Karur case SLP full copy cbi case bjp gs mani

IN THE SUPREME COURT OF INDIA
CRIMINAL APPELLATE JURISDICTION
SPECIAL LEAVE PETITION (CRL) No. OF 2025
(UNDER ARTICLE 136 OF THE CONSTITUTION OF INDIA READ WITH ORDER XXI, 3 (1) (a) of SUPREME COURT RULES, 2013)
(With Prayer for Interim Relief)
(Against the Common Impugned final Judgment & Order dated 03.10.2025 passed by the Madurai Bench of Madras High Court in W.P.(MD)No.27571 of 2025)

(All Parties are contesting parties)
BETWEEN
STATUS OF THE PARTIES
Before High Court Before this Court

G.S. Mani, Advocate, S/o. Late Sh. K. Ganeshan Pillai, aged about 44 Years, R/o Plot No. 1 & 2, Flat No. F1, 1st Floor, Nandhi Block, MGR Salai, Nehru Nagar, Chennai – 600 093. Petitioner

Petitioner

-AND-

1. Government of Tamil Nadu Represented by its Chief Secretary, Secretariat, Fort St. George, Chennai – 600 009.
2. The Home Secretary, Government of Tamil Nadu, Secretariat, Fort St. George, Chennai – 600 009.
3. The Director General of Police, Dr. Radhakrishnan Salai, Mylapore, Chennai – 600 004.
4. The Superintendent of Police, Karur District, Near Collector Office, Karur-639 007.
5. The Inspector of Police, Karur Town Police Station, Karur 639 007, Tamil Nadu.
6. Government of India, Represented by its Home Secretary, Ministry of Home Affairs Room No. 113, North Block, New Delhi – 110001.
7. The Director – General Central Bureau of Investigation Lodhi Road, CGO Complex, New Delhi – 110 003.
8. The Joint Director, Central Bureau of Investigation Shastri Bhavan, Haddows Road, Chennai – 600 006.
9. Thiru.Vijay Joseph Alias Vijay, S/o, S.A. Chandrasekhar, R/o, No. 64, Casuarina Drive, Neelankarai, Chennai-600 115.
10. Thiru N.Anand Alias Bussy Anand, General Secretary, TVK Party, Headquarters, 275, Seashore Town, 8th Avenue, Panaiyur, East Coast Road, Chennai – 600 119.
11. Thiru.Mathiyalagan, Karur District Secretary, TVK Party, Headquarters, 275, Seashore Town, 8th Avenue, Panaiyur, East Coast Road, Chennai – 600 119.
12. Thiru.CTR Nirmalkumar, State Joint Secretary, TVK Party. Headquarters, 275, Seashore Town, 8th Avenue, Panaiyur, East Coast Road, Chennai-600 119. Respondent No.1

 

 

Respondent No.2

 

Respondent No.3

 

Respondent No.4

Respondent No.5

Respondent No.6

 

Respondent No.7

 

Respondent No.8

 

Respondent No.9

 

 

Respondent No.10

 

 

Respondent No.11

 

 

Respondent No.12
Respondent No.1

 

 

Respondent No.2

 

Respondent No.3

 

Respondent No.4

Respondent No.5

Respondent No.6

 

Respondent No.7

 

Respondent No.8

 

Respondent No.9

 

 

Respondent No.10

 

 

Respondent No.11

 

 

Respondent No.12

All are contesting Respondents
THE HON’BLE CHIEF JUSTICE OF INDIA AND HIS COMPANION JUDGES OF THE HON’BLE SUPREME COURT OF INDIA
THE HUMBLE PETITION OF THE PETITIONER ABOVE NAMED:
MOST RESPECTFULLY SHOWETH;

