Dr Swamy Petition in SC on Kaalaadhan (May 12, 2015)

8/9/2019 Dr Swamy Petition in SC on Kaalaadhan (May 12, 2015)

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IN THE SUPREME COURT OF INDIA

CIVIL WRIT JURISDICTION

I.A. NO. OF 2015

IN

WRIT PETITION (CIVIL)NO. 176 OF 2009

IN THE MATTER OF:

Subramanian Swamy Applicant for Impleadment

Vs

Ram Jethmalani and Others Respondents

INDEX

SNo Document Pages

1. Affidavit on behalf of Applicant to support hisApplication for Impleadment as a Petitioner inthe instant Writ Petition

2. Annexure A-1 being Letter dated 9.7.2014 sentby the Applicant to the Hon’ble Chairman, SIT

3. Annexure A-2 being letter dated 6.5.2015 sentby the Applicant to the Hon’ble Prime Minister

4 Application on behalf of Applicant for leave toappear, file and argue as Applicant in Personwith Affidavit in Support thereof

Subramanian Swamy

Applicant in Person

Delhi

May11th 2015


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I.A. NO. OF 2015

IN


IN THE MATTER OF:

Subramanian Swamy

A-77 Nizamuddin East,

New Delhi-110013 Applicant for Impleadment

Vs


AND IN THE MATTER OF

WRIT PETITION (CIVIL) No. 176 OF 2009

IN THE MATTER OF:

Ram Jethmalani and Others Petitioners

VS.

Union of India and Others Respondents


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AFFIDAVIT ON BEHALF OF APPLICANT TO

SUPPORT HIS PLEA FOR IMPLEADMENT AS APETITIONER IN THE MAIN WRIT PETITION

I, Subramanian Swamy, son of Sitarama Subramanian

aged about 75 years ,resident of A 77 Nizamuddin East,

New Delhi 110013, Applicant/Petitioner do hereby

solemnly affirm and state as under:

1. (a)The Application made by the instant Applicant,

being Applicant in Person, for being impleaded in the

aforesaid Writ Petition(Civil) was heard on 21.4.2015 by

this Hon’ble Court when permission was granted to him

by this Hon’ble Court to file a detailed affidavit in support

of his Impleadment Application.

(b)It is the Applicant’s contention that since 2009 the

year of filing of the instant Writ Petition ,urgent orders

were required from this Hon’ble Court to enable the

recovery and return to India of the enormous amount of

“black money” taken out from this country, which

amount presently estimated to be in the region of Rs. 1.5

trillion dollars ,has been illegally taken out of India and

parked in foreign secret banking (estimated to be in

some 90 countries and tax havens).

(c ) The Applicant verily believes that where the

Government has the requisite will, this black money can

be brought back very speedily.


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(d) Yet for the past five years, this has not been done;

even though and more particularly since last year when

the Indian electorate decisively voted in a new

Government (which had made an electoral promise that if

it got a decisive electoral mandate it would immediately

bring all this black money back to the nation --- which it

estimated at an amount of Rs. 15 lakhs per each man ,

woman, and child---.The result of failure to move

decisively in this regard during the new Government’s first

year in office, is that by default, public anger at the

inaction and apparent indifference to this urgent need,

has had tremendous and far reaching consequences on

the psyche of all Indians. The same has been exploited by

a vicious disaffected section of persons both in India and

abroad who have more or less indicated that all these

black money stashers are sitting pretty, confident that this

new Government, like the earlier Government is quite

ineffectual and cannot –or will not—do anything to

address this black money problem.

2.(a)The Applicant has filed the instant application for the

benefit of the citizens of the country. The Applicant is also

a citizen of the country and he along with the rest of the

citizens has a duty to expose and get action taken against

the aforesaid black money problem.


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(b)The Applicant is a nationally known public figure,

active in politics and public affairs. He is deeply

concerned with the protection of the Rule of Law and the

enforcement of the statutory duties of the Government as

well as purity in public life.

The Applicant holds a doctorate in Economics from the

world famous Harvard University in the U.S.A., where,

before returning to India he had taught Economics – and

he has continued to teach there for some decades in the

summer semester; and he had also taught Economics at

the Indian Institute of Technology in Delhi, as a full

Professor. He is a senior politician, a Member of

Parliament for five terms, who has been a senior Cabinet

Minister in the Central Government, holding the portfolios

of Commerce and Law & Justice, and later he was

Chairman of the Commission for Labour Standards, a post

of Cabinet Rank. Twice he has been elected to the Rajya

Sabha from the State of Uttar Pradesh, to the Lok Sabha

twice from Maharashtra and once from the State of Tamil

Nadu. He has numerous books and articles to his credit.

He has lectured both in India and abroad on national

concerns as well as on Economics. He has initiated and

conscientiously fought many public interest litigations. He

regards this as a duty he owes his country.


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(c)In particular, the Applicant being a bonafide law

abiding citizen believes that it is his duty to set into

motion the legal process when grave offences which

affect the society at large are brought to his notice which

,in his opinion ,cause a grave miscarriage of justice. It is

this duty he seeks to perform in the instant case, as set

out herein below.

(d) The Applicant is personally bearing the cost of this

Writ Petition Impleadment.

3. Ever since he entered politics in or about 1970, the

Applicant has deemed it his duty to fight corruption and

authoritarianism. He has ever since been a rallying point

in fighting corruption and autocracy in public life. He has

filed a number of Public Interest Litigations against

corruption and other public issues both in this Hon’ble

Court and in various High Courts in India . For instance,

in the last decade, the Applicant was instrumental in

exposing the mammoth corruption involved in the

allocation by the Union Government ,of 2G Spectrum ;

whereafter the Hon’ble Supreme Court is monitoring the

matter in C.A. No. 10660/2010 in which matter the

Petitioner is an impleaded party.

(b) As an economist and long time Professor of

Economics, and having held senior Cabinet minister

positions , the Applicant believes he can assist this Hon’ble


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Court to devise ways to bring back black money of

Indians stashed away in foreign secret banking (estimated

to be held presently in some 90 countries and tax

havens). A summary of these suggestions is set out here

in below:

4.(a) It is a matter of disappointment so far that all the

present Government has sought to bring into law is the

proposed Bill No.84 of 2015 introduced in the Lok Sabha .

The Bill is completely inadequate for securing the return

of the estimated $ 1.5 trillion of black money deposited

abroad, by Indian citizens, in secret banking in some 90

countries.

(b)This Bill is structured to deal merely with enhanced

punishment of black money hoarders once the black

money is detected or admitted to for seeking amnesty.

Thus the Bill has no provisions at all on how to secure the

stock of black money stashed away abroad.

(c )The embedded amnesty scheme is also contrary to the

Union of India’s solemn assurance made in 1997 to this

Hon’ble Court ,to never again introduce another amnesty

scheme for undisclosed or tax evaded funds.

(d)The DTAA route also does not cover black money

generated by scams, gambling, drug running and arms

peddling: it deals solely with secret banking made to

evade taxes on legitimate earnings.


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(e)It must be emphasized that this money, seeking only to

avoid taxes on legitimate earnings , is a very small share

of the total black money.

5.There are four ways by which the names and accounts

illegally held abroad by Indian citizens can be ascertained

and acted on.

(1) The First Method is for the CBI/ED to register an FIR ,

obtain a Letter of Request u/s 166A of the Criminal

Procedure Code (1973) from a designated Court, and then

(making use of the Swiss Law On International Judicial

Assistance in Criminal Matters seek Swiss cooperation)

proceed to get Swiss cooperation which the Swiss

authorities will be obliged to facilitate. This can be done

whenever there is prima facie evidence of any person,

institution or company maintaining a secret and illegal

account in Switzerland. The Swiss Federation Act on the

Restitution of Assets of Politically Exposed Persons

obtained by Unlawful Means (RIAA) governs the freezing,

forfeiture and restitution of the assets of politically

exposed persons (PEPs) or their close associates in cases

where a request for mutual assistance in criminal matters

cannot succeed due to the failure of the judicial system in

the requesting state. This Act has been in force since 1

February 2011.


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(2)The Second Method is the German/French method

which these two Governments used to obtain records of a

particular bank by offering monetary inducements to

willing senior bank officials . This is what these two

countries did with Bank of Lichtenstein and the HSBC in

Geneva.

(3)The Third Method is the US method used by the US

authorities against the Washington D.C. based branch

offices of the Union Bank of Switzerland and Credit Suisse

Thereby the US obtained the names of over 5000 US

citizens who had illegally opened bank accounts in these

banks. When these banks had claimed secrecy as a

business principle, the US authorities simply arrested the

Washington D.C. based senior officers of these two banks.

Thereafter, the bank headquarter office gave in and

shared the desired information. India too has these Swiss

bank branch offices in Mumbai, and this method can be

pressed into service for this purpose.

(4)The Fourth Method is the method suggested by

eminent jurist and Senior Advocate, Fali S. Nariman in his

Rajya Sabha speeches and op ed articles in newspapers,

viz., advocating invoking the Resolution of the UN

Convention against Corruption adopted by the UN General

Assembly in 2005 and ratified by India in 2011.


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Action Committee Against Corruption in India [ACACI] had

sent written complaints to the then Director CBI, New

Delhi, Mr. A.P. Singh, with particular references to

disclosure of offences committed under the Prevention of

Corruption Act (PCA).

(b)The Enforcement Directorate was also sent a Complaint

regarding the offences alleged to have been committed

under PMLA and FEMA.

(c)By his letter dated 9.7.2014, the information in the

said Complaints , was also supplied by letter to the SIT

as follows:

(i)the First information so supplied was from an article

published in the reputed Swiss monthly Schweizer

Illustrierte , November 1991 issue, which magazine is a

highly respected and widely circulated magazine in

German language, and published in Switzerland.

This information disclosed that the former Prime Minister,

Mr. Rajiv Gandhi (now deceased), had about $2 billion in

secret bank accounts in Switzerland, (an amount which is

clearly disproportionate to his known sources of income as

per his affidavit filed with his nomination papers upon

becoming a candidate for Lok Sabha elections in 1991).

This attracts section 13(1(e) of the PCA. Although the

information is two decades old, the Director CBI was well

aware that there is no time limitation on corruption cases


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(v)The Third information was the information that Mr.

Rahul Gandhi, presently Vice President of the Congress

Party, and also presently an Opposition MP, was detained

in Boston’s Logan Airport by US law enforcement

authorities sometime in the later half of September 2001.

He was found in possession of $160,000 in cash which he

did not declare upon arrival. ( US Customs require all

amounts above $10,000 in cash to be declared, and if this

is not done, every $10,000 instalment carries an 8 year

prison term , if convicted).

(vi)This means that Mr.Rahul Gandhi was indictable for a

prison term of 144 years. However, Mr. Brijesh Mishra

the then Principal Secretary to the then PM Mr. Atal Bihari

Vajpayee, personally intervened with the US Secretary of

State, and arrangements were made to get Mr. Gandhi

released. Nevertheless the information is that the US

Homeland Security has registered a case which is still on

record.

(vii)It is reliably learnt that in his deposition to the US

authorities , made before he was allowed to return to

London, Mr. Rahul Gandhi had declared that the money

was legally his own , and he had drawn it out of his secret

and undisclosed account in Pictet Bank, which bank is

head-quartered in Zurich, Switzerland.


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(vii)It may also be noted here, that while Mr.Rahul

Gandhi enrolled briefly at Harvard University, and later in

Rollins College, Winter Park, Florida, USA, he paid his

Tuition and other fees to these Colleges from his secret

accounts, said to be from Bank of America branch in the

Cayman Islands. This can be easily verified by the

Enforcement Directorate.

(viii)Further this Intervenor also wrote to the Finance

Minister and also informed the Prime Minister that

information had become available that accounts existed

in Sarasin Bank and Pictet both of Zurich, and the Vatican

Bank in the name of Sonia Gandhi and her legatee son

Rahul Gandhi. This information is also with the

Enforcement Directorate.

8.(a) It may be noted that on February 13, 2012, while

inaugurating the first Interpol global programme on anti-

corruption and asset recovery, the then CBI Director also

had stated that Indians are the largest depositors in banks

abroad with an estimated 500 billion US dollars (nearly

24.5 lakhs crore) of illegal money stashed by them in tax

havens; and that the largest group of depositors in Swiss

Banks are also reported to be Indians.

(b)He also added that there was a lack of political will in

the leading tax haven states to part with the information

because they are aware of the extent to which their


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economies have become “geared to this flow of illegal

capitals from the poorer countries.”

[http://timesofindia.indiatimes.com/india/Black‐money‐Indians‐have‐

stashed‐over‐500bn‐in‐banks‐abroad‐says‐

CBI/articleshow/11871624.cms].

(c )It is against this background that the submissions in

writing were made by the ACACI to Special Investigation

Team of Hon’ble Justice Shah, Chairman, and Hon’ble

Justice Arijit Pasayat, Vice-Chairman, as follows:

(1).SIT must seek a report from Financial Intelligence Unit

{FIU} of the Government of India on what it has done on

Suspicious Transactions Reported by Banks.

(2)This reporting ensures that the Banks on a real time

basis report on all Suspicious Transactions for further

investigations. SIT should demand that at least 100

major STRs reported in the past 3 years must be

investigated and action taken reported within the next 10

days, while following-up on all other cases promptly, as

and when the reports surface.

(3)There is no precise definition of PEP {politically

exposed persons} in India, while there is no ambiguity in

international financial world as may be seen from a Swiss

Federation Act on restitution of illicit wealth of PEP

discussed further on.


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(4) Consequently, the Finance Ministry must immediately

come out with a guideline on PEP along with all Anti-

Money Laundering Vehicles which are known to have been

deployed by the offenders.

(5)PEP is defined as per UN Convention against Corruption

(2005) to which India had become a signatory and ratified

the same in 2011.

[http://www.unodc.org/unodc/treaties/CAC/signatories.html].

(6)Until 2011, SEZs had become an institutional vehicle

for Money Laundering as there was no tax on them.

Subsequently MAT was introduced which led to the

collapse of the SEZ economy. A Progress Report should

be demanded on the progress in investigations made by

ED on all those suspected cases.

(7) In line with the provisions of Section 12 of the

Prevention of Money Laundering Act all institutions must

declare to the Government as to their Beneficial ownership

– this will include ICICI Bank, Axis Bank, HDFC Bank, Jet

Airways etc.. Unless this is done, ownership of several

large corporate will remain unknown and hence exposing

themselves to become vehicles for Money Laundering.

9. The following are Immediate Steps that SIT can direct

the CBI/ED to take:

(1)This Intervenor has provided information on Zurich

based Pictet and Sarasin Bank Accounts of Sonia Gandhi


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and Rahul Gandhi; SIT be requested to seek progress

reports on the details of transactions of these accounts

and the legal basis for keeping the monies in foreign bank

accounts and also on details of any other undeclared

assets, if any.

(2)The SIT be asked for status on investigation of the

truth of the Schweizer Illustrierte expose on the illicit

wealth of the late PM Rajiv Gandhi and his legatees.

(3) The SIT be asked by this Hon’ble Court to investigate

on the legatees of this prima facie illicit wealth and inquire

about the steps to be taken under the Swiss Federation

Act [http://www.oecd.org/daf/anti-bribery/anti-

briberyconvention/42103425.pdf .

(4)After consulting Sr. Advocate Fali S. Nariman ,the SIT

be asked to recommend to the Union of India that it issue

an Ordinance declaring such illicit wealth of politically

exposed persons obtained by unlawful means as black

money and declare such illicit wealth as nationalised.

(5)This Black Money Nationalisation Ordinance should be

conveyed to all financial institutions all over the world to

ensure the freezing of all accounts which are under the

beneficial ownership of Indian citizens and demanding

restitution of this kaalaadhan into Union Treasury

Consolidated Fund of India. This Ordinance can be for the


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objectives which were stated when private banks were

nationalised on 19 July 1969.

(6)The SIT be asked to seek details of private jet travels

abroad and their passport entry and exit stamping under

Immigration procedures, as well as the attested records of

financing the costs of such travels of prominent and

frequent foreign travellers such as Ms. Sonia Gandhi, Mr.

Rahul Gandhi, Ms. Priyanka Vadra, Mr. Shashi Tharoor,

etc., and other members in public life declaring them as

politically exposed persons under international law and as

defined in many enactments such as the Swiss Federation

Act.

(7) The SIT be asked to seek investigation of the

corporate tax fraud exposed and reported by ICIJ on Pepsi

Bottling Group taking shelter under the Luxembourg-India

Double Tax Avoidance Treaty and depriving Indian

Treasury of legitimate corporate tax revenues.

{http://www.icij.org/project/Luxembourg-leaks}.

(8) The SIT be asked to call for SEBI records to plug the

loophole on Participatory Notes (PNs) under the FII

Guidelines and act according to findings of Hon’ble SAT in

UBS case and Goldman Sachs case.

[http://www.business‐standard.com/article/printer‐friendly‐

version?article_id=109010501009_1].


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(9)The SIT be asked to investigate why the

recommendations of the Tarapore Committee , instituted

by the RBI, which called for the phasing out of

Participatory Notes, were ignored : since these derivative

financial instruments violate the basic tenet of financial

propriety of identity of the beneficial owner of the

underlying foreign currency funds (referred to in financial

parlance as Know Your Client). SIT be asked to take up

with Finance Ministry and RBI the need to phase out

within the next six months the Participatory Notes (PNs)

which are known conduits for black money using hawala

routes.

Full text of Tarapore Committee Report can be obtained :

{http:3rbidocs.rbi.org.in/rdocs/PublicationReport/Pdfs/722

50.pdf}.

(10)Request SIT to seek status report on the investigation

of Blackmoney and Swiss Bank deposits of $ 8 billion on

behalf of Moin Qureshi.

(11)All FIPB clearances and the approval given by the

Finance Minister during 2004-2015 be fact-checked to

determine which are prima facie money laundering. For

example in the presently Court-monitored cases of Aircel-

Maxis scam and in the Swan Telecom –Etisalat share

dilution scam.


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10. (a)As another glaring instance which has come to the

notice of the intervenor, the Bharat Hotels Limited case,

Richmond Enterprises SA is prima facie a non-existent

company at the given address in London, and is not a

registered entity in the United Kingdom. The address

given by this Richmond Enterprises SA in FIPB documents

is : 5, Westmoreland Place, London, SW1V4AB, London.

(b)Enquiries made reveal that there is no such company

registered in UK at this address and in fact no such firm at

this address in London.

(c )Yet the Bharat Hotels Limited got an FIPB clearance

and then a FIPB approval in December 2005 from the

then former Finance Minister P Chidambaram.

(d)According to the FIPB approval, Richmond Enterprises

was allowed to invest Rs.50 lakh in one Deeksha Holdings

Private Limited, a subsidiary of Bharat Hotels Limited. This

clearance was given at the FIPB meeting of December 23,

2005, and later approved by then Finance Minister P

Chidambaram [Page No : 11, Item No : 40].

(e)But in the Prospectus filed to Bombay Stock Exchange

by Bharat Hotels Limited (Page No : 21. Prospectus

attached) in December 2008 the bogus London firm,

Richmond Enterprises has 7.22% shares in Bharat Hotels

Private Limited.


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(f)Meanwhile contemporaneously during this period, a

Dubai firm called Dubai Ventures Ltd was allotted 5.40%

shares in Bharat Hotels Limited. This deal was widely

reported and the value available in public domain and as

well as disclosed by both parties to media is Rs.160 crore

for the 5.40% stake.

(g)By this valuation, the 7.22% shares allotted to the

bogus firm and in non-publicised deal would have been

any way much more than Rs.200crore. How this money

routing is possible as FDI, when the company got only

Rs.50 lakh to invest that too in subsidiary firm Deeksha

Holdings.

(h)This by contemporary valuation is more than Rs.200

crore worth in 2008. Thus is it legal for a firm which was

permitted to have Rs.50 lakh in FDI in its subsidiary firm

to route Rs.200 crore in the holding firm without

intimating the FIPB?

(i)More over Commerce Ministry’s DIPP’s data on FDI flow

in Hotel Sector shows that (Page No : 3, Item No : 23.

DIPP data attached) Rs.118 crore from bogus London firm

Richmond has routed to Bharat Hotels.

(j)These contradicting figures of Rs.50 lakh from FIPB

approvals and more than Rs.200crore worth shares in

Prospectus to BSE, and Rs.118 crore from the fund routed

to Bharat Hotels Limited according to DIPP data from


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bogus non-existent firm Richmond Enterprises, is

obviously prima facie nothing but the flow, routing, and

round tripping of unaccounted money through London and

therefore a fit case for the Financial Investigation Unit

(FIU) under Section 12 of the PMLA by the Enforcement

Directorate .

(k)In above mentioned circumstances, a thorough probe

on the Black Money trail from a non-existent London

company Richmond Enterprises to Bharat Hotels Limited

should have been initiated by the Finance Ministry itself.

The promoters of Bharat Hotels, FIPB officials, and

including former Finance Minister P Chidambaram should

be interrogated to find the real face behind the London

based bogus non-existent company, Richmond

Enterprises, to unearth the black money raised through

corruption in India. The probe should be also initiated

under Prevention of Corruption Act, IPC and PMLA by CBI

and Enforcement Directorate also.

11.This Applicant has also studied the recent share

transfer leading to ownership change of the Spice Jet

Airlines. There appears to be, prima facie, money

laundering and black money transaction in the said deal. A

letter dated 6.5.2015,written by this Applicant to the

Prime Minister detailing the scam in the deal is annexed

with this IA , as Annexure A-1.


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12. Furthermore, hereinbelow is summarised various

submissions on “Black Money” Ordinance for illicit wealth

restitution.

(a)This Intervenor submits that the issue of black money

should not get muffled as a mere taxation avoidance

issue but as a major systemic crime of denying the

proceeds of wealth within the nation’s financial system

which denial should be declared as constituting treason

with wilful deprivation of opportunities of sharing the

wealth for the benefit of the poor people of the nation.

(b) Just as the illicit wealth of Mubarak of Egypt or Gaddafi

of Libya were declared illicit and restitution of illicit wealth

ordered, Union of India through the an ordinance declare

the intent of the nation to ensure restitution of

nationalised illegal money deposit abroad for the benefit of

the deprived poor of the nation and to promote

development initiatives of the governments under the

Directive Principles of State Policy, as was done for the

nationalisation of private banks. Such a declaration of the

will of the people of India through an Ordinance by the

State nationalisation of all accounts of Indian citizens in

the banks of the 90 odd nations permitting secret banking,

as suggested Senior Advocate and eminent scholar Fali S.

Nariman.


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(c )It will have a chilling effect on the behaviour of

institutions in tax havens holding illicit wealth of Indian

citizens. The suggested ordinance should provide for

categorical directions to all financial institutions all over

the world and signatories of Inter Governmental

Agreements to honour this commitment of the Union of

India, to facilitate restitution of illicit monies held outside

Indian financial system depriving their beneficial use for

the benefit of the poor masses of the nation and for

developmental imperatives which are a struggle to

overcome the colonial loot and loot by the corrupt

violating the laws of the State.

(d)SIT may be asked by this Hon’ble Court to invite

distinguished Senior Advocate Fali Nariman who had

suggested such an Ordinance, a suggestion which should

become a crucial instrument of black money restitution

which is mandated by the Hon’ble Supreme Court to be

achieved through decisive actions of SIT on Black Money.

(e )These submissions are made in furtherance of the

solemn assurance of the PM, Shri. Narendra Modi, to the

people of the nation during the 2014 Lok Sabha election

campaign.

13.PRAYER: It is therefore prayed that this Hon’ble Court:


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(a) pass an order incorporating as directions, each

and every one of the suggestions submitted

hereinabove;

(b) Permit this Intervenor to interact or assist the SIT

in unearthing the black money stock stashed abroad.

(c ) pass such other and further orders as this

Hon’ble Court deems fit and proper in the interest of

justice.

DEPONENT

Verified at Delhi on this 11th day of May 2015 that

the facts stated hereinabove in paras 1 to 12 are

true to my personal knowledge, based on data given

to me which I believe to be true; para 13 is a prayer;

the annexures are true copies.

DEPONENT


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I.A. NO. OF 2015

IN


IN THE MATTER OF:


Vs


APPLICATION FOR LEAVE TO FILE,APPEAR

ANDARGUE IN THE INSTANT MATTER IN PERSON

To the Hon’ble the Chief Justiceof the Supreme Court of India,

And his Companion Judges of the Supreme CourtThe humble Petition of the Applicant abovenamed MOST

RESPECTFULLY STATES THAT:

1. The Applicant has this day filed the Application for

Impleadment in the instant matter. The facts are stated

therein and the Applicant craves leave to rely thereon

hereunder as if they form part and parcel of the instant

Application.

2(a) The Applicant understands his case thoroughly.

Indeed he has researched it over a period of more than a

decade. He is well equipped to file and appear in person in


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the instant case . He has done so and succeeded too in

several important matters before this Hon’ble Court .

He does not wish to engage an advocate.

2(b)The Applicant is not willing to accept an advocate

who can be appointed for him by the Court.

3. It is in the interest of justice that the Applicant be

permitted to file ,appear and argue, in the instant matter,

in person.

4. PRAYER: It is therefore prayed that this Hon’ble Court:

(a) pass an order permitting the Applicant to file, appear

and argue in the instant matter as Applicant in Person;

(b) pass such other and further orders thereon as this

Hon’ble Court deems fit and proper in the interest of

justice.

AND FOR THIS ACT OF KINDNESS,THE APPLICANT

SHALL,AS IN DUTY BOUND,EVER PRAY.

(Subramanian Swamy,

Applicant in Person)

Delhi, 11th May 2015


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I.A. NO. OF 2015

IN


IN THE MATTER OF:


Vs


A F F I D A V I T

I, Subramanian Swamy, son of Sitarama Subramanian,

aged about 75 years,resident of A 77 Nizamuddin East,

New Delhi 110013,do hereby solemnly affirm and state as

under:

1. I am Applicant for Impleadment in the aforesaid

Writ Petition and the accompanying Applicant for

Leave to Appear, File and Argue in Person; and am

fully acquainted with the matter and fully

competent to swear thereto.

2. The facts in the Application for Leave to Appear/

Argue in person in paras 1-3 are true to my

personal knowledge. Paragraph 4 is a prayer.


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DEPONENT

VERIFICATION: Verified at Delhi this day of May

2015. that the contents of Paragraphs 1 - 2 of the above

Affidavit are true to my personal knowledge and no part of

the Affidavit is false and nothing material has been

concealed therefrom.

Verified at Delhi this day of 11th My 2015.

DEPONENT

Dr Swamy Petition in SC on Kaalaadhan (May 12, 2015)

Documents

Transcript of Dr Swamy Petition in SC on Kaalaadhan (May 12, 2015)