IN THE HON’BLE HIGH COURT OF DELHI, AT NEW DELHI · Krishna Kr. Sharma Petitioner Versus Govt. of NCT of Delhi Respondent COURT FEES Filed By New Delhi Dated 03.06.2020 Krishna

IN THE HON’BLE HIGH COURT OF DELHI, AT NEW

DELHI

EXTRAORDINARY WRIT JURISDICTION

Writ Petition (Civil) No _____ of 2020

IN THE PUBLIC INTEREST LITIGATION OF:

Krishna Kr. Sharma Petitioner

Versus

Govt. of NCT of Delhi Respondent

WITH

C.M. NO. OF 2020 : Exemption from filing

certified, dim, typed & margin

copies of documents

PAPER BOOK

[SEE INDEX INSIDE]

Krishna Kr. Sharma/K.M. Monika(Advocate)

(Petitioner in Person)

Ch. No. 906, Patiala House Courts,

New Delhi-110001

Mob- +91-9958891040

E-mail- [email protected]

mailto:[email protected]


DELHI


Writ Petition (Civil) No _____of 2020



Versus


INDEX

S.NO

PARTICULAR (S) PAGE NO.

1. Court Fees

A

2. Urgent Application

B

3. Notice of Motion

C

4. Synopsis & List of Dates

D – K

5. Memo of Parties

1 – 2

6. Civil Writ Petition along with affidavit

3 – 15

7. Application under section 151 C.P.C for

exemption from filing certified/true

typed/ with proper margins of the

annexure, along with affidavit in

support.

16 – 19

8 The copy of order dated 17.04.2020 and

multiple news article are annexed

herewith as Annexure A-1 and

Annexure A-2 respectively.

20 - 40

9 The copy of the order-dated 24.04.2020

is annexed herewith as Annexure A-3.

41 – 68

10 The copy of news article dated

28.04.2020 is annexed herewith as

Annexure A-4. and ICMR guidelines

dated 20.03.2020 is annexed herewith as


69 - 73

11 The copy of News article dated


Annexure A-6.

74 - 76

12 The copy of order dated 30.04.2020 is

annexed herewith as Annexure A-7.

77 – 79



Annexure A-8.

80 – 83

14 The copy of News article dated 84 - 91


Annexure A-9.

15 A copy of News Paper article dated


Annexure A-10.

92 – 98



Annexure A-11.

99

17 VAKALATNAMA (Not Required as

Petition is being filed in person)

Filed By

New Delhi

Dated 03.06.2020 Krishna Kr. Sharma/K.M. Monika



New Delhi-110001

Mob- +91-9958891040



DELHI





Versus


COURT FEES

Filed By

New Delhi




New Delhi-110001

Mob- +91-9958891040



DELHI





Versus


NOTICE OF MOTION

Esteemed Sir/Madam

Kindly take notice that the accompanying Writ Petition under

Article 226 of the Constitution of India r/w section 151 of the Civil

Procedure Code, for, is being filed for and behalf of the Petitioner

and is likely to be listed before the Hon’ble Court for hearing on

________________ or any other day, thereafter, as per rules.

Filed by

New Delhi




New Delhi-110001

Mob- +91-9958891040



DELHI





Versus


URGENT APPLICATION

Esteemed Sir/Madam

Will you kindly treat this accompanying Petition/Application on an

urgent one in accordance with the High Court Rules and Orders?

The Ground of urgency are as prayed in the petition

Filed by

New Delhi




New Delhi-110001

Mob- +91-9958891040


SYNOPSIS AND LIST OF DATES

The Writ Petition is being filed in public interest to seek an

appropriate writ or directions against the Respondent authorities to

urge the Government Hospital and Private Hospital to comply with

the order of the Respondent pertaining to the treatment and

admission of asymptomatic and symptomatic or (COVID-19 and

non-COVID-19) patients, direct not to make COVID-19 test

mandatory before admitting elective and even emergency patients in

any Government and Private Hospital, direct Private Hospital not to

charge high amount (beyond the actual cost) for PPE kits from

Patients using every day during treatment, and direct not to force

frontline hospital staff to wear “USED PPE”, which was being

used by COVID-19 positive patient.