1. The Petitioner has filed this Special Leave Petition against the Common Impugned final Judgment & Order dated 03.10.2025 passed by the Madurai Bench of Madras High Court in W.P.(MD)No.27571 of 2025; wherein the Division Bench has erroneously dismissed the batch of writ petitions including the aforesaid writ petition filed by him, observing that the investigation was at a nascent stage and no allegations had been raised against the State machinery or local police. The Court also declined to direct enhanced compensation, noting that the State Government had announced compensation of Rs. 10 lakhs to each victim’s family, while the political party had announced Rs. 20 lakhs.
1A. It is clarified that the present SLP is in criminal nature as the same is seeking transfer of criminal investigation.
2. QUESTIONS OF LAW:
The following questions of the law arise for consideration by this Hon’ble Court: –
2.1. Whether the Hon’ble High Court erred in law and on facts in refusing to transfer the investigation to an independent agency such as the CBI, despite serious and specific allegations of complicity, negligence and suppression of evidence by the local police and district administration?
2.2. Whether the High Court failed to appreciate that the right to a fair, impartial and independent investigation is a facet of Article 21 of the Constitution of India, and that such right stands violated when the investigating agency itself is under a cloud of suspicion?
2.3. Whether the Hon’ble High Court committed a jurisdictional error in mechanically accepting the State’s version without ordering an independent probe, contrary to settled law that when State machinery itself is alleged to be involved, investigation by an independent agency like the CBI is warranted to uphold public confidence in the criminal justice system?
2.4. Whether the High Court failed to exercise its extraordinary jurisdiction under Articles 226 and 227 of the Constitution in a case involving large-scale loss of human lives, thereby frustrating the principles of accountability and transparency expected in custodial or administrative negligence cases?
2.5. Whether the refusal to transfer investigation to the CBI in a case involving deaths of 41 innocent citizens, allegedly due to administrative lapse and deliberate power disruption during a political meeting, amounts to denial of justice and violation of the victims’ families’ fundamental rights under Articles 14 and 21?
2.6. Whether the Hon’ble High Court erred in law in disregarding binding precedents of this Hon’ble Court which have consistently held that where local police are accused or suspected of bias, fair investigation demands transfer to an independent central agency such as CBI (e.g., State of West Bengal v. Committee for Protection of Democratic Rights, (2010) 3 SCC 571; Babubhai v. State of Gujarat, (2010) 12 SCC 254)?
2.7. Whether the High Court failed to consider that a fair investigation is the foundation of fair trial and an integral part of the rule of law, and that the mere registration of FIR or constitution of a local SIT cannot substitute the independence and credibility of a central investigation?
2.8. Whether the High Court, by refusing to order a CBI probe despite prima facie material showing administrative failure and possible cover-up, acted contrary to the constitutional duty to protect life, ensure accountability, and prevent miscarriage of justice?
2.9. Whether the Hon’ble High Court erred in ignoring the plea of the petitioner that involvement of high-ranking officials, political figures, and local police made a fair and impartial investigation impossible by the same authorities?
2.10. Whether the order of the Hon’ble High Court, declining transfer of investigation, suffers from non-application of mind and violates the principles laid down by this Hon’ble Court in similar cases involving mass casualties and public tragedies?
2.11. Whether the principles of natural justice have been violated in the investigation process, given the State’s role in granting permission for the meeting and potential interference in the investigation?
2.12. Whether the High Court can direct enhanced compensation to the victims’ families in cases of this nature, where the State Government and the political party have announced compensation?
2.13. Whether the State’s role in granting permission for the meeting and potential biases in the investigation process necessitate a CBI investigation?
2.14. Whether the High Court has failed in exercising its discretion properly in dismissing the petitions seeking a CBI investigation and enhanced compensation?
2.15. Whether the integrity of the investigation has been compromised, given the potential biases and interference in the investigation process?
2.16. Whether the High Court has violated the victims’ rights to a fair and impartial investigation and adequate compensation in this case?
2.17. Whether the decisions of this Hon’ble Court in Nilabati Behera v. State of Orissa (1993) 2 SCC 746, the Hon’ble Supreme Court has held that adequate compensation for violation of Article 21 is enforceable under writ jurisdiction, support the petitioner’s contention for a CNI investigation.
3. DECLARATION IN TERMS OF RULE 3 (2)
The Petitioners states that they have not filed any other petition seeking leave to appeal against impugned final Judgment & Order dated 03.10.2025 passed by the Madurai Bench of Madras High Court in W.P.(MD)No.27571 of 2025.
4. DECLARATION IN TERMS OF RULE 5
Annexure P-1 to P-4 produced along with the SLP are true copies of the pleadings/documents that formed part of the records of the case in the court below against whose order the leave to appeal is sought for in this petition.
5. G R O U N D S

