SHREE VILE PARLE KEVLANI MANDAL’S
PRAVIN GANDHI COLLEGE OF LAW
SEMESTER- X
DRAFTING, PLEADING & CONVEYANCING III
ASSIGNMENT SUBMISSION (PORTFOLIO)
SUBMITTED BY:
RIYANSHI JAIN
DIVISION & ROLL NO.- A019
5TH YEAR, B.L.S. LL.B.
INDEX
Sr. No. Particulars Page No.
1. Testamentary Petition for Succession Certificate 2
2. Legal Notice for Defective Goods 8
3. Plaint 11
4. Legal Notice under Section 138 of the Negotiable 16
Instruments Act, 1881
5. Anticipatory Bail Application 19
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ASSIGNMENT I – TESTAMENTARY PETITION FOR SUCCESSION
CERTIFICATE
The petition seeks a succession certificate for the late Vishal Vishwang’s assets, including
Reliance Industries and Poonawalla Fincorp shares worth ₹19.76 lakh. The deceased died
intestate in 2013, survived by five legal heirs (two sons and three daughters, including
petitioner Ishika Apte). The delayed filing (2025) is attributed to the late discovery of physical
share certificates during the COVID-19 lockdown. The petition complies with inheritance
laws and confirms no prior applications for probate or succession certificates exist.
IN THE HIGH COURT OF JUDICATURE AT BOMBAY
TESTAMENTARY AND INTESTATE JURISDICTION
PETITION NO. OF 2025
Petition for Succession Certificate in respect of
certain Debt and Securities belonging to
Baburao Apte, Indian Inhabitant of Mumbai, a
Widower, Occupation: Retired Businessman,
who was residing at the time of his death at 24/4
Indus Court, A Road, Opposite Jai Hind
College, Churchgate, Mumbai- 400 020.
......Deceased
Isha Vishal Vishwang, ]
Aged-67 years, Indian Inhabitant of ]
Mumbai, Occupation: Homemaker, ]
residing at 24 - 4, Indus Court, ]
A-Road, Opposite Jai Hind College, ]
Churchgate, Mumbai – 400020. ]
being the Daughter of the deceased ]
abovenamed. ] …… Petitioner
TO,
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THE HON’BLE THE CHIEF JUSTICE
AND OTHER PUISNE JUDGES OF HON’BLE
HIGH COURT OF JUDICATURE AT BOMBAY
THE HUMBLE PETITION OF THE
PETITIONER ABOVE NAMED MOST
RESPECTFULLY SHOWETH: -
1. That the abovenamed Vishal Vishwang, died at Mumbai on 8th day of December, 2013.
Hereto annexed and marked as Exhibit “A” is the copy of Death Certificate of the
Deceased issued by Department of Health, Municipal Corporation of Greater Mumbai
and Exhibit “A-1” is the copy of passport of the Deceased.
2. That the said Deceased ordinarily resided at 24/4 Indus Court, A-Road, Opposite Jai
Hind College, Churchgate, Mumbai- 400020 and left properties within the Greater
Bombay and in the State of Maharashtra.
3. That the said Deceased died intestate, and that due and diligent search has been made
for a “Will” but none has been found.
4. That the said Deceased left behind him surviving as his only heirs and next-of-kin
according to the Hindu Succession Act, 1956, the following persons, who are residing
at the addresses set out against their respective names:
Sr. Name and address of the Age Relationship with the
Deceased
No. legal heirs of the Deceased
1. Meenal Seth, 74 Daughter of the
Deceased.
204, Ankita Building, Jankidevi
School Road, Four Bungalow,
Mhada, Andheri West, Mumbai-
400053.
2. Aasha Shetty 72 Daughter of the
Deceased.
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53/2 Nanik Niwas, Bhulabhai Desai
Road, Breach Candy, Cumballa Hill,
Mumbai-400026.
