IN THE HON’BLE HIGH COURT OF DELHI, AT NEW
DELHI
EXTRAORDINARY WRIT JURISDICTION
Writ Petition (Civil) No _____ of 2020
IN THE PUBLIC INTEREST LITIGATION OF:
Krishna Kr. Sharma Petitioner
Versus
Govt. of NCT of Delhi Respondent
WITH
C.M. NO. OF 2020 : Exemption from filing
certified, dim, typed & margin
copies of documents
PAPER BOOK
[SEE INDEX INSIDE]
Krishna Kr. Sharma/K.M. Monika(Advocate)
(Petitioner in Person)
Ch. No. 906, Patiala House Courts,
New Delhi-110001
Mob- +91-9958891040
E-mail- [email protected]
IN THE HON’BLE HIGH COURT OF DELHI, AT NEW
DELHI
EXTRAORDINARY WRIT JURISDICTION
Writ Petition (Civil) No _____of 2020
IN THE PUBLIC INTEREST LITIGATION OF:
Krishna Kr. Sharma Petitioner
Versus
Govt. of NCT of Delhi Respondent
INDEX
S.NO
PARTICULAR (S) PAGE NO.
1. Court Fees
A
2. Urgent Application
B
3. Notice of Motion
C
4. Synopsis & List of Dates
D – K
5. Memo of Parties
1 – 2
6. Civil Writ Petition along with affidavit
3 – 15
7. Application under section 151 C.P.C for
exemption from filing certified/true
typed/ with proper margins of the
annexure, along with affidavit in
support.
16 – 19
8 The copy of order dated 17.04.2020 and
multiple news article are annexed
herewith as Annexure A-1 and
Annexure A-2 respectively.
20 - 40
9 The copy of the order-dated 24.04.2020
is annexed herewith as Annexure A-3.
41 – 68
10 The copy of news article dated
28.04.2020 is annexed herewith as
Annexure A-4. and ICMR guidelines
dated 20.03.2020 is annexed herewith as
Annexure A-5 respectively.
69 - 73
11 The copy of News article dated
28.04.2020 is annexed herewith as
Annexure A-6.
74 - 76
12 The copy of order dated 30.04.2020 is
annexed herewith as Annexure A-7.
77 – 79
13 The copy of News article dated
07.05.2020 is annexed herewith as
Annexure A-8.
80 – 83
14 The copy of News article dated 84 - 91
13.05.2020 is annexed herewith as
Annexure A-9.
15 A copy of News Paper article dated
25.05.2020 is annexed herewith as
Annexure A-10.
92 – 98
16 A copy of News Paper article dated
26.05.2020 is annexed herewith as
Annexure A-11.
99
17 VAKALATNAMA (Not Required as
Petition is being filed in person)
Filed By
New Delhi
Dated 03.06.2020 Krishna Kr. Sharma/K.M. Monika
(Petitioner in Person)
Ch. No. 906, Patiala House Courts,
New Delhi-110001
Mob- +91-9958891040
E-mail- [email protected]
IN THE HON’BLE HIGH COURT OF DELHI, AT NEW
DELHI
EXTRAORDINARY WRIT JURISDICTION
Writ Petition (Civil) No _____of 2020
IN THE PUBLIC INTEREST LITIGATION OF:
Krishna Kr. Sharma Petitioner
Versus
Govt. of NCT of Delhi Respondent
COURT FEES
Filed By
New Delhi
Dated 03.06.2020 Krishna Kr. Sharma/K.M. Monika
(Petitioner in Person)
Ch. No. 906, Patiala House Courts,
New Delhi-110001
Mob- +91-9958891040
E-mail- [email protected]
IN THE HON’BLE HIGH COURT OF DELHI, AT NEW
DELHI
EXTRAORDINARY WRIT JURISDICTION
Writ Petition (Civil) No _____of 2020
IN THE PUBLIC INTEREST LITIGATION OF:
Krishna Kr. Sharma Petitioner
Versus
Govt. of NCT of Delhi Respondent
NOTICE OF MOTION
Esteemed Sir/Madam
Kindly take notice that the accompanying Writ Petition under
Article 226 of the Constitution of India r/w section 151 of the Civil
Procedure Code, for, is being filed for and behalf of the Petitioner
and is likely to be listed before the Hon’ble Court for hearing on
________________ or any other day, thereafter, as per rules.
Filed by
New Delhi
Dated 03.06.2020 Krishna Kr. Sharma/K.M. Monika
(Petitioner in Person)
Ch. No. 906, Patiala House Courts,
New Delhi-110001
Mob- +91-9958891040
E-mail- [email protected]
IN THE HON’BLE HIGH COURT OF DELHI, AT NEW
DELHI
EXTRAORDINARY WRIT JURISDICTION
Writ Petition (Civil) No _____of 2020
IN THE PUBLIC INTEREST LITIGATION OF:
Krishna Kr. Sharma Petitioner
Versus
Govt. of NCT of Delhi Respondent
URGENT APPLICATION
Esteemed Sir/Madam
Will you kindly treat this accompanying Petition/Application on an
urgent one in accordance with the High Court Rules and Orders?
The Ground of urgency are as prayed in the petition
Filed by
New Delhi
Dated 03.06.2020 Krishna Kr. Sharma/K.M. Monika
(Petitioner in Person)
Ch. No. 906, Patiala House Courts,
New Delhi-110001
Mob- +91-9958891040
E-mail- [email protected]
SYNOPSIS AND LIST OF DATES
The Writ Petition is being filed in public interest to seek an
appropriate writ or directions against the Respondent authorities to
urge the Government Hospital and Private Hospital to comply with
the order of the Respondent pertaining to the treatment and
admission of asymptomatic and symptomatic or (COVID-19 and
non-COVID-19) patients, direct not to make COVID-19 test
mandatory before admitting elective and even emergency patients in
any Government and Private Hospital, direct Private Hospital not to
charge high amount (beyond the actual cost) for PPE kits from
Patients using every day during treatment, and direct not to force
frontline hospital staff to wear “USED PPE”, which was being
used by COVID-19 positive patient.
By this Public Interest Litigation, the Petitioner wishes to bring to
your kind notice the difficulties being faced by the public at large.
Pursuant to the report and news articles received, multiple Private
Hospitals have made COVID-19 test mandatory before admitting
elective and even emergency patients, despite Respondent issued a
clarification on aforesaid issue, asking hospitals authority not to test
asymptomatic patients. It is submitted that many hospitals, are
hesitating in providing critical services such as dialysis, blood
transfusion, chemotherapy and institutional deliveries. It has also
been noticed that at many places the hospitals/ clinics are insisting
for a COVID-19 test before providing services.” Multiple directions
issued by the Respondent that any Government and Private Hospital
or Nursing home in the National Capital Territory that refuses
emergent medical care to the person amid COVID-19 pandemic,
strict action will be taken against those defaulters, especially in the
case of ESRD (End Stage Renal Disease) patients. Further,
registration shall be cancelled for such Private Hospital and/or
Nursing Home. There is no compliance of directions and order of
the Respondent.
It will not be out of the place to mentioned that Respondent
emphasized that while continuing to focus on COVID 19 related
activities, providing other essential services was important not only
to maintain people's trust in the health system to deliver essential
health services, but also to minimize an increase in morbidity and
mortality from other health conditions. Accordingly all states were
directed to identify essential services such as: pregnant women,
those recently delivered, infants and children under five, those on
treatment for chronic diseases, communicable diseases like
TB/Leprosy, vector borne diseases, requiring treatment for dialysis,
cancer, blood transfusions, and other special needs, that would be
prioritized in the efforts to maintain continuity of service delivery.
Further, Respondent directed to ensure the availability of regular
medical services at non-COVID-19 Hospitals to maintain their full
operations for the care of patients and try to accommodate the load
of the hospitals, which has been declared as COVID-19 hospital by
Respondent.
It is submitted that 63-year-old cancer patient in Delhi had to wait
for more than 24 hours to get hospitalized and quarantined even
after he was found to be COVID-19 positive. It is further submitted
that Delhi Police constable, who was asymptomatic till he suffered
from fever and developed breathing problems, was allegedly denied
admission by hospital, despite, being a frontline warrior, showing
COVID-19 symptoms and worsening health conditions. He died on
the way to RML Hospital, mere hours after he complained of
medical problems.
