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8/22/2019 PIL on Delhi Gang Rape Case
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IN THE SUPREME COURT OF INDIACIVIL ORIGINAL JURISDICTION
I. A. NO. OF 2012
IN
WRIT PETITION (CIVIL) NO. OF 2012
In the matter of :-
Nipun Saxena & Anr. Petitioners
VERSUS
Union of India & ors. Respondents.
AN APPLICATION FOR PERMISSION TO APPEARAND ARGUE AS PETITIONER IN PERSON UNDER ORDER
XLVII OF SUPRME COURT RULES, 1966.
TO,
THE HON'BLE CHIEF JUSTICE OF INDIAAND HIS COMPANION JUSTICES OF THEHON'BLE SUPREME COURT OF INDIA
THE HUMBLE PETITION OF THEPETITIONERS ABOVE-NAMED
MOST RESPECTFULLY SHOWETH :
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SYNOPSIS & LIST OF DATES
The petitioner no.2 is public spirited upcoming lawyer
and petitioner no.1 is likewise fourth year law student of
National Law University, Delhi concerned with the rising
rate of crime namely rape of innocent women all over the
country. All the measures taken in this regard proved to
be ineffective till date and hence the need of fresh
innovative measures to check this menace. The first such
measure should be that all public and transport vehicle
should be fitted with GPS system and high security
registration plate with maintenance of log book of all the
destinations covered by such vehicles. All such vehicles
should carry the names and telephone numbers of theowners, drivers, conductors, cleaners in large size on the
back side of the vehicles. The second such measures is
that the Government should give encouragement to
employ more and more women as bus driver/bus
conductor and also to start taxi/auto service with women
under wheels so that women will have the option to
choose the transport of their choice.
The third such measure is to allot booths/small shops
and the bus stand/railway station/ shopping malls and
all along the major roads in the city to the women who
had earlier Police/ Army/Para-military background to
boost the confidence of the women.
The fourth such measures is to revive the system of
appointment of Honorary magistrate from the people of
repute to check the functioning of proper transport
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system and also to give the power and jurisdiction to
them to issue challans etc in the event of finding
violations of rules on the road. It has been seen in
practice in the past or all over India that there is no
complaint of sexual harassment from the petrol pumps/
food joints or take away zones/taxi/autos mend by the
women.
The fifth such measure should be a direction/suggestion
to the ministry of women and child welfare development
to encourage the participation of elderly people like
grandparents, in the families of those where both the
parents are working employees.
The sixth such measure is a direction/suggestion to the
ministry of home affairs and its police department to
revive the age old practices of beat constables which has
recently been substituted by patrolling by the police
vehicles( Mobile PCR) for the reason that the beat
constables are more effecting in gathering the
intelligence/inputs of bad characters of the area andchecking them in their ulterior motive and to boost
confidence among the masses about the law and order
situation.
Simple measures by the centre and the state government
can help us to contain the crime in general and heinous
crime of rape, robbery and murder in particular.The petitioner is constrained to file the writ petition
under Article 32 read with Article 14, 16(1) and 21 of the
Constitution of India as the Right to Dignity is severely
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threatened and also the right to protection if the same is
jeopardized.
The recent atrocity committed on 16th December, 2012
in Delhi where a girl aged 23 years was gang raped and
other instances of similar offence have led the Petitioner
to file the instant petition. The gruesome and heinous
manner in which the said crime was perpetrated has led
to the advancement of the instant petition wherein the
girl was brutally attacked with a blunt object and had
allegedly been raped thereafter.
The petitioner respectfully submits that four prominent
issues are critical to the instant case:
Firstly, the operation of private buses, especially those in
the nature of bearing an interstate license and their
travelling in late hours of the night, in and around
National Capital Region, poses a serious threat to the
safety and security of the travelers especially women and
female children, who equate them with the DelhiTransport Commission approved buses and board them
thereby putting their lives in great danger.
The Delhi Motor Vehicles Rules, 1993 provide for three
types of permit requirements, those which are DTC
CNG Stage and Contract Carriage Buses, Private CNG
Stage Carriage Buses, and Private CNG Contract Carriage
Buses under Rule 71 A, B and C respectively.
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Rule 48 defines the functioning of the State Transport
Authority which is endowed with the task of granting/
revoking/ cancelling the permits of a vehicle under Rule
61 which is read with Section 86 of the Motor Vehicles
Act, 1988, the authority being vested in the Secretary,
State Transport Authority or any person delegated in that
respect. In addition to such safeguards, Rule 95A furtherlays down special guidelines for educational institutional
buses and omnibus transport vehicle carrying school
children.
