IN THE HON’BLE COURT OF MS.

SAMIKSHA GUPTA, ADDITIONAL

CHIEF METROPOLITAN MAGISTRATE
DWARKA DISTRICT COURT, NEW DELHI
CC No. /2022

IN THE MATTER OF:

Ms. Bhawna Juyal …Complainant

Vs.
Mr. Rohitash Pal …Accused

INDEX

S. NO. PARTICULARS P. NO.

Application under Section 156(3) of the CrPC,
1.
along with Affidavit
Annexure A: FIR bearing No. 0338/22 dated
2.
July 31, 2022
Annexure B (Colly): Copies of the
3. Complainant’s MLC and other Medical
Documents
4. Annexure C: Complainant’s Written Statement
Annexure D (Colly): Complainant’s letter dated
September 30, 2022 to the SHO, Police Station,
5.
Sector 23, Dwarka, along with copy of
Complaint and other enclosures
Annexure E (Colly): Complainant’s letter dated
6. October 14, 2022 to the SHO, Police Station,
Sector 23, Dwarka
Annexure F: Complainant’s letter dated
7. November 7, 2022 to the Deputy Commissioner
of Police, South West Distt. Office.
 Annexure G: Color photograph of accident of
8.
July 31, 2022
Annexure H: E-mail dated August 6, 2022 by
9.
Manish Mishra to Cognizant
Annexure I: E-mail dated August 10, 2022 by
10.
the Complainant to Cognizant
Annexure J: Flowchart of Scheme and Form II
11. as provided under the Motor Vehicles (Fifth)
Amendment Rules, 2022
12. Vakalatnama

Date: /11/2022
 IN THE HON’BLE COURT OF MS. SAMIKSHA GUPTA, ADDITIONAL
CHIEF METROPOLITAN MAGISTRATE
DWARKA DISTRICT COURT, NEW DELHI
CC No. /2022

IN THE MATTER OF:

Ms. Bhawna Juyal …Complainant

Vs.
Mr. Rohitash Pal …Accused

MEMO OF PARTIES

IN THE MATTER BETWEEN:

Ms. Bhawna Juyal …Complainant

D-116, Nawada Housing
Complex, Dwarka,
New Delhi - 110059
Vs.
Mr. Rohitash Pal …Accused
H No. C/S 91/165
Mahila Mohalla, Near Raj Public Vidyalaya,
Madanpur Khadar, Sarita Vihar,
New Delhi - 110076

New Delhi
/11/2022
 IN THE HON’BLE COURT OF MS. SAMIKSHA GUPTA, ADDITIONAL
CHIEF METROPOLITAN MAGISTRATE
DWARKA DISTRICT COURT, NEW DELHI
CC No. /2022

IN THE MATTER OF:

Ms. Bhawna Juyal …Complainant

D-116, Nawada Housing
Complex, Dwarka,
New Delhi - 110059
Vs.
Mr. Rohitash Pal …Accused
H No. C/S 91/165
Mahila Mohalla, Near Raj Public Vidyalaya,
Madanpur Khadar, Sarita Vihar,
New Delhi - 110076

APPLICATION UNDER SECTION 156(3), CRPC READ WITH SECTION 200

CRPC FOR REGISTRATION OF AN FIR AGAINST THE ACCUSED UNDER
SECTIONS 304A, 279, 337, AND 338 OF THE INDIAN PENAL CODE,
1860

IT IS MOST RESPECTFULLY SHOWETH:

1. The present application is with respect to a road accident that

occurred between a cab and a truck in the early morning hours of
July 31, 2022.

2. The Complainant was a passenger in the cab which was being driven
by the Accused herein. That further the Complainant was grievously
injured in the accident, suffering a skull fracture, a slip disk and
multiple stitches, and is still recuperating from the aforesaid injuries.
3. That the FIR in the matter has been lodged on the basis of false and
incorrect facts, with incomplete charges, and against the wrong
accused. That further, the IO has displayed a biased mind in the
manner with which he has conducted the investigation and the
Complainant has no other choice but to believe that he is protecting
the Accused.

4. That the Complainant was also a primary witness to how the accident
occurred. The Complainant submits that the accident occurred due to
the negligence of the Accused herein, and the negligence of a Mr.
Mayank Shekhar.

5. The whole gamut of facts regarding the accident and the events
leading up to it are given below. Through the present Application, the
Complainant requests that an FIR under Sections 304A, 279, 337 and
338 of the Indian Penal Code, 1860 be registered against the Accused,
and Mr. Mayank Shekhar.