3. Saksham Vishal Vishwang, 71 Son of the Deceased.
41/4, Sadhana Building, B Road,
Opp. Sydenham College,
Mumbai-400020.
4. Reyansh Vishal Vishwang, 70 Son of the Deceased.
27/5, Indus Court, A Road,
Opp. Jai Hind College,
Churchgate, Mumbai-400020.
5. Isha Baburao Apte, 67 Daughter of
24/4 Indus Court, A Road, the Deceased and the
Petitioner herein.
Opposite Jai Hind College,
Churchgate, Mumbai-400020.
5. That the mother of the deceased viz. Chandkrika Vishwang, pre-deceased the Deceased.
That the Wife of the Deceased viz. Sareena Vishal Vishwang, also pre- deceased the
Deceased and died on 25/03/2011. Hereto annexed and marked as Exhibit “B” is the
copy of Death Certificate of Wife of the Deceased. That the Deceased is survived by
his two sons and Three Daughters, who are only class-I legal heirs of the Deceased as
per the provision of Section 8 of Hindu Succession Act, 1956. That the said deceased
had no other Son and no other Daughter. Save and except the heirs mentioned herein
above, there are no other Legal heirs or next-of-kin left by the Deceased.
6. That the Petitioner as Daughter of the Deceased claims to be entitled to 1/5th Share of
the estate.
7. That there is no impediment under Section 370 of the Indian Succession Act 1925,
or under any other provisions of this Act or any other enactment to the Grant of
the Certificate or the validity thereof if it were granted.
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8. That the Petitioner has truly set forth in Schedule-I hereto annexed and marked as
Exhibit “C” the Debt and Securities in respect of which the certificate is applied for.
The Succession Certificate is required for the purpose of collecting the said debt and to
receive interest thereon and for transferring, negotiating, or otherwise dealing with the
said Securities and to receive dividend due thereon. The said assets in respect of which
succession certificate is required are of the value of Rs.19,76,519.69 (Rupees Nineteen
Lakhs Seventy Six Thousand Five Hundred Nineteen and Sixty-Nine Paisa Only).
9. That no application has been made to any District Court or District Delegate or to any
High Court for Probate of any Will of the said Deceased or for Letters of
Administration with or without the “Will” annexed to his property and credits.
10. That no other application has been made to any District Court or District Delegate or
to any High Court for Succession Certificate in respect of any debts or security
belonging to the estate of the Deceased.
11. The Petitioner states that there is a delay in filing the present Petition on account of the
fact that the securities held by the Deceased were in physical form, the whereabouts of
which were not known to the Petitioner. In and around the year 2020, the Petitioner
discovered the said physical share certificates while clearing and arranging the old
documents during the lockdown period, wherein the original bonus certificate for 300
shares of Reliance Industries Limited was found. After retrieving 300 bonus share
certificates, the Petitioner realized that the original 300 shares certificates were
misplaced/lost. On the basis of total 600 shares of Reliance Industries Limited, around
600 shares of Jio Financial Services Limited were received in the year 2023, pursuant
to the Scheme of Arrangement as approved by the National Company Law Tribunal,
Mumbai Bench. The amount of dividend accrued from the holding of 600 shares of
Reliance Industries Limited has also been credited in the bank account held jointly by
the Petitioner and Deceased. The Petitioner, till the year 2021, was unaware of the
holdings of the Deceased in the shares of Poonawalla Fincorp Limited. It was only
when the Petitioner received a letter by post, requiring the holder of the shares to
surrender the original physical shares and exercise KYC requirement as per the latest
SEBI guidelines the Petitioner got aware of the shares of Poonawalla Fincorp Limited.
Till date, the Petitioner was not aware of the requirement for obtaining the succession
certificate. It was only recently when the Petitioner sought to transfer the securities held
by the Deceased abovenamed, the Petitioner was asked to produce succession
certificate. Accordingly, the Petitioner, being a senior citizen sought legal advice and
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proceeded to file the present Petition. Therefore, the Petitioner most respectfully
submits and prays to the Hon’ble Court that the delay in fling the present Petition be
condoned in the interest of justice.
