JIN THE HIGH COURT FOR THE STATE OF ANDHRA PRADESH AT AMARAVATHI ‘WP(PIL) . Between: (PIL). NO. OF 2020 Dr. Rajendra Singh an -Petionerls “The State of Andhra Pradesh, Respondent/s SSMS FOR WerrpermTIoN Siem No Pag io, chasing Ors Senauie— Ra ORIGINALSET 1) Proof of Service 1 2) CourFeers. | 2 3) Writ Petition 3a 4) Amenestan — g—> 5) Afgevit Bo s4 2) Averment regarding previous proceedings (mention Page No, Para No. d 1b) Averment regarding. aerate reef (mention Page to, 2 Para No.1 ® ) 6) Veefcaion Statement 7) Enclosure a 8) ‘Material Papers (Duly Indexed P-Series) BS to y's 9) 9) VabthR. Ang 8). Power of attorney/Resalition Authoring to se f petition fled in rep.capacty 10) Sheet containing Respondents Addresses 4. << DUPLICATE SET 11) WritPetiion ane 12) Annewresta = Se 13) Affidavit Bost 14) Material Papers asta MISCELLANEOUS 15) Batta Rs. ol— 16) Rule Nis Forms 17) Covers with Postal Addresses & Ack Forms 18) Copies of Petiion and Afidavts (As many as the No.of the Respondents + 2) 5 5 rac on Court Fee Rs. tol Se 180 estates Ahoy eee nto oma wages Respondent Vakalat filed by for Respt.No. fern ee Ce sd ear Scanned with CamScannerHIGH COURT OF ANDHRA PRADESH AT AMARAVATHI WP(PIL).No, OF 2020 CHRONOLOGICAL / RUNNING INDEX Si. | Exhi- |Description of Document | Date of ] Date offing | Pape No.| bit Document _|_of Document | _ No. 1. | -_ [Proof of Service 17-09-2020 | 17-09-2020, 1 2. | - [Court Fee ~do- ~do- 2 | 3. | - | Writ Petition ~do- ~do- 4. |= [Annexure T& il ~do- ~do- 5. [| - | Affidavit do do | 6. ‘Annexure 5 “do “ao ' 7 ‘Annexure -6 ~do- do | 3 ‘Annexure -7-A ~do- ~do- | 9 ‘Annexure -8 ~do- ~do- T ‘Annexure -10 ~do- ~do- : o § Material Papers: TI [PI _| Copy of Representation | 01.08.2019 | __-do- : to the commissioner, as-SH GVMC, Visakhapatnam. 12 |P2 | Copy of Paper News 16.02.2020 | -do- 7 Cutting (THE HINDU). ne-39 13 ]P3 [Copy of Paper News 16.02.0020 | -do- Cutting (TIMES OF . INDIA). a 14 |Pa [Copy of Paper News _|19.08.2019 | -do- Cutting (DECCAN : CHRONICLE). Almas 5. Vakalath 17-09-2020 | 17-09-2020 | 4-4 16. Respondents Addresses | -do- “as 17. Personal details of the petitioners. Ab DATE: 17-09-2020 AT AMARAVATHI eanlld ke Scanned with CamScannerSERVICE CERTIFICATE (PROOF OF SERVICE) We have served the copies of Writ Petition, Affidavit, Writ Petition Miscellaneous Petition(s) and Material Papers on the other side Counsel/Government Pleader. AMARAVATHI Counsel{6F the Petitioner DATE: 17-09-2020 Scanned with CamScanner© “490 Paid to Register Judicial He AP Challa ajaykumar (5250) CF -le0 ve Ss ae 1s B- 180 | r= 10 Paid % 490 S- 180 “a —_ Sep 17, 2020 + 1:18 PM ae a UPI transaction ID 026113004511 To we 9134 From: M SUDHAKAR SUDHAKAR REDDY (State Bank of India) sudhakarreddy9346@okicici Google transaction ID CICAgKCVucCgaQ Seanmed with GanScanner Scanned with GonSconner- s MEMORANDUM OF WRIT PETITION (SPECIAL ORIGINAL JURISDICTION) (UNDER ART, 226 OF THE CONSTITUTION OF INDIA) IN THE HIGH COURT FOR THE STATE OF ANDHRA PRADESH AT AMARAVATHI WP(PIL). NO. OF 2020 Between: 1, Dr. Rajendra Singh, ‘S/o. Sukhveer Singh, Hindu, aged 61-years, Environmentalist and Waterman of India, Raman Megasessy Awardee, Ryo. Ward No-8, Teh Tanagazi, Tarun Bharat Sangh, Bhikempura, Alwar, Rajastan-301002 ‘Aachar No.7432 4176 0362 Email: rajen59singh@gmall.com Jalpurushtbs@gmail.com Phone: +91 9414066765 2. Bolisetty Satyanarayana So. Srimannarayena, Hindu, aged 62-years, Environmentalist, Ro. HIG-SO, MVP Colony, Sector-1, Vishakepatnam-S30 017 ‘Aadhar No.3594 1483 9729 Email: bolisetisatyanarayena@gmall.com Phone: +91 9849152757 Bank A/c.No.00501530013772, HDFC Bank, IFSC:HDFC0000050, Dwareka Nagar Branch, Vishakapetnam. ~Petitioner/s AND 1. The State of Andhra Pradesh, Rep. by its Special Chief Secretary, Environment and Forest, Government of Andhra Pradesh. Secretariat, Velagapudi, Amaravathi. Email: splcs_efst@ap.g 2. The Chairman, {AP State Pollution Control Board, ‘Government of Andhra Pradesh, Velagapudi, Amaravathi. Email: chairman@appcb.gov.in 3. The Chairman, AP State Bio-diversity Board, State of Andhra Pradesh, Email: apsbiodiversityboard@amall.com Scanned with CamScanner4. The Secretary, Ministry of Environment, Forests & Climate Change (MOEF & CC) Union of India, Indira Paryavaran Bhawan, Jor Bagh Road, New Delhi-110 003 Email: secy_moef@niein Phones: +91 11 24695262; 2462192 (Office) +91 11 24695270 (Fax) 5, The District Collector, Ofo. Collectorate Visakhapatnam, Visakhapatnam District, Emall: collector_vsk@ap.gov.in 6. The Commissioner, ‘Ofo. Commissionerate of GVMC, Greater Visakhapatnam Municipal Corporation, ‘Visakhapatnam, Email: commissioner_gvme@yahoo.co.in ~Respondent/s ‘The address for service on the above named Petitioners is that of thelr counsel Mr. CHALLA AJAY KUMAR, Shanti Prasad Singaluri (14886), RV SURENDRANATH VARMA, NAGABHUSHANAM GUDIPATI at Office : # 201, Vasantha Wind Flower Resi. Behind Lakshmi Narasimha Swamy’ Colony, Ratnala cheruvu, Near NRI Hospital, Mangalagiti, Guntur District- 522503, Phone No. 08645-233046. For the reasons stated in the accompanying affidavit, it is hereby prayed. that this Hon'ble Court may be pleased to issue a Writ, Order or Direction, more particularly one in the nature of Writ of Mandamus by remedial actions of not allowing untreated industrial effluents and toxic sewerage water being thrown in to the nearby sea water and adjacent water bodies, failing which greater damage may also ensue in near future endangering Flora and Fauna, Blodiversity and also endangering the lives and health conditions of the Fishermen ving on the abutting sea shore of the area and to pass such other order or orders as this Hon'ble Court deems fit and proper in the said circumstances of the case and in the interests of justice. and to pass such other order or orders as this Hon‘ble Court may deems fit just and proper In the clreumstances ofthe case. AMARAVATHI cue l bce DATE: 17-09-2020 Scanned with CamScannerVISAKHAPATNAM District IN THE HIGH COURT FOR THE STATE OF ANDHRA PRADESH AT AMARAVATHI \WP(PIL). NO. OF 2020 ar -10e 180 i 108 | een 1S WRIT PETITION Filed By: M/s CHALLA AJAY KUMAR (5250) & ‘Shanti Prasad Singaluri (14886) ‘Advocate Counsel for Petitioner ti Gerla Foot Pores sefar Norns Sosrmudon Otten Bs Cup her Casson 7 Re, sober quac.s:bane Scanned with GanSconner anes INTHE HIGH COURT FOR THE STATE OF ANDHRA PRADESH AT AMARAVATHI WP(PIL).NO, of 2020 LIST OF EVENTS innexure — S.No} Date Description ofthe Events | Noein | Novin Affidavit Affidavit The Petitioners also mention that for the last three years the petitioners are raising the awareness on this issue but authorities of GVMC or the Pollution Control Board and other respondents have not shown any concern. Whenever there is a downpour due to rains, the 1 rainwater washes large) \G [5 amounts of plastic on to the beach, further aggravating the situation. The Respondents should realize that Environment, Ecology, rsity, Air and Water pollution amount to violation of the RIGHT TO LIFE of the Fishermen as assured in Article.21 of the The petitioners have put their best efforts to appraise about the situation and consequences, but no response from any of the respondents and no let-off in the situation on the ground and untreated sewer going into the sea and| 44, thereby a large number of fish died in the area and the same was being seen on the shore of the Rishikonda beach area and the same is being reported in various print and electronic media on Dt.19-08-2020, Scanned with CamScanner6 ‘The State Government and the authorities of GVMC have not responded on the representations given by the clvic societies and hence the 1" petitioner representing Tarun Bharat Sangh wrote a letter to the Commissioner of GVMC on 01-07-2019 mentioning therein various environmental issues being faced by the Visakhapatnam and other areas in and around and one of the key Issue ralsed specifically is about untreated sewer in Vishakhapatnam and Industrial Effluent being let pass In to sea from Parawada Industrial Area, consisting of Pharma City. Ve The matter was being taken before the Commissioner of GVMC by the 2” petitioner who Is working In tandem with 1% petitioner, being the local area man and an environmentalist himself. Yet no action has been initiated, nor being verified as to the passage of Industrial effluents and untreated sewage water containing noxious and toxic plastic material into the sea waternear Peddajalaripeta \r The same is being reported in majority of English National and Local Vernacular print and electronic media and the situation Is very alarming even endangering environment and the human life, if they take this dead fish as food innocently. Even now, inspite of reporting of the matter in various media platforms, and the 2™ petitioner being taken the same to the \> 10 Scanned with CamScanner+ ‘authorities of GVMC, they have not visited the place | and nor conducted any enquiry, nor initiated any | action against the Pharma companies situate in Pharma City of Parawada, The petitioners urge that an Immediate enquiry Is to be ‘ordered Into the incident of | death of large number of fish coming and depositing to the Rishkonda Sea shore, | for which the authorities of the Department of Fisheries saying and throwing the 6 blame on the Mother Nature] \% | 12 and also depletion of Oxygen levels in the sea | | water, If what the authorities of Department of Fisheries, Is to be believed, all kinds of fish are to be dead and come and accumulate on the sea shores. | ‘ANNEXURE-II Under Article 226 of Constitution of India, ‘AMARAVATHI Counséffor Petitioner/s DATE: 17-09-2020 reer renner eae etl Scanned with CamScannerSm HIGH COURT OF ANDHRA PRADESH AT AMARAVATHI (Rule-4(e) the High Court of Judicature at Hyderabad for the State Telangana and the State of Andhra Pradesh Public Interest Litigation Rules, 2015) W.P. (PIL)No. of 2020 Between: y) Dr. Rajendra Singh, S/o. Sukhveer Singh, Hindu, aged 61-years, Environmentalist and Waterman of India, Raman Megasessy Awardee, R/o. Ward No-8, Teh Tanagazi, Tarun Bharat Sangh, Bhikampura, Alwar, Rajastan-301002 Aadhar No.7432 4176 0362 Email: rajen59singh@gmail.com jalpurushtbs@gmail.com Phone: +91 9414066765 2) Bolisetty Satyanarayana S/o. Srimannarayana, Hindu, aged 62-years, Environmentalist, R/o. HIG-50, MVP Colony, Sector-1, Vishakapatnam-530 017 Aadhar No.3594 1483 9729 Email: bolisettisatyanarayana Phone: +91 9849152757 Bank A/c.No.00501530013772, HDFC Bank, IFSC:HDFC0000050, Dwaraka Nagar Branch, Vishakapatnam. .. Petitioners And 1) The State of Andhra Pradesh, Rep. by its Special Chief Secretary, Environment and Forest, Government of Andhra Pradesh. Secretariat, Velagapudi, Amaravathi. Email: spics_efst@ap.gov.in 2) The Chairman, AP State Pollution Control Board, Government of Andhra Pradesh, Velagapudi, Amaravathi. Email: chairman@apocb.gov.in Phone:0866-2463202 a Lebbege Scanned with CamScannerg 3) The Chairman, AP State Bio-diversity Board, ‘State of Andhra Pradesh, Email: apsbiodiversityboard@amail. 4) The Secretary, Ministry of Environment, Forests & Climate Change (MOEF & CC) Union of India, Indira Paryavaran Bhawan, Jor Bagh Road, New Delhi-110 003 Email: secy moef@nic.in Phones: +91 11 24695262; 2462192 (Office) +91 11 24695270 (Fax) 5) The District Collector, O/o. Collectorate Visakhapatnam, Visakhapatnam District. Email: collector vsk@ap.gov.in 6) The Commissioner, O/o. Commissionerate of GVMC, Greater Visakhapatnam Municipal Corporation, Visakhapatnam. Email: commissioner avmc@yahoo.co.in sass Respondents AFFIDAVIT 1, Bolisetty Satyanarayana S/o. Srimannarayana, Hindu, aged 62-years, Environmentalist, R/o. HIG-50, MVP Colony, Sector-1, Vishakapatnam, ‘Aadhar No.3594 1483 9729, having temporarily come down to ‘Amaravathi, do hereby solemnly and sincerely affirm and state on oath and follows: 1. 1am the 2™ petitioner herein and I am well acquainted with the facts of the case and I am authorized to file this petition on behalf of other 1® petitioner also do to so. THE C ORDER AGA: (CH THE PETITION Lbafe Scanned with CamScanner) 1.1 SUBJECT MATTER IN BRIEF; \e This petition is filed challenging the acts of the respondents in not taking steps inspite of writing letters, reminding through the print and electronic media and also orally complaining about the pathetic condition of the sea water getting polluted with untreated sewer and garbage including plastic and toxic waste, flowing Into the sea at Lawson's Bay, Rishikonda Area, Vishakhapatnam. The sald sewer, garbage including toxic and plastic waste flowing into the sea near Peddajalaripeta from drain flowing from Megadhrigedda through VishakhapatnamCity at Lawson's Bay, Rishikonda Area Vishakhapatnam,and also untreated toxic chemical waste flowing from Parawada, which is the Hub of Pharma | Companies, also known as *Parawada Pharama City’ into the sea and in | this regard Tarun Bharat Sangh, a registered society and voluntary Organization represented by the Petitioners and the 2™ petitioner being | the National Coordinator, resides at Visakhapatnam, and the 1 petitioner | wrote a letter to the GVMC Commissioner on 01-07-2019 also sent an | ‘email dated 2nd July 2019, also quoting that 2 petitioner would pursue | the matter, on behalf of their voluntary organization society, and the petitioners personally visited the area on 10th December 2019, made a video of the same and the link of the same is https://youtu,be/Pr3bO104- 8 and the petitioners posted the said video for the viewership to public and also to concerned authorities on YouTube and also sent a copy of the same to GVMC with a caption “Our beautiful Visakha... Sewer, Dirt flowing straight into Visakha Beach... responsible people shall be sent to Jail", and also again on 15th of February 2020 the petitioners visited Lawson's Bay and the news of their visit also being prominently published in all National and local Dailies and the links of the said visit story published in Hindu and also in Times Of India are given here for the perusal in to the issue and the consistent and constant appraisal of the issue and the consequent dangers involved due to the pathetic condition of the sea water getting polluted with untreated sewer and garbage including plastic and toxic waste, flowing into the sea at Lawson's Bay, Rishikonda Area, Vishakhapatnam and the links of those National Dailies are also given here for the perusal of the Hon'ble Court for better appreciation of the Issue. The Links are Jabew ye Scanned with CamScanner|) bttns://timesofindia,indlatimes,com/clty/visakhanatnam/polly Il) htps://www.deccanchronicle,com/nation/crime/190719/visak with a picture of the beach enclosed therein with a captions that “Health risks - Apart from the untreated sewage water, chemical and toxic waste Is also finding its way into the sea, thus posing a risk to marine ecology and affecting the livelihood of fishermen and the health of people bathing In the beach. About 20,000 fishermen live along the coast in Yendada and Jalaripeta, and thelr lives are being affected due to the unchecked pollution at Lawson's Bay beach and the contents of the same are also filed along with application as documents for consideration. 2, PARTICULARS OF THE PETITIONERS: 1) The 1* petitioner viz.,Dr.RajendraSingh also called "Waterman of India" is a well-known Water Conservationist and Environmentalist of India. He Is the founder and chairman of ‘Tarun Bharat Sangh’ (TBS), a Non-governmental Organization (NGO). He Is also heading a national network of organizations working on water Issues and for the restoration of the rivers and water bodies in the country. The 1* petitioneris a true humanitarian and a firm believer in the Empowerment of Rural communities. After studying Ayurvedic Medicine and Surgery, he went to thecountryside in Rajasthan in the mid-1980s to set up a health clinic, Instead, the 1% petitionerwas told by the villagers that the greatest need was not health care, but water. As wells dried up; crops wilted; rivers ran dry, and forests disappeared, many villagers left for cities In search of work. Women, children and the elderly were left to fend for themselves. yr LAfe. Scanned with GanSconner| | | | \2 Considering the hardships of the villagers, Rajendra Singh left the idea of setting up a health clinic and with the help of local people, the 1* petitioner set out to build Johads or traditional earthen dams.Starting from a single village In 1985, over the years, the * petitionenwith the help of TBS has helped bulld over 8,600 Johads and other water conservation structures across manyStates In North Inca, Considering the selfless contribution to community development, the 1" petitioner was Honored with the Ramon Magsaysay Award;|n the year 2001. For promoting Gandhian values, community service, and social development, the 1* petitioner was bestowed also with Jamnalal Bajaj Award, the most prestigious award of India, In the year2005.Heis also the winner of Stockholm Water Prize, considered as the Nobel Prize for Water, in the year2015. 2) The 2” Petitioner viz., Bollsetty Satyanarayana halls from Vishakapatnam of State of AP and he Is well known Environmentalist and Social Activist, He works along with the 1" petitioner in restoring the water bodles across India and he himself filed number of cases against the Environment Polluters. Recently he filed along with the 1* petitioner and 2-others, against the Sand Mafia illegally mining in the upper area of Prakasam Barrlage and got order of 100 crores of rupees compensation belng Imposed on the State Government, from the National Green Tribunal New Delh! vide 0.A.No.935 of 2018, which is disposed recently on Dt,24-08- 2020, in favour of the petitioners and against the State of AP. The 2 petitioner also filed recently a case against the State of AP for encroaching and destroying the protected Korangl Blo-Diversity Forest in Kakinada of East Godavari District In the name of the *peadalu andariki Illu” under present government programme of *Navaratnalu” on the file of the National Green Tribunal, Southern Zone, Chennaivide 0.A.No.65 of 2020.The 2" petitioner also filed PIL No.19 of 2019 In this very Hon'ble Court for the removal of Statues of Flim Personalities viz, Akkinenl Nageswara rao, Nandamuri Balakrishna and Dasarl Narayanarao, on the Beach Road of the Vishkapatnam. The 2™' petitioner also got filed through some other activist 0.A.No.91 of 2020 against the illegal sand mining In ha ZA Scanned with CamScanner\S Razole Constituency of East Godavarl. The 2 petitioner Is also the Natlonal Convener of Jal Biradarl, an organization fighting for the protection of water bodies In India. He also fights along with Shrl,EAS Sharma, a retired IAS Officer for the betterment of the City of Vishakapatnam. The 2" petitioner is an Environmentalist and also a Social Worker, 3. Declaration and undertaking of the petitioners: w ww) That the present petition is being filed by way of Public Interest Litigation and the petitioner does not gain anything personally from the present litigation, That the entire litigation cost including the Advocate’s fee and other charges are being borne by the petitioner. That the petitioners possess all the relevant documents to substantiate the grievance under the present public interest litigation, Iv) That we did not file any other writ petition before this Hon’ble yw vi) Court prior to the present one on the same issue and to the best of my knowledge no other case was filed by any other person before this Hon’ble Court on the very same cause of action. That thorough enquiry and verification has been conducted in the matter raised through this petition. All the relevant documents pertinent to the subject are discovered and acquired by the petitioner to this petition. The petitioners collected the Information through his sources and following procedure stipulated by the Authorities. That to the best of the petitioner's knowledge and verification, the issue that Is raised was not dealt with or decided and that a similar or Identical petition was not filed earlier by the petitioner. vil) That issue was not dealt with or decided earlier and we have not filed any similar or identical petition or petitions earlier. We also pe LAoe Scanned with CamScannerunderstood that in the course of hearing of this petition, we may be required to furnish any security towards any cost or any other charges and 1 will comply with such requirement, 4. FACTS IN BRIEF, CONSTITUTING THE CAUSE: 1) The Greater Visakhapatnam Municipal Corporation (GYM) Is irresponsible in not protecting the sea and other natural resources in Visakhapatnam and GVMC has miserably falled to protect Visakhapatnam Beach, Mudsurlova Reservoir, Chillapeta tank in Bhimili and many other water bodies and streams In Visakhapatnam District, where it’s jurisdiction is covered. 2) The Pharma City located In Visakhapatnam Industrial area has been in question with regard to releasing of untreated effiuents, pollutants, noxious and toxic substances Into the sea water and adjacent water bodies indiscriminately and without following due norms laid down in this regard, by Environmental Protections Laws viz., Sectlons of 25, 26, 32, 33 and 33-A of The Water (Prevention and Control of Pollution) Act, 1974 and Sections. 7, 8 and 9 of The Environment (Protection) Act,1986and Section-20 of The Andhra Pradesh Water, Land and Trees Act,2002 and also Rule-19 of The Andhra Pradesh Water, Land and Trees Rules,2002, 3) The civic society in Visakhapatnam appraising about the alarming situation arising out of indiscriminate passage of untreated Pharma Industrial effluents and sewerage water containing noxious, toxic and plastic waste. 4) The visit of Petitioners to protect lakes and tanks In Uttarandhra has been published https://www.deccanchronicle.com/nation/crime/190719/visakhapatnam- industrial-waste-polluting-tanks~ nt and the ist petitioner has made a clear, clarion and open statement accusing the AP Pollution Control Board and published Is " ae Scanned with CamScanner1s Quote:"Visakhapatnam: The health of the people Is In danger as industrial wastes have been contaminating the water bodies in the city. Apart from the toxic chemicals disposed off by the industries, pesticides used in agricultural lands are also spelling a doom to the environment. This is also having an impact on the health of human beings and animals. Expressing serious concern over the increasing water pollution, environmentalists have demanded the Andhra Pradesh Control Board (APPCB) to take immediate action on the factories and industries that do not follow proper disposing of sewage, industrial effluent or any other waste into water bodies causing loss to public health. Jal Biradari (Water Community) founder and well-known water conservationist viz., the 1% petitioner, who is also known as the Waterman of India and recipient of Raman Megasessay International ‘Award for his work in the field of Reviving the Water Sources, Water Bodies in and around Rajasthan State wrote a letter to the Chief Minister of Andhra Pradesh to protect the water bodles from toxic substances. The 2" petitioner is the National Convener of the Jal Biradari. ‘The members of Jal Biradari, in which the petitioners are members observed that the industrial pollutants of Jindal, Mahamaya and GSAL steel industries reach up to Meghadrigedda of Vishakapatnam and the petitioners sought the civic bodies of Vishakapatnam to look at the inflow of water sources to the rivers, tanks and reservoirs. The petitioners also Urged the GVMC commissioner to protect the water bodies from pollution, ddustries. encroachment and over exploitation by thi It is pathetic that untreated sewer with plastic waste from the city flows into the sea at Peda Jalaripeta. On the other side, the toxic chemical waste from Pharma City enters into the beach near Parawada. The APPCB must take action to save human and marine life as well as the livelihood of the fishermen,” he further added. Jal Biradari members have demanded the administration officials for demarcation of tanks and catchment areas. They also asked to Identify Leb wk Scanned with CamScanner16 the inflows to the tanks and re-establish them to rejuvenate the tanks. -UnQuote 5) The Petitioners also mention that for the last three years the Petitioners are raising the awareness on this issue but authorities of GVMC or the Pollution Contro! Board and other respondents have not shown any concern. Whenever there is a downpour due to rains, the Tainwater washes large amounts of plastic on to the beach, further aggravating the situation. The Respondents should realize that Environment, Ecology, Bio-diversity, Air and Water pollution amount to violation of the RIGHT TO LIFE of the Fishermen as assured in Article.21 of the Constitution. Further it's the responsibility of the authorities who are shown as respondents herein, under Article 48-A of the Constitution that “the Protection and improvement of environment and safeguarding of forests and wild life, the State shall endeavor to protect and improve the environment and safeguard the forests and wild life of the country” 6) The State and various Authorities should do the same as they are duty bound and the respondents di citizens and environment enthusiasts the petitioners have put their best not do it and as a responsible efforts to appraise about the situation and consequences, but no response from any of the respondents and no let-off in the situation on the ground and untreated sewer going into the sea and thereby a large number of fish died in the area and the same was being seen on the shore of the Rishikonda beach area and the same is being reported in various print and electronic media on Dt.19-08-2020, yet no action has been initiated till today and no enquiry being conducted in to the matter by app an independent commission consisting of eminent people who are having academic and experienced qualification in the said field of Toxicology and ate action on the errant Pharma ting Marine Biology and also to i companies, by the authorities i.e., the respondents who are to look into the matter as per law, instead, divulging the issue by throwing the blame on the Mother Nature. 7) The State Government and the authorities of GVMC have not responded on the representations given by the civic societies and hence the 1° petitioner representing Tarun Bharat Sangh wrote a letter to the tbh Scanned with CamScanner\4- Commissioner of GVMC on 01-07-2019 mentioning therein various environmental issues being faced by the Visakhapatnam and other areas In and around and one of the key Issue ralsed specifically Is about untreated sewer In Vishakhapatnam and Industrial Effluent being let pass In to sea from Parawada Industrial Area, consisting of Pharma City. 8) Many a time, the matter was being taken before the Commissioner of GVMC by the 2 petitioner who is working in tandem with 1* petitioner, being the local area man and an environmentalist himself, Yet no action has been initiated, nor being verified as to the passage of Industrial effluents and untreated sewage water containing noxious and toxic plastic material into the sea waternear Peddajalaripeta from a drain flowing from Megadhrigedda through VishakhapatnamCity at Lawson's Bay, Rishikonda Area Vishakhapatnam,and also untreated toxic chemical waste flowing from Parawada and also in to adjacent water bodies. 9) Recently in the 3" week of August large number of carcasses of dead fish came to shore of the Rishikonda area at Visakhapatnam showing large level of pollution of sea water in an area of Vishakhapatnam, the industrial effluents and toxics sewerage of water containing plastic material mixing in the sea water and making the lives of the fishermen living in the villages on the coast and also effecting their livelihood. 10) The same is being reported In majority of English National and Local Vernacular print and electronic media and the situation is very alarming ‘even endangering environment and the human life, if they take this dead fish as food innocently. Even now, inspite of reporting of the matter in various media platforms, and the 2% petitioner being taken the same to the authorities of GVMC, they have not visited the place and nor conducted any enquiry, nor initiated any action against the Pharma companies situate in Pharma City of Parawada, 11) Being aggrieved by the inaction of the authorities of the GVMC, inspite of many reminders made to them by the petitioners, and due to the untoward incident of death of large number of fish and the same is being coming and accumulated on the shore of the Rishikonda beach area “ dahofe el Scanned with CamScannerVisakhapatnam, the petitioners prefer this application before the Hon’ble court for appropriate a ns, reliefs and redresses. 12) The petitioners urge that an Immediate enquiry is to be ordered into the incident of death of large number of fish coming and depositing to the Rishkonda Sea shore, for which the authorities of the Department of Fisherles saying and throwing the blame on the Mother Nature and also depletion of Oxygen levels in the sea water. If what the authorities of Department of Fisherles, is to be believed, all kinds of fish are to be dead and come and accumulate on the sea shores. But, only one kind of fish are dead and accumulated on the shores of Rishikonda beach, speaks volumes about the high contamination of sea water due to industrial effluents and untreated sewage water containing noxious and toxic plastic material into the sea waternear Peddajalaripeta from a drain flowing from Megadhrigedda through VishakhapatnamCity at Lawson's Bay, Rishikonda Area Vishakhapatnam, for which the more sensitive fish could not survive in the sea water consequently died and their carcasses are being accumulated on the beach shore of Rishikonda Beach. 13) The 4! respondent is the overall in-charge and supervisor of environment, it’s protector and implementor of various measures and violations as per Environment Laws and hence is formally added as the one of the party to the proceedings. 14) The petitioners urge that an immediate enquiry is to be ordered in to the incident, as to why the authorities of GVMC or other government authorities not responded to the various representations made by the civic societies, more particularly of the petitioners, and also initiate action against the errant Pharma City industrial companies who are allowing 9 noxious, toxic and plastic material into the seaand adjacent water bodies, ‘as per the procedure prescribed under various Environmental Laws. theuntreated industrial effiuents and toxic sewerage water contai 15) The petitioners also urge that an immediate remedial actions of not allowing untreated industrial effluents and toxic sewerage water being thrown in to the nearby sea watersand adjacent water bodies, falling which greater damage may also ensue in near future endangering Flora _ Lhe Scanned with GanSconnerand Fauna, Biodiversity and also endangering the lives and health conditions of the Fishermen living on the abutting sea shore of the area. 16) The Petitioners also urge that the Hon’ble Court may order for appointment of an Expert Committee consisting of eminent people and Scientists who are Experts in Environmental Laws, Bio-Diversity studies, Marian Biology, Marine Engineering, and Industrial and Chemical Experts and to conduct and identify the reasons, causes and remedial measures for this Industrial and Chemical Hazardous Pollutants, and future degradation of Water and Land pollutions across the line of Coast of AP, and more particularly of Vishakapatnam, Kakinada etc., 5. E OF INFORMATI THE PETITION:- The information furnished by me in this petition consists of the various local media publications, Appeals through Media, Letter Dt.01-07- 2019 to Commissioner of GVMC, Environmental Laws, gone through by me and there after I believe them to be true and correct. 6. NATURE OF EXTENT OF INJUR) |ED/ APPREHENDED: - The petitioners also urge that an immediate remedial actions of not allowing untreated industrial effluents and toxic sewerage water being thrown in to the nearby sea water and adjacent water bodies, failing which greater damage may also ensue in near future endangering Flora ‘and Fauna, Biodiversity and also endangering the lives and health conditions of the Fishermen living on the abutting sea shore of the area. 7. REPRESENTATIONS MADE, IF ANY:- Letter Dt.01-07-2019 written to Commissioner, GMC on behalf of Tarun Baghat Sangh, by ist petitioner and various representations through media by visiting the sites. 8. LAY MADE, IF ANY:= NO DELAY yo Lib fh Scanned with GanSconner2O 9, DOCUMENTS RELIED UPON: St. No | Description of Document | Date of paper 1. [Copy of Representation to the commissioner, 11.08.2019 | | Gvatc, Visakhapatnan | FR Fopy oF Paper Neves Cutting (THE HINDU) 16,02.2020 3 | Copy ‘of Paper News Cutting (TIMES OF INDIA). [16, 02,2020 4 {Copy of Paper News Cutting (DECCAN 19.00.2019 CHRONICLE), I filed all the documents in the material papers filed along with the present writ petition. 10, In the circumstances stated above, the petitioner has no efficacious alternative remedy, except to seek the redressal before this Hon'ble Court seeking the indulgence of this Hon’ble Court to exercise the extraordinary original jurisdiction vested in this Hon'ble Court by virtue of Article 226 of the Constitution of India. The petitioner has not filed any writ petition, suit or other proceedings for the relief or relleves sought hereln MAIN RELIEF It Is therefore prayed that this Hon’ble Court may be pleased to issue a Writ, Order or Direction, more particularly one In the nature of Writ of Mandamus by remedial actions of not allowing untreated Industrial effiuents and toxic sewerage water being thrown In to the nearby sea water and adjacent water bodies, falling which greater damage may also ‘ensue In near future endangering Flora and Fauna, Biodiversity and also endangering the lives and health conditions of the Fishermen llving on the abutting sea shore of the area and to pass such other order or orders a5 this Hon'ble Court deems fit and proper In the sald circumstances of the case and in the interests of justice. INTERIM RELIEF : It is therefore prayed that this Hon’ble Court may be pleased to order for appointment of an Expert Committee consisting of eminent persons such as scientists who are Experts in Environmental Laws, Blo~ Diversity studies, Marian Biology, Marine Engineering, Industrial and other experts to conduct and Identify the reasons, causes and for suggesting remedial measures for this Industrial and Chemical Hazardous Pollutants, across the line of Coastal of AP (Visakhapatnam & Kakinada), pending disposal ‘of the WP PIL and to pass such other order or orders as this Hon'ble Court deems fit and proper In the sald circumstances of the foknfir case and In the interests of justice. w ‘Scanned with GawScannerAL, CAVEAT, IF ANY:= a1 1 submit that there Is no notice of caveat has been received of lodging of caveat by this petitioner. 11, 1 submit that 1 did not face Contempt courts proceedings under the Contempt of Courts Act, 1971, 12, I submit that, 1 have not been ordered by this Hon’ble Court or any other court not to file public Interest litigation cases. 13, T submit that, 1 was not Involved In a civil, criminal and revenue which has a nexus with preset W.P. (PIL). 14, [hereby solemnly state under oath affirm and declare that the writ petition Is being Instituted purely in public interest and not at the Instance of any other person or organization. 15. I hereby solemnly state on oath and affirm and declare that the questions raised In the Writ Petition has not been ralsed are agitated carller and that there Is no other case(s) or petition(s) filed or that are pending before this Hon’ble Court or any other Forum or Court to the best of my knowledge, research and belief. sworn and signed before me Loh fe. This the 16" of September, 2020 [e Deponent we Advocate/ Amaravathi + CStpemncnees VERIFICATION STATEMENT 1, Bolisetty Satyanarayana, S/o. Sreemnnarayana, Hindu, aged about 62-years, Occu: Environmentalist, R/o. HIG-50, MVP Colony, Sector-1, Vishakapatnam Urban, Andhra Pradesh., the petitioner herein whatsoever facts stated above In the above affidavit are true to the best of my knowledge, bellef and Information. verified on this 16" day of September, 2020 at Amaravathl. debe. seve ‘the Petitioner Petitioner Hence, Scanned with CamScanner2L IN THE HIGH COURT FOR THE STATE OF ANDHRA PRADESH AT AMARAVATHI WP(PIL).NO. OF 2020 Between: 1. Dr. Rajendra Singh, S/o. Sukireer Singh, Hindu, aged 61-years, Environmentalist and Waterman of India, Reman Megasessy Awardee, Ro. Ward No-8, Teh Tanagazi, Tarun Bharat Sangh, Bhikampure, Alvar, Rajasten-301002 Aadhar No.7432 4176 0362 Email: rajenS9singh@gmail.com Jelpurushtbs@gmail.com Phone: +91 9414066765 2. Bolisetty Satyanarayana S/o. Srimannarayana, Hindu, aged 62-years, Environmentalist, P/o. HIG-50, MVP Colony, Sector-1, Vishakapatnam-530 017 ‘Aadhar No.3594 1483 9729 Email: bolisettisatyanarayana@gmail.com Phone: +91 9849152757 Bank A/c.No.00501530013772, HOFC Bank, IFSC:HDFC0000050, Dwraka Nagar Branch, Vishakapatnam. Petitioner AND 1. The State of Andhra Pradesh, Rep, by its Special Chief Secretary, Environment and Forest, Government of Andhra Pradesh. Secretariat, Velagapudi, Amaravathi. Email: sples_efst@ap.gov.in 2. The Chairman, ‘AP State Pollution Control Board, Government of Andhra Pradesh, Velagapudi, Amaravathi. Phone:0866-2463202 3, The Chairman, AP State Bio-diversity Board, State of Andhra Pradesh, Email: apsbiodiversityboard@gmail.com w LAn fe pea ee Scanned with CamScanner23 4, The Secretary, Ministry of Environment, Forests & Climate Change (MOEF & CC) Union of India, Indira Paryavaran Bhawan, Jor Bagh Road, New Dethi-110 003 Email: secy_moef@nic.in Phones: +91 11 24695262; 2462192 (Office) +91 11 24695270 (Fax) 5. The District Collector, Ojo. Collectorate Visakhapatnam, Visakhapatnam District. Email: collector_vsk@ap.gov.in . The Commissioner, fo. Commissionerate of GVMC, Greater Visakhapatnam Municipal Corporation, Visakhapatnam. Email: commissioner_gvme@yahoo.co.in 1, Bolisetty Satyanarayana S/o. Srimannarayana, Hindu, aged 62-years, : Environmentalist, R/o. HIG-50, MVP Colony, Sector-1, Vishakapatnam, ‘Aadhar No.3594 1483 9729, having temporarily come down to Amaravathi, do hereby solemnly and sincerely affirm and state on oath and follows: 1. Iam the 2” petitioner herein and I am well acquainted with the facts of the case and I am authorized to file this petition on behalf of other 1* petitioner also do to : so. 2. I state that my mail ID is bolisettisatyanarayana@gmail.com, mobile number +91 9849152757, Aadhar number 3594 1483 9729, Bank Account No. 0050153013772, HDFC Bank, IFSC:HDFCO000050,Dwaraka Nagar Branch, PAN Number z ADAPB2940B and my address and all particulars furnished in the g above cause title is true and correct, 4 5 ql a 3 p debhfe Scanned with CamScannerply 1am herewith annexing coples of Andhar Card, Banke Aecount, PAN Card towards my Wlentty and address proof as required ‘under Rulae8(b) of the PIL Rules, 2108, 4,1 submit that 1 did not face contempt of court proceedings Lunda tha Contempt of Courts Act, 1971. 5. 1 have not been ordered by this Hon'ble Court or any other court not to file Public Interest Litigation Cat95, 6. submit that I have not involved In a cil, eriininal and revenue cases, 7 Lan not a party In panding eWvil or criminal cases that has a nexus with the subject motter of the above public Interest Uitigation ec : Lob fi last page corrs. Deponent Solemnly andl siycerely aff this the day of 1609-2020 and signed his name in my presence, ean pol ADVOCATE :: AT AMARAVATHI (ornare wus WR) VERIFICATION STATEMENT. I, Bollselty satyanarayana S/o, Srimannarayanarao, Aged about 62-years, R/o.HIG-50, MVP Colony, Sector-1, Vishakapatnam- 530017, Andhra Pradesh, Aadhar No.3594 1483 9729 Email: bollsettisatyanarayana@gmall.comPhone: +91 9849152757, being the petitloner/ person acqualnted with the facts do hereby verfy and state that the contents of the above paras of the Affidavit are true and correct to the best of my knowledge, Hence verifed at AT AMARAVATHT on this the day of 17-09-2020 Lie LAL. Scanned with CamScanner“eG HIGH COURT GF ANDHHA PRADESH AT AMAKAUATHE WHOL) NO. F Mity Between: 1. Dr. Hajendra Sinigti, Sfo. Sukinrees Siregh, Hin aged 61-years, Erotrorinentalise atid Waterrnan of India, Rarnan Mecsas hares, flo, Wand No-f, Tah Tanagpd, Carin thatsk Sait, Bhilkampura, Alvar, Kapastan- AGL ‘adhion No.1452 4116 O62 HJendosinyh@geriail.corts htbe@yrniail cont Phones +91 9414066765 2. Bolisetty Satyanarayana Sfo, Srimannarayana, Hind, ‘aged 62-years, Envirorinsntalis, Ro, HIG-50, MVP Colony, Settor4, Vishakapatnarn-520 017 Aadhar No.3594 1483 9729 Email: bolisettisatyanarayana@grnall.comn Phones +91 984911 Bank A/c.No,00501530013772, HOFC Bank, FICHDFCIOIIS, Dviaraka Nagar Branch, Vishakapatnarn, Veiner AND 1, The State of Andhra Pradesh, Rep. by Its Special Chief Secretary, Environment and Forest, Governmnent of Andhra Pradesh, Secretariat, Velagapudl, Amaravatht, Emall: splcs_efst@ap.gov.in 2, The Chalrinan, ‘AP State Pollution Control Board, Government of Andhra Pradesh, Velagapudl, Amaravathl. Emall: chairrnan@appeb.gov.in Phone:0866-2463202 3, The Chairman, AP State Blo-diversity Board, State of Andhra Pradesh, Emall: apsblodiversityboard@gmnall.com [phe ‘Scanned with GawScanner26 4, The Secretary, Ministry of Environment, Forests & Climate Change (MOEF & CC) Union of India, Indira Paryavaran Bhawan, Jor Bagh Road, New Delhi-110 003 Email: secy_moef@nic.in Phones: +91 11 24695262; 2462192 (Office) +91 11 24695270 (Fax) 5. The District Collector, Ofo. Collectorate Visakhapatnam, Visakhapatnam District Emall: collector_vsk@ap.gov.in 6. The Commissioner, fo. Commissionerate of GVMC, Greater Visakhapatnam Municipal Corporation, Visakhapatnam. Email: commissioner_gvme@yahoo.co.In Respondent t DECLARATION FILED UNDER RULE 6 ILES, 201: I, Bolisetty styanarayana S/o. Srimannarayanarao, Aged about 62-years, R/O.HIG-50, MVP Colony, Sector-1, Vishakapatnam- 530017, Andhra Pradesh, Aadhar No.3594 1483 9729. Email: bolisettisatyanarayana@gmall.comPhone: +91 9849152757, now having temporarily come down to AT AMARAVATHI, do hereby solemnly and sincerely affirm and state on oath and declare that the writ petition (PIL) is being instituted purely In Public Interest and not at the instance of any other persons or organization other than the petitioner. Verified at AT AMARAVATHI on this day 17-09-2020 fate Deponent Nene —— li Scanned with CamScanner2 IN THE HIGH COURT FOR THE STATE OF ANDHRA PRADESH AT AMARAVATHI WP(PIL).NO, OF 2020 Between; 1, Dr. Rajendra Singh, S/o. Sukhveer Singh, Hindu, aged 61-years, Environmentalist and Waterman of India, Raman Megasessy Awardee, Ro, Ward No-8, Teh Tanagazl, Tarun Bharat Sangh, Bhikampura, Alwar, Rajastan-301002 ‘Radhar No.7432 4176 0362 Emall: rajens9singh@gmall.com Jalpurushtbs@gmail.com Phone: +91 9414066765 2, Boliselty Satyanarayana S/o. Srimannarayana, Hindu, aged 62-years, Environmentalist, R/o, HIG-50, MVP Colony, Sector-1, Vishakapatnam-530 017 Aadhar No.3594 1483 9729 Email: bolisettisatyanarayana@gmail.com_ Phone: +91 9849152757 Bank A/c.No.00501530013772, HDFC Bank, IFSC:HDFC0000050, Dwaraka Nagar Branch, Vishakapatnam. Petitioner AND 1. The State of Andhra Pradesh, Rep. by Its Special Chief Secretary, Environment and Forest, Government of Andhra Pradesh. Secretariat, Velagapudl, Amaravathi. Emall: splcs_efst@ap.gov.in 2. The Chairman, AAP State Pollution Control Board, Government of Andhra Pradesh, Velagapudi, Amaravathi. Email: chaitman@appcb.gov.in Phone:0866-2463202 3, The Chairman, AP State Bio-diversity Board, State of Andhra Pradesh, Emall: apsbiodiversityboard@gmall.com ica Lb> Sf. Scanned with CamScanner22 4. The Secretary, Ministry of Environment, Forests & Climate Change (MOEF & CC) Union of India, Indira Paryavaran Bhawan, Jor Bagh Road, New Delhi-110 003 Email: secy_moef@nic.in Phones: +91 11 24695262; 2462192 (Office) +91 11 24695270 (Fax) 5. The District Collector, Ojo. Collectorate Visakhapatnam, Visakhapatnam District. Email: collector_vsk@ap.gov.in ‘The Commissioner, fo. Commissionerate of GVMC, Greater Visakhapatnam Municipal Corporation, Visakhapatnam, Email: commissioner_gvme@ yahoo.co.in Respondent AFFIDAVIT IN COMPLIANCE WITH RULE 7A : OF THE PUBLIC INTEREST LITIGATION RULES, 2015 1, Bolisetty Satyanarayana S/o. Srimannarayana, Hindu, aged 62-years, ‘ Environmentalist, R/o. HIG-50, MVP Colony, Sector-1, Vishakapatnam, ‘Aadhar No.3594 1483 9729, having temporarily come down to Amaravathi, do hereby solemnly and sincerely affirm and state on oath and follows: 1, Lam the 2” petitioner herein and I am well acquainted with the facts of the case and I am authorized to file this petition on behalf of other 1* petitioner also do to 50. 2. Thereby affirm and state on oath that I have no personal interest in the above subject matter of this petition. I hereby undertake to pay exemplary costs and or compensatory | | ‘ Scanned with CamScanner24 damages as directed by the court that the wilt petition (PIL) Is, filed for extraneous / personal considerations or with aft oblique motive, ey last page corrs. Deponent Solemnly and sincerely affirm this the day of 17-09-2020 and signed his name in my presence, BEFORE, (‘ ADVOCATE S AMARAVATHI La ee meen’ VERIFICATION STATEMENT 1, Bolisetty satyanarayana S/o. Srimannarayanarao, Aged about 62-years, R/O.HIG-5S0, MVP Colony, Sector-1, Vishakapatnam- 530017, Andhra Pradesh, Aadhar No.3594 1483 9729 Emall: bolisettisatyanarayana@gmall.comPhone: +91 9849152757, being the petitioner/ person acquainted with the facts do hereby verify and state that the contents of the above paras of the Affidavit are true and correct to the best of my knowledge. Hence verified at AT AMARAVATHI on this the day of 17-09-2020 dle and - so | Scanned with CamScanner20 IN THE HIGH COURT FOR THE STATE OF ANDHRA PRADESH AT AMARAVATHI WP(PIL).NO. OF 2020 Between: 41, Dr, Rajendra Singh, S/o, Sukhveer Singh, Hindu, ‘aged 61-years, Environmentalist and Waterman of India, Raman Megasessy Awardee, Ryo, Ward No-8, Teh Tanagaz), Tarun Bharat Sangh, BBhikampura, Alwar, Rajastan-301002 ‘nada No.7432 41176 0362 mall: rajenS9singh@gmal.com Jalpurushtbs@gmall.com Phone: +91 9414066765 2, Bolisetty Satyanarayana S/o, Srimannarayana, Hindu, ‘aged 62-years, Envlronmentalls, Ryo. HIG-50, MVP Colony, Sector, Vishakapatnam-530 017 ‘Aadhar No.3594 1483 9729 Email: bollsetisatyanarayana@gmall.com Phone: +91 9849152757 Bank A/c.No,00501530013772, HDFC Bank, IFSC:HDFCO000050, Dwaraka Nagar Branch, Vishakapatnam, Petitioner AND 1, The State of Andhra Pradesh, Rep. by ts Special Chief Secretary, Environment and Forest, Government of Andhra Pradesh, Secretariat, Velagapudl, Amaravathl. Emall: sples_efst@ap.gov.in 2, The