Habeaus Corpus Ram Sita

IN THE HON’BLE HIGH COURT OF TELANGANA AT HYDERABAD
Extraordinary Original Civil Jurisdiction
WRIT PETITION (CIVIL) NO. _________ OF 2019.
Mrs. Sita Sinha …….Petitioner
Versus
State of Telangana …..Respondent
WRIT PETITION FILED UNDER ARTICLE 226 OF THE CONSTITUTION
OF INDIA SEEKING A WRIT OF HABEAUS CORPUS OR ANY OTHER
APPROPRIATE WRIT, ORDER OR DIRECTIONS TO THE
RESPONDENTS TO RELEASE THE HUSBAND OF THE PETITIONER.
To,
THE HON’BLE CHIEF JUSTICE

AND HIS COMPANION JUDGES
OF THE HON’BLE HIGH COURT OF HYDERABAD
THE HUMBLE PETITION OF
THE PETITIONER ABOVE-NAMED
MOST RESPECTFULLY SHOWETH: -
1. That the petitioner is a law-abiding citizen and is a married woman of 29 years living
with her husband Ram.

2. That the petitioner underwent a family planning operation at Shree Sai Ram Nursing
House on 26th June 2019 after having 2 kids aged about 3-4 years.
3. That after the petitioner underwent the family planning operation, she faced some
major difficulties in her body. Soon enough the petitioner along with her husband
went to the nursing house to get examined and the doctor gave some medications to
reduce the pain
4. That even after taking the medications as suggested by the nursing home the
petitioner continued to face the same difficulties as before. So, the petitioner along
with her husband went to the other hospital where they discovered that the family
planning operation was done with negligence and that is why the petitioner was
facing difficulties after her operation.
5. That the petitioner’s husband then wanted to initiate legal proceeding against the said
nursing home for medical negligence towards her wife which is the petitioner.
6. That the nursing home authorities requested petitioner’s husband to not to take the
legal action but when he did not accede to the nursing home’s requests. The
management of nursing home started to threaten the petitioner’s husband.
7. That it may also be mentioned that the owner of the said nursing home is the relative
of Ex Director General of State of Telangana.
8. That using the influence of the said officer the management of the said nursing home
started to threaten the petitioner’s husband to not to initiate any legal proceedings
against them or their nursing home. That this incident occurred on 18.08.2019
9. That 2 days after the incident i.e. on 20.08.2019 some people (around 4 or 5) came to
the petitioner’s residence and fished petitioner’s husband from their residence while
the petitioner was at home and could not do anything.
10. That the whereabouts of the petitioner’s husband are unknown and the identity of the
people who fished him away is also unknown as they kept their identity a secret by
covering their face with masks.
11. That the petitioner and her relatives tried to trace the whereabouts of the petitioner’s
husband in all the almost all the nearby police stations and other possible places
where he could be found but all of that was of no avail.
12. That the police officer has not made any investigations about this matter despite of
being complained several times.
GROUNDS
A. That the fundamental right of a citizen for free movement is also a
fundamental right, enshrined under the Constitution of India and by illegally
detaining petitioner’s husband the above said right of petitioner’s husband is
being infringed.
B. That right to personal liberty is also a fundamental right enshrined in the
Constitution of India. It is to be co-related that personal liberty must have a
cogent and harmonious understanding in respect of the freedom to move
anywhere across the country. And in this case the above said right to
petitioner’s husband is infringed.
C. For that the inaction on the part of police authorities on the report of the
petitioner is per se illegal.

13. That the petitioner has not filed any other petition seeking relief similar to as is prayed for
in the present petitioner. No other equally efficacious remedy, other than preferring the
present petition, is available to the petitioner.
PRAYER
In the aforesaid premise, it is most respectfully and humbly prayed that this
Hon’ble Court may graciously be pleased to:
a. Issue direction in the nature of writ of Habeaus Corpus to Respondent for
the immediate production of the petitioner’s husband, aged 40 years before this
Hon’ble Court.
b. Direct the authorities to take appropriate action against respondents for
their illegal act of detaining the petitioner’s husband and not permitting them to
come back.
c. Pass any other order(s) as this hon’ble Court deem fit and proper in the
facts and circumstances of the present petition.
PETITIONER IN PERSON
DATED:
TELANGANA
THROUGH
VAISHNAVI JAISWAL (ADVOCATE)
OFFICE: - 123, MANAS COMPLEX, HYDERABAD
TELANGANA
MOB: 7830433917

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IN THE HON’BLE HIGH COURT OF TELANGANA AT HYDERABAD

Extraordinary Original Civil Jurisdiction

WRIT PETITION (CIVIL) NO. _________ OF 2019.

Mrs. Sita Sinha …….Petitioner

State of Telangana …..Respondent

WRIT PETITION FILED UNDER ARTICLE 226 OF THE CONSTITUTION

OF INDIA SEEKING A WRIT OF HABEAUS CORPUS OR ANY OTHER

APPROPRIATE WRIT, ORDER OR DIRECTIONS TO THE

RESPONDENTS TO RELEASE THE HUSBAND OF THE PETITIONER.

THE HON’BLE CHIEF JUSTICE

with her husband Ram.

reduce the pain

facing difficulties after her operation.

management of nursing home started to threaten the petitioner’s husband.

of Ex Director General of State of Telangana.

the petitioner was at home and could not do anything.

covering their face with masks.

where he could be found but all of that was of no avail.

being complained several times.

A. That the fundamental right of a citizen for free movement is also a

fundamental right, enshrined under the Constitution of India and by illegally

detaining petitioner’s husband the above said right of petitioner’s husband is

B. That right to personal liberty is also a fundamental right enshrined in the

Constitution of India. It is to be co-related that personal liberty must have a

cogent and harmonious understanding in respect of the freedom to move

petitioner’s husband is infringed.

petitioner is per se illegal.

present petition, is available to the petitioner.

Hon’ble Court may graciously be pleased to:

a. Issue direction in the nature of writ of Habeaus Corpus to Respondent for

b. Direct the authorities to take appropriate action against respondents for

facts and circumstances of the present petition.

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