HC Writ Ex service man extended benefits
IN THE HON'BLE HIGH COURT OF TN AT CHENNAI
CWP No:_____ of 2004
Petitioner
Versus
Respondents
CIVIL WRIT PETITION UNDER ARTICLE 226/227 OF THE CONSTITUTION OF INDIA FOR APPROPRIATE WRIT, ORDER OR DIRECTIONS TO THE RESPONDENTS
Chennai
Petitioner
______
Through, Advocate
Respectfully Sheweth;
(1) That your Lordship's humble petitioner is a citizen of India and on the grounds hereinafter mentioned is entitled to file and maintain the present writ petition before this Hon'ble Court.
(1) That __
GROUNDS
(2) That the petitioner is invoking the extra-ordinary jurisdiction of this Hon'ble court and seeking indulgence on the following grounds amongst other each one of which is without prejudice to and independent of other: -
(a) That such an act of omission and commission on the part of the respondent whereby they have __, is illegal, arbitrary, malafide, discriminatory, and against the well-established principles of natural justice as well as violative of the mandatory provisions of the Constitution of India.
(b) That __
(c) That the impugned act of the respondent is against the well settled principles of law laid down by the Hon'ble Supreme Court and this Hon'ble court in catena of cases.
(3) That the petitioner has no other speedy and efficacious remedy available except to approach this Hon'ble court by way of the present writ petition.
(4) That the petitioner has not filed any other writ petition on same or similar grounds either before this Hon'ble court or before the Supreme Court of India.
(5) That the petitioner, therefore, prays that an appropriate writ, order or directions be issued for the following reliefs:-
(a) Quash the impugned order __;
(b) Direct the respondents __
(c) Direct the respondents to produce all the relevant records along with reply for perusal by this Hon'ble court;
(d) Allow the cost of this writ petition to the petitioner, and;
(e) Allow such other relief or pass such other orders as deemed fit and proper in the facts and circumstances of the case in favour of the petitioner and justice be done.
AND FOR THIS ACT OF KINDNESS, THE HUMBLE PETITIONER AS IN DUTY BOUND, SHALL EVER PRAY.
Chennai
Applicant
______
Through, Advocate
IN THE HON'BLE HIGH COURT OF TN AT CHENNAI
CWP No:_____ of 2004
Petitioner
Versus
Respondents
Affidavit in support of the Civil Writ Petition under Articles 226/227 of the Constitution of India.
I, _____ , do hereby solemnly affirm and declare as under:-
1. That the accompanying writ petition has been prepared under my instructions.
2. the contents of paras 1 to ______ of the accompanying writ petition are correct and true to the best of my knowledge.
3. That I further solemnly affirm and declare that this affidavit of mine is correct and no part of it is false and nothing material has been concealed therein.
Affirmed at Chennai this the _____ .
Deponent
IN THE HON'BLE HIGH COURT OF TN AT CHENNAI
CMP No.:_____ of 2004 in CWP No:_____ of 2004
Petitioner/Applicants
Versus
Respondents/Non-Applicants
Application Under Rule 2 of the Writ Rules for dispensing with Seven days notice of motion
Respectfully Sheweth:
1. That the petitioner/applicant has filed the above mentioned writ petition in this Hon'ble court.
2. That on perusal of the allegations made in the writ petition and the documents attached therewith it is evident that the matter is of urgent nature and dispensing with of seven days notice is essential in the interest of justice.
3. It is, therefore, prayed that this application may be allowed and seven days notice of motion dispensed with and writ petition be listed immediately.
Chennai
Applicant
______
Through, Advocate
IN THE HON'BLE HIGH COURT OF TN AT CHENNAI
CMP No.: ______of 2004 in CWP No:______ of 2004
Petitioner/Applicant
Versus
Respondents/Non-Applicants
Affidavit in support of the application under Rule 2 of the Writ Rules.
I, ______, do hereby solemnly affirm and declare as under: -
1. the accompanying application has been prepared under my instructions.