BRIEF FACTS

1. The Complainant is employed as a Senior Process Executive (Voice)

with Cognizant Technology Solutions Pvt. Ltd. (“Cognizant”) which is
located in Gurgaon. On the night of the accident i.e., July 31, 2022,
she was working the night shift i.e., from July 30, 2022 at 5 pm in the
evening to 3 am early morning of July 31, 2022.

2. The Accused is a cab driver who has been contracted by Cognizant for
the purpose of picking up and dropping off the employees. That on the
night of the accident, he had been assigned the duty of dropping the
Complainant to her residence. The drivers were assigned to pick up
and drop employees, by Cognizant’s internal transport team. The
 person heading the transport team on the night of the accident was
Mr. Mayank Shekhar, a Cognizant employee. It is also worth noting
that the Accused had been assigned to drop the Complainant to her
residence numerous times before.

3. After the Complainant completed her shift at 3 am, she proceeded to

the Pick-up and Drop off bay area, located on the premises of
Cognizant. She was accompanied by her colleague Manish Mishra
(“the Colleague”). They were both scheduled to be picked up at 3:15
am by the Accused for being dropped to their respective residences.

4. On arriving at the pick-up and drop off area, they discovered that
neither the cab nor the cab driver i.e., the Accused, was present. The
Complainant and her Colleague contacted Mr. Mayank Shekhar who
informed them that the Accused was in a state of extreme drowsiness,
and not in a state to drive and therefore he was being given tea to
wake him up. For reasons best known to Mr. Mayank Shekhar, no
other driver, who was fresh and alert, was appointed by him, despite
being aware that the Accused was not in a fit state to drive.

5. The Accused arrived ten minutes later, and the cab, a Maruti Suzuki
Ertiga bearing No. HR-55 AK-1688 (“the Cab”), departed at 3:30 am.
The passengers in the Cab included the Accused, the Complainant,
the Colleague, and a security guard.

6. However, the Accused was still extremely drowsy and disoriented.

Despite having dropped off the Complainant on earlier occasions, on
this night the Accused took three wrong turns. To ensure that the
Accused was driving in the correct direction, the Complainant became
alert and kept an eye on the road.

7. After the cab entered Dwarka, the Complainant noticed that there was
a Tata 909 Dumper truck, bearing No. DL-1 MA-0138 (“the Truck”)
 that was travelling slowly, ahead of the Cab and in the same direction.
However, the Cab was approaching it at high speed. The Complainant
noticed that the Accused made no signs of slowing down or turning
away to avoid crashing into the truck. When the Cab got extremely
close, the Complainant let out a shout, causing the Accused to
awaken and jerk the steering wheel to the left. However, they were
unable to completely miss the truck, and the cab suffered serious
damage to its front and right side.

8. The accident caused grievous injuries to the Complainant including a

fracture to the skull, a slip disk, and multiple stitches. She was taken
to Indira Gandhi Memorial Hospital, where the MLC was issued.
However, due to lack of proper infrastructure, she was further referred
Deen Dayal Upadhyaya Hospital and then to Safdarjung Hospital, for
further tests. To date, the Complainant is still recuperating from her
injuries, and is undergoing physical and mental therapy in the
hospital.

9. Due to the grievous nature of injuries, the Complainant was confined

to bed rest for three weeks. During this period, she received no news
regarding the investigation of the accident. No police officer came to
record her statement. Therefore, she was also not aware whether any
FIR had been filed in the matter.

10. That on the Complainant’s request, her friend, who is also an

advocate (“the Complainant’s advocate”), visited the police station to
enquire the status of the investigation and discovered that the IO in
the matter was Assistant Sub Inspector Anil Kumar of Police Station,
Sector 23, Dwarka.

11. That the Complainant’s advocate procured a copy of the FIR bearing
No. 0338/22 (“the FIR”) from the IO.
(A copy of the FIR bearing No. 0338/22 is at Annexure A)
12. On receiving a copy of the FIR from her advocate, the Complainant
was shocked to discover that the facts recorded in the FIR were
incorrect and false. Further, the FIR had been filed against the Truck
Driver, when it was in fact the rash and negligent driving of the
Accused that had resulted in the accident.

13. Thus, to get the correct facts recorded, the Complainant made
multiple efforts to get in touch with IO Anil Kumar. However, the IO
refused to meet her and take her statement.

