The petitioner, a lawyer, has filed a writ petition in the High Court of Punjab and Haryana on behalf of Sudha Bharadwaj, who has been detained by the Maharashtra Police. The petition alleges that Bharadwaj's detention and arrest are illegal and violate her fundamental rights. It seeks orders for her immediate release, appointment of a commission to investigate, and a stay on her remand order. The petition states that Bharadwaj has been detained without cause and questions the legality of the police action. Interim relief is sought for her to be placed under house arrest during the hearing of the petition.

1. IN THE HIGH COURT FOR THE STATES OF PUNJAB AND
HARYANA AT CHANDIGARH
CRWP No.701of 2018
ANKIT GREWAL, ADVOCATE AS A NEXT BEST FRIEND OF ADVOCATE SUDHA
BHARADWAJ (DETENUE)
…Petitioner
Versus
STATE OF HARYANA and Others
…Respondents
I N D E X
Sr.
No.
Particulars Dates Pages Court
Fee
1. Urgent Form 28.08.2018
2. Memo of parties 28.08.2018
3. Criminal Writ Petition 28.08.2018
5. ANNEXURES
6. P-1 (DOCUMENT
SUPPLIED BY THE POLICE)
7. P-2 COPY OF PETITION
FILED BEFORE HON.
DELHI HIGH COURT IN
WP (CRI) 2559 OF 2018
8. Power of Attorney -
NOTE:-
Total Court Fee Rs.___________
The main law points canvassed in this writ petition are mentioned at
Page in Para thereto.

2. 1
.
Relevant Rules/Statute: Constitution of India,
2
.
Any other Case: NIL
Any Caveat Petition: No
CHANDIGARH
DATED: 28/08/2018
(ARJUN SHEORAN) (NEHA SONAWANE)
P/867/2011 MAH/5843/2011
ADVOCATES
COUNSEL FOR THE PETITIONER
M:9592771330/9855686442
office@vaakyalegal.com

3. IN THE HIGH COURT FOR THE STATES OF PUNJAB AND HARYANA
AT CHANDIGARH
CRWP No._______ of 2018
ANKIT GREWAL, ADVOCATE AS A NEXT BEST FRIEND OF ADVOCATE SUDHA
BHARADWAJ (DETENUE)
…Petitioner
Versus
STATE OF HARYANA and Others
…Respondents
Total Court Fee Rs.___________
CHANDIGARH
DATED: 28/08/2018
(RS BAINS) (ARJUN SHEORAN) (NEHA SONAWANE)
P/867/2011 MAH/5843/2011
ADVOCATES
COUNSEL FOR THE PETITIONER
M:9592771330/9855686442
office@vaakyalegal.com

5. IN THE HIGH COURT FOR THE STATES OF PUNJAB AND HARYANA
AT CHANDIGARH
CRWP No._______ of 2018
MEMO OF PARTIES
CRWP No._______ of 2018
ANKIT GREWAL, ADVOCATE AS A NEXT BEST FRIEND OF ADVOCATE SUDHA
BHARADWAJ (DETENUE)
Aged 28 years, s/o Jitender Singh, r/o 1474, Sector 20 B, Chandigarh
VERSUS
1.STATE OF HARYANA
2.POLICE STATION, SURAJKUND THROUGH ITS SHO
3.MAHARASHTRA POLICE
THROUGH THE RESIDENT COMMISSIONER MAHARASHTRA
4. DIRECTOR GENERAL OF POLICE, HARYANA, POLICE HQ,
PANCHKULA
RESPONDENTS
…Respondents
CHANDIGARH
DATED: 28/08/2018
(RS BAINS) (ARJUN SHEORAN) (NEHA SONAWANE)
P/867/2011 MAH/5843/2011
ADVOCATES
COUNSEL FOR THE PETITIONER
M:9592771330/9855686442
office@vaakyalegal.com

