IN THE HON'BLE HIGH COURT OF JUDICATURE AT ALLAHABAD
**************************
DATES AND EVENTS
IN
CIVIL MISC. WRIT PETITION (PIL) NO. OF 2013
(Under Article 226 of the Constitution of India)
(DISTRICT – GHAZIABAD)
People’s Vigilance Committee for Human Right
(PVCHR)& Ors. ----------- Petitioner.
VERSUS
State of U.P. and Ors. -----------Respondents.
(Jauhar Adeeb)(K.K.Roy)(Vishal Kashyap)
ADVOCATES, ADVOCATES ROLL : A/J ,A/K0040,A/V0830,
COUNSELS FOR THE PETITIONER, LAWYERS CHAMBER NO. 122,
HIGH COURT, ALLAHABAD, DATE : .12.2013 MOB.: 7505442158.
IN THE HON'BLE HIGH COURT OF JUDICATURE AT ALLAHABAD
**************************
CIVIL MISC. STAY APPLICATION NO. OF 2013
(Under Chapter XXII Rule 1 of High Court Rules)
ON BEHALF OF
People's Union for Civil Liberties.
----------- Applicant
IN CIVIL MISC. WRIT PETITION (PIL) NO. OF 2013 (Under Article 226 of the Constitution of India)
( DISTRICT – GHAZIABAD )
People’s Vigilance Committee for Human Right (PVCHR),
Through its President Lenin Raghuvanshi, R/o S-A 4/2A, Daulatpur,
Varanasi. -------- Petitioner
VERSUS
1. State of U.P.,
Through Principal Secretary (Home)
U.P., Lucknow.
2. Director General of Police,
U.P. Lucknow.
3. State Human Right Commission,
Through its Secretary,
4/44, Vishal Khand, Gomti Nagar,
Lucknow.
4. Superintendent of Police,
Ghazipur.
5. Station House Officer,
Police Station Dildar Nagar,
District Ghazipur.
6. Shyam Babu,
S.H.O., Police Station Dildar Nagar,
District Ghazipur.
-------- Respondents
To, The Hon’ble The Chief Justice and his other
Companion Judge of the aforesaid Hon’ble Court.
The humble application of the abovenamed
applicants Most Respectfully Showeth as under:-
1. That full facts, reasons and circumstances
have been disclosed in the accompanying writ
petition for the kind perusal and
consideration of this Hon'ble Court.
2. That in view of the facts and circumstances
stated in the accompanied writ petition, it
is, therefore, expedient in the interest of
justice that this Hon'ble Court may graciously
be pleased to direct the State Human Right
Commission to appoint an enquiry committee
headed by one of its Member under the
monitoring of the Hon'ble High Court of
custodial torture and death of Shakeel, S/o
Khalil Ahmad, R/o Ward No. 2, Yaseen Garhi,
Dasna, Police Station Kavi Nagar, District
Ghaziabad by the police of Police Station Kavi
Nagar, District Ghaziabad and submit its
report before this Hon’ble Court in a
stipulated time, otherwise the petitioners
shall suffer an irreparable loss and injury.
P R A Y E R
It is, therefore, Most Respectfully Prayed
that this Hon’ble Court may graciously be pleased
to direct the State Human Right Commission to
appoint an enquiry committee headed by one of its
Member under the monitoring of the Hon'ble High
Court of custodial torture and death of Shakeel,
S/o Khalil Ahmad, R/o Ward No. 2, Yaseen Garhi,
Dasna, Police Station Kavi Nagar, District
Ghaziabad by the police of Police Station Kavi
Nagar, District Ghaziabad and submit its report
before this Hon’ble Court in a stipulated time,
otherwise the applicant/petitioner shall suffer an
irreparable loss and injury.
And/or to pass such other and further order
which this Hon’ble Court may deem fit and proper
in the circumstances of the case.
