Before The High Court of Judicature at Mumbai

To

The Hon’ble Chief Justice

High Court Mumbai

Misc.Application .......2020

1-Smt.Punam Kaur,aged about 52 Yrs. W/o Sardar Tejendra Singh

2-Mohit Singh aged about 27 years, S/o Sardar Tejendra Singh,Both Residents of H.N..C 14/151
Kazipura khurd Sonia District-Varanasi (U.P) ........Applicants

Vs

1-District Magistrate Goregaon Mumbai

2-Police Commissioner Mumbai

3-District Magistrate, Varanasi (U.P.) ....Respondents

1-The applicants above named are Residents of District Varanasi, U.P. and came to Mumbai on
religious tour to visit at Siddhivinayak Temple and the return ticket of flight of both the applicants
was confirmed on 25th March 2020 to District Varanasi, but due to spread of Covid-19 (Coronavirus)
and sudden pronouncement of locked down effective on 22nd March the flight of applicants was
cancelled and both have been stuck at Mumbai leaving behind the 87 year old mother of applicant
no.1 as well as the husband of applicant no.1.

2-That the applicants have taken Shelter under home of their relative and followed the guidelines of
locked down.

3-That the flight journey of applicants have been rescheduled for 15th April which was again
cancelled due to further extension of lockdown till 3rd of May.

4-That the mother of applicant no.1 was fallen ill and now is critical and also the husband of
applicant no.1 is also diabetic and hypertensive and on bed due to being stacked the applicants at
Mumbai, and no one remained there at Varanasi to look after their medications as well as the foods
also.

5- That the applicants are law abiding citizens and followed the directives issued by the government
in regards to lockdown but are in dire situations as they have been stuck at Mumbai and unable to
extend their support to the old aged mother who is critical and senior citizen husband of applicant
no.1.

6-That the applicants have applied for permission through the website of Mumbai Police which have
been rejected outrightly without assigning any proper and suitable reason.
7-That the applicants are ready to travel to District Varanasi at Uttar Pradesh by hiring a Cab with its
return permission for Cab Driver, but the Police Department of Mumbai are not interested to give
the travel permission to the applicants.

8-That the applicants are ready to furnish any terms and conditions to the satisfaction of Mumbai
Police as they deem fit and proper under the circumstances of the facts as explained above.

9- That this Hon’ble court may treat the instant application as Mercy application under the facts and
necessity of the travelling to Varanasi District at U.P.

10-That if the applicants have not been provided the travel pass for road journey to Varanasi by this
Hon'ble Court the applicants will lost the valuable moments of serving to the elderly members of
family.

Prayer:
That it is therefore humbly submitted in the interest of Justice that this Hon’ble court may graciously
be pleased to direct to the respondent authorities to Manage a travel pass to the applicants through
a road journey to District Varanasi at UP, So that the justice be done, otherwise the applicants will be
suffered a great hardships.

Date- 26/04/2020

Smt. PUNAM KAUR

MOHIT SINGH

Mobile No: 7007308140

Email ID: mohitchstobhu@gmail.com

(Applicants)