Curative Petition

IN THE SUPREME COURT OF INDIA

CIVIL APPELLATE JURISDICTION

CURATIVE PETITION (CIVIL) No.___________ OF 2011IN

REVIEW PETITION (CIVIL) NOS. 2045-2052 OF 2010

IN

SPECIAL LEAVE PETITION (CIVIL) NOS.14249-14256 OF 2010

IN THE MATTER OF:

Suresh Garg & etc. etc. … Petitioners

Versus

State of Haryana & Anr. ....Respondents

PAPER – BOOK [FOR INDEX KINDLY SEE INSIDE]

ADVOCATE FOR THE PETITIONERS: MS. GARIMA PRASHAD

1





IN


1. ARISING OUT REVIEW PETITION NO. 2045 OF 2010 IN SLP NO. 14249 OF 2010:

IN THE MATTER OF:

Suresh Garg, son of Shri Om Parkash, Resident of House No. 730, HUDA Part-I, Sector-11, Panipat, (Haryana) … Petitioner

Versus

1. State of Haryana Through its Secretary, Urban Development/Urban Estate, Haryana Secretariat, Chandigarh.

2. Land Acquisition Collector, Urban Estate, Haryaa, S.C.O. No. 61, Sector-8, Panchkula (Haryana) … Respondents


IN THE MATTER OF:

Sham Lal, son of Shri Ram, New Housing Board Colony, Panipat, (Haryana) … Petitioner

Versus

2




IN THE MATTER OF:Smt. Parveen, W/o Shri Suresh Kumar, Resident of House No. 62, Yamuna Enclave, Panipat, (Haryana) … Petitioner

Versus




IN THE MATTER OF:Gopal Krishan, Son of Shri Budh Ram, R/o 124, Yamuna Enclave, Panipat, (Haryana) … Petitioner

Versus

3




IN THE MATTER OF:Bal Krishan, Son of Sham Lal, New Housing Board Colony, Panipat (Haryana) … Petitioner

Versus




IN THE MATTER OF:Smt. Neeta, W/o Bhupinder Kumar, R/o 232-Respondent Model Town, Panipat (Haryana) … Petitioner

Versus

4




IN THE MATTER OF:Arun Kumar, S/o Bhupinder Kumar, R/o 232-Respondent Model Town, Panipat (Haryana) … Petitioner

Versus




IN THE MATTER OF:Kanta Singla, W/o Sh. R.S. Singla, R/o Salar Ganj, Panipat (Haryana) … Petitioner

Versus

1. State of Haryana Through its Secretary,

5

Urban Development/Urban Estate, Haryana Secretariat, Chandigarh.


CURATIVE PETITION UNDER ARTICLES 137, 142 AND 145(1)(E) OF THE CONSTITUTION OF INDIA AND ORDER XVIII, RULE 5 AND ORDER XLVII RULE 6 OF THE SUPREME COURT, 1966.

TO

HON’BLE THE CHIEF JUSTICE OF INDIA

AND HIS COMPANION JUDGES OF THE

SUPREME COURT OF INDIA AT NEW DELHI.

THE HUMBLE PETITION OF THE

PETITIONERS ABOVE- NAMED

MOST RESPECTFULLY SHEWETH:

1. The present Curative Petition has been filed by the Petitioners

pursuant to the dismissal of the Petitioners’ Review Petitions filed

for reviewing the orders passed in the Petitioners’ Special Leave

Petitions challenging the orders of the Hon’ble High Court in

Regular First Appeals. In deciding the Petitioners’ Regular First

Appeals, the Hon’ble High Court had relied upon another RFA No.

2213 of 1995 titled Kasturi Lal & Ors. Vs. The State of Haryana &

Ors. While the Special Leave Petitions filed by the Petitioners

have been dismissed by this Hon’ble Court, notice has been

issued to the Respondent state of Haryana in the Special Leave 6

Petitions filed by those Petitioners whose judgment had been

relied upon.

2. The Petitioners submit that aggrieved by the dismissal of their

Special Leave Petitions while notice had been issued in the

Special Leave Petitions arising out of the relied upon judgment i.e.

Kasturi Lal Vs. State of Haryana the Petitioners filed Review

Petitions being Review Petition (Civil) Nos. 2045-2052 of 2010.

