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Quashing of FIR Petition

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467 views

Quashing of FIR Petition

Uploaded by

bls.ankuryadavx2020
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as PDF, TXT or read online on Scribd
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IN THE HON’BLE HIGH COURT OF DELHI

CRIMINAL MISCELLANEOUS PETITION NO. [_____] OF [____]

IN THE MATTER OF:


AKASH CHAUHAN …PETITIONER
VERSUS
THE STATE … RESPONDENT

INDEX
S.No. Particulars Pages Court Fees
1. Urgent Application
2. Notice of Motion
3. Memo of Parties
4. List of Dates and Synopsis
5. Petition under section 528 of BNSS, 2023 for
quashing of FIR No. 02/20, under sections 281
and 125(a) of BNS, 2023 in PS Amar Colony,
New Delhi along with affidavit
6. Affidavit of Petitioner No. 1
7. Statement of Non filing
8. Application under section 528 of BNSS for
exemption of certified copies of annexures
alongwith affidavit.
9. Court Fees
10. Vakaltnama
Akash Chauhan …PETITIONERS
12/11/2024 THROUGH
Adv. Ridit Luthra
Ch. 112, Lawyers Block-III
Delhi Hight Court, New Delhi
IN THE HON’BLE HIGH COURT OF DELHI

CRIMINAL MISCELLANEOUS PETITION NO. [_____] OF [____]

IN THE MATTER OF:


AKASH CHAUHAN …PETITIONER
VERSUS
THE STATE … RESPONDENT

TO,
THE DEPUTY REGISTRAR
HIGH COURT OF DELHI
SUBJECT: URGENT APPLICATION

Sir,
Kindly treat the enclosed petition as an urgent one according to
Hight Court rules and orders. The ground of urgency is under:-

“Necessary orders for quashing the FIR No. 02/20, under section 281
and 125(a) of BNS, 2023 and filed at PS Amar Colony, New Delhi, are
prayed for.”

Akash Chauhan …PETITIONERS


12/11/2024 THROUGH
Adv. Ridit Luthra,
Chamber No. 112, Lawyers Block-III,
Delhi High Court, New Delhi
IN THE HON’BLE HIGH COURT OF DELHI

CRIMINAL MISCELLANEOUS PETITION NO. [_____] OF [____]

IN THE MATTER OF:


AKASH CHAUHAN …PETITIONER
VERSUS
THE STATE … RESPONDENT

NOTICE OF MOTION

Adv. Ridit Luthra


High Court of Delhi

Sir,
The accompanying petition is being preferred for quashing of FIR
No. 02/20, under section 281 and 125(a) of BNS and filed in PS Amar
Colony, New Delhi is annexed, which is likely to come up before the
Hon’ble High Court on__________ or any other date thereafter.

This is for your information and necessary action.

Akash Chauhan …PETITIONERS


12/11/2024 THROUGH
Adv. Ridit Luthra,
Chamber No. 112, Lawyers Block-III,
Delhi High Court, New Delhi
IN THE HON’BLE HIGH COURT OF DELHI

CRIMINAL MISCELLANEOUS PETITION NO. [_____] OF [____]

IN THE MATTER OF:


AKASH CHAUHAN …PETITIONER
VERSUS
THE STATE … RESPONDENT

PETITION UNDER SECTION 528 OF THE BHARATIYA


NAGRIK SURAKSHA SANHITA, 2023, PRAYING THIS HON’BLE
COURT TO PASS NECESSARY ORDERS AND DIRECTIONS
THEREBY QUASHING AND CANCELLING THE FIR No. 02/20
UNDER SECTIONS 281 AND 125(a) OF BNS, 2023 FILED IN PS
AMAR COLONY, NEW DELHI.

MEMO OF PARTIES
1. Akash Chauhan S/o Naresh Chauhan R/o H. No. 138, Sadakwala
Mohalla, Vill- Allipur, PS- Bahadurgarh, PO-Neknampur Nanai, Distt.
Hapur (UP)
…PETITIONERS
VERSUS
1. THE STATE

Akash Chauhan …PETITIONERS


12/11/2024 THROUGH
Adv. Ridit Luthra,
Chamber No. 112, Lawyers Block-III,
Delhi High Court, New Delhi
List of Dates and Events
IN THE HON’BLE HIGH COURT OF DELHI

CRIMINAL MISCELLANEOUS PETITION NO. [_____] OF [____]

IN THE MATTER OF:


AKASH CHAUHAN …PETITIONER
VERSUS
THE STATE … RESPONDENT

PETITION UNDER SECTION 528 OF THE BHARATIYA


NAGRIK SURAKSHA SANHITA, 2023, FOR QUASHING OF FIR
NO. 02/20 DATED 01/01/2020, REGISTERED AT PS AMAR
COLONY, NEW DELHI, UNDER SECTIONS 281 AND 125(a) OF
BHARATIYA NYAYA SANHITA, 2023, PENDING
INVESTIGATION/TRIAL.
AND ALSO
PRAYING THIS HON’BLE COURT TO PASS ANY OTHER
ORDER OR DIRECTION AS THIS HON’BLE COURT DEEM FIT
AND PROPER IN THE FACTS AND CIRCUMSTANCES OF THE
CASE.
TO,
THE HON’BLE CHIEF JUSTICE
AND HIS HON’BLE COMPANION
JUSTICES OF THE HIGH COURT OF DELHI

