stay

BEFORE THE HON’BLE HIGH COURT OF JUDICATURE AT CHENNAI
(Special Original Jurisdiction)
(Under Art226 of Indian Constitutional Law)
M.P.No:1/15
In
W.P.No: /15
1) P.Chandira,M.E.,(M.B.A)(B.G.L),
Wife and Power of Attorney to R.Thangavel,2nd Petitioner,
E-77, Anna Road,
Block-27, Neyveli-3,Cuddalore District.
2) R.Thangavel,M.E.,M.I.E.,
The Chief Manager, CPFNo:27329,
First Thermal Power Station,
Neyveli Lignite Corporation,
Neyveli-607803,Cuddalore Dt. -------------Petitioner/Petitioner
Verses
1) The Chairman cum Managing Director,NLC,Neyveli.
2) The Chief Vigilance officer,NLC,Neyveli.
3) The Director (Personnel Redesignated as HR),NLC,Neyveli.
4) The Chief General Manager (P&A Redesignated as HR),NLC,Neyveli.
5) The Deputy General Manager (P&A Redesignated as HR)
NLC,Neyveli. ----------Respondents/Respondents.
AFFIDAVIT FILED BY THE PETITIONER.
1. I, the 1st petitioner Mrs.P.Chandira W/o R.Thangavel aged about 47
years is working as an Assistant Engineer(H)Nabard and Rural Roads,Panruti and
the 2nd petitioner is Er.R.Thangavel,is aged about 56 years, the Chief Manager

Neyveli Lignite Corporation, First Thermal Power Station, Neyveli residing at E-
77,Anna Road,Block-27,Neyvei-3 is sincerely and solemnly state as follows:
2. The 2nd petitioner humbly pray that this Hon’ble High Court may
please to permit the first petitioner his power of Attorney and his wife
Mrs.P.Chandira to represent this case on behalf of the 2nd petitioner as she knows
the facts and circumstances of the case very well and humbly submits the copy of
power of Attorney before this Hon’ble High Court and the petitioner has already
appeared before this Hon’ble High Court against the NLC not to transfer the 2nd
petitioner from Tamilnadu to Rajasthan Barshingsar Project. Even though the 2nd
petitioner challenged the cases with malafide and in individual capacity,this
Hon’ble High Court has not permitted reasonable opportunity in accordance with
law. The Hon’ble High Court decided the case based upon the report of the 5th
respondent without calling for the records from NLC.On the contrary the fifth
respondent
3. The 2nd petitioner studied Bachelor of Engineering Degree in
Mechanical in Coimbatore Institute of Technology, Coimbatore in the year of 1981
and Master of Engineering, Design in Government College of Technology,
Coimbatore in the year of 1983. The 2nd Petitioner worked as Lecturer in
Coimbatore Institute of Technolgy,Coimbatore. The 2nd petitioner joined his duty
as Graduate Engineer Trainees on 15/11/1983 in esteemed Neyveli Lignite
Corporation. The 2nd petitioner was promoted as Assistant Executive Engineer on
01.06.1985, Executive Engineer on 01.09.1989 and Deputy Superintendent (Scale),
Senior Executive Engineer on 01.09.1993. The 2nd petitioner availed Lien Service,
Foreign Service (Lien) in abroad in the period of 19.09.2001 to 30.10.2003 after
relieving from the Neyveli Lignite Corporation on 18.09.2001. The 2nd petitioner
rejoined his duty back to Neyveli Lignite Corporation on 31.10.2003.

4. The 2nd petitioner was promoted as Deputy Chief Engineer E5 with
effect from 01.09.1997 by paper movement before the Departmental Promotion
Committee for his four years of his service completion as Senior Executive
Engineer, the Deputy Superintendent (Scale) 01.09.1993 to 30.08.1996. The 2nd
petitioner was promoted as Additional Chief Manager Scale E6 on 01.07.2005 and
subsequently on Additional Chief Manager, M-1 Grade/E6 on 01.07.2006.
5. In the mean time the petitioners purchased a land to construct an
apartment under PPA rules and regulation in the year of 2008 jointly with some
other Neyveli Lignite Corporation employees on 13.03.08 through
Thiru.Natarajan, the Chief Technician, Neyveli Lignite Corporation, Neyveli.
Thiru.Ananthakrishnan is also the one of the purchaser in Pondy. Thiru.Natarajan,
the Chief Technician and Thiru.Ananthakrishnan is doing real estate business from
2008 . In the mean the 1st petitioner was posted to Rajasthan Barshingsar Project
on 02.04.08 by Neyveli Lignite Corporation Proceeding. The petitioners submitted
several representations to the Neyveli Lignite Corporation Chairman-Cum-
Managing Director of Neyveli Lignite Corporation and all the Directors of Neyveli
Lignite Corporation to permit to continue the 2nd petitioner to do his duty at
Tamilnadu until FIRNo: 10/03 filed by the Vigilance Anti-Corruption Department
is pending as the 1st petitioner is witness to Tamilnadu State Vigilance Department
subsequent orders in W.P.No:26463/01 Dated: 04.03.02, 14.03.02, 23.04.03 and
24.06.03.
6. When the 2nd petitioner were went to his native for her mother’s death
six month ceremonial function at his native he was deemed to be relieved on
14.04.08 without serving the Transfer order. The 2nd petitioner submitted a
representation on 18.04.08 to the Director (Power) and the Chairman-Cum-
Managing Director of Neyveli Lignite Corporation to permit to continue his duty at
Neyveli. Further the petitioners planned to purchase an apartment at Chennai
Valasarawakkam on 14.05.08 through Thiru.Natarajan. The Director (Power)

permitted the 1st petitioner to continue the duty up to 14.07.08 in his proceeding on
22.05.08.
7. The 1st petitioner filed a defamation case in C.C.No:314/02 on
08.10.02 before the Judicial Magistrate Court-II, Chidambaram against a)
Thiru.Tamilselvan, the former Divisional Engineer (H) (Regular) Cuddalore b)
Thiru.Ponnselvan, the former Assistant Divisional Engineer (H) (Regular)
Chidambaram c) Thiru.Haribabu, the former Junior Engineer (H), Nabard and
Rural Roads, KattumannarKovil. Subsequently the first petitioner filed 91CRPC
before the Judicial Magistrate Court-II, Chidambaram on 29.01.2003 and is still
pending and hence the transfer OP No: 4787/14 is filed before the Judicial
Magistrate Court-II, Chidambaram to the District Munisiff Cum Judicial
Magistrate Court, Neyveli. The 1st petitioner is the complainant in
W.P.No:39160/04 to regularise the period. When the 1st petitioner was in a position
to attend the Hon’ble High Court as party-in-person after getting vakalat from
Thiru.Nithiandam,the Advocate for NLC in the year of 2008,the 1st petitioner
authorised the 2nd petitioner to represent the case C.C.No:314/02 in the month of
March2008 and he is also one of the witness in the case.
8. The 2nd petitioner filed a W.P.No:17124/08 before this Hon’ble
High Court on 14.07.08 with M.P.No:1/08 to dispense the transfer order and to
stay the transfer order in M.P.No:2/08 against a) The Director (Power) NLC,
Neyveli b) The DGM (P&A) NLC, Neyveli c) The General Manager, Thermal
Power Station-I, Neyveli d) The DGM (P&A) Welfare, NLC, Neyveli e) The Chief
Manager (P&A) Neyveli. The Hon’ble High Court granted an interim stay in
M.P.No:2/08 in W.P.No:17124/08 on 05.08.08. Subsequently the 1st petitioner was
permitted to continue duty at First Thermal Power Station, Neyveli on 08.08.08. In
order to prove the malafide act of respondents in M.P.No:2/08 in
W.P.No:17124/08 ,the 2nd petitioner filed M.P.No:4/08 in individual capacity and
to extend the stay in M.P.No:5/08 before the Hon’ble High Court on 13.08.08.
During the hearing on 18.08.08 the Hon’ble High Court permitted the implead

petition in M.P.No:4/08 and added the six to tenth respondents in individual
capacity and extended the stay petition in M.P.No:5/08 until further orders.
9. The 2nd respondent DGM (P&A) filed counter in M.P.No:3/08 on
behalf of the one to five respondents in official capacities in W.P.No:17124/08.
The respondents in individual capacity has not filed counter in W.P.No:17124/08.
During the hearing on 01.09.08 the Hon’ble High Court dismissed the
W.P.No:17124/08 with the direction to the second respondent DGM (P&A) to
consider the grievances in accordance with law. The 2nd petitioner was forcefully
relieved on 05.09.2008 by the Neyveli Lignite Corporation. The 2nd petitioner filed
Writ Review No: 103/08 with M.P.No:1/08 on 06.09.08. The Hon’ble High Court
issued notice to the ten respondents to file counter in M.P.No:1/08. The proof of
the Private notice also filed before the Hon’ble High Court High Court. During the
hearing on 18.09.08 the case is argued without counter by the one to ten
respondents and the case is adjourned for judgements. The Hon’ble Court passed
an order in Writ Review No: 103/08 without any order in M.P.No:1/08 without the
knowledge of the petitioners on 24.09.08. In the mean time the petitioners arranged
for an advocate N.R.R.Natarajan from Mrs.Nalini Chidambaram madam office.
The advocate issued contempt notice to the NLC management Chairman-Cum-
Managing Director of Neyveli Lignite Corporation, to the Directors and DGM,
(P&A) of Neyveli Lignite Corporation. Further the 1st petitioner filed a Writ
Petition against the 1st respondent herein the Chairman-Cum-Managing Director of
Neyveli on 14.05.2009 and the 2nd petitioner filed contempt petition which is
numbered as Cont.Pet.No:483/09 on 01.06.09. Even though the 1st petitioner filed
Writ Petition on 14.05.09 and 2b petition on 27.05.09 to add the 2nd petitioner in
the single writ petition, the Writ Petition was numbered in the second petitioner
only in W.P.No:11001/09 to call for the records on the file of
CORP/P&A/EE/0502/2008 Dated: 15.09.08 on the file of CGM (P&A) and all
further proceedings initiated by the Neyveli Lignite Corporation.

10. In the mean time the 1st respondent has not conducted DPC in the
year of 2009. In the mean time the Project head, Rajasthan has issued a illegal
charge memo to the 2nd petitioner. Even though the 1st respondent permitted the
second petitioner to attend DPC in the year 2010, because of the illegal charge
memo created by the Project head the 2nd petitioner was not promoted as Chief
Manager. Even though the 1st respondent permitted the 2nd petitioner to attend DPC
in the year 2011, because of the illegal charge memo created by the Project head
the 2nd petitioner was not promoted as Chief Manager. The 1st petitioner submitted
complaints on 27.05.2012 to the 2nd respondent herein against
Thiru.Ananthakrishnan and Thiru.Natarajan .The 2nd respondent directed the Chief
Manager Thiru.Sivashanmugham to conduct the preliminary enquiry on
14.05.2012 .The 1st petitioner submitted seventeen pages of documents along with
three pages of written statement. The petitioner was promoted as Chief Manager
Scale E6A on 01.07.2012 and subsequently on Chief Manager, M-2 Grade/E6A on
01.07.2013.
11. The 1st petitioner filed a Writ Petition before this Hon’ble High
Court on 07.10.2012 with twelve orders 1)FI.R.No:10/03 filed by the Vigilance
and Anti-Corruption Department, Cuddalore 2) The order of the Hon’ble High
Court in W.P.No:17124/08 Dated: 01.09.08 3) The order of the Hon’ble High
Court in Writ.Review.No:103/08 Dated: 24.09.08 4) The Secretary,Highways and
Minor Ports Department Lr Dated:13.10.08 5) The order of the Hon’ble High
Court in W.A.No:282/09 Dated: 18.03.09 6) The order of the Hon’ble High Court
in Writ Appeal Review.No:37/09 Dated: 30.04.09 7) The 2b Petition in
SRNo:41218 Dated:27.05.09 8)The substituted order of the Hon’ble High Court in
W.P.No:17124/08 Dated: 02.07.09 9) The substituted order of the Hon’ble High
Court in W.P.No:17124/08 Dated: 07.08.09 10) To set aside the order of the third
respondent dated:01.12.09 11) The order of the Hon’ble High Court in
W.P.No:11001/09 Dated: 13.02.09 12) The order of the Hon’ble High Court in
Crl.O.P.No:22241/11 Dated: 11.11.11.The first petitioner filed a Writ Petition in
W.P.No:11001/09 against the CMD,NLC,Neyveli which is numbered in the second

petitioner by the Registrar(Judicial) with the influence of the Principle
Secretary,Highways and Minor Ports Department,Secretariat,Chennai-9, the Chief
Judicial Magistrate Court,Cuddalore and the Inspector of Police,V&AC,Cuddalore
and caused undue harassment to the petitioners. Hence the petitioners filed this
Writ Petition on 07.10.2012 to regularise the period of the petitioner and her
husband with damaged remedy and relief and thus render justice.
12. In the reasons stated the 1st petitioner humbly prayed on 07.10.2012
that this Hon’ble High Court may please to direct the CMD,NLC,Neyveli which is
numbered in the 2nd petitioner by the Registrar(Judicial) with the influence of the
Principle Secretary,Highways and Minor Ports Department,Secretariat,Chennai-9,
the Chief Judicial Magistrate Court,Cuddalore and the Inspector of
Police,V&AC,Cuddalore to file their report before this Hon’ble High Court based
upon the above case bundles and the representations submitted to them within the
stipulated period of time until disposal of the writ petition on 07.10.12 and thus
render justice.
13. In the reasons stated the 1st petitioner humbly prayed on 07.10.2012
that this Hon’ble High Court may please to issue the Writ of Certiorari or any other
Writ calling for the records on the file of respondents in 1)FI.R.No:10/03 filed by
the Vigilance and Anti-Corruption Department, Cuddalore 2) The order of the
Hon’ble High Court in W.P.No:17124/08 Dated: 01.09.08 3) The order of the
Hon’ble High Court in Writ.Review.No:103/08 Dated: 24.09.08 4) The
Secretary,Highways and Minor Ports Department Lr Dated:13.10.08 5) The order
of the Hon’ble High Court in W.A.No:282/09 Dated: 18.03.09 6) The order of the
Hon’ble High Court in Writ Appeal Review.No:37/09 Dated: 30.04.09 7) The 2b
Petition in SRNo:41218 Dated:27.05.09 8)The substituted order of the Hon’ble
High Court in W.P.No:17124/08 Dated: 02.07.09 9) The substituted order of the
Hon’ble High Court in W.P.No:17124/08 Dated: 07.08.09 10) To set aside the
order of the third respondent dated:01.12.09 11) The order of the Hon’ble High
Court in W.P.No:11001/09 Dated: 13.02.09 12) The order of the Hon’ble High

Court in Crl.O.P.No:22241/11 Dated: 11.11.11 and consequently quash the illegal
proceedings of respondents on public interest to prevent the misuse of Government
funds and to regulate the period from the date of transfer order issued to the 2nd
petitioner to the date of his joining duty as duty period and promote him as Deputy
General Manager and regularization of Period 08.06.09 to 25.10.09 as duty to the
1st petitioner and promote the petitioner as Assistant Divisional Engineer and the
compensation to the petitioners as this Hon’ble High Court may deem fit and
proper in the circumstances of the case and thus render justice.
14. The 1st respondent arranged for the departmental enquiry against
Thiru.Ananthakrishnan and Thiru.Natarajan in the month of January- 2014. When
the 1st petitioner had a plan to attend enquiry against Thiru.Ananthakrishnan at
Rajasthan Barshingsar Project with the 2nd petitioner,an accident happened at First
Thermal Power station on 20.05.2014 which is registered as FIRNo:59/14 by the
Inspector of Police,Thermal Power Station,Neyveli on the file of District Munisiff
Cum Judicial Magistrate Court,Neyveli and subsequently the 1st petitioner was
threatened on 24.05.2014 and falsely implicated in C.C.No:41/14 before the
Judicial Magistrate Court-II,Panruti which was transferred to the District Munisiff
Cum Judicial Magistrate Court,Neyveli. The 2nd petitioner submitted twenty three
pages of documents by fax to the departmental internal enquiry officer,Rajasthan
Barshingsar Project against Thiru.Ananthakrishnan. The 2nd petitioner submitted
nineteen documents to the departmental external enquiry
officer,A.R.Ramachandran against Thiru.Natarajan which is conducted in
Tamilnadu.
GROUNDS.
15) The 1st petitioner submitted complaints dated: 27.05.2012 to the 2nd
respondents to take necessary action against Thiru.Ananthakrishnan and
Thiru.Natarajan. The 2nd respondent had taken necessary steps to conduct an
enquiry through the 1st respondent department against Thiru.Ananthakrishnan
through departmental internal enquiry officer and an enquiry against
Thiru.Natarajan against through external enquiry officer Thiru.A.R.Ramachandran.

The respondents failed to serve the details of the action taken by them based upon
the complaints submitted by the petitioner to them is in violation of Principles of
Natural Justice and against law. Even though the petitioner requested the details
the presenting officer advised to get the details under Right to Information
Act2005. The first petitioner submitted an application under Right to Information
Act 2005 to the Central Public Information officer, Neyveli Lignite Corporation.
As the Central Public Information has not provided the details an appeal has been
submitted to the Appellate Authority, Right to Information Act2005.As the
Appellate authority also has not submitted the details the Second Appeal submitted
before the Central Information Commissioner to get the details and the respondents
are causing undue harassment to the petitioners in different ways.
16) The Hon’ble High Court passed an order in W.P.No:17124/08 on
01.09.08 and substituted on 02.07.09 and 07.08.09. The period between 01.09.08
to 07.08.09 is stay exist period.
17) The petitioner filed M.P.No:1/08 in Writ Review No:103/08 on
06.09.08.The Hon’ble High Court issued notice to the respondents in M.P.No:1/08
on 10.09.08. The proof also filed before the Hon’ble High Court. The respondents
in Writ Review not filed counter in the official capacity. In individual capacity not
filed counter and not appeared either in person or through advocate. The Hon’ble
High Court has not passed any orders in M.P.No:1/08 in Writ Review No:103/08.
In the mean time the fourth respondents passed impugned proceedings on
15.09.08.
18) The 1st petitioner humbly submits that the Postal department receipt
despatched from NLC management on 12.03.09 through the post office in vide
serial No:A687 to the 2nd petitioner, in vide serial No:688,to the District
Collector,Cuddalore and in vide serial No:689,to the Secretary, Highways/Govt of
Tamilnadu Highways Department,Secretariat,Chennai-9.

19) The 1st petitioner humbly submits that the Central Public Information
officer Letter No: PRD/CPIO/0062/2008-6 Dated: 08.07.2008. As per the terms
and conditions of appointment and promotion orders of the employees, they are
liable to be transferred to any branch/Department/subsidiaries/undertaking of the
Corporation situated anywhere in India. There is a need of experienced and
dedicated executives at the Project site for coordinating and executing various
activities for smooth implementation of the Project. Barshingsar Project at
Rajasthan is an upcoming and Prestigious, Mining-Cum-Power Project of NLC and
several senior and experienced executives have been transferred so as to
commence the project of NLC and several senior and experienced executives have
been transferred so as to commence this project as envisaged as per schedule.
Transfer is administrative decision and Prerogative of the Management and
transfer orders are issued deployment of employees who well experienced and
trained, so as to get best results for the Organisation. The 2nd petitioner as per the
direction of the Hon’ble High Court joined his duty on 19.08.09 and submitted a
representation to the 1st respondent to regularise the litigation period as duty and
promote the 2nd petitioner as Deputy General Manager and performed his duty for
the period of two years at Rajasthan Barshingsar Project.
20) The 1st petitioner humbly prayed on 07.10.2012 that this Hon’ble
High Court may please to direct the CMD,NLC,Neyveli which is numbered in the
second petitioner by the Registrar(Judicial) with the influence of the Principle
Secretary,Highways and Minor Ports Department,Secretariat,Chennai-9, the Chief
Judicial Magistrate Court,Cuddalore and the Inspector of Police,V&AC,Cuddalore
to file their report before this Hon’ble High Court based upon the above case
bundles and the representations submitted to them within the stipulated period of
time until disposal of the writ petition on 07.10.12 and thus render justice.
21) The 1st petitioner humbly prayed on 07.10.2012 that this Hon’ble
High Court may please to issue the Writ of Certiorari or any other Writ calling for
the records on the file of respondents in 1)FI.R.No:10/03 filed by the Vigilance and

Anti-Corruption Department, Cuddalore 2) The order of the Hon’ble High Court in
Writ.Review.No:103/08 Dated: 24.09.08 4) The Secretary,Highways and Minor
Ports Department Lr Dated:13.10.08 5) The order of the Hon’ble High Court in
W.A.No:282/09 Dated: 18.03.09 6) The order of the Hon’ble High Court in Writ
Appeal Review.No:37/09 Dated: 30.04.09 7) The 2b Petition in SRNo:41218
Dated:27.05.09 8)The substituted order of the Hon’ble High Court in
W.P.No:17124/08 Dated: 02.07.09 9) The substituted order of the Hon’ble High
Court in W.P.No:17124/08 Dated: 07.08.09 10) To set aside the order of the third
respondent dated:01.12.09 11) The order of the Hon’ble High Court in
Crl.O.P.No:22241/11 Dated: 11.11.11 and consequently quash the illegal
proceedings of respondents on public interest to prevent the misuse of Government
funds and to regulate the period from the date of transfer order issued to the 2nd
petitioner to the date of his joining duty as duty period and promote him as Deputy
General Manager and regularization of Period 08.06.09 to 25.10.09 as duty to the
1st petitioner and promote the petitioner as Assistant Divisional Engineer and the
compensation to the petitioners as this Hon’ble High Court may deem fit and
proper in the circumstances of the case and thus render justice. The petitioner also
filed another Writ Petition to regularise the period and Rating of the Petitioner as
“Out Standing”.
22) The petitioner humbly submitted a representation Dated: 11.02.15
to the second respondent to fix the seniority of Engineers based upon their date of
joining at Rajasthan .The second respondent transferred the representation to the
third respondent. The third respondent failed to fix the seniority of the Engineers as
per the date of Joining at Rajasthan.
23) The Petitioner humbly prayed that this Hon’ble Court may please to
direct the respondents to fix the seniority of the Engineers based upon their date of

Joining at Rajasthan Barshingsar Project, to permit the second petitioner to attend
DPC 2015 for the post of Deputy General Manager.
24) In the above circumstances the first petitioner humbly prayed that
this Hon’ble Court may please to direct the respondents to stay the further
proceedings in Lr.No: CORP/ HR/EB (Exe)/517/CM/ 2014-1 Date: 12.04.2015 in
Departmental Promotion committee to fix the seniority of the Engineers based
upon their date of joining at Rajasthan Barshingsar Project, the 2nd petitioner to
attend DPC 2015 until disposal of this Writ Petition and thus render Justice.
25) In the above circumstances the petitioners humbly prayed that this
Hon’ble Court may please to issue a writ of certiorarified mandamus calling for the
records on the file of the fifth respondent in his Lr.No:CORP/
HR/EB(Exe)/517/CM/ 2014-1 Date:12.04.2015 ,the Chief Manager and other
Engineers list in the Neyveli Lignite Corporation, the details of employees joined
in Rajasthan Barshingsar Project to quash the same and consequently direct the
respondents to fix the seniority of the Chief Manager based upon their date of
joining at Barshingsar Project as directed by the second respondent office
Lr.No:VIG/NLC/CTS/AA/0025/2015 Dated:03.03.15 based upon the
representation of the 1st petitioner dated:11.02.15 and thus render Justice
Sincerely and solemnly as sworn
On 20.04.15 at Chennai Signature of the Petitioners-in-Person/
Power of Attorney and his wife.

BEFORE THE HON’BLE HIGH COURT
OF JUDICATURE AT CHENNAI
IN
W.P.No: /15
1) P.Chandira,W/o R.Thangavel,
E-77, Anna Road,
Block-27, Neyveli-3
2) R.Thangavel,
The CM, TPS-I,NLC,
Neyveli-607803 ---Petitioner/Petitioner
Verses
1) The Chairman cum Managing Director,
NLC,Neyveli.
2) The Chief Vigilance officer,
NLC,Neyveli.
3) The Director (Personnel
Redesiginated as HR),
NLC,Neyveli.
4) The CGM(P&A Redesignated as HR)
NLC,Neyveli.
5) The DGM (P&A Redesignated as HR)
NLC,Neyveli---Respon/Respondents
.
P.CHANDIRA
PARTY-IN-PERSON

MEMORANDUM OF WRIT MISCELLANEOUS PETITION
M.P.No:1/15
In
W.P.No: /15
E-77, Anna Road,
TPS-I,NLC,Neyveli-607803,Cuddalore Dt. -------------Petitioner/Petitioner
Verses
4) The Chief General Manager(P&A Redesignated as HR),LC,Neyveli.
5) The Deputy General Manager(P&A Redesignated as HR)
DIRECTION PETITION
In the reasons stated in the accompanying affidavit the 2nd Petitioner
humbly prayed that this Hon’ble Court may please to direct the respondents to fix
the seniority of the Engineers based upon their date of Joining at Rajasthan
Barshingsar Project, to permit the 2nd petitioner to attend DPC 2015 for the post of
Deputy General Manager and thus render Justice.
Dated at Chennai on 22.02.15 Petitioners-Party-in-Person

IN
W.P.No: /15
E-77, Anna Road,
Block-27, Neyveli-3
2) R.Thangavel,
The CM, TPS-I,NLC,
Verses
NLC,Neyveli.
NLC,Neyveli.
Redesignated as HR),
NLC,Neyveli.
NLC,Neyveli.
NLC,Neyveli---Respon/Respondents
.
P.CHANDIRA
PARTY-IN-PERSON

MEMORANDUM OF WRIT MISCELLANEOUS PETITION
M.P.No:1/15
In
W.P.No: /15
E-77, Anna Road,Block-27, Neyveli-3,Cuddalore District.
TPS-I,Neyveli Lignite Corporation,
Neyveli-607803,Cuddalore District. -------------Petitioner/Petitioner
Verses
4) The Chief General Manager (P&A Redesignated as HR),LC,Neyveli.
5) The Deputy General Manager (P&A Redeginated as HR)
NLC,Neyveli. ----------Respondents/Respondents
STAY PETITION
In the reasons stated in the accompanying affidavit the 2nd Petitioner
humbly prayed that this Hon’ble Court may please to direct the respondents to stay
5th respondent Lr.No:CORP/ HR/EB(Exe)/517/CM/ 2014-1 Date:12.04.2015 the
Departmental Promotion committee to fix the seniority of the Engineers based
upon their date of joining at Rajasthan Barshingsar Project until disposal of this
Writ Petition and thus render Justice.

MEMORANDUM OF WRIT PETITION
In
W.P.No: /15
E-77, Anna Road,Block-27, Neyveli-3,Cuddalore Dt.
TPS-I,Neyveli Lignite Corporation,
Neyveli-607803,Cuddalore District -------------Petitioner/Petitioner
Verses
3) The Director (Personnel Redeginated as HR),NLC,Neyveli.
WRIT PETITION
The First Petitioner:
The first petitioner is Mrs.P.Chandira, W/o R.Thangavel, E-77, Anna
Road,Block-27, Neyveli-3 and the address for service of all the notices are as
stated above and appearing as Party-in-Person.
The Second Petitioner:
The second petitioner is R.Thangavel,the Chief Manager,First Thermal
Power Station,Neyveli Lignite Corporation,Neyveli-607803 and the address for

service of all the notices are as stated above and appointed his wife,the first
petitioner as power agent.
The First Respondent:
The First Respondent is the Chairman cum Managing Director, Neyveli
Lignite Corporation,Neyveli and the address for service of all the notices are the
Chief Law officer,NLC,Neyveli.
The Second Respondent:
The second Respondent is the Chief Vigilance officer,Neyveli Lignite
Corporation,Neyveli and the address for service of all the notices are the Chief
Law officer,NLC,Neyveli.
The third Respondent:
The third respondent is the Director (Personnel Redeginated as HR),
NLC, Neyveli and the address for service of all the notices are the Chief Law
officer,NLC,Neyveli.
The fourth Respondent:
The fourth respondent is the The CGM(P&A Redeginated as HR)
NLC, Neyveli and the address for service of all the notices are the Chief Law
officer,NLC,Neyveli.
The fifth Respondent:
The DGM (P&A Redeginated as HR)NLC, Neyveli and the address for
service of all the notices are the Chief Law officer,NLC,Neyveli.

In the reasons stated in the accompanying affidavit the petitioners humbly
prayed that this Hon’ble Court may please to issue a writ of certiorarified
mandamus calling for the records on the file of the fifth respondent in his
Lr.No:CORP/ HR/EB(Exe)/517/CM/ 2014-1 Date:12.04.2015 ,the Chief Manager
list in the Neyveli Lignite Corporation, the details of employees joined in
Rajasthan Barshingsar Project to quash the same and consequently direct the
respondents to fix the seniority of the Chief Manager based upon their date of
joining at Barshingsar Project as directed by the second respondent office
representation of the 1st petitioner dated:11.02.15 and thus render Justice.

IN
W.P.No: /15
E-77, Anna Road,
Block-27, Neyveli-3
2) R.Thangavel,
The CM, TPS-I,NLC,
Verses
NLC,Neyveli.
NLC,Neyveli.
Redesiginated as HR),
NLC,Neyveli.
NLC,Neyveli.
NLC,Neyveli---Respondents/Respondents
.
P.CHANDIRA
PARTY-IN-PERSON

M.P.No:1/15
In
W.P.No: /15
1) P.Chandira,M.E(M.B.A)(B.G.L)
E-77, Anna Road,Block-27, Neyveli-3,Cuddalore District.
2) R.Thangavel,M.E.,
The Chief Manager,TPS-I,
NLC,Neyveli- 3,Cuddalore District -------------Petitioner/Petitioner
Verses
3) The Director (Personnel Redeginated as HR),NLC,Neyveli.
2b Petition filed by the Petitioner.
In the reasons stated in the accompanying affidavit the
petitioner humbly prayed that this Hon’ble High Court may please to permit the
Petitioners to join together and file a single Writ Petition and thus render justice.
Dated at Chennai on 20.04.2015 Petitioner-in-Person

BEFORE THE HON’BLE HIGH COURT OF JUDICATURE AT
CHENNAI
M.P.No:1/15
In
W.P.No: /15
1) P.Chandira,M.E(M.B.A)(B.G.L)
E-77, Anna Road,Block-27, Neyveli-3,Cuddalore District
2) R.Thangavel,M.E.,
The Chief Manager,TPS-I,
NLC,Neyveli- 3,Cuddalore District. -------------Petitioner/Petitioner
Verses
AFFIDAVIT FILED BYTHE 1st
PETITIONERS ON HER BEHALF AND ON BEHALF
OF THE 2ND
PETITIONER.
1. I, P. Chandira, wife of R. Thangavel, Hindu, aged 47 years, residing at E-
77, Anna Road, Block – 27, Neyveli, now temporarily come down to Chennai, do
hereby solemnly affirm and sincerely state as follows.

2. I am the 1st Petitioner herein and I am well acquainted with the facts of this
case. I am filing this affidavit on my behalf and on behalf of the 2nd Petitioner, who
is my husband. I am authorised by the 2nd petitioner to file this affidavit on his
behalf. The Petitioners submit that the above Writ Petition is being filed In the
reasons stated in the accompanying affidavit the petitioners humbly prayed that
this Hon’ble Court may please to issue a writ of certiorarified mandamus calling
for the records on the file of the fifth respondent in his Lr.No:CORP/
HR/EB(Exe)/517/CM/ 2014-1 Date:12.04.2015 ,the Chief Manager list in the
Neyveli Lignite Corporation, the details of employees joined in Rajasthan
Barshingsar Project to quash the same and consequently direct the respondents to
fix the seniority of the Chief Manager based upon their date of joining at
Barshingsar Project as directed by the second respondent office
representation of the 1st petitioner dated:11.02.15 and thus render Justice. The 1st
Petitioner is witness to Tamilnadu State Vigilance in FIRNo:10/03 filed by the
Inspector of Police,V&AC,Cuddalore and Neyveli Lignite Corporation Vigilance
Department against Thiru.Ananthakrishnan and Thiru.Natarajan and the cases are
proved.The 2nd petitioner is victimised due to the accused in the both the cases.The
Petitioners crave leave of this Hon’ble Court to read the affidavit filed in support
of the above writ petition as part and parcel of this affidavit.
3. The Petitioners submit that the grievances of the Petitioners are common and
the compensation for the both the petitioners. Hence, the Petitioners pray that they
may be permitted to join together and file a single Writ Petition.
4. In these circumstances, the Petitioners pray that this Hon’ble Court may be
pleased to permit the Petitioners to join together and file a single Writ Petition and
thus render justice.
Sincerely and solemnly sworn The 1st Petitioner-in-Person
At Chennai on 20th day of April-15 2nd Petitioner through his wife, 1st petitioner.

In
W.P.No: /15
W/o R.Thangavel, E-77, Anna Road,
The Chief Manager,CPFNo:27329,
First Thermal Power Station,
Neyveli Lignite Corporation,
Neyveli-607803,Cuddalore District. -------------Petitioner/Petitioner
Verses
NLC,Neyveli. &Four others -------Respondents/Respondents.
TYPED SET
S.No Date Description of documents P.No
1 08.07.08 NLC CPIO Lr No: PRD/CPIO/0062/2008-6 1
2 12.03.09 The postaldepartment communication 2
3 27.05.09 2b petitioner filed by the first petitioner 3
4 01.11.11 The Power of Attorney. 4
5 11.02.15 The representation submitted to the first
respondent to fix the seniority by speed post.
5
6 03.03.15 Lr.No:VIG/NLC/CTS/AA/0025/2015
Dated:03.03.15
6=7
7 15.04.15 The fifth respondent in his Lr.No:CORP/
HR/EB(Exe)/517/CM/ 2014-1 Date:12.04.2015
8-15
Dated at Chennai on 20th April 2015 Petitioner-in-Person

REGISTERED POST WITH ACK DUE
NEYVELILIGNITE CORPORATION LIMITED
(‘Mini Ratna’-A Govt of India Enterprise)
P.O.NEYVELI-607801, CUDDALORE DISTRICT, TAMILNADU
CENTRAL PUBLIC INFORMATION OFFICE: P.R.DEPARTMENT
LetterNo.PRD/CPIO/0062/2008-6 Dated:08.07.2008
To
Smt.P.Chandira,201,Jawaharlal NehruStreet,Vridhachaam,CuddaloreDistrict.
Madam,
Sub:Informationon EmployeesPosted/JoinedandProcedure forSelectionof employeesfor
BarshingsarProjectunderthe Rightto InformationAct,2005-Reg.
Ref:1.Applicationdated:12.06.2008 receivedon16.06.2008 from Smt.P.Chandira,201,Jawaharlal
NehruStreet,Vridhachalam,Cuddalore District.
2. This office LetterNo.PRD/CPIO/0062/2008-1 dated:13.06.2008.
3. Paymentof ApplicationfeeforRs.10/bybanker’scheque receivedon21.06.08.
4. This office LetterNo.PRD/CPIO/0062/2008-4 dated:04.07.2008
5. Your letterdated:07.07.2008 alongwitha DD for Rs 14/-
-----------------------
Withreference toyourapplicationcitedabove andsubsequentpaymentof fee, the information
on employeesposted/joined and procedure for Selection of employees for Barshingsar Project under
the Right to Information Act, 2005.
Q.1&2.The name and details of the employees posted to Barshingsar Project in NLC furnished in
Annexure-A.
Q.3 .As per the terms and conditions of appointment and promotion orders of Employees, they are
liable to be transferred to any Branch/Department/Subsidiaries/Undertaking of the Corporation
anywhere in India. There is a need of experienced and dedicated executives at the Project site for
coordinating and executing various activities for smooth implementation of the project, Barshingsar
Project at Rajasthan is an upcoming and Prestigious, Mining-Cum-Power Project of NLC and several
seniorandexperiencedexecutiveshave beentransferred is administrative decision and prerogative of
the managementandtransferordersare issuedfordeploymentof employeeswhoare well experienced
and trainedso as to get best results for the Organisation. If you are aggrieved against the above reply,
you may prefer an appeal within 30 days of receipt of the same, to the Appellate Authority whose
address is given below:
The Chief General Manager/TA, Appellate officer under RTI Act,
Township Administrative office,NLC Limited,Neyveli-607801.
CENTRAL PUBLIC INFORMATION OFFICER.
Enclosure:As above(7 Pages)

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