3. That this Hon’ble Court dismissed the Petitioners’ Review

Petitions in SLP (C) Nos. 14249-56 of 2010 by its order dated

9.12.2010. True copy of the order dated 9.12.2010 passed by this

Hon’ble Court in Review Petition (Civil) No. 2045-52 of 2010 in

SLP Civil) No. 14249-56 of 2010 is annexed herewith and marked

as ANNEXURE P-1.

4. In the above circumstances the Petitioner is filing the present

Curative Petition and humbly seeks indulgence of this Hon’ble

Court for reviewing its order dated 16.7.2010 in Special Leave

Petition (Civil) No. 14249-56 of 2010. The Petitioners submit that

very strong reasons exist for the exercise of its inherent powers by

this Hon’ble Court.

5. That the facts and circumstances leading to the filing of the

present Curative Petition are already set out in detail in the

Special Leave Petitions. However for convenience the facts in

brief are narrated below: -

7

A. That a notification dated 10.5.89 U/S 4 of the Land acquisition Act

was issued which was published in the Haryana Govt. (Extra

Ordinary) gazette on 10.6.89. This was followed by a section 6

Notification published on 09.05.90. By the aforesaid notifications

an area falling in villages Kabri (31.34 areas), Faridpur (68.58

acres); Sarai, Bachhra (47.92 acres); Patti Magdum Jadgan (5.13

acres) and Patti Taraf Insar (334.15 acres), total measuring

487.12 acres was notified, but in fact, land in village Kabri (28.85

acres) Faridpur (11.22 acres) Sarai Bachhra, (30.08 acres), Patti

Magdum Jadgan (3.86 acres) and Patti Taraf Insar (298.25 acres)

(total 372.26 acres of land), was acquired for the public purpose,

of development and utilization of land as residential, commercial,

industrial and institutional area in Sectors 6, 7 and 8 at Panipat.

B. That in the year 1992-93, the Land Acquisition Collector, Urban

Estate, Panchkula (for short, the Collector) vide his award No.7 for

the year 1992-93, classified the acquired land and awarded

compensation at various rates ranging from Rs.1,00,000 per acre

to Rs.2,15,000 per acre.

C. Aggrieved against the award of the Collector, the claimants i.e.

the Petitioners herein filed objections under Section 18 of the

Land Acquisition Act, before the Ld. Addl. District Judge Panipat

alleging inter-alia that the compensation awarded was absolutely

insufficient and inadequate. It was stated that the acquired land

was situated within the Municipal Limits of Panipat on the main

G.T. Road (National Highway) and was just one Kilometre away 8

from the main Bus Stand, Civil Hospital, Rest House, Panipat and

the Petrol Pump. It was also stated that the land abutted the

National Highway & was within the Industrial area of Panipat,

therefore keeping in view the potentiality of the land the

compensation assessed was highly inadequate.

D. That on 10.5.2007 the Learned Reference Court without taking

into account the sale deeds tendered by the claimants on the

ground that the sale deeds Exs. P-3 to P-10, giving value of the

acquired land, sold in the year 1988, @ Rs.128/- to Rs.133/- per

square yard pertained to small pieces of land, and there being

nothing to show that these small pieces of land were identical in

location and use etc. as compared to the subject matter of the

reference assessed the market value of the acquired land at the

rate of Rs.81 per square yards. A copy of the judgment dated

10.5.2007 by the Reference Court is already annexed as

Annexure P-1 to the Special Leave Petition.

E. Both the claimants i.e. the Petitioners herein and the State of

Haryana aggrieved by the judgment of the Learned Reference

Court came up in appeals before the High Court of the Punjab &

Haryana at Chandigarh. The claimants prayed for enhancement

of compensation, whereas the State of Haryana prayed for

reducing the amount of compensation awarded by the Learned

Reference Court.

9

F. That on 24.09.2009, the Petitioners herein filed R.F.A. No. 3970

of 2007 (O&M) 3969of 2010 and 3972, 3973, 3974, 3605 and

3606 of 2007 and 311 of 2009 before the Hon’ble High Court of

Punjab and Haryana at Chandigarh.

G. That the Hon’ble High Court vide its final Judgment and order

dated 11.11.2009 passed in R.F.A. No. 3970 of 2007 and order

dated 11.3.2010 in RFA No. 3605 & 3606 of 2007 was pleased to

decide the aforesaid R.F.As. in terms of another RFA No. 2213 of

1995 titled Kasturi Lal & Ors. Vs. State of Haryana & which was

disposed of by the High Court vide judgment dt. 27.5.2009.

