Though:Mr - Divyakantlahoti (Advocate)

IN THE HIGH COURT OF ALLAHABAD AT UTTARPRADESH
W.P(CRL)293/2014
IN THE MATTER OF:
DR.RAJESHTALWAR ....PETITIONER
&ANOTHER
Though:Mr.DivyakantLahoti
(Advocate)
VERSUS
CENTRAL BUREAU OF
IVESTIGATION ....RESPONDENT
WITH
I.A. NO. _______/2014 APPLICATION FOR BRINGING

ADDITIONAL DOCUMENTS ON RECORD
PAPER BOOK
(FOR INDEX PLEASE SEE INSIDE)

INDEX
SL.NO. Particulars of the Document Page No. of part Remarks
to which it
belongs
1 O/R ON Limitation
2 Listing Proforma
3 Cover Page of paper Book
4 Index of Record
5 Limitation Report prepared

by the registry
6 Synopsis and list of dates
7 Prayer
W.P(CRL)293/2014
IN THE MATTER OF:
&ANOTHER
VERSUS
CENTRAL BUREAU OF
SYNOPSIS
That the instant petition filed under article 226 of the Constituion of india,
namely habeous corpos against the State for unlawful detention of the talwars
couple in the matter withour having “insufficient evidence” against the couple.
That the petitioner named above filling this writ petition under section 226 of
Indian constitution for illegal detention of petitioner against the order passéd by
CBI judge against the petitioner for murder of their daughter (arushi) and
domestic help (Hemraj) , that the court can not complete the chain of event
which is essential in the case based on circumstance evidence and no conclusive
evidence was presented in front of the court .
LIST OF DATES AND EVENTS
DATE EVENTS OF THE CASE

May 16, 2008 Aarushi Talwar, the daughter of dentist
couple Rajesh and Nupur Talwar, found
dead with her throat slit in the bedroom of
her Noida home. Nepalese domestic help
Hemraj suspected of murder.
May 17,2008 Body of Hemraj found on the terrace of the
Talwar house
May 18,2008 Police say murders were conducted with
surgical precision, insider job suspected.
May 23,2008 Aarushi's father Rajesh Talwar arrested for
double murder.
May 31,2008 Central Bureau of Investigation (CBI)
takes over case.
June 13,2008 Krishna, Rajesh Talwar's compounder,
arrested by the CBI. Ten days later, Raj
Kumar, the servant of a doctor friend of the
Talwars, and Vijay Mandal, the domestic
help of Talwars neighbour, were also
nabbed.
July 12,2008 Rajesh given bail by a Ghaziabad court
after CBI fails to present evidence against
him.
Feb 9 ,2009 A special Ghaziabad court rejects CBI's
closure report and orders that Rajesh and
Nupur Talwar be tried for Aarushi's
murder. The couple also face allegations of
destruction of evidence. A : CBI special
court in Ghaziabad issues bailable warrants
against the couple for not being present in
court
December CBI team files a closure reporting citing
29,2009 “insufficient evidence.” Servants get clean
chit and Talwars remain prime suspects.
January Rajesh Talwar suffers grievious injuries
25,2011 following an attack by Utsav Sharma on
the Special CBIcourt premises in
Ghaziabad
Feb 9,2011 Court rejects CBI’s closure report and
summons Aarushi’s parents to face charges
of murders.
Feb 21,2011 Talwars approach Allahabad High Court
for quashing trial court summons.
March 18,2011 Allahabad high court dismmises the plea.
March 19,2011 The couple approaches the Supreme Court.
January 2011 Supreme Court says the bail granted to
Rajesh Talwar by the lower court in the
‘Aarushi murder case’ would continue and
that he should appear before the Ghaziabad
Magistrate on Feburary 4 to face trial along
with his wife ,Nupur Talwar.
March 14, 2012 CBI argues in court for cancellation of
Rajesh Talwar's bail.
April 30,2012 Nupur Talwar arrested.
May 3,2012 Sessions court rejects Nupur Talwar's bail
plea May 25: Rajesh and Nupur Talwar
charged by Ghaziabad court with murder,
destruction of evidence and conspiracy..
September 25 Nupur Talwar released on bail on the
Supreme Court's order
April 2013 CBI officer tells court that Aarushi and
Hemraj were killed by the Talwars. CBI
also tells court that Aarushi and Hemraj
were found in an objectionable,
compromising position.
May 3,2013 Defence counsel pleads before a special
court to summon 14 people, including
former CBI joint director Arun Kumar as
witness. CBI opposes the plea.
May 6,2013 Trial court dismisses Talwar's petition for
summoning 14 witnesses. It orders
recording of statements of Rajesh and
Nupur Talwar
October 18 CBI closes arguments, says Talwars
"misled" investigators.
November 12 Court reserves verdict in the case for
November 25
November 25 Court delivers verdict in double-murder

case.
November 26 Rajesh and Nupur Talwar were

sentenced to life term by a CBI court.
October 12, Allahabad HC acquitted talwar couples

2017:
W.P(CRL)293/2014
IN THE MATTER OF:
&ANOTHER
VERSUS
CENTRAL BUREAU OF
In the matter of article 226 and 227 of the constitution of India
THE HON’BLE CHIEF JUSTICE AND OTHER HON’BLE JUDGES OF THE HIGH
COURT OF JUDICATURE AT ALLAHBAD
THE PETITIONER ABOVE NAMED MOST HUMBLY SHEWETH AS
UNDER:
1.By the present Writ Petition, the Petitioner is constrained to invoke the extra ordinary Writ
Jurisdiction of this Hon’ble Court under article 226 and 227 of the Constitution of India to
issue the writ of Habeus corpus.
The material facts giving rise to the present petition are as below:
2.That On the morning of May 16, 2008, 14-year-old Aarushi Talwar daughter of petitioner
was found dead in the bedroom of her house in Jalvayu Vihar, Noida. Her throat was slit and
her head hammered

3.That family’s live-in domestic help Hemraj Banjade was seen as the prime suspect in the
murder, but, a day later, Hemraj (45) was found dead on the terrace of the same flat. His
throat was also slit and he had suffered injuries to his head. There were wounds all over his
body and the door to the terrace was found locked from inside.
4. That after the found body of Hemraj Banjade, Noida Police suspected the twin murders to
be an insider job and said that they had been committed with ‘surgical precision.
5.That petitioner former domestic help Vishnu Sharma was initially named as a suspect in the
case. Soon, Delhi Police also joined the probe.
6. Six days after Aarushi’s body was found, police suspected it to be a case of honour killing
and the petitioner , Rajesh Talwar and Nupur Talwar, both dentists, came under the scanner.
Noida Police alleged that petitioner had committed the twin murders after finding Aarushi
and Hemraj in an “objectionable” position. However, no forensic or material evidence was
provided to substantiate the claim.
7. On May 23, 2008 Rajesh Talwar was arrested for the double murder. As the case became a
topic of household debate with divided public opinion on who killed Aarushi, the case was
handed over to the CBI.
8. On June 13, CBI arrested Krishna Thadaraj, an assistant at petitioner Noida clinic and on
June 20, CBI conducted a lie detector test on petitioner (Rajesh Talvar). Five days later, a
second lie detector test was also conducted on petitioner ( Nupur Talwar), as the first one was
found to be inconclusive. After spending almost two months in jail, petitioner (Rajesh
Talwar) got bail on July 12.
9..As the investigation continued, narco-analysis tests were conducted on the petitioner. On
December 2010, CBI submitted a closure report on the grounds of “insufficient evidence”.
Giving a clean chit to the servants, CBI named petitioner (Rajesh Talwar) as the prime
suspect. However, due to lack of evidence, CBI did not charge petitioner (Rajesh Talvar).
10.On November 25, 2013, CBI judge Shyam Lal convicted the petitioner guilty of both
murders and destruction of evidence.
11. That the CBI judge awarded life impressment to the petitioner in this double murder case
without any conclusive evidence.
12. That the petitioner named above filling this writ petition under section 226 of Indian
constitution for illegal detention of petitioner against the order passéd by CBI judge against
the petitioner for murder of their daughter (arushi) and domestic help (Hemraj) , that the court
can not complete the chain of event which is essential in the case based on circumstance
evidence and no conclusive evidence was presented in front of the court .
AND FOR THIS ACT OF KINDNESS AND JUSTICE THE PETITIONER AS IN
DUTY BOUND SHALL EVER PRAY
Place:
This 30th day of 2014
Mr. Divyakant Lahoti
Advocate for the Petitioner
Dr.Rajesh Talwar
Petitioner
PRAYER
It is most respectfully prayed that this Hon’ble Court may be
pleased to:
a) Condone the delay of 4 days in filing the present special leave

petition before this Hon’ble Court;
b) Pass any such further order or orders as this Hon’ble Court may
deem fit in light of the facts and the circumstances of the case.
AND FOR THIS ACT OF KINDNESS THE PETITIONER SHALL IN

DUTY BOUND EVERY PRAY.
DRAWN BY FILED BY
DIVYAKANT LAHOTI
(ADVOCATE) ADVOCATES FOR THE PETITONER
DRAWN ON:- 2014
FILED ON:- 2014

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IN THE HIGH COURT OF ALLAHABAD AT UTTARPRADESH

IN THE MATTER OF:

I.A. NO. _______/2014 APPLICATION FOR BRINGING

(FOR INDEX PLEASE SEE INSIDE)

3 Cover Page of paper Book

5 Limitation Report prepared

6 Synopsis and list of dates

IN THE MATTER OF:

LIST OF DATES AND EVENTS

DATE EVENTS OF THE CASE

November 25 Court delivers verdict in double-murder

November 26 Rajesh and Nupur Talwar were

October 12, Allahabad HC acquitted talwar couples

IN THE MATTER OF:

In the matter of article 226 and 227 of the constitution of India

COURT OF JUDICATURE AT ALLAHBAD

THE PETITIONER ABOVE NAMED MOST HUMBLY SHEWETH AS

issue the writ of Habeus corpus.

her head hammered

case. Soon, Delhi Police also joined the probe.

and Hemraj in an “objectionable” position. However, no forensic or material evidence was

provided to substantiate the claim.

handed over to the CBI.

Talwar) got bail on July 12.

murders and destruction of evidence.

without any conclusive evidence.

evidence and no conclusive evidence was presented in front of the court .

AND FOR THIS ACT OF KINDNESS AND JUSTICE THE PETITIONER AS IN

DUTY BOUND SHALL EVER PRAY

This 30th day of 2014

Mr. Divyakant Lahoti

Advocate for the Petitioner

a) Condone the delay of 4 days in filing the present special leave

AND FOR THIS ACT OF KINDNESS THE PETITIONER SHALL IN

(ADVOCATE) ADVOCATES FOR THE PETITONER

DRAWN ON:- 2014

FILED ON:- 2014

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