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IN THE HON’BLE SUPREME COURT OF WOODLANDS

SPECIAL LEAVE PETITION NO.: ___/ 2021

UNDER ARTICLE 136 OF THE CONSTITUTION OF INDIA

I N THE MATTERS OF:

Abdul……………………………………………………......Appellant 1

V.

Bavithra……………………………………………………..Respondent
1

Hygienic Health Care Products Ltd………………………Appellant 2

V.

Catherine……………………………………………………..Respondent2

MEMORIAL ON BEHALF OF APPELLANT

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INDEX

SR NO. PARTICULARS

1.
List of abbreviations

2. Index of authorities

3. Statement of jurisdiction

4. Statement of facts

5. Statement of Issues

6. Summary of Arguments

7. Arguments Advanced

8. Prayer

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LIST OF ABBREVIATIONS

Abbreviation Expansion

AIR All India Reporter

& And
Anr. Another
Art. Article
cl. Clause
Del. Delhi
Ed. Edition
HC High Court
Hon’ ble Honorable
Mad Madras
N. Note
Ors. Others
Raj. Rajasthan
SC Supreme Court
SCR Supreme Court Report
Sec. Section
SSC Supreme Court Cases
U.P. Uttar Pradesh
v. Versus
W.P.C Woodlands Penal Code
WSHWW(PP&R) ACT2013 Woodlands Sexual Harassment Of
Women At Workplace (Prevention,
Prohibition And Redressal) Act, 2013

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INDEX OF AUTHORITIES

CASES

Sr
No. PARTICULARS
1. Amber Tickoo v. Government of NCT Of Delhi & Ors, 10.05.2019 21
2.
Bindeshwari Prasad Singh v. Kali Singh, A.I.R (1977) S.C.R (1) 125. 20
3.
Chandrama Tewari v. Union Of India, Through General, 1988 AIR 117 15
4.
Delhi Transport Corporation v. D.T.C. Mazdoor , 1991 AIR 101 15
5.
Dr. B.N. Ray v. Ramjas College & Ors A.I.R.(2012) Del. H.C 13
6.
Dr. B.N. Ray v. Ramjas College & Ors.,(2012) Del HC 13
7.
Indian Hotel and Restaurant Association and Anr. v. State of Maharashtra (2019) 21
8.
Indian Iron And Steel Compant Limited v. Workmen , A.I.R (1958) S.C. 130 at 138 16
9.
J.K.Synthetics Ltd. v. K.P.Agrawal & Anr.(2007) SC 17
10.
Justice P.D. Dinakaran v Hon'Ble Judges Inquiry Committee, (2011) S.C 16

STATUTES

1. The Constitution of India

2. The Penal Code, 1860

3. The Industrial Disputes Act, 1947.

4. The Information Technology Act, 2000.

5. The Sexual Harassment of Women at Workplace (Prevention, Prohibition

and Redressal )Act, 2013

BOOKS

1. M.P. Jain, Indian Constitutional Law, VI Ed., Reprint (2011)

2. S.N. Misra, Labour and Industrial Laws, 28th Ed

3. Ratanlal & Dhirajlal, The Indian Penal Code.

4. K.D. Gaur, The Indian Penal Code

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STATEMENT OF JURISDICTION

The Hon’ble Supreme Court of Woodlands has the inherent jurisdiction to try, entertain and
Dispose of the present case by virtue of article 136 of The Constitution of Woodlands.

Article 136 - Special Leave to Appeal by the Supreme Court

1. Notwithstanding anything in this chapter, the Supreme Court may,
in its discretion, grant special leave to appeal from any judgment,
decree, determination, sentence or order in any cause or matter
passed or made by any court or tribunal in the territory of India.

2. Nothing in clause (1) shall apply to any judgment, determination,

sentence or order Passed or made by any court or tribunal constituted
by or under any law relating to the Armed Forces.

Article 32 - Remedies for enforcement of rights conferred by this Part

1) The right to move the Supreme Court by appropriate proceedings for
the enforcement of the rights conferred by this Part is guaranteed
2) The Supreme Court shall have power to issue directions or orders or
writs, including writs in the nature of habeas corpus, mandamus,
prohibition, quo warranto and certiorari, whichever may be
appropriate, for the enforcement of any of the rights conferred by this
Part
3) Without prejudice to the powers conferred on the Supreme Court by
clause ( 1 ) and ( 2 ), Parliament may by law empower any other court
to exercise within the local limits of its jurisdiction all or any of the
powers exercisable by the Supreme Court under clause ( 2 )
4) The right guaranteed by this article shall not be suspended except as
otherwise provided for by this Constitution

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STATEMENT OF FACTS

1. There in an industrial establishment “Hygienic Health Care Products Ltd.” in

“Apple island”, a state in the Union of Woodlands(Constitution and other laws
of Union of Woodlands are in perimeter with that of the Union of India). There
establishment was set of for 3 years employing nearly 100 in which 50% are
women. Abdul and Bavithra are co-employees and perform miscellaneous
works.
2. On New Year after taking lunch in a common dining hall sitting in the
adjacent seats Abdul and Bavithra were talking about their family. Abdul took
out a gift (Taj Mahal statue) with note written on it and gave it to Bavithra and
said he is giving her as a New Year gift. At that time she became shy and
hesitated to receive as everyone looking at her. She refuses to take it and said
she was not in a position to take it. But Abdul forcibly put that gift in her
handbag.
3. After that incident happened Bavithra had a sleepless night as the incident
comes in her mind repeatedly. Next day she consulted it with her close friend
Cathrine who was also a member of internal complaints Committee constituted
under the Woodlands Sexual Harassment of Women at workplace. As per her
suggestion Bavithra came forward and complaint against Abdul. After knowing
this incident Abdul went to Bavithra‟s home and apology for that and said he
had no intention to hurt her.
4. Bavithra moved by his apology and thought that she over thinks and acted in
instance Of Cathrine. Immediately she requested the internal committee about
settlement. Later at the first day of conciliation she was absent so the
proceedings ended in failure.
5. The internal committee conducted the inquiry by giving opportunity to both the
Parties to state their case in accordance with the service rule. In the inquiry
Abdul admitted the incident but pleaded not guilty as he has no intention. At
the conclusion internal committee gave its finding as Abdul guilty of sexual
harassment, causing criminal force, act intended to insult the modesty and
recommend employer to take action against him for sexual harassment as
misconduct in accordance with the service rules of respondent.

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6. Abdul challenged his termination before the Labour Court. He took the plea
that the Inquiry proceedings of the internal committee were vitiated by bias on
the part of its member Catherine in whose influence Bavithra complaint about
him. He also contended that the punishment allotted is excessive. The Labour
Court pronounced awards as the misconduct against Abdul proved and inquiry
proceedings conducted in Accordance with law. Labour Court ordered
reinstatement of Abdul in his original employment with continuity of service
but without back wages, holding that the workman deserves sympathy and an
opportunity should be given to reform. For ordering reinstatement the court
took into consideration special facts and mitigating circumstances.
7. Bavithra moved a writ petition before the High Court of Apple island for
quashing the award of Labour Court, Catherine moved a separate writ petition
against employer on the ground of right to privacy of women. Both the writ
petitions were taken up together for common hearing and disposal. The High
Court allowed the writ petition of Bavithra holding –
(i) When the labour court found that all the charges were proved
against Abdul, it cannot order reinstatement.
(ii) When the employer proved the plea of loss of confidence in
Abdul, the labour court ought not to have ordered reinstatement of
the workman. The writ petition filed by Catherine was allowed by
the High Court on the found that the right to privacy of the women
employees was violated by the employer who was under an
obligation to provide a safe environment to his employees at the
workplace. The High Court disallowed the contention of the
employer that the installation of the CCTV camera at many places
of the establishment would cause heavy financial burden.
8. Both Abdul and the employer have reached the doors of Supreme Court by
means of Special Leave Petition and Writ Appeal respectively against the
judgment of the High Court. The petitions and appeal are clubbed together by
virtue of the order of the Hon’ble Supreme Court of Woodlands. The Hon’ble
Court has the requisite jurisdiction for the adjudication of the present dispute.

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STATEMENT OF ISSUES

ISSUE NO PARTICULARS

1 Whether the employer proved the charges of misconduct framed

against Abdul.

2 The inquiry proceedings by the internal committee and the

subsequent disciplinary proceedings against are in violation of
the principles of law and natural justice.

3 Whether Abdul deserves sympathy on account of the special

mitigating circumstances as pointed out by the Labor court
warranting his reinstatement in service

4 Whether the quantum of punishment is excessive warranting a

lesser penalty in the place of dismissal from service.

5 Whether the plea of loss of confidence in the employee is

available to employer for its refusal to reinstate the employee
in service, in the facts and circumstances of the case.

6 Whether the defense provided under section 95 of Woodland

Penal code can be invoked by Abdul for disciplinary
proceedings initiated against him by the employer.

7 Whether the employer is justified in refusing to provide CCTV

camera facilities on the ground that the right to safe working
environment of the employees is not violated by him and that
will cause heavy financial burden to it.

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SUMMARY OF ARGUMENTS

1. Whether the employer proved the charges of misconduct framed against

Abdul. It is humbly submitted giving or offering gift to someone who is known
to you or having friendly relation with that person doesn’t amount to sexual
harassment as misconduct. As gift given by Appellant 1 to Respondent 1 was
in the knowledge of his wife who is also friend to respondent1 and the same
was given on the new years’ eve which does not show any Mens Rea or any
intention of sexual harassment from Appellant1.
2. Whether the inquiry proceedings by the internal committee and the subsequent
disciplinary proceedings against Abdul are in violation of the principles of law
and natural justice.
a. It is humbly submitted the aim of the rules of natural justice is to secure
justice or to put it negatively to prevent miscarriage of justice. The
person cannot act as Judge of a cause in which he himself has some
interest either pecuniary or otherwise as it affords the strongest proof
against neutrality. He must be in a position to act judicially and to decide
the matter objectively. As in our present case the member of the Internal
Committee who was also a close friend to the complainant. So she
cannot act as a judge of a cause as she has some interest as it affords
the strongest proof against neutrality so, the inquiry proceedings of the
internal committee were vitiated by bias on the part of respondent2
as the report of the inquiry was also prepared by her.
3. Whether Abdul deserves sympathy on account of the special mitigating
circumstances as pointed out by the Labor court warranting his reinstatement
in service.
a. It is humbly submitted the statement of objects and reasons has
specifically referred to the limitations on the powers of an Industrial
Tribunal. The Labour Court ordered reinstatement of Appellant 1 in his
original employment holding that the workmen deserved sympathy and
opportunity should be given to reform him, considering that he has got
more than 25 years of service before retirement.

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4. Whether the quantum of punishment is excessive warranting a lesser penalty

in the place of dismissal from service.
a. The punishment of discharging the person from the service imposed by
the employer is excessive and harsh which could lead the Appellant 1
and his family members to suffer from economic and mental
destruction. As with this case it must be noted that the harm caused to
Respondent 1 was so light that no person of ordinary sense and temper
would complaint of such harm.
b. The plea of loss of confidence in the employee is available to employer
for its refusal to reinstate the employee in service, in the facts and
circumstances.
c. It is humbly submitted that the employer cannot take plea of loss of
confidence in employee to refuse his reinstatement in service. Loss of
confidence by the employer in the employee is a feature which certainly
affects the character or reputation of the employee as the allegation of
loss of confidence amounted to a stigma. Appellant1 was in position of
trust and confidence so, while terminating his service he should consider
his past conduct.
5. The plea of loss of confidence in the employee is available to employer for its
refusal to reinstate the employee in service, in the facts and circumstances.
a. It is humbly submitted that the employer cannot take plea of loss of
confidence in employee to refuse his reinstatement in service. Loss of
confidence by the employer in the employee is a feature which
certainly affects the character or reputation of the employee as the
allegation of loss of confidence amounted to a stigma. Appellant1 was
in position of trust and confidence so, while terminating his service he
should consider his past conduct.

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6. Whether the defense provided under section 95 of Woodland Penal code

can be invoked by Abdul for disciplinary proceedings initiated against him
by the employer.
a. The defense provided under section 95 of Woodland Penal Code can be
invoked by Appelant1 for disciplinary proceedings initiated against him
by the employer. As the act of appellant1 was so slight that no person of
ordinary sense and temper would complain of such harm. As also
respondent1 was so confused about the things happens to her. Later
Appellant1 gets to know that she complaint under the influence of
respondent 2 who was also a member of Internal Committee.

7. Whether the employer is justified in refusing to provide CCTV camera

facilities on the ground that the right to safe working environment of the
employees is not violated by him and that will cause heavy financial
burden to it.
a. The appellant2 is justified in refusing to provide CCTV camera facilities
on the ground that right to safe working environment of the employees
is not violated by him and that it will also cause heavy financial burden
to it. By providing CCTV Camera facilities may hamper the individual
right to privacy. CCTV Cameras subjects individuals to the gaze of
people they do not want to be watched or observed by.

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ARGUMENTS ADVANCED
1. Whether the employer proved the charges of misconduct framed against
Abdul.
a. It is humbly submitted to the apex court that the charges against
Appellant1 of misconduct during his course of employment was
not proved by the employer. As stated in the fact that the gift given
by Appellant l does not signify any act related to misconduct as
sexual harassment1.
b. As the word Misconduct is a transgression of some established and
definite rule of action, a forbidden act, a dereliction from duty,
unlawful behavior, willful in character, improper or wrong
behavior; its synonyms are misdeed, misbehavior, delinquency,
impropriety, mismanagement, offense, but not negligence or
carelessness and does not include sexual harassment as
misconduct within its meaning.
c. These acts and omission include willful in-subordination,
disobedience, theft, fraud, dishonestly and habitual negligence.
d. Sexual Harassment is not an offence merely amounting to
disruption of law and order but it is an act of power, and a public
and collective violation that is often trivialized by labelling it an
interpersonal transgression2 In Our present case Appellant 1 gifted
the gift to respondent no. 1 in front of all the co-employees which
shows that his act was not misconduct.
e. It is the duty of employer or other responsible persons in work
places or other Institutions to prevent or deter the commission of
acts of sexual harassment and to provide the procedures for the
resolution, settlement or prosecution of acts of sexual harassment
by taking all steps required as per

a) 1 Section 2(n),The Woodlands Sexual Harassment Of Women At Workplace (Prevention, Prohibition And Redressal) Act,2013 (Act No. 14 Of
2013)
b) 2 Dr. B.N. Ray v. Ramjas College & Ors A.I.R.(2012) Del. H.C.
c) 3 The Management Of Christian Medical College And Hospital v. S.G. Dhamodharan (2019) IILLJ 487Mad.

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f. The guidelines given by the Hon’ble Supreme Court of India. In

our present case it was the duty of co-employees and Respondent
2 who was also the member of Internal Complaints Committee to
prevent the sexual harassment act as they were present when
Appellant 1 gifted the respondent no.1 which they do not
prevented which shows that the act was not a misconduct.
g. The motive of presenting a gift was neither past cohabitation nor
future cohabitation the court unable to hold that the object of the
gift was illegal and therefore, hold in disagreement with the
learned Civil Judge that contemplated future cohabitation was
2. The inquiry proceedings by the internal committee and the subsequent
disciplinary proceedings against are in violation of the principles of law
and natural justice.
a) It is humbly submitted to the Hon’ble Apex Court that the inquiry proceedings
by internal committee and subsequent disciplinary proceedings are in
violation of the Principles of natural justice.
b) It is true that the order is administrative in character, but even an
administrative order which involves civil consequences as already stated,
must be made consistently with the rules of natural justice. The aim of the
rules of natural justice is to secure justice or to put it negatively to prevent
miscarriage of justice. These rules can operate only in areas not covered by
any law validly made. In other words they do not supplant the law of the
land but supplement it. The concept of natural justice has undergone-
i. No one shall be a judge in his own case( Nemo debt esse judex
propria causa)

ii. No decision shall be given against a party without affording him

a reasonable hearing( Audi Alteram Partem)

4
Smt. Naraini v. Pyaremohan (1971) Raj HC.

5 State Of Orissa v. Dr. (Miss) Binapani Dei & Ors ,A.I.R (1967) S.C. 1269

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iii. Quasi-judicial enquiries must be held in good faith

without bias and not arbitrary5.
c) Being heard before the administrative body passes an order against him. As in
our present case-

a) Also to administrative order adversely affecting the party in question

unless the rule has been excluded by the act in question7.

b) A declaration that the punishment of dismissal awarded to him was illegal

and unconstitutional mainly on the ground that the enquiry had been held in
violation of t h e principles of natural justice and he was denied reasonable
opportunity of defense 8. In our present case there is audi alteram partem but
there was denial of reasonable

c) opportunity of defense, as petitioner admitted the incident which occurred

d) On 01.01.2019 but he also pleaded not guilty stating that he had no

intention to harass or cause any harm to Bavithra and as he acted in good
faith. These facts were not considered and gave its findings holding Abdul
guilty.

e) The person cannot act as Judge of a cause in which he himself has some
interest either Pecuniary or otherwise as it affords the strongest proof against
neutrality. He must be in a position to act judicially and to decide the matter
objectively. A Judge must be of sterner stuff. His mental
Equipoise must always remain firm and undetected.
f) He should not allow his personal prejudice to go into the decision-
making. The object is not merely that the scales be held even; it is also
that they may not appear to be inclined. If the Judge is subject to bias in
favor of or against either party to the dispute or is in a position that a bias
can be assumed, he is disqualified to

6
The Constitution of Woodlands,1950.
7
Delhi Transport Corporation v. D.T.C. Mazdoor , 1991 AIR 101.
8
Chandrama Tewari v. Union Of India, Through General, 1988 AIR 117.General, 1988 AIR 117.

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g) Act as a Judge, and the proceedings will be vitiated. This rule applies to
the judicial and administrative authorities required to act judicially or
quasi-judicially9. As in our present case the member of the Internal
Committee Respondent 2 (Catherine) who was also a close friend to the
complainant (respondent 1). So she cannot act as a judge of a cause as
she has some interest as it affords the strongest proof against neutrality
so, the inquiry proceedings of the internal committee were vitiated by bias
on the part of respondent 2 as the report of the inquiry was also prepared
by her.

3. Whether Abdul deserves sympathy on account of the special mitigating

circumstances in place of dismissal from service as the quantum
punishment is excessive.
h. It is humbly submitted to the Hon’ble Apex Court that the quantum of
punishment was excessive, where appellant 1 deserves sympathy on
account of mitigating circumstances the court should warrant less
penalty in place of dismissal from service. A court may set aside the
order of discharge or dismissal which are not justified and give such
other relief to the workman including the award of any lesser
punishment in lieu of discharge or dismissal as there circumstances of
10
the case may require .To avoid the charges of vindictiveness,
justice, equality and fair play demand that
Punishment must always be commensurate with the gravity of the offence charged
[Issue 3] SYMPATHY ON ACCOUNT OF MITIGATING CIRCUM
STANCES.
i. that the inquiry proceedings of the internal committee were vitiated by
bias on the part of its member Catherine (Respondent 2) Who
influenced Respondent 1 to make complaint against him and also
influenced the internal committee on the other hand to submit findings
against appellant1

9
Justice P.D. Dinakaran v Hon'Ble Judges Inquiry Committee, (2011) S.C.
10
Sec. 11-A, The Industrial Dispute Act, 1947 14 Of 1947).

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j. Court confirms the finding regarding misconduct, but only interferes

with the Punishment being of the view that it is excessive and awards a
lesser punishment, resulting in reinstatement of employee16. In a same
way in our present case after observing the fact labour court reinstate
Appellant 1 in his original employment with continuity of service but
without back wages. As court thinks that the workman
k. Deserves sympathy and an opportunity should be given to him to reform
himself. The discretion which can be exercised u/s 11A17 is available
only on the existence of certain factors like punishment being
disproportionate to the gravity of misconduct so as to disturb the
conscience of the court, or the existence of any mitigating circumstances
which require the reduction of the sentence other past conduct of the
workman which may persuade the labour court to reduce the
punishment18.
4. [Issue 4] QUANTUM OF PUNISHMENT SHOULD BE LESS THAN
DISMISSAL FROM SERVICE.

l. The object is stated to be that the tribunal should have power in cases,
where necessary, to set aside the order of discharge or dismissal and
direct reinstatement or award any lesser punishment. The statement of
objects and reasons has specifically referred to the limitations on the
powers of an Industrial Tribunal12.
The punishment of discharging the person from the service imposed
by the employer Is excessive and harsh which could lead the appellant 1
and his family members to suffer from economic and mental
destruction13. As with this case it must be noted that. The harm caused
to Respondent 2 was so light that no person of ordinary sense and

5. Whether the plea of loss of confidence in the employee is available to

employer for its refusal to reinstate the employee in service, in the facts
and circumstances of the case.

a) It is humbly submitted to the Hon’ble Apex Court that the appellant 2

cannot take plea of loss of confidence in employee to refuse his
reinstatement in service. Loss of confidence by the employer in the

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employee is a feature which certainly affects the character or reputation of

the employee as the allegation of loss of confidence amounted to a
stigma19.

b) The test for loss of confidence to find out as to whether there was bona
fide loss of confidence in the employee, observing that ,
i. The workman is holding the possession of trust and confidence ;

ii. By abusing such position he commits act which results in

forfeiting the same; and
iii. To continue him in service/establishment would be
embarrassing and in convenient to the employer, or would be
detrimental to the discipline or

iv. Security of the establishment.

v. Loss of confidence cannot be subjective, based upon the mind of the

management , objective facts which would lead to a definite

vi. Inference of apprehension in the mind of the management, regarding

trustworthiness or reliability of the employee must be alleged and
20
proved . As in our present case Petitioner no. 1 was in position of
trust and confidence so, while terminating his service he should
consider his past conduct.

vii. Also, petitioner never committed such act which results into
embarrassment and inconvenient to employer in course of
employment. The act which was done by the petitioner no. 1 was of
no such nature which result him in termination of his service.

6. Whether the defense provided under section 95 of Woodland Penal code

can be invoked by Abdul for disciplinary proceedings initiated against
him by the employer. It is humbly submitted to the Hon’ble Apex Court that
the defense
a) provided under section 95 of Woodland Penal Code can be invoked
by Appellant 1 for disciplinary
i. Proceedings initiated against him by the employer. As the act

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done by petitioner 1 to respondent1 was so slight that no person

of ordinary sense and temper would c o m p l a i n of such
harm. In this case respondent1 was so confused about the thing
happens to her, she was not sure about the act is wrong or not,
whether this is a major issue to complaint against Appellant 1.
Later, she made complaint under the influence of her friend
respondent 2 who was also a member of Internal Committee.
b) The Supreme Court held that whether an act which amounts to an
offence is trivial would undoubtedly depends upon the nature of the
injury, the position of the parties, the knowledge or intention with
which the offending act is done,
c) Respondent1 who was his childhood friend is of very petty nature which
cannot harms anyone’s feeling that much which cause her to complaint
against him.
d) Sexual harassment is not an offence merely amounting to disruption of
law and order. Sexual harassment is an act of power, and a public and
collective violation that is often trivialized by labelling it an
interpersonal transgression. It is therefore a violation of gender equality
e) And also, of the right to a safe education and work environment for all.
Sexual harassment not only affects a few individuals but reinforces
gender- based discrimination for everyone23. Appelant1 gifted
respondent 1 as a New Year gift is nowhere a violation of gender
equality. To gift someone, something which does not signifies any
sexual favor or sign to her is not amount to any such harm which caused
her to take major step towards it. As Appellant 1 gift to respondent 1 is
very normal, she was his childhood friend. He gifted her out of
friendship, it cannot cause that much harm that she actually
complaint about it and result it into termination of Abdul’s employment.
7. Whether the employer is justified in refusing to provide CCTV camera
facilities on the ground that the right to safe working environment of the
employees is not violated by him and that will cause heavy financial
burden to it?
a. It is humbly submitted to the kind perusal of the jurisdiction it is
justified to the appellant 2 in providing CCTV camera facilities on the
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ground that the right to safe working environment of the employees is

not violated by him and that it will cause heavy financial burden. As by
providing CCTV camera facilities may hamper the individual right to
privacy. Employees have the right to privacy, and intrusive and
disproportionate CCTV monitoring may breach this right. Breaches to
this right could manifest as filming in areas where individuals would
expect privacy, such as in toilets or break areas.
f) CCTV surveillance subjects individuals to the gaze of people they do
not want to be watched or observed by The said installation of CCTV
cameras and providing live feed of the same to anyone with a user id
g) Where surveillance technologies, including CCTV cameras, can
effectively monitor any individual’s location and movements. While
hundreds of millions are being spent worldwide on CCTV systems,
there is a little evidence of the success of CCTV to combat or deter
crime. These systems have not been properly evaluated. Majority of
people are not even aware of CCTV cameras neither aware
about the laws related to the issue. These footages of CCTV
cameras maybe misused stalking or personal abuse, majority of
people don’t feel conscious when being watched. This aims to
produce the impression of constant observation in the name of
security

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PRAYER

SR PARTICULARS
NO
1. In the light of arguments advanced an authorities cited, the petitioner humbly
submits that the Hon’ble Apex Court may be pleased to adjudge and declare
that:
2. Appellant 1 should be reinstated in service with full back wages and should
be awarded compensation for sufferings
3. There is no violation of safe working environment, by installing CCTV
camera it will cause heavy financial burden to Appellant 2.
4. Any other order as it deems fit in the light of Equity, law and Good
Conscience
5. For This Act Of Kindness, the Petitioner Shall Duty Bound Forever Pray

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