Police orderly case THE HON’BLE HIGH COURT OF JUDICATURE AT MADRAS (Special Jurisdiction) W.P. M.P. No. of 2026 in W.P.Crl.No. 472 of 2025 SHANKAR @ SAVUKKU SHANKAR S/o. Late. Achimuthu

MEMORANDUM OF WRIT MISCELLANEOUS PETITION
(Under Article 226 of Constitution of India)
IN THE HON’BLE HIGH COURT OF JUDICATURE AT MADRAS
(Special Jurisdiction)

W.P. M.P. No. of 2026 in
W.P.Crl.No. 472 of 2025

SHANKAR @ SAVUKKU SHANKAR
S/o. Late. Achimuthu
Male; Aged: 49 years
No.1417, 12th Floor
TVS EMERALD LIGHT HOUSE
200 Feet Radial Road,
Iswarya Nagar, Pallavaram
Chennai-600041. …..Petitioner/ Proposed Respondent

-Vs-
1. A.Radhakrishnan S/o. T.Arumuga Gounder
38, Mettur Agraharam
Salem – 636001 … 1st Respondent/Petitioner

2. The Secretary
Ministry of Home Affairs
Government of India, New Delhi

3. The Secretary to Government Pubic (Law and Order, B Section)
Department, Secretariat, Chennai -600009

4. The Secretary to Government
Revenue Department
Secretariat, Chennai 600009

5. The Commissioner of Revenue
Administration
Chepauk, Chennai – 600005

6. The Director General of Police/
Head of the Police Force Dr. Radhakrishnan Salai Chennai -600004.

7. The Additional Director General of Police
BC (Law and Order)
Dr. Radhakrishnan Salai Chennai – 600004.

8. The Inspector General of Police
Intelligence Dr. Radhakrishnan Salai Chennai 600004.

9. The Superintendent of Police
Security Branch Crime Investigation Department, Chennai – 600028.

10. The Superintendent of Police Special Branch Crime Investigation Department, Dr. Radhakrishnan Salai Chennai 600004.

11. The Inspector General of Police West Zone, Race Course Road Coimbatore.

12. The Deputy Inspector General of Police Salem Range Salem – 636007.

13. The District Executive Magistrate/
District Collector Dharmapuri.

14. The District Executive Magistrate /
District Collector Salem.

15. The Commissioner of Police Salem City Salem – 636006.

16. The Superintendent of Police Salem District
Salem 636002.

17. The Superintendent of Police
Dharmapuri District
Dharmapuri

18. The Inspector of Police
District Special Branch
District Police Office Campus
Dharmapuri. …2nd to 18th Respondents/1st to 17th Respondents

AFFIDAVIT OF A. SHANKAR @ SAVUKKU SHANKAR
I, A. Shankar @ Savukku Shankar, S/o.Late Achimuthu, aged about 49 years, residing at No.1417, 12th Floor, TVS Emerald Light, 200 Feet Radial Road, Iswarya Nagar, Pallavaram, Chennai-600041, do hereby solemnly affirm and sincerely state as follows:-

1. I submit that I seek to be impleaded as a party in the above pending writ petition, since I had already submitted a written representation dated 23.07.2025, addressed to the 5th Respondent herein, in relation to the subject matter arising out of the order passed by this Hon’ble Court dated 19.12.2025 in W.P.(Crl.) No.472 of 2025. As such, I am well acquainted with the facts of the case and hence competent to swear to this affidavit.
2. I learnt that in the above writ petition, this Hon’ble Court was pleased to pass an order dated 19.12.2025, issuing directions for the eradication of the illegal “orderly system” in the Police Department as follows:
‘10.In view of several informations made available in the public domain through electronic media and newspapers and amongst Police Department officials, this Court is unable to trust upon the statement made by the Director General of Police that the orderly system is totally dispensed with and no uniformed personnel are performing household works in the residences of the higher police officials.
11. In view of the above position and to ensure that the services of uniformed personnel are utilised for public services and for efficient functioning of the Police Department and to assist the officials of the Police Department to provide services to the people of our great Nation, it is just and necessary to secure correct and complete facts and information from the Government in order to deal with the issues pragmatically and to resolve the same.”
3. I submit that this Hon’ble Court had already passed appropriate orders and directions on 23.08.2022 in W.P. No.2627 of 2014, directing that the practice of the orderly system shall be eradicated in entirety, that Police Personnel shall not be deputed to the residences of Police officials and that in the event of receipt of any complaint or information regarding misconduct or offences, the competent authorities shall conduct an enquiry and initiate appropriate action under the relevant law and the applicable disciplinary rules.
4. I submit that in exercise of the liberty and in terms of the directions given by this Hon’ble Court, I submitted a detailed written representation dated 23.07.2025 to the Director General of Police and Head of Police Force, Tamil Nadu, the 5th Respondent herein bringing to his notice the continued and blatant existence of the orderly system within the residential premises of the Tamil Nadu All India Service Officers Housing Association (TAISHA), Nerkundram, where several IPS officers are residing.
5. I submit that in my said representation, I had specifically complained about Police Personnel, including Grade-II Police Constables and Head Constables, being unlawfully utilised for personal and menial chores such as purchasing groceries, attending to domestic work, caring for pets and acting as drivers, in direct violation of the orders of this Hon’ble Court.
6. I submit that I had further pointed out that the CCTV footage maintained in the TAISHA complex would clearly reveal the continued misuse of Police Personnel and requested that the same be obtained from the Tamil Nadu All India Service Housing Association, a registered cooperative society, for the purpose of verification and enquiry.
7. I submit that acting upon my representation, the 5th Respondent herein issued proceedings in Rc.No.2923942/NGB III(1)/2022 dated 22.08.2025, calling for an enquiry report and directing the Additional Director General of Police, Crime Branch-CID, Chennai, to conduct an enquiry on my complaint and submit a report for taking suitable action.
8. I submit that in the above writ petition, this Hon’ble Court is dealing with the very same issues raised by me, seeking compliance with the directions issued by this Hon’ble Court in the matter of orderly system. I further submit that since I also seek enforcement of the prohibition against the orderly system, which has culminated in the proceedings of the 5th Respondent, I have a direct, substantial and bona fide interest in the subject matter of the writ petition.
9. I submit that I am a video journalist and the Chief Executive Officer of Savukku Media (OPC) Private Limited and I have been engaged in investigative journalism and whistle blowing activities exposing corruption and maladministration through my YouTube channel “Savukku Media. I further submit that unless I am impleaded as a party, the continued violations of this Hon’ble Court’s order, brought to light through my representation may not be fully placed before this Hon’ble Court, thereby affecting effective adjudication and enforcement of its directions.
10. I submit that my impleadment is necessary for a complete and effective adjudication of the issues involved in the writ petition and to avoid multiplicity of proceedings. My presence will not cause any prejudice to the existing parties, but will only assist this Hon’ble Court in ensuring compliance with its binding orders.
It is therefore humbly prayed that this Hon’ble Court may be pleased to implead the Petitioner as a party Respondent in W.P.Crl. No.472 of 2025 and 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.

Solemnly affirmed at Chennai BEFORE ME
On this day of January, 2026
And signed his name in my presence. ADVOCATE, CHENNAI