SEQUEL 2: Armed Forces (a Legend of Patriotism) vs. Corrupted Justice Delivery System, etc

IMMEDIATE

Date: 10.11.2017

To

1) H.E. Shri Ram Nath Kovind, President of the Republic of India

And Supreme Commander of Armed Forces of India

Rashtrapati Bhavan, President’s Estate, New Delhi-110004

2) Hon’ble Shri Narendra Damodardas Modi, Prime Minister of India

7 Lok Kalyan Marg, New Delhi-110011

3) Hon’ble Chief Justice Dipak Misra, Chief Justice of India

5 Krishna Menon Marg, New Delhi-110003.

Your Excellency/ Sir/ My Lord,

SUB: APPLICATION BY INDIAN WAR-VETERAN FOR IMMEDIATE & EFFECTIVE REDRESS OF THE GRAVE MISCARRIAGES OF JUSTICE ARISING FROM GROSS BREACH OF ‘RESTATEMENT OF VALUES OF JUDICIAL LIFE’ AND OF COUNTRY’S CONSTITUTION & LAWS AS ALSO OF THE UNIVERSALLY APPLICABLE JUDICIAL MAXIMS, BY CERTAIN JUDICIAL OFFICERS WHO -- IN ABSENCE OF EFFECTIVE & TIMELY REMEDY AGAINST JUDICIAL MALPRACTICES -- CONSIDER THEMSELVES ABOVE THE SUPREME LAW AND, THUS, PASS WITH IMPUNITY UNLAWFULLY MOTIVATED JUDGMENTS & ORDERS. 

1. Further to my Application dated 18.10.2017 -- regarding my Writ Petition (Criminal) No.xxx which was, in the absence of timely intervention by Constitutional Authorities to whom my said Application was addressed, was decided on 31.10.2017 by Ld. Division Bench No.x of Allahabad High Court (… Bench) in a manner that will shock the conscience of Intellectuals.

2. The Guiding words, worth being etched in Gold, of Hon’ble Supreme Court in M S Ahlawat vs. State of Haryana & Anr [cited as 1999 (6) SCALE 648] read as under:-

“To perpetuate an error is no virtue but to correct it is a compulsion of judicial conscience.”

Regulation No.26 (3) of Consumer Protection Regulations 2005, framed by the National Consumer Disputes Redressal Commission with the previous approval of the Central Government (these Regulations were placed before both Houses of Parliament under Consumer Protection Act 1986 and, moreso, the National Commission comprises of, inter alia, retired Hon’ble Supreme Court Judges) -- lays down that:-

The Consumer Forum shall give proper respect and courtesy to the parties who appear in person and shall provide separate accommodation in the Hall for the convenience of the parties. 

It is now for your goodselves to determine -- in the facts, circumstances & law of the instant case -- as to whether theour Judiciary has lived up to its above-cited words in the above Crl Writ Petition (W.P., for short)?

2. With great respect, there has apparently been grave failure of ‘Justice Delivery System’ in India in the instant matter, in that:-

a) Despite advance knowledge of imminently likely grave miscarriage of Justice, the same was allowed to occur, in the first place, by powers whose Duty or Dharma it is to prevent such Miscarriages -- Bhisham Pitamah & Dronacharya were punished for their unforgivable sin of remaining moot witnesses to the acts of inhumanity perpetrated by the Kaurvas in the former’s presence (Bhisham Pitamah & Dronacharya were imbued with the power to prevent the Kaurvas, and were also the most powerful warriors of the times).

It is pertinent here to mention an anecdote from Mahatma Gandhi’s life:-

A woman approached Shri MK Gandhi with a request to advise her little son who used to over-eat sugar; Mahatama asked her to come again the next week -- although he knew that she lived very far off. On her 2nd visit to Mahatma, the latter patiently advised that lady’s son about the adverse effects of taking too much sugar. The lady then asked Mahatma as to why he could not give the same advice earlier, instead of making her to travel all over again? The Mahatma truthfully replied, “I, too, used to eat too much sugar; so, I had to first reform myself before being able to convincingly advise your son.” This little anecdote conveys a big lesson in that:-

Empty words -- inconsistent with the speaker’s own behaviour, sound hollow and become unconvincing to the listeners.

Hence, as a corollary of the aforesaid two great historical & mythological Lessons, with what face are we going to argue before Hon’ble International Court of Justice (ICJ, for short) to the following effect when our own War-Veterans are being ill-treated and mala fide denied Justice in our own Country by some of our Courts, and the latter repeatedly cause Miscarriages of Justice  -- that are not bona fide errors of omission or commission but pre-conceived & well-calculated acts motivated by quid pro quos (with great respect, how such ‘black-sheep’ get through the ‘Selection Process’ is a matter to be seriously investigated by all the VVIP-Addressees above in consultation with all such Intellectuals as are demonstrably Patriotic, like the Applicant herein):-

That another Country’s Courts failed to do Justice to Kulbhushan Jadhav (an Indian ex-Naval Officer who is not even a War-Veteran) under a ‘Summary & in-camera Procedure’ which is probably prescribed in its Municipal Laws (Constitution & statutory Law) especially when that Country’s own citizens have also been subjected to the same very trial-process as was followed in the case of Shri Kulbhushan Jadhav ji, and such convictions were also upheld by that other Country’s own Supreme Court -- as per information available in ‘public domain’ on the World-Wide Web?

Will the World at large believe our above & similar arguments before the ICJ, IF the International Media comes to know the unpalatable facts about judicial proceedings that are taking place in our own Country -- 15 days notice-period stated in my previous Application is over, please? Has the Hon’ble President, Prime Minister and Chief Justice of India cared to protect the ‘Basic Human Rights’ of our own War-Veterans (for example, the Applicant herein) in India itself? It is time for those who are ‘Commissioned for Life’ and all other Patriotic Indians to rise up and strengthen the hands of Shri Narendra Modi ji to rid our Country of Corruption and corrupt individuals -- which is well-nigh impossible for the Hon’ble Prime Minister alone to do (as the last 3 years History of his rule has shown) as long as any corrupt public official in the Country’s Judicial System remains in such a seat as he, in the first place, did not temperamentally & intellectually deserve.

