IN THE HIGH COURT OF DELHI AT NEW DELHI
MANOHAR LAL SHARMA
Through In person.
UNION OF INDIA AND ORS
HON’BLE THE ACTING CHIEF JUSTICE
HON’BLE MR. JUSTICERAJIV SAHAl ENDLAW
The prayer made in this petition shall be examined by the
respondent no.1 and suitable decision shall be taken thereupon.
Writ petition stands disposed of.
Status Report be filed within three months.
ACTING CHIEF JUSTICE
RAJIV SAHAI ENDLAW, J
MAY 30, 2012/
IN THE HIGH COURT OF DELHI AT New Delhi
(EXTRA ORDINARY WRIT JURISDICTION)
(Under art.226 of constitution of India)
Civil writ petition No.
IN THE MATTER OF A PUBLIC INTEREST LITIGATION
Manohar Lal Sharma Advocate
Supreme court of India
1. Union of India
Ministry of Home Affairs
North Block, New Delhi
2. Ford foundation
Through Regional Director
320East, 43rd street
New York. N.Y. 10017 USA
55, Lodhi Estate, New Delhi-03
3. Kishan Baburao Hazare @ Anna Hazare
Resi. Village Ralegan Siddhi , Tal Pamer
Distt. Ahmed Nagar, Maharastra.
4. Manish Sisodia
Kabir, E-109, Pandav
5. Arvind kejriwal
Parivartaan , L 403 , Girnar ,
Kaushambi, Gaziabad (.U.P.)
6. Mrs. Kiran Bedi
56 Uday Park, New pelhi – 110049
7. Prashant Bhushan Advocate
B-16 ,Sector 14
8. Shanti Bhushan Advocate
B-16 ,Sector 14
Writ Petition under art 226 of constitution of India.
read with the foreign contribution (regulation) Act ,1976.
THE HON’BLE CHIEF JUSTICE
OF· DELHI HIGH COURT AND HIS
COMPANTION HON’BLE JUSTICES
OF THE HIGH COURT.
THE HUMBLE PETITIONER ABOVE NAMED MOST
1. That Petitioner has no personal interest in the litigation
and the petition is not guided by self gain of any other
person/institution/ body and there is no motive other than
of public interest in filing the writ petition.
a. Sources of knowledge as to the facts alleged in the
writ petition are based upon statements & disclosure
by the respondents in their own website as well as
in press conference held by them as are mentioned
in the present writ petition herein below.
b. Petition is being filed on behalf of the all citizen of
India who relied constitutional systems but are
unable to come forward for justice/action against the
foreign sponsored anti-government graft-agitation
being supported by the U.O.I. contra to the FCRA,
1976 and constitution.
2. That Petitioner is an advocate having his regular practice. in
the Supreme Court of India and in the High courts.
Petitioner has the means to pay the cost, if any, imposed
by the court.
3. That Petitioner has filed his complaint dt.20.8.2011 to the
respondent no.1 but did not find any action upon it till
4. That the petitioner has not filed any other PIL / letter
petitions before this Hon’ble court for the relief prayed
5. That Petitioner is filing the present petition also to decide
following constitutional question of law;-
government graft agitation is permitted under
constitution of India?
(regulation) Act, 1976 is not an offence?
6. That during 2005 to 2011 contra to the FCRA, 1976
respondent (U.O.I.) allowed/ supported Team Anna’s
agitations, sponsored by the foreign companies, which has
finally resulted lowering the prestige and reputation of the
Parliament of India.
7. That Respondent no.2 is an American trust having its office
at above address in India and is a foreign company, having
its several offices in all over world including in India, has
funded & promoted impugned anti-govt agitation for
imposing their charter namely Lokpal bill in India.
various countries such as in Russia, Israel, Africa etc.
etc. They used to fund them to collect intellectual
class of persons, i.e. media journalist, artist,
Industrialist, leaders etc., for running anti
government agitations raising sweet slogan i.e. anti-
corruption movement to impose their charter to
establish their political and business interest.
established true well known facts that FF is also a
front of CIA (central inelegancy of America) and its
main object/function is to protect/establish
American interest/charters in the various countries.
8. Respondent no.3 to 8 are citizens of India & reside at
above address. R-3 is an uneducated driver, who due to
injury took voluntary retirement from military. On the
behest of FF he formed a group ‘Civil Society’ in India
having R-4 to 8 as his core members and front runner of
the impugned anti-govt. agitation to impose FF’s charter
/framed Lokpal Bill in India.
9. That said civil society @ Team Anna, jointly and severally,
has been receiving funds from Ford foundation and other
foreign companies/ organizations for running their anti-
government graft movement.
10. That civil society @ Team Anna, jointly and severally, has
been running their anti-government graft movement being
sponsored by FF and other foreign companies to establish
FF’s charter via sponsored electronic media creating false
propaganda for lowering Indian parliament & defaming
entire constitutional & Judicial structure as corrupt.
11. On 23.8.2011, in an interview to the Beyond Headlines,
civil society@ Team Anna admitted/ declared for receiving
funds from foreign companies for running their said anti-
govt. agitation as bulk SMSs, distributing t-shirts, caps,
flags and other means. They admitted to receive fund from
the foreign organization & sources as follow:-
Manjunath Shanmugam Trust
Association for India’s
India’s friends Association
United Nationals Development Prog
From individual in 2007-10.
True copy of the Beyond Headlines report
dated 23.8.11 is being filed as Annexure P-l
12. That FF’s regional director also admitted to provide
funding to Team Anna’s member “KABIR”, NGO running
jointly by Manish Sisodia and Arvind Kejriwal, since 2005.
