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IN THE HIGH COURT OF JUDICATURE AT MADRAS

(Contempt Jurisdiction)

Contempt Petition No. of 2017

IN
W.P.No.18141 of 2017

Dravida Munnetra Kazhagam,

Rep. by its organization Secretary,
R.S. Bharathi,
DMK Headquarters,
‘Anna Arivalayam’,
367 & 369, Anna Salai,
Chennai-600 018. ... Petitioner/Writ Petitioner

Vs.

1. Mr. M. Malik Ferozh Khan, I.A.S. (R),

State Election Commissioner,
Tamil Nadu State Election Commission,
No.208/2, Jawaharlal Nehru Road,
Opp. CMBT, Arumbakkam,
Chennai-600 106.

2. Thiru. T. S. Rajasekar, I.A.S.,

The Secretary,
The Tamil Nadu State Election Commission,
No.208/2, Jawaharlal Nehru Road,
Arumbakkam,
Chennai-600 106.

3. Dr. (Mrs.) Girija Vaidyanathan,

Chief Secretary to Government,
Fort St. George, Secretariat,
Chennai – 600 009.

4. Mr. Hans Raj Verma, I.A.S.,

Principal Secretary to Government,
Rural Development and Panchayat Raj Department,
Government of Tamil Nadu,
Secretariat, Fort St. George,
Chennai-600 009.

5. Mr. Harmander Singh, I.A.S.,

Principal Secretary to Government,
Municipal Administration & Water Supply Department,
Fort St. George, Secretariat,
Chennai – 600 009.

6. Mr.S.S. Poovalingam,
Secretary to Government (i/c),
Law Department,
Fort St. George, Secretariat,
Chennai 600 009.

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7. Mr.S. Palanisamy, IAS.,

Director of Town Panchayats,
Kuralagam, Chennai - 600 001.

8. Dr. D. Karthikeyan, I.A.S.,

Commissioner,
Greater Chennai Corporation,
Ripon Building,
Chennai-600 003. … Respondents /Respondents

AFFIDAVIT R.S.BHARATHI

I, R.S. Bharathi, son of D.J. Raman, Indian, aged 69 years, having office

at the Head Quarters of Dravida Munnetra Kazhagam (DMK), “Anna

Arivalayam”, No. 367 & 369, Anna Salai, Teynampet, Chennai -600 018, do

hereby solemnly affirm and sincerely state as follows:

1. I am the Organization Secretary of the Petitioner herein and also a

Member of Parliament (Rajya Sabha). I am authorized by the General Secretary

of the DMK to depose this affidavit on behalf of the party and as such I am well

acquainted with the facts and circumstances of the case.

2. I humbly submit that the Petitioner had earlier filed a Writ Petition

in W.P. No. 33984 of 2016 before this Hon’ble Court seeking for the following

relief:

“Writ of Certiorarified Mandamus calling for the records pertaining

to the impugned Government Orders in G.O.Ms No.103, Rural

Development and Panchayat Raj (PR-1) Department Dated 16.09.2016 in

respect of the offices of Chairman of Panchayat Union Councils; G.O.Ms

No.105, Rural Development and Panchayat Raj (PR-1) Department Dated

16.09.2016 in respect of the seats of Wards in District Panchayats;

G.O.Ms No.106, Rural Development and Panchayat Raj (PR-1)

Department Dated 16.09.2016 in respect of seats of Wards in Panchayat

Union Councils and quash the same, both on Reservation and on rotation

and consequently, direct the Respondents to conduct the ensuing local

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body election in the State of Tamilnadu, by strictly providing adequate

reservation to the Scheduled Tribe, followed by necessary rotation of

seats in all the posts, as mandated in the Constitution of India”

3. I humbly submit that the Learned Single Judge by an Order dated

04.10.2016 was pleased to dispose of W.P.No.33984 of 2016 by issuing

various directions at para 42 which is extracted hereunder:

“42. While upholding the impugned Government Orders, to

maintain purity in public life, this Court moulds the relief and gives the

following directions: (i) Election Notifications dated 26.09.2016 issued for

conduct of Local Body Election by the State Election Commission on

17.10.2016 and 19.10.2016 are vitiated for non-compliance of Rule 24 of

the Tamil Nadu Panchayat (Elections) Rules, 1995. (ii) The State Election

Commission is directed to issue fresh notifications, conduct elections and

complete the election process, as per law, at the earliest, not later than

31.12.2016. (iii) The State government is directed to invoke Section 261 –

Transitory provision of the Tamil Nadu Panchayats Act, 1994, to

administer the Local Bodies by appointment of Special Officers till the

elections are held, as the present terms of the present Local Bodies are to

expire soon and the same cannot be extended beyond five years. (iv) The

State Government shall amend Rule 26 of the Tamil Nadu Panchayats

(Election) Rules, 1995 by insertion of a sub-rule to incorporate State

Election Commission Notification bearing S.O.No.43/2006/EG dated

01.09.2006 mandating the candidates desiring to contest to a local body,

to file a separate affidavit, to furnish full and complete information, in

regard to five categories, including criminal background, at the time of

filing nomination, at the earliest. (v) The State Election Commission shall

follow its notification bearing S.O.No.43/2006/ EG dated 01.09.2006 by

suitably and strictly informing the Election Officers to reject the

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nominations of candidates who fail to file affidavit, as per the above

notification dated 01.09.2006. (vi) The State Election Commission shall

sensitise the public especially candidates about its notification dated

01.09.2006 requiring affidavit disclosing criminal cases against the

candidate by issue of advertisements so that the voters would be

informed about the details of the candidates. (vii) The State Election

Commission shall consolidate, record and data base the details provided

by the candidates in the form of affidavits and upload them in its

website. (viii) The State Government and State Election Commission shall

look into and decide about complaints regarding reservation, de-

reservation of posts, deletion or addition of genuine eligible voters and

enrolment of bogus voters etc., before conducting the election, after

issuance of fresh election notifications. (ix) The State Election Commission

shall write to recognized and registered political parties/organizations, in

exercise of power under Article 243K of the Constitution of India asking

them not to field/sponsor any candidate with criminal

background/history for the local body election within four weeks to

prevent criminalisation and hijacking of local bodies by criminal

elements.”

4. I humbly submit that aggrieved by the said Order dated

04.10.2016, the State Election Commission alone had preferred an appeal in

W.A.No.1268 of 2016 before the Direction Bench of this High Court. It is

submitted that when the above Writ Appeal was pending for hearing, the

Division Bench of this Hon’ble court on the request of the petitioner to hold the

local body elections , by an order dated 21.02.2017 directed the Respondents

to complete the election process by 14.05.2017 thereby directing the

Respondents to conduct and complete elections of all local bodies by

14.05.2017. However, the order of the Division Bench was not complied with

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and therefore the Petitioner herein has filed Contempt Petition No.642 of 2017.

The Division Bench has ordered notice to the Respondents therein and the said

Contempt Petition is pending. Meanwhile, the 2nd Respondent filed

C.M.P.No.3031 of 2017 and sought extension of time upto 31.05.2017 for

preparation of Electoral Roll and complete the process of election before July

2017. The affidavit of the 2nd Respondent may be read as part and parcel of

this affidavit. However, the Respondents 1 and 2 violated their own

undertaking given to the Court and danced to the tunes of political masters as

the climate was not in favour of the ruling party and therefore did not come

forward to conduct election before July 2017. Sensing that the Respondents

have no idea of conducting elections, during the pendency of the above Writ

Appeal, the Petitioner therefore had filed one more Writ Petition in

W.P.No.18141 of 2017 seeking issuance of a Writ of Mandamus directing the

Respondents therein to hold election to all local bodies in the State of Tamil

Nadu including Panchayats and Municipalities by exercising the powers under

Articles 243–K and 243–ZA of the Constitution of India within a stipulated

time.

5. I humbly submit that during the pendency of the above appeal one

social activist namely, “Change India” represented by its Director A. Narayanan

filed another Writ Petition in W.P.No.14381 of 2017 seeking issuance of a Writ

of Declaration, declaring the promulgation of the Tamil Nadu Municipal Laws

(Third Amendment) Ordinance, 2016 (Tamil Nadu Ordinance 2 of 2016) and

promulgation of the Tamil Nadu Panchayats (Third Amendment) Ordinance,

2016 (Tamil Nadu Ordinance 1 of 2016) and notification of G.O.Nos.145, 146,

147 and also G.O.Nos.124, 125 and 126 appointing Special Officers for the

urban and rural local bodies respectively till 31.12.2016 and further extension

of their tenure till 30.06.2017 as ultra vires of the Constitution.

