best interest of the person concemed and in accordance with domestic law. However, the person concerned should be involved to the greatest extent possible in the decision-making process of consent, as well as that of withdrawing consent: (b) research should only be carried out for his or her divect health benefit, subject 10 the authorization and the protective conditions prescribed by taw, and if there is na research alternative of comparable effectiveness with research participants able ro consent. Research which does not have potential direct health benefit should only be undertaken by way of exception, with the utmost restraint, exposing the person only fo a minimal risk and minimal burden and, if the research is expected to contribute to the hecith benefit of other persons in the same category, subject to the conditions aprescribed by law and compatible with the protection of the individual's human rights. Refusal of such persons to take part in research should be respected. Article 8 — Respect for human vulnerability and personal integrity In applying and advancing scientific knowledge, medical practice and associated technologies, human vulnerability should be taken into account. Individuals and groups of special vulnerability should be protected and the personal integrity of such individuals respected. Article 16 ~ Protecting future generations The impact of life sciences on future generations, inchiding on their genetic constitution, should be given due regard. Application of the principles Article 18 ~ Decision-making and addressing bioethical issues 1. Professionalism, honesty, integrity and transparency in decision-making shauld be promoted, in particular declarations of all conflicts of interest and apprepriate sharing of knowledge, Every endeavour should be inade to use the best available scientific kuowledge and methodology in addressing and perivdically reviewing bivethical issues 2. Persons and professionals concerned and society as a whole should be engaged in dialogue on a regular basis vei ee3. Opportunities for informed pluralistic public debate, seeking the expression of ail relevant opinions, should be promoted.” 20.3. In Montgomery Vs. Lanarkshire Health Board [2015] UKSC 11, it is ruled as under; “89. Three further points should be made. First, it follows from this approach that the assessment of whether a risk tg material cannot be reduced to percentages. The significance of a given risk is likely 10 reflect a variety of factor’ besides its magnitude: for example, the nature of the risk, the effect which its occurrence would have upon the life of the patient, the importance to the patient of the benefits sought to be achieved by the treatment, the alternatives available, and the risks involved in those alternatives. The assessment és therefore fact-sensitive, and sensitive alsa to the characteristics of the patient 77. These developments in society are reflected in professional practice. The court has been referred in particular to the guidance given fo doctors by the General Medical C present appeal, Que of the documents currently in force (Good Medical Practice (2013}) states, under the heading “The duties of a doctor registered with the General cil, who participated as interveners in the “Work in partnership with patients, Listen to, and respond fo, their concerns and preferences. Give patients the information they _want_or_need_in_a way they can ontunderstand. Respect patients’ right to reach decisions with you about their treatment and care,” 78. Another current document (Consent: patients and doctors making decisions together (2008) describes a basic model of partnership between doctor and patient: “The doctor explains the options to the patient, setting out the potential benefits, risks, burdens and side effects of ¢ach option, including the option to have no treatment, The doctor may recommend a_ particular option which they believe to be best for the patient, but they must not put pressure on the patient to accept their advice. The patient weighs up the potential benefits, risks and burdens of the various options as well as any non-clinical issues that are relevant to them. The patient decides whether to accept any of the options and, if so, which one, " (para 5) In relation to risks, in particular, the doctment advises that the doctor must tell patients if wearment might result in a Hand serious adverse outcome, even if the risk iv very sin should also tell patients about less serious complications if they occur frequently (para 32). The submissions on behalf of the General Medical Councit acknowledged. in relation to these documents, that an approach based upon the infarmed involvement of patients in their treatment, rather than their being passive and potemially reluctant recipients, can have therapeutic benefits, and is regarded as an integral aspect of professionalism in treatment,80. In addition to these developments in society and in medical practice, there have also heen developments in the law, Under the stimulus of the Human Rights Act 1998, the courts have become increasingly conscious of the extent to which the common law reflects fundamental values, As Lord Scarman pointed out in Sidaway's case, these include the value of self-determination (see, for example, S (An infamt) v S [1972] AC 24, 43 per Lord Reid: McColl v Strathclyde Regional Council 1983 SC 225, 241; Airedale NHS Trust v Bland [1993] AC 789, 864 per Lord Goff of Chieveley}, As well as underlying aspects of the common law, that value also underlies the right 1o respect for private life protected by article 8 of the European Convention on Human Rights. The resulting duty to involve the patient in decisions relating to her treatment has been recognised in judgments of the such as Glass ¥ United ae v Poland (2007) 45 EHRR 947, as well as in a number of decisions of courts in European Court of Human Righ Kingdom (2004) EHRR 341 and Ts the United Kingdom. The same value is also reflected more specifically in other international instruments: see, in particular. article 5 of the Convention for the Protection of Human Rights and Dignity of the Human Being with regard to the Application of Biology and Medicine: Convention on Human Rights and Biomedicine, concluded by the member states of the Council of Europe, other states and the European Community at Oviedo on 4 April 1997. 82. In the law of negligence, this approach entails a duty on the part of doctors to take reasonable care to ensure onethat a patient is aware of material risks of injury that are inherent in treatment. This can be understood, within the traditional framework of negligence, as a duty of care to avoid exposing a person 10 a risk of injury which she would otherwise have avoided, but it is also the counterpart of the patient's entitlement 10 decide whether or not to incur that risk. The existence of that entitlement, and the fact that its exercise does not depend exclusively on medical considerations, are important. They point to a fundamental distinction between, on the one hand, the doctor's role when consiel “ring possible investigatory or treatment options and, on the other, her role in discussing with the patient any reconmended treatment and possible alternatives, and the risks of injury which may be involved. ional skill and 83. The former role is an exercise of pro] Judgment: what risks of injury are involved in an operation, for example, is a matter falling within the expertise of members of the medical profession. But it is a non sequitur to conclude that the question whether « risk of injury, or the availability of an alternative form of treatment, ought to be discussed with the patient is aiso a matter of purely professional judgment, The doctor's advisory role cannot be regarded as solely an exercise of medical skifl without leaving out of account the patient’s entitlement to decide on the risks to her health which she is willing to run (a decision which may be influenced by non-medical considerations). Responsibility for determining the nature and extent of a Vege SEFSORE ME . Zoe@ person’s rights rests with the courts, nat with the medical professions. 