b) With great respect, on 31.10.2017 (supra) Ld. Presiding Judge of Division Bench No.x (at Allahabad High Court … Bench) was permitted to deliver a Judgment & Order which, as is palpably apparent on the face of the record, suffers from inter alia several grave violations of the Constitutional Law, statutory Law and the Law laid down by Hon’ble Supreme Court of India itself, as also of the Universally accepted Judicial Maxims; moreso, the said Judgment & Order suffers from gross inconsistencies inter sé the Orders that were passed by previous Division Benches (DBs, for short) in the same very matter -- WHEREAS Hon’ble Supreme Court has, vide para 24 of P Suseela vs.UGC [cited as 2015 (3) SCALE 726], passed strictures against the same very High Court upon the latter’s different Division Benches passing mutually inconsistent Orders in similar matters. The said Judgment of Hon’ble Supreme Court was before the aforesaid DB No.x also; moreso, the said Judgment of Hon’ble Supreme Court was also alluded to by a previous Division Bench which, by its Order dated 29.09.2016, had permitted the Applicant herein “liberty” to file a Review Petition in the same very matter. Relevant extracts of Order dated 29.09.2016 are reproduced below:-

“Contention of the petitioner is that the aforesaid order passed by this Court is inconsistent with the law laid down by the Hon’ble Supreme Court.

…                                                  …                                                      …

… liberty is given to the petitioner to move a review petition.”

The Judgment in P Suseela’s case holds, inter alia, as under:

i) UGC’s Regulations which have to be pre-approved by Central Government and are laid before the two Houses of Parliament, cannot be superseded even by UGC’s own Resolutions.

As a corollary, Ph.D. Ordinances of local Universities cannot be inconsistent with UGC’s Regulations.

In any case, the Applicant’s contention was upheld even by Respondent University -- which revised its Ph.D. Ordinance to the effect that Guides will be allotted only after a Candidate is Admitted to Ph.D. as a ‘student’, and NOT before. The said Revised Ordinance is also on record of High Court.

ii) UGC’s NET is a standardised measure of Merit at the National level and, thus, it is more reliable that the Ph.Ds. awarded by local Universities.

As a corollary, candidates who pass a locally conducted Test by individual University cannot be selected over & above the NET-qualified candidates. 

Is it, therefore, not a grave Travesty of Justice for the subsequent DB No.x to impose, vide impugned Order dated 31.10.2017, Rs.5,000 as “costs” upon the Applicant for his complying with the aforesaid written Order of the previous DB in the same very matter?

Is it just, fair & reasonable to make the humble Applicant -- who is already mala fide aggrieved by the Respondents & the High Court -- to suffer another lengthy round of litigation by way of Special Leave Petition at great financial costs to him, WHEREAS the guilty ‘public officials’ laugh at their ability to manipulate at will the Executive & Judicial Organs of the State since our present system does not punish the guilty judicial officers?

c) In a Criminal Writ Petition, Ld. DB No.x even applied the Code of Civil Procedure to achieve its pre-determined/ pre-decided ends, as under:-

“The applicant/petitioner has neither been able to show any error apparent on the face of the record nor has been able to show any other good reason to entertain this review application as envisaged under Section 114 of the C.P.C., which reads as follows …

…                                                  …                                                      …

Order XLVII Rule 1 CPC further lays down …”

WHEREAS it was pointed out by the Applicant both in writing & orally that:-

A Ld. DB had, vide Order dated 27.04.2017 dismissed a Criminal Writ Petition that had already been disposed of in the Applicant’s favour vide its Order dated 19.08.2010, without even restoring the said Writ Petition back to its original position -- WHEREAS Section 362 of Cr.P.C. bars any change in the previous Final Order except correcting the typographical or clerical errors. Moreso, the latter DB had dismissed it after perusing it only for 85 seconds -- that, too, when the averments made in the Writ Petition had already gone as admitted under the Law of Pleadings (my previous Application dated 18.10.2017 to your goodselves refers). In addition, Order dated 27.04.2017 repeated the same grave errors of Law as were severely deprecated by Hon’ble Supreme Court vide para 24 of P Suseela’s case (supra). The Applicant herein had argued all these points before Ld. DB No.x on 09.10.2017, and also orally stated that he was not arguing on Writ Petition unless it was first restored -- because unless it was restored, it could not be said to be before the Court for adjudication.

In any case, IF Ld. DB No.x could, without the assistance of any Counsel for Respondent No.2, by itself find -- through a fishing inquiry -- paras 7-9 of the Counter-Affidavit of the said Respondent University, then it is reasonable to expect Ld. DB No.x to have perused the corresponding paras in Petitioner’s Rejoinder and Crl MPs (including Crl MPs for initiating suo motu Contempt of Court Proceedings against Registrar etc of Respondent University).

d) The following misplaced words in the impugned Judgment dated 31.10.2017 show that Ld. DB No.x was still nursing, at the time of dictating Judgment & Order dated 31.10.2017 (i.e. after 22 days) the grouse that the Applicant herein (Petitioner therein) had not repeated in the body of the Crl Writ Petition what he had already specifically stated in the List of Dates & Events and the same was also adopted as a part & parcel of the Crl Writ Petition and, moreso, his supporting Affidavit also affirmed the truth of the contents of List of Dates & Events -- which had led the said Ld. DB to shout, for no rhyme or reason, at the humble War-Veteran (as stated in my previous Application dated 18.10.2017 addressed to your goodselves):-

“He has leveled these allegations in the list of dates and events but no averment has been made anywhere in the writ petition.”

WHEREAS, with great respect, the Truth is that the first unnumbered para at page 7 of the Crl Writ Petition reads as under:-

“The facts in this case are briefly stated in the ‘List of Dates & Events’; contents of this List are supported by the accompanying Affidavit. The humble Petitioner respectfully seeks the indulgence of this Hon’ble Court to read the same as part & parcel of this para.” [Emphasis already supplied]

And the first unnumbered para at page ‘C’ of List of Dates & Events states:-

“Thereafter, Respondent No.1 orally demanded a Bribe of Rs. 3 lakhs …”

And, in addition, para 2 of the Supporting Affidavit reads:-

“The contents of paras 1-8 at pages 1-9 of the accompanying Writ Petition and CMP and at pages A to C of the List of Dates & Events are true …”

It is pertinent to mention here that direct evidence of demand for Bribe is seldom available, and the Ld. Courts rely upon Circumstantial Evidence -- in the instant matter ample Circumstantial Evidence is available; for example:-

Prof JVV, the then Dean of the Faculty of Commerce (under which Department of Business Administration also falls), was found by Uttar Pradesh State Vigilance Establishment to have illegally manipulated the Marks in the Answer-sheets of certain M.Com. students; the said Findings were approved by the Academic Council of yyy University. Apparently the said Dean was not enhancing the Marks of the concerned students out of ‘charity’. The News-Reports about the said Corruption are also on record in the above Writ Petition (W.P., for short).

