LIST OF EVENTS:-

28-01-2011 (Annexure P-1

Brief happenings of this date

Annexure P-2 Annexure P-3)

23-02-2011 (Annexure P-3)

Brief facts of this day

24-04-2011 (Annexure P-4)

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Chandigarh Date:

(VIPAN KUMAR GOYAL) (PUSHPINDER KAUSHAL) Advocates Counsels for the petitioner

IN THE HONBLE HIGH COURT FOR THE STATES OF PUNJAB & HARYANA AT CHANDIGARH **** Civil Writ Petition No.___________/2011

Name, Address of Petitioner -----Petitioner. Versus

123-

1st 2nd Ors

-----Respondents.

Civil

Writ

Petition

under

Article

226/227 of the Constitution of India for issuing the writ of xxxxxxx

directing the respondents xxxxxxx in accordance with provisions of Article 14 of the Constitution of India and the provisions of xxxxxxxxxxxx in the interest of justice.

Or any other suitable, writ, order or direction which this Honble Court deems fit in the circumstances of the case be also issued.

RESPECTFULLY SHOWETH:

1-

That the petitioner -------------------is entitled to invoke

the extra-ordinary writ jurisdiction by way of filing the present writ petition in this Honble High Court under Article 226/227 of the Constitution of India.

2-

That -------------- brief facts

3-

That the relevant portion of Section xxxxxxxxx of ----

Act is reproduced herewith for the kind perusal of the Honble Court:-

4-

That after taking into cognizance the factual position

and the above provisions of section xxxxxxxxx, it is quite evident that the --------------.

5-

That the main law points involved in this writ petition

are as under:i) Whether ----------------?

ii)

Whether the petitioner is entitled to

entitle to the issuing of -------------- or any other writ, order or direction by the Honble Court in view of the facts and circumstances of the case as prayed for in the writ petition?

15-

That the petitioner has not filed such or similar writ

petition either in this Honble Court or in the Honble Supreme Court of India, for the same cause of action.

16-

That the petitioner has not left with no other alternative

remedy in the form of appeal or revision except to approach this Honble Court, by way of the present writ petition under Article 226/227 of the Constitution of India.

It is, therefore, respectfully prayed that the Honble Court may kindly be pleased to:-

(a)

issue the writ of ------------- directing

the respondents to ---------------.

Or

Any

other

suitable,

writ,

order

or

direction which this Honble Court deems fit in the circumstances of the case be also issued.

b)

Service

of

notice

as

upon

the

respondents as required by the writ rules of this Honble Court and filing of certified copies of annexures may kindly be dispensed with;

c)

Advance notice to the respondents may

kindly be dispensed with; d) Costs of the present writ petition may

kindly be granted in favour of the petitioner and against the respondents/department;

Chandigarh.

Dated:

Petitioner THROUGH COUNSELS:

(VIPAN KUMAR GOYAL) (PUSHPINDER KAUSHAL) Advocates

VERIFICATION: It is verified that the contents of para No. 1 --------------- of my writ petition are true and correct to the best of my knowledge and belief. The contents of para No. ----------- are law points, which are believed to be true. No part of it is false and nothing has been kept concealed there in.

Place: Chandigarh. Dated: Petitioner

IN THE HONBLE HIGH COURT FOR THE STATES OF PUNJAB & HARYANA AT CHANDIGARH **** Civil Writ Petition No.___________/2011

------Petitioner Versus State of Punjab & others Respondents

AFFIDAVIT of Mr. -------------

I, the above named deponent do hereby solemnly affirm and declare as under:-

1.

That the deponent

2.

3.

That all the facts mentioned in the petition are true in

the knowledge of the deponent. No part of it is false and nothing has been concealed therein.

PLACE: CHANDIGARH Dated: DEPONENT

VERIFICATION: It is hereby verified that the contents from Para No. 1 to 4 of my above mentioned affidavit are true and correct to my knowledge and belief. No part of it is false and nothing has been kept concealed therein.

PLACE: Chandigarh DATE: DEPONENT