87. The correct position, in relation to the risks of injury involved in treatment, can now be seen to be substantially that adopted in Sidaway by Lord Scarman, and by Lord Woolf MR in Pearce, subject 10 the refinement made by the High Court of Austratia in Rogers v Whitaker, which we have discussed at paras 77-73. An adult person of sound mind is entitled to decide which, if any, of the available forms of treatment to undergo, and her consent must be obtained before treatment interfering with her bodily integrity is undertaker, The doctor is therefore under a duty to take reasonable care to ensure that the patient is aware of any material risks involved in any recommended treatment, and of any reasonable alternative or variant treatments, The test of materiality ix whether. in the circumnsrans ces of the particular case, « reasonable person in the patient's pasition would be likely to attach significan to the risk, or the doctor is or should reasonably be aware that the particular patient would be likely to attach significance to it. 90. Secondly, the doctor's advisory role involves dialogue, the aim of which is to ensure that the patient understands the seriousness of her condition, and the anticipated benefits and risks of the proposed treatment and any reasonable aliernatives, so that she is then in a position to make an informed decision. This role will only be performed effectively if the information provided is Neacomprehensible. The doctor's duty is not therefore fulfilled by bombarding the patient with technical information which she cannot reasonably be expected to grasp, let alone by routinely demanding her signature on a consent forn 116. Ay NICE (2011) puis it, “Pregnant women should be offered evidence-based information and support to enable them 10 make informed decisions about their care and treatment” (para 1.1.1.1). Gone are the days when it was thought that, on becoming pregnant, a woman lost, not only her capacity, but also her right to act as a genuinely autonomous human being.” 20.4. But Respondent No.4 and other state authorities failed to perform its duyy as per law and vaccinated the public by suppressing the data and it is a case of cheating. 20.4.1. That, recently the Health Ministry of Japan bas made Following . declaration/orders on their website: “Consent to vaccination Although we encourage all citizens to receive the COVID-19 vaccination, it is not compulsory or mandatory. Vaccination will be given only with the consent of the person to be vaccinated after the information provided, Please get vaccinated of your own decision, understanding both the effectiveness in preventing infectious diseases and the risk of side effects. No vaccination will be given without consent, Please do not force anyone in your workplace ar those who oe sername Mabecses GANGADHAParound you to be vaccinated, und do not discriminate against those who have not been vaccinated, 20.4.2. Furthermore, the Government of Japan also asked the citizens to make complain to Human Rights Division if there is any discrimination on the besis of vaccination status. 20.4.3. The government made companies of Covid “vaccines” to warn of dangerous and potentially deadly side effects such as myocarditis. In addition, the country is reaffirming its commutment to adverse event reporting requirements to ensure all possible side effects are documented. For more details read the article: hupsi/rairfoundation.convaiert-japan-places-myocarditis-warn! on-vaccines- requires-informed-consent/ ‘Alert: Japan Places Myocarditis Waring on *Vaccines’ - Requires Informed Consent Amy Mek. 20.4.4. That the above declaration is mandatory to all countries across the world because of Universal Declaration on Bioethics & Human Rights, 2005 and also as per Jaw laid down in Montgomery's case [2015] UKSC 1 Airdale NHS Trust Vs. Bland (1993) | All ER 821, Common Cause Ys. Union of India (2018) SSCC 1, Registrar General Vs. State of Meghalava 2021 SCC OnLine Megh 130, 20.4.8. That as per legal requirements, there should be a mandatory procedure 10 him the vaccine. In Ajav take written consent of the person before givi Gautam Vs. Amritsar Eye Clinie & Ors. 2010 SCC OnLine NCDRC 96, iv is observed as under: a gerore M ye HAR RAMU VEIDYA SANG AO ory Gaul. af inl San ic Sassoses9 Ree No VaEeFAnan st GANGADHAR SANT tied “10, Now. it is to be seen if the opposite party-doctor was entitled 10 publish such an advertisement or whether it was unethical on his part to do so. tn this context, we may notice the injunction of the Medical Council of India under Regulation no. 6.1 of the Code of Ethics Regulations, 2002, which reads ax under: ‘Chapter 6 6. UNETHICAL ACTS: A physician shall not aid or aber or commit any of the following acts, which shall be construed as unethical - 6.4 Advertising: 6.11 Soliciting of patients directly or indirectly, by a physician, by a group of physicians or by institutions or organisations is unethical. A physician shail nor make use of him/her (or his/her name) as subject of any form or manner of advertising or publicity through any mode either alone or in conjunction with others which is of such a character as to invite attention to him or to his professional pasition, skill, qualification, achievements, attainments, _ specialities, appoiniments, associations, affiliations or honours and/or of such character as would ordinarily result in his. self aggrandisement, A ph ician shall not give ta any person, whether for compensation or otherwise, any approval, recommendation, endorsement, certificate, report or Statement with respect of any drug, medicine, nostrum remedy. surgical, or therapeutic article, apparatus or appliance or any commercial product or article with respect of any property, quality or use thereof or any test, VEL eeedemonstration or trial thereof, for use in connection with his name, signature, or photograph in any form or manner of advertising through any mode nor shall he boast of cases, operations, cures or remedies or permit the publication of report thereof through any mode. A medical practitioner is however permitted to make a formal announcement in press regarding the following: 1. On starting practice. 2. On change of type of practice, 3. On changing address. 4. On temporary absence from duty. 5. On resumption of another practice, 6. On succeeding to another practice. 