The Petitioner therefore prays that:
A Succession Certificate may be granted to her in respect of the debt and Securities set forth in
schedule-I hereto, with the power to collect the said debt and to receive interest or dividend
thereon and to negotiate or transfer the said Securities.
Dated this 7th April 2025
Isha Vishal Vishwang ( Petitioner )
M/s. RJ Associates, Advocates and Solicitors
Advocates for Petitioner
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VERIFICATION
I, Isha Vishwang, aged-67 years, residing at 24-4, Indus Court, A-Road, Opposite Jai
Hind College, Churchgate, Mumbai – 400020, the Petitioner abovenamed, do hereby on
solemn affirmation state that what is stated in paragraphs No. 1 to 11 of this Petition is true
to my own knowledge and I believe the same to be true.
Solemnly declared at Mumbai )
On this 7th Day of April 2025 )
Isha Vishal Vishwang ( Petitioner )
Identified by us,
M/s. RJ Associates, Advocates and Solicitors
Advocates for the Petitioner
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ASSIGNMENT II – LEGAL NOTICE FOR DEFECTIVE GOODS
This legal notice demands immediate action from Apple Store BKC regarding the supply of 7
defective MacBook Pro units (Model M4) delivered on March 28, 2025, under Invoice No.
AA/2025/1924. Despite documented evidence of physical damage and malfunctions shared
with customer care, the store has failed to replace the products or refund ₹7.15 lakhs, violating
the Sale of Goods Act, 1930 and Consumer Protection Act, 2019. The notice gives 15 days to
replace the defective units or refund the amount, along with ₹50,000 compensation for damages
and ₹10,000 legal costs, failing which legal action will be initiated.
BY REGISTERED POST A.D.
Date: 06.04.2025
To,
The Manager,
Apple Store BKC.
Ground Floor, Jio
Drive, Mumbai.
Subject: Legal Notice for Supply of Defective Goods – Macbook – Non-
compliance with terms of contract and Indian Contract Act, 1872 and Consumer
Protection Act, 2019.
Sir/Madam,
Under instructions from and on behalf of my client, Mr. Rajiv Malhotra, residing at Flat No.
4003, Oberoi Residency, Andheri (W), Mumbai – 400069 (hereinafter referred to as "My
Client"), I hereby serve upon you the following legal notice:
1. That pursuant to a telephonic enquiry and subsequent email correspondence dated 10th
February 2025, My Client placed an order for 10 units of Macbook Pro (Model: M4
Edition 256 GB) with your company, Elite Electronics Pvt. Ltd., for commercial resale
purposes.
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2. That your company issued Tax Invoice No. AA/2025/1924 dated 27th March 2025 for a
total sum of Rs. 12,50,000/- (Rupees Twelve Lakhs Fifty Thousand only) inclusive of all
taxes and delivery charges.
3. That the said goods were delivered to My Client on 28th March 2025 at his registered
premises in Mumbai through your designated logistics partner.
4. That upon inspection, My Client observed that 7 out of the 10 Macbook Pro were either
physically damaged (screen cracks, power failure) or malfunctioning (distorted display,
unresponsive input panel). Photos and videos of the same were promptly shared with your
customer care team on 29th March 2025.
5. That despite repeated follow-ups via email and calls between 28th March 2025 to 4th April
2025, your company has failed to replace the defective goods or refund the corresponding
amount, thereby breaching both contractual obligations and statutory warranties implied
under Section 16 of the Sale of Goods Act, 1930.
6. That your failure to act amounts to deficiency in service and supply of defective goods
under the provisions of the Consumer Protection Act, 2019. The continued delay has
caused not only financial loss to My Client but also mental agony and reputational damage
in his business.