Copies of the judgments dated 11.11.2009 & 11.3.2010 are

already annexed as impugned judgments to the Special Leave

Petitions.

H. That on 09.03.2010, the petitioners herein filed Special Leave

Petition (c) Nos. 14249-14256 of 2010 before this Hon’ble Court

against the dismissal of their Regular first Appeals.

I. That this Hon’ble Court vide its Order dated 16.07.2010 in Special

Leave Petition (C) Nos. 14249-14256/2010 was pleased to

dismiss the said Special Leave Petitions. True copy of the order

dated 16.7.2010 dismissing the Special Leave Petitions is

annexed hereto as ANNEXURE P-2.

J. That the petitioners in the relied upon judgement filed Special

Leave Petitions Nos.19399-19406 of 2010 titled as “Kasturi Lal &

10

Ors. etc. etc. Vs. State of Haryana & Anr.” before this Hon’ble

Court and this Hon’ble Court vide its order dated 20.08.2010

issued notice on the applications for condonation of delay as well

as on the Special Leave Petitions. True copy of the order dated

20.08.2010 passed by this Hon’ble Court is annexed hereto as

ANNEXURE P-3.

K. The Petitioners submit that since the land which was the subject

make of the petitioners Special Leave Petitions and the land

forming the subject matter of the Special Leave Petitions i.e.

Kasturi Lal & Ors. was acquired by a common notification dated

10.05.89 and since the petitioners Special Leave Petitions had

been dismissed while notice had been issued in respect of Kasturi

Lal & Ors., therefore on the principle of parity, the petitioners filed

Review Petitions No. 2045-52 of 2010 for review of the order

dated16.7.2010 passed in the petitioners SLP.

6. That this Hon’ble Court dismissed the Review Petitions in SLP

(Civil) Nos. 14249-56 of 2010 by its order dated 16.7.2010.

7. Aggrieved by the dismissal of Review Petitions, the Petitioners are

filing the present the Curative Petition and humbly seek

indulgence of this Hon’ble Court for reviewing its judgment and

order dated 16.7.2010 in Special Leave Petition (Civil) Nos.

14249-56 of 2010, since very strong reasons exist in the present

case for the exercise of inherent powers by this Hon’ble Court.

11

8. The Petitioners are filing the present Curative Petition in

conformity with the law laid down by this Hon’ble Court in Rupa

Ashok Hurra’s case: (2002) 4 SCC 388 and humbly seeks

indulgence of this Hon’ble Court for review of its substantive

Judgment and Order dated 16.7.2010 in Special Leave Petition

(Civil) Nos. 14249-56 of 2010.

9. That in terms of Rupa Ashok Hurra’s case; the petitioner aver and

submit specifically herein that the grounds mentioned herein had

been taken in Review Petition (Civil) Nos. 14249-56 of 2010 and

that the said Review Petitions were dismissed by circulation.

Further, this Curative Petition contains at its foot a certification by

a Senior Advocate with regard to the fulfillment of the said

requirements.

10. For brevity, the Petitioners crave leave to incorporate and urge as

part of these grounds the various other grounds raised in its said

Review Petition as also in its earlier pleadings in the said Special

Leave Petitions before this Hon’ble Court.

11. That the petitioner have not filed any other Curative Petition

earlier against the impugned order dated 9.12.2010 passed in

Review Petition (C) Nos. 2045-52 of 2010 in Special Leave

Petition (Civil) Nos. 14249-56 of 2010.

12. That the grounds mentioned in this Curative Petition have been

taken in the Review Petition and that it was dismissed by

12

circulation and no new grounds have been taken in this Curative

Petition.

