In A Writ Petition Writ Of Certiorari - Legal Draft

Precedent No. 19

AFFIDAVIT: IN A WRIT PETITION - WRIT OF CERTIORARI

BEFORE THE HON'BLE HIGH COURT OF

Original Petition No of 20

Petitioner:

Vs.

Respondent:

AFFIDAVIT of , W/o , aged about years,

presently residing in

The abovenamed deponent hereby solemnly affirms and states on oath as

under:—

1. That the deponent herein is the petitioner in the Original Petition

referred

to above and also in the Civil Miscellaneous Petition No The

deponent is well conversant with the facts and circumstances of the case

and stands fully competent to swear to this affidavit.

1. That the Original Petition referred to above is filed seeking

the issuance of, inter alia, a writ of Certiorari, direction or order

quashing Ex. P. 12 order passed by the respondent cancelling the

passport of the deponent herein.

1. That it is submitted that all the statements of facts contained

in the aforesaid petition are true and correct to the best of my

knowledge, and all the statements of law contained therein are believed

to be true and correct belief as per information received by me from

experts. The exhibits produced alongwith the Original Petition are true

copies of the Originals they purport to represent.

1. That it is further submitted that, the impugned order in the

aforesaid petition stands vitiated by very serious errors apparent on

the face of the record.

1. That, it may be mentioned here that, the 1st respondent

completely disregarded the objections filed by the deponent herein to

the show-cause notice issued by the 1st respondent to the deponent.

Therefore, there has been a clear and gross violation of the principles

of natural justice by the said respondent.

1. That the aforementioned facts and circumstances lay bare the

arbitrariness exercised by the 1st respondent in cancelling the passport

of the deponent herein and there has been absolutely no application of

mind on the part of the said respondent in passing the impugned order.

1. That in view of the abovementioned facts and circumstances, it

is in the interest of justice, equity and conscience, that this Hon'ble

Court may be pleased to quash the aforesaid order passed by the 1st

respondent.

Sd./ Deponent.

Verification

Verified at on this the day of 20 , that

the contents of the above affidavit are true and correct to the best of

my knowledge, belief and information and nothing material has been

concealed therefrom.

Sd./ Deponent.

Solemnly affirmed and signed before me by the deponent, who is

personallyknown to me, on this the day of , 20

Sd./

Counsel for the deponent.

Note: Affidavit to be attested by the appropriate authority prescribed

under law.