In addition, several other News-Reports of various Crimes & Corruption are also on record in the above Criminal Writ Petition, to cite a few of these:-

i) Plagiarism by a Professor of Department of Business Administration under the same Faculty of Commerce -- Respondent No.1 was the Head of the same Department, and the Professor who was found guilty of plagiarism by the Respondent University itself, was one of the Guides who had substantially interfered in the administration of Justice in the above Crl Writ Petition;

ii) Corruption in a Hostel Mess whose Warden is a Teacher of the Respondent University;

iii) Undue long delay between the Date (21.02.2009) of Recommendations for Admission made by Departmental Research Committee of the Department of Business Administration (whose Head of Department was Respondent No.1) and the Meeting of the Faculty Board of Commerce on 15.02.2010;

iv) Petitioner’s Application dated 06.09.2009 addressed to Vice-Chancellor and Dean of Faculty of Commerce, about corruption & nepotism etc during Ph.D. Admissions;

v) Withdrawal by Respondent No.1, without prior permission from Vice-Chancellor for a change in Guide and also behind the back of the Petitioner, WHEREAS the Minutes of the Meeting of the Faculty Board of Commerce as on 15.02.2010 do not show any valid reason for such withdrawal -- the only reasons on which change in Guide is permissible are given in the then applicable PhD Ordinance which is on record in the above Crl Writ Petition;

vi) Filing by the Registrar of Respondent University (Respondent No.2) of a false, fabricated & misleading Counter-Affidavit dated 13.05.2010 -- which also suppressed crucial information, as already stated on record;

vii) Concerted refusal, without assigning any reason at all, by 7 Teachers -- out of whom 4 had themselves earlier made the Recommendation, as Members of Departmental Research Committee of Department of Business Administration for Petitioner’s Admission to Ph.D.;

viii) All the averments made in the Crl Writ Petition against Respondent No.1 about the said Bribe, went as admitted under the Law of Pleadings (supra).

It is pertinent to add that it was under the aforesaid Dean that the Applicant’s Guide (who was then Head of Department of Business Administration) had demanded a Bribe from the Applicant for the latter’s smooth-sailing through the entire process (that is to say, from Ph.D. Admission to Ph.D. Degree) but had mala fide denied the Applicant Admission to Ph.D. -- despite the Applicant being, admittedly on record, the most qualified candidate. Immediately after the aforesaid Bribe was demanded, the Petitioner moved an Application dated 06.09.2009 to the Vice-Chancellor of Respondent University (with a Copy to Dean of Commerce Faculty) -- copies of the same were received by the Offices of Vice-Chancellor and Dean of Faculty of Commerce, and Receipts thereof were endorsed by the concerned Offices on the Petitioner’s Copy (the said Application is annexed at pages 13-16 of Crl Writ Petition itself, and the aforesaid Receipted Copy thereof was also shown to Hon’ble DB (Presided over by Justice UNS) before the Crl Writ Petition was disposed of in the year 2010; the said Receipted Copy was again shown to the aforesaid Hon’ble DB during the hearing of Crl MP No.zzz/2014 -- which was moved for suo motu initiating Contempt of Court Proceedings against, inter alia, Registrar of Respondent University since the said Registrar was the Affiant who had affirmed & filed the false & misleading Counter-Affidavit dated 13.05.2010 on behalf of Respondent No.2. The same was also pointed out to Ld. DB No.x on 09.10.2017 vide page 35 of Crl MP No.yyy/2010.

 With great respect, in the aforementioned premises, there was no occasion at all for Ld. DB No.x to shout at the War-Veteran (Applicant herein), or to hold that the Applicant did not satisfy the said Ld. DB -- WHEREAS the Applicant had specifically pointed out that he had prayed for a CBI Inquiry into the charge of corruption against Respondent No.1 and further that, in any case, the averments made against the said Respondent in the Crl. W.P. had already gone as admitted in Law under the well-settled Law of Pleadings read with Rule 4 (2nd unnumbered para), Chapter-XXII of Allahabad High Court Rules. Moreso, he was not arguing on the Crl Writ Petition since it was not restored till then.e) Ld. DB No.x did not adjudicate & determine as to whether there was any valid criterion, prescribed in Respondent University’s Ph.D. Ordinance, for refusing Admission in Ph.D. to the Petitioner -- despite his being the most qualified candidate (details of his qualifications vis-à-vis Hon’ble Supreme Court’s observations in P Suseela’s case on the importance of UGC’s NET are already on record) as well as an NET (JRF/SRF) which is the highest category of UGC’s NET; it is submitted that any criterion that is inconsistent with Regulation 12 of UGC’ Regulations 2009, is NOT a ‘valid’ criterion since Respondent University’s Ph.D. Ordinance has not been ‘assented’ to by the President of the Republic of India.

f) It is pertinent to add that when the Applicant moved a Crl Review Petition against Order dated 19.08.2010 on the ground, inter alia, that the said Order was passed per incuriam of Regulation 12 of the UGC’s Regulations 2009 (supra) which did not permit Respondent University to allow Candidates and Teachers to mutually settle the ‘Guides’ -- WHEREAS the aforesaid Order was, in effect, allowing them to do so even before the candidates were admitted as Ph.D. ‘students’), the Registry of the same High Court had declined to accept a Crl Review Petition in a Crl. Writ Petition on the ground of bar of Section 362 of Cr.P.C. Hence, the Applicant moved a Crl MP/ Application for Clarification/ Modification of Order dated 19.08.2010, and also added therein a prayer-clause for suo motu Review by Hon’ble High Court under its inherent powers on the ground that Cr.P.C. is inapplicable to Writ Petitions (infra) and that the statuary bar u/s 362 Cr.P.C. applies only to such Criminal Proceedings as are a continuation of the criminal proceedings from the courts below, i.e. such criminal proceedings as have come before the High Court by way of an Appeal or Revision or u/s 482 of Cr.P.C., etc.