(Jauhar Adeeb)(K.K.Roy)(Vishal Kashyap) ADVOCATES,
ADVOCATES ROLL : A/J ,A/K0040,A/V0830, COUNSELS FOR APPLICANT/PETITIONER,
LAWYERS CHAMBER NO. 122, HIGH COURT, ALLAHABAD,
DATE : .12.2013 MOB.: 7505442158.
IN THE HON’BLE HIGH COURT OF JUDICATURE AT ALLAHABAD
*************************
CIVIL MISC. WRIT PETITION (PIL) NO. OF 2013
(Under Article 226 of the Constitution of India)
( DISTRICT – GHAZIABAD )
People’s Vigilance Committee for Human Right (PVCHR),
Through its President Lenin Raghuvanshi, R/o S-A 4/2A, Daulatpur,
Varanasi. -------- Petitioner
VERSUS
1. State of U.P.,
Through Principal Secretary (Home)
U.P., Lucknow.
2. Director General of Police,
U.P. Lucknow.
3. State Human Right Commission,
Through its Secretary,
4/44, Vishal Khand, Gomti Nagar,
Lucknow.
4. Superintendent of Police,
Ghazipur.
5. Station House Officer,
Police Station Dildar Nagar,
District Ghazipur.
6. Shyam Babu,
S.H.O., Police Station Dildar Nagar,
District Ghazipur.
-------- Respondents
To,
The Hon’ble the Chief Justice and his other
companion Judges of the aforesaid Court.
The humble petition of the above named
petitioners Most Respectfully Showeth as under:-
1. That this is the first writ petition (Public
Interest Litigation) filed by the petitioners
before this Hon'ble Court and no other writ
petition has been filed with the same cause of
action.
2. That the petitioners further declare that they
have not received any copy of the caveat
application till date.
3. That this Public Interest Litigation relates
to worst crime of society governed by rule of
law called as custodial death of Shakeel, S/o
Khalil Ahmad, R/o Ward No. 2, Yaseen Garhi,
Dasna, Police Station Kavi Nagar, District
Ghaziabad.
4. That the Petitioner’s organization is a
registered organization who is working in the
State of Uttar Pradesh for the preservation,
protection and promotion of Human Rights and
specially for the rights of those peoples who
were subjected to cruel discrimination for the
centuries due to social backwardness and in
economic disparity.
5. That Petitioner’s organization is actively
involved in awareness building among the poor
people to communicate their rights which has
been guaranteed by the Constitution of India
regarding equality, dignity and protection of
their rights.
6. That the Petitioner’s organization has a
constructive and creative outlook towards the
human problem and it is specially engaged in
work for the upliftment of the conditions of
the women, children, dalits, tribals and
minorities.
7. That the Petitioner’s organization is totally
committed to the high and noble ideas of the
Constitution of the country which is based on
the equal protection of law to every citizen
and every person.
8. That the Petitioner’s organization has already
filed several Public Interest Litigations in
the High Court of social importance which is
pending before the Court.
9. That the Petitioner’s organization has filed
Public Interest Litigation No. 42247 of 2013
(People’s Vigilance Committee for Human Right
Vs. State of U.P. & others) for the
educational rights of the children of the
women prisoners languishing in jails of Uttar
Pradesh.
10. That the Petitioner’s organization has filed
Public Interest Litigation No. 54998 of 2013
(People’s Vigilance Committee for Human Right
Vs. State of U.P. & others) for the effective
functioning of the State Human Rights
Commission.
11. That the Petitioner’s organization has filed
Public Interest Litigation No. 52813 of 2013
(People’s Vigilance Committee for Human Right
Vs. Union of India & others) about the
implementation of the a MNREGA programme and
investigation of corruption in it.
12. That the Petitioner’s organization was
contacted by some human rights activists of
the Ghaziabad city in regard to a custodial
death which happened in the month of June,
2013.
13. That a team of the Petitioner’s organization
reached Ghaziabad and collected some materials
which is the proof of the most inhuman crime
committed by the police who was set to the
custodial of law.
14. That according to the facts gathered by the
Petitioner’s organization, on 13.06.2013 a
police party with Station House Officer, Kavi
Nagar Sudhir Tyagi went to the house of Khalil
Ahmad and enquired about a person named
Shakeel who was the neighbor of the Khalil
Ahmad.
