IN THE COURT OF CHIEF METROPOLITAN MAGISTRATE,

DWARKA COURT, NEW DELHI

APPLICATION NO. ______OF 2020
IN
FIR NO. 0004/2020
IN THE MATTER OF:

STATE

VERSUS

MR. ______
S/o______
R/o_______ …APPLICANT

APPLICATION ON BEHALF OF ABOVE NAMED APPLICANT

FOR RELEASING OF VEHICLE[insert model name] BEARING
NO. “UP-16GT-2750” ON SUPERDARI TO APPLICANT, THE
SAME BEING SEIZED BY HEAD CONSTABLE RADHESHYAM
STATIONED AT PS-DOMESTIC AIRPORT, NEW DELHI UNDER
SECTION 4(a) of PREVENTION OF TOUTING AND
MALPRACTICES AGAINST TOURISTS ACT, 2010 SEIZED

MOST RESPECTFULLY SHOWETH:

1. That the Applicant is a law abiding citizen and is a cab driver

by profession operating in the National Capital Territory of

Delhi.

2. That an FIR dated 08.01.2020 has been registered against the

brother of Applicant namely Mr. Shiv Dev Singh at PS-

Domestic Airport, New Delhi under Section 4(a) of Delhi

Prevention of Touting and Malpractices against Tourists Act,

2010 (hereinafter referred as “Act”). It is stated that the

brother of Applicant is also a cab driver and often uses the

vehicle of Applicant for the purpose of earning his livelihood.

 The Copy of FIR dated 08.01.2020 is annexed herewith as

ANNEXURE A1.

3. That in the garb of aforementioned false and frivolous FIR

being registered against the brother of Applicant, the Head

Constable namely Mr. Radhe Shyam bearing particulars as

No. 44/A, PIS No. 28012212 had seized the vehicle of

Applicant on 08.01.2020 while being stationed at PS-Domestic

Airport, New Delhi and the vehicle of Applicant is still lying

under the custody of SHO, PS-Domestic Airport, New Delhi.

4. That the Applicant is the sole owner of vehicle bearing No. UP-

16GT-2750, as can be ascertained from a bare perusal of

Registration Certificate, Insurance Documents, Commercial

Permit, Pollution related Documents etc., all of them being

issued in the name of Applicant. Copy of Registration

Certificate, Insurance, Commercial Permit, Pollution Control

Certificate pertaining to vehicle no. UP-16GT-2750 are

annexed herewith as ANNEXURE A2 (Colly).

5. That the Applicant comes from a financially backward family

and earns his everyday livelihood by driving the

aforementioned vehicle and therefore, the same is required by

him on an urgent basis so that he can resume his work and

earn daily wages for himself and his family members who all

are dependent on him.

6. That the Applicant herein undertakes to produce the

aforementioned vehicle before this Hon’ble Court as and when

mandated by this Hon’ble Court.

 PRAYER

Therefore, in the light of aforementioned facts and

circumstances, it is most respectfully prayed that this Hon’ble

Court may be pleased to release _______ bearing No. UP-16GT-

2750 to the Applicant on Superdari.

AND/OR

May pass any other order (s) as this Hon’ble Court may think

fit and proper in the interest of justice.

APPLICANT

THROUGH
DATE:
LAVKESH BHAMBHANI
& BHARAT GROTRA
PLACE: NEW DELHI COUNSELS FOR APPLICANT
D-143-A, EAST OF KAILASH,
NEW DELHI-110065
CONTACT(+91) 9717552410
 IN THE COURT OF CHIEF METROPOLITAN MAGISTRATE,
DWARKA COURT, NEW DELHI
APPLICATION NO. ______OF 2020
IN
FIR NO. 0004/2020

IN THE MATTER OF:

STATE

VERSUS

MR. ______ …APPLICANT

AFFIDAVIT
I, ______, S/o ________, aged about _______ years R/o
_____________________ do hereby solemnly affirm declare as
under:-
1. That I am the Applicant in the above noted Application and
conversant with the facts and circumstances of the Applicant
and as such competent to depose on that behalf.
2. That I have read over the contents of the accompanying
Application for release of vehicle bearing No. UP-16GT-2750 on
Superdari to Applicant being prepared by the counsel and I state
that the statement of facts contained therein, are true and
correct to the best of my knowledge.

DEPONENT
VERIFICATION
Verified at New Delhi on this ____day of January, 2020 that the
contents of the above affidavit are true and correct to the best of
my knowledge and nothing material has been concealed
therefrom.

DEPONENT