IN THE COURT OF MS______; LD. M.M. MAHILA COURT; NORTH DIST., ROHINI COURT, DELHI.

CR. CASE NO. _____ OF 2023.

IN THE MATTER OF: -

_________________                                             : COMPLAINANT

VERSUS

________________                                                    : RESPONDENTS

N.D.O.H.:_______-

APPLICATION FOR AND ON BEHALF OF THE APPLICANT / COMPLAINANT FOR ISSUANCE OF NECESSARY DIRECTION TO THE PROTECTION OFFICER AND RESPONDENTS.

MOST RESPECTFULLY SHOWETH :-

1.       That the aforesaid Complaint has been filed by the complainant against the Respondents and the same is fixed for __________.

2.       That on___________ both the parties along with State was appeared this Hon’ble Court and direction has been issued to the Protection Officer to visit the house _________ along with both the parties on ________ at _____ PM also directed to SHO to render necessary assistance to Protection Officer carrying out the exercise.

3.       That in terms of the said order, Applicant along with their counsels duly reached the spot at __PM as mentioned in the said order, however the Protection Officer didn’t come. After waiting for long period of time, the applicant contacted the concerned Police Station where such Protection Officer is posted, however it was informed to the applicant that no official communication has been received regarding the said order from the Hon’ble Court. On …… Applicant again moved the Application for direction to Protection Officer for compliance of the order dated _________ passed by this Hon’ble Court and same was allowed vide order dated ………..

4.       That on _______ Protection Officer came to the house at _________ along with both the parties, where Protection Officer and Applicant were only allowed to check the room in front of the balcony and the room next to it. It is pertinent to mention that the said entire exercised were videographed by the Protection Officer. 

5.       That the Applicant and Protection Officer have checked the drawing room area and the kitchen and in drawing room drawer Applicant has found her aadhar card. Applicant got her Aadhar Card, but her passport not found because Protection Officer and applicant have not allowed to check other rooms of the said matrimonial house.

6.       It is submitted that Protection Officer and Applicant were not allowed by the respondent to check the terrace room and the guest room, few articles of her are found in the house which are captured in the video, Passport of Applicant is still inside the house as she could only check few rooms. Applicant has apprehension that her passport might be there in the other remaining rooms which were not allowed to the Applicant and Protection Officer by the Respondent.

4.       That the Applicant seeks the permission before this Hon’ble Court to kindly allow the Protection Officer and Applicant along with Respondent to check the other rooms of the said matrimonial house to get her passport with necessary assistance to Protection Officer in carrying out the said search exercise. That the present application is bonafidely and in the interest of justice.

PRAYER:-

          In view of the facts and circumstances made above it is therefore respectfully prayed that this Hon’ble Court may kindly allow the present application and necessary direction may kindly be issued to the Protection Officer and fresh date and time may be given for the purpose of collecting the Passport of the Applicant from _____________ along with necessary assistance to Protection Officer, in the interest of justice.

Any other and further relief which this Hon’ble Court deem fit and necessary in the circumstances explained above, may also be passed in favour of the Applicant.

APPLICANT/COMPLAINANT

DELHI

DATED                 THROUGH

ADVOCATE

__________

IN THE COURT OF MS. _______; LD. M.M. MAHILA COURT; NORTH DIST., ROHINI COURT, DELHI.

CR. CASE NO. ______ OF 2023.

IN THE MATTER OF: -

________________                                               : COMPLAINANT

VERSUS

_________________                                                   : RESPONDENTS

AFFIDAVIT

I, ________ W/o Sh._______, presently residing at Flat No ____________, do hereby solemnly affirm and declare as under:

1.              That the deponent is the Complainant in the above noted case and well conversant with the facts of the case and competent to swear the present affidavit.

2.              That the contents of above accompanying application has been drafted by my counsel under my instructions and the contents of the same are true and correct to my knowledge and nothing material has been concealed.

DEPONENT

VERIFICATION:

Verified at New Delhi on ___ this day November, 2023 that the facts stated in the above affidavit are true to my knowledge. No part of the same is false and nothing material has been concealed. 

DEPONENT