15. That incidentally, the name of the son of the
Khalil Ahmad is also Shakeel.
16. That to help the police party, when Khalil
Ahmad went to the house of the Shakeel, he
found Shakeel absent and informed it to the
police.
17. That the police party held some discussion
within themselves and took Shakeel who is son
of Khalil Ahmad to the Police Station.
18. That Khalil Ahmad tried to persuade the police
party that the person whom you are taking to
the Police Station is my son and he is not
that Shakeel wanted by him.
19. That police party under Shudhir Tyagi, Station
House Officer, Kavi Nagar told Khalil Ahmad
that they will make some query in the Police
Station and then set him free.
20. That after some hours, when father of the
Shakeel went to the Police Station, he saw 3-4
Policemen bitterly beating him and torturing
him.
21. That when Khalil Ahmad tried and pleaded to
release his son who was the object of torture
by the police personnel, he was asked to
arrange Rs. 80,000/- for his release.
22. That being a lower middle class person, Khalil
Ahmad was not in a position to arrange that
huge amount.
23. That Shakeel was kept in the Police Station
for two days without any First Information
Report or warrant in a severely injured
position.
24. That on 15.06.2013, in the morning, the
Shakeel died in the police custody in the
Police Station Kavi Nagar, District Ghaziabad
due to custodial and third degree torture.
25. That Shakeel was neither wanted in a case nor
there was any First Information Report pending
against him.
26. That on 15.06.2013 itself Khalil Ahmad made an
application before the Station House Officer,
Police Station Kavi Nagar narrating the entire
story of the custodial torture and killing of
his son Shakeel. A photocopy of the complaint
of the Khalil Ahmad dated 15.06.2013 moved
before the Station House Officer, Police
Station Kavi Nagar is being filed herewith and
marked as Annexure No. 1 to this Writ
Petition.
27. That according to the contents of the
application of Khalil Ahmad, Station House
Officer Sudhir Tyagi was accompanied by Mangal
Tyagi, Bhupendra, Hom Singh (Dhoom Singh),
Jitendra, Raj Kumar amr Tyagi, Irfan and
Ravindra who were constables in the same
Police Station.
28. That the matter was flashed in the newspaper
about the custodial torture of an innocent
youth by the police of Kavi Nagar Police
Station.
29. That there was a massive protest by the people
of all sects against the third degree torture
and custodial killing of Shakeel who was
neither a criminal nor a wanted law breaker.
30. That after much pressure and persuasion, First
Information Report was lodged in Case Crime
No. 631/2013, U/s 147, 148, 302, 342 & 406
I.P.C. at Police Station Kavi Nagar, District
Ghaziabad on 15.06.2013. A true and typed copy
of the First Information Report dated
15.06.2013 alongwith the details of the
accused is being filed herewith and marked as
Annexure No. 2 to this Writ Petition.
31. That custodial torture is not only naked
violation of human dignity but it is also an
assault civilized society.
32. That the death of Shakeel due to dehumanizing
torture and custodial violence in Kavi Nagar
Police Station raises a finger over the rule
of law in State of U.P.
33. That the incident of the custodial death of
Shakeel is flagrant violation of Article 21 of
the Constitution of India which envisages that
no person shall be deprived of his life and
liberty except accordance with the procedure
established by law.
34. That the recommendation of the National
Human Right Commission was fully and
consciously ignored and over looked.
35. That custodial violence including torture
and death in the lock ups strike a blow at
the rule of law. It is committed by the
person who are supposed to be the protectors
of the citizens. It is committed under the
shield of uniform and authority where the
victims are totally helpless.
36. That in all custodial crimes, what is of
real concern is not only the infliction of
body pain but the mental agony which the
person undergoes within the four wall of
police station or lock-up.
37. That custodial violence is one of the worst
crime in a civilised society governed by
rule of law.
