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IN THE HIGH COURT OF JUDICATURE AT MADRAS (SPECIAL ORIGINAL JURISDICTION) W.P. No. of 2026 Agri S.S. Krishnamurthy, Son of S. Sundaresan, Official Whip, All India Anna Dravida Munnetra Kazhagam (AIADMK), MGR Maaligai, No.226, Avvai Shanmugham Salai, Royapettah, Chennai – 600 014 … Petitioner versus 1. The Secretary, Tamil Nadu Legislative Assembly, Fort St. George, Chennai – 600009. The State of Tamil Nadu, Rep. by its Chief Secretary, Secretariat, Chennai – 600009. 2. State of Tamilnadu, Represented by its Chief Secreatry, Secretariat, Fort St. George, Chennai – 600009. 3. Union of India, Rep. by Secretary, Ministry of Jal Shakti, New Delhi. …Respondents AFFIDAVIT OF AGRI S.S. KRISHNAMURTHY I, Agri S.S. Krishnamurthy, son of S. Sundaresan, aged about 66 years, Official Whip of the All India Anna Dravida Munnetra Kazhagam (“AIADMK”), having office at MGR Maaligai, No. 226, Avvai Shanmugham Salai, Royapettah, Chennai – 600 014, do hereby solemnly and sincerely affirm and state

by Sekar Reporter · July 30, 2026

IN THE HIGH COURT OF JUDICATURE AT MADRAS
(SPECIAL ORIGINAL JURISDICTION)

W.P. No. of 2026

Agri S.S. Krishnamurthy,
Son of S. Sundaresan,
Official Whip, All India Anna Dravida Munnetra Kazhagam (AIADMK), MGR Maaligai, No.226,
Avvai Shanmugham Salai,
Royapettah, Chennai – 600 014
… Petitioner

versus

1. The Secretary, Tamil Nadu Legislative Assembly,
Fort St. George, Chennai – 600009.
The State of Tamil Nadu,
Rep. by its Chief Secretary,
Secretariat, Chennai – 600009.

2. State of Tamilnadu,
Represented by its Chief Secreatry,
Secretariat,
Fort St. George, Chennai – 600009.

3. Union of India,
Rep. by Secretary, Ministry of Jal Shakti,
New Delhi.
…Respondents

AFFIDAVIT OF AGRI S.S. KRISHNAMURTHY

I, Agri S.S. Krishnamurthy, son of S. Sundaresan, aged about 66 years, Official Whip of the All India Anna Dravida Munnetra Kazhagam (“AIADMK”), having office at MGR Maaligai, No. 226, Avvai Shanmugham Salai, Royapettah, Chennai – 600 014, do hereby solemnly and sincerely affirm and state as follows:
1. I am the Petitioner in the above Writ Petition and as such I am well acquainted with the facts and circumstances of this case. I am competent to swear to this affidavit.
2. I am the duly appointed Official Whip of the All India Anna Dravida Munnetra Kazhagam and I am swearing to this affidavit in my capacity as such Whip. I am an elected Member of the Legislative Assembly representing No. 65, Kalasapakkam Constituency in Tiruvannamalai District. I completed my Bachelor of Law degree from Madras Law College. I have successfully contested elections to the Legislative Assembly on several occasions and have discharged my duties as a Minister, having held various portfolios in the past. Owing to my background in agriculture and my roots in an agriculturist family, I am fondly known by the nickname “Agri.”
3. I further submit that I was present during the proceedings relating to the Government Resolution concerning the Mekedatu Dam Project and am personally aware of the events that transpired on the floor of the House. The present challenge is also founded upon the objections raised by various political parties, including members of the AIADMK Legislature Party, regarding the procedure adopted for incorporation of the additional clause seeking constitution of a fresh Tribunal under Section 4 of the Inter-State River Water Disputes Act, 1956. The said clause did not form part of the Government Resolution originally circulated to the Members of the House. Further, no amendment incorporating the said clause was formally moved, seconded, debated or put to vote in accordance with the Rules governing the proceedings of the Tamil Nadu Legislative Assembly. In the absence of compliance with the prescribed procedure, the subsequent recording, authentication and communication of the amended Resolution to the Union Government as having been passed by the House constitutes the principal cause of action for the present writ petition.
4. The challenge in the present writ petition is not to the Assembly’s decision to oppose the Mekedatu Dam Project, but to the legality of the amended resolution that was subsequently published and communicated to the Union Government. The Government Resolution circulated to Members on 18.06.2026 did not contain the demand for constitution of a fresh Tribunal under Section 4 of the Inter-State River Water Disputes Act, 1956, whereas the final resolution published as passed on 19.06.2026 contained such an additional paragraph. The complaint is that the said amendment was never separately moved, seconded, debated or put to vote in accordance with Rule 104 of the Tamil Nadu Legislative Assembly Rules and despite objections raised by members of AIADMK, PMK and CPI, the amended resolution was recorded and communicated as having been passed unanimously. The grievance, therefore, is not a mere procedural irregularity within the House protected by Article 212 of the Constitution of India, but that a resolution materially different from the one debated by the Assembly was represented to external Constitutional Authorities as the unanimous decision of the Tamil Nadu Legislative Assembly, thereby necessitating judicial intervention to preserve the authenticity of legislative records and prevent constitutional authorities from acting upon a resolution allegedly not validly approved by the House. It is the subsequent authentication, publication and communication to external constitutional authorities of a materially altered Resolution allegedly not adopted in accordance with the Rules of Procedure.