However the plight of such operations is that private
buses usually act in contravention of Section 84 of the
MV Act, which inter alia provides for the identity of the
bus operators to be painted in a legible form, in addition
to the stricture imposed on driving beyond the daily duty
hours, or after the course of employment. The
implementation of the said provisions and ensuring their
compliance is a grave hurdle, from which the drivers and
other agents reap benefit. With a heavy dependence on
Transport Buses by over 70 % of the total population of
Delhi, the risk to their life and security becomes
unimaginable, especially in the wake of the recent
egregious and unfortunate event.
The Drivers and other operational staff of private buses,
with an intention of making additional profits carry out
trips in the areas, beyond their scope of employment, and
commit felonies of the nature that have been referred to
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above. With a burgeoning number of private buses, the
investigation, periodic review of the antecedents of the
drivers and other operators becomes difficult for the
State enforcement agencies to keep under its supervision.
The Honble High Court of Delhi in the case of Court on
its own motion v Union of India and Others. in W.P. (c)
No. 16565 / 2006 has also underscored the importance
of the said problem by giving directions to the State
Transport Authority to make appointments of the drivers
on the basis of minimum 10 +2 qualification so as to
condition a better and responsible behavior towards their
passengers. Another reason for a genuine identification
requirement stems from the fact that the licenses arebeing sold and the buses are being operated by the
persons other than the persons, who were awarded the
license as the licenses are being sold by indirect process
after taking huge money.
This leads to a greater mental assurance to the
perpetrator while giving effect to crimes as heinous as
rape. The untracebility of the said offenders who hold
interstate permits and move freely into other states
further exacerbates the procedure for conducting
investigation. It is therefore quintessential and urgent
that owing to such a humungous number of private
buses operating without valid licenses or under sold
identities, should be brought to book, and immediate
action should be initiated against the perpetrators by
cancellation/ revocation of their licenses in addition to
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booking them under other offences embedded in the
Motor Vehicles Act, 1988 or Indian Penal Code, 1860. In
pursuance thereof, it is most humbly requested before
this Honble Court, to direct the State Transport
Authority and the Police agencies to immediately cancel
and revoke the licenses and permits of the buses which
operate at odd timings and conduct their businesswithout the authority of law.
Secondly, It is further most humbly submitted before this
Honble Court that keeping in view of the dispensing
mechanism of the Criminal justice delivery system, there
is a compelling need for the establishment of a formalcompensatory mechanism for victims called the Criminal
Injuries Compensation Board (hereinafter referred to as
CICB) which provides for instantaneous and expeditious
monetary relief to the victim(s) of gruesome offences such
as rape. The case of Rudul Sah v State of Bihar, (1983) 4
SCC 141 and the case of Peoples' Union for Democratic
Rights (through its Secretary and Anr.) v. Police
Commissioner, Delhi Police HQs. and Anr. (1989) 4 SCC
730 stand as a testimony to the veracity of expansion of
right to life under Article 21. It has also been held by this
Honble Court that Right to a dignified life is inherent to
the very right enshrined under Article 21. Heinous
offences such as Rape are an egregious violation of this
Right to Life. It is therefore essential that there are
additional safeguards to ensure that the sufferers of such
traumatic offence are not subjected to post traumatic
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mental agony. It destroys the entire psychology of a
woman and pushes her into deep emotional crises. It is
only by her sheer will power that she rehabilitates herself
in the society which, on coming to know of the rape,
looks down upon her in derision and contempt. Rape is,
therefore, the most hated crime. It is a crime against
basic human rights and is also violative of the victim'smost cherished of the Fundamental Rights, namely, the
Right to Life contained in Article 21.
This Honble Court has in the causa celebre of Delhi
Domestic Working Womens Forum v. Union of India and
Others., (1995) 1 SCC 14, categorically laid down that for
offences as deplorable as Rape, a Criminal InjuriesCompensation Board should be established in addition to
the already contained provisions embedded within the
Code of Criminal Procedure. A further direction was
issued to the Central Government to ensure that such a
scheme is indispensable to achieve the objective of a
reformative judicial mechanism and that the same must
be implemented within six months from the date of the
decision. However, the elaborate guidelines pertaining to
the victim centric approach to deliver justice, has not
been effectively manifested by the Government of India.
