IN THE HIGH COURT OF JUDICATURE AT BOMBAY
ORDINARY ORIGINAL CIVIL JURISDICTION
WRIT PETITION NO. OF 2016
Unnamed Girl Child of 13 days
Through its Mother the Natural Guardian
Noori Sameer Mujavar . …Petitioner
Versus
State of Maharashtra & Ors. …Respondents
P R O F O R M A
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Direction and Prothonotary’s order]
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Office Notes, Office Memoranda of ]Court or Judge’s
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IN THE HIGH COURT OF JUDICATURE AT BOMBAY
ORDINARY ORIGINAL CIVIL JURISDICTION
WRIT PETITION NO. OF 2016
Unnamed Girl Child of 13 days
Through its Mother the Natural Guardian
Noori Sameer Mujavar . …Petitioner
Versus
State of Maharashtra & Ors. …Respondents
INDEX
Sr. No
Particulars
PAGE No.
Proforma
Synopsis.
Memorandum of Petition.
Vakalatnama.
Memorandum of Registered Address.
List of Documents
Exhibit “A’’
A copy of the Notification No.LEN10/2001/ P.F.225/J-1 dated 4th April, 2002 issued by the Revenue Department of the Government of Maharashtra
Exhibit “B”
A Copy of the Notification Dated 17/04/2008 Extending the cut of date to 1/1/2000.
Exhibit “C”
Notification dated 12.8.2014 bearing No. ZPD/1001/PN 125/14.ZPS-1 extending the cut-off date from 1st January, 1995 to 1st January, 2000.
Affidavit in support of the Writ Petition.
Advocate’s Certificate
Advocate for the Petitioner
IN THE HIGH COURT OF JUDICATURE AT BOMBAY
ORDINARY ORIGINAL CIVIL JURISDICTION
WRIT PETITION NO. OF 2016
Unnamed Girl Child of 13 days
Through its Mother the Natural Guardian
Noori Sameer Mujavar .
Residing at Kavthekhadi,
Versova, Andheri (west) Mumbai…Petitioner
Versus
State of Maharashtra & Ors. …Respondents
SYNOPSIS
S.No.
Date
Events
Exhibit
Page No.
1
The Petitioner, an infant of 13 days old, constitutes the poorest of the poor strata of the society. She hails from _______ A good number of slum dwellers hail from the interior parts of Maharashtra. Some of them are born and brought up in the very slum itself. The Petitioner’s parents were forced to come to Mumbai in search of a livelihood faced with extreme poverty. Unlike other cities in India where some kind of rented accommodation could be afforded even by the poorest of the poor, in Mumbai the rent of even a match box like apartment would have meant more than their monthly income. They have only one option, to live on the street, under the bridges or set up a shanty, namely, a plastic sheet over their head wherever little space could be found. Mumbai being a marshy, unkempt island, millions of people who come in search of a job for their mere existence have to set up shanties wherever some vacant space is found. Thousands of poor people set up such shanties near and around the Kavthekhadi, Versova, Andheri (west) Mumbai..
2
The Authorities resorted to the most barbarian, cruel and inhuman means of sending bulldozers and JCBs with large contingent of police heavily armed, to destroy the shanties of the Petitioners and others and reduced their personal belongings, utensils, study materials of school going children, clothes, small possessions etc., to rubbles
3
4.4.2002
The State Government also took note of the aforesaid social and economic reality and took a policy decision to regularize all slums which were set up prior to 1st January, 1995 vide Notification No.LEN10/ 2001/P.F.225/J-1 dated 4th April, 2002 issued by the Revenue Department of the Government of Maharashtra regularizing such shanties/slums which have come into existence as of 1st January, 1995. Later the State Government took note of the fact that fixing a cut-off date as 1st January, 1995 is unrealistic and would mean thousands of slum dwellers being denied the benefit of regularization of their occupation, which is illegal in the eyes of those who are heartless, feudalistic et al. Accordingly, it issued a Notification dated 12.8.2014 bearing No. ZPD/1001/PN 125/14.ZPS-1 extending the cut-off date from 1st January, 1995 to 1st January, 2000.
“A” & “B”
Date: _____ day of March 2016.
Mumbai
Advocate for the Petitioner
Acts Relied upon:
Slum Rehabilitation Act
Constitution of India.
Authorities to be relied on:
At the time of hearing
IN THE HIGH COURT OF JUDICATURE AT Bombay
ORDINARY ORIGINAL CIVIL JURISDICTION
WRIT PETITION NO. OF 2016
Unnamed Girl Child of 13 days
Through its Mother the Natural Guardian
Noori Sameer Mujavar .