By this Public Interest Litigation, the Petitioner wishes to bring to

your kind notice the difficulties being faced by the public at large.

Pursuant to the report and news articles received, multiple Private

Hospitals have made COVID-19 test mandatory before admitting

elective and even emergency patients, despite Respondent issued a

clarification on aforesaid issue, asking hospitals authority not to test

asymptomatic patients. It is submitted that many hospitals, are

hesitating in providing critical services such as dialysis, blood

transfusion, chemotherapy and institutional deliveries. It has also

been noticed that at many places the hospitals/ clinics are insisting

for a COVID-19 test before providing services.” Multiple directions

issued by the Respondent that any Government and Private Hospital

or Nursing home in the National Capital Territory that refuses

emergent medical care to the person amid COVID-19 pandemic,

strict action will be taken against those defaulters, especially in the

case of ESRD (End Stage Renal Disease) patients. Further,

registration shall be cancelled for such Private Hospital and/or

Nursing Home. There is no compliance of directions and order of

the Respondent.

It will not be out of the place to mentioned that Respondent

emphasized that while continuing to focus on COVID 19 related

activities, providing other essential services was important not only

to maintain people's trust in the health system to deliver essential

health services, but also to minimize an increase in morbidity and

mortality from other health conditions. Accordingly all states were

directed to identify essential services such as: pregnant women,

those recently delivered, infants and children under five, those on

treatment for chronic diseases, communicable diseases like

TB/Leprosy, vector borne diseases, requiring treatment for dialysis,

cancer, blood transfusions, and other special needs, that would be

prioritized in the efforts to maintain continuity of service delivery.

Further, Respondent directed to ensure the availability of regular

medical services at non-COVID-19 Hospitals to maintain their full

operations for the care of patients and try to accommodate the load

of the hospitals, which has been declared as COVID-19 hospital by

Respondent.

It is submitted that 63-year-old cancer patient in Delhi had to wait

for more than 24 hours to get hospitalized and quarantined even

after he was found to be COVID-19 positive. It is further submitted

that Delhi Police constable, who was asymptomatic till he suffered

from fever and developed breathing problems, was allegedly denied

admission by hospital, despite, being a frontline warrior, showing

COVID-19 symptoms and worsening health conditions. He died on

the way to RML Hospital, mere hours after he complained of

medical problems.

It will not be out of place to mention that a man preferred Apollo

Hospital for his treatment since the said hospital was closest to his

home, compelled or forced to pay an additional Rs 4,500 (the

price of the RT-PCR COVID-19 test) along with his dialysis fee.

Further, three more patients who was visiting, Apollo Hospital at

Delhi’s Sarita Vihar for day-care treatment services like dialysis

and chemotherapy were being asked to get RT-PCR tests for

COVID-19 every week before their procedures.

Recently a nurse succumbed to COVID-19 in Hospital since she

was forced to wear USED PPE, which was used by COVID-19

positive patient (according to source). It will not be out of place to

mention that the Private Hospitals are charging heavy amount for

PPE.

LIST OF DATES

Date Particulars

17.04.2020 The direction issued by the Respondent

that any Hospital or Nursing Home in the

National Capital Territory that refuses

emergent medical care to the person amid

COVID-19 pandemic, strict action will be

taken against those defaulters, especially

in the case of ESRD (End Stage Renal

Disease) patients. Further, Registration

shall be cancelled for such Hospitals

and/or Nursing Home.

17.04.2020 The Respondent directed to ensure the

availability of regular medical services at

Non-COVID-19 Hospitals to maintain

their full operations for the care of patients

and try to accommodate the load of the

hospitals, which has been declared as

COVID-19 hospital by Respondent.

24.04.2020 The Respondent directed that no patient

other than with COVID-19, reaching non-

COVID Government or Private Hospital

shall be denied treatment or admission in

the hospital.

