THE HIGH COURT OF JUDICATURE AT MADRAS W.P. of 2025 1.M/s Pattali Makkal Katchi Rep by its General Secretary Mr.Murali Sankar Thailapuram,Dindivanam, Villupuram District …..Petitioner today
MEMORANDUM OF WRIT PETITION
(Under Article 226 of Constitution of India)
IN THE HIGH COURT OF JUDICATURE AT MADRAS
W.P. of 2025
1.M/s Pattali Makkal Katchi
Rep by its General Secretary Mr.Murali Sankar
Thailapuram,Dindivanam,
Villupuram District …..Petitioner 
-Vs-
1.Dr.R.Anbumani,
Executive President
M/s Pattali Makkal Katchi.
No.10.Thilak Street,T.Nagar,
Chennai-600 017.
2.The Election Commission of India
Election Commission,
Nirvachan Bhavan, New Delhi.
3.The State Election Commission Tamilnadu.
No.208/2,Jawaharlal Nehru Road,Opp CMBT,
Arumbakkam,Chennai-600 106.
4.The Secretary to Govt
Home Department
Govt of Tamil Nadu,
Fort St.George,
Chennai-600 009
5.The Director General General of Police
Police Head quarters,
South Beach Road,
Chennai. …Respondents
AFFIDAVIT
The Petitioner states as follows:
The Petitioner M/s Pattali Makkal Katchi, Rep by its General Secretary Mr.Murali Sankar having office at Thailapuram, Dindivanam, Villupuram District.
The address for service of all notices and processes on the petitioner is that of his counsel, Dr. K. Arul, S.Mahaveer Shivaji, V.S.Gopu, Dr.S.Vidya V. Archana, S.Siva Kumar ,R. Sangeetha , J.Sathiya Vimal , Advocates at No.1, Binny Street, Off Mount Road, Egmore, Chennai 600 008.
The Petitioner submits that he is the General Secretary of the M/s Pattali Makkal Katchi a registered political party in the State of Tamil Nadu. He is authorized on 02/08/2025 by the founder and the President of M/s Pattali Makkal Katchi Dr.S.Ramadoss to prefer the Writ petition before this Hon’ble Court for appropriate directions and orders.
4. The Petitioner further submit that the Petitioner Party was founded on 16-07-1989 by the President Dr.S.Ramadoss for serving the poor and backward class and other scheduled castes and tribe etc., and for upliftment, social justice to the downtrodden in the state of Tamil Nadu and Puducherry. M/s Pattali Makkal Katchi is very popular among the people of tamilnadu in view of the polices and steps took by the founder Dr.S.Ramadoss.
5. The Petitioner has a long political history in Tamilnadu. It is having its own representative as MLA’s, MP’s, Counselors in both Parliament and Legislature during various periods for serving the people of the society,most particularly the poor and working class.
6. It is further submitted that the Petitioner is having its own bye-laws for the internal organisation /management to run the party smoothly by having its own office bearers for having a well organised socio democratic setup.
7. The Petitioner further submits that the party used to have its President, General Secretary, Treasurer and other key office bearers for the parent body duly elected / Nominated by the competent body as per bye-laws.The Bye-law enables the party to have meetings of Chief Administrative Committee ,State Executive Committee and State General Body for appointing its office bearers with the Guidelines and the approval of the Founder /President of the party.
8. The Petitioner Submits that the practice of appointing President ,General Secretary, Treasurer and other office bearers were done time to time periodically only under the guidelines and advice of the Founder of the Party only. The former President of the party was the first Respondent who was appointed by the founder Dr.Ramadass and on its advice he was appointed as the President on 28-05-2022 for a period of three years i.e up to 28-05-2025. The tenure of first Respondent as President has expired by 28-05-2025.Then it essential to appoint a new president of the party for the next tenure from 29-05-2025 by adopting the established procedure of the party as per bye-laws with the guidelines and advice of party founder Dr.S.Ramadass the authority to take decisions on appointing the office bearers including the state president is with the Founder.
