Writ petition

Dear Sir, In writ petition criminal, what is to be included in the list of dates and events? Am I to give the dates and events of actual facts only or I am also to include some case laws pertaining to violation of fundamental right which is the question of law of my concern. Say for example inactivity of police and administration in certain happening, date of launching complaints etc,only or I have to refer case law e.g maneka Gandhi vs state of Delhi. Actually my case is against instrumentality of state under Article 32, and also violation of Article 19 to 21 in which there is clear indulgence of administration for which I want to seek CBI investigation as I don't have access to collect definite evidence and have got evidence of few incidence of inactivity of various public authorities and also the ground,facts and circumstances of indulgence and inactivity . kindly suggest how to draft properly the writ petition so as to get the writ of mandamus in my favour from the circumstantial evidence