14. It is important to mention that in between all this, the Complainant’s

advocate was able to meet with the IO once and submit the
Complainant’s original MLC and other medical documents, and her
photographs to the IO on September 1, 202. This was so that the
Complainant may receive the compensation she was entitled to under
the Motor Vehicles Act, 1988. That it was thereafter the IO became
increasingly difficult to get in touch with.
(A copy of the MLC and medical documents submitted to IO Anil
Kumar are at Annexure B (Colly))

15. After much persistence, IO Anil Kumar finally met with the
Complainant on September 23, 2022 i.e., more than one and a half
months after the accident. He reluctantly heard the Complainant’s
side of the story but refused to take it on record. The Complainant’s
statement described in detail the cognizable offences committed by the
Cab Driver and Mr. Mayank Shekhar and it was clear that further
investigation was required into the matter. Any effort to give the IO a
written copy of the Complainant’s statement was met with refusal,
and no further investigation seems to have been conducted by the IO.

(A copy of her written Statement is at Annexure C)

16. The Complainant further requested IO Anil Kumar to register her
statement as a separate complaint, and subsequently lodge an FIR on
her behalf against Mr. Rohitash Pal/Accused/cab driver. The IO
refused to do so, providing no reasonable justification.

17. Seeing that the IO was not interested in investigating the case in a fair
and impartial manner, on September 30, 2022 the Complainant wrote
to the Station House Officer (“SHO”), Police Station, Sector 23,
Dwarka, with a copy of her Complaint. The Complainant requested the
SHO to lodge an FIR against the Accused based on the complaint, and
to direct IO Anil Kumar to investigate the matter in a fair and
transparent manner.
(A copy of the letter dated September 30, 2022, along with the
Complaint, and the posting and receipt are at Annexure D (Colly))

18. Based on the Complainant’s letter, a complaint bearing No.

81760052201144 was registered in the Police Station on September
30, 2022. However, the Complainant discovered that on October 5,
2022, the Enquiry Officer (“EO”) appointed to investigate the
Complaint was IO Anil Kumar. Not surprisingly, the IO made no effort
to contact the Complainant let alone register an FIR against the
Accused, based on the complaint. The Complainant again made
numerous efforts to get in touch with the IO, but he ignored her.

19. On October 14, 2022, the Complainant again wrote to the SHO
requesting an FIR to be filed based on her complaint (“October
Letter”). The Complainant also informed the SHO of the improper
investigation being conducted by the IO. Further, the IO had also not
given her any information regarding the insurance compensation since
she had submitted her medical documents. Any attempt to contact
him was met with total radio silence.
(A copy of the letter dated October 14, 2022, and the posting and
receipt are at Annexure E (Colly))
 20. The October letter was also registered as a complaint bearing No.
81760052201208 (“Second Complaint”) on October 17, 2022. On
October 20, 2022, the EO appointed in the matter was again IO Anil
Kumar. Unsurprisingly, the IO behaved in the same manner as before.

21. Thereafter, on November 7, 2022, the Complainant wrote to the

Deputy Commissioner of Police requesting him to file an FIR based on
her complaint. However, no action has been taken by the Deputy
Commissioner of Police either. Thus, the Complainant has no option
but to approach this Hon’ble Court for relief.
(A copy of the letter dated November 7, 2022 is at Annexure F)

GROUNDS FOR ALLOWING THE PRESENT PETITION

I. THE COMPLAINANT’S STATEMENT INTRODUCES NEW FACTS THAT

MUST BE INVESTIGATED

22. That the Complainant’s statement showcases multiple cognizable

offences committed by the Accused, and Mr. Mayank Shekhar. It is
submitted that the law is settled that where a complaint showcases
that cognizable offences have been committed, it is mandatory for an
FIR to be registered. Therefore, an FIR must be lodged against them
under Sections 304A, 279, 337, and 338 of the Indian Penal Code,
1860.

23. That the facts in the FIR bearing No. 0338/22 are false and incorrect.
That the accident occurred due to the rash and negligent driving of
Accused/Rohitash Pal, but the FIR has been lodged against the truck
driver. This is a grave travesty of justice.

24. That in circumstances where the description of events leading upto

offence provided by two parties are different or where the Complainant
 and Accused are not the same parties as in the first FIR, or where the
event was the culmination of a larger game at play, then in that case
not only are Second FIRs justified but recommended. That the facts in
the matter before you satisfy each condition on their own standing,
and therefore an FIR must be lodged against the Accused/Rohitash
Pal, and against other people involved.

