REJOINDER

Content of para 3 of respondent is incorrect and misleading. Respondent in order to

mislead this court has concealed the fact in year 2011 respondent has issued
adverstismet for the regular appointment for the post of librarian. After 2011 till
2017 no adverstisement for the post of librarian has been issued by the respondent.

It is further denied that all the appointment were on temporary basis sustained out
of pta funds and only for one academic session. It is further submitted that the
petitioner was paid salary from the managing committee account and not from pta
account, as claimed by the respondent no. 1. It is pertinent to point out here that the
concept and system of pta ceased to exist since 2009 and same are misleading and
false to the knowledge of the respondents.
That content of para 4 of is factually incorrect and misleading. It is factually
incorrect and denied that re-appointment of the petitioner was made for the
academic session 2019-2020 and the term of the petitioner’s engagement
concluded at the end of the academic session i.e. in march 2020. It is submitted
that petitioner continued to receive starting from 2009 to 2020 without any break.
Check details of the same are annexed and marked here as annexure__.

Para 4 same as in the original rejoinder.

Para 5.
It is submitted that terms & conditions for appointment of wardens does not apply
to assistant warden as current warden is Zaheen Ahmed and petitioner is also
performing duties of assistant warden. It is further submitted on my request of
petitioner addressed to Hon’ble Vice chancellor, Jamia Millia Islamia for my
permanent appointment as Librarian dated 30.07.2018. the hostel is under the
supervision of Delhi Education Society and Janab Prof. Talat Ahmed, Vice
Chancellor, is also serving as president of Delhi Education Society.
Hon’ble Vice chancellor, Janab Prof. Talat Ahmed has recommended through
letter dated 30/07/2018, that petitioner may continue as assistant warden till
position of petitioner as Librarian becomes permanent.
Para 6.
It is claimed by the respondent no. 1 school that order dated 22.10. 2020 of this
Hon’ble high court shall not be considered as a stay order but only as a statement.
It is submitted that despite the order of this Hon’ble court, Respondent no. 1 has
appointed another person in complete violation of order of this Hon’ble court.

Para 7.
It has already been submitted in the para 4 that petitioner has continued to served
even after march 2020 and also received salaries from the respondent till May
2020. Therefore, claim of the respondent is incorrect and contrary.

Para 8.

Para 9. The claim of respondent that petitioner has applied for appointment on the
post of Librarian against the advertisement dated 27.06.2021 is factually incorrect.
It is submitted that after filing of this petition, the petitioner has not applied for the
against the said advertisement dated 27.06.2021.

Para 10. It is submitted that in pursuance of advertisement dated 27.10.2021 for the
post of librarian, the petitioner has raised the objection against said advertisement
through a legal notice addressed to the manager of respondent no. 1 school.

Para 11.