IN THE HIGH COURT OF JUDICATURE AT MADRAS (Special Original Jurisdiction) W.P.No. of 2026 Dravidar Kazhagam, Rep by its Vice President, Kali.Poongundran, Male/aged 87 years, Having office at 84/1, Periyar Thidal, EVK Sampath Salai, Vepery, Chennai – 600 007. ….Petitioner. -Vs- 1. The Director General of Police, O/o. the Director General of Police, Dr.Radhakrishnan Salai, Mylapore, Chennai – 600 004. 2. The Commissioner of Police, O/o.the Commissioner of Police, Vepery, Chennai. 3. The Commissioner of Police, O/o.the Commissioner of Police, Tiruppur – District. 4. The Superintendent of Police, O/o.the Superintendent

W.P.No. of 2026
Dravidar Kazhagam,
Rep by its Vice President,
Kali.Poongundran, Male/aged 87 years,
Having office at
84/1, Periyar Thidal, EVK Sampath Salai,
Vepery, Chennai – 600 007. ….Petitioner.
-Vs-

1. The Director General of Police,
O/o. the Director General of Police, Dr.Radhakrishnan Salai, Mylapore, Chennai – 600 004.

2. The Commissioner of Police, O/o.the Commissioner of Police, Vepery, Chennai.

3. The Commissioner of Police, O/o.the Commissioner of Police, Tiruppur – District.

4. The Superintendent of Police, O/o.the Superintendent of Police, Villupuram – District.

5. The Superintendent of Police, O/o.the Superintendent of Police, Thiruvarur – District.

6. The Superintendent of Police, O/o.the Superintendent of Police, Thiruvannamalai – District.

7. The Superintendent of Police, O/o.the Superintendent of Police, Tenkasi – District.
8. The Inspector of Police,
G-1, Vepery Policer Station, Law & Order, Vepery, Chennai.

9. The Inspector of Police,
R-8, Vadapalani Police Station, Law & order, Chennai.

10. The Inspector of Police,
Arani Town Police Station, Arani – Taluk,
Thiruvannamalai – District.

11.The Inspector Police, Town Police Station,
Thiruvannamalai – Post & District.

12. The Inspector of Police, Kalambur Police Station, Thiruvannamalai – District.

13. The Inspsctor of Police, Polur Police Station, Thiruvannamalai – Distric.

14. The Inspector of Police, Tindivanam Police Police, Villupuram – District.

15. The Inspector of Police, Vellore Law & Order Police Station, Vellore – District.

16.The Inspector of Police, Gudiyatham Town Police Station, Vellore – District.

