ANALYSING LAW OF DIPLOMATIC RELATIONS AND IMMUNITIESFEROZ PATHAN - The Daily Guardian
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ANALYSING LAW OF DIPLOMATIC RELATIONS AND IMMUNITIESFEROZ PATHAN

Feroz Pathan

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Law of diplomatic relations is of ancient origin. It derives strength from the concept of ‘Sovereign Equality’ and ‘Sovereign Immunity.’ International relations of different nation states in pursuit of their national interest and goals have witnessed a sea change. Nation-states today interact not only with other states but also with international system, organizations, social groups and so on.

Many principles of diplomatic community have been for a long considered to be customary law. Diplomats formally represent the sovereign and hence the receiving state grants certain privileges and immunities to them so as to ensure that they carry out their duties effectively. These are normally provided on a reciprocal basis.

These diplomatic privileges and immunities were previously absolute. Now it’s a matter of functional necessity. They are restricted only to the official acts of diplomats now. Traditionally, diplomats enjoyed these immunities and privileges out of the theory of ‘extra-territoriality’ as diplomats were deemed to be outside jurisdiction of state.

Today, however, they enjoy it out of the special functions that they perform. The Supreme Court of Australia has also ruled that diplomatic agents enjoy certain immunities and privileges because of special functions that they perform.

Originally they were granted these immunities on a bilateral and ad hoc basis. It however paved way for misunderstandings, hostility, and often conflict between nation-states. The weaker states were vulnerable in this deal.

The United Nations thus codified these rules on diplomatic relations through ‘Vienna Convention on Diplomatic Relations, 1961’ which was adopted on 18th April,1961. It was entered into force on 24th April, 1964.

The codification of these rules into a law (convention) that has been ratified by 192 states as of October, 2018 facilitated efficient conduct and regulation of international relations.

The functions and interactions of states on international level are of varied nature. Consuls who are representatives of states also discharge a vital function of looking after the commerce and trade interests of their countries.

In view of this important function rendered by them, a convention entitled Vienna Convention on Consular Relations was adopted on 24th April, 1963. It came into force on 19th March,1967. It has been ratified by 179 countries as of May, 2016.

Those issues which are not explicitly regulated by the above two conventions continue to be governed by the rules of customary international law. ICJ has time and again reiterated that these conventions continue to apply notwithstanding the nature of relations shared by states and even during state of armed conflict between the states concerned. (Democratic Republic of Congo v.Uganda, ICJ Reports,2005 pp.168,274)

It’s pertinent to note that these privileges and immunities have been often in the eye of storm due to its abuse, misuse and overuse by diplomatic agents of state. Let’s peep into some of the important provisions and case laws of Vienna Convention on Diplomatic Relations(VCDR), 1961 –

It’s not obligatory for nation-states to establish diplomatic relations under any international law. Such relations are carved out of reciprocity and mutual consent between two or more states. Art 2 of Vienna Convention expressly states that the establishment of diplomatic relations between states and of permanent diplomatic missions takes place by mutual consent.

The consent of receiving state for sending the mission and for the person as head of the mission must be taken by the sending state. Besides, receiving state is not obliged to give reasons to the sending state for refusal of consent as provided in Art 4 of the convention.

The receiving state even holds discretion of declaring any member of diplomatic mission as ‘persona non grata’ at any time. They may declare him as unrecognized and unwelcomed as dignitary. In such a case, the sending state shall either recall the person concerned or terminate his functions with the mission as provided in Art 9 of the convention.

Some of the main functions of diplomatic mission as enumerated in Art 3 are representing the sending state, protecting the interest of sending state and its nationals, negotiating with the Government of the receiving state, reporting the conditions and developments in receiving state , promoting friendly relations between receiving state and sending state, et al.

Its obligation upon all the persons enjoying diplomatic privileges and immunities not to interfere in internal affairs of the receiving state and to respect its laws and regulations as enumerated in section 41.

The heads of the mission are classified into three classes as highlighted in Art 14 of the convention namely – 1.ambassadors or nuncios, envoys 2. Envoys, ministers, and internuncios and 3. Charges d’ affaires.

