in the hon’ble high court of judicature at · pdf file · 2017-11-03in the...

IN THE HON'BLE HIGH COURT OF JUDICATURE AT ALLAHABAD

**************************

DATES AND EVENTS

IN

CIVIL MISC. WRIT PETITION (PIL) NO. OF 2013

(Under Article 226 of the Constitution of India)

(DISTRICT – GHAZIABAD)

People’s Vigilance Committee for Human Right

(PVCHR)& Ors. ----------- Petitioner.

VERSUS

State of U.P. and Ors. -----------Respondents.

(Jauhar Adeeb)(K.K.Roy)(Vishal Kashyap)

ADVOCATES, ADVOCATES ROLL : A/J ,A/K0040,A/V0830,

COUNSELS FOR THE PETITIONER, LAWYERS CHAMBER NO. 122,

HIGH COURT, ALLAHABAD, DATE : .12.2013 MOB.: 7505442158.

IN THE HON'BLE HIGH COURT OF JUDICATURE AT ALLAHABAD

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CIVIL MISC. STAY APPLICATION NO. OF 2013

(Under Chapter XXII Rule 1 of High Court Rules)

ON BEHALF OF

People's Union for Civil Liberties.

----------- Applicant

IN CIVIL MISC. WRIT PETITION (PIL) NO. OF 2013 (Under Article 226 of the Constitution of India)

( DISTRICT – GHAZIABAD )

People’s Vigilance Committee for Human Right (PVCHR),

Through its President Lenin Raghuvanshi, R/o S-A 4/2A, Daulatpur,

Varanasi. -------- Petitioner

VERSUS

1. State of U.P.,

Through Principal Secretary (Home)

U.P., Lucknow.

2. Director General of Police,

U.P. Lucknow.

3. State Human Right Commission,

Through its Secretary,

4/44, Vishal Khand, Gomti Nagar,

Lucknow.

4. Superintendent of Police,

Ghazipur.

5. Station House Officer,

Police Station Dildar Nagar,

District Ghazipur.

6. Shyam Babu,

S.H.O., Police Station Dildar Nagar,

District Ghazipur.

-------- Respondents

To, The Hon’ble The Chief Justice and his other

Companion Judge of the aforesaid Hon’ble Court.

The humble application of the abovenamed

applicants Most Respectfully Showeth as under:-

1. That full facts, reasons and circumstances

have been disclosed in the accompanying writ

petition for the kind perusal and

consideration of this Hon'ble Court.

2. That in view of the facts and circumstances

stated in the accompanied writ petition, it

is, therefore, expedient in the interest of

justice that this Hon'ble Court may graciously

be pleased to direct the State Human Right

Commission to appoint an enquiry committee

headed by one of its Member under the

monitoring of the Hon'ble High Court of

custodial torture and death of Shakeel, S/o

Khalil Ahmad, R/o Ward No. 2, Yaseen Garhi,

Dasna, Police Station Kavi Nagar, District

Ghaziabad by the police of Police Station Kavi

Nagar, District Ghaziabad and submit its

report before this Hon’ble Court in a

stipulated time, otherwise the petitioners

shall suffer an irreparable loss and injury.

P R A Y E R

It is, therefore, Most Respectfully Prayed

that this Hon’ble Court may graciously be pleased

to direct the State Human Right Commission to

appoint an enquiry committee headed by one of its

Member under the monitoring of the Hon'ble High

Court of custodial torture and death of Shakeel,

S/o Khalil Ahmad, R/o Ward No. 2, Yaseen Garhi,



Nagar, District Ghaziabad and submit its report

before this Hon’ble Court in a stipulated time,

otherwise the applicant/petitioner shall suffer an

irreparable loss and injury.

And/or to pass such other and further order

which this Hon’ble Court may deem fit and proper

in the circumstances of the case.

(Jauhar Adeeb)(K.K.Roy)(Vishal Kashyap) ADVOCATES,

ADVOCATES ROLL : A/J ,A/K0040,A/V0830, COUNSELS FOR APPLICANT/PETITIONER,

LAWYERS CHAMBER NO. 122, HIGH COURT, ALLAHABAD,

DATE : .12.2013 MOB.: 7505442158.

