IN THE HON’BLE HIGH COURT OF JUDICATURE AT ALLAHABAD.

Civil Misc. Writ Petition No. of 2004

(Under Article 226 of constitution of India)
(District – Agra)
Institute of Rewriting Indian History Through its Founder President, P. N. Oak.
S/O Late Shri Nagesh Krishna Oak, R/O - Plot No. 10, Goodwill Society,
Aundh, Pune – 411007 and another
VERSUS
Union of India through Secretary,
Human Resources and Development (HRD.),
Government of India, New Delhi. And others …………...Respondents
]

Sl.No Particular Dates Annexure Page No.

.
1. Dates of Events. 1-2

2. Stay Application U/S 151 of 3-7

the C.P.C.
3. Writ Petition Under Article 8- 65
226 of The Constitution
4. Association of the aforesaid society / public 1
trust having fundamental objectives along with
Income tax exemption certificate
5. Association of the aforesaid society / public 2
trust having fundamental objectives
6. Book namely The Taj Mahal is a 3
Temple Palace written by Sri P. N.
Oak,
7. Books namely Some Missing 4
Chapters of World History
8. Some Blunder Of Indian Historical 5
Research written by Sri P. N. Oak
containing his Boigraphy sketch
9. Book was first published in 1968, 2nd 6
edition on 1969, 3rd edition in 1974
10. Freedom of Information Act, 2002 7
11. Hindustan Times regarding the sign 6/7/2004 8
of maker of Taj Mahal published
12. Admission in Shahjahan’s own 9
Badshnama, the original persion
script and its english translation
publish in book written by Sri P. N.
Oak
13. Taj Mahal is a Temple Palace kept 10
with the National Archives, New
Delhi
14. Prince Aurangazab’s letter written in 11
urdu language to his father, Emperor
Shahjahana dt. July-August 1652A.D.
 15 English translation of Prince 12
Aurangazab’s letter
16 Documentary proof in support of the 13
research work on Taj Mahal identity
and authorship based on evidence.
17 Forming part of the research work on 14
Taj Mahal identity and authorship
based on evidence
18 Proof/ Evidence in support thereof 15
direct proof of its authorshipwritten
by Sri P.N. Oak
19 Carbon-14 dating of these wooden 16
doors having the details of 800 years
old
20 Particulars of the different 17
monuments regarding their false
identity
21 Photographs of Taj Mahal Deplicting 18
Hindu Religious Symbols
22 THE ANCIENT MONUMENTS 19
PRESERVATION ACT, 1904,
23 Ancient And Historical Monuments 20
And Archaeological Sites And
Remains,Act, 1951
24 The Ancient Monuments And 21
Archaeological Sites And Remains
Act, 1958 ( Act No.24 of !958)
25 Representation submitted to the 22
respondent No. 1 on the basis of the
reserch work conducted by Sri P. N.
Oak
26 Affidavit
27 Vaklatnama

Dated : 7th September, 2004

Yogesh Kumar Saxena

Advocate, High Court
(Counsel for the Petitioner)
Chamber No.139, High court, Allahabad
IN THE HON’BLE HIGH COURT OF JUDICATURE AT ALLAHABAD.
List Of Dates and Events in Choronological order
IN
Civil Misc. Writ Petition No. of 2004
(Under Article 226 of constitution of India)
(District – Agra)
Institute of Rewriting Indian History Through its Founder President, P. N. Oak.
S/O Late Shri Nagesh Krishna Oak, R/O - Plot No. 10, Goodwill Society,
Aundh, Pune – 411007 and another
VERSUS
Union of India through Secretary,
Human Resources and Development (HRD),
Government of India, New Delhi. And others …Respondents

S.N. Dates/ Year Particulars of Events as disclosed through research work

1 1155- 1158 Raja Paramdardi dav, a Jat Ruler on his behalf and on behalf of the
minister salakahan who constructed Tejoji Mahal which came in
occupation Of Raja Man Singh and remain in possession of Raja Jai
Singh when It was tken for conversion to Taj Mahal, for the purposes of
shifting the remains of Arjumand Banu( Mumtaj )W/o Emperor
Shahajahan Died In between 1629-1632 and buried at Burhanpur and
her body Exhumed after about 6 months (as disclosed in Shahajan
Badshahnama written by MullaAbdul Hameed lahori)
2 1629-1632 A.D. Arjumand Banu( Mumtaj )W/o Emperor Shahajahan Died in between
and buried at Burhanpur and her body Exhumed after about 6 months
3 18th ,December, 1633 Sahajahan issued two Farmans ( Bearing MordenNumbers R..176 and
177) to Ex- maharaja of Jaipur and Rajasthan state Arcchives at
Bikaner for Fake centaphs for descration of the original structure after
Arjumand Banu( Mumtaj )W/o Emperor Shahajahan Died in between
and buried at Burhanpur for supply of Makarana Marble and Stone
cutters for Usurpation of Temple building having the Palace And Lord
Shiva Temple with Koranic Grafts and thereby to get the Blatant Seizure
of Tejo – Mahalaya
4 1641-1668 A.D. Probable Period of the shroud deluding changeover of Hindu
Palace/Temple as mughal Monument/ Graveyard
5 1652 A.D. Aurangazab Letter showing his somsidern about need of elaborate
repairs of Taj Mahal.. If Taj Mahal was constracted in 1641 to 1668,
why Auranjab sought for illobrate repair except for changing the
authoriship of building as Mughal monument
6 1658 A.D. Emperor Shah jahan died and there after his graveyard was placed in Taj
Mahal near the graveyard of Arjumand Banu( Mumtaj )W/o Emperor
Shahajahan. It appear that koranic in graving dragged for camouflaging
Hindu building with Muslim Lattering as a hoary tredition which is
evidence Adhai- Din-Ka-opda at Ajmar which was a part of vigragharaj
Vishandeo’s palace an also at kutabminar with a legerdemain of
 Islamik carinngs on it
7 1843 A.D. The Governer Genral Lord Auckland with his lieutinant cunningham
tempered entire historical data of the arcologicaly department by
converning the authoriship of these Hindu palaces to Mughal
monument for adoptding the policy of divide and rule A deep
Conspiracy Committed By lieutenant Alexander Cunningham in
1842-1847
8 1904 A.D. The Ancient Monuments Preservation Act, 1904, tempered the
entire histrocial data of the arcologicaly department by converning the
authoriship of these Hindu palaces to Mughal monument for adoptding
the policy of “Divide and Rule”
9 1951 A.D. The Ancient And Historical Monuments And Archaeological Sites And
Remains (Declaration Of National Importance) Act, 1951 to the extend
Of declaring the ancient and historical monuments and other and
Archaeological Sites namely Taj Mahal. Fatehpur-sikiri, Agra Red Ford
, Ethmadualla and other Monuments as built by Mugal invaders
allegedly on the basis of report submitted by Then Governor General,
Lord Auckland, and young lieutenant Alexander Cunningham
conceived indigenous scheme of “Divide and Rule”and thereby
misusing the archaeological studies, be declared as ultravires to
Article 19 (1) (a), 25,26 49 And 51-A (f) (h) Constitution of India.
10 1958 AD This Hon’ble Court may future declare the provision of Ancient and
Historical Monuments and Archaeological Sites and Remains
(Declaration of National Importance) Act, 1951 (71 of 1951),
The Ancient Monuments And Archaeological Sites And Remains Act,
1958 of declaring these ancient building/ monuments preserved with
1959 such false identity with out any scientific inquiry/ investigation as
purported Mugal monuments / Graveyards as unconstitutional and void.
11 1968 AD Sri P.N.Oak written his first book titled as Taj Mahal is TEJO-
MAHALAYA : A SHIVA TEMPLE
12 1974A.D. Carbon dating test –14 conducted of the doors timber placed on the
Northern side of Taj Mahal building now remooved from its location
Towards Yamuna River at Dashahara Ghat and Basai Ghat from where
the Public could have a glance towards Shiva Temple constructed at
the top of Raja Mansingh Palace Which was in Occupation of his
grand Son Raja Jai Singh, when it was forciably taken by Emperor
Sahajahan for burial of Arjumand Banu( Mumtaj )W/o Emperor
Shahajahan Died in between and buried at Burhanpur and her body
Exhumed after about 6 months
Dated : 7th September, 2004 Yogesh Kumar Saxena
Advocate, High Court
(Counsel for the Petitioner)
Chamber No.139, High court, Allahabad
IN THE HON’BLE HIGH COURT OF JUDICATURE AT ALLAHABAD.
Civil Misc. Application No. of 2004
(Under Section 151 CPC)
In
Civil Misc. Writ Petition No. of 2004
(Under Article 226 of constitution of India)
(District – Agra)

1. Institute of Rewriting Indian History Through its Founder President, P. N. Oak.

S/O Late Shri Nagesh Krishna Oak, R/O - Plot No. 10, Goodwill Society,
Aundh, Pune – 411007
2. P. N. Oak. S/O Late Shri Nagesh Krishna Oak, R/O - Plot No. 10, Goodwill
Society, Aundh, Pune - 411007 ,Founder President, Institute of Rewriting
Indian History, Aundh, Pune – 4110071-------------Petitioner

VERSUS

1. Union of India through Secretary,

Human Resources and Development (HRD),
Government of India, New Delhi.

2. Secretary, Tourism and Archeological Department, Govt. of India,

New Delhi

3. Director General,
Archaeological Survey of India,
Government of India, Janapath, New Delhi.---------Respondents

To,
The Hon’ble the Chief Justice and his Lordships other companion Judges of the
aforesaid Court.
The humble writ petition of the abovenamed petitioner MOST
RESPECTFULLY SHOWETH AS UNDER;

1. That the full facts and circumstance of the case are given in accompanied writ
petition, it is most respectively prayed that an ad-interiem-mandamus by
appointing a facts finding committee for exposing the falsehood of the
Arceaological department regarding the historical blunder committed by them in
respect of their purported claim set-up in declaring Taj-Mahal, Red- fort Agra,
Fatahpur –Sikiri and other ancient Hindu buildings/ monuments as Muslim
monuments and truth may be disclosed to the public/citizens and students in
subject of history regarding their true authorship prior to Mughal period in
furtherance of their fundamental rights conferred to the Citizens under Article 19
 (1) (a), 25 and 26 read with49 and 51-A(f) (h) of Constitution of India and
Freedom Of Information Act, 2002.
2. That it is further prayed that an ad-interim-Mandamus directing the respondent
authorities after due Scientific investigation and facts finding inquiry report, the
respondents in particular the Archaeological Survey of India may Declare and
Notify in terms of the true history, as the Taj Mahal was not built by Shahajahan
and thereby directing the Archaeological Survey of India to remove the notices
displayed by them in the Taj Mahal premises crediting Shahjahan as its creator
and to futher desist from writing / publishing / proclaiming / propagating and
teaching about Shahjahan being the author of Taj Mahal and stop and discontinue
the free entry in Taj Mahal premises on Fridays in the week.
3. That it is further prayed that an ad-interim mandamus directing the respondent
authorities in particular Archaeological Survey of India 1)-to open the locks of
upper and lower portions of the 4 storeyed red stone building of Taj Mahal having
numbers of rooms, 2)-to remove all bricked up walls build later blocking such
rooms therein, 3)-to investigate scientifically and certify that which of those or
both cenotaphs are fake,4)-to look for a subterrance storey below the river bank
ground level, 5)-to look into after removing the room-entrance directly beneath
the basement cenotaph-chamber.6)- by removing the brick and lime barricade
flocking the doorway, 7)-to look for important historical evidence such as idols
and inscriptions hidden inside there by the Shahjahan’s orders as truth may not
make us rich but the same will make us free from superstitions and false
propoganda.
4. That it is further prayed that an ad-interim-mandamus may further be issued
declaring the provisions of The Ancient And Historical Monuments And
Archaeological Sites And Remains (Declaration Of National Importance) Act,
1951 to the extend of declaring the ancient and historical monuments and other
and Archaeological Sites namely Taj Mahal. Fatehpur-sikiri, Agra Red Ford ,
Ethmadualla and other Monuments as built by Mugal invaders allegedly on the
basis of report submitted by Then Governor General, Lord Auckland, and young
lieutenant Alexander Cunningham conceived indigenous scheme of “Divide and
Rule” and thereby misusing the archaeological studies, be declared as ultravires
to Article 19 (1) (a), 25,26 49 And 51-A (f) (h)constitution of India and this
Hon’ble Court may futher declare the provision of Ancient and Historical
Monuments and Archaeological Sites and Remains (Declaration of National
Importance) Act, 1951 (71 of 1951), The Ancient Monuments And Archaeological
Sites And Remains Act, 1958 of declaring these ancient building/ monuments
 preserved with such false graeyards identity with out any scientific inquiry/
investigation as purported Mugal monuments / graveyards as unconstitutional and
void.
5. That it is further prayed that an ad-interim mandamus on the basis of the
Research Conducted by the petitioner No.-2 as published in the different books
written by him as referred in earlier paragraphs namely 1. World Vedic Heritage,
2. The Tajmahal is a Temple Place, 3.Some Blunders of Indian Historical
Research, 4. Flowers Howlers, 5. Learning Vedic Astrology, 6. Some Missing
Chapters of World History, 7. Agra red Fort is a Hindu Building, 8.Great
Britain was Hindu Land, 9. The Taj Mahal is Tejomahalaya a Shiva Temple,
10.Who Says Akbar was Great, 11. Vedic Guide to Health, Beauty, Longevity
and Rejuvenation, 12. Islamic Havoc in Indian History Published by-HINDI
SAHITYA SADAN 2, B. D. Chambers, 10/54 D. B. Gupta Road, Karol Bagh,
New Delhi-110005, and the truth may be exposed through Scientific inventions
and temperaments to the Citizen/ Students of history by conducting the research/
excavations of the remains of Hindu monuments by the Central Government
surroundings to all such Hindu Palace/ temple and other ancient archaeological
building/ Monuments as the incidents like demolition of disputed structure at
Ayodhya may not be repeated resulting in mass destruction of the public property
shacking of public confidence under Rule Of Law in the society; Or and Any
other Direction, Which this Hon’ble Court May deem fit in the circumstances of
the case
Prayer
It is most respectively prayed that an ad-interiem-mandamus by
appointing a facts finding committee for exposing the falsehood of the Arceaological
department regarding the historical blunder committed by them in respect of their
purported claim set-up in declaring Taj-Mahal, Red- fort Agra, Fatahpur –Sikiri and
other ancient Hindu buildings/ monuments as Muslim monuments and truth may be
disclosed to the public/citizens and students in subject of history regarding their true
authorship prior to Mughal period in furtherance of their fundamental rights
conferred to the Citizens under Article 19 (1) (a), 25 and 26 read with49 and 51-A(f)
(h) of Constitution of India and Freedom Of Information Act, 2002.
1. It is further prayed that an ad-interim-Mandamus directing the
respondent authorities after due Scientific investigation and facts finding inquiry
report, the respondents in particular the Archaeological Survey of India may
Declare and Notify in terms of the true history, as the Taj Mahal was not built by
Shahajahan and restrain them from displaying the authorship of these buildings as
 constructed by Sahajahan or by any mughal Invaders thereby directing the
Archaeological Survey of India to remove the notices displayed by them in the Taj
Mahal premises crediting Shahjahan as its creator and to futher desist from
writing / publishing / proclaiming / propagating and teaching about Shahjahan
being the author of Taj Mahal and stop and discontinue the free entry in Taj Mahal
premises on Fridays in the week.
2. It is further prayed that an ad-interim mandamus directing the
respondent authorities in particular Archaeological Survey of India 1)-to open the
locks of upper and lower portions of the 4 storeyed red stone building of Taj
Mahal having numbers of rooms, 2)-to remove all bricked up walls build later
blocking such rooms therein, 3)-to investigate scientifically and certify that which
of those or both cenotaphs are fake,4)-to look for a subterrance storey below the
river bank ground level, 5)-to look into after removing the room-entrance directly
beneath the basement cenotaph-chamber.6)- by removing the brick and lime
barricade flocking the doorway, 7)-to look for important historical evidence such
as idols and inscriptions hidden inside there by the Shahjahan’s orders as truth
may not make us rich but the same will make us free from superstitions and false
propoganda.
3. It is further prayed that an ad-interim-mandamus may further be issued
declaring the provisions of The Ancient And Historical Monuments And
Archaeological Sites And Remains (Declaration Of National Importance) Act,
1951 to the extend of declaring the ancient and historical monuments and other
and Archaeological Sites namely Taj Mahal. Fatehpur-sikiri, Agra Red Ford,
Ethmadualla and other Monuments as built by Mugal invaders allegedly on the
basis of report submitted by Then Governor General, Lord Auckland, and young
lieutenant Alexander Cunningham conceived indigenous scheme of “Divide and
Rule” and thereby misusing the archaeological studies, be declared as ultravires
to Article 19 (1) (a), 25,26 49 And 51-A (f) (h)constitution of India and this
Hon’ble Court may futher declare the provision of Ancient and Historical
Monuments and Archaeological Sites and Remains (Declaration of National
Importance) Act, 1951 (71 of 1951), The Ancient Monuments And Archaeological
Sites And Remains Act, 1958 of declaring these ancient building/ monuments
preserved with such false graeyards identity with out any scientific inquiry/
investigation as purported Mugal monuments / graveyards as unconstitutional and
void.
4. It is further prayed that an ad-interim mandamus on the basis of the
Research Conducted by the petitioner No.-2 as published in the different books
 written by him as referred in earlier paragraphs namely 1. World Vedic Heritage,
2. The Tajmahal is a Temple Place, 3.Some Blunders of Indian Historical
Research, 4. Flowers Howlers, 5. Learning Vedic Astrology, 6. Some Missing
Chapters of World History, 7. Agra red Fort is a Hindu Building, 8.Great
Britain was Hindu Land, 9. The Taj Mahal is Tejomahalaya a Shiva Temple,
10.Who Says Akbar was Great, 11. Vedic Guide to Health, Beauty, Longevity
and Rejuvenation, 12. Islamic Havoc in Indian History Published by-HINDI
SAHITYA SADAN 2, B. D. Chambers, 10/54 D. B. Gupta Road, Karol Bagh,
New Delhi-110005, and the truth may be exposed through Scientific inventions
and temperaments to the Citizen/ Students of history by conducting the research/
excavations of the remains of Hindu monuments by the Central Government
surroundings to all such Hindu Palace/ temple and other ancient archaeological
building/ Monuments as the incidents like demolition of disputed structure at
Ayodhya may not be repeated resulting in mass destruction of the public property
shacking of public confidence under Rule Of Law in the society.
5. Any other Direction, Which this Hon’ble Court May deem fit in the
circumstances of the case

Dated; 7th Sepetember ,2004

Yogesh Kumar Saxena

Advocate, High Court
(Counsel for the Petitioner)
Chamber No.139, High court, Allahabad
IN THE HON’BLE HIGH COURT OF JUDICATURE AT ALLAHABAD.

Civil Misc. Writ Petition No. of 2004

(Under Article 226 of constitution of India)
(District – Agra)

1. Institute of Rewriting Indian History Through its Founder President, P. N. Oak.

S/O Late Shri Nagesh Krishna Oak, R/O - Plot No. 10, Goodwill Society,
Aundh, Pune – 411007
2. P. N. Oak. S/O Late Shri Nagesh Krishna Oak, R/O - Plot No. 10, Goodwill
Society, Aundh, Pune - 4110071. Founder President, Institute of Rewriting
Indian History, Aundh, Pune - 4110071 -----------Petitioner

VERSUS

1. Union of India through Secretary,

Human Resources and Development (HRD),
Government of India, New Delhi.

2. Secretary, Tourism and Archeological Department, Govt. of India,

New Delhi

3. Director General,
Archaeological Survey of India,
Government of India, Janapath, New Delhi.----------Respondents

To,
The Hon’ble the Chief Justice and his lordships other companion Judges of the
aforesaid Court.
The humble petition of the abovenamed petitioner MOST RESPECTFULLY
SHOWETH AS UNDER;