Subsequently, Hon’ble Supreme Court held in State of Punjab vs. Devinder Pal Singh Bhuller and Ors [cited as (2011) 14 SCC 770] that any Review of Judgment/ Order, passed in a Criminal matter, by a High Court is barred by Section 362 of the Cr.P.C. -- however, the said Judgment is silent as to whether the statutory bar applies to Writ Petitions under Article 226 of the Constitution of India?

g) Assuming but not admitting that the Petitioner was allowed to argue “for quite some time” (instead of only 10 minutes -- vide my previous Application dated 18.10.2017 addressed to your goodselves) then why did Ld. DB No.x fail to cite, in its impugned Judgment dated 31.10.2017, even one or two such Issues as were allegedly argued by him and, moreso, why did Ld. DB No.x not determine those Issues? For example, there is not even a whisper about the proven cases of Corruption & Plagiarism against the then Dean of Commerce Faculty and a Teacher of Department of Business Administration, respectively.

With great respect, the said Ld. DB did not examine and adjudicate upon any criterion on which the Applicant, despite being the most qualified candidate, was not admitted to Ph.D. -- WHEREAS candidates far less qualified than him were admitted, especially when the information that was earlier directed to be produced by a previous Hon’ble DB, vide Order dated 08.07.2010, was required to show to the Hon’ble Court the comparative position between the ‘selected’ candidates and ‘rejected’ candidates, because this would be an additional Circumstantial Evidence as to the demand for Bribe.

On the other hand, none of the Respondents appeared on 09.10.2017 despite receipt of Notice from High Court’s Registry, and none of the Respondents filed any Counter-Affidavit to any of the two Review Petitions filed by the Petitioner -- in such situations, the fair & impartial Courts normally proceed ex-parte against the Respondents or, at least, treat the written defense of the Respondents as ‘not pressed’. Yet Ld. DB No.x, instead of proceeding ex-parte or treating the defense of Respondents Nos. 1 &2 as not pressed, proceeded to act in defense of the said two Respondents -- especially on the points on which they had already been cornered -- by relying upon the Counter-Affidavit that was filed by Respondent No.2 in the year 2010 (i.e. before the Crl Writ Petition was disposed of) BUT without adverting to the rebuttal of the said para of Counter-Affidavit, in corresponding para of Petitioner’s Rejoinder-Affidavit.  

With great respect it is, thus, palpably apparent on the face of record that Ld. DB No.x desired, without taking the risk of restoring the Crl Writ Petition to its original position, to pass such observations on those crucial points on which Respondents Nos.2 & 1 had already been cornered in the Writ Petition and allied Crl MPs -- that is to say, the Ld. DB No.x seems to have gone by a pre-decided agenda to screen the said Criminal Offenders and also to overawe the Petitioner into silence by shouting at him and not allowing him to argue for more than 10 minutes (supra). Moreso, Ld. DB No.x wrote its Judgment in such a way [i.e. by suppressing all the evidence that went in Petitioner’s favour, and selectively & unlawfully citing such material as was impermissible (supra) from the aforesaid Counter-Affidavit as, if torn out-of-context, went against the Petitioner] -- in the knowledge that, in the event of paucity of time, Hon’ble Appellate Courts may only look at the impugned Judgment. 

h) The Applicant filed Crl Review Petitions Nos.aaa/2016 & bbb/2017 on, inter alia, the following legally sound Grounds:-

i) Hon’ble DB (Presided over by Justice SSC) not only orally advised the Applicant herein to file a Review Petition in the said Crl. Writ Petition, but also granted, vide Order dated 29.09.2016, “liberty” to file the same (supra); moreso, in the same Order his Lordship also alluded to Hon’ble Supreme Court’s aforesaid Judgment in P Suseela’s case (supra).

ii) With great respect, it appears that Judgment in Devinder Pal Singh’s case (supra) was probably passed in the context of criminal matters that reach the High Courts from the courts below (e.g. an “Appeal”) because such Appeals in Crl matters are a continuation of the proceedings of the courts below; hence, Section 362 of Cr.P.C. continues to apply to such extended proceedings before the High Courts. However, in Criminal Writ Petitions under Article 226 of the Constitution of India the provisions of Cr.P.C. do not ordinarily apply. In any case, this Question of Law of general public importance is not conclusively settled till date. In any event, Code of Civil Procedure is NOT applicable to Crl Writ Petitions [Expln. to S.141 CPC, Puran Singh vs. State of Punjab (SC) cited as 1975 AIR SC 1674].

iii) Criminal Review Petition No.bbb/2017 was filed because -- despite the Applicant’s Advance Application dated 24.04.2017 to the effect that his above-mentioned Writ Petition (for which no date had till then been fixed) be not listed during the period when he would be away to Delhi to appear before Hon’ble Supreme Court in matters in which dates had already been fixed by Hon’ble Supreme Court in advance, and the specific period during which his matters be not listed in the High Court was also stated therein, viz. from 25.04.2017 to 10.05.2017; but the above Crl Writ Petition was listed on the same very date on which the Applicant was on his legs before Hon’ble Supreme Court and, moreso, the Date of Hearing in the said Crl Writ Petition was not intimated to the Applicant in-Person in advance (it is the normal practice even in Hon’ble Supreme Court to intimate the date of hearing to the in-Person Litigants at least one month in advance) -- the Applicant produced, vide Crl Review Petition No.bbb, before the same Hon’ble DB as had passed impugned Order dated 27.04.2017, Hon’ble Supreme Court’s Order dated 02.03.2017 (by which next Date of Hearing was fixed as 27.04.2017, in advance) as well as his aforesaid Application dated 24.04.2017 alongwith an Affidavit of another Ld. Advocate. Hence, vide Order dated 25.07.2017, the said Hon’ble DB was pleased to issue Notice to all the four Respondents in the above Crl. Writ Petition, on the ground that no opportunity of hearing had been afforded to the Petitioner therein (Applicant herein). Thus, the said Review Petition was filed on the sound legal ground of violation of Universal Judicial Principle of audi alteram partem -- the Applicant was not given any opportunity at all to be heard before passing Order dated 27.04.2017 although Hon’ble High Court had prior notice of the likelihood of conflict of dates between the matters in Lucknow & Delhi.

It was pointed out in Crl Review Petition No.bbb that Judgment & Order dated 27.04.2017 passed by Ld. DB (Presided over by Justice SA) is a non-speaking Order and, hence, violates the Law repeatedly laid down by Hon’ble Supreme Court that all appealable Orders must be ‘speaking orders’ -- the same goes for appealable Judgments.

