As of now govt issues NOC to an employee 3 times in a year. They can not deny to issue NOC.
Demand for NOC by written communication with a copy to the appointing authority and also to concerned ministry. You can issue the notice by any lawyer also but it is not essential.
In default file suit in appropriate court tribunal seeking directions to your employer to issue NOC.
It is your right to apply for new job. Govt or other authority can not take away such right from you except in accordance with law.