Residing at Kavthekhadi,
Versova, Andheri (west) Mumbai…Petitioner
Versus
1) State of Maharashtra,
represented by the Chief Secretary,
Mantralaya, Mumbai 400 032.
2) The Union of India, represented by its
Secretary in the Department of
Urban Development and Poverty
Eradication, Nirman Bhavan,
New Delhi.
3) Municipal Commissioner,
Municipal Corporation of
Greater Bombay,
Mahanagarpalika
Marg, Opp. C.S.T. Station,
Mumbai – 400 001.
4) The Commissioner of Police,
Greater Mumbai,
Crawford Market,
Mumbai. …Respondents
TO
THE HONOURABLE THE CHIEF JUSTICE
AND THE OTHER HONOURABLE PUISNE
JUDGES OF THIS HONOURABLE Court
HUMBLE PETITION OF THE Petitioners ABOVENAMED UNDER Article 226 OF THE CONSTITUTION OF INDIA
MOST RESPECTFULLY SHEWETH:
The Petitioner, an infant Girl of 13 days is a citizen of India. Since the Petitioner is only 13 days old, her naming ceremony as per rituals is yet to take place. Petitioner is a resident of Kavthekhadi, Versova, Andheri (W) Mumbai., a slum dweller, whose family ekes out a living by the female members working as maids and the male members as sundry workers. They constitute to be the poorest of the poor section of the society. They possess nothing to be reminded of the words of Jesus Christ, “The foxes have holes and birds of the air has nest but the son of man has nowhere to lay His head”. Petitioner and thousands like him/her are born in poverty, hunger, destitution and live in the mire of illiteracy and ignorance since their early childhood have never ever enjoyed happiness and the pleasure of life, but only pain, hunger, poverty, being driven away from wherever they tried to make their humble beds, on pavements, under the bridges etc., left with no option have set up shanties on the precincts of the Versova, Andheri (west) Mumbai Mumbai. These poor and hapless keep their body and soul together by working day in and day out for paltry sums.
The Petitioner an infant of an infant Girl of 13 days is the residents of Rahul Nagar, a slum situate at Versova, Andheri (west) Mumbai in Mumbai and is filing this Petition under Chapter V, Rule 3 of the Bombay Original Side Rules. Mrs. Noori Sameer Mujavar has filed the affidavit, as the natural guardian / a next friend to the Petitioners and she has no interest directly or indirectly adverse to that of the minor, and she is otherwise a fit and proper person to act as such next friend. The
The Petitioners’ parents have set up their shanties prior to 1995/ 2000 dates which are relevant since the Government of Maharashtra has taken a policy decision to regularize all slums set up prior to 1995/2000. There are about 70 families who, like the Petitioners, living in almost inhuman conditions in Kavthekhadi Versova, Andheri (west) Mumbai. They have obtained electricity connection, ration card, Aadhar Card etc. and with the little savings over the years they could purchase some utensils, furniture etc. The parents of the petitioner are illiterates and, as aforesaid, constitute the weakest of the weaker section of the society. Being illiterates and living in extreme poverty and depravation, they did not come to know about the PIL and the orders passed therein by this Hon'ble Court, particularly the monitoring mechanism evolved therefrom.
The Petitioner through her natural guardian is constrained to institute the instant petition, since the BMCI MHADA without any rhyme or reason and without any Notice whatsoever and without giving any opportunity for the Petitioner’s kith and kin to remove their personal belongings, the most important things such as medicines, clothing, and basic summer clothings, nay, even without allowing them to remove their personal belongings, on ________, armed with massive police force, using JCBs and other equipments, demolished their shanties and rendered them homeless, without providing any alternative accommodation or any humanitarian aid such as water, food, medicine, Clothing, especially in the chilling weather. The Petitioner being only 13 days old runs a very high risk of loosing her life under the given circumstances.
The seemingly brutal act of attacking the Petitioner, has left her with no roof over its head thereby endangering its very existence. The Petitioner, his mother, sisters, so too elderly women, mothers with infants and toddlers were left to be exposed to the hot and humid nights so also the scorching heat without a shade over their heads or clothes to protect; much less, even water to drink. At a time when they were cursing themselves hopelessly, having no idea what was to be done, where/ how to seek justice; they were advised that though humble, helpless and penniless they were, they could surely knock the doors of this majestic court under Article 226 of their Constitution.
