Thursday, 19 April 2012

State Transport Authority Maharashtra is above the Law?????


IN THE HIGH COURT OF JUDICATURE AT BOMBAY
ORDINARY ORIGINAL CIVIL JURISDICTION

Review Petition  No 27 of 2012 
in 
PUBLIC INTEREST LITIGATION NO.  17 OF 2012

Mumbai Taximen Sangathan and others         ……… Petitioners
Versus
The State of Maharashtra & others …….. Respondents

INDEX
S.NO.
PARTICULARS
PAGE NOS
1.      
Proforma
A-D
2.      
Synopsis
E-
3.      
Petition
1-
4.      
Memo of Appearance

5.      
Memorandum of Address

6.      
List of Documents

7.
Annexure

8.
Annexure P-1, Copy of the Trade certificate of the petitioner.

9
Annexure P-2, Copy of the Resolution passed by the petitioner

10
Affidavit in Support

11
Advocate Certificate

12
Affidavit as per rule of High Court


Total pages







 
 
IN THE HIGH COURT OF JUDICATURE AT BOMBAY
ORDINARY ORIGINAL CIVIL JURISDICTION
Review Petition  No 27 of 2012 
in 
PUBLIC INTEREST LITIGATION NO.  17 OF 2012

     Mumbai Taximen Sangathan and others         ……… Petitioners
Versus
The State of Maharashtra & others …….. Respondents

SYNOPSIS

Date
Particular

1st July 1989


State of Maharashtra had constituted the State Transport Authority and The MMRTA U/s. 68 of the Motor Vehicle Act, 1988 vide As per notification no. MVA. 0183/57(i)/TRA-2 No. MVA. 0183/57(i)/TRA -2 and notification no. MVA. 0192/1553/CR-97/TRA-2 respectively

-----
Subject Matter of the Present Petition:
The State Transport Authority: As per notification no. MVA. 0183/57(i)/TRA-2 No. MVA. 0183/57(i)/TRA -2 - In Exercise of the powers conferred by sub-section (1) of Section 68 of the Motor Vehicles Act, 1988 (59 of 1988), in its application to the State of Maharashtra and in supersession of all notifications issued in this behalf, the Government of Maharashtra hereby constitutes, with effect from the 1st day of July 1989, the State Transport Authority, comprising of the following persons, to exercise and discharge the powers and functions specified in sub-section (3) of the said Section 68, namely:-

(1)            Shri P. Subrahmanyam, Secretary to the Government of Maharashtra, Industries, Energy and Labour
Department (Energy) and Environment Department.
Chairman

(2)            Deputy the Inspector General of Police (Traffic),            Maharashtra State, Bombay
Member

(3)            The Transport Commissioner, Maharashtra State, Bombay.
Member

(4)            Dr. P.G. Patankar, Director, Central Institute of        Road Transport, Pune.
Member

(5)            Shri Mukesh Rasiklal Patel, 4-A, Vikas Centre 104, S.V. Road, Santacruz (West), Bombay- 400 054.
Member

The Mumbai Metropolitan Regional Transport Authority: As per notification no. MVA. 0192/1553/CR-97/TRA-2

No. MVA 0192/1553/CR-97/TRA-2 – In exercise of the powers conferred by sub-section (1) of section 68 of the Motor Vehicles Act, 1988 (59 of 1988). In its application to the State of Maharashtra, and in supersession of all notifications issued in this behalf the Government of Maharashtra, hereby constitutes, with effect from the date of issue of this Notification the Regional Transport Authorities consisting of the persons mentioned in column (2) of the Schedule hereto appended, for the regions as shown opposite thereto, in columns (3) and (4) of the said Schedule, to exercise and discharge throughout the said regions, the powers and functions conferred upon them by or under Chapter V of the said Act, namely :-gazette shall be


Earlier the respondent no.2 had two expert/ non-official members in the respondent no.2 body but now there are no non-official members, the reason best known to the State.




Respondent no.2 had only 4 members and all are bureaucrat’s i.e.   
                                                  i.      The Principal Secretary, Transport is the Chairman of the STA
                                               ii.      The Addl. Transport Commissioner is the Secretary of the STA
                                             iii.      The Transport Commissioner is the member of the STA
                                             iv.      The Addl. Director General of Police – Traffic is the member of STA.




The present Secretary of the respondent no.2 Mr. Shirish Thakur is holding this position in the STA for the last more than 7 years and now he is acting as a dictator. As per Section 60 (6) of the Motor Vehicle Act, 1988 clear that the Joint Transport Commissioner or the officer appointed by the Government by the notification in the official gazette shall be the secretary of the State Transport Authority


There is no guideline to prepare the agenda of the respondent no.2 and 3 hence the Secretaries are preparing the agenda for their own benefit or favoring their associates. It is pertinent to note that neither the dates of the meeting nor the agenda of the respondent no.2 and 3 are made public.


When the respondent no.2 and 3 approved any agenda or scheme then after no time, they are amended the same on the request of the interested parties without looking through the interest of the State. It is pertinent to note that the respondent no. 2 and 3 amended the fleet taxi scheme 2006 for the interest of private fleet taxi operators. 


whenever the interested parties want to pass any resolution in their favor then the Secretary of the respondent no.2 and 3 put their proposal or request in the agenda of the meetings.  It is pertinent to note that if any other common person or the Trade Union wants or put their grievances/proposals  in the respondent no. 2 and 3 meeting then the Secretaries of the respondent no. 2 and 3 was neglected the same intentionally and deliberately for their own interest.


respondent no. 2 and 3 has not published / made public the agenda of their forthcoming meeting nor are they inviting any suggestions from anyone before preparing the agenda of the meeting.


after the approval of the agenda by the respondent no. 2 and 3, they are not ready to disclose or make public in regard of the approval of the agenda.


it is very dangerous that four bureaucrats are misusing the power of the respondent no. 2 and 3. It is pertinent to note that out of four three officials are from the Transport department.


respondent no. 2 and 3 are organizing the meeting as per their convenience and also approve the items of the agenda of their own choice and rest on the agenda of the meeting are forwarded to the next meeting.


officers of the RTO and Transport Commissioner are making a fool of the public on the name of the agenda/meetings of the respondent no. 2 and 3 stating that they are going to put the issue of the aggrieved person in the next meeting but they never put the issue of the aggrieved person in the agenda itself.


respondent no. 2 attempts to please the influential people and they will get the approval from the respondent no. 2 through circulation amongst its members without any of the respondent no. 2 meeting. It is pertinent to note that earlier the respondent no. 2 had increased fleet taxi rates overnight without any meeting when the drivers of the fleet taxi operators went on strike.


Respondent no. 2 and 3 are not disclosing the agenda and the date of the meetings and they passed resolution for the influential persons and making amendments for their own convenience without going through the merits


Present Secretary of the respondent no.2 has become the more powerful person in the State Transport Department and he put the agenda of their own convenience and to please his associates and political bosses for the last seven years.


Respondent no. 2 has also taken the harsh decisions to increase the fair without any meeting and by circulation only for the one fleet taxi operator overnight. It is pertinent to note that first the respondent no. 2 introduced/ passed the various schemes but within no time they are doing the amendments without any delay just to please the beneficiary of the schemes.


present petition is being filed by way of public Interest litigation and the petitioner does not/do have any personal interest in the matter.


petition is being filed in the interest of the Taximen as well as public at large. Hence this present petition is filed by the present petitioner i.e. Mumbai Taximen Sangathan.


Entire litigation costs, including the other cost/ fee and other charges are being borne by the petitioner. The PAN No. of the petitioner is AQMPK6798B.


Petitioner has understood that in the course of hearing of this petition the Court may require any security to be furnished towards costs or any other charges and the petitioner shall have to comply with such requirements.


PETITIONER got the information through the office of the respondent no. 2 and 3 including the office of the Transport Commissioner Government of Maharashtra under the RTI Act. 2005


Declare the source of information of the facts pleaded in the petition and as to whether the petitioner/petitioners has/have verified the facts personally, if yes, in what manner?


Petitioner had made several representations before the Authorities but no reply has been given by such authorities, the reasons best known to them.


There is no delay, for filing the present petition.


the respondent no. 1 to appoint the secretary of the respondent no.2 as per the Section 60 (6) of the Maharashtra Motor Vehicle Rule 1989 or appoint the Joint Transport Commissioner or any other officer other than the present Secretary of the respondent no. 2. AND the present Secretary of respondent no.2 for the last about seven years continuously. 


Petitioners have no personal and or private interest and the present Petition is been filed by them in the true interest for the benefits and welfare of the group of the society who are into the similar kind of situation as the Petitioner is at present.


there is no control on the Respondent no. 2 and 3
because the secretary of the respondent no. 2 are holding this position for the last more than 7 years and 3 officers from the transport department and one from the traffic police.

It is pertinent to note that no non-official/ expert members are the part of the respondent no. 2 and 3 for the last ten years and more and all the resolutions passed by the respondent no. 2 and 3 need to be revised by the full Coram of the respondent no. 2 and 3.

It is further pertinent to note that petitioners are shocked and surprised when the petitioners come to know that non- official members had appointed in all the districts regional transport authority but not in the respondent no. 2 and 3 i.e.  in the MMRTA

15-02-2012
Hence this public interest litigation has been filed before this Hon’ble court
                                   
              ACTS/RULES REFERRED TO:
1)   Constitution Of India
2)   Motor Vehicle   Act, 1888
JUDICAL AUTHORITIES CITED
                        At the time of Argument
                        POINTS TO BE URGED

1)   Whether it’s legal that no unofficial member in the STA- State Transport Authority and the MMTRA – Mumbai Metropolitan Transport Regional Authority, Central, Western, and Eastern meetings for the last ten years and more as per the Notification number MVA. 0183/57(i)/TRA-2 dated 1st July 1989?
2)   Whether all the resolutions passed by the STA- State Transport Authority and the MMTRA – Mumbai Metropolitan Transport Regional Authority, Central, Western, and Eastern meetings for the last ten years and more are illegal and to be declared null and void?
3)   Whether the terms of appointment of the Secretary of the STA- State Transport Authority is illegal as  per the provision of section 96(2) (i), when the Secretary of the STA- State Transport Authority is holding this position for last seven years and more?
4)   Whether the STA- State Transport Authority and the MMTRA – Mumbai Metropolitan Transport Regional Authority, Central, Western, and Eastern have the discretionary powers to put any issue or matter in the agenda of the their meetings, without getting the opinions from the experts or the public at large?
5)   Whether the agenda of the STA- State Transport Authority and the MMTRA – Mumbai Metropolitan Transport Regional Authority, Central, Western, and Eastern to be public or published in the media or put on the official website of the transport department for their opinion before taking the decision in the meetings?
                                                                                    Petitioner










IN THE HIGH COURT OF JUDICATURE AT BOMBAY
ORDINARY ORIGINAL CIVIL JURISDICTION

Review Petition  No 27 of 2012 
in 
PUBLIC INTEREST LITIGATION NO.  17 OF 2012

In the matter of Articles 226 of the Constitution of India for writ of Certiorari and writ of Mandamus   

And

In the matter of the functions of the State Transport Authority and Mumbai Metropolitan Regional Transport Authority

And

In the matter of the Agenda of the State Transport Authority and Mumbai Metropolitan Regional Transport Authority

And

In the matter of the dates of the meetings of the State Transport Authority and Mumbai Metropolitan Regional Transport Authority

And

In the matter of the resolutions of the State Transport Authority and Mumbai Metropolitan Regional Transport Authority

And

In the Matter of publish the dates of meetings and agendas of the State Transport Authority and Mumbai Metropolitan Regional Transport Authority in the leading news papers / official website of the State Government or the State Transport Department and the Public Gazette

And

In the matter of fix the tenure of the Secretary of the State Transport Authority
And

In the matter of the agenda and resolution passed by the State Transport Authority and Mumbai Metropolitan Regional Transport Authority through circulation among its members

And

In the matter of to frame guidelines to prepare the agenda of the State Transport Authority and Mumbai Metropolitan Regional Transport Authority


And

In the matter of the non official members/ Independent public representations in the State Transport Authority and Mumbai Metropolitan Regional Transport Authority

And

In the matter of Transportation and traffic expert representation in the State Transport Authority and Mumbai Metropolitan Regional Transport Authority other than the Government officials

And

In the matter of minimum six meetings in the year of the State Transport Authority and minimum twelve meetings of the Mumbai Metropolitan Regional Transport Authority

1.     MUMBAI TAXIMEN SANGATHAN 
Through its General Secretary

   ……………………………Petitioners
                                               
VERSUS

1.     State of Maharashtra
Through Public Prosecutor,
Original Side,
PWD Building,
High Court Mumbai

2.     The Chairman,
State Transport Authority
Cum Principal Secretary
Transport
Government of Maharashtra,
Mantralya,
Mumbai


3.     The Chairman,
Mumbai Metropolitan Regional Transport Authority
Cum Principal Secretary
Transport
Government of Maharashtra,
Mantralya,
Mumbai

……… RESPONDENTS

HUMBLE PETITION OF THE
PETITIONER ABOVENAMED

MOST RESPECTFULLY SHWETH:

THE HON’BLE CHIEF JUSTICE AND
THE HON’BLE PUISNE JUDGES OF
THE HIGH COURT OF JUDICATURE AT BOMBAY

                                                                                    THE HUMBLE PETITION OF THE
PETITIONERS ABOVE NAMED

MOST RESPECTFULLY SHOWETH:

1.     The Petitioners submit that the cause of action for filing this public interest litigation petition has arisen in Mumbai and this Hon’ble Court has jurisdiction under Article 226 of the Constitution of India to try and entertain this petition.
2.     The Petitioner states that he has thoroughly studied and researched on this on the subject matter of present petition for the last five years.
3.     That the petitioners state that, petitioner no. 1 is a Trade Union formed by the Taximen under the name and style of Mumbai Taximen Sangathan & petitioners 2 to 4 are law students. The respondent no. 1 is the State of Maharashtra, respondent no. 2and 3 are the chairman of the State Transport Authority and the MMRTA. The petitioners are residents of Mumbai, Maharashtra and are running the trade union and rest others are law students and residents of Mumbai, and as such are competent to invoke the extra – ordinary jurisdiction Hon’ble court.
4.                 That the petitioner no.1 is the trade union and registered with registrar of trade union on the name and style of Mumbai Taximen Sangathan. The petitioner is a resident of Maharashtra and is working for the welfare of taximen in Mumbai and Maharashtra, and as such is competent to invoke the extra-ordinary jurisdiction of this Hon'ble court. The copy of the trade certificate is annexed as Annexure P-1
5.                 That the present petition is filed through Sh. Sanjay Khemka the Secretary of the Mumbai Taximen Sangathan and petitioner no. 2 to 4 are law students and they are appearing in person, who are well conversant with facts of the case and matter. The copy of the resolution passed by the petitioner no. 1 is annexed as Annexure P-2
6.     That the petitioner states that he is the General Secretary of the Mumbai Taximen Sangathan and the Chief Executive Officer of the Tristars Alliance Group. It is pertinent to note that earlier the petitioner was the Chief Executive Officer of the Asian Sky Shop Limited. The details of the office bearers of the present petitioner is as under:
Mr. Bhupendra Surani – President
Mr. Shiv Adhar Yadav – Vice President
Mr. Sanjay Khemka – General Secretary
Mr. Kanhaiya Singh – Secretary
Mr. Hemant Khemka – Treasurer

7.     That the petitioners states that the petitioners or any of the petitioners when there are more then one, is/are or has been involved in any other civil, revenue, criminal litigation in any, capacity before any Court or Tribunal and if so, complete details of such litigation including the subject matter thereof. 
Subject Matter of the Present Petition:
(a)             The State Transport Authority: As per notification no. MVA. 0183/57(i)/TRA-2 No. MVA. 0183/57(i)/TRA -2 - In Exercise of the powers conferred by sub-section (1) of Section 68 of the Motor Vehicles Act, 1988 (59 of 1988), in its application to the State of Maharashtra and in supersession of all notifications issued in this behalf, the Government of Maharashtra hereby constitutes, with effect from the 1st day of July 1989, the State Transport Authority, comprising of the following persons, to exercise and discharge the powers and functions specified in sub-section (3) of the said Section 68, namely:-
(6)            Shri P. Subrahmanyam, Secretary to the Govern-                 Chairman
Ment of Maharashtra, Industries, Energy and Labour
Department (Energy) and Environment Department.
(7)            Deputy the Inspector General of Police (Traffic),                  Member
Maharashtra State, Bombay.
(8)            The Transport Commissioner, Maharashtra State,               Member
Bombay.
(9)            Dr. P.G. Patankar, Director, Central Institute of                     Member
Road Transport, Pune.
(10)      Shri Mukesh Rasiklal Patel, 4-A, Vikas Centre                                    Member
104, S.V. Road, Santacruz (West), Bombay- 400 054.

(b)            The Mumbai Metropolitan Regional Transport Authority: As per notification no. MVA. 0192/1553/CR-97/TRA-2
No. MVA 0192/1553/CR-97/TRA-2 – In exercise of the powers conferred by sub-section (1) of section 68 of the Motor Vehicles Act, 1988 (59 of 1988). In its application to the State of Maharashtra, and in supersession of all notifications issued in this behalf the Government of Maharashtra, hereby constitutes, with effect from the date of issue of this Notification the Regional Transport Authorities consisting of the persons mentioned in column (2) of the Schedule hereto appended, for the regions as shown opposite thereto, in columns (3) and (4) of the said Schedule, to exercise and discharge throughout the said regions, the powers and functions conferred upon them by or under Chapter V of the said Act, namely :-gazette shall be
8.     That the petitioners state that, petitioner or any of the petitioners when there are more then one, is or has been involved in any other civil, revenue, criminal litigation in any, capacity before any Court or Tribunal and if so, complete details of such litigation including the subject matter thereof

9.     That the petitioners state that, earlier the respondent no.2 had two expert/ non-official members in the respondent no.2 body but now there are no non-official members, the reason best known to the State.

10.                       That the petitioners state that, respondent no.2 had only 4 members and all are bureaucrat’s i.e.   

                                                                                                                                      i.      The Principal Secretary, Transport is the Chairman of the STA
                                                                                                                                   ii.      The Addl. Transport Commissioner is the Secretary of the STA
                                                                                                                                 iii.      The Transport Commissioner is the member of the STA
                                                                                                                                 iv.      The Addl. Director General of Police – Traffic is the member of STA.

11.                       That the petitioners state that, the present Secretary of the respondent no.2 Mr. Shirish Thakur is holding this position in the STA for the last more than 7 years and now he is acting as a dictator. As per Section 60 (6) of the Motor Vehicle Act, 1988 clear that the Joint Transport Commissioner or the officer appointed by the Government by the notification in the official gazette shall be the secretary of the State Transport Authority
12.                       That the petitioners state that, there is no guideline to prepare the agenda of the respondent no.2 and 3 hence the Secretaries are preparing the agenda for their own benefit or favoring their associates. It is pertinent to note that neither the dates of the meeting nor the agenda of the respondent no.2 and 3 are made public.
13.                       That the petitioners state that, when the respondent no.2 and 3 approved any agenda or scheme then after no time, they are amended the same on the request of the interested parties without looking through the interest of the State. It is pertinent to note that the respondent no. 2 and 3 amended the fleet taxi scheme 2006 for the interest of private fleet taxi operators. 
14.                       That the petitioners state that, whenever the interested parties want to pass any resolution in their favor then the Secretary of the respondent no.2 and 3 put their proposal or request in the agenda of the meetings.  It is pertinent to note that if any other common person or the Trade Union wants or put their grievances/proposals  in the respondent no. 2 and 3 meeting then the Secretaries of the respondent no. 2 and 3 was neglected the same intentionally and deliberately for their own interest.
15.                       That the petitioners state that, the respondent no. 2 and 3 has not published / made public the agenda of their forthcoming meeting nor are they inviting any suggestions from anyone before preparing the agenda of the meeting.
16.                       That the petitioners state that, after the approval of the agenda by the respondent no. 2 and 3, they are not ready to disclose or make public in regard of the approval of the agenda.
17.                       That the petitioners state that, it is very dangerous that four bureaucrats are misusing the power of the respondent no. 2 and 3. It is pertinent to note that out of four three officials are from the Transport department.
18.                       That the petitioners state that, the respondent no. 2 and 3 are organizing the meeting as per their convenience and also approve the items of the agenda of their own choice and rest on the agenda of the meeting are forwarded to the next meeting.
19.                       That the petitioners state that, the officers of the RTO and Transport Commissioner are making a fool of the public on the name of the agenda/meetings of the respondent no. 2 and 3 stating that they are going to put the issue of the aggrieved person in the next meeting but they never put the issue of the aggrieved person in the agenda itself.
20.                       That the petitioners state that, the respondent no. 2 attempts to please the influential people and they will get the approval from the respondent no. 2 through circulation amongst its members without any of the respondent no. 2 meeting. It is pertinent to note that earlier the respondent no. 2 had increased fleet taxi rates overnight without any meeting when the drivers of the fleet taxi operators went on strike.
21.                        That the present petition is being filed by way of public Interest litigation and the petitioner does not/do have any personal interest in the matter.
22.                       The petition is being filed in the interest of the Taximen as well as public at large. Hence this present petition is filed by the present petitioner i.e. Mumbai Taximen Sangathan.
23.                       That the entire litigation costs, including the other cost/ fee and other charges are being borne by the petitioner. The PAN No. of the petitioner is AQMPK6798B.

24.                       The Petitioner has not filed any other petition in this Hon’ble Court or in the Hon’ble Supreme Court of India wherein the impugned actions are subject matter of challenge.
                                      
25.                         That a thorough research has been conducted in the matter raised through the petition (all the relevant material in respect of such research shall be annexed with the petition).
26.                       That to the best of the petitioner(s) knowledge and research, the issue raised was not dealt with or decided and that a similar or identical petition was not filed earlier by him/it
27.                       That the petitioner has understood that in the course of hearing of this petition the Court may require any security to be furnished towards costs or any other charges and the petitioner shall have to comply with such requirements.
28.                       That the petitioner states that he got the information through the office of the respondent no. 2 and 3 including the office of the Transport Commissioner Government of Maharashtra under the RTI Act. 2005
29.                       Declare the source of information of the facts pleaded in the petition and as to whether the petitioner/petitioners has/have verified the facts personally, if yes, in what manner?
30.                       That the petitioner states that the petitioner had made several representations before the Authorities but no reply has been given by such authorities, the reasons best known to them.
31.                       That the petitioners states that there is no delay, for filing the present petition.
32.                       This Hon’ble Court may please to direct the respondent no. 1 to appoint the secretary of the respondent no.2 as per the Section 60 (6) of the Maharashtra Motor Vehicle Rule 1989 or appoint the Joint Transport Commissioner or any other officer other than the present Secretary of the respondent no. 2.   That the petitioner states that the present Secretary of respondent no.2 for the last about seven years continuously. 
33.                       That the petitioner states that, there is no caveat been filed or no notice been received of lodging a caveat by the respondents /opposite party.

34.                       The Petitioners state that, they have no personal and or private interest and the present Petition is been filed by them in the true interest for the benefits and welfare of the group of the society who are into the similar kind of situation as the Petitioner is at present.

35.                       The Petitioners submit that, there is none an efficacious and effective a remedy as available under the law otherwise than the remedy in Writ Jurisdiction.
36.                       The Petitioner is paying fixed court fee of Rs. 1000/- for the purpose of this petition.
37.                       The Petitioner shall rely upon documents, a list whereof is annexed hereto and also the documents to which reference has been made in this petition.
38.                        The petitioners craves leave off this Hon’ble Court ot add, amend, alter, delete and/or rescind any of the averments and/or submissions made hereinabove  with the leave of this Hon’ble Court.
The Petitioner therefore prays:-
a)    This Hon’ble Court may declare all the resolutions passed by the respondent no. 2 and 3 without completed the Coram of the respondent no. 2 and 3.
b)    This Hon’ble Court may pleased to direct the respondent no. 1 to appoint the expert/ non-official member of the respondent no. 2 and 3
c)     This Hon’ble Court may pleased to direct the respondent no. 2 and 3 to frame the guidelines to prepare the agenda of the meetings of the respondent no. 2 and 3
d)   This Hon’ble Court may pleased to direct the respondent no. 2 and 3 to publish the agenda in the media or put on the official website of the State Transport Department to get the opinion of the public at large.
e)    This Hon’ble Court may pleased to direct the respondent no. 2 to have minimum six meetings in the year and the respondent no. 3 to have minimum 12 meetings in the year
f)      This Hon’ble Court may please to direct the respondent no. 1 to appoint the secretary of the respondent no.2  as per the Section 60 (6) of the Maharashtra Motor Vehicle Rule 1989 or appoint the Joint Transport Commissioner or any other officer other than the present Secretary of the respondent no.2
g)    The Interim relief clause (f) be granted till the pendency of this petition in the interest of natural justice.
h)   Any other order or direction deemed fit and proper by this Hon’ble Court in the interest of natural justice.
            Place: Mumbai
            Dated this 15th day of February 2012

                                                                                               
Petitioners in Person
VERIFICATION
We, Sanjay Khemka, Aarti Cindala, Arka Navle and Madhavi Garde adult Indian Inhabitant are the Petitioners above named having office at Andheri-East, Mumbai – 400 093902, Solitaire Corporate Park, Chakala, Andheri – Ghatkopar Link Road, do hereby on solemn affirm that the contents of  the foregoing paragraphs are true correct to my knowledge and is believed to be true and correct as per legal information received and believed to be correct. No part of it is incorrect and false and nothing material fact has been kept concealed there from.
Solemnly declared at Mumbai
Aforesaid dated this, the                                                                         Deponents
 Day of   15th February 2012                                                                                                   Before me





IN THE HIGH COURT OF JUDICATURE AT BOMBAY
ORDINARY ORIGINAL CIVIL JURISDICTION
PUBLIC INTEREST LITIGATION NO    17    OF 2012


Mumbai Taximen Sangathan and others         ……… Petitioners
Versus
The State of Maharashtra & others        …….. Respondents
           

LIST OF DOCUMENTS ON WICH PETITIONER WILL RELY
---------------------------------------------------------------------------
 
1.    Copy of the Trade certificate.
2.    Copy of the Resolution.








            

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