7. That My Client states that he has been left with no option but to initiate legal proceedings
against you for the following reliefs:
a) Replacement of the 7 defective Macbook Pro;
b) Refund of the proportionate amount of Rs. 7,15,000/- if not replaced within the
stipulated time;
c) Compensation of Rs. 50,000/- for losses and mental harassment;
d) Costs of this legal notice and proposed litigation to the tune of Rs. 10,000/-.
8. Accordingly, I hereby call upon you, through this legal notice, to:
a) Replace the defective goods or refund the said amount within 15 days of the
receipt of this notice;
b) Tender a written apology and assurance against recurrence of such negligence.
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9. Please take notice that failure to comply with the above within the stipulated time will
compel My Client to initiate appropriate civil and consumer proceedings before the
competent court/forum at your sole risk, cost, and consequence, including a claim for
damages, compensation, and litigation costs.
10. This notice is sent without prejudice to all other rights and remedies available to My Client
in law and equity.
A copy of this notice is retained in my records for future reference and legal proceedings.
Yours faithfully,
M/s. RJ Associates, Advocates and Solicitors
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ASSIGNMENT III – PLAINT
This suit filed by Mr. Pratik Sawantseeks specific performance of an agreement dated 17th May
2021 to purchase "Amara Villas" in Andheri East from Ms. Tulsi Dutta for ₹60 crores, alleging
that despite paying ₹20 crores as advance and being financially ready to pay the remaining ₹40
crores, the defendant unlawfully refused to complete the sale, prompting the plaintiff to demand
performance through legal notice and now seeking court intervention to compel the sale,
restrain further alienation of the property, and recover costs, while offering to deposit the
balance consideration with the court as proof of readiness to fulfill the contractual obligations.
IN THE HIGH COURT OF JUDICATURE AT BOMBAY
ORDINARY ORIGINAL CIVIL JURISDICTION
SUIT NO. OF 2025
Mr. Pratik Swant )
Age- 43, Indian inhabitant, )
residing at 9, Bliss Apartments, )
Nariman Point, Mumbai-400 027 ) ... Plaintiff
Versus
Ms. Tulsi Dutta, )
Dutta Villas, )
Hanging Garden, Malabar Hill, )
Mumbai-400016 ) … Defendant
SUIT FOR SPECIFIC PERFORMANCE OF
AGREEEMENT TO SELL IN RESPECT OF A RESIDENTIAL
BUNGALOW
THE PLAINTIFF RESPECTFULLY STATES AS FOLLOWS:
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1. The Plaintiff is an Indian citizen and is engaged in the business of trading and servicing
refrigeration systems and spare parts. The Plaintiff has over 15 years of experience in the
said line of business and enjoys a reputable standing in the commercial circles of Mumbai.
2. The Defendant is the owner of and is otherwise fully entitled to the immovable property
being Amara Villas, Andheri East, Mumbai (hereinafter referred to as the “Suit
Property”), which is a high-value residential property situated in one of the most premium
and exclusive locations in Mumbai.
3. On or about 17th May 2021, the Plaintiff and Defendant entered into an agreement in
writing for the sale of the Suit Property for total consideration of Rs. 60,00,00,000/-
(Rupees Sixty Crores Only). A true copy of the said agreement is annexed hereto and
marked as “Exhibit A”.
4. The agreement was executed after several rounds of negotiation between the parties, and
the Defendant specifically represented that he had clear, marketable, and unencumbered
title to the Suit Property and that there were no impediments, including any litigation,
charge, or tenancy, affecting the sale thereof.
5. At the time of execution of the agreement, the Plaintiff paid an advance/part consideration
of Rs. 20,00,00,000/- (Rupees Twenty Crores Only) by way of Cheque No. 123455 dated
17th May 2021 drawn on Axis Bank, Nariman Point Branch, which was duly encashed by
the Defendant. This payment was made against a specific receipt issued by the Defendant
acknowledging the receipt of the advance and reaffirming his obligation to complete the
sale by executing the conveyance deed.
