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It is respectfully stated that to determine whether the petitioner received SMS
alerts on her mobile phone containing the aforementioned SIM Card, it is
essential to obtain information from Bharti Airtel Limited, the
Telecommunication Company, which issued the SIM Card registered in her
husband's name. Furthermore, it is submitted that a thorough police investigation
involving the Bharti Airtel Ltd. would reveal whether the petitioner was a victim
Page No.# 6/11
of SIM swapping or SIM cloning by miscreants. To rectify the aforementioned
mistakes oversights, the petitioner now seeks to amend the writ petition to
include the concerned authorities of the 'Bharti Airtel', the
telecommunications company, as respondents in the W.P.(C) No. 6523/2023.
(iii) After the paragraph no. 9 and before the paragraph no. 10 at Page No. 13 of the
Writ Petition, the following new Paragraph No. 9 A shall be added:
"9A. That the petitioner states that: there is a probability that the
petitioner may have been targeted by a SIM swapping or SIM
cloning attack, a type of identity theft that exploits vulnerabilities in
mobile network security. A thorough investigation involving Bharti
Airtel Ltd. if directed may uncover whether the petitioner was
indeed a victim of SIM swapping or SIM cloning by malicious -
individuals. The concerned authorities of Bharti Airtel Ltd. are
being made parties to this writ petition. Bharti Airtel Ltd. can
provide this Hon'ble Court as well as the police authorities with
crucial information regarding: whether the petitioner received
timely SMS alerts from the banks concerning the fraudulent
UPI transaction on her mobile phone containing the
aforementioned SIM Card. Specifically, Bharti Airtel Ltd. can
confirm the exact date and time if the petitioner received these
SMS alerts in her mobile phone containing the aforesaid SIM
Card. To ascertain this information, it is essential to obtain records
from Bharti Airtel Ltd., the telecommunication company that issued
the SIM Card used by the petitioner at the relevant point of time.
While the petitioner does not seek any relief from the respondents 7
& 8, those concerned authorities of the Bharti Airtel Ltd. may
provide necessary facts from their system records, shedding light
on the matter by filing an affidavit."