Wp vernon gonsalves and anr vs state of maharashtra & ors.

1. IN THE HIGH COURT OF JUDICATURE BOMBAY
CRIMINAL APPELLATE JURISDICTION
CRIMINAL WRIT PETITION NO._____ OF 2020
Vernon Gonsalves & Anr. …Petitioners
v/s.
The State of Maharashtra & Ors. ...Respondents
I N D E X
Sr.No. Exhibits Particulars Page No.
1. Synopsis. A-B
2. Memo of Petition. 1-19
“A” Copy of FIR no. 4 of 2018 dated 08.01.2018. 20-23
3. “B” Copy of Case details of the FIR filed by the
NIA.
24-26
4. “C” Copies Of emails written by the relatives of
the Petitioners to the Respondent No.3.
27-28
5. Vakalatnama 29-32

2. A
IN THE HIGH COURT OF JUDICATURE BOMBAY
CRIMINAL APPELLATE JURISDICTION
CRIMINAL WRIT PETITION NO._____ OF 2020
Vernon Gonsalves & Anr. …Petitioners
v/s.
The State of Maharashtra & Ors. ...Respondents
The Present Writ Petition is being filed on behalf of the Petitioners who are
presently lodged at Taloja Central Prison. An inmate at the prison, with whom the
Petitioners were in close contact with has tested positive and thus there is an
urgent need to conduct swab tests for the Petitioners and make arrangements for
them accordingly.
S Y N O P S I S
Sr.no. Date Events
1. 31.12.2017 Elgaar Parishad was organized by retired Judges Hon’ble
Justice PB Sawant and Hon’ble Justice Kolse-Patil.
2. 08.01.2018 Tushar Damgude, the present complainant files FIR
4/2018, Vishrambagh P.S. u/s 153A, 505(1)(B), 117, 34
IPC.
3. 28.08.2018 The house of Petitioner No.1 was raided. The house of
the Petitioner No.2 was attempted to be raided by the
Maharashtra State Police.
4. 25.10.2018 The Petitioner No.1 was taken in Police Custody by the
State Police. Petitioner No.1 was lodged at Taloja Central
Prison.
5. 14.04.2020 The Petitioner No.2 was lodged at Taloja Central Prison.
6. 24.10.2020 Investigation was handed over to NIA.
7. 02.06.2020 Mr.Varavara Rao was shifted to JJ Hospital. Thereafter
he was admitted to the Jail Hospital.
8. 28.06.2020 Petitioner No.1 was assigned to look after Mr.Rao and
assist him in the day to day activities.
9. 13.07.2020 Mr.Rao was again admitted to JJ Hospital.

3. B
10. 16.07.2020 Mr.Rao tested positive for Covid-19.
11. The Petitioner No.2 has also been in close contact with
Mr.Rao as he was assigned the duty to take care of him at
Taloja Hospital.
Hence the Petitioners prefers the present petition.
POINTS TO BE URGED
As made out in the Memo of Petition.
ACTS AND BOOKS TO BE REFERRED
1. Indian Penal Code.
2. Code of Criminal Procedure.
3. Indian Evidence Act.
4. Unlawful Activities (Prevention) Act, 1967 amended 2008.
5. Constitution of India, 1950
AUTHORITIES TO BE CITED
Nil at present.
Advocate for Petitioner

4. 1
IN THE HIGH COURT OF JUDICATURE AT BOMABY
CRIMINAL APPELLATE JURISDICTION
CRIMINAL WRIT PETITION NO. OF 2020
In the matter of article 226
of the Constitution of India,
1950 and section 482 of the
Criminal Procedure Code,
1973;
AND
In the matter of article 14,
19 & 21 of the Constitution
of India, 1950;
AND
In the matter of the safety
of the Petitioners who are
presently lodged at Taloja
Central Prison and a fellow
inmate/co-accused having
tested positive for Covid-
19;
AND
In the matter that, both the
Petitioners are high risk
persons and have come in

