IN THE HIGH COURT OF JUDICATURE FOR

RAJASTHAN AT JOHDPUR

S.B. CIVIL WRIT PETITION NO. 18138/2022

PETITIONER:

L. N. Yadav

Versus

RESPONDENTS:

The State of Rajasthan and ors.

APPLICATION UNDER ARTICLE 226(3) OF CONSTITUTION OF

INDIA ON BEHALF OF RESPONDENTS

To,

The Hon'ble Acting Chief Justice and his other

companion Judges of the High Court of Judicature for

Rajasthan at Jodhpur.

MAY IT PLEASE YOUR LORDSHIPS:

The answering respondents submit following way

of reply to stay application :-

1. The answering respondents have filed a detailed para

wise reply to the writ petition.

2. That the answering respondent respectfully submits

that the reply to fact and grounds submitted by the

answering respondent may kindly be taken as part of

this reply to stay petition.

3. That from the parawise reply given by the answering

respondents, it is clear that the petitioner has not been

able to make out any case warranting any interim order

to be passed by this Hon'ble Court.

4. That this Hon'ble Court while issuing notice to the

respondents had passed interim order in favour of the

petitioner on 09.12.2022 staying the effect and operation

of order dated 7.11.2022 and order dated 22.11.2022

passed by RCSAT.

It has been categorically stated in the reply that that vide

order dated 02.10.2010 passed by the Agricultural Department

(Group-1), Assistant Director, Agriculture (Extension)

transferred earlier to Zila Parishads, Deputy Director,

Agriculture (Extension) working in the district in place of Zila

Parishad, complete staff, entire activities and the budget

provision is made under the Zila Parishad. Further, Staff and

activities of Horticulture Department and its subordinate

offices at district level and division level i.e. Office of

Assistant Director (Horticulture), Deputy Director

(Horticulture) and Joint Director (Horticulture), has not been

transferred under Panchayati Raj Department. The rules of

Rajasthan Panchayati Raj (Transfer Activities) Rules, 2011

does not applicable on the petitioner as he is Agriculture

Research Cadre Officer working in Horticulture Department

which has not been transferred to Panchayati Raj. That the

 petitioner has narrated a false story before this hon’ble court

for obtaining this interim order by concealment of true facts.

In these circumstances, the interim order is liable to be

vacated.

It is, therefore, respectfuly prayed that the stay

petition filed by the petitioner having no merit may kindly

be dismissed and the interim order dated 09.12.2022 may

kindly be vacated and cost may be imposed on the

petitioner for obtaining interim order on false basis and

concealment of fact.

COUNSEL FOR RESPONDENT RESPONDENTS

NOTES:

1. That no such application has ever been filed in this Hon'ble High Court.
2. That this application has been typed by my pvt. Steno.
3. That due to non-availability of pie-papers, this application has been typed on
these stout papers
4. Email – mcbishnoi@gmail.com, Mobile – 9414134477

COUNSEL FOR RESPONDENT

IN THE HIGH COURT OF JUDICATURE FOR

RAJASTHAN AT JODHPUR

S.B. CIVIL WRIT PETITION NO. 18138/2022

PETITIONERS:
L. N. Yadav
versus
RESPONDENTS:
The State of Rajasthan and Ors.

AFFIDAVIT IN SUPPORT OF THE APPLICATION

I, Rajesh Kumar, Aged About 55 years, Deputy

Director Agriculture (Stat.), in the office of Additional
Director Ag. Extension Jodhpur-Division, Jodhpur do
hereby swear in the name of God and state as under:-
1. That I am the office – in - charge in this case and as
such competent to sign and verify all the pleadings
related to this case.
2. That I have carefully gone through the entire
application and the application has been prepared in
consultation with me.
3.That the contents of the application, so far relate to facts
are true and correct to my knowledge based on official
record available.
4.That the legal submissions made therein are true and
correct based on legal advice given to me.

DEPONENT

VERIFICATION

I, the abovenamed deponent do hereby verify on

oath that the averments of my above affidavit are true
and correct to my knowledge and nothing has been
concealed therein and no part of it is false. So, help me
God.
 DEPONENT

IN THE HIGH COURT OFJUDICATURE FOR

RAJASTHAN AT JOHDPUR

S.B. CIVIL WRIT PETITION NO. 18138/2022

PETITIONER:

L.N Yadav
 Versus

RESPONDENTS:

The State of Rajasthan and ors.

INDEX
S. No. PARTICULAR PAGE
-----------------------------------------------------------------------------
1. Application under Article 226 (3)
of Constitution of India
1. Affidavit in support of application
=========================================
COUNSEL FOR RESPONDENTS

(M. C. BISHNOI)
Govt. Counsel