Virender Dev Dixit: Public Interest Litigation

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Virender Dev Dixit: Public Interest Litigation

Post22 Jan 2018

This is a copy of the 'Public Interest Litigation' filed on behalf of Seema Sharma's Foundation for Social Empowerment against Virender Dev Dixit and others.
IN THE HIGH COURT OF Delhi AT NEW Delhi

PUBLIC INTEREST LITIGATION

(CIVIL ORIGINAL JURISDICTION)

Writ Petition (Civil) No. ______ Of 2017

A WRIT PETITION IN PUBLIC INTEREST UNDER ARTICLE 226 OF THE CONSTITUTION OF India HIGHLIGHTING THE INACTION OF THE AUTHORITIES AGAINST THE ILLEGAL AND IMMORAL ACTIVITIES DONE BY RESPONDENT NO. 5 UNDER THE GARB OF RUNNING A SPIRITUAL ASHRAM

MEMO OF PARTIES

In the matter of Public Interest Litigation:
    Foundation for Social Empowerment,
    262, Second Floor, DDA Janta Flat,
    Khirki, New Delhi 110017.
VERSUS
    1. Union of India
    Through the Cabinet Secretary
    Cabinet Secretariat Rashtrapati Bhawan,
    New Delhi-110004

    2. NCT of Delhi
    Home Department
    5th Floor, C- Wing
    Delhi Secretariat,
    New Delhi-110001

    3. Commissioner of Police
    Police Headquarter,
    ITO, New Delhi

    4. Station House Officer
    P.S. Vijay Vihar,
    Rohini Sector- 5
    New Delhi.

    5. Mr. Virender Dev Dixit
    Founder and Spiritual Head
    Adhyatmik Vishwa Vidhyalya,
    A-1/351-352,
    Vijay Vihar, Rohini,
    New Delhi-110085.

    6. Adhyatmik Vishwa Vidhyalya,
    Through its Manager/Head
    A-1/351-352,
    Vijay Vihar, Rohini,
    New Delhi-110085.
    Through its Manager

    7. National Commission for Women,
    Plot No.21, FC33,
    Jasola Institutional Area,
    New Delhi-110025

    8. Delhi Commission For Women
    Govt. of NCT of Delhi
    C-Block, 2nd Floor,
    Vikas Bhawan I. P. Estate,
    New Delhi-110002.
RESPONDENTS

PETITIONER
through
    (SHALABH GUPTA & CO.)
    Advocates & Consultants
    6/3, LGF, Jangpura-B,
    Place: New Delhi. New Delhi-110014
    Dated: Ph.: 9818681699
IN THE HIGH COURT OF Delhi AT NEW Delhi

PUBLIC INTEREST LITIGATION

(CIVIL ORIGINAL JURISDICTION)

Writ Petition (Civil) No. ...... Of 2017

IN THE MATTER OF :
    Foundation for Social Empowerment ... Petitioner
    Versus
    Union of India & Ors. ... Respondents
A WRIT PETITION IN PUBLIC INTEREST UNDER ARTICLE 226 OF THE CONSTITUTION OF India HIGHLIGHTING THE INACTION OF THE AUTHORITIES AGAINST THE ILLEGAL AND IMMORAL ACTIVITIES DONE BY RESPONDENT NO. 5 UNDER THE GARB OF RUNNING A SPIRITUAL ASHRAM

To,
    THE HON’BLE CHIEF JUSTICE OF Delhi AND HER COMPANION JUDGES OF THE HON’BLE HIGH COURT OF Delhi, AT NEW Delhi
The Humble Petition of the Petitioner above-named

MOST RESPECTFULLY SHOWETH: -
    1. That the petitioner is filing the instant writ petition in public interest. The petitioner has no personal interest in the litigation and the petition is not guided by self-gain or for gain of any other person / institution / body and that there is no motive other than of public interest in filing the writ petition.

    2. That the petitioner has based the instant writ petition from information and documents made available through publically available documents, aggrieved families, websites of the Respondent No. 5 & 6 and various media reports circulating in the media pertaining to the Respondent No. 5 & 6.