The Court while rendering its judgment is empoweredunder Section 357 to award compensation to the victim.
However, throughout the length and breadth of the
provision, the wordings of the provision, if read literally,
give rise to two anomalies, namely: That there exists an
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element of judicial discretion, to the prejudice of the
victims right to be compensated. The second anomaly is
with respect to the establishment of offence to be a
prerequisite before granting such compensation. It is
most respectfully submitted that there may be instances
wherein the accused remains untraceable even if the
medical reports suggest that rape has been committed, orin other cases where due to lack of evidence a person
cannot be held guilty, however it is proven that there has
been a forceful penetration, in such category of cases, the
provision adumbrated under section 357 provides no
recourse to the victim. It is due to these factors, that it is
essential to establish a Criminal Injuries Compensation
Board which will primarily be entrusted with the task of
providing relief, both interim as well as final by taking
into account such factors as have already been laid down
by this Honble Court in the cases annotated above.
The order delivered by a division bench of this Court inthe Delhi Domestic Working Womens Forum (supra) had
specifically entrusted the task of setting up of CICB to
the National Commission for Women, which was its
legislative mandate under section 10. However, the same
has not been carried out so far, therefore it is implored
before this Honble Court to implead the Union of India
and the National Commission for Women as a
Respondent in the instant petition so as to account for
the delay in setting up of a scheme of such nature for
over sixteen years after the passing of the judgment.
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Thirdly, that it is respectfully submitted that the Honble
Court in giving effect to the Right to Speedy and fair trial
as being inherent to the Right to Life may be pleased to
establish Fast Track Courts for the expeditious disposal
of rape cases, particularly those in the nature of Gang
Rapes so that expeditious remedy can be provided tothem at affordable costs. This is in specific regard to
subject matter specific fast track courts, such as
instances of rape cases, wherein day to day proceedings
should be mandated which has been extrapolated in this
Honble Courts ruling in the case of Brij Mohan Lal v.
Union of India and Others. T.C. Case Civil No. 22 of
2001.
The instant writ petition under Article 32 read with
Articles 14, 21, 38, 39 and 41 of the Constitution has
been advanced in view of ghastly instances of violence
perpetrated at a burgeoning rate in India, and
particularly in metropolitan areas which is violation of
individuals right to life with dignity even though there is
a well organized system of Delhi Police operating in the
State of Delhi. Hence this Writ Petition.
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IN THE SUPREME COURT OF INDIACIVIL ORIGINAL JURISDICTION
WRIT PETITION (CIVIL) NO. OF 2012Under Article 32 of the Constitution of India.
In the matter of:-
1.NIPUN SAXENA (student)National Law University, Delhi
2.ANKITA CHAUDHARY (Advocate)Petitioners
VERSUS
1.UNION OF INDIA THROUGH SECRETARY,MINISTRY OF HOME AFFAIRSNorth Block, Central Secretariat
New Delhi-110001
2.UNION OF INDIA THROUGH SECRETARY,MINISTRY OF WOMEN AND CHILD DEVELOPMENT
Shastri Bhawan, A-wing,
Dr. Rajendra Prasad Road
New Delhi-110001
3.SECRETARY, STATE TRANSPORT AUTHORITY,GOVT. OF DELHI,5/9 under Hill Road,
New Delhi-110054
4.NATIONAL COMMISSION FOR WOMEN11 Rouse Avenue Lane
Deen Dayal Upadhyaya Marg,
New Delhi-110002Respondents.
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WRIT PETITION UNDER ARTICLE 32 OF THECONSTITUTION OF INDIA
TO,THE HON'BLE CHIEF JUSTICE OF INDIAAND HIS COMPANION JUSTICES OF THEHON'BLE SUPREME COURT OF INDIA
THE HUMBLE PETITION OF THEPETITIONER ABOVE-NAMED
MOST RESPECTFULLY SHOWETH:
1. That the instant writ petition filed before this
Honble Court is in the nature of mandamus
seeking to direct the Secretary State Transport
Authority, Government of Delhi, the Central
Government and the National Commission for
Women to take necessary steps in curbing the
menace of rampant rape and other offences against
women.
2. The instant petition has been filed under Article 32
read with Article 14, 21, 38, 39 and 41 of the
Constitution, in view of the recent atrocity
committed on 16th December, 2012 in Delhi where
a girl aged 23 years was gang raped. The gruesome
and heinous manner in which the said crime was
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perpetrated has led to the advancement of the
instant petition.
