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Punjab & Haryana High Court Monthly Digest: January 2025
Aiman J. Chishti
24 Feb 2025 5:45 PM IST
Citations [2025 LiveLaw (PH) 01 - 2025 LiveLaw (PH) 44]XXX v. STATE OF HARYANA AND OTHERS 2025 LiveLaw (PH) 01ICICI BANK LTD. v. M/S ORIENT CLOTHING CO. PVT. LTD. AND OTHERS 2025 LiveLaw (PH) 02Kuldeep Kumar Sharma v. Randeep Rana 2025 LiveLaw (PH) 03Amit Katyal v. CBI 2025 LiveLaw (PH) 04Devender v. State of Haryana [along with connected matters] 2025 LiveLaw (PH) 05PARVEEN ALIAS DADA v....
Citations [2025 LiveLaw (PH) 01 - 2025 LiveLaw (PH) 44]
XXX v. STATE OF HARYANA AND OTHERS 2025 LiveLaw (PH) 01
ICICI BANK LTD. v. M/S ORIENT CLOTHING CO. PVT. LTD. AND OTHERS 2025 LiveLaw (PH) 02
Kuldeep Kumar Sharma v. Randeep Rana 2025 LiveLaw (PH) 03
Amit Katyal v. CBI 2025 LiveLaw (PH) 04
Devender v. State of Haryana [along with connected matters] 2025 LiveLaw (PH) 05
PARVEEN ALIAS DADA v. UNION OF INDIA AND ORS 2025 LiveLaw (PH) 06
X v/s Y 2025 LiveLaw (PH) 07
Sobia Mujib v. State of Punjab and others 2025 LiveLaw (PH) 08
Ashu v. State of Punjab 2025 LiveLaw (PH)09
Amit Kumar Aggarwal and others v. Bimla Devi 2025 LiveLaw (PH) 10
Kulwinder v. State of Punjab 2025 LiveLaw (PH) 11
Khalid v State of Haryana 2025 LiveLaw (PH) 12
XXX v. FORTIS HOSPITAL MOHALI AND OTHERS 2025 LiveLaw (PH) 13
Gulmohar Township India Pvt. Ltd. and others v. State of Punjab and others [along with connected matters] 2025 LiveLaw (PH) 14
Nabhdeep Bansal v. State of Punjab and Anr [with other connected matters] 2025 LiveLaw (PH) 15
Manmeet Kaur v. The State of UT Chandigarh 2025 LiveLaw (PH) 16
Soni Kumar v. State of Punjab 2025 LiveLaw (PH) 17
AMANDEEP KAMBOJ @ AMAN v. STATE OF PUNJAB 2025 LiveLaw (PH) 18
Mahinder Ram v. Commandant General, Punjab Home Guards and others 2025 LiveLaw (PH) 19
LSE Securities Ltd v. Jaswinder Singh Kapoor 2025 LiveLaw (PH) 20
Rajpal v. State of Punjab 2025 LiveLaw (PH) 21
Brindco Sale Pvt Ltd. v. State of Punjab 2024 LiveLaw (PH) 22
Prem Kumar v. Punjab & Haryana High Court, Chandigarh and another 2025 LiveLaw (PH) 23
Dabir Singh v State of Haryana 2025 LiveLaw (PH) 24
Gurpreet Singh v. State of Punjab 2024 LiveLaw (PH) 25
]Vuenow Infotech Pvt. Ltd. v. Directorate of Enforcement, Jalandhar Zonal Office, Punjab and Another 2025 LiveLaw (PH) 26
JOGINDER SINGH v. STATE OF PUNJAB 2025 LiveLaw (PH) 27
Sarwan Singh v. Jagmohan Singh 2025 LiveLaw (PH) 28
SUKHPREET SINGH DHALIWAL @ BUDHA v. UNION OF INDIA AND OTHERS
Citation: 2025 LiveLaw (PH) 29
Dr. Sushank v. Union of India and others 2025 LiveLaw (PH) 30
Neeraj Saluja v. Directorate of Enforcement 2025 LiveLaw (PH) 31
Subhash Chand v. Financial Commissioner, Haryana and others 2025 LiveLaw (PH) 32
PUNEET AGGARWAL V/S PUNJAB AND HARYANA HIGH COURT AND ANOTHER 2025 LiveLaw (PH) 33
Smt Bhagrathi v. State Of Haryana and ors. 2025 LiveLaw (PH) 34
STATE OF HARYANA AND ANOTHER v. V N GROVER AND OTHERS 2025 LiveLaw (PH) 35
UNION OF INDIA v. JC 428517 EX SUBEDAR ANOKH SINGH AND ANOTHER 2025 LiveLaw (PH) 36
Arun Kumar Gupta and others v. M/s Karnal Motors Pvt. Ltd 2025 LiveLaw (PH) 37
Amar Singh v. State of Punjab & Ors 2025 LiveLaw (PH) 38
SAURABH MADAAN MITHU v. STATE OF PUNJAB & ORS. 2025 LiveLaw (PH) 39
M/S BRAHMA MAINTENANCE PVT.LTD. v. THE CONSUMER GRIEVANCES REDRESSAL FORUM (UHBVN) AND OTHERS 2025 LiveLaw (PH) 40
Association of NCTE approved Colleges Trust v. State of Haryana and others 2025 LiveLaw (PH) 41
