Draft of Quashing of FIR

BEFORE THE HON’BLE HIGH COURT OF DELHI, AT NEW DELHI
WRIT PETITION (CRIMINAL) NO. ______OF 2023
IN THE MATTER OF:

SUBHRA KABASI & ORS. …PETITIONER
VERSUS
THE STATE & ANR …RESPONDENTS
INDEX
SL. NO. PARTICULARS PAGE NO.
1. NOTICE OF MOTION
2. URGENT APPLICATION
3. MEMO OF PARTIES
4. SYNOPSIS AND LIST OF DATES AND
EVENTS
5. PETITION UNDER ARTICLE 226 OF THE
CONSTITUTION OF INDIA READ WITH
SECTION 482 CR.P.C.
6. AFFIDAVITS OF PETITIONERS
7. ANNEXURE P-1 (COLLY): COPY OF FIR
NO 409 OF 2023 AND COPY OF FIR NO.
191 OF 2019 BOTH PS CIVIL LINES
8. ANNEXURE P-2 (COLLY): TRUE
COPIES OF IMPUGNED ORDER DATED
04.09.2023, 07.11.2023 AND 22.11.2023
BY MM-06 (CENTRAL) DIRECTING
REGISTRATION OF FIR U/S 156(3) CRPC
9. ANNEXURE P-3(COLLY): TRUE COPIES
OF ORDER DATED 17.12.2021,
11.02.2022, 20.01.2023
10. ANNEXURE P-4: TRUE COPY OF
ORDER DATED 05.10.2023 AND
03.11.2023 BY ASJ-03(CENTRAL) IN
CRL. REVISION NO. 501/2023
11. ANNEXURE P-5: TRUE COPY LETTER
DATED 16.05.2023 VIDE NO. L&DO/L-
III/8/3/(40)/40 FROM LAND &
DEVELOPMENT OFFICE, NIRMAN
BHAWAN, NEW DELHI
12. APPLICATION U/S 482 CRPC FOR
INTERIM/AD INTERIM STAY OF
PROCEEDINGS OF CT. CASES/3112/2021
PENDING BEFORE MM-06(CENTRAL),
TIS HAZARI COURTS ALONG WITH
AFFIDAVITS
13. APPLICATION U/S 482 CR.P.C. FOR
EXEMPTION FROM FILING CERTIFIED
/TRANSLATION/DIM
HANDWRITING/ILLEGIBLE COPIES OF
ORDERS AND ANNEXURES ALONG
WITH AFFIDAVITS
14. ID PROOF OF PETITIONERS
DELHI
DATED: PETITIONERS-IN-PERSON
BEFORETHE HON’BLE HIGH COURT OF DELHI, AT NEW DELHI
WRIT PETITION (CRIMINAL) NO. _____ OF 2023
IN THE MATTER OF:

SUBHRA KABASI & ORS. …PETITIONER
VERSUS
NOTICE OF MOTION
SIR,
The enclosed petition/application in the aforesaid matter have been filed on behalf
of the petitioner and is likely to be listed on_______. Please take notice
accordingly.
DELHI
IN THE MATTER OF:

SUBHRA KABASI & ORS. …PETITIONERS
VERSUS
URGENT APPLICATION
THE REGISTRAR
DELHI HIGH COURT
NEW DELHI
SIR,
Would your honour may kindly be pleased to treat the accompanying
petition as urgent one, as the ground of urgency are: -
“That the respondent no. 2 has got registered second FIR No. 409/2023 at
PS Civil Lines based on the same facts and same cause of action by impugned
order u/s 156(3) Cr.P.C during the trial of the first FIR No. 191 of 2019, PS Civil
Lines under the same offence u/s 448/34 IPC. The next date of hearing before
MM-06(Central) is on 11.12.2023 for compliance of further orders.”
DELHI
BEFORETHE HON’BLE HIGH COURT OF DELHI, AT NEW DELHI
MEMO OF PARTIES
1. SUBHRA KABASI, AGED 58
W/O SH. MANORANJAN KABASI
R/O HOUSE NO. 27,
KHYBER PASS, CIVIL LINES,
DELHI – 110054
MOB: 8700608356
2. SHUBHANKAR KABASI, AGED 27

