Page 1 of 29 IN THE HIGH COURT OF DELHI AT NEW DELHI CIVIL WRIT JURISDICTION W.P. (CIVIL) No. of 2020 In the matter of A Public Interest Litigation: 1. Susheel Mahajan ….…..Petitioner VERSUS 1. Ministry of Health and Family Welfare Union of India and Anr. …….Respondents INDEX – I S.No. PARTICULARS PAGE NO. 1. Brief facts of the case 2. Memo of Parties 3. Public Interest Litigation by way of Affidavit INDEX - II S.No. Description of Documents as annexed 1. ANNEXURE – I List of places of Delhi Containment zones. 2. ANNEXURE – II World Health Organization Guidelines to deal with Covid - 19 . 3. ANNEXURE – III Guidelines and directions issued by Government of India to deal with the pandemic Covid – 19. 4. ANNEXURE – IV (Colly) Guidelines with regard to use of disinfectants. 5. ANNEXURE –V Guidelines issued by NCDC 6. ANNEXURE – VI Email to Secretary Health and Family Welfare 7. ANNEXURE – VII Email to Commissioner of Police regarding non following of guidelines by UOI by private persons and endangering the life of citizens
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Page 1 of 29
IN THE HIGH COURT OF DELHI AT NEW DELHI CIVIL WRIT JURISDICTION
W.P. (CIVIL) No. of 2020
In the matter of A Public Interest Litigation:
1. Susheel Mahajan ….…..Petitioner
VERSUS
1. Ministry of Health and Family Welfare Union of India and Anr. …….Respondents
INDEX – I
S.No. PARTICULARS PAGE NO. 1. Brief facts of the case 2. Memo of Parties 3. Public Interest Litigation by way of Affidavit
INDEX - II
S.No. Description of Documents as annexed 1. ANNEXURE – I
List of places of Delhi Containment zones.
2. ANNEXURE – II World Health Organization Guidelines to deal with Covid - 19 .
3. ANNEXURE – III Guidelines and directions issued by Government of India to deal with the pandemic Covid – 19.
4. ANNEXURE – IV (Colly) Guidelines with regard to use of disinfectants.
5. ANNEXURE –V Guidelines issued by NCDC
6. ANNEXURE – VI Email to Secretary Health and Family Welfare
7. ANNEXURE – VII Email to Commissioner of Police regarding non following of guidelines by UOI by private persons and endangering the life of citizens
Page 2 of 29
8. ANNEXURE – VIII Email to Secretary Health, Government of National Capital Territory of Delhi regarding non implementation of guidelines as prescribed by Government of India.
9. ANNEXURE – IX Precautionary measurements to be taken while disinfecting the places.
10. ANNEXURE – X Making tunnels to sanitize the public in violation of the rules
11. ANNEXURE – XI Direct effect of sanitization without precaution
12. ANNEXURE – XII Some important photographs with respect to sanitization
13. ANNEXURE – XIII Myth buster examples
14. ANNEXURE – XIV Vehicles catching fire because of sanitizers
15. Application for exemption as prayed in Prayer
Petitioner Through
Dr. N. Pradeep Sharma & Harsh K Sharma,
Advocates for Petitioners 5, Jungpura Road, Bhogal Jungpura, New Delhi -110014 Contact: 9899696333
VERSUS 1. Ministry of Health and Family Welfare Shastri Bhawan, New Delhi. (Through its Secretary) 2. Ministry of Health & Family Welfare New Secretariat, ITO, Govt. of NCT, New Delhi. (Through its Secretary) 3. The Commissioner of Police, Police Head Quarter, ITO, New Delhi …….Respondents
Petitioner
Through
Dr. N. Pradeep Sharma & Harsh Kumar Sharma Advocates for Petitioner
5,Jungpura Road, Bhogal Jungpura, New Delhi – 110014.
