SYNOPSIS

The petitioners are permanent residents of above said address

and being citizens of India they are entitle to invoke extra

jurisdiction of this Hon’ble court and therefore seeking the

indulgence of this Hon’ble Court for directing respondents No. 2

and 3 to protect the life and personal liberty of the petitioners and

further directing respondent No. 4 to 7 not to interfere with the

liberty and lives of petitioners or harass them in any manner

against their wishes and to their detriment by using force as there

is a threat from respondent No. 4 to 7 or anybody else to the

petitioners.

11.01.1999 Petitioner no. 2 born.

04.03.2003 Petitioner no.1 born

12.05.2024 Parents of petitioner no.1 pressurize her for marriage

and Petitioner no. 1 disclosed about her relationship.

14.05.2024 Both the petitioner ran away and solemnized

marriage

15.05.2024 Petitioners made representation to police authorities

Hence the present petition

Place:- Chandigarh
Date:- 16.05.2024

(Mohit Kakkar)
Advocate
Counsel for the petitioners
P/628/17 NOR : PH 223105
IN THE HON’BLE HIGH COURT FOR THE STATES OF THE PUNJAB
AND HARYANA AT CHANDIGARH
CRM(W) No. ______________ of 2024
Anjali Kumari and another ...Petitioners
Versus
State of UT, Chandigarh and others ...Respondents

Application under section 482 Cr.P.C seeking

exemption from filing local identity proof, in the

interest of justice.

RESPECTFULLY SHOWETH:-
1. That the Applicants/petitioners are filing the accompanying

petition seeking protection to their life and liberty from private

respondents, who are family member of petitioner no. 1. Both of

the petitioners belongs to Uttar Pradesh, India and the petitioner

no. 2 is working in Industrial Area at Chandigarh from last one and

half year and petitioner no. 1 solemnized marriage with petitioner

no. 2 and since then the petitioners were living at House No. 295,

Ram Darbar, Phase 1, Chandigarh, regarding the said fact, the rent

deed is annexed with the petitioner as Annexure P-1.

2. That the applicants/petitioners are unable to change their

addresses on identity proof, because they are living under threats

from the private respondents and are undertakes they will change

their addresses soon.

It is therefore, respectfully prayed that the

present application may kindly be allowed and
petitioners may kindly be exempted from filing their
local identity proofs, in the interest of justice.

Place:- Chandigarh
Date:- 16.05.2024

(Mohit Kakkar)
Advocate
Counsel for the petitioners
P/628/17 NOR : PH 223105
 IN THE HON’BLE HIGH COURT FOR THE STATES OF THE PUNJAB
AND HARYANA AT CHANDIGARH
Criminal Writ Petition ______________ of 2024
Anjali Kumari and another ...Petitioners
Versus
State of UT, Chandigarh and others ...Respondents

Affidavit of Anil Kumar, age about 25 Years, born on 11.01.1999, son of

Sh. Ashok Kumar, resident of Village Rukunpur, Post Surhurpur,
Ambedkar Nagar, Uttar Pradesh at present residing at House No. 295,
Ram Darbar, Phase 1, Chandigarh..
(Aadhar Card No. 9075 3846 1877) Phone No. 97818 59426
I the above named deponent do hereby solemnly affirm and
declare as under:

1. That the statement of facts made in the para of accompanying

application are true and correct to my knowledge and as per the
documents placed on record.

2. That the deponent and is fully conversant with the facts the
accompanying application is prepared by the counsel under the
instructions of the deponent and no such or similar petition has
earlier been filed by the petitioners either in this Hon’ble Court or
in the Hon’ble Supreme Court of India or before Ld.
Sessions/District Courts.

3. That the deponent has annexed his Aadhar card with the petition

and the details mentioned in memo of parties i.e. Aadhar card

number and mobile number is true and correct.

Place:- CHANDIGARH

DATED: DEPONENT
VERIFICATION
Verified that the contents of para No. 1 to 3 of my above said
affidavit are true and correct to my knowledge and belief and
same has been explained to deponent in Simple Punjabi. Nothing
material has been concealed therein.