S/O SH. MANORANJAN KABASI
R/O HOUSE NO. 27,
DELHI – 110054
3. SANJUCTA KABASI, AGED 32

D/O SH. MANORANJAN KABASI
R/O HOUSE NO. 27,
DELHI – 110054 …PETITIONERS-IN-PERSON
VERSUS
1. THE STATE
THROUGH THE CHIEF SECRETARY
NCT OF DELHI
2. SAROJ
W/O LATE CHANDERPAL
MANGOLPURI
DELHI 110083 …RESPONDENTS
DELHI
IN THE MATTER OF:

VERSUS
SYNOPSIS
The petitioners prefer the present petition under Article 226 of constitution of
India read with section 482 Cr.P.C. to Quash FIR bearing no. 409/2023 dt.
15.09.2023 under section 448/34 IPC, PS Civil Lines, Delhi registered on the
direction of impugned order dated 04.09.2023 by MM-06(Central) u/s 156(3)
Cr.P.C. in ct cases 3112/2021 titled “Saroj v. Subhra Kabasi & Ors.” on the same
facts and cause of action during trial of the first FIR bearing No. 191 of 2023
dated 19.11.2023, PS Civil Lines filed by the same complainant woman namely
Saroj. The petitioners have also filed Revision petition before the court of ASJ-
03(Central) against the impugned order which is pending for arguments on
18.12.2023. The Respondent no. 2 and her aides are continuously harassing and
implicating the petitioner and her family members in multiple civil suits and
criminal cases, misusing/abusing the process of court, so as to drag out the
petitioner and her family members from the property in litigation. Hence the
present petition is being preferred before this Hon’ble court for quashing of the
FIR and subsequent proceeding emanating therefrom.
LIST OF DATES AND EVENTS

DATES EVENTS
13/11/2019 Petitioner was repairing her house, few persons/women
from neighbourhood who are aides of respondent no. 2,
tried to stop the work. Upon protest petitioner and her
mother were beaten blue and black.
19/11/2019 Respondent no. 2 got registered one FIR No. 191 of
2019 at PS Civil Lines u/s 448/34 IPC.
20/11/2019 The police on the basis of DD no. 30A dated
14/11/2009 and DD no. 46A have already registered
two case FIRs against the petitioners i.e. the FIR no.
191/2019 and FIR no. 189/2019 PS Civil Lines u/s
323/451/506/34 IPC respectively apart from two
Kalandras which have been disposed of by the
concerned SEM court.
06/02/2020 The Petitioner filed quashing on merits of FIR No.
191/2019 and FIR No. 189 of 2019 PS Civil Lines in
W.P. (CRL.) 367 of 2020 and W.P. (CRL.) 429 of 2020
before the Hon’ble High Court of Delhi and pending
for quashing on merits for 24.01.2024.
02/12/2021 Fresh Complaint case No. 3112/2021 was filed before
the Predecessor Ld. Trial Court MM-06(Central) by the
same complainant Saroj on the same facts and cause of
action by tweaking of certain facts of already registered
FIR No. 191/2019
11/02/2022 The SHO PS Civil Lines submitted ATR dated
11.02.2022 stating that the matter pertains to PS Civil
Lines and complaint has been sent at PS Kashmiri gate.
22/11/2022 Challan against all three petitioners are filed in the
court of Ld. MM PS Civil Lines in the first FIR no. 191
of 2019 u/s 448/468/471/120B/34 IPC and pending for
quashing on merits for 24.01.2024.
04.09.2023 Ld. Successor M.M. Ms. Arjinder Kaur MM -06
allowed the application u/s 156(3) Cr. P. C. of the
respondent no.2 and directed the SHO PS civil lines to
register fir against the petitioners herein.
15.09.2023 For Compliance of order u/s 156(3) CRPC, a second
FIR was registered of FIR No. 409/2023 on 15.09.2023
by SHO PS Civil Lines on same offence u/s 448/34
IPC.
18.09.2023 Revision petition of Crl. Revision No. 501/2023 was
filed by the petitioner Ms. Sanjucta Kabasi in the court
of ASJ-03 (Central) against the impugned order dated
04.09.2023 by Ld. MM Court
05.10.2023 The Revision petition was allowed and notice was
issued to the complainant Saroj. Trial Court Record is
also requisitioned by the Hon’ble Sessions Court.
07.11.2023 The trial court again ordered for addition of relevant
sections after the registration of FIR No. 409/2023 vide
impugned single order dated 04.09.2023
22.11.2023 The trial Court ordered for compliance of order dated
07.11.2023 for next date on 11.12.2023. Hence the
present petition for quashing of FIR No. 409/2023.
DELHI
IN THE HON’BLE HIGH COURT OF DELHI, AT NEW DELHI
WRIT PETITION (CRIMINAL) NO. ______ OF 2023
IN THE MATTER OF:

VERSUS
WRIT PETITION UNDER ARTICLE 226 OF CONSTITUTION OF INDIA

READ WITH SECTION 482 CR.P.C. FOR QUASHING OF SECOND FIR NO.
409/2023 REGISTERED VIDE IMPUGNED ORDER DATED 04.09.2023 U/S
156(3) CRPC DURING THE TRIAL OF FIRST FIR NO 191 OF 2023 ON
SAME OFFENCE U/S 448/34 IPC PS CIVIL LINES AND THE
PROCEEDINGS EMANATING THERETO AGAINST THE PETITIONERS
THE HON’BLE CHIEF JUSTICE

AND HIS HON’BLE COMPANION
JUDGES OF THE HON’BLE COURT
THE HUMBLE PETITION OF THE PETITIONER
ABOVE NAMED
MOST RESPECTFULLY SHOWETH:

1. That the petitioner prefers the present petition for quashing of FIR bearing
no. 409/2023 dt 15/09/2023 under section 448/34 IPC PS Civil Lines,
Delhi and the proceedings emanating thereto registered by the impugned
order dated 04.09.2023 u/s 156(3) CRPC by the order of MM-06(Central)
Ms. Arjinder Kaur in ct. cases 3112/2021 titled “Saroj v. Subhra Kabasi &
Ors.” during the pendency and trial of FIR No. 191/2019 u/s 448/34 IPC
before the same court on same facts and same cause of action. The true
copies of the FIRs are annexed as ANNEXURE P-1 (COLLY) and the
true copy of impugned order dated 04.09.2023 is annexed as ANNEXURE
P-2(COLLY).
2. That the petitioners have a respectable background and the respondent no.2
is land grabber. She is an encroacher over government land and want to
pressurize the petitioners to settle the pending civil suits. Respondent no. 2
has already been declared an encroacher by Land and Development Office,
Ministry of Urban and Development. The true copy of the reply of Land
and Development Office, Nirman Bhawan dated 16.05.2023 is annexed as
ANNEXURE P-5. Because of this reason, the Respondent no. 2 and her
family members and their aides are using all tactics, hooks and crooks to
drag out the petitioner and her family members from the tenanted premises.
The registration of false and frivolous cases is among those cheap tactics.
Hence the present petition is being preferred before this Hon’ble court for
quashing of FIR and the subsequent proceedings emanating therefrom.
3. That the allegations in both these proceedings are identical. That the
respondent no.2. did not disclose the fact that the aforesaid FIR No.
191/2019 has been registered by the respondent no.2 and chargesheet has
been filed against all the three petitioners. It is pertinent to mention herein
that sections 468 and 471 IPC has been added by the IO in the FIR No.
191/2019. That the petitioner has filed a quashing petition u/s 482 Cr. P.
C. bearing Writ Petition (Crl.) No. 367/2020 before Hon’ble High court
of Delhi and the same is fixed for argument on 24.01.2024. That, the
petitioner cannot be prosecuted for the same offence twice, when a matter
is already pending before the court concerned, there was no reason for the
Ld. M.M. to direct registration of FIR against the petitioner.
4. That the Ld. MM Court erroneously ignored the Action taken report dated
11.02.2022 of SHO PS Civil Lines to the complaint case u/s 156(3) Cr.P.C
and also continuously ignoring the quashing proceedings of the Hon’ble
High Court and revision proceedings by Hon’ble ASJ -03 over the matter
and whimsically passing the orders for registration of FIRs without
deciding the maintainability of the complaint and locus standi of the
complainant thereby abusing/misusing the discretionary powers u/s 156(3)
Cr.P.C. That the Ld. MM passed the impugned order on application under
section 156 (3) of Cr. P.C. in a routine manner, without compliance of u/s
154(3) Cr.P.C. and without considering the records and contention of the
IO that the court has no jurisdiction to entertain the complaint and the
matter has been transferred to another jurisdiction i.e., PS Kashmere Gate.
5. That there was nothing on record to form opinion by the LD. Magistrate
on perusal of complaint and annexures attached which reveal that the
allegations contained therein disclose commission of such cognizable
offence which required to be investigated by the police. Such observation
of the Ld. MM is vague, general in nature and does not disclose which type
of cognizable offence seems to be committed by the accused persons.
6. That prior to setting out the grounds for the present petition, the petitioner
craves leave of your honour to prefer the brief facts of the matter which are
as under: -
BRIEF FACTS AS PER FIR