9. It is further submitted that as a new party president for the tenure of the three years starting from 29-05-2025 have to be done by adopting the procedures prescribed under the bye-law by convening a general body meeting it was decided to have a president of the state body immediately for running the party the high level committee has unanimously nominated the party founder Dr.S.Ramadass as new president from 29-05-2025 with the idea of ratifying the same by the competent body in due course. As such, the founder Dr.S.Ramadass was nominated as new president of the party and he took office of state president from 30-05-2025 by assuming the charges of the state president of Pattali makkal katchi.
10. It is Pertinent to pendown and notworth to note that the administrative committee meeting was conducted with 21 administrative members on 05-07-2025 in which 10 resolutions were passed the same is submitted for the kind perusal and consideration of this Hon’ble court for deciding the subject in issue.On 07 -07- 2025 the state executive committee meeting was conducted in which about 1440 office bearers participated and 25 resolutions were passed in the resolution No.11 as per rule 33 of Pattali Makkal Katchi Bye-law was amended the amendments are made for rule 13 of Bye-law which speaks about the founder.In that rule 13 (1) is made:
A) After the expiry of the tenure of incumbent presidents tenure the founder of the party is empowered to assuming the office of the state president by himself for looking after the various administrative activites of the party on assuming the charge of the state president by his authority as Founder.
B)The Founder himself is empowered to Appoint/Nominate all key administrative positions of the party after expiry of the tenure of earlier persons,to have a new appointments for smooth functioning of the party organization and administration without any break till new office bearers are duely appointed under the guidance and direction of the founder.
C)The Founder is empowered to convening all emergent and ordinary meetings like administrative committee,state executive committee,special general body meeting committee and any other committee or meetings of party to any situation for strengthening the party and also conduct party proceedings during the interregnum period of appointing a new president.In Nutshell the founder of the party is sole authority to appoint and organize the meetings in any nature on his own capacity of founder which cannot be called in question by any one at any point of time or before any legal forum.
11. It is submitted, while the things being so, the then president R.Anbu Mani was also nominated as Executive president and Mr.G.K.Mani MLA was Re-Nominated as Honoury president the party also appointed Mr.Murali sankar as general secretatary and syed mansur as its treasurer for the new tenure period of 30-05-2025 (for a period of three years ending 29-05-2028)
12. It is further submitted that in clear terms the founder of Pattali makkal katchi Dr.S.Ramadoss was appointed as the state president of Pattali makkal katchi for the first time as the party needed special attention to get re-recognication by facing the ensuing assembly elections of 2026.The same was accepted by all the leaders and cadres of the party accepting the presidentship of Dr.S.Ramadoss and were functioning smoothly for the past two months.
13. It is further submitted that despite the appointment of first Respondent as Executive president of the party ,he started unwarrented dis-obedience to the party high command and the state president Dr.S.Ramadoss, used to create confusions on the minds of leaders and caders and inspite of advise of the founder ultimately was turned as the outfit of the party and claiming himself as the president without any authority was holding meetings and prosession which were timely objected and averted by the founder and president of the party.
14. As such in clear terms the first respondent who has not been the state president at present is also attempting to hold various party meetings unilaterly without the authority of state president and founder Dr.S.Ramadoss which is considered to the an illegal to the requireing to proceed with disciplinary action against the first respondent
15. It is submitted that there were various communications and complaints about the illegal and misdeeds of first respondents to the other respondents on various dates by requesting them to take appropriate actions against the first respondent who is not obeying the directions of the founder and state president Dr.S.Rama Doss for the past two months ,Those communication were also submitted before the hon’ble court for easy understanding of the happenings in the state of tamil Nadu. In that, one illegality was a hundred days walking procession announced by first respondent without the approval of the state president and the founder of party Dr.S.Ramadoss.Though the director general of police gave circular to stop the walking procesion it was not stopped by first respondent who had dis-obeyed the orders of police for which action is sought to be taken.