Leave to appeal is sought for on the following grounds:
5.1. Because the Hon’ble High Court gravely erred in refusing to transfer the investigation to an independent agency such as the Central Bureau of Investigation (CBI), despite the undisputed fact that the local police and district administration — against whom serious allegations of negligence, dereliction of duty, and possible complicity are made — are themselves the investigating authorities.
5.2. Because the principle of nemo judex in causa sua (no one can be a judge in his own cause) squarely applies to investigation also, and when the local police and State officials are under a cloud of suspicion, continuation of investigation by them destroys the very foundation of fairness and impartiality guaranteed under Article 21 of the Constitution of India.
5.3. Because the High Court failed to appreciate that a fair, honest and impartial investigation is an essential component of the right to life and personal liberty, and forms part of the basic structure of the Constitution. Denial of such independent investigation amounts to denial of justice to the victims and their families.
5.4. Because the Hon’ble High Court erred in not appreciating that the Karur stampede, which resulted in the tragic death of 41 innocent people including women and children, occurred during a public meeting organized by a political party led by a prominent actor-turned-politician, where allegations of deliberate power cut, overcrowding, and administrative lapses have been made. These circumstances required a probe beyond the control of local authorities.
5.5. Because the High Court failed to consider the binding precedents of this Hon’ble Court that when allegations of bias or involvement of State machinery exist, transfer of investigation to an independent central agency is imperative to maintain public confidence — (State of West Bengal v. Committee for Protection of Democratic Rights, (2010) 3 SCC 571; Babubhai v. State of Gujarat, (2010) 12 SCC 254; Narmada Bai v. State of Gujarat, (2011) 5 SCC 79; Sakiri Vasu v. State of Uttar Pradesh, (2008) 2 SCC 409*).
5.6. Because the Hon’ble High Court failed to exercise its extraordinary and supervisory jurisdiction under Articles 226 and 227 of the Constitution, and its inherent jurisdiction under Section 482 of the Cr.P.C., to ensure a fair and independent investigation in a case of mass casualty involving apparent administrative negligence.
5.7. Because the Hon’ble High Court erred in mechanically accepting the submissions of the State and local police that investigation is proceeding “fairly”, without calling for the case diary, factual progress reports, or an independent status assessment.
5.8. Because the refusal to transfer the investigation violates the principles of natural justice, public confidence in the administration of justice, and the fundamental duty of the State to protect life and ensure accountability in cases of mass death caused by official failure.
5.9. Because the Hon’ble High Court erred in law in holding that the mere constitution of a local SIT (Special Investigation Team) suffices, whereas such SIT members are drawn from the same police hierarchy under the control of the State Government, which is itself accused of negligence and cover-up.
5.10. Because the Hon’ble High Court overlooked that when the State is an interested party or accused of wrongdoing, the investigation must necessarily be entrusted to an independent agency like CBI, as held in R.S. Sodhi v. State of U.P., (1994) 2 SCC 214 and Vineet Narain v. Union of India, (1998) 1 SCC 226.
5.11. Because the order impugned suffers from non-application of mind, misdirection in law, and failure to consider material facts, rendering it unsustainable and violative of the settled jurisprudence on transfer of investigation in cases involving public tragedies and alleged administrative complicity.
5.12. Because the Hon’ble High Court failed to recognize that in such large-scale public tragedies, only a central agency can conduct a scientific, transparent and neutral investigation, especially where involvement of political figures, senior bureaucrats and law enforcement officers is alleged.
5.13. Because the refusal to grant relief sought by the petitioner has resulted in miscarriage of justice, perpetuated loss of faith in the criminal justice system, and violated the constitutional mandate under Articles 14, 21 and 32 of the Constitution of India.
5.14. Because the Common Impugned final Judgment & Order dated 03.10.2025 passed by the Madurai Bench of Madras High Court in W.P.(MD)No.27571 of 2025; The Division Bench dismissed the petitions, observing that the investigation was at a nascent stage and no allegations had been raised against the State machinery or local police. The Court held that sweeping allegations without tangible material cannot justify transferring the investigation to a central agency. The Court also declined to direct enhanced compensation, noting that the State Government had announced compensation of Rs. 10 lakhs to each victim’s family, while the political party had announced Rs. 20 lakhs, is not maintainable in the eyes of law hence liable to be set aside.
