Hemaltha and Othr 6
Hemaltha and Othr 6
Hemaltha and Othr 6
… Petitioners
AND
AFFIDAVIT
1. I am the 1st petitioner herein and as such well acquainted with the facts of the
case. I am deposing this affidavit on behalf of myself and 2 nd, 3rd, 4th, 5th and 6th
petitioners as I am authorized to do so. I respectfully submit that since the cause of
action of all the petitioners herein is one and the same and hence, we are filing this
single Writ Petition for and on behalf of all our petitioners. However, Separate court
fee is paid on behalf of each petitioner herein, as per the Writ Rules.
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2. It is humbly submitted that the present writ petition is filed aggrieved by the
action of the 3rd and 4th respondents in orally directing the petitioners not to attend
their duties as Village Organizer Assistants of their respective villages without
issuing any notice to the petitioners under political involvement as illegal, arbitrary
and violative of Principles of Natural Justice.
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7. It is submitted that as matter stood thus, all of a sudden, the 3 rd and 4th
respondent without issuing any notice, orally instructed me and other petitioners not
to attend our duties as Village Organizer Assistants (VAO). We have requested the
3rd and 4th respondent several times for the reason, but there is no reply from him.
Despite resolutions were passed by our respective Gram Panchayats to continue us
as Village Organizer Assistants (VAO), under the political pressure and political
involvement, the 3rd and 4th respondent has orally instructed us not to attend out
duties, without issuing any notice by violating the Service Rules and Procedure.
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9. In view of the above, the Petitioners left with no other alternative efficacious
remedy, except to approach this Hon’ble Court under Article 226 of the Constitution
of India.
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10. The Petitioners have not filed any other writ or proceedings in any court of law
with regard to the above cause of action against the respondents herein and to the
best of their knowledge, no writ or proceedings are pending in any court of law
except to the extent stated above.
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11. It is therefore prayed that this Hon’ble Court may be pleased to issue a Writ,
Order or Direction more particularly one in the nature of Writ of Mandamus declaring
the action of the 3rd and 4th respondents in giving oral instructions to the petitioners
not to attend their duties as Village Organizer Assistants in their respective villages
without issuing any notice to the petitioners under political involvement as illegal,
arbitrary and violative of Principles of Natural Justice and violative of Articles 14 and
21 of Constitution of India and consequently direct the 3 rd and 4th respondent not to
restrain the petitioners from discharging their duties as Village Organizer Assistants
(VAO) in in Venkatachalam Mandal, SPSR Nellore District respectively and pass
such other order or orders as this Hon’ble Court may deem fit and proper in the
circumstances of the case.
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12. It is also just and necessary that this Hon’ble Court may be pleased to direct
the 3rd and 4th respondent not to restrain the petitioners from discharging their duties
as Village Organizer Assistants (VAO) in Edagali Gram Panchayat and other Gram
Panchayats respectively pending disposal of the above Writ Petition and pass such
other order or orders as this Hon’ble Court may deem fit and proper in the
circumstances of the case.
BEFORE ME
ADVOCATE ∷ AMARAVATHI
VERIFICATION STATEMENT