Clearly, Order dated 31.10.2017 -- imposing whopping costs of Rs.5,000 for having filed the said Review Petition No.bbb -- is ex facie inconsistent with Order dated 25.07.2017 that was passed by the previous Ld. DB.

i) Without first restoring the already disposed of Criminal Writ Petition to its original position, Ld. DB No.x has attempted to decide in the impugned Judgment dated 31.10.2017 certain facts in the aforesaid ‘disposed of’ Writ Petition, by relying upon para 7 of Counter-Affidavit filed by Respondent No.2 in the year 2010, without even adverting to the corresponding para, in rebuttal, contained in the Rejoinder-Affidavit, WHEREAS even a Clerk (‘Munshi’) of an Advocate with less than 5 years experience has enough legal knowledge that whenever ‘evidence’ is taken on ‘affidavits’, then the averments made in the Petition, Counter-Affidavit & Rejoinder-Affidavit are to be perused & weighed together and only then the Issues therein are adjudicated upon (i.e. determined). Moreso, it is a well-settled Law -- known even to an Advocate with only 1-2 years standing at the Bar -- that whenever any Party to a matter (case) fails to appear at the Final Hearing, then it is either proceeded ex-parte or all the averments made in its pleadings are treated as ‘not pressed’, unless it has filed Written Arguments, with an Advance Copy thereof having been served upon the Opposite Party. But in the above Crl Review Petition none of the four Respondents appeared to press their case on 09.10.2017, nor did they file any Written Arguments, nor was any Counter filed by them in response to the Notice served by the Registry of the High Court on the above Review Petition.

It is pertinent to add that vide Clause 15 of the then applicable Ph.D. Ordinance portions of Research already made in MBA/ M.Phil. can also be incorporated by the Ph.D. student in his Ph.D. Thesis. Moreso, vide Clause 8 of the said Ordinance even a Teacher who is not a Ph.D. but has done independent research, can be appointed as a Ph.D. Guide!

With great respect, Crl Writ Petition was decided in Petitioner’s favour on 19.08.2010 by Hon’ble DB (Presided over by Justice UNS); hence their Lordships’ judgment cannot be completely overturned/ superseded and costs imposed by a latter DB, viz. Ld. DB No.x.

j) Every intelligent person would readily appreciate that whenever numerous issues are involved in a case, then -- unless a Party Argues a point of law or fact at the time of ‘Final Hearing’ -- the Opposite Party is not called upon to rebut the same. Hence, in the interests of Justice, no fair & impartial court alludes to any such point, for the first time, in its Judgment & Order as has not been argued before it in the ‘open’ court -- because doing so will deny the affected Party proper opportunity to rebut the same. It is not known as to when, where & how any of the four Respondents argued paras 7-9 of the Counter-Affidavit of Respondent No.2 -- whether it was in Chambers behind the back of the Petitioner, or at Camp-Office (Residence) or at any Party hosted by Respondent University? A Party hosted by Respondent University and attended by some of Ld. Judges is cited in my previous Application dated 18.10.2017.

With great respect, such alarming ‘errors apparent on face of record’ and grave breach of Judicial Ethics not only cast serious doubts upon the efficacy of the present ‘Selection Process’ (i.e. Collegium System) that does not test even the basic legal knowledge of candidates before recommending their appointment (‘elevation’) as Judges of High Courts, but also erodes the trust & confidence of the general public in our ‘Justice Delivery System’.    

Some of the numerous other instances of mala fide & bias which are palpably apparent on the face of record in the impugned Judgment dated 31.10.2017, are respectfully given in para 3 below.

3. (i) While citing para 7 of Counter-Affidavit of Respondent No.2 as the Gospel Truth, the said Respondent was not even asked by Ld. DB No.x as to when, where and at what time the Petitioner had made the statements that are being falsely attributed to him in the said para? Moreso, the contents of the said para were rebutted vide Rejoinder-Affidavit. Hence, the said contents ought not to have been relied upon in the impugned Judgment dated 31.10.2017 without determining the facts-in-issue on the basis of the said Counter & Rejoinder.  

(ii) The following words in the impugned Judgment dated 31.10.2017 show that Ld. DB No.x was still nursing the grouse against the Applicant herein (i.e. Petitioner therein) for not again repeating in the body of the Crl Writ Petition what he had already stated in the List of Dates & Events and adopted as a part & parcel of the Writ Petition and, moreso, his supporting Affidavit also affirmed the truth of the contents of List of Dates & Events -- it was this grouse which led to said Ld. DB shouting at the humble War-Veteran (as stated in my previous Application dated 18.10.2017 addressed to your goodselves):-

“He has leveled these allegations in the list of dates and events but no averment has been made anywhere in the writ petition.”

WHEREAS, with great respect, the first unnumbered para at page 7 of the Crl Writ Petition reads as under:-

“The facts in this case are briefly stated in the ‘List of Dates & Events’; contents of this List are supported by the accompanying Affidavit. The humble Petitioner respectfully seeks the indulgence of this Hon’ble Court to read the same as part & parcel of this para.” [Emphasis already supplied]

And the first unnumbered para at page ‘C’ of List of Dates & Events states:-

“Thereafter, Respondent No.1 orally demanded a Bribe of Rs. 3 lakhs …”

In addition, para 2 of the Supporting Affidavit reads:-

“The contents of paras 1-8 at pages 1-9 of the accompanying Writ Petition and CMP and at pages A to C of the List of Dates & Events are true …”

It is pertinent to mention here that Prof. JVV, the then Dean of Faculty of Commerce (under which Department of Business Administration also falls) in the Respondent University, was found by Uttar Pradesh State Vigilance Establishment to have illegally manipulated the Marks in the Answer-sheets of certain M.Com. students; the said Findings were also approved by the Academic Council of Respondent University. Apparently the said Dean was not enhancing the Marks of the concerned students out of pure ‘charity’. The News-Reports about the said Corruption are also on record in the above Writ Petition (W.P., for short) alongwith several other News-Reports of various Crimes & Corruption (supra) that were committed in the Respondent University. And it was under the said Dean that the Applicant’s Guide (who was then Head of Department of Business Administration) had demanded a Bribe from the Applicant for the latter’s smooth-sailing through the entire process (that is to say, from Ph.D. Admission to Ph.D. Degree) but had mala fide denied the Applicant Admission to Ph.D. -- despite the Applicant being, admittedly on record, the most qualified candidate. And, hence, immediately after the aforesaid Bribe was demanded, the Petitioner made an Application dated 06.09.2009 to the Vice-Chancellor of Respondent University (with a copy to the said Dean) -- copies of the same were received by the Offices of Vice-Chancellor and Dean of Faculty of Commerce, and Receipts thereof were endorsed by the concerned Offices on the Petitioner’s Copy (the said Application is already annexed at pages 13-16 of Crl Writ Petition, and its Receipted Copy is also on record at page 35 of Crl MP No.yyy; the same was also pointed out to Hon’ble DB (Presided over by Justice UNS) before the Crl Writ Petition was disposed of in the year 2010. It was again shown to Ld. DB during the hearings of Crl MP No.ccc (which was moved for suo motu initiating Contempt of Court Proceedings against, inter alia, Registrar of Respondent University since the said Registrar was the Affiant who had filed false & misleading Counter-Affidavit dated 13.05.2010 on behalf of Respondent No.2) and Crl Review Petition No.bbb.