Place:- CHANDIGARH

DATED: DEPONENT
 IN THE HON’BLE HIGH COURT FOR THE STATES OF THE PUNJAB AND
HARYANA AT CHANDIGARH
Criminal Writ Petition ______________ of 2024

MEMO OF PARTIES
1. Anjali Kumari, age about 21 Years, born on 04.03.2003, wife of Anil
Kumar, daughter of Sh. Deepak Kumar, resident of Gra, Beili, Post
Rampur Katharawan, Azamgarh, Uttar Pradesh at present residing at
House No. 295, Ram Darbar, Phase 1, Chandigarh.
(Asadhar Card No. 4043 0689 0568) Phone No. 97818 59426

2. Anil Kumar, age about 25 Years, born on 11.01.1999, son of Sh. Ashok
Kumar, resident of Village Rukunpur, Post Surhurpur, Ambedkar Nagar,
Uttar Pradesh at present residing at House No. 295, Ram Darbar, Phase
1, Chandigarh..
(Aadhar Card No. 9075 3846 1877) Phone No. 97818 59426

Whether any petitioners declared PO : No.

...Petitioners
Versus
1. State of UT, Chandigarh through Home Secretary, Department of Home,

Law & Justice, 2nd Floor, Chandigarh Secretariat, Sector 9, Chandigarh

2. Senior Superintendent of Police, Chandigarh,

3. S.H.O Police Station Phase 1, Industrial Area, Chandigarh.

4. Deepak Kumar s/o Jainath Ram (Father of Pt. No. 1), resident of Batala
Road, Banke Bihari Gali, Ram Bali Chowk, Amritsar, Punjab.
5. Basant Lal son of Jainath Ram, (Uncle of Pt No.1), R/o Ram Darbar, Phase
2, Chandigarh.
6. Suman Bala wife of Umesh, (Aunt of Pt. No. 1), R/o House No. 679, Ram
Darbar, Phase 2, Chandigarh.
7. Suraj son of Lal Chand, (Maternal Uncle of Pt. No. 1), R/o Kirawal Nagar,
New Delhi, India.
...Respondents
Place:- Chandigarh
Date:- 16.05.2024

(Mohit Kakkar)
Advocate
Counsel for the petitioners
P/628/17 NOR : PH 223105
 Criminal Writ Petition under Articles 226 of the

Constitution of India for issuance of an appropriate Writ,

Order or Direction in the nature of mandamus directing the

respondents No. 2 and 3 to protect the life and personal

liberty of the petitioners from the hands of respondents No.

4 to 7 further directing the respondent’s No. 2 and 3 not to

allow/let respondent No. 4 to 7 or anybody else to interfere

with the life and liberty of the petitioners or to harass them

in any manner against the wishes of the petitioners or to

cause any detriment to the petitioners in any manner and

for issuance of any other appropriate order or direction to

which this Hon’ble Court may deem fit and proper in the

facts and circumstances of the case as made out hereunder.

RESPECTFULLY SHOWETH:

1. That the petitioners are permanent residents of above said address and

being citizens of India they are entitle to invoke extra jurisdiction of this

Hon’ble court and therefore seeking the indulgence of this Hon’ble Court

for directing respondents No. 2 and 3 to protect the life and personal

liberty of the petitioners and further directing respondent No. 4 to 7 not

to interfere with the liberty and lives of petitioners or harass them in any

manner against their wishes and to their detriment by using force as

there is a threat from respondent No. 4 to 7 or anybody else to the

petitioners.

2. That the petitioners knew each other for the last about 1 years and

having likings for each other and wanted to marry with each other, when

they disclosed about their relations and desire to their respective family

members then they got agitated over the relationship between the

petitioners. Both the petitioners requested family members and relatives

 more particularly to respondent no. 4 to 7 to solemnize their marriage

but respondents no. 4 to 7 and other relatives did not agree for the

marriage of petitioners because the family members of petitioner no.1

were desirous to get petitioner no. 1 marry to a person of their choice

without taking the consent of petitioner no. 1. It is important to state

herein that the petitioners were having no child from their relationship

and having no immovable or movable properties in their names.

3. That it would be relevant to mention herein that both the petitioners

belongs to different Caste as petitioner no. 1 belongs to Schedule Caste

and Petitioner no. 2 belongs to Backward Caste and are educated as the

Petitioner no. 1 is graduated and is unemployed and having no earning

and petitioner no. 2 is 12th passed and is making Electrical Panel Board

at Industrial Area, Chandigarh and is earning Rs. 15,000/- Per Month and

from last one and half year the petitioner no. 2 is residing at House No.