3. That the petitioner is the citizen of India and have
locus to file the above writ petition under Article 32
of the Constitution of India in this Hon'ble Court.
4. That the petitioner respectfully submits that four
prominent issues are critical to the instant case.
Firstly, the operation of private buses, especially
those in the nature of bearing an interstate license
and their travelling in late hours of the night, in and
around National Capital Region, poses a serious
threat to the safety and security of the travellers,
who equate them with the Delhi Transport
Commission approved buses.
5. That the petitioner respectfully submitted before
this Honble Court that keeping in view of the
dispensing mechanism of the Criminal justice
delivery system, there is a compelling need for the
establishment of a formal compensatory mechanism
for victims called the Criminal Injuries
Compensation Board (hereinafter referred to as
CICB) which provides for instantaneous and
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expeditious monetary relief to the victim(s) of
gruesome offences such as rape.
6. That the above mentioned act is an animalistic act
which has taken place and a shocking incident and
the worst possible crime to have taken place.
7. That the petitioner submits that this is not a
petition that has been triggered by the sole
incidence of the alleged rape that took place on 18th
December, 2012 wherein a girl was attacked and
rape. These shocking incidents have shaken the
moral conscience of the society, and particularly of
the women who feel unsafe and unsecured to move
out of their homes.
8. That the petitioner, therefore, is advancing the
present writ petition under Article 32 of the
Constitution of India raising the following questions
of law:-
A. Whether there is a violation of Article 21 of the
Constitution of India which encapsulates the Right
to live with freedom and dignity?
B. Whether the failure of the State and its enforcement
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agencies in taking proactive steps to mitigate the
hardship caused to the victim and a consequent
failure in taking preventive measures to curb the
growing menace of Rape violative of the Right to Life
adumbrated under Article 21 which includes Right
to Human dignity?
9. That the aforesaid relief has been prayed for under
Articles 32 read with Articles 14, 21, 38, 39 and 41
of the Constitution of India before this Honble
Court as the state agencies have repeatedly failed to
take effective steps to provide for an effective
redressal to the women.
10. The petitioner has not filed any other similar writ
Petitioner before this Hon'ble Court or before the
Honble High Court for the relief sought herein.
PRAYER
It is, therefore, most respectfully prayed that this Hon'ble
Court may kindly be pleased to:-
A)ISSUE a Writ of mandamus to the Secretary,State Transport Authority and the Commissioner
of Delhi Police to cancel / revoke license of such
permit holders who are in violation of provisions
of the Motor Vehicles Act especially in view of the
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recent increment in rapes, and to conduct
immediate inquiry into the antecedents of such
drivers/ license holders.
B)ISSUE a Writ of mandamus to the Union of Indiaand the National Commission of Women to file a
status report entailing the steps taken by them to
establish Criminal Injuries Compensation Board.
C)ISSUE a Writ of mandamus directing the CentralGovernment and NCW to take steps to set up a
Criminal Injuries Compensation Board in breach
of its order passed in Delhi Domestic Working
Womens Forum v. Union of India has resulted
into contempt of such order for over 16 years.
D)ISSUE a Writ of mandamus to the StateGovernments for the establishment of Fast Track
Courts to deal with specific instances of Rape
Cases throughout India.
E)PASS such other order or orders as this Hon'bleCourt may deem fit and proper in the facts and
circumstances of the present case;
AND FOR THIS ACT OF KINDNESS THE PETITIONER
SHALL EVER PRAY AS DUTY-BOUND
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Drawn & Filed by:
(ANKITA CHAUDHARY, NIPUN SAXENA)
Petitioners in Person
DATE OF DRAFTING: 20.12.2012
PLACE: New Delhi
FILED ON: 20.12.2012
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IN THE SUPREME COURT OF INDIACIVIL ORIGINAL JURISDICTION
WRIT PETITION (CIVIL) NO. OF 2012
In the matter of :-
Nipun Saxena & Anr. Petitioners
VERSUS
Union of India & ors. Respondents.
AFFIDAVIT
I, Nipun Saxena, presently at New Delhi, do herebysolemnly affirm and state as under :
1. That I am one of the petitioners in the Writ Petitionand well acquainted with the facts and
circumstances of the present case and in thatcapacity, competent to swear the present affidavit insupport of the present Writ Petition and theaccompanying List of Dates.
