IN THE HON'BLE HIGH COURT OF KARNATAKA,

AT BANGALORE

CRL. P. NO. 72023

IN THE MATTER OF:

Alok Ohhe ...PETITIO N ER

AND

State of Karnataka and Anr. ...RESPONDENTS

IN D EX

Sr. P articu lars Pg.

No. No.
1. Synopsis and List of Dates

2. [Memorandum of Criminal Petition under Section 482 of the

Code of Criminal Procedure, 1973 read with Articles 226
and 227 of the Constitution of India, 1950.

3. Verifying Affidavit
15
4. A nnexure A: Certified Copy FIR bearing Cr. No.
0001/2023 registered at Madivala Traffic P. S. along with tb -
readable copy of the FIR

5. A nnexure B: Certified Copy of Complaint dated

01.01.2023 submitted by Respondent No. 2

6. A nnexure C: Certified Copy of Application dated

16.01.2023 for inserting Section 304A, IPC into FIR
bearing Cr. No. 0001/2023 along with order dated
17.01.2023 and the accompanying inquest report.

7. A nnexure D: A Copy of a photograph of the car being

driven by the Petitioner dated 01.01.2023

8. A nnexure E: A Copy of Memorandum of Settlement

dated 31.01.2023 executed between Petitioner and ^0 - Mb
Respondent No. 2, along with copies of supporting
affidavits.

9. Vakalatnama Hn
 10. Interlocutory Application under Section 482 seeking Stay
of Further Proceedings along with Affidavit.

11. Interlocutory Application under Section 482 seeking

dispensation of production of translated and typed copies
of Annexures A, B and C, along with Affidavit.

Place: Bangalore
r
Date: 31.01.2023 Counsel for the Petitioner
 IN THE HON'BLE HIGH COURT OF KARNATAKA,
AT BANGALORE

CRL. P. N O ._______/2023

IN THE MATTER OF:

Alok Ohrie ...PETITIO N ER

AND

State of Karnataka and Anr, ...RESPONDENTS

SYN O PSIS

The present petition has been filed seeking quashing of Complaint dated

01.01.2023 filed by Respondent No. 2/the Complainant, the FIR bearing

Cr. No. 0001/2023 registered by Respondent No. 1, initially under Sections

279, 337 IPC and Sections 13 4(a,b ), 187 of the Motor Vehicles Act, 1988,

to which Section 304A, IPC was subsequently added, as well as all

consequential proceedings emanating therefrom ('the Im pugned

Proceedings'). The Petitioner and the Respondent No. 2 have amicably

and voluntarily executed a Joint Memorandum of Settlement dated

31.01.2023 ('the Settlem ent') to put an end to all disputes between them ,

including the Impugned Proceedings.

It is the case of the Petitioner that offences alleged are not against society

at large, are not serious or heinous. The Settlem ent is not opposed to public

policy and the grant of relief as prayed for by this Hon'ble Court is necessary

to secure the ends of justice.

No useful purpose will be served by continuing the Impugned Proceedings.

The cause of justice will be subserved if this Hon'ble Court gives its

imprimatur to the Settlement, as well as grants the relief of quashing the

Impugned Proceedings on the basis of the Settlement.

L IS T OF DATES

Date P articulars
01.01.2023 The Petitioner (along with his wife) was driving to Bangalore

from Coonoor. While on Hosur Road, the Petitioner's car w as

run into on the rear left-side by a motorist riding a two-

wheeler. Immediately upon noticing this, the Petitioner

stopped his car, alighted from it, and went to the aid of the

motorist that had fallen off his two-wheeler. Noticing that

the motorist seemed stable, and upon being informed by

members of a gathering crowd that an ambulance had been

called for, the Petitioner removed himself from the location

of the accident. The Injured motorist was admitted to S t.

John's Medical College Hospital soon after.

01.01.2023 Later on the sam e day. Respondent No. 2/Complainant

submitted a complaint in relation to the accident involving

his brother and the Petitioner. This complaint was registered

as FIR bearing Cr. No. 0001/2023 at Madivala Traffic P. S.

 under Sections 279, 337 IPC and Sections 134 (a ,b ), 187 of

the Motor Vehicles Act, 1988.

02.01.2023 The Petitioner appeared before Madivala Traffic P. S .,

complied with all legal formalities, provided necessary

documents, and obtained station bail.

05.01.2023 On being informed that the Respondent No. 2's brother had

sustained serious injuries due to the accident, the Petitioner

reached out to the Respondent No. 2 through counsel and

provided- on a good-faith basis- financial assistance of Rs.

1,50,000/- for medical expenses.

16.01.2023 The Respondent No. 2's brother breathed his last at St.

John's Medical College Hospital.

17.01.2023 Section 304A, IPC was added to the FIR bearing Cr. No.

0001/2023.

31.01.2023 The Petitioner and Respondent No. 2 (along with

dependents and immediate fam ily members of the

deceased) arrived upon an amicable settlement vide which

the Respondent No. 2, inter alia, agreed to withdraw

 ©
allegations made against the Petitioner vide his complaint

dated 01.01.2023, and has consented to quashing of the

criminal proceedings pending against the Petitioner.

Hence this Petition.