6. As per the terms of the agreement, the balance consideration of Rs. 40,00,00,000/-
(Rupees Eighty Crores Only) was to be paid in tranches within three months from the date
of agreement, upon completion of basic formalities such as handing over clear title
documents and clearance of property dues.
7. The Plaintiff, being financially sound, duly arranged for the remaining consideration
through internal accruals and sanctioned credit lines and on multiple occasions between
May 2021 and July 2021, approached the Defendant for execution of the sale deed and
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acceptance of the remaining payment. Despite repeated oral and written requests, the
Defendant avoided the performance of his obligations under the agreement on frivolous
grounds.
8. On 1st August 2021, the Plaintiff issued a legal notice calling upon the Defendant to
perform his part of the contract and accept the balance consideration. The Plaintiff
specifically asserted his readiness and willingness to perform the agreement and warned
the Defendant that failure to comply would compel legal action. A true copy of the said
notice is annexed and marked “Exhibit B”.
9. The Defendant replied on the same day, i.e., 1st August 2021, wherein he categorically
refused to proceed with the sale and unjustifiably alleged that he had retracted from the
agreement. A copy of the said reply is annexed and marked “Exhibit C”.
10. The Plaintiff states that the Defendant’s refusal to execute the conveyance was without
cause and is indicative of the Defendant’s mala fide intentions to resile from a legally
binding contract. The Plaintiff verily believes that the Defendant may have subsequently
received better offers or was induced to breach the contract due to the soaring real estate
prices in the area.
11. The Plaintiff submits that he has always been ready and willing to perform his part of the
agreement and has never defaulted in any manner whatsoever. The Plaintiff is prepared
to deposit the remaining consideration of Rs. 40 Crores before this Hon’ble Court as a
mark of bona fide intent and financial capability.
12. The Plaintiff further submits that Suit Property is a unique immovable asset with
irreplaceable value owing to its location, layout, and heritage character. No amount of
monetary compensation can substitute for the same, and therefore, specific performance
is the only just and equitable remedy available to the Plaintiff.
13. The Plaintiff has not created any third-party rights or encumbered his rights under the
contract and remains the sole beneficiary under the agreement with the Defendant.
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14. The cause of action for the present suit first arose on 1 st August 2021s when the Defendant
issued the refusal letter and has continued to subsist ever since. The present suit is filed
within the period of limitation prescribed under Article 54 of the Limitation Act, 1963.
15. The Suit Property is situated within the territorial jurisdiction of this Hon’ble Court, and
the agreement was also executed in Mumbai. The cause of action has arisen wholly within
Mumbai.
16. The present suit is valued at Rs. 60,00,00,000/- (Rupees Sixty Crores Only) for the
purposes of jurisdiction and court fees, which is within the pecuniary jurisdiction of this
Hon’ble Court.
17. In view of the aforesaid facts and circumstances, the Plaintiff most respectfully prays that
this Hon’ble Court may be pleased to:
a. Pass a decree of specific performance of the Agreement dated 17th May 2021 and
direct the Defendant to accept the balance consideration of Rs. 80,00,00,000/-
(Rupees Forty Crores Only) and execute the Sale Deed in respect of the Suit
Property being Amara Villas, Andheri East, Mumbai in favour of the Plaintiff;
b. Permit the Plaintiff to deposit the balance consideration of Rs. 40,00,00,000/-
(Rupees Forty Crores Only) with this Hon’ble Court or in an escrow account as
directed;
c. Grant a permanent order of injunction restraining the Defendant, his agents,
servants, representatives or any person acting on his behalf from selling,
transferring, alienating, parting with possession, or creating any third-party
interest in respect of the Suit Property during the pendency of the suit;
d. Appoint a Court Commissioner, if necessary, to verify the status and possession
of the Suit Property and submit a report to this Hon’ble Court;
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e. Award costs of this suit and incidental proceedings in favour of the Plaintiff and
against the Defendant;
f. Pass such other and further orders as this Hon’ble Court may deem just, proper
and expedient in the interest of justice.