It will not be out of place to mention that a man preferred Apollo
Hospital for his treatment since the said hospital was closest to his
home, compelled or forced to pay an additional Rs 4,500 (the
price of the RT-PCR COVID-19 test) along with his dialysis fee.
Further, three more patients who was visiting, Apollo Hospital at
Delhi’s Sarita Vihar for day-care treatment services like dialysis
and chemotherapy were being asked to get RT-PCR tests for
COVID-19 every week before their procedures.
Recently a nurse succumbed to COVID-19 in Hospital since she
was forced to wear USED PPE, which was used by COVID-19
positive patient (according to source). It will not be out of place to
mention that the Private Hospitals are charging heavy amount for
PPE.
LIST OF DATES
Date Particulars
17.04.2020 The direction issued by the Respondent
that any Hospital or Nursing Home in the
National Capital Territory that refuses
emergent medical care to the person amid
COVID-19 pandemic, strict action will be
taken against those defaulters, especially
in the case of ESRD (End Stage Renal
Disease) patients. Further, Registration
shall be cancelled for such Hospitals
and/or Nursing Home.
17.04.2020 The Respondent directed to ensure the
availability of regular medical services at
Non-COVID-19 Hospitals to maintain
their full operations for the care of patients
and try to accommodate the load of the
hospitals, which has been declared as
COVID-19 hospital by Respondent.
24.04.2020 The Respondent directed that no patient
other than with COVID-19, reaching non-
COVID Government or Private Hospital
shall be denied treatment or admission in
the hospital.
28.04.2020 The multiple Private Hospitals have made
COVID-19 test mandatory before
admitting elective and even emergency
patients, hesitating in providing critical
services such as dialysis, blood
transfusion, chemotherapy, and
institutional deliveries and also noticed
that at many places the hospitals and
nursing homes are insisting individual for
COVID-19 test before providing services,
despite clarification issued by Ministry of
Health and Family Welfare and ICMR on
aforesaid issue, asking hospitals authority
not to test asymptomatic patients and
allow testing of only all symptomatic
patients, symptomatic contacts of
laboratory confirmed cases, symptomatic
health care workers, hospitalized patients
with severe acute respiratory illness (fever
and cough and/or shortness of breath), and
asymptomatic direct and high-risk
contacts of a confirmed case respectively.
28.04.2020 A 63-year-old cancer patient in Delhi had
to wait for more than 24 hours to get
hospitalized, and quarantined even after he
was found to be COVID-19 positive.
30.04.2020 The Respondent emphasized that while
continuing to focus on COVID 19 related
activities, providing other essential
services was important not only to
maintain people's trust in the health
system to deliver essential health services,
but also to minimize an increase in
morbidity and mortality from other health
conditions. Accordingly all states were
directed to identify essential services such
as: pregnant women, those recently
delivered, infants and children under five
years, those on treatment for chronic
diseases, communicable diseases like
TB/Leprosy, vector borne diseases,
requiring treatment for dialysis, cancer,
blood transfusions, and other special
needs, that would be prioritized in the
efforts to maintain continuity of service
delivery.
07.05.2020 Delhi Police constable, who was
asymptomatic till he suffered from fever
and developed breathing problems, was
allegedly denied admission by hospital,
despite, being a frontline warrior, showing
COVID-19 symptoms and worsening
health conditions. He died on the way to
RML Hospital, mere hours after he first
complained of medical problems.
13.05.2020 A man preferred Apollo Hospital for his
treatment since the said Hospital was
closest to his home, compelled or forced
to pay an additional Rs 4,500 (the price
of the RT-PCR COVID-19 test) along
with his dialysis fee. Further, three more
patients who was visiting, Apollo
Hospital at Delhi’s Sarita Vihar for day-
care treatment services like dialysis and
chemotherapy were being asked to get
RT-PCR tests for COVID-19 every week
before their procedures.
25.05.2020 Nurse succumbed to COVID-19 in
Government Hospital since she was forced
to wear used PPE, which was used by
COVID-19 positive person (according to
source).
