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IN the SUPREME COURT of INDIA CRIMINAL ORIGINAL JURISDICTION WRIT PETITION (CRL) NO. of 2019 in the MATTER OF: Vineet Dhand

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IN the SUPREME COURT of INDIA CRIMINAL ORIGINAL JURISDICTION WRIT PETITION (CRL) NO. of 2019 in the MATTER OF: Vineet Dhand Bar & Bench (www.barandbench.com) IN THE SUPREME COURT OF INDIA CRIMINAL ORIGINAL JURISDICTION WRIT PETITION (CRL) NO. OF 2019 IN THE MATTER OF: Vineet Dhanda Petitioner VERSUS Union of India &Ors. Respondents PAPER BOOK [FOR INDEX KINDLY SEE INSIDE] DR. J.P.DHANDA: ADVOCATE FOR THE PETITIONER Bar & Bench (www.barandbench.com) INDEX Sl. Particulars of Document Page No. of Part to Rema No. which it belongs rks Part 1 Part II (Contents (Contents of Paper of file Book) alone) (i) (ii) (iii) (iv) (v) 1. Court Fees 2. Listing Proforma A-A1 A-A1 3. Cover Page of Paper Book A-3 4. Index of Record of A-4 Proceedings 5. Limitation Report prepared A-5 by the Registry 6. Defect List A-6 7. Note Sheet NS1 to 8. List of Dates B-Z 9. Writ Petition with Affidavit 1-59 10. Annexure P-1: 60-62 A copy of the news article dated 26.11.2012 published in Rediff News.com 11. Annexure P-2: 63-67 A copy of the news article of Times of India dated 10.08.2015 Bar & Bench (www.barandbench.com) 12. Annexure P-3: 68-77 A copy of the detailed Wikipedia regarding the Uri attack dt. Nil 2016 13. Annexure P-4: 78-87 A copy of the detailed Wikipedia regarding the All Partied Hurriyat Conference dt. Nil 14. Annexure P-5: 88-90 A copy of the news article published in Business Standard dated 29.11.2017 15. Annexure P-6: 91-95 A copy of the news article published Press Trust of India dated nil January 2018 16. Annexure P-7: 96-98 A copy of the news article dated 03.02.1018 published in The Tribune 17. Annexure P-8: 99-100 A copy of the news article dated 07.06.2018 published in Hindustan Times Bar & Bench (www.barandbench.com) 18. Annexure P-9: 101-105 A copy of the news article dated 14.02.2019 published in NDTV.com 19. Annexure P-10: 106-108 A copy of the news article dated 14.02.2019 published in Timesnow news.com 20. Annexure P-11: 109-114 A copy of the news article dated 16.02.2019 published in Hindustan Times.com 21. Annexure P-12: 115-117 A copy of the news article dated 16.02.2019 published in NDTVNews.com 22. F/M 118 23. V/A 119 24. Authority Letter 120 Bar & Bench (www.barandbench.com) PROFORMA FOR FIRST LISTING SECTION:PIL The case pertains to : (Please tick/check the correct box) Central Act : Constitution of India Section : 32 Central Rule : N/A Rule No(s) : N/A State Act : N/A Section : N/A State Rule : N/A Rule No(s) : N/A Impugned Interim Order : N/A Impugned Final Order/Decree : N/A High Court : N/A Name of Judges : N/A Tribunal/Authority : N/A 1. Nature of matter Criminal 2. (a) Petitioner/appellant No.1 : Vineet Dhanda (b) e-mail ID : N/A (c) Mobile phone number : N/A 3. (a) Respondent No.1 : Union of India &Ors. (b) e-mail ID : N/A (c) Mobile phone number : N/A 4. (a) Main category : 08 classification (b) Sub classification : 817 5. Not to be listed before : N/A 6. (a) Details of Similar/Pending : No similar matter is matter with citation pending Bar & Bench (www.barandbench.com) (b) Details of Disposed off N/A matter with citation 7. Criminal Matters : Yes (a) Whether accused/convict has Yes No surrendered (b) FIR No. N/A Date: N/A (c) Police Station : N/A (d) Sentence Awarded : N.A. (e) Sentenced Undergone : N.A. 8. Land Acquisition Matters : N/A (a) Date of Section 4 N/A notification (b) Date of Section 6 N/A notification (c) Date of Section 17 N/A notification 9. Tax Matters : N/A 10. Special Category ( first petitioner/appellant only): N/A Senior citizen > 65 SC/ST Woman/child years Disabled Legal Aid case In Custody 11. Vehicle Number (in case of Motor Accident Claim Matters): N/A 12. Decided case with citation : N/A Date: AOR for petitioner (s)/appellant(s) Dr. J.P. DHANDA Registration: No.: 1119 Email id: [email protected] Bar & Bench (www.barandbench.com) SYNOPSIS AND LIST OF DATES Whenever we introduce our armed forces and give respect to them, first and always repeated sentence is “WE SLEEP IN PEACE BECAUSE THEY ARE AWAKE FOR US” and it is because of the continuous efforts of our armed forces which includes Indian Army and paramilitary forces like CRPF, ITBP, BSF, CISF and other forces who do a unbelievable and impossible task in protecting our boundaries from all the corners of our country. Be it an extreme temperature as -50 degrees in Siachen glacier or excess heat of 50 degrees in Rajasthan the sons and daughters of India serving the armed forces and paramilitary forces do a remarkable task of protecting our boundaries even if their lives are led down and by giving a supreme sacrifice of their lives, the forces