B T H ' S C O K: Writ Jurisdiction

19TH NLIU Annual Freshers Moot Pool Tournament, 2019
19TH NLIU Annual Freshers Moot Pool Tournament, 2019 Team Code - 48
Team Code- 48
BEFORE THE HON’BLE SUPREME COURT OF KASHINDIA
WRIT JURISDICTION
UNDER ART. 32 OF CONSTITUTION OF KASHINDIA
NIPUNJ GOYAL SHRIVASTAVA AND ANR ...Petitioner(s)
v.
UNION OF INDIA ...Respondent
WRITTEN SUBMISSION FILED ON BEHALF OF THE PETITIONER
Memorial on behalf of Defendant

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TABLE OF CONTENTS
INDEX OF AUTHORITIES............................................................................................1
STATEMENT OF JURISDICTION.................................................................................2
STATEMENT OF FACTS..............................................................................................3
ISSUES FOR CONSIDERATION...................................................................................4
Issue No.1.....................................................................................................................................4
Whether Article 370 is a temporary provision?...........................................................................4
Issue No.2.....................................................................................................................................4
Whether the state of J&K has a right to unilaterally secede from Kashindia?............................4
SUMMARY OF ARGUMENTS......................................................................................5
Issue No.1.....................................................................................................................................5
Issue No.2.....................................................................................................................................5
Whether the state of J&K has a right to unilaterally secede from Kashindia?............................5
ARGUMENTS ADVANCED..........................................................................................7

1.1. The purpose, headnote and text of Article 370 and the constitution all emphasize the
temporary nature.............................................................................................................7
1.2. Article 370 does not come under basic structure of the Kashindian constitution.............7
1.3. The non-existence of constituent assembly of J&K does not make Art. 370 permanent..8
1.4. The president of Kashindia can issue an order making the article inoperative or abrogate
it.......................................................................................................................................8
Whether the state of J&K has a right to unilaterally secede from Kashindia?..........................10
2.1. There exists a right to secede under international law....................................................10
2.2. Secession is a possibility under Kashindian legal framework........................................11
2.3. The right to secede is applicable in case of J&K and the secession is justified..............11
Memorial on behalf of Petitioner

Team Code- 48
2.4. That the agreement between J&K and Kashindia is breached and Pacta Sunt Servanda
maxim of the international law shall apply...................................................................13
2.5. The integration of J&K to the Kashindian union was never actually completed............13
PRAYER....................................................................................................................15
Memorial on behalf of Petitioner

INDEX OF AUTHORITIES
Cases
In Re: The Berubari Union and Exchange of Enclaves v Reference under Article 143(1) of the
Constitution of India (1960) 3 SCR 250....................................................................................12
Kesavananda Bharati vs. State of Kerala (1973) 4 SCC 225..........................................................8
Mohd Maqbool Damnoo v. State Of J&K (1972) 1 SCC 536.........................................................9
R Ganpatrao v. Union of India (1993) 1 SCR 480..........................................................................8
State Bank of India Vs. Santosh Gupta and. Anr. (2017) 2 SCC 538..............................................9
Statutes
Jammu and Kashmir Public Safety Act (PSA) 1978.....................................................................14

The Constitution of India. (1950)..................................................................................................12
The Constitution of Jammu & Kashmir. (1957)............................................................................13
Treatises
United Nations, Charter of the United Nations, 24 October 1945, 1 UNTS XVI, available at:
https://www.refworld.org/docid/3ae6b3930.html [accessed 2 November 2019]......................11
Books
Webb, M. (2012). Kashmir's Right to Secede. 1st ed. Hoboken: Taylor & amp...........................11
Other Sources
Icj-cij.org. (2010). Advisory opinion of 22 july 2010. [online] Available at: https://www.icj-
cij.org/files/case-related/141/141-20100722-ADV-01-00-EN.pdf [Accessed 3 Nov. 2019]....11
Reports
UN High Commissioner for Human Rights. (2019). Update of the Situation of Human Rights in
Indian-Administered Kashmir and Pakistan-Administered Kashmir fromMay 2018 to April
2019. [online] Available at:
Page 1 of 21 Memorial on behalf of Petitioner