28.04.2020 The multiple Private Hospitals have made

COVID-19 test mandatory before

admitting elective and even emergency

patients, hesitating in providing critical

services such as dialysis, blood

transfusion, chemotherapy, and

institutional deliveries and also noticed

that at many places the hospitals and

nursing homes are insisting individual for

COVID-19 test before providing services,

despite clarification issued by Ministry of

Health and Family Welfare and ICMR on

aforesaid issue, asking hospitals authority

not to test asymptomatic patients and

allow testing of only all symptomatic

patients, symptomatic contacts of

laboratory confirmed cases, symptomatic

health care workers, hospitalized patients

with severe acute respiratory illness (fever

and cough and/or shortness of breath), and

asymptomatic direct and high-risk

contacts of a confirmed case respectively.

28.04.2020 A 63-year-old cancer patient in Delhi had

to wait for more than 24 hours to get

hospitalized, and quarantined even after he

was found to be COVID-19 positive.

30.04.2020 The Respondent emphasized that while

continuing to focus on COVID 19 related

activities, providing other essential

services was important not only to

maintain people's trust in the health

system to deliver essential health services,

but also to minimize an increase in

morbidity and mortality from other health

conditions. Accordingly all states were

directed to identify essential services such

as: pregnant women, those recently

delivered, infants and children under five

years, those on treatment for chronic

diseases, communicable diseases like

TB/Leprosy, vector borne diseases,

requiring treatment for dialysis, cancer,

blood transfusions, and other special

needs, that would be prioritized in the

efforts to maintain continuity of service

delivery.

07.05.2020 Delhi Police constable, who was

asymptomatic till he suffered from fever

and developed breathing problems, was

allegedly denied admission by hospital,

despite, being a frontline warrior, showing

COVID-19 symptoms and worsening

health conditions. He died on the way to

RML Hospital, mere hours after he first

complained of medical problems.

13.05.2020 A man preferred Apollo Hospital for his

treatment since the said Hospital was

closest to his home, compelled or forced

to pay an additional Rs 4,500 (the price

of the RT-PCR COVID-19 test) along

with his dialysis fee. Further, three more

patients who was visiting, Apollo

Hospital at Delhi’s Sarita Vihar for day-

care treatment services like dialysis and

chemotherapy were being asked to get

RT-PCR tests for COVID-19 every week

before their procedures.

25.05.2020 Nurse succumbed to COVID-19 in

Government Hospital since she was forced

to wear used PPE, which was used by

COVID-19 positive person (according to

source).

26.05.2020 Private Hospitals are charging heavy

amount for PPE using everyday.

The Respondent has not taken any action upon the same, therefore

the present petition.


DELHI


Writ Petition (Civil) No. __________ of 2020



Versus


MEMO OF PARTIES

Krishna Kr. Sharma

Advocate

Chamber No.-906,

Patiala House Court’s Complex

New Delhi-110001 Petitioner

VERSUS

Govt. of NCT of Delhi

Department of Health Administration

Through its Directorate General of Health Services

Health and Family Welfare Department

9th Level, A-Wing, IP Extension,

Delhi Secretariat, Delhi - 110002 Respondent

Filed by

New Delhi




New Delhi-110001

Mob- +91-9958891040



DELHI


Writ Petition (Civil) No __________ of 2020



Versus


THE INSTANT PUBLIC INTEREST LITIGATION (WRIT

PETITION) UNDER ARTICLE 226 OF THE

CONSTITUTION OF INDIA R/W SECTION 151 C.P.C FOR

SEEKING ISSUANCE OF WRIT OF MANDAMUS OR ANY

OTHER WRIT, ORDER OR DIRECTION THEREBY

DIRECTING THE RESPONDENT TO COMPEL AND/OR

URGE THE GOVERNMENT HOSPITAL AND PRIVATE

HOSPITAL TO COMPLY WITH THE ORDER OF THE

RESPONDENT PERTAINING TO THE TREATMENT AND

ADMISSION OF ASYMPTOMATIC AND SYMPTOMATIC

OR (COVID-19 AND NON-COVID-19) PATIENTS, DIRECT

NOT TO MAKE COVID-19 TEST MANDATORY BEFORE

ADMITTING ELECTIVE AND EVEN EMERGENCY

PATIENTS IN ANY GOVERNMENT AND PRIVATE

HOSPITAL, DIRECT PRIVATE HOSPITAL NOT TO

CHARGE HIGH AMOUNT (BEYOND THE ACTUAL COST)

