1

IN THE HIGH COURT OF DELHI AT NEW DELHI

CIVIL ORIGINAL WRIT JURISDICTION
WRIT PETITION (CIVIL) NO. ………..OF 2024

IN THE MATTER OF:

CAPTAIN DEEPAK KUMAR … PETITIONER
VERSUS
ELECTION COMMISSION OF INDIA …RESPONDENT
INDEX

S.NO DESCRIPTION PAGE

NO.
1. Listing Proforma A1
2. Index 1
3. Memo of Parties 2
4. Notice of Motion and Proof of Service 3-3B
5. Urgent Application 4
6. Court Fees and Court fees Voucher Rs. 100.00 5
7. Synopsis and List of Dates 6-9
8. WRIT PETITION FILED UNDER ARTICLE 226 OF THE 10-21
CONSTITUTION OF INDIA, TO ISSUE A WRIT OF
MANDAMUS OR CERTIORARI OR ANY OTHER
NATURE SEEKING RELIEF AS PRAYED ALONGWITH
AFFIDAVIT.
9. ANNEXURE-P1 A Copy of The ID cards alongwith
Aadhar cards and the Pilot license of petitioner.
10. ANNEXURE-P2 A copy of the application filed with the
ECI, along with annexures.
11. APPLICATION FOR GRANT OF EXEMPTION FROM
FILING DIM/ILLEGIBLE/HANDWRITTEN/TYPED
/COPIES OF ANNEXURE.

Place: New Delhi. Filed By:

Date: 24.05.2024..
Deepak Kumar,
Petitioner, In Person,
H.No. 817, VPO Barahi,
Tehsil Bahadur Garh, District Jhajjar,
Haryana-124507.
 2
IN THE HIGH COURT OF DELHI AT NEW DELHI
CIVIL ORIGINAL WRIT JURISDICTION
WRIT PETITION (CIVIL) NO. ………..OF 2024

IN THE MATTER OF:

CAPTAIN DEEPAK KUMAR … PETITIONER
VERSUS
ELECTION COMMISSION OF INDIA …RESPONDENT

MEMO OF PARTIES
BETWEEN

1. Captain Deepak Kumar

S/o Sh. Phool Kumar,
H.No. 817, VPO Barahi,
Tehsil Bahadur Garh, District Jhajjar,
Haryana-124507.
…PETITIONER

VERSUS

1. Election Commission of India,

Through Chief Election Commissioner,
Nirvachan Sadan,
Ashoka Road, New Delhi-110001.
.
…RESPONDENT
Place: New Delhi. Filed By:
Date: 24.05.2024..
Deepak Kumar,
Petitioner, In Person,
H.No. 817, VPO Barahi,
Tehsil Bahadur Garh, District Jhajjar,
Haryana-124507.
 3
IN THE HIGH COURT OF DELHI AT NEW DELHI
CIVIL ORIGINAL WRIT JURISDICTION
WRIT PETITION (CIVIL) NO. ………..OF 2024

IN THE MATTER OF:

CAPTAIN DEEPAK KUMAR … PETITIONER
VERSUS
ELECTION COMMISSION OF INDIA …RESPONDENT

NOTICE OF MOTION
TAKE NOTICE that the accompanying writ petition may be listed before court
on 24.05.2024 in the Hon’ble High Court of Delhi or so soon thereafter as may
be convenient to the Hon’ble court.

Place: New Delhi. Filed By:

Date: 24.05.2024.
Deepak Kumar,
Petitioner, In Person,
H.No. 817, VPO Barahi,
Tehsil Bahadur Garh, District Jhajjar,
Haryana-124507.
 4
IN THE HIGH COURT OF DELHI AT NEW DELHI
CIVIL ORIGINAL WRIT JURISDICTION
WRIT PETITION (CIVIL) NO. ………..OF 2024

IN THE MATTER OF:

CAPTAIN DEEPAK KUMAR … PETITIONER
VERSUS
ELECTION COMMISSION OF INDIA …RESPONDENT

URGENT APPLICATION

TO,
THE REGISTRAR,
Hon’ble HIGH COURT OF DELHI,
NEW DELHI.

Respected Sir,

1. The petitioner herein prayed this application to be treated as urgent one

as The urgency of the petition arises from that the Candidate against whom
the petition is filed is seeking votes on the basis in the general election of
2024 on the basis of false oath to the allegiance to the Indian State when his
acts do not reflect the same and the candidate is being projected as a Prime
Minister Candidate by the Major National Political Part Bhartiya Janta Party
commonly known as BJP.

2. Additionally, UNION OF INDIA and its Sponsored Actors involvement in

discriminatory practices amounting to constitutionally prohibited
"UNTOUCHABILITY" against a schedule caste petitioner.
Filed By:

DATE: 24.05.2024. PETITIONER

PLACE: NEW DELHI. THROUGH
PETITIONER IN PERSON
ADDRESS: H.NO. 817, VPO BARAHI,
TEHSIL BAHADUR GARH,
DISTT. JHAJJAR,HARYANA-124507.
M. …………….,
EMAIL: I…………………@GMAIL.COM
 5
IN THE HIGH COURT OF DELHI AT NEW DELHI
CIVIL ORIGINAL WRIT JURISDICTION
WRIT PETITION (CIVIL) NO. ………..OF 2024

IN THE MATTER OF:

CAPTAIN DEEPAK KUMAR … PETITIONER
VERSUS
ELECTION COMMISSION OF INDIA …RESPONDENT
COURT FEES

Date: 24.05.2024.. Through Petitioner in Person

Place: New Delhi. Address: H.No. 817, Vpo Barahi,
Tehsil Bahadur Garh, Distt. Jhajjar,Haryana-124507.
 6
SYNOPSIS
This petition under Article 226 of the Constitution of India is filed by humble
Petitioner, seeking the disqualification of candidate Narender Modi from
contesting or being a member of the Lok Sabha from the Varanasi constituency
for the 2024 general elections. The Narender Modi, the current Prime Minister
of India, submitted a false oath or affirmation to bear true faith and allegiance to
the Constitution of India. The petitioner confirms and the Hon’ble high Court
can call upon records from the file of CP of Delhi Police as well to confirm to
the fact that Narender Modi has influenced the Delhi Police to avoid registering
a case against him and his accomplices concerning serious allegations of
corruption and national security threats, including an attempted but he election
schedule for the General Elections in India for 2024 was declared by the
Election Commission of India on March 29, 2024. The elections are to be
conducted in seven phases starting from April 11, 2024, and ending on May 19,
2024, with the counting of votes scheduled for May 23, 2024.unsuccessful
planning to cause fatal crash of Flight AI 459 on 08.07.2018.

That the proposed candidate Narender Modi of Varanasi constituency for the
2024 general elections had been known to all such allegations against him and
is influencing the police and legal departments to not proceed in accordance
with law and is charged assisting the accused persons remaining away from the
lawful scrutiny and screening the accused of criminal conspiracy due to his post
of prime minister of India.

That the Narender Modi had made a false Oath or affirmation which otherwise
must be made after the nomination paper has been submitted to RO. Oath or
affirmation must be made before the commencement of the date of scrutiny of
nominations, i.e., latest by mid-night of the date preceding the date of scrutiny.
Thus the Narender Modi is acting contrary to law and is screening a national
level criminal conspiracy hatched by his accused accomplices namely
Thawarchand Gehlot and IFCI VCFSC, IL&FS Trust Company Limited and
Air India Limited being the prominent accused.

That the accused Accomplices of Narender Modi had attempted an anti national
act of terrorism and in attempt to kill the undersigned as Pilot In command of
Flight No. AI 459 of08.07.2018 the accused Accomplices of Narender Modi
had attempted to kill all the innocent occupants of Flight No. AI 459 of
08.07.2018. Thereby this amounts to a Terror attack on the democratic and
sovereignty of India thus amounting to destabilize the national and internal
security of INDIAN STATE and Government of INDIA.
 7
The Candidate for Varanasi constituency for the 2024 general elections
Narender Modi had submitted before the returning officer a false oath or
affirmation to bear true faith and allegiance to the Constitution of India. Modi
and his accomplices are accused of screening the criminal conspiracy where the
accused accomplices Candidate Modi attempted to destabilize national security
by planning a fatal crash of Flight AI 459 of 08.07.2018. Candidate Modi has
obstructed the investigation of serious allegations against him and his
accomplices. The petitioner for being a schedule caste is made to face an
economic and social boycott orchestrated by Modi's accomplices. Candidate
Modi is abusing the post of Prime Minister of India to shield himself and his
accomplices from legal scrutiny.

Through This Petition the petitioner seeks the disqualification of Narender

Modi from contesting or being a member of the Lok Sabha from the Varanasi
constituency for the 2024 general elections.

Candidate Narender Modi's candidature for making a false oath should be

investigated in a effective time bound manner and if proven to be false then
Candidate Narender Modi should be debarred from holding any public office
until proven not guilty by a respective investigation agency or court and
Cancellation of his official powers should be undertaken or reassessed in view
of allegations of destabilizing the national Security while screening the Accused
of Incident related to 08.07.2018 and 19.10.2019. Any other order deemed fit
and proper in the circumstances of the case causing debarment of such
candidate would be in the interest of national Security.

Hence, the petitioner is before this Hon’ble Court seeking invocation of his
fundamental rights which has been scrapped by the Prime Minister of India and
his accomplices.
 8
Brief List of Dates
08.07.2018 An incident involving an reported by petitioner as Pilot In
Command, but unsuccessful, attempt to cause a fatal crash of
Flight AI 459 of 08.07.2018 and kill the occupants, along with
the petitioner as the pilot in command, took place. On
11.07.2018 petitioner was declared sick while the petitioner was
not and petitioner was not allowed to operate discharge his
duties due to influence of PM Narender Modi and His
Accomplices.

19.10.2019 An unlawful simulator training session at Air India Limited's

Central Training Establishment took place. The accomplices of
Hardeep Singh Puri and Air India Limited, who are being
supported by PM Narendra Modi, are screening the said
unlawful person from identification. This unlawful person is
suspected of being trained to wage a war against the nation. Due
to reporting of this incident entire service records of the
petitioner is destroyed by N Chandershekhran and his
accomplices and Air India Limited thereby amounting to commit
Unlawful offenses against a Civil Aviation Facility of Govt. of
India.

12.01.2020 A request to register FIR against the Air India Limited's CMD
for causing economic and social boycott of the petitioner was
emailed to CP of Delhi Police.

29.07.2022 Under the instruction of PM Narendra Modi, the Home Minister

of India, Amit Shah, and the then Commissioner of Delhi Police,
IPS Rakesh Asthana, hatched a criminal conspiracy against the
petitioner to take away the petitioner’s life by abusing the
resources of the state. This conspiracy is also not being
investigated due to the influence of PM Narendra Modi and his
accomplices despite being in knowledge of Hon’ble Court of
LD. ASJ-05,PHC, New Delhi and LD. MM-01 (Mahila),SE,
Saket Courts.