2.That the facts of the accompanying Writ Petition inparas 1 to from pages 1 to the synopsis is frompage No. A to and the I.A. for direction runningfrom page No.to of the Paper-Book have beenprepared under my instructions as well as read over
and explained to me and I say that the contents ofthe same are true and correct to my knowledge. Nopart of it is false and nothing material has beenkept concealed therefrom.
DEPONENT
VERIFICATION
Verified at New Delhi on this 20th day of December,
2012 that the facts stated in the above affidavit are true tomy knowledge. No part of the same is false and nothingmaterial has been kept concealed therefrom.
DEPONENT
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IN THE SUPREME COURT OF INDIACIVIL ORIGINAL JURISDICTION
I. A. NO. OF 2012
IN
WRIT PETITION (CIVIL) NO. OF 2012
In the matter of :-
Nipun Saxena & Anr. Petitioners
VERSUS
Union of India & ors. Respondents.
AN APPLICATION FOR DIRECTION UNDER ORDER
XLVII OF SUPRME COURT RULES, 1966.
TO,
THE HON'BLE CHIEF JUSTICE OF INDIAAND HIS COMPANION JUSTICES OF THEHON'BLE SUPREME COURT OF INDIA
THE HUMBLE PETITION OF THE
PETITIONERS ABOVE-NAMED
MOST RESPECTFULLY SHOWETH :
1. That this is a petition under Article 32 of the
constitution of India, praying for the issue of direction,
orders or writ as may be appropriate for the
enforcement of fundamental rights by part III of the
constitution of India.
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2. That the petitioner craves leave of this Hon'bleCourt to refer to the contents of the writ petition at
the time of hearing of this application.
3. That it is in the interest of justice that the rights ofthe petitioner may be protected during the pendency
of their case in this Hon'ble Court and therefore
makes the following prayer for direction.
PRAYER
It is, therefore, most respectfully prayed that this
Hon'ble Court may graciously be pleased to :
a)DIRECT the Secretary, State Transport Authorityand the Commissioner of Delhi Police to cancel /
revoke license of such permit holders who are in
violation of provisions of the Motor Vehicles Act
especially in view of the recent increment in
rapes, and to conduct immediate inquiry into the
antecedents of such drivers/ license holders.
b)DIRECT the Union of India and the NationalCommission of Women to file a status report
entailing the steps taken by them to establish
Criminal Injuries Compensation Board.
c) HOLD that the failure of Central Government and
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NCW to take steps to set up a Criminal Injuries
Compensation Board in breach of its order
passed in Delhi Domestic Working Womens
Forum v. Union of India has resulted into
contempt of such order for over 16 years.
d)DIRECT the State Governments for theestablishment of Fast Track Courts to deal with
specific instances of Rape Cases throughout
India.
e) PASS such other order or orders as this Hon'bleCourt may deem fit and proper in the facts and
circumstances of the present case;
AND FOR THIS ACT OF KINDNESS THE PETITIONER
SHALL EVER PRAY AS DUTY-BOUND
Drawn & Filed by:
(ANKITA CHAUDHARY, NIPUN SAXENA)
Petitioners in Person
DATE OF DRAFTING: 20.12.2012
PLACE: New Delhi
FILED ON: 20.12.2012
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I N D E X
SI. NO. P A R T I C U L A R S. PAGE NO.
1. LIST OF DATES. A
2. CIVIL WRIT PETITION ALONGWITHAFFIDAVIT. -
3. I. A. NO. OF 2012AN APPLICATION FOR DIRECTION
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IN THE SUPREME COURT OF INDIACIVIL ORIGINAL JURISDICTION
WRIT PETITION (CIVIL) NO. OF 2012
In the matter of :-
Nipun Saxena & Anr. Petitioners
VERSUS
Union of India & ors. Respondents.
WITH
I. A. NO. OF 2012AN APPLICATION FOR DIRECTION
PAPERBOOK(For Index : Kindly see inside)
---------------------------------------------------------------------------------------------------------PETITIONERS IN PERSON : ANKITA CHAUDHARY & NIPUN SAXENA
---------------------------------------------------------------------------------------------------------Filed On: 20.12.2012
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IN THE SUPREME COURT OF INDIACIVIL ORIGINAL JURISDICTION
WRIT PETITION (CIVIL) NO. OF 2012
In the matter of :-
Nipun Saxena & Anr. Petitioners
VERSUS
Union of India & ors. Respondents.
