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IN THE HON'BLE HIGH COURT OF DELHI AT NEW DELHI

(EXTRAORDINARY CRIMINAL JURISDICTION)

(UNDER SECTION 482 Or CRIMINAL PROCEDURE CODE)


CRIMINAL M.C. NO. OF 2023

IN THE MATTER OF:


Bir Singh & Ors ... Petitioners
VERSUS
The State & Anr ... Respondent
INDEX

S.No Particulars Page No.


1. Notice of Motion
I
2. Urgent Application z.
3. Court Fee 3
4. Synopsis and List of Dates
4-7
5. Memo of Parties
8- ~
6. Petition under section 482 of
Cr.P.C. seeking quashing of F.I.R
ro - Ir?
dated 06.10.2021 bearing number
842/2021 under sections 498-
N406/34 IPC at P.S. Khya la, Delhi
and its consequential proceedings
along with affidavits
7. CRL.M.A NO. 202~
I~ -- JJ.
Application for exemption from filing
official translated copies of
ANNEXURE P-1 with affidavit.
8. CRL.M.A NO. 2022
Application under section 482 of
2-1 - l-1
Cr.P.C. for stay of the proceedings
in F.I.R. No. 751/2018 with affidavit.
9. ANNEXURE P-1: A copy of the
30 -½3
F.I. R dated 06.10.2021 bearing
number 842/2021 under sections
498-N406/34 IPC at P.S. Khyala,
Delhi
12. Vakalatnama \.j \.J
13. Proof of service

~
ed.~ CY,
Petitioner .2
a. trcr--
Petitioner No. 3
Dated ~sr, ft3 Through
Place Pf-t.-rfJ;
~ rma
Advocates & Associates
Chamber No. 222, Civil Wing,
Tis Hazari Courts, Delhi-1 10054
Mob: 9560299886
Email: piyushsharmaa86@gmail.com
r
IN THE HON'BLE HIGH COURT OF DELHI AT NEW DELHI
(EXTRAORDINARY C RIMINA L JURISDICTI ON)
(UNDER SECTION 482 OF CRIMINAL PROCEDURE CODE)
CRIMINAL M.C. NO. O F 2023
IN THE MATTER OF:
Bir Singh & Ors ... Petitioners
VERSUS
The State & Anr . . . Respondents
NOTICE OF MOTION
Sir,

Please find enclosed the accompanying petition along with its

annexures filed before the Hon'ble High Court on behalf of Petitioner$

herein. T he matter is likely to be listed before the Hon'ble High Court on

or on any other day as per the convenience of the Hon'ble Court

Peti
af<r< ~110-1
P,etitioner t)k) . 2
~ \l o-rfr
Petitioner No. 3
Dated t.4, /l!3 T hrough
Place t>/,f, H, ~
Piyush Sharma
Advocates & Associates
Chamber No . 222, Civil W ing,
Tis Hazari Courts, Delhi-110054
Mob: 9560299886
Email: piyushsharmaa86@gmail.com
IN THE HON'BLE HIGH COURT OF DELHI AT NEW DELHI
(EXTRAORDINARY CRIMINAL JURISDICT ION)
(UNDER SECTION 482 01= CRIMINAL PROCEDURE CODE)
CRIMINAL M.C. NO. OF 2023

IN THE MATIER OF:


Bir Singh & Ors ... Petitioners
VERSUS
The State & Anr ... Respondents
URGENT APPLICATION
Sir,
Kindly treat the accompanying application as an urgent one in
accordance with the High Court Rules. The ground of urgency is the fact
that the above mentioned case would unnecessarily lead to hardships to
the parties and no fruitful result will be achieved. As the matter is already
settled and the Petitioners are staying together since last 10 months,
there is no requirement to delay the quashing of FIR. Further the case
number Cr. Case 12066/2022 has been registered on the said F.I.R. and
is pending disposal before the Court of Ld. MM, West, Tis Hazari Court,
Delhi. So kindly list this matter before the Hon 'ble High Court urgently.

Quashing of the concerned FIR is prayed for.

Pet~
1 evil cvj
~ .r Q,

P,e~ ij J;!_/1,. 2
Petitioner No. 3
Dated ~ , }28. Through
Place D~·
~ ma
Advocates & Associates
Chamber No. 222, Civil Wing ,
Tis Hazari Courts, Delhi-110054
Mob: 9560299886
Email: piyushsharmaa86@gmail.com
IN THE HON'BLE HIGH COURT OF DELHI AT NEW DELHI
(EXTRAORDINARY CRIMINAL JURISDICTION)

(UNDER SECTION 482 OF CRIMINAL PROCEDURE CODE)


CRIMINA L M.C . NO. OF 2023

IN THE MATTER OF:


Bir Singh & Ors ... Petitioners
VERSUS
The State & Anr ... Respondents
CONSOLIDATED COURT FEE

Pe ·
dt~<Z CJ/ I Ni
Eetitio~tJ- 2
Q.11 a--n
PetitionerNo. 3
Dated ~ / , / ~ Through
Place f)-e ,lw.• ::::----
P1yush Sharma
Advocates & Associates
Chamber No. 222, Civil Wing,
Tis Hazari Courts, Delhi-110054
Mob: 9560299886
Email: piyushsharmaa86@gmail.com
SYNOPSIS AND LIST OF DATES

The Petitioners have approached this Hon'ble Court whereby the

Petitioners most respectfully prays that F.I. R dated 06.10.2021 bearing

number 842/2021 under sections 498-N406/34 IPC lodged at P.S.

Khyala may kindly be quashed as the Petitioners have already settled

their matrimonial dispute with the Respondent No. 2. It is pertinent to

mention here that both the Respondent No. 2 and the Petitioners are

staying together at the matrimonial home since last 10 months.

Briefly, the facts of the case are that the Petitioner no. 1 is the husband of

the Respondent No. 2 and the_marriage between them was solemnized

on 08.04.2014 at Delhi according to Hindu rites and ceremonies. There is

a daughter who is about 7 years of age out of the wedlock between the

Petitioner No. 1 and Respondent No. 2.

Because of some matrimonial discords and misunderstandings

between the Petitioners and Respondent No. 2, the Respondent No. 2

lodged an F.I.R dated 06.10.2021 bearing number 842/2021 under

sections 498-N406/34 IPC at P.S. Khyala, Delhi against the Petitioners.

The members of family and friends intervened in the matter and

both the parties were made to understand the sacramental status of the

Hindu marriages and settled their disputes. The Petitioners and the

Respondent No. 2 arrived at an oral settlement in December 2022 and

agreed to stay together.


The Respondent No. 2 is since then staying with the Petitioners at

her matrimonial home and leading a happy married life. It is pertinent to

mention here that the Respondent No. 2 is about 7-8 months pregnant at

the time of filing of the present Petition for quashing of the F.I.R.

The Petitioners seek the -indulgence of this Hon'ble Court to invoke

the inherent jurisdiction under Section 482 of Cr.P.C. for quashing the

F.I.R dated 06.10.2021 bearing number 842/2021 under sections 498-

N406/34 IPC at P.S. Khyala, Delhi and its proceedings in furtherance

thereto.

Hence the Present Petition.


LIST OF DATES AND EVENTS

DATES PARTICULARS

08.04.2014 The marriage of Petitioner No. 1

and Respondent no. 2 was

solemnized at Delhi.

15.06.2016 A daughter namely Anushka was

born out of the wedlock.

06.10.2021 F.I.R lodged by the Respondent

No. 2 against the Petitioners,

bearing number 842/2021 under

sections 498-A/406/34 IPC at

P.S. Khyala, Delhi

December, 2022 The members of family and

friends intervened in the matter

and the Petitioners and the

Respondent No. 2 orally agreed

to settle all their disputes and the

Respondent No. 2 is since then

staying at her matrimonial home

with the Petitioners and leading a

happy married life.