FOR PPE KITS FROM PATIENTS USING EVERY DAY

DURING TREATMENT, AND DIRECT NOT TO FORCED

FRONTLINE HOSPITAL STAFF TO WEAR “USED PPE”,

WHICH WAS BEING USED BY COVID-19 POSITIVE

PATIENT;ALONGWITH AFFIDAVIT IN SUPPORT AND

FOR SEEKING FURTHER DIRECTIONS.

TO,

THE HON’BLE CHIEF JUSTICE

THE HON’BLE HIGH COURT OF DELHI

AND HIS COMPANION JUSTICES

MOST RESPECTFULLY SHOWETH:

That the Petitioner is Advocate by profession and is invoking the

extraordinary writ jurisdiction of this Hon’ble Court for seeking

writ of mandamus or any other writ of like nature for seeking

directions to the Respondent to (i) urge the Government Hospital

and Private Hospital to comply with the order of the Respondent

pertaining to the treatment and admission of asymptomatic and

symptomatic or (COVID-19 and non-COVID-19) patients, (ii)

direct not to make COVID-19 test mandatory before admitting

elective and even emergency patients in any Government and

Private Hospital, (iii) direct Private Hospital not to charge high

amount (beyond the actual cost) for PPE kits from Patients using

every day during treatment, and (iv) direct not to forced frontline

hospital staff to wear “USED PPE”, which was being used by

COVID-19 positive patient. The petitioner has no personal interest

in the petition and the petition is not guided by self-gain of any

other person/institution/body and that there is no motive other than

of public interest in filing the writ petition.

1. THE BRIEF FACTS OF THE CASE ARE AS UNDER

a. That the direction issued by Respondent that any Private

Hospital or nursing home in the National Capital Territory

that refuses emergent medical care to the person amid

Covid-19 pandemic, strict action will be taken against

those defaulters, especially in the case of ESRD (End

Stage Renal Disease) patients. Further, Registration shall

be cancelled for such Private Hospital and/or Nursing

Home. However, no effect. The copy of order dated

17.04.2020 and multiple newspaper article are annexed

herewith as Annexure A-1 and Annexure A-2

respectively.

b. That on 17.04.2020, the Respondent directed to ensure the

availability of regular medical services at Non-COVID

hospitals to maintain their full operations for the care of

patients and try to accommodate the load of the hospitals,

which has been declared as COVID 19 hospital by

Respondent.

c. That on 24.04.2020, the Respondent directed that any non-

COVID patient other that COVID – 19, reaching “non-

COVID” Government and Private Hospitals, shall not be

denied treatment or admission in the hospital. However,

no effect. The copy of the order-dated 24.04.2020 is


d. That further, multiple Private Hospitals have made

COVID-19 test mandatory before admitting elective and

even emergency patients, hesitating in providing critical

services such as dialysis, blood transfusion, chemotherapy,

and institutional deliveries and also noticed that at many

places the hospitals and nursing homes are insisting

individual for COVID-19 test before providing services,

despite clarification issued ICMR on aforesaid issue,

asking hospitals authority not to test asymptomatic

patients and allow testing of only all, symptomatic

individuals who have undertaken international travel in the

last 14 days, symptomatic contacts of laboratory

confirmed cases, symptomatic health care workers,

hospitalized patients with Severe Acute Respiratory Illness

(fever AND cough and/or shortness of breath),and

Asymptomatic direct and high-risk contacts of a confirmed

case respectively. However, no effect. The copy of

newspaper article dated 28.04.2020 and ICMR guidelines

dated 15.03.2020 is annexed herewith as Annexure A-4

and Annexure A-5 respectively.

e. It is submitted that a 63-year-old cancer patient in Delhi

had to wait for more than 24 hours to get hospitalized and

quarantined even after he was found to be COVID-19

positive. The copy of newspaper article dated 28.04.2020


f. That on 30.04.2020, the Respondent emphasized that

while continuing to focus on COVID 19 related activities,

providing other essential services was important not only

to maintain people's trust in the health system to deliver

essential health services, but also to minimize an increase

in morbidity and mortality from other health conditions.

