SYNOPSIS and LIST OF DATES

The present petition under Article 32 of the Constitution of India seeks to obtain from this Hon’ble Court relief against the continued permissibility of cow-slaughter by Respondent No.2 to 4 as violative of their fundamental right the Constitution and obtain appropriate directions/orders/or a writ of mandamus including writ in the nature of mandamus requiring the respondents herein to take effective executive and/or legislative steps including, if necessary, to bring about requisite institutional amendment entitling the Respondent No.1 to enact necessary legislation and exercise consequent executive power, to bring about a total ban on the slaughter of cow and its progeny in solemn discharge of their mandatory duty and obligation under the provision of Constitution of India and in view of the solemn promises made form time to time by Respondent No.1 inside and outside the parliament.
That, the Petitioner is a citizen and inhabitant of India. The Petitioner also endeavour to remove the social ills and inequality which have creped into the Indian Society and its fabric in the course of the long periods of subjugation by alien and unsympathetic rulers and again raise their religion to the pristine glory which it owned had. The petitioner submits that in so doing they are also performing their fundamental duties imposed upon them by the Constitution.
That, the Respondents are the constitutional organs exercising legislative and executive functions and powers as specified by the Constitution of India under which they are invested with a solemn obligatory, positive and non-optional public duty to take appropriate legislative and/or executive measures for ensuring that no trade, business or occupation is allowed to develop or continue so as to be determental to the fundamental rights guaranteed to the citizen of India and/or not to undertake directly either by any or all of them or indirectly by granting permission to undertake may activity by one section of the Indian people as to result in taking away or abridging the fundamental rights guaranteed to other section of the Indian citizens.
That, since the beginning of the Hindu religion in hoary past when the Vedic Samhitas were compiled recording its fundamental tenets, the word ‘cow’ has always been used and understood in a comprehensive and generic sense and includes within its scope and admit the female cow as also bulls and bullocks and in fact the entire progeny of the cow. The cow, understood in this wide and generic sense, has been accorded a prominent position by the religion of the petitioners as compared with its position in other religious and also with regard to other domesticated animals in the Hindu Society itself. It is treated as inviolable and un-killable and a paramount religious duty is cast on every Hindu to protect a cow from being done to unnatural and premature death by anybody industries the one not belonging to the Hindu religion. To the ancient Indian cow was never an economic commodity but a divine entity, which, by its grace, showers material and spiritual benefits and wealth on its votaries. Hence the long historical tradition of India has never included cow as falling under a mercantile commodity with respect to which right to slaughter can be claimed as a trade, business or occupation. The cow is an integral, inservrable and fundamental part of the Hindu religion and its cites from the time immemorial and the Vedas, the oldest extent written record of the human race, merely record the spiritual and religious significance of cow to the Hindus. Thus being an integral part of the Hindu religion and enjoying a divine status therein, cow forms a class by itself for the protection of which express injunctions have been made through out the religious literature of the Hindu casting a heavy, imperative and paramount duty on them to protect it form slaughtered or killed or even maltreated.
That, the indirect promotion of cow slaughter as a means of a trade, business or occupation in beef and other items obtained from a slaughtered cow during the British rule in British India was adopted by the alien, imperialistic and ambitious people with a view not only to undermine and subvert the religious sentiments of the Hindu people but also as a part of their deliberate policy to destroy the very basic of their economic, social, cultural, religious and philosophical life as well as of a spiritual foundation of an ancient and peace loving sub-continent which was both alluring and disconcerting to them. It is pertinent that the British were concerned to convert India into a market for their industrial product and for this purpose systematically struck at the very root of the Indian economic system and structure which revolved round the cow, bulls and bullock. It is also important to submit that British tried to make WALL between two major religious group Hindu and Muslim through cow, while cow has its religious, economic and scientific values among Hindu, Muslim and other millions of Indians.
That, even the concept of secularise as enshrined in the Indian Constitution is founded on the age old Indian tradition of equal respect to all religion and the essential unity and indivisibility of human kind and of apparently separate religions. In order to transform this concepts of secularism into a living organism permeating the body politic of India and upon the foundation of which to build a truly multi-religious society which is informed with a unifying outlook, attitude and goal and which genuinely understands and respects the deep-rooted religious sentiments and spiritual ideals and vision, goal and aspiration, methods and means of their realization of each of the sections comprising it, requites that merely temporal affairs are separated from a community’s genuinely fundamental religious tenets and beliefs and affairs and adjust the former with the religion tenets, faith, sentiments, ideals and beliefs of another community in such a manner as never to permit the temporal to hurt, violate and disregard the activities and affairs which are undertaken in the course of discharging the peremptory religious injunctions for the realisation of their religious goal. Indian concept of secularism requires even to curb such temporal affairs and beliefs if they are antagonistic and opposed to and irreconcilable with the fundamental concepts and valves and injunctions of another religion. They submit that secularism in India and the inherent requirement for its due and proper observance and regard thereto render it incumbent and obligatory on the part of the respondents to take all the necessary and appropriate legislative and executive measures so as to balance the competing interests of various religious communities which arise from the diversity of their belief and to curb those temporal affairs and practice which are though permissible under their respective religion in conflict with and derogatory and antagonistic to the fundamental and inservrable religious tenets, beliefs and injunctions of other religious. The petitioner further submits that only such al policy on the part of the Indian States of which the respondents are integral parts, is conducive to the effective realisation of the Indian concept of secularism and is efficacious in protecting the fundament right guaranteed by Article 25 of Constitution of India to a person if it is violated or is in danger of violation by any activity which may be merely permissible by but not an essential, inseverable, integral and fundamental part of religion of another.
That, this Hon’ble Court has laid down the law in Mohammed Hanif Qureshi’s case in the following proposition;
1. That a total ban on the slaughter of cows of all ages and calves of cows and calves of buffaloes, male, female, in quite reasonable and valid and is in consonance with the directive principles laid down in Article 48.
2. that a total ban on the slaughter of the buffaloes or breeding bulls or working bullocks (cattle’s as well as buffalo) as long as they are milk or draught cattle is also reasonable and valid; and
3. that a total ban on the slaughter of she buffalo after they cease to be capable of yielding milk or breading or working as draught animals not be supported as reasonable in the interest of the general public.
The law thus laid down by this Hon’ble Court and followed by it in the later cases being the law of the land, the aforesaid judgement in Mohammed Hanif Qureshi’s case operates as disability on the part of the State including the respondents to enact a valid legislation prohibiting completely the slaughter of cow and its progeny even through its continued slaughter violates the fundamental right to Hindu.