15.03.2024 Petitioner filed a Complaint case which subsequently came up

before the Ld. MM-09, Dwarka Courts, New Delhi regarding an
attempted but unsuccessful planning to cause fatal crash of
Flight AI 459 on 08.07.2018.

21.03.2024 The petitioner filed a police complaint for the registration of an

FIR before the IGI Police of Delhi. However, the complaint
could not be registered due to the involvement of Narender
 9
Modi, along with his colleagues Amit Shah, Thawar Chand
Gehlot, Hardeep Singh Puri, Jyotiraditya Scindia, and others, as
accused. Narender Modi and Amit Shah, and their accomplices
such as CP of Delhi Police etc. abusing their dominant positions
as the Prime Minister and Home Minister of India, have been
influencing and directing the IGI Police, under whose
jurisdiction various offenses against the petitioner occurred, to
not register any crime or offense committed against the
petitioner, his family, or his dependent children.

29.03.2024 Election schedule for the General Elections in India for 2024 was
declared by the Election Commission of India. The Election to
be conducted in various phases and the result to be declared in
June 2024. However, the Respondent only can provide most
accurate and up-to-date information about this fact.

08.07.2018-

Till Date Narender Modi and his accomplices are obstructing

investigations and legal proceedings of cases against them and
preventing any FIRs from being registered, despite the charges
of cognizable offenses. This obstruction also involves falsely
submitting an affidavit before the Election Commission to get
his candidature approved and maintain a clean image to woo
innocent voters who are unaware of PM Narender Modi’s
criminal antecedents. Only after a thorough investigation and a
clean chit from the authorities can he claim to be innocent and
free from any accusations.

17.05.2024 Application seeking disqualification of Narender Modi as a

candidate for the Varanasi Lok Sabha seat in the 2024 general
elections was sent to the respondent but the same was neither
acknowledged nor being adequately replied by the respondent or
the Hon’ble President of India.

24.05.2024 Hence, this Petition.

 10
IN THE HIGH COURT OF DELHI AT NEW DELHI
CIVIL ORIGINAL WRIT JURISDICTION
WRIT PETITION (CIVIL) NO. ………..OF 2024

IN THE MATTER OF:

CAPTAIN DEEPAK KUMAR … PETITIONER
VERSUS
ELECTION COMMISSION OF INDIA …RESPONDENT

TO,

HON'BLE THE CHIEF JUSTICE OF HON’BLE HIGH

COURT OF DELHI AND HIS COMPANION JUSTICES OF
THE HON'BLE HIGH COURT OF DELHI

THE HUMBLE PETITION OF THE PETITIONER NAMED

ABOVE;

WRIT PETITION FILED UNDER ARTICLE 226 OF THE

CONSTITUTION OF INDIA, TO ISSUE A WRIT OF
MANDAMUS OR CERTIORARI OR ANY OTHER NATURE
FOR SEEKING RELIEF AS PRAYED.

MOST RESPECTFULLY SHOWETH:

1. That petitioner is a law abiding, peaceful citizen of India and resided at the
address mentioned in the petition.

FACTS OF THE CASE IN BRIEF:

2. That on 17.05.2024 Petitioner sent a application to ECI seeking the

disqualification of candidate Narender Modi from Varanasi Lok Sabha Seat
but till date no such acknowledgement of action taken report has been
received by the petitioner.

3. That Any person aspiring to be Member of Lok Sabha/ Legislative

Assembly, whether by election or by nomination, must be qualified and
must not be disqualified under the Constitution OR under any law for such
membership (RPA 1951).

4. That one such qualification requires that the candidate aspiring to be

Member of Lok Sabha must take Oath or affirmation to bear true faith and
allegiance to the Constitution of India.
 11
5. That the person named Narender Modi who had filed nomination from BJP
Party to be Member of Lok Sabha seat from Varanasi Loksabha
Constituency had submitted a false and fake take Oath or affirmation to
bear true faith and allegiance to the Constitution of India whereby the
person named Narender Modi is influencing the Delhi police to not register
a case against himself and his accomplices whereby the allegations are
serious, anti national and the attempt to destabilize the internal and national
security of India whereby the accused accomplices of Narender Modi are
remaining at large due to him being the prime Minister of India whereby
the said accused accomplices of him are accused of the attempt to cause a
fatal crash to Flight AI 459 of 08.07.2018 in which the petitioner was the
pilot in command.

6. That the petitioner had filed the police complaint on 21.03.2024 and the
complaint in the concerned Hon’ble Court of Ld.MM-09,Dwarka Courts,
New Delhi around 15.03.2024.

7. That the proposed candidate had been known to all such allegations against
him and is influencing the police and legal departments to not proceed in
accordance with law and is charged assisting the accused persons
remaining away from the lawful scrutiny and screening the accused of
criminal conspiracy due to his post of prime minister of India.

8. That the Narender Modi had made a false Oath or affirmation which
otherwise must be made after the nomination paper has been submitted to
RO. Oath or affirmation must be made before the commencement of the
date of scrutiny of nominations, i.e., latest by mid-night of the date
preceding the date of scrutiny. Thus the Narender Modi is acting contrary
to law and is screening a national level criminal conspiracy hatched by his
accused accomplices namely Thawarchand Gehlot and IFCI VCFSC,
IL&FS Trust Company Limited and Air India Limited being the prominent
accused.