    3. That the petition, if allowed, would benefit the citizens of this country generally as rule of law is essential for democracy and such brazen violation of law by Respondent No. 5 & 6 under the protection of the local administration is to the detriment of citizens as a whole. Since the aggrieved families mostly belong to low socio-economic strata and are mostly located away from Delhi having scattered presence, they are unlikely to approach this Hon’ble Court on this issue. Hence the petitioner herein is preferring this PIL.

    4. That through this PIL the Petitioner would like to bring to the notice of this Hon’ble Court various shady and illegal activities going on in the Adhyatmik Vishwa Vidhyalaya under the garb of providing a spiritual path to enlightenment. But in reality, the so called Ashrams of the respondent No. 5 & 6 have become a jail of sorts where women (both minor and major) are being detained and exploited by the respondent No. 5 & 6. These women are also kept under the influence of drugs and indoctrination, and are being used for the purpose of running a prostitution racket. The inmates of the Ashram are mostly women and all of them have been brought from various parts of the country.

    5. That recently the activities going on in the ashram campus situated at Vijay Vihar, Delhi came to The Knowledge of the public at large on or around 11.11.2017 when a family from Jhunjhnu, Rajasthan, visited the said Ashram to meet their daughter (name not disclosed herein) who had been detained at the Ashram since 09.11.2017. When the said family tried to meet their daughter, the Manager and other staff of the Ashram raised stiff resistance and did not allow the family to meet the girl. When the family raised hue and cry, some of the neighbours informed the media and police as well. Despite requests from the police, media persons, neighbours and family of the said girl, the staff of the Ashram did not allow them to meet the said girl. After a lot of scuffle and with the intervention of the large gathering who assembled there, the relatives of the said girl were allowed to come inside the Ashram. They had to cross atleast seven locked gates in order to reach the room where the said girl was kept. The said girl was visibly under a shock and it appeared that she was administered some intoxicating substance. Under the influence of the Ashram Staff, the said girl refused to go back with her relatives. The Media highlighted the plight of the said girl in various news channels.

    6. That after the media reports, various similarly aggrieved persons gathered outside the Ashram on 12.11.2017. One such victim shared her horrifying story with the media and also filed a complaint at P.S. Vijay Vihar which resulted in registration of an FIR No. 1353 dated 12.11.2017 under section 376(2)(n)/506 IPC against the head of the organization Mr. Virender Dev Dixit i.e. respondent No. 5. The victim gathered the courage to come forward after finding that there were various other victims like her who have been sexually exploited by the respondent No. 5. The victim was also tried to meet her younger Sister who has been entrapped by the respondent No. 5 & 6 and who has not been able to meet her family for the last many years. It is pertinent to mention here that the Medical examination of the said victim was conducted at BSA Hospital, which confirmed her allegations of rape. The FIR No. 1353 dated 12.11.2017 is annexed herewith as ANNEXURE P-1.

    7. That this is not the first FIR that has been lodged against Mr. Virender Dev Dixit - respondent No. 5 herein. It has been found out that earlier also various similar FIRs and complaints have been filed against the respondent No. 5 & 6. Most of the FIRs contain similar allegations that they were lured by the respondent No. 5 and his associates to visit the Ashrams of the respondent No. 5 & 6 under the pretext of seeking spiritual guidance. However, the respondent No. 5 committed rape upon the young girls (both minor and major), threatened them with dire consequences in case they told about the incidence to anyone, and has also kept them as prisoners in inhuman conditions in the Ashrams without giving any opportunity to them to go out of the Ashrams.

    8. That another similar case also came to The Knowledge of the petitioner pertaining to the same police station i.e. Vijay Vihar. In the said case, an FIR No. 88 dated 19.01.2017 has been registered under section 376(2)(n)/506/ 344/34 IPC inter-alia against the respondent No. 5. The complainant in the said case has alleged that she and her four daughters were raped by the respondent No. 5 at the Vijay Vihar Ashram. Even though the complainant managed to flee from the clutches of the respondent No. 5, but her daughters are still entrapped in the Ashram. She is not been allowed to meet her daughters, two of whom are minor. In the said FIR, she has also stated that various other girls have also been trapped by the respondent No. 5 under the pretext of giving them spiritual enlightment. It was also mentioned that the girls who are kept in various Ashram have been kept as prisoners without allowing them to meet or even talk to their relatives. FIR No. 88 dated 19.01.2017 is annexed herewith as ANNEXURE P-2.