The premises of the mission shall be inviolable as enumerated in Article 22. The agents of receiving states may not enter them, except with the consent of the head of the mission. This is an ‘absolute rule’ as held in Third Avenue Associates v. Permanent Mission of the Republic of Zaire to the UN 988 F.2d 295(1993); 99 ILR p.194

This inviolability extends even to members of diplomatic mission (Art 29), property ,furnishings, premises, means of transport, and archives which are immune from search, requisition, attachment or execution. This inviolability must be respected by receiving state. Art 23 provides for general exception from taxation in respect of mission premises.

THE IRANIAN HOSTAGES CASE (USA V. IRAN), ICJ REPORTS, 1980

The embassy of USA in Tehran and all diplomatic personnel were held hostages in 1979 by militants. The assault continued for three hours, Iranian Government made no attempts to rescue the hostages. The militants were not persuaded by Government to terminate their action against embassy. Archives, documents were seized by militants.

USA approached ICJ with a contention that Iran has violated its obligations to USA under Vienna Convention on diplomatic relations 1961. ICJ held that militants had no official status and their conduct can’t be regarded as imputable to the state of Iran, but Iran Government had failed altogether to take any appropriate steps to protect the embassy premises, staff and achieves.

Iran’s conduct was in conflict with international obligations that Iran owed to USA under Art 22 of VCDR, 1961 wherein it was duty of Iran as a receiving state to take all appropriate steps to protect premises of mission against any intrusion or damage.

Iran had infringed its categorical obligations, observed the court. It instructed Iran to immediately release the nationals of USA held as hostages and place the premises of embassy in hands of protecting power. Iran was held under an obligation to make reparation for the injury caused to USA, ruled ICJ.

It’s an established principle that the person of a diplomatic agent is regarded inviolable. It’s incorporated under Article 29 of Vienna convention which states that diplomatic agents shall not be liable to any form of arrest or detention. The receiving state shall treat him with due respect and shall take all appropriate steps to prevent any attack on his person, freedom or dignity.

ARREST OF INDIAN DIPLOMAT DEVYANI KHOBRAGADE IN US

Devyani Khobragade, an Indian consular agent was arrested on 12 December,2013 on charges of visa fraud and making false statements to the Government of USA. Khobragade had allegedly submitted an employment contract to US state department in support of visa application of her domestic help, Sangeeta Richard.

It’s imperative to understand that at the time of her arrest, she was serving as a consular agent and hence was immune from proceedings of law enforcement agencies in light of Art 41( 1) of VCCR which expressly states that –Consular officers shall not be liable to arrest or detention pending trial, except in case of a grave crime and pursuant to a decision by the competent judicial authority.

The contention of US was that the allegations against Ms. Devyani were pertaining to her ‘personal acts’ and not her ‘official acts’. It was thus argued that she was not immune from prosecution in court owing to the nature of allegations which were personal. Indian authorities, on the other hand continued pressing that -for her arrest to be made legal , USA besides proving its jurisdiction of prosecution will have to establish that allegations leveled against her are of grave offence. It was also expected of USA to clarify whether her arrest was pursuant to a decision by a competent judicial authority.

Devyani was subsequently released on bail , but USA was adamant on her prosecution. Meanwhile, Indian Government declared that Devyani has been appointed to permanent mission of India to UN. As she had acquired diplomatic immunity following her appointment, US reviewed her bail conditions in order to allow her to leave the country.

On 12th March, 2014, Judge Shira Scheindlin ordered that all charges against Khobragade be dismissed. As Khobragade had received diplomatic immunity from UN on 8th Jan,2014 and she held that immunity until 9th January,2014 on which day she left the US. Since indictment was issued on 9th January, the court held that “the Government may not proceed on an indictment obtained when Khobragade was immune from the jurisdiction of court.”

The order has however left an option open for a fresh indictment once Khobragade returns USA without any diplomatic immunity. Public Prosecutor, Preet Bahara had officially stated that- “there’s currently no bar to a new indictment against her for her alleged criminal conduct, and we intend to proceed accordingly.”

An interesting issue of acquiring immunity during pendency of proceedings came up in Devyani’s arrest case. The debate over abuse of diplomatic immunity and it hindering the administration of criminal justice in receiving state suddenly gained momentum.

In most of the cases where a diplomat of sending state receives a raw deal in receiving state , the response from former is equally unfriendly and is often considered to be an ‘act of retorsion’ . The way Indian authorities had removed barricades in front of US embassy after Devyani’s arrest is evidentiary to it.

