PRAYER
In view of the facts and circumstances mentioned in the accompanying Writ Petition, it is most respectfully prayed that this Hon’ble Court may be pleased to:
(a) Issue a Writ of Mandamus or any other appropriate writ, order, or direction in the nature of Mandamus, directing the Respondents to grant the Petitioner the benefits of the Modified Assured Career Progression (MACP) scheme by reckoning the residency period from the date of his reporting for Basic Recruit Training (BRT), at par with similarly situated personnel who have been granted such benefits pursuant to judicial pronouncements;
(b) Direct the Respondents to re-fix the pay and pension of the Petitioner accordingly and to release the arrears of pay and pension along with interest at the rate of 12% per annum from the date the amounts became due until the date of actual payment;
(c) Pass any other or further order(s) as this Hon’ble Court may deem fit and proper in the interest of justice and equity.
AND FOR THIS ACT OF KINDNESS, THE PETITIONER SHALL EVER PRAY.
Place: Date:
Petitioner-in-Person