FF’s website also disclose to provide FF’s fund US $
2,00,000 to team Anna, Kabir NGO during 2011. True
copy of the ford foundation’s website of 2011 year is being
exhibited as Annexure P-2.
13. That FCRA 1976 made mandatory to seek permission via
form “c” in advance for taking /giving any foreign fund and
to spent it accordingly. Receiver cannot change it
consumption even his banker’s branch. Violation of it is an
offence under FCRA, 1976 for 3 years imprisonment with
14. That Respondent no 2 to 8 have not secured any such
permission for securing funds from foreign companies and
to spend it in the said anti govt. agitation for imposing
Lokpal Bill in India within the ambit of FF & USA.
15. That respondent, U.O.I., despite having knowledge about
this scenario, did not take any action in accordance with
FCRA,1976 till date and supported their anti govt.
agitation in all manner which ultimately in August 2011
lowered reputation of the parliament by admitting their
direction for processing their demands of Lokpal Bill as
sponsored by FF within the charter of the USA & FF.
16. In addition of above team Anna has also declared in
press specially to ‘The times of India’ that they had spent
more than RS.1.5 crores upon one of their protest in
August 2011 agitated at RamLeela ground, New Delhi,
compelling government to impose their Lokpal Bill. Details
of the expenses has been classified as follow;-
a. Rs. 52 lakhs in Public meetings
b. Rs. 26 lakhs in printing of pamphlets
c. Rs. 9.8 lakhs for traveling and conveyance.
d. Rs. 45 lakhs in sending over 30 crores SMSes.
Total Rs. 1.25 crores.
True typed copy of the times of India report dt.
1.11.2011 is being filed as Annexure P-3
17. That Team Anna admitted/ declared for spending above
said fund in agitation for demanding to impose only their
own version of the Lokpal Bill and has launched impugned
FF’s sponsored agitation to compel lowering Indian
constitutional authorities. They did not hesitate even to
declare that Indian Judiciary as a most corrupt institution.
Bhushan Advocate and Shanti Bhushan Advocate
declared in media that every 4th Justice of the
supreme court are corrupt.
Mr.Shanti Bhusha Advocate again declared that out of
18 CJI, 16 CJI are corrupt. However they are now
facing contempt of court proceeding in the Supreme
Court for their Action.
18. That on 5.4.2011 Team Anna launched their said anti-
graft agitation at Janter Manter New Delhi demanding to
have a draft committee, including them also as a chairman
and member therein, to draft/prepare a Lokpal Bill.
Within three days U.O.I. admitted their demand, issued
exclusively one notification dt. 8.4.2011 without having
sanction/permission of the president of India. This draft
committee run till Jun end 2011.
19. That on August 2011 they again launched their 2nd stage
of their anti-govt agitation at RamLeela ground, New Delhi,
compelling government to pass only their Lokpal Bill in the
parliament. Respondent U.O.I., knowingly under their
planned understanding, arrested Anna Hazare for a day
which gave him mass support against his arrest action
publicized him all over India.
20. That contra to the existing constitutional systems
respondent U.O.I. agreed to put their Bill in the house.
Respondent U.O.I.’s action, for accepting to impose foreign
sponsored Lokpal Bill, ultimately lowered prestige and
reputation of the Parliament in all over world.
successfully similar civil society anti-graft agitation in
Russia in 1985-90 which has finally resulted 17
division of Russia and has destroyed entire country.
21. That impugned foreign sponsored anti-government
movement is still continued and respondent U.O.I. has
been supporting their anti-govt. graft movement.
22. That not only foreign fund is behind said agitation but one
of the electronic media, being sponsored by FF & others,
also played a serious role in publicizing their agitation
regularly without disclosing their interest and having any
permission from the Respondent under FCRA,1976 which is
also a subject matter of CBI investigation prior of further
23. That Petitioner is filing the present petition on the
following amongst other
contribution/fund without pre-permission of the
Respondent U.O.I. within the provision of FCRA.
3 year imprisonments couple with fine.
constitutional and FCRA provisions equally upon all in
the country. Therefore under any circumstances
impugned action cannot be permitted fallow by the
respondent either within FCRA or constitution of
India. Therefore also Petitioner is entitled for the
relief s prayed for.
Respondent nO.2 to 8 and their associates who has
been conducting foreign sponsored agitation in the
country. In the interest of general public and
national security there must be a proper C.B.I.
investigation in the scenario for further prosecution
of the accused persons under FCRA, 1976 & others.
prosecution. They must prohibit foreign sponsored
anti govt. agitation in the country. It is a clear case
of violation of FCRA,1976.
CBr investigation must be within the supervision of
this Hon’ble High court in the interest of justice.
24. That Petitioner has not filed any other writ petition before
this Hon’ble High court for the relief prayed herein.
Therefore within the aforesaid facts and circumstances in the
interest of citizen of India for justice, equity and fair play this
1. Be pleased to declare foreign sponsored agitation as illegal,
unconstitutional and an offence under FCRA,1976 & Others
2. Be pleased to declare respondent’s action, allowing
impugned foreign sponsored agitation, as unconstitutional &
3. Be pleased to restrain respondent, U.O.I. allowing any
foreign sponsored agitation in India being as contra to the
FCRA1976 and constitution of India. AND
4. Be pleased to direct respondent U.O.I. to conduct an C.B.I.
Investigation against Respondent no.2 to 8 and others and
to file their report before this Hon’ble court for direction &
conducting prosecution of Team Anna and others under
FCRA,1976 & others.
5. Be pleased to provide cost to the Petitioner. AND
6. Pass such other order or further orders, as this Hon’ble court
may deem fit and proper under the facts and circumstances
of the case.
Manohar Lal Sharma Advocate
IN – PEERSON