16. In such circumstances,as an extreme illegality the first repondent made a public notice of convening a general body meeting for which he is not authorized either by the party new president and founder or by the party bye-laws.This was announced on 01-08-2025 for holding the meeting of general body on 09-08-2025 which is totally an illegal act with the ulterior motive behind that to create confusion among the leaders and caders among the party.
17. In fact the duly competant new president and the founder of the party made a notification on 25-5-2025 for convening a special gereral body meeting on 17-08-2025 for taking important decisions including ratification of acts and resolutions made in administrative and executive committes during 05th and 09th july 2025.When the competent authority of the Pattali makkal katchi when decided to hold a special general general body meeting with a authority entrusted on it by fixing 17-08-2025 the act of first respondent without any legality and authority has fixed 09-08-2025 for a general body meeting itself its an outcome of illegality without any authority which needs to be stopped immediately to avoid,avoidable unwarrented law and order issue on 09-08-2025 or any subsequent date in view of the mischeives act of first respondent who is not a law avaiding citizen.
18. Hence, it is most respectfully submitted that the proposed illegal and unauthorised general body meeting fixed on 09-08-2025 at confluence hall Mamallapuram,Kanchipuram district immediately.
19. For the reason stated in the accompanying affidavit, ,it is most respectfully prayed before this Hon’ble court to prohibit the convening of a illegal general body meeting fixed on 09-08-2025 by the first respondent at confluence hall mamallapuram,kanchipuram district by issuing the writ in the nature of WRIT OF MANDAMUMS or any other writ or order or direction directing the official respondents for prohibiting the convening of said general body meeting by the first respondent which is not only an outcome of illegality and also an outcome of greedy intention of the first respondent and may pass such other or further orders as this Hon’ble Court deem fit and proper in the facts and circumstances of the case and thus render justice.
Solemnly affirmed at Chennai on this Before me:
the day of 05th August , 2025 and
signedhisnameinthepresencof: Advocate :Chennai
IN THE HIGH COURT OF JUDICATURE AT MADRAS
W.P. of 2025
Pattali Makkal Katchi
Rep by its General Secretary Mr.Murali Sankar
Thailapuram,Dindivanam,
Villupuram District …..Petitioner
-Vs-
1.Dr.R.Anbumani,
Executive President
Pattali Makkal Katchi.
No.10.Thilak Street,T.Nagar,
Chennai-600 017
2.The Election Commission of India
Election Commission,Nirvachan Bhavan,
New Delhi.
3.The State Election Commission Tamilnadu.
No.208/2,Jawaharlal Nehru Road,Opp CMBT,
Arumbakkam,Chennai-600 106.
4.The Secretary to Govt
Home Department
Govt of Tamil Nadu,
Fort St.George,
Chennai-600 009
5.The Director General general of police
Police Head quarters,
South Beach Road,
Chennai. ……Respondents
WRIT PETITION
The petitioner states as follows:
The petitioner Mr.Murali Sankar , residing at Thailapuram, Dindivanam, Villupuram District.
The address for service of all notices and processes on the petitioner is that of his counsel, Dr. K. Arul, S.Mahaveer Shivaji, V.S.Gopu, Dr.S.Vidhya V. Archana, S.Siva Kumar ,R. Sangeetha , J.Sathiya Vimal , Advocates at No.1, Binny Street, Off Mount Road, Egmore, Chennai 600 008.
The address for service of all notice and process on the Respondent is the same as stated above.
