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IN THE HIGH COURT OF JUDICATURE AT ALLAHABAD

*****
INDEX

IN

CIVIL MISC. WRIT PETITION (PIL) NO. OF 2020


(Under Article 226 of the Constitution of India)

( DISTRICT :: PRAYAGRAJ )

Ayush Srivastava and Others …Petitioners.


Versus
State of Uttar Pradesh and Others …Respondents.

Sl. Particular of Papers. Dates Annex. Page No.


No. No. Fm | To
1.

2.

3.

4.

5.

7.

8.
9.

10.

11.

10.

11.

(Ayush Kumar Srivastava) (Akshay Prakash) (Darshan Gupta)

(Kiran Srivastava) (Shabih Fatima) (Ayush Maurya) (Namrata Singh)

(Simran Yadav) (Ayush Yadav)

(ALL IN-PERSON)

Dated :………… Mob.:…………….


IN THE HIGH COURT OF JUDICATURE AT ALLAHABAD
*****

DATES AND EVENTS

IN

CIVIL MISC. WRIT PETITION (PIL) NO. OF 2020


(Under Article 226 of the Constitution of India)

( DISTRICT :: PRAYAGRAJ )

Ayush Srivastava and Others …Petitioners.


Versus
State of Uttar Pradesh and Others …Respondents.

Dates Events
The petitioners are the law students doing internship under
the guidance of advocate Charlie Prakash and Law graduate
Prabal Pratap

(Ayush Kumar Srivastava) (Akshay Prakash) (Darshan Gupta)


(Kiran Srivastava) (Shabih Fatima) (Ayush Maurya)

(Namrata Singh)

(Simran Yadav) (Ayush Yadav)

(ALL IN-PERSON)

Dated :………… Mob.:…………….

IN THE HIGH COURT OF JUDICATURE AT ALLAHABAD


*****

CIVIL MISC. STAY APPLCIATION No. OF 2020


(Under Chapter XXII Rule 1 of the High Court Rules)

On behalf of :-

Ayush Srivastava……Applicant/Petitioner.
IN

CIVIL MISC. WRIT PETITION (PIL) NO. OF 2020


(Under Article 226 of the Constitution of India)

( DISTRICT :: PRAYAGRAJ )

District:Prayagraj

Ayush Kumar Srivastava


Son of Shree Sharad Kumar Srivastava
B.A.LL.B, 3rd Year, C.M.P. Degree College, Prayagraj
R/o: 112 A Ashok Nagar.
District: Prayagraj.

Akshay Prakash
Son of Shree Rakesh Kumar
B.A.LL.B,4th Year, Osmania University, Hyderabad
R/o: 245-A Om Gayatri Nagar, Salori.
District:Prayagraj.

Darshan Gupta
Son of Shree Sanjay Gupta
B.A.LL.B, 2nd Year, Bhartiya Vidya Peeth, Pune.
R/o: 233/35 2bBaba Chauraha, Ashok Nagar
District:Prayagraj

Kiran Srivastava
Daughter of Dr. Sudhir Kumar Srivastava
B.A.LL.B, 3rd Year, C.M.P. Degree College, Prayagraj
R/o: 72, Tilaknagar Allahpur.
District: Prayagraj.

Shabih Fatima
Daughter of Mr. Hasan Asghar Naqvi
B.A.LL.B, 2nd Year, Jamia Millia Islamia, New Delhi.
R/o:. 467, Dariyabad.
District: Prayagraj

Ayush Maurya
Son of Shree Ratan Maurya
BA.LLB, 3rd Year, C.M.P. Degree College Prayagraj
R/O, Sarai Abdul Malik, Phuplur
District: Prayagraj

Namrata Singh
Daughter of Shree Bhanu pratap
BBA.LLB, 4th Year, UPES, Dehradun
R/O, S2/169, Tagore Town Colony, Orderly Bazar
District: Varanasi.
Daughter of Shree Sant Lal Yadav
B.A.LLB, 3rd Year, RML(NLU)
R/O 5/3A T.B. Sapru Road, Civil Lines
District:Prayagraj

Ayush yadav
Son of Shree Sant Lal yadav
B.A.LLB, 2ndYear, Faculty of Law, Allahabad University
R/O 5/3A T.B. Sapru Road, Civil Lines
District:Prayagraj.