Lakshay Attri v. Chandigarh Administration and others 2025 LiveLaw (PH) 42
Faisal Ali v. UOI & Ors 2025 LiveLaw (PH) 43
Reports
Title: XXX v. STATE OF HARYANA AND OTHERS
Citation: 2025 LiveLaw (PH) 01
The Punjab and Haryana High Court has issued a slew of guidelines to be followed by the State and Police when it is approached by an individual or a run away couple, alleging threat to their life and liberty.
In his 23-page order made available on December 24, 2024, Justice Sandeep Moudgil said, "It is need of the hour that a mechanism needs to be framed by the States with the aim for expeditious inquiry consisting of facts finding and adjudication of the dispute at the administrative level which are primarily in the nature of dissent of elders in a family to the wishes and desire of younger ones due to multifacet reasons which need not to be gone at this stage by this Court."
Title: ICICI BANK LTD. v. M/S ORIENT CLOTHING CO. PVT. LTD. AND OTHERS
Citation: 2025 LiveLaw (PH) 02
The Punjab and Haryana High Court has made it clear that a party cannot invoke the alternative jurisdiction in a dispute once they have decided the territorial jurisdiction by way of entering into a valid contract.
The bench of Justice Sureshwar Thakur and Justice Sudeepti Sharma said if the contract is validly executed wherein the parties have consensually conferred the jurisdiction of a court, then the party is "estopped from negating it."
Title: Kuldeep Kumar Sharma v. Randeep Rana
Citation: 2025 LiveLaw (PH) 03
The Punjab and Haryana High Court has made it clear that Local Commissioner is not a witness of any party and the discretion lies with the Executing Court to permit or refuse to examine the Commissioner.
Justice Deepak Gupta said "the Local Commissioner appointed by the Court is not a witness for any of the party. In fact, he performs his duty as an extended arm of the court and thus to all intent and purposes, he is an officer of the Court."
Title: Amit Katyal v. CBI
Citation: 2025 LiveLaw (PH) 04
The Punjab and Haryana High Court has upheld the order summoning an additional accused to face trial in the Gurugram land acquisition scam, allegedly involving then Haryana Chief Minister Bhupinder Singh Hooda and others from the Industrial Model Township.
Justice Kuldeep Tiwari opined that there are sufficient incriminating evidence which require the Petitioner- Amit Katyal, who was the Director of the company allegedly involved in the scam, to face trial along with other co-accused.
Title: Devender v. State of Haryana [along with connected matters]
Citation: 2025 LiveLaw (PH) 05
The Punjab & Haryana High Court set aside the conviction in a murder case against multiple accused persons wherein the Trial Court gave a common verdict after reviewing its earlier order directing to try them separately.
Title: PARVEEN ALIAS DADA v. UNION OF INDIA AND ORS
Citation: 2025 LiveLaw (PH) 06
The Punjab and Haryana High Court has upheld the preventive detention of Haryana's alleged Azad gang member Parveen alias Dada under the National Security Act, 1980.
Among other grounds, it was argued that the State authorities did not follow the timeline provided under Section 3(5) of NSA.
Case Title: X v/s Y
Citation: 2025 LiveLaw (PH) 07
The Punjab & Haryana High has said that the "ordinary residence of a child" or a ward would determine which court would have jurisdiction to decide the child's custody under the Guardianship & Wards Act.