13. The Petitioners are filing the present Curative Petition on the

following amongst other grounds each of which have been taken

by the Petitioners in the Review Petitions filed in the Special

Leave Petitions referred to hereinabove and the corresponding

grounds in the Review Petitions are indicated accordingly: -

GROUNDS

A. Because the Petitioner’s Special Leave Petitions and

thereafter the Review Petition for enhancement of

compensation of the acquired lands were dismissed

wherein the challenge was made to the order of the Hon’ble

High Court. The High Court in Petitioner’s Regular First

Appeal while determining the compensation in regard to the

Petitioner’s lands relied upon another Regular First Appeal

No. 2213 of 1995 tilted as Kasturi Lal & Ors. Vs. State of

Haryana & Ors. The Petitioners of this relied upon

judgment i.e. Kasturi Lal & Ors. Vs. State of Haryana & Ors.

also preferred Special Leave Petition Nos. 19399-19406 of

2010 before this Hon’ble Court. These Special Leave

Petitions were heard by the Bench comprising of the

Hon’ble Mr. Justice V.S. Sirpukar and Hon’ble Mr. Justice

Cyriac Joseph of this Hon’ble Court. By order dated

20.8.2010 notice was issued to the Respondents – State of

13

Haryana in these petitions. On the other hand the Special

Leave Petitions filed by the Petitioners have been

dismissed despite the fact that the land which formed the

subject matter of the above two different sets of Special

Leave Petitions was acquired by way of a common Section

4 Notification dated 10.5.1989. The Review Petitions filed

thereafter have also been dismissed. The Petitioners by

way of this Curative therefore seek the same relief as the

Petitioners in the relied upon judgment i.e. Kashturi Lal &

Ors. Vs. State of Haryana & Ors. wherein notice has

already been issued (Corresponding to paras A, B, C of the

Review Petition).

B. Because if finally the Special Leave Petitions of the

Petitioners in the relied upon judgment are allowed and the

compensation of the acquired land enhanced, the

petitioners herein would be subjected to discrimination

leading to grave miscarriage of justice. The Petitioners are

therefore filing the present Curative Petitions on the

principle of parity. (Corresponding to ground C of the

Review Petition).

C. Because this Hon’ble Court did not appreciate that the

Learned Additional District Judge Panipat had awarded

compensation at the rate of Rs. 81/- per sq. yards which

was inadequate. The High Court enhanced the

14

compensation to Rs. 139/- per sq. yards on the date of

issuance of Notification under Section 4 of the Act alongwith

all statutory benefits. The High Court while denying interest

also assessed the compensation on the lower side. It needs

to be stated that the Haryana Urban Development Authority

has sold the same land after development at the rate of Rs.

3080-4849 per sq. yards. Thus even after deducting the

charges for the development of land and leaving margin for

development, the price of agricultural land should have

been determined as more than Rs. 2000/- per sq. yards.

(Corresponding to ground D & E of the Review Petition).

D. Because this Hon’ble Court failed to appreciate that the

Courts below had assessed the price of the acquired land

only on the basis of assessment arrived at in two earlier

judgments rendered qua two earlier Notifications of the

years 1982 and 1989. In taking the orders passed relating

to other lands as the guiding principle and ignoring the fact

that the Petitioners land had the Grand Trunk Road in front,

shopping complex on the left and 52 acres of the city park

on the other side, the courts below failed to assess the fair

value of the Petitioner’s land which ought to have been

enhanced. (Corresponding to paras F & H of the Review

Petition).

15

E. Because this Hon’ble Court and Ld. Court below did not

appreciate that in the present case a tract of prime land

abutting Grand Trunk Road No. 1 up to Railway Line was

acquired vide Notification dated 10.5.1989 under Section 4

of Land Acquisition Act adjoining the abadi of City Panipat

which is just 2 kms. from the main shopping centre and

industrial area and is about ½ km. from main bus stand

Panipat, Civil Hospital, Reset House, Arya College, Office

of the Sub Registrar, Sky-Lark Haryana Govt. Tourist

Complex and Railway Station and Office of Post Office &

Telegraph. The Panipat Town is known as Manchester of

India and is at the top of industrial map of World and in fact

the acquired land is a part of Panipat town and there are

posh residential colonies, industrial and commercial

establishment around the land acquired for Sector 6, 7 and

8. In fact no land at all is available in or around Panipat for

setting up residential commercial and industrial units except

the land acquired by the H.U.D.A. which is of great potential

value. In the circumstances the compensation has been

awarded at a very lower side which is liable to be

enhanced. (Corresponding to para I of the Review Petition).

F. Because as per annum increase in the land price is

required to be taken as minimum 15% in the instant case

keeping in view of the fact that the acquired land is situated

in the Panipat township, a premier city of National Capital

16

Region, having place in world industrial centre, only 90

kilometers away from Delhi and is situated on the National

Highway No. 1. (Corresponding to para G of the Review

Petition).

