IN THE HIGH COURT OF KARNAQTKA AT

BENGALURU
(Original Jurisdiction)
Writ Petition No.22432/2023 (EDN)
Between:
Ideal Educational society …. Petitioner
And
Rajiv Gandhi University
Of Health Sciences …. Respondent

Memo for Production of Photographs/Documents

The Petitioner hereby humbly Submits as follows: -
1. The Petitioner seeks leave of this Hon’ble court to produce
photographs which depicts the extent of Construction
/Infrastructure put up by the petitioner for the purpose of
petitioner’s nursing college i.e., Dr. N B college of Nursing,
Chitradurga. The photographs are produced along with
the present Memo marked as Document -1 to 6.

2. The petitioner further seeks leave to produce copies of

Invoice/purchase receipt for having purchased various
equipments and books for the purpose of petitioner’s
nursing college i.e., Dr. N B college of Nursing,
Chitradurga. Copies of the Invoice/Purchase receipt are
produced herewith as Document -7 to 14.
 3. The Petitioner also seeks leave to produce documents
which demonstrate that the Respondent University has
considered and recommended for grant of Affiliation in
respect of institutions where the number of availability of
beds are certified by the KPME to be numbered 50 in the
parent Hospital. In respect of ‘Shree Sadguru
Kabeerananda Swamy Institute of Nursing
Sciences’ the respondent has taken note of availability of
50 beds in ‘Chitradurga Multispecialty Hospital’ and
recommended for grant of affiliation. Also, in respect of
‘Jhanhavi Institute of Nursing Sciences’ the
respondent has once again taken note of availability of 50
beds in ‘Akshaya Global Hospital’ and recommended
for grant of affiliation. Copies of the relevant documents
are produced herewith as Document -15 to 16.

Wherefore it is prayed before this Hon’ble Court be

pleased to take the present memo along with the above
produced documents on record in the interest of Justice and
Equity.

Bengaluru
Date: - Advocate for Petitioner
 IN THE HIGH COURT OF KARNAQTKA AT
BENGALURU
Writ Petition No.22432/2023 (EDN)
Between:
Ideal Educational society …. Petitioner
And
Rajiv Gandhi University
Of Health Sciences …. Respondent
INDEX
SI No. Particulars Page No.
1. Memo for Production of Photographs/Documents 1-2
2. Document No. 1 Copy of Photograph of Dr. N B college of Nursing, 3
Chitradurga
3. Document No. 2 Copy of Photograph of Dr. N B college of Nursing, 3
Chitradurga
4. Document No. 3 Copy of Photograph of Dr. N B college of Nursing, 4
Chitradurga
5. Document No. 4 Copy of Photograph of Dr. N B college of Nursing, 4
Chitradurga
6. Document No. 5 Copy of Photograph of Dr. N B college of Nursing, 5
Chitradurga
7. Document No. 6 Copy of Photograph of Dr. N B college of Nursing, 5
Chitradurga
8. Document No 7 Copy of the Purchase invoice for books 6-7
9. Document No. 8 Copy of the Purchase invoice for books 8-9
10. Document No. 9 Copy of the Purchase invoice for books 10-14
11. Document No. 10 Copy of the Purchase invoice for books 15
12. Document No. 11 Copy of the Purchase invoice for books 16-17
13. Document No. 12 Copy of the Purchase invoice for equipments 18
14. Document No. 13 Copy of the Purchase invoice for equipments 19
15. Document No. 14 Copy of the Purchase invoice for equipments 20-25
16. Document No. 15 Copy of the document pertaining to Shree Sadguru 26-27
Kabeerananda Swamy Institute of Nursing Sciences’
17. Document No. 16 Copy of the document pertaining to Jhanhavi Institute 28-29
of Nursing Sciences’

Bengaluru
Date: - Advocate for Petitioner