Senior adv kubtha Ravi argue in kalachathra case. In view of the reconstituted internal committee appointed to receive complaints, I seek this Hon’ble Court to also direct the complaints committee to enquire into my earlier complaint dated 29.03.2023 as against Nirmala Nagarajan, Nandini Nagarajan and Indhu Nideesh to be taken on record. Interest of justice requires that I be made a party to the WP pending before this Hon’ble Court. .

IN THE HIGH COURT OF JUDICATURE AT MADRAS

(Special Original Jurisdiction)

W.M.P. No.              of 2023

IN

W.P. No. 11764 of 2023

1) K.R. Sreenath

…Petitioner/Proposed Respondent

Vs

1) XYZ – 1 2) XYZ – 2

  • XYZ – 3
  • XYZ – 4
  • XYZ – 5
  • XYZ – 6
  • XYZ – 7 …Respondents/Petitioners
  • Kalashetra Foundation

Rep by its Chairperson,

Kalashetra Road,

Thiruvanmiyur, Chennai – 600 004

 

  • Government of India

Rep by its Secretary,

Ministry of Culture,

Room No. 501, C Wing, Shasrti Bhavan, New Delhi – 110 001

 

  • Government of Tamil Nadu

Rep by its Secretary,

Department of Education Department of School Education

Fort St George, Chennai – 600 021

 

  • Government of India

Rep by its Secretary,

Ministry of Education Department of School Education and Literacy,

109-C, Shasrti Bhavan, New Delhi – 110 001

 

  • Tamil Nadu State Commission For Women

Rep by its Chairperson,

Kailasa Mahal , 1st Floor,

Chepauk, Chennai – 600 005

A3, Sriram Apartments,

196A, St. Marys Road,

Abiramapuram, Chennai – 600 018                                …Respondents/Respondents

 

AFFIDAVIT FILED BY THE PETITIONER

I, K.R. Sreenath , son of Shri. Kuttanpillai Rajendrasekharan Nair, Hindu, aged about

do hereby solemnly affirm and sincerely state as follows:-

  1. I am the Petitioner herein and as such I am well acquainted with the facts of the case.
  2. I submit that I come from a very humble background having my roots in Trivandrum District, Kerala. Though my family was unable to provide me any financial assistance to pursue my passion in dance, I took upon myself to join the Kalakshetra foundation during June, 2004. I joined a course of Diploma in Bharatanatyam which is a 4 years course. During my 1st year itself, I got selected for the dance drama and my teacher and the then director of Kalakshetra, Shri. Rajaram felt that I was very much suitable for the role of Lakshmana in the dance drama “Seetha Swayambaram”. Thereafter I was offered several main roles in other dance dramas conducted by Kalakshetra which was not liked by many in the institution. The 4th and the final year of my Diploma in Bharatanatyam was under my teacher Nirmala Nagarajan. Everyone in the Kalakshetra including my teachers knew about my background that I was not financially sound and I worked for my livelihood and pursued my passion for dance as well. On several days, I would not even have my breakfast due to shortage of funds but I struggled to pursue the passion that I had towards Bharatanatyam. When I was doing my 4th year under Nirmala Nagarajan, I was again selected to the role of Lakshmana in 5 other Ramayana series. In fact, Kalakshetra was called upon to perform a dance drama performance of Ramayana abroad and my own teacher Nirmala Nagarajan rudely asked me the reason as to why only I was being asked to play the role of Lakshmana in all the dramas when there were other artists also. Nirmala Nagarajan also indicated that Shri Hari Padman who was mainly into organising such dance dramas had very strong likes and dislikes and that Nirmala Nagarajan alleged that Shri.Hari did not want to give opportunity to other artists and projected as if things were not going good in Kalakshetra.
  3. In fact during the one year under Nirmala Nagarajan, I found that she developed hatred towards me because she did not have control over the selection of artists to perform in various dance dramas of Kalakshetra. She directed the hatred towards me because, Mr. Hari Padman offered me the role of Lakshmana in all the dance drama performance in Kalakshetra and felt that all the students respected Hari sir more than Nirmala Nagarajan. Sometime in 2008, Nirmala Nagarajan approached me and started a conversation wherein she informed me that Sheejith

Krishna who was also a teacher in Kalakshetra was not happy with the role of Lakshmana being offered to me in all the dance drama performances and asked me to be more careful with Sheejith Krishna. However, in 2008 after completion of my

4th  year of Diploma course in Bharatanatyam, I joined Post- Diploma course in

Bharatanatyam from 2008 to 2010, wherein  Sheejith Krishna was my teacher for the 1st year. However while interacting with Sheejith Krishna, it came to my knowledge which was a shock to me that Sheejith Krishna did not harbour any ill-feeling as against me nor did anything transpire as was alleged by Nirmala Nagarajan. After my successful completion of post-graduation in 2010, I was appointed as a guest artist by the then director of Kalakshetra, Leela Samson. In fact, in the year 2012, when Ms. Leela Samson was embroiled in a case for financial irregularities in the renovation of Koothambalam auditorium at Kalakshetra Foundation, Nirmala Nagarajan and Nandini Nagarajan spearheaded the protest and conducted a signature campaign by roping in all the students and sent the said signatures obtained from the students to the Ministry of Fine Arts in expressing their displeasure in extending the tenure of Ms. Leela Samson thereby leading to the resignation of Ms. Leela Samson. At that point in time Nirmala Nagarajan was unable to digest the fact that I refused to be part of the signature campaign.

  1. I submit that sometime in April 2012, I resigned my part-time job at Kalakshetra since I had to travel out of Chennai. Sometime in June 2015, I was again called to join Kalakshetra wherein the arrangement was that I will be part of the dance drama troop and I was required to perform for Kalakshetra during the various programs. I was appointed as a full-time repertory artist on 15.11.2019 for a period of 3 years. Upon signing the said contract, the only teacher who was still in

Kalakshetra under whom I completed my Diploma and Post-Diploma courses was

Nirmala Nagarajan.  Hence, I visited Nirmala Nagarajan to seek her blessings. However, Nirmala Nagarajan instead of feeling happy about the fact that her student was appointed as a repertory artist started expressing her views that repertory artists were not required for Kalakshetra since they were eating into the finance and expressed her views that she knew how to shut the repertory section in Kalakshetra. But she however conveniently glossed over her statement by adding that since it was a livelihood for me she will not take any steps to close the repertory section and reserved it for a later plan of action. This statement of Nirmala Nagarajan shook me very badly.

  1. I submit that after the Covid19 pandemic, students started attending regular classes along with online classes from September 2021. However, till September 2021, only the teachers and staffs were permitted to enter the campus. It was during that time that when I was getting ready for a dance drama, one of the repertory staff barged into the makeup room, where unintentionally the staff almost would have touched me and I avoided it and the staff instantly enquired if Nirmala Nagarajan’s words are duly respected by me. I immediately enquired with the staff as to what happened. I was not aware that a rumour was going around the campus as if Nirmala Nagarajan had called me and asked me not to touch girls while talking to them. This news came as a rude shock to me and I immediately confronted Nirmala Nagarajan. However, to my surprise Nirmala Nagarajan became very defensive and stated that she would have as a teacher slapped me on my face instead of calling me and talking if it really had happened. She immediately put the blame on the other repertory artists who were spoiling my name. She also assured me that she will inform the then director of Kalakshetra and stop such rumours from being spread.
  2. I submit that Nandini Nagarajan on the other hand was to body shame me and openly criticised my dance performance and also humiliated me in front of her students and other staff members by stating that her students performed better than me and despite which she was unable to understand as to how I was selected to perform roles as Lakshmana time and again in various dance drama programs. In fact, right after the performance on 10.08.2021, Nandini Nagarajan criticised my dance performance and advised me to reduce my body weight in the presence of all the other artists. There was a lot of jealousy and hatred brewing in the minds of Nirmala Nagarajan, Nandini Nagarajan and Indhu Nideesh.
  3. I state that my contract of 3 years came to an end and the contract was renewed on 15.11.2022 till 15.11.2024. However the Management is yet to forward the copy of renewal of my contract.
  4. I submit that on 24.12.2022, Ms. Leela Samson posted an anonymous post in the social media by making allegations that one person who played the role of

Lakshmana was a pervert and removed the said comment within a few hours.

Everyone knew that the role of Lakshmana was only played by me and Nirmala Nagarajan immediately came and hugged me in front of everyone when she found that I was very upset with the post and stated that I was not such a person and that she was besides me to support me. However, Nirmala Nagarajan was a double standard person who projects herself as a very supportive person, but made allegations to the then director by referring to the post made by Ms. Leela Samson against me and wanted me to be removed from the repertory immediately. Further, I have always seen Nirmala Nagarajan hate Malayali men. Though she would seem to be very nice in front of me while abusing me behind my back with other teachers and students by character assassinating me. She has systematically played in throwing out all the Malayali artists by instigating the students and other faculty members by spreading rumours and hatred behind their back. She also instigated the other two teachers namely Nandini Nagarajan and Indhu Nideesh. Nirmala Nagarajan also did not like the dance dramas that Kalakshetra is famous for and she has made this statements several times to me. Nirmala Nagarajan always adopts a strategy to pushout a Malayalee male artist the moment she finds that the male artist is appreciated for his performance. She harbours a lot of jealousy and hatred as against the artists, or the director of the Kalakshetra more so because of the person wielding power or fame. In fact, Kalakshetra has from time immemorial strictly followed the Guru Shishya Parampara wherein the teacher treats her students as her own children and the students are taught to respect the dignity of each other, to thereby create a healthy atmosphere. However, Nirmala Nagarajan and Nandini Nagarajan quite contrary to the values of Kalakshetra, tried to malign the name of the students and artists who do not dance to their tunes in destroying the very institution.

  1. I submit that Indhu Nideesh had slapped a dancer named Sai Krishna on his butts during a dance rehearsal. I immediately confronted, that what she did was wrong and would it be taken lightly if a male had done the same to a woman. Indhu Nideesh just laughed and walked off. Indhu Nideesh instead of helping the artist with the production of dance dramas took great interest in gossip mongering about persons she did not like.
  2. I submit that after the re-opening of the Repertory in the year 2019, the Central Govt invited the artists of the repertory Section to several dance dramas. In all the programmes, myself, Sai Krishnan, Jai Krishnan and Sanjit Lal came to prominence under the guidance of Mr. Haripadman. There was huge appreciation and Kalakshetra’s artists were looked upon with awe in the field of fine Arts. We played the roles of Laxmana, Sugriva, Hanuman and Vibheesana in all the Ramayana series of Dance Drama’s. This was not to the liking of the 3 teachers namely Nandini Nagarajan, Indhu Nideesh and Nirmala Nagarajan. Hence they plotted to permanently close the Repertory Section using the various character assassinating defamatory statements made by Leela Samson and started passing rumors initially against Mr.Haripadman by tagging him along with his own student. Several public posts were circulated to demean Mr.Hari by projecting as if he was a sexual maniac. Based on such public uproar, Kalakshetra conducted a sou moto enquiry into the same. Students were called by ICC committee to come forward and place complaints if they have faced any sexual abuse in the campus. Nandini Nagarajan was an ICC member of Kalakshetra and not one complaint was received as against anyone from any of the students. Since there was no complaints received, the Kalakshetra Foundation issued a press note on informing the public clearly stating that based on social media allegations a detailed enquiry was conducted over a period of two and a half months to ascertain their veracity. It was further stated that the allegations were unfounded and baseless and that Kalakshetra foundation has not received any active complaints.
  3. However I started sensing that the 3 teachers unhappy with the silence started weaving rumours as against Hari Padhmanaban and other repertory artists with a view to tarnish their reputation and to ultimately close down the Repertory section. Several students confided with me to be careful as steps were taken to tarnish my name and finally throw me out of Kalakshetra. Unable to bear the mental trauma due to the false rumours passed on by the 3 teachers among the staffs and students and the character assassination made by them in the public, I decided to put an end to the said situation.
  4. I submit that on 29.03.2023 I gave a complaint to the Kalakshetra foundation,

Ministry of Fine Arts and to the National Commission for woman as against Nirmala

Nagarajan, Nandini Nagarajan and Indhu Nideesh for taking action against them on account of propagation of false allegations against me thereby vitiating the entire atmosphere of the campus and in defaming my reputation. The said complaint is yet to be acted upon. However, since Nandini Nagarajan who was part of the ICC committee at that point in time, leaked out my complaint to Nirmala Nagarajan and Indhu Nideesh. Immediately to avoid any kind of an action being taken as against the said teachers based on the said complaint, an SOS call was given to all the students under the guise that girls were subjected to sexual harassment thereby bringing about a wave of sympathy factor and on 30.03.2023, the students were mobilised by the three teachers for a protest. The students did not even know for what purpose they were protesting and acted as a pawn in the hands of the three teachers. Since the students in the Guru-Shishya Parampara have a great bonding towards the teachers, Nirmala Nagarajan, Nandini Nagarajan and Indhu Nideesh in the guise of protecting the students and the institution, pushed for a mass protest. Since on 31.03.2023, a dance drama programme was arranged at Hyderabad, the management has already sent the students to the venue on 29th itself and the repertory artists left for Hyderabad on 30th evening. However in order to scuttle the dance drama,  the 3 teachers instigated the students at Hyderabad to refuse to perform along with the repertory artists till the demands were met by the Management. Hence the Management had to cancel the programme and called back the repertory artists. When the management wanted the students to go back to the classes and prepare for their exams, the students refused and wanted the termination of all the repertory artists immediately including me for no rhyme or reason. However, in order to bring about  peace in the campus, the management promised the students to look into the complaints received if any. However, the students under the instigation of the three teachers refused to budge till the three repertory artists were dismissed. The 3 teachers were successful in completely vitiating the campus by poisoning the minds of the students.

  1. However, on 03.04.2023 a termination order was issued by Kalakshetra Foundation terminating my services as repertory artist and further barring me from entering the Kalakshetra campus without any enquiry and without providing an opportunity of being heard. The order of termination issued by Kalashetra is contrary to law and in violation of the principle of natural justice. I am taking steps to challenge the order of termination independently. I am a victim of concerted campaign carried out by the 3 teachers and I have been unceremoniously dismissed from service.
  2. In view of the reconstituted internal committee appointed to receive complaints, I seek this Hon’ble Court to also direct the complaints committee to enquire into my earlier complaint dated 29.03.2023 as against Nirmala Nagarajan, Nandini Nagarajan and Indhu Nideesh to be taken on record. Interest of justice requires that I be made a party to the WP pending before this Hon’ble Court.

It is therefore prayed that this Hon’ble Court may be please to implead the Petitioner /Proposed Respondent as a 7th Respondent in WP. No. 11764 of 2023 and pass such other or further orders as this Hon’ble court may deem fit and proper in facts and circumstances of the case and  thus render justice.

 

 

Solemnly affirmed at Chennai on                                                                                         Before Me

this the 21st day of April, 2023 and signed his name in my presence                               Advocate, Chennai.

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