Mumbai
Dated this ____day of ____, 2025
Plaintiff Advocate for the Plaintiff
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ASSIGNMENT IV – LEGAL NOTICE UNDER SECTION 138 OF THE NEGOTIABLE
INSTRUMENTS ACT, 1881
Legal Notice under Section 138 of the Negotiable Instruments Act, 1881 for dishonour of Cheque
No. 100308 drawn in favour of Encore Homes Furniture – Demand for payment of Rs. 3,40,000/-
along with applicable charges, damages, and legal expenses.
BY REGISTERED POST A.D.
Date: 06.01.2025
To,
Mr. Dhaval Motwane,
Flat No. 34, Lotus Apartments,
Borivali East,
Mumbai 400068. .
Subject: Legal Notice under Section 138 of the Negotiable Instruments Act, 1881 for dishonour of
Cheque No. 100308 drawn in favour of Encore Homes Furniture – Demand for payment of Rs.
3,40,000/- along with applicable charges, damages, and legal expenses.
Sir,
Under instructions from and on behalf of my client Encore Homes Furniture, having its principal
office at Shop No. 41 to 43, Tejpal Residencies, Kandivali (hereinafter referred to as "My Client"), I
hereby address you this legal notice as follows:
1. That My Client is engaged in the business of furniture and fixtures.
2. That you, the Noticee, are a salaried individual residing at the above-mentioned address,
and had approached My Client to purchase furniture for your house worth Rs. 3,40,000/-
for which a Cheque dated 12th March 2025 bearing Cheque No. 100308 drawn on HDFC
Bank was issued in favour of my Client.
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3. That upon presentation of the said cheque for encashment, the same was returned
dishonoured by the Bank with the remarks “Insufficient Funds” as per return memo
dated 27th March 2025.
4. That the issuance of a cheque without sufficient funds in your account reflects a dishonest
intention and constitutes a breach of trust and a punishable offence under the law.
5. That the dishonoured cheque was issued by you in discharge of your legally enforceable
debt owed to My Client.
6. That despite reminders, you have failed to make good the payment of the dishonoured
cheque amount.
7. That as on date, a sum of Rs. 3,40,000/- is due and payable by you to My Client, along
with Rs. 10,000/- as cheque return charges, Rs. 50,000/- towards damages and
inconvenience, interest @ 4% per month on the outstanding amount, and Rs. 1,00,000/-
as legal charges for issuance of this notice.
8. You are hereby called upon to make the full payment of the above-mentioned amounts
within fifteen (15) days from receipt of this notice.
9. Please take notice that in the event of your failure to comply with the requisitions
contained herein within the stipulated period, My Client shall be constrained to initiate
criminal proceedings against you under Section 138 read with Section 142 of the
Negotiable Instruments Act, 1881, which may result in imprisonment for up to two years
and/or fine extending to twice the amount of the dishonoured cheque, at your sole risk,
cost, and consequence.
10. This notice is issued without prejudice to any other rights or remedies available to My
Client in law or equity.
11. A copy of this notice is retained in my office for future reference and legal proceedings.
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Yours faithfully,
M/s. RJ Associates, Advocates and Solicitors
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ASSIGNMENT V – LEGAL NOTICE UNDER SECTION 138 OF THE NEGOTIABLE
INSTRUMENTS ACT, 1881
Amrish Dasani, seeks anticipatory bail under Section 482 of Bharatiya Nagarik Suraksha Sanhita,
2023, fearing arrest in a false trespass/intimidation case filed by his cousin Rakesh Dasani at
D.N. Nagar Police Station, which he claims is a retaliatory action for his own complaint about
property dispute issues, and undertakes to fully cooperate with investigations while requesting
protection from arrest to safeguard his professional reputation and personal liberty.
