IN THE HIGH COURT OF
(EXTRA ORDINARY CRIMINAL JURISDICTION)
Crl. Misc. (Main) No. ______ of 20__
IN THE MATTER OF:
______________                       …       PETITIONER
VERSUS
N.C.T. of Delhi & Another                    …       RESPONDENTS
INDEX
S.No. Particulars   Page
Nos.

1. Notice of Motion   A

2. Urgent Application   B

3. Memo of party   C

4. Criminal Misc. Main petition for quashing of FIR
no. ___ dated _______, U/S 285/304-A IPC, P.S.
_______, u/s 482 Cr.P.C. alongwith affidavit

1 –

5.
Annexure P-1
Copy of FIR No.___ dated _____

6.
Annexure P-2
Copy of Compromise Deed dated ______

7.
Annexure P-3
Copy of the Demand Draft dated _________

8
Annexure P-4
Affidavit of Respondent No. 2

9. Application for exemption from filing certified
copies of the annexures alongwith affidavit

10. Vakalatnama
Petitioner
Through
________

Advocate
_______________,
Place:                                                  _____________________
Date:
IN THE HIGH COURT OF
(EXTRA ORDINARY CRIMINAL JURISDICTION)
Crl. Misc. (Main) No. ______ of 20__
IN THE MATTER OF:
_____________________                             …       PETITIONER
VERSUS
& Another                    …       RESPONDENTS
NOTICE OF MOTION
Sir,
The enclosed petition in the aforesaid matter is being filed on behalf of the
petitioner and is likely to be listed on __________ or any date, thereafter.
Please take notice accordingly. Issue any appropriate order for quashing
and setting aside the FIR No. ___ dated ______.
Petitioner
Through
Advocate
IN THE HIGH COURT OF
To,
The Deputy Registrar,
Case No. ________________________ of 2010
IN THE MATTER OF:
_____________________                             …       PETITIONER

VERSUS
& Another                    …       RESPONDENTS
URGENT APPLICATION
Sir,
Will you kindly treat the accompanying petition as urgent one in accordance
with the High Courts Rules and Orders.
1.       The ground of urgency are:
Yours faithfully,
IN THE HIGH COURT OF \
(EXTRA ORDINARY CRIMINAL JURISDICTION)
Crl. Misc. (Main) No. ______ of 20__
IN THE MATTER OF:
__________________                         …       PETITIONER
VERSUS
\ Another                    …       RESPONDENTS
MEMO OF PARTIES
1.
2.
…       PETITIONERS
Versus
1.       \
2.
…       Respondents
Petitioner
Through
Advocate

____________,
Place:                                                  ______________
Date:                                                    \
IN THE HIGH COURT OF \
(EXTRA ORDINARY CRIMINAL JURISDICTION)
Crl. Misc. (Main) No. ______ of 20__
IN THE MATTER OF:
_____________ &  Others                            …       PETITIONER
VERSUS
N.C.T. of Delhi & Another                    …       RESPONDENTS
CRIMINAL MISC. MAIN PETITION FOR QUASHING OF FIR NO.____
Dated _________, U/S ________IPC, P.S. _______________, DEL\U/S
482 CR.P.C.
It is most respectfully submitted as under:-
That the petitioner no 1 is a ___________ and petitioner no. 2 is working as
a Manager of the petitioner no. 1 concern.
That the respondent No. 2 is the of the deceased, Late
That the deceased was working as in the factory of petitioner no 1 and was
drawing a monthly salary of Rs. ______/- per month.
That on _______ the deceased unfortunately died in an accident while
working in the factory of the petitioner no. 1.
That an FIR No. _____ was registered at P.S. __________   on _____,
U/ss 285/304-A IPC in connection with the death of the deceased
___________. Copy of the said FIR is enclosed and marked as Annexure
P-1.
That subsequently the parties executed a compromise deed dated
__________, wherein it has been mutually agreed and settled between the
parties that neither the petitioners nor any other person was responsible for
the death of the deceased, which took place by way of an accident under

extremely unfortunate circumstances. A copy of the Memorandum of
Settlement is enclosed and marked as Annexure P-2.
That it has been settled between the parties in the aforesaid Compromise
Deed that the petitioner no. 1 has agreed to pay a sum of _______/-
(Rupees _________ only) by way of Pay Order dated Copy of the aforesaid
pay order is enclosed and marked as Annexure P-3(colly)
That as per the Memorandum of Settlement executed between the parties,
there is no claim or dispute whatsoever pending between the respondent
as against the petitioners.   As per the settlement deed, the FIR No. _____
and the allegations made by the respondent in the FIR stand withdrawn
and the respondent shall make a formal statement for quashing of the
aforesaid FIR, before this Hon’ble Court. A copy of the affidavit of
respondent no. 2 is enclosed and marked as Annexure P-4.
That in view of the amicable settlement between the parties, the present
petition is being filed for quashing of the aforesaid FIR.
That the present petition is being filed on inter-alia the following amongst
other grounds:-
GROUNDS
For that the petitioners and respondent no. 2 have amicably settled the
matter vide Memorandum of Settlement dated __________, whereby the
respondent has agreed to the quashing of the aforesaid FIR No. ____.
For that no useful purpose would be served by continuing the prosecution
pursuant to the aforesaid FIR. It would be in the interests of justice that the
said FIR is quashed.
For that it has been settled between the parties that the death of was
caused due to an accident and that no one was responsible for the same.
For that in any event, on a reading of the FIR as it is, no offence
whatsoever is made out against the petitioners including the offences U/S’s
287,336,304-A, IPC.
That this Hon’ble Court has the jurisdiction to entertain and adjudicate the
instant petition.

