PIL against Team Anna alleges foreign funding behind agitation

W.P.(C) 3412/2012


Through In person.

….. Petitioner

….. Respondent

Through Mr. A.S. Chandhiok, ASG with Mr. Sumeet Pushkarna, Mr.
Ritesh Kumar, Mr. Siddharth Tyagi, Advocates for UOI.






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.



MAY 30, 2012/

(Under art.226 of constitution of India)


Civil writ petition No.
of 2012


Manohar Lal Sharma Advocate


Supreme court of India

New Delhi-01


1. Union of India

Through secretary

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
Nagar, Delhi-92

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
Noida -201301

8. Shanti Bhushan Advocate
B-16 ,Sector 14
Noida -201301

Writ Petition under art 226 of constitution of India.
read with the foreign contribution (regulation) Act ,1976.




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.


c. Petitioner say and submits that present petition is
confined to the respondents only and no other
person / body / institutions are likely to be effected
by the order sought in the writ petition.


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;-

a. Whether foreign sponsored movement / anti-
government graft agitation is permitted under
constitution of India?
b. Whether violation of foreign contribution
(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.

a. FF used to setup a group namely “Civil society’ in
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.
b. As per various reports published in USA It is already
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:-

a. Rs 86,61,742.
b. Rs 2,37,035.
c. Rs 3,70,000
d. Rs 19,61,968
e. Rs 15,00,000
f. Rs 7,86,500
g. Rs 12,52,742
h. Rs 11,35,857

Ford Foundation

Manjunath Shanmugam Trust
Dutch Embassy

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.

a. In October 2010 Team Anna’s core member Prashant
Bhushan Advocate and Shanti Bhushan Advocate
declared in media that every 4th Justice of the
supreme court are corrupt.
b. Upon contempt notice by the Supreme Court
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.

a. It is pertaining to say that FF has already launched
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


a. Because no citizen is allowed to have any foreign
contribution/fund without pre-permission of the
Respondent U.O.I. within the provision of FCRA.


Violation of it is an offence liable to be penalized for
3 year imprisonments couple with fine.
b. Because constitution of India does not allow any
foreign sponsored agitation, in any manner in the
country. Respondents’ no.3 to 8 have no
constitutional right to run foreign sponsored agitation
in India even Art.19(1) of the constitution of India
does not provide such rights.
c.Because respondent’s action, for permitting
impugned said foreign funding as well as sponsored
agitation in India, is a serious breach of
constitutional and FCRA provisions. Therefore
Petitioner is entitled for the relief as prayed for.
d. Because admission and declaration in press is an
extra judicial confession and is admitted facts for
receiving funds from foreign companies to run above
said anti government graft movement. It is an
offence under FCRA and punishable for imprisonment
with fine. Respondent’s action permitting said
agitation is an serious violation of constitution and
FCRA provisions.
e. Because, knowingly and deliberately, respondent
remain failure to prohibit & taking action against the
Respondent no.2 to 8 and their associates under
FCRA act and other law due to above said foreign
sponsored agitation/ movement in India.
f. Because collecting of man for lowering reputation of
the government is also an offence under IPC.


g. Because respondent is duty bound to follow
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.
h. Because respondent U.O.I. is duty bound to follow
FCRA and conduct an C.B.I. investigation against
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.
i. Because respondent U.O.I. is duty bound to comply
FCRA,1976 and must conduct investigation and
prosecution. They must prohibit foreign sponsored
anti govt. agitation in the country. It is a clear case
of violation of FCRA,1976.
j. Because offence and activities has seriously
damaged National securities and prestige. Therefore
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
Hon’ble court

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 &
illegal. And

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.


New Delhi

Date: 21.5.2012
Manohar Lal Sharma Advocate

One comment

  1. Dear Sir,

    I have always liked your views on “Jan Lokpal Bill” and its quite obvious that this whole agiation has been to destabilise this country and very well planned.

    What has happened in Libia , Egypt something similar is being experimented here , I’m no expert but I strongly feel its to bring the oligarchy system.

    Yes corruption is a problem , but to tackle this problem “Is killing the democracy” the solution. If someone says yes then that person is an extremist. !

    My question to the media is why no one is pinpointing the dangerous situation this country will be in if this “Jan Lokpal Bill” is passed. Its too powerful to be given to a handful of people. And according to me its called “Dictatorship” !
    Why no one in the media has done a research on background of Mr Hazare.

    Whats happening in this country is highly sad and I urge all the people to atleast read and understand of preposterous this bill is and also never to follow anyone blindly.



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