IN THE HIGH COURT OF DELHI AT NEW DELHI
W.P. (Crl) No. _______ of 2024
IN THE MATTER OF: -
Meena Dahiya …Petitioner
Versus
State & Anr. …Respondents
INDEX
S.No. PARTICULARS C/FEE PAGE
NO.
1.
Letter of Service
2. Urgent Application
3. List of Dates and Events
4. Memo of Parties
5. Criminal Writ Petition under Article
226/227 of the Constitution of India
read with Section 530 of The
Bharatiya Nagarik Suraksha Sanhita
2023 for Issuance of writ in the nature
of certiorari or any other writ or
order/s, direction/s for quashing of
FIR bearing no. 61/2023 registered at
police station North Avenue, New
Delhi.
7. ANNEXURE- A: FIR bearing no.
0061/2023 registered at police station
North Avenue, New Delhi along with,
True Typed and Translated Copy.
8. ANNEXURE- B: Copy of the Letter
dated 28.02.2024 issued by
Respondent no. 2 to Director,
ABVIMs and Dr RML Hospital, New
Delhi.
9. ANNEXURE- C: Copy of the Letter
dated 09.03.2024 issued by Inquiry
Officer of Disciplinary Authority to Dr.
Vijay Kumar Vigilance Officer of Dr.
RML Hospital, New Delhi.
10. ANNEXURE – D: Copy of the order
dated 08.03.2024 passed by Dr. Ajay
Shukla, Director & Medical
Superintendent, Ram Manohar Lohia
Hospital, New Delhi.
11. ANNEXURE – E: Copy of the letter
dated 22.06.2024 issued by Vijay
Prakash Nodiya Dy. Director
Administration to SHO, PS North
Avenue.
13. ANNEXURE – F (Colly): Copy of
Identity proof of petitioner and
respondent no. 2 alongwith
photographs.
13. Application u/s. 530 BNSS for stay of
Proceedings before trial court
alongwith supporting affidavit.
15. Vakalatnama of Petitioner
16. Vakalatnama of Respondent no. 2
17. Court Fees
FILED BY:
(RISHABH THAKUR & ASSOCIATES)
Advocate (D-2842/2017)
CH NO 431 4th Floor
Rohini, Delhi
Mobile No. 8287828816
Email: adv.rishabhthakur@gmail.com
New Delhi
Dated: .07.2024
IN THE HIGH COURT OF DELHI AT NEW DELHI
W.P. (Crl) No. _______ OF 2024
IN THE MATTER OF: -
Meena Dahiya …Petitioner
Versus
State & Anr. …Respondents
GROUNDS OF URGENCY
Kindly treat the accompanying petition as an urgent one in
accordance with High Court Rules and Orders.
The grounds of urgency are: -
That since the petitioner is law abiding citizen of India and the
petitioner seeks the quashing of the FIR bearing no. 0061/2023
registered at police station North Avenue under section 186/332/353
Indian penal code & Section 4 Medicare service persons and
Medicare service institutions act through this writ petition. Hence the
present petition should be considered urgent in nature.
FILED BY:
(RISHABH THAKUR & ASSOCIATES)
Advocate (D-2842/2017)
CH NO 431 4th Floor
Rohini, Delhi
Mobile No. 8287828816
Email: adv.rishabhthakur@gmail.com
New Delhi
Dated: .07.2024
IN THE HIGH COURT OF DELHI AT NEW DELHI
W.P. (Crl) No. _______ of 2024
IN THE MATTER OF: -
Meena Dahiya …Petitioner
Versus
State & Anr. …Respondents
LETTER OF SERVICE
To
The Standing Counsel
High Courts Lawyers Chambers
4th Floor, Delhi High Court,
New Delhi
Respected Sir,
Kindly acknowledge the copy of Writ Petition under Article 226/227 of
the Constitution of India R/w Section 530 BNSS. for issuance of writ,
order or direction(s) in the nature of Certiorari or any other writ thereby
quashing the FIR bearing no. 0061/2023 registered at police station
North Avenue under section 186/332/353 Indian penal code & Section
4 Medicare service persons and Medicare service institutions act
against the petitioner. This quashing petition will be coming before the
Hon’ble High Court on ___.07.2024 so you may kindly be present at
the time of hearing of this petition. This is for your kind information and
necessary action.