AFFIDAVIT OF URGENCY
I, Nipun Saxena, presently at New Delhi, do herebysolemnly affirm and state as under :
1. That I am one of the petitioners in the Writ Petition andwell acquainted with the facts and circumstances of the
present case and in that capacity, competent to swearthe present affidavit in support of the present WritPetition and the accompanying List of Dates.
2.That the matter is urgent and requires immediatehearing as in the wake of escalation in the incidence ofrape on hourly basis wherein the majority of suchheinous crimes of rapes, sexual assault have beencommitted on such contract buses which do not haveproper licenses and permission from the transport
authority and running on fraudulent identities withinthe knowledge of transport authority and police. Thatrecent crimes have all been committed are movingvehicles like cars/cabs, SUV, charted buses and also onprivate owned buses meant for public transport andtherefore to reduce/prevent such crimes against womenand especially students and working women. Thismatter needs to be heard immediately. The facts statedherein are true and correct to my knowledge. No part ofit is false and nothing material has been kept concealed
therefrom.
DEPONENT
VERIFICATION
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Verified at New Delhi on this 20th day of December,2012 that the facts stated in the above affidavit are true tomy knowledge. No part of the same is false and nothingmaterial has been kept concealed therefrom.
DEPONENT
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IN THE SUPREME COURT OF INDIACIVIL ORIGINAL JURISDICTION
I. A. NO. OF 2012
IN
WRIT PETITION (CIVIL) NO. OF 2012
In the matter of :-
Nipun Saxena & Anr. Petitioners
VERSUS
Union of India & ors. Respondents.
AN APPLICATION FOR PERMISSION TO APPEARAND ARGUE AS PETITIONER IN PERSON UNDER ORDER
XLVII OF SUPRME COURT RULES, 1966.
TO,
THE HON'BLE CHIEF JUSTICE OF INDIAAND HIS COMPANION JUSTICES OF THEHON'BLE SUPREME COURT OF INDIA
THE HUMBLE PETITION OF THE
PETITIONERS ABOVE-NAMED
MOST RESPECTFULLY SHOWETH :
1.That today a petition under Article 32 of theConstitution of India, praying for the issue of direction,
orders or writ as may be appropriate for the
enforcement of fundamental rights by part III of the
Constitution of India has been filed.
2. That the petitioners may be permitted by this Honble
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court to appear and argue in person before this Honble
Court.
PRAYER
It is, therefore, most respectfully prayed that this
Hon'ble Court may graciously be pleased to :
A) PERMIT the petitioners to appear and argue inperson before this Honble Court by this
Honble Court and
B)PASS such other order or orders as this Hon'ble Courtmay deem fit and proper in the facts and
circumstances of the present case;
AND FOR THIS ACT OF KINDNESS THE PETITIONER
SHALL EVER PRAY AS DUTY-BOUND
Drawn & Filed by:
(ANKITA CHAUDHARY, NIPUN SAXENA)
Petitioners in Person
FILED ON: 20.12.2012
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To,The RegistrarSupreme Court of India
Diary No. 42734W.P (C) 565/2012
Subject: Application for Urgent Hearing Before the HonbleChief Justice of India
Nipun Saxena & Anr. PetitionersVersus
Union of India & ors Respondents
Sir,
That the matter is urgent and requires immediate hearing asin the wake of escalation in the incidence of rape on hourlybasis wherein the majority of such heinous crimes of rapes,sexual assault have been committed on such contract buses
which do not have proper licenses and permission from thetransport authority and running on fraudulent identitieswithin the knowledge of transport authority and police. Thatrecent crimes have all been committed are moving vehicleslike cars/cabs, SUV, charted buses and also on private ownedbuses meant for public transport and therefore toreduce/prevent such crimes against women and especiallystudents and working women. This matter needs to be heardimmediately. In pursuance thereof we request you to kindlypermit us to raise our grievances before the Honble Chief
Justice of India as the date given by the Registry is11.01.2013 by which time it would be too late to initiate anypreventive measures especially in the wake of rapid incrementin instances of rape and sexual assault. We have observed therequisite formalities by attaching an urgency affidavit with thewrit petition.We therefore implore you to kindly consider it as an urgentmatter and list it today.
Thanking you.
Petitioners-in-Person
Nipun SaxenaAnkita Chaudhary
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