[3/4, 15:37] Sekarreporter 1: வனப்பகுதி case Affidavit…👆🏼 [3/4, 15:37] Sekarreporter 1: AAG J.Ravintheran adv IN THE HIGH COURT OF JUDICATURE AT MADURAI BENCH OF MADRAS HIGH COURT (SPECIAL ORIGINAL JURISDICTION) (Public Interest Litigation) W.P.(MD) No. 8466 of 2020 G.Thirumurugan @ Theeran Thirumurugan,(M,38/2020),

IN THE HIGH COURT OF JUDICATURE AT MADURAI BENCH OF
MADRAS HIGH COURT
(SPECIAL ORIGINAL JURISDICTION)
(Public Interest Litigation)
W.P.(MD) No. 8466 of 2020

G.Thirumurugan @ Theeran Thirumurugan,(M,38/2020),
S/o. Ganesan,
Morepannai Fishing Village,
Uppoor post, Thiruvadanai Taluk,
Ramanathapuram district. ….. Petitioner

-Vs-
1. Union of India, represented by,
The Principal Secretary,
Ministry of Environment, Forest and Climate change,
Indira Paryavaran Bhavan,
Jarbagh Road, New Delhi-110003.

2. State of Tamilnadu, represented by,
The Principal Secretary to the Government,
Environment and Forests Ministry,
State of Tamilnadu,
Fort St, George, Chennai 600009.

3. The Principal Chief conservator of forests and Head of Forest Force,
Panagal Maligai,
1, Jeenis Road,
Saidapet, Chennai -600015.

4. The Principal Conservator of forests and Chief Wildlife Warden,
Panagal Maligai,
1, Jeenis Road,
Saidapet, Chennai -600015.

5. The District Collector,
Office of the District Collector, Theni District 625531.

6. The Wildlife Warden,
Megamalai Wildlife division,
Forest Road,
Theni 625531.

7. The District Forest Officer,
District Forest Office , Theni,
Housing Board Colony, KRR Nagar,
Theni 626331.

8. The Regional Joint Director,
Office of the Regional joint director,
Animal Husbandry,
Allinagaram veterinary Hospital Compound,
Theni625531. … Respondents
AFFIDAVIT OF THE PETITIONER
I, G.Thirumurugan @ Theeran Thirumurugan, son of Ganesan, aged about 36 years, residing at Morepannai fisihing village, Uppoor Post, Ramanathapuram District, and do hereby solemnly affirm and sincerely state as under:-
1. I am the petitioner herein and well acquainted with the facts and circumstances of the case, and therefore I am competent to swear this affidavit.

2. I state that I am respectfully approaching this Honourable Court by way of this Writ Petition for pleased to issue Writ of Mandamus or any other writ or direction or order in the nature of writ, to direct the Respondents to completely ban cattle grazing in the Megamalai Wildlife Division & Sanctuary under the jurisdiction of the Respondent No.6 and the Theni Forest Division under the Jurisdiction of the Respondent No.7 within the time stipulated by this Hon’ble Court.

3. I state that I am residing in the above mentioned address along with my family members, I state that I am practicing as an Advocate before Hon’ble District Court of Ramanathapuram District. I am a public spirited citizen, and Environment enthusiast.

4. I state that as I hail from the Sea shore Fishing village of Ramanathapuram District, I am very much aware of the importance and need of the sustainable usage of the environmental resources. I state that 5 Southern districts of Tamilnadu (i,e Theni, Madurai, Ramanathapuram, Sivagangai, Virudhunagar) depends mainly on the Vaigai river for their water needs. In the origin of the Vaigai river the grasslands of Megamalai hills plays a vital role. I state that Ramanathapuram district is also hugely depend on Vaigai River water for it’s Agricultural needs and other needs. Hence I state that the destruction of Megamalai grasslands at any form will definitely pave way for the water crisis in southern districts of Tamilnadu.

5. I state that River Vaigai, the lifeline of Pandya dynasty was never a perennial river, but its flow was once augmented by tributaries and under the British regime, in the year 1898 a drinking water project was set up and the Vaigai water flowed through out the city. I state that nearly for the past 10 years the catchment areas in the Megamalai forests of Theni district is receiving very scanty rainfall due to the destruction of the natural grasslands inside the Megamalai forest and Megamalai Wildlife Sanctuary. I state that the Vaigai river empties into the Palk Strait near Uchipuli, close to Pamban bridge in Ramanathapuram District, but due to the lack of flow in the river, Vaigai never emptied into the sea for a long time. I state that stopping rivers from reaching the ocean causes enormous damage to coastal ecosystems, biodiversity, beauty, natural amenity and cultural values associated with coastal ecosystems. Also many fisheries depend on river flow to the ocean. I state that if the river flow to the ocean gets affected, it will have an adverse impact on the fisheries. Also if the river flow to the ocean gets affected, pollutants, salt, or excess nutrients can not be get cleared out and these accumulate over time which will affect the Bio-diversity of the region and lives of the fishermen.