5.15. Because Hon’ble High court has erred in considering that on 27.09.2025, a political meeting of Thiru. Vijay Joseph, actor-turned-politician and leader of TVK, was conducted at Karur, Tamil Nadu. The meeting was attended by about 30 thousand of people, but due to gross mismanagement of crowd control, sudden power outage, and failure of authorities to ensure safety arrangements, chaos ensued, leading to a stampede in which 41 persons tragically lost their lives and many others were grievously injured.
5.16. Because the FIR in Crime No. 855 of 2025 registered at Karur Town Police Station under Sections 105, 110, 125 (b), 223 Bharatiya Nyaya Sanhita, 2023 (BNS) & S. 3 of TNPPDL Act. However, serious lapses on the part of higher-level organisers, district officials, police authorities, and the electricity department have been ignored. This shows selective and biased investigation to shield powerful individuals.
5.17. Because the High Court has ignored that state police have deliberately with an illegal intension have given permission to conduct political meeting by TVK party at the place where even 5 thousand people cannot gather. The respondents state authorities illegally granted permission to conduct political public meeting rally at the heavy traffic movement roads.
5.18. Because the High Court erred in ignoring that it has been reported by survivors and eyewitnesses that the sudden power cut during the political meeting created total chaos, panic, and confusion, directly resulting in the stampede. There is strong and reasonable suspicion that this power cut was not accidental but deliberate, and that certain higher state officials and authorities, including police and electricity department functionaries, were complicit or grossly negligent in causing this man-made disaster. The local investigation by the state police cannot be expected to be fair, impartial, or transparent, since state machinery itself is under suspicion.
5.19. Because the High Court’s decision fails to consider that this tragedy has shaken the conscience of the nation and raises grave questions of public safety, accountability of authorities, and criminal conspiracy.
5.20. Because the High Court has erroneously not consider that the criminal investigation under relevant provisions of IPC (including Sections 109-Attempt to Murder, 105-Punishment for culpable homicide not amounting to murder, 106 (1)-Causing death by negligence, 61 (2)-Punishment for Criminal Conspiracy of BNS against concerned 9th Respondent Actor Vijay and other government officials’ politicians and persons responsible if any and get them punished is just and necessary. The registration of FIR against few TVK District functionary and an appointment of one-man commission of retired Madras High Court Judge Aruna Jagadeesan ignoring real accused person is all an eyewash.
5.21. Because the accountability be fixed not only upon local event organizers but also upon those in higher leadership positions who convened and commanded the event as well as the erring government officials and their higher authority who responsible power deliberate power.
5.22. Because the High Court has erred in ignoring that time-bound, impartial investigation by the CBI, fixing accountability at every level of failure, including deliberate sabotage if any. That all CCTV footages, video recordings, drone visuals, permission records, and medical reports be preserved and taken into custody forthwith to prevent tampering.
5.23. Because the High Court failed to appreciate that the loss of 41 innocent lives due to a preventable tragedy calls for nothing less than an independent, transparent court monitored CBI probe, or SIT headed by sitting or retired Supreme Court Judges so that truth is unearthed, guilty are punished, and justice is ensured
5.24. Because the High Court failed to appreciate that the incident is not only a case of criminal negligence but also a gross violation of Article 21 of the Constitution. The Supreme Court has consistently held that fair, impartial investigation is part of the fundamental right to life and liberty. Where the State machinery itself is under suspicion, investigation must be entrusted to an independent agency like the CBI, or a Special Investigation Team (SIT) headed by a retired/sitting Judge of the Supreme Court.
5.25. Because the learned High court ignored that the victims’ families be granted fair compensation, medical care for the injured, and long-term rehabilitation support. A direction to ensure such man-made tragedies are never repeated in political or public gatherings by enforcing strict safety protocols.
5.26. Because the learned High Court had failed to consider the families of the 41 deceased victims, most of whom are from poor and vulnerable backgrounds, deserve adequate compensation. The State must bear constitutional liability and pay ₹50,00,000 per deceased victim, and the political party/organisers led by actor-politician Thiru. Vijay Joseph must be directed to pay ₹1,00,00,000 per deceased victim.
5.27. Because the paramount duty of every citizen and the State is to protect and ensure the fundamental rights of life, liberty, safety and dignity guaranteed under our Constitution of our fellow citizen like poor, illiterate, ill & aged women and general public in the hands of its violators. If anyone harass, infringe & violate their fundamental rights, a necessary stringent criminal and legal actions should be taken.
