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Petition to release the JDR from Jail

IN THE COURT OF THE CITY CIVIL JUDGE, NEW DELHI
I.A. No. 23/2025 in O.S. No. 1024/2024

Mr. Arjun Kumar,
S/o Ramesh Kumar,
Hindu, aged about 35 years,
Businessman,
Residing at 123, Green Park, New Delhi – 110016.

…Petitioner / Judgment Debtor (JDR)

Vs.

Ms. Neha Sharma,
D/o Mahesh Sharma,
Hindu, aged about 32 years,
Businesswoman,
Residing at 45, Rose Enclave, New Delhi – 110014.

…Respondent / Decree Holder (DHR)

Petition filed on behalf of the petitioner/JDR under Sec. 59(3) and 151 of CPC

The petitioner most respectfully submits as follows:

For the reasons stated in the accompanying affidavit, the petitioner prays that this Hon’ble Court may be pleased to issue necessary directions to the Superintendent, Tihar Jail, New Delhi, to release the petitioner forthwith on medical and compassionate grounds, and to pass such other orders as this Hon’ble Court may deem fit and proper under the circumstances and in the interest of justice.

Place: New Delhi
Date: 10.06.2025

Advocate for the Petitioner/JDR
(Signature)

IN THE COURT OF THE CITY CIVIL JUDGE, NEW DELHI
I.A. No. 23/2025 in O.S. No. 1024/2024

Ms. Neha Sharma

…Decree Holder

Vs.

Mr. Arjun Kumar

…Judgment Debtor

Affidavit

I, Mrs. Sunita Kumar, W/o Arjun Kumar, Hindu, aged about 33 years, Homemaker, residing at 123, Green Park, New Delhi – 110016, do hereby solemnly affirm and state as follows:

  1. I am a third party in the Execution Petition proceedings, and the Judgment Debtor, Mr. Arjun Kumar, is my husband. I am fully acquainted with the facts of the case.
  2. Pursuant to the orders of this Hon’ble Court, my husband was arrested and sent to civil prison on 25.05.2025 and is presently lodged in Tihar Jail, New Delhi.
  3. Upon visiting him recently, I found that he is in a deteriorating state of health. He is suffering from acute hypertension and early-stage kidney failure, and requires urgent medical attention and consistent care, which cannot be sufficiently provided within the jail premises.
  4. Therefore, I respectfully pray that this Hon’ble Court may be pleased to release the Judgment Debtor from custody on humanitarian and medical grounds, without prejudice to the right of the Decree Holder to apply for his re-arrest upon recovery.

Failing which, the Judgment Debtor’s life and well-being may be irreparably harmed, and I would suffer irreparable hardship and loss.

Deponent
(Signature of Sunita Kumar)

Solemnly affirmed and signed before me after the contents were read over and explained in Telugu and admitted to be true and correct by the deponent on this the 10th day of June, 2025.

Place: New Delhi
Date: 10.06.2025

Advocate