Place: Bangalore

Date: 31.01.2023 Counsel for the P etitioner

 IN THE HON'BLE HIGH COURT OF KARNATAKA,
AT BANGALORE

CRL. P. NO. J2Q23

IN THE HON'BLE COURT OF THE METROPOLITAN M AGISTRATE

(TR A FFIC CO URT-6), CMM COURTS, BANGALORE

Cr. No. 0 0 0 1 /2 0 2 3

RANK OF THE P A R TIES

IN THE MATTER OF: BEFO RE TH IS BEFO RE THE

HON'BLE COURT T R IA L COURT

Alok Ohrie Petitioner A ccused

Aged 56years,
S/o. S. S. Ohrie,
Resident of #121, 3'^ Floor
3''^ Main, Defence Colony,
Indiranagar,
Bangalore-560038.

AND

1. S ta te of Karnataka, Respondent No. 1 In vestig atin g

Through Madivala Traffic Agency
Police Station, Represented
by the Ld. High Court
Government Pleader.

2. Afroz Khan, Respondent No. 2 In fo rm an t

Aged 43 years, /C o m p lain ant
S/o. Usman Khan,
Resident of #318,
Lai Bagh Road, Bada Makan,
Wilson Garden,
Bangalore-560027.

MEMORANDUM OF CRIM IN A L P ET IT IO N UNDER SEC T IO N 4 8 2 OF

THE CODE OF CRIM IN A L PRO CED U RE. 1973 READ W ITH A R T IC LES
226 AND 227 OF THE CO N STITU IO N OF IN D IA , 1950.

The Counsel for the Petitioner resp ectfully subm its:

1. The addresses of the parties for the purpose of service of notices,

summons and other processes of this Hon'bie Court are as stated in tlie

cause title above. The Petitioner may also be served through his counsel

at the Chambers of Rohan Kothari, D4, Dona Cynthia, 35 Primrose Road,

Bangalore-560025.

2. The present petition has been preferred seeking quashing of (I)

Complaint dated 01.01.2023 filed by the Respondent No. 2/Complainant

in relation to a motor-vehicle accident that involved his (now deceased)

brother and the Petitioner herein ('the Com plaint^, (ii) the FIR bearing

Cr. No. 0001/2023 registered by the Respondent No. 1 on the basis of

the Complaint for offences punishable under Sections 279, 337 IPC and

Sections 1 3 4 (a,b ), 187 of the Motor Vehicles Act, 1988 ('the FIR") and

(iii) all proceedings emanating from the Complaint and FIR. The

Complaint, FIR and the proceedings emanating therefrom are

collectively referred to as 'the Im pugned Proceedings'.

3. It is stated that Section 304A, IPC was added to the FIR on 17.01.2023,

as a consequence of the Respondent No. 2's brother succumbing to his

injuries on 16.01 .2 0 2 3 .

(A certified copy of FIR bearing Cr. No. 0001/2023 registered at Madivala

Traffic P. S. is annexed hereto as ANN EXURE-A)

(A certified copy of the Complaint dated 01.01.2023 is annexed hereto

as AN N EXURE-Bl
 ©
(A certified copy of the Application dated 16.01.2023 to insert Section

304A, IPC into FIR bearing Cr. No. 0001/2023, the order thereon dated

17.01.2023 and the accompanying inquest report are annexed hereto

as ANN EXURE-C)

4. The FIR is presently pending on the file of the Hon'ble Metropolitan

Magistrate (Traffic Court-6), CMM Courts, Bangalore, at the stage of

investigation. To the best of the Petitioner's knowledge, chargesheet has

been submitted in respect of the FIR by the Respondent No. 1.

5. It is submitted that the Petitioner and Respondent No. 2 have arrived

upon an amicable settlement and the present petition has been

preferred primarily on account of such settlement. It is the case of the

Petitioner that no purpose will be served by letting the Impugned

Proceedings continue, and that quashing the Impugned Proceedings is

in the interests of justice.

B R IE F FACTS

6. The Petitioner is a respected member of the business community and is

presently the Managing Director of Dell Technologies India Pvt. Ltd. On

the evening of 01.01 .2 0 2 3 , the Petitioner (along with his wife) was

driving into Bangalore from Coonoor, Tamil Nadu in a car bearing No.

KA 03 NL 2601. While driving on Hosur Road, the Petitioner suddenly

 (D
heard a loud noise and felt a minor impact on the rear-left side of his

car. He immediately stopped on the side of the highway, noticed from

his rearview mirror that a motorist on a two-wheeler had fallen on the

road. Thereafter, the Petitioner immediately alighted from his vehicle to

check on the motorist.

7. On reaching the motorist, the Petitioner noticed that he was injured but

conscious and stable. A crowd of passersby had gathered by this tim e,

and one of them informed the Petitioner that an ambulance had been

called for, and that he need not wait. Noting that the injured motorist

was conscious and that help was on its way, the Petitioner returned to

his car and drove home.

8. It may be noted that the Petitioner, at the time of the accident, was

driving in compliance with all applicable laws and regulations. His driving

was responsible, safe and not at all rash or reckless. Even the impact

sustained by the car he was driving (on the rear left-side, where the

front and rear doors meet) Is extremely slight.

