1

Before the Lokayukta, National Capital Territory of Delhi

C- 3973 of 2019

Complainant Naresh Kadyan son of Shri Om Parkash Kadyan, Chief National Commissioner,
Scouts & Guides for Animals & Birds / National Authority for Animal Welfare: OIPA – Indian
People for Animals, resident of C-38, Rose Apartment, Prashant Vihar, sector-14, Rohini, Delhi –
110085 in the matter of allegation against:

1. Secretary, Department of Higher Education, NCT of Delhi.

2. Vice Chancellor – Registrar of Dr. B. R. Ambedkar University, Delhi.
3. Secretary of Delhi Legislative Assembly.

Respectfully Showeth:

It is humbly submitted that:

The Father of Indian Constitution decorated with National awards after his demise, hence no
violation of the terms and conditions of the Bharat Ratna at the level awardees, if we prefix or
suffix Bharat Ratna with his name, same points needs to be examine legally, if any hitch then
Constitution can be amended to avoid contempt of Hon’ble Supreme Court of India.

I am in the opinion that if any decoration or National awards are being awarded posthumously,
that can be exempted and allowed under article 18 (1) of Indian Constitution, which is the only
solution to avoid further litigation’s in relation with the functioning of Dr. BR Ambedkar
University of Delhi with Bharat Ratna.

1. The petitioner Naresh Kadyan born by Jat, Cobbler by Profession, Fighter by spirit,
Activist by Mission and Humanitarian by choice, having Master of Arts in Journalism and
Mass Communication along with Post Graduate Diploma and Diploma in Footwear
Technology and Advance Course with Distinction, elected as Member on the Clothing &
Footwear Institute, London (England) as on 8-11-88.
2. The petitioner is Chief National Commissioner, Scouts & Guides for Animals & Birds /
National Authority for Animal Welfare: OIPA – Indian People for Animals, representing
United Nation affiliated OIPA in India, voluntarily retired as Technical Supervisor
(Leather), Haryana Khadi and Village Industries Board at the time of promotion before
five years under protest.
3. Article 18 (1) of Indian Constitution doesn’t defined National awards as title read with the
orders passed by the Hon’ble Supreme Court of India, besides it terms and conditions of the
Bharat Ratna prohibit the misused of this decoration, keeping in view the life time
achievements and performances of a particular person in different fields.
4. There are no clarification if National awards prefixed by any other person with the name of
awardees, after their death as Govt. of Delhi notified as Bharat Ratna Dr. B. R. Ambedkar
University as on July 29, 2008. Application under RTI Act, 2005 was moved as under:
 2

RTI Request Registration number MHOME/R/2019/52259

Public Authority Ministry of Home Affairs

Abolition of title as per article 18 of the Indian Constitution, besides it condition 10 of decoration
agreement of Padma awards, whereas Supreme Court also prohibit title as per these, hence supply
me the following information along with noting sheets:
1. Padma awards and Bharat Ratna prefixed as title by self and family members is legal, please
clarify.
2. Padma awards and Bharat Ratna prefixed as title by third party is legal, please clarify.
3. Title as SATTI, SIR, NAWAB, RANI, RAJA can be legally prefixed with the name, please
clarifies as Rani Laxmibai University and Sir Ganga Ram Hospital in Delhi on allotted land.
4. List of complaints received about abolition of title since last five years along with orders passed.
5. Padma awardee Sant Singh Chatwal convicted by American Courts of law, complaint lodged,
hence all communication made and received with noting sheets be supplied.
6. Copy of guidelines related to ban on eligibility for National awards to convicted persons.
7. Sant Singh Chatwal convicted as 3 years probation by American Courts of law also decorated
with National Rajiv Gandhi awards, he is entitled to keep said award being convicted please clarify.
8. Bharat Ratna Bhim Rao Ambedkar Institute of Telecom Training Jabalpur is legal, please
clarify along with status of complaint lodged related to pre-fixation of Bharat Ratna as title.
9. Status of degree, diploma, MoU, marks sheets, agreement decorated by Bharat Ratna Dr. B. R.
Ambedkar University being pre-fixation of National awards as title.
Ministry of Home Affairs replied vide No. 24/134/2019-Public dated 8-8-2019 as under:
“In terms of the directions of the Supreme Court of India, “the National Awards do not amount to
“titles” within the meaning of Article 18(1) of the Constitution”, and they should not be used as a
suffix or prefix to the name of the recipient in any manner whatsoever. In case of any misuse,
defaulter will forfeit the award.

