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I, Kamini Jaiswal D/o Mr. R.S. Jaiswal R/o E-77 (FF), Saket, New Delhi, do herby solemnly affirm and declare as under:-
1. That I am an advocate by profession regularly practising at the Supreme Court of India since 1978.
2. That I have been residing at Delhi since 1976 and have been acquainted with the family of Mr.Ram Jethmalani and his daughter Ms. Rani Jethmalini since 1978. They had at that time been residing at 7 – B, Janpath, New Delhi and I was living at 60, Navjeevan, New Delhi.
3. That on 31st Oct.'84, sometime in the afternoon news of the assassination of Mrs. Indira Gandhi then Prime Minister of India was received, after the court hours. I went to the residence of Ms. Rani Jethmalani to meet her at around 4:00 pm that at about 5:00 pm there was a phone call from Ms. Laila Fernandes informing Ms. Jethmalani that large scale killing and violence was going on around South Delhi. Innocent people were being killed mercilessly and something should be done. She said, "I am coming there immediately".
4. That after some deliberation it was thought appropriate that we should go and meet Hon'ble Home Minister Mr. P.V.Narsimha Rao who was also a senior leader of Congress Party. An appointment was sought from him and we went it his residence around 7:00 pm He came out and we told him that he should do something about this merciless and brutal killings that were going on in the city.
To our shock, he did not react at all but responded by saying that yes he would be looking into this matter. We came back and more reports of killing came in from all over. In fact, the situation was so grave that it was the one and only time when I was advised not to return to my residence that night since people were being burnt on the road leading to Kotla Mubarakpur.
5. That on 1st and 2nd Nov.'84, some lawyers met at Supreme Court, we visited various areas like Laxmi Nagar, Vinod Nagar, Pandav Nagar, Kalyanpuri, etc. At all these places, we witnessed horrendous sights of petrified women and children huddled-up to-gather at certain places and remains of burnt bodies with car/scooter tyres burning and remains of large scale loot and carnage.
I distinctly recollect the sight of a severely injured Sikh gentlemen hiding in the corner of his house behind a trunk, other male members of his family had been killed by the crowd. He was the sole male survivor. On asking them how all this had happened, they all said that they were attacked by groups of people who were led by local leaders like H.K.L. Bhagat, Tajdar Babbar, etc.
This gentlemen dared to come out from hiding only after he was sure that we were only going to help and if possible get him medical aid. We requested the driver of Mr. Jethmalani to take him to hospital.
6. That on 3rd Nov.'84, we visited amongst other places, a Gurdwara in Pandav Nagar where we were informed that a large number of persons belonging to the Sikh Community were hiding there. While we were going to the Gurdwara, we were met by a group of persons who asked us to go back as nothing was wrong. On inquiry, the leader of the group identified himself as Mr. Padam Sharma DPCC (I) President, but since we had been to this Gurdwara on 2nd Nov. also and had seen the people hiding there, we did not believe him.
When we reached the Gurdwara, some of the persons in the Gurdwara were very anxious about their family members who had been left behind across the road at South Ganesh Nagar. We volunteered to rescue those people but when we tried to do that, it was met with great hostility and violence from the very persons namely Sh. Padam Sharma etc. and who had met us earlier and we were attacked with the iron rods, stones and stick and asked to go back immediately.
Their contention was that we were up-setting the balance of Sikhs and Non-Sikhs in the area and they would feel threatened. We tried to tell them that their fear was unfounded. Here were the people who seemed to have lost everything and were scared for their lives- how could such baseless allegations be made but the crowd turned violent and attacked us with iron rods and stones.
7. That in those days, all the areas specially the colonies that we repeatedly visited, we heard a similar tale of woe. The experiences of all those persons were of similar horrible nature.
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