Cat reply 1
BEFORE THE HON'BLE CENTRAL ADMINISTRATIVE TRIBUNAL TN AT CHENNAI
OA No.:______ /______/______
Applicant
Versus
Respondents
Application under Section 19 of the Central Administrative Tribunals Act
Chennai
Applicant
______
Through, Advocate
Respectfully Sheweth:
Details of application:
1. Particulars of Orders Against Which this Application is Made:
That this application is made against the order of the respondent __
2. Jurisdiction of Tribunal:
That the applicant declares that the subject matter of this application is within the jurisdiction of this Hon'ble Tribunal and it is competent to issue the directions to the respondents for full compliance.
3. Limitation:
That the applicant further declares that the application is within the limitation period as prescribed in section 21 of the Central Administrative Tribunals Act 1985.
4. Facts of the Case:
(4.1) That the applicant_______
5. Grounds for Relief:
That the applicant seeks the indulgence of this Hon'ble Tribunal on the following grounds amongst others, each one of which is without prejudice to and independent of other:
(5.1) That the impugned order __ is malafide, arbitrary, discriminatory and issued in utter violation of rules, regulations, and is violative of Article 14 and 16 of the Constitution of India and natural justice.
(5.2) hat the respondents are estopped due to their own act, deed and conduct. The principle of promissory Estopple applies against the respondents.
(5.3) That the impugned order of the respondents is also against the well settled principles laid down by the Hon'ble Supreme Court of India and this Hon'ble Tribunal in catena of cases.
6. Details of Remedies Exhausted:
That the applicant has exhausted all the remedies available to him. Moreover, the matter being of urgent nature, the applicant has no other way but to approach this Hon'ble Tribunal for speedy and efficacious remedy for staying and quashing the impugned order. _______
7. Matters not Previously Filed or Pending with any Other Court:
The applicant further declare that he has not filed any application, writ petition or suit regarding the matter in respect of which this application has been made in any court, other authority or any other Bench of this Hon'ble Tribunal. No such application, writ petition or suit is pending before any of them. _______
8. Reliefs Sought:
That in view of the facts in para 4 above and the grounds in para 5 supra, your Lordship's humble applicant prays for the following reliefs:
(a) Quash the impugned order ______ being arbitrary, malafide, discriminatory and illegal;
(b) Direct the respondents ______
(c) Direct the respondents to produce all the records of the case along with their reply for perusal by this Hon'ble Tribunal;
(d) Allow the cost of this application to the applicant.
(e) Pass such other orders or reliefs as deemed fit and proper in the facts and circumstances of the case in the favour of the applicant and against the respondent.
AND FOR THIS ACT OF KINDNESS, THE HUMBLE APPLICANT AS IN DUTY BOUND, SHALL EVER PRAY.
9. Interim Orders:
It is, therefore, most respectfully prayed that during the pendency of this O.A. the operation of impugned order A-______ may kindly be stayed in the interest of justice.
10. N.A.
11. Particulars of Postal Order Towards Application Fees:
1. Postal Order Nos:_______
dated:_______
2. Issuing P.O. : _______
3. Amount Rs : 50/- [Rs fifty only]
4. Payable at : _______
12. List of Enclosures:
As per index.
Chennai
Applicant
______
Through, Advocate
Verification:
I,______, do hereby verify that the contents of paras 1 to 5 are true to my personal knowledge and paras 6 to 12 believed to be true on legal advice and that I have not suppressed any material fact.
Verified here at Chennai this______
Chennai
______
Applicant
BEFORE THE HON'BLE CENTRAL ADMINISTRATIVE TRIBUNAL TN AT CHENNAI
OA No.: ______/______/______
Applicant
Versus
Respondents
Affidavit
I, ______, do hereby solemnly affirm and declare as under :-
1. That the accompanying application has been prepared under my instructions.
2. That the contents of paras 1 to 12 of the O.A. are correct and true to the best of my knowledge.
3. That I further solemnly affirm and declare that this affidavit of mine is true, no part of it is false and nothing material has been concealed therein.
Affirmed at Chennai this the ______
Deponent
BEFORE THE HON'BLE CENTRAL ADMINISTRATIVE TRIBUNAL TN AT CHENNAI
MA No.: ______/______ in OA No.:______/______/______
Applicants
Versus
Respondents/Non-applicants
MA under Rule 4 (5) (a) of Central Administrative Tribunal (Procedure) Rules 1987
Respectfully Sheweth:
1. That the applicants have filed the above mentioned OA jointly.
2. That on perusal of the above OA and documents attached therewith it is amply evident that all the applicants have common cause of action and common nature of relief prayed for by them and are desirous of joining in a single application as they have a common interest in the matter.
3. That interest of justice demands that the applicants are allowed to file the OA in the jointly in the interest of justice.
4. It is therefore, most respectfully prayed that this application may be allowed in the interest of justice and the applicants may be allowed to file the present OA jointly. Such other orders be also passed as deemed fit and proper in the facts and circumstances of the case.
Chennai
Applicant
______
Through, Advocate
Verification:
I, ______, do hereby verify that the contents of para 1 to ______are true on legal and that have not suppressed any material fact.
Verified here at Chennai this ______
Chennai
Applicant
______
Through, Advocate
BEFORE THE HON'BLE CENTRAL ADMINISTRATIVE TRIBUNAL TN AT CHENNAI
MA No.: _______/_______ in OA No.:_______/_______/_______
Applicant
Versus
Respondents/Non-applicants
Affidavit
I, _______, do hereby solemnly affirm and declare as under:-
1. That I am duly authorized by the other applicants to file the present MA and am fully conversant with the facts of the case.
2. That the accompanying MA has been drafted under my instructions.
3. That the contents of paras 1 to 4 of the MA are correct and true to the best of my knowledge.
4. That I further solemnly affirm and declare that this affidavit of mine is correct and true, no part of it is false and nothing material has been concealed therein.
Affirmed at Chennai this the_______.
Deponent
BEFORE THE HON'BLE CENTRAL ADMINISTRATIVE TRIBUNAL TN AT CHENNAI
MA No.: _______/_______ in OA No.:_______ /_______/_______
Applicants
Versus
Respondents/Non-applicants
MA under Rule 4 (5) (b) of Central Administrative Tribunal (Procedure) Rules 1987
Respectfully Sheweth:
1. That the applicants have filed the above mentioned OA jointly.
2. That on perusal of the above OA and documents attached therewith it is amply evident that all the members of the applicant association have common cause of action and common nature of relief prayed for by them and are desirous of joining in a single application as they have a common interest in the matter.
3. That interest of justice demands that the applicants are allowed to file the OA through their Association in the interest of justice.
4. It is therefore, most respectfully prayed that this application may be allowed in the interest of justice and the applicants may be allowed to file the present OA through their Association. Such other orders be also passed as deemed fit and proper in the facts and circumstances of the case.
Chennai
Applicant
______
Through, Advocate
Verification:
I, ________, do hereby verify that the contents of para 1 to ______ are true on legal advice and that have not suppressed any material fact.
Verified here at Chennai this _______.
Chennai
Applicant
______
Through, Advocate
BEFORE THE HON'BLE CENTRAL ADMINISTRATIVE TRIBUNAL TN AT CHENNAI
MA No: ______ /______ in OA No:______/______/______
Applicant
Versus
Respondents/Non-applicants
Affidavit
I, ,______ do hereby solemnly affirm and declare as under:-
1. That I am duly authorized by the other applicants to file the present MA and am fully conversant with the facts of the case.
2. That the accompanying MA has been drafted under my instructions.
3. That the contents of paras 1 to 4 of the MA are correct and true to the best of my knowledge.
4. That I further solemnly affirm and declare that this affidavit of mine is correct and true, no part of it is false and nothing material has been concealed therein.
Affirmed at Chennai this the ______
Deponent
