IN THE HIGH COURT OF DELHI CIVIL ORIGINAL JURISDICTION

CONTEMPT PETITION (C) NO. ___________OF 2023

IN
Writ Petition (Civil) No._____ 0f 2023

IN THE MATTER OF:

GURUGRAM GARMIN BANK WORKERS ORGANIZATION & ANR

…PETITIONER

VERSUS

PRASAR BHARTI BROADCASTING CORPORATION OF INDIA & ORS

…RESPONDENTS

URGENT APPLICATION
TO,
THE REGISTRAR,
OF THE HIGH COURT OF DELHI,
AT NEW DELHI

Sir,
Kindly treat the accompanying writ petition as urgent on as per the Delhi
High Court Rules. It is most humbly prayed that an urgent hearing be
given on
Through Counsel
 Ganesh Chand Sharma
ADVOCATE FOR THE PETITIONER
RIDDHI LEGAL CONSULTANTS
1517 II FLOOR 21D
NIT FARIDABAD
M: 896 0896 896
DATE: 2023
IN THE HIGH COURT OF DELHI CIVIL ORIGINAL JURISDICTION
CONTEMPT PETITION (C) NO. ___________OF 2023
IN
Writ Petition (Civil) No._____ 0f 2023

MEMO OF PARTEIS

GURUGRAM GARMIN BANK WORKERS ORGANIZATION

THROUGH CHIEF COORDINATOR/ AUTHORISED
REPRESENTATIVE MUKESH KUMAR JOSHI, S/O LATE SH. N.P.
JOSHI R/O FLAT NO. 206, SHIVALIK APARTMENT, GH-12,
SECTOR-46, FARIDABAD, HARYANA-121010
…PETITIONER
VERSUS

1. PRASAR BHARTI (BROADCASTING CORPORATION OF INDIA

THROUGH AUTHORISED REPRESENTATIVE CIVIL
CONSTRUCTION WING ALL INDIA RADIO. 6TH
FLOOR SOOCHNA BHAWAN
CGO COMPLEX LODHI ROAD NEW DELHI-110003
EMAIL: RAJEEVSHARMALEGAL@HOTMAIL.COM
RESPONDENT NO.1

2. MR Gaurav Dwivedi
CEO of PRASAR BHARATI
Secretariat Prasar Bharati House,
Copernicu Marg, New Delhi – 110001
 Email- ceo@prasarbharati.gov.in ,official no- +91-11-23118803
RESPONDENT NO.2

3. Shri D.P.S. Negi, Member Of PRASAR BHARTI

Secretariat Prasar Bharati House,
Copernicu Marg, New Delhi – 110001
Off. Tel.: +91-11-23118808
Email: dpsnegi@prasarbharati.gov.in
RESPONDENT NO.3
4. Ms. Neerja Sekhar,
Nominated Member Prasar Bharati Board
Secretariat Prasar Bharati House,
Copernicu Marg, New Delhi – 110001
Off. Tel:+91-11-23387558
Asmib.inb@nic.in
RESPONDENT NO.4
5. Shri Alok Agrawal,
Part Time Member
Prasar Bharati Board
Secretariat Prasar Bharati House,
Copernicu Marg, New Delhi – 110001
Email: alok.agrawal17@gmail.com
RESPONDENT NO.5
6. Shri Ashok Kumar Tandon
Part Time Member,
Prasar Bharati Board
Secretariat Prasar Bharati House,
Copernicu Marg, New Delhi – 110001
 RESPONDENT NO.6

7. Shri Sanjay Gupta,

Part Time Member,
Prasar Bharati Board
Secretariat Prasar Bharati House,
Copernicu Marg, New Delhi – 110001
RESPONDENT NO.7
8. Ms. Shaina NC
Part Time Member,
Prasar Bharati Board
Secretariat Prasar Bharati House,
Copernicu Marg, New Delhi – 110001
RESPONDENT NO.8
9. Ms. Vasudha Gupta,
DG AIR,
Prasar Bharati Board
Secretariat Prasar Bharati House,
Copernicu Marg, New Delhi – 110001
Email: dgair@air.org.in
Off. Tel.:+91-11-23421300/ 23421061
RESPONDENT NO.9

Through Counsel
GANESH CHAND SHARMA
ADVOCATE FOR THE PETITIONER
PUNJAB AND HARYANA HIGH COURT
1517 II floor 21D, NIT FARIDABAD
M: 896 0896 896
 Date:
IN THE HIGH COURT OF DELHI CIVIL ORIGINAL JURISDICTION
CONTEMPT PETITION (C) NO. ___________OF 2023
IN
Writ Petition (Civil) No._____ 0f 2023

IN THE MATTER OF

GURUGRAM GARMIN BANK WORKERS ORGANIZATION & ANR

…PETITIONER

VERSUS

PRASAR BHARTI BROADCASTING CORPORATION OF INDIA & ORS

…RESPONDENTS

NOTICE OF MOTION
To,
Standing Counsel,
Union Of India, Chamber Nos.
Delhi High Court

Please note that the above matter will be listed on___________2023

before the Hon’ble High Court of Delhi. It is, therefore, requested you to
please enter your appearance on the said date.

PETITIONER

THROUGH COUNSEL
GANESH CHAND SHARMA
 ADVOCATE FOR THE PETITIONER
RIDDHI LEGAL CONSULTANTS
1517 II floor 21D,
NIT FARIDABAD
896 0896 896
DATE:

IN THE HIGH COURT OF DELHI CIVIL ORIGINAL JURISDICTION

 CONTEMPT PETITION (C) NO. ___________OF 2023
IN
Writ Petition (Civil) No._____ 0f 2023

IN THE MATTER OF:

GURUGRAM GARMIN BANK WORKERS ORGANIZATION & ANR

…PETITIONER

VERSUS

PRASAR BHARTI BROADCASTING CORPORATION OF INDIA & ORS

…RESPONDENTS

CONTEMPT PETITION ON BEHALF OF THE PETITIONER U/S 11

and 12 OF THE CONTEMPT OF COURTS ACT, 1971 FOR INITIATING
CONTEMPT PROCEEDINGS AGAINST THE ABOVE-NAMED
ALLEGED CONTEMNORS FOR NON-COMPLIANCE OF THE
JUDGMENT/ ORDER DATED 01.05.2023 OF THIS HON’BLE COURT
IN W.P.(C) 5551/2023 & CM APPL. 22070/2023

To,
The Hon’ble Chief Justice of the

High Court of Delhi and His

Companion Judges of the

Hon’ble High Court of Delhi.

Humble Petition of the Petitioner above named:

MOST RESPECTFULLY SHEWETH:-
1. Petitioner above named is filing the instant contempt petition seeking
initiation of contempt proceedings against the above named alleged
contemnors for wilfully disobeying the specific directions of this Hon’ble
Court issued vide order dated 01.05.2023, in W.P.(C) 5551/2023 captioned
as “GURUGRAM GARMIN BANK WORKERS ORGANIZATION &
ANR VS PRASAR BHARTI BROADCASTING CORPORATION OF
INDIA & ORS” wherein this Hon’ble Court directed “that considering
that the Respondent No. 1 is a statutory corporation, the Chairperson of
Prasar Bharti Broadcasting Corporation of India shall look into the
allegations in this petition and take a decision on the same. The said
decision shall also be brought to the notice of the Prasar Bharti Board.
The said decision shall be communicated to the Petitioners within three
months.”
2. That the petitioner many time contacted the respondent office but the

respondent is not willing to discuss the concern of the petitioner and

willfully flouted the direction of this Hon’ble court

3. Since, there has been wilful disobedience on the part of the respondent in

compliance with the order dated 01.05.2023 passed by this Hon’ble Court

in WPC respondent is liable for contempt of the court and contempt

proceedings should be initiated against the respondent

4. That this is the first contempt petitioner of the petitioner.

5. That the petitioner has not filed any petition in the subject matter before

Hon’ble Supreme Court of India

6. The petitioner has no better remedy available.

PRAYERS

In the premises, the petitioner most humbly prays that the Hon’ble Court

may graciously be pleased to pass the following orders:

a) Initiate contempt proceeding against the alleged contemnors i.e

respondent for willfully and deliberately disobeying the order-

dated 01.05.2023 passed by this Hon’ble Court in WPC

5551 / 2023

b) Direct the respondent to comply the order dated 01.05.2023 passed

by this Hon’ble Court in WPC 5551 / 2023

c) Exemption from filing the certified copies of the documents

annexed with the petition.

d) Any Such further and/or other order or order be passed, direction

or directions be given, as the Hon’ble Court may deem fit and

proper in respect of the facts and circumstances of the present case.

Petitioner
DATE
PLACE: DELHI
 THROUGH COUNSEL

GANESH CHAND SHARMA

ADVOCATE FOR THE PETITIONER
RIDDHI LEGAL CONSULTANTS
1517 II floor 21D
NIT, FARIDABAD,
HARYANA 121001

IN THE HIGH COURT OF DELHI CIVIL ORIGINAL JURISDICTION

CONTEMPT PETITION (C) NO. ___________OF 2023
IN
 Writ Petition (Civil) No._____ 0f 2023

IN THE MATTER OF:

GURUGRAM GARMIN BANK WORKERS ORGANIZATION & ANR

…PETITIONER

VERSUS

PRASAR BHARTI BROADCASTING CORPORATION OF INDIA & ORS

…RESPONDENTS

AFFIDAVIT IN SUPPORT

I, GURUGRAM GARMIN BANK WORKERS ORGANIZATION

THROUGH CHIEF COORDINATOR/ AUTHORISED
REPRESENTATIVE MUKESH KUMAR JOSHI, S/O LATE SH.
N.P. JOSHI R/O FLAT NO. 206, SHIVALIK APARTMENT, GH-12,
SECTOR-46, FARIDABAD, HARYANA-121010 PRESENTLY AT
HIGH COURT OF DELHI, NEW DELHI DO HEREBY
SOLEMNLY DECLARE AND AFFIRM ON OATH AS
HEREUNDER

1. I say and submit that I am the Applicant / Petitioner in the aforesaid

application and in that capacity I am able and competent to depose
the present Affidavit.
2. I say and submit that above application has been drafted under the
instruction and at the instance of the petitioner the facts stated
 therein are true and correct. No part of it is false and material has
been concealed there from. The same may be read as part and
parcel of this affidavit being not repeated herein for the sake of
brevity.
3. I say and submit that I have not filed any petition before any court
with regard to subject matter of the petition
4. I say and submit that I am well conversant to the facts of the present
Case and the same are true and correct to my personal knowledge
and belief.
5. I say and submit that the affidavit has been read over to me in my
vernacular and is clearly understood to me.

DEPONENT
Date:
Place: NEW DELHI

VERIFICATION
I, the Deponent above named do hereby verify that the contents of
my above affidavit are true and correct to my knowledge, no part of
it is false and nothing material has been concealed therefrom.
Verified on this day of , 2023 at Delhi.
DEPONENT
DATE:
PALCE: DELHI
IN THE HIGH COURT OF DELHI CIVIL ORIGINAL JURISDICTION
CONTEMPT PETITION (C) NO. ___________OF 2023
IN
Writ Petition (Civil) No._____ 0f 2023
IN THE MATTER OF:

GURUGRAM GARMIN BANK WORKERS ORGANIZATION & ANR

…PETITIONER

VERSUS

PRASAR BHARTI BROADCASTING CORPORATION OF INDIA & ORS

…RESPONDENTS

UNDER SECTION 151 OF THE CODE OF CIVIL PROCEDURE 1908,

SEEKING EXEMPTION FROM FILING THE CERTIFIED COPIES OF
THE DCOUMENTS IN THE PRESENT PETITION

The petitioner / Applicant most respectfully states and submits as hereinunder:

1. That the petitioner / Applicant is being filing the accompanying

contempt petition for initiating contempt proceedings against the
contemnors
2. That the detailed facts and circumstances leading to the filing of the
petition and the grounds in support of your Petitioner’s challenge are set
out in detail inter alia captioned petition. For the sake of brevity and to
avoid repetition, the said facts, submissions and grounds are neither
being repeated nor dilated upon herein. The petitioner however carves
the leave of this Hon’ble Court to refer to and rely upon the said facts
and submissions as if the same have been fully incorporated herein and
from the part of the present application.
 3. That the documents annexed with the petition are true copy/carbon
copy/photocopy of their representative originals and due to paucity of
time.

4. The petitioner /Applicants submits that each and every ground

mentioned in petition by the petitioner and contained to establish their
case, are specifically substantiated with the adequate evidence, however
petitioner carve leave to refer any other and or further evidence at
different stages of the proceedings in order to prove their case.

5. That the documents annexed with the petition are true copy / carbon
copy / photocopy of their respective originals and the petitioner
undertake to file the certified copy of the same as and when required by
this Hon’ble Court on the later stage.

PRAYER
Wherefore, in the light of facts and circumstances stated herein above , it is most
humbly prayed that this Hon’ble Court may graciously be pleased to :

A. allow the present application of the petitioner; and

B. exempt the petitioners to file the certified copies and permit to file the
fair and typed copies of the Annexures
C. Pass any such other and further orders as this Hon’ble Court may deem
fit and proper in the facts and circumstances of this case.

And For This Act of Kindness The Petitioner As In Duty Bound Shall
Every Pray
PALCE
DATE
……..PETITIONER

THROUGH COUNSEL

GANESH CHAND SHARMA

ADVOCATE FOR THE PETITIONER
RIDDHI LEGAL CONSULTANTS
1517 II floor 21D
NIT, FARIDABAD,
HARYANA 121001

IN THE HIGH COURT OF DELHI CIVIL ORIGINAL JURISDICTION

CONTEMPT PETITION (C) NO. ___________OF 2023
IN
Writ Petition (Civil) No._____ 0f 2023
IN THE MATTER OF:

GURUGRAM GARMIN BANK WORKERS ORGANIZATION & ANR

…PETITIONER

VERSUS

PRASAR BHARTI BROADCASTING CORPORATION OF INDIA & ORS

…RESPONDENTS

AFFIDAVIT IN SUPPORT

I, GURUGRAM GARMIN BANK WORKERS ORGANIZATION

THROUGH CHIEF COORDINATOR/ AUTHORISED
REPRESENTATIVE MUKESH KUMAR JOSHI, S/O LATE SH. N.P.
JOSHI R/O FLAT NO. 206, SHIVALIK APARTMENT, GH-12, SECTOR-
46, FARIDABAD, HARYANA-121010 PRESENTLY AT HIGH COURT
OF DELHI, NEW DELHI DO HEREBY SOLEMNLY DECLARE AND
AFFIRM ON OATH AS HEREUNDER

1. I say and submit that I am the Applicant / Petitioner in the aforesaid

application and in that capacity I am able and competent to depose the
present Affidavit.
2. I say and submit that above application has been drafted under the
instruction and at the instance of the petitioner the facts stated therein
are true and correct. No part of it is false and material has been
concealed there from. The same may be read as part and parcel of this
affidavit being not repeated herein for the sake of brevity.
 3. I say and submit that I have not filed any petition before any court with
regard to subject matter of the petition
4. I say and submit that I am well conversant to the facts of the present
Case and the same are true and correct to my personal knowledge and
belief.
5. I say and submit that the affidavit has been read over to me in my
vernacular and is clearly understood to me.

DEPONENT
Date:
Place: NEW DELHI

VERIFICATION
I, the Deponent above named do hereby verify that the contents of my above
affidavit are true and correct to my knowledge, no part of it is false and nothing
material has been concealed therefrom. Verified on this day of , 2023
at Delhi

DEPONENT

IN THE HIGH COURT OF DELHI CIVIL ORIGINAL JURISDICTION

CONTEMPT PETITION (C) NO. ___________OF 2023
IN
Writ Petition (Civil) No._____ 0f 2023

IN THE MATTER OF:

GURUGRAM GARMIN BANK WORKERS ORGANIZATION & ANR
…PETITIONER
VERSUS
PRASAR BHARTI BROADCASTING CORPORATION OF INDIA & ORS
…RESPONDENTS

TOTAL AMOUNT OF COURT FEE AFFIXED

Date
Place: DELHI
……..PETITIONER

THROUGH COUNSEL

GANESH CHAND SHARMA

ADVOCATE FOR THE PETITIONER
RIDDHI LEGAL CONSULTANTS
1517 II floor 21D
NIT, FARIDABAD,