(A copy of the photograph of the Petitioner's car immediately after the

occurrence of the accident on 01.01.2023 is annexed hereto as

AN N EXURE-D^

9. Subsequently, it came to the Petitioner's knowledge that the Respondent

No. 2 had submitted the Complaint to the Respondent No. 1 in relation

 to the accident that involved the Petitioner. The Complaint came to be

registered as the FIR. The Petitioner was directed to appear before the

Respondent N o.l in connection with the Complaint on 0 2.01.2023. He

appeared as directed, provided all information and documents as

sought, and also obtained station bail. It was upon reading the

Complaint and FIR that the Petitioner came to know that the injured

motorist was one Sh. Fairoz Khan, and that the Respondent No. 2 w as

his brother.

10. Soon thereafter, the Petitioner was informed that Sh. Fairoz Khan had

sustained serious injuries (in his brain) and was being treated at S t.

John's Medial College Hospital, Bangalore. On learning this, the

Petitioner immediately established contact with Respondent No. 2

through counsel. The Petitioner was made aware that Sh. Fairoz Khan

was a man of modest means, and that he had a wife and two children

that were his dependents.

11. Given this, the Petitioner extended financial assistance (on a good-

faith basis) for the medical expenses being incurred in Sh. Fairoz Khan's

treatm ent. The financial assistance provided was an amount of Rs,

1,50,000/- (Rupees One Lakh Fifty Thousand) paid vide cheque dated

04.01.2023 bearing No. 000094, drawn in favour of Respondent No. 2.

Discussions between the Petitioner and Respondent No. 2 for an

 amicable resolution of the matter were on-going, and both parties had

agreed that protracted legal proceedings would be in nobody's interest.

12. As things stood thus, Sh. Fairoz Khan succumbed to his injuries and

breathed his last on 15.01.2023. Consequently, Section 304A, IPC came

to be added to the FIR on 17.01.2023.

13. Notwithstanding the above, the discussion between Petitioner and

Respondent No. 2 to give quietus to the pending (and potential) legal

proceedings continued. This culminated in the execution of

Memorandum of Settlement dated 31.01.2023 by the Petitioner and

Respondent No. 2 ('the Settlem ent').

(A copy of the Memorandum of Settlement dated 31.01.2023 along with

supporting affidavits is annexed hereto as A N N EX U R E-E^

14. As per the Settlem ent, the Respondent No. 2 has withdrawn all

allegations made against the Petitioner vide the Complaint. He has also

given consent for closure/quashing of the Impugned Proceedings, and

has agreed not to prefer any claims in the future against the Petitioner

or in relation to the accident dated 0 1 .0 1 .2 0 2 3 . It may be noted that

the dependents and Immediate family members of Sh. Fairoz Khan have

acted as consenting witnesses to the Settlem ent and have also provided

affidavits in support thereof.

 ©
15. It is light of the amicable settlement entered into between the

Petitioner and Respondent No. 2 that the present petition has been

preferred. It is stated that no other petition has been preferred in respect

of the subject-matter of the present petition, and the present petition is

preferred on the basis of the following, amongst other grounds.

GROUNDS

16. That the Petitioner and Respondent No. 2 have amicably settled all

their inter-se disputes, including those arising out of and underlying the

Impugned Proceedings. The Settlem ent is neither against public policy

and nor does it have any deleterious effect on society or the general

public. Hence this Hon'ble Court has the jurisdiction to allow the present

petition based on the amicable settlement arrived between the Petitioner

and Respondent No. 2.

17. That in addition to the above, it is submitted that it is evident that

the offences alleged to have been committed by the Petitioner are

private in nature and do not have a serious impact on society.

18. That the Hon'ble Supreme Court has, in several judgm ents, held that

continuation of criminal proceedings- when parties have inter-se settled

their disputes and such settlem ent is in respect of offences which are

private in nature, and have no societal impact- would tantamount to an

 abuse of process of the law. It has further been held that exercise of the

Court's inherent powers under Section 482, CrPC read with Articles 226

and 227 of the Constitution, would in such cases be permissible and in

the interests of justice (See Gian S in g h v. S t a t e o f P u n ja b (2 0 1 2 )

10 s e e 303).

19. That the offences alleged to have been committed by the Petitioners

are not serious or heinous, and there are several prior instances where

Hon'ble High Courts have quashed proceedings arising out of the sam e

offences in view of an amicable settlement between parties.

20. That it is now well settled that mere non-compoundability of an

offence will not come in the way of this Hon'ble Court exercising its

inherent powers to quash the Impugned Proceedings.

21. That since parties have entered into the Settlem ent, it will be futile

to continue with the Impugned Proceedings as no public interest would

be served, and such continuance would result In an avoidable wastage

of precious judicial time and expense.

22. That the Petitioner will be put to great hardship and prejudice if the

Impugned Proceedings are not quashed as he will have to face the

rigours of a criminal trial despite having arrived at an amicable

 settlement with the Respondent No. 2, through which all the allegations

made against him have also been withdrawn.

23. That even on the face of the record, the Petitioner is innocent and

has not committed any offence.

24. The Petitioner seeks liberty of this Hon'ble Court to urge such

additional grounds as may be necessary when this petition is taken up

for hearing.