i) That respondent no. 2 states in the impugned FIR No. 409 OF 2023 that
the complainant is the absolute owner of the property bearing no. 27,
Khyber Pass, Silk Mill Quarters, Khyber Pass, Civil Line, Delhi –
110054 constructed upto ground floor and first floor, by virtue of
registered G.P.A., Will, Possession Letter, Receipt, etc. executed in the
year 2012 in favour of the complainant Saroj and her son Ranjeet. In
the year 2015 the property was let out to Smt. Subhra Kabasi, the
petitioner for a monthly rent of Rs. 5,000/- per month. The petitioner
had not paid the rent after March 2016 and is now the
encroacher/trespasser on the property of the complainant. Thereafter,
the petitioners allegedly broke the locks of ground floor of the property
and in this regard an FIR No. 191 of 2019 u/s 448/34 IPC has been
registered by the complainant namely saroj. Thereafter, the first floor
of the property was decreed by the Civil Judge 06 (Central) Tis Hazari
Courts under Order XII Rule 6 CPC. It is further alleged in the
complaint that the petitioners in connivance with each other prepared
some forged and fabricated documents in respect of the property of the
complainant and therefore the complainant filed the complaint in the
Hon’ble Court for registration of FIR under relevant sections of IPC
against the petitioners.
ii) Prior to this FIR, another case was filed from the side of respondent no.
2 in FIR No. 191 of 2019 dated 19.11.2019 at PS Civil Lines. That
respondent no. 2 states in the impugned FIR that in the year 2012 her
family purchased a 25 square yard house no. 23 Khyber Pass. In the
year 2015 the first-floor portion was let out to the petitioner Subhra
Kabasi for a monthly rent of Rs. 5,000/- per month and she retained the
ground floor portion with herself. The petitioner was asked to vacate
the same in 2016 but she sought some time. The petitioner instead of
vacating the same filed a court case. On 11/11/2019 respondent no. 2
along with her husband visited the said house, seeing them petitioner,
her mother and brother started verbally abusing them. The petitioners
locked the door of the house. They have also affixed the name plate of
their name. When respondent no. 2 peeped inside from iron grilled gate,
she found her TV, Deewan, Bed, One small Almirah, Kitchen goods
missing and enquired from neighbours, who told her that the goods have
been removed by the petitioners and after removing the same, they put
their own lock. It was further stated in the FIR that the police shall take
all actions to handover the possession of the property from the
trespassers petitioners to her.
iii) In relation to this alleged incident, a subsequent FIR was registered
apart from two different Kalandra which were disposed of.
iv) That the present petition is being preferred before this Hon’ble Court
inter-alia amongst the following grounds: -
GROUNDS
a) Because the impugned order passed by Ld. MM is bad in law and likely to
cause grave injustice against the petitioners. The complainant who is an
encroacher has got the present FIR registered by tweaking certain facts in
her complaint u/s 156(3) Cr.P.C. The Ld. MM has grossly erred in
appreciating the facts and materials before her that a subsequent FIR cannot
be registered on same facts and without deciding the legal questions as to
the maintainability of the complaint and locus standi of the complainant
has given directions for registration of FIR which is against the settled
principles of Hon’ble Supreme Court.
b) Because the subsequent FIR bearing No. 409/2023 dt 15/109/2023 under
section 448/34 IPC P.S. Civil Lines, Delhi, was registered against the
petitioners during the trial of first FIR No. 191 of 2019 by the same trial
court with prior knowledge of same facts and cause of action in both the
cases and therefore has abused the discretionary power under Section
156(3) Cr. P.C. to harass the petitioners in the hands of the complainant.
c) Because the respondent no.2 has already initiated proceedings against the
petitioner for similar set of allegations in FIR no. 191/2019 which is
pending for 24.01.2023 before the same trial court and is also pending for
quashing before the Hon’ble High Court of Delhi in W.P. (Crl.) 367 of
2020 and ignoring the averred facts, the Ld. Trial court has passed orders