I. FACTS OF THE CASE THAT ARE GERMANE AND NECESSARY FOR ADJUDICATION OF THE PRESENT PETITION ARE AS UNDER:
5. On 18.06.2026, the Tamil Nadu Legislative Assembly Secretariat circulated the List of Business and Government Resolution relating to the proposed Mekedatu Dam Project.

6. The agenda specifically recorded that the Government Resolution would be moved by the Hon’ble Chief Minister.
7. The text circulated to Members objected to the Mekedatu Dam Project and urged the Union Government and Central Water Commission not to grant approvals. The circulated resolution did not contain any demand for constitution of a fresh Tribunal under Section 4 of the Inter-State River Water Disputes Act, 1956.

8. Post the moving of the Government Resolution, and in accordance with the established practice, convention and Rules governing the proceedings of the Tamil Nadu Legislative Assembly, members belonging to various political parties participated in the debate on the Resolution as originally circulated and placed before the House. The Resolution so moved did not contain any proposal seeking constitution of a fresh Tribunal under Section 4 of the Inter-State River Water Disputes Act, 1956. The debate conducted by the members was therefore confined to the terms of the original Government Resolution circulated to the House. It was only during the course of the deliberations that the Hon’ble Leader of Opposition pointed out that he had, by a notice addressed to the speaker has given an amendment for inclusion in the resolution before the house regarding demand for constitution of a fresh/ Separate Tribunal. The records further disclose that the Hon’ble Speaker subsequently observed that the said amendment had been accepted. Thus, the additional Tribunal clause did not form part of the Resolution originally moved before the House but came to be introduced only during the course of the debate and was thereafter treated as having been accepted and incorporated into the Resolution.
9. The final resolution subsequently issued by the Assembly Secretariat contained an entirely new paragraph demanding constitution of a fresh Tribunal under Section 4 of the Inter-State River Water Disputes Act, 1956.
10. No separate motion on the amendment was moved by the Leader of Opposition. No seconder was recorded. No separate debate on the amendment was conducted. No vote was taken on the amendment before its incorporation into the main motion.
11. The Leader of the AIADMK Party, Mr.Edappadi K Palanisami, subsequently objected in the Assembly that Rule 104 required the amendment to be moved, debated and voted upon before incorporation into the Resolution.
12. Members belonging to CPI and PMK also expressed objection to the amendment and stated that a fresh Tribunal was unnecessary and potentially detrimental to Tamil Nadu’s existing legal position before the Supreme Court and Cauvery Water Management Authority. Despite such objections recorded during the proceedings, the amended Resolution came to be published and communicated as having been unanimously passed by the House
13. The challenge to the impugned Resolution is, inter alia, on the ground that the Government Resolution circulated to all Members of the Tamil Nadu Legislative Assembly on 18.06.2026 did not contain any clause seeking constitution of a fresh Tribunal under Section 4 of the Inter-State River Water Disputes Act, 1956. The said demand came to be introduced only subsequently during the course of proceedings and was accepted while the Chief Minister was replying to the debate, purportedly on the basis of a suggestion made by the Leader of Opposition. The records of the Assembly disclose that the amendment procedure prescribed under Rule 104 of the Tamil Nadu Legislative Assembly Rules was not followed inasmuch as the proposed amendment was neither formally moved, nor seconded, separately debated or put to vote before its incorporation into the main Resolution. Consequently, the petitioner contends that only the original Government Resolution circulated on 18.06.2026 can be treated as having been validly adopted by the House and not the modified Resolution subsequently recorded and communicated as passed. The present writ petition therefore raises substantial questions as to whether the alleged amendment was processed in accordance with Rule 104 of the Assembly Rules, whether the official records ought to have expressly reflected that the additional paragraph relating to constitution of a fresh Tribunal originated from an Opposition proposal, and whether the procedure adopted by the Chair in incorporating such addition departed from the Rules and established legislative practice governing amendments to resolutions.