    9. That another similar case of daughter of one Mr. Ram Reddy also came to The Knowledge of the petitioner. His daughter had been kept in the Ashram of respondent No. 6 for the last more than two years. As per his complaint bearing DD No. 39B dated 23.12.2015 made at P.S. Vijay Vihar, Delhi, his daughter is a Chemical Engineering scholar with a Ph. D and Post Doctorate from IOWA State University (USA) in nano technology as a research scientist, is an outstanding scholar, a national resource, dedicated to her profession and has made valuable research contributions to the society through her various nano experiments and articles. However, he came to know that his daughter was abducted from the USA in the beginning of July 2015 without any information to her parents and detained in the Ashram. When he tried to meet his daughter at the Ashram, he was not easily allowed to meet her. After waiting for several hours on every visit, the parents were allowed to meet their daughter only 5-6 times. Even during the meeting no privacy was given to him, and it appear that he was responding on the signals given to her by the people surrounding her. In his other complaints, he has stated that during the last 2-1/2 years he had been allowed to meet his daughter only 5-6 times that too after so much persuasion. He had also made complaint to the National Commission for Women on 04.11.2016 and to Delhi Commission for Women on 09.05.2016 in this regard. The parents are now going through a turbulent life in the pursuit of his aim of getting his daughter free from the clutches of the respondent No. 5 & 6. His plight can be imagined from the fact that he has left his home at Telangana and is presently residing at a rented accommodation at Delhi under the hope that he will be able to get his daughter free from the evil control of the respondent No. 5 & 6. The DD No. 39B dated 23.12.2015 is annexed as ANNEXURE P-3.

    10. That a similar complaint has been made at P.S. Vijay Vihar vide DD No. 95B dated 05.09.2017 by one Mr. Santosh Sahu. In the said complaint he has stated that his daughter had some how come to the Ashram of respondent No. 5 & 6. When he and his wife came to know about the same, they visited the Ashram of respondent No. 6 and they were allowed to meet their daughter after waiting for nearly 5-6 hours. They were taken to third or fourth floor of the Ashram where they found iron gates on various places. When they crossed one gate, the said gate was locked again before they could enter another gate. In the same fashion they were made to cross 3-4 gates to reach a Hall where their daughter was sitting along with 5-6 other women. Their daughter had expressionless face and she was only repeatedly saying that she had come there with her own will. It appears that she had been brain washed and kept in the Ashram. The said Mr. Santosh Sahu also made complaints to various authorities including National Commission for Women requesting them to save his daughter. DD No. 95B dated 05.09.2017 is annexed as ANNEXURE P-4.

    11. That a list of the cases/FIRs which have so far come to The Knowledge of the petitioner are summarized as below:-
      S. No. FIR No. & Date Under Section Police Station Name of Accused Complainant
      1. 47/98 16.04.1998 376, 376(G), 114 IPC Farukhabad, UP Virender Dev Dixit, Shanta Kumari Tara Devi
      2. 48/98 17.04.1998 376, 376(G), 114 IPC Farukhabad, UP Virender Dev Dixit, Shanta Kumari, Ravinder Dass, KamalaDixit Jaya Bhardwaj
      3. 58/98 28.04.1998 376/376(G)/114/506 IPC Farukhabad, UP Virender Dev Dixit, Shanta Kumari, Kamla Devi Dixit Meena Kumari
      4. 68/98 14.05.1998 376, 376(G), 114 IPC Farukhabad, UP Virender Dev Dixit, Shanta Behan Renuka
      5. 1809/11 09.12.2011 363,366 IPC Kolhui, Mahraj Ganj Sonu @/o Ram Naman Rajinder Prasad
      6. 88/11 419, 420, 364,342,504,506, 120B IPC Kolhui, Mahraj Ganj Virender Dev Dixit Rajinder Prasad
      7. 88/17 19.01.2017 376(2)(N), 506, 344, 34 IPC Vijay Vihar, Delhi Virender Dev Dixit Urmila Mata
      8. 1353/17 12.11.2017 376(2)(N), 506IPC Vijay Vihar, Delhi Virender Dev Dixit Rachna
      9. 0894/2017 21.11.2017 367/344 IPC Kotwali Nagar, Banda, UP Hemant Ram, Virender Dev Dixit Brijesh Bhushan
      10. 0149/17 24.11.2017 506 IPC Kotwali Nagar, Banda, UP Sita Ram, Rekha Ram, Kushal Rai etc. Shanti Devi @ Sunita
    12. That apart from the above FIRs, certain daily diary entries have also been found out which have probably not been culminated into the registration of an FIR which are as under:-
      1. D.D. No. 47B dated 27.10.2012 P.S. Vijay Vihar Delhi filed by Ramvati Kushwaha