for compliance of fresh registration of FIRs based on the same facts and
cause of action.
d) Because the Complainant is an encroacher/trespasser on the government
land and has no valid title deeds in her name. The Ld. MM has erred in
appreciating both the fact and law that only rightful owner can institute
criminal proceedings in relation to the property and not a
trespasser/encroacher.
e) Because the Ld. MM erred by ignoring the facts and report filed by the IO
in form of ATR that the matter does not pertain to its jurisdiction and has
been transferred to another jurisdiction. The Ld. MM instead of relying
upon the material available before her and considering the Status report
allowed the application for registration of FIR in routine manner.
f) Because the Ld. MM court cannot pass more than one direction for
registration of FIR of the same complainant in the same complaint case
neglecting the pending criminal cases based on the same facts and also
cannot direct the Investigation Officer to add relevant sections in the same
FIR by misusing its powers granted under section 156(3) Cr.P.C
g) Because the Ld. Trial Court has grossly erred in ignoring the revision
proceedings of Hon’ble ASJ-03(Central) and cannot randomly pass orders
under section 156(3) Cr.P.C. to the Investigation Officer for further
addition of sections in subsequent FIRs.
h) Because due to impugned order passed by the Ld. MM, the petitioner got
deprived from getting remedy for wrong done with her by the respondent
no.2.
i) Because the respondent no.2 has filed the present complaint case/FIR
against the petitioner in order to pressurize the petitioner in order to take
advantage of civil cases pending between the parties can go to any extent
including framing in criminal cases.
j) Because the Case of the petitioner and his right to get justice get
jeopardized due to impugned order passed by the LD. MM.
k) Because the contents of the present FIR are absolutely false and frivolous,
which is ample clear from the bare reading of the FIR.
l) Because police machinery and judiciary cannot be misused for settling
personal scores of respondent no. 2.
m) Because the impugned complaint/FIR does not have any ingredient as of
section 448 or of any relevant section under IPC.
n) Because no fruitful purpose is going to be served by continuing with the
criminal proceedings of the above noted case FIR.
o) Because the petitioner is having other various grounds in the matter and
she craves leave of this Hon’ble court to raise them at the time of arguments
before your Lordships.
p) Because in the light of the facts and circumstances of the matter as
enumerated hereinabove the impugned FIR needs to be quashed.
7. That no challan has been filed in the present case with addition of sections
and as such the present criminal writ petition is being preferred before this
Hon’ble Court.
8. That the petitioner has not filed any other petition for grant of same or
similar relief either before this Hon’ble court or before the Hon’ble
Supreme Court of India.
PRAYER
It is, therefore, most respectfully prayed that your Lordships may graciously be
pleased: -
i) To Quash the subsequent FIR bearing no. 409/2023 dt. 15.09.2023
under section 448/34 IPC, PS Civil Lines, Delhi registered through
complaint case no. 3112/2021 vide impugned order dated 04.09.2023
passed by Ld. MM-06(Central), Ms. Arjinder Kaur against the
petitioners Subhra Kabasi, Shubhankar Kabasi and Sanjucta Kabasi for
being registered on same facts and cause of action as in FIR No.
191/2019 dated 19.11.2023 u/s 448/34 IPC PS Civil Lines pending
before the same court for trial and Chargesheet to be filed in the said
FIR, along with any consequent proceedings emanating thereto from
the subsequent FIR.
ii) To quash the proceedings of complaint case no. 3112/2021 pending
before Ms. Arjinder Kaur, MM-06(Central) and quash further orders
and compliance for addition of further sections in FIR No. 409/2023
dated 15.09.2023 and registration of further FIRs in the same matter
against the three petitioners abovementioned.
iii) Any other or further direction/order which your Lordships may deem
fit and proper may also be passed in the facts and circumstances of the
matter, in the interest of justice.
DELHI
WRIT PETITION (CRIMINAL) NO. _______ OF 2023
IN THE MATTER OF:

VERSUS
AFFIDAVIT
I, Subhra Kabasi W/o Sh. Manoranjan Kabasi, aged 58 years, R/o HN27, Khyber
Pass, Civil Lines, Delhi -110054, do hereby solemnly affirm and declare as under:
1. I am the Petitioner-in-person no. 1 in the abovementioned matter and as
such well conversant with facts and circumstances of the case, hence
competent to sign and verify the present affidavit.
2. I have carefully read and understood contents of the accompanying
quashing petition and the same has been drafted by us. I have read and
understood the contents thereof and the same are true and correct to the
best of my knowledge and information.
DEPONENT
VERIFICATION:
Verified at Delhi on this_____ day of November, 2023 that contents of the above
affidavit are true and correct to my knowledge and belief and no part of it is false
and nothing has been concealed therefrom.
DEPONENT
IN THE MATTER OF:

VERSUS
AFFIDAVIT
I, Shubhankar Kabasi S/o Sh. Manoranjan Kabasi, aged 27 years, R/o HN27,
Khyber Pass, Civil Lines, Delhi -110054, do hereby solemnly affirm and declare
as under:
DEPONENT
VERIFICATION:
DEPONENT
IN THE MATTER OF:

VERSUS
AFFIDAVIT
I, Sanjucta Kabasi D/o Sh. Manoranjan Kabasi, aged 32 years, R/o HN27, Khyber
DEPONENT
VERIFICATION:
DEPONENT
CRL. M.C. (NO.) ________ OF 2023
IN
WRIT PETITION (CRIMINAL) NO. ____ OF 2023
IN THE MATTER OF:

VERSUS
APPLICATION U/S 482 CRPC FOR INTERIM/AD-INTERIM STAY OF
PROCEEDINGS OF CT. CASES/3112/2021 PENDING BEFORE MS.
ARJINDER KAUR, MM-06(CENTRAL), TIS HAZARI COURTS FOR
11.12.2023
1. That the petitioners prefer the present application in the accompanying
quashing petition seeking for stay of proceedings in complaint case
3112/2021 pending before Ms. Arjinder Kaur, MM-06 (Central), Tis
Hazari Courts for 11.12.2023. The averments in the quashing petition are
true and correct and are not being repeated for the sake of brevity and may
be read as part and parcel of this application
2. That the Ld. MM Court has ordered for second registration of FIR based
on same facts and events in complaint case No. 3112/2023 vide its
impugned order dated 04.09.2023 under section 156(3) Cr.P.C. during the
pendency of trial of first FIR No. 191/2019 for 24.01.2024. The second
FIR No. 409/2023 was registered on same offence u/s 448/34 Cr.P.C. by
the same complainant namely saroj at PS Civil lines on 15.09.2023.
3. That subsequent to the registration of second FIR, the LD. MM vide its
impugned order dated 07.11.2023 has directed/ordered for compliance of
adding new sections/relevant sections to the investigation officer in the
same case and further put for compliance on 11.12.2023 ignoring the
submissions and contentions made by the petitioner. The petitioners are
under apprehension of arrest and other kinds of harassment in the hands of
police.
q) That if the application for stay of proceedings is not allowed the petitioners
will suffer irreparable loss and injury/harm to their reputation, body, mind
and property. Because police machinery and judiciary cannot be misused
for settling personal scores of respondent no. 2. The impugned proceedings
before Ld. MM warrant immediate stay or else it will cause serious
miscarriage of justice.
PRAYER
It is, therefore, most respectfully prayed that your Lordships may graciously be
pleased: -
i) Grant interim stay of the criminal proceedings in complaint case no.
3112/2021 titled “Saroj v. Subhra Kabasi & Ors.” pending before Ms.
Arjinder Kaur, MM-06(Central) for 11.12.2023 and stay further orders
and compliance for addition of further sections in FIR No. 409/2023
dated 15.09.2023 and registration of further FIRs in the same matter
against the three petitioners abovementioned.
ii) Any other or further direction/order which your Lordships may deem
fit and proper may also be passed in the facts and circumstances of the
matter, in the interest of justice.
DELHI
IN THE MATTER OF:

VERSUS
AFFIDAVIT
application and the same has been drafted by us. I have read and understood
the contents thereof and the same are true and correct to the best of my
knowledge and information.
DEPONENT
VERIFICATION:
DEPONENT
IN THE MATTER OF:

VERSUS
AFFIDAVIT
as under:
DEPONENT
VERIFICATION:
DEPONENT
IN THE MATTER OF:

VERSUS
AFFIDAVIT
DEPONENT
VERIFICATION:
DEPONENT
CRL. M.C. (NO.) ________ OF 2023
IN
WRIT PETITION (CRIMINAL) NO. ____ OF 2023
IN THE MATTER OF:

VERSUS
APPLICATION U/S 482 CR.P.C. FOR EXEMPTION FROM FILING

CERTIFIED /TRANSLATION/DIM HANDWRITING/ILLEGIBLE COPIES
OF ORDERS AND ANNEXURES
1. That the complete facts of the case have been averred and set out in the
accompanying quashing petition and is not repeated herein for the sake of
brevity and the same be read as part and parcel of the accompanying
application.
2. That the Ld. MM Court has ordered for second registration of FIR based
on same facts and events in complaint case No. 3112/2023 vide its
impugned order dated 04.09.2023 under section 156(3) Cr.P.C. during the
pendency of trial of first FIR No. 191/2019. The second FIR No. 409/2023
was registered on same offence u/s 448/34 Cr.P.C. by the same
complainant namely saroj at PS Civil lines on 15.09.2023. The petitioners
are challenging the subsequent registration of the FIR and the proceedings
u/s 156(3) Cr.P.C. in the present quashing petition.
3. That the petitioners are unable to furnish the certified /translation/dim
handwriting/illegible copies of orders and annexures at the stage as are not
readily available and due to urgency of the matter, only true copy of
impugned orders are being filed and will submit the same as and when
required by the Hon’ble High Court.
PRAYER
It is, therefore, most humbly and respectfully prayed that filing of certified
/translation/dim handwriting/illegible copies of orders and annexures may kindly
be exempted in the interest of justice.
DELHI
IN THE MATTER OF:

VERSUS
AFFIDAVIT
DEPONENT
VERIFICATION:
DEPONENT
IN THE MATTER OF:

VERSUS
AFFIDAVIT
as under:
DEPONENT
VERIFICATION:
DEPONENT
IN THE MATTER OF:

VERSUS
AFFIDAVIT
DEPONENT
VERIFICATION:
DEPONENT

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BEFORE THE HON’BLE HIGH COURT OF DELHI, AT NEW DELHI

WRIT PETITION (CRIMINAL) NO. ______OF 2023

IN THE MATTER OF:

IN THE MATTER OF:

IN THE MATTER OF:

2. SHUBHANKAR KABASI, AGED 27

3. SANJUCTA KABASI, AGED 32

IN THE MATTER OF:

LIST OF DATES AND EVENTS

IN THE MATTER OF:

WRIT PETITION UNDER ARTICLE 226 OF CONSTITUTION OF INDIA

THE HON’BLE CHIEF JUSTICE

MOST RESPECTFULLY SHOWETH:

IN THE MATTER OF:

IN THE MATTER OF:

IN THE MATTER OF:

IN THE MATTER OF:

IN THE MATTER OF:

IN THE MATTER OF:

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APPLICATION U/S 482 CR.P.C. FOR EXEMPTION FROM FILING

IN THE MATTER OF:

IN THE MATTER OF:

IN THE MATTER OF:

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