14. The petitioner submits that he has no efficacious or alternative statutory remedy against the impugned action. The grievance does not pertain merely to an internal debate of the Legislative Assembly but concerns the publication, authentication and communication to the Union Government of a Resolution allegedly different from the one validly considered and adopted by the House. The impugned Resolution has already been acted upon and projected outside the Legislature as the unanimous decision of the Tamil Nadu Legislative Assembly, thereby producing consequences beyond the precincts of the House. There exists no statutory appellate, revisional or corrective mechanism by which the petitioner can seek examination of the legality of such communication or secure correction of the official legislative record. The issues raised involve constitutional and public law questions relating to compliance with mandatory legislative procedure, the authenticity of a Resolution communicated to constitutional authorities, and the limits of protection available under Article 212 of the Constitution. In these circumstances, and in the absence of any equally efficacious remedy, the petitioner is constrained to invoke the extraordinary jurisdiction of this Hon’ble Court under Article 226 of the Constitution of India for appropriate judicial review and consequential reliefs.
II. FACTS DEMONSTRATING THE NATURE OF THE RESOLUTION AND SUBSEQUENT AMENDMENT
15. The records placed before this Hon’ble Court unequivocally establish that the Mekedatu issue was introduced and taken up in the Tamil Nadu Legislative Assembly as a Government Resolution and not as a Resolution moved by the Leader of Opposition. The List of Business dated 19.06.2026 specifically records under Item No. 5 that the Government Resolution concerning the Mekedatu Dam Project was to be moved by the Hon’ble Chief Minister. The proceedings further show that under Item No. 4, the House resolved to postpone discussion on the Motion of Thanks to the Governor’s Address and take up the Government Resolution for discussion. The text circulated to Members prior to the sitting contained the original version of the Government Resolution.
16. It is further respectfully submitted that the Resolution ultimately published as having been passed by the House materially differed from the Resolution originally circulated to Members. The final Resolution contains an additional paragraph requesting the Union Government to constitute a fresh Tribunal under Section 4 of the Inter-State River Water Disputes Act, 1956, a clause which did not form part of the original text circulated to Members before commencement of the debate. The final record also states that the Resolution, as amended, was passed unanimously by the Assembly on 19.06.2026.
17. The Assembly proceedings relied upon by the respondents themselves make it clear that the Hon’ble Chief Minister moved the Government Resolution and that the Leader of Opposition did not move the Resolution. On the contrary, the Speaker expressly recorded that the Leader of Opposition had only submitted an amendment and that such amendment was accepted and incorporated into the Resolution. The Speaker further stated that the Resolution was thereafter proceeded with incorporating the said amendment. Thus, even according to the Assembly proceedings, the Leader of Opposition was only the proposer of an amendment and not the mover of the Mekedatu Resolution itself.
18. The Leader of the Opposition subsequently objected on the floor of the House that the text circulated to Members on 18.06.2026 did not contain the additional Tribunal clause and that if the amendment was to be adopted, the procedure prescribed under Rule 104 required the amendment to be formally moved, seconded, debated and put to vote before its incorporation into the principal Resolution. The objection was specifically directed against the procedure by which the amendment came to be incorporated into the Resolution.
19. Accordingly, the documents on record do not support any conclusion that the Leader of Opposition moved the Mekedatu Resolution. The records consistently disclose that (i) the Mekedatu Resolution was a Government Resolution moved by the Hon’ble Chief Minister, (ii) the Leader of Opposition proposed an amendment, (iii) such amendment was accepted by the Chair and incorporated into the Resolution, and (iv) the amended Resolution was thereafter recorded as having been unanimously passed.
20. It is this sequence of events that gives rise to the controversy in the present writ petition. The petitioner’s grievance is that the Resolution ultimately authenticated and communicated as the decision of the Tamil Nadu Legislative Assembly does not faithfully reflect the procedure contemplated by the Assembly Rules for consideration of amendments and further records unanimity despite contemporaneous objections regarding the amendment and the procedure adopted for its incorporation. The issues that therefore arise for consideration are whether the amendment was processed in accordance with Rule 104 of the Tamil Nadu Legislative Assembly Rules, whether the official records ought to have clearly reflected that the additional Tribunal paragraph originated from an Opposition amendment, and whether the Resolution subsequently communicated to the Union Government could lawfully be treated as the unanimous decision of the House