The Petitioner through his/her guardian is advised that the injustice to which they are subjected to, the indescribable pain, agony and suffering they are subjected to, by the most Cruel, illegal, arbitrary and inhuman act of the BMC, MHADA and Police authorities require no elaboration for there cannot be a greater infringement of their very right to life, the protection in terms of 14, 19 and 21 of the Constitution than the one as the instant.
As stated earlier, it is the poverty, destitution, hunger and illiteracy that made Petitioner’s parents and thousands like them to set up shanties in the precincts of the Kavthekhadi Versova, Andheri (west) Mumbai Suffice to say, the Respondents State of Maharashtra and the Mumbai Municipal Corporation, instead of finding a holistic solution to the greatest problem which the city of Mumbai faces today, namely, of providing a roof over the heads of the millions of homeless, which is certainly possible if the city is allowed to go vertical, supported by Metro and wide roads, so too by utilizing the large extent of vacant land today termed as non-development zone either because they are salt pans or mangroves, have resorted to the most barbarian, cruel and inhuman means of sending bulldozers and JCBs with large contingent of police heavily armed, to destroy the shanties of the Petitioners and others and reduced their personal belongings, utensils, study materials of school going children, clothes, small possessions etc., to rubble. The Hon'ble Judges of this Court are benevolent, large hearted, compassionate, justice conscious, humane, wise and sagacious and it is undoubtedly preposterous for the Petitioners to go on elaborating what it means for a poor man to have his shanty demolished and his little belongings to be reduced to rubble.
The Petitioners constitute the poorest of the poor strata of the society. They hail from different parts of the country and belong to different religions. A good number of them hail from the interior parts of Maharashtra. Some of them are born and brought up in the very slum itself. The Petitioners were forced to come to Mumbai in search of a livelihood faced with extreme poverty. Unlike other cities in India where some kind of rented accommodation could be afforded even by the poorest of the poor, in Mumbai the rent of even a match box like apartment would have meant more than their monthly income. They have only one option, to live on the street, under the bridges or set up a shanty, namely, a plastic sheet over their head wherever little space could be found. Mumbai being a marshy, unkempt island, millions of people who come in search of a job for their mere existence have to set up shanties wherever some vacant space is found. Thousands of poor people set up such shanties. But necessity and hunger knows no law.
The Supreme Court in Olga Tellis v. Municipal Corporation of Bombay, AIR 1986 SC 180, took note of the fact that millions of people migrate to Mumbai in search of a job and unable to find a place to rest their head after a day’s toil are forced to set up shanties at places where vacant land is found – marshy, filthy and so on. In that case the Supreme Court was pleased to hold that slum dwellers who make the city move by providing for the essential manpower are not trespassers on public land, but out of their total helplessness are forced to set up such shanties. In the said judgment, the Supreme Court also took note of the fact that right to life does not mean mere animal existence but a right to lead a life with all its richness and fullness. In the case of slum dwellers, protection against demolition of their shanties involved not the question of enjoying a life in its richness and fullness, but meant the very animal existence.
The State Government also took note of the aforesaid social and economic reality and took a policy decision to regularize all slums which were set up prior to 1st January, 1995. A copy of the Notification No.LEN10/2001/ P.F.225/J-1 dated 4th April, 2002 issued by the Revenue Department of the Government of Maharashtra regularizing such shanties/slums which have come into existence as of 1st January, 1995, which is in Marathi, is produced and marked for reference as Exhibit “ A ”. The Government on 17/04/2008 issued a notification extending the cutoff date to 20/01/2000 in the case of project affected slum dwellers. A copy thereof annexed as Annexed “B”. Later the State Government took note of the fact that fixing a cut-off date as 1st January, 1995 is unrealistic and would mean thousands of slum dwellers being denied the benefit of regularization of their occupation, which is illegal in the eyes of those who are heartless, feudalistic et al. Accordingly, it issued a Notification dated 12.8.2014 bearing No. ZPD/1001/PN 125/14.ZPS-1 extending the cut-off date from 1st January, 1995 to 1st January, 2000. A copy of the said Notification is produced and marked for reference as Exhibit “ C ”.
It is an undeniable fact that a section of the public opinion and the society is anti-poor and a section of the society also nourishes parochial feelings. To the opulent and the heartless, poor people are nothing but dirt and despicable and they ought to be thrown out of the city. In their parochial and feudalistic bias against the poor, they forget the fact that it is they, who live in filth and dirt, who constitute entirely of the unskilled and semi-skilled work force in the commercial city which Mumbai is, who work at construction sites, for construction of roads, as drivers, office assistants, lift operators, peons, et al. It is ironical that the rich and the mighty and those who nourish and nurture parochial philosophy are so thankless to the poor, who toil and very often get injured and even died at construction sites and other hazardous industries.