6. I state that Theni district is blessed with about 1.05 lakh hectares of the forest land which constitutes about 40% of the geographical area of the district. There are two forest divisions in the district viz. Theni Forest Division and Megamalai Wildlife Division. I state that Megamalai Wildlife Division includes Megamalai Wildlife Sanctuary.

7. I state that there is a regular cattle grazing inside these forest areas which leads to degradation of the forest area. Rampant illegal cattle grazing in forests of Theni district leads to habitat loss for wildlife, which furthermore leads to devastating human-wildlife conflict.

8. I state that there is a particular group of people who claims their cattle are a special breed called as ‘Malaimaadu’. But there is no record of such a breed. It is just a native breed of cattle which are grazing inside forest areas.

9. I state that for their own benefit, the owners of these cattle have popularised the name ‘Malaimadu’ to distinguish their cattle and attract special attention. There are no records of the breed ‘Malaimaadu’ available as per the reply from Animal Husbandry Department. There are no records of presence of such breed in any other districts of Tamil Nadu too. They claim that they are conserving the native breed. But in reality, grazing is the cheapest way of feeding one’s cattle since it helps in decreasing the rearing cost of cattle. As per the information received around 18300 cattle have been transported to Kerala in the last 5 years from Theni district. Most of these are Scrub cattle that has been sold to the neighbouring state for sake of butchering.

10. I state that according to the current market rates, one cattle is sold at about Rs 30000 to 40000. One tractor load of dung is sold at a rate of around Rs 6000 to 7000/-. All these returns coming literally without any expenditure to the persons who graze their cattle inside forests. Apart from cattle, grazing by sheep and goat is also prevalent in forests of Theni district.

11. I state that furthermore, because of cattle grazing in the forests, wild animals are suffering from food & water shortage. As per the information from Animal Husbandry department a cattle requires around 20 kg of fodder a day. Malaimaadu are exclusively fed on free ranging in the forests only. As a result, there is increased risk of habitat degradation. I state that these cattle can be fed on cultivable fodder also. But owners of Malaimaadu claim that these cattle need to be fed with free ranging inside forests only which is not true.

12. I state that cattle grazing was not allowed in the entire forest in Theni district for 4 continuous years between 2009-2013, when both the divisions were a single division then the contention of these graziers that these scrub cattle ‘Malaimaadu’ are dependent on the forests for grazing was proven wrong as none of these cattle had lost their lives because they were not allowed to graze inside forests then.

13. I state that Cattle movement in reserved forests and also effects negatively on grass and foliage grown inside the forest. This means wild animals like gaur, deer, elephant and other herbivorous animals suffer due to lack or dearth of foods. There are frequent fire incidences wherever cattle grazing happens. Graziers put fires intentionally expecting good grass growth after midsummer rains. I state that this is the main reason behind the frequent Wildfires that is happening in the forest of the Theni District. But loss caused to the forest is heavy and with complete disturbance to the biodiversity of the landscape.

14. I state that it is more shocking in this situation that the attitude of the people dwelling nearby the forests, who are not concerned about the spread of Foot and Mouth Disease (FMD) & Anthrax. These are spread by the domesticated cattle to the wild animals. There is a potential risk of spread of other diseases like Haemorrhagic septicaemia, Black quarter, Tuberculosis etc from these domesticated cattle to wild animals. Parasites like Gastrointestinal nematodes, lung worms can be transmitted from domesticated cattle to wild animals through dung. Blood parasites like Theilaria and abesia can also be transmitted through ticks to the wild animals. I state that there are around 5000 sheep and 2000 goats which are vaccinated every year in the last 5 years. Actual number of sheep and goat grazing inside forests must be higher than the number of animals vaccinated. I state that Sheep and goat need around 2 to 5 kg of fodder a day. Majority of which are grazing in the forests only.