Some of the other immunities and privileges of diplomatic agents are- immunity from civil and criminal jurisdiction of court of the receiving state. Immunity regarding residence as residences of diplomats are generally regarded inviolable, Immunity from being present as a witness, immunity from taxes, immunity from police rules, immunity from the local and military obligations, immunity from inspection of diplomatic bag(Art 27) .

In case of consular bag, however, as per Art 35(3) of VCCR, 1963 if competent authorities of receiving state have serious reasons to believe that bag contains something other than consular correspondence, documents or articles, the authorities may request that the bag be opened in their presence by an authorized representative of the sending state. If this request is refused by authorities of sending state, bag shall be returned to its place of origin.

CAN A DIPLOMATIC AGENT WAIVE HIS IMMUNITY?

A diplomatic agent may waive his own immunity. When a diplomatic agent presents himself as a witness in court of law unconditionally, it will be deemed that he has waived his immunity. Such a waiver must be however always express as enumerated in Art 32 of Vienna convention. Such immunity may be waived even by a sending state.

In light of foregoing discussion, it can be concluded that today the diplomatic immunities and privileges accorded to agents and consuls are not exclusive, absolute or blanket kind, but they pertain only in relation to the ‘official acts’ performed by them.

In cases of grave offences committed by diplomats in their personal capacities, they can be prosecuted by receiving state pursuant to a decision by the competent judicial authority. In garb of diplomatic immunity, society as a whole cannot be victimized by dismissal of valid criminal proceedings that are essential to protect the public interest.

A diplomatic agent may waive his own immunity. When a diplomatic agent presents himself as a witness in court of law unconditionally, it will be deemed that he has waived his immunity. Such a waiver must be however always express as enumerated in Art 32 of Vienna convention. Such immunity may be waived even by a sending state.

It’s an established principle that the person of a diplomatic agent is regarded inviolable. It’s incorporated under Article 29 of Vienna convention which states that diplomatic agents shall not be liable to any form of arrest or detention. The receiving state shall treat him with due respect and shall take all appropriate steps to prevent any attack on his person, freedom or dignity.

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MP HIGH COURT SEEKS DGP’S REPLY: DOES POLICE’S FAILURE TO COMMUNICATE FULL CRIMINAL ANTECEDENTS OF ACCUSED AMOUNTS TO MISCONDUCT, INTERFERENCE WITH JUSTICE?

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The Madhya Pradesh High Court in the case Kuldeep Dohare Versus the State of Madhya Pradesh observed, recently the Gwalior bench directed the Director General of Police, State of Madhya Pradesh to file an affidavit explaining as to whether non-communication of criminal antecedents of an Applicant or Accused to the Court is a minor misconduct or if it amounts to interference with the criminal justice dispensation system. Before the next date of hearing, the affidavit is to be filled.

The bench comprising of Justice G.S. Ahluwalia observed and remarked that the court was frequently finding that the police authorities were not sending the complete criminal antecedents, in spite of the circular issued by Police Headquarters.

It was observed that the police authorities did not send the criminal antecedents of the applicant. Furthermore, it is clear that it is a clear attempt to facilitate the applicant to obtain bail by projecting that he has no criminal antecedents. The issue raised is weather the conduct of police officers can be said to be a minor negligence or it is an interference with the criminal justice dispensation system?

In the present case, the court was dealing with a bail application moved by the accused applicant for offences punishable under section 307, Section 149, section 148, section 147, section 506, section 294, section 201. On an earlier hearing, the court had observed that even though the case diary did not reflect any criminal antecedents on the part of the Applicant. The impugned order passed by the lower court rejecting his bail application mentioned otherwise.

It was observed that a reply was sought by the court from the Superintendent of Police, District Bhind as to why the important information with regard to the criminal antecedents of the Applicant were withheld by the respective SHO. The SP informed the Court on the subsequent hearing that the SHO concerned as well as the Investigating Officer in the case were found guilty of misconduct and were fined with Rs. 2,000 and Rs. 5,000, respectively.