26.05.2020 Private Hospitals are charging heavy
amount for PPE using everyday.
The Respondent has not taken any action upon the same, therefore
the present petition.
IN THE HON’BLE HIGH COURT OF DELHI, AT NEW
DELHI
EXTRAORDINARY WRIT JURISDICTION
Writ Petition (Civil) No. __________ of 2020
IN THE PUBLIC INTEREST LITIGATION OF:
Krishna Kr. Sharma Petitioner
Versus
Govt. of NCT of Delhi Respondent
MEMO OF PARTIES
Krishna Kr. Sharma
Advocate
Chamber No.-906,
Patiala House Court’s Complex
New Delhi-110001 Petitioner
VERSUS
Govt. of NCT of Delhi
Department of Health Administration
Through its Directorate General of Health Services
Health and Family Welfare Department
9th Level, A-Wing, IP Extension,
Delhi Secretariat, Delhi - 110002 Respondent
Filed by
New Delhi
Dated 03.06.2020 Krishna Kr. Sharma/K.M. Monika
(Petitioner in Person)
Ch. No. 906, Patiala House Courts,
New Delhi-110001
Mob- +91-9958891040
E-mail- [email protected]
IN THE HON’BLE HIGH COURT OF DELHI, AT NEW
DELHI
EXTRAORDINARY WRIT JURISDICTION
Writ Petition (Civil) No __________ of 2020
IN THE PUBLIC INTEREST LITIGATION OF:
Krishna Kr. Sharma Petitioner
Versus
Govt. of NCT of Delhi Respondent
THE INSTANT PUBLIC INTEREST LITIGATION (WRIT
PETITION) UNDER ARTICLE 226 OF THE
CONSTITUTION OF INDIA R/W SECTION 151 C.P.C FOR
SEEKING ISSUANCE OF WRIT OF MANDAMUS OR ANY
OTHER WRIT, ORDER OR DIRECTION THEREBY
DIRECTING THE RESPONDENT TO COMPEL AND/OR
URGE THE GOVERNMENT HOSPITAL AND PRIVATE
HOSPITAL TO COMPLY WITH THE ORDER OF THE
RESPONDENT PERTAINING TO THE TREATMENT AND
ADMISSION OF ASYMPTOMATIC AND SYMPTOMATIC
OR (COVID-19 AND NON-COVID-19) PATIENTS, DIRECT
NOT TO MAKE COVID-19 TEST MANDATORY BEFORE
ADMITTING ELECTIVE AND EVEN EMERGENCY
PATIENTS IN ANY GOVERNMENT AND PRIVATE
HOSPITAL, DIRECT PRIVATE HOSPITAL NOT TO
CHARGE HIGH AMOUNT (BEYOND THE ACTUAL COST)
FOR PPE KITS FROM PATIENTS USING EVERY DAY
DURING TREATMENT, AND DIRECT NOT TO FORCED
FRONTLINE HOSPITAL STAFF TO WEAR “USED PPE”,
WHICH WAS BEING USED BY COVID-19 POSITIVE
PATIENT;ALONGWITH AFFIDAVIT IN SUPPORT AND
FOR SEEKING FURTHER DIRECTIONS.
TO,
THE HON’BLE CHIEF JUSTICE
THE HON’BLE HIGH COURT OF DELHI
AND HIS COMPANION JUSTICES
MOST RESPECTFULLY SHOWETH:
That the Petitioner is Advocate by profession and is invoking the
extraordinary writ jurisdiction of this Hon’ble Court for seeking
writ of mandamus or any other writ of like nature for seeking
directions to the Respondent to (i) urge the Government Hospital
and Private Hospital to comply with the order of the Respondent
pertaining to the treatment and admission of asymptomatic and
symptomatic or (COVID-19 and non-COVID-19) patients, (ii)
direct not to make COVID-19 test mandatory before admitting
elective and even emergency patients in any Government and
Private Hospital, (iii) direct Private Hospital not to charge high
amount (beyond the actual cost) for PPE kits from Patients using
every day during treatment, and (iv) direct not to forced frontline
hospital staff to wear “USED PPE”, which was being used by
COVID-19 positive patient. The petitioner has no personal interest
in the petition and the petition is not guided by self-gain of any
other person/institution/body and that there is no motive other than
of public interest in filing the writ petition.
