We have been trying to incorporate the company established by us and it has been

incorporated and given with the ROC and then, a Writ of Certiorari has been initiated against
us by the NGO stating the objective of the company was illegal and thus, the incorporation of
the company was not valid and should be de registered. The company and the objective of the
company is no way illegal and even the establishment process also happened as per the Law.
The following clearly explains my contention:-

1. Online dating/ Mobile dating is not illegal in any ways:-

a. This website is not infringing any fundamental rights or constitutional rights in any
ways.

b. This is not encouraging anything related to prostitution.

c. This is similar to the already existing Platforms such as Tinder, Happn, Ok Cupid,
Badoo, etc. Which have been in operation in India since a very long time.

d. This platform is being brought only for the purpose of bringing in some satisfaction
among the lonely males and females who have been facing loneliness, depression and
are seeking a relationship with a person from other sex.

e. Online dating provided individuals with access to many more potential partners
than they could often find in their daily lives.

f. The main objective of the company identifies that it is “not to interfere with the
institution of marriage” but “to create a secure and anonymous space for people
seeking affairs outside their relationships. The company is mainly formed for dealing
with people who are lonely and awaiting for the companionship in their life.
g. All the males and females who are interested in registering themselves in our
website are seeking it and none of them are being forced or instigated in any ways by
our website directly or in any other indirect ways such as promoting it through agents
or representatives. All the users who registered themselves have done so out of their
sole interest and not due to any force or undue influence by us or our website.

h. Any person (Male/ Female) will get the right to choose the person whom he/ she
would like to go on a date or have a sexual relationship and the website has nothing to
force a person to get into a sexual relationship with any other person other than the
person he/ she selects.

i.The main criteria to be met for a person to register himself in our website is him/her
being a Major ( 18 years and above ) and there are no provisions in India that restrict a
person from being in such relationships.

j. This might be immoral but not illegal. None of the immoral activities like
consumption of liquor and smoking of cigarettes are illegal in India and there are
online platforms that authorize the sale of liquor, cigarettes, hookah pots, etc.
Unfortunately, the NGO has been looking at this beyond moral grounds.

k. This website is also a similar one and there is nothing wrong in providing such
services when it is not illegal.

l. This is a website that is providing a platform for the people who want to avail such
services and they are seeking such services with their consent and conscience.

m. Even a social networking platform such called Face book has planned to launch
Dating service vide an app or by integrating the same service into the existing social
networking app and this was officially announced by the CEO of Face book Mr.
Mark. And they've planned to launch it even in India which was not opposed by any
person on an NGO.

n. If our website is illegal, then all the other platforms such as Tinder, Happn, Ok
Cupid, Badoo, etc. should've also been illegal and should not have been granted
permissions to establish their platforms in India.

o. The Honourable Supreme Court of India in a recent case has given a judgement that
scraped off 150 year old law of adultery by quashing Section 497 which clearly states
that this is not a crime

p. Once a person is above 18 years, There is no legal provision that prohibits him/her
from dating, living in together or even a sexually active relationship. \

q. There is nothing wrong happening because of our platform ( at least legally even if
it is a sexual relationship ) as an adult in India have right to live life as per their wish
and there is nothing happening here without a person giving their consent.

r. If you want someone to talk to but are not ready to meet face-to-face, meeting
people online will let you start making connections from the comfort of your own
home.

s. In December 2010, a New York State Law called the "Internet Dating Safety Act"
(S5180-A) went into effect that requires online dating sites with customers in New
York State to warn users not to disclose personal information to people they do not
know. The same concept is implemented by the websites and platforms even in India
and thus there will be no breach of any personal data either by the platform or by the
registered users of the platform.
 t. Dating websites are just one of many online platforms that can lead to a romantic
connection. Those who describe themselves as single and looking for a partner
comprise a relatively small segment of the online population that totals about 10
million people. They use the internet both as a roadmap for the offline world and as a
destination to meet people by marshalling things like search engines, email, and
instant messaging to connect with a romantic partner.

u. Online websites and mobile apps are not the only ways to get involved in such
relationships and people who are not interested in online dating but interested in
dating some random person to overcome their loneliness will find numerous ways
offline also to satisfy their desires.

v. Unlike bars, clubs, parks, restaurants, gyms, or other places you could meet
someone, our dating website has tons of safety features in place to protect their users.
These include 24/7 customer support, extensive help pages, SSL encryption
technology to prevent scammers from entering the site, moderators to remove fake
profiles, and buttons to block and report abusive members. Some sites will also verify
and/or do background checks on every member to prove they are who they say they
are.

w. we vizag infidelity pvt.ltd helps the people who need to find a date. Our company
recognises, it will be difficult to meet people with whom you share common interests
and goals within your geographical area, our company helps in finding matches with
compatible local men or women –whether you are looking for love in vizag.

x. At infidelity pvt.ltd privacy is the top priority. Your privacy is the core of the way
we design and build the services. We involve experts from various fields.

2. The company is not encouraging for demolishing or for disrespecting the concept or
institution of marriage in any ways specially through wide publicity.
3. None of the provisions of The Hindu Marriage Act, 1955 are being violated by the
objectives or the policies of the company.

4. During the establishment of the company, all the requirements set as per the Section 3 and
Section 7 of The Companies Act, 2013 have been satisfied and none of these provisions or
any other required provisions have been violated or neglected.

5. Thus, as per the points mentioned above, the incorporation of the company is completely
legal and this incorporation cannot be restricted in any ways as everything has happened as
prescribed by the provisions of The Companies Act, 2013 and thus, there should not be any
de registration of the company.

MY REPLY TO THE WRIT PETITION FILED:

In the petition, the petitioner has mentioned the following reasons to de-register my
company:

1. The company is illegal.

2. It is against the public policy.

3. Devastating consequences in terms of broken families and abandoned children.

4. It will promote divorces.

5. Reduction of moral fear.

6. It leads to Depression.

My reply to the above mentioned reasons in the writ petition:

1. My company is not illegal because we have registered our company according to law
and submitted all the required documents for the registration of the company
according to section 3 and section 7 of the companies act, 2013.
2. Even consumption of liquor and cigarettes are against public policy but based on this
reason none of the company’s manufacturing liquor and cigarettes are deregistered.
Moreover in this modern world dating and sexual relationship has become common
and according to our law people above 18 years cannot be restricted.

3. Dating is not solely based upon online platforms there are many ways available
offline, if a person wants to date. Even in such scenarios there are chances of broken
families and abandoned children, So you can’t blame only our company for that.
Moreover there are several other dating apps which are legal according to law.

4. Dating is not the only reason for divorce there. There are several other reasons which
instigate divorce and this is a very small part of it. Taking of divorce based on such
reasons will be dependent on the mindset of the people married.

5. Not everything which is morally wrong would become legally wrong in certain
scenarios. This though morally wrong, will not be legally wrong.

6. This will only help in reducing the mental strain which in turn helps in overcoming
the existing depression and in no ways this will put people into more depression.