IN THE HIGH COURT FOR THE STATE OF TELANGANA AT HYDERABAD

Contempt Case No. of 2021

in

W.A.No. 938 of 2019

Between:

Smt. Mangilipalli Bhargavi d/o Ramulu,

aged about 35 years, r/o H.No. 9105/15,
Sai Maruthi Nagar Colony, Boduppal village,
Ghatkesar Mandal, R.R.District. ..Petitioner/Appellant
No. 23

and

1) Sri Rahul Bojja, I.A.S., Principal Secretary

Social Welfare Department, State of Telangana
Secretariat, Hyderabad.

2) D. Ronald Rose, IAS , o/o the Secretary

Telangana Tribal Welfare residential Education
Institutions, D.S.S.Bhavan, Masab Tank,
Hyderabad.

3) Dr.R.S. Praveen Kumar, IPS, o/o the Secretary

Telangana Tribal Welfare residential Education
Institutions, D.S.S.Bhavan, Masab Tank,
Hyderabad.

4) Dr. B.Janardhan Reddy, IAS,

Chairman, Telangana State Public Service
Commission, Prathibha Bhavan, M.J.Road
Nampally, Hyderabad-500 001. ..Respondents/Respondents
Nos. 6, 7 and 8

AFFIDAVIT

I, Smt. Mangilipalli Bhargavi d/o Ramulu, aged about 35 years, r/o H.No.
9105/15, Sai Maruthi Nagar Colony, Boduppal village, Ghatkesar Mandal, R.R.District,
do hereby solemnly affirm and state on oath as follows:-

1) I am the petitioner herein and Appellant No. 23 in the above W.A.No. 938 of
2019 and as such I am well acquainted with the facts of the case.

2) I submit that myself and the 230 others have filed W.A.No. 938 of 2018 having
been aggrieved by the interim orders granted on 16-9-2019 passed in I.A.No 6 of 2019
and I.A.Nos 2 and 3 of 2018. I submit that during the course of hearing of the
W.A.No. 938 of 2018 and batch, the Government of Writ Appeal, by a common
Judgment dt. 8-3-2021 with the following order:
 -2-

“The Appellant/State is directed to complete the entire exercise and publish the
selected list of candidates in the two cadres at the earliest, preferably within two
weeks from today”

3) I submit that in the course of submissions the learned Additional Advocate

General states, on instructions, that the State may be permitted to comply with the
directions issued in the impugned judgment , calling upon it to identify and segregate
the PET posts that would be required to be filed up by those teachers, who would be
imparting physical education to students studying in Class IX and X in the respondents
institutions and that the said segregation is done, the eligibility of the candidates for the
subject posts shall be considered strictly in terms of the NCTE Regulations and on
merit. the i.e., 8.3.2021. It is submitted that once the appellant/State has agreed to
separate the cadre of the teachers, who have applied for the PET Posts into the posts
that will be earmarked for PETs upto Class VIII and posts that will be earmarked for
PETs for Class-IX and X, then the remaining directions contained in clauses (b) to (f) of
Para 67 of the Impugned Judgment will go and a fresh list of selection candidates shall
be published by the State by segregating the aadre as stated above, within two weeks.

4) I humbly submit that despite the specific directions passed by this Hon’ble Court
in W.A.No. 938 of 2019 and batch, the respondents have not chosen to implement the
same even after lapse of more than two weeks, when admittedly the respondents being
the authorities are bound to honour and implement the orders passed by this Hon’ble
Court, but they willfully and intentionally disobeyed the said orders and failed to
complete the entire exercise and publish the list of the selected candidates as a result
of which the candidates like me are put to hardship and I am sure that I would be
selected and unless and until the list of the selected candidates is displayed the further
process will not be done.

5) I submit that the respondents have no respect or regard towards the orders
passed by this Hon’ble High Court, and the negligence and disobedience of the
respondents in complying with the orders passed in W.A.No. 938 of 2019 clearly
constitutes the offence punishable under the provisions of Contempt of Courts Act,
1971. As such I have sent contempt notice dt.12-6-2021 to the respondents, but no
response is forthcoming.
 -3-

6) I submit that the Law of Contempt of Courts is for keeping the administration of
justice pure and undefiled. While dignity of the court is to be maintained at all costs,
the contempt jurisdiction, which is of a special nature, should be sparingly used. I
submit that any willful disobedience to the orders of the court to do or abstain from
doing any act or breach of any undertaking given to the court is prima-facie constitute
an offence punishable under the provisions of Contempt of Courts Act, 1971. In the
instant case, the respondents have flouted the said orders wantonly and rendered
themselves liable for punishment.

7) Therefore, it is prayed that this Hon’ble Court may be pleased to summon the
respondents herein before this Hon’ble Court and to punish them for wilfully and
deliberately flouting the orders passed in W.P.No. 938 of 2019 and batch dt. 8-3-2021,
in the interest of justice and to pass such other order or orders as this Hon’ble Court
deems fit and proper in the circumstances of the case.

Sworn and signed before me on

this the day of July, 2021
at Hyderabad. DEPONENT

Advocate/Hyderabad

VERIFICATION STATEMENT

I, Smt. Mangilipalli Bhargavi d/o Ramulu, aged about 35 years, r/o H.No.
9105/15, Sai Maruthi Nagar Colony, Boduppal village, Ghatkesar Mandal, R.R.District,
do hereby declare that what has been stated in para Nos. 1 to 7 filed in support of Writ
Petition are true and correct to the best of my knowledge and belief and also based on
legal advice given to me.

Verified at Hyderabad on this the day of July, 2021.

ADVOCATE DEPONENT
 Memorandum of Contempt Case
(Under Section 10 to 12 of Contempt of Courts Act, 1971)
IN THE HIGH COURT FOR THE STATE OF TELANGANA AT HYDERABAD

Contempt Case No. of 2021

in

W.A.No. 938 of 2019

Between:

Smt. Mangilipalli Bhargavi d/o Ramulu,

aged about 35 years, r/o H.No. 9105/15,
Sai Maruthi Nagar Colony, Boduppal village,
Ghatkesar Mandal, R.R.District. ..Petitioner/Appellant
No. 23

and

1) Sri Rahul Bojja, I.A.S., Principal Secretary

Social Welfare Department, State of Telangana
Secretariat, Hyderabad.

2) D. Ronald Rose, IAS , o/o the Secretary

Telangana Tribal Welfare residential Education
Institutions, D.S.S.Bhavan, Masab Tank,
Hyderabad.

3) Dr. B.Janardhan Reddy, IAS,

Chairman, Telangana State Public Service
Commission, Prathibha Bhavan, M.J.Road
Nampally, Hyderabad-500 001. ..Respondents/Respondents
Nos. 6, 7 and 8

The address for service of all notices etc., on the above named Petitioner is that
of his counsel B.Nachiketh, Advocate, Flat No. A-4, Raghavendra Krupa Apartment,
Domalaguda, Hyderabad.

For the reasons stated in the accompanying affidvit, it is prayed that this Hon’ble
Court may be pleased to summon the respondents herein before this Hon’ble Court and
to punish them for wilfully and deliberately flouting the orders passed in W.P.No. 938 of
2019 and batch dt. 8-3-2021, in the interest of justice and to pass such other order or
orders as this Hon’ble Court deems fit and proper in the circumstances of the case.

HYDERABAD

Dated: COUNSEL FOR PETITIONER

 RANGA REDDY DISTRICT

IN THE HIGH COURT FOR THE STATE

OF TELANGANA AT HYDERABAD

C.C.No. of 2021

in

W.A.No. 938 of 2019

CONTEMPT CASE

Filed by:

B. NACHIEKTH (10916)
Advocate

COUNSEL FOR PETITIONER