CAT DATE OF BIRTH
BEFORE THE HON'BLE STATE ADMINISTRATIVE TRIBUNAL AT _____________
OA No:______ of _____
___________________________________Appellant.
VERSUS
___________________________________Respondent.
Application Under Section 19 of the Administrative Tribunals Act, 1985
Respectfully:
1. Particulars of the Applicant:
As given in the Memo of Parties.
2. Particulars of the Respondents:
As given in the Memo of Parties.
3. Impugned Order:
That the applicant is aggrieved by the impugned order _____ of the respondents whereby they are not allowing the applicant to change his date of birth
In accordance with GI, MHA, Dept of Per. & AR Notification No. ______ dated ______ published as ______ in the Gazette of India, dated the ______ and takes effect from that date as per which the request for change of date of birth can be made within five years of his entry into Government service and as the applicant has joined the service on ______, therefore, the request of the applicant is within 5 years as stipulated supra.
The said impugned order is arbitrary, illegal, malafide, violative of the Constitutional Rights and natural justice and issued in colourable exercise of power.
4. Jurisdiction:
That the applicant declares that the subject matter is within the jurisdiction of this Hon'ble Tribunal.
5. Limitation:
That the applicant further declares that the application is within the limitation.
6. Facts of the Case:
a. That the applicant submits that ______
GROUNDS
6.2 That feeling aggrieved by such an arbitrary, malafide, discriminatory and illegal actions of the respondents, the applicant seeks the indulgence of this Hon'ble Tribunal on the following grounds amongst others, which may be taken at the time of arguments, each one of which is without prejudice to and independent of others:-
(a) That the impugned order issued by the respondent is arbitrary, malafide, illegal, ultra vires, against the Articles 14 and 16 of the Constitution of India, dehors the rules and regulations and against the natural justice.
(b) That ______
(c) That the respondents are estopped due to their own act, deed and conduct. The principle of the Promissory Estoppel applies against the respondents.
(d) That the impugned order is against the well-settled principles of the law as laid down by the Hon'ble Supreme Court and this Hon'ble Tribunal in catena of cases.
7. Reliefs Sought:
That the applicant, therefore, prays that your Lordship be pleased to issue an appropriate writ, orders or directions to grant the following reliefs in favour of the applicant in the interest of justice:-
(a) Quash the impugned order A-_____ issued arbitrarily, malafide and illegally by the respondents;
(b) Direct the respondents _____ ;
(c) Direct the respondents to produce all the relevant documents along with their reply for perusal by this Hon'ble Tribunal;
(d) Allow the cost of this OA;
(e) Pass such other order or directions as deemed fit and proper in favour of the applicant.
AND FOR THIS ACT OF KINDNESS, THE HUMBLE APPLICANT AS IN DUTY BOUND, SHALL EVER PRAY.
8. Interim Orders, If Prayed:
It is most respectfully prayed that during the pendency of this OA, the operation of the impugned order A-_____ may kindly be stayed in the interest of justice.
9. Details of Remedies Exhausted:
That the applicant submits that since the matter being of an urgent nature, there is no other alternative speedy and efficacious remedy available to him except to approach this Hon'ble Tribunal.
10. Matter not Pending with any Other Courts Etc:
That the applicant further declares that the matter regarding which this application has been made, is not pending before any court of law or any other Authority or any other bench of this Hon'ble Tribunal.
11. Particulars of Court Fees:
Court fees worth Rs 50/- is attached herewith.
12. Details of Index:
An index containing the details of the documents to be relied upon is enclosed herewith.
(Name of Place) Applicant
_____ Through, Advocate
VERIFICATION
I,_____, do hereby verify that the contents of paragraphs 1 to 12 of the OA are correct and true to the best of my knowledge, and no part of it is false and nothing material has been concealed therein.
Verified here at (Name of Place) this _____.
Applicant
BEFORE THE HON'BLE STATE ADMINISTRATIVE TRIBUNAL AT _____________
OA No.:_____ of _______
_________________________________Appellant.
VERSUS
__________________________________Respondent.
Affidavit in support of OA under Section 19 of the Administrative Tribunals Act 1985.
I, _____, do hereby solemnly, affirm and declare as under:-
1. That the accompanying OA has been prepared under my instructions.
2. That the contents of paragraphs 1 to 12 of the accompanying application are correct and true to the best of my knowledge.
3. That I further solemnly affirm and declare that this affidavit of mine is correct and true to the best of my knowledge and no part of it is false and nothing material has been concealed therein.
Affirmed at (Name of Place) this the _____.
Deponent
BEFORE THE HON'BLE STATE ADMINISTRATIVE TRIBUNAL AT _______________
OA No.:_____ of ______
_________________________________Appellant.
VERSES
_________________________________Respondent.
Index
|
SI No |
Annx |
Particulars of Documents |
Pages |
|
1 |
|
Court Fees |
[I] |
|
2 |
|
Memo of Parties |
1 |
|
3 |
|
OA |
2 |
|
4 |
|
Affidavit |
|
|
5 |
A-1 |
|
|
|
6 |
A-2 |
|
|
|
7 |
A-3 |
|
|
|
8 |
A-4 |
|
|
|
9 |
|
Power of Attorney |
|
(Name of Place) Applicant
______ Through, Advocate