7
Hence this present Petition under

Section 482 Cr.P.C.

p~

te~i~~ 2
P& it~}n: No. 3
Dated t-s/"I /•~ Through
Place txJ,tv.
~ ma
Advocates & Associates
Chamber No. 222, Civil Wing,
Tis Hazari Courts, Delhi-110054
Mob: 9560299886
Email: piyushsharmaa86@gmail.com
IN THE HON'BLE HIGH COURT OF DELHI AT NEW DELHI
(EXTRAORDINARY CRIMINAL JURISDICTION)
(UNDER SECTION 482 OF CRIMINAL PROCEDURE CODE)
CRIMINAL M.C. NO. OF 2023

IN THE MATTER OF:


Bir Singh & Ors ... Petitioners
VERSUS
The State & Anr . . . Respondents
MEMO OF PARTIES
1. Bir Singh
Slo Shri Bansi Lal
Ri o P-19, Chanchal Park,
Gurdayal Vihar Part-2,
Bakkar wala, West Delhi-110041

2. Bansi Lal
Slo Shri~o.A X R/41-l,
Rio Plot No. P- 19, Khasra No. 64112,
Gurdayal Vihar, Chanchal Park II,
Bakkar Wala, West Delhi:-110041

3. Shanti Devi
Wlo Shri Bansi Lal
Rio P-19, Chanchal Park,
Gurdayal Vihar Part-2,
Bakkar wala, West Delhi-110041 ... Petitioners

VERSUS

1. State
Through Ministry of Home Affairs,
North Block, Central Secretariat,
New Delhi-110001

2. Chander Kanta
Wlo Bir Singh,
Rio Plot No. P-19, Khasra No. 64112,
Gurdayal Vihar, Chanchal Park II,
Bakkar Wala, West Delhi-110041 ... Respondents
Pet1 Ioner No. 1
4t c-p '4.1i cv~l

Pei io~er o. 3
Dated~11/~ Through .
Place f ? ~
~ Sharma
Advocates & Associates
Chamber No. 222, Civil Wing,
Tis Hazari Courts, Delhi-110054
Mob: 9560299886
Email: pivushsharmaa86@gmail.com
IN THE HON'BLE HIGH COURT OF DELHI AT NEW DELHI
(EXTRAORDINARY CRIMINAL JURISDICTION)
(UNDER SECTION 482 OF CRIMINAL PROCEDURE CODE)
CRIMINAL M.C. NO. OF 2023
IN THE MATTER OF:
1. Bir Singh
S/o Shri Bansi Lal
Rio P-19, Chanchal Park,
Gurdayal Vihar Part-2, .
Bakkar wala, West Delhi-110041

2. Bansi Lal
S/o Shri S'o~ ;y Rfrf"I
R/o Plot No. P-19, Khasra No. 64/12,
Gurdayal Vihar, Chanchal Park 11,
Bakkar Wala, West Delhi-110041

3. Shanti Devi
W/o Shri Bansi Lal
Rio P-19, Chanchal Park,
Gurdayal Vihar Part-2,
Bakkar wala, West Delhi-110041 ... Petitioners

VERSUS

1. State
Through Ministry of Home Affairs,
North Block, Central Secretariat,
New Delhi-110001
lI

2. Chander Kanta
W/o Bir Singh,
R/o Plot No. P-19, Khasra No. 64/12,
Gurdayal Vihar, Chanchal Park 11,
Bakkar Wala, West Delhi-110041 ... Respondents

PETITION UNDER SECTION 482 OF THE CR.P.C SEEKING


QUASHING OF F.I.R DATED 06.10.2021 BEARING NUMBER
842/2021 UNDER SECTIONS 498-A/406/34 IPC AT P.S.
KHYALA, DELHI AND ITS CONSEQUENTIAL PROCEEDINGS

MOST RESPECTFULLv ·sHOWETH:

1. The Petitioners have approached this Hon'ble Court whereby the

Petitioners most respectfully prays that F. I. R dated 06.10.2021

bearing number 842/2021 under sections 498-A/406/34 IPC lodged

at P.S. Khyala may kindly be quashed as both the Petitioners and

the Respondent No. 2 have already settled their matrimonial

dispute. It is pertinent to mention here that Respondent No. 2 and

the Petitioners are staying together at the matrimonial home since

last 10 months.

2. The Petitioner no. 1 is the husband of the Respondent No. 2. And

both are law abiding citizens of India.

3. That the marriage between the Petitioner No. 1 and Respondent

No. 2 was solemnized on 08.04.2014 at Delhi .according to Hindu

rites and ceremonies.


4. That out of the wedlock, a daughter was born on 15.06.2016. The

daughter is now about 7 years of age.

5. That because of some matrimonial discords and

misunderstandings between the Petitioners and Respondent No. 2,

the Respondent Nb. 2 lodged an F.I.R dated 06.10.2021 bearing

number 842/2021 under sections 498-A/406/34 IPC at P.S. Khyala,

Delhi against the Petitioners.

6. That the members of family and friends intervened in the matter

and both the parties were made to understand the sacramental

status of the Hindu marriages and settled their disputes.

7. That the Petitioners and the Respondent No. 2 arrived at an oral

settlement in December 2022 and agreed to stay together.

8. That the Respondent No. 2 is, since then, staying with the

Petitioners at her matrimonial home and leading a happy married

life.

9. That it is pertinent to mention here that the Respondent No. 2 is

about 7-8 months pregnant at the time of filing of the present

Petition for quashing of the F.I.R.

10. That the Petitioners seek the indulgence of this Hon'ble

Court to invoke the inherent jurisdiction under Section 482 of

Cr.P.C. for quashing the F.I.R dated 06.10.2021 bearing number

842/2021 under sections 498-A/406/34 IPC at P.S. Khyala, Delhi


and its proceedings in furtherance thereto on the following grounds

viz:

GROUNDS

A Because the Petitioners and Respondent No. 2 have orally

settled and compromised the matter out of their own free will,

volition and consent and without any undue pressure, coercion,

influence, misrepresentation or mistake.

B. Because the Petitioners and Respondent No. 2 have already

settled their disputes out of court as a result of intervention by

members of family and friends.

C. Because the Respondent No. 2 is, since December 2022,

staying with Petitioners at her matrimonial home.

D. Because the Respondent No. 2 is about 7-8 months pregnant

and is leading a happy married life with her husband and his

family.

E. Because this Hon'ble Court has the necessary power under

section 482 Cr.P.C. to quash the F.I.R on the basis of oral

mutual settlement arrived between the parties as it is now a

settled principle that in family disputes, where the matter has

been amicably settled, the criminal prosecution should be

deprecated and discouraged.


1'-1

F. Because no fruitful pu.rpose is likely to be served in continuing

the proceedings· of the aforesaid case and the continuance of

criminal proceedings instituted against the Petitioners would

result in abuse of process of the court.

G. Because the Petitioners have no other alternative and efficacious

remedy but to approach this Hon'ble Court under its extra

ordinary jurisdiction.

H. The Petitioners crave leave of this Hon'ble Court to raise such

other or further ground that may be available to them at the time

of hearing of the present petition.

I. That this Hon'ble court has jurisdiction to entertain the petition

and grant relief sought for as the F.I.R. is registered in Delhi.

J. That there is no petition, except the present one, of such nature

pending before any other court including before the Hon'ble

Supreme Court of India.

PRAYER

In view of the submissions made above it is most respectfully

prayed that in the facts and circumstances of the case, this

Hon'ble Court may graciously be pleased to:

a. Quash the F.I.R dated 06.10.2021 bearing number 842/2021

under sections 498-A/406/34 IPC at P.S. Khyala, Delhi and its

consequential proceedings; or
Pass such other order/s or direction/s which the Hon'ble court may

deem fit and proper in the above mentioned facts and

circumstances of the case.

AND FOR THIS ACT OF KINDNESS THE PETITIONER AS IN

DUTY BOUND SHALL EVER PRAY

Petit1 er No. 1
c1'c-~~l (YI I~
e ·· 2

·Dated ,u/1/1.f3, Through


p~JJ:- 0. 3

Place ~
~ rma
Advocates & Associates
Chamber No. 222, Civil Wing,
Tis Hazari Courts, Delhi-110054
Mob: 9560299886
Email: piyushsharmaa86@gmail.com
IN THE HON'BLE HIGH COURT OF DELHI AT NEW DELHI
(EXTRAORDINARY CRIMINAL JURISDICTION)
(UNDER SECT ION 482 OF CRIMINAL PROCEDURE CODE)
CRIMINAL M:C. NO. OF 2023
IN THE MATTER OF:
Bir Singh & Anr ... Petitioners
VERSUS
The State . . . Respondent
AFFIDAVIT

I, Bir Singh, S/o Shri Bansi Lal, aged about 32 years, Rio P-19, Chanchal

Park, Gurdayal Vihar, Part-2, Bakkar Wala, West Delhi-1 10041, do

.· hereby solemnly affirm and declare as under:

1. That I am the Petitioner in the accompanying Petition and I have

made myself aware of the facts and circumstances of the case.

Hence I am competent to swear this affidavit.