8. CRIMINAL WRIT PETITION UNDER ARTICLES 226 & 227 OF THE
CONSTITUTION OF INDIA FOR ISSUANCE OF A WRIT IN THE
NATURE OF HABEAS CORPUS AND/OR ANY OTHER APPROPRIATE
WRIT OR ORDER ISSUE A WRIT ORDER OR DIRECTION IN THE
NATURE OF HABEAS CORPUS DIRECTING THE RESPONDENTS TO
IMMEDIATELY SET THE DETENUE AT LIBERTY;
ISSUE A WRIT ORDER OR DIRECTION IN THE NATURE OF
MANDAMUS DIRECTING THE DETENUES NOT TO ARREST THE
DETENUE WITHOUT PRIOR NOTICE ENABLING HIM TO SEEK
APPROPRIATE REMEDIES
DIRECTING THE RESPONDENTS TO PRESENT THE DETENUE
BEFORE THIS HON’BLE COURT AND/OR SET HER FREE;
AND
ISSUE A WRIT, ORDER OR DIRECTION, IN THE NATURE OF
HABEAS CORPUS DIRECTING THE APPROPRIATE OFFICIALS,
INCLUDING DISTRICT MAGISTRATE, FARIDABAD, TO LOCATE
THE DETENUE AND SET HER FREE FROM THE ILLEGAL CUSTODY
;
AND
ISSUE A WRIT IN THE NATURE OF HABEAS CORPUS AND/OR ANY
OTHER APPROPRIATE WRIT OR ORDER TO KINDLY ENSURE THE
RELEASE OF THE DETENUE I.E. THE PRESENT PETITIONER FROM
THE ILLEGAL CUSTODY OF THE RESPONDENT POLICE OR FROM
THE ILLEGAL CUSTODY FROM ANY OTHER PERSON
AND

9. ISSUE AN APPROPRIATE WRIT OR ORDER OR DIRECTION
APPOINTING AN INDEPENDENT COMMISSION/LOCAL
COMMISSIONER(S) UNDER ARTICLE 226 OF THE CONSTITUTION
OF INDIA READ WITH ORDER 26 OF THE CIVIL PROCEDURE CODE,
1908;
AND
AND
IT IS FURTHER PRAYED THAT WRIT PETITION MAY KINDLY BE
ALLOWED.
AND
ANY OTHER SUITABLE WRIT OR DIRECTION WHICH THIS
HON’BLE COURT MAY DEEMS FIT AND PROPER IN THE FACTS
AND CIRCUMSTANCES OF THIS CASE MAY KINDLY BE PASSED.
AND
DISPENSE WITH THE FILING OF CERTIFIED/LEGIBLE
COPIES/FAIR/UNMARKED/PROPER LEFT HAND SPACE/DOUBLE
SPACE/VERNACULAR COPIES OF ANNEXURES;
AND
DISPENSE WITH THE SERVICE OF ADVANCE NOTICES TO THE
RESPONDENTS;
AND
DISPENSE WITH THE VAKALATNAMA AND AFFIDAVITS TO BE
FILED WITH THE PETITION ;

10. INTERIM PRAYER
DURING THE PENDENCY OF THE PRESENT PETITION, THE
REMAND ORDER OF THE DETENUE MAY KINDLY BE STAYED AND
SHE MAY BE ALLOWED TO STAY AT HER HOUSE UNDER POLICE
SUPERVISION

11. RESPECTFULLY SHOWETH:
1. That the Petitioner is a citizen of India and, is entitled to invoke the extra-
ordinary writ jurisdiction of this Hon’ble Court.
2. That the petitioner is an Advocate practicing in the High Court of Punjab and
Haryana.
3. The detenue is a citizen of India and a Advocate, human rights activist and a
Visiting Faculty at the National Law University, Delhi. She is the National
Vice President of the Peoples Union for Civil Liberties. The detenue has been
a member of several committees and has been internationally recognized for
her contributions to the cause of the marginal and downtrodden section of the
society. She is outspoken with regards to her views regarding the actions of
the present government and has articulated the same multiple public and
social media platforms.
4. In what appears to be a witch hunt for unsympathetic political views the
Maharashtra Police Officials came early morning on 28th August 2018 to her
home at Badarpur border in State of Haryana under the jurisdiction of P.S
Surajkund where she is staying with her daughter.
5. That the documents given to the detenue are in Marathi language which is not
known to the Detenue. There is no compliance with the requirements of
Sections 165 and 166 CrPC inasmuch as the documents are in Marathi, a
language which the detenue does not know, thus are unable to read its
contents. Furthermore, neither the grounds nor the purpose of conducting the
search, supposed to be made in writing by the searching officer in terms of
Section 165(1) have been made available to the Detenue and the remaining
occupants of the premises under search, after a copy thereof has been

