INTERNSHIP DIARY

In Partial Fulfilment of the curriculum for Semester V

Law Centre-I, Faculty Of Law , University of Delhi

UNDER THE GUIDANCE AND SUPERVISION OF :

ADVOCATE GAURAV CHAUDHARY

SUBMITTED TO :
Dr. Swati Jindal Ma'am

SUBMITTED BY :
Narendra Singh
CLASS ROLL NO. 226555
SECTION – I

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 INDEX

S.No. Particulars Page No.

1. Acknowledgment 3
2. About the Internship 4
3. PART – A: Factual and Analytical Information About the Internship 5 – 40
4. PART – B: Legal Documents Drafted during the Internship 41-73

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 ACKNOWLEDGEMENT

I wish to express my sincere gratitude to Advocate Mr. Gaurav Chaudhary for

providing me the opportunity to intern under Her guidance and for helping me gain
the knowledge of legal practice as well as the skills of drafting various legal
documents. I also wish to express my sincere gratitude to the associates working in
Her chambers for guiding and helping me in completing every task assigned to me,
efficiently.

I am also grateful and indebted to my teacher Dr. Swati Jindal Ma'am, for filling in
the gaps in my knowledge and for her cordial support, valuable information and
guidance, which helped me in completing this task.

Dated : ………

Place : New Delhi

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 ABOUT THE INTERNSHIP

In the month of October 2022, I interned with Advocate Mr Gaurav Chaudhary.

His chamber is located in CH-No. D-507, Lawyer's Building, Karkardooma Courts,
Delhi, 1100032

Her areas of practice are Family, Criminal and Civil Disputes. Her matters are
listed in the Hon’ble Supreme Court Of India and various District Courts and
Tribunals.

Chamber Address: CH-No. D-507, Lawyer's Building, Karkardooma Courts,

Delhi, 1100032

Enrolment Number:

Duration of Internship:……..

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 PART – A

FACTUAL AND ANALYTICALINFORMATION ABOUT THE INTERNSHIP

DAY 1:

I started my internship in the chamber of Senior Advocate Mr. Gaurav Chaudhary………. I

received a mail from His chamber, confirming my internship, in the month of October 2022. I was
asked to report to the office at 5.30 p.m. as the Court had resumed that day after the summer break
and all the associates would have been in the Court in the morning. I reached the office at 5.15
p.m. I introduced myself to the receptionist and gave Him my personal details for the intern
records. he showed me to the intern room and asked me to wait as Rajkumar Sir was busy in a
client meeting. Meanwhile, I proceeded to the intern room and met the other interns. Apart from
me, thise were four more interns. It was their first day as well. Some of them had been told to
report to the Chambers directly in the morning. After one hour, the receptionist called me to
introduce me to sir, in His office. he had another client meeting scheduled and she could only spare
5 minutes. Advocate Mr. Shivani Luthra Lohiya, who also heads the interns, was also present thise.

Anyone would think that 5 minutes is too less a time to meet someone for the first time and
introduce yourself. But, those 5 minutes were all I needed to feel comfortable in the new
environment. After I had introduced myself, sir asked me what kind of work I was interested in. I
told His that I was keen to learn everything about the litigation world and I would be interested in
any kind of work assignedto me in His chamber. I took this opportunity to inform Him about the
internship report we were required to make as a part of our curriculum. he inquired about the
requirements of the internship report. he, in a humorous manner, told me that they did not have so
much work to be done and gave me a warm welcome to Her chamber by saying “Join our small
gang”.As it was my first day, I was not given any work to do. I was allowed to leave the office by

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7.30 p.m.However, one of the associates asked to me to go directly to Patiala House District Court
the next day at 12 p.m. and to call him once I had reached thise.

DAY 2

Court Visit - Patiala House District Court

As told, I reached Patiala House District Court at 11.45 a.m. This was my second time in the
Patiala House District Court. It took me a while to find the court room of Learned Metropolitan
Magistrate (Court Room No.21). Once I reached thise, I called the associate who had allotted me
this task. He explained to me what was to be done. I went to the Ahlmad of the said court room
and requested him to take out the files of the matter A v. B. Once he took them out, I checked if
the compliance of process fees for the summons had been done. Since it was not done, I requested
the Ahlmad to prepare the required documents. It took him around 40 minutes to do the same,
stamp them and get them signed from the concerned person. He handed me copies of the four
documents that he had prepared, which I handed over to the associate who assigned me this task
once I reached the office.

He asked me if I knew what those documents were. Since, I did not know, he was more than happy
to explain it to me.

Case File Reading

When the associates came back to the office in the evening, I went and asked one of them for work.
He handed over a case file to me to read and make a synopsis for her reference. The matter was
titled C v. D, in which the husband had filed a petition under Section 13(1)(ia) of the Hindu
Marriage Act, 1955 against our client (her wife) for divorce. He had alleged that our client indulged
in voluntary sexual intercourse with a person other than him and also subjected him to cruelty.
They also had a seven-year-old daughter. Written Statement had to filed on behalf of our client,
alleging that she was the one who was subjected to cruelty and that Her husband was having an
extra-marital relationship due to which had deserted Her and their daughter.

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During my internship, I assisted the associate in this matter on a regular basis and closely worked
with the client as well.

He handed me the original copy of the Written Statement and the Counter Claim that had been
drafted by him and asked me to report to Family Court in the Patiala House District Court the next
day, at 9 a.m. sharp. He gave me the client’s contact number and asked me to coordinate with Her
in the morning and get all the documents ready for filing before he came to the Court. While
entrusting we with the original documents and the evidences, he told me that it was my
responsibility to keep them safe till the next day.

Later during the day, all the interns were added to the whatsapp group for future updates regarding
the allotment of Courts. Once the cause list for the next day was prepared by the clerk, the same
would be updated on the group by one of the associates.

I left the office at 7.30 p.m.

DAY 3

Court Visit – Patiala House Court, High Court of Delhi and Supreme Court of India

I reached the Family Court in Patiala House Court at 9 a.m. sharp and called the client. She told
me that she will be reaching by 9.30 a.m. and that I should start getting the documents ready. I had
to get three copies made of the Written Statement (37 pages) as well as the Counter Claim (54
pages). Luckily, the associate had told me the exact photocopy shop to go to, to get the work done
faster and on time. I got the photocopies done till the client arrived. I got all the documents signed
from Her and got them attested from the Notary Public.

While waiting for the associate, I had a conversation with the client about Her case. She told me
what all happened during Her marriage and how Her husband and her family subjected Her to
cruelty. She also told me that they were planning to file an application for implement of the woman
with whom Her husband was having an extra-marital relationship.

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Once the associate had come, we went to the court room and I stayed with the client the entire
time. Our client was supposed to pay Rs. 10,000 to the opposite party. However, due to some
misunderstanding, she thought it was only Rs. 5,000 and had not paid the rest. The opposing
counsel argued that we did that on purpose and it prejudiced her client. But, we were able to
convince the learned Judge that it was a genuine mistake and he imposed an additional nominal
cost for non-compliance of the order.

The Written Statement and the Counter Claim had to be filed. But, our client wanted to add some
new evidence and additional information, so the associate requested the Court to grant additional
time to file the same.

Since I was in the Court since 9 a.m., our client decided to give me a treat for the efforts I had put
in getting Her documents ready on time. We continued to have a conversation about Her case till
she had to leave.

Once the client left,I went to the High Court of Delhi to get my monthly pass made. I went to the
Chambers and joined the other interns present thise. We were called to Court Room No. 8.
However, by the time we reached thise, the matter was already over.

Then, one of the associates asked me and another intern to go to the Supreme Court of India and
get a file from the Chamber. We took the file and then went to the office.

On my 3rd day of my internship, I had already visited three courts.

Case File Reading and Other Tasks

Once I went back to the office, the same associate gave me authorities to make a compilation in
the matter of E v. F– Prepare an index, arrange and number them. In the said matter, the accused
had been sentenced and he had filed an appeal. Till the Court gave a decision on the appeal, he
wanted a suspension of her sentence. Once I had compiled the authorities, he asked me to read one
of them and understand how suspension of sentence works. The authorities I read were:

- Bhagwan Rama Shinde Gosai and Others v. State of Gujarat; (1994) 4 SCC 421;
- Stanny Felix Pinto v. Jangid Builders Pvt. Ltd. and Another; (2001) 2 SCC 416;
- Angana and Another v. State of Rajasthan; (2009) 3 SCC 767

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Our client had deposited cash in a Bank under someone else’s name (fictitious) and withdrew some
of it. A case was filed under the Prevention of Corruption Act, 1988 and for ‘forgery’ under the
Indian Penal Code, 1860. I was asked to read cases on forgery also. The associate handed me a
commentary of the Indian Penal Code, 1860 and asked me to read, understand and then explain to
him what I understood about Section 463 and Section 464. He kept asking me to read
commentaries and the authorities on the same, till I understood the concept of ‘forgery’. Once I
had explained the provisions to him, he asked me to apply them to our client’s case and tell him
whether he was guilty for forgery. The authority I read on ‘forgery’ was Mohammed Ibrahim and
Others v. State of Bihar and Another; (2009) 8 SCC 751.

I was asked to report to Patiala House District Court the next day.

I left the office at 8.30 p.m.

DAY 4

Court Visit – Patiala House District Court

I reached the Patiala House Court at 10 a.m. The associate asked me to go to the court room of
Mr. Snigdha Sarvaria, Learned Metropolitan Magistrate (Court Room No.21) and observe the
proceedings. I was asked to update him on the matter that was being heard in the court room and
inform him when our matter was about to be called out.

The said matter was technically not our matter as the client had decided to change her Counsel.
However, due to certain circumstances, the associate was anticipating that the client would come
back, so he wanted to keep a track on the proceedings in the said matter.

The matter was called out just before the lunch time. The associate asked me go to the Reader of
the court room and ask him the date for the next hearing.
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I was then asked to report to the office.

Legal Research

An associate gave me a proposition to research on, which was, ‘Whether the wife or the children
have a share in the self-acquired property of the husband/ fathis, which was purchased after
the marriage’.

He had already researched on the proposition and he was not able to find anything on the same.
So, he asked me to spend a maximum on 15 minutes on the same and revert to him with anything
and everything that I find within 15 minutes.

I did not find any authority on the same but, I found a few articles which discussed this issue. One
such article mentioned that the Marriage Laws (Amendment) Bill seeks to empower the courts to
decide the compensation amount from the husband’s in Herited and in Heritable property for the
wife and children once the marriage legally ends. The bill has a provision for share in a husband’s
self-acquired property. It also mentioned that as per the new Divorce law, wife’s share in property
would be 50% in all Her husband’s residential properties, no matter what and in other properties,
Her share will be decided as per the court decision. Earlier, no quantum was defined as per law.
However, the wife would have to specifically apply for Her share. This rule was applicable to all
the properties of the husband, acquired before and after the marriage.

The associate asked me to mail him the article, which I did.

I had not been assigned any Court for the next day and was asked to report to the office in the
morning. I left the office at 8 p.m.

DAY 5

I reached the office at 10.30 a.m.

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Drafting of Legal Document

The associate working on the matter titled C v. D was in the office at that time. I went to him and
asked him for work. He asked me to draft a Complaint under Sections 323, 406, 420, 498-A, 506,
509, 34, 120-A and 511 of the Indian Penal Code, 1860 for the said matter and address it to the In-
charge of the Crime Against Women Cell.

He handed the Written Statement as well as the Counter Claim, both of which were very lengthy,
to me and asked me to read them in and out and draft a Complaint on the basis of the content in
the said documents. He also gave me two sample complaints for reference purpose.

Though I had already read both the documents earlier during the internship, I started reading them
again so that I could start drafting the Complaint.

The associate told me to continue taking work from other associates and draft the Complaint side-
by-side and send it to him within one week.

Legal Research

Meanwhile, I was given a proposition to research on, which was, ‘Whether the defence can be
struck off in a divorce proceeding, if the husband has persistently and wilfully defaulted in
the payment of interim maintenance or litigation expenses ordered by the Court to be paid
to the wife.’

This research was in the matter of G v. H. In the said matter, the husband was a persistent and
wilful defaulter in payment of interim maintenance to the wife (our client). Thus, thise was non-
compliance of the orders of the Court. Initially, he was paying the maintenance but then he stopped.
Execution proceedings had also been initiated by the wife.

The associate asked me to research on the said proposition in light of the provision to strike off
defence of the husband on the ground of persistent and wilful non-compliance of the orders of the
Court under Order VI Rule 16 of the Code of Civil Procedure, 1908 and also under the inherent
powers of the Court under Section 151 of the Code of Civil Procedure, 1908.

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I stopped reading the documents in the matter of C v. D and starting researching on the said
proposition.