25. The Complainant was a primary witness and the most injured person
in the accident. It cannot be said to be a fair and proper investigation
if the Complainant’s statement is not even on record.

26. The Complainant has evidence to corroborate the facts in her

statement, but the IO gave her no opportunity to present them to him.
Further, the pictures taken of the accident do not support the version
of facts recorded in the FIR.
(A copy of the photograph of the Accident site is at Annexure G)

27. That the IO has not given any reasonable grounds for not taking the
Complainant’s statement on record, or for not lodging an FIR based on
her complaint, against the Accused.

II. FIR FILED ON FALSE AND INCORRECT FACTS AND AGAINST THE
WRONG PARTY BY IO ANIL KUMAR

28. That the facts stated in FIR bearing No. 0338/22 are false and
incorrect.
The FIR states that it was the truck that crashed head on into the
right side of the cab, at an intersection. It is submitted that this is
false as the photographs of the incident clearly show that the damage
sustained by the cab is not only to its right side, but also to its front
side. Further, the front of the truck does not have any damage to it.
 Therefore, it is clear that the accident could not have occurred in the
manner that has been described in the FIR.
(A copy of the photograph of the Accident site is at Annexure G)

29. Further, the FIR has been lodged on behalf of the Accused and against
the truck driver, when it was in fact the rash and negligent driving of
the Accused, that led to the accident occurring in the first place. After
the accident, the Complainant and her Colleague both wrote emails to
Cognizant describing the accident. The emails clearly state that the
Accused was in a state of extreme drowsiness.
(A copy of the email sent by the Colleague dated August 6, 2022 at
Annexure H)
(A copy of the email sent by the Complainant dated August 10, 2022
at Annexure I)

30. Further, the charges under which the FIR is presently filed are
incomplete. The charge of Section 338 of the Indian Penal Code, 1860
is also made out against the Accused, and also Mr. Mayank Shekhar,
as the Complainant suffered grievous injuries, as can be seen from the
Complainant’s medical documents.

31. It is further submitted that charge of Section 304A of the Indian Penal
Code, 1860 is also made out against the Accused and against Mr.
Mayank Shekhar, head of the Internal Transport Team at Cognizant.
as it was due to his negligence and recklessness that the Accused was
assigned to drive the Complainant, despite being fully aware of the
disoriented and drowsy state that the Accused was in. The omission of
the aforementioned charges is a glaring irregularity in FIR bearing no.
0338/22.

III. IMPROPER INVESTIGATION CONDUCTED BY IO ANIL KUMAR

32. It is submitted that IO Anil Kumar made no effort to inform the
Complainant that the FIR bearing no. 0338/22 had been lodged, for at
least three weeks after the accident. It was only after the
Complainant’s advocate contacted the IO that the IO provided them
with a copy of the FIR.

33. That during his investigation of the accident the IO made no effort to
record the Complainant’s statement. This is despite the fact that the
Complainant is clearly identified in the FIR as a passenger in the car.
Since the Complainant was not only the most injured in the accident,
but also a primary witness, it is imperative for the IO to have taken
her statement and investigated her allegations. Therefore, it cannot be
said that the IO has conducted a proper investigation. That it was only
after persistent effort that IO Anil Kumar agreed to meet the
Complainant on September 23, 2022, more than a month and a half
after the accident. That even during that meeting, IO Anil Kumar
refused to listen to the Complainant’s oral statement or take it on
record.

34. That the injured/Complainant had clearly stated in her statement

that the Accused was already in a state of extreme drowsiness and
was unable to drive coherently, and that the accident occurred
because the Accused slept at the steering wheel and crashed into the
back of the truck. Despite cognizable offence being showcased in her
statement, and her complaints (First Complaint and Second
Complaint) sent thereafter, IO Anil Kumar refused to investigate
further, let alone file another FIR based on the complaints.

35. That had IO Anil Kumar investigated the matter properly he would
have realized that the Complainant’s statement is corroborated by the
statement of her Colleague also.
(A copy of the Colleague’s email dated August 6, 2022 to Cognizant is
at Annexure H)
36. That even otherwise at the stage of investigation only the allegation of
the Complainant/aggrieved party/injured are to be taken on its face
value and as per the statement of the injured given to IO Anil Kumar,
the SHO concerned and all other higher police authority, the
authorities have failed to register an FIR against the accused under
appropriate sections prescribed in the Indian Penal Code and the
same can be lodged only with the direction of this Hon’ble.