PRA YER

W HEREFORE, in light of the foregoing, it is respectfully prayed that this

Hon'ble Court be pleased to:

(a) Set aside and quash the Complaint dated 01.01.2023 filed by the

Respondent No. 2 (A nnexure-B ^. the FIR bearing Cr. No. 0001/2023

registered by Respondent No. 1 on 01.01.2023 for offences

punishable under Sections 279, 337 IPC and Sections 134 (a ,b ), 187

of the l^otor Vehicles Act, 1988 rA nnexure-A '). to which Section

304A, IPC was added on 17.01.2023 vide A nnexure-C. as well as all

proceedings emanating therefrom .

(b) Pass such other order/directlon(s) as may be necessary in the

interests of justice and equity;

Place: Bangalore

Date: 31 .01 .2 0 2 3 Counsel for the Petitioner

A d d re s s fo r S ervice:
Chambers of Rohan Kothari
D4, Dona Cynthia
35, Primrose Road,
Bangalore-560025.

Em ail; rohan.kothari@chambersrk.com
Mobile: 9845287182
 ©
IN THE HON'BLE HIGH COURT OF KARNATAKA,
AT BANGALORE

CRL. P. N O .______ /2 0 2 3

IN THE MATTER OF:

Alok Ohrie ...PETITIO N ER

AND

State of Karnataka and Anr. ...RESPONDENTS

A FFID A V IT

I, Alok Ohrie, aged 56 years, s/o. Mr. S .S . Ohrie, resident of # 12 1 , 3rd

Floor, 3rd Main, Defence Colony, Indiranagar, Bangalore-560038, do

hereby declare and affirm that:

1. I am the Petitioner in the present petition. I am fully aware of the facts

and circumstance of the case and competent to sw ear to this affidavit.

2. I state that the averments contained in Paragraphs 1 t o ___in the present

petition are true and correct to the best of my knowledge, information

and belief, including legal advice provided to me.

3. I state that the documents annexed as ANNEXURE A to E to the ^ e se n t ^

petition are true copies of their originals.

PLACE: Bangalore

DATE: 31.01.2023 ^DEPONENT

ID E N T IF IE D BEFO RE ME:
2. sr?cS3.. S51^ BOorfes ; [pc ibbo (U/s-2/9,337); INDIAN MOTOR VEHICLES ACT, 1988 (U/s-134(a&b).187)

3. (s) £i7j: Sunday ajK osaoD ; 01/01/2023 SwSogddn; 01/01/2023

: 19;15;00 sevojj^iSn : 19:16:00

(b) CJSsfoi)©^ k^Qkz5 ; 01/01/2023 21:45:00 E.:tfs^rif,o±0„ / ; others

(c) &od:3miwsd / stz^r) s d a s±53Sdf* csocsrt^o :

(d) ^osS^ hsj-os : 1 , 21:45:00

BETA^EEN BOMMANA HALLl & ROPPENA AGPvAHARA BSU STOP, ROOPEN

AGRAHARA, Bengaluru City, Karnataka,
(b) c&>od '?dasj 0 ^3^ iSjsd: 1 kM TOWARDS EAST
(c) RUFENA AGRAHAJ^ HOSUR ROAD
(c^ £Jed ® ssiIcsd :

5. &v^3srdocrad/S5sfeeurod:
(a) : AFROZ KHAN ^ / Tio:^ ^ d o : LATE. USMAN KHAN

ssa±iso^ : 43 (c) sSej4: - Businessman

(d) z ;^ r ■ Musiim (e) ESS'S : MUSLIM

(f) (g) '^-:±!co«':

0D5&;^?Qd3^ '■ India

'5^s^r?^o^A'4'- aesrf a^oo:

T?;
C?UL^

/o
 ©

Sil.ori iSsir
/asSdj ssu { s^i
!tj^
CAR DRIVER NO

KAG5LN9133(A1)
,-Bengaiuru City,
Kamaiaka.

7 . cSososa^D £)s d ?i ? d
SL
ccrSdw
No

'/ F A iR O Z khan
NO.319. BADA

MAKHAN, K.SiDDAIAH
Driver-autoricks
road
haw
‘-’^iiycsjuiu ;C it^
Bengaluru
, _^ ------------------- Kamata'Ka

Si.No
Property Type
Item description
Esfimated Value (in Rs.)

fc-S5Ssg„o='SoEoc^;KA-m-Wi ^
SofiJc&od E550S es

tsSci. 1 Ac-^jssdd
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r .
S y & In s p e c to r ot P c v c e
«»^adf¥ala T r a f n c P o lic e S t a t io *

^e7^<n ; Superintendent o f Po!ice/Commissioner o f Police

.z
i.)
^ \% V /r^'
 SjdQ
(CjCC335/!^0^^CCkjScJJC 154 u uvil )
jrasOSraaoS); Metropolitan Magistrate (Traffic Court -6),Nrupatunga Road,
Bangalore City

1. z2«3„ ; Bengaluru City azjrart ; South East Traffic Sub-Div 3ifs«Df?o^ : Madivala Traffic
»sdro^ : 0001/2023 ; 01/01/2023

2. ffSOjDo ; ip c i860 (U/s-279,337); INDIAN MOTOR VEHICLES ACT, 1988 (U/s-134(a&b), 187)

3. (a) asi; Sunday a?rao^ aod ; 01/01/2023 ajrao^ : 01/01/2023

rfes?c&orf : 19:15:00 s5es?0±)si!3rt ; 19:16:00

(b) G3E«o±)«„ s^;^Fsto?i arooii: 01/01/2023 21:45:00 JJddrlr1o±)«3„ / ; Others

(c) l)Oji::t)F!±)TOd / tasl^ccrod sJda :