1. That, no other writ petition has been filed or pending on the same controversy
involved in the present writ petition before this Hon’ble Court, nor the petitioner’s
institution, namely, “ Institute for Re-writing Indian (and World) History” has received
any notice of caveat application so far in the present writ petition. The petitioner No.1
and petitioner No.2 are same person, but they are impleaded in different capacity.
2. That this writ petition is moved to re-establish the truth and cultural heritage of
our Country. This writ petition is pertaining to the world marvel, one of the Seven
Wonders of the World, namely, Taj Mahal, and other monuments authorship attributed to
Hindu Rulers, much prior to the period of Mugal Invaders. The ancient monuments and
structure are part of our tradition and culture and evidence of glorious-marvelous
architectural achievement and further to that it is a part of our heritage. Fraud upon
 history should not be perpetuated as life is evaluated in the perspective of history. For
the sake of history of heritage, these monuments should be identified, protected and
preserved properly in the right perspective with right historical records of creation and
construction of truth and realities, which includes rectifying and/ or correcting the wrong
records, notions, motivated dis-information and mis- information.
3. That this writ petition is moved in the Public Interest, for a National Cause, to
establish the truth there is no private interest or any other oblique motive, or any other
personal gain. The petitioner institution, known as Institute for Re-writing Indian
History, Thane, having registration no. F-1128 (T) is a public trust. The founder
president of the trust is Shri P.N. Oak S/o Late Shri Nagesh Krishna Oak, R/o- Plot no.
10, Goodwill Society, Aundh, Pune.411007, who has written number of books namely 1.
World Vedic Heritage, 2. The Tajmahal is a Temple Place, 3.Some Blunders of Indian
Historical Research, 4. Flowers Howlers, 5. Learning Vedic Astrology, 6. Some Missing
Chapters of World History, 7. Agra red Fort is a Hindu Building, 8.Great Britain was
Hindu Land, 9. The Taj Mahal is Tejomahalaya a Shiva Temple, 10.Who Says Akbar was
Great, 11. Vedic Guide to Health, Beauty, Longevity and Rejuvenation, 12. Islamic
Havoc in Indian History.
4. That the petitioner No. 2 is the founder President of an Institution, namely, “
Institute for Re-writing Indian (and World) History “. The aim and objective of that
institution, which is a registered society having register no. F-1128 (T) as the public trust
under the provision of Bombay Public Trust Act. Inter alia, is to re-discover the Indian
history. The monumental places of historical importance in their real and true
perspective having of the heritage of India. The true copy of memorandum of association
of the aforesaid society / public trust having fundamental objectives along with Income
tax exemption certificate under section 80-G (5) of I.T. Act, 1961 for period 1/4/2003 to
31/3/2006 are filed herewith as marked as Annexure No.1 and 2 to the writ petition.
5. That the founder-President of Petitioner’s Institution namely Shri P. N. Oak is a
National born Citizen of India. He resides permanently at the address given in case title.
The petitioner is a renowned author of 13 renowned books including the books, titled as,
“ The Taj Mahal is a Temple Place”. This petition is related to Taj Mahal, Fatehpur-
Sikiri, Red-fort at Agra, Etamaudaula, Jama- Masjid at Agra and other so called other
monuments. All his books are the result of his long-standing research and unique
rediscovery in the respective fields. The titles of his books speak well about the contents
of the subject. His Critical analysis, dispassionate, scientific approach and reappraisal of
facts and figures by using recognised tools used in the field gave him distinction through
out the world. The true copy of the title page of book namely “The Taj Mahal is a
 Temple Palace” . written by Sri P. N. Oak, the author/ petitioner No. 2 is filed as
Annexure –3 to this writ petition.
6. That the great “Kshatriya community” pride to defend their faith and the
culture of our country against foreign invasions in converting the monuments by the
foreign invaders requires a sacrificial magnanimity and moral purity in the exposure of
the truth to the public and thereby to safeguard their right of freedom of information
couched under Article 19(1) (a) is the theme behind the writing this Article and the
present Petition .The serene beauty, majesty and grandeur of the Taj Mahal, one of the
seventh wonders of the world and other monuments is still not so well known to the
world regarding the true story of its origin. The magnificent palace, which was built
earlier got converted into the Tomb .The changeover has proved a shroud deluding from
lay visitors to the researchers and the great historian Sri P.N. Oak, a co-worker of Netaji
Subhash Chandra Bose. The popular nostalgia of legendary love to get the conversion of
every Hindu Palace/Temple due to mythical attachment from fanatic raging fire
converting dazzle of leaping flames and blinding smoke should be discouraged into a
cool research regarding the origin. This is required to check a different form of terrorism
prevalent amongst the crusader of the death to the innocent victim on the psychological
level. Let us examine the scared truth about the origin of the monuments.The true copy
of the title cover of books namely “Some Missing Chapters of World History” and
“Some Blunder Of Indian Historical Research” written by Sri P. N. Oak containing the
Boigraphy sketch of identity of great author are filed as Annexure No. 4 and 5
7. That the said book, which is the ‘ research paper’ of the author on the subject
that the so-called “Taj Mahal “ is not a monument built by an Invader Emperor
Shahajahan in memory of his late wife but a Hindu Shiva Temple which was converted
into a love-memorial by a Invader Emperor. The true copy of the book was first
published in 1968, 2nd edition on 1969, 3rd edition in 1974 namly THE TAJ MAHAL IS
TEJO-MAHALAYA : A SHIVA TEMPLE is filed herewith as Annexure No.6 and large
4th edition published in 1993 shall be produced is being directed by this Hon’ble Court.
8. That the afforesaid book contaning 35 pages –booklet lists scrially numbeded
118 points of evidence with may be treated as the submission made before this Hon’ble
Court for making following demands (I) The Archaeological Survey of India (ASI) be
ordered to remove forthwish its notices at the entrance to the Taj mahal in Agra
attributting its creation to Shahjahan, since those notice in English, Hindi and Urdu are
false and baseless and quate no authority.(II) Misuse of the left – flank building as a
mosque be banned since the entire premises constitute a pre-Shahjahan Tejomhalaya
Shiv Temple complex. (III) Free entry on Fridays be ordered to be discontinued since
there being no geniune mosque in the premises why should the Government lose a day’s
 revenue! (IV) If Free entry on Fridays is not discontinued then Mondays should also be
free-entey days because that is a day of special Shiv worship. (V) The Tejmahal, its two
flanking buildings and a well being all seven-storyed they enclose over a thousand
rooms which should all be thrown open to visitorssince they are charged an entrance
free. (VI) The A.S.I. be ordered to remove its locks from those storyed and also pull
down the crude unplastered walling-up by Shahjahan of staircases, ventillators and
doorways leading to those sealed rooms. (VII) The A.S.I. be directed to search for
hidden histirical evidence such as inscriptions, divine idols etc. in those sealed rooms
and thick walls tampered with by Shahjahan. (VIII) The water in the seven-storyed wall
be pumped out to look for jettisoned valuable and inscription etc. at its bottom when
Shahjahan’s Mogul troops swooped to confiscate that temple palace complex and the
bullion, gems, gold-pitcher, the gem-studded gold-railing and the Peacock Throne inside,
owned by Raja Jaisingh of Jaipur. (IX) Beating of Nagaras (drums) at ausicious dawn
and dusk hours be resumed as of yore in the two Nagarkhanas in the premises. (X) Since
the Taj has two cenotaphs each in the name of Shahjahan and Mumtaz in two storeyes at
least one each of those two pairs of cenotaphs must be fake since Muslims don’t cut their
dead into two pieces to be buried under two cenotahs it is belived. Even the basement
conotaphs could’s be genuine because they are two storeyed higher than the Yamuna
river bed ground level. Therefore the ASI be directed to investigate which of those
cenotaphs if any are genuine or whether both are fakes or whether there are any more
fake conotaphs upto the ground level ? (XI) The Koranic graft patched along the
entrance arches be ordered to be removed since those are illagel forged imposition to be
Islamic lettering desecrating the ancient sacred Shiv shrine. (XII) Extensive repairs to
the hundreds of sealed or locked rooms in the storeyes beneath and above the marble
floor be ordered to be undertaken immediately to prevent collapes of the Tajmahal from
internal weakness. (XIII) The A.S.I. should be directed to intestigate as to who stencilled
the Arabic letter ‘Allah’ and some Englishmen’s names on the mental pinnacle shift
rooted in the dome, since no such names exits on the full scale replica of the pinnacle
shaft inlaid in the red stone courtyard on the eastern flank of the Tajmahal. (XIV) The
Muslim attendants squatting by the side of the cenotaphs should be decommissioned and
disbanded because the cenotaphs are fakes covering the ancient Shivlings. (XV) Since
the towering seven-storyed Tajmahal edifice must have been raised over an underground
basement the ASI should be directed to investigiate whether there is any such hidden,
buried basement as was the ancient Vedic practice.
9. That in 1155- 1158 A.D.It is said that Raja Paramdardi dav, a Jat Ruler on his
behalf and on behalf of the Minister Salakahan who constructed Tejoji Mahal which
came in occupation Of Raja Man Singh and remain in possession of Raja Jai Singh
 when It was tken for conversion to Taj Mahal, for the purposes of shifting the remains of
Arjumand Banu( Mumtaj )W/o Emperor Shahajahan Died In between 1629-1632 and
buried at Burhanpur and her body Exhumed after about 6 months (as disclosed in
Shahajan Badshahnama written by MullaAbdul Hameed lahori).
10. That, it is said that in 1629-1632 A.D. Arjumand Banu( Mumtaj )W/o
Emperor Shahajahan Died in between and was buried at Burhanpur and her body may
be Exhumed after about 6 months.It is submitted that 1641-1668 A.D.is probable period
of the shroud deluding changeover of Hindu Palace/Temple as mughal Monument/
Graveyard. It is submmited that in 1652 A.D. Aurangazab Letter showing his somsidern
about need of elaborate repairs of Taj Mahal.. If Taj Mahal was constracted in 1641 to
1668, why Auranjab sought for illobrate repair. It was nothing, except for changing the
authoriship of building as Mughal monument. In 1658 A.D. Emperor Shah jahan died.
Their after his graveyard was also placed in Taj Mahal near the graveyard of Arjumand
Banu( Mumtaj )W/o Emperor Shahajahan. It appear that koranic in graving dragged for
camouflaging Hindu building with Muslim Lattering as a hoary tredition, which is
evidence Adhai- Din-Ka-opda at Ajmar which was a part of vigragharaj Vishandeo’s
palace an also at kutabminar with a legerdemain of Islamik carinngs on it.
11. That in 1843 A.D., the Governer General Lord Auckland with his lieutenant
cunningham tempered entire historical data of the arcologicaly department by
converning the authoriship of these Hindu palaces to Mughal monument for adoptding
the policy of “Divide and Rule”. A deep Conspiracy Committed By Lieutenant
Alexander Cunningham in 1842-1847.
12.That in 1904 A.D., the provisons of The Ancient Monuments Preservation Act,
1904,have further tempered the entire histrocial data of the arcologicaly department by
converning the authoriship of these Hindu palaces/monuments to Mughal monument for
adoptding the policy of “Divide and Rule”
13. That in 1951 A.D., the provision of “The Ancient And Historical Monuments
And Archaeological Sites And Remains (Declaration Of National Importance) Act,
1951”are further intesified the falsehood of these Buildings by shifting the authership of
these monuments. Thus this Writ Petition is filed seeking declaration to the extend of
declaring the ancient and historical monuments and other and Archaeological Sites
namely Taj Mahal. Fatehpur-sikiri, Agra Red Fort, Ethmadualla and other Monuments as
built by Mugal invaders allegedly on the basis of report submitted by Then Governor
General, Lord Auckland, and young lieutenant Alexander Cunningham conceived
indigenous scheme of “Divide and Rule”and thereby misusing the archaeological
studies, be declared as ultravires to Article 19 (1) (a), 25,26 49 And 51-A (f) (h)
Constitution of India.
14. That this Hon’ble Court may futher declare the provision of Ancient and
Historical Monuments and Archaeological Sites and Remains (Declaration of National
Importance) Act, 1951 (71 of 1951), The Ancient Monuments And Archaeological Sites
And Remains Act, 1958 of declaring these ancient building/ monuments preserved with
such false mughal identity with out any scientific inquiry/ investigation as purported
Mughal monuments / Graveyards as unconstitutional and void.
15. That in 1968 A.D Sri P.N.Oak written his first book titled as Taj Mahal is
TEJO-MAHALAYA : A SHIVA TEMPLE. In 1974 A.D. It is submitted that in the
Carbon dating test –14 conducted of the doors timber placed on the Northern side of Taj
Mahal building now remooved from its location Towards Yamuna River at Dashahara
Ghat and Basai Ghat from where the public could have a glance towards Shiva Temple
constructed at the top of Raja Mansingh Palace Which was in Occupation of his grand
Son Raja Jai Singh, when it was forciably taken by Emperor Sahajahan for burial of
Arjumand Banu( Mumtaj )W/o Emperor Shahajahan Died in between and buried at
Burhanpur and her body Exhumed after about 6 months
16. That this book is being well accepted in India and abroad. The popular
nostalgia for legendary love has helped fan then flame of Shahajajahan’s mythical
attachment to Mumtaz into a raging fire, envoloping the taj in the dazzale of leaping
flames and blinding smoke of imaginary accounts, discouraging the cool, dispassionate
research about its origion It has raised no controversy. Since the reasons given therein
supported with documented record have proved conclusively the findings and
conclusions of the author. Thus the objective of the research conducted by the petitioner
No.2 is not to cultivate any animosity or any thing to invade the feeling of any citizen,
except the exposure of the truth to the citizen, historians and to the young generation, as
they may not be mislead by falsehood, in order to swept away by the impulse of terrorist
oriented approach of the fundamentalist under our secular democratic structural
approach in the preamble of our constitution.
17. That Hindu Palace/Temple conversion in Invader Monuments like Taj
Mahal- Invasion of our Indian Heritage by Archaeological Dept under the garb of The
Ancient Monuments And Archaeological Sites And Remains Act, 1958 ( Act No.24 of !
958)- Indian Historical Blunders – A deep Conspiracy Committed By lieutenant
Alexander Cunningham in 1842-1847.Reference collected from the books of Sri P.N.
Oak – The Taj Mahal Is A Temple palace – Some Blunder of Indian Historical Research
–Some Missing Chapters of World History- AGRA RED FORT is a Hindu building.
Published by-HINDI SAHITYA SADAN 2, B.D. Chambers, 10/54 D. B. Gupta Road,
Karol Bagh, New Delhi-110005.
18. That the freedom of speech and expression is basic to indivisible from a
democratic polity .It includes right to impart and receive information. Restriction to the
said right could be only as provided in Article 19(2) to (6) of the constitution of India.
The old dictum let the people have the truth and the freedom to discuss it and all will go
well with the Government. It should prevail. The true test for deciding the validity is
whether it takes away or abridges fundamental right of the citizens. If there were direct
abridgement of the fundamental right of freedom of speech and expression, the law
would be invalid. If the provisions of the law violate the constitutional provisions, they
have to be struck down and that is what is required to be done in the present case .It is
made clear that no provision is nullified on the ground, that the Court does not approve
the underlying policy of the enactment.
19. That the ambit and scope of “Right to Know “ along with right of conscience,
fath and Religion are conferred fundamental right under Article 19 (1)(a), 25, 26, 49, 51-
A (f) (h) of the Constitution of India; read with the provision of Freedom of Information
Act, 2002 .The right to get information in democracy is recognized all throughout and it
is a natural right flowing from the concept of democracy itself. Freedom of expression
may be necessarily included in the right of information. There is no expression with out
having an idea on the subject, regarding which the expression of an individual may be
given effect to change the existing values of ideology, which are based on the notable
extracts of certain facts. An enlightening informed citizen would undoubtedly enhance
democratic values. On one hand, we are suffering from the past prejudice of caste
predomination amongst the different section of the citizen. This country called as Arya
Varta in the ancient time was so excellent, as there was no match equal to our country on
this earth. The creation of the terminology of Aryan considering themselves to be noble
was earlier regarded the real philosopher’s touchstone to eradicate the falsehood from its
perception. However by the gradual deterioration in the standard of the good behavior,
righteousness, decency which were having the foundation of impartiality, love and
conscientiousness, there has been the complete absence of discrimination in the social
coordination. The true copy of the provision of Freedom of Information Act, 2002 is
filed herewith and marked as Annexure No. 7.
20. That truth will not make us rich, but it will certainly make us free. The wrong
historical data leads to the horror, as we have seen during the period of demolition of the
Babri Masjid. There has been number of concomitant given by the respective community
representing to the follower of two prominent religions, but the loss that we have
suffered in the shape of hatred between the two section of the society, cannot be
compensated without revealing the truth. Unfortunately, the term Hindu communalism is
more exaggerated by the fanaticism under the garb of secularism, while the Hindu
 community as a whole has always been receptive to all the religion. The question, which
is cropping its importance, is much more in relations to the question pertaining to
Invader contributions to Indian life and culture. Such facts which have been geared to
brainwash the subject of the pupil, with that of perverted history under the long spell of
foreign rule, may be distorted according to the command of the ruler and as such till date
the truth has not brought forward to the surface and is exclusively aliens to the
appeasement policy generated in order to rule the parliamentary democratic set up in our
country.
21. That the mentalities affect and paralyse the traditional heritage and provide a
loss to the integrity of our country. Our ancient ancestors namely Rana Pratap and
Chattrapati Shivaji Maharaj and Guru Govind Singh during the period of Mughal rulers
have not conceded with the terror and torture, they used in proselytization. It is very
shameful for the independent citizens to live under the false perception of character
assassination. Thus in all fairness, we may be bound to accept that although the
Britishers may pose themselves more civilized, but inspite of their so called great
insight, there is the historical blunder committed by them, while writing the Indian
history in relations to the authorship of the monuments. Invader rulers, without
exception were sadist, yet they represent themselves as just, kind and patrons of
learning. The construction is seen with all Hindu traditions, while these foreigners, who
were either Invader or crusaders have done the destruction of these constructions. These
persons were stained with all wickedness and disgraceful conduct, which is still apparent
in the society and remain prevalent during a thousand year of rampant Invader
communalism, then how we can expect that they have not demolished all the Hindu
Temple and converted them with slight modification as their monuments. The township
of Ferozabad, Tuglaqabad, Ahmedabad, and Hyderabad are falsely ascribed to that of
Sultan, though the same was belonging to our ancient Hindu Rulers. The country in
which the milk was available to every citizen without investing any money to the extent
of his requirement and consumption has now been adulterd after ruthless killings of our
cattle’s by these invaders of the public confidence. Actually “Hinduism” is nothing
representing to religious foundations, but our belief, synonymous to nationalism and
sooner it may be understood and practiced in such a manner, we may seek the protection
of our integrity by saving the population of the innocent citizens.
22. That at Dilwara Jain temple in District Shirohi, Rajasthan having the white
Marvel and the Elephants statue, there are still the sign of the atrocities committed by
these Mugal invaders having the mass destruction of the construction on the upper
portion of structure. However, since the temple lying below the surface was filled up
with the mud and earth., this Dilwara Jain Temple having identical construction as that
 of Taj Mahal and other Marvel buildings could have been saved from these invaders of
Humanities. Thus the truth may be exposed to the public that the invaders were never the
Builders of monuments, but they were rather the destroyer of our ancient cultural
heritage, which was preserved by the 85% of Hindu citizens from the time immortal. Let
Hindu be now permitted to save their temple from being converted to the Graveyards
any more by our so-called guardians of society under the appeasement policy of “Divide
and Rule”.
23. That the mankind must be satisfied with the reasonableness within reach
and the decision-making process may belong to the knowledge of the law. Thus the
reasonableness and the rationality, legality, as well as philosophically, provide colour to
the meaning of fundamental right .The concept of equality is not doctrinaire approach. It
is a binding threat, which runs through the entire constitutional text. Thus the affirmative
action may be constitutionally valid and the same cannot ignore the constitutional
morality, which embraces in itself the doctrine of inequality. It would be constitutionally
immoral to perpetuate inequality among majority .The constitution is required to kept
young energetic and alive. The attempt be endured to expand the ambit of fundamental
right. It is said that the dignity of the ocean lies not in its fury capable of causing
destruction, but in its vast extent and depth with enormous tolerance. Thus the wider the
power, the higher the need of caution and care, while exercising the power.
24. That public education is essential for functioning of the process of popular
government and to assist the discovery of truth and strengthening the capacity of
individual in participating in decision making process .The decision making process
include the right to know also and pushing the protection beyond the primary level
betrays the bigwigs desire to keep the crippled more crippled forever. The education of
spiritualism is the foundation for value based survival of human being in a civilized
society. The force and sanction hidden behind civilized society depend upon moral
value; and the morality cannot be cultivated through the falsehood of ideological barrier.
Thus the children may not be required to read such facts, which are having the
foundation of falsehood.
25. That our educational institutions are the foundation of the characteristics; on
the basis of which; the young generation will solve the problem of national solidatory
and integration. The children are taught to adhere with the truth for their existence in
future; but the alarming situation linked with the history written by the alien rule has not
only nurtured the myth amongst the independent citizens; but many monuments have
been falsely credited to the alien Invader rulers, who were driven across the Indian
borders at sword point and continued to rule our nation mercilessly without given any
 importance to the existing palace and the temple built by the inhabitant ancestors of the
rulers at the contemporary period.
26. That education is an investment made by the nation in its children for harvesting
a future crop of responsible adults productive of a well functioning society. However
children are vulnerable. They need to be valued, nurtured, caressed, and protected.
Imparting of education is State function. Thus since the human mind is not a tape
recorder, it would make a perfect reproduction letter in the society .It is said that every
State action must be informed by reason. Thus the freedom of expression, which
includes “Right to Know” may be allowed to be enjoyed by the citizen to the fullest
possible extent without putting shackles of avoidable cobweb of rules and regulations
putting restriction on such freedom. Justice has no favorite, except the truth. A reason
varies in its conclusion according to the idiosyncrasy of the individual and the times and
the circumstances, in which he thinks.
27. That the terminology of history is derived from Greek word ‘Historia’ meaning
there by an enquiry. Since the enquiry is nothing, but the same is attributed to the
different branch of knowledge. Thus the inquisitiveness is always generated in educated
mind. The history should not be guided solely on etymological terminology. The
meaning of ‘Itihas’ which is derivated from a Sanskrit word, leads to three terminology
.The first one namely ‘iti’ means such and such (a happening or event),’ha’ means
indefinitely while ‘aas’ means happened. Thus the history is chronological happening of
the different event during the past period
28. That the Student/children, the future citizens under taking the education of
Indian History studying on the misconception/ pattern of Anglo Saxon teaching, which
was meant for division of Indian society on the policy of “Divide and Rule”. There is a
important question posed, as to whether we have actually gain our independence or we
have to undertake another journey full of animosity, aggressism on account of terrorism
and fanatic ideology prevalent throughout the World of some particular religion. Thus on
account of being sentinel /Guardian at large, this is the voice of the majority of Hindu
Citizens to save our ancestral cultural heritage and thereby to give protection to our
future citizens. They have the threat of being subjected to atrocities, if the drastic step to
save the citizens from the oppression and exposure of falsehood may not be done at an
earliest time. Thus every nationalist, who has got a slightest patriotic cult in his
inhibition, has got a Fundamental Right and a Constitutional Duty to safeguard our
cultural heritage against the falsehood. Imparting of education is a State function. The
State, however, having regard to its financial and other constraints is not always in a
position to perform its duties. The function of imparting education has been, to a large
 extent, taken over by the citizens themselves. Some do it as pure charity; some do it for
protection of their Interests.
29. That Article 25 of the constitution in India secures to every person, subject of
course to public order, health and morality and other provisions of Part III, including
Article 17 freedom to entertain and exhibit outward acts as well as to propagate and
disseminate such religious belief according to his judgement and conscience for
edification of others. The right of the State to impose such restrictions as are desired or
found necessary on grounds of public order, health, and morality is inbuilt in Arts. 25
and 26 itself. Article 25(2)(b) ensures the right of the State to make a law providing for
social welfare and reforms besides throwing open of Religious institutions of a public
character to classes and sections of Citizens and any such rights of State or of the
communities or classes of the society were also considered to need with due regulation
in the process of harmonizing the various rights. The vision of the founding fathers of
the Constitution to liberate the society from blind and ritualistic adherence to mere
traditional superstitious beliefs sans reason or rational basis has found expression in the
form of Art. 17 of Constitution of India. The protection under Arts. 25 and 26 extends a
guarantee for rituals and observances, ceremonies and modes of worship which are
integral parts of religion but as to what really constitutes an essential part of religion or
religious practice has to be decided by the courts with reference to the doctrine of a
particular religion or practices regarded as parts of religion
30. That a society, where there is no moral values, there would neither be social
order nor secularism. Bereft of moral values secular society or democracy may not
survive. Almighty alone is the dispenser of the absolute justice. Thus an independent and
efficient judicial system, belong the repository of omnipotent power is always consider
as one of the basic structure of our constitution. The pre-constitutional days cannot be
countenanced as a source of law to claim any rights, when it is found to violate human
rights, dignity social equality amongst citizen. Democracy cannot survive and the
constitution cannot work unless Indian citizens are only learned and intelligent; and they
are also of moral character and imbibed the inherent virtue of human being such as truth,
love and compassion. Duty of every citizen of India is collective duty of the state.
31. That every citizen of India is fundamentally obligated to develop a scientific
temper and humanism .He is fundamentally duty bound to strive towards excellence, in
all sphere of individual and collective activity, so that the nation constantly rises to the
higher level of endeavor and achievements. Everyone, whether individually or
collectively is unquestionably under the supremacy of law. However it is true that
exaggerated devotion to the rule of benefit must not nurture fanciful doubts or lingering
suspicion and thereby destroy social defense, as the curiosity cannot be the subject
 matter of fair criticism. Thus the conclusion derived that on one hand, every citizen is
having the freedom of speech and expression so far as they do not contravene the
statutory limits and may prevail in the atmosphere with out any hindrance. Fundamental
duties and the obligation of the citizen may yet provide a valuable guide and aid to
interpretation of constitutional issues which not only required for resolving the issues but
also to provide guidance to the society. Giving a man his due, one of the basics of justice
finds reflected in right to equality .Law frowns upon such conduct thus the court accords
legitimacy to possession in due course of time.
32. That the concept of sovereignty was present from the ancient time but the
sovereignty was conferred upon an individual who is suppress the wicked and is
recognized as great resources in itself like the god of fire, air, sun, moon and religion.
The religion in the ancient time was considered as spiritualism and it was not dependent
upon any ritual ceremony, but it was considered s the knowledge in the darkness of
ignorance and injustice. The sovereignty was supposed to promote the cause of the
religion, wealth and enjoyment of life and those, who were voluptuous, malicious, mean
and low-minded, were ruined by the retributive justice. Thus the sovereignty was
considered as a destroyer of the wicked by fire; a restrainer of the wicked by storm
(Varun) and its controller. It was considered to be the dispenser of ease to the best pupil
like the moon and a replenisher of wealth. These qualities were the quality of the
sovereign power.
33. That now the sovereignty is attributed upon the three institution namely the
legislature, the executive and the judiciary. The combined effect of the three institutions
makes a democratic society. The legislature is creature like lord Brahma while the
executives like lord Vishnu may provide the welfare to the public. The judicial
institutions like lord Shiva is the dispenser of justice and is also the protector of all
subjects. The law of retributive justice wakes when the people sleep. Hence wise men
regard the law or punishment as virtue or religion.
34. That the sovereignty and the people should form three Councils, Educational,
Religious, and Administrative. One individual should not have the absolute power of
government, the sovereignty being the general president of the councils .The
qualifications of the president the presidents of separate councils are their interest in the
welfare of the country, their excellence of learning and character, and their influence
over the people. A country prospers as long as the people are righteous. Also their
welfare requires the appointment of learned educational officers, appointment of learned
men as the dignitaries of the spiritual council and of virtuous learned men as
administrators. Obedience to law is required of all.
35. That the secularism is the basic structure of constitution and as such in
absence of study of religion for generating brotherhood amongst the fellow citizens as to
provide mutual coordination and the ideology of live and let live to other is the basic
education, which cannot be said as an attempt against the secular philosophy of the
constitution .The constitution as it stands does not proceed on the “melting pot theory”
while it represents a “salad bowls”, where there is homogeneity without any obliteration
of identity . The foundation of the religion is spiritualism, which is based on trust and
confidence and an ability to strive for the good self of the other individual. The law must
be enforceable to preserve the society with out any derivation and hindrance and thus it
may not resultantly face the social catastrophe.
36. That the little Indian shall not be hijacked from the course of freedom by mob
muscle method and thereby to subtle perversion of discretion by other large Indian
“dressed in little, brief authority”. The people of our country has right to know every
public Act and the principle of finality may not be insisted upon as the maxim “interest
reipublicae ut sit finis litiun”. Wisdom and advisability of public policy may be
demonstrated in order to given effect to the statutory provisions under our constitution
thus an inquiry and investigation may be needed a complete with the opinion of the
expertise to arrive a conclusion as to whether the plurability in a society is not splited the
very object of the law through appeasement to the minority group of the citizen in order
to provide a conducive political social and legal framework with out destroying the very
fabric on the basis of which the pillar and the foundation were built in order to assimilate
the minorities with the majority.
37. That the Hon’ble court may never venture to disown its jurisdiction when the
constitution is found to be at stake and the fundamental rights of the citizen are under
fire of falsehood and thereby usurpation of the power by terrorizing for personal leisure
and pleasure through self created dogmas and rituals of particular religion at the cost of
other citizens. Thus the exposure of the falsehood may become the right of the affected
party to vanish the assertion based on unpatriotic sentimental perversity.
38. That in Bijoe Emmanuel Vs State of Kerala (1986) 3 SCC 615, the
question raised in the aforesaid case, as to whether three children who were faithful to
“Jehovah’s witnesses” may refuse to sing our national anthem or salute the national flag
of our country despite being the student in the school, where during morning assembly,
the national anthem is sung by other children. The circular issued by the Director of
Public Instruction, Kerala provided obligation of school children to sing the National
Anthem. Thus these children were expelled. The Hon’ble Supreme court while setting
aside the aforesaid order of expulsion of the children from the school was pleased to
examine, as to whether the children faithful to “Jehovah’s witnesses”, a worldwide sect
 of Christianity may be compelled against tenets of their religious faith duly recognized
and well established all over the world which was upheld by the highest court in United
States of America, Australia and Canada and find recognition in Encyclopedia
Britannica. It was held that the appellants truly and conscientiously believed that their
religion does not permit them to join any rituals except it them in their prayers to
Jehovah, their God. Though their religious beliefs may appear strange, the sincerity of
their beliefs is beyond question. They do not hold their beliefs idly and their conduct is
not the outcome of any perversity. The appellants have not asserted the beliefs for the
first time or out of any unpatriotic sentiments. Their objection to sing is not just against
the National Anthem of India. They have refused to sing other National Anthems
elsewhere. They are law abiding and well-behaved children, who do stand respectfully
and would continue to do so, when National Anthem is sung. Their refusal, while so
standing to join in the singing of the National Anthem is neither disrespectful of it, nor
inconsistent with the Fundamental Duty under Article 51 A (a). Hence no action should
have been taken against them.
39. That in a pluralistic society like India, which accepts secularism as the basic
ideology to govern its secular activities, education can include study based on “Religious
Pluralism”. Religious pluralism exclusivism and encourages inclusivism. Thus in
pluralistic society, it is necessary that there may not be any encroachment upon the
follower of other ideology. Value based education is likely to help the mission to fight
against all the kinds of prevailing fanaticism, ill will, violence, dishonesty, corruption
and terrorism in the different form Citizens by getting the protection to a certain degree
of preference to the minority on the cost of majority of citizen .The education is
permissible only on the grounds of convenience, suitability and familiarity with an
educational environment but the same should not be excessive to the substantial
departure of tolerance and based on practically not existent intolerable fanatic
ideological aggressism .
40. That the prevalent socio-economic system having the vast majority of the
people, ignorant uneducated and easily liable to be mislead may also be provided their
due legitimization in governance of their life as they repose tremendous faith in the
secularism .It is the constitutional obligation of the state to provide the justice by
emancipation of the falsehood as the commitment of Article 19 (1) (a), providing right of
expression to an individual. It may be unreasonable if we are unable to give the exact
definition of reasonableness to the people in a democratic institution .Law cannot afford
any favorite other than truth as the manifest injustice is curable in nature; rather than
incurable mediocrity over meritocracy, which cuts the root of justice. Protective push or
prop by way of reservation or classification must withstand any over generous approach
 to the section of the beneficiary, if it handles the effect of destroying another’s right to
education, more so, by pushing in a mediocre over meritorious and thereby belies the
hope of generating the social coordination.
41. That long slavery, paradoxically enough, makes the slave to look upon the very
change that bind him as his life support. This story was told to the convict in ancient
time and who was confined in the dingy cell for fifteen years. After fifteen year the
detainee was set free and he gingerly step out of the prison gate. His eyes, which were
used to the dim light wilted at the bright sunshine outside everything including traffic,
the gazing eyes were the strange look to the detainee and as such he felt terrified. He
took a long look at the outside world and thereafter he inhaled a deep breath and there
after by a sudden dash he again reached to his dog’s tether in the cell as his
imprisonment has sapped his self-confidence. This is what has happened in India.
42. That this feeling utter destitution, dejection, desperation and the loss of all
confidence is the result of our slavery, by which the Indians have forgotten their own
past history, lost freedom and obliviousness of the delights of an unfettered life thus it is
necessary to keep the flame of the truth burning in the heart of every enlightened citizen
as the majority of the public is unaware of the truth.
43. That the glory of our country may only be restored when our traditional heritage
culture may revive, when every citizen may get the rid from adulterated history. The
historical concepts, which have been distorted during the long period of slavery, may
become a task of utmost importance and urgency. An inadequate understanding on
impressionable citizen has resulted in the further accessibility in implanting the
misleading concepts and thereby breaking the heads and idols of the fellow citizen due
to the segmentation of the society in many composition.
44. That the true history must atleast be written in the contemporary language and
it should remain independent from interpolation, otherwise the very existence of our
cultural heritage may be evaporated from the sight of the future generation. The
Governor General, Lord Auckland, and young lieutenant Alexander Cunningham
conceived indigenous scheme of misusing the archaeological studies. This young
Cunnigham, an army engineer had no training in the archaeological department, he
wrote a lengthy letter dated September 15, 1842 suggesting archeological exploration in
India. This letter is reproduced on page no 246 Volume 7 journal of Royal Asiatic
Society, London, 1843 A. D. It discloses that the purpose of archeological exploration in
India is neither the study; nor preservation of historical monuments, but to use
archeology as the imperial tool to create mutual dissension and resentment between
Buddhists, Jains and other Hindu with Invaders by falsely crediting all monuments to the
 authorship to alien invaders while few may be labeled as that of being constructed by
Buddhist or Jain, but not by Hindus.
45. That the indo-saranice theory of architecture is the existence of Hindu
patrons in all medieval monuments thus it is necessary that the credit must be given to
such Hindu artists who designed the monuments. It may not be given to medieval cruelty
and fanaticism adopted by chauvinistic Invader invaders. The infidel designs on each
and every Invader mosque and tomb reveals the tolerance of Hindu citizens who were
subjected to the cruelty and terrorism from the last one thousand years. This article does
not reflect any animosity between the different section of the society but this is a
description of sum of the thought provocating a revelation in relations to the blunder
committed by the Historian on the foundation of sacrosanct concepts.
46. That the pioneer, In English daily newspaper of Lucknow it was observed that
“The Archeological survey of India reports (brought out under Alexander Cunningham)
are feeble, inane and all but useless and the Government has reasons to be ashamed of
the majority of the volume. It appears that Cunningham planted false Invader cenotaphs
inside Hindu building, inserted Koranic over writing on Hindu edifices and sponsored
the fabrication of documents to be given to Invader caretaker for conversion of the
Hindu Building like Taj Mahal, Red fort, Fatehpur Sikri, Sikandara, Etmadudullah built
by Hindu rulers to the Invader monuments. Let us begin with the dubious instance of
230-ft. high tower called as Qutub Minar to which historian claims to have been built by
Qutuubbdin Aibak from 1206-1210 A.D. The other historian claims that it was built by
his son- in- law and successor Iltmash, while other claim it to be built by Allauddin
Khilji. The fourth view is of Ferozshah Tuglaq, while the fifth view is that all these
rulers jointly or severely built the tower. Everyone knows that there is no basis for the
above assertion. But the public knows the truth by mere seeing the sight of Qutub Minar
that the same is having so many deity and temple adjoining to this monument. The true
copy of report published in Hindustan Times regarding the sign of maker of Taj Mahal
published on 6th July 2004 is filed as Annexure No. 8 .
47. That these historians may be impeached for gross dereliction of their duty
and for committing cheating upon the conscience of the public. The truth is not
amenable to all individual as no one could dare to become vigilant enough and to collect
true version about the mediaeval township of Hindu rulers. We therefore caution the
world of history not to place any faith in Anglo-Invader translations of Invader lettering
or documents made hitherto.it is submited that The number of report regarding the
authorship of Taj Mahal, Fatehpur-sikiri published in Amar Ujala on the basis of the
reserch condect by its Senior Sub-Editer Sri Bhanu Pratap Singh Resident of Shastri-
puram, Bodala Road, Sinkandra, Agra shell be produced at the time of arguments.
48. That the Later Percy Brown, James Ferguson, Sir Kenneth Clarke, Sir Bannister
Fletcher and Encyclopaedia Britannica orchestrated the same cunning tune of
Cunnigham. That resulted in firmly establishing and perpetuating a colossal
archaeological fraud which is being sedulously taught all over the world as profound
academic truth and is echoed in newspaper articles and telecasts for over a century.
Cunningham’s suggestion was obviously highly appreciated. Because when he retired
from the army as a Major General he was straightaway appointed the first archeological
surveyor of India in 1861,as director from 1862 to 1865 and as Director General from
1871 to 1885. Thus the historical data based on archeological study conducted by
Cunningham are scheming brain of notorious design regarding their vagueness and
deceptive notions. The archeological survey of India was dramatically closed from 1861
to 1865 when the two assistant of Cunningham namely J D Beglar and Carlleyle took
over the charge and prepare the list of historical monuments with fabricated historical
records. Consequently persons working around the world as the expert Invader known as
Saracenic architecture in museum became the pseudo experts unwittingly perpetuating
the fraud with the people. T he historical cities were converted to Islam and the pre
Invader edifices built according to the Vedic architecture were vanished from existence.
49. That the ancient Indian history is remarkable from the time of the epic of
Ramayana and Mahabharata. There are the evidence that their exists the Hindu palaces
having the creation of it by the marble and other precious stone. In the ancient time there
was sculpture based on our ethical and religious concepts. The cultural heritage was in
existence in the form of iron pillars, the mandate of the ruler on copper scripts and the
creation of the artistic image indicating civilization on the different religious temple of
the contemporary period. These were the valuable antiques, which were ruthlessly
destructed by the foreign invaders. The portraits of the ruler and their identification
could be seen on the rocks and coins of the relevant period, which are hidden inside the
earth due to the barbaric destruction of our Hindu heritage. The prominent place of these
heritage found are at Mohinjaddeo, Harrapa (Sind), Takshila (Punjab), Kaushambi,
Sarnath, Mathura(Uttar Pradesh), Patilaputra , Nalanda(Bihar), Rajgiri , Sanchi,
Burhotra (Madhya Bharat),Agadi, Vanvasi, Talkand and Maski(south).
50. That there has been number of articles written by foreign
visitors/delegates/diplomat and ambassadors amongst whom Magastahenes from
Domiscus (Syria) and Deoneses (Egypt) are prominent .The descirption of the great ruler
Sri Chandragupta Maurya may be found in the writing of Magasthenes. The Chinese
writer Faiyan left the glimpse of Vikramaditya period thereafter Honchong came to India
and remained here for about 15 years who has described the period of Harshvardhan
religious and social coordination. Harshvardhan was the prominent ruler of our nation.
 At the last we may get some description from the article of Alavruni who came along
with Mohammed Ghaznavi and examined the traditions of Hindu which are described in
(Tahikate hind )
51. That thus the civilization at Sindh river at Harappa has got the enormous storing
capability of the food articles which were distribute by the Hindu rulers during their
‘Anusthan’ in the different part of our country .The discovery of ‘Godam’ meant for
storage of the grains is still found in Harrapa civilization which has become a part of
Pakistan after th division of our country. It is evident that the people of the contemporary
period were having their expertise in molding the copper pots for storage of the valuable
herbal extracts meant for providing the cure from the ailments. All these cultural heritage
of our Hindu civilization has not been preserved by our archeological department.
52. That the period of destruction after reaching to the optimum heights after the
propagation of Jain religion and Buddhism, may be relate back from the period of
Ajatshatru, Nand Samrajya when Sikander invaded our country in 267 B.C. at Peshawar.
He fought a battle from King Puru near Jhelum river and due to natural calamity of
unprecedented rains, the elephant could not provide any impact upon aggressors, who
were fully equipped to fight the Guerilla battle. The defeat of King Abhishad in Kashmir
was the beginning of external invasion by the foreign invaders.
53. That during the Maurya dynasty, the King Chandragupta Maurya, who was
getting instructions from great Chanakya had successfully defeated Celucus but
subsequently he entered with a compromise with Chandragupta Maurya as a result of
which Chandragupta got eastern part of Unan namely aria, archosia, gadrosia and
paronishdi. Chandragupta Maurya subsequently married with the daughter of King of
Unan. Thus our country under the domination of the dynasty of Chandragupta Maurya
was extended up to Unan to Mysore in the south. Thus except Kashmir and Kalinga the
boundary our country was extended upto Afghanistan and Baluchistan. But
unfortunately the period of Chandragupta Maurya could not remain intact. There was the
revolt at tatshila which was suppressed during the reign of Bindusar by great ruler of our
nation namely Ashoka the great. King Ashoka fought a battle with Kalinga and in this
manner the dimension of the area, which was extended upto Baluchistan was further
extended from makaram, sindh, kutch, kyauli, swat ki vally, but Kashmir Nepal and
Assam remained in exclusion to the aforesaid domination.
54. That subsequently Great King Ashoka became the disciple of Lord Buddha and
he has started expansion to the percepts of the religion by having the affixation of the
symbolic predomination adhered with the aforesaid religion. He constructed the Ashoka
pillars from mono block of a rock. On the top of which, there was the symbolic
resemblance of four lion, while in midst, there was a chakra comprising of 24 arches and
 the Bull and the elephants scriptures were carved out in the middle of the single rock,
below which, there was the lotus in the downward directions. The symbolic resemblance
of the lotus became a tradition for construction of the temple. Thus we may find out that
wherever the lotus is evident on any monument with the scripture like the vegetable
leafs, grapes, peacock and other religious offering provided to the deity kept inside the
temple.
55. That the foundations of Invader were based on the concepts of destruction of
the existing values prevalent amongst the Buddha and Hindu religion. Although, it is
widely accepted that prior to the creation of other Religion, every one was himself
initially the follower of Hindu religion. He was initially opposed to existence of other
religious adomination. There was the preaching, that whosoever he might be, he does not
follow the Islam, then, there may be the army of Invader followers, who may terrorise
him for conversion to them. In this process if there may be the use of terrorism by
showing of it the follower of other religion may loose the confrontation in the expansion
of Invader fundamentalist then even they use to profess the aforesaid crusade. Thus after
the existence of such a drastic army of the crusaders, there was no possibility that the
other peace loving religion may still remain in existence. Unfortunately Hindu, Jain,
Buddh religion followers were dependent upon the policy of non-violence, peace and
tranquillity and under their religious philosophy i.e, the entire world is likes a family of
the different ideology.
56. That the beginning of the Invader invasion in our country starting from the
time of Mohammed Bin Quasim in 712 A.D., there was the gruesome murder committed
of King Daher and thereafter his two daughters after outraging their modesty were
handed over by Mohammed Bin Quasim to his uncle namely Abdul Abbass of Oman.
However the Invader ruler after been instigated by the daughters of the King Daher got
this Mohammed Bin Quasim death by putting him alive inside the leather of the cow for
invading the chastity of two girls prior to their offering to Sultan. This was the beginning
of destruction of our cultural heritage by these ruthless invaders. The description of it
may be seen in a book written by R. C. Mazumdar namely the ‘Arab mission of India’.
57. That Sultan Mohammed Ghaznavi robbed Somenath temple. Ultimately
after invading and defeating the different Rajput rulers for more than seventeen time
from the year of 1000 to 1026 A.D. This man was the follower of Islamic fanatism, who
destructed many temples during his aggression. Abdul Fateh Daud,a Invader ruler of
Sultan was so terrified that he offered his apology to Mohammed Ghaznavi and at the
same time Jaypal who committed the suicide instead of being surrendered before
Mohammed Ghaznavi, his son Anand Pal was also defeated near Peshawar. In the sixth
attack committed upon our nation by Mohammed Ghaznavi. Anand Pal thereafter
 associate of the King of Ujjain, Gwalior, kalingar, kannuanj, Delhi and Ajmer, but due to
the division in the army , Mohammed Ghaznaviu again defeated him and thereafter the
he attacked on the Palace of Nagarkot Kingdom. These invasions started from the year
of 1007 upto 1027 A.D. continued to remain near Sindhsagar Navnandh, Yagesghwar,
Barran, Mahram, Mathura, Kalinjar and ultimately at Katiabad due to disintegrity of the
Hindu rulers. Ultimaley Mohhamed Ghaznavi died on 30th April 1030.
58. That the journey of Shahabuddin Mohammed Gauri started from 1176 to 1178
for the victory of Multan and Kutch. He conducted so many attacks with the help of
King of Jammu upto 1186. He entered in Gujrat, but Mool Raj the King of Anhilavada
got him defeated. However in 1191, he conquered Malinga and Shar-Hind, which
included the territory of Delhi. Thus Delhi and Ajmer remained under his domination,
while he attacked at Kannuaj, Chandivada (near Etawah), Gwalior and Vijana.
Gayasuddin Mohammed Gauri died in 1102.
59. That the reason for the defeat of Rajput rulers was on account of the fact,
which is exhibited by the recital of Turk aggressors that there is the survival of the
fittest. There was no morality in the Hindu army and as such the Invader rulers defeated
them. The main reasons for the defeat were the caste system and idol worships prevalent
at the relevant time. The intellectuals were side tracked and the society was divided into
much segmentation in which Kshatriya only were considered to be the fighting class
amongst the Hindus. Hindu Religion was based on diversity of different caste, Creed,
Sects and Multiplicity of Religion The citizens were having the orthodox feeling and
they were very much living under the domination of superstitions. This was the reason
that the Hindus were subjected to the cruelty by the foreign invaders.
60. That the Kutubuddin Aibak appointed a Invader governor upon Ajmer. He
expanded the territory of Mohammed Guari to Meerut, Jhansi, Kol, and Runthambor. He
converted many temples into Invader Mosques at Gwalior and Anhilvada.
Bakhtiyaruddin Khilji invaded Bengal at the time of Kutubbuddin. There were many
rulers namely Aalathmus, Razia Sultana, Naseeruddin Mohammed, Tuglaq Khan, and
ultimately Jalaluddin Khilji came to the power. But his real nephew and son-in-law
Allauddin Khilji trapped him and killed as a traitor. He committed the murder of
Jallaluddin’s sons namely Aktali khan and Rukunniddin. This Allauddin after getting his
enemy killed became the ruler to control the governance of the occupied territory. There
was the stability in respect of the price of food grains. The cow was sold at one by third
cost of the goat during his period. However Alluaddin died in the year of 1316 A.D.
61. That the starting of Gayasuddin Tuglaq and after his death one Mohammed
Tuqlaq who was called as a symbol of many contradictions at the same time he was
intelligent and cruel while on the other hand he was a religious and lunatic but he was
 called as unfortunate idealistic who shifted his capital from Delhi to Devgiri at
Daulatabad .The successor of Mahmmaed Tuglaq was Feroz Tuglaq who developed the
government farm and made the invention for the rotation of the crops. He converted
many Hindu monuments and all these monument description is described at Fatauath- e-
ferozshahi .The cities were known as Feroza, Ferozabad, Hissar, Jaunpur and Fatehabad
during his time period. He created a army of the slaves comprising of about one lakh
eighty thousand people belonging to the inhabitant of the same place where he was the
conqueror. After the end of Tuglaq dynasty the Taimur dynasty completely vanished the
remains of Tuglaq rluers. However soon the Taimur dynasty appointed Khijr Khan as
there representative who created Syed regime. It has been said by the great German
philosopher Gete that the success and the defeat are the part of the same coin as the joy
and sorrow are reactionary and the unity is disintegrity are the reflections of the same
quality. This was also the reason that after Mohhamed tuglaq there was the extinction of
Invader dynasty and there was the beginning of Hindu rulers at Vijaynagar.
62. That the correspondent of BBC, London Times, Derspegel, New York Times
,Washington Post ,Christian Science ,Monitor Times and ‘life’ weekly’s continue to
misrepresent these Hindu Building as that of Invader origin. The freedom of expression
continues to ruthlessly suppress the truth about these historical buildings belonging to
the pre-Invader origin. These Historian have meticulously calculatively kept their
readership ignorant regarding the truth of pre–existing palaces and temple prior to
declare them the building as Invader monuments.
63. That now our government has provided the restriction for taking even the
photograph of the prominent historical buildings in India under the guise of
archeological department as to maintain the status quo regarding the falsehood created
by the historian and to avoid the alleged animosity between the majority class of the
Hindu with the minority Invader. It has been revealed by Encyclopaedias Islamia that the
Arabia itself obliterated all its past history by destroying image before the foundation of
Islam. The origin of Kaba which is the central shrine is in itself a Hindu temple
surrounded by huge shrine consisting of 360 HIndu images belonging to Indian king
Vikarmaaditya who founded them in 58 B.C. Even the word ‘Allah’ is a Sanskrit word
signifies “Mother or goddess“ while mekha (Makka) in Sanskrit signifies a sacrificial
fire of Vedic worship prevalent during the pre Islamic days. The monuments have not
only been destroyed in the peninsula of arvasthan belonging to King Vikramaditya,
which was captured by the Arabian during the Islamic invasion. The intriguing aspect of
regarding the existence of Shivalinga in Kaba shrine in Mecca is well known as sun-gay
aswad that is of black stone. It is still a misfortunate part on the majority of Hindu
Citizens that the income collected from the temples of Karnataka is distributed to about
 80% of its share to the Haze piligrimage, where there is the slaughtering of the 2500
cows and camale as that of the rituals.
64. That the poetic composition of pre Islamic Arabian poets kept in famous library
called as Makahtab-e-Sultania in Istambul in turkey contains the biographic details of
these pre Islamic construction while the second part embodies the period beginning just
after prohphet Mohammaed upto the end of Vanee- umaya dynasty resembling the
Sanskrit name of Krishnayya voice. There has been a big signboard few mile away from
Mecca banning the entry of any non Invader in the area. This signboard signifies the
period shrine was stormed and captured by the invader having their faith in Islam. The
same position is visualized at Azmer sharif where there is still the covering over the
Shivalinga for which the Islamic follower are strictly providing the vigilance as it may
not be disclosed the existence of the Temple of Lord Shiva. Thus it be go on searching
the different historical facts with the open eyes we will find that there are ample
evidence to deflate the Indo- Saracenic architecture theory bubble.
65. That there is thus a valid reason why Hindus are not in a position to produce any
documentary evidence with regard to the Hindu origin of fort. Even then we maintain
that if a systematic archaeological excavation is undertaken inside the fort and if its
dingy cellars and basements are opened and scoured they may still reveal Sanskrit
inscriptions and idols smashed and buried by Invader occupiers. In fact whatever little
and excavation has been made has resulted in the recovery of horse and elephant statues.
Yet taking things as they stand any court of law will uphold the plea that Hindus have a
valid reason for not being able to produce any documentary proof.
66. That the Hon’ble court will then ask the Anglo-Invader school to produce its
documents. That school too has not got even a shred of a document to prove that any one
or more Invader rulers built or rebuilt the fort. A hazy mention to that effect in a court
flatterer’s chronicler is no documentary proof. It is like you or we noting in our diaries
that we built the Houses of Parliament in London.
67. That the Apex court held in Ram Sharan Autyanuprasi’s case 1989 (Supp.) (1)
SCC 251/AIR 1989 S. C. 549, that men’s life is inclusive of his tradition, culture and
heritage and protection of that heritage in its full measure would certainly come within
the encompass of an expanded concept of Article 21 of the Constitution. It is the life-
mission of the petitioner to re-establish the truth with regard to the National and
Important monuments having heritage of Indian culture and values of Indian life.
68. That as per the discovery of the author Sri P. N. Oak, (contrary to the assertions
by the Aechiological Survey of India, in short ASI), the Taj Mahal is Tejomahalaya, a
Shiva Temple raised (500 years before Sahahjahana became the Mogul ruler) by Raja
 Paramar Dev’s Chief Minister, Salakshan, as per the Bateswar inscription stocked in the
Lucknow Museum.
69. That during the turbulent time of Invader invasions from 712 A. D. to 1761 A. D., the
edifice was raided plundered and desecrated a number of times. Ultimately it passed into
the hands of Raja Man Singh of Jaipur, who was a contemporary of the third generation
Mogul Emperor, Akbar. Man Singh’s grand son, Jai Singh was the ruler of Jaipur, when
Akbar’s grand son, Shahjahan ruled in Agra and Delhi.
70. That consequently, Shahjahan’s own Court Chronicler, the ‘Badshnama’, written by
his own paid Court Chronicler, Mulla Abdul Hamid Lahori, emphatically mentions (on
page 403 of vol. I, now kept in National Archives, New Delhi) that “ The mansion
knows as Raja Man Singh’s Manzil, at present owned by his grandson Jai Singh was
selected for the burial of Mumtaz and she was buried in it. The edifice kept with a dome
is a spectacular wonder monument.” The true copy of the admission in Shahjahan’s own
Badshnama, the original persion script and its english translation publish in book written
by Sri P. N. Oak i,e, Taj Mahal is a Temple Palace which is also kept with the National
Archives, New Delhi, is made Annexure –9 and 10 (The transcription of the Persian
passages in Roman script and the corresponding English translation, of relevant pages
only, which are record in chapter 2 of the said book.)
71. That another contemporary document is Prince Aurangazab’s letter to his
father, emperor Shahjahana dtd. July-August 1652 A. D. pointing out how that
“Illustrious mausoleum complex being very ancient had cracks and leaks at several
places needed extensive repairs”. Prince Aurangazab’s letter (quoted above) reporting
that the tomb-complex being very ancient had cracks and leaks in 1652 A. D. itself gives
a lie to the ASI’s notices declaring that the Taj Mahal stood brand new 1652 A. D. The
true copy of the Prince Aurangazab’s letter written in Persian Language to his father,
emperor Shahjahana dtd. July-August 1652 A. D. and english translation are marked as
Annexure-11 and 12(The transcription of the Persian passages in Roman script and the
corresponding English translation, of relevant pages only, which are record in chapter 2
of the said book.)
72. That besides the above two Invader Court records of Shahjahan’s time, the
said book of the author which runs into 360 pages with 86 photos and photocopies of
above two Invader documents another booklet titled The Taj Mahal is Tejomahalaya. A
Siva Temple presents 118 points of documentary as well as circumstantial photographic
and other historic evidences. Apart from the historical and documentary evidence, if
there are some practical considerations. Since it is claimed that Shahjahan’s great
infatuation for Mumtaz impelled him to raise a wonder edifice over her corpse the
obvious cross-question would be? -Shahjahan’s exclusive infatuation for Mumtaz is
 belied by the existence of his harem consisting over than 5000 women mentioned in
authentic history books.
73. That another question would be that if Shahjahan loved Mumtaz so deeply what
explains the total absence of any book of Shahjahan-Mumtaz love stories unlike Laila-
Maznu, Romio-Juliet romances? The fact is that Mumtaz was buried at Burhanpur, a
place 600 miles south of Agra. After 6 months the corpse is stated to have been lifted
from there and re-buried in the Taj Mahal temple palace. The true copy of the
documentary proof in support thereof forming part of the research work on Taj Mahal
identity and authorship based on evidence having direct proof of its authorshipwritten by
Sri P.N. Oak having the discription of different monuments regarding their authorship is
filed as Annexure 13, 14 and 15.
74. That the truth hidden inside the four story building known as Taj Mahal is full of
mysterious circumstances as no where in the world. There may be the fourth floor of the
graveyards of Mumtaj and Sahajahan on the third and fourth floor of the alleged Muslim
monuments. Actually, even the archeological department, while diging the adjoining
place ment for Goushala, has found the crown of the deity worship by Hindus during
pre-mughal period, but in order to avoid the further repercussion resulting in to
animosity by the Muslim fundamentalist, this fact has been subsided again inside the
earth. There has been the existence of castle surrounding the building, which can not be
there, except inside the palace ment for the Rajputana Rulers. Since the entire treasury
was given as endowment trust beneath the foundation of the temple and Lord Shiva
being the God of resembling to the sovereignty of the judicial institution, was considered
to have the over all superintendence of the expenditure incurred by the rulers and as such
the ingress and outgoes to the treasury was at the door step below the feet of the temple.
Thus while the upper story constructed through the marble stone on the third and fourth
floor was comprising of the temple of Lord Shiva, just beneath the aforesaid temple
where the visitors are allowed to reach there through the taress, was actually the treasury
chamber of Rajputana style living of Hindu Rulers.
75. That Ex- Maharaja of Jaipur has Kapad Dwara collection bearing Two orders
(FARMANS) from Sahajahan dated Dec.18, 1633 (bearing morden Numbers R.176 and
177) having the requisitioning the Tejo- Mahallyan Building from Raja Jai Singh
through blatant reward to him for fighting against Maharan Pratap Singh ,Mewar ruler
by his father and thereby got the usurpation of this Building. Subsequently Rajasthan
State archives at Bikaner preserves three Farmans address by Sahajahan to Raja Jai
Singh to supply the Marble used for Koranic Grafts from his Markana Querries, and also
the Stone cutter. The cost of the scaffolding was more than that of the cost of entire
work. These farmans were issued after about two years of death of Mumtaz, who was
 buried at Burhanpur, a place 600 miles south of Agra. After 6 months the corpse is stated
to have been lifted and there after these Farmans were issued from there and re-buried in
the Taj Mahal temple palace. The grafting Koranic superimposition lettering in the Taj-
mahal is of inferior quality and is pale white shade while rest of the existing building
was of rich yellow tint.
76. That even the rulers were guided by their Raj Guru living inside the forest meant
for providing education to princes, before admonition of the power of the sovereignty in
their hand. Thus every Hindu ruler was God fearing person and he was regarding the
Brahmins superior on the intellectual and other sacrosanct functions. Thus the existence
of the symbol like Swastik, Stars, Hooklikemark, triangle, Damru shape mark, Flowers,
Intersecting, Triangles, Trident, Three Cojoined Fish, Ball with S-Shaped inside, Four
Square, Fish, Goad, Arrow, Axe, Geomatrical Flowers and the character written in Dev
Nagri arrenged in the order of frequency are the evidence available in support of the
argument to the extend. The southest corner of the Taj –Mahal corner of the Taj garden
has an ancient royal- cattle house, from where the AMLAKH- THE TOP GOLDEN
COVERAGE TO THE DIETY has been discovered to the supreintendent of
archeaological dept. at Agra, but the matter has again subsided under the instruction of
the present Govt. officials. Even a cowshed is an incongruity in an islamic tomb.
77. That the Taj Mahal is a temple/palace of Kshatriya /Rajputana Rulers and was
built by some Jat courtier in 1155 A.D.. Lord Shiva is known as Tejo Ji by Jats still in the
western Utter Pradesh, which is resemble the nomenclature of Tejo Mahal converted in
to Taj Mahal by the efflux of time. The Bateshwar inscription originally installed in Taj
Gardens( currently preserved on the top floor in Lucknow Museum) refers to 1155 AD
costruction of Tejo- Mahalaya the raising of a “ CRYSTAL- WHITE SHIVA TEMPLE
SO ALLURING THAT LORD SHIVA ONCE ENSHRINED IN IT DECIDED NEVER
TO RETURN TO MOUNT KAILASH PARVAT- HIS USUAL ABODE”. The eaight
directional shafts in a small central circle surrounded by other circles respectively are
depicting 16 Cobras, 32 tridents and 64 lotus buds. All these motifs in multiples of 8 are
of vedic significances. Cobras , Lotuses and tridents are always associated with LORD
SHIVA TEMPLE.
78. That this tempering by Sahajahan may be in the report of Archaeogical
Survey Of India Vol. IV pages 216-217 (published in 1874), stating that a “great square
black basaltic pillar which, with the base and capital of another similar pillar”. In 1959-
1962, when sri S.R.Roa was the Archaeological Superintendent in Agra, there was a
deep crack in the wall of the central Octagonal chamber of Taj Mahal. There were two or
three marble Hindu idols discovered but the matter was hushed up and the images were
 reburied and embedded at the behest of govt..In the garden in 1973, another set of
fountains were found about six feet below the present fountains.
79. That an Englishman, Thomas Twining, records (page 191 of his book
(Travels in India- a Hundred years Ago)that in november 1794 “I arrived at the high
walls which encloses the Taj Mahal and its circumjacent buildins--. Ihave got out of the
palanquine and --- mounted a short flight of steps leading to a beautiful portal which
formed the centre of this side of the court of Elephants as the great area was called at
that time. Where are these missing Elephants standing outside the Hindu Palaces
buildings. These are burried in side the surface of this great Shiva Temple.
80. That the octagonal shape of the taj Mahal has a special Hindu significance.
Hindu alone have special names for the eaight directions, and celestial guards assigned
to them. The Taj Mahal has a trident pinnacle over the dome. The central shaft of the
trident depicts a Kalash (sacred pot) holding two bent mango leaves and the coconut.
This is a scred Hindu motif. Identical pinnacals may be seen over Hindu And Buddhist
temples over the Himalayan region.
81. That during the investigation conducted by the different journalists of daily news
papers “Amar Ujala” at Agra, as they have conducted the survey in which below the
Red stone building, there has been the stairs for taking the dip inside the holly Yamuna
river as per the Hindu tradition to offer the water to the rising sun rising from the eastern
side of the palace. These stairs are hidden inside the earth. The place was known as
Dashhera and Basai bathing Ghat for the pilgrimage coming for paying their respects to
Lord Shiva, whose idol was visible to the common men, even from outside the palace.
The building proposed by Rajputana Rulers to be constructed in black stones opposite to
the Taj Mahal was also an efforts to provide a glimpse of the temple of Lord Shiva to the
common men, which could have been seen also from the glass projecting Taj Mahal on
the upper story.
82. That neither Shahjahan nor Mumtaz could have been buried here because
this chamber is on the 4th floor above the river surface. Corpses are invariably buried in
mother-earth and never on stone floors. Consequently this so-called Mumtaz’s cenotaph
in this central octagonal chamber either covers the sacred Hindu (Vedic) Shivling itself
or the sacred spot from which the Shivling was uprooted. Shahjahan and Mumtaz must
be fake. Why should there be even one pair of fake cenotaph? And since one pair of
cenotaphs is fake the crucial question is which is the fake one. The one in the lower
chamber or upper chamber? Or does each floor contain one fake and the genuine
cenotaph alternating between Shahjahan and Mumtaz?
83. That all doors which have been found more than 800 years old through the
carbon-dating process, which have now been closed without any cogent reasons. After
 conducting the research for many years has disclosed that these doors were closed on 8th
February 1964. The true copy of the report regarding carbon-14 dating of these wooden
doors having the details of 800 years old is filed herewith as Annexure No. 16 .
84. That search was made after reading the abstract of the book written by Mr. P.N.
Oak. To the greater astonishment, when these students asked the query from some
officer of archaeological department, as to whether the three tunnels lying beneath the
structure of Red Fort, Agra are also connected with Taj Mahal below the ground floor of
the structure constructed in red stone. It was found that on the second Ground storey
beneath surface of the red building below the Taj Mahal, there are the sculpture carved
out having the statute of Lord Ganesh, and that of the other prominent God worshiped by
the Hindus, but they have been completely closed in derogation to the right conferred to
the citizens. Actually from inside the tunnels, an army having four horse ridden soldiers
in the row can pass through these tunnels from Agra Red Fort even to Fateh pur Sikri,
Taj Mahal and some of the historian claims that since at the site of Jama Masjid Agra,
since there were the great palaces in existence, prior to the pre-Mughal period, the
ingress and outgoes of the soldier entering from Red Fort, Agra was up to these palatial
building comprising of the temple inside Jama Masjid, Agra , Etmaudaulla and other
historical places at Agra. The existence of three tunnels inside Red Fort Agra is a truth as
that of the broad day light, which is situated beneath Baradari, where the execution of
the death sentence by chopping the head of the culprit was done by the Mughal rulers.
85. That this has got atleast more than 280-step downward from there.
Actually, while entering inside Red Fort , Agra one has to ride atleast about 50 meters
above to the ground situated near Yamuna river but since the surrounding having the
coverage by the ditch and by crossing the same one could get entrance inside the main
building as such the existence of the tunnels must be beneath the earth level and since
Etmaudollah is situated across the Yamuna river, while Sikandara and Fatehpur Sikri are
at a very long distance and as such these three tunnels firstly reaches to Jama Masjid
Agra , one to Taj Mahal but the existence of the third tunnels, appears to adjoining to the
road, Which is said to have been built by Sher Shah Suri, while it was ever- remain in
existence from the time, of these building constructed prior to the pre-Mughal invaders
aggression to our country by the Hindu contemporary rulers of the relevant time.
86. That the contribution in the monuments known as Taj Mahal by these invaders is
only to the extend of construction of only four Meenars, the script of Quran and closing
of the door way of main apartment from where the public may offer their gratitude to the
constructed building known as Taj Mahal having the deity of Lord Shiva (Shiv-lingi),
Nandi, Ganeshjee, and Parvatiji. Where are the remains of the maker of these buildings .
The spectator of the pathetic situation resulting in the terrorist attack on the these
 cultural Haritage belonging to Hindu citizens, who were settled in this country and were
comprising of the people coming from Purtagal, Spain, Partia, Saiberia, and other
Scavandians country of the Eourope, China, Russia. The news report Annexed here- in-
after all are the glaring example of the atrocities committed with the truth by the present
ruling political setup, which is no other than the British system based upon the theory
upon “Divide and Rule” in our Country.
87. That the Central Government has provided the grant of forty million of
Rupees to archaeological department for renovation of the ancient structure. It has been
revealed that there has been number of the gates with the flank opening from the red
stone structure building below the marble monument of Taj Mahal. The bricks have been
affixed to close these doors, but these bricks do not appears to have been manufactured
inside the brick clin in the ancient time. Then who have closed these doors which could
have been used by the rulers either for entering inside the palace or for appearing to
Yamuna River. Who are these fundamentalists behind such racket as the falsehood may
not be exposed regarding the authorship of the monuments alleged to have been
constructed by Shahajahan. Ex Vice Chancellor Prof. Agam Prasad Mathur, the great
Historian another Ex Vice- Chancellor of Gorakhpur university Prof. Dr.Pramila Asthana
have express their concern regarding the closer of these gates by the brick work. If the
impact is provided upon the red stone, then it is revealed regarding the empty wall.
Number of the people residing in the same vicinity, who have seen the shooting of the
film LEADER at Taj Mahal, in which Dilip Kumar And Vaijanti Mala have participating
the role of Actor and Actress, have seen these internal portion of building of taj Mahal.
There has been 14 rooms constructed inside there, which were the living apartment of
the rulers. The entire building of Taj Mahal is eight dimention constructed comprising of
four storeys building in the first floor and there has been 22 rooms on the ground floor.
There has been multi-story “Kuayan”(Deep Well) available from all the building for
availability of drinking water through the rope carrying the buckets. Towards the
northern side, there is the existence of ventilators from where one may look towards
Yamuna River.
88. That Fatehpur Sikri may actually be declared as the “HERITAGE CITY” in the
due course of time. There has been the existence of 2200 years old the ancient broken
statue of YAKSHA at Chrima-Shahpur. There has been the existence of 3 feet long
SHIV-LINGI , while at Sikri in village Imlabda, the old statue of Lord Vishnu more than
1100 years old has been found after excavation. There has been number of the statue
recovered, which are belonging to the period of the expansion of the Jain religion. There
has been the existence of Jain temple. Near the Tank reservoir of the water, which was
considered to be the big lake on the gateway of Fatehpur-Sikiri. There is still the
 existence of Triran and Amlaka, which indicates that there was hundred feet height
temple. The broken statute of Lord Shiva having GALE KI KANTHI, BAIJANTI
MALA, SRI VATSA MARK ON THE CHEST AND YAGYAPABIT may be still seen ,
while the head, hands and the portion below the chest has been broken by the invaders.
These all facts coupled together may convey the irrevocable conclusion regarding the
existence of the monuments of Fatehpur Sikri and associated building prior to the
Mughal period, which were ruthlessly broken by the invaders of the cultural heritage just
to propagate and expend their religion and by conversion of the weaker class of Hindu
Citizens.
89. That the great Archaeologist Shri Dharam Veer Sharma, then Superintendent of
the archaeological Department at Agra has define the meaning of these antique for re
writing the Indian history on the basis of all these circumstantial evidence, as the entire
world may become conversant, that these monuments were not been constructed by
these invaders to our ancient spiritual heritage but the existence of Fatehpur Sikri is
much prior to the period of the mughal emperors. Tuksal, Deewane-Aam, AnoopTalab,
which may find place in the book written by E.W. Smith, the great English Historian
visiting Fatehpur Sikri in 1896 and 1898 A.D.. Actually Tuksal is the castle meant for the
horse captivity, which has got the capability of drinking water and the system of
drainage, sewage may be seen to some remote place through these Drainage.
90. That the Water supply system is unique at Fatehpur Sikri. Actually, the lakes,
which have the accumulation of water storage, were expanded in an area comprising of
more than 25 square mile, but by the passage of time, this was extinguished purposely as
to abrogate the existence of great scientific way of living style by the Hindu Rulers to
the inhabitant at the relevant period of Rajputana Rulers. The existence of the ancient
building may also be seen in the different faces. There has been a conspiracy hatched by
the followers of a particulars dynasty, who invaded our country to get the extinction of
all such evidence, which may be helpful for the exposure of the truth as the foundation
of the invaders are based on the false hood.
91. That it has been disclosed during the High level Committee Meeting at Paris
during the convention of United Nation Education Science and Cultural Organisation
(UNESCO) that near Anoop Talab (Pond), there has been the ancient palatial building
and the ancient cultural activities remain in existence prior to the period of invasion by
the Mughal invaders. The historian have related them back to the existence of all such
palatial building during the period of Sikarwar, Rajput, which find support by the
research were conducted Prof. Ram Nathan historian of Rajasthan University, Jaipur and
also by Dr. Prathima Asthana Ex Vice Chancellor of Gorakhpur University.
92. That it has been stated that then Central Education Minister Nural Husan
had stoped the excavation work conducted by Aligarh Muslim University at Fatehpur
Sikri, when the broken statute were found hidden behind the earth. Prof. Agam Prasad
Mathur the Ex. vice Chancellor and the Historian of Agra University has disclosed that
Agra was the helmet, while Mathura was the real State prior to Mughal invasion. This
fact may be taken with the angle that Agra was the city surrounded by Shiva Temple of
pre Mughal dynasty period at Taj Mahal. All these facts are fully supported with the
circumstantial evidence as well as by the research work conducted by the great historian
of post independence period. The existence of Hanuman Temple may be seen at Kagarol
near the well, while Chamunda temple may remain in existence at Sultan Garhi, from
where Amlak used in Kalash of the temple has been discovered by the excavator. There
has been a lot of wealth hidden beneath the surface of the Kagarol near Fatehpur Sikri,
which has been usurp by some greedy local people constructing their residence, while
digging the plinth inside the surface. However the recovery of the antique and broken
portion of the deity and the existence of the different religious monuments are in itself a
proof regarding the great heritage. The existence of Fatehpur Sikri is on account of a
long period consistent efforts by the different sculpture and name of the Sikri was
Sacrikya, which was the place of inhibition of Jain religion philosophy by its follower
during 1000 A.D. There has been number of the broken statue of Pasarva Nath at Veer
Chhabila on the working style of Chatya Basi procedure. The sculpture found there also
relates the expesion of Jain Swetambar from Sikri to Bharatpur, much more prior to the
period of Akbar. At Bilaspur number of the statue indicating the ancient culture of
Rajput ruler, while at village Sakalpur on Agra Jalesar Road, there has been the remains
old Vishnu deity, where Hindu are still worshipping their religious God. The Shiva Lingi
has been installed at village Sakalpur, which has been inspected by the officers of
Archeological Department. All these things may required the investigation by same of
the agency and direction for the exposure of the truth my be issued to the Aercheological
Department by this Hon’ble Court.
93. That due to Superstition and the Orthodox tradition prevalent in Hindu
religion, all such more than 47 countries of the world, which remained under the
domination and expansion of Mughal period and the British period, their character
assassination was the main reason of the conquest upon these nations. If any religion is
not capable to expose the falsehood, it will perish. It may be deemed that the followers
of the Hindu religion are still living under the period of slavery. The invaders of any
country were never the builders of the monuments. The main objective hidden behind
such invasion was to snatch the wealth of the people and thereafter convert them to their
own religion. These people, who were taken from these countries were sold in the
 market of slavery just to rule upon them by destroying their cultural heritage and thereby
eroding the very foundation, on the basis of the existence of Hindu religion is dependent.
If we are still unable to expose the falsehood, the existence of the religion of the
majority of citizen is at stake. It is the question of saving our future generation.
94. That no individual can tolerate the bondage of the slavery, than how does it
become possible to get them the acceptance of the falsehood. The exposure of the truth
is not only beneficial for the growth of the country and to encourage the like citizen to
provide further contribution to construct the still greater palatial structure like Taj Mahal,
Fatehpur Sikri, Red Fort, Jama Masjid by the followers of the Hindu religion. The
construction of the temple at Dayalbagh at Agra and J. K. Temple at Kanpur are the
glaring example of the traditions of Hindu Culture. Till these monuments will be deemed
to have been constructed by these invaders who are now declared as the bitter critics of
the Hindu Ideology of the humanity, no Hindu citizens can claim, that he is living in
independent Nation.
95. That now the question arises, that if Hindu invites the animosity of the minority
by the exposure of the truth regarding the construction of these monuments by Hindu
Rulers, weather such Hindu citizens are really providing any contribution to their on
existence or to the existence of the followers of these invaders. There is no repudiation
of the truth as a single day- light may shallow the darkness by exposure of the brightness
for harmonious way of living. In case, one may feel offended by the exposure of the
truth, then there shall be the complete dis-association in the activity of these
fundamentalists. The apathy is the answer of every problem. If we start isolating these
invaders in the general esteem of the business of these fundamentalist citizens, they
themselves become followers of the truth. Thus instead of providing any discouragement
to these pious activities, every citizens, who has got the responsibility for deep rooted
integration of nation based upon our cultural heritage, every patriotic citizens may be
raising their voice against the modesty of their religion by exposing aggressive trend of
invaders, which ware based on the atrocities committed by them.
96. That the claim that Akbar built the fort is also found to be baseless because
while he is said to have demolished the fort in 1565 A.D., a murderer Adham Khan
being thrown from the terrace of a palace-apartment inside the fort in 1566 A.D. is
emphatic proof that the claim made on behalf of Akbar is as fraudulent as those made on
behalf of two other Invader sultans earlier. In fact it is also pointed out that not a single
building of Akbar’s time exists in the fort. Akbar’s son Jahangir is said to have perhaps
built a palace inside the fort here or there demolishing his own father’s palace but even
that conjecture is found to be based on mere fancy or on some idle engravings.
97. That the meticulous inquiry into the matter through the coherent and authentic
account .The exposure of the falsehood is always reconcilable with the historical event
and thus the burden of proof is always lying upon the individual denying the existing
facts. The onus will be shifted upon the authority when inconsistent anomalous and
contradictory versions about the origin of Taj Mahal may be scientifically tested upon
the yardstick of the truth. Let us begin with Badshahnama, a Shahjahan’s chronicle
which discloses that the cost of scaffolding exceeded that of the entire work done
regarding Mausoleun. Mr Narul Hasan Siddiqui books that a Hindu Palace was
commandeered to bury Mumtaz in which Shahjahan’s fifth generation ancestor Barbar
lived in Tejo Mahalaya. All these facts are to be examined through the scientific methods
in order to expose the false propaganda that the Mogul invaders have not given any
contribution for building the monuments. We may further examine that the mythical
indo Saracen architecture medieval mosques and tombs in India were built or conquered
and misused by the invaders the number of such monuments may include Mohammed
Ghaus ‘s tomb in Gwalior, Salim Chisti mausoleun in Ftahepur Sikri, Nizzamuddin
Kabar in Delhi, Moinuddin Chisti’s Makbara in Ajmer, Red fort Shicundera
Etamatudaula at Agra, Jama Masjid, Red fort Delhi, Kutub Minar in Delhi and
Sufdarjung. The disputed site of Lord Krishna temple Mathura and Vishwanath Temple
at Varanasi may also be examined not only to resolve the controversy but also to curve
out the animosity among the citizen in India on the ground of the religion.
98. That the extract of Badshahnama may be examined after getting them translated
form Persian passage in the English rendering. On page number 403 of Badshahnama it
is admitted in verse 26 to 33 that Huzurat Mumtazul Zamani whose sacred dead body
was buried in Burhanpur in a garden was brought from 600 miles after six months and
transported to Agra(Akbarabad). In the south of the great city there was a palace of Raja
Maan Singh which was owned by Raja Jay Singh known as Tejo Mahalaya (The temple
of Lord Shiva /Teji ji) And this place was selected burial of the Queen for which the
great ancestral heritage, religious sanctity was associated with Raja Jai Singh who was
compensated by offering the government land. Thus a palace was converted in a dome,
handy readymade Mausoleum. The authority of Badshahnama is the first proof regarding
the existence of the temple at the time when Huzurat Mumtazul Zamani was buried. The
similar treatment were given to the different Hindu palaces and temples by converting
them at as Mausoleum of Akbar at Shicandara and Humayun in Delhi and the Vishnu
temple to Kutub Minar by overbearing Invader fanatic potentate specially when these
monuments were constructed by Hindu Rulers.
99. That in this connection we also want to alert visitors to mediaeval buildings and
students and scholars of history not to believe in translations of Arabic and Persian
 inscriptions presented readymade to them through earlier books. We have found in very
many instances that they have been distorted in translation. For instance on the Taj
Mahal the inscriber has carved his name as Amanat Khan Shirazi (an insignificant slave
of the emperor Shahjahan). Anglo-Invader accounts have boosted this inscriber of letters
as one of the great wonder architects of the world. Similarly on Fatehpur Sikri where a
building is said to have been graced (by his presence) by Salim Chisti it is merrily
ascribed to him. The true copy of the particulars of the different monuments regarding
their false identity in respect of authorship attributed upon them as disclosed in the
scholarly research Articles Contained in the Books Written by Shri P. N. Oak are filed
herewith as marked as Annexure-No. 17
100. That we therefore advise all students of history never to take for granted the
translation of Invader inscriptions provided heretofore but get them translated de novo
whenever one has to make use of them. The whole question of the translation and
interpretation of Invader inscriptions not only in India but throughout the world must be
reopened and gone through thoroughly, for much wishful thinking has gone into
presenting them in translations to non-Invaders. In fact it would be very educative to
have an encyclopaedia for all Invader inscriptions and the misleading translations and
interpretations they have been subjected to heretofore. As an instance of a great snare in
the study of mediaeval history such exposure will be of immense educative value in
warning future researchers and students of history.
101. That once the hurdle of a false Invader claim made on Akbar’s behalf is got
over, we find that the fort that we see today in Agra, is the same which was owned by
ancient Hindu kings like Ashok and Kanishka. After Akbar there is no serious claim
made on behalf of any Invader ruler as the author of the fort. That means that the fort
that we see in Agra city today is the ancient Hindu ochre fort a colour so dear to Hindus.
In fact ochre is the colour of Hindu flag- a colour for which and under which they have
fought for their national and cultural existence and identity –a colour which has inspired
them to great deeds of valour, sacrifice, bravery, chivalry, gallantry and glory. Can that
ochre colour be ever owned by Invaders? It goes against all history and tradition.
102. That despite several centuries of Invader occupation and canards of
Invader authorship all the fort’s Hindu associations are intact. This is something
remarkable. The two thousands year history of the fort that Keene traces turns out to be
authentic. The slight hitch and doubt that he encounters gets explained away by his own
very intelligent footnote that the incident of a murderer having been flung from the
terrace of the palace inside the fort could not be possible if the fort had been destroyed a
year earlier. The lack of any coherence in the dates of starting the fort construction and
 its completion is proof of the fact that the world has been buffed about the Invader origin
of the fort.
103. That Invader accounts are unable to explain the name of any apartment, as to
who built it, when was it built, what for it was built, what its cost was and why it has an
Hindu aura about it? This is because the fort did not originally belong to the invaders
from Arabia, Iran, Turkey, Afghanistan, Khazasstan, and Uzbekstan. They were mere
intruders, conquerors, and usurpers. All this discussion should convince the reader that
the Red Fort in Agra is of hoary Hindu antiquity and is at least 2200 years old.
104. That one great tragedy of Indian history has been that while Indians remained
subdued and gagged under alien domination for over a millenium foreigners who
wielded all power in India played great havoc with Indian history merrily destroying or
distorting it at will either out of sheer cunning and cussedness or through their colossal
ignorance and wanton barbarism.
105.That In that process all mediaeval buildings which came under long Invader occupation
came to be misused as tombs or mosques. And in course of time, thanks to alien
chauvinism, court flattery and fanatic cunning, all ancient Hindu townships and building
got ascribed to Invader authorship. Thus with astounding historical naivete Ahmedabad
was, by its sheer name, assumed to have been founded by Ahmedshah, Tughlaqabad by
Tughlaq Shah and Ferozabad by Ferozshah.
106. That If one is to be guided by such puerile logic and shallow historical
scholarship then one will have to conclude that the city of Allahabad in the state of Uttar
Pradesh must have been founded by the Invader God Allah himself. This is with regard
to mediaeval townships. But even for mediaeval buildings the same nonchalant,
nondescript method is followed. Thus it is blatantly stated that if a building is known as
Salimgarh it must have been built by or for Sheikh Salim Chisti (emperor Akbar’s
fancied spiritual preceptor) or Prince Salim (Akbar’s heir apparent)or some other Salim.
Likewise if a building is called Jahangiri Mahal it is, by that very token insisted that it
must have been built by Prince Salim after ascending the throne as Jahangir. Such
superficial derivations and conclusions about authorship make nonsense of all historical
research methodology.
107. That During nearly 1100 years of alien rule in India most of her history has
been distorted or destroyed. All massive, majestic and alluring historic Hindu
constructions in India, from Kashmir to Cape Comorin ,have got ascribed to alien
Invader invaders such as Turks, Afghans,Iranians ,Arabs, Abyssinians and Moguls out
of sheer usurpation or conquest. Such misappropriated constructions include forts,
palaces, mansions, sera’s, roads, bridges, wells, canals and even road- side mile-pillars.
Misuse of a colossal number of Hindu temples, palaces and mansions as tombs and
 mosque for several centuries has misled many generations of the publics, tourists,
students and scholars of history all over the world into believing that those buildings
were originally commissioned by the Invaders.
108. That the intelligentsia of Hindusthan has been somewhat slow in assimilating
that finding is a measure of the havoc that history causes in the minds of a subject people
by making it impervious even to logic and legal proof. While warrior -patriots like Rana
Pratap and the great Chhatrapati Shivaji spill their purple blood to emancipate the land
and its people should it not be the patriotic duty of historians to spill at least some blue-
black ink for an academic re-conquest of occupied buildings falsely ascribed to alien
conquerors?
109. That there was E. B. Havell, a great architect, and one endowed with deep
insight. Havell has debunked the claim that the Taj Mahal is the product of any non-
Hindu architectural style. In discussing the architecture of the Taj Mahal and the claim of
some historians that an Italian named Veroneo may have been its designer, Mr. Kanwar
Lal quotes Mr.Havell thus: “So if Veroneo was so deeply versed in Indian craft tradition
that he could design a lotus dome after the rules laid down in the Shilpa Shastras, the
dome itself, built by Asiatic craftsmen would not have been his. The dome of Taj at Agra
and the dome of Ibrahim’s tomb (in Bijapur) both are constructed on the same principles.
They are nearly of the same dimensions, and a fact unnoticed by Fergusson and his
followers, the contours of both correspond exactly, except that the lotus crown of the Taj
at Agra tapers more finely and the lotus petals at the springing of the dome are inlaid
instead of being sculptured. The Taj Mahal is, infact, exactly such a building as one
would expect to be created in India …by a group of master builders inheriting the
traditions of Buddhist and Hindu buildings. The plan which consists of a central dome
chamber surrounded by four small domed chambers, follows the plan of an Indian
pancharatna, or “five jewelled” temple. Its prototype as have shown elsewhere is found
in the Buddhist temple of Chandi Sewa in Java and in the sculptured stupa shrines of
Ajanta. Neither Shahjahan nor his court builders, much less an obscure Italian
adventurer can claim the whole merit of its achievements.
110. That now as such, Mr.Havell in his assertion is very clear that the Taj Mahal is
built in the ancient Indian, Hindu style and none of Shahjahan’s contemporaries could
design or conceive of it. We regret that Mr. Havell was unaware of the admission in
Shahjahan’s own official chronicle, The Badshahnama, that the Taj Mahal is an ancient
Hindu mansion. Had that confession come to light in his time he would have rejoiced to
find his architectural conclusion fully corroborated by history, and he would then have
been acknowledged as an authority on Indian architecture far superior to Percy Brown or
Fergusson.
111. That Like all other so called Invader tombs i.e. Hindu buildings used by them
first as residences and later as burial places the Taj Mahal too is not a single tomb but an
ancient Hindu mansion reduced to an Islamic burial ground. Besides Mumtaz, Shahjahan
himself lies buried by her side. But that is not all. There are two other graves in the same
precincts.
112. That Mr Kanwar lal (P. 69 The Taj by Kanwar Lal, ibid.) observes. “At the
other end of the Jilokhana, towards the east there are again two buildings These are the
tombs of Satunnisa (Khanam) who was a favourite attendant of Mumtaz Mahal and who
was entrusted with the task of looking after the temporary tomb of Mumtaz Mahal at
Burhanpur. Similar is the tomb of Sarhandi Begum, another of Shahjahan’s queens. The
two structures are built exactly the alike.”
113. That the Satunnisa Khanam’s tomb consists of a high octagonal plinth,
round a central octagonal mortuary chamber. That Taj is based on good authority, but the
special assignment to her of this particular tomb has no better foundation than popular
belief. That shows that like every other detail about the Taj Mahal legend even the
Satunissa Khanam tomb is a concoction. All such tomb like mounds were erected in
usurped Hindu mansions so that Hindus may not reclaim and re use those buildings. The
Invaders knew of the Hindu weakness of not disturbing or reclaiming sepulchral sites.
So, erecting false oblong grave like mounds was like posting a strong military contingent
or planting a scarecrow, which cost practically nothing. It was a simple device a strategic
totem to claim Hindu buildings for Islam and it worked admirably.
114. That It is sometimes innocently asked by history teachers that if the Taj
Mahal had existed centuries before Shahjahan, how is it there are no earlier references to
it. There are three answer to the question. Firstly, the Taj Mahal being then the palace
and not the monument open for public inspection as it now is, used to be closely
guarded. It was accessible only to the elite and then only on invitation or conquest. As
such one cannot except the same prolific references to it as a tourist attraction that one
comes across in these days of publicity and modern communications. The second answer
is that ancient and mediaeval India teemed with mansions, palaces and temples of
bewildering and bewitching variety, so much so that being all very spectacular, one
could not be distinguished from another by mere description. Despite such very good
reasons for not expecting any identifiable details in earlier records of what is at present
known as Taj Mahal, luckily, Babur, the founder of the Mogul dynasty in India, who was
the great great grandfather of emperor Shahjahan, has left us a disarming and
unmistakable description of the Taj Mahal, if only we have the inclination and insight to
grasp it. So our third answer to the question why no mention is found in earlier
chronicles of the Taj Mahal and other buildings is that though many a time there is a
 clear mention of such buildings, our senses benumbed by traditional tutoring fail to
grasp their significance. Such is the case with the Taj Mahal.
115. That the rampant corruption was prevalent during the Mogul time and there
were large percentage of unauthorized profits of innumerable middle men thus there was
no money to raise a cenotaph in the ground floor in octagonal chamber by covering them
with costly mosaic stones to match with the palace flooring and barricading the hundred
of rooms, ventilators staircases, doorways, balconies and corridor. There exist a seven-
storey marble Tejo Mahalaya Hindu temple palace complex. The seven storey massive
girth in its lofty gateways and arches necessitates the removal of stone pitching and as
such Badshahnama discloses the expenditure incurred in scaffolding of these Hindu
complexes and in engraving the Koran on the walls of edifice. The great French
merchant visitor tavernier testimony too fully corroborates the aforesaid conclusion. Let
us examine his testimony introduce in Maharashtreeya Jnyankosh. “Jean Baptiste
Tavernier, a French jeweler, toured India for trade between 1641 and 1668 A.D. His
travel account is mainly devoted to commerce. He used to sojourn at Surat and Agra
(while in India). He visited all parts of India, including Bengal, Gujrat, Punjab, Madras,
Karnatak, etc. He owned a vehicle .He had to spend Rs. 600 for the cart and pair of
bullocks. ‘The bullocks used to cover 40 miles a day for two months at a stretch. Four
days were enough for the journey from Surat to Agra or Golcunda and the expense used
to be between Rs. 40 and Rs.50. The roads were as good as Roman highways. European
traveler’s felt inconvenienced in Hindu territories for want of meat, which was freely
available in Invader dominions. A good postal system was in vogue. Both the town –folk
and the government used to provide protection against highway robbery’…is the kind of
information Travernier has recorded (in his book titled Travels in India). Not being
learned, he has not recorded much except where wealth and commerce was concerned.
116. That the other important piece of evidence arises from some chance digging
conducted in the Garden in front of the marble edifice early in the year 1973 A.D. It so
happened that the fountains developed some defect .It was therefore thought advisable to
inspect the main pipe that lay imbedded underneath. When the ground was dug to that
level some hollows were noticed going down to another five feet. Therefore the ground
was dug to that depth. And to the utter surprise of all there lay at that depth another set of
fountains hitherto unknown. What appeared more significant was that those fountains
are aligned to the Taj Mahal, decisively indicating that the present building existed even
before Shahjahan. Those hidden fountains could have been installed neither by
Shahjahan not his successors, the British. Therefore they were of the pre-Shahjahan era.
Since they were aligned to the Taj Mahal building it followed ipso facto that the building
too pre-dated Shahjahan. This piece of evidence too therefore clinches the issue in
 favour of our conclusion that Shahjahan only commandeered an ancient Hindu temple –
palace for Mumtaz’s burial.
117. That the archaeology officer, who supervised that digging, was Mr. R. S.
Verma, a conservation assistant, who made another chance discovery. Once while
strolling staff-in-hand on the terrace near the so-called mosque and the circular well on
the western flank of the marble edifice, Mr. Verma detected a hollow sound coming
from below the floor where his staff hit the terrace. He had a slab covering that spot
removed and to his surprise that was an ancient opening, apparently sealed by
Shahjahan, to a flight of about 50 steps reaching down into a dark corridor. The broad
wall under the terrace was apparently hollow. From this it is clear that the corresponding
spot on the eastern terrace also hides a similar staircase and corridor, at its bottom. And
God only knows how many more such walls, apartments and stories lie sealed, hidden
and unknown to the world. Thus also incidentally points to the sorry state of research
with respect to the Taj Mahal. Nobody seems to have done neither any archaeological
investigation in the grounds of the Taj Mahal nor conducted a diligent academic study of
the whole issue. Apparently extraneous political and communal considerations have
inhibited historians and archeologists from conducting any meaningful research into the
origin of Taj Mahal. Such Academic cowardice is highly reprehensible.
118. That Naturally when chance alien visitors like Peter Mundy visit such sites
undergoing extensive superficial changes his observing that “the building is begun…. …
( and ) is prosecuted with extraordinary diligence “ is not wrong .He couldn’t visualise
that some generations after him posterity would be bluffed into believing that the Taj
Mahal complex was raised by Shahjahan himself .Travernier and Peter Mundy could
not possibly visualize such a falsification of history and could not be more explicit. We
ourselves visiting some building as chance visitors wouldn’t be more explicit. For
instance if we were to visit Bombay or London at a time when somebody has acquired
somebody else’s mansion and has enclosed it in massive scaffolding to renovate it for his
own purpose we won’t dare or care to ask him how he acquired the building, for how
much, from whom, what changes he proposed to make, and spend how much over it .We
would simply refer to it as his building. Such inquiries are all the more impossible when
a wide hiatus of language, race, culture authority, and wealth separates the two. Peter
Mundy also fortunately records the object of the leveling up of the hillocks. The hillocks
were removed, he says, ”because they might not hinder the prospect “ of the mausoleum
.The very fact that within a couple of years of Mumtaz’s death the hillocks were leveled
to afford a glimpse of the mausoleum clearly indicates that the Taj building complex
already existed .All that was necessary was to level some of the hillocks and make the
building visible from a distance. In fact the very object of the ancient Hindu builders of
 the Taj raising those hillocks seems from Mundy’s noting, to prevent the tempting Taj to
be the target of a malicious enemy’s attack. Since Shahjahan was converting it into a
tomb open to all and sundry, he no longer had the need to keep it out of the gaze of
enmical people.
119. That Waldemar Hansen notes on pages 181-182 of his book (titled “The
Peacock Throne”, published by Holt, Rhinehart and Winston) that “Even as early as
1632 on the first anniversary of Mumtaz Mahal’s death, the courtyard of the mausoleum
in progress had been adorned with superb tents, with the entire court assembled to pay
homage- princes of the royal blood, grandees and an assemblage of religious scholars
including sheikhs, ulemas and hafizes who knew the whole Koran by heart. Shahjahan
had graced the event with his presence, and as the empress’s father Asaf Khan was
present by imperial request, a great banquet was spread before the then nascent tomb and
guests partook of a variety of foods, sweetmeats, and fruits. Verses from the Koran filled
the air, prayers were offered for the soul of the dead and a hundred thousand rupees went
into charity. In later years on other anniversary days, Shahjahan attended memorials at
the incomplete edifice whenever in Agra, formally accompanied by Jahanara and the
harem .The ladies always occupied a central platform set up for the occasion, and
remained concealed from the public gaze by kanats, screens of red cloth and velvet.
Noblemen gathered under pitched tents.
120. That the Taj Mahal originated as a temple -The inscription in Sanskrit has 34
stanzas of which stanzas 25,26 and 34 being relevant to our topic are reproduced as
translation. Translated, these means:”He (King Parmardi Dev or on his behalf his
minister Salakshan) raised a palace which had inside it the idol of Lord Vishnu whose
feet the king used to touch with his (bowed) head.
121. That “Similarly the King also had constructed this temple,(dedicated) to the
God who bears the crescent on His (fore)head, made of crystal white stone. Consecrated
in that (magnificent) temple the lord (was so pleased that He) never thought of repairing
to His (Himalayan) abode on mount Kailas. The inscription found at Mauja Bateshwar,
near Agra is at present in the Lucknow Museum.It is of the King Paramardi Dev dated
Vikram Samvat 1212, Ashwin (month),5th day of the bright lunar fortnight. It has in all
34 stanzas which describe the origin of the Chandratreya (regal) dynasty and its
important rulers. The inscription was found embedded in a mound at Bateshwar .It was
later deposited in the Lucknow Museum by General Cunnigham, where it still is. The
two beautiful marble temples which King Paramardi Dev had raised, one for Lord
Vishnu and the other for Lord Shiva were subsequently desecrated during Invader
invasions. Some clever (farsighted) person has this inscription ,concerning these
temples,buried in a mound. It remained buried for many years until1900 A.D. when
 during excavations it was discovered by General Cunnigham. The Shiva
(Chandramauleeshwar) temple is obviuosly the Taj Mahal for the following reasons:
Taj Mahal is scrawled over with 14 chapters of the Koran.
122. That the age of the original stone of the Taj Mahal and the age of the Koran
scrawled-stone are certainly different and which could be ascertain scientifically. No
where is there even the slightest or remotest elusion in that Islamic overwriting stating
Shahjahan’s authorship of the Taj. Had Shahjahan been the builder of Taj Mahal,
naturally some words would have been scrawled there. When koranic lettering has been
forged on the walls of Taj Mahal, then why not the name of Mumtaz in whose memory it
was stated to be built.
123. That it is mentioned by the inscriber, Amanat Khan Shirazi himself in an
inscription on the building that Shahjahan, far from building the marvel Tej, only
disfigured it with black lettering. A clue to that tampering by Shahjahan is found on
pages 216-217, Vol. IV of Archaeological Survey of India Reports, published in 1874,
stating that a .“great square black basaltic pillar which, with the base and capital of
another similar………..now in the grounds of the Museum at Agra……………….it is
well known, one stood in the garden of Taj Mahal.” The true copy of the photographs
deplicting the different monument with tempered representation having deceptive
indintity proclaiming as Mughal constriction as exhibited in the photographs are
Annexure no.18
124. That there was also a Sanskrit inscription dated 1155 A. D. in the Taj Mahal
which speaks conclusively that it was a Hindu Temple, which was subsequently wrongly
termed as Bateshwar inscription, now preserved at the top floor of the Lucknow
Museum.