      2. D.D. No. 49B dated 07.12.2016 P.S. Vijay Vihar Delhi filed by G.T.B. Hospital (pertaining to a lady jumping from terrace of Ashram while trying to escape rape attempt)

      3. D.D. No. 81B dated 04.03.2017 P.S. Vijay Vihar Delhi, by PCR Cell under section 176 Cr.P.C.

      4. D.D. No. 94B dated 11.11.2017 P.S. Vijay Vihar Delhi by residents of area.

      5. D.D. No. 56B dated 15.12.2016 P.S. Vijay Vihar Delhi by Ramreddy D and Meenavathi D. The D.D. No. 56B is annexed herewith as ANNEXURE P-5.
    13. That record pertaining to DD No. 49/B dated 7.12.2016 registered at P.S. Vijay Vihar, Delhi have also been obtained by the petitioner. The said DD entry shows that one lady had jumped from the terrace of the premises of respondent No. 6 Ashram while trying to flee from rape attempted on her at the terrace by someone. The said victim was taken to GTB Hospital for treatment and MLC No. 1892/16 was prepared. However, no other record of the said DD entry could be obtained by the petitioner. DD No. 49/B dated 7.12.2016 is annexed herewith as ANNEXURE P-6.

    14. That record pertaining to DD No. 81/B dated 4.3.2017 lodged at P.S. Vijay Vihar reveals that a female resident who was staying at the premises of respondent No. 6 Ashram had committed suicide by hanging herself. An inquiry under section 176 Cr.P.C. was conducted into the cause of death of the deceased by the Ld. SDM, Rohini, New Delhi. In the said inquiry it was noticed that “Some irregularities has been found between the statement of Sister Vinodini and the statement made by Sisters Anita and Sister Vandana. Further the campus of the spiritual university was under CCTV surveillance (the hard disk which was siezed has not been investigated) and hence the police may investigated the CCTV footage if the need be. Some unusual behavior (like some super natural personality/human shadow was following her and dominating her mind) by the deceased for two-three days before her death had also come into notice as told by all three Sisters whose statements on record. The same may be investigated by the police”. No further records of any investigation done by the police pertaining to the CCTV footage or the unusual behavior of the deceased could be traced out by the petitioner. However, the relevant fact is that one of the inmates of respondent No. 6 Ashram had allegedly committed suicide for the reasons which are beyond the comprehension of the mind of a man of ordinary prudence. It is quite evident that something really unusual and suspicious is happening inside the premises of the respondent No. 6. DD No. 81/B dated 04.03.2017 is annexed herewith as ANNEXURE P-7 and the Final Inquest Report under section 176 Cr.P.C. of DD No. 81/B is annexed herewith as ANNEXURE P-8(colly).

    15. That the high links of the respondent No. 5 & 6 are clear from the reports pertaining to a search warrant under section 97 Cr.P.C. dated 21.11.2017 issued by Ld. SDM, Surajgarh, Distt. Jhunjhunu, Rajasthan. It is pertinent to mention here that as per the directions containing in the said search warrants, the concerned police official had visited the premises of respondent No. 6 to conduct the search operations. However, despite best efforts of the said police officials, the police was not allowed to carry out their job and had to leave empty handed without searching the premises of respondent No. 6.