1. THE BRIEF FACTS OF THE CASE ARE AS UNDER
a. That the direction issued by Respondent that any Private
Hospital or nursing home in the National Capital Territory
that refuses emergent medical care to the person amid
Covid-19 pandemic, strict action will be taken against
those defaulters, especially in the case of ESRD (End
Stage Renal Disease) patients. Further, Registration shall
be cancelled for such Private Hospital and/or Nursing
Home. However, no effect. The copy of order dated
17.04.2020 and multiple newspaper article are annexed
herewith as Annexure A-1 and Annexure A-2
respectively.
b. That on 17.04.2020, the Respondent directed to ensure the
availability of regular medical services at Non-COVID
hospitals to maintain their full operations for the care of
patients and try to accommodate the load of the hospitals,
which has been declared as COVID 19 hospital by
Respondent.
c. That on 24.04.2020, the Respondent directed that any non-
COVID patient other that COVID – 19, reaching “non-
COVID” Government and Private Hospitals, shall not be
denied treatment or admission in the hospital. However,
no effect. The copy of the order-dated 24.04.2020 is
annexed herewith as Annexure A-3.
d. That further, multiple Private Hospitals have made
COVID-19 test mandatory before admitting elective and
even emergency patients, hesitating in providing critical
services such as dialysis, blood transfusion, chemotherapy,
and institutional deliveries and also noticed that at many
places the hospitals and nursing homes are insisting
individual for COVID-19 test before providing services,
despite clarification issued ICMR on aforesaid issue,
asking hospitals authority not to test asymptomatic
patients and allow testing of only all, symptomatic
individuals who have undertaken international travel in the
last 14 days, symptomatic contacts of laboratory
confirmed cases, symptomatic health care workers,
hospitalized patients with Severe Acute Respiratory Illness
(fever AND cough and/or shortness of breath),and
Asymptomatic direct and high-risk contacts of a confirmed
case respectively. However, no effect. The copy of
newspaper article dated 28.04.2020 and ICMR guidelines
dated 15.03.2020 is annexed herewith as Annexure A-4
and Annexure A-5 respectively.
e. It is submitted that a 63-year-old cancer patient in Delhi
had to wait for more than 24 hours to get hospitalized and
quarantined even after he was found to be COVID-19
positive. The copy of newspaper article dated 28.04.2020
is annexed herewith as Annexure A-6.
f. That on 30.04.2020, the Respondent emphasized that
while continuing to focus on COVID 19 related activities,
providing other essential services was important not only
to maintain people's trust in the health system to deliver
essential health services, but also to minimize an increase
in morbidity and mortality from other health conditions.
Accordingly all states were directed to identify essential
services such as: pregnant women, those recently
delivered, infants and children under five, those on
treatment for chronic diseases, communicable diseases like
TB/Leprosy, vector borne diseases, requiring treatment for
dialysis, cancer, blood transfusions, and other special
needs, that would be prioritized in the efforts to maintain
continuity of service delivery. However, no effect. The
copy of order-dated 30.04.2020 is annexed herewith as
Annexure A-7.
g. It will not be out of place to mention that Delhi Police
constable, who was asymptomatic till he suffered from
fever and developed breathing problems, was the first cop
in Delhi to die due to coronavirus, was allegedly denied
admission by hospital, despite, being a frontline warrior,
showing COVID-19 symptoms and worsening health
conditions. He died on the way to RML Hospital, mere
hours after he first complained of medical problems. The
copy of newspaper article dated 07.05.2020 is annexed
herewith as Annexure A-8.
h. It is submitted that a patient preferred Apollo hospital for
his treatment since the said Hospital was closest to his
home, compelled or forced to pay an additional amount
of Rs 4,500 (the price of the RT-PCR COVID-19 test)
along with his dialysis fee. Further, three more patients
who was visiting, Apollo Hospital at Delhi’s Sarita Vihar
for day-care treatment services like dialysis and
chemotherapy were being asked to get RT-PCR tests for
COVID-19 every week before their procedures. The copy
of newspaper article dated 13.05.2020 is annexed herewith
as Annexure A-9.
i. A nurse in Hospital succumbed to COVID-19 since she
was forced to wear used PPE. A copy of newspaper article
dated 25.05.2020 is annexed herewith as Annexure A-10.
j. Private Hospitals in Delhi are charging high amount for
PPE from patients using PPE everyday. A copy of
newspaper article dated 26.05.2020 is annexed herewith as
Annexure A-11.
