NAME-ANKIT NANDE

ROLL NO-1783015

B.A.LL.B(A)

IN THE HIGH COURT OF CHHATTISGARH AT BILASPUR

CIVIL ORIGINAL (EXTRA-ORDINARY) JURISDICTION

CIVIL WRIT PETITION NO........................ OF 2020

IN THE MATTER OF:-

An application under article 226 of the constitution of India;

And

Subject matter relating to :

Issuance of Writ Mandamus, directing the respondent to issue the petitioner a new passport

And

IN THE MATTER OF:-

Ankit Nande,

S/o Rajeev Ranjan Nande, R/o Kunkuri, District- Jashpur ,Chhatisgarh………….PETITIONER

-Versus-

The Passport Officer of Regional Passport Office, Raipur……………………...RESPONDENT

May it please the Hon'ble Chief Justice of the High Court of Bilaspur, Chhattisgarh and His

Lordship's companion Judges.

THE PETITIONER MOST RESPECTFULLY SHOWETH:

1. The petitioner is a citizen of the country and is not debarred by law for the issuance of
Passport by any authority.
2. The respondent is state machinery performing its duties under the instructions of the
government, amenable to the writ jurisdiction of this Hon’ble Court.
3. The Petitoner applied for passport under the Passport act of 1967 .
4. He submitted all the relevant documents which is necessary for registering under the
Passport act of 1967 including all the address proofs and age proofs.
5. The passport office did not take any further action regarding to issue the passport due to
which petitioner had to suffer a lot.
6. The petitioner states that the petitioner is entitled to get the passport issued to him by that
time.
7. Being aggrieved by and dissatisfied with the functioning of the Passport Authority , the
petitioner begs to prefer the instant application under Article 226 of the Constitution of
India inter alia on the following :-

GROUNDS:-

I. FOR THAT Passport authority have acted contrary to the Constitution and in
derogation of rights of petitioner to him.
 II. FOR THAT after submitting all the relevant documents under passport
registration act of 1967. The Passport authority not issuing the passport it is the violation of the
rights of the petitioner.
III. FOR THAT delaying in issuing the passport it violates Right to Liberty under 21
and Article 19(1). It is illegal and immoral on that basis.
IV. FOR THAT compiled with required formalities but the authority has not issued
the passport. It violates the fundamental rights of the Petitioner.

8. Unless there is a direction upon the Passport Authority to issue the Passport as early as
possible ,the petitioner will suffer irreparable loss and injury.
9. In the facts of the case there is no scope of making any further demand for justice.
10. The cause of action has arisen within the jurisdiction of the Hon’ble Court and is
continuing in view of the illegal violation of right to life,liberty and freedom to speech
and expression.
11. There is no other alternative and efficacious remedy available to your petitioner than to
prefer this application and the relieves prayed for herein, if granted, will be in the benefit
of the petitioner.
12. On the self same facts and cause of action no other application has been filed by your
petitioners in this Hon’ble Court or any other Court.
13. This application is made bonafide and in the interest of justice.

PRAYER

Under the circumstances herein above stated your petitioner most humbly respectfully prayed
that this honorable court may graciously be pleased to;

Issue a writ of Mandamus or further any appropriate writ or order directing the respondent to
perform their Statutory duty.

To pass such orders and further order as deemed necessary on the facts and int the circumstances
of the case Issue a writ or order or direction to the respondent act accordingly.
 FOR WHICH ACT OF KINDNESS, THE PETITIONER SHALL AS INDUTY BOUND,
EVER PRAY

PETITIONER

THROUGH

COUNSEL

MR. B.P. SHARMA DATED..10/08/2020

In the Honourable High Court of Judicature at Bilaspur

Writ Petition No ..............of 2020

Ankit Nande, aged 20 son of Shri R.R. Nande resident of Kunkuri, Dist-Jashpur

…….....PETITIONER

Versus

The Passport Officer of Regional Passport Office, Raipur……………………...RESPONDENT

Affidavit of Ankit Nande aged 20 son of Shri R.R.Nande resident of Kumkuri Dist-Jashpur

I, Ankit Nande, the above named deponent, do hereby solemnly affirm and state on oath as
under:

1 . That I am the Petitioner in the abovementioned writ petition and am fully conversant with the

facts of the case deposed in the writ petition.

2. That the contents of paragraphs 1 to 13 of the accompanying writ petition are true to my
personal knowledge and the contents of paragraph 7is based on legal advice, which I believe to
be true. No material has been concealed and no part is false. So help me God.

3. That the Annexure Nos. 1 to 12 to the accompanying writ petition are the true copies of the
originals and I have compared the said annexures with their respective originals and certify them
to be true copies thereof.

Place - Kunkuri

Date-10/08/2020 Deponent
 Verification

I, Ankit Nande, the above named deponent do hereby certify that the contents of paragraphs 1 to
13 of this affidavit are true to my knowledge. Nothing has been concealed and no part of it is
false. So help me God.

Verified at Kunkuri this 10th day of August.

Date-10/08/2020

Deponent