15. I state that even though Animal Husbandry department claims to have vaccinated cattle every six months, there is no marking on the cattle about vaccination. Mere certificate of number of cattle vaccinated is not sufficient to verify whether the particular cattle is vaccinated. I state that many cattle grazing inside forests are not vaccinated which pose a potential risk of disease transmission to the wild animals. There is no mechanism of vaccination to the wild animals. Therefore wild animals are always at a risk of disease transmission.

16. I state that although penning is not allowed inside forests, these cattle grazing in forests remain inside only for months together. Grazing is permitted only between 6 am and 6 pm, but cattle are never taken out, as the Forest Department doesn’t have any mechanism to ensure cattle come out in the evening. Also Forest Department has failed to stop penning inside forests. As per the information sought, Megamalai Wildlife Division has issued around 2250 grazing passes each year since 2016 -17. But there is a rampant misuse of these passes and 10 times greater number of cattle graze inside the forests illegally. I state that as per the information sought under Right to Information Act, 2005 from Regional Joint Director, Animal Husbandry, Theni, there are only about 39 persons who possess around 1946 Malaimaadu/Scrub cattle. The 20th livestock census, states the presence of about 12000 Scrub cattle in Theni district. But there are more than 100 persons in Theni district who demand grazing passes for around 20000 cattle.
17. I state that the grazers are also indirectly contributing for the poaching of the Wild animals and their organs. Cattle grazers allegedly poison a carcass of their cattle and kill wild animals purposefully for poaching. Recently on 10.04.2020 I have read a news in “Times of India daily” that two 10-year-old tigers, a male and female, killed after feeding on the carcass of a poisoned wild boar at Pollachi in Anamalai Tiger Reserve. I state that illegal grazing also indirectly gives rise to the ‘Wildlife Crime’ like Poaching.

18. I state that Forest Department has failed to ensure the number of cattle grazing is as per the passes issued. Further there is no marking on the cattle regarding the applicability of pass. The penning of cattle takes place in prime forest patches that have good access to food/water and penning of cattle in such vital places leads to compaction of the ground beneath, which doesn’t support any flora but only the noxious weed Parthenum.

19. I state that the cattle grazing leads not only to disease spread, shortage of fodder/water, forest fires, fresh encroachments by grazers, poisoning of tigers and carnivores that prey on the cattle while grazing inside the forests, but also to human animal conflict as the wild animals move out of the forests in search of food and water.

20. I state that this very small group of the people is exploiting the common resources for humankind for their personal gain which is highly unacceptable. Most of them keep more than 100 cattle which must be considered as commercial practice. It proves that grazing of such a huge number of cattle by very small number of owners is an exploitation of the common natural resource for their greed.

21. I state that as per the Section 21 of “The (Tamilnadu) Forest Act (1882)”, any person who trespasses or pastures cattle, or permits cattle to trespass shall in addition to such compensation for damage done to the forest as the convicting court may direct to be paid, be punished with imprisonment for a term which may extend to Six months or with fine which may extend to five hundred rupees or if it relates to any scheduled timber, with imprisonment for a term which may extend to five years and with fine which may extend to twenty-thousand rupees. Yet this practice continues unabated, with cattle graziers taking advantage of the lack of surveillance and inadequate numbers of field staff, despite the forest department’s efforts.

22. I state that under Chapter VIII of “The (Tamilnadu) Forest Act (1882)” as per the Section 57, Cattle trespassing in a reserved forest, on lands on which the grazing of cattle has been prohibited by rules made under section 26 or which has been closed under section 27, shall be deemed to be cattle doing damage to a public plantation within the meaning of the eleventh section of the Cattle Trespass Act, 1871, and may be seized and impounded as such by a Forest Officer or Police Officer. Whereas, Section 26 and 27 of ,“The (Tamilnadu) Forest Act (1882)”state as under,

Section 26. Subject to all rights now legally vested in individuals and communities, the Government may for any district or portion of a district make rules to regulate the use or the pasturage or of the natural produce of land at the disposal of Government and not included in a reserved forest. Such rules may with respect to such land

(a) regulate or prohibit the clearing or breaking up of land for cultivation or other purposes;
(b) regulate or prohibit the kindling of fine and prescribe the precautions to be taken to prevent the spreading of fires;
(c) regulate or prohibit the cutting, sawing, conversion and removal of trees and timber and the collection and removal of natural produce;
(d) regulate or prohibit the cutting, sawing, conservation and removal of trees and timber and the collection and removal of natural produce;
(e) regulate or prohibit the cutting of grass and pasturing or cattle, and regulate the payments (if any) to be made for such cutting or pasturing;
(f) regulate or prohibit hunting, shooting, fishing, poisoning water and setting traps or snares;
(g) regulate the sale or free grant of timber or other natural produce and
(h) prescribe the fees, royalties or other payments for such timber or other natural produce, and the manner in which such fees, royalties or other payments shall be levied.
Provided that the (Government) may exempt any person or class of persons from the operation of all or any of such rules.