12. forwarded to the nearest magistrate. A true copy of the documents supplied by
the Respondent police is annexed herewith as Annexure P-1.
6. An FIR No.4/2018 P.S. Vishrambagh Pune has been shown to the detenue
regarding a cultural program held on 31/12/2017, mentioning Sections
153A,505, 117 read with S.34 IPC. The same does not even contain the
detenue’s name, rightly so because she was not even present at this cultural
meeting. The detenue was not even present at the meeting. Furthermore, the
officers conducting the search seem to have, at their own behest, added certain
provisions of the Unlawful Activities Prevention Act, 1967 in the search
warrant. Notably, Sections 13 and 18 of the UAPA have been added. It is
therefore possible that the officers conducting the search have added these
provisions purely for the purpose of preventing any application for
anticipatory bail. Hence, this Writ Petition as any form of detention without
any probable cause or reasonable grounds would amount to illegal/preventive
detention.
7. The search has not yielded any objectionable material, yet the detenue, who
has been detained and kept under preventive custody and has been arrested.
In fact, they have effectively detained her and restricted her movements to the
extent of not allowing her to even use her phone. The occupants of the house
have been forced to switch off their phones, in flagrant violation of
Constitutional, Fundamental and Human Rights, as well as established
principles and protocol of search and seizure.
8. The designation of the officers conduct the search is not being informed to the
detenue.

13. 9. That it is pertinent to mention that another activist, namely Sh. Gautam
Navlakha was illegally detained in New Delhi in the same matter. A habeas
corpus petition was filed on his behalf before the Hon’ble Delhi High Court,
vide WP (Cri) 2559 of 2018 and vide an order dated 28/08/2018 passed by the
Division Bench of Justice S. Murlidhar and Vinod Gupta, the remand order
passed by the jurisdictional court was stayed till tomorrow. A copy of the
petition filed in Delhi is annexed herewith as ANNEXURE P-2. The Hon’ble
Court has allowed Sh. Navlakha to stay at his house till then under house
arrest and will be hearing the petition tomorrow.
10. This is clearly an assault on liberals, liberal thinking and a motivated act.
There is no ground for detention or restriction of movement. The actions are
illegal and unconstitutional. Yet the detenue has extended all possible
cooperation to the searching officers, even in these circumstances.
11. The detenue is entitled to a protection of his life and liberty by an appropriate
Writ/order or direction by this court.
.
GROUNDS
12. That aggrieved by the aforesaid illegal, arbitrary, unconstitutional conduct
and action of the Respondents, the present writ is being preferred before
the Hon'ble court inter-alia, upon the following grounds:
A. BECAUSE the detenue has been illegally detained and not in
accordance with law.

14. B. BECAUSE the actions of the respondents have been arbitrary, illegal
and unjust;
C. BECAUSE the actions of the respondents infringe the detenue’s right
to life under Article 21 of the Constitution of India;
D. BECAUSE the actions of the respondents infringe the detenue’s right
to life under Article 21 of the Constitution of India;
E. BECAUSE grave and manifest injustices have been done to the
petitioner and thus infringe upon his fundamental rights under Article
14 and 21 of the Constitution.
F. The petitioner seeks leave to urge any other Grounds at the time of
hearing of the present matter.
QUESTIONS OF LAW
13. That the following questions of law arise in this writ petition for the kind
consideration of this Hon'ble Court:
I. Whether the actions of the respondents have been arbitrary, illegal and
unjust?
II. Whether the actions of the respondents infringe the detenue’s right to
life under Article 21 of the Constitution of India?
III. Whether grave and manifest injustices have been done to the detenue
and thus infringe upon his fundamental rights under Article 14 and 21
of the Constitution?
IV. Whether the actions of the respondents infringe the detenue’s right to
life under Article 21 of the Constitution of India?

15. V. Whether grave manifest injustices have been done to the petitioner?
14. That the petitioner has been left with no other alternative remedy of
appeal/revision except to approach this Hon’ble Court by way of filing the
present writ petition under Article 226/227 of the Constitution of India.
15. That the petitioner is not in immediate possession of certified/legible
copies/fair/unmarked/proper left hand space/double space copies of
Annexures annexed with the instant petition. However, true typed copies
and clear/legible photocopies of the same are being annexed with the
present petition for the kind consideration of this Hon’ble Court.
Therefore, filing of certified/legible copies of Annexures annexed with the
instant petition may kindly be dispensed with and true typed copies
thereof may kindly be taken on record, in the interest of justice, equity and
fair play.
16. That the petitioner has not filed any such or similar petition in this
Hon’ble Court or in the Hon’ble Supreme Court of India.
PRAYER
The petitioner humbly prays for the following reliefs:
I. Issue a writ order or direction in the nature of Habeas Corpus directing the
respondents to immediately set the detenue at liberty;
II. Issue a writ order or direction in the nature of mandamus directing the
detenues not to arrest the detenue without prior notice enabling him to seek
appropriate remedies
III. ISSUANCE OF A WRIT IN THE NATURE OF HABEAS CORPUS AND/OR ANY OTHER
APPROPRIATE WRIT OR ORDER DIRECTING THE RESPONDENTS TO PRESENT THE
DETENUE BEFORE THIS HON’BLE COURT AND/OR SET THEM FREE;
IV. ISSUE A WRIT, ORDER OR DIRECTION, IN THE NATURE OF HABEAS CORPUS
DIRECTING THE APPROPRIATE OFFICIALS, INCLUDING DISTRICT MAGISTRATE,