7. Public declaration of charges 6.1.2 Printing of self photograph, er any such material of publicity in the lenter head or on sign board of the consulting room or any such clinical establishment shail be garded as acts of self advertisement anid unethical conduct on the part of the physician. However, printing of sketches, diagrams, picture of human system shall not be treated as unethical Cleary the doctor violated the above mentioned Regulation which by itself was unethical conduct and hence constitute deficiency in service. Moreover, the contents of the advertisement appear to be prima facie misleading to the reader inasmuch as it gives an impression that any defective vision could be corrected to the normal vision of 6/6 at respondent no. I-hospital by the use of the excimer laser machine acquired by the Oerespondent no. 1 & 2. The complainant states that having come across such a misleading advertisement, he contacted respondent no. 2-doctor who also gave assurance and promised that defect in his eye would be fully corrected and cured and only shereafier he agreed to undergo the PRK surgery at the hands of the respondent-doctor. The respondent-doctor denies that te had given any such arssurance/promise, The expert medical opinion received from the Rajendra Prasad Centre for Opthalmic Sciences would clearly show that such @ claim as was published in the above mentioned advertisement was untenable altogether aud. therefore, amounted to representation by the respondent-doctor which could not have been fulfilled. The respondent-doctor also claimed that he had explained the implications of such a surgery and had obtained the consent of the complainant. As noticed above, the doctor and the hospital have faited to produce the consent form which the complainant had purportedly signed before undergoing the PRK surgery. However, reliance is placed on the format of other consent forms obtained from other patients which contain: some admissions on the part of the palients that they had been explained the implications of the procedure. 11, Having considered the matter in its entirety, we are of the opinion that the finding of the State Commission that the complainant — has failed ta establish any negligence/deficiency in service on the part of the ing him the treatment respondent-doctor and hospitad in y way of PRK surgery is justified on record and needs no oeinterference. However. it has also been established on record that the doctor and the hospital are guilty of adopting unfair trade practice within the meanin section 2(1)(r) of the Consumer Protection Act, 1986 as well_as_violating the Code of Ethics Regulations (Regulation no. 6.1) by _ publishing _ misleading advertisement. They are also held guilty of not having been able to produce/maintain the record, ie., consent form said to have been signed by the complainant before undertaking PRK_ surgery. The complainant_is_entitled 10 some reasonable compensation on these two counts, 12.in our view. it wold meet the ends of justice if respondents no. 1 & 2 are called upon to pay hunpsum compensation of Rs. 1,00,000/- 10 the complainant on these counts and a direction is given to respondent no. I and the doctor to forthwith withdraw any suck advertisement in electronic, print or any other media and desist from doing so.in future, 13, In the resutt appeal is partly allowed and respondent na, L& 2 ie, hospital and doctor are hereby directed to pay lunnpstan compensation of Rs, 1,00,000% to the comptainant and also to give an undertaking before this Commission that he will not publish any such advertisement in future within a period of four weeks from the date of receipt of order, However, in case the amount is not paid within the prescribed perio 1 it will carry interest @ 12% pa.” 21. No immunity to Vaccine Manufacturing Companies of India:~ teh2d. 22. 221. 3 Union of India, in its affidavit dated That, the Respondent No. 28.11.2021 submitted before the Hon'ble Supreme Court in the case of Jacob Puliyel Vs. Union of India in Writ Petition (Civil) No. 607 of 2021 had made it clear that as per Indian Law there is no immunity available to the vaccine manufacturing companies ‘The relevant para of the affidavit reads thus: “INDEMNIFICATION OF VACCINE MANUFACTURERS 65. No indemnity has been granted and she current legal regime under the New Drugs and Clinical Trials Rules, 2019 and Drugs and Cosmeties Act, 1940 does not contain any such provisions.” Law of granting compensation in Writ Jurisdiction: That, the law is very well settled by this Hon"ble Court and Hon'ble Supreme Court in catena of judgment that whenever fundamental rights of any persons are violated or if any person lost his/her life due to act of commission und omission on the part of a publie servant then the High Court can direct the Stale Government to pay interim compensation to the viction or their family members under writ jurisdiction and the siate can recover the said! amount from erting public servant later. Relied on:- i) ii) Veena Sippy Vs. Narayan Dumbre_ 2012 SCC OnLine Bom _339. iii) Chairman Railway Board Vs. Mrs. Chandrima Das (2000) 2 SCC 465. er@) iy) Nina Rajan Pillai Vs, Union of India 2011 (5) AD Well 22.2. In Sanjeevani Vs, State MANU/MH/0469/202J, it is ruled as under; “13.4... Apex Court in the case of D.K. Basu Vs, State of West Bengal reported in MANU/SC/OIS7/1997: AIR 1997 Supreme Court 610(1) wherein it has been held thus: 55. Thus, to sum xp, it is now a well accepted proposition in most of the jurisdiction, that monetary or pecuniary compensation is an appropriate and indeed an effective and sometimes perhaps the only suitable remedy for redressal of the established infringement of the fundamental right to life of a citizen by the public servants and the Sate is vicariously ligble for their exts. The claim of the citizen is based on the principle of strict liability 1o which the defence of sovereign immunity is not available and the citizen must receive the canount of compensation from the State, which shall have the rigit to be indemnified by the wrong doer. fn the assessinent of compensation, the emphasis has to be on the conrpensatory and not on pinitive element. The objective is to_apply balm to the wounds and not to punish the transgrescor_or_ the offender, ax awarding appropriate punishment for the offence (irrespective of compensation must be left to the Criminal Courts in which the offender is prosecuted, which the Stare in law, is duly bound to do. The award of compensation in the public law jurisdiction is also without prejudice to any other action like civil suit for damages which is lawfully available to the victim or the faheirs of the deceased victim with respect to the same matter : for the tortious act committed by the functionaries of the State. The quantum of compensation will, of course, : depend upon the peculiar facts of each case and no strait. jacket formula can be evolved in that behalf, The relief to Q redress the wrong for the established invasion of the fundamental rights of the citizens, under the public law g jurisdiction is, thus, in addition to the traditional remedies and not in derogation of them, The amount of compensation as awarded by the Court and paid by the State to redress the 5 wrong done, may in a given case, be adjusted against any amount which may be awarded to the claimant by way of § damages in a civil suit.” ‘That in a case of side effects of vaccines, the United States Government has set up the ‘National Vaccine Injury Compensation Program’. In a case of side effects of MMR vaccines the court granted a settlement of 101 Million U.S Dollars (7.50.34,31.400 Crores), A copy of the news article published in “metlaw" is marked and annexed herewith at “Exhibit -G”. 