IN THE HIGH COURT OF DELHI AT NEW DELHI CIVIL WRIT JURISDICTION
W.P. (CIVIL) No. of 2020
In the matter of A Public Interest Litigation:
1. Susheel Mahajan ….…..Petitioner
VERSUS
1. Ministry of Health and Family Welfare Union of India and Ors. …….Respondents
AFFIDAVIT ON BEHALF OF THE PETITIONER
I, Susheel Mahajan S/o Late. Tara Chand, R/o C-525, DDA
Janta Flats, Pocket No. 11, Jasola, New Delhi– aged about
50 years, do hereby solemnly affirm and state as follows:
1. That the Petitioner is a social activist and is also a practicing
lawyer at various courts of Delhi and other states and has also
been practicing Advocates at Supreme Court and other High
Courts of India, for about four years and is a well known figure
in the legal fraternity and in order to extend my duties towards
the nation by filing the present PIL and as such I am well
acquainted and conversant with the facts and circumstances of
the case and I am competent to swear to this affidavit.
2. That the present writ petition is being filed by the undersigned
being Petitioner. The Hon’ble Court would be assisted by my
Page 8 of 29
Counsels on my instructions. By way of present Public Interest
Litigation, for issuance of an Order or a Writ, more in the
nature of a Writ of Mandamus, directing the Respondents to
implement all necessary steps as advised and declared by the
World Health Organization and the advisory issued by
Government of India, to its States for proper implementation of
the Guidelines passed by World Health Organization to deal
with the pandemic Corona - 19, in the interest of justice and
thus render justice.
3. That the present PIL (Writ Petition) has been filed by the
Petitioner to the effect that petitioner has no personal interest in
the litigation and the petitioner is not guided by self- gain or for
gain of any other person / institution / body and thus there is no
motive other than of public interest litigation save as a member
of the General Public in the present PIL (Writ Petition).
4. That the class persons for whose benefit the petition has been
filed and as to such persons are incapable of accessing the
Courts themselves due to their inability to approach the system
of justice because of lockdown due to epidemic COVID – 19.
5. That the petitioner has done whatsoever inquiry / investigation /
collected documents, 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
Page 9 of 29
that I have not concealed in the present petition any data /
material / information which may have enabled this Hon’ble
Court to form an opinion whether to entertain this Petition or
not and or whether to grant any relief or not.
6. Brief Facts leading to the filing of the Writ Petition(PIL):
(I) COVID – 19; THE SPRAYING OF DISINFECTANT IS A
CURSE AND NOT A BLESSING, AS PER INTERIM GUIDELINES OF WORLD HEALTH ORGANIZATION (WHO) DATED MAY 15, 2020. That currently, the entire world is facing with an
unprecedented situation due to the global breakout of the
COVID 19 virus, commonly known as the Corona virus. Under
these circumstances, even our entire country has been kept in
lockdown, and the citizenry have been forced to keep indoors. It
is submitted that the health care staff i.e. the Health Warriors,
who have been thus deployed for maintaining health of the
citizens by endangering their lives. This is putting the health
care workers, directly in the front line, and making them
vulnerable to contracting COVID – 19.
(II) That as per the Interim guidance dated15 May 2020 issued by
the World Health Organization, regarding the Cleaning and
disinfection of environmental surfaces in the context of
COVID-19, it has been recommended and said that the spraying
or fumigation of outdoor spaces, such as streets or marketplaces
Page 10 of 29
are not recommended to kill the Covid -19 virus or other
pathogens because disinfectant is inactivated by dirt and debris
and it is not feasible to manually clean and remove all organic
matter from such spaces.
(III) That one study has shown that spraying as a primary
disinfectant is ineffective in removing contaminants outside of
(IV) That moreover the spraying disinfectants can result in risks to
the eyes, respiratory or skin irritation and the resulting health
effects.
REF:39
Mehtar, S., Bulabula, A.N.H., Nyandemoh, H., Jambawai, S., 2016. Deliberate exposure of humans to chlorine-the aftermath of Ebola in West Africa. Antimicrob Resist Infect Control 5, 45. (https://doi.org/10.1186/s13756-016-0144-1, accessed 6 May 2020)
(V) That it has been found that the spraying individuals with
disinfectants (such as tunnel, cabinet or chamber) is not
(VI) That this could be physically and psychologically harmful and
would not reduce an infected person’s ability to spread the virus
through droplets or contact. Moreover spraying individuals with
chlorine and other toxic chemicals could result in eye and skin
irritation, bronchospasm due to inhalation and gastrointestinal
eggects such as nausea and vomiting.