III. GROUNDS OF CHALLENGE

A. VIOLATION OF PRINCIPLES OF NATURAL JUSTICE, ARBITRARINESS AND PROCEDURAL IMPROPRIETY
Because the impugned action is vitiated by violation of the principles of natural justice, arbitrariness and non-adherence to the prescribed procedure. The Resolution circulated to the Members of the Legislative Assembly on 18.06.2026 did not contain the additional clause seeking constitution of a fresh Tribunal, yet the final Resolution published and communicated as having been passed by the House contained a substantial additional paragraph introducing a new and significant policy position. Members who had participated in the debate on the basis of the circulated Resolution were not afforded an effective opportunity to consider, debate, support or oppose the additional proposal in accordance with the prescribed Rules. The Assembly records further disclose objections from members regarding the manner in which the additional clause was incorporated and the absence of a separate consideration of the same. The action of incorporating a substantive amendment without following the established procedure governing amendments to resolutions is arbitrary, unfair and contrary to the requirements of transparency and orderly legislative functioning. The decision-making process, being as important as the decision itself, must conform to the Rules and to the minimum standards of procedural fairness. Any departure therefrom renders the resulting action vulnerable to judicial review.
B. MANIFEST ARBITRARINESS
Because the impugned Resolution, insofar as it incorporates the additional Tribunal clause and records the same as having been unanimously adopted, is manifestly arbitrary. The contemporaneous proceedings disclose reservations and objections expressed by members belonging to different political parties regarding both the substance of the additional proposal and the manner of its incorporation. Despite such objections, the final Resolution was recorded and communicated as a unanimous Resolution of the House, thereby creating an impression that there existed complete unanimity on the amended text. Such action is arbitrary, unreasonable and liable to be interfered with under Article 226 of the Constitution.
C. PROCEDURAL ILLEGALITY APPARENT ON THE FACE OF THE RECORD
Because the impugned action suffers from procedural illegality apparent on the face of the record. From the Assembly proceedings themselves, it is evident that the Resolution originally circulated was materially different from the Resolution ultimately notified as passed. The records further raise a substantial question as to whether the procedure contemplated for consideration of amendments under Rule 104 was followed before the additional clause was incorporated into the Resolution. The legality of the process adopted is therefore a justiciable issue, particularly when the resultant Resolution has been authenticated and communicated to authorities outside the Legislature.
D. FAIRNESS IN PUBLIC DECISION MAKING
Because every public authority, including constitutional functionaries acting under statutory or procedural rules, is required to act fairly, transparently and in accordance with the procedure established for the exercise of power. Where a Resolution having constitutional and inter-State ramifications is altered and communicated in a form different from that originally placed before members, without demonstrable compliance with the procedure governing amendments, the resultant action becomes vulnerable on the ground of procedural unfairness and failure to adhere to established norms governing public decision making.
E. VIOLATION OF LEGISLATIVE RULES
Because the amendment was incorporated without complying with the mandatory procedure governing amendments to resolutions under the Tamil Nadu Legislative Assembly Rules. The amendment was neither separately moved nor voted upon before inclusion in the original Government Resolution.
F. RESOLUTION DIFFERENT FROM THE ONE CIRCULATED
Because the text circulated to Members on 18.06.2026 was materially different from the resolution ultimately published as adopted. Members debated a resolution that did not contain the fresh-Tribunal clause. The final resolution communicated to the Union Government contained that additional clause.
G. FAILURE OF NATURAL JUSTICE WITHIN HOUSE PROCEEDINGS
Members opposing the amendment were not afforded an opportunity to debate the amendment before incorporation. CPI and PMK members subsequently stated that the amendment ought not to have been approved without discussion.
H. EXERCISE OF POWER CONTRARY TO RULES
The Speaker’s power to regulate proceedings must be exercised in accordance with the Rules of Procedure and established conventions. A resolution materially altered without following the prescribed amendment procedure lacks procedural legitimacy.
I. ARTICLE 212 DOES NOT BAR JUDICIAL REVIEW OF CONSTITUTIONAL ILLEGALITIES
