In an affidavit filed before a bench of Chief Justice G Rohini and Justice R S Endlaw, the woman pleaded for "reinforcement" of an interim order of the court to the Delhi government to provide the residents of Motia Khan shelter home with a designated ambulance for pregnant women who require lab investigations or delivery services.
The affidavit, filed through counsel Abhiti Gupta, said that the shelter home lacked adequate toilets, bathing area and kitchen facilities.
"Without access to adequate services these children often face the same fate as their mothers being homeless, begging for money, and victimisation...," the affidavit said.
It said the Motia Khan shelter still needs improvement, especially in hygiene, privacy and access to government schemes for children and pregnant and lactating women.
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It has also said, "Order be issued to Delhi Urban Shelter Improvement Board and Department of Health and Family Welfare of Delhi government to conduct an assessment and create a plan to address widespread inadequate access to the government entitlement schemes including widow pension, old age pension and the Ladli scheme."
She has alleged her daughter died after inadequate access to quality delivery services forced her to deliver on the balcony of the shelter home.
Motia Khan home first opened in 2011 and today remains unfit for habitation, the affidavit submitted.
On February 1, 2013, the high court had directed the authorities to improve the living condition at the home.