Hence this Petition.


IN THE SUPREME COURT OF INDIA
ORIGINAL JURISDICTION
WRIT PETITION NO………….OF 2010

Position of parties before
IN THE MATTER OF: Trial Court High Court this Court

Naresh Kadyan

-Petitioner


VERSUS


Union of India
Through the Secretary
Ministry of Home
Government of India
New Delhi


The State of West Bengal
Through Chief Secretary
Government of West Bengal
Calcutta

The State of Kerala
Through Chief Secretary
Government of Kerara
Trivendrum

The State of Maharashtra
Through Chief Secretary
Government of Maharashtra
Mumbai

The State of Sikkim
Through Chief Secretary
Government of Sikkim
Gangtok
-Respondent


In the matter of :
Article 13, 14, 15(1), 25, 38(10, 47, 48, 51A, 246, 259(10, 252 and
368 of the Constitution of India.

And

In the matter of :
Right of the Indian Citizen for the protection of Cow i.e. the holy creature for the Indian society and most useful animal for the all human being.

And

In the matter of :
The Mandatory Non-optional duty of the Indian States to impose as absolute and complete ban on the slaughter of cow and its progeny.


And

In the matter of :
The non-application of Art.19(1) (g) of the constitution of India to the trade, business or occupation and/or the practice, usage or custom of trade relating to slaughter of cows special in the occasion of Eid-ul-Zuha popularly known as Baqar Eid.


To
The Hon’ble Chief Justice of India
And his Companion Justices of the
Supreme Court of India.


The humble petition of the
Petitioners above named.


MOST RESPECTFULLY SHOWETH:

This, the present petition under Article 32 of the Constitution of India seeks to obtain from this Hon’ble Court relief against the continued permissibility of cow-slaughter by Respondent No.2 to 4 as violative of their fundamental right the Constitution and obtain appropriate directions/orders/or a writ of mandamus including writ in the nature of mandamus requiring the respondents herein to take effective executive and/or legislative steps including, if necessary, to bring about requisite institutional amendment entitling the Respondent No.1 to enact necessary legislation and exercise consequent executive power, to bring about a total ban on the slaughter of cow and its progeny in solemn discharge of their mandatory duty and obligation under the provision of Constitution of India and in view of the solemn promises made form time to time by Respondent No.1 inside and outside the parliament.
That, the Petitioner is a citizen and inhabitant of India. By religion he is Muslim and believe in Islam. Islam does not allow hearting the sentiments and believes of others and is a peace loving religion. The Petitioner also endeavour to remove the social ills and inequality which have creped into the Indian Society and its fabric in the course of the long periods of subjugation by alien and unsympathetic rulers and again raise their religion to the pristine glory which it owned had. The petitioner submits that in so doing they are also performing their fundamental duties imposed upon them by the Constitution.
That, the Respondents are the constitutional organs exercising legislative and executive functions and powers as specified by the Constitution of India under which they are invested with a solemn obligatory, positive and non-optional public duty to take appropriate legislative and/or executive measures for ensuring that no trade, business or occupation is allowed to develop or continue so as to be determental to the fundamental rights guaranteed to the citizen of India and/or not to undertake directly either by any or all of them or indirectly by granting permission to undertake may activity by one section of the Indian people as to result in taking away or abridging the fundamental rights guaranteed to other section of the Indian citizens.
That, since the beginning of the Hindu religion in hoary past when the Vedic Samhitas were compiled recording its fundamental tenets, the word ‘cow’ has always been used and understood in a comprehensive and generic sense and includes within its scope and admit the female cow as also bulls and bullocks and in fact the entire progeny of the cow. The cow, understood in this wide and generic sense, has been accorded a prominent position by the religion of the petitioners as compared with its position in other religious and also with regard to other domesticated animals in the Hindu Society itself. It is treated as inviolable and un-killable and a paramount religious duty is cast on every Hindu to protect a cow from being done to unnatural and premature death by anybody industries the one not belonging to the Hindu religion. To the ancient Indian cow was never an economic commodity but a divine entity, which, by its grace, showers material and spiritual benefits and wealth on its votaries. Hence the long historical tradition of India has never included cow as falling under a mercantile commodity with respect to which right to slaughter can be claimed as a trade, business or occupation. The cow is an integral, inservrable and fundamental part of the Hindu religion and its cites from the time immemorial and the Vedas, the oldest extent written record of the human race, merely record the spiritual and religious significance of cow to the Hindus. Thus being an integral part of the Hindu religion and enjoying a divine status therein, cow forms a class by itself for the protection of which express injunctions have been made through out the religious literature of the Hindu casting a heavy, imperative and paramount duty on them to protect it form slaughtered or killed or even maltreated.
That, the indirect promotion of cow slaughter as a means of a trade, business or occupation in beef and other items obtained from a slaughtered cow during the British rule in British India was adopted by the alien, imperialistic and ambitious people with a view not only to undermine and subvert the religious sentiments of the Hindu people but also as a part of their deliberate policy to destroy the very basic of their economic, social, cultural, religious and philosophical life as well as of a spiritual foundation of an ancient and peace loving sub-continent which was both alluring and disconcerting to them. It is pertinent that the British were concerned to convert India into a market for their industrial product and for this purpose systematically struck at the very root of the Indian economic system and structure which revolved round the cow, bulls and bullock. It is also important to submit that British tried to make WALL between two major religious group Hindu and Muslim through cow, while cow has its religious, economic and scientific values among Hindu, Muslim and other millions of Indians.
That, even the concept of secularise as enshrined in the Indian Constitution is founded on the age old Indian tradition of equal respect to all religion and the essential unity and indivisibility of human kind and of apparently separate religions. In order to transform this concepts of secularism into a living organism permeating the body politic of India and upon the foundation of which to build a truly multi-religious society which is informed with a unifying outlook, attitude and goal and which genuinely understands and respects the deep-rooted religious sentiments and spiritual ideals and vision, goal and aspiration, methods and means of their realization of each of the sections comprising it, requites that merely temporal affairs are separated from a community’s genuinely fundamental religious tenets and beliefs and affairs and adjust the former with the religion tenets, faith, sentiments, ideals and beliefs of another community in such a manner as never to permit the temporal to hurt, violate and disregard the activities and affairs which are undertaken in the course of discharging the peremptory religious injunctions for the realisation of their religious goal. Indian concept of secularism requires even to curb such temporal affairs and beliefs if they are antagonistic and opposed to and irreconcilable with the fundamental concepts and valves and injunctions of another religion. They submit that secularism in India and the inherent requirement for its due and proper observance and regard thereto render it incumbent and obligatory on the part of the respondents to take all the necessary and appropriate legislative and executive measures so as to balance the competing interests of various religious communities which arise from the diversity of their belief and to curb those temporal affairs and practice which are though permissible under their respective religion in conflict with and derogatory and antagonistic to the fundamental and inservrable religious tenets, beliefs and injunctions of other religious. The petitioner further submits that only such al policy on the part of the Indian States of which the respondents are integral parts, is conducive to the effective realisation of the Indian concept of secularism and is efficacious in protecting the fundament right guaranteed by Article 25 of Constitution of India to a person if it is violated or is in danger of violation by any activity which may be merely permissible by but not an essential, inseverable, integral and fundamental part of religion of another.
That, this Hon’ble Court has laid down the law in Mohammed Hanif Qureshi’s case in the following proposition;
I. That a total ban on the slaughter of cows of all ages and calves of cows and calves of buffaloes, male, female, in quite reasonable and valid and is in consonance with the directive principles laid down in Article 48.
II. That a total ban on the slaughter of the buffaloes or breeding bulls or working bullocks (cattle’s as well as buffalo) as long as they are milk or draught cattle is also reasonable and valid; and
III. That a total ban on the slaughter of she buffalo after they cease to be capable of yielding milk or breading or working as draught animals not be supported as reasonable in the interest of the general public.
The law thus laid down by this Hon’ble Court and followed by it in the later cases being the law of the land, the aforesaid judgement in Mohammed Hanif Qureshi’s case operates as disability on the part of the State including the respondents to enact a valid legislation prohibiting completely the slaughter of cow and its progeny even through its continued slaughter violates the fundamental right to Hindu.
Aggrieved by slaughtering of cows and its progeny during eid-ul-zuha or general, the petitioner prefers this Petition on the following among other: -

G R O U N D S

B. This, the present petition under Article 32 of the Constitution of India seeks to obtain from this Hon’ble Court relief against the continued permissibility of cow-slaughter by Respondent No.2 to 4 as violative of their fundamental right the Constitution and obtain appropriate directions/orders/or a writ of mandamus including writ in the nature of mandamus requiring the respondents herein to take effective executive and/or legislative steps including, if necessary, to bring about requisite institutional amendment entitling the Respondent No.1 to enact necessary legislation and exercise consequent executive power, to bring about a total ban on the slaughter of cow and its progeny in solemn discharge of their mandatory duty and obligation under the provision of Constitution of India and in view of the solemn promises made form time to time by Respondent No.1 inside and outside the parliament.
C. That, the Petitioner is a citizen and inhabitant of India. The Petitioner also endeavour to remove the social ills and inequality which have creped into the Indian Society and its fabric in the course of the long periods of subjugation by alien and unsympathetic rulers and again raise their religion to the pristine glory which it owned had. The petitioner submits that in so doing they are also performing their fundamental duties imposed upon them by the Constitution.
D. That, the Respondents are the constitutional organs exercising legislative and executive functions and powers as specified by the Constitution of India under which they are invested with a solemn obligatory, positive and non-optional public duty to take appropriate legislative and/or executive measures for ensuring that no trade, business or occupation is allowed to develop or continue so as to be determental to the fundamental rights guaranteed to the citizen of India and/or not to undertake directly either by any or all of them or indirectly by granting permission to undertake may activity by one section of the Indian people as to result in taking away or abridging the fundamental rights guaranteed to other section of the Indian citizens.
E. That, since the beginning of the Hindu religion in hoary past when the Vedic Samhitas were compiled recording its fundamental tenets, the word ‘cow’ has always been used and understood in a comprehensive and generic sense and includes within its scope and admit the female cow as also bulls and bullocks and in fact the entire progeny of the cow. The cow, understood in this wide and generic sense, has been accorded a prominent position by the religion of the petitioners as compared with its position in other religious and also with regard to other domesticated animals in the Hindu Society itself. It is treated as inviolable and un-killable and a paramount religious duty is cast on every Hindu to protect a cow from being done to unnatural and premature death by anybody industries the one not belonging to the Hindu religion. To the ancient Indian cow was never an economic commodity but a divine entity, which, by its grace, showers material and spiritual benefits and wealth on its votaries. Hence the long historical tradition of India has never included cow as falling under a mercantile commodity with respect to which right to slaughter can be claimed as a trade, business or occupation. The cow is an integral, inservrable and fundamental part of the Hindu religion and its cites from the time immemorial and the Vedas, the oldest extent written record of the human race, merely record the spiritual and religious significance of cow to the Hindus. Thus being an integral part of the Hindu religion and enjoying a divine status therein, cow forms a class by itself for the protection of which express injunctions have been made through out the religious literature of the Hindu casting a heavy, imperative and paramount duty on them to protect it form slaughtered or killed or even maltreated.
F. That, the indirect promotion of cow slaughter as a means of a trade, business or occupation in beef and other items obtained from a slaughtered cow during the British rule in British India was adopted by the alien, imperialistic and ambitious people with a view not only to undermine and subvert the religious sentiments of the Hindu people but also as a part of their deliberate policy to destroy the very basic of their economic, social, cultural, religious and philosophical life as well as of a spiritual foundation of an ancient and peace loving sub-continent which was both alluring and disconcerting to them. It is pertinent that the British were concerned to convert India into a market for their industrial product and for this purpose systematically struck at the very root of the Indian economic system and structure which revolved round the cow, bulls and bullock. It is also important to submit that British tried to make WALL between two major religious group Hindu and Muslim through cow, while cow has its religious, economic and scientific values among Hindu, Muslim and other millions of Indians.
G. Islam provides options to Muslims to offer Qurbani of Baqra, Camel, Ship (Menda) and others so it is not mandatory to offer Qurbani of Cow’s only. There are several FATVAS issued by authorities of Islamic world regarding non-offering cow’s qurbani on the occasion of Edi-ul-Zuha being optional (WAZIB).
H. even the concept of secularise as enshrined in the Indian Constitution is founded on the age old Indian tradition of equal respect to all religion and the essential unity and indivisibility of human kind and of apparently separate religions. In order to transform this concepts of secularism into a living organism permeating the body politic of India and upon the foundation of which to build a truly multi-religious society which is informed with a unifying outlook, attitude and goal and which genuinely understands and respects the deep-rooted religious sentiments and spiritual ideals and vision, goal and aspiration, methods and means of their realization of each of the sections comprising it, requites that merely temporal affairs are separated from a community’s genuinely fundamental religious tenets and beliefs and affairs and adjust the former with the religion tenets, faith, sentiments, ideals and beliefs of another community in such a manner as never to permit the temporal to hurt, violate and disregard the activities and affairs which are undertaken in the course of discharging the peremptory religious injunctions for the realisation of their religious goal. Indian concept of secularism requires even to curb such temporal affairs and beliefs if they are antagonistic and opposed to and irreconcilable with the fundamental concepts and valves and injunctions of another religion. They submit that secularism in India and the inherent requirement for its due and proper observance and regard thereto render it incumbent and obligatory on the part of the respondents to take all the necessary and appropriate legislative and executive measures so as to balance the competing interests of various religious communities which arise from the diversity of their belief and to curb those temporal affairs and practice which are though permissible under their respective religion in conflict with and derogatory and antagonistic to the fundamental and inservrable religious tenets, beliefs and injunctions of other religious. The petitioner further submits that only such al policy on the part of the Indian States of which the respondents are integral parts, is conducive to the effective realisation of the Indian concept of secularism and is efficacious in protecting the fundament right guaranteed by Article 25 of Constitution of India to a person if it is violated or is in danger of violation by any activity which may be merely permissible by but not an essential, inseverable, integral and fundamental part of religion of another.
I. That, this Hon’ble Court has laid down the law in Mohammed Hanif Qureshi’s case in the following proposition;
I. That a total ban on the slaughter of cows of all ages and calves of cows and calves of buffaloes, male, female, in quite reasonable and valid and is in consonance with the directive principles laid down in Article 48.
II. that a total ban on the slaughter of the buffaloes or breeding bulls or working bullocks (cattle’s as well as buffalo) as long as they are milk or draught cattle is also reasonable and valid; and
III. that a total ban on the slaughter of she buffalo after they cease to be capable of yielding milk or breading or working as draught animals not be supported as reasonable in the interest of the general public.
IV. The law thus laid down by this Hon’ble Court and followed by it in the later cases being the law of the land, the aforesaid judgement in Mohammed Hanif Qureshi’s case operates as disability on the part of the State including the respondents to enact a valid legislation prohibiting completely the slaughter of cow and its progeny even through its continued slaughter violates the fundamental right to Hindu.


I N T E R I M P R A Y E R

In the circumstances, it is most respectfully prayed that this Hon’ble Court may be pleased;
(a) to grant INTERIM ORDER against the Respondent in compliance of order passed by this Hon’ble Court in Ashutosh Lehri Vs. State of West Bengal in 1994 and other orders passed by this Hon’ble Court for ban on cow slaughter.
(b) To impose ban on sales and purchase of Cow and its progeny in State of West Bengal, Maharashtra, Kerala and Sikkim during 10 November 2009 till 5 December 2009 (Edi-ul-Zoha).
(c) To impose ban on movement of cows and its progeny on street in State of West Bengal, Maharashtra, Kerala and Sikkim during 10 November 2009 till 5 December 2009 (Edi-ul-Zoha).
(d) To issue poster or handbills to stopping Qurbani of Cow and its progeny during Edi-ul-Zuha.
(e) to pass any interim order or further orders as this Hon’ble Court may deem fit and proper in the facts and circumstances of the case.
P R A Y E R

In the circumstances, it is most respectfully prayed that this Hon’ble Court may be pleased;
(a) to issue a Writ of mandamus or a writ in the nature of mandamus or any other directions or orders requiring the respondents either jointly or singly to take effective, efficacious and appropriate legislative and executive measures for bringing about a total ban on the slaughter (Qurbani) of cow and its progeny.
(b) To declare that the respondents have a non-optional, mandatory obligation to exercise its power under the Constitution to bring about such a legislation and its non-performance is ultra vires and violative of its constitutional obligation.
(c) to pass any order or further orders as this Hon’ble Court may deem fit and proper in the facts and circumstances of the case.

FOR WHICH ACT OF KINDNESS THE PETITIONER SHALL AS IN DUTY BOUND EVER PRAY.
NEW DELHI

DRAWN BY:

Advocate
Drawn on: FILED BY:
Filed on:

ADVOCATE FOR THE PETITIONER


IN THE SUPREME COURT OF INDIA
ORIGINAL JURISDICTION
WRIT PETITION NO………….OF 2010
---------------------------------------------------------------------------------------

IN THE MATTER OF:

Naresh Kadyan
…..Petitioner

VERSUS


State of West Bengal …. Respondents


WITH
CRL. M.P. NO……………OF 2010
APPLICATION FOR EXEMPTION FROM FILING OFFICIAL TRANSLATION

AND


PAPER BOOK

(FOR INDEX KINDLY SEE INSIDE)


ADVOCATE FOR THE PETITIONER


I N D E X
SL.NO. PARTICULARS PAGE NOS.

1. Office Report on limitation `A’

2. Check list ‘A1 to A2’

3. Synopsis and List of Dates `B –F’

4. Impugned judgment dt.10.12.2008
Passed by the Hon’ble High Court of West Bengal
Bench at Calcutta in W.P.No.2155/07 -

5. WRIT PETITION with affidavit. -

6. ANNEXURE P1
A true copy of


15. Application for exemption from filing official translation


IN THE SUPREME COURT OF INDIA
ORIGINAL JURISDICTION
WRIT PETITION NO………….OF 2010

IN THE MATTER OF:
Naresh Kadyan Petitioner

VERSUS

State of West Bengal …. Respondents

AFFIDAVIT
I, Naresh Kadyan aged 49 years, S/o. Sh. Om Parkash Kadyan, at present in Delhi do hereby solemnly affirm and state as follows:
1. That I am the Petitioner in the above WRIT PETITION and I am conversant with the facts of the case and I am competent to swear this affidavit.
2. That the facts stated in the list of dates from pages B- D, and the WRIT PETITION from page 3 to 10 from para 1-5 are true and correct and the rest is the legal submissions before this Hon’ble Court.
3. The Annexures P1-P in the petition is true copy of their respective originals.
4. The above stated facts are true and correct to the best of my knowledge and belief.
DEPONENT
Singed before me in my office at New Delhi on this the day of Advocate.

IN THE SUPREME COURT OF INDIA
ORIGINAL JURISDICTION
WRIT PETITION NO………….OF 2010

IN THE MATTER OF:

Naresh Kadyan …..Petitioner

VERSUS


Union of India & others …. Respondents


C E R T I F I C A T E

I certified that the WRIT PETITION is confined only to the pleadings before the Hon’ble High Court of West Bengal Bench at Calcutta whose order is challenged and the other documents relied upon in those proceedings. No additional facts, documents or grounds have been taken therein or relied upon in the WRIT PETITION. It is further certified that the copies of the annexures attached to the WRIT PETITION are necessary to answer the questions of law raised in the petition or to make out grounds urged in the WRIT PETITION for consideration of this Hon’ble Court. This certificate is given on the basis of the instructions given by the petitioner whose affidavit is filed in support of the WRIT PETITION.

NEW DELHI
DATE: ADVOCATE FOR THE PETITIONER