38. That it is clear and emerging principle of
human rights jurisprudence that the State is
responsible not only for the acts of its own
agents, but also for the acts of non-State
players acting within its jurisdiction. The
State is, in addition, responsible for any
inaction that may cause or facilitate the
violation of human rights.
39. That the protection of individual from
oppression and abuse by the police and other
enforcing officer is a major interest in a
free society. Arrest and detention with
violence can cause incalculable harm to the
reputation and self esteem of the person.
40. That torturing a person and using third
degree method are of medieval nature and
they are barbaric and contrary to law.
41. That it may be a legitimate right of any
police officer to interrogate or arrest any
suspect on some credible material but
interrogation does not mean inflicting
injuries.
42. That the Law Commission in its 113th report
recommended that in prosecution of the
police officer, for an alleged offence of
having caused bodily injury to a person,
during the period when the person was in the
custody of police, the court may presume
that the injury was caused by the police
officer having the custody of that person
during that period.
43. That the third report of the National Public
Commission in India expressed its deep
concern with custodial violence and lock up
deaths and made useful suggest of arresting
only in grave offence. The report said that
nearly 60% of the arrests are either
unnecessary or unjustified.
44. That the 4th report of The National Police
Commission, also noticed the prevalence of
custodial torture and deserved that nothing
is so dehumanizing as the conduct of police
in practicing torture of any kind on a
person in their custody.
45. That Article 9(5) of the International
Covenant of Civil and Political Rights, 1966
(ICCPQ) that any one who has been the victim
of unlawful arrest or detention shall have
the enforceable right to compensation.
46. That a scanning of successive reports of
National Human Right Commission would show
that the Uttar Pradesh has been the highest
violator of human right in the whole
country.
47. That for the kind's perusals of Hon'ble
Court some of the details of Human Right
violation are given below.
48. That a chart, diagram of registered case's
during the year from all state in 2000,
2001, 2002, 2004 before National Human Right
Commission would show that U.P. is on the
top of the list.
49. That in annual report of the 2000, 2001,
published by National Human Right Commission
the total case's of human right violation
registered is 70,510 out of which Uttar
Pradesh sitting of top has the credit of
registering 40312, case's next to Bihar with
4113, and Delhi with 4047 case's.
50. That in annual report of the 2001-2002,
published by National Human Right
Commission, the total cases of human right
violation registered is 83695, out of which
Uttar Pradesh sitting of top has the credit
of registering 47445, cases next is Bihar
with 5340, and Delhi with 3540 cases.
51. That a news item was published in Amar
Ujala, a esteemed Hindi Daily, Kanpur
Edition on 30.12.2010 with the heading that
U.P. tops in human right violation matter.
The news is based on report of the National
Human Right Commission and it contains that
in year 2010, total 84223 cases of human
right violation received in the office of
National Human Right Commission, out of
which 48000 cases came from Uttar Pradesh.
The National Human Right Commission report
further reveals that 18068 cases of police
atrocities were reported from Uttar Pradesh
alongwith 14 custodial deaths in jail. That
in annual report of 2002-2003, the total
registered cases has been 68779, the cases
of Uttar Pradesh is 40839, next to it is
Bihar with 4189, then Delhi with 3834.
52. That in year 2003-2004, the total cases
registered with at National Human Right
Commission is 71727, out of which Uttar
Pradesh standing of top has the credit of
40396, cases Bihar second with 4392 cases.
53. That in the matter of custodial death/rape
recorded the National Human Right Commission
1993-1994, with 34 custodial death / rape,
the Uttar Pradesh stand on top. In 1994–1995
Uttar Pradesh fared will with total sixty
eight out of 171 custodial death/rape in
country, Delhi with 38, Assam with 18, Bihar
with 17, West Bengal 15, Punjab 12,
Rajasthan 10, were higher than Uttar
Pradesh. In 1995-1996, out of 444 custodial
deaths/rapes Uttar Pradesh has 37 among the
top six with Bihar 75, Andhra Pradesh 55,
Delhi 40, Maharashtra 34, and West Bengal
51.