The demolition effected as aforesaid is in clear violation of the constitutional/fundamental rights of the Petitioner Nos. 1 and 2 as also in direct conflict with the order, extracted above. Therefore, the Respondents ought to be directed to undo the injustice caused to the Petitioner Nos. 1 and 2 and the only way to do so is to provide them with alternate accommodation/ rehabilitate them forthwith, provide them shelter, food and other basic amenities, without which their very life cannot be sustained.
Section 314 of the Mumbai Municipal Corporation Act, invoking of which, the Petitioners have been rendered homeless and their shanties were demolished, is unconstitutional and void inasmuch as it empowers the Municipal Commissioner/its officers to demolish the hutment of a slum dweller or a roof of a pavement dweller without giving any notice providing any alternative accommodation. Right to life is one of the basic features of the Constitution of India; one of the fundamental rights of great sanctity, which no authority, legislature nor the Court, could take away from a citizen. The Petitioners who eke out their livelihood by working at construction sites, for construction of roads, as drivers, office assistants, lift operators, peons, et al, were compelled to set up their shanties in the land supposed to be belonging to the Municipal Corporation out of dire necessity. They, therefore, are not encroachers. Necesitas non habet legem – necessity knows or has no law. They are on the land in question out of dire necessity; and encroachment done out of extreme necessity is no encroachment in the eye of law and is legally permissible. It is well settled in law that the validity or otherwise of an Act of Parliament will have to be tested on ground realities. In effect, Section 314 of the MMC Act empowering a destitute, a homeless, a slum dweller, to be deprived of his or her sheet over head without affording any hearing without providing any rehabilitation, is unconstitutional and void ab initio. The said Section, therefore, is liable to be struck down at the hands of this Hon'ble Court as unconstitutional. If this Hon'ble Court were to save the said Section from its unconstitutionality, which is put to challenge here, then the said Section has to be construed in consonance with Part III of the Constitution, namely, that not only the right to be heard has to be read into the said Section but the right to life, as well.
GROUNDS
Classification of the slums as those set up prior to 1st January, 1995 or 1st January, 2000 and thereafter and afford protection to the former and deny the same to the latter is wholly unconstitutional;
Food, clothing and shelter are the bare necessities of life. Hundreds of school going children are deprived of the basic needs of life. School going children, babies, sick and ailing women are entitled to the protection of the State. Rex est procurator factuoram - it is the duty of the king to protect those who cannot protect themselves;
The judgment dated 13th January, 2016 in Writ Petition No. WPL 64/2016 is one rendered void ab initio. It is a gross violation of the concept of justice, equity and fairness to arrive at a conclusion on a question of fact in a proceeding under Article 226 of the Constitution without taking evidence, without affording an opportunity to the affected to contradict the assertion of the BMC. If a Constitution Amendment could be declared to be void, being in violation of the basic structure of the Constitution, the aforesaid judgment of this Hon'ble Court could be no exception to the doctrine of nullity.
11. The Petitioners crave leave of this Hon’ble Court to add to, alter, amend and/or modify any of the aforesaid grounds as and when required.
12. No other application in respect of the subject-matter of this Petition has been filed either in the Hon’ble Supreme Court of India or in this Hon’ble High Court.
13. The Petitioners state that there is no period of limitation for preferring this Petition and hence the same is within limitation.
14. The Petitioners have no other efficacious alternative procedure may remedy through to use the phrase ‘remedy’ is in corrected.
15.The Petitioners state that the cause of action has arisen in Mumbai and hence this Hon’ble Court has jurisdiction to entertain this Petition.
THE PETITIONERS, THEREFORE, PRAY THAT THIS Hon'ble Court BE GRACIOUSLY PLEASED TO:
receive the present Writ Petition, which is certainly one for redressal of the injustice and unthinkable horror committed on the Petitioner & their like, exempt the Petitioner from payment of Court-fee as also compliance with the rules of procedure, lest the very cause of justice will be sacrificed in the altar of procedure which is only a handmaiden of justice and not its mistress;
declare that the dispossession of the Petitioner and their like, from their homes is against the basic tenets of law, a crime against humanity and grave violation of human rights and further to not only direct immediate restoration of their shanties, their abode, but also to compensate them for the unthinkable calamity, injustice and cruelty wreaked on them;
issue a writ of mandamus or any or any other appropriate writ or order directing the Government of Maharashtra, BMC/MMC/ MHADA to forthwith provide alternate accommodation, medical aid and other essential facilities to the Petitioner Nos. 1 & 2 and their like, lest their infants and toddlers will die being exposed to the simmering sun, being without food;
declare that a Full Bench or even a larger Bench of this Hon’ble Court is required to be constituted since the instant Writ Petition involve larger issues of right to life of the millions of slum dwellers who constitute to be the 60% of the population of the City of Mumbai, particularly since there exist to be a number of judgments of the various Division Benches of this Court, rendered upon PILs “a ravenous wolf in a clothing of a sheep”, without issuing notice to the public at large, slum dwellers/ the affected parties and thus rendered void ab initio, so too in conflict with a catena of Constitutional benches of the Supreme Court, in particular, Keshavananda Bharthi, Olga Tellis etc. and accordingly pass an appropriate order for the matter to be placed before the Hon’ble Chief Justice for constitution of a Full Bench / Larger Bench;
issue an appropriate writ or order or declaration, declaring that the notification LEN10/2001/P.F.225/J-1 dated 4th April, 2002 and ZPD/1001/PN 125/14.ZPS-1 dated 12.8.2014 (Exhibit “B” hereto) classifying slum dwellers into different categories, namely, (i) those prior to 1st January, 1995 (ii) those between 1st January, 1995 and 1st January, 2000 and (iii) those who have come after 2000 is wholly irrational, arbitrary and unconstitutional, being in violation of Article 14 of the Constitution;
issue an appropriate writ, be it in the nature of certiorari or any other appropriate writ, order or declaration, declaring that Section 314 of the Mumbai Municipal Corporation Act, 1888 is unconstitutional and void inasmuch as it empowers the Municipal Commissioner/its officers to demolish/ cause to be removed the hutment of a slum dweller or a roof of a pavement dweller without notice, which is against the fundamental rights guaranteed to a citizen under the Constitution of India or in the ALTERNATIVE to declare that such a requirement is to be read into the said Section;
pass an order of ad-interim, mandatory and prohibitory injunction restraining and prohibiting the Respondents from in any manner interfering with the estate, rights, title, possession and enjoyment of the shanties in question which stands demolished and in particular causing any obstruction of the estate title and right which are invested in them as slum dwellers and further to direct that the be provided food, clothing and medicines pending final disposal of the above Writ Petition;
pass such further and other orders as the nature and circumstances of the case may warrant.
Petitioner through her guardian Noori Sameer Mujavar
Advocates for the Petitioners
V E R I F I C A T I ON
I, Noori Sameer Mujavar aged about _____years residing at Kavthekhadi Versova, Andheri (west) Mumbai, on behalf of the Petitioner being the natural guardian/ next friend, do hereby solemnly declare that what is stated in paragraphs 1 to 10 of the foregoing Petition is true to my own knowledge, information and belief and what is stated in remaining paragraphs is based on information which I believe to be true and correct.
Solemnly declared at Mumbai]
on this ___ day of March , 2016.] Petitioner through her guardian Noori
Sameer Mujavar
Advocates for the Petitioners
We are not members of Advocates Welfare Fund and hence court fees of Rs.2 have not been affixed.
V A K A L A T N A M A
IN THE HIGH COURT OF JUDICATURE AT Bombay
ORDINARY ORIGINAL CIVIL JURISDICTION
WRIT PETITION NO. OF 2016
Unnamed Girl Child of 13 days
Through its Mother the Natural Guardian
Noori Sameer Mujavar .
Residing at Kavthekhadi,
Versova, Andheri (west) Mumbai…Petitioner
Versus
1) State of Maharashtra,
represented by the Chief Secretary,
Mantralaya, Mumbai 400 032.
2) The Union of India, represented by its
Secretary in the Department of
Urban Development and Poverty
Eradication, Nirman Bhavan,
New Delhi.
3) Municipal Commissioner,
Municipal Corporation of
Greater Bombay,
Mahanagarpalika
Marg, Opp. C.S.T. Station,
Mumbai – 400 001.
4) The Commissioner of Police,
Greater Mumbai,
Crawford Market,
Mumbai. …Respondents
To
The Prothonotary/ Registrar O.S
High Court of Judicature at Bombay
MUMBAI 400 032
Madam,
I, Noori Sameer Mujavar the natural guardian of Petitioner abovenamed, do hereby appoint Mrs. Rohini M. Amin and Shri R.R. Nair, Advocates, to act, appear and plead for us in the above petition.
