In the light of the arguments advanced and authorities cited, the Petitioner(s)

humbly plead before the Hon’ble Court to adjudge the following:

1. Section 67A, 69A and 69B of the Information Technology (Amendment)Act 2008 are
unconstitutional and allied provisions in the Indecent Representation of
Women(Prohibition) Act, 1986 and the Indian Penal Code, 1860 are not applicable.
2. There was infringement of right to privacy by the search of private documents and letters
which were not meant for public disclosure.
3. There was violation of Article 20(3) if any private unpublished document/ information
has been used in order to convict the Accused.

Any other order as it deems fit in the interest

of equity, justice and good conscience.

For this act of kindness, the appellant faction shall be duty bound forever.

(counsel for the petitioner/s)