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IN THE HON’BLE HIGH COURT OF DELHI AT

NEW DELHI.
Crl. Misc. (MAIN) NO. OF 2022

IN THE MATTER OF:


PITAMBER & ANR. …………..PETITIONERS

VERSUS

STATE & ANR. .........RESPONDENTS

I N D E X

S.NO. PARTICULARS C.FEES PAGES


1. Consolidated Court fees 1
2. Notice of Motion 2
3. Urgent Application 3
4. Memo of parties 4-5
5. Synopsis of List of dates and 6 - 10
events
6. Petition under Section 482 11 - 28
of the Code of Criminal
Procedure, 1973 along with
affidavit in support
7. Application under Section 29 - 35
482 of the Code of Criminal
Procedure, 1973 for stay of
the trial along with affidavit
8. Application seeking 36 - 41
exemption from filing
certified/ legible copies
along with affidavit
9. Annexure-P1- True copy 42 - 60
as well as Fair true typed
and true English translated
typed copy of F.I.R.
10. Annexure-P2- True copy 61 - 96
as well as Fair true
translated typed copy of
Charge-Sheet.
11. Annexure P3- Copy of 97 - 104
Settlement Deed dated 01-
05-2017 alongwith true
typed copy.
12. Annexure P4- Certified 105
Copy of Decree of
Dissolution of Marriage
13. Annexure P5- Copy of 106
demand drafts for Rs.
25,000/-
14. Annexure P6- Copy of 107-108
Aadhar Card of petitioners
15. Annexure P7- Copy of 109
Aadhar of Respondent No. 2
16. Vakalatnama 110–111

PETITIONERS
New Delhi
Through
Dated
Krishna Kumar Sharma
Advocate
Enrl. No. D/828-A/2001
657, Lawyer’s Chamber
Dwarka Court Complex,
Sector-10, Dwarka,
New Delhi – 110075
Mobile : 9899234777, 9311234777
Krishna.attorney1503@gmail.com

IN THE HON’BLE HIGH COURT OF DELHI AT


NEW DELHI.
Crl. Misc. (MAIN) NO. OF 2022
IN THE MATTER OF:
PITAMBER & ANR. …………..PETITIONERS

VERSUS

STATE & ANR. .........RESPONDENTS

NOTICE OF MOTION

Take notice that the accompanying petition will be listed


before Court on ___.01.2022 at 10:30 A.M. or so soon
thereafter as may be convenient to the Hon’ble Court.

PETITIONERS
New Delhi
Through
Dated
Krishna Kumar Sharma
Advocate
Enrl. No. D/828-A/2001
657, Lawyer’s Chamber
Dwarka Court Complex,
Sector-10, Dwarka,
New Delhi – 110075
Mobile : 9899234777, 9311234777
Krishna.attorney1503@gmail.com

To,

THE STANDING COUNSEL (CRIMINAL)


NEW DELHI.
IN THE HON’BLE HIGH COURT OF DELHI AT
NEW DELHI.
Crl. Misc. (MAIN) NO. OF 2022

IN THE MATTER OF:


PITAMBER & ANR. …………..PETITIONERS

VERSUS

STATE & ANR. .........RESPONDENTS

URGENT APPLICATION
THE DEPUTY REGISTRAR,
HIGH COURT OF DELHI,
NEW DELHI.

Sir,

Kindly treat the accompanying petition as urgent according


to the Delhi High Court Rules as “the marriage of the
petitioner no.1 and the respondent no.2 has already been
dissolved on 20.07.2019 and the quashing along with the
relief for stay of Trial Proceedings of the F.I.R. NO.
275/2016, P.S. Mayapuri under section 498-A/406/34 IPC,
are prayed for.”
PETITIONERS
New Delhi
Through
Dated
Krishna Kumar Sharma
Advocate
Enrl. No. D/828-A/2001
657, Lawyer’s Chamber
Dwarka Court Complex,
Sector-10, Dwarka,
New Delhi – 110075
Mobile : 9899234777, 9311234777
Krishna.attorney1503@gmail.com
IN THE HON’BLE HIGH COURT OF DELHI AT
NEW DELHI.
Crl. Misc. (MAIN) NO. OF 2022

IN THE MATTER OF:


