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Code No:

Group: (M/S)
District: Lucknow
IN THE HON’BLE HIGH COURT OF JUDICATURE AT
ALLAHABAD, LUCKNOW BENCH, LUCKNOW.
WRIT PETITION NO. (M/S) OF 2019
Ankita Yadav …….………………..Petitioner
Versus
State of U.P. & others ………………….……opposite parties
INDEX
S.No. Particulars Page No.
1. List of Date and events. Separate
2. Application for Interim relief. Separate
3. Memo of Writ Petition.
4. ANNEXURE NO.1
The photo copy of the death certificate of the
grandfather
5. ANNEXURE NO.2
The photo copy of the electricity Bill on the
name of the father of the petitioner
6. ANNEXURE NO.3.
The application dated 08.04.2019 of the
petitioner
6. Affidavit along with I.D
7. Vakalatnama.
Lucknow :
Dated : .2019
( Surendra Yadav)
Advocate
Counsel for the Petitioner
Mobile No. 9389281118

Code No:
Group: (M/S)
District: Lucknow
IN THE HON’BLE HIGH COURT OF JUDICATURE AT
ALLAHABAD, LUCKNOW BENCH, LUCKNOW.
WRIT PETITION NO. (M/B) OF 2019
Ankita Yadav …….………………..Petitioner
Versus
State of U.P. & others ………………….……opposite parties
DATES AND EVENTS

S.No. Date Events


1. The Petitioner is resident of village
Kanchanpur Matiyaari, Chinhat,
Lucknow and petitioner have
Mahrajdeen Complex situated at
Matiyaari Chauraha , Deva Road
Lucknow and in passion peacefully,
over the Mahrajdeen Complex in
question since many long years.
2. The Mahrajdeen Complex was built by
the grandfather of the petitioner and a
power/electricity connection was taken
by her grandfather from opposite party
no.2 in the Mahrajdeen Complex
situated at Matiyaari Chauraha , Deva
Road Lucknow and a power
connection account no. 1865960000
has been generated on the name of the
father of the petitioner.
3. 2018 Grandfather of the petitioner was died
in 2018 livening behind him two son
namely Arun Kumar and Amrit Lal.
4. After the death of the grandfather of the
petitioner, father of the petitioner has
lost his mental health.
5. 28.01.2019 Uncle of the petitioner namely Amrit Lal
also died in the year of 28 January
2019 living behind him his wife namely
Preeti yadav who is legal heirs of the
Late Amrit Lal and she is living with the
family of the petitioner.
6. Opposite party no. 3 has prepared fake
and fabricated documents for the
purpose of grabbing the Mahrajdeen
Compex which was made by the Grand-
father of the petitioner and had taken
power connection on her own name
illegally.
Opposite party no. 3 have no interest,
right in the property of the grandfather
of the petitioner but opposite party no.2
has given power connection and
transferred the power connection
account which was registered on the
name of the father of the petitioner, on
the name of the opposite party no.3
illegally.
Due to fake and fabricated entry has
taken place in the record of the power
corporation/opposite party no.2 and
name of the opposite party no.3 has
wrongly entered and she have taken
power connection and opposite party
no.2 has wrongly transferred the power
connection account on the name of the
opposite party no.3 , opposite party
no.3 is taking undue advantage want to
dispossess from the peaceful
possession of the petitioner illegally and
Forcibly and when Petitioner tried to
stop to doing it she threatening to kill
and she tried to take possession
illegally without any right in most illegal
and arbitrary manner.
Petitioner has made her objection
regarding the power connection of the
opposite party no.3, before the opposite
party no.2 but no heed has been paid
by the opposite party no.2.
The opposite party no. 2 have
transferred the power connection of the
father of the petitioner without inviting
the objection from the legal heirs of the
uncle and grandfather of the petitioner
and without giving an opportunity of
hearing to the Petitioner
08.04.2019 on 08.04.2019 application, petitioner
no. 1 has given an application to the
opposite party no.2 and requested to
stop the illegal act of the opposite party
no. 3 and take appropriate legal action
against the opposite party no.3 but no
action has been taken by the opposite
party no.2 and same is pending till date.
7. Hence this writ petition.
Lucknow :
Dated : .2019
( Surendra Yadav)
Advocate
Counsel for the Petitioner
Mobile No. 9389281118

Code No:
Group: (M/S)
District: Lucknow
IN THE HON’BLE HIGH COURT OF JUDICATURE AT
ALLAHABAD, LUCKNOW BENCH, LUCKNOW.
WRIT PETITION NO. (M/S) OF 2019

Ankita Yadav aged about 25 years, D/O Arun Kumar Yadav,


resident of village-42-Kanchanpur Matiyari, Chinhat, District-
Lucknow, U.P.
…….…..Petitioner

Versus
1. State of U.P. Through Collector District-Lucknow.
2. Chief Engineer Madhyanchal Electricity Distribution Corporation
Limited, Lucknow, U.P.
3. Renu Gautam resident of village-Kanchanpur Matiyari, Chinhat,
District- Lucknow, U.P.
………Opposite parties.

Writ Petition under Article 226 of the Constitution of India


To,
The Hon’ble Chief Justice and his other Hon’ble his other
companion judge of this Hon’ble High court.

The Petitioner above named most respectfully begs to submit


as under:-

1. That this is the first writ petition of its own nature. the Petitioner
declare that they have not field any other writ petition prior to
the present writ petition challenging the same subject matter,
either at Allahabad or at Lucknow Bench of this Hon’ble Court.

2. That it is further submitted by the above named Petitioner, that


the Petitioner have not received any notice/information or copy
of any caveat application from any of the opposite parties, till
today, either through the registered post or by any other mean.

3. That the Petitioner are seeking writ, order or direction in the


nature of mandamus to the opposite parties to direct to provide
power/electricity connection to name of my father, in the
interest of justice.

4. That for the proper disposal of the case brief fact of the case is
given as under.

5. That it is pertinent to mention here that grandfather of the


petitioner was died in 2018 livening behind him two son namely
Arun Kumar and Amrit Lal and after the death of the
grandfather of the petitioner, father of the petitioner has lost his
mental health. The photo copy of the death certificate of the
grandfather is being field as ANNEXURE NO1.to this writ
petition.

6. That it is pertinent to mention here that uncle of the petitioner


namely Amrit Lal also died in the year of 28 January 2019 living
behind him his wife namely Preeti yadav who is legal heirs of
the Late Amrit Lal and she is living with the family of the
petitioner.

7. That, the Petitioner is resident of village Kanchanpur Matiyaari,


Chinhat, Lucknow and petitioner have Mahrajdeen Complex
situated at Matiyaari Chauraha , Deva Road Lucknow and in
passion peacefully, over the Mahrajdeen Complex in question
since many long years.

8. That the Mahrajdeen Complex was built by the grandfather of


the petitioner and a power/electricity connection was taken by
her grandfather from opposite party no.2 in the Mahrajdeen
Complex situated at Matiyaari Chauraha , Deva Road Lucknow
and a power connection account no. 1865960000 has been
generated on the name of the father of the petitioner. The photo
copy of the electricity Bill on the name of the father of the
petitioner is being field as ANNEXURE NO2.to this writ petition.

9. That it is pertinent to mention here that opposite party no. 3 has


taken a power connection illegally on the basis of the forged
and fabricated document.

10. That it is pertinent to mention here that opposite party no. 3 has
prepared fake and fabricated documents for the purpose of
grabbing the Mahrajdeen Compex which was made by the
Grand-father of the petitioner and had taken power connection
on her own name illegally.

11. That it is pertinent to mention here that opposite party no. 2 with
the collusion of the opposite party no. 3 has given power
connection on the name of the opposite party no.3 in very
illegally and arbitrary manner.

12. That it is pertinent to mention here that opposite party no. 3


have no interest, right in the property of the grandfather of the
petitioner but opposite party no.2 has given power connection
and transferred the power connection account which was
registered on the name of the father of the petitioner, on the
name of the opposite party no.3 illegally.

13. that due to fake and fabricated entry has taken place in the
record of the power corporation/opposite party no.2 and name
of the opposite party no.3 has wrongly entered and she have
taken power connection and opposite party no.2 has wrongly
transferred the power connection account on the name of the
opposite party no.3 , opposite party no.3 is taking undue
advantage want to dispossess from the peaceful possession of
the petitioner illegally and Forcibly and when Petitioner tried to
stop to doing it she threatening to kill and she tried to take
possession illegally without any right in most illegal and
arbitrary manner.

14. That petitioner has made her objection regarding the power
connection of the opposite party no.3, before the opposite party
no.2 but no heed has been paid by the opposite party no.2.

15. That on 08.04.2019 application, petitioner no. 1 has given an


application to the opposite party no.2 and requested to stop the
illegal act of the opposite party no. 3 and take appropriate legal
action against the opposite party no.3 but no action has been
taken by the opposite party no.2 and same is pending till date.
The application dated 08.04.2019 of the petitioner is being field
as ANNEXURE NO3.to this writ petition.

16. That the opposite party no 3 tried to dispossess to the


Petitioner from their peace full possession over the Mahrajdeen
Complex without any right and title, in most arbitrary manner.
17. That the opposite party no. 2 have transferred the power
connection of the father of the petitioner without inviting the
objection from the legal heirs of the uncle and grandfather of
the petitioner and without giving an opportunity of hearing to the
Petitioner.

18. That the action of the opposite parties is illegal and bad in the
eyes of law.

19. That rules of natural justice have been violated by the opposite
parties.

20. That the fundamental rights granted under the constitution of


India to the Petitioner have been violated by the opposite
parties.

21. That the act and conduct of the opposite parties is not
sustainable in the eyes of law and same is illegal, arbitrary &
vogue in the interest of the justice.

22. That the Petitioner aggrieved and having no other efficacious


alternative remedy except invoking the extra ordinary
jurisdiction of this Hon’ble Court is filing the instant writ petition
under Article 226 of the Constitution of India on the following
amongst other grounds:-

GROUNDS

a. Because, grandfather of the petitioner was died in 2018 livening


behind him two son namely Arun Kumar and Amrit Lal and after
the death of the grandfather of the petitioner, father of the
petitioner has lost his mental health.
b. Because, uncle of the petitioner namely Amrit Lal also died in
the year of 28 January 2019 living behind him his wife namely
Preeti yadav who is legal heirs of the Late Amrit Lal and she is
living with the family of the petitioner.
c. Because, the Petitioner is resident of village Kanchanpur
Matiyaari, Chinhat, Lucknow and petitioner have Mahrajdeen
Complex situated at Matiyaari Chauraha , Deva Road Lucknow
and in passion peacefully, over the Mahrajdeen Complex in
question since many long years.
d. Because, the Mahrajdeen Complex was built by the grandfather
of the petitioner and a power/electricity connection was taken
by her grandfather from opposite party no.2 in the Mahrajdeen
Complex situated at Matiyaari Chauraha , Deva Road Lucknow
and a power connection account no. 1865960000 has been
generated on the name of the father of the petitioner.
e. Because, opposite party no. 3 has taken a power connection
illegally on the basis of the forged and fabricated document.
f. Because, opposite party no. 3 has prepared fake and fabricated
documents for the purpose of grabbing the Mahrajdeen
Compex which was made by the Grand-father of the petitioner
and had taken power connection on her own name illegally.
g. Because, opposite party no. 2 with the collusion of the opposite
party no. 3 has given power connect on the name of the
opposite party no.3 in very illegally and arbitrary manner.
h. Because, opposite party no. 3 have no interest, right in the
property of the grandfather of the petitioner but opposite party
no.2 has given power connection and transferred the power
connection account which was registered on the name of the
father of the petitioner, on the name of the opposite party no.3
illegally.
i. Because, due to fake and fabricated entry has taken place in
the record of the power corporation/opposite party no.2 and
name of the opposite party no.3 has wrongly entered and she
have taken power connection and opposite party no.2 has
wrongly transferred the power connection account on the name
of the opposite party no.3 , opposite party no.3 is taking undue
advantage want to dispossess from the peaceful possession of
the petitioner illegally and Forcibly and when Petitioner tried to
stop to doing it she threatening to kill and she tried to take
possession illegally without any right in most illegal and
arbitrary manner.
j. Because, on 08.04.2019 application, petitioner no. 1 has given
an application to the opposite party no.2 and requested to stop
the illegal act of the opposite party no. 3 and take appropriate
legal action against the opposite party no.3 but no action has
been taken by the opposite party no.2 and same is pending till
date.
k. Because, the opposite party no 3 tried to dispossess to the
Petitioner from their peace full possession over the Mahrajdeen
Complex without any right and title, in most arbitrary manner.
l. Because, the opposite party no. 2 have transferred the power
connection of the father of the petitioner without inviting the
objection from the legal heirs of the uncle and grandfather of
the petitioner and without giving an opportunity of hearing to the
Petitioner.
m. Because, the action of the opposite parties is illegal and bad in
the eyes of law.
n. Because, rules of natural justice have been violated by the
opposite parties.
o. Because, the fundamental rights granted under the constitution
of India to the Petitioner have been violated by the opposite
parties.
p. Because, the act and conduct of the opposite parties is not
sustainable in the eyes of law and same is illegal, arbitrary &
vogue in the interest of the justice.

PRAYER

(i) To issues a writ, order or direction in the nature of mandamus


to the opposite parties to direct to provide power/electricity
connection to name of my father and take appropriate legal
action against the responsible persons, in the interest of justice.
(ii) To direct the opposite parties to decide the representation of
the Petitioner within the stipulated time in accordance with law,
in the interest of justice.

(iii) To issue any other order or direction which this Hon’ble High
Court may deem fit and proper may pass in favor of the
Petitioner.

(iv) To allow the petition with costs.

Lucknow :
Dated : .2019
( Surendra Yadav)
Advocate
Counsel for the Petitioner
Mobile No. 9389281118
IN THE HON’BLE HIGH COURT OF JUDICATURE AT
ALLAHABAD, LUCKNOW BENCH, LUCKNOW.
WRIT PETITION NO. (M/B) OF 2019
C.M. APPLICATION NO. of 2019
In Re:
Ankita Yadav …….………………..Petitioner
Versus
State of U.P. & others ………………….……opposite parties

Application for Interim Relief


To,
The Hon’ble Chief Justice and all his
Companion judges of this Hon’ble Court

For the fact, reasons and circumstances stated in the


accompanying writ petition, duly supported by an affidavit, it is
most respectfully prayed that this Hon’ble court may kindly be
pleased to direct to opposite parties to provide power/electricity
connection to name of my father, in the interest of justice.

Any other order or direction which this Hon’ble


court may deem fit just and proper may also kindly be passed in
favor of the petitioner.

Lucknow :
Dated : .2019
( Surendra Yadav)
Advocate
Counsel for the Petitioner
Mobile No. 9389281118
IN THE HON’BLE HIGH COURT OF JUDICATURE AT
ALLAHABAD, LUCKNOW BENCH, LUCKNOW.
WRIT PETITION NO. (M/B) OF 2019
Ankita Yadav …….………………..Petitioner
Versus
State of U.P. & others ………………….……opposite parties

AFFIDAVIT

I, Ankita Yadav aged about 25 years, D/O Arun


Kumar Yadav, profession-private work, qualification -literate ,
religion –Hindu, resident of village- 42-Kanchanpur Matiyari,
Chinhat, District- Lucknow, U.P.and resident of present address
mentioned above for which she is filling photocopy of the
Aadhar card and also fixed her photo graph, the deponent do
hereby solemnly affirm and states on oath as under:-
1. That the deponent is the Petitioner no.1 and as such she is fully
conversant with the facts case.
2. That the content of paragraph 1 to & to of the writ petition
are true to my own knowledge and those of paragraph to &
are believed to be true on the basis of record and the
contents of paragraph to are believed to be true on the basis
of legal advice.
3. That the Annexure no. 1 and 3 of the writ petition true/Photostat
copies of his respective original and are duly compared by the
deponent.

Lucknow :
Dated : .2019

Deponent
VERIFICATION
I, the deponent named above do hereby verify that
the contents of paragraph 1 to 3 of this affidavit are true to my
personal knowledge. No part of it is false and nothing material
has been concealed.
So help me GOD.

Lucknow :
Dated : .2019 Deponent
I, identify the deponent who has signed/put L.T.I.
before me on the basis of records produced by him.

(Surendra Yadav)
Advocate on Roll B/S-1454
Regd. No. U.P.3959/2007
Mobile.9389281118

Solemnly affirmed before me on .2019 at a.m./p.m. by


Ankita Yadav, the deponent who has been identified by Sri
Surendra Yadav Advocate High Court, Lucknow Bench,
Lucknow.
I have satisfied myself by examining the deponent that he
understands the contents of this affidavit which has been read
over and explained to him by me.

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