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B. S. Cheema versus Sunil Kanwar & others

Proceedings U/s 340 Cr.P.C.

Application for granting permission to summon

witnesses in inquiry u/s. 340 Cr.P.C. with permission
to deposit fee for summoning them.

Respectfully Showeth -

That the present matter is pending before this Hon'ble Court. To avoid
the miscarriage of justice and to reach the right decision, the petitioner wants
to examine the below mentioned witnesses. Permission may kindly be granted
to summon the following witnesses -

I. Director, Army Welfare Education Society (AWES Cell), Chandimandir through

Principal, Army Public School, Chandimandir along with entire case file of
termination matter "Ravinderjeet Kaur Cheema, Librarian (1994-2012) Army
Public School, Chnadimandir" and all documents received from dated 01.12.2011
to 10.12.2011 on email account of AWES (also known as AWES Cell),

II. Dispatch Clerk, Paschim Kaman Mukhalaya, HQ, Western Command,

Chandimandr with dispatch record of dated 8.12.2011, 09.12.2011, 03.01.2012,
03.08.2012 about the letters sent by Lt. Col Kuldeep Singh(I/C APS) and by
G.P.Singh (Chairman, APS) to Mrs Punita Kanwar.

III. Col. Kuldeep Singh, …………………………………………………………………

IV. Mrs. Punita Kanwar w/o Sh. Sunil Kanwar, House No. 227, Sector-25, Panchkula

V. Director (Schools), AWES, New Delhi through Principal, APS, Chandimandir

VI. Ms. Preeti Ahluwalia, Counselor, Army Public School, Chandimandir

VII. Staff Officer Chairman-cum- Incharge, Army Public School, Chandimandir with
entire enquiry file of the termination matter about "RAVINDERJEET KAUR
CHEEMA, Librarian (1994-2012), APS, Chandimandir" pertaining to period 01-08-
2011 to 31-08-2012.

2. That no prejudice will be caused to respondent party, if the above

mentioned witnesses will be allowed to appear for inquiry in this matter.

3. That there is no delay in this matter, as the original matter "Sunil

Kanwar v Ravinderjeet Kaur, is pending for 24.07.2018" from which this matter
u/s. 340 Cr.P.C arise.

It is therefore prayed to this Hon'ble Court that the present application

may kindly be allowed, in the interest of justice. dated ……….at Panchkula

Submitted by