REF:40,45
Zock, J.-P., Plana, E., Jarvis, D., Antó, J.M., Kromhout, H., Kennedy, S.M., Künzli, N., et al., 2007. The Use of Household Cleaning Sprays and Adult Asthma: An International Longitudinal Study. Am J Respir Crit Care Med 176, 735–741. (https://doi.org/10.1164/rccm.200612-1793OC, accessed 6 May 2020)
ALSO Benzoni, T., Hatcher, J.D., 2020. Bleach Toxicity, in: StatPearls. StatPearls Publishing, Treasure Island (FL). (https://www.ncbi.nlm.nih.gov/books/NBK441921/, accessed 6 May 2020)
(VII) That health workers are deployed in red zone / Hot Spot /
containment areas for collection of samples of the affected
persons are more susceptible to COVID-19. The present
petition is being filed to ensure that the Union of India and
Government of NCT of Delhi to take steps to give incentives to
them for taking the risk and facing the hardship. This more so,
when Delhi has been declared containment areas, and some
districts of Delhi have been designated red zones/Hotspot
therefore increasing the need and responsibility of the police
personnel to ensure that these areas continuously remain under
Page 12 of 29
lockdown, strictly. This is going to lead to a further work force
by the health workers.
(VIII) That devices using UV irradiation have been designed for
health-care settings. However, several factors may affect the
efficacy of UV irradiation, including distance from the UV
device; irradiation dose, wavelength and exposure time; lamp
placement; lamp age; and duration of use. Other factors include
direct or indirect line of sight from the device; room size and
shape; intensity; and reflection.
REF:5 Bennett, J.E., Dolin, R., Blaser, M.J. (Eds.), 2015. Mandell, Douglas, and Bennett’s principles and practice of infectious diseases, Eighth edition. ed. Elsevier/Saunders, Philadelphia, PA. (https://www.ncbi.nlm.nih.gov/pmc/articles/PMC7099662/, accessed 6 May 2020) (IX) That the Petitioner is seeking directions to the Ministry of
Health and Family Welfare, Govt. of India and GNCTD and
Delhi Police for proper implementation of the guidelines being
formulated by the World Health Organization. In consonance
with the guidelines as issued by WHO, to deal with the Corona
Virus, the Government of India, by way of advisory to its
States, have directed to follows certain step. These steps are
with regard to the sanitization of the places and the following a
due procedure for the same.
(X) That the Government of National Capital Territory of
Delhi has declared the containment zones in Delhi depending
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upon the number of cases in that particular area. Such list is
enclosed herewith for the perusal of this Hon’ble Court as
ANNEXURE - I.
(XI) That the Petitioner is seeking directions to the Ministry of
Health and Family Welfare, Govt. of India, Government of
National Capital Territory of Delhi and Commissioner of
Police, Delhi, for the proper implementation of the guidelines
with regard to the spraying / use of chemicals for sanitization of
public places / offices / individual etc. as per the guidelines of
World Health Organization. Such guidelines issued by the
World Health Organization is attached herewith for the perusal
of this Hon’ble Court as ANNEXURE -II.
(XII) That the Petitioner is seeking directions to various
authorities to effectively implement the advisories / directions
issued by the Government of India, with regard to the spraying /
use of chemicals for sanitization of public places / offices /
individual etc. as per the guidelines of World Health
Organization. Such guidelines issued by the Government of
India is attached herewith for the perusal of this Hon’ble Court
as ANNEXURE -III.
(XIII) That the guidelines with respect to the use of
disinfectants were also issued by the central government. Such
guidelines are annexed herewith for the perusal of this Hon’ble
Page 14 of 29
Court as ANNEXURE – IV. Some guidelines were also issued
by the NCDC, Government of India, which are annexed as
ANNEXURE – V.
(XIV) That by not doing so, the rights of the citizens which
have been guaranteed to the citizens, under Article 14 and 21 of
Constitution of India are infringement. The contents of Article
14 and 21 of Constitution of India are reproduced herewith for
the ready reference of this Hon’ble Court.
Article 14 of the Constitution of India provides for
equality before the law or equal protection of the laws
within the territory of India. ... "The State shall not deny
to any person equality before the law or the equal
protection of the laws within the territory of India."