9. The Accused Accomplices of Narender Modi namely Thawarchand Gehlot

and IFCI VCFSC,IL&FS Trust Company Limited and Air India Limited
being the prominent accused attempted to kill the complainant as soon as
the undersigned reported a multi crore corruption syndication being run by
then Union Minister of Social Welfare and Empowerment Thawarchand
Gehlot and IFCI VCFSC, IL&FS Trust Company Limited and many others.

10. That the accused Accomplices of Narender Modi had attempted an anti
national act of terrorism and in attempt to kill the undersigned as Pilot In
command of Flight No. AI 459 of 08.07.2018 the accused Accomplices of
Narender Modi had attempted to kill all the innocent occupants of Flight
No. AI 459 of 08.07.2018. Thereby this amounts to a Terror attack on the
democratic and sovereignty of India thus amounting to destabilize the
national and internal security of INDIAN STATE and Government of
INDIA.
 12
11. That while being considered as Candidate for the Varanasi Loksabha Seat
the candidate Narender Modi is to abide by and owe allegiance to the
constitution like every other Indian. This includes influencing the
investigation agencies for not probing a matter and influencing them to not
register a sensitive case against him or his accused accomplices in the
matter of Flight No. AI 459 of 08.07.2018 whereby the police complaint at
IGI Police Station, terminal-3 was registered by the complainant
(undersigned) on 21.03.2024 but due to the influence of this person named
Narender Modi and his accused accomplices Amit Shah, Jyotiraditya
Sindhia, Nirmala Sitharaman, Thawarchand Gehlot etc. the police is not
registering the case and is causing the disappearance of evidences with the
assistance of m/sTata group of companies and N Chander shekhran of M/s
Air India Limited. A copy of the same can be obtained from the above said
police station or Ministry of Civil Aviation or through the file of case no.
584/24 filed before Ld. MM-09, Dwarka Courts, New Delhi. A copy of
Status report submitted before DL.ASj-02,Dwarka Courts ,New Delhi
which is filed by ACP of IGIA is submitted as Annexure herein as Proof of
the same.

12. That fact is that the Narender Modi does not owe his allegiance to the
constitution of India and is abusing his post of prime Minister of India to
not let an case register against himself and his accused accomplices who
are accused of attempting to cause fatal crash to flight AI 459 of
08.07.2018 and this proves the fact that being the Prime Minister of India
the candidate Narender Modi had been obstructing the fundamental rights
of legal remedy as well as other fundamental rights of the Schedule Caste
complainant (undersigned) due to his hatred for the schedule caste
complainant and thus proving to be acting contrary to the OATH Narender
MODI otherwise must prove to the letter and spirit of his affidavit
submitted before the returning officer of Varanasi Loksabha Seat.

13. That the candidate Narender Modi and his accused accomplices are also
screening a UNLAWFUL person who had been unlawfully trained in a
simulator session on 19.10.2019 that took place in the simulator facility of
Air India limited and due to the reporting of abovesaid two incidents
calling it to be strategic decision the Narender Modi convinced his cabinet
colleagues to sell of Air India Limited to his accused accomplice M/s Tata
Group of companies. Whereby the candidate Narender Modi knew that the
sale of Air India limited is nothing but a proceed of crime. Due the facts
that numerous offences had been committed against the schedule caste
complainant and the one of which (Economic and Social Boycott of
schedule caste employee by CMD of AIL) was reported on 12.01.2020 and
the decision to sell of Air India limited was taken on immediately.

14. That the Narender Modi is also accused of influencing Accused Air India
limited to takeaway complainant’s employment and service in violation of
article 311 of Indian Constitution just before its privatization after ensuring
cancellation his means of employment i.e. his pilot license thereby
 13
confirming his anti constitutional behavior and of being habitual offender.
All such thing happened as complainant denied complying with the sexual
desires of his accused accomplices Hardeep Singh Puri and IAS Rakesh
Sarwal and were also reporting the corruption of Pradhan mantra Kisan
Sampda Yojna For being a beneficiary as proprietor of M/s Deepak Dairy
to the amount of 9.75 Crore Rupees Subsidy. The Sextortion, Extortion
amount and the land accused accomplices of Candidate Narender Modi
sought also proves the criminal nature of such persona and such accused
without being proven as not guilty should be debarred from or not allowed
to submit or to take such false oath before the Returning officer or any
other authority of Indian Government and thus should be debarred for
making false oath of allegiance to the Indian Constitution as the Candidate
Narender Modi is Prime Minister of India and is not a ordinary citizen of
India. Candidate Narender Modi is also required to prove his innocence for
the facts that the said candidate is being designated as next Prime Minister
of India by his influential and one of the biggest political party of India
(named BJP) registered with election commission of India.

15. That the candidate Narender Modi and His accused Accomplice are rogue
elements influencing the day to day life of petitioner and his minor
children and also threatening the petitioner and his minor children to
defame them as the accused Accomplice of candidate Narender Modi had
obtained the semi naked picture of the complainant’s minor children with
the help of police personals, IPS Rakesh Asthana, Ex. CJI UU Lalit,
Pataiala House Court’s Session Judge Devender Kumar jangala,, saket
Court Judge Sangmitra and many others.

16. That the Narender Modi for the purpose of remaining at large and Proving
himself being free of charge with the help of prostitute supplier IDAS Arti
Bhatnagar who was previously deployed in Narender Modi’s Security had
falsely implicated the complainant in false vigilance enquiry and through
Amit shah And IPS Rakesh Asthana in a bogus FIR just prior to removing
the complainant form his lawful public employment and just days before
selling the Air India Limited shares to the m/s Tata Group of Companies.
The Candidate Narender Modi very consciously had chosen his accused
accomplices IAS Rajiv bansal (a kidnapper who had been hiding the
complainant’s minor child with the help of Ex. CJI UU lalit and Devender
jangala and Saghmitra etc. in residence of Narender Modi itself).