125. That despite such staggering evidence the respondent authorities have been
guilty of Tomin the Taj Mahal as a marble creation of Shahjahan and thereby creating
and misleading the world for over a century. All of them have also been making illegal
gains through their deceitful activities by being paid huge sums for their books, articles,
news reports, broadcasts, and telecasts.
126. That Archaeological Survey of India is guilty of charging high entrance fee
from thousands of visitors every day from all over the world for over a century
purveying through its licensed guides concocted details about Shahjahan’s take
authorship of the Taj Mahal and through Archaeological Survey of India notices in
Hindi, Urdu and English on three stone plaques displayed at the Tajmahal entrance
declaring that Shahjahan raised the monument from 1631 to 1653 A. D.
127. That the authorities are guilty of giving mis-information and dis-information
all over the world for over a century. The enormity of that academic crime affecting the
whole world has caused a deep injury and prejudice to the human population of the
world. The national motto of our country is “Satyameva Jayate“ (Truth alone triumphs).
That In that context the blatant lie that the Archaeological Survey of India has been
propagating to the entire academic and tourist world is a matter of national sham and a
serious concern to all.
128. That there is no valid reason why Anglo-Invader school should not be able to
produce even a single document pertaining to the Invader claims to the fort. Had the
claims been true such documents should have been available in plenty because when the
British deposed the Mogul emperor they preserved and carefully classified all the
documents they seized form the mogul archives. Those records contain hardly anything
but letters. That when the Anglo-Invader school is unable to produce even a single
document in support of its claim any law court would draw an a priori adverse inference.
129. That even then we claim no special advantage form this fundamental weakness in
the case of the respondent Anglo-Invader school. In ordinary life, there are very many
occasions when documents are not available on either side and yet there is
overwhelming circumstantial evidence on the basis of which the court can come to a
clear judgement over the rival claims. It is such circumstantial evidence which we
propose to lay before the bar and bench of learned public opinion:
130. That according to the British historian Keene, Agra fort has been in existence
from the pre-Christian era. Ancient Hindu kings like Ashok (3 rd Century B.C.) and
Kanishka (1st Century B.C.) had lived in that fort. That same fort is again referred to by
the Persian poet-historian Salman, in the 11th century A.D.. Early in that century when
the Hindu king Jaipal ruled over Agra. The fort suffered its first Invader raid under the
invader Mahmud of Ghazni.Thereafter some chauvinistic Islamic accounts vaguely
claim that the Invader sultan Sikandar Lodi demolished the Hindu fort. That claim has
been found to be baseless. A few years later another vague claim is made by some other
mediaeval Invader faltterers that sultan Salim Shah Sur either destroyed the Hindu fort
or Sikandar Lodi’s fort and built his own fort at exactly the same place or some other
place. Even the claim has been found to be fraudulent because no trace is found of the
fort that Salim Shah Suri is said to have built. Invader history is replete with such
fraudulent claims, according to the late British historian Sir H.M. Elliot.
131. That an English visitor, Peter Mundy who was in India only for about a year after
Mumtaz’s death mentions the Taj Mahal as one of the most spectacular buildings. Thus
Shahjahan’s sacrilege of the Hindu Taj temple-palace by misusing it as an Islamic
graveyard ought to be rectified by removing Arjumand Banu’s remains,if they really are
 in the Taj Mahal, to her original grave, still existing in Burhanpur. The garden pavilion
of an Hindu mansion in Burhanpur (about 600 miles south west of Agra) where Mumtaz
was buried in 1631 A.D. after her death in her 14th delivery during 18 years of married
life. Shahjahan Mumtaz had encamped in the adjoining Hindu palace during a north
south journey when Mumtaz died.
132.That the ground plan of the orthodox Vedic octagonal Tejomahalaya shrine in Agra
where Mumtaz’s exhumed body is supposed to have been interred again. Why this
sacrilege? An aerial view. The white marble Tejomahalaya framed by four towers at its
plinth-corners on the south bank of the sacred Yamuna river. Two identical red stone
buildings (each with three marble domes) facing the marble edifice from the east and
west were meant to be reception pavilions for royal or religious congregations. The
central marble building and the flanking red stone buildings are all seven storied with
octagonal features, which is a Vedic specialty. Seven storied octagonal buildings are
mentioned even in Ramayanic description of Ayodhya. A meticulous count will reveal 33
arches in the marble plinth seen in front in between the two towers on the left and the
right. Since the marble platform is a square the breadth too has 33 arches consequently
the marble plinth itself encloses 33x 33=1089 rooms That is the ground floor. Above it
on either side of the lofty entrance arch may be seen vaulted arches on two levels one
above the other, which constitutes two more stories in marble.
133.That the outer western gateway leading to the spacious parking area for visitors’
vehicles lined by arcaded red stone verandahs with rooms for shopkeepers selling their
wares. The entire parking area is lined by such shopping arcades which Tavernier
describes as bazar of six courts. The western gateway has assumed importance in
modern times because the main bus depot and railway stations of the populace, bustling
Agra city lies in that direction. In olden days it was the elevated gateway at the left
which used, to be the main entrance of the Tajganj alias Tajganj township. The
Tejomahalaya shopping arcade has had at its outer eastern and western corners, flanking
the Shree gate, two other subsidiary sentinel-temples. This octagonal pavilion with a
white dome in the southwest corner bearing the inverted lotus cap and straight Vedic
pinnacle pitcher shaft is one of them. But alas, since Shahjahan’s time the sacred
sanctum has an Islamic cenotaph attributed to an harem-maid Satunnisa Khanam. But
since no name is inscribed on it that seems to be an inspired canard explaining away the
desecration of the Hindu shrine.
134. That the interior of the multi-storied vaulted entrance gate leading first to the
rectangular garden and then to the wonder marble edifice at the far end. The temple
palace management staff used to work on both floors on various assigned duties. The
carved decorative red stone bunting around the interior and exterior of this gateway,
 about knee-high from the floor, if minutely observed turns out to be an ingenious
running chain of three-in-one Ganesh images, two in profile on the flanks and one with a
frontal facing in the middle. The marble Taj Mahal has identical vaulted lofty archways
in all the four directions. Their temple décor was chiseled away and Koranic extracts
were improvised to fill the cavities. Close look at the marble stone frames around the
vertical and horizontal Koranic passages to notice the patches of dissimilar shapes and
tints of marble used. Cobras lined up above a string of inlaid temple bells pattern form
the upper border of the Taj Mahal. Both cobras and bells have sacred associations in
Vedic spiritual lore.
135. That the gateway at which entry tickets are issued, is decorated both inside and out, at
the knee level with a bunting depicting such ingeneous three-in-one Ganesh caricatures;
two in profile on the flanks enclosing a frontal one in the middle. The arches in the
marble plinth and the rectangular ventilator above each one of them,(allowing light and
air to the 1089 chambers inside the plinth)may be minutely observed to have been sealed
with marble slabs.
136. That the seven arches at the bottom enclose the stairs, which lead to the top of the
marble plinth symmetrically from the right and left. The Nandi (Lord Shiva ‘s Bull)
occupied the spot where the person clad in white robes is seen standing facing the
entrance, before it was uprooted at Shahjahan’s orders. That spot was patched up later
with inferior reddish slabs. There is trident shaped designs in inlay filigree at the two
upper corners of the entrance and the trident shaped red lotus bud at the apex of the arch.
137. That the Koranic stones fixed vertically and horizontally along such lofty arches on
all four sides were improvised to fill up gaping cavities left after digging out idols of
Vedic deities and Sanskrit extracts. We arrive at the above conclusion because (1) a close
inspection of the marble frames enclosing the Koranic extracts reveal patches of marble
of different shapes and tints (2) The Koranic extracts are random, haphazard out of
sequence and incomplete (3) On hot days with the visitor’s feet burning on the marble
plinth a fierce sun beating down on the head and the eyes burning with intense sunlight
radiated by the white marble sheen even a devout Invader knowing Arabic won’t have
the heart or even the steady head or patience to crane and strain his eyes and neck
alternately vertically and horizontally to make any head or tail of that message of Allah.
A close-up of the upper part of a minaret. The galleries rest on snake-shape brackets,
which is a distinct Hindu architectural trait. Mumtaz’s tomb in the crypt (basement). The
pavement patched up with marble slabs of varying sizes and tints indicating that the
Shivling here has either been replaced by the cenotaph or is covered up by it.
138. That after one enters the lofty arch from the marble platform one-steps onto
spacious halls which form a perambulatory passage all around the central octagonal
 sanctum. That sanctum too has entrances on all four sides. But only the south entrance
has been kept open since Shahjahan’s time. All these outer and inner entrances had silver
doors, which are common to all renowned Hindu (Vedic) shrines. Those were uprooted
and ranged on the outer marble plinth before being spirited away to Shahjahan’s Mogul
treasury. European visitors to the shrine around 1631 A.D. noticing the uprooted costly
fixtures such as silver doors ranged on the marble platform misunderstood them to have
been ordered by Shahjahan to be used in the building. Contrarily the thousands of
labourers rounded up from the by lanes of Agra city under threats of dire consequences
were forced to toil gratis to uproot all the costly fixtures such as the gem studded gold
railings (around the Shivaling), silver doors, precious stones stuffed in the marble
lattices and the golden pitcher dripping water on the Shivlinga, and transport them to the
mogul treasury. Notice the framed decorative panels to the left and right of the doorway.
They depict embossed OM shaped Dhatura flowers and conchshell- type foliage. The
panel at the left has the sacred conchshell design. The right side panel depicts a plant
with flowers shaped like the sacred Vedic chant (OM).
139. That Mumtaz’s cenotaph in the foreground and subsequent Shahjahan’s cenotaph
besides it in the upper marble octagonal chamber. Notice that both the cenotaphs are
highly decorated with inlay work. Science have been so somnolent for the last 350 and
odd years as to allow the preposterous Shahjahan and Mumtaz legend, stained with
carnal love to pass muster in spite of being riddled with a myriad loopholes disclosed
.Around the hook (from which hangs the chain) is a sketch in concentric circles. In the
smallest innermost circle are arrows symbolizing the eight surface directions. Around it
is another circle of 16 serpents looking down on the Shivling underneath. Around it is a
wider circle of 32 tridents. Surrounding it is a bigger circle depicting 64 lotus buds. Even
this mathematical progression of multiples of 8 i.e. 8x2=16x2=32x2=64 is of esoteric
Vedic significance and has no relation with Islam.The preponderating significance of 8
in Vedic tradition may be judged from terms such as Ashtapailu, Ashtavadhani,
Ashtaputra, Ashtadhatu, Ashtang Ayurved, Mangalashtak and Sastang namaskar.
140. That the octagonal lattice around the cenotaph of Mumtaz (which has replaced or
covered the sacred Shivling) has in its upper border a total of 108 pitchers, some rotund
and striped and some oblong like vases. The rotund striped pitcher is seen bathing the
Shivaling underneath with a stream of milk. The decorative flora on the vase and other
parts of the Taj Mahal alias Tejomahalaya is all native to India. Such decoration in the
orange, Vedic colour behooves a Hindu temple or palace but never a somber Islamic
sepulchre.
141. That a close-up of the gilded pinnacle rising from the inverted lotus cap of the
marble dome .The pinnacle is known as Kalash in Vedic parlance because of the stack of
 pitchers which constitute it. The curvy shaft seen in the upper portion represents the
crescent on Lord Shiva’s forehead. Above it is an oblong pitcher, two mango leaves
curving on either side with a coconut balanced on top. Such a coconut –topped pitcher
represents divinity in Vedic tradition.
142. That the three domes of the so-called mosque are a misfit in Islam. Since Islam has
only one Allah and one prophet for who is the third dome? Moreover the qibla (i.e. the
prayer niche) is not aligned to the Kaba in Mecca, as it should be in a genuine mosque.
Also when there are three qiblas instead of one they couldn’t all be aligned to the Kaba
at the same time. And since the twin buildings on the eastern flank is a non-mosque it
automatically follows that its counterpart to the west is also a non-mosque. Only
buildings with the same function and purpose can have an identical design.
143. That there is staircase and another symmetrical one at the other end lead down to the
storey beneath the marble platform Tow such staircases (one each at the eastern and
western ends) behind the marble plinth take one to the nether chambers. Visitors may go
to the back of the marble plinth at the eastern or western end and descend down the
staircase because it is open to sky. But at the foot the archaeology department has set up
an iron grill door, which it keeps, locked. Yet one may peep inside from the iron grill in
the upper part of the door. Shahjahan had sealed even these two staircases. It was the
British who opened them. But from Shahjahan’s time the stories below and above the
marble ground floor have been barred to visitors. We are still following Mogul dictates
and Invader secrecy though long free from Mogul Islamic rule.
144. That One of the 22 locked rooms in the secret storey beneath the marble platform
of the Taj Mahal, which the archaeological Survey of India keeps conspiratorially locked
to hoodwink the public. Therefore the public must pressurized the government to open
all locked and sealed chambers in all monuments including the Taj.
145. That the strips of ancient Hindu paint are seen on the wall flanking the doorway.
The niches above had paintings of Hindu gods, obviously rubbed off by Invader
desecrators. One of the 22 riverside rooms in a secret storey of the Taj Mahal unknown
to the public. Shahjahan far from building the shining marble Taj wantonly disfigured it.
Here he has crudely walled up a doorway. Such imperial Mogul vandalism lies hidden
from the public. This room is in the red stone storey immediately below the marble
platform. Indian history has been turned topsy- in lauding destroyers as great builders.
Therefore Shahjahan should be referred to not as the creator of Taj but as a plunderer of
its costly fixtures and disfigurer of the sublime, serene beauty of the holy Tejomahalaya.
146. That many such doorways of chambers in secret stories underneath the Taj
Mahal have been sealed with brick and lime. Concealed inside could be valuable
evidence such as Sanskrit inscriptions, Hindu idols, the original Hindu model of Taj, the
 desecrated Shiva Linga, Hindu scriptures and temple equipment .The Government is
deliberately refraining from opening hundreds of such sealed chambers. Inside the Taj
Mahal for fear of enraging Invaders and exposing the incompetence of historians
worldwide.
147. That there was the traditional treasury well of the Hindu temple palace.
Treasure chests used to be stacked in the lower stories. Accountants, cashiers, and
treasurers sat in the upper stories. On being besieged if the building had to be
surrendered to the enemy the treasure chests used to be pushed into the water for salvage
later after recapture. For real research, water should be pumped out of this well to reveal
the evidence that lies at the bottom. This well is inside a tower near the socalled mosque
to the west of the marble Taj. Had the Taj been a mausoleum this octagonal multi storied
well would have been superfluous.
148. That it has come to the notice of the petitioner’s institute that there has been
the digging of the place where “gowshala” cow protection shelter was situated .It was
revealed that there are the remains of the temple dig inside the earth and the upper
portion of the temple called as “Amlak” was found to have been hidden inside there. The
official sought the instructions from the officials of the archaeological department but
the matter was subsided on the instructions of the authority as it may annoy the
fundamentalist as a result of which the appeasement policy adopted by the government
for getting the vote of the minority may be adversely affected. Thus the spot inspections
by appointing the team of survey commissioner to submit Its report may kindly be
ordered by this Hon’ble Court
149. That Visitors to the Taj may notice the letter “om” woven in bold relief in
embossed flower –designs on the interior marble walls. As one stands poised at the top
of the stairs leading to the basement (to se what they call the ‘real graves’) one may see
on the walls around the upper marble cenotaph chamber, at chest level, the esoteric