17. The Inspector of Police,
Thalaiyamangalam Police Station, Mannargudi – Taluk,
Thiruvarur – District.

18. The Inspector of Police,
Tenkasi Town Police Station,
Tenkasi – District. …Respondents.
AFFIDAVIT OF THE PETITIONER
I, Kali.Poongundran son of Kandasamy aged about 87 years, Vice President of Dravidar Kazhagam having office at 84/1, Periyar Thidal, EVK Sampath Salai, Vepery, Chennai – 600 007 hereby solemnly affirm and sincerely state as follows:-
I am the petitioner herein and I am well acquainted with the facts of the case.
1. I submit that I am filing this writ petition to issue a writ of Certiorarified Mandamus to call for the records relating to the order made in Na.Ka.No.14909650/Public 2(2)/2026 on the file of the Director General of Police/1st respondent dated 27.07.2026 and quash the same along with all the consequential order issued by the respondents No.8 to 18 and further direct the respondents to grant permission to conduct two wheeler propaganda against the NEET and EWS in the State of Tamil Nadu for the reasons setout hereunder.
2. I submit that the Dravidar Kazhagam is founded by Thathai Periyar. The Dravidar Kazhagam is a Non-Political, Socio- Cultural, Secular Movement, a multi-focal organisation. It persuade the people of all sections and the government to render justice to different communities. It is a non-political organisation without violence to create awareness to bring about deep-rooted social transformation.
3. I submit that the Dravidar Kazhagam is stands for the establishment of casteless, classless, egalitarian, new social and economic order. Securing all men and women equal status, equality of opportunities and rights in all spheres of human activity. Fighting against all kinds of birth-based discrimination among humans on the basis of race, ethnicity, caste, religion, colour or nationality etc. and striving to eradicate ignorance and supersititions that breed prejudices, fears and animosities, which give rise to violence and conflicts and also stressing the need for state’s obligations and to develope scientific temper, Rational Humanism and the spirit of inquiry and freedom. For achieving social and gender justice as an integral action plan. Consistently advocating the policy that disadvantaged or deprived sections should be given reservation in education and job opportunities: affirmative action is its weapon to uplift depressed and downtrodden sections.
4. I submit that one of the policies of the Dravidar Kazhagam is to educate and create awareness among people through conferences and meetings. The Medical Council of India (presently National Medical Commission) initiated steps to implement of national wide common entrance examination for admission to the medical course in the year 2010. The entrance examination is not a method to scale the skill of the students and also the proposal made by the Medical Council of India was against the social justice, snatching the opportunities of the socially backward and rural students. Also, it taken away the educational rights of the State of Tamil Nadu and also improve the growth of coaching centres. The entrance examination affected the mental health and spoiled the students’ future. Now a days, the NEET entrance examination became a symbol of scam, paper leaks and re-examination.
5. I submit that the Dravidar Kazhagam conducted demonstration against the National Eligibility cum Entrance Examination all over the state of Tamil Nadu on 29.12.2010. Subsequently, the party conducted demonstration in the District Headquarters against the National Eligibility cum Entrance Examination on 22.10.2015. Thereafter, the Dravidar Manavar Kazhagam conducted demonstration near the District Collectorate of Chennai on 07.05.2016.
6. I submit that the Dravidar Kazhagam conducted the conference relating to the abolition of National Eligibility cum
Entrance Examination at Arakkonam on 19.11.2016. Subsequently, on the very next year, the Dravidar Kazhagam conducted triangle conference including students, parents and teachers at Trichy on 19.12.2016. Consequently, the Dravidar Kazhagam conducted demonstration against the National Eligibility cum Entrance Examination including students, teachers and parents on 30.12.2016.
7. I submit that all over the State of Tamil Nadu, the Dravidar Manavar Kazhagam conducted two wheeler propaganda from
18.03.2017 to 21.03.2017 and conducted human chain propaganda on 20.07.2017. Thereafter, all the student movement conducted the candle light protest in the Periyar Thidal on 26.07.2017. All of sudden, a meritorious student namely Anitha lost her life due to NEET in the State of Tamil Nadu on 01.09.2017 and became an icon of Anti NEET protest.
8. I submit that the Dravidar Kazhagam conducted remembrance of Anitha at Priyar Thidal on 28.09.2017. Subsequently, the Dravidar Kazhagam conducted demonstration and seminar against the National Eligibility cum Entrance Examination at Delhi on 03.04.2018. Thereafter, all over the State of Tamil Nadu the Dravidar Kazhagam conducted demonstration against NEET at the District Head Quarters on 15.06.2019.
9. I submit that President of Dravidar Kazhagam
Dr.K.Veeramani Propagate against the National Eligibility cum Entrance Examination for 2,700 K.M. in the State of Tamil Nadu from 20.01.2020 to 30.01.2020. Thereafter, Dravidar Manavar Kazhagam demanded abolition of NEET and implementation of reservation in the private section by way of protest on 15.07.2020. The continuous propaganda was conducted by the Dravidar Kazhagam under head of party President Dr.K.Veeramani against the NEET and National Educational Policy from Nagarkovil to Chennai inbetween 03.04.2022 and 25.04.2022.
10. I submit that the Dravidar Kazhaga Ilangnarani and Dravidar Manavar Kazhagam conducted anti NEET protest all over the State of Tamil Nadu on 22.08.2023. Subsequently, the Dravidar Manavar Kazhagam conducted protest against NEET by organising all the party leaders at Chennai on 18.06.2024. The two wheeler propaganda against the NEET was conducted by the Dravidar Kazhaga Ilangnarani and Dravidar Manavar Kazhagam from 11.07.2024 to 15.07.2024 in the State of Tamil Nadu. Subsequently, the NEET is introduced to paramedical course. Hence, the Dravidar Manavar Kazhagam condemned such implementation and staged protest in the State of Tamil Nadu on 31.01.2026.