I came across the following High Court judgments to support the contention of striking off the
defence of the husband under the facts and circumstances of the said case:

- Hema v. Parthasarathy; (2002) 4 CTC 17 – It was observed that the legal position is that if the
husband fails to make payment of interim maintenance/litigation expenses, as ordered by the
Court, then the wife can file an application praying the Court to dismiss the petition or strike
off the defence. However, the Court should not straight-away pass an order. It should give him
another opportunity giving reasonable time, minimum of three weeks. Only on her failure to
make the payment, the original petition can be dismissed or defence can be struck off.
- C. S. Mangalam v. Velayudhan Asari @ Surendran Asari; (1992) 2 KLJ 912– It was observed
that the Court has jurisdiction to prevent the abuse of the process of the Court. It would have
been justified to strike off the defence, even if thise is no such provision in the Hindu Marriage
Act, 1955. The defence of the husband should be struck off for deliberate non-payment of
maintenance and litigation expenses.

Similar observations were made in –

- Kannamma v. Y. Subramaniam; (1997) 1 LW 637
- Narayana Nadar v. Jayakodi Ammal; I (1990) DMC 596
- Atreyapurapu Venkata Subba Rao v. Atreyapurapu Venkata Shyamala; II (1990) DMC
486

Once I was done with the research, I continued reading the documents in the matter of C v. D and
I started drafting the Complaint after I finished reading it.

At around 8.30 p.m., Rajkumar sir came to the intern room and informed us that he had been
invited to the Indian Habitat Centre to give a talk on international child abduction and we should
attend His talk the next day.

I had not been assigned any Court for the next day and was asked to report to the office in the
morning.

I left the office at 9.30 p.m.

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 DAY 6

I reached the office at 10 a.m.

Drafting

Since none of the associates were in office when I reached, I continued drafting the complaint in
the matter of C v. D. The Complaint was under Sections 323, 406, 420, 498-A, 506, 509, 34, 120-
A and 511 of the Indian Penal Code, 1860. I was required to inculcate all the incidences mentioned
in Written Statement and the Counter Claim, though in a concise and to-the-point manner.

Talk on The Hague Convention on the Civil Aspects of International Child Abduction

At around 2 p.m., we left for the India Habitat Centre to attend Rajkumar talk on ‘Whether India
should be a signatory to The Hague Convention on the Civil Aspects of International Child
Abduction’.

Apart from sir, thise were 6 to 7 other eminent speakers. sir was of the opinion that the International
Courts are faster as compared to the Indian Courts. Till the cases start in India, the International
Courts have already decided the matter. India first needs to tackle the problem within the country
before it can become a signatory to The Hague Convention.

The other speakers discussed certain precedents, some of them are:

- Ruchi Majoo v. Sanjeev Majoo; (2011) 6 SCC 479 - It was held that the interest of the minor
shall be better served if he continued in the custody of her mother. The duty of the Court
exercising its parens patriae jurisdiction as in cases involving custody of minor children is all
the more onerous. Welfare of the minor in such cases being the paramount consideration, the
Court has to approach the issue regarding the validity and enforcement of a foreign decree or
order carefully. Since no system of private international law exists that can claim universal
recognition on this issue, Indian courts have to decide the issue regarding the validity of the

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 decree in accordance with the Indian Law. Comity of courts simply demands consideration of
any such order issued by the foreign courts and not necessarily their enforcement.
- V. Ravi Chandran (Dr.) v. Union of India and Others; (2010) 1 SCC 174 – It was held that
while dealing with a case of custody of a child removed by a parent from one country to another
in contravention of the orders of the court where the parties had set up their matrimonial home,
the court in the country to which the child has been removed must first consider the question
whether the court could conduct an elaborate enquiry on the question of custody. If the court
takes the view that an elaborate enquiry is necessary, it is bound to consider the welfare and
happiness of the child as the paramount consideration and go into all relevant aspects of welfare
of the child including stability and security, loving and understanding care and guidance and
full development of the child's character, personality and talents. While doing so, the order of a
foreign court as to her custody may be given due weight. The weight and persuasive effect of a
foreign judgment must depend on the circumstances of each case.
- Surya Vadanan v. State of Tamil Nadu and Others; (2015) 5 SCC 450 - Thise are following
two principles in such cases. They are:
(i) The principle of comity of courts; and
(ii) The principle of the best interests and the welfare of the child.

These principles have been referred to as ‘contrasting principles of law’(Shilpa

Aggarwal v. Aviral Mittal; (2010) 1 SCC 591) but they are not ‘contrasting’ in the sense of one
being the opposite of the other. They are contrasting in the sense of being different principles
that need to be applied in the facts of a given case.

When we came back to the office after the talk, Rajkumar sir called all the interns to His cabin and
asked us what we thought about the talk. The conversation was a short one because he had clients
waiting. But, he took everyone’s view and also gave us Her view on the topic and about what the
other speakers said.

Drafting (Continued)

After this, I continued drafting the Complaint in the matter of C v. D.

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I was not allotted any Court for the next day and was asked to report to the office in the morning.

I left the office at 9 p.m.

DAY 7

I reached the office at 10 a.m.

Legal Research

I was given a proposition to research on, which was, ‘Whether a counter claim can be raised
once the right to file a written statement has been lost’.

I found a Supreme Court judgment which laid down the law on the abovementioned question.

Ramesh Chand Ardawatiya v. Anil Panjwani; (2003) 7 SCC 350 – It was held that once the right
of the defendant to file written statement has been lost or the time limited for delivery of the
defence has expired, then neithis can the written statement be filed as of right nor a counter-claim
can be allowed to be raised, for the counter-claim under Rule 6-A must find its place in the written
statement. The court has a discretion to permit a written statement being filed belatedly and,
thisefore, has a discretion also to permit a written statement containing a plea in the nature of set-
off or counter-claim being filed belatedly. Such discretion shall be exercised in a reasonable
manner keeping in view all the facts and circumstances of the case including the conduct of the
defendant, and the fact whether a belated leave of the court would cause prejudice to the plaintiff
or take away a vested right which has accrued to the plaintiff by lapse of time.

Drafting

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I completed the drafting of the Complaint in the matter of C v. D and mailed it to the concerned
associate.

A copy of the draft of the said complaint has been reproduced in Part – B of this internship diary.
The names of the parties involved as well as their personal information has been blacked out since
it is confidential information.

Other Tasks

One of the associates asked me to type an 18-page long Lease Deed, as the same had to be attached
as an annexure in a matter. He also asked me to type the resolution passed in the Board of Directors
meeting of XYZ Company (our client).

I was asked to report to the Family Court in Saket District Court the next day at 10 a.m.

I left the office at 8p.m.

DAY 8

Court Visit –Saket District Court

I reached the Family Court in Saket District Court at 10 a.m. and I straight-away went to the
Family Court of Learned Mr. Justice Dinesh Kumar Sharma. The matter listed in that Court was I
v. J. In the said matter, the opposite counsel had taken a passover multiple times. While arguing
Her case, she was literally yelling at the learned Judge and was very rude to him. The Judge did
not appreciate such kind of behaviour and despite her warning, she continued to behave in the
same manner. He refused to hear Her arguments and imposed a cost of Rs.15000 for deliberately
delaying the proceedings and for misconduct.

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I received a call from one of the associates in office and she asked me to file a list of authorities in
the court room of Mr. Sheetal Chaudhary Pradhan, Learned Metropolitan Magistrate, Mahila Court
(Court Room No. 507). She had mailed me the judgments. I went to the print-out room in the Court
to get the judgments printed and also prepared an index for the same. Thise after, I went to the
photocopy room to get one additional set made. After compiling the set, I went to the Reader of
the court room and handed Her the compilation for putting it on the record and also enquired the
next date for the hearing.

Drafting

When I went to the associate working on the matter titled C v. D to ask him if he had read the
Complaint I had drafted, he informed me that an urgent issue had come up in the said matter. The
Ministry of Defence had issued a notice to our client under Section 4(1) & 4(2)(b)(ii) of the Public
Premises (Eviction of Unauthorised Occupants) Act, 1971 for Her eviction on the grounds
mentioned in the said notice. Our client was required to show cause on or before 25 th July 2018 as
to why such an order of eviction should not be made and she was also called upon to appear in
person in front of the Estate Officer or through a duly authorized representative on 25 th July 2018
at 3 p.m. for personal hearing. If she failed to appear, the case would be decided ex-parte.

Since this involved the question of our client’s eviction, it was a priority task.

Legal Research

The associate asked me to research on the proposition for the purpose of replying to the Notice
of Eviction, which was, ‘Which will prevail, an eviction notice under the Public Premises
(Eviction of Unauthorised Occupants) Act, 1971 or a Residence Order passed under the
Protection of Women from Domestic Violence Act, 2005’.

I carried out an extensive research on the said proposition, however, I was not able to find a
precedent which answered the question stated above. However, I did find a precedent which
could help us. It was V.D. Bhanot v. Savita Bhanot; (2012) 3 SCC 183, in which the Magistrate
passed a protection/residence order under Section 18 and 19 of the Act, protecting the right of
the respondent wife to reside in Her matrimonial home in Mathura. The Petitioner retired from

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 service and filed an application for eviction from the government accommodation in Mathura
Cantonment. The Hon’ble Supreme Court directed the Petitioner to provide a suitable portion
of her residence to the Respondent for Her residence with all necessary amenities to make it
properly habitable. Consequently, a sum of Rs.10000 to be paid to the Respondent for obtaining
alternative accommodation in the event the Petitioner was reluctant to live in the same house
with Her.

The associate asked me to mail the said authority to him, which I did immediately.

I assisted him in the vetting of the Reply to the Notice of eviction to show cause, which he filed
the very next day with the concerned authority.

I was asked to report to the Patiala House District Court at 10 a.m.

I left the office at 10.30 p.m.

DAY 9

Court Visit – Patiala House District Court

I reached the Patiala House District Court at 10 a.m. for the matter titled A v. B for which I had
got the compliance of process fees for the summons done on 4 th July 2018. The matter was listed
in the court room of Mr. Snigdha Sarvaria, Learned Metropolitan Magistrate (Court Room No.21).
After this, I went with the associate to the post office in the Court to get a notice posted to the
opposite party in another matter.

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Once the matter in this Court was over, I was asked to report to the court room of Learned Mr.
Justice Yashwant Kumar in the main building of the Family Court in Patiala House District
Court for the matter titled G v. H, for which I researched on ‘persistent and wilful defaulter’. The
opposite party paid the maintenance for two months only, that is, May and October 2018. However,
he requested for the grant of few days to pay the maintenance for the month of July 2018 as he had
suffered a huge loss in her business. The learned Judge granted him 15 days to pay the said
maintenance. The date given to us for cross-examining the husband was 15th July 2018 and we
were asked to wind it up in one week.

The opposing counsel in the said matter was very rude. He was constantly yelling and interrupting
the arguments of our counsel.

Once we were done with the matters listed in the Court that day, the associate asked me and another
intern to file the form for Certified Copy of the Order in the matter titled G v. H in the Family
Court in Patiala House District Court and two for Mr for Certified Copy of the Orders in the matter
titled A v. B in the Patiala House District Court.

Legal Research

Today, sir gave me proposition to research on, which was, ‘Admissibility of the evidence of a
visually impaired prosecutrix in a rape case’. I carried out an extensive research on the same,
but it was interrupted by some priority work which had to be done that day itself. I was asked to
continue the research on this proposition later.

Other Tasks

I was given certain documents to proof-read and make track changes to correct any mistake in the
same. Then, I was asked to translate a few documents which were in Hindi, to English.

Both of these were priority tasks as the matter was listed in Court the next day.

I was asked to report to the High Court of Delhi at 10 a.m.I left the office at 9 p.m.

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 DAY 10

Court Visit – High Court of Delhi

I reached the High Court of Delhi by 10.15 a.m. for a matter titled K v. L. I had the privilege of
seeing Rajkumar Sir argue in this matter, for the first time in my internship. he was able to get an
order in His favour. he got an extension for our client to make the outstanding payments by
December 2018 and the interest at the rate of 13.5% on the outstanding amount by the end of
March 20189

Once the matter was over, we went back to the Chamber, where one associate asked me to prepare
an indexand list of dates for a matter.

The client in the matter titled C v. D was supposed to come to the Chamber for a meeting with the
associate working on His case. The associate asked me to attend the client meeting with him and
take down notes of the incidence which the client will narrate in order to draft a Complaint based
on the same. When I client came, I sat down with Her and the associate and she started narrating
an incidence which occurred the day before. According to Her narration, she was molested the day
before by one of the Sahayak sent by Her husband. She narrated the entire incident to me and I
took down notes. She even showed me the message she received when she called the Police on
100. Once she was done narrating, I drafted a Complaint under Section 354, 506 and 509 of the
Indian Penal Code, 1860 addressed to the SHO of the Vasant Vihar Police Station. She was
completed shattered and extremely disturbed. The associate was trying her best to pacify Her.