22.4. Needless to mention here that, in a recent e of vaccine injury the Government of Singapore granted a compensation of Rs. 1 Crore 78 Las to the victim as vaccine cause increase in heart beats. Link:« hutps://greutguncindia.conYpfizer-heart-atfuck-compensation/ ‘That, there is another case related with misrepresentation by pharma companies by suppressing the side effects of medicines.A copy of AEFI Report & RTI reply by Ministry of Health & Family Welfare marked and annexed herewith at “Exhibit H Colly” ‘The companies failure to report certain safety data was also taken into consideration. The investigating agency of US at their own investigated and recovered an amount 10.2 Billion U.S. around 7,57,71,92,40,000 Crore Rupees. The excerpts from the news published on July 2, 2012 in ‘The United State’ Department of Justice. GLAXOSMITHKLINE TO PLEAD GUILTY AND PAY _ $3 BILLION TO RESOLVE FRAUD ALLEGATIONS AND FAILURE TO REPORT SAFETY DATA Largest Health Care Praud Setlement in U.S. History “1, The United States alleges that GSK stated that Avandia had a positive cholesterol profile despite having no well- controled studies to support that message. The United pragrains States also alleges thet the company sponsored suggesting cardiovascular benefits from Avandia therapy despite warnings on the FDA-approved label regarding cardiovascular risks, GSK has agreed to pay S657 million relating to false claims arising from misrepresentations about Avandia, The federal share of this settlement is $508 million and the state share is $149 million. 2. In addition to the criminal and civil resolutions, GSK has executed a five-year Corporate Integrity Agreement (CIA) with the Department of Health and Human Services, Office of Inspector Generel (HHS-O1G). The plea agreement and CIA include novel provisions that require that GSK implement and/or maintain major changes 10 the way it does aE FORE MIE Ol eas Sambusiness, including changing the way its sules force is compensated to remove compensction based on sales goals for territories, one of the driving forces behind much of the conduct at issue in this matier. Under the CIA, GSK is required to change its ¢: cutive compensation program to permit the company to recoup annual bonuses and long-term incentives from covered executives if they, or their subordinates, engage in significant misconduct. GSK may recoup monies from executives who are current employees and those who have left the company. Among other things, the CIA_also_ requires GSK to implement and maintain transparency in_its research practices and publication policies and to follow specified policies in its contracts with various health care payors, Federal employees deserve health care providers. and suppliers, including drug manufacturers, that meet the highest standards of ethical and professional behavior,” said Patrick E, McFarland, Inspector General of the U.S, Office of Personnel Management. Assistant Director of the FBI's Criminal, Cyber, Response and Services Branch, “Together, we will continue to bring fo justice those engaged in illegal schemes that threaten the safety of prescription drugs and other critical elements of our nation’s healthcare system. This matter was investigated by agents from the HHS-OIG: the EDA's Office of Criminat Investigations: the Defense Criminal Investigative Service of the Department of Ve 3H,Defense: the Office of the Inspector General for the Office of rhe Department of Veterans Affairs: Personnel Management; the Department of Labor: TRICARE Program Integrity: the Office of Inspector General for the U.S. Postal Service and the PBL This resolution is part of the government's emphasis on combating health care fraud and another step for the Heatth Care Fraud Prevention and Enforcement Action Teant (HEAT) initiative, which was announced in May 2009 by Attorney General Eric Holder and Kathleen Sebelius, Secretary of HHS, The partnership between the nwo departments has focused efforts to reduce and prevent Medicare and Medicaid financial fraud through enhanced cooperation. Over the last three years, the department has 0.2 billion in settlements, recovered a total of more than judgments, fines, restitution, and forfeiture in health care fraud matters pursued under the False Claims Act and the Food, Drug and Cosmetic Act. The company’s unlawful promotion of certain prescription drugs, its failure to report certain safety data, and its ¢i ligbility for alleged false price revorting practices, GSK did not make available data fram two other studies in which Paxil atso failed to demonstrate effieaey in treating depression in patients under 18. The United States further alleges _that_GSK_ sponsored dinner programs, lunch programs, spa programs and similar activities to promote the use of Paxit in children and adolescents. GSK paid @ Mrspeaker to talk to an audience of doctors and paid for the ineal or spa treatment for the doctors who attended. Between 2001 and 2007, GSK failed to include certain safety data about Avandia, a diabetes drug. The missing information included data regarding certain post-marketing studies, as_well_as data regarding two studies undertaken in response to European regulators’ ince concerns about the cardiovascular safety of Avandia. 2007. the EDA has added two black box warnings to the Avandia label to alert physicians about the potential risk of (Li congestive heart failure, and (2) myocardial infarction (heart attack). GSK has agreed to plead guilty to failing to report data to the FDA cad has agreed 10 pay a criminal fine in the amount of $242,612,800 for its wwilawful conduct concerning Avandia. It also includes allegations that GSK paid kickbacks to health: care professionals fo induce them to promote and prescribe these drugs as well as the drugs Imitrex, Lotronex, Flovent and Valtrex. The United States alleges that this conduct caused false claims 10 be submitted 10 federal health care programs. GSK has agreed 10 pay $1043 billion relating to false claims avising from this alleged conduct. The federal share of this settlement is $832 million and the state share is $210 million,” eae‘The details of abovesaid report is marked and annexed herewith at Exhibit —1”. 22.6, That, the case of Petitioner is on highest footing of getting compensation because here the case is of loss of life. Constitution Bench of Hon'ble Supreme Court in the case of Anita Kushwaha Vs, Pushap Sada 2016) $ SCC_509, has ruled that the life of Indian Citizen is not Tess pricy than the life of people in England or anywhere. But in Tndia the rights are more precious. Itis ruled that: “18... Bose. J, enpphasised the importance of the right of any person to apply to the court and demand that he be dealt with according to law, He said: (Prabhakar Kesheo case [Prabhakar Keshee Tare v. Emperor, AIR 1943 Nag 26 1942 SCC OnLine MP 78}, SCC OnLine MP para 1) “1... The right is prized in India no less highly than in England, or indeed any other part of the Empire, perhaps even more highly here than elsewhere: and it is zealously guarded by the courts 22.7. That, Hon’ble Civil Court in Pune has granted a compensation of Rs, 100 Crores for defamation of half an hours news mistaken identity, Said fact was also taken in to consideration by Hon'ble Bombay High Court in the drs. 2012 SCC case of Veena Sippy Vs. Mr, Narayan Dumbre &: OnLine Bom ILis observed as under “29...We nucst state here that the Petitioner in person has relied upon an interim order passed by this Court in First Appeal arising ow of a decree passed in a suit. The decree was passed in a suit filed by a retired Judge of the Apex vetCourt wherein he claimed compensation on account of act of defamation. Considering the evidence on record, the Trial Court passed a decree for payment of damages of Rs, 100/- crores. While admitting the Appeal and while considering the prayer for grant of stay, this Court directed the Appellant-Defendant to