THE HUMBLE PETITION OF THE


PETITIONERS ABOVE NAMED.
MOST RESPECTFULLY SHOWETH:
1. That the petitioner is filing the present petition under 528 OF THE
BHARATIYA NAGRIK SURAKSHA SANHITA, 2023 for quashing
FIR No. 02/20 dated 01/01/2020 registered at PS Amar Colony, New
Delhi, under Sections 281 and 125(a) of BHARATIYA NYAYA
SANHITA, 2023.
2. That the petitioner submits the incident was purely accidental and
lacked criminal intent or negligence.
3. That multiple factors contributed to the incident, casting doubt on the
petitioner’s sole responsibility.
4. That the petitioner has fully cooperated, demonstrating good faith.
5. That the injured party is willing to provide a statement that may
mitigate liability.
6. That the continuation of proceedings would cause undue hardship and
misuse judicial resources.

PRAYER
It is therefore, humbly and respectfully prayed that this Hon’ble Court
may kindly be pleased to quash the FIR No. 02/20 dated 01/01/2020 filed in
PS Amar Colony, New Delhi, under section 281 and 125(a) of BHARATIYA
NYAYA SANHITA , 2023, in the interest of justice.

Akash Chauhan …PETITIONERS


12/11/2024 THROUGH
Ridit Luthra,
Chamber No. 112, Lawyers Block-III,
Delhi High Court, New Delhi
IN THE HON’BLE HIGH COURT OF DELHI

CRIMINAL MISCELLANEOUS PETITION NO. [_____] OF [____]

IN THE MATTER OF:


AKASH CHAUHAN …PETITIONER
VERSUS
THE STATE … RESPONDENT

AFFIDAVIT

I, Akash Chuhan S/o Naresh Chauhan, aged about 28 years R/o H. No.
138, Sadakwala Mohalla, Vill- Allipur, PS- Bahadurgarh, PO Neknampur
Nanai, Distt. Hapur (UP), do hereby solemnly affirm and declare as under:

1. That the deponent is petitioner No. 1 in this petition and is fully conversant
with the facts and circumstances of this case. The deponent is competent to
swear this affidavit.

2. That the accompanying petition has been drafted and filed under my
instruction by my counsel. I have read the same in between lines and the
same is true and correct to the best of my knowledge and belief and nothing
has been concealed therein.

3. That the deponent has not filed any other similar petition seeking quashing
of FIR in question either before this Hon’ble Court or before the Hon’ble
Supreme Court of India.
DEPONENT
VERIFICATION

Verified at ____________ on this 12 day of November, 2024 that the


contents of the above affidavit are true and correct to the best of my
knowledge and nothing material has been concealed therein.

Akash Chauhan …DEPONENT


IN THE HON’BLE HIGH COURT OF DELHI

CRIMINAL MISCELLANEOUS PETITION NO. [_____] OF [____]

IN THE MATTER OF:


AKASH CHAUHAN …PETITIONER
VERSUS
THE STATE … RESPONDENT

STATEMENT OF NON FILING

That the petitioner has not filed any other similar petition seeking
quashing of the FIR in question either before this Hon’ble Court or before
the Hon’ble Supreme Court of India.

Akash Chauhan …PETITIONER


12/11/2024 THROUGH
Ridit Luthra,
Chamber No. 112, Lawyers Block-III,
Delhi High Court, New Delhi
IN THE HON’BLE HIGH COURT OF DELHI

CRIMINAL MISCELLANEOUS PETITION NO. [_____] OF [____]

IN THE MATTER OF:


AKASH CHAUHAN …PETITIONER
VERSUS
THE STATE … RESPONDENT

APPLICATION UNDER SECTION 528 OF THE BHARATIYA


NAGRIK SURAKSHA SANHITA, 2023 FOR EXEMPTION
FROM THE FILING CERTIFIED COPY OF THE
ANNEXURES.

MOST RESPECTFULLY SHOWETH:

1. That the petitioner has filed the above said petition before this Hon’ble
Court seeking quashing of FIR No. 02/20, under section 281 and
125(a) of BNS, the contents whereof are not being repeated herein for
the sake of brevity and may be read as part and parcel of the present
application.

2. That the petitioner is unable to furnish the certified copy of the


aforesaid annexures at this stage and will submit the same before this
Hon’ble Court after their receipt.

It is, therefore, most humbly and respectfully prayed that filing of the
certified copies of the annexures may kindly be exempted, in the
interest of justice.
Akash Chauhan …PETITIONER

12/11/2024 THROUGH

Adv. Ridit Luthra,


Chamber No. 112, Lawyers Block-III,
Delhi High Court, New Delhi
IN THE HON’BLE HIGH COURT OF DELHI

CRIMINAL MISCELLANEOUS PETITION NO. [_____] OF [____]

IN THE MATTER OF:


AKASH CHAUHAN …PETITIONER
VERSUS
THE STATE … RESPONDENT

COURT FEES

Akash Chauhan …PETITIONER


12/11/2024 THROUGH
Adv. Ridit Luthra,
Chamber No. 112, Lawyers Block-III,
Delhi High Court, New Delhi

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