Thanking you,
FILED BY:
(RISHABH THAKUR & ASSOCIATES)
Advocate (D-2842/2017)
CH NO 431 4th Floor
Rohini, Delhi
Mobile No. 8287828816
Email: adv.rishabhthakur@gmail.com
New Delhi
Dated: .07.2024
IN THE HIGH COURT OF DELHI AT NEW DELHI
W.P. (Crl) No. _______ OF 2024
IN THE MATTER OF: -
Meena Dahiya …Petitioner
Versus
State & Anr. …Respondents
CRIMINAL WRIT PETITON UNDER ARTICLE 226/227 OF THE
CONSTITUTION OF INDIA READ WITH SECTION 530 OF THE
BHARATIYA NAGARIK SURAKSHA SANHITA 2023 FOR
ISSUANCE OF WRIT IN THE NATURE OF CERTITORARI OR ANY
OTHER WRIT OR ORDER/S, DIRECTION/S FOR QUASHING OF
FIR BEARING NO. 0061/2023 REGISTERED AT POLICE STATION
NORTH AVENUE UNDER SECTION 186/332/353 IPC & SECTION
4 MSPMI ACT REGISTERED AGAINST THE PETITIONER AND
SUBSEQUENT PROCEEDINGS EMANATING THEREFROM ON
THE GROUND OF COMPROMISE.
To,
THE HON’BLE CHIEF JUSTICE
AND HIS COMPANION JUDGES
OF THE HIGH COURT OF DELHI
AT NEW DELHI.
MAY IT PLEASE YOUR LORDSHIP: -
MOST RESPECTFULLY SHOWETH: -
1. That the petitioner is filing the present petition for issuance of
writ in the nature of certiorari or any other writ or order/s,
direction/s for quashing of FIR bearing no. 0061/2023
registered at police station North Avenue under Section
186/332/353 Indian penal code & Section 4 Medicare service
persons and Medicare service institutions act registered on
04.08.2023 and subsequent proceedings emanating there from
on the ground of compromise.
2. That the petitioner herein is the law-abiding citizen of India and
have full faith in the administration of justice. It is pertinent to
mention here that the petitioner is working as Sr. Nursing
Officer in RML Hospital and respondent no.2 is HOD Psychiatry
in RML Hospital, New Delhi.
4. THAT THE BRIEF FACTS OF THE CASE ARE: -
i) That the petitioner is employed in RML Hospital as Sr. Nursing
officer and respondent no.2 is also employed as HOD in
Psychology Department in RML Hospital, Delhi.
ii) That the daughter of the petitioner Miss Ojaswi is the student of
Psychology of Delhi University and Miss. Ojaswi was directed
by the college for the One Month Internship under respondent
no.2 which was to be started from 01.08.2023.
iii) That on 02.08.2023 the daughter of petitioner was not allowed
to take the classes and she was kicked out of the class on the
pretext of incomplete documents due to this reason petitioner
first time approached to respondent no.2 on the same day
regarding internship of her daughter.
iii) That on 02.08.2023 petitioner got to know from the respondent
no.2 that daughter of petitioner had applied for internship with
letter of recommendation dated 30.06.2023 from her college for
internship from 01.07.2023 to 01.08.2023 and petitioner was
advised to get the letter of recommendation changed for tenure
w.e.f 01.08.2023.
iv) That on making contacts to the college, daughter of petitioner
got to know that college will not provide fresh letter of
recommendation to the student.
v) That on 03.08.2023 petitioner got the approval letter for the
internship from the office of Medical Superintendent, RML
Hospital after getting the documents checked and on
04.08.2023 petitioner again went to meet the respondent no.2
to get the internship classes started but due to temperamental
differences, some altercation occurred between the petitioner
and the respondent no.2 as the fresh letter of recommendation
was demanded by the respondent no.2 for the internship.
iv) That on the compliant of complainant/ respondent no.2 to
Medical Superintendent, ABVIMs and RML Hospital, FIR
bearing no. 0061/2023 registered at police station North
Avenue under section 186/332/353 Indian penal code & Section
4 Medicare service persons and Medicare service institutions
act alleging therein:
a. That the on 04.08.2023 petitioner came to the room of
respondent no.2 with the approval application for the joining.
b. That after perusing through the application, respondent no.2
remarked very gently that the letter of recommendation was not
rectified but she will be allowed to join but petitioner started
screaming and slapped her on her left cheek and left the room
and petitioner further stated that she will assault the respondent
no.2 further and left the premises despite female guard trying
to stop her.