    16. That as per the contents of various complaints, FIRs, media reports etc., it has been revealed that the inmates at the premises of respondent No. 6 are kept in a pathetic condition. In the aforementioned ashram campus, the women are being kept in very small rooms with no proper ventilation. They are being subjected to very high mental abuse so as to break down their spirits. Girls from various far flung parts of the country are being kept in the ashram campus. These women are being subjected to a lot of indoctrination at the hands of ashram officials which portrays that the head of the organization (respondent No. 5) is Lord Krishna and places the women inmates in the category of his ‘Gopis’.

    17. That the respondent No. 5 and his organization i.e. respondent No. 6 have been repeatedly accused of committing offences against women devotees. Very recently an ashram run by the same organization was raided and the Manager was arrested. An FIR dated 21.11.2017 has been lodged against the accused and his organization therein accusing Mr. Virender Dev Dixit of running a sex racket under the garb of a spiritual organization.

    18. That there have been various reports and complaints from neighboring area of the ashram campus of respondent No. 6 specifying how in the middle of night women from the ashram are brought and taken away in packed cars. This keeps going on till the early hours of the morning without any hindrance. What is surprising is the carefree and insensitive attitude of the police officials under whose nose all of this has been going on. It is submitted that the neighbors of the ashram are fed up with the activities going on in the ashram and have filed various complaints to the SHO concerned but nothing has been done against Mr. Virender Dev Dixit and his organization. A recent complaint in this regard has been filed by the residents of the area against the respondent No. 5 & 6.

    19. That the abovementioned circumstances raise a stink as to the activities going on in the ashram. What is even more curious is the fact that the parents of these women are not being allowed to meet them by the ashram authorities. The parents of these girls repeatedly try to meet their daughters but they meet strict resistance from the Ashram staff. The parents/relatives are usually left with no option but to return back to their home without meeting their children at the Ashram. By any off chance the parents are allowed to meet their ward, they are made to wait almost for 3-4 hours in one of the dingy rooms. Then the parents/relatives are made to pass through 6-7 doors and the same are locked from behind when the parents/relatives are meeting their children. This is obviously a trick to avoid any of the inmates leaving the ashram with their relative even if she so chooses. Moreover, there are almost 7-8 women accompanying the inmate during the short meeting between the family members and the inmate is not allowed to speak freely. Various complaints have been filed by the parents of these girls before various forums such as the SHO of the concerned Police Station, National Commission for Women, Delhi Commission Women, National Human Right Commission and Prime Minister’s Office but to no avail. Copy of complaint made to NCW by Mr. D. Ram Reddy is Annexed herewith as ANNEXURE P-9. Copy of complaint made to Hon'ble Prime Minister by Mr. D. Ram Reddy is Annexed herewith as ANNEXURE P-10. Copy of complaint made to DCW by Mr. D. Ram Reddy is Annexed herewith as ANNEXURE P-11. Copy of letter written by NCW after receipt of complaint of Mr. D. Ram Reddy is annexed as ANNEXURE P-12. Mr. D. Ram Reddy also wrote complaint to the SHO, P.S. Vijay Vihar, Delhi on 01.04.2016 which is annexed as ANNEXURE P-13.

    20. That all over north India there have been various media reports against the illegal activities that have been committed under the garb of running ashram. There have been various cases and complaints filed against the officials of the ashram for abduction of children from their houses. There have been widespread allegations of a sex racket being run in the ashrams of the organization. There was a report stating an ashram in Farukhhabad where in 60 girls were rescued from that ashram. The organization has been in limelight for one scandal or another however, the police authorities must be given due credit for not been able to prosecute either Mr. Virender Dev Dixit or any one of his associates or to shut down the ashrams and rescue the inmates.

    18. That the parents and relatives of the inmates have been running from pillar to post and have not been able to get either daughters back or have any action taken against the Mr. Virender Dev Dixit or his organization for ruining the lives of so many young women through his illegal and immoral activities. The situation in this ashram is similar to those in the ashrams of Baba Ram Rahim and Baba Rampal. But the same is even further worsened by the rampant allegations of sexual misconduct and sex trafficking on part of the organization’s head Mr. Virender Dev Dixit. A thorough investigation needs to happen regarding the activities being carried out in the ashrams of the Respondent No. 5. The Respondent no. 5 has been allowed so long to carry out these illegal activities with tacit acquiescence of the local authorities. So the Petitioner prays that this Hon’ble Court may be pleased to order the investigation into various crimes committed by the Organization either to CBI or initiate a court monitored SIT to look into all the allegations leveled against the Respondents no. 5 & 6.