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https://www.ohchr.org/Documents/Countries/PK/KashmirUpdateReport_8July2019.pdf
[Accessed 3 Nov. 2019].............................................................................................................13
Journals
Wehberg, H. (1959). Pacta Sunt Servanda. The American Journal of International Law, 53(4),
pp.775-786.................................................................................................................................15

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STATEMENT OF JURISDICTION
The Petitioner humbly submits to this Hon’ble Supreme Court of Kashindia as per power to
adjudicate upon this case by the virtue of Article 32 of the Constitution of Kashindia. Article 32
read as under.
Article 32 in The Constitution of Kashindia
32. Remedies for enforcement of rights conferred by this Part
(1) The right to move the Supreme Court by appropriate proceedings for the enforcement of the
rights conferred by this Part is guaranteed
(2) The Supreme Court shall have power to issue directions or orders or writs, including writs
in the nature of habeas corpus, mandamus, prohibition, quo warranto and certiorari, whichever
may be appropriate, for the enforcement of any of the rights conferred by this Part
(3) Without prejudice to the powers conferred on the Supreme Court by clause ( 1 ) and ( 2 ),
Parliament may by law empower any other court to exercise within the local limits of its
jurisdiction all or any of the powers exercisable by the Supreme Court under clause ( 2 )
(4) The right guaranteed by this article shall not be suspended except as otherwise provided for
by this Constitution

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STATEMENT OF FACTS
Historical Background
Kashindia gained independence in 1947 from the Zamindari empire and partitioned into
Kashindia and Nigamistan. Kashindian constitution is quasi-federal in nature to uphold
and actualize values of national unity, regional autonomy, cultural diversity, democracy
and rapid socio-economic growth. Supreme court of Kashindia is the final interpreter of
the constitution and custodian of basic civil rights and liberties of its citizens.
State of Jacoob and Kartishkir (hereon referred to as J&K) is in an important strategic
location was previously an independent princely state under Maharaja Jazz Singh who
agreed to accede to Kashindia after facing invasion from Nigamistan. The state still faces
militancy and insurgency sponsored by Nigamistan. The instrument of accession was
signed and the schedule appended to the instrument gave Kashindia power to legislate on
the matters of Defence, External Affairs and Communications. The terms of Instrument
of Accession were incorporated in the constitution of India through Article 370 which
allowed J&K substantial autonomy in internal affairs and have its own constitution which
J&K adopted in 1956.
In 1954, Article 35A was introduced in Kashindian constitution through a Presidential

Order which enabled legislature of J&K to define who are the permanent residents of
J&K and to confer special rights and duties to them.
Current Situation
The Petitioner Nipunj Goyal Shrivastava is a resident of the state who, along with
Rajtiwari Sarvagya Sood (RSS), a NGO, has challenged the constitutional validity and
nature of both the provisions in Supreme court of India. The petitioners also contend that
Article 35A is violative of Fundamental right to equality. The question whether J&K can
unilaterally secede from Kashindia is also up for discussion.

Team Code- 48
ISSUES FOR CONSIDERATION
Issue No.1
Whether Article 370 is a temporary provision?
Issue No.2
Whether the state of J&K has a right to unilaterally secede from Kashindia?

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SUMMARY OF ARGUMENTS
Issue No.1
The counsel submits that the object of Article 370, which was to govern the constitutional
relationship between the Kashindia and the State of Jacoob and Kartishkir till the enactment of a
Constitution for the State, was fulfilled on the day the Constitution of J&K was enacted.
Therefore, to consider that Article 370 has become a permanent feature of the Constitution which
cannot be abrogated by any means would be fallacious. The constitution is an organic statute. it
grows by its own inherent force and therefore constitutional provisions are couched in elastic
terms. any constitution, howsoever rigid it may be, has a provision for an amending power, along
with procedure. The counsel also submits that even a literal interpretation of Article 370,
combined with headnote and background of existence elucidate its temporary nature.
Furthermore, it is humbly contended that the provisions of the constitution should be given an
interpretation which prevents their fossilization and gives dynamic meaning to them so that they
can meet the ever-evolving needs and challenges. One cannot assume that Article 370(3) cannot
be given effect to merely because the Constituent Assembly of J&K cannot be revived. That
would make a part of the constitution immune to amendment, such immunity is only allowed to
what constitutes basic structure and article 370 as has been decided, is just a reflection of
Instrument of Accession in the Kashindian constitution and cannot be part of the basic structure.
Issue No.2
The counsel for petitioner submits that there exists a right under international law of secession
which allows a state to unilaterally secede from a parent state, this right is a subset of right to
self-determination provided in the UN Charter. Such right is applicable to the state of J&K as it

Team Code- 48
fulfils the requisites established. Moreover, the petitioner also contends that article 370 was
essentially reflection of a contract between two states, and since the said contract was effectively
breached, the temporary article 370 should be removed and the state of J&K be restored to its
previous status in accordance with the international law maxim of Punctus Sunt Servanda.
The counsel submits that the situation has reached a point of no turning back because of the
frequent human right violations in the form of Illegal detentions, use of torture, frequent
suspension of communications and even rape, and remedial secession is necessitated.

Team Code- 48
ARGUMENTS ADVANCED
Issue No.1
The counsel for petitioner submits that Article 370 is a temporary provision which can be
abrogated by a presidential order on the following grounds:
1.1. The purpose, headnote and text of Article 370 and the constitution all emphasize the
temporary nature.
The petitioner submits that in Kashindia’s acceptance of the Instrument of Accession of J&K ,
Governor-General clearly stated that “it is my Government’s wish that as soon as law and order
have been restored in J&K and her soil is cleared of the invader, the question of the State’s
accession be settled by a reference to the people”. Thus, Kashindia regarded accession as purely
temporary and provisional till the time a plebiscite was conducted.
Further, the counsel submits that strict interpretation of Part XXI of the constitution of the
Kashindia0 in which Article 370 is present says that the part contains “temporary transitional
and special provisions” of the constitution and the marginal notes says that it contains
“Temporary provisions with respect to the state of J&K” will allow the hon’ble court to reach
the clear conclusion that article 370 was always meant to be temporary.
1.2. Article 370 does not come under basic structure of the Kashindian constitution.
It is submitted that Article 370 cannot possibly come under basic structure of the Indian
constitution, the headnote itself regards it as a temporary provision and the existence of article
itself was supposed to be till the point that constituent assembly of J&K could frame the
0
The Constitution of India. (1950)

Team Code- 48
constitution. Reliance is placed on R Ganpatrao v. Union of India0 where the Petitioners in

Ganpatrao were rulers of some of the erstwhile princely states, who had relinquished their
powers and joined the Indian Dominion by signing Instruments of Accession and Instruments of
Merger, much like in the case of J&K’s accession. Their contention was that Instrument of
Accession and terms was part of the basic structure as without the instruments, there would be no
union of India. The bench in Ganpatrao though rejected the above argument and held that the
provisions did not form part of the basic features. One of the primary reasons cited for this
conclusion was that the accession was inevitable, even if the rulers of the princely states wished
otherwise. Applying the ratio to the present situation, the petitioner submits that since Article
370 is essentially a reflection of the instrument of accession, it does not constitute basic structure
of the Kashindian constitution and consequentially is not permanent, as propounded in
Kesavananda Bharati0 case.
1.3. The non-existence of constituent assembly of J&K does not make Art. 370 permanent.
The petitioner submits that the constituent assembly of J&K was supposed to draft a constitution
for the State of J&K and determine the sphere of Union jurisdiction over the state. In 1956, the
Constitution of J&K came into being and thus was fulfilled the purpose for the very existence of
the Constituent Assembly of J&K. Having fulfilled its purpose and having embodied its
intentions in the Constitution, the CA dissolved in 1957, albeit without recommending anything
with respect to the Article 370 so it can be implied that constituent assembly of J&K wanted the
implementation of the article only till the date the constitution of J&K comes into effect which is
in consonance with the origin and nature of Article 370. In fact, if there was any intention of
constituent assembly to make Article 370 permanent then why was there no effort on their part
during the numerous years of existence of the assembly to make it so.
0
R Ganpatrao v. Union of India (1993) 1 SCR 480
0
Kesavananda Bharati vs. State of Kerala (1973) 4 SCC 225.

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1.4. The president of Kashindia can issue an order making the article inoperative or
abrogate it.
The petitioner humbly submits that the impugned article can be abrogated through a presidential
order even in absence of either the constituent or a legislative assembly in J&K. The Supreme
Court of Kashindia in Santosh Gupta0 declared that after the dissolution of the Constituent
Assembly, an order under Article 370(3) can be made with the concurrence of the “State
Government”. This must be seen in consonance with the Presidential Order of 1954 extending
Emergency Provisions under Articles 356 and 357 of the Constitution of India to Jammu and
Kashmir.
After establishing that the consent of state government is required, the counsel submits that
Governor of state of J&K can be considered state. President’s Rule under Article 356 runs
concurrently with Governor’s Rule under Section 92 of the Constitution of J&K. Section 92
allows for far more expansive powers to the Governor: under Section 92(1)(a), the Governor
may assume to himself all or any of the functions of the Government of the State and hence can
provide the consent needed to abrogate the article. As noted by the judgment in Santosh Gupta,
the powers “modify” under Article 370(1) have to be given “the widest possible amplitude” and
not a restrictive meaning. This would imply that the President by order would also have the
power to amend Article 370 itself. This is also evident from the scheme of the article. Sub-
Clause (3) of Article 370, which applies “notwithstanding” anything in the foregoing provisions
expressly notes that “this Article (i.e. Article 370), shall cease to be operative or be operative
with “exceptions and modifications” by an order of the President. Further, A 5 judge bench in
Mohd Maqbool Damnoo v. State Of J&K 0 clearly states it that governor is equally and similarly
liable to give concurrence on behalf of state of j and k as were the power with ‘sadr e riyasat’ so
by this we can state that article 370 can be amended by the president with the concurrence of the
governor of the state, this is because governor is the successor of the ‘sadr e riyasat’ and he holds
all the power that ‘sadr e riyasat’ had. Hence, the petitioner concludes that Article 370 can be
abrogated by a Presidential Order.
0
State Bank of India Vs. Santosh Gupta and. Anr. (2017) 2 SCC 538.
0
Mohd Maqbool Damnoo v. State Of J&K (1972) 1 SCC 536

Team Code- 48

Team Code- 48
Issue No.2
The counsel for the petitioner contends that J&K does have a right to secede unilaterally from
Kashindia0 and presents the following arguments in support of the contention.
2.1. There exists a right to secede under international law.
Secession is allowed in an extreme scenario under the right to self-determination, which was
included in the United Nations (UN) Charter. Article 1(2) of the UN Charter 0 provides that one
of its purposes and principles is
“to develop friendly relations among nations based on respect for the principle of equal rights
and self-determination of peoples, and to take other appropriate measures to strengthen universal
peace.”
Similarly, Article 55 of the UN Charter contains provisions
“with a view to the creation of conditions of stability and well-being which are necessary for
peaceful and friendly relations among nations based on respect for the principle of equal rights
and self-determination of peoples.”
The counsel submits that current situation in J&K calls for Remedial secession. It is a remedy to
the varying degrees of oppression inflicted upon a particular group by its governing State.
International law recognizes a continuum of remedies ranging of protection of individual rights
and ending with secession as the ultimate remedy. The same has been previously expounded by
International Court of Justice in its Advisory Opinion on Kosovo 0to argue in favor of Kosovar
secession and independence, based on the argument that international law embraced a principle
of remedial secession/external self-determination in instances of severe oppression by the mother
state.
0
Webb, M. (2012). Kashmir's Right to Secede. 1st ed. Hoboken: Taylor & amp.
0
United Nations, Charter of the United Nations, 24 October 1945, 1 UNTS XVI, available at:
https://www.refworld.org/docid/3ae6b3930.html [accessed 2 November 2019]
0
Icj-cij.org. (2010). Advisory opinion of 22 july 2010. [online] Available at: https://www.icj-cij.org/files/case-
related/141/141-20100722-ADV-01-00-EN.pdf [Accessed 3 Nov. 2019].

Team Code- 48
2.2. Secession is a possibility under Kashindian legal framework.
The counsel submits that the Supreme Court of Kashindia when confronted with a situation of
cession of parts of territory and its validity under the Constitution in the matter of In Re: The
Berubari Union and Exchange of Enclaves v Reference under Article 143(1) of the Constitution
of India (1960)0 has answered it in the affirmative.
While dealing with the specific issue before it, the Court made certain important observations
that are relevant for understanding the right to self-determination leading to the secession of parts
of the territory. It was argued before the Court in the Berubari case that “even Parliament has no
power to cede any part of the territory of India in favour of a foreign State either by ordinary
legislation or even by the amendment of the Constitution0.” The supreme court held that
“..if the power to acquire foreign territory which is an essential attribute of sovereignty is not
expressly conferred by the Constitution there is no reason why the power to cede a part of the
national territory, which is also an essential attribute of sovereignty, should have been provided
for by the Constitution. Both of these essential attributes of sovereignty are outside the
Constitution and can be exercised by India as a sovereign State.”
In the instant issue, even though there is no constitutional mechanism for secession, that does not
imply that it cannot be allowed under Kashindian state in the exercise of their own sovereignty
within their legal framework.
2.3. The right to secede is applicable in case of J&K and the secession is justified.
According to Principle VIII of the Helsinki Declaration of Principles which states that
0
In Re: The Berubari Union and Exchange of Enclaves v Reference under Article 143(1) of the Constitution of
India (1960) 3 SCR 250
0
The Constitution of India. (1950)

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“By virtue of the principle of equal rights and self-determination of people all peoples always
have the right in full freedom to determine when and as they wish, their “internal and external
political status, without external political interference and to pursue as they wish their political,
economic, social and cultural developments.”
The counsel submits that people of J&K do not have that freedom, their constitution is held to be
sub-ordinate to Kashindian constitution0, they cannot determine their own political status and
there is ample Kashindian interference which includes but is not limited to jailing of voices of
dissent. They cannot pursue their own developmental goals successfully either and hence the
right to self-determination and consequentially secession is applicable to the state of J&K.
The counsel for petitioner submits that there are rampant violation of human rights in J&K by
Kashindian authorities. The report by the Office of the UN High Commissioner for Human
Rights (OHCHR)0, released on July 8, 2019, raises serious concerns about abuses by state
security forces and armed groups in both Kashindian and Nigamistan-held parts of Kartishkir. It
mentions that around 160 civilians were killed in 2018, which is believed to be the highest
number in over one decade. Last year also registered the highest number of conflict-related
casualties since 2008 with 586 people killed including 267 members of armed groups and 159
security forces personnel. According to JKCCS, 1,081 civilians have been killed by security
forces in extrajudicial killings between 2008 and 2018. Further, according to information from
Srinagar’s Shri Maharaja Hari Singh Hospital, where most pellet shotgun injured are treated,
1,253 people have been blinded by the metal pellets used by security forces from mid-2016 to
end of 2018. 0
It is well recognized that in order to justify secession is the serious violation of Human Rights.
To determine severity of violation of human rights, examination of the extent to which it suffers
‘subjugation and exploitation’ is necessary and the same has been well established above, and
justifies J&K’s secession from Kashindia.
0
The Constitution of Jammu & Kashmir. (1957).
0
UN High Commissioner for Human Rights. (2019). Update of the Situation of Human Rights in Indian-
Administered Kashmir and Pakistan-Administered Kashmir fromMay 2018 to April 2019. [online] Available at:
https://www.ohchr.org/Documents/Countries/PK/KashmirUpdateReport_8July2019.pdf [Accessed 3 Nov. 2019].
0

Team Code- 48
Authorities have also continued to use various forms of arbitrary detention to target protesters,
political dissidents and other civil society actors. A number of laws in Jammu and Kashmir
provide the legal basis for arbitrary detention, but the one that is used most frequently to stifle
protests and political dissent is the Jammu and Kashmir Public Safety Act (PSA) 1978. The PSA
does not provide for a judicial review of detention, and state authorities have defied orders by the
Jammu and Kashmir High Court to release people detained under this law by issuing successive
detention orders.
2.4. That the agreement between J&K and Kashindia is breached and Puncta Sunt
Servanda maxim of the international law shall apply.
The counsel submits that the frequent use of presidential orders – allowed under Article 370 – to
extend the writ of the centre to Jammu and Kashmir has considerably weakened Article 370 in
the Constitution. To change the provision (in the J&K Constitution) of the governor being
elected by the state assembly, Article 370 was used to convert the position into a nominee of the
President. Similarly Article 249, i.e., the power of Parliament to make laws on entries in the state
list, was extended to Jammu and Kashmir without a resolution by the state assembly. This is
tantamount to breach of the terms of instrument of accession. Coupled with the fact that
accession was contingent to a plebiscite being held and the fate of J&K was to be decided by the
voice of the people and such a plebiscite was never held, hence the Instrument of Accession
between J&K stands breached. And the maxim under international law which governs contracts
or treaties between states is Pacta Sunt Servanda, i.e., promises between states must be
honoured. If there is a breach of contract, the general rule is that parties are to be restored to the
original position, i.e., the pre-agreement status.0 The pre-agreement status of J&K was that of an
independent princely state and as after the breach, the counsel submits that they should revert
back to their independent status.
2.5. The integration of J&K to the Kashindian union was never actually completed
It is humbly submitted that the integration of any princely state with Union of Kashindia was a
two-fold process, requiring both Instrument of Accession and merger, the latter was never
0
Wehberg, H. (1959). Pacta Sunt Servanda. The American Journal of International Law, 53(4), pp.775-786.