sacred Hindu letter ‘om’ woven into embossed marble flower pattern. Pink lotus
patterns on the border of the grilled panels that enclose the cenotaph may also be
noticed.
150. That a peacock Throne could never have been ordered by fanatic mediaeval Invader
rulers surrounded by even more fanatic maulvis. Throughout their millennium long rule
in India their one penchant was to break images not to make them. The peacock Throne
could only be a piece of Hindu Palace furniture because traditionally a Hindu throne
must have the effigy of some bird or animal known for its splendor or valour. In Hindu
terminology the very term for a throne is a “Lion Seat (Simhasan).”Hardly had the
project begun, than we are told that by 1635 Shahjahan had amassed such a plethora of
 gems and bullion, within seven years of his accession that he did not know what to do
with them. He therefore had a fabulous Peacock Throne ordered.
151. That According to Shahjahan’s court chronicler (PP. 45-46,ibid.), it appears that
the peacock Throne was “three yards long, two and a half yards broad, yards high and
set with jewels worth 86 lakh rupees. The canopy had 12 emerald columns. On top of
each pillar were two peacocks thick –set with rubies, diamonds, emeralds, and pearls.
The throne cost ten million Rupees.” “The marble screen enclosing an octagonal area in
the centre of the cenotaph chamber was, according to the Badshahnama placed here in
1642 by Shahjahan …According, however, to competent authority the screen was placed
here by Aurangzeb after he laid his father’s remains there.
152. That “The basement rooms are centrally situated as a line of 14 rooms along the
face of the Great Basement, under its terrace; and each of them is connected by a
doorway with as inner lobby running east and west along their entire length. From each
end of the lobby a staircase ascends to the terrace of the Great Basement, where its
entrance closed by red sandstone slabs, lay unsuspected until discovered a few years
ago, the clue being given by a small window overlooking the river in each of the two
easternmost rooms. The rooms, once frescoed and otherwise decorated being now in
darkness and infested by bats, cannot be explored without a torch or lamp. Whether they
originally opened on to a ghat and gave admittance to the Taj from the river; or being
provided with windows, were used as cool resorts during the heat of the day, cannot now
be decided”.
153. That in the Agra Fort gallery, facing the Taj, is a tiny glass piece embedded in the
wall to mirror the Taj Mahal. Originators of the Taj legend have conveniently annexed
the device to add to the mesmeric effect of the myth. Embedding tiny, round glass
reflectors by their thousands in arched recesses of palaces and in women’s dresses is a
very common and widespread Rajput practice. Such glass reflectors can still be seen
fixed in numerous ancient palaces in Rajasthan, and continue to be used for decoration
in Rajput women’s dresses. Saracenic architecture, if there be any such should rather
believe in “purdah “ i.e. shrouding or hiding and would never think of glass reflectors.
Mirror –pieces decorated the royal apartments in Agra fort because it was a Hindu fort.
Moreover Shahjahan was never permitted access during interment to that part of the fort
which overlooks the Taj. It is, therefore absurd to argue that during detention he
consoled himself by catching glimpses of the Taj in the tiny glass piece.
154. That a further absurdity and inconsistency is; would an old monarch, bent with
age, stand up all the time to strain his bedimmed vision, and peer into a tiny glass piece
with his back to the Taj to catch a fleeting, reflected glimpse of the Taj when he could as
well have a clear, full, straight and direct view of it seated comfortably facing the
 monument? And would not such a stance give him a pain in the neck? This is yet another
instance of how students of history, archaeologists and lay visitors have never bothered
or cared to take stock of the loose bits of the Taj legend, and tried to rearrange them to
find out whether they add up to at least a coherent and cogent account, even if fictitious.
155. That in addition to its sculptural splendor, the Taj is also believed to have had
gem studded marble screens, gold railing, and silver doors. Readers can well add up to
the cost of all these. It will amount to a fabulous, astronomical sum. Perhaps even all the
Mogul emperors together could not have invested that much on a single monument. Had
the Taj been an original tomb, Shahjahan would never have allowed Indian flora to form
the dominant feature of the tapestry design inside the mausoleum of his wife. It is idle to
argue that because the workmen employed on the Taj happened to be Hindus their motifs
got incorporated in the Taj design. It must be remembered that it is the person who pays
the piper that calls the tune. Moreover when it is a question of the peace of departed
soul, symbols and motifs of a detested religion would never have been allowed to be
incorporated in the ornamental patterns of the Taj. In fact the whole idea of having such
a luxurious tomb built and having decorative patterns made inside it is frowned upon in
Islamic religion and tradition. But Shahjahan had no alternative, but to put up with them,
since he had taken over a ready-made “heathen” monument.
156. That under these circumstances, it is expedient in the interest of justice that a
facts finding committee may be appointed for exposing the falsehood of the
Arceaological department in respect of their purported claim set-up regarding the
historical blunder committed by them in declaring Taj-Mahal, Red- fort Agra, Fatahpur –
Sikiri and other ancient buildings as Muslim monuments and truth may be disclose to the
public/citizens and students of subject of history regarding their true authorship prior to
Mughal period in furtherance of their fundamental rights conferred under Article 19 (1)
(a), 25 and 26 read with 49 and 51-A(f) (h) of Constitution of India and Freedom Of
Information Act, 2002.
157. That it is prayed that this Hon’ble Court May graciously be pleased to declare the
provisions of The Ancient And Historical Monuments And Archaeological Sites And
Remains (Declaration Of National Importance) Act, 1951 to the extend of declaring the
ancient and historical monuments and other and Archaeological Sites namely Taj Mahal.
Fatehpur-sikiri, Agra Red Ford, Ethmadualla and other Monuments built by Mugal
invaders on the basis of report submitted by The Governor General, Lord Auckland, and
young lieutenant Alexander Cunningham conceived indigenous scheme of misusing the
archaeological studies as ultravires to Article 19 (1) (a), 25,26 49 And 51-A (f) (h) of
constitution of India and may futher declare the provision of Ancient and Historical
Monuments and Archaeological Sites and Remains (Declaration of National Importance)
 Act, 1951 (71 of 1951), The Ancient Monuments And Archaeological Sites And
Remains Act, 1958 of declaring these ancient building/ monuments preserved with such
identity with out any scientific inquiry/ investigation as Muslim monuments / graveyards
as unconstitutional and void. The true copy of THE ANCIENT MONUMENTS
PRESERVATION ACT, 1904, The Ancient And Historical Monuments And
Archaeological Sites And Remains (Declaration Of National Importance) Act, 1951 and
The Ancient Monuments And Archaeological Sites And Remains Act, 1958 ( Act No.24
of !958) and other relevant Acts are filed herewith and marked as Annexure No. 19,
20 and 21
158. That it is further prayed that on the basis of the Research Conducted by the
petitioner No.-2 as published in the different books written by him as referred in earlier
paragraphs namely 1. World Vedic Heritage, 2. The Tajmahal is a Temple Place,
3.Some Blunders of Indian Historical Research, 4. Flowers Howlers, 5. Learning
Vedic Astrology, 6. Some Missing Chapters of World History, 7. Agra red Fort is
a Hindu Building, 8.Great Britain was Hindu Land, 9. The Taj Mahal is
Tejomahalaya a Shiva Temple, 10.Who Says Akbar was Great, 11. Vedic Guide
to Health, Beauty, Longevity and Rejuvenation, 12. Islamic Havoc in Indian
History Published by-HINDI SAHITYA SADAN 2, B. D. Chambers, 10/54 D. B. Gupta
Road, Karol Bagh, New Delhi-110005, the truth may be exposed through Scientific
inventions and temperaments to the General Citizen/ Students of history by conducting
the research/ excavations of the remains of Hindu monuments by the Central
Government surroundings to all such Hindu Palace/ temple and other ancient
archaeological building/ Monuments as the incidents like demolition of disputed
structure at Ayodhya may not be repeated resulting in mass destruction of the public
property shacking of public confidence in Rule Of Law in the society. The true copy of
the representation submitted to the respondent No. 1 on the basis of the reserch work
conducted by Sri P. N. Oak having legal interpretation to the legal right conffered to the
citizen having scientific and analytcial approach regarding Hindu authorship of
monuments is filed as Annexure No. 22
159. That it is further prayed that A writ , order, directions in the nature of mandamus
directing the respondent authorities after due Scientific investigation and facts finding
inquiry report, the respondents in particular the Archaeological Survey of India to
Declare and Notify in terms of the true history, as the Taj Mahal was not built by
Shahalahan and thereby directing the Archaeological Survey of India to remove the
notices displayed by them in the Taj Mahal premises crediting Shahjahan as its creator to
desist from writing / publishing / proclaiming / propagating and teaching about
 Shahjahan being the author of Taj Mahal and stop and discontinue the free entry in Taj
Mahal premises on Fridays or any other day in the week.
160. That it is further prayed that a writ, order, direction in the nature of mandamus
directing the respondent authorities in particular Archaeological Survey of India to open
the locked-up upper and lower portions of the 4 storeyed building of Taj Mahal with
numbers of rooms, to remove all bricked up walls build later and look into room therein,
to investigate scientifically and certify which of those or both cenotaphs are fake to look
for a subterrance storey below the river bank ground level, to look into after removing
the room-entrance directly beneath the basement cenotaph-chamber. by removing the
brick and lime barricade flocking the doorway, to look for important historical evidence
such as idols and inscriptions hidden inside the Shahjahan’s orders.Recitiation of name
in the west-flank building be banned because that building is part of a temple
complex.The water in the 7 storeyed well, inside the tower near the so-called mosque, be
drained to for drained to look for historical evidence (such as Court jewels idols and
inscription jettisoned when Shahjahan’s troops stormed the premises to plunder the Shiv
Shrine).Free entry on Fridays should be discontinued to prevent loss of revenue to the
Government .If free entry on Friday is allowed to continue then free entry on Mondays
should be ordered because Mondays are Shiv worship days.
161. That the petitioners has no other efficacious remedy , expect to file the present
Writ Petition on the following and other grounds:-

Grounds
A. Because truth will not make us rich, but it will certainly make us
free. The wrong historical data leads to the horror, as we have seen during
the period of demolition of the Babri Masjid. There has been number of
concomitant given by the respective community representing to the follower
of two prominent religions, but the loss that we have suffered in the shape
of hatred between the two section of the society, cannot be compensated
without revealing the truth. Unfortunately, the term Hindu communalism is
more exaggerated by the fanaticism under the garb of secularism, while the
Hindu community as a whole has always been receptive to all the religion.
B. Because Article 25 of the constitution in India secures to every
person, subject of course to public order, health and morality and other
provisions of Part III, including Article 17 freedom to entertain and exhibit
outward acts as well as propagate and disseminate such religious belief
according to his judgement and conscience for edification of others. The
right of the State to impose such restrictions as are desired or found
 necessary on grounds of public order, health, and morality is inbuilt in Arts.
25 and 26 itself. Article 25(2)(b) ensures the right of the State to make a law
providing for social welfare and reforms besides throwing open of Hindu
religious institutions of a public character to classes and sections of Hindus
and any such rights of State or of the communities or classes of the society
were also considered to need due regulation in the process of harmonizing
the various rights.
C. Because every citizen of India is fundamentally obligated to
develop a scientific temper and humanism .He is fundamentally duty bound
to strive towards excellence, in all sphere of individual and collective
activity, so that the nation constantly rises to the higher level of endeavor
and achievements. Everyone, whether individually or collectively is
unquestionably under the supremacy of law. However it is true that
exaggerated devotion to the rule of benefit must not nurture fanciful doubts
or lingering suspicion and thereby destroy social defense, as the curiosity
cannot be the subject matter of fair criticism. Thus the conclusion derived
that on one hand, every citizen is having the freedom of speech and
expression so far as they do not contravene the statutory limits and may
prevail in the atmosphere with out any hindrance.
D. Because public education is essential for functioning of the
process of popular government and to assist the discovery of truth and
strengthening the capacity of individual in participating in decision making
process .The decision making process include the right to know also and
pushing the protection beyond the primary level betrays the bigwigs desire
to keep the crippled more crippled forever. The education of spritualism is
the foundation for value based survival of human being in a civilized society.
The force and section behind civilized society depend upon moral value;
and the morality cannot be cultivated through the falsehood of ideological
barrier. Thus the children may not be required to read such facts, which are
having the foundation of falsehood.
E. Because in Bijoe Emmanuel vs State of Kerala (1986) 3 SCC
615, the question raised in the aforesaid case, as to whether three children
who were faithful to “Jehovah’s witnesses” may refuse to sing our national
anthem or salute the national flag of our country despite being the student
in the school, where during morning assembly, the national anthem is sung
by other children. The circular issued by the Director of Public Instruction,
Kerala provided obligation of school children to sing the National Anthem.
 Thus these children were expelled. The Hon’ble Supreme court while
setting aside the aforesaid order of expulsion of the children from the school
was pleased to examine, as to whether the children faithful to “Jehovah’s
witnesses”, a worldwide sect of Christianity may be compelled against
tenets of their religious faith duly recognized and well established all over
the world which was upheld by the highest court in United States of
America, Australia and Canada and find recognition in Encyclopedia
Britannica. It was held that the appellants truly and conscientiously believed
that their religion does not permit them to join any rituals except it them in
their prayers to Jehovah, their God. Though their religious beliefs may
appear strange, the sincerity of their beliefs is beyond question. They do not
hold their beliefs idly and their conduct is not the outcome of any perversity.
The appellants have not asserted the beliefs for the first time or out of any
unpatriotic sentiments. Their objection to sing is not just against the
National Anthem of India. They have refused to sing other National Anthems
elsewhere. They are law abiding and well-behaved children, who do stand
respectfully and would continue to do so, when National Anthem is sung.
Their refusal, while so standing to join in the singing of the National Anthem
is neither disrespectful of it, nor inconsistent with the Fundamental Duty
under Article 51 A (a). Hence no action should have been taken against
them.
F. Because the concept of sovereignty was present from the ancient
time but the sovereignty was conferred upon an individual who is suppress
the wicked and is recognized as great resources in itself like the god of fire,
air, sun, moon and religion. The religion in the ancient time was considered
as spiritualism and it was not dependent upon any ritual ceremony, but it
was considered s the knowledge in the darkness of ignorance and injustice.
The sovereignty was supposed to promote the cause of the religion, wealth
and enjoyment of life and those, who were voluptuous, malicious, mean,
and low-minded, were ruined by the retributive justice.
G. Because the apex court held in RamSharan Autyanuprasi’s case
1989 (Supp.) (1) SCC 251/AIR 1989 S.C 549 , that men’s life is inclusive of
his tradition , culture and heritage and protection of that heritage in its full
measure would certainly come within the encompass of an expanded
concept of Article 21 of the Constitution
H. Because the mankind must be satisfied with the reasonableness
within reach and the decision-making process may belong to the knowledge
 of the law. Thus the reasonableness and the rationality, legality, as well as
philosophically, provide colour to the meaning of fundamental right .The
concept of equality is not doctrinaire approach. It is a binding threat, which
runs through the entire constitutional text thus the affirmative action may be
constitutionally valid and the same cannot ignore the constitutional morality,
which embraces in-itself the doctrine of inequality. It would be
constitutionally immoral to perpetuate inequality among majority .The
constitution is required to kept young energetic and alive. The attempt be
endure to expand the ambit of fundamental right. It is said that the dignity of
the ocean lies not in its fury capable of causing destruction, but in its vast
extent and depth with enormous tolerance. Thus the wider the power, the
higher the need of caution and care while exercising the power.
I. Because the Student/children, the future citizens under taking the
education of Indian History on the misconception/ pattern of Anglo Saxon
teaching meant for division of Indian society on the policy of “Divide and
Rule”. There is a important question posed as to whether we have actually
gain our independence or we have to under take another journey full of
animosity, aggressism on account of terrorism and fanatic ideology a
prevalent throughout the World of a particular religion.
J. Because this writ petition is moved in the Public Interest, for a National
Cause, to establish the truth there is no private interest or any other oblique
motive, or any other personal gain. The petitioner institution, known as
Institute for Re-writing Indian History, Thane, having registration no.F-1128
(T) is a public trust. The founder president of the trust is Shri P.N. Oak S/o
Late Shri Nagesh Krishna Oak, R/o- Plot no. 10, Goodwill Society, Aundh,
Pune.411007, who has written number of books namely 1. World Vedic
Heritage, 2. The Tajmahal is a Temple Place, 3.Some Blunders of Indian
Historical Research, 4. Flowers Howlers, 5. Learning Vedic Astrology, 6.
Some Missing Chapters of World History, 7. Agra red Fort is a Hindu
Building, 8.Great Britain was Hindu Land, 9. The Taj Mahal is Tejomahalaya
a Shiva Temple, 10.Who Says Akbar was Great, 11. Vedic Guide to Health,
Beauty, Longevity and Rejuvenation, 12. Islamic Havoc in Indian History.
K. Because the petitioner No. 2 is the founder President of an Institution,
namely, “ Institute for Re-writing Indian (and World) History “. The aim and
objective of that institution, which is a registered society having register no.
F-1128 (T) as the public trust under the provision of Bombay Public Trust
Act. Inter alia, is to re-discover the Indian history. The monumental places of
 historical importance in their real and true perspective having of the
heritage of India.
L. Because the ‘ research paper’ of the author on the subject that the
so-called “Taj Mahal “ is not a monument built by an Invader Emperor in
memory of his late wife but a Hindu Shiva Temple which was converted into
a love-memorial by a Invader Emperor.
M. Because the freedom of speech and expression is basic to indivisible
from a democratic polity .It includes right to impart and receive information.
Restriction to the said right could be only as provided in article 19(2). The
old dictum let the people have the truth and the freedom to discuss it and all
will go well with the Government. It should prevail. The true test for deciding
the validity is whether it takes away or abridges fundamental right of the
citizens. If there were direct abridgement of the fundamental right of
freedom of speech and expression, the law would be invalid.
N. the ambit and scope of “Right to Know “ is conferred fundamental right
under Article 19 (1)(a),25 and26 read with Article 49 and 51-A(f) (h) of the
Constitution of India; read with the provision of Freedom of Information Act,
2002 .The right to get information in democracy is recognized all throughout
and it is a natural right flowing from the concept of democracy itself.
Freedom of expression may be necessarily included in the right of
information. There is no expression with out having an idea on the subject,
regarding which the expression of an individual may be given effect to
change the existing values of ideology, which are based on the notable
extracts of certain facts. An enlightening informed citizen would undoubtedly
enhance democratic values.
O. Because the Governor General, Lord Auckland, and young lieutenant
Alexander Cunningham conceived indigenous scheme of misusing the
archaeological studies. This young Cunnigham, an army engineer had no
training in the archaeological department, he wrote a lengthy letter dated
September 15, 1842 suggesting archeological exploration in India. This
letter is reproduced on page no 246 Volume 7 journal of Royal Asiatic
Society, London, and 1843 A.D. It discloses that the purpose of
archeological exploration in India is neither the study; nor preservation of
historical monuments, but to use archeology as the imperial tool to create
mutual dissension and resentment between Buddhists, Jains and other
Hindu with Invaders by falsely crediting all monuments to the authorship to
 alien invaders while few may be labeled as that of being constructed by
Buddhist or Jain, but not by Hindus.
P. Because it has been disclosed during the High level Committee
Meeting at Paris during the convention of United Nation Education Science
and Cultural Organisation (UNESCO) that near Anoop Talab (Pond), there
has been the ancient palatial building and the ancient cultural activities
remain in existance prior to the period of invasion by the Mughal invaders.
The historian have related them back to the existence of all such palatial
building during the period of Sikarwar, Rajput, which find support by the
research were conducted Prof. Ram Nathan historian of Rajasthan
University, Jaipur and also by Dr. Pratima Asthana, Ex Vice Chancellor of
Gorakhpur University.
Q. Because one great tragedy of Indian history has been that while Indians
remained subdued and gagged under alien domination for over a millenium
foreigners, who wielded all power in India played great havoc with Indian
history merrily destroying or distorting it at their sweetwill either out of sheer
cunning and cussedness or through their colossal ignorance and wanton
barbarism.
R. Because that life includes all the meaning given to a man’s life
including his tradition, culture and hertiage and protection of that heritage in
its full measure squarely comes within the encompass of the extended
concept of Article 21 of the Constitution of India.
S. Because that the Taj Mahal, is a mark of history of hertiage and the
glorious achievement of Indian Art and Archaeology, and has to be named
and recognised in its true perspective and origin as a monument of world
important must not be allowed to be the victim subject of an “Historical
fraud” as an infringement of Indian tradition and heritage if the said
monument is wrongly and falsely indentifing and reconized as a mausoleum
giving a go bye to its origin and actual creation as a Palace/Temple in
redemption of fact and restoration of history.
T. Because the history of one’s heritage has to be rewritten to give a true
and correct account of the facts and figures, achievements and failures,
conquest end the defeat.as the Taj Mahal was not built by the fifth
generation Mugal emperor, namely, Shahjahan which is evidently proved.
PRAYER
It is, therefore, MOST RESPECTFULLY, prayed that this Hon’ble
Court May graciously be pleased to
1. Issue a Writ, order, direction in the nature of mandamus by
appointing a facts finding committee for exposing the falsehood of the
Arceaological department regarding the historical blunder committed by
them in respect of their purported claim set-up in declaring Taj-Mahal,
Red- fort Agra, Fatahpur –Sikiri and other ancient Hindu buildings/
monuments as Muslim monuments and restrain them from displaying
the authorship of these buildings as constructed by Sahajahan or by any
mughal Invaders as truth may be disclosed to the public/citizens and
Students in Subject of History regarding their true authorship prior to
Mughal period in furtherance of their fundamental rights conferred to
the Citizens under Article 19 (1) (a), 25 and 26 read with49 and 51-A(f)
(h) of Constitution of India and Freedom Of Information Act, 2002.
2. Issue a writ, order, direction in the nature of mandamus
declaring the provisions of The Ancient And Historical Monuments
And Archaeological Sites And Remains (Declaration Of National
Importance) Act, 1951 to the extend of declaring the ancient and
historical monuments and other and Archaeological Sites namely Taj
Mahal. Fatehpur-sikiri, Agra Red Ford , Ethmadualla and other
Monuments as built by Mugal invaders on the basis of report submitted
by Then Governor General, Lord Auckland, and young lieutenant
Alexander Cunningham conceived indigenous scheme of “Divide and
Rule” and thereby misusing the archaeological studies, as ultravires to
Article 19 (1) (a), 25,26 49 And 51-A (f) (h)constitution of India and
this Hon’ble Court may futher declare the provision of Ancient and
Historical Monuments and Archaeological Sites and Remains
(Declaration of National Importance) Act, 1951 (71 of 1951), The
Ancient Monuments And Archaeological Sites And Remains Act, 1958
of declaring these ancient building/ monuments preserved with such
false identity with out any scientific inquiry/ investigation as purported
Muslim monuments / graveyards as unconstitutional and void.
3. Issue a writ, order, direction in the nature of mandamus on the
basis of the Research Conducted by the petitioner No.-2 as published in
 the different books written by him as referred in earlier paragraphs
namely 1. World Vedic Heritage, 2. The Tajmahal is a Temple Place,
3.Some Blunders of Indian Historical Research, 4. Flowers Howlers, 5.
Learning Vedic Astrology, 6. Some Missing Chapters of World History,
7. Agra red Fort is a Hindu Building, 8.Great Britain was Hindu Land,
9. The Taj Mahal is Tejomahalaya a Shiva Temple, 10.Who Says Akbar
was Great, 11. Vedic Guide to Health, Beauty, Longevity and
Rejuvenation, 12. Islamic Havoc in Indian History Published by-HINDI
SAHITYA SADAN 2, B. D. Chambers, 10/54 D. B. Gupta Road, Karol
Bagh, New Delhi-110005, the truth may be exposed through Scientific
inventions and temperaments to the Citizen/ Students of history by
conducting the research/ excavations of the remains of Hindu
monuments by the Central Government surroundings to all such Hindu
Palace/ temple and other ancient archaeological building/ Monuments
as the incidents like demolition of disputed structure at Ayodhya may
not be repeated resulting in mass destruction of the public property
shacking of public confidence under Rule Of Law in the society.
4. Issue a writ, order, directions in the nature of mandamus directing the
respondent authorities after due Scientific investigation and facts
finding inquiry report, the respondents in particular the Archaeological
Survey of India may Declare and Notify in terms of the true history, as
the Taj Mahal was not built by Shahajahan and thereby directing the
Archaeological Survey of India to remove the notices displayed by
them in the Taj Mahal premises crediting Shahjahan as its creator and
to futher desist from writing / publishing / proclaiming / propagating
and teaching about Shahjahan being the author of Taj Mahal and stop
and discontinue the free entry in Taj Mahal premises on Fridays in the
week.
5. Issue a writ, order, direction in the nature of mandamus directing
the respondent authorities in particular Archaeological Survey of India
1)-to open the locks of upper and lower portions of the 4 storeyed
building of Taj Mahal having numbers of rooms, 2)-to remove all
 bricked up walls build later blocking such rooms therein, 3)-to
investigate scientifically and certify that which of those or both
cenotaphs are fake,4)-to look for a subterrance storey below the river
bank ground level, 5)-to look into after removing the room-entrance
directly beneath the basement cenotaph-chamber.6)- by removing the
brick and lime barricade flocking the doorway, 7)-to look for important
historical evidence such as idols and inscriptions hidden inside there by
the Shahjahan’s orders as truth may not make us rich but the same will
make us free from superstitions and false propoganda of some of
fundamentalists.
6. Any other Writ , Order or Direction, Which this Hon’ble Court
May deem fit in the circumstances of the case

Dated-7th September ,2004 Yogesh Kumar Saxena

Advocate, High Court
(Counsel for the Petitioner)
Chamber No.139, High court, Allahabad
IN THE HON’BLE HIGH COURT OF JUDICATURE AT ALLAHABAD.
Annexure No.

Civil Misc. Writ Petition No. of 2004

(Under Article 226 of constitution of India)
(District – Agra)

Institute of Rewriting Indian History Through its Founder President, P. N. Oak.

S/O Late Shri Nagesh Krishna Oak, R/O - Plot No. 10, Goodwill Society,
Aundh, Pune – 411007 and another…………..Pettioners

VERSUS

Union of India through Secretary,

Human Resources and Development (HRD),
Government of India, New Delhi. ……………….Respondents

Signs of Taj- makers found

H.T. 6th July 2004
The Archaeological Survey of India (ASI) has discovered 671 symbols
and signatures claimedTo pertain to workers who snapped the Taj
Mahal more than 350 years ago.
The inscription, etched on the sandstone facing the boundary wall
near the Yamuna, also includes symbols like the swastika, the trishul,
cymbals, stars
and flowers, superintending archaeologist of the zone D Dayalan said.
Some of the names are etched in Arabic and Persian, while others are
in Devanagri, he said, adding some names occur at many places.
Other boundary walls of the monuments would also be scanned for
the names of workmen, Dayalan said.
PTI, Agra
IN THE HON’BLE HIGH COURT OF JUDICATURE AT ALLAHABAD.
Annexure No.