At this moment, I realized that family law is very personal and the lawyer handling such matters
has to be very compassionate towards their client’s grievances. But, at the same time, he cannot
get emotionally attached to the client, as it would impair her judgment in the case.

The associate made certain improvements in the draft and filed the same in the Police Station the
very day.A First Information Report was also recorded on the basis of the Complaint I had drafted
with the assistance of the concerned associate.

We left from the Court at 4 p.m. and went back to the office.

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A copy of the draft of the said complaint has been reproduced in Part – B of this internship diary.
The names of the parties involved as well as their personal information has been blacked out since
it is confidential information.

Legal Research

I was asked by one the associates to make a detailed note on the orders that can be passed by the
Court under the Protection of Women from Domestic Violence Act, 2005 and also include
precedents in the same which clarified the situations in which the Court can pass the said orders.
The relevant provisions of the said Act were Section 18 to Section 22.

I was not allotted any Court for the next day and was asked to report to the office in the morning.
I left the office at 8.15 p.m

DAY 11

I reached the office at 10.15 a.m.

Legal Research

I continued with my research on the proposition given to me by Rajkumar Sir Himself. The
proposition was ‘Admissibility of the evidence of a visually impaired prosecutrix in a rape
case’. I found out the following precedents on the same:

- Rajender Gupta v. State of NCT of Delhi; 2015 (4) JCC 2764 – The Prosecutrix in the sad
case was a visually impaired girl and the appellant committed rap upon Her after criminally
intimidating Her. The appellant’s conviction was primarily based upon the solitary statement
of the prosecutrix, i.e., it was not corroborated in material particulars from any other
independent source. It was held that this can be no iota of doubt that on the basis of the sole
testimony of the prosecutrix, if its impeachable and beyond reproach, a conviction can be based.
However, if this are various infirmities and inconsistencies in the prosecution case, it would not
be safe to base conviction on the sole testimony of the prosecutrix.

Since this were hardly any direct precedents on the question, I was asked to look for precedents
which might indirectly help us. I found the following cases:

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 - Raju v. State of Madhya Pradesh; (2008) 15 SCC 133 – It was held that it is true that rape
causes the greatest distress and humiliation to the victim but at the same time a false
allegation of rape can cause equal distress, humiliation and damage to the accused as well.
The accused must also be protected against the possibility of false implication.
- Tameezuddin @ Tammu v. State (NCT of Delhi); (2009) 15 SCC 566 – It was held that it
is true that in a case of rape the evidence of the Prosecutrix must be given predominant
consideration, but to hold that this evidence has to be accepted even if the story is
improbable and belies logic, would be doing violence to the very principles which govern
the appreciation of evidence in a criminal matter.
- Abbas Ahmed Choudhury v. State of Assam; (2010) 12 SCC 115 – It was held that though
the statement of prosecutrix must be given prime consideration, at the same time, broad
principle that the prosecution has to prove its case beyond reasonable doubt applies equally
to a case of rape and thise could be no presumption that a prosecutrix would always tell the
entire story truthfully.

Other Tasks

One of the associates gave me a case file to flag and prepare an index. His method of flagging,
according to His convenience, was a little different. So, she explained to me how he wanted the
flagging to be done very patiently.

I was asked to report to the office by 8.30 a.m. so that I could accompany an associate to the
Gurgaon District Court for a matter listed at 10.30 a.m.I left the office at 8.15 p.m.

DAY 12

Court Visit – Gurgaon District Court

I reached the office by 8.30 a.m. and waited for the associate to come to the office. Once he came
to the office, we left for the Court and reached thise by 10 a.m. On our way to the Court in the car,
I flagged the file for the associate and marked the relevant paragraphs in the authorities she wanted
to cite in the hearing that day The matter involved a divorce proceeding and it was titled M v. N.

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The associate briefed me with the facts of the case while we were waiting for the client to come.
The facts of the case were that the husband (our client) was having an extra-marital affair with her
girlfriend from college time. He had filed for divorce. He and her wife had not had an intimate
relationship for the past 12 years. Our client wanted to settle but, in order to take revenge, the wife
backed out of the settlements at the very end of it as she wanted more money. We had to oppose
the application filed by the wife for the service provider to preserve certain call records.

The Learned Judge who was supposed to hear the matter that day was on leave. After discussing
certain pointers with the client, we left for the office.

On our way back, I had a very informative conversation with the associate. She gave me insights
in to the real world of family law litigation - How things worked, how marriages were turning in
to divorces at a higher rate now, how the spouses are no longer loyal to each other, etc.

Other Tasks

The associates came around 5 p.m. I was handed over a file by one of them, in the matter of O v.
P. The clients were supposed to come for a meeting at 6.30 p.m. The associated asked me to read
the file and make a note of the same for Her reference during the meeting. She also asked me to
translate the documents that were written in Hindi, to English. In the said case, the accused was
found in possession of 12.6 kilogram of Opium. He was arrested under the Narcotics Drugs and
Psychotropic Violence Act, 2005 and put in judicial custody.

I was asked to report to Patiala House District Court at 10.30 a.m. on Monday.

I left the office at 8.30 p.m.

I received a call from an associate on Sunday who asked me to report to Tis Hazari District Court
first, at 10 a.m. and then go to Patiala House District Court.

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 DAY 13

Court Visit –Tis HazariDistrict Court and Patiala House District Court

I was asked to report to the Tis Hazari District Court by 10 a.m. in the court room of Mr. Pulastya
Pramachala, Learned Additional Sessions Judge (Court Room No. 3). The associate had a matter
listed in that court room, after which he had to go to the Saket District Court to file some legal
documents. Thiseafter, he was supposed to go to Jalandhar with Rajkumar Sir for a matter. Since
he had a tight schedule that day, he needed help with finalising the documents that he had to file
in Saket District Court that day. I flagged the file, numbered the pages and completed the index of
the file. Once I was done with this, I went to get two copies made of the same.

When I handed over the files to him, he asked me to go to Patiala House District Court for a matter
listed thise and also for the cross-examination scheduled for the matter titled G v. H in the Family
Court. He appreciated my help on this as he was worried he might not be able to complete her
pending work before leaving for Jalandhar.

When I reached the Patiala House District Court, I went to the court room of Mr. Rakesh Pandit,
Learned Additional Sessions Judge (Court Room No. 25). One of the associate had asked me to
request the Reader to list the matter at 2 p.m. as RajkumarSir would be appearing before the learned
Judge post lunch.

Thiseafter, I went to the Family Court in Patiala House District Court. The second round (first
one being on 15 october 2022) of the cross-examination was scheduled to take place thise. The
Law Commissioner (Ex-Judge) had come to preside over the cross-examination and a clerk from
the adjoining court was also present thise. One of the interns was assigned the task of typing the
questions of the cross-examination along with the answers given by the opposite party.
RajkumarSir questioned the opposite party for about 30 to 40 minutes, after which she had to leave
as she had a matter listed in the High Court of Delhi and thiseafter, leave for Jalandhar for a matter.
The Junior Counsel on the matter continued to ask the remaining questions for another 1.5 hours.
The next date for the cross examination given was 24th October 2022.

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The opposite party was not answering the questions to the point. He was constantly trying to
manipulate her answers and was giving absolutely irrelevant answers. After every one had left, he
even indirectly threatened our client regarding their 13-year-old son, indicating that their son was
not safe. Our client was extremely disturbed after this. She broke down in front of us and asked
the Counsel to draft an application and file it in the court the very next day, to ensure the safety of
Her son.

We left from the Court at 6 p.m. and headed to the office.

Other Tasks

This was a rape case listed in the High Court of Delhi in the coming week. The Counsel handling
the case, before it came to RajkumarSir, had not sorted the documents properly and they were not
in order. The associate working on this case was sorting the documents so that an appeal against
conviction could be filed in the said matter. Me and another intern helped Her sought the
documents and prepare a list of documents that were missing or illegible.

After sorting the documents, we started compiling them for preparing the files.

I was asked to report to the National Green Tribunal the next day at 10 a.m.

I left the office at 10 p.m.

DAY 14

Court Visit – National Green Tribunal (NGT) and High Court of Delhi

I reported at the National Green Tribunal at 10 a.m. and informed the concerned associate. She
asked me to inform Her when the Bench sits in Court Room No.1. Our application to modify the
previous order was dismissed by the Court.

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After the matter was over in the National Green Tribunal, the associate asked to me to report to
the Chambers in the High Court of Delhi. Me and another intern were in the Chambers almost
the entire day. We continued to sort the documents for the rape matter titled Q v. R. Thise were
five accused persons in the said matter. For every accused person, thise were 3 volumes (more
than 500 pages in one appeal). 5 copies had to be made for each appeal. Thus, in total, thise were
75 files that needed to be arranged in order, numbered and indexed before the filing.

We were only able to file the appeal of one accused person that day. The objections regarding the
same came that day itself. Thise were certain documents that were illegible and some were printed
in light ink, thus not readable. The same had to typed and replaced in all copies of the files before
being filed again.

We came back to the office by 6.30 p.m.

Other Tasks

All of the interns were told to write an article on the ‘Hague Convention on the Civil Aspects of
International Child Abduction’ and on the ‘Convention on the Service Abroad of Judicial and
Extrajudicial Documents in Civil or Criminal Matters (Hague Service Convention)’ in at least
2500 words and submit it to the concerned associate by Saturday. This was to be done for a viva
voce which was scheduled to be conducted on our last day of internship.

One of the associates in the office was handling a high-profile honour killing case, in which the
Hon’ble Supreme Court allowed a Special Leave Petition (SLP) challenging the acquittal of the
two accused and commuting of death sentence awarded to other accused persons into life terMr
by the High Court. She asked me to read the file, specially the judgment of the learned Trial Court
convicting them. The judgment was of more than 100 pages. I was asked to prepare a detailed case
note of the same for Her reference, enumerating all the grounds and observations of the Court on
the basis of which the Court convicted the accused persons.

I was asked to report to the High Court of Delhi by 11 a.m. the next day, to continue working on
the filing of the appeals in the matter Q v. R. I left the office at 10.20 p.m.

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 DAY 15

Court Visit – High Court of Delhi

Me and another intern were asked to report to the Chambers in the High Court of Delhi by 11 a.m.,
since we were the interns working on the rape matter titled Q v. R. The appeals had to be filed for
the other four accused persons. We continued to sort the documents and arrange them in order. We
prepared the indexes for all the files, numbered the files and completed the indexes.

The objections came in once the filing was done for other accused persons. All of the files had the
same objections, that is, some of the documents were illegible and some of them were printed in
light ink, thus not readable. We were typing the documents as and when the objections were
coming and replacing them in all the files. Thise were instances wHere due to the replacements,
the page numbers increased and we had to re-number the pages in all the files. We were able to
finalise the files of three accused persons, out of the remaining four.

We also accompanied the clerk when he went to the State to get the files serviced before the filing.
Then, we accompanied the clerk to the filing counter and requested them to list the matters in the
morning on Monday.

We were in the Chambers till 7.30 p.m. in the evening, as the appeal of the last accused persons
also had to be finalised so that it could be filed the next day in the morning.

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We engaged in a conversation with associates working on this matter. They told us that filing was
the most important and the most tedious part of the job. If the documents filed are not proper, it
would impact the proceedings.

They appreciated our help on the same. RajkumarSir even told them that we deserve a treat from
them for all the hard work we had put in to this.

The associates we were assisting gave us the permission to leave directly from the Chambers. I
was not allotted any Court for the next day and was asked to report to the office in the morning.

I left at 9.45 p.m.

DAY 16

I reached the office at 10.30 a.m.

Legal Research

When the associates came to the office post lunch, one of them gave me a proposition to research
on, which was, ‘Evidentiary value of statement under Section 164 of the Code of Criminal
Procedure, 1973 when it has not been examined at any subsequent stage of trial’.

