IN THE COURT OF SH. YASHDEEP CHAHAL; LD. JMFC-01; PATIALA HOUSE COURTS; NEW DELHI.

CR. CASE NO. xxxx/2016.

IN THE MATTER OF:-

xxxxxxxxx           VERSUS    xxxxxxxxxxxxxxxxxx

FIR No. xxxxxxxxxxx
P.S.: xxxxxxxxxxxx

D.O.D.: xxxxxxxxxxxx

APPLICATION ON BEHALF OF THE COMPLAINANT / VICTIM SEEKING DIRECTION TO THE SHO TO REVERIFY OF THE FACTUM OF DEATH OF THE ACCUSED.

MOST RESPECTFULLY SHOWETH:-

1.                 That the present FIR case registered at P.S. Connaught Place against the Accused Xxxxxxxxxx before this Hon’ble Court and the said proceeding same was abated against the accused by this Hon’ble Court vide order dated xxxxxxxx.

2.                 That the applicant / complainant is the victim in the present FIR case and during the pendency of the present proceeding the complainant has been diligently pursuing the matter to ensure justice.

3.                 That during the proceedings, a report was filed by the SHO of PS Connaught Place stating that the accused, Xxxxxxxxxx, had expired, and the SHO submitted that he had verified the original death certificate of the accused.

4.                 That based on the report of the SHO, this Hon'ble Court, vide order dated xx.xx.xxxx, abated the proceedings against the accused and file be consigned to the record room after due compliance.

5.                 That the complainant has reasons to believe that the report filed by the SHO requires further scrutiny to ascertain:

a)     Whether the death certificate relied upon for verification pertains to the same person, i.e., the accused Xxxxxxxxxx.

b)    The process and the basis on which the SHO verified the death certificate and its authenticity.

c)     The contest and circumstances under which the verification of the accused's death was concluded by the SHO.

6.                 That the complainant/victim seeks reverification of the factum of the accused’s death as a matter of justice and transparency. It is imperative to ensure that the accused and the deceased referred to in the death certificate are one and the same person, particularly in light of the gravity of the allegations and the public interest involved.

7.                 That if it is found that the verification report is based on insufficient or inadequate grounds, it would amount to miscarriage of justice and would prejudice the rights of the complainant.

PRAYER:-

In view of the above, it is most respectfully prayed that this Hon’ble Court may kindly be pleased to:

a)     Direct the SHO of Police Station Connaught Place, to reverify the factum of the accused's death, including the authenticity of the death certificate and whether it pertains to the accused Xxxxxxxxxx.

b)    Call for a detailed report from the SHO explaining the steps undertaken during the initial verification process.

c)     Pass any other or further orders as may be deemed just and proper in the interest of justice.

It is prayed accordingly.

                                                APPLICANT/COMPLAINANT

DELHI                          THROUGH

DATED                                 

(xxxxxxxxxxxxx &

xxxxxxxxxxxx)

ADVOCATES

xxxxxxxxxxxxxxxx

New Delhi-110014.

Email Id: xxxxxxxxxxxxxxx

Mob No: xxxxxxxxxxxx