5. 2
close contact with the
person having tested
positive for Covid-19;
AND
In the matter of offences
registered under sections
153, 505(1(b), 117 & 34 of
Indian Penal Code 1860,
Sections 13, 16, 18, 18B,
20 & 39 of Unlawful
Activities Prevention Act,
2012;
AND
In the matter of offence
registered as Case RC-
01/2020/NIA/Mum dated
24.01.2020 registered at
NIA Police Station,
Mumbai.
1. Vernon Stanislaus Gonsalves )
Aged 61 years, having address at )
C-3, New Prem Vasundhara, off )
Mahakali Caves Road, Andheri East, )
Mumbai 400093 )

6. 3
Presently lodged at Taloja Central Prison )
2. Anand Teltumbde )
Occupation- Senior Professor )
Chair, Big Data Analytics, )
Goa Institute of Management )
Aged 68 Years )
Presently lodged at Taloja Central Prison )…Petitioners
Versus
1. State of Maharashtra )
Through its Secretary for )
Ministry of Home Affairs )
Maharashtra Mumbai )
Through the Learned Public Prosecutor )
High Court at Bombay )
2. National Investigation Agency )
Through its Deputy Inspector General )
Having office at- 7th Floor, )
Cumballa Hill, MTNL Telephone )
Exchange Building, Peddar Road, )
Mumbai, Maharashtra-400026 )
3. Taloja Central Prison )
Through the Superintendent )
Inampuri, Taloja, )
Navi Mumbai, Maharashtra 410208 )…Respondents

7. 4
TO
THE HON’BLE CHIEF JUSTICE AND
THE OTHER HON’BLE PUISNE JUDGES
OF THIS HON’BLE COURT OF
JUDICATURE AT BOMBAY
THIS HUMBLE PETITION OF
THE PETITIONER
ABOVENAMED
MOST RESPECTFULLY SHEWETH:
PARTIES
1. The Petitioners are both intellectuals, writers, authors and
persons highly reputed in the society. The Petitioners have
been falsely accused and have been arraigned as accused in
Case RC-01/2020/NIA/Mum dated 24.01.2020 registered at
NIA Police Station, Mumbai under sections 153, 505(1(b), 117
& 34 of Indian Penal Code 1860, Sections 13, 16, 18, 18B, 20
& 39 of Unlawful Activities Prevention Act, 2012. The
Petitioners who are both Senior Citizens are presently lodged
at Taloja Central Prison.
2. The Respondent No.1 is the State of Maharashtra through
its Ministry of Home Affairs. The Respondent No.1 is the body
responsible for the overall administration of law and order in
the State of Maharashtra.
3. The Respondent No.2 is the National Investigation Agency
through the Deputy Inspector General. The Respondent No.2 is
the Police Station where the impugned First Information

8. 5
Report (hereinafter referred to as ‘FIR’ for the sake of brevity
and convenience) dated 24.01.2020 in Case RC-
01/2020/NIA/Mum has been registered.
4. The Respondent No.3 is the Superintendent, Taloja Central
Prison, where the Petitioners are lodged presently.
All the parties are amenable to the Writ Jurisdiction of this
Hon’ble High Court.
ISSUE
5. The Petitioners are constrained to move this Hon’ble High
Court under Section 482 of the Code of Criminal Procedure,
1973 (hereinafter referred to as ‘CrPC’ for the sake of brevity
and convenience). The Petitioners are filing the present
Petition as, the Petitioners who are presently lodged at Taloja
Central Prison are in grave risk and danger of their lives. The
Petitioners are under an imminent threat of contracting Covid
19 virus or have already contacted the same as a fellow co-
accused/inmate Mr.Varravara Rao has yesterday i.e. on
16.07.2020 tested positive for Covid-19 after battling for his
life for several weeks/month. The Petitioner No.1 was assigned
the duty of being the aid of Mr.Varravara Rao. The Petitioner
No.1 was helping Mr.Varravarao Rao with his day to day
activities for the past three to four weeks. The Petitioner No.2
was lodged at the same hospital.
6. The Petitioners state that, the Petitioners are both high risk
category candidates as both the Petitioners are senior citizens
with under lying health ailments.