Chairman, AP State Pollution Control Board, Government of Andhra Pradesh, Velagapudl, Amaravathl. Email: chalrman@appcb.gov.In Phone:0865-2463202 3, The Chairman, AP State Blo-diversity Board, State of Andhra Pradesh, Email: apsblodiversityboard@gmall.com Ltn Scanned with GanSconner4, The Se Ministry of Environment, Forests & Climate Change (MOEF & CC) Union of India, Indira Paryavaran Bhawan, Jor Bagh Road, New Delhl-110 003 Emall: secy_moef@nic.in Phones; +91 11 24695262; 2462192 (Office) +91 11 24695270 (Fax) 5, The District Collector, Ofo. Collectorate Visakhapatnam, Visakhapatnam District, Emall: collector_vsk@ap.gov.in 6, The Commissioner, fo, Commissionerate of GVMC, Greater Visakhapatnam Municipal Corporation, Visakhapatnam. Emall: commissioner_gvme@yahoo.co.in Respondent DECLARATION FILED UNDER RULES LITIGATI I, Bollsetty styanarayana S/o. Srimannarayanarao, Aged about 62-years, R/o.HIG-50, MVP Colony, Sector-1, Vishakapatnam- 530017, Andhra Pradesh, Aadhar No.3594 1483 9729 Email: bolisettisatyanarayana@gmallcomPhone: +81 9849152757, now having temporarily come down to AT AMARAVATHI, do hereby solemnly and sincerely affirm and declare that the questions made in the writ petition (PIL) has not been raised are agitated earlier and there are no other case/s or petition/s filed or that are pending before this Hon'ble Court or any other forum or court to the best of my knowledge, and belief. Verified at AMARAVATHI on this day 17-09-2020 Me eet Scanned with CamScannerSr IN THE HIGH COURT FOR THE STATE OF ANDHRA PRADESH AT AMARAVATHT WP(PIL).NO. OF 2020 Between: 1. Dr, Rajendra Singh Jo. Sukhveer Singh, Hindu, aged 61-years, Environmentalist and Waterman of India, Raman Megasessy Awardee, Ryo, Ward No-8, Teh Tanagazl, Tarun Bharat Sangh, Bhikampura, Alwar, Rajastan-301002 ‘Aadhar No.7432 4176 0362 Email: rajenS9singh@gmail.com jalpurushtbs@ gmail.com Phone: +91 9414066765 2. Bolisetty Satyanarayana So. Srimannarayana, Hindu, aged 62-years, Environmentalist, R/o. HIG-50, MVP Colony, Sector-1, Vishakapatnam-530 017 Aadhar No.3594 1483 9729 Email: bolisettisatyanarayana@gmall.com Phone: +91 9849152757 Bank A/c.No,00501530013772, HDFC Bank, IFSC:HDFC0000050, Dwaraka Nagar Branch, Vishakapatnam. Petitioner AND 1. The State of Andhra Pradesh, Rep. by its Special Chief Secretary, Environment and Forest, Government of Andhra Pradesh. Secretariat, Velagapudi, Amaravathi, Email: sples_efst@ap.gov.in 2. The Chairman, AP State Pollution Control Board, Government of Andhra Pradesh, Velagapudi, Amaravathi. Email: chaltman@appcb.gov.in Phone:0866-2463202 3. The Chairman, AP State Bio-diversity Board, State of Andhra Pradesh, Email; apsbiodiversityboard@gmail.com eo LAG. Scanned with CamScanneros 4, The Secretary, Ministry of Environment, Forests & Climate Change (MOEF & CC) Union of India, Indira Paryavaran Bhavan, Jor Bagh Road, Nev Delhi-110 003 Email: secy_moef@nic.in Phones: +91 11 24695262; 2462192 (Office) +91 11 24695270 (Fax) 5. The District Collector, Ofo. Collectorate Visakhapatnam, Visakhapatnam District. Email: collector_vsk@ap.gov.in 6. The Commissioner, fo. Commissionerate of GVIMC, Greater Visakhapatnam Municipal Corporation, Visakhapatnam, Email: commissioner_gvmc@yahoo.co.in Respondent AFFIDAVIT IN_COMPLIANCE WITH RULE 10(a),(b).(c)&(e) OF ‘THE PUBLIC INTEREST LITIGATION RULES, 2015 1, Bolisetty Satyanarayana S/o. Srimannarayana, Hindu, aged 62-years, Environmentalist, R/o. HIG-50, MVP Colony, Sector-1, Vishakepatnam, ‘Aadhar No.3594 1483 9729, having temporarily come down to Amaravathi, do hereby solemnly and sincerely affirm and state on oath and follows: } 1, Lam the 2™ petitioner herein and I am well acquainted with the facts of the case and I am authorized to file this petition on behalf of other 1* petitioner also do to so. 2. I respectfully state that I have no personal gain, private motive or oblique reason In filing the present public Interest Litigation. we Lobwomll eC a io al Scanned with GonSconnera4 3. Thereby undertake to pay costs as ordered by the court, if it Is ultimately held that the petition Is frivolous or has been filed for extraneous consideration or that It lack bona fides, 4.1 hereby undertake that 1 will disclose the source of my information, leading to the filing of the Public Interest Ligation, if and ‘when called upon by the court, to do so, 5. I hereby undertake that I will disclose the source of my information, leading to the filing of the Public Interest Litigation, if and when called upon by the court, to do so. 6. I hereby undertake that in case I seeks to withdraw the petition Or if I fail to attend the case by myself or through my advocate, I will bear the cost incurred by the respondent and pay such amount of additional costs as may be imposed in the discretion of the court. dete. last page corrs. Deponent Solemnly and sincerely affirm this the day of 17-09-2020 and signed his name in my presence, BEFORE Mi Jol ‘ADVOCATE :: AMARAVATHI » SBR GRERVER OG 1, Bolisetty styanarayana S/o. Srimannarayanarao, Aged about 62-years, R/O.HIG-50, MVP Colony, Sector-1, Vishakapatnam- 530017, Andhra Pradesh, Aadhar No.3594 1483 9729 Emall: bolisettisatyanarayana@gmail.comPhone: +91 9849152757, being the petitioner/ person acquainted with the facts do hereby verify and state that the contents of the above paras of the Affidavit are true and correct to the best of my knowledge, Hence verified at AT AMARAVATHI on this the day of | 17-09-2020 > ' Saban Xx Deponent Le Scanned with CamScannerSINGLE / BENCH SERVICE/NON-SERVICE DEFT: Category Code and Sub Category Code ‘Admission Court: HIGH COURT ‘SPECIAL ORIGINAL JURISDICTION ‘WiP(PIL).NO. OF 2020 VISAKHAPATNAM District Dr. Rajendra Singh -Petitioner/s By M/s CHALLA AJAY KUMAR (5250) COUNSEL FOR PETITIONER NATURE OF APPLICATION (Under Art. 226 of Constitution of India) The Hon'ble Court may be pleased to issue @ Writ, Order or Direction, more particularly one in the nature of Writ of Mandamus by remedial actions of not allowing untreated industrial effluents and toxic sewerage water being thrown in to the nearby sea water and adjacent water bodies, failing which greater damage may also ensue in near future endangering Flora and Fauna, Biodiversity and also endangering the lives and health conditions of the Fishermen ving on the abutting sea shore of the area and to pass such other order or orders as this Hon'ble Court deems fit and proper in the said circumstances of the case and in the Interests of justice. and to pass such other order or orders as this Hon'ble Court may deems fit Just and proper in the circumstances of the case. Permitted on ; 17-09-2020 Presented on : 17-09-2020 Filedon ——: 17-09-2020 LANo. OF 2020, Scanned with CamScanner