Article 21 has a much wider meaning which includes
right to live with human dignity, right to livelihood, right
to health, right to pollution free air, etc. Right to life is
fundamental to our very existence and includes all those
aspects of life which go on to make a man's life
meaningful, complete and worth living.
(XV) That it is submitted that the sanitization of various places is
done on the behest of State by using certain chemicals or Ultra
violet procedures.
Page 15 of 29
(XVI) That By way of present Public Interest Litigation, the
Petitioner is trying to draw the attention of this Hon’ble Court
towards the non following of the guidelines as contemplated by
the World Health Organization to deal with COVID - 19.
Although the Government of India has issued advisories in this
effect, but it has been noticed by the Petitioner by way of
personal presence and also by way of the various media reports.
(XVII) That noticing the difficulties faced by the fellow citizen
of the country and feeling their apathy, the Petitioner preferred
to bring the problems being faced by the citizens, to the notice
of the Secretary, Ministry of Health and Family Welfare,
Government of India, by way of emails. The Petitioner did not
get any reply against that email from any authority. Such email
by the Petitioner to the Ministry of Health and Family Welfare,
Government of India is annexed herewith for the perusal of this
Hon’ble Court as ANNEXURE –VI.
(XVIII) That the Petitioner also apprised the Commissioner of
Police about the wrong practices adopted by various agencies
and requested him also to take remedial steps. No response has
been received by the Petitioner from the office of Police
Commissioner, Delhi Police also. Such email to the
Commissioner of Delhi Police is enclosed for the perusal of this
Hon’ble Court as ANNEXURE -VII.
Page 16 of 29
(XIX) That the Petitioner also preferred to bring the problems being
faced by the citizens, to the notice of the local Government i.e.
the Secretary, Ministry of Health and Family Welfare,
Government of NCT of Delhi by way of email. The Petitioner
did not get any reply against that email from any authority.
Such email by the Petitioner to the Principal Secretary, Ministry
of Health and Family Welfare, Government of NCT of Delhi is
annexed herewith for the perusal of this Hon’ble Court as
ANNEXURE –VIII.
(XX) That as per the guidelines issued by the World Health
Organization, Environment Protection Agency and Government
of India, 70% alcohol can be used to wipe down surfaces where
the use of bleach is not suitable. It has been recommended to
always use freshly prepared 1% sodium hypo-chloride solution
and wear appropriate PPE kit, while carrying out cleaning and
disinfection work. It is also recommended, to wear disposable
rubber boots, gloves (heavy duty), and a triple layer mask,
which should be removed and discarded after every use, to
minimize the possibility of infection. The disinfectants are used
to minimize the effect of infection. Such information is attached
herewith for the perusal of this Hon’ble Court as ANNEXURE
-IX.
(XXI) That the disinfectants are chemicals that destroy disease
causing pathogens or other harmful microorganisms. It is
Page 17 of 29
advised by WHO that Spraying of individuals or groups is NOT
recommended under any circumstances.
(XXII) That as per WHO guidelines, the Disinfectant solutions
should always be prepared in well-ventilated areas. Avoid
combining disinfectants, both during preparation and usage, as
such mixtures cause respiratory irritation and can release
potentially fatal gases, in particular when combined with
hypochlorite solutions.
(XXIII) That as per WHO guidelines, the personnel preparing or
using disinfectants in health care settings require specific PPE,
due to the high concentration of disinfectants used in these
facilities and the longer exposure time to the disinfectants
during the workday.49 Thus, PPE for preparing or using
disinfectants in health care settings includes uniforms with
long-sleeves, closed work shoes, gowns and/or impermeable
aprons, rubber gloves, medical mask, and eye protection
(preferably face shield).
Ref:48 Medina-Ramon, M., 2005. Asthma, chronic bronchitis, and exposure to irritant agents in occupational domestic cleaning: a nested case-control study. Occup Environ Med 62, 598–606. (https://doi.org/10.1136/oem.2004.017640, accessed 6 May 2020)
(XXIV) That as per WHO guidelines, the Hypochlorite is rapidly
inactivated in the presence of organic material; therefore,
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regardless of the concentration used, it is important to first
clean surfaces thoroughly with soap and water or detergent
using mechanical action such as scrubbing or friction. High
concentrations of chlorine can lead to corrosion of metal and
irritation of skin or mucous membrane, in addition to potential
side-effects related to chlorine smell for vulnerable people such
as people with asthma.
