2. The Special Secretary, Tamil Nadu Legislative Assembly Secretariat, Fort St. George Chennai 600 009. … Respondents Page No. 1 No. of corns: Nil   COMMON COUNTER AFFIDAVIT FILED BY THE SECOND RESPONDENT

IN THE HIGH COURT OF JUDICATURE AT MADRAS
(Special Original Jurisdiction)

WMP Nos.
in
WP No. 29205 of 2023

T.Manohar
S/o.Thangavel
No.147, R.K.Nagar, Perumal Koil Street
Periyasekkadu
Madhavaram Milk Colony
Chennai 600 051 … Petitioner in WP.No.29205 of 2023

Vs.

1. Mr. Udhayanidhi Stalin
S/o.M.K.Stalin,
Hon’ble Minister for Youth Welfare &
Sports Development,
Government of Tamil Nadu,
Secretariat, Fort St. George,
Chennai 600 009.

2. The Special Secretary,
Tamil Nadu Legislative Assembly
Secretariat, Fort St. George
Chennai 600 009. … Respondents

Page No. 1
No. of corns: Nil

COMMON COUNTER AFFIDAVIT FILED BY THE SECOND RESPONDENT
I, K. Srinivasan, son of V. Krishnan (late), aged 59 years, residing at No.5, Prakasam Street, Anbalagan Nagar, Sembium, Perambur, Chennai-600 011, do hereby solemnly affirm and sincerely state as follows:
1. I am filing this Counter Affidavit on behalf of the second respondent herein. I am well acquainted with the facts and circumstances of the case as per records.
2. It is submitted that it is necessary to clarify that the post of Special Secretary comes under a separate category with different responsibilities than that of Secretary. Further, the post of Secretary holds the position of the Head of the Legislative Assembly Secretariat and carries all responsibilities.
3. With regard to the petitioners’ request for the production of the video recording of the meeting recorded by the Thanthi News Channel, it is submitted that the meeting was not organized by the Government and it was organized by a private organization. The meeting has been recorded by a private agency and it is imperative to emphasize the point that the Assembly Secretariat has no role in this matter.

Page No. 2
No. of corns: Nil

4. It should be noted that the petitioner’s inclusion of additional claims or issues in the original writ may raise procedural concerns or necessitate a distinct legal process for their consideration.
5. The petitioner has not joined the proper and relevant respondents as party in the writ petition. The Secretary , Assembly Secretariat or the Special Secretary are not the proper officers to execute any action in support of the prayer of Quo Warranto against a Minister unless the provisions of law for disqualification are attracted .
6. In view of the above, it is humbly prayed that this Hon’ble Court may be pleased to dismiss the present Writ miscellaneous petition as not maintainable and devoid of merits and thus render justice.

Solemnly affirmed at Chennai
On this th day of November 2023 and BEFORE ME
Signed his name in my presence.

Page No. 3
No. of corns: Nil

IN THE HIGH COURT OF JUDICATURE AT MADRAS
(Special Original Jurisdiction)

W.M.P Nos.
in
WP No. 29205 of 2023

COMMON COUNTER AFFIDAVIT FILED BY THE SECOND RESPONDENT

STATE GOVERNMENT PLEADER

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