C~mmi~'o at the contents of the accompanying petition under section 482


.<:.:,~-J~~~f.f.~
~ \: "o. i~12olu?. ~.. .
~~\'lcoutt -;
.
.C seeking quashing of FIR has been drafted by my counsel as
~ \)•~~· Q~~jl)1/'2.0?.'j $ .
ic !z,P..\l ~et\otAI011'2.0i'\..,,
to t,'?,W
r my instructions and the contents of the same have been read
'S Hazarl cout\.
over and explained to me in vernacular and are admitted by me to

~ be true and correct.


\ \dent\~ the-deponent ~ho ~
~s signed \n ma~ Qresence DEPONENT
VERIFICATION : I

. 'i . ~ SEP 2023, 2023 and I do ·solemnly affirm


.
Verified at , on _t111s 'Clay of
that the contents of the above said paras 1 to 2 of the affidavit are
. ~re. ~r)q~ff~~ tp best of my knowledge and belief and nothing
vERTIFIED 1j-iAT ti '-' ~
Shri/Smt./ Km.>'-?_·~~ .!. :J ~J:~:~:~::~oncealed therefrom.
S/0 W/0\.f:X" .... ·· · ~ ~ ' Li J
~Ji~~ , ~~~{~~~~~·f~-~~" ~ DEPONENT
1 5 ,>.es s&j 23 ..:,I. No .. ~ ....
Delhi onc"'i'e~ts.~f-th·~·.iidav1! which h ve
that the donnd ie xplalned t him are true nd
been rea a
correct to his knowtwdg
uath ~ ~i..--11-fls_s_10_11_e,-0 en,•(
1 5 SEP 2023
IN THE HON'BLE HIGH COURT OF DELHI AT NEW DELHI
(EXTRAORDINARY CRIMINAL JURISDICTION)
(U NDER SECTION 482 OF CRIMINAL PROCEDURE CODE)
CRIMINAL M.C. NO. OF 2023
IN THE MATTER OF:
Bir Singh & Anr ... Petitioners
VERSUS
The State ... Respondent
AFFIDAVIT

I, Bansi Lal, S/o Sh. Soay Ram, aged about 60 years, Rio Plot No. P-19,

Gurdayal Vihar, Chanchal Park II, Bakkar Wala, West Delhi-110041 , do

hereby solemnly affirm and declare as under:

1. That I am the Petitioner in the accompanying Petition and I have

made myself aware of the facts and circumstances of the case.

Hence I am competent to swear this affidavit.

~--- 2. That the contents of the accompanying petition under section 482
X\ commlss;0 ·
~ £>l?..\)'2.~\\ '0.,r. .C seeking quashing of FIR has been drafted by my counsel as
(() ~~~·('{·~ IX e,oul\ ..
.- ~
.c
l\)i~
~e\i\ \W~ ~ my instructions and the contents of the same have been read
i'i•· "l:>1\)1 1 c. ~
~ ~\)\). \06·' 1 1i\)'L-'. ,"'
.. ..ve\ 0 ,M\) ~'?J~-.: ver and explained to me in vernacular and are admitted by me to
'1s Hazarl coul\, •
be true and correct.

·1identify t eponent -NhO


~s signed in may presence DEPONENT
· VERIFICATION:

Verified at
I
1OcS~~is'9£~ of , 2023 and I do solemnly affirm
that the contents of the above said paras 1 to 2 of the affidavit are

ih~i~l~n~~..~~Im~~-~-~.~-~ to best ·of my knowledge and belief and nothing


Jj~.~ ~ P,(~~ ~~ ~ ~ ' i . f fncealed therefrom. ~ cr;z~ cvf/01{
~:ri1sEP202'3~~d·lt;1~·~t~V"
Oelhl on...... ..~ ~~-
.. ............... . No ..
k . DEPONENT
that the Contents of the atrldc1v1 which have
been read and explained to him are true and
correct to his knowlwctge.

r SE p 202~ u,ath Comml s ~ oq1n;


IN THE HON'BLE HIGH COURT OF DELHI AT NEW DELHI
(EXTRAORDINARY CRIMINAL JURISDICTION)
(UNDER SECTION 482 OF CRIMINAL PROCEDURE CODE)
CRIMINAL M.C. NO. OF 2023
IN THE MATTER OF:
Bir Singh & Anr . .. Petitioners
VERSUS
The State . . . Respondent
AFFIDAVIT

I, Shanti, W/o Sh. Bansi Lal, aged about 56 years, Rio Plot No. P-19,

Gurdayal Vihar, Chanchal Park 11, Bakkar Wala, West Delhi-110041 , do

hereby solemnly affirm and declare as under:

1. That I am the Petitioner in the accompanying Petition and I have

made myself aware of the facts and circumstances of the case.

Hence I am competent to swear this affidavit.

2. That the contents of the_accompanying petition under section 482

ll..---- Cr.P.C seeking quashing of FIR has been drafted by my counsel as


c mr.iissio
~<:,\ i~\'2.~i~?. 1fe my instructions and the contents of the same have been read
rr,"t> $ ~- ~~~i \~~ o~\\ ~
r
~
~~'o~-~e\"\~11i\)'2.~
tA-
~~\.-\.- . ,··~" \J .._..
~ rand explained to me in vernacular and are admitted by me to
~ ~\)\)· ·oo·\l:i,.,1i~?..'6 ,~
\'e'' AIO' ,i'<
~ ~ \O '\ •\ ()'<·' be true and correct. · (S" \ \ ~
s Ha rl cou, ' ~

~ .nn..e~~no DEPONENT
·d n\\\~ \: e \){esen~ ERIFICATION: '
\\ e •gned \n «'a~ . \ E SEP 2023
. ~s S\ Verified at , on this day 9f , 2023 and I do solemnly affirm
that the contents of the above said paras 1 to 2 of the affidavit are

/5
.
-
1JERTIF!
:hri/S,m,~~Jvd
1
true and corrects to best of my knowledge and belief ~nd nothing

lo)t-//Q A.lo

sil;.~5~;; ; ~~:-~ ,
~1
• · .,. .. ..; ..
~
therefrom.
EV I

1
'/
~
cJ.. ·
DEPONENT
Deihl on.. r1r rned b·e· t..LJ,ui.~ .~ L,-1 'Y u.1""
th t .. .. · o f e .qt~ -------r --~
0 a the Contencs ·~·,; ........ ~ elf. No.,f l .. t
1 5 Sr:p6;~:at~ a~~d exp1ain~d~H ~t,t V; hich h~~~
8

LULJ s know/wdg m are true and

Oath Co-mm/ssloner DP.'t)•


---...
IN THE HON'BLE HIGH COURT OF DELHI AT NEW DELHI
(EXTRAORDINARY CRIMINAL JURISDICTION)
(UNDER SECTION 482 OF CRIMINAL PROCEDURE CODE)
CRIMINAL M.C. NO. OF 202~
C f:_ l, />? 14 }..lo o f!-- 2--l> '2.-1
IN THE MATTER OF:
Bir Singh & Ors ... Petitioners
VERSUS
The State & Anr ... Respondent

APPLICATION FOR EXEMPTION FROM FILING TRUE TYPED


COPIES AND OFFICIAL TRANSLATION.

Most Respectfully Showeth:


1. That the above named Petitioners have filed the accompanying

petition for quashing of the aforesaid F.I.R dated 06.10.2021

bearing number 842/2021 under sections 498-A/406/34 IPC at P.S.

Khyala, Delhi and its ·proceedings in furtherance thereto, the

contents whereof are not being repeated herein for the sake of

brevity and may be read as part and parcel of the present

application. The petition is pending disposal before this Hon'ble

Court.

2. That the petitioners herein submit, for the kind consideration of this

Hon'ble Court, that the disputes between the parties have been

amicably settled and the Respondent No. 2 is staying with

Petitioners and leading a happy married life.


3. That the documents in form of ANNEXURE P-1 is the copy of the

F.I.R dated 06.10.2021 bearing number 842/2021 under sections

498-N406/34 IPC at P.S. Khyala, Delhi and the same has been

translated and typed copy. However, in getting the official

translation of the said document, the same will take undue time

thereby causing undue delay.

4. That the present application has been filed bona fide and in the

interest of justice.