PITAMBER & ANR. …………..PETITIONERS

VERSUS

STATE & ANR. .........RESPONDENTS

MEMO OF PARTIES

1. Mr. Pitamber Singh


S/o Late Shri Murari Lal
R/o H. No. M-549,
Shakurpur,
Delhi-110034

2. Mrs. Rajani @ Rajeshwari


W/o Sh. Prem Pal
R/o H. No. M-549,
Shakurpur,
Delhi-110034 ………………..PETITIONER

VERSUS

1. The State (N.C.T. Of Delhi)


‘Through its Chief Secretary
2. Ms. Monika
D/o Late Sh. Ram Lal
R/o H. No. WZ-671, Padam Basti,
Nangal Raya,
New Delhi – 110046 ...........RESPONDENTS

PETITIONERS
New Delhi
Through
Dated
Krishna Kumar Sharma
Advocate
Enrl. No. D/828-A/2001
657, Lawyer’s Chamber
Dwarka Court Complex,
Sector-10, Dwarka,
New Delhi – 110075
Mobile : 9899234777, 9311234777
Krishna.attorney1503@gmail.com
IN THE HON’BLE HIGH COURT OF DELHI AT
NEW DELHI.
Crl. Misc. (MAIN) NO. OF 2022

IN THE MATTER OF:


PITAMBER & ANR. …………..PETITIONERS

VERSUS

STATE & ANR. .........RESPONDENTS

SYNOPSIS OF LIST OF DATES AND EVENTS

18.11.2010 That the Petitioner No.1 and the Respondent


no. 2 were married according to Hindu Rites
and Ceremony at Hanuman temple situated
at Janakpuri, D- Block, New Delhi on 18 th
November, 2010. The marriage between the
parties was duly consummated and one
female child namely Baby Yashika was born
on 02-07-2012 out of this wedlock.

20.12.2011 That on account of temperamental


differences, the parties to the present
petition started having disputes and
consequent thereto they have been living
separately since 20th December, 2011.

30.09.2016 That the Respondent no. 2 had initiated


Criminal Proceedings under section
498A/406/34 IPC, F.I.R. NO. 275/2016, P.S.
Mayapuri pending before the Court of Ms.
Neetu Nagar, MM, Tis Hazari Court and now
listed for 24-02-2022 which are the subject
matter of the present petition. That the F.I.R.
was registered against the Petitioner i.e.
Husband and sister in law (Jethani) and the
charge sheet has been filed against the
petitioners i.e. husband and sister in law by
the investigating officer. That the true copy
as well as Fair true typed and English
translated typed copy of F.I.R. and charge
sheet is annexed herewith as ANNEXURE-P1
and ANNEXURE-P2.

That the matter is fixed for miscellaneous


purpose/charge.
That both the parties have voluntarily
decided to settle their disputes and
differences.

01.05.2017 That the matter has been settled between the


parties in the MEDIATION CENTRE, TIS
HAZARI COURT, the agreed terms and
conditions by and between the parties of the
settlement have been recorded before the
mediator on 01.05.2017, as per terms &
conditions of the settlement, the petitioner
will pay a total sum of Rs.1,00,000/- (Rupees
One Lakh Only) as full and final amount
against the stridhan, dowry and maintenance
towards past, present and future to the
Respondent No.2 and her minor daughter.
Both the parties further agreed that the
Petitioner no. 1 will pay Rs. 25,000/- (Rupees
Twenty-Five Thousand Only) to the
Respondent no. 2 at the time of granting
anticipatory bail by the court. Both the
parties further agreed that the Petitioner will
pay Rs. 25,000/- (Rupees Twenty-Five
Thousand Only) to the Respondent No. 2 at
the time of first motion, they further agreed
that petitioner will pay Rs. 25,000/- (Rupees
Twenty-Five Thousand Only) to the
respondent no. 2 at the time of second
motion and Rs. 25,000/- (Rupees Twenty-
Five Thousand Only) at the time of quashing
of F.I.R. before this Hon’ble court (IN THE
HON’BLE HIGH COURT) to the Respondent
no.2 through demand draft in the name of
Respondent No. 2. The Copy of Settlement is
annexed herewith as ANNEXURE-P3.

That as per agreed terms and conditions, all


the instalment of Rs. 25,000/- (Rupees
Twenty-Five Thousand Only) each, has
already been paid by the petitioner No. 1 at
the time of Bail, at the time of statement of
the parties recorded in the first motion of
divorce by mutual consent on 05.12.2018
and at the time of statement of the parties
recorded in the second motion of divorce by
mutual consent on 20.07.2019 to the
Respondent No.2.

