IN THE COURT OF SH. ANSHUMAN, LD.

JUDICIAL
MAGISTRATE 1ST CLASS,
GURUGRAM DISTRICT COURTS
DV. 354 OF 2023

IN THE MATTER OF:

DIPALI MAKIN …COMPLAINANT

VERSUS

AMIT CHAWLA & ORS. …RESPONDENTS

INDEX

S. NO. PARTICULARS PAGE NO.

1. APPLICATION FOR DIRECTIONS
TO PAY MEDICAL BILL(S) OF
MASTER NIKSHAY
2. ANNEXURE A1
TRUE COPY OF ‘DISHCHARGE
SUMMARY’
3. ANNEXURE A2
TRUE COPY OF ‘INPATIENT BILL’
4. ANNEXURE A3(COLLY.)
CASH BILLS DATED 29.03.2024

COMPLAINANT
THROUGH
NEW DELHI:
DATE: KARTIKEYA MUDGIL
& PRASHANT BHARDWAJ
Advocate.
Ch No. 332, Lawyers Chamber
Block, Dwarka District Court,
Sector-10, Dwarka, New Delhi-110075
Mob: 9971885087
Email: adv.kartikeyamudgil@gmail.com
 IN THE COURT OF SH. ANSHUMAN, LD. JUDICIAL
MAGISTRATE 1ST CLASS,
GURUGRAM DISTRICT COURTS
DV. 354 OF 2023

IN THE MATTER OF:

DIPALI MAKIN …COMPLAINANT

VERSUS

AMIT CHAWLA & ORS. …RESPONDENTS

URGENT APPLICATION ON BEHALF OF COMPLAINANT

FOR ISSUANCE OF DIRECTIONS TO RESPONDENT NO. 1
REGARDING PAYMENT OF MEDICAL BILLS OF
MASTER NIKSHAY.
MOST RESPECTFULLY SHOWETH:
1. That the aforementioned matter is pending adjudication
before this Hon’ble Court and the same is fixed for
03.06.2024.
2. That the Complainant and the Respondent No. 1 are the
parents of Master Nikshay Makin, who is in the custody of
the Complainant since the separation in August, 2020. It is
pertinent to mention that the Complainant has been bearing
all the expenses of her son solely by herself and despite
several requests having been made to the Respondent No. 1,
to her utter shock and dismay, the Respondent No. 1 has
refused to provide any sort of financial relief to the
Complainant or their son namely Master Nikshay Makin.
3. That the said child is suffering from Insulin Dependent
Diabetes Mellitus, ie. Type-I Diabetes, owing to which he is
extremely dependent on usage of costly medicines. It is
 pertinent to mention that on 29.03.2024, the said son of the
Complainant had to be admitted in hospital due to diabetes-
related disease(s). It is further submitted that the Complainant
has been solely bearing all the medical expenses of the said
son and that the Respondent No. 1 has refused to bear the
even the medical expenses of their child. It is submitted that
the said son was discharged on 01.04.2024. The true copy of
‘Dishcharge Summary’of Master Nikshay is annexed
herewith as Annexure A1.
4. That due to the son of the Complainant suffering and Diabetes
Type I and other related diseases, the Complainant had to
resign from her job in the month of December, 2023, in order
to take care of the health of the said son.
5. That the Complainant since leaving her job for taking care of
her son has been facing financial issues in as much as having
to take further loans from near relatives in order to manage
the medical and educational expenses of her son.
6. That the episode wherein Master Nikshay was admitted to
‘Aarvy Healthcare Superspeciality Hospital’ owing to
vomiting, kidney pain and high blood sugar has costed the
Complainant upwards of Rs. 78,446/- (Rupees Seventy-Eight
Thousand Four Hunded and Forty-Six Only) wherein the
Inpatient Bill was Rs. 76,654/- (Seventy-Six Thousand Six
Hundred Fifty-Four Only) and two Cash Bills dated
29.03.2024 were Rs. 525/- (Rupees Five Hundred Twenty-
Five Only) plus Rs. 1,267/- (Rupees Twelve Hundred Sixty-
Seven Only), respectively. The ‘Inpatient Bill’ of Master
Nikshay for the period of 29.03.2024 to 01.04.2024 is
 annexed herewith as Annexure A2 and Cash Bills dated
29.03.2024 are annexed herewith as Annexure A3(Colly.).
7. That the Respondent No. 1, despite several requests by the
Complainant, refused to share the existing the health
insurance policy details of Master Nikshay, and therefore, the
Complainant had to rely on paying cash bills using her
savings and some loans taken from her father.
8. That the Complainant is facing a financial crisis owing to the
aforementioned medical and educational expenses of her son
Nikshay. It is submitted that in case the present application is
not allowed, the son of the Complainant will be deprived of
necessary future medicine required to sustain a normal life.

PRAYER:
It is, therefore, most respectfully prayed that this Hon’ble
Court may kindly be pleased to direct the Respondent No. 1 to
reimburse the medical bills of Rs. 78,446/- (Rupees Seventy-Eight
Thousand Four Hundred and Forty-Six Only) to the Complainant, in
the interests of justice.

COMPLAINANT
THROUGH
NEW DELHI:
DATE: KARTIKEYA MUDGIL
& PRASHANT BHARDWAJ
Advocate
Ch No. 332, Lawyers Chamber
Block, Dwarka District Court,
Sector-10, Dwarka, New Delhi-110075
Mob: 9971885087
Email: adv.kartikeyamudgil@gmail.com