nusrl petition

8/12/2019 Nusrl Petition

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IN THE HIGH COURT OF JHARKHAND, AT RANCHI

(CIVIL WRIT JURISDICTION)

I.A. No. ----- /2012

IN

W.P. (PIL) No. 2347/2012

IN THE MATTER OF;

An interlocutory application for

impleading the interveners as co-

petitioners for bringing on record

certain relevant facts for just decision

in this case;

AND

IN THE MATTER OF;

Bar Association of JharkhandPetitioner


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Vs

State of Jharkhand and othersRespondents

And

1. Abhinav Prakash S/O Dr. Kailash Singh2. Abhishek Chaube S/O Shri Lalit Prakash Chaubey3. Aditi Singh D/O Shri Deepak Singh4. Ashish Abhijit S/O Shri N. N. Pandey5. Riddhi. M. DsouzaD/O Dr. George Dsouza6. Saurav Bhaumik S/O Shri R. K. Bhaumik

And

All are the Students of and residents of National University of

Study and Research in Law, Ranchi, BIT Polytecnic Campus,

Mesra, P.O- Mesra, P.S- Ormanjhi, District- Ranchi, Jharkhand.

Most respectfu l ly sheweth:

1. That by this interlocutory application, the intervener petitioners pray tobe impleaded as co-petitioners for bringing on record certain relevant

facts for the kind consideration of this Honble Court so that complete

justice can be done in this instant case to all the parties concerned.


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2. That the intervener petitioners had not moved any such interlocutoryapplication for the self- same relief earlier made in this application for

impleading them as parties.

3. That the intervener petitioners are citizens of India and are themembers of Center for Legal Aid Programme (hereinafter CLAP),

National University of Study and Research in Law, Ranchi

(hereinafter, NUSRL, Ranchi) an unregistered society, consisting of

bona-fide students and faculty members of NUSRL,Ranchi.

4. That CLAP was established under the patronage of the Honble ViceChancellor of NUSRL, Ranchi in February 2011 with an aim to serve

as an effective medium for voicing the concerns of the downtrodden

and the poor sections of society and to find a feasible solution to their

problems through the medium of law. That since its very inception,

CLAP had intermittently drafted proposals, offered meaningful

suggestions and has come up with alternative approaches of tackling

the constraints in the system. Moreover, it has acted as a pillar of

support for the common man who fails to get his grievances heard and

knock the doors of justice due to innumerable constraints.

5. That it is most humbly submitted that CLAP has been playing a veryactive role in the social domain and some of its past activities and


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initiatives taken in this regard are provided hereunder for the kind

attention of this Honble Court.

6. That an informative interactive campaign named SOOCHNA-11waslaunched in a village named Panchauli (on the outskirts of BIT, Mesra,

Ranchi) on 1st June, 2011 stressing on the importance of issues related

to RTI, Land Disputes, Family Law and Criminal Law.

7. That it also organized a series of informal talks with prominentpoliticians of national repute under a programme named Meet your

Lawmakerwhich was attended by the politicians and the bureaucrats

of repute and aimed at showcasing the deeper misunderstood realities

of administrative and political set up.

8. That CLAP invited participants from law colleges across the state ofJharkhand to form an intra-state network of Legal Aid Societies within

Law Universities and Colleges of Jharkhand for developing a better co-

ordination among them in reaching out to the people in dire need of

free quality legal services, at a seminar on Scope of Legal Aid in

Jharkhand organized by CLAP.That it is most respectfully submitted

that most recently CLAP has organized various Legal Aid camps in

Tenughat, Tamar and Giridih on 4th, 9th and 25th August, 2012

respectively.


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9. That it is most respectfully submitted that, the student body ofNUSRL, Ranchi in general and the members of CLAP in particular are

going to be substantially affected by the decision of this Honble Court

in this ongoing public interest litigation, therefore, they most humbly

pray themselves to be impleaded as co-petitioners so that they can

bring on record their concerns with respect to the subject matter under

consideration before this Honble Court.

10. That the intervener petitioners most humbly submit that the details ofthe problems being faced by NUSRL, Ranchi on the account of

inaction and lacklustre attitude of the concerned respondents has

properly been brought to the kind attention of this Honble Court in the

main writ petition filed by the petitioner Bar Association Jharkhand

High Court, Doranda, Ranchi, therefore, for the sake of brevity the

intervener petitioners shall not be repeating those facts here in this

interlocutory application.

11. That the intervener petitioners shall be confining this interlocutoryapplication to present their humble submissions in response to the

distortion of facts in a malicious and mischievous manner made in

various newspapers and media by certain vested interests and


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politically motivated persons, as this Honble Court itself noted in its

Order No. 5 passed in this Writ Petition (PIL) No. 2347 of 2012.

12. That it is most humbly submitted that it appears that some fallaciousarguments are being presented before this Honble Court with an

intention of misleading people against the proposed construction of

NUSRL, Ranchi campus on the ground that; these lands are fertile and

since the majority of the concerned villagers are illiterate, and their

sole occupation is cultivation, therefore, if their land is taken away

from them for the construction of the campus of NUSRL, Ranchi they

will have no means of livelihood left with them.

13. That it is most humbly submitted that it is being falsely presentedbefore this Honble Court that the past acquisition of land and its

subsequent allotment of land in question to NUSRL, Ranchi is against

the human rights of concerned villagers, arbitrary, malicious and

illegal exercise of power by the state.

14. That it is most humbly submitted that the past acquisition of land inquestion and the subsequent allotment thereof to NUSRL, Ranchi is

not violating the human rights of aggrieved parties and it is not an

arbitrary, malicious and illegal exercise of power by state. That it is


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most humbly submitted that the state action of acquiring land and the

further allotment of land to NUSRL, Ranchi rather than being violative

of human rights of the affected villagers, is actually in the best interests

of the affected villagers.

15. That it is further submitted that the past acquisition of land and thefurther allotment of the land to NUSRL, Ranchi for the purpose of

establishment of NUSRL, Ranchi is a just and proper exercise of

power by the state authorities. That it is further submitted that it is the

bounden duty of the state to promote and establish institutions of

excellence for the wholesome development of the newly created state

of Jharkhand.

16. That it is humbly submitted that the Honble Vidhan Sabha ofJharkhand felt the need for the establishment of a Law University for

the purpose of advancement of cause of learning, teaching, and

research and dissemination of knowledge in the field of law, legal

capacity building of appropriate state and non-state institutions,

strengthening the system of delivery of legal services, specialization in

reasonably relevant techno development clusters of knowledge (like


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mines and minerals, environment, IT, Biotechnology etc) and

contribution to public policy development in the use of law in

governance as also to cater to the needs of the society by the

development as also to cater the needs of the society by developing

professional skills of persons intending to take up advocacy, judicial

services, law officers/managers and legislative drafting as their

profession and matters incidental thereto, and therefore passed an Act

(Act No. 4 of 2010) to establish National University of Study and

Research in Law, Ranchi.

17. That it is most humbly submitted that in furtherance of theestablishment of NUSRL, Ranchi as envisaged by the Vidhan Sabha of

Jharkhand, the state government allotted 63.76 acres of land to

NUSRL, Ranchi, the details and history of land allotment had been set

out in the main writ petition filed by the main petitioner and to avoid

unnecessary repetition, intervening petitioner humbly prays before this

Honble Court that the relevant portions [Para ,1, 2, 4, 5, 6, 7, 8, 9,10,

12, 13 ,14, 15 ,17] shall be read as part and parcel of this interlocutory

application.


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18. That one of the major contention that is being made on behalf of theconcerned villagers through I.A.no.1558/2012, filed in this public

interest litigation had been that the concerned land is fertile and

majority of the affected villagers being illiterate, their sole occupation

is cultivation, therefore, if their land is taken away from them for the

construction of NUSRL, Ranchi, then they will not have any means of

livelihood left with them.

19. That it is most humbly submitted before this Honble Court that noneof the assertions made on behalf of the concerned villagers can stand

the test of an objective analysis of the material facts and data available

in the public domain.

20. That the intervener petitioners respectfully submit that the scientificreports available in public domain show that generally lands of

Jharkhand are not suitable for sufficient agricultural production and

more particularly the land in question cannot be regarded as fertile

land, that can provide even a rural household a decent standard of

living, cultivation being their sole source of livelihood.


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21. That the intervener petitioners most humbly submit, that the soil ofJharkhand is not very fertile and productive, more essentially the land

in dispute is worse off when it comes to fertility and productivity.

22. That it is humbly submitted before this Honble Court that, Ranchidistrict consists of tabular landmass and it has flat surface with isolated

hillocks known as Tongri Hills lying on the west having elevation

above 800 meters and those lying in east having elevation less than 75

meters. That the average elevation of the district is 650 meters but

western portion is relatively higher than the eastern part.

23. That it is humbly submitted that depending upon topography, soil isbroadly classified into upland, medium land and lowland. That the

brief description of upland, medium land and lowland is as given

below;

Upland: Upland soils are generally red, acidic (pH 5.5-5.9) andhave poor water holding capacity (WHC). Moisture is easily

saturated during rains but release of moisture is very fast in the

upland. It is suitable for Kharif pulses (pigeon pea, urd, moong &

kurthi).

Medium land: Medium land soil is generally yellowish, slightlyacidic (pH 6.0-6.5) and has intermediate water holding capacity. It is


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suitable for Rabi pulses (chickpea, lentil & pea) and in sequential

cropping system, rice-chickpea/lentil; maize-chickpea/lentil may be

produced, but in intercropping system, under irrigated situation, wheat,

chickpea/mustard, chickpea/lentil can be produced.

Low land: This type of soil is grayish, slightly alkaline (pH 7.0-7.3) and has high water holding capacity. That the Low land may be

utilized for spring/summer cultivation. Low land is generally vacated

after harvesting of transplanted paddy in 2ndweek of December to 2nd

week of January and it takes time for removal of moisture.

24. That it is most humbly submitted that the land can further be classifiedinto two sub categories:

GROUP SUB-GROUP TYPE DESCRIPTION

Don Land Don I Low Land Clay-loam soil, lowest in

toposequence, suitable for

long duration rice crop

Don II Shallow Land Clay loam soil and best for

rice production, rarely faces

drought, suitable for medium


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duration rice

Don III Drought prone

shallow land

Clay loam soil, transitional

lands between Don & Tanr,

upper toposequence and

suitable for short duration rice

Tanr land Tanr I Upland Loam soil and land

immediately adjacent to the

houses. Land used for

vegetables, maize and rice

seedlings

Tanr II Upland Sandy loam soil, gentle slopy,

good soil depth, low WHC,

poor in organic matter,

erosion prone, acidic in

nature

Tanr III Upland Sandy loam soil, slopy, poor

soil fertility, shallow soil

depth, low WHC, Near

foothills and acidic in nature


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25. That it is most humbly submitted that, soil fertility is an aspect of thesoil-plant relationship. That it is respectfully submitted that fertility

status of the soil is primarily and importantly dependent upon both the

macro and micronutrient reserve of that soil i.e. the nature of

vegetation, climate, topography, texture of soil and decomposition rate

of organic matter. That it is humbly submitted that the optimum

productivity of any cropping system depends on the adequate supply of

plant nutrients.

26. That it is further submitted that, the majority of land in the District ofRanchi is covered with sandy loam with acidic soil (pH 4.56.5) and

having low fertility. That the soil pH ranges from 4.2 to 7.6. That the

majority of the area is acidic (96.4 % of Thermogravimetric analysis)

in reaction. That the soil of 1.2% area of the district is neutral, whereas

0.2% of the area is slightly alkaline in reaction.

27. That the organic carbon content in the district ranges from 0.14 to3.76%. That the 43.8% of the areas in the district have high organic

carbon content. That the medium and low organic carbon content

constitutes 28.7% and 25.3% of the area respectively. That the

available nitrogen content in the surface soil of the district ranges


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between 109 and 638 kilogram/hectare [hereinafter Kg/ha]. That the

majority soil (67.2 % of TGA) of the district have medium availability

of nitrogen (280-560 kg/ha) whereas soil of 26.1% area have low

available nitrogen content (


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(


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29.That it is humbly submitted that the state of Jharkhand has 24 districtsand total geographical area is 79.71 lakh hectares and an estimated 38

lakh hectares has been classified as cultivable. That about 18 lakh

hectare is the net sown area, comprising 22.7% of the total area and

47% of the cultivable area. That the state has 9.9%, 7.2%, 3.48% and

15.22% of the total geographical area of the State as land put to non-

agriculture use, barren & unutilized land, cultivable wasteland and

current fallows, respectively. That the State has 23.33 lakhs hectares of

land under forest cover, comprising 29.27% of the total geographical

area, which is much above the national average of about 18%. The net

irrigated area is only 2.01 lakh hectares which is about 8% of the net

sown area. The average area of holding in Jharkhand is 1.58 hectares

and it was slightly higher than all-India average of 1.57 hectares and

the land surface is rugged and undulating, ranging from flat lands to

almost steep slopes. The state produces a little less than half of its food

grains requirements. As a result, per capita food grain availability has

been 230g against 523g of all-India average and against 480g of

minimum requirement. That additional annual production of 24-25

lakh tonnes will be an uphill task in a scenario where land holdings are


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petition no.1558/2012 is herewith

annexed and marked as

Annexure-3

31. That careful reading of the khatians undisputedly reveals that majorityof the land in question which has been allotted to NUSRL, Ranchi is of

type Tanr-II, which is a Upland Sandy loam soil (generally red in

colour), with a characteristics of gentle slopy, good soil depth, low

water holding capacity (WHC), poor in organic matter, erosion prone,

acidic in nature (pH 4.56.5), having low fertility and under no

circumstances it can be termed as a fertile cultivable land.

A photo copy of the detailed

report of land allotted to

NUSRL, Ranchi is being

herewith annexed and

marked as Annexure-4

32. That it is humbly contended before this Honble Court that the state ofJharkhand comes under Agro-Climatic Zone VII (Eastern Plateau and

Hill Region). The whole State is divided in 3 sub zones, viz. sub zone


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IV (Central and North-Eastern Plateau), sub zone V (Western Plateau

Region) and sub zone VI (South Eastern Plateau). The sub zone IV

consists of 12 districts i.e. Dumka, Jamtara, Deoghar, Godda,

Sahebganj, Pakur, Hazaribagh, Koderma, Chatara, Giridih, Bokaro and

Dhanbad, sub zones V has 9 districts i.e. Ranchi, Gumla, Simdega,

Lohardaga, Palamau, Garhwa, Latehar, Khunti and Ramgarh while sub

zone VI consists only 3 districts, West Singhbhum, East Singhbhum

and Saraikela districts. There are three main crop seasons namely

Kharif, Rabi and Summer.

33. That it is further submitted that Kanke block comes under Ranchidistrict which is in sub zone V. That according to the survey of the

Directorate of Rice Research, the total yield of rice in this zone was

2830 kg/ha in the year 2008-09 which was a year of good monsoon

and thus of good yield. That it is humbly submitted that the

productivity of the land in question may deteriorate substantially in a

year of bad monsoon as the irrigation as well as power infrastructure in

the land in question is very rudimentary. The small size of land

holdings due to fragmentation also mean that scientific means of

production can hardly be employed.


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34. This implies that each family will have only 1217 kg of Dhan perannum, which is certainly insufficient to meet the need of grain

production for any rural household.

A photo copy of the

Research Report by the

Director of Research,

B.A.U, Ranchi on

production of rice in

District Ranchi on the

basis of which given

calculation is done is

being annexed herewith

& marked as

Annexure-5

35. That it is humbly submitted that the pattern of subsistence is reflectedin the demographic trend because out of 1,026,488 (total population) of

Kanke block only 23,121 people are cultivators, rest of the people are

working as either manual labour in some construction projects or in

household or as a marginal worker. Therefore, it is evident from the


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above data that agriculture is not and cannot be the sole occupation of

the people of Nagri village which comes under Kanke block.

36. It is further submitted that due to endemic impoverishment in Kankeblock, a number of policies are being undertaken by the Government

like MNREGA, PDS etc. which has improved the living conditions of

the villagers in some measure. Educational programmes run by the

government have resulted in a high literacy rate of 80.2% in the block.

That it becomes imperative to submit that the establishment of reputed

and renowned institutes in the locality will provide an impetus towards

socio economic growth of the region. However, the possibility of long

term benefits accruing to the people of the area after the establishment

of NUSRL, Ranchi is being undermined by certain vested interests that

have myopic selfish object. Since Nagri village is not very far from

Ranchi city, the life style of the villagers is influenced by the urban

way of living, and it has also affected the new generation so much so

that their cost of living has increased to a great extent and in order to

meet that expense, they have resorted to short-cuts. It is this young and

impressionable generation which is lead astray by the aforesaid vested

interests.


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A photo copy of

Jharkhand Governments

official data about Kanke

block is herewith annexed

and marked as

Annexure-6

37. That it is being contended on behalf of concerned villagers thatbecause some of affected villagers have not actually taken the

compensation amount awarded by the authorities in lieu of acquisition

of their land, therefore, the land acquisition is bad in the eyes of law.

However, it is pertinent to mention here that current land acquisition

was done more than 50 years back and as so judiciously noted by this

Honble Court that none of the agitating aggrieved parties were even

born at the time of acquisition so as to why the compensation amount

was not collected by those original rayyats could only be a matter of

conjecture. Additionally, it is most humbly submitted before this

Honble Court, that it is an established law of the land as provided for

in the Land Acquisition Act 1894 (hereinafter the Act), that if the

compensation awarded to the concerned persons from whom the land


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that money had been deposited with the state treasury for than 50

years. It is most humbly brought to the notice of this Honble Court

that in the said petition, the validity of the acquisition was never

challenged. It is most respectfully submitted that now the

compensation awarded per acre of land rests at Rs 20 lakh. It is

important to bring to the kind attention of this Honble Court that the

land in question is Bakhast Bhumihari land which cannot be sold in

free market to any one that they want to.

A photo copy of news

paper report published in

Prabhat Khabar dated

26th August 2012 giving

details of the current

amount of compensation

is being herewith

annexed and is marked as

Annexure No. 7

39. That it is most humbly submitted before this HonbleCourt that thereis no express bar on the government acquiring the agricultural land for


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public purposes, provided the appropriate procedure is followed during

the acquisition.

40. In the present case the land in dispute is not a highly productiveagricultural land and can be cultivated only during the rainy reason

vide Order No.3 of this Honble Court in W.P.(PIL)No.2347 of 2012

dated 16thMay 2012. Moreover, it is not the sole source of income for

their families as submitted in the preceding paragraphs of this

interlocutory application.

41. That it is most respectfully submitted that the courts have onlynullified those acquisitions wherein the statutory procedure and the

principles of natural justice have been grossly violated by the

concerned authorities. However, it is most humbly submitted that so

far acquisition of Nagri land is concerned the procedure had been

religiously followed.

42. That the intervener petitioners most humbly submit, even at the cost ofrepetition, that adequate compensation had already been awarded at the

time of acquisition which was never challenged by any of the raiyats

living at the time of acquisition. That it is further submitted that with

the lapse of time as the HonbleHigh Court had kindly noted that now


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the amount of compensation has accumulated to a large sum of money

as mentioned in para 38 of this interlocutory application.

43. That the intervening petitioners most humbly submit, that in thepresent case all the statutory provisions with respect to the land

acquisition have been religiously followed. Moreover, it is humbly

submitted that the HonbleSupreme Court has opined in Raja Anand

Brahma Shah v. State of Uttar Pradesh (AIR 1967 SC 1081) that once

Section 17(4) of the Act is invoked then Section 5A shall not be

applicable.

44. That it is most humbly submitted that after being carved out from thestate of Bihar, Jharkhand came into existence in Nov 15, 2000. That

the creation of this state is the culmination of more than half a century

of aspirations and struggle of the tribal people, who had witnessed the

ingress of outsiders in their land, economy and their social system. It

becomes imperative to mention that the prosperity of any state depends

upon its institutions and the opportunities provided by these

institutions to the people of the state. That the ability of the people to

make the best use of such opportunities is undoubtedly high, but they

can be improved considerably if the large masses are well educated


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and healthy. That though the state of Jharkhand is rich in minerals, it is

economically as well as educationally poor. Additionally it is to be

most humbly submitted that the state lags far behind in terms of

institutes of higher learning that can build capacity in local people to

exploit the natural wealth and richness so abundantly available within

the confines of state.

45. It is most pertinent to mention that eastern India used to be a hub ofeducation and research in ancient times. Since the very onset of

cultured civilized society, this region played a very significant role in

making people educated and research oriented despite of the fact that

the other societies across the country did not prioritize education. That

until before Independence, this region had been a cynosure of

education and research. People used to come and study in Universities

of Bihar, West Bengal. However, with the passage of time, these states

started lagging behind, not only in education but almost in all the

sectors of the economy.

46. That it is most humbly submitted that low level of education and lackof employment opportunities in Jharkhand has resulted in exodus of

tribal People to other states. This has created an alarming situation

for the tribal communities in the State as they continue to perish on


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A photo copy of the census

statistics about levels of

education among the major

scheduled tribes is being


marked as Annexure-8

49. It is humbly submitted that, the establishment of NUSRL in Nagrivillage will not only develop the infrastructure of the nearby areas, but

also provide employment opportunities to the local population. It is

humbly submitted that the local population may acquire Grade III and

Grade IV posts in the University, which will improve their standard of

living substantially. It is humbly submitted that due to the increase in

standard of living due to availability of better employment

opportunities, there might be a possibility of the local children being

future students in the University due to the 50% reservation for

Jharkhand domicile holders. Thus, it is humbly submitted that the

establishment of the University will furnish all round progress for the

surrounding community, promoting adequate growth and development.


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50. It is further submitted that due to non-availability of its own campusthe cost of running the university is going very high. A detailed

expenditure of amount already being spent and continuous cost of

running this university is presented below for the kind consideration

this Honble Court The detail of expenditure over construction of

boundary wall at site (Nagri) and rentals paid is as under:-

1) Against the Estimated Cost for the Construction of Boundary of theMain Campus a total amount of Rs. 2.36 crores, our contractor M/s

CPWD has so far submitted a Bill for Rs. 2.25 crores.

However, Rs. 1.5 crores has already been paid and Rs.75 lacks is yet to

be paid by us to CPWD for which CPWD has already furnished the

Bill and University is in the process to pay the same.

2)Rent details

S.No. Particulars Period Rent Remarks


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Amount

1 Academic Building and

Mess Building at BIT

Mesra

Dec 2010 to

June 2012

23,46,312.00 Yet to be

paid

(From July

2012 to till

Date Bill

has not yet

been

Received)

2 Boys Hostel

(Niwaranpur)

June2011 to

Nov 2011

7,55,000.00 Paid

3 Boys Hostel and Girls

Hostel

(Sahara Vihar)

Nov2011 to

Till Date

22,00,000.00 Paid

4 University Guest House Nov2010 to

April 2011

95,000.00 Paid

5 Honble V.C Residence

at Ashok Nagar

Nov2010 to

April 2011

80,000.00 Paid

6 Honble V.C Residence

at Dipatoli

April 2011 to

till Date

2,08,880.00 Paid


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7 Girls Hostel at BSNL June2011 to

Nov 2011

7,00,000.00 Paid

8 Girls Hostel at Gautam

Green City

Dec2010 to

Aug 2011

2,52,000.00 Paid

9 Boys Hostel at

KhelGaon

May 2012 to

till date

9,20,000.00 Yet to be

paid

TOTAL 75,57,192.00

Notes:

(A)Since the Hostel is situated at a considerable distance from the AcademicCampus, the University has purchased Two Buses for plying Students to

and fro from University to Hostel. This too has considerable expenditure in

terms of upkeep of (i) Staff for Bus (ii) Fuel Expenditure (iii) Vehicle

Maintenance.

(B)The University is in the process of purchasing the third Bus as presentlyTwo Busses are insufficient and causing tremendous inconvenience.


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Therefore, the costs as mentioned in (A) above are going to rise further.

(C)Mess is also being run at three different places i.e. in Boys and Girls Hosteland then in the Academic Bloc, accordingly the Cost of Mess Expenditure

which is being incurred by Students is also high and difficult to manage.

(D)Scattered infrastructure in absence of Universitys own campus has notonly been creating inconvenience of different sort but is also a

tremendously costly affair in terms of maintenance and more number of

staff for its upkeep and maintenance.

A photo copy of details

of expenditure of

NUSRL,Ranchi is


marked as Annexure- 9

51. That, it is humbly submitted that NUSRL is providing its students thebest academic experience. That the students are not lagging behind the

other prestigious law school so far the academic inputs are concerned.

However this is being achieved at a very high emotional and physical


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pleased for impleading them as co

petitioners for bringing on record certain

relevant facts for the kind consideration of

this Honble Court so that an appropriate

order can be passed so that complete

justice be done in the instant case to all the

parties concerned.

AND/ OR

For any other relief(s) as Your

Lordships may deem fit & proper.


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AFFIDAVIT

I, . S/O., Aged.., resident of

, P.S, District- do hereby solemnly affirm on

oath and declare as follows:

1.That I am appellant in this appeal.2.That I am fully acquainted with facts and circumstances of the

case.

3.That the statement written on foregoing appeal petition alongwith affidavit has been read and explained to me and I

understood the same and declare that the same is true and

correct as per my knowledge , information and belief.

Sworn and signed this affidavit on 28th

day of June 2013.

Place:

Deponet

Identified by me

nusrl petition

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