G. Because this Hon’ble Court and Ld. Court below failed to

appreciate that no allowance for development from the date

of notification under Section 4 till the pronouncement of

award has been granted and it is a settled law that an

increase at a rate of 18% per annum for the increased in

price is granted as per settled law, but the learned ADJ,

Panipat has ignored this legal proposition of law hence.

(Corresponding to para J of the Review Petition).

PRAYERIt is, therefore, most respectfully prayed that this Hon’ble Court

may graciously be pleased to:-

(a) to allow the Curative Petition and further in due course of law set

aside the Order dated 9.12.2010 passed in Review Petition (Civil)

Nos. 2045-2052 of 2010.

(b) pass such other or further orders as this Hon’ble court may deem

fit and proper under the facts and circumstances in exercise of its

inherent powers to do complete justice between the parties to the

present case.

Drawn by FILED BY

17

(GARIMA PRASHAD) Advocate ADVOCATE FOR THE PETITIONERS

Drawn on: 12.2.2011 Filed on: 17.2.2011New Delhi

18

INDEX

SL. NO. PARTICULARS PAGE NO.

1. Curative Petition with affidavit. 1 – 17

2. Certificate of Senior Advocate 18 – 19

3. ANNEXURE P-1: True copy of the order dated 9.12.2010 passed by this Hon’ble Court in Review Petition (Civil) No. 2045-52 of 2010 in SLP Civil) No. 14249-56 of 2010.

20

4. ANNEXURE P-2: True copy of the order dated 16.7.2010 passed by this Hon’ble Court in Special Leave Petitions (Civil) Nos. 14249-56 of 2010.

21

5. ANNEXURE P-3: True copy of the order dated 20.08.2010 passed by this Hon’ble Court in SLP (Civil) No. 19399-19406 of 2010.

22 – 23

19





IN


IN THE MATTER OF:


Versus


CERTIFICATE

“Certified that have carefully examined the above Curative Petition. It

appears to me that in the present case, the land under acquisition

having in mense potentiality the Hon’ble High Court ought to have

enhanced the compensation. Secondly notice has already been issued

by this Hon’ble Court in the Special Leave Petitions arising out of the

judgment relied upon by the High Court i.e. Kasturi Lal & Ors. Vs. State

of Haryana & Ors. while the Special Leave Petitions filed by the

Petitioners herein have been dismissed, despite the fact that the land

which formed the subject matter of the above two different sets of

Special Leave Petitions was acquired by way of a common notification

dated 10.5.1989 u/s 4 of the Land Acquisition Act. The conclusions as

reached by the High Court constitute sufficient reason to entertain the

petition seeking reconsideration of judgment and order of this Hon’ble

Court passed in the Review Petition dated 9.12.2010 and in the

substantive judgment and order dated 16.7.2010 in Special Leave

Petition.

20

The Curative Petition also fulfils the requirement as laid down in the

judgment of this Hon’ble Court in Rupa Ashok Hurra Vs. Ashok Murra

(2002) 2 SCC 388”

(R.P. Bhatt) Senior Advocate

21

ANNEXURE P-2

ITEM NO.43 COURT NO.3 SECTION IVB

S U P R E M E C O U R T O F I N D I ARECORD OF PROCEEDINGS

Petition(s) for Special Leave to Appeal (Civil) No(s).14249-14256/2010

(From the judgement and order dated 11/11/2009 in RFA No. 311/2009 & RFA No. 3605/2007 & RFA No. 3606/2007 & RFA No. 3969/2007 & RFA No. 3970/2007 & RFA No. 3972/2007 & RFA No. 3973/2007 & RFA No. 3974/2007 of The HIGH COURT OF PUNJAB &HARYANA AT CHANDIGARH)

SURESH GARG & ETC. Petitioner(s)

VERSUS

STATE OF HARYANA & ANR. Respondent(s)

(With appln(s) for permission to file addl. documents and office report)

Date: 16/07/2010 These Petitions were called on for hearing today.

CORAM : HON'BLE MR. JUSTICE R.V. RAVEENDRAN HON'BLE MR. JUSTICE H.L. GOKHALE

For Petitioner(s) Dr. Sushil Balwada,Adv.

For Respondent(s)

UPON hearing counsel the Court made the following

O R D E RThe Special Leave Petitions are dismissed.