Manushi
Daughter of Dr. Pradeep Kumar
B.A.LLB (Hons),4th Year, Himachal Pradesh (NLU), Shimla
R/O H/s 498 lane 8 karamchari nagar
District: Bareli
.

…Petitioners.
Versus

1. State of U.P
Through Principal Secretary, Forest
Department, Lucknow

2. Principal Chief Conservator of Forest (PCCF)


District Lucknow, Uttar Pradesh

3. District Magistrate,
District Prayagraj, Uttar Pradesh

4. Divisional Forest Officer, Forest Department,


District Prayagraj, Uttar Pradesh

5. Uttar Pradesh State Highway Authority through its regional


manager,
District Prayagraj, Uttar Pradesh

6. Prayagraj Development Authority through its Secretary, District


District Prayagraj, Uttar Pradesh

7. Nagar Nigam, Prayagraj, through its city commissioner,


District Prayagraj, Uttar Pradesh
…Respondents.

To,

The Hon’ble the Chief Justice and his other companion Judges of the
aforesaid court.

The humble application on behalf of above named, Applicant/ Petitioner,


Most Respectfully Showeth as under:

1. That the full facts and circumstances of the case have been stated in the

accompanying (PIL) writ petition, which forms part of this application.

PRAYER

It is, therefore, most respectfully prayed that this Hon'ble Court may

graciously be pleased to direct the respondent no. 2, 3, 4, and 5 to


provide the details of tree plantation records done in Prayagraj

Nagar Nigam Area, in lieu of trees cut down during the widening

of the road and… before the Hon’ble High Court in a stipulated

time in the interest of Justice.

(Ayush Kumar Srivastava) (Akshay Prakash) (Darshan Gupta)

(Kiran Srivastava) (Shabih Fatima) (Ayush Maurya) (Namrata Singh)

(Simran Yadav) (Ayush Yadav)

(ALL IN-PERSON)

Dated :………… Mob.:…………….


IN THE HIGH COURT OF JUDICATURE AT ALLAHABAD
*****

CIVIL MISC. WRIT PETITION (PIL) NO. OF 2020


(Under Article 226 of the Constitution of India)

( DISTRICT :: PRAYAGRAJ )

District:Prayagraj

Ayush Kumar Srivastava


Son of Shree Sharad Kumar Srivastava
B.A.LL.B, 3rd Year, C.M.P. Degree College, Prayagraj
R/o: 112 A Ashok Nagar.
District: Prayagraj.

Akshay Prakash
Son of Shree Rakesh Kumar
B.A.LL.B,4th Year, Osmania University, Hyderabad
R/o: 245-A Om Gayatri Nagar, Salori.
District:Prayagraj.

Darshan Gupta
Son of Shree Sanjay Gupta
B.A.LL.B, 2nd Year, Bhartiya Vidya Peeth, Pune.
R/o: 233/35 2bBaba Chauraha, Ashok Nagar
District:Prayagraj

Kiran Srivastava
Daughter of Dr. Sudhir Kumar Srivastava
B.A.LL.B, 3rd Year, C.M.P. Degree College, Prayagraj
R/o: 72, Tilaknagar Allahpur.
District: Prayagraj.
Shabih Fatima
Daughter of Mr. Hasan Asghar Naqvi
B.A.LL.B, 2nd Year, Jamia Millia Islamia, New Delhi.
R/o:. 467, Dariyabad.
District: Prayagraj

Ayush Maurya
Son of Shree Ratan Maurya
BA.LLB, 3rd Year, C.M.P. Degree College Prayagraj
R/O, Sarai Abdul Malik, Phuplur
District: Prayagraj

Namrata Singh
Daughter of Shree Bhanu pratap
BBA.LLB, 4th Year, UPES, Dehradun
R/O, S2/169, Tagore Town Colony, Orderly Bazar
District: Varanasi.

Simran Yadav
Daughter of Shree Sant Lal Yadav
B.A.LLB, 3rd Year, RML(NLU)
R/O 5/3A T.B. Sapru Road, Civil Lines
District:Prayagraj

Ayush yadav
Son of Shree Sant Lal yadav
B.A.LLB, 2ndYear, Faculty of Law, Allahabad University
R/O 5/3A T.B. Sapru Road, Civil Lines
District:Prayagraj.

