BEFORE THE HON’BLE HIGH COURT OF JAMMU & KASHMIR
AND LADAKH AT JAMMU.
WP(C) No. ______/2023
M.P. No. ______/2023
V/s
…Petitioners …Respondents
IN THE MATTER OF: -
APPLICATION FOR INTERIM RELIEF
MAY IT PLEASE YOUR LORDSHIPS;
The petitioners/applicants most respectfully submit as under: -
1. That the petitioners/applicants have filed the above titled writ
petition before this Hon’ble Court which is sure to succeed on
merits.
2. That the averments made in the writ petition may be read as
part and parcel of this application also in order to avoid
repetition and for the sake of brevity.
3. That the petitioners/applicants have strong prima-facie case
and the balance of the convenience is also in favour of the
petitioners/applicants.
4. That in case the relief prayed in the CM. is not granted in
favour of the petitioners/applicants, the petitioners shall suffer
an irreparable loss and harm which will not be compensated
latter on by any mode.
5. That it will be in the interest of justice that the relief prayed in
this application be granted in favour of the
petitioners/applicants and against the respondents/non
applicants.
An affidavit in support of the application is enclosed
herewith.
IN THE PREMISES: -
It is, therefore, most respectfully prayed that keeping in
view the submissions made hereinabove and those to be
urged at the time of hearing, the Hon’ble Court may very
kindly be pleased to:-
i)
ii) The Hon’ble Court be further pleased to grant any
other interim or final relief as may be deemed
appropriate in the circumstances of the case.
PETITIONERS
THROUGH COUNSEL
Dated:
Place:Jammu
(H.A. SIDDIQUI)
ADVOCATE
SHAMAS-UD-DIN SHAAZ
ADVOCATE
Licence No. JK-345/2015
Mob.9419155312
Email: - advocateshamas@[Link]
BEFORE THE HON’BLE HIGH COURT OF JAMMU & KASHMIR
AND LADAKH AT JAMMU.
WP(C) No. ______/2023
CM. No. ______/2023
Sadam Hussain & Ors V/s U.T. Of J & K & Ors
…Petitioners …Respondents
IN THE MATTER OF: - AFFIDAVIT IN SUPPORT OF WRIT PETITION.
I, Sadam Hussain Age 26 years S/o Mohd Hussain
R/o Village Panihad Tehsil Kotranka Distt Rajouri, do
hereby solemnly affirm and declare as under
1. That the accompanying writ petition has been read over and
explained to me and the contents of the para No.____ to ____
of the writ petition are true and correct as per my knowledge
and those of para No.____ are true as per information
received from record and those of remaining paras ____ to
____ are bases on legal advice.
2. The deponent is the petitioner No.1 in the above titled writ
petition, he is well versed with the facts and circumstances
of the case, hence he is competent to swear the instant
affidavit.
I solemnly swear/affirm that the affidavit is true, no part of this is false
and nothing has been concealed.
Place: Jammu
Dated: 26-12-2022
DEPONENT
BEFORE THE HON’BLE HIGH COURT OF JAMMU & KASHMIR
AND LADAKH AT JAMMU.
WP(C) No. ______/2023
CM. No. ______/2023
Sadam Hussain & Ors V/s U.T. Of J & K & Ors
…Petitioners …Respondents
IN THE MATTER OF: - AFFIDAVIT IN SUPPORT OF INTERIM
APPLICATION.
I, Sadam Hussain Age 26 years S/o Mohd Hussain
R/o Village Panihad Tehsil Kotranka Distt Rajouri, do
hereby solemnly affirm and declare as under
1. That the accompanying interim application has been read
over and explained to me and the contents of the para
No.____ to ____ of the interim application are true and
correct as per my knowledge and those of para No.____ are
true as per information received from record and those of
remaining paras ____ to ____ are bases on legal advice.
2. The deponent is the petitioner No.1 in the above titled
interim application, he is well versed with the facts and
circumstances of the case, hence he is competent to swear
the instant affidavit.
I solemnly swear/affirm that the affidavit is true, no part of this is false
and nothing has been concealed.
Dated:
Place:Jammu
DEPONENT
BEFORE THE HON’BLE HIGH COURT OF JAMMU & KASHMIR
AND LADAKH AT JAMMU.
WP(C) No. ______/2023
CM.. No. ______/2023
Sadam Hussain & Ors V/s U.T. Of J & K & Ors
…Petitioners …Respondents
IN THE MATTER OF: -
INDEX
S No. Particulars Page No.
1. Memo of urgency
2. Memo of Parties
3. List of Date and Events
4. Writ Petition along with Affidavit.
5. ANNEXURE-I
(Copy of the resolution dated 15-11-2022)
6. ANNEXURE-II
(Copy of letter dated 02-12-2022)
7. ANNEXURE-III
(Copy of notice 06-12-2022)
8. ANNEXURE-IV.(Copy of impeachment
motion. Dated 17-12-2022)
9. CM for interm relief alongh with affidavit.
10. Vakalatnama
11. Court Fees
Filed by:-
PETITIONER
THROUGH COUNSEL
Dated:26-12-2022
Place:Jammu. [Link]
Advocate
SHAMAS-UD-DIN SHAAZ
ADVOCATE
BEFORE THE HON’BLE HIGH COURT OF JAMMU & KASHMIR
AND LADAKH AT JAMMU.
WP(C) No. ______/2022
CM. No. ______/2022
Sadam Hussain & Ors V/s U.T. Of J & K & Ors
…Petitioners …Respondents
IN THE MATTER OF: - Memo of urgency.
MAY IT PLEASE YOUR HONOUR,
The petitioners, respectfully submit as under:-
1. That the petitioners have filed the above titled writ petition alongwith
application for interim relief which is sure to succeed on merits.
2. That the matter is of emergent in nature and requires to be taken up for
today itself otherwise the applicants shall suffer an irreparable loss and
injury which cannot be compensated by any other means.
It is, therefore, respectfully prayed that the above titled writ
petition may very kindly be directed to listed for today itself in the
interest of justice.
THE PETITIONERS
THROUGH COUNSEL
DATED: 26-12-2022
Place:Jammu.
(H.A. SIDDIQUI)
ADVOCATE
SHAMAS-UD-DIN SHAAZ
ADVOCATE
BEFORE THE HON’BLE HIGH COURT OF JAMMU & KASHMIR
AND LADAKH AT JAMMU.
WP(C) No. ______/2022
M.P. No. ______/2022
Sadam Hussain & Ors V/s U.T. Of J & K & Ors
…Petitioners …Respondents
IN THE MATTER OF:- LIST OF DATES AND EVENTS
S No. DATE EVENTS
1.
2.
3.
4.
PETITIONERS
THROUGH COUNSEL
Dated: 26-12-2022
Place: Jammu.
(H.A. SIDDIQUI)
ADVOCATE
SHAMAS-UD-DIN SHAAZ
ADVOCATE
Licence No. JK-345/2015
Mob.9419155312
Email: - advocateshamas@[Link]
BEFORE THE HON’BLE HIGH COURT OF JAMMU & KASHMIR
AND LADAKH AT JAMMU.
Writ petition under Art 226 of the Constitution of India.
Matter pertains to District Rajouri.
WP(C) No. ______/2022
M.P. No. ______/2022
Sadam Hussain & Ors V/s U.T. Of J & K & Ors
…Petitioners …Respondents
IN THE MATTER OF:
MEMO OF PARTIES
1. Sadam Hussain Age 26 years
S/o Mohd Hussain
R/o Village Panihad Tehsil Kotranka Distt Rajouri.
2. Rabnawaz Chowdhary Age 35 years
S/o Gulzar Hussain
R/o Village Panihad Tehsil Kotranka Distt Rajouri.
3. Mohd Shabir Age 50 years
S/o Mir Hussain
R/o Village Panihad Tehsil Kotranka Distt Rajouri.
4. Mohd Bashir Age 45 years
S/o Allah Din
R/o Village Panihad Tehsil Kotranka Distt Rajouri.
5. Mustaiq Ahmed Age 35 years
S/o Ghulam Hussain
R/o Village Panihad Tehsil Kotranka Distt Rajouri.
6. Mohd Qasim Age 40 years
S/o Wazir Mohd
R/o Village Panihad Tehsil Kotranka Distt Rajouri.
7. Mumtaz Begum Age 28 years
S/o Shah Hussain
R/o Village Panihad Tehsil Kotranka Distt Rajouri.
…PETITIONERS
VERSUS
1. U.T. Of Jammu and Kashmir through Commissioner Secretary
Rural Development & Panchayati Raj Civil Secretariat Jammu.
2. Deputy Commissioner Rajouri.
3. Addl. District Development Commissoiner/ Chief Executive Officer
District Development Authority Rajouri.
4. Asst. Commissioner Panchayati Raj (ACD) Rajouri.
5. Block Development Officer, Block Budhal Old.
6. Chairman Block Development Council, Block Budhal Old.
7. Secretary Panchayat Halqa Panchayat Panihad.
8. Mir Qasim sarpanch, Halqa Panchayat Panihad.
…RESPONDENTS
PETITIONERS
THROUGH COUNSEL
Dated:26-12-2022
Place:Jammu
(H.A. SIDDIQUI)
ADVOCATE
SHAMAS-UD-DIN SHAAZ
ADVOCATE
Licence No. JK-345/2015
Mob.9419155312
Email: - advocateshamas@[Link]