With great respect, in the aforementioned premises there was no occasion at all for Ld. Presiding Judge of DB No.x to shout at the War-Veteran, or to hold in impugned Judgment that the Applicant did not satisfy the Ld. DB, WHEREAS the Applicant had specifically pointed out that he had prayed for CBI Inquiry into the charge of corruption against Respondent No.1 and, in any case, the averments made against the said Respondent in the Crl. W.P. had already gone as admitted in Law under the well-settled Law of Pleadings read with Rule 4 (2nd unnumbered para), Chapter-XXII of Allahabad High Court Rules. To the specific query as to where the Bribe was demanded, it was replied that it was demanded in the Office of the said Head of Department (Respondent No.1) immediately before the Applicant moved the aforesaid Application dated 06.09.2009 addressed to Vice-Chancellor about corruption & nepotism (supra).

(iii) A Ld. DB had, vide Order dated 27.04.2017, dismissed Criminal Writ Petition that had already been disposed of in the Applicant’s favour vide Order dated 19.08.2010 passed by a previous DB, yet it was again dismissed without restoring the ‘disposed of’ Criminal Writ Petition back to its original position --   WHEREAS Section 362 of Cr.P.C. bars any correction other than a typographical or clerical error. Moreso, the latter DB had dismissed the Criminal Writ Petition after perusing it for 85 seconds -- that, too, when the averments made in the Writ Petition had already gone as admitted under the Law of Pleadings (my previous Application dated 18.10.2017 addressed to your goodselves, refers). Moreso, it was a non-speaking Order. The Applicant herein had argued these points before Ld. DB No.x on 09.10.2017, and also stated that he was not arguing the Writ Petition because it was not restored till then and, hence, it was not before the Ld. Court. With great respect, such mutually inconsistent Orders passed by different DBs were severely deprecated by Hon’ble Supreme Court in P Suseela’s case (supra).

(iv) Ld. DB No.x has relied upon the contents of paras 8-9 of Counter-Affidavit of Respondent No.2 (although it was not before Ld. DB No.x since the ‘disposed of’ Crl Writ Petition had not been restored by the said Ld. DB) which pertain to a matter that was stayed by Hon’ble Supreme Court on 16.04.2007 (i.e. long before the Crl Writ Petition was filed in the year 2010) and copies of the said Stay Order were also produced before Hon’ble DB (Presided over by Justice UNS) and taken on record; it was also pointed out in the corresponding paras of Rejoinder-Affidavit that the contents of the aforesaid paras of Counter-Affidavit were not only extraneous to the conditions ‘prescribed for admission to Ph.D.’ (i.e. prescribed in the relevant Ph.D. Ordinance) but also that such Orders passed in the said matter as went against the machinations of Respondent No.2 (e.g. Stay Order passed in the year 2007) had been deliberately suppressed in order to mislead the Hon’ble Court. Moreso, the sole purpose in citing those contents in its Counter-Affidavit, out-of-context, was to delay the judicial proceedings and also bias the minds of Hon’ble DB. Thereafter, no cognisance of the said contents was rightly taken by Hon’ble DB (Presided over by Justice UNS). It is most respectfully submitted that the aforesaid portions of pleadings were also pointed out to Ld. DB No.x on 09.10.2017, and their Lordships were requested to peruse the same on its own since they had permitted the Applicant herein only 10 minutes to argue a matter that ran into about 1,000 pages.

It is well-settled Law that the contents of any Judgment that has been stayed either by a Ld. Larger Bench or by Hon’ble Supreme Court, cannot be relied upon by any other Bench or by any High Court; and even if the matter is sub judice before a higher Forum, this fact ought to be mentioned while referring to the contents of the Judgment that is sub judice. With great respect, IF Ld. DB No.x could find, by a fishing inquiry, the contents of paras 7-9 of Respondent’s Counter -- unassisted by its Counsel (rather in his absence) -- then the Ld. DB could be reasonably expected to find out that the matter it was citing was stayed by Hon’ble Supreme Court, because the said Stay-Order was also in the same judicial file from which paras 7-9 were taken. It is respectfully submitted that the very fact that the Duty of a Counsel is to only “assist” the Court, means that the Duty to dispense Justice lies squarely upon the shoulders of concerned Court -- because judicial notice may be taken of the well-recognised fact that ‘Courts exist to do Justice’; in other words, Courts exist as long as they do Justice. 

Further that in the corresponding para of Rejoinder-Affidavit, the contents of paras 8-9 of the aforesaid Counter-Affidavit were denied as, inter alia, half-truths and mala fide suppression of the actual status, e.g. Stay-Order (supra).

(v) Vide Order dated 20.07.2010 Hon’ble DB (Presided over by Justice UNS) directed Respondent No.2 to produce all those documents whose copies had not been given by the said Respondent although the same were also demanded under the Right to Information Act 2005 -- the same are ‘public documents’ and, thus, accessible by general public. Moreso, even the UGC, vide Regulation No.5.6 of UGC’s Regulations 2016 (which came into force on 05.05.2016) mandates that the said information must be displayed on every University’s website. Hence, the following observations made in impugned Judgment dated 31.10.2017 are not only wholly inconsistent with the previous Orders (that were passed by another DB before the above Criminal Writ Petition was disposed of in the year 2010) but also violate the RTI Act 2005 as well as UGC’s Regulations 2016:-

“This Court feels that the applicant/petitioner did not have any statutory right to ask for entire information from the University through a writ petition.

