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Application - Khushnuma Vs Arshad

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20 views7 pages

Application - Khushnuma Vs Arshad

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Uploaded by

Naveen Roy
Copyright
© © All Rights Reserved
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IN THE HON’BLE COURT OF MS.

SHAINA GOYAL, JUDICIAL


MAGISTRATE FIRST CLASS (MAHILA COURT), CENTRAL, TIS
HAZARI COURT
MISS. APPL ____ OF 2025
IN
CT. CASES/1673/2023
IN THE ATTER OF:-
KHUSHNUMA …. COMPLAINANT
~VS~
ARSHAD & ORS. …. RESPONDENTS
MISCELLANIOUS APPLICATION ON THE BEHALF OF
RESPONDENTS TO SET ASIDE THE ORDER DATED 01.08.2024
CLOSING THE RIGHTS OF THE RESPONDENTS TO FILE THE
WRITTEN STATEMENTS
MOST HUMBLY RESPECTFULY SHOWETH:-
1. That the above captioned matter is listed before this Hon’ble court and
pending for adjudication and determination.
2. That on 10.05.2024, the counsel of complainant pressed to supply the copy
of complaint to the Respondent which was not supplied to the respondents.
3. However, on 01.08.2024, the Ld. Predecessor Judge of this Hon’ble court,
inadvertently passed an order, wherein she closing the rights of the
Respondents to file written statement by the Respondents.
4. It is humbly submitted that the counsel for the Complainant has supplied the
copy of complaint to the counsel of Respondents on 10.09.2024. The
screenshot of the same is annexed herewith as Annexure A-1.
5. The rights closed to file the written statement by the Respondents will have
an adversarial impact on the rights of all the Respondents. The respondent
will not be able to present their facts and circumstances in pellucid way,
which will cast a prejudice to their rights.
6. Therefore in the interest of justice, it is imperative to vacate the rights of
Respondents to file the written statement.
PRAYER

In view of the above submissions, it is therefore, most respectfully prayed


that this Hon’ble Court may kindly be pleased:-
a. To vacate the rights of the Respondents to file written statements in the
interest of justice.
b. Any other order, as this Hon’ble court may deem fit.

RESPONDENT NO.1 RESPONDENT NO.2 RESPONDENT NO.3

RESPONDENT NO.4
Place:- New Delhi
Dated:- 08.09.2024 THROUGH

AASIF ABDULLAH MEO & AKASH KUMAR


ADVOCATE
Office-A-6, Patel Chest, Christian Colony,
Near Delhi University, New Delhi- 110007
Ph- 9555973086, Email- ursvakilakash@gmail.com

VERIFICATION:-
Verified at Delhi on this ____ day of December, 2024 that
the contents of the paras of the above application are true and
correct to the best of our knowledge and nothing material has
been concealed therefrom.

RESPONDENT NO.1; RESPONDENT


NO.2;

RESPONDENT NO.3; RESPONDENT NO.4


IN THE HON’BLE COURT OF MS. SHAINA GOYAL, JUDICIAL
MAGISTRATE FIRST CLASS (MAHILA COURT), CENTRAL, TIS
HAZARI COURT
CT. CASES/1673/2023
IN THE MATTER OF:-
KHUSHNUMA ….
COMPLAINANT
~VS~
ARSHAD & ORS. ….
RESPONDENTS

AFFIDAVIT

I, Arshad, S/o- Dilshad Ahmad, aged 28 years, resident of:- C-88/332, T


Hurts Mir Dard Marg Minto Road, Gurudwara, Darya Ganj, Central
Delhi, New Delhi- 110002, do hereby solemnly affirm and state as
under:

1) That I am the Applicant no. 1 in the above noted matter and as


such am competent to swear the instant affidavit.
2) That I have read and understood the contents of the
accompanying application and state that the same has been
drafted in accordance under my instructions and is true and
correct.
3) That the contents of my above affidavit are true and correct.