10. 7
online opinion platform of the well-known and established
India Today Group, which has contracted them to write on the
above-mentioned topics. He has also contributed to other
reputed journals and outlets like the Hindu Business Line,
Rediff, Scroll, The Wire and others. There are over fifty essays
by the Petitioner which are currently available online. Two of
these pieces entitled “Why the letter about a 'Rajiv Gandhi-
type' assassination plot to kill Modi is fake” published on
11.06.2018 and available at
https://www.dailyo.in/politics/bhima-koregaon-probe-death-
threats-to-pm-fake-political-narrative-sinister-plots-by-
maoists/story/1/24769.html and “A propaganda tool called
#UrbanNaxal” published on 13.07.2018 and available at
http://www.rediff.com/news/column/a-propaganda-tool-called-
urbannaxal/20180713.htm have been critical of the
investigation in the present case done by the Respondent State.
10. The Petitioner No.1 is a gold medalist from the Bombay
University in Commerce and has been an accounts officer at
Siemens, and lecturer of Business Organisation at various
reputed Mumbai colleges. His translation of Annabhau Sathe’s
“Gold from the Grave” from Marathi to English is published in
David Davidar’s “A Clutch of Indian Masterpieces”. The
Petitioner has at various times, on invitation, delivered lectures
at reputed Universities and institutions such as Delhi
University Dept of Political Science, Jawaharlal Nehru

11. 8
University, Dept. of International Relations, LLM (Access to
Justice) course at Tata Institute of Social Sciences.
11. The Petitioner No.2 was born in a family of landless
laborers’ in Vidarbha region of Maharashtra. He was active in
student politics and held several elected offices. On the
academic front, the Petitioner has a brilliant record. The
Petitioner holds the qualification of BE in Mechanical
Engineering from VNIT, Nagpur; MBA from Indian Institute
of Management, Ahmedabad; Doctorate in Management
focusing on a pioneering area of cybernetic modeling for
public systems. The Petitioner is also conferred upon D Litt.
(honouris causa) by Karnataka State University, Mysore.
12. The Petitioner No.2 has reached the zenith of the corporate
world as the Executive Director of Bharat Petroleum and the
Managing Director & CEO of Petronet India Limited up to
2010. After his corporate stint, he was invited by the
prestigious Indian Institute of Technology, Kharagpur as
Professor of Management, where he served up to June 2016.
The Petitioner No.2 is widely respected and well-known in his
professional fields of Technology and Management in which
he has published many research papers in international
journals. He has been invitee speaker in many international
conferences over last four decades.
The Petitioner No.2 is widely respected and well-known for his
original insights on various contemporary social, economic and
political issues in academic circles all over the world. He is
regularly invited by number of universities in the US, Canada

12. 9
and Europe for giving lectures over the last several years. The
Petitioner No.2 has written extensively in all leading
newspapers, magazines, organizational pamphlets and booklets
as an aid to the struggling masses, and lectured widely in India.
The Petitioner has authored 26 books and has pioneered a
theoretical critique of neoliberal globalization vis-à-vis dalits
and other oppressed masses. The Petitioner was also associated
with various people’s struggle- significantly the struggles of
construction workers and casual labour in West Bengal in late
1970s and thereafter in Mumbai with the struggles of textile
workers’, slum dwellers’ and contract labours’ in 1980s. The
Petitioner is associated with the Committee for Protection of
Democratic Rights (CPDR), one of the earliest civil rights
organizations in the country, of which he is the General
Secretary. The Petitioner is also associated with the All India
Forum of Rights to Education (AIFRE), which is a movement
for common school system, as a member of Presidium. The
said Petitioner had participated in numerous fact finding teams
over the last three decades that have produced widely
acclaimed reports on issues such as tsunami rehabilitation
efforts, caste atrocities, communal conflagration etc. The
Petitioner No.2 for several years has worked on editorial
boards of Samaj Prabodhan Patrika, Vidrohi and many other
progressive publications. He is a regular contributor to India’s
most respected social science journal, Economic and Political
Weekly, wherein he writes a monthly column ‘Margin Speak’
and also contributes to other progressive journals such as