    19. That the Petitioner prays that the Hon’ble Court be pleased to direct any Ld. Judge of the concerned district to visit the ashram premises and file a report on the conditions in which the girls are living in the ashram. The same is necessary so as to throw light on conditions under which the inmates are being kept in. The Hon’ble Madras High Court had done the same in Mrs. K. Sathiajothi vs State of Tamil Nadu (H.C.P. No. 1656 of 2016) wherein the principal judge of Coimbatore was sent into the ashram of ISHA Foundation to record the statement of the detenues and file a detailed report as to whether the detenues were in fact being detained illegally or not.

    20. That the detenues of the ashram are being kept in an agonizing environment. Their parents are not being made to meet their daughters irrespective of them being minor or major. The petitioner fears that the agents of the Mr. Virender Dev Dixit are day in and day out trying to mind wash the detenues against their parents. The petitioner humbly pray that the detenues be kindly shifted to some other social welfare institution where they’re taken care of properly. The parents of the inmates have been trying their level best to get their daughters freed from the clutches of the Respondents No. 5 & 6 so that they can enjoy their life as they wish too. If they wish to pursue the spiritual path then no one has any qualms with that but the same ought not be pursued through such shady means. The petitioner however pray that the custody of the minor daughters be given immediately back to their parents as the Respondents No. 5 & 6 have absolutely no right to keep the minor daughters away from their parents under the garb of spirituality.

    21. That the Petitioner submits the finding written in the Inquest Report filed Under section 176 of the Cr.P.C. by the Ld. SDM in case of suicide of one the detenues. It clearly observes that the deceased was seeing certain supernatural beings or shadows following her right before her death. This clearly points towards either high level of mental abuse or administration of drugs to the deceased which led to her taking her own life or to some foul play. The petitioner prays this Hon’ble Court to get the detenues medically examined to ascertain the type of physical and mental abuse they’ve been subjected to.

    22. That the petitioner submits that the way these women are being kept is worse than farm animals are kept. Article 21 of our constitution gives everyone a right to live life with dignity. The petitioner beseech this Hon’ble Court to protect the rights of the detenues by protecting violation of their right to freedom and give directions to the concerned authorities to get the detenues free from the clutches of the respondents No. 5 & 6 immediately.

    23. That the respondents No. 7 & 8 should be directed to submit a detailed report thereby advising the Government about passing of certain rules, regulation and law to foresee the activities of various ashrams including that of respondent No. 6. It is an urgent need that the activities of the ashrams be governed by some law so that similar incidences are not repeated in future.

    24. That the inaction of the Respondent No. 1 to 4 against various activities of Respondent No. 5 is arbitrary and without any just excuse.

    25. That the writ petitioner has no personal interest in the litigation and that the petition is not guided by self-gain or for gain of any other person/institution/body and that there is no motive other than of public interest in filing the writ petition.

    26. That the persons for whose benefit the petition has been filed are the citizens of this country. The aggrieved families mostly belong to low socio-economic strata and are mostly located away from. These families are incapable of accessing the courts themselves.

    27. That the writ petition of the persons/bodies/ institutions likely to be affected by the orders sought in the writ petition and which shall be impleaded as respondents and to The Knowledge of the petitioner no other person/bodies/ institution are likely to be affected by the orders sought in the writ petition.

    28. That the petitioner has means to pay the costs, if any, imposed by the court and on an undertaking to the court in that respect.

    29. That petitioner has no other efficacious remedy except to approach this Hon'ble Court by way of this writ petition under Art.226 of the Constitution of India.

    30. That the petitioner has not filed any other petition, claim, suit or proceeding in any court or tribunal throughout the territory of India regarding the matter in dispute.

    PRAYER

    In view of the facts & circumstances stated above, it is prayed that this Hon’ble Court in public interest may be pleased to: -
      a. Direct a thorough court-monitored investigation by SIT or the CBI into the various activities being carried out in various campuses of the respondent No. 6.

      b. Direct the inspection of the ashram premises of the respondent no. 6 through the Principal judge of the said district and to file a detailed report as to the living conditions of the detenues.

      c. Direct immediate release of the detenues/inmates of the respondent No. 6 and handing over of their custody to any NGO, Nari Niketan etc. where they can be taken care of free from any influence of the agents of the Respondents No. 5 & 6.

      d. Direct the police authorities to collect the information of all the detenues of the ashram of respondent No. 6 and send the information of the detenues to their parents in as much as many of them might not be even aware about the whereabouts of their daughters.

      e. Direct the concerned authorities to conduct the medical examination of the detenues to find out whether they have been physically or mentally exploited or not.

      f. Direct the sealing of the ashram campus of the respondent No. 6.

      g. Direct the respondent No. 7 & 8 to furnish a detailed report to the concerned authorities on the measures which can be taken to prevent the similar ashrams from carrying out any illegal activities in their ashrams by bringing them under certain rules and regulations which can be made applicable in the ashrams.

      h. Grant any other and further relief(s) which this Hon’ble Court may deem fit and proper in the facts and circumstances of the present case.
PETITIONER

through
    (SHALABH GUPTA & CO.)
    Advocates & Consultants
    6/3, LGF, Jangpura-B,
    Place: New Delhi. New Delhi-110014
    Dated: Ph.: 9818681699
IN THE HIGH COURT OF Delhi AT NEW Delhi
(CIVIL ORIGINAL JURISDICTION)

PUBLIC INTEREST LITIGATION

Writ Petition (Civil) No. ____________ Of 2017

IN THE MATTER OF :
    Foundation for Social Empowerment ... Petitioner
    Versus
    Union of India & Ors. ... Respondents
I N D E X

S.NO. PARTICULARS COURT FEES PAGES
    1. Urgent Application

    1

    2. Memo of parties

    2- 3

    3. Notice of motion

    4

    4. A Writ Petition in Public Interest under Article 226 of the Constitution of India highlighting the inaction of the authorities against various illegal and immoral activities done by Respondent No. 5 & 6 under the garb of running an spiritual ashram

    5 – 27

    5. Annexure P-1 :

    FIR No. 1353 dated 12.11.2017 with its true typed copy

    28 - 36

    6. Annexure P-2 :

    FIR No. 88 dated 19.01.2017 with its true typed copy

    37 – 50

    7. Annexure P-3 :

    DD No. 39B dated 23.12.2015 with its true typed copy

    51 - 54

    8. Annexure P-4 :

    DD No. 95B dated 05.09.2017 with its true typed copy

    55 - 67

    9. Annexure P-5 :

    D.D. No. 56B dated 15.12.2016 with its true typed copy

    68 - 72

    10. Annexure P-6 :

    DD No. 49/B dated 7.12.2016 with its true typed copy

    73 - 74

    11. Annexure P-7:

    DD No. 81/B dated 04.03.2017 with its true typed copy

    75 - 76

    12. Annexure P-8 (Colly):

    Final Inquest Report under section 176 Cr.P.C. of DD No. 81/B with its true typed copy

    77 - 87

    13. Annexure P-9 :

    Complaint dated 27.09.2016 to the Chairperson NCW, Jasola, Delhi by D. Ram Reddy
    with its true typed copy

    88 - 92

    14. Annexure P-10 :

    Complaint dated 27.09.2016 to the Hon'ble Prime Minister, Govt. of India by D. Ram Reddy
    with its true typed copy

    93 - 97

    15. Annexure P-11 :

    Complaint dated 09.05.2016 to the Delhi Commission for Women by D. Ram Reddy
    with its true typed copy

    98 - 104

    16. Annexure P-12 :

    Letter dated 04.11.2016 of National Commission for Women written to Mr. Alok Rawat, IAS (retd.) in response to the complaint of Mr. D. Ram Reddy with its true typed copy

