IN THE HIGH COURT OF DELHI AT NEW DELHI

CRL. WRIT PETITION No._____ OF XXXX.

IN THE MATTER OF :-

XXXXXXXXXXXXX                            : PETITIONER

VERSUS

XXXXXXXXXXXX                              : RESPONDENTS

FIR No. XXX/XXXX

                                      U/s.: 376/511/354 IPC,

P.S.: XXXXXXXX, Delhi

INDEX

          PETITIONER

                                                Through

Place: New Delhi

Dated:

XXXXXXXXX & ASSOCIATES

Advocate

XXX, XXXXXXXXXXXXX,

Delhi-XXXXXX

Mob.No. XXXXXXXXX

Email: xxxxxxxxxxx@yahoo.in

IN THE HIGH COURT OF DELHI AT NEW DELHI

CRL. WRIT PETITION No._____ OF 2022

IN THE MATTER OF:-

XXXXXXXXXXXXXX                          : PETITIONER

VERSUS

THE STATE & ANR.                            : RESPONDENTS

COURT FEE

Place: XXXXXXXX                                                         Petitioner

Dated:-XX.XX.XXXX              Through

Counsel for the Petitioner

XXXXXXXXX & Associates

XXX, XXXXXXXXXXXXX,

Delhi-XXXXXX

Mob.No. XXXXXXXXX

Email: xxxxxxxxxxx@yahoo.in

IN THE HIGH COURT OF DELHI AT NEW DELHI

CRL. WRIT PETITION No._____ OF 2022

IN THE MATTER OF:-

XXXXXXXXXXXXXX                          : PETITIONER

VERSUS

THE STATE & ANR.                            : RESPONDENTS

URGENT APPLICATION

To,

The Hon'ble Joint Registrar,

High Court of Delhi,

New Delhi

Sir/Madam,

Kindly treat the present petition as an urgent one as per the Rules of Hon'ble High Court of New Delhi. The Petitioner by virtue of the Present petition seeking Quashing of the FIR No. XXX/XXXX, U/s.: 376/511/354 IPC, P.S.: XXXXXX, Delhi.

The above-mentioned FIR was filed by the Respondent No.2 because of the misunderstanding and she has stated the same before Ld. M.M, Dwarka Courts, Delhi.

The ground of urgency is "Early Hearing of captioned petition for urgent hearing is sought for".

New Delhi

Date: XX.XX.XXXX

Filed by:

Counsel for the Petitioner

XXXXXXXXX & Associates

XXX, XXXXXXXXXXXXX,

Delhi-XXXXXX

Mob.No. XXXXXXXXX

Email: xxxxxxxxxxx@yahoo.in

IN THE HIGH COURT OF DELHI AT NEW DELHI

CRL. WRIT PETITION No._____ OF XXXX.

IN THE MATTER OF :-

XXXXXXXXXXXXX                            : PETITIONER

VERSUS

THE STATE & ANR.                            : RESPONDENTS

FIR No. XXX/XXXX

                                      U/s.: 376/511/354 IPC,

P.S.: XXXXXXXXXX,

             NOTICE OF MOTION

Sir/Madam,

The enclosed petition for quashing of F.I.R No. XXX/XXXX in the aforesaid matter is being filed on behalf of petitioner and the same is likely to be listed on XX.XX.XXXX or any other date thereafter, before the Hon’ble High court of Delhi at New Delhi.

Please acknowledge the receipt of complete set of the said petition, please notice according.

Thanking you.

PETITIONER

                                                Through

Place: New Delhi

Dated:

XXXXXXXXX & ASSOCIATES

Advocate

XXX, XXXXXXXXXXXXX,

Delhi-XXXXXX

Mob.No. XXXXXXXXX

Email: xxxxxxxxxxx@yahoo.in

IN THE HIGH COURT OF DELHI AT NEW DELHI

CRL. WRIT PETITION No._____ OF XXXX.