13. 10
Mainstream, Frontier, Seminar. Some of the Petitioner’s recent
books are Radical in Ambedkar (Ed) (Penguin Random House,
2018), Republic of Caste (Navayana, New Delhi 2018), Dalits:
Past, Present and Future (Rutledge, London 2016) and
Persistence of Caste (Zed book, London, 2009). The Petitioner
No.2 has received prestigious awards and recognition from
reputed public institution/ foundations all across the country,
the notable being Vikas Ratna Award, Ambedkar Centenary
Award (UK), Lohia Centenary Award, Maharashtra Foundation
Awards and others. The Petitioner No.2 was the President of
the last Vichar Vedh Sammelan, a prestigious forum for
progressive intellectuals in Maharashtra in 2007.
13. The Petitioners state and submit that, the facts
relevant/story of the prosecution is as under-
i.On 31.12.2017 an Elgaar Parishad was organized by two
retired Judges - former Supreme Court Judge, Hon’ble Justice
PB Sawant and Hon’ble Justice Kolse Patil, retired Bombay
High Court Judge. The programme concluded with a pledge by
participants to uphold the Constitution of India and protect
democracy by ensuring that the “New Peshwa” i.e. present
ruling establishment government, does not return to power.
Eight days after the Elgaar Parishad, on 08.01.2018, Tushar
Damgude, the present complainant lodged FIR 4/2018 P.S.
Vishrambagh, Pune u/s 153A, 505(1)(B), 117, 34 IPC. The
Complaint and F.I.R. mentions the name of six persons. There
was no mention of the names of the Petitioners in the said FIR.

14. 11
Their names were added later as an afterthought to merely
target the Petitioners. A copy of the said F.I.R. is annexed
herein as Exhibit A.
ii.The Petitioner No.1’s house was raided on 28.08.2018 and he
was arrested the same day. However, Writ Petition No. 260 of
2018 filed in Supreme Court by certain prominent persons
against the then arrested 5 persons. The Hon’ble Supreme
Court ordered that the then arrested 5 persons, including the
Petitioner No.1 be kept under house arrest.
iii.The Supreme Court gave its final judgment in the above case
vide judgment dated 28.09.2018 and while refusing to transfer
investigation extended the house arrest for 4 weeks to enable
the arrested accused to adopt appropriate remedies.
iv.The Petitioner No.1 filed a bail application on 5.10.2018
before the Hon’ble Special Court at Pune. The same came to
be rejected vide order dated _____. Subsequently, the
Petitioner filed Bail Application No.3007 of 2018 before this
Hon’ble High Court, which came to be rejected vide order
dated 15.10.2019. The Petitioner No.1 was taken in Police
Custody on 25.10.2018.
v.On 28.08.2018, the Petitioner No.2’s house was attempted to
be raided when the Petitioner and his wife were not present at
home. The Petitioner No.2 was not arrested and was under
protection by several orders of this Hon’ble Court and the
Apex Court and came to be arrested by the Respondent No.2
only on 14.04.2020.