Manushi
Daughter of Dr. Pradeep Kumar
B.A.LLB (Hons),4th Year, Himachal Pradesh (NLU), Shimla
R/O H/s 498 lane 8 karamchari nagar
District: Bareli

Anuradha Gupta
Daughter of Shree Lal Ji Gupta
R/o 46 2/A Ganesh Nagar Muirabad
District Prayagraj
…Petitioner.
Versus
1. State of U.P
a. Through Principal Secretary, Forest
Department, Lucknow

2. Principal Chief Conservator of Forest (PCCF)


a. District Lucknow, Uttar Pradesh

3. District Magistrate,
District Prayagraj, Uttar Pradesh

4. Divisional Forest Officer, Forest Department,


District Prayagraj, Uttar Pradesh

5. Uttar Pradesh State Highway Authority through its regional


manager,
a. District Prayagraj, Uttar Pradesh

6. Prayagraj Development Authority through its Secretary, District


District Prayagraj, Uttar Pradesh

7. Nagar Nigam, Prayagraj, through its city commissioner,


District Prayagraj, Uttar Pradesh
…Respondents.

To,
The Hon’ble the Chief Justice and his other companion Judges of the

aforesaid court.

The humble application on behalf of above named, Petitioner, Most

Respectfully Showeth as under:

1. That this is the first Writ Petition being filed on the present cause of action

and no other Petition of any kind has been filed by or on behalf of the

Petitioners for the same or similar relief.

2. That no copy of the caveat application has been received by the Petitioners

nor do Petitioners have any knowledge regarding filing of any caveat

application on behalf of any of the Respondents.

3. That the petitioners have no ill-will of prejudice towards anyone and they

are not prejudiced in filing the present Public Interest Litigation.

4. That the petitioners are not filing this petition to benefit themselves or to

harm any person or institution.

5. That the petitioners are not filing this Public Interest Litigation at the behest

of some other persons to fulfill their other motives.

6. That the petitioners are not filing this Public Interest Litigation for any

personal interest or personal gain.

7. That there is no pronouncement of the Supreme Court and High Court on

this very subject of Mass Scale Tree Felling in the city of Prayagraj.
8. That this P.I.L. has not been sponsored, it is not at the behest of some

persons having ulterior motive and it has compiled with the requirement

contained in Chapter XXII (3A) of the High Court Rules.

9. That the petitioners are the law students who are doing internship on Human

Rights under the guidance of Adv. Charlie Prakash and Prabal Pratap at the

office of the Human Rights Legal network at Prayagraj.

10.That under the mandatory guidelines of the Bar Council of India, if law

students undergoing 5 years course have to attend 10 internships

compulsorily in different fields. One of the fields for internship is Human

Rights in which the petitioners are expected to study the cases of violation of

human rights, environmental rights, juvenile rights, women rights, do fact

finding and if necessary prepare a fact finding report, sending it to various

commissions like Human Rights Commission, Commission for Women’s

Rights, NCPCR, etc. The law interns also file PILs and argue in person

before the Hon’ble High Courts and Supreme Courts.

11.That the petitioners camre through a news paper report published in reputed

Hindi daily “Hindustan” under the heading stating ‘सड़क चौड़ीकरण के लिए फिर

काटेगे हजारों पेड़’ dated 12 oct 2020. A photocopy of is being filed herewiith and

marked as Annexure No. 1.

12. That on the basis of news report an urgent meeting was called in the office

of Human Rights Legal Network (HRLN) on 20 th october 2020 and a fact

finding team was formed under the guidance of Advocate Charlie Prakash

and Mr. Prabal Pratap Srivastava and it was decided that the fact finding
team shall visit all the places where trees would be cut for the purpose of

road widening and highway construction.

13. That the fact finding team consisted of law students who visited various

parts of the city,took photographs of various places where trees would be cut

for the purpose of road widening and highway construction.

14. That the following is the summary of the report filed by the interns:

Chief Conservator of Forest, Circular Road

● The fact finding team had a conversation with the senior clerk of the
department.
● The team enquired of the news published in the reputed hindi daily
‘Hindustan’ regarding the cutting of trees in widening and making of roads.
● The Department questioned the authenticity of the news published in the
reputed Hindi daily ‘Hindustan’.
● The workers of the department told the team that they are not concerned and
don’t deal in matters relating to cutting of tress and and sanctions related to
it.

PWD OFFICE, KATRA


● The team met Assistant Engineer (AE), Mr. Akash Goyal in CD-3 and
enquired about the upcoming project.
● The team enquired about the plan related to cutting of trees in widening of
State Highway from Jhunsi to Handia.
● The team was informed by him that it has not been implemented into a
project and is yet a mere proposal.
● On asking few more questions about the same, the officer got aggressive
and replied unethically.
● The officer took the questions of the team personally and started questioning
the position of the team.
● When told about the intention of the fact finding team , that is to save the
trees from felling, the officer sarcastically asked for the substitutes for not
cutting the trees from the team.

FOREST LOGGING DEPARTMENT, JAGRAM CHAURAHA


● The team met Mr. H.O. Bahadur Singh and discussed about the plan for the
construction of highway and road widening .
● The officer told us that the Divisional Forest Officer will send the list once
the inspection is done.
● After receiving the list logging department will go to cut the trees according
to the list provided by Divisional Forest Officer.
● The trees after being cut will be transported to the warehouse situated in
Meja and Mauama.

DIVISIONAL FOREST OFFICER, MINTO PARK, PRAYAGRAJ


● The team went to the Forest Office, Minto Park to meet the Divisional
Forest Officer and enquired about the project.
● The Divisional Forest Officer, Minto Park informed that there has been a
meeting regarding the proposal and there has only been verbal discussion
on that.
● In contrast with the information gathered from the PWD Office, the DFO
replied that the notice for joint inspection has already been sent to
Lucknow and the work will start after getting the orders from Lucknow.
● The officer told that there is no pre-allotted place for replantation of trees
and hence it takes a lot of time for the department to replant the trees.
15. That the batch of interns doing internship under the guidance of Advocate

Charlie Prakash and Mr.Prabal Pratap filed a PIL Jyoti Verma and others

v. State Of Uttar Pradesh and others (PIL) No. 1323 of 2019 for the

purpose of saving tress from being Hon’ble High Court.


16.That in the case of Jyoti Verma and others v. State Of Uttar Pradesh

and others (PIL) No. 1323 of 2019, the Hon’ble Court issued guidelines

for-

● District Magistrate with the help of Forest Department shall prepare a

plan for the aforestation in and around Prayagraj CIty within next two

years. The plan shall also include estimated expenditure so that

necessary instructions can be issued to Statet Government for the

implementation of the plan.

● The District Magistrate shall also explore the possibility to utilise the

GaonSabha Land and other public utility plan in the district for the

purpose of aforestation.

17. That in the case of Jyoti Verma and others v. State Of Uttar Pradesh

and others (PIL) No. 1323 of 2019 order dated July 10th 2019, the court

also directed that a fresh plan submitted by the next date for the plantation of

2 Lakh plants in the next two year in the DIstrict Prayagraj by Prayagraj

Development Authority, the Nagar Nigam Prayagraj, the Forest Department.

District Magistrate may explore the possibility to engage the Forest

Department in tree plantation, their maintenance and water harvesting.

18. That in the case of Jyoti Verma and others v. State Of Uttar Pradesh

and others (PIL) No. 1323 of 2019 order dated November 6th, 2019

● In response to order dated May 31st, 2019, an affidavit was filed on

behalf of Minister of Environment, Forest and Climate change where

it has been mentioned that no other proposals of tree felling and/or


diversion of forest land with regard to widening or construction of the

road in Allahabad has been recieved in the Regional Office Lucknow.

● The Learned Counsel for Union of India has passed an intstruction

recieved by him from the Ministry of Environment, Forest and

Climate change Regional office (Central Region) dated November

4th, 2019, wherein it is recoorded that for procurement of transplanter

machine to replant trees which are uprooted while

constructing/widening of National/State Highways will be considered

by user agencies at project cost.

19. That the Hon’ble Court directed:

● The Chief Secretary, Government of Uttar Pradesh to issue necessary

circulars/orders to all concerned departments regarding the statement

made in counter affidavit in Union of India that in Allahabad there is

no other proposal for felling of trees. The chief Secretary shall also

issue necessary directions to the State Public Works Department and

other agencies which are involved in widening and constructing of the

state highways regarding the decision of the ministry of environment,

forest and Climate Change for procurement of the transplanter

machine.

● The Ministry of Environment, Forest and Climate Change shall issue

circular to all agencies, National/State highways for procurement of

transplanter machines to replant trees which are uprooted while

widening/constructing National/State highways at project cost.


● The District Magistrate Allahabad shall send progress report of

plantation work in every three months ( of 5 Lakh plants) which was

directed by the Hon’ble Court during pendency of Jyoti Verma and

others v. State Of Uttar Pradesh and others (PIL) No. 1323 of

2019.

20.That the copy of judgment delivered by the Hon’ble Court in Jyoti Verma

and others v. State Of U.P. and others (PIL) No. 1323 of 2019 is annexed

herein as Annexure number 2.

21. That In Re: Cutting of Trees In Allahabad Under Beautification of

Road in Allahabad v. Union of India and others (PIL) No.3843 of 2018

the Hon’ble court stated “Cutting of such large number of trees in the road

widening/beautification scheme is not acceptable in the modern democratic

society. The ecological balance is required to be maintained by striking

a balance between development and environment. The court find that in

other countries where trees are found in conflict with the development they

are relocated by transplanter machine. The machines are affordable and can

be easily operated. Techniques have also developed to shift even more than

100 years old trees from one place to another without causing harm to them.

22.That , Hyderabad transplantation

23.That in Re: Cutting of Trees Under Beautification of Road in Allahabad

v. Union of India and others (PIL) No.3843 of 2018 court directed that

trees in Allahabad City shall not be cut unless there is no other alternative,
subject to the approval of District Magistrate, Allahabad. . The copy of

judgment is annexed herein as Annexure number 3.

24.That the Hon’ble Supreme Court in the case of T.N. Godavarman

Thirumulpad v. Union of India and others, (2013) 11 SS 466, has

considered the same issue and directed the National Highways Authority of

India to plant twice number of trees for every trees for five years and to

create a fund for the said purpose. The copy of judgment is annexed herein

as Annexure number 4.

25.That the Municipal Corporation has failed to maintain the trees which they

planted in the year 2019 because of which most of the trees planted died and

very few of them are surviving. A report of Nagar Nigam showing the

number of trees planted and number of trees surviving is annexed herein as

Annexure number 5.

26.That there is no land/space available with Nagar Nigam, Prayagraj to plant

trees because of which they were able to plant only 34939 plants where the

target was to plant 2 lakh plants and out of only 4029 plants are alive. A

report of Nagar Nigam, Prayagraj is annexed herein as Annexure number

6.

27.That Public Works Department has made a list of 23 roads which are to be

widened and a large number of trees will be cut for the purpose of road

widening.

28.That the state government approved an amendment to the “Uttar Pradesh

Protection of Trees Actin Rural And Hill Areas,1976 on December 9, and


made it mandatory to plant and mature at least 10 saplings for every tree

felled.

29.That the amendment also states that in case of lack of private space for

planting the saplings, designated forest land will be provided for the

plantation activity.

30. That Prayagraj city was known for its greenery and the large area of the

cities were under the tree cover which also used to give shelter and food to

the lakhs of birds all across the city. These birds formed an integral part of

the city’s ecosystem, which as a result of cutting of trees has been destroyed.

31.That at the start of the summer season, the mercury climbed upto 46 degree

in the initial days of the month of April which is a direct outcome of the

mass scale tree felling.

32.That the petitioners have got no other efficacious alternative speedy remedy

other than to invoke the extraordinary jurisdiction of the court under Article.

226 of the constitution of India. On below mentioned grounds.

GROUNDS

I. BECAUSE, That the respondents have done irreparable


damage to the greenery of the Prayagraj and damage its eco
system beyond repair, that the promise and commitment of the
respondent district magistrate, ADA, Forest department have
miserably failed about the planting of the double no. of trees,
that the respondents acted like nexus to destroy the green
cover of the city and they were only interested in the
construction of the roads its widening and modernization
which had faced huge budget , that the trees are the lifeline of
the city its operate like the lungs and such non sensible is
voilative of Article.21 of the constitution .

II. BECAUSE, That the provisions of the Environment protection


act 1986 was completely violated that India being the signatory
of the united nations conference on the human environment
held at Stock home has committed for the protection and
improvement of the environment which has been completely
given go by.

III. BECAUSE, the forest department, development authority had


no planning and program for the alternative of the either new
trees or transportation of those trees by using technology
because the rising the temperature in the city is direct result of
large scale trees felling. And there is every probability of death
due to sunstroke that trees are lungs of the cities and cutting of
the trees is voilative of Article 21 of the constitution.

IV. BECAUSE, this condition the cutting of trees will lead to the
environmental hazard that is dangerous, harmful and will keep
further deteriorating in the absence of these trees.

V. BECAUSE, in regards with the environment it is also important


to mention here that, the level of groundwater in Prayagraj is
getting decreased by 62 cm every year, this is a result of over-
exploitation of water and less rainfall, which would become a
regular condition in this city due to mass cutting of the trees
which help in holding water by their roots through the process
of “Percolation.”

VI. BECAUSE, the cutting of trees comes under violation of


Article 21 of the Constitution of India, which provides for Right
to live in natural habitat and is against the principle of
sustainable development and healthy livelihood.

VII. BECAUSE, the petitioners have no other equally, effective,


speedy, adequate and alternative remedy than to approach this
honorable court under article 226 of the constitution of India on
the following amongst other ground

PRAYER

It is, therefore, most respectfully prayed that this Hon’ble Court may

graciously be pleased to:

i) issue a writ, order or direction in the nature of MANDAMUS

directing the Respondent District Magistrate and Divisional Forest

Officer, Prayagraj from granting any permission for cutting or felling

of trees without leave of the Hon’ble High Court..


ii) issue a writ, order or direction in the nature of MANDAMUS

commanding the Respondents to provide the chart on Affidavit about

the numbers of the trees cut down, and number of trees planted along

with the area before this Hon’ble Court.

iii) issue a writ, order or direction in the nature of MANDAMUS

commanding the Respondents No. 2, 3, and 4 to take up a massive

drive for the plantation of trees like Sheesham, Mango, Jamun,

Bargad, Pakad, Tamrind, and other big and utilitarian trees, in the

Nagar Nigam area of Prayagraj.

(Ayush Kumar Srivastava) (Akshay Prakash) (Darshan Gupta)

(Kiran Srivastava) (Shabih Fatima) (Ayush Maurya)


(Namrata Singh)

(Ayush Yadav)

(ALL IN-PERSON)

Dated :………… Mob.:…………….


IN THE HIGH COURT OF JUDICATURE AT ALLAHABAD
*****

DECLARATION

IN

CIVIL MISC. WRIT PETITION (PIL) NO. OF 2020


(Under Article 226 of the Constitution of India)

( DISTRICT :: PRAYAGRAJ )

Ayush Srivastava and Others …Petitioners.


Versus
State of Uttar Pradesh and Others …Respondents.

I, Akshay Prakash,aged about 20 years Son of Rakesh Kumar, R/o 245A, OM


Gayatri Nagar, District-Prayagraj, do hereby solemnly affirm and declare that the
contents of para
nos._______________________________________________________________
_____________________&__of the accompanying writ petition are true to my
personal knowledge and information received and those contents of paragraph
nos._______________________________________________________________
__&___of the accompanying writ petition are based on perusal of record and those
contents of paragraph nos.
__________________________________________________________&__of the
accompanying writ petition are based on legal advice; which all I believe to be true
that no part of it is false and nothing material has been concealed in it.

1. That due to lockdown the deponent is not in a position to swear affidavit and

the contents of writ petition alongwith Annexures have been read over and

verified.
2. That the deponent undertakes that he will file the proper affidavit after the

lockdown is over or if required by this Hon’ble Court.

3. That in view of the above facts and circumstances this Hon’ble Court may be

pleased to take this verification on record and treat the same as part of writ

petition, to meet the ends of justice.

So Help Me God.

(Darshan Gupta) (Akshay Prakash) (Ayush Kumar Srivastava)

(Kiran Srivastava) (Shabih Fatima) (Ayush Maurya)

(Namrata Singh)

(ALL IN-PERSON)

Dated :………… Mob.:…………….

IN THE HIGH COURT OF JUDICATURE AT ALLAHABAD


*****

CIVIL MISC. EXEMPTION APPLICATION NO. 2020


(Under Chapter XXII Rule 1 of the High Court Rules, 1952)
IN

CIVIL MISC. WRIT PETITION (PIL) NO. OF 2020


(Under Article 226 of the Constitution of India)

( DISTRICT :: PRAYAGRAJ )

1. Ayush Kumar Srivastava


Son of Shree Sharad Kumar Srivastava
B.A.LL.B, 5th Semester, C.M.P. Degree College, Prayagraj
R/o: 112 A Ashok Nagar.
District: Prayagraj.

2. Akshay Prakash
Son of Shree Rakesh Kumar
B.A.LL.B, 6th Semester, Osmania University, Hyderabad
R/o: 245-A Om Gayatri Nagar, Salori.
District:Prayagraj.

3. Kiran Srivastava
Daughter of Dr. Sudhir Kumar Srivastava
B.A.LL.B, 5th Semester, C.M.P. Degree College, Prayagraj
R/o: 72, Tilaknagar Allahpur.
District: Prayagraj.

4. Shabih Fatima
Daughter of Late Shree Prasun Kumar Bose
LL.B, 1st Semester, LPU, Punjab.
R/o: 82A TulaRam Bagh, M.G Marg.
District: Prayagraj

5. Darshan Gupta
Son of Shree Sanjay Gupta
B.A.LL.B, 3rd Semester, Bhartiya Vidya Peeth, Pune.
R/o: 233/35 2bBaba Chauraha, Ashok Nagar.
District:Prayagraj

6. Ayush Maurya
Son of Shree Ratan Maurya
BA.LLB, 5th Semester C.M.P. Degree College Prayagraj
R/O, Sarai Abdul Malik, Phuplur
District: Prayagraj

7. Namrata Singh
Daughter of Shree Bhanu pratap
BBA.LLB, 7th Semester UPES, Dehradun
R/O, S2/169, Tagore Town Colony, Orderly Bazar
District: Varanasi.

8. Simran Yadav
Daughter of Shree Sant Lal Yadav
B.A.LLB, 5th Semester, RML(NLU)
R/O 5/3A T.B. Sapru Road, Civil Lines
District:Prayagraj

9. Ayush yadav
Son of Shree Sant Lal yadav
B.A.LLB, 3rd Semester, Faculty of Law, Allahabad University
R/O 5/3A T.B. Sapru Road, Civil Lines
District:Prayagraj

…Petitioners.
Versus

1. State of U.P
(Through its Chief Secretary).
District: Lucknow

2. State of U.P
(Through its Principal Secretary, Environment)
District: Lucknow

3. District Magistrate.
District: Prayagraj

4. Senior Superintendent of Police


District: Prayagraj.

5. Regional Office, State Pollution Control Board


Through its Regional Director.
District:Prayagraj.

…Respondents.

To,

The Hon’ble the Chief Justice and his other companion judge of the
aforesaid curt.

The humble application of the above named applicant most respectfully


showeth as under.

1. That , full facts, reason and circumstances and narrated in the


accompanying writ petition which also from part of this application.

2. That due to lock down the petitioner is unable to file the photo affidavit,
stamps and affidavit which may kindly condoned and petitioner shall
full all necessary requirements immediately within the fifteen days of
lifting of lock down.

PRAYER

It is, therefore most respectfully prayed that this Hon’ble Court may
kindly condone the petitioner in filling photo affidavit, stamps which
shall be submitted within fifteen days of the lifting of the lock down
period and to pass such other and further order which this Hon’ble Court
may deem fit and proper under the facts and circumstances of the
present case.

(Darshan Gupta) (Akshay Prakash) (Ayush Kumar Srivastava)


(Kiran Srivastava) (Shabih Fatima) (Ayush Maurya) (Namrata
Singh)

(Simran Yadav) (Ayush Yadav)

(ALL IN-PERSON)

Dated :………… Mob.:…………….


IN THE HIGH COURT OF JUDICATURE AT ALLAHABAD

*****

ANNEXURE NO. ( 6 )

IN

CIVIL MISC. WRIT PETITION (PIL) NO. OF 2020


(Under Article 226 of the Constitution of India)

( DISTRICT :: PRAYAGRAJ )

Ayush Srivastava and Others …Petitioners.


Versus
State of Uttar Pradesh and Others …Respondents.

(Ayush Kumar Srivastava) (Darshan Gupta) (Akshay Prakash)

(Kiran Srivastava) (Shabih Fatima) (Ayush Maurya) (Namrata Singh)

(Simran Yadav) (Ayush Yadav)

(ALL IN-PERSON)

Dated :………… Mob.:…………….

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