Koodankulam Protesters Appeal To IAEA

March 27, 2012

The People’s Movement Against Nuclear Energy (PMANE)

Idinthakarai & P.O - 627 104

Tirunelveli District

koodankulam@yahoo.com

98656-83735

The Chairman

Atomic Energy Regulatory Board

Niyamak Bhavan

Anushaktinagar

Mumbai 400 094

Dear Sir/Madam:

Greetings! We, the people of southern districts of Tamil Nadu and Kerala have been struggling against the Koodankulam Nuclear Power Project (KKNPP) at Koodankulam in Tirunelveli district, Tamil Nadu, India since its inception in the 1980s.

The KKNPP reactors from Russia are being set up without sharing the Environmental Impact Assessment (EIA), Site Evaluation Study and Safety Analysis Report with the people, or the people’s representatives and the press. After a 23-year-long struggle, we obtained a copy of the outdated and incomplete EIA only a few months back. No public hearing has been conducted for the first two reactors either. The KKNPP project has been imposed on an uninformed and unwilling population throwing all democratic precepts and values of our country to the wind.

The people of Tamil Nadu and Kerala are deeply concerned about our safety and wellbeing as the KKNPP reactors pose grave and serious threats.  The actual siting of the reactors, the quality of construction and the pipe work and the overall integrity of the KKNPP structures have been called into question by the very workers and contractors who work there in Koodankulam. Similarly, the then Minister of State in the Ministry of Environment and Forest (MoEF) Mr. Jairam Ramesh announced a few months ago that the central government had decided not to give permission to KKNPP 3-6 as they had violated the Coastal Regulation Zone stipulations. It is pertinent to point out that KKNPP 1 and 2 are also violating CRZ terms.

The 2004 December tsunami did flood the KKNPP installations. And there was a mild tremor in the surrounding villages of Koodankulam on March 19, 2006. On August 12, 2011, there were tremors in 7 districts of Tamil Nadu. These happenings heighten our anxieties and worries about the possibility of natural disasters occurring in the project area.

Similarly, more than 1.5 million people live within the 30 km radius of the KKNPP which far exceeds the AERB (Atomic Energy Regulatory Board) stipulations. It is quite impossible to evacuate this many people quickly and efficiently in case of a nuclear disaster at KKNPP.

There have been serious and credible international concerns about the design, structure and workings of the untested Russian-made VVER 1000 reactors. Even a Russian government-sponsored study has found serious flaws with the VVER 1000 reactors.

The issue of liability for the Russian plants has also not been settled yet. Defying the Indian nuclear liability law, Russia insists that the Inter-Governmental Agreement (IGA), secretly signed in 2008 by the Indian and Russian governments, precedes the liability law and that Article 13 of the IGA clearly establishes that NPCIL is solely responsible for all claims of damage. We wonder if the Russian reactors are the best in the world, as claimed by the Russian Ambassador to India, why they refuse to offer any liability.

On the contrary, our own Expert Team has identified several serious safety issues with regards to the KKNPP project which we have listed below as an annexure.

Most importantly, the KKNPP and the Nuclear Power Corporation of India Ltd. (NPCIL) officials have not conducted any mock drills and evacuation drills in the 30 km radius of the project. The NPCIL informed us in its letter dated January 9, 2012 (No. NPCIL/VSB/CPIO/1400/KKNPP/2012/44) that Off-site “Emergency Exercise has not been carried out in KKNPP.” In a subsequent letter dated February 16, 2012 (No. NPCIL/VSB/CPIO/1598/KK/2012/300) NPCIL stated: “As per the AERB guidelines, offsite emergency exercise shall be conducted prior to regular operation of a Nuclear Power Plant. AERB guidelines will be followed in KKNPP in this regard.” However, we hear reliably that the KKNPP officials are trying to load the fuel rods in the reactors against the AERB and other international stipulations.

In the light of the above situation, we would very much like to request you to intervene in the KKNPP matter and stall its commissioning. Looking forward to hearing from you soon, we send you our best regards and all peaceful wishes.

Cordially,

S.P.Udayakuamr, Ph.D.                                 M. Pushparayan                                 M. P. Jesuraj

Coordinator

Enclosures:

[1] Issues PMANE Expert Team Has Identified

Copy to:

The Head

Safety Research Institute

IGCAR Campus

Kalpakkam 603 102

Tamil Nadu

Email: ycm@igcar.gov.in

            ksm@igcar.gov.in

International Atomic Energy Agency

Vienna International Centre

P.O. Box 100

A-1400 Vienna

Austria

Email : Official.Mail@iaea.org

United Nations Environment Programme
United Nations Avenue, Gigiri
PO Box 30552, 00100
Nairobi, Kenya

Email: executiveoffice@unep.org

            unepinfo@unep.org

International Committee of the Red Cross

19 Avenue de la paix

CH 1202

Geneva

Amnesty International

1 Easton Street

Lonndon WC1X 0DW

International Alert

346 Clapham Road

London SW9 9AP

Email: general@international-alert.org

Human Rights Watch

350 Fifth Avenue

34^th Floor

New York, NY 10118-3299

International Commission on Radiological Protection
280 Slater Street Ottawa, Ontario K1P 5S9 CANADA sci.sec@icrp.org admin@icrp.org

Greenpeace International
Ottho Heldringstraat 5
1066 AZ Amsterdam
The Netherlands

Email: supporter.services.int@greenpeace.org

ANNEXURE

Issues PMANE Expert Team Has Identified with the KKNPP Project

1.      The Koodankulam site is not only prone to small-volume volcanic eruptions, but also to mega-tsunamis with heights exceeding 100 feet, arising out of the presence of two large “slumps” in the seabed of Gulf of Mannar less than 100 km from the plant. A 1982 study in a noted journal documents the presence of two slumps -- the East Comorin slump and the Colombo slump -- in the vicinity of the Koodankulam site. The second report by the Central Govt Expert Group has accepted the presence of the slumps and the possibility of a Near Field Tsunami occurring out of a landslide. This is in opposition to their earlier position and also to the position of AERB that Near field Tsunamis are not possible in India. However, their contention is on the height of the Tsunami waves. While welcoming their change in accepting the possibility of Near Field Tsunami, the PMANE Expert Team wishes to state that after the 1982 study, a tsunami did occur in December 2006 and it may have changed the structures of the Slumps. Hence merely answering the question from the 1982 text is not sufficient.

2.      PMANE’s Expert Team is alarmed that NPCIL has allowed the siting of the plant in an area characterised by sub-volcanic intrusions – an indication of volcanism in the vicinity of the plant. The presence of sub-volcanic intrusions of the kind found in the KKNPP site is precisely the reason why the United States Government abandoned the Yucca Mountain site as a possible waste storage site owing to concerns about the structural integrity. In addition to this, small volume volcanic eruptions have occurred in the KKNPP site’s vicinity from the year 1998.

3.      Studies by Oil and Natural Gas Commission (ONGC), the Geological Survey of India (GSI) and numerous other terrestrial and marine geologists confirm the presence of basaltic intrusions into the crust and the Gulf of Mannar seabed. Their findings tell us that the Gulf of Mannar sea bed has been thinned because of this. Its thickness is a mere 1,000 to 5,000 metres instead of average 40,000 metres for continental crust.

4.      Scientists from various national institutes have published as late as 2010 that the crustal thickness of Koodankulam site is much thinner than the Gulf of Mannar Crust because of similar sub-volcanic intrusions. Ground Magnetic Surveys conducted by them have suggested that the Crustal thickness is a mere 150 to 200 metres at Koodankulam site.

5.      The entire Koodankulam region is known for its lime stone formations. Lime stone formations are known to the formation of Sink holes and underground caves. Events that occurred on November 26, 2011 at Pannaiyarkulam, in 2008 at Radhapuram (both located 10 kms from the KKNPP site), and in 1998 at Maruthankulam (25kms from the KKNPP site) have suggested that this is a “KARST” Region. AERB’s safety laws clearly state that if a Karst region is suspected a detailed study has to be conducted. Such a study has not been attempted by the NPCIL.

6.      During the 2004 tsunami the withdrawal of the sea was around 4-5 Kms from the shore. Every year after this tsunami, the some places of the coast of Tamil Nadu have faced the issue of sea water withdrawal at least 3 times a year. Tsunami hazard manual released by the USNRC in March 2009 states that if sea water withdrawal is an issue at the site then the chances of the reactor going in for a dry intake should be studied thoroughly. Dry intake can cause damage to the turbines and reactors. Each minute a reactor needs 5,000 cubic-metres of sea water. Hence a detailed volcanic hazard study, tsunami hazard study and a study about the “Karst” Terrain is a must.

7.      Another crucial failure of the NPCIL is the fact that the plant has been assured supply of freshwater for merely 36 hours and 25 minutes. The dependence on a single source, namely, the desalination plants, further reduces the reliability of this water source because desalination plants rely on the sea and electricity. Both can be disrupted by disturbances in electricity supply and cyclones and extreme weather events in the sea along with Jelly fish intrusions. In such a situation, reactors will have to be closed down immediately and they may have just enough water for maintaining the safety systems for only 10 days. The reserve of potable water for the KKNPP Township is sufficient only for 2 days. The seawater intake pipeline of the Minjur desalination plant in Thiruvallur district was uprooted during the Cyclone Nisha in 2008. Repairing the pipeline required engineers from the Netherlands and it took more than 45 days to mend the pipeline.

8.      Department of Atomic energy (DAE) funded study by Dr. Manjula Datta has found that the morbidity burden in the proximity villages of Kalpakkam is 400% higher than in distant villages. The diseases include Cancer, mental retardation, thyroid problems, infertility, lumps, stroke, cataract, TB, ulcer and diabetes. Another study conducted by Dr. V. Pugazhendhi et. al. showed that auto immune thyroid disease among women living in upto 40 kms from the Kalpakkam site was significantly higher than those living 500 kms away. In another study conducted by the same doctor in 2003 among the Kalpakkam employees and family members had shown that the death rate due to Multiple Myloma (a bone marrow cancer) is statistically significant. Studies based on data supplied by the NPCIL shows that the prevalence of cancer among workers and wives of the BARC and the TAPS is significantly higher than that found in MAPS. The first 2 reactors became critical during the 1960’s and the 1970’s whereas the MAPS came critical during 1984-85. Yet another study shows significant deviation in sex-ratio of children born to employees of the BARC and the TAPS which is indicative of genetic mutations.

<> <> <> <>

Idinthakarai Update, March 22, 2012 - S.P. Udayakumar

The situation here is still grim. There are some 10,000 people from coastal and interior villages. Most of them are women including pregnant women and nursing women. I myself saw many nursing women feeding their babied sweetened water as there was no milk coming to the village. More people are coming by boats and on foot as the access roads are all blocked by police. There is no bus service to this place. There is no sanitary complex and women bear the brunt of it. No public health official has ever come to help the people.

Some 15 of us have been on indefinite hunger strike and no medical doctor has ever come here to check our health. The Dinamalam newspaper has reported today that we have all been eating heartily and pretending to be fasting. If this anti-Tamil newspaper can prove that there is a trace of food in my or Pushparayan’s stomach, we are ready to leave this protest. Otherwise, will they stop publishing this stupid paper? We are fighting for a cause not prostituting our soul like the Dinamalam does.

On March 21, my mother had received a phone call from one advocate by the name T. Udayakumar and he claimed he was calling from the DGP office in Chennai. He asked my mother to ask me to leave the protest so that all the cases against me would be dropped and I would get whatever I ask for. My mother told him that I was not a man of that nature and ended the conversation. That evening the Superintendent of Police of Tirunelveli District called me on my mobile and asked me to surrender alone so that people would not be affected. I told him that I was all ready for that but the people here at Idinthakarai also wanted to get arrested along with me and they would not let me go alone. I proposed to the SP to send enough number of buses and two police officers so that there would not be any stampede or tussle and we all would board the buses peacefully and go wherever they wanted us to go. He would not accept that proposition and said in anger: “This is the last time I talk to you.” There ended our conversation.

That night the police officer who was on security duty at our SACCER Matriculation School outside Nagercoil town had received a phone call from the Kanyakumari District SP office to go away from the school. Then a group of vandals, obviously with the blessings of the police, had entered the school and destroyed it very badly. The compound wall was completely demolished and the gate damaged. They ransacked the school bus after tearing down the car shed’s iron shutters. They had entered the KG classrooms and destroyed all the small little chairs which my children were using to sit on. They had broken all the tables and chairs and I do not understand why they punished my little children like this. The vandals had entered our school library and destroyed all the 12 glass bookshelves and tables and threw away the books. My 250 children are all avid readers and have been using our library extensively. This reminds me of the burning of the Public Library at Jaffna a few years ago.

The governments and the police treat and speak of me as if I were Osama bin Laden and our people some mindless terrorists. We resent this inhuman and brutal treatment . Electricity, water, milk and other essentials have been cut for two days; people cannot go out of and come into Idinthakarai as there is brutal police control. We are surrounded by police and I truly feel like I am at Mullivaickal. We are a group of simple people who have been fighting nonviolently and democratically against an untested foreign reactor with all kinds of problems and hiccups. We have not done any harm to anybody or anybody’s property in our eight-month long struggle. The whole country is proud of our people.

The stalemate continues. There are protests happening all over the country and the state of Tamil Nadu. Whoever is farsighted enough to worry about the future of India’s “ordinary citizens,” our natural resources, the well-being of our progeny, the possibility of losing our freedom to the New Nuclear East India Companies and most importantly, the democratic fabric of our country support us. We thank them and you for standing with us. We are ready for any brutal police action but will not give up our nonviolent noncooperation campaign.

- S.P. Udayakumar

PIL filed to revoke Cr.P.C. 144 order at Koodankulam

In the High Court of Judicature at Madras

(Special Original Jurisdiction)

W.P. No. 7520 of 2012

P.Pugalenthi,  

Advocate

No.5, 4^th Floor,

Sunkurama Street,

Chennai.600 001                                                              .. Petitioner

Vs

1)   State of Tamil Nadu

represented by the

Chief Secretary to Government,

Secretariat,

Chennai.600 009

2)   The District Collector,

Tirunelveli District

Tirunelveli.

AFFIDAVIT

          I, P.Pugalenthi, S/o  Pandian, aged about 36 years, residing at No.97, Bangaru Street, Ellis Road, Anna Salai, Chennai.2,    do hereby on solemn affirmation, state as under:

1.. I am the petitioner herein.  I am conversant with the facts of the case.  I am competent to file this affidavit.

2..      I submit that I am an advocate having a standing of about 10 years.    I am also  the Director of the Prisoners Rights Forum, Chennai which is a registered public trust  (Regn. No.4319/2008).   I am the Secretary of Tamil Nadu Peoples Rights Forum which is a human rights organization. I have initiated a number of Public Interest Litigations before the Hon’ble Court concerning enforcement of human rights, fundamental rights and Constitutional rights of the citizens as well as the foreigners.   In the Writ Petitions filed by me in public interest , the Hon’ble High Court has been pleased to pass several orders directing the State to discharge its public duty in tune with the command of the Constitution.  To cite an instance, when a woman prisoner was tortured in Vellore Central Prison, I rushed to the Hon’ble Court with  a Writ Petition for the purpose of enforcement of her rights under Article 21 of the Constitution and the Hon’ble High Court was pleased to award the woman prisoner a compensation of Rs.50,000/- for the injuries suffered by her at the hands of prison officials and was also appreciative of my efforts to bring to light the ghastly incident which had taken place inside Vellore Prison.

3.    I state that “The Hindu”  dated 20 March 2012 reported that a prohibitory order under Section 144 C. P.C. was clamped on Radhapuram Taluk, Tirunelveli District.  Radhapuram Taluk comprises about 50 villages.  According to the press reports the prohibitory order would remain in force until 2^nd April 2012.   The order was passed by respondent No.2 only with a view to preventing the villagers of the entire Radhapuram Taluk from moving from one place to another.   In other words, thousands of people residing in those villages of Radhapuram taluk have been virtually under house arrest since yesterday.   Hence this Writ Petition in public interest for a direction to the State of Tamil Nadu to immediately lift the prohibitory order passed under section 144 Cr. P.C. and allow the people of Radhapuram Taluk to move freely on the following amongst other grounds.  

GROUND

a)       It is submitted that the “Wise Indian Chief of Seattle” (USA) once replied to the “Great Wise Chief in Washington” when he offered to buy the land of native Red Indians. “Every part of the earth is sacred to my people, every shiny pine needle, every sandy shore, every mist in the dark woods, every clearing and humming insect is holy in the memory and experience of my people.  The sap which courses through the trees carries the memories of the red man.”  The people of almost 50 villages of Radhapuram Taluk have today lost their villages, lost their land, and lost every amenities of life because they are made incapacitated to move from one place to another.   It is no exaggeration to say that Radhapuram Taluk has gone out of the map of India today.    One would recall the colonial days when people were not allowed to move freely and were treated like slaves at the command of the State.  The press reports and visual media reports appearing today are an indication that the women folk and the children are afraid of the huge police force deployed in and around Idinthakarai village and they are unable to go even to buy Milk.  Their day today life is in danger.  They are scared of the police personnel numbering more than 5000.   The respondent – State of Tamil Nadu has no justification whatsoever to deploy large number of police personnel in and around the villages of Radhapuram Taluk.  The Supreme Court has in Gulam Abbas and others vs State of UP and others : AIR 1981 SC 2198 held :

“The entire basis of action under Section 144 is provided by the urgency of the situation and the power thereunder is intended to be availed of for preventing disorders, obstructions, and annoyances with a view to secure the secure the public weal by maintaining public peace and tranquility. Preservation of public peace and tranquility is the primary function of the government and the aforesaid power is conferred on the executive magistracy enabling it to perform that function effectively during emergent situations and as such it may become necessary for the executive magistrate to override temporarily private rights and in a given situation the power must extend to restraining individual from doing acts perfectly lawful in themselves, for, it is obvious that when there is a conflict between the public interest and private interest the former must prevail.”

Here, in the case of Radhapuram Taluk, respondent No.2 has, in the guise of exercising his powers for maintaining public peace and tranquility, deprived the people of Radhapuram Taluk of their basic and most valuable fundamental right to move freely from one place to another.   Under Section 144 Cr. P.C., private rights of the people can be curtailed by the executive magistrate, certainly not fundamental rights of the people.   Preventing people from moving from one place to another can never fall within the realm of reasonable restriction.   When an authority of the State prevents a person from moving from one place to another the authority concerned  is virtually arresting that person and does not allow him to move for no fault of his.   All the people of Radhapuram Taluk are today under house arrest by virtue of a single order by respondent No.2 passed under Section 144 Cr. P.C.    No material whatsoever was disclosed by the respondent – State of Tamil Nadu to the people of Radhapuram Taluk explaining the necessity of imposing this unreasonable restriction on the people’s movement from one’s house from other places.    Since the prohibitory order under Section 144 Cr.P.C. operative today in the entire territory of Radhapuram Taluk is in gross violation of Article 21 of the Constitution, the order cannot be allowed to stand even for a moment and deserves to be declared by the Hon’ble Court to be null and void.

b) It is submitted that more than 3000 people, largely women who are participants in the protest against commissioning of Koodankulam Nuclear Power Plant in Idinthakarai village including the children who came to meet their parents near the place of protest have no option but to remain in the place of protest without food and other basic amenities.   Admittedly the protest which is alleged to be posing a threat to public peace and tranquility is a non-violent protest.   No untoward incident whatsoever has so far been reported from any corner.   The protest has been going on for months together.   Even the Chief Minister of Tamil Nadu was pleased to meet the representatives of the protestors including Advocate Sivasubramaniam, now arrested  on charges of sedition, not long ago and considered their legitimate grievance against the dangers of nuclear power plant.   Respondent No.2, who has now exercised his powers under Section 144 Cr. P.C. never found that the protestors were ever the cause of any unrest in the society.   There is no reason whatsoever why a prohibitory order under Section 144 Cr. P.C. should have been clamped on the entire Radhapuram Taluk. Instead of giving adequate protection to the people living in about 50 villages of Radhapuram Taluk, and instead of allowing them to enjoy their fundamental rights guaranteed under the constitution the respondent- State of Tamil Nadu has made them prisoners.  Therefore, the prohibitory order under Section 144 Cr. P.C. deserves to be declared null and void.

c)       It is submitted that until the conclusion of Sankarankoil bye-election on 18.03.2011, the respondent – State of Tamil Nadu remained satisfied that Radhapuram Taluk is a peaceful place.    The moment the bye-election was over, the respondent – State of Tamil Nadu came to a conclusion that there was no public peace nor was there tranquility in the entire Radhapuram Taluk and that therefore the people of Radhapuram Taluk should be imprisoned in the place where they are and should not be allowed to move from one place to another.   All of a sudden, the entire Radhapuram Taluk became a place of riot and chaos in the opinion of the law enforcement authorities.  The only report that was made available to the people of Tamil Nadu by the State Government is that the commissioning of Koodankulam nuclear power plant may go on in view of the report of the Expert Committee headed by Dr.Iniyan. Nowhere the respondent – State of Tamil Nadu has taken a stand that there has been unrest in Radhapuram Taluk for quite some time and that therefore a large contingent of police personnel would be posted near Idinthakarai village.    In the absence of any decision based on relevant materials, deployment of about 5000 armed police and para-military personnel near Idinthakarai village and prevention of the people of the entire Radhapuram Taluk to move from one place to another and continuance of such deployment of armed police personnel in the said place without any threat perception in the locality, would be not only unjust, unfair and unreasonable and would be violative of Articles 14, 19 and 21 of the Constitution. 

d)       It is submitted that the respondent – State of Tamil Nadu uses tax payers’ money and deploys large contingents of police personnel only with a view to curtailing the fundamental rights of the people who are the masters of the state.   There is no difference between a foreigner ruling the country with the funds of the natives and the police personnel ruling the country who are paid by the people for whom they exist.   In the event of the police personnel being allowed to take law into their own hands and to put all kinds of restrictions on the exercise of the basic fundamental right to move freely from one place to another, the day would not be far off where the constitutional machinery would totally fail in the state of Tamil Nadu.    In the circumstances, the prohibitory order under Section 144 Cr. P.C. deserves to be declared by the Hon’ble Court, void.

e)       It is submitted that it is learnt from the press persons stationed in Idinthakarai village that all mediapersons have been instructed by the police not to move beyond A.V.Thomas Mandapam which is about 4 Km away from Idinthakarai where the protest against Koodankulam Nuclear Power Project is going on.   The protestors, largely women, who have been on this peaceful and non-violent protest for more than six months are today not allowed to move freely from the place of protest to their residence and come back to continue their protest. No power in the state however great it may be can curtail the fundamental right of the people to speech and expression.    By not allowing the protestors and the people to move from one place to another, the respondent – State of Tamil Nadu has made them deaf and dumb.   A country which boasts of a great democratic constitution in the world is now under the shackles of ‘near-dictatorship’.    No expression would be adequate to describe the state of affairs of Radhapuram Taluk where thousands of people residing in about 50 villages are made to live like slaves. Depravation of one’s fundamental rights to speech and expression and to live with human dignity can never be compensated by any remedial action of the State.  Once freedom is lost, it is lost forever.  The Hon’ble Court being the custodian of the Constitution would be pleased to declare that  a wholesale prohibitory order like the one clamped on Radhapuram Taluk, Tirunelveli District, Tamil Nadu would be violative of all canons of democratic polity and would ring a death knell to democracy in the country.  

4.       I state that I have not filed any other petition in the Hon'ble Court or in any other Court regarding the subject matter of this Writ Petition.

5.  I state that I have no personal interest in the case.     I have earlier filed  many public interest litigations in the Hon’ble Court.   One such Public Interest Litigation relating to public employment is WP No.110/2010 challenging the decision of the Government of Tamil Nadu in G.O. Ms. No. 170 dated 18.12.2009 to fill up the vacancies for various posts by appointing retired government servants and those retiring from quasi government organisations on contract basis.  Pursuant to the said public interest litigation, the Government of Tamil Nadu issued a fresh G.O. viz. G.O. Ms. No.15 dated 03.02.2010 to the effect that the contract of retired persons already appointed 

would be terminated on the availability of eligible persons and the Hon’ble Court disposed of the said W.P. on 30.03.2010.     I undertake to pay the costs, if any, if this PIL is found to be intended for personal gain or oblique motive.  I have filed this petition from my own funds.    To my knowledge, no PIL arising on the issue raised in this petition has been filed anywhere.   This public interest litigation is maintainable in law. The contents of this paragraph are in compliance with the Rules to regulate the Public Interest Litigations filed under Article 226 of the Constitution of India.

Solemnly affirmed at Chennai                                             Before me

this the 21^st March 2012

and signed his name in my presence.      

Advocate, Chennai

In the High Court of Judicature at Madras

(Special Original Jurisdiction)

W.P. No. 7520 of 2012

P.Pugalenthi,  

Advocate,

No.5, 4^th Floor,

Sunkurama Street,

Chennai.600 001                                                              .. Petitioner

Vs

1)   State of Tamil Nadu

represented by the

Chief Secretary to Government,

Secretariat,

Chennai.600 009

2)   The District Collector,

Tirunelveli District

Tirunelveli.

WRIT PETITION UNDER ARTICLE 226 OF THE CONSTITUTION

1..      The address for service of the petitioner is that of his counsel M.Radhakrishnan, Advocate, 134, Thambu Chetty Street, Chennai. 600 001.

2..      The address for service on the respondent is as stated above.

3..      For the reasons stated in the accompanying affidavit, it is prayed that the Hon’ble Court be pleased to issue a WRIT OF DECLARATION that the action of respondent No.2 of clamping an order under Section 144 Cr. P.C. on the entire Radhapuram Taluk, Tirunelveli District  which is in force till April 2, 2012 is null and void, and thus render justice.

Dated at Chennai this the  21^st day of March 2012

                                                                             Counsel for the petitioner

In the High Court of Judicature at Madras

(Special Original Jurisdiction)

M.P. No. 1 of 2012

in   

W.P. No.  7520 of 2012

P.Pugalenthi,  

Advocate,

No.5, 4^th Floor,

Sunkurama Street,

Chennai.600 001                                                              .. Petitioner

Vs

1)   State of Tamil Nadu

represented by the

Chief Secretary to Government,

Secretariat,

Chennai.600 009

2)   The District Collector,

Tirunelveli District

Tirunelveli.

PETITION OF DIRECTION UNDER ARTICLE 226 OF THE CONSTITUTION

1..      The address for service of the petitioner is that of his counsel M.Radhakrishnan, Advocate, 134, Thambu Chetty Street, Chennai. 600 001.

2..      The address for service on the respondent is as stated above.

3..      For the reasons stated in affidavit filed in support of the Writ Petition, it is prayed that the Hon’ble Court be pleased to grant an interim direction directing the respondents to give adequate protection to all the people of Radhapuram Taluk including the protestors against Koodankulam Nuclear Power Plant at Idinthakarai Village, Tirunelveli District and all other citizens to move freely pending disposal of the writ petition, and thus render justice. 

Dated at Chennai this the  21^st day of March 2012

                                                                             Counsel for the petitioner