,'

TN

THE HIGH COI]RT OF DELHI AT NE,IV DELHI

w.P.(c) No.6702 OF 20ls

IN THE MATT.ER 9F:

AJAY MAKEN

. . . PETITIONER

VERSUS
TINION OF INDIA & ANR.

, . .RESPONDENT

N.D.O.}I. : 05.08.2015

PARTICULARS
AFFIDAVIT ON BEHALF OF
RESPONDENT NO. 2
ANNEXURE.A
COPY OF PRINT MEDIA
ADVERTI SMENT EXPENDITURE
ANNEXURE-B (COLLY.)
COPY OI. ELECTRONIC
AVERTI SEMENT EXPENDITURE
ANNEXURE-C
COPY OF CLIPPINGS OF VARIOUS
NEWSPAPERS

NEW DELHI.

DATED:

03.08.2015

(RANI
DTJGGAL)
^rlJ
Standing Counsel (Civil)
for GNCT of Delhi.
423, Law r,'er' s Chamber,
Delhi High Court,
1.1"* pcilhi- I 10003
Mob. lr', t. :9212008425

IN THE HIGH COURT OF DELHI AT NEW DELHI

w.P.(c) NO. 6702 0F 20 15

IN THE MATTER OF:
A"IAY MAKEN

PETITIONER
VERSUS

UI{IION OF INDIA & ANR.

RESPONIlETTTS

Ab-I-IDAVIT ON BEHALF OF RESPONDENT NO. 2.

I, M.C. Maurya aged about 58 years, working as Dy. Directorf

F{ead of Office, Directorate of Information and Publicity Block No. 9,

OL1 Secretariat, Delhi-

11

0054, do hereby solemnly affirm and

der:lare as under:
1.

I say that I am working' as Dy. Director, Drrectorate of

Information and Publicity and conversant with

tl--.e

facts

amd

of the present case and as such conlpetent to

'ay that

have perused the petition under reply and the

Synopsis, Lisi of dates and the petition are wrong and denied

unless the contents of the salne

a-re

specifically admitted

hereunder.
3. I say that in terms of order dated 29th July, 2015 passed in the
aforesaid matter, this Honble Court qua respondent no. 2 is

now placed to pass two fold directions namely to file response

b1r Jro Augusc, 2015 meeting

all the a-llegations

:rlrade

in

the

petition and to furnish the detail of the amount spent and the
1

tu

Honble Apex Court, as such the petition under reply is

rnisconceived qua the answering respondent.

PRELIMINARY SUBMISSIONS

it is g.,ertinent to mentiqn herein that vide order dated

1. That

15.07.2oL5 this Honble court had directed Respcndent No.

herein to file an a-ffidavit stating the steps taken for the

implementation of the Government Advertisem;,nt (Content

Regulations) Guidelines, 2014 however the Respondent No.
1 failed to file the said affidavit.

h:rsuant thereto vide order

dated 29.07.2015 this Honble Court directed the answering

respondent to file its response meeting al1 a11eg,:.t.ons made

t

in the petition and also directed the answering respondent

rnish details of the amount spent and the source of
iture for the Government advertisements by print

nic media after

13.05.20

5 as th,:r an,swering

ent is filing the present affidavit.

2. That

the petition under reply is prematureas the three

member body as directed to be constituted. by the Honble

Apex court vide its judgment dated 13.0s.20

the

appropriate forum

to

i5 would be

implement

the

directions/guidelines iaid down by the Honble Apex Court.

It is

submitted that

this Honble court und.e r

writ

jurisdiction cannotadjudicate/give directionsor:r. . :attsrsfor

&

which a

machin ery f mechanism

has been st.ipulated

as

such the petition under reply is liable to be dis missed with

exemplary cogts.

3.

That it is pertinent to mention herein that the Delhi

Government launched the 'Anti- Corruption Hclpline 103 1 '

campaign with the photograph of Honble Chief lvlinister of

Delhi in outdoor media such as BQS, Public utilities,

Unipoles, Bill Boards, Railway Bridge Panels, Metro Train

inside Panels, Live media Screens. The said campaign was

mourrted on outdoor media owned by sole cr)ir^esSioners

and approved media by DAVP for a period of 15 days with

effect from 06th Aprii 2015 to 21"t April 2015 witkr. 05 days

bonus display upto

Lrj ::
,:,1.'

il/.i

sites

26Lh

April 20i5. while

o1r,

Rent Free

-it was mounted for a period of one molrth starting

lt.l
, \

li miltto Train inside for a per,iod. of one month and Live med.ia
ii'l
.* l-' i,
fi
.!-:j',1/
.;,).