It further underscored that the "ordinary residence" of the child would determine the court's jurisdiction which can hear the custody case, and the "natural guardianship" of the child will not determine this jurisdiction. The court further emphasized that the two concepts cannot be superimposed.
Title: Sobia Mujib v. State of Punjab and others
Citation: 2025 LiveLaw (PH) 08
The Punjab and Haryana High Court has held that once a family member has availed the benefit of compassionate appointment, the same cannot be granted to another family member after the service of that family member had been terminated.
In the present case, the appellant's brother was appointed on compassionate grounds in position of her father, who passed away during service. However, the brother absented himself from duty, and his service was terminated. Thereafter, the appellant sought the appointment in place of his brother.
Title: Ashu v. State of Punjab
Citation: 2025 LiveLaw (PH) 09
The Punjab & Haryana High Court has made it clear that while adjudicating anticipatory bail under NDPS, the manner in which the petitioner has been arraigned or implicated is a required to be seen.
Justice Sumeet Goel explained, “The final evidentiary value and admissibility of the disclosure statement made by a co-accused fall within the domain of the trial Court and are to be adjudicated during the course of the trial in accordance with established principles of law. However, while adjudicating a plea for anticipatory bail, this court cannot remain oblivious to the circumstances under which the petitioner has been arraigned or implicated, including the nature of the allegations, the evidence linking the petitioner to the offence as well as the specific role attributed to the petitioner in the commission of the alleged offence.”
Title: Amit Kumar Aggarwal and others v. Bimla Devi
Citation: 2025 LiveLaw (PH) 10
The Punjab & Haryana High Court has said that single judge passing order allowing to withdraw the contempt plea with liberty to revive it during the pendency of appeal is unnecessary intrusion into the appellate jurisdiction.
While hearing a contempt plea the single judge had noted that "...counsel for the petitioner does not press the present petition at this stage with liberty to seek revival, if required, subject to final outcome of the aforesaid contempt appeal.Ordered accordingly..."
Title: Kulwinder v. State of Punjab
Citation : 2025 LiveLaw (PH) 11
The Punjab & Haryana High Court has made it clear that the grant of bail in a case pertaining to commercial quantity, on the ground of undue delay in trial, cannot be said to be fettered by Section 37 of the NDPS Act, 1985.
As per Section 37 of the NDPS Act, the Court can grant bail to an accused in case of commercial quantity only after hearing the public prosecutor. If the prosecutor opposes bail, the accused has to satisfy the court that (a) there are reasonable grounds for believing that he is not guilty of such an offence and that (b) he is not likely to commit any offence after being released from jail. This provision makes it difficult to secure bail in NDPS cases.
Title: Khalid v State of Haryana
Citation: 2025 LiveLaw (PH) 12
The Punjab & Haryana High Court has expressed concern about increasing litigation under the Haryana Gauvansh Sanrakshan and Gausamvardhan Act, observing that the objective of the Act was to curtail the "consumption of beef menace emanating from the powerful meat lobby consuming and selling beef" but State is not executing properly. The Court rejected the anticipatory bail plea of the accused who was apprehending arrest for allegedly being the owner the pick up vehicle used for carrying the cows for slaughtering.
Title: XXX v. FORTIS HOSPITAL MOHALI AND OTHERS
Citation: 2025 LiveLaw (PH) 13
The Punjab & Haryana High Court held that a woman living separately from her husband without obtaining divorce can terminate pregnancy without taking consent from the husband under the Medical Termination of Pregnancy Act.
Justice Kuldeep Tiwari referring to X Vs. Principal Secretary, Health and Family Welfare Department and Anr and, Rule 3(B)(c) of the The Medical Termination of Pregnancy Rules, 2003 said, "giving a purposive interpretation to the expression “change of marital status”, this Court can safely conclude that although the petitioner does not fall within the purview of “widow or divorcee”, however, since she has decided to live separately from the company of her husband without legally obtaining divorce, hence she is eligible for termination of pregnancy."
Title: Gulmohar Township India Pvt. Ltd. and others v. State of Punjab and others [along with connected matters]
Citation: 2025 LiveLaw (PH) 14
The Punjab & Haryana High Court quashed an FIR lodged under Prevention of Corruption Act (PC Act) against Gulmohar Township India Pvt Ltd and its director for allegedly fraudulently bifurcating a land into smaller plots without following due process of law and causing huge loss to State exchequer.