295, Ram Darbar, Phase 1, Chandigarh and regarding the said fact, the

rent agreement is annexed herewith as ANNEXURE P-1. Aadhar Cards of

petitioners are annexed herewith as ANNEXURE P-2 AND P-3.

4. That since the family members of petitioner No. 1 wanted to forcibly

marry her with the boy of their choice and as such petitioners jointly

decided to marry with each other after running away from their homes

and accordingly they have solemnized marriage on 14.05.2024 as per

Hindu Rights and Rituals at Pracheen Pashupati Nath Shiv Mandir

Society, Panchkula. The Marriage Certificate and photographs evidencing

the same are annexed as ANNEXURE P-4 & ANNEXURE P-5.. After the

solemnization of marriage both the petitioners told about the same to

their respective family members, but they got furious and extended

threats to the petitioners to eliminate both the petitioners and have not

accepted the marriage of the petitioners but later on the family member
 of the petitioner no. 2 got agreed with the marriage of the petitioners but

the family members of petitioner no. 1 most probably respondent no. 4

to 7 are threatening the petitioners with dire consequences and since

then the petitioner are running pillar to post to save their life but no one

adhere their genuine grievance and accordingly the petitioner

approaching this Hon’ble Court by filing the present petition.

5. That since 14.05.2024, the respondent no. 4 to 7 searching the petitioner

no. 1 and now they came to know about the factum of marriage and

reached at Chandigarh and are searching the petitioners, petitioners on

being apprehended danger to their personal life and liberty are away

from their houses and have also moved representation dated 15.05.2024

to the police authorities in whose jurisdiction they would reside. Copy of

representation dated 15.05.2024 is annexed as ANNEXURES P-6.

6. That the petitioners have not committed any offence in the eyes of law as

they are having marriageable age and are able to know what is right and

wrong. They are innocent, law abiding and peace loving citizens and

wanted to choose their partners at their wishes.

7. That the marriage concept as emerging from the times back, it was a

trend in the society to marry the boy and girl according to wishes of their

parents. There used to be no concern about the likes and dislikes of the

boy and girl. Though in our modern times, with the growing of

Criminalization, the trend is increasing towards the likeness of both the

girl and boy, but still the approach of the society is constrained to marry

within their choice and any alteration to this is still not acceptable to the

parents of both the girl and boy.

8. That with the advancement in education and liberalization, though our

horizons have expanded, but when we talk of the marriage, still the

narrow mindedness rules the mind. It seems that though the society or
 people how much educated that are still find themselves to be bounded

by the system of caste-ism, religion, wealth, reputation of the family of

boy and girl and many other factors, which otherwise have nothing to do

with the marriage. In marriage, in our modern times, love marriages

have to face stiff opposition from all the sections of the society and their

marriage is not easily acceptable.

9. That both the petitioners were unmarried at the time of their marriage

on 14.05.2024 and it is the first marriage of both the petitioners.

10. That Article 21 of the Constitution of India envisages that no person shall

be deprived of his right to freedom and personal liberty except in

accordance with the procedure established by law.

11. That the main questions of law arises for the kind consideration of this

Hon’ble Court are as under:-

i) Whether the petitioners are entitled for the relief claimed in

the present petition in the light of facts and circumstances

of the present case?

ii) Whether the official respondents are duty bound to protect

the life & personal liberty of the petitioners who are having

immense threat to their lives?

iii) Whether the petitioners can be left remediless for the

redressal of their grievance i.e. for protection of their right

to life & liberty as provided under Article 21 of the

Constitution of India?

12. That the petitioners in the facts and circumstances of the present case

are not left with any other alternative remedy of appeal or revision

except to approach this Hon’ble Court by way of filing the present writ

petition under Article 226 of the Constitution of India.

13. That the petitioners have not earlier filed any such or similar writ

petition either in this Hon’ble Court or in the Hon’ble Supreme Court of

India.