(d) zs^da®' sJosJe s ii;^ ?j5±>oi3: 1 , 21:45:00

4- (a) :
BETWEEN BOMMANA HALLI & ROPPENA AGRAHARA BSU STOP, ROOPEN
AGRAHARA, Bengaluru City, Karnataka,
(b) S35l otoorf '^dosi atJo* 5 *;^ clrad : 1 KM TOWARDS EAST
(c) rro;5i): RUPENA AGRAHARA ^?ido : HOSUR ROAD
(d) ?Otp^sS s5ed 43i£)??3«' S3fl rae5i,rt sodosSo^^SocSo^ edd « sJpiSe;!!*' crss^ai) 2o?Jdo ;
23«3„:
5. SjoSraFdorod/zrai^ensd:
(a) ^Aido : AFROZ KHAN ;^oc3 / rioc^Ei ^?odo : LATE. USMAN KHAN

(b) 55o±)So^ 43 (c) Businessman

(d) Muslim (e) sssvS MUSLIM

(f) (g) ^-sbeo'':

(h) dradrorS (i)ro&i^«ai3^ India

(j) TOTo*' sJpete^F ?ioaJe: aearf a^rao^S :

 Male
(k) : N0.319. BADA (') :
MAKHAN.H.SIDD
AIAH ROAD ,
Bengaluru City ,
Karnataka-560027

(m) £jo±raFrforoci iOocTOon fl/seadod oqiro Se%^jsoac3«'

HEARING

^ 6. rU>4do5^/ sgjs^F
Soi^do/iiorfoi) sSf^do/ sroa
SI.No. sJ44,oS) ^aqi dori
I £i<?S7i

CAR DRIVER NO
Accused Common Male
KA05LN9133(A1)
man
,-Bengaluru City,
Karnataka

7. fSjsocisici
SI.
2oSid0 £)TO?J nsaiid aqj Sort 5dol)?oO^ =^o4,
No
FAIROZ KHAN N0.319. BADA
1 Male 44 Driver-autoricks
MAKHAN, H.SIDDAIAH
years haw
ROAD
Bengaluru City
Karnataka

8. ^?*orar>ciosj / rorioSrancjosS ^)s5ciri?*o

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1

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i'^r/M rs./M iss....... ........................... .....................................................................sged a b o u t........... L ..;................ years

c o m e /b ro u g h t to th e e m e rg e n c y m e d ic in e d e p a rtm e n t V v 'itli a lle g e d h is io ry o f RTA

Q Assault Q W ork place injury Q Poisoning Q Elecirocution Q Hanging Q Drovming

The above Mentioned Patient

/*
□ Admitted in........ .............................ward floor. Ward telephone number.,
^ ( G-U. ..v^ard
on.... .l.*°..J..l/..?;.r'....(Date) a t A : . } . R in.

□ Brought Dead.

□ Absconded from the Hospital on................................... ....................

□ Gone against Medical advice.

□ Treated and sent home.

□ Please come and record statement immediately, p'atien't is serious.

4
I Patient’s Residential address
/\
i )Door number: •it
/
^ re e t; (Ic
Locality A/illage: b ^
Taluk: ^ Kindly do the needful
District: Ci ^ 0~Q ^ ^ Yours faithfully

Phone/Mobile no: 33 ^ 3 Signature:

Site of accident with Land iVIark
Name:
Road: 6 0 f v U \ NJ-Ar
For Senior CMO
Locality: ■ R o 0(?| lO ^ A fc ^ \
intimation yeceived by Police^ on...... .......................... (Date)........... ................ (Time)
' 1
Signature ■
INTIMATOOl /ROO
Seal of Po ice
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 INDIA N O N JUDICIAL

G o x e rn n H rn o tK a m a ^ ^

e-Stamp

Certificate No.
IN-KA66421049753792V
Certificate Issued Date
31-Jan-2023 10:27 AIVI
Account Reference
NONACC (FI)/ kabacslOS/ M G ROADi/ KA-SV
Unique Doc. Reference
Purcl'iased by S U B IN -K A K A B A C S L 0 8 2 5 4 8 8 0 2 0 6 7 2 0 8 6 V
ALOKOHRIE
Description of Document
Article 48 Settlement
Property Description
SETTLEMENT AGREEMENT
Consideration Price (Rs.) 0
(Zero)
First Party
AFROZ KHAN
Second Party
ALOKOHRIE
Stamp Duty Paid By
ALOK OHRIE
Stamp Duty Amount(Rs.)
200
(Two Hundred only)

Please write or type below this line

MEMORANDUM OF SETTLEM EN T

This memorandum of settlement is executed on this the of January,

2023 at Bangalore, by and between; / \

S ta tu to ry A le rt:

P cv oleasfc mforiTi ihe Competent Authority

 1. Mr. Afroz Khan, aged 43 years, s/o. Mr. Usman Khan, residing at # 3 i s ,
Lai Bagh Road, Bada Makan, Wilson Garden, Bangalore-560027 ( 'P a r t y
1 ), which shall mean and include his heirs, legal representatives and
pernnitted assigns;

AND
2. Mr. Alok Ohrie, aged 56 years, s/o. Mr. S .S . Ohrie, residing at # 121, T l ,
3'''^ Floor, 3'"'^ Main, Defence Colony, Indiranagar, Bangalore-560036
('P a rty 2 ');

W H EREA S,

(a) Party 1 had filed a connplaint dated 01.01.2023 with the Madivala
Traffic Police Station in respect of a road accident that occurred on the
same day, involving Party I's brother, Mr. Fairoz Khan and Party 2 ('th e
C o m p la in t'), on the basis of which and FIR bearing Cr. No. 0001/2023
came to be registered under Sections 279 and 337 IPC and Sections 134
and 187 of the Indian Motor Vehicles Act, 1988, ('th e F IR ') which is
pending investigation.