Section 27. Whenever fire is caused willfully or negligently in any land to which all or any of the rules made under section 26 have been extended, the Government may, notwithstanding that a penalty has been inflicted under that section, direct that such land be closed against pasture for such period as it thinks fit.

Section 11 of Cattle Trespass Act, 1871 states as ,
Cattle damaging public roads, canals and embankments:- Persons is charge of public roads, pleasure-grounds, plantations, canals, drainage-works, embankments and the like, and officers of police, may seize, or cause to be seized, any cattle doing damage to such roads, grounds, plantations, canals, drainage-works, embankments, and the like, or the sides or slopes or such roads, canals, drainage-works, or embankments, or found straying thereon. And shall [send them or cause them to be sent within twentyfour hours] to the nearest pound.

23. I state that also under Section 2 of the “(Forest Conservation) Act, 1980” ‘Use of forest land for non-forest purpose is restricted’. But in the name of grazing in Theni district, all the provisions mentioned above are flouted and the valuable natural resources are lost. This will lead to the irreversible impact on the ecosystem. And also the wild animals are suffering from the lack of food due to the reason that the Cattle are exploiting the food resources of the wild animals. I state that this forces the Wild animals to came out of the forest in search of the foods, and ultimately results in the frequent Animal- Human Conflict in recent times. And I state that this results in the death of the wild animals due to various man made reasons like electrocution of elephants, road accidents of deers and so on.

24. I state that under CHAPTER III A of “Wildlife (Protection) Act,1972,” as per
Section 17A,
17A. Prohibition of picking, uprooting, etc. of specified plant.—Save as otherwise provided in this Chapter, no person shall—
(a) willfully pick, uproot, damage, destroy, acquire or collect any specified plant from any forest land and any area specified, by notification, by the Central
Government;
(b) posses, sell, offer for sale, or transfer by way of gift or otherwise, or transport any specified plant, whether alive or dead, or part or derivative thereof:
Provided that nothing in this section shall prevent a member of a scheduled tribe, subject to the provisions of Chapter IV, from picking, collecting or possessing in the district he resides any specified plant or part or derivative thereof for his bona fide personal use.
In contrary to the above provision, all the valuable plants in Theni District are being violated by the grazers and the valuable plants are being depleted in an surplus manner by the Cattle and ultimately results in the lack of food for the Herbivores wild animals like Elephant, Samba deer, Spotted deer and so on.,
I state that , “Pitcher Plant (Nepenthes) Khasiana” which is a specified plant under Schedule VI of Wildlife (Protection) Act,1972 is present around the Southern regions of western ghats like Periyar Tiger Reserve and in the vicinity of Megamalai Wildlife Sanctuary.

25. I state that the Hon’ble Supreme Court issued several orders in the series of Judgements in “T.N Godavarman Thuirumalpad V. Union of India & Ors” to address the issue of deforestation and restoration of forests in the entire nation. I state that in this case on December 12, 1996, a bench led by Hon’ble Chief Justice J.S. Verma passed an interim order directing that tree-felling and non-forestry activity in forests across the country be stopped. In contrary to the direction of Hon’ble apex court the valuable resources are unabatedly getting exploited in Megamalai Wildlife Sanctuary in the name of Grazing.

26. I state that on 03.06.2020, The Bench of Hon’ble Chief Justice of Hon’ble Manipur High Court Shri. Ramalingam Sudhakar and Hon’ble Mr. Justice A. Bimol Singh observed that in Public Interest Litigation NO.21 of 2020, reiterated that the directions of “T.N Godavarman Thuirumalpad V. Union of India & Ors” must be strictly followed and also observed that destruction of forests and invasion/intrusion of human beings in the forest domain displacing the forest species appears to be a major factor for the series of diseases like present COVID19. Further the Hon’ble court directed the respondents to take immediate measures to arrest wildfires which appear to be man made in many cases and issued several other directions to protect wild animals, flora, fauna as provided under Acts and Rules and to take up afforestation of lands which have been subjected to deforestation by various means including forest fires.

27. I state that as per the information sought under Right to Information Act from Wildlife Warden, Megamalai Wildlife Division, around 36000 saplings have been planted inside forests in last three years. A cattle grazing is a leading factor in damage to the saplings and failure of the plantations.