For the reason stated in the accompanying affidavit, ,it is most respectfully prayed before this Hon’ble court to prohibit the convening of a illegal general body meeting fixed on 09-08-2025 by the first respondent at confluence hall mamallapuram,kanchipuram district by issiung the writ in the nature of WRIT OF PROHIBITION or any other writ or order or direction directing the official respondents for prohibiting the convening of said general body meeting by the first respondent which is not only an outcome of illegality and also an outcome of greedy intention of the first respondent and may pass such other or further orders as this Hon’ble Court deem fit and proper in the facts and circumstances of the case and thus render justice.
Counsel for the Petitioner
IN THE HIGH COURT OF JUDICATURE AT MADRAS
W.P. of 2025
Pattali Makkal Katchi
Rep by its General Secretary Mr.Murali Sankar
Thailapuram,Dindivanam,
Villupuram District …..Petitioner
-Vs-
1.Dr.R.Anbumani,
Executive President
Pattali Makkal Katchi.
and 4 others. ….Respondents
INDEX TO TYPED SET OF PAPERS
S.No
Date Particulars Page Nos
1 Dates & Events
2 Synopsis
3 Coding Sheet
4 Court Fee
5 Writ Petition
6 Affidavit
7 02-08-2025 Notification for Illegal General Body Meeting called by Dr.R.Anbumani
TYPED SET OF PAPERS
8 16-07-1989 Bye-law- 1989 of the Party
9 15-06-2025 Appointment of Mr.Murali Sankar as General Secretary -By Dr.S.Rama doss(President of Pattali Makkal Katchi)
10 05-07-2025 Minutes of state administrative committee meeting
11 05-07-2025 Copy of FIR No.385/2025
12 07-07-2025 Letter by Dr.S.Rama Doss to DGP
13 07-07-2025 Minutes of state executive committee meeting
14 22-07-2025 Letter by Dr.S.Rama Doss to DGP
15 24-07-2025 Letter of DGP to IG (North Zone)
16 24-07-2025 Letter of DGP to all SP /Commissioner of Police
17 25-07-2025 Memorandum of DGP
18 25-07-2025 Notification of Special General Body Meeting called by Founder President on 17-08-2025
19 28-07-2025 Letter of swaminathan secretary to Dr.Rama doss to Home secretary Tamil Nadu.
20 29-07-2025 Copy of FIR No.292/2025
21 30-07-2025 Letter of Mr.Rama doss to Chief Election commission of india
22 01-08-2025 Authorization Letter for Filing case
23 02-08-2025 Copy of Complaint for Stoping Illegal General Body Meeting
24 Vakalath
25 Batta
It is certified that the above documents are true copies of its originals. Dated at Chennai on this the 05th day of Aug 2025.
Counsel for petitioner
IN THE HIGH COURT OF JUDICATURE AT MADRAS
W.P. of 2025
Pattali Makkal Katchi
Rep by its General Secretary Mr.Murali Sankar
Thailapuram,Dindivanam,
Villupuram District …..Petitioner
-Vs-
1.Dr.R.Anbumani,
Executive President
Pattali Makkal Katchi.
and 4 others. ….Respondents
DATES AND EVENTS
S.No
Date Particulars Page Nos
1 16-07-1989 Bye-law- 1989 of the Party
2 15-06-2025 Appointment of Mr.Murali Sankar as General Secretary -By Dr.S.Rama doss(President of Pattali Makkal Katchi)
3 05-07-2025 Minutes of state administrative committee meeting
4 07-07-2025 Letter by Dr.S.Rama Doss to DGP
5 07-07-2025 Minutes of state executive committee meeting
6 22-07-2025 Letter by Dr.S.Rama Doss to DGP
7 24-07-2025 Letter of DGP to IG (North Zone)
8 24-07-2025 Letter of DGP to all SP /Commissioner of Police
9 25-07-2025 Memorandum of DGP
10 28-07-2025 Letter of swaminathan secretary to Dr.Rama doss to Home secretary Tamil Nadu.