VERIFICATION: DEPONENT
I, the above named deponent, hereby verify that the contents of my
above affidavit are true and correct. No part thereof is wrong and
nothing has been concealed there from.
Verified at New Delhi on this ____ day of _____________ 2024.
DEPONENT

IN THE HON’BLE COURT OF MS. SHAINA GOYAL, JUDICIAL


MAGISTRATE FIRST CLASS (MAHILA COURT), CENTRAL, TIS
HAZARI COURT
CT. CASES/1673/2023
IN THE MATTER OF:-
KHUSHNUMA ….
COMPLAINANT
~VS~
ARSHAD & ORS. ….
RESPONDENTS

AFFIDAVIT

I, Reshma, w/o- Dilshad Ahmad, aged 46 years, resident of:- C-88/332,


T Hurts Mir Dard Marg Minto Road, Gurudwara, Darya Ganj, Central
Delhi, New Delhi- 110002, do hereby solemnly affirm and state as
under:

4) That I am the applicant no. 2 in the above noted matter and as


such am competent to swear the instant affidavit.
5) That I have read and understood the contents of the
accompanying application and state that the same has been
drafted in accordance under my instructions and is true and
correct.
6) That the contents of my above affidavit are true and correct.

VERIFICATION: DEPONENT
I, the above named deponent, hereby verify that the contents of my
above affidavit are true and correct. No part thereof is wrong and
nothing has been concealed there from.
Verified at New Delhi on this ____ day of _____________ 2024.

DEPONENT

IN THE HON’BLE COURT OF MS. SHAINA GOYAL, JUDICIAL


MAGISTRATE FIRST CLASS (MAHILA COURT), CENTRAL, TIS
HAZARI COURT
CT. CASES/1673/2023
IN THE MATTER OF:-

KHUSHNUMA …. COMPLAINANT

~VS~

ARSHAD & ORS. …. RESPONDENTS

AFFIDAVIT

I, Iram, D/o- Dilshad Ahmad, aged 28 years, resident of:- C-88/332, T


Hurts Mir Dard Marg Minto Road, Gurudwara, Darya Ganj, Central
Delhi, New Delhi- 110002, do hereby solemnly affirm and state as
under:

7) That I am the Respondent no. 3 in the above noted matter and as


such am competent to swear the instant affidavit.
8) That I have read and understood the contents of the
accompanying application and state that the same has been
drafted in accordance under my instructions and is true and
correct.
9) That the contents of my above affidavit are true and correct.
VERIFICATION: DEPONENT
I, the above named deponent, hereby verify that the contents of my
above affidavit are true and correct. No part thereof is wrong and
nothing has been concealed there from.
Verified at New Delhi on this ____ day of _____________ 2024.

DEPONENT

IN THE HON’BLE COURT OF MS. SHAINA GOYAL, JUDICIAL


MAGISTRATE FIRST CLASS (MAHILA COURT), CENTRAL, TIS
HAZARI COURT
CT. CASES/1673/2023
IN THE MATTER OF:-

KHUSHNUMA …. COMPLAINANT

~VS~

ARSHAD & ORS. …. RESPONDENTS

AFFIDAVIT

I, Sumaila, D/o- Dilshad Ahmad, aged ___ years, resident of:- C-88/332,
T Hurts Mir Dard Marg Minto Road, Gurudwara, Darya Ganj, Central
Delhi, New Delhi- 110002, do hereby solemnly affirm and state as
under:

10) That I am the Respondent no. 4 in the above noted matter and as
such am competent to swear the instant affidavit.
11) That I have read and understood the contents of the
accompanying application and state that the same has been
drafted in accordance under my instructions and is true and
correct.
12) That the contents of my above affidavit are true and correct.
VERIFICATION: DEPONENT
I, the above named deponent, hereby verify that the contents of my
above affidavit are true and correct. No part thereof is wrong and
nothing has been concealed there from.
Verified at New Delhi on this ____ day of _____________ 2024.

DEPONENT

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