2. That issue involved in the petition is in larger public interest
since symptomatic, asymptomatic, and frontline warriors are
sufferers in terms of not getting access of medical treatment and
routine checkup.
3. That Respondent shall suppress and urge Government and
Private Hospital to comply with the order and directions issued
for Government and Private Hospitals amid COVID-19
pandemic. Furtherance of mentioned direction, Respondent shall
authorize officers to compound offences under the Act within
the territory of NCT of Delhi and take overall control upon the
Government and Private Hospital to ensure that Hospitals are
complying with the order and directions and orders of
Respondent within the territory of Delhi. To the knowledge of
the Petitioner, no other person/bodies/institutions are likely to be
affected by the orders sought in the writ petition. The Petitioner
undertakes to add and/or amend the parties to the petition, if this
Hon’ble Court so direct.
4. That the Petitioner is Advocate by profession and such Petitioner
is very well conversant of the cause for which the present
petition is filed. The Petitioner has means to pay the costs, if
any, imposed by the Court. The Petitioner undertakes to deposit
the costs, if so, imposed by this Hon’ble Court.
5. That the petitioner has earlier filed no any Public Interest
Litigation,
6. That the present petition is filed on the following grounds
amongst others, as under: -
GROUNDS
A. BECAUSE multiple Private Hospitals have made
COVID-19 test mandatory before admitting elective
and even emergency patients, despite the Government
issuing a clarification on aforesaid issue, asking
hospitals authority not to test asymptomatic patients. It
is submitted that many hospitals, are hesitating in
providing critical services such as dialysis, blood
transfusion, chemotherapy, and institutional deliveries.
B. BECAUSE the Government and Private Hospitals are
continuously denying admission of asymptomatic and
symptomatic COVID-19 patient and not complying
with the order of the Respondent pertaining to the
treatment and admission of asymptomatic and
symptomatic or (COVID-19 and non-COVID-19)
patients.
C. BECAUSE the direction issued by Respondent that any
Private Hospital or nursing home in the National
Capital Territory that refuses emergent medical care to
the person amid COVID-19 pandemic, strict action will
be taken against those defaulters, especially in the case
of ESRD (End Stage Renal Disease) patients. Further,
Registration shall be cancelled for such Private
Hospital and/or Nursing Home. However, there is no
compliance of the direction.
D. BECAUSE Hospitals are charging high amount for
PPE (beyond the actual cost) from Patients using every
day during treatment.
E. BECAUSE Hospitals are forcing/compelling frontline
health workers to wear used PPE. According to source,
a nurse succumbed to COVID-19 in Hospital since she
was forced to wear “USED PPE”, which was used by
COVID-19 positive patient.
F. BECAUSE of negligence is being performed in
following and implementation of multiple orders of
Respondent pertaining to COVID -19 and non-COVID
19 patient due to which the health of the citizens in
Delhi is at high risk amid COVID-19 pandemic.
G. BECAUSE the grievance raised by the Petitioner is
genuine and the petition of the petitioner deserves to be
allowed.
7. That the petitioner seeks kind permission of this Hon’ble Court
to urge such other and further grounds as may available to him
as the time of hearing of the present writ petition.
8. That the present petition is bona fide and the same may be
allowed in the interest of justice.
9. That the petitioner craves indulgence of this Hon’ble Court to
raise any other or further ground(s) during the course of
arguments of the present petition.
10. That the present petition is bona-fide and the same may kindly
be allowed in the interest of Justice.
11. That the petitioner has not filed any other petition/application for
seeking similar relief before this Hon’ble Court or the Hon’ble
Supreme Court of India.