54. That in 1997-1998 out of total 999 custodial
deaths/rapes Uttar Pradesh again come on top
with 186 deaths with Madhya Pradesh 133.
Bihar 117, Andhra Pradesh 74, Karnataka 40,
Tamilnadu 67 custodial deaths/rapes.
55. That in 1998-1999 out of total 1286
custodial deaths/rapes in the country, Uttar
Pradesh having 243, Bihar 192, Andhra
Pradesh 121, Madhya Pradesh 118, and
Maharashtra 118, keeps Uttar Pradesh on top.
56. That in 1999-2000 out of total 1093
custodial deaths/rapes Uttar Pradesh having
159, Bihar 162, Assam 162, Andhra Pradesh
64121, and Maharashtra 118.
57. That in 2000-2001, out of total 1037 cases
custodial death/rape Uttar Pradesh with 131
in just below Bihar 139 then Maharashtra 123
and Andhra Pradesh 78.
58. That the from 1993-1994 up to 2000-2001 the
total registered cases custodial death/rape
from the whole of the country has been 5951
with Uttar Pradesh on top with 940 cases
thereafter Bihar with 799, Andhra Pradesh
with 515, Madhya Pradesh with 333 and West
Bengal with 222 cases, these are the cases
reposted before National Human Right
Commission. A photocopies of the different
datas narrated above is being filed herewith
and marked as ANNEXURE NO. 3 to this writ
petition.
59. That the grim human right situation of Uttar
Pradesh could not escape the attention of
the judicial scrutiny time and again. The
need of formation of Human Right Commission
was felt and three mandamus judgments were
issue to form it.
60. That all these data has been taken from the
reports and annual reports published by the
National Human Right Commission.
61. That on 14.12.1993, the Secretary General of
the National Human Right Commission sent a
letter to all the Chief Secretaries on the
reporting of the custodial deaths within 24
hours of its happening to the office of the
National Human Right Commission and it has
requested the Chief Secretaries that in view
of the rising number of incidents and
reported attempt, to suppress or present a
different picture of this incidents of
custodial deaths and custodial rapes. A
direction should be issued to the District
Magistrates and Superintendents of police of
every districts that they should report to
the Secretary General of the Commission of
such incident within 24 hours of occurrence.
Failure would give rise to the presumption
that there was an attempt to suppress the
incident. A photocopy of the letter dated
14.12.1993 issued by the National Human
Right Commission to the Chief Secretary of
all States is being filed herewith and
marked as ANNEXURE NO. 4 to this writ
petition.
62. That thereafter on 21.06.1995, the Secretary
General of National Human Right Commission
wrote letter to the Chief Secretaries of all
States and Union territories that the
Commission be informed regarding all deaths
in judicial custody also and it should be
reported to Commission within 24 hours of
its occurrence. A photocopy of the letter
dated 21.06.1995 issued by the National
Human Right Commission to the Chief
Secretary of all States is being filed
herewith and marked as ANNEXURE NO. 5 to
this writ petition.
63. That again on 01.01.2000, the Chairperson of
the National Human Right Commission who also
happens to be the Former Chief Justice of
India, circulated a letter to the Chief
Justices of all High Courts with regard to
human rights in prison and requested the
Hon'ble Chief Justices to give appropriate
instructions to the District and Session
Judges to take necessary steps to resolve
the acute problem which has the impact of
violating a human right which is given the
status of constitutional guarantee. In
this letter the Chairman of the National
Human Right Commission expressed his
dissatisfaction to the fact that Session
Judges are not regular in visiting prisons
and the District Committee is not meeting at
regular intervals to review the conditions
of the prisoners. A photocopy of the letter
dated 01.01.2000 issued by the Chairman of
the National Human Right Commission is being
filed herewith and marked as ANNEXURE NO. 6
to this writ petition.
64. That protection of Human Rights Act was
elected in 1993 with the laudable object of
protecting and preserving the Human Rights.
65. That State Human Right Commission in Uttar
Pradesh has been formed in terms of Section
21 of the Protection of Human Rights Act.
