IN THE HON’BLE HIGH COURT OF CHATTISGARH

Writ no. 21 of 2021

(Under Article 226 of the Constitution of India)

INDEX

Raju Rastogi Age – 32 son of Rohit Rastogi age 63 …………………………….. Petitioner

Address – Patel Nagar 21 Ram vihar colony

Through Advocate Shreyansh Singh Chandel

Versus

Government of Chattisgarh Through

Home secretary Ministry of Home Affairs

Chaurangi Lane Raipur

Mr. Giriraj Singh sub Inspector Patel Nagar Police Station , Raigarh……………… Respondent

S No. Particulars Page No.

1 Memo
2 Synopsis
3 List of events
4 Court fees
5 Facts
6 Grounds
7 Prayer
8 Affidavit
9 Verification

Date- 4th may 2021

Shreyansh Singh Chandel

Advocate

(Counsel of the petitioner)

 IN THE HON’BLE HIGH COURT OF CHATTISGARH

Writ no. 21 of 2021

(Under Article 226 of the Constitution of India)

SYNOPSIS AND LIST OF EVENTS

Raj Rastogi Age – 63 son of Late Raju Rastogi …………………………….. Petitioner

Address – Patel Nagar 21 Ram vihar colony

Versus

Government of Chattisgarh Through

Home secretary Ministry of Home Affairs

Mr. Giriraj Singh sub Inspector Patel Nagar Police Station , Raigarh……………… Respondent

SYNOPSIS

The petitioner is the father of the detained victim and a retired Army officer. I am filing this writ
petition because on 1st may 2021 at night 9:30 pm IST my son got arrested by Mr. Giriraj Singh
Sub inspector Patel Nagar police station on baseless ground . We waited for 3 days
consecutively no response came from the police and after we wanted to file F.I.R police
refrained itself by doing so . This couple of events have violated the right of an individual under
article 14 , 19 and 21 enshrined under constitution.
 LIST OF EVENTS

DATE EVENTS
st
1 May 2021 Arrest made by respondent
3rd May 2021 F.I.R was refrain to file by police station
4th May 2021 Writ petition filed by petitioner

3rd May 2021

Shreyansh Singh Chandel

(Counsel of the Petitioner )

 IN THE HON’BLE HIGH COURT OF CHATTISGARH

Writ no. 21 of 2021

(Under Article 226 of the Constitution of India)

Court Fees

Raju Rastogi Age – 32 son of Rohit Rastogi age 63 …………………………….. Petitioner

Address – Patel Nagar 21 Ram vihar colony

Through Advocate Shreyansh Singh Chandel

Versus

Government of Chattisgarh Through

Home secretary Ministry of Home Affairs

Chaurangi Lane Raipur

Mr. Giriraj Singh sub Inspector Patel Nagar Police Station , Raigarh……………… Respondent

The petitioner has deposited the court fees which worth rupees 500 /- . Receipt is attached in
annexure no. _____

Court Registrar

(Signautre)
 IN THE HON’BLE HIGH COURT OF CHATTISGARH

Writ no. 21 of 2021

(Under Article 226 of the Constitution of India)

Court Fees

Raju Rastogi Age – 32 son of Rohit Rastogi age 63 …………………………….. Petitioner

Address – Patel Nagar 21 Ram vihar colony

Through Advocate Shreyansh Singh Chandel

Versus

Government of Chattisgarh Through

Home secretary Ministry of Home Affairs

Chaurangi Lane Raipur

Mr. Giriraj Singh sub Inspector Patel Nagar Police Station , Raigarh……………… Respondent

The Petitioner humbly submits thereof

1. That the Petitioner has invoked this article under original jurisdiction of the Hon’ble
High Court under article 226 and 227 of the Constitution of India to command to release
the detainee which is detained by Respondent.
2. That the petitioner is father of detainee name Raju Rastogi which was arrested by the
Respondent on 1st May 2021 on frivolous ground

3. That the petitioner waited for 3 days but no response came from the side of police.

4. That the petitioner tried to register F.I.R but the police department of Patel Nagar
refrained from doing so.

5. That the petitioner filed writ petition because of wrongful detention made by respondent.
 GROUNDS

1. Because detention made by the respondent was illegal and arbitrary no reason was
also furnished by the Respondent

2. Because it is the violation of article 14 , 19 and 21 of Constitution Of India .

3. Because it is submitted that entire cause of action has arisen within the jurisdiction of
this Hon’ble Court and hence, this Hon’ble Court has the jurisdiction to entertain and
adjudicate the issue involved in the instant Writ Petition.

4. Because the Petitioner has no other equally efficacious remedy except by way of the
present Writ Petition and relief prayed under this petition, if granted, would be
complete and effectual.

5. Because the Petitioner has paid a fixed Court fee of Rs.500 on the Writ Petition.
 PRAYER

That the Petitioner, therefore, pray before this Hon’ble Court in the light of above
circumstances, that the Hon’ble Court may be pleased to grant the following reliefs in
favour of the Petitioner and against the Respondent.

1. To issue writ of Habeas corpus and direct the respondent for immediate release of
detainee.
2. To grant compensation of all mental and physical harassment faced by detainee
and petitioner.
.
That Any other relief that this Hon’ble Court may be pleased to grant in the interest
of Justice, Equity and Good Conscience.

Shreyansh Singh Chandel

Advocate
( Counsel of the petitioner )
 . IN THE HON’BLE HIGH COURT OF CHATTISGARH

Writ no. 21 of 2021

(Under Article 226 of the Constitution of India)

AFFIDAVIT

Raju Rastogi Age – 32 son of Rohit Rastogi age 63 …………………………….. Petitioner

Address – Patel Nagar 21 Ram vihar colony

Through Advocate Shreyansh Singh Chandel

Versus

Government of Chattisgarh Through

Home secretary Ministry of Home Affairs

Chaurangi Lane Raipur

Mr. Giriraj Singh sub Inspector Patel Nagar Police Station , Raigarh……………… Respondent

AFFIDAVIT

I Raju Rastogi s/o Rohit Rastogi Patel Nagar 21 Ram vihar colony Raigarh Chattisgarh solely
hearby affirm that

1. I am the father of the detainee and henceforth I am competent to file writ petition
2. All the facts above mentioned in the writ petition is true and best of my knowledge
3. All the grounds which are stated above in writ petition are addressed to me with
diligently.
DEPONDENT
VERIFICATION

I Raju Rastogi s/o Rohit Rastogi depondent here .Do HEARBY verify on this day of May
4th 2021 that all the affirmations made under affidavit by me are true and best of my
knowledge .All the facts which are stated by me are true and the grounds which are
pleaded are based on the legal advice which I believe to be true
All facts are true and no any material or substantial concealment is made