Accordingly all states were directed to identify essential

services such as: pregnant women, those recently

delivered, infants and children under five, those on

treatment for chronic diseases, communicable diseases like

TB/Leprosy, vector borne diseases, requiring treatment for

dialysis, cancer, blood transfusions, and other special

needs, that would be prioritized in the efforts to maintain

continuity of service delivery. However, no effect. The

copy of order-dated 30.04.2020 is annexed herewith as

Annexure A-7.

g. It will not be out of place to mention that Delhi Police

constable, who was asymptomatic till he suffered from

fever and developed breathing problems, was the first cop

in Delhi to die due to coronavirus, was allegedly denied

admission by hospital, despite, being a frontline warrior,

showing COVID-19 symptoms and worsening health

conditions. He died on the way to RML Hospital, mere

hours after he first complained of medical problems. The

copy of newspaper article dated 07.05.2020 is annexed

herewith as Annexure A-8.

h. It is submitted that a patient preferred Apollo hospital for

his treatment since the said Hospital was closest to his

home, compelled or forced to pay an additional amount

of Rs 4,500 (the price of the RT-PCR COVID-19 test)

along with his dialysis fee. Further, three more patients

who was visiting, Apollo Hospital at Delhi’s Sarita Vihar

for day-care treatment services like dialysis and

chemotherapy were being asked to get RT-PCR tests for

COVID-19 every week before their procedures. The copy

of newspaper article dated 13.05.2020 is annexed herewith

as Annexure A-9.

i. A nurse in Hospital succumbed to COVID-19 since she

was forced to wear used PPE. A copy of newspaper article

dated 25.05.2020 is annexed herewith as Annexure A-10.

j. Private Hospitals in Delhi are charging high amount for

PPE from patients using PPE everyday. A copy of

newspaper article dated 26.05.2020 is annexed herewith as

Annexure A-11.

2. That issue involved in the petition is in larger public interest

since symptomatic, asymptomatic, and frontline warriors are

sufferers in terms of not getting access of medical treatment and

routine checkup.

3. That Respondent shall suppress and urge Government and

Private Hospital to comply with the order and directions issued

for Government and Private Hospitals amid COVID-19

pandemic. Furtherance of mentioned direction, Respondent shall

authorize officers to compound offences under the Act within

the territory of NCT of Delhi and take overall control upon the

Government and Private Hospital to ensure that Hospitals are

complying with the order and directions and orders of

Respondent within the territory of Delhi. To the knowledge of

the Petitioner, no other person/bodies/institutions are likely to be

affected by the orders sought in the writ petition. The Petitioner

undertakes to add and/or amend the parties to the petition, if this

Hon’ble Court so direct.

4. That the Petitioner is Advocate by profession and such Petitioner

is very well conversant of the cause for which the present

petition is filed. The Petitioner has means to pay the costs, if

any, imposed by the Court. The Petitioner undertakes to deposit

the costs, if so, imposed by this Hon’ble Court.

5. That the petitioner has earlier filed no any Public Interest

Litigation,

6. That the present petition is filed on the following grounds

amongst others, as under: -

GROUNDS

A. BECAUSE multiple Private Hospitals have made

COVID-19 test mandatory before admitting elective

and even emergency patients, despite the Government

issuing a clarification on aforesaid issue, asking

hospitals authority not to test asymptomatic patients. It

is submitted that many hospitals, are hesitating in

providing critical services such as dialysis, blood

transfusion, chemotherapy, and institutional deliveries.

B. BECAUSE the Government and Private Hospitals are

continuously denying admission of asymptomatic and

symptomatic COVID-19 patient and not complying

with the order of the Respondent pertaining to the

treatment and admission of asymptomatic and

symptomatic or (COVID-19 and non-COVID-19)

patients.

