‘Treated her like family... she visited parlour, used our phone’
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"The plaintiff [Devyani Khobragade] is represented in the present suit through her father, Uttam Khobragade, who is also the power-of-attorney holder for his daughter...
"It is pertinent to mention here that the plaintiff and her family treated defendant No. 1 [Sangeeta Richard] as a member of their own family and used to pay her according to the terms of the agreement. The defendant No. 1 was provided all the facilities at home to enable her to execute her assigned work as per the said contract. Defendant No. 1 was the only adult person staying at the plaintiff's home between 9 am and 7 pm and was working as per her own choice, as the plaintiff and her husband generally remain out throughout the day. The house is equipped with all modern domestic gadgets. Defendant No. 1 was being given leave/off on Sundays when she used to visit a beauty parlour, church and her friends. Defendant No. 1 used to mention a friend called Maggie working in a nearby salon. Defendant No. 1 was at liberty to use and in fact was using the plaintiff's residential phone to talk to her family in Delhi regularly. Defendant No. 1 had all the liberties to work, talk and move freely and was accorded due respect and dignity as an IBDA [Indian-based domestic assistant].
"On June 23, when the plaintiff came back, defendant No. 1 was not at home... The plaintiff searched the room allotted to defendant No. 1 and found that she had left with most of her belongings and the official passport... The plaintiff also made a preliminary search of her apartment and could not locate a red file marked 'important papers to be sorted'.
"...The plaintiff received a call from a lady who claimed to be the lawyer of defendant No. 1... She said defendant No. 1 was verbally abused and made to work for 19 hours a day. She did not wish to go to court and only wished to claim her dues, provided the consulate signed the '566 form' authorising her to terminate her employment and change her visa status from a government visa to a normal visa...
"On July 8, the plaintiff was called to Access Immigration in New York regarding terms of settlement. Defendant No. 1 was present. They were told that she demanded $ 10,000, an ordinary Indian passport and immigration relief... In view of the aforesaid developments, the Government of India revoked her official passport and gave a notice of termination...
"The plaintiff filed an FIR against the defendants with Police Station Mehrauli, New Delhi, on July 2. As a counter-blast, the defendants filed a writ petition in this court making several unfounded allegations against the plaintiff, including that she was being treated as a 'slave' and as 'a person in bondage'. The court, by its order dated July 19, dismissed the petition as withdrawn while giving limited rights to the petitioner [Philip Richard] to file another writ petition for directions to the Delhi police to grant him protection.
"The plaintiff has a strong apprehension that they may raise similar grounds by filing another suit/proceedings in the US, which they are now barred from doing, having already agitated the same before this court... A decree in the nature of mandatory and permanent injunction/declaration may kindly be passed... restraining the defendants from any action and/or proceedings or filing any suit and/or claims against the plaintiff in any court/tribunal/forum outside India..."
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