Further no direction could have been issued to the respondent to submit all the documents in the possession of the opposite party no. 2, who is the Registrar of the University.” [Emphasis added]

With great respect, controversies before the courts are determined on the basis of facts & law, and not on the basis of feelings. Moreso, no Law has been cited by Ld. DB No.x to show that the previous Ld. DBs could not have issued a direction that the previous Ld. DBs had in fact, in their Wisdom, issued -- IF Ld. DB No.x still thinks that all the previous Hon’ble DBs are not as smart/ wise as Ld. DB No.x itself -- then, as held by Hon’ble Supreme Court, vide para 24 of P Suseela’s case (supra), Ld. DB No.x ought to have referred the matter to a Larger Bench.

(vi) Vide ratio laid down in Hon’ble Supreme Court’s Judgment in State of Punjab vs. Devinder Pal Singh Bhuller and Ors [cited as (2011) 14 SCC 770] Review of Judgment/ Order passed in a Criminal matter by a High Court is barred by Section 362 of Cr.P.C., yet upon the Oral Suggestion made during the hearing on 29.09.2016 and especially because of written liberty granted vide last un-numbered para in Order dated 29.09.2016 passed by Hon’ble Division Bench (Presided over by Justice SSC), the Petitioner moved a Review Petition No.aaa. Relevant para of the said Order is reproduced below:-

“However, liberty is given to the petitioner to move a review petition.”

[Emphasis added]

With great respect, it will be a Travesty of Justice IF one Ld. DB grants liberty to file a Review Petition, and yet another Ld. DB imposes whopping costs for complying with the Order of the former Ld. DB!

(vii) With great respect, without first restoring the disposed of Writ Petition, how could Ld. DB No.x go into its ‘merits’ -- that, too, to the extent of over-turning Orders which were passed by earlier DBs in the same Writ Petition?

(viii) Circumstantial evidence. Petitioner had prayed in the Criminal Writ Petition for a CBI Inquiry into the charge of Bribe, under the Prevention of Corruption Act 1988 against Respondent No.1. In the meanwhile, all the averments made in his Criminal Writ Petition went as admitted in Law under the Law of Pleadings read with Rule 4 (2nd unnumbered para), Chapter-XXII of Allahabad High Court Rules -- because Respondent No.1 failed to enter appearance and to file any Counter-Affidavit. Hence, instead of a CBI Inquiry, only a direction to local Police was needed to register an FIR against the said Respondent -- the same was prayed for vide Crl MP No.ddd.

Moreso, Hon’ble Supreme Court has opined that in Bribery cases it is difficult to collect direct evidence, unless money is paid and a raid is simultaneously organised by the Anti-Corruption Branch. In the alternative, an unbroken chain of circumstantial evidence may be relied upon by the Investigating Agencies. Details of some of the circumstantial evidence -- that the Petitioner, not being an Investigating Agency equipped with statutory powers, could himself collect -- are already given above; it is for the Investigating Agency to collect further evidence and produce the same before the Trial Court. With great respect, a High Court is NOT a Trial-Court in a case under Prevention of Corruption Act.

The relevant portions from List of Dates & Events were read out in court on 09.10.2017, too. Moreso, “corruption” includes not only financial transactions but also other favours/ advantages (e.g. admission of son or ward to a particular Course/ Programme in a University, enhancement of Marks), and dishonesty can be both financial & intellectual.

With great respect, the allegation in the impugned Judgment about Applicant having failed to satisfy the High Court, as an Investigating Agency, about the ‘when, where & time’ of bribe etc is purely a creature of after-thought -- audio-recording of the court-proceedings may be summoned, please.

4. With great respect, some of the clever judicial officers -- forearmed with the knowledge that due to paucity of time some of the Hon’ble Appellate Courts may read only the impugned Judgments before coming to Court -- write their Judgments in such a way as would favour a particular, pre-decided outcome, in that they selectively include only such evidence as will support their Judgment and suppress all such evidence as would harm their Judgment and, moreso, they seek to include anything that may bias/ prejudice the mind of Hon’ble Appellate Court against the Appellant; and the pre-decided agenda of Ld. DB No.x appears to be, on the face of record, to screen the Criminal Offenders (i.e. Respondents Nos. 1 & 2 etc) from what had already gone against them in the pleadings on record, without taking the risk of restoring the Crl Writ Petition, viz. the imminently likely action under the Prevention of Corruption Act 1988 (for admitted Bribery) against Respondent No.1, and under the Contempt of Courts Act 1971 (for not complying with Orders passed by previous Ld. DBs).

It is pertinent to mention here that the aim of Respondent No.2 was to try and delay the proceedings so much that the purpose for which the Petitioner desired to complete Ph.D. (viz. employment as a Director of any MBA Institute) was defeated by crossing the age of eligibility for such a Post in the meanwhile,  and to tire out -- financially & physically -- the Petitioner in the meanwhile, and also to seize every opportunity to get his case dismissed in default in the meanwhile during the almost seven and a half long years. On the other hand, Respondents Nos.1 & 2 were not proceeded ex-parte although they failed to appear for several months/ years; and when their most such attempts failed and, moreso, when these Criminal Offenders were cornered from all sides, then attempts were made to obtain favourable Orders by inviting the Administrative Heads of both the Benches of Hon’ble High Court of Allahabad to a Party hosted by the Respondent University (supra) in grave violation of Judicial Ethics -- admittedly, the then Dean of Commerce Faculty had also threatened the Petitioner that the latter would not get any judicial relief in Uttar Pradesh and, hence, the Petitioner even filed a Transfer Petition in Hon’ble Supreme Court, but without any timely remedy. As such, with great respect, the impugned Judgment dated 31.10.2017 logically appears to be the outcome.

5. The Stay-Order dated 16.04.2007 was produced in Court and taken on record by Hon’ble DB (Presided over by Justice UNS) after giving a copy thereof to the Opposite Counsel. 

The aforesaid mutually inconsistent Orders were passed by subsequent DBs despite the strictures passed by Hon’ble Supreme Court, in another matter, against Allahabad High Court for passing mutually inconsistent Orders in similar matters -- vide para 24 of P Suseela’s case; a copy of the Judgment in P Suseela’s case is already on record in the above Criminal Writ Petition (supra).

Even the 3rd unnumbered para of Order dated 29.09.2016 reads “inconsistent with the law laid down by the Hon’ble Supreme Court”, i.e. in P Suseela’s case.

The impugned Judgment dated 31.10.2017 admits that Ld. DB No.x had asked, without citing any prescribed format from Allahabad High Court Rules, the Applicant herein to show as to where a particular averment was repeated in the body of the Writ Petition besides mentioning the same in the List of Dates & Events notwithstanding that the Applicant had adopted the same in the body of the Criminal Writ Petition and also supported the same with Affidavit (supra).