14.12.2018 That the said settlement arrived at between


the parties has been duly acted upon and in
pursuance thereto the parties had preferred a
petition under section 13B (1) H.M.A. (First
Motion of Divorce) was filed and the same
was allowed vide order dated 14-12-2018.

20.07.2019 That after the seven months as per Law


again a petition under section 13B (2) H.M.A.
(Second Motion of Divorce) was filed and the
Decree has been passed vide order dated
20.07.2019. True copy of the Decree is
annexed as ANNEXURE-P4.

HENCE THE PRESENT PETITION BEFORE THIS HON’BLE


COURT.
IN THE HON’BLE HIGH COURT OF DELHI AT
NEW DELHI.
Crl. Misc. (MAIN) NO. OF 2022

IN THE MATTER OF:


PITAMBER & ANR. …………..PETITIONERS

VERSUS

STATE & ANR. .........RESPONDENTS

PETITION UNDER SECTION 482 OF THE


CRIMINAL PROCEDURE CODE, 1973 PRAYING
INTER-ALIA FOR QUASHING OF FIR NO.
275/2016, U/S 498A/406/34 IPC, P.S. MAYA
PURI PENDING BEFORE THE COURT OF MS.
NEETU NAGAR, MM, TIS HAZARI COURTS AND
ALL CONSEQUENT PROCEEDINGS IN
PURSUANCE OF THE SAME.

TO,

HON’BLE THE CHIEF JUSTICE OF THE HIGH COURT OF


DELHI AND HIS COMPANION JUSTICE OF THIS HON’BLE
COURT.

THE HUMBLE PETITION OF THE PETITIONER ABOVE NAMED,


MOST RESPECTFULLY SHEWETH:

1. That the petitioner herein is filing the present petition


under section 482 of the Code of Criminal Procedure,
1973, praying inter-alia, for quashing of the FIR NO.
275/2016, U/S 498A/406/34 IPC, P.S. Maya Puri,
pending before the Court of Ms. Neetu Nagar, MM, Tis
Hazari Courts and now listed for 24-02-2022 and all
proceedings in pursuance of the same. That copy as
well as true typed copy along with true English
translated typed copy of the said FIR and charge sheet
is annexed herewith as ANNEXURE-P1 and
ANNEXURE-P2.

2. That the brief facts leading to the filing of the present


petition are narrated here in under:-

(a) That the Petitioner No. 1 and the Respondent no. 2


were married according to Hindu Rites and
Ceremony at Hanuman temple situated at
Janakpuri, D- Block, New Delhi on 18 th November,
2010. The marriage between the parties was duly
consummated and one female child namely Baby
Yashika was born on 02-07-2012 out of this
wedlock.

(b) That on account of temperamental differences, the


parties to the present petition started having
disputes and consequent thereto they have been
living separately since 20th December, 2011.

(c) That the Respondent no. 2 had initiated Criminal


Proceedings under section 498A/406/34 IPC, F.I.R.
NO. 275/2016, P.S. Mayapuri pending before the
Court of Ms. Neetu Nagar, MM, Tis Hazari Court
and now listed for 24-02-2022 which are the
subject matter of the present petition. That the
F.I.R. was registered against the Petitioner i.e.
Husband and sister-in-law (Jethani) and the charge
sheet has been filed against the petitioners i.e.
husband and sister in law by the investigating
officer. That the true copy as well as Fair true
typed and English translated typed copy of F.I.R.
and charge sheet is annexed herewith as
ANNEXURE-P1 and ANNEXURE-P2.

That the matter is pending for miscellaneous


appearance/arguments on charge.

