IN THE HIGH COURT OF JUDICATURE FOR THE STATES OF
PUNJAB AND HARYANA AT CHANDIGARH
In CIVIL WRIT PETITION NO. 14133 OF 1998

Sudershan Goel        …        …..      ….       …..      …..      Petitioner

                                                Versus

The Union of India & Others           ………….                    Respondents

LIST OF EVENTS

 Hence this writ petition seeking a direction to the respondents 1 and 2 to restrain the Commission - Respondent No. 3 to hold its scheduled sittings at Ludhiana from October 23 to 25, 1998.

CHANDIGARH                                         (M.L. PURI & S.C. GUPTA)

                                                                             ADVOCATES

SEPTEMBER 3, 1998                               COUNSEL FOR THE PETITIONER

 IN THE HIGH COURT OF JUDICATURE FOR THE STATES OF

PUNJAB AND HARYANA AT CHANDIGARH

                   CIVIL WRIT PETITION NO. 11433 OF 1998

Sudershan Goel, Advocate, Punjab and Haryana High Court, resident of 731,

Sector 11-B, Chandigarh.

                                                          ………… …..     Petitioner

Versus

1.   The Union of India through Secretary to Government, Department of Home, ministry of Home Affairs, Government of India, North Block, New Delhi.

2.   The State of Punjab through Secretary to Government, Department of Home, Punjab civil Sectt., Chandigarh.

3.   The People's Commission, through its Chairman, Mr. Justice D.S. Tewatia, former Chief Justice, Punjab and Haryana High Court, resident of 27/15, Qutab Enclave Phase I, Gurgaon (Haryana).

4.   The Tribune, Chandigarh, through its General Manager

……….  ……….. ………   Respondents           

'PUBLIC INTEREST LITIGATION'

PETITION under Article 226 of the Constitution of India for issuance of a writ of Mandamus to the respondents - No. 1 and 2 for taking approperiate action against the respondent No. 3 by prohibiting it from carrying on its avowed objects; and for prohibiting the holding of its scheduled sittings at Ludhiana on October 23 to 25, 1998; or for any other appropriate writ, order or direction as may be deemed fit and proper by this Hon'ble Court on the facts and in the circumstances of the case.

Respectfully showeth:

1.  That the petitioner is a citizen of India and is a member of the Punjab and Haryana High Court Bar Association since 1979. The petitioner is an income tax payee since 1977 and is entitled to invoke the extra ordinary writ jurisdiction of this Hon'ble Court being a rate payer. The present writ petition is being filed by petitioner in large public interest. The petitioner is not in any manner personally interested in the relief being claimed herein. However, the petitioner represent the

sentiments of millions of citizens of India, inter-alia, people living in the State of Punjab and surrounding areas who are interested to see that the majesty of law is upheld and the administration of justice is not tampered with or interfered with in any manner by any other judicial process except that provided in accordance with the Constitution of India. Therefore, this 'Public Interest Litigation' is maintainable.

2.  That respondents 1 and 2 are duty bound to maintain law and order and to ensure administration of justice in accordance with the judicial process as laid down in the Constitution of India. By way of this writ petition the petitioner seeks to challenge the inaction of the respondents 1 and 2 in not taking note of the activities of Respondent No. 3 thereby causing a feeling of loss of governance in the minds of the people and creating lawlessness in the country which may jeopardize the sovereignty and integrity of India. The petitioner seeks a direction from this Hon'ble Court Mandamusing the respondents 1 and 2 to fulfill their constitutional obligations by preventing any person, more particularly the respondent No. 3, from subverting the judicial process.

3.  That since the matter is of extreme urgency and since the Respondents 1 and 2 are fully aware of the subject matter but has chosen to sit and watch like spectators and since the inaction on their part is so grave leading to manifest injustice to the millions of unorganized members of society, no advance notice has been given for seeking relief being claimed herein. The petitioner craves indulgence of this Hon'ble Court by exempting advance notices to the respondents 1 and 2 for the relief being claimed herein.

4.  That as per news report a commission under the name and style of 'Peoples' Commission on Human Rights Violations in Punjab' (hereinafter to be referred to as the 'Commission') has been set up under the Chairmanship of Mr. Justice D.S. TEWATIA, former Chief Justice of Punjab and Haryana High Court. The other members of this Commission are also retired High Court Judges. A news item appeared in 'The Tribune' of August 9, 1998 disclosing that 'a people's commission on human rights violations in Punjab began its three day "court" in the convention hall of the Gurdwara in Sector 34 here. This commission has been set up by 20-odd organizations and political outfits engaged in work related to the preservation and protection of civil liberties and human rights. Earlier, these organizations had decided to form an "umbrella" in the name of the Committee for Coordination on Disappearances in Punjab."

5.  That as per the said news item, the commission comprises Justice D.S. Tewatia (a former Chief Justice of the Calcutta High Court) Chairman; with Justice H. Suresh (a retired Judge of Maharashtra High Court) and Justice Jaspal Singh (a former Judge of the Delhi High Court) as members.

6.  That the reasons for formation of this commission have been given in the said news item in these words, "this commission, as Justice Kuldip Singh told TNS, would not, perhaps been formed had the Punjab Government responded in a positive manner to the suggestion of the committee on disappearances to set up "a truth commission" to investigate "genesis" of the Punjab problem. The SAD-BJP Government, however, responded by saying that let the past be "buried and forgotten", he added. Despite a lapse of over six months with no tangible response received from the Government, the committee decided to set up the people's commission."

7.  That the terms of reference of the said Commission, as disclosed in the said news item, are as under:

"The Commission will examine the complaints of illegal abductions, custodial torture, enforced disappearances, summary executions and en masse illegal cremations and to give its findings on:

"(1)  Whether from 1979 to 1997 the agencies of the State carried out and tolerated, directly or indirectly, any of the above atrocities and, thereby committed violation of human rights as guaranteed under the Constitution and various international covenants and declarations;

"(2)  Whether the State agencies, individuals have prima facie committed any offence under the law of the land or international law;

"(3)  The Commission will further suggest the remedies available to the victims of the atrocities, including their entitlement to compensation from the State and its agencies."

8.  That according to Article 5 (2) of the rules framed by the commission, it can enquire into the conduct of persons who have already been tried by a court of law if it can be established 'that the court proceedings were not impartial or independent and were designed to shield the accused from criminal responsibility or the case was not diligently prosecuted'.

9.  That to achieve the said object reproduced above, the commission has issued summons to many police officers calling upon them to answer the charges leveled against them and to defend themselves before the Commission.

10. That the said commission issued public notices in various news papers inviting complaints of atrocities by police officials of Punjab during the period when terrorism prevailed in the State of Punjab.

11. That the commission held its sittings at Chandigarh on August 8, 9 and 10. The first sitting was held on August 8 at Gurdwara in Sector 34, Chandigarh. The next sitting of the Commission is scheduled to be held at Ludhiana from October 23 to 25, 1998.

12. That as per the Constitution of India, the administration of justice in the country is to be governed in accordance with the provisions made for the Union Judiciary and the State Judiciary. Article 124 of the Constitution of India provides that, 'there shall be a Supreme Court of India …..' Similarly Article 214 of the Constitution provides that 'there shall be a High Court for each State'. Thus there is judicial hierarchy constituted by the Constitution of India. The District Judiciary judgments and decisions are appealable to the High Court which has the territorial jurisdiction over District Courts. The High Courts have jurisdiction of superintendence of all courts under their territorial jurisdiction as per Article 227 of the Constitution of India. Similarly, the Supreme Court has jurisdiction throughout the country over all judicial and quasi judicial authorities as per Articles 132 to 142 of the Constitution.

13. That both the High Courts as well as the Supreme Court are the Court of Records and have the power to make law by way of judicial pronouncements.

14. That by sitting over judgments passed by Courts of competent jurisdiction in cases of alleged atrocities during the period of militancy, as per Article 5 (2) of the rules framed by the Commission, an attempt is being made to set up a parallel judicial system which may have the result of subverting the judicial process of the country as well as causing a serious threat to the survival of the Republic of India.

15. That functioning of the Commission to carry out its avowed objects shall bring the system of administration of justice in the country into disrepute and will amount to interference in the administration of justice.

16. That the respondents No. 1 and 2 are silently watching the activities of the Commission and have not prevented the respondent No. 3 from subverting judicial process by its inaction.

17. That the Commission has 'no authority of law' to issue any summons or to adjudicate complaint of any person. The 'judgment' by the Commission is not enforceable in any court of law. The 'findings' that may be recorded by the commission are likely to be used more for the purposes of publicity than for providing any relief to any person.

18. That the State of Punjab had remained a terrorist affected area for more than a decade. During the said period there had been reports of large scale atrocities on the people by the terrorist as also by the Government officials, including officials belonging to the forces. But in specific complaints actions have been taken against the officials. Even this Hon'ble Court had in a large number of cases directed registration of cases against the erring officials and investigations are going on. The action is required to be taken and is being taken in accordance with procedure established by law. Any other mode, particularly the one adopted by the Commission, which does not have the sanctity of law, shall have the effect of interfering in the administration of justice and subverting the due process of law which is not permissible either in law or in equity or as a matter of public policy.

19. That actions of the Commission in summoning the police officials and other State officials and in holding them guilty without following procedure established by law shall have the effect of demoralization not only amongst such officials but also amongst the society at large. If the police officials, who by risking their lives, curbed militancy and restored normalcy in the State, are demoralized by the actions of the Commission, then in case militancy is revived in the State, the police force will not be in a position to combat and control that situation. In this respect it is submitted that the Director General Police of Punjab has often said in Press Statements that chances of revival of militancy in Punjab cannot be ruled out.

20. That even members of the Council of Ministers of Punjab have demanded action against the Commission. As per reports appeared in news papers even Mr. Balramji Dass Tandon, Minister, Punjab, has demanded action against the Commission. Mr. Tandon is reported to have said that the Commission was not a legal body and therefore no official would be appearing before it.

21. That even the Advocate-General of Punjab State, Shri G.S. Grewal, Senior Advocate, Punjab and Haryana High Court, in his letter to editor, published in The Tribune of 29.8.1998 has condemned the setting up of the Commission - Respondent No. 3. An extract from this letter is reproduced below for the facility of ready reference:

"………… The only effect of the so called people's commission would be to paint some police officers black in the public eye. The Commission has no financial resources to pay compensation in any genuine case. Ultimately the cases will have to go to courts. Instead of holding private trial and projecting the police officers criminals before the public, it would have been more in accordance with the judicial norm, if Justice Kuldip Singh had organized a team of Lawyers to scrutinize the facts of each allegation and file petitions for compensation direct in the relevant court. To hold a public trial before the cases are sent to the court is objectionable from legal, moral, and political point of view. The Commission has issued summons to the police officers to defend themselves before it. Does the Commission have such powers under law? The only sanction behind the Commission is its capacity to black mail the officers who under law cannot appear before the Commission. Judges can exercise only those powers which are vested in them by law. Do retired Judges have more powers? If today such private courts are permitted to function, tomorrow we will have private High Court and private Supreme Court. Does the concept of equality and freedom in our Constitution mean this? ……."

22. That the Communist party of India, in a statement released to the press which was published in the Indian Express of 3.9.1998, has condemned the working of respondent No. 3 and has demanded a ban on its working.

23. That from the facts narrated above it is clear that even Constitutional functionaries of the State like its Ministers and Advocate-General are against the working of respondent No. 3 but had been helpless because of inaction of respondents 1 and 2.

24. That inaction of the Respondents 1 and 2 is not in the interest of the general public of Punjab and India nor in the interest of law and order of the State. The public interest petition filed by the petitioner as an individual in his representative capacity is therefore maintainable.   

25. That question of law involved in the present writ petition is as to whether an extra constitutional body like the commission (Respondent No. 3) is entitled to bye pass the judicial process and the system of administration of justice as enshrined in the Constitution of India?

26. That the petitioner is left with no other equally efficacious and speedy remedy except to approach this Hon'ble Court by way of the present writ petition.

27. That no such or similar writ petition has earlier been filed by this petitioner either before this Hon'ble Court or in the Hon'ble Supreme Court of India.

It is, therefore, most humbly and respectfully prayed that this Hon'ble Court may very kindly be pleased to:

(a) direct the Respondents No.1 and 2 to take appropriate legal action against the respondent No. 3 restraining the Commission to carrying out its avowed objects;

(b) issue an ad interim injunction to respondent No. 3 not to hold the scheduled sittings of People's Commission on October 23 to 25 at Ludhiana or on any other date during the pendency of this writ petition.

(c) Issue any other appropriate writ, order or direction as may be deemed fit and proper by this Hon'ble Court on the facts and in the circumstances of the case;

(d) Dispense with the requirement of serving advance notices upon the respondents;

CHANDIGARH                                                  SUDERSHAN GOEL

SEPTEMBER 3, 1998                                                  PETITIONER

                                      THROUGH

                                                                   (M.L. PURI & S.C. GUPTA)

                                                          ADVOCATES FOR THE PETITIONER

VERIFICATION:

Verified that the contents of paras 1 to 3 and 27 of the petition are true and correct to my knowledge and of paras 4 to 23 of the said petition are true and correct to my knowledge based on news reports which are believed to be correct. Contents of paras 24 to 26 are based on legal advice which is believed to be correct. No part of it is false and nothing material has been kept concealed.

CHANDIGARH                                                  SUDERSHAN GOEL

SEPTEMBER 3, 1998                                                  PETITIONER

ADDITIONAL SUBMISSIONS

IN THE HIGH COURT OF JUDICATURE FOR THE STATES OF

PUNJAB AND HARYANA AT CHANDIGARH

                   In CIVIL WRIT PETITION NO. 11433 OF 1998

Sudershan Goel        …        …..      ….       …..      …..      Petitioner

                                                Versus

The Union of India & Others           ………….                    Respondents

          Additional submissions/replication on behalf of the writ petitioner by way of affidavit of Sudershan Goel son of Shri R.R. Goel, resident of 731, Sector 11-B, Chandigarh.

I, the above named deponent, do hereby solemnly declare and affirm as under:-

1.  That the deponent has perused the affidavit filed by Shri Ram Narayan Kumar, Convener, 'Committee for Coordination on Disappearances in Punjab (hereinafter called the CCDP)'; and the affidavit of Shri Surjit Singh Sood; who have been allowed as interveners in the aforesaid writ petition. The deponent most respectfully submits that the contents of these affidavits, except to the extent of specifically admitted herein, are denied being wrong and incorrect. No averment in the affidavit filed by Mr. R.N. Kumar of CCDP has been verified on the basis of his knowledge and therefore the affidavit is not admissible being not properly verified.

2.  That the contents of paras (x) and (xi) of the affidavit filed by Mr. Surjit Singh Sood are vehemently denied. It is denied that the petition has been filed for mala fide political reasons. It is denied that the petitioner has no experience of working in the field of human rights.

3.  That the writ petitioner is entitled to maintain the present writ petition as a 'pro bono publico' on the basis of the following facts:

(i) The writ petitioner is a citizen of India holding a valid Voters' Identity Card issued by Chief Electrol Officer, Chandigarh; and a valid Passport issued by the Regional Passport Officer, Chandigarh;

(ii)  The writ petitioner is a tax payer and is assessed to Income Tax since 1977.

(iii) The writ petitioner is involved in the arena of social activities, in larger public interest, right from his student days. The petitioner has the privilege of working in close association with late Sri Lok Nayak Jai Parkash Narayan (hereinafter called as 'JP') and had himself been a human rights activist. The petitioner was actively involved in the movement for 'Total Revolution' launched by 'JP' during 1973-79 and remained actively involved in anti-emergency movement in the country during the years 1975-77.

(iv)             The petitioner himself had been a victim of police atrocities and has personally suffered illegalities and physical and psychological intimidation in the hands of the police. The petitioner was illegally and unofficially picked up by the police from his residence during 'emergency' in year 1975 and was illegally kept at police station central, Sector 17, Chandigarh on several occasions.

(v) The petitioner's elder brother, Mr. Adarsh Goel, Advocate, Supreme Court of India, New Delhi, was detained and arrested by the Chandigarh police and was released by this Hon'ble Court on bail. A copy of the order passed by this Hon'ble Court, if available, shall be produced before this Hon'ble court at the time of hearing.

(vi)             The petitioner's father, Shri Rati Ram Goel son of late Shri Lekh Raj Goel, resident of 1261, Sector 18-C, Chandigarh (at that time) remained in jail during emergency in the years 1975 and 1976 which is a matter of record of  the Chandigarh Administration. The petitioner has thus family background as well as a background of his own for working in the arena of facing and opposing illegalities of the establishment in general and police in particular.

(vii)           In April 1977 Chhatra Yuva Sangharsh Vahini (CYSV) was formed at the national level with 'JP' as its President and with head quarters at Kadam Kuan, Patna. The petitioner was appointed as Convener of CYSV Punjab Unit. The petitioner was elected as a member of the National Executive Committee of the CYSV in June, 1977. The aims and objects of CYSV were to accelerate the movement for 'Total Revolution' and to act as a watch-dog body so as to expose and oppose the misdeeds of people in power in particular and the Government in general.

(viii)          During 1978 there was an utter chaos and widespread unrest in the State of Punjab on account of the widely known Akali-Nirankaris dispute culminating in the death of a number of innocent persons on 13.4.1978 at Amritsar. The Government of the day was unable to prevent killings of innocent people in the State and even killings of school children had become an order of the day. A report was called from the petitioner by 'JP'. The petitioner prepared a fact finding report with the help of other members of the CYSV spread throughout the State of Punjab and submitted the same to 'JP'. On the basis of report submitted by the petitioner, 'JP' deputed the petitioner to carry a letter and to meet on his behalf the then Prime Minister of India late Sri Morarji Bhai Desai. The petitioner was also deputed, vide letters written by 'JP' to be delivered per hand, to meet the then President of Akali Dal, Shri Jagdev Singh Talwandi, President of SGPC Shri G.S. Tohra and the then Chief Minster Shri Parkash Singh Badal, seeking prevention of killings of innocent people in the State.

(ix)             The petitioner also organized a number of talks/seminars on the citizens' rights of life and liberty and involved a number of public personalities like late Justice Tek Chand, Prof. Balraj Madhok; Prof. K.K. Dhawan, Prof. D.P. Maini, etc. etc.

(x)  On the basis of information provided by the petitioner, a number of steps were taken by the Punjab Government to ensure protection of lives and liberties of innocent citizens in discharge of its constitutional obligations, the failure whereof could result dismissal of Punjab Government in the hands of the Central Government.

(xi)             The activities of petitioner are on records of the respondents 1 and 2; and the facts about detention of his elder brother and father are on record of Chandigarh Administration.

(xii)            The petitioner challenged before this Hon'ble Court the illegal detention of late Sri Raj Narayana by Chandigarh Police in June 1982. The petitioner was a counsel in the writ petition filed by late Shri Raj Narayan challenging illegal appointment of Shri Bhajan Lal as the Chief Minster of Haryana in June 1982 despite his having commanded support of only 35 MLAs in the house of 90.

(xiii)          The petitioner was nominated as a Member of the 'Local Advisory Committee' of Chandigarh Administration during 1983 and a member of the 'Jail Advisory Committee' of Chandigarh Administration during 1985.        

(xiv)         The petitioner actively worked for the cause of poor and downtrodden tribals of South Bihar and actively associated with the 'Jharkhand Movement'. The petitioner was invited by the then Prime Minister of India, Shri P.V. Narsimha Rao, in June-July 1991 for making suggestions on the Jharkhand issue. On the advice of the Prime Minister, the petitioner drafted a proposed bill which could meet aspirations of the people of Jharkhand area. The proposed draft bill was submitted to the then Prime Minister for constituting 'Jharkhand Areas autonomous Council' to meet immediate aspirations of the people of Jharkhand.

(xv)           The petitioner has seen cruelty, poverty and human rights violations in its naked form and is fully competent to comprehend the situations detailed by the deponent in his affidavit. Therefore the petitioner cannot be dubbed as 'nobody' or a person having no background of working in larger public interest or being associated with the organizations working in the field of human rights.

4.  That it is denied that the petition is frivolous. The petitioner is aggrieved on account of non action of the respondent-State in their failure to prevent the C.C.D.P. and the respondent No. 3 from setting up a parallel judicial system.

5.  That the Rules of the 'Peoples' commission on Human rights violations In Punjab' were circulated by the intervener, viz., the CCDP on 27.8.1998 which is an important document to decide the controversy. A true copy of this document is annexed herewith and marked as Annexure P-1. 

6.  That the next sitting of the 'peoples' Commission on Human Rights Violations in Punjab' is scheduled for November 28, 29 and 30, 1998 at Amritsar. A press Release by the CCDP was issued on or after 2.11.1998. A true copy of the press release dated 2.11.1998 is annexed herewith and marked as Annexure P-2. The press release mentions the names of members of organizing committee who are entrusted in the task of making arrangements for the said sittings of Respondent No. 3 at Amritsar. The names include Shri Kirpal Singh Randhawa against whom Criminal Writ Petition No. 70 of 1998, titled Swinder Singh vs. State of Punjab and others, was filed in this Hon'ble Court on 21.1.1998. The matter was last heard by Hon'ble Mr. Justice K.K. Srivastava and is fixed for hearing for 14.1.1999. It has been alleged by the petitioner that the said Mr. Randhawa (Respondent No. 4 in the criminal writ petition) was coercing the petitioner therein to make a false statement against police officials. A true copy of this writ petition is annexed herewith and marked as Annexure P-3.

7.  That a Public Notice was published on behalf of the Respondent No. 3 summoning 124 police officials to appear before the Peoples Commission on 28.11.1998 to 30.11.1998. This public notice has appeared in several newspapers and news about this notice has been published by Respondent No. 4 in its edition of November 9, 1998. A true copy of this public notice is annexed herewith and marked as Annexure P-4. As per news report published by the Respondent No. 4 in The Tribune of 10.11.1998, the CCDP has issued notices to 524 persons, including police personnel, in 87 cases.

8.  That as per para 1 of Civil Misc. Application No. 24631-24633 filed in the present petition on behalf of Shri Madanjit Singh, PPS, Assistant Commandant, Indian Reserve Battalion, two members of the C.C.D.P., namely Sri D.S. Rajput and Shri Jasvir Singh Dhillon, have been arrested and are facing criminal trial in 'Burail jail break case'. As averred in the above mentioned C.M.A., these two members of C.C.D.P. allegedly actively participated in a criminal conspiracy to blow up the high security jail so as to facilitate the escape of Jagtar Singh Hawara, the prime accused in Beant Singh assassination case. The said C.M.A. also contains 11 letters addressed by foreigners to authorities in India seeking protection for Shri Jaspal Singh Dhillon, one of the Members of the CCDP who is allegedly involved in the said Burail Jail Break case. The petitioner craves leave of this Hon'ble Court to refer to and rely upon the contents of afore C.M.A. along with documents annexed therewith.

9.  That the State of Punjab remained under President's Rule for the period from 6.10.1983 to 29.9.1985 and 11.5.1987 to 25.2.1992 in terms of proclamations issued by the President of India. During this period sub section 3-A was inserted in Section 197 of the Criminal Procedure Code by Act 43 of 1991 whereby it was provided that cases against members of armed forces for acts purported to be done in the discharge of their official duty and exercise of power vested in them under law could not be proceeded without prior sanction of Union Government (Respondent No. 1).

10. That the Peoples' Commission Respondent No. 3, lacking any sanction of law, is arrogating to itself powers beyond what the competent court in India have and is indulging in fishing and roving enquiry singling out only one section of public servants contrary to law in a discriminatory manner for oblique and improper purposes.

11. That w writ petition, being Civil Writ petition No. 17121 of 1998, Mohan Singh and others vs. Union of India and others, has been filed before this Hon'ble Court and is pending for hearing. A perusal of contents of this writ petition reveals that one of the consequence of impugned illegal actions of the Peoples' Commission could be isolating and maligning a section of the public servants to the risk of being inevitable target of the forces who are anti-national, anti-social, secessionist, having extra-territorial loyalties and are known to have eliminated people who either opposed or did not succumb to their demands. Recent history of Punjab is replete with such instances in which either upright or innocent persons have lost their lives and their family members have also been eliminated. The geographical location of Punjab also permits agencies who are opposed to the integrity of India to utilize the illegal exercise now being conducted to cause disaffection, disharmony, disloyalty amongst local population which in the unique context of India is pluralistic.

12. That the impugned illegal activities are fraught with potential danger of undermining the integrity of Punjab and India. In the guise of protection of Human Rights and exercise of Fundamental Rights, rampant fundamentalism is sought to be revived by the Respondent No. 3. The impugned action do not and cannot find any support from Article 19 of the Constitution of India. These are rather violative of Fundamental Rights of the citizens, including the petitioner and are subversive of the concept of rule of law.

CHANDIGARH                                                  SUDERSHAN GOEL

NOVEMBER 13, 1998                                        DEPONENT

VERIFICATION:     

Verified that the contents of paras 1 to 4 of this affidavit are true and correct to my knowledge and belief. The contents of paras 5 to 8 are based upon records circulated by CCDP and of this Hon'ble High Court. The contents of paras 9 to 12 are based upon legal advice which is believed to be correct. No part of it is false and nothing material has been kept concealed.

CHANDIGARH                                                  SUDERSHAN GOEL

NOVEMBER 13, 1998                                        DEPONENT

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