IN THE HIGH COURT OF JHARKHAND, AT RANCHI
                     (CIVIL WRIT JURISDICTION)
I.A. No. ----- /2012
IN
W.P. (PIL) No. 2347/2012

                                                                           IN THE MATTER OF; 
                                                                               An interlocutory application for impleading the interveners as co-petitioners for bringing on record certain relevant facts for just decision in this case; 
       AND
                                                                                     IN THE MATTER OF;

Bar Association of Jharkhand………………………………Petitioner
                                                          Vs
State of Jharkhand and others………………………………Respondents
And
1.	Abhinav Prakash S/O Dr. Kailash Singh
2.	Abhishek Chaube S/O Shri Lalit Prakash Chaubey
3.	Aditi Singh D/O Shri Deepak Singh
4.	Ashish Abhijit S/O Shri N. N. Pandey
5.	Riddhi. M. D’souza D/O Dr. George D’souza
6.	Saurav Bhaumik S/O Shri R. K. Bhaumik

And

All are the Students of and residents of National University of Study and Research in Law, Ranchi, BIT Polytecnic Campus, Mesra, P.O- Mesra, P.S- Ormanjhi, District- Ranchi, Jharkhand.

Most respectfully sheweth:
1.	That by this interlocutory application, the intervener petitioners pray to be impleaded as co-petitioners for bringing  on record certain relevant facts for the kind consideration of this Hon’ble Court so that complete justice can be done in this instant case to all the parties concerned.
2.	That the intervener petitioners had not moved any such interlocutory application for the self- same relief earlier made in this application for impleading them as parties.
3.	That the intervener petitioners are citizens of India and are the members of Center for Legal Aid Programme (hereinafter CLAP), National University of Study and Research in Law, Ranchi (hereinafter, NUSRL, Ranchi) an unregistered society, consisting of bona-fide students and faculty members of NUSRL,Ranchi.
4.	That CLAP was established under the patronage of the Hon’ble Vice Chancellor of NUSRL, Ranchi in February 2011 with an aim to serve as an effective medium for voicing the concerns of the downtrodden and  the poor sections of society and to find a feasible solution to their problems through the medium of law. That since its very inception, CLAP had intermittently drafted proposals, offered meaningful suggestions and has come up with alternative approaches of tackling the constraints in the system.  Moreover, it has acted as a pillar of support for the common man who fails to get his grievances heard and knock the doors of justice due to innumerable constraints.
5.	That it is most humbly submitted that CLAP has been playing a very active role in the social domain and some of its past activities and initiatives taken in this regard are provided hereunder for the kind attention of this Hon’ble Court. 
6.	That an informative interactive campaign named ‘SOOCHNA-11’ was launched in a village named Panchauli (on the outskirts of BIT, Mesra, Ranchi) on 1st June, 2011 stressing on the importance of issues related to RTI, Land Disputes, Family Law and Criminal Law.
7.	That it also organized a series of informal talks with prominent politicians of national repute under a programme named “Meet your Lawmaker” which was attended by the politicians and the bureaucrats of repute and aimed at showcasing the deeper misunderstood realities of administrative and political set up. 
8.	That CLAP invited participants from law colleges across the state of Jharkhand to form an intra-state network of Legal Aid Societies within Law Universities and Colleges of Jharkhand for developing a better co-ordination among them in reaching out to the people in dire need of free quality legal services, at a seminar on “Scope of Legal Aid in Jharkhand” organized by CLAP. That it is most respectfully submitted that most recently CLAP has organized various Legal Aid camps in Tenughat, Tamar and Giridih on 4th, 9th and 25th August, 2012 respectively.

9.	That it is most respectfully submitted that, the student body of NUSRL, Ranchi in general and the members of CLAP in particular are going to be substantially affected by the decision of this Hon’ble Court in this ongoing public interest litigation, therefore, they most humbly pray themselves to be impleaded as co-petitioners so that they can bring on record their concerns with respect to the subject matter under consideration before this Hon’ble Court.  
10.	That the intervener petitioners most humbly submit that the details of the problems being faced by NUSRL, Ranchi on the account of inaction and lacklustre attitude of the concerned respondents has properly been brought to the kind attention of this Hon’ble Court in the main writ petition filed by the petitioner “Bar Association Jharkhand High Court, Doranda, Ranchi”, therefore, for the sake of brevity the intervener petitioners shall not be repeating those facts here in this interlocutory application.
11.	That the intervener petitioners shall be confining this interlocutory application to present their humble submissions in response to the distortion of facts in a malicious and mischievous manner made in various newspapers and media by certain vested interests and politically motivated persons, as this Hon’ble Court itself noted in its Order No. 5 passed in this Writ Petition (PIL) No. 2347 of 2012. 
12.	That it is most humbly submitted that it appears that some fallacious arguments are being presented before this Hon’ble Court with an intention of misleading  people  against the proposed construction of NUSRL, Ranchi campus on the ground that; these lands are fertile and since the majority of the concerned villagers are illiterate, and their sole occupation is cultivation, therefore, if their land is taken away from them for the construction of the campus of NUSRL, Ranchi they will have no means of livelihood left with them.

13.	That it is most humbly submitted that it is being falsely presented before this Hon’ble Court that the past acquisition of land and its subsequent allotment of land in question to NUSRL, Ranchi is against the human rights of concerned villagers, arbitrary, malicious and illegal exercise of power by the state. 
14.	That it is most humbly submitted that the past acquisition of land in question and the subsequent allotment thereof to NUSRL, Ranchi is not violating the human rights of aggrieved parties and it is not an arbitrary, malicious and illegal exercise of power by state. That it is most humbly submitted that the state action of acquiring land and the further allotment of land to NUSRL, Ranchi rather than being violative of human rights of the affected villagers, is actually in the best interests of the affected villagers.  

15.	That it is further submitted that the past acquisition of land and the further allotment of the land to NUSRL, Ranchi for the purpose of establishment of NUSRL, Ranchi is a just and proper exercise of power by the state authorities. That it is further submitted that it is the bounden duty of the state to promote and establish institutions of excellence for the wholesome development of the newly created state of Jharkhand. 

16.	That it is humbly submitted that the Hon’ble Vidhan Sabha of Jharkhand felt the need for the establishment of a Law University “for the purpose of advancement of cause of learning, teaching, and research and dissemination of knowledge in the field of law, legal capacity building of appropriate state and non-state institutions, strengthening the system of delivery of legal services, specialization in reasonably relevant techno development clusters of knowledge (like mines and minerals, environment, IT, Biotechnology etc) and contribution to public policy development in the use of law in governance as also to cater to the needs of the society by the development  as also to cater the needs of the society by developing professional skills of persons intending to take up advocacy, judicial services, law officers/managers and legislative drafting as their profession and matters incidental thereto,” and therefore passed an Act (Act No. 4 of 2010) to establish National University of Study and Research in Law, Ranchi.

17.	That it is most humbly submitted that in furtherance of the establishment of NUSRL, Ranchi as envisaged by the Vidhan Sabha of Jharkhand, the state  government allotted 63.76 acres of land to NUSRL, Ranchi, the details and history of land allotment had been set out in the main writ petition filed by the main petitioner and to avoid unnecessary repetition, intervening petitioner humbly prays before this Hon’ble Court that the relevant portions [Para ,1, 2, 4, 5, 6, 7, 8, 9,10, 12, 13 ,14, 15 ,17]  shall be read as part and parcel of this interlocutory application. 

18.	That one of the major contention that is being made on behalf of the concerned villagers through I.A.no.1558/2012, filed in this public interest litigation had been that the concerned land is fertile and majority of the affected villagers being illiterate, their sole occupation is cultivation, therefore, if their land is taken away from them for the construction of NUSRL, Ranchi, then they will not have any means of livelihood left with them. 

19.	That it is most humbly submitted before this Hon’ble Court that none of the assertions made on behalf of the concerned villagers can stand the test of an objective analysis of the material facts and data available in the public domain. 
20.	That the intervener petitioners respectfully submit that the scientific reports available in public domain show that generally lands of Jharkhand are not suitable for sufficient agricultural production and more particularly the land in question cannot be regarded as fertile land, that can provide even a rural household a decent standard of living, cultivation being their sole source of livelihood. 
21.	That the intervener petitioners most humbly submit, that the soil of Jharkhand is not very fertile and productive, more essentially the land in dispute is worse off when it comes to fertility and productivity.
22.	That it is humbly submitted before this Hon’ble Court that, Ranchi district consists of tabular landmass and it has flat surface with isolated hillocks known as Tongri Hills lying on the west having elevation above 800 meters and those lying in east having  elevation less than 75 meters. That the average elevation of the district is 650 meters but western portion is relatively higher than the eastern part. 
23.	That it is humbly submitted that depending upon topography, soil is broadly classified into upland, medium land and lowland. That the brief description of upland, medium land and lowland is as given below;
•	Upland: Upland soils are generally red, acidic (pH 5.5-5.9) and have poor water holding capacity (WHC). Moisture is easily saturated during rains but release of moisture is very fast in the upland. It is suitable for Kharif pulses (pigeon pea, urd, moong & kurthi).
•	Medium land: Medium land soil is generally yellowish, slightly acidic (pH 6.0-6.5) and has intermediate water holding capacity. It is suitable for Rabi pulses (chickpea, lentil & pea) and in sequential cropping system, rice-chickpea/lentil; maize-chickpea/lentil may be produced, but in intercropping system, under irrigated situation, wheat, chickpea/mustard, chickpea/lentil can be produced.
•	Low land:  This type of soil is grayish, slightly alkaline (pH 7.0-7.3) and has high water holding capacity. That the Low land may be utilized for spring/summer cultivation. Low land is generally vacated after harvesting of transplanted paddy in 2nd week of December to 2nd week of January and it takes time for removal of moisture.

24.	That it is most humbly submitted that the land can further be classified into two sub categories:
GROUP	SUB-GROUP	TYPE	DESCRIPTION	
Don Land	Don I	Low Land	Clay-loam soil, lowest in toposequence, suitable for long duration rice crop	
	Don II	Shallow Land	Clay loam soil and best for rice production, rarely faces drought, suitable for medium duration rice	
	Don III	Drought prone
shallow land	Clay loam soil, transitional lands between Don & Tanr, upper toposequence and suitable for short duration rice	
Tanr land	Tanr I	Upland

	Loam soil and land immediately adjacent to the houses. Land used for vegetables, maize and rice seedlings	
	Tanr II	Upland	Sandy loam soil, gentle slopy, good soil depth, low WHC, poor in organic matter, erosion prone, acidic in nature	
	Tanr III	Upland

	Sandy loam soil, slopy, poor soil fertility, shallow soil depth, low WHC, Near foothills and acidic in nature

25.	That it is most humbly submitted that, soil fertility is an aspect of the soil-plant relationship. That it is respectfully submitted that fertility status of the soil is primarily and importantly dependent upon both the macro and micronutrient reserve of that soil i.e. the nature of vegetation, climate, topography, texture of soil and decomposition rate of organic matter. That it is humbly submitted that the optimum productivity of any cropping system depends on the adequate supply of plant nutrients. 
26.	That it is further submitted that, the majority of land in the District of Ranchi is covered with sandy loam with acidic soil (pH 4.5–6.5) and having low fertility. That the soil pH ranges from 4.2 to 7.6. That the majority of the area is acidic (96.4 % of Thermogravimetric analysis) in reaction. That the soil of 1.2% area of the district is neutral, whereas 0.2% of the area is slightly alkaline in reaction. 
27.	That the organic carbon content in the district ranges from 0.14 to 3.76%. That the 43.8% of the areas in the district have high organic carbon content. That the medium and low organic carbon content constitutes 28.7% and 25.3% of the area respectively. That the available nitrogen content in the surface soil of the district ranges between 109 and 638 kilogram/hectare [hereinafter Kg/ha]. That the majority soil (67.2 % of TGA) of the district have medium availability of nitrogen (280-560 kg/ha) whereas soil of 26.1% area have low available nitrogen content (<280 kg/ha). That the phosphorus content in this soil ranges between 0.5 and 26.6 kg/ha. That the majority of the soil is medium (56.2 % of TGA) in available phosphorous content. That the soil of 40.1% of the area is low and 1.5% of the area is high in available phosphorous content. That available potassium content in this soil ranges between 49 and 941 kg/ha. That the majority of the soil (57.1 % of TGA) have medium available potassium content (108-280 kg/ha). That the soil of 27.7% of the area are high (above 280 kg ha-1) and 13.0% of the area are low (below 108) in available potassium content. That it is most humbly submitted that the available sulphur content in the soil ranges from 0.6 to 72.1 mg/kg. That soil of 36.7% of the area is low in available sulphur, whereas soil of 30.5% and 30.6% of the area are medium and high in available sulphur content respectively. That the soil is sufficient in available iron and manganese whereas soil of 4.1% and 5.6% area are deficient in available zinc and copper respectively. That available boron content in the soil ranges between 0.02 and 3.52 mg/kg and 42.8% area of district is deficient (<0.50 mg kg-1). That the water holding capacity of the soil is very low due to porous nature of the soil and undulating topography. 
28.	Therefore it is most humbly submitted that it implies that the land of Ranchi district has very low fertility and cannot be termed as fertile land.

          A photo copy of the research on soil analysis of district of Ranchi undertaken by the National Bureau of Soil Survey and Land Use Planning (ICAR) Regional Centre, Kolkata in collaboration with Department of Soil Science & Agricultural Chemistry, B. A. U, Ranchi, Jharkhand, sponsored by Department of Agriculture and Cane Development, Govt. of Jharkhand is being herewith annexed and marked as 
     Annexure-1
29.	That it is humbly submitted that the state of Jharkhand has 24 districts and total geographical area is 79.71 lakh hectares and an estimated 38 lakh hectares has been classified as cultivable. That about 18 lakh hectare is the net sown area, comprising 22.7% of the total area and 47% of the cultivable area. That the state has 9.9%, 7.2%, 3.48% and 15.22% of the total geographical area of the State as land put to non-agriculture use, barren & unutilized land, cultivable wasteland and current fallows, respectively. That the State has 23.33 lakhs hectares of land under forest cover, comprising 29.27% of the total geographical area, which is much above the national average of about 18%. The net irrigated area is only 2.01 lakh hectares which is about 8% of the net sown area. The average area of holding in Jharkhand is 1.58 hectares and it was slightly higher than all-India average of 1.57 hectares and the land surface is rugged and undulating, ranging from flat lands to almost steep slopes. The state produces a little less than half of its food grains requirements. As a result, per capita food grain availability has been 230g against 523g of all-India average and against 480g of minimum requirement. That additional annual production of 24-25 lakh tonnes will be an uphill task in a scenario where land holdings are small and continuously shrinking and pressure on land keeps increasing.
                                                                                  A photo copy of report on Land Utilization Pattern in Jharkhand, as mentioned in the report of B. N. Singh, Director of Research, B.A.U, Ranchi is herewith annexed and marked as Annexure-2
30.	That it is most humbly submitted that because of the ongoing strike of land revenue staff and circle inspectors of state of Jharkhand, the intervener petitioners could not themselves procure the copies of the Khatian of the land in question, however the intervener petitioners had the opportunity to peruse the khatian filed in IA No. 1558/2012 in this writ petition. 
The photocopy of the khatians of the intervener petitioners filed as annexure- in the interlocutory petition no.1558/2012 is herewith annexed and marked as 
Annexure-3 
31.	That careful reading of the khatians undisputedly reveals that majority of the land in question which has been allotted to NUSRL, Ranchi is of type ‘Tanr-II’, which is a Upland Sandy loam soil (generally red in colour), with a characteristics of gentle slopy, good soil depth, low water holding capacity (WHC), poor in organic matter, erosion prone, acidic in nature (pH 4.5–6.5), having low fertility and under no circumstances it can be termed as a fertile cultivable land. 
                                                                                                 A photo copy of the detailed report of land allotted to NUSRL, Ranchi is being herewith annexed and marked as Annexure-4

32.	That it is humbly contended before this Hon’ble Court that the state of Jharkhand comes under Agro-Climatic Zone VII (Eastern Plateau and Hill Region). The whole State is divided in 3 sub zones, viz. sub zone IV (Central and North-Eastern Plateau), sub zone V (Western Plateau Region) and sub zone VI (South Eastern Plateau). The sub zone IV consists of 12 districts i.e. Dumka, Jamtara, Deoghar, Godda, Sahebganj, Pakur, Hazaribagh, Koderma, Chatara, Giridih, Bokaro and Dhanbad, sub zones V has 9 districts i.e. Ranchi, Gumla, Simdega, Lohardaga, Palamau, Garhwa, Latehar, Khunti and Ramgarh while sub zone VI consists only 3 districts, West Singhbhum, East Singhbhum and Saraikela districts. There are three main crop seasons namely Kharif, Rabi and Summer.
33.	That it is further submitted that Kanke block comes under Ranchi  district which is in sub zone V. That according to the survey of the Directorate of Rice Research, the total yield of rice in this zone was 2830 kg/ha in the year 2008-09 which was a year of good monsoon and thus of good yield. That it is humbly submitted that the productivity of the land in question may deteriorate substantially in a year of bad monsoon as the irrigation as well as power infrastructure in the land in question is very rudimentary. The small size of land holdings due to fragmentation also mean that scientific means of production can hardly be employed.             
34.	This implies that each family will have only 1217 kg of Dhan per annum, which is certainly insufficient to meet the need of grain production for any rural household.
A photo copy of the Research Report by the Director of Research, B.A.U, Ranchi on production of rice in District Ranchi on the basis of which given calculation is done is being annexed herewith & marked as Annexure-5
35.	That it is humbly submitted that the pattern of subsistence is reflected in the demographic trend because out of 1,026,488 (total population) of Kanke block only 23,121 people are cultivators, rest of the people are working as either manual labour in some construction projects or in household or as a marginal worker. Therefore, it is evident from the above data that agriculture is not and cannot be the sole occupation of the people of Nagri village which comes under Kanke block.
36.	It is further submitted that due to endemic impoverishment in Kanke block, a number of policies are being undertaken by the Government like MNREGA, PDS etc. which has improved the living conditions of the villagers in some measure. Educational programmes run by the government have resulted in a high literacy rate of 80.2% in the block. That it becomes imperative to submit that the establishment of reputed and renowned institutes in the locality will provide an impetus towards socio economic growth of the region. However, the possibility of long term benefits accruing to the people of the area after the establishment of NUSRL, Ranchi is being undermined by certain vested interests that have myopic selfish object. Since Nagri village is not very far from Ranchi city, the life style of the villagers is influenced by the urban way of living, and it has also affected the new generation so much so that their cost of living has increased to a great extent and in order to meet that expense, they have resorted to short-cuts. It is this young and impressionable generation which is lead astray by the aforesaid vested interests. 
                                                                                                    A photo copy of Jharkhand Government’s official data about Kanke block is herewith annexed and marked as 
Annexure-6
37.	That it is being contended on behalf of concerned villagers that because some of affected villagers have not actually taken the compensation amount awarded by the authorities in lieu of acquisition of their land, therefore, the land acquisition is bad in the eyes of law. However, it is pertinent to mention here that current land acquisition was done more than 50 years back and as so judiciously noted  by this Hon’ble Court that none of the agitating aggrieved parties were even born at the time  of acquisition so as to why the compensation amount was not collected by those original rayyats could only be a matter of conjecture. Additionally, it is most humbly submitted before this Hon’ble Court, that it is an established law of the land as provided for in the Land Acquisition Act 1894 (hereinafter the Act), that “if the compensation awarded to the concerned persons from whom the land had been acquired for, is not accepted by them, the money would directly be deposited by the Collector in the Court”. This was affirmed in the case of Tamil Nadu Housing Board vs. A. Viswam (Dead)By Lrs 1996 SCALE (2) 418, which dealt with the non acceptance of compensation of the land acquired. In this matter, the Hon’ble Supreme Court of India held that in case no one accepted the compensation which he is entitled to, by virtue of Section 30 of the Act, then the money thereafter is to be deposited in the concerned Court. More importantly, the Hon’ble Court further held that; in such a case, the possession would be taken and thereafter the land stands vested in the State Government under Section 16 of the Act, free from all encumbrances. Hence, the acquisition becomes complete and the title of the land is legally assumed by the Government.
38.	That it is humbly submitted before this Honorable Court, that as per the law no further interest is to be paid once the compensation amount is deposited in the court, however, this Hon’ble Court in a writ petition [Writ Petition No. 2356 of 2009] filed by concerned raiyat took a very liberal and kind approach on this issue and allowed the raiyats to receive compensation amount with interest @ 15% which accumulates  up to a substantially large amount considering the fact that money had been deposited with the state treasury for  than 50 years. It is most humbly brought to the notice of this Hon’ble Court that in the said petition, the validity of the acquisition was never challenged. It is most respectfully submitted that now the compensation awarded per acre of land rests at Rs 20 lakh. It is important to bring to the kind attention of this Hon’ble Court that the  land in question is Bakhast Bhumihari land which cannot be sold in free market to any one that they want to.   
A photo copy of news paper report published in Prabhat Khabar dated 26th August 2012 giving details of the current amount of compensation is being herewith annexed and is marked as Annexure No. 7
39.	That it is most humbly submitted before this Hon’ble Court that there is no express bar on the government acquiring the agricultural land for public purposes, provided the appropriate procedure is followed during the acquisition. 
40.	In the present case the land in dispute is not a highly productive agricultural land and can be cultivated only during the rainy reason vide Order No.3 of this Hon’ble Court in W.P.(PIL)No.2347 of 2012 dated 16th May 2012. Moreover, it is not the sole source of income for their families as submitted in the preceding paragraphs of this interlocutory application. 
41.	That it is most respectfully submitted that the courts have only nullified those acquisitions wherein the statutory procedure and the principles of natural justice have been grossly violated by the concerned authorities. However, it is most humbly submitted that so far acquisition of Nagri land is concerned the procedure had been religiously followed. 
42.	That the intervener petitioners most humbly submit, even at the cost of repetition, that adequate compensation had already been awarded at the time of acquisition which was never challenged by any of the raiyats living at the time of acquisition.  That it is further submitted that with the lapse of time as the Hon’ble High Court had kindly noted that now the amount of compensation has accumulated to a large sum of money as mentioned in para 38 of this interlocutory application. 
43.	That the intervening petitioners most humbly submit, that in the present case all the statutory provisions with respect to the land acquisition have been religiously followed. Moreover, it is humbly submitted that the Hon’ble Supreme Court has opined in Raja Anand Brahma Shah v. State of Uttar Pradesh (AIR 1967 SC 1081) that once Section 17(4) of the Act is invoked then Section 5A shall not be applicable. 

44.	That it is most humbly submitted that after being carved out from the state of Bihar, Jharkhand came into existence in Nov 15, 2000.  That the creation of this state is the culmination of more than half a century of aspirations and struggle of the tribal people, who had witnessed the ingress of outsiders in their land, economy and their social system. It becomes imperative to mention that the prosperity of any state depends upon its institutions and the opportunities provided by these institutions to the people of the state. That the ability of the people to make the best use of such opportunities is undoubtedly high, but they can be improved considerably if the large masses are well educated and healthy. That though the state of Jharkhand is rich in minerals, it is economically as well as educationally poor. Additionally it is to be most humbly submitted that the state lags far behind in terms of institutes of higher learning that can build capacity in local people to exploit the natural wealth and richness so abundantly available within the confines of state. 
45.	 It is most pertinent to mention that eastern India used to be a hub of education and research in ancient times. Since the very onset of cultured civilized society, this region played a very significant role in making people educated and research oriented despite of the fact that the other societies across the country did not prioritize education. That until before Independence, this region had been a cynosure of education and research. People used to come and study in Universities of Bihar, West Bengal. However, with the passage of time, these states started lagging behind, not only in education but almost in all the sectors of the economy. 
46.	That it is most humbly submitted that low level of education and lack of employment opportunities in Jharkhand has resulted in exodus of tribal People to other states. This  has  created  an  alarming  situation for  the  tribal  communities  in  the  State as they continue to perish on account of limited educational opportunities. Jharkhand is known as a home for 32 notified tribes, of which 9 are, notified primitive Tribes. According to 2001 Census Report these constitute 26.3% of the total population of the State. It is also pertinent to mention that percentage of poverty among tribal in Jharkhand is 60% whereas literacy rate among them is only 40.7%. In spite of constitutional safeguards, tribal people still continue to be socially and economically backward. Lack of education becomes their biggest impediment in their desire of working in an organized sector. As a result of which they migrate to other neighbour states in search of job opportunities where they easily get jobs as domestic helpers or sustain their livelihood by doing other menial work. Despite the exploitative nature of the salary earned by them, they remain silent in absence of other alternative source of income. Only with spread of education and generation of employment opportunities inside the state, this problem of migration will start receding. Socio economic empowerment of tribal people is the need of the hour to protect the identity of this community in the state.
47.	That it is most respectfully submitted that the overall literacy rate among the STs has increased from 27.5 per cent at 1991 census to 40.7 per cent at 2001 census. Among the total tribal literates, 33.6 per cent are either without any educational level or have attained education below primary level. The proportions of literates who have attained education up to primary level and middle level are 28.6 per cent & 17.7 per cent respectively. Persons educated up to Matriculation / Secondary / Higher secondary constitute 16.5 percent. This implies that every 6th tribal literate is a matriculate. 
48.	That it is most humbly submitted that it is starkling to submit that the total number of Graduates and above are only 3.5 per cent while non-technical & technical diploma holders constitute a negligible 0.1 per cent only. The data also shows that the proportion of tribal literates decline sharply in higher level of education as the percentage of students after matriculation drops down to almost one third in higher secondary level.  Therefore, it is submitted that this being the scenario, there arises an obligation on the part of the government to assure that their share in higher studies goes upwards. If this is not done, the dream of inclusive growth as envisioned by our forefathers will remain meaningless. There thus, arises a legitimate reasonable expectation on the part of the people towards the government and the government must ensure that it does not shirk its responsibility. 
                                                                                                    A photo copy of the census statistics about levels of education among the major scheduled tribes is being herewith annexed and marked as Annexure-8
49.	It is humbly submitted that, the establishment of NUSRL in Nagri village will not only develop the infrastructure of the nearby areas, but also provide employment opportunities to the local population. It is humbly submitted that the local population may acquire Grade III and Grade IV posts in the University, which will improve their standard of living substantially. It is humbly submitted that due to the increase in standard of living due to availability of better employment opportunities, there might be a possibility of the local children being future students in the University due to the 50% reservation for Jharkhand domicile holders. Thus, it is humbly submitted that the establishment of the University will furnish all round progress for the surrounding community, promoting adequate growth and development.
50.	It is further submitted that due to non-availability of its own campus the cost of running the university is going very high. A detailed expenditure of amount already being spent and continuous cost of running this university is presented below for the kind consideration this Hon’ble Court The detail of expenditure over construction of boundary wall at site (Nagri) and rentals paid is as under:- 

1)	Against the Estimated Cost for the Construction of Boundary of the Main Campus a total amount of Rs. 2.36 crores, our contractor M/s CPWD has so far submitted a Bill for Rs. 2.25 crores.

However, Rs. 1.5 crores has already been paid and Rs.75 lacks is yet to be paid by us to CPWD for which CPWD has already furnished the Bill and University is in the process to pay the same.

2)	Rent details

S.No.	Particulars	Period	Rent Amount	Remarks	
1	Academic Building and Mess Building at BIT Mesra	Dec’ 2010 to June 2012	23,46,312.00	Yet to be paid
(From July 2012 to till Date Bill has not yet been Received)	
2	Boys Hostel (Niwaranpur)	June’2011 to Nov’ 2011	7,55,000.00
	Paid	
3	Boys Hostel and Girls Hostel
(Sahara Vihar)	Nov’2011 to Till Date	22,00,000.00
	Paid	
4	University Guest House	Nov’2010 to April 2011	95,000.00	Paid	
5	Hon’ble V.C Residence at Ashok Nagar	Nov’2010 to April 2011	80,000.00	Paid	
6	Hon’ble V.C Residence at Dipatoli	April 2011 to till Date	2,08,880.00	Paid	
7	Girls Hostel at BSNL	June’2011 to Nov’ 2011	7,00,000.00	Paid	
8	Girls Hostel at Gautam Green City	Dec’2010 to Aug’ 2011	2,52,000.00	Paid	
9	Boys Hostel at KhelGaon	May 2012 to till date	9,20,000.00	Yet to be paid	
	TOTAL	75,57,192.00
		
Notes:

(A)	Since the Hostel is situated at a considerable distance from the Academic Campus, the University has purchased Two Buses for plying Students to and fro from University to Hostel. This too has considerable expenditure in terms of upkeep of (i) Staff for Bus (ii) Fuel Expenditure (iii) Vehicle Maintenance. 

(B)	The University is in the process of purchasing the third Bus as presently Two Busses are insufficient and causing tremendous inconvenience. Therefore, the costs as mentioned in (A) above are going to rise further.

(C)	Mess is also being run at three different places i.e. in Boys and Girls Hostel and then in the Academic Bloc, accordingly the Cost of Mess Expenditure which is being incurred by Students is also high and difficult to manage.

(D)	Scattered infrastructure in absence of University’s own campus has not only been creating inconvenience of different sort but is also a tremendously costly affair in terms of maintenance and more number of staff for its upkeep and maintenance. 	

A photo copy of  details of expenditure of NUSRL,Ranchi is herewith annexed and marked as Annexure- 9
51.	That, it is humbly submitted that NUSRL is providing its students the best academic experience. That the students are not lagging behind the other prestigious law school so far the academic inputs are concerned. However this is being achieved at a very high emotional and physical cost. It is humbly submitted that being a residential college the students are expected to stay close to the academic centre in order to avail facilities to their best, however this is not being achieved and also the hostels are being continuously changed with the passage of each semester. It is humbly submitted that in the short span of two and a half years hostels have been shifted from Gautam Green City to BSNL Colony and finally now to Sahara Vihar for the girls and from BIT Polytechnic Campus to Nivaranpur to finally at Khelgaon  for the boys. It is humbly submitted that due to the distance between the academic block and the hostel, heavy expenditure is being incurred by the University as mentioned in preceding paragraph and additionally it is also causing a lot of mental stress to the students. It is humbly submitted that, since the girls need to be back to their hostels by 6p.m due to safety reasons, no co-curricular and extracurricular activities can usually be conducted that is hampering the overall development of students of NUSRL.  

It is therefore, prayed that, your lordship may graciously be pleased to allow this interlocutory application and further be pleased for impleading them as co petitioners for bringing on record certain relevant facts for the kind consideration of this Hon’ble Court so that an appropriate order can be passed so that complete justice be done in the instant case to all the parties concerned.

AND/ OR
For any other relief(s) as Your Lordships may deem fit & proper.