17. That IAS Rajiv bansal now CEO of MyIT and is removing those essential
information otherwise required to be furnished on websites.

18. Thus all these facts are some of the facts of offences the accused Narender
Modi is committing and also had been accused of submitting false
allegiance to the constitution of India While not letting a FIR registered
against himself and his accused accomplices. The candidate Narender Modi
is accused of many offences committed against the complainant and his
minor children and is being remaining at large due to his abuse of power as
prime minister of India and nothing else.
 14

19. That the candidate Narender Modi and his accused Accomplices. Amit
Shah, Jyotiraditya Sindhia, Nirmala Sitharaman, Thawarchand Gehlot,
Vijay Sampla, IPs Rakesh Astahana, Ex. CJI U U lalit, Devender jangala,
Sanghmitra etc. does not disavowal of terrorism which was to be spread
through the fatal crash of Flight AI 459 of 08.07.2018 and also have no
interest towards to protect the integrity of the nation.

20. That not just public servants such as sitting MPs designated as Prime
Minister of India but every occupant of public office such as Judges also is
required to swear and also adhere to an oath of allegiance to the
constitution so that the integrity of Indian Constitution can be upheld.
However since the candidate Narender Modi being the Prime Minister of
India had adopted illegal means thus had caused defamation to the entire
nation and thus had falsely submitted before the returning officer that the
candidate Narender Modi bear true faith and allegiance to the Constitution.

21. That Candidates Narender Modi, Amit Shah, Jyotiraditya Sindhia also in
public rallies are lying that he will uphold the constitutional provisions of
all citizen of India where he through his government had scraped all the
fundamental rights of complainant and his minor children as well. Narender
Modi, Amit Shah, Jyotiraditya Sindhia and their accomplices are a criminal
element will be detrimental for Indian Society at large. Thus is to be
declared a rogue element as well as unqualified for submitting false Oath or
affirmation to bear true faith and allegiance to the Constitution as being
candidate for Varanasi Loksabha Seat for the general election of year 2024.

22. That the candidate Narender Modi, Amit Shah, Jyotiraditya Sindhia and
their Accused accomplices are hatching much bigger criminal conspiracy
and the petitioner have reason to believe that due the fact the candidate
Narender Modi being the Prime Minster of India is causing the CCTV
Footage of Simulator Session of 19.10.2019 that took place at Central
Training establishment of Air India Limited (while it was State
Instrumentality) is being destroyed or screened as the Narender Modi and
His accused accomplices are planning to wage a war against India and also
has been or is under any acknowledgement of allegiance or adherence to a
foreign State. Otherwise being a Honest Indian Citizen and that too holding
the post of Prime Minister of India the said Candidate Narender Modi
cannot obstruct the free and fair investigation of the allegation raised by the
undersigned and the CCTV footage of the incident cannot be destroyed by
the IAS Arun Kumar Ex. Dg of DGCA and/or IAS Vikram dev Dutt the
present DG Of DGCA and/or IAS rajiv Bansal and/or Ashwini Lohani
and/or IAs Pardeep Kharolaand/or IDAS Arti Bhatnagar and/or RS Sandhu
v amitabh Singh and/or Styender Mishraand/or Jyotiraditya M. Scindia and
/or Hardeep singh Puri and /or Gen. (Dr.) V. K. Singh(Retd.) and/or
Thawarchand Gehlot and/or IAS Vumlunmang Vualnam Etc.
 15
23. Thus due to the above said fact that the offence of training a Unlawful
person in simulator facility of Air india Limited on 19.10.2019, causing the
fabrication of service records of the complainant ( a Lawful Public Servant)
had been continuing because of the fact that candidate Narender Modi and
his accused accomplices are under any acknowledgement of allegiance or
adherence to a foreign State and they are attempting to first kill the
complainant through such means which otherwise would be called a lawful
manner with the help of UU lalit ( An Hon’ble Ex. CJI) who is managing
the unlawful acts of these accused persons lawfully behind the door.

24. Thus this allegiance or adherence to a foreign State of candidate Narender

Modi also proves that the candidate Narender Modi is not qualified to state
such false oath and also is unqualified of being selected or contesting the
Lok sabha seat of Varanasi in general elections2024. This also proves that
the candidate Narender Modi had taken a false oath of allegiance to the
constitution of India and has no intention to uphold its sovereignty and
integrity according to the format laid down in the Third Schedule of the
constitution thus had taken the said false oath with known dishonest
intention before any such person as authorized by the Election Commission
of India.

25. It is also worthwhile to examine how many times Candidate Narender

Modi, Amit Shah, Jyotiraditya Sindhia etc. since 08.07.2018 has officially
subscribed to this or similar types of false oath till date.