Ref:32 IL DIRETTORE GENERALE D’Amario, C. 2020. Disinfezione degli ambienti esterni e utilizzo di disinfettanti (ipoclorito di sodio) su superfici stradali e pavimentazione urbana per la prevenzione della trasmissione Dell’infezione da SARS-CoV-2. Ministero della Salute. (https://www.certifico.com/component/attachments/download/17156, accessed 6 May 2020)
(XXV) That as per WHO guidelines, the Spraying or fumigation
of outdoor spaces, such as streets or marketplaces, is also not
recommended to kill the COVID-19 virus or other pathogens
because disinfectant is inactivated by dirt and debris and it is
not feasible to manually clean and remove all organic matter
from such spaces. Moreover, spraying porous surfaces, such as
sidewalks and unpaved walkways, would be even less effective.
Even in the absence of organic matter, chemical spraying is
unlikely to adequately cover all surfaces for the duration of the
required contact time needed to inactivate pathogens.
Furthermore, streets and sidewalks are not considered to be
Page 19 of 29
reservoirs of infection for COVID-19. In addition, spraying
disinfectants, even outdoors, can be harmful for human health.
(XXVI) That the Spraying individuals with disinfectants (such as
in a tunnel, cabinet, or chamber) is not recommended under
any circumstances. This could be physically and
psychologically harmful and would not reduce an infected
person’s ability to spread the virus through droplets or contact.
Moreover, spraying individuals with chlorine and other toxic
chemicals could result in eye and skin irritation, bronchospasm
due to inhalation, and gastrointestinal effects such as nausea
and vomiting.
Ref:40,45 Zock, J.-P., Plana, E., Jarvis, D., Antó, J.M., Kromhout, H., Kennedy, S.M., Künzli, N., et al., 2007. The Use of Household Cleaning Sprays and Adult Asthma: An International Longitudinal Study. Am J Respir Crit Care Med 176, 735–741. (https://doi.org/10.1164/rccm.200612-1793OC, accessed 6 May 2020)
AND
Benzoni, T., Hatcher, J.D., 2020. Bleach Toxicity, in: StatPearls. StatPearls Publishing, Treasure Island (FL). (https://www.ncbi.nlm.nih.gov/books/NBK441921/, accessed 6 May 2020)
(XXVII) Personal safety when preparing and using
disinfectants:
That the cleaners should wear adequate personal
protective equipment (PPE) and be trained to use it safely.
When working in places where suspected or confirmed
Page 20 of 29
COVID-19 patients are present, or where screening, triage and
clinical consultations are carried out, cleaners should wear the
following PPE: gown, heavy duty gloves, medical mask, eye
protection (if risk of splash from organic material or chemicals),
and boots or closed work shoes.
(XXVIII) That Disinfectant solutions should always be prepared in
well-ventilated areas. Avoid combining disinfectants, both
during preparation and usage, as such mixtures cause
respiratory irritation and can release potentially fatal gases, in
particular when combined with hypochlorite solutions.
(XXIX) That the Personnel preparing or using disinfectants in
health care settings require specific PPE, due to the high
concentration of disinfectants used in these facilities and the
longer exposure time to the disinfectants during the workday.
Thus, PPE for preparing or using disinfectants in health care
settings includes uniforms with long-sleeves, closed work
medical mask, and eye protection (preferably face shield).
(XXX) That in non-health care settings, resource limitations
permitting, where disinfectants are being prepared and used, the
minimum recommended PPE is rubber gloves, impermeable
aprons and closed shoes. Eye protection and medical masks
Page 21 of 29
may also be needed to protect against chemicals in use or if
there is a risk of splash.
REF: 48. Rational use of personal protective equipment for coronavirus disease (COVID-19); Geneva: World Health Organization;2020 (https://www.who.int/emergencies/diseases/novelcoronavirus-2019/technical-guidance/infectionprevention-and-control, accessed 6 May 2020)
(XXXI) That spraying an individual or group with chemical
disinfectants is physically and psychologically harmful. It has
been observed by the Petitioner that the disinfectants are
sprinkled on the human being by lot of agencies and private
organizations, to disinfect.