37. That there has been no effort from the side of IO Anil Kumar to
unearth the details of the alleged accident. He has failed to conduct a
proper enquiry/investigation, casting grave uncertainty over the
genuineness and authenticity of the entire investigation process qua
the accused person.

38. That the statements of the Complainant and the Colleague, both are
contrary to the facts recorded in FIR bearing No. 0338/22.

39. That the pictures of the accident also do not corroborate the version of
facts recorded in FIR bearing No. 0338/22

40. It is submitted that had IO Anil Kumar investigated the matter

probably, he would have realized that the accident occurred due to the
recklessness and negligence of Mr. Mayank Shekhar, head of
Cognizant’s Transport Team, and not just the Accused.

41. That the case of the injured is still at an initial stage and great
prejudice will be caused to the injured if the report filed by the
investigating agency is accepted. The investigating agency has caused
miscarriage of justice by not recording the statement of the injured
person and by further not filing the charge sheet under appropriate
sections even after the injured had given his statement through post
and the same were also duly received.
42. That there has been no news from the IO regarding the status of the
Complainant’s claim under the Motor Vehicles Act, 1988. The
Complainant has submitted all the requisite documents to the IO but
has not been given any information by IO Anil Kumar.

43. That the conduct of IO Anil Kumar displays biasedness and a made-
up mind before the investigation was complete. This can be seen by
the fact that no effort was made to get in touch with the
Complainant/victim even after three weeks of the accident.

44. That it is an equally enforceable canon of the criminal law that the
high responsibility lies upon the IO not to conduct an investigation in
tainted and unfair manner. The investigation should not prima facie
be indicative of a biased mind and every effort should be made to
bring the guilty to law as nobody stands above law dehors his position
and influence in the society.

IV. IMPROPER PROCEDURE FOLLOWED BY THE IO UNDER THE MOTOR

VEHICLES ACT, 1988

45. The procedure to be followed by an Investigating Officer on the

occurrence of a road accident can be found under the Motor Vehicles
Act, 1988 (“MV Act”), the allied Central Motor Vehicles (Fifth
Amendment) Rules, 2022 (“MV Rules”), and the Hon’ble High Court of
Delhi’s decision in the matter of Rajesh Tyagi & Ors. v. Jaibir Singh
& Ors. (2021 SCC Online Del 2549).

46. For example, it is the duty of the Investigating Officer, in this case IO
Anil Kumar, to intimate the Claims Tribunal and the Insurance
Company within 48 hours, by submitting to them a First Action
Report (“FAR”) in Form I as provided under the MV Rules. Any victims
 in the accident, as the Complainant is in the present one, is also
entitled to a copy of the FAR. However, no copy of the FAR has been
provided by the IO to the Complainant till date, despite repeated
requests.

47. It is submitted that as per Rule 3 of the MV Rules, the victim (“the
Complainant”) in the present case, is to be furnished the Rights of
Victims of Road Accident and Flow Chart of the Scheme as mentioned
in Form II of the MV Rules. Form II consists of various documents,
copies of which must be provided by the IO to the victim. It is stated
that none of the documents mentioned thereunder have been provided
by the IO to the Complainant, despite repeated requests.
(A copy of the Flow Chart of the Scheme and Form II is at Annexure
J)

48. It is submitted that as per Rule 8 of the MV Rules, the IO is required

to provide the Complainant, with a blank copy of Form VI, which is to
be filled by her and submitted to the IO within 60 days. However,
despite repeated requests the IO did not provide the Complainant with
any form. Instead, he directed the Complainant to provide all her
original medical documents, including the Medico Legal Certificate
(“MLC”) and photographs, informing her that the process for the
compensation under the MV Act and the MV Rules that she is entitled
to, will be initiated by him regardless of the procedure. That
admittedly she submitted her original medical documents by
September 1, 2022, as she had no other choice.

