Sub: Writ Appeal against the order of the learned Single Judge of this Hon’ble Court declining the ad-interim injunction sought for by the appellant seeking the respondents to refrain from proceeding any further with the selection and appointments of judges to the august office of Supreme Court and Various High Courts by means of the “Collegium System” pending finalization of Memorandum of Procedure (MOP) as envisaged in the judgment of the NJAC case.
BEFORE THE HON’BLE HIGH COURT OF KERALA AT ERNAKULAM
WRIT APPEAL NO.__________ OF 2016
(Against the order dated 08/04/2016 passed by the learned Single Judge of this Hon’ble Court in Unnumbered WP 208/2016 declining interim injunction)
Jacob Samuel .… Appellant/Petitioner
Vs.
The Union of India & Ors …. Respondents/Respondents
MEMORANDUM OF writ APPEAL UNDER SECTION 5 OF THE Kerala high Court act filed by the Appellant through his lawyer sri P.BIJIMON against the order dated 08/04/2016 passed by the learned Single judge in UNNUMBERED writ petition 208/2016 declining interim injunction.
P.BIJIMON (B-732) (K/3173/1999)
Room No.210, 2nd Floor,
Prasanna Vihar Appartments,
Near High Court of Kerala,
Cochin-682 031
Ph.No.0484-2368737
Counsel for the Petitioner
BEFORE THE HON’BLE HIGH COURT OF KERALA AT ERNAKULAM
WRIT APPEAL NO.__________ OF 2016
(Against the order dated 08/04/2016 passed by the learned Single Judge of this Hon’ble Court in Unnumbered WP 208/2016 declining interim injunction)
Jacob Samuel … Appellant/Petitioner
Vs.
The Union of India & Ors …. Respondents/Respondents
I N D E X
Sr.No
Particulars Documents
Page No.
1.
Synopsis
A-B
2.
Memorandum of Writ Appeal
1-8
3.
Certified copy of judgement dated 08/04/2016 in Unnumbered Writ Petition No.208/2016
9
4.
True Copy of Unnumbered Writ Petition No.208/2016
10-22
5.
Annexure-A
True Copy of the Order dated 16/12/2015 by Hon’ble Supreme Court in Writ Petition © N0 13/2015
23-38
6.
Affidavit
39
7.
Petition for condoning the delay
40
8.
Petition for accepting Annexure-A
41-44
Dated this the 20th day of June 2016
P.BIJIMON
Advocate for the Appellant/Petitioner
-A-
BEFORE THE HON’BLE HIGH COURT OF KERALA AT ERNAKULAM
APPEAL NO.__________ OF 2016
(Against the order dated 08/04/2016 passed by the learned Single Judge of this Hon’ble Court in Unnumbered WP 208/2016 declining interim injunction)
Jacob Samuel .… Appellant/Petitioner
Vs.
The Union of India & Ors …. Respondents/Respondents
SYNOPSIS
The Appellant, a lawyer primarily practising in the District Court at Mavelikara and other Courts near and around Mavelikara, which are subordinate to the Hon'ble High Court of Kerala and occasionally in the Hon'ble High Court of Kerala, was constrained to institute Unnumbered WP 208/2016 since he bona fide believed that the current collegium system of selection and appointment of judges to the higher judiciary worked out to the great disadvantage of the lawyers practising in the Courts subordinate to the Supreme Court and High Courts. The new Memorandum of Procedure for appointment of Judges, which the Constitution Bench in the NJAC case had directed the Government of India to draft in consultation with the Hon'ble Chief Justice of India/collegium, is yet to be done/notified to the public at large. However, apparently since appointments to the Supreme Court and High Courts were held up since the NJAC Act was notified, the collegium of the Supreme Court/High Courts had made number of recommendations for appointments of Judges. It was in the above circumstances that the Appellant instituted the aforesaid Writ Petition and sought an emergent interim order restraining and prohibiting the Respondents from making any recommendation for appointment of Judges and the Union of India from acting on such recommendations, if any, made.
But, by the impugned order dated 08/04/2016, the learned Single Judge was pleased to decline the ad-interim injunction sought for, as aforesaid. The learned Single Judge in his order did not advert to any of the contentions raised by the Appellant. The learned Single Judge refused to grant the interim injunction sought for on the ground that the Registry has raised some objections as to the maintainability of the Writ Petition.. The Writ Petition, therefore, was not assigned any final registration and since the office objections remained to be cleared, the injunction cannot be granted
The Appellant, therefore, with utmost respect begs to submit that the learned Single Judge failed to apply his judicial mind, still worse, failed to even notice what the contentions of the Appellant are, failed to take notice of the gravity thereof and happened to go at a tangent, misdirecting himself from the real issue, and to render an order declining the interim relief sought for, by offering a reason which is wholly arbitrary in the impugned order which shows total non-application of mind. Hence, the instant writ appeal.
Dated this the 17th day of June 2016
P.BIJIMON
Advocate for the Appellant/Petitioner
BEFORE THE HON’BLE HIGH COURT OF KERALA AT ERNAKULAM
APPEAL NO.__________ OF 2016
(Against the order dated 08/04/2016 passed by the learned Single Judge of this Hon’ble Court in Unnumbered WP 208/2016 declining interim injunction)
Jacob Samuel,S/o.Samuel, aged 47 years
Residing at Kalluvalayathil Puthen veedu,
Thazhakara,P.O,Mavelikara
Alappuzha Dist.-Kerala
Pin 69010 …Appellant/Petitioner
Versus
Union of India,
represented by its Secretary
in the Department of Justice,
New Delhi 110 001.
The Hon'ble Chief Justice of India,
represented by the Registrar General,
Supreme Court of India,
Tilak Marg, New Delhi 110 001.
The Collegium, Supreme Court of India,
Supreme Court of India,
represented by the Registrar General,
Supreme Court of India,
Tilak Marg, New Delhi 110 001.
The Hon'ble Chief Justice,
represented by the Registrar General,
High Court of Kerala,
Ernakulam 682 031.
The Collegium, High Court Of Kerala,
represented by the Registrar General,
High Court of Kerala,
Ernakulam-682 031.
The State of Kerala,
represented by its Chief Secretary,
Trivandrum 695001. ….Respondents/Respondents
Address for service of the Appellant is that of his Counsel Sri P.BIJIMON, 210,2nd Floor,Prasanna Vihar Apartments,near High Court,Kochi-31
Address for service of Respondents is in the above shown addresses of theirs respectively unless engaged by any lawyer.
MEMORANDUM OF APPEAL UNDER SECTION 5 OF THE Kerala high Court act filed by the Appellant through his lawyer sri P.BIJIMON against the order dated 08/04/2016 passed by the learned Single judge in UNNUMBERED writ petition 208/2016 declining interim injunction.
The Appellant, a lawyer primarily practising in the District Court at Mavelikara and other Courts near and around Mavelikara, which are subordinate to the Hon'ble High Court of Kerala and occasionally in the Hon'ble High Court of Kerala, was constrained to institute Unnumbered WP 208/2016 since he bona fide believed that the current collegium system of selection and appointment of judges to the higher judiciary worked out to the great disadvantage of the lawyers practising in the Courts subordinate to the Supreme Court and High Courts. The reasons which made it imperative for the Appellant to say so are many. Briefly stated, they are as follows:-
Even assuming that the collegium system of selection and appointment of judges to the Supreme Court and high Courts is otherwise ideal, it falls short of being the just and fair system inasmuch as in so far as the lawyers, like the Appellant, who practice in the subordinate Courts, the Chief Justice and senior Judges of the Supreme Court/High Courts, who constitute to be the collegium, ordinarily will have no occasion to assess the competence, performance and talents of the lawyers who practice in the subordinate Courts who are equally competent and talented as lawyers practising exclusively in the higher Courts because the former seldom appear before the superior Courts, with the result that their skill, competence, suitability and desirability to be elevated as a Judge of the Supreme Court or High Court are never assessed. The collegium system, an offspring of the judgments in Judges-2 and Judges-3 cases, meant rewriting of the Constitution, though no such jurisdiction is vested in the Supreme Court. Time and experience, the greatest teacher, proved that the collegium system is wholly defective. The Parliament, which is the voice of the people, the supreme legislature, therefore, enacted the Constitution (Ninety-ninth Amendment) Act, 2014 and the National Judicial Appointment Commission Act, 2014 (the Acts, for short) to remedy the deficiency which it took notice of. However, by its judgment dated 16th October, 2015 in Judges-5 case (not Judges-4 case), namely, Supreme Court Advocates-on-Record Association and another v. Union of India & Ors. [Writ Petition (Civil) No.13 of 2015 and others] popularly known as the NJAC case, a Five-Judge Constitution Bench of the Supreme Court struck down as unconstitutional the said Acts. The Supreme Court happened to “quash” the said Acts only because the learned Attorney General failed, if not refused, to bring to the notice of the Constitution Bench and the public domain that the said Acts being legislations in the domain of executive policy involving no violation of anybody’s fundamental rights are not even justiciable. The judgments in Judges-2 and Judges-3 cases also happened to be rendered only because the then Attorney General/counsel representing the Union of India/State Governments failed to point out that the said writ petitions were not maintainable inasmuch as no petition under Article 32 of the Constitution would lie, no matter what terminology is employed, whether writ petition or PIL, unless there is violation of anybody’s fundamental right.
It is a fundamental principle of law that if a judgment of a Court, even of the Full Court of the Supreme Court, is one rendered without jurisdiction, it is void ab initio. The judgments in Judges-2, Judges-3 and the NJAC cases are, therefore, rendered void ab initio. Though the plea, as aforesaid, that the judgments in Judges-2, Judges-3 and the NJAC cases are void ab initio and they could be declared as unconstitutional by a learned Single Judge of this Hon'ble Court or by a Civil Court is wholly unthinkable, in so long as the doctrine of nullity, a concept of universal jurisprudence/ acceptance, time immemorial, is the foundation on which the concept of rule of law is built, the Appellant is well within his right to plead so. In support of his said proposition, the Appellant begs to rely on, among others, the judgments in T.C. Basappa v. T. Nagappa, AIR 1954 SC 440, A.R. Antulay v. R.S. Nayak, (1988) 2 SCC 602,NawabkhanAbbhaskhan Kasab v. State of Gujarat, AIR1974SC1471.
Even assuming that the judgments in Judges-2, Judges-3 and the NJAC cases are rendered per incuriam, then also no appointment of Judges could have been made on the recommendation of the collegium of the Supreme Court/High Court till the collegium system is improved in terms of the directions/observations contained in the judgment of the Supreme Court in the order dated 16/12/2015 in the NJAC case and a new Memorandum of Procedure for appointment of Judges is drawn up which will ensure a just and fair method of selection and appointment of judges to the higher judiciary. A copy of the order dated 16/12/2015 is produced as Exhibit P-1. The new Memorandum of Procedure for appointment of Judges, which the Constitution Bench in the NJAC case had directed the Government of India to draft in consultation with the Hon'ble Chief Justice of India/collegium, is yet to be done/notified to the public at large. However, apparently since appointments to the Supreme Court and High Courts were held up since the NJAC Act was notified, the collegium of the Supreme Court/High Courts had made number of recommendations for appointments of Judges. It was in the above circumstances that the Appellant instituted the aforesaid Writ Petition and sought an emergent interim order restraining and prohibiting the Respondents from making any recommendation for appointment of Judges and the Union of India from acting on such recommendations, if any, made. A copy of the Writ Petition so instituted is produced as Exhibit P-2.
By the impugned order the learned Single Judge was pleased to decline the ad-interim injunction sought for, as aforesaid. The learned Single Judge in his order did not advert to any of the contentions raised by the Appellant. The learned Single Judge refused to grant the interim injunction sought for on the ground that the Registry has raised some objections as to the maintainability of the Writ Petition.. The Writ Petition, therefore, was not assigned any final registration and since the office objections remained to be cleared, the injunction cannot be granted. The copy of impugned order dated 08/04/2016 passed by the learned Single Judge of this Hon’ble Court in Unnumbered WP 208/2016 declining interim injunction is produced herewith and marked as Exhibit P-3.
The Appellant begs to submit with utmost respect that the reason so offered by the learned Single Judge is an affront to reason, logic and law, if not ex facie perverse. The learned Single Judge ought to have noticed the plea of the Appellant that the office objections, which are ministerial in nature, are capable of being cured by the Appellant and that they are objections which are in the realm of the very jurisdiction of the Court to grant the relief sought for. The Registry had taken the plea that no declaration as sought for in the Writ Petition that the judgments of the Supreme Court are rendered per incuriam or a mandamus cannot be granted are not objections which the Registry could have raised and determined, but are pure questions of law concerning interpretation of the Constitution and the law of the land. The Appellant, therefore, with utmost respect begs to submit that the learned Single Judge failed to apply his judicial mind, still worse, failed to even notice what the contentions of the Appellant are, failed to take notice of the gravity thereof and happened to go at a tangent, misdirecting himself from the real issue, and to render an order declining the interim relief sought for, by offering a reason which is wholly arbitrary in the impugned order which shows total non-application of mind. Hence, the instant appeal.
GROUNDS
Grounds in support of the reliefs sought for herein are fairly elaborated in the statement of facts in paragraphs Nos.1 to 5 above and the Appellant respectfully submits that the same may be read and treated as the grounds in support of the instant appeal. Nonetheless, the Appellant begs to briefly add further that
the impugned order passed by the learned Single Judge is a cryptic and non-speaking one and the same is vitiated by manifest non-application of mind;
the impugned order is bad in law inasmuch as the learned Single Judge has failed to take notice, even briefly, what the contentions of the Appellant are. The Appellant’s plea while pressing for an interim injunction was that great prejudice and injustice could be caused to him and the public unless the Respondents/collegium/Union of India are restrained and prohibited from selecting/recommending candidates for appointment as Judges of the Supreme Court/High Courts without putting in place a just and fair mechanism of selection and appointment of Judges, of which the most imperative requirement is to advertise the vacancies, invite applications from all eligible candidates, bring in a just and fair mechanism for scrutinizing the applications, short list the names, call for objections from the public at large, consider those objections and thereafter make recommendations for appointments;
the Appellant maintains that the judgments in Judges-2, Judges-3 and the NJAC cases are rendered per incuriam and in spite of the said judgments the Constitution (Ninety-ninth Amendment) Act, 2014 and the National Judicial Appointment Commission Act, 2014 remain to be the laws of the land. Even assuming that the judgments in the aforesaid cases are rendered per incuriam, which probably is the only view which this Hon'ble Court would take considering the practical realities of the day as Article 141 of the Constitution, which only embodies the principle of stare decisis, is misunderstood to be as one which mandates that the judgments of the Supreme Court are to be treated as the laws of the land, no appointment could have been made unless and until the collegium system is improved in terms of the order dated 16/12/2015 passed by the Supreme Court by redrafting the Memorandum of Procedure for appointment of Judges. As already stated, the learned Single Judge in the impugned order did not notice any of the contentions canvassed by the Appellant in his Writ Petition. Justice, therefore, was denied to him;
The minimum that was expected of the learned Single Judge was to refer briefly to the contentions of the Appellant and offer reasons why they were not found favour with him. The learned Single Judge, the Appellant is afraid to say, also did not in his order notice the explanation offered by the Appellant to the technical objections raised by the Registry on account of which he was pleased to decline the interim injunction. The impugned order, therefore, is in gross violation of the fundamental rights of the Appellant;
The Appellant submits that the error committed by the learned Single Judge is not an error within his jurisdiction which he is free to make, but an error which is of a jurisdictional nature, which has rendered his order void ab initio. The said order is, therefore, liable to be declared as void. This Hon'ble Court being an appellate Court is within its jurisdiction to grant or refuse the relief sought for by the Appellant but after recording the contentions of the Appellant and after offering reasons if they are to be rejected and that is what the concept of due process of law demands as the bare minimum from this Hon'ble Court as the holder of public trust.
THE Appellant, THEREFORE, PRAYS THAT -
this Hon’ble Court be graciously pleased to quash and set aside the order dated 08/04/2016 (Exhibit P-3) passed by the learned Single Judge in Writ Petition Unnumbered 208/2016 declining the interim reliefs sought for and to grant the ad interim reliefs as sought for or be pleased to direct the learned single judge to hear the petitioner afresh and pass a speaking order stating at least in brief what the contentions of the petitioner are and the reasons for which it was found to be not maintainable ;
(b) pass such other and further reliefs in the nature and circumstances of the case may require.
P.BIJIMON
Advocate for the Appellant
V E R I F I C A T I ON
I, Jacob Samuel, S/o Samuel Varghese, aged 47 years, the Appellant herein, residing at Kalluvalayathil Puthen veedu,Thazhakara,P.O,Mavelikara -690102 do hereby verify that what is stated in paragraphs Nos.1 to 6 of the foregoing Memorandum of Appeal is true to my own knowledge and what is stated in the remaining paragraphs are stated on information and belief and I believe the same to be true.
Dated this the 17th day of June 2016.
Deponent: Jacob Samuel
Solemnly affirmed and signed before me by the Deponent, who is personally known to me, on this the 17th day of June, 2016 in my office at Ernakulam.
P.BIJIMON
Advocate for the Appellant
BEFORE THE HON’BLE HIGH COURT OF KERALA AT ERNAKULAM
APPEAL NO.__________ OF 2016
(Against the order dated 08/04/2016 passed by the learned Single Judge of this Hon’ble Court in Unnumbered WP 208/2016 declining interim injunction)
Jacob Samuel … Appellant/Petitioner
Vs.
The Union of India & Ors …. Respondents/Respondents
AFFIDAVIT
I, Jacob Samuel, aged 47 years, S/O Samuel Varghese ,Kalluvalayathil Puthen veedu,Thazhakara,P.O,Mavelikara -690102 do hereby solemnly affirm and state as follows
I am the petitioner in the above writ appeal and I am fully competent to swear the above affidavit.
The above writ appeal is filed against the order dated 08/04/2016 passed by the learned Single Judge of this Hon’ble Court in Unnumbered WP 208/2016 declining interim injunction.
I have not filed any other writ appeal seeking similar relief before this Hon’ble court and the annexures filed along with this writ appeal are true and genuine
All what is stated above are true and correct to the best of my knowledge belief and information
Dated this the 17th day of June 2016
JACOB SAMUEL
Deponent
Solemnly affirmed and signed before me by the deponent who is personally known to me in my office at Ernakulam on this the 16th day of June 2016.
P.BIJIMON
Advocate for the Petitioner
BEFORE THE HON’BLE HIGH COURT OF KERALA AT ERNAKULAM
APPEAL NO.__________ OF 2016
(Against the order dated 08/04/2016 passed by the learned Single Judge of this Hon’ble Court in Unnumbered WP 208/2016 declining interim injunction)
Jacob Samuel … Appellant/Petitioner
Vs.
The Union of India & Ors …. Respondents/Respondents
AFFIDAVIT
I, Jacob Samuel, aged 47 years,S/O Samuel Varghese ,Kalluvalayathil Puthen veedu,Thazhakara,P.O,Mavelikara -690102 do hereby solemnly affirm and state as follows
I am the petitioner in the above writ appeal and I am fully competent to swear the instant affidavit.
The above writ appeal is filed against the order dated 08/04/2016 passed by the learned Single Judge of this Hon’ble Court in Unnumbered WP 208/2016 declining the interim injunction sought for without assigning any valid reason
There happened to be a delay of 33 days in preferring this appeal against the said order which is neither intentional nor deliberate. I lost my mother on 05/05/2016 after prolonged illness.
The above said delay happened in preferring the appeal is liable to be condoned in the interest of justice for it is wholly bonafide lest appellant should be put to irreparable loss, legal injury and hardships.
All what is stated above are true and correct to the best of my knowledge belief and information
Dated this the 17th day of June 2016
Jacob Samuel
Deponent
Solemnly affirmed and signed before me by the deponent who is personally known to me in my office at Ernakulam on this the 17th day of June 2016.
P.BIJIMON
Advocate for the Petitioner
BEFORE THE HON’BLE HIGH COURT OF KERALA AT ERNAKULAM
(Against the order dated 08/04/2016 passed by the learned Single Judge of this Hon’ble Court in Unnumbered WP 208/2016 declining interim injunction)
I.A NO. __________OF 2016
IN
WRIT APPEAL NO.__________ OF 2016
Jacob Samuel,S/o.Samuel, aged 47 years
Residing at Kalluvalayathil Puthen veedu,
Thazhakara,P.O,Mavelikara
Alappuzha Dist.-Kerala
Pin 69010 …Appellant/Petitioner
Versus
Union of India,
represented by its Secretary
in the Department of Justice,
New Delhi 110 001.
The Hon'ble Chief Justice of India,
represented by the Registrar General,
Supreme Court of India,
Tilak Marg, New Delhi 110 001.
The Collegium, Supreme Court of India,
Supreme Court of India,
represented by the Registrar General,
Supreme Court of India,
Tilak Marg, New Delhi 110 001.
The Hon'ble Chief Justice,
represented by the Registrar General,
High Court of Kerala,
Ernakulam 682 031.
The Collegium, High Court Of Kerala,
represented by the Registrar General,
High Court of Kerala,
Ernakulam-682 031.
The State of Kerala,
represented by its Chief Secretary,
Trivandrum 695001. ….Respondents/Respondents
PETITION FILED UNDER SECTION 5 OF THE LIMITATION ACT
For the reasons stated in the accompanying affidavit it is humbly prayed that this Hon’ble Court may be pleased to condone the delay of days in filing the appeal.
Dated this the 17th day of June 2016
P.BIJIMON
Advocate for the Appellant/Petitione
BEFORE THE HON’BLE HIGH COURT OF KERALA AT ERNAKULAM
WRIT APPEAL NO.__________ OF 2016
(Against the order dated 08/04/2016 passed by the learned Single Judge of this Hon’ble Court in Unnumbered WP 208/2016 declining interim injunction)
Jacob Samuel … Appellant/Petitioner
Vs.
The Union of India & Ors …. Respondents/Respondents
AFFIDAVIT
I, Jacob Samuel, aged 47 years,S/O Samuel Varghese ,Kalluvalayathil Puthen veedu,Thazhakara,P.O,Mavelikara -690102 do hereby solemnly affirm and state as follows
I am the petitioner in the above writ appeal and I am fully competent to swear the instant affidavit.
The above unnumbered writ petition is instituted before this Hon’ble court seeking a mandamus against respondents to notify the vacancies of the august offices of the judges of Hon’ble Supreme court and High Courts and to invite application from all eligible candidates.so too reference from all stake holders. There was a reference about the judgment of the Five Judges Constitutional Bench dated 16/10/2015 in SCAORA Vs Union of India and other connected cases popularly known as the NJAC Case.
Since the judgment runs into more than 1000 pages, nay half a million words, I give an undertaking to produce the reported copy of the said judgment in the court at the time of hearing. In the instant writ appeal also there is a reference of the above said NJAC case. To produce a copy of the said judgment running into 1064 pages along with the instant appeal memorandum is too voluminous and unhandy. The cost involved in taking photocopy is also prohibitive.
The said judgment is a reported one. A judgment which is reported is not required to be produced along with a plaint/petition/appeal, need only to be produced at the Bar.
Therefore there is no need to file any petition at all seeking an exemption from production of the said judgment. None the less as a matter of abundance of caution, I am filing the accompanying application for exemption from the production of the copy of the main judgment in the NJAC case and in the interest of justice required that an exemption is needed is granted.
The said judgment could not be produced at the time of filing of the above writ petition. But the production of the above judgment is imperative in this writ appeal for a fair disposal of the matter.
A separate petition is filed herewith for the said purposes.
All what is stated above are true and correct to the best of my knowledge belief and information
Dated this the 20th day of June 2016
Jacob Samuel
Deponent
Solemnly affirmed and signed before me by the deponent who is personally known to me in my office at Ernakulam on this the 20th day of June 2016.
P.BIJIMON
Advocate for the Petitioner
BEFORE THE HON’BLE HIGH COURT OF KERALA AT ERNAKULAM
(Against the order dated 08/04/2016 passed by the learned Single Judge of this Hon’ble Court in Unnumbered WP 208/2016 declining interim injunction)
I.A NO. __________OF 2016
IN
WRIT APPEAL NO.__________ OF 2016
Jacob Samuel,S/o.Samuel, aged 47 years
Residing at Kalluvalayathil Puthen veedu,
Thazhakara,P.O,Mavelikara
Alappuzha Dist.-Kerala
Pin 69010 …Appellant/Petitioner
Versus
Union of India,
represented by its Secretary
in the Department of Justice,
New Delhi 110 001.
The Hon'ble Chief Justice of India,
represented by the Registrar General,
Supreme Court of India,
Tilak Marg, New Delhi 110 001.
The Collegium, Supreme Court of India,
Supreme Court of India,
represented by the Registrar General,
Supreme Court of India,
Tilak Marg, New Delhi 110 001.
The Hon'ble Chief Justice,
represented by the Registrar General,
High Court of Kerala,
Ernakulam 682 031.
The Collegium, High Court Of Kerala,
represented by the Registrar General,
High Court of Kerala,
Ernakulam-682 031.
The State of Kerala,
represented by its Chief Secretary,
Trivandrum 695001. ….Respondents/Respondents
PETITION FILED UNDER RULE 154 OF THE KERALA HIGH COURT RULES AND PRACTICE 2013
For the reasons stated in the accompanying affidavit it is humbly prayed that this Hon’ble Court may be pleased to exempt the appellant from producing the entire copy of the reported judgment of the Hon’ble Supreme Court in SCAORA Vs Union of India in the popular NJAC case and allow the petitioner to produce the reported copy of the same at the Bar, if needed at the time of hearing and allow to accept the same as Annexure A along with this writ appeal.
Dated this the 20th day of June 2016
P.BIJIMON
Advocate for the Appellant/Petitioner
