APPLICATION UNDER SECTION 19 OF THE

ADMINISTRATIVE TRIBUNALS ACT, 1985

LEGAL HEIRS OF CHINUBHAI CHAVDA v. SOIL SURVEY

OFFICER, SOIL AND LAND USE SURVEY OF INDIA

INDEX

Sr. No. Documents Relied Upon Page No.

1. Application
2.
3.
4.
5.

FOR USE IN TRIBUNAL’S OFFICE

SIGNATRE OF THE APPLICANT

 IN THE CENTRAL ADMINISTRATIVE TRIBUNAL
AHMEDABAD BENCH

ORIGINAL APPLICATION NO. OF 2024

BETWEEN

LEGAL HEIRS OF CHINUBHAI CHAVDA

… APPLICANT

VERSUS

SOIL SURVEY OFFICER, SOIL AND LAND USE SURVEY

OF INDIA
… RESPONDENT

ORIGINAL APPLICATION UNDER SECTION 19 OF THE

ADMINISTRATIVE TRIBUNALS ACT, 1985

MOST RESPECTFULLY SHEWETH:

1. PARTICULAR OF THE ORDER AGAINST WHICH
THE APPLICATION IS MADE

The Applicant is seeking appointment on compassionate basis in line

with the DOPT O.M. No. 14014/6/94-Estt. (D) dated 09.10.1998. It is
respectfully submitted that the Applicant has made two representations
to the … dated … and … however, the … has not passed any order or
taken any measures to address the representations made by the
Applicant. As such, in the absence of a final order being passed within
six months from the date of the last representation, the Applicant,
 relying upon Section 20 (2) (b) of the Administrative Tribunals Act,
1985, prefers the present application.

The Representations made by the Applicant herein to the … dated … and

… are annexed herewith and marked as Annexure P1.

2. JURISDICTION OF THE TRIBUNAL

The Applicant declares that the subject matter of this Original

Application is within the jurisdiction of this Hon'ble Tribunal as the
Applicant is seeking relief against the Respondents to the extent that
this Hon’ble Tribunal may be pleased to direct the Respondents to
consider the representations made by the Applicant before them, and
further direct the Respondents to provide a suitable appointment to the
Applicant on compassionate grounds.

3. LIMITATION

The Applicant further submits that this Application is within the time
limit as per Section 21 of the Administrative Tribunals Act, 1985.

4. FACTS OF THE CASE:

4.1. It is respectfully submitted that the Applicant is aged about twenty-five

years and that he is the son of the deceased Chinubhai Kalyanji Chavda.
The father of the Applicant was appointed by the Respondent Authority as
Driver and Since 1989, the father of petitioner was doing duty as a Driver
with the Respondent No.1, however during the tenure petitioner’s father
was promoted with higher Grade and subsequently, on dated 18/08/2005 the
petitioner’s father was promoted with Grade-I Jeep Driver. Copy of the
Appointment Letter, Promotion letter and Identity card issued by the
respondent authority is annexed herewith and marked as Annexure-A
(Colly).

5. GROUNDS WITH LEGAL PROVISIONS

6. DETAILS OF REMEDIES EXHAUSTED
7. MATTER NOT PREVIOUSLY FILED OR PENDING
BEFORE ANY OTHER COURT
8. RELIEF SOUGHT / PRAYER
9. INTERIM RELIEF
10. DETAILS OF BANK DRAFT / POSTAL ORDER
FILED IN RESPECT OF THE APPLICATION FEE
11. LIST OF ENCLOSURES

VERIFICATION

AFFIDAVIT