IN THE COURT OF MS.

ANKITA LAL, NEW DELHI DISTRICT,

PATIALA HOUSE COURT COMPLEX, NEW DELHI.

APPLICATION NO. OF 2019

IN THE MATTER OF:

YUHANA MANZOOR …APPLICANT/COMPLAINANT

VERSUS

ANIL KUMAR AND ORS. … ACCUSED/RESPONDENTS

P.S-CHANAKYAPURI
FIR NO 088/2019
U/s 323, 341, 356, 379 and 34 IPC.

INDEX

S.NO. PARTICULARS PAGES

1. APPLICATION UNDER SECTION 156 (3) OF THE

CR.P.C. SEEKING DIRECTIONS FOR PROPER
AND COURT MONITORED INVESTIGATION AND
ADDITION OF CERTAIN NEW
CHARGES/OFFENCES IN THE FIR WHICH
WERE COMMITTED BY THE ACCUSED
PERSONS AGAINST THE
APPLIANT/COMPLAINANT ALONG WITH
AFFIDAVIT IN SUPPORT.
2. ANNEXURE – C-1

COPY OF THE FIR BEARING NO 088/2019

DATED 12.08.2019 LODGED AT PS
CHANAKYAPURI.
5. VAKALATNAMA

FILED BY

ADVOCATE FOR APPLICANT/COMPLAINANT

C–66, SECOND FLOOR,
NIZAMUDDIN EAST,
NEW DELHI–110013
PH. NO.
EMAIL:
DATED: 26.09.2019
 IN THE COURT OF MS. ANKITA LAL, NEW DELHI DISTRICT,
PATIALA HOUSE COURT COMPLEX, NEW DELHI.

APPLICATION NO. OF 2018

IN THE MATTER OF:

YUHANA MANZOOR
D/O MR. MANOOR BHAT
R/O HOUSE NO SHUHUL 09
RAJBAGH, SRINAGAR ,
JAMMU AND KASHMIR … APPLICANT/COMPLAINANT

VERSUS

1. ANIL KUMAR
S/O VINCENT PETER
R/O ST MICHEAL CHURCH,
PRASAD NAGAR, NEW DELHI

2. JACINTA VINCENT
W/O ANIL KUMAR
R/O ST MICHEAL CHURCH,
PRASAD NAGAR, NEW DELHI

3. JENNY VINCENT
D/O VINCENT PETER
R/O ST MICHEAL CHURCH,
PRASAD NAGAR, NEW DELHI

4. APARAJITA
D/O BHOLA SINGH
R/O DHANBAD, JHARKHAND … ACCUSED/RESPONDENTS

P.S-CHANAKYAPURI
FIR NO 088/2019
U/s 323, 341, 356, 379 and 34 IPC.

APPLICATION UNDER SECTION 156 (3) OF THE

CR.P.C. SEEKING DIRECTIONS FOR PROPER AND
COURT MONITORED INVESTIGATION AND
ADDITION OF CERTAIN NEW CHARGES/OFFENCES
IN THE FIR WHICH WERE COMMITTED BY THE
ACCUSED PERSONS AGAINST THE
APPLIANT/COMPLAINANT ALONG WITH AFFIDAVIT
IN SUPPORT.

MOST RESPECTFULLY SHOWETH:

1. That the Applicant is a law abiding and peace loving citizen of

this country who happens to be a makeup artist by

profession.

2. That the applicant is a renowned personality in her field and

has brought many laurels and accolades to her name, both

nationally as well as internationally.

3. That it is submitted that on 12.08.2019, an FIR bearing

number 088/2019 u/s 323, 341, 356, 39 and 34 IPC was

lodged at PS Chanakyapuri against the above-mentioned

accused persons at the instance of the

Complainant/Victim/Applicant.

4. That it is prima facie evident from the contents of the FIR that

the Complainant/Victim/Applicant has been subjected to

many other grave offences, which have been made out,

however, the Police/Investigating Agency has failed to do its

duty in a fair and unbiased manner by not booking the

accused persons under relevant sections of law.

5. That it is pertinent here to note that the

Complainant/Victim/Applicant was subjected to so much of

physical as well as mental harassment and trauma and that

the Police has tried its level best to water down the case, so

that the Accused go scot free.

6. That a bare reading of the FIR clearly indicates that various

heinous offences punishable have been committed by the

accused persons, however, the accused persons have not

been booked under relevant sections of IPC.

7. That the entire conspiracy to water down the case of the

Complainant/Victim/Applicant has been in connivance with

the Police as well as the accused persons.

8. That a bare perusal of the RUKKA clearly indicates that

various heinous offences such as offences punishable under

sections 354, 392, 397, 506 IPC have been committed by the

Accused persons, however, the same has not been registered

by the Police.

9. That the Complainant/Victim/Applicant, by the way of this

application wants to convey to this Hon'ble Court that the

Complainant/Victim/Applicant is constantly receiving death

threats to settle the matter with the accused persons, as the

main accused namely Anil Kumar happens to be a very

powerful man who is very well politically connected and that

the said accused may go to an extent of killing the

Complainant/Victim/Applicant if she does not settle the

matter.

