IN THE HON’BLE HIGH COURT OF DELHI AT NEW DELHI

WRIT PETITION (CRL.) NO. _____/2023

IN THE MATTER OF:

VIKAS DHULL AND OTHERS …. PETITIONERS
VERSUS
STATE OF NCT DELHI & ANR. …. RESPONDENT
FIR NO 29/2021,
P.S. SWAROOP NAGAR
U/S 409,420,467,468,471,120B

INDEX
 S.NO. PARTICULARS PAGES

1. NOTICE OF MOTION

2. COURT FEES

3. URGENT APPLICATION

4. LIST DATES AND EVENTS

5. MEMO OF PARTIES

6. SYNOPSIS AND LIST OF DATES &

EVENTS.

7. WRIT PETITION (CRL) UNDER

ARTICLE 226 OF THE
= CONSTITUTION OF INDIA READ
WITH 482 CR. PC ON BEHALF OF
THE PETITIONERS INTER ALIA
PRAYING FOR QUASHING OF FIR
NO. 29/2021 P.S. SWAROOP NAGAR.
DATED 21/01/2021 UNDER
SECTION U/S
409,420,467,468,471,120B INDIAN
PENAL CODE, 1860 ALONG WITH
CONSEQUETING PROCEDDINGS
ON THE BASIS OF SETTLEMENT
DATED 01.11.2022 WITH
SUPPORTING AFFIDAVITS.

8. ANNEXURE P – 1
TRUE COPY OF THE FIR NO.
29/2021 DATED 21.01.2021, P.S
SWAROOP NAGAR, DELHI U/s
409,420,467,468,471,120B.

9. ANNEXURE P-2.
TRUE COPY OF CERTIFICATE OF
INCORPORATION (V INSPIRE
FACILITY MANAGEMENT
PRIVATE LIMITED).
10. ANNEXURE P– 3(COLLY)
COPY OF THE MOU APRIL, 2022
EXECUTED BETWEEN THE
PARTIES.
11. ANNEXURE P-4(COLLY)
COPY OF THE BAIL ORDER DATED
 APPLICANT
THROUGH
NEW DELHI
DATE: -

HITESH KUMAR, YATIKA CHOUDHARY

& SURAJ RAWAT
(ADVOCATES)
CH N0 – 317, LAWYERS BLOCK
SAKET COURT COMPLEX,
NEW DELHI – 110017
8130668896, 9968058236.

IN THE HON’BLE HIGH COURT OF DELHI AT NEW DELHI

WRIT PETITION (CRL.) NO. _____/2023

IN THE MATTER OF:

VIKAS DHULL AND OTHERS …. PETITIONERS
VERSUS
STATE OF NCT DELHI &ANR. …. RESPONDENT
FIR NO 29/2021,
P.S. SWAROOP NAGAR
U/S 409,420,467,468,471,120B

URGENT APPLICATION

Sir,

Kindly treat the accompanying petition as an urgent one as per rules and orders
of this Hon’ble Court.

‘‘Prayer for urgent orders/ directions has been made therein.’’

NEW DELHI
THROUGH
DATED:
 HITESH KUMAR, YATIKA CHOUDHARY
& SURAJ RAWAT
(ADVOCATES)
CH N0 – 317, LAWYERS BLOCK
SAKET COURT COMPLEX,
NEW DELHI – 110017

IN THE HON’BLE HIGH COURT OF DELHI AT NEW DELHI

WRIT PETITION (CRL.) NO. _____/2023

IN THE MATTER OF:

VIKAS DHULL AND OTHERS …. PETITIONERS
VERSUS
STATE OF NCT DELHI & ANR. …. RESPONDENT
FIR NO 29/2021,
P.S. SWAROOP NAGAR
U/S 409,420,467,468,471,120B

NOTICE OF MOTION
To
The Standing Counsel (Crl.),
Delhi Police,
436, Lawyers Chambers
Delhi High Court, New Delhi
Email: [email protected]
Mob: 9891919168.