It is, therefore, respectfully prayed that the entire record of

the case be called for and after perusing the same this Hon’ble Court may

be pleased to:-

(a) Issue an appropriate Writ, Order or Direction in the nature

of mandamus directing appropriate Writ, Order or

Direction in the nature of mandamus directing the

respondents No. 2 and 3 to protect the life and personal

liberty of the petitioners from the hands of respondent’s

No. 4 to 7 further directing the respondents No.2 and 3 not

to allow/let respondent No. 4 to 7 or anybody else to

interfere with the life and liberty of the petitioners or to

harass them in any manner against the wishes of the

petitioners or to cause any detriment to the petitioners in

any manner and for issuance of any other appropriate order

or direction to which this Hon’ble Court may deem fit and

proper in the facts and circumstances of the case as made

out hereunder;

OR

(b) In the alternative issuance of an appropriate writ, order or

direction in the nature of mandamus directing the official

respondent(s) to take action on the representation dated

15.05.2024 (P-6) and decide the same in a time bound

manner;
 (c) Issue any other appropriate writ, order or direction as this

Hon’ble Court may deem fit and proper in the facts and

circumstances of the present case;

(d) Filing of certified/original copies/true typed copies of

Annexure P-1 to P-6 may kindly be dispensed with;

(e) Filing of fair/legible/proper font/proper left hand

space/double space copies of Vernacular Annexures may be

dispensed with;

(f) dispense with the requirement of service of advance

notices;

Place:- Chandigarh

Date:- 16.05.2024

(Mohit Kakkar)
Advocate
Counsel for the petitioners
P/628/17 NOR : PH 223105
 IN THE HON’BLE HIGH COURT FOR THE STATES OF THE PUNJAB
AND HARYANA AT CHANDIGARH
Criminal Writ Petition ______________ of 2024
Anjali Kumari and another ...Petitioners
Versus
State of UT, Chandigarh and others ...Respondents
Affidavit of Anjali Kumari, age about 21 Years, born on 04.03.2003, wife
of Anil Kumar, daughter of Sh. Deepak Kumar, resident of Gra, Beili, Post
Rampur Katharawan, Azamgarh, Uttar Pradesh at present residing at
residing at House No. 295, Ram Darbar, Phase 1, Chandigarh.
(Aadhar Card No. 4043 0689 0568) Phone No. 97818 59426
I the above named deponent do hereby solemnly affirm and
declare as under:
1. That the statement of facts made in the para of accompanying
petition are true and correct to my knowledge and as per the
documents placed on record.

2. That the deponent and is fully conversant with the facts the
accompanying petition is prepared by the counsel under the
instructions of the deponent and no such or similar petition has
earlier been filed by the petitioners either in this Hon’ble Court or
in the Hon’ble Supreme Court of India or before Ld.
Sessions/District Courts.

3. That the deponent has annexed his Aadhar card with the petition
and the details mentioned in memo of parties i.e. Aadhar card
number and mobile number is true and correct.

Place:- CHANDIGARH

DATED: DEPONENT

VERIFICATION
Verified that the contents of para No. 1 to 3 of my above said
affidavit are true and correct to my knowledge and belief and
same has been explained to deponent in Simple Punjabi. Nothing
material has been concealed therein.

Place:- CHANDIGARH

DATED: DEPONENT
 IN THE HON’BLE HIGH COURT FOR THE STATES OF THE PUNJAB
AND HARYANA AT CHANDIGARH
Criminal Writ Petition ______________ of 2024
Anjali Kumari and another ...Petitioners
Versus
State of UT, Chandigarh and others ...Respondents
Affidavit of Anil Kumar, age about 25 Years, born on 11.01.1999, son of
Sh. Ashok Kumar, resident of Village Rukunpur, Post Surhurpur,
Ambedkar Nagar, Uttar Pradesh at present residing at House No. 295,
Ram Darbar, Phase 1, Chandigarh..
(Aadhar Card No. 9075 3846 1877) Phone No. 97818 59426
I the above named deponent do hereby solemnly affirm and
declare as under:

1. That the statement of facts made in the para of accompanying

petition are true and correct to my knowledge and as per the
documents placed on record.

2. That the deponent and is fully conversant with the facts the
accompanying petition is prepared by the counsel under the
instructions of the deponent and no such or similar petition has
earlier been filed by the petitioners either in this Hon’ble Court or
in the Hon’ble Supreme Court of India or before Ld.
Sessions/District Courts.

