IN THE HIGH COURT OF JUDICATURE OF ANDHRA PRADESH AT HYDERABAD

Writ Petition No. 201 of 2019

IN THE MATTER OF:

Sri Bangaru Ram Das,
S/o. Sri Bangaru Ramanaiah
Aged about 40 years,
Member,
Andhra Pradesh Public Service Commission,
R/o 23?5/444, Nampally Road,
Hyderabad, Andhra Pradesh
Petitioner
Versus
Government of Andhra Pradesh,
Rep. by its Chief Secretary
Sri Venkata Swamy,
Secretariat
Hyderabad, Andhra Pradesh
& Ors
Respondents
AFFIDAVIT FILED ON BEHALF OF THE PETITIONER
I, Sri Bangaru Ram Das, S/o. Bangaru Ramanaiah, aged about 40 years, Occupation: Member
APPSC, R/o. 23/5/444, Nampally Road, Hyderabad, do hereby solemnly affirm and sincerely
state on oath as follows:
1. I am the petitioner herein and as such I am well acquainted with the facts and
circumstances of the case. Hence, I am deposing through this affidavit.
2. I humbly submit that the first respondent Government illegally, arbitrarily and without
verifying the facts and situations has appointed the respondent No. 2 the Chairperson of
Andhra Pradesh Public Service Commission vide order No. Estt./20/2006 dated
2.02.2006 for a period of two years from the date of taking over charge. The second
respondent took over charge on 10.02.2006 and he is continuing in the post ever since.
3. I humbly submit that the Respondent No. 2 herein is not at all qualified for the
appointment to the post of Chairperson, APPSC as is evident from a mere reference to the
relevant provisions of the Constitution of India. However, the first respondent arbitrarily
and in total deviation from the constitutional and legal requirements has appointed the
second respondent by ignoring the candidature of the petitioner for the said post without
assigning any reason.
4. I humbly submit that the second respondent does not have valid credentials apart from
qualifications for appointment to the post of the Chairperson. He was already involved in
many anti-corruption cases which are pending before the competent authority for the last
four years. Besides, the second respondent has an established criminal history showing
his involvement in a number of criminal cases some of which are pending before the
criminal courts.
5. I humbly submit that I am filing the present petition questioning the appointment of the
second respondent by the first respondent as chairperson of the APPSC as being illegal,
unconstitutional and against the settled principles of law, inter alia on the following:

GROUNDS
i. That the impugned order appointing the second respondent by the first respondent
being totally illegal, arbitrary, unconstitutional, against public policy and settled
principles of law and practice.
ii. That under the Constitution a person to be appointed as Chairperson has to fulfill
certain qualifications and whereas the respondent no. 2 did not possess such
qualifications either at the time of his appointment or even today.
iii. That the first respondent Government failed to see that he second respondent is
having a criminal background and involved in a number of anti- corruption and
criminal cases which are pending before the respective courts.
iv. That the first respondent Government has appointed the second respondent by
ignoring the candidature of other eligible and quite competent persons who were
competing for that post.
v. That the second respondent has no right or authority to continue in the post of
Chairperson of APPSC any more and his appointment is prima facie illegal and
unconstitutional.
6. I humbly submit that I have no other effective alternative remedy except approaching this
Hon’ble court.
7. I humbly submit that I have not filed any other suit, writ or other proceedings either
before this Hon’ble Court or before any other court or tribunal in connection with the
present subject- matter.
For the reasons mentioned above it is humbly prayed that this Hon’ble court may be pleased
to issue a writ, order or direction more so a writ in the nature of quo warranto quashing the
order no. Estt./20/2006 dated 2.02.2006 issued by the first respondent appointing the second
respondent as Chairperson, APPSC, as illegal and unconstitutional nad consequently
directing the second respondent to stop discharging the duties of Chairperson, APPSC
forthwith and a further direction to the first respondent to consider the case of the petitioner
for the appointment as Chairperson, APPSC with immediate effect and to pass such other or
further orders as this Hon’ble court may deem fit and proper in the facts and circumstances of
the case and in the interests of justice and fair play.

Place- Hyderabad
Date- 3-10-2019
Counsel for the Petitioner
Snajay Kapoor
Hyderabad, Andhra Pradesh

VERIFICATION
I, Bangaru Ram Das, Petitioner in the above Writ Petition, do hereby state that the contents
of the Writ Petition/ Writ Affidavit are true to my personal knowledge; as those paras 1 to 5
etc, are believed to be true and those paras 6 to 7 etc., are based on legal advice believed to
be correct.
Place- Hyderabad
Date- 3-10-2019
Counsel for the Petitioner
Snajay Kapoor
Hyderabad, Andhra Pradesh