deposit a sum of Rs, 20/- crores in the Court and to furnish Bank Guarantee for rest of the decretal amount as a condition of grant of stay. However, this Court directed investment of the amount of Rs. 20% crores till the disposal of the Appeal. The interim order of this Court has been confirmed by the Apex Court DBasw i. We hald that the detention af the Petitioner by the officers of Gamdevi Police Station from 5” April, 2008 to 6" April, 2008 is illegal and there has been a gross violation of the fundamental right of the Petitioner guaranteed by Article 21 of the Constitution of India dé, We direct the 5” Respondent-State of Maharashtra to pay compensation of Rs. 2,50,000/- to the Petitioner together with interest thereon at the rate of 8% per annmn from S" April, 2008 till the realization or payment, We direct the .000/- to State Government to pay costs quantified at Rs, 2: the Pel fioner. We grant time of six weeks to the State Government to pay the said amounts to the Petitioner by an account payee cheque. tt will be also open for the fifth Respondent - State Government to deposit the amounts in this Court within the stipulated time. In such event it will be open for the Petitioner to withdraw the said amount. ae22.8. 22.9, We clarify that it is open for the State Government to take proceedings for recavery of the amount of compensation and costs from the officers responsible for the default, if so advised. iv, Petition stands dismissed as against the Respondent No. 4, vi, We make it clear that it will be open for the Petitioner to adopt a regular remedy for recovery. of compensation/damages in addition to the anount directed to be paid under this Judgment. That, based on the abovesaid principles and comparing with the seriousness of the loss of life caused and consequential harm caused to the Petitioner, the Petitioner is at feast entitled for an interim compensation of Rs. 1000 Crores. For a total compensation of Rs. 10,000 Crores, the Petitioner is going to initiate a separate appropriate legal proceeding which will take some time. But this Hon’ble court, on the basis of settled legal and factual position, can grant interim compensation to the petitioner for the loss of life of Petitioner’s daughter. ‘That the Petitioner lost her elder danghter. Who was just 334% years old. His loss can neither be explained in words nor can be compensated terms of money. Only some sort of succor can be done by awarding compensation, The petitioner’s claim for compensation is more intended to put deterrence among other officials and thereby to save similar deaths Henee, il is just and necessary that an interim compensation of Rs. 1000 Crores be granted to the Petitioner in the weit jurisdiction, Moreover, this loss is not only to the Petitioner's family, but a loss to the whole dentistry community. Being an Oral Pathologist (MDS). she wasproviding free services at various places in Nashik such as Samkrupa Hospital & Charitable Trust, NAMCO Hospital and many such places. She conducted free treatment for Thalessemia children at various camps held at Nashik. Being the most dynamic and enthusiastic teacher of SMBT college, she was most interested in research in dentistry. Proving this, she had encouraged and guided many of her students to present research papers at State level and National Level from SMBT college and made sure that they reach the Semi Final Round at ‘Avishkaar’. Her contribution to the profession was numerous. She had been recently admitted to Ph, D at People’s University Bhopal and was about to research on the topic was oral pathology and micro biology. Her dream which she had writen in her bio-data clearly says that she wanted 10 promote research in dentistry in India and carry out research on cheaper treatment in Oral Cancer for the poor people coming from rural areas who cannot afford the heavy cost of treatment of Oral Cancer. Just because of the uninformed trial of vaccination made on her, she sacrificed her life for the country by participating in the trials of yaecination in the national movement of India. The petitioner seeks declaring the deceased a for she had sacrificed her precious life which could have made wonders i the field of dentistry in the future and would have guided many more such students saving lives of many poor people. Petitioner also seeks a dedicated research Institute to be started by the Government of India under the name of Dr, Snehal Lunawat where research in dentistry would be carried out in various areas. Similarly, petitioner seeks compensation for the damages caused to the family due to fraudulent reply by Sil even afier they were very much knowing about the fact that such adverse events are cause of the vaccine. ‘Their denial to the fact after levrning the ease study with the facts calls eeaH & 2pm wa a kr dui war wing Nok de tke cnc dunn, 201 end se ii for fraud and offence punishable under 1.P.C. for hiding the facts from us, denying help and non-co-operation at their part. eta pens ised before his How bis Carta herr, hs Hale Courts eel alee cnet te pe et, 23. 24, 25. 26, 27. The Petitioner states that he has not filed any other petitions, pertaining to the subject matter of this Petition in this Hon'ble Court or in aay other Coun. The Petitioner is approaching this Hon'ble Court expeditiously and there is no lapse and delay on his part. ‘The Petitioner has paid the prescribed court fees af Rs. J. ‘The Petitioner will rely upon the documents a list whereof is annexed hereto, PRAYERS:- ‘The Petitioner therefore prays that, this Hon'ble Court may pleased to: 1) To hold that, the petitioner's daughter was given vaccine under deception, ond false narratives by the state authorities that the vaccines are completely safe and if any serious or severe side effects occurs then the state authorities have define treatment, however when she suffered serious side effects then there was no ueatment available and lastly she died due to side effects of vaecines as has been confirmed by the Government of India’s AEFI Committee, therefore state authorities are responsible for causing her death by spreading false narratives and therefore, they are bound 10 compensate the petitioner in view of aw laid by Hon’ble Supreme Court and Hon'ble High Courts and more particularly in the case of Registrar General, High Court of Meghalaya Vs. State of Meghalaya 2021 SCC OnLine Mesh 130; eerore VE Odin BAN DON aasast VIDE PEE No 1fi) To hold that the respondent state authorities are having callous criminal attitude as til! date they have not changed their frequently asked questions and even on 15.12.2021 they are continuing their false narratives that they are having definite treatment for any side effects of vaccines: fii) ‘To hold that as per taw laid down by the Constitution Bench of Hon’ble Supreme Court in Anita Khushwha’s case (2016) 8 SCC $09, the value of life of Indian citizen is not less than that of any person across the world either of America or of any country and therefore the Petitioner is entitled (o the compensation in i proportion to the compensation granted in other similar cases in : United State, Singapore ete iv) To hold that, in view of factual and legal position mentioned in the petition, the petitioner is entitled for an interim compensation of Rs. 1600 Crores as a deterrence to guilty and as succor t petitioner's family for loss of life of petitioner's daughter due (0 deliberate act of commission and omission on the part of respondents. with a liberty to the state authorities to recover it from the