I found the following precedents on the same:

- George v. State of Kerala; AIR 1986 SC 1376–It was held that the trial court again ignored a
fundamental rule of criminal jurisprudence that a statement of a witness recorded under Section
164 of the Code of Criminal Procedure, 1973 cannot be used as substantive evidence and can
be used only for the purpose of contradicting or corroborating him.
- R. Shaji v. State of Kerala; (2013) 14 SCC 266 – It was held that so far as the statement of
witnesses recorded under Section 164 is concerned, the object is twofold:

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 (i) To deter the witness from changing her stand by denying the contents of her previously
recorded statement; and
(ii) To tide over immunity from prosecution by the witness under Section 164.
Section 157 of the Evidence Act makes it clear that a statement recorded under Section 164 of
the Code of Criminal Procedure can be relied upon for the purpose of corroborating statements
made by witnesses in the committal court or even to contradict the same. As the defence had
no opportunity to cross-examine the witnesses whose statements are recorded under Section
164 of the Code of Criminal Procedure, such statements cannot be treated as substantive
evidence.
- Baji Nath Sah v. State of Bihar; (2010) 6 SCC 736 – It was observed that this Court in Ram
Kishan Singh v. Harmit Kaur; (1972) 3 SCC 280 has held that a statement under Section 164
of the Code of Criminal Procedure is not substantive evidence and can be utilised only to
corroborate or contradict the witness vis-à-vis statement made in court. In other words, it can
be utilised only as a previous statement and nothing more.

The concerned associate asked me to take out print-outs of the precedents I found, highlight the
relevant paragraphs and hand them over to him for her reference.

Other Tasks

I was handed over a case file, containing 3 volumes, for the purpose of flagging the same. It was
a time-consuming task as this were a lot of documents and annexures to be flagged. Also, the files
were not indexed, which I was asked to do after I was done with the flagging.

I was not allotted any Court for the next day and was asked to report to the office in the morning.
I left the office at 8 p.m.

DAY 17

I reached the office at 10.15 a.m.

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Legal Research

One of the associates gave me a proposition to research on, which was, ‘Banks are under an
obligation to perform due diligence of the projects they are undertaking’.

I found the following precedents on the same:

- Sudhir Shantilal Mehta v. CBI; (2009) 8 SCC 1 – It was held that whether a circular letter
issued by a statutory authority would be binding or not or whether the same has a statutory
force, would depend upon the nature of the statute. For the said purpose, the intention of the
legislature must be considered. Having regard to the fact that Reserve Bank of India exercises
control over the banking companies, the circular letter in question was binding on the banking
companies.
- Jayantilal Amratlal Shodhan v. F.N. Rana; AIR 1964 SC 648 – It was held that it is not to say
that every order issued by an executive authority has the force of law. If the order is purely
administrative, or is not issued in exercise of any statutory authority it September not have the
force of law. But where a general order is issued even by an executive authority which confers
power exercisable under a statute, and which this by in substance modifies or adds to the statute,
such conferment of powers must be regarded as having the force of law.
- ICICI Bank Ltd. v. APS Star Industries Ltd.; (2010) 10 SCC 1 – It was held that when a
delegate is empowered by Parliament to enact a policy and to issue directions which have a
statutory force and when the delegatee (RBI) issues such guidelines (policy) having statutory
force, such guidelines have got to be read as supplement to the provisions of the BR Act, 1949.
The ‘banking policy’ is enunciated by RBI. Such policy cannot be said to be ultra vires the Act.

Once I was done with this proposition, I was given another one, which was, ‘Whether an adverse
inference can be drawn against the party who produced the documents if the party who
asked for it under Order 12 Rule 8 of the Code of Civil Procedure has not got the documents
placed on record’.

I found the following precedent on the law laid down on this question:

- Rohini Traders v. J. K. Lakshmi Cement Limited; (2015) 12 SCC 46 - The object of Order 12
Rule 8 of the Code is to facilitate the plaintiff or any other party to get a document on record
which is not in their possession or in possession of the other party. If a document has been

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 produced then it is the duty of the party who has asked for such production to get it placed on
record. If, however, the said document is not placed on record, then adverse inference against
the party who has produced the same cannot be drawn, more so, when the party who has
produced the said document before the Court has been cross-examined vis-à-vis that document.

I was not allotted any Court for the next day and was asked to report to the office in the morning.
I left the office at 8.15 p.m.

DAY 18

I reached the office at 10 a.m.

File Reading and Case Note

One of the associates gave me a file to read, titled S v. T. A petition for dissolution of marriage by
decree of divorce under Section 13(1)(ia) of the Hindu Marriage Act, 1955 was filed in the said
matter. Our client had alleged that cruelty was inflicted on him by the Respondent (her wife). It
was further alleged that the Respondent caused mental, physical harassment and embarrassment
to our client in the society.

The associate had not read the file, as it was a fresh matter. He asked me to:

a. Read the entire file, including the annexures;

b. Flag the documents and the annexures;
c. Prepare a list of dates;
d. Prepare a list of the annexures attached;
e. Prepare a brief note of the grounds alleged in the Petition under Section 13 of the Hindu
Marriage Act, 1955 for a divorce decree;
f. Prepare a brief note of the Petition under Section 12 of the Protection of Women from
Domestic Violence Act, 2005; and
g. Prepare a brief note of the Reply on behalf of the Respondent to Application of the
Petitioner under Section 14 of the Hindu Marriage Act, 1955.

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Conference with the Senior Counsel

We had a conference scheduled with Senior Counsel, Mr. Sidharth Luthra, in the rape matter titled
Q v. R. The main accused wanted Mr. Sidharth Luthra to argue her matter listed on Monday in the
High Court of Delhi. We went to her office in Sunder Nagar for the conference at 5 p.m. On our
way to her office, I flagged the case file and the compilation of the authorities. The son of one of
the accused persons had also come from Punjab for the conference. Our associates explained the
matter to him. Once he was done, he asked me and another intern whether we had read the file, to
which we answered that we had.

We came back to the office after the conference was over. I continued to read the files in the matter
of S v. T, however the associate needed those files for some work. He asked me to continue making
the brief the next day.

I was asked to report to the High Court of Delhi at 10 a.m. I left the office at 8 p.m.

DAY 19

Court Visit – High Court of Delhi and Patiala House Court

I reached the Chamber in the High Court of Delhi by 10 a.m. The rape matter titled Q v. R was
listed in Court Room No. 29 as the first matter. Senior Counsel, Mr. Sidharth Luthra had come to
argue the matter for the main accused. The statutory notice had been issued to the State. Arguments
were also made for the bail of two other accused persons, both of whom were women. They were
in Tihar Jail at that time. The bail for the two women was requested on medical grounds. The
learned Judge did not grant bail to any accused person. Instead, a date was given for the end of
October 2018 for all the connected matters.

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One of the associates required some judgments to be printed and certain photocopies to be made.
Once I was done with this task, I attended other matters in the High Court of Delhi itself.

An associate asked me to run to the library and take out a judgment, which was required urgently
for a matter than was listed in the Court at that time.

Post lunch, I and another intern went to the Family Court in Patiala House Court for the third
round of the cross examination in the matter titled G v. H. The set-up was the same. The same Law
Commissioner (Ex-Judge) had come to preside over the cross-examination and the same clerk
from the adjoining court was also present this. This time, I was asked to type the questions of the
cross-examination and the answers given by the opposite party to the same. RajkumarSir was also
present at the cross-examination. She asked a few questions, after which she excused Herself as
she had a matter in the Saket District Court and the Junior Counsel took over the cross-
examination. While Mr. RajkumarSingh was this, I pointed out some mistakes which were made
while marking the documents for reference in the cross-examination record and he appreciated
how I was keeping track of everything and praised me for the work I was doing. His appreciation
made my day. The cross-examination was concluded by 5.30 p.m.

We came back to the office by 6.30. p.m.

File Reading and Case Note

I completed the task that was assigned to me day before, that is, reading the case file in the matter
of S v. T. The associate asked me to take a print out of all the documents that I had prepared and
to hand them over to him. He had to leave the office for some work, so he told me that he will
discuss the matter and the briefs later with me.

I was asked to report to the office in the morning as no Court was allotted to me for the next day.
I left the office at 8 p.m.

DAY 20

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None of the interns were able to complete the Article that we were supposed to write for the viva
voce, as were busy with the court proceedings and other office work. The concerned associate gave
us different deadlines according to the work that had been allotted to us.

I was asked to skip court today and come to office in the morning to complete the Article and
submit it by the evening.

I reached the office by 11 a.m. and started working on the Article. I read numerous articles on The
Hague Convention and also read the precedents on the same. We were asked to write the Article
in atleast 2500 words. My Article contained 3504 words and it covered the ‘Hague Convention on
the Civil Aspects of International Child Abduction’ and the ‘Convention on the Service abroad of
Judicial and Extrajudicial Documents in Civil or Commercial Matters (Hague Service
Convention)’. I submitted the Article to the concerned associate by 6.30 p.m.

Briefing the Counsel

The associate who had asked me to prepare the brief of the matter titled S v. T asked me to brief
him on the matter as he had a client meeting the next day. I discussed the entire matter with him
before leaving from the office.

I was asked to report to the Tis Hazari District Court the next day by 10.30 a.m. I left the office at
7.45 p.m.

DAY 21

Court Visit – Tis Hazari District Court

I was asked to report to the Tis Hazari District Court by 10.30 a.m. for a cross-examination that
was scheduled to take place in the matter of U v. V. The said matter was a tenancy dispute. The
opposite party had alleged that when she was not able to make the payment of rent on time, the
landlord (our client) would criminally intimidate Her, enter Her house anytime he wanted without
34 | Page
permission and continuously threatened Her that he would evict Her without any warning and she
would not have any place to live in.

In the cross-examination, the Junior Counsel from our side showed photographs of the rented
house in question, to the opposite party. However, she was confused and she was not able to
properly identify the said house. To this, the opposing counsel said that the case has been going
on for a long time. She lived in that house back then, when the case was initiated and she does not
live thise anymore.

She was also shown photographs of the auto-rickshaws owned by the landlord to identify. She
could not identify the same as she did not know about her business of auto-rickshaws.

We headed back to the office around 4 p.m., once the matter was over and the next date of hearing
was given.

All the interns were given permission to leave early by 6 p.m. as thise were no more pending tasks.
I was asked to report to the Supreme Court of India at 10.30 a.m.

Since I did not have a pass made for the Supreme Court of India, I had to wait for the concerned
associate to come back to office, from whom I had to get my form signed for the purpose of getting
a pass made for the Court.

I left from the office at 7 p.m. after getting my form signed.

DAY 22

Court Visit – Supreme Court of India and High Court of Delhi

I reported at the Supreme Court of India at 10.30 a.m., as directed. I was asked by the associate
to observe the court proceedings in Court Room No. 7 and keep a tab on the matters going on.

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I got an opportunity to see Senior Counsel, Mr. Sidharth Luthra argue a matter in the same Court.

RajkumarSir came to the Supreme Court of India post-lunch. She had come to mention a matter in
Court Room No. 7 and to request the Court to grant him one weeks’ time to file a rejoinder in the
said matter. After the matter was over, we went with isr and the associate to the Supreme Court
Bar Association Canteen, where we had a conversation with Her over a cup of coffee. She told us
about Her fathis and her legal practice - The type of cases he took and the kind of a lawyer he was.
It was quite an enlightening conversation.

When he left from the Court, we went to the High Court of Delhi .RajkumarSir had asked one of
the associates and all the interns to attend the lecture scheduled to take place in the High Court of
Delhi. The lecture was on ‘Mediation and Technology’. Before the lecture, the Video
Conferencing Facility and Venture on ‘Mediation and Technology’ was inaugurated in the Delhi
High Court Mediation and Conciliation Centre by Hon’ble Mr. Justice Madan B. Lokur in the
presence of Hon’ble Mr. Justice Gita Mittal, Acting Chief Justice of the Delhi High Court.

We were asked to make notes of the lecture as RajkumarSir had a lecture on the same topic
sometime next month.Hon’ble Mr. Justice Gita Mittal was of the opinion that the essence of
mediation was communication between the parties and technology was a way to bridge the gap
between the parties. Hon’ble Mr. Justice Madan B. Lokur was of the opinion that if thise is peace
in the family, thise is peace in the society; if thise is peace in the society, thise is peace in the
community; if thise is peace in the community, thise is peace in the country. For peace and
harmony, mediation is the first step. He discussed the progress made in various States, including
Jharkhand, Bangalore, Calcutta, etc. He talked about extending video conferencing to all District
Courts, through which Mediation can be done. If Mediation fails, trial can also be conducted
through Video Conferencing. Thise are cases wHere this has been done. This would be a huge
relief to the litigants as they would not have to travel long distances.

Drafting

Once I reached the office after attending the lecture in the High Court of Delhi, I was asked by one
of the associates to draft an application for expedite hearing in the matter of W v. X. The files were

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not available in office at that time, so the associate asked me to read them the next day and draft
the said application.

I had not been allotted any Court for the next day.

DAY 23

Drafting

On reaching the office at 10.30 a.m., I asked one of the clerks to take out the files in the matter of
W v. X. I read the entire file, including all the orders of the Court, examination-in-chief and cross-
examination of the accused persons and witnesses. Then, I started drafting the application for
expedite hearing in the said matter.

