A.K.AMARAVEL PANDIYAN Advocate IN THE HIGH COURT OF JUDICATURE AT MADRAS AT MADURAI BENCH (Special Original Jurisdiction) W.P.(MD)No. of 2025 K.Kathiresan [M/58/2025], S/o. Karuppiah, Plot No.52, Kovarthanapuram, Poothagudi, Madurai North Taluk, Madurai – 625 017. … Petitioner Versus 1. The State of Tamil Nadu, Rep.by its Home Secretary, Secretariat, Chennai-600 009. 2. The Election Commission of India, Rep.by its Chief Election Commissioner, Nirvachan Sadan, Ashoka Road, New Delhi – 110 001. 3. The Chief Electoral Officer/Secretary to Government, Public (Elections) Department, Secretariat, St.George Fort, Chennai – 600 009. 4. The Director General of Police (Head of Police Force), No.4, Dr.Radhakrishnan Saalai, Mylapore, Chennai – 600 004. 5. Tamilaga Vettri Kazhagam, Rep.by it’s General Secretary,

A.K.AMARAVEL PANDIYAN Advocate
IN THE HIGH COURT OF JUDICATURE AT MADRAS AT MADURAI BENCH
(Special Original Jurisdiction)
W.P.(MD)No. of 2025
K.Kathiresan [M/58/2025],
S/o. Karuppiah,
Plot No.52, Kovarthanapuram,
Poothagudi, Madurai North Taluk,
Madurai – 625 017. … Petitioner
Versus
1. The State of Tamil Nadu, Rep.by its Home Secretary,
Secretariat, Chennai-600 009.

2. The Election Commission of India,
Rep.by its Chief Election Commissioner,
Nirvachan Sadan,
Ashoka Road,
New Delhi – 110 001.

3. The Chief Electoral Officer/Secretary to Government,
Public (Elections) Department,
Secretariat, St.George Fort,
Chennai – 600 009.

4. The Director General of Police (Head of Police Force),
No.4, Dr.Radhakrishnan Saalai,
Mylapore,
Chennai – 600 004.
5. Tamilaga Vettri Kazhagam,
Rep.by it’s General Secretary,
Bussy N.Anand,
Plot No. 275, Seashore Town, 8th Avenue, Panaiyur, Chennai-600119.

6. Mr.Joseph Vijay, S/o, Mr. Chandrasekhar,
Founder-President, Tamilaga Vettri Kazhagam,
Plot No. 275, Seashore Town, 8th Avenue,
Panaiyur, Chennai-600119. … Respondents

AFFIDAVIT FILED BY THE PETITIONER

I, K.Kathiresan, S/o. Karuppiah, aged about 58 years, residing at Plot No.52, Kovarthanapuram, Poothagudi, Madurai North Taluk, Madurai – 625 017, do hereby solemnly affirm and sincerely state as follows:

1. I respectfully submit that that I am the petitioner herein and, as such, I am well acquainted with the facts and circumstances of the case, and I have not filed any other writ petition or public interest litigation seeking similar relief sought for herein elsewhere.

2. I humbly submit that I am filing this writ petition as a Public Interest Litigation and there is no oblique motive or any other personal interest in filing this writ petition. I humbly submit that I am filing this Public Interest Litigation out of my own funds and out of my own knowledge gathered from various news publications and reports. I undertake to pay any cost if this Hon’ble Court finds that the present public interest litigation is filed for any other oblique motive. My Aadhar card number is 6341 1033 5587 and I am not an income tax assesse.

3. I humbly submit that I am a public-spirited individual engaged in social welfare work, and an active member of labour/trade union movements. Over the years, I have been driven by a sense of responsibility in standing and fighting for the causes of marginalized and vulnerable people who are left to suffer due to administrative neglect. I have previously filed several Public Interest Litigations before the Madurai Bench of the Madras High Court on issues of public health, civic safety, and human rights, notably in the year 2018, after the Sterlite Firing, I approached this Hon’ble Court through a PIL, filed in WP(MD)No.11391/2018 seeking CBI enquiry for the Sterlite Shooting, and registration of 302 IPC against the Police Officers involved in the indiscriminate firing at Thoothukudi. In the year 2017, I had filed a PIL in WP(MD)No.12482/2017, challenging the extension of service granted to the then DGP (Head of Police Force) Mr.T.K.Rajendiran I.P.S, who was allegedly implicated in the Gutka Scam, after some incriminating evidence were recovered from the Residence of the then Late.Chief Minister.Selvi Jayalalitha, disposing off the PIL, this Hon’ble Court allowed the Writ Petition, and ordered for DVAC enquiry into Mr.T.K.Rajendiran DGP.

4. I humbly submit that in 2018, I filed another PIL in WP(MD)25215/2018, also against Mr.T.K.Rajendiran I.P.S, DGP, wherein I sought for a direction directing the Government to recall the appointment of Mr.T.K.Rajendiran, I.P.S., after he was implicated in the alleged gutka scam, where incriminating evidence was recovered from the residence the then Late.Chief Minister.Selvi Jayalalitha and another PIL in
WP(MD)No.5775/2019 was filed seeking to keep away Mr.T.K.Rajendiran I.P.S, DGP from the post of DGP Head of Police Force, till the completion of Parliamentary General Elections 2019, which was allowed, directing the Election Commission to Consult and issue appropriate directions as per law. At present through this Public Interest Litigation, I seek to bring to the attention of this Hon’ble Court the grave and recurring systemic failure resulting in catastrophic loss of life during public gatherings, particularly political rallies, due to lack of adequate safety precautions, and to implore the requirement and implementation of mandatory, legally enforceable regulations to prevent such tragedies in future. Only to prevent any other tragedy, which may ensue in the near future, since the election campaign for the upcoming state general elections, seems to have caught pace, leading to many political parties who are rallying across various constituencies, to show their political clout, and power, have been acting in a manner endangering the lives of innocent people, therefore I am constrained to knock the doors of this Hon’ble Court, even during the Dusshera Holidays, and I am filing this as an emergency petition, seeking relief to prevent any loss of lives.

5. I humbly submit that in recent times there is a raise in recurring tragedies in Tamil Nadu and across India arising from ill-managed public gatherings, political rallies, roadshows, and conferences where thousands of innocent people, including party cadres, bystanders, women, and children, lose their lives in stampedes and crowd surges due to the negligence of the organizers. In a very recent tragedy that occurred at Karur on 27.09.2025, during a political rally organized by the newly formed political party, Tamilaga Vettri Kazhagam (TVK), led by its Founder-President, actor-turned-politician Mr. Joseph Vijay, the scheduled event effectively turned into a roadshow. The said rally commenced at Namakkal and concluded at Karur.

6. I humbly submit that On 27 September 2025 during the late evening hours in Karur district (Veluswamypuram region, along the Karur–Erode highway), the political rally organized by Tamilaga Vettri Kazhagam (TVK), led by Mr. Joseph Vijay, ended in horror when 40 persons (as per the verified news reports, confirmed by official Government Communications) were killed and more than 80 injured as the unmanageable crowd suddenly surged and trampled over each other, leading to an inadvertent stampede. Though permission had been granted (reportedly for about 10,000 persons as per the permission letter submitted by TVK organizers for the Karur gathering), eyewitnesses and media reports show that the actual crowd massively exceeded permitted strength, swelling over hours in stifling heat without proper water, medical aid, or appropriate crowd control. Some reports highlight that Mr.Vijay’s delayed arrival (by more than seven hours) further aggravated crowd impatience, who were made to wait in scorching sun, without any basic amenities for water and toilets, leading to dehydration, chaos and mass hysteria, thereby compounding the risk. The stampede was allegedly triggered when the congested crowd surged toward barricades near the campaign caravan of Mr.Vijay and towards the adjacent structures and the absence of adequate buffer zones, cordons, absence of multiple exits (ingress and egress), insufficient police personnels, and poor monitoring exacerbated the tragedy leading to the loss of 40 Innocent lives.

7. I humbly submit that, it is not an exaggeration to say that in Tamil Nadu and across India, mass gatherings especially for political speeches, roadshows, public meetings which are often organized with scant regard for basic safety protocols. The allure of gathering large crowds showing their political clout and might, the pressure of electoral competition, and lack of accountability result in corners being cut, even when human lives are at stake. Attendance of the people sometimes far exceeds expected numbers, crowd density becomes intolerable, exit routes are inadequate or blocked, medical and rescue infrastructure is insufficient or at times non-existent, and real-time crowd management (via proper liaisons, CCTV monitoring, public announcements) is poorly handled or absent. Yet time and again, when a minor trigger or panic sets in, the result is a stampede, or crowd crush resulting in loss of innocent lives. Post Karur tragedy, the Government of Tamil Nadu declared a judicial commission of inquiry (headed by a retired judge) to investigate and unravel the causes and recommend remedial measures to prevent future tragedies alike. This disaster is not merely the failure of a single political event it underscores a systemic lapse in the security and safety protocols especially in political rallies, despite their scale and risk, which are routinely exempt from stringent safety regulations.

8. I humbly submit that the tragic incident at Karur is the recent addition to a long and distressing history of mass-casualty events arising from inadequate safety measures during public gatherings. The State of Tamil Nadu itself has witnessed several such calamities, including the Mahamaham stampede at Kumbakonam on 18th February 1992, where nearly 50 lives were lost and over 70 persons injured when pilgrims surged into the Mahamaham tank during festival rituals, and the MGR Nagar relief distribution stampede in Chennai on 18th December 2005, which claimed 42 lives and left 37 injured when a queue for flood-relief tokens turned chaotic. Beyond the State, India has faced similar tragedies, such as the Sabarimala stampede in 2011, resulting in over 100 deaths, and the Hathras religious gathering in 2024, where more than 120 people perished. In Tamil Nadu, incidents such as the Brihadeeswara Temple fire at Thanjavur (1997), the Kumbakonam school fire (2004), the Srirangam hall fire (2004), and the Erwadi fire tragedy (2001) also carried a dimension of stampede or crowd crush, exacerbated by blocked exits, unsafe structures, and gross overcrowding. Collectively, these incidents demonstrate a recurring and preventable pattern of mass casualties, wherein repeated loss of innocent lives has been followed by the Government announcing compensation, inducting commissions of inquiry and various other judicial observations, yet, despite such findings, no comprehensive, binding, or enforceable regulatory framework has been instituted to govern political, religious, or other large-scale public gatherings, thereby leaving public safety inadequately protected.

9. I humbly submit that over the years, both the Central and State Government institutions, disaster management bodies, Bureau of Police Research and Development, and the civil society at large have recognized this need and prepared guiding documents, procedures and protocols. But, regrettably, these remain only advisory and are seldom mandated, especially for political rallies. It is submitted that the Government of India, through its statutory authorities, has already recognized the urgent necessity of moving from a framework of “crowd control” to that of “crowd management, and to that effect the National Disaster Management Authority (NDMA) has issued the National Guide on Crowd Management, which emphasizes a systematic and multi-agency approach. The said guide underscores the importance of risk assessment, capacity planning, scientific design of ingress and egress routes, real-time monitoring, emergency response protocols, and accountability mechanisms for organizers and authorities alike. This guide, which is accessible through the NDMA’s official website, lays down detailed protocols for managing crowds at events and venues of mass gatherings.

10. I humbly submit that the National Institute of Disaster Management (NIDM) has published a comprehensive Training Module on the Management of Crowds at Large Congregations. This module elaborates upon practical and ground-level measures, including the training of stewards and volunteers, medical preparedness and planning, mechanisms for mass communication, emergency evacuation protocols, and relevant legal provisions to ensure compliance. In addition to the above, the Bureau of Police Research and Development (BPRD) has issued its Guidelines on Crowd Control and Mass Gathering Management. These guidelines, while not binding in nature, are nevertheless recognized as best practices and provide valuable operational protocols for the police. They cover aspects such as traffic management, coordination with organizers, liaison with various agencies, and integration with emergency rescue services. It is also relevant to point out that internationally accepted models and best practices exist, which India can emulate and adapt. These include the United Kingdom’s Green Guide and Purple Guide, as well as the World Health Organization’s Mass Gatherings Risk Management Guidelines. These standards prescribe norms such as permissible capacity per square meter, mandatory buffer zones, proper signage, fixed thresholds for emergency evacuation times, and crowd density limits all of which are scientifically devised to prevent crushes, stampedes, and mass casualty events.

11. I humbly submit that, despite the existence of these national and international frameworks, serious lacunae remain in their application to political rallies and election-related events in Tamil Nadu and across India. At present, none of the above standards have the force of statutory law in this context. There is no State-level regulation in Tamil Nadu which mandates that compliance with these guidelines is a precondition for the grant of permission to conduct rallies or mass gatherings. Organizers of such political events are rarely, if ever, held liable under civil or criminal law even when glaring safety lapses are evident. Furthermore, there is no statutory requirement for political parties or organizing bodies to provide any form of financial surety, deposit, or group insurance, which could ensure timely compensation to victims and their families in the event of a tragedy.

12. I humbly submit that the Indian constitutional framework leaves no room for doubt that the right to life under Article 21 is non-negotiable. Citizens who attend public rallies whether as supporters, bystanders, or mere passers-by do so on the legitimate expectation that the State will safeguard their lives. The Supreme Court has repeatedly held that the right to life includes the right to live with safety and dignity (Olga Tellis v. Bombay Municipal Corporation, (1985) 3 SCC 545, Municipal Council, Ratlam v. Vardichan, (1980) 4 SCC 162). Further, Article 14 mandates equality before law, requiring that uniform safety norms apply to all mass gatherings, whether religious, political, or social. Political rallies cannot be granted exceptions or treated with undue laxity. The Hon’ble Apex Court in State of West Bengal v. Anwar Ali Sarkar, AIR 1952 SC 75, emphasized that any classification must satisfy the test of fairness and reasonableness, and selective enforcement or relaxation of norms would offend Article 14. The State, including its agencies such as the Government, police, and election authorities, carry a positive obligation not merely to issue permissions for rallies, but to make such permissions strictly conditional upon compliance with established safety protocols. In
In Re: Amarnath Shrine, (2012) 12 SCC 274, the Hon’ble Supreme Court underscored that the State has a constitutional duty to ensure safety, medical aid, and welfare measures during mass gatherings, and cannot abdicate its responsibility by merely granting permissions.

13. I humbly submit that tragedies of this nature cannot be treated as isolated accidents. They represent a pattern of recurring administrative neglect where public safety is sacrificed in the name of political spectacle or mass mobilization. Time and again, after such events, commissions of inquiry are announced and compensation packages are declared, but the systemic causes are left unaddressed. The families of the deceased are left with nothing but grief and inadequate compensation, while those responsible escape accountability. Unless preventive frameworks are instituted, the same cycle will continue, and innocent citizens will continue to pay with their lives.

14. I humbly submit that the Hon’ble Supreme Court has consistently recognized that this Hon’ble Court, under its extraordinary jurisdiction, is empowered to issue preventive directions to fill legal and regulatory gaps. In Vishaka v. State of Rajasthan, (1997) 6 SCC 241, the Apex Court laid down binding guidelines in the absence of legislation to protect women against sexual harassment at workplaces. Likewise, in Bandhua Mukti Morcha v. Union of India, (1984) 3 SCC 161, the Court intervened to secure the fundamental rights of bonded labourers. These landmark judgments embody the principle of preventive jurisprudence wherein the Hon’ble Supreme Court had time and again emphasized that the Courts need not wait for future violations to occur, but can proactively frame guidelines to safeguard fundamental rights.

15. I humbly submit that the failure to regulate political rallies with binding safety norms constitutes not only a violation of Article 21, but also a hit on Article 14, which guarantees equality before law and equal protection of law, and political rallies often enjoy exceptions or laxity in the enforcement of stringent conditions for organizing such political gatherings. Furthermore, political parties’ right to assemble under Article 19(1)(b) cannot override the equally sacrosanct rights i.e., the right to life, safety, and dignity. The Constitution of India permits reasonable restrictions on assemblies in the interests of public order, health, and safety, and it is the duty of the State to enforce such restrictions uniformly.

16. I humbly submit that accountability must also extend to organizers and political parties themselves. In Sanjay Gupta & Others v. State of Uttar Pradesh, (2015) 5 SCC 423, arising out of a public event tragedy, the Hon’ble Supreme Court apportioned liability between the organizers and the State, recognizing that both share responsibility when safety lapses cause loss of life. Yet, in Tamil Nadu, political organizers continue to conduct mass rallies without financial sureties, indemnities, or group insurance, leaving the burden of compensation entirely on the State exchequer. This creates moral hazard and exerts undue pressure on the public exchequer, where political parties externalize the risks of their conduct onto innocent citizens and impose on the government to use the taxpayers money to compensate, and those who responsible for such lapses walk away Scott free.

17. The tragic loss of 40 innocent lives at Karur stands as a painful and stark reminder that whenever large crowds are brought under political display, human lives are placed at risk and reduced to collateral, all because basic safeguards like water, shade, medical aid, multiple exits, and buffer zones were ignored in pursuit of crowd size and political theatre. This public interest litigation is not made in any partisan spirit, but out of deep concern and anguish for every family that has been irreparably affected by such an avoidable tragedy. If the Government and the Election Commission do not act with immediacy to institutionalize enforceable safety mechanisms, it is inevitable that similar tragedies will recur, and the State will once again be left to account for preventable loss of lives. This Hon’ble Court has always stood as vigilant guardian, protecting the fundamental rights of voiceless citizens. It is in that spirit that I approach this Court, with folded hands, seeking that binding, enforceable regulations be framed and implemented, so that no such innocent lives have to be lost for merely attending a public gathering. In that letter and spirit, I have made a detailed representation to the respondents 1 to 4 on 29.09.2025, through official E-mail of the respondents 1 to 4 and through Registered post with AD, but thus far no adequate measures have been taken and having left with no other alternate and efficacious remedy, I am constrained to approach this Hon’ble Court by invoking the extraordinary jurisdiction of this Hon’ble Court Under Article 226 of the Constitution of India, calling upon this Hon’ble High Court’s interference to render justice.

18. I humbly submit that as per the Schedule released by the 5th and 6th Respondent, they have planned to organise political rally beginning from 13.09.2025 to 20.12.2025, wherein the private respondent had planned to cover all the Constituencies, during the rally organised only on Weekends (Saturday and Sunday). Therefore, I pray before this Hon’ble Court, to grant an Ad-Interim Injunction, restraining the 5th and 6th Respondent and any other political party from organizing further political rallies, unless until stringent regulations are formulated mandating strict safety conditions and precautionary measures, if the Injunction is not granted and the Respondents 5 to 6 or any other political parties/organizations be allowed to continue their mass gatherings without any regulatory rules framed, will cause severe prejudice to the public safety. This would not in any manner curtail the Fundamental Right to Peaceable assembly guaranteed under Article 19(1)(b), since such Fundamental Rights are not absolute in nature and is subject to reasonable restrictions, and this Hon’ble Court is empowered to impose such reasonable restrictions till such regulations are framed. The balance of inconvenience is in favour of granting the interim order, and if this interim order is not granted the general public at large will be put into much hardship and irreparable loss.

Therefore it is most humbly prayed that his Hon’ble Court may be pleased to grant and AD-INTERIM INJUNCTION restraining the 5th and 6th Respondent namely the political party Tamilaga Vettri Kazhagam (TVK) and its Founder-President Mr. Joseph Vijay, from organizing or conducting any further political rallies, roadshows, or mass gatherings in the State of Tamil Nadu, and further restraining any other political party or organization from conducting such rallies or congregations, unless and until stringent and legally enforceable regulations, mandating strict safety conditions and precautionary measures, are framed and notified by the Respondents 1 to 4 and to pass such further or other orders as this Hon’ble Court may deem fit and proper in the circumstances of the case and thus render justice.

Therefore it is most humbly prayed that his Hon’ble Court may be pleased to grant and AD-INTERIM DIRECTION directing the respondents 1 to 4 to constitute a state level expert committee comprising of retired judges, disaster management professionals, crowd-safety engineers, and public health experts, to prepare a comprehensive statutory framework including provisions for pre-event risk assessment, crowd-capacity certification, safety and evacuation plans, viability in collection of caution deposits/indemnity bonds, and group insurance schemes to ensure compensation to victims in case of loss of life or injury, for safe conduct of such public events within a time limit that may be prescribed by this Hon’ble Court, and to pass such further or other orders as this Hon’ble Court may deem fit and proper in the circumstances of the case and thus render justice.

Therefore it is most respectfully prayed that this Hon’ble Court may be pleased to issue a writ, order or direction more particularly in the nature of WRIT OF MANDAMUS or any other appropriate writ directing the Respondents 1 to 4 to frame and notify appropriate rules, regulations, standard operating procedures (SOP’s) for regulating political rallies, roadshows, conferences and other mass gatherings in Tamil Nadu by adopting the crowd management guidelines issued by the NDMA(National Disaster Management Authority), NIDM (National Institute for Disaster Management) and BPRD (Bureau for Police Research and Development), thereby mandating the imposition of stringent regulations which are legally enforceable on the organizers of such rally in order to ensure adequate safety and precautionary measures, with appropriate guidelines for the collection of safety deposits, indemnity bonds, enrolment of group insurance scheme from such organizers/political parties who intend to organize such rallies, large congregations to ensure compensation for victims who may suffer irreparable injury and loss of life in the event of any untoward incidents that may happen, by considering my representation dated 29.09.2025 within a time limit that may be fixed by this Hon’ble Court which is deem fit proper in the circumstances of the case and thus render justice.

Solemnly affirmed at Madurai ]
on this the 30th day of September 2025 ]
the contents of this Affidavit were ] read to him and explained to him in Tamil ]
and he appeared to have understood the same ]
Perfectly and signed his name in ]
My presence. ]
BEFORE ME

ADVOCATE

MEMORANDUM OF WRIT MISCELLANEOUS PETITION
FILED UNDER ARTICLE 226 of CONSTITUTION OF INDIA)
IN THE HIGH COURT OF JUDICATURE AT MADRAS
MADURAI BENCH
(Special Original Jurisdiction)

W.M.P.(MD)No. of 2025
In
W.P. (MD) No. of 2025

K.Kathiresan [M/58/2025],
S/o. Karuppiah,
Plot No.52, Kovarthanapuram,
Poothagudi, Madurai North Taluk,
Madurai – 625 017. … Petitioner/Petitioner
-Vs-
1. The State of Tamil Nadu, Rep.by its Home Secretary, Secretariat, Chennai-600 009.

2. The Election Commission of India, Rep.by its Chief Election Commissioner,
Nirvachan Sadan, Ashoka Road,
New Delhi – 110 001.

3. The Chief Electoral Officer/Secretary to Government,
Public (Elections) Department,
Secretariat,
St.George Fort, Chennai – 600 009.

4. The Director General of Police (Head of Police Force),
No.4, Dr.Radhakrishnan Saalai, Mylapore,
Chennai – 600 004.

5. Tamilaga Vettri Kazhagam,
Rep.by it’s General Secretary,
Bussy N.Anand,
Plot No. 275, Seashore Town, 8th Avenue, Panaiyur, Chennai-600119.

6. Mr.Joseph Vijay,
S/o, Mr. Chandrasekhar,
Founder-President, Tamilaga Vettri Kazhagam,
Plot No. 275, Seashore Town, 8th Avenue,
Panaiyur, Chennai-600119. … Respondents/Respondents

AD-INTERIM INJUNCTION
For the Reasons stated in the accompanying affidavit, it is therefore prayed that this Hon’ble Court may be pleased to issue an AD-INTERIM INJUNCTION restraining the 5th and 6th Respondent namely the political party Tamilaga Vettri Kazhagam (TVK) and its Founder-President Mr. Joseph Vijay, from organizing or conducting any further political rallies, roadshows, or mass gatherings in the State of Tamil Nadu, and further restraining any other political party or organization from conducting such rallies or congregations, unless and until stringent and legally enforceable regulations, mandating strict safety conditions and precautionary measures, are framed and notified by the Respondents 1 to 4 and to pass such further or other orders as this Hon’ble Court may deem fit and proper in the circumstances of the case and thus render justice.

Dated at Madurai on this 30th day of September, 2025.

Counsel for the Petitioner
MEMORANDUM OF WRIT MISCELLANEOUS PETITION
FILED UNDER ARTICLE 226 of CONSTITUTION OF INDIA)
IN THE HIGH COURT OF JUDICATURE AT MADRAS
MADURAI BENCH
(Special Original Jurisdiction)

W.M.P.(MD)No. of 2025
In
W.P. (MD) No. of 2025

K.Kathiresan [M/58/2025],
S/o. Karuppiah,
Plot No.52, Kovarthanapuram,
Poothagudi, Madurai North Taluk,
Madurai – 625 017. … Petitioner/Petitioner
-Vs-
1. The State of Tamil Nadu, Rep.by its Home Secretary,
Secretariat, Chennai-600 009.

2. The Election Commission of India, Rep.by its Chief Election Commissioner,
Nirvachan Sadan, Ashoka Road,
New Delhi – 110 001.

3. The Chief Electoral Officer/Secretary to Government,
Public (Elections) Department,
Secretariat,
St.George Fort, Chennai – 600 009.

4. The Director General of Police (Head of Police Force),
No.4, Dr.Radhakrishnan Saalai, Mylapore,
Chennai – 600 004.

5. Tamilaga Vettri Kazhagam,
Rep.by it’s General Secretary,
Bussy N.Anand,
Plot No. 275, Seashore Town, 8th Avenue, Panaiyur, Chennai-600119.

6. Mr.Joseph Vijay,
S/o, Mr. Chandrasekhar,
Founder-President, Tamilaga Vettri Kazhagam,
Plot No. 275, Seashore Town, 8th Avenue,
Panaiyur, Chennai-600119. … Respondents/Respondents

AD-INTERIM DIRECTION
For the Reasons stated in the accompanying affidavit, it is therefore prayed that this Hon’ble Court may be pleased to issue an order of ADINTERIM DIRECTION directing the respondents 1 to 4 to constitute a state level expert committee comprising of retired judges, disaster management professionals, crowd-safety engineers, and public health experts, to prepare a comprehensive statutory framework including provisions for pre-event risk assessment, crowd-capacity certification, safety and evacuation plans, viability in collection of caution deposits/indemnity bonds, and group insurance schemes to ensure compensation to victims in case of loss of life or injury, for safe conduct of such public events within a time limit that may be prescribed by this Hon’ble Court, and to pass such further or other orders as this Hon’ble Court may deem fit and proper in the circumstances of the case and thus render justice.

Dated at Madurai on this 30th day of September’2025.

Counsel for the Petitioner
MEMORANDUM OF WRIT PETITION
FILED UNDER ARTICLE 226 of CONSTITUTION OF INDIA)
IN THE HIGH COURT OF JUDICATURE AT MADRAS
MADURAI BENCH
(Special Original Jurisdiction)

W.P. (MD) No. of 2025

K.Kathiresan [M/58/2025], S/o. Karuppiah,
Plot No.52, Kovarthanapuram,
Poothagudi, Madurai North Taluk,
Madurai – 625 017. … Petitioner
-Vs-
1. The State of Tamil Nadu, Rep.by its Home Secretary, Secretariat, Chennai-600 009.

2. The Election Commission of India, Rep.by its Chief Election Commissioner,
Nirvachan Sadan, Ashoka Road, New Delhi – 110 001.

3. The Chief Electoral Officer/Secretary to Government,
Public (Elections) Department,
Secretariat,
St.George Fort, Chennai – 600 009.

4. The Director General of Police (Head of Police Force),
No.4, Dr.Radhakrishnan Saalai, Mylapore,
Chennai – 600 004.

5. Tamilaga Vettri Kazhagam,
Rep.by it’s General Secretary,
Bussy N.Anand,
Plot No. 275, Seashore Town, 8th Avenue, Panaiyur, Chennai-600119.

6. Mr.Joseph Vijay,
S/o, Mr. Chandrasekhar,
Founder-President, Tamilaga Vettri Kazhagam,
Plot No. 275, Seashore Town, 8th Avenue,
Panaiyur, Chennai-600119. … Respondents

WRIT PETITION
The address for service on the Petitioner is that of his counsel M/s A.K.AMARAVEL PANDIYAN Advocate having his office at Plot
No.30,East 2nd Cross Street, K.K.Nagar, Madurai- 625 020. The address for service on the Respondents is as stated above.

For the reasons stated in the accompanying affidavit, it is therefore humbly prayed that this Hon’ble Court may be pleased to issue a writ, order or direction, more particularly in the nature of a WRIT OF MANDAMUS or any other appropriate writ directing the Respondents 1 to 4 to frame and notify appropriate rules, regulations, standard operating procedures (SOP’s) for regulating political rallies, roadshows, conferences and other mass gatherings in Tamil Nadu by adopting the crowd management guidelines issued by the NDMA(National Disaster Management Authority), NIDM (National Institute for Disaster Management) and BPRD (Bureau for Police Research and Development), thereby mandating the imposition of stringent regulations which are legally enforceable on the organizers of such rally in order to ensure adequate safety and precautionary measures, with appropriate guidelines for the collection of safety deposits, indemnity bonds, enrolment of group insurance scheme from such organizers/political parties who intend to organize such rallies, large congregations to ensure compensation for victims who may suffer irreparable injury and loss of life

in the event of any untoward incidents that may happen, by considering the petitioner’s representation dated 29.09.2025 within a time limit that may be fixed by this Hon’ble Court which is deem fit proper in the circumstances of the case and thus render justice.

Dated at Madurai on this 30th September 2025.

COUNSEL FOR THE PETITIONER

DISTRICT : MADURAI
IN THE HIGH COURT OF
JUDICATURE AT MADRAS MADURAI BENCH
(Special Original Jurisdiction)
W.P.(MD) No. of 2025
K.Kathiresan …Petitioner
Vs
THE STATE OF TAMIL NADU,
REP. BY ITS HOME SECRETARY,
& 5 ORS.
…Respondents

*******************************
WRIT PETITION
PAPER BOOKLET – I
*******************************

M/s.

A.K. AMARAVEL PANDIYAN
(5811/2022)

COUNSEL FOR THE PETITIONER