BEFORE THE HON’BLE CENTRAL ADMINISTRATIVE

TRIBUNAL, JAMMU.

The details of all the applicants and respondents in the case should be
furnished in the given below format:-

(i) Subject (Appendix vii of CAT Rules of practice, 1993)

Cancellation of Appointment

(ii) Ministry/Department )as per List attached)

J&K Health and Medical Education Department.

S No. Description Details

1 Type of O.A/T.P Original
2 No. of applicants 1
3 No. of Respondents 05
4 Applicant’s Name Deepika Sharma
5 Age 27 years
6 Group Nil
7 Sex female (Applicant)
8 Nationality Indian
9 Father’s Name Rajinder Kumar Sharma.
10 Residence Address R/o Opp H.No 856-B, Janipur
colony Jammu
11 Office address Nil
12 Email Address advocateshamas@gmail.com
13 Mobile No.of Applicant 09055448693
14 Phone No. nil
15 Fax Nil

Name of Advocate : H.A. SIDDIQUI & SHAMAS-UD-DIN SHAAZ(Advocate)

Address of Advocate:H.No.72-C Sector 2 Ganga Nagar Bantalab, Jammu
Mobile No. : 9419155312
Phone No. : 01912592146
Email: - : advocateshamas@gmail.com

Place:- Jammu
Dated

Signature of Advocate
 BEFORE THE HON’BLE CENTRAL ADMINISTRATIVE
TRIBUNAL, JAMMU.

OA_______2022

1. M/s Rumana Abass

D/o Mohd Abass
R/o Village Umar Mohalla
District Kishtwar – 182204.

………….APPLICAN
T

Versus

1. Union Territory of Jammu and Kashmir, Through its Commissioner/

Secretary, Health & Medical education Department, Civil Secretariat
Jammu.Pin 180001
2. Principal Govt. Medical College, Bakshi Nagar, Jammu.Pin180001.
3. Medical Superintendent Govt. Psychiatric Hospital Diseases, Bakshi
Nagar, Jammu.Pin180001.
4. Secretary J&K Service Selection Board, Bahu Plaza Jammu.
Pin 180012.
5. Director JK Board of School Education, Rehari Colony Jammu. Pin
180005.
6. Director National Institute of Open Schooling, A-24-25 Institutional
Area, Sector 62, Noida- Pin 201309.
7. Regional Director National Institute of Open Schooling, Ved Mandir
Road, 105. Amphalla Road Opposite Trikuta Yatri Niwas Karn Nagar
Jammu. Pin 180005.
…..…RESPONDENTS

IN THE MATTER OF:-

An application seeking recall of order dated 19-04-

2023 passed in diary no 3733 2020 titled Rumana
Abass V/s Directorate of technical education.

MAY IT PLEAS YOUR HONOUR,

The applicant respectfully submits as under.
 1. That applicant filed aforesaid OA through Shri Md Qazi Advocate
seeking continuation in service. It appears that in the registry
pointed out certain defects in the OA which were required to be
removed which the ld counsel never informed the applicant nor
removed the defects as pointed out by the registry.
2. That a direction was issued to the registry to return the pleadings
to the applicant. Copy of order dated 19-04-2023 is enclosed
____________
3. That once the OA was admitted for hearing on 21-09-2020, it
could not have been disposed off in a manner it has been done in
terms of order dated 19-04-2023.
4. That the applicant came to know about the order dated 19-04-
2023 on 15-05-2023 and obtained the copy of order on 15-05-
2023 and this application is being moved immediately for recall of
the said order and for entertaining the OA for disposal on its
merits.
5. That applicant is legally disabled and was advised by the ld
counsel not to attend the court on each and every date as he will
pursue the matter with due diligence however it appears that for
reasons best known to the counsel, he neither informed the
applicant about the defects pointed out by the registry nor himself
removed the defects himself as a result whereof an expert order
was passed on 19-04-1023 which has the effect of virtually
rejecting the application of the petitioner without decision on its
merits.
6. That the application is well within time.
7. Affidavit in s
8.

Prayer-

Your honour may be pleased to allow the application and recall order
dated 19-04-2023 by directing the registry to trace the said OA
registered under diary no 3733/2020 and list the same before the Honble
CAT for appropriate order. In the event of listing the same the applicant
undertakes to remove the defects as pointed out by the registry.
 BEFORE THE HON’BLE CENTRAL ADMINISTRATIVE
TRIBUNAL, JAMMU.
OA_______2022

DEEPIKA SHARMA ………..Applicants

Versus
UNION TERRITORY OF JAMMU AND KASHMIR AND OTHERS.
……Respondents/ Non-Applicant

LIST OF DATES AND EVENTS

S.No DATE EVENTS

1 1994 That the applicant is an unfortunate daughter of Shri Rajinder
Kumar Sharma who has disappeared in the year 1994 when the
age of the applicant was only few days (DOB- 15-12-1994). The
applicant was raised by her mother. Later on the mother of the
applicant suffered from depression due to missing of her
husband.
2 2010 That with great struggle and financial crises the applicant
continued her studies up to 8 th standard and passed 8th class
from Govt High School Janipur Jammu.The Applicant came to
contacted a lady teacher namely Smt. Koushalya Abrol who
was working in a private school namely Tiny Tots Higher
Secondary School extended the promise to the Applicant and
her mother to help her in pursuit of her further studies. The said
lady teacher asked the applicant to furnish her middle pass
certificate besides other requisite documents so as to get the
Applicant admitted directly in class 10 th under an open school
system known as National Institute of Open Schooling.
Applicant got her admission in National Institute of Open
Schooling through regional centre at Jammu in the year april
2010.
3 2016 That on the basis of the documents as furnished to the
Applicant by said Smt. Koshalya Abrol, Applicant approached
JK Board of School Education Jammu for her registration as
Applicant intended to continue her further studies through JK
Board of School Education Jammu for class 11th and 12th got
admission in 11th in Tiny Tots Higher Secondary School which
is a JK Board of School Education Jammu and successfully
pass the exam of 12th class in the year 2016.
4 2021 That based on the said qualification of being 12 th pass Applicant
 got admission in B.A through distance mode of learning from
university of Jammu in the subjects General English, Education,
Psychology and Philosophy and completed the 3 years degree
course through distance mode from university of Jammu in the
year 2021.
5 26-06-2020 That Applicant was in search of a govt. job due to her poor
economic conditions and serious domestic problems when
Jammu and Kashmir Service selection Board issued
Advertisement Notice No.1 of 2020 dated 26-06-2020 inviting
application form eligible candidates for appointment of class 4 th
vacancies.
6 22-10-2021 That Applicant being fully eligible participated in the selection
process initiated by JKSSRB for class 4th vacancies laying
down the Advertisement Notice No.1 of 2020 dated 26-06-2020
and participated in the written test conducted by the SSRB.
The result of said test was compiled and notified by the JK
SSRB vide Govt. Order No.669-JK (HME) of 2021 dated 22-
10-2021. In terms of the said notification, Applicant was placed
at Serial No.44 having been selected with merit under
economically weaker section category.
7 17-11-2021 That after declaration of the result SSRB verified the academic
record of the Applicant and she was sponsored/recommended
for appointment against the class 4th vacancy in Health and
Medical Education Department. Acting on the recommendation
of JK SSRB the Health and Medical Education Department
issued Govt. order No.392/AHJ of 2021 dated 17-11-2021
thereby appointing the Applicant against the class 4th vacancy
in GMC Jammu.
18-04-2022 That to the surprise for the Applicant that her 10 th class marks
card was reported not to be genuine and seems to be fake.
20-09-2022 That respondent without providing opportunity of being heard in
violation of principle of natural justice cancel the appointment
order of the applicant vide order bearing No. 681-JK(HME) of
2022 dated 20-09-2022 issued by respondent no. 1.Hence this
petition.

Applicants
Through Counsel

Place:Jammu.
Dated: SHAMAS-UD-DIN SHAAZ
 ADVOCATE
Mob.9419155312.
BEFORE THE HON’BLE CENTRAL ADMINISTRATIVE
TRIBUNAL, JAMMU.
OA_______2022

DEEPIKA SHARMA ………..Applicants

Versus
UNION TERRITORY OF JAMMU AND KASHMIR AND OTHERS.
……Respondents/ Non-Applicant

IN THE MATTER OF: -

Affidavit in support of O.A.

I, Deepika Sharma Age 27 years D/o Rajinder Kumar R/o

Opposite House No. 856-B Janipur Colony Jammu , do hereby
solemnly affirm and declare that the accompanying O.A has been read
over and explained to me and the contents of the para No.____ to ____
of the application are true and correct as per my personal knowledge
and those of remaining paras ____ to ____ are based on legal advice.

The deponent is the petitioners in the above titled application, he

is well versed with the facts and circumstances of the case, hence is
competent to swear the instant affidavit.

I solemnly swear/affirm that the affidavit is true, no part of this is false

and nothing has been concealed.
PLACE: JAMMU
DATED:

DEPONENT