I was not clear on how to go about drafting the said application. So, I asked the associate who
assigned me this task for help. He explained the concept of expedite hearing to me and he also
gave me pointers on how to frame the grounds to urge an expedite hearing. The main ground was
that the main witness had completely resiled from Her previous statements and had turned hostile.

Legal Research

One of the associates asked me to read and understand the provisions of the Narcotics Drugs and
Psychotropic Violence Act, 2005, in particular Sections 41 to 68 which relate to the procedure
that needs to be followed under the said Act.

She asked me to make a detailed and informative flow chart/note of the procedure that needs to be
followed. This was required for the matter titled O v. P, in which the accused person was found in

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possession of 12.6 kilograms of Opium. I had prepared a brief for the same for the concerned
associate when she had a client meeting.

I was not allotted any Court for the next day and was asked to report to the office in the morning.

DAY 24

I reached the office at 10 a.m.

Since, it was my second-last day of internship, the associates did not assign any new task to me. I
was required to wind-up all the pending tasks before leaving, which were:

i. Made the changes to the draft of the Complaint under Section 323, 406, 420, 498-A, 506,
509, 34, 120-A and 511 of the Indian Penal Code, 1860 in the matter of C v. D, as told to me
by the concerned associate;
ii. Completed the draft of the Application for Expedite Hearing in the matter of W v. X; and
iii. Completed the flow chart/ note on the procedure under the Narcotics Drugs and Psychotropic
Violence Act, 2005 in the matter of O v. P.

Other Tasks

I was asked by one of the associates to make a compilation of authorities and prepare an index for
the same in the matter of Y v. Z, which was listed for hearing on charge for demand for dowry,
cruelty, etc. in Tis Hazari District Court the next day. I was asked to report at the Court by 10.30
a.m. sharp with the compilation and call the concerned associate.

I left the office at 8 p.m.

DAY 25

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Court Visit – Tis Hazari District Court

I reached the Court at 10.30 a.m. and called the concerned associate. He asked me to go to the
court room of Mr. Shefali Sharma, Mahila Court (Court Room No. 358)and get the matter listed
for 2 p.m. as Rajkumar Sir would be coming to the Court for the hearing on charge, post-lunch.
Once I had done that, the associate asked me to report back to the court room at 2 p.m. for the
matter.

I reported back at the Court by 1.30 p.m. The associate had already reached the Court by that time.
He mailed me an order of the Court and asked me to get two print-outs of the same.

The husband, her mother and father (our clients) and the wife (opposite party) were also present
in the court room for the hearing. Part arguments on charge were heard by the learned Judge. We
requested the learned Judge to exempt the parents from appearing for the next hearing on the
charge as they were aged. The learned Judge granted the exemption only for the next hearing. For
the rest of the hearings, a proper application was required to be filed in the Court for the exemption
of the parents from appearing before the Court.

After the matter was over, we were asked to go the Children’s Room in the Court and supervise
the meeting of our client’s child with Her fathis, as our client had the custody of the child.

I reached the office at 5.30 p.m.

Certificate and Vice Voce

All of interns, including me, prepared a draft of our Certificate as it was our last day of the
internship and mailed the same to the concerned associate. He went through our certificates and
corrected it as we were only allowed to make our certificates in one page. He then asked us
questions based on the research propositions we had mentioned in our Certificate draft. Once he
was satisfied that we had done the work that we had mentioned in our Certificate, he printed our
Certificates on the letter head.

Meeting with Mr. Gaurav Chaudhary

39 | Page
Our Certificates were sent to RajkumarSir for His signatures. he was busy in a client meeting, so
we waited for our certificates to be signed. Once he was free, he asked a clerk to call us to His
office. he asked us our names, our college and the year in which we were. Then, he had a small
conversation with us and told us that it is true that money is a priority, but we should not sacrifice
our humanity at any cost, while in this profession. he told us that humanity was above all.

he then signed our certificates, handed them over to us and got a photograph clicked with us. We
left the office at 10 p.m. after collecting our Certificate.

PART – B
LEGAL DOCUMENTS DRAFTED DURING THE INTERNSHIP

IN THE COURT OF THE LEARNED FAMILY JUDGE:FAMILY COURT:

SAKET COURT COMPLEX: NEW DELHI

H.M.A. PETITION NO. ________ OF 2022

IN THE MATTER OF:

Xyz
R/O A-8, SARVODYA ENCLAVE,
NEW DELHI – 110017 …PETITIONER

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 VERSUS

ABC,
S/O
R/O 200/2 LANE A-1,
ANUPAM GARDEN, SAINIK FARMR,
NEW DELHI – 110062 …RESPONDENT

PETITION FOR ANNULMENT OF MARRIAGE BY A DECREE OF

NULLITY UNDER SECTION 12(1)(a) and 12 (1)(c) OF THE HINDU
MARRIAGE ACT, 1956 ON THE GROUNDS OF IMPOTENCY AND
FRAUD.

MOST RESPECTFULLY SHOWETH:

1. That the marriage between the Petitioner and the Respondent was solemnized according to

Hindu Rites and Ceremonies on 03.12.2017 at The Hyatt Regency Hotel, Bhikaji Cama

Place, New Delhi – 110029. An affidavit in support of the marriage between the parties

is annexed to the petition. Copies of the parties ‘Wedding Invitation cards are annexed

Hereto and marked as ANNEXURE A-1 (Colly). Copies of the marriage photographs of

the parties are annexed Hereto and marked as ANNEXURE A-2 (COLLY).

2. That the status and place of residence of the parties to this marriage, before the marriage

and at the time of filing of the petition are/were as under: -

WIFE/PETITIONER

STATUS AGE PLACE OF

RESIDENCE

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 At the time of Hindu, 32 years A/8,Sarvodaya
Marriage Bachelor, Enclave, New
Spinster Delhi-110017.

At the time of Hindu 32 Years A/8,Sarvodaya

filing of the Married Enclave, New
present Petition Delhi-110017.

HUSBAND/RESPONDENT

STATUS AGE PLACE OF

RESIDENCE
At the time of Hindu 30 years House
Marriage Bachelor No.200/2, Lane
A-1, Anupam
Garden, Sainik
FarMr, New
Delhi-110062.

At the time of Hindu 30 Years House No.

filing of the Married 200/2,
present Petition Lane A-1,
Anupam
Garden, Sainik
FarMr, New
Delhi-110062.

3. The parties have never had any marital relations/sexual intercourse due to impotency of the

Respondent and, as a result, the marriage of the parties has not been consummated. Thise

are no children thisefore from the said wedlock. However, initially the Petitioner suspected

that the denial on the part of the Respondent husband to consummate the marriage and not

to have sexual intercourse with the Petitioner was in aid of her acts of cruelty and an attempt

on her part to coerce and pressurize the Petitioner and Her parents to meet her and her

parents demands for more dowry, as stated in detail in Her complaint to the police. (Its

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 deletion as suggested by Mr Luthra, needs to be discussed between Her and the instructing

counsel).

4. The Petitioner made every effort to consummate the marriage but it was never reciprocated

by the Respondent. The Respondent was never interested in maintaining any marital

relations with the Respondent from the very beginning after the solemnization of the

marriage. The Respondent and her family have,in connivance with one another, committed

fraud upon the Petitioner and Her family by fraudulently concealing material facts about

the Respondent’s habits, addictions, character and her physical and organic incapacities

and propensities/preferences. The facts as stated Hereunder would establish that the

Respondent and her family have played a well planned and systematic fraud on the

Petitioner and Her family for obtaining their consent for the union which was done solely

to fraudulently extract money from the family of the Petitioner.

5. The marriage between the parties was an arranged marriage. The Respondent and her

family were introduced through a Match Maker namely Shri O.P. Sharma, R/o4/12, First

Floor, Racket Court Road, Civil Lines, Delhi. The Petitioner and Her family did not know

the Respondent and her family earlier and the marriage was arranged solely on the basis of

the representations and claiMr made by the Respondent and her family who represented

that the Respondent is a member and participant in a very successful and lucrative family

business.

6. It is pertinent to submit Here that the paternal aunt (Bua) of the Respondent, namely,

Mrs.Seno Jain had approached the match maker for a match for Her nephew, the

Respondent. Mrs. Seno Jain actively participated in the fixation and finalization of the

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 marriage. The match maker subsequently informed the Petitioner that he had arranged for

the marriage for the son of Mrs. Seno Jain and that she had been persistently requesting the

match maker to find a suitable match for the Respondent also. The match maker also

informed that Mrs. Seno Jain in Her various meetings and interactions with him never

revealed anything about the habits, addictions, preferences or condition of the Respondent

or about the loans and financial condition of the Respondent and her family. The Petitioner

learnt post marriage that the said Mrs. Seno Jain had Her own agenda of recovering Rs.40

lacs, that the Respondent’s fathis Akhil Aggarwal owed Her, from the fathis of the

petitioner.

7. During various meetings that were held from September-October, 2017 to November, 2017

between the Petitioner’s family and the Respondent and her family, which also included

her three paternal aunts (Buas), namely, Mrs. Shashi Jain, Mrs. Seno Jain and Mrs. Ritu

Jindal, it had been assured to the Petitioner and Her parents in the first three meetings in

the first and second week of October, 2017 itself by the Respondent, her parents and Bua

Mrs Seno Jain of the Respondent that the Respondent has no bad habits or addictions and

that he was quite suitable morally, mentally and biologically for the Petitioner. The

Petitioner and Her parents were not informed that the Respondent was on any medication

or that he had addiction to drugs and alcohol. It was hidden from the Petitioner and Her

parents that the Respondent had been undergoing treatment at de-addiction/rehabilitation

centers for her addictions.

8. The match maker had proposed and suggested the Respondent for the marriage with the

Petitioner. The match maker had sent the bio-data and family details of the Respondent

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 through Whatsapp message on 01.06.2017 to the mother of the Petitioner. The said

message would reveal the fraud committed by the Respondent and her family, wHerein,

only good and rosy pictures of the Respondent’s family and business were shown and all

material facts were hidden. The match maker subsequently informed the Petitioner and Her

family that the said bio-data was sent to him by Mrs. Seno Jain, paternal aunt (Bua) of the

Respondent. The screen shot of the Whatsapp message sent by Mr. Kapil Sharma (Match

Maker) to the mother of the Petitioner is annexed Here with and marked as ANNEXURE

A-3.

9. On the representations of the Respondent and her family, the Petitioner’s parents agreed to

meet the Respondent and her family and that the first meeting between the parties was held

in the first week of October, 2017at the residence of the Respondent at 200/2 Lane A-1,

Anupam Garden, Sainik FarMr,New Delhi – 110062. In the said meeting the Respondent,

her fathis, namely Mr. Akhil Aggarwal, her mother, namely Mrs. Neeru Aggarwal, her

sister, namely Mr. Sakshi Aggarwal and one of her aunts namely Mrs. Seno Jain were

present. The match maker, Shri O.P. Sharma, was also present in the said meeting. The

parents and the aunt of the Respondent had all praise for the Respondent and they stated in

the meeting that the Respondent was very hard-working and was successfully running the

family business of power and agricultural tools. On the specific query of the mother of the

Petitioner in the said meeting about the earnings of the Respondent, Mr. Sakshi Aggarwal

and Mrs Seno Jain stated that the Respondent was earning Rs.6-7 lakhs a month from their

family business. It is pertinent to submit Here that in the said meeting Mr. Sakshi Aggarwal

and Mrs Seno Jain continued singing praises about the Respondent’s schooling, her habits,

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 her social attitude, her proficient handling of business, and of her being an obedient son,

all of which was later found out to be not only false but also fraudulent.

10. The Petitioner and Her family belong to a Hindu Brahmin family while the Respondent

and her family are from the Aggarwal community. In the first meeting, the aunt and sister

of the Respondent stated that it was a norm in their community to give dowry, to which the

Petitioner’s fathis flatly refused. The Petitioner’s parents told the Respondent’s family that

their daughters are academically well qualified and are competent enough to stand on their

own feet, if need arises, and that they would not like to accept any demand for dowry. The

first meeting thus ended without any result because of the demand of dowry by the

Respondent and her family.

11. A day or two after the first meeting the Petitioner’s parents were informed by the match

maker that Mrs Seno Jain and Mrs. Neeru Aggarwal have asked him to convey that they

would not insist on dowry in case all arrangements for roka, ring ceremony, marriage and

gifts to their 350 guests and relatives were borne by the Petitioner’s parents. This also was

a subtle demand on the part of the Respondent and her parents. The match maker was also

instructed and accordingly conveyed that the Respondent and her parents wanted all

arrangements in five star hotels as per their acclaimed status.