\5gt!i'6creens for one month.

It is submitted that the entire media was released at

DAVP rates, with the approval of competent authority. The
campaign finally culminated on
The campaign was mounted on
1)

800 Rent Free sites

)\ 80 Public Utilities

1Oti,

May 2OIS.

3) 25 BQS NDMC area

4) 50 BQS Ring road

5) 50 BQS Outer'Ring Road west Delhi, East Delhi

6) 25 BQS BRT Corridor from Delhi Gate to Ambedkar' Nr

Termina-l

7) l17 ,50% added va1ue BQS

8) 50 Display Boards/ Metro Bridge Panels lunipoles

g) Live med.ia

ooc screens in

sa-far stores,

ccD,

MTNL,

McDonald stores etc 36 times a'daY

10) MetrO Train inside Panels

in 31 trains (covenng entire

Delhi)

It is submitted. that pursuant to the judgment of the

Hon'lcle Apsx Court dated. 13.05 .2Q15 wherein restrictions the

placed on the publication of the photographs of Government

functionaries, and political leaders, a TVC prepal'ed b5r Delhi

rnment with the photographs of Honble Chief Minister

telecast w. e,f. 1 5- 1 6 I OS I 2OI5

he orders of the

Honn'

Ie SuPrerne

Court De1hi, the' government has not spent a single penny

from exchequer on photograph of any government functionary
:

on governmgnt advertisements/campaigns which waS released

thereafter.

4. That

it is further submitted that the answering re:spondent

has launched an outdoor media campaign on Anti-Corruption

n
sssqili!

ryd

campaign Fart-II to n:ount on outdoor mode of mt:dia slrch as

Bus Qr.reue Shelters, Public utilities, Unipo1es, rrrsll wraps,

display boards, metro brid,ge panels, metro train inside panels,
LED screens I Lwe media& rent free sites for a period of 15 to

30 days w.e.f. 23.05.2015 to 22.06.2QI5 with bc.'nus rnedtaf

add on med.ia which was released on DAVP rates

committed, expend.iture incurred

and

on the above media is

approximately Rs. 3 Crores.

Further a campaign was released on increaseo uuciget on

Ed.ucation arld Health was launched for a period

of 15 -30

days with add on media/bonus daysin the outdoor media in

ad,dition to mobile media/ LED

screens /

dhallows

for

information of ctttzens w.e.f. 10.07.2OI5 to 09.08.'.2015 and an

expenditure of Rs. 4.5 crores was incurred on the riame'

he demise of the formel President of

.,

il-i
ti: '

.:-+rryrf.f,

lKqlqrn the
the answering
answerins rr:spondent
rr:snondent
uL. ,\rv r\vsqr Ka1am,

.-

a period of 15 daYs in atrl rent free

rented media for a P.r:riod of

15

a mark of respect for the departed leader. It is

submitted that the ongoing campaign which is likely to

days as

culminateon 09.08.2015 on rent free sites was renloved and

the campaign to pay homage' to Dr. Kaiam was nounted

within the same amount of moneyas mentioned above on hired
med.ia such as rent free sited, metro feeder br:.s, i.e. mobile

media, inside panel of metro train and LED sct:eens of which

only the expenditure of mounting and printing ilex charges

1

etc. would be paid additionally.Apart from the above, the

media which was hiredfor 15 daysfor the ongoing campaign
was removed due to the demiseof Dr. Kalam and some of the
rented med.ia for informing citizens was hired for a period of i5
days such as public utilities, bus queue shelters, metro bridge
panels, display boards, bicycle stands etc. in a iimited number

and expenditure on entire med.iawould be

al,pi oximately

Rupees 1.2 crores.

0

5. That as per official. records the details of amount invoived

on Print Media of Government advertisement aft,:r 13th May,

5 till rlate is sum of Rs. 2,19,75,8781- and the details

whereof are given in ANNEXURE '3A" hereto and that o11
2Of

Electronic med.ia comes to Rs. LI,43,48,78I

.^\
\3")
'\

ver,

till

l-

and the details

date no payment from the Government Funds

has been made.

