IN THE HIGH COURT OF DELHI AT NEW DELHI

WRIT PETITION (Crl.) OF 2019

IN THE MATTER OF:-

UMESH …PETITIONER

V/S

STATE OF N.C.T. OF DELHI & ANR ……RESPONDENTS

INDEX

SN PARTICULAR PAGES C.F

1. Letter of Motion

2. Urgent Application

3. Memo of Parties

4. List of Date and events

5. Caveat petition.

6. Annexure-A: Adhar Card of

petitioner with its true
type copy.

7. Vakalatnama

DATE …PETITIONER
DELHI THROUGH
JAVED AHMAD (ADVOCATE),
ENRL. NO. D/2417/2007, F-75,
KARKARDOOMA COURT, DELHI-
110032, M NO. 7906042692
 IN THE HIGH COURT OF DELHI AT NEW DELHI
WRIT PETITION (Crl.) OF 20____

IN THE MATTER OF:-

UMESH …PETITIONER

V/S

STATE OF N.C.T. OF DELHI & ANR

……RESPONDENTS

LETTER OF MOTION
To,

The Standing Counsel (Crl.)

Delhi High Court
At New Delhi
Sir,

This is to informed you that present Writ

petition (Crl.) is being filed by me in the

Hon'ble High Court of Delhi. Please receive the

copies of the petition for your records and the

petition is likely to be listed on

this Hon'ble High Court of Delhi, on which date

you may kindly be present in the court to assist

this Hon'ble Court.

DATE …PETITIONER

DELHI THROUGH

JAVED AHMAD (ADVOCATE),

ENRL. NO. D/2417/2007, F-75,
KARKARDOOMA COURT, DELHI-
110032, M NO. 7906042692
 IN THE HIGH COURT OF DELHI AT NEW DELHI
WRIT PETITION (Crl.) OF 2019

IN THE MATTER OF:-

UMESH …PETITIONER

V/S

STATE OF N.C.T. OF DELHI & ANR

……RESPONDENTS

URGENT APPLICATION

To,

The Registrar,

High Court of Delhi

At New Delhi.

Sir,

Kindly treat this petition on urgent basis

and list the same for hearing on

.The grounds of urgency is that the wife of the

petitioner is missing and her life might be in

danger.

DATE …PETITIONER
DELHI THROUGH
JAVED AHMAD (ADVOCATE),
ENRL. NO. D/2417/2007, F-75,
KARKARDOOMA COURT, DELHI-
110032, M NO. 7906042692
 IN THE HIGH COURT OF DELHI AT NEW DELHI

WRIT PETITION (Crl.) OF 2019

IN THE MATTER OF:-

UMESH …PETITIONER

V/S

STATE OF N.C.T. OF DELHI & ANR

……RESPONDENTS

MEMO OF PARTIES

UMESH

S/O: SH. MAHESH CHAND

R/O:- ANJALI VIHAR, LONI DEHAT,

LONI, GHAZIABAD,

UTTAR PRADESH-201001, …PETITIONER

VERSUS
1. THE STATE OF NCT OF DELHI

THROUGH ITS CHIEF SECRETARY

2. S.H.O.POLICE STATION,

PREM NAGAR, DELHI.

3. SUGREEV PRASAD

4. USHA DEVI W/O SUGREEV PRSAD

5. BITTOO S/O SUGREEV PRASAD

RESPONDENT NO. 3 TO 5 ALL R/O:

A-8/21, GALI NO.8, PREM NAGAR-3,

KIRARI SULEMAN NAGAR, DELHI,

NORTH-WEST DELHI,

DELHI 110086. ... RESPONDENTS

DATE …PETITIONER
DELHI THROUGH
JAVED AHMAD (ADVOCATE),
ENRL. NO. D/2417/2007, F-75,
KARKARDOOMA COURT, DELHI-
110032, M NO. 7906042692
 IN THE HIGH COURT OF DELHI AT NEW DELHI

WRIT PETITION (Crl.) OF 2019

IN THE MATTER OF:-

UMESH …PETITIONER

V/S

STATE OF N.C.T. OF DELHI & ANR

……RESPONDENTS

LIST OF DATES AND EVENTS

26.07.2019
The petitioner married with

his missing wife namely Smt.

Reema D/o: Sugreev Prasad

R/o: A-8/21, GALI NO.8, PREM

NAGAR-3,KIRARI SULEMAN NAGAR,

DELHI,NORTH-WEST DELHI, DELHI

110086.

26.07.2019 Father and brother in law of

the petitioner i.e.

respondent No.3 and

Respondent No.5 came to the

petitioner’s home and assured

that they wants to make the

marriage of the petitioner

 and missing wife of the

petitioner namely Reema

social and requested to send

the petitioner’s wife with

them and assured the

petitioner that after one

week the petitioner along

with his near and dear may

came to the house of the

respondent no. 3 to

respondent No.5 and they will

sent the petitioners wife

with him happily.

07.08.2019 That the petitioner was

unable to contact his wife in

any manner therefore he

approached to the respondent

No.3 to respondent no.5 for

send the petitioner’s wife

with him but the respondents

no.3 to 5 flatly refused to

sent the petitioner’s wife

with the petitioner and

extend threat for face dire

consequences to the
 petitioner, and allowed to

meet the petitioner with his

missing wife, that the

petitioner on inquiry from

the local persons came to

know that the wife of the

petitioner has been detained

in a room forcefully.

07.08.2019 Petitioner meet with police

officials of P.S Prem Nagar

who assured to help the

petitioner and also make D.D.

Entry of the complaint of the

petitioner.

11.08.2019 The police officials refused

to help the petitioner for

search the missing wife of

the petitioner.

13.08.2019 That finding no other

alternate to get his missing

wife back the petitioner file

the present petition before

this hon’ble court.

30.08.2019 This hon’ble court allowed

 w.p. crl. Of the petitioner.

27.12.2019 Petitioner have apprehension

of any illegal activity by

the respondents no. 3 etc.

DATE …PETITIONER

DELHI THROUGH

JAVED AHMAD (ADVOCATE)

ENRL. NO. D/2417/2007,

F-75, F BLOCK FIRST FLOOR

KARKARDOOMA COURT, DELHI

MOBILE NO. 7906042692

 IN THE HIGH COURT OF DELHI AT NEW DELHI

Original /Appellate Criminal Jurisdiction Caveat

No.____________ of 20____

IN

WRIT PETITION (Crl.) 2272 OF 2019

IN THE MATTER OF:-

UMESH …PETITIONER

V/S

STATE OF N.C.T. OF DELHI & ANR

……RESPONDENTS

To,

THE REGISTRAR,

DELHI HIGH COURT, NEW DELHI

Let no order regarding protection and criminal

case against the petitioner and his wife be made
in the above matter without notice to the
undersigned.

DATE …PETITIONER

DELHI THROUGH

JAVED AHMAD (ADVOCATE),

ENRL. NO. D/2417/2007, F-75,
KARKARDOOMA COURT, DELHI-
110032, M NO. 7906042692