10. That it is pertinent here to note, that on ......, the main

Accused, Anil Kumar, through his legal counsel, Mr Kapil

Chandana has returned back Rs 50,000/- which was looted

by the Accused persons and an unsealed new IPhone 8+

mobile phone to the Complainant/Victim/Applicant.

From......, the Accused person(s) are after the life of

Complainant/Victim/Applicant to settle the matter and sign

the MoU, so that the FIR can be quashed.

11. That the present Application is being filed by the Applicant

being aggrieved of the inaction on part of the concerned police

officials who have failed to register an FIR under relevant

provisions of law despite repeated oral complaints filed the

Applicant disclosing commission of various heinous offences,

by the Accused, which have not been added in the FIR, till

date. The Applicant is therefore, constrained to move the

present Application seeking directions from this Hon’ble

Court for proper time bound investigation and registration of

F.I.R. under relevant provisions of law against the Accused

persons

12. It is submitted thatin ‘Sakiri Vasu v. State of UP and Ors.’

[(2008) 2 SCC 409], the Hon'ble Supreme Court of India has

held that:

"Section 156(3) Cr.P.C. is wide enough to include all such

powers in a Magistrate which are necessary for ensuring a
proper investigation, and it includes the power to order
registration of an F.I.R. and of ordering a proper investigation if
the Magistrate is satisfied that a proper investigation has not
been done, or is not being done by the police. Section 156(3)
Cr.P.C, though briefly worded, in our opinion, is very wide and
it will include all such incidental powers as are necessary for
ensuring a proper investigation".

13. That it is submitted that since no action whatsoever has been

taken by the police officials against the Accused persons till

date with regard to the aforesaid complaints filed by the

Applicant, the Applicant is therefore, approaching this

Hon’ble Court seeking strict action against the culprits who

are named in his Complaint as per law. It is pertinent here to

note that this Hon'ble Court has granted interim protection to

 only one accused, namely, Anil Kumar and the other accused

persons are still roaming around scot free. Hence, the

present Application.

14. That the Applicant craves kind leave of this Hon’ble Court to

add, alter, amend or delete the contents of the present

Application and rely on any additional grounds as may be

available to him at the time of hearing before this Hon’ble

Court.

15. That since the aforesaid offences have been committed within

the jurisdiction of this Hon’ble Court, therefore, this Hon’ble

Court has the territorial jurisdiction to hear and decide the

present Application.

16. That the Applicant has not filed similar Application or any

other Application seeking same relief(s) before this Hon’ble

Court or any other court in India.

17. That the present Application has been moved bonafide and in

the interest of justice.

PRAYER

In light of the aforementioned facts and circumstances, it is

therefore, respectfully prayed that this Hon’ble Court may

kindly be pleased:

a) to issue directions to the S.H.O. P.S.

Chanakyapuri, New Delhi/concerned police

officer/s to add other charges/ offences against

the Accused/Respondents u/s 354, 392, 397 and

506 IPC and carry out the investigation in a free

 and fair manner and submit the final report in

this regard; and/or

b) topass any other and further order(s) as this

Hon’ble Court deems fit and proper in the facts

and circumstances of the present case in favour of

Applicant/Complainant and in the interest of

justice.

APPLICANT/COMPLAINANT

THROUGH

ADVOCATE FOR APPLICANT/COMPLAINANT

C–66, SECOND FLOOR,
NIZAMUDDIN EAST,
NEW DELHI–110013
PH. NO. EMAIL:
PLACE: NEW DELHI
DATED: 26.09.201
 IN THE COURT OF MS. ANKITA LAL, NEW DELHI DISTRICT,
PATIALA HOUSE COURT COMPLEX, NEW DELHI.

APPLICATION NO. OF 2018

IN THE MATTER OF:

YUHANA MANZOOR … APPLICANT/COMPLAINANT

VERSUS

ANIL KUMAR AND ORS. … ACCUSED/RESPONDENTS

AFFIDAVIT

I, Yuhana Manzoor D/o Mr. Manzoor Bhat, aged 24 years R/o

House No Shuhul 09, Rajbagh, Srinagar, Jammu and
Kashmir, presently at New Delhi, do hereby solemnly affirm
and declare as under:-
1. That I am Applicant/Complainant in the present case and
being well conversant with the facts and circumstances of the
present case, I am competent to swear this affidavit.

2. That the accompanying Application under Section 156 (3)

Cr.P.C. has been drafted by my counsel on my instructions
and I have read and understood the contents of the same and
I state that they are true and correct to the best of my
knowledge and belief.

3. That the contents of the accompanying Application may

kindly be read as part and parcel of this affidavit also as the
same are not being repeated herein for the sake of brevity.

DEPONENT

VERIFICATION:

Verified at New Delhi on this 19th day of September 2019

that the contents of my above affidavit are true and correct to
the best of my knowledge and belief and nothing material has
been concealed therefrom.
DEPONENT