28. I state that government money in crores are spent in biodiversity up gradation and sustenance of the forests so that it benefits the people dependent on the waters of the river it gives birth to. But I state that for the greed of few hundreds, all these money goes waste, with huge disturbance to the rich natural habitat.

29. I state that the ever-increasing cattle grazing population and its encroachment into forest area may result in the loss of wild habitats. Grazing has been completely prohibited in the adjoining Srivilliputtur Grizzled Giant squirrel sanctuary. On similar lines it should be prohibited in Megamalai Wildlife Sanctuary, as the litigation against declaration of reserve forest in this area has been quashed by the Honourable High court paving way for declaration of the entire division as a sanctuary.

30. I state that Theni district is a part of Western Ghats biodiversity hotspot. Megamalai Wildlife Division is a connecting corridor for wildlife between Periyar Tiger Reserve and Srivilliputtur Grizzlled Squirrel Sanctuary. It is rich in biodiversity with high wildlife population which includes endangered animals like Tiger, Leopard, NilgiriTahr, Lion Tailed Macaque, Slender Lorris. Elephants are seen moving all over the division area. It is also a part of proposed Srivilliputtur Megamalai Tiger Reserve. Similarly Theni Forest Division is a part of Periyar Elephant Reserve and Madikattan Shola tiger corridor which connects Periyar Tiger Reserve and Kodaikanal Wildlife Sanctuary. But grazing in the forest areas of both these divisions leads to degradation of forests and wildlife habitat. It is expected to lead to large number of human-wildlife conflicts in near future.

31. I state that forest areas of Megamalai act as catchment of Vaigai River. Around 1 crore population of the five districts of southern Tamil Nadu viz. Theni, Dindigul, Madurai, Ramanathappuram and Sivagangai is dependent on the water of this river. I state that degradation of forests in Theni district directly affects this catchment and flow of water in Vaigai. Forest areas of Theni forest division acts as catchment for Kottagudi river, on whose waters the entire town of Bodinayakanur depend on.

32. I state that there are many grazing lands, poromboke lands as per the government records which are earmarked for the livestock grazing in the name of Mechal Poromboke. As per the records sought, there are around 400 Hectare of different types of grazing lands available in Theni District. But it is observed that many of such lands are under encroachments. Therefore I state that it is high time to remove all such encroachments and revive the grazing lands. Livestock grazing may be restricted to such grazing lands outside forests, so that the undue pressure on the forest land for commercial purposes is offset.

33. I state that it would be prudent to keep these cattle away from the fragile forest ecosystem, and sustain them in the Poromboke lands earmarked for the very purpose. Implementation of policies through various promotional schemes sponsored by the government will lead to greater community involvement in managing grasslands, and thus save the habitat for endemic and non-endemic species in reserved forests all over the state. Considering the damages caused by grazing to the forests and rivers, grazing may be completed banned in all the forest areas of Theni District to protect the natural resources of the humankind for future.

34. I state that the movement of the domesticated cattles (with big bells in its neck) in huge numbers create a noise pollution in the Deep forest areas known for its serenity and impacts the peaceful living of the Wild Animals.

35. I state that Article 48A in The Constitution Of India mandates that ‘The State shall endeavour to protect and improve the environment and to safeguard the forests and wildlife of the country’. And Article 51-A (g), says that “It shall be duty of every citizen of India to protect and improve the natural environment including forests, lakes, rivers and wild life and to have compassion for living creatures.”

36. I state that on 20.03.2020 and 05.06.2020 I have sent a detailed representation to the respondents to take immediate actions in an expedite manner to prohibit the cattle grazing in forests of Theni district and to save the Grasslands of Megamalai wildlife Sanctuary, and other grasslands in Theni District, and to ensure the Safe Habitat for the Wild Animals residing in the Forest Area. But I state that no positive action was taken regarding my request till I am approaching this Hon’ble Court.

37. I state that I am filing this public interest writ petition with my own costs, in my knowledge no such writ petition pending before any other court and did not filed relating to the subject matter of this writ petition, I am ready to pay the cost if any imposed by this Hon’ble court, I am filing this writ petition on public interest, I have no other motive or oblique reasons for filing this writ petition. I state my Aadhar card number is 9693779941635 and I am not income tax assessee, my PAN number is AQBPT5165AI. I am filing this Public interest litigation Writ petition with my own knowledge and information.

For the above reasons I have no other effective and efficacious alternative remedy except approaching this Hon’ble Court on the following among other

GROUNDS
a. Grazing of Malaimaadu and other cattles in Megamalai grasslands and Megamalai Wildlife Sanctuary is violative of the, Section 21 and Section 57 of “The (Tamilnadu) Forest Act, (1882)” and Section 2 of the “(Forest Conservation) Act, 1980” and Section 17-A of the “Wildlife (Protection) Act, 1972”.

b. In “T.N Godavarman Thuirumalpad V. Union of India & Ors” Hon’ble apex
court laid several guidelines to safe guard the natural resources of the nation. But in “Megamalai Wildlife Sanctuary” none of the guidelines were followed and the grasslands and other natural resources are exploited against law.

c. In the order of W.P (MD) No. 7606 of 2017 with W.P (MD) No. 13763 of 2016 with W.P (MD) No. 3633 of 2014 [2019 SCC Online Madras 3883], it is observed by the Hon’ble Justices M.M Sundresh J and N. Sathish Kumar J that ‘unlike perennial rivers of the Northern India supported by glaciers, rivers in Southern India are owing their existence to grasslands and shoal forests’. In contrary due to the illegal grazing the Megamalai grasslands is at the brink of extinction, which is a source of River Vaigai.

d. In the “T.N Godavarman Thuirumalpad V. Union of India & Ors” [(2006) 5 SCC 47] it was observed by the Hon’ble apex court in Para 16 that “Section
29 of 1972 Act specifically prohibits commercial activity inside the wildlife sanctuary”. In contrary, the Cattles which are grown up solely for the monetary purpose i,e to transported to Kerala and sold for beef, are feeding on the forest produce of the Megamalai Wildlife Sanctuary, which is a violation of Section 29 of the Wildlife (Protection) Act, 1972.

e. The Bench of Hon’ble Chief Justice of Hon’ble Manipur High Court Shri. Ramalingam Sudhakar and Hon’ble Mr. Justice A. Bimol Singh oboserved in a recent Public Interest Litigation case and observed that immediate measures must be taken to arrest wildfires which appear to be man made in many cases and issued several other directions to protect wild animals, flora, fauna.
f. Risk of transmission of disease like Foot and Mouth Disease (FMD) & Anthrax from domesticated cattle to Wild animals is a huge risk associated with the grazing of domesticated cattle within the vicinity of the Wild animals. Also Man to Animal disease transmission is also possible like the present Covid-19.
g. Destruction of the habitats and livelihoods of the Wild Animals eventually leads to Human- Wildlife Conflict, which is prevalent in recent times in Megamalai Wildlife Sanctuary and Wildlife division.
h. The movement of the domesticated cattles (with big bells in its neck) in huge numbers create a noise pollution in the Deep forest areas known for its serenity and impacts the peaceful living of the Wild Animals.
i. That the petitioner sent representation dated 20.03.2020 and 05.06.2020 to the respondents and requested to take immediate actions in an expedite manner to prohibit the cattle grazing in forests of Theni district and to save the Grasslands of Megamalai wildlife Sanctuary, and other grasslands in Theni District, to ensure the Safe Habitat for the Wild Animals residing in the Forest Area. But no positive action was taken regarding his representation.

Therefore I have no other effective, efficacious alternative remedy except approaching this Honorable Court by way of this Writ Petition under Article 226 of the Constitution of India.
Therefore for the above reasons the petitioner most respectfully pray that this Hon’ble Court may be pleased to grand ad interim injunction by restraining the Respondents No.6 and 7 from granting permission for grazing cattle inside the Megamalai Wildlife Division& Sanctuary and the Theni Forest Division till the disposal of the Writ Petition and pass such further or other order as this Hon’ble Court may deem fit and proper in the circumstances of the case and thus render Justice.
For the reasons stated above the I most respectfully pray that this Honorable Court may be pleased to issue writ of Mandamus or any other writ or order or direction in the nature of Writ, to direct the Respondents to completely ban cattle grazing in the Megamalai Wildlife Division& Sanctuary under the jurisdiction of the Respondent No.6 and the Theni Forest Division under the Jurisdiction of the Respondent No.7 within the time stipulated by this Hon’ble Court in accordance with the law and pass such further or other order as this Honorable court may deem fit and proper in the circumstances of the case and thus render justice.

Solemnly affirmed at Madurai, on this PETITIONER
24th day of July 2020, read and explained to the Petitioner in Tamil and in English and signed his name
in my presence. BEFORE ME

ADVOCATE