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6. I humbly submit that meanwhile as against the order dated

21.02.2017 made in W.A.No.1268 of 2016 neither the State Election

Commission nor the State government filed SLP before supreme court. Thus

the said order became final and conclusive. However one Mr.P.K. Ganesan filed

SLP No.4878 of 2017 before the Hon’ble Supreme Court of India challenging

the above said order and the Hon’ble Supreme Court of India dismissed the

SLP on 20.03.2017 and requested the division bench to proceed to hear the

main Writ Appeal in WA No 1268 of 2016.

7. I humbly submit pursuant to the directions of the Hon’ble

Supreme court, this Hon’ble court proceeded to hear the Writ Appeal and above

writ petitions together and reserved the matters for orders on 01.08.2017 and

pronounced the orders on 04.09.2017. This Hon’ble court has extracted the

arguments made by the Learned Advocate General appearing for the

Government in the order dated 4.9.2017 as follows:

“23. The Learned Advocate General appearing on behalf of the

State of Tamil Nadu submitted that in accordance with the endeavour of

the State Government to comply with its constitutional mandate of

conducting elections to local bodies before the expiry of the term as

enshrined under Article 243-E of the Constitution of India, elections to the

local bodies were announced.

24. The learned Advocate General submitted that even though

there is another constitutional mandate under Article 243-C to delimit

wards as per latest census data, the Government decided to conduct local

body elections without going through the process of delimitation of wards

as per the census of 2011 in order to ensure that the electoral process was

completed by October, 2016.

25. Accordingly, to retain the existing territorial wards for the

ensuing elections without delimitation amendments were made to the

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Tamil Nadu Panchayats Act, 1994, Tamil Nadu District Municipalities Act,

1920 and laws relating to Municipal Corporations in the State. He further

stated that many writ petitions were filed seeking directions on the

Respondents to undertake delimitation prior to elections and rotate the

reservation of wards, which had remained the same for about 20 years.

26. The Learned Advocate General further submitted that the

consultation with Tamil Nadu State Election Commission was completed

by September, 2016 and the entire administrative machinery of election

officers and police personnel was placed at the disposal of State Election

Commission for conduct of elections. On 26.9.2016, the Tamil Nadu State

Election Commission notified the programme of elections, pursuant to

which 4.9 lakh nominations were received from the candidates till

3.10.2016, which was the last date for filing nominations. However, on

4.10.2016, a Single Bench of this Court issued the order in W.P.No.33984

of 2016 under appeal, as a result of which the election process could not

be completed.

xxx xxx xxx xxx

33. The Learned Advocate General submitted that completion of

the delimitation process would enable the State Government to fully

discharge the constitutional obligations imposed on the State under Article

243-C of the Constitution.”

However, after hearing the arguments of the Learned Advocate General and the

respective Counsels, this Hon'ble Court at para no.51 has held as follows:-

“51. The proposition which emerges from the judgment of the

Supreme Court in Kishansing Tomar v. Municipal Corporation of the City of

Ahmedabad and others (supra), is that the Election Commission is to

complete election to municipal bodies before the expiration of five years. It

is not to put forward any excuse on unreasonable grounds to postpone

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elections. Any revision of electoral rolls are to be carried out in time and if

it cannot be carried out within a reasonable time, the election has to be

conducted on the basis of the then existing rolls.”

Further, this Hon'ble Court, at para no.57, has held as follows:

“57. In Kishansing Tomar v. Municipal Corporation of the City of

Ahmedabad and others, (supra), the Supreme Court referred to the

aforesaid opinion of Pasayat, J. and held that from the opinion thus

expressed, it is clear that the State Election Commission was not to put

forward any excuse based on unreasonable grounds that the election

could not be completed in time. The Election Commission would have to try

to complete the election before the expiration of the duration of five years

period as stipulated. Any revision of electoral rolls is to be carried out in

time and if it cannot be carried out within a reasonable time, the election

has to be conducted on the basis of the then existing rolls. In other words,

the Election Commission would have to complete the election before the

expiration of the duration of five years period as stipulated in Clause (5)

and not yield to situations that may be created by vested interests to

postpone elections from being held within the stipulated time.”

Further, at paras 84 and 87, this Hon'ble Court has held as follows:

“84. As observed above, elections to local bodies were to be held

within five years from the date of the first meeting. This has not been

done. Elections are long overdue. A period of almost one year has elapsed

from the date of expiration of the tenure of the local bodies. In the

circumstances, it is imperative that elections be held immediately.

