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Human rights violation

(Querist) 24 November 2014 This query is : Resolved 
KINDLY ARRANGE IT LEGALLY
BEFORE THE HONRABLE CHAIRMEN / SECRETARY STATE HUMAN RIGHTS COMMISSION JAMMU & KASHMIR OLD ASSEMBLY COMPLEX –OLD SECRETRIAT AT SRINAGAR

In the matter of:-
Shahnawaz Akhtar
S/o: Khurshid Ahmad
R/o: Chanapora …...…….…………… (Applicant)

VERUS

FAROOQ AHMAD TEELI
(EXECUTIVE ENGINEER)
ELECTRIC DIVISION BUDGAM …………………. (Non-applicant)

May it please your honor:-
The applicant most respectfully states as under,
1. That the applicant (herein also called Servant ) is presently working as (Executive) in Electric Division Budgam , underneath hierarchy of the Non- applicant ( herein also called Master)
2. That the applicant on 19-11-2014 has approached the non-applicant for medical leave for 30 days from 20-11-2014 onwards; with plea that the applicant is suffering badly from back ache.
3. That the non-applicant refused the applicant without any justified reasoning, in-spite of that the applicant requested non-applicant to the extent, begs before his master for his leave on medical grounds for medical consultation, as non-applicant then and now is suffering with pain in his back.
4. That the applicant was previously working in the field and is now working on assigned job of clerk by the Non-applicant , the applicant functus officio performed his legitimate duties towards his Master , and from the date of his appointment in the department has never availed medical leave till date.
5. That upon repeated request of the applicant for medical leave , the Non- applicant has threatened applicant ( herein also called Servant) to the extent, that non-applicant will kill applicant and his family.
6. That the applicant went to the concerned Police Station Budgam with application and reported the threat by his Master (Non-applicant ) and requested concerned police officer for cognizance , and has also approached the Dy. Commissioner Budgam , whereupon the applicant has given receipt vide No: 4301 dated : 19-11-2014 but no action in this regard has been initiated against the Non- applicant.
7. That the applicant has come to know from the respectable and reliable sources that the Non-applicant is native of some Minster of the State having close aquitance with him, which may the cause of delay by the authorities to initiating any action under rules against the Non-applicant.
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8. That the applicant has every right to enjoy his life and his property constitutionally, and is also guaranteed by the constitution for his safe guard and protection.
9. That if in case of any untoward with applicant happens hereafter, or in case of event of any hurt to the applicant’s life and property happens in future, it may be believed that the Non- applicant having strong men-s-rea to be held is responsible for same.
10. That the applicant most humbly invoking territorial jurisdiction of your Lordship for his safe guard and protection of life and property , therefore praying for interim orders for human rights violation by the Non-applicant , and also kindly direct the Police Station Budgam concerned for the cognizance.

Yours faithfully

ShahNawaz Akhtar
S/o: Khurshid Ahmad
R/o: Chanapora Srinagar


Sudhir Kumar, Advocate (Expert) 25 November 2014
refer

http://www.lawyersclubindia.com/experts/Fir-509046.asp
Sudhir Kumar, Advocate (Expert) 25 November 2014
also refer

http://www.lawyersclubindia.com/experts/LEAVE-RULES--509366.asp#.VHPZlWeO5G1
Shailesh Kr. Shah (Expert) 25 November 2014
repeated query:-
http://www.lawyersclubindia.com/experts/Fir-509046.asp
Shailesh Kr. Shah (Expert) 25 November 2014
Also repeated:-

http://www.lawyersclubindia.com/experts/LEAVE-RULES--509366.asp#.VHPZlWeO5G1
T. Kalaiselvan, Advocate (Expert) 27 November 2014
If repeated, then no reply to the query.


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