Writ in HIGH COURT Under Art.

226 of the Constitution of India or in

supreme court under art 32 .

For the issue of a writ of Certiorari : -

1. That the Petitioner is a stockist and dealer in drugs and carries on his business in the
name and style of _________at ______

2. That the Petitioner held a drug dealer’s licence No_________. dated _________ and has
been carrying on this business for the last six years.

3. That on _________ the Petitioner received a notice from Respondent No. 2 to show cause
why his licence should not be cancelled for selling substandard and spurious drugs. He was
also required by the notice to produce his licence before Respondent No. 2.

4. That on _________ the Petitioner submitted his explanation to the show-cause notice
submitting that he did not sell any substandard or spurious drugs and that he sold only drugs
in their original containers obtained from reputed drug manufacturers. He expressed his
inability to produce the licence as the same had been submitted to the Civil Surgeon for
renewal.

5. That without giving proper consideration to the pleas raised by the Petitioner Respondent
No. 2 passed an order dated _________ cancelling the Petitioner’s licence.

6. That, thereupon, the petitioner preferred an appeal against the order of Respondent No. 2
to Respondent No. 3.

7. That by order dated _________ Respondent No. 3 dismissed the appeal.

8. That the Petitioner has no other remedy but to approach this Hon’ble Court.

9. That the orders of Respondents No. 2 and No. 3 are void and illegal for the following
amongst other—

REASONS

(i) Because the orders of respondents Nos. 2 and 3 are vitiated as they have acted in
violation of the principles of natural justice.

(ii) Because both respondents Nos. 2 and 3 have placed great reliance on the report of the
Central Drugs Laboratory dated _________ which report was never disclosed to the
Petitioner and which the Petitioner was not given any opportunity to meet.

(iii) Because the authorities have been influenced by the failure of the Petitioner to produce
the licence but have themselves failed to consider the Petitioner’s explanation that the
licence had been submitted to the Civil Surgeon for renewal.

(iv) Because respondents Nos. 2 and 3 have not applied their minds to the facts and
circumstances of the case.

(v) Because the impugned orders violate the fundamental right of the Petitioner to carry on
his trade and business guaranteed by Article 19(1)(g) of the Constitution.

It is, therefore, most respectfully prayed that a writ, direction or order in the nature of
certiorari be issued quashing the order of Respondent No. 2 dated _________ and the order
of Respondent No. 3 dated_________

______________

(Petitioner.)

Dated_________

ISSUE OF WRIT OF HABEAS CORPUS :-

1. That the petitioner is a resident of _________. and he was living peacefully at his
residence at the place aforesaid.

2. That on _________. Respondent No. 1 made an order under Section 3 of the Conservation
of Foreign Exchange and Prevention of Smuggling Activities Act, 1974 by which he directed
that the Petitioner shall be arrested and detained for a period of three months. A copy of the
order is annexed herewith as Annexure 荘 A 鋳.

3. That the Petitioner was arrested the same day and was detained in _________Jail. The
grounds of detention were not supplied to the petitioner on that day. The grounds were
actually supplied on_________. A copy of the grounds supplied is annexed herewith as
Annexure 荘 B 鋳.

4. That on _________. the Petitioner submitted a representation against his detention

through Respondent No. 2 but the same was considered by the Advisory Board after one
month and was rejected on _________. . . .

5. That the grounds of detention supplied to the Petitioner were in English which language
the Petitioner does not know.

6. That the orders of detention of the Petitioner are illegal, improper and without jurisdiction
on the following:

GROUNDS

1. Because the Conservation of Foreign Exchange and Prevention of Smuggling Activities Act,
1974, is unconstitutional and void as it is beyond the legislative competence of Parliament.

2. Because the order has been passed by an officer not duly authorised.

3. Because the grounds were supplied after undue delay.

4. Because the grounds are in English which language the Petitioner does not know and this
has prevented him from making an effective representation.

5. Because the grounds are irrelevant to the object of the Act.

6. Because the grounds are vague.

7. Because there was undue delay in the disposal of the representation submitted by the
petitioner.

Wherefore it is respectfully prayed that this Hon 鍛 le Court may be pleased to issue a writ in
the nature of Habeas Corpus to the opposite parties quashing the order of detention and
directing that the Petitioner be set at liberty forthwith.

Date _________ Advocate for the Petitioner.

 WRIT OF MANDAMUS

IN THE HON 達 LE HIGH COURT OF JUDICATURE AT_____

(Original Civil Jurisdiction)

Writ Petition No_________of _________20_________

AA., son of _________resident of _________Petitioner;

Versus

1. Collector, _________.District

2. State of _________. Respondents.

Petition under Article 226 of the Constitution for the issue of a writ of mandamus.

To

The Hon 鍛 le the Chief Justice and his companion Judges of the Hon 鍛 le High Court of
Judicature at _________.

The above named Petitioner begs to submit as under:

1. That the Petitioner is the owner of a plot of land numbered _________in _________at
_________detailed in Annexure 荘 A 鋳 to this petition.

2. That on _________a notification under Section 4 of the Land Acquisition Act, 1894, was
published that certain land including the Petitioner 痴 aforesaid plot was needed for a public
purpose.

3. That the Petitioner filed objections to the proposed acquisition of his plot under Section 5-
A of the Act.

4. That the objections filed by the petitioner were heard by the Collector on _________and
thereafter he submitted his report with recommendations to the State Government.

5. That the State Government accepted the report and recommendations of the Collector and
rejected the objections filed by the petitioner.

6. That on _________the State Government made the declaration under Section 6 of the Act.

7. That on _________the Petitioner received a notice under Section 9 of the Act, to state his
claim to compensation for his plot which was under acquisition.

8. That on _________the Petitioner filed his claim to compensation claiming Rs_________as

compensation for the acquisition of his plot.

9. That on _________the Collector gave his award determining a sum of only

Rs_________as compensation for the Petitioner 痴 plot.
10. That the award was filed in the Collector 痴 Office and notice of the same was given to the
Petitioner.

11. That the compensation awarded by the Collector for the Petitioner 痴 plot was grossly
inadequate and the Petitioner did not accept it. On _________the Petitioner made an
application under Section 18 of the Act to the Collector requesting that the matter be
referred for determination to the District Judge.

12. That though under Section 18 the Collector was bound to refer the matter of
compensation to the District Judge he has declined to do so.

It is, therefore, most respectfully prayed that a writ, direction or order in the nature of
mandamus be issued to Respondent No. 1 directing him to refer the matter of compensation
for the Petitioner 痴 plot for determination to the District Judge . . . . . . .

AA.

Dated _________.

(Petitioner)

___________________

(Counsel for the Petitioner)

Mr. ………………………………, s/o. ………………………… village

……………….., district …………………….., at present detained
at……………………. District Jail at……….…………
Petitioner.

Versus

(1) The State of ……… }

(2) The District Magistrate, ……….. and } Respondents.
(3) The Superintendent, District Jail, ……… }

Hon'ble Shri ………………….……., Chief Justice Patna High court and his
companion Justices.
The humble petition of the petitioner above
named under Art. 226 of the Constitution of
India praying for a writ of habeas corpus or
 such other writs, direction or order as the
court may deem fit.
Most respectfully Sheweth:

1. That the petitioner is a respectable law-abiding citizen of India and was

arrested by the ………………… [City Name] ……….…… [State] Police on
the ………… day of……………. 20……. and is now confined as a detenu
under the orders of the second respondent in the custody of third
respondent in the District Jail at …………….

2. That the arrest and detention of the petitioner is illegal, mala fide and
capricious. His continued detention in the above circumstances is in direct
violation of his fundamental rights.

3……………………………………………

Grounds:

(i) ……………………………………………..

Your humble petitioner therefore begs to

pray that Your Lordships may be pleased to
issue rule nisi to the respondents directing
them to produce the petitioner before this
Hon'ble Court and to justify his detention in
accordance with procedure established by
law and that after hearing the parties, Your
Lordships may be pleased to issue a writ of
habeas corpus or other appropriate writ or
direction to set the petitioner at liberty.
For which the humble petitioner shall ever pray.