66. That under Section 12 of the Protection of
Human Rights Act, the Commission shall
perform duty including enquiry, suo-moto or
on a petition presented to it by a victim or
any person into complaint of Violation of
Human Right.
67. That under section 17 of the Protection of
Human Rights Act, the commission is empower
to enquire into the complaints of violations
of human rights.
68. That it is the duty and obligation of the
State Human Right Commission to enquire into
the matter of custodial death which is worst
form of the human right violation.
69. That for the reasons stated above, it is,
therefore, expedient in the interest of
justice that this Hon'ble High Court may
graciously be pleased to direct the State
Human Right Commission to appoint an enquiry
committee headed by one of its Member under
the monitoring of the Hon'ble High Court of
custodial torture and death of Shakeel, S/o
Khalil Ahmad, R/o Ward No. 2, Yaseen Garhi,
Dasna, Police Station Kavi Nagar, District
Ghaziabad by the police of Police Station Kavi
Nagar, District Ghaziabad and submit its
report before this Hon’ble Court in a
stipulated time, otherwise the petitioner
shall suffer an irreparable loss and injury.
70. That petitioner is advised to state that he
has no other alternative and efficacious
remedy than to approach this Hon'ble High
Court in its extra ordinary jurisdiction under
Article 226 of Constitution of India on
following amongst other grounds.
GROUNDS
i. Because, ii. Because,
P R A Y E R
It is, therefore, Most Respectfully Prayed
that this Hon’ble Court may be pleased to:-
(i) issue a writ, order or direction in the
nature of MANDAMUS commanding the State
Human Right Commission to appoint an
enquiry into the matter of the custodial
torture and death of Shakeel, S/o Khalil
Ahmad, R/o Ward No. 2, Yaseen Garhi, Dasna,
Police Station Kavi Nagar, District
Ghaziabad by the police of Police Station
Kavi Nagar, District Ghaziabad and other
constables in Police Station Kavi Nagar
U/s 17 of Protection of Human Right Act,
1993 and submit its report before this
Hon'ble Court in stipulated time.
(ii) issue a writ, order or direction in the
nature of MANDAMUS directing an
independent, impartial enquiry to be
conducted by any retired District Judge
of the State for submitting its report
before the Court in a stipulated time.
(iii) issue a writ, order or direction in the
nature of MANDAMUS commanding the
Respondent No. 1 & 2 to furnish the
record all custodial torture, custodial
death and custodial rape in Police
Stations, Police Lines and Police
Outposts, Lock-ups in Uttar Pradesh for
the last one year.
(iv) issue a writ, order or direction in the
nature of MANDAMUS commanding the
Respondent No. 1 to pay adequate
compensation to the family members of the
deceased Shakeel, S/o Khalil Ahmad, R/o
Ward No. 2, Yaseen Garhi, Dasna, Police
Station Kavi Nagar, District Ghaziabad.
(v) issue a writ, order or direction in the
nature of MANDAMUS commanding the
respondents to initiate the departmental
and disciplinary proceeding against the
police personnel of Police Station Kavi
Nagar, District Ghaziabad who are
responsible for the custodial death of
Shakeel.
(vi) issue a writ, order or direction which
this Hon'ble Court may deem fit and
proper under the facts and circumstances
of the case.
(vii) award the cost of the petition to the
petitioner.
(Jauhar Adeeb)(K.K.Roy)(Vishal Kashyap) ADVOCATES,
ADVOCATES ROLL : A/J ,A/K0040,A/V0830, COUNSELS FOR THE PETITIONER,
LAWYERS CHAMBER NO. 122, HIGH COURT, ALLAHABAD,
DATE : .12.2013 MOB.: 7505442158.
IN THE HON’BLE HIGH COURT OF JUDICATURE AT ALLAHABAD
********************
AFFIDAVIT
IN
CIVIL MISC. WRIT PETITION (PIL) NO. OF 2013
(Under Article 226 of the Constitution of India)
(DISTRICT – GHAZIABAD)
People’s Vigilance Committee for Human Right
(PVCHR)& Ors. ----------- Petitioner.