2. the contents of paras 1 to 3 of the accompanying application are correct and true to the best of my knowledge.
3. I further solemnly affirm and declare that this affidavit of mine is correct and no part of it is false and nothing material has been concealed therein.
Affirmed at Chennai this the ______.
Deponent
IN THE HON'BLE HIGH COURT OF TN AT CHENNAI
CMP No.: ______of 2004 in CWP No: ______of 2004
Petitioner/Applicant
Versus
Respondents/Non-Applicants
Application Under Section 151 of CPC for Ad interim orders
Respectfully Sheweth:
1. That the petitioner/applicant has filed the above mentioned writ petition in this Hon'ble court.
2. That on perusal of the allegations made in the writ petition and the documents attached therewith it is evident that the petitioner/applicants have prima facie a very good case in their favour and the writ petition is likely to succeed. The Balance of Convenience is in favour of the petitioners/applicants.
3. That the interest of justice demands that during the pendency of the writ petition __
4. It is, therefore, prayed that this application may be allowed and __ in the interest of justice. Such other orders may also be passed in favour of the petitioners as deemed fit and proper by this Hon'ble court in the facts and circumstances of the case.
Chennai
Applicant
______
Through, Advocate
IN THE HON'BLE HIGH COURT OF TN AT CHENNAI
CMP No.: _____ of 2004 in CWP No:_____ of 2004
Petitioner/Applicant
Versus
Respondents/Non-Applicants
Affidavit in support of the application Under Section 151 of CPC
I, _____, do hereby solemnly affirm and declare as under: -
1. That the accompanying application has been prepared under my instructions.
2. That the contents of paras 1 to 4 of the accompanying application are correct and true to the best of my knowledge.
3. That I further solemnly affirm and declare that this affidavit of mine is correct and no part of it is false and nothing material has been concealed therein.
Affirmed at Chennai this the _____.
Deponent
BEFORE THE HON'BLE HIGH COURT OF TN AT CHENNAI
Case No: _______ of 2004
Petitioner
VERSUS
Respondents
KNOW ALL TO whom these presents shall come that I/We _______ the above named __PETITIONER/RESPONDENT do hereby appoint: - ______________ to be the advocate for the __ PETITIONER/RESPONDENT in the above mentioned case, to be all following acts, deeds and things or any of them that is to say:
1. To act, appear and plead in the above mentioned case in this Court or any Court in which the same may be tried or heard in the first instance or in Appeal or Letters Patent Appeal or Review or Revision or execution or in any other stage of its progress until its final decision.
2. To present Complaints, Pleadings, O.A., M. A. Appeals, Letters Patent Appeals, Petitions for Appeal to High Court/Supreme Court, Cross-objections or Petition for execution, review, revision withdrawal compromise or other petitions or affidavit or other documents as may be deemed necessary or advisable for the prosecution of the said case in all it's stages.
3. To withdraw or compromise the said case or submit to arbitration any difference or disputes that shall arise touching or in any manner relating to the said cause.
4. To receive moneys and grant receipts thereof and to do all other acts and things which may be necessary to be done for the progress and in course of the prosecution of the said case.
5. To employ and instruct any other Legal Practitioner authorizing him to exercise the powers and authorities hereby conferred on the Advocate whenever he may think fit to do so.
AND I/We hereby agree to ratify whatever the advocate or his substitute shall do in the premises.
AND I/We hereby agree not to hold the advocate or his substitute responsible for the result of the said cause in consequence of his absence from the court when the said cause is called up for hearing.
AND I/We hereby agree that in the event of the whole or any part of the fee agreed by me/us to be paid to the advocate remaining unpaid he shall be entitled to withdraw from the prosecution of the said cause until the same is paid.
IN WITNESS WHEREOF I/We here up to set my/our hands to these presents the contents of which have been explained to me/us and understood by me/us the ______.
Accepted
Advocate Client