    105 - 107

    17. Annexure P-13 :

    Complaint dated 01.04.2016 to the SHO, P.S. Vijay Vihar, Delhi by Mr. D. Ram Reddy
    with its true typed copy

    108 - 114

    18. Certified true copy of the authorization letter

    19. Vakalatnama
PETITIONER

through
    (SHALABH GUPTA & CO.)
    Advocates & Consultants
    6/3, LGF, Jangpura-B,
    Place: New Delhi. New Delhi-110014
    Dated: Ph.: 9818681699
IN THE HIGH COURT OF Delhi AT NEW Delhi
(CIVIL ORIGINAL JURISDICTION)
Writ Petition (Civil) No. ...... Of 2017

PUBLIC INTEREST LITIGATION

IN THE MATTER OF :
    Foundation for Social Empowerment ... Petitioner
    Versus
    Union of India & Ors. ... Respondents
URGENT APPLICATION
    The Deputy Registrar,
    High Court of Delhi,
    New Delhi.
Sir,

Kindly treat the accompanying petition as urgent according to the Delhi High Court Rules as the relief for stay of proceedings before the Trial Court has been prayed for.
PETITIONER

through
    (SHALABH GUPTA & CO.)
    Advocates & Consultants
    6/3, LGF, Jangpura-B,
    Place: New Delhi. New Delhi-110014
    Dated: Ph.: 9818681699
IN THE HIGH COURT OF Delhi AT NEW Delhi
(CIVIL ORIGINAL JURISDICTION)


Writ Petition (Civil) No. ____________ Of 2017

PUBLIC INTEREST LITIGATION

IN THE MATTER OF :
    Foundation for Social Empowerment ... Petitioner
    Versus
    Union of India & Ors. ... Respondents

AFFIDAVIT

I, Seema Sharma, D/o Mr. Gulab Singh, Trustee, Foundation for Social Empowerment, 262, Second Floor, DDA, Janta Flat, Khirki, New Delhi, aged about 32 years, do hereby solemnly affirm and declare as under:
    1. The petitioner is a Trust having its registered office at 262, Second Floor, DDA, Janta Flat, Khirki, New Delhi, am a trustee of the Petitioner, and I have been authorized vide resolution passed in the Meeting of the General Body of the Trust to institute and sign this petition.

    2. I have filed the present petition as a Public Interest Litigation.

    3. I have gone through the Delhi High Court (public Interest Litigation) Rules, 2010 and do hereby affirm that the present Public Interest Litigation is in conformity thereof.

    4. The petitioner has no personal interest in the litigation and neither myself nor anybody in whom I am/petitioner is interested would in any manner benefit from the relief sought in the present litigation save as a member of the General Public. This petition is not guided by selfgain or gain of any person, institution, body and there is no motive other than of public interest in filing this petition.

    5. I have done whatsoever inquiry/investigation which was in my power to do, to collect all data/material which was available and which was relevant for this court to entertain the present petition. I further confirm that I have not concealed in the present petition any data/material /information which may have enabled this court to form an opinion whether to entertain this petition or not and/or whether to grant any relief or not.
DEPONENT

VERIFICATION:

Verified at New Delhi on this _____ day of December 2017 that the contents of the aforesaid affidavit are true and correct to my knowledge, no part of it is false and nothing material has been concealed therefrom.
DEPONENT

IN THE HIGH COURT OF Delhi AT NEW Delhi
(CIVIL ORIGINAL JURISDICTION)
Writ Petition (Civil) No. ...... Of 2017

PUBLIC INTEREST LITIGATION

IN THE MATTER OF :
    Foundation for Social Empowerment ... Petitioner
    Versus
    Union of India & Ors. ... Respondents
NOTICE OF MOTION


Kindly take notice that the accompanying petition will be listed before Court on ________ at 10:30 AM in the forenoon or so soon thereafter as may be convenient to the Hon’ble Court.

Place: New Delhi
PETITIONER

Dated:

through
    SHALABH GUPTA & CO.
    Advocates & Consultants
    6/3, LGF, Jangpura-B
    New Delhi – 110014
    M.: 9818681699

To,
    The Standing Counsel (Criminal)
    National Capital Territory of Delhi,
    Delhi.

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