IN THE SUPREME COURT OF INDIA
CIVIL ORIGINAL JURISDICTION
WRIT PETITION (CIVIL) NO.________ OF 2015
(Under Article 32 of the Constitution of India)
IN THE MATTER OF:
ARJUN GOPAL &Ors.,

…

Petitioners
VERSUS
UNION OF INDIA&Ors.,
Respondents

PAPER BOOK
(FOR INDEX PLEASE SEE INSIDE)

…

 ADVOCATE FOR THE PETITIONERS: PoojaDhar

INDEX
S.No.
1.
2.
3.
4.
5.

Particulars
Office Report on Limitation
Listing Proforma
Synopsis and List of Dates
Writ Petition with affidavit
ANNEXURE P-1:A true copy of “The ambient air
and noise quality in India during Diwali festival:
A review” Recent Research in Science and
Technology, 2014, 6(1): 203-210 dated NIL.

6.

ANNEXUREP-2:A true copy of “Potential impact of
fireworks on respiratory health” by Gouder C,
Montefort S, Lung India 2014;31:375-9 dated
NIL.

7.

ANNEXURE P-3: A true copy of “Assessment of the
Impact of Fireworks on Ambient Air Quality”by
Sapan Bhatnagar and Shubham Dadhich,
IJRASET, Volume 3, Issue IV, April 2015 dated
NIL.

8.

ANNEXURE P-4: A true copy of “The effects of air
pollution on the health of children” Paediatr
Child Health, 2006 Oct; 11(8): 513–516 dated
NIL.

9.

ANNEXURE P-5: A true copy of the 2005 World
Health Organization report on air pollution and
respiratory diseases dated NIL.

10.

ANNEXURE P-6: A true copy of “Air Pollution and
its Impact on Lung Function of Children in Delhi”
by S.Siddique, et al., cited as Environ We Int. J.
Sci. Tech. 5 (2010) 163-175 dated NIL.

11.

ANNEXURE P-7: A true copy of“Beijing Better
Than Delhi”published in the Hindustan Times
dated 22.04.2015.

12.

ANNEXURE P-8: A true copy of a report in the
Daily Mail 05.05.2015 showing findings of two
studies which show 1 in 4 children in Delhi have
unhealthy lungs.

13.

ANNEXURE P-9: A true copy of The Hindustan
Times report of04.06.2015 about a 12 year old

Page Nos.
A
A1 - A2
B–
1–

 boy who has asthmatic attacks due to Delhi
NCR’s bad air quality
14.

ANNEXURE P-10: A true copy of the Times of
India News Report published on 27.06.2015
about the rising levels of PM1.

15.

ANNEXURE P-11: Atrue copy of the article on
India Today on 29.06.2015 reporting how
successive Delhi Governments have failed to
utilize Rs. 385 Cr. of funds collected to reduce
pollution on the Environment

16.

ANNEXURE P-12:A true copy of an NDTV report
on 23.07.2015 where research conducted by the
government has shown that 80 people die per
day on average according to data collected from
2002-2005 due to Air Pollution

17.

ANNEXURE P-13: Atrue copy of The Economic
Times article on 25.08.2015 about the admission
of bad Air Quality of Delhi by Union Ministry of
Environment

18.

ANNEXURE P-14: A true copy of a Times of India
report on 28.08.2015 about a University of Texas
study that reveals that Air Pollution can affect
grades

19.

ANNEXURE P-15: A true copy of detailed
accounts of expats who are leaving New Delhi for
locations with better air quality published in The
Economic Times on 07.06.2015.

20

I.A.NO.___/2015:APPLICATION FOR STAY
IN THE SUPREME COURT OF INDIA
CIVIL ORIGINAL JURISDICTION
WRIT PETITION (CIVIL) NO.________ OF 2015
(Under Article 32 of the Constitution of India)
IN THE MATTER OF:
ARJUN GOPAL &Ors.,
VERSUS

…Petitioners

 UNION OF INDIA &Ors.,

…Respondents

OFFICE REPORT ON LIMITATION
The Petition is within time.

New Delhi
Dated: __.09.2015
OFFICER

BRANCH

 A1
LISTING PROFORMA
IN THE SUPREME COURT OF INDIA
SECTION PIL(W)
The case pertains to (Please tick / check the correct box):
Central Act (Title)
Provision

:
:

NA
NA

Central Rule (Title)

:

NA

Rule No(s)

:

NA

State Act

NA

Provision(s)

:

NA

State Rule (Title)

:

NA

Rule No(s)

:

NA

Impugned Interim Order

:

NA

Impugned Final Order

:

NA

High Court

:

NA

Names of Judges

:

NA

Tribunal/Authority

:

NA

1. Nature of Matter

:

Civil

2.
(a)Petitioner No. 1
(b) Email ID
(c) Mobile Number

:
:
:

Arjun Gopal
[...]
[...]

(a)Respondent No. 1
(b) Email ID
(c)Mobile Number

:
:
:

Union of India
NA
NA

3.

4. Classification
(a)Main category
(b) Sub classification

:
:

 A2
5. Not to be listed before

:

NA

6. Similar/Pending Matter

:

NA

7. Criminal Matters

:

NA

8. Land Acquisition Matters

:

9. Tax Matters
10.

:

Special Category

NA

NA
:

NA

Senior
Citizen

SC/ST

Woman/Child

Disabled

Legal Aid

In custody

11.
Vehicle Number
:
NA
(in case of Motor Accident Claim matters)
12.

Decided cases with citation

Date :__.09.2015
Petitioners

Advocate
Name :
Code :
E-mail :

:

on

NA

Record

for

 2

SYNOPSIS
Over the last 2 years, Delhi has retained the unique
distinction of being the most polluted city in the world. The
levels of particulate matter are highest, and across the
country, over 700,000 deaths occur annually due to air
pollution related diseases. Studies show that citizens have
30% lower lung capacity than Europeans, and that the
children are the worst affected, as their lungs have not yet
fully developed and their vulnerable systems are made
vulnerable. In Delhi, a majority of the pollution is caused by
over 500 million tons of crop residue burning that happens in
the States around the capital, by polluting trucks that pass
through the city at night and road dust and industry. To add
to this, in the months of October and November, the festivals
of Dussehra and Diwali lead to massive risks to lung disease
with firecrackers and fireworks clogging the atmosphere.
The present Writ Petition is filed by and on behalf of 3 infants,
all

citizens

of

Delhi,

seekinginter

aliathe

immediate

intervention of this Hon’ble Court against theinevitable and
upcoming widespread use of firecrackers and fireworks and
other products of the same classification, especially during
the festivals of Dussehra and Diwali, but thereafter in all
other events and festivals as well. While considerable debate
and long-term measures are being discussed by the slow
moving state machinery for implementation of measures to
control pollution levels in Delhi, this Hon’ble Court is duty
bound under Article 32 to take interim steps in effectuating

 3

the people’s right to clean, healthy and breathable air under
Article 21 of the Constitution of India.
This Hon’ble Court has directly monitored the harmful effects
of air pollution on India inter alia with its following orders:

 Directing

relocation

of

noxious

and

polluting

industries in M.C.Mehtav. Union of India, (1996) 4
SCC 750

 After

accepting

the

Report

of

the

BhureLal

Committee, laying down a clear time frame within
which there would be a conversion of commercial
diesel vehicles to CNG and several other measuresin
M.C.Mehtav.

Union

of

India

(Delhi

Vehicular

Pollution), (1998) 6 SCC 63.

 Closing down of brick kilns in M.C.Mehtav. Union of
India, (1998) 9 SCC 149.

 Directing the National Highways Authority of India
(NHAI)

to

be

the

nodal

agency

to

carry

out

completion of the construction of bypasses and
expressways in M.C.Mehtav. Union of India, (2004)
10 SCC 180.
Clearly, therefore, a Writ Petition for preservation of ecology
and the environment will be maintainable under Article 32
due to violation of Article 21.
Firecrackers use charcoal, sulphur and potassium nitrate
with aluminium instead of or in addition to charcoal in order
to

brighten

the

explosion.Sparklers

use

oxidisers

like

 4

potassium nitrate. The fuel is charcoal and sulphur, with a
binder which can be sugar or starch. Aluminium, iron, steel,
zinc or magnesium dust is added to create bright, shimmering
sparks.Fireworks generate a variety of air pollutants, like
carbon monoxide, sulphur dioxide and nitrogen oxide, in
addition to aerosols or particulate matter that worsens lung
conditions like asthma.
While Article 25 of the Constitution guarantees the right to
profess, practice and propagate religion, and hence celebrate
festivals with all fervour and enthusiasm, it restricts such
celebration on grounds of public order, morality and health.
In this Writ Petition the main ground for seeking this Hon’ble
Court’s intervention is that the historic and beautiful city of
Delhi is slowly being poisoned with the worst quality of air
that is being consumed daily by the people of Delhi, and the
needless and harmful fad of celebrating festivals with
firecrackers is the last nail in the coffin.
This Hon’ble court in M.C.Mehta v. Kamal Nath and Others,
(1997) 1 SCC 388 held that the government is under a strict
obligation to hold the natural resources of the countryRivers, air, sea-shores, forests, flora and fauna as a trustee.
The court, after discussing the jurisprudence on the subject
of Public trust, stated:
“Our legal system - based on English Common Law includes the public trust doctrine as part of its
jurisprudence. The State is the trustee of all natural
resources which are by nature meant for public use and
enjoyment. Public at large is the beneficiary of the seashore, running waters, airs, forests and ecologically

 5

fragile lands. The State as a trustee is under a legal duty
to protect the natural resources”
Based on the above judgement, it is amply clear that even
though the State and Central Governments are protectors of
our natural resources, they are taking no effective steps to
curb the growing menace of air pollution. The only way to
effectuate rapid, wide-spread change in air pollution is by
making urgent efforts to address this rising concern, and in
the meantime, take all precautions and measures in the shortterm to stop further air pollution from needless and equally
harmful sources such as fireworks.
Diwali is the biggest festival in India celebrated all
across the country regardless of sub-sects of Hinduism. Being
a festival of lights and an auspicious occasion, public places,
monuments, roads etc. were cleaned and beautified; People
repainted and cleaned their homes, the most common and
popular way to celebrate the festival of light was by lighting
“Diyas”

or

earthen

lamps

which

used

biodegradable

ingredients such as “ghee” and cotton to have a slow burning
candle

effect.

But

in

modern

times

especially

after

Independence, lighting fireworks has become a popular way
to celebrate Diwali across India with several factories for the
same set up in the Sivakasi region of Tamil Nadu. But due to
increase in population and increase in demand for such
fireworks, they not only became more widespread in use
around Diwali but also more dangerous. Apart from the risk
of death or grievous injury, it also now poses a silent threat to
life around festival time.

 6

The quality of air in major cities in India is degrading
by the day due to heavy traffic and industrialization, but this
needless new gimmick in the name of celebration is posing a
risk not only to us but our children and generations of Indians
yet to be born. The amount of toxins and particulates released
by fireworks are well documented by various research studies
and scholarly papers. Apart from air pollution, the harmful
effects through noise pollution due to fireworks is also well
documented and particularly in the development of the
children of our country.
The millions of Delhi residents who live in this toxic, unclean
air have no hope or respite but to either wait for the
government or legislature to take steps or to seek this
Hon’ble Court’s help in enforcing their fundamental right to
life which is being slowly choked by Delhi’s deadly air.
LIST OF DATES
1940

Indian Explosives Rules enacted wherein a
system

of

licensing

was

introduced

for

manufacture, possession and sale. The first
organized factory of the fireworks industry
set up at Sivakasi, Tamil Nadu.
2001

Number of factories in Sivakasi region for
manufacture

of

fireworks

and

matches

increases to more than 450.
2005

This Hon’ble Court in Noise Pollution(V), In
Re, (2005) 5 SCC 733 laid down directions

 7

for use of fireworksto control their impact on
Noise Pollution and held that uncontrolled
use of firecrackershas a harmful impact on
the

environment through Noise and Air

pollution.
23.06.2014

An NDTV News report stated that the Union
Environment Ministry in its reply to the Rajya
Sabha claimed that an alarming 80 people
die every day due to Air Pollution. The above
figures have been released based on the
‘Epidemiological Study on Effects of Air
Pollution on Human Health in Delhi' during
2002-2005 and 'Study on Ambient Air Quality,
Respiratory Symptoms and Lung Function of
Children in Delhi' that was done between
2003-2005

2014

The World Health Organization study of 1600
cities across 91 countries ranked New Delhi
as the worst city in the world in terms of
Ambient Air quality calculated in terms of
amount of particulate matter (PM 10 and
PM2.5) in the air.

27.06.2015

A news article published in Times of India
stated that Delhi Air, apart from having two
of the worst pollutants i.e. PM10 and PM2.5
in

high

levels,

has

the

worst

type

of

 8

suspended particulate matter (PM1) in large
quantities, and that these are the primary
source of cardiovascular diseases according
to a Chinese study since they can easily enter
the blood stream.
29.06.2015

An article on the India Today online Magazine
reported that a Planning department report
has

shown

Governments

that
in

the

successive
past

7

Delhi

years

have

collected close to Rs. 385 Crores for pollution
control through a 0.25 paise Environment
Cess,

yet

87%

of

those

funds

remain

unutilized. The Rs. 49.57 Croresthat was
utilized was for reimbursing the concession
on Battery operated vehicles.
07.08.2015

A

news

report

in

The

Huffington

Post

reported that the Environment ministry has
submitted a report to the Rajya Sabha that
more than 35000 people have died due to
acute respiratory diseases in the period
between 2006 and 2015. The report also
states that a joint study was conducted by the
Central Pollution Control Board with the
Chittranjan National Cancer Institute which
focussed on the effects of air pollution in
causing cancer in children.

 9

25.08.2015

An article in the Economic Times stated that
the Union Minister for Environment has
admitted to Delhi being one of the worst
polluted cities of the world and the need to
monitor indoor air quality which itself is
rising to unhealthy levels in most areas of
Delhi.

28.08.2015

A University of Texas study of effects of toxic
air on 1,895 fourth and fifth grade school
students in Texas reveals that children’s
grades are affected due to exposure to air
pollution. The study states that neurological
damage due to air toxins could be one of the
reasons for lower grades

__.09.2015

Hence, the present Petition under Article 32
of the Constitution of India.

 1

IN THE SUPREME COURT OF INDIA
CIVIL ORIGINAL JURISDICTION
WRIT PETITION (CIVIL) NO.________ OF 2015
(Under Article 32 of the Constitution of India)
IN THE MATTER OF:
1. Arjun Gopal
Aged 6 months
Through Next Friend
Gopal Sankaranarayanan,
[...],
New Delhi – 110070.
2. Aarav Bhandari
Aged 6 months
Through Next Friend
Amit Bhandari
[...],
New Delhi – 110076.
3. Zoya Rao Bhasin
Aged 14 months
Through Next Friend
Saurabh Bhasin,
[...],
New Delhi – 110017.
PETITIONERS

…

VERSUS
1. Union of India
Through the Secretary,
Ministry of Environment, Forests & Climate Change,
Shashtri Bhawan
New Delhi – 110001
2. Central Pollution Control Board
Through the Secretary,
Parivesh Bhawan,
CBD-cum-Office Complex,
East Arjun Nagar,
New Delhi – 110032
3. Delhi Pollution Control Committee
Through the Secretary,
6th Floor, ISBT Building,
Kashmere Gate,
Delhi – 110006.

 2

4. The Delhi Police Licensing Unit
Through its Joint Commissioner of Police,
1st Floor, Police Station, Defence Colony,
New Delhi – 110040.
…
RESPONDENTS
A PETITION UNDER ARTICLE 32 OF THE CONSTITUTION
OF INDIA FILED IN PUBLIC INTEREST
To,
Hon’ble the Chief Justice of India and
His Companion Judges of the
Supreme Court of India
MOST RESPECTFULLY SHOWETH:
1. The present Writ Petition is filed by and on behalf of 3
infants, all citizens of Delhi, seeking

inter alia the

immediate intervention of this Hon’ble Court against the
inevitable and upcoming widespread use of firecrackers
and fireworks and other products of the same classification,
especially during the festivals of Dussehra and Diwali, but
thereafter in all other events and festivals as well. While
considerable debate and long-term measures are being
discussed

by

the

slow

moving

state

machinery

for

implementation of measures to control pollution levels in
Delhi, this Hon’ble Court is duty bound under Article 32 to
take steps in effectuating the people’s right to clean,
healthy and breathable air under Article 21 of the
Constitution of India.
THE PARTIES
2. All the 3 Petitioners are between 6 and 14 months of age,
are citizens of Delhi and are filing the present Petition
through their fathers who acts as their next friends/legal
guardians. The Petitioners seek to enforce their guaranteed
right under Article 21 of the Constitution to a clean and

 3

pollution free environment. The inaction by the Government
authorities in not taking due steps to ensure that the dust,
smog and suspended particulate matter in the air of Delhi
are reduced has compelled the approach to this Hon’ble
Court.
3. All the 4 Respondents herein are ‘State’ for the purposes of
Article 12 of the Constitution and public authorities against
whom a Petition under Article 32 is maintainable. The
details of the Respondents are as follows:
i. Respondent No. 1 is the Central Government through
the nodal Union Ministry of Environment and Forests
which

is

tasked

with

the

initiation

and

implementation of all steps for the protection of the
Environment. Under its auspices are the measures to
ensure there is no air pollution.
ii. Respondent No. 2 is the Central Pollution Control
Board (CPCB) which is a statutory body constituted
under the Water Act, 1974 and the Air Act, 1981. One
of its main tasks is the monitoring of air quality
through the National Air Monitoring Programme
(NAMP). Both the laying down of standards and the
execution of programmes for the prevention and
control of air pollution are specific functions of the
CPCB.
iii. Respondent No. 3 is the nodal environmental agency
for the Government of Delhi to which the Central
Pollution Control Board has delegated certain powers
and functions as a State Board as specified by the

 4

Central Government in March, 1991. This committee
has been reconstituted on 14th June 2002 vide
notification No. B-12015/7/92-AS.
iv. Respondent No.4 is the licensing unit of the Delhi
Police responsible for granting temporary licenses
for the sale of fireworks. No licenses are required for
stock less than 100kgs, but most of these licences
are applied for in advance of the Diwali season and
granted by this authority.
THE CAUSE OF ACTION
4. The facts that lead to the cause of action for the present
Petition is the alarming rate of deterioration of the quality
of air in Delhi due to air pollution caused by, but not limited
to, traffic congestion, dust from widespread construction,
industrial pollution and the seasonal use of firecrackers.
5. The timely intervention of this Hon’ble Court in the year
2005, in a Public Interest Litigation, Noise Pollution (V) In
Re, facilitated the implementation of directives in usage of
firecrackers and changing the basis for evaluation of these
firecrackers from amount of noise produced to chemical
composition. Although not enforced fully in practice due to
the lax nature of enforcement authorities, these directions
have substantially reduced the amount of noise pollution
caused by firecrackers during festivals in residential
colonies, thereby giving great relief to residents and also
ensuring higher safety standards due to the change in basis
of evaluating the firecrackers.

 5

6. The present Petition is based on authentic information and
public

documents

sourced

from

the

World

Health

Organisation, authentic news reports, opinions and writings
of eminent experts and scholars on environment and other
publicly available information.
BACKGROUND
7. In the early Twentieth Century, the fireworks industry
began in India by importing “Sparkle” fireworks from
Germany and UK. The first indigenous factory for making
fireworks began operations in 1940 after the Indian
Explosives Rules were enacted whereby licensing for
manufacture, possession and sale of fireworks was granted.
By 2001, there were 450 factories in the Sivakasi Area of
Tamil Nadu engaged in the production of Fireworks. This
just shows the magnitude and scale of the fireworks
industry in India, where the demand to burst crackers for
enjoyment during festivals all around the year is insatiable,
but at the cost of completely destroying the ecology with air
pollution caused by these fireworks.
8. With the advent of Industrial Development around big cities
like

New

Delhi

and

increasing

road

traffic

and

developmental construction going round the clock since the
past

25

years,

Delhi’s

air

is

suffering

the

worst

consequences. There have been several representations to
the Government to take measures to control air pollution,
and

also

to

Governments

this
sit

Hon’ble
with

a

court

to

interfere

lackadaisical

when

attitude

on

strategizing how to combat air pollution. While the above

 6

mentioned causes of Air Pollution as a necessary evil in
developing Delhi to a great world-class city, the needless
pollutants like fireworks that heap on the already miserable
air quality of Delhi should be stopped for the sake of the
millions of people living in Delhi. This Hon’ble Court was
approached in Noise Pollution(V), In re; (2005) 5 SCC 733to
curb the problem of Noise pollution. This Hon’ble Court
passed orders restricting use of fireworks during only a
specific time period from 6AM to 10 PM and changed the
basis of evaluating fireworks from noise level to chemical
composition. The Apex court also acknowledged how
fireworks are a needless air and noise pollutant and its use
must be restricted in the following words:

“Fireworks are used all over the world to celebrate
special occasions. In India, fireworks are burst on
festivals like Dussehra, Diwali and on special occasions
like social gatherings, marriages, Independence day,
Republic day, New year day, etc. In other countries of the
world, fireworks are generally burst either on the New
Year day or on the birthday of their respective countries.
However, bursting of firecrackers is a health hazard since
it is responsible for both air pollution and noise pollution.
The use of Fireworks has led to air pollution in the form
of noise and smoke. Their excessive use has started to be
a public hazard and violation of their fundamental rights
as enshrined in the Constitution of India.”

9. However, while the court laid down the law for restricted
use of fireworks to avoid noise pollution, there was no total
ban as the lis at that point of time concerned only noise
pollution. Now with countless news reports, an unenviable
first position in Global rankings of most polluted cities in
the world by the World Health Organization and alarming

 7

pollution levels released by the Central Pollution Control
Board, the time has come to completely ban the use of
firecrackers for Diwali due to the irreparable and needless
damage it will cause to an already damaged ecology.
SUPPORTING MATERIAL
Research Studies
10. There are a plethora of reports on ambient air and noise
quality in India during Diwali, a select few of which are
below:
• “The ambient air and noise quality in India during
Diwali

festival:

A

review”

Recent

Research

in

Science and Technology, 2014, 6(1): 203-210. A true
copy of this report is annexed herewith and marked
as AnnexureP-1 (pp.__-__).
• A Study “Potential impact of fireworks on respiratory
health” by Gouder C, Montefort S, noted authors of
Mater Dei Hospital, Malta published inLung India
2014;31:375-9. A true copy of this report is annexed
herewith and marked as AnnexureP-2 (pp.__-__).
• A recent paper entitled “Assessment of the Impact of
Fireworks

on

Ambient

Air

Quality”by

Sapan

Bhatnagar and Shubham Dadhich published in the
International Journal for research in Applied Science
& Engineering Technology (IJRASET), Volume 3,
Issue IV, April 2015. A true copy of this report is
annexed herewith and marked as AnnexureP-3
(pp.__-__).

 8

All the above reports detail the harmful impact on air
quality due to Suspended Particulate Matter of different
sizes. They state that Fireworks cause dispersion of such
Particulate Matter (PM) into the environment, which
consist of metals, organic chemicals, soil dust and other
minute materials which cause harmful effects to ecology
and human life.
11. Particulate matter such asPM2.5 or PM1 is the most
harmful and it can penetrate deep into the lungs and blood
stream, thus, affecting vital organs and the respiratory
system.PM2.5 and PM1 aerosols can penetrate into the
alveolar region of the lungs. PM of size 2.5-10 micrometres
is less harmful since it stays in the nose or mouth, but it is
still important to measure PM10 levels because it causes
asthma attacks.The National Ambient Air Quality Standards
(NAAQS) by the Central Pollution Control Board (CPCC)
puts the maximum permissible level of PM10 at 100μg/m3
and PM2.5 at 60μg/m3.
12. The

study

in

AnnexureP-3is

a

detailed

experiment

conducted in Dhanbad, Jharkhand in 2014 where the levels
of PM in air were observed a day before and after Diwali
day to track changes in PM levels. The sampling method is
explained in detail on page 3 of the research study. The
results that were recorded were shocking and alarming and
point to a clear causation between Diwali day firecrackers
and increased air pollutants. The level of PM10 was at
>220

μg/m3,

an

increase

of

more

than

twice

the

permissible amount of 100μg/m3. The Level of PM2.5 had

 9

increased

to

>86

μg/m3

compared

to

the

National

permissible limit of 60μg/m3. Hence levels of PM10 and
PM2.5 increase significantly during Diwali and are a
leading cause of respiratory diseases in people.
13. Fireworks consist of Carbon and Sulphur for combustion
but harmful materials like arsenic, manganese, sodium
oxalate,

aluminium,

iron

dust

powder,

potassium

perchlorate, strontium nitrate and barium nitrate are used
in

their

manufacturing

for

stabilizing,

colouring

and

oxidizing, as stated in AnnexureP-2.
14. The following are a non-exhaustive list of most common
diseases and health disorders caused by PM and other
toxins released in the air due to burning of fire crackers
(AnnexureP-1):a. Increased respiratory symptoms such as difficulty in
breathing, coughing and irritation etc.
b. Decreased lung capacity
c. Chronic Bronchitis
d. Asthma
e. Irregular Heartbeat
f. Heart attacks
g. Premature Death
h. Phlegm
i. Chronic obstructive pulmonary disease
j. Allergic rhinitis
k. Lung cancer
l. Lower respiratory tract infections

 10

15. The various types of air pollutants that are released by
combustion of firecrackers (AnnexureP-2): Sulphur dioxide (SO2)
 Carbon dioxide (CO2)
 Carbon Monoxide (CO)
 Nitrogen dioxide (NO2)
 Nitric Oxide
 Particulate Matter (PM) found in elevated levels:o Aluminium
o Barium
o Strontium
o Antimony
o Lead
o Magnesium
o Potassium
o PM10
 Total suspended particulate matter
o PM1, PM2, PM 2.5
o Benzene
o Toluene
o Ethylbenzene
o Xylene-volatile aromatic compounds (BTEX)
o Percolate
o Chloride
 Metal salts likeAluminium, manganese and cadmium
16.

The research studies also list the National Ambient

air quality standards of some of the common pollutants
released in burning firecrackers. The research has found
that the air quality drops significantly during Diwali and
exposes humans to a greater risk of pollution related
diseases.
17.

The studiesalso confirm that the effects of fireworks activity in
degrading the air quality continue to linger for several days

 11

after Diwali day. Even rural areas like Rajim near Raipur,
Chhattisgarh, which should ideally have a clean environment
with fewer pollutants compared to a crowded metropolitan like
Delhi had very unhealthy levels of PM in its air after Diwali in
high concentrations.
18.

Higher values of all the above mentioned pollutants were seen
on Diwali day. In the study conducted in AnnexureP-1,a
comparison

chart

depicts

the

Respiratory

Suspended

Particulate Matter (RSPM) and the concentration of PM10 in
Delhi was the highest amongst the Tier-A cities while RSPM
concentrations

in

cities

like

Kolkata

and

Mumbai

were

comparatively much lower.
19.

Table 6 in AnnexureP-1illustrates various toxic effects of the
toxic elements that are released due to burning of firecrackers.
The table contents are reproduced below for reference:

Toxin

Usage

in Toxic Effect

Fireworks

Aluminium

Brilliant Whites

1)Contact
Dermatitis

Arsenic Sulfide

Colorant

2)Bioaccumulation
Toxic ash can cause
Lung

Antimony Sulfide

Glitter effect

cancer

skin

irritation and warts
1)Toxic
smoke
2)possible

Barium Nitrate

Glittering greens

carcinogen
Poisonous,
Fumes can irritate
respiratory

tract,

Possible radioactive
Copper
compounds

Blue colour

fallout
Bioaccumulation
and cancer risk

 12

Hexachlorobenzen

Banned

e(HCB)

substance still in Mutagen

Lead

Carcinogen,
and

use

Reproductive

Oxidizer

Hazard
Bioaccumulation

Dioxide/Nitrate/Ch

Hampers

child

loride

development
Danger for unborn
babies
May

remain

airborne for days
Poisonous to plants
Lithium
compounds
Mercury

Red colour

and animals
Toxic and irritating

Chlorine donor

fumes when burned
Toxic heavy metal
that

bio

accumulate
some Toxic when inhaled

Nitric Oxide

Used

Nitrogen dioxide

fireworks
Used in

Free radical
some Highly toxic when

Ozone

fireworks
Used in

inhaled
some Greenhouse

gas

fireworks

that

and

Ammonium

in

may

and Propellant/oxidiz

Potassium

er

Perchlorate

attacks

irritates lungs
Can
contaminate
ground and surface
waters

and

cause

thyroid problems in

Potassium Nitrate
Strontium

humans

and

Black Powder

animals
Toxic

dusts,

Red colour

Carcinogenic
Can replace calcium

Compounds
Sulphur Dioxide

in

the

body

and

Gaseous

slightly toxic
by Acid
rain

from

product

of sulphuric

acid

Sulphur

affects

combustion

sources, vegetation

water

and causes property

 13

damage
20. The study also states that due to wide spread awareness
campaigns and enforcement mechanisms, the city of
Bangalore showed a sharp 32% decrease in pollution levels
in 2013 compared to 2012. The same can be done in Delhi
if this Hon’ble Court intervenes and puts a stop on usage of
these harmful fireworks.
21. In the research study conducted in AnnexureP-2, it was
found that in India, a 30-40% increase occurs in cases of
wheezing, respiratory diseases, exacerbation of bronchial
asthma, and bronchitis in patients of all ages and both
genders during Diwali. Many epidemiological studies that
the article itself cites directly linked exposure to a variety
of air particles to exacerbate symptoms of the above
mentioned respiratory disorders. Dominici et al reported
almost a doubling of hospital admissions for every 10μg

3

of

increase in PM2.5.
22. A research paper published on the U.S. National Institutes
of Health's National Library of Medicine website entitled
“The effects of air pollution on the health of children” cited
as Paediatr Child Health, 2006 Oct; 11(8): 513–516
discusses the adverse impact of ambient air quality on
children's health. The article highlights the mortality,
pregnancy outcomes, vitamin D deficiencies and alteration
of the immune system of children. The committee on
Environmental Health of American Academy of Pediatrics
issued a policy statement in 2004 on the link between
ambient air pollution and children's health. Children are

 14

more vulnerable to the adverse health effects of air
pollution

due

to

longer

exposure

outdoors,

rigorous

physical activity requiring more intake of oxygen from air,
higher minute ventilation, undeveloped immune system and
lung development during childhood.
a. A large number of epidemiological studies have
shown a link between exposure to ambient air
pollutants and morbidity and mortality in children.
There are 6 pollutants that this study is based on
that cause adverse health effects- Ozone, PM,
Nitrogen dioxide, Sulphur dioxide, Carbon monoxide
and lead. The work refers to various studies that
show

the

above

mentioned

pollutants

cause

increased child and adult mortality in Canada and
other developed countries.
b. It

was

observed

that

there

is

a

significant

relationship between PM and respiratory related
mortality and also sudden infant death syndrome.
c. The ambient air pollutants also cause adverse
pregnancy outcomes like premature birth, low birth
weight,

growth

abnormalities.One
investigated

and

retardation
study
found

by
a

and
Ritz

physical

et

relationship

al

has

between

exposure to ambient air and birth defects.
d. Carbon monoxide has been found to cause cardiac
ventricular septal defects and Ozone exposure is
associated with risk of arterial, pulmonary and valve
defects.Ambient

air pollution

causes

acute

and

 15

chronic respiratory defects in both asthmatic and
non-asthmatic children with increased asthmatic
symptoms and incidence of attacks.
e. Other studies have also shown a link between lung
function and air pollution whereby there is a deficit
in lung development. A natural consequence of being
ill due to air pollution is school absenteeism.
f. Vitamin D deficiency causes rickets in children and
in tropical regions with higher levels of ambient air
pollution there is an increased risk of developing
rickets. The amount of sunlight needed for a healthy
dose of vitamin D is inversely related to the level of
ambient air pollution or haze.
The research study also discusses effects of improved air
quality on children's health. A decline in ambient SO2 and
PM levels in the former East Germany after reunification
saw

improvements

in

lung

function,

reduction

in

respiratory diseases such as bronchitis and sinusitis. In US,
children who relocated to areas with lower ambient air PM
experienced

increased

growth

in

lung

function

and

conversely, those who moved from lower ambient air PM
States to higher, experienced a decreased growth in lung
function. During the 1996 Olympics in Atlanta, Georgia,
USA,

there

concentration

was

a

levels

steep
and

27.9%

decline

consequently,

a

in

Ozone

significant

reduction in childhood asthma events. A true copy of this
report is annexed herewith and marked as AnnexureP-4
(pp.__-__).

 16

23.

As per a report published by the World Health

Organization (WHO) in 2005 on the ill effects caused by air
pollution in children:
“Various

periods

children.

The

of

vulnerability

intrauterine,

perinatal

characterize
and

early

childhood periods, during which the lungs are
developing and maturing, are very vulnerable times.
These are periods when the lungs are susceptible to
injury by air pollutants. Exposure during these
periods reduces the maximal functional capacity
achieved in adult life and can lead to enhanced
susceptibility during adulthood to infection and to
the effects of such pollutants as tobacco smoke and
those present in occupational exposures. Children
with underlying chronic lung diseases, particularly
asthma and cystic fibrosis, are especially vulnerable.
These children are at greater risk of adverse effects
from pollution than are healthy children. Also,
children subject to higher exposures indoors – for
example, from tobacco smoke or smoke from poorly
maintained heating or cooking appliances – are at
greater risk of being affected by outdoor pollutants.”
24. The report also states that there is a causal relationship
between air pollution and health effects in children.
Aggravation of Asthma, coughing, bronchitis, retarded
nervous system development and cognitive impairment are
some of the effects for which evidence exists that they are
caused by air pollution.
“The evidence also shows a relationship between
exposure to ambient air pollutants and adverse effects
on the development of lung function. Reversible lung
function deficits, chronically reduced lung growth
rates and lower lung function levels are associated
with exposure to air pollution. Moreover, the evidence

 17

shows clearer relationships for particulate matter and
traffic-related air pollution (indicated by nitrogen
dioxide) than for other pollutants. Based on current
knowledge, air pollutants seem to interact with other
environmental factors, such as allergens, viruses and
diet that influence the overall impact of air pollutants
on children’s health.”
25.

The report also states that there is suggestive

evidence of there being a causal link between air pollution
and low birth weight, premature births and intrauterine
growth retardation. There is also considerable evidence of
a causal link between ambient air pollutants and childhood
morbidity and mortality. A true copy of this report is
annexed herewith and marked as AnnexureP-5 (pp.__-__).
26.

A Research Gate study entitled “Air Pollution and its

Impact on

Lung Function

of Children in

Delhi” by

S.Siddique, et al., cited as Environ We Int. J. Sci. Tech. 5
(2010) 163-175 corroborates the WHO study findings that
air pollution has a causal relationship with asthma. The
study found that annual average levels of PM10 in Delhi
were more than twice as much as that of rural areas of
Uttaranchal and West Bengal. The incidence of Asthma,
both current (wheezing anytime within 12 months) and
physician-diagnosed was also almost twice as much in Delhi
compared to the rural control areas. It was also found that
the prevalence of asthma was found more in Boys than girls
in the age group of up to 14 years. The prevalence of
asthma in children above 14 years of age was less, hence
showing that occurrence of asthma is substantially high in

 18

childhood. A true copy of this report is annexed herewith
and marked as AnnexureP-6 (pp.__-__).
News Reports
27. Several news reports have carefully catalogued the
dangerous levels of particulate matter and how the
environment is getting irreversibly polluted in Delhi,
particularly with reference to the ill effects on children.
a. The Hindustan Times, in a report dated 22 nd April,
2015 entitled Beijing Better Than Delhi found that
between the 2 capitals notorious for dirty air, Delhi
had healthy air for just 7 days out of 730 while
Beijing had managed that for as many as 58 days.
This is because Beijing had introduced stringent air
pollution measures as against India which failed with
both Central and Delhi Governments taking no
serious steps. A true copy of this report is annexed
herewith and marked as AnnexureP-7 (pp.__-__).
b. The Daily Mail online newspaper, on 5 th May 2015,
reported that as per a study conducted by the HEAL
foundation and Breathe Blue, it was found that 4 in
10

children

in

Delhi

suffer

from

severe

lung

problems. The study by Breathe Blue found that 35%
of school children across the country fared badly in
the Lung Health Screening Test (LHST) which
determines how much air lungs can hold and
transmit from the body. In Delhi, 21% of the children
surveyed were categorized as ‘poor’ and another
19% ‘bad’. Children are exposed to Delhi’s toxic air

 19

while playing outdoors, travelling to and from school,
and even in ventilated school corridors. Bangalore
was a close second with 36% children faring either
‘poor’ or ‘bad’. Kolkata children were marginally less
at 35% and Mumbai children were comparatively
safer at only 27% securing ‘poor’ or ‘bad’ in the lung
test. The study found that the people neither held
themselves accountable for the quality of air, nor
believed themselves to be capable of effectuating
change in air quality. Thus, only rapid sensitization
and education about pollution and its effect is
needed to curb the growing threat. A true copy of
this report is annexed herewith and marked as
AnnexureP-8 (pp.__-__).
c. In a news report by Hindustan Times on 4th June
2015 that followed the unfortunate story of a 12 year
old boy in Delhi who has contracted asthma which
had been aggravated due to Delhi’s bad air quality,
Dr.

Randeep

Department

Guleria,
of

Professor

Pulmonary

and

Medicine

Head
and

of

Sleep

Disorders, AIIMS said that with the advent of
monsoons, one would expect cooler weather to bring
in fresher air, but because of heavy cloud cover and
overcast, the toxins in the air hang low and this
aggravates asthmatic patients, in children even more
so. A true copy of this is annexed herewith and
marked as AnnexureP-9 (pp.__-__).

 20

d. The Times of India on June 27 th2015 reported that
apart from the already dangerous PM10 and PM2.5
that are floating in Delhi above the permissible levels
decided by the Central Pollution Control Board, a
government agency has found the most dangerous
class of particulate pollutant, which is ultrafine PM
or PM1. The level at which there is suspended PM1
is alarmingly high even in cleaner and greener areas
such as Lodhi Road area of Delhi.PM1 is so
dangerous that no safe standard has been prescribed
yet

by

the

government,

but

according

to

the

monitoring agency SAFAR, its level peaked 70
micrograms/cubic metre which is even higher than
the permissible level of PM2.5. A study in China’s
Fudan University found that PM2.5 and below can
enter the blood stream and affect the inner walls of
arteries and cause cardiovascular problems. The
news report also claims it is linked to strokes since it
travels in the blood stream.A true copy of this is
annexed herewith and marked as AnnexureP-10
(pp.__-__).
e. In a report in India Today on June 29, 2015, it was
stated that over the past 7 years from 2006-07 to
2014-15, over Rs.385Crore has been collected via
environment cess of .25paise, yet only around 13% of
it, i.e. Rs. 49.57Crore has been utilized, ironically to
reimburse

concession

on

purchase

of

battery

operated vehicles. Successive Delhi Governments

 21

have not utilized these funds in curbing the air
pollution that is choking Delhi today.The article also
reports that these funds remain unutilized even
though the levels of PM are up to 5 times more than
permissible levels of 60 microgram/cubic meter.In
the wake of rise in number of vehicles, construction
projects, industries around the National Capital
region, there seems to be no clear direction or
strategy that the governments will use to curb air
pollution,

even

with

all

the

requisite

funds

available.The article also included a comment from
the

present

Delhi

government

that

they

have

engaged IIT-Kharagpur to charter out a plan to
reduce air pollution in Delhi. As such vague promises
are the hallmark of all governments, hence this court
is requested to protect the residents of Delhi who are
left helpless at the hands of successive governments
doing nothing about the state of its air quality.A true
copy of this is annexed herewith and marked as
AnnexureP-11 (pp.__-__).
f. A news report on 23rd July 2015 on the NDTV
website stated that the Union Environment Minister,
in his written reply to the Rajya Sabha stated that an
alarming 80 people die on average everyday due to
Air pollution in Delhi, according to two studies
commissioned by the centre, the ‘Epidemiological
study on effects of air pollution on human health in
Delhi’ done between 2002-2005 and ‘Study on

 22

Ambient Air Quality, Respiratory symptoms and Lung
Function of Children in Delhi’ done between 20032005.The ministry also admitted that severe health
hazards including pulmonary and DNA damage is
associated with high level of PM pollution. A true
copy of this is annexed herewith and marked as
AnnexureP-12 (pp.__-__).
g. On August 25, 2015, the Central Government, after
several

media

reports

and

the

World

Health

Organization’s 2014 ambient air quality by city
report which ranked Delhi to have the worst quality
air in the world, finally admitted that Delhi was
facing a pollution crisis. According to an Economic
Times report, the Environment minister, Mr. Prakash
Javadekar spoke of the National Air Quality Index
that was launched by the government and said that
the government is working on preparing an indoor
air quality protocol as well. The minister called for a
collective effort at creating awareness and reducing
pollution, but the news report said little about antipollution laws that the government should put in
place. The news item shows little in terms of actual
effective measures being taken in the short run to
control air pollution. This news report is another
example of why the intervention of this Hon’ble
Court is most urgently required to curb this nationwide threat of needless pollution caused by burning

 23

firecrackers.A true copy of this is annexed herewith
and marked as AnnexureP-13 (pp.__-__).
h. A Times of India report on August 28, 2015 from
Washington, USA states that new research by the
University of Texas, El Paso shows that children’s
grades are affected by high levels of toxic air
pollutants especially from vehicular emissions. The
researchers have two theories to explain a decline in
grades and causal relationship with air pollution. The
first is absenteeism due to respiratory illnesses,
hence consequently missing school and performing
poorly. The second is that air pollutants can severely
affect children’s neurological and brain development.
The study was also published in the Population and
Environment Journal of the University. A true copy of
this report is annexed herewith and marked as
AnnexureP-14 (pp.__-__).
i. In an article published on the Economic Times
website on 7th of June, 2015, personal accounts of
facing Delhi’s toxic air was discussed with the
growing trend amongst expatriates to move back to
their respective home countries. It features the
following:
i. Jack Leenars, a former journalist from Holland
who has a successful business in Delhi, but
after spending three years in Delhi, has now
decided to move out in view of the toxicity
present in Delhi’s air.

 24

ii. Philly Malicka, a British writer and publishing
consultant, who moved to India for a 5 year
stint, but has decided to move back to London
mainly due to the congestion and pollution in
Delhi which she believes are harming her
health.
iii. Alex Le Beuan, a French travel agent who has
lived in Delhi for the past 10 years, and has
now decided to move to Bali. Le Beuan regrets
that he has to depart a city that he considers
his second home, but says the pollution and
traffic has changed for the worse since he
moved to Delhi. When his daughter was born,
he and his wife took the decision to leave Delhi.
iv. Rod Oliver, a British MNC professional who has
had a short stint of less than a year in Delhi,
but is concerned about his family’s health
especially

after

the

scientific

evidence

on

pollution in Delhi has been found to be a major
cause for concern. Rod and his wife are already
considering moving out for the sake of their
children’s health.
While expatriates may have the luxury of moving cities
and countries when faced with such dire health concerns,
the same is not available to Indian citizens who live and
work in Delhi. Those who have lived for many years in the
city are unaware of how clean air feels and are unable to
tell the difference, with toxicity having become second

 25

nature. A true copy of this report is annexed herewith and
marked as AnnexureP-15 (pp.__-__).
28. The present Writ Petition is being filed on the following
grounds and without prejudice to one another:
GROUNDS
A.

THAT the Hon’ble Court has always acted as parens
patriae

of

the

citizens

of

the

country,

more

particularly of its disadvantaged and vulnerable
sections. It is in the interests of the children who are
claiming their fundamental right under Article 21 for
a clean and healthy environment that the present
petition is filed. The right to breathe clean air is
essential for a conducive environment for their
growth and development.
B.

THAT as several studies referred to above have
shown,

Indian

cities

and

particularly

Delhi

is

suffering from grave pollution issues which affect the
right to health of its citizens. Children are more
gravely affected because of their less developed
immune systems, and so are at greater risks than
adults. It is imperative that immediate steps are
taken to ensure that crop burning in the surrounding
areas of the Delhi/NCR are immediately stopped as
they unleash several million tonnes of fumes and
dangerous suspended particles into the air which are
transported over Delhi by the seasonal winds.
C.

That it is necessary that the Central Government and
State Governments take immediate steps to bring the

 26

Bharat Stage Emission standards in line with the
highest

international

norms

so

that

Euro-VI

equivalent fuel, which is presently exported will now
be used domestically and uniformly across the
country. It is necessary that at the very least BharatV fuel be implemented with immediate effect and
that rigorous penalties imposed and implemented on
erring parties.
D.

THAT the use ofFirecrackers are a needless and
harmful vice that is caused by innocent citizens in
the

spirit

of

celebrations

not

knowing

or

understanding the deep implications of burning these
firecrackers

which

have

grave

and

poisonous

consequences.
E.

THAT there are already several pollutants choking
the

air

we

intervention

breathe
through

which
policy

need
and

government

norms

namely

construction induced dust, vehicular emissions and
industrial pollutants, many of which are wholly
ignored by the Government and no serious steps are
taken to engage with them.
F.

THAT there is nothing in the religious texts of any
major religion practiced in India that advocates or
calls for the use of firecrackers in celebrating
festivals and the same cannot be claimed to be a
right under Article 25 of the Constitution.

G.

THAT the custom of celebrating Diwali and other
Indian festivals which have been using fireworks in

 27

recent years have to be viewed historically in the
nature of the festival’s pith, substance and entirety.
Merely because the late 20th century practice of
celebrating national festivals has up till now involved
the use of firecrackers does not by itself make them a
custom or ritual.
H.

THAT the reasoning that firecrackers are burnt on
only special occasions cannot detract from the longterm costs and injury to life and property involved.
Apart from pollution, several injuries, fires and
deaths will be avoided on an annual basis.

I.

THAT this Hon’ble Court, as decided in M.C. Mehta v.
Kamal Nath has expounded the roman doctrine of
public trust, whereby the Government holds the
environment-

air,

sea-shores,

rivers,

forests

in

trusteeship for the free and unimpeded use by the
general public. Hence, the Government’s omission in
not protecting this public trust may then be imposed
by this Hon’ble Court.
J.

THAT

the

fireworks

industry

is

res

extra

commercium, and with the evils of child labour,
danger

to

humans

and

property

while

both

manufacturing and using, and the harm to the
environment, there can probably be no contesting
right which can preclude a ban on fireworks.
K.

THAT as this Hon’ble Court has been constantly
monitoring the air pollution issues of Delhi, this is
the only forum that the Petitioners can approach and

 28

crave interference in the interest of protecting
guaranteed fundamental rights to live a healthy,
fruitful life.
PRAYER
It is most respectfully prayed that this Hon’ble Court be
pleased to:
(a)

Pass a Writ of Mandamus or any other appropriate
writ, order or direction to banthe use in any form, of
firecrackers, sparklers and minor explosives in any
form, for use during festivals or otherwise;

(b)

Pass a Writ of Mandamus or any other appropriate
writ, order or direction directing the Respondents to
ensure that seasonal crop burning is halted in
favour of less harmful alternatives;

(c)

Pass a Writ of Mandamus or any other appropriate
writ, order or direction directing the Respondents to
take stringent action against those who dump dust,
malba and other pollutants without following due
regulations and permissions, the failure of which
will entail severe penalties;

(d)

Pass a Writ of Mandamus or any other appropriate
writ, order or direction directing the Respondents to
immediately bring Bharat-V or better emission
norms into operation uniformly across the country;

(e)

Pass a Writ of Mandamus or any other appropriate
writ, order or direction to the Respondents to
constitute anindependent permanent body tasked

 29

with spreading awareness and maintain compliance
of this Hon’ble Court’s orders;
(f)

Pass a Writ of Mandamus or any other appropriate
writ, order or direction Respondents to widely
publicize the steps being actively taken, if any, in
reducing pollution in Delhi, especially pollution
caused by Particulate Matter of different sizes;

(g)

Appoint an expert committee consisting of key
stakeholders from the legal ecosystem (comprising
members of Academia, the Bench and the Bar) to
review the working of the state’s efforts at curbing
environmental degradation caused specifically by
ambient air pollution and suggest institutional
reforms with a view to making our environment
more robust and healthy for not just our sake but for
future generations as well; and

(h)

Pass such other and further orders as are deemed fit
and appropriate in the interest of justice.

FILED BY
DRAWN BY:
Zeeshan Dhawan,
Advocate, Supreme Court of India
DHAR

POOJA

ADVOCATE FOR PETITIONERS
Drawn On : __.09.2015
Filed On : __.09.2015

 30

IN THE SUPREME COURT OF INDIA
CIVIL ORIGINAL JURISDICTION
WRIT PETITION (CIVIL) NO.________ OF 2015
IN THE MATTER OF:
ARJUN GOPAL &Ors.,

…Petitioners

VERSUS
UNION OF INDIA &Ors.,

…Respondents
AFFIDAVIT

I, Gopal Sankaranarayanan, aged about 38 years, residing
at

B-1/1148,

VasantKunj,

New

Delhi-110070,

do

hereby

solemnly affirm and state as under:
1. That I am the father of the minor Petitioner No.1 in the
abovementioned matter, and as his next friend and legal
guardian, am conversant with facts and circumstances of
the case and as such competent to swear the present
affidavit. I have also been authorized by the next friends/
legal guardians of the other Petitioners to swear to this
affidavit on their behalf as well.
2. That the contents of the Synopsis and List of Dates from
pages B to __ and those of Paragraphs 1 to ___ of the Writ
Petition from Page Nos.1 to ___ are facts true to my
knowledge and belief, while Paragraphs __ to __ are the
prayers made to this Hon’ble Court.
3. That the Annexures filed along with the Writ Petition are
the true copies of their respective originals.
DEPONENT
VERIFICATION
I, the above named Deponent, do hereby solemnly affirm
and verify that the contents of this affidavit are true to best of
my knowledge and belief and nothing material has been
concealed therefrom.
DEPONENT