IN THE HON’BLE HIGH COURT OF DELHI AT NEW DELHI

Crl. Misc. Application No. _______ of 2021

IN
Crl. Revision Petition No.1263 of 2019
IN THE MATTER OF:
Vineet Anand …Applicant
Versus
Aakanksha Anand & Ors. …Respondent(s)
INDEX
S. NO. PARTICULARS PAGE NO.
1. Urgent Application 1
2. Notice of Motion 2
3. Application under Section 482 of the Code of
Criminal Procedure, 1973 praying for Stay of
Execution of the Trial Court Order dated
3-19
29.11.2018, subjudice before this Hon’ble Court
in Criminal Revision Petition No. 1263 of 2019
and/or reduction/modification in interim
maintenance during the pendency of Criminal
Revision Petition No. 1263 of 2019
4. Annexure A 1:
True copy of the Order dated 29.11.2018 passed
by the Ld. Trial Court, whereby granting a 20-30
monthly maintenance of Rs. 50,000/- to the
Respondent No. 1
5. Annexure A 2:
The photographs and CCTV footage showing 31-32
departure of the Respondent No. 1 on 20.05.2016
6. Annexure A 3:
The still photographs of the video footage
captured through the CCTV camera showcasing 33-43
the rude and arrogant behaviour of the
Respondent No. 1 and her family members
7. Annexure A 4:
The True Copy of the Order dated 13.12.2019
passed by this Hon’ble Court, whereby, granting 44-46
bail to the Applicant herein in FIR No. 44 of
2018 under Section 498A/406/34
8. Annexure A 5:
FIR No. 88 of 2018 under Section 452/506 being
a false and fabricated FIR filed by the 47-55
Respondent No. 1 at PS Rani Bagh
9. Annexure A 6:
Log book in respect of FIR No. 88/2018 filed at 56-59
PS Rani Bagh
10. Annexure A 7:
Copy of the details of the Joint Locker illegally 60-65
accessed by the Respondent No. 1.
11. Annexure A 8:
True Copy of the Order dated 28.11.2019 passed
by this Hon’ble Court in Crl Rev. P. 1243/2019 66-68
filed by the Respondent No. 3/father of the
Application/Mr. Kiran Kumar Anand
12. Annexure A 9:
The Certified Copy of the Execution Petition No.
72 of 2019 filed by the Respondent no. 1 69-85
(without supporting documents)
13. Annexure A 10:
The Certified Copy of the Objection filed to the
Execution Petition No. 72 of 2020 by the 86-94
Applicant (without supporting documents)
14. Annexure A 11:
True Copy of the order dated 08.01.2021 passed
in Criminal Revision Petition No. 1243 of 2019 95-96
titled “Kiran Kumar Anand v. Aakanksha Anand
& Ors”

15. Annexure A 12 (Colly):

The Certified Copy of the Order dated
18.01.2021 of the Ld. Trial and the amended 97-112
Execution Petition filed by the Respondent No. 1
seeking execution of the Trial Court Order dated
29.11.2018 against the Applicant (without
supporting documents)
16. Annexure A 13:
The True Copy of the Objection to the Amended 113-137
Execution filed by the Applicant herein
17. Annexure A 14 (Colly.)
The True Copies of the Orders dated 22.01.2021
passed in Criminal Revision Petition No. 1263 of
2019 titled “Vineet Anand vs Aakanksha Anand
& Ors” and the Order dated 19.02.2021 passed in 138-140
Criminal Revision Petition No. 1243 of 2019
titled “Kiran Kumar Anand vs Aakanksha Anand
& Ors”
18. Annexure A 15:
 True Copy of the Judgment titled Annurita Vohra
vs Sandeep Vohra 110 (2004) DLT 546, being
141-143
heavily relied upon by the Ld. Trial Court while
granting interim maintenance of Rs. 50,000/- per
month.
19. Annexure A 16:
True Copy of the Offer letters, Work Visa Permit
(Dubai), Salary Slip, Income Tax Returns, Bank
Account Statements and Income Affidavit filed 144-194
before the Ld. Trial Court from the year 2009 to
September 2020
20. Annexure A 17:
True Copy of the Order in the case filed before
195-200
the Labour Court in Dubai along with translation
21. Annexure A 18:
True Copy of Completion certificate of SWIFT 201
C++ from NIIT of the Applicant.
22. Annexure A 19:
True Copy of 1 year Diploma and Marksheets of 202-203
the Applicant
23. Annexure A 20:
True Copy of the 2 year Diploma and Mark
204-205
Sheets of the Applicant
24. Annexure A 21:
True Copy of the Income Tax Returns filed by
the Respondent No.1 since the year 2012-13 to 206-209
2016-2017.
25. Application under Section 482 CrPC seeking
exemption from filing certified, left side margin
and translated copies of annexures along with 210-212
Affidavit

26. Proof of Service

Applicant
(Through Special Power of Attorney Holder)
THROUGH
New Delhi
Dated: 22.03.2021 Aarti Manchanda
Advocate for the Applicant
278, 1st floor, Rajdhani Enclave,
Britania Rani Bagh Road, Pitampura,
New Delhi-110034
M: 9654185180
 1

E: aarti@legaltempo.com
IN THE HON’BLE HIGH COURT OF DELHI AT NEW DELHI
Crl. Misc. Application No. _______ of 2021
IN
Crl. Revision Petition No.1263 of 2019

IN THE MATTER OF:

Vineet Anand …Applicant
Versus
Aakanksha Anand & Ors. …Respondent(s)
URGENT APPLICATION

To,
The Registrar
High Court of Delhi,
New Delhi
Sir,
The above stated Criminal Miscellaneous Application may kindly be listed
urgently for hearing before this Hon’ble Court. The reason for urgency being
that the Applicant is seeking stay of execution of the Trial Court Order dated
29.11.2018 granting interim maintenance of Rs. 50,000/- (Rupees Fifty
Thousand Only) to the Respondent No. 1. That the Applicant is presently
drawing a monthly salary of AED 1800/- approximately Rs. 36000/- per
month and is not in the condition to pay the said amount.

Applicant
(Through Special Power of Attorney Holder)
THROUGH
New Delhi
Dated: 22.03.2021 Aarti Manchanda
Advocate for the Applicant
278, 1st floor, Rajdhani Enclave,
Britania Rani Bagh Road, Pitampura,
New Delhi-110034
M: 9654185180
E: aarti@legaltempo.com
 2

IN THE HON’BLE HIGH COURT OF DELHI AT NEW DELHI

Crl. Misc. Application No. _______ of 2021
IN
Crl. Revision Petition No.1263 of 2019

IN THE MATTER OF:

Vineet Anand …Applicant
Versus
Aakanksha Anand & Ors. …Respondent(s)
NOTICE OF MOTION

To,

Take notice that the accompanying revision petition will be listed before
Hon’ble Court on ___.03.2021 at 10:30 A.M. in the forenoon or soon
thereafter.

Please take notice accordingly.

Applicant
(Through Special Power of Attorney Holder)
THROUGH
New Delhi
Dated: 22.03.2021 Aarti Manchanda
Advocate for the Applicant
278, 1st floor, Rajdhani Enclave,
Britania Rani Bagh Road, Pitampura,
New Delhi-110034
M: 9654185180
E: aarti@legaltempo.com
 3

IN THE HON’BLE HIGH COURT OF DELHI AT NEW DELHI

Crl. Misc. Application No. _______ of 2021
IN
Crl. Revision Petition No.1263 of 2019

IN THE MATTER OF:

Vineet Anand …Applicant
Versus
Aakanksha Anand & Ors. …Respondent(s)

APPLICATION UNDER SECTION 482 OF THE CRIMINAL

PROCEDURE CODE FOR STAY OF EXECUTION PETITION NO. 72 OF
2020 FOR EXECUTION OF ORDER DATED 29.11.2018 GRANTING
INTERIM MAINTENANCE OF RS. 50,000/- (RUPEES FIFTY
THOUSAND ONLY) PER MONTH AND ARREARS OF RS. 21,00,000/-
(RUPEES TWENTY ONE LACS ONLY) FILED BEFORE THE LD. MM,
MAHILA COURTS, NORTH-WEST, DELHI AND/OR
REDUCTION/MODIFICATION IN INTERIM MAINTENANCE DURING
THE PENDANCY OF CRIMINAL REVISION PETITION NO. 1263 OF
2019 AND CC NO. 11302/2017 PENDING BEFORE THE LD. TRIAL
COURT

MOST RESPECTFULLY SHOWETH:

1. That a Criminal Revision Petition bearing No. 1263 of 2019 under
Section 397 of Cr.P.C 1973 was filed by the Applicant before this
Hon’ble High Court seeking to set aside the impugned common order
dated 29.08.2019 of Ld. Appellate Court i.e., Ld. ASJ North West,
Rohini District Courts, Delhi in Criminal Appeal bearing No.190/2018
titled as “Aakansha Anand vs Vineet Anand & Ors.” whereby allowing
a maintenance of Rs. 1,25,000/- per month in favour of the Respondent
no. 1 and against the Petitioner/Applicant and the father of the
Applicant (Respondent No. 3).

2. That the Respondent No. 1 filed CC No. 11302/2017 in the Court of Ld.
MM, Mahila Courts, North West Delhi, being an application under
 4

Section 12 of the Protection of Women from Domestic Violence Act,

2005 along with application for interim relief under Section 23 of the
Act. The Ld. Trial Court was pleased to decide the application under
Section 23 of the Act in favour of the Respondent No. 1 by granting an
interim maintenance amount of Rs. 50,000/- per month. The copy of the
Order dated 29.11.2018 passed by the Ld. Trial Court is attached
herewith as Annexure A 1.

3. That the contents of the Criminal Revision Petition No. 1263 of 2019
be read as part and parcel of the instant miscellaneous application and
the same are not reiterated herein for the sake of brevity.

4. That a marriage was solemnised between the Applicant and the

Respondent No. 1 on 23.01.2013. That out of the said wedlock, a girl
child namely, Baby Sanvika Anand was born on 28.03.2014.

5. That till 28.04.2016, everything was going smoothly on the part of

Respondent No.1 and between the marital life of the
Petitioner/Applicant, whereas the parents of Respondent No. 1 and
brother always instigated and dictated the Applicant for fulfilling her
undesirable demands and made their every effort to interfere in her
matrimonial life. That in a planned manner, in the month of May 2016,
the parents and brother of the Respondent No. 1 came up with a new
and open demand in connivance with the Respondent No. 1 “to transfer
the ownership of the residence/house in the name of Respondent No.
1”. That it was the first time the mother-in-law of the Respondent No. 1
denied straight forward and stood firmly against the unlawful demand
of the Respondent No. 1 and her parents and brother. That thereafter the
attitude and behaviour of the Respondent No. 1 and her parents had
changed totally towards the husband (the Applicant herein) and in-laws.

6. That due to the bitterness created due to non-fulfilment of her

undesirable demands and reasons best known to the Respondent No. 1,
the Respondent No.1 voluntarily left her matrimonial home on
20.05.2016 along with her child and belongings, accompanied by her
mother and court staff of the mother. The photographs and CCTV
 5

footage to this effect evincing the same are attached herewith and
marked as Annexure A 2.

7. That after about 4 years and 7 months of marriage and moreover after
passage of 14 months since leaving the marital home, the Respondent
No. 1 filed the Application under Section 12 of the Protection of
Women from Domestic Violence Act, 2005 in the Court of Ld. MM,
Mahila Courts, North West Delhi and criminal complaint before CAW
Cell against the husband and her in-laws. It is pertinent to mention that
not a single complaint, any MLC or any adverse document showing
domestic violence has been filed by the Respondent no. 1 along with
the frivolous complaints.

8. That there are numerous incidents, where the Respondent No. 1 and her
parents, brother and other family members created day to day problems
and used intolerable language, even after leaving the matrimonial home,
which are clearly revealed from the photographs and video footage as
captured in the CCTV Camera installed at the house of the Applicant’s
parents. Copy of the Still Photographs captured through the CCTV
camera showcasing the rude and arrogant behaviour of the Respondent
No. 1 and her family member has been annexed herewith as Annexure
A 3 (Colly).