(O.P. Sharma) (M.S. Negi) Court Master Court Master

//true copy//

22

ANNEXURE P-3 ITEM NO.33+51 Court No.8 SECTION IVB

S U P R E M E C O U R T O F I N D I ARECORD OF PROCEEDINGS

Petition(s) for Special Leave to Appeal (Civil) No(s).19399-19406/2010

(From the judgement and order dated 27/05/2009 in RFA No. 27/1996 & RFA No. 126/1996 & RFA No. 131/1996 & RFA No. 188/1996 & RFA No. 1099/1996 & RFA No. 2213/1995 of The HIGH COURT OF PUNJAB & HARYANA AT CHANDIGARH)

KASTURI LAL & ORS.ETC.ETC. Petitioner(s)

VERSUS

STATE OF HARYANA & ANR. Respondent(s)

(With office report )

WITH SLP(C) NO. 11932-11934 of 2010(With office report)

S.L.P.(C)...CC NO. 12561-12562 of 2010with I.A. No. 1-2 (c/delay in filing SLP and office report)

SLP(C) NO. 18231 of 2010(With office report)

S.L.P.(C)...CC NO. 21955-21960 of 2009with I.A. No. 1-2 (c/delay in filing SLP and office report)

S.L.P.(C)...CC NO. 7647-7650 of 2010with I.A. No. 1 (c/delay in filing SLP and c/delay in refiling Slp and office report)

S.L.P.(C)...CC NO. 7894 of 2010with I.A. No. 1-2 (c/delay in filing SLP and c/delay in refiling Slp and office report)

S.L.P.(C)...CC NO. 7897-7902 of 2010(For substitution and permission to file Slp and c/delay in filing substitution appln. and office report)

SLP(C) No. 23829 of 2010(with prayer for interim relief and office report)

Date: 20/08/2010 These Petitions were called on for hearing today.

23

CORAM : HON'BLE MR. JUSTICE V.S. SIRPURKAR HON'BLE MR. JUSTICE CYRIAC JOSEPH For Petitioner(s) Mr. A.V.Palli, Adv. Ms. Ashwani Talwar, Adv. Mrs.Rekha Palli,Adv. Mr. Atul Sharma, Adv. Mr. A.K.Wadhawan, Adv.

Mr. Jasbir Singh Malik, Adv. Ms. Ekta Kadian, Adv. Ms. Meenakshi Mittal, Adv. Mr. S.K. Sabharwal, Adv.

For Respondent(s)

UPON hearing counsel the Court made the following

O R D E R

Issue notice on the applications for condonation of delay as well

as on the special leave petitions.

(Shashi Sareen) (Shashi Bala Vij) Court Master Court Master

//true copy//

24

ANNEXURE P-1



REVIEW PETITION (C) NOS. 2045-2052 OF 2010IN

SPECIAL LEAVE PETITION (C)Nos.14249-14256/2010

SURESH GARG & ETC . Petitioners

VERSUS

STATE OF HARYANA & ANR. Respondent

O R D E R

Delay condoned.

We have gone through the review petitions and the connected

papers. We find no merit in these review petitions and the same are

dismissed.

........................J. ( R.V. RAVEENDRAN )

........................J. ( H.L. GOKHALE )

NEW DELHI,DECEMBER 9, 2010.

//true copy//

25

IN THE SUPREME COURT OF INDIACIVIL APPELLATE JURISDICTION



IN


IN THE MATTER OF:


Versus


AFFIDAVIT

I, Suresh Garg, son of Shri Om Parkash, Resident of House No. 730, HUDA

Part-I, Sector-11, Panipat, (Haryana), at present at New Delhi, do hereby

solemnly affirm and state as under:

1. That I am the Petitioner No. 1 in the abovesaid Curative Petition and as

such I well acquainted with all the facts and circumstances of the case

and am duly competent to swear this affidavit on all the Petitioners.

2. I state that I have read and understood the contents of the

accompanying Curative Petition are true to my knowledge and

paragraphs are prayers before this Hon’ble Court.

3. I also state that the Annexures annexed with the Curative Petition are

true copies of their respective originals and form part of the record of

the Courts below.

4. That the facts stated herein above are true to my knowledge and no

part of it is false and no material facts have been concealed therefrom.

Verified at New Delhi on this 15th day of February, 2011

DEPONENT26

Documents

Curative Petition