responsible officials and Serum Institute, Pune who is the manuta in Veena Sippy Vs. Mr. Narayan Dumbre & Ors. 2012 SCC § OnLine Bom 339; turer of Covishield Vaccine, as per law & ratio laid down : vy) > Direct appropriate action by the Respondent No. 3 Union of India Against ail including main stream and social media like Google. YouTube. facebook etc. who are involved in the conspiracy ofsuppressing the correct data about death causing and other serious vaccine injuries and spreading false, misleading and one sided data to deprive the citizen to take informed decision and compel them to take vaccines: vi) Direct the state authorities to take proper steps to stop farther deaths of citizen and to publish the side effects of vaccines by following the rules of Universal Declaration on Bioethics & Human Rights, 200 and as per law teid down in Master Haridan UOT 2019 SCC ontine Del 11929 and also as recently done by the Government of Japan: Kumar Vs vii) Declare that, the Petitioner’s daughter Dr. Snehal Lunawat and other doctors, as a Mactyr who were.given Covid vaccines through deception and coercion and who died due to side effects of vaccines. viii) Open a dedicated research institute in India under the name of Dr. Snehal Lunawat, ix) Pass any other order which this Hon'ble Court may deems fit and proper in the fact and circumstances of the case, Dated this 25% day of January, 2022 Petitioner Advocate for the Petitioner EsORE ME SgZORE ME, “Gar ne RAN A nite RAMAN VALOYR vo aBso8Ge» 1, Mr. Dilip Lunawat, the petitioner do hereby on solenm affirmation state and VERIFICATION declare that whatever stated above is true and correct to my own knowledge and belief and what is stated in abovesaid paragraphs is based on the information “and legal advice which I believe to be true and correct. Solemaly affirmed at Bombay ) . This day of January, 2022 ) BEFORE ME Mr. Dilip Lunawat (Petitioner) &E FIDAVIT ee Near Burma Burma Restaurant, Fort, Mumbai - 400 023. ady.abhishekmishral @gmail.com Mob No.:- 9082530797.Adv. Deepika G. Jaiswal (I-30967) Office No. 2 & 3, Kothari House, 5/7 Oak Lane, A. R Allana Marg, Near Burma Burma Restaurant, Fort, Mumbai - 400 023. [email protected] Mob No.:- 8286370230.EXHIBIT® A» India's Wait Over, Drug Regulator Says Covid Vaccines Cleared "110% Safe" Source Name: NDTV Link: https://www.ndty.conv/india-news/oxford-covid-19-vaccine-bharat- biotechs-covaxin-get-final-approval-by-drug-regulator-will-be-indias-first- vaecines-2347053 fe Date: January 04, 2021 Author Name: Anindita Sanyal. Drug Controller General of India VG Somani said,."We'll never approve anything if there is slightest of safety concern. The vaccines are 110 per cent safe", New Delhi: Two vaccines for coronavirus, Oxford University's Covishield, which is being developed by the Pune-based Serum Institute, and Bharat Biotech's Covaxin, received emergency approval from the country’s drug regulator on Sunday. "We'll never approve anything if there is slightest of safety concern. The vaccines are 110 per cent safe,” Drug Controller General of India VG Somani said, adding Covishield was found to be 70.42 per cent effective and Bharat Biotech’s Covaxin was "safe and provides a robust immune response". Hailing the scientific community and frontline Corona warriors, Prime Minister Narendra Modi tweeted, "It would make every Indian proud that the two vaccines that have been given emergency use approval are made in India". There is no word yet on when the vaccination process will begin. Here are the top 10 points in this big story: 1. "We'll never approve anything if there is slightest of safety concem. The vaccines are 110 per cent safe. Some side effects like mild fever, pain and = be veallergy are common for every vaceine," Drug Controller General of India VG Somani said. The approval from the Drug Controller comes days after a government-appointed experts" pane! gave clearance to the vaccines. . Both vaccines have to be administered in two doses and stored at temperatures between 2 and 8 degrees Celsius. The government will give priority to 1 crore healthcare workers and 2 crore frontline workers when the vaccinations begin, Union Health Minister, Dr Harshvardhan said as a countrywide dry run for the vaccination process was conducted on Saturday. . "It would make every Indian proud that the two vaccines that have been given emergency use approval are made in India! This shows the eagerness of our scientific community to fulfil the dream of an Aatmanirbhar Bharat, at the root of which is care and compassion," PM Modi tweeted. Pune-based Serum Institute, the Drug Controller General said, conducted Phase 2 and Phase 3 trials on 1,600 participants in India. Recommendation was made for restricted use and the trials will continue, he added. The vaccine, developed by the Oxford University and pharma giant AstraZenca is already in use abroad. Bharat Biotech’s Covaxin is conducting trials in collaboration with the Indian Council of Medical Research. The Drug Controller said that its Phase I and Phase II trials were conducted in around 800 people and the results showed that it is "safe and provides a robust immune response". The Phase II trial in on and 22,500 of the 25,800 participants have been vaccinated. The health ministry said the government's expert committee has reviewed Bharat Biotech’s data on "safety and immunogenicity" and gave permission for “restricted use in emergency situation in public interest". The idea was tohave "more options for vaccinations, especially in case of infection by mutant strains,” the ministry said, adding that the clinical trials will continue, 7. "Happy new year, everyone! All the risks @Seruminstindia took with stockpiling the vaccine, have finally paid off. COVISHIELD, India's first COVID-19 vaccine is approved, safe, effective and ready to roll-out in the coming weeks," Serum Institute chief Adar Poonawalla tweeted. 8. "It has beon learnt that the vaccines of Bharat Biotech and the Serum Institute have received emergency approval. All preparations are underway for the Delhi government. First health workers and frontline workers will be given the vaccine, Then those above age 50 will be given the vaccine. Health workers and frontline workers will be vaccinated under First phase,” Delhi health minister Satyendar Jain said. The vaccines will be given free of cost in Delhi, the minister earlier said. 9, Flagging concems over Bharat Biotech's Covaxin, senior Congress leader Shashi Tharoor tweeted, “The Covaxin has not yet had Phase 3 trials. Approval was premature and could be dangerous. @drharshvardhan should please clarify. Its use should be avoided till full trials are over. India can start with the AstraZeneca vaccine in the meantime". 10.India has reported 18,177 new infections in the Jast 24 hours - 4.7 per cent lower than yesterday - taking the total Coronavirus cases to 1,03,23,965. Data from the health ministry showed the country has also logged 217 deaths, taking the total number of fatalities to 1,49435.EXHIBIT!