Prayers:

a) This Hon’ble Court be pleased to issue a writ of mandamus or a writ in the nature of mandamus or any other writ or order under Article 226 of the Constitution of India for setting aside the guidelines issued by the Home Secretary Government of India and Chief Secretary West Bengal dated 12.04.2020, 15.01.2022, 24.04.2020, 29.06.2021, regarding wearing face mask in public on the ground till date as admitted by the Ministry of Health and Family Welfare, Govt. of India that no study conducted by the concerned department or by any research institute to establish the effectiveness of face mask in preventing infection.

b) This Hon’ble Court be pleased to issue a writ of mandamus or a writ in the nature of mandamus or any other writ or order under Article 226 of the Constitution of India for setting aside the or der regarding wearing face mask in public on the ground that W.H.O. in his different reports stated that there is no evidence to show that face mask prevents Covid, on the contrary the report states that the mask causes serious health hazard to the people having no symptoms.

c) This Hon’ble Court be pleased to issue a writ of mandamus or a writ in the nature of mandamus or any other writ or order under Article 226 of the Constitution of India for setting aside the orders regarding wearing face mask in public on the ground of Potential headache and/or breathing difficulties etc.

d) This Hon’ble Court be pleased to issue a writ of mandamus or a writ in the nature of mandamus or any other writ or order under Article 226 of the Constitution of India for setting aside the orders regarding wearing face mask in public on the ground police indiscriminately arresting people wrongly invoking provision of Disaster Management Act and Indian Penal Code.

e) This Hon’ble Court be pleased to issue a writ of mandamus or a writ in the nature of mandamus or any other writ or order under Article 226 of the Constitution of India for setting aside the orders regarding wearing face mask in public on the ground every citizen has right to free movement under Article 19 of the Constitution and no person shall be deprived of his life or personal liberty except according to procedure established by law.

f) This Hon’ble Court be pleased to issue a writ of mandamus or a writ in the nature of mandamus or any other writ or order under Article 226 of the Constitution of India for setting aside the orders regarding wearing face mask in public on the ground judicial review is permissible on account of manifest arbitrariness as executive authorities are operating without medical and scientific opinion.

g) This Hon’ble Court be pleased to issue a writ of mandamus or a writ in the nature of mandamus or any other writ or order under Article 226 of the Constitution of India for setting aside the orders regarding wearing face mask in public on the ground that a public health emergency does not give executive authorities carte blanche to disregard the constitution for as long as the medical problem persists.

h) A declaration that the order of compulsory vaccination for entering into park, restaurant, gym, salon etc. is unconstitutional;

i) A declaration that the order one should get vaccinated for entering into park, restaurant, gym salon etc. is unsustainable;

j) A declaration that the order dated 12.04.2020, 24.04.2020, 15.01.2022, 28.08.2021 is bad in law and unconstitutional as the said orders are not backed by any medical evidence arising out of serious research work by the experts in the field;

k) To issue a writ in the nature of certiorari calling upon the concerned respondents to certify and transmit the records of the case before this Hon’ble Court so that conscienceless justice by passing the appropriate order;

l) Rule NISI in the terms of prayers a), b), c) d), e),f), g), h), i);

m) To pass ad-interim order of injunction restraining the respondents and their men and agents to carry out the orders till the disposal of the present case;

n) To pass interim injunction in terms of prayer k);

o) Make Rule absolute if no cause or insufficient cause is shown;

p) To issue any other suitable writ/writs/order/Orders/ direction/ directions which this Hon’ble Court may deem fit and proper;

q) Cost and incidentals to the petitioner;

Download here