Though legislative proceedings generally enjoy protection under Article 212 of the Constitution of India, judicial review survives where the challenge concerns substantive illegality, jurisdictional error, constitutional violation or action contrary to mandatory provisions governing legislative functioning.
21. The present challenge is not directed against a mere procedural irregularity but against publication and communication of a resolution that was never validly adopted by the House in accordance with the Rules.
22. The Petitioner respectfully submits that the Assembly records, as presently maintained and relied upon, contain material inaccuracies regarding the manner in which the Mekedatu Resolution was considered and adopted. In particular, if the records are construed as reflecting that the Leader of Opposition moved the Mekedatu Resolution itself, such recording is contrary to the agenda and proceedings, which disclose that the Resolution was a Government Resolution moved by the Hon’ble Chief Minister and that the Leader of Opposition had only suggested an amendment thereto. The Petitioner submits that the primary relief sought is correction and rectification of the Assembly record through the competent authorities of the Legislature, including the Hon’ble Speaker and the Assembly Secretariat. However, since the impugned Resolution, as recorded and authenticated, has already been published and communicated to the Union Government as the official decision of the Tamil Nadu Legislative Assembly, the matter has transcended the realm of purely internal legislative proceedings. The present challenge is therefore not directed merely at the accuracy of internal proceedings, but at the continuing public and constitutional consequences flowing from an allegedly incorrect and procedurally defective legislative record. In the absence of any effective mechanism to secure correction of such record and its external communication, the Petitioner is constrained to invoke the extraordinary jurisdiction of this Hon’ble Court under Article 226 of the Constitution of India.
IV. MAINTAINABILITY OF THE WRIT PETITION AND LIMITED SCOPE OF ARTICLE 212 OF THE CONSTITUTION OF INDIA
A. ARTICLE 212 DOES NOT CREATE AN ABSOLUTE BAR
The respondents may contend that the present writ petition is barred by Article 212 of the Constitution of India. Such a contention is misconceived. Article 212 protects legislative proceedings from challenge on the ground of a mere “irregularity of procedure”. It was never intended to confer absolute immunity upon actions which are ex facie unconstitutional, without jurisdiction, contrary to mandatory statutory rules, or which misrepresent the actual decision of the House. The constitutional protection under Article 212 extends only to bona fide internal proceedings of the Legislature. It does not authorize any authority to attribute to the House a decision which the House never in fact took, nor does it protect actions which have the effect of falsifying or materially misrepresenting the will of the Legislature.
B. PRESENT CHALLENGE IS NOT BASED ON A MERE PROCEDURAL IRREGULARITY
The petitioner is not inviting this Hon’ble Court to review legislative debates, voting patterns, political positions or matters lying exclusively within the internal domain of the Legislature. The challenge is confined to the legality of the subsequent authentication, publication and communication of a Resolution allegedly differing from the Resolution validly considered by the House. The challenge is founded on the narrower and more fundamental issue that:
a) the resolution circulated to Members on 18.06.2026 was materially different from the resolution subsequently communicated as passed;
b) the additional paragraph relating to constitution of a fresh Tribunal was never separately moved, debated and voted upon in accordance with Rule 104;
c) several members belonging to different political parties expressly objected to such amendment and opposed the proposal for a fresh Tribunal;
d) despite such opposition, the published resolution records the matter as having been unanimously passed.
Therefore, the grievance is not one of procedural irregularity alone but concerns the authenticity, legality and constitutional validity of the resolution communicated to external constitutional authorities.
C. JUDICIAL REVIEW SURVIVES WHERE THERE IS CONSTITUTIONAL ILLEGALITY
It is settled that legislative action is not completely immune from judicial review where the complaint pertains to constitutional illegality, jurisdictional error, mala fides or patent illegality. The present petition falls within that limited jurisdiction because the petitioner seeks judicial scrutiny of the act of representing an amended resolution as the unanimous decision of the Assembly when the materials on record demonstrate that objections were raised to the amendment itself.
V. NECESSITY FOR INTERVENTION OF THIS HON’BLE COURT