3. That the deponent has annexed his Aadhar card with the petition

and the details mentioned in memo of parties i.e. Aadhar card

number and mobile number is true and correct.

Place:- CHANDIGARH

DATED: DEPONENT
VERIFICATION
Verified that the contents of para No. 1 to 3 of my above said
affidavit are true and correct to my knowledge and belief and
same has been explained to deponent in Simple Punjabi. Nothing
material has been concealed therein.

Place:- CHANDIGARH

DATED: DEPONENT
 ANNEXURE P-2

Copy of Aadhar Card of Anjali Kumari /Petitioner No. 1

Logo Government of India

Photograph Anjali Kumari

DOB: 04.03.2003

Female

Bar Code

4043 0689 0568

XXX

Logo Unique Identification Authority of India

Address : D/O Deepak Kumar, Gram Beili, Post Rampur

Katharawan, Rampur Katharawan, Azamgarh, Uttar

Pradesh, 276201.

4043 0689 0568

XXX

CERTIFIED TO BE TRUE COPY

ADVOCATE
 ANNEXURE P-3

Copy of Aadhar Card of Anil Kumar/Petitioner No. 2

Photo Government of India

Anil Kumar

DOB : 11.01.1999

Male

9075 3846 1877

My Aadhar My Identity

Unique Identification Authority of India

Address : S/o Ashok Kumar, Gram Beili, Post Rampur Katharawan,

Rampur Katharawan, Azamgarh, Uttar Pradesh

CERTIFIED TO BE TRUE COPY

ADVOCATE
 ANNEXURE P-4

PRACHEEN PASHUPATI NATH SHIV MANDIR SOCIETY

Booth No. 228, MDC Sector 4, Panchkula, Haryana

Marriage Certificate

Certified that Bridegroom Anil Kumar having date of birth

11.01.1999 son of Ashok Kumar, resident of Village Rukunpur,

Post Surhupur, Amedkar Nagar, Uttar Prdesh now #295, Ram

Darbar, Phase 1, Chandigarh and Bride Anjali Kumari having date

of Birth 04.03.2003 daughter of Deepak Kumar, resident of Gram

Beili, Post Rampur Katharawan, Azamgarh, U P. performed

marriage on 14.05.2024 by Sonu Sharma as per Hindu Rights and

Rituals, we prayed for their better future, both are major and

accepted each other with their free wish.

Sd/- Anil Kumar Bridegroom

Sd/- Anjali Kumari Bride
Witness: Omparkash sd/-
Stamp Sd/-
Sonu Sharma

CERTIFIED TO BE TRUE TRANSLATION COPY

ADVOCATE
ANNEXURE P-4
True copy

Advocate
To
Senior Superintendent of Police, Chandigarh
PS Phase 1
Subject: Application for protection of life and liberty of the
applicants from 1. Deepak Kumar (Father), resident of Batala
Road, Banke Bihari Gali, Ram Bali Chowk, Amritsar, Punjab, 2.
Basant Lal (Uncle), R/o Ram Darbar, Phase 2, Chandigarh 3.
Suman Bala (Aunt), R/o House No. 679, Ram Darbar, Phase 2,
Chandigarh 4. Suraj (Maternal Uncle), R/o Kirawal Nagar, New
Delhi, India.
Sir,

With due respect applicant are submits herein:

1. That the applicant Anjali Kumari solemnized marriage with

Anil Kumar with her free will and consent on 14.05.2024 as

per Hindu Rights and Rituals against the wishes of her parents.

2. That the applicant is major and well known to the right and

wrongs decisions and has no committed any offence by

solemnizing marriage against the wishes of above said

persons.

3. That the applicant Anjali Kumari and Anil Kumar were known

to each other and were liking each other from last 1 years. The

applicant Anjali Kumari disclosed about their relationship to

the above said persons and desired their wishes to marry each

other at the time, when they pressurize her to solemnize

marriage as per their wishes, but the above said persons did

not agreed with the same because the above said persons

want to marry applicant Anjali Kumari with the boy of their

choice and accordingly the applicant ran away from their

respective houses and solemnized marriage.

4. That after getting the information about the solemnization of

marriage of applicants, the above said persons were become

ruthless and start threatening them with dire consequences

and still roaming in Chandigarh and the applicants

apprehension that they may cause harm on finding occasions.