IN THE MATTER OF :-

XXXXXXXXXXXXXXX                                : PETITIONER

VERSUS

THE STATE & ANR.                                    : RESPONDENTS

FIR No. XXX/XXXX

                                      U/s.: 376/511/354 IPC,

P.S.: XXXXXXXXX,

MEMO OF PARTIES

MR. XXXXXXXXXXX

S/o Sh. XXXXXXXXX

R/o Flat No. X, XXXXXXX,

New Delhi-XXXXXX.                                           : PETITIONER

VERSUS

1. THE STATE (NCT OF DELHI)               

2. PROSECUTRIX

D/o Sh. XXXXXXXXXX

R/o H. No. XX, XXXXXXXXXX,

XXXXXX, Delhi.                                                 : RESPONDENTS

---------------------------------------------------------------------------------------

Place:                                                                                PETITIONER

:Through

Dated:

XXXXXXXXX & ASSOCIATES

Advocate

XXX, XXXXXXXXXXXXX,

Delhi-XXXXXX

Mob.No. XXXXXXXXX

Email: xxxxxxxxxxx@yahoo.in

IN THE HIGH COURT OF DELHI AT NEW DELHI

CRL. WRIT PETITION No._____ OF XXXX.

IN THE MATTER OF :-

XXXXXXXXXXXX                              : PETITIONER

VERSUS

THE STATE & ANR                             : RESPONDENTS

FIR No. XXX/XXXX

                                      U/s.: 376/511/354 IPC,

P.S.: XXXXXXXXX, Delhi

LIST OF DATES & EVENTS

XX.XX.XXXX                 A FIR No. XXXX/XXXX, U/s.: 376/511/354 IPC, P.S.: XXXXX, Delhi.

Statement of prosecutrix was recorded U/s 164 Cr.P.C before Ld. M.M, Dwarka Courts, Delhi.

XX.XX.XXXX                 Petitioner was granted regular bail from Ld. Session Judge, Dwarka Courts, Delhi. 

PETITIONER

                                                Through

Place: New Delhi

Dated:

XXXXXXXXX & ASSOCIATES

Advocate

X, XXXXXXXX,

Delhi-XXXXXX

Mob.No. XXXXXXXXXX

xxxxxxxxxxxxxxx@yahoo.in

IN THE HIGH COURT OF DELHI AT NEW DELHI

CRL. WRIT PETITION No._____ OF XXXX.

IN THE MATTER OF :-

MR. XXXXXXXXXXXX

S/o Sh. XXXXXXXXXX

R/o Flat No. X, XXXXXXX,

New Delhi-XXXXXX.                                           : PETITIONER

VERSUS

1. THE STATE (NCT OF DELHI)               

2. PROSECUTRIX

D/o Sh. XXXXXXXXXXXX

R/o H .No. XX, XXXXXXXX,

XXXXXXX, Delhi.                                               : RESPONDENTS

FIR No. XXX/XXXX

                                      U/s.: 376/511/354 IPC,

P.S.: XXXXXXXX,

CRIMINAL WRIT PETITION FILED BY THE PETITIONER UNDER ARTICLES 226 & 227 OF THE CONSTITUTION OF INDIA READ WITH SECTION 482 OF CODE OF CRIMINAL PROCEDURE FOR QUASHING OF THE PROCEEDINGS IN FIR BEARING No. XXXX/XXXX REGISTERED WITH POLICE STATION DWARKA SOUTH, DELHI, UNDER SECTION 376/511/354 OF INDIAN PENAL CODE.

MOST RESPECTFULLY SHOWETH :-

1.      That the Petitioner is law-abiding and senior citizen of India and has full faith in the administration of justice. That the Petitioner has sought to invoke the Extra-ordinary jurisdiction of this Hon’ble Court under Section 482 of the Code of Criminal Procedure for quashing of FIR No. XXXX/XXXX registered at Police Station: XXXXXXXXX, under Section 376/511/354 of Indian Penal Code, which was lodged by the prosecutrix / respondent no.2 against the petitioner.

          Copy of FIR bearing no. XXXX/XXXX is annexed to this petition as Annexure P-1.

2.      That the petitioner is aggrieved by FIR lodged by the prosecutrix / respondent no.2 at the Police Station: XXXXXX. By this petition, the petitioner is inter alia, seeking the quashing of the said FIR No. XXXX/XXXX and proceedings emanating there under;

3.      That the present petition has been filed by the Petitioner and the brief facts of the case, necessary for the disposal of the present petition are summoned up as under:-

3.1    It is alleged in the impugned FIR that the complainant works in the office the petitioner and on the date of alleged incident, the petitioner called to her cabin, molested her and attempted to rape her.