(b) During the pendency of the aforementioned matter. Party I 's brother,
Mr. Fairoz Khan, who had been admitted for treatm ent to St. John's
Medical College Hospital, Bangalore, breathed his last on 16.01 .2 0 2 3 .
Consequently, Section 304A, IPC came to be added to the FIR on
17.01.2023.

(c )It has come to Party I's attention that the road accident in question
occurred due to no act or omission of Party 2, and therefore no fault can
be attributed to him in respect of the accident, or the resulting
consequences.

(d) In light of the above, Party 1 and Party 2 have amicably arrived at
this settlement to give complete closure to the Complaint, the FIR and
proceedings emanating therefrom , as well as any and all other
 proceedings that can or may arise as a consequence of the
aforementioned accident.

NOW , T H E R E F O R E , the parties hereto agree as follows:

1. It is agreed that the road accident in question took place through no

fault of Party 2, and Party 1 withdraws all allegations made in the
Complaint against Party 2 in his capacity as driver of car bearing
Registration No. KA 03 NL 2601.

2. Party 2, as a gesture of goodwill and on humanitarian grounds has

provided financial assistance towards the medical expenses incurred
towards treatment of Mr. Fairoz Khan, and towards welfare of his
dependents to an extent of Rs. 30,00,000/- (Rupees Thirty Lacs Only)
('the Settlement Amount') in the following manner:
(i) Rs. 1,50,000/- (Rupees One Lac Fifty Thousand Only) paid vide
cheque bearing No. 000094 dated 0 5 .0 1 .2 0 2 3 , drawn in favour
of Mr. Afroz Khan;

(ii) Rs. 28,50,000/- (Rupees Twenty Eight Lacs Fifty Thousand

Only) to be paid vide Demand Draft drawn in favour of i^r.
Fairoz Khan's w ife, Mrs. Shaheen T a j, on appearance of Party
1 before the Hon'ble High Court of Karnataka at the time of
hearing of the petition filed by Party 2 for quashing of the
Complaint, the FIR and all proceedings emanating therefrom ;
the sufficiency of which is hereby confirmed.

3. Party 1 agrees that upon receipt of the Settlem ent Amount, neither he
nor any other dependent, relative or family member of Late Mr. Fairoz
Khan shall have any claim whatsoever in respect of the accident in
question and/or against Party 2. To that extent. Party 1 has represented
to Party 2 that besides him, the dependents and immediate fam ily
members of Mr. Fairoz Khan are (i) his wife Mrs. Shaheen Taj (ii) his
0^
 son, Master Shahid Khan, (iii) his daughter, Ms. Farzana Khanum, and
(iv) his older brother, Mr. Akram Khan ('the Immediate Fam ily'), who
have been made aware of the terms of this Settlement, and have
executed affidavits affirming their acquiescence to the sam e. Th e
affidavits of the Dependents annexed to this Settlement as A p p e n ^

4. Party 1 represents that besides the Immediate Family, there Is no other

person that can make a claim/demand/complaint or initiate legal
proceedings against Party 2 in respect of the accident in question or the
execution of this Settlement. No claim shall be preferred under
provisions of the Motor Vehicles Act, 1988 or any other statute in respect
of the accident in question.

5. Party 1 and the Immediate Family agree that any statement provided to
the Madivala Traffic Police or any other law-enforcement authority or
judicial officer which Is at variance with the term s of this settlem ent,
specifically Clause 1 hereof, shall be void and deemed to be unreservedly
withdrawn.

6. Party 1 agrees to indemnify and hold harm less Party 2 against any
clalms/demands/complalnts/legal proceedings brought against Party 2
by any person or entity (including but not limited to the Im m ediate
Family) in connection with the accident In question, and in respect of
this Settlem ent.

7. It is agreed that the payment of the Settlem ent Amount shall not be
construed under any circumstances as an admission of any wrongdoing
on the part of Party 2, and that such payment has only been made out
of concern for the wellbeing the of Mr. Fairoz Khan's dependents, and
for amicable closure of the pending and potential legal proceedings.
 8. Party 1 and the members of the Immediate Family agree that that t h e y

have no dispute or claims (present or future) against Party 2, and th at

they will extend all necessary co-operation for the closure of the
Complaint, the FIR and all proceedings emanating therefrom, including
but not limited to:

(i) providing any statem ent that may be necessary to the

jurisdictional police in the course of their investigation;
(ii) appearing before the Hon'ble High Court of Karnataka in the
event a petition for quashing the Complaint, FIR and
proceedings emanating therefrom is preferred by Party 2,
attesting to the execution of this settlement, affirming the
contents hereof and the affidavits appended in support hereof,
and providing his consent for any such petition to be allowed;
and
(iii) providing unreserved consent on the basis of this Settlem ent
for the compounding of offences, should an application for
compounding be preferred by Party 2.