IN THE HON’BLE HIGH COURT OF JUDICATURE AT ALLAHABAD

*************************



( DISTRICT – GHAZIABAD )

People’s Vigilance Committee for Human Right (PVCHR),

Through its President Lenin Raghuvanshi, R/o S-A 4/2A, Daulatpur,

Varanasi. -------- Petitioner

VERSUS

1. State of U.P.,

Through Principal Secretary (Home)

U.P., Lucknow.

2. Director General of Police,

U.P. Lucknow.

3. State Human Right Commission,

Through its Secretary,

4/44, Vishal Khand, Gomti Nagar,

Lucknow.

4. Superintendent of Police,

Ghazipur.

5. Station House Officer,

Police Station Dildar Nagar,

District Ghazipur.

6. Shyam Babu,

S.H.O., Police Station Dildar Nagar,

District Ghazipur.

-------- Respondents

To,

The Hon’ble the Chief Justice and his other

companion Judges of the aforesaid Court.

The humble petition of the above named

petitioners Most Respectfully Showeth as under:-

1. That this is the first writ petition (Public

Interest Litigation) filed by the petitioners

before this Hon'ble Court and no other writ

petition has been filed with the same cause of

action.

2. That the petitioners further declare that they

have not received any copy of the caveat

application till date.

3. That this Public Interest Litigation relates

to worst crime of society governed by rule of

law called as custodial death of Shakeel, S/o



Ghaziabad.

4. That the Petitioner’s organization is a

registered organization who is working in the

State of Uttar Pradesh for the preservation,

protection and promotion of Human Rights and

specially for the rights of those peoples who

were subjected to cruel discrimination for the

centuries due to social backwardness and in

economic disparity.

5. That Petitioner’s organization is actively

involved in awareness building among the poor

people to communicate their rights which has

been guaranteed by the Constitution of India

regarding equality, dignity and protection of

their rights.

6. That the Petitioner’s organization has a

constructive and creative outlook towards the

human problem and it is specially engaged in

work for the upliftment of the conditions of

the women, children, dalits, tribals and

minorities.

7. That the Petitioner’s organization is totally

committed to the high and noble ideas of the

Constitution of the country which is based on

the equal protection of law to every citizen

and every person.

8. That the Petitioner’s organization has already

filed several Public Interest Litigations in

the High Court of social importance which is

pending before the Court.

9. That the Petitioner’s organization has filed

Public Interest Litigation No. 42247 of 2013

(People’s Vigilance Committee for Human Right

Vs. State of U.P. & others) for the

educational rights of the children of the

women prisoners languishing in jails of Uttar

Pradesh.




Vs. State of U.P. & others) for the effective

functioning of the State Human Rights

Commission.




Vs. Union of India & others) about the

implementation of the a MNREGA programme and

investigation of corruption in it.

12. That the Petitioner’s organization was

contacted by some human rights activists of

the Ghaziabad city in regard to a custodial

death which happened in the month of June,

2013.

13. That a team of the Petitioner’s organization

reached Ghaziabad and collected some materials

which is the proof of the most inhuman crime

committed by the police who was set to the

custodial of law.

14. That according to the facts gathered by the

Petitioner’s organization, on 13.06.2013 a

police party with Station House Officer, Kavi

Nagar Sudhir Tyagi went to the house of Khalil

Ahmad and enquired about a person named

Shakeel who was the neighbor of the Khalil

Ahmad.

15. That incidentally, the name of the son of the

Khalil Ahmad is also Shakeel.

16. That to help the police party, when Khalil

Ahmad went to the house of the Shakeel, he

found Shakeel absent and informed it to the

police.

17. That the police party held some discussion

within themselves and took Shakeel who is son

of Khalil Ahmad to the Police Station.

18. That Khalil Ahmad tried to persuade the police

party that the person whom you are taking to

the Police Station is my son and he is not

that Shakeel wanted by him.

19. That police party under Shudhir Tyagi, Station

House Officer, Kavi Nagar told Khalil Ahmad

that they will make some query in the Police

Station and then set him free.

20. That after some hours, when father of the

Shakeel went to the Police Station, he saw 3-4

Policemen bitterly beating him and torturing

him.

21. That when Khalil Ahmad tried and pleaded to

release his son who was the object of torture

by the police personnel, he was asked to

arrange Rs. 80,000/- for his release.

22. That being a lower middle class person, Khalil

Ahmad was not in a position to arrange that

huge amount.