3.2    It is further alleged that the prosecutrix was inappropriately touched by the petitioner and the FIR was registered on XX.XX.XXXX, the petitioner was called by the IO for joining the investigation and when the petitioner reached at the police station to join the investigation, he was arrested on the same day and thereafter, he was sent to judicial custody and there is no specific allegations against the petitioner and he was falsely implicated by the prosecutrix.

3.2    That on XX.XX.XXXX, during the course of hearing of the bail application of the petitioner before the Ld. Session Judge-XX, South West Dwarka, the prosecutrix submitted that the allegations were no longer to be pursued by the later and statement of the complainant under Section 164 Cr.P.C was to the same effect and that the prosecutrix had rather represented it to be a case of misunderstanding.

3.3    That on XX.XX.XXXX, the Ld. Addl. Session Judge-XX, South West Dwarka was pleased to grant bail to the petitioner on the basis statement recorded under Section 164 Cr.P.C of the prosecutrix, whereas she stated that “she perceives no threats from the petitioner if he was to be released on bail”.

          True copy of Bail order dated XX.XX.XXXX granted by Ld. Session Judge-XX, South West Dwarka is annexed as Annexure P-2.

4.      That the impugned FIR had been lodged by the prosecutrix by misunderstanding between the employer (petitioner) and employee (prosecutrix) and the complainant submitted that the allegations were no longer to be pursued by the later statement recorded under Section 164 Cr.P.C to the same effect. 

5.      Aggrieved from the FIR registered against petitioner, petitioner is moving this petition seeking quashing of the FIR on the following amongst other grounds:-

- : G R O U N D S : -

A.      For that it is a settled principle of law that even otherwise there is no allegation against the petitioner and no material evidence has been filed against the petitioner, which would constitute an offence, and therefore the said FIR is liable to be quashed on this ground alone.

B.      For that it is submitted that the present complaint does not disclose any alleged offence committed by the petitioner as the prosecutrix submitted that the allegations were no longer to be pursued by the later and statement of the complainant under Section 164 Cr.P.C was recorded to the same effect and the prosecutrix had rather represented it to be a case of misunderstanding.

C.      For that statement recorded under Section 164 Cr.P.C of the prosecutrix, whereas she stated that “she perceives no threats from the petitioner if he was to be released on bail” vide order dated- XX.XX.XXXX before the Ld. Addl. Session Judge-XX, South West Dwarka, Delhi.

D.      For that the present FIR fails to show that the petitioner made any illegal act/statement to the complainant and in the statement recorded u/S 164 Cr.P.C before Ld. Magistrate, the respondent no.2 submitted that the FIR was registered with some misunderstanding. There is no material on record to show that the petitioner attempted to rape or inappropriately touched to the prosecutrix. None of the ingredients of Section 376/354 IPC is made out in the FIR.

E.      For that the present proceedings have been launched malafide and by the suppression of material facts. The complainant/respondent no.2 has deliberately suppressed the fact of material facts, which is the subject matter of the present FIR. Hence, the present FIR No. XXXX/XXXX under Section 376/511/354 IPC, Police Station: XXXXXXX, being an abuse of process of law ought to be quashed.

F.      For that, the present FIR being ex-facie malafide falls squarely within the scope of the judgment of the Hon’ble Supreme Court in the case of State of Haryana Vs. Bhajan Lal, reported in AIR 1992 SC 604 (para 107. and the petitioner is entitled to have the proceedings quashed on that ground as well).

G.      Because in the present case, no offence under Section 376/354 IPC is made out and in the present case there is no such allegation in the complaint. It is pertinent to mention that even if the contentions of the complainant are believed to be true, the present case does not fall in that preview.

H.      Because it has been held by the Hon’ble Supreme Court in case “K.R. Purushothaman Vs. State of Kerala” 2005 (12) SCC 631; that each one of the circumstances should be proved beyond reasonable doubt and such circumstances proved must form a chain of events from which the only irresistible conclusion is about the guilt of the accused which can be safely drawn and no other hypothesis of the guilt is possible. We respectfully agree with the law laid down in Navjot Sandhu’s case and K.R. Purushothaman’s case.