Dear Sir,

Please be informed that the accompanying petition is going to be listed for

hearing before Court on___ day of July, 2023.
NEW DELHI
THROUGH
DATED
HITESH KUMAR, YATIKA CHOUDHARY
& SURAJ RAWAT (ADVOCATES)
CH N0 – 317, LAWYERS BLOCK
SAKET COURT COMPLEX,
NEW DELHI – 110017
Email id: [email protected]

IN THE HON’BLE HIGH COURT OF DELHI AT NEW DELHI

WRIT PETITION (CRL.) NO. _____/2023

IN THE MATTER OF:

VIKAS DHULL AND OTHERS …. PETITIONERS
VERSUS
STATE OF NCT DELHI & ANR. …. RESPONDENT

COURT FEES
 APPLICANT
THROUGH
NEW DELHI
DATE: -
HITESH KUMAR, YATIKA CHOUDHARY
& SURAJ RAWAT
(ADVOCATES)
CH N0 – 317, LAWYERS BLOCK
SAKET COURT COMPLEX,
NEW DELHI – 110017
8130668896, 9968058236.

LIST AND DATES OF EVENTS

By way of this Petition, Petitioners are filing the present Petition for quashing of

FIR No. 29/2021, P.S. Swaroop Nagar, Delhi under U/s

409,420,467,468,471,120B.

It is submitted that a peaceful mutual settlement has been arrived at between the

parties and all the issues amongst the Parties i.e. relating to Monetary

transactions that the disputes has been resolved amicably and terms thereof have

complied with as per settlement agreement.

The Hon’ble Supreme Court in Gain Singh case 2012 (10) SCC 303 has held as

under:

“But the criminal cases having overwhelmingly and predominatingly civil

flavour stand on different footing for the purposes of quashing, particularly the
offences arising from commercial, financial, mercantile, civil, partnership or

such like transactions or the offences arising out of matrimony relating to

dowry etc. or the family disputes where the wrong is basically private or

personnel in nature and the parties have resolved their entire dispute In this

category of cases, High Court may quash criminal proceedings if in its view,

because of the compromise between the offender and victim, the possibility of

conviction is remote and bleak and continuation of criminal case would put

accused to great oppression and prejudice and extreme injustice would be

caused to him by not quashing the criminal case despite full and complete

settlement and compromise with the victim. In other words, the High Court

must consider whether it would be unfair or contrary to the interest of justice to

continue with the criminal proceeding or continuation of the criminal

proceeding would tantamount to abuse of process of law despite settlement and

compromise between the victim and wrongdoer and whether to secure the ends

of justice, it is appropriate that criminal case is put to an end and if the answer

to the above question(s) is in affirmative, the High Court shall be well within its

jurisdiction to quash the criminal proceeding.”.

It is further reiterated the same principle in Narinder Singh case 2014(6) SCC

466, the Hon’ble Apex Court has held as under: “Quashing of Criminal

Proceedings on the basis of settlement - Timing of settlement - Importance -

Where the settlement is arrived at immediately after the commission of offence

and the matter is still under investigation, the High Court may accept the

settlement.

In the present case, the charge sheet has not been filed as such the matter is in at

initial stage and quashing of FIR would suffice to meet the end of justice.

21.01.2021 The FIR No. 29/2021 dated 21.01.2021 was filed at PS:
Swaroop Nagar Under Sections
409,420,467,468,471,120B of The Indian Penal Code,
1860 By the Respondent, Mr. Jai Prakash.

29.07.202 The Petitioners got arrested by the Police Officials of

1 P.S Swaroop Nagar.

09.10.2021 The Petitioners were admitted to Interim Bail in view of

the amicable settlement arrived at Between the parties
and further Again bail was extended till 11.02.2022 As
Petitioners have Already complied with all Terms And
conditions of the Settlement.

21.02.2022 The Petitioners namely Arun dhull and Vikas Dhull

admitted to regular bail granted by Sh. Gagandeep
Singh ASJ/Spl. Judge (NDPS), North, Rohini Courts
Complex, Delhi.

