Search Results

Sat application 2  BEFORE THE HON'BLE STATE ADMINISTRATIVE TRIBUNAL TN AT CHENNAI O. A. No:_____ of 2004 Applicant  Versus Respondents  Application Under Section 19 of the Administrative Tribunals Act, 1985 Chennai Applicant ______ Through, Advocate Respectfully Sheweth: 1. Particulars of the Applicant: As given in the Memo of Parties. 2. Particulars of the Respondents: As given in the Memo of Parties. 3. Impugned Order: That the applicant is aggrieved by the impugned action of the respondents whereby they ______________________. The said impugned action is arbitrary, illegal, malafide, violative of the Constitutional Rights and natural justice and issued in colourable exercise of power 4. Jurisdiction: That the applicant declares that the subject matter is within the jurisdiction of this Hon'ble Tribunal. 5. Limitation: That the applicant further declares that the application is within the limitation. 6. Facts of the Case: (a) That the facts leading to filing of the present case and the relevant facts are furnished hereunder in chronological order for the convenience of this Hon’ble court: - (b) That  GROUNDS (c) That feeling aggrieved by such an arbitrary, malafide, discriminatory and illegal actions of the respondents, the applicant seeks the indulgence of this Hon'ble Tribunal on the following grounds amongst others, which may be taken at the time of arguments, each one of which is without prejudice to and independent of others: - (i) That the impugned action of the respondent is arbitrary, malafide, illegal, ultra vires, against the Article 39 (d) read with 14 and 16 of the Constitution of India, dehors the rules and regulations and against the natural justice. (ii) That ____ 7. Reliefs Sought: That the applicant, therefore, prays that your Lordship be pleased to issue an appropriate writ, orders or directions to grant the following reliefs in favour of the applicant in the interest of justice: - (a) Quash the impugned _________ being arbitrary, malafide and illegal; (b) Direct the respondents to _____; (c) Allow the cost of this O.A.; (d) Pass such other order or directions as deemed fit and proper in favour of the applicant. AND FOR THIS ACT OF KINDNESS, THE HUMBLE APPLICANT AS IN DUTY BOUND, SHALL EVER PRAY. 8. Interim Orders, If Prayed: It is prayed that during the pendency of this OA, the operation of the impugned order A-____ may kindly be stayed in the interest of justice. 9. Details of Remedies Exhausted: That the applicant submits that since the matter being of an urgent nature, there is no other alternative speedy and efficacious remedy available to him except to approach this Hon'ble Tribunal. 10. Matter not Pending with any Other Courts Etc: That the applicant further declares that the matter regarding which this application has been made, is not pending before any court of law or any other Authority or any other bench of this Hon'ble tribunal. 11. Particulars of Court Fees: Court fees worth Rs 50/- is attached herewith. 12. Details of Index: An index containing the details of the documents to be relied upon is enclosed herewith. Chennai Applicant ______ Through, Advocate  BEFORE THE HON'BLE STATE ADMINISTRATIVE TRIBUNAL TN AT CHENNAI O. A. No: _____ of 2004 Applicant  Versus Respondents  Affidavit I,____________________, do hereby solemnly, affirm and declare as under: - 1. That the accompanying O.A. has been prepared under my instructions. 2. That the contents of paras 1 to 12 of the accompanying application are correct and true to the best of my knowledge. 3. That I further solemnly affirm and declare that this affidavit of mine is correct and true to the best of my knowledge and no part of it is false and nothing material has been concealed therein. Affirmed at Chennai this _____. Deponent  BEFORE THE HON'BLE STATE ADMINISTRATIVE TRIBUNAL TN AT CHENNAI Case No:_____ of 2004 Petitioner             VERSUS Respondents  KNOW ALL TO whom these presents shall come that I/We __________________ the above named PETITIONER/RESPONDENT do hereby appoint: - __________________ to be the advocate for the __ PETITIONER/RESPONDENT in the above mentioned case, to be all following acts, deeds and things or any of them that is to say:  1. To act, appear and plead in the above mentioned case in this Court or any Court in which the same may be tried or heard in the first instance or in Appeal or Letters Patent Appeal or Review or Revision or execution or in any other stage of its progress until its final decision.  2. To present Complaints, Pleadings, O.A., M.A. Appeals, Letters Patent Appeals, Petitions for Appeal to High Court/Supreme Court, Cross-objections or Petition for execution, review, revision withdrawal compromise or other petitions or affidavit or other documents as may be deemed necessary or advisable for the prosecution of the said case in all it's stages.  3. To withdraw or compromise the said case or submit to arbitration any difference or disputes that shall arise touching or in any manner relating to the said cause.  4. To receive moneys and grant receipts thereof and to do all other acts and things which may be necessary to be done for the progress and in course of the prosecution of the said case.  5. To employ and instruct any other Legal Practitioner authorizing him to exercise the powers and authorities hereby conferred on the Advocate whenever he may think fit to do so.  AND I/We hereby agree to ratify whatever the advocate or his substitute shall do in the premises.  AND I/We hereby agree not to hold the advocate or his substitute responsible for the result of the said cause in consequence of his absence from the court when the said cause is called up for hearing.  AND I/We hereby agree that in the event of the whole or any part of the fee agreed by me/us to be paid to the advocate remaining unpaid he shall be entitled to withdraw from the prosecution of the said cause until the same is paid.  IN WITNESS WHEREOF I/We here up to set my/our hands to these presents the contents of which have been explained to me/us and understood by me/us the _____  Accepted  Advocate Client Download Word Document In English. (Rs.60/-) Download PDF Document In Marathi. (Rs.60/)

For condonation of delay in filing of ________  BEFORE THE HON'BLE STATE ADMINISTRATIVE TRIBUNAL TN AT COIMBATORE MA No.:______ of 2009 in OA No.:______                                                 Applicants/Non-Applicants                                                                Versus                                                     Respondents/Applicants  Application under Rule 8 (3) of TN Administrative Tribunal Rules for condonation of delay in filing of ________ . Respectfully Sheweth : 1. That the above mentioned OA is filed in this Hon'ble Tribunal by the original applicants. 2. ____________________________ 3. That filing of reply/rejoinder _______________________ is essential for adjudication of the matter in interest of justice. The present applicant could not file the reply/rejoinder ________________ within the stipulated time. 4. It is, therefore, most humbly prayed that the reply/rejoinder ___________________ may kindly be taken on record in the interest of justice. Such other order may also be passed as deemed fit and proper in the facts and circumstances of the case. Coimbatore Applicant ______ Through, Advocate  Verification: I,___________________________, do hereby verify that the contents of paras 1 to 4 of the above application are correct and true and no part of it is false and nothing material has been concealed therein. Verified here at Coimbatore this ______.  BEFORE THE HON'BLE STATE ADMINISTRATIVE TRIBUNAL TN AT COIMBATORE MA No.:______ of  2009 in OA  No.: ______ Applicants Versus Respondents/Applicants Affidavit I,___________________________________, do hereby solemnly affirm and declare as under :- 1. That the accompanying application has been prepared under my instructions. 2. That the contents of paras 1 to 4 of the accompanying application are correct and true to the best of my knowledge. 3. That I further solemnly affirm and declare that this affidavit of mine is correct and true and no part of it is false and nothing material has been concealed therein. Affirmed at Coimbatore this the _______________________ Deponent  Download Word Document In English. (Rs.30/-) Download PDF Document In Marathi. (Rs.30/-)

Sat appoint promotion contact  BEFORE THE HON'BLE TN STATE ADMINISTRATIVE TRIBUNAL AT CHENNAI O. A. NO :______ of 2004 Applicant  Versus Respondents  Application Under Section 19 of the T.N. Administrative Tribunals Act, 1985 Chennai Applicant ______ Through, Advocate Respectfully Sheweth : 1. Particulars of the Applicant: As given in the Memo of Parties. 2. Particulars of the Respondents: As given in the Memo of Parties. 3. Impugned Order: That the applicant is aggrieved by the impugned order issued by the respondents where by they have replaced the services of the applicant as contract teacher by transferring another teacher on promotion vide Annexure A-__________, which is against the decision laid down by the Hon'ble Apex court and this Hon'ble court in catena of cases that the contract teachers can be replaced only by regularly appointed new hands through the Commission against the same vacancy. 4. Jurisdiction: That the applicant declares that the subject matter of the order against which he wants redressal is within the jurisdiction of this Hon'ble Tribunal. 5. Limitation: That the applicant further declares that the application is within the limitation prescribed in section 21 of the Administrative Tribunals Act, 1985. 6. Facts of the Case: (6.1) That the applicant submits that he was initially engaged as a contract teacher against the sanctioned vacant post at Govt. Sr. Sec. School ___________ wef ___________ (A-1). The said contract was valid upto _______________ and renewable on the termination of the said contract. (6.2) That it is submitted that the post against which the applicant was initially engaged is still vacant as no regular hand on fresh appointment through commission has joined as yet. The applicant was working in the winter/summer ___________________ closing school. It is also submitted that the applicant is also not being paid salary for the vacations/holidays/fictional breaks. (6.3) That it is also submitted that the appointment of the applicant against the said post was through a proper procedure and the applicant fulfilled all the conditions and minimum requisite qualification for the said post in accordance with the R&P Rules. The qualification of the applicant is _______________, which is the minimum requisite qualification for the said post. (6.4) That the Full Bench of this Hon'ble Tribunal has adjudicated upon the matter on __________ as regards replacement of the contract teachers in the OA No. ______________ titled as Vijay Shetty Vs State of TN and others and has held as under:- "In view of it we hold that the petitioners are entitled to continue till the time they are replaced by regularly appointed persons in accordance with R&P Rules."(6.5) That the Hon'ble Apex Court in Raj Bala Vs State of Tamil Nadu has also held as under:- "After hearing learned counsel for the parties, we allow the writ petition and direct the respondents to continue the petitioners in service until persons regularly selected by the Punjab Public Service Commission are appointed to the posts presently held by the petitioners and join these posts. These petitioners who have been appointed to posts in leave vacancies will continue in these posts until the employees who have proceeded on leave return and join these posts. We dispose of this writ petition by ordering that subject to one clarification that State of Punjab would not be permitted to terminate the services of any of the petitioners by transferring a regular recruit from another institution to any institution where any of the petitioners may be serving. Termination would be had only when direct recruits through the Public Service Commission are recruited to such posts." (6.6) That _____                                                                                Grounds  (6.7) That feeling aggrieved by such an arbitrary, malafide, discriminatory and illegal actions of the respondents, the applicant seeks the indulgence of this Hon'ble Tribunal on the following grounds amongst others, which may be taken at the time of arguments, each one of which is without prejudice to and independent of others :- (a) That the impugned order of the respondent whereby they have terminated the services of the applicant by transferring a teacher on promotion against the applicant wef __ and not permitting the applicant to continue till the regular hand comes on fresh appointment through the HP State Public Service Commission is arbitrary, malafide, illegal, ultra vires, against the Articles 14 and 16 of the Constitution of India, dehors the rules and regulations and against the natural justice.  (b) That the applicant was appointed against the permanent sanctioned post which is still vacant. The applicant was discharging his duties to the entire satisfaction of his superiors, students and public men.  (c) That the applicant was made to sign a contract on the dotted lines. The applicant who is highly qualified man and facing grave financial problem had no option but to sign the one-sided contract in obedience to the command given to him in the appointment letter/Contract, with the underlying threat of loosing the job in case he had not signed on the dotted lines. Thus the respondent exerted undue influence on the applicant to sign the contract on the dotted line and is thus violative of the law. The applicant was not in a position to bargain against the respondent state which is far mightier than an unemployed applicant and in a position to dictate its unconscionable terms on the applicant. But the applicant bonafidely believed that no undue advantage will be taken of signing the one-sided contract and he will be allowed to continue and regularized in due course of time. Moreover, the format prescribed by the respondents is not sustainable in the eyes of law and is against the well settled principles of law.  (d) That it is submitted hat there is a vast difference in the bargaining power of the applicant as compared to the respondents. The applicant being an un-employed and desperate youth could not have been subjected to such unconscionable conditions of terminating his services at the whims. Unconscionable conditions confounded in dotted line agreement/contracts cannot be enforced against the weaker party, ie the applicant. This proposition of the law has been settled by the Hon'ble Apex Court and this Hon'ble Court in catena of cases. Such a practice is reminiscent of an archaic practice of "Hire and Fire", which is highly reprehensible and condemnable and has been deprecated by the Hon'ble Supreme Court and this Hon'ble Court.  (e) That it is also a settled law that beginning of service in the government is contractual but thereafter the appointee acquires status and his rights are no longer determined by the contract of the parties. Moreover, offering a job on contract is an indigenous device adopted by the respondents to out reach the law laid down in this regard and to deprive the incumbents from claiming regularization and other benefits which would accrue to him with the efflux of time. Moreover, the Personal Hand Book vide chapter 16.35 specifically provides that all other appointments made dehors R & P Rules will be treated as abhor appointments.  (f) That the applicant is also entitled for the salary for the winter/summer vacations and holidays at par with the regular hands on the same and similar post.  (g) That the impugned order has been issued without assigning any reasons and is non-speaking order. Thus, it is clearly indicative of the arbitrariness of the respondent's action. The impugned order is null and void.  (h) That the respondents are estopped due to their own act, deed and conduct. The principle of the Promissory Estopple applies against the respondents.  (i) That the impugned order is against the well settled principles of the law as laid down by the Hon'ble Supreme Court and this Hon'ble Tribunal in catena of cases. 7. Reliefs Sought: That the applicant, therefore, prays that your Lordship be pleased to issue an appropriate writ, orders or directions to grant the following reliefs in favour of the applicant in the interest of justice:- (a) Quash the impugned action of the respondents whereby they have terminated the services of the applicant by transferring a teacher on promotion against the post of the applicant wef __ and not permitting the applicant to continue in service till the regular hand joins on fresh appointment through TN State Public Service Commission, being arbitrary, malafide and illegal;  (b) Direct the respondents not to give notional/fictional breaks to the applicant for the period(s) of summer/winter vacations and other holidays and the applicant may be held to be entitled to arrears for the period of winter/summer vacations and holidays;  (c) Direct the respondents to re-engage the applicant at the same place against the same post with immediate effect with all the consequential benefits and protect the seniority etc of the applicant;  (d) Direct the respondents to produce all the relevant documents along with their reply for perusal by this Hon'ble Tribunal;  (e) Allow the cost of this O.A.;  (f) Pass such other order or directions as deemed fit and proper in favour of the applicant. AND FOR THIS ACT OF KINDNESS, THE HUMBLE APPLICANT AS IN DUTY BOUND, SHALL EVER PRAY. 8. Interim Orders, If Prayed: It is prayed that during the pendency of OA the impugned order/action of the respondents be stayed and the respondents may be ordered to re-engage the applicant at the same place against same post and pay the salary for the vacation period to the applicant. 9. Details of Remedies Exhausted: That the applicant submits that since the matter being of an urgent nature, there is no other alternative speedy and efficacious remedy available to him except to approach this Hon'ble Tribunal. 10. Matter not Pending With any other Courts etc. That the applicant further declares that the matter regarding which this application has been made, is not pending before any court of law or any other Authority or any other bench of this Hon'ble tribunal. 11. Particulars of Court Fees: Court fees worth Rs 50/- is attached herewith. 12. Details of Index: An index containing the details of the documents to be relied upon is enclosed herewith. Chennai Applicant ______ Through, Advocate BEFORE THE HON'BLE TN STATE ADMINISTRATIVE TRIBUNAL AT CHENNAI O. A. No.______ of 2004 Applicant  Versus Respondents  Affidavit I,____________________________, do hereby solemnly, affirm and declare as under :- 1. That the accompanying O.A. has been prepared under my instructions. 2. That the contents of paras 1 to 12 of the accompanying application are correct and true to the best of my knowledge. 3. That I further solemnly affirm and declare that this affidavit of mine is correct and true to the best of my knowledge and no part of it is false and nothing material has been concealed therein. Affirmed at Chennai this ________________________.  Download Word Document In English. (Rs.60/-) Download PDF Document In Marathi. (Rs.60/-)

Cat Application early hearing  BEFORE THE HON'BLE CENTRAL ADMINISTRATIVE TRIBUNAL TN AT CHENNAI MA No._______________ in OA No.: ___________________  Applicant  Versus Respondents  Reply to MA Respectfully  Sheweth: Preliminary Submissions/Objections: 1. That the present MA is not maintainable at all.  Reply on Merits: 1. That the contents of this para of MA are wrong and denied.  2. That the contents of this para of MA are wrong and denied.  3. That the contents of this para of MA are wrong and denied.  4. That the contents of this para of MA are wrong and denied.  5. That the contents of this para of MA are wrong and denied.  6. That the contents of this para of MA are wrong and denied.  7. That the contents of this para of MA are wrong and denied.  8. That the contents of this para of MA are wrong and denied.  9. That the contents of this para of MA are wrong and denied.   Chennai  Replying Respondent No.   ____ Through, Advocate  BEFORE THE HON'BLE CENTRAL ADMINISTRATIVE TRIBUNAL TN AT CHENNAI MA No.: ______ in OA No: ______ Applicant  Versus Respondents  Affidavit  I,______________________________________, do hereby solemnly affirm and declare as under :- 1. That the accompanying reply has been prepared under my instructions. 2. That the contents of paras 1 to______________of the Preliminary submission and paras 1 to _____________________of the reply on merits are correct and true to the best of my knowledge. 3. That I further solemnly affirm and declare that this affidavit of mine is true, no part of it is false and nothing material has been concealed therein. Affirmed at Chennai this the ___________________. Deponent  Download Word Document In English. (Rs.20/-) Download PDF Document In Marathi. (Rs.20/-)

Sat appointment interview only  to employment exchange  BEFORE THE HON'BLE TN STATE ADMINISTRATIVE TRIBUNAL AT CHENNAI OA No:_____ of 2004 Applicant  Versus Respondents  Application Under Section 19 of the TN Administrative Tribunals Act, 1985 Chennai Applicant _____ Through, Advocate Respectfully Sheweth : 1. Particulars of the Applicant: As given in the Memo of Parties. 2. Particulars of the Respondents: As given in the Memo of Parties. 3. Impugned Order: That the applicant is aggrieved by the impugned action of the respondents whereby they are not permitting the applicant to appear in the interview to be held on for the post of and the applicant is also aggrieved by the action of the respondent Employment Exchange whereby they have not sponsored the name of the applicant for the above post despite the fact that juniors to the applicant have been sponsored. The said impugned action is arbitrary, illegal, malafide, violative of the Articles 14 and 16 of the Constitutional Rights and natural justice and issued in colourable exercise of power. 4. Jurisdiction: That the applicant declares that the subject matter is within the jurisdiction of this Hon'ble Tribunal. 5. Limitation: That the applicant further declares that the application is within the limitation. 6. Facts of the Case: 1. That the applicant submits that ____  GROUNDS 2. That feeling aggrieved by such an arbitrary, malafide, discriminatory and illegal actions of the respondents, the applicant seeks the indulgence of this Hon'ble Tribunal on the following grounds amongst others, which may be taken at the time of arguments, each one of which is without prejudice to and independent of others :- (a) That the impugned action of the respondents whereby they are not permitting the applicant to appear in the said interview is arbitrary, malafide, illegal, ultra vires, against the Articles 14 and 16 of the Constitution of India, dehors the rules and regulations and against the natural justice.  (b) That the impugned action of the respondents whereby they are not permitting the applicant to appear in the said interview is against the well settled law by the Hon'ble Supreme Court in Excise Superintendent Malkapatnam Krishna District Vs KBN Visweshwara Rao and others, wherein the Hon'ble court has held that "restricting the selection only to the candidates sponsored by employment exchange is not proper and in addition to requisitioning the names from employment exchange, names should also be called for by publication in newspapers, having wide circulation and display on office notice boards or announcement on radio, Television and employment news bulletins. Such a procedure would subserve fair play envisaged by the Articles 14 and 16 of the Constitution of India.  (c) That the respondents are estopped due to their own act, deed and conduct. The principle of the Promissory Estopple applies against the respondents.  (d) That the impugned order is against the well settled principles of the law as laid down by the Hon'ble Supreme Court and this Hon'ble Tribunal in catena of cases. 7. Reliefs Sought: That the applicant, therefore, prays that your Lordship be pleased to issue an appropriate writ, orders or directions to grant the following reliefs in favour of the applicant in the interest of justice:- (a) Quash the impugned action of the respondents whereby they have not sent interview call letters to the applicant arbitrarily, malafidely and illegally; (b) Direct the respondents to permit the applicant to appear in the said interview;  (c) Direct the respondents to produce all the relevant documents along with their reply for perusal by this Hon'ble Tribunal;  (d) Allow the cost of this OA;  (e) Pass such other order or directions as deemed fit and proper in favour of the applicant. AND FOR THIS ACT OF KINDNESS, THE HUMBLE APPLICANT AS IN DUTY BOUND, SHALL EVER PRAY. 8. Interim Orders, If Prayed: It is most respectfully prayed that the said interview being held by the respondents on _____ may kindly be stayed during the pendency of this OA or in the alternative the respondents may kindly be directed to permit the applicant to appear in the said interview provisionally in the meantime. 9. Details of Remedies Exhausted: That the applicant submits that since the matter being of an urgent nature, there is no other alternative speedy and efficacious remedy available to him except to approach this Hon'ble Tribunal. 10. Matter not Pending with any Other Courts Etc: That the applicant further declares that the matter regarding which this application has been made, is not pending before any court of law or any other Authority or any other bench of this Hon'ble tribunal. 11. Particulars of Court Fees: Court fees worth Rs 50/- is attached herewith. 12. Details of Index: An index containing the details of the documents to be relied upon is enclosed herewith. Chennai Applicant _____ Through, Advocate  BEFORE THE HON'BLE TN STATE ADMINISTRATIVE TRIBUNAL AT CHENNAI OA No:_____ of 2004 Applicant  Versus Respondents  Affidavit  I,__________________, do hereby solemnly, affirm and declare as under :- 1. That the accompanying O.A. has been prepared under my instructions. 2. That the contents of paras 1 to 12 of the accompanying application are correct and true to the best of my knowledge. 3. That I further solemnly affirm and declare that this affidavit of mine is correct and true to the best of my knowledge and no part of it is false and nothing material has been concealed therein. Affirmed at Chennai this the ______. Deponent  Download Word Document In English. (Rs.50/-) Download PDF Document In Marathi. (Rs.50/-)

Condonation of delay in filing of OA.  BEFORE THE HON'BLE STATE ADMINISTRATIVE TRIBUNAL TN AT COIMBATORE MA No.______ of  2009 in OA No.:________ of  2009                                             Applicant                                               Versus                       Respondents/Non-Applicants  Application under Section 21 (3) of the Administrative Tribunals Act condonation of delay in filing of OA. Respectfully  Sheweth :  1. That the above mentioned OA is filed in this Hon'ble Tribunal by the original applicant. 2. That on perusal of the contents of OA, its grounds and the documents annexed therewith it is evident that the applicant has a plausible case in his favour and the balance of convenience is also in favour of the applicant. The OA is likely to succeed. 3. That however, there has been delay in filing the OA due to the reasons _______________. But for these good and sufficient reasons, the applicant would have come before this Hon'ble Tribunal within the stipulated time. However, it is submitted that the applicant stands to gain nothing by delaying the matter. No harm or prejudice will be caused to the respondent if the delay in filing the OA is condoned in the interest of justice.  4. It is, therefore, most humbly prayed that the present application may kindly be allowed and the delay in filing the OA may kindly be condoned in the interest of justice. Such other order may also be passed as deemed fit and proper in the facts and circumstances of the case. Coimbatore Applicant ______ Through, Advocate  BEFORE THE HON'BLE STATE ADMINISTRATIVE TRIBUNAL TN AT COIMBATORE MA No.______ of  2009 in OA No.______ of  2009                                          Applicant                                             Versus                                      Respondents  Affidavit  I,_________________________________, do hereby solemnly affirm and declare as under:-  1. That the accompanying application has been prepared under my instructions.  2. That the contents of paras 1 to _______ of the accompanying application are correct and true to the best of my knowledge.  3. That I further solemnly affirm and declare that this affidavit of mine is correct and true and no part of it is false and nothing material has been concealed therein. Affirmed at Coimbatore this  the _____________________________. Deponent  Download Word Document In English. (Rs.30/-) Download PDF Document In Marathi. (Rs.30/-)

SALE TO TWO PERSONS PAYING EQUALLY  Sale deed made this _______ day of _______ 20______,  by AA., son of _________________________ of ___________ (Vendor) of the one part,  in favour of BB. son of _____________________ of ____________________ and CC, son of _______________________, of ___________________(Purchasers) of the other part: WHEREAS the said AA. being now absolutely entitled free from encumbrances to the premises hereinafter described had agreed/is agreeable to sell the same to the said BB. and CC. absolutely and free from encumbrances for the sum of Rs__________ (in words, rupees _______________________________) : NOW THIS INDENTURE WITNESSES that in consideration of the sum of Rs_____________ (in words, rupees ____________________________ ), now paid by the said BB. and CC. in equal shares from and out of the moneys belonging to them (the receipt of which sum the said AA. hereby acknowledge) he, the said AA., hereby sells and conveys to the said BB. and CC. all that house with land No__________ situate at __________________ Road in the city of ______________________ in the District of _______. (with the boundaries thereof more particularly described in the Schedule hereto): To hold the same and to the use of the said BB. and CC. as tenants-in-common in equal shares forever. The Schedule above referred to  Description of the Property hereby sold.  All that house with land measuring __________________ together with all the buildings thereon and the appurtenances, fixtures and fittings thereto bearing municipal number _______ of _______ /Road/Mohalla/in the town of _______ and bounded as follows: On the North by _______  On the East by _______  On the South by _______  On the West by _______  IN WITNESS WHEREOF the above named AA. has executed this instrument on the date first hereinabove mentioned. Sd. AA.  Vendor. Witnesses:  1 _______  2 _______  Download Word Document In English. (Rs.20/-) Download PDF Document In Marathi. (Rs.20/-)

Cat reply  BEFORE THE HON'BLE CENTRAL ADMINISTRATIVE TRIBUNAL TN AT CHENNAI O. A. No: _______ Applicant  Versus Respondents  Reply on behalf of the Replying Respondent Nos._______ Respectfully  Sheweth: PRELIMINARY OBJECTIONS/SUBMISSIONS 1. That the _______ REPLY ON MERITS:  1. That the contents of this para of OA are wrong and denied. 2. Calls for no reply.  3. Calls for no reply.  4. That the contents of this para of OA are wrong and denied.4.1 That the contents of this para of OA are wrong and denied.4.2 That the contents of this para of OA are wrong and denied.4.3 That the contents of this para of OA are wrong and denied. 4.4 That the contents of this para of OA are wrong and denied.4.5 That the contents of this para of OA are wrong and denied.4.6 That the contents of this para of OA are wrong and denied. 4.7 That the contents of this para of OA are wrong and denied.4.8 That the contents of this para of OA are wrong and denied. 4.9 That the contents of this para of OA are wrong and denied. 4.10 That the contents of this para of OA are wrong and denied. 4.11 That the contents of this para of OA are wrong and denied. 4.12 That the contents of this para of OA are wrong and denied.  5. That the contents of this para of OA are wrong and denied. 6. That the contents of this para of OA are wrong and denied. The applicant has not exhausted all the remedies available to him  7. That the contents of this para of OA are wrong and denied.  8. That the contents of this para of OA are wrong and denied. 9. That the contents of this para of OA are wrong and denied. It is submitted that the applicant has obtained ex-parte interim orders from this Hon’ble Tribunal by suppression of material facts. As such the interim orders passed by this Hon’ble Tribunal on deserves to be vacated in the interest of justice and may kindly be vacated.  10. Calls for no reply.  11. Calls for no reply.  12. Calls for no reply. It is, therefore, most respectfully prayed that the OA is false, frivolous and vexatious and bereft of merits and therefore the same deserves to be dismissed and may kindly be dismissed with cost in the interest of justice. Chennai Applicant  ____ Through, Advocate  BEFORE THE HON'BLE CENTRAL ADMINISTRATIVE TRIBUNAL TN AT CHENNAI O. A. No.: ______ Applicant  Versus Respondent  Affidavit  I,______________________________, do hereby solemnly affirm and declare as under :- 1. That the accompanying reply has been prepared under my instructions. 2. That the contents of paras 1 to of the preliminary objections and paras 1 to 12 of reply on merits are correct and true to the best of my knowledge. 3. That I further solemnly affirm and declare that this affidavit of mine is correct and true, no part of it is false and nothing material has been concealed therein. Affirmed at Chennai this the ____. Deponent  BEFORE THE HON'BLE CENTRAL ADMINISTRATIVE TRIBUNAL TN AT CHENNAI M. A. No.: ______of ______ in O. A. No.: ______ Applicant  Versus Respondent  Application under Rule 4 [4] of Administrative Tribunal Rules for condonation of delay in filing the reply. Respectfully  Sheweth :-  1. That the applicant has filed above O. A. in this Hon'ble Tribunal.  2. That this Hon'ble court was pleased to grant time to file the reply. However, the respondent could not file the reply within the stipulated period as the respondent had to collect certain information/records. The delay in filing the reply is neither intentional nor willful.  3. It is, therefore, most respectfully prayed that this application may be allowed and the delay in filing the reply may kindly be condoned and the reply filed along with be allowed to be placed on record in the interest of justice. Such other orders be also passed in favour of the applicant as deemed fit and proper in the facts and circumstances of the case. Chennai Applicant ______ Through, Advocate  BEFORE THE HON'BLE CENTRAL ADMINISTRATIVE TRIBUNAL TN AT CHENNAI M. A. No.: ______of ______in O. A. No.: ______ Applicant  Versus Respondent  Affidavit. I,_______________________________________, do hereby solemnly affirm and declare as under :- 1. That the accompanying application has been prepared under my instructions.  2. That the contents of paras 1 to 3 of the accompanying application are correct and true to the best of my knowledge.  3. That I further solemnly affirm and declare that this affidavit of mine is correct and true, no part of it is false and nothing material has been concealed therein. Affirmed at Chennai this the ______. Deponent  Download Word Document In English. (Rs.50/-) Download PDF Document In Marathi. (Rs.50/-)

Application sat reply  BEFORE THE HON'BLE STATE ADMINISTRATIVE TRIBUNAL TN AT CHENNAI MA No. _______ in OA No. ______ Applicants  Versus Respondents/Non-Applicants  Reply to the Application under Rule 8 (3) of TN Administrative Tribunal Rules filed by the applicant Respectfully Sheweth : Preliminary Objections/Submissions: 1. That the present application is misconceived and is not maintainable at all. ____________ Reply on Merits: 1. That the contents of para 1 of the application as stated are wrong and denied. ____ _____2. That the contents of para 2 of the application as stated are wrong and denied. __________3. That the contents of para 3 of the application as stated are wrong and denied. ___ ______4. That the contents of para 4 of the application as stated are wrong and denied. ____ _____5. That the contents of para 5 of the application as stated are wrong and denied. ____ ______6. That the contents of para 6 of the application as stated are wrong and denied. ____ ______7. It is, therefore, most humbly prayed that this application is mis-conceived and deserves to be dismissed and may be dismissed in the interest of justice. Such other order may also be passed as deemed fit and proper in the facts and circumstances of the case. Chennai Replying  Respondent No. _____ ________________Through, Advocate  Verification: I____________________, do hereby verify that the contents of paras 1 to ______ of Preliminary Submissions and paras 1 to __________ of the reply on merit to the MA are correct and true and no part of it is false and nothing material has been concealed therein. Verified here at Chennai this ______________.  BEFORE THE HON'BLE STATE ADMINISTRATIVE TRIBUNAL TN AT CHENNAI MA No.: ______ in OA No.: ______ Applicants  Versus Respondents/Non-Applicants  Affidavit I,___________________________, do hereby solemnly affirm and declare as under :- 1. That the accompanying reply to the application has been prepared under my instructions. 2. That the contents of paras 1 to __________ of Preliminary Objections/Submissions and paras 1 to __________ of the reply on merit of the accompanying reply to the application are correct and true to the best of my knowledge. 3. That I further solemnly affirm and declare that this affidavit of mine is correct and true and no part of it is false and nothing material has been concealed therein. Affirmed at Chennai this the ______________ Deponent  Download Word Document In English. (Rs.30/-) Download PDF Document In Marathi. (Rs.30/-)

DEED OF SALE BY CO-OWNERS OF UNDIVIDED PROPERTY  THIS DEED OF VENDING IS MADE on. ............ day of ..................,  BETWEEN A, son of ………………………………………………..……............... resident at ...…………………........................................................... and C, son of …………………………….................................................  resident at .................................................................................. after it referred to as the sellers (which term shall include their successors, heirs and legal representatives) of the one part  and  E, son of ................................................................................  resident at ...................................................................................... after it referred to as the buyer (which term shall include his heirs, nominees and assignees) of the other part. Whereas one P late of, etc. who was a Hindu ruled by the -………………………………………………. School of Hindu Law expired on the .............. day of. ....................intestate, leaving him living only two sons i.e., the said A and C as his successors and legal representatives per said school and whereas the said P left inter alia the following estate as portion of his property and whereas the estate of the said P has been fully administered and whereas the said A and C are possessing/enjoying the property jointly hereinafter stated as co-owners with equated shares without effecting any division/partition thereof and whereas the said A and C have consented to vend the said properties free from all encumbrances, to the said E for the sum of Rs............................ Now this deed witnesses that in pursuance of the said covenant and in consideration of Rupees ............................................... paid to the said A and C by said E at or at once prior execution of these presents the receipt whereof the said A and C hereby acknowledge, admit and confirm, they, the said A and C and every being beneficial owner of one equal undivided moiety thereof do hereby and hereunder grant, convey, vend, transfer, assign and assure unto and to the use the said E all that, etc. parcel etc., as in a conveyance): To hold and have the same unto and to the use of the said E, his successors, executors, administrators, agent and assigns completely and for good. and the seller doth hereby agree with the buyer that despite any deed, act, matter or thing whatsoever by the seller or any person lawfully or equitably claiming by, from, through, under or in trust for the seller, done, made committed or omitted or knowingly sustained the contrary the seller hath the rightful/complete power and authority to convey, grant and assure the said premises hereby convey/assure the said premises hereby and assure and intended so to be unto and the use of the buyer in the way aforesaid and it shall be legal for the buyer from time being and at all times after it and quietly peaceably to enter upon enjoy and possess the said premises stated in the Schedule hereunder written and to receive all rents issues/profits thereof and of every portion thereof to and for the buyer’s own use with benefit without any suit legal eviction interruption claim or demand whatsoever for or by the seller or any person legally or equitably claiming or to claim by, under or in trust for seller and that clear and free and clearly and freely and completely acquitted exonerated and forever discharged or otherwise by the seller well and sufficiently saved, defended and kept harmless and compensated of from and against all former/other properties titles charges and all encumbrances whatsoever had made executed occasioned or sustained by the seller or any other person legally or equitably claiming or to claim by from under or in trust for seller and also that the seller and all persons having or legally or equitably claiming any property or interest whatsoever in the said premises or any of them or any portion thereof from under or in trust for the seller shall and will from time to time and at all times hereafter at the request/costs of the buyer do and execute or cause to be done and executed all such further and other legal reasoned acts, deeds, things and assurances in the said land and heredity property and premises whatsoever for the better and more perfectly assuring the said premises stated in the Schedule hereunder written and for every portion thereof unto and to the buyer in the way aforesaid as by the buyer shall be reasonably required. The Schedule above referred to  In witness whereof the parties herein have executed these presents on the day, month and year first above-written. Signed, sealed and delivered by the within-stated seller in the presence of:  Signed, sealed and delivered by the within-stated buyer in the presence of:  MEMO OF CONSIDERATION  Received of and from the within-named buyer the sum of Rs. ............... (Rupees .,.............................................) being the full consideration stated above by Bank Draft No. ................ dated .............. for Rs................... on X Bank Ltd., Calcutta Branch. witness Received Signature  Download Word Document In English. (Rs.30/-) Download PDF Document In Marathi. (Rs.30/-)

Sat appoint anganwadi selection not as per rules  BEFORE THE HON'BLE TN STATE ADMINISTRATIVE TRIBUNAL AT CHENNAI OA No.:______ of 2004 Applicant  Versus Respondents  Application Under Section 19 of the Administrative Tribunals Act, 1985 Chennai Applicant ______ Through, Advocate Respectfully Sheweth :  1. Particulars of the Applicant As given in the Memo of Parties.  2. Particulars of the Respondents As given in the Memo of Parties.  3. Impugned Order: That the applicant is aggrieved by the impugned order issued by the respondents  4. Jurisdiction That the applicant declares that the subject matter is within the jurisdiction of this Hon'ble Tribunal.  5. Limitation: That the applicant further declares that the application is within the limitation.  6. Facts of the Case: 6.1 That the applicant submits that ____ 6.2 That the respondent department while calling the applicant for interview has sought for the following documents, which were duly produced by the applicant:-(i) School Certificates (For Educational qualifications) (ii) Certificate of permanent residence of ____________,  (iii) IRDP Certificate  (iv) Certificate indicating that the applicant belonged to the same village and distance certificate  (v) Affidavit indicating that there is none in the Govt / Semi-govt service from the family of the applicant.  (vi) Certificate of Caste/Tribe.  (vii) Experience Certificate of any type. 6.3 That _____ GROUNDS 6.4 That feeling aggrieved by such an arbitrary, malafide, discriminatory and illegal actions of the respondents, the applicant seeks the indulgence of this Hon'ble Tribunal on the following grounds amongst others, which may be taken at the time of arguments, each one of which is without prejudice to and independent of others :-  (a) That the impugned order A-_______ issued by the respondent is arbitrary, malafide, illegal, ultra vires, against the Articles 14 and 16 of the Constitution of India, dehors the rules and regulations and against the natural justice.  (b) That the respondent state has formulated guidelines on ______ for selection/appointment of Anganwadi Workers under Integrated Child Development Scheme Programmer in pursuance to Civil Review Petition No. ______ in CWP No. ______ of ______ filed by ______ dated ______ as under:-  (i) Specific guidelines for selection/appointment be formulated which interalia, should contain specific guidelines for awarding head wise marks, ie; for Educational Qualifications, Experience etc by the Selection Committees as also specifying the authority by whom relaxation, if any, can be given.  (ii) The Selection Committee should be chaired by the representative of the Director of Welfare, who should be from outside of the ICDS Project area.  (iii) The Selection made by the Selection Committee should be monitored at the Directorate level with a view to ensuring that the selection is made in accordance with the law/guidelines.  (c) That the respondent department has not conducted selection in consonance with the above guidelines.  (d) That the respondent department while calling the applicant for interview has sought for the following documents, which were duly produced by the applicant:- (i) School Certificates (For Educational qualifications)  (ii) Certificate of permanent residence of ______,  (iii) IRDP Certificate  (iv) Certificate indicating that the applicant belonged to the same village and distance certificate  (v) Affidavit indicating that there is none in the Govt/Semi-govt service from the family of the applicant.  (vi) Certificate of Caste/Tribe.  (vii) Experience Certificate of any type.  (e) That the respondents are estopped due to their own act, deed and conduct. The principle of the Promissory Estopple applies against the respondents.  (f) That the impugned order is against the well settled principles of the law as laid down by the Hon'ble Supreme Court and this Hon'ble Tribunal in catena of cases.  7. Reliefs Sought: That the applicant, therefore, prays that your Lordship be pleased to issue an appropriate writ, orders or directions to grant the following reliefs in favour of the applicant in the interest of justice:- (a) Quash the impugned order A-__________ whereby the respondent department has selected the respondent No. ____________, being issued arbitrarily, malafide and illegally by the respondents;  (b) Direct the respondents to select and appoint the applicant against the post of Anganwadi Worker on the basis of merits ___________________, with all the consequential benefits;  (c) Direct the respondents to produce all the relevant documents along with their reply for perusal by this Hon'ble Tribunal;  (d) Allow the cost of this OA;  (e) Pass such other order or directions as deemed fit and proper in favour of the applicant. AND FOR THIS ACT OF KINDNESS, THE HUMBLE APPLICANT AS IN DUTY BOUND, SHALL EVER PRAY.  8. Interim Orders, If Prayed: (a) That it is most respectfully prayed that during the pendency of this OA the operation of the impugned order/action ________________ of the respondents whereby they are going to appoint the respondent No. _________________________, may kindly be stayed during the pendency of this OA in the interest of justice.  9. Details of Remedies Exhausted: That the applicant submits that since the matter being of an urgent nature, there is no other alternative speedy and efficacious remedy available to him except to approach this Hon'ble Tribunal.  10. Matter not Pending with any Other Courts Etc: That the applicant further declares that the matter regarding which this application has been made, is not pending before any court of law or any other Authority or any other bench of this Hon'ble tribunal.  11. Particulars of Court Fees: Court fees worth Rs 50/- is attached herewith. 12. Details of Index: An index containing the details of the documents to be relied upon is enclosed herewith. Chennai Applicant ______ Through, Advocate  BEFORE THE HON'BLE TN STATE ADMINISTRATIVE TRIBUNAL AT CHENNAI OA No.:______ of 2004 Applicant  Versus Respondents  Affidavit  I,_________________________________, do hereby solemnly, affirm and declare as under :- 1. That the accompanying  OA  has been prepared under my instructions. 2. That the contents of paras 1 to 12 of the accompanying application are correct and true to the best of my knowledge. 3. That I further solemnly affirm and declare that this affidavit of mine is correct and true to the best of my knowledge and no part of it is false and nothing material has been concealed therein. Affirmed at Chennai this the _____________________________. Deponent  Download Word Document In English. (Rs.60/-) Download PDF Document In Marathi. (Rs.60/-)

Sat Appoint Selection Without Eligibility  BEFORE THE HON'BLE TN STATE ADMINISTRATIVE TRIBUNAL AT CHENNAI OA No.:______ of 2004 Applicant  Versus Respondents  Application Under Section 19 of the Administrative Tribunals Act, 1985 Chennai Applicant ______ Through, Advocate Respectfully Sheweth : 1. Particulars of the Applicant As given in the Memo of Parties. 2. Particulars of the Respondents As given in the Memo of Parties. 3. Impugned Order: That the applicant is aggrieved by the impugned order of the respondents whereby they have selected and appointed the respondent No. as Part Time Water Carrier in GPS despite not being eligible. 4. Jurisdiction That the applicant declares that the subject matter is within the jurisdiction of this Hon'ble Tribunal. 5. Limitation: That the applicant further declares that the application is within the limitation. 6. Facts of the Case: 6.1 That the applicant has applied for the post of Part Time Water Carrier in Govt Pry School , under Block Primary Education Officer and under Gram Panchayat . The applicant also belongs to the same Gram Panchayat and the distance of the applicant's residence from the School is only . 6.2 The applicant possesses the following qualifications and certificates which were duly produced before the Selection Committee on the date of interview as called for by them:- - Matriculation _____% marks A-_______ - Plus Two % marks A-  - SC A-__ - Handicap A-__ - Land Donation A-__ - IRDP A-__ - Un-employed Family A-__ 6.3 That the interview for the said posts were held at on in which the applicant alongwith the respondent No. and other candidates participated.  6.4 That the marks are to be allocated in the manner prescribed in the Part Time Water Carrier Scheme, as per which the applicant viz-a-viz Respondent No. scores the marks as follows:-  S.No . Qualification Applicant Respondent - Distance  ( mtrs from School) (__ Mtrs) - Land Donation   - SC   - Un-employed Family   - Marks in Interview   Total Marks   6.5 That from above it is amply evident that the applicant scored more marks than the respondent No. . However, there are 7 marks for viva which are to be given by the Chairman and the members in the following manner:- Marks Given to applicant (a) SDM (Chairman) 2   (b) BPEO 2 __  (c) Pradhan 2 __  (d) CHT 1  6.6 That   GROUNDS 6.7 That feeling aggrieved by such an arbitrary, malafide, discriminatory and illegal actions of the respondents, the applicant seeks the indulgence of this Hon'ble Tribunal on the following grounds amongst others, which may be taken at the time of arguments, each one of which is without prejudice to and independent of others :- (a) That the impugned orders of selection and appointment issued by the respondent department are arbitrary, malafide, illegal, ultra vires, against the Articles 14 and 16 of the Constitution of India, dehors the rules and regulations and against the natural justice.  (b) That the respondent State has formulated Part Time Water Carrier Scheme for selection/appointment of Part Time Water Carrier.  (c) That the respondent department has not conducted selection in consonance with the above guidelines. (d) That the respondents are estopped due to their own act, deed and conduct. The principle of the Promissory Estopple applies against the respondents.  (e) That the impugned order is against the well settled principles of the law as laid down by the Hon'ble Supreme Court and this Hon'ble Tribunal in catena of cases. 7. Reliefs Sought: That the applicant, therefore, prays that your Lordship be pleased to issue an appropriate writ, orders or directions to grant the following reliefs in favour of the applicant in the interest of justice:- (a) Quash the impugned selection and appointment order A-__ whereby the respondent department has selected the respondent No. __, being issued arbitrarily, malafide and illegally by the respondents;  (b) Direct the respondents to select and appoint the applicant against the post of Part Time Water Carrier on the basis of merits __, with all the consequential benefits;  (c) Direct the respondents to produce all the relevant documents alongwith their reply for perusal by this Hon'ble Tribunal;  (d) Allow the cost of this O.A.;  (e) Pass such other order or directions as deemed fit and proper in favour of the applicant. AND FOR THIS ACT OF KINDNESS, THE HUMBLE APPLICANT AS IN DUTY BOUND, SHALL EVER PRAY. 8. Interim Orders, If Prayed: That it is most respectfully prayed that during the pendency of this OA the operation of the impugned order/action of selection and appointment of the respondents whereby they are going to appoint the respondent No. , may kindly be stayed during the pendency of this OA in the interest of justice. 9. Details of Remedies Exhausted: That the applicant submits that since the matter being of an urgent nature, there is no other alternative speedy and efficacious remedy available to him except to approach this Hon'ble Tribunal. 10. Matter not Pending with any Other Courts Etc: That the applicant further declares that the matter regarding which this application has been made, is not pending before any court of law or any other Authority or any other bench of this Hon'ble tribunal. 11. Particulars of Court Fees: Court fees worth Rs 50/- is attached herewith. 12. Details of Index: An index containing the details of the documents to be relied upon is enclosed herewith. Chennai Applicant ______ Through, Advocate  BEFORE THE HON'BLE TN STATE ADMINISTRATIVE TRIBUNAL AT CHENNAI OA No.:______ of 2004 Applicant  Versus Respondents  Affidavit I,______________________________, do hereby solemnly, affirm and declare as under:- 1. That the accompanying OA has been prepared under my instructions. 2. That the contents of paras 1 to 12 of the accompanying application are correct and true to the best of my knowledge. 3. That I further solemnly affirm and declare that this affidavit of mine is correct and true to the best of my knowledge and no part of it is false and nothing material has been concealed therein. Affirmed at Chennai this the ____________.  Download Word Document In English. (Rs.60/-) Download PDF Document In Marathi. (Rs.60/-)