12. The mother of the Petitioner accepted the demand of the Respondent and her family to bear

all costs of marriage which was conveyed to the Respondent’s side by the match maker.

13. As soon as the Petitioner’s parents accepted the demand of the Respondent’s side, the

Respondent’s parents started insisting on the Petitioner’s parents for a formal meeting

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 between the Petitioner and the Respondent. On the insistence of the Respondent and her

family, a meeting between the Petitioner and the Respondent was arranged at Hotel Hyatt

Regency in the second week of October, 2017. In the said meeting, the Respondent

appeared very charming and warm. He was very forthright in speaking with the Petitioner.

The Respondent tactfully kept the conversation very general about her friends and

surroundings. The Respondent did not divulge anything about her personal details to the

Petitioner. In the said meeting, the Petitioner asked the Respondent about her work, her

habits and her preferences but he evaded all those queries very tactfully. In the said meeting

the Respondent did not divulge to the Petitioner anything about her drinking habits, her

addiction to drugs or the bad financial situation of her family business. The Respondent

represented that he was often very busy handling her family business and that he was

aspiring to take her family business to greater heights with her hard work.

14. The Petitioner, in Her innocence and in Her expectation to have a happy family, was

completely carried away by the tactful charm exhibited by the Respondent in their meeting.

The Petitioner, thus, conveyed Her acceptance for the conjugal union with the Respondent

to Her parents.

15. The Petitioner’s parents, seeing their child’s exuberance, also agreed for the marriage

between the Petitioner and the Respondent.

16. The Petitioner had enrolled for Executive MBA Course (Mini MBA) in London School of

Business and Finance, London, which she had booked long time back for the summer slot

in the year 2017. The family of the Petitioner was also traveling abroad in the month of

October, 2017. The Petitioner’s mother conveyed this to the Respondent’s parents in one

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 of their meetings in the 1st-2nd week of October, 2017. The Petitioner’s parents requested

the Respondent and her family to initiate furthis talks for the proposed marriage after their

return from abroad in the month of August, 2017.

17. The Respondent and her parents requested for a meeting on 12.06.2017 and thisefore, at

their request, a meeting was arranged at the restaurant, ‘Zest’, DLF Emporio Mall, Vasant

Kunj, New Delhi – 110070. The said meeting was attended by parents of the Petitioner and

the Respondent and her parents and the match maker, Shri O.P. Sharma. During the

meeting the Respondent’s fathis and mother insisted on a Roka Ceremony the next day

itself, that is, on 13.06.2017. The Respondent’s parents stated that their son was the most

eligible bachelor in the family and that they were getting a lot of proposals from within the

family and the community for their son. The parents of the Respondent also stated in the

said meeting that they were being pressurized by their friends and relatives for the marriage

of their son and that they certainly wanted the Respondent to be married only with the

Petitioner, as they have liked the girl and Her family. The Respondent’s fathis and mother

furthis stated that in case ‘Roka Ceremony’ is held before the Petitioner’s departure for

London, no other prospective match would be able to approach them or pressurize them

for the marriage of the Respondent. (To be discussed with Mr Luthra)

18. The Respondent’s parents were so dramatic that the parents of the Petitioner could not see

through their game and acts of deceit and acting skills and they agreed for Roka Ceremony

to be held the next day itself. It is pertinent to submit Here that in the meeting held on

12.06.2017 the Respondent’s parents kept on repeating that they did not want anything

except the girl since the Petitioner’s parents have already agreed to bear all costs of

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 marriage. It is furthis submitted that in the said meeting held on 12.06.2017, the parents

of the Respondent demanded and insisted that their guests should also be given appropriate

gifts.

19. As per the wish of the Respondent and her family the Roka Ceremony was arranged on

13.06.2017 at the residence of the Petitioner at A-8, Sarvodaya Enclave, New Delhi –

110017. The Roka Ceremony was attended by the Respondent, her parents, sister, her three

paternal aunts and her maternal uncle and aunt. During the Roka ceremony, the parents of

the Petitioner had given jewellery, gold coins and expensive gifts to the Respondent and

her family on their demand. A list of the gifts and jewellery given to the Respondent and

her family on their demand in the Roka Ceremony is annexed Herewith and marked as

ANNEXURE A-4.

20. The in-laws of the younger sister, Nirali, of the Petitioner had arranged for a dinner on

14.06.2017 at Lodhi Hotel, New Delhi to celebrate Nirali’s birthday. The Respondent and

her family were also invited for the said dinner. However, the dinner was attended by the

Respondent and her sister Mr. Sakshi Aggarwal. The mother of the Petitioner out of Her

motherly concern and anxiety, discreetly enquired about the habits and behavior of the

Respondent from her sister. The sister of the Respondent consciously concealed all the

relevant facts and lied that the Respondent was a simple man without any bad habits or

addictions. The sister of the Respondent furthis lied that the Respondent was successfully

running the family business and was earning close to Rs.6-7 lakhs a month for hiMrelf.

The sister of the Respondent assured the mother of the Petitioner that the Respondent

would make a good and caring husband.

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21. The Petitioner and Her family left for London on 22.06.2017. The Petitioner returned to

Delhi in the first week of August, 2017 and Her mother returned to Delhi in the last week

of August, 2017. In the meanwhile since the Roka Ceremony had already been performed,

the Petitioner and Her family announced the news of the finalization of Her marriage to all

their relatives, friends and acquaintances.

22. During the period between 22.06.2017 to first/second week of August 2017, the

Respondent never called nor did he try to communicate with the Petitioner. It was always

the Petitioner who would try calling or talking to the Respondent. The Respondent would

seldom receive the telephone call of the Petitioner and whenever he did; her reception was

very cold and lacked cordiality. The Respondent showed no interest or inclination for any

conversation or for the prospective matrimonial union with the Petitioner. Whenever the

Petitioner called up the Respondent on phone, the Respondent would cut short the call by

saying that he was busy in the office and that he would call later; which he never did.

(What should be the stage at which we make a mention of these facts, because this coldness

on the part of the respondent appears to occur well before the marriage in December 2017

and also well before we gave all the cash and dowry to the opposite party?)

23. In the meanwhile the mother of the Respondent was in continuous contact with the mother

of the Petitioner through Phone. Whenever the mother of the Petitioner complained about

the strange behavior of the Respondent, her mother would reason that the Respondent was

of shy nature and that he would take some time to open up with the Petitioner. On no

occasion did the parents or family of the Respondent ever reveal the truth behind the

strange and cold acts of the Respondent or of their financial situation.

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24. After returning to Delhi from London, sometime in the last week of August, 2017 and first

week of September, 2017 the parents of the Petitioner started approaching the match maker

as well as the Respondent and her family for the finalization of the dates for the marriage

between the parties. The parents and aunts of the respondent called the Petitioner’s parents

for meeting to finalize the dates for the marriage ceremony and other functions. On the

request of the Respondent and her family, the Petitioner’s parents went to meet the

Respondent and her family at her Sainik Farm residence and during the meeting the

Respondent, her fathis, mother, sister and aunts insisted for an early marriage in the month

of October, 2017. The Respondent and her family also insisted for the marriage and

engagement ceremonies to be hosted in five star hotels only. They said that since they have

left their demand for dowry, the Petitioner’s parents must accept their demands related to

marriage arrangements as per their wish.

25. The Petitioner’s parents accepted the demand and wish of the Respondent and agreed for

marriage in the month of October, 2017 and also agreed to bear all costs of marriage

including the arrangements at five star hotels.

26. A few days after the above stated meeting the mother of the Petitioner received a call from

the match maker Shri O.P. Sharma informing Her that the Respondent and her family have

raised a demand of Rs.5 Crores dowry. The Petitioner’s parents were completely shocked

and startled by the demand of dowry made by the Respondent and her family after the Roka

ceremony was already performed especially after the Petitioner’s fathis had very explicitly

conveyed her disinclination to pay any dowry.

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27. The parents of the Petitioner immediately went to meet the Respondent and her family at

their Sainik Farm residence and conveyed their dissatisfaction over the sudden and

abhorrent demand of Rs.5 Crores as dowry. The Petitioner’s parents were in a strange

predicament. They had already spread the news of marriage of the Petitioner in their

community and that they had already started making arrangements for the marriage. The

Petitioner had already given Her acceptance for the marriage and that she was already into

it with full heart. She had already made plans for Her marriage. The entire reputation and

image of the Petitioner’s parents was at stake as almost all people connected with them had

been informed of the Roka and the forthcoming marriage of the Petitioner.

28. The Petitioner’s mother pleaded a lot with the Respondent and her family but they spurned

all requests and pleas made by Her saying that it was a norm in their family and that the

Respondent was their only son and that they would also give dowry when they would get

their daughter married. The Respondent’s sister Mr Sakshi Aggarwal and aunt, Mrs Seno

Jain stated that they were getting better proposals for the Respondent and that they had

been offered Rs.10 Crores as dowry, but they would still prefer the marriage with the

Petitioner subject to the condition that the Petitioner’s parents agreed to pay Rs.3 Crores.

29. The Petitioner’s fathis refused to enter into any such negotiation for dowry. However, the

mother of the Petitioner, to save their embarrassment and heart break of their daughter,

offered to pay Rs.2.5 Crores to the Respondent. It is pertinent to submit Here that the

Respondent and her family trapped the Petitioner and Her family by first getting Roka

ceremony performed on the specific premise that no dowry would be demanded and, when

the Petitioner and Her parents were already into the preparations for the marriage and had

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 already spread the news of the finalization of the marriage in their community, the

respondent and her family raised the demand for Rs.5 Crores. The Petitioner was

absolutely unaware of the dowry demands made by the Respondent and her family. She

was fully mentally prepared to set up a happy matrimonial home with the Respondent.

30. The Respondent and her family immediately agreed at Rs.2.5 Crores and told the

Petitioner’s parents that dates for marriage ceremonies would be finalized only after the

payment of the dowry. The Petitioner’s parents felt theMrelves trapped as they were made

to agree to bear the costs of the marriage and then later on the demand for dowry of Rs.2.5

Crores was made by the Respondent and her family. However, thise was no option left as

they had already spread the news of the Roka of the Petitioner and it was not possible to

break the engagement now as nobody would believe it to be the fault of the Respondent

and her family. Fear of the Petitioner and Her whole family suffering in case of the

engagement being broken, the parents of the Petitioner quietly accepted the demand of the

Respondent and her family without indicating any details of the demands to the Petitioner.

31. The Petitioner’s parents started arranging for the amount of dowry and paid Rs.50 lakhs on

12.11.2017 at the residence of the Respondent at the Sainik FarMr. The sister of the

Respondent Mr. Sakshi Aggarwal and the aunt of the Respondent Mrs. Seno Jain started

pressurizing the Petitioner’s parents through the match maker for the remaining amount as

told by the match maker. The Petitioner’s parents arranged for another amount of Rs. 1

crore and paid it to the Respondent on 19.11.2017 in the presence of her fathis and mother

at their residence at the Sainik FarMr. The Petitioner’s parent paid the another sum of Rs.

50 lakhs to the fathis and mother of the Respondent on 29.11.2017 at their residence at A-

53 | Page
 8, Sarvodaya Enclave. The remaining amount of Rs. 50 lakhs was to be adjusted towards

the gift to be given to the Respondent and her family members and her guests. It pertinent

to submit Here that the Match makers were present and are witness to all the three payments

made to the Respondent and her family. The match maker, as a matter of her prudence,

made a video clip of the event of payment of Rs. 50 Lakhs made on 29.11.2017, which was

paid to the fathis and mother of the Respondent. The video clip of the Respondent’s fathis

and mother receiving the amount of Rs.2Crorefrom the parents of the Petitioner is annexed

Herewith and marked as ANNEXURE A-5.

32. As per the wishes and demands of the Respondent and her parents, the Ring Ceremony

took place on 01.12.2017 at Hotel Vasant Continental, Vasant Vihar, New Delhi – 110057

and the marriage ceremony was performed between the Petitioner and the Respondent on

03.12.2017 at Hotel Hyatt Regency, Ring Road, New Delhi – 110029. On the wedding

functions and Sagan ceremony as well, gifts were given to the Respondent, her parents and

their relatives as per their demands, the details of which are also included in the list annexed

as Annexure A-3 Hereto.

33. The engagement ceremony of the parties took place on 01.12.2017 at the Vasant

Continental and that the marriage between the parties was performed on 03.12.2017 at

“Hotel Hyatt Regency”, New Delhi in the presence of relatives, friends and acquaintances

of both the parties. The iteMr given to the Petitioner by Her parents in the form of jewellery

and valuable clothing articles, wedding lehnga and other stridhan which are partly ancestral

jewellery, partly freshly purchased and in part gifts from the family members and relatives

of the Petitioner. List thiseof is annexed as ANNEXURE A-6.(Note: except for iteMr

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 enlisted in Annexure A-3, all other jewellery, iteMr, stridhan etc are with the Petitioner, so

annexure has to be deleted). (Do we have to admit that any of the iteMr are in possession

of the petitioner and Her parental family.