(XXXII) That the Petitioner has observed that at so many places,
where companies are installing the chemical tunnels to sanitize
the visitors / staff / general public, is totally in violation of the
guidelines as prescribed by the World Health Organization.
Such working of tunnels is annexed herewith for the perusal of
this Hon’ble Court as ANNEXURE -X. At some places the
migrant workers are sanitized by sprinkling disinfectant
solution on them and showering them with it. Such photo is
annexed herewith for the perusal of this Hon’ble Court as
ANNEXURE – XI and XII.
(XXXIII) That even the government is engaging in such an
procedure regarding the spraying of chemicals on general
Page 22 of 29
public by way of machines, which is giving a wrong message to
the general public.
(XXXIV) That as per the finding of the World Health Organization,
the spraying of chlorine on individuals can lead to irritation of
eyes and skin and potentially gastrointestinal effects such as
nausea and vomiting. Inhalation of sodium hypochlorite can
lead to irritation of mucous membranes to the nose, throat,
respiratory tract and may also cause bronchospasm. Such myth
buster document is annexed herewith for the perusal of this
Hon’ble Court as ANNEXURE - XIII.
That at some places it has been observed that UV tunnels
are also been placed in order to kill the virus but without
following the WHO guidelines.
(XXXV) That it has been seen by the petitioner that there is a
direct spraying of chemical by the machine on the general
public, which is very harmful to the human body.
(XXXVI) That at some places it has also been observed that the
direct spraying of chemical may catch fire and the life and
property falls in danger. Such incidence is attached herewith for
the perusal of this Hon’ble Court as ANNEXURE -XIV.
GROUNDS
Page 23 of 29
(a) BECAUSE the guidelines formed to combat Covid -19, as
contemplated by the World Health Organization are not
properly implemented.
(b) BECAUSE the advisories directed by Government of India are
not being implemented effectively.
(c) BECAUSE the chemicals sprinkled directly on the human
beings is a health hazard and may be life endangering exercise.
(d) BECAUSE the direct contact of the chemicals has a
psychological impact.
(e) BECAUSE the direct exposure to the unmanned Ultra Violet
radiations is cancer generating.
(f) BECAUSE the use of chemical tunnel is very dangerous to the
human life.
(g) BECAUSE by not complying with the precautions being
advised by the World Health Organization and the advisory
issued by the Union of India, the life of Health Warriors are
placed at great risk.
(h) BECAUSE the latest research shows, which are also adopted
by the World Health Organization, the impact of chemicals on
the human being is hazardous.
Page 24 of 29
(i) BECAUSE by not complying with the precautions being
advised from time to time, by the World Health Organization
and the advisory issued by the Union of India, the life and
property of individual is at great risk.
(j) BECAUSE the direct exposure of the sanitation workers and
other sanitization staff to the chemical exposure without proper
PPE kit, is putting such workers to death trap by the
Government.
(k) BECAUSE the health workers and the sanitization staff are
working in high-active field areas and are already facing
hardship.
(l) BECAUSE it is a right vested in every individual to be
provided with necessary precautionary device.
(m) BECAUSE the government is duty bound to protect its citizens
and their properties during ordinary days and during any kind
of disaster.
(n) BECAUSE by not providing the required kits and other
material as per the guidelines of WHO, there is a clear violation
of the Article 21 of Constitution of India also.
(o) BECAUSE the State is duty bound to its health workers,
especially those that are in the frontline.
Page 25 of 29
(p) BECAUSE the heightened risk of infection, anxiety has added
vows to the health workers and indirectly their families, the
health workers are also increasingly dealing with social
ostracism, harassment and even assault.
(q) BECAUSE there is an urgent requirement to protect the rights
and interest of the frontline medical healthcare medical
professionals who form the backbone of medical healthcare
system of any Country.
(r) BECAUSE the Environmental Protection Agency has given a
chart with respect to the exposure.
(s) BECAUSE the spray of chemicals should be as per the
references given above.
(t) BECAUSE the exposure to the chemical by the human being is
explained by the various agencies.
