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IN THE SUPREME COURT OF INDIA

CIVIL ORIGINAL JURISDICTION
(PUBLIC INTEREST LITIGATION PETITION)
CIVIL WRIT PETITION NO. OF 2020
(UNDER ARTICLE 32 OF THE CONSTITUTION OF INDIA)
BETWEEN:
Kishan Chand Jain aged about 66 years S/o Late Shri Kailash Chand
Jain R/o 22/156, Moti Lal Nehru Road, Agra-282004 (UP) Ph. No.
9412263072, Email: kishanjain@gmail.com ………Petitioner
VERSUS
1. Union of India through its Secretary,
Department of Personnel and Training,
Ministry of Personnel, PG and
Pensions, North Block, New Delhi –
110001 ….Respondent No. 1
2. Union of India through its Secretary,
Ministry of Electronics & Information
Technology, Electronics Niketan, 6,
CGO Complex, Lodhi Road, New
Delhi–110003
Andhra Pradesh State Information
Commission,
1st Floor MGM Capital,
Near NRI Y Junction, Chinnakakani
(V), Mangalagiri (M), Guntur District,
PINCODE:522508
Anunachal Pradesh State Information
Commission
Block No 1, First Floor Room No. 107,
Civil Secretariat, Itanagar–791111,
Arunachal Pradesh (India)
Assam State Information Commission,
Jonakee Complex Shilpgram Road
Panjabari, Guwahati-37
Bihar State Information Commission,
Fourth Floor, Soochna Bhawan, Bailey
Road, Patna - 800021
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Chhattisgarh State Information

Commission
Sector-19, North Block, Nava Raipur
Atal Nagar, District - Raipur - 492002
(Chhattisgarh)
Goa State Information Commission
Kamat Towers, Patto Plaza, Patto
Centre, Panaji, Goa 403001
Gujarat State Information Commission
Karmayogi Bhavan, State Level
Offices, Block No. 1, Second Floor,
sector-10 A, Gandhinagar, Gujarat
382010
Haryana State Information
Commission
SCO No. 70-71(Ist Floor), Sector 8-C,
Chandigarh
Himachal Pradesh State information
Commission
E Bourne Hotel Rd, Nigam Vihar,
Khalini, Shimla, Himachal Pradesh
171002
J&K State Information Commission
DC office road, Jammu 180001, near
Deputy C commissioner Office,
Jammu and Kashmir 180001
Karnataka Information Commission
Mahiti Soudha, Devaraj Urs Road,
Opposite to Vidhan Soudha, West
Gate-2, Bengaluru-560001.
Kerala State Information Commission,
T.C. 26/298, Punnen Road
Thiruvananthapuram Kerala - 695 001
Madhya Pradesh State Information
Commission
35-B, Arera Hills, Bhopal (Madhya
Pradesh)-462011
Maharastra State Information
Commission
13th Floor, New Administrative
Building, Mantralaya, Mumbai 400032
Meghalaya State Information
Commission Ist Floor, New
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Administrative Building, Lower

Lachumiere, Shillong – 793001
Meghalaya
Mizoram Information Commission
New Secretariat Complex, Khatla
Mizoram : Aizawl-796001
Nagaland State Information
Commission,
Near Raj Bhavan, Officers Hill,
Kohima, Nagaland 797005
Odisha Information Commission
Address- B-1 Block, Toshali Bhawan
Satyanagar, Bhubaneswar-751007 E-
mail: odishasoochana@nic.in
Phone/Fax- (0674) 2571401/2570561

Punjab State Information Commission

Red Cross Building, Near Rose
Garden,
Sector 16, Chandigarh
Phone no. : 0172-2864105

Rajasthan State Information

Commission,
Jhalana Link Road,
OTS-MNIT Chauraha, JLN Marg
Jaipur-302017
E-mail: ric.rajasthan@yahoo.com

Sikkim Information Commission.

Lower Secretariat, 2nd. Floor.
Opposite Supermarket.
Gangtok - 73710, Sikkim, India

Tamil Nadu Information Commission

No.2, Theagaraya Salai, Near Aalai
Amman Koil,
Teynampet, Chennai - 600 018
(Post Box No. 6405, Teynampet,
Chennai - 600 018)

Tripura Information Commission

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(TIC),
Secretariat Annexe Building, ……….Respondent No.
Pt. Nehru Complex, 25
Agartala - 799 006
Tripura West.
Telephone : +0381 – 2318021
Email: Tripura.info123@gmail.com

Telangana State Information

Commission,
Samachara Hakku Bhavan,
D.No.5-4-399,
Behind Mozam-Jahi Market, ……….Respondent No.
Hyderabad - 500001, 26
Phone No: 040-24740240 FAX: 040-
24740592,
E-mail: recp-tsic@telangana.gov.in,

Uttarakhand Information Commission,

RTI Bhawan,
Mussoorie Bypass Ring Road, ……….Respondent No.
Ladpur, Dehradun 248008, India 27
+91 135 2675780
+91 135 2675779
secy-uic@gov.in

U.P. Information Commission ……….Respondent No.

7/7A, RTI Bhawan, 28
Vibhuti Khand, Gomti Nagar
Lucknow, Uttar Pradesh
Office Phone Number : 0522-2724930
E-mail : webmaster.upic@gmail.com
State of Uttar Pradesh through its
Chief Secretary, 1st Floor, Room No.
110, Lal Bahadur Sastri Bhawan, Uttar
Pradesh Secretariat, Lucknow, Uttar
Pradesh – 226001

……….Respondent No. 3
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The State of Uttarakhand through its

Principal Secretary, 4, Subhash Road,
Uttarakhand Secretariat, Dehradun,
Uttarakhand – 248001

……….Respondent No. 4
Central Information Commission
CIC Bhawan, Baba Gang Nath Marg,
Staff Quarters, Old JNU Campus,
Munirka, New Delhi, Delhi 110067

To,

The Hon’ble Chief Justice of India And his

Companion Justices of the Hon’ble Supreme
Court of India

The humble Petition of the Petitioners, above named

MOST RESPECTFULLY SHOWETH:

1. This Petition in the nature of Public Interest Litigation (“PIL”)

under Article 32 of the Constitution of India is for direction to the
State Information Commissions (“SICs”) of the country to hear
the second appeals and complaints arising under Right to
Information Act, 2005 (“RTI Act”) through video conferencing
to ensure unobstructed and time-bound flow of information
without physical presence. Though the RTI Act is a powerful
tool in the hands of Indian citizens, it is weakening as the
travelling of the RTI applicants to attend hearings before the
SICs creates invincible hurdles due to the prohibitive cost,
enormous time and tiring efforts besides loss of working
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days, which are also adjourned many a times. While the

Below Poverty Line (“BPL”) Card-holder-applicant is
exempt from paying RTI application fee and other applicants
are to pay on Rs. 10/- but on denial of such information, the
applicant is to travel several hundred kilometers to attend
hearings before the SIC. According to a Report, 90 per cent
of the applicants who are denied information do not approach
the SICs because of the procedural hassles and other
difficulties.

1(a). The particulars of the petitioner are as below:-

1. Full Name Kishan Chand Jain

2. Complete Postal 22/156, Motilal Nehru Road, Agra-

Address 282004 (UP)

3. e-mail address kishanjain@gmail.com

4. Phone Number 9412263072

5. Proof regarding National Unique Identity Card No. 6826

personal 8180 9290 (copy attached with affidavit)
identification

6. Occupation Lawyer

7. Annual income Rs. 22 lac (approx)

8. PAN Number ABOPJ7746F

9. National unique 6826 8180 9290

identity card
number

1(b). Facts constituting the cause of action:-

The Right to Information Act, 2005, vide its Section 6(1), entitles
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a person to move an application for information through electronic

means, but the Respondents-High Courts have not created online
portal, while framing Rule u/s 28 of the said Act. A similar issue
for creation of online portals by the State Governments of the
country is pending consideration before this Hon’ble Court, being
Writ Petition (Civil) No. 1040 of 2019 (Pravasi Legal Cell v.
Union of India & Ors). The creation of such online portal by the
Respondent Nos. 4 to 28 would greatly help to effectuate the
‘right to information’, being an integral part of the Fundamental
Right to Speech and Expression under Article 19(1)(a) of the
Constitution.

1(c). Nature of injury caused or likely to be caused to the public:-

The ‘right to information’ is an integral part of the Fundamental

Right of Speech and Expression, enshrined in Article 19(1)(a) of
the Constitution of India. At present, no facility of online portal
for filing the RTI applications and appeals has been created by the
Respondent Nos. 4 to 28 (various High Courts). With the result,
the right to information is not able to be effectively exercised due
to the various procedural hassles, which is causing injury to the
public and weakening the Fundamental Right to get unobstructed
and expeditious information from the said Respondents.

1(d). Nature & extent of personal interest, if any, of the

petitioner:-

The petitioner has got no personal interest in this petition. He is

motivated by public interest in filing this petition.

1(e). Details of litigations:-

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That the petitioner is not involved in any civil, criminal or revenue

litigation, which has or could have a legal nexus with the issues
involved in this PIL.

1(f). Whether concerned authority was moved for reliefs sought

for:-

Since the Writ Petition (Civil) No. 1040 of 2019 (Pravasi Legal
Cell v. Union of India & Ors), involving identical issue of creation
of online RTI portal by the State Governments is pending
consideration before this Hon’ble Court, the petitioner has not
moved to the Respondent Nos. 4 to 28 for the relief.

1(g). No personal gain, private motive or oblique reason in PIL:-

This petition is only motivated by public interest. The petitioner

has no personal gain, private motive or oblique reason this filing
in PIL. The affirmation of this fact has also been made in the
accompanying affidavit.

2. The Central Government has already established an online RTI

portal whereby any Indian Citizen including Non-Residential
Indians (“NRIs”) can apply for information under the RTI Act
with the desired Ministry/Department under Central Government.
The Applicant can also pay the requisite fee through online
payment in this portal and submit the RTI application and also
prefer RTI appeal.

3. The Ministry of Personnel, Public Grievances & Pensions

Department of Personnel & Training (“DoPT”) issued a Office
Memo on 08.04.2013 wherein it was stated:-

“A Web Portal namely RTI Online with url https://rtionline.govin

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has been launched. This is a facility for the Indian Citizens to file
RTI applications and first appeals online and also to make
payment of RTI fees online. To begin with, this facility is
available only for Department of Personnel and Training
(DoPT)……..

All the requirements for filing an RTI application and first appeal
as well as other provisions regarding time limit, exemptions etc.,
as provided in the RTI Act, 2005 shall continue to apply.”

A true copy of the Office Memo dated 08.04.2013 is Annexure P-

1 at Pg. Nos 17-18.

4. The DoPT launched its web portal, namely, RTI Online with url
https://rtionline.gov.in to facilitate the Citizens to file their RTI
applications and first appeals online and also to make online
payment of the fee for RTI applications and copies. A true copy of
the Office Memo dated 22.04.2013 is Annexure P-2 at Pg. Nos.
19-20.

5. Thereafter, the RTI Web Portal facility was extended to all the
Ministries/Departments of the Central Government. A true copy of
the Office Memo dated 12.08.2013 is Annexure P-3 at Pg. Nos.
21-22.

6. In a press release issued on 19.12.2018 by the Press Information

Bureau (PIB), it was stated as below:-

“All the States have been requested vide this Department’s

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letter dated 3rd December, 2013 to explore the feasibility of

implementing online RTI in their respective States. National
Informatics Centre (NIC) has been requested to provide
technical support, such as software, and source code to the
State Governments which desire to replicate the web portal
for online filing of RTI applications at state level.

This was stated by the Minister of State in the Ministry of

Personnel, Public Grievances & Pensions and Minister of State
in the Prime Minister’s Office Dr. Jitendra Singh in a written
reply to a question in the Lok Sabha today.”

A true copy of the above release of the PIB dt. 19.12.2018 is

Annexure P-5 at Pg. No. 24.

7. It is humbly submitted that a person seeking information

under the RTI Act from the Public Information Officer
(“PIO”) of any High Court or any Court subordinate thereto,
at present, has to make a physical application and cannot do
so through any electronic means. Also, the applicant is to
obtain a postal order and pay the requisite fee for such an
application or to obtain a bank draft from the bank. Then the
applicant is supposed to send by post or courier the physical
application to the PIO of the concerned High
Court/subordinate court. The provision of an online web
portal will help the Indian citizens including the NRIs by
speedy dissemination of information requested and bringing
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greater transparency in administration.

8. The Respondent no. 1 is the Union of India, represented by

its Secretary, Department of Personnel and Training, Ministry
of Ministry of Personnel, Public Grievances and Pensions
which is the appropriate Ministry dealing with proper
implementation of the Right to Information Act, 2005.

9. That the Respondent No. 2 is the Union of India through its

Secretary, Ministry of Electronics & Information Technology
and Respondent No. 3 is the Union of India through its
Secretary, Ministry of Law & Justice. Both of them have
their important role in creation of online portal of the High
Courts and their subordinate Courts.

10. The Respondent No. 4 to Respondent No. 28 are the

Registrar General of the High Courts of the Country.

11. The petitioner herein is a senior citizen, being 66 years old,

and is practicing law since March 1979. He is a public
spirited person and holds office in numerous social
organizations which are committed to transparency, ethics
and better governance. The petitioner enjoys a sound
reputation in the society. The petitioner earlier also preferred
two writ petitions in this Hon’ble Court, being WP (Civil)
Nos. 40 & 205 of 2016, against the arbitrary fixation of the
application fee by the RTI rules made by the UP Legislative
Assembly and the UP Legislative Council which were
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allowed by this Hon’ble Court vide its order dated

20.03.2018. The Petitioner herein has no personal interest in
the matter as the petition has been solely filed in Public
interest. There is no civil, criminal or revenue litigation
involving the petitioner which would or could have legal
nexus with the issues involved in the public interest litigation.

12. That it may be mentioned that Writ Petition (Civil) No. 1040 of
2019 (Pravasi Legal Cell v. Union of India & Ors) has been
filed in this Hon’ble Court with the following prayer:-

“Pass an appropriate Writ or order or direction to all the State

Governments to establish online RTI portal for the respective
States to enable the citizens to file online applications for
information from any department of the State Governments
under the RTI Act, 2005 ”

A true copy of the above writ petition dated 14.05.2019 is

Annexure P-6 at Pg. No. 25-41.

13. That the above WP (Civil) No. 1040 of 2019 has been
entertained by this Hon’ble Court and the following order has
been passed on 26.08.2019:

“Heard the learned senior counsel for the petitioner. Let notice
be issued in the matter. Dasti service, in addition, is
permitted.”

A true copy of the aforesaid order dated 26.08.2019 is

Annexure P-7 at Pg. No. 42.
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RIGHT TO INFORMATION - A FUNDAMENTAL RIGHT

14. In successive judgments, this Hon’ble Court has held that the
Right to Information is a “fundamental right” and flows
from Article 19(1)(a) (the freedom of speech and expression)
and Article 21 (right to life and liberty) of the Constitution of
India. The Courts of the country have declared in a plethora
of cases that transparency is the key for the functioning of a
healthy democracy. In the matter of State of UP v. Raj Narain,
AIR 1975 SC 865, a constitution bench of this Hon’ble Court
held that:

“[I]n a government of responsibility like ours, where all the

agents of the public must be responsible for their conduct,
there can be but few secrets. The people of this country have
a right to know every public act, everything that is done in a
public way, by their functionaries...The right to know, which
is derived from the concept of freedom of speech, though not
absolute, is a factor which should make one wary, when
secrecy is claimed for transactions which can, at any rate,
have no repercussion on public security. To cover with veil of
secrecy, the common routine business is not in the interest of
public.” (Para 74)

15. In the case of S.P. Gupta v. President of India and Ors, AIR
1982 SC 149, a 7 Judge Bench of this Hon’ble Court made
the following observations regarding the Right to
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Information:

“The concept of an open government is the direct emanation

from the right to know which seems to be implicit in the right of
free speech and expression guaranteed under Article
19(1)(a). Therefore, disclosure of information in regard to the
functioning of Government must be the rule and secrecy an
exception justified only where the strictest requirement of
public interest so demands. The approach of the court must be
to attenuate the area of secrecy as much as possible
consistently with the requirement of public interest, bearing
in mind all the time that disclosure also serves an important
aspect of public interest...”

16. In the case of Reliance Petrochemicals Ltd vs Proprietors of

Indian Express 1989 AIR 190, this Hon’ble court observed:

"34...We must remember that the people at large have a right

to know in order to be able to take part in a participatory
development in the industrial life and democracy. Right to
know is a basic right which citizen of a free country aspire in
the broader horizon of the right to live in this age in our land
under Article 21 of our Constitution. That right has reached
new dimensions and urgency. That right puts greater
responsibility upon those who take upon themselves the
responsibility to inform."
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17. In the case of the Union of India v. Association for

Democratic Reforms, AIR 2002 SC 2002, while declaring that
it is part of the fundamental right of citizens, under Article
19(1)(a) to know the assets and liabilities of candidates
contesting election to Parliament or the State Legislatures,
this Hon’ble Court, held unequivocally that:

“The right to get information in a democracy is recognised

all throughout and is a natural right flowing from the concept
of democracy.” (Para 56)

18. In Reserve Bank of India Versus Jayantilal N. Mistry

Transferred Case (Civil) No. 91 Of 2015, this Hon’ble Court
while upholding peoples’ right to access information, made
the following observations regarding the Right to
Information:

“Because an informed citizen has the capacity to reasoned

action and also to evaluate the actions of the legislature and
executives, which is very important in a participative
democracy and this will serve the nation's interest better
which as stated above also includes its economic interests.
Recognizing the significance of this tool it has not only been
made one of the fundamental rights Under Article 19 of the
Constitution but also a Central Act has been brought into effect
on 12th October 2005 as the Right to Information Act, 2005.”
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...“The ideal of 'Government by the people' makes it

necessary that people have access to information on matters
of public concern. The free flow of information about affairs
of Government paves way for debate in public policy and
fosters accountability in Government. It creates a condition
for 'open governance' which is a foundation of democracy.”

19. The RTI Act provides a practical regime for people to

exercise their fundamental right to information and to access
information from public authorities and its preamble of the
RTI Act states:

“...democracy requires an informed citizenry and

transparency of information which are vital to its functioning
and also to contain corruption and to hold Governments and
their instrumentalities accountable to the governed”

ONLINE RTI PORTAL FOR DISPENSING

INFORMATION EFFECTIVELY

20. A person seeking information under the RTI Act from the
PIO of any High Court or to any Court subordinate thereto, at
present, has to make a physical application and cannot do so
through any electronic means. Also, the applicant will have to
obtain a postal order by visiting the post office and paying the
requisite fee for such an application. Then the applicant is
supposed to send the physical application to the concerned
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department. The provision of an online web portal will only

help the Indian citizens including the NRIs by speedy
dissemination of information requested which in turn would
only help in achieving the aim of the RTI laws of bringing
transparency in administration.

21. The present petition before this Hon’ble Court is thus

preferred for a direction to the Registrar General of the High
Courts and the Courts subordinate thereto to provide the
online RTI portal facility to the citizens so that they can
obtain the information from each public authority through
electronic mode.

GROUNDS
A. BECAUSE for seeking RTI information, an applicant is
exempt from paying any application fee vide S.7(5), proviso,
of the RTI Act, if the applicant is a holder of Below Poverty
Line (“BPL”) Card while other applicants are to pay on the
Rs. 10/- but if such applicants are denied information, they
are to travel several hundred kilometers to appear before the
SICs, which are generally located in the capital towns of the
States.

B. BECAUSE the travelling of the RTI applicants to attend a

hearings before the SICs creates invincible hurdles due to the
prohibitive cost, enormous time and tiring efforts besides loss
of their working days.

C. BECAUSE the hearing before the SICs are adjourned many

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times multiplying the problems for the RTI applicants.

D. BECAUSE faced with the above scenario of prohibitive cost

and other hardships, attached with the travelling, mostly the
RTI applicants are constrained to give up their attempt to
obtain information much against the constitutional mandate
of unobstructed flow of information for vindication of the
fundamental right of Speech and Expression vide Article
19(1)(a) of the Constitution of India.

E. BECAUSE a study report, about 90% of the applicants who

are denied information do not approach the SICs obviously of
the procedural hurdles and other hardships which they are
required to face.

F. BECAUSE while the Central Information Commission

(“CIC”) is conducting its hearings through video
conferencing through the National Informatics Centre
(“NIC”), the SICs are largely legging behind in this much
needed initiative.

G. BECAUSE of the practice of physical hearings of matters by

the SICs, the transparency law has weakened.

H. BECAUSE the procedure of physical hearings should be

replaced by an effective mechanism of video conferencing for
hearings by the SICs.

I. BECAUSE the hearings before the SICs are quite short and
mostly they do not involve complicated questions of law and
facts.

J. BECAUSE S. 19(5) of the RTI Act postulates that “in any

appeal proceedings, the owners to prove that a denial of a
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request was justified shall be on the Central Information

Commissioner or State Information Commissioner, as the
case may be, who denied the request”, which shows that a
role of the applicant before the SICs is rather minimal.

K. BECAUSE it looks enolomous that a BPL card holder should

travel hundreds of kilometers for hearing of his matters, while
the legislature exempted him from even paying the
application fee.

L. BECAUSE the legislative desire is that the information

should be provided at most reasonable expense and,
therefore, the procedure that entails prohibitive cost of
repeated travelling to SICs should be discontinued.

M. BECAUSE the hearings before the SICs are adjourned on

numerous occasions, multiplying hardships of the applicants

N. BECAUSE the RTI Act provides a legal mechanism to

enforce the citizen’s right to information, guaranteed under
Article 19(1)(a) and Article 21 of the Constitution of India
and the procedure which damages such fundamental right
should be discontinued.

O. BECASUSE the hearing through video conferencing has

been proven to be most convenient, cost-efficient and
transparent way of governance.

P. BECAUSE the present system of the physical hearings by

SICs defeats the letter and spirit of the transparency law.

Q. BECAUSE of the conventional method of physical hearings

by SICs needs to be done away with.
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R. BECAUSE the SICs and the State Governments are

statutorily bound to innovate such methods which make the
access to information most convenient and, per contra, it
violates the fundamental right to information.

S. BECAUSE the Petitioner has not filed any other petition for
similar or same reliefs before any Court, including this
Hon’ble court.

T. BECAUSE this Hon’ble Court has adequate territorial

jurisdiction to issue directions, orders and writs given the
cause of action in whole and in part arising within the
territories in which it exercise jurisdiction.

U. Because it would be befitting in the facts and circumstances

that an appropriate writ or order or direction to the SICs to
hear second appeals and complaints under the RTI Act
through video conferencing to ensure unobstructed and time-
bound flow of information without physical presence of the
appellants/complainants before them.

V. The use of technology is most convenient, economic, speedy

and transparent and takes our systems to next level.

W. Because two PILs, being Writ Petition (Civil) Nos. 1040 of

2019 and 1325 of 2020 are pending consideration before this
Hon’ble Court, which involve the issue for the establishment
of online RTI portals by the State Governments and it would
be expedient in the interest of justice to tag and hear this
matter along with the above writ petitions.

X. BECAUSE the Petitioner has no other equally efficacious

alternative remedy and therefore, the petitioner is
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approaching this Hon’ble Court by filing the present petition.

Any other grounds that may be urged at the time of hearing
with the permission of the Hon’ble Court.

22. That the present petitioner has not filed any other petition in
any High Court or the Supreme Court of India on the subject
matter of the present petition.

PRAYER

In view of the facts and circumstances of the case, it is most

respectfully prayed that this Hon’ble Court may be pleased to:

i) Pass an appropriate writ or order or direction to the State

Information Commissions (Respondent Nos. 3 to ……) to
hear second appeals and complaints under the RTI Act
through video conferencing to ensure unobstructed and time-
bound flow of information without physical presence of the
appellants/complainants before the State Information
Commissions;

ii) Pass an appropriate writ or order for directions to the State

Governments (Respondent Nos…… to…..) to financially and
technically support there respective State Information
Commissions for the establishment of proper video
conferencing facility and its functioning;

iii) Pass an appropriate writ or order or direction to the

Government of India through its Secretary, Ministry of
Personnel, PG and Pensions, New Delhi, to monitor, guide
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and support the State Governments in establishment of video

conferencing facility and functioning in the State Information
Commissions;

iv) Pass an appropriate writ or order or direction to the State

Information Commissions (Respondent Nos……to……..) to
ensure disposal of second appeals and complaints filed before
them within a period of………days from the date of filing of
such matter;

v) Any other suitable order/s as this Hon’ble Court may deem fit
and necessary in light of the facts and circumstances of the
case and in the interest of justice.

Filed by

(E.C. Agrawala)
Counsel for the Petitioner
48, Lawyers’ Chambers
Supreme Court of India
New Delhi-110 201

Place: New Delhi

Dated: ________________
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IN THE SUPREME COURT OF INDIA

CIVIL ORIGINAL JURISDICTION
(PUBLIC INTEREST LITIGATION PETITION)
CIVIL WRIT PETITION NO. OF 2020
(UNDER ARTICLE 32 OF THE CONSTITUTION OF INDIA)
IN THE MATTER OF:
Kishan Chand Jain
…………Petitioner
AND
Union of India & Ors.
…………Respondents
AFFIDAVIT
I, Kishan Chand Jain S/o Late Shri Kailash Chand Jain R/o 22/156,
Motilal Nehru Road, Agra-282 004 (U.P.), presently at Delhi, do
hereby solemnly affirm and state on oath as under:
1. That I am the petitioner in the aforementioned writ petition and
being familiar with the facts and circumstances of the case, I am
competent and authorized to swear this Affidavit.
2. That I have read and understood the contents of the Synopsis and
List of Dates (Page B to H), Writ Petition (Page 1 to 16). I state
that the facts therein are true to the best of my knowledge and
nothing material has been concealed therefrom. The annexure
Nos. 1 to 7 of the writ petition are true copies of their respective
original.
3. That this petition is only motivated by public interest. I affirm
that I have no personal interest in this matter.
4. That I have done whatsoever enquiry that was possible and I
state that no relevant facts in my knowledge have been withheld.

DEPONENT
VERIFICATION:
I, the above named Deponent, do hereby verify that the contents of the
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above Affidavit are true and correct to my knowledge, no part of it is

false and nothing material has been concealed therefrom.
Verified at New Delhi on this ____ day of November, 2020.

DEPONENT