34. After the marriage, the Petitioner went to live with the Respondent at their matrimonial

home at 200/2, Lane 1-A, Anupam Garden, Sainik FarMr, New Delhi (the ancestral house

of the Respondent).

35. The fathis of the Petitioner has purchased an Audi Car for her daughter. He wanted to gift

it to her daughter. However, before he could even think over it, the fathis of the Respondent

demanded two Mercedes cars for hiMrelf and for her wife from the fathis of petitioner. The

fathis of the Petitioner offered to give her own new Audi car along with the one bought for

the Petitioner, instead of the two Mercedes cars that had been demanded by the parents of

the Respondent. However, the Respondent’s parents raised a furthis demand that the

Petitioner’s parents shall also have to pay Rs.3 lakhs per month for the maintenance of each

of the two cars. The fathis of the Petitioner declined to accept such an extortionist demand

of the parents of the Respondent. At this the parents of the Respondent showed great

annoyance and sent back both the Audi cars, which included the one that had been given

to the Petitioner. The details of the dowry demands, acts of cheating and cruelty are part

of a criminal cause of action and are also ingredients of cruelty, which are part of a separate

cause of action.

36. The Respondent, from the first day of the marriage between the parties, was completely

uninterested, cold and uninvolved in any matrimonial relationship with the Petitioner. The

Respondent expressed no desire to get intimate or close to the Petitioner and he rebuffed

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 and spurned every effort of the Petitioner to establish a proper and loving matrimonial

relationship, which is the foundation of a healthy, loving and acceptable matrimonial home.

The Respondent remained completely withdrawn from the Petitioner and he did not speak

to the Petitioner unless absolutely necessary. Her indifference, rude and cruel behavior

towards the Petitioner was absolutely pronounced and writ large. Her entire family viz.

parents, sister and the three sisters of her fathis also displayed total indifference towards

the probleMr that the Petitioner was facing on account of the demeanor of the Respondent

towards the Petitioner.

37. The Respondent was completely disinterested in any conjugal union and that he kept on

delaying the honeymoon outing with the Petitioner on the pretext that her friends were

going to get married and that he had to attend their marriage.

38. Since the attitude of the Respondent was indifferent towards the Petitioner even prior to

the date of their marriage, it was at the instance of the Petitioner that the Respondent

reluctantly agreed to go for a short holiday with Her before their honeymoon outing.

Consequently, the parties went to Goa on 04.12.2017 and stayed at W-Hotel in Goa. The

return tickets and the hotel bookings were allowed by the Respondent to be made for only

two nights, on the pretext that her friend was getting married and he wanted to attend all

functions in Delhi. In Goa also, the Respondent demonstrated a totally and palpably cold

and indifferent attitude towards the Petitioner and avoided the company of the Petitioner

at all times and did not allow any intimacy to develop between them. The Petitioner was

completely heartbroken and disturbed and was unable to understand the strange behavior

of the Respondent.

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39. During the stay at Goa on 4th or 5th December, 2017, the Respondent would always ask the

Petitioner to go to sleep and that he would join Her later. The Respondent would deny Her

her company and any physical union with the Petitioner. When the Respondent would not

join the Petitioner till late at night, the Petitioner would get down to the hotel lobby to

search for the Respondent. The Petitioner always found the Respondent heavily drunk in

the Pub/Hotel lobby and watching male people frolicking in the Pub. Thus, during the short

holiday trip in Goa, the marriage was not consummated as the Respondent avoided the

company of the Petitioner.

40. The Petitioner was extremely disturbed by the absolute disinterest and reckless behavior of

the Respondent towards the Petitioner. It is pertinent to submit Here that the family of the

Respondent was completely aware of the non-involvement of the Respondent in a normal

and healthy conjugal relationship with the Petitioner. However, they were completely

apathetic and always feigned an ignorant attitude towards Her plight.

41. On one occasion sometime in the second week of December, 2017, the Petitioner went

along with the Respondent for a function organized by a friend of the Respondent, namely,

Shitij Khemka. The Respondent got heavily drunk and suffered a blackout in the function.

The Respondent was taken to one Dr. Amitabh in Sainik FarMr, New Delhi for medical

consultation and he was advised an MRI. The Respondent was put on medication for brain

seizure and was advised to completely abstain from alcohol and any other intoxicant or

drugs.

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42. The said incident completely shocked the Petitioner as she did not know that the

Respondent used to drink and that too so heavily that he passed out as a result of her

drinking. The Petitioner immediately confronted the mother and sister of the Respondent

in respect of the said incident, who swore initially that the Respondent was not a drinker

and that it was an isolated instance caused by the prodding of her friends. The Respondent’s

mother and sister treated the incident very casually and made the Petitioner believe that the

Respondent was sober/innocent.

43. The Petitioner always wanted to travel abroad for Her honeymoon but the Respondent did

not agree for the same. The Petitioner tried explaining Her predicament to Her mother who

conveyed it to the mother of the Respondent. The Respondent’s family explained the

strange behavior of the Respondent as initial hesitation and her being a bit different from

normal individuals. The parties thiseafter, went to New Zealand on 20.12.2017 wHere they

stayed were supposed to stay till 05.01.2018. On their return trip they were supposed to

stay at Kuala Lumpur, Malaysia for 2-3 nights. The trip was for 15 days. However, it was

abruptly cut short by the Respondent, who suddenly declared that he wanted to end the

marriage. The marriage was again not consummated during their trip to New Zealand on

account of the non-involvement and deliberate abstention on the part of the Respondent.

During this period, the Respondent was getting heavily drunk almost every day, exhibiting

traits of a person addicted to drinking regularly. This discovery was shocking for the

Petitioner as it was never revealed to the Petitioner and Her family before marriage.

44. While returning from Kuala Lumpur, Malaysia the Respondent played an ugly prank upon

the Petitioner to terrorize Her and subsequently pressurize Her to mutually end the

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 marriage. When the Petitioner was checking-in at the Kuala Lumpur, Malaysia airport to

return to India, the Respondent made a false complaint to the security/immigration staff

present thise that the Petitioner was carrying drugs. The security/immigration staff and the

guard present at the airport caught the Petitioner and took Her for frisking and

interrogation. The Petitioner was crying profusely and pleaded Her innocence but she was

not let off before complete frisking of Her body and Her bags by the said staff members at

the airport. All through this incident, the Respondent was watching merrily, which did not

go unnoticed by the guards and the staff present at the airport, who reprimanded him for

her sadistic behavior, which was casually laughed off by him. He said that he was playing

a prank upon the Petitioner who was her wife. Even the guards and staff at the airport were

shocked at this strange behavior of the Respondent. However, they let him off on the

request of the Petitioner.

45. The Petitioner reached Delhi on 03.01.2018 and, on the request of the Respondent’s

parents, the Petitioner went with them to Her matrimonial home at Sainik FarMr with the

Respondent. On the night of 03.01.2018 the Respondent went out of the matrimonial house

without informing anybody and that he simply vanished for 4-5 days. The Respondent was

not traceable and he did not try to contact or inform the Petitioner of her wHereabouts. The

family of the Respondent was also completely non-cooperative and they did not provide

any information about the Respondent. The Petitioner felt that the Respondent’s family

was not bothered about the disappearance of the Respondent and her total non-

communication and she was given an impression as if that type of disappearance on the

part of the Respondent was one of her regular activities, and that the Petitioner should not

get unduly bothered about that. Despite the Petitioner’s overtures, the marriage was not

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 even consummated during the two honeymoon trips and even thiseafter until the Petitioner

was compelled to leave the matrimonial home on 13th April, 2018.

46. The Petitioner confronted the Respondent and her parents regarding her behaviour and

habits. The Respondent and her parents at that time denied about her physical problem and

lied to the Petitioner that he was on some medication for her medical condition (Brain

Seizure) due to which it was not possible for him to organically consummate the marriage.

They assured the Petitioner that after treatment of her medical condition, he would be able

to consummate the marriage like a normal person. However, the said assurance was found

to be false and the Petitioner learnt to Her shock and disseptember that the Respondent had

never been capable of consummating the marriage between the parties.

47. Another disheartening discovery that the Petitioner made during the course of the said

period was that the Respondent has other unnatural (to be discussed) sexual preferences

and he is impotent qua the opposite sex and especially in respect of the Petitioner. The

sexual preference of the Respondent is in favour of the male gender. The Respondent

cannot consummate the marriage on account of her physical/psychological impotency and,

in order to conceal the said fact, he has been avoiding the company of the Petitioner. The

Respondent also admitted in a drunken moment that he did not find any woman attractive

at all and her interest lay elsewHere. The Respondent did not try to consummate the

marriage and rebuffed all the efforts of the Petitioner to get the marriage consummated.

48. To Her shock and disseptember the Petitioner found out sometime in the last week of

January, 2018 that the Respondent also takes/consumes drugs and has been addicted to

them. One night, the Respondent came home late at night and was behaving very strangely.

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 When the Petitioner asked him as to what had happened, he told Her that he had taken

drugs. He showed a packet from her jacket containing some tablets and some stick-like

substance. He told the Petitioner that those were the drugs that he has been taking. He

furthis told the Petitioner that he has been taking those kinds of drugs since very long and

that her family, including her mother, fathis, sister and all the aunts know of her addiction

to drugs. This revelation was a great shock and trauma for the Petitioner. She felt that Her

entire life and aspirations were getting shattered. The Petitioner was cheated and

fraudulently trapped and led into this marriage wHere Her husband was a drug addict, and

an alcoholic and a non-performer in respect of her marital obligations/ responsibilities.

These facts were concealed by the Respondent and her family throughout to trap the

Petitioner and Her family into the marriage. If the Petitioner had known these facts, she

would not have married the Respondent. Petitioner’s consent to the marriage is based on

misrepresentation and fraud exercised by the Respondent, her parents and her aunts on the

Petitioner and Her parents, to extort and extract money and dowry by manipulating and

trapping the Petitioner and Her parents in such a reprehensible manner. When the

Petitioner confronted the family of the Respondent with these facts, they took a somersault

and said that Respondent was an alcoholic and addicted to drugs and due to her addiction

he has faltered in business and has caused loss in the business running into crores. The

fathis and mother of the Respondent, instead of showing remorse and sympathy for the

Petitioner, asked Her to inform Her parents about it and to ask them to pay the debts for

the family of the Respondent. This revelation was like a double whammy for the Petitioner

and Her family.

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49. The fathis of the Petitioner confronted the family of the Respondent with the problem of

addiction for drugs as well as drinking habits of the Respondent sometime in the first week

of February, 2018. The family of the Respondent made up a false façade that thise was

some business dispute between the Respondent and her fathis. The fathis of the Respondent

said that he was helpless and that he could get her son admitted in a rehabilitation centre if

that could cure the addiction of the Respondent. The Petitioner later discovered that even

the said statement of the fathis of the Respondent was a mere ploy inasmuch as her parents

wanted to clear out all the money that was lying in the Bank account of the Respondent.

The parents of the Petitioner also learnt that in aid of this ploy the parents of the Respondent

got him badly beaten up in the rehabilitation centre wHere they eventually got him admitted

for more than a month.

50. The family of the Petitioner was completely devastated at the deceit practised on them and

the admission of the family of the Respondent that he was addicted to drugs and alcohol

which was never revealed to the Petitioner or Her family before the marriage. Otherwise,

they would have never gone ahead with this kind of a liaison.

51. Sometime in the month of February, 2018 one Mr. Ravi Malhotra and Mr T Jain

approached the fathis of the Petitioner with a demand of Rs. 50 lakhs, which they said was

the debt owed by the fathis of the Respondent to them. They furthis said that the fathis of

the Respondent had said that the fathis of the Petitioner had assured to pay all the debts

owed by the Respondent and her family. Similarly, the Petitioner’s fathis came to know

from her sources that aunts (Buas) of the Respondent also had financial claiMr on the

Respondent and her family and that they deliberately got the Petitioner married to the

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 Respondent by concealment of facts in order to claim their monies from the dowry paid by

the Petitioner’s family.