Team Code- 48
completed. The process of integration included merger of these princely states and their
subsequent democratisation. While some of the princely states eventually signed an Instrument
of Merger to form larger administrative units, the same was not done by J&K. Due to the unique
circumstances, it was supposed to be formalised through the plebiscite, and since the plebiscite
never happened, it is contended that the integration itself is incomplete.

Team Code- 48
PRAYER
In light of the issues raised, arguments advanced and authorities cited, this Hon’ble Court may
please to adjudge, hold, direct and declare that,
i. Declare that Article 370 was a temporary provision which has fulfilled its object and can
be made inoperative/abrogated.
ii. Hold that J&K constitutes a sovereign state which has a right to secede unilaterally from
Union of Kashindia.
iii. Direct that a referendum must be held in the state of J&K regarding the said secession
and all use of force against secessionists must cease with immediate effect.
Or to grant any other relief that this Hon’ble Court may deem fit in the interest of justice, equity
and good conscience.
And for this act of kindness the Petitioners shall forever be duty bound.
Sd/-
Counsels on behalf of Petitioner

B T H ' S C O K: Writ Jurisdiction

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19TH NLIU Annual Freshers Moot Pool Tournament, 2019

BEFORE THE HON’BLE SUPREME COURT OF KASHINDIA

UNDER ART. 32 OF CONSTITUTION OF KASHINDIA

NIPUNJ GOYAL SHRIVASTAVA AND ANR ...Petitioner(s)

UNION OF INDIA ...Respondent

WRITTEN SUBMISSION FILED ON BEHALF OF THE PETITIONER

Memorial on behalf of Defendant

ISSUES FOR CONSIDERATION...................................................................................4

Whether Article 370 is a temporary provision?...........................................................................7

Memorial on behalf of Petitioner

Memorial on behalf of Petitioner

Jammu and Kashmir Public Safety Act (PSA) 1978.....................................................................14

Page 1 of 21 Memorial on behalf of Petitioner

Page 2 of 17 Memorial on behalf of Petitioner

Article 32 in The Constitution of Kashindia

32. Remedies for enforcement of rights conferred by this Part

Page 3 of 17 Memorial on behalf of Petitioner

In 1954, Article 35A was introduced in Kashindian constitution through a Presidential

Page 4 of 17 Memorial on behalf of Petitioner

ISSUES FOR CONSIDERATION

Whether Article 370 is a temporary provision?

Page 5 of 17 Memorial on behalf of Petitioner

Whether Article 370 is a temporary provision?

Page 6 of 17 Memorial on behalf of Petitioner

Page 7 of 17 Memorial on behalf of Petitioner

Whether Article 370 is a temporary provision?

Page 8 of 17 Memorial on behalf of Petitioner

constitution. Reliance is placed on R Ganpatrao v. Union of India0 where the Petitioners in

Page 9 of 17 Memorial on behalf of Petitioner

Page 10 of 17 Memorial on behalf of Petitioner

Page 11 of 17 Memorial on behalf of Petitioner

2.1. There exists a right to secede under international law.

Similarly, Article 55 of the UN Charter contains provisions

Page 12 of 17 Memorial on behalf of Petitioner

2.2. Secession is a possibility under Kashindian legal framework.

Page 13 of 17 Memorial on behalf of Petitioner

Page 14 of 17 Memorial on behalf of Petitioner

Page 15 of 17 Memorial on behalf of Petitioner

Page 16 of 17 Memorial on behalf of Petitioner

Counsels on behalf of Petitioner

Page 17 of 17 Memorial on behalf of Petitioner

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