[CLEAN COPY]
IN THE HIGH COURT OF JUDICATURE AT MADRAS
W.M.P. No. of 2024
In
W.P. NO: 20193 OF 2024
A. Mohan doss,
No.13/2, Khan street,
Choolaimedu, Chennai – 600 094.
-Vs-
1) R.S.Bharathi Organising Secretary,
Dravida Munnetra Kazhagam,
No.367 and 369, Anna Salai, Teynampet, Chennai – 600 018.
Residing at
No.18, 29th Street, Thillai Ganga Nagar, Nanganallur, Chennai – 600 061. … Petitioner
/Proposed 3rd Respondent
2) Union of India,
Represented. By its secretary,
Ministry of home affairs, …1st Respondent/Petitioner
New Delhi – 110 001. …2nd Respondent/ Respondent
3) State of Tamil Nadu,
Represented. By its secretary,
Ministry of Home, Prohibition and Excise Department, Secretariat, Chennai – 600 009.
…3rd Respondent/ Respondent
Affidavit of A. Mohan doss
I, A. Mohan doss, S/o. Antony, Hindu, aged about 54 years and residing at No.13/2, Khan Street, Choolaimedu, Chennai – 600 094 do solemnly affirm and sincerely state as follows :
- I am the petitioner to be impleaded in the Writ Petition No. 20196 of 2024 and as such am well acquainted with the facts of the case.
-2-
- I state that the petitioner in W.P. has filed this Writ petition in connection with “Bharathiya Sakshya Adhinayam, 2023” which has been introduced on 12.12.2023 passed in Parliament 20.12.2023. At the time of 1st Respondent/petitioner’s political party has 39 members in Parliament and what should have been raised in Parliament but not raised cannot be raised in a court of law.
- I state that the said law has been passed and made to be applicable throughout Bharath, that is India, and as such this is not the forum to raise this issue. Already some person or persons had raised this in the Supreme Court of India and the Apex body is seized of the matter, and passed orders to the effect that the law has the sanction and authority of this sovereign nation.
- I however state that unless the papers connected with the said W.P. are given to me I will not be able to file a counter. However what I want to insist and say is inasmuch the petitioner has a case against the Adhinayam likewise I too have a case against the person who raises objection to the law enacted by Parliament and put into effect on and from 18 July 2024.
I, therefore humbly pray that this Hon’ble court may be pleased to grant me an order permitting me to be impleaded as respondent in the main W. P. No. 20193 of 2024 and pass such other order or orders as this Hon’ble Court may deem fit and proper in the circumstances of the case and thus render justice.
Solemnly affirmed at Chennai BEFORE ME on this 29th July 2024 and signed his name in my presence.
ADVOCATE IN THE HIGH COURT OF JUDICATURE AT MADRAS
(UNDER ARTICLE 226 OF THE CONSTITUTION OF INDIA)
W.M.P. No. of 2024
In
W.P. NO: 20193 OF 2024
A. Mohan doss,
No.13/2, Khan street,
Choolaimedu, Chennai – 600 094.
-Vs-
1) R.S.Bharathi Organising Secretary,
Dravida Munnetra Kazhagam,
No.367 and 369, Anna Salai, Teynampet, Chennai – 600 018.
Residing at
No.18, 29th Street, Thillai Ganga Nagar, Nanganallur, Chennai – 600 061. … Petitioner
/Proposed 3rd Respondent
2) Union of India,
Represented. By its secretary,
Ministry of home affairs, …1st Respondent/Petitioner
New Delhi – 110 001. …2nd Respondent/ Respondent
3) State of Tamil Nadu,
Represented. By its secretary,
Ministry of Home, Prohibition and Excise Department, Secretariat, Chennai – 600 009.
…3rd Respondent/ Respondent
IMPLEAD PETITION
For the reasons stated in the accompanying Affidavit the petitioner humbly prays that this Hon’ble Court may be pleased to grant the petitioner an order permitting the petitioner to be impleaded as a Respondent in the main Writ Petition No. 20193 of 2024 and pass such other order or orders as this Hon’ble Court may deem fit and proper in the circumstances of the case and thus render justice.
Dated at Chennai on this the 29th July 2024.
COUNSEL FOR PETITIONER
[CLEAN COPY]
IN THE HIGH COURT OF JUDICATURE AT MADRAS
W.M.P. No. of 2024
In
W.P. NO: 20195 OF 2024
A. Mohan doss,
No.13/2, Khan street,
Choolaimedu, Chennai – 600 094.
-Vs-
1) R.S.Bharathi Organising Secretary,
Dravida Munnetra Kazhagam,
No.367 and 369, Anna Salai, Teynampet, Chennai – 600 018.
Residing at
No.18, 29th Street, Thillai Ganga Nagar, Nanganallur, Chennai – 600 061. … Petitioner
/Proposed 3rd Respondent
2) Union of India,
Represented. By its secretary,
Ministry of home affairs, …1st Respondent/Petitioner
New Delhi – 110 001. …2nd Respondent/ Respondent
3) State of Tamil Nadu,
Represented. By its secretary,
Ministry of Home, Prohibition and Excise Department, Secretariat, Chennai – 600 009.
…3rd Respondent/ Respondent
Affidavit of A. Mohandoss
I, A. Mohandoss, S/o. Antony, Hindu, aged about 54 years and residing at No.13/2, Khan Street, Choolaimedu, Chennai – 600 094 do solemnly affirm and sincerely state as follows :
- I am the petitioner to be impleaded in the Writ Petition No. 20196 of 2024 and as such am well acquainted with the facts of the case.
-2-
- I state that the petitioner in W.P. has filed this Writ petition in connection with “Bharathiya Nayaya Sankita, 2023” which has been introduced on 12.12.2023 passed in Parliament 20.12.2023.
- At the time of 1st Respondent/petitioner’s political party has 39 members in Parliament and what should have been raised in Parliament but not raised cannot be raised in a court of law.
- I state that the said law has been passed and made to be applicable throughout Bharath, that is India, and as such this is not the forum to raise this issue. Already some person or persons had raised this in the Supreme Court of India and the Apex body is seized of the matter, and passed orders to the effect that the law has the sanction and authority of this sovereign nation.
- I however state that unless the papers connected with the said W.P. are given to me I will not be able to file a counter. However what I want to insist and say is inasmuch the petitioner has a case against the Bharathiya Nayaya Sankita likewise, I too have a case against the person who raises objection to the law enacted by Parliament and put into effect on and from 18 July 2024.
I, therefore humbly pray that this Hon’ble court may be pleased to grant me an order permitting me to be impleaded as respondent in the main W. P. No. 20195 of 2024 and pass such other order or orders as this Hon’ble Court may deem fit and proper in the circumstances of the case and thus render justice.
Solemnly affirmed at Chennai BEFORE ME
on this 29th July 2024 and signed his name in my presence.
ADVOCATE IN THE HIGH COURT OF JUDICATURE AT MADRAS
(UNDER ARTICLE 226 OF THE CONSTITUTION OF INDIA)
W.M.P. No. of 2024
In
W.P. NO: 20195 OF 2024
A. Mohan doss,
No.13/2, Khan street,
Choolaimedu, Chennai – 600 094.
-Vs-
s
1) R.S.Bharathi Organising Secretary,
Dravida Munnetra Kazhagam,
No.367 and 369, Anna Salai, Teynampet, Chennai – 600 018.
Residing at … Petitioner
/Proposed 3rd Respondent
No.18, 29th Street, Thillai Ganga Nagar,
Nanganallur, Chennai – 600 061. …1st Respondent/Petitioner
2) Union of India,
Represented. By its secretary,
Ministry of home affairs,
New Delhi – 110 001. …2nd Respondent/ Respondent
3) State of Tamil Nadu,
Represented. By its secretary,
Ministry of Home, Prohibition and Excise Department, Secretariat, Chennai – 600 009.
…3rd Respondent/ Respondent
IMPLEAD PETITION
For the reasons stated in the accompanying Affidavit the petitioner humbly prays that this Hon’ble Court may be pleased to grant the petitioner an order permitting the petitioner to be impleaded as respondent in the main Writ Petition No. 20195 of 2024 and pass such other order or orders as this Hon’ble Court may deem fit and proper in the circumstances of the case and thus render justice.
Dated at Chennai on this the 29th July 2024.
COUNSEL FOR PETITIONER
[CLEAN COPY]
IN THE HIGH COURT OF JUDICATURE AT MADRAS
W.M.P. No. of 2024
In
W.P. NO: 20196 OF 2024
A. Mohan doss,
No.13/2, Khan street,
Choolaimedu, Chennai – 600 094.
-Vs-
1) R.S.Bharathi Organising Secretary,
Dravida Munnetra Kazhagam,
No.367 and 369, Anna Salai, Teynampet, Chennai – 600 018.
Residing at
No.18, 29th Street, Thillai Ganga Nagar, … Petitioner
/Proposed 3rd Respondent
Nanganallur, Chennai – 600 061. …1st Respondent/Petitioner
2) Union of India,
Represented. By its secretary,
Ministry of home affairs,
New Delhi – 110 001. …2nd Respondent/ Respondent
3) State of Tamil Nadu,
Represented. By its secretary,
Ministry of Home, Prohibition and Excise Department, Secretariat, Chennai – 600 009.
…3rd Respondent/ Respondent
Affidavit of A. Mohan doss
I, A. Mohan doss, S/o. Antony, Hindu, aged about 54 years and residing at No.13/2, Khan Street, Choolaimedu, Chennai – 600 094 do solemnly affirm and sincerely state as follows :
- I am the petitioner to be impleaded in the Writ Petition No. 20196 of 2024 and as such am well acquainted with the facts of the case.
-2-
- I state that the petitioner in W.P. has filed this Writ petition in connection with “Bharathiya Nagarik Suraksha Sanhita, 2023” which has been introduced on 12.12.2023 passed in Parliament
20.12.2023. At the time of 1st Respondent/petitioner’s political party has 39 members in Parliament and what should have been raised in Parliament but not raised cannot be raised in a court of law. - I state that the said law has been passed and made to be applicable throughout Bharath, that is India, and as such this is not the forum to raise this issue. Already some person or persons had raised this in the Supreme Court of India and the Apex body is seized of the matter, and passed orders to the effect that the law has the sanction and authority of this sovereign nation.
- I however state that unless the papers connected with the said W.P. are given to me I will not be able to file a counter. However what I want to insist and say is inasmuch the petitioner has a case against the Adhinayam likewise I too have a case against the person who raises objection to the law enacted by Parliament and put into effect on and from 18 July 2024.
I, therefore humbly pray that this Hon’ble court may be pleased to grant me an order permitting me to be impleaded in the main W. P. No. 20196 of 2024 and pass such other order or orders as this Hon’ble Court may deem fit and proper in the circumstances of the case and thus render justice.
Solemnly affirmed at Chennai BEFORE ME on this 29th July 2024 and signed his name in my presence.
ADVOCATE IN THE HIGH COURT OF JUDICATURE AT MADRAS
(UNDER ARTICLE 226 OF THE CONSTITUTION OF INDIA)
W.M.P. No. of 2024
In
W.P. NO: 20196 OF 2024
A. Mohan doss,
No.13/2, Khan street,
Choolaimedu, Chennai – 600 094.
-Vs-
1) R.S.Bharathi Organising Secretary,
Dravida Munnetra Kazhagam,
No.367 and 369, Anna Salai, Teynampet, Chennai – 600 018.
Residing at … Petitioner
/Proposed 3rd Respondent
No.18, 29th Street, Thillai Ganga Nagar,
Nanganallur, Chennai – 600 061. …1st Respondent/Petitioner
2) Union of India,
Represented. By its secretary,
Ministry of home affairs,
New Delhi – 110 001. …2nd Respondent/ Respondent
3) State of Tamil Nadu,
Represented. By its secretary,
Ministry of Home, Prohibition and Excise Department, Secretariat, Chennai – 600 009.
…3rd Respondent/ Respondent
IMPLEAD PETITION
For the reasons stated in the accompanying Affidavit the petitioner humbly prays that this Hon’ble Court may be pleased to grant the petitioner an order permitting the petitioner to be impleaded in the Writ Petition No. 20196 of 2024 and pass such other order or orders as this Hon’ble Court may deem fit and proper in the circumstances of the case and thus render justice.
Dated at Chennai on this the 29th July 2024.
COUNSEL FOR PETITIONER
W.P. NO: 20193 OF 2024
AFFIDAVIT OF THE PETITIONER
M/s.
R.SUBRAMANIAN, 105/1995
In
W.P. NO: 20193 OF 2024
IMPLEAD PETITION
M/s.
R.SUBRAMANIAN, 105/1995
W.P. NO: 20195 OF 2024
AFFIDAVIT OF THE PETITIONER
M/s.
R.SUBRAMANIAN, 105/1995
In
W.P. NO: 20195 OF 2024
IMPLEAD PETITION
M/s.
R.SUBRAMANIAN, 105/1995
W.P. NO: 20196 OF 2024
AFFIDAVIT OF THE PETITIONER
M/s.
R.SUBRAMANIAN, 105/1995
In
W.P. NO: 20196 OF 2024
IMPLEAD PETITION
M/s.
R.SUBRAMANIAN, 105/1995