IN WITNESS WHEREOF I have subscribed my hand hereto.
Dated this ___ day of March 2016.
Accepted:
Mrs. Rohini M. Amin,
R.R.Nair
Advocates
304, Hari Chambers, 58/64 SBS Marg,
Near Old Customs House, Fort,
Mumbai- 400 023
(98205 35428 &
9892809502)
IN THE HIGH COURT OF JUDICATURE AT BOMBAY
ORDINARY ORIGINAL CIVIL JURISDICTION
WRIT PETITION NO. OF 2016
Unnamed Girl Child of 13 days
Through its Mother the Natural Guardian
Noori Sameer Mujavar . …Petitioner
Versus
State of Maharashtra & Ors. …Respondents
AFFIDAVIT IN SUPPORT
I, Noori Sameer Mujavar, aged about ________years residing at Kavthekhadi Versova, Andheri (west) Mumbai on behalf of the Petitioner being the natural guardian since I am the Petitioner’s Mother, do hereby solemnly affirm and state as under:
I am the Natural Guardian Petitioner in the above Writ Petition. I know the facts of the case and am competent swear this affidavit.
That, the above Writ Petition has been drafted by the Petitioner’s Counsel on my instructions. I have read and understood the contents of the same which are true and correct to my knowledge and belief. No fact of it is false and nothing material has been concealed therefrom.
That, the Exhibits filed along with the Writ Petition are the true and correct copies of their respective originals.
I, therefore, pray that this Hon’ble Court be pleased to allow the above Writ Petition with costs.
Solemnly affirmed at Mumbai ]
on this day of March 2016 ] Petitioner
Advocate for the Petitioner
IN THE HIGH COURT OF JUDICATURE AT BOMBAY
ORDINARY ORIGINAL CIVIL JURISDICTION
WRIT PETITION NO. OF 2016
Unnamed Girl Child of 13 days
Through its Mother the Natural Guardian
Noori Sameer Mujavar . …Petitioner
Versus
State of Maharashtra & Ors. …Respondents
LIST OF DOCUMENT
1.Documents and Exhibits referred to and relied upon in the Petition.
2.Documents annexed to this Petition.
3.Any other documents.
Advocates for the Petitioner
IN THE HIGH COURT OF JUDICATURE AT BOMBAY
ORDINARY ORIGINAL CIVIL JURISDICTION
WRIT PETITION NO. OF 2016
Unnamed Girl Child of 13 days
Through its Mother the Natural Guardian
Noori Sameer Mujavar . …Petitioner
Versus
State of Maharashtra & Ors. …Respondents
To
The Registrar (OS) / Prothonotary& Senior Master,
High Court of Judicature at Bombay
MUMBAI 400 032.
ADVOCATE’S CERTIFICATE
I, Mrs. Rohini M. Amin, Shri R.R.Nair, Advocates for the Petitioner, do hereby state that the above matter is required to be considered by a Division Bench of this Hon’ble Court under Rule 636(1)(b) of the High Court (Original Side) Rules.
Dated this __ day of March 2016.
Advocates for the Petitioner
IN THE HIGH COURT OF JUDICATURE AT BOMBAY
ORDINARY ORIGINAL CIVIL JURISDICTION
WRIT PETITION NO. OF 2016
Unnamed Girl Child of 13 days
Through its Mother the Natural Guardian
Noori Sameer Mujavar . …Petitioner
Versus
State of Maharashtra & Ors. …Respondents
MEMORANDUM OF ADDRESS
Mrs. Rohini M. Amin,
R.R.Nair
Advocates
304, Hari Chambers, 58/64 SBS Marg,
Near Old Customs House, Fort,
Mumbai- 400 023
(98205 35428 &
9892809502)
Advocates for Petitioners
IN THE HIGH COURT OF JUDICATURE AT BOMBAY
ORDINARY ORIGINAL CIVIL JURISDICTION
WRIT PETITION NO. OF 2016
Unnamed Girl Child of 13 days
Through its Mother the Natural
Guardian Noori Sameer Mujavar . …Petitioner
Versus
State of Maharashtra & Ors. …Respondents
WRIT PETITION NO. OF 2016
Dated ____March 2016
Mrs. Rohini M. Amin,
R.R.Nair
Advocates
304, Hari Chambers,
58/64 SBS Marg,
Near Old Customs House, Fort,
Mumbai- 400 023
(98205 35428 &
9892809502)
