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impugned show cause notice has been issued pursuant to the conduct of the RSS camp and it is submitted that RSS activities and camps are neither religious nor political in nature. Persons of all faith, irrespective of their religion, caste, color or creed participate in the camps and the organization primarily boasts the goal such as “Nation First” and intends to promote proven life science activities such as Yoga as part and parcel of their camp activities. The rationale behind the camps is to inculcate patriotism in the minds of fellow citizens who join the camp voluntarily.

by Sekar Reporter · February 3, 2026

IN THE HIGH COURT OF JUDICATURE AT MADRAS (Special Original Jurisdiction)

W.P. No. of 2026

Sri Saraswathi Vidyalaya

Nursery & primary school,

Rep. by its Correspondent

S.Surenthiran- Age/28

U. Mangalam , Virudhachalam Taluk, Cuddalore District–607804.

…Petitioner

-Versus-

1. The Government of Tamilnadu Rep. by its Principal Secretary,

Department of Education

Fort St.George, Chennai – 600 009.

2. The Directorate of School Education (Private Schools)

Rep. by its Director

No. 17, College Rd,

Subba Road Avenue, Nungambakkam, Chennai, Tamil Nadu 600006.

…Respondents

PETITIONER’S AFFIDAVIT

I, S.Surenthiran- Age/28, the correspondent of Sri Saraswathi Vidyalaya

Nursery & primary school, located at U. Mangalam Virudhachalam Taluk, Cuddalore District-607804, temporarily come down to chennai, do hereby solemnly affirm and sincerely state on oath as follows:

1. I respectfully state that I am the correspondent of the school and as such I am well acquainted with the facts and circumstances of the case and I am competent to swear this Affidavit and institute this writ petition on behalf of the School.

2. I respectfully state that the Sri Saraswathi Vidyalaya Nursery & primary school, is private school, which regularised under the directorate of private school, in the state of Tamilnadu . The schools is established as per the existing act of the state.

3. I humbly state that the schools having sufficient teaching and nonteaching staff on a regular basis.

4. I further state that, the learned that organisers of RSS camps are foundational to its structure, transforming volunteers into disciplined members committed nationalist vision integral physical training, ideological indoctrination community building, and developing These camps focus on discipline, culture, character building, often targeting youth and students.

5. I further submit that Key aspects such camps being to in-still discipline, nationalist ideology physical fitness, Physical exercises, games, ideological sessions (sermons), patriotic songs, and community service are being essence as a movement for national reconstruction totally nurtured by the people.

6. I humbly submit that Youths and boys of all ages engage in varieties of indigenous games. Uninhibited joy fills the air. There are exercises, Suryanamaskar, sometimes training in skill fully wielding the “Danda”. All activities arc totally disciplined while so,

7. I respectfully state that during the December month vacation 2025, the Petitioner had given the school playground to be used for the purpose of conducting Seva Bharathi camp, a wing of Rashtriya Swayam Sangh on

24.12.2025 and 30.12.2025. I further state that the School was not functioning on the said dates when the camps were held as the students were on their holidays.

8. I respectfully state that the said camp camp held in December 2025 was conducted with 50 participants and the same was the routine practice and procedure followed by RSS throughout India including the State of Tamilnadu for several years. The participants and the cadre at the said camps maintained utmost discipline and orderly behaviour at all times.

9. I humbly submit that the participants approached the school in a wellinformed manner, without disrupting the school’s day-to-day activities. The event was conducted exclusively during holidays, ensuring no interference with the school’s regular functions. Furthermore, the participants’ conduct and the activities carried out on campus were wholesome and aligned with everyday human pursuits essential for physical and mental development.

10. I humbly state that it was stated by the organiser that the organisation is formed for character building constitutes the primary and most fundamental activity of every citizen to think of the nation’s growth and to develop the patriotism and compassion for society. This activity aims at the physical, psychological (emotional), and intellectual development of participants.

11. I humbly state that on December 2025 school holidays, the program organisers have approached the school for conducting the said activity and the premises were allowed to conduct the camp from 24.12.2025 to 30.12.2025, being so, on the day of commencement the local police people have approached us and enquired about the camp asked us to send

out the participants out from the school and pressurised us also not to conduct the same in the near future.

12. I respectfully state that under such circumstances, the 2nd Respondent issued the impugned show cause notice vide its proceedings bearing Na.Ka.No.5458-2/F3/2025 dated 30.12.2025, across Tamilnadu, which is unilaterally and arbitrarily circulated this.

GROUNDS

i. The impugned show cause notice issued by the 2nd Respondent is arbitrary, malicious, oppressive, made without jurisdiction and completely devoid of merits and contrary to facts.

ii. The trust and Societies are being formed by the team of philanthropic individuals who are committed to carry out certain specific activities of the organization and its goals to substantiate Govt initiatives for the welfare of the people and society need in time to time. Wherein the education may be one among the objectives of the organization.

iii. The 2nd Respondent issued the impugned show cause notice on the basis that the Petitioner has violated Rule 9 (jj) of Tamil Nadu Recognised Private Schools (Regulation) Rules, 1974 and the relevant provisions is extracted hereunder:

Rule 9(jj) The use of the building and other properties including the playground of any recognised private school for conducting drill or training with or without arms by persons who are not students or members of the staff of the school shall not be permitted by the management under any circumstances:

Provided further that non-observance of the condition laid down in clause (jj) above will entail the withdrawal of recognition, and aid as per sub-section (1) of section 12 of the Tamil Nadu Recognised Private Schools (Regulation) Act, 1973 (Tamil Nadu Act 29 of 1974).

iv. A bare reading of Rule 9 (jj) of Tamil Nadu Recognised Private Schools (Regulation) Rules, 1974 would show that it applies only to those days when the school is functioning and it has no application for those days when the school is closed for vacation.

v. The show Cause notice also stems on the premise that no religious activity or meeting can be held in the premises of private schools and that the same is in contravention to the Tamilnadu Private Schools Regulations Act 1973, as no such provision exists in the legislation itself.

vi. The impugned show cause notice has been issued pursuant to the conduct of the RSS camp and it is submitted that RSS activities and camps are neither religious nor political in nature. Persons of all faith, irrespective of their religion, caste, color or creed participate in the camps and the organization primarily boasts the goal such as “Nation First” and intends to promote proven life science activities such as Yoga as part and parcel of their camp activities. The rationale behind the camps is to inculcate patriotism in the minds of fellow citizens who join the camp voluntarily.

vii. The said camp being conducted entire country during summer vocation holidays with proper permission of administration of the institution to scale up our social mileage in the local vicinity where we institution has passion to support such Non Political and non-Religion based activities. Thereby we used to get volunteers from our local surrounding villagers during any organised events for the welfare of the community advancement through our schools as like Rotary and Lions, environment, Health clubs cte. Furthermore, there has been celebrations for the all the religious festivals including Pongal, Christmas and ramjan festivals etc.

with intent of cultural enrichment of the younger generations. viii. The impugned show cause is issued with the sole intention of furthering the interests of the ruling party in the upcoming State elections. The Government machineries are being used as engines of oppression to crush the sense of Nationalism which is gaining ground and favour among the people of the State.

ix. The said impugned order is only in the state of Tamilnadu for trying to satisfied few portioned of people and to take away the rights of the institution aims and objectives of the foundation and its vision.

x. The Petitioner reserves its right to raise additional grounds at the time of arguments.

xi. I respectfully state that the Petitioner is left with no other alternative or efficacious remedy, except to approach this Hon’ble court by way of the present writ petition invoking Article 226 of the Constitution of India. xii. I respectfully state that the Petitioner has not filed any other writ petition before any other court.

xiii. I respectfully state that the original impugned show cause notice is circulated across many private school and the same is applicable

to the office of the Petitioner and it us therefore just and necessary to dispense with the production of the original impugned show cause notice bearing Na.Ka. No.5458-2/F3/2025 dated 30.12.2025 issued by the 2nd Respondent.

It is therefore prayed that this Hon’ble Court may be pleased to dispense with the production of the original of the impugned show cause notice bearing Na.Ka. No.5458-2/F3/2025 dated 30.12.2025 issued by the 2nd Respondent and thus render justice.

It is therefore prayed that this Hon’ble Court may be pleased to issue Writ, Order or Direction more particularly in the nature of a Writ of Certiorari calling for the records of the impugned show cause notice bearing Na.Ka. No.5458-2 /F3/2025 dated 30.12.2025 issued by the 2nd Respondent, quash the same as unconstitutional, made without jurisdiction, arbitrary and pass such further and other orders as this Hon’ble Court may deem fit and proper according to the facts and circumstances of the case and thus render justice.

Solemnly affirmed at Chennai {} Before me on this the 27th day of January 2026 {} and signed his name in my presence {}

Advocate, Chennai