(d) That both the parties have voluntarily decided to


settle their disputes and differences and the matter
has been settled between the parties in the
MEDIATION CENTRE, TIS HAZARI COURT, the
agreed terms and conditions by and between the
parties of the settlement have been recorded
before the mediator on 01.05.2017, as per terms &
conditions of the settlement, the petitioner will pay
a total sum of Rs.1,00,000/- (Rupees One Lakh
Only) as full and final amount against the stridhan,
dowry and maintenance towards past, present and
future to the Respondent No.2 and her minor
daughter. Both the parties further agreed that the
Petitioner no. 1 will pay Rs. 25,000/- (Rupees
Twenty-Five Thousand Only) to the Respondent
no. 2 at the time of granting anticipatory bail by
the court. Both the parties further agreed that the
Petitioner will pay Rs. 25,000/- (Rupees Twenty-
Five Thousand Only) to the Respondent No. 2 at
the time of first motion, they further agreed that
petitioner will pay Rs. 25,000/- (Rupees Twenty-
Five Thousand Only) to the respondent no. 2 at the
time of second motion and Rs. 25,000/- (Rupees
Twenty-Five Thousand Only) at the time of
quashing of F.I.R. before this Hon’ble court (IN
THE HON’BLE HIGH COURT) to the Respondent
no.2 through demand draft in the name of
Respondent No. 2 and after the settlement both
the parties shall not interfere in the lives of each
other. That the true copy as well as Fair true
translated typed copy of Settlement / Compromise
Deed dated 01-05-2017 is annexed herewith as
ANNEXURE-P3. That the contents of the said
settlement be read as part of the present petition.

(e) That on request of the respondent no. 2, It is


further agreed by and between the parties that the
petitioner no. 1 shall not claim any right, even
visitation right for his daughter.

(f) That as per agreed terms and conditions, all the


instalment of Rs. 25,000/- (Rupees Twenty-Five
Thousand Only) each, has already been paid by
the petitioner No. 1 at the time of Bail, at the time
of statement of the parties recorded in the first
motion of divorce by mutual consent on
05.12.2018 and at the time of statement of the
parties recorded in the second motion of divorce
by mutual consent on 20.07.2019 to the
Respondent No. 2.

(g) That the said settlement arrived at between the


parties has been duly acted upon and in pursuance
thereto the parties had preferred a petition under
section 13B (1) H.M.A. (First Motion of Divorce)
was filed and the same was allowed vide order
dated 14-12-2018.

(h) That after the seven months as per Law again a


petition under section 13B (2) H.M.A. (Second
Motion of Divorce) was filed and the Decree has
been passed vide order dated 20.07.2019. True
copy of the Decree is annexed as ANNEXURE-P4.

(i) That as per the said settlement the Respondent


No.2 has agreed to assist in getting quashed the
Criminal Proceedings under section 498A/ 406/34
IPC, FIR NO. 275/2016, P.S. Maya Puri pending
before the Court of Ms. Neetu Nagar, MM, Tis
Hazari Courts and now listed for 24-02-2022.

(j) That as per settlement Petitioner is to pay a sum


of Rs. 25,000/- (Rupees Twenty-Five Thousand
Only) by way of Bank Draft bearing No. 085674
Dated 07.02.2020 drawn on State Bank of India,
New Delhi, to the Respondent no. 2 at the time of
recording of statement of the parties in the present
petition. The copy of draft for the said amount is
annexed herewith and marked as ANNEXURE-P5.

3. That the petitioner is thus filing the present petition


before this Hon’ble Court seeking quashing of the FIR
NO. 275/2016, U/S 498A/ 406/34 IPC, P.S. Maya Puri
pending before the Court of Ms. Neetu Nagar, MM, Tis
Hazari Court and now listed on 24-02-2022 and all
proceedings in pursuance of the same, on the following,
amongst other grounds:-

GROUNDS

a) Because the matter has already been mutually and


amicably settled between the parties and settlement
to this effect have also which is annexed with the
present petition and marked as ANNEXURE-P3.

b) Because the said settlement arrived at between the


parties has been duly acted upon and in pursuance
thereto the parties had preferred a petition under
section 13B (1) HMA (First Motion of Divorce) which
was granted vide order dated 14.12.2018.

c) Because again the said settlement arrived at between


the parties has been duly acted upon and in
pursuance thereto the parties had preferred a petition
under section 13B (2) HMA (Second Motion of
Divorce) and Decree has been passed dated
20.07.2019 and true certified copy of decree annexed
herewith as ANNEXURE-P4.

d) Because the Petitioner is to pay a sum of Rs. 25,000/-


(Rupees Twenty-Five Thousand only) to the
Respondent no. 2 under the settlement at the time of
recording of statement of the parties in the present
petition. That copy of draft for the said amount is
annexed herewith and marked as ANNEXURE-P5.
That accordingly the settlement arrived at between
the parties has been fully acted upon.

e) Because no useful purpose would be served by the


continuation of the proceedings which are the subject
matter of the present petition and it would not be in
the interests of justice if the Petitioner has to undergo
the rigorous of trial.

f) Because the Petitioner would be put to great prejudice


if the present proceedings are allowed to continue and
he has to face the trial.
4. That in the aforesaid circumstances, no purpose would
be served by continuing with the further proceedings
in respect of subject F.I.R./ complaint case, hence this
Petition before this Hon’ble Court.

