IN THE HIGH COURT OF DELHI AT NEW DELHI

WRIT PETITION (CIVIL) No of 2023

In The Matter of:

Shweta Singh ……. Petitioner

Versus

Union of India & Ors …….Respondent/s

INDEX

S. PARTICULARS PAGE NO
No
1. Notice of Motion

2. Urgent Application

3. Court Fee

4. Memo of Parties

5. Synopsis & List of Dates and Events

6. Petition U/s 226/ 227 Constitution of India

along with Affidavit

7. Annexure-P1(Colly)
True Copy of Admit Card, Score Card, and
allotment letter of the Petitioner
8. Annexure P-2
True copy of medical records of the Petitioner

9. Annexure P3
True Copies of notification of schedule for
special stray round vacancy

10. Vakalatnama
11. Proof of Service

PETITIONERS

THROUGH COUNSEL

AJITABHA PANDEY& D.K CHAUBEY

ADVOCATES

352/C-1B MUNIRKA

NEW DELHI-110067

9354793708

IN THE HIGH COURT OF DELHI AT NEW DELHI

 WRIT PETITION (CIVIL) No of 2023

In The Matter of:

Shweta Singh ……. Petitioner

Versus

Union of India & Ors …….Respondent/s

NOTICE OF MOTION

Sir,

The enclosed Petition in the aforesaid matter is being filed on

behalf of the petitioner and is likely to be listed on 21.11.2023,
or, thereafter any date. Please take notice accordingly.

PETITIONER

THROUGH COUNSEL

AJITABHA PANDEY & D.K CHAUBEY

ADVOCATES
352/C-1B MUNIRKA
NEW DELHI-110067
9354793708
Place: New Delhi

Dated: 20.11.2023

IN THE HIGH COURT OF DELHI AT NEW DELHI

 WRIT PETITION (CIVIL) No of 2023

In The Matter of:

Shweta Singh ……. Petitioner

Versus

Union of India & Ors …….Respondent/s

URGENT APPLICATION
To
The Registrar
High Court of Delhi at New Delhi
Sher shah Suri Road
New Delhi
Sir,

Kindly treat the accompanying Writ Petition (Civil) as an urgent

one as accordance with the Delhi High Court Rules.

PETITIONER
THROUGH COUNSEL
AJITABHA PANDEY & D.K CHAUBEY
ADVOCATES
352/C-1B MUNIRKA
NEW DELHI-110067
9354793708
Place: New Delhi
Dated: 20.11.2023

IN THE HIGH COURT OF DELHI AT NEW DELHI

 WRIT PETITION (CIVIL) No of 2023

In The Matter of:

Shweta Singh ……. Petitioner

Versus

Union of India & Ors …….Respondent/s

COURT FEE

PETITIONER
THROUGH COUNSEL
AJITABHA PANDEY & D.K CHAUBEY
ADVOCATES
352/C-1B MUNIRKA
NEW DELHI-110067
9354793708
Place: New Delhi
Dated:20.11.2023
 IN THE HIGH COURT OF DELHI AT NEW DELHI

WRIT PETITION (CIVIL) No of 2023

In The Matter of:

Shweta Singh ……. Petitioner

Versus

Union of India & Ors …….Respondent/s

MEMO OF PARTIES

Shweta Singh

R/o 140 Vikas Puram Colony

Janaura, Faizabad

Uttar Pradesh-224001 Petitioner

Versus

1. Union of India

Through its

Secretary, Department of Higher Education

Ministry of Education, 127-C Shastri Bhawan

New Delhi-110001

Email; secy.dhe.nic.in … Respondent No -1

2. National Medical Commission

Through its Secretary

Pocket- 14 , Sector – 8, Dwarka Phase -1

New Delhi – 110077

Email; pg.marb@nmc.org.in ...Respondent No 2

3. Directorate General of Health Services

Through its Director General

Room No 446 A Nirman Bhawan

Delhi-110011

Email; dghs@nic.in ..... Respondent No 3

4. Aarupadai Veedu Medical college & Hospital

Through Competent Officer

Pondy Cuddalore Main Road,

Kirumam Pakkam Bahour Commune Panchayat

Puducherry - 607402

Email- dean@avmc.edu.in .....Respondent No 4

PETITIONER

THROUGH COUNSEL

AJITABHA PANDEY & D.K CHAUBEY

ADVOCATES
352/C-1B MUNIRKA
NEW DELHI-110067
9354793708
Place: New Delhi

Dated: 20.11.2023
 IN THE HIGH COURT OF DELHI AT NEW DELHI

WRIT PETITION (CIVIL) No of 2023

In The Matter of:

Shweta Singh ……. Petitioner

Versus

Union of India & Ors …….Respondent/s

Synopsis and List of Dates

The Petitioner

List of Dates

06.04.2023

20.11.2023 Hence, the present Petition.

 IN THE HIGH COURT OF DELHI AT NEW DELHI

WRIT PETITION (CIVIL) No of 2023

In The Matter of:

Shweta Singh ……. Petitioner

Versus

Union of India & Ors …….Respondent/s

PETITION U/S 226/227 CONSTITUTION OF INDIA FOR

ISSUANCE OF WRIT OF MANDAMUS TO THE
RESPONDENT NO 2 &3 TO ALLOW THE PETITIONER TO
PARTICIPATE IN THE SPECIAL STRAY ROUND
VACANCY AND TO PERMIT MIGRATION

MOST RESPECTFULLY SHOWETH:

1. That the Petitioner

2. That this Hon’ble Court a territorial Jurisdiction to
entertain this Petition.
3. That the Petitioners have filed no other Petition in this
subject matter in any other Court of Law.
4. That no caveat has been on record in the subject matter of
the Petition by the Respondent No 1, 2, 3 and 4.
5. That the Petitioners seek leave to add and amend the facts
and grounds at any such later stages of hearings by the
permission of this Hon’ble Court.
6. That the Petitioners have a prima facie merit to succeed.

GROUNDS

The Petitioners seeks the appropriate relief/s on the grounds as

herein below;
 a. Because the
b.
c. Because the Petitioner seek leave to add and amend
the grounds at any such later stages of hearings by
the permission of this Hon’ble Court.
d. Because the Petitioners has a prima facie merit to
succeed.

PRAYER
It is, therefore, most respectfully prayed in the interest of
substantial Justice to be pleased to;
i. Issue a writ of nature of mandamus to the
Respondent 3 to permit the petitioner above named
to register for special stray round vacancy for NEET
PG 2023 and to keep open for counseling the seat
allotted to the Petitioner in the Respondent No 4
University
ii. Pass a direction to Respondent No 3 to pass a
direction to Respondent No 4 to return back all the
documents of the Petitioner.
iii. Pass a direction to the Respondent No 2 to consider
the case of the Petitioner for the migration.
iv. Pass any such further order/s as this Hon’ble Court
may deem fit and proper in the interest of substantial
Justice.

PETITIONERS

THROUGH COUNSEL
 AJITABHA PANDEY & D.K CHAUBEY
ADVOCATES
352/C-1B MUNIRKA
NEW DELHI-110067
9354793708

PLACE: NEW DELHI

DATED: 20.11.2023