Since

in terms of the order dated 29th Ju1;, f 015 this

Hon'Jrle Court has directed the Respondent No.

2 to furnish

the detail of arnount with regard to print and electrorr.ic media,

only, however,

in all fairness it is re levant to bring to the

notice of this Honble Court that besides tht: print and

electronic media the 'outdoor media' is other way for publicity

and whereon amount worth Rs. 8,70,00,000/- is 'committed

8::

:ji.,,r(l )irt: iirTZ

liability'to be paid after processing of the bills. TL^rs the gross

total arnount with regard to the print, electronic media and
also for outdoor publicity colrres to Rs. 22,33,24 ,659 I - for

which the source of paJrment is from

Advertisement Funds earmarked for

Government

Depa.r'tin

ent

of

information and publicity.

PARAWISE REPLY
1.

That the contents of the para under reply

are

: wrong and

denied aud the contents of the Preliminary Sub.inissions are

reaffirmed and reiterated.

It is reiterated tha1. the petition

und.er reply is not public interest litigation but

:i

"'t';t'1;And

tl'e same is

is actua-lly meant to settle poiitica-l scores as such the

petition under reply is liable to be dismissed with exemplary

costs.Rest of the contents are denied for want ol'k.,rowledge.

However assuming that the ,petition of the petitioner was

rejected by the Honble Apex Court, the Petition.er herein

can approach the Honble Apex Court by way of contempt

proceedings, as such

in view of the above, the present

petition is liabie to be d.ismissed with exemplary costs.

2. That the contents of the para under reply are v/rong and
denied.
o
-/

i'-='*t:i

s;

3. That the contents of the para u.nder reply are wrong and

denied and the contents of the reply are

re &J'i^ me

d and

reiterated. It is reiterated. thatthe answering respondent has

vide the alleged advertisements spread awaren(iss about

governmgnt policies, programmes, activities, achigvements,

services and. initiatives amongst the public, as such

it

is

wrong and cienied that the answering respondent is

misusing public funds for advertisements aimed at
glorificationas such the petition under reply

is liable to

para under replY are wrong and

5. That the ccntents of the para under reply are wrong and
d.enied and the Petitioner maybe

put to strict proof about

the same. It is reiterated that the petitioner does not have

the locus to institute the present petitionas n:' element of
pubiic interest in invoived in the present petition which is

politically motivated. and has been filed

in the guise of

pubiic interest to settle politicai scores as such the petition

und.er reply is liabie to be dismissed with exen:p.rry costs.

"Afanexrtre C" filed herewith are clippings from newspaper5

wherefrom

it is evid,ent that it is blatant violati,ln of the

guidelines iaid down

by the Honble Supreme Courtr orrr.ut

va--voL;t) c^!
I

Petitioner with an obiique pr-r<*ical motive5 ht'rs not

.",r.,.

rf

w=

f\rsq"*'
brought^ in view of

this Hon'ble

Cor-rrt

which

hows

the partisan bend of mind of the petitioner.

SA.That the contents of the para under reply arn wrong and

denied and the contents of the reply are reaffirmed and

reiterated.

It is reiterated that the judgrnent of the I{onble

Apex Court is misquoted by the petitioneras the same is nqt

applicable to the facts and circumstances of the ie

se.

6. That the contents of the para under reply are v,.rong and

denied ar:d the contents of the reply are reaffirmed and

reiterated.

It is reiterated that the petition ur cer reply is

premature as the three member body as directecl to

be

answering respondent is violating the Guid.elines stipulated

by the Honble Apex court. Rest of the contents

a=re

wrong

and denied.

7. That the contents of the para under reply are wrong and

denied and the contents of the reply are reaffirmed. and

reiterated.It

is submitted that the answering respond,ent

has not violated the Guid.elines laid down by the I{onble

Apex court.

It is lurther submitted that this Honble court

under writ jurisdiction cannot adjudicate/give directions on

ll

matters for which a machin ery f rnechanism has

been

stipulated. as such the petition und.er reply is. liable to be

dismissed with exemplary costs. Further

it is merely the

perception of the petitioner that the answering respondent

is violating the Guidelines laid down by the I-Ionble Apex

Court.

It is submitted that the answering responclent

is

bound to implement the Guidelines laid down , by the

Honbie Apex Court and the admission by the Petit,ioner that

the advertisements were modified by the

answering

respondent to the extent that the photograph of the Chief

Minister

-\^/as

replaced with his name is indicati're of the fact

that the a-riswering respondent has upheld the judgment of

the Hon'bie Apex Court in letter and spirit.

Re

'st of

the

ntents are wrong and denied,

reply do not pertain to

position to respond to
salne.

9. That the contents of the para under reply are vr'rong and.

denied and the contents of the reply are reaffirmed and

reiterated.

It is submitted that the answering respondent

has not violated the Guidelines laid down by the Hon'ble

Apex Court. It is r.vrorrg and denied that the advertisements

regularly aired/published by the answering respondent only

seek to glorify the chief Minister of Delhi and ir.Lu pa.rty in

power and to cast a negative impression of other parties,

12,

j: ri,.r,-aa;tri{8t ;-\"-!.}.,'*:i.;{,:

ii:i!:.:iiit;

critics etc, It is wrong and denied that the answering

respondent

is misusing public funds by airing

and

publishjng illegal advertisements. At the cost of repetition it

is reiteratcd that the petition under reply is

politically

motivated as the answering respondent has vide the alleged

advertisements spread awareness

about

government

policies, prograrnmes, activities, achievements, r;ervices and

initiatives amongst the public as such the petition und er

reply is liable to dismissed with costs.Rest of the contents
are wrong and denied.

REPLY TO BRIEF FACTS

lhat the contents

of the para

. Tha.t the contents of

need no reply,

the pa,ra2 need no reply.

That the contents of the para3 need no reply.

4-6. That the contents of paragraphs 4 to 6 beir,g matter of

record needs no repIy.

7. That the contents of the para under reply are wrong ernd
denied and the contents
reiterated.

of the reply are reaffirmed

and

It is submitted that the answering respondent

has

not violated. the Guid.elines laid d.own by the Horrble Apex

Court. It is further submitted that

it is merely the perception

of the petitioner that the answering respondent is vic,iating the

1a

IJ

]v*---trF

\5

tq
laid down by the Honble Apex Court. It is
subrnitted that the answering respondent is bound to

t'

Guid.elines

'

,.

implement the Guidelines laid. down by the Hon'ble Apex Court

a1d the admission by the Petitioner that the advertisements

were modified by the answering respondent to thc extent that

the photograph of the Chief Minister was replaced with his

narne is ind.icative of the fact that the answerin.g respondent

has upheld the judgment of the Honble Apex court in letter

and spirit.

It is further submitted that the answering respondent

has vide the

:alleged

ad.vertisements spread. 4s731Bn::ss about

government policies, programmes, activities, achievements,

ser-vices and initiatives anongst the public, as such

it is wrong

ering respondent is misusing public

aimed at glorification as such the

Ie to dismissed.

nts of the Preliminary submissions

are reaffirmed. and reiterated. It is reiterated that pursuant to

wherein restrictions the placed on the publication of the

of Government functionaries, and political

leaders, a TVC prepared by Delhi Governmet:'(- with the

photographs

photographs of Honble Chief Minister which was released for

telecast on News Channels was withdrawn and stopped from

telecast w.e.f. 15-16 lOSl2O15. Pursuant therqto the

government haS not spent a single penny from e tlcheqUer on
1A
r-r

f5

ft
photograph of any government functionary on government
advertisements/campaigns which was released therpafter.Rest
of the contents a-re wrong and denied.

8. That the contents of the para under reply are wrong and
denied.lt is submitted that the petitioner is making his own
presumptions and perceptions and is trying to nrrs;uide this
Flon'ble Court.

It is wrong and denied that the Directorate of

Information &

Publicity has been approving

advertisements on behalf

of

the

GNCTD without any effective

analysis/study in regard to thp expenditure of tlre proposed

commel'cia=ls/ad',,ertisements. Rest of the cOntents are wrong

the cqntents of the para under reply are wrong and

--'.''

.,,

,,,

,i4ed.

and the contents of Preiiminarv Submissjons and the

::'y'
.'/

,'' reply are reaffirmed and reiterated and are not being repeated
herein for the sake of brevity. It is wrong and denied that the
answering respondent has violated the Advertising Guidelines,

2OI4. Rest of the'contents are wrong and denied.

10.

That the contents of the para under reply insofar as the

sarne pertains to the judgment of the Honble Apex Court,

needs

no coinments. Rest of the contents are wrong

denied.

1(
-t -'

aad

tL

&,

lA. That the contents of the par.a under

rep)-,r arre wrong

and denied and. are based on assumptioris and

presumptions and perceptionsof the Petitioner. In this
regard the contents of the reply are reafirmed and
reiterate,C and are not being repeated herein

fo:

cl-.e

sake,of

brevity. It is denied that the advertisement aired

17

on

.06.2OI4 violated the Guidelines stipulated by the

Honble Apex Court.Rest of the contents are wrong and

denied.

i 18. That the contents of the pa;.a under repiy are wrong

and denied. and are based on assumptions ald

presumptions and perceptionsof the Petitioner. Admittedly

.i-1ri

petition the advertisement dated 24.06.2015

lights the policies and achievements and highlights the

--future road map

in the field of education by the ruling

p,arty, the petitioner is presuming that the

said

->/

advertisementviolates
a,

the Guidelines stipUia lr'rl by

the

Honble Apex Court. Rest of the contents are wrong and

denied.

1lC. That the contents of the para under repl'y are wrong

and denied and are based on assumptions and

prqsumptions and perceptiorls of the Petitioner. Admittedly

in the petition the

ad.vertisement

ated

highlights the policies and achievements

1A
I\J

QI 'Q7 .20 15

in the Health

Sector and highlights the fact that the educatiort budget has

been increased by 105%, the petitioner is presuming that

the said advertisement violates the Guidelines srtii^ulated by

the Honble Apex Court, Rest of the contents are wrong and
denied.

11D. That the contents of the para under

repl"'.7

are wrong

and denied a.nd the contents of paragraphs 3 &4 of the

Preliminarv Submissions are reaffirmed and reiterated.It is

reiterated that pursuant to the judgment of the Hon'lcle

Apex Court, the photographs of the Chief Minister were
withdrawn immediatelv. However
that

herein

the

it is pertinent to mention

displaying

sements/ campaignbearing

/,i
=l
ol

rr isterafter

.S,-:i'-'' of .th e,i'Iaw

Xor;':,' 't:. ,"-'

of

the photograph of

any

the

its expiry period is the sole responsibility

enforcing authority. As such the coit1.-nts of the

; ,,i;ii, paPS under reply are frivolous, wrong and denied.

E. That the contents of the para under reply are wrong and

denied and are based on assumptions and presumptions

and percepitions of the Petitioner. Admittedly in the petition

the advertisement highlights the policies and achievements

of the ruling party, the petitioner is presuming that the said

advertisement violates

the Guidelines stipukited by the

Honble Apex Court. Rest of the contents are wrong and

denied.
1'l
tt
:' i'2"t':'t::i:

ft

f*

L2-L4. That the contents of the paragraphs urrder reply

insofa.r as the Sarne pertains to a matter of record needs no

reply. It is pertinent to mention herein thal the funds

allocated PV the answering respondentfor the purpose of
Information and Fublicity is Rs. 526.74 crores which is the
outer limit to be spent for the purpose of dissemination of

t-

Information and Publicity. Total budget

is for

a sum of Rs. 4O,OOO Crores, out of which Rs. 523 Crores is

earmarked for Information and Publicily which comes to
1.518%. From the date of the Common Cause iudgment in

question, that is from 13tr'May,2Ol5 and tiIl derte, a sum of'

Rs. 22,33,24,6591-

&S mentioned above,

has been spent

Yr '\

well as outdno': publicity

i;,;1ii;ilA print, electronic med.ia as
,/,;,'

\i)::^,.

is from the date of judgment in

s to a very meager amount as

compared

to the total budget of Rs. 523 Crores for

Information and Publicity.

It is further submitted that the subject matter of the

answering respondent allocating funds in the budget for the

particular purpose is

a policy d.ecision as such it

is

apparent that the petitioner in the galb of public interest is

making averments with regard to a policy decision made in

the petition is trying to expand the scope of the petition. The
averments made

in the para under reply make' it apparent

18

i.?F.}.;!!:!E:51

m
that the petition is politically motivated.Rest of the cQntents
are wrong and denied.

15. That the contents of the para under reply are wrong and
denied. arrcl the contenrs of the Preliminary Submissions and

repiy are reaffirmed and reiterated and aqe not being repeated
herein for the sake of brevity.Rest of the contentri 2-f wrong
and denied.It is reiterated that the petition under re:p$ besiCes
being politically motivated. is based on the presumptions and
perceptions of the petitioner; as such the same is liable to be
dismissed.

Lq.. ThAt

the contents of the para under reply are wrong and

at the petition is premature and is

ttedly the petitioner has approached

the basis of certain articles

in

edlY states that the answering

respondent wouid launch a massive ad campaign pertaining to
a loan scheme to students.As suchthe motive of ttre Petitioner

is clearly to malign his politicaL ad.versary and to settle politica-l

scores.Rest of the contents are wrong and denied.

l7-l8.That the contents of the paragraphs under reply

are

wrong ancl .lenied and the contents of the reply a:'e reaffirmed
and reiterated and are not being repeated herein for the sake

of brevity.It is wrong and denied that the fund is being mislc)

::,ii

r-rtilised by the answering respondent continuous PR exerclse

is to slam the dicsenting opinion and voice of the opposition at

tlr.e cost of pubiic funds.Rest of the contents a-re wrong and
denied.

19. That the contents of the para under reply arr \ rrong and

denied; are vague and evasive and are based on assumptions

ancl presumptions. As such the petition und.er repiy is liable to

be dismissed with

costs.The contents

of the reply ate

reaffirrned and reiterated and are not being repe;r c^d for the

.20-22. That the contents of the paragraphs uncler reply

ar.e

-t

\r
\AlroFAand denied and the contents of the repiy ai'g reaffirmed

i/ jj;''
,

;i

iterated and a-re not being repeated for the sake of

.:: :'

It is reiterated that the petition under reply Is

acious and the sarne has been filed in the guise of
public interest and is actually meant to settle po..itical scores
as such the petition under reply is liabie to be disr.nissed with
exemplary costs,

'

REPLY TO GROUNDS

1. That

the contents the ground under being matter of record

needs no replv.

?0

bl
2. Thatsince the ground under reply does not pertain to the
answering respondent as such the answering reSpondent is

not in a position to reply to tfre salrle.

3. That the contents the ground under being mat[er of record
needs no repltt.

4. That the contents of the ground under reply are wrong arrd
denied. It is submitted that the Guidelines

laid ic-vn by the

Hon'ble Apex Court under Article L42 ts the law of the land,
as such consequences would follow if there is any infraction

of the sard law sooner or later, as such the averment that

the purpose of the Act would be defeated withc lt the three

member bod';

in

existence

is has no force.Rest of

the

t the contents of the ground under reply need no repiy.

,/t,

That the contents of the ground under reply

a-re vague is

based on conjectures and surmises and assut itptions and

presumptions. It is submitted. that the petitioner has made

general allegations against governments exploiting the

absence of the

3 member body, as such the a'ierrnents

made in the ground under reply are bereft of me .rit.

8. That the contents

of the ground und.er reply need. no reply.

21

9. That the cqntents of the ground under reply ar.e wrong and

denied and the contents of the reply are

reiterated.

rea lfirmed and

It is wrong and denied that the

answering

respondent has been airing advertisements promoting its

political and personal interests and the contents of the reply
are reaffirmed and reiterated.

10,

That the contents of the ground under reply are vrrong and

of the reply are reaflirmed and

d.enied and the contents

-

reiterated and are not beirrg repeated for the sale of brevity.

It is \ rrorlg arrd d enied that the advertisement is aimed at

glorification of the Chief Minister of Delhi and is aimed at
achieving political and personal benefits.

t the contents of the grounds under reply rr'pqtitive and

same has been dealt with by the answering Respondent

reply to paragraph 11A of the repiy on merits as such the

contents of paragraph 11A of the repiy on merits and the

reply are reaffirmed and reiterated and

?.r(, . -ot being

repeated ior the sate of brevity.It is wrong and denied that

the answering respondent has violated the

p;r-ridelines

stipulated by the Honble Apex Court. It is reiterated ,that the

averments made

in the grounds under reply ai'e based on

the assumptic,ns and presumptions and perceptions of the

Petitioner, as such the petition under reply is liable to be

,//ar

-\
tt

/4

<':'i-;i':'.ti:i],;t:':df li{:::1jii::::'.it;i

TV
dismissed with costs.Rest of the contents are wrong and
denied.

23

That the contents of the pa:.a under reply ar I rong and

d,enied and the contents

of the reply are reaffirmed and

reiterated.

24.

That the contents of the ground under reply a e repetitive,

wrong and d:nied and the contents of the reply

are

In this regard. the answering

respond.ent craves leave to refer to and rely upon the

reaffirmed and reiterated.

contents of paral lB of the reply on merits.It is reiterated the

contents of the ground. und.er reply a-re wrong and denied

and

a-re based

on assumptions and presumptions

and

ptions of the Petitioner. Admittedly in the petition the

vertisement date d, 24,06.2015 highlights the policies and
hievements and highlights the future road ma:., j-r the field
of education by the ruling pAfiy, the petitioner is presuming

that the said advertisement violates the

Cuidelines

stipulated by the Honble Apex Court. Rest of the contents

a-re

wrong and denied.

25. That the contents of the ground under reply a.re repetitive,
wrong and denied and the contents of the repiy
reaffirmed and reiterated.
respondent craves Ieave
^z-

are

In this regard tht: answering

to refer to and relv upon the

vq

b
contents of para 11C of the reply on merits.Rest of the
contents are wrQng and denied.

26.

That the contents of the ground under reply are v'rong and
d.enied.

and the contents of the reply are reaffirmed and

reiterated.

27-28. That the contents of the ground.s under reply are repetitive,

wrong and denied. afid, the contents of the repiy

reaffirmed and reiterated,.
respondent craves leave
contents of para

In this regard thc

are

answering

to refer to and relrl upon

the

l1E of the reply on merits. Rest of the

contents a-re wrong and denied.

29-32. That the contents of the grounds under reply iirr'. reptitrve,

tqnieilts of parasL2-I4 of the reply on merits. it is further

submitted that the subject matter of the answering
respondent allocating funds in the budget for the particuiar
purpose is a poiicy decision as such

it is appa.rent that the

petitioner in the garb of public interest is making averments

with regard to a policy decision made in the petitiorr is trying

to expand the scope of the petition. The averments made

the para under reply make

')A
L-r

it

apparent that the petition

aqz7li:tftz

1n
1S

politically. motivated. Rest of the contents are wrong and

denied.

33-34 That in repiy to the contents of the grounds uncer reply it is

reiterated that the present petition has been filed

in

the

guise of public interest to settle political scoresas the

petitioner is a political ad.versary of the party in power ,in
Delhi.It is submitted that there is no violation of Articie

or Article 2I of the Constitution by the

L4

answering

respondent:and the contents of the reply are reaffirmed and

reiterated. It is reiterated that the answering respondent has

vide advertisements has spread awareness

about

government policies, prograrnrTres, activities, acliiu'rentents,

services and initiatives a nongst the public since the public

has a right to such information.Further the conte::rts of the

repiy are reaffirmed and reiterated and are not

being

repeated herein for the sake of brevity.Rest of ,:he contents

are wrong and denied.

contents of the grounds 35-37 needs no reply.

3 I i: ;i i> l:

i'llirc:tQ
-'\

:-,-.

'v

l-r

I-

3,9_

atthe contents of the ground under reply is 1, erverse and

a

unsustainable in law as the sarne is meant to ovgr-reach

*t

a.

and modify the Judgment of the Honble Apex Court;which

cannot be permitted. in the present proceed.ings. As such the

')<
LJ

,iil?{t+

&..
'r,j}"

petition under reply is liable to be dismissed wittr exemplary

costs.

That the contents of the grounds 39 needs no reply.

J:/.

40. That the contents of the ground under reply insofar as the
same being a matter of record needs no reply. Rest of the

contents are wrong and denied. It is wrong and denied that

the answering respondent has widened the gap by

circumventing the guidelines stipulated by the Apex Court

for persor'r.al and political gains. It is, submittcd that the

contents of the grounds under reply are based on the
presumptions and perception of the petitioner and as such

the same are devoid of any merits.

4I.

That the contents of the grounds under reply are wrong and

denied and the contents of the reply are reaffirmed. and

reiterated.

It is submitted that the answering

respondent

has not violated the guideiines stipulated k,y the Apex

',;iiCourt and has tried to implement the same

,;

in ietter and

,i:,rjispirit, as such the petition under repiy is misconceived and

.rr/u"'''

is liable to be dismissed with exemp

M. C. MAURYA
Dv. Director/HOQ
Dte. Infoimation & PublicitY
Govt. of NCT of Dolhl

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Kesari (Delhi, Jaipu0,
Dainik Tribune
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0P(P/D), Jadeed-lnDinon
Delhi editions - HT, Hindu,
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