5. That the Petitioners have not filed any other petition in


respect of the aforesaid F.I.R./ complaint case either
before this Hon’ble Court or before the Hon’ble
Supreme Court of India.

6. That the annexures to this Petition are the true copies


of the originals available with the Petitioners.

PRAYER
It is, therefore, most respectfully prayed that in the
interest of justice this Hon’ble Court may graciously be
pleased to:

(a) Quash the FIR NO. 275/2016, U/S 498A/406/34


IPC, P.S. Maya Puri pending before the Court of Ms.
Neetu Nagar, MM, Tis Hazari Courts and now listed
for 24-02-2022 and all proceedings in pursuance of
the same; and

(b) Stay the trial proceedings in quashing of the FIR


NO. 275/2016, U/S 498A/406/34 IPC, P.S. Maya
Puri pending before the Court of Ms. Neetu Nagar,
MM, Tis Hazari and now listed for 24-02-2022 and/
or
(c) Grant any other or further relief(s) which this
Hon’ble court may deem fit and proper in the facts
and circumstances of the present case and in the
interests of justice.

PETITIONERS
New Delhi
Through
Dated
Krishna Kumar Sharma
Advocate
Enrl. No. D/828-A/2001
657, Lawyer’s Chamber
Dwarka Court Complex,
Sector-10, Dwarka,
New Delhi – 110075
Mobile : 9899234777, 9311234777
Krishna.attorney1503@gmail.com
IN THE HON’BLE HIGH COURT OF DELHI AT
NEW DELHI.
Crl. Misc. (MAIN) NO. OF 2022

IN THE MATTER OF:


PITAMBER & ANR. …………..PETITIONERS

VERSUS

STATE & ANR. .........RESPONDENTS

AFFIDAVIT

I, Pitamber Singh aged about 40 S/o Late Sh. Murari


Lal R/o H. No. M-549, Shakurpur, New Delhi - 110034,
years do hereby solemnly affirm and declare as under:

1. I say that I am the Petitioner No. 1 in the present


case, and am conversant with the facts of the case
and as such I am competent to swear this affidavit.

2. That the deponent has filed accompanying petition


under section 482 Cr.P.C. for quashing of FIR, the
contents of which may kindly be read as part and
parcel to this affidavit as well which are not being
repeated here for the sake of brevity.

3. That the accompanying petition under section 482


Cr.P.C. has been drafted by my counsel under my
instructions and the contents of the same have been
read over to me in my vernacular, which are true
and correct to my knowledge. I have signed the
same after having understood the contents.

DEPONENT
VERIFICIATION:
Verified on solemn affirmation at New Delhi on this
____ day of January, 2022 that the contents of the
aforesaid affidavit are true and correct to my knowledge and
belief. No part of it is false, and nothing material has been
concealed therefrom.

DEPONENT
IN THE HON’BLE HIGH COURT OF DELHI AT
NEW DELHI.
Crl. Misc. (MAIN) NO. OF 2022

IN THE MATTER OF:


PITAMBER & ANR. …………..PETITIONERS

VERSUS

STATE & ANR. .........RESPONDENTS

AFFIDAVIT

I, Rajani @ Rajeshwari aged about 45 W/o Sh. Prem


Pal R/o H. No. M-549, Shakurpur, New Delhi - 110034,
years do hereby solemnly affirm and declare as under:

1. I say that I am the Petitioner No. 2 in the present


case, and am conversant with the facts of the case
and as such I am competent to swear this affidavit.

2. That the deponent has filed accompanying petition


under section 482 Cr.P.C. for quashing of FIR, the
contents of which may kindly be read as part and
parcel to this affidavit as well which are not being
repeated here for the sake of brevity.

3. That the accompanying petition under section 482


Cr.P.C. has been drafted by my counsel under my
instructions and the contents of the same have been
read over to me in my vernacular, which are true
and correct to my knowledge. I have signed the
same after having understood the contents.

DEPONENT
VERIFICIATION:
Verified on solemn affirmation at New Delhi on this
____ day of January, 2022 that the contents of the
aforesaid affidavit are true and correct to my knowledge and
belief. No part of it is false, and nothing material has been
concealed therefrom.

