Application for Direction - Supreme Court.

Format of Application seeking direction in Supreme Court.

IN THE SUPREME COURT OF INDIA
CIVIL WRIT ORIGINAL JURISDICTION
CIVIL WRIT PETITION NO. ___________OF 20_____

IN THE MATTER OF:
__________ PETITIONER
Versus
_______________ RESPONDENTS

AN APPLICATION FOR INTERIM DIRECTION
To,
The Hon'ble Chief Justice of India and His Companion Justices of the Hon'ble Supreme Court of India.

The Humble application of the petitioner above-named

MOST RESPECTFULLY SHOWETH:
1. That the present writ petition is being filed in public interest under Article 32 of the Constitution of India. The Petitioner by way of the present writ petition is challenging the validity of Clause __ of the _____________ (hereinafter referred as Order, 20_____), framed under The _______________ (Recruitment and Conditions of Service) Rules, 19_____ (herein after referred as Rule, 19_____) since it does not provide for any criterion or eligibility condition or qualification for appointment or promotion to the posts of Joint Secretary and above.

It is submitted that the absence of rules deprives eligible and meritorious officers/employees of the __________ their just and fair right of being recruited or promoted to the posts of Joint Secretary and above and hence, this violates Article 21 of the Constitution also.

Besides the aforementioned challenge to the Clause _____ of the _____, 20_____, the Petitioner is also raising the issue of illegalities and violation of Rules in the appointment/recruitment process for the posts of Director and below (upto the level of Attendant), for which detailed rules are already in existence. The Petitioner is giving few illustrative cases of such appointments made since 20_____ and therefore, also seeking an independent inquiry into the entire selection process in last 8 years in the __________.

2. That the Petitioner is not repeating the facts of the writ petition for the sake of brevity and same may be read as part of the present Application.

3. That the Petitioner has an excellent case and there is every possibility of succeeding in the present writ petition. The Petitioner is filing the present application seeking interim direction in the nature of a direction for Respondent Nos. 1 & 2 to follow the _____ Rules for appointments through promotion as well as deputation on the posts of Joint Secretary and above till the Rules for the said posts are framed in the _____ _____. The Petitioner is also seeking an independent inquiry in to the appointments made in the _____ in last 8 years. It is submitted that any such order will not cause any prejudice to any party and it is much needed in public interest.

PRAYERS

In view of the aforementioned facts and circumstances, this Hon'ble Court may be pleased to:

(a) Direct Respondent Nos. 1 & 2 to follow _____ and Conditions of Service Orders, 19_____ for making appointments, both through deputation and promotion, for the posts of Joint Secretary and above in the _____ till the prayer for framing of Rules, as prayed in the writ petition, is granted;

(b) Direct an inquiry into all the appointments made in the _____ since 20_____; and

(c) Pass any other order as this Hon'ble Court may deem fit and proper.

Applicant/Petitioner

Through
Dated: _____