5.28. Because the right to life, liberty, dignity, safety and security are a fundamental right guaranteed under our Constitution of India under Part-III. The State defined under Article 12 of the Constitution is obliged and duty bound to protect and provide the same. If the state machinery failed to do so, the Hon’ble Supreme Court of India and Hon’ble High Court under Article 32 & 226 has got Judicial Power to direct the State Machinery to enforce and protect the said rights. The respondent state authorities herein have totally failed to protect the aforesaid fundamental rights guaranteed under our constitution by not and thereby render justice.
5.29. Because High court has ignored the judgment passed by the Hon’ble Supreme Court of India in the case of “Rubabbudin Sheikh vs. State of Gujarat case, reported in (2010) 2 SCC 200, para 60 & 61, has held that “in an appropriate case, the court is empowered to hand over the investigation to an independent agency like CBI even when the charge sheet has been submitted”
5.30. Because this Hon’ble Hon’ble Court of India in the case of “Narmada Bai vs. State of Gujarat and Others” case (direct) in WP (Crl.) No. 115 of 2007, reported in (2011) 5 SCC 79 in para 27, 59 and 71 has held that “in an appropriate case, particularly, when the court feels that the investigation by the state police authorities is not in the proper direction as the high level politicians and higher police officials involved in the crime, in order to do complete justice, it is always open to the court to hand over the investigation to an independent and specialized agency like CBI.” In the present case the TVK leaders have complaint against the former DMK minister Thiru Senthil Balaji and his alleged involved in the stamped tragedy death of 41 people.
5.31. Because this Hon’ble Court of India in the case of “Sunita Devi and Anr. Vs. Union of India and Anr. reported in (2018) 3 SCC 664, in para 5, 9, 10 & 11 has held that “It is clear that the investigating agency showed lackadaisical approach in carrying/proceeding with the investigation. We are of the view that it is necessary to have a fair, honest and complete investigation”.
5.32. Because the High Court has failed to consider that the Hon’ble Supreme Court of India in the case of “Bharat Tamang vs. Union of India and Others, reported in (2013) 15 SCC 578, in para 1, 2, 23, 33, 34 & 35, has held that “..it is the responsibility of the police to come up to the expectation of the public at large and display that no stone will remain unturned to book the culprits and bring them for trial for being dealt with under the provisions of the criminal law of prosecution. Any slackness displayed in that process will not be in the interest of public at large and therefore as has been pointed out by this Court in the various decisions, which we have referred to in the earlier paragraphs, we find that it is our responsibility to ensure that the prosecution agency is reminded of its responsibility and duties in the discharge of its functions effectively and efficiently and ensure that the criminal prosecution is carried on effectively and the perpetrators of crime are duly punished by the appropriate court of law”.
5.33. Because this Hon’ble Court of India in the case of “Mithilesh Kumar Singh vs. State of Rajasthan and others, reported in [(2015) 9 SCC 795], in para 22 has held that “22. It is true that the prayer for transfer of investigation from the State Police to CBI can be allowed only in rare and exceptional circumstances when fair investigation by the State Police does not inspire confidence on account of any external influence or otherwise as held in State of W.B. v. Committee for Protection of Democratic Rights [(2010) 3 SCC 571: (2010) 2 SCC (Cri) 401]. There can be no cast-iron parameters and whether an exceptional situation has arisen may be determined by the Court by taking an overview of the fact situation of a particular case. In the present case, we do not consider it necessary to blame the college authorities or the local police but we are also unable to reject the apprehension of the petitioner and his prayer for transfer of investigation. The death of a young girl student has taken place in mysterious circumstances. According to the petitioner, the statement of the girl was not recorded even though it could have been done and thus, truth has not come out. In these circumstances, without expressing any opinion on merits, it will be appropriate that the matter is investigated by CBI.”
5.34. Because the High Court has ignored the Principle of Natural Justice of right to life under Article 21 of the Constitution includes the right to a fair and impartial investigation (Maneka Gandhi v. Union of India, AIR 1978 SC 597).
5.35. Because FIR in Crime registered at Karur Town Police Station under Sections 105, 110, 125, 123 Bharatiya Nyaya Sanhita, 2023 (BNS) & S. 3 of TN Prevention of Damage to Public Property Act has been registered only against a few organisers, leaving out senior party leaders and state officials. This Hon’ble Court in Rubabbuddin Sheikh v. State of Gujarat (2010) 2 SCC 200 held that shielding influential persons justifies transfer to CBI.