5. Bharat Ratna Dr. B. R. Ambedkar University after July 29, 2008, got affiliation and
recognition, making agreements, signing memorandum of association, awarded degree and
diploma etc under the same name and style, prefixing Bharat Ratna.
6. The Petitioner along with Mrs. Sukanya Berwal along with Abhishek Kadyan & Mrs.
Suman Kadyan raised the violation of the article 18 (1) of the Indian Constitution,
breaching terms and conditions read with orders passed by the Hon’ble Supreme Court of
India, being unconstitutional Bharat Ratna Dr. B. R. Ambedkar University appointing the
Vice Chancellor under section 12 of previous Act, besides it No amendment in the
recognition – affiliation with the NAAC – UGC.
7. After processing the points raised at above said para, Govt. of Delhi placed the bill on Dated
22-8-2016, before the Legislative Assembly of Delhi for approval and same was converted in
the legislation adopting due procedure vide Notification Dated 25-11-2016.
8. The Board of Management of the Ambedkar University of Delhi discussed the above said
position in its meeting held on Dated 13-2-2017, thereafter Resolution No. 10.1 was
approved and Board of Management decision Dated 3-11-2008 continued as it was
approved.
9. The said position as explained above was conveyed to all concerned as on 21-3-2017, now
the question raised the legality of all the functions, degree, diploma, affiliation, recognition,
memorandum of association etc as committed under the unconstitutional Bharat Ratna Dr.
B.R. Ambedkar University, Delhi in between 29-7-2008 to 21-3-2017, contempt of court as
well.
 3

The above named complainant is satisfied that the aforesaid public functionary:

(i) Has abused their position, failed to perform their duties, misguiding Delhi Legislative
Assembly, placing unconstitutional bill before House, introducing the Bharat Ratna Dr.
B. R. Ambedkar Vishwavidyalaya Bill, 2007, prefixing National award as title, violating
article 18 (1) of Indian Constitution, keeping in view abolition of title.
(ii) Has failed to restore the trust of passed out students because Dr. B. R. Ambedkar
University (Amendment) Bill, 2016 placed before the House, passed and enforced since
beginning July 30, 2008.
(iii) All degree, diploma, transcripts and mark sheets awarded under name and seal of the
Bharat Ratna Dr. B. R. Ambedkar University between July 30, 2008 and March 21,
2017 can’t be treated as legal documents, unlawfully misguided passed students, played
with their sentiments and emotions, breaching their trust and believes.
(iv) The Cabinet of Ministers also failed to protect and safeguard the interest of passed
students, while approving the proposal of Dr. B. R. Ambedkar University (Amendment)
Bill, 2016.
(v) All budget allocation, expenditure, Bank transactions, Memorandum of
Understandings, Agreements etc can’t be treated as legal under the name and seal of
Bharat Ratna Dr. B. R. Ambedkar University.
(vi) The NAAC and UGC, still recognizing as Bharat Ratna Dr. B. R. Ambedkar University,
whereas Bharat Ratna omitted as title.
(vii) In exercise of the powers conferred by sub section (2) of section 12 of the Bharat Ratna
Dr. B. R. Ambedkar Vishwavidyalaya Act, 2007 (Delhi Act 9 of 2007), the Lt. Governor
of the National Capital Territory of Delhi as the Chancellor of the Dr. B. R. Ambedkar
University, Delhi, is pleased to appoint Prof. Anu Singh Lather as the Vice Chancellor
of the Dr. B. R. Ambedkar Vishwavidyalaya, Delhi, which is also illegal as I have
obtained relevant noting sheets under RTI Act.

To support the allegations the applicant relies on the following facts and is also filing an affidavit.
The applicant is prepared to swear an affidavit again before the Lokayukta if so desired. The
necessary deposit of Rs. 500/- has been made by affixing judicial stamps of the value on the
complaint.

PRAYER

I, Naresh Kadyan, Jat by birth: Cobbler by profession: Fighter by spirit: Activist by mission:
Humanitarian by choice, It is, therefore, prayed that:

1. An enquiry be made against the said public functionary for their non performance
restoring the trust of public, safeguarding the interest of passed out student, obtained
degree, diploma and mark sheets under the name and seal of the Bharat Ratna Dr. B. R.
Ambedkar University.
2. Amendment in the article 18 (1) of the Indian Constitution, clarifying the use of National
award as decorated with Bharat Ratna after the demise of awardees as posthumously.
3. Legalize the functioning, budget provisions, expenditures, degree, diploma, MoU, affiliation
and recognition of the University under the name and style of Bharat Ratna Dr. B. R.
 4

Ambedkar between its existences as on 29-7-2008 to 21-3-2017, keeping in view the article
18 (1) of Indian Constitution read with orders passed by the Court of law.
4. Necessary amendment in the recognition – affiliation of Br. B. R. Ambedkar University
with NAAC – UGC, which is not made till now.
5. Responsibilities may kindly be fixed on the tainted public servants, recovery be made as
huge amount incurred on the publication of materials, prefixing Bharat Ratna.
6. Any other orders deems fit.