The Court observed that since the problem was stemming from different police stations. However, the DGP should file his reply regarding the prevailing situation-

Since in different police station, this situation is prevailing. Therefore, an affidavit is directed to be filled by the DGP, State of Madhya Pradesh as to whether non- communication of criminal antecedents of an applicant is a minor misconduct or it amounts to interfere with the criminal antecedents of justice dispensation system.

Accordingly, the affidavit needs to be filled within a period of 1 week, the matter would be heard next on 08.07.2022.

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HIGH COURT OF MADHYA PRADESH: SECTION 5 OF THE LIMITATION ACT APPLIES TO ARBITRATION REFERENCE UNDER NATIONAL HIGHWAY ACT, 1956

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The High Court of Madhya Pradesh in the case Ghanshyam Gupta v. State of Madhya Pradesh and Ors observed and stated that Section 5 of the Limitation Act would be applicable to reference to arbitration under the National Highways Act, 1956.

The Division Bench comprising of Justice Ravi Malimath and Justice Purushiandra Kumar Kaurav observed and reiterated that since no limitation is provided under Section 3G (5) of the National Highways Act. The bench stated that the provisions of Article 137 of the Schedule to the Limitation Act, 1963 would apply to such proceedings.

Therefore, the court held that the limitation period for filing an appeal against the decision of the competent authority before the arbitrator from the date of expiry of 90 days is three years from the decision of the competent authority.

FACTS OF THE CASE:

The petitioner, Mr. Ghanshyam Gupta was the landowner of the land which was acquired by the Respondent, Madhya Pradesh Road Development Corporation. Thereafter, the competent authority determined the quantum of compensation payable to the petitioner and passed an award to that effect on 30.07.2015.

The petitioner being dissatisfied with the quantum of compensation determined by the competent authority. On 04.12.2019, an appeal was filled by the petitioner before the arbitrator. The appeal was dismissed by the arbitrator as time-barred filed after the expiry of three years limitation period.

the petitioner filed a writ petition before the High Court, Aggrieved by the decision of the arbitrator.

Contentions Raised by the Parties:

It is stated that Section 5 of the Limitation Act is applicable to arbitration reference under Section 3G (5) of the National Highways Act, 1956.

It was observed that the petitioner was unaware of the availability of the remedy of appeal against the decision of the competent authority, the petitioner only after consulting his lawyer, that the petitioner came to know that he could seek enhancement. Further, there is a valid ground to condone the delay.

The submissions of the petitioner were countered by the Respondent on the following grounds:

Though, in the absence of a period of limitation for filing an appeal under Section 3G (5) of the Act of 1956, it was construed that the provisions of Article 137 of the Limitation Act would stand applicable.

It was stated that Article 137 provides for 3 years period, and the petitioner filed the appeal after a delay of 4 years.

COURT ANALYSIS:

The court observed and stated that since no limitation is provided under Section 3G (5) of the National Highways Act, the provisions of Article 137 of the Schedule to the Limitation Act would apply to such proceedings.

Therefore, the court held that the limitation period for filing an appeal against the decision of the competent authority before the arbitrator from the date of expiry of 90 days is three years from the decision of the competent authority.

The court observed that there is nothing in the National Highways Act that excludes the applicability of Section 5 of the Limitation Act. However, Section 5 of the Limitation Act would be applicable to reference to arbitration under the National Highways Act, 1956 and the arbitrator has the power to condone the delay against the award, in filing an appeal by the competent authority.

The court noted that the petitioner was not aware that an appeal could be filed against the decision of the Competent Authority and it is only after consulting his lawyer that the petitioner came aware of any such right, therefore, there is sufficient reason to condone the delay.

Accordingly, the application was allowed by the court and the court directed the arbitrator to decide the case of the petitioner on merit.

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KERALA HIGH COURT APPOINTS AMICUS CURIAE IN SARITHA NAIR’S PLEA; IS A STATEMENT RECORDED U/S 164 CRPC A PUBLIC DOCUMENT?

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The Kerala High Court in the case Saritha S. Nair v. Union of India & Anr observed and appointed an amicus curia to assist the court to decide the legal question of whether a statement recorded under Section 164 of the CrPC is a public document.

The bench comprising of Justice Kauser Edappagath appointed the amicus curiae, in the petition filled by Saritha S. Nair, the prime accused in the infamous solar panel scam seeking a direction to provide her with copies of the Section 164 statement given by Swapna Suresh, the accused in the gold smuggling case.

