IN THE HIGH COURT OF JUDICATURE AT MADRAS
Tamil Nadu Higher Secondary
Postgraduate Teacher's Association,
(Registration No.160/1980),
Represented by is Legal Wing
Secretary, R. Srinivasan
No.159, Gengu Reddy Salai,
Egmore, Chennai-600 008.…..Petitioner
Versus
1)State of Tamil Nadu
Represented by its Secretary,
School Education Department,
Fort St. George,
Chennai-600 009.
2)The Director of School Education,
DPI Campus,
College Road,
Chennai-600 006.……Respondents
AFFIDAVIT OF THE PETITIONER
I, R. Srinivasan, Son of Ramalingam , Hindu, aged about 36 years,presenting holding the post of Legal Wing Secretary of the petitioner association having office at No.159, Gengu Reddy Salai, Egmore, Chennai-600 008, do hereby solemnly affirm and sincerely state as follows:
1.
I am the Legal Secretary of the petitioner association and hence I have been authorized to swear to this affidavit on behalf of the petitioner association.
2.
I state that I am filing the present Writ Petition in the nature of public interest litigation for the implementation of G.O.Ms.No.525, School Education, dated 29.12.1997 which mandates the teacher student ratio in the schools in the State of Tamil Nadu.
3.
I state that the petitioner is before this Hon'ble Court in view of the fact that despite bringing to the notice of the respondents the inadequacy of teachers in various schools especially with reference to the Higher Secondary Schools in Krishnagiri District, the respondents have not chosen to act upon the representation of the petitioner association.
4.
I state that as the Postgraduate Teacher's Association, the petitioner's association consists of postgraduate teachers working in various districts in the State of Tamil Nadu.
5.
It is submitted that it was brought to the notice of the association by the members of the association the fact that in certain schools in Kirishnagiri District, there are only 2 teachers in each subject to teach 1500 students. It is submitted that due to inadequacy of teachers, the students suffer in as much as the teachers are made to take classes for sections containing more than 120 students whereas the Government order prescribes the ratio of one teacher for every 40 students.
6.
It is submitted that after the advent of the Right to EducationAct, though it is confined only up to the age of 14 years, it is theconstitutional right of every child to be taught in a qualitativemanner.
7.
It is submitted that due to the fact that a teacher is made to take classes for 750 students, obviously the quality of education suffers and the students are not imparted with even the most basic knowledge which the syllabus requires.
8.
It is submitted that the petitioner's association gave a detailed representation bringing to the notice of the respondents through the Chief Minister's Cell, to which a reply was received that as and when the posts are sanctioned by the Government, the same would be allotted to the schools.
9.
It is submitted that in Krishnagiri District in Government Girls Higher Secondary School, Hosur, there is a students' strength of 1500 in numbers and the teachers strength is as per the tabular column below:………………
10.
It is submitted that thus a Commerce Teacher is teaching Mathematics for more than 100 students and English is being taught by two teachers for 1500 students. It is submitted that each teacher has to take 6 classes of English per week and therefore the ratio instead of being 1:40 has become 1:120. It is submitted that the same position is prevalent in many schools in Tamil Nadu. The petitioner has brought to the notice of the respondents the prevalent scenario with regard to the schools in Krishnagiri vide his representation dated 27.01.2015.
11
It is submitted that despite the same, the respondents have not taken any steps in addressing the issue and instead have replied to the complaint given to the Chief Minister's Cell that as and when the teachers are appointed, they will be allotted to the schools.
12.It is submitted that if the said position is permitted to continue, it will definitely damage the entire fabric of the education system in as much as the inadequacy of teachers will affect the quality of education that is imparted. On the one hand, the burden is heavy on the teachers and on the other hand, the children suffer.
Under the said circumstances, it is humbly prayed that this Hon'ble Court may be pleased to issue a Writ or direction or order, more in the nature of a Writ of Mandamus directing the respondents herein to consider the representation of the petitioner's association dated 27.01.2015 and accordingly sanction and allot postgraduate teachers to the Government Higher Secondary Schools in Tamilnadu in accordance with G.O. Ms. No.525, School Education Department, dated 29.12.1997 within a time frame to be fixed by this Hon'ble Court and pass such further or other orders as this Hon'ble Court may deem fit and proper in the facts and circumstances of the case and thus render justice.
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