5. That the above said persons are threatening the applicants

that they will kill them and the applicants want to reside at

House No. 295, Ram Darbar, Phase 1, Chandigarh and your

good self is the competent authority to hear the grievance.

It is therefore respectfully prayed that the above said

persons may kindly be called and legal action be taken against
them and protection be provide to us. We shall be highly
obliged.
Dated: 15.05.2024
Submitted by

Sd/-
(i) Anjali Kumari D/o Deepak
Kumar
(ii) Anil Kumar son of Sh. Ashok
Kumar,
Both residents of House No. 295,
Ram Darbar, Phase 1, Chandigarh.
M. No. 97818 59426
 IN THE HON’BLE HIGH COURT FOR THE STATES OF THE PUNJAB
AND HARYANA AT CHANDIGARH

Criminal Writ Petition ______________ of 2024

Anjali Kumari and another ...Petitioners
Versus
State of UT, Chandigarh and others ...Respondents
INDEX

SN Particulars Dates Page Cour

t Fee
Urgent Form 16.05.2024 --
Synopsis 16.05.2024 A
1. Application u/s 482 CrPC 16.05.2024 1
2. Affidavit in support 16.05.2024 2
3. Memo of Parties 16.05.2024 3
4. Criminal Writ Petition 16.05.2024 4-9
5. Affidavit of Pet. No.1 in support 16.05.2024 10
6. Affidavit of Pet. No.2 in support 16.05.2024 11
7. Annexure P-1 (Rent Deed) 15.05.2024 12-14
8. Annexure P-2 (Aadhar Card) ___ 15
9. Annexure P-3 (Aadhar Card) ___ 16
10. Annexure P-4 (Marriage Certificate) 14.05.2024 17
11. Annexure P-5 (Photographs) 14.05.2024 18
12. Annexure P-6 (Representation) 15.05.2024 19-20
13. Power of Attorney 16.05.2024 21
VERNACULARS/PHOTOCOPIES
14. Annexure P-2 (Aadhar Card) ___ 22
15. Annexure P-3 (Aadhar Card) ___ 23
16. Annexure P-4 (Marriage Certificate) 14.05.2024 24
Total court fee:- Rs.
Note:
i. That the main law points canvassed in this writ petition are
contained in Para No. 11 at pages 7.
ii. Act, Rule/Statute
a. Constitution of India.
iii. No caveat petition has been received by the petitioners.
iv. Any other similar Case: Nil
v. Advance copy has been supplied to State.
vi. Verification not required in Criminal Writ Petition.
vii. Mobile No. 9812222246
viii. NO MP/MLA/Former MLA, Minister is involved in the case.

Place:- Chandigarh
Date:- 16.05.2024

(Mohit Kakkar)
Advocate
Counsel for the petitioners
P/628/17 NOR : PH 223105
IN THE HON’BLE HIGH COURT FOR THE STATES OF THE PUNJAB
AND HARYANA AT CHANDIGARH

Criminal Writ Petition ______________ of 2024

Anjali Kumari and another ...Petitioners

Versus

State of UT, Chandigarh and others ...Respondents

Court Fees
______________________________________________ _____

______________________________________________ _____

Total Court Fees Rs. /-

Place:- Chandigarh
Date:- 16.05.2024

(Mohit Kakkar)
Advocate
Counsel for the petitioners
P/628/17 NOR : PH 223105
IN THE HON’BLE HIGH COURT FOR THE STATES OF THE PUNJAB

AND HARYANA AT CHANDIGARH

To

The Deputy Registrar (Judicial)

Punjab and Haryana High Court,

Chandigarh.

Criminal Writ Petition ______________ of 2024

Anjali Kumari and another ...Petitioners

Versus

State of UT, Chandigarh and others ...Respondents

Sir,

Will you kindly treat the accompanying petition as an

urgent one in accordance with the provisions of Rule 9, Chapter 3-A,

Rules and orders of the High Court Chandigarh, Volume – V.

The ground (s) of urgency are:-

Protection of Life and Liberty is prayed for.

Kindly list this matter before Vacation Roster

Yours faithfully

Place:- Chandigarh
Date:- 16.05.2024

(Mohit Kakkar)
Advocate
Counsel for the petitioners
P/628/17 NOR : PH 223105