That this petition is being filed within a reasonable time and there is no
delay in the same.
That no other petition for quashing of FIR, has been filed by the petitioners
before this Hon’ble Court or any other Court of law.
That the aforesaid facts and grounds constitute the cause of action for filing
the present petition.
PRAYER
In view of the aforesaid, it is most respectfully prayed that this Hon’ble
Court may be pleased to:-
a)           Quash the FIR No. ____ U/s 287/ 336/304- A, Indian Penal Code,
P.S. ________________;
b)           Pass any other order as may be deem fit and proper in the facts
and circumstances of the case.
Petitioners
Through
______
Advocate
IN THE HIGH COURT OF DELHI AT NEW DELHI
(EXTRA ORDINARY CRIMINAL JURISDICTION)
Crl. Misc. (Main) No. ______ of 20__
IN THE MATTER OF:
________________________                        …       PETITIONER
VERSUS
N.C.T. of Delhi & Another                    …       RESPONDENTS
AFFIDAVIT
I, _________, S/o Late ______________, aged about ____ years, R/o
____________ do hereby solemnly affirm and declare as under:-

That I am the petitioner in the aforesaid case and am acquainted with the
facts and circumstances of the case.
That the accompanying petition for quashing of FIR has been drafted by my
counsel under my instructions.
That the contents of the petition are true and correct to the best of my
knowledge, information and belief and nothing material has been
concealed there from.
DEPONENT
Verification:
Verified at New Delhi today i.e.            day of ____, 20__ that the contents
of this affidavit are true and correct to the best of my knowledge and belief
and nothing material has been concealed there from.
DEPONENT
IN THE HIGH COURT OF DELHI AT NEW DELHI
(EXTRA ORDINARY CRIMINAL JURISDICTION)
Crl. Misc. (Main) No. ______ of 20__
IN THE MATTER OF:
__________________                         …       PETITIONER
VERSUS
N.C.T. of Delhi & Another                    …       RESPONDENTS
AFFIDAVIT
I,                                    S/o                                           , R/o
do hereby solemnly affirm and declare
as under:-
That I am the petitioner in the aforesaid case and am acquainted with the
facts and circumstances of the case.
That the accompanying application for exemption has been drafted by my
counsel under my instructions.

That the contents of the application are true and correct to the best of my
knowledge, information and belief and nothing material has been
concealed there from.
DEPONENT
Verification:
Verified at New Delhi today i.e.            day of ___, 20__ that the contents of
this affidavit are true and correct to the best of my knowledge and belief
and nothing material has been concealed there from.
IN THE HIGH COURT OF DELHI AT NEW DELHI
(EXTRA ORDINARY CRIMINAL JURISDICTION)
Crl. Misc. (Main) No. ______ of 20__
IN THE MATTER OF:
________________                             …       PETITIONER
VERSUS
N.C.T. of Delhi & Another                    …       RESPONDENTS
AFFIDAVIT

I, ________ W/o _________________ R/o _________________ do hereby
solemnly affirm and declare as under:-
That I am the respondent no. 2 in the aforesaid case and am acquainted
with the facts and circumstances of the case.
That I have no objection to the quashing of FIR No. ___ dated _______
U/ss 285 & 304-A IPC registered in Police Station ____________. I have
entered into a compromise in this regard, vide Compromise Deed dated
____________.
That the contents of the affidavit have been read and explained to me in
vernacular language.
DEPONENT
Verification:

Verified at New Delhi today i.e.            day of ___, 20__ that the contents of
this affidavit are true and correct to the best of my knowledge and belief
and nothing material has been concealed there from.
DEPONENT
IN THE HIGH COURT OF DELHI AT NEW DELHI
(EXTRA ORDINARY CRIMINAL JURISDICTION)
I.A. No.______ of 20__
IN
Crl. Misc. (Main) No. ______ of 20___
IN THE MATTER OF:
__________________                         …       PETITIONER
VERSUS
N.C.T. of Delhi & Another                    …       RESPONDENTS
APPLICATION FOR EXEMPTION FROM FILING CERTIFIED COPIES OF
THE ANNEXURES.
The Petitioner most respectfully submit as under:-
1.       That the certified copies of certain Annexures (as required by the
Rules) mentioned in the accompanying petition, shall be filed before this
Hon’ble Court in due course as and when the same are received.
PRAYER
It is most respectfully prayed that this Hon’ble Court may be pleased to:
a.       Grant exemption from filing of certified copies of certain annexures,
with liberty to file the same in due course; &
b.       pass any other order as may be deemed fit in the facts and
circumstances of the case.
Petitioner
Through
Advocate

IN THE HIGH COURT OF DELHI AT NEW DELHI
(EXTRA ORDINARY CRIMINAL JURISDICTION)
Crl. Misc. (Main) No. ______ of 20__
IN THE MATTER OF:
_____________________                             …       PETITIONER
VERSUS
N.C.T. of Delhi & Another                    …       RESPONDENTS
AFFIDAVIT
I, ______ , S/o ______ , aged about _____ ,Chamber _____,  New Delhi
do hereby solemnly affirm and declare as under:-
That I am the proxy counsel in the aforesaid case and am acquainted with
the facts and circumstances of the case.
That the accompanying application for exemption for filing certified copies
has been drafted by me.
That the contents of the application are true and correct to the best of my
knowledge, information and belief and nothing material has been
concealed there from.
DEPONENT
Verification:
Verified at New Delhi today i.e.            day of March, 20__ that the contents
of this affidavit are true and correct to the best of my knowledge and belief
and nothing material has been concealed there from.
DEPONENT