_3 _® 1 i IN THE HIGH COURT OF JUDICATURE AT BOMBAY CIVIL APPLELATE JURISDICTION PUBLIC INTEREST LITIGATIONNO.85 OF 2021 DISTRICT: YohanTengra .» Petitioner Vis “The State of Maharashtra & others ... Respondents INDEX Sr EXHIBITS Particulars Page No Nos. Memo of Affidavit 443-952 1 JA Copy of data showing reduction ofgea hospitalization in COVID-19 patients (95. i { |The copy of FAQ ree Go)gut IN THE HIGH COURT OF JUDICATURE AT BOMBAY CIVIL APPLELATE JURISDICTION PUBLIC INTEREST LITIGATION NO.85 OF 2021 DISTRICT: YohanTengra .. Petitioner ws 1. The State of Maharashtra, Through Chief Secretary, State of Maharashtra, Mantralaya, Mumbai 2. Under Secretary, Disaster Management Unit, Mantralaya, Mumbai-23. . Shri, [qbalChahal, Municipal Commissioner, MCGM Annex Bldg, Fort, Mumbai-01. Shri. ShirgangGholap, Under Secretary, Disaster Management Unit, Govt. of Maharashtra. Shri, SitaramKunte, Chief Secretary, M.H State. Ministry of Railways, Bee cary aFA Rail Bhawan, Rafi Marg, New Delhi. i 7. The Union of India, Through Chief Secretary, To the Govt. of India, New Delhi-01 | 8. Central Bureau of Investigaiton, \ i Lodhi Road, New Delhi-110003. ... Respondents ' | | ABFIDAVIT IN REPLY ON BEHALF OF RESPONDENT NO. I,Dr.Sadhana M. Tayade, Age: 58, Service: presently working as Director of Health Services, Public Health Department, Mumbai, do hereby state on solemn affirmation on behalf of Respondent Nos. 1, 2, and 3 as under:- 1. Thave read the copy of the present PIL along with the annexure | thereto, also perused the official record pertaining to the subject matter of the case and on the basis of the information derived there from, | am filing this Affidavit Reply to the above PIL. I am filing this Affidavit for the purpose of opposing the PIL. I say that the contentions, which are not specifically denied by me in this Affidavit-in-reply, should not be construed as an admission on my part. I crave leave of this Hon'ble Court to file additional affidavit, if so required. I am filing this affidavit as under:~ a | say that present PIL has been filed by the Petitioner for directing the Respondent No.6to amend circular, direction/Sop dt. 10.08.2021, 11.08.2021 and 15.07.2021 issued by the Respondent to theQs? should not be treated differently than those who are vaccinated and further prayed for directing the Respondents to open Local Trains for all irrespective of their status as vaccinated or non-vaccinated and also for other prayers mentioned in the said PIL. 3. 1 say that, the directions, circular/sop are issued by the State Government for the benefit of the public at large. 1 say that the said circular/sop are issued only after consulting with the various departments of the State Government more particularly the Task Force Committee constituted by the State, J further say that, the said circular are issued afier consulting the Task Force Committee and after proper and detail study of the departments. 4, [say that the contention of the Petitioner in the present PIL is that, the vaccination is voluntary and not compulsory and the Petitioner has relied upon the various Judgments. I say that, in fact due to vaccinating the people the rates of hospitalization of COVID-19 patients is gradually reduced, Hereto annexed and marked as Exh is the copy of data showing reduction of hospitalization in COVID-19 patients. 5. I say that, thevaccination is important which could save the life. COVID-19 vaccines provide strong protection against serious illness hospitalization and death. There is also some evidence that beingothers, which means your decision to get the vaccine dlso protects those around you. 6. I say that, the need for emergency care/hospitalization due to breakthrough COVID-19 is an exceedingly rate even in fully vaccinated patients. As vaccination has increased regionally, emergency care visits amongst fully vaccinated individuals have remained low and occur much Jess frequently than unvaccinated individuals. If, hospital-based treatment is required, elderly patients with significant comorbidities are at high-risk for severe outcomes regardless of vaccination status.Hereto annexed and marked as is the copy of FAQ. 7. I further say and submit that, by not allowing the non-vaccinated people to open Local Trains or other public places is only to secure the right to live of the other vaccinated people. In view of above appropriate order may be passed.asl IFICATION L,Dr.Sadhana M. Tayade, Age: 58, Service: presently working as Director of Health Services, Public Health Department, Mumbai,do hereby state on solemn affirmation that whatever sated herein above is based upon the information derived from the official records, which I believe to be true and correct. Solemnly affirmed at Mumbai.) 2 yer adhana M. Tayade) mAs Joaas wifes Mak ges men This day of December, 2021 ) (Dy Director of Health Services, Public Health Department, Mumbai. 1 identify the Deponent, ‘Clerk to the Office of the Government Pleader, AS. (Writ Cell), High Court, Mumbai, MANTST: Draftes Mrs.R. A. Salukhe Assistant Government Picader, AS. (Writ Cell), High Court, Mumbai Settled by:- Government Pleader, AS. (Writ Cell), High Court, Mumbaiay” \- ‘No. of Admitted patient information and Covid 19 vaccination performance Tigre Target sexn | on pate nines ysiert | Poplaiontor | git % ade % accieution am 1 312021 97853 91435000 | 18009903 19.70 ‘4570306 5.00 2 072021 34018 91435000 | 26070687 28.51 6373224 6.97 3 773172021, 33163 91435000 _|__ 33384721 36.51 11202851 12.25 a w312001 16818 91435000 | 43090513 47.13 16002636 17.50 5 973072021 10134 91435000 | _57644999 63.04 24267887 26.54 6 iata021 an 91435000 | 67201631. 73.50 30976476 33.88 7 1750/2021 25 91435000 _| 74334513 81.30 | _40045655 43.80 ® 1272021 246 91435000 | _77916475 85.22 46621812 50.99 et onyFrom when the COVID-19 vaccination for 18-44 year age group is starting? Registrations have started on 28 April and vaccination has started on 01 May. Please check www.cowin.gov.in for available slots bale vaccination centres. | | Where can I gat the Vaccine from? You can get the vaccine from Govt Hospital in districts which are] selected by State Govt. | You can also get vaccine in selected private hospital vaccination | centers. Check cowin.gov.in for details after registration. for Vaccination? Registration i is only via COWIN Website (www.cowin.gov.in)/Aarogya Setu App only. No other app/website/walk-in/spot registration would be allowed. Register using mobile number and Aadhaar number. Follow the simple steps as guided by the website, register, and choose your Vaccination Centre via Pin code/District. You would get an SMS Confirmation. Keep it safe. | Can a person get the COVID-19 vaccine without registration with Health Department?! No, the registration of beneficiary is mandatory for vaccination for COVID-19 vaccine. | | After registration; the beneficiaries have to book a siet for vaccination or walk into the vaccination center For 18 to 44 age group vaccination no walk in is permitted as of now. Vaccination. In this age group will only possible through scheduled appointment. Appointment:can be sought orcowin. gov.in after registration. Notifi¢étion and information about the vaccine session. date and time will be:shared with the beneficiary after scheduling the appointment. %What documents are required for registration of eligible beneficiary? Any of the below mentioned ID with Photo may be produced at the time of registration: ‘aadhaar Card Driving License Health Insurance Smart Card _—_ Mahatma Gandhi National issuedunder the scheme of. Rural Employment Guarantee Ministry of Labour ActIMGNREGA} Job Card Official identity cards PAN Card Passhooks issued by Passport issued to MPS/MLASIMLCS Bank/Post Office Pension Document Service Identity Card (ssued to employees by Voter ID Central State Govt J Public Limited Companies Can I reschedule.my Vaccination Appointment? Yes. You can reschedule till the previous day. What are the vaccines that would be made available? At present, COVISHIELD (Oxford-AstraZeneca Vaccine) and COVAXIN (Bharat Biotech) would