PRAYER
In the light of aforementioned facts and circumstances, it is
therefore most respectfully prayed to this Hon’ble Court that this
Hon’ble Court would be pleased to:
i. Issue a writ in the nature of Mandamus or any other writ
of like nature thereby passing order or direction to the
Respondent for ensuring that those Government and
Private Hospital or Nursing home in the National Capital
Territory that refuses emergent medical care to the person
amid Covid-19 pandemic, an immediate action shall be
taken against those defaulters.
ii. Issue a writ in the nature of Mandamus or any other writ
of like nature thereby passing order or direction to the
Respondent for ensuring that the Government and Private
Hospitals shall not deny the admission of asymptomatic
and symptomatic Covid-19 patient and complying with the
order of the Respondent pertaining to the treatment and
admission of asymptomatic and symptomatic or (COVID-
19 and non-COVID-19) patients.
iii. Issue a writ in the nature of Mandamus or any other writ
of like nature thereby passing order or direction to the
Respondent for ensuring that Covid-19 test shall not be
mandatory before admitting elective and even emergency
patients by Government and Private Hospitals.
iv. Issue a writ in the nature of Mandamus or any other writ
of like nature thereby passing order or direction to the
Respondent for ensuring that Hospitals are not forcing
Frontline health worker to wear used PPE.
v. Issue a writ in the nature of Mandamus or any other writ
of like nature thereby passing order or direction to the
Respondent for ensuring that hospitals are not charging
high amount for PPE (beyond the actual cost) from
patients, shall charge reasonable.
vi. Pass any other appropriate Order or Direction as this
Hon’ble Court may deem fit.
Filed By
New Delhi
Dated 03.06.2020 Krishna Kr. Sharma/K.M. Monika
(Petitioner in Person)
Ch. No. 906, Patiala House Courts,
New Delhi-110001
Mob- +91-9958891040
E-mail- [email protected]
IN THE HON’BLE HIGH COURT OF DELHI, AT NEW
DELHI
EXTRAORDINARY WRIT JURISDICTION
Writ Petition (Civil) No _____of 2020
IN THE PUBLIC INTEREST LITIGATION OF:
Krishna Kr. Sharma Petitioner
Versus
Govt. of NCT of Delhi Respondent
AFFIDAVIT
I Krishna Kr. Sharma S/o Sh. Sushil Kr. Sharma aged about 27
years having Office at Ch. No. 906, Patiala House Court Complex,
New Delhi- 110001 do hereby solemnly affirm and declare as
under:-
1. That I am the petitioner above named I have filed the present
petition as a Public Interest Litigation.
2. I have gone through the Delhi High Court (Public Interest
Litigation) Rules, 2010 (with all timely modification) and do
hereby affirm that the present Public Interest Litigation is in
conformity thereof.
3. I petitioner have/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 member of General Public.
This petition is not guided by self-gain of any person,
institution, body and there is no motive other than of public
interest in filing this petition.
4. 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.
5. That the contents of para ___ to ____ and grounds _____to
______ and prayer of the writ petition are drafted by me and
the same are true and to the personal knowledge of the
Deponent.
6. That the petitioner has not filed any other or similar petition
before this Hon’ble Court or before the Hon’ble Supreme
Court of India for seeking same relief.
DEPONENT
VERIFICATION
Verified at New Delhi on _________ that the contents of my
above affidavit are true and correct to my knowledge and
belief and nothing has been concealed therefrom.
DEPONENT
IN THE HON’BLE HIGH COURT OF DELHI, AT NEW
DELHI
EXTRAORDINARY WRIT JURISDICTION
Writ Petition (Civil) No _____of 2020
IN THE PUBLIC INTEREST LITIGATION OF:
Krishna Kr. Sharma Petitioner
Versus
Govt. of NCT of Delhi Respondent
APPLICATION UNDER SECTION 151 OF C.P.C FOR
SEEKING EXEMPTION FROM FILING CERTIFIED
COPIES, TRUE COPIES, TRUE TRANSLATED COPIES
WITH PROPER MARGINS OF THE ANNEXURES.
