To, March 7, 2018

1. The Council of States (Rajya Sabha), New Delhi.

2. The National Human Rights Commission.
3. The Lokayukta of Delhi.
4. The Registrar, Supreme Court of India.
5. The Committee on Petitions, State Legislative Assembly of Delhi.
6. Chairman, University Grants Commission.
7. Director, National Assessment and Accreditation Council: NAAC.
8. Chairman, All India Council for Technical Education: AICTE, New Delhi.
9. Registrar, Dr. B.R. Ambedkar University, Delhi.

The petition of Naresh Kadyan, Commissioner (Headquarter), Bharat Scouts and Guides, Haryana,
C-38, Rose Apartment, Prashant Vihar, sector-14, Rohini, Delhi – 110085 along with:

1. Abhishek Kadyan, Adviser cum Consultant, Business Management – Human Resources,

Ontario in Canada.
2. Ms. Suman Malik Kadyan, Manager (Retails) at Mumbai.
3. Ms. Sukanya Kadyan Berwal, Educationalist at Ahmadabad.

Respectfully Showeth:

It is humbly submitted that:

1. The petitioner Naresh Kadyan born by Jat, Cobbler by Profession and Activist by Mission,
having Master of Arts in Journalism and Mass Communication along with Post Graduate
Diploma and Diploma in Footwear Technology and Advance Course with Distinction.
2. The petitioner is Commissioner (Headquarter), Bharat Scouts and Guides, Haryana along
with Chairman, People for Animals Haryana, 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 Kadyan Berwal along with Abhishek 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.
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.

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 death of awardees.
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.
3. Responsibilities may kindly be fixed on all concerned.
4. Any other orders deems fit.

Name of Petitioner Address Signature

Naresh Kadyan Commissioner, BSG, Haryana,
C-38, Rose Apartment,
Prashant Vihar, sector-14,
Prashant Vihar, Rohini,
Delhi – 110085.

Counter-Signature of Member presenting