Civil Misc. Writ Petition No. of 2004

(Under Article 226 of constitution of India)

(District – Agra)

Institute of Rewriting Indian History Through its Founder President, P. N. Oak.

S/O Late Shri Nagesh Krishna Oak, R/O - Plot No. 10, Goodwill Society,
Aundh, Pune – 411007 and another…………..Pettioners

VERSUS

Union of India through Secretary,

Human Resources and Development (HRD),
Government of India, New Delhi. ……………….Respondents

ADMISSION IN SHAHJAHAN’S OWN BADSHAHNAMA

A CLEAR, unequivocal and disarming admission that the Taj Mahal is a Hindu
palace commandeered for use as a Invader tomb is contained in Shahjahan’s own court
chronicle written by a paid courtier named Mulla Hamid Lahori.

In Elliot and Dowson we are told, “Badshahnama of Abdul Hamid Lahori is a history
of the first twenty years of the reign of Shahjahan…. Abdul Hamid himself says in his
preface, that the Emperor desired to find an author who could write the memories of his
reign in the style of Abdul Fazl’s I Akbarnama. He was recommended to the Emperor for
the work, and was called from Patna, where he was living in retirement, to undertake the
composition.” From this passage it is clear that Mulla Abdul Hamid Lahori wrote the
Badshahnama (in Persian) as an official chronicle at Emperor Shahjahan’s own command.
The Persian text in its original from is published by the Asiatic Society of Bengal.
Reproduced elsewhere in this book are pages 403 and 403 of Vol. 1 of this Badshahnama.

There are 22 lines on page 402 and 19 on 403. We have numbered them serially so
that those who cannot read the

1. P. 3 The History of India as Told by its Own Historians. Vol. VII, The Posthumous Paper
of the late Sir H. M. Elliot, K. C. B. edited by Professor John Dowson, M. R. A. S.,
published by Kitab Mahal (Private) Ltd. 56-A Zero Road, Allahabad.

2. Persian text of Mulla Abdul Hamid’s Badshahnama, in two volumes, published by the
Asiatic Society of Bengal in the Bibliotheca Indian series. I obtained the Photostat from
the copy in the National Archives, Government of India, in December 1965. Copies of
that publication are available in all-important institutional libraries throughout the world,
dealing with Indian Mediaeval history.
Persian script may follow the line-by-line transcript in the Roman script and later the
line-by-line rendering in English.
IN THE HON’BLE HIGH COURT OF JUDICATURE AT ALLAHABAD.
(Under Article 226 of constitution of India)
Annexure No.

Civil Misc. Writ Petition No. of 2004

(District – Agra)

Institute of Rewriting Indian History Through its Founder President, P. N. Oak.

S/O Late Shri Nagesh Krishna Oak, R/O - Plot No. 10, Goodwill Society,
Aundh, Pune – 411007 and another…………..Pettioners

VERSUS

Union of India through Secretary,

Human Resources and Development (HRD),
Government of India, New Delhi. ……………….Respondents

A TRANSCRIPT OF THE PERSIAN PASSAGE IN ROMAN CHARACTERS

(PAGE 402)

1. Har do ra az ham huda mee sakht wa hamin zorhae’ beja beemar shudah

2. Pas az chande dar zindagi e pidar sipare shud, saabiqa chun Fateh Khan

3. Pisare Ambar ba wa seelae Yaminuddoulah Asif Khan arzah dasht mehtawe bar

4. Dowlat khwahi wa hawa jooee firistadah maarooz dashta bood keh ein

5. Khidmatguzar ikhlas shiaar benizammra keh az kotah bini wa shaqawat

6. Guzeenee bad sagaali wa mukhalifate awliya-e-dowlat-e-abad meeaad mee namood

7. Muqavyad sakhteh ummidwari-I marahmi-I badshahi ast, wa dar jawabe aan farman

8. Qazah jiriyan (sic) izze sudoor yafteh bawad keh agar guftar-e-oo farooghe rastee darad

9. Jahan ra az aalaaishe wajoode besawaad-e-oo pak gardaanad chun Fateh Khan

10.Baad az waroode hukme jahan-mutah burhane-be-nizam bad farjam ra khufah namoodeh

11.Shoarat daad keh ba ajalle tabeeyee dar guzasht, wa Hussein nam pisare Darsalae

12.Oora janashin-e-aan badaayeengurdaa need. Wa arzh dashtee mebnee az

13.Haqiqat-e-ein waqueh ba dast-e-Muhammad Ibrahim keh az nowkarane moatamade oo

14.Bood, ba dargahe salateen panah firistad misalelazimul imtisal sabir shud keh
15.Lqbale ra ke ba daroone hisare Dowlatabaad burdeh az quillat-e-azzooqah (supplies)
zaayai khwahand

16.Shud aan ra ba nafais jawahar wa murasseh alat-e-be-nizam hamrahe-pisare

17.Kalane Khood ba rasme peshkash usaal numayad ta multimassate oo, izze qubul yadab

18.Wa ba nanshoore nawazish kahpoh murassah wa da yake Iraqui ba Zin-tila’

19.Deeagare Turkee rah waar ba zin-e-mutalaa’ mashoobe Shukrullah Arab wa Fateh Khan

20.Ba Dow latabaad farishtadand. Oodajiram ba benam-e-chihal hazar roopiah sarfaraz

gardeedeh

21.Rooze-juma’ hafdahum Jamadil awal naashe muqaddase musafire aqleeme

22.Tareeqae hazarat mehd alia Mumtazuzzamaneera keh ba tareeqae a amaanat mudafoon

(PAGE 403):

23.Bood masahoobe Badshehzadae namadaar Muhammad Shah Shuja Bahadur a Wazir

Khan.

24.Wa Sati (sic) Unnisa Khanum keh ba mijaz shanasi wa kaardaanee ba darise aolaee pesh

25.Dastee we waqaalat elaan Maalike Jahan malikae Jahaaniyaan raseeh bood, rawane-e

26.Darul khalafae Akbarabad namoodand wahukm shud keh har roz dar rah aash e bisiyar

27.Wa darahim wa dananeere be shumar ba fuqra wa nayazmadaan bibihand, wa zamine

dar

28.Nihayat rifaat wa nizaahat keh junoobrooe aan misr jaana astwa

29.Peah az ein Manzil-e Rajah Mansigh bood wadaree waqt ba Rajah Jaisingh

30.Nabirae talluq dasht bara-e-madfan e ann bashist muwaattan bar guzeedand

31.Agarcheh Raja Jaisingh husule ein dawlatra foze azeem danishtanmab

32.Az rooe ahatiyaat keh dar jameeye shewan khususan umoore diniyeh naguzir ast

33.Dar awaz aan aali manzil-e az khalisa e sharfah badoo marahmat farmoodand

34.Baad az raisdane naash be aan shahar-e karamat bahar panz dahun Jamadi Ussanieh

35.Sale aayandane paikare nooranee-e ba aan aamaanee jowhar ba khake pak sipurdeh
aamad

36.Wa mutasaddiyan-e darul khilafah ba hukme muallae ajaalatul waqt turbat-e-falak

martabate

37.Aan jahan iffatra az nazar poshidand. wa Imaarate-e-aalee shaan wa gumbaze

38.Rafi bunyan keh ta rastakheez dar balandee yadgare himmate gardoon rifaat

39.Hazrate Sahib Qarah-e-saani bashed wa dar ustuwaree namoodare istigamat

40.Azayam banee tarah afganddand wa muhandisane doorbeen wa meamaran-e-saanat

41.Aafreen chihal lakh roopiahi akharajate ein imaarat bar aawurd anmoodand

HERE UNDER IS THE LINE-BY-LINE ENGLISH RENDERING (PAGE 402)

1. Both were separated from one another and with those unjust atrocities fell ill

2. After some time during his father’s time (he) passed away. Prior to this since Fatehkhan

3. Son of Ambar through Yaminuddaulah Asafkhan had submitted a petition

4. Declaring his allegiance and loyalty and praying that this

5. Loyal servant full of sincerity requests that because the shortsightedness and cruelty

6. Ill will and opposition of the royal official came into play.

7. And putting me under rigorous imprisonment – and I hope to receive Royal mercy and
in validity of that death-inflicting

8. Royal order…. has had the honour of being issued and if that statement has any truth in
it

9. Then this world should be relieved of the existence of such a person since Fatehkhan

10.After reciving the royal order – obeyed by the world – be advanced arguments and
excuses for his bad administration

11.And publicised it to appear as a natural death Hussain named son of Darsaleh was…

12.Made successor illegally and a petition far from the

13.Reality of this event (was) sent through Mohammad Ibrahim – one of his trusted
employees

14.And the court of the Protector of Kings – issued an order which had to be strictly
complied with

15.That the confessor be taken inside Daulatabad fort and starves to death

16.And he with all the splendour and glory and fanfare accompanied by his son

17.Eldest (son) as per tradition be given a send off, so that his requests were accepted

18.And equipped with the gracious charter (order) and with two horses – one Iraqui with
golden saddle

19.The other – Turkish with an ornamental golden saddle through Shukurullah Arab and
Fatehkhan
20.Were sent to Daulatabad – and Udajahan was honoured with a reward of 40,000 rupees –

21.Friday – 15th jamadi-ul-awwal the sacred dead body of the traveller to the kingdom of
heaven, Her

22.Holiness, hazrat Mumtazul Zamani – who was buried temporarily, was sent –

(PAGE 403)

23.Accompanied by prince Mohammad Shah Shuja Bahadur, Wazir Khan –

24.And Satium Nisa Khanam – who knew the temperament of the (deceased) so intimately

25.And was well versed in the job and represented the views of the queen of queens etc.

26.Was brought to the capital Akbarabad (Agra) and an order was issued that very day

27.During the journey countless coins be distributed among the fakirs and needy, The site

28.Covered with a majestic magnificent lush garden, to the south of the great city and

29.Amidst which (garden) the building known as the palace (Manzil) of Raja Mansingh, at
present owned by Raja Jaisingh,

30.Grandson (of Mansingh), was selected for the burial of the Queen whose abode is in
heaven

31.Although Raja Jaisingh valued it greatly as his ancestral heritage and property, yet he
would have been agreeable to part with it gratis for the Emperor Shahjahan

32.(Still) out of sheer scrupulousness so essential in matter of bereavement and religious

(thinking it improper to take his palace gratis)

33.in exchange of that (aali Manzil) grand palace, he (Jaisingh) was granted a piece of
government land

34.After the arrival of the dead body in that great city (Agra) on 15th Jamadul Saniya

35.Next year that illustrious body of the heavenly Queen was laid to rest

36.The officials of the capital, according to the royal order of the day, under the sky-high
lofty mausoleum

37.Hid (the body of) that pious lady from the eyes of the world, and this Palace (Imarat-e-
Aalishan) so majestic and (capped) with a dome

38.So lofty that in its stature (it) is a memorial to the courage of sky-dimensions

39.(of) Sahib Qarani SANI – (the king) and in strength so might

40.In his resolution so firm – the foundation was laid and geometricians with far sight and
archietects of talent

41.Incurred an expenditure of Rs. 40 lakhs on this building

IN THE HON’BLE HIGH COURT OF JUDICATURE AT ALLAHABAD.
(Under Article 226 of constitution of India)
Annexure No.

Civil Misc. Writ Petition No. of 2004

(District – Agra)

Institute of Rewriting Indian History Through its Founder President, P. N. Oak.

S/O Late Shri Nagesh Krishna Oak, R/O - Plot No. 10, Goodwill Society,
Aundh, Pune – 411007 and another…………..Pettioners

VERSUS

Union of India through Secretary,

Human Resources and Development (HRD),
Government of India, New Delhi. ……………….Respondents
Paying due compliments and respects to his father Emperor Shahjahan, Aurangzeb
states in the letter, it was a written in 1652 A. D. stating therein that the repair is needed to
the old building complex. Had the Taj Mahal been a building completed in 1653 it would
not have fallen to the lot of a chance, lone visitor like Aurangzeb to notice the defects and
order repairs in 1652.
I reached (Akbarabad, i.e. Agra) on Thursday, 3rd of Moharam Mukram. On arrival I
called on Badshahzada Jahanbani (i.e. the elder Prince Dara) in the garden of Jahanara. In
that splendourous house surrounded by springing verdure I enjoyed their company and
inquired about everybody’s well-being. I stayed in the garden of Mahabat Khan.
Next day it being a Friday. I went to pay my homage to the sacred grave which had
been laid in Your Majesty’s presence. Those (i.e. cenotaph, grave etc.) are in good shape,
strong and solid but the dome over the grave leaks at two or three places during the rainy –
season on the northern side. Similarly several royal rooms on the second storey, and
jamposh of the bigger dome have all asborbed water through seepage and drip water during
the current monsoon season at several places. All these I have got temporarily repaired.
But I wonder what will happen to the various domes, the mosque, the community
hall, etc. during subsequent rainy seasons. They all need more elaborate repairs. I feel that
the second storey roof needs to be opened up and re-dome with mortar, brick and stone.
Repairs to the smaller and bigger domes would save these palatial building from decadence.
It is hoped that Your Majesty will look into the matter and order necessary action.
The Mehtab garden is innundated and looks desolate. Its scenic beauty will reappear
only when the floods recede.
That the rear portion of the building complex remains safe is a mistery. The stream
keeping away from the rear wall has prevented damage.
“On Saturday too I visited the spot and then I called on the Prince (Dara) who also
paid me a return visit. Then taking leave of all I resumed my journey (to take charge as
governor of the Deccan) on Sunday and today the 8th instant I am in the vicinity of
Dholpur….”
IN THE HON’BLE HIGH COURT OF JUDICATURE AT ALLAHABAD.
(Under Article 226 of constitution of India)
Annexure No.

Civil Misc. Writ Petition No. of 2004

(District – Agra)

Institute of Rewriting Indian History Through its Founder President, P. N. Oak.

S/O Late Shri Nagesh Krishna Oak, R/O - Plot No. 10, Goodwill Society,
Aundh, Pune – 411007 and another…………..Pettioners

VERSUS

Union of India through Secretary,

Human Resources and Development (HRD),
Government of India, New Delhi. ……………….Respondents

Details in respect of the Hindu Identity of Different Buildings/Monuments

Agra the Taj Mahal

1 That this symphony in marble was a royal Hindu palace. Its very name Taj Mahal
signifies nothing more or less. Its octagonal shape and the cupolas and four towers at the
plinth corners are all Hindu features. Havell, the English architect has all along stressed
that the Taj is an entirely Hindu structure in design and execution. The four towers used
to sport multi-coloured lights. The Taj precincts are a huge building complex
encompassing over three hundred rooms. The locality was known as Jaisinghpur. This
ornate marble trelliswork entirely in the Hindu style now encloses tow tombs believed to
be those of Mumtaz and Shahjahan .The network was stuffed with rare gems. Traditional
accounts tell us that this enclosure had silver doors and gold railings to boot. Even
Shahjahan’s and Mumtaz’s palaces never boasted of such fabulous fixtures when the pair
was alive and kicking from the imperial throne. How come then that when Mumtaz died
(1630 A.D.) all this wealth descended on earth all of a sudden. Far from that this
expensive and resplendent enclosure was made to house the dazzling Hindu peacock
throne that throne, wrongly credited to Shahjahan, came to his possession when he
dispossessed the Taj Mahal’s last Rajput owner Jai Singh of this fabulous ancient Hindu
palace.
The Marble Screen at the Taj -The Gateway of Taj
2 That the gateway leading to the Taj garden is like any other Hindu gateway tallying in
every detail with those of other forts and palaces depicted. The tiny domes over these
gateways in a row invariably make an odd figure like 5,7,9, or 11,since in Hindu
tradition the odd figure is preferred to the even. For instance donors give away
101,501,1001 rupees but never an even figure.

That Jahangir’s son Shahjahan is said to have demolished 500 buildings inside the
fort and erected 500 others. On the very face of it this claim is absurd. No one will merely
for fun of it destroy 500 palatial mansions built by one’s father or grandfather. Such
demolition itself will occupy a lifetime. Moreover it must also be remembered that
Shahjahan is credited with building the fabulous Taj Mahal in Agra, a whole new township
of Delhi, also the Red fort in Delhi, The Jama Masjid in Delhi and perhaps many other
buildings. Not only are there no court records of any building activity but even inscriptions
do not substantiate any building claim. We wish to alert visitors not to be misled by the
appearance of Arabic or Persian lettering on mediaeval buildings. All such lettering is
mostly of Koranic extracts or the name of Allah. Those inscriptions are seldom temporal. In
a few instances where there are temporal inscriptions they usually bear the name of the
engraver or of the person buried and some irrelevant matter. For instance nowhere on the
Taj Mahal has it been mentioned that the Taj Mahal was built by Shahjahan.We therefore
wonder how the whole world had been duped for 300 long years into believing that the Taj
Mahal was built by Shahjahan. Similar is the case with Red fort in Agra. No where is it said
that Akbar or his son Jahangir or the latter’s son Shahjahan built anything there.
Delhi Gate, Agra Fort, Anguri Bagh, Agra fort
3 That this gateway of the Red Fort Agra is entirely in the traditional Rajput styles. Like
many other Rajput forts this too had elephant images flanking it. Emperors Kanishka and
Ashok made use of this fort in the pre-Christian era. All its interior apartments too are of
the exclusive Rajput variety. The version which ascribes authorship of this fort to Akbar,
is a piece of court flattery. All its gateways have Hindu names. In addition to elephant
images this fort had images of Rajput horses. The Anguri bagh pavilion inside Agra fort
proves that the geometrical pattern garden has Rajput origins. Note the arches, the
pillars, the brackets, the cupola at the right, the curved ceiling partly visible adjoining
the cupola, which are all Rajput characteristics.
Golden Pavilion, Agra fort
4 That the cupola in the top left-hand corner, the curved roof, and the spikes on it vividly
depicts that this Golden Pavilion in Agra’s Red Fort was built by the Rajputs for the
Rajputs.
Diwan-I-Aam, Agra fort
5 That the so-called Diwan-I-Aam or hall of public audience inside Agar fort has neither
domes nor minarets. Its graceful arches and slender pillars is still the pattern for Hindu
pandals raised for auspicious ceremonies. Invader tradition has always avoided such
Hindu, ‘infidel’ patterns. Theirs are grotesque, tortuous shapes. The Red Fort in Delhi
too has an identical pavilion.
Statue of Akbar’s Horse
6 That this replica believed to be of Akbar’s horse is in fact an earlier Rajput horse. Akbar,
a Invader ordered no statues. Rajputs were known to erect elephant and horse statues.
Those slyly attributing the construction of Agra Fort to Akbar had Willy nilly also to
thrust upon him the erection of ‘infidel’ statues.
Statue of Amar Singh’s Horse Outside Agra Fort
7 That this horse head belongs to pre Invader times. It commemorates a brave steed. There
were ever so many Amar Singhs in Rajput history. The invented story that this replica is
Moghul wrought and is of the horse on which Amar Singh galloped away in a huff from
the Moghul court takes for granted that the lay visitor has hardly the time or the
necessary grounding in history to debunk such canards.
Tomb of Sadiq Khan
8 That this truncated corner tower cum-bastion of a demolished Rajput palace standing in
splendid isolation was later used to shelter Sadiq Khan’s corpse. That should not,
however blind visitors to the fact that this monument was part of a Rajput palace. Its
niches, the arched entrances and the upper floor all show that it was meant to be a place
for the living.
Jahangiri Mahal, Agra fort
9 That the entrance to the so-called Jahangiri Mahal inside Agra fort is of the typical
Rajput design and workmanship. Usurpation and centuries of occupation resulted in
Moghul names being given to earlier captured Rajput buildings. Gullible Western
 Scholarsm lacking indigenous insight perpetuated the myth of Invader authorship of
buildings misled by their names and latest associations. They hardly cared whether a
building was attributed to a Fakirchand or a Fakir Mohammad.

Jama Masjid, Agra

10 That all so called mediaeval Jama Masjids in India were earlier main (Jama) temples of
the town. This so-called Jama Masjid in the centre of Agra was a Rajput citadel with
ladies apartments and an underground passage to the fort. It has a huge basement too.
The inscription crediting its construction to Jahanara Begum is an interpolation. Jahanara
an unmarried lady who spent her sorrowing life in the smothering confines of the
Invaders purdah nursing her imprisoned and deposed father Shahjahan, had hardly any
money left with her. Even for two square meals a day she was at the mercy of her wily
and hardhearted brother Aurangzeb.
Salim Chisti Tomb, Fatehpur Sikri
11 That this so-called Salim Chisti tomb in Fatehpur Sikri is clearly an ornate Rajput
temple. Note the two round stone flower emblems on either side of the arch, and the
curving brackets. In the right background is the typical Rajput gateway capped by
cupolas. The lotus shaped fountain base in the foreground tank is also reminiscent of
Rajput ownership. This ornamental pillar Pillar supporting Akbar’s Throne in Diwan-I-
Khas with a narrow circular perch on top approached by four stone-slab bridges in
Fatehpur Sikri could as well have been a royal Rajput bathroom while concocted Akbar
legends claim it to be a throne room. But throne rooms in Akbar’s time were not as tiny
as a Pigeon house.
Hiran Minar, Fatehpur Sikri
12 That this so called Hiran Minar infront of the Hathi Pol gate of Fatehpur Sikri is falsely
claimed to mark the burial of a pet deer (Hiran) of Akbar .We ask whether the deer had
whispered a dying wish in Akbar’s ear to be commemorated with a fat Hindu temple
lamp post? The bristles were used to support oil lamps Such pillars are common infront
of Hindu Temples and palaces. The spiraling staircase inside leading to the cupola on top
remins one of the so called Kutub Minar in Delhi which have proved to be of Hindu
origin. This tower was known as ‘Hiranmaya’ since it sparkled like gold when it bristled
with flames of hundreds of lamps hung on it. That Sanskrit word has been deftly twisted
to be stuffed into the concocted Akbar legend.
Buland Darwaza, Fatehpur Sikri
13 That this towering gateway in Fatehpur Sikri is currently known to us as Buland
Darwaza.It is a typical Rajput Township. The stone flower emblems flanking the arch
are an unmistakable sign of its Hindu origin. The three big cupolas and the 13 tiny ones
in front in a row on the terrace front are of the exclusive Rajput design. The slender
pillars spiked at the top were used for hoisting flags. Such pillars are a part of almost all-
mediaeval Rajput monuments. The stone flower emblems are invariably present on all
Hindu homes and temples of the orthodox design, while they never exist on genuine
mosques.

Itmad-ud-Daulah’s Tomb
14 That this interior mural decoration in the so called Itmad-ud-Daulah tomb ,Agra is no
different from that found the pre-Invader Ambar palace in Jaipur,which proves that the
building was an earlier Rajput palace.
So-called Akbar’s Mausoleum at Sikandra
15 That every arch, supporting brackets and capping cupola of this mansion consisting of
pile upon pile of pavilions proves to the hilt that it was a Rajput palace. Euphemistically
called Sikandra ever since Sikandar Lodi a Pathan ruler lived in it, this mansion six
miles to the north of Agra is known to posterity as Akbar’s tomb. Akbar lay ill and died
here.
 Gateway Sikandra
16 That this is the majestic gateway to Sikandra Palace. The mansion inside was turned into
a tomb after Akbar’s death. It was built by the Rajputs centuries before Invader invaders
launched on a career of vandalism and usurpation. The four towers rising above the
gateway are replicas of the Taj Mahal towers. The mosaic flooring of the mansion has
the esoteric Hindu Shakti-Chakra (interlocked triangles) inlaid in it by the dozen.
Invader funeral rites admit of no such design.
Salabat Khan’s Mausoleum, Agra
17 That this Salabat Khan’s mausoleum is a truncated Rajput pavilion allotted to Khan for
his residence. On his death he was buried there.
Ganesh Pol Ambar Palace, Jaipur
18 That it was built around 984 A.D.,it had obviously no Invader influence. The gates of all
extant mediaeval monuments in India are similar to the Ganesh Pol. Gates of Mosques
and tombs in west Asian countries are also of identical design. This proves that far from
Indian mediaeval monuments having being designed or ordered by Invader potentates
and craftsmen, it was West Asian monuments, which were designed and executed by
Indian technicians as recorded by Mohammed Ghazni and Taimurlang. That incidentally
it may also be pointed out that the recorded fact of Mohammed Ghazni having been
buried in his own palace in Ghazni (1030 A.D.) also proves that all so called Invader
tombs whether in India or in West Asian countries are usurped palaces which they
occupied during their life times. That this Shish Mahal inside the Ambar fortress in
Jaipur was built (about 984. A.D.) Centuries before the founding of Invader Kingdoms in
India. Its ornate inlay work is no different from that in what are believed to be mediaeval
Invader mosques and tombs. It proves two things; firstly that the so-called tombs and
mosques were of Rajput origin and secondly that they were intended for the living not
for the dead.
Palace Garden Ambar
19 That this pavilion and the garden in the Ambar Palace with its spiked and curved roof,
the graceful Hindu arch and the geometrical design in the foreground is typical of all
mediaeval buildings. Ambar which lies three miles away from modern Jaipur, was
founded not later than 984 A.D. That was much before alien Invaders established their
principalities in India.
20 Thatreaders not acquainted with legal procedure might then ask as to whether there is
any documentary evidence available to prove that the fort was built by the Hindus in the
pre-christian era. The answer to this is that the immense Hindu evidence that existed in
the form of Hindu idols, inscriptions and documents in the archives of ancient Hindu
kings was all looted and destroyed when Mohammad Ghazni first raided the red fort in
the early part of the 11th century and again when the fort remained under continued
Invader occupation from 1526 to about 1760 A.D. If the owner of a building is forced
out of his mansion and the aggressor remains in occupation for several centuries will the
owner find his record intact on obtaining possession of his mansion after several
centuries?
Iron Pillar near the Qutub Tower
21 That the iron pillar bearing a Hindu inscription has been standing un-rusted through rain
and shine for milleniums beside the so–called Qutub Minar amidst the surrounding
temples battered by Invader hordes. Qutubuddin could never have brought piles of
material and dug a sprawling foundation for the stone tower called (Qutub) inside the
narrow confines of surrounding temples and other building work. Dislodged stones
bearing Hindu images on one side and Arab lettering on the other found the so called
Qutub Tower also prove that Invader conquerors staked false claim to Hindu monuments
through sculptural forgeries.
Qutub Minar
22 That this 238 ft. tall tower euphemistically called Kutub Minar was erected by King
Vikramaditya for astronomical observation centuries before Islam was even founded.
The adjoining township called Mehrauli is the corrupt form the Sanskrit term Mihira-
Awali meaning the Mihira Township. Mihira was Vikramaditya’s royal mathematician-
cum-astronomer-cum meteorologist. Even the Arabic term Kutub Minar signifies an
astronomical tower. Kutub and Kutubuddin was a subsequent unwitting mix-up. Around
the tower were 27 constellation temples which Kutubuddin’s inscription vaunts to have
destroyed. The tower too has 27 flutings. Near the first storey ceiling are 27 holes one in
each is likely. True to the significance of the term Kutub, this Tower’s entrance faces due
north.
Quwat-ul-Islam Mosque
23 That turned into a mosque called Quwat-ul-Islam the rows of ornamental pillars of this
monument by the side of the so-called Qutub Tower are a clear proof of its having been a
Hindu temple. No genuine mosque has ever such pillars lest reciters of Namaz standing
and bending with half-closed eyes inadvertently break their heads against them.
Nizam-ud-din Tomb
24 That the ornamental Hindu style pillars in the white marble structure turned into
Nizamuddin Tomb. The arch on the right and parts of arches visible on either side of the
dome are clear proof that this haphazard conglomerate of heterogeneous buildings was a
part of an ancient Hindu township stormed by invading Invader armies. Fakirs like
Nizamuddin following in their wake used to take up residence in the ruins of battered
buildings for preaching Islam to terrorize ‘infidels’. On their death they used to be
buried in the ruins where they lived. That is why tombs like those of Nizamuddin and
Bakhtiar Kaki in Delhi, Salim Chisti in Fatehpur Sikri and of Moinuddin Chisti in Ajmer
present a mix-up of Hindu structure devoid of any coherent plan. Around the
Nizamuddin tomb in Delhi are fanciful halls called Chausath Khamba, crumbling walls,
bastions, towers, decadent graves, cellars ,plinths and cornices which are remnants of the
stormed Hindu township still remembered by the term Keel-Ukhri(Kilokri). Keel used to
be the central pillar erected when a Hindu township was planned. Since it got up-rooted
in the Invader assault that area came to be known as Kilokri.
So called Humayun’s Tomb
25 That just about half a mile away from this building known as Humayun Tomb is the
narrow staircase from which Humayun the second generation Moghul emperor fell, in
Delhi. He was carried to his palace say contemporary chronicles. This was the palace he
was carried to and it was there that he died a few days later. He was buried in the central
chamber where he lay ill as has happened throughout Invader history in India. This
solves the tantalizing riddle why we have tombs but apparently no palaces of luxury-
steeped pleasure-seeking alien potentates. This monument still forms part of Jaipur
Estate in Delhi. It is surrounded by ruined walls, annexes, guesthouses, and guardrooms.
An arcade of arches leads to it. Close-by is a huge annexes euphemistically called Arab-
ki-Serai deriving its name from the times that invading Arab hordes encamped in it .The
entire grounds are littered with graves of invading Invader soldiers slain by Hindu
defenders. Before being turned into a tomb Humayun as a usurper lived in this sprawling
Hindu captured palace which was the focal point of the ruined township since known as
Kilokri. The nearby ruins in which Fakir Nizamuddin lies buried were a part of this huge
Hindu citadel.
Roshanara Garden
26 That this is believed to be the tomb of Roshanara, the daughter of the last powerful
Moghul emperor Aurangzeb. Note that it has neither domes nor minarets. Instead it has
ornamental pillars, Hindu arches and cupolas. Very parsimonious and hardhearted as the
Hindu-baiter Aurangzeb was he would hardly spend any money on a Hindu style resting-
place for his daughter’s corpse. Obviously, therefore, this is a usurped Hindu garden
palace commandeered to serve as a tomb as was usual in those times.
Fatehpuri Mosque
27 That this so called Fatehpuri Mosque at one end of Delhi’s crowded Chandni Chowk
highway was a pre-Invader Rajput temple of the city’s guardian and royal deity Lord
Shankara alias Eklingaji. Its entrance arches have the Hindu stone flower emblems on
either side of the apex. The word ‘Fatehpuri’ means a conquered (Hindu) township. The
marble slab on the red-stone entrance proclaiming it to be a mosque is evidently as
interpolation. The monuments, arches and pillars and cupolas are entirely of Hindu
Rajput style. The so-called mosque’s rental revenue is all derived exclusively from
Hindu shops swarming its fringes. This proves that while the stalls remained with the
Hindu their temples fell a victim to conquest and conversion.
Mausoleum of Safdar Jang
28 That this so called Safdarjang tomb in Delhi was an ancient Rajput palace which
devolved on the Invader aristocracy through conquest .It has an ornamental Rajput style
gateway and a protective wall with watch-towers and bastions which are superfluous for
a genuine tomb. Safdarjang, an ex-chief Minister of the Nawab of Oudh had been
disgraced and dismissed prior to his death. Who would foot the bill to build a palace for
an unemployed deceased nobleman’s corpse? A little prodding with two sharp questions
brings down the entire illusory structure of tall Invader claims to Hindu building-work.
We ask that if Safdarjang’s corpse could afford such a stupendous palace he should have
had at least ten palaces when living. But there is none. The other question is that if his
heir and successor built this palace for the corpse of the deceased Safdarjang the former
must himself have had tens of palaces in Delhi. But he too had none. Our answer to this
riddle is that Safdarjang and in fact all alien Invader rulers and noblemen were buried in
their own palaces.
Diwan-I-Khas, Red Fort, Delhi
29 That contrary to popular belief the Red Fort in Delhi is a very ancient structure.
Prithviraj used to stay in this Lalkot (red palace). Saffron and ochre are colours sacred to
the Hindus, but avoided by Invaders The main highway of Delhi known as Chandni
Chowk connects the Red Fort with the royal and guardian deity’ temple now turned into
Fatehpuri Mosque. Around this axis was built Old Delhi protected by a massive wall.
According to Akbarnama and the Agni Purana, Delhi was built by the Hindu King
Anagpal around 372 A.D. before founding of Islam.
Imambadas in Lucknow
30 The so called Imambadas in Lucknow for instance are ancient Hindu places which are
being merrily ascribed to this or that alien Invader nawab who subjugated that part of
Hindusthan.
31
IN THE HON’BLE HIGH COURT OF JUDICATURE AT ALLAHABAD.
(Under Article 226 of constitution of India)
Annexure No.

Civil Misc. Writ Petition No. of 2004

(District – Agra)

Institute of Rewriting Indian History Through its Founder President, P. N. Oak.

S/O Late Shri Nagesh Krishna Oak, R/O - Plot No. 10, Goodwill Society,
Aundh, Pune – 411007 and another…………..Pettioners

VERSUS

Union of India through Secretary,

Human Resources and Development (HRD),
Government of India, New Delhi. ……………….Respondents

THE ANCIENT AND HISTORICAL MONUMENTS AND ARCHAEOLOGICAL

SITES AND REMAINS (DECLARATION OF NATIONAL IMPORTANCE) ACT,
1951.
Act NO.LXXI OF 1951
An Act to declare certain ancient historical monuments and archaeological sites and remains
in Part A States and Part B States to be of national importance and to provide for certain
matters connected therewith.

[28th November, 1951]

BE it enacted by Parliament as follows:--

1.Short title.--This Act may be called the Ancient and Historical Monuments and
Archaeological Sites and Remains (Declaration of National Importance) Act, 1951.

2.Declaration of certain monuments and archaeological sites and remains to be of

national importance.--The ancient and historical monuments referred to or specified in
Part I of the Schedule and the archaeological sites and remains referred to or specified in
Part II thereof fare hereby declared, respectively, to be ancient and historical monuments
and archaeological sites and remains of national importance.

3.Application of Act VII of 1904 to ancient monuments, etc., declared to be of national

importance.-- All ancient and historical monuments and al archaeological sites and
remains declared by this Act to be of national importance shall be deemed to be protected
monuments and protected areas, respectively, within the meaning of the Ancient
Monuments Preservation Act, 1904, and the provisions of that Act shall apply accordingly
to the ancient and historical monuments or archaeological sites and remains, as the case
may be, and shall be deemed to have so applied at all relevant times.
---------------
THE SCHEDULE
(See section 2)
PART I
Ancient and Historical Monuments
I.All ancient and historical monuments in Part A States and Part B States with, before
the commencement of this Act, have either been declared by the Central Government ,
to be protected monuments within the meaning of the Ancient Monuments
Preservation Act, 1904, or which have been taken possession of by the Central Government
as protected monuments.

II.The following ancient and historical monuments in Part B states not covered by
Item No.I immediately preceding:-
---------------------------------------------------------------------------------------------------------------
------------------
Serial No. Name of monument
Locality
---------------------------------------------------------------------------------------------------------------
------------------
HYDERABAD STATE
District Aurangabad
1. Ajanta caves... Ajanta.
2. Aurangabad Caves Aurangabad
3. Daulatabad Fort and Monuments therein (e.g.Chand Minar) Daulatabad
4. Ellora Caves Ellora
5. Pithalkhora Caves Pithalkhora
6. Tomb of Aurangzeb Khuldabad
7. Tomb of Malik Ambar Do.
8. Tomb of Rabia Daurani (Bibi-ka-Maqbara) Aurangabad
District Bidar
9. Baihmani Tombs Ashtur
10. Barid Shahi Tombs Bidar City
11. Bidar Fort Do.
12. Madrasa Mahmud Gawan Do.
District Gulbarga
13. Gulbarga Fort and Great Mosque in the Fort Gulbarga
14. Hafth Gumbad Tomb of Firoz Shah Do.
District Hyderabad
15. Char Minar Hyderabad
City
16. Golconda Fort and Tombs Golconda
District Parbhani
17. Naganath Temple Aundha
District Raichur
18. Alampur Temples Alampur
19. Mahadev Temple Ittagi
District Warangal
20. Ramappa Temple Palampet
21. Thousand Pillar Temple Hanamkonda
22. Warangal Fort , Defences and Gateways Warangal
MADHYA BHARAT STATE
District Bhilsa
1. Athakhamba Gyaraspur
2. Bajramath Do.
3. Hindola Torana Do.
4. Maladevi Temple Gyaraspur
5. Bara Khambi Udyapur
6. Pisnarika Temple Do.
7. Udayeshwar Mahadeva Temple Do.
8. Bhimagaja Pathari
9. Caves Do.
10. Bijamandal Mosque Bhilsa
11. Lohangi Hill Capital Do.
12. Caves 1 to 20 Udaygiri
13. Dashavatara Temple Badoh
14. Gadarmal Temple Do.
15. Jain Temple Do.
16. Sola Khambi Do.
17. Khamb Baba (Heliodoras Pillar) Besnagar
18. Brick Temple (two) Kherat
19. Open Air Museum Do.
20. Fort Ater
District Dewas
21. Siddheshwar Temple Nemawar
22. Unfinished Temple Do.
District Dhar
23. Adar Gumbaz Mandu
24. Alamgir Gate Do.
25. Ancient Hindu Baodi Do.
26. Ancient Hindu well Do.
27. Andheri Baodi Do.
28. Ashrafi Mahal Do.
29. Baz Bahadur's palace Do.
30. Bhagwania Gate Do.
31. Bhangi Gate Do.
32. Champa Baodi Do.
33. Chhapan Mahal Do.
34. Chistikhan's Mahal Do.
35. Chor Kot Do.
36. Chorakot Mosque Do.
37. Nahar Jharokha Compound Do.
38. Daika Mahal Do.
39. Daike Chhote Behan ka Mahal Do.
40. Darya Khan's tomb Do.
41. Delhi Gate Do.
42. Dharmashalla Do.
43. Dilawarkhan's Mosque Do.
44. Ek-khamba Mahal Do.
45. Gadhasa's Palace Do.
46. Gadhasa's shop Do.
47. Gadi Dharmaja Do.
48. Hammam Do.
49. Hathi Gate Do.
50. Hathi Mahal Mandu
51. Hindola Mahal Do.
52. Hoshang's tomb Do.
53. Jahaz Mahal Do.
54. Jahangirpur Gate Do.
55. Jama Masjid Do.
56. Kali Baodi Do.
57. Kapoor Talao and the ruins on its banks Do.
58. Lal Bag Do.
59. Lal Bungalow Do.
60. Lohani Caves Do.
61. Lohani Gate Do.
62. Jali Mahal Do.
63. Nahar Jharoka Do.
64. Mahmud's tomb Do.
65. Malik Moghi's Mosque Do.
66. Mosque near Sopi Tanka Do.
67. Mosque near Tarapur Gate Do.
68. Mosque north-west of Daryakhan's tomb Do.
69. Nameless Tomb Do.
70. Nameless Tomb Do.
71. Nameless Tomb Do.
72. Nameless Tomb Do.
73. Neelkanth Do.
74. Rampol Gate and the Mosque opposite to it Do.
75. Royal Palaces Do.
76. Rupmati Pavilion Do.
77. Caravan Sarai Do.
78. Sarai near Daryakhan's Tomb Do.
79. Sat Kothari Cave Do.
80. Somoti Kund Do.
81. Songarh Gate Do.
82. Tarapur Gate Do.
83. Teveli Mahal Do.
84. Tomb and Mosque attached Do.
85. Tomb north of Almgir Gate Do.
86. Tomb north of Daryakhan's Tomb Do.
87. Tower of Victory Do.
88. Tripolia Gate Do.
89. Ujali Baodi Do.
90. Water Palace Do.
91. Bhoja Shala and Kamal Maula's Mosque Dhar
92. Lakti Masjid Do.
93. Buddhist Caves 1to7 Bagh
94. Water Palace Sadalpur
District Gwalior
95. Mahadeva Temple Amrol
96. Tila Monument Pawaya
97. Tomb of Mohammad Ghaus Gwalior
District Guna
98. Jain Temple 1 to 5 Budhi Chander
99. Chanderi Fort and:
Bada Madarasa Chanderi
Battisi Baodi Do.
Badal Mahal gateway Do.
Jama Masjid Do.
Kati Ghati Do.
Koshak Mahal Do.
Nizam-ud-din's tomb Do.
Shahjadi-ka-Roza Do.
100. Mohajamata temple Terahi
101. Monastery Do.
102. Torana gate Do.
103. Monastery Kadwaha
104. Temples 2 to 7 Do.
District Gwalior
105. Gwalior fort:
Chaturbhuj temple Gwalior
Mansingh's Palace Do.
Rock out Jain colossi Do.
Sas Bahu temples Do.
Teli ka Mandir Do.

District Khargone

106. Ballaleshwar Un
107. Chaubara Dera Do.
108. Gupteshwar Do.
109. Jain temples 1 to 3 Do.
110. Temples of Mahakaleshwar 1 and 2 Do.
111. Temple of Nilakantheshwar Do.
District Mandasor
112. Brahmanical Rockcut temples Dhamnar
113. Buddhist Caves Do.
114. Nau Torana temple Khor
115. Yasodharman's Pillars of Victory Sondni
District Murena
116. Ekottarso Mahadeva temple Mitaoli
117. Gadhi Padhavli
118. Kakanmadh temple Suhania
119. Temple Padhavli
120. Temple 1 to 22 Naresar
District Sivapuri
121. Large Shiva temple Mahua
122. Small Shiva temple Do.
123. Monastery Ranod
124. Monastery Surwaya
125. Open air museum Do.
126. Shiva temple Do.
127. Surwaya Gadhi Do.

MYSORE STATE
District Bangalore
1. Aprameyaswami Temple Malur
2. Ashurkhana Doddaballapur
3. Cenotaph Bangalore
4. Old Dungeon Fort and Gates Do.
5. Tipu Sultan's Palace Do.
6. Fort Devanahalli
7. Tipu Sultan's Birthplace Do.
8. Syed Ibrahim's Tomb or Bada Makkan Channapatna
District Chitaldrug
9. Akkatangi temple and Asoka inscription on Emmethammananagundu
Siddapur
10. Asoka inscriptions Brahmagiri
11. Fortress and temples on the hill Chitaldrug
12. Hariharesvara temple Harihar
13. Inscription and Jatingi, Rameswar temple Jatingi Ramesvara Hill
14. Santhebagilu and Rangayyanabagilu with preserved bastions Chitaldrug
District Hashan
15. Adinatha Basti Halebid
16. Hoysalesvara temple Do.
17. Kedaresvara temple Do.
18. Parsvanatha Basti Do.
19. Santhinatha Basti Do.
20. Akkana Basti
Sravanabelgola
21. Chandragupta Basti Do.
22. Chavundaraya Basti Do.
23. Gomatesvara Do.
24. Inscriptions Do.
25. Parsvanatha Basti Do.
26. Buchesvara temple Koravangala
27. Fort and Dungeons Manjarabad
28. Isvara temple Arsikere
29. Kalyani Hulikere
30. Kesava temple and inscriptions Belur
31. Lakshmidevi temple
Doddagaddavalli
32. Lakshminarasimha temple Nuggehalli
33. Sadashiva temple Do.
34. Nagesvara and Chennakesava temple Mosale

District kadur

35. Amritesvara temple Amritapura

36. Yupastambha and Isvara temple Hiremagalur
37. Vidyasankara temple Sringeri
38. Viranarayana temple Belavadi
District Kolar
39. Bhoganandisvara temple Nandi Hills
40. Tipu's Palace Do.
41. Yoganandisvara temple Do.
42. Haidar Ali's Birthplace Budikote
43. Kolaramma temple Kolar
44. Mokhbara (Mausoleum of Hyder Ali's father) Do.
45. Somesvara temple Do.
46. Ramalingesvara temples and inscriptions Avani
District Mysore
47. Arkesvara temple Hale Alur
48. Gaurisvara temple Yelandur
49. Kesava temple Somanathapur
50. Kirthinarayana temple Talkad
51. Vaidyesvara temple Do.
52. Lakshmikanta temple Mullur
53. Mallikarjuna temple Basral
54. Ramesvara temple
Narasamangala
55. Sidlu Mallikarjuna temple Bettadapur
56. Sri kantesvara temple Nanjangud
57. Sri Vijayanarayana temple Gundlupet
District Mandya
58. Colonel Bailey's Dungeon Seringapatam
59. Daria Daulat Bagh Do.
60. Gumbaz containing tomb of Tipu Sultan Do.
61. Jumma Masjid Do.
62. Obelisk Monuments and Fort walls near the breach Do.
63. Spot where Tipu's body was found Do.
64. Sri Kanthivara Statue in Narasimha temple Do.
65. Sri Ranganathasvami temple Do.
66. T.Innman's Dungeon Do.
67. Kesava temple Nagamangala
68. Lakshminarasimha temple Marehalli
69. Lakshmi narayana temple Hosaholalu
70. Lakshmi narayana temple Sindhaghatta
71. Narayanasvami temple Melkote
72. Panchakuta Basti Kambadahalli
73. Panchalingesvara temple
Govindanahalli
74. Temples Tonnur
District Shimoga
75. Aghoresvara temple Ikkeri
76. Anekal temple Bandalike
77. Somesvara temple Do.
78. Trimurthinarayana temple Do.
79. Bastis and inscriptions Huncha
80. Bherundesvara temple Belgavi
81. Kedaresvara temple Do.
82. Tripurantesvara temple Do.
83. Devaganga ponds
Basavanabyane
84. Fort Chennagiri
85. Fort Kavaledurga
86. Fortress and Renuka temple Chandragutti
87. Inscribed pillar Malavalli
88. Inscribed pillar Talagunda
89. Pranavesvara temple Do.
90. Jain basti with Brahmadeva Pillar Melagi
91. Kaitabhesvara temple Kubatur
92. Parsvanatha Basti Do.
93. Ramesvara temple Do.
94. Mallikarjuna and Ramesvara temples Kadkalsi
95. Musafirkhana and Honda Santhebennur
96. Palace site outside Fort Nagar
97. Ramesvara temple Keladi
98. Ramesvara temple Kudli
99. Shahji's tomb Hodigere
100. Shivappa Naik's fort Nagar
101. Temples and inscriptions Udri
102. Ditto. Kuppagadde
District Tumkur
103. Channigaraya temple Aralaguppe
104. Fort Madhugiri
105. Jumma Masjid Sira
106. Mallik Rihan Darga Do.
107. Kedaresvara temple Nagalapura
108. Onennakesava temple Do.
PATIALA AND EAST PUNJAB STATES UNION
District Bhatinda
1. Bhatinda fort Bhatinda
District Kandaghat
2. Pinjaur gardens and monuments of Fidai Khan Pinjaur

RAJASTHAN STATE
District Alwar
1. Gumbad Khan-i-Khana Alwar
2. Siva temple Do.
District Banswara
3. Neel Kantha Mahadeva's temple Banswara
4. Siva temple and Ruins Arthuna
5. Sun temple Talwara
District Bharatpur
6. Akbar's Chhatri Bayana
7. Ancient Fort with its monuments Do.
8. Brahmabad Idgah Do.
9. Islam Shah's Gate Do.
10. Jahangir's Gateway Do.
11. Jhajri Do.
12. Lodhi's Minar Do.
13. Saraj Sad-ul-lah Do.
14. Usha Mandir Do.
15. Chaurasi Khamba temple Kaman
16. Colossal image of Yaksha Noh
17. Deeg Bhawans (palace) Deeg
18. Looted Gun Do.
19. Marble Jhoola Do.
20. Delhi Gate Bharatpur Fort(
outside )
21. Fateh Burj near Anah Gate Bharatpur
22. Jawahar Burj and ashtadhatu gateway Bharatpur Fort
( inside )
23. Lal Mahal Rupvas
District Bikaner
24. Bhandasar Jaina Temple Bikaner
25. Fort Bhatner Hanumangarh
26. Jain temple of Susani Goddess Morkhena
village
27. Pallu Jaina sculptures Bikaner
District Bundi
28. Wall paintings of Hardoti school in the palace Bundi
District Dholpur
29. Jogni jogna temple Dholpur
30. Sher Garh Fort Do.
District Dungarpur
31. Jaina Temple inscription Baroda
32. Somnath temple Dev Somnath
District Jaipur
33. Banjaron ki Chhatri containing two pillars similar to the railing pillars Lalsote
of Bharhut stupa.
34. Baori Abaneri
35. Harsat Mata-ka-Mandir Do.
36. Baories old Todaraisingh
37. Kala Pahar temple Do.
38. Kalyanraiji's temple Do.
39. Laxmi Narainji's temple Do.
40. Pipaji's temple (near dispensary) Do.
41. Bisal Deoji's temple Bisalpur
42. Fresco paintings in the Ambar Palaces (personal property of the
AmbarMaharaja).
43. Harshnath temple Harshnath-
Sikar
44. Jama Masjid Ambar
45. Laxmi Narainji's temple Do.
46. Sri Jagat Siromaniji temple Do.
47. Sun temple Do.
48. Hathi Batha Kakore
49. Inscription in Fort Nagar
50. Mand Kila Tal inscription Do.
51. Yupa pillars in Bichpuria temple Do.
52. Inscription Panwar
53. Jain temple Sawai Madhopur Alanpur
54. Persian inscription in a Baori Do.
55. Punderikji ki Haveli-Paintings in a room Brahmpure
56. Ranthambhore fort Ranthambhore
57. Temple containing frescoes paintings Gultaji
58. Yupa pillars recovered from mounds Barnala
District Jaisalmer
59. Fort including ancient temples Jaisalmer
District Jhalawar
60. Buddhist Caves Hathiagor
61. Buddhist Caves, Pillars, Idols Kolvi (Dag)
62. Buddhist Caves and pillars Binnayaga
(Dag)
63. Caves of Naranjani, etc Do.
64. Old temples near the Chandrabhaga Jhalrapatan
District Jodhpur
65. Fort Mandore
District Karauli

66. Wall Paintings in the palaces of Maharaja Gopal Lal Karauli

District Kotah
67. Old temples, statues and inscriptions Shergarh
68. Siva temples and two unpublished Gupta inscriptions Charchoma
69. Temple (12 century) Baran
70. Temple, fort wall and statues Dara or Mukandara
71. Temple with inscriptions Kanswa
72. Yupa pillars Badva
District Udaipur
73. Fort of chitor as a whole Chitor
74. Fort of Kumbhalgarh as a whole Kumbhalgarh
75. Maha Kal and two other temples Bijholi
76. Rock inscription (12th century ) Do.
77. Sas Bahu temples Nagada

SAURASHTRA STATE
1. Ananteshwar temple Anandpur
2. Ashokan Rock Junagadh
3. Caves Do.
4. Darbargadh Halvad Halvad
5. Dhank Caves Dhank
6. Gop temple Gop
7. House where Mahatma Gandhi was born and Kirti Mandir Porbandar
8. Inscription in the Harsata Mata temple Veraval
9. Jain Temples Talaja
10. Jama Masjid Veraval
11. Jami Masjid and Rahimat Masjid, Raveli Masjid Mangrol
12. Navlakha temple and Step well Ghumli
13. Navlakha temple Sejakpur
14. Neminath temple with 3 inscriptions V.S.1333, 35, 39 Mt.Girnar
15. Nilakantha temple Anandpur
16. Pindara, Durvasa Rishi's Ashram and its site Pindara
17. Ra Khengar Mahal (temple) Mt.Girnar
18. Ranak Devi's temple Wadhwan
19. Sun temple Than
20. Surya temple Sutrapada
21. Talaja Caves Talaja
22. Temples- Shatrunjay
Hill
Adishwar temple
Balabhai's temple
Bhulavani temple
Chaumukha temple
Dalpet Bhai and Bhagu Bhai's shrine
Keshwaji Nayak temple
Moti Shah's Tuk temple
Nandeshwara Dipa temple
Panch Pandava temple
23. Vastupal Temple Junagadh
24. Varaha Mandir Kadwar

TRAVANCORE-COCHIN STATE
District Trichur
1. Mural Paintings (16-17th Century) on the walls of the Trichur
TenKailasanatha temple
2. Mural Paintings (16-17th Century) on the walls of the Mattancheri
Mattancheri town
Palace
3. Mural Paintings (16-17th Century) on the walls of the Siva Temple
Thiruvanchikulam
4. Mural Paintings (17-18th Century) on the walls of the Srikoil of Eyyal
The Siva Temple at Chemmanthatta
5. Mural Paintings on the walls of the Srikoil of the Pallimanna temple
Vadakkanchery
6. Mural Paintings on the walls of the Sriramaswami temple
Triprayar
7. Mural Paintings of the 17th-18th century on the walls of the Srikoils
Oorakam
of the Siva Temple at Peruvanam; and wooden bracket images of a
still earlier period on the Srikoils of the same shrine.
8. Twenty-nine wooden bracket images on the outer walls of the
Katavallur
Srikoil of the Vishnu temple at Katavallur and other works of art in
the same shrine

PART II
Archaeological sites and remains

I.All archaeological sites and remains in Part A States and Part B States which ,
before the commencement of this Act, have either been declared by the Central Government
to be protected areas or whch have been taken possession of by the Central Government as
protected areas.
II.The following archaeological sites and remains in Part B States not covered by
Item No.I immediately preceding :-
---------------------------------------------------------------------------------------------------------------
------------------
Serial Name of archaeological sites or remains. Locality
No.
---------------------------------------------------------------------------------------------------------------
------------------

HYDERABAD STATE
District Aurangabad
1. Ancient mound Paithan
District Gulbarga
2. Prehistoric site Evathalli
3. Ditto Rajankallur
District Medak
4. Ancient mound Kondspur
District Raichur
5. Ancient mound Kopbal
6. Ancient mound Maski
7. Prehistoric site Benkal
District Warangal
8. Prehistoric site Janampet
MADHYA BHARAT STATE
District Bhilsa
1. Ancient site Besnagar
2. Buddhist stupa Gyaraspur
3. Ruins of Gupta temple Udaygiri
District Dhar
4. Ruins in Bhoipura Mandu
5. Ruins on the west of Rewa Kund Do.
District Newar
6. Excavated site Kasrawad
District Gird
7. Ancient site Pawya
District Ujjain
8. Ancient mounds, viz., Bhairon Gadh, Vaishya Tekri,Kumbhar Tekri Ujjain

MYSORE STATE
District Bangalore
1. Prehistoric site Chikjala
2. Ditto Hejjala
3. Ditto Managondana-halli
4. Ditto Sevandurga
District Chitaldrug
5. Prehistoric site Brahmagiri
6. Ditto Chandravalli
District Kolar
7. Prehistoric site Hunkunda District Mysore
8. Prehistoric site Kittur

RAJASTHAN STATE
District Alwar
1. Ancient remains Pandrupol
2. Ancient site Bhangadh
District Banswara
3. Ancient remains Vithal Deva
District Bharatpur
4. Ancient Mound Malah
5. Ditto Noh
District Bikaner
6. Ancient mounds} Badopal
7. Ditto } Bhadrakali
8. Ditto } Bhannar Theri
9. Ditto } Dhokal
10. Ditto } In the neighbourhood of Suratgarh town Manak
11. Ditto } Munda
12. Ditto } Peer Sultan
13. Ditto } Rang Mahal
14. Ancient mounds (3) Kalibanga
15. Ancient mound Pilibanga
16. Ancient mound Baror ( Anupgarh Tahsil )
17. Ancient mounds (2) Binjor(Anupgarh Tahsil )
18. Ancient mound chak 86 (Do.)
19. Ancient mounds (2) Mathula (Do.)
20. Ancient mound Tarkhanewala-Dewa (Do.)District Bundi
21. Ancient mounds Nainwa, Lakheri and Keshwarai Patan
District Jaipur
22. Ancient mound Abaneri
23. Ditto Bundwali-Doongri
24. Ditto Gariagarh (Newai)
25. Ditto Maheshra
26. Ditto Nagar
27. Ditto Raniwas
28. Ditto Sikrai
29. Devapura Barodia mounds Jhalai
30. Excavated site Nagar
31. Ditto Rairh (Newai)
32. Excavated site Bairat and Sambhar
District Jaisalmer
33. Ancient site Lodruva Patan
District Jhalawar
34. Ancient ruins Dalsagar Ganga Dhar
35. Ditto Dudhaliya (Dag)
District Kotah
36. Ancient ruins and structural remains Krishnavilas
37. Ruins of temples Artu or Ganesh Ganj
District Udaipur
38. Ancient ruins Kalyanpur
39. Ditto Nagari
40. Ditto Badoli

SAURASHTRA STATE
1. Ancient mound Darbargadh Shihor
2. Ditto Intwa
3. Ditto Rangpur
4. Ditto Sejakpur
5. Ditto Valabhipur

TRAVANCORE-COCHIN STATE
1. Ariyannur Umbrellas.A prehistoric site consisting of seven or Ariyannur
more Kudakals or umbrella stones.

2. Burial cave of Chovannur Chovannur

3. Burial cave of Eyyal Eyyal
4. Burial cave of Kandanasseri Kandanasseri
5. Burial cave of Kattakampal Kattakampal
6. Burial cave of Kakkad Kunnamkulam
7. Kudakallu Parambu.A prehistoric site consisting of 50 to 60
Cheramanagad
Kudakals or umbrella monuments.
IN THE HON’BLE HIGH COURT OF JUDICATURE AT ALLAHABAD.
(Under Article 226 of constitution of India)
Annexure No.

Civil Misc. Writ Petition No. of 2004

(District – Agra)

Institute of Rewriting Indian History Through its Founder President, P. N. Oak.

S/O Late Shri Nagesh Krishna Oak, R/O - Plot No. 10, Goodwill Society,
Aundh, Pune – 411007 and another…………..Pettioners

VERSUS

Union of India through Secretary,

Human Resources and Development (HRD),
Government of India, New Delhi. ……………….Respondents

THE ANCIENT MONUMENTS PRESERVATION ACT, 1904

ACT NO.7 OF 1904

[AS ON 1957]

An Act to provide for the preservation of Ancient Monuments and of objects of

archaeological, historical, or artistic interest.

[18th March 1904.]

WHEREAS it is expedient to provide for the preservation of ancient monuments, for the
exercise of control over traffic in antiquities and over excavation in certain places, and for
the protection and acquisition in certain cases of ancient monuments and of objects of
archaeological, historical or artistic interest; It is hereby enacted as follows:—
1.Short title and extent.- (1) This Act may be called the Ancient Monuments Preservation
Act, 1904.
{ Subs.by the A.O.1950, for sub-section (2).}[(2) It extends to the whole of India {Subs.by
Act 3 of 1951, s.3 and Sch., for " except Part B States ".} [except the State of Jammu and
Kashmir].]

2.Definitions.- In this Act, unless there is anything repugnant in the subject or context,—

(1) " ancient monument " means any structure, erection or monument or any tumulus or
place of interment, or any cave, rock-sculpture, inscription or monolith, which is of
historical, archaeological or artistic interest, or any remains thereof, and includes—

(a) the site of an ancient monument;

(b) such portion of land adjoining the site of an ancient monument as may be required for
fencing or covering in or otherwise preserving such monument; and

(c) the means of access to and convenient inspection of an ancient monument:

(2) "antiquities" include any moveable objects which {Subs.by the A.O.1937, for " the
Govt.".} [the Central Government], by reason of their historical or archæological
associations, may think it necessary to protect against injury, removal or dispersion:

(3) " Commissioner " includes any officer authorized by {Subs.ibid., for "the L.G."} [the
Central Government] to perform the duties of a Commissioner under this Act:

(4) " maintain " and " maintenance " include the fencing, covering in, repairing,
restoring and cleansing of a protected monument, and the (doing of any act which may be
necessary for the purpose of maintaining a protected monument or of securing convenient
access thereto:

(5) " land " includes a revenue-free estate, a revenue-paying estate, and a permanent
transferable tenure, whether such estate or tenure be subject to incumbrances or not: and

(6) " owner " includes a joint owner invested with powers of management on behalf of
himself and other joint owners, and any manager or trustee exercising powers of
management over an ancient monument, and the successor in title of any such owner and
the successor in office of any such manager or trustee:

Provided that nothing in this Act shall be deemed to extend the powers which may lawfully
be exercised by such manager or trustee.

3.Protected monuments.- (1) The { Subs.by the A.O.1937, for " L.G.".} [Central
Government] may, by notification in the Official Gazette, declare an ancient monument to
be a protected monument within the meaning of this Act.

(2) A copy of every notification published under sub-section (1) shall be fixed up in a
conspicuous place on or near the monument, together with an intimation that any objections
to the issue of the notification received by the { Subs.by the A.O.1937, for " L.G.".}
[Central Government] within one month from the date when it is so fixed up will be taken
into consideration.

(3) On the expiry of the said period of one month, the { Subs.by the A.O.1937, for " L.G.".}
[Central Government], after considering the objections, if any, shall confirm or withdraw
the notification.

(4) A notification published under this section shall, unless and until it is withdrawn, be
conclusive evidence of the fact that the monument to which it relates is an ancient
monument within the meaning of this Act.

Ancient Monuments
4.Acquisition of rights in or guardianship of an ancient monument.-(1) The Collector,
with the sanction of the { Subs.by the A.O.1937, for "L G".} [Central Government], may
purchase or take a lease of any protected monument.

(2) The Collector, with the like sanction, may accept a gift or bequest of any protected
monument.
(3) The owner of any protected monument may, by written instrument, constitute the
Commissioner the guardian of the monument, and the Commissioner may, with the sanction
of the {Subs.by the A.O.1937, for " L.G.".}[Central Government], accept such
guardianship.

(4) When the Commissioner has accepted the guardianship of a monument under sub-
section (3), the owner shall, except as expressly provided in this Act, have the same estate,
right, title, and interest in and to the monument as if the Commissioner had not been
constituted guardian thereof.

(5) When the Commissioner has accepted the guardianship of a monument under sub-
section (3), the provisions of this Act relating to agreements executed under section 5 shall
apply to the written instrument executed under the said sub-section.

(6) Where a protected monument is without an owner, the Commissioner may assume the
guardianship of the monument.

5.Preservation of ancient monument by agreement.- (1) The Collector may, with the
previous sanction of { Subs.by the A.O.1937, for " the L.G "} [the Central Government],
propose to the owner to enter into an agreement with {Subs, ibid., for "the Secretary of
State for India in Council''.}[the Central Government] for the preservation of any protected
monument in his district.

(2) An agreement under this section may provide for the following matters, or for such of
them as it may be found expedient to include m the agreement:—

(a) the maintenance of the monument;

(b) the custody of the monument, and the duties of any person who may be employed to
watch it;

(c) the restriction of the owner's right to destroy, remove, alter or deface the monument or to
build on or near the site of the monument;

(d) the facilities of access to be permitted to the public or to any portion of the public and to
persons deputed by the owner or the Collector to inspect or maintain the monument;

(e) the notice to be given to {Subs.ibid., for "the Govt.".}the Central Government in case
the land on which the monument is situated is offered for sale by the owner, and the right to
be reserved to {Subs.ibid., for "the Govt.".}[the Central Government] to purchase such
land, or any specified portion of such land, at its market-value;

(f) the payment of any expenses incurred by the owner or by {Subs.by the A.O.1937, for "
the Govt.".}[the Central Government] in connection with the preservation of the
monument;

(g) the proprietary or other rights which are to vest in Government in respect of the
monument when any expenses reinsured by {Subs.by the A.O.1937, for " the Govt."} [the
Central Government] in connection with the preservation of the monument;

(h) the appointment of an authority to decide any dispute arising out of the agreement; and

(i) any matter connected with the preservation of the monument which is a proper subject of
agreement between the owner and {Subs.by the A.O.1937, for " the Govt.".}[the Central
Government].
{Sub-section (3) omitted ibid.}

(4) The terms of an agreement under this section may be altered from time to time with the
sanction of {Subs., ibid., for " the L.G.".} [the Central Government] and with the consent
of the owner.

(5) With the previous sanction of {Subs., ibid., for " the L.G.".}[the Central Government],
the Collector may terminate an agreement under this section on giving six months notice in
writing to the owner.

(6) The owner may terminate an agreement under this section on giving six months' notice
to the Collector.

(7) An agreement under this section shall be binding on any person claiming to be owner of
the monument to which it relates, through or under a party by whom or on whose behalf the
agreement was executed.
(8) Any rights acquired by {Subs., ibid., for " Govt.".}[the Central Government] in respect
of expenses incurred in protecting or preserving a monument shall not be affected by the
termination of an agreement under this section.

6.Owners under disability or not in possession.- (1) If the owner is unable, by reason of
infancy or other disability, to act for himself, the person legally competent to act on his
behalf may exercise the powers conferred upon an owner by section 5.

(2) In the case of village-property, the headman or other village-officer exercising powers of
management over such property may exercise the powers conferred upon an owner by
section 5.

(3) Nothing in this section shall be deemed to empower any person not being of the same
religion as the persons on whose behalf he is acting to make or execute an agreement
relating to a protected monument which or any part of which is periodically used for the
religious worship or observances of that religion.

7.Enforcement of agreement.- (1) If the Collector apprehends that the owner or occupier
of a monument intends to destroy, remove, alter, deface, or imperil the monument or to
build on or near the site thereof in contravention of the terms of an agreement for its
preservation under section 5, the Collector may make an order prohibiting any such
contravention of the agreement.

(2) If an owner or other person who is bound by an agreement for the preservation or
maintenance of a monument under section 5 refuses to do any act which is in the opinion of
the Collector necessary to such preservation or maintenance, or neglects to do any such act
within such reasonable time as may be fixed by the Collector, the Collector may authorize
any person to do any such act, and the expense of doing any such act or such portion of the
expense as the owner may be liable to pay under the agreement may be recovered from the
owner as if it were an arrear of land-revenue.

(3) A person aggrieved by an order made under this section may appeal to the
Commissioner, who may cancel or modify it and whose decision shall be final.

8.Purchasers at certain sales and persons claiming through owner bound by

instrument executed by owner.- Every person who purchases, at a sale for arrears of land-
revenue or any other public demand, or at a sale made under the Bengal Patni Taluks
Regulation, 1819, (Ben.Reg., 8 of 1819) an estate or tenure in which is situated a monument
in respect of which any instrument has been executed by the owner for the time being,
under section 4 or section 5 and every person claiming any title to a monument from,
through or under an owner who executed any such instrument, shall be bound by such
instrument.

9.Application of endowment to repair of an ancient monument.- (1) If any owner or

other person competent to enter into an agreement under section 5 for the preservation of a
protected monument, refuses or fails to enter into such an agreement when proposed to him
by the Collector, and if any endowment has been created for the purpose of keeping such
monument in repair, or for that purpose among others, the Collector may institute a suit in
the Court of the District Judge, or, if the estimated cost of repairing the monument does not
exceed one thousand rupees, may make an application to the District Judge for the proper
application of such endowment or part thereof.

(2) On the hearing of an application under sub-section (1), the District Judge may summon
and examine the owner and any person whose evidence appears to him necessary, and may
pass an order for the proper application of the endowment or of any part thereof, and any
such order may be executed as if it were the decree of a Civil Court.

10.Compulsory purchase of ancient monument.- (1) If the {Subs.by the A.O 1937, for "
L.G.".}[Central Government] apprehends that a protected monument is in danger of being
destroyed, injured or allowed to fall into decay.{Subs., ibid., for " the L.G.may proceed to
acquire it ".}[the Central Government may direct the State Government to acquire it] under
the provisions of the Land Acquisition Act, 1894, (1 of 1894)as if the preservation of a
protected monument were a " public purpose " within the meaning of that Act.

(2) The powers of compulsory purchase conferred by sub-section (1) shall not be exercised
in the case of—

(a) any monument which or any part of which is periodically used for religious
observances; or

(b) any monument which is the subject of a subsisting agreement executed under section 5.

(3) In any case other than the cases referred to in sub-section (2) the said powers of
compulsory purchase shall not be exercised unless the owner or other person competent to
enter into an agreement under section 5 has failed, within such reasonable period as the
Collector may fix in this behalf, to enter into an agreement proposed to him under the said
section or has terminated or given notice of his intention to terminate such an agreement.

{ Ins.by Act 18 of 1932, s.2.}[10A.Power Central Government to control mining, etc., near
ancient monument.- (1) If the{Subs.by the A.O 1937, for " L.G.".} [Central Government]
is of opinion that mining, quarrying, excavating, blasting and other operations of a like
nature should be restricted or regulated for the purpose of protecting, or preserving any
ancient monument, the {Subs.by the A.O 1937, for " L.G.".}[Central Government] may, by
notification in the Official Gazette, make rules—

(a) fixing the boundaries of the area to which the rules are to apply,

(b) forbidding the carrying on of mining, quarrying, excavating, blasting or any operation of
a like nature except in accordance with the rules and with the terms of a licence, and

(c) prescribing the authority by which, and the terms on which, licences may be granted to
carry on any of the said operations.
(2) The power to make rules given by this section is subject to the condition of the rules
being made after previous publication.

(3) A rule made under this section may provide that any person committing a breach thereof
shall be punishable with fine which may extend to two hundred rupees.

(4) If any owner or occupier of land included in a notification under sub-section (1) proves
to the satisfaction of the {Subs.by the A.O.1937, for " L, G.".} [Central Government] that
he has sustained loss by reason of such land being so included, the {Subs.by the A.O.1937,
for " L, G.".} [Central Government] shall pay compensation in respect of such loss.]

11.Maintenance of certain protected monuments.- (1) The Commissioner shall maintain

every monument in respect of which the Government has acquired any of the rights
mentioned in section 4 or which the Government has acquired under section 10.

(2) When the Commissioner has accepted the guardianship of a monument under section 4,
he shall, for the purpose of maintaining such monument, have access to the monument at all
reasonable times, by himself and by his agents, subordinates and workmen, for the purpose
of inspecting the monument, and for the purpose of bringing such materials and doing such
acts as he may consider necessary or desirable for the maintenance thereof.

12.Voluntary contributions.- The Commissioner may receive voluntary contributions

towards the cost of maintaining a protected monument and may give orders as to the
management and application of any funds so received by him:

Provided that no contribution received under this section shall he applied to any purpose
other than the purpose for which it was contributed.

13.Protection of place of worship from misuse, pollution or desecration.- (1) A place of

worship or shrine maintained by the Government under this Act shall not be used for any
purpose inconsistent with its character.

(2) Where the Collector has, under section 4, purchased or taken a lease of any protected
monument, or has accepted a gift or bequest, or the Commissioner has, under the same
section, accepted the guardianship thereof, and such monument, or any part thereof, is
periodically used for religious worship or observances by any community, the Collector
shall make due provision for the protection of such monument or such part thereof, from
pollution or desecration—

(a) by prohibiting the entry therein, except n accordance with conditions prescribed with the
concurrence of the persons in religious charge of the said monument or part thereof, of any
person not entitled so to enter by the religious usages of the community by which the
monument or part thereof is used, or

(b) by taking such other action as he may think necessary in this behalf.

14.Relinquishment of Government rights in a monument.- With the sanction of {Subs.,

ibid., for " Govt." } [the Central Government], the Commissioner may—

(a) where rights have been acquired by {Subs., ibid., for " Govt." } [the Central
Government] in respect of any monument under this Act by virtue of any sale, lease, gift or
will, relinquish the rights so acquired to the person who would for the time being be the
owner of the monument if such rights had not been acquired; or

(b) relinquish any guardianship of a monument which he has accepted under this Act.
15.Right of access to certain protected monuments.- (1) Subject to such rules as may
after previous publication be made by { Subs.by the A.O.1937, for " the L.G.".} [the Central
Government], the public shall have a nut right of access to any monument maintained by
{Subs., ibid., for " the Govt." } [the Central Government] under this Act.

(2) In making any rule under sub-section (1) {Subs.by the A.O.1937, for " the L.G.".} [the
Central Government] may provide that a breach of it shall be punishable with fine which
may extend to twenty rupees.

16.Penalties.- Any person other than the owner who destroys, removes, injures, alters,
defaces or imperils a protected monument, and any owner who destroys, removes, injures,
alters, defaces or imperils a monument maintained by {Subs., ibid., for " Govt." }[the
Central Government] under this Act or in respect of which an agreement has been executed
under section 5, and any owner or occupier who contravenes an order made under section 7,
sub-section (1), shall be punishable with fine which may extend to five thousand rupees, or
with imprisonment which may extend to three months, or with both.

Traffic in Antiquities
17.Power to Central Government to control traffic in antiquities.- (1) If the Central
Government apprehends that antiquities that are being sold or removed to the detriment of
India or of any neighbouring country, it may, by notification {For notification, see Gazette
of India, 1917, Pt.I, p 989.} in the Official Gazette, prohibit or restrict the bringing or
taking by sea or by land of any antiquities or class of antiquities described in the
notification into or out of {Subs.by Act 3 of 1951.3 and Sch., for " the territories for the
time being comprised within Part A States and Part C States ".}[the territories to which this
Act extends] or any specified part of {Subs.by the A.O.1950.for " the Provinces ".} [the said
territories].

(2) Any person who brings or takes or attempts to bring or take any such antiquities into or
out of {Subs.by the A.O.1950.for " the Provinces ".} [the said territories] or any part of
{Subs.by the A.O.1950.for " the Provinces ".} [the said territories] in contravention of a
notification issued under sub-section (1), shall be punishable with fine which may extend to
five hundred rupees.

(3) Antiquities in respect of which an offence referred to in sub-section (2) has been
committed shall be liable to confiscation.

(4) An officer of Customs, or an officer of Police of a grade not lower than Sub-Inspector,
duly empowered by the {Subs.by the A.O.1937, for "L.G." }[Central Government] in this
behalf, may search any vessel, cart or other means of conveyance, and may open any
baggage or package of goods, if he has reason to believe that goods in respect of which an
offence has been committed under sub-section (2) are contained therein.

(5) A person who complains that the power of search mentioned in sub-section (4) has been
vexatiously or improperly exercised may address his complaint to the {Subs.by the
A.O.1937, for "L.G." }[Central Government], and the {Subs.by the A.O.1937, for "L.G." }
[Central Government] shall pass such order and may award such compensation, if any, as
appears to it to be just.

Protection of Sculptures, Carvings, Images, Bas-reliefs, Inscriptions or like objects.

18.Poweer to Central Government to control moving of sculptures , carvings or like
objects.- (1) If {Subs., ibid.for " the L.G.".} [the Central Government] considers that any
sculptures, carvings, images, bas-reliefs, inscriptions or other like objects ought not to be
moved from the place where they are without the sanction of {Subs., ibid., for " the
Govt."} [the Central Government], {Subs., ibid.for " the L.G.".} [the Central Government]
may, by notification in the Official Gazette, direct that any such object or any class of such
objects shall not be moved unless with the written permission of the Collector.

(2) A person applying for the permission mentioned in subsection (1) shall specify the
object or objects which he proposes to move.and shall furnish, in regard to such object or
objects, any information which the Collector may require.

(3) If the Collector refuses to grant such permission, the applicant may appeal to the
Commissioner, whose decision shall be final.

(4) Any person who moves any object in contravention of a notification issued under sub-
section (1), shall be punishable with fine which may extend to five hundred rupees.

(5) If the owner of any property proves to the satisfaction of {Subs.by the A.O.1937 for "
the L.G."}[the Central Government] that he has suffered any loss or damage by reason of
the inclusion of such property in a notification published under sub-section (1), {Subs.by
the A.O.1937 for " the L.G."}[the Central Government] shall either—

(a) exempt such property from the said notification;

(b) purchase such property, if it be moveable, at its market - value; or

(c) pay compensation for any loss or damage sustained by the owner of such property, if it
be immoveable.

19.Purchase of sculptures, carvings or like objects by the Government.- (1) If {Subs.by

the A.O.1937 for " the L.G."} [the Central Government] apprehends that any object
mentioned in a notification issued under section 18, sub-section (1), is in danger of being
destroyed, removed, injured or allowed to fall into decay, {Subs.by the A.O.1937 for " the
L.G."} [the Central Government] may pass orders for the compulsory purchase of such
object at its market-value, and the Collector shall thereupon give notice to the owner of the
object to be purchased.

(2) The power of compulsory purchase given by this section shall not extend to—

(a) any image or symbol actually used for the purpose of any religious observance; or

(b) anything which the owner desires to retain on any reasonable ground personal to himself
or to any of his ancestors or to any member of his family.
{The heading and ss.20, 20A, 20B and 20C subs.by Act 18 of 1932, s.3, for the original
heading and s.20 Power of Central Government to notify areas as protected.}

[Archaeological Excavation]
20.Power of Central Government to notify areas as protected.-(1) If the Central
Government {The words " after consulting the L.G." omitted by the A.O.1937.} of opinion
that excavation for archaeological purposes in any area should be restricted and regulated in
the interests of archaeological research, the Central Government may, by notification in the
Official Gazette specifying the boundaries of the area, declare it to be a protected area.

(2) From the date of such notification all antiquities buried in the protected area shall be the
property of the Government and shall be deemed to be in the possession of the Government,
and shall remain the property and in the possession of the Government until Ownership
thereof is transferred; but in all other respects the rights of any owner or occupier of land in
such area shall not be affected.
20A.Power to enter upon and make excavations in a protected area.- (1) Any officer of
the Archaeological Department or any person holding a license under section 20B may, with
the written permission of the Collector enter upon and make excavations in any, protected
area.

(2) Where, in the exercise of the power conferred by sub-section (1), the rights of any
person are infringed by the occupation or disturbance of the surface of any land, {Subs.by
the A.O.1937, for "the Govt.".}[the Central Government] shall pay to that person
compensation for the infringement.

20B.Power of Central Government to make rules regulating Archaeological excavation

in protected areas.- (1) The Central Government may make rules {For such rules, see
Gazette of India, 1934, Pt.I, p.1103.}—

Power of Central Government to make rules regulating archaeological excavation in

protected areas.

(a) prescribing the authorities by whom licences to excavate for archæological purposes in a
protected area may be granted;

(b) regulating the conditions on which such licences may be granted, the form of such
licences, and the taking of security from licensees;

(c) prescribing the manner in which antiquities found by a licensee shall be divided between
{Subs.by the A.O.1937, for "Govt.".}[the Central Government] and the licensee; and

(d) generally to carry out the purposes of section 20.

(2) The power to make rules given by this section is subject to the condition of the rules
being made after previous publication.

(3) Such rules may be general for all protected areas for the time being, or may be special
for any particular protected area or areas.

(4) Such rules may provide that any person committing a breach of any rule or of any
condition of a licence shall be punishable with fine which may extend to five thousand
rupees, and may further provide that where the breach has been by the agent or servant of a
licensee the licensee himself shall be punishable.

20C.Power to acquire a protected area.- If the Central Government is of opinion that a

protected area contains an ancient monument or antiquities of national interest and value, it
may direct the State Government to acquire such area, or any part thereof, and the State
Government may thereupon acquire such area or part under the Land Acquisition Act, 1894,
as l o for a public purpose.]

General
21.Assessment of market-value or compensation.- (l) The market-value of any property
which Government is empowered to purchase at such value under this Act, or the {The
words " amount of " omitted by Act 18 of 1932, s.4.} compensation to be paid by
Government in respect of anything done under this Act, shall, where any dispute arises
{Subs.by s.4, ibid., for " touching the amount }[in respect] of such market-value or
compensation, be ascertained in the manner provided by the Land Acquisition Act, 1894,
sections 3, 8 to 34, 45 to 47, 51and 52, so far as they can be made applicable:
Provided that when making an inquiry under the said Land Acquisition Act, 1894, the
Collector shall be assisted by two assessors' one of whom shall be a competent person
nominated by the

Collector, and one a person nominated by the owner or, in case the owner fails to nominate
an assessor within such reasonable time as may be fixed by the Collector in this behalf, by
the Collector.

22.Jurisdiction.- A Magistrate of the third class shall not have jurisdiction to try any
person charged with an offence against this Act.

23.Power to make rules.- (1) The Central Government {The words " or the L G." omitted
by the A.O.1937.} may make rules for carrying out any of the purposes of this Act.

(2) The power to make rules given by this section is subject to the condition of the rules
being made after previous publication.

24.Protection to public servants acting under Act.- No suit for compensation and no
criminal proceeding shall lie against any public servant in respect of any act done, or in
good faith intended to be done, in the exercise of any power conferred by this Act.
THE HON’BLE HIGH COURT OF JUDICATURE AT ALLAHABAD.
(Under Article 226 of constitution of India)
Annexure No.

Civil Misc. Writ Petition No. of 2004

(District – Agra)

Institute of Rewriting Indian History Through its Founder President, P. N. Oak.

S/O Late Shri Nagesh Krishna Oak, R/O - Plot No. 10, Goodwill Society,
Aundh, Pune – 411007 and another…………..Pettioners

VERSUS

Union of India through Secretary,

Human Resources and Development (HRD),
Government of India, New Delhi. ……………….Respondents

THE ANCIENT MONUMENTS AND ARCHAEOLOGICAL

SITES AND REMAINS ACT, 1958
Act NO.24 OF 1958
[28th August, 1958]
An Act to provide for the preservation of ancient and historical monuments and
archaeological site and remains of national importance, for the regulation of archaeological
excavations and for the protection of sculptures, carvings and other like objects.

BE it enacted by Parliament in the Ninth Year of the Republic of India as follows:-

PRELIMINARY

1.Short title, extent and commencement.- (1) This Act may be called the Ancient
Monuments and Archaeological Sites and Remains Act, 1958.

(2) It extends to the whole of India, but sections 22, 24, 25 and 26 shall not apply to the
State of Jammu and Kashmir.

(3) It shall come into force on such date as the Central Government may, by notification in
the Official Gazette, appoint.

2.Definitions.- In this Act unless the context otherwise requires-,

(a) "ancient monuments" means any structure, erection or monument, or any tumulus or
place of interment, or any cave, rock-sculpture, inscription or monolith, which is of
historical, archaeological or artistic interest and which has been in existence for not less
than one hundred years, and includes-

(i) the remains of an ancient monument.

(ii) the site of an ancient monument,
(iii) such portion of land adjoining the site of an ancient monument as may be required for
fencing or covering in or otherwise preserving such monument, and
(iv) the means of access to, and convenient inspection of, an ancient monument;

(b) "antiquity" includes-

(i) any coin, sculpture , manuscript, epigraph, or other work of art or craftsmanship.
(ii) any article, object or thing detached from a building or cave,
(iii) any article, object or thing illustrative of science, art, crafts, literature, religion,
customs, morals or politics in bygone ages,
(iv) any article, object or thing of historical interest, and
(v) any article, object or thing declared by the Central Government, by notification in the
Official Gazette, to be an antiquity for the purposes of this Act.

which has been in existence for not less than one hundred years;
(c) "archaeological officer" means an officer of the Department of Archaeology of the
Government of India not lower in rank than Assistant Superintendent of Archaeology;

(d) "archaeological site and remains" means any area which contains or is reasonably
believed to contain ruins or relics of historical or archaeological importance which have
been in existence for not less than one hundred years, and includes-

(i) such portion of land adjoining the area as may be required for fencing or covering in or
otherwise preserving it, and
(ii) the means of access to, and convenient inspection of, the area;

(e) "Director-General" means the Director-General of Archaeology, and includes any

officer authorised by the Central Government to perform the duties of the Director-General;

(f) "maintain, with its grammatical variations and cognate expressions, includes the
fencing, covering in, repairing, restoring and cleansing of a protected monument, and the
doing of any act which may be necessary for the porpoise of preserving a protected
monument or of securing convenient access thereto;

(g) "owner" includes-

(i) a joint owner invested with powers of management on behalf of himself and other joint
owners and the successor-in-title of any such owner; and
(ii) any manager or trustee exercising powers of management and the successor-in-office of
any such manager or trustee;

(h) "prescribed" means prescribed by rules made under this Act;

(i) "protected area" means any archaeological site and remains which is declared to be of
national importance by or under this Act;

(j) "rotected monument" means an ancient monument which is declared to be of national

importance by or under this Act.

ANCIENT MONUMENTS AND ARCHAEOLOGICAL SITES AND REMAINS

OF NATIONAL IMPORTANCE

3.Certain ancient monuments, etc., deemed to be of national importance.- All ancient

and historical monuments and all archaeological sites and remains which have been
declared by the Ancient and Historical Monuments and Archaeological Sites and Remains
(Declaration of National Importance) Act, 1951 (71 of 1951), or by section 126 of the States
Reorganisation Act, 1956 (37 of 1956), to be of national importance shall be deemed to be
ancient and historical monuments or archaeological sites and remains declared to be of
national importance for the purposes of this Act.

4.Power of Central Government to declare ancient monuments, etc., to be of national

importance.- (1) Where the Central Government is of opinion that any ancient monument
or archaeological site and remains not included in section 3 is of national importance, it
may, by notification in the official Gazette, give two months' notice of its intention to
declare such ancient monument or archaeological site and remains to be of national
importance; and a copy of every such notification shall be affixed in a conspicuous place
near the monument or site and remains, as the case may be.

(2) Any person interested in any such ancient monument or archaeological site and remains
may, within two months after the issue of the notification, object to the declaration of the
monument, or the archaeological site and remains, to be of national importance.

(3) On the expiry of the said period of two months, the Central Government may after
considering the objections, if any, received by it, declare by notification in the Official
Gazette, the ancient monument or the archaeological site and remains, as the case may be,
to be of national importance.

(4) A notification published under sub-section (3) shall, unless and until it is withdrawn, be
conclusive evidence of the fact that the ancient monument or the archaeological site and
remains to which it relates is of national importance for the purposes of this Act.

PROTECTED MONUMENTS
5.Acquisition of rights in a protected monument.- (1) The Director-General may, with the
sanction of the Central Government, purchase, or take a lease of, or accept a gift or bequest
of, any protected monument.

(2) Where a protected monument is without an owner, the Director-General may, by

notification in the Official Gazette, assume the guardianship of the monument.

(3) The owner of any protected monument may, by written instrument, constitute the
Director-General the guardian of the monument, and the Director-General the guardian of
the monument, and the Director-General may, with the sanction of the Central Government,
accept such guardianship.

(4) When the Director-General has accepted the guardianship of a monument under sub-
section (3), the owner shall, except as expressly provided in this Act, have the same estate,
right, title and interest in and to the monument as if the Director-General had not been
constituted a guardian thereof.

(5) When the Director-General has accepted the guardianship of a monument under sub-
section (3), the provisions of this Act relating to agreements executed under section 6 shall
apply to the written to agreements executed under the said sub-section.

(6) Nothing in this section shall affect the use of any protected monument for customary
religious observations.

6.Preservation of protected monument by agreement.- (1) the Collector, when so

directed by the Central Government, shall propose to the owner of a protected monument to
enter into an agreement with the Central Government within a specified period for the
maintenance of the monument.
(2) An agreement under this section may provide for all or any of the following matters,
namely:-

(a) the maintenance of the monument:

(b) the custody of the monument and the duties of any person who may be employed to
watch it;

(c) the restriction of the owner's right-

(i) to use the monument for any purpose,

(ii) to charge any fee for entry into, or inspection of, the monument,
(iii) to destroy, remove, alter or deface the monument, or
(iv) to build on or near the site of the monument;

(d) the facilitates of access to be permitted to the public or any section thereof or to
archaeological officers or to persons deputed by the owner or any archaeological officer or
the Collector to inspect or maintain the monument;

(e) the notice to be given to the Central Government in case the land on which the
monument is situated or any adjoining land is offered for sale by the owner, and the right to
be reserved to the Central Government to purchase such land, or any specified portion of
such land, at its market value;

(f) the payment of any expenses incurred by the owner or by the Central Government in
connection with the maintenance of the monument;

(g) the proprietary or other rights which are to vest in the Central Government in respect of
the monument when any expenses are incurred by the Central Government in connection
with the maintenance of the monument;

(h) the appointment of an authority to decide any dispute arising out of the agreement; and

(i) any matter connected with the maintenance of the monument which is a proper subject
of agreement between the owner and the Central Government.

(3) The Central Government or the owner may, at any time after the expiration of three
years from the date of execution of an agreement under this section, terminate it on giving
six months' notice in writing to the other party:
Provided that where the agreement is terminated by the owner, he shall pay to the Central
Government the expenses, if any, incurred by it on the maintenance of the monument during
the five years immediately preceding the termination of the agreement or, if the agreement
has been in force for a shorter period, during the period the agreement was in force.

(4) An agreement under this section shall be binding on any person claiming to be the
owner of the monument to which it relates, from, through or under a party by whom or on
whose behalf the agreement was executed.

7.Owners under disability or not in possession.- (1) If the owner of a protected

monument is unable, by reason of infancy or other disability, to act for himself, the person
legally competent to act on his behalf may exercise the powers conferred upon an owner by
section 6.
(2) In the case of village property, the headman other village-officer exercising powers of
management over such property may exercise the powers conferred upon an owner by
section 6.

(3) Nothing in this section shall be deemed to empower any person not being of the same
religion as the person on whose behalf he is acting to make or execute an agreement relating
to a protected monument which or any part of which is periodically used for the religious
worship or observances of that religion.

8.Application of endowment to repair a protected monument.- (1) If any owner or other

person competent to enter into an agreement under section 6 for the maintenance of a
protected monument refuses or fails to enter into such an agreement, and if any endowment
has been created for the purpose of keeping such monument in repair or for that purpose
among other, the Central Government may institute a suit in the court of the district judge,
or, if the estimated cost of repairing the monument does not exceed one thousand rupees,
may make an application to the district judge, for the proper application of such endowment
or part thereof.

(2) On the hearing of an application under sub-section (1), the district judge may summon
and examine the owner and any person whose evidence appears to him necessary and may
pass an order for the proper application of the endowment or of any part thereof, and any
such order may be executed as if it were a decree of a civil court.

9.Failure or refusal to enter into an agreement.- (1) If any owner or other person
competent to enter into an agreement under section 6 for the maintenance of a protected
monument refuses or fails to enter into such an agreement, the Central Government may
make an order providing for all or any of the matters specified in sub-section (2) of section
6 and such order shall be binding on the owner or such other person and on every person
claiming title to the monument from, through or under, the owner or such other person.

(2) Where an order made under sub-section (1) provides that the monument shall be
maintained by the owner or other person competent to enter into an agreement all
reasonable expenses for the maintenance of the monument shall be payable by the Central
Government.

(3) No order under sub-section (1) shall be made unless the owner or other person has been
given an opportunity of making a representation in writing against the proposed order.

10.Power to make order prohibiting contravention of agreement under section 6.- (1) If
the Director-General apprehends that the owner or occupier of a protected monument
intends to destroy, remove, alter, deface, imperil or misuse the monument or to build on or
near the site thereof in contravention of the terms of an agreement under section 6, the
Director-General may, after giving the owner or occupier an opportunity of making a
representation in writing, make an order prohibiting any such contravention of the
agreement:
Provided that no such opportunity may be given in any case where the Director-General, for
reasons to be recorded, is satisfied that it is not expedient or practicable to do so.

(2) Any person aggrieved by an order under this section may appeal to the Central
Government within such time and in such manner as may be prescribed and the decision of
the Central Government shall be final.

11.Enforcement of agreements.- (1) If an owner or other person who is bound by an

agreement for the maintenance of a monument under section 6 refuses or fails within such
reasonable time as the Director-General may fix, to do any act which in the opinion of the
Director-General is necessary for the maintenance of the monument, the Director-General
may authorise any person to do any such act, and the owner or other person shall be liable
to pay the expenses of doing any such act or such portion of the expenses as the owner may
be liable to pay under the agreement.

(2) If any dispute arises regarding the amount of expenses payable by the owner or other
person under sub-section (1), it shall be referred to the Central Government whose decision
shall be final.

12.Purchasers at certain sales and persons claiming through owner bound by

instrument executed by owner.- Every person who purchases, at a sale for arrears of land
revenue or any other public demand, any land on which is situated a monument in respect
of which any instrument has been executed by the owner for the time being under section 5
or section 6, and every person claiming any title to a monument from, through or under, an
owner who executed any such instrument, shall be bound by such instrument.

13.Acquisition of protected monuments.- If the Central Government apprehends that a

protected monument is in anger of being destroyed, insured, misused, or allowed to fall into
decay, it may acquire the protected monument under the provisions of the Land Acquisition
Act, 1894 (1 of 1894), as if the maintenance of the protected monument were a public
purpose within the meaning of that Act.

14.Maintenance of certain protected monuments.- (1) The Central Government shall

maintain every monument which has been acquired under section 13 or in respect of which
any of the rights mentioned in section 5 have been acquired.

(2) When the Director-General has assumed the guardianship of a monument under section
5, he shall, for the purpose, of maintaining such monument, have access to the monument at
all reasonable times, by himself and by his agents, subordinates and workmen, for the
purpose of inspecting the monument and for the purpose of bringing such materials and
doing such acts as he may consider necessary or desirable for the maintenance thereof.

15.Voluntary contributions.- The Director-General may receive voluntary contributions

towards the cost of maintaining a protected monument and may give orders as to the
management and application of any funds so received by him;
Provided that no contribution received under this section shall be applied to any purpose
other than the purpose for which it was contributed.

16.Protection of place of worship from misuse, pollution or desecration.- (1) A

protected monument maintain by the Central Government under this Act which is a place of
worship or shrine shall not be used for any purpose inconsistent with its character.

(2) Where the Central Government has acquired a protected monument under section 13, or
where the Director-General has purchased, or taken a lease or accepted a gift or bequest or
assumed guardianship of, a protected monument under section 5, and such monument or
any part the derives used for religious worship or observances by any community, the
Collector hall make due provisions for the protection of such monument or part thereof,
from pollution or desecration-

(a) by prohibiting the entry therein, except in accordance with the conditions prescribed
with the concurrence of the persons, if any, in religious charge of the said monument or part
thereof, of any person not entitled so to enter by the religious usages of the community by
which the monument or part thereof is used, or

(b) by taking such other action as he may think necessary in this behalf.
17.Relinquishment of Government rights in a monument.- With the sanction of the
Central Government, the Director-General may,-

(a) where rights have been acquired by the Director-General in respect of any monument
under this Act by virtue of any sale, lease, gift or will, relinquish, by notification in the
Official Gazette, the rights so acquired to the person who would for the time being be the
owner of the monument if such rights had not been acquired; or

(b) relinquish any guardianship of a monument which he has assumed under this Act.
18.Right of access to protected monuments.- Subject to any rules made under this Act, the
public shall have a right of access to any protected monument.

PROTECTED AREAS
19.Restrictions on enjoyment of property rights in protected areas.- (1) No person,
including the owner or occupier of a protected area, shall construct any building within the
protected area or carry on any mining quarrying, excavating, blasting or any operation of a
like nature in such area, or utilise such area or any part thereof in any other manner without
the permission of the Central Government:

Provided that nothing in this sub-section shall be deemed to prohibit the use of any such
area or part thereof for purposes of cultivation if such cultivation does not involve the
digging of not more than one foot of soil from the surface.

(2) The Central Government may, by order, direct that any building constructed by any
person within a protected area in contravention of the provisions of sub-section (1) shall be
removed within a specified period and, if the person refuses or fails to comply with the
order, the Collector may cause the building to be removed and the person shall be liable to
pay the cost of such removal.

20.Power to acquire protected area.- If the Central Government is of opinion that any
protected area contains an ancient monument or antiquities of national interest and value, it
may acquire such area under the provisions of the Land Acquisition Act, 1894 (1 of 1894),
as if the acquisition were for a public purpose within the meaning of that Act.

ARCHAEOLOGICAL EXCAVATIONS
21.Excavations in protected areas.- An archaeological officer or an officer authorised by
him in this behalf or any person holding a licence granted in this behalf under this Act
(hereinafter referred to as the licensee) may, after giving notice in writing to the Collector
and the owner, enter upon and make excavations in any protected area.

22.Excavations in areas other than protected areas.- Where an archaeological officer has
reason to believe that any area not being a protected area contains ruins or relies of
historical or archaeological importance, he or an officer authorised by him in this behalf
may, after giving notice in writing to the Collector and the owner, enter upon and make
excavations in the area.

23.Compulsory purchase of antiquities, etc., discovered during excavation operations.-

(1) Where, as a result of any excavations made in any area under section 21 or section 22,
any antiquities are discovered, the archaeological officer or the licensee, as the case may be,
shall,-

(a) as soon as practicable, examine such antiquities and submit a report to the Central
Government in such manner and containing such particulars as may be prescribed;
(b) at the conclusion of the excavation operations, give notice in writing to the owner of the
land from which such antiquities have been discovered, of the nature of such antiquities.

(2) Until an orders for the compulsory purchase of any such antiquities is made under sub-
section (3), the archaeological officer or the licensee, as the case may be, shall keep them in
such safe custody as he may deem fit.

(3) On receipt of a report under sub-section (1), the Central Government may make an order
for the compulsory purchase of any such antiquities at their market value.

(4) When an order for the compulsory purchase of any antiquities is made under sub-section
(3), such antiquities shall rest in the Central Government with effect from the date of the
order.

24.Excavations, etc., for archaeological purposes.- No State Government shall undertake

or authorise any person to undertake any excavation or other like operation for
archaeological purposes in any area which is not a protected area except with the previous
approval of the Central Government and in accordance with such rules or directions, if any,
as the Central Government may make or give in this behalf.

PROTECTION OF ANTIQUITIES
25.Power of Central Government to control moving of antiquities.- (1) If the Central
Government considers that any antiquities or class of antiquities ought not to be moved
from the place where they are without the sanction of the Central Government, the Central
Government may, by notification in the Official Gazette, direct that any such antiquity or
any class of such antiquities shall not be moved except with the written permission of the
Director-General.

(2) Every application for permission under sub-section (1) Shall be in such form and
contain such particulars as may be prescribed.

(3) Any person aggrieved by an order refusing permission may appeal t the Central
Government whose decision shall be final.

26.Purchase of antiquities by Central Government.- (1) If the Central Government

apprehends that any antiquity mentioned in a notification issued under sub-section (1) of
section 25 is in danger of being destroyed, removed, injured, misused or allowed to fall into
decay or is of opinion that, by reason of its historical or archaeological importance, it is
desirable to preserve such antiquity in a public place, the Central Government may make an
order for the compulsory purchase of such antiquity at its market value and the Collector
shall thereupon give notice to the owner of the antiquity to be purchased.

(2) Where a notice of compulsory purchase is issued under sub-section (1) in respect of any
antiquity, such antiquity shall vest in the Central Government with effect from the date of
the notice.

(3) The power of compulsory purchase given by this section shall not extend to any image
or symbol actually used for bona fide religious observations.

PRINCIPLES OF COMPENSATION
27.Compensation for loss or damage.- Any owner or occupier of land who has sustained
any loss or damage or any diminution of profits from the land by reason of any entry on, or
excavations in, such land or the exercise of any other power conferred by this Act shall be
paid compensation by the Central Government for such loss, damage or diminution of
profits.
28.Assessment of market value or compensation.- (1) The market value of any property
which the Central Government is empowered to purchase at such value under this Act or the
compensation to be packed by the Central Government in respect of anything done under
this Act shall, where any dispute arises in respect of such market value or compensation, be
ascertained in the manner provided in sections, 3, 5, 8 to 34, 45 to 47, 51 and 52 of the Land
Acquisition Act, 1894 (1 of 1894), so far as they can be made applicable:

Provided that, when making an enquiry under the said Land Acquisition Act, the Collector
shall be assisted by two assessors, one of whom shall be a competent person nominated by
the Central Government and one a person nominate by the owner, or, in case the owner fails
to nominate an assessor within such reasonable time as may be fixed by the Collector in this
behalf, by the Collector.

(2) Notwithstanding anything contained in sub-section (1) or in the Land Acquisition

Act.1894 (1 of 1894), in determining the market value of any antiquity in respect of which
an order for compulsory purchase is made under sub-section (3) of section 23 or under quite
by reason of its being of historical or archaeological importance shall not be taken into
consideration.

29.Delegation of powers.- The Central Government may, by notification in the Official

Gazette , direct that any powers conferred on it by or under this Act shall, subject to such
conditions as may be specified in the direction, be exercisable also by-

(a) such officer or authority subordinate to the Central Government or

(b) such State Government or such officer or authority subordinate to the State Government,
as may be specified in the direction.

30.Penalties.- (1) Whoever-

(i) destroys, remove, injures, alters, defaces, imperil or misuses a protected monument, or
(ii) being the owner or occupier of a protected monument, contravenes an order made under
sub-section (1) of section 9 or under sub-section (1) of section 10, or
(iii) removes from a protected monument any sculpture carving, image, bas-relief,
inscription, or other like object, or
(iv) does any act in contravention of sub-section (1) of section 19.
shall be punishable with imprisonment which may extend to three shall be punishable with
imprisonment which may extend to three months, or with fine which may extend to five
thousand rupees, or with both.

(2) Any person who moves any antiquity in contravention of a notification issued under
sub-section (1) of section 25 shall be punishable with fine which may extend to five
thousand rupees; and the court convicting a person of any such contravention may be order
direct such person to restore the antiquity to the place from which it was moved.

31.Jurisdiction to try offences.- No court inferior to that of a presidency magistrate or a

magistrate of the first class shall try any offence under this Act.

32.Certain offences to be cognizable.- Notwithstanding anything contained in the Code of

Criminal Procedure, 1898 (5 of 1898), an offence under clause (i) or clause (iii) of sub-
section (1) of section 30, shall be deemed to be a cognizable offence within the meaning of
that Code.
33.Special provision regarding fine.- Notwithstanding anything contained in section 32 of
the Code of Criminal Procedure, 1898 (5 of 1898), it shall be lawful for any magistrate, of
the first class specially empowered by the State Government in this behalf and for any
presidency magistrate to pass a sentence of fine exceeding two thousand rupees on any
person convicted of an offence which under this Act is punishable with fine exceeding two
thousand rupees.

34.Recovery of amounts due to the Government.- Any amount due to the Government
from any person under this Act may, on a certificate issued by the Director-General or an
archaeological officer authorised by him in this behalf be recovered in the same manner as
an arrear of land revenue.

35.Ancient monuments, etc., which have ceased to be of national importance.- If the

Central Government is of opinion that any ancient and historical monument or
archaeological site and remains declared to be of national importance by or under this Act
has ceased to be of national importance, it may, by notification in the Official Gazette,
declare that the ancient and historical monuments or archaeological site and remains, as the
case may be, has ceased to be of national importance for the purposes of this Act.

36.Power to correct mistakes, etc.- Any clerical mistake, patent error or error arising form
accidental slip or omission in the description of any ancient monument or archaeological
site and remains declared to be of national importance by or under this Act may, at any time,
be corrected by the Central Government by notification in the Official Gazette.

37.Protection of action taken under the Act.- No suit for compensation and no criminal
proceeding shall lie against any public servant in respect of any act done or in good faith
intended to be done in the exercise of any power conferred by this Act.

38.Power to make rules.- (1) The Central Government may, by notification in the Official
Gazette and subject to the condition of previous publication, make rules for carrying out the
purposes of this Act.

(2) In particular, and without prejudice to the generality of the foregoing power, such rules
may provide for all or any of the following matters, namely:-

(a) the prohibition or regulation by licensing or otherwise of mining, quarrying, excavating

blasting or any operation of a like nature near a protected monument or the construction of
buildings on land adjoining such monument and the removal of unauthorised buildings;

(b) the grant of licences and permissions to make excavations for archaeological purposes
in protected areas, the authorities by whom, and the retractions and conditions subject to
which, such licences may be granted, the taking of securities from licensees and the fees
that may be charged for such licensees;

(c) the right of access of the public to a protected monument and the fee, if any, to be
charged therefor;

(d) the form and contends of the report of an archaeological officer or a licensee under
clause (a) of sub-section (1) of section 23;

(e) the form in which application s for permission under section 19 or section 25 may be
made and the particulars which they should contain

(f) the form and manner of preferring appeals under this Act and the time within which they
may be preferred;
(g) the manner of service of any order or notice under this Act;

(h) the manner in which excavations and other like operations for archaeological purposes
may be carried on;

(i) any other matter which is to be or may be prescribed.

(3) Any rule made under this section may provide that a breach thereof shall be punishable,-

(i) in the case of a rule made with reference to clause (a) of sub-section (2), with
imprisonment which may extend to three months, or with fine which may extend to five
thousand rupees, or with both;
(ii) in the case of a rule made with reference to clause (b) of sub-section (2), with fine which
may extend to five thousand rupees;
(iii) in the case of a rule made with reference to clause (c) of sub-section (2), with fine
which may extend to five hundred rupees.

(4) All rules made under this section shall be laid for not less than thirty days before each
House of Parliament as soon as possible after they are made, and shall be subject to such
modifications as Parliament may make during the session in which they are so laid or the
session immediately following.

39.Repeals and savings.- (1) The Ancient and Historical Monuments and Archaeological
Sites and Remains (Declaration of National Importance) Act, 1951 (71 of 1951), and
section 126 of the States Reorganisation Act, 1956 (37 of 1956), are hereby, repealed.

(2) The Ancient Monuments Preservation Act, 1904 (7 of 1904), shall cease to have effect
in relation to ancient and historical monuments and archaeological sites and remains
declared by or under this Act to be of national importance, except as respects things done or
omitted to be done before the commencement of this Act.
IN THE HON’BLE HIGH COURT OF JUDICATURE AT ALLAHABAD.
(Under Article 226 of constitution of India)
Annexure No.

Civil Misc. Writ Petition No. of 2004

(District – Agra)

Institute of Rewriting Indian History Through its Founder President, P. N. Oak.

S/O Late Shri Nagesh Krishna Oak, R/O - Plot No. 10, Goodwill Society,
Aundh, Pune – 411007 and another…………..Pettioners

VERSUS

Union of India through Secretary,

Human Resources and Development (HRD),
Government of India, New Delhi. ……………….Respondents

THE FREEDOM OF INFORMATION ACT, 2002

[Act No. 5 OF 2003]

6th January, 2003

An Act to provide for freedom to every citizen to secure access to information under the
control of public authorities, consistent with public interest, in order to promote openness,
transparency and accountability in administration and in relation to matters connected
therewith or incidental thereto.

BE it enacted by Parliament in the Fifty-third Year of the Republic of India as follows:-

CHAPTER I
PRELIMINARY

1. Short title, extent and commencement.

(1) This Act may be called the Freedom of Information Act, 2002.

(2) It extends to the whole of India except the State of Jammu and Kashmir.

(3) It shall come into force on such date as the Central Government may, by notification in
the Official Gazette, appoint.

2. Definitions.
In this Act, unless the context otherwise requires,-
(a) "appropriate Government" means in relation to a public authority established,
constituted, owned, substantially financed by funds provided directly or indirectly or
controlled-

(i) by the Central Government, the Central Government;

(ii) by the State Government, the State Government;
(iii) by the Union territory, the Central Government;

(b) "competent authority" means-

(i) the Speaker in the case of the House of the People or the Legislative Assembly and
the Chairman in the case of the Council of States or the Legislative Council;
(ii) the Chief Justice of India in the case of the Supreme Court;
(iii) the Chief Justice of the High Court in the case of a High Court;
(iv) the President or the Governor, as the case may be, in the case of other authorities
created by or under the Constitution;
(v) the administrator appointed under article 239 of the Constitution;

(c)"freedom of information" means the right to obtain information from any public
authority by means of,-

(i) inspection, taking of extracts and notes;

(ii) certified copies of any records of such public authority;
(iii) diskettes, floppies or in any other electronic mode or through print-outs where such
information is stored in a computer or in any other device;

(d) "information" means any material in any form relating to the administration,
operations or decisions of a public authority;

(e) "prescribed" means prescribed by rules made under this Act by the appropriate
Government or the competent authority, as the case may be;

(f) "public authority" means any authority or body established or constituted,-

(i) by or under the Constitution;

(ii) by any law made by the appropriate Government, and includes any other body
owned, controlled or substantially financed by funds provided directly or indirectly by
the appropriate Government;

(g) "Public Information Officer" means the Public Information Officer appointed under
sub-section (1) of section 5;

(h) "record" includes-

(i) any document, manuscript and file;

(ii) any microfilm, microfiche and facsimile copy of a document;
(iii) any reproduction of image or images embodied in such microfilm (whether enlarged or
not); and
(iv) any other material produced by a computer or by any other device;

(i) "third party" means a person other than the person making a request for
information and includes a public authority.

CHAPTER II
FREEDOM OF INFORMATION AND OBLIGATIONS OF PUBLIC AUTHORITIES
3. Freedom of information.
Subject to the provisions of this Act, all citizens shall have freedom of information.

4. Obligations on public authorities

Every public authority shall-

(a) maintain all its records, in such manner and form as is consistent with its operational
requirements duly catalogued and indexed;

(b) publish at such intervals as may be prescribed by the appropriate Government or

competent authority,-

(i) the particulars of its organisation, functions and duties;

(ii) the powers and duties of its officers and employees and the procedure followed by
them in the decision making process;
(iii) the norms set by the public authority for the discharge of its functions;
(iv) rules, regulations, instructions, manuals and other categories of records under its
control used by its employees for discharging its functions;
(v) the details of facilities available to citizens for obtaining information; and
(vi) the name, designation and other particulars of the Public Information Officer;

(c) publish all relevant facts concerning important decisions and policies that affect the
public while announcing such decisions and policies;

(d) give reasons for its decisions, whether administrative or quasi-judicial to those
affected by such decisions;

(e) before initiating any project, publish or communicate to the public generally or to
the persons affected or likely to be affected by the project in particular, the facts available
to it or to which it has reasonable access which in its opinion should be known to them in
the best interests of natural justice and promotion of democratic principles.

5. Appointment of Public Information Officers.

(1) Every public authority shall for the purposes of this Act, appoint one or more
officers as Public Information Officers.

(2) Every Public Information Officer shall deal with requests for information and shall
render reasonable assistance to any person seeking such information.

(3) The Public Information Officer may seek the assistance of any other officer as he
considers necessary for the proper discharge of his duties.

(4) Any officer whose assistance has been sought under sub-section (3), shall render all
assistance to the Public Information Officer seeking his assistance.

6. Request for obtaining information.

A person desirous of obtaining information shall make a request in writing or through
electronic means, to the concerned Public Information Officer specifying the particulars
of the information sought by him:

Provided that where such request cannot be made in writing, the Public Information Officer
shall render all reasonable assistance to the person making the request orally to reduce it in
writing.
7. Disposal of requests.
(1) On receipt of a request under section 6, the Public Information Officer shall, as
expeditiously as possible, and in any case within thirty days of the receipt of the request,
either provide the information requested on payment of such fee as may be prescribed or
reject the request for any of the reasons specified in sections 8 and 9:

Provided that where the information sought for concerns the life and liberty of a person,
the same should be provided within forty-eight hours of the receipt of the request:

Provided further that where it is decided to provide the information on payment of any
further fee representing the cost of providing the information, he shall send an intimation
to the person making the request, giving the details of the fees determined by him,
requesting him to deposit the fees and the period intervening between the despatch of
the said intimation and payment of fees shall be excluded for the purpose of calculating the
period of thirty days referred to above.

(2) Before taking any decision under sub-section (1), the Public Information Officer
shall take into consideration the representation made by a third party under section 11.

(3) Where a request is rejected under sub-section (2), the Public

Information Officer shall communicate to the person making request,-

(i) the reasons for such rejection;

(ii) the period within which an appeal against such rejections may be preferred;
(iii) the particulars of the appellate authority.

(4) Information shall ordinarily be provided in the form in which it is sought unless it
would disproportionately divert the resources of the public authority or would be
detrimental to the safety or preservation of the record in question.

8. Exemption from disclosure of information.

(1) Notwithstanding anything hereinbefore contained, the following information not being
information relating to any matter referred to in sub-section (2), shall be exempted from
disclosure, namely:-

(a) information, the disclosure of which would prejudicially affect the sovereignty and
integrity of India, security of the State, strategic scientific or economic interest of India
or conduct of international relations;

(b) information, the disclosure of which would prejudicially affect public safety and order,
detection and investigation of an offence or which may lead to an incitement to commit an
offence or prejudicially affect fair trial or adjudication of a pending case;

(c) information, the disclosure of which would prejudicially affect the conduct of Centre-
State relations, including information exchanged in confidence between the Central and
State Governments or any of their authorities or agencies;

(d) Cabinet papers including records of deliberations of the Council of Ministers,

Secretaries and other officers;

(e) minutes or records of advice including legal advice, opinions or recommendations

made by any officer of a public authority during the decision making process prior to the
executive decision or policy formulation;
(f) trade or commercial secrets protected by law or information, the disclosure of which
would prejudicially affect the legitimate economic and commercial interests or the
competitive position of a public authority; or would cause unfair gain or loss to any
person; and

(g) information, the disclosure of which may result in the breach of privileges of
Parliament or the Legislature of a State, or contravention of a lawful order of a court.

(2) Subject to the provisions of clause (a) of sub-section (1), any information relating to
any occurrence, event or matter which has taken place occurred or happened twenty-five
years before the date on which any request is made under section 6 shall be provided to
any person making a request under that section:

Provided that where any question arises as to the date from which the said period of
twenty-five years has to be computed, the decision of the Central Government shall be
final.

9. Grounds for refusal to access in certain cases.

Without prejudice to the provisions of section 8, a Public Information Officer may reject a
request for information also where such request-

(a) is too general in nature or is of such a nature that, having regard to the volume of
information required to be retrieved or processed would involve unreasonable diversion
of the resources of a public authority or would adversely interfere with the functioning of
such authority:

Provided that where such request is rejected on the ground that the request is too general,
it would be the duty of the Public Information Officer to render help as far as possible to the
person making request to reframe his request in such a manner as ay facilitate compliance
with it;

(b) relates to information that is required by law, rules, regulations or orders to be published
at a particular time and such information is likely to be so published within thirty days of
the receipt of such request;

(c) relates to information that is contained in published material available to public; or

(d) relates to information which would cause unwarranted invasion of the privacy of any
person.

10. Severability.
(1) If a request for access to information is rejected on the ground that it is in relation to
information which is exempted from disclosure, then notwithstanding anything contained
in this Act, access may be given to that part of the record which does not obtain any
information that is exempted from disclosure under this Act and which can reasonably be
severed from any part that contains exempted information.

(2) Where access is granted to a part of the record in accordance with sub-section (1), the
person making the request shall be informed,-

(a) that only part of the record requested, after severance of the record containing
information which is exempted from disclosure, is being furnished; and

(b) of the provisions of the Act under which the severed part is exempted from
disclosure.
11. Third party information.

(1) Where a public authority intends to disclose any information or record, or part thereof,
on a request made under this Act which relates to, or has been supplied by a third party and
has been treated as confidential by that third party, the Public Information Officer shall,
within twenty-five days from the receipt of a request, give written notice to such third party
of the request and of the fact that the public authority intends to disclose the
information or record, or part thereof:

Provided that except in the case of trade or commercial secrets protected by law,
disclosure may be allowed if the public interest in disclosure outweighs in importance any
possible harm or injury to the interests of such third party.

(2) Where a notice is given by the Public Information Officer under sub-section (1) to a
third party in respect of any information or record or part thereof, the third party shall,
within twenty days from the date of issuance of notice, be given the opportunity to make
representation against the proposed disclosure.

(3) Notwithstanding anything contained in section 7, the Public Information Officer

shall, within sixty days after receipt of the request under section 6, if the third party
has been given an opportunity to make representation under sub-section (2), make a
decision as to whether or not to disclose the information or record or part thereof and give
in writing the notice of his decision to the third party.

(4) A notice given under sub-section (3) shall include a statement that the third party to
whom the notice is given is entitled to prefer an appeal against the decision under section
12.

12. Appeals.
(1) Any person aggrieved by a decision of the Public Information Officer may, within
thirty days of receipt of such decision, prefer an appeal to such authority as may be
prescribed:

Provided that such authority may entertain the appeal after the expiry of the said period
of thirty days if it is satisfied that the appellant was prevented by sufficient cause from
filing the appeal in time.

(2) A second appeal against the decision under sub-section (1) shall lie within thirty days
of such decision, to the Central Government or the State Government or the competent
authority, as the case may be:

Provided that the Central Government or the State Government or the competent
authority, as the case may be, may entertain the appeal after the expiry of the said period
of thirty days if it is satisfied that the appellant was prevented by sufficient cause from
filing the appeal in time.

(3) The appeals referred to in sub-sections (1) and (2) shall be disposed of within
thirty days of the receipt of such appeals or within such extended period, as the case may
be, for reasons to be recorded in writing.

(4) If the decision of the Public Information Officer against which the appeal is preferred
under sub-section (1) or sub-section (2) also relates to information of third party, the
appellate authority shall give a reasonable opportunity of being heard t that party.
CHAPTER III
MISCELLANEOUS

13. Protection of action taken in good faith.

No suit, prosecution or other legal proceeding shall lie against any person for anything
which is in good faith done or intended to be done under this Act or any rule made
thereunder.

14. Act to have overriding effect.

The provisions of this Act shall have effect notwithstanding anything inconsistent
therewith contained in the Official Secrets Act, 1923 (19 of 1923), and any other law for
the time being in force or in any instrument having effect by virtue of any law other than
this Act.

15. Bar of jurisdiction of courts.

No court shall entertain any suit, application or other proceeding in respect of any order
made under this Act and no such order shall be called in question otherwise than by way of
an appeal under this Act.

16. Act not to apply to certain organizations.

(1) Nothing contained in this Act shall apply to the intelligence and security
organisations, specified in the Schedule, being organizations established by the
Central Government or any information furnished by such organisations to that
Government.

(2) The Central Government may, by notification in the Official

Gazette, amend the Schedule by including therein any other intelligence or security
organisation established by that Government or omitting therefrom any organisation
already specified there and on the publication of such notification, such organisation shall
be deemed to be included in or, as the case may be, omitted from the
Schedule.

(3) Every notification issued under sub-section (2) shall be laid before each House of
Parliament.

(4) Nothing contained in this Act shall apply to such intelligence and security organisations
which may be specified, by a notification in the Official Gazette, by a State Government
from time to time.

(5) Every notification issued under sub-section (4) shall be laid before the State
Legislature.

17. Power to make rules by Central Government.

(1) The Central Government may, by notification in the Official Gazette, make rules to
carry out the provisions of this Act.

(2) In particular, and without prejudice to the generality of the foregoing power, such
rules may provide for all or any of the following matters, namely:-

(a) intervals at which matters referred to in sub-clauses (i) to (vi) of clause (b) of section 4
shall be published;
(b) the fee payable under sub-section (1) of section 7;
(c) the authority before whom an appeal may be preferred under sub-section (1) of
section 12;
(d) any other matter which is required to be, or may be, prescribed.
18. Power to make rules by State Government.
(1) The State Government may, by notification in the Official Gazette, make rules to carry
out the provisions of this Act.

(2) In particular, and without prejudice to the generality of the foregoing power, such
rules may provide for all or any of the following matters, namely:-

(a) the fee payable under sub-section (1) of section 7;

(b) the authority before whom an appeal may be preferred under sub-section (1) of
section 12;

(c) any other matter which is required to be, or may be, prescribed:

Provided that initially the rules shall be made by the Central Government by
notification in the Official Gazette.

19. Rule making power by competent authority.

(1) The competent authority may, by notification in the Official Gazette, make rules to
carry out the provisions of this Act.

(2) In particular, and without prejudice to the generality of the foregoing power, such
rules may provide for all or any of the following matters, namely:-

(a) the fee payable under sub-section (1) of section 7;

(b) the authority before whom an appeal may be preferred under sub-section (1) of
section 12;
(c) any other matter which is required to be, or may be, prescribed.

20. Laying of rules.

(1) Every rule made by the Central Government under this Act shall be laid, as soon as
may be after it is made, before each House of Parliament, while it is in session, for a total
period of thirty days which may be comprised in one session or in two or more successive
sessions, and if, before the expiry of the session immediately following the session or
the successive sessions aforesaid, both Houses agree in making any modification in the
rule or both Houses agree that the rule should not be made, the rule shall thereafter have
effect only in such modified form or be of no effect, as the case may be; so, however,
that any such modification or annulment shall be without prejudice to the validity of
anything previously done under that rule.

(2) Every rule made under this Act by a State Government shall be laid, as soon as
may be after it is notified, before the State Legislature.

21. Power to remove difficulties.

(1) If any difficulty arises in giving effect to the provisions of this Act, the Central
Government may, by order published in the Official Gazette, make such provisions not
inconsistent with the provisions of this Act as appear to it to be necessary or expedient for
removal of the difficulty:

Provided that no such order shall be made after the expiry of a period of two years from the
date of the commencement of this Act.

(2) Every order made under this section shall, as soon as may be after it is made, be laid
before each House of Parliament.
IN THE HON’BLE HIGH COURT OF JUDICATURE AT ALLAHABAD.
(Under Article 226 of constitution of India)
Annexure No.

Civil Misc. Writ Petition No. of 2004

(District – Agra)

Institute of Rewriting Indian History Through its Founder President, P. N. Oak.

S/O Late Shri Nagesh Krishna Oak, R/O - Plot No. 10, Goodwill Society,
Aundh, Pune – 411007 and another…………..Pettioners

VERSUS

Union of India through Secretary,

Human Resources and Development (HRD),
Government of India, New Delhi. ……………….Respondents

32 That some other glaring considerations are cited hereunder which are not
necessarily exhaustive, in support of the claim of the petitioner as under.
The Nomenclature of Taj Mahal is it-self the symbolic Tejomahalaya

i) That the term, “Taj Mahal” itself never figures in any Invader Court document or
chronicle even in Auranzeb’s time. The meaning of the term “Taj Mahal” is a crown among
residences, therefore the attempt to explain a Mausoleum as Taj Mahal is ridiculous and
absurd.

ii) That since the very name, Taj Mahal, means a crown place or a resplendent shrine
(Tejo Maha Alaya) and not a tomb, it cannot be a Mausoleum.

iii) That several European visitors of Shahjahan’s time allude to the building as Tej-e-
Mahal, which is almost the correct traditional, age-old Sanskrit name Tej-o-Mahalaya. If Taj
is believed to be a burial, how can the term “Mahal” i.e. a mansion apply to it? Both the
components of the name, viz. “Taj“ and “Mahal” are of Sanskrit origin but not of Arabic or
Parsian origin.
IN THE HON’BLE HIGH COURT OF JUDICATURE AT ALLAHABAD.
(Under Article 226 of constitution of India)
Annexure No.

Civil Misc. Writ Petition No. of 2004

(District – Agra)

Institute of Rewriting Indian History Through its Founder President, P. N. Oak.

S/O Late Shri Nagesh Krishna Oak, R/O - Plot No. 10, Goodwill Society,
Aundh, Pune – 411007 and another…………..Pettioners

VERSUS

Union of India through Secretary,

Human Resources and Development (HRD),
Government of India, New Delhi. ……………….Respondents

Relevant Evidence for exposer of truth in relation to the Authership of Taj Mahal

*****(A) That If a psycho analysis of the emperor is made, we will find that he was a
cruel hard-hearted stingy person devoid of any cultural or artistic softness, lacking any
generosity to lavish wealth on art and culture and particularly lasters of a man totally
committed to physical indulgence and such a person cannot build a world marvel in
memory of one his numerous wives. In fact none of the earlier or later Invader Emperors
had indulged in such a lavish sepulchral fantasy.

(B) That there is a record in history, by any of the historians of any part of the country or
by the Court chronicle of the Mughal Emperor about the date of death of Mumtaz. If such a
world-class monument is built, over a span of 22 years to mark the man’s love for the
woman, then why was the date of death not recorded in the court chronical the
Badshanama?

(C) That the name of the test is Carbon-14 Test which is well accepted scientific test to
determine the age of wood.

(D) That a piece of the wooden door (riverside eastern doorway) of Taj Mahal was tested
in an American Laboratory which revealed that door to be 300 years older than Shahjahan.

(E) That there is a lot of architectural evidence, which clearly indicates that the Taj Mahal
cannot be a Invader Monument architecturally. It does not have any similarity with any
monument, undisputedly built by a Invader Emperor or a Invader Architect.

(F) That the so-called claim, that the Taj Mahal was built by Shahjahan, can not be
satisfied the grammar of Architecture. On the contrary its architecture that it was a Hindu
Temple. The Architectural design of Taj Mahal does not accord with the claim of Invader
authorship of such a building.
(G) That Well known Western Authorities on Architecture such as E. B. Havell, Mrs.
Kenoyer and W. W. Hanter have recorded that the Taj Mahal is built in the Hindu Temple
Style. Havell points out that the ground plan of the Ancient Chandi Seva Temple in Java is
identical with that of the Taj in terms of architecture.

(H) There is nothing on record or in history that Shahjahan had any special infatuation for
Mumtaz. In fact history records that he used to run after various other women, starting from
his daughter (Jahanara) to his maids he had many wives and besides a harem of five
thousand women. His special love for Mumtaz is thus a psychological absurdity.

(I) The Human experience indicates that Carnal physical sexual love is an incapacitating
emotion. A womanizer ipso facto is incapable of any constructive activity. Thus a person
like Shahjahan cannot build a world marvel like Taj Mahal.

(J) That Encyclopedia Britannica states that Taj Mahal building consists of guestrooms,
guardrooms and stables. Those are all irrelevant, inconsistent and absurd in a mausoleum,
since a dead wife would not go out riding or entertaining guests at parties. Further it
comprises of about 500 rooms. Residential accommodation on such a stupendous scale is
unthinkable in a mausoleum. The Taj Mahal has pleasure pavilion which a tomb would
never have. Apart from existence of other Vedic tradition the most significant one is. The
Interior of the Dark Dome rising over Mumtaz’s Cenotaph has a figure-sketch of 8
directional shafts set in a small central circle, surrounded by other circle respectively
depicting 16 cobra, 32 tridents and 64 lotus buds. (the main dome is also lotuscapped). All
those motifs being multiples of eight are of Vedic significantly Cobra, Lotus and Trident are
always associated with Lord Shiva. The Mehtab garden is innundated and looks desolate. Its
scenic beauty will reappear only when the floods recede”. The rear portion of the building
complex remains safe is a mystery. The stream keeping away from the rear wall has
prevented damage.
Thus from Aurangzeb’s noting, i.e “On Saturday too I visited the spot and then I
called on the Prince (Dara) who also paid me a return visit. Then taking leave of all I
resumed my journey (to take charge as govrneor of the Deccan) on Sunday and today
the 8th instant I am in the vicinity of Dholpur…”
It is apparent that in 1652 A.D. itself the Taj Mahal building complex had become so
ancient that it needed elaborate repairs. So what was carried out in 1652 A.D was not
the completion of a new building but the repairs to an old building complex. Had The
Taj Mahal been a building completed in 1653 it would not have fallen to the lot of a
chance , lone visitor like Aurangzeb to notice the defects and order repairs in
1652.The defects should have been noticed by the thousands of workmen and
hundreds of court supervisors who were supposed to be building the Taj Mahal. And
since such serious defects had been in fact noticed a year before completion all the
tom-tomming of the “master –builders” of the Taj is utterly unjustified. The builders
of the Taj were no doubt master-craftsmen but they were not Shahajahan’s
contemporaries but Hindus of several centuries earlier. Similarly it was not Shahjahan
who commissioned the Taj Mahal but some ancient Hindu king . Likewise the Taj did
not come into being as an Islamic mausoleum but as Hindu temple –palace. The
builders of the Taj Mahal –ancient secret revealed
“Tourists come from the world over to see Taj at Agra and all marvel at the genius
of the architects that could plan and accomplish so lovely a “dream of marble”.
(K) They were commissioned by the Mogul emperor Shahjahan to raise a
mausoleum befitting his love for Mumtaz Mahal , his beloved consort ; and they
created this Wonder of the world.
(L) “Yet, despite strenuous efforts to discover it , their identity had remained a
mystery ;wild guesses as to their origin being foreign were abroad. Even Bernier
(1642 A.D.) notes only a rumour that the architect was killed lest the secret of his
art be revealed and a rival to Taj created.
(M) “But the secret has at long last been found in a manuscript book discovered
lately in the library of Mr.Mehmud Khan of Bangalore. The glory of building the
Taj belongs definitely to India,to a family of Lahore architect, Ahmad, the father
,and his three sons. The book is in Persian verses in the Persian character, its
author being Lathfullah Maaahandis, himself one of the three son architects and it
is almost 300 years old, falling within the last years of Shahjahan’s reign.
(N) It has been declared to be the only copy in the world, by the well-known
authority on these matters , Syed Suleiman Sahib Nadvi,Principal ,Shibly
Academy ,Azamgarh.
(O) “The book is in Mahandis’ own handwriting .As is noticed from different verses,
the author was a staunch follower of Dara Shikoh , Shahjahan’s eldest son ,and
when Aurangzeb finally came to power, after defeating Dara Shikoh, the author
and his family suffered. He sent a petition to the emperor but as it was not heeded
the family had to retire into seclusion and poverty.
(P) “It seems that the book was very secretly kept by the family in fear of Aurangzeb
,as it contained verses in praise of Dara Shikoh .The subsequent dates and writing
on the last page show that the book was brought and kept in the library of the
library of the historical personage Nawab Ebrahim Khann Hazbar Jung ,the
famous Mahammedan general nick named Gardy ,who sided with the Maharatas
in the battle of Panipat in 1761 against Ahmed Shah Abdali.The book has been in
the family of the present owner for generations, but it was not noticed until
Moulana Syed Suleiman Nadvi ,the well known historian, author and editor of the
Moariff (the monthly journal of the Society of Authors and Shibly Academy,
Azamgarh ,U.P.) Discovered it and, on information gleaned from it, read a lengthy
Urdu paper on the builders of the Taj in Punjab University.
(Q) “In the verses on two pages of the book described in the article, the author
praises Shahjahan ,and speaks of his father Ahmed, the ‘Nadar–ul-Asar’ (the
unique of the world ),as supreme master craftsman, geometer ,astronomer and
prosateur .He was appointed court architect by Shahjahan’s Ryal Warrant ,and
was the builder of the Taj Mahal at Agra and the Lal Quila (Red Fort) at Delhi.
He died in 1649,two years after the Taj was built .The author his son and co-
architect of the Taj learnt at his feet.”
(R) Article titled Some Facts About the Taj Mahal by Mohammed Din, published in
The illustrated weekly of India dated December 30,1951.The article runs thus:
(S) “When The Taj Mahal was built, the many mechanical aids available today were
unheard of; yet the extraordinary ingenuity employed in its construction and the
high degree of engineering skill evidenced in its design make the mind pause.
(T) Not less remarkable were the talent and skill of the artisans employed. In
translating this fabulous architectural dream into brick and mortar, and area 967 ft.
long and 373 ft. wide was excavated to a depth of 44 ft. where sub-soil water was
met .The whole excavated area was filled in mass with rubble stone in hydraulic
lime to provide a common foundation for the three heavy structures, the Taj Mahal
, Jamaet – Khana and one mosque which were to be raised close to one another.
About 20,000 men were engaged on this work.
(U) “Over this foundation the plinth of the Taj Mahal , 313 ft. square and 8 ft. high,
was built in stone with hydraulic lime mortar and marble stone casing. The casing
was laid after the rubble masonry was raised to its designed height, then the
marble facing was set.
(V) “The main engineering problem was to haul up the materials to the required
height during the progress of the work. This was done by constructing wooden
pillars of square timber posts bundled together and skillfully tied with top levels
at different heights, and so spaced as to carry a strong platform 40 ft. wide and a
spiral roadway with a slope of 1 in 20, to permit loaded mules and mule carts to
run over it, and to hold dumps of materials for construction work. This spiral
platform was continuous and ran all round the dome, and remained in position till
 the work was raised to its designed height of 240 ft. above ground level. Special
engineers were engaged to build the scaffolding and platform, and 500 carpenters
and 300 blacksmith were employed on this project alone. The total length of the
spiral platform was about 4,800 ft. The mortar was hoisted by means of Persian
wheels, which were fitted on the spiral platform. These were worked by bullocks
and mules.
(W) “The materials for the massive work were brought from many distant places. The
marble stone was obtained from Makrana in Rajputana ,for which about a
thousand elephants were engaged. The maximum weight of a block of stone was
about 2.5 tons, which is the safe carrying capacity of an elephant. A number of
elephants were also engaged to work the pulleys.
(X) “The timber for scaffolding was brought from the Kashmir and Naini Tal areas.
About 2000 camels and 1000 bullock carts were employed for carting bricks and
light materials to the construction site and about 1000 mules for lifting the
materials along the spiral platform.
(Y) “The marble stone required for drum and dome was dressed on the ground and
then lifted and laid in position by means of pulleys…
(Z) “After the main dome and drum work was finished, work on annexes and
subsidiary buildings was taken in hand and completed in the same manner.
(AA) There are four minarets at the four corners of the Taj Mahal …
(BB) “The river Jumna was half a mile away from the structure. After the building was
completed , the river was diverted artificially to flow alongside the Taj to add to
the beauty of landscape.
(CC) “Contemporary Invader writers recorded the names of those who designed and
constructed the Taj Mahal, and the names and quantities of precious stones used. It
appears that Mohammed Isa Afandi, of turkey, was the chief designer and
draftsman. Among the other foreigners employed on the construction, there were
men from Arabia ,Persia, Syria ,Baghdad and Samarkand and there was at least
one Frenchmen, Austin de Bordeaux, a goldsmith.
(DD) The precious stones used included 540 pieces of cornelian from Baghdad, 670
turquoises from upper Tibet, 614 malachite’s from Russia ,559 onyxes from
Deccan and 625 diamonds from Central India. The construction of Taj Mahal was
begun in 1632 and was not completed till 1650.It is believed to have cost more
than a crore and a half of rupees which in terms of the present value of money
,would be at ten times as much .Two thirds of this were contributed by the State
office and one third by third by the State treasury of the province. The allocations
of expenditures on different parts of the structure have been carefully recorded in
documents which are still existent.
(EE) “Shahjahan, magnificent in his kingship, was equally magnificent in his
sorrows. This exquisite memorial of an emperor’s love was built by the sorrowing
Shahjahan for his departed spouse. He manifestly designed it to go down in
history to a worshipful posterity; three hundred years after, it is still acclaimed as
one of the supreme achievements of the architect.
(FF) The measurement mentioned could of course always be taken from the erstwhile
Hindu Temple palace, which stands before us today as the Taj Mahal, and stuffed
into any post-mortem of the construction.
(GG) The account of how the edifice was erected is apparently the result of an hind-
sight post-mortem carried out by some contemporary architects, as far as they can
visualize it .As for the 500 carpenters and 300 blacksmiths and such others
employed, we have no special objection because that many would be easily
absorbed in erecting even a scaffolding around the massive Hindu Temple palace,
which the Taj Mahal is, to convert it into a Invader tomb.
IN THE HON’BLE HIGH COURT OF JUDICATURE AT ALLAHABAD.
(Under Article 226 of constitution of India)
Annexure No.

Civil Misc. Writ Petition No. of 2004

(District – Agra)

Institute of Rewriting Indian History Through its Founder President, P. N. Oak.

S/O Late Shri Nagesh Krishna Oak, R/O - Plot No. 10, Goodwill Society,
Aundh, Pune – 411007 and another…………..Pettioners

VERSUS

Union of India through Secretary,

Human Resources and Development (HRD),
Government of India, New Delhi. ……………….Respondents

The following conclusions emerge from what Emperor Shahjahan’s own

court chronicler has recorded in the official history of the reign, Badshahnama :
1.The Taj Mahal is a Hindu palace.
2.It has around it a majestic and spacious garden.
3.The huge building complex was obtained in exchange (if at all ) for almost a song, i.e. at
best transferring to the owner an open plot of land. This too seems fishy because the
location and the size of the plot of land are not mentioned. Most probably it was just a
blatant expropriation effected by turning Jaisingh out of his wealthy ancestral palace. The
detail that Jaisingh was compensated by gifting him on open plot of land is obviously a
royal Islamic bluff to cover up the fact that Raja Jaisingh was blatantly robbed of his
wealthy temple-palace.
4.The Hindu palace had a dome.
5.Mumtaz was buried, so they say, under that dome soon after her exhumed body was
brought from Burhanpur to Agra, if at all.
6.The estimated expenditure (to transform the Hindu Palace into a Invader tomb ) was
Rs.40 lakhs .(the actual expenditure is unknown ).
7.Of the above sum , Rs.5 lakhs was spent on the grave and cenotaph and the balance of Rs
35 lakhs on the scaffolding and the Koranic engravings.
8.Designer or architects are out of the picture, since the Taj Mahal was never raised by
Shahjahan.
9.The Hindu palace was known as Mansingh’s palace during Emperor Shahjahan’s time
though it was in the occupation of his grandson Jaisingh.
IN THE HON’BLE HIGH COURT OF JUDICATURE AT ALLAHABAD.
(Under Article 226 of constitution of India)
Annexure No.

Civil Misc. Writ Petition No. of 2004

(District – Agra)

Institute of Rewriting Indian History Through its Founder President, P. N. Oak.

S/O Late Shri Nagesh Krishna Oak, R/O - Plot No. 10, Goodwill Society,
Aundh, Pune – 411007 and another…………..Pettioners

VERSUS

Union of India through Secretary,

Human Resources and Development (HRD),
Government of India, New Delhi. ……………….Respondents

The above account being fairly plausible fits with the truth that the Taj Mahal is
an ancient Hindu palace commandeered for conversion into a Invader tomb.
In spite of this fundamental vagueness we would have accepted the duration
of the period during which the Taj Mahal was a building if there had been any consensus
about it among historians. Unfortunately, there is none .See how many versions are there:
1.The Maharashtreeya Jnyankosh quoted (Pp. 35-36 ,Maharashtreeya Jnyankosh ,ibid,Vol.
15) says that the “construction commenced in 1631 A.D. and ended in January 1643
A.D.”That gives a period of a little less than 12 years .
2.The encyclopaedia Britannica (P. 758, Encyclopaedia Britannica ,1964 Ed.,Vol. 21) says
“the building was commenced in 1632.More than 20,000 workmen were employed daily to
complete the mausoleum building itself by 1643,although the whole Taj complex took 22
years to complete .Unlike the first encyclopaedia ,the latter gives us two separate periods
:one of 10 to 11 years and the other of 22 years. About this latter period of 22 years we
would also like to know why the mausoleum needed a building complex containing stables
and guard and guest rooms was Mumtaz still supposed to go riding, casting away the burqa
and escorted by large cavalry contingents? Was she also expected to receive guests?
3.Tavernier’s account runs completely counter to all Invader versions, which form the basis
of the encyclopedic accounts quoted above. The Encyclopaedia Britannica account is
actually as amalgam of the Tavernier and Invader accounts in as much as it borrows the
figure of 20,000.workmen and 22 years from Tavernier while deftly weaving in it the 11or
12 year period fancied in Invader accounts.
Tavernier (PP.109-111, Travels in India, ibid.) says he witnessed the commencement and
accomplishment of this great work on which they expended 22 years during which 20,000
men worked incessantly .The cost of it has been enormous. The scaffolding alone cost more
than the entire work…”
Even presuming that Tavernier arrived in Agra in 1641, and the work began soon after his
arrival there, it should have lasted from 1641 to 1663.But Shahjahan was deposed and
imprisoned by his son Aurangzeb in 1658 .How then could the work of the Mumtaz
mausoleum proceed until 1663,i.e. five years after his losing control of state affairs ? And if,
in fact, It did, what are we to make some Invader accounts, which claim that the work had
ended in 1643? Then again, is the problem of the commencement of the construction still
remains hanging in air.
4.Mr.Mohammed Din’s article (The Illustrated weekly of India dated Dec 30,1951.) asserts
“the construction of the Taj Mahal was begun in 1632 and was not completed till
1650”.Mr.Mohammed Din seems to be sure only of the date when the building commenced
.If we take 1632 as the year of commenced then what are we to make of Tavernier’s
assertion that work started in his presence ?
5.Yet another version estimates the Taj Mahal to have been under construction for 17 years
.This is from Mr.Arora’s book (P. 10 City of Taj by R.C.Arora ,printed at the Hiberninan
Press,15 Portuguese Church Street ,Calcutta). He says “Shahjahan commenced building the
Taj in 1631,the fourth year his accession .The splendid mausoleum was completed in 1648.
It is not even certain that Mumtaz died in 1630.Even assuming that she died in 1630 she
perhaps died towards the close of that year. In such a case is it possible for the emperor to
make a decision to build a dreamland monument, have a huge amount sanctioned for it,
broadcast his scheme to distant lands, have artists prepare plans have them sent to
Shahjahan, from among which, we are told ,he selected one ,have a wooden model
constructed ,the necessary workmen collected, the bewildering variety of material ordered
and construction begun all by 1630?
6. A like version is also found in The Columbia Lippincott Gazetteer(P. 19 ,Vol II). It states:
“the beautiful Taj Mahal (built 1630-1648) probably the most noted mausoleum in the
world.. etc .etc. All the arguments repeated above apply to this Gazetteer version too,
namely, that since we are not even sure whether Mumtaz died in 1630, how could calling
for mausoleum plans, selecting one, ordering the building material etc. all be done just in
one year?
Since bricks (and timber) are generally bought and used soon after being marketed (and are
not stored for generations like diamonds, bullion and ornaments) thermoluminescence is
very helpful in determining the age of a brick-structure fairly accurately. The carbon – C14
test is applicable to anything, which had been part of a living organism such as piece of
bone or timber. A living tree continues to breathe in carbon di oxide while alive.But once it
is dead the breathing in stops and the dead piece continues to lose its carbon di oxide
(including C14) content at a known rate.
The report published in the Itihas Patrika (a quarterly journal,Vol 4 No. 4 dated 31
December 1984,THANA)is produced hereunder….
Sample 1
“Wood piece from door at North (east) end of Taj Mahal at beach level fronting on Jumna
River.
“Age 1359+ - 89 A.D. Thus there is a 67% probability that the age of the sample lies
between 1448 and 1270 A.D.
Submitted by Evan T.Williams
Professor of chemistry
City University of New York,
Brooklyn College,
Brooklyn,N.Y.,11210
IN THE HON’BLE HIGH COURT OF JUDICATURE AT ALLAHABAD.
(Under Article 226 of constitution of India)
Annexure No.

Civil Misc. Writ Petition No. of 2004

(District – Agra)

Institute of Rewriting Indian History Through its Founder President, P. N. Oak.

S/O Late Shri Nagesh Krishna Oak, R/O - Plot No. 10, Goodwill Society,
Aundh, Pune – 411007 and another…………..Pettioners

VERSUS

Union of India through Secretary,

Human Resources and Development (HRD),
Government of India, New Delhi. ……………….Respondents

1.It is of crystal white marble as mentioned in the inscription .

2.Its pinnacle and entrance arches bear the trident (trishul) which is an exclusive emblem of
Chandramauleeshwar.

3.The edifice is said to have been of such captivating beauty that the Lord (Shiva)
Chandramauleeshwar never again thought of returning to his Himalayan abode of Kailas.

4.The Taj Mahal garden included plants and tress all sacred to Hindus. Among them is the
Bel and Harshringar ,the leaves and flowers of which are considered a necessity for the
worship of lord Shiva.
5.The central Chamber of the Taj Mahal which is now believed to contain the cenotaphs of
emperor Shahjahan and his wife Arjumand Banu Begum has around it ten quadrangular
chambers providing a perambulatory passage for devotees as is the Hindu custom.

6.As the devotee passes through each of those rooms, ventilators provide him a view of the
centre of the octagonal central chamber where the emblem of Lord Chandramauleeshwar
was consecrated.

7. The high dome of the Taj Mahal central chamber with its reverberative effect provided
the proper gimmick to produce the ecstatic din that accompanies the worship of Lord
Shiva when he is supposed to perform the cosmic(Tandava Nritya) dance amidst the
blowing of conches, beating of drums and tolling of bells.

8.The high dome is also a common feature of Shiva temples to enable the hanging of a
pitcher for water to drip over the emblem of Lord Shiva. The chain which held the pitcher
still remains suspended from the centre of the dome.
9.Silver doors and gold railings mentioned as fixtures of the Taj Mahal are a common
feature of Hindu temples surviving even to our own day .Had the gold railing, fancied to
have been provided for Mumtaz’s tomb, been subsequently removed one should have seen
holes in the mosaic flooring for the props which supported the railing. There are no such
holes. That means that it was Shahjahan who removed the gold railing of the ancient Hindu
Shiva temple and carried it away to the treasury, before using the location of the Hindu idol
to graft an Islamic cenotaph. Visitors may also notice there an ancient Hindu colour sketch
of eight directional pointers,16 cobras,32 tridents and 64 lotus buds all Hindu motifs in
multiples of eight That design is sketched in the concave domed ceiling of the octagonal
central chamber, which anyone standing close to Mumtaz’s cenotaph may look up and see.

10.Guides at the Taj Mahal still mention a tradition of a drop of rainwater dropping from the
high dome top on the cenotaph within. This obviously is a remnant of the past memories of
the water dripping on the emblem of Lord Shiva from the pitcher.

11.Tavernier mentions the six courts in the Taj Mahal building complex where a bazar used
to be held.It is common knowledge that in Hindu tradition bazars and fairs are invariably
held around temples which constitute the focal points of Hindu life.

12.The trident(trishul) which is Lord Shiva’s exclusive weapon is also inlaid at the apex of
the Taj Mahal’s marble entrance arches on all four sides It is in red and white lines exactly
as some Hindus wear in colour on their foreheads. Its being installed there at the apex of
the entrance arches clearly proves that it is an unmistakable Shiva temple.

13.A full length design of the entire trident pinnacle as it towers above the dome, has been
inlaid in the red stone yard to the right of the Taj Mahal as we stand facing the marble
edifice. This again proves its Hindu origin since it has been a tradition in Hindu architecture
to inscribe the basic scale used in the construction of every building ,somewhere in the
premises. In the case of Taj Mahal the length of its trident pinnacle may be the basic scale
used in raising the Shiva temple.

14.The ‘Taj Mahal itself is far from Persian .It is a corrupt from of the Sanskrit term “Tejo
Maha Alaya meaning Resplendent Shrine “It was known as resplendent shrine because it
reflects a dazzling sheen in sunlight and moonlight. That name also attaches to it because
Lord Shiva’s third eye is said to emit a jet of lustre i.e. teja.The tarditional conjecture that
the term Taj Mahal derives from the name of Mumtaz Mahal porves baseless on closer
scrutiny.

15. Apparently Akbar did not dispossess the Jaipur royal family of the Taj Mahal because
the Jaipur family was his strongest Hindu ally and its scion ,Bhagwandas and Mansingh
were his most trusted generals. They were also in laws of the Mogul rulers.That after
Humayun’s defeat the Taj Mahal passed into the hands of the Jaipur royal family is apparent
from Emperor Sahhajahan’s chronicle which admits having commandeered The Taj Mahal
from Jai Singh ,the then head of the Jaipur royal family.

16.Besides the trident pinnacle, there are other Hindu symbols in the Taj namely the conch,
the lotus and the sacred Hindu chant “OM” in Devanagiri character.
IN THE HON’BLE HIGH COURT OF JUDICATURE AT ALLAHABAD.
(Under Article 226 of constitution of India)
Annexure No.

Civil Misc. Writ Petition No. of 2004

(District – Agra)

Institute of Rewriting Indian History Through its Founder President, P. N. Oak.

S/O Late Shri Nagesh Krishna Oak, R/O - Plot No. 10, Goodwill Society,
Aundh, Pune – 411007 and another…………..Pettioners

VERSUS

Union of India through Secretary,

Human Resources and Development (HRD),
Government of India, New Delhi. ……………….Respondents

We have cited five direct proofs to establish that the Taj is an ancient Hindu palace.These
are:

1.Shahjahan’s own court chronicler Mulla Abdul Hamid’s admission.

33
2.Mr.Nurul Hasan Siddiqui’s book, The City of Taj, reiterates the same position.

34 3.Tavernier’s testimony too establishes that a lofty palace had been obtained, and that it
was a world tourist attraction even before Mumtaz’s burial.

35 4.Emperor Shahjahan’s great great grandfather Babur’s Memoirs refer to the Taj Mahal
104 years before Mumtaz’s death whose tomb the Taj is supposed to be.

36 5.The Encyclopaedia Britannica has been quoted to show that the Taj Mahal building
complex comprises guest rooms, guard rooms and stables. These are all adjuncts of a
temple palace but never of a tomb.
37 In addition to the above we have ,in the foregoing pages,advanced many other proofs as
follows:

38 6.The very name Taj Mahal means a crown palace or a resplendent shrine (Tejo Maha
Alaya) and not a tomb .
39
40 7.Shahjahan’s reign was as full of turmoil and warfare as that of most other Invader
rulers of India. He could not therefore, have any wealth, peace, security or inclination to
launch on such an ambitious project as the Taj Mahal.

41 8.Shahjahan’s lechery and profligacy ruled out any special attachment to Mumtaz,
whose mausoleum the Taj has been misrepresented to be.
42 9.Shahjahan was cruel, hard hearted and stingy ;as such he could never have the artist’s
soft heart and a liberal patron’s generosity to lavish wealth on a building to house a
corpse.Mulla Abdul Hamid Lahori, the court chronicler, mentions no architect and
estimates the cost of the work done to be only Rs 40,00,000 which clearly shows that no
new building was erected.

43 11.Shahjahan, whose reign was supposed to be a golden period of history, has not left
even a scrap of authentic paper about the construction of Taj Mahal. There are no
authentic orders commissioning the Taj ,no correspondence for the purchase or
acquisition of the so-called site ,no design drawings no bills or receipts and no expense
account sheets Some of those usually produced or referred to have already been proved
to be forgeries.

44 12.Had Shahjahan really been the conceiver of the Taj Mahal, he need not have specially
instructed Mulla Abdul Hamid Lahori not to forget mentioning or describing its
‘construction’ in the official chronicles, because the grandeur and majesty of the Taj as
the finest achievement of a ruling monarch could never be lost sight of by a paid court
chronicler.

45 13.That Shahajahan could not even in his wildest dreams conceive undertaking such a
gorgeous project is apparent from the fact that even the Invader accounts tell us that he
made the workers toil on meagre rations without giving them any cash payment.
Tavernier tells us that Shahjahan could not marshal even timber enough for as much as
scaffolding. Some accounts have also pointed out that Shahjahan made Rajas and
Maharajas pay a large part of the “cost”. So even the additions and alterations required
in converting a Hindu palace to the semblance of a Invader tomb were made by
compelling labourers to toil for a mere meagre food allocation and by imposing levies on
subservient chieftains.

46 14. If a stupendous monument like the Taj Mahal were specially built for the burial of a
consort there would be a ceremonial burial date and it would not go unrecorded. But not
only is the burial date not mentioned but even the approximate period during which
Arjumand Banu Begum may have been buried in the Taj Mahal varies from six months
to nine years of her death.

47 15. Mumtaz was married to Shahjahan when the latter was 21 years old. Royal children
in his times used to be married much before their teens. This shows that Arjumand Banu
was Shahjahan’s umpteenth wife. There was thus no reason why she should have been
buried in a special monument.

48 16. Having been a commoner by birth Arjumand Banu was not entitled to a special
monument

49 17.History makes no special mention of any out of the way attachment or romance
between the two, unlike that of Jahangir and Nurjahan. This shows that the story of their
love is a concoction seeking to justify the myth about the building of the taj over her
body.

50 18. Shahjahan was no patron of art. Had he been one, he would not have had the heart to
chop off the hands of those who are said to have toiled to ‘build’ the monument for his
wife. An art lover especially one disconsolate on his wife’s death,would not indulge in
an orgy of maiming skilful craftsman. But the maiming story is apparently true because
made to toil mercilessly on meagre rations on a palace usurped from its erstwhile Hindu
master, the infuriated workmen broke out in revolt.
51 19.There is no record in history that Shahjahan had any special infatuation for Mumtaz.
In fact history records that he used to run after various other women from his own
daughter to his maids.

52 20.The existence of the landing ghat at the rear suggests a temple palace, not a tomb.

53 21.Even the central marble structure consists of a 23-room marble palace suit which is
superfluous for a tomb.

54 22.The plan tallies with ancient Hindu architectural design and specifications.

55 23.The entire Taj building consists of over 1000 rooms along its corridor, in two
basements, on the upper floors and in its numerous towers, which clearly bears out the
contention that it was meant to be a temple palace.

56 24. The many annexes guard and guest rooms etc. prove that it is a temple palace. The
pleasure pavilions in the Taj premises could never form part of a tomb but only of a
palace.

57 25.The Taj complex houses a pair of Nakkar Khanas, i.e. drum houses. Drum houses
58 are not only superfluous in a tomb but it is a positive misfit because a departed soul
needs peace and rest. On the other hand a drum house is a necessary concomitant of a
temple-palace because drum beats are used to herald royal arrivals and departures
summoning of the townsfolk for royal announcements and proclamations and announce
divine worship time.

59 26.The Taj building complex also contains cowpen which used to be part of all Hindu
royal and temple premises.

60 27.The Sanskrit words “Kalas” and “pranchi” (fenced off open spaces around the dome
and other structures) would never have been in the Taj premises had it originated as a
Invader tomb.

61 28.The decorative patterns and motifs throughout the Taj Mahal are not only entirely of
Indian flora but also of sacred Hindu emblems like the lotus, which infidel
characteristics, according to Islamic beliefs would never allow any peace to the soul of
the Invader lady, if any, lying buried beneath.

62 29. The galleries, arches, supporting brackets and cupolas are entirely in the Hindu style
such as can be seen all over Rajasthan.

63 30. Like every other suspicious aspect of Taj, its period of construction is variously
stated to be 10,12,13,17 or 22 years, which again proves that the traditional story is a
concotion.

64 31.Even Tavernier’s testimony that he saw the commencement and the end of this work,
while weakening the traditional case, strengthens ours.

65 32. The reports that Shahjahan levied large amounts on rajas and Maharajas and that the
so-called (tampering) work dragged on over 10,12,13,17,or even 22 years are all very
true details. Since Shahjahan was too shrewd and hard headed to spend anything out of
his own treasury and would lose no opportunity of taxing and persecuting the local
people, he made political capital even out of the death of his own wife.
66 33.The designers are variously mentioned by Western scholars to be Europeans, and are
claimed by Invaders to be Invaders, while the Imperial Library Manuscript contains
Hindu names.

67 34.The Taj Mahal had a grand garden. A graveyard never boasts of luscious fruits and
fragrant flower trees, since the idea of enjoying fruit and flowers of a graveyard orchard
68 is revolting.

69 35.The trees, moreover were those bearing Sanskrit names and select sacred plants at
that ,like Ketaki, Jai, Jui, Champa, Maulashree, Harshringar and Bel.

70 36.The designer of Taj is unknown.

71 37.Far from causing him any expenditure, the Taj proved to be a veritable gold mine for
Shahjahan. While Arjumand Banu was buried in a stripped, cold,stone temple palace, the
building was robbed of all its costly trappings which were removed to Sahjahan’s
treasury.

72 38. The Taj palace is located in the twin township of Jaisinghpura and Khawaspura
which are Rajput words, not Invader.”Pura” in Sanskrit signifies a busy locality and not
an open plot of land as is sometimes claimed.
73 39.The Taj Mahal entrance faces south. Had it been a Invader building it should have
faced west.

74 40.Its decorative and marble work tallies exactly with that in the Amer(Jaipur) palace
built circa 967.

75 41.The Taj temple palace has various other annexes outside its outer peripheral redstone
wall, meant for courtiers and palace staff.

76 42. Akbar on his early visits to Agra used to stay in Khawaspura and Jaisinghpura, which
clearly shows that he stayed in the Taj .

77 43.Bernier,another foreign visitor to Shahjahan’s court, tells us that the nether chambers
had a rare magnificence and no non-invader was allowed entry to them.That shows the
hush-hush secrecy maintained about them.

78 44.Even the term Taj Mahal doesn’t figure in any Mogul court records.
IN THE HON’BLE HIGH COURT OF JUDICATURE AT ALLAHABAD.
(Under Article 226 of constitution of India)
Annexure No.

Civil Misc. Writ Petition No. of 2004

(District – Agra)

Institute of Rewriting Indian History Through its Founder President, P. N. Oak.

S/O Late Shri Nagesh Krishna Oak, R/O - Plot No. 10, Goodwill Society,
Aundh, Pune – 411007 and another…………..Pettioners

VERSUS

Union of India through Secretary,

Human Resources and Development (HRD),
Government of India, New Delhi. ……………….Respondents
 IN THE HON’BLE HIGH COURT OF JUDICATURE AT ALLAHABAD,
AFFIDAVIT
IN

. Civil Misc. Writ Petition No. of 2004

(Under Article 226 of constitution of India)
(District – Agra)
Institute of Rewriting Indian History Through its Founder President, P. N. Oak.
S/O Late Shri Nagesh Krishna Oak, R/O - Plot No. 10, Goodwill Society,
Aundh, Pune – 411007 and another
VERSUS
Union of India through Secretary,
Human Resources and Development (HRD),
Government of India, New Delhi. And others …Respondents
Affidavit of Pankaj Kumar ,Advocate, High Court
Aged about 26 years s/o Sri Lal Bahadur singh
R/O. 203,Preetam Nagar, Sulem Sarai
Housing scheme, Allahabad
( DEPONENT)
I, the above named Deponent, do hereby solemnly affirm and state as follows:
1. That the deponent is the active life member of the Institute of Rewriting Indian
History and has been authorised Through its Founder President, P. N. Oak. S/O Late
Shri Nagesh Krishna Oak, R/O - Plot No. 10, Goodwill Society,Aundh, Pune – 411007
petitioner No. 2 of writ petition to file the affidavit in support of writ petition and as
such he is fully acquainted with the facts deposed to below.
2.That Sri P.N. Oak was born on 2nd March 1917 at Indore and he faught the battle of
indendence in association with Neta Ji Sri Subhash chandra Bosh and thereafter
conducted the research on the ancient Vedic Cultural Heritiage in India and also in
different part of the World. He is now running at the age of 87 years and is suffering
from ailments due to old age and as such authorised the deponent to file this affidavit,
which may kindly be accepted by this Hon’ble Court .

That the contents of paragraphs 1 and 2 of this affidavit and those of paragraphs
no.1,2,20,21,22,23,24,25,26,27,28,30,31,34,35,36,37,39,40,41,42,43,45,49,50,51,52,53,5
4,55,56,59,64,65,76,82,85,90,94,95,97,100,108,114,127,129,132,133,134,135,139,143,14
4,145,146, 148,149,154,155, of the writ petition are true to the personal knowledge of the
deponent, those of paragraphs no.,3,4,5,6,7,8,9,10,11,12,13,14,
15,16,17,44,46,47,48,57,58,60,61,62,63,66,68,69,70,71,72,73,74,75,77,78,79,80,81,83,84
,86,87,88,89,91,92,93,96,98,99,101,12,103,104,105,106,107,109,110,111,112,113,115,116
,117,118,119,120,121,122,123,124,125,126,128,130,131,136,137,138,140,141,142,147,15
0,151,152,153, of the affidavit are based on perusal of records and those of paragraphs no
18,19,29,32,33,38,67,156,157,158,159,160, &161of the writ petition are based on legal
advice, which also deponent believes to be true that nothing material has been concealed
and that no part of this affidavit is false. So help me God.

( Deponent )
 I, Yogesh Kumar Saxena Advocate High Court Allahabad do hereby identify the deponent
is personally known to me..

( Yogesh Kumar Saxena)

Advocate
U.P.Bar Council Ragistration No. 946/1974

Solemnly affirmed before me this------------------day of -----------------2004--------at A.M./ P.M. by the

deponent who is identified by the aforesaid clerk/ Advocate.

I have satisfied myself examining the deponent that he understand the contents of this
affidavit, Which have been read over and explained to him by me.

Oath Commissioner