“87. The notification announcing elections to local bodies in Tamil

Nadu shall definitely be published within 18th September 2017 and

elections to local bodies shall be completed by 17th November, 2017. We

are informed that the appeal is listed for hearing before the Supreme

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Court on 06.09.2017. Needless to mention that these directions will be

subject to any orders that might be passed by the Supreme Court on

06.09.2017.”

8. I humbly submit that therefore duty is cast upon the 1st and 2nd

Respondent to conduct elections unmindful of any alleged impediment brought

out by the Respondents 3 to 6 to satisfy the political masters to delay the

elections. On the contrary, despite the clear directions of this Hon'ble Court

that elections should be held on the basis of the then existing rolls and wards,

the Respondents, contrary to the said directions, served an affidavit dated

18.09.2017 seeking to keep para 87 of common judgment dated 04.09.2017 in

W.A.No.1268 of 2017 in abeyance. Such prayer is unknown within the legal

Parameters and cannot be countenanced in law. The intention of the

Respondents 3 to 8 is to defy the constitutional requirement of conducting the

elections despite removing all the impediments by this Hon'ble Court under the

order dated 04.09.2017. The Respondents 3 to 6 with an intention of

overcoming the orders of this Hon'ble Court, created barricades and obstacles

by way of abusing their executive powers by arranging to issue Ordinance No.4

dated 03.09.2017 on a Sunday.

9. I humbly submit that originally this Hon'ble Court posted for

pronouncing orders in the Writ Appeals and connected Writ Petitions on

01.09.2017. However, there was no sitting on the said date and hence the

orders were pronounced on 04.09.2017 by this Hon’ble court. Before

pronouncing the orders, the Respondents through their Counsels made a

request to defer from pronouncing the orders. However, this Hon'ble Court

rejected their request and pronounced the orders on 04.09.2017. All these

events would reflect that the Respondents have no respect towards the

implementation of the orders of this Hon'ble Court nor they have any regard to

the constitutional requirements.

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10. I humbly submit that local bodies being the voice of the people, the

constitutional requirement is that the local bodies have to function without any

break. The Hon’ble Supreme Court in the judgment reported in 2002(8) SCC

Page 237 has held that constitutional bodies cannot be kept vacant for more

than 6 months. Following the said judgment, the Hon’ble Supreme Court in

the judgment reported in 2006(8) SCC page 352 has held that Art 243 E(3)

and 243 U(3) has to be respected and followed by the State Election

Commissioner who is appointed specifically for this purpose.

11. The 1st Respondent who is the constitutional authority appointed

specifically to conduct local body elections and whose salary is paid out of

public exchequer is now indulging in all acts of forestalling the same. His

actions and conduct amounted to breach of trust and faith the constitution has

reposed on him. 1st Respondent has taken law in to his own hands and claims

that he is neither bound by orders of court or by the constitution but remain

loyal and faithful to political masters of ruling party who are his appointees. He

claims that unless his political master who has appointed him gives a green

signal he will not issue election notification for the local bodies.

12. Be that as it may the conduct of the Respondents 3 to 8 is still

worse. No allocation of funds has been made and no initial steps were taken by

them. No meeting has taken place in this regard. Interestingly on the contrary

to scuttle the election process all connived and contrived with each other and

with the help of legal brains and 6th Respondent who operates as front to

sabotage the local body elections hastly brought out an ordinance on 3.9.2017

two days after judgment was proposed to be delivered on 1.9.2017. There was

no need for the executive to pass this Ordinance on a Sunday viz. 03.09.2017

and there is no grave urgency to pass such Ordinance by executive when

Assembly was not in Session. This shows sheer abuse of power and to over

reach the court proceedings and the orders that was slated to be pronounced

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on 4.9.2017. The Respondents 3 to 6 who have appeared before this Hon'ble

Court argued through the Counsel and orders have been reserved on

01.08.2017 ought to have sought permission from this Hon'ble Court to bring

such Ordinance. The acts of the Respondents are certainly contemptuous and

overreaching the court proceedings particularly when the matters were heard

and reserved for orders. This shows there is no rule of law prevailing in the

State.

13. I state that when this Hon'ble Court posted the matter for orders

on 01.09.2017 and postponed to 04.09.2017 suddenly the Respondents 3 to 6

has brought out an Ordinance on 03.09.2017 to thwart the orders of this

Hon'ble Court. The conduct of the Respondents shows that all is not well in

the functioning of the Government and the State Election Commission who are

bent upon in overreaching the court proceedings and orders of this Hon'ble

Court.

14. I humbly submit that the 1st Respondent after the orders were

pronounced has come out with a lame excuse that by virtue of the Ordinance

issued by the Respondents 3 to 6, the election cannot be conducted. The

Ordinance dated 03.09.2017 omits the following Sections in the following Acts:-

I. Amendment to the Chennai City Municipal Corporation Act:

(a) Section 5(3) proviso omitted.

(b) Sections 46AA, 46AAA and 46AAAA omitted.

II. Amendment to the Tamil Nadu District Municipalities Act, 1920:

(a) Sections 43AA, 43AAA and 43AAAA omitted.

III. Amendment to the Madurai City Municipal Corporation Act, 1971:

(a) Section 5(3) Proviso deleted.

(b) Sections 50A, 50AA and 50AAA omitted.

IV. Amendment to the Coimbatore City Municipal Corporation Act, 1981:

(a) Section 5(3) Proviso deleted.

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(b) Sections 52AA, 52AAA and 52AAAA omitted.

V. Amendment to the Tamil Nadu Panchayats Act, 1994:

(a) Sections 28A, 28AA and 28AAA Omitted.

In the explanatory statement, the 6th Respondent has given misleading reasons

for bringing out the Ordinance. Para 3 of the explanatory statement reads as

follows:

“In view of pendency of cases in High Court and Supreme Court of

India, ordinary elections to local body could not be conducted till date.”

Such stand of 6th Respondent to introduce impugned Ordinance is ex-facie

illegal and contemptuous and has attempted to overreach the proceedings

pending before this Hon'ble Court. Hence 6th Respondent has directly and

indirectly helped the 1st Respondent to come out with lame excuse to delay the

Orders of this Hon'ble Court.

15. I humbly submit that the arguments of all the Counsels were

heard by this Hon'ble Court including the learned Advocate General and orders

were reserved by this Hon'ble Court on 01.08.2017. When the matter is sub-

judice before this Hon'ble Court particularly relating to the Local Body

Elections, Respondents 3 to 6 ought not to have issued an Ordinance enabling

them to delete the provisions from statute books. However, the effect of

omitting these provisions will have no bearing in conducting the elections as

this Hon'ble Court relying upon the judgments of the Hon’ble Supreme Court of

India has already clarified at para no.51 that the election has to be conducted

on the basis of the then existing rolls and wards. In view of the fact that the

election notification dated 25.09.2016 was issued to conduct the election on

the basis of the wards and census that was followed on the notification day and

in view of this Hon'ble Court giving a categorical direction at para no.51 to

conduct elections on the basis of the then existing rolls and also wards without

going for a delimitation, there was no justification on the part of the 1st

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Respondent to seek for clarification either from this Hon'ble Court or from the

Hon’ble Supreme Court of India. In this regard, para 57 of the order of this

Hon'ble Court makes it clear that the 1st Respondent should not yield to

situations that may be created by vested interests to postpone elections from

being held within the stipulated time. The vested interests viz. 3 to 6th

Respondents are creating an legal obstacle by way of an Executive Ordinance

which cannot come in the way of enforcing the orders of this Hon'ble Court. In

fact the Hon’ble supreme court in the judgment referred above reported in

2006(8)SCC Page 352 has held that only in a case of natural calamity the

election can be postponed and for no other reasons the election can be

postponed. Infact this Hon’ble court has followed the said judgment and has

given a clear directions in this regard to the Respondents. Therefore as held by

the Hon’ble supreme court whatever electoral rolls, wards that was available

last local body election the same could be followed. This is what reiterated in

2006(8)SCC Page 352 and by this Hon’ble court in the impugned common

judgment.

16. I humbly submit that the effect of omitting all the provisions

referred in the Ordinance has not created any legal impediment as claimed by

the 1st Respondent as reading of the common judgment of this Hon'ble Court

dated 04.09.2017 makes it abundantly clear that despite the fact that the

delimitation process are not over the constitutional requirement of conducting

the election as contemplated under Article 243-E(3) and 243-U(3) has to be

followed mandatorily. This was answered by this Hon'ble Court clearly in the

common judgment dated 04.09.2017.