C. BECAUSE the direction issued by Respondent that any

Private Hospital or nursing home in the National

Capital Territory that refuses emergent medical care to

the person amid COVID-19 pandemic, strict action will

be taken against those defaulters, especially in the case

of ESRD (End Stage Renal Disease) patients. Further,

Registration shall be cancelled for such Private

Hospital and/or Nursing Home. However, there is no

compliance of the direction.

D. BECAUSE Hospitals are charging high amount for

PPE (beyond the actual cost) from Patients using every

day during treatment.

E. BECAUSE Hospitals are forcing/compelling frontline

health workers to wear used PPE. According to source,

a nurse succumbed to COVID-19 in Hospital since she

was forced to wear “USED PPE”, which was used by

COVID-19 positive patient.

F. BECAUSE of negligence is being performed in

following and implementation of multiple orders of

Respondent pertaining to COVID -19 and non-COVID

19 patient due to which the health of the citizens in

Delhi is at high risk amid COVID-19 pandemic.

G. BECAUSE the grievance raised by the Petitioner is

genuine and the petition of the petitioner deserves to be

allowed.

7. That the petitioner seeks kind permission of this Hon’ble Court

to urge such other and further grounds as may available to him

as the time of hearing of the present writ petition.

8. That the present petition is bona fide and the same may be

allowed in the interest of justice.

9. That the petitioner craves indulgence of this Hon’ble Court to

raise any other or further ground(s) during the course of

arguments of the present petition.

10. That the present petition is bona-fide and the same may kindly

be allowed in the interest of Justice.

11. That the petitioner has not filed any other petition/application for

seeking similar relief before this Hon’ble Court or the Hon’ble

Supreme Court of India.

PRAYER

In the light of aforementioned facts and circumstances, it is

therefore most respectfully prayed to this Hon’ble Court that this

Hon’ble Court would be pleased to:

i. Issue a writ in the nature of Mandamus or any other writ

of like nature thereby passing order or direction to the

Respondent for ensuring that those Government and

Private Hospital or Nursing home in the National Capital

Territory that refuses emergent medical care to the person

amid Covid-19 pandemic, an immediate action shall be

taken against those defaulters.

ii. Issue a writ in the nature of Mandamus or any other writ


Respondent for ensuring that the Government and Private

Hospitals shall not deny the admission of asymptomatic

and symptomatic Covid-19 patient and complying with the

order of the Respondent pertaining to the treatment and

admission of asymptomatic and symptomatic or (COVID-

19 and non-COVID-19) patients.

iii. Issue a writ in the nature of Mandamus or any other writ


Respondent for ensuring that Covid-19 test shall not be

mandatory before admitting elective and even emergency

patients by Government and Private Hospitals.

iv. Issue a writ in the nature of Mandamus or any other writ


Respondent for ensuring that Hospitals are not forcing

Frontline health worker to wear used PPE.

v. Issue a writ in the nature of Mandamus or any other writ


Respondent for ensuring that hospitals are not charging

high amount for PPE (beyond the actual cost) from

patients, shall charge reasonable.

vi. Pass any other appropriate Order or Direction as this

Hon’ble Court may deem fit.

Filed By

New Delhi




New Delhi-110001

Mob- +91-9958891040



DELHI





Versus


AFFIDAVIT

I Krishna Kr. Sharma S/o Sh. Sushil Kr. Sharma aged about 27

years having Office at Ch. No. 906, Patiala House Court Complex,

New Delhi- 110001 do hereby solemnly affirm and declare as

under:-

1. That I am the petitioner above named I have filed the present

petition as a Public Interest Litigation.

2. I have gone through the Delhi High Court (Public Interest

Litigation) Rules, 2010 (with all timely modification) and do

hereby affirm that the present Public Interest Litigation is in

conformity thereof.

3. I petitioner have/has no personal interest in the litigation and

neither myself nor anybody in whom I am/petitioner is

interested would in any manner benefit from the relief sought

in the present litigation save as member of General Public.

This petition is not guided by self-gain of any person,

institution, body and there is no motive other than of public

interest in filing this petition.