DEPONENT
IN THE HON’BLE HIGH COURT OF DELHI AT
NEW DELHI.
Crl. Misc. (MAIN) NO. OF 2022

IN THE MATTER OF:


PITAMBER & ANR. …………..PETITIONERS

VERSUS

STATE & ANR. .........RESPONDENTS

APPLICATION UNDER SECTION 482 OF THE


CRIMINAL PROCEDURE CODE, 1973 PRAYING
INTER-ALIA FOR STAY OF PROCEEDING OF
FIR NO. 275/2016, U/S 498A/406/34 IPC,
P.S. MAYA PURI PENDING BEFORE THE COURT
OF MS. NEETU NAGAR, MM, TIS HAZARI
COURTS, DELHI

MOST RESPECTFULLY SHEWETH:-

1. That the petitioner herein have filed a petition


under section 482 of the Code of Criminal
Procedure, 1973, praying inter-alia, for quashing of
the FIR NO. 275/2016, U/S 498A/406/34 IPC, P.S.
Maya Puri pending before the Court of Ms. Neetu
Nagar, MM, Tis Hazari and now listed on 24-02-
2022.
2. That the contents of the aforesaid accompanying
Petition may kindly be read as part and parcel of
this application as well as those not being repeated
herein for the sake of brevity.

3. That the matter has already been compromised


between the parties in the Mediation Centre, Tis
Hazari Courts, Delhi on 01.05.2017. That nothing
remains in the matter and the Petitioner thus
expect to succeed and to get relief as prayed for in
the petition from this Hon’ble Court.

4. That in the interregnum if the trial in respect of the


aforesaid F.I.R. continues, the petitioner would be
put to great prejudice and the very purpose of filing
the present petition would be defeated and
frustrated.

5. That no fruitful purpose would be served by


continuation of the trial since the matter stands
already settled.

PRAYER

It is, therefore, most respectfully prayed that in the


interest of justice this Hon’ble Court may graciously be
pleased to stay the trial proceedings in the FIR No.
275/2016, U/S 498A/406/34 IPC, P.S. Maya Puri pending
before the Court of Ms. Neetu Nagar, MM, Tis Hazari and
now listed for 24-02-2022 and/ or pass any other or further
order(s) which this Hon’ble Court may deem fit and proper
in the facts and circumstances of the present case.

PETITIONERS
New Delhi
Through
Dated
Krishna Kumar Sharma
Advocate
Enrl. No. D/828-A/2001
657, Lawyer’s Chamber
Dwarka Court Complex,
Sector-10, Dwarka,
New Delhi – 110075
Mobile : 9899234777, 9311234777
Krishna.attorney1503@gmail.com
IN THE HON’BLE HIGH COURT OF DELHI AT
NEW DELHI.
Crl. Misc. (MAIN) NO. OF 2022

IN THE MATTER OF:


PITAMBER & ANR. …………..PETITIONERS

VERSUS

STATE & ANR. .........RESPONDENTS

APPLICATION UNDER SECTION 482 OF THE


CRIMINAL PROCEDURE CODE, 1973 PRAYING
INTER-ALIA FOR SEEKING EXEMPTION FROM
FILING THE ORIGINAL/ CERTIFIED/LEGIBLE
COPIES OF THE ANNEXURES TO THE PRESENT
PETITION.

MOST RESPECTFULLY SHEWETH:-

1. That the Petitioners have filed the aforesaid petition


under section 482 CrPC for quashing of F.I.R. and
other proceedings.

2. That the Petitioner is filing the present petition with


the true copies of the annexures. That the original/
certified copies/ legible copies of the same would
be produced on record as soon as the same are
available with the petitioners or as and when
directed by this Hon’ble Court.
PRAYER

It is, therefore, most respectfully prayed that in the


interest of justice this Hon’ble Court may graciously be
pleased to exempt the petitioners from filing the original/
certified/ legible copies of the annexures in the interests of
justice.

PETITIONERS
New Delhi
Through
Dated
Krishna Kumar Sharma
Advocate
Enrl. No. D/828-A/2001
657, Lawyer’s Chamber
Dwarka Court Complex,
Sector-10, Dwarka,
New Delhi – 110075
Mobile : 9899234777, 9311234777
Krishna.attorney1503@gmail.com
IN THE HON’BLE HIGH COURT OF DELHI AT
NEW DELHI.
Crl. Misc. (MAIN) NO. OF 2022

IN THE MATTER OF:


PITAMBER & ANR. …………..PETITIONERS

VERSUS

STATE & ANR. .........RESPONDENTS

AFFIDAVIT

I, Rajani @ Rajeshwari W/o Sh. Prem Pal aged about


45 years R/o H. No. M-549, Shakurpur, New Delhi, do
hereby solemnly affirm and declare as under:

1. I say that I am the Petitioner in the present case, am


conversant with the facts of the case and as such I am
competent to swear this affidavit.