IN THE COURT OF SESSIONS FOR GREATER BOMBAY
CRIMINAL APPELLATE JURISDICTION
ANTICIPATORY BAIL APPLICATION NO. 354 OF 2025
Amrish Dasani S/o Harish Dasani
Indian Inhabitant,
Residing at C-604, Maple Heights,
Near Shastri Nagar, Andheri (West)
Mumbai – 400058. … Petitioner
Versus
State of Maharashtra
(Through the Officer-in-Charge,
D.N. Nagar Police Station) … Respondent
ANTICIPATORY BAIL APPLICATION UNDER SECTION 482 OF THE BHARATIYA
NAGARIK SURAKSHA SANHITA, 2023
TO,
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The Hon’ble Principal Judge and Companion Judges of the Hon’ble Sessions Court at Greater
Bombay.
THE HUMBLE PETITION OF THE PETITIONER ABOVE NAMED:
MOST RESPECTFULLY SHEWETH:
1. The Petitioner is a law-abiding citizen of India, aged about 40 years, and resides
permanently at the address mentioned in the title above. He is a qualified Architect and
runs an independent design firm based in Andheri (West), Mumbai.
2. The Petitioner’s father, Mr. Harish Dasani, jointly owns residential and commercial
properties with his cousin, Mr. Rakesh Dasani. Over the last few years, several civil
proceedings have arisen between them over the division and control of jointly held
properties, including litigation in the Bombay High Court and City Civil Court.
3. The Petitioner submits that due to the ongoing family disputes, Mr. Rakesh Dasani has
developed animosity and has consistently resorted to filing baseless complaints against the
Petitioner’s father and other family members, including the Petitioner himself. These complaints
have previously resulted in no criminal action due to lack of substance.
4. Recently, on or around 12th March 2025, the Petitioner came to know that Mr. Rakesh
Dasani has lodged yet another complaint with the D.N. Nagar Police Station, falsely
implicating the Petitioner and his family members in allegations of trespass and
intimidation, purportedly in relation to a dispute concerning renovation works in a jointly
held office premises.
5. The Petitioner strongly believes that the said complaint is retaliatory in nature, arising out
of a prior N.C. Complaint (No. 222 of 2025) filed by the Petitioner on 27th February 2025,
against Mr. Rakesh Dasani for forcibly entering and disrupting ongoing renovation work
at the premises.
6. The Petitioner is a respected professional with no prior criminal record and is willing to
cooperate fully with the police in any investigation. However, he has reason to believe that
the said complaint by Mr. Rakesh Dasani is being used to unjustly harass and detain him.
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7. The Petitioner submits that there is no requirement for custodial interrogation in the matter
and that his arrest would cause irreparable damage to his personal and professional
reputation.
8. The Petitioner undertakes to make himself available for investigation and comply with any
directions that may be issued by this Hon’ble Court. He resides in Mumbai permanently
and has deep family and business roots in the city, and there is no apprehension of him
absconding or tampering with evidence.
9. In view of the above, the Petitioner most respectfully prays that this Hon’ble Court may
be pleased to:
a. Grant anticipatory bail to the Petitioner in the event of his arrest by the D.N. Nagar
Police Station in connection with the complaint filed by Mr. Rakesh Dasani;
b. Pass such further or other orders as may be deemed just and proper in the facts and
circumstances of the case.
Mumbai
Dated this 7th April, 2025
Drawn by:
Advocate for the Petitioner
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VERIFICATION
I, Amrish Dasani S/o Harish Dasani, the petitioner above-mentioned, do solemnly affirm that
what is stated in this petition save and except legal submissions is true to my personal
knowledge.
Solemnly affirmed at Mumbai on this 7th April 2025
Petitioner
Before me
Advocate for the petitioner.
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