15. 12
vi.The Petitioner No.2 had filed a Writ Petition for quashing of
the said FIR No.4 of 2018 before this Hon’ble Court vide
WP.No.4596 of 2018. The same was rejected vide order dated
21.12.2018. The Petitioner No.2 challenged the same vide an
SLP before the Apex Court. The Apex Court was pleased to
dismiss the said SLP but extended the protection against arrest
for a period of four weeks during which the Petitioner could
apply inter alia for regular/pre- arrest bail from Competent
Authority.
vii.The Petitioner No.2 approached the Sessions Court at Pune
vide an Anticipatory Bail Application, however, the same was
rejected vide order dated 01.02.2019. Subsequently, the
Petitioner No.2 filed Anticipatory Bail Application No.314 of
2019 before the Hon’ble Bombay High Court. The Petitioner
was granted interim protection from arrest vide order dated
21.02.2019. The same was extended by further orders of this
Hon’ble High Court. The ABA No.314 of 2019 was dismissed
by this Hon’ble Court vide order dated 14.02.2020.
Subsequently, the Petitioner No.2 approached the Hon’ble
Supreme Court vide a SLP, the same came to be dismissed vide
order dated ___. The Petitioner No.2 was arrested on
14.04.2020 by the Respondent No.2.
The Petitioners seek liberty to refer and rely upon the
proceedings and the judgments mentioned above as and when
produced before this Hon’ble High Court.
14. The Petitioners state and submit that, the investigation of
the said case was handed over to the Respondent No.2 and the

16. 13
Respondent No.2 registered the FIR being Case RC-
01/2020/NIA/Mum ON 24.01.2020. Till date no Charge Sheet
has been filed by the Respondent No.2. Copy of the same has
been marked and annexed hereto as Exhibit B.
15. The Petitioners state and submit that, one of the co-
accused in the said matter and an inmate with the Petitioners,
Mr.Varavara Rao has been tested positive for COivd-19 on
16.07.2020. The Petitioner No.1 was assigned to aid and assist
Mr.Varavara Rao with his day to day activities since
28.06.2020. Mr.Varavara Rao was shifted to J.J.Hospital
because of his deteriorating health condition, he was
discharged on 02.06.2020 and was later shifted to the Jail
Hospital and further shifted to J.J.Hospital again on
13.07.2020. While Mr.Varavara Rao was in the Jail Hospital,
i.e. till 13.7.2020 the Petitioner No.2 was also lodged at the
same hospital to assist Mr. Rao and as such was in proximate
and continuous physical contact with Mr. Rao.
16. The Petitioner No.1 has been suffering from hypertension,
blood pressure and bleeding piles. The Petitioner has been on
medications for the same. The Petitioner is a senior citizen.
The Petitioner was in close contact with Mr.Varravara Rao till
13.07.2020. Thus the Petitioner No.1 is at a high risk of
contracting Covid-19. The Petitioner No.2 has a host of
chronic health problems ranging from (1) chronic bronchitis
asthma, (2)chronic cervical spondylitis, (3) supraspinatus
tendinosis and (4) postrtomegaly. Particularly because of the
first issue of asthma being on the inhaler pump and oral drugs,

17. 14
the Petitioner No.2 is particularly vulnerable to Covid 19. The
Petitioner No.2 is lodged in the Jail Hospital where
Mr.Varravara Rao was also lodged till 13.07.2020. Thus he
was also in close and proximate contact with Mr. Rao. Both the
Petitioners are high risk contacts.
17. Thus the Petitioners state and submit that, both the
Petitioners have been in close contact with Mr.Varravara Rao,
who has tested positive for Covid-19 on 16.07.2020. The
investigation has been going for more than two years now.
Both the Petitioners have fully cooperated with the
investigation. Both the Petitioners are senior citizens with
several underlying health issues and have come in contact with
a Covi-10 positive patient. Thus the Petitioners ought to be
tested for Covid-19 on an immediate basis, they be isolated
and kept in a place where social distancing is possible as they
continue to be at constant risk at the prison. Thus the
Petitioners have been constrained to approach this Hon’ble
High Court. The relatives of the Petitioners have already
written e mails to the Jail Authority asking for immediate
testing of the Petitioners but there is no response. Besides,
looking at the conduct of the Respondents in the past they are
likely to dilly dally over this unless there is a direction from
the Court. Even Mr. Vara Vara Rao was shifted to JJ Hospital
and tested only after his relatives made a hue and cry about his
health condition. Copies of the emails have been marked and
annexed herewith collectively as Exhibit C. That the Indian
Council for Medical Research guidelines ought to be followed