9. That it is pertinent to mention that the Respondent No. 1 has also filed
two frivolous and baseless FIRs against the Applicant bearing FIR
No. 44/2018 under section 498A/ 406/ 34 of IPC wherein bail has
already been granted to the Applicant and FIR No. 88/2018 under
Section 452/506 at Police Station Rani Bagh. The copy of return report
of spot and the log book (wireless message of PCR) itself showcases
the malafide intention of the Respondent No. 1 while lodging of the
said FIR. The copy of Order dated 13.12.2019 passed in FIR No.
44/2018 is annexed herewith as Annexure A 4 and FIR No. 88 of 2018,
log book in the said FIR has been annexed herewith as Annexure A 5
and Annexure A 6 respectively.
 6

10.That it is pertinent to mention that on 04.05.2017, the Applicant

approached the Andhra Bank, where Applicant and the Respondent
were having a Joint Locker. On enquiry from the Bank staff, it came to
the knowledge of the Applicant that despite having a joint operation
Locker, without Applicant’s presence (when Applicant was in Dubai)
on 19.08.2016, the Respondent No. 1 operated the Locker individually.
That it is pertinent to mention that the Respondent No 1 had taken all
the jewellery from the said Joint Locker which also includes
Applicant’s ancestral jewellery. This act of the Respondent No. 1 itself
shows the malafide and greedy conduct of the Respondent No. 1. Copy
of the details of the said Joint Locker of the Applicant and the
Respondent No. 1 are annexed herewith as Annexure A 7.

11. That the Respondent No. 1 filed the CC No. 11032 of 2017 being an
application under Section 12 of the Protection of Women from
Domestic Violence Act, 2005 along with application under Section 23
for Interim Relief after a delay of 14 months after leaving her
matrimonial home and 4 years and 7 months of marriage.

12.That the Ld. Trial Court vide Order dated 29.11.2018 was pleased to
decide the application under Section 23 of the DV Act and was pleased
to grant a monthly interim maintenance of Rs. 50,000/- to the
Respondent No. 1 herein. It is pertinent to mention that despite having
filed the Income Tax Returns, Income Affidavits as well as employment
documents, the said order was passed by the Ld. Trial Court.

13.That being aggrieved by the Order dated 29.11.2018 of the Ld. Trial
Court, the Applicant filed an appeal bearing no. 10/2019 against the
said order seeking reduction of the monthly maintenance amount. It is
pertinent to mention that another appeal bearing no. 190/2018 was filed
by the Respondent No.1 seeking enhancement of the monthly
maintenance amount.

14.That the Ld. Appellate Court was pleased to pass a detailed common
Order dated 29.08.2019 in the Criminal Appeal No. 190/2018 filed by
 7

the Respondent no. 1 and Criminal Appeal No. 10/2019 filed by the
Applicant herein, whereby, enhancing the monthly maintenance amount
from Rs. 50,000/- to Rs. 1,25,000/-, to be jointly paid by the
Petitioner/Applicant and the father of the Applicant (Respondent No.3
herein) being a ‘Karta of HUF’ and dismissed the Appeal bearing no.
10/2019 filed by the petitioner/Applicant herein.

15.That being aggrieved by the order of the Ld. Appellate Court, the
Petitioner/Applicant filed the Criminal Revision Petition No.
1263/2019, whereas the Respondent No. 1 herein has not challenged the
order of the Ld. Appellant Court.

16.That the Respondent No. 3 herein, the father of the Applicant filed a
separate Criminal Revision Petition bearing No. 1243/2019, wherein
this Hon’ble High Court of Delhi was pleased to grant the stay of the
common Order dated 29.08.2019 of the Ld. Appellate Court vide Order
dated 28.11.2019. That the Applicant herein, is the Respondent No. 2 in
the said Petition. That this Hon’ble Court further acknowledged that the
Ld. Appellate Court had proceeded on wrong premise that when the
parents of the girl marry their daughter on the strength of wealth and
prosperity of the parents of the boy and not on the strength of wealth
and prosperity of the boy, it raises a question for consideration. This
Hon’ble Court further stated that the Ld. Appellate Court got caught
into an illogical, irrational and erroneous question which is not tenable
in law and came to an erroneous and perverse conclusion that the case
law relied upon by the Respondent Nos. 2 to 4 are distinguishable on
facts. True Copy of the Order dated 28.11.2019 passed by this Hon’ble
Court has been annexed herewith as Annexure A 8.

17.That this Hon’ble Court also acknowledged that it is not the case of the
Respondent No. 1 that the parents of the Applicant misrepresented the
status of the Applicant before the marriage. The Appellate Court had
failed to appreciate the evidence on record in judicial file of the trial
court record and had passed the verdict, in various clauses of Judgment,
out of pleadings and also against the law.
 8

18.That the Respondent no.1 herein filed the Execution Petition No. 72 of
2020 before the Court of Ld. M.M., Mahila Courts, North West, Rohini
District Courts praying for execution of the common Order dated
29.08.2019 passed by the Appellate Court against the Applicant herein
and the Respondent no. 3 herein (father of the Applicant). The Certified
Copy of the Execution Petition No. 72 of 2019 filed by the Respondent
No.1 is attached herewith as Annexure A 9. The Certified Copy of the
Objection filed to the said Execution by the Applicant herein is attached
herewith as Annexure A 10.

19.That this Hon’ble Court vide Order dated 08.01.2021 further clarified
that the Applicant/petitioner herein shall continue to pay the interim
maintenance amount as per the trial court order. The relevant paragraph
of the said order dated 08.01.2021 is reproduced herein below:

“2. Till the next date, interim order as passed by this Court in para-8 of
the order dated 28th November, 2019 would continue and the
directions as noted in para-9 would be applicable to the Respondent
No.2 who would comply with the order of maintenance as passed by the
learned Trial Court including the arrears thereof.”

True Copy of the order dated 08.01.2021 passed in Criminal Revision

Petition No. 1243 of 2019 titled “Kiran Kumar Anand v. Aakanksha
Anand & Ors” is attached herewith as Annexure A 11.

20.That in view of the same, an amended execution petition dated

18.01.2021 was filed by the Respondent no. 1 seeking execution of the
Trial Court Order dated 29.11.2018, wherein, the Ld. Trial Court was
pleased to grant an interim monthly maintenance jointly for Rs.
50,000/- to the Respondent no. 1 and her minor daughter i.e.
Respondent no. 2 and the arrears of Rs. 21,00,000/- (Rupees Twenty
One Lac Only). The Certified Copy of the Order dated 18.01.2021 of
the Ld. Trial and the amended Execution Petition filed by the
Respondent No. 1 seeking execution of the Trial Court Order dated
29.11.2018 against the Applicant herein is attached herewith as
 9

Annexure A 12 (Colly.) and the True Copy of the Objection to the

Amended Execution is filed herewith as Annexure A 13.

21.That it is pertinent to mention that the Applicant herein filed two

separate applications for modification of the order dated 08.01.2021
passed by this Hon’ble Court in Crl Rev. P. 1243 of 2019 expressing
his incapability to pay the arrears as well as the monthly maintenance
amount of Rs. 50,000/- (Rupees Fifty Thousand Only). The said
applications were dismissed by this Hon’ble Court. The True Copies of
the orders dated 22.01.2021 passed in Criminal Revision Petition No.
1263 of 2019 titled “Vineet Anand vs Aakanksha Anand & Ors.” and
the Order dated 19.02.2021 passed in Criminal Revision Petition No.
1243 of 2019 titled “Kiran Kumar Anand vs Aakanksha Anand & Ors.”
are attached herewith as Annexure A 14(Colly.).

22.That the Applicant herein prefers the present miscellaneous application

inter-alia amongst following grounds:

A. Because the Applicant went into appeal bearing No.10 of 2018

against the order of the Ld. Trial Court dated 29.11.2018 because of
his incapability to pay the amount of Rs. 50,000 per month as
maintenance, which is beyond the earnings of the Applicant herein.

B. Because the Applicant cannot be asked to pay the amount of

maintenance beyond his capability to pay. It is settled preposition of
law that the maintenance awarded to the wife should neither be so
extravagant which becomes oppressive and unbearable.

C. Because the Respondent no. 1 has only made bald averment that the
Applicant herein owns more than twenty properties in his name.
Under the law, the burden is placed upon the wife to show that the
means of her husband are sufficient.

D. Because the Ld. Trial Court had failed to acknowledge that the
Judgment on which the Ld. Trial Court has relied on i.e., Annurita
Vohra vs Sandeep Vohra 110 (2004) DLT 546 is not applicable in
 10

the present circumstances of the case. The Ld. Trial Court while
relying on Annurita Vohra vs Sandeep Vohra (Supra) has stated that
the family resource cake must be divided amongst all family
members. However, the Ld. Trial Court failed to acknowledge that
the Hon’ble High Court in the above mentioned Judgment has stated
that the family resource earning capacity of the spouse will
constitute the family resource cake and not of the parents. True
Copy of the Annurita Vohra vs Sandeep Vohra 110 (2004) DLT 546
Judgment has been Annexed herewith as Annexure A 15.

E. Because the Ld. Trial Court has failed to acknowledge that in order
to arrive at the probable formula to award maintenance to the wife,
status of the parents of the husband in no manner, can be considered
by the Court while awarding maintenance to his wife. It is the duty
of the husband to maintain the wife and not of his parents.

F. Because the Ld. Trial Court has wrongly emphasized the fact that
the wedding between the parties were lavish, functions were at large
scale, or the outstation trips to various destination were expensive. It
is pertinent to note that at that point of time all these events and trips
were sponsored by the parents of either the Applicant or Respondent
no.1 who cannot be held liable to pay the maintenance.

G. Because the Ld. Trial Court has wrongly acknowledged that the
Applicant is earning Rs.1,00,000/- p.m. No basis for this finding has
been given in the order. No weightage has been given to the ITRs,
income affidavit, salary slips, offer letters and bank statements. No
ground to disbelieve the ITRs and other documents has been given
in the impugned order. True Copy of the Offer letters, Work Visa
Permit (Dubai), Salary Slip, Income Tax Returns, Bank Account
Statements and Income Affidavit filed before the Ld. Trial Court
from the year 2009 to the salary slips till September 2020 filed
before this Hon’ble Court has been annexed herewith as Annexure A
16 (Colly)
 11

H. Because the Ld. Trial Court was in so haste to decide the application
under Section 23 of DV Act that the Respondent no.1 had not even
filed her Income Affidavit in terms of observation made by Hon’ble
High Court of Delhi in the case of “Puneet Kaur Sawhney vs
Inderjeet Singh Sawhney, 183 (2011) DLT 403” The Respondent
no.1 did not file all the documents as are required as per the
Judgment deliberately despite the Ld. Trial Court order just to
conceal her employment and her true financial status despite
submissions made by the Applicant herein seeking directions to the
Respondent no.1 herein to produce the same.

I. Because the Ld. Trial Court has wrongly acknowledged the

statement of Respondent No.1 that the Applicant has restaurants in
Dubai without acknowledging the legal documents which have been
filed by the Applicant which shows that the Applicant was having a
job in Dubai but had not received his salary due to which he was
constrained to file a case before Labour Court in Dubai. True Copy
of the order in the case filed before the Labour Court in Dubai along
with translation is annexed herewith as Annexure A 17.

J. Because Ld. Trial Court has wrongly relied upon the false and
fabricated submissions made by the Respondent no.1 without any
documentary evidence.

K. Because the Ld. Trial Court has wrongly concluded that the income
of the Appellant herein is at least Rs. 1,00,000/- p.m and awarding
the Respondent no.1 Rs 50,000/- p.m towards maintenance of
herself and the child.

L. Because the Ld. Trial Court has failed to appreciate that the present
complaint is wrong, false, baseless and frivolous and the contents of
the same have been concocted and engineered against the Applicant
and his family members just to harass and humiliate them
unnecessarily with the intention to defame them and cause mental as
well as financial losses.
 12

M. Because the Ld. Trial Court has failed to appreciate that the
allegations which were levelled by the Respondent No.1 in her
complaint are frivolous, vague and with malafide intentions as there
is no prior complaint, any MLC or any other adverse document filed
by the Respondent No.1 along with her present alleged complaint
about physical abuse and torture by the Applicant or his family
members. It is pertinent to mention that the applications under
Section 12 and Section 23 of the Protection of Women from
Domestic Violence Act consists of nothing but only concocted
stories unsupported by any documents. The Respondent No.1 had
not disclosed in her pleadings the exact reasons as to why she had
not provided any documents in support of her application so as to
enable the Applicant to take specific objections to the nature of
documents.

N. Because the Ld. Trial Court has failed to appreciate the cruel acts of
the Respondent No. 1, her family was only with the malafide
intention of extorting money from the Applicant and his parents at
every stage which are relevant from the contradictory statements
made in the reply to the present petition, FIR No. 44 of 2018 filed at
PS Rani Bagh and the Complaint under Section 12 of the Act. That
the Respondent No.1 and her family members have even debarred
the Applicant of his right to meet his only child, despite having
equal rights. That the Respondent No. 1 used the baby as a tool to
cause emotional torture to the Applicant and his family.

