IN THE HIGH COURT OF JUDICATURE FOR RAJASTHAN

AT JAIPUR BENCH, JAIPUR

S.B. CIVIL WRIT PETITION NO. ________ / 2025

Shri Om Prakash Sharma & Anr.

Versus

State of Rajasthan & ors.

PROFORMA

[Link] WRIT PETITION

The Impugned Action of Demolition By The

Respondent Department Of House No. 156,
Nataniyo Ki Haweli, Nataniyo Ka Rasta, Jaipur,
Rajasthan, In An Arbitrary Manner And In
Violation Of Principles Of Natural Justice By Not
Ensuring Any Proper Demarcation Of The
Properties; No Marking And No Re-Development
Plan, Upon Which Tenancy Rights Is Created
Thereby Causing The Extinction Of The Tenancy
Rights.
Rajasthan Municipality Act, 2009

THROUGH COUNSELS
 IN THE HIGH COURT OF JUDICATURE FOR RAJASTHAN

AT JAIPUR BENCH, JAIPUR

S.B. CIVIL WRIT PETITION NO. ________ / 2025

Shri Om Prakash Sharma & Anr.

Versus

State of Rajasthan & ors.

INDEX

S. Particulars Page
No No.
.
1. Writ Petition

2. Affidavit in support of Writ Petition

3. Stay Application

4. Affidavit in support of Stay Application

5. DOCUMENTS
:
Annexure-1: Photostat copies of the Rent
Agreement of the Petitioners along
with the Rental Receipts and also the
Order dated 19.03.2025 passed by
the Ld. Magistrate evidencing the
landlord tenant relationship of one
the Petitioner being Mr. Sumit Rawal.
Annexure-2: Photostat copy of the Notice dated
31.07.2025
Annexure-3: Photostat copy of the Receipt dated
04.08.2025 and 04.08.2025
Annexure-4: coloured photographs taken on
06.08.2025
Annexure-5 & Photostat copy of the Representation
6: Letter dated 06.08.2025 and another
being 06.08.2025 sent by the
Petitioners along with receipt
6. Affidavit in support of Documents
 ADVOCATES

[Ashwani Chobisa; Rachit Sharma; Hanumant Singh Shekhawat)

ADVOCATES

Enrolment No. R/159/1995, R/789/2019, R/4539/2021)

Mob: 9829132732

Email I.D: [Link]@[Link]

 IN THE HIGH COURT OF JUDICATURE FOR RAJASTHAN

AT JAIPUR BENCH, JAIPUR

S.B. CIVIL WRIT PETITION NO. ________ / 2025

Shri Om Prakash Sharma & Anr.

Versus

State of Rajasthan & ors.

SYNPOSIS

The present Writ Petition has been filed by the Petitioners

who are longstanding tenants lawfully occupying commercial
premises in part of House No. 156, Nataniyo ki Haweli,
Nataniyo ka Rasta, Jaipur, Rajasthan. The Petitionershave
been in continuous possession for several decades and have
regularly paid rent to the landowners under valid tenancy
arrangements.

The Petitioners are aggrieved by the arbitrary and unlawful

demolition action initiated by the Respondent Department
pursuant to a Show Cause Notice dated 31.07.2025 under
the Rajasthan Municipality Act, 2009. The said notice, neither
served to the Petitioners nor providing a meaningful
opportunity to be heard, came to their knowledge only when
demolition work had already commenced

Despite the Petitioners’ willingness, along with certain

landowners, to carry out necessary repairs as directed in the
Show Cause Notice, their efforts were obstructed by other co-
owners and the Respondent Department. Representations
and requests submitted on 04.08.2025 and 06.08.2025,
including police intervention and appeals to the Respondent
Department, went unanswered, while demolition continued in
a haphazard and unjustified manner.
The Respondent’s actions are in gross violation of the
principles of natural justice, lacking proper notice,
demarcation, transparency, or a redevelopment plan. The
demolition has resulted in the unlawful deprivation of the
Petitioners’ tenancy rights and livelihood, in violation of the
Rajasthan Municipalities Act, 2009 and constitutional
protections.

The Petition raises substantial questions of law involving due

process, protection of tenancy, and abuse of statutory power,
warranting urgent relief by this Hon’ble Court.

[Ashwani Chobisa, Rachit Sharma, Hanumant Singh

Shekhawat)

ADVOCATES

Enrolment No. R/159/1995, R/789/2019, R/4539/2021

Mob: 9829132732

Email I.D: [Link]@[Link]

IN THE HIGH COURT OF JUDICATURE FOR RAJASTHAN

AT JAIPUR BENCH, JAIPUR

 S.B. CIVIL WRIT PETITION NO._______/2025

1. Mr. Om Prakash Sharma, S/o Late Jagannath Sharma,

aged about 64 years being the owner of ‘Shree

Agencies R/o F-79, Gautam Marg, C-Scheme, Jaipur-

302001, Rajasthan.

2. Mr. Avdesh Shara S/o Shri Ashok Shara aged about 45

years being the owner of ‘AN Sales, R/o D-97, Tulsi

Marg, Bani Park, Jaipur, Rajasthan.

3. Mr. Ratan Lal Agarwal S/o Shri Ram Lal Agarwal aged

about 71 years being the owner of ‘Agarwal Tools and

Hardware’, R/o C-35, Shiv Colony, Airport Road,

Sanganer, Jaipur, Rajasthan.

4. Mr. Sumit Rawal S/o Late Shri OM Prakash Rawal aged

about 52 years being the owner of ‘OM Prakash

Narendra Kumar’ R/o 605B, 20 Dukan, Adarsh Nagar,

Jaipur, Rajasthan.

…Petitioners

Versus

1. State of Rajasthan through Principal Secretary, Local

Bodies, Local Self Government Department,

Government of Rajasthan, G-3 Rajmahal Residency

Area, Civil Lines Crossing, C-scheme.

2. Commissioner, Nagar Nigam, Jaipur Heritage, Jaipur,

Rajasthan

3. Office of Deputy Commissioner, Kishanpole Zone,

Municipal Corporation Jaipur Heritage.

4. Police Station, Kotwali, Jaipur Through SHO, Jaipur.

…Respondents

S.B. CIVIL WRIT PETITION UNDER ARTICLE

226 OF CONSTITUTION OF INDIA DIRECTED

AGAINST THE IMPUGNED ACTION OF

DEMOLITION BY THE RESPONDENT

DEPARTMENT OF HOUSE NO. 156,

NATANIYO KI HAWELI, NATANIYO KA

RASTA, JAIPUR, RAJASTHAN, IN AN

ARBITRARY MANNER AND IN VIOLATION OF

PRINCIPLES OF NATURAL JUSTICE BY NOT

ENSURING ANY PROPER DEMARCATION OF

THE PROPERTIES; NO MARKING AND NO RE-

DEVELOPMENT PLAN, UPON WHICH

TENANCY RIGHTS IS CREATED THEREBY

CAUSING THE EXTINCTION OF THE TENANCY

RIGHTS

AND

IN THE MATTER OF VIOLATION OF

PRINCIPILES OF NATURAL JUSTICE BY NOT

SERVING ANY SHOW CAUSE NOTICE

AND

IN THE MATTER OF GENERAL GUIDELINES

FRAMED BY THE HON’BLE APEX COURT

WITH REGARD TO THE PROCEDURE TO BE

 FOLLOWED BEFORE INITIATING

DEMOLITION

AND

IN THE MATTER OF ARTICLES 14, 19(1)

(G), 21 AND ARTICLE 300A OF THE

CONSTITUTION OF INDIA.

To,

The Hon’ble Chief Justice and his Lordship’s companion

Judges of the High Court of Judicature for Rajasthan at Jaipur

Bench, Jaipur.

MAY IT PLEASE YOUR LORDSHIPS:

The humble petitioners, above named, most

respectfully submit as under : -

1. That Petitioners are citizen of India resident at the

address stated herein above and thus, are competent

to invoke the extraordinary jurisdiction of this Hon'ble

Court under Article 226 of the Constitution of India.

2. That the present petition has been filed by the

petitioners who are Tenants of the small part of the

property at House No. 156, Nataniyo ki Haweli,

Nataniyo ka Rasta, Jaipur, Rajasthan by the premise’s

named as mentioned below in the tabular chart.

 TENANT SHOP NAME POSSESSED

NAME SINCE AS TENANT

Om Prakash Shree Agencies 36 years

Sharma

Avdesh Shara AN Sales 15 years

Ratan Lal Agarwal Tools 14 years

Agarwal and Hardware

Sumit Rawal Om Prakash 70 years

Narendra

Kumar

3. That the aforesaid Petitioners are engaged in the

business on the aforesaid stated premise and are in

peaceful and lawful possession from a very long period

of time. The Petitioners have regularly paid the rentals

to the landowners and duly followed the terms and

conditions mentioned as per the Rent Agreements. The

Photostat copies of the Rent Agreement of the

Petitioners along with the Rental Receipts and also the

Order dated 19.03.2025 passed by the Ld. Magistrate

evidencing the landlord tenant relationship of one the

Petitioner being Mr. Sumit Rawal are enclosed herewith

and marked as Annexure 1 (Colly)

4. That by way of the present Writ Petition the Petitioners

are challenging the Impugned action of the Respondent

Department in pursuance of which the process of

demolition has been initiated under the garb of Show

Cause Notice dated 31.07.2025 which even has not

been served to the Tenant / Occupier and which came

in the knowledge only when the demolition process has

been initiated by the Respondent Department and then

only the Officials of the Respondent Department has

handed over the said Show Cause Notice dated

31.07.2025 to the Petitioners who are Tenants. A

Photostat copy of the Notice dated 31.07.2025 is

enclosed herewith and marked as Annexure 2.

5. That from the bare perusal of the said Show Cause

Notice dated 31.07.2025 it reveals that the Respondent

Department has directed the owners as well occupiers

to either to carry out necessary repairs of the premise

which is in bad physical condition or to permit to carry

out necessary repairs of the said part within a period of

3 days failing which necessary action will be taken

under Section 194/243 of the Rajasthan Municipality

Act, 2009.

6. That now by taking the shelter of the said Show Cause

Notice dated 31.07.2025 few of the landowners are not

permitting either the remaining landowners and also

the Petitioners / Tenants to carry out necessary repairs

 so as to comply the directions of the Nigam only for the

sole purpose that upon failure of the said directions the

said building will be demolished and the Tenants will

lose their Tenancy rights upon the said subject

property.

It is pertinent to mention herein that even the

Tenant and the landowner of the Tenant who desire to

carry out the repairs as per the directions of the Nigam

have also requested the Nigam to grant the permission

to carry out necessary repairs vide Receipt dated

04.08.2025 and other Letter dated 04.08.2025 but the

Respondent Department even is not taking any

decision on the said request as a result of which now

the Demolition activities has been carried out in a

haphazard manner without following any due process of

law.

A Photostat copy of the Receipt dated 04.08.2025

and 04.08.2025 are enclosed herewith and marked as

Annexure 3 (Colly).

7. That the action of the Respondent authorities, in

proceeding with the demolition of the aforesaid

premises without ensuring any proper demarcation of

the property, without making any markings, and

without preparing or disclosing any re-development

plan, constitutes a gross violation of the principles of

natural justice. The arbitrary and opaque manner in

 which the demolition is being carried out has directly

impacted the tenancy rights of the Petitioner, which

were valid and subsisting at the time of such action.

The Petitioners were neither given any prior notice with

adequate particulars nor afforded an effective

opportunity of being heard. The complete absence of

transparency and procedural fairness in the decision-

making process has resulted in the unlawful extinction

of the Petitioner’s tenancy rights, causing irreparable

loss, hardship, and deprivation of livelihood which is

evidenced from the Photographs taken on 06.08.2025,

the coloured print out of photographs taken on

06.08.2025 are enclosed herewith and marked as

Annexure 4.

8. That the petitioners had physically appeared before the

Police Station on 05.08.2025, to allow the Tenants to

carry out the repairs. Thereafter, no heed was paid by

the Police Officials.

9. That the Petitioners had even served the representation

Letter dated 06.08.2025 before the Police station,

Kotwali to allow the Tenants to carry out necessary

repairs in order to comply with the Notice but there is

no action and even apart from the aforesaid the

Petitioners had also sent the Representation Letters

dated 06.08.2025 and 06.08.2025 has been sent to the

Respondent Department regarding the unlawful

 conduct in the form of demolition for the purpose of

extinction of Tenancy rights which can only be

terminated in accordance with law and not otherwise

and also the Notice dated 31.07.2025 which even has

not been served to the undersigned and further the

entire purpose of demolition is to achieve some ulterior

oblique motives as a result of which the Petitioners

Tenants even on account of the connivance with the

landowners are not able to carry out necessary repairs

for the purpose of protection of their Tenancy rights. A

Photostat copy of the Representation Letter dated

06.08.2025 and another being 06.08.2025 sent by the

Petitioners alongwith receipt are enclosed herewith and

marked as Annexure 5 and Annexure 6.

10. That on 06.08.2025, one of the Petitioner approached

the Respondent Department stating that he had not

received any notice issued by Department, without

issuance/giving any notice, the Respondents cannot

demolish the premise. It is pertinent to mention here

that, the Respondent Department affixed the notice

dated 05.08.2025, on the premise of the Petitioner,

which is not sustainable in the eyes of law.

11. That even the Petitioners have demanded Site

Inspection Report dated 30.07.2025 from the Officials

so in order to ensure that there is a proper demarcation

of the properties in possession of the Tenants but the

 same was not given that may inflict future litigation

regarding reinstatement of the tenant’s rights over the

subject property.

12. That the impugned Show Cause Notice dated

31.07.2025 on the basis of which the Demolition

activities has been carried from 04.08.2025 are totally

unlawful and malafide and would encourage the owners

to oust the present petitioners in whose favor the

Tenancy rights has been created since years and now

by taking the shelter of such Notices the Landowners

not enabling the Petitioners to carry out repairs which

even the Respondent Department are not giving any

permission for repair which clearly shows the conduct

of the Respondent Department.

13. That it is unclear on what basis the Respondent

Department concluded that which part of the subject

property requires demolition, which part can be

repaired and which part is in a good state either by the

occupier or owner of the premise which is huge chunk

of land and without any basis and reasoning as nothing

has been disclosed to either the owner or occupier

regarding such demolition activities and may invite

serious repercussions on the rights of the Petitioners in

future especially when there is no proper detailing of

the subject premise regarding the creation of tenancy

rights of the petitioners.

14. That thus the exercise of power by the respondent is

completely unlawful and arbitrary and source of power

is not found in Rajasthan Municipalities Act, 2009. That

thus, the Impugned action of Demolition as well as the

Show Cause Notice dated 31.07.2025 is completely

unsustainable in law and that too without even giving

opportunity of hearing to the petitioners.

15. That in these circumstances the writ petition is being

filed challenging on the following grounds:

GROUNDS

a) Because the Impugned action of Demolition as well as

the Show Cause Notice dated 31.07.2025 is ex-facie an

order without jurisdiction and deserves to be set aside.

b) Because the Impugned action of Demolition as well as

the Show Cause Notice dated 31.07.2025 has been

passed as a final order without even opportunity of

hearing provided to the petitioners. The said order

being contrary to principles of natural justice is wholly

unsustainable in law.

c) Because the impugned action of demolition undertaken

by the Respondent–Nagar Nigam is in gross violation of

the principles of natural justice, inasmuch as no proper

demarcation of the property was carried out, no

boundary markings were made, and no redevelopment

 plan was prepared or communicated to the affected

parties, including the Petitioner. The demolition was

executed in a wholly arbitrary and opaque manner,

without issuance of any clear notice or providing the

Petitioner an opportunity to be heard. Such action has

resulted in the unlawful extinction of the Petitioner’s

valid tenancy rights, which were created and protected

under law, thereby causing irreparable injury and

violating the Petitioner’s fundamental rights under

Articles 14 and 21 of the Constitution of India.

d) Because the arbitrary and unlawful demolition of the

Petitioner's premises, carried out without considering

the facts and circumstances which caused severe loss

to the Petitioner's business, including irreparable harm

to its goodwill, reputation, and livelihood. The Petitioner

was conducting lawful commercial activities from the

said premises, and the sudden and high-handed action

of the Respondent–Nagar Nigam has disrupted the

continuity of business, resulting in financial losses, loss

of clientele, and long-term damage to the Petitioner’s

standing in the market. Such action, taken without

following due process and without affording an

opportunity of hearing, violates the fundamental rights

guaranteed under Articles 14, 19(1)(g), and 21 of the

Constitution of India.
e) Because the present Impugned action of the

Respondent Department regarding warning of

Demolition is in clear violation of the general directions

passed by the Hon’ble Apex Court in the case of

WRIT PETITION (CIVIL) NO.295 OF 2022 (In Re:

Directions in the matter of demolition of

structures)

f) Because the Impugned action of Demolition as well as

the Show Cause Notice dated 31.07.2025 has been

passed by the respondent acting as an original

authority. The respondent is appellate authority under

Section 194(12) of the Rajasthan Municipalities Act,

2009. Admittedly no appeal was pending before the

respondent and there was no occasion to pass such an

order which is wholly without jurisdiction and deserves

to be set aside.

g) Because the Impugned action of Demolition as well as

the Show Cause Notice dated 31.07.2025 has been

passed an administrative side without full facts of the

case being before the respondent. The said order has

been passed without any material. The petitioners have

admittedly applied for regularisation of the building

plans of the building as constructed. Pending such

application no coercive order for seizure/sealing could

have been passed by the respondent.

 h) Because the order of seizure/sealing is a quasi judicial

order. As authority required to act as quasi judicial

authority municipality in this case cannot act under

dictation. However in this case the respondent has

directed Nagar Parshad Beawar to seize/seal the

premises. Such direction amounting to dictation and

could not have been given and therefore the impugned

order is bad in law.

i) Because the Petitioners are Tenants and such an action

would jeopardise the interest of the Tenants.

j) Because the order has been passed arbitrarily and

without even giving opportunity of hearing to the

petitioners.

k) Because other grounds would be urged at the time of

arguments of the case.

16. That the petitioners have no efficacious alternate

remedy and are left with no option but to approach the

Hon’ble Court in the exercise of its extraordinary

jurisdiction under Article 227 of Constitution of India as

reiterated as above.

PRAYER

It is, therefore, most respectfully prayed that this

Hon'ble Court be pleased to allow this writ petition and

further be pleased to -
 (i) By an appropriate writ, order or direction, quash and

set aside the Impugned action of Demolition on the

aforesaid premise including the aforesaid Show

Cause Notice dated 31.07.2025, 05.08.2025 quo the

Petitioners and / or in alternate to allow the

Petitioners for carrying out necessary repairs on the

rented premises subject to the complete satisfaction

of the Respondent department;

(ii) To direct the Respondent Department for carrying

out Proper Site Inspection report, Technical

Feasibility having proper demarcation and marking

of the rented premise so even if there is total

demolition then also the rights of the Petitioners may

be reinstated;

(iii) To frame necessary guidelines, policies and SOP’s for

the Authority before initiating any activity under

section 243 of the Rajasthan Municipality Act, 2009,

in light of judgment passed by Hon’ble Apex Court in

Writ Petition Civil no. 295 of 2022, having citation

2024 SCC OnLine SC 3291, on 13.11.2024.

(iv) Any other order which this Hon'ble Court deems just

and proper in the facts and circumstances of the

case.

HUMBLE PETITIONERS

THROUGH COUNSEL

PLACE: JAIPUR
DATE: 06.08.2025

[Ashwani Chobisa; Rachit Sharma; Hanumant Singh Shekhawat)

ADVOCATES

Enrolment No. R/159/1995, R/789/2019, R/4539/2021)

Mob: 9829132732

Email I.D: [Link]@[Link]

Notes :

1. This is S.B. Civil Writ Petition. No such writ petition

has been filed either before this court or before the

Hon’ble Supreme Court prior to it.

2. A copy of the same has been given to public

prosecutor.

3. P.F. notices and extra copies will be filed as soon as

it is ordered.

4. It has not been typed by any staff member of this

Hon’ble Court.

5. No vires of any Act or Rules is under challenge.

6. Since pie papers are not available hence typed on

stout paper.

ADVOCATES
 IN THE HIGH COURT OF JUDICATURE FOR RAJASTHAN

AT JAIPUR BENCH, JAIPUR

S.B. CIVIL WRIT PETITION NO. ________ / 2025

Shri Om Praksh Sharma & Anr.

Versus

State of Rajasthan & ors.

AFFIDAVIT IN SUPPORT OF WRIT PETITION

I, Om Prakash Sharma, S/o Late Jagannath Sharma, aged

about 64 years being the owner of ‘Shree Agencies R/o F-79,

Gautam Marg, C-Scheme, Jaipur-302001, Rajasthan, do

hereby take oath and state as under:

1. That I am the petitioner no. 1 in the above noted writ

petition and am, therefore, well conversant with the

facts and circumstances of the case.

2. That the writ petition has been drafted by my counsel

in my presence and under my instructions.

3. That the factual contents of the writ petition are true

and correct to the best of my knowledge and legal

averments made in the writ petition are based on the

legal advice tendered to me by my counsel, which I also

believe to be true and correct.

DEPONENT
 VERIFICATION

I, the above named deponent do hereby take oath and

verify that the contents of Para Nos. 1 to 3 of my above

affidavit are true and correct to the best of my personal

knowledge. Nothing has been concealed and no part of it is

false. So help me GOD.

DEPONENT
IN THE HIGH COURT OF JUDICATURE FOR RAJASTHAN

AT JAIPUR BENCH, JAIPUR

S.B. CIVIL MISC. STAY APPLICATION NO.________ /2025

IN

S.B. CIVIL WRIT PETITION NO. ________ / 2025

1. Mr. Om Prakash Sharma, S/o Late Jagannath Sharma,

aged about 64 years being the owner of ‘Shree

Agencies R/o F-79, Gautam Marg, C-Scheme, Jaipur-

302001, Rajasthan.

2. Mr. Avdesh Shara S/o Shri Ashok Shara aged about 45

years being the owner of ‘AN Sales, R/o D-97, Tulsi

Marg, Bani Park, Jaipur, Rajasthan.

3. Mr. Ratan Lal Agarwal S/o Shri Ram Lal Agarwal aged

about 71 years being the owner of ‘Agarwal Tools and

Hardware’, R/o C-35, Shiv Colony, Airport Road,

Sanganer, Jaipur, Rajasthan.

4. Mr. Sumit Rawal S/o Late Shri OM Prakash Rawal aged

about 52 years being the owner of ‘OM Prakash

Narendra Kumar’ R/o 605B, 20 Dukan, Adarsh Nagar,

Jaipur, Rajasthan

…Petitioners

Versus

1. State of Rajasthan through Principal Secretary, Local

Bodies, Local self Government Department,

Government of Rajasthan, G-3 Rajmahal Residency

Area, Civil Lines Crossing, C-scheme.

 2. Commissioner, Nagar Nigam, Jaipur Heritage, Jaipur,

Rajasthan

3. Office of Deputy Commissioner, Kishanpole Zone,

Municipal Corporation Jaipur Heritage.

4. Police Station, Kotwali, Jaipur Through SHO, Jaipur.

S.B. CIVIL MISC. STAY APPLICATION UNDER

ARTICLE 226 OF THE CONSTITUTION OF INDIA

To,

The Hon’ble Chief Justice and his Lordship’s companion

Judges of the High Court of Judicature for Rajasthan at Jaipur

Bench, Jaipur.

MAY IT PLEASE YOUR LORDSHIPS:

The humble petitioners-applicants, above named, most

respectfully beg to submit as under:

1. That the Petitioners have preferred the accompanying

Writ Petition under Article 226 of the Constitution of

India, challenging the arbitrary and illegal

demolition action carried out by the Respondent–Nagar

Nigam and the impugned Show Cause Notice dated

31.07.2025 and 05.08.2025. which was never served

upon the Petitioners prior to the initiation of demolition.

2. That the Petitioners are long-standing lawful tenants in

the premises situated at House No. 156, Nataniyo Ki

 Haveli, Nataniyo Ka Rasta, Jaipur, Rajasthan, and have

been in peaceful possession and regularly paying rent

to the respective landowners.

3. That the entire demolition action has been carried out

in gross violation of the principles of natural justice,

without any due process, without proper demarcation

of the properties, and without serving any valid notice

to the Petitioners–Tenants.

4. That the Respondents, in collusion with certain

landowners, are attempting to forcibly oust the

Petitioners from their long-standing tenancy under

the pretext of structural danger, without offering any

re-development plan, rehabilitation, or alternate

accommodation, and without deciding and further

neither the Respondent Department nor the land owner

are not giving any permission or not allowing to carry

out the necessary repairs on the premise.

5. That the continued demolition activity is causing

irreparable harm, including loss of tenancy rights, loss

of livelihood, and destruction of business goodwill, and

is leading to civil consequences of a grave and

irreversible nature, which cannot be compensated in

monetary terms.

6. That unless the Hon’ble Court intervenes urgently, the

Petitioners shall suffer irreparable injury, and the entire

 building including tenanted portions shall be

demolished.

PRAYER

In view of the facts and circumstances stated above, it is

most respectfully prayed that this Hon’ble Court may be

pleased to:

A. To pass an interim order restraining the Respondents,

and their representatives from carrying out any further

demolition activity arising out of the Notice dated

31.07.2025 and 05.08.2025 in respect of the property

bearing House No. 156, Nataniyo Ki Haveli, Nataniyo Ka

Rasta, Jaipur, particularly the tenanted portions in

possession of the Petitioners, until final adjudication of

the Writ Petition;

B. In the meantime, to allow the Petitioners for carrying

out necessary repairs in the presence of either the

Authority or the Police to the satisfaction of the

Respondent Department.

C. To direct the Respondents to maintain status quo with

respect to the structure and possession of the tenanted

premises.

D. Pass such other or further orders as this Hon’ble Court

may deem fit and proper in the interest of justice.

 [Ashwani Chobisa, Rachit Sharma, Hanumant Singh

Shekhawat)

ADVOCATES

Enrolment No. R/159/1995, R/789/2019, R/4539/2021

Mob: 9829132732

Email I.D: [Link]@[Link]

PLACE: JAIPUR

DATE:

NOTES :

1. No such stay application has been filed either before

this court or before the Hon’ble Supreme Court prior to
it.
2. P.F. & Notices and extra-sets shall be filed within the
prescribed period.
3. This has not been typed by any staff member of this
Hon’ble Court.
4. Since pie papers are not readily available the same is
typed on stout papers.

ADVOCATES
 IN THE HIGH COURT OF JUDICATURE FOR

RAJASTHANAT JAIPUR BENCH, JAIPUR

S.B. CIVIL MISC. STAY APPLICATION NO.________ /2025

IN

S.B. CIVIL WRIT PETITION NO. ________ / 2025

Shri Om Prakash Sharma & Anr.

Versus

State of Rajasthan & ors.

AFFIDAVIT IN SUPPORT OF STAY APPLICATION

I, Om Prakash Sharma, S/o Late Jagannath Sharma, being

the owner of ‘Shree Agencies R/o F-79, Gautam Marg, C-

Scheme, Jaipur-302001, Rajasthan, do hereby take oath and

state as under:

1. That I am the petitioner-applicant no.1 in the above

noted writ petition and am, therefore, well conversant

with the facts and circumstances of the case.

2. That the stay application has been drafted by my

counsel in my presence and under my instructions.

3. That the factual contents of the stay application are true

and correct to the best of my knowledge and legal

averments made in the stay application are based on the

legal advice tendered to me by my counsel, which I also

believe to be true and correct.

DEPONENT
 VERIFICATION

I, the above named deponent do hereby take oath and

verify that the contents of Para Nos. 1 to 3 of my above

affidavit are true and correct to the best of my personal

knowledge. Nothing has been concealed and no part of it is

false. So help me GOD.

DEPONENT
 IN THE HIGH COURT OF JUDICATURE FOR RAJASTHAN

AT JAIPUR BENCH, JAIPUR

S.B. CIVIL WRIT PETITION NO. ________ / 2025

Shri Om Prakash Sharma & Anr.

Versus

State of Rajasthan & ors.

AFFIDAVIT IN SUPPORT OF DOCUMENTS

I, Om Prakash Sharma, S/o Late Jagannath Sharma,

being the owner of ‘Shree Agencies R/o F-79, Gautam Marg,

C-Scheme, Jaipur-302001, Rajasthan, do hereby take oath

and state as under:

1. That I am the petitioner-applicant no. 1 in the above

noted writ petition and am, therefore, well conversant

with the facts and circumstances of the case.

2. That the documents Annexure-1 to Annexure-6

(except Annexure-4), are the true and exact copy of

their original, and Annexure-4, is the coloured print

out of the photographs.

DEPONENT
 VERIFICATION

I, the above named deponent do hereby take oath and

verify that the contents of Para Nos. 1 to 2 of my above

affidavit are true and correct to the best of my personal

knowledge. Nothing has been concealed and no part of it is

false. So help me GOD.

DEPONENT