26. That each term since 08.07.2018 though would have required Candidate
Narender Modi, Amit Shah, Jyotiraditya Sindhia etc. to subscribe to the
oath of allegiance to the constitution but Candidate Narender Modi Amit
Shah, Jyotiraditya Sindhia etc. never had complied with this constitutional
requirement as can be seen against the allegation raised against Candidate
Narender Modi and Amit Shah, Jyotiraditya Sindhia etc. for the reason no
such free and fair investigation had been taken place under influence of
Candidate Narender Modi‘s as Prime Minister of India till date. Candidate
Narender Modi committed himself to uphold the sovereignty and integrity
of India before entering the office of Prime minister of India but every
occasion after 08.07.2018 he had acted contrary to what he had stated in his
OATH The Candidate Narender Modi‘s as Prime Minister of India acting
like SS Rathore of Haryana (famous for Minor Victim’s harassment Case
took place in Haryana ) is continuously punishing the complainant for not
complying to proceed with satisfying the sexual desires of his accused
accomplices IAS Rakesh Sarwal and Hardeep Singh Puri as the said sexual
desires of his accused accomplices of Candidate Narender Modi‘s as Prime
Minister of India remains unfulfilled the Candidate Narender Modi had
been acting in contravention of Constitution of india and had taken away all
the fundamental rights like the rights to equality, life and liberty and the
right to approach the High Court of Delhi from the schedule caste
petitioner.
 16

27. That Accused candidate Narender Modi, Amit Shah, Jyotiraditya Sindhia
being prime minister of India is managing the registry of Hon’ble High
Court of Delhi through UU lalit ( an Ex. CJI) and is not letting the
Schedule caste petitioner’s case to be listed for hearing without him
attending the registry in person thereby candidate Narender Modi being
prime minister of India with known dishonest intentions is causing many
and great hardship to the in this otherwise stated a independent and free
nation. And Since these fundamental rights of Schedule caste petitioner are
breached by the actions or omissions of state functionary candidate
Narender Modi being prime minister of India and otherwise should be
protected by this candidate Narender Modi being prime minister of india it
would easily confirm that what candidate Narender Modi as candidate of
Varanasi Loksabha Seat had submitted is an false Oath and candidate
Narender Modi, Amit Shah, Jyotiraditya Sindhia also had falsely swear
allegiance to the constitution of India when they intended to not do so and
had not been doing so in previous times as well at present times also.

28. That the efforts put in by Candidate Narender Modi as Prime Minister of
India to screen those accused who had planned to cause the fatal crash of
Flight AI 459 on 08.07.2018 and the efforts put in by Candidate Narender
Modi as Prime Minister of India to screen those accused who had been
screening the unlawfully trained person in sensitive CAT3B training on
19.10.2019, constitute a breach of allegiance to the constitution by
Candidate Narender Modi.

29. Hence. This Petition is filed before this Hon’ble Court.

30. That this Petition contains 21 Signed pages.

QUESTION OF LAW:

i. Whether the utterance of a written oath or affirmation before the

Returning Officer or any other public servant or authority makes
it a valid oath and affirmation for a candidate (not an ordinary
one, but one who was previously the Prime Minister of India and
is also proposed to be the next Prime Minister of India by a
major political party, BJP) who is accused of destabilizing
national security and screening those accused of wanting to wage
a war against the nation.

ii. Whether the candidate Narender Modi (Being PM of India) and

his accomplices are above the law or the provisions of CR.P.C.,
against whom no FIR can be registered despite evidentiary proof
of their involvement in organized crime against the nation, as
well as against the schedule caste petitioner.
 17

iii. Whether the candidate Narender Modi and his accomplices had
conspired to replace the Indian Penal Code, 1860; Code of
Criminal Procedure, 1898; and the Indian Evidence Act, 1872
into Bharatiya Nyaya Sanhita, Bharatiya Nagrik Suraksha
Sanhita and the Bharatiya Sakshya Adhiniyam that will come
into effect from July 1, 2024 to evade their own prosecution;

iv. iv. Whether the oath and affirmations to the Constitution of India
permit or approve of a Prime Minister of India's actions to
commit sins and take away the petitioner’s fundamental rights,
such as the rights to equality, life, liberty, and the right to
approach the Hon’ble Court to seek legal remedies. If such
actions are indeed approved, then what are the conditions or
circumstances that make the oath and affirmation true rather than
false?

GROUNDS:

A. Because there is no reason whatsoever to not entertain a complaint filed

for registration of FIR against candidate Narender Modi and his
accomplices under relevant provisions of law when the offence reported
is of cognizable in nature;.

B. Because The Station House Officer (SHO) of Palam Domestic Airport

and the SHO of IGIA Airport Police Station terminal-3 of Delhi police,
while acting contrary to law, continue to hold their positions under the
influence of Candidate Narender Modi. This influence is obstructing the
process of justice against the scheduled caste petitioner, resulting in a
failure to protect the fundamental rights of the petitioner. This failure
demonstrates Candidate Narender Modi's inability to abide by the
Constitution of India as the Prime Minister of India and as an elected
representative of the Lok Sabha from 2019 to 2024.

C. Because Candidate Narender Modi is also accused of destruction of

evidence by influencing and playing an active role in the selling process
of Air India Limited, whereby Air India Limited is accused of canceling
the schedule caste petitioner’s pilot license and ratings by fabricating his
records of service under the influence of Candidate Narender Modi and
his accused accomplices who were in power as Prime Minister of India.
Under such circumstances, there is ample reason to believe that such a
person, as a candidate, is prone to making false oaths and pledges of
allegiance to the Indian state, which he does not intend to abide by and
all such oath and allegiance to Indian State and Constitution thus are
 18
false an denture making candidate ineligible to contest the said
elections.

D. Because the Sextortion, Extortion amount and the land accused

accomplices of Candidate Narender Modi sought also proves the
criminal nature of such persona and such accused without being proven
as not guilty should be debarred from or not allowed to submit or to take
such false oath before the Returning officer or any other authority of
Indian Government and thus should be debarred for making false oath of
allegiance to the Indian Constitution as the Candidate Narender Modi is
Prime Minister of India and is not a ordinary citizen of India. Candidate
Narender Modi is also required to prove his innocence for the facts that
the said candidate is being designated as next Prime Minister of India by
his influential and one of the biggest political party of India (named
BJP) registered with election commission of India.