11 30-07-2025 Letter of Mr.Rama doss to Chief Election commission of india
Counsel for petitioner
In the High Court of Judicature at Madras
W.P No of 2025
1.Pattali Makkal Katchi
Rep by its General Secretary Mr.Murali Sankar …..Petitioner
-Vs-
1.Dr.R.Anbumani,
Executive President
Pattali Makkal Katchi.
and 4 others. ….Respondents
I/We,Pattali Makkal Katchi rep by its General Secretary Mr.Murali Sankar , in the above Appeal / Petition do hereby appoint and M/s. DR.K.Arul (586/1984), V.S.Gopu (2569/2008),S.Mahaveer Shivaji (2435/2006), Dr.S.Vidya (1174/1995) V.Archana (2840/2018), S.Siva Kumar(1196/2018) R.Sangeetha (2118/2021), J.Sathya Vimal (6207/2023) Advocates at room No.1,Binny Road,(Opp to Taj Connemara Hotel), Mount Road,Chennai .Advocate of the High Court to appear for me/us in the above Appeal / Petition to conduct and to prosecute (or defend) the same and all proceedings that may be taken in respect of any application connected with the same or any decree or orders passed therein including all applications for return of documents or the receipt of the money that may be payable to me/us in the said Appeal / Petition and also in appeal under Section 15 of the Letters Patent and in applications for leave to Supreme Court of India, and in all applications for review of Judgement.
I certify that the contents of this Vakalat
were read out and explained in
In my presence to the
Executant who appeared
perfectly to understand the same and signed
his/her name in my presences.
Executed before me this 05th day of Aug 2025
ACCEPTED: The Address for Service of the said
Counsel for petitioner
IN THE HIGH COURT OF JUDICATURE AT MADRAS
W.P. of 2025
Pattali Makkal Katchi
Rep by its General Secretary Mr.Murali Sankar
…..Petitioner
Vs
1.Dr.R.Anbumani,
Executive President
Pattali Makkal Katchi.
and 4 others.
….Respondents
VAKALATH
Counsel for Petitioner
DR. K .ARUL (586/1984)
V.S.Gopu (2569/2008)
Mahaveer Shivaji(2435/2006)
Dr.S.Vidya (1174/1995)
V.Archana (2840/2018)
S.Siva Kumar(1196/2018)
R.Sangeetha (2118/2021)
J.Sathiya Vimal (6207/2023)
Ph.8939685749
Email : aruladvocate10@gmail.coM
IN THE HIGH COURT OF JUDICATURE AT MADRAS
W.P. of 2025
1.Pattali Makkal Katchi
Rep by its General Secretary Mr.Murali Sankar …..Petitioner
-Vs-
1.Dr.R.Anbumani,
Executive President
Pattali Makkal Katchi.
2.The Election Commission of India
Election Commission,New Delhi.
3.The State Election Commission Tamilnadu.
No.208/2,Jawaharlal Nehru Road,Opp CMBT,
Arumbakkam,Chennai-600 106.
4.The Secretary to Govt
Home Department
Govt of Tamil Nadu
5.The Director General general of police
Police Head quarters,
Chennai. …Respondents
SYNOPSIS
The Petitioner state that he is the General secretary of the Pattali Makkal Katchi a register political party in the state of tamil nadu.He is authorized by the founder and the president of pattali makkal katchi Dr.S.Ramadoss MBBS to prefer the Writ petition before this Hon’ble court for appropriate directions and orders.That the pattali makkal katchi was founded on 16-07-1989 by Dr.S.Rama doss for serving the poor and backward class and other scheduled castes and tribe etc. who have upliftment and rendering solical justice to all concern in the state of Puducherry and Tamil Nadu.That the said Pattali makkal katchi is very popular among the people of tamilnadu in view of the polices and steps took by the founder Dr.S.Rama Doss.The Petitioner Pattali Makkal Katchi had a long History in the political history of tamilnadu as it was having it own ministers member of parliaments and MLA’s in various periods for serving the people of the society most particularly the poor and working class.That the Pattali makkal katchi having its own bye-laws for the internal organisation to run the party smoothly by having its own office bearers for having a well organised socio democratic setup.The Bye-laws are submitted for the kind consideration of the Hon’ble court for the purpose of the subject matter initio.That the party used to have its president, General Secretary, treasurer and other key office bearers for the parent body duely elected / Nominated by the competant body as per bye-laws.The Bye-law enables the party to have meetings of chief admistrative committee ,State Executive Committee and state general body for appointing its office bearers with the guidenes and the approval of the founder president of the party.