It is respectfully submitted that the Applicant’s Crl MPs/ Applications for a Clarification & Modification and for Partial Recall of Order dated 19.08.2010 were justified & maintainable in that Order dated 19.08.2010 was passed per incuriam of Regulation 12 of UGC’s Regulations 2009 (which are already on record) to the effect that a Guide shall be allotted by the University AFTER a Candidate is selected as a ‘student’ and NOT be left to be settled between the student & teacher -- WHEREAS the said Order allowed the appointment of Guide even before the candidates’ Admission to Ph.D. This position was partly acknowledged by Respondent University by revising its Ph.D. Ordinance in the year 2011 so that a Guide be allotted only after a candidate becomes a student -- that is to say, after his/ her Admission to Ph.D. The said Ordinance proclaims in its ‘Preamble’ that it was drafted so as to conform to UGC’s Regulations 2009. The said revised Ordinance is already on record of Criminal Writ Petition and, hence, ought to have been perused by Ld. DB No.x since it did not give more than 10 minutes to the humble War-Veteran to ‘assist’ it (my previous Application to your goodselves refers), especially when it had suo motu perused the Counter-Affidavit that was filed in the year 2010 by Respondent No.2 (supra) -- despite the absence of the latter at the time of Final Hearing on 09.10.2017.

The Petitioner had stated on 09.10.2017 that the permitted 10 minutes were over but he had not been able to finish his Oral Arguments, yet to no avail.

Moreso, the Petitioner (Applicant herein) was denied Admission to Ph.D. on the sole ground of withdrawal of Respondent No.1 (Hon’ble DB’s Order dated 19.08.2010 refers) -- that is to say, to allow a change in Guide even before the Applicant became a ‘student’ and without even the Vice- Chancellor’s prior approval although such approval is mandatory under Clause 12 of the then applicable Ph.D. Ordinance (which is also on record); moreso, in the first place, such prior allotment of guide even before the candidate’s Admission as a student is in grave & gross violation of Reg.12 of UGC’s Regulations 2009 and, hence, withdrawal of such an illegally allotted Guide ought not to have had any effect on a Candidate’s Admission to Ph.D. Vide aforesaid Revised PhD Ordinance 2011, it is impliedly acknowledged that appointment of Guide before Admission of a candidate was inconsistent with UGC’s Regulations 2009. Hence, inter alia, only partial recall of Order dated 19.08.2010 was prayed for vide Crl MPs Nos.eee & fff.

As submitted in my previous Application addressed to your goodselves, on 27.04.2017 Hon’ble DB (Presided over by Justice SA), without first restoring the disposed of Writ Petition (which was disposed of by Hon’ble DB Presided over by Justice UNS vide Final Order dated 19.08.2010, in the Applicant’s favour), overturned the same on the ground that the Prayer-Clauses -- which were not only entertained but some of which were also granted vide Orders dated 08.07.2010 & 19.08.2010 by the previous Ld. DB after a lengthy hearing, could not be granted and that “Interim order, if any, stands vacated”. Is the latter DB treating the Final Order dated 19.08.2016 as an “interim order”? Moreso, did the latter Ld. DB (Presided over by Justice SA) peruse the entire record comprising of about 1,000 pages in just 85 seconds -- that, too, unassisted by the Applicant herein?

With great respect, the Applicant is not only a product of Top-10 educational Institutes in India [viz. Delhi School of Economics, Hindu College (Delhi), Campus Law Centre (Delhi) etc] but has also passed UGC’s NET (JRF/SRF) [it is on record in the above matter that in answer to a Query under RTI Act 2005 made by the Applicant, Respondent University replied that the Applicant was the only NET (JRF/SRF) candidate to apply to the concerned Department for Admission in Ph.D. from 01.05.2008 to 31.10.2009] and, moreso, the Applicant also passed Advocates-on-Record Exams; in addition, the Applicant completed Pre-Ph.D. Course-Work in FMS (Delhi) at a time when Respondent University was not carrying out any such course-work in the said Department, and also -- based upon guided original research under a highly respected Management Guru in Internationally known Pune University (Maharashtra) -- on 01.08.2013 the Applicant published a Book which received good Reviews from, inter alia, Globally known Scientists Dr APJ Abdul Kalam (now Late) and Dr Jayant V Narlikar. The said Book was also adjudged as equivalent to Ph.D. by a Panel of 3 Subject-Experts comprising of Dr PC Shejwalkar [Professor Emeritus (Pune University) in two Subjects, viz. Management & Commerce] who has guided 87 Ph.D. scholars, and another Expert is an Alumnus of IIM. Thus, the Applicant has also shown his ability to do Research -- all these documents are on record in the above Writ Petition.

Then why did Ld. DB No.x not determine as to what was the valid ground, if any, on which the Applicant -- who was recommended for Admission to Ph.D. by the Departmental Research Committee -- was not admitted, WHEREAS those less qualified than him were admitted, despite aforesaid Order dated 19.08.2010? Was the brief of Ld. DB No.x limited only to the screening of Offenders from two Criminal Offences that the latter had, as palpably apparent on the face of record, committed? 

With great respect:-

Is a financially unaffordable and lengthy Appeal Procedure a proper answer to malpractices that are mala fide committed by certain judicial officers -- especially when the Applicant herein is without any source of Income and the Criminal Writ Petition runs into about 1,000 pages? Should there be no deterrent punishment to judicial officers who pass such motivated Judgments & Orders and, thus, increase the burden of new cases upon Hon’ble Supreme Court? Why should the costs incurred on such Appeals be not recovered from guilty judicial officers? These are some of the pertinent Questions of great public importance, especially in a country whose about 1/3 population lives Below the Poverty-Line, to be determined by Hon’ble Supreme Court by treating this Application as a Letter-Petition, with a direction to the Registry to get the requisite number of copies of all records printed at State-expense.

Hon’ble Prime Minister is hereby requested to initiate proper ‘impeachment proceedings’ in Parliament against Ld. Justices SH & SKS, if Hon’ble the Chief Justice of India does not suo motu initiate either in-house disciplinary proceedings or u/s 16 of the Contempt of Courts Act against the said Ld. Judges within 15 days from the date of this humble Application, please.

Yours Truly,

(xxx) 1971-War Veteran

Copy to (for information only):

Hon’ble Chief Justice Dilip Babasaheb Bhosale

Chief Justice of Allahabad High Court

Nayaya Marg, Civil Lines, Allahabad-211017