E. Because the candidate Narender Modi and his accused Accomplices.

Amit Shah, Jyotiraditya Sindhia, Nirmala Sitharaman, Thawarchand
Gehlot, Vijay Sampla, IPs Rakesh Astahana, Ex. CJI U U lalit,
Devender jangala, Sanghmitra etc. does not disavowal of terrorism
which was to be spread through the fatal crash of Flight AI 459 of
08.07.2018 and also have no interest towards to protect the integrity of
the nation.

F. Because not just public servants such as sitting MPs designated as Prime
Minister of India but every occupant of public office such as Judges also
is required to swear and also adhere to an oath of allegiance to the
constitution so that the integrity of Indian Constitution can be upheld.
However since the candidate Narender Modi being the Prime Minister
of India had adopted illegal means thus had caused defamation to the
entire nation and thus had falsely submitted before the returning officer
that the candidate Narender Modi bear true faith and allegiance to the
Constitution.

G. Because candidate Narender Modi, Amit Shah, Jyotiraditya Sindhia also

in public rallies are lying that they will uphold the constitutional
provisions of all citizen of India where he through his government had
scraped all the fundamental rights of complainant and his minor children
as well. Candidates Narender Modi, Amit Shah, Jyotiraditya Sindhia are
a criminal element will be detrimental for Indian Society at large. Thus
is to be declared a rogue element as well as unqualified for submitting
false Oath or affirmation to bear true faith and allegiance to the
Constitution as being candidate for Varanasi Loksabha Seat for the
general election of year 2024.

H. Because the fact the candidate Narender Modi being the Prime Minster
of India is causing the CCTV Footage of Simulator Session of
19.10.2019 that took place at Central Training establishment of Air
India Limited (while it was State Instrumentality) is being destroyed or
 19
screened as the Narender Modi and His accused accomplices are
planning to wage a war against India and also has been or is under any
acknowledgement of allegiance or adherence to a foreign State.
Otherwise being a Honest Indian Citizen and that too holding the post of
Prime Minister of India the said Candidate Narender Modi cannot
obstruct the free and fair investigation of the allegation raised by the
petitioner and the CCTV footage of the incident cannot be destroyed by
his accused accomplices public servants.

I. Because allegiance or adherence to a foreign State of candidate

Narender Modi, Amit Shah, Jyotiraditya Sindhia also proves that the
candidate Narender Modi is not qualified to state such false oath and
also is unqualified of being selected or contesting the Lok sabha seat of
Varanasi in general elections2024. This also proves that the candidate
Narender Modi had taken a false oath of allegiance to the constitution of
India and has no intention to uphold its sovereignty and integrity
according to the format laid down in the Third Schedule of the
constitution thus had taken the said false oath with known dishonest
intention before any such person as authorized by the Election
Commission of India.

J. Because Since sexual desires of previously Prime Minister of India but

now Candidate Narender Modi‘s accused accomplices remains
unfulfilled the Candidate Narender Modi had been acting in
contravention of Constitution of india and had taken away all the
fundamental rights like the rights to equality, life and liberty and the
right to approach the High Court of Delhi from the schedule caste
complainant. This is not what is desired or directed by the constitution
of India.

K. Because the efforts put in by Candidate Narender Modi as Prime

Minister of India and Amit Shah As Home Minister of India And
Jyotiraditya Sindhia as Civil aviation Minister of India as to screen those
accused who had planned to cause the fatal crash of Flight AI 459 on
08.07.2018 and the efforts put in by Candidate Narender Modi as Prime
Minister of India and Amit Shah As Home Minister of India And
Jyotiraditya Sindhia as Civil aviation Minister of India to screen those
accused who had been screening the unlawfully trained person in
sensitive CAT3B training on 19.10.2019, constitute a breach of
allegiance to the constitution by Candidate Narender Modi and Amit
Shah And Jyotiraditya Sindhia.

L. Because the candidates in question are seasoned politicians who have

previously served as Chief Ministers or Ministers at both the state and
central levels. They are presently serving in significant roles such as
Prime Minister, Home Minister, and Civil Aviation Minister of India,
thus they are not ordinary citizens of India.
 20
PRAYER:

In view of the facts and circumstances of the facts of the case this Hon’ble
Court may please to :-

I. Make an Enquiry if the OATH or affirmation submitted by

Candidate Narender Modi, Jyotiraditya Sindhia, Amit Shah
before the respective returning officer to become eligible for the
general election of lok sabha 2024 is a valid Oath or affirmation;

II. Examine if through this petition the Hon’ble Court is empowered

to Make an Enquiry if the OATH or affirmation undertaken by
Thawarchand Gehlot as Hon’ble Governor of Karnataka State is
also an valid Oath or affirmation;
And
If, the Hon’ble Court find it a fit case then pass an direction to
the respective authority to consider the verification for such Oath
and Affirmation under taken by Thawarchand Gehlot as Hon’ble
Governor of Karnataka State for establishing the fact of it being
true to the sense it was meant for;

III. Issue direction to respondent to Set Aside Candidature of

Candidate Narender Modi from Varanasi Loksabha Seat,
candidature of Amit Shah from Gandhi nagar Seat and Candidate
Jyotiraditya Sindhia’s Candidature from Guna loksabha Seat
from which these candidate are contesting by submitting a false
oath and affirmations;

IV. Issue direction to respondent to establish the fact that the CCTV
footage of 19.10.2019 of Simulator facility of State
Instrumentality Air India Limited is not destroyed
AND IF DESTROYED THEN

Pass direction to the respondent to debar the candidate Narender

Modi, Amit Shah and Jyotiraditya Sindhia from making such
unlawful and false oath again until candidate Narender Modi,
Amit Shah and Jyotiraditya Sindhia is proven not guilty by any
Hon’ble Court of Law.

