Soe » BEFORE THE CENTRAL ADMINISTRATIVE TRIBUNAL, PRINCIPAL BENCH, NEW DELHI 0.A. No.1641 of 2014 In the Matter‘of;, Dr. Sudhir Kumar Gupta Applicant ‘ ' Versus AIIMS & Ors 4 ’ Respondents DOH: 01.07.2014 INDEX SI.No. PARTICULARS PAGES fe Rejoinder on behalf of Applicant to the | 4 BY Counter Reply on behalf of AlIMS dated 26.01 40Mof Shri Shashi Tharoor H/O late Sunanda Pushkar admitting influencing Director, AIIMS for a_ tailor | made autopsy report. a Annexure RA/1: sZrue copy of email] 23-24 Annexure RAIZ True copy of AIMS) 35 Notice dated 02.06.14 for meeting on| ») Sunanda Pushkar autopsy matter. | Annexure RA/3: True copy of AIMS) aé Memorandum dated 14.06.14 to Applicant. | Annexure RAJ4: True copy of Applicants a far reply dated 17.06.14 to AIIMS Memorandum datéd 14.06.14. ‘ Annexure RAIS: True copy of MCI notice fF dated 06.08.14 to the Applicant 7. | Annexure RA/6: True copy of is Applicant : Reply 12.06.14 to MCI notice Sched of 4-34 06.06.14, sel Rf[Annexure RA. True copy of Applicant's letter dated 04.04,04 to MCI. 32 Annexure RA/8: True copy of Dr. Yash Nigam's judgment by Hon'ble Delhi High Court 33-36 Annexure RA/ 9: True copy of minutes of 127” GB meeting dated 12.10.04 of MCI. FF -34 Annexure _RA/10: True copy of Applicant's written statement dated ‘46.05.05 to DMC. Yo < 12. Annexure RA/ 11: True copy of DMC letter to Applicant along with closure report. . Y1-49 ‘Annexure RAI 12; Tite copy of MGI letter dated 08.08.09 to AlIMS uy Annexure RA/13 True Copy of Applicant's Tepresentation dated 06.05.14 to President, AlIMS. usu a Annexure _RA/14- True copy of Applicant's representation dated 27.05.14 to CVC/CVO, AIIMS 4\@-U4 Annexure RA/ 15: True copy of Applicant's representation dated 06.06.14 to the Director AIIMS S0 Annexure RAI 16 True copy of provisional Promotion Order dated 07.06.14 of the Respondent No.3. SA - G2 Annexure RA / 17: True copy of the AIIMS Warning Memo dated 25.10.13 to the Respondent No.3. SS Annexure RA /48: True copy of AIIMS | notice dated 03.02.14 to Respondent No.3 se 20, 21, | Annexure RA/ 19° True copy of SSC report sheet dated 26.02.14 for reporting | on assessment of Respondent No.3 under | APS. | Annexure RA/ 20: True copy of the Govt. of India Guidelines/OM dated 22.12.59. ss Sé- 64|: 22 Annexure RA / 21: True copy of the 6a- bb DoPT Guidelines/OM dated 14.09.92. 23. Annexure RA 122° True copy of the be DoPT Guidelines/OM dated 03.11.95 24, Annexure RA/23: True copies ‘of = ‘Applicant's Resume, and Awards ete. 6% hoy (R.R.Kumal & Amrendra Kumar) Advocates for Applicant | nig, evel foale nos Dated: 26.06.2014 i | ‘aes pee ella - Woe32- Mobi geo 2Ib2 SL Aang STF 49999 OS A HF Eynalt sad mocnct enmoneee9 fs Ew.Xi. iy That the admitted contents of Para No. X of Counter Reply needs no rejoinder except the fact that when their was no reply of reference dated 25.10.12 by AIIMS to Respondent No.2 what was the great hurry that urgent agenda was suddenly prepared to illegally promote the Respondent No.3 by purging the seniority of Applicant herein. It is submitted that the real issue was to influence the autopsy matter of late Sunanda Pushkar by removing the Applicant from the post of HoD on 12.05.2014 because the than vested interests had sensed the loss power after 2014 general elections. Unfortunately, their loyalist is still carrying the vendetta and his agenda to influence the said autopsy report by pressurizing the Applicant. The Applicant is ready and willing to file his professional report prepared in the said autopsy in sealed cover before this Hon'ble Tribunal which would clearly show that why the impugned agenda has been hurriedly prepared and pushed by the Respondent No.1 & 2 That the contents of Para No, XI of Counter Reply are denied as alleged. AlIMS has one again twisted the admitted facts for the benefit of Respondent No.3. There is no word as to why second Censure be not considered while considering the promotion of Respondent No.3 in 20414, and how can he become eligible for retrospective promotion in teeth of settled law and DoPT guidelines to consider promotion of a candidate folRyo ‘Shashi Taroor Mal Ret chines anor sah Re: Important 3 she sag: Shashl Tharoor-<———____|_"_ > “To: Or Rajiv Bhasin ——$—$—————>, Anil Chatta < Co: Abhinav Kumar ———=p> wrote: | > Hi Shashi, a3 \ \> | > Ive been reading the newspaper reports saying that Sunands had been drinking only coconut water for3 | days before her demise. , > | feoollect thet | had seen and examined her on 4/12/13 when you had called me in a panic because she had { high fever and was finding It very difficult to breath, At that point, her 8.P. was around 90/60 and she had | Improved when we gave her electral and nimbupani > If she had no food over 3 days and had only coconut water which has a very high content of potassium, this could have eleveted her serum potassium levels and possibly slowed her heatt rate. > In addtion, if she took alprax, It could have contributed to the slowing down of her heart rate and made it possibly difficult for'her to call for help. > My healt condolence Shashi. | shall always cherish her memories, a > May God give Shiv and you the strength to bear the loss. > Rajeev . > Dr Rajeev Bhasin —— > Sent fom my iPad Abhinav Kumar ==>, ‘26 January 2014 21:49 ‘To: Shashi Tharoar <= Got it Sir. Abhinav Kumar IPS PS to Dr Shashi Tharoor Minister of State, Ministry of HRD Room no 115 C, Shastri Bhawan Dr Rajendra Prasad Road New Delhi 110001 Tel: 28384073/23381567/23986163 psa g09|acemalsO/Ai= i= se 8bonnpdqaDraOBhaslnsaseryekseorcquaryh= HSclSAtcSeT, ¥son 10s HOST rawno, 125087771 zr Feb, zone 18:47? 3 an rea BER secnaees ; COOPER | Esa a (ALT . pgoxes? et Toonami may encom \ peor 10" 2014 | se» Soanda Push Tarot | i sama nal fil uate or nf, paneain uc anaave bee rng : i 1ercenelng heen : | sSunenda Pushiker was a close family trend for tne iaat 8 years sta exe -vory saddened by hor waie death and aven mote cereesed about he ee Yeas vor about Ye cause of her death. Wist | de not lain to know #2 os surrounding speculation abou Me fiend who happeried tobe a docot | was py 19 some medio! Sos ror death. Beng acumen hese a8 ti Information might help determing cavse of Mey death, 4) She told me she had Lupus and was consuting @ LUPUS exper. 22m cadet months there were several auch eplsodes of punting Wood pressure in 1 eee rg hor share, wich led Or Tharoor (cling ftom ine) ot nar een 6 Dubel dung nat aden, | was concemed tat laeing equ episodes of iow blood (pe owe untreated could lad to serous consequences, and | urged rte seek ine Etention of a specialist, which | understand she never di. 4)’ She vsedtobruiga waaly ana we have discussed ile several imes in pansing A re yeah or blood test or bumping Ito a iecs of furnture could result n bie ising: tee omed as brusing on ner body % being lscussed as iflcted in the mesa \ writ tis cdempetey on my wn inate in the hope that it might shed sare Nght on enuse of her death, : 2 §, v.GAt (LON), MRC. P(PAEDUK). 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