I.       Because it has been held by the Hon’ble Supreme Court in case “Gian Singh Vs. State of Punjab” in para 57, it has been held that the position that emerges from the above discussion can be summarized thus: the power of the High Court in quashing a criminal proceeding or FIR or complaint in exercise of its inherent jurisdiction is distinct and different from the power given to a criminal court for compounding the offences under Section 320 of the Code. Inherent power is of wide plenitude with no statutory limitation but it has to be exercised in accord with the guideline engrafted in such power viz; (i) to secure the ends of justice or (ii) to prevent abuse of the process of any Court. In what cases power to quash the criminal proceeding or complaint or F.I.R may be exercised where the offender and victim have settled their dispute would depend on the facts and circumstances of each case and no category can be prescribed. However, before exercise of such power, the High Court must have due regard to the nature and gravity of the crime. Heinous and serious offences of mental depravity or offences like murder, rape, dacoity, etc. cannot be fittingly quashed even though the victim or victim’s family and the offender have settled the dispute. Such offences are not private in nature and have serious impact on society. Similarly, any compromise between the victim and offender in relation to the offences under special statutes like Prevention of Corruption Act or the offences committed by public servants while working in that capacity etc; cannot provide for any basis for quashing criminal proceedings involving such offences. But the criminal cases having overwhelmingly and pre-dominatingly civil flavor stand on different footing for the purposes of quashing, particularly the offences arising from commercial, financial, mercantile, civil, partnership or such like transactions or the offences arising out of matrimony relating to dowry, etc. or the family disputes where the wrong is basically private or personal in nature and the parties have resolved their entire dispute. In this category of cases, High Court may quash criminal proceedings if in its view, because of the compromise between the offender and victim, the possibility of conviction is remote and bleak and continuation of criminal case would put accused to great oppression and prejudice and extreme injustice would be caused to him by not quashing the criminal case despite full and complete settlement and compromise with the victim. In other words, the High Court must consider whether it would be unfair or contrary to the interest of justice to continue with the criminal proceeding or continuation of the criminal proceeding would tantamount to abuse of process of law despite settlement and compromise between the victim and wrongdoer and whether to secure the ends of justice, it is appropriate that criminal case is put to an end and if the answer to the above question(s) is in affirmative, the High Court shall be well within its jurisdiction to quash the criminal proceeding.

J.       In R. Klayani Vs. Janak C. Mehta & Ors 2009 (1) SCC 516 wherein in para. no. 15 & 16 it was held as under:

"15. Propositions of law which emerge from the said decisions are:

(1) The High Court ordinarily would not exercise its inherent jurisdiction to quash a criminal proceeding and, in particular, a first information report unless the allegations contained therein, even if given face value and taken to be correct in their entirety, disclosed no cognizable offence. (2) For the said purpose the Court, save and except in very exceptional circumstances, would not look to any document relied upon by the defence.

(3) Such a power should be exercised very sparingly. If the allegations made in the FIR disclose commission of an offence, the Court shall not go beyond the same and pass an order 9 in favour of the accused to hold absence of any mens rea or actus reus.

(4) If the allegation discloses a civil dispute, the same by itself may not be a ground to hold that the criminal proceedings should not be allowed to continue."

It is furthermore well known that no hard and fast rule can be laid down. Each case has to be considered on its own merits. The Court, while exercising its inherent jurisdiction, although would not interfere with a genuine complaint keeping in view the purport and object for which the provisions of Sections 482 and 483 of the Code of Criminal Procedure had been introduced by the Parliament but would not hesitate to exercise its 13 jurisdiction in appropriate cases. One of the paramount duties of the Superior Courts is to see that a person who is apparently innocent is not subjected to persecution and humiliation on the basis of a false and wholly untenable complaint."

K.      For that regarding power and jurisdiction of this Court to entertain the present petition under Section 482 Cr.P.C., the Apex Court in the recent decisions in Prashant Bharti v. State of NCT of Delhi 2013 (2) AD (S.C.) 89" on 23.01.2013 has in a similar and identical case observed inter alia as under:-

"19. The proposition of law, pertaining to quashing of criminal proceedings, initiated against an accused by a High Court under Section 482 of the Code of Criminal Procedure (hereinafter referred to as "the Cr.P.C.") has been dealt with by this Court in Rajiv Thapar & Ors. vs. Madan La/ Kapoor (Criminal Appeal No...... of 2013, arising out of SLP (Crl.) no.4883 of 2008, decided on 23.1.2013) wherein this Court inter alia held as under:

22. The issue being examined in the instant case is the jurisdiction of the High Court under Section 482 of the Cr.P.C., if it chooses to quash the initiation of the prosecution against an accused, at the stage of issuing process, or at the stage of committal, or even at the stage of framing of charges. These are all stages before the commencement of the actual trial. The same parameters would naturally be available for later stages as well. The power vested in the High Court under Section 482 of the Cr.P.C., at the stages referred to hereinabove, would have far reaching consequences, inasmuch as, it would negate the prosecution's/complainant's case without allowing the prosecution/complainant to lead evidence. Such a determination must always be rendered with caution, care and circumspection. To invoke its inherent jurisdiction under Section - 482 of the Cr.P.C., the High Court has to be fully satisfied, that the material produced by the accused is such, that would lead to the conclusion, that his/their defence is based on sound, reasonable, and indubitable facts; the material produced is such, as would rule out and displace the assertions contained in the charges leveled against the accused; and the material produced is such, as would clearly reject and overrule the veracity of the allegations contained in the accusations levelled by the prosecution/complainant. It should be sufficient to rule out, reject and discard the accusations leveled by the prosecution/complainant, without the necessity of recording any evidence. For this the material relied upon by the defence should not have been refuted, or alternatively, cannot be justifiably refuted, being material of sterling and impeccable quality. The material relied upon by the accused should be such, as would persuade a reasonable person to dismiss and condemn the actual basis of the accusations as false. In such a situation, the judicial conscience of the High Court would persuade it to exercise its power under Section 482 of the Cr.P.C. to quash such criminal proceedings, for that would prevent abuse of process of the court, and secure the ends of justice.

L.       For that the present proceeding has been launched as an engine of oppression with the sole purpose of restraining the petitioner to pursue the FIR lodged against the petitioner by terrorizing the petitioner with a motivated and false criminal prosecution.

M.     On the strength of the allegations, it is clear that no offence is made out against the Petitioner as such FIR is liable to be quashed.

N.      For that it is a settled principle of law that even otherwise there is no allegation against the petitioner and no material evidence has been filed against the Petitioner which would constitute an offence, and therefore the said FIR is liable to be quashed on this ground alone.

6.      That the criminal proceeding is manifestly intended with malafide and the same has been instituted with an ulterior motive for wreaking vengeance upon them and with a view to spite them due to private and personal grudge.

7.      That the petitioner craves the leave of this Hon’ble Court to raise such other or further ground that may be available to them at the time of hearing of the present petition.

8.      That petitioner craves leave to alter or amend the petition with the permission of this Hon’ble Court and by way of the present petition the petitioner humbly seeks the indulgence of this Hon’ble Court to pass appropriate orders for quashing of FIR.

9.      That petitioner has not filed any similar petition in the above noted matter either before this Hon’ble Court or before Hon’ble High Court of Delhi or Hon’ble Supreme Court of India.

P R A Y E R

In the facts and circumstances of the case, it is respectfully prayed that this Hon’ble Court may be pleased to :-

A.      Pass an appropriate order/direction quashing of FIR No. XXXX/XXXX under Section 376/511/354 of IPC, Police Station: XXXXXX, and all other proceedings emanating thereunder.

B.      Such other or further orders as this Hon’ble Court may be deem fit and proper in the facts and circumstances of the case be also passed to meet the ends of justice.

It is prayed accordingly,

          PETITIONER

Through

Place: New Delhi

Dated:

XXXXXXXXX & ASSOCIATES

Advocate

XXX, XXXXXXXXXXXXX,

Delhi-XXXXXX

Mob.No. XXXXXXXXX

Email: xxxxxxxxxxx@yahoo.in

IN THE HIGH COURT OF DELHI AT NEW DELHI

CRL. WRIT PETITION No._____ OF XXXX.

IN THE MATTER OF :-

XXXXXXXXXXXXXXX                                : PETITIONER

VERSUS

THE STATE & ANR.                                    : RESPONDENTS

AFFIDAVIT

Affidavit of Mr. XXXXXXXXXXX age about XX years S/o Sh. XXXXXXXXXX R/o Flat No. XXX, XXXXXX, New Delhi-XXXXXX, do hereby solemnly affirm and declare as under:-

1.      That I am the petitioner in the above-mentioned application and am therefore, competent to swear this affidavit.

2.      That the above-mentioned Civil Writ Petition Under Article 226 of the Constitution of India r/w Section 482 CrPC for issuance of necessary writ or direction in the nature of certiorari, mandamus or any other nature have been drafted by my counsel under my instructions, while the legal submissions made therein are based on legal advice received and believed to be true.