O. Because the Ld. Trial Court has failed to appreciate that the
Respondent No. 1 has on her own deserted the company of her
husband and has been wilfully living separately from her husband
without any substantive reason.

P. Because the Ld. Trial Court has failed to appreciate the malafide
intention of the Respondent No. 1 and has not considered the illegal
acts of accessing locker without authorization and further taking
possession of the family gold. That the said has not been disclosed
 13

by the Respondent No. 1 in her Complaint in the CAW Cell or her

detailed application under Section 12 of the Protection of Women
from Domestic Violence Act, 2005.

Q. Because the Ld. Trial Court failed to appreciate the fact that the
Respondent No. 1 and her family arranged the marriage between the
Applicant and the Respondent No. 1 only with the greed of financial
resources of the Applicant’s family and having assumed that he will
join the business of his father. The Ld. Trial Court has failed to
consider the sanctity of marriage in the Hindu religion. That the
greedy intention to extort money from the Applicant and his family
is apparent from the arguments advanced by the Respondent No. 1
before the Ld. Trial Court and recorded in the order dated
29.08.2019.

R. Because the Respondent No. 1 in her reply to the Criminal Revision

No. 1263/2019, the FIR No. 44 of 2019 Application under Section
12 of the DV Act has made contradictory statements and as per her
own convenience.

S. Because the Respondent No. 1 has suppressed the actual facts from
the Hon’ble Court below. Further, it is noted that the Respondent
No.1 has not come out with a truthful version of the Applicant,
rather some guesswork has been resorted to by the Ld. Trial Court
while forming an opinion as what the income of the Applicant
would be. That as held in Amit Khanna vs Priyanka Khanna Crl.
M.A. No. 13807/2009, date of decision dated 01.09.2010, held by
the Hon’ble High Court of Delhi “that the Respondent has not
enumerated the immoveable property owned by the husband”.

T. Because the Applicant has never been involved in the business of his
father and since the year 2007 has shown keen interest in software
and hardware. Brief Educational and Professional Profile of the
Applicant is reproduced herein below:-

1. Education Qualification of the Applicant-

 14

 Pre-Primary schooling from Sachdeva Public School Sector-13

Rohini.
 Primary to Middle classes from St. Xavier School, Shahbad,
Daulatpur, Delhi.
 Secondary School passed in the year of 2005.
 Senior Secondary passed in the year of 2007.
 During the schooling period, completed the computer language
course- SWIFT C++ from NIIT. Certificate showing the same is
attached herewith as Annexure A 18.
 Graduation Diploma from Technia Institute of Advanced Studies,
Madhuban Chowk, Rohini.
1. One Year Graduate Diploma in executive leadership in
Information Technology for the academic year 2007-2008.
The True Copy of the Diploma and Marksheets of the
Applicant are attached herewith as Annexure A 19.
2. Two Year Graduate Diploma in executive leadership in
Information Technology for the academic year 2008-2009.
The True Copy of the Diploma and Mark Sheets of the
Applicant are attached herewith as Annexure A 20.

2. Since 2009, the Applicant has been working and studying

simultaneously and earning on the basis of the knowledge he
gained after the completion of the above certificates and diploma.

3. That a perusal of the educational as well as professional

documents reveal that the Applicant has keen interest in the field
of computer. The Applicant herein has worked in various
companies in order to gain experience and has also worked as a
freelancer in the same field by assembling and repairing
computers and also attended the complaints of customers and
earned the income prior to and after the marriage and accordingly
filed the ITRs.

4. That the Applicant herein took a training and decided to start his
own business and created a proprietorship firm under the name
 15

and style of M/s. Aakanksha Enterprises. It is pertinent to

mention here that the Applicant was himself the proprietor of that
firm, but the business of the Applicant was not a success because
of not giving proper attention and care at the phase of start-up
only. This was due to the fact that Respondent no. 1 always kept
him mingled and busy in her parental family, outings, functions,
family get together, shopping, dinners as a result of which he
could not concentrate and give time towards his business due to
which the Applicant herein had to bear loss of business.

5. That after coming back from Dubai in the month of March 2018,
the Applicant was engaged with A4 Securities Limited and TLC
Worldwide Services Pvt Ltd. That due to the ongoing litigation
and threats from the family of the Respondent No. 1, it became
impossible for the Applicant to work in Delhi. It is pertinent to
mention that frivolous FIR No. 88/2018 under Section 452/506
IPC, resultant of Applicant’s effort to meet his child in the
presence of the Police and other ongoing litigations made it
impossible for the Applicant to have a successful professional
life in India.

U. Because the Applicant has submitted the ITRs and the Affidavit of
Income, assets and expenditure which is at Rs. 23,000/- per month
while working as a sales executive in a company. The Applicant has
also submitted evidence in respect of his previous employment with
various Companies as a Trainee or Associate. That the said
documents are relevant to substantiate that the Applicant has always
tried working on his own independent of his father’s business and
that he has no interest in joining his father’s business.

V. Because the Applicant has never denied maintaining the Respondent

No. 1 as per his capacity. That the Applicant’s and the Respondent
No. 1’s journey to Dubai was set and planned before the Respondent
No.1’s departure from her marital home. That the Applicant and the
Respondent No. 1 even finalised the school of Respondent No. 2.
 16

That this ground alone evinces the fact that the Applicant has never
been involved in the business of Respondent No. 3.

W. Because the Ld. Trial Court has failed to appreciate that the
business of manufacturing of cooker is run by the Respondent No. 3
and not by the Applicant. The Applicant has always expressed his
desire to establish a career independent of his father and the same is
substantial from the evidence placed on record.

X. Because the Ld. Trial Court below has erred to acknowledge that the
Respondent No.1 is a highly qualified individual holding a masters
degree in English who is even more qualified than the Applicant and
was earning an amount more than that of the Applicant before
marriage while teaching in a Private school i.e., Rs. 25,000/- per
month. It is pertinent to mention that the Respondent No.1 is still
earning a handsome amount by providing private tuitions. Even if
the version of the Respondent No.1 is accepted which is otherwise
strictly denied that she has no earning, it is a settled rule and had
been time and again upheld by the Hon’ble Courts that a woman
who is qualified to earn but doesn’t want to earn, despite
qualification and aptitude and enjoy the benefit of maintenance from
the husband is not entitled to maintenance.

Y. Because the Ld. Trial Court failed to acknowledge that it is

immaterial that whether the Respondent No.1 has filed her income
tax returns along with the Petitioner or not. It is pertinent to mention
that the Petitioner and the Respondent No.1 were living together
since 2013 to 2016 and therefore they have also filed their ITR
together. The Ld. Trial Court has erred to acknowledge that if the
Respondent No.1 is not earning or has no source of income of her
own then from where does the amounts were coming for which she
filed her ITRs. True Copy of the Income Tax Return filed by the
Respondent No.1 since the year 2012-13 to 2016-2017 has been
annexed herewith as Annexure A 21 (Colly)
 17

Z. Because no case of domestic violence is made out and the

Respondent No. 1 is not an aggrieved person within the meaning of
the Section 2(a) of the Protection of Women from Domestic
Violence Act, 2005 as she has not been subjected to any violence by
the Applicant or his parents and no prima facie case is made out
against the Applicant and in favour of the Respondent No. 1. That
the Ld. Trial Court has failed to appreciate that no evidence has been
placed on record by the Respondent No. 1 citing any act of domestic
violence.

AA. Because the Applicant has a monthly income of AED 1800/- i.e.
INR 36000 and has no moveable and immoveable properties of his
own, himself is residing in a company provided accommodation in
Dubai and is ready maintain the Respondent No. 1 & 2 as per as per
his earnings.

23.That it is pertinent to mention that the Applicant has already paid an

amount of Rs. 99000/- in the account of Respondent no. 1 and has not
denied to pay the maintenance to the Respondent no.1 and his daughter
however, he is not in a position to pay a maintenance of Rs. 50,000/-
p.m. and is willing to pay the maintenance as per his capacity as he is
earning a salary of Rs. 36,000/- per month which is apparent from his
latest salary slips.

24.That the Applicant has been working with Transparent General Security
Guard, having office at the address 07-b, P-3, Empire Heights Tower
Podium 03 Floor Bay Square, Dubai at the post of “Messenger” since
August 2019. The Applicant undertakes to pay an interim maintenance
amount equivalent/according to his present salary.

25.That the Applicant craves leave of this Hon’ble court to raise any other
ground with the permission of the court.

26.That the present application has been made bonafide and in the interest
of justice.
 18

PRAYER
It is therefore most respectfully prayed that this Hon’ble Court may
be pleased to:

a) Kindly stay the Execution Petition No. 72 of 2020 titled “Aakanksha

Anand vs. Vineet Anand” filed before the Ld. MM, Mahila Courts,
North West Delhi, Rohini District Courts, New Delhi; and/or

b) Kindly modify the monthly maintenance amount to be paid by the

Applicant as per his current salary of Rs. 36,000/- per month till the
disposal of Criminal Revision Petition No. 1263 of 2019.

c) Kindly modify the monthly maintenance amount to be paid by the

Applicant as per his current salary of Rs. 36,000/- per month till the
disposal of CC No. 11302 of 2017 pending before the Court of Ld
MM, Mahila Courts, North West Delhi.

d) Pass such other or further orders as this Hon’ble Court may deem fit
and proper in the facts and circumstances of the present case.

AND FOR THIS ACT OF KINDNESS THE APPLICANT SHALL

BE DUTY BOUND AND SHALL EVERY PRAY.

Applicant
(Through Special Power of Attorney Holder)
THROUGH
New Delhi
Dated: 22.03.2021 Aarti Manchanda
Advocate for the Applicant
278, 1st floor, Rajdhani Enclave,
Britania Rani Bagh Road, Pitampura,
New Delhi-110034
M: 9654185180
E: aarti@legaltempo.com
19
 20
ANNEXURE A 1
21
22
23
24
25
26
27
28
29
30
 31

ANNEXURE A 2
32
 33
ANNEXURE A 3
34
35
36
37
38
39
40
41
42
43
 44

ANNEXURE A 4

$~29
* IN THE HIGH COURT OF DELHI AT NEW DELHI
+ BAIL APPLN. 3088/2019
VINEET ANAND ..... Petitioner
Through Ms Aarti Manchanda, Mr Shaishav
Manu, Advocates.

versus

STATE ..... Respondent

Through Mr Aman Preet, Advocate for State for
Mr Rahul Mehra, Standing Counsel for GNCTD.
SI Prem Kumar, P.S. Mehrauli present.

CORAM:
HON'BLE MR. JUSTICE VIBHU BAKHRU
ORDER
% 13.12.2019

CRL.M.A. 42702/2019

1. Allowed, subject to all just exceptions.

2. The application is disposed of.
BAIL APPLN. 3088/2019

3. The petitioner has filed the present petition, inter alia, seeking
anticipatory bail in connection with FIR No. 44/2018 under Sections
498A/406/34 of the IPC registered with PS Rani Bagh (North West), Delhi.
4. The said FIR was registered at the instance of the petitioner’s wife.
The petitioner’s marriage with the complainant was solemnized on
23.01.2013. It is stated that in August, 2016 the petitioner had left India and
gone to Dubai for taking up employment. The FIR in question was filed
 45

approximately fourteen months thereafter – on 13.02.2018. The petitioner

disputes the allegations and had filed an application for anticipatory bail
before the Additional Sessions Judge. The said application was rejected by
an order dated 06.12.2019. The said order indicates that petitioner’s
application was denied on the ground that the stridhan articles had not been
restored to the complainant and the petitioner had failed to join the
investigation despite notices given by the Investigating Officer (IO).
5. The petitioner disputes the allegations and states that he is not in
possession of any of the stridhan articles allegedly given at the time of his
marriage with the complainant. He has also produced photographs to
establish that the complainant had full access to the matrimonial house even
after she left the same. The photographs bear the date of 20.05.2016 and
07.06.2016. It is also alleged in the present petition that the petitioner and
the complainant had a joint locker and the same had been operated by the
complainant individually.
6. Insofar as the joining of the investigation is concerned, the learned
counsel appearing for the petitioner states that since he is employed in
Dubai, it is not feasible for him to appear before the IO as and when called;
however, he would make himself available from 15.01.2020 to 25.01.2020
and thereafter, from 15.04.2020 to 25.04.2020.
7. Considering the above, this Court considers it apposite to allow the
present application. The petitioner would be released on anticipatory bail on
his furnishing a personal bond in the sum of ₹10,000/- with one surety of the
equivalent amount to the satisfaction of the IO. This is subject to the
petitioner joining the investigation and appearing before the IO on
16.01.2020 at 10.30 a.m. at P.S. Rani Bagh (North West). The petitioner
 46

shall ensure that he shall appear before the IO as and when called till
24.01.2020. The petitioner would, if required by the IO, come back to Delhi
on 15.04.2020 and appear before the IO on 16.04.2020. The petitioner shall
also provide his mobile number and ensure that he is reachable on it at all
times.
8. The petition is allowed in the aforesaid terms.
9. Order dasti.

VIBHU BAKHRU, J
DECEMBER 13, 2019
pkv
ANNEXURE A 5 47
48
49
50
51
52
53
 54
ANNEXURE A 6
55
56
57
58
59
ANNEXURE A 7 60
61
62
63
64
65
 66

ANNEXURE A 8

$~53
* IN THE HIGH COURT OF DELHI AT NEW DELHI
+ CRL.REV.P. 1243/2019
KIRAN KUMAR ANAND ..... Petitioner
Through: Mohd. Nayeemuddin, Mayank
Sawhney, Advs.
versus

AAKANKSHA ANAND & ORS ..... Respondents

Through: None

CORAM:
HON'BLE MR. JUSTICE SURESH KUMAR KAIT

ORDER
% 28.11.2019

CRL. M.A. 41343/2019

1. Allowed, subject to all just exceptions.
2. Application is disposed of.
CRL.REV.P. 1243/2019 with CRL.M.As. 41342/2019 (Stay) and
CRL.M.A. 41344/2019 (seeking permission to bring on record
documents)

3. The present petition is filed on the ground that the impugned

judgment dated 29.08.2019 is not maintainable in law inasmuch as the
learned Appellate Court proceeded on wrong premise that when the
parents of the girl marry their daughter on the strength of wealth and
prosperity of the parents of the boy, and not on the strength and
prosperity of the boy, it raises a question for consideration. The
learned Appellate Court get caught into an illogical, irrational and
 67

erroneous question which is not tenable in law and came to an

erroneous and perverse conclusion that the case laws relied upon by
the respondent Nos. 2 to 4 (the petitioner herein and his wife and the
daughter) are distinguishable on facts. The Appellate Court
proceeded on false and baseless presumptions that the parents of
Vineet Anand, misrepresented that Vineet Anand is a businessman
and concealed the factum of his employment. This is not the case of
the respondent no. 1-appellant that the parents of Vineet Anand have
misrepresented about his status before his marriage. The Appellate
Court has failed to appreciate the evidence on record in the judicial
file of the trial court record and has passed the verdict, in various
clauses of judgment, out of pleadings and also against the law.

4. The Ld. Appellate Court has heavily relied upon "a ledger of Kiran
Anand & Son (HUF)" and fastened liability on respondent No. 2
(petitioner herein) being the Karta of above named HUF.

5. Learned counsel for the petitioner submits that copy of this document
was not supplied to the respondent Nos. 2 to 4 (petitioner herein, his
wife and the daughter) before the learned Trial Court. The petitioner
is not aware as to when such document was brought on record. The
issue of HUF neither figured in the pleadings nor surfaced during
submissions and arguments either before the learned Trial Court or
before the learned Appellate Court. The learned Trial Court did not
whisper about the ledger of Kiran Anand & Son (HUF) in its order
dated 29.11.2018. The learned Appellate Court heavily relied upon
this document and read the said HUF ledger against the petitioner
 68

without giving an opportunity to petitioner to put forth his version in

this regard.

6. Notice.

7. Let notice be served upon the respondent, returnable by 19.02.2020.

8. Till further orders, impugned order dated 29.08.2019 passed by the

learned Appellate Court shall remain stayed.

9. However, it is made clear that the petitioner shall continue to pay the
maintenance as awarded by the learned Trial Court including the
arrears, if any.

Dasti.

SURESH KUMAR KAIT, J

NOVEMBER 28, 2019

PB
 69

ANNEXURE A 9
70
71
72
73
74
75
76
77
78
79
80
81
82
83
84
85
 86

ANNEXURE A 10
87
88
89
90
91
92
93
94
 95

ANNEXURE A 11

$~21
* IN THE HIGH COURT OF DELHI AT NEW DELHI
+ CRL.REV.P. 1243/2019
CRL.M.A.41342/2019 (stay)
CRL.M.A.41344/2019 (bring on record documents)
CRL.M.A.12500/2020 (directions)
CRL.M.A.16955/2020 (stay of execution proceedings No.72/2020)
CRL.M.A.17869/2020 (directions)
KIRAN KUMAR ANAND ..... Petitioner
Represented by: Ms.Ashima Mandla, Advocate.

versus
AAKANKSHA ANAND & ORS ..... Respondent
Represented by: Ms.Anu Narula, Advocate for
respondent No.1.
Mr.Shaishav Manu and Ms.Aarti
Manchanda, Advocates for respondent
No.2.
CORAM:
HON'BLE MS. JUSTICE MUKTA GUPTA
ORDER
% 08.01.2021
The hearing has been conducted through Video Conferencing.
1. List for hearing on 23rd April, 2021.
2. Till the next date, interim order as passed by this Court in para-8 of the
order dated 28th November, 2019 would continue and the directions as noted in
para-9 would be applicable to the respondent No.2 who would comply with the
order of maintenance as passed by the learned Trial Court including the arrears
thereof.
3. Order be uploaded on the website of this Court.

MUKTA GUPTA, J.
JANUARY 08, 2021/‘vn’

Signature Not Verified

Digitally Signed By:SANDEEP
KUMAR Crl. Rev. P. 1243/2019 Page 1 of 1
Signing Date:08.01.2021 23:14:09
This file is digitally signed by PS
to HMJ Mukta Gupta
 96

$~22
* IN THE HIGH COURT OF DELHI AT NEW DELHI
+ CRL.REV.P. 1263/2019
CRL.M.A.41818/2019 (stay)
VINEET ANAND ..... Petitioner
Represented by: Mr.Shaishav Manu and Ms.Aarti
Manchanda, Advocates.
versus

AAKANSHA ANAND & ORS. ..... Respondent

Represented by: Ms.Anu Narula, Advocate for
respondent No.1.
Ms.Ashima Mandla, Advocate for
respondent No.3/Kiran Kumar Anand.
CORAM:
HON'BLE MS. JUSTICE MUKTA GUPTA
ORDER
% 08.01.2021
The hearing has been conducted through Video Conferencing.
1. List on 23rd April, 2021.
2. Order be uploaded on the website of this Court.

MUKTA GUPTA, J.
JANUARY 08, 2021
‘vn’

Signature Not Verified

Digitally Signed By:SANDEEP
KUMAR Crl. Rev. P. 1263/2019 Page 1 of 1
Signing Date:08.01.2021 23:14:09
This file is digitally signed by PS
to HMJ Mukta Gupta
 97
ANNEXURE A 12
--- -
(COLLY.)

J
E-~ CRIMINAL 72/2020
AAKANKSHA ANAND Vs. VINEET ANAND AND OTHERS

Proceedings th rough Cisco Webex (from chamber}

18.01.2021
At 11:30 am.

Present:
Sh. B.K Wadhwa Ld. Counsel for the DH present in the court today.
Ms. Anu Narula, Ld. Counsel for DH through VC.
Ms. Arti Manchanda Ld. Counsel for JD through VC.
The copy .of the order dated 08.01.2021 passed in CRL. Rev. P.
1243/2019 passed by the court of Hon'ble Ms. Justice Mukta Gupta, perused. The
para 2 of the said order read as "till the next date, interim order as passed by this
court in para 8 of the order dated 28 1h Novemeber, 2019 would continue and the
directions as noted in para 9 would be applicable to the respondent no. 2 who
would comply with the order of maintenance as passed by the Ld. Trial Court
including the arrears thereof'.
An order to comply with the order of maintenance as awarded by the
trial court has been passed vide order dated 08.01.2021 and the same direction
was present in the order dated 28.11.2019 in CRL. Rev. P. 1243/2019, however,

A:
one material issue is that the execution has been sought of the order dated
29.08.2019 passed by the court of Ld. ASJ, North West which was stayed vide
order dated 28.1 1.2019 passed in P. 1243/2019 and vide order dated

17 ~021
_r.. . IT,
l. ' ' I '
I. __ _ . . _ -- -~--•·-
 98

-2-
os.o l.2021. Accordingly, the DH is directed to file a fresh execution petition or
to file an amended execution petition for the arrears of the amount that was
awarded by the Ld. Trial Court.

Since both the parties are aware of the interim maintenance order
passed by the trial court through which a sum of Rs.50,000/- per month was
awarded to the complainant. Accordingly, let the amended execution petition be
filed and in the meanwhile, let a sum of Rs. 20,000/- at least be paid by JD no. 1
to the DH by the next date.

Put up for filing of amended execution petition / payment on

22.01.2021.
(The reader has reported that no document h een filed by any
of the parties for today's hearing). "vj
( ANY A DALAL)
MM/Mahila Court No. 2
North West/ Rohini /Delhi
18.01.2021

At2:30 pm.
· Wadhwa' Ld. Counsel for the DH has filed the
. stage, Sh • BK
At this
h' h h ears of the interim maintenance
mended execution petition through w ic t e arr .
a . d d 29 11 2018 has been sought. The same ts taken
amount awarded v1de order ate . .

on record.
 99

---
.
, """"'--
,Jr-~ ,;;-
';;_-:::::_::-;.?'

-3-
Let the copy of the same be also supplied to the other party by the next date of
hearing. Let the copy of this order be sent to both the P ~ h e-modes.

(SANYAD~y)
MM/Mahila Court No. 2
North West/ Rohini /Delhi
18.01.2021

i 7~ 2021

··---- tR\"8:Tr.P
 100
NCT OF OElHl .
O l O T ~ I ~FEE

-lli\lllR,illlll
· ., . r;} .
IN TIIE COURT OF MS. SANYA DALAL: LD. M.M (MARIi} ," • 1

NORTH-WEST DISTRICT, ROHINI COURT, DELH~ J @

EXECUTION PETITION NO. 72/2020 •
. IN
CC NO. 11302/2017
IN THE MATTER OF:
...DECREE HOLDER
MS. AAl{ANKSHA ANAND
VERSUS
.... JUDGMENT DEBTOR
SH. VINEET ANAND
APPLIC N,9 ••11 · ,._.._, •l">O'>\
ATION ON BEHALF OF THE DECREE HOLDER FOR SEEKINy
AMENDMENT IN THE EXECUTION PETITION..

MOST RESPECTFULLY SHOWETH:

1. That the above captioned execution petition is pending
adjudication before this Hon'ble court and the same is fixed for

22/01/2021.

2. That the instant execution petition was filed by the

applicant/decree holder herein as there was no effective staY with
regard to the order of the Ld. Appellate court but during the course
of proceedings, the Judgment Debtor No.2 filed an Cr!. M.A. before
the Hon'ble High court of Delhi in Crl. Rev. P. No.1243/2019
wherein the Hon'ble Court ofDelhi vide its order dated os.01.2021
was pleased to further ,ray/revive/extend the order dated
29,8,2019 of the Ld, Appellate court as well as stay the payment of
maintenance qua JD No.2 till the next date of hearing and further
directed the JD No,1 to comply by the Order dated 29.11.2018 in
respect of payment of mamtenance as passed by this Hon'ble court.

3. That therefore, In view of the recent developments, the

applicant/DH seeks leave of this Hon'ble court to amend the instant
execution petition particularly paras No.3,4,7,9,10 and prayer
clause of the present execution petition as the same were in
consonance with tb;'O;_g,e.r...dat'ed- 29 ..2019 passed by the Ld.
. - .. I
Appellate court a , d ~ tl}e pi.~ex utibn petition is sought to
 101

be amended in tune With order dated 29.11 ~--- is

Hon'ble court against the Judgment Debtor No.1 only. Other

consequential amendment for example amenqed memo of parties,
title etc. are also been made an amended memo of parties and
amended execution petition are filed along with this application.

4. That the present application is being moved bonafide and in the

interest of justice on behalf of decree holder against the Judgment
debtor No.1 as till today not even a single penny has been paid by
the Judgment No.1.

s. That great prejudice would be caused t0 the applicant/decree

holder if the amendment as sought is. not aII owe d and no prejudice
would be caused to the Judgment debtors.

It is therefore, respectfully.prayed that this Hon'ble court may

' be pleased to allow the present apprication' in the interest of
kindly
justice.
DECREE HOLDER/APPLICANT

THROUGH:

ANU NARULA fe.K WADHWA

(ADVOCATES)
OFFICE: AD-12
4
·~E~!~:i::i:;
MOB:8130896099/98711~2620
·1· baliwadhwa@gmail.com
E-ma1.

--
--
~ ~
\
NEW DELHI
DATED: 18.01.2021

--
. • . J

°' .
11
~ a
---
. J

- ~-=--
·
- - - - - -- --- -
 102

.
,
IN THE COURT
N OF MS,SANYAD 'C
ORTH-WEST DISTRIC~: LD. M.M (MAHILA C
, ROHINI COURT, DELHI

EXECUTION PETITION NO. 72/2021

IN
CC NO. 11302/2017

IN THE MATTER OF:

MS. AAKANKSHA ANAND ...DECREE HOLDER

VERSUS
.... JUDGMENT DEBTOR
SH. VINEET ANAND
AFFIDAVIT
l, Aakanksha Anand W /o Shri Vineet Anand aged about 30 years
presently R/o 429, Sainik Vihar, Pitam PUra, Deihi-11003!4, do here~y

solemnly affirm and declare as under: -

That l am the Decree Holder in the above titled execution and

am fully conversant with the facts of the case and am competent

to swear this affidavit.

That the contents of the accompanying application for seeking
mendment in execution petition which has been drafted by my
.:;."{59 under my instrUctions the contents of which are trUe
.
$><I'.,,,,,
•"1''()"'~ and correct to my knoWledge and the same may be md as part
and parcel of this affidavit as the same are not being reproduced
-~e,; ~,<.:·
o A ~ ,

herein for the sake of brevity.

..
DEPONENT
UD JAN 1:-:·

VERIFICATION:
Verified at Delhi on this 10• day of January,2021, that the contents
c5Rhe'""9'1!,J!\"davit are trU• and correct to mY knowledge and nothing

THE
0
~!:.9J"J,.!)\"tre
~~~~~~llr1:::C~~~L-
Shri/Smt /K

"'"""""" e, s~;,imi'~"''~""""_J..C..J,=-=" · · --~ .

~:: th;··~~-~iJ~i
~,-,,, •ffi•~'~~
u,ai.. N~2t~'!Jt t.;!;,; '.' . - =-~~
~,.;;;;-
been read & 00( . e arhliavit wfilch .iv GP~ ~ ' , I
<;orrect lo hls/h 1;,:ne to him/her a r.' tr
now dge. .1\ 1 ~!R82ff1N ?I
 --
103

1 ·. '
.. I

INTHECOURTOFMS,SANYAD
NORTH-WEST l>ISTRIC~: LD. M.M (MAHILA COURT),
EXECUTION PETrrio~!!' ~:/~!!oDELHI
IN
CC N0, 11"302/2017
IN THE MATTER OF:
MS. AAKANKSHA ANAND
. ...DECREE HOLDER

VERSUS

SH. VINEET ANAND .... JUDGMENT DEBTOR

NDOH:22/01/2021
INDEX

I S.NO PARTICULARS PAGE NO. CFEES

1. Amended Memo of Parties

2. Amended Execution Petition against the -

7
Judgment Debtor/Respondent in respect of - · b
the order dated 29.11.2018 passed by this
Hon'ble Court.
3. Affidavit of the Petitioner/Decree Holder 1' ,:'• 8
4. ANNEXURE•A: q -Jg R1 . It?
Copy ofOrder dated 29.11.2018 passed by
this Hon'ble Court.

5. ANNEXURE•B:
Copy of the order dated 08.01.2021 passed I -~
by the Hon'ble High Court of Delhi in Cr!;.
Rev(P) No.1243/2019.
6, List of the Movable & Immovable J..l1 r 'l--l

Properties of the Judgment Debtor.

7. Proof of Service
 104

Jr~:
DECREE·ff OLDER/APPLICANT
THROUGH:

rv?.~I\~ .
ANO NARULA & B.K WADHWA
(ADVOCATES)
OFFICE: AD-124 D, SHALIMAR BAGH,
NEW DELHI-110088
MOB:8130896099/9871122620
E-mail: baliwadhwa@gmail.com

NEWDELHI
DATED: 18.01.2021
 105

I
IN THE COURT OF MS. SANvA D . .
NORTH-WF.sr DISTRJ Al.AL: LD. M.M CMAHILA COUR
EXECUTION p ~ROHINJ COURT, onm TJ,
a.111 •ON NO. 72/2020
IN
IN THE u A'l'Tnft
'am OF:
lYJI\ •
cc N0.11302/2017
MS. AAKANKSHA ANAND
...DECREE HOLDER
SH,VINEETANAND
VERsus
.... JUDGMENT DEBTOR
AMENDED MEMO OF PARTIES
MS. AAKANKSHA ANAND
W/0 SH. VINEET ANAND
R/0: 429, SAINIKVIHAR,
PITAM PURA, DELHI-110034. .... DECREE HOLDER/APPUCANT

VERSUS
SH. VINEET ANAND
S/O SH.KIRAN KUMAR ANAND
R/0 B-6-131/132, GROUND FLOOR,
SECTOR-7, ROHINI, DELHI-110085
E-mail: vineet112S@gmaiJ.com
Moblle:9643028044

SH. VINEET ANAND THROUGH HIS

SPA HOLDER MS. VEENA)
AT: 6-G, KISSAN BASTI, W.N 1, NILOKHERI,
KARNAL, HARYANA-322117 .... JUDGMENT DEBTOR/RESPONDENT

DECREE HOLDER/APPLICANT

THROUGH:

w-,cul~
ANO NARULA & B.K WADHWA
(ADVOCATES)
OFFICE: AD-124 D, SHALIMAR BAGH,
NEW DELHl-110088
MOB:8130896099/9871122620
~ - E-~ ail: b~ wadhwa@gmail.com

NEW DELHI x=112r-1 ~[-1, J"

DATED:18.01.2021

'.'.~~.'.~flB'.2?_'
. r '
_;
 IJ~ . 106

/•ii-n.,m
' ~PT Of DELHI COURT FE~ .

. ' H---
\ %\, ,,,
JJNTHE COURT OF MS, SANYA D
NORTH-WEST DISTRJc~: LD. M.M (MAHJLA COURT)
,_

, ROHINI COURT, DELHI ,

EXECUTION PETITION NO, 72/2021
IN
CC N0, 11302/2017
IN THE MATTER OF:

MS. AAKANKSHA ANAND

.... PETITIONER
VERSUS
SH. VINEET ANAND .... RESPONDENT

The Decree Holder prays for the execution of the Decree/Order the
particulars where of are stated in the columns hereunder: -

1. No. of Suit CC NO.11302/2017

2. Name of the parties MS. AAKANJ\SHA ANAND

W/0 SH. VINEET ANAND
PRESENTLY R/O: 429, SAINIK VIHAR,
PITAM PURA, DELHI-110034.
.... DECREE HOLDER/APPLICANT

VERSUS

SH. VINEET ANAND

S/0 SH.KIRAN KUMAR ANAND
R/O B-6-131/132, GROUND FLOOR,
SECTOR-7, ROHINI, DELHI-110085
(SH. VINEET ANAND THROUGH HIS SPA
HOLDER MS. VEENA)
AT: 6-G, KISSAN BASTI, W.N 1,
NILOKHERI, KARNAL, HARYANA-322117
.... JUDGMENT DEBTOR

3. Date of Decree/order of Order dated 29.11.2018 passed by this

which execution is sought Hon'ble Court CC No. 11302/2017 in
case titled as "Aakanksha Anand Vs
Vineet Anand & Ors.". The copy of order
J!at~d ?-9tlf 2'018 passed by this Hon'ble
0

~ JLn, Jj,c\ ,

J :'·
 107

court is annexed h ere r

A. e-

4. Whether an appeal was filed

Yes. The decree holder and the judgment
against the decree/order deb~or had filed their respective appeals
under execution. agamS t the Order dated 29.11.2018
passed by this Hon'ble Court, bearing No.
190 / 2018 ·and 10/2019 respectively
and both the said appeals were disposed
off by a common judgment dated
29.08.2019 wherein the Ld. Appellate
Court was pleased to allow the appeal
filed by the D.H and dismiss the appeal of
the JD. The Ld. Appellate Court vide its
order dated 29.08.2019 was pleased to
enhance the amount of maintenance
from Rs. 50,000/· to Rs. 1,25,000/· as
interim maintenance to the Decree
Holder and her minor daughter namely
Saanvika and directed the Judgment
debtor as well as the Karta of the Kiran
Anand & Sc:ms. HUF to pay the said
enhanced maintenance from the date of
filing the DV complaint. Both the
Judgment debtor and the Karta of the
said HUF being aggrieved from the said
order filed two separate Cr!. Rev.(P)
bearing No.1263/2019(filed by JD) and
Cr!. Rev.(P) No.1243/2019(filed by
Karta of Kiran Anand & Sons HUF) and
the Hon'ble High Court of Delhi vide its
orders dated 29.11.2019 as well as
recently vide order dated 08.01.2021
was pleased to stay the order of the Ld.
Appellate Court qua the Karta of the
Kiran Anand & HUF till the next date of
hearing and di~ected the JD herein to pay
· •· - _ ..maintenance 'l and clear arrears of
;:;.. - : ~~¥;:~an\ e in accordance with the
 108

('\

order dated 29.11.201

Hon'bl c asse Ythis
m . e ourt and continue to pay the
amtenance amountto the DH Th
date of h · · e next
eanng before the Hon'ble High
Court · both the above-stated
. . of Delhi m
Revision Petitions is 23.04.2021. The
copy of the order dated 08.01.2021
passed by the Hon'ble High Court of
Delhi is annexed as ANNEXURE-B for the
kind perusal of this Hon'ble Court
5. Whether any payment has No
been received towards
satisfaction of Decree/order.

6. Whether any application was No.

made previous to this & if so
their dates & results.
7. Amount of suit along with An amount of Rs. 50,000/-(Rupees Fifty-
Five Thousand Only) per month towards
interest as per decree or any
the maintenance of the Decree Holder
other relief granted by the
and her minor daughter was passed by
decree. this Hon'ble Court in CC No. 11302/2017
titled as "Aakanksha Anand Vs Vineet
Anand & Ors." from the date of filing of
the Petitio:q till the date of disposal of
this Petition.

That in terms of the order dated

29.11.2018, the JD has failed to comply
with the directions envisaged in the said
order and have not even paid even a
single penny as of today. The Decree
Holder has been awarded interim
maintenance of@ Rs. 50,000/-(Rupees
Fifty Thousand Only) per month by this
Hon'ble Court commencing from August,
2017 up to January, 2021 totaling to
____ · _Rs.21,00,000/-(Rupees Twenty-One
-~ ~ J r s Only) in terms of the order dated
~ .F,•• f$cf .

- -- - - - - - t --:-
, D-~~r·/ -
:_\...... - {
·-
·· . .. '"•,, ·
~ -'
 109

~,, . ,-.

29.11.2018 in the
Petition He
·
' i

nee th'
~oo.
\~~@
prese xecution
folloWing is execution for
amount t .
21,00,000 • otalmg Rs.
Only), / (Rupees Twenty-One Lacs

Furthermore' th e JD desp1'te J
d' · c ear
1rect1ons of the Hon'ble H' h C
Delhi h ig ourt of
as failed to pay even a single
penny to the Applicant and her minor
daugh~er till today. Hence the present
execution petition is being filed.

8. Amount of costs if allowed by No.

Court.
9 . Against whom execution is Against Respondent/Judgment Debtor
sought. Mr. Vineet Anand

10. In what manner Courts' By issuance of warrants of attachment of

assistance is sought. the movable and immovable properties
of & against the Judgment debtor Vineet
Anand as per list attached.

The Decree Holder humbly prays that:

a) It is, therefore, most respectfully prayed that this Hon'ble court

may kindly be pleased to issue a warrant for recovery of Rs.
21,00,000/-(Rupees Twenty-One Lacs Only) w.e.f. August, 2017
till January, 2021 and thereafter towards each month's
allowance and if the Judgment debtor fails to comply by the
direction, then this Hon'ble Court may even sentence the
Judgment debtor as per law, in the interest of justice.

b) It is, therefore, most respectfully prayed that this Hon'ble court

may kindt --:~$~;,Ple»sed to issue the warrants of attachment
against th, J -- - ~ ~ ~ pdent of their movable and
·• ~ -:F=fH -. 1 .!
1
-I '11 ~n2\ ,
- - - - -- --
~ ' ~. .-.~.--·
·~· i:_ d ____ -------- -----·
,.,- __ _J
 110

immovable properties thereby attaching the articles e

O
Judgment debtor, and after sale precedes the amount be paid to
the decree holder.

cJ Any other order/ relief which this Hon'b!e Court deems fit in the
interest and justice.

AND FOR. 1'HIS ACT OF KINDNESS, THE APPLICANT AS IN

D\ITY BOUND SHALL EVER PRAY.

DECREE HOLDER/APPLICANT

THROUGH:

ANU NARULA & f!~A~~:~

SHALIMAR BAGH,
OFFICE: AD-124 ~EW DELHI-110088

MOB: 8130 8%0 99/9871122620

ail.com
. il·• baliwadhwa@gm
E-ma

•:n:mrDELHl
1-rr.n • 18 01.2021
DA1'ED. ·.
CATION;

YiJUF\ . hat the contents of

the above application are
ha Anand venfy t . his 18th day of
l Aakanks . 'f'ed at Delhi on t
• d belief ven I
true to my knowledge an

January, 2021.

.1
..... 1,.
io~1
0 .~.
 111

£coURT OF MS. SANYA DALAL·

NORTH·WEST DISTRICT RoffLIND. M.M {MAHILA COU
I ICOURT, DELHI

EXECUTl~N PETITION NO. 72/2021

IN
CC NO.11302/2017

IN THE MATTER OF:

MS. AAKANKSHA ANAND "'.DECREE HOLDER

VERSUS
.... JUDGMENT DEBTOR
SH. VINEET ANAND
AFFIDAVIT
I, Aakanksba Anand W/o Shri Vineet Anand aged about 30 years
presently R/o 429, Sainik Vihar, Pitam Pura, Delhi-110034, do hereby

solemnly affirm and declare as under: -

1. That I am the Decree Holder in the above titled execution and

am fully conversant with the facts of the case and am competent ·

to depose on oath.
That the Judgment debtor as well as the Karta of the Kiran
Anand & HUF filed two separate Cr!. Rev. P bearing
No.1263/2019 and Cr!. Rev. PNo.1263/2019 before the Hon'ble
High Court of Delhi against the judgment dated 29.08.2019
passed by the Court of Sh. Harish Kumar, Ld. AS), North-West

District, Rohini Court. Delhi.

3. That in Crl. Rev.(P) No.1263/2019 filed by the Karta of Kiran

Anand & HUF titled as "Kiran Kumar Anand Vs. Aakanksha
Anand & Ors", the Bench of HM) Mukta Gupta vide its order
dated 08.01.2021 was pleased to pass an order thereby staying
the Ld. Appellate Court's order dated 29.08.2019 till the next
date of hearing qua ~eJ(<!rta of the Kiran Anand & HUF and the
,.,-- ~ .
ID has been spJcificall ..be · · - · pay maintenance in
; ·m ~f,ci
'
 112

((t(I\~
accordance with the order d t d
W·
~-- ~:/
Hon'ble Court. a e 29.11.2018 passed by th.is

4. Hence the present execution petiti . b.

on Is emg filed as there is no
stay from any other Court

DEPONENT

VERIFICATIQNi 1·8 JAN 2021

Verified at Delhi on this 18th day of January, 2021, that the contents of

Paras of the above affidavit are true and correct to my knowledge and

nothing false has been stated therein nor has anything material being
.....-.\ Ie d.
\)c\OO~a
\~c ~c.'>
' \\'-0. t\•':l
O.'-~\\ \t\
\ \~$\I!,~

"~~) DEPONENT
I(~.., . ~h~l~~0~~-~ ~ ~-£ - i . ; ~ - ~
'JI)
l ~)., ,.
f', 11,1)
I
StoNJto/Dt6.J,.4,.~eA~r.. ~ ~ -·-· ··
~:~i1ii~;;··;;;;·;·r·;·,1:~i::.:.::.a::;:~~-~
has solemnly "'ffirmed befon;, J1"'i al_'f :'ni
On t · O H~s121W ... (.. :.. k.:::: ........
thai"i'i;~"~',,;,"t\i,;·,i'oHhe ~Ir.davit which have
been read & oxplain to him/her are true {!.
Correct to hislherik edge.
 113

ANNEXURE A 13
IN THE COURT OF MS. SANYA DALAL: LD. M.M. (MAHILA COURT),

NORTH WEST DISTRICT, ROHINI COURT, DELHI

EXECUTION PETITION NO. 72 /2020

IN

CC NO. 11302/2017

IN THE MATTER OF :

MS. AAKANSHA ANAND … DECREE HOLDER

VERSUS

SH. VINEET ANAND & ORS. … JUDGMENT DEBTORS

INDEX

S.NO PARTICULARS PAGE NOS.

1. Reply on behalf of the judgment debtor no.1/respondent

no.1 to the execution petition filed by the decree
holder/petitioner of the order dated 29.11.2018 Along 1-12
with its affidavit

2. Annexure A-1 Latest salary slip of Judgment Debtor

13-24

JUDGMENT DEBTOR NO.1/RESPONDENT NO.1

Through

Place: New Delhi

Dated:

(Aarti Manchanda & Shaishav Manu)

Advocates for the Judgment Debtor No.1/ Respondent No.1
278, Rajdhani Enclave, Pitam Pura, New Delhi-110034
Mobile: 9654185180, 9971012908
Email: aarti@legaltempo.com
 114
1

IN THE COURT OF MS. SANYA DALAL: LD. M.M. (MAHILA COURT),

NORTH WEST DISTRICT, ROHINI COURT, DELHI

EXECUTION PETITION NO. 72 /2020

IN

CC NO. 11302/2017

IN THE MATTER OF:

MS. AAKANSHA ANAND DECREE HOLDER

VERSUS

SH. VINEET ANAND & ORS. JUDGMENT DEBTORS

REPLY ON BEHALF OF THE JUDGMENT DEBTOR NO.1/RESPONDENT

NO.1 TO THE EXECUTION PETITION FILED BY THE DECREE

HOLDER/PETITIONER OF THE ORDER DATED 29.11.2018 PASSED BY THE

COURT OF Ld. MM Ms. AAKANSHA VYAS MAHILA COURT, NORTH WEST

DISTRICT, ROHINI COURT, DELHI IN CRIMINAL COMPLAINT

NO.11302/2017 TITLED AS AAKANSHA ANAND Vs VINEET ANAND &

ORS.

Most Respectfully Showeth:

1. That it is submitted that the present petition for execution of order dated

29.11.2018 passed by the court of Ld. MM Ms. Aakansha Vyas, Mahila Court,

North west District, Rohini Court, Delhi in Criminal Complaint 11302/2017

Titled as Aakansha Anand vs Vineet Anand & Ors. has been filed wherein the

Hon’ble High Court of Delhi has via its order dated 08.01.2021 in Crl.

Revision Petition 1243 of 2019 has directed the Judgment Debtor to comply

with the order of the Ld Trial Court.

 115
2

2. That it is pertinent to mention that due to his incapacity to pay the said amount

of Rs 50,000 per month Judgment Debtor had filed an appeal bearing no.10

of 2019 before the Ld. Appellate Court North West District, Rohini Court,

Delhi challenging the said order dated 29.11.2018. That another appeal was

filed by the petitioner bearing number 190/2018 seeking enhancement of the

said amount of Rs. 50,000. The Ld. Appellate Court via its common order

dated 29.08.2019 in both the appeals directed the Judgment debtor and his

father to pay an amount of maintenance to Rs 1,25,000/- enhancing from Rs.

50,000/- as per trial court order as interim maintenance to the decree holder

and her minor daughter. Thereafter both the Judgment Debtor and the father

of Judgment Debtor filed separate revision petition bearing Crl. Revision

Petition No.1243 of 2019 & 1263 of 2019 & the Hon’ble Delhi High Court

vide its order dated 29.11.2019 was pleased to stay the order of the appellate

court.

3. That on 08.01.2021 the Hon’ble High Court of Delhi was pleased to enhance

the stay dated 29.11.2019 however, it further directed the Judgment debtor to

comply with the order of the Ld. Trial Court without acknowledging the fact

that the Judgment Debtor is in no position to pay the amount of Rs 50,000 per

month as maintenance.

4. That the Judgment Debtor states that the amount of maintenance awarded to

the wife is so extravagant that it has become oppressive and unbearable for

the Judgment Debtor to pay. That the Ld. Trial Court has failed to

acknowledge that the Judgment Debtor is a person of self-esteem and has been

living separately from his family and working in Dubai since the year 2016

and is currently earning a salary of AED 1200 per month that is currently
 116
3

around Rs 32,000 Per Month as per the conversion rate today. True Copy of

his current salary slip has been annexed herewith as Annexure A-1.

5. That it is pertinent to mention that the assets mentioned in the list of assets

filed by the Decree holder does not belong to the Judgment debtor and only a

few of them belong to the father of the Judgment Debtor. It is further

submitted that the Judgment Debtor does not have any right in any of his father

property as the same are self-owned property of the father of the petitioner

and not any ancestral property over which petitioner can have any right. It is

the settled preposition of law that it is the duty of the husband to maintain the

wife and not of his parents.

6. That it is a settled legal preposition, the decree if any, must be executed only

against the Judgment Debtor and only his properties could be attached. No

properties of the parents of Judgment Debtor can be attached. However, in the

present petition under reply the list of assets provided, belongs to the father of

the Judgment Debtor and not the Judgment Debtor thus no execution order

can be passed on the basis of the said properties.

7. That it is pertinent to mention that the Judgment Debtor has an intention to

pay the maintenance as per his capability however, the amount of Rs. 50,000

is beyond his capacity as it is clear from the salary slip his current earnings is

only around Rs. 32,000 per month..

8. That it is a settled preposition of law as per Section 125 of Cr.P.C that a person

having sufficient means neglects or refuse to maintain his wife, unable to

maintain herself a magistrate of the first class may, upon proof of such neglect
 117
4

or refusal, order such person to make a monthly allowance for the

maintenance of his wife, as such magistrate thinks fit, and to pay the same to

such person as the magistrate may direct from time to time. Further if any such

person so ordered fails to comply without sufficient cause with the order, any

such magistrate may, for every breach of the order, issue a warrant for levying

the amount due in the manner for levying fines, and may sentence such person,

for the whole or any part of each month’s remaining unpaid after the execution

of the warrant, to imprisonment for a term which may extend to one month or

until payment if sooner manner. That as per the section there are two important

elements of mens rea to consider:- Firstly, That there should be sufficient

means to pay whereas in the present case the petitioner does not have the

sufficient means to pay the amount of maintenance at the rate of Rs 50,000/-

per month since the filing of application. Secondly, in regards to execution

Sub clause (3) of Section 125 Cr.P.C specifically states that the Judgment

Debtor fails to pay without having sufficient cause to comply. A perusal of

Section 125 Cr.P.C has been made hereby for the convenience of this Court:-

Order for maintenance of wives, children and parents.

(1) If any person having sufficient means neglects or refuses to maintain-

(a) his wife, unable to maintain herself, or

(b) his legitimate or illegitimate minor child, whether married or not, unable

to maintain itself, or

(c) his legitimate or illegitimate child (not being a married daughter) who has

attained majority, where such child is, by reason of any physical or mental

abnormality or injury unable to maintain itself, or

(d) his father or mother, unable to maintain himself or herself,

 118
5

a Magistrate of the first class may, upon proof of such neglect or refusal,

order such person to make a monthly allowance for the maintenance of his

wife or such child, father or mother, at such monthly rate [***], as such

Magistrate thinks fit, and to pay the same to such person as the Magistrate

may from time to time direct:

Provided that the Magistrate may order the father of a minor female child

referred to in clause (b) to make such allowance, until she attains her majority,

if the Magistrate is satisfied that the husband of such minor female child, if

married, is not possessed of sufficient means.

Provided also that an application for the monthly allowance for the interim

maintenance and expenses for proceeding under the second proviso shall, as

far as possible, be disposed of within sixty days from the date of the service

of notice of the application to such person

Explanation.- For the purposes of this Chapter,-

(a) " minor" means a person who, under the provisions of the Indian Majority

Act, 1875 (9 of 1875 ); is deemed not to have attained his majority;

(b) " wife" includes a woman who has been divorced by, or has obtained a

divorce from, her husband and has not remarried.

(2) Such allowance shall be payable from the date of the order, or, if so

ordered, from the date of the application for maintenance.

 119
6

(3) If any person so ordered fails without sufficient cause to comply with the

order, any such Magistrate may, for every breach of the order, issue a warrant

for levying the amount due in the manner provided for levying fines, and may

sentence such person, for the whole or any part of each month' s [allowances

for the maintenance or the interim maintenance and expenses of the

proceedings, as the case may be,] remaining unpaid after the execution of the

warrant, to imprisonment for a term which may extend to one month or until

payment if sooner made:

Provided that no warrant shall be issued for the recovery of any amount due

under this section unless application be made to the Court to levy such amount

within a period of one year from the date on which it became due:

Provided further that if such person offers to maintain his wife on condition

of her living with him, and she refuses to live with him, such Magistrate may

consider any grounds of refusal stated by her, and may make an order under

this section notwithstanding such offer, if he is satisfied that there is just

ground for so doing.

Explanation- If a husband has contracted marriage with another woman or

keeps a mistress, it shall be considered to be just ground for his wife' s refusal

to live with him.

(4) No Wife shall be entitled to receive an allowance from her husband under

this section if she is living in adultery, or if, without any sufficient reason, she

refuses to live with her husband, or if they are living separately by mutual

consent.
 120
7

(5) On proof that any wife in whose favour an order has been made under this

section is living in adultery, or that without sufficient reason she refuses to

live with her husband, or that they are living separately by mutual consent, the

Magistrate shall cancel the order.

9. That it is pertinent to mention that as per Section 125(3) of Cr.P.C the

execution of maintainence order has to be done in accordance to Section 421

of Cr.P.C which states as follow:-

421. Warrant for levy of fine.

(1) When an offender has been sentenced to pay a fine, the Court passing the

sentence may take action for the recovery of the fine in either or both of the

following ways, that is to say, it may-

(a) issue a warrant for the levy of the amount by attachment and sale of any

movable property belonging to the offender;

(b) issue a warrant to the Collector of the district, authorising him to realise

the amount as arrears of land revenue from the movable or immovable

property, or both, of the defaulter:

Provided that, if the sentence directs that in default of payment of the fine, the

offender shall be imprisoned, and if such offender has undergone the whole

of such imprisonment in default, no Court shall issue such warrant unless, for

special reasons to be recorded in writing, it considers it necessary so to do, or

unless it has made an order for the payment of expenses or compensation out

of the fine under section 357.

 121
8

(2) The State Government may make rules regulating the manner In which

warrants under clause (a) of sub- section (1) are to be executed, and for the

summary determination of any claims made by any person other than the

offender in respect of any property attached in execution of such warrant.

(3) Where the Court issues a warrant to the Collector under clause (b) of sub-

section (1), the Collector shall realise the amount in accordance with the law

relating to recovery of arrears of land revenue, as if such warrant were a

certificate issued under such law: Provided that no such warrant shall be

executed by the arrest or detention in prison of the offender.

10.That it is a settled preposition of law that no one shall be punished merely on

the ground of inability to fulfil a decree debt. To be poor is no crime and to

“recover” debts by the procedure of putting one in prison is too flagrantly

violative of Article 21 unless there is proof of minimal fairness of his wilful

failure to pay in spite of his sufficient means and absence of more terribly

pressing claims on his means.

11.That the simple default to discharge is not enough. There must be some

element of bad faith beyond mere indifference to pay, some deliberate or

recusant disposition in the past or, alternatively, current means to pay the

decree or a substantial part of it. This emphasises the need to establish not

mere omission to pay but an attitude of refusal on demand verging on

dishonest disowning of the obligation under the decree. Here considerations

of the debtor's other pressing needs and straitened circumstances will play

prominently.
 122
9

12.At the outset I wish to clarify that the present reply is being filed for the

purpose of reducing the maintenance amount claimed by the present execution

petition filed by the petitioner based on the order passed by the court of LD.

MM AAKANSHA VYAS NORTH WEST DISTRICT, ROHINI COURT,

DELHI IN CRIMINAL APPEAL NO. 190/2018 TITLED AS AAKANSHA

ANAND Vs VINEET ANAND & Ors dated 29.11.2018.

13.That being limited in its scope, the present reply should not be deemed to be

exhaustive and all such allegations, averments, contentions and/or statements

as contained in the petition under reply which may not have been specifically

traversed or denied by respondent no.1 herein but are contrary to the contents

of this reply should not be deemed to be admitted by reason of mere non-

traverse but should be treated as expressly denied. I also crave leave of this

Hon’ble Court to file a further reply or replies if the situation so this Hon’ble

Court so desires.

14. That the submissions which have been raised by the Judgment

Debtor/Respondent hereinabove are independent of and without prejudice to

each other and the same may be treated as such.

The prayer clause cannot be executed as per the present capacity of the

Judgment Debtor. It is denied that the Judgment Debtor deserves the order

dated 29.11.2018 to be executed by issuing a warrant for recovery of Rs.

21,00,000/- (Rupees Twenty One Lacs Only) w.e.f. August 2017 till October

2020 and thereafter towards each month allowance. Therefore the Judgment
 10
123

Debtor kindly request before this court to kindly allow the Judgment Debtor

to pay the maintenance as per his present earning capacity.

JUDGMENT DEBTOR NO.1/RESPONDENT NO.1

Through

Place: New Delhi

Dated: 25-01-2021

(Aarti Manchanda & Shaishav Manu)

Advocates for the Judgment Debtor No.1/ Respondent No.1
278, Rajdhani Enclave, Pitam Pura, New Delhi-110034
Mobile: 9654185180, 9971012908
Email: manchanda.aarti25@gmail.com
11
124
12
125
13
126
14
127
15
128
16
129
 17
130

General Security Guard

Salary Slip Confidential

Period : 1st to 29th Feb, 2020

Name: : Vineet Anand Title : Messenger

Employee ID: : MS/4561 Department : HR
Basic Salary 1200 A.E.D P.M.
Description Earning Deductions
Salary HRA 600.00 1,075/- A.E.D against Leave
Transport Allce 150.00 from 10th Feb to 25th Feb,
2020

Net Balance 875.00

Payment Date: 5-Mar-20 Amount Paid 875.00 A.E.D

Name Vineet Anand
Five Hundred dirham's Only.
Bank Name NA
Bank Account NA
IBAN Number NA

Note: Computerized generated, no signature required on salary slip.

Transparent General Security Guard Services LLC.

Office No. O7-b P-3 Empire Heights Tower Podium 03 Floor Bay Square, Dubai UAE P.O. Box No. 391426, Dubai, UAE
Landline No. 044462032 FAX No 043309732, www.transparent-security.com
 18
131

General Security Guard

Salary Slip Confidential

Period : 1st to 31st Mar, 2020

Name: : Vineet Anand Title : Messenger

Employee ID: : MS/4561 Department : HR
Basic Salary 1200 A.E.D P.M.
Description Earning Deductions
Salary 1,200.00 500 A.E.D against advance
HRA 300.00
Transport Allce 300.00
Advance Cash 500.00

Net Balance 1,300.00

Payment Date: 5-April-20 Amount Paid 1,300.00 A.E.D

Name Vineet Anand
One Thousand Three Hundred dirham's Only.
Bank Name NA
Bank Account NA
IBAN Number NA

Note: Computerized generated, no signature required on salary slip.

Transparent General Security Guard Services LLC.

Office No. O7-b P-3 Empire Heights Tower Podium 03 Floor Bay Square, Dubai UAE P.O. Box No. 391426, Dubai, UAE
Landline No. 044462032 FAX No 043309732, www.transparent-security.com
 19
132

General Security Guard

Salary Slip Confidential

Period : 1st to 30th April, 2020

Name: : Vineet Anand Title : Messenger

Employee ID: : MS/4561 Department : HR
Basic Salary 1200 A.E.D P.M.
Description Earning Deductions
Salary 1,200.00 500 A.E.D against advance
HRA 300.00
Transport Allce 300.00
Advance Cash 500.00

Net Balance 1,300.00

Payment Date: 5-May-20 Amount Paid 1,300.00 A.E.D

Name Vineet Anand
One Thousand Three Hundred dirham's Only.
Bank Name NA
Bank Account NA
IBAN Number NA

Note: Computerized generated, no signature required on salary slip.

Transparent General Security Guard Services LLC.

Office No. O7-b P-3 Empire Heights Tower Podium 03 Floor Bay Square, Dubai UAE P.O. Box No. 391426, Dubai, UAE
Landline No. 044462032 FAX No 043309732, www.transparent-security.com
 20
133

General Security Guard

Salary Slip Confidential

Period : 1st to 31st May, 2020

Name: : Vineet Anand Title : Messenger

Employee ID: : MS/4561 Department : HR
Basic Salary 1200 A.E.D P.M.
Description Earning Deductions
Salary 1,200.00 500 A.E.D against advance
HRA 300.00
Transport Allce 300.00
Advance Cash 500.00

Net Balance 1,300.00

Payment Date: 5-Jun-20 Amount Paid 1,300.00 A.E.D

Name Vineet Anand
One Thousand Three Hundred dirham's Only.
Bank Name NA
Bank Account NA
IBAN Number NA

Note: Computerized generated, no signature required on salary slip.

Transparent General Security Guard Services LLC.

Office No. O7-b P-3 Empire Heights Tower Podium 03 Floor Bay Square, Dubai UAE P.O. Box No. 391426, Dubai, UAE
Landline No. 044462032 FAX No 043309732, www.transparent-security.com
 21
134

General Security Guard

Salary Slip Confidential

Period : 1st to 30th Jun, 2020

Name: : Vineet Anand Title : Messenger

Employee ID: : MS/4561 Department : HR
Basic Salary 1200 A.E.D P.M.
Description Earning Deductions
Salary 1,200.00 500 A.E.D against advance
HRA 300.00
Transport Allce 300.00
Advance Cash 500.00

Net Balance 1,300.00

Payment Date: 5-Jul-20 Amount Paid 1,300.00 A.E.D

Name Vineet Anand
One Thousand Three Hundred dirham's Only.
Bank Name NA
Bank Account NA
IBAN Number NA

Note: Computerized generated, no signature required on salary slip.

Transparent General Security Guard Services LLC.

Office No. O7-b P-3 Empire Heights Tower Podium 03 Floor Bay Square, Dubai UAE P.O. Box No. 391426, Dubai, UAE
Landline No. 044462032 FAX No 043309732, www.transparent-security.com
 22
135

General Security Guard

Salary Slip Confidential

Period : 1st to 31st Jul, 2020

Name: : Vineet Anand Title : Messenger

Employee ID: : MS/4561 Department : HR
Basic Salary 1200 A.E.D P.M.
Description Earning Deductions
Salary 1,200.00 500 A.E.D against advance
HRA 300.00
Transport Allce 300.00
Advance Cash 500.00

Net Balance 1,300.00

Payment Date: 5-Aug-20 Amount Paid 1,300.00 A.E.D

Name Vineet Anand
One Thousand Three Hundred dirham's Only.
Bank Name NA
Bank Account NA
IBAN Number NA

Note: Computerized generated, no signature required on salary slip.

Transparent General Security Guard Services LLC.

Office No. O7-b P-3 Empire Heights Tower Podium 03 Floor Bay Square, Dubai UAE P.O. Box No. 391426, Dubai, UAE
Landline No. 044462032 FAX No 043309732, www.transparent-security.com
 23
136

General Security Guard

Salary Slip Confidential

Period : 1st to 31st Aug, 2020

Name: : Vineet Anand Title : Messenger

Employee ID: : MS/4561 Department : HR
Basic Salary 1200 A.E.D P.M.
Description Earning Deductions
Salary 1,200.00 500 A.E.D against advance
HRA 300.00
Transport Allce 300.00
Advance Cash 500.00

Net Balance 1,300.00

Payment Date: 5-Sep-20 Amount Paid 1,300.00 A.E.D

Name Vineet Anand
One Thousand Three Hundred dirham's Only.
Bank Name NA
Bank Account NA
IBAN Number NA

Note: Computerized generated, no signature required on salary slip.

Transparent General Security Guard Services LLC.

Office No. O7-b P-3 Empire Heights Tower Podium 03 Floor Bay Square, Dubai UAE P.O. Box No. 391426, Dubai, UAE
Landline No. 044462032 FAX No 043309732, www.transparent-security.com
 24
137

General Security Guard

Salary Slip Confidential

Period : 1st to 30th Sep, 2020

Name: : Vineet Anand Title : Messenger

Employee ID: : MS/4561 Department : HR
Basic Salary 1200 A.E.D P.M.
Description Earning Deductions
Salary 1,200.00 500 A.E.D against advance
HRA 300.00
Transport Allce 300.00
Advance Cash 500.00

Net Balance 1,300.00

Payment Date: 5-Oct-20 Amount Paid 1,300.00 A.E.D

Name Vineet Anand
One Thousand Three Hundred dirham's Only.
Bank Name NA
Bank Account NA
IBAN Number NA

Note: Computerized generated, no signature required on salary slip.

Transparent General Security Guard Services LLC.

Office No. O7-b P-3 Empire Heights Tower Podium 03 Floor Bay Square, Dubai UAE P.O. Box No. 391426, Dubai, UAE
Landline No. 044462032 FAX No 043309732, www.transparent-security.com
 138
ANNEXURE A 14

$~50
* IN THE HIGH COURT OF DELHI AT NEW DELHI
+ CRL.REV.P. 1263/2019
VINEET ANAND ..... Petitioner
Represented by: Ms. Aarti Manchanda, Adv.

versus

AAKANSHA ANAND & ORS. ..... Respondent

Represented by: Ms. Anu Narula, Mr. B.K. Wadhwa,
Advs. for R-1.
CORAM:
HON'BLE MS. JUSTICE MUKTA GUPTA
ORDER
% 22.01.2021
The hearing has been conducted through Video Conferencing.
CRL.M.A.967/2021 (exemption)
Exemption allowed subject to just exception.
CRL.M.A.966/2021 (modification of order dated 8th January, 2021)
1. By this application the petitioner seeks modification of the order dated
8th January, 2021.
2. Vide order dated 8th January, 2021 this Court simply renotified the
revision petition for 23rd April, 2021. Hence, no modification of that order
can be granted.
3. Application is dismissed.
4. Order be uploaded on the website of this Court.

MUKTA GUPTA, J.
JANUARY 22, 2021
‘ga’

Signature Not Verified

Digitally Signed By:SANDEEP
KUMAR Crl. Rev. P. 1263/2019 Page 1 of 1
Signing Date:23.01.2021 14:08:04
This file is digitally signed by PS
to HMJ Mukta Gupta
 139

$~45
* IN THE HIGH COURT OF DELHI AT NEW DELHI
+ CRL.REV.P. 1243/2019
CRL.M.A. 2729/2021 (for modification)

KIRAN KUMAR ANAND ..... Petitioner

Represented by: Mr. Mayank Sawhney, Advocate with
Ms. Kanika Sawhney & Mr. Atal
Kumar, Advocates.

Versus

AAKANKSHA ANAND & ORS. ..... Respondents

Represented by: Mr. Chander M. Maini, Advocate
with Mr. B.K. Wadhwa, Advocate for
R-1.
Mr. Shaishav Mann, Advocate for
R-2/applicant.

CORAM:
HON'BLE MS. JUSTICE MUKTA GUPTA

ORDER
% 19.02.2021
The hearing has been conducted through Video Conferencing.
CRL.M.A. 2730/2021 (exemption)
1. Exemption allowed subject to just exceptions.
2. Application is disposed of.
CRL.M.A. 2729/2021 (for modification)

1. By this application the applicant/respondent No.2 seeks modification

of the order dated 8th January, 2021.

Signature Not Verified

Digitally Signed By:JUSTICE
Crl. Rev. P. 1243/2019 PageGUPTA
MUKTA 1 of 2
Signing Date:20.02.2021
09:05:37
 140

2. By order dated 8th January, 2021, this Court had only reiterated the
order dated 29th August, 2019, the modification wherein has not been
challenged.
3. Application is accordingly dismissed.
4. Order be uploaded on the website of this Court.

MUKTA GUPTA, J.
FEBRUARY 19, 2021
vk

Signature Not Verified

Digitally Signed By:JUSTICE
Crl. Rev. P. 1243/2019 PageGUPTA
MUKTA 2 of 2
Signing Date:20.02.2021
09:05:37
 141

ANNEXURE A 15
MANU/DE/0166/2004
Equivalent Citation: 2004(18)AIC 810, 110(2004)DLT546, I(2004)DMC 568, 2004(74)DRJ99, 2004(3)RC R(C ivil)362

IN THE HIGH COURT OF DELHI

C.R. No. 71 of 2002
Decided On: 15.03.2004
Appellants: Annurita Vohra
Vs.
Respondent: Sandeep Vohra
Hon'ble Judges/Coram:
Vikramajit Sen, J.
Counsels:
For Appellant/Petitioner/plaintiff: Sudarshan Rajan, Adv
For Respondents/Defendant: Geeta Luthra, Avtar Singh and Sanjiv Sahai, Advs.
Case Note:
Civil Procedure Code, 1908 - Section 115--Revision against grant of
maintenance pendente lite--Such order is an interim measure which does
not call for interference in revision--Error committed by the Trial Court in
granting maintenance of Rs. 6000/- as against income of husband assessed
at Rs. 32000/- --The amount of maintenance enhanced to Rs. 15000/- per
month--Criminal Procedure Code, 1973, Section 125--Hindu Marriage Act,
1955, Section 24.
JUDGMENT
Vikramajit Sen, J.
1 . This revision petition is directed against the Order dated 20.8.2001 whereby the
Additional District Judge had granted maintenance at the rate of Rs. 6,000/- per
month to the Petitioner/Applicant/Wife for herself and her minor children. The Court
had come to the conclusion that the net disposable income of the
Respondent/Husband is about Rs.32,000/- per month which is exclusive of his perks
and reimbursements. It had also been found that there were no dependents other
than the wife and children. In Jasbir Kaur Sehgal v. District Judge, Dehradun and
Ors., MANU/SC/0835/1997 : AIR1997SC3397 , it has been observed that - "no set
formula can be laid for fixing the amount of maintenance. It has, in the very nature of
things, to depend on the facts and circumstances of each case. Some scope for
leverage can, however, be always there. The court has to consider the status of the
parties, their respective needs, the capacity of the husband to pay having regard to
his reasonable expenses for his own maintenance and of those he is obliged under
the law and statutory but involuntary payments or deductions. The amount of
maintenance fixed for the wife should be such as she can live in reasonable comfort
considering her status and the mode of life she was used to when she lived with her
husband and also that she does not feel handicapped in the prosecution of her case.
At the same time, the amount so fixed cannot be excessive or extortionate".
2 . In other words the court must first arrive at the net disposable income of the

22-03-2021 (Page 1 of 3) www.manupatra.com Aarti Manchanda

 142

Husband or the dominant earning spouse. If the other spouse is also working these
earnings must be kept in mind. This would constitute the Family Resource Cake which
would then be cut up and distributed amongst the members of the family. The
apportionment of the cake must be in consonance with the financial requirements of
the family members, which is exactly what happens when the spouses are one
homogeneous unit. Ms. Geeta Luthra, learned counsel for the respondent had
fervently contended that normally 1/5th of the disposable income is allowed to the
Wife. She has not shown any authority or precedent for this proposition and the only
source or foundation for it may be traceable to Section 36 of the Indian Divorce Act,
1869. This archaic statute mercifully does not apply to the parties before the Court,
and is a vestige of a bygone era where the wife/woman was considered inferior to the
husband as somewhat akin to his chattels. The law has advanced appreciably, and for
the better. In the face of Legislatures reluctant to bring about any change over fifty
years ago the Courts held that the deserted wife was entitled to an equal division of
matrimonial assets. I would be extremely loath to restrict maintenance to 1/5th of the
Husband's income where this would be insufficient for the Wife to live in a manner
commensurate with her Husband's status or similar to the lifestyle enjoyed by her
before the marital severance. In my view, a satisfactory approach would be to divide
the Family Resource Cake in two portions to the Husband since he has to incur extra
expenses in the course of making his earning, and one share each to other members.
3 . Observations in similar vein have been made by a Learned Single Judge of this
Court in Harminder Kaur vs. Sukhwinder Singh 2002 6 AD (DELHI) 797. S.N. Kapoor,
J. had opined that one should not be oblivious of the fact that equal status has been
given to the Indian women under Articles 14 and 16 of the Constitution and that she
should live according to the status of her husband along with the child of the parties.
The Learned Judge had ordered that the income has to be equitably apportioned for
maintenance of wife and the child. In his opinion the income should have been
divided into five units, two units for each of the parents and one for the young child.
On a disposable income of Rs.12,000/- he had granted Rs.7,200/- per month for the
maintenance of the wife and the child.
4 . Whichever method one may adopt, on a disposable income of Rs.32,000/- per
month, the wife and child would ordinarily be entitled to approximately Rs.18,000/-.
It has been vehemently argued that since the Petitioner/Wife has set up her
residence, on her own volition, with her affluent parents, she does not require to pay
rentals etc. but this factor has been rejected by the Court.
5. The determination of maintenance pendente lite is essentially an interim measure
which normally does not call for interference under Section 115 of the Code of Civil
Procedure, especially after the amendments carried out in the Code of Civil
Procedure. On an understanding of the law as enunciated in Shiv Shakti Coop.
Housing Society, Nagpur vs. Swaraj Developers and Ors., MANU/SC/0335/2003 :
[2003]3SCR762 , no scope for discussion on this question remains.
6 . However, in the present circumstances the Trial Court has committed an error in
the exercise of jurisdiction vested in it of such proportions as would necessitate
interference by this Court. The impugned Order is modified to the extent that in place
of Rs. 6,000/- per month the Husband shall pay monthly maintenance of Rs.15,000/-
keeping in view the tender age of the child of the parties. It may be reiterated that
whenever a change in the circumstances occurs, the affected party can seek
modification of interlocutory orders such as interim maintenance. As the children
starts going to school, the financial needs of the Wife would increase. Such

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 143

adjudication should be left to the Trial Court.

7. The revision petition is allowed in these terms.

© Manupatra Information Solutions Pvt. Ltd.

22-03-2021 (Page 3 of 3) www.manupatra.com Aarti Manchanda

ANNEXURE A 16 144
(COLLY.)
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ANNEXURE A 17 195
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141
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143 200
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ANNEXURE A 18
ANNEXURE A 19 202
205
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ANNEXURE A 20
204
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ANNEXURE A 21
207
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 210

IN THE HON’BLE HIGH COURT OF DELHI AT NEW DELHI

Crl. Misc.Application. _________/ 2021

In
Criminal Revision Petition No. 1243 of 2019
IN THE MATTER OF:
Vineet Anand …Applicant/Petitioner
Versus
Aakansha Anand & Ors … Respondents

APPLICATION UNDER SECTION 482 CR.P.C FOR GRANT OF

EXEMPTION FROM FILING OF CERTIFIED COPIES, ORIGINALS,

DIM ANNEXURES

MOST RESPECTFULLY SHOWETH:

1. That it is stated that an Application under Section 482 Cr. P.C. 1973 for

Stay of Execution No. 72 of 2020 against the Order dated 29.11.2018 in

CC No. 11302 of 2017 and/or reduction/modification of the monthly

maintenance during the pendency of Criminal Revision Petition No. 1263

of 2019 has been filed by the applicant, the contents of which are not

repeated here for the sake of brevity.

2. That due to urgency in the matter, the Applicant is relying upon certain

illegible, dim, handwritten, xerox documents and untranslated documents since

they are the copies of original documents being relied upon by the Applicant

in the case at hand.

3. The Applicant therefore pray for being exempted from filing original as well

as typed copy of the annexure(s) and be allowed to file true copy of the same.

4. It is stated that this application is bonafide and in the interest of justice.

 211

PRAYER

It is most humbly prayed therefore:

a) Exempt the Appellants from filing original as well as true typed copy of

the annexure(s);

b) pass any other order/orders which this Hon’ble Court may be pleased in

the facts & circumstances of the case.

AND FOR THIS ACT OF KINDNESS THE PETITIONER SHALL BE

DUTY BOUND AND SHALL EVER PRAY.

Applicant
(Through Special Power of Attorney Holder)
THROUGH
New Delhi
Dated: 22.03.2021 Aarti Manchanda
Advocate for the Applicant
278, 1st floor, Rajdhani Enclave,
Britania Rani Bagh Road, Pitampura,
New Delhi-110034
M: 9654185180
E: aarti@legaltempo.com
212
3/22/2021 Gmail - Advance Service: Criminal Misc App-CRL 1263 of 2019- VINEET ANAND VS AAKANKSHA ANAND & ORS

Aarti Manchanda, Advocate <manchanda.aarti25@gmail.com>

Advance Service: Criminal Misc App-CRL 1263 of 2019- VINEET ANAND VS

AAKANKSHA ANAND & ORS
1 message

Aarti Manchanda, Advocate <manchanda.aarti25@gmail.com> Mon, Mar 22, 2021 at 4:52 PM

To: "ADV.B.K. Wadhwa" <baliwadhwa@gmail.com>
Cc: aarti@legaltempo.com

Dear Sir,

Please find attached herewith the Criminal Miscellaneous application filed by us on behalf of Mr. Vineet Anand in
Criminal Revision Petition No. 1263 of 2019 titled "Vineet Anand vs Aakanksha Anand & Ors".

Application without book mark.pdf

Regards,
Aarti Manchanda
Advocate
9654185180

https://mail.google.com/mail/u/4?ik=ec7afae306&view=pt&search=all&permthid=thread-a%3Ar-3358939678710301441&simpl=msg-a%3Ar-7685… 1/1