VERSUS
State of U.P. and Ors. -----------Respondents.
Affidavit of : Lenin Raghuvanshi,
Aged about 48 years, Son of Shri
Surendra Nath Singh, President of
People’s Vigilance Committee for
Human Right (PVCHR) Organization,
Resident of S-A 4/2A, Daulatpur,
Varanasi. Hindu by religion,
Occupation : Social Worker.
(Deponent)
I, the deponent above named do hereby solemnly
affirm and state on oath as under:-
1. That the deponent is the President of the
Petitioner’s organization in the aforesaid
writ petition and as such he is fully
acquainted with the facts of the case
deposed to below.
I, the deponent above named do hereby swear
that the contents of para 1 of this affidavit and
contents of paras ....................... ........
........... of the writ petition are true to my
personal knowledge, those of paras ............
...... .......... of the writ petition are based
on perusal of records and those of paras .......
........ of the writ petition are based on legal
advice, that no part of it is false and nothing
material has been concealed.
SO HELP ME GOD
DEPONENT
I, Vishal Kashyap, Advocate, Enrollment No.
UP-05363/12 do hereby declare that the person
making this affidavit and alleging himself to be
the deponent is known to me from perusal of
papers, produced by him in this case and I am
satisfied that he is the same person.
ADVOCATE
Solemnly affirmed before me on this day of
December’2013 at a.m./pm by the deponent who
has been identified by the aforesaid person.
I have satisfied myself by examining the
deponent that he has understood the contents of
this affidavit as well as the contents of
accompanying writ petition which have been
explained to him.
OATH COMMISSIONER
IN THE HIGH COURT OF JUDICATURE AT ALLAHABAD
********************
ANNEXURE NO. ( 1 )
IN
CIVIL MISC. WRIT PETITION (PIL) NO. OF 2013
(Under Article 226 of the Constitution of India)
(DISTRICT – GHAZIABAD)
People’s Vigilance Committee for Human Right
(PVCHR)& Ors. ----------- Petitioner.
VERSUS
State of U.P. and Ors. -----------Respondents.
********************
IN THE HON'BLE HIGH COURT OF JUDICATURE AT ALLAHABAD **************************
INDEX
IN
CIVIL MISC. WRIT PETITION (PIL) NO. OF 2013
(Under Article 226 of the Constitution of India)
(DISTRICT – GHAZIABAD)
People’s Vigilance Committee for Human Right
(PVCHR)& Ors. ----------- Petitioner.
VERSUS
State of U.P. and Ors. -----------Respondents.
S.No. Particular Date Annex Page No.
1. Dates and Events
2.
Civil Misc. Stay
Application U/C XXII Rule
1 of High Court Rules.
3.
Civil Misc. Writ Petition
U/A 226 of Constitution of
India.
4.
Photocopy of the complaint of the Khalil Ahmad moved before the Station House Officer, Police Station Kavi Nagar.
15.06.2013 1
5.
True and typed copy of the First Information Report alongwith the details of the accused.
15.06.2013 2
6. Photocopies of the
different datas. 3
7. Photocopy of the letter
issued by the National 14.12.1993 4
Human Right Commission to
the Chief Secretary of all
States.
8.
Photocopy of the letter
issued by the National
Human Right Commission to
the Chief Secretary of all
States.
21.06.1995 5
9.
Photocopy of the letter
issued by the Chairman of
the National Human Right
Commission.
01.01.2000 6
10. Affidavit in support of
the Writ Petition.
11. Proof of identification of
the deponent.
12. Vakalatnama
(Jauhar Adeeb)(K.K.Roy)(Vishal Kashyap) ADVOCATES,
ADVOCATES ROLL : A/J ,A/K0040,A/V0830, COUNSELS FOR THE PETITIONER,
LAWYERS CHAMBER NO. 122, HIGH COURT, ALLAHABAD,
DATE : .12.2013 MOB.: 7505442158.