9. In the event that the petition for quashing is disallowed by the Hon'ble
A
High Court of Karnataka, Party 1 agrees to provide such additional co­
operation as may be necessary for closure of the Complaint, the FIR and
all proceedings emanating therefrom , and he further agrees to ensure
such additional co-operation by the Immediate Family.

10. Party 1 represents that beside the Complaint, neither he nor any
other member of the Im m ediate Family have initiated any legal
proceeding against Party 2, and agree not to do so in the future.

11. It is agreed that the term s of this Settlem ent and Its execution shall
be kept confidential, and shall not be disclosed to any third party. It is
further agreed that in the event it comes to Party 2's attention that the
term s of this Settlem ent and/or its executior> have been made known to

/ A > . 0
 any third party due to any act or omission of Party 1, the members of
the Immediate Family, or any party acting on behalf or on instruction of
such persons, Party 2 shall be entitled to refund of the Settlem ent
Amount in its entirety.

12. In the event of the breach of any of the term s of this Settlement by
Party 1 or any members of the Immediate Fam ily, Party 2 shall have the
right to initiate appropriate legal proceeding(s) seeking the relief of
damages and/or remedies available in law or equity, including, but not
limited to obtaining injunctive relief.

13. Any tax liabilities incurred on account of payment and receipt of the
Settlement Amount shall be borne entirely and exclusively by the party
that has received the Settlement Amount or any portion thereof, without
any reference or recourse to Party No. 2. In no event shall Party 2 bear
any tax-related liability in connection with payment of the Settlem ent
Amount.

14. Party 1 states that he has executed this Settlem ent voluntarily, of his
own volition, without any coercion, and agrees to abide by its term s.
Party 1 further represents that the term s of this settlement have been
read out to him in English as well as Hindi, and that he (as well as the
members of the Immediate Family) have completely understood its
terms and the implications thereof. The members of the Im m ediate
Fam ily, as consenting witnesses to this Settlem ent, and having provided
affidavits in support hereof, also agree that such affidavits have been
provided voluntarily, without any coercion, and they agree that having
executed such affidavits, the terms of this Settlem ent are binding on
them.
 P a rty 1

(Mr. Afroz Khan) (Mr. Alok Ohrie)

C o n s e n t in g W it n e s s e s :

l . S K a K e g O T jfMrs. Shaheen Taj)

f I

7gjM rs . Shaheen Taj as legal guardian of Mast Shahid Khan)

3. ^ M ro m fMs. Farzana Khanum)

4. ____________ ( (Mr. Akram Khan)

/v K R a M
 IN THE HON'BLE HIGH COURT OF KARNATAKA,
AT BANGALORE

CRL. P. NO. J2023

IN THE MATTER OF:

Alok Ohrie ...PETITIO N ER

AND
/ >
State of Karnataka and Anr. .RESPONDENTS

IN D EX

Sr. Particulars Pg.

No. No.
1. Interlocutory Application under Section 482 seeking Stay of
Further Proceedings

2. Verifying Affidavit
SC)

P lace: Bangalore

Date: 31.01.2023 Counsel for the Petitioner

 ©
_IN THE HON'BLE HIGH COURT OF KARNATAKA,
AT BANGALORE

CRL. P. N O .______ /2 0 2 3
I.A . N O ._____/2 0 2 3

IN THE MATTER OF:

Alok Ohrie ...PETITIONER/APPLICANT

AND

State of Karnataka and Anr. ...RESPONDENTS

IN TERLO CU TO RY A PPLICA TIO N UNDER SECTIO N 482 SEEK IN G

STAY OF FU RTH ER PRO CEED IN G S

The Counsel for the Petitioner respectfully subm its as follows:

1. The accompanying petition has been filed seeking quashing of Complaint

dated 01.01.2023 filed by Respondent No. 2, the FIR bearing Cr. No.

0001/2023 registered by Respondent No. 1, initially under Sections 2 7 9,

337 IPC and Sections 1 3 4(a,b ), 187 of the Motor Vehicles Act, 1988, to

which Section 304A, IPC was subsequently added, as well as all

consequential proceedings emanating therefrom ('the Im pugned

Proceedings').

2. It is submitted that the averm ents made and grounds raised in the

accompanying petition be read as part and parcel of the present

application.
3. It is submitted that since quashing of the Impugned Proceedings has

been sought on account of an amicable settlement arrived at between

the Petitioner and the Respondent No. 2, no useful purpose would be

served by permitting the said proceedings to continue during the

pendency of the accompanying petition.

PRAYER

W HEREFORE, in light of the foregoing it is respectfully prayed that this

Hon'ble Court be pleased to:

(a) Stay all further proceedings in FIR bearing Cr. No. 0001/2023

registered by the Respondent No. 1 on 01.01.2023 for offences

punishable under Sections 279, 337 IPC and Sections 134 (a ,b ),

187 of the Motor Vehicles Act, 1988 (A nnexure-A V to which

Section 304A, IPC was added on 17.01.2023 vide A n n e xu re -C .

till the pendency of the accompanying petition; and

(b) Pass any other order/direction(s) deemed necessary In the

interests of justice and equity.