17. I humbly submit that the Respondents are well aware of the order

as the order copy have been furnished to all parties on 04.09.2017 itself which

could be seen from the typed set of papers. The 1st Respondent has

deliberately waited up till 16.09.2017 and thereafter has filed petition seeking

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to keep the order in abeyance. Neither the Respondents 3 to 8 have taken any

steps to allocate funds for conduct of election nor they have raised a little finger

to take steps to ensure compliance of the orders of this Hon'ble Court. Thus,

all the Respondents consciously, willfully and wantonly have disobeyed the

common judgment of this Hon'ble Court dated 04.09.2017.

18. I humbly submit that no leniency should be shown for the

deliberate inaction on the part of the Respondents despite two Division Bench

orders namely, dated 21.02.2017 as well as 04.09.2017 besides the orders of

Supreme Court passed time and again directing them to hold elections. The

Respondent’s contemptuous act shows scant respect towards the orders of this

Hon'ble Court; towards the Constitution and democracy and this is a classical

example as to how the highest authority are defying the orders of the highest

Court in the State. The High Court being the highest court in the State and the

Hon'ble First Bench’s order being disregarded and disobeyed with impunity for

the purpose of gaining advantage for ruling party to satisfy their political

masters and this will only send a strong message that the Court’s order could

be sabotaged by virtue of abusing and misusing the executive powers. The

Court being the last resort for any litigant, if the Respondents are allowed to go

scot free despite violating the orders by not adhering to election schedule,

common man will lose his confidence on the judiciary. Hence, they should be

dealt with iron hands and should be punished with maximum sentence.

19. I state that the local body election being the lifeline of democracy,

which echoes the views of the people, the Respondents are deliberately

scuttling the establishment of such platform. The only reason is the ruling

party does not enjoy the peoples support and therefore the Respondents

political matters are against conducting the local body elections. However the

fact remains that the people of Tamilnadu are agitated and frustrated as the

entire Tamilnadu is hit with dengue fever, malaria etc. There is no proper water

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supply. Roads, infrastructure facilities, sanitary and hygienic environment are

not maintained as the local bodies have come to a standstill as there is no

people’s representative to pull them and extract the work. The saddest part is

that the Central Government funds to various local bodies are withheld as no

elections were conducted by the 1st Respondent. Thus 4000 crores of Rupees

set-apart for Tamilnadu by Central Government is going waste due to the

political games played by the Respondents and the people are the ultimate

sufferers.

20. The Respondents are bound by the orders of this Hon'ble Court

and constitutional mandates and cannot dance to the tunes of the political

masters and disrespect the intention of the constitution makers. If this being

the attitude of the Respondents even to the direction issued by the First Bench

of this Hon'ble Court, certainly a time has come that they should be taught a

lesson by sending them to jail by imposing a maximum punishment. Therefore

the Respondent has to be directed to conduct and complete the local body

elections with the then existing electoral rolls and wards which were available

when the 1st and 2nd Respondent issued Election Notifications dated

26.09.2016 for conduct of Local Body Election by the State Election

Commission on 17.10.2016 and 19.10.2016.

21. It is, therefore, prayed that this Hon’ble Court may be pleased to

direct the Respondents to conduct and complete the local body elections in the

State of Tamilnadu within the time frame fixed by this Hon’ble Court based

upon the then existing electoral rolls and wards which were available when the

1st and 2nd Respondent issued Election Notifications dated 26.09.2016 for

conduct of Local Body Election by the State Election Commission on

17.10.2016 and 19.10.2016 pending disposal of the above Contempt Petition

and pass such or further orders as this Hon’ble court may deem fit proper and

thus render justice.

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22. It is, therefore, humbly prayed that this Hon'ble Court may be

pleased to punish the Respondents for violating the common judgment of this

Hon'ble Court dated 04.09.2017 in W.A.No.1268 of 2017, W.P. No.18141 of

2017 etc., by imposing maximum punishment as contemplated under the

Contempt of Courts Act, 1971 by imprisoning them to jail and pass such

further or other orders as this Hon’ble Court may deem fit and proper to pass

in the circumstances of the case and thus render justice.

Solemnly affirmed and signed his name in : BEFORE ME

my presence at Chennai on this the 2nd

day of October 2017. ADVOCATE – CHENNAI

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