IN THE HIGH COURT OF JUDICATURE OF

ANDHRA PRADESH, HYDERABAD

CIVIL WRIT PETITION NO. ____

IN THE MATTER OF

Sh. Bangalu Ram Das s/o Ved Prakash r/o Hyderabad …..Petitioner

v.

Union of India …..Respondent

WRIT PETITION IN THE MATTER OF ARTICLE OF THE

CONSTITUTION OF INDIAFOR ISSUANCE OF WRIT OF QUO
WARRANTO OR OTHER APPROPRIATE WRIT

MAY IT PLEASE THE HON'BLE CHIEF JUSTICE OF DELHI HIGH

COURT OF…………………… AND HIS LORDSHIP'S COMPANION
JUDGES.

Most Respectfully Showeth:

1. Petitioner is a citizen of India and is therefore entitled to enjoy all the rights guaranteed
by the constitution of India.
2. The petitioner is living in Hyderabad, and a very respectable citizen.
3. At the same time 2 persons Sh. Ram Prakash and Sh. Bangalu Ramdas have been
appointed for the same post of chairperson of public service commission.
4. While verification it was found that Sh. Ram Prakash was not qualified as chairperson
as he has some criminal cases pending against him.
5. So, Sh. Ram Prakash appointment of 2 years should be canceled.
6. Sh. Bangalu Ramdas who was also appointed of the post.
7. Sh. Bangalu Ramdas has not filed any other petition in any High Court or the Supreme
Court of India on the subject matter of the present petition.
 GROUNDS
1. Because petitioner is a citizen of India and is therefore entitled to enjoy all the rights
guaranteed by the constitution of India.
2. Because the respondent is wrongfully claiming himself to be chairperson of public
service commission in which petitioner resides.
3. Because the January 1998, the respondent was convicted by the Sessions Judge, under
sections 376 and 511 of Indian Penal Code, 1860 and was sentenced to six months
rigorous imprisonment. The conviction and the sentence were upheld in appeal by the
Hon’ble High Court.
4. Because the conviction of the respondent being in respect of an offence involving moral
turpitude, he was disqualified, for being nominated as a chairperson and from being
elected as a chairperson of the public service commission .
5. Because the respondent has no right to hold the office of Chairperson of public service
commission.
6. Because petitioner has not filed any other petition in any High Court or the Supreme
Court of India on the subject matter of the present petition.

PRAYER

It is therefore, most respectfully prayed that a writ of Quo Warranto or a writ order or
direction of the appropriate nature be issued so the respondent, requiring to show the
authority under which he holds the office of chairperson of public service commission, and
he be restrained from functioning as such

Petitioner

Counsel

Dated 03/10/2019 Chirag Aggarwal

 VERIFICATION

I, Sh. Bangalu Ram Das s/o Ved Prakash R/o Hyderabad, the above-named petitioner does
hereby verify on the oath that the contents of my above petition from para 1 to para 7 are true
and correct to my personal knowledge. Nothing material has been concealed therein and no
part of it is false.

PETITIONER

Chirag Aggarwal