Place: New Delhi. Filed By:

Date: 24.05.2024.
Deepak Kumar,
Petitioner, In Person,
H.No. 817, VPO Barahi,
Tehsil Bahadur Garh, District Jhajjar,
Haryana-124507. M.No. …………...
Email: i……………….@gmail.com
 21
IN THE HIGH COURT OF DELHI AT NEW DELHI
CIVIL ORIGINAL WRIT JURISDICTION
WRIT PETITION (CIVIL) NO. ………..OF 2024

IN THE MATTER OF:

CAPTAIN DEEPAK KUMAR … PETITIONER
VERSUS
ELECTION COMMISSION OF INDIA …RESPONDENT
AFFIDAVIT
I, CAPTAIN Deepak Kumar, S/o Sh., Phool Kumar, Aadhar No. ……………..
aged 43 years R/o H.No. 817,VPO Barahi, Tehsil Bahadur Garh, District
Jhajjar, Haryana-124507 New Delhi, the Petitioner above named do hereby
solemnly affirm and state as under:

1. That I am the Petitioner in the present Writ petition and am well

conversant with the facts and circumstances of the present case and as
such am competent to depose by way of this affidavit.

2. That I have drafted the contents of the accompanying writ petition

Pages 1 to ___, which have been drafted by me and state that all the
facts stated therein are true and correct to the best of knowledge
acquired through legal books and judgments.

3. That the annexure are true copies of their respective originals.

DEPONENT

VERIFICATION

Verified at New Delhi on this 23rd day of May 2024 That the contents of the
above affidavit are true and correct to my knowledge, that no part of it is false
and that nothing material has been concealed therefrom.

DEPONENT
 22
IN THE HIGH COURT OF DELHI AT NEW DELHI
CIVIL ORIGINAL WRIT JURISDICTION
WRIT PETITION (CIVIL) NO. ………..OF 2024
IN THE MATTER OF:
CAPTAIN DEEPAK KUMAR … PETITIONER
VERSUS
ELECTION COMMISSION OF INDIA …RESPONDENT

APPLICATION FOR GRANT OF EXEMPTION FROM FILING

OF DIM/ ILLEGIBLE/HANDWRITTEN/CERTIFIED/TYPED
COPIES OF ANNEXURE.
MOST RESPECTFULLY SHOWETH:
1. That the accompanying application has been filed by the petitioner in the
aforementioned writ petition the contents whereof may be read as part of
the accompanying application and the same is not being repeated herein for
the sake of brevity.

2. That the petitioner has filed certain annexure which are uncertified and
without 4-inch margins and therefore craves leave from this Hon’ble court
to permit him to file the same alongwith the aforementioned writ petition.

3. That the petitioner undertakes to file the original and certified of the
aforementioned documents as and when ordered by this Hon’ble Court.

4. That the present application is genuine and bonafide and the same may be
allowed in the interest of justice.

PRAYER:-
It is most respectfully prayed before this Hon’ble Court that this Hon’ble Court
may be graciously pleased to:
A. Exempt the petitioner from filing the typed copies of the dim/ illegible/
handwritten/certified annexure and also exempt the petitioner from
maintaining 4-inch margin in certain annexure; and allow the present
application; and

B. Pass such any other order/ directions as this Hon’ble Court may deem
fit and proper in the facts and circumstances of this case.

Date: 24.05.2024.. Through Petitioner in Person

Place: New Delhi. Address: H.No. 817, VPO Barahi,

Tehsil Bahadur Garh, Distt. Jhajjar,Haryana-124507.
M. ……….., Email: …………….@gmail.com
 23
IN THE HIGH COURT OF DELHI AT NEW DELHI
CIVIL ORIGINAL WRIT JURISDICTION
WRIT PETITION (CIVIL) NO. ………..OF 2024

IN THE MATTER OF:

CAPTAIN DEEPAK KUMAR … PETITIONER
VERSUS
ELECTION COMMISSION OF INDIA …RESPONDENT
AFFIDAVIT
I, CAPTAIN Deepak Kumar, S/o Sh., Phool Kumar, Aadhar No. …………aged
43 years R/o H.No. 817,VPO Barahi, Tehsil Bahadur Garh, District Jhajjar,
Haryana-124507 New Delhi, the Petitioner above named do hereby solemnly
affirm and state as under:

1. That I am the Petitioner in the present APPLICATION FILED

ALONGWITH Writ Petition and am well conversant with the facts and
circumstances of the present case and as such am competent to depose
by way of this affidavit.

2. That I have drafted the contents of the accompanying APPLICATION

Pages 1 to ___, which have been drafted by me and state that all the
facts stated therein are true and correct to the best of knowledge
acquired through legal books and judgments.

3. That the annexure are true copies of their respective originals.

DEPONENT

VERIFICATION

Verified at New Delhi on this 24th day of May 2024 That the contents of the
above affidavit are true and correct to my knowledge, that no part of it is false
and that nothing material has been concealed therefrom.

DEPONENT