The Court noted that the complaint was lodged by "Navjot Singh-congressman" whose identity is unknown and without verification the complaint was sent to the Deputy Superintendent of Police.
Title: Nabhdeep Bansal v. State of Punjab and Anr [with other connected matters]
Citation: 2025 LiveLaw (PH) 15
The Punjab and Haryana High Court refused to answer a reference question placed before it, observing that that the single judge prima facie breached the "norm of propriety governing judicial functionings" and called itself as "coram non judice".
Title: Manmeet Kaur v. The State of UT Chandigarh
Citation: 2025 LiveLaw (PH) 16
The Punjab & Haryana High Court quashed an FIR lodged against a woman–an international civil servant with the United Nations–who traveled from South Africa to India, under Sections 269 IPC and Section 51 of Disaster Management Act for allegedly spreading COVID-19 infection during the outbreak in 2021.
Title: Soni Kumar v. State of Punjab
Citation: 2025 LiveLaw (PH) 17
The Punjab & Haryana High Court has said that an FIR under Section 174-A IPC (non-appearance of a person in response to a court summons or warrant of arrest) does not get quashed merely because the main case is quashed or the parties have entered into compromise, however the same will be a relevant factor to consider in the quashing plea.
Title: AMANDEEP KAMBOJ @ AMAN v. STATE OF PUNJAB
Citation: 2025 LiveLaw (PH) 18
The Punjab and Haryana High Court granted bail to conman Aman Skoda accused of defrauding by taking hefty sum of money in exchange of providing government job in Punjab.
Amandeep Kamboj, alias Aman Skoda, was declared proclaimed offender in other cases and was absconding for 2 years and allegedly involved in 48 FIRs. He was arrested in Varanasi in March, 2024 by Punjab Police.
Title: Mahinder Ram v. Commandant General, Punjab Home Guards and others
Citation: 2025 LiveLaw (PH) 19
The Punjab and Haryana High Court has directed the authorities to grant subsistence allowance to a home guard who worked continuously for 27 years, observing that denying the same on the ground that he was not permanent or regular employee would be violative of Article 14 and 21 of the Constitution.
Title: LSE Securities Ltd v. Jaswinder Singh Kapoor
Citation: 2025 LiveLaw (PH) 20
The Punjab & Haryana High Court has made it clear that a company cannot refuse to produce a summoned document by seeking protection of Article 20(3) of the constitution, without satisfying its ingredients.
Title: Rajpal v. State of Punjab
Citation: 2025 LiveLaw (PH) 21
The Punjab & Haryana High Court has said that "non-cooperation in investigation” must be interpreted with precision and cannot be equated with the failure of the accused to disclose information about his alleged accomplices or for facilitating the recovery of bribe money.
Title: Brindco Sale Pvt Ltd. v. State of Punjab
Citation: 2024 LiveLaw (PH) 22
The Punjab & Haryana High Court has set aside the order rejecting a liquor license (L-1), observing that if a director is involved in a criminal case then it would not mean that the company is also involved.
Title: Prem Kumar v. Punjab & Haryana High Court, Chandigarh and another
Citation: 2025 LiveLaw (PH) 23
The Punjab & Haryana High Court has directed to reinstate an additional and sessions judge with consequential benefit, who was dispensed from service during the probation period on account of "doubtful integrity" .
Title: Dabir Singh v State of Haryana
Citation: 2025 LiveLaw (PH) 24
The Punjab and Haryana High Court has refused to grant anticipatory bail to a man accused of taking 10 crore with other co-accused for securing the post of Lieutenant Governor in Andaman and Nicobar, observing that granting relief when there is prima facie sufficient evidence would send a "very negative message" to the public.
Gurpreet Singh v. State of Punjab
Citation: 2024 LiveLaw (PH) 25
The Punjab & Haryana High Court has refused to grant anticipatory bail to a man accused in a drugs case seeking relief on the ground that the co-accused has been granted regular bail, observing that the petitioner wilfully evaded his arrest for more than 2 years.
Title: Vuenow Infotech Pvt. Ltd. v. Directorate of Enforcement, Jalandhar Zonal Office, Punjab and Another
Citation: 2025 LiveLaw (PH) 26
The Punjab and Haryana High Court has refused to de-freeze bank account of Vuenow Infotech Pvt. Ltd, a company allegedly involved in the "Cloud Particle Scam".