The true copy of FIR bearing no. 0061/2023 registered at police
station North Avenue under section 186/332/353 Indian penal
code & Section 4 Medicare service persons and Medicare
service institutions act with true typed and translated copy is
annexed herewith as ANNEXURE A.
v) That due to the discussion in the chamber of the Director,
ABVIMs & RML Hospital in presence of Registrar, ABVIMs and
after the apology given in writing by the petitioner to the
respondent no.2 for her misbehavior/indecent behavior,
respondent no.2 decided not to pursue any disciplinary
proceedings against petitioner. Therefore, due to indulgence of
director and registrar, RML Hospital, both the parties have
settled the dispute amicably.
Copy of the Letter dated 28.02.2024 issued by
Respondent no. 2 to Director, ABVIMs and Dr RML Hospital,
New Delhi for not to pursue any case against petitioner is
annexed herewith as ANNEXURE B.
vi). That after considering the mutual understanding of both the
parties, the Disciplinary authority has decided to drop the
disciplinary proceeding against the petitioner.
Copy of the Letter dated 09.03.2024 issued by Inquiry Officer of
Disciplinary Authority to Dr. Vijay Kumar Vigilance Officer of Dr. RML
Hospital, New Delhi to drop the disciplinary proceeding against the
petitioner is annexed herewith as ANNEXURE C.
vii). That on completion of the inquiry conducted by the inquiry
authority viz Sh. Murari Lal Sharma, Registrar, RML Hospital
has submitted that the charges against the petitioner are settled
on basis of mutual understanding by both parties. Therefore,
suspension of petitioner from the service was revoked with
immediate effect and petitioner was warned not to exert
improper behavior and be more careful in future.
Copy of the order dated 08.03.2024 passed by Dr. Ajay Shukla,
Director & Medical Superintendent, Ram Manohar Lohia
Hospital, New Delhi is annexed herewith as ANNEXURE D.
viii). That in view of mutual settlement between both the parties,
Vijay Prakash Nodiya, Dy. Director Administration, RML
Hospital, Delhi gave written notice to the SHO, PS North
Avenue, Delhi and requested that this institute do not want to
pursue this case further and same need to be closed.
Copy of the letter dated 22.06.2024 issued by Vijay Prakash Nodiya
Dy. Director Administration to SHO, PS North Avenue is annexed
herewith as ANNEXURE E.
5. That petitioner is filing the present petition inter-alia on the
following grounds amongst others: -
GROUNDS
A. Because the petitioner and respondent no.2 have compromised
all disputes amicably and Respondent No.2 have no further
claim of either civil or criminal nature against the petitioner.
Copy of id proofs of petitioners and respondent no.2 alongwith
their photographs are annexed herewith as ANNEXURE F
(COLLY).
B. Because the FIR in question discloses the criminal disputes
between the parties. It is pertinent to mention here that all the
disputes between petitioner and respondent no.2 have been
amicably resolved due to intervention of the Director and
Registrar, ABVIMS & RML Hospital, New Delhi.
C. Because the Hon’ble Supreme court of India as well this
Hon’ble court has time and again held that “it the finest hour in
the judiciary when the parties end their differences themselves
by way of compromise which saves not only the precious time
of the courts but also become a factor whereby harmony
prevails in the society”.