PRAYER
It is therefore most respectfully prayed that in view of the facts and

Circumstances of the case and in the interest .of justice, this

Hon'ble Court may be pleased to: -

i. Allow the present application for exemption from filing official

translation of ANNEXURE P-1; and

ii. Pass such other and further orders as this Hon'ble Court may

deem fit and proper, and in the interest of justice.~

Petitioner No. 1
at. c;-. Q..1J t::!l Icvl
Petitioner ~ 2
~ ~\ T
P~ ron~ ~ - 3
Dated ~~/~~ Through
Place p~ f,py~
r ~ Sharma
Advocates & Associates
Chamber No. 222, Civil Wing,
Tis Hazari Courts, Delhi-110054
Mob: 9560299886
Email: piyushsharmaa86@gmail.com
IN THE HON'BLE HIGH COURT OF DELHI AT NEW DELHI
(EXTRAORDINARY CRIMINAL JURISDl9TION)
(UNDER SECTION 482 OF CRIMINAL PROCEDURE CODE)
CRIMINAL M.C. NO. OF 2023
IN THE MATTER OF:
Bir Singh & Anr . . . Petitioners
VERSUS
The State . . . Respondent
AFFIDAVIT

I, Bir Singh, S/o Shri Bansi Lal, aged about 32 years, R/o P-19, Chanchal

Park, Gurdayal Vihar, Part-2, Bakkar Wala, West Delhi-110041 , do

hereby solemnly affirm and declare as under:

~ - - . 1 . . _ .. That I am the Petitioner in the accompanying Petition and I have


oa ~ Com miss;
~()\ ~o JoJ'l.02Jp. ~ myself aware of the facts and circumstances of the case.
J~✓~f.'f-~ ~~n coutt *
<:>~~ ·
~f:>.\W ·~r 0-~~)o-ifio?.J H e I am competent to swear this affidavit.
* . \>eno~ 4101 /?.02~ _,,cs ..
"'s Haz~ori c o u ~ hat the contents of the accompanying application for exemption
has been drafted by my counsel as per my instructions and the

. ~ ,.....--- contents of the same have been read over and explained to me in
l identify th~ deponent NhO
.\\aS signed in may p1eseni:8vernacular and are admitted by me to be true and corre~

DEPONENT
VERIFICATION:

Verified at , ~r1 ttw; ~~f oJULJ


, 2023 and I do solemnly affirm
\
that the contents of the a~ove said paras 1 to 2 of the affidavit are

c ERTI Fl ED true and corrects to best of my knowledge and belief and nothing
Shrl/ Smt./Km ~~~HJ QEPONE N,
~j° \Wo ~~o .. ~h·.:~ ' 1_r:~ en.cpncealed therefrom. _ \ ~___,,...
I o ..,~: · Uf I iQ.~ ~ -······ . .. ~
1 sh,re~Z023 rrtM~:::ei:.t i ~ ~ ~ DEPONENT
Deihl on... .. . - rme d befo r e ~ ·
that the Conte~·t·~--•-~.... ·· ··:· ->l. No .... ..
8"' t
been read and exp~!,~~/ff,, ovit w hich ha· ;; ·
correct to hi s knowlwd to ' m are true and
ge.

1 r SEp 2023
IN THE HON'BLE HIGH COURT OF DELHI AT NEW DELHI
(EXTRAORDINARY CRIMINAL JURISDICTION)
(UNDER SECTION 482 OF CRIMINA L PROCEDURE CODE)
CRIMINAL M.C. NO. OF 2023
IN THE MATTER OF:
Bir Singh & Ors ... Petitioners
VERSUS
The State & Anr ... Respondent
AFFIDAVIT

I, Bansi Lal, S/o Sh. Soay Ram, aged about 60 years, Rio Plot No. P-19,

Gurdayal Vihar, Chanchal Park II, Bakkar Wala , West Delhi-110041 , do

hereby solemnly affirm and declare as under:

1. That I am the Petitioner No. 2 in the accompanying Petition and I

\~ ommlss;~i made myself aware of the facts and circumstances of the


~'~ £>1?.~'2.~ ' ·ra>.,.
~ \. ~o-i v. I\U~ \ 1<
~~ --~"~~£.t:,\~~\\ C°'1~ a~ Hence I am competent to swear this affidavit.
ui\,, 1i~"" !-3
9·~~ - _., s1\\1 ~~ ~
(b ''""' .
-c:
i( ~9 \>e~\o~ti-101 l'l:....~i"'t at the contents of the accompanying application for exemption
'1s Ha~rl cou~\.~~ ·
has been drafted by my counsel as per my instructions and the

contents of the same have been read over and explained to me in

. ~ en\ ~\\\Yernacular and are admitted by me to be true and correct. (Q C' ?_:-o<Yf lrtr
\\\e (\e\)O" el\C.I
\ \(\en~\\~ \\\\\{(\a~ \)teS . . DEPONENT
~s S\~1\e VERIFICATION:

Verified Jtf. SEP


, on t~,,013 ·
is day of , 2023 and I do solemnly affirm
'
that the contents of the above said paras 1 to 2 of the affidavit are

true and corrects to best of my knowledge and belief and nothing

GE_RTIFIED
i
. Shn/ Smt./Km.
H~
.
t~l · ~Wl::li'Ji\ncealed
ffT
therefrom .
· S/, /oQ/o . · --~-- _c,:_&.t ..~............. ·
Ri o .-:-ll-1 ~ -u:.,· · ~ Y:n:··~
1
Was se,
e tf,f · 1
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. ··
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· ·· · · ·· · · -•~
--~h.. ~ ~"'
t
. 4
~
~hat the Content5 ·~·; ~
':he-~f;;;_ v~~-:~~t; ha
een read and expla ined to h m are tru e a d
correct to his knowl w dge.

1 5 SEP 2023 Uath ~..


IN THE HON'BLE HIGH COURT OF DELHI AT NEW DELHI
(EXTRAORDINARY CRIMINAL JURISDICTION)
(UNDER SECTION 482 OF CRIM_ INAL PROCEDURE CODE)
CRIMINA L M.C. NO. OF 2023
·1N THE MATTER OF:
Bir Singh & Ors ... Petitioners
VERSUS

The State & Anr . . . Respondent


AFFIDAVIT

I, Shanti, W/o Sh. Bansi Lal, aged about 56 years, Ri o Plot No. P-19,

Gurdayal Vihar, Chanchal Park II, Bakkar Wala, West Delhi-110041 , do

hereby solemnly affirm and declare as under:

1. That I am the Petitioner No. 3 in the accompanying Petition and I

contents of the same have been read over and explained to ~

~ onet\\ t1b~acular and are admitted by me to be true and correct.~ O""() l


. l\\~ \"e de\l tesence
\,Mt\. ed '"ma~\) DEPONENT
~S S\(1\\ VERIFICATION: .

11 5 SEP 2n23
Verified a~ , on this d'ay of , 2023 and _
I do solemnly affirm

that the contents of the above said paras 1 to 2 of the affidavit are

true and corrects to best of my knowledge and belief and not: w

'.n~;%T~f.~~~-~'~
· i! : ~~
~~~B.
,~ !~: aledtherefrom. - ~ \\ I
·, .t1 5 SEP~m,~~
~P~""'l I ' v-~l.. ••.. x·n · a . t .. (
.... , .. .f:if:1Y-A; -\
DEPONENT
1
ldentif ~U. ..P.,t.l..<l.~b-.-l \--.Q..,- ~
has s < n ncd befort:! ~~
Oelhl on.. .. . .. . ... ...... .:>i. No ........ ..
. t hat the ponte1,1_, of the affid vit which ave
f C'f been read and explained to h , are true and
. ~--Pc2(J'l.Jt to his knowlwdge.
IN THE HON'BLE HIGH-COURT OF DELHI AT NEW DELHI
(EXTRAORDINARY CRIMINAL JURISDICTION)
(UNDER SECTION 482 OF CRIMINAL PROCEDURE CODE)
CRIMINAL M.C. NO. OF 2023
C f<.t- /YI fJ Au () p- ~ '28

IN THE MATTER OF:


Bir Singh & Ors . . . Petitioner
VERSUS

The State & Anr ... Respondents

APPLICATION U/S 482 OF THE CODE OF CRIMINAL PROCEDURE,


1973 SEEKING NECESSARY ORDERS AND DIRECTIONS FROM
THIS HON'BLE COURT FOR STAY OF PROCEEDINGS IN F.I.R
DATED 06.10.2021 BEARING NUMBER 842/2021 UNDER SECTIONS
498-A/406/34 IPC AT P.S. KHYALA, DELHI.

Most Respectfully Showeth: · •


1. That the above named petitioners have filed the accompanying

petition for quashing of the aforesaid F.I.R dated 06.10.2021

bearing number 842/2021 under sections 498-Af406/34 IPC at P.S.

Khyala, Delhi, the contents whereof are not being repeated herein

for the sake of brevity and may be read as pa.rt and parcel of the

present application . The petition is pending disposal before this

Hon'ble Court.

2. That the petitioners herein submit, for the kind consideration of this

Hon'ble Court, that the disputes between the parties viz Petitioners

and Respondent No. 2 have been amicably settled and the


Petitioners and Respondent No. 2 are living together since last 10

months and living a happy married life.

3. That in view of the above said circumstances ; it is not only

expedient but also in the interest of justice that further proceeding

may be stayed in F.I.R dated 06.10.2021 bearing number 842/2021

under sections 498-A/406/34 IPC at P.S. Khyala, Delhi as no useful

purpose will be served by the continuation of the same.

4. That case number Cr. Case 12066/2022 has been registered on

the said F.I.R. and is currently pending before the Court of Ld. MM,

West District, Tis Hazari Court, Delhi. The next date before the Ld.

MM is given as 16.11 .2023.

5. That the present application has been filed bona fide and in the

interest of justice.

PRAYER
It is therefore most respectfully prayed that in view of the facts and

Circumstances of the case and in the interest of justice, this

Hon'ble Court may be pleased to: -

i. Pass necessary orders and directions thereby staying the

proceedings pend1ng adjudication in F.I.R dated 06.10.2021

bearing number 842/2021 under sections 498-A/406/34 IPC

at P.S. Khyala, Delhi pending before the Court of Ld. MM,

West District, Tis Hazari Court, Delhi during the pendency of

the present petition;· AND


11. Pass such other and further orders as this Hon'ble Court may

deem fit and proper, and in the interest of justice.

P · ner No. 1
<fl 6"' ~7J cvl lcvl
~
P~ tfJn~ ~ o'. 3
Dated ~ , , ~ Through ·
Place p,e,U.....'
~ Sharma
Advocates & Associates
Chamber No. 222, Civil Wing,
Tis Hazari Courts, Delhi-110054
Mob: 9560299886
Email: piyushsharmaa86@gmail.com
z_'1
IN THE HON'BLE HIGH COURT OF DELHI AT NEW DELHI
(EXTRAORDINARY CRIMINAL JURISDICTION)
(UNDER SECTION 482 OF CRIMINAL PROCEDURE CODE)
CRIMINAL M.C. NO. OF 2023
IN THE MATTER OF:
Bir Singh & Ors ... Petitioners
· vERSUS
The State & Anr . . . Respondent
AFFIDAVIT

I, Bir Singh, S/o Shri Bansi Lal, aged about 32 years, R/o P-19, Chanchal

Park, Gurdayal Vihar, Part-2., Bakkar Wala, West Delhi-110041, do

hereby solemnly affirm and declare as under:

mmis . That I am the Petitioner in the accompanying Petition and I have


t\\ 0 • SJo
~~ i?s,ii ,?d>,..
~~\. ~o.i~ \<..p,.u \\ t\ e myself aware of the facts and circumstances of the case.
::~ ~~~~\:.:~,~,~~~:
-r= ~99 . ~~- ~-'\~ll.)11~?..I:> ..._
""
nee I am competent to· swear this affidavit.
'°: l7.
'?'
\)et\O\t.-1011'2: .,:.,-./'
\0 ~~~· .
ts Hazari co\~0:,. . That the contents of the accompanying application for stay has

been drafted by my counsel as per my instructions and the

.
b (l~e,~\ ~""
" contents of the same have been read over and explained to me in
I
•·~'J\\\~~~~ ~~,~cz,~~ernacular and are admitted by me to be true and correc~ .
.

\ \~t~~ ~~~\\\ \'(\?; .


~~CZ,\~ .
DEPONENT
VERIFICATION:

Verified at ,1or6t~tgaf@J , . , 2023 and I do solemnly affirm


that the contents of the above said paras 1 to 2 of the affidavit are

true and corrects to best of my knowledge and belief and nothing

~DEPONENT
IN THE HON'BLE HIGH COURT OF DELHI AT NEW DELHI
(EXTRAORDINARY CRIMINAL JURISDICTION)
(UNDER SECTION 482 OF CRIMJNAL PROCEDURE CODE)
CRIMINAL M.C. NO. OF 2023
IN THE MATTER OF:
Bir Singh & Ors . . . Petitioners
VERSUS
The State & Anr . . . Respondent
AFFIDAVIT

I, Bansi Lal, S/o Sh. Soay Ram, aged about 60 years, R/o Plot No. P-19, ,

Gurdayal Vihar, Chanchal Park II, Bakkar Wala, West Delhi-110041, do

hereby solemnly affirm and declare as under:

v~- -i.-. - 1 hat I am the Petitioner No. 2 in the accompanying Petition and I
· ~ omm,ssio
~~ \)'2.~ 1)0
~(;)" ~0-~oll~u\l. hette made myself aware of the facts and circumstances of the
~fl;~ s~- . .,~~' ·,. ~ cou\ iC
~~\J'" \'i\\ \-\\~ ?..~ '""
~ .'o'i·\)\1:il\\11i\-c.._ . . Hence I am competent to swear this affidavit.
r- t:.-9\\,e,\OO ~1\)1 !'2.~i'.<:\'<' ~.1/
iC l'is Ha;~r~ cout\, ('\• That the contents of the accompanying application for stay has

been drafted by my counsel as per my instructions and the

A\ _ tt\\~ontents of the same have been read over and explained to me in


I\J~ 0;e\\\
1
,
~\\~ \\\i oe \~ \)te1;,e~ rnacular and are admitted by me to be true and correct. n,1_ /'J. (/ fr
\ \\\e\\ • ~e\\\t\ t1' ur-> .-..:...1!rY rev!
~S S\g DEPONENT
VERIFICATION:

Verified ft 1 5,~~ ~hiw i~Y. of , 2023 and I do solemnly affirm

that the contents of the above said paras 1 to 2 of the affidavit are

true and corrects to best of my knowledge and belief and nothing


v t:RTI FIED ~ AT l"HE PONENl
,.-t,_ ~ fl
10Cfdl".. . .. '
Shri/Smt./Km..
S/o 1
·_
a l -- .. •.Gonoealed therefrom.
C} .. . .. . .....~ •. , . . II{ 0 ~'1/
- A(,.,_,1
lV( 1..._v 1

1 5 SEWf~q~~ . ~:~~}~~~~~k . 1

Delhi on ......... .. ........... ·.. ~- ;:,I. No ..


that the Content_, of the affid vit which have
been read and explained t o m are true and
~s. DEPONENT

correct to hi s .knowlwdg e.
1 r SfP 2023 oath C ~ sloile, oe 111t1 '
IN THE HON'BLE HIGH COURT OF DELHI AT NEW DELHI
(EXTRAORDINARY CRIMINAL JURISDICTION)
(UNDER SECTION 482 OF CRIMINAL PROCEDURE CODE)
CRIMINAL M.C. NO. OF 2023
IN THE MATTER OF:
Bir Singh & Ors ... Petitioners
· VERSUS
The State & Anr .·.. Respondent
AFFIDAVIT

I, Shanti, W/o Sh. Bansi Lal, aged about 56 years, R/o Plot No. P-19,

Gurdayal Vihar, Chanchal Par~ II, Bakkar Wala, West Delhi-110041 , do

2. That the contents of the accompanying application for stay has

been drafted by my counsel as per my instructions and the

contents of the same have been read over and explained to me in

~en\ ~l\Overnacular and are admitted by me to be true and correci.• 9_\\ D'-~
\ \den\\t~ \\\~ :a~ \)tesenct
. ~ss\gne(\\t\ DEPONENT
VERIFICATION:.

Verified at , oJ ttfis S~fot023 , 2023 and I do solemnly affirm

that the contents of the above said paras 1 to 2 of the affidavit are

true and corrects to best of my knowledge and belief and nothing

t, i::.R TIFIEO T f;M~riall~ IP,a~Qqealed therefrom.


Shrt/Smt./Km ... ~ .~.. ,
S/o ft.o D~ -~~.....'3.tLN[: :{a]··:·· ......·
!11 \ tr-"rft
1 5 $lniillJ23 , ~w..~~~ l(J DEPONENT
has so i ti ' ~ .\ J ...t:-.1..U .~h~1.,..q ¥ V--,.....V ,
0
Deihl on ... ..... ....::... ~.~.~.d _b ! t ; ; . ~~ ~ . .
that the Conte nts of the aff" ,avit which have
been read and explained to Im are true and .
correct to his knowlwdg
.• .,_ S[ P 2023
ANNEXURE P-1

FIRST INFORMATION REPORT

(under s~ction 154 Cr.P.C.)

1. district: west Delhi P.S. : Khyala year : 2021 Fl R No. 0842 date :

6.10.2021

2. Act(s) IPC 1980 Sections 498A/406/34

3. Occurrence of offence:

(a) Day Date from Date to

Time Period time from time to

(b) information received at P.S. date 6.10.21 time 23:44 hrs

(c) general diary reference entry no. 134A time 23:44 hrs

4. type of information: written

5. place of occurrence

(a) direction and distance from P.S. beat No.

(b) Address :

(c) in case, outside the limit of the police station

Name of P.S. District

6. Complainant/informat

(a) Name: Chander Kanta (w/o) Bir Singh

(b) Date/year of birth: 1994· · nationality: India

(c) Passport No. date of issue place of issue

(d) Occupation

(e) Address : P19, Gurudayal Bihar, Chanchal Park, Nangloi- Nazafgarh .

Road, Outer District, Delhi, India


7. Details of Known/ suspected/unknown accused with full particulars

(attach separate sheet if necessary)

8. Reasons for delay in reporting by the Complainant/informant: no delay

9. Particulars of property stolen/involved (attach separate sheet if

necessary)

S.No. Property type( description) Est. Value. Statue

10. Total Value of property stolen

11 . inquest report/U.D. Case No., if any

12. F.I.R. Contents (attach separate sheet, if required) (First Information

·Report Facts):

FIR NO. 0842 DATE:08/10/2021

To Mr.ACP women police station, Kirti Nagar, New Delhi, Sir It is requested
that, I Chandra Kanta w/o Beer Singh, P-19, Gurudayal viahar, Chanchal Park
Nangloi- Najafgarh Road PH 9711754498 I was married on 8/4/14 according to
Hindu customs and my marriage was done by grandfather in law (Nautram) and
I was fine for two months of my marriage but After two months, my husband
(Beer Singh) started beating me along with his parents (Shanti-Bansilal) and
along with them, my sister-in-law and her husband (Kishan Sunita) also started
abusing me like saying that I am dirty woman, you are of low caste and my
.mother-in-law (Shanti) used to abuse me like a prostitute, bastard, scoundrel
sister-in-law and my father-in-law (B. Lal) used to abuse me in such words
which I cannot tell you in words by writing or speaking my mother-in-law-
Father-in-law, Shanti-Bansilal abused me .my Father-in-law Bansilal fought with
me along with my husband at 9:00 pm on 19/7/14, abused me and said that
your parents did not give anythin~ in marriage like dowry clothes Didn't even
give gold and silver things and said you are daughter of beggars, your parents
are belong to low caste, daughter of low caste, they not give anything and later
this continued and again and again my in-laws and my husband (Beer Singh) all
used to say that you were not given anything in marriage and you did not even
bring our clothes from your parents go and bring the money from your parents,
on 2/8/14 at 8:00 pm told me to bring 10,000 money and my mother-in-law
(Shanti) and sister-in-law (Sunita) hit me in my room and pulled me out by my
hair and my husband Beer Singh also did not say anything, no one stood by my
side, then on 10/8/14 at 7:00 am my father-in-law told me to bring 50,000 as he
need to buy a car, bring fridge or washing machine from your father and used to
beat me and then one day my husband Veer Singh on 19/3/15 at 9-10 fought
with me and started beating me. I (Chandrakanta) was also pregnant at that
time, then I went to Ranhola poli~e station on 20/3/15 at 11 am and where my
mother-in-law's son came to Ranhola police station (Roshan Lal) as he was in
the police, because of his post, no action was taken on my father-in-law's side.
My brother-in-law (Roshan Lal) said that I am working in the police station, so
no action was taken on my in-laws' side in the police station. 20/3/ 15 DD
No.44BD ) No. 51 B Then I (Chandrakanta) came from the police station
wearing only one pair of clothes and came to Raghuveer Nagar to my parental
home. At that time my parents paid all the expenses for the delivery of my
daughter (Anushka ) on 15/6/16 at 4 am in Guru Govind Hospital, my brother
(Bunty) called my mother-in-law and father-in-law at 5 am on 15/6/16 and said
that a daughter was born to Katna but my in-laws not came, then after 1 month
my father (Lakshmi Narayan ji) called to my grandfather father-in-law (Nautram)
who was the middleman of my marriage, then 5 people came from my in-laws
side and 5 people also came from our side. And after consulting and on
suggestion of all persons in the temple, the in-laws side apologized and said
that this will not happen again and took us to the in-laws house, then it was
okay for some time, but after some time, my husband started fighting again with
me and Said that your parents qid not give you anything even on birth of our
daughter Anushka , sent you empty handed, your parents are beggars, then 1
day on Rakshabandhan, I went to my house in Raghuvir Nagar after doing
Rakhi, when I went to my in-laws house with my husband the husband started
fighting with me, started abusing me and said that your father are beggars, did
not give anything, did not even give clothes, and along with mother-in-law,
father-in-law, brother-in-law, everyone said that even though it is our first
children, you should not get clothes and money. On 14/1/16 at 8 pm because of
quarrel with my in laws, I, kanta was upset with the daily quarrel and used to
live in my room but one day when there was a lot of fighting, mother-in-law,
father-in-law, brother-in-law and husband were removed me from home to my
parents' house in Raghuveer Nagar and I Kanta was come to my parental home
along with my daughter Anushka. this thing happened on 5/12/2016 at 10
o'clock when my daughter Anushka was 7 months old and my daughter
Anushka's first birthday was also celebrated at maternal grandmother's place
and I stayed in Raghuveer Nagar for six-seven months. One day, suddenly my
husband came to pick me up at Raghuveer Nagar in Evening at 6: PM, then my
parents didn't say anything and my husband assure my parents that nothing
wrong will happen now and please send her with him to her in-laws house then
it was fine for few months then they started fighting and They used to send me
out in the middle of the night, sitting on the stairs of the house I used to spend
the night. Mother-in-law and father-in-law also said that they used to threaten to
throw me out of the house. They used to beat me and abuse me when I refused
to go out. When I complained in the police station Gehaula, then Roshan Lal
who was in the police said that there will be no action taken, you all be at ease
DD No. 27 and Date. 6/10/16 Then I stayed with my parents for some time, all
this went on like this, then one day my husband came to ·take me from Raghu
Veer Nagar and took me home to my in-laws house, then everything was fine
for some time, but after some time he Started fighting again, started beating and
beating. I used to bear the torture and thought that everything will be fine but
nothing happened. One day, My Husband fought excessively with me and
thrown me out of the House and my daughter Anushka was also not given.

And from there she came to her home in Raghuveer Nagar on foot, then stayed
for a month and contacted on the phone, she used to call her husband to talk to
Anushka , but he did not get her to talk to Anushka. When she went to her in~
laws house and mother-in-law; father-in-law, brother-in-law and husband
quarreled, then the lady called the Women's Commission .here on 100 number,
then l got the daughter through the police, all this is a matter of 29/10/17, the
time was 2-3 o'clock. At the time of coming, our 10 in the police station, who
was Ran Singh ji he got me my daughter through the police, then from there I
started living in my father's house. And stayed there for around 7-9 months.
That on one day with the consent of all like husband, mother-in-law and father-
in-law talking with my parents and then husband apologized and said that I will
not do it from now and send Kata along with me then I came to my in-laws
house everything was normal for some time then there was a fight for some
time then everything was fine - It's okay, sometimes there used to be a lot of
quarrel like beating, abusing and abusing kept on like this and I was facing the
same problem. I had received the phone but there also my husband used to
break it after some time, many such phones have been broken by my husband.
This all happened in 2018. On 1 day 27/3/19, my husband broke it at 7:00 in the
morning. The quarrel was going on with me since the night of the fight, but in
the morning at the time of tea, the quarrel increased, I called the women's
helpline and lodged an FIR in the Ranhola police station and went to my house
on 27/3/19 DD No. 14B Then I stayed in Raghuveer Nagar for some time then
after some time my husband called me and said come home everything will be
fine I refused that I will not come but he kept calling again and again when I told
him that now I will do the case to the Mahila Mand al then he got scared and he
left home and started living in a rented house and came home calling me then
one day he came along with his friend Ravi in a car and his friend also said that
sister-in-law nothing will happen to you I am saying Beer will not hit you, let's go
home, now it is a rented house and husband also said the same, then I thought
let's see once, then I went with my daughter to the rented room in my parents'
house. Raghuveer Nagar stayed for 2½ months when I obeyed Ravi and my
husband and went to a rented room, took me for the night, at that time my
father-in-law also took me home after talking to my father May 30, 2019 at
10:30 pm I went to the room with ry,y husband at Bakkarwala Flat no.66. things
remained normal for some time, he didn't beat me but used abusive language.
He didn't let me go anywhere. Why are you standing on the balcony, your friend
is standing there, looking at him, calls men after I leave, takes money, used to
speak many dirty things, which I can't even describe, then after some time,
mother-in-law and father-in-law started coming and going there too. starting,
fighting again, then mother-in-law and father-in-law started saying that stay at
home, vacate here, you give two to four thousand , stay at your house, obeying
husband's words, I also evacuated from there and came to my house on 7 Sep
2019. The same fight started again on 17 Sep 2019, my sister-in-law fought with
me many times and sister-in-law said that Kanta should not come to the lower
Ground floor and will not take things of my brother-in-law. She takes husband's
stuff, still he didn't say anything, no problem, I stopped going downstairs to G.F.
and started to live on backside room of first floor. My mother-in-law and sister-
in-law makes my life miserable. My Daughter Anushka used to play in the lower
G.F house, and sometimes she used to ask for water, then my sister-in-law
used to say, is there no water in your house, come after drinking water from
your, and my mother-in-law used to take my daughter Anushka out of the
Ground Floor by holding both hands and My daughter used to tell me that
grandmother told me like this and when I told my husband, he started saying
that keep your daughter at home, don't let her go down. 9th March April 2020
but fought and beat me. mother-in-law also started abusing me but I didn't do
anything because my father was very sick at that time because he had cancer
and he was a heart patient, he had two attacks, so we did all this. One day my
father's health started getting worse, then my mother told me on the phone,
then I told my husband, he leave . me home in Raghuveer Nagar, left me for
three days, then one day on Saturday, he told that he will comes to pick me up
and My father was unwell at that time, so I called him and refused to go, so he
came home and had a fight with my father and me on Saturday, so my father
could not be spoken at that time, so he told me with folded hands that you go. I
am fine, then I came from Raghuveer Nagar to Chanchal Park in-laws house,
then everything was fine for a while but my father became ill for a day, then my
mother said on the phone, I told my husband, he called on Thursday, 17/9/2020
in the morning. Raghuveer Nagar came with her husband at 6:30. Husband
went to his work from Raghuveer Nagar. My father's health worsened on Friday
night, then I and my brother brought him to E.S.I. hospital in the morning on
19/09/2020. But my father left us forever at 9:45 on 19/09/20, then there was a
program of the kriya and satsang; At 2:00, my husband had the same quarrel
with me, abusing me and took me home from Raghuveer Nagar to Chanchal
Park, that too on an empty stomach and neither did I eat or drink anything. I had
come to my home in Raghuvar Nagar, even then my husband quarreled with
me on the phone, abused me even used abusive language for my late father,
he. call me a thief, from there I went to my grandfather and father-in-law's house
in Madipur and told everything to my Grandmother-in-law but she did not say
anything at my in-laws house, then I stayed here at my mother's house in
Raghuveer Nagar for 2 months, then I went to my house on 22/11/20 for
collecting my daughter's clothes went to her in-laws house to buy winter
clothes, then there also the husband quarreled with me then I called the Women
Cell and the police from there and I got the clothes from the Women Cell police,
then there is something that I can not tell you. Let me tell you some such things
that you can hear, on 24/11/20 my husband request me to come back to my
matrimonial home for the sake of my daughter and I had gone to the house, but
it was a thought-out conspiracy against me that they would take me to my in-
laws house and beat me up. And my husband Veer Singh, my mother-in-law
Shanti, father-in-law Bansilal, my sister-in-law Priya, sister-in-law's mother
Lakshmi Haisi, all of them used to talk on the phone and my sister-in-law Priya
and my husband Bir Singh had something to do with each.other. I have proof of
this, then I had such a big fight in my in-laws house within 1½ months that in
this fight my husband, mother-in-law, father-in-law and brother-in-law beat me,
husband beat me so bad that I can't even tell you. all this 10/12/20 happened
on at about 8:30, I was beaten up by everyone, my sister-in-law said that took
me out of the house by pulling Kanta hair will beat her on the road, then my
brother in law Bheem Singh saves me from being beaten by Bir Singh. My
brother in law Beer Singh always saves me from beating my husband. If my
sister Suman and my brother in law Bheem Singh speaks on my behalf then all
my in laws fight with them and they beat my brother in law as well and today
on1012/20,when my husband qu~rreled with me, then my brother-in-law did not
·save me, then everything went on like this, I also let it go on like this, then one
day when my father was completing 5½ months, then mother called all the
sisters home and made a program for 5½ months inheritance, then the husband
had sent the work for 2/2/21. On 2/2/21 itself, at 2:30 pm, I went to my house
Chanchal Park in-laws house, then my Husband abused me as soon as I came
home, abused me and broke the ):>hone, took the sim also, then I made noise
there, then my father-in-law came with me and started abusing me, then I called
my brother from the phone of an .uncle Kaushal ji. Then my family members
came to Ranhola police station and there too there was a lot of argument. Then
through the police, I brought my daily use clothes to my house in Raghuveer
Nagar. I am living here and my husband is going on spending like meeting
photos with different girls and having fun and not giving me even a single penny
and my stree dhan is also with my mother-in-law and father-in-law like gold
.nose cloves, Gold earrings, gold mangalsutra, gold ring ladies, silver anklets,
silver waist brace, gold silver jeans ring , silver pinch, all this is with my mother-
in-law and father-in-law. My brother in law and sister in law always said to Me
again and again Prostitute etc. is more educated, Kajri, brother's woman,
scoundrel, sleeps under others, very dirty, which I can't write to you, please, I
Chandrakanta, for the last 6 years, I am troubled by this daily fight with my in-
laws. My daughter is with me and I do not have any way of earning, daughter's
education is also getting spoiled, please take legal action against my above
named in-laws, it will be very kind of you. Husband ( Bir Singh) 9716808700 ,
8178682300 , Mother-in-law ( Shanti ) 9289449131 , Father-in-law ( Bansi Lal )
9990628061 , Brother in law ( Kishan ) 8527214333 , Jethani ( Sunita )
852721 4333 r/o P - 19 Gurudiya L Vihar Chanchal Park Nangloi- Najafgarh
Road Sd English Chandra kanta Chandra Kanta B - 17 Raghuveer Nagar New
Delhi- 27 P.H. 9711754498 Do Ps Khyala register a case U / S 498A / 406 / 34
