Application 482

1
IN THE HON’BLE HIGH COURT OF DELHI AT NEW DELHI

I.A. NO. _______________ OF 2018
IN
Crl.M.C. No. _______ of 2018
IN THE MATTER OF :
ASHA AJMANI PETITIONER
Versus
STATE & Anr. RESPONDENT
APPLICATION U/S 482 OF THE CR.PC TO BRING ON RECORD

ADDITIONAL DOCUMENTS.
MOST RESPECTFULLY SHOWETH:
1. The Present Petition is pending disposal before this Hon’ble

Court. The Petitioner by the present application is seeking
permission of this Hon’ble Court to place on record the additional
documents for the reasons as enumerated hereafter.
2. It is submitted that Respondent No. 2 & 3 have executed a forged

Gift Deed dated 28.10.2015 and gotten it registered at the office of
Sub Registrar 1, Kashmere Gate, Delhi vide registration no. 9595 in
book no.1 volume no.5968 on pages 176 to 180 dated 30.10.2015,
with regards to the disputed property. The Petitioner has submitted
several complaints in this regard in different departments but no
relevant action taken by concerned authorities. By virtue of a
Forensic Handwriting report dated 22.02.2016, the authenticity of
the signatures of Late. Sh. Ram Avtar on Will dated 10.03.2004,
therein stated as Q1-Q2, was determined to be forged and fabricated
in comparison to the signature of the aforesaid person in one
affidavit attached with documents of shop dated 27.09.1995,
therein stated as S-1, S-2 and S-3.
In this context, the Forensic Handwriting report dated 22.02.2016
becomes relevant to establish the forgery and fraud committed by
the Respondent with respect to the Will dated 10.03.2004 and the
Gift Deed dated 28.10.2015, and therefore is a necessary document
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and the same is annexed to the accompanying petition as
Annexure-A/7.
3. It is submitted that the Petitioner had made a RTI application

dated 07.02.2018 to the Revenue Department, requesting to know
the status of ownership of the allotted property. It is submitted that
the Revenue Department in its reply dated 23.02.2018 to the above
stated application of the Petitioner clearly stated that a
rented/licensed property allotted to an individual cannot be further
transferred/registered or bequeathed by way of Sale Deed/ Gift
Deed without ownership rights. In view of the aforesaid opinion of
the Revenue Department, it becomes relevant to bring on record the
replies to the Petitioner’s RTI application. Accordingly, the copy of
replies from 21.06.2017 to 23.02.2018 to the RTI application are
annexed to the accompanying petition as Annexure-A/9( Colly.).
4. The Petitioner craves the leave of this Hon’ble Court to bring on

record these additional documents. The Petitioner submits that
these documents are essential for deciding the issue arising in the
above petition. It is in the interest of justice that this Hon’ble Court
may be pleased to permit the Petitioner to place on record the same.
PRAYER
It is, therefore, most respectfully prayed that this Hon’ble

Court may be pleased to:
(a) permit the Petitioner to bring on record the additional

documents marked as Annexure-A/7 and Annexure-A/9( Colly.) to
the accompanying petition.
(b) pass such other or further orders as may be deemed just and
proper by this Hon’ble Court on the facts and in the
circumstances of the case and in the interest of justice.
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Filed by :
A.K. Associates
Advocates & Legal Consultants
Ashish Chauhan & Kushagra Bansal

502, Sethi Bhawan, Rajendra Place,
New Delhi-110008
Ph. 9999468603, 9999448797
Email: ashishchauhan@akassociates.org.in
Place: New Delhi

Dated: 24.07.2018
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IN THE SUPREME COURT OF INDIA
CIVIL APPELLATE JURISDICTION
I.A. NO. _______________ OF 2009
IN
SPECIAL LEAVE PETITION (CIVIL) NO. 14997 OF 2009
IN THE MATTER OF :
Reliance Natural Resources Limited …Petitioner

Versus
Reliance Industries Limited …Respondent/Applicant
AFFIDAVIT
I, B. Ganguly, s/o (Late) Murari Mohan Ganguly, aged about

54 years, having my office at 5th Floor, Meridien Commercial Tower,
Windsor Place, New Delhi, do hereby solemnly affirm and state as
under: -
1. That I am the Senior Vice President of the Respondent

Company in the above matter and am conversant with the facts and
circumstances of the case and as such competent to swear this
affidavit on behalf of the Respondent.
2. That I have read the accompanying Application for bringing

on record additional documents and say that what is stated therein
is true to my knowledge and belief, based on office records.
3. The annexures filed along with the application are true copies
of their respective originals.
DEPONENT
VERIFICATION:
I, the deponent abovenamed, do hereby verify that the

contents of paras 1 to 3 of my above affidavit are true to my
knowledge, no part of it is false and nothing material has been
concealed therefrom.
Verified at New Delhi on this the 06th day of October 2009.
DEPONENT

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1

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

ASHA AJMANI PETITIONER

STATE & Anr. RESPONDENT

APPLICATION U/S 482 OF THE CR.PC TO BRING ON RECORD

MOST RESPECTFULLY SHOWETH:

1. The Present Petition is pending disposal before this Hon’ble

2. It is submitted that Respondent No. 2 & 3 have executed a forged

3. It is submitted that the Petitioner had made a RTI application

4. The Petitioner craves the leave of this Hon’ble Court to bring on

It is, therefore, most respectfully prayed that this Hon’ble

(a) permit the Petitioner to bring on record the additional

Advocates & Legal Consultants

Ashish Chauhan & Kushagra Bansal

Place: New Delhi

Reliance Natural Resources Limited …Petitioner

I, B. Ganguly, s/o (Late) Murari Mohan Ganguly, aged about

1. That I am the Senior Vice President of the Respondent

2. That I have read the accompanying Application for bringing

I, the deponent abovenamed, do hereby verify that the

Verified at New Delhi on this the 06th day of October 2009.

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