7. The petitioner is filing the present petitioner for common cause
and benefits of the society at large more particularly the health
workers and sanitation staff. That the petition, if allowed, would
benefit the health workers, senior citizens, pensioners, police and
defence personnel associated with fight against COVID and will
relieve them from insurmountable hardships.
Page 26 of 29
8. The petitioner has not filed any similar petition/case previously
before this Hon’ble Court or before any other High Court.
9. That this Hon'ble Court has the jurisdiction to entertain the present
Writ Petition. This writ petition is made bona fide and in the
interest of justice and the Petitioner has no other efficacious
remedy left other than approaching this Hon’ble Court.
10. That the Petitioner crave leave of this Hon’ble Court to amend or
alter the grounds at the appropriate stage, as and when required.
PRAYER
In the facts and circumstances above mentioned the Applicant
most respectfully prays that this Hon’ble Court may graciously
be pleased to:-
a) Issue a Writ of Mandamus or any other appropriate Writ,
order or direction to the Respondents to implement the Covid -
19 guidelines effectively.
and
b) Issue a Writ of Mandamus or any other appropriate Writ,
order or direction to the Respondents not to allow any
installation of any chemical chamber / tunnel at public places /
offices / homes / offices etc.
and
Page 27 of 29
c) Issue a Writ of Mandamus or any other appropriate Writ,
order or direction to the Respondents not to allow the
installation of any Ultra Violet radiation tunnel at public places
/ offices or any other place in the interest of health of the
citizens.
and
d) Issue a Writ of Mandamus or any other appropriate Writ,
order or direction to the Respondent No.3 to book such persons
/ companies as per the applicable provisions of law.
and
e) pass such other and further order/orders as deemed fit and
proper in the facts and circumstances of the present case and in
the interest of justice.
AND FOR THIS ACT OF KINDNESS THE PETITIONER
AS IN DUTY BOUND SHALL EVER PRAY
Petitioner
Through
Dr. N. Pradeep Sharma & Harsh K Sharma Advocates for Petitioner
5, Jungpura Road, Bhogal Jungpura, New Delhi – 110014.
IN THE HIGH COURT OF DELHI AT NEW DELHI CIVIL WRIT JURISDICTION
W.P. (CIVIL) No. of 2020
In the matter of A Public Interest Litigation:
1. Susheel Mahajan ….…..Petitioner
VERSUS
1. Ministry of Health and Family Welfare Union of India and Ors. …….Respondents
APPLICATION U/S 151 CPC FOR EXEMPTION FROM FILING DULY AFFIRMED PETITION ALONGWITH
AFFIDAVIT, NON FILING OF COURT FEES To, Hon’ble the Chief Justice of India and his Hon’ble Companion Justices of the Hon’ble High Court of Delhi at New Delhi;
MOST RESPECTFULLY SHOWETH: -
1. That the present PIL is pending adjudication before this
Hon’ble Court and is listed for --.06.2020.
2. That the Petitioner prefers present Application for exemption
from filing duly affirmed petition alongwith affidavit, non filing
of court fees seeking.
2. That the Petitioner undertakes to pay the court fees within 72
hours from the date of resumption of the regular functioning of
this Court.
3. That it is in this regard urgent interim directions be given to
Registry to inter-alia take immediate steps.
Page 29 of 29
4. That the present Application is made bonafide and interest of
justice.
PRAYER:
In the facts and circumstances above mentioned the Applicant
most respectfully prays that this Hon’ble Court may graciously
be pleased:-
a) pass an order thereby exempting the Petitioner from filing duly
affirmed petition alongwith affidavit and court fees till the time,
the Hon’ble Court resumes normal functioning.
b) pass such other and further order/orders as deemed fit and
proper in the facts and circumstances of the present case and in
the interest of justice.
AND FOR THIS ACT OF KINDNESS THE PETITIONER SHALL AS IN DUTY BOUND EVER PRAY.
Petitioner Through Dr. N. Pradeep Sharma & Harsh K Sharma
Advocates for Petitioner 5,Jungpura Road, Bhogal Jungpura,
New Delhi – 110014. Contact: 9899696333 e-mail: [email protected] Dated: 07.06.2020 Place: New Delhi