Naresh Kadyan

VERIFICATION

I Naresh Kadyan son of Shri Om Parkash Kadyan resident of C-38, Rose Apartment,
Prashant Vihar, sector-14, Rohini, Delhi – 110085 hereby declare that the facts stated by me in
Para’s one to seven in the complaint are true to my personal knowledge and / or are based on
information and / or documents, and believed to be true.

Naresh Kadyan

Verified at Rohini Court this August 14, 2019.

तमसो मा ज्योततर्ग मय : अंधकार से प्रकाश की ओर चलो, बढो

Kind attention:

1. Committee on Petitions, Rajya Sabha.

2. Committee on Petitions, Delhi Legislative Assembly.
3. Leader of opposition, Delhi Legislative Assembly.
 5

Before the Lokayukta, National Capital Territory of Delhi

C- 3973 of 2019

Complainant Naresh Kadyan son of Shri Om Parkash Kadyan, Chief National Commissioner,
Scouts & Guides for Animals & Birds / National Authority for Animal Welfare: OIPA – Indian
People for Animals, resident of C-38, Rose Apartment, Prashant Vihar, sector-14, Rohini, Delhi –
110085 in the matter of allegation against:

1. Secretary, Department of Higher Education, NCT of Delhi.

2. Vice Chancellor – Registrar of Dr. B. R. Ambedkar University, Delhi.
3. Secretary of Delhi Legislative Assembly.

INDEX

1. Delhi Gazatte Notification 19-2-2019 6

2. Accreditation by NAAC prefixing Bharat Ratna s title, valid up to 9-12-2019 7-8
3. PMOPG 0290275, MINPA 00254, GNCTD 03656, PG Portals 9-11
4. Delhi Gazatte Notification 29-7-2008 prefixing Bharat Ratna as title 12
5. Delhi Gazatte Notification 22-8-2016; Bill No. 05 of 2016 13-16
6. Delhi Gazatte Notification 24-11-2016; Applicable as on wards 30-7-2008 17-19
7. AUD replied to Govt. of Delhi 20
8. AUD Notification; 21-3-2017 21
9. Ministry of Home Affairs MINHA/E/2017/00215 to Chief Secretary of Delhi 22
10. MoH reply on RTI application MHOME/R/2019/52259 23
11. Communications between AUD with Govt. of Delhi 24-25
12. Inspection of AUD records as per legal provisions under RTI Act 26-27
13. Communications on Committee on Rajya Sabha petition 28-31
14. Appeal decided by AUD 32-33
15. ID No. 1718 dated 17-6-2019 34

August 14, 2019

Delhi Naresh Kadyan
6
7
8
 9

Grievance Status for registration number: PMOPG/E/2019/0290275

Grievance Description:
It is humbly submitted that: The Father of Indian Constitution decorated with National
awards after his demise, hence no violation of the terms and conditions of the Bharat Ratna
at the level awardees, if we prefix or suffix Bharat Ratna with his name, same points needs
to be examine legally, if any hitch then Constitution can be amended to avoid contempt of
Hon’ble Supreme Court of India. We are jointly in the opinion that if any decoration or
National awards are being awarded posthumously, that can be exempted and allowed
under article 18 (1) of Indian Constitution, which is the only solution to avoid further
litigation in relation with the functioning of Dr. BR Ambedkar University of Delhi with
Bharat Ratna. 1. The petitioner Naresh Kadyan born by Jat, Cobbler by Profession,
Activist by Mission and Humanitarian by choice, having Master of Arts in Journalism and
Mass Communication along with Post Graduate Diploma and Diploma in Footwear
Technology and Advance Course with Distinction, elected as Member on the Clothing
Footwear Institute, London (England) as on 8-11-88. 2. The petitioner is Chief National
Commissioner, Scouts Guides for Animals Birds - National Authority for Animal Welfare:
OIPA - Indian People for Animals, representing United Nation affiliated OIPA in India,
voluntarily retired as Technical Supervisor (Leather), Haryana Khadi and Village
Industries Board at the time of promotion before five years under protest. 3. Article 18 (1)
of Indian Constitution doesn’t defined National awards as title read with the orders passed
by the Hon’ble Supreme Court of India, besides it terms and conditions of the Bharat
Ratna prohibit the misused of this decoration, keeping in view the life time achievements
and performances of a particular person in different fields. 4. There are no clarification if
National awards prefixed by any other person with the name of awardees, after their death
as Govt. of Delhi notified as Bharat Ratna Dr. B. R. Ambedkar University as on July 29,
2008. 5. Bharat Ratna Dr. B. R. Ambedkar University after July 29, 2008, got affiliation
and recognition, making agreements, signing memorandum of association, awarded degree
and diploma etc under the same name and style, prefixing Bharat Ratna. 6. The Petitioner
along with Mrs. Sukanya Berwal along with Abhishek Kadyan Mrs. Suman Kadyan raised
the violation of the article 18 (1) of the Indian Constitution, breaching terms and conditions
read with orders passed by the Hon’ble Supreme Court of India, being unconstitutional
Bharat Ratna Dr. B. R. Ambedkar University appointing the Vice Chancellor under
section 12 of previous Act, besides it No amendment in the recognition - affiliation with the
NAAC - UGC. 7. After processing the points raised at above said para, Govt. of Delhi
placed the bill on Dated 22-8-2016, before the Legislative Assembly of Delhi for approval
and same was converted in the legislation adopting due procedure vide Notification Dated
25-11-2016. 8. The Board of Management of the Ambedkar University of Delhi discussed
the above said position in its meeting held on Dated 13-2-2017, thereafter Resolution No.
10.1 was approved and Board of Management decision Dated 3-11-2008 continued as it was
approved. Petitioner (s) prayers that: 1. Amendment in the article 18 (1) of the Indian
Constitution, clarifying the use of National award as decorated with Bharat Ratna after the
demise of awardees as posthumously. 2. Legalize the functioning, degree, diploma, MoU,
affiliation and recognition of the University under the name and style of Bharat Ratna Dr.
B. R. Ambedkar between its existences as on 29-7-2008 to 21-3-2017, keeping in view the
article 18 (1) of Indian Constitution read with orders passed by the Court of law.
 10

Grievance Status for registration number: MINPA/E/2019/00254

Grievance Description:
It is humbly submitted that: The Father of Indian Constitution decorated with National awards
after his demise, hence no violation of the terms and conditions of the Bharat Ratna at the level
awardees, if we prefix or suffix Bharat Ratna with his name, same points needs to be examine
legally, if any hitch then Constitution can be amended to avoid contempt of Hon’ble Supreme
Court of India.
We are jointly in the opinion that if any decoration or National awards are being awarded
posthumously, that can be exempted and allowed under article 18 (1) of Indian Constitution, which
is the only solution to avoid further litigation in relation with the functioning of Dr. BR Ambedkar
University of Delhi with Bharat Ratna.
1. The petitioner Naresh Kadyan born by Jat, Cobbler by Profession, Activist by Mission and
Humanitarian by choice, having Master of Arts in Journalism and Mass Communication along
with Post Graduate Diploma and Diploma in Footwear Technology and Advance Course with
Distinction, elected as Member on the Clothing & Footwear Institute, London (England) as on 8-11-
88.
2. The petitioner is Chief National Commissioner, Scouts & Guides for Animals & Birds - National
Authority for Animal Welfare: OIPA - Indian People for Animals, representing United Nation
affiliated OIPA in India, voluntarily retired as Technical Supervisor (Leather), Haryana Khadi and
Village Industries Board at the time of promotion before five years under protest.
3. Article 18 (1) of Indian Constitution doesn’t defined National awards as title read with the orders
passed by the Hon’ble Supreme Court of India, besides it terms and conditions of the Bharat Ratna
prohibit the misused of this decoration, keeping in view the life time achievements and
performances of a particular person in different fields.
4. There are no clarification if National awards prefixed by any other person with the name of
awardees, after their death as Govt. of Delhi notified as Bharat Ratna Dr. B. R. Ambedkar
University as on July 29, 2008.
5. Bharat Ratna Dr. B. R. Ambedkar University after July 29, 2008, got affiliation and recognition,
making agreements, signing memorandum of association, awarded degree and diploma etc under
the same name and style, prefixing Bharat Ratna.
6. The Petitioner along with Mrs. Sukanya Berwal along with Abhishek Kadyan & Mrs. Suman
Kadyan raised the violation of the article 18 (1) of the Indian Constitution, breaching terms and
conditions read with orders passed by the Hon’ble Supreme Court of India, being unconstitutional
Bharat Ratna Dr. B. R. Ambedkar University appointing the Vice Chancellor under section 12 of
previous Act, besides it No amendment in the recognition - affiliation with the NAAC - UGC.
7. After processing the points raised at above said para, Govt. of Delhi placed the bill on Dated 22-
8-2016, before the Legislative Assembly of Delhi for approval and same was converted in the
legislation adopting due procedure vide Notification Dated 25-11-2016.
8. The Board of Management of the Ambedkar University of Delhi discussed the above said
position in its meeting held on Dated 13-2-2017, thereafter Resolution No. 10.1 was approved and
Board of Management decision Dated 3-11-2008 continued as it was approved.
Petitioner (s) prayers that:
1. Amendment in the article 18 (1) of the Indian Constitution, clarifying the use of National award
as decorated with Bharat Ratna after the demise of awardees as posthumously.
2. Legalize the functioning, degree, diploma, MoU, affiliation and recognition of the University
under the name and style of Bharat Ratna Dr. B. R. Ambedkar between its existences as on 29-7-
2008 to 21-3-2017, keeping in view the article 18 (1) of Indian Constitution read with orders passed
by the Court of law.
 11

Grievance Status for registration number: GNCTD/E/2019/03656

Grievance Description:
It is humbly submitted that: The Father of Indian Constitution decorated with National awards
after his demise, hence no violation of the terms and conditions of the Bharat Ratna at the level
awardees, if we prefix or suffix Bharat Ratna with his name, same points needs to be examine
legally, if any hitch then Constitution can be amended to avoid contempt of Hon’ble Supreme
Court of India.
We are jointly in the opinion that if any decoration or National awards are being awarded
posthumously, that can be exempted and allowed under article 18 (1) of Indian Constitution, which
is the only solution to avoid further litigation in relation with the functioning of Dr. BR Ambedkar
University of Delhi with Bharat Ratna.
1. The petitioner Naresh Kadyan born by Jat, Cobbler by Profession, Activist by Mission and
Humanitarian by choice, having Master of Arts in Journalism and Mass Communication along
with Post Graduate Diploma and Diploma in Footwear Technology and Advance Course with
Distinction, elected as Member on the Clothing & Footwear Institute, London (England) as on 8-11-
88.
2. The petitioner is Chief National Commissioner, Scouts & Guides for Animals & Birds - National
Authority for Animal Welfare: OIPA - Indian People for Animals, representing United Nation
affiliated OIPA in India, voluntarily retired as Technical Supervisor (Leather), Haryana Khadi and
Village Industries Board at the time of promotion before five years under protest.
3. Article 18 (1) of Indian Constitution doesn’t defined National awards as title read with the orders
passed by the Hon’ble Supreme Court of India, besides it terms and conditions of the Bharat Ratna
prohibit the misused of this decoration, keeping in view the life time achievements and
performances of a particular person in different fields.
4. There are no clarification if National awards prefixed by any other person with the name of
awardees, after their death as Govt. of Delhi notified as Bharat Ratna Dr. B. R. Ambedkar
University as on July 29, 2008.
5. Bharat Ratna Dr. B. R. Ambedkar University after July 29, 2008, got affiliation and recognition,
making agreements, signing memorandum of association, awarded degree and diploma etc under
the same name and style, prefixing Bharat Ratna.
6. The Petitioner along with Mrs. Sukanya Berwal along with Abhishek Kadyan & Mrs. Suman
Kadyan raised the violation of the article 18 (1) of the Indian Constitution, breaching terms and
conditions read with orders passed by the Honble Supreme Court of India, being unconstitutional
Bharat Ratna Dr. B. R. Ambedkar University appointing the Vice Chancellor under section 12 of
previous Act, besides it No amendment in the recognition - affiliation with the NAAC - UGC.
7. After processing the points raised at above said para, Govt. of Delhi placed the bill on Dated 22-
8-2016, before the Legislative Assembly of Delhi for approval and same was converted in the
legislation adopting due procedure vide Notification Dated 25-11-2016.
8. The Board of Management of the Ambedkar University of Delhi discussed the above said
position in its meeting held on Dated 13-2-2017, thereafter Resolution No. 10.1 was approved and
Board of Management decision Dated 3-11-2008 continued as it was approved.
Petitioner (s) prayers that:
1. Amendment in the article 18 (1) of the Indian Constitution, clarifying the use of National award
as decorated with Bharat Ratna after the demise of awardees as posthumously.
2. Legalize the functioning, degree, diploma, MoU, affiliation and recognition of the University
under the name and style of Bharat Ratna Dr. B. R. Ambedkar between its existences as on 29-7-
2008 to 21-3-2017, keeping in view the article 18 (1) of Indian Constitution read with orders passed
by the Court of law.
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34