BEFORE THE HONBLE THE CHIEF COMMISSIONER FOR PERSONS WITH

DISABILITIES, MINISTRY OF SOCIAL JUSTICE OF EMPOWERMENT

CONTEMPT PETITION NO. ______/2015

IN
CASE NO.

.. Complainant/Petitioner
Versus
(1)

North Western Railway, H.Q. Office, Near Jawahar Circle, Jaipur through- the
General Manager (Personnel).

(2)

West Central Railway, Indira Market, Jabalpur, Through General Manager.

.. Contemnors/Respondents
CONTEMPT PETITION U/S 12 OF CONTEMPT OF COURT ACT.

MAY IT PLEASE YOUR HONOUR

Humble Applicant/Petitioner, above named, most respectfully beg to submit

contempt Petition before this Honble Court as under:1.

That the Complaint filed on through Letter before Honble Court.

2.

That the notices given to the opposite parties on 05.03.2015 and subsequent on
09.06.2015, then matter taken on 10.07.2015 when Respondents not filed any
Reply.

3.

That Respondent orally submitted on 10.07.2015 that North Western Railway is

4.

ready to create an alternative post for Petitioner in Kota. Respondents represented

has repatriate Petitioner to Jaipur division to his present division because his lien
is in North Western Railway.

5.

That West Central Railway has disobeyed the Honble Courts Order and passed
such Order and relieved the Petitioner it is Contempt of Court by not following the
Orders of Honble Court.

6.

That Respondent without taken permission of the Honble Court or request for
amending the order that the directions to be given to the North Western Railway.

7.

That it was already clearly discussed in the order that West Central Railway is
ready to create an alternative post in the same pay scale for Petitioner/Complainant
because Petitioner is wheel chair person and completely dependent on his family
members for day to day chores, so it is not possible him to live alone in Jaipur
where he never worked even for a day.

8.

That the Petitioner has no alternative remedy to invoke for his redressal West
Central Railway vide it is order dated 01.10.2015 relieve the Petitioner to join at

9.

Jaipur in North Western Railway.

and requested to same post and position as mention in the Order of the
Commission at Kota. Petitioners letter for perusal of Commission is Annexure-3.

10.

That the humble Petitioner crave leave of this Honble Commission to urge the
additional grounds at the time of hearing of the present contempt Petition.
It is, therefore, most humbly prayed that your Lordship be pleased to accept/allow
this Contempt and further be pleased to punish Contemnor/Respondents for their
intentional and willful disobedience in complying with order/direction of this
Honble Courts dated 20.07.2015.
Further this Honble Court be pleased to direct Contemner/Respondents to
forthwith comply with order dated 20.07.2015, allow Petitioner work at place of
his previously respective post on the same terms and conditions existed on the date
of accident of Petitioner.
Further the Contemner be directed to forthwith recall/cancel the order dated
01.10.2015 passed in utter disregard to the order of Honble Court dated
20.07.2015 and further, to forthwith restore the position of the post as was existing
at the date of accident.