22.05.2023 The Petitioner no 1, 2 and 3 the Respondent have

entered Into the Settlement agreement in purview of the
Same all the Payments were made According to the
Payment schedule which was mentioned and elaborated
 in the settlement agreement.
APPLICANT
NEW DELHI
DATE: -
THROUGH

HITESH KUMAR, YATIKA CHOUDHARY

& SURAJ RAWAT
(ADVOCATES)
CH N0 – 317, LAWYERS BLOCK
SAKET COURT COMPLEX,
NEW DELHI – 110017
8130668896, 9968058236.

IN THE HON’BLE HIGH COURT OF DELHI AT NEW DELHI

WRIT PETITION (CRL.) NO. _____/2023

IN THE MATTER OF:

VIKAS DHULL AND OTHERS …. PETITIONERS
VERSUS
STATE OF NCT DELHI & ANR. …. RESPONDENT
FIR NO: 29/2021,
P.S. Swaroop Nagar, Delhi
U/s 409,420,467,468,471,120B

MEMO OF PARTIES

1. VIKAS DHULL
R/O A-35, 36 SUN CITY
SECTOR 35 ROHTAK,
HARYANA
…..PETITIONER NO.1
2. ARUN DHULL
R/O A-35, 36 SUN CITY
SECTOR 35 ROHTAK,
HARYANA …..PETITIONER NO.2

3.DEEPIKA DHULL
R/O A-35, 36 SUN CITY
 SECTOR 35 ROHTAK,
HARYANA ….PETITIONER NO.3

4.RAKESH KUMAR HANS

R/O GH-4/313/MEERA
APARTMENTS, PASCHIM VIHAR
DELHI, 110063
.....PETITIONER NO.4

5. NIMESH VASHISHT
R/O WZ-121, FIRST FLOOR,
PLOT NO.13, GOPAL NAGAR
NEW DELHI -110058 ….PETITIONER NO.5

6. SANJAY SHARMA
R/O AT 2125, NEAR
TELEPHONE EXCHANGE,
HOUSE BOARD COLONY,
SECTOR-1 ROHTAK
HARYANA-124001 ….PETITIONER NO.6

7.SUNIL KUMAR
R/O AT 2125, NEAR
TELEPHONE EXCHANGE,
HOUSE BOARD COLONY,
SECTOR-1 ROHTAK
HARYANA-12 …..PETITIONER NO.7

8. SANJAY JOSHI
R/O S-309, SECOND FLOOR
CORPORATE PLAZA,
PALAM VIHAR’
GURGAON, HARYANA …PETITIONER NO.8

VERSUS

`1.STATE
NCT OF DELHI
EMAIL: - [email protected]
Mob.No-9891919168
….RESPONDENT NO.1

2. ABP TRAVELS AND FACILITY

MANAGEMENT PRIVATE LIMITED
 CORPORATE OFFICEAT 290,
NANGLIPUNA, SIRASPUR,
DELHI
….RESPONDENT NO.2

NEW DELHI
DATED: THROUGH

HITESH KUMAR, YATIKA CHOUDHARY

& SURAJ RAWAT
(ADVOCATES)
CH N0 – 317, LAWYERS BLOCK
SAKET COURT COMPLEX,

IN THE HON’BLE HIGH COURT OF DELHI AT NEW DELHI

WRIT PETITION (CRL.) NO. _____/2023

IN THE MATTER OF:

VIKAS DHULL AND OTHERS …. PETITIONERS
VERSUS
STATE OF NCT DELHI & ANR. …. RESPONDENT

PETITION UNDER ARTICLE 226 OF THE CONSTITUTION OF INDIA

READ WITH SECTION 482 0F THE CODE OF CRIMINAL
PROCEDURE, 1973 ON BEHALF OF THE PETITIONERS INTER ALIA
PRAYING FOR QUASHING OF FIR NO.0029/2021, DATED 21.01.2021
FILED AT P.S. SWAROOP NAGAR UNDER SECTION
409,420,467,468,471,120B IPC OF THE INDIAN PENAL CODE, 1860
ALONG WITH THE OTHER PROCEEDINGS EMANATING FROM
THE SAID FIR NO. 29/2021.

TO,
THE HON’BLE CHIEF JUSTICE
AND HIS HON’BLE COMPANION JUSTICES
JUSTICE OF THE HIGH COURT OF DELHI

THE HUMBLE PETITION OF THE PETITIONERS ABOVE NAME.

MOST RESPECTFULLY SHOWETH:

1. That the Petitioners are approaching this Hon’ble Court under Section 482

of Code of Criminal Procedure Code, 1973 (Cr.P.C) for quashing the FIR

bearing No. 29/2021 dated 21.01.2021(hereinafter referred to as (“THE

FIR”), registered at PS Swaroop Nagar, New Delhi U/s

409,420,467,468,471,120B of the Indian Penal Code, 1860 (‘IPC’) on the

ground that the matter has been settled between the parties amicably and

terms thereof has been complied with by parties as well and nothing useful

purpose would be served as there is any remote chance of conviction of the

Petitioners. The disputes were is purely commercial and relating to

Monetary transactions between the parties’ activities and the parties has

resolved it. True copy of the FIR no. 29/2021 dated 21.01.2021, P.S.

Swaroop Nagar- Delhi, under section 409,420,467,468,471,120B) is

annexed hereto as Annexure P-1.

2. That brief facts in the present case are as under:

a. M/s V Inspirer Facility Management Private Limited was

incorporated under the provision Companies Act,1956 as a Private

 Limited Company vide CIN U74140HR2008PTC038519 having

its registered office at S- 309, Second Floor, Corporate Plaza,

Palam Vihar, Gurugram (herein after referred to as “the

Company”). True copy of certificate of incorporation is annexed

hereto as Annexure P-2.

b. That Petitioners are the one of directors of the company and in the

Company and is thus operational control in the Company.

c. That Petitioners Company M/s V Inspirer Facility Management

Private Limited and the Respondent company M/s ABP Travels &

Facility Management Pvt Ltd. was in business relationship with

each other

d. That Respondent no.2 had preferred a criminal complaint against

the Petitioners for Misappropriation of money, forging documents

for embezzlement of company money and siphoning of Company’s

money for their personal gain resulting of which a FIR no. 29/2021

dated 21.01.2021 has been registered by P.S Swaroop Nagar Delhi

under section 420/409/467/468/471/120B IPC.

e. That the investigating agency has registered the FIR no. 29/2021

against the Petitioners and the True copy of FIR no.0029/2021,

P.S. Swaroop Nagar, Delhi dated 21.01.2021.

f. That since the disputes amongst the parties was commercial as

such the parties with big heart and open mind started discussion to

resolve all the disputes in the business and proposals were

exchanged for settlement with the help of close friends and were

agreed without prejudice to their respective rights contentions to

forged the disputes between them

g. That on 29.07.2021, Petitioners were arrested by the Investigating

Officer, Delhi and the petitioners were sent to the Judicial custody.

h. That there is no case against the state, this was a dispute between

two companies, petitioner’s company and respondent’s company

and after endeavoring to understand the real motives of the

Respondent and trying to reach a common ground, the Petitioners

no 1, 2 and 3 and the respondents entered in the settlement

agreement in the month of April, 2022.

i. That during the Judicial Custody, the parties reached the settlement

agreement dated April, 2022 after mutual discussions and the

settlement was duly executed in the presence of Counsels of the

respective parties. The signed settlement between the parties is

annexed hereto as Annexure P-3 (Colly).

j. That during investigation the only allegations that survive were

regarding the mis-utilization of the company money, which has

been made good by the petitioners in terms of the settlement

agreement.

k. The Petitioners were granted Regular Bail in lieu of the settlement

agreement executed between the Parties and the Bail order of the

date 21.02.2022 is annexed hereto as Annexure P-4 (Colly).

l. That a full and final settlement has been drawn between the parties

via order dated 09.10.2021 and on 22.05.2023 complete disputes in

all respect relating to the Monetary transactions and other issues

have been resolved between the party’s settlement agreement dated

22.05.2023 annexed hereto as Annexure P-5(Colly). Original copy

of full and final settlement agreement has reduced in writing as

follows:

i. When ICICI BANK account was opened and handed over

it was 0 balance and while handing over back it to the s

econd Party the same bank account had Rs. 198,00,000

balance the second party accepted the said amount of Rs.

198,00,000 against the present settlement.

 ii. A Bank Guarantee of Rs.2, 35,00,000was also handed

over to Second Party from First Party against the present

settlement.

iii. The first party acknowledged the handover of business

related to Chhattisgarh 112 and Ericsson to the 2 nd Party

and undertake not to raise any dispute or claim in respect

to the operation of these 2 projects.

m. That all the disputed between the Petitioners and the Respondent

stood settled and both the parties agree that no dispute or claim

remains pending between the parties. The Petitioner and

Respondent has done the settlement agreement out of their free will

and without any pressure or coercion of any nature whatsoever and

after consultation with their advisors and friends.

3. THAT THE RELIEFS UNDER THE PRESENT PETITION ARE

BEING SOUGHT ON THE FOLLOWING GROUNDS:

a. Because the all the disputes between have been settled between the
parties as per the settlement agreement April, 2022 and a full and
final settlement dated 22.05.2023 has been arrived at and it was
duly executed by the parties to this Petition except the State as such
there is no remote of chance of conviction in the present FIR as
such the same is liable to be quashed.
b. Because this Hon’ble Court have the inherent powers to quash FIR
and all the subsequent proceedings, if this Hon’ble Court finds that
continuance of such proceedings would be an abuse of the process
of the court and prosecution could secure conviction of accused
person and further to meet ends of justice require the criminal
proceedings to be quashed.

c. Because as per the settled law by the Hon’ble Supreme Court in the
Gian Singh (Supra) has held as under:
“But the criminal cases having overwhelmingly and
predominatingly civil flavour stand on different footing for the
purposes of quashing, particularly the offences arising from
commercial, financial, mercantile, civil, partnership or such like
transactions or the offences arising out of matrimony relating to
dowry etc. or the family disputes where the wrong is basically
private or personnel in nature and the parties have resolved their
entire dispute In this category of cases, High Court may quash
criminal proceedings if in its view, because of the compromise
between the offender and victim, the possibility of conviction is
remote and bleak and continuation of criminal case would put
accused to great oppression and prejudice and extreme injustice
would be caused to him by not quashing the criminal case despite
full and complete settlement and compromise with the victim. In
other words, the High Court must consider whether it would be
unfair or contrary to the interest of justice to continue with the
criminal proceeding or continuation of the criminal proceeding
would tantamount to abuse of process of law despite settlement and
compromise between the victim and wrongdoer and whether to
secure the ends of justice, it is appropriate that criminal case is put
 to an end and if the answer to the above question(s) is in
affirmative, the High Court shall be well within its jurisdiction to
quash the criminal proceedings.
d. Because in the present case Chargesheet has not been filed yet and
present case is at the initial stage as per the settlement agreement
executed between the parties and now no useful purpose would be
achieved by prosecution.
e. Because as per the guidelines set by Hon’ble Apex Court for
quashing the FIR as under:
“(II) When the parties have reached the settlement and on that basis

petition for quashing the criminal proceedings is filed, the guiding

factor in such cases would be to secure:

(i) ends of justice, or

(ii) to prevent abuse of the process of any Court.

While exercising the power the High Court is to form an

opinion on either of the aforesaid two objectives.

(iii) Such a power is not be exercised in those prosecutions which

involve heinous and serious offences of mental depravity or

offences like murder, rape, dacoity, etc. Such offences are

not private in nature and have a serious impact on society.

Similarly, for offences alleged to have been committed

under special statute like the Prevention of Corruption Act or

the offences committed by Public Servants while working in

 that capacity are not to be quashed merely on the basis of

compromise between the victim and the offender.

(iv) On the other, those criminal cases having overwhelmingly

and pre-dominantly civil character, particularly those arising

out of commercial transactions or arising out of matrimonial

relationship or family disputes should be quashed when the

parties have resolved their entire disputes among themselves.

(v) While exercising its powers, the High Court is to examine as

to whether the possibility of conviction is remote and bleak

and continuation of criminal cases would put the accused to

great oppression and prejudice and extreme injustice would

be caused to him by not quashing the criminal cases.

(vi) Because Petitioners are fulfilling all the guidelines set out by

the Hon’ble Apex Court and meet all the ingredients setout

therein squarely as such the present petition is liable to be

accepted and FIR no. 29/2021. P.S. Swaroop Nagar U/S

420/409/467/468/471/120B is liable to be quashed.

f. Because Criminal cases involving offences which arise from

commercial, financial, mercantile, partnership or similar

transactions with an essentially civil flavour may in appropriate

situations fall for quashing where parties have settled the dispute.
g. Because as per the settled law by the Hon’ble Apex Court that in

such a case, the High Court may quash the criminal proceeding, if,

in view of the compromise between the disputants, the possibility

of a conviction is remote and the continuation of a criminal

proceeding would cause oppression and prejudice.

h. Because there is no statutory bar under any provision of Cr.P.C

which could affect the inherent powers of this Hon’ble Court under

article 226 of the Constitution of India read with Section 482

Cr.P.C. Furthermore, the same cannot be limited to matrimonial

disputes only and the court has wide power to quash criminal

proceedings even in non-compoundable offences notwithstanding

the bar under Section 320 Cr.PC.

i. Because the powers of the Hon’ble High Court under article 226 of

the Constitution of India Section 482 Cr.PC are plenary in nature

and those powers are not fettered or unbribbled by any provisions

of Cr.P.C.

j. Because the Petitioners are law abiding citizens of the country and

have no bad antecedents to their name.

 k. Because there exists no prima facie case against the applicant or

any reasonable ground to believe that the Petitioners have taken

part in a commission the offences.

4. That the Petitioners craves leave of this Hon’ble Court to urge such

further additional grounds (s), at the time of hearing of this petition,

which has been specifically taken up in this petition.

5. That the Petitioners have no alternative and efficacious remedy except to

approach this Hon’ble court for seeking relief claimed in the petition.

6. That the Petitioner have not filed any other similar petition seeking

quashing of complainant case in question either before this Hon’ble Court

or before the Hon’ble Supreme Court of India.

7. That the present petition is being made bona-fide and in the interests of
justice.

PRAYER

In view of the submissions made hereinabove, it is most respectfully prayed that this

Hon’ble Court may graciously be pleased to: -

(i) Quash the FIR No 29/2021 U/S 409,420,467,468,471,120B of the IPC registered

at P.S Swaroop Nagar, Delhi on the basis of settlement as annexed as annexure

P-1.
(ii) Pass any other or further order which this Hon’ble Court may deem fit and

proper in the interest of justice.

PETITIONER

NEW DELHI
THROUGH
DATED:

HITESH KUMAR, YATIKA CHOUDHARY

& SURAJ RAWAT (ADVOCATES)
CH N0 – 317, LAWYERS BLOCK
SAKET COURT COMPLEX,
NEW DELHI – 110017
Email id: [email protected]
8130668896, 9968058236

IN THE HON’BLE HIGH COURT OF DELHI AT NEW DELHI

CRL.M.C NO._____/2023

IN THE MATTER OF:

VIKAS DHULL AND OTHERS …. PETITIONERS
VERSUS
STATE OF NCT DELHI & ANR. …. RESPONDENT
APPLICATION ON BEHALF OF THE PETITIONER UNDER SECTION
482 OF THE CR.P.C. FOR STAY OF THE INVESTIGATION IN FIR
NO. 29/2021 UNDER SECTION 409,420,467,468,471,120B READ WITH
SECTION 120-B IPC REGISTERED AT PS SWAROOP NAGAR DELHI.

MOST RESPECTFULLY SHOWETH:

1. That the Petitioner has filed the accompanying petition under article 226 of

the constitution of India read with Section 482 of the Cr.P.C. for quashing

of FIR No.0029/2021 under Section 409,420,467,468,471,120B read with

Section 120-B IPC registered at PS Swaroop Nagar, Delhi. The contents of

the petition are not being repeated herein for the sake of brevity and the

same may please read as if forming part and parcel of the present

application.

2. That the settlement between the parties has been arrived at and acted upon

parties relating to their business activities and now they are looking

forward to re-start the work jointly together and had forged all the

misunderstanding. The c present case is fall in all the parameter set out by

the Hon’ble Apex Court and followed by the various Hon’ble High Courts.

Hence, FIR No. 29/2021 P.S – Swaroop Nagar, Delhi is liable to be

quashed in the interest of justice.

3. That in present case Charge sheet has not been filed at and as such the

matter is in very initial stage and no prejudice would cause, if the

 proceeding may be sated by this Hon’ble Court in FIR no. 29/2021, P.S

Swaroop Nagar-Delhi.

4. That the present application is being moved in the interest of justice.

5. That the Applicant would suffer irreparable loss and injury in case the

prayer made herein is not allowed by the Hon’ble Court, however, no

prejudice would be caused to the Respondent No.2

PRAYER

In view of the submissions made hereinabove, it is most respectfully prayed that

this Hon’ble Court may graciously be pleased to: -

(i) Stay the investigation case FIR No. 29/2021 under Section

409,420,467,468,471,120B read with Section 120-B of the IPC registered

at P.S Swaroop Nagar, Delhi till the final disposal of the present petition;

(ii) Pass any other or further order which this Hon’ble Court may deem fit

and proper in the interest of justice.

PETITIONER

NEW DELHI
THROUGH
DATED:

HITESH KUMAR, YATIKA CHOUDHARY

& SURAJ RAWAT (ADVOCATES)
CH N0 – 317, LAWYERS BLOCK
SAKET COURT COMPLEX,
 NEW DELHI – 110017
Email id: [email protected]
8130668896, 9968058236

IN THE HON’BLE HIGH COURT OF DELHI AT NEW DELHI

WRIT PETITION (CRL.) NO. _____/2023

IN THE MATTER OF:

VIKAS DHULL AND OTHERS …. PETITIONERS
VERSUS
STATE OF NCT DELHI & ANR. …. RESPONDENT
APPLICATION UNDER SECTION 482 CR.P.C. FOR EXEMPTION
FROM FILING OFFICIAL TRUE/CERTIFIED COPIES OF THE
DOCUMENTS.

MOST RESPECTFULLY SHOWETH:

1. That the Petitioner has filed the accompanying petition under article 226

of the constitution of India read with Section 482 of the Cr.P.C. for

quashing of FIR No.0029/2021 under Section 409,420,467,468,471,120B

read with Section 120-B IPC registered at PS Swaroop Nagar, Delhi. The

contents of the petition are not being repeated herein for the sake of

brevity and the same may please read as if forming part and parcel of the

present application.

2. That the Petitioner has preferred the accompanying petition on urgent

basis and have annexed certain annexures, however, the copies of the

same are true copies of the annexures and the certified copies/official true

typed copies/official true typed copies are not available for filing the

same with the present Petition.

3. That the Petitioner undertakes to file the official true typed

copies/certified copies of the annexures as and when directed by this

Hon’ble Court or as and when the same is made available to the

petitioner.
 4. That in case the present application is not allowed and the accompanying

petition is not entertained without the official true typed/certified copies

of the Annexures, the petitioner shall suffer irreparable loss and injury.

PRAYER

It is therefore, most respectfully prayed that in the interest of justice this

Hon’ble Court may kindly be pleased to exempt the Petitioner from filing

the official true typed/certified copies of the annexures annexed with the

accompanying petition, in the interest and furtherance of justice.

Any other/further relief may also be granted in favour of the petitioner as

this Hon’ble court may deem fit and proper in the facts and circumstances

of the case and in the interest of justice.

It is prayed accordingly.

NEW DELHI
THROUGH
DATED:
HITESH KUMAR, YATIKA CHOUDHARY
& SURAJ RAWAT (ADVOCATES)
CH N0 – 317, LAWYERS BLOCK
SAKET COURT COMPLEX,
NEW DELHI – 110017
Email id: [email protected]
8130668896, 9968058236