A. RESOLUTION HAS ALREADY BEEN COMMUNICATED OUTSIDE THE HOUSE
The controversy has travelled beyond the four walls of the Legislative Assembly. The impugned amended resolution was not retained merely as an internal legislative record. It was published, authenticated and communicated to the Union Government as the official decision of the Tamil Nadu Legislative Assembly. Once such communication was made to constitutional and statutory authorities outside the Legislature, the consequences ceased to be purely internal legislative matters.
B. FALSE IMPRESSION OF UNANIMOUS SUPPORT
The official resolution records that the amended resolution was passed unanimously. However, the Assembly records themselves reveal objections to the amendment concerning constitution of a fresh Tribunal:
a) AIADMK objected to the procedure and disputed incorporation of the amendment.
b) PMK expressly opposed the amendment and demanded its withdrawal.
c) CPI stated that the amendment ought not to have been accepted without discussion and reiterated opposition to creation of a fresh Tribunal.
Thus, the assertion that the amended Resolution enjoyed unanimous support appears inconsistent with the objections and reservations recorded during the contemporaneous proceedings of the House.
C. POTENTIAL PREJUDICE BEFORE THE UNION GOVERNMENT
The additional paragraph seeks constitution of a fresh Tribunal under Section 4 of the Inter-State River Water Disputes Act, 1956. The Union Government may legitimately proceed on the basis that the Tamil Nadu Legislative Assembly unanimously demanded such a course of action. If the communication remains uncorrected, the Union Government may be misled into believing that all parties represented in the Tamil Nadu Legislative Assembly support the proposal for a new Tribunal, whereas the Assembly proceedings disclose significant reservations and opposition from multiple parties.
D. CONSTITUTIONAL SIGNIFICANCE OF THE CAUVERY DISPUTE
The Mekedatu issue concerns inter-State river waters, implementation of the Cauvery Tribunal Award and the judgment of the Hon’ble Supreme Court. Questions relating to constitution of a fresh Tribunal have serious legal and constitutional ramifications. Several members specifically expressed concern that such a proposal could adversely affect the existing legal position secured by Tamil Nadu before the Cauvery Water Management Authority and the Supreme Court. Therefore, accuracy in the communication of the Assembly’s decision is not a matter of political formality but one having direct constitutional consequences.
VI. NO DELAY OR LACHES
I respectfully submits that the present Writ Petition has been instituted with utmost diligence and without any delay. The cause for approaching this Hon’ble Court arose only upon becoming aware that the amended Resolution, containing the additional clause relating to constitution of a fresh Tribunal, had not merely been recorded in the Assembly proceedings but had also been authenticated and communicated to the Union Government as the official and unanimous decision of the Tamil Nadu Legislative Assembly. Immediately upon becoming aware of such external communication and the consequential implications arising therefrom, I have approached this Hon’ble Court. The Petition is therefore bona fide, prompt and filed at the earliest available opportunity. There is neither delay nor laches attributable to me and no prejudice whatsoever is caused to the Respondents by the institution of these proceedings.
VII. NO EFFICACIOUS ALTERNATIVE REMEDY
I respectfully submits that there exists no efficacious, adequate or alternative remedy available in law. The challenge in the present proceedings concerns the legality of the Resolution ultimately authenticated, recorded and communicated as the decision of the Tamil Nadu Legislative Assembly and the constitutional consequences flowing therefrom. The grievance extends beyond the internal proceedings of the House and relates to the authenticity and validity of a Resolution communicated to constitutional and statutory authorities outside the Legislature. There is no statutory appeal, revision, review or other remedial mechanism by which I could seek correction of the impugned communication or obtain adjudication of the questions raised herein. The issues involved concern constitutional governance, compliance with mandatory procedural requirements and the legality of official action having public law consequences. In such circumstances, the extraordinary jurisdiction of this Hon’ble Court under Article 226 of the Constitution of India constitutes the only effective and efficacious remedy available to me.
VIII. NO OTHER PROCEEDINGS DECLARATION
I respectfully state that, to the best of his knowledge, information and belief, no other writ petition, proceeding, appeal or application seeking substantially the same relief as prayed for in the present Writ Petition has been filed by me or is pending before this Hon’ble Court, the Hon’ble Supreme Court of India, or before any other Court, Tribunal or Authority. The present Writ Petition is therefore the sole proceeding instituted by me for adjudication of the issues raised herein.