P lace: Bangalore

Date: 31.01.2023 Counsel for the Petitio n er/A pplicant

 IN THE HON'BLE HIGH COURT OF KARNATAKA,
AT BANGALORE

CRL. P. N O .______ /2 02 3
I.A . N O ._____/2 0 2 3

IN THE MATTER OF:

Alok Ohhe ...PETITIONER/APPLICANT

AND

State of Karnataka and Anr. ...RESPONDENTS

A FFID A V IT

I, Alok Ohrie, aged 56 years, s/o. Mr. S .S . Ohrie, resident of # 12 1 , 3rd

Floor, 3rd Main, Defence Colony, Indiranagar, Bangalore-560038, do

hereby declare and affirm that:

1. I am the Petitioner in the above petition. I am fully aware of the facts

and circumstance of the case and competent to sw ear to this affidavit.

2. I state that the averments contained in Paragraphs 1 to ___ in the

accompanying application are true and correct to the best of my

knowledge, information and belief, including legal advice provided to

me. ^

PLACE: Bangalore

DATE: 31.01.2023 DEPONENT

ID E N T IF IE D BEFO RE ME:
 IN THE HON'BLE HIGH COURT OF KARNATAKA,
AT BANGALORE

CRL. P. NO. J2023

IN THE MATTER OF:

Alok Ohrie ...PETITIO N ER

AND

State of Karnataka and Anr. ...RESPONDENTS

IN D EX

Sr. P articulars Pg.

No. No.
1. Interlocutory Application under Section 482 seeking
dispensation of production of translated and typed copies of
Annexures A, B and C, along with Affidavit.

2. Verifying Affidavit

Place: Bangalore

Date: 31.01.2023 Counsel for the Petitioner

 IN THE HON'BLE HIGH COURT OF KARNATAKA,
AT BANGALORE

CRL. P. N O .______ /2 0 2 3
I.A . N O ._____/2 0 2 3

IN THE MATTER OF:

Alok Ohrie ...PETITIONER/APPLICANT

AND

State of Karnataka and Anr. ...RESPONDENTS

IN TERLO CU TO RY A PPLICA TIO N UNDER SECTIO N 482 SEEK IN G

D ISPEN SA TIO N FROM PRODUCTION OF TYPED AND TRAN SLATED

C O P IES OF ANNEXURES A, B, AND C

The Counsel for the Petitioner respectfully subm its as follows:

1. The accompanying petition has been filed seeking quashing of Complaint

dated 01.01.2023 filed by Respondent No. 2, the FIR bearing Cr. No.

0001/2023 registered by Respondent No. 1, initially under Sections 279,

337 IPC and Sections 13 4(a,b ), 187 of the Motor Vehicles Act, 1988, to

which Section 304A, IPC was subsequently added, as well as all

consequential proceedings emanating therefrom ('the Im pugned

Proceedings').

2. The present application has been filed seeking exemption from

production of typed and translated copies of ANNEXURES A, B, and C.

ANN EXURE-A is the certified copy of FIR bearing Cr. No. 0001/2023
 dated 01.01.2023 registered by Respondent N o .l. ANNEXURE-B the

Complaint dated 01.01.2023 filed by Respondent No. 2. ANNEXURE-C

ist he Application for insertion of Section 304A, IPC into FIR bearing Cr.

No. 0001/2023 along with order dated 17.01.2023 and the

accompanying inquest report.

3. It is submitted that since the accompanying petition has been preferred

on account of the amicable settlement arrived at between the Petitioner

and Respondent No. 2, typed and translated copies of the

aforementioned annexures may not be necessary for the adjudication of

this case.

4. In any event, it is submitted that the certified copies of the

aforementioned annexures are legible. The certified copies are therefore

sufficient for the purposes of effective consideration of the reliefs prayed

for in the accompanying petition and the grounds raised in support

thereof.

PRA YER

W HEREFORE, in light of the foregoing, it is respectfully prayed that this

Hon'ble Court be pleased do:

(a) Dispense with production of typed and translated copies of

ANNEXURES-A, AN N EXURE-B, and ANN EXURE-C annexed to

the accompanying petition;

 (b) Pass and other order/direction(s) deemed necessary in the

interests of justice and equity.

Place: Bangalore

Date: 31.01.2023 Counsel for the Petitio n er/A pplicant

 IN THE HON'BLE HIGH COURT OF KARNATAKA,
AT BANGALORE

CRL. P. N O .______ /2 0 2 3
I.A . N O ._____/2 02 3

IN THE MATTER OF:

Alok Ohrie ...PETITIONER/APPLICANT

AND

State of Karnataka and Anr. ...RESPONDENTS

A FFID A V IT

I, Alok Ohrie, aged 56 years, s/o. Mr. S .S . Ohrie, resident of # 1 2 1 , 3rd

Floor, 3rd l^ain. Defence Colony, Indiranagar, Bangalore-560038, do

hereby declare and affirm that:

3. I am the Petitioner in the above petition. I am fully aware of the facts

and circumstance of the case and competent to sw ear to this affidavit.

4. I state that the averm ents contained in Paragraphs 1 to ___ in the

accompanying application are true and correct to the best of my

knowledge, information and belief, including legal advice provided to

me.

PLA CE: Bangalore

DATE: 31.01.2023

ID E N T IF IE D BEFO RE ME: