Before the Lokayukta National Capital Territory of Delhi

Complainant Naresh Kadyan son of Shri Om Parkash Kadyan, Chief National Commissioner,
Scouts & Guides for Animals & Birds / National Authority for Animal Welfare: OIPA – Indian
People for Animals, resident of C-38, Rose Apartment, Prashant Vihar, sector-14, Rohini, Delhi -
110085 in the matter of allegation against:

1. Secretary, Department of Higher Education, NCT of Delhi.

2. Vice Chancellor – Registrar of Dr. B. R. Ambedkar University, Delhi.
3. Secretary of Delhi Legislative Assembly.

Respectfully Showeth:

It is humbly submitted that:

The Father of Indian Constitution decorated with National awards after his demise, hence no
violation of the terms and conditions of the Bharat Ratna at the level awardees, if we prefix or
suffix Bharat Ratna with his name, same points needs to be examine legally, if any hitch then
Constitution can be amended to avoid contempt of Hon'ble Supreme Court of India.

I am in the opinion that if any decoration or National awards are being awarded posthumously,
that can be exempted and allowed under article 18 (1) of Indian Constitution, which is the only
solution to avoid further litigation's in relation with the functioning of Dr. BR Ambedkar
University of Delhi with Bharat Ratna.

1. The petitioner Naresh Kadyan born by Jat, Cobbler by Profession, Activist by Mission and
Humanitarian by choice, having Master of Arts in Journalism and Mass Communication
along with Post Graduate Diploma and Diploma in Footwear Technology and Advance
Course with Distinction, elected as Member on the Clothing & Footwear Institute, London
(England) as on 8-11-88.
2. The petitioner is Chief National Commissioner, Scouts & Guides for Animals & Birds /
National Authority for Animal Welfare: OIPA – Indian People for Animals, representing
United Nation affiliated OIPA in India, voluntarily retired as Technical Supervisor
(Leather), Haryana Khadi and Village Industries Board at the time of promotion before
five years under protest.
3. Article 18 (1) of Indian Constitution doesn’t defined National awards as title read with the
orders passed by the Hon’ble Supreme Court of India, besides it terms and conditions of the
Bharat Ratna prohibit the misused of this decoration, keeping in view the life time
achievements and performances of a particular person in different fields.
4. There are no clarification if National awards prefixed by any other person with the name of
awardees, after their death as Govt. of Delhi notified as Bharat Ratna Dr. B. R. Ambedkar
University as on July 29, 2008.
5. Bharat Ratna Dr. B. R. Ambedkar University after July 29, 2008, got affiliation and
recognition, making agreements, signing memorandum of association, awarded degree and
diploma etc under the same name and style, prefixing Bharat Ratna.
6. The Petitioner along with Mrs. Sukanya Berwal along with Abhishek Kadyan & Mrs.
Suman Kadyan raised the violation of the article 18 (1) of the Indian Constitution,
 breaching terms and conditions read with orders passed by the Hon’ble Supreme Court of
India, being unconstitutional Bharat Ratna Dr. B. R. Ambedkar University appointing the
Vice Chancellor under section 12 of previous Act, besides it No amendment in the
recognition – affiliation with the NAAC – UGC.
7. After processing the points raised at above said para, Govt. of Delhi placed the bill on Dated
22-8-2016, before the Legislative Assembly of Delhi for approval and same was converted in
the legislation adopting due procedure vide Notification Dated 25-11-2016.
8. The Board of Management of the Ambedkar University of Delhi discussed the above said
position in its meeting held on Dated 13-2-2017, thereafter Resolution No. 10.1 was
approved and Board of Management decision Dated 3-11-2008 continued as it was
approved.
9. The said position as explained above was conveyed to all concerned as on 21-3-2017, now
the question raised the legality of all the functions, degree, diploma, affiliation, recognition,
memorandum of association etc as committed under the unconstitutional Bharat Ratna Dr.
B.R. Ambedkar University, Delhi in between 29-7-2008 to 21-3-2017, contempt of court as
well.

The above named complainant is satisfied that the aforesaid public functionary:

(i) Has abused their position, failed to perform their duties, misguiding Delhi Legislative
Assembly, placing unconstitutional bill before House, introducing the Bharat Ratna Dr.
B. R. Ambedkar Vishwavidyalaya Bill, 2007, prefixing National award as title, violating
article 18 (1) of Indian Constitution, keeping in view abolition of title.
(ii) Has failed to restore the trust of passed out students because Dr. B. R. Ambedkar
University (Amendment) Bill, 2016 placed before the House, passed and enforced since
beginning July 30, 2008.
(iii) All degree, diploma, transcripts and mark sheets awarded under name and seal of the
Bharat Ratna Dr. B. R. Ambedkar University between July 30, 2008 and March 21,
2017 can’t be treated as legal documents, unlawfully misguided passed students, played
with their sentiments and emotions, breaching their trust and believes.
(iv) The Cabinet of Ministers also failed to protect and safeguard the interest of passed
students, while approving the proposal of Dr. B. R. Ambedkar University (Amendment)
Bill, 2016.
(v) All budget allocation, expenditure, Bank transactions, Memorandum of
Understandings, Agreements etc can’t be treated as legal under the name and seal of
Bharat Ratna Dr. B. R. Ambedkar University.
(vi) The NAAC and UGC, still recognizing as Bharat Ratna Dr. B. R. Ambedkar University,
whereas Bharat Ratna omitted as title.
(vii) In exercise of the powers conferred by sub section (2) of section 12 of the Bharat Ratna
Dr. B. R. Ambedkar Vishwavidyalaya Act, 2007 (Delhi Act 9 of 2007), the Lt. Governor
of the National Capital Territory of Delhi as the Chancellor of the Dr. B. R. Ambedkar
University, Delhi, is pleased to appoint Prof. Anu Singh Lather as the Vice Chancellor
of the Dr. B. R. Ambedkar Vishwavidyalaya, Delhi, which is also illegal.

To support the allegations the applicant relies on the following facts and is also filing an affidavit.
The applicant is prepared to swear an affidavit again before the Lokayukta if so desired. The
necessary deposit of Rs. 500/- has been made by affixing judicial stamps of the value on the
complaint.
 PRAYER

I, Naresh Kadyan, Jat by birth: Cobbler by profession: Activist by mission: Humanitarian by

choice, It is, therefore, prayed that:

1. An enquiry be made against the said public functionary for their non performance
restoring the trust of public, safeguarding the interest of passed out student, obtained
degree, diploma and mark sheets under the name and seal of the Bharat Ratna Dr. B. R.
Ambedkar University.
2. Amendment in the article 18 (1) of the Indian Constitution, clarifying the use of National
award as decorated with Bharat Ratna after the demise of awardees as posthumously.
3. Legalize the functioning, budget provisions, expenditures, degree, diploma, MoU, affiliation
and recognition of the University under the name and style of Bharat Ratna Dr. B. R.
Ambedkar between its existences as on 29-7-2008 to 21-3-2017, keeping in view the article
18 (1) of Indian Constitution read with orders passed by the Court of law.
4. Necessary amendment in the recognition – affiliation of Br. B. R. Ambedkar University
with NAAC – UGC.
5. Responsibilities may kindly be fixed on the tainted public servants.
6. Any other orders deems fit.

Chowkidar Naresh Kadyan

VERIFICATION

I Naresh Kadyan son of Shri Om Parkash Kadyan resident of C-38, Rose Apartment,
Prashant Vihar, sector-14, Rohini, Delhi - 110085 hereby declare that the facts stated by me in
Para's one to seven in the complaint are true to my personal knowledge and / or are based on
information and / or documents, and believed to be true.

Chowkidar Naresh Kadyan

Verified at Rohini Court this June 8, 2019.

तमसो मा ज्योततर्ग मय : अंधकार से प्रकाश की ओर चलो, बढो

 Grievance Status for registration number: PMOPG/E/2019/0290275
Grievance Description:
It is humbly submitted that: The Father of Indian Constitution decorated with National
awards after his demise, hence no violation of the terms and conditions of the Bharat Ratna
at the level awardees, if we prefix or suffix Bharat Ratna with his name, same points needs
to be examine legally, if any hitch then Constitution can be amended to avoid contempt of
Hon’ble Supreme Court of India. We are jointly in the opinion that if any decoration or
National awards are being awarded posthumously, that can be exempted and allowed
under article 18 (1) of Indian Constitution, which is the only solution to avoid further
litigation in relation with the functioning of Dr. BR Ambedkar University of Delhi with
Bharat Ratna. 1. The petitioner Naresh Kadyan born by Jat, Cobbler by Profession,
Activist by Mission and Humanitarian by choice, having Master of Arts in Journalism and
Mass Communication along with Post Graduate Diploma and Diploma in Footwear
Technology and Advance Course with Distinction, elected as Member on the Clothing
Footwear Institute, London (England) as on 8-11-88. 2. The petitioner is Chief National
Commissioner, Scouts Guides for Animals Birds - National Authority for Animal Welfare:
OIPA - Indian People for Animals, representing United Nation affiliated OIPA in India,
voluntarily retired as Technical Supervisor (Leather), Haryana Khadi and Village
Industries Board at the time of promotion before five years under protest. 3. Article 18 (1)
of Indian Constitution doesn’t defined National awards as title read with the orders passed
by the Hon’ble Supreme Court of India, besides it terms and conditions of the Bharat
Ratna prohibit the misused of this decoration, keeping in view the life time achievements
and performances of a particular person in different fields. 4. There are no clarification if
National awards prefixed by any other person with the name of awardees, after their death
as Govt. of Delhi notified as Bharat Ratna Dr. B. R. Ambedkar University as on July 29,
2008. 5. Bharat Ratna Dr. B. R. Ambedkar University after July 29, 2008, got affiliation
and recognition, making agreements, signing memorandum of association, awarded degree
and diploma etc under the same name and style, prefixing Bharat Ratna. 6. The Petitioner
along with Mrs. Sukanya Berwal along with Abhishek Kadyan Mrs. Suman Kadyan raised
the violation of the article 18 (1) of the Indian Constitution, breaching terms and conditions
read with orders passed by the Hon’ble Supreme Court of India, being unconstitutional
Bharat Ratna Dr. B. R. Ambedkar University appointing the Vice Chancellor under
section 12 of previous Act, besides it No amendment in the recognition - affiliation with the
NAAC - UGC. 7. After processing the points raised at above said para, Govt. of Delhi
placed the bill on Dated 22-8-2016, before the Legislative Assembly of Delhi for approval
and same was converted in the legislation adopting due procedure vide Notification Dated
25-11-2016. 8. The Board of Management of the Ambedkar University of Delhi discussed
the above said position in its meeting held on Dated 13-2-2017, thereafter Resolution No.
10.1 was approved and Board of Management decision Dated 3-11-2008 continued as it was
approved. Petitioner (s) prayers that: 1. Amendment in the article 18 (1) of the Indian
Constitution, clarifying the use of National award as decorated with Bharat Ratna after the
demise of awardees as posthumously. 2. Legalize the functioning, degree, diploma, MoU,
affiliation and recognition of the University under the name and style of Bharat Ratna Dr.
B. R. Ambedkar between its existences as on 29-7-2008 to 21-3-2017, keeping in view the
article 18 (1) of Indian Constitution read with orders passed by the Court of law.
 Grievance Status for registration number: MINPA/E/2019/00254
Grievance Description:
It is humbly submitted that: The Father of Indian Constitution decorated with National awards
after his demise, hence no violation of the terms and conditions of the Bharat Ratna at the level
awardees, if we prefix or suffix Bharat Ratna with his name, same points needs to be examine
legally, if any hitch then Constitution can be amended to avoid contempt of Hon’ble Supreme
Court of India.
We are jointly in the opinion that if any decoration or National awards are being awarded
posthumously, that can be exempted and allowed under article 18 (1) of Indian Constitution, which
is the only solution to avoid further litigation in relation with the functioning of Dr. BR Ambedkar
University of Delhi with Bharat Ratna.
1. The petitioner Naresh Kadyan born by Jat, Cobbler by Profession, Activist by Mission and
Humanitarian by choice, having Master of Arts in Journalism and Mass Communication along
with Post Graduate Diploma and Diploma in Footwear Technology and Advance Course with
Distinction, elected as Member on the Clothing & Footwear Institute, London (England) as on 8-11-
88.
2. The petitioner is Chief National Commissioner, Scouts & Guides for Animals & Birds - National
Authority for Animal Welfare: OIPA - Indian People for Animals, representing United Nation
affiliated OIPA in India, voluntarily retired as Technical Supervisor (Leather), Haryana Khadi and
Village Industries Board at the time of promotion before five years under protest.
3. Article 18 (1) of Indian Constitution doesn’t defined National awards as title read with the orders
passed by the Hon’ble Supreme Court of India, besides it terms and conditions of the Bharat Ratna
prohibit the misused of this decoration, keeping in view the life time achievements and
performances of a particular person in different fields.
4. There are no clarification if National awards prefixed by any other person with the name of
awardees, after their death as Govt. of Delhi notified as Bharat Ratna Dr. B. R. Ambedkar
University as on July 29, 2008.
5. Bharat Ratna Dr. B. R. Ambedkar University after July 29, 2008, got affiliation and recognition,
making agreements, signing memorandum of association, awarded degree and diploma etc under
the same name and style, prefixing Bharat Ratna.
6. The Petitioner along with Mrs. Sukanya Berwal along with Abhishek Kadyan & Mrs. Suman
Kadyan raised the violation of the article 18 (1) of the Indian Constitution, breaching terms and
conditions read with orders passed by the Hon’ble Supreme Court of India, being unconstitutional
Bharat Ratna Dr. B. R. Ambedkar University appointing the Vice Chancellor under section 12 of
previous Act, besides it No amendment in the recognition - affiliation with the NAAC - UGC.
7. After processing the points raised at above said para, Govt. of Delhi placed the bill on Dated 22-
8-2016, before the Legislative Assembly of Delhi for approval and same was converted in the
legislation adopting due procedure vide Notification Dated 25-11-2016.
8. The Board of Management of the Ambedkar University of Delhi discussed the above said
position in its meeting held on Dated 13-2-2017, thereafter Resolution No. 10.1 was approved and
Board of Management decision Dated 3-11-2008 continued as it was approved.
Petitioner (s) prayers that:
1. Amendment in the article 18 (1) of the Indian Constitution, clarifying the use of National award
as decorated with Bharat Ratna after the demise of awardees as posthumously.
2. Legalize the functioning, degree, diploma, MoU, affiliation and recognition of the University
under the name and style of Bharat Ratna Dr. B. R. Ambedkar between its existences as on 29-7-
2008 to 21-3-2017, keeping in view the article 18 (1) of Indian Constitution read with orders passed
by the Court of law.
 Grievance Status for registration number: GNCTD/E/2019/03656
Grievance Description:
It is humbly submitted that: The Father of Indian Constitution decorated with National awards
after his demise, hence no violation of the terms and conditions of the Bharat Ratna at the level
awardees, if we prefix or suffix Bharat Ratna with his name, same points needs to be examine
legally, if any hitch then Constitution can be amended to avoid contempt of Hon’ble Supreme
Court of India.
We are jointly in the opinion that if any decoration or National awards are being awarded
posthumously, that can be exempted and allowed under article 18 (1) of Indian Constitution, which
is the only solution to avoid further litigation in relation with the functioning of Dr. BR Ambedkar
University of Delhi with Bharat Ratna.
1. The petitioner Naresh Kadyan born by Jat, Cobbler by Profession, Activist by Mission and
Humanitarian by choice, having Master of Arts in Journalism and Mass Communication along
with Post Graduate Diploma and Diploma in Footwear Technology and Advance Course with
Distinction, elected as Member on the Clothing & Footwear Institute, London (England) as on 8-11-
88.
2. The petitioner is Chief National Commissioner, Scouts & Guides for Animals & Birds - National
Authority for Animal Welfare: OIPA - Indian People for Animals, representing United Nation
affiliated OIPA in India, voluntarily retired as Technical Supervisor (Leather), Haryana Khadi and
Village Industries Board at the time of promotion before five years under protest.
3. Article 18 (1) of Indian Constitution doesn’t defined National awards as title read with the orders
passed by the Hon’ble Supreme Court of India, besides it terms and conditions of the Bharat Ratna
prohibit the misused of this decoration, keeping in view the life time achievements and
performances of a particular person in different fields.
4. There are no clarification if National awards prefixed by any other person with the name of
awardees, after their death as Govt. of Delhi notified as Bharat Ratna Dr. B. R. Ambedkar
University as on July 29, 2008.
5. Bharat Ratna Dr. B. R. Ambedkar University after July 29, 2008, got affiliation and recognition,
making agreements, signing memorandum of association, awarded degree and diploma etc under
the same name and style, prefixing Bharat Ratna.
6. The Petitioner along with Mrs. Sukanya Berwal along with Abhishek Kadyan & Mrs. Suman
Kadyan raised the violation of the article 18 (1) of the Indian Constitution, breaching terms and
conditions read with orders passed by the Honble Supreme Court of India, being unconstitutional
Bharat Ratna Dr. B. R. Ambedkar University appointing the Vice Chancellor under section 12 of
previous Act, besides it No amendment in the recognition - affiliation with the NAAC - UGC.
7. After processing the points raised at above said para, Govt. of Delhi placed the bill on Dated 22-
8-2016, before the Legislative Assembly of Delhi for approval and same was converted in the
legislation adopting due procedure vide Notification Dated 25-11-2016.
8. The Board of Management of the Ambedkar University of Delhi discussed the above said
position in its meeting held on Dated 13-2-2017, thereafter Resolution No. 10.1 was approved and
Board of Management decision Dated 3-11-2008 continued as it was approved.
Petitioner (s) prayers that:
1. Amendment in the article 18 (1) of the Indian Constitution, clarifying the use of National award
as decorated with Bharat Ratna after the demise of awardees as posthumously.
2. Legalize the functioning, degree, diploma, MoU, affiliation and recognition of the University
under the name and style of Bharat Ratna Dr. B. R. Ambedkar between its existences as on 29-7-
2008 to 21-3-2017, keeping in view the article 18 (1) of Indian Constitution read with orders passed
by the Court of law.