IX. PLEADINGS FOR DISPENSING WITH PRODUCTION OF IMPUGNED RESOLUTION.
I respectfully submits that I am seeking for dispensing with production of the original copy of the impugned Resolution at this stage. There is no dispute regarding the contents of the Resolution communicated to the Union Government, particularly the inclusion of the additional paragraph relating to constitution of a fresh Tribunal under Section 4 of the Inter-State River Water Disputes Act, 1956. The present cause of action arose immediately upon me becoming aware that the amended Resolution had been authenticated and communicated to Government of India as the official decision of the Tamil Nadu Legislative Assembly passed unanimously. Thus I have approached this Hon’ble Court with utmost expedition and without any delay. Despite diligent efforts, I am not been able to obtain an authenticated copy of the communication and the Resolution forwarded to the Union Government. Having regard to the urgency of the matter, the continuing constitutional consequences flowing from the said communication and the fact that the existence and contents of the impugned amendment are not in dispute, I respectfully prays that this Hon’ble Court may be pleased to dispense with the production of the impugned Resolution at the time of filing and permit me to produce the same, if necessary, upon receipt of the records from the Respondents.
X. CIRCUMSTANCES IN FAVOUR OF GRANT OF INTERIM RELIEF
I respectfully submits that a strong prima facie case exists in favour of grant of interim protection. The central issue in the present writ petition is whether the additional paragraph relating to constitution of a fresh Tribunal under Section 4 of the Inter-State River Water Disputes Act, 1956 was validly incorporated into the Resolution and thereafter communicated to the Union Government as the decision of the Tamil Nadu Legislative Assembly. Pending adjudication of this issue, any reliance upon the impugned amended portion of the Resolution may give rise to irreversible constitutional and administrative consequences and may create an impression before the Union Government that the said proposal enjoys the considered and unanimous approval of the House. The balance of convenience is overwhelmingly in favour of preserving the status quo, as no prejudice would be caused to the Respondents if reliance upon the disputed amendment is temporarily deferred pending disposal of the writ petition. On the other hand, if action is taken on the basis of the impugned amendment during the pendency of these proceedings, the very purpose of the writ petition may be rendered nugatory. It is therefore just, necessary and expedient that this Hon’ble Court direct that no reliance shall be placed upon, and no action shall be taken on the basis of, the amended portion of the Resolution relating to constitution of a fresh Tribunal under Section 4 of the Inter-State River Water Disputes Act, 1956, pending disposal of the present writ petition.
XI. INTERIM PRAYER
It is therefore in the interest of justice necessary and prayed that this Hon’ble Court may be pleased to:
a) permit dispense with the production of the impugned Assembly Resolution dated 19.06.2026 concerning the Mekedatu Dam issue at the time of filing of the writ petition and permit me to produce the same, if necessary, upon receipt of the records from the Respondents and
b) Pending disposal of the writ petition, this Hon’ble Court may be pleased to direct that no reliance shall be placed by Respondents on the amended portion of the resolution relating to constitution of a fresh Tribunal under Section 4 of the Inter-State River Water Disputes Act, 1956 and thus render justice.
XII. PRAYER
In the above circumstances, it is therefore prayed that this Hon’ble Court may be pleased to issue a Writ of Certiorarified Mandamus calling for the records relating to the Assembly Resolution communicated as having been passed on 19.06.2026 concerning the Mekedatu Dam issue and quash the portion inserted relating to constitution of a fresh Tribunal under Section 4 of the Inter-State River Water Disputes Act, 1956; and/or thereby declare that only the Government Resolution circulated to Members of the Legislative Assembly on 18.06.2026 can be treated as having been validly adopted by the Assembly; and thereby direct the First Respondent to withdraw the amended communication sent to the Union Government and substitute the original resolution circulated on 18.06.2026 and pass such further or other orders as this Hon’ble Court may deem fit and proper in the circumstances of the case.
Solemnly affirmed at Madras
this the day of July, 2026
and signed his name in my
presence Before me,