IN THE SUPREME COURT OF MAURITIUS

In Re:-

Devendranath Hurnam also know as Dev Hurnam,

a [UK] Qualified Barrister, of 22 Bourbon Street, Port Louis Applicant

Navinchandra Ramgoolam, Prime Minister, Minister of Defence, Home

Affairs and External Communications, service at Treasury Building
Port Louis Respondent

In the Presence of:-

The Attorney-General[Unreturned], Y N Varma, Renganaden Seeneevassen Building,

Port Louis
Co-Respondent

NOTICE OF MOTION

Take Notice that You, the above named Respondent and Co-Respondent, may not
plead or pretend ignorance of same that Applicant shall, on Monday 2 May 2011,
@10.00 a.m. move the above Court for an Order:-

A. Declaring and decreeing that Respondent has committed a contempt of Court by

publicly stating to the assembled audience [in local creole dialect of French] at
the Varusha Pirapu celebrations organised by the Mauritius Tamil Temples
Federation [MTTF] on or about 13 April 2011 at the IGCIC amongst
others”………..qui sa problem la et qui si jamin sa problem la resoudre nou
capave regeutte CT Power pe ena aucauine raison ki fer nu pas capave regeutter
mais seulment nu bizin fer sure (clappings going on)……nous conner enna enn
crise se pourquoi nu va nu va rexamine et nu pu reguette rapport la parcequi
enna enn koze ki finne vine dans mo zoreille qui sa rapport la finne soidisant
manipuler mo pas capave dire ou si li vrai ou si pas li fausse mais nu va regeutte
li parcequi moi mo enna enn souci de justice’ basically suggesting that cabinet
was misled by a report on CT Power ….and that Government is ready to revisit
the matter and this at a time when the Environmental Appeal Tribunal is
legally seized with an appeal by The Mauritius CT Power [CN 02/11 against
The Minister of Environnement and Sustainable Development’s refusal to
grant an EIA Licence to Messrs CT Power Ltd which public speech was widely
reported on the National TV, Private Radios and in the press whereby he
undermined the course of justice and has attempted to influence the decision
of the aforesaid Tribunal and or he has influenced the conduct in the litigation
process ;

B. Declaring that Respondent’s aforesaid public speech is aimed at influencing not

only the aforesaid Tribunal but all other jurisdictions that may be legally seized
with its decision in the event of an appeal that may be undertaken by the
relevant parties and
C. Committing Respondent to jail for contempt and or he be dealt with for
contempt as the Supreme Court may deem fit in the particular circumstances of
the case.

ALTERNATIVELY:

D. Directing Co-Respondent to take over the proceedings as a Relator Action

should the Court find that Applicant has no locus standi and

E. And make any other order as the justice of the case may require.

AND THIS for the reasons fully set forth in the hereto annexed affidavit, a true and
certified copy of which is herewith served upon you. You are hereby required,
summoned and called upon to be and appear PERSONALLY before the above Court
on the day and at the hour aforesaid to show cause, if any, why the above motion
should not be granted.

TAKE further Notice that the said motion shall be made on the above date and hour
whether you be present or not.

Under all legal reservations

Dated this 20th day of April 2011

D Hurnam/Applicant In Person
22 Bourbon Street, Port Louis.