This is a counter petition being filed against false and baseless petition filed by Amandeep Hospital, Amritsar, in which, its management has leveled absolutely false and baseless against me.

The true facts of the matter are as under: -

1. That as we all know that with the onset of pandemic Covid19, a lockdown is going on in our country, which is being observed by all the citizens in the interest of the country as well as in their own interest. In addition to the lockdown, the honorable Chief Minister Punjab has imposed curfew in the entire State of Punjab.

2. That pursuant to the lockdown as well as the Curfew, residents of all the villages and cities of Punjab have confined themselves within their houses. Rather, the villages have sealed their boundaries. Even residents have closed all the entry and exit points of their respective localities, so as to prevent any unnecessary movement out of and inside their localities. The Honorable Chief Minister of Punjab Captain Amrinder Singh during his interaction with the honorable Prime Minister of India had duly mentioned the fact that out of 13300 villages of Punjab, except 1500 villages, all other villages have sealed their boundaries, on their own, to prevent any unnecessary entry and exit to their village.

3. That Amandeep Hospital, GT Road ,Amritsar, is a private hospital providing treatment for Ortho related ailments, Joint Replacement, Neuro and Plastic Surgery. There is a private parking lot in our Ward No. 53, known as Rani Ka Bagh, Amritsar, situated about half kilometer away from the Hospital, taken on rent by the aforesaid Hospital for the last about four years. Patients of the above hospital, which hail from different parts of Punjab and even from surrounding States, have been parking their vehicles in the above parking place. None of the residents of our ward has ever objected to it.

" It is worth mentioning here that the above hospital has not been ear marked for any Covid19 related treatment/test nor any patient suffering from Covid19 has ever been admitted there. "

4. That it is also pertinent to mention over here that Smt. Neetu Tangri, wife of the undersigned is a Councilor of Ward No. 53. In view of the daily entry and exit of hundreds of vehicles of patients of the above Hospital, the residents of our locality were worried about spread of infection by those commuters, who hailed from different parts of Punjab as well as other States. In this regard, two written representations were moved by the residents to wife of the undersigned to stop the entry of outside vehicles, particularly, of patients of the above hospital. As submitted above, the above hospital is providing treatment for Ortho related ailments, Joint Replacement and Neuro Surgery only. No treatment/test of Covid19 patients is being done there. On the request of the residents, we requested the management of the above Hospital to temporarily shift the parking to another space measuring 4000 sq. yards available with them. It was further requested to instruct their patients to park their vehicles in that open space till the Corona situation is over and thereafter, they can again use the parking lot situated inside our ward. But, the Hospital authorities flatly refused to do so and when, all the requests and genuine demands made by the residents fell on their deaf ears, keeping in view their health, the residents closed the gates of the colony. It was totally in consonance with the ongoing lockdown as well as the curfew in the State. None of the hospital doctors or the staff members was ever stopped, as falsely claimed by them. Moreover, they were not doing any Corona related treatment, but, were indulged in private affair of the hospital only, which provided only Ortho related treatment. None of the Doctors or staff member is deputed on COVID19 duty. The hospital has falsely, wrongly and with an ulterior motive cashed on and taken undue advantage of sentiments of the general public to serve their self interest. Rather, they have played with the sentiments of the general public and under the garb of Corona situation, they wanted to bully the residents of our locality, so that they may not object to entry and exit of vehicles of Ortho patients of their hospital.

5. That there is another side of the matter. On an earlier occasion, a patient from the locality of the undersigned (the undersigned has all the records of that incident with him) visited Amandeep Medicity, Mall Road, Amritsar, which is also owned by Amandeep Hospital. Within a short time of his admission the said patient passed away. But, the hospital slapped the family members with a bill running into lakhs of rupees. The family of the patient was too poor to bear the bill. The hospital authorities refused to hand over dead body of the patient to them. The matter went to Police.

However, with the intervention of the undersigned and after much persuasion, the hospital reduced the bill and handed over the dead body to the family members of the patient. Since then, the owners of the hospital are nursing a grudge against the undersigned. Besides this, both the hospital i.e. Amandeep Hospital G.T. Road, Amritsar and Amandeep Medicity, Mall Road, Amritsar, has carried out illegal constructions against the Municipal By-laws. The construction of the Hospital of G.T.Road, Amritsar, which has also encroached upon the area of Rani Ka Bagh, Amritsar, was objected to by the residents and at that time too, I had accompanied the residents, which thing also didn’t go down well with the Hospital. Now, the present situation has been encashed by the hospital authorities to settle the old scores with the undersigned.

6. That on 13-04-2020, the residents closed the doors of the locality, to prevent any vehicle to enter into it. This infuriated the hospital authorities. They filed a false and baseless complaint against him and some other persons, leveling absolutely false allegations. However, with the intervention of the respectables, the matter was amicably settled. All the residents of Ward no. 53 including the undersigned and owners of the Hospital i.e. Dr. Avtar Singh entered into a written compromise in the office of the hospital, in presence of Mrs. Archana Sharma, Executive Magistrate, Amritsar, Sh. Dev Dutt Sharma, A.C.P. (West), Amritsar, Mr. Ranjit Singh,S.H.O. Cantonment, Mrs. Rajwinder Kaur, SHO P.S. Chheharta, Sh. Raman Bakshi, Senior Deputy Mayor, Municipal Corporation, Amritsar and some other respectables. It was settled that till 21-04-2020, vehicles of staff members of the hospital will be allowed to be parked in the above parking and thereafter, parking will temporarily be shifted to their another parking lot and after the lockdown is over, they can again park their vehicle in the parking lot taken on rent by them in Ward no. 53. This compromise was signed by both the parties. But, now, again, the matter is being blown out of proportion and the hospital authorities are trying to garner undue sympathy by speaking lie on social media under the garb of Corona situation, by posting false posts, thereby, defaming the undersigned.

7. That the undersigned has a great regard for medical fraternity, which is serving our nation with all the devotion and fighting this battle in front line. The undersigned and the fellow residents are, rather, indulged in distributing free medicines, ration, clothing and other necessities of life to poor people of the locality. But, the hospital authorities with an ulterior motive by concealing real facts and exploiting sentiments of the general public are defaming the undersigned and spreading hatred against him.

8. Respected sirs, the real facts have been narrated above. There are always three sides of a story, you, me and the Truth and the truth always prevails. The undersigned has strong belief in the rule of law and the Devine Justice as well. With these humble submissions, I leave matter to the wisdom of the general public and submit myself before your honour to provide justice to me.