MOST RESPECTFULLY SHOWETH:
1. That the Petitioner has filed the accompanying writ
petition under article 226 Constitution of India r/w section
151 C.P.C.; for seeking directions.
2. That the Petitioner is unable to furnish the certified copies,
true copies, true translated copies, copies with proper
margins of the annexure at this stage due to paucity of
time and will submit the same before this Hon’ble Court
after obtaining the same in due course.
PRAYER
It is, therefore, most humbly and respectfully prayed that
filing of the certified copies, true copies, true translated
copies, copies with proper margins of the annexures may
very kindly be exempted in the interest of justice.
Filed by
New Delhi
Dated 03.06.2020 Krishna Kr. Sharma/K.M. Monika
(Petitioner in Person)
Ch. No. 906, Patiala House Courts,
New Delhi-110001
Mob- +91-9958891040
E-mail- [email protected]
IN THE HON’BLE HIGH COURT OF DELHI, AT NEW
DELHI
EXTRAORDINARY WRIT JURISDICTION
Writ Petition (Civil) No _____of 2020
IN THE PUBLIC INTEREST LITIGATION OF:
Krishna Kr. Sharma Petitioner
Versus
Govt. of NCT of Delhi Respondent
AFFIDAVIT
I Krishna Kr. Sharma S/o Sh. Sushil Kr Sharma aged about 27 years
having Office at Ch. No. 906, Patiala House Court Complex, New
Delhi- 110001 do hereby solemnly affirm and declare as under:-
1. That I am the petitioner above named and conversant with the
facts and circumstances of the present case and as such
competent to swear the present affidavit.
2. That I say that the accompanying application under section
151 of the Code of Civil Procedure. 1908; has been drafted
me and nothing material has been concealed therefrom.
DEPONENT
VERIFICATION
Verified at New Delhi on ____________ that the contents of
my above Affidavit are true and correct to my knowledge and
belief and nothing material has been concealed therefrom.
DEPONENT
IN THE HON’BLE HIGH COURT OF DELHI, AT NEW
DELHI
EXTRAORDINARY WRIT JURISDICTION
Writ Petition (Civil) No _____of 2020
IN THE PUBLIC INTEREST LITIGATION OF:
Krishna Kr. Sharma Petitioner
Versus
Govt. of NCT of Delhi Respondent
INDEX
S.NO
PARTICULAR (S) PAGE NO.
1. Court Fees
A
2. Urgent Application
B
3. Notice of Motion
C
4. Synopsis & List of Dates
D – K
5. Memo of Parties
1 – 2
6. Civil Writ Petition along with affidavit
3 – 15
7. Application under section 151 C.P.C for
exemption from filing certified/true
typed/ with proper margins of the
annexure, along with affidavit in
support.
16 – 19
8 The copy of order dated 17.04.2020 and
multiple news article are annexed
herewith as Annexure A-1 and
Annexure A-2 respectively.
20 - 40
9 The copy of the order-dated 24.04.2020
is annexed herewith as Annexure A-3.
41 – 68
10 The copy of news article dated
28.04.2020 is annexed herewith as
Annexure A-4. and ICMR guidelines
dated 20.03.2020 is annexed herewith as
Annexure A-5 respectively.
69 - 73
11 The copy of News article dated
28.04.2020 is annexed herewith as
Annexure A-6.
74 - 76
12 The copy of order dated 30.04.2020 is
annexed herewith as Annexure A-7.
77 – 79
13 The copy of News article dated
07.05.2020 is annexed herewith as
Annexure A-8.
80 – 83
14 The copy of News article dated 84 - 91
13.05.2020 is annexed herewith as
Annexure A-9.
15 A copy of News Paper article dated
25.05.2020 is annexed herewith as
Annexure A-10.
92 – 98
16 A copy of News Paper article dated
26.05.2020 is annexed herewith as
Annexure A-11.
99
17 VAKALATNAMA (Not Required as
Petition is being filed in person)
Filed By
New Delhi
Dated 03.06.2020 Krishna Kr. Sharma/K.M. Monika
(Petitioner in Person)
Ch. No. 906, Patiala House Courts,
New Delhi-110001
Mob- +91-9958891040
E-mail- [email protected]