Vuenow Infotech is accused of dishonestly inducing large number of investors to invest in cloud particles or data center assets by selling them non- existent and insubstantial particles and have, therefore, cheated and breached the trust of various investors.
Title: JOGINDER SINGH v. STATE OF PUNJAB
Citation: 2025 LiveLaw (PH) 27
The Punjab & Haryana High Court has said that accused persons who are not present at the crime scene should be held equally accountable and should not be afforded any leniency under Narcotic Drugs and Psychotropic Substances Act (NDPS Act).
Title: Sarwan Singh v. Jagmohan Singh
Citation: 2025 LiveLaw (PH) 28
The Punjab & Haryana High Court has said that the Court Fees (Punjab Second Amendment) Act, 2009, will be applicable on appeals filed in the High Court if the suit from which an appeal has arrived was instituted in Punjab, regardless of the fact that the High Court is located in UT Chandigarh.
Title: SUKHPREET SINGH DHALIWAL @ BUDHA v. UNION OF INDIA AND OTHERS
Citation: 2025 LiveLaw (PH) 29
The Punjab & Haryana High Court has refused to grant immunity under the Extradition Act, 1962 to an alleged “notorious gangster” Sukhpreet Singh Dhaliwal (Budda) finding that he was arrested at IGI airport (New Delhi) after Armenia authorities had released him.
Title: Dr. Sushank v. Union of India and others
Citation: 2025 LiveLaw (PH) 30
The Punjab & Haryana High Court has directed the National Medical Commission to ensure creation of Appellate Medical Body to address disputes related to disability certificates for medical admissions.
Title: Neeraj Saluja v. Directorate of Enforcement
Citation: 2025 LiveLaw (PH) 31
The Punjab & Haryana High Court has granted bail to the former director of SEL Textiles Limited Neeraj Saluja in a money laundering case, accused of diverting loan amount for purposes other than what it was sanctioned for.
Title: Subhash Chand v. Financial Commissioner, Haryana and others
Citation: 2025 LiveLaw (PH) 32
The Punjab & Haryana High Court has held that the post of Lambardar is a civil post and his dismissal or removal attracts the provisions of Article 311 of the Constitution.
Justice Sureshwar Thakur and Justice Kirti Singh said that a Lambardar who occupies a civil post, thus cannot claim eligibility for his being appointed against some other civil post.
TITLE: PUNEET AGGARWAL V/S PUNJAB AND HARYANA HIGH COURT AND ANOTHER
Citation: 2025 LiveLaw (PH) 33
The Punjab & Haryana High Court on Thursday (January 23) issued notice on a plea challenging the marks allotted to a candidate in mains examination of Haryana Superior Judiciary, 2023.
While issuing notice on the plea, a bench of Chief Justice Sheel Nagu and Justice Sumeet Goel orally remarked, "Under Judicial Review we are entering into an area which is not our domain."
Title: Smt Bhagrathi v. State Of Haryana and ors.
Citation: 2025 LiveLaw (PH) 34
The Punjab & Haryana High Court has issued slew of directions for conducting the no-confidence against Chairman of Faridabad block samiti on January 24.
Suspecting horse-trading the plea filed by the Chairman challenged the notice to postpone the No-Confidence Motion meeting from January 13 to January 24.
Title: STATE OF HARYANA AND ANOTHER v. V N GROVER AND OTHERS
Citation: 2025 LiveLaw (PH) 35
The Punjab & Haryana High Court took a stern stand on Haryana Government's action to only give 1 Rupee hike in pay scale of Executive Engineer following High Court's direction to revise the salary, observing that the revised salary is "non-functional" and "patently illegal."
Justice Sanjeev Prakash Sharma and Justice Meenakshi I. Mehta said, "We find that the action of the State authorities is committing mockery of the Court's orders, and certain officers who pass such orders deserve to be hauled up. We deprecate the practice adopted by the officers in making lip service to the Court's orders."
Title: Narender Kumar Malhotra v. Union of India and another
Citation: 2025 LiveLaw (PH) 36
The Punjab & Haryana High Court dismissed a Public Interest Litigation (PIL) filed seeking declaration to make celebration of festival of “Karwa Chauth” compulsory by women irrespective of their status of being widows, separated, divorcees and the women in live-in relation.
