IN THE HIGH COURT OF KARNATAKA AT BENGALURU

WRIT PETITION NO. ______ OF 2024

In the matter of:

Luv Agarwal, S/o Manish Agarwal, Aged about 26 years, Residing at #45, Green Park Layout,
Koramangala, Bengaluru - 560034 ………………...Petitioner

Versus

1. State of Karnataka ...Respondent No. 1

2. Harish Kumar Sharma, S/o Late Gopal Sharma, aged about 54 years, Residing at #23,
Rosewood Street, Jayanagar, Bengaluru - 560041 ...Respondent No. 2
3. Anjali Sharma, W/o Harish Kumar Sharma, aged about 49 years, Residing at #23, Rosewood
Street, Jayanagar, Bengaluru - 560041 ...Respondent No. 3
4. Kushi Sharma, D/o Harish Kumar Sharma, aged about 25 years, Residing at #23, Rosewood
Street, Jayanagar, Bengaluru - 560041 ...Respondent No. 4

PETITION UNDER ARTICLE 226 OF THE CONSTITUTION OF INDIA FOR THE

ISSUANCE OF A WRIT OF HABEAS CORPUS

MOST RESPECTFULLY SHOWETH:

1. Luv Agarwal, a lawful citizen of India and residing at the aforementioned address, hereby
petitions under Article 226 of the Constitution of India, requesting a Writ of Habeas Corpus for
the immediate release of Kushi Sharma (Respondent No. 4), believed to be unlawfully detained
by Respondent Nos. 2 and 3, followed by her placement into a secure environment.
2. The Petitioner, Luv Agarwal, and Respondent No. 4, Ms. Kushi Sharma, have maintained a
consensual live-in relationship for the past three years, fostering mutual respect and
understanding. As consenting adults, they jointly decided to cohabit and have since resided at the
mentioned address.

3. On March 10, 2024, the couple visited Respondent No. 4's parental residence at #23,
Rosewood Street, Jayanagar, Bengaluru, to celebrate the Holi festival, during which the events
leading to this petition occurred.

4. Following the initial festivities, a dispute arose concerning the living arrangements of the
Petitioner and Respondent No. 4. Respondent Nos. 2 and 3 expressed disapproval and demanded
that Kushi sever ties with the Petitioner and remain at her parental home.

5. Despite resistance from both Kushi and the Petitioner, Respondent Nos. 2 and 3 forcibly
detained Kushi within their residence, preventing her from leaving or communicating with
external parties, including the Petitioner.

6. The Petitioner was forcefully removed from the premises by security personnel employed by
Respondent Nos. 2 and 3 and was cautioned of dire consequences should he attempt to contact
Kushi. Despite numerous attempts since March 10, 2024, through phone calls, messages, and
intermediaries, all efforts to reach Kushi have been unsuccessful.

7. Concerned for Kushi's safety and well-being, the Petitioner sought assistance from the local
police station but was advised to pursue legal action due to the complex family dynamics
involved. The Petitioner asserts that Kushi's detention is unlawful, violating her fundamental
rights, especially her right to liberty and freedom of movement as guaranteed by Article 21 of the
Constitution of India.

8. Kushi Sharma, as a capable adult capable of independent decision-making, should not be

subjected to illegal confinement by any party, including her parents. The Petitioner is deeply
concerned about Kushi's physical and mental welfare, suspecting that her autonomy is being
compromised under duress.

Prayer:

The petitioner respectfully seeks the following reliefs from this esteemed Court:

a. May the Court graciously issue a Writ of Habeas Corpus, directing Respondent Nos. 2 and 3 to
promptly produce Kushi Sharma before this Court.

b. Upon her appearance, it is requested that Kushi Sharma undergo examination by the Court in a
manner deemed suitable to ascertain her wishes and well-being.

c. The Court is implored to promptly order the release of Kushi Sharma from the unlawful
custody of Respondent Nos. 2 and 3, ensuring her safety and freedom.

d. Furthermore, the Court is respectfully urged to grant any additional relief or remedies it deems
just and necessary in the pursuit of justice and safeguarding Kushi Sharma's liberties.

The petitioner solemnly affirms that the facts and circumstances presented above are true and
accurate to the best of his knowledge and belief. No falsehood has been included, and no
material information has been withheld.

Place: Bengaluru
Date: 20.03.2024

Petitioner through Counsel

VERIFICATION

I, Luv Agarwal, the petitioner involved in this case, solemnly affirm under oath in Bengaluru, on
the 20th day of March 2024, that the statements contained in this petition are accurate to the best
of my personal knowledge. I declare that all information provided is truthful, and no material
facts have been intentionally omitted.
Petitioner through Counsel

BEFORE THE HONORABLE CHIEF METROPOLITAN MAGISTRATE,

BENGALURU
Private Complaint Case No. ______ of 2024

Mr. Arjun Reddy,

S/o Mr. Vijay Kumar Reddy,
Aged about 34 years,
Residing at #67, Lotus Road, Indiranagar,
Bengaluru – 560038 ...Complainant

Versus

1. Christy's Auction House,

Represented by its Manager,
Mr. Rohan Gupta,
#45, Church Street, MG Road Area,
Bengaluru - 560001 ...Accused No.1

2. Mr. Rohan Gupta,

Manager, Christy's Auction House,
#45, Church Street, MG Road Area,
Bengaluru - 560001 ...Accused No.2

PRIVATE COMPLAINT UNDER SECTION 190 READ WITH SECTION 200 OF THE
CODE OF CRIMINAL PROCEDURE, 1973 FOR THE OFFENSES PUNISHABLE
UNDER SECTIONS 420, 465, 467, 468 AND 471 OF THE INDIAN PENAL CODE, 1860
1. The plaintiff, Mr. Arjun Reddy, respectfully presents this private complaint against the
defendant for offenses involving cheating, forgery, and the sale of counterfeit artworks. Mr.
Reddy, a resident of Bengaluru and an avid art enthusiast, deeply values the acquisition of rare
and esteemed paintings.

2. The defendant, Christy's Auction House, extensively advertised an auction featuring rare
paintings scheduled for January 11, 2024, at their Bengaluru premises, widely publicized across
various media platforms.

3. On the specified date, Mr. Reddy attended the auction organized by the defendant and
acquired a painting titled "Sunset Serenity," purportedly created by the renowned artist Ravi
Varma, for a sum of Rs. 10,00,000, trusting its authenticity based on the defendant's assertions.

4. Following the purchase, Mr. Reddy sought expert evaluation of the painting, which, on
January 11, 2024, confirmed it to be a counterfeit, not an original work by Ravi Varma. The
defendant had advertised and presented the painting as an authentic Ravi Varma creation,
deceiving Mr. Reddy into significant financial expenditure under false pretenses.

5. The defendant knowingly engaged in the sale of the counterfeit painting to Mr. Reddy with the
intent to deceive and unlawfully profit. As a result, Mr. Reddy suffered financial loss and
emotional distress due to the defendant's fraudulent conduct.

6. Furthermore, the possession of a counterfeit painting has adversely impacted Mr. Reddy's
reputation as an esteemed art collector, tarnishing his standing in the art community.

Prayer:

a. The plaintiff requests the registration of charges against the defendant under Sections 420
(Cheating), 465 (Forgery), 467 (Forgery of valuable security), 468 (Forgery for the purpose of
cheating), and 471 (Using a forged document) of the Indian Penal Code, 1860.
b. Additionally, the plaintiff pursues restitution and compensation for the financial losses and
emotional suffering inflicted by the deceptive conduct of the defendant.

Place: Bengaluru
Date: 11.03.2024

Complainant through Counsel

VERIFICATION

I, Arjun Reddy, the plaintiff in this case, affirm and declare that the statements provided above
are accurate to the best of my knowledge. There is no falsehood contained therein, and no
significant information has been omitted. Verified in Bengaluru, on this 11th day of January
2024.

Complainant through Counsel

IN THE COURT OF ADDITIONAL DISTRICT AND SESSION JUDGE, BANGALORE

Criminal Bail Application No. …… of 2024

IN THE MATTER OF:

Swarana D/o Anant Rao,

Aged about 27 years ...Applicant/Accused No. X

Versus

State of Karnataka ...Respondent

APPLICATION UNDER SECTION 439 OF THE CODE OF CRIMINAL PROCEDURE

1973 FOR GRANT OF BAIL

Most Respectfully Showeth:

1. This application, under section 439 of the Code of Criminal Procedure 1973, is being filed by
the Petitioner to seek bail in connection with FIR No. 420 registered at the Bangalore Police
Station under Sections 21, 29, 61, and 85 of the Narcotic Drugs and Psychotropic Substances
Act, 1985. The arrest stemmed from a raid where the applicant was allegedly found in possession
of 340 grams of morphine. The Petitioner was arrested on 23.03.2024 and is currently in judicial
or police custody.

2. The Petitioner asserts innocence, stating that he is wrongly accused in the case and is not
involved in the matter.

3. A law-abiding citizen of India, the Petitioner is actively engaged in the paper mill business in
Halasuru.

4. The Petitioner, a responsible individual, resides at the address mentioned above.

5. On the incident date, 23.10.2023, Swarana was participating in a charitable event organized at
a local sports club. Unbeknownst to her, individuals at the event were under police surveillance
for suspected drug-related activities. During a subsequent police raid, multiple bags, including
Swarana’s, were seized, with hers allegedly containing morphine. Swarana maintains that her
bag was mistakenly or deliberately swapped during the event, as she had no knowledge or
possession of such substances.

6. The Petitioner has procured statements from various witnesses present at the event, supporting
her innocence and displaying behavior inconsistent with drug trafficking. Swarana has fully
cooperated with law enforcement since her arrest, providing all necessary information and
complying with procedural requirements.

7. No direct evidence links Swarana to the possession, sale, purchase, or transportation of the
confiscated morphine. There is a lack of forensic evidence, such as fingerprints or DNA,
connecting Swarana to the contraband.

8. The Petitioner has presented substantial evidence, including time-stamped photographs and
testimonies, indicating her engagement in lawful activities at the time of the alleged drug
transaction.

9. The Petitioner, being innocent, argues that there is no valid reason to keep him in custody,
making this a suitable case for bail. (It is pertinent to mention the stage of the investigation,
whether charges have been filed, evidence initiated, the number of prosecution witnesses listed,
etc., as these would be mitigating circumstances).

10. The Petitioner pledges to comply with any conditions imposed by this Honorable Court upon
granting bail and commits to attending every trial hearing.

PRAYER:

Given the facts and circumstances, it is respectfully requested that this Honorable Court:

a. Extend bail to the Petitioner concerning FIR No. 420 filed under Sections 21, 29, 61, and 85 of
the Narcotic Drugs and Psychotropic Substances Act, 1985, at Bangalore Police Station.

b. Issue any other order that this Honorable Court deems appropriate and just in the pursuit of
justice.

Petitioner Through Counsel

Place: Bengaluru Dated: 24.03.2024