2. I say that I have gone through the contents of the


accompanying application under section 482 Cr.P.C.
for stay of proceedings of FIR No.275/2016 under
Section 498-A/406/34 IPC, P.S. Maya Puri, which has
been drafted my counsel at my instructions, the
contents of which may be read as part of the present
affidavit and the same are true and correct.

DEPONENT
VERIFICIATION:

Verified on solemn affirmation at New Delhi on this


____ day of January, 2022 that the contents of the
aforesaid affidavit are true and correct to my knowledge and
belief. No part of it is false, and nothing material has been
concealed therefrom.

DEPONENT
IN THE HON’BLE HIGH COURT OF DELHI AT
NEW DELHI.
Crl. Misc. (MAIN) NO. OF 2022

IN THE MATTER OF:


PITAMBER & ANR. …………..PETITIONERS

VERSUS

STATE & ANR. .........RESPONDENTS

AFFIDAVIT

I, Monika D/o Late Sh. Ram Lal, aged 35 years, R/o. H. No.

WZ-671, Padam Basti, Nangal Raya, New Delhi - 110046, do

hereby solemnly affirm and declare as under:

1. That I am the Respondent No. 2 in the accompanying

petition and well conversant with the facts of the case

and hence I am competent to swear this affidavit.

2. That I have already settled the dispute with the

petitioner vide settlement dated 01.05.2017 before

the mediation centre, Tis Hazari Courts, Delhi.

3. That I have no objection if present quashing petition

under section 482 Cr.P.C, be allowed by this Hon’ble

Court and the FIR No. 275/ 2016, dated 30.09.2016,


u/s 498-A/406/34 IPC lodged with the Police Station

Maya Puri, be quashed.

4. That I have given my consent for presenting the

accompanying petition, with my free will and without

any pressure, force, inducement or fraud and undue

influence.

DEPONENT

VERIFICIATION:

Verified at New Delhi on this day of January,

2022 that the contents of the present affidavit are true and

correct to the best of my knowledge and belief. No part of it

is false, and nothing material has been concealed therefrom.

DEPONENT
IN THE HON’BLE HIGH COURT OF DELHI AT
NEW DELHI.
Crl. Misc. (MAIN) NO. OF 2022

IN THE MATTER OF:


PITAMBER & ANR. …………..PETITIONERS

VERSUS

STATE & ANR. .........RESPONDENTS

AFFIDAVIT

I, Pitamber Singh aged about 40 S/o Late Sh. Murari


Lal R/o H. No. M-549, Shakurpur, New Delhi - 110034,
years do hereby solemnly affirm and declare as under:

1. I say that I am the Petitioner in the present case, am


conversant with the facts of the case and as such I am
competent to swear this affidavit.

2. I say that I have gone through the contents of the


accompanying application under section 482 Cr.P.C.
for stay of proceedings of FIR No.275/2016 under
Section 498-A/406/34 IPC, P.S. Maya Puri, which has
been drafted my counsel at my instructions, the
contents of which may be read as part of the present
affidavit and the same are true and correct.

DEPONENT
VERIFICIATION:

Verified on solemn affirmation at New Delhi on this


____ day of January, 2022 that the contents of the
aforesaid affidavit are true and correct to my knowledge and
belief. No part of it is false, and nothing material has been
concealed therefrom.

DEPONENT
IN THE HON’BLE HIGH COURT OF DELHI AT
NEW DELHI.
Crl. Misc. (MAIN) NO. OF 2022

IN THE MATTER OF:


PITAMBER & ANR. ………PETITIONERS

VERSUS

STATE & ANR. ......RESPONDENTS

CONSOLIDATED COURT FEE

PETITIONERS
New Delhi
Through
Dated
Krishna Kumar Sharma
Advocate
Enrl. No. D/828-A/2001
657, Lawyer’s Chamber
Dwarka Court Complex,
Sector-10, Dwarka,
New Delhi – 110075
Mobile : 9899234777, 9311234777
Krishna.attorney1503@gmail.com

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