11. I submit that the NEET was cancelled due to scam and paper leak all over the India. Hence, the Dravidar Kazhagam demanded the Union Government by way of demonstration for abolition of NEET all over the State of Tamil Nadu on 16.05.2026. The Government of Tamil Nadu endorse the views and feeling of the people and students of the State of Tamil Nadu passed resolution to exempt the State of Tamil Nadu from NEET. In such situation, the Dravidar Kazhagam decided to propagate against NEET and introduction of Economic Weaker Section quota for the welfare of students and the people of the State of Tamil Nadu and need of abolition of NEET by way of Two Wheeler program from 30.07.2026 to 02.08.2026.
12. I submit that the said propaganda is planned to all over the State of Tamil Nadu. Hence, I made a representation along with schedule to the 1st respondent/Director General of Police on 18.07.2026 for grant of general permission and give direction to the respected Commissioner of Police and Superintendent for protection. The 1st respondent/Director General of Police forwarded the same to the Additional Director General of Police. Subsequently, the Additional Director General of Police forwarded the same to the Director General of Police. Instead of granting general permission, the 1st respondent/Director General of Police directed the concern police office for permission and protection on 27.07.2026 and the same is circulated the subordinate officers. Immediately, the party cadres made a representation to the concerned police station on the very next date. But all the over the State of Tamil Nadu, the permission is denied by the respondents. The Dravidar Kazhagam propagate against the NEET from the year 2010 onwards. Hence, the order of the 1st respondent/Director General of Police, Tamil
Nadu is liable to quashed for the following among other grounds,
GROUNDS
a) The order of the respondents relating the denial of permission for conducting Propaganda in the form of two wheeler against NEET and EWS is against law.
b) The Article 19A and 19 B of the Constitution of India guarantees for speech and expression to assemble peacefully and without arms. Hence, the order of denial for propagating against the NEET and EWS is against the Constitution of India.
c) There cannot be a complete ban or prohibition to express the views of the citizens or people are assemble peaceful without arms expressing their sentiments, views bound to the particular issues. Therefore, the total prohibition is banning the program proposed by the petitioner is against the constitutional mandate.
Hence, the order of the 1st respondent and consequential order passed by the other respondents is liable to be set aside.
d) There can be a regulation have regulatory measures for complete fiction of the peaceful assembly and the expression of the views of the petitioners. Therefore, instead of regulating the procedure regulating the program completely banning are prohibiting the same is against the constitutional mandate and also violate of part III of the Constitution of India.
e) Except two plead as if there is a metro works and the time is for the students going to the school and colleges. There is no ther reason given by the respondents. The reason given vy the respondents are vague and in general and therefore, the impugned order is liable to be set aside and the petitioner may be permitted their program.
f) The petitioner conducted the very same method of program propagate against the NEET in the year 2017 and 2024. Hence, the denial of permission is not sustainable is law.
g) The other reasons assigned in the impugned order is not
sustainable is law.
h) The petitioner reserves his rights to raise additional
grounds at the time of final hearing of the case.
13. I submit that the certified order of the 1st respondent/Director General of Police dated 27.07.2026 is not available at present. The certified copy of the order is not received by the petitioner. Hence, the photo copy is filed along with this petition. The non production of certified copy of the order of the 1st respondent is neither wilful nor wanton but the reason state above. In the interest of justice, this Hon’ble Court may be pleased to dispense with the production of the certified copy of the order dated 27.07.2026.
14. I have no other effective and efficacious alternative remedy except to approach this Hon’ble Court by invoking Article 226 of the Constitution of India.
It is therefore prayed that this Hon’ble Court may be pleased to dispense with the production of the certified copy of the order made in Na.Ka.No.14909650/Public 2(2)/2026 on the file of the Director General of Police/1st respondent dated 27.07.2026 at present and pass such further or other orders as this Hon’ble court may deem fit and proper in the circumstances of this case and thus render justice.
It is therefore prayed that this Hon’ble Court may be pleased to issue a writ of Certiorarified Mandamus or any other writ or order or direction in the nature of writ to call for the records relating to the order made in Na.Ka.No.14909650/Public 2(2)/2026 on the file of the Director General of Police/1st respondent dated 27.07.2026 and quash the same along with all the consequential order issued by the respondents No.8 to 18 and further direct the respondents to grant permission to conduct two wheeler propaganda against the NEET and EWS in the State of Tamil Nadu and pass such further or other orders as this Hon’ble court may deem fit and proper in the circumstances of this case and thus render justice.

Solemnly affirmed at Chennai )( this the 31st day of July, 2026 )( BEFORE ME and read over the contents of the )( affidavit and explained to him in )(
Tamil and he understood the same. )( ADVOCATE, CHENNAI