23. That Shakeel was kept in the Police Station

for two days without any First Information

Report or warrant in a severely injured

position.

24. That on 15.06.2013, in the morning, the

Shakeel died in the police custody in the

Police Station Kavi Nagar, District Ghaziabad

due to custodial and third degree torture.

25. That Shakeel was neither wanted in a case nor

there was any First Information Report pending

against him.

26. That on 15.06.2013 itself Khalil Ahmad made an

application before the Station House Officer,

Police Station Kavi Nagar narrating the entire

story of the custodial torture and killing of

his son Shakeel. A photocopy of the complaint

of the Khalil Ahmad dated 15.06.2013 moved

before the Station House Officer, Police

Station Kavi Nagar is being filed herewith and

marked as Annexure No. 1 to this Writ

Petition.

27. That according to the contents of the

application of Khalil Ahmad, Station House

Officer Sudhir Tyagi was accompanied by Mangal

Tyagi, Bhupendra, Hom Singh (Dhoom Singh),

Jitendra, Raj Kumar amr Tyagi, Irfan and

Ravindra who were constables in the same

Police Station.

28. That the matter was flashed in the newspaper

about the custodial torture of an innocent

youth by the police of Kavi Nagar Police

Station.

29. That there was a massive protest by the people

of all sects against the third degree torture

and custodial killing of Shakeel who was

neither a criminal nor a wanted law breaker.

30. That after much pressure and persuasion, First

Information Report was lodged in Case Crime

No. 631/2013, U/s 147, 148, 302, 342 & 406

I.P.C. at Police Station Kavi Nagar, District

Ghaziabad on 15.06.2013. A true and typed copy

of the First Information Report dated

15.06.2013 alongwith the details of the

accused is being filed herewith and marked as

Annexure No. 2 to this Writ Petition.

31. That custodial torture is not only naked

violation of human dignity but it is also an

assault civilized society.

32. That the death of Shakeel due to dehumanizing

torture and custodial violence in Kavi Nagar

Police Station raises a finger over the rule

of law in State of U.P.

33. That the incident of the custodial death of

Shakeel is flagrant violation of Article 21 of

the Constitution of India which envisages that

no person shall be deprived of his life and

liberty except accordance with the procedure

established by law.

34. That the recommendation of the National

Human Right Commission was fully and

consciously ignored and over looked.

35. That custodial violence including torture

and death in the lock ups strike a blow at

the rule of law. It is committed by the

person who are supposed to be the protectors

of the citizens. It is committed under the

shield of uniform and authority where the

victims are totally helpless.

36. That in all custodial crimes, what is of

real concern is not only the infliction of

body pain but the mental agony which the

person undergoes within the four wall of

police station or lock-up.

37. That custodial violence is one of the worst

crime in a civilised society governed by

rule of law.

38. That it is clear and emerging principle of

human rights jurisprudence that the State is

responsible not only for the acts of its own

agents, but also for the acts of non-State

players acting within its jurisdiction. The

State is, in addition, responsible for any

inaction that may cause or facilitate the

violation of human rights.

39. That the protection of individual from

oppression and abuse by the police and other

enforcing officer is a major interest in a

free society. Arrest and detention with

violence can cause incalculable harm to the

reputation and self esteem of the person.

40. That torturing a person and using third

degree method are of medieval nature and

they are barbaric and contrary to law.

41. That it may be a legitimate right of any

police officer to interrogate or arrest any

suspect on some credible material but

interrogation does not mean inflicting

injuries.

42. That the Law Commission in its 113th report

recommended that in prosecution of the

police officer, for an alleged offence of

having caused bodily injury to a person,

during the period when the person was in the

custody of police, the court may presume

that the injury was caused by the police

officer having the custody of that person

during that period.

43. That the third report of the National Public

Commission in India expressed its deep

concern with custodial violence and lock up

deaths and made useful suggest of arresting

only in grave offence. The report said that

nearly 60% of the arrests are either

unnecessary or unjustified.

44. That the 4th report of The National Police

Commission, also noticed the prevalence of

custodial torture and deserved that nothing

is so dehumanizing as the conduct of police

in practicing torture of any kind on a

person in their custody.

45. That Article 9(5) of the International

Covenant of Civil and Political Rights, 1966

(ICCPQ) that any one who has been the victim

of unlawful arrest or detention shall have

the enforceable right to compensation.

46. That a scanning of successive reports of

National Human Right Commission would show

that the Uttar Pradesh has been the highest

violator of human right in the whole

country.

47. That for the kind's perusals of Hon'ble

Court some of the details of Human Right

violation are given below.

48. That a chart, diagram of registered case's

during the year from all state in 2000,

2001, 2002, 2004 before National Human Right

Commission would show that U.P. is on the

top of the list.

49. That in annual report of the 2000, 2001,

published by National Human Right Commission

the total case's of human right violation

registered is 70,510 out of which Uttar

Pradesh sitting of top has the credit of

registering 40312, case's next to Bihar with

4113, and Delhi with 4047 case's.

50. That in annual report of the 2001-2002,

published by National Human Right

Commission, the total cases of human right

violation registered is 83695, out of which

Uttar Pradesh sitting of top has the credit

of registering 47445, cases next is Bihar

with 5340, and Delhi with 3540 cases.

51. That a news item was published in Amar

Ujala, a esteemed Hindi Daily, Kanpur

Edition on 30.12.2010 with the heading that

U.P. tops in human right violation matter.

The news is based on report of the National

Human Right Commission and it contains that

in year 2010, total 84223 cases of human

right violation received in the office of

National Human Right Commission, out of

which 48000 cases came from Uttar Pradesh.

The National Human Right Commission report

further reveals that 18068 cases of police

atrocities were reported from Uttar Pradesh

alongwith 14 custodial deaths in jail. That

in annual report of 2002-2003, the total

registered cases has been 68779, the cases

of Uttar Pradesh is 40839, next to it is

Bihar with 4189, then Delhi with 3834.

52. That in year 2003-2004, the total cases

registered with at National Human Right

Commission is 71727, out of which Uttar

Pradesh standing of top has the credit of

40396, cases Bihar second with 4392 cases.

53. That in the matter of custodial death/rape

recorded the National Human Right Commission

1993-1994, with 34 custodial death / rape,

the Uttar Pradesh stand on top. In 1994–1995

Uttar Pradesh fared will with total sixty

eight out of 171 custodial death/rape in

country, Delhi with 38, Assam with 18, Bihar

with 17, West Bengal 15, Punjab 12,

Rajasthan 10, were higher than Uttar

Pradesh. In 1995-1996, out of 444 custodial

deaths/rapes Uttar Pradesh has 37 among the

top six with Bihar 75, Andhra Pradesh 55,

Delhi 40, Maharashtra 34, and West Bengal

51.

54. That in 1997-1998 out of total 999 custodial

deaths/rapes Uttar Pradesh again come on top

with 186 deaths with Madhya Pradesh 133.

Bihar 117, Andhra Pradesh 74, Karnataka 40,

Tamilnadu 67 custodial deaths/rapes.

55. That in 1998-1999 out of total 1286

custodial deaths/rapes in the country, Uttar

Pradesh having 243, Bihar 192, Andhra

Pradesh 121, Madhya Pradesh 118, and

Maharashtra 118, keeps Uttar Pradesh on top.

56. That in 1999-2000 out of total 1093

custodial deaths/rapes Uttar Pradesh having

159, Bihar 162, Assam 162, Andhra Pradesh

64121, and Maharashtra 118.

57. That in 2000-2001, out of total 1037 cases

custodial death/rape Uttar Pradesh with 131

in just below Bihar 139 then Maharashtra 123

and Andhra Pradesh 78.

58. That the from 1993-1994 up to 2000-2001 the

total registered cases custodial death/rape

from the whole of the country has been 5951

with Uttar Pradesh on top with 940 cases

thereafter Bihar with 799, Andhra Pradesh

with 515, Madhya Pradesh with 333 and West

Bengal with 222 cases, these are the cases

reposted before National Human Right

Commission. A photocopies of the different

datas narrated above is being filed herewith

and marked as ANNEXURE NO. 3 to this writ

petition.

59. That the grim human right situation of Uttar

Pradesh could not escape the attention of

the judicial scrutiny time and again. The

need of formation of Human Right Commission

was felt and three mandamus judgments were

issue to form it.

60. That all these data has been taken from the

reports and annual reports published by the

National Human Right Commission.

61. That on 14.12.1993, the Secretary General of

the National Human Right Commission sent a

letter to all the Chief Secretaries on the

reporting of the custodial deaths within 24

hours of its happening to the office of the

National Human Right Commission and it has

requested the Chief Secretaries that in view

of the rising number of incidents and

reported attempt, to suppress or present a

different picture of this incidents of

custodial deaths and custodial rapes. A

direction should be issued to the District

Magistrates and Superintendents of police of

every districts that they should report to

the Secretary General of the Commission of

such incident within 24 hours of occurrence.

Failure would give rise to the presumption

that there was an attempt to suppress the

incident. A photocopy of the letter dated

14.12.1993 issued by the National Human

Right Commission to the Chief Secretary of

all States is being filed herewith and

marked as ANNEXURE NO. 4 to this writ

petition.

62. That thereafter on 21.06.1995, the Secretary

General of National Human Right Commission

wrote letter to the Chief Secretaries of all

States and Union territories that the

Commission be informed regarding all deaths

in judicial custody also and it should be

reported to Commission within 24 hours of

its occurrence. A photocopy of the letter

dated 21.06.1995 issued by the National

Human Right Commission to the Chief

Secretary of all States is being filed

herewith and marked as ANNEXURE NO. 5 to

this writ petition.

63. That again on 01.01.2000, the Chairperson of

the National Human Right Commission who also

happens to be the Former Chief Justice of

India, circulated a letter to the Chief

Justices of all High Courts with regard to

human rights in prison and requested the

Hon'ble Chief Justices to give appropriate

instructions to the District and Session

Judges to take necessary steps to resolve

the acute problem which has the impact of

violating a human right which is given the

status of constitutional guarantee. In

this letter the Chairman of the National

Human Right Commission expressed his

dissatisfaction to the fact that Session

Judges are not regular in visiting prisons

and the District Committee is not meeting at

regular intervals to review the conditions

of the prisoners. A photocopy of the letter

dated 01.01.2000 issued by the Chairman of

the National Human Right Commission is being

filed herewith and marked as ANNEXURE NO. 6

to this writ petition.

64. That protection of Human Rights Act was

elected in 1993 with the laudable object of

protecting and preserving the Human Rights.

65. That State Human Right Commission in Uttar

Pradesh has been formed in terms of Section

21 of the Protection of Human Rights Act.

66. That under Section 12 of the Protection of

Human Rights Act, the Commission shall

perform duty including enquiry, suo-moto or

on a petition presented to it by a victim or

any person into complaint of Violation of

Human Right.

67. That under section 17 of the Protection of

Human Rights Act, the commission is empower

to enquire into the complaints of violations

of human rights.

68. That it is the duty and obligation of the

State Human Right Commission to enquire into

the matter of custodial death which is worst

form of the human right violation.

69. That for the reasons stated above, it is,

therefore, expedient in the interest of

justice that this Hon'ble High Court may

graciously be pleased to direct the State

Human Right Commission to appoint an enquiry

committee headed by one of its Member under

the monitoring of the Hon'ble High Court of

custodial torture and death of Shakeel, S/o




Nagar, District Ghaziabad and submit its

report before this Hon’ble Court in a

stipulated time, otherwise the petitioner

shall suffer an irreparable loss and injury.

70. That petitioner is advised to state that he

has no other alternative and efficacious

remedy than to approach this Hon'ble High

Court in its extra ordinary jurisdiction under

Article 226 of Constitution of India on

following amongst other grounds.

GROUNDS

i. Because, ii. Because,

P R A Y E R

It is, therefore, Most Respectfully Prayed

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

(i) issue a writ, order or direction in the

nature of MANDAMUS commanding the State

Human Right Commission to appoint an

enquiry into the matter of the custodial

torture and death of Shakeel, S/o Khalil

Ahmad, R/o Ward No. 2, Yaseen Garhi, Dasna,

Police Station Kavi Nagar, District

Ghaziabad by the police of Police Station

Kavi Nagar, District Ghaziabad and other

constables in Police Station Kavi Nagar

U/s 17 of Protection of Human Right Act,

1993 and submit its report before this

Hon'ble Court in stipulated time.

(ii) issue a writ, order or direction in the

nature of MANDAMUS directing an

independent, impartial enquiry to be

conducted by any retired District Judge

of the State for submitting its report

before the Court in a stipulated time.

(iii) issue a writ, order or direction in the

nature of MANDAMUS commanding the

Respondent No. 1 & 2 to furnish the

record all custodial torture, custodial

death and custodial rape in Police

Stations, Police Lines and Police

Outposts, Lock-ups in Uttar Pradesh for

the last one year.

(iv) issue a writ, order or direction in the


Respondent No. 1 to pay adequate

compensation to the family members of the

deceased Shakeel, S/o Khalil Ahmad, R/o

Ward No. 2, Yaseen Garhi, Dasna, Police

Station Kavi Nagar, District Ghaziabad.

(v) issue a writ, order or direction in the


respondents to initiate the departmental

and disciplinary proceeding against the

police personnel of Police Station Kavi

Nagar, District Ghaziabad who are

responsible for the custodial death of

Shakeel.

(vi) issue a writ, order or direction which

this Hon'ble Court may deem fit and

proper under the facts and circumstances

of the case.

(vii) award the cost of the petition to the

petitioner.


ADVOCATES ROLL : A/J ,A/K0040,A/V0830, COUNSELS FOR THE PETITIONER,


DATE : .12.2013 MOB.: 7505442158.

IN THE HON’BLE HIGH COURT OF JUDICATURE AT ALLAHABAD

********************

AFFIDAVIT

IN






VERSUS


Affidavit of : Lenin Raghuvanshi,

Aged about 48 years, Son of Shri

Surendra Nath Singh, President of

People’s Vigilance Committee for

Human Right (PVCHR) Organization,

Resident of S-A 4/2A, Daulatpur,

Varanasi. Hindu by religion,

Occupation : Social Worker.

(Deponent)

I, the deponent above named do hereby solemnly

affirm and state on oath as under:-

1. That the deponent is the President of the

Petitioner’s organization in the aforesaid

writ petition and as such he is fully

acquainted with the facts of the case

deposed to below.

I, the deponent above named do hereby swear

that the contents of para 1 of this affidavit and

contents of paras ....................... ........

........... of the writ petition are true to my

personal knowledge, those of paras ............

...... .......... of the writ petition are based

on perusal of records and those of paras .......

........ of the writ petition are based on legal

advice, that no part of it is false and nothing

material has been concealed.

SO HELP ME GOD

DEPONENT

I, Vishal Kashyap, Advocate, Enrollment No.

UP-05363/12 do hereby declare that the person

making this affidavit and alleging himself to be

the deponent is known to me from perusal of

papers, produced by him in this case and I am

satisfied that he is the same person.

ADVOCATE

Solemnly affirmed before me on this day of

December’2013 at a.m./pm by the deponent who

has been identified by the aforesaid person.

I have satisfied myself by examining the

deponent that he has understood the contents of

this affidavit as well as the contents of

accompanying writ petition which have been

explained to him.

OATH COMMISSIONER

IN THE HIGH COURT OF JUDICATURE AT ALLAHABAD

********************

ANNEXURE NO. ( 1 )

IN






VERSUS


********************

IN THE HON'BLE HIGH COURT OF JUDICATURE AT ALLAHABAD **************************

INDEX

IN






VERSUS


S.No. Particular Date Annex Page No.

1. Dates and Events

2.

Civil Misc. Stay

Application U/C XXII Rule

1 of High Court Rules.

3.

Civil Misc. Writ Petition

U/A 226 of Constitution of

India.

4.

Photocopy of the complaint of the Khalil Ahmad moved before the Station House Officer, Police Station Kavi Nagar.

15.06.2013 1

5.

True and typed copy of the First Information Report alongwith the details of the accused.

15.06.2013 2

6. Photocopies of the

different datas. 3

7. Photocopy of the letter

issued by the National 14.12.1993 4

Human Right Commission to

the Chief Secretary of all

States.

8.

Photocopy of the letter

issued by the National

Human Right Commission to

the Chief Secretary of all

States.

21.06.1995 5

9.

Photocopy of the letter

issued by the Chairman of

the National Human Right

Commission.

01.01.2000 6

10. Affidavit in support of

the Writ Petition.

11. Proof of identification of

the deponent.

12. Vakalatnama


ADVOCATES ROLL : A/J ,A/K0040,A/V0830, COUNSELS FOR THE PETITIONER,


DATE : .12.2013 MOB.: 7505442158.

in the hon’ble high court of judicature at · pdf file · 2017-11-03in the...

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