The court appointed Advocate K.K. Dheerendrakrishnan, as the amicus curiae in the case.

In the present case, it was observed that Saritha Nair is accused of having duped several influential people to the tune of 70 lakhs, by offering to install solar power units for them or by making them business partners and by receiving advance payments for the same.

Moreover, Swapna Suresh is accused of smuggling 30 kilograms of gold through diplomatic cargo dispatched to UAE Consulate at Thiruvananthapuram.

It was observed that when the petition came up for hearing, the counsel appearing for the petitioner, Advocate B.A Aloor appearing that the statement given by Swapna was a public document and therefore the petitioner was entitled to get a copy.

Further, Nair approached the Court apprehending that certain allegation may have been brought on record against her in the statement given by Suresh. It was prayed by Nair, that the c court allow her plea, directing the production of certified copies of the said document to her, failing which she would sustain an irreparable injury, the hardship and as well as physical and mental agony.

It was observed that the Nair had had initially moved the Principal District and Sessions Court of Ernakulam, with the same request, but this was denied. The court noted and adjourned the matter to July 11, while on a petition filed by the accuse, Saritha S. Nair in the solar scam cases, for seeking a directive to provide a copy of the statement given by Swapna Suresh, accused in the diplomatic gold smuggling case before a subordinate court.

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Supreme Court issues notice in an SLP; can section 156 (3) CRPC be invoked after failing to get desired relief in a civil suit?

It was observed that before the Calcutta High Court, it was contended by the accused that the allegations made in the application under Section 156(3) CrPC fails to make out any offence against them. Further, it was submitted that a frustrated unsuccessful litigant before the Civil Court has approached the Criminal Court and the Criminal Investigation.

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The Supreme Court in the case Usha Chakraborty vs State of West Bengal observed and issued a notice in a Special Leave Petition filled, raising an issue whether in a dispute essentially in a dispute of civil nature that can a person, after having failed to get the desired relief from a civil suit, invoke Section 156(3) of the Code of Criminal Procedure?

In the present case, an FIR was registered against the accused under Sections 323, Section 384, Section 406, Section 423, Section 467, Section 468, Section 420 and Section 120B of the Indian Penal Code, 1860 following an order passed by the Magistrate under Section 156(3) CrPC.

It was observed that before the Calcutta High Court, it was contended by the accused that the allegations made in the application under Section 156(3) CrPC fails to make out any offence against them. Further, it was submitted that a frustrated unsuccessful litigant before the Civil Court has approached the Criminal Court and the Criminal Investigation, which has commenced, is for the purposes of throttling them. The petition was dismissed by the High Court observing that the materials which have already been collected by the Investigating Agency, prima facie, make out a case for investigation. The issue raised before the court was weather the same would make out an offence after the investigation is concluded is absolutely at the end of the investigation to be analysed.

Therefore, challenging this order, one of the accused approached the Apex Court. However, It was submitted that the dispute is essentially of civil nature, for which the applicant in Section 156(3) CrPC petition filed a civil suit but having failed to get the desired relief, he invoked Section 156(3) CrPC.

The bench comprising of Justice Surya Kant and the Justice JB Pardiwala, while issuing notice also stayed further proceedings in FIR lodged against the accused.

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GAUHATI HIGH COURT QUASHES NO-CONFIDENCE MOTION AGAINST GRAM PANCHAYAT PRESIDENT CITING PARTICIPATION OF MEMBER DISQUALIFIED FOR HAVING THREE CHILDREN

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The Gauhati High Court in the case Jugitawali Pawe v State of Assam and 15 ors observed and quashed a resolution expressing no-confidence in the petitioner – the President of a Gram Panchayat, as a result of which she as removed from office. It was stated that it is as per the citing no compliance with Assam Panchayat Act, 1994, reading with Rule 62 of the Assam Panchayat (Constitution) Rules, 1995.

It was preferred by the petitioner to the materials available on record to argue that one of the members of the Gaon Panchayat, the respondent. The respondent voted against the petitioner and had given birth to her third child the previous year. Moreover, by virtue of Section 111(2)(a) of the Assam Panchayat Act, 1994, reading with Rule 62 of the Assam Panchayat (Constitution) Rules, 1995, the petitioner stood automatically disqualified on the date of voting. Following, which her vote was taken by passing No-confidence motion.