18. 15
while dealing with the present case. The Petitioners crave leave
to refer and rely upon the same as and when produced by this
Hon’ble Court.
GROUNDS
18. Under such circumstances the Petitioners are filing the
present Petition on the following amongst other grounds which
are without prejudice to one another:
A. That, both the Petitioners, who are presently lodges at
Taloja Central Prison, have come in close contact with
Mr.Varravara Rao who has tested positive for Covid-19 on
16.07.2020.
B. That, the Petitioner No.1 is suffering from hypertension,
high blood pressure and bleeding piles. The Petitioner No.1 is
on medication for the same and is a senior citizen
C. That, the Petitioner No.2 has a host of chronic health
problems ranging from (1) chronic bronchitis asthma,
(2)chronic cervical spondylitis, (3) supraspinatus tendinosis
and (4) postrtomegaly. Particularly because of the first issue of
asthma being on the inhaler pump and oral drugs, the
Petitioner No.2 is particularly vulnerable to Covid 19. The
Petitioner No.2 is also a senior citizen.
D. That, the investigation in the said case has been ongoing
for more than two years now.
E. That, the Petitioners have fully cooperated with the
investigation till date.

19. 16
F. That, till date no charge sheet has been filed by the
Respondent No.2.
G. That, the Petitioners continue to be at risk due to their
health condition.
H. That, the Petitioners could pose a grave risk to the other
inmates as well.
I. That, keeping the Petitioners, who are at a high risk of
contracting Covid-19 and posing a risk to the other inmates,
without sufficient cause, is grave and absolute violation of
their rights under articles 4, 19 and 21 of the Constitution of
India, 1950.
19. That the Petitioners have not filed any such or similar
petition earlier before this Hon’ble High Court or Hon’ble
Supreme Court of India.
20. The Writ Petition is filed bonafide and in the interest of
justice.
21. The Petitioners states that the Respondents also have their
offices and Mumbai, therefore, the cause of action has arisen
within the Criminal Appellate Side jurisdiction of this Hon’ble
Court; hence, it can admit the petition and hear it.
22. The Petitioners states that he has no other alternative
efficacious remedy but to approach this Hon’ble Court and the
reliefs prayed for herein, if granted, shall be complete.
23. The Petitioners will rely on documents a list whereof is
annexed hereto.
24. There is no delay or laches in filing this petition.

20. 17
25. That, the verification of the present Petition may be
dispensed with as the Applicants are presently lodged at Taloja
Central Prison.
26. The Petitioner has affixed the required court fees of Rs.
______/- to this Petition.
27. No caveat with regard to the subject matter of this petition
has been received by the Petitioners from the Respondents till
date.
PRAYER:
28. The Petitioners therefore prays as follows:
a. That this Hon’ble Court be pleased to issue Writ of
Mandamus or any other direction or order in nature of
Mandamus or any other appropriate writ, direction or order, to
the Respondent No.1 to conduct a Covid-19 swab test for the
Petitioners and keep them in isolation in the jail hospital where
physical distancing is possible and provide all facilities and
take all such steps as may be required depending on the
outcome of the test.
b. Pending hearing and final disposal of the present Petition,
this Hon’ble Court be pleased to issue Writ of Mandamus or
any other direction or order in nature of Mandamus or any
other appropriate writ, direction or order, to the Respondent
No.1 to conduct a Covid-19 swab test for the Petitioners and