across the country do a daunting, next to impossible and dangerous task even in the extreme most conditions of weather and nature. A soldier be it from paramilitary force or from armed forces doesn’t think about himself or herself, for a soldier country and its people comes first and to protect the country and its people the bravehearts of our country have laid down their lives since 1947 to protect the sovereignty and sanctity of our nation. The soldiers across the country not only protect the borders of our nation but also protect the country from with in. even in the serious calamities like flood, earthquakes and other serious law and order Bar & Bench (www.barandbench.com) problems it is the army and the paramilitary forces which play a pivotal role in every tough time and circumstances which are faced in the country the armed forces and the paramilitary forces do a remarkable job in protecting the lives of the citizens of this country. The State of Jammu and Kashmir has had serious problems like terrorism, floods, avalanche etc and the armed forces and the paramilitary forces have done their best to protect the residents of The State of Jammu and Kashmir in every possible way and for protecting the boundaries as well as the interiors of The State of Jammu and Kashmir the precious lives of the armed forces and paramilitary forces have been lost as those brave heart soldiers sacrificed their lives while protecting the citizens of this country and the residents of The State of Jammu and Kashmir. The situation inThe State of Jammu and Kashmir after the Kargil War in 1999 has worsened day by day as more than 4000 soldiers have been killed in the country after the Kargil operations. The problem of terrorism, political supported terrorism and misguidance of innocent youth of The State of Jammu and Kashmir is at peak at present and the young generation belonging to The State of Jammu and Kashmir is being misguided towards terrorism and attacking their own armed forces which is a most serious situation as if not controlled thousands of soldiers will more be killed and there are chances that The State of Jammu and Kashmir will loose its existence itself to Pakistan supported terrorism. Bar & Bench (www.barandbench.com) The religious leaders as well as political leaders belonging to The State of Jammu and Kashmir are actively involved in destabilizing the State and misguiding the youth with a fake dream of Independent Jammu and Kashmir. The political parties like All Parties Hurriyat Conference are playing a very negative role in destabilizing The State of Jammu and Kashmir by actively involving with pro-Pakistan outfits as well as provoking the innocent youth of The State of Jammu and Kashmir to attack the armed forces in The State of Jammu and Kashmir. In the past few years it has been reported in the media and has been shown on television the worsening situation of The State of Jammu and Kashmir and the increasing problem of terrorism in the State which is not only the result of Pakistan supported terrorism but the problem has aggravated due to the local political parties misguiding the youth to the path of terrorism and attacking their own countries armed forces and the worst part is the ignorance of Central Government towards such anti-India activities in The State of Jammu and Kashmir by not only the terrorist outfits but also the local political parties who go out of the way in organizing and promoting anti – India stand with a fake promise and dream of Independent Jammu and Kashmir. The local political parties of The State of Jammu and Kashmir are going out of the way in conniving with Pakistan and Pakistani supported terror outfits with a sole aim to destabilise our country and such activities are causing severe loss of lives, destruction in The State of Jammu and Bar & Bench (www.barandbench.com) Kashmir and the worst part is that the Central Government is watching it as a mute spectator by not taking action against local political parties who are actively involved in supporting terrorism in The State of Jammu and Kashmir as a result of which our nation is bleeding of the precious lives of its soldiers as well as the economy of our country is bleeding as immense monetary support is involved in maintain The State of Jammu and Kashmir. The local political parties such as All Parties Hurriyat Conference and other local political parties having the same ideology as All Parties Hurriyat Conference are hell bent in destroying The State of Jammu and Kashmir, its youth and are also actively involved in those activities which are not only against India but such activities are also causing loss of precious lives of our soldiers in the process of maintaining peace and harmony inThe State of Jammu and Kashmir.
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