5.36. Because in the case of State of West Bengal v. CPDR (2010) 3 SCC 571, the Constitution Bench of this Hon’ble Court has held that High Courts can direct transfer the criminal investigation to CBI whenever necessary to provide credibility and instill confidence in investigations.
5.37. Because this Hon’ble Court Narmada Bai v. State of Gujarat (2011) 5 SCC 79 and Zahira Habibullah Sheikh v. State of Gujarat (2004) 4 SCC 158, the Supreme Court ordered transfer to SIT/CBI when state police investigations were neither fair nor impartial.
5.38. Because the negligence of State authorities (electricity board, district administration, and police) is alleged. A state-controlled investigation amounts to a conflict of interest.
5.39. Because the High Court’s decision ignores the constitutional essence that under Articles 38 and 47, the State has a constitutional duty to safeguard citizens’ welfare. Its failure to ensure public safety at the meeting is a constitutional breach.
5.40. Because the High Court failed to consider the Petitioner parents’ expectations when transferring the property to the appellant, which was to receive care and support in their old age.
5.41. Because the High Court failed to appreciate that there is a likelihood of tampering or destruction of crucial evidence such as CCTV footage, EB logs, and wireless records if investigation continues under local police. Hence, an appropriate order to preserve the same is just and necessary.
5.42. Because the High court failed to consider this that in Nilabati Behera v. State of Orissa (1993) 2 SCC 746, this Hon’ble Supreme Court has held that adequate compensation for violation of Article 21 is enforceable under writ jurisdiction.
5.43. Because the High court did not consider that petition is maintainable as it concerns mass deaths due to negligence involving violation of Article 21, State accountability, and failure of law and order. The petitioner has locus standi under the well-established principles of public interest litigation.
5.44. Because the petitioner sent a representation to all the official respondent and sought transfer of CBI or SIT investigation and adequate compensation through email on 28.09.2025, the same was served on them, however, no action or response or reply has given.
5.45. Because the compensation announced by the State Government and the political party is inadequate and does not reflect the severity of the incident.
6. GROUNDS FOR INTERIM RELIEF :-
The Petitioner has got a prima facie strong case of success before this Hon’ble Court in the SLP. The investigation by the local police will not ensure the free, fair and impartial investigation. If stay of the local police investigation and the SIT constituted by the High Court is not granted, the petitioners case will be seriously prejudiced. Hence, the Petitioner sought this Hon’ble Court may be pleased to stay investigation by the local in connection with the impugned FIR till the disposal of the present Special Leave Petition in the interest of Justice, Equity and Good Conscience.
7. MAIN P R A Y E R :-
It is, therefore, most humbly prayed that this Hon’ble Court may be pleased to:
(a) Grant Special Leave to Appeal to the petitioners from impugned final Judgment & Order dated 03.10.2025 passed by the Madurai Bench of Madras High Court in W.P.(MD)No.27571 of 2025.
b) Pass such other and further order orders as this Hon’ble Court may deem fit and proper.
8. PRAYER FOR INTERIM RELIEF:-
It is, therefore, most humbly prayed that this Hon’ble Court may be pleased to:
a) Stay the Investigation by 5th respondent local police in connection with the FIR in Crime No. 855 of 2025 registered at Karur Town Police Station, Karur District Tamil Nadu and the SIT; and
b) Pass such other and further order orders as this Hon’ble Court may deem fit and proper.
AND FOR WHICH ACT OF KINDNESS THE PETITIONER SHALL AS IN DUTY BOUND EVER PRAY
DRAWN & SETTLED BY FILED BY

MS. YASMEEN R.SATHISH
ADVOCATE ADVOCATE ON RECORD FOR PETITIONER
FILED ON:16.09.2025

IN THE SUPREME COURT OF INDIA
CRIMINAL APPELLATE JURISDICTION
SPECIAL LEAVE PETITION (CRL) No. OF 2025

IN THE MATTER OF:
G.S Mani …Petitioner

Versus

The Government of Tamil Nadu & Ors. …Respondents
C E R T I F I C A T E
Certified that the Special Leave Petition confined only to the pleadings before the High Court whose order is challenged in this Special Leave Petition and the other documents relied upon in those proceedings. No additional facts, documents or grounds have been taken therein or relied upon in the Special Leave Petition. It is further certified that Annexures annexed to the Special Leave Petition are necessary to answer the questions of law raised in the Petition to make out grounds urged in the Special Leave Petition for consideration of this Hon’ble Court. This Certificate is given on the basis of the instructions given by the petitioner whose affidavit is filed in support of this Special Leave Petition.

DRAWN & SETTLED BY FILED BY

Ms. Yasmeen R. SATHISH
ADVOCATE ADVOCATE ON RECORD FOR PETITIONER
PLACE: NEW DELHI
FILED ON: 16.09.2025

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