ia t t— cc rr cc IN THE SUPREME COURT OF MAURITIUS in Re: Devendranath Hurnam also called Dev Hurnam, a British Qualified Barrister, Leader of Peoples Force ++4 [Truth and Justice Party] of 16 Malherbes Street, Curepipe. Applicant v 1, The Very Noble Madam Justice Nirmala Devat ] 2. The Noble Judge P Fekna ] 3. Dhan Kan Cheong J ] 4. GAngohJ ] service “ 5. ARHAbdoula) Jon all 6. AF Chui Yew Cheong J Ico : 7. Lam Shang Leen J ] Supreme 8. AHamuth } ] Court : 9. KP Matadeen SP) ]P Louis 10. Y KL Yeung Sik Yuen CJ 1 11. Mrs Magistrate Hamuth Lauloo service @ Intermediate Court, P Louis 12, Rama Valayden, Chambers. Port Louis; 13. Raouf Gulbul, Chambers, Port Louis; 14. Sir Hamid Moollan QC, Chambers, Port Louis 15. Sanjay Bhuckory, Sterling House, Port Louis 16. The Attorney General (Unreturned}Port Louis and 17. The State of Mauritius, c/o AG's office]Port Louis Respondents IN THE PRESENCE OF:- Jean Claude Delaitre c/o Devat J, Chambers, $ Court Co-Respondent NOTICE OF MOTION: Take Notice that the above named Applicant shall on Monday (13. 4-ZO12 at 10.00 a.m. with leave of the court move the above Court the Supreme Court of Mauritius for the following Orders from the above Court declaring and decreeing that: A] Respondents No. 1 to 11 have breached several clauses of the Guidelines For Judicial Conduct ranging from propriety, Independence, integrity, Impartiality and Competence and Respondents No. 1 to 10 be directed to abstain from hearing Applicant's cases pending the Supreme Court; (8] Respondents No. 3, 4 & 5 have committed forgeries in public documents; {C] Respondents No. 7, 8, 9 & 10 have failed to observe statutory procedures and made an abuse of authority in the dispatch of their judicial functions;{0} Respondent No. 10's conduct following a telephone conversation from a Chinese Director of a Clinic whereupon he held a special sitting on 4 January 2012, the Supreme Court being on vacation until 09 January 2012, to receive the, one and only application for leave to apply for a Judicial Review against the Medical Council Re: SCR 106223-5A/1/12 and thereafter, on 09 January 2012 granting an Interim illegal order without hearing the objection of the Medical Council by the competent court substituting himself for the Registrar of the Medical Council and his conduct 07 April 2012- pregnant with illegality which undermines judicial process by causing proceedings to be transmitted live on the Mauritius Broadcasting Service whilst dispatching formal chambers business; (E] Respondent No. 12's deliberate lies to the Court of Criminal Appeal presided by Respondents No. 10, 6 & anor on 31 March 2011 in Re: J J B Virassamy v The State SCR No, 104985 breaches the Code of Ethics for Law Practitioners GN 1702 of 1997 and whether such conduct is contemptuous; he be further ordered to pay to Applicant a sum of Rs S million; [F] Respondent No. 12's public speech on 16 September 2007 Re: Un cas particulier defendu par Me Renganaden Seeneevassen (this latter advising his client to repair to the locus of the larceny of a particular dimension of macadams and to substitute a totally different dimension of macadam whereby the client was acquitted] in his, then capacity of Unreturned Attorney General with an Order directing Respondent No. 16 to advise the Government to re-name the AG's building in order to preserve and protect the integrity of the judicial offices housed therein ; (G] Respondent No. 13 by his conduct in the Bottessoie case by suggesting to his one time client to withdraw the alleged allegation against one Vele Vindron on receiving RsSm from this latter which sum be paid to high officials and judges to curry a lenient sentence Re The State v V Vindron SCS 6/2003 breaches the Code of Ethics for Law Practitioners GN 1702 of 1997; He be further ordered to pay to Applicant a sum of Rs 10million; {H] Respondent No. 14’s conduct in Re Police v R D K F Lan Yee Chiu-3/200 IC, his subsequent appearance as Counsel for Respondent No.10 and thereafter appearing before Respondent 10 as Counsel for a private party and his recent appearance in Re Police v § K J Ramphul & anor CN 2012/106 IC before the full bench of the Intermediate comprising of his former pupil breaches the Code of Ethics for Law Practitioners GN 1702 of 1997 following his declared stand that he does not appear before his pupils who have been appointed on the bench; and he be ordered to pay to Applicant Rs § million; [I] Respondent No.15’s conduct as set out for conspiring with ICAC Commissioner and his further conduct in the Money Laundering case be declared and decreed in breach of the Code of Ethics for barristers; ee 3) 2 a) ae a 4 = =I — a 535 5a JFU1] Respondent No.16's conduct in touting from statutory bodies to retain his name on the panel of Legal Advisers coupled with his recent referral of a money laundering case listed before the Intermediate Court to the then Campaign Manager of the Prime Minister, a barrister in private practice, Respondent No.15- commonly known as Hedging Counsel and his interference with Respondent No. 9 prior to judgment in the contempt case against Respondent No.10 Re SCR 104492-5/180/10 be decreed and declared not conducive to the office to which he has been appointed: he be ordered to pay to Applicant a sum of Rs § million; Ik] An order directing Respondent No. 16 to initiate disciplinary proceedings against Respondents 12, 13, 14 and 15 in the light of the above and further directing the record of the court in this matter be submitted to the Ag President for action Pursuant to Section 78 [4] of the Constitution in relation to Respondents No.1 to 10 and to the Judicial and Legal Service Commission quo-ad Respondent No.11; {L] An order directing Respondent No. 17 to Pay to Applicant a sum of Rs 25m for the Prejudice he has suffered at the hands of Respondents No 1 to 11 and Respondent 15 for their illegal interferences, inobservance of statutory procedures and abuse of authority and forgery in his matters; [M] An order that Co-Respondent be restrained from circulating any confidential documents received in his capacity as the lover of Respondent No. 1 and N] Such other or further orders as the justice of the case may require. AND this for the’ reasons fully set forth in the hereto annexed affidavit, a true and Certified copy of which is herewith served upon you in order that you may not plead or pretend ignorance of same. TAKE further Notice that the said motion shall be made on the above date and hour whether you be present or not. AND this for the reasons fully set forth in the hereto annexed affidavit. Under all legal reservations Dated this Qo,A)day of July 2012 te ae C Most, ta D Hurnam/Applicant In Person Attorney f6¢ Applicant 16, Malherbes Street, P Louis