IPC And Investigation handed over to undersign . Sd English Sunil ASI Sunil
Kumar Ps Khyala Delhi Dt. 006/10/2021 Police Action ASI Sunil Kumar came in
a Hindi Tahrir DO Room and presented his mind to HC / DO which on receipt of
article Case No-842 I 21 U / S 498A I 406 I 34 IPC Computer Operator in
CCTNS After getting registered, the original, FIR Copy and 65 (B) Evidence Act
Certificate were handed over to ASI Sunil Kumar by the orders of SHO. Who
will take action on further investigation. Related documents will be sent to the
higher authorities by post. Written By HC / DO P.S. 2021 6842 Date :
0/10/22021

13. Action taken since the above information reaveals commission of offence
u/s as mentioned at item no. 2.
i. registred the case and took up the investigation
ii. name of the 1.0.: Sunil Kumar Rank ASI No. 28931577 to take up the
investigation
iii. Refused investigation due to
iv. transferred to P.S. : name.: district:

FIR read over to the Complainant / I nformant admitted to be correctly


recorded and a copy given to the complainant/ informant free of cost.

ROAC
14. Signature/ Thumb impression of the complainant/ informant

Signature of the officer Name: Ram Lubhaya Rank HC


No.28980477
15. Date and time of dispatch to the court:

TRUE TRANSLATED COPY


FIRST INFORMATION REPORT
(Under Section 154 Cr.P.C.)

(UTU 154 ~ uflmrr 'Uft'm ~ ~ )

1. District ( ~ ):WEST P.S.('lRT): KHYALA Yoar(ri): 2021 FIR No(ll'.~.lt:u.):0842 Date : 06/10/2021

2. Act(s)(~ ): Section(s)(IJTTI{,t)):

- IPC 1860 498A/4 06/34

3. Occurrence of Offence (arimu .£'\ Uc-ff):


(a)Day(~: Date From(~-«): Date To(~ ncti):
Time Period (lllnf arcnu): Time From~ ll): Time To ( ~ <ffi):
(b)lnforrnation received at P.S.(tfRT ~ ~ 1rnf ~ ): Date(~: 06/10/2021 Time ('Ulm): 23:44 hrs
(c)General Diary Reference {<1'41-tllhll ~ ) : Entry No.{llfaft ll'.): 134A Date/Tlme(~/lrlnl'):06/10/2021 23:44
4. Type of Information (~ iliT ll'ifill'): Written
5. Place of Occurrence (Ubl lt-tlol ):
(a) Direction and Distance from P.S (m-rr ll ~ ah ft;:ffl): Beat No(i& lt.) : 0
(b) Address(l@l):
(c) In case, Outside the limit of the Police Station ~ ITRT lftm ~ ~ ! ):
Name of P.S(m:rr iliT :m:J): District(~):
6. Complainant / Informant (~<filUiilfi11f/~iRT<fi(ff ):
(a)Name(;n'il}: CHANDER KANTA (W/0) BIR SINGH

(b)Date/Year of Birth~ ftritr /q!fJ: 1994 Nationality (utnra'T): INOIA


(c)Passport No.(ll'TlJll1t ll'.): Date of Issue ( ~ lfi"R ~ ~ ): Place o f Issue ( ~ 1'ir-l 1fiT 'flfR):

(d)Occupatlo n ( ~: NOT KNOWN


(e)Address(l@l): P19, ~ ~ mr.;J trm, ~ - ~ m,OUTER DISTRICT, DELHI, INDIA,
7. Details of Known/Suspect/Unknown accused with full partlculars(attach separate sheet If necessary) ( ~ / ~ /ar.;m, ~ ilil
iliT~~mt<,m 1:

8. Reas on for delay In r eporting by the complainanUlnformant (~ifilUiilli<if / q<1-11ifinf ~ ftini t"ft ll ~ ifK'R ~ lfITTVI}:
NO DELAY

9. Particulars of the properties stolen/involved (attach separate sheet If necessary):

SI.No. {ifi.lf.) Property Type(Descrlption) Est Value(Rs.) ~ (~ ~))

10. Total value of property stolen (.Aft'¢~ 1fiT fM ~):


11 .lnquest Report / U.D. Case No., if any (1{~ 'UlftlJT ftini I ~.tt.lllfitVT ~-. m't lfTTf ~ ):
District : WEST P.S: l<HYALA Year: 302 1 FIR No 0&-12 Date. 01111=1
P.S: Year. 21n, FIR No: OM2 Date: 06/10/2.02t
District : WEST KHYALA

3
District : WEST P.S: KHYAI.A Year. 2021 FIR No: OIW2 Date: 01111o,m1

4
..
District : WH T P.S: KHYALA Year: 2021 FIR No: ct42 Date: w1012021

13.Acllon Taken Since the above Information reveals commission of offence(s) u/s as mentioned at Item No. 2:
(ifil 1Tlft ~ : i{fiif ,J'lfffll; ~ i ll"i'l1 ~ 3 fiif ~ rnn amru in-; .t.2.il ~ • um~~ t ):
(!)Registered the cue anc;t took VP the Investigation: OR(lll)
(IA'i{VT ~ f.lra1 lTl'JI <!ITT ";iff<1 ~ ~ ~ '1'1<11):
(iQ Directed (Name of the 1.0 .)("1u ~ ~ ~ ): SUNIL KUMAR Rank (Q?;):
AS$T. SI {ASSISTANT SVB-INSPECTQR)
No(lf.): 28931577 to take up the Investigation (cfi\ "'1il anir-l QTIJ il N~ t ~ P-lt~ ~ mrr) OR(lll)
(Ill) Refu11d investigation due to("1il ~ ~ ): OR (* ~ ~ ~ ~
(Iv) Transferred to P.S(name)('1Rl): Olstrlct{R:r.n):
on point of Jurisdiction ('lfi1 ~ ~PIITT•1 Ettiinf'<n)

F.I.R read over to the complalnantllnformant,aqmltted to be correctly recorded and a copy given to the complainantllnformant,
free of cost : (fls<til4tl<titlf / i.•Flict,nf ffl V J ~ ~ <ti< ~:ni mft, ~~sf liRI .ii-{ 'Q"11i lfilift f.\'~~ fhm1t1ct,rlf <l'il tt mft) :

R.O.A.C.(3ITT.3rr,'Q".'UT.):

14.Slgnature I Thumb Impression Signature of Qfflcer


of the Complainant / Informant:
(QrtJl4oMf I~~~ ~ f l { I 3111,~ lll'T f.l'ffl't): Name{"1"11): RAM LUBHAYA
Rank{~: HC (HEAD CONSTABLE)

---
No.(lf.): 28980477

15. Date and Time of despatch to the court:


( ~ il g.-ci ~ ~ c t , 3'rl lflf71):
r

C.C. No..................................

FIR No. • 8..1,.'b./f.P..'b.}........


@
NCT Of' DELHI COURT l'CE
DlCT2337390HZ321 K
23.AUG-2023 UIS •. 1.,s..:~.lt..!.~/:Jlt.: ~ f ct..
L . . . . - -_ _ !~IIIIIIIIIIIIIUlllllllllllllll~llllllllllnlllllllil P.S . .. lhtt:/.~ ;/....D.'P.:-U1 I

Suit / Appeal No. _ _ _ _ __ _ __ _ _ _ _ _ _ _ _ _ _ _ __ _ JURISDICTION OF 202

P,!JlRttllis) Or Peti~ s) ,
A~(s) Com~s)

VERSUS
7ft/4 §r:Mf h:M €. . D e f ~ /Resp~ ent(s) / A ~

KNOW ALL to whom these present shall come that I/ We g,"' s,,-i ~ ) RAN JI li}J , k"
.Yt utt-11,
The above named f &Tl V 12 tJ C,f,£ do hereby appoint

P1yvrH .PHMfr>fl
~1>V ·
v,~ ~.., ~l- V~tl.
tu V·
1>/1-1t.2-/2--t>J'2- f>/877 -K/ua,
'f r-602J11KBt
t:!.>-, - fll~ <LUr. ~Vll-'W /ll l, 1 W H,A.24-lfb ,~o vf{(f"J/ 06--LH 1 -)f~orzr .
(herein after called the advocate/s1o be my/our Advocate m the above-noted case au~horize h1m:-
To act. appear and plead in the above-noted case in this court or in any other court in which the same may be ed
or heard and also in the apRellate court including High court subject to payment of fees separately for each court by
To sign file, verify and present pleadings, appeals cross-objections or petitions for
executions review, revision, withdrawal, compromise or other petitions or affidavits or other
documents as may be deemed necessary or proper for the prosecution of the said case in all its
stages subject to payment of fees for each stage.
To file and take back documents, to admit and/or deny the documents or opposite party.
To withdraw or compromise the said case or submit to arbitration any differences or
disputes that may arise touching or in any manr.er relating to the said case.
To take execution proceedings on paying separate fee.
To deposit, draw and receive money, cheques, case and grant receipts hereof and to
do all other acts and things which may be necessary to be done for the progress and in the
course of the prosecution on the said case.

To appoint and Instruct any other Legal Practitioner authorizing him to exercise the power
conferred upon the Advocate whenever he may think fit to do so and to sign the power o f att• ""
And 1/ We the undersigned do hereby agree to ratify and confirm all acts done by th Advocate or
his substitute in the matter as my/our own facts. as if done by me/us to all intents and purpose.
i
::,y
Jf.

And I/We undertake that I/ We or my/our duly authorised agent would appear In court and all hearings
and will inform theAdvocate for appearance when the case is called.
And I/We undersigned do hereby agree not to hold the advocate of his substitute responsible for the re-;ult of
the said case. The adjourn ent costs whenever ordered by the court shall be of the Advocate which he shall receive
and retain for himself.
nd nde~ned do hereby agree that in the event o f the whole or part of the fee agreed by me/us to be
e ~:er~ qifiing ~npaid he shall be entitled to withdraw from the prosecution of the said case until the
p. ~ e settle 1s only for the above case and above Court. I/We hereby agree that once the fee is
w·11 ~~ e entitled for the refund of the same in any case whatsoever and If the case prolongs for
1'H; th original fee shall be paid again by me/lls
HNESS WHERE OF I /We do hereunto ~et my/our hand to th ~ resents the contents · .

beenunde stoodbyme/usonthis ............ /£~.......... ... y~ ~ ~.. ... .


Accepted subject to the terms of the fees

I Identify tho Sl gna tu, c /Thumb Impression of tho Below Mentioned Person,
Who Has been Signed l n my presence. The Client.

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