As such, he submitted that the practice of appointing president ,General Secretatry,Treasurer and other office bearers were done time to time periodically under the guideness and advice of the founder of the party all along.The last president of the party was the first respondent Dr.Anbu mani who was identified by the founder Dr.Rama Dass and on its advice he was appointes as president on 28-05-2022 for a period of three years i.e up to 28-05-2025 .The tenure of first respondent has president was expired by 28-05-2025.Then he nesistated to appoint a new president of the party for a period of three years starting from 29-05-2025 by adopting the established procedure of the party as per bye-laws with the guideness and advice of party founder Dr.S.Rama Dass who is the supreme authority to take decisions on appointing the office bearers including the state president.That as a new party president for the tenure of the three years starting from 29-05-2025 have to be done by adopting the procedures precribed under the bye-law by convening a general body meeting it was decided to have a president of the state body immediately for running the party the high level committee as unonimously nominated the party founder Dr.S.Rama Dass as new president from 29-05-2025 with the idea of ractifing the same by the competent body in due course. As such, the founder Dr.S.Rama Doss was nominated as new president of the party and he took office of state president from 30-05-2025 by assuming the charges of the state president of Pattali makkal katchi.
That despite the appointment of first respondent as Executive president of the party ,he started unwarrented dis-obedience to the party high command and the state president Dr.S.Rama Doss, used to create confusions on the minds of leaders and caders and ultimately was turned as the outfit of the party and claiming himself as the president without authority was holding meetings and prosections which were timely objected and averted by the founder and president of the party.
It is submitted that there were various communications and complaints about the illegal and misdeeds of first respondents to the other respondents on various dates by requesting them to take appropriate actions against the first respondent who is not obeying the directions of the founder and state president Dr.S.Rama Doss for the past two months those communication were also submitted before the hon’ble court for easy understanding of the happenings in the state of tamil Nadu. In that, one illegality was a hundred days walking procesion announced by first respondent without the approval of the state president and the founder of party Dr.S.Rama doss.Though the director general of police give circular of stop the walking procesion it was not stopped by first respondent who had dis-obeyed the renders of police for which action is sought to be taken.In such circumstances,as an extreme illegality the first repondent made a public notice of convening a general body meeting for which is not authorised either by the party new president and founder or by the party bye-laws.This was announced on 01-08-2025 for holding the meeting of general body on 09-08-2025 which is totally an illegal act with the alterer motive behind that to create confucion among the leaders and caders among the party.
In fact the duely competant new president and the founder of the party made a notification on 25-5-2025 for convening a special gereral body meeting on 17-08-2025 for taking important decisions including racification of acts and resolutions made in administrative and executive committes during 08th and 10th july 2025.When the competent authority of the Pattali makkal katchi when decided to hold a special general general body meeting with a authority entrusted on it by fixing 17-08-2025 the act of first respondent without any legality and authority has fixed 09-08-2025 for a general body meeting itself its an outcome of illegality without any authority which needs to be stopped immediately to avoid,avoidable unwarrented law and order issued on 09-08-2025 or any subsequent date in view of the mischeives act of first respondent who is not a law avaiding citizen.Hence, it is most respectfully submitted that the proposed illegal and unauthorised general body meeting fixed on 09-08-2025 at confluence hall mamallapuram,kanchipuram district immediately.
Counsel for the Petitioner