It was prayed by the petitioner in the plea for setting aside the impugned resolution and for issuance of a direction to restore his client back in the office. Thereafter, to initiate fresh proceedings, liberty should be granted to the respondent, following the due process.

It was agreed by the Counsel representing for the respondent that the said member of the panchayat had been disqualified but retained on the ground that the disqualification would have no bearing on the petitioner’s case, as the impugned resolution was passed before the declaration of petitioner disqualification.

In the present case, It was noticed by Justice Suman Shyam the member had voted against the petitioner and without her vote. The petitioner would not have been ousted from office. Justice Shyam also found no dispute about the fact that the member had incurred disqualification under the law prior the date of adoption of the impugned resolution. Justice Shyam found it unnecessary to delve into other aspects of the matter which includes the procedural formalities for declaring the member a disqualified candidate.

It is observed that the impugned resolution was declared to be vitiated and liable to be set aside. Further, the Court restored the petitioner to the office of the President of the Bongalmara Gaon Panchayat with immediate effect and it was stated by the court that the order will not stand in the way should the authorities or any member of the Gaon Panchayat propose a fresh motion of “no-confidence” against the petitioner and the due process of law needs to be followed.

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Halt DDA’s demolition action against jhuggis in Nizamuddin’s Gyaspur area, orders Delhi High Court

As per the JJ Rehabilitation and Relocation Policy 2015 and the Delhi Urban Shelter Improvement Board, the residents who can establish their residence prior to 01.01.2015 are eligible for rehabilitation under the JJ Rehabilitation and Relocation Policy 2015.

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plea in Delhi High Court seeking repatriation of 56 pregnant nurses

The Delhi High Court in the case Manoj Gupta & Ors. v. DDA & Ors observed and has ordered status quo on the Delhi Development Authority’s proposal to demolish jhuggi clusters in city’s Gyaspur area in Hazrat Nizamuddin. The vacation bench comprising of Justice Neena Bansal Krishna observed in the petition filled by the residents and the court granted an interim relief.

It was ordered by the court status quo till July 11, the next date of hearing.

The bench orally remarked that a ten-day delay in demolition won’t make a difference but if today it is demolished and later, we come to know that they were entitled, who’s going to… the bench will consider it on July 11, 2022 but in the Meanwhile, some protections are entitled them. Adding this, Status quo be maintained. If since 1995, they have been there, heavens won’t come down if for 10 more days they are protected.

In the plea the petitioner stated that the T-Huts settlement in the area, which was stated by the authorities to vacate. It has been in existence for almost two decades and compromise of 32 jhuggis or households.

In the plea it was alleged that the bulldozers have been parked around the camp and a DDA official has orally asked them to vacate the area and it is noted that till date no proper notice have been sent to them nor has DDA conducted any survey of the area.

Furthermore, the DDA did not provide any alternate arrangement for their rehabilitation which resulted in extreme distress among the residents.

Moreover, it was admitted by the petitioner that the land in question belongs to DDA and they may seek that status-quo to be maintained at the site. It was urged that the residents should not be physically dispose or evicted from the demolition site until the survey is conducted and rehabilitation is provided to the residents as per the DUSIB policy of 2015.

As per the JJ Rehabilitation and Relocation Policy 2015 and the Delhi Urban Shelter Improvement Board. The residents who can establish their residence prior to 01.01.2015 are eligible for rehabilitation under the JJ Rehabilitation and Relocation Policy 2015.

It is observed that in the case Ajay Maken v. Union of India, Reliance is placed on the Supreme Court decision and the High Court decision in the case Sudama Singh & Ors. v. Government of Delhi & Anr, it was held in the case that that removal of jhuggis without ensuring relocation would amount of gross violation of Fundamental Rights under Article 21 of the Constitution. Further, it was held that the agencies conducting the demolitions ought to conduct survey before undertaking any demolition.

It is submitted that these observations would apply across the board, in the entire NCT of Delhi.

Advocates Vrinda Bhandari, Shiyaz Razaq, Kaoliangpou Kamei, Jepi Y Chisho and Paul Kumar Kalai, represented the petitioner.

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