Chief Justice Sheel Nagu and Justice Sumeet Goel while dismissing the plea imposed a token cost of Rs.1000.
Title: UNION OF INDIA v. JC 428517 EX SUBEDAR ANOKH SINGH AND ANOTHER
Citation: 2025 LiveLaw (PH) 37
The Punjab & Haryana High Court has taken a stern stand on the failure of the Union Government to grant disability pension to a retired Armed Forces Officer following the Supreme Court's directions. In an order passed on January 23, a bench of Justice Sanjeev Prakash Sharma and Justice Meenakshi I. Mehta said, "In another three days, we are going to celebrate the 76th Republic Day, and the entire celebrations of Independence and Republic Day are basically on account of our Army Forces performing strenuous duties at the borders and even challenging the counter-terrorism. The Union of India and its authorities are therefore required to be alive to their situations."
Breach Of Lok Adalat Order Will Not Amount To Contempt Of Court: Punjab & Haryana High Court
Title: Arun Kumar Gupta and others v. M/s Karnal Motors Pvt. Ltd
Citation: 2025 LiveLaw (PH) 38
The Punjab & Haryana High Court has said that Lok Adalat is not a Court under the Contempt of Courts Act and breach of its order will not amount to contempt of court.
Justice Sureshwar Thakur and Justice Kirti Singh allowed an appeal against a contempt notice issued for violating an undertaking given before the Lok Adalat.
Title: Amar Singh v. State of Punjab & Ors
Citation: 2025 LiveLaw (PH) 39
The Punjab and Haryana High Court has directed to reinstate a policeman expelled from service for being accused in robbery case even after being acquitted in the matter.
Justice Jagmohan Bansal noted that the, “police authorities dismiss an officer as soon as FIR is registered whereas mandate of Rule 16.2 and 16.3 is to dismiss from service after conviction. The officer may be suspended or assigned non sensitive posting, however, department should not take harsh action of dismissal from service in every case where an FIR has been registered. In an exceptional case, action of dismissal at the first instance may be taken but it should not be practice.”
Title: SAURABH MADAAN MITHU v. STATE OF PUNJAB & ORS.
Citation: 2025 LiveLaw (PH) 40
The Punjab & Haryana High Court today directed the video recording of proceedings to be conducted for electing the mayor of Amritsar Municipal Corporation.
In a plea filed by a Congress Councillor it was alleged that the houses of some of the Councillors, who are to participate in the meeting, were being raided by the Police authorities to harass them and prevent their participation in the aforesaid meeting for electing the Mayor.
Title: M/S BRAHMA MAINTENANCE PVT.LTD. v. THE CONSUMER GRIEVANCES REDRESSAL FORUM (UHBVN) AND OTHERS
Citation: 2025 LiveLaw (PH) 41
The Punjab & Haryana High Court dismissed a firm's plea which had challenged an order of the Consumer Grievances Redressal Forum (UHBVN) formulated under the regulations of the Haryana Electricity Regulatory Commission (HERC) which had directed the former to provide electricity bill to the consumers showing clearly the energy consumed and tariff applicable following the regulations.
Title: Association of NCTE approved Colleges Trust v. State of Haryana and others
Citation: 2025 LiveLaw (PH) 42
The Punjab & Haryana High Court imposed a cost of Rs 4 lakh on the Association of Colleges which has been approved by the National Council for Teacher Education (NCTE) for filing a frivolous petition challenging regular inspection carried out by the University under which colleges are affiliated.
Title: Lakshay Attri v. Chandigarh Administration and others
Citation: 2025 LiveLaw (PH) 43
The Punjab & Haryana High Court has dismissed a PIL seeking directions to Chandigarh UT Administration to take immediate remedial steps to restore a Football Stadium, in Sector-17 Chandigarh in conformity with international standards, observing that the court cannot step into the administration's shoes and start running it.
Title: Faisal Ali v. UOI & Ors
Citation: 2025 LiveLaw (PH) 44
The Punjab & Haryana High Court on Friday has disposed of a plea seeking a ban on the release of a movie based on the Delhi riots 2020.
The Court took note of the Union Government's submission that the producer of the movie 'Delhi-2020' has not yet applied for the certificate before the Central Board of Film Certification (CBFC).