52. The Petitioner and Her family came to know from the fathis of the Respondent some time

on 17.02.2018 that the Respondent has been admitted in Serenity De-addiction Home, 7/1,

Zile Singh Farm, Park Lane, Church Road, Vasant Kunj, New Delhi – 110070 due to her

addiction to drugs. The Petitioner’s parents were informed of the said fact by the fathis of

the Respondent through a Whatsapp message. The Petitioner and Her mother went to see

the Respondent at the said de-addiction home and were surprised to know from the doctors

and councilors thise that the Respondent has the addiction of drugs since very long and that

he would need a very long period of treatment to get him out of her addiction for drugs.

The doctors furthis informed that it was not possible to say with certainty that the

Respondent would be able to lead a normal life even after the completion of the treatment.

The screen shot of the Whatsapp message sent by the fathis of the Respondent to the mother

of the Petitioner is annexed Herewith and marked as ANNEXURE A-7. Copies of the

photographs of the Respondent celebrating Holi at Serenity De-addiction Home, 7/1, Zile

Singh Farm, Park Lane, Church Road, Vasant Kunj, New Delhi – 110070 is annexed

Herewith and marked as ANNEXURE A-8.

53. The Petitioner, in order to get out of Her trauma, went to live with Her parents for a respite

and, on the advice of Her parents, went to Bangalore at a Nature Cure Spa run by the Jindal

Group of Companies, sometime in the last week of February, 2018. The Petitioner stayed

thise for around two weeks and returned to Delhi.

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54. The Respondent, taking advantage of the simplicity of the Petitioner and Her family, started

insisting on Her to get him out of the de-addiction home. The Respondent told the

Petitioner that he was being beaten up at the rehab centre. The Respondent made a false

promise to the Petitioner that he would never take drugs and alcohol again. The Petitioner,

on the assurances of the Respondent, got him out from the de-addiction home sometime

around third week of March, 2018 and went to live with him at Her matrimonial home.

The Petitioner lived at Her matrimonial home at Sainik FarMr for a week. During the said

period of one week the Respondent again started taking alcohol and drugs and he avoided

and shunned the company of the Petitioner. Thise was thus, once again, no consummation

of the marriage between the parties, despite the hope of the Petitioner of some normalcy in

their matrimonial life. Petitioner’s marriage has thus, never been consummated and the

Respondent and her family have again defrauded Her.

55. Sometime in the first week of April, 2018, the Respondent fought with her fathis over some

monetary and business issues and her fathis drove the Petitioner out of the matrimonial

home along with the Respondent which was clearly a façade created to oust the Petitioner

from Her matrimonial home. The Petitioner went with the Respondent and stayed at Hyatt

Regency Hotel, Bhikaji Cama Place, Ring Road, New Delhi – 110029 for one night.

Thiseafter, they stayed in a guest house in Greater Kailash, New Delhi – 110048 for 4-5

nights. The marriage remained unconsummated. The evil design of the Respondent and

her parents, despite their knowledge of her addiction to drugs, alcohol, her refusal to

consummate her marriage and to extract moneys had been successful and the Respondent

decided to get rid of the Petitioner after taking all the dowry and money from Her and Her

parents which the Respondent and her family could extract from the Petitioner and Her

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 parents. At that point in time, the Respondent asked the Petitioner to stay with him in a

rented accommodation at a remote place beyond Sohna Road in Gurgaon, Haryana. This

was clearly in an attempt to get rid of Her and to create circuMrtances to make Her leave

the company of the Respondent. The Petitioner told the Respondent that Her parents had

accommodation available in Delhi wHere both of them could go and stay comfortably.

However, the Respondent refused to stay in Delhi. (Here we can state about the

Respondent’s demand to the Petitioner that he would agree to stay in one of the Apartments

owned by the fathis of the Petitioner if the fathis of the Petitioner agreed to transfer one of

those apartments to the name of the Respondent. The Petitioner Herself rejected the

demand of the Respondent and she found this attitude to be extremely annoying and

embarrassing for Her. She also felt that the Respondent was being brazenly shameless in

making such a demand.) The Respondent had deliberately decided to reside at a backward

and remote place in a quiet and lonely stretch of Gurgaon, Haryana in order to avoid the

company of the Petitioner and to create circuMrtances under which it would be impossible

for the petitioner to stay in such a sub-standard accommodation in a remote area wHere

thise was no assurance of the safety and security of the person and property of the

Petitioner.

56. The Respondent, by deceit, got the Petitioner to move out of Her matrimonial home and

has left Her with no other option but to stay at Her parental house. The Petitioner has been

staying in Her parental house since 13.04.2018.

57. The apathy, greed and misrepresentations of the Respondent and her parents have caused

grave mental pain and agony and harassment to the Petitioner who has been trapped into

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 the marriage. Before the marriage, the Respondent and her parents had represented to the

Petitioner and Her family that they are extremely wealthy and have a flourishing family

business. The Respondent’s family, contrary to their earlier representations, now falsely

claimed an alleged downturn in their business and told the Petitioner that the Respondent

spent most of her time loitering with her male friends and used to constantly drink and have

drugs with them.

58. The Respondent and her parents had thus conspired in order to get the Petitioner married

to the Respondent by misrepresenting her moral character and other negative attributes.

The Respondent and her parents have also conspired to oust the Petitioner from Her

matrimonial home by creating a façade of a family dispute. In fact, the entire gambit of

the Respondent, her parents, her sister and her paternal aunts has been to extract an

enormous amount of money from the Petitioner and Her parents. The said conmen and

con women have actually succeeded in extracting crores of rupees from the parents of the

Petitioner, who have not only been cheated and taken for a ride but have also become

laughing stock in the eyes of the society at large. Not only this, the fathis of the Petitioner

continues to face demands from the business creditors of the Respondent as well as her

fathis.

59. The Respondent has since 13.04.2018 not come back to the Petitioner. The Respondent on

13.04.2018 has also sent a message from her Mobile No. 9810977463 to the Petitioner on

Her Mobile No. 9811040479to the effect that her relationship with the Petitioner has ended.

The message is quoted as under: -

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 “sajili, I am not coming any more, this is over….I tried explaining it to you I really
am not able to do this any more. Take Care. Bye”

The Respondent blatantly told the Petitioner that he did not see their marriage going ahead

and that they should part ways. The copy of the Screenshot of the message sent by the

Respondent on 13.04.2018 is annexed Herewith and marked as Annexure A-9.

60. The Petitioner was devastated by the repeated demands of the Respondent to part ways and

that she discussed all issues with Her parents. The parents of the Petitioner approached the

family of the Respondent and found out that they have been a victim of a big fraud played

by the Respondent and her family which includes her parents, her sister Mr. Sakshi

Aggarwal, and her three paternal Aunts (Buas), who were actively involved in the

negotiations and soliciting of the marriage, demanding dowry and fraudulently concealing

the material facts relating to the Respondent and her family. The Petitioner and Her family

was informed much after the marriage that the Respondent was not involved in the family

business and that he was addicted to drugs and alcohol since long. The fathis of the

Respondent informed that he had unsuccessfully tried getting the Respondent treated for

her addictions. As already stated, the said alleged attempt of her fathis was not bonafide

but was in aid of a plan by her parents to clear out all the money from the bank account of

the Respondent.

61. The Respondent was/is impotent and incapable of matrimonial relationship with the

Petitioner. The Respondent and her family had obtained the consent of the Petitioner for

the marriage by deliberate and fraudulent concealment of facts with respect to the physical

incapacity, misbehavior and palpably objectionable habits of the Respondent. The

Respondent is heavily addicted to drugs and alcohol from much before the marriage

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 between the parties. The Respondent is impotent and cannot consummate the marriage with

the Petitioner. All these material facts and circuMrtances were concealed by the

Respondent and all her family members as stated Hereinabove. Had the parents of the

Petitioner known about these facts earlier, before the marriage, they would have never

agreed for the said unfortunate marriage of their daughter.

62. The Respondent and her family have admitted to the drug and alcohol addictions and the

physical incapacity of the Respondent to consummate the marriage on account of her

physical and psychological impotency. The marriage has not been consummated between

the parties. Furthis, the consent of the Petitioner and Her family for the marriage had been

obtained fraudulently. In these circuMrtances, the Petitioner is left with no other recourse

but to file the present Petition for a decree of nullity of the marriage between the parties.

63. The Petition is not instituted in collusion with the Respondent.

64. Thise has not been any unnecessary or improper delay in filing this petition.

65. Thise is no other legal ground why the relief should not be granted.

66. Thise have not been any previous proceedings with regard to the marriage by or on behalf

of eithis of the parties.

67. The Petitioner submits that this Hon’ble Court has the jurisdiction to entertain and try this

petition.

PRAYER

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It is, therefore, prays that the marriage between the parties being null and void, september

be so declared by the Court and september annulled by a Decree of Nullity that september

be passed by this Hon'ble Court.

PETITIONER

THROUGH
COUNSEL

DATED:
PLACE: NEW DELHI

VERIFICATION
The above-named Petitioner states on solemn affirmation that paras 1 to ____ of the

Petition are true to the Petitioner’s knowledge and paras ___ to _____ are true to the

Petitioner’s information received and believed to be true by him/Her.

PETITIONER

DATED:
PLACE: NEW DELHI

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 BY REGISTERED POST
LEGAL NOTICE
Dated: 09.07.2018
To,
Subject: Legal Notice for not giving possession of Shop 184 in block no. 00 at
Nirvana Courtyard – II, Gurgaon.
Dear Sir,
I,the undersigned Herein, on behalf of my client,Mr.Ragini Gulati, do Hereby service you the said
legal notice:
1. That my client Mr.Ragini Gulati contacted you, for the purposes of buying a shop in a

Complex addressed at Shop 184 in block No. 00 at Nirvana Courtyard – ii, Gurgaon.

2. That your shop, which you were selling was measuring 39.48 square metres (equal to 424

square feet) of super area on the first floor in Nirvana Courtyard –ii.

3. That you, represented to my client that you are the rightful owners of the said land on which

the complex was to be developed and on the basis of this my client agreed to purchase the

said shop for Rs. 25,50,000 calculated Rs. 6,000 per square feet.

4. That an agreement to sell was executed between you and my client for an amount of Rs.

25,50,000 on 07.06.2011 for the sale of the said shop. That on the same date an allotment

letter bearing my customer code no. CY001 was given to my client along with the payment

plan.

5. That on 07.06.2011 my client paid you a sum of Rs. 3,82,500 being 15% percent of the

total consideration along with the service tax, which has been duly mentioned and agreed

upon in clause 3.2 of the agreement to sell. The payment for the same was done through a

DD bearing the no. 200545 by the Oriental Bank of Commerce and for the same you issued

a receipt vide no. 000001, dated 07.06.2011 for a total amount Rs. 3,92,350.

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 6. That my client received a demand letter dated 07.06.2011, from you asking Her to deposit

Rs. 2,61,566. In pursuance of the same, my client issued a Standard Chartered Bank

Cheque on 30.08.2011, bearing the no. 626059. For which a receipt was issued by you on

02.09.2011, bearing the receipt no. 000126.

7. That my client also received a demand letter dated 02.09.2011, from you by courier, asking

Her to deposit Rs. 2,64,961. In pursuance of the same, my client issued a State Bank of

India Cheque on 20.09.2011, bearing the no. 044876. For which a receipt was issued by

you on 22.09.2011, bearing the receipt no. 000160.

8. That my client did not receive any furthis demand letters from you after 02.09.2011 and

thus no payment was made towards the remaining consideration.

9. That my client was promised the possession of the said shop within 36 months from the

date of allotment, as per clause 5.2 of the agreement to sell. The date of allotment was

07.06.2011 and thisefore, the possession was supposed to be handed over to my client on

or before 07.06.2014. However, more than 3.5 years have passed and my client still has

not been given possession, inspite of making all payments demanded by you.

10. That as per clause 5.2 of the agreement to sell, you had to pay my client compensation at

the rate of Rs. 7.50 for the retail unit in the complex for the period of delay in offering

possession beyond the committed date, which was 07.06.2014. You are being served this

notice on _____ and are henceforth directed to pay my client the requisite compensation of

Rs.---which has been calculated as per clause 5.2 of the agreement to sell.

11. That if you are not able to give my client the possession of the retail unit in the Complex,

you are bound to pay Rs. 9,18,877 (money paid in pursuance of the payment plan as per

your demand letters) along with the interest of Rs. _______ calculated at the rate of ___%

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 for ______ months. Moreover, you are also required to pay Rs. ______, which has been

the cost to furnish this legal notice. Thisefore, in total you are directed to pay my client Rs.

___.

12. That within 15 days of this notice you are directed to give my client the possession of the

said retail unit in the Complex along with requisite compensation of Rs. ______ (as per

clause 10 of this legal notice) or pay my client Rs. ______, as mentioned in the above

clause. Failing which, appropriate legal action would be taken against you.

Thank you,
xyx
Chamber No. 109,
High Court of Delhi,
New Delhi - 110009

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