21. 18
keep them in isolation in the jail hospital where physical
distancing is possible and provide all facilities and take all
such steps as may be required depending on the outcome of the
test.
c. For ad-interim reliefs in terms of prayer clause (b) above.
d. Any other just and proper order may be pleased be given in
favor of the Petitioner in the interest of justice.
(Advocate for Petitioners) Petitioner No.1
Petitioner No.2

22. 19
VERIFICATION
I, Anand Teltumbde, age- 68 years, Residing at Flat No. 2102,
Goa Institute of Management, Sanquelim, Goa-403505, the
Petitioner No.2 above named do hereby solemnly declare that
what is stated in para no.1 to 16 of the Petition is true to my
knowledge and belief, and what is stated in the remaining
paras is based on information and belief and I believe the
same to be true.
Solemnly affirmed at Mumbai )
On this 17TH
day of July 2020 )
Identified by me Before me
(Advocate for Petitioners) Petitioner No.2

23. 29
IN THE HIGH COURT OF JUDICATURE AT BOMABY
CRIMINAL APPELLATE JURISDICTION
CRIMINAL WRIT PETITION NO. OF 2020
In the matter of article 226 of the
Constitution of India, 1950 and
section 482 of the Criminal
Procedure Code, 1973;
AND
In the matter of article 14, 19 & 21
of the Constitution of India, 1950;
AND
In the matter of the safety of the
Petitioners who are presently lodged
at Taloja Central Prison and a fellow
inmate/co-accused having tested
positive for Covid-19;
AND
In the matter that, both the
Petitioners are high risk persons and
have come in close contact with the
person having tested positive for
Covid-19;
AND
In the matter of offences registered
under sections 153, 505(1(b), 117 &
34 of Indian Penal Code 1860,
Sections 13, 16, 18, 18B, 20 & 39 of

24. 30
Unlawful Activities Prevention Act,
2012;
AND
In the matter of offence registered as
Case RC-01/2020/NIA/Mum dated
24.01.2020 registered at NIA Police
Station, Mumbai.
1. Vernon Stanislaus Gonsalves )
Aged 61 years, having address at )
C-3, New Prem Vasundhara, off )
Mahakali Caves Road, Andheri East, )
Mumbai 400093 )
Presently lodged at Taloja Central Prison )
2. Anand Teltumbde )
Occupation- Senior Professor )
Chair, Big Data Analytics, )
Goa Institute of Management )
Aged 68 Years )
Presently lodged at Taloja Central Prison )…Petitioners
Versus
1. State of Maharashtra )
Through its Secretary for )
Ministry of Home Affairs )
Maharashtra Mumbai )
Through the Learned Public Prosecutor )
High Court at Bombay )

25. 31
2. National Investigation Agency )
Through its Deputy Inspector General )
Having office at- 7th Floor, )
Cumballa Hill, MTNL Telephone )
Exchange Building, Peddar Road, )
Mumbai, Maharashtra-400026 )
3. Taloja Central Prison )
Through the Superintendent )
Inampuri, Taloja, )
Navi Mumbai, Maharashtra 410208 )…Respondents
To,
The Registrar
High Court,
Criminal Appellate Side
Mumbai
Sir,
I the Petitioner No.2 above named, presently under house arrest, do
hereby appoint DEVYANI H. KULKARNI Advocate, High Court, to
act, appear and plead on our behalf in the above matter.
IN WITNESS WHEREOF WE HAVE SET AND SUBSCRIBED MY
HANDS TO THIS WRITING on this 17TH
day of July, 2020 at
Mumbai.

26. 32
Accepted
DEVYANI H. KULKARNI (I-15449) Petitioner No.1
Advocate for the Petitioners
4th
Floor,
Hind Rajasthan Chambers,
6 Oak Lane (Allana Marg),
Next to Allana House,Fort,
Mumbai- 400 001.
Ph.No.-22625021/+91-9767757637
Email Id- devyanik13@gmail.com
Petitioner No.2