49. It is submitted that as per Rule 6 of the MV Rules, the IO is required

to submit the Interim Action Report (“IAR”) in Form V to the Claims
Tribunal within 50 days of the accident. A copy of the same has to be
provided to the Complainant. However, till date no copy of the IAR has
been given by IO Anil Kumar to the Complainant.
50. It is submitted that as per Rule 12 of the MV Rules, the IO is required
to submit the Detailed Action Report (“DAR”) to the Motor Vehicles
Claims Tribunal, in no later than 90 days of the accident. Further, in
accordance with Rule 13 of the MV Rules, a copy of the same has to
be provided to the Complainant. It is stated that despite the statutory
time limit having expired, no copy of the DAR has been provided to the
Complainant by IO Anil Kumar.

51. Further, no insurance investigator/surveyor has approached the

Complainant yet for their own internal investigation. Therefore, the
Complainant is uncertain as to whether IO Anil Kumar has initiated
the process for the Complainant’s claim for compensation. If the IO
has not informed the Motor Vehicles Claims Tribunal and/or the
Insurers, then such conduct would be illegal as it interferes with the
victim’s statutory right to compensation under the MV Act.

52. Furthermore, the injuries suffered by the Complainant qualify as

grievous injuries. In other words, the injuries sustained are not
superfluous, and therefore she is entitled to considerable
compensation. This is important as even almost four months after the
accident, she still has to frequently visit the hospital for
therapy/check-ups, and therefore still has medical bills to pay.

53. That IO Anil Kumar’s inaction has seriously prejudiced the

Complainant’s right to compensation under the MV Act and the MV
Rules.

54. Further, the accident was serious, and that the Complainant was
truly fortunate to have survived. Therefore, it is imperative that the
correct persons who are actually responsible, due to their
recklessness and their negligence, are brought to book.
 55. It is submitted that this Hon’ble Court has the territorial jurisdiction
to entertain the present Application inasmuch as the criminal
complaint is presently lying with Police Station, Sector 23, Dwarka,
situated within the territorial limits of this Hon’ble Court.

56. It is submitted that the present Application is made bonafide and in

interest of justice and the Complainant has no other effective remedy
except to file the present Application under Section 156(3) of the
CrPC, for seeking direction to be issued to the concerned police
officials for registration of FIR inter alia under sections 304A, 279, 337
and 338 of the Indian Penal Code, 1860.

PRAYER
In light of the aforesaid facts and circumstances, it is therefore most
respectfully prayed that this Hon’ble Court may be pleased to:

a. Direct the SHO of Police Station Sector 23, Dwarka to file an FIR for
rash and negligent acts under Sections 304A, 279, 337, and 338
under the Indian Penal Code, 1860 against the Accused, and Mr.
Mayank Shekhar, and investigate the matter in a fair and impartial
manner.

b. Pass any other and further order which is deemed fit and proper in
the given facts and circumstances, in the interest of justice.

AND FOR THIS ACT OF KINDNESS, THE PETITIONER AS IS DUTY BOUND

SHALL EVER PRAY.

COMPLAINANT

FILED THROUGH
 Armaan Pratap Singh
Advocate for the Complainant
C-163, Defence Colony
New Delhi – 110024
E-mail: [email protected]
Tel: +91 7895272594
IN THE HON’BLE COURT OF MS. SAMIKSHA GUPTA, ADDITIONAL
CHIEF METROPOLITAN MAGISTRATE
DWARKA DISTRICT COURT, NEW DELHI
CC No. /2022

IN THE MATTER OF:

Ms. Bhawna Juyal …Complainant

Vs.
Mr. Rohitash Pal …Accused

AFFIDAVIT

I, Ms. Bhawna Juyal, D/o Mr. Raghuwer Dutt Juyal, aged about 29 years
and resident of D-116, Nawada Housing Complex, Dwarka, New Delhi –
110059, do hereby state and affirm as under:

1. I am the Complainant in the above-matter and I am conversant with

the facts and circumstances of the present case and competent to
swear the present affidavit.

2. The contents of the Application under S. 156(3) read with S. 200 of

the CrPC, are true to the best of my knowledge, based on information
derived from the record of the case, and the legal submissions made
therein are based on legal advice received and believed to be true by
me.
 3. All the contents of the accompanying Application have been drafted by
my legal counsel under my instructions and the contents have been
read over to me and are true and correct.

4. The annexures annexed with the Application are true and correct
copies of their respective originals.

5. I have not preferred any similar or any other application in the above-
mentioned matter.

DEPONENT

VERIFICATION
Verified at New Delhi on this ______ day of November, 2022, that the
contents of the above affidavit are true and correct to my knowledge. No part
of it is false and nothing material has been concealed therefrom.

DEPONENT