be available. In due course, many other vaccines are expected to be made available. While booking the appointment, you will be able to see both the name of the centre and the vaccine being given in private facility. Vaccine of choice among the available options at the displayed cost may be received from private facilities. At Government facilities/ sites there is no choice of vaccine.10 i 12 13 How mu hoi Epa vaccine dose? In the private sector, the price would be decided by the Private Vaccine Providers. In the government hospitals, the vaccine will be available free of cost in Uttar Pradesh. | ama young person. Is COVID-19 vaccines (COVISHIELD and COVAXINE) are safe? Yes, Both the available vaccines are entirely safe and effective. Millions of persons have received COVISHIELD and COVAXINE in India, with extremely rare side effects. And, even in the unlikeliest scenario of a serious adverse event, i there are established management protocols, There is nothing to fear, Can a pregnant or lactating woman receive COVID-19 vaccine? Studies are ongoing to prove the safety of COVID-19 vaccines i in pregnant and lactating women. Currently, Government of India guidance does not include vaccination for pregnant and lactating women. raceive the vaccine? Yes, you can. Kindiy do not believe the rumours regarding the same. Eamon my ¢ Which of the vaccines is better for me - COVISHIELD or COVAXIN? Both are equally efficacious in-preventing mild, moderate, and severe COVID, Choose whatever is available to you, at the Vaccination Centre.16 a7 Iam young. I believe I have good immunity. Do f need to still take the Vaccine? Yes. No one is safe from COVID-19, not even the fittest and healthiest of individuals. Better safe, than sorry. Iam hearing reports of people testing COVID-19 Positive even after receiving the first dose of Vaccine. Is it even useful? First, the rate of infection after vaccination is much lower than the unvaccinated. And, even if such an infection occurs, by virtue of the vaccination, the body has a good titre of antibodies to limit the infection to a mild stage, thereby significantly reducing the chance of progressing to severe COVID, hospitalization and deaths. Therefore, vaccines are life-saving and effective! What are the common side effects that I can expect after Vaccination? Fever, headaches, body aches, fatigue, injection site pain are the common side effects, and they are manageable by a short course of Paracetamol. Most resolve by 2-3 days. You are observed for 30 minutes after receiving the dose, for any serious or severe effects, and even though they are rare to occur, there is definite treatment for each such serious effect. I recently tested COVID-19 Positive. Should I still take the vaccine? Yes. You should receive the vaccine 4-8 weeks after testing COVID-19 positive. L received the First Dose of the Vaccine and then tested COVID-19 Positive in between the two doses? Cant take the second dose? Yes. You should receive the vaccine 4-8 weeks after testing COVID-19 positive.20 21 Yes. On getting due dose of COVID-19 vaccine, the beneficiary will receive SMS on their registered mobile number. After all doses of vaccine are administered, a QR code-based certificate will also be sent to the registered mobile number of the beneficiary. The second dose of Covishield vaccine can be taken 4-8 weeks after the first dose and the second dose of Covaxin can be taken 4-6 weeks after the first Atos dose. “sey Vaccination for COVID-19 is voluntary. However, it is advisable to receive the complete schedule of COVID-19 vaccine for protecting oneself against this disease and to limit the spread of this disease to the close contacts eae family members, friends, relatives, and co-workers.$233 If one is taking medicines for illnesses like Cancer, Diabetes, Hypertension etc, can s/he take the COVID-19 vaccine and/or If I suffer from HTN/DM/ CKD/heart disease/lipid disorders etc., can I safely take this vaccine? Yes, persons with one or more of these comorbid conditions are considered among the high-risk categories. They need to get COVID-19 vaccination on priority. Overall, the vaccine is safe and efficacious in adults with comorbidity. The maximum benefit of getting the COVID-19 vaccine is for those who have such co-morbidities. However, if you are concerned for any specific reason, please consult your doctor Do I need to use the mask/other COVID-19 appropriate precautions after receiving the vaccine? Yes, it is absolutely necessary that everyone who has received the COVID-19 vaccine should continue to follow the COVID-19 appropriate behaviour i.e., mask, do gaj ki doori and hand sanitization to protect themselves and those around from spreading the infection. aa = Use mask Wash hands with soap and Maintain 6 feet correctly water frequently and thoroughly (2 gai) physical i or use hand sanitizer distance ei after vaccination? How long will T remain pr Longevity of the immune response in vaccinated individuals is yet to be determined. Hence, continuing the use of masks, handwashing, physical distancing, and other COVID-19 appropriate behaviours is strongly recommended:96] 25 26 27 28 Does vaccination protect me against newer strains / mutated virus of SARS-CoV 2? The body responds to vaccination by making more than one type of antibodies to virus parts including spike protein. Therefore, all vaccines are expected to provide reasonable amount of protection against the mutated virus also. Based on the available data the mutations as reported are unlikely to make the vaccine ineffective. will the vaccination create an orse and protection? Adequate immune response takes 2-3 weeks after completion of entire vaccination schedule i.e., after the second dose of COVISHIELD® and COVAXIN®. in how many days adequate fmmune re What prec. after ¢ g Both the vaccines are safe, but in case of any discomfort or complaint, ask the beneficiary to visit the newrest health facility and/or call the health worker whose phone number is given in the Co-WIN SMS. received after vaccination. me vaccine As the vaccines avaliable are not inter- changeable, itis important to receive the second dose of the same vaccine as the first one. The Co-WIN portal is also going to help to ensure that everyone receives the same vactine TEXHIBIT!_C_* @- = Ministry of Health & Family Welfare ‘Government of India Certificate for COVID-19 Vaccination Issued in India by Ministry of Health & Family Welfare, Govt of India CCertfesteiD 285136017 Beneficiary Details Beneficiary Name / mre ara Dr.Snohal Dilip Lunawat k Age / 3 33 Gender fT Female 1D Verified / sara PAN Card # AHOPL8I60H Unique Health 1D (UHID) Beneficiary Reference ID 21380753155348, Vaccination Status /artara Ft Partially Vaccinated (1 Dose) Vaccination Details Vaccine Name / after are COVISHIELD Vaccine Type / FEE COVID-19 vaccine, non-replicating viral vector Manufacturer / 3m Serum institute of India Dose Number / Shr wrres v2 Date of Dose / aah ahs 28 Jan 2021 Bitch Number / erates arzoz012 Next Due Date / gel a after, Between 22 Apr 2021 and 20 May 2021 Vaccinated By / arama aes Sunit Shinde Vaccination At/ sateen Flas SMBT Medical collage, Nashik, Maherashtre + aire gar snftt feist ger Ca Together, India will defeat. COVID-19” eee Incase of any adverse evans, kindly contact the necrest Public Heath Center! Hentreare WorkerDitret Inmurezton OMcerSIate Helpline No, 1075 sherds areata per eae ae ey eat moar Garner say oe Somer ene to we HE AM, ow. es +E x “Ths comicot canbe vee by scanning Be OR Eoce at : Steleeineannamn