3.      That the annexures annexed to the accompanying writ petition are true to their respective originals.

DEPONENT

VERIFICATION :-

Verified at Delhi on this _____, day of XXX, XXXX that the contents of this affidavit are true and correct to the best of my knowledge and belief and nothing material has been concealed therefrom.

DEPONENT

IN THE HIGH COURT OF DELHI AT NEW DELHI

CRL. WRIT PETITION No._____ OF XXXX.

IN THE MATTER OF :-

XXXXXXXXXXXXXXXXX                           : PETITIONER

VERSUS

THE STATE & ANR.                                    : RESPONDENTS

AFFIDAVIT

Affidavit of Ms. XXXXXXXX aged about XX years D/o Sh. XXXXXXX R/o H. No. X, XXXXXXXXX, Delhi, do hereby state on solemn affirmation and declare as under:-

1.      That I am the complainant/Respondent No.2 in the above-mentioned case and as such I am conversant with the facts and circumstances of the case, and hence competent to swear this Affidavit.

2.      That the respondent no.2 has gone through the averments made in the accompanying writ petition filed under Section 482 Cr.P.C. are true and correct to the best of the deponent knowledge and explained to me in vernacular.

3.      I confirm that the present FIR in question bearing No. XXXX/XXXX under Section 376/354/511 of IPC registered with PS: XXXXX was registered by misunderstanding only on the heat of the moment and I am no longer pursued the FIR.

DEPONENT

VERIFICATION :-

Verified at Delhi on this ____, day of XXXX, XXXX that the facts stated in the above Affidavit are true to my knowledge and no part of the same is false and nothing material has been concealed therefrom.

DEPONENT

IN THE HIGH COURT OF DELHI AT NEW DELHI

CRL. M.C. NO. ______ OF XXXX.

IN

CRL. WRIT PETITION No._____ OF XXXX.

IN THE MATTER OF :-

XXXXXXXXXXXXXXX                                : PETITIONER

VERSUS

THE STATE & ANR.                                    : RESPONDENTS

FIR No. XXX/XXXX

                                      U/s.: 376/511/354 IPC,

P.S.: XXXXXXXX,

APPLICATION UNDER SECTION 482 OF THE CODE OF CRIMINAL PROCEDURE CODE FOR EXEMPTION FROM FILLING CERTFIED COPIES OF THE ANNEXXURES.

MOST RESPECTFULLY SHOWETH ;-

1.      That the petitioner has filed Annexures along with the main petition in order to support the writ petition and the Annexures filed is the true, correct and compared copies of the original.

2.     That the petitioner shall apply for obtaining the certified copies of the Annexures and undertakes to file the same as soon as the same is made available by copying agency concerned.

PRAYER:

It is most respectfully prayed before this Hon’ble Court that the petitioner may kindly be exempted from filling the certified copies of the Annexures.

Such other or further orders as this Hon’ble Court may be deem fit and proper in the facts and circumstances of the case be also passed to meet the ends of justice.

          PETITIONER

Through

Place: New Delhi

Dated:

XXXXXXXXX & ASSOCIATES

Advocate

XXX, XXXXXXXXXXXXX,

Delhi-XXXXXX

Mob. No. XXXXXXXXX

Email: xxxxxxxxxxx@yahoo.in

IN THE HIGH COURT OF DELHI AT NEW DELHI

CRL. WRIT PETITION No._____ OF 2022.

IN THE MATTER OF :-

XXXXXXXXXXXXXXX                                : PETITIONER

VERSUS

THE STATE & ANR.                                    : RESPONDENTS

AFFIDAVIT

Affidavit of Mr. XXXXXXXXXXXX age about 44 years S/o Sh. XXXXXXXX R/o Flat No. XX, XXXXXXX, New Delhi-XXXXXX, do hereby solemnly affirm and declare as under:-

1.      That I am the petitioner in the above-mentioned application and am therefore, competent to swear this affidavit.

2.      That the submissions as to facts made in the accompanying application under Section 482 of the Code of Criminal Procedure seeking exemption from filling certified copies are based on legal advice received and believed to be true.

3.      That the annexures annexed to the accompanying application are true to their respective originals.

DEPONENT

VERIFICATION :-

          Verified at Delhi on this _____, day of XXX, XXXX that the contents of this affidavit are true and correct to the best of my knowledge and belief and nothing material has been concealed therefrom.

DEPONENT