IN THE HIGH COURT OF JUDICATURE FOR __________ AT __________ BENCH, __________

***

S.B. CIVIL WRIT PETITION NO.             /2022

***

MR. XYZ SINGH S/O SH. ABC, AGED ABOUT 31 YEARS, RESIDENT OF 356, CIVIL LINES, __________.

(Petitioner)

Versus

  1. STATE OF __________ THROUGH THE PRINCIPAL SECRETARY, DEPARTMENT OF HEALTH AND FAMILY WELFARE, __________.

(Respondents)

***

S.B. CIVIL WRIT PETITION UNDER ARTICLE 226 OF THE CONSTITUTION OF INDIA

AND

IN THE MATTER OF IMPUGNED ARBITRARY AND UNLAWFUL ACTION OF THE RESPONDENTS ____________

AND

IN THE MATTER OF PRINCIPLES OF NATURAL JUSTICE, EQUITY AND GOOD CONSCIENCE.

*****

To,

THE HON’BLE CHIEF JUSTICE AND HIS OTHER COMPANION JUDGES OF THE HIGH COURT OF JUDICATURE FOR __________ AT __________ BENCH, __________.

MAY IT PLEASE THIS HON’BLE COURT

The humble Petitioner, above named, most respectfully begs to submit as under:-

  1. That the petitioner is a citizen of India who is being aggrieved of the arbitrary and unlawful action of the respondents wherein the services of the petitioner has been dispensed with in a wholly arbitrary and unlawful manner in utter violation of the principles of natural justice. The petitioner being aggrieved of the impugned action is competent to invoke the extraordinary jurisdiction of this Hon’ble Court in order to seek redressal of his grievances by preferring the instant writ petition under article 226 of the constitution of India.
  2. That all the respondents are state and its functionaries who are duly covered under the ambit of ‘State’ as enshrined under article 12 of the constitution of India. Hence, they are amenable to the writ jurisdiction of this Hon’ble Court.

BRIEF FACTS OF THE CASE

  1. That the brief facts leading to the filing of the instant writ petition are that the …..
  2. That the petitioner being aggrieved of the arbitrary action of the respondents in dispensing the services of the petitioner in an wholly arbitrary and unlawful manner vide order dated __________, prefers this present writ petition on following grounds:-

GROUNDS

  1. BECAUSE the petitioner craves the liberty to raise other grounds which would be submitted at the time of final arguments.
  2. That the petitioner has not previously filed any such writ petition in the matter under Article 226 of the   Constitution of India either before this Hon’ble Court or before the Supreme Court of India.
  3. That the petitioner is left with no other equally efficacious alternative remedy and speedy remedy available except to approach this Hon’ble Court by way of filing this writ petition.

PRAYER

It is, therefore, humbly prayed that Your Lordships may graciously be pleased to call for entire record of this case and after examining the same, admit and allow this writ petition by issuing an appropriate writ order or directions:-

i. To quash and set aside ________ (the major relief should be prayed here).

ii. To direct the respondents to give relaxation to the petitioner for the period _______________ .

iii. Any other relief which this Hon’ble Court may deem fit  and proper in the facts and circumstances of the case  may also kindly be passed in favour of the petitioner.

iv.Cost of the litigation may kindly be passed in favour of the petitioner.

Humble Petitioner

Through Counsel

     Place: 

      Dated:                    Advocate                                

   NOTES:

  1. That the process fees, notices and extra sets of the writ petition shall be filed within 3 days after admission of the writ petition
  2. That this is a S.B.Civil Writ Petition  and no vires of any Act or Rules made thereunder, has been challenged in this writ petition.
  3. It has been typed by my private Steno who is not an employee of this Hon’ble Court.
  4. As pie papers are not readily available, it has been typed on stout papers.
  5. That the jurisdiction lies in the High Court of Judicature for ____________________.

IN THE HIGH COURT OF JUDICATURE FOR __________ AT __________ BENCH __________

S.B.CIVIL WRIT PETITION NO.           /2022

MR. XYZ SINGH

VERSUS

STATE OF __________ & ORS.

AFFIDAVIT IN SUPPORT OF  WRIT PETITION

  I, XYZ Singh son of Sh. ABC, Aged About 31 Years, Resident Of 356, Civil Lines, __________, do hereby take oath and state as under:- 

1.That I am the petitioner in the present writ petition and as such am well conversant with the facts and circumstances of the case.

2.That the annexed writ petition has been drafted under my instructions by my counsel. I admit that the content mentioned therein are true and correct to my personal knowledge. 

3.That the contents of paras 1 to 30 and 33 of the annexed writ petitions are true and correct to my personal knowledge, while the submissions made in grounds are believed to be true and correct on the basis of legal advice given to me by my counsel.

DEPONENT

VERIFICATION:

I, the above named deponent do hereby verify on oath that the contents of paras 1 to 3 of my above stated affidavits are true and correct to my personal knowledge. Nothing material has been concealed in it and no part of it is false. So help me God.

DEPONENT

IN THE HIGH COURT OF JUDICATURE FOR __________ AT __________ BENCH __________

S.B.CIVIL WRIT PETITION NO.           /2022

MR ABC SINGH

VERSUS

 STATE OF __________ AND OTHERS 

AFFIDAVIT IN SUPPORT OF DOCUMENTS

I, XYZ Singh son of Sh. ABC, Aged About 31 Years, Resident Of 356, Civil Lines, __________, do hereby take oath and state as under:- 

  1. That I am the petitioner in the present writ petition and as such am well conversant with the facts and circumstances of the case.
  2. That the annexed documents being Annexures 1 to 17 with the writ petition are true and correct photostat/downloaded copies of the original documents.

DEPONENT

VERIFICATION:

I, the above named deponent do hereby verify on oath that the contents of paras 1 and 2 of my above stated affidavits are true and correct to my personal knowledge. Nothing material has been concealed in it and no part of it is false. So help me God.

DEPONENT

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