1

IN THE HIGH COURT OF JUDICATURE MADRAS BENCH AT

MADURAI

(Special Original Jurisdiction)

W.P.(MD)No. of 2024

G. Loga Abivardhini
D/O T. Gopalakrishnan,
Sowdamman kovil Street,
Vishwakarma kalyana mandapam,
Bodinayakanur,
Theni district.
……………
…. Petitioner
1) The District Collector,
Bodinayakanur.
2) The Assistant Director of Town Panchayat,
Bodinayakanur Zone,
Bodinayakanur.
3) The Executive officer,
Pottipuram Town Panchayat
Bodinayakanur Taluk,
Bodinayakanur.
4) Department of Atomic Energy (DAE)
Government of India.

…………...Respondents
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AFFIDAVIT OF THE PETITIONER

I, G. Loga Abivardhini, D/O of T. Gopalakrishnan, aged about 21

years, residing at Sowdamman kovil Street, Vishwakarma
kalyana mandapam, Bodinayakanur, Theni district, do hereby
affirm and sincerely state as follows;

1. I am petitioner and I am well aware of the facts and

circumstances of the case.
2. I humbly submit I am filing this writ petition as a public
interest litigation and I have enclosed my Aadhar Card. I
have no personal interest or gain and I meet the expenses of
filing this Writ Petition from out of my own funds. I have not
filed any other Writ Petition on the same subject matter either
before this Hon’ble Court or any other Court. I am ready to pay
the costs that may be imposed by this Hon’ble Court, if this
Hon’ble Court finds that the present writ petition is frivolous
and an abuse of process of the court. My Aadhar card
No.______________. My Pan Card number
is____________________. I am filing this writ petition based on
own personal knowledge.
3. I humbly submit that I am a law student and I have large
interest to serve the society, especially to my home town.
Further myself along with other people of my age have been a
volunteer of a non-governmental organisation in the name of
“Poovulagin Nanbargal” and we address the needs and
demands of the public. We have also taken many
environmental campaigns to preserve the ecology and the
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greenery of our town with regard to saving the ponds, streams

and protecting the extinction of animals etc., in my town.
4. I humbly submit that the Indian Neutrino Observatory project
that is to be implemented in the Ambarappar Hills in the
Pottipuram town consisting of the population of about 15,000
people which is the first-grade town panchayat in the
bodinayakanur taluk, Theni district. Pottipuram is situated in
the foothills of western ghats. Now due to the construction of
the proposed India Neutrino Observatory at Bodi West hills in
Theni district.
5. I humbly submit that the neutrino observatory project is
envisioned as a “world class underground laboratory to study
fundamental issues in science”. The mega science project with
an investment of about Rs. 1538 crores is a project of national
importance, and once completed, will be the largest basic
science project in India. The project is located 4.9 km off
Mathikettan Shola National Park and falls in Bodi Hills West
Reserve Forest In the southern western ghats.
6. I humbly submit that the Mathikettan-Periyar Tiger Corridor
has a critical function of maintaining the genetic flow, which
will be destroyed by the project activities.
7. I humbly submit that the Mathikettan Shola National Park in
Idukki district of Kerala falls under the eco-sensitive zone
(ESZ), but not the Tamil Nadu side, making the INO project
free of clearance from the Standing Committee of the National
Board for Wildlife (NBWL). However, 31.45 hectares of the
construction site fell inside the Mathikettan-Periyar tiger
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corridor, one of India’s 32 major tiger corridors recognised by

the NTCA.
8. I humbly submit that this project involves the creation of a
tunnel of about two kilometers in length, cutting through the
rock formation, at a depth of one kilometer from the peak.
9. I humbly submit that this project tunneling a rock which will
be a greater risk for the sanctuaries nearby the pottipuram
village. The main aim of this project is that the Indian
Neutrino Observatory along with the FERMILAB research
center had decided to bring artificial neutrinos which is being
tested to produce neutrino weapons and other sort of things
and exported accordingly.
10. Furthermore the tunneling work in the project involves
carrying out blasting in the hard and composite rock mass and
required a huge quantity of high strength explosives to break
it. This involves excavation of 6 lakh cubic meters of
Charnockite rock from the mountain. The depth of this
tunneling will create problems like rock bust and roof collapse.
The proposed area forms a significant watershed and water
catchment for river sambal and river kottakudi. The small
streams on the west side of bodi hills join river kottakudi,
which merges with river periyar, before flowing into vaigai
dam.
11. In addition to the watershed was the lifeline of the local
communities as it supported their livelihood and provided
water for drinking and agricultural needs for five districts of
Tamil Nadu.
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12. I humbly submit that this project will extinct the specific
region which is harbouring many endemic species of flowering
plants, fish, amphibians, reptiles, birds, mammals and
invertebrates other than large numbers of elephants and
tigers.
13. I humbly submit that the environmentalists and the
scientist utter that even the least disturbance to the habitat
would have a huge impact on the movement of tigers. By their
biological behaviors, tigers would completely avoid human
presence and any other anthropogenic disturbances and move
through undisturbed patches of forest. Even a little vibration
in the land can bring enough disturbance to its movement
pattern.
14. I humbly submit that this project endangers the ESZs
which are the ecologically fragile areas within 10 kms around
the protected areas, national parks and wildlife sanctuaries.
These are notified by the Ministry od Environment, Forest and
Climate Change (MoEFCC) under Environment Protection Act,
1986.
15. I humbly submit to this hon’ble high court that this project
violates the Wildlife (Protection) Act 1972 and Forest
(Conservation) Act 1980.
16. I humbly submit that this project is carried forward by the
Fermilab which is the largest contributor in the project, since
the central government is keeping quiet about the functioning
of the project, I would like to add that in Grandsaso, Italy, the
neutrino research center was established and after the
functioning of that center the people in that village faced many
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ecological issues and the earthquake while performing the

tunneling underground the village. We, the citizen of Earth,
should not breach the law of nature for the development of the
landscape.
17. I humbly submit that highlighting the above facts, I have
addressed a comprehensive representation dated 25.03.2024
& 12.04.2024 to the respondents, even after receiving the
representations there is no progress. However, I have
addressed a representation to the Hon’ble Chief Minister,
Special Cell at Chennai by which I received a communication
from the 3rd respondent wherein I was informed that they are
looking into the project and its effects caused to the land in
around the village and the environmental issue related to the
project. But there is no progress from the concern department
and thereby I am constrained to file this Public Interest
Litigation seeking direction to stop the project which will be a
danger to the future and present generation and to the ecology
of the environment.

It is therefore prayed that this Hon'ble Court may be

pleased to issue a writ or order or direction in the nature of
WRIT OF MANDAMUS for bearing the respondents from
implementing this project in Pottipuram town of the
Bodinayakanur taluk, Bodinayakanur, Theni district, Tamil
Nadu and pass such or other orders as this Hon’ble Court
may deem fit and proper in the fact and circumstances of the
case and thus render justice.
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Solemnly affirmed at Madurai after the contents are explained to

him in Tamil and having understood the same on this ________
day of 2024 before me and signed his name in my presence.

Advocate, Madurai

MEMORANDUM OF WRIT PETITION

(Under Article 226 of the Constitution of India)
IN THE HIGH COURT OF JUDICATURE AT MADRAS
BENCH AT MADURAI
(Special Original Jurisdiction)
W.P.(MD).No. of 2021

G. Loga Abivardhini
D/O T. Gopalakrishnan,
Sowdamman kovil Street,
Vishwakarma kalyana mandapam,
Bodinayakanur,
Theni district.
………………. Petitioner
1) The District Collector,
Bodinayakanur.
2) The Assistant Director of Town Panchayat,
Bodinayakanur Zone,
Bodinayakanur.
3) The Executive officer,
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Pottipuram Town Panchayat

Bodinayakanur Taluk,
Bodinayakanur.
4) Department of Atomic Energy (DAE)
Government of India.
……………. Respondents

WRIT PETITION

The address for service of all notice and process on the petitioner
is through her counsel Mr. Chinnaiah and Mrs. Indhuja having
the office at #3 Kannimari Amman Kovil, 2 nd street, K.Puthur,
Madurai.

The address of the service of all notice and process on the

respondents are stated as above.

It is therefore most humbly prayed that this Hon’ble Court

may be pleased to issue Writ, Order or Direction in the nature of
WRIT OF MANDAMUS directing the respondents 1 to 4 to initiate
appropriate action to prevent the project of the Indian Neutrino
Observatory and pass such other orders as this Hon’ble Court
may think deem fit in the facts and circumstances of the case
and thus render justice.

Dated at Madurai on this the_______day of April, 2024.

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Counsel for the petitioner

IN THE HIGH COURT OF JUDICATURE MADRAS BENCH AT

MADURAI

(Special Original Jurisdiction)

W.P.(MD)No. of 2024

G. Loga Abivardhini
D/O T. Gopalakrishnan,
Sowdamman kovil Street,
Vishwakarma kalyana mandapam,
Bodinayakanur,
Theni district.
……………
…. Petitioner
1) The District Collector,
Bodinayakanur.
2) The Assistant Director of Town Panchayat,
Bodinayakanur Zone,
Bodinayakanur.
3) The Executive officer,
Pottipuram Town Panchayat
Bodinayakanur Taluk,
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Bodinayakanur.
4) Department of Atomic Energy (DAE)
Government of India.

…………...Respondents

INDEX TO TYPED SET OF PAPERS

S.No Date Description of Documents Page No
1 26.03.2024 Evidence of Neutrino project
2 28.03.2024 Photos related to project
3 12.03.2024 Report of the project

Dated at Madurai on this__________Day of April, 2024.

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Counsel for the Petitioner.

IN THE HIGH COURT OF JUDICATURE MADRAS BENCH AT

MADURAI

(Special Original Jurisdiction)

W.P.(MD)No. of 2024

G. Loga Abivardhini
D/O T. Gopalakrishnan,
Sowdamman kovil Street,
Vishwakarma kalyana mandapam,
Bodinayakanur,
Theni district.
……………
…. Petitioner
1) The District Collector,
Bodinayakanur.
2) The Assistant Director of Town Panchayat,
Bodinayakanur Zone,
Bodinayakanur.
3) The Executive officer,
Pottipuram Town Panchayat
Bodinayakanur Taluk,
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Bodinayakanur.
4) Department of Atomic Energy (DAE)
Government of India.

…………...Respondents
SYNOPSIS WITH DATES AND EVENTS
The Petitioner humbly submits that he is filing this writ petition
as Public Interest Litigation to direct the respondents the
respondents 1 to 4 to initiate appropriate action to prevent the
project of the Indian Neutrino Observatory and pass such other
orders as this Hon’ble Court may think deem fit in the facts and
circumstances of the case and thus render justice.

The Petitioner humbly submits that a representation to the

respondents was sent on 25.03.2024 & 12.04.2024. But no
effective action has been taken by the respondents. Hence,
having no other speedy and efficacious remedy the petitioner has
approached this Hon’ble Court under Article 226 of Constitution
of India.
DATES AND EVENTS
1. 25.03.2024 – Representation sent by the Petitioner.
2. 12.04.2024 – 2ND Representation by the Petitioner.

Dated at Madurai on this__________Day of April, 2024.

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Counsel for the petitioner

IN THE HIGH COURT OF JUDICATURE MADRAS BENCH AT

MADURAI

(Special Original Jurisdiction)

W.P.(MD)No. of 2024

G. Loga Abivardhini
D/O T. Gopalakrishnan,
Sowdamman kovil Street,
Vishwakarma kalyana mandapam,
Bodinayakanur,
Theni district.
……………
…. Petitioner
1) The District Collector,
Bodinayakanur.
2) The Assistant Director of Town Panchayat,
Bodinayakanur Zone,
Bodinayakanur.
3) The Executive officer,
Pottipuram Town Panchayat
Bodinayakanur Taluk,
Bodinayakanur.
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4) Department of Atomic Energy (DAE)

Government of India.

…………...Respondents
BATTA MEMO

1) The District Collector,

Bodinayakanur. ….. Rs. 30

2) The Assistant Director of Town Panchayat,

Bodinayakanur Zone,

Bodinayakanur. ….. Rs. 30

3) The Executive officer,

Pottipuram Town Panchayat

Bodinayakanur Taluk,

Bodinayakanur. ….. Rs. 30

4) Department of Atomic Energy (DAE)

Government of India. ….. Rs. 30

Total ….. Rs. 120

Dated at Madurai on this__________Day of April, 2024.

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Counsel the petitioner

VAKALATHNAMA

IN THE HIGH COURT OF JUDICATURE AT MADRAS,

MADURAI BENCH

(MD). No. of 2024

G. Loga Abivardhini
D/O T. Gopalakrishnan,
Sowdamman kovil Street,
Vishwakarma kalyana mandapam,
Bodinayakanur,
Theni district.

…….Petitioner

Versus ...

1) The District Collector,

Bodinayakanur.
2) The Assistant Director of Town Panchayat,
Bodinayakanur Zone,
Bodinayakanur.
3) The Executive officer,
Pottipuram Town Panchayat
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Bodinayakanur Taluk,
Bodinayakanur.
4) Department of Atomic Energy (DAE)
Government of India.

……Respondents

I, G. Loga Abaivardhini , the Petitioner in the

above petition do hereby appoint and retain Advocates of the
High Court to appear for me in the above WRIT petition and to
conduct and prosecute the same and all proceedings that may be
taken in respect of any application connected with the same or
any decree or order passed therein including all applications for
return of documents of the receipt of any money that may be
payable to me in the said WRIT Petition and application for leave
to the Supreme Court of India and in all applications for review of
judgment.

[Signature of the petitioner]

I certify that the contents of this vakalath were read out and
explained in Tamil in my presence to the executant who
appeared perfectly to understand the same and made
signature in my presence.

Executed before me this Monday of April, 2024

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We accept the vakalathnama

(Advocate)
the address of the service of the advocate
any Identity card No.
Name and address of the part(ies)
with Mobile No. and email id., if any
& any Identity card No.

MADURAI DISTRICT

IN THE HIGH COURT OF JUDICATURE AT MADRAS,

MADURAI BENCH

(MD). No. of 2024

UNDER ORDER III RULE 1 OF

CODE OF CIVIL PROCEDURE, 1908

VAKALAT
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Mr. Chinnaiah, M.A.B.L

Mrs. Indhuja, B.A.B.L

Counsels for petitioner