16. FARIDABAD, TO LOCATE THE DETENUE AND SET HER FREE FROM THE ILLEGAL
CUSTODY ;
V. ISSUE A WRIT IN THE NATURE OF HABEAS CORPUS AND/OR ANY OTHER
APPROPRIATE WRIT OR ORDER TO KINDLY ENSURE THE RELEASE OF THE
DETENUE I.E. THE PRESENT PETITIONER FROM THE ILLEGAL CUSTODY OF THE
RESPONDENT POLICE OR FROM THE ILLEGAL CUSTODY FROM ANY OTHER
PERSON
VI. ISSUE AN APPROPRIATE WRIT OR ORDER OR DIRECTION APPOINTING AN
INDEPENDENT COMMISSION/LOCAL COMMISSIONER(S) UNDER ARTICLE 226 OF
THE CONSTITUTION OF INDIA READ WITH ORDER 26 OF THE CIVIL PROCEDURE
CODE, 1908;
VII.IT IS FURTHER PRAYED THAT WRIT PETITION MAY KINDLY BE ALLOWED.
VIII. ANY OTHER SUITABLE WRIT OR DIRECTION WHICH THIS HON’BLE COURT MAY
DEEMS FIT AND PROPER IN THE FACTS AND CIRCUMSTANCES OF THIS CASE MAY
KINDLY BE PASSED.
IX. DISPENSE WITH THE FILING OF CERTIFIED/LEGIBLE
COPIES/FAIR/UNMARKED/PROPER LEFT HAND SPACE/DOUBLE SPACE
COPIES/VERNACULAR OF ANNEXURES;
X. DISPENSE WITH THE SERVICE OF ADVANCE NOTICES TO THE RESPONDENTS;
INTERIM PRAYER
DURING THE PENDENCY OF THE PRESENT PETITION, THE REMAND ORDER OF THE
DETENUE MAY KINDLY BE STAYED AND SHE MAY BE ALLOWED TO STAY AT HER
HOUSE UNDER POLICE SUPERVISION

17. CHANDIGARH
DATED: 28/08/2018
(RS BAINS) (ARJUN SHEORAN) (NEHA SONAWANE)
P/867/2011 MAH/5843/2011
ADVOCATES
COUNSEL FOR THE PETITIONER
M:9592771330/9855686442
office@vaakyalegal.com

19. IN THE HIGH COURT FOR THE STATES OF PUNJAB
HARYANA AT CHANDIGARH
CRWP No._______ of 2018
ANKIT GREWAL, ADVOCATE AS A NEXT BEST FRIEND OF ADVOCATE SUDHA
BHARADWAJ (DETENUE)
…Petitioner
Versus
STATE OF HARYANA and Others
…Respondents
AFFIDAVIT OF ANKIT GREWAL, ADVOCATE, aged 28 years, s/o
Jitender Singh, r/o 1474, Sector 20 B, Chandigarh
I, the above named deponents do hereby solemnly affirm and declare as under:-
1. That the deponent is fully conversant with the facts of the case, as such I am competent
to swear this affidavit. That the deponent has read and understood the contents of the
said writ petition alongwith the prayer and the grounds and facts stated in the body of
the petition and deponent believe that all the facts stated in the petition are true &
correct and the petition is being filed in this Hon'ble Court with the knowledge and
belief of the deponent. That the annexures filed alongwith the civil writ petition are
true copies/ true typed/fair copies of their respective originals.
2. That the deponent has not filed any such or similar writ petition either in this Hon'ble
Court or in the Hon'ble Supreme Court of India.
Place: Chandigarh
Dated:
Verification:-
Verified that the contents in para No.1 & 2 is true and correct to my knowledge. No part
of it is false and nothing has been kept concealed therein.
Place: Chandigarh
Dated: