TEAM CODE -

H.R.S.P.M’S SARSENAPATI HAMBIRRAO MOHITE LAW COLLEGE, RAJGURUNAGAR

IN THE HON’BLE SUPREME COURT OF INDIYANA UNDER ARTICLE 32

OF THE CONSTITUTION OF INDIAYANA, 1950

IN THE MATTER OF

ARTICLE 2, 3, 367, 370, 35 A OF THE CONSTITUTION OF INDIAYANA, 1950

WRIT PETITION NO.________/2020

REPUBLIC GROUP OF PEOPLE…………………………………….PETITIONER

V.

UNION OF INDIYANA………………………………..…………………RESPONDENT

BEFORE SUBMISSION TO THE HON’BLE CHIEF JUSTICE AND HIS

COMPANION JUSTICES OF THE

HON’BLE SUPREME COURT OF INDIYANA

MEMORIAL ON BEHALF OF THE RESPONDENT

Name of the College: Yashwantrao Chavan Law College, Parvati, Pune-09

Name of the Participants: 1) Kshitija Jadhav
2) Vasundhara Rathod
3) Kaustubh Patil
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CONTENTS

LIST OF ABBREVIATIONS................................................................................................3

INDEX OF AUTHORITIES..................................................................................................4

[A] Case Laws........................................................................................................................4

[B] Statutes.............................................................................................................................4

STATEMENT OF JURISDICTION......................................................................................5

STATEMENT OF FACTS.....................................................................................................6

STATEMENT OF ISSUES....................................................................................................7

SUMMARY OF ARGUMENTS...........................................................................................8

ARGUMENTS ADVANCED ...............................................................................................9

PRAYER..............................................................................................................................19

BIBLIOGRAPHY................................................................................................................20

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LIST OF ABBREVIATIONS

& And

A.I.R. All India Reporter

ARA Ashmir Reorganisation Act

DSI Democratic society of Indiana

J&K Jammu And Kashmir

Ors. Others

r/w Read With

S.C. SC

Sec. Section

UT Union Territory

u/a Under Article

v. Versus

INDEX OF AUTHORITIES

[A] Case Laws

1. JANATA DAL v. H. S. CHAUDHARY [(1992) 4 SCC 305]

2. G. C. COLLEGE, SILCHAR v. GAUHATI UNIVESITY [AIR 1973 SC 761]

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3. B. SINGH v. UNION OF INDIA [AIR 2004 SC 1923]

4. SAMPAT PRAKASH v. STATE OF J & K [AIR 1970 SC 1118 (1121-22)]
5. MOHD. MAQBOOL DAMNOO v. STATE OF J & K [AIR 1972 SC 963]
6. KESAVANAND BHARATI v. STATE OF KERALA [AIR 1973 SC 1461]
7. STATE OF JAMMU AND KASHMIR V. DR. SUSHEELA SAWHNEY [AIR 2003
J&K 83: 2003 (4) IND LD 217],
8. DEVI DAS V. PANNA LAL [AIR 1959 J&K 62]
9. PRAKASH V. MST. SHAHNI [AIR 1965 J&K 83: 1965 KASH LJ 85]

[B] Statutes

THE CONSTITUTION OF INDIA, 1950

THE CONSTITUTION OF J & K, 1956

THE CONSTITUTIONS (APPLICATION TO J & K) ORDER, 1954

THE CONSTITUTIONS (APPLICATION TO J & K) ORDER, 2019

THE JAMMU AND KASHMIR REORGANISATION BILL, 2019

STATEMENT OF JURISDICTION

The Hon’ble SC of Indiana has jurisdiction to hear the instant matter under Art. 32 of the
Constitution of Indiyana.

The present memorandum sets forth the facts, contentions and arguments.

Art. 32 of the Constitution of Indiyana reads as:

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Remedies for enforcement of rights conferred by this Part.-

“(1) The right to move the SC by appropriate proceedings for the enforcement of the
rights conferred by this Part is guaranteed.

(2) The SC 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 SC by clauses (1) and (2),
parliament may by law empowered any other court to exercise within the local limits
of its jurisdiction all or any of the powers exercisable by the SC under clause (2).

(4) The right guaranteed by this Art.Shall not be suspended except as otherwise
provided for by this constitution.”

STATEMENT OF FACTS

1. On 26th Oct. 1947 by instrument of accession state of Bshmir was included into union
of Indiyana. Mohammad Ali Seena opposed said instrument of accession, so all
political leaders comes together and made “Shahajahanabad Agreement, 1952” which

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decide terms and conditions of instrument of Accession, same introduced in Article

370 of Indiyana Constitution.
2. By Article 370 “Temporary, Transitional and Special provisions” was made for state
of Bshmir by 1954th Presidential order.
3. On 14th May, 1954 Article 35 A was introduced for State of Bshmir and thereby rights
permanent residents was given to State of Bshmir.
4. On 5th Aug. 2019, Presidential Order issued and removed Article 370 and Article 35A
thereafter all of Indiyana Constitution are to applied to the State of Bshmir without
any Special Provision.
5. This would imply that state of Bashmir’s separate constitution stands inoperative,
including the privileges sanctioned by Article 35 A.
6. Republic Group Of People renowned NGO have filed Writ Petition in Supreme Court
of Indiyana Under Article 32 of the Indiyana Constitution and inherently
unconstitutional. The Petition has been admitted the Hon’ble Supreme Court and
matter is now put for Final Hearing.

STATEMENT OF ISSUES

1. Whether the Petitioner has a locus standi to file this Petition or not?

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2. Whether the recommendation of the Governor of State of Bshmir amounts to the

violation of Art. 370 or not?

3. Whether Omission of Article 35A is constitutionally valid or not?

SUMMARY OF ARGUMENTS

ISSUE 1:- Whether, the Petitioner has a locus standi to file this petition or not?

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No, as there is no violation of fundamental rights, the petitioner cannot have locus standi to
file this writ petition.

ISSUE 2:- Whether the recommendation of the Governor of State of Bshmir amounts to
the violation of Art. 370 or not?

No, though there is presidential rule imposed in State of Bshmir, the recommendation of the
Governor of State of Bshmir, does not amounts to the violation of Art. 370

ISSUE 3:- Whether omission of article 35 A is constitutionally valid or not?

Article 35 A, inter alia, empowers Jammu and Kashmir State Legislature to confer special
rights and privileges on permanent residents in matters of employment under the state
government. Under the state laws only permanent residents of the State can be appointed to
post under the State Government and exclusion of non permanent residents does not violet
their fundamental rights to equality guaranteed under the Constitution.

ARGUMENTS ADVANCED

ISSUE 1:- Whether, the Petitioner has a locus standi to file this petition or not?

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No, as there is no violation of fundamental rights, the petitioner cannot have locus standi to
file this writ petition.

What is locus standi?

1. Art. 32 does not prescribe the persons or classes of persons who can invoke the SC
jurisdiction for the redressal of their grievances. The matter of ‘standing’ thus lies within the
realm of the SC.

The general principal is that a person whose fundamental right has been infringed has locus
standi to move the SC u/a 32 for the enforcement of his right. The legal right to be enforced
u/a 32 must ordinarily be the right of petitioner himself. As rights are different and inhere in
different legal entities, it is not competent to a person to seek to enforce right to another
except when the law permits him to do so.

The liberal rule of Locus Standi might be misused by vested interests. So, in this case, the
court will not allowed the remedy to be abused.

JANATA DAL v. H. S. CHAUDHARY1

“These is an example where the Petitioner tried to abuse the Public Interest
Litigation for Political Purposes. The special judge dismissed the Petition on the
ground that the Petitioner had no Locus Standi. The SC by 4-1 majority held that the
Petitioner had no Locus Standi to file the Petition. The Petitioner have no Public
purpose in filing the Petition.”

B. SINGH v. UNION OF INDIA2

“The Court held that the PIL filed with reckless allegations and vitriolic statements
against judges and person whose names were under consideration for judgeship must
be sternly dealt with. The Petitioner is Busi Person seeking publicity and not
interested in the welfare of judicial system.”

G. C. COLLEGE, SILCHAR v. GAUHATI UNIVESITY3 [AIR 1973 SC 761]

1
Janata Dal V. H. S. Chaudhary [(1992) 4 Scc 305]
2
B. Singh V. Union Of India [Air 2004 Sc 1923]
3
G. C. College, Silchar V. Gauhati Univesity [Air 1973 Sc 761]

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“The legal right to be enforced u/a 32 must ordinarily be the right of the Petitioner
himself. As right are different and inhere in different legal entities, it is not competent
to a person to seek to enforce the rights of another except when the law permits him
to do so. This principle emanates from the theory that the remedy and the rights are
correlative and therefore, only a person whose own right is in jeopardy is entitle to
seek remedy.”

ISSUE 2:- Whether the recommendation of the Governor of State of Bshmir amounts to
the violation of Art. 370 or not?

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No, though there is presidential rule imposed in State of Bshmir, the recommendation of the
Governor of State of Bshmir, does not amounts to the violation of Art. 370.

370. Temporary provisions with respect to the State of Bshmir

(1) Notwithstanding anything contained in this Constitution,—

(b) The power of Parliament to make laws for the said state shall be limited to—

(I) those matters in the Union List and the Concurrent List which, in consultation with

the Government of the State, are declared by the President to correspond to matters specified
in the Instrument of Accession governing the accession of the State to the Dominion of
Indiana as the matters with respect to which the Dominion Legislature may make laws for
that State; and

(ii) Such other matters in the said Lists as, with the concurrence of the Government of the
State, the President may by order specify.

(d) Such of the other provisions of this Constitution shall apply in relation to that State
subject to such exceptions and modifications as the President may by order specify:

Provided that no such order which relates to the matters specified in the Instrument of
Accession of the State referred to in paragraph (I) of sub-clause (b) shall be issued except in
consultation with the Government of the State:

Provided further that no such order which relates to matters other than those referred to in the
last preceding proviso shall be issued except with the concurrence of that Government.

(2) If the concurrence of the Government of the State referred to in paragraph (ii) of sub-
clause (b) of clause (1) or in the second provision to sub-clause (d) of that clause be given
before the Constituent Assembly for the purpose of framing the Constitution of the State is
convened, it shall be placed before such Assembly for such decision as it may take thereon.

(3) Notwithstanding anything in the foregoing provisions of this Art., the President may, by
public notification, declare that this Article shall cease to be operative or shall be operative
only with such exceptions and modifications and from such date as he may specify:
Provided that the recommendation of the Constituent Assembly of the State referred to in
clause (2) shall be necessary before the President issues such a notification.

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Art. 370 (2) further provided that if the State Government gave its concurrence, as mentioned
above, before the convening of the state Constituent Assembly, “ it shall be placed before
such Assembly for such a decision as it may take on”. As the Constituent Assembly exist no
more, Art. 370(2) has exhausted itself.

Art. 370(1) (d) lays down that the other provisions of the constitution, besides above can be
applied to the state with or without modifications by order of the President. Such an order is
not to be issued by the President:

(1) Without consulting the state government if matters to be specified in an order

relate to those mentioned in the instrument of Accession.
(2) Without the concurrence of the State Government if the matters to the specified in
the order relate to matters other than those mentioned in the instrument.

Sec. 5 of Constitution of State of Bshmir states that:

The executive and legislative power of the State extends to all matters except those with
respect to which Parliament has power to make laws for the State under the provisions of the
Constitution of Indiyana.

Executive Power of the State vested in the Governor and is exercised by him on the aid and
advice of a Council of Minister except in a matters of appointment of Minister and Deputy
Minister while issuing a proclamation under Sec. 92 in a breakdown of a constitutional
machinery in the State.

Art. 163: Council of Ministers to aid and advice Governor

(1) There shall be a council of Ministers with the chief Minister at the head to aid and advise
the Governor in the exercise of his functions, except in so far as he is by or under this
constitution required to exercise his functions or any of them in his discretion

(2) If any question arises whether any matter is or is not a matter as respects which the
Governor is by or under this Constitution required to act in his discretion, the decision of the
Governor in his discretion shall be final, and the validity of anything done by the Governor
shall not be called in question on the ground that he ought or ought not to have acted in his
discretion

(3) The question whether any, and if so what, advice was tendered by Ministers to the
Governor shall not be inquired into in any court.

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Salient Features of Art. 370:

Art. 370 stipulates the special status of Bshmir state as under:

1. The application of provisions of the Indiyana Constitution and Parliament’s

Legislative power over the state is restricted to 3 subjects namely defence, foreign
affairs and communications. However, the President has the power to extend to the
state such other provisions of the Indiyana Constitution and laws relating to the
matters specified in the instrument of accession. This only requires consultation with
the state government since the state has already accepted them as a part of instrument
of accession.
2. The other Constitutional provisions or other Union Powers which do not fall within
the ambit of the instrument of accession can be extended to the state only with the
prior concurrence of the state government.
3. The concurrence given by the state government has to be ratified by the states
constituent assembly. Art.370 (2) reads “if the concurrence of the government of the
state the given before the constituent assembly for the purpose of framing the
constitution of the state is convened, it shall be placed before such assembly for such
a decision as it may take thereon”. The constituent assembly exist no more or any
mentioned of it as an ongoing constitutional authority has become redundant.
4. Art. 370 (3) empowers the president to make an order abrogating or amending it. For
these purpose the Recommendation of the State’s constituent assembly shall be
necessary before the president issues a notification.
5. Under Art. 368 (3), there is a proviso which says that no constitutional amendment
shall have effect in a relation to the state of Bshmir unless applied by the order of the
president under clause (1) of Art. 370 which requires the concurrence of the state
government and ratification by the constituent assembly. The ‘concurrence’ factor
suggest that the Bshmir State had agreed to increasingly fall in line with the
provisions of the constitution of Indiyana as is evident from the order of 1954 and its
subsequent amendment

Status of Art. 370: temporary versus special

Art. 370 were placed in a constitution of Indiyana in a part XXI called “Temporary and
Transitional Provisions”. The headnote to Art. 370 are titled as “Temporary Provisions
with a respect to the State of Bshmir”.

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An important issue which needs discussion is whether governor has a power to give a
concurrence for extending a particular provision of the constitution of Indiyana in
the absence of popular government in the state. Such a situation may arise when the
state of Bshmir is brought under Governor/ President’s rule under sec. 92 of the state
constitution or under Art. 356 of the constitution of Indiyana.

Art. 370(1) (b) (ii) provides that the power of parliament to make a laws for the state of
Bshmir shall be limited to such other matters in the union and concurrent lists, as with the
concurrence of the government of the state, the President may by order specify.

The State of Bshmir was under Governor’s Rule in 1986 and Art. 249 was extended to the
state by the constitution (Application to Bshmir) Amendment Order, 1986. These order
was issued with the concurrence of the Governor as there was no council of Ministers to
Aid and advise him. Thus, the action of the President issuing an order under Artcle370
with the concurrence of the Governor in the absence of popular government was
constitutionally valid.

The constituent assembly of the state exists no more as it to dissolve after completing the
task of framing the constitution.

The important question which needs thoughtful consideration is the power and
competence of Indian parliament to amend Art. 370. The power of the Indiyana
Parliament to amend the constitution and the procedure thereof is a laid down in anArt.
368. Art. 368 in its application to the state of Bshmir mandates that no constitutional
amendment shall have effect in a relation to the state of Bshmir unless applied by the
order of President under Art. 370 which requires the ‘concurrence of’ or ‘consultation
with’ the state government and ratification by the constituent assembly. Therefore, if any
modification is to be made in Art. 370, the parliament will have to take a recourse to Art.
368. Similarly, the parliament cannot unilaterally amend or abrogate Art. 370 and destroy
the mechanism envisaged in these Art.for the extension of central laws and constitutional
provisions to the state of Bshmir. Such a state on the part of Parliament will be subject to
the concurrence of the state government and further ratification by the state legislature.

Erosion of Art. 370: Instrument of Accession

A close Scrutiny of the provisions of Art. 370 r/w the clauses (4) and (7) of the
Instrument of Accession leads to the conclusion that the constitution provisions and the

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laws extended to the state with the concurrence of or in consultation with the state
government have become a part and parcel of the instrument of Accession. As the
Accession of the state to the Indiyana Union is complete, final and irrevocable so the
applicability of the constitutional provision and the central laws to the state is
constitutionally valid. Art. 370 was placed in the Indiyana constitution as the enabling
provision providing a full scope for the application and extension of central laws to the
state. These being a flexible arrangement under which the constitutional positions of the
state can be defined from time to time.

SAMPAT PRAKASH v. STATE OF J & K4[AIR 1970 SC 1118 (1121-22)]

“It was contended by the Petitioner that since Art. 370 was intended to be effective
until the constitution of the state was framed and the will of the people of Jammu and
Kashmir had been expressed and thereafter, this article must be held to have become
ineffective, so that the modification made by president in exercise of his powers under
that provision is subsequent to the enforcement of the constitution of the state would
be without any authority of law.”

MOHD. MAQBOOL DAMNOO v. STATE OF J & K 5[AIR 1972 SC 963]

“It can be concluded that in the absence of council of ministers, the Governor has the
powers to give concurrence for the application of central laws or any constitutional
provision to the state of J & K. What the State government is at a particular time must
be determined in the context of the constitution of J & K.”

KESAVANAND BHARATI v. STATE OF KERALA [AIR 1973 SC 1461]

“It may be submitted that certain features which have so far been declared by the SC
to constitute the Basic Structure of the constitution make no such reference to Art.

4
Sampat Prakash V. State Of J & K[Air 1970 Sc 1118 (1121-22)]

5
Mohd. Maqbool Damnoo V. State Of J & K [Air 1972 Sc 963]

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370. It is submitted that every integral part of the constitution is not necessarily an
essential features of the constitution. Both are totally distinct and qualitatively
different concept. Therefore, destroying an integral part of the constitution does not
amount to destroying the basic structure or framework of the constitution.”

ISSUE 3:- Whether Omission of Article 35A is constitutionally valid or not?

Article 35A, inter alia, empowers the Jammu and Kashmir State Legislature to confer special
rights and privileges on permanent residents in matters of employment under the State
Government. Under the State laws only permanent residents of the State can be appointed to
posts under the State Government and exclusion of non-permanent residents does not violate
their fundamental right to equality guaranteed under the Constitution.

Article 35A: The Special Rights and Privileges of Permanent Residents

Under article 35A, the State Legislature is empowered to make special laws for the benefit of
permanent residents in following matters:

i. employment under the State Government;

ii. acquisition of immovable property in the State;
iii. settlement in the State; or
iv. right to scholarship and such other forms of aid as the State Government may provide;

Such a law shall not be void on the ground that it is inconsistent with or takes away or
abridges any rights conferred on other citizens of India by any provisions in Part III of the
Constitution of India relating to fundamental rights.

In DR. SUSHEELA SAWHNEY6

An important question which the Court had to consider was whether the qualification of
being a permanent resident of the State as a condition of appointment applies only at the time
of initial appointment or continues to be an essential qualification throughout the service
tenure of an incumbent.

6
STATE OF JAMMU AND KASHMIR V. DR. SUSHEELA SAWHNEY [AIR 2003 J&K 83: 2003 (4) IND
LD 217]

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On this point Muzaffar Jan, J., agreeing with the majority opinion observed:

“I am of the view that at the time of initial appointment, if a person qualifies as a

permanent resident of the State, such person does not lose his continuance in the
employment by virtue of having lost his status as a permanent resident of the State.
There is no rule or regulation providing for such a disqualification. I, therefore, hold
that a woman who in employment of the State and at the time of initial appointment is
permanent resident of the State can continue to be in employment of the State even
after her marriage with a non-permanent resident.”

Right to Settlement in The State

The State Legislature can make laws favouring its permanent residents over the outsiders in
matters of settlement within the territory of the State. The right to settlement generally
includes the right to construct a house and reside within the State. Both the right to reside and
settle are necessary concomitants of the right to acquire immovable property within the State.
A person who is not a permanent resident of the State cannot settle within the State without
the permission of the Government. The Government can direct the removal of such persons
who are not permanent residents but, are residing within the State.

Right to Acquisition of Immovable Property In The State

There is a well-settled law on this point that persons who are not permanent residents of the
State cannot acquire immovable property within the territory of the State.

In DEVI DAS V. PANNA LAL7

“The Full Bench of Jammu and Kashmir High Court examined all the Irshads and
Commands of His Highness in order to determine whether there is any restriction on
acquisition of immovable property by persons who are not permanent residents of the
State and held that the transfer of immovable property by or in favour of non-State
Subjects is prohibited.”

7
Devi Das V. Panna Lal [Air 1959 J&K 62]

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In PRAKASH V. MST. SHAHNI8

“The Division Bench of Jammu and Kashmir High Court held that a person who is not
a State Subject or permanent resident of the State if “could not in her own name
acquire immovable property in the State she cannot be permitted to purchase it in the
name of a Benamidar and then claim it as her own. No such declaration can be granted
in her favour by any Court of law in the State.”

In the matters of employment under the Government, the State of Jammu and Kashmir
can thus give preference to its permanent residