IN THE HIGH COURT OF JUDICATURE AT BOMBAY (UNDER RULE 4(e) OF BOMBAY HIGH COURT PIL RULES 2010)
PUBLIC INTEREST LITIGATION NO.
OF 2016
Dr.Kanagasabapathy Sundaram Pillai, Founder, “Integrating Society India Net”NGGO, Shop No.1 and 2, Kantharia Mansion, C.S.312, Dharavi Cross Road, Dharavi, Mumbai 400017 Phone: 9920309223 email:
[email protected] …………Petitioner Versus Union Govt. of India through The Reserve Bank of India, Mumbai 400001 Telephone No: 022 22602804 / 022 22602944 Email id:
[email protected] ……….Respondent. District:BOMBAY(Mumbai) Writ Petition under Article 226 of constitution of India The Reserve Bank of India Act,1934 & 1935 and The Banking Regulation Act, 1949 TO THE HON’BLE CHIEF JUSTICE AND HIS COMPANION HON’BLE JUSTICES OF THE HON’BLE HIGH COURT OF BOMBAY
THE HUMBLE PETITION OF THE PETITIONER ABOVE NAMED: MOST RESPECTFULLY SHOWETH:
Particulars
of
the
cause
against
which
the
petition is made:(1)
Subject matter in brief:
Demonetization
is
the
act
of
making
a
currency unit of its status as legal tender quranteed under
by
the
control
&
Prime
Bank
directions
of of
the
country
the
Finance
Ministry of the country’s government. In India Reserve Bank of India having its Head Office at Mumbai is the agency for the same. One of the duty of RBI is printing valuable denominations of
currency
units
for
distribution
and
collecting the same after damage/soiling etc to destroy
and
replacement.
Such
legal
tender
currency units are demonitized usually when the country is changing the national currency to make the currency pairing in foreign exchange market.
Usually
currency
will
demonitization
to not
prevent be
because
a it
misuse
sound
of
the
basis
for
involves
major
bugetary expenses for a developing country like India. Now India has chosen the Demonetization
of Rs.500 & Rs.1000 denominations notified by Gezette Notification DCM(Plg)No.1226/10.27.00/2016-17 0f Govt. Of India dated 8th
November 2016. Hon’ble Prime
minister of India in his address to people on 8th
November
2016
and
the
Hon’ble
Finance
minister in his interview in medias that this demonetization
of
higher
denominations
courrency is aimed to prevent hoarding as black money
earned
unscrupulous
by /
evading
unfair
tax,
trading
curruption, /
scams
/
collecting so called donations permitted uder the law of the land. Then such easy money is spend for illegal purposes especially terrarism. The impact in countries progress is challenged by the black & grey parrallel economy. In India these have gone as enormous volume uncontrolled as the other machineries are not fully capable of preventing as though law of the land is adequate.
Under
the
circumstances
the
deminetization preferred by the government is welcome
but
replacement
with
the
still
more
higher value like Rs.2000 denomination will not only defeat the very
basic purpose of the move
but also double the hoardng keeping chip / RFI etc. will be a failure because the hoarders will find new ways to jump the hurdles. The exchange for the demonetization should be
a
change
denominations.
in This
the
existing
will
check
low the
value
thought-
objectives as well as inflation which will come down
to
realities.
The
present
distribution
system of taking form with identity proof for an amount of Rs.4000/ which can be repeated by Individuals will a fallacy/anomaly that all the hoarded
money
will
be
safely
converted
for
future use/misuse. I do not want to discuss the security
features
of
the
new
Rs.2000
denomination but one thing adertisement is not allowed on the legal tender as per rules & regulations of printing currency. Here in the Rs.2000 denomination slogan for the cleanliness campaign printed which is not permitted under the rules. Moreover its depiction may not be
good.
There
fore
the
distribution
of
the
Rs.2000 should be stayed immediately forthwith and
the
giving
back
the
lower
denominations
like Rs.100, Rs.50. by opening KYB account with the
form
designed
duly
filled
with
identity
proofs address proofs with photos & biometrics like finger prints taken digitally etc. for new accounts only having detail of past exchange taken already. Account holders deposit in their existing accounts with PAN numbers. This will fullfil
the
ojectives
100%.
If
not
the
mechanism if leaked already & loopholes already studied the objectives will be defeated and the expenses will go downthedrain. Therfore the issue of the new denomination Rs
2000
especially
demonetisation
of
in Rs.500
exchange &
of
Rs.1000
the is
immediately stopped. 2. Particulars
of
the
Petitioner(s)
:-
1. The petitioner is a senior citizen aged 63 years retired from the post of Asst.Professor, Preventive Social Medicine (Community Medicine)
G.S.Medical College & KEM Hospital, Parel, Mumbai 400012, a law abiding indian ordinarily residing in Mumbai. The petitioner is a medical graduate MBBS, DPH, MD, MBA in OR and LLB from Mumbai University. The petitioner is doing free medical & social service through a platform of an “NGGO” organization known as “Integrating Society India Net”NGGO, as founder, addressing social issues to agencies and if no relief by PIL. 2. At present one PIL under No. PILL/25/2015 in the matter of exorbittant repeatted increase of BEST
undertaking
admission
stage
Bus in
charges this
is
Hon’ble
pending
at
Court.
The
petitioner is representing in the cases of his wife’s criminal
property as
litigations
complainant
in
at
Dharavi
CC/64/2015
in
both 12th
court Bandra, SC/1696/2015 in city civil court and
WP/47/2015
in
this
Hon’ble
Court
all
proceedings for forcible dispossession of clinic & NH. A service matter for enhanced retirement for medical teacher under WP(OS)/1550/2011 is at final hearing & disposal stage.
3.
Declaration
and
understanding
of
the
Petitioner(s):1.
That the present petition is being filed by
way
of
public
Interest
litigation
and
the
petitioner(s) does not have any personal interest in the matter. The pettioner has applied to the reserve bank and GOI Finance Ministry since the previous
UPA
Integrating
Govt.
Society
Regime
India
Net
for
the
NGGO
establishing
no
currency banking system for the lower economic strata as “Special Eonomic Group” (SEG) which was never finalised till date. The final application is annexed herein and marked as Exhibit – A. The objective of such establishing was to keep the black
economy
not
only
under
check
but
also
benefit the SEG mass. Having the same objective the present petition to improve the system by some
suggestions
attempted
by
this
PIL.
2. That the entire litigation costs, including the advocate's fee and other charges are being borne by the petitioner in person His permanent Account Number with the Income Tax Department, is
AALPP/5507E. 3. That a thorough research has been conducted in the matter raised through this petition all the relevant
material
is/shall
be
4.
That
to
in
annexed the
respect with
best
the of
of
such
research
petition the
herein.
petitioner(s)
knowledge and research, the issue raised dealt with and that a similar or identical petition are filed earlier by some public interested advocates and this petition may please be heared along with those petitions. The petitioner has not filed any other litigation touching the same subject matter in any other court of law. 5. That the petitioner has understood that in the course of hearing of this petition the Court may require any security to be furnished torwards costs or any other charges and the petitioner shall have to comply with such requirements.
4. Facts in brief, constituting the cause:
Demonetization
is
the
act
of
making
a
currency unit of its status as legal tender quranteed under
by
the
control
&
Prime
Bank
directions
of of
the
country
the
Finance
Ministry of the country’s government. In India Reserve Bank of India having its Head Office at Mumbai is the agency for the same. One of the duty of RBI is printing valuable denominations of
currency
units
for
distribution
and
collecting the same after damage/soiling etc to destroy
and
replacement.
Such
legal
tender
currency units are demonitized usually when the country is changing the national currency to make the currency pairing in foreign exchange market.
Usually
currency
will
demonitization
to not
prevent be
because
a it
misuse
sound
of
the
basis
for
involves
major
bugetary expenses for a developing country like India. Now India has chosen the Demonetization of Rs.500 & Rs.1000 denominations notified by Gezette Notification
DCM(Plg)No.1226/10.27.00/2016-17 0f Govt. Of India dated 8th November 2016.Herein annexed and marked as Exhibit – B. Hon’ble Prime minister of
India
in
his
address
to
people
8th
on
November 2016 and the Hon’ble Finance minister in
his
interview
demonetization
in
of
medias
higher
that
this
denominations
courrency is aimed to prevent hoarding as black money
earned
unscrupulous
by /
evading
unfair
tax,
trading
curruption, /
scams
/
collecting so called donations permitted uder the law of the land. Then such easy money is spend for illegal purposes especially terrarism. The impact in countries progress is challenged by the black & grey parrallel economy. Annexed herein
the
copy
of
Honb’le
Prime
Ministrs
Message and marked as Exhibit – C. In India these have gone as enormous volume uncontrolled as the other machineries are not fully capable of preventing as though law of the land is adequate.
Under
the
circumstances
the
deminetization preferred by the government is
welcome
but
replacement
with
the
still
more
higher value like Rs.2000 denomination will not only defeat the very
basic purpose of the move
but also double the hoardng keeping chip / RFI etc. will be a failure because the hoarders will find new ways to jump the hurdles. The exchange for the demonetization should be
a
change
denominations.
in This
the
existing
will
check
low the
value
thought-
objectives as well as inflation which will come down
to
realities.
The
present
distribution
system of taking form with identity proof for an amount of Rs.4000/ which can be repeated by Individuals will a fallacy/anomaly that all the hoarded
money
will
be
safely
converted
for
future use/misuse. I do not want to discuss the security
features
of
the
new
Rs.2000
denomination but one thing adertisement is not allowed on the legal tender as per rules & regulations of printing currency. Here in the Rs.2000 denomination slogan for the cleanliness campaign printed which is not permitted under
the rules. Moreover its depiction may not be good.
There
fore
the
distribution
of
the
Rs.2000 should be stayed immediately forthwith and
the
giving
back
the
lower
denominations
like Rs.100, Rs.50. by opening an account with the
form
designed
duly
filled
with
identity
proofs address proofs with photos & biometrics like finger prints taken digitally etc. for new accounts
only.
Others
in
their
existing
accounts with PAN numbers. This will fullfil the ojectives 100%. If not the mechanism if leaked already & loopholes already studied the objectives will be defeated and the expenses will go downthedrain. Therfore the issue of the new denomination especially in exchange of the demonetisation of Rs.500 & Rs.1000 is immediately stopped by a suitable order of writ at this juncture for exchange of demonetisation on following grounds: a.)
The
act
does
not
fall
withon
purview of the term “Demoneization Exchange”
the
b.)
The
RBI
guidelines
do
not
reflect
issue of Rs.2000 but only Rs.100 denominations. c.)
The
demonetization
very is
basic
purpose
defeated
and
of
this
therewill
be
rebound phenomenon will occur. d.)
There is already evidences of leak
of this demonetization like one gujarati news clip annexed herein as Exhibit – D e.)
The
system
of
Rs.4000
per
person
with choice of identities any branch any where multiple possible times daily for about 50 days is a loophole that thirdparty hoarded money can be exchanged through poor mass and IT machinary is not adequate to review the mass drops of issues making a flood of amount can not be checked as the main aim of hoarders check will be defeated especially small hoaders. f.)
So the Form of KYC issue to be made
as account and all amount of the person at one time in one account with all the identity proof that is with that individual to be declared on the same form. This is a chance to check the
benami situation also and the signed numbered form
will
be
the
account
number
with
bank,
branch & Govt Purpose Account code will be a follproof
method.
This
is
an
opportunity
to
bring poor, ignoant mass in main stream for future benefits to reach the correct eligibles without exploitations. g.)
It
demonetised
can
be
notes
distributed
to
apprehended
that
the
hoarding
can
be
in
mass
in
non
ethical
election
practices which can be exchanged afterwards by the mass. So exchange by lower denominations by creating one KYC account of individuals to be finished
in
short
period
say
one
week
only
before elections/such situations favouring the hoarded money exchanged. 5. Source of Information :The source of information of the facts pleaded in the petition by the circulars of RBI stating the Gazette
noification
messages
of
the
PM
and &
FM
media of
qouting
Union
Govt.
the The
petitioner has verified the facts personally from
the relevant web sites and personal application to his bank. 6. Nature and extent of injury caused/apprehended. The petitioner apprehend that if not prperly implemented the objectives of the scheme may not be acieved as realised in the past efferts in curbing
this
menace
of
black
money
and
tax
evation. 7. Any
representation
etc.
made:-
The petition is served on the respondent as the time is short and the result will be seen by their
reply. There
is
no delay
in
filing
the
petition. This Hon’ble court has got jurisdiction to try this writ petition. 9. Documents relied upon: 1.
Letter of NGGO to RBI dt 03.10.2016.Ex-A
2.
Gezette Notification
DCM(Plg)No.1226/10.27.00/2016-17 0f Govt. Of India dated 8th November 2016. & Appeal to Bankers by RBI. Ex-B
3. Hon’ble Prime minister of India in his address to people on 8th November 2014.Ex.C 4.News clip Gujarati paper dt 1.4.2016.Ex-D 10.
Caveat :-
That no notice has been received of lodging a caveat by the opposite party but the respondent is
served
notice
of
with
the
copy
information
of
of
the
moving
petition this
with
Honb’le
court. 11. Relief(s) prayed for :The
denomiation
circulated
and
of
the
Rs.2000
already
should
circulated
not
be
to
be
deposited in bank account and the issue should not be in denominations Rs.100 & below only and the highr amounts to be used through electronic accounting
system
or
by
smart
card
charging
system for common people so that the parallel black economy will be Zero. 12. Interim order in terms of prayer above at 10 the exchange / distribution of Rs.2000 till the demonetized Rs.500 & Rs.1000 is flushed out
of the economy which is an essential step and need of the time. At
Mumbai
This
day
of
November
2016
(Dr.Kanagasabapathy Sundarm Pillai) Petitioner in person VERIFICATION
I,
Dr.Kanagasabapathy
Petitioner
above
Sundarm
named
do
Pillai,
hereby
on
the solemn
affirmation state and declare that what is stated in the paragraphs 1 to knowledge
and
belief
9 is true to my own
and
what
is
stated
in
paragraph 10 & 11 is based on the information and legal advice
which
I
belief
to
be
true
and
correct. Solemnly affirmed at Mumbai, This
day of
November
2016
(Dr.Kanagasabapathy Sundarm Pillai) Petitioner in person Before me.
IN THE HIGH COURT OF JUDICATURE AT BOMBAY [RULE 4(e)OF THE BOMBAY HIGH COURT PUBLIC INTEREST LITIGATION RULES, 2010] PIL PETITION NO.
OF 2016 DISTRICT: MUMBAI
Akhil Anil Chitre……
Petitioner Versus
The Union of India and Others (2)……
Respondents
INDEX Sr
Particulars
Page
No.
Nos.
1.
Synopsis
2.
Public Interest Litigation
3.
Annexure A Affidavit in terms of sub-rule (a), (b) and
(c)
Court 2010
of
Public
rule
7
of
Interest
The
Bombay
Litigation
High
Rules,
IN THE HIGH COURT OF JUDICATURE AT BOMBAY [RULE 4(e)OF THE BOMBAY HIGH COURT PUBLIC INTEREST LITIGATION RULES, 2010] PIL PETITION NO.
OF 2016 DISTRICT: MUMBAI
Akhil Anil Chitre……
Petitioner Versus
The Union of India and Others (2)……
Respondents
SYNOPSIS Time 8th
Particulars
November Honourable Prime Minister of India Mr
2016
Narendra
Modi
Denomination
declared
Notes
(HDN)
that of
Rs
High 500/-
and Rs 1000/- would cease to be a legal tender from the midnight of 9th November 2016. 9th November
In
2016 to 14th
Unaccounted
a
bid
November 2016 hoarders
to
secure
Money,
the
desperately
existing
currency
available
change
artificial
in
scarcity
the
stashed
Black
Money
exchanged
their
with
all
the
the
market.
An
of
change
was
witnessed by the common man. 14th November
The
2016
have been increased slightly, however no
limits
change
of
is
withdrawal
from
available
for
banks
daily
routine.
Issues Raised 1. Whether the Petitioner is entitled to seek a direction against
the
Respondents
from
this
available change to the common man? 2. Generally.
Court
for
making
Statutes Relied On 1. The Constitution of India, 1950. Authorities Relied On At Present NIL Mumbai 15th November 2016 Tapan Thatte Advocate
IN THE HIGH COURT OF JUDICATURE AT BOMBAY [RULE 4(e)OF THE BOMBAY HIGH COURT PUBLIC INTEREST LITIGATION RULES, 2010] PIL PETITION NO.
OF 2016 DSITRICT: MUMBAI In
the
Matter
of
Article
226 of the Constitution of India. AND In
the
Matter
Notification November
of
dated
8th
at
No.
2016
S.O.3408 (E). AND In
the
of
Serious
and
income
crunch
especially
change
crunch
cash
Matter
faced by poor sections of the society. Akhil Anil Chitre Age:
30
Years,
Business, Samadhan
Occupation:
Residing 45/1
at:
Gandhinagar,
MHB Colony Bandra East Mumbai 400 051. ……Petitioner Versus 1. Union of India 2. The State of Maharashtra 3. The Reserve Bank of India Central Shahid
Office Bhagat
Building, Singh
Road,
Fort Mumbai, PIN 400 001.
……Respondents To, The Chief Justice and other puisne
judges
Court
of
of
the
High
Judicature
at
Bombay,
Humble
Petition
by
the
Petitioner herein
Most Respectfully Sheweth; 1.
The Petitioner is a citizen of India and resides at the address
mentioned
Petitioner
being
in
the
cause
a
public
title
hereto.
spirited
The
citizen
has
instituted this public interest litigation to seek a direction
against
the
Respondentsto
make
available
change currency to individuals below poverty line on priority and other ancillary reliefs. 2.
That the present Petition is being filed by way of Public Interest Litigation and Petitioner does not have any
personal
interest
in
the
matter.
The
entire
Petition cost including the Professional Fees of the Advocate
are
being
Petitioner’s
borne PAN
by
the
Petitioner.
Card
No.
. The Petitioner has carried out exhaustive research of the issues raised. The issues raised in this
Petition
have
not
been
decided
by
any
court
earlier or that no Petition is pending before any other court. The Petitioner understands that the Court may impose costs and security onto the Petitioner. All that is stated by the Petitioner is through his personal knowledge. 3.
Respondent No. 1 is the union of India. Respondent No. 2 is the state of Maharashtra. Respondent No. 3 is the reserve bank of India. Respondent No. 3 is responsible for
exercising
administrative
control
over
all
banks functioning in India.
DEMONETIZATION SCHEME AND CASCADING EFFECTS OF IT
the
4.
On
the
8th
introduced
of a
November
2016,
demonetisation
the
Respondent
scheme
vide
No.
1
notification
No. S.O. 3408(E). Under the notification, all currency notes of denomination of 500 and 1000 were derecognised as legal tender with effect from the midnight of 9th November 2016. 5.
Understandably,
the
said
scheme
was
introduced
for
bringing to light the unaccounted stashed cash from the safes of black money hoarders. The scheme is indeed salutary. However, the dynamics of the scheme, which in the
perception
of
the
Petitioner,
could
not
be
contemplated, while framing and executive the policy have resulted in serious cash and income crunch for the weaker
sections
situation
as
of
the
it
society.
exists
An
overview
today
is
of
the
illustrated
hereinafter. 6.
Soon
after
the
demonetisation,
the
black
money
hoarders, in a bid to secure their unaccounted for cash which was presumably in high denomination notes made desperate attempts to exchange the stashed cash for available change in the market. The Petitioner from his personal knowledge quotes that at VT station Mumbai, currency in hundred rupee or lower denomination was selling at a premium of around 20% for exchange with demonetised
high
denomination
notes.
Thus,
parking
contractors, public toilet contractors, BEST cashiers et cetera who in the course of their business collect huge
amounts
of
change
fell
prey
to
the
immediate
premium available for exchanging change. That be as it is.
As
on
today,
practically,
there
is
hardly
any
change available in the market. 7.
The paucity of change currency has adversely affected small
businessmen
illustration,
A
and
bhel-puri
service vendor
providers. who
has
all
For his
customers paying him an amount lower than rupees fifty has not only been robbed of change but also has to forego his business due to unavailability of change currency.
Similar
is
the
situation
of
maidservants,
hawkers, vegetable vendors et cetera. The situation for these weaker individuals stands further aggravated as they are even unable to buy provisions due to lack of change with the concerned vendor. 8.
It has been rightly adjudged by the honourable Prime Minister that the present cash crunch, especially the crunch in change currency would go on for a period of 50 days. Under these circumstances, weaker individuals who earn around hundred rupees a day and who have no holding
capacity
would
stand
seriously
prejudiced
during this transition. 9.
Apart from the aforesaid, though the honourable Chief Minister of Maharashtra has taken a positive decision of accepting old high denomination notes in government offices
the
weaker
sections
are
still
unable
to
transact with the government institutions due to lack of change in both their and government institutions’ hands. 10.
It
is
submitted
that,
despite
bank
officials
doing
their best to re-infuse high denomination notes into the economy, a person withdrawing any amount from the bank generally is given a Rs. 2000 note which again cannot
be
readily
used
for
lack
of
change.
The
Petitioner submits that due to lack of change the Bank official
have
been
refusing
any
payments
below
Rs
2000/-. SUGGESTED SOLUTION 11.
Before this
the
Petitioner
court
it
is
suggests
humbly
any
conceded
solution that
through
neither
the
Petitioner nor his lawyer is an expert in the field of finance
and
instituted
monetary
this
public
policy.
The
interest
Petitioner
litigation
only
has in
order to mouth the sufferings of the weaker section of the society and to bring the same to the notice of the highest authorities. Cooperation and activesuggestions from the Respondents, in order to resolve this acute cash
and
income
crunch
which
weaker individuals is solicited.
has
severely
hit
the
12.
As far as the solution is concerned; since it is the weaker section of the society which has taken a major brunt of demonetisation which has cascaded into severe cash and especially change crunch, it is submitted that the Respondents may provide for separate counters at banks and post offices which would strictly dispense 10, 20, 50, and 100 rupee notes to anyone who wishes to exchange only a single note of 500 or 1000 in a day. The rationale for this is that a person who wishes to exchange a single note can rightfully be expected to be from weaker section of the society.
13.
Alternatively, essentially
all
have
withdrawals appropriate
from
the
banks
component
in
must
smaller
denomination notes as aforesaid. 14.
Smaller
denomination
notes
and
coins
must
be
made
available to all government institutions on priority so as to facilitate access to those by weaker sections of the society. 15.
In a rare case if none of these suggested alternatives are viable at this juncture the State government may consider opening free eateries for below poverty line individuals upon showing orange ration card.
16.
Any other practicable solution from the Respondents is welcome. GROUNDS
17.
Being aggrieved by the serious cash and income crunch especially change crunch which has seriously hit small businessmen and service providers the Petitioner relies on
the
following
grounds
which
are
urged
without
prejudice to one another; A. a bare reading of clause (b) of article 39 of the Constitution
of
India
brings
out
that
all
policies framed by the state should secure
the “the
ownership and control of the material resources of the
community
or
so
distributed
as
best
to
subserve the common good”. In the context of this petition, the availability of change in the hands of
weaker
sections
of
the
society
who
may
be
termed as daily wage earners, constitutes control of material resources as envisaged by the article. Any
artificial
scarcity
in
the
availability
of
change, even if remotely caused by any policy of the State, would not only be de hors the directive principles enshrined in the article but would also seriously prejudice right of livelihood available under article 21 of the Constitution. B. Even if for arguments sake it is conceded that the State policy being directed towards better nationbuilding
some
inconvenience
occasioning
to
individuals must be ignored; the state cannot be allowed to escape its duty of securing livelihood especially
when
it
is
claimed
for
mere
subsistence. C. Generally. 18.
The Petitioner has no personal interest in the matter and that he has no knowledge of any petition on the same point pending before any court. The Petitioner has not instituted any other petition on the same point before any court. No caveat has been received by the Petitioner.
19.
The Petitioner has filed along with this Petition the prescribed Affidavit.Annexed hereto as Annexure A is a copy of the said affidavit.
20.
Under the circumstances it is prayed that; A. This
High
Court
may
direct
The
Respondents
to
immediately implement any of the suggested solution as enumerated in Paragraphs 11 to 16 of this Petition. B. This
High
Court
may
make
any
other
order
in
the
interest of justice. Mumbai 15th November 2016 Tapan Thatte Advocate for the Petitioner Verification
I, Akhil Anil Chitre, Age: 30 Years, Occupation: Business, residing at: Samadhan 45/1 Gandhinagar, MHB Colony Bandra East Mumbai 400 051, being the Petitioner herein, do hereby solemnly affirm that the contents of this Petition are true and correct to the best of my knowledge and ability and in witness whereof I have put my hand hereunder on this 15th day of November 2016 at Mumbai. Mumbai 15th November 2016 Akhil Anil Chitre Affiant I know the Affiant Tapan Thatte, Advocate.
IN THE HIGH COURT OF JUDICATURE AT BOMBAY [RULE 4(e)OF THE BOMBAY HIGH COURT PUBLIC INTEREST LITIGATION RULES, 2010] PIL PETITION NO.
OF 2016 DISTRICT: MUMBAI
Akhil Anil Chitre……
Petitioner Versus
The Union of India and Others (2)……
Respondents
Affidavit in terms of sub-rule (a), (b) and (c) of rule 7 of The Bombay High Court Public Interest Litigation Rules, 2010
I,
Akhil
Anil
Chitre,
Age:
30
Years,
Occupation:
Business, residing at: Samadhan 45/1 Gandhinagar, MHB Colony Bandra East Mumbai 400 051, being the Petitioner herein, do hereby solemnly affirm that; 1. That the present Petition is being filed by way of Public Interest Litigation and Petitioner does not have any
personal
interest
in
the
matter.
The
entire
Petition cost including the Professional Fees of the Advocate
are
being
Petitioner’s
borne PAN
by
the
Petitioner.
Card
No.
.
2. The Petitioner has carried out exhaustive research of the issues raised. The issues raised in this Petition have not been decided by any court earlier or that no Petition is pending before any other court.
3. The Petitioner understands that the Court may impose costs
and
security
onto
the
Petitioner
in
case
the
petition is found to be out of mala fides or frivolous. All that is stated by the Petitioner is through his personal knowledge.
In witness whereof I have out my hand hereunder on the 15th day of November 2016 at Mumbai.
Mumbai 15th November 2016 Akhil Anil Chitre Affiant I know the affiant. Tapan Thatte, Advocate.