4. I have done whatsoever inquiry/investigation which was in

my power to do, to collect all data/material which was

available and which was relevant for this court to entertain

the present petition. I further confirm that I have not

concealed in. the present petition any data/

material/information which may have enabled this court to

form an opinion whether to entertain this petition or not

and/or whether to grant any relief or not.

5. That the contents of para ___ to ____ and grounds _____to

______ and prayer of the writ petition are drafted by me and

the same are true and to the personal knowledge of the

Deponent.

6. That the petitioner has not filed any other or similar petition

before this Hon’ble Court or before the Hon’ble Supreme

Court of India for seeking same relief.

DEPONENT

VERIFICATION

Verified at New Delhi on _________ that the contents of my

above affidavit are true and correct to my knowledge and

belief and nothing has been concealed therefrom.

DEPONENT


DELHI





Versus


APPLICATION UNDER SECTION 151 OF C.P.C FOR

SEEKING EXEMPTION FROM FILING CERTIFIED

COPIES, TRUE COPIES, TRUE TRANSLATED COPIES

WITH PROPER MARGINS OF THE ANNEXURES.

MOST RESPECTFULLY SHOWETH:

1. That the Petitioner has filed the accompanying writ

petition under article 226 Constitution of India r/w section

151 C.P.C.; for seeking directions.

2. That the Petitioner is unable to furnish the certified copies,

true copies, true translated copies, copies with proper

margins of the annexure at this stage due to paucity of

time and will submit the same before this Hon’ble Court

after obtaining the same in due course.

PRAYER

It is, therefore, most humbly and respectfully prayed that

filing of the certified copies, true copies, true translated

copies, copies with proper margins of the annexures may

very kindly be exempted in the interest of justice.

Filed by

New Delhi




New Delhi-110001

Mob- +91-9958891040



DELHI





Versus


AFFIDAVIT

I Krishna Kr. Sharma S/o Sh. Sushil Kr Sharma aged about 27 years

having Office at Ch. No. 906, Patiala House Court Complex, New

Delhi- 110001 do hereby solemnly affirm and declare as under:-

1. That I am the petitioner above named and conversant with the

facts and circumstances of the present case and as such

competent to swear the present affidavit.

2. That I say that the accompanying application under section

151 of the Code of Civil Procedure. 1908; has been drafted

me and nothing material has been concealed therefrom.

DEPONENT

VERIFICATION

Verified at New Delhi on ____________ that the contents of

my above Affidavit are true and correct to my knowledge and

belief and nothing material has been concealed therefrom.

DEPONENT


DELHI





Versus


INDEX

S.NO

PARTICULAR (S) PAGE NO.

1. Court Fees

A

2. Urgent Application

B

3. Notice of Motion

C

4. Synopsis & List of Dates

D – K

5. Memo of Parties

1 – 2

6. Civil Writ Petition along with affidavit

3 – 15

7. Application under section 151 C.P.C for

exemption from filing certified/true

typed/ with proper margins of the

annexure, along with affidavit in

support.

16 – 19

8 The copy of order dated 17.04.2020 and

multiple news article are annexed

herewith as Annexure A-1 and


20 - 40

9 The copy of the order-dated 24.04.2020


41 – 68

10 The copy of news article dated


Annexure A-4. and ICMR guidelines

dated 20.03.2020 is annexed herewith as


69 - 73



Annexure A-6.

74 - 76

12 The copy of order dated 30.04.2020 is


77 – 79



Annexure A-8.

80 – 83

14 The copy of News article dated 84 - 91


Annexure A-9.



Annexure A-10.

92 – 98



Annexure A-11.

99

17 VAKALATNAMA (Not Required as

Petition is being filed in person)

Filed By

New Delhi




New Delhi-110001

Mob- +91-9958891040


Documents

IN THE HON’BLE HIGH COURT OF DELHI, AT NEW DELHI · Krishna Kr. Sharma Petitioner Versus Govt. of NCT of Delhi Respondent COURT FEES Filed By New Delhi Dated 03.06.2020 Krishna