D. Because the Hon’ble Apex Court in Gian Singh vs State of
Punjab has held:
“…….But the criminal cases having overwhelmingly and
pre-dominatingly civil flavor stand on different footing for
the purposes of quashing, particularly the offences
arising from commercial, financial, mercantile, civil,
partnership or such like transactions or the offences
arising out of matrimony relating to dowry, etc. or the
family disputes where the wrong is basically private or
personal in nature and the parties have resolved their
entire dispute. In this category of cases, High Court may
quash criminal proceedings if in its view, because of the
compromise between the offender and victim, the
possibility of conviction is remote and bleak and
continuation of criminal case would put accused to great
oppression and prejudice and extreme injustice would be
caused to him by not quashing the criminal case despite
full and complete settlement and compromise with the
victim. In other words, the High Court must consider
whether it would be unfair or contrary to the interest of
justice to continue with the criminal proceeding or
continuation of the criminal proceeding would tantamount
to abuse of process of law despite settlement and
compromise between the victim and wrongdoer and
whether to secure the ends of justice, it is appropriate
that criminal case is put to an end and if the answer to
the above question(s) is in affirmative, the High Court
shall be well within its jurisdiction to quash the criminal
proceeding…”
E. Because it is pertinent to mention here that the Hon’ble Apex
Court in B.S. Joshi and Ors.v. State of Haryana and Anr. in
Appeal (Crl.) 383 of 2003, acts as guide for the High Court to
determine whether to exercise the powers under Section 482,
Cr.P.C. in a given case or not.
“The Court held in that matter that there was no
general proposition limiting power of quashing the
criminal proceedings or FIR or complaint as vested
in Section 482 or extraordinary power under Article
226 of the Constitution of India. Therefore, if for the
purpose of securing the ends of justice, quashing
of FIR becomes necessary. Section 320 would not
be a bar to the exercise of power of quashing. It is,
however, a different matter depending upon the
facts and circumstances of each case whether to
exercise or not such a power.”
F. Because the Hon’ble High Court of Punjab and Haryana at
Chandigarh in Nirmal Singh Vs. State of Punjab and Another
allowed the petition and quashed the FIR stating that: -
“compromise in modern society is the sine qua
non of harmony and orderly behavior. As observed
by Hon’ble Justice Krishna Iyer., the finest hour of
justice arrives propitiously when parties despite
falling apart, bury the hatchet and weave a sense
of fellowship of reunion. Inherent powers of the
court under section 482 Cr.P.C is not limited to the
matrimonial cases alone. The court has wide
powers to quash the proceedings even in non-
compoundable offences in order to prevent the
abuse of process of law and to secure ends of
justice, notwithstanding bar under section 320
CrPC. Exercise of power in a given situation will
depend on facts of each case. The duty of the court
is not only to decide a lis between the parties after
a protracted litigation but it is a vital and extra-
ordinary instrument to maintain and control social
order. The resolution of dispute by way of
compromise between two warring groups should
be encouraged unless such compromise is
abhorrent to lawful composition of society or would
promote savagery”.
G. Because the Hon’ble High Court of Delhi in Basara versus State
reported as 2007(97) DRJ 381 while quashing the held in the
para No.14 & 15 of Judgment;
“In the present case since the parties have
amicably compromised the subject of matter of the
FIR in question among themselves, no useful
purpose is likely to be served by continuing with
the aforementioned criminal case registered
against the petitioners. Petitioners and
complainant are residents of the same locality.
Peace has been brought in locality with the
intervention of the well-wishers of the locality.
When there is peace in locality, there will be peace
in the town. When there is peace in the town, there
will be peace in city. When there is peace in city,
there will be peace in State. When there is peace
in State, there will be peace in Country. It is
therefore in the interest of the society that
permission to quash the FIR in question is granted
by this Court. Moreover, since petitioners and
complainant are resident of same locality,
continuation of criminal proceedings will only
revive the bitter memories of the past and may lead
to further enmity between them.”
H. Because the Hon’ble High Court of Delhi in the case titled as
Rishi Raj & ORS. Vs. State reported as 2009 (1) JCC 265, while
quashing the FIR and Proceedings, arising therefrom held in
Para 6 of the judgment that:
“In light of the above referred factual and legal
position, I am of the considered view that it would
be an exercise in futility to proceed with the trial of
this case as the injured as well as the accused
party have compromised and settled the disputes
with each other for all the times to come. They
have also assured to this court that in future they
will maintain good behaviour and would not indulge
in such activities.”
I. Because the Hon’ble High Court of Delhi in the case titled as
Mahender Koli @ Chiddi & ORS. Vs. State in Crl.
MC.3887/2011 and Crl. MA. 18344/2011, while quashing the
FIR No.554/2007 in a case under Section 308/323/427/
452/506/34 Indian Penal Code, 1860 which was registered
against the petitioner Nos.1 to 5 on the complaint of petitioner
No.6, Chander Bhan at PS Keshav Puram, held in Para 8 of the
judgment that:
“Keeping in view the fact that all the petitioners
stay in the same locality to maintain peace and
harmony in the society and to put an end to their
enmity, I deem it proper to quash the present FIR.
Ordered accordingly.”
J. Because the Hon’ble High Court of Delhi in the case titled as
Navrang Pal & ORS. Vs. State in Crl. MC.2328/2004, while
quashing the FIR held that:
“High Court while exercising inherent powers could
quash a criminal proceeding on a complaint in a non-
compoundable case and that Section 320 of the Code
could not limit or affect the powers under Section 482 of
the Code.”
6. That the petitioner craves leave of this Hon’ble Court to urge any
other ground or grounds at the time of hearing of the present
case.
7. That in these circumstances, it is prayed that it would be in the
fitness of things and to secure the ends of justice that FIR bearing
no. 0061/2023 registered at police station North Avenue under
Section 186/332/353 Indian penal code & Section 4 Medicare
service persons and Medicare service institutions act registered
on 04.08.2023 and subsequent proceedings emanating there
from on the ground of compromise, be quashed.
8. That the petitioner has not filed any other or similar petition either
before this Hon’ble Court or before any other court for same or
similar relief.
13. That the annexures annexed with the petition are true copies of
their respective originals.
PRAYER
It is, therefore, most respectfully prayed that this Hon’ble Court may
kindly be pleased to: -
a) Quash the FIR bearing no. 0061/2023 registered at police
station North Avenue under Section 186/332/353 Indian penal
code & Section 4 Medicare service persons and Medicare
service institutions act registered on 04.08.2023 and
subsequent proceedings emanating there from in the interest of
justice;
b) Pass any other order or direction which this Hon’ble Court may
deem fit and proper under the facts and circumstances of the
case.
FILED BY:
(RISHABH THAKUR & ASSOCIATES)
Advocate (D-2842/2017)
CH NO 431 4th Floor
Rohini, Delhi
Mobile No. 8287828816
Email: adv.rishabhthakur@gmail.com
New Delhi
Dated: .07.2024
IN THE HIGH COURT OF DELHI AT NEW DELHI
Crl M.No. OF 2024
In
W.P. (Crl) No. _______ OF 2024
IN THE MATTER OF: -
Meena Dahiya …Petitioner
Versus
State & Anr. …Respondents
APPLICATION UNDER SECTION 530 BNSS FOR STAY OF
INVESTIGATION IN FIR BEARING NO. 0061/2023
REGISTERED AT POLICE STATION NORTH AVENUE
UNDER SECTION 186/332/353 IPC & SECTION 4 MSPMI
ACT REGISTERED ON 04.08.2023 ON BEHALF OF
PETITIONER.
MAY IT PLEASE YOUR LORDSHIP: -
MOST RESPECTFULLY SHOWETH: -
1. That the petitioner is filing the accompanying petition under
article 226/227 of the Constitution Of India read with Section
530 of The Bharatiya Nagarik Suraksha Sanhita 2023 for
issuance of writ in the nature of certiorari or any other writ or
order/s, direction/s for quashing of FIR bearing no. 0061/2023
registered at police station North Avenue under section
186/332/353 IPC and Section 4 MPMSI Act against the
petitioner on 04.08.2023 and subsequent proceedings
emanating therefrom on the ground of compromise qua the
petitioner. The contents of the same are not being repeated
herein for the sake of brevity and may be treated as part and
parcel of the present application.
2. That the petitioner and respondent no.2 have settled their
disputes vide letter dated 28.02.2024 issued by respondent
no.2 to Director ABVIMs and Dr RML Hospital to drop the
Disciplinary proceedings against Petitioner and order dated
08.03.2024 passed by Dr. Ajay Shukla, Director & Medical
Superintendent, RML Hospital to exonerate the charges levied
against petitioner on the basis of mutual understanding of
petitioner and respondent no.2.
3. That the petitioner has a very good prima facie case in his favor
and is every likelihood to succeed.
4. That since the disputes between the parties have resolved and
they have settled their disputes amicably. Thus, pursuing the
investigation in FIR bearing no. 0061/2023 registered at police
station North Avenue under section 186/332/353 IPC and
Section 4 MPMSI Act will be futile, therefore in this fact and
circumstances the investigation in the FIR in question be
stayed.
PRAYER
It is, therefore, most respectfully prayed that this Hon’ble Court may
kindly be pleased to :-
a) Stay the proceedings of trial court in FIR bearing no. 0061/2023
registered at police station Crime North Avenue under section
186/332/353 IPC and Section 4 MPMSI Act till the disposal of
the present petition;
b) Pass any other order or direction which this Hon’ble Court may
deem fit and proper under the facts and circumstances of the
case.
FILED BY:
(RISHABH THAKUR & ASSOCIATES)
Advocate(D-2842/17)
CH NO 431 4th Floor
Rohini, Delhi
Mobile No. 8287828816
Email: adv.rishabhthakur@gmail.com
New Delhi
Dated: .07.2024
IN THE HIGH COURT OF DELHI AT NEW DELHI
Crl M.No. OF 2024
In
W.P. (Crl) No. _______ OF 2024
IN THE MATTER OF: -
Meena Dahiya …Petitioner
Versus
State & Anr. …Respondents
MEMO OF PARTIES
Smt. Meena Dahiya
W/o Sh. Satish Kumar
R/o ______________
______________-124412 …Petitioner
Versus
1. State
Through Govt. of NCT of Delhi,
New Delhi
2. Smt. Meena Chandra
D/o ___________
R/o _____________
______________-110039 …..Respondents
FILED BY:
(RISHABH THAKUR & ASSOCIATES)
Advocate(D-2842/17)
CH NO 431 4th Floor
Rohini, Delhi
Mobile No. 8287828816
Email: adv.rishabhthakur@gmail.com
New Delhi
Dated: .07.2024
LIST OF DATES AND EVENTS
DATE EVENTS
IN THE HIGH COURT OF DELHI AT NEW DELHI
Crl M.No. OF 2024
In
W.P. (Crl) No. _______ OF 2024
IN THE MATTER OF: -
Meena Dahiya …Petitioner
Versus
State & Anr. …Respondents
AFFIDAVIT
I, Meena Dahiya, aged about _____ years D/o ________, R/o
_______________, do hereby solemnly affirm and declare as under: -
1. That I am the Petitioner in the above noted case and as such am
fully conversant with the facts and circumstances of the case and
competent to depose the present affidavit.
2. That the accompanying writ petition has been drafted under my
instructions which has been read and understood by me and I say
that the averments made therein on the basis of record and to the
best of my knowledge and believed to be correct.
3. That the contents of List of Dates are drafted by my counsel which
are true to best of my knowledge and the records maintained by
me.
4. That the contents of the para _____ and para _____ of the writ
petition are drafted by my counsel and based on legal advice
received, which I believe to be true.
5. That I say that Annexures of the writ petition are true copies of
originals.
6. That the deponent and the respondent no.2 have settled the
disputes as per the letter dated 28.02.2024 issued by respondent
no.2 to the Director, ABVIMs and Dr. RML, Hospital, New Delhi
for dropping/not to pursue the Disciplinary proceedings against
the petitioner, in view of this the respondent no.2 is not interested
in pursuing the present FIR.
7. That in terms of the Letter dated 28.02.2024 and 09.03.2024, and
Order dated 08.03.2024 deponent and the respondent no.2 has
filed present petition, for quashing of FIR bearing no. 0061/2023
registered at police station North Avenue under section
186/332/353, IPC and Section 4 MPMSI Act dated 04.08.2023.
8. That the respondent no.2 has no objection in case the FIR bearing
no. 0061/2023 registered at Police Station North Avenue under
section 186/332/353, IPC and Section 4 MPMSI Act dated
04.08.2023 was registered against the Petitioner be quashed in
terms of the Letter dated 28.02.2024 and 09.03.2024, and Order
dated 08.03.2024
9. I say that the consent of respondent no.2 for quashing of the FIR
is of her own free will and consent, without any force, pressure,
and coercion from any quarter whatsoever.
10. That I have not filed any similar or other petition in matter.
Deponent
VERIFICATION:-
Verified at New Delhi on this day of ________, 2024, that the
contents of my above affidavit are true and correct to my knowledge,
based on the information derived from the records and nothing has
been concealed therefrom.
Deponent
IN THE HIGH COURT OF DELHI AT NEW DELHI
Crl M.No. OF 2024
In
W.P. (Crl) No. _______ OF 2024
IN THE MATTER OF: -
Meena Dahiya …Petitioner
Versus
State & Anr. …Respondents
AFFIDAVIT
I, Meena Chandra, aged about _____ years D/o ________, R/o
_______________, do hereby solemnly affirm and declare as under: -
11. That I am the Respondent No.2/complainant in the above noted
case and as such am fully conversant with the facts and
circumstances of the case and competent to depose the present
affidavit.
12. That the accompanying writ petition has been drafted under my
instructions which has been read and understood by me and I say
that the averments made therein on the basis of record and to the
best of my knowledge and believed to be correct.
13. That the contents of List of Dates are drafted by my counsel which
are true to best of my knowledge and the records maintained by
me.
14. That the contents of the para _____ and para _____ of the writ
petition are drafted by my counsel and based on legal advice
received, which I believe to be true.
15. That I say that Annexures of the writ petition are true copies of
originals.
16. That the deponent and the petitioner have settled the disputes as
per the letter dated 28.02.2024 issued by deponent to the Director,
ABVIMs and Dr. RML, Hospital, New Delhi for dropping/not to
pursue the Disciplinary proceedings against the petitioner, in view
of this the deponent is not interested in pursuing the present FIR.
17. That in terms of the Letter dated 28.02.2024 and 09.03.2024, and
Order dated 08.03.2024 petitioner and the deponent has filed
present petition, for quashing of FIR bearing no. 0061/2023
registered at police station North Avenue under section
186/332/353, IPC and Section 4 MPMSI Act dated 04.08.2023.
18. That the deponent has no objection in case the FIR bearing no.
0061/2023 registered at Police Station North Avenue under
section 186/332/353, IPC and Section 4 MPMSI Act dated
04.08.2023 was registered against the Petitioner be quashed in
terms of the Letter dated 28.02.2024 and 09.03.2024, and Order
dated 08.03.2024
19. I say that the consent for quashing of the FIR is of my own free
will and consent, without any force, pressure, and coercion from
any quarter whatsoever.
20. That I have not filed any similar or other petition in matter.
Deponent
VERIFICATION:-
Verified at New Delhi on this day of ________, 2024, that the
contents of my above affidavit are true and correct to my knowledge,
based on the information derived from the records and nothing has
been concealed therefrom.
Deponent
IN THE HIGH COURT OF DELHI AT NEW DELHI
Crl M.No. OF 2024
In
W.P. (Crl) No. _______ OF 2024
IN THE MATTER OF: -
Meena Dahiya …Petitioner
Versus
State & Anr. …Respondents
AFFIDAVIT
I, Meena Dahiya aged about ____ years, w/o Satish Kumar, R/o Qtr
588, INA Metro Station Gate No.3, Laxmi Bai Nagar, Sarojini Nagar,
South West Delhi, presently at Delhi do hereby solemnly affirm and
declare as under:-
1. That I am Petitioner in the above noted case and as such fully
conversant with the facts of the case and competent to depose
the present affidavit.
2. That the accompanying application has been drafted by my
counsel under my instruction and the contents of the same are
true and correct to my knowledge and read over to me in
vernacular and may be treated as part and parcel of this
affidavit and are not being repeated herein for the sake of
brevity.
Deponent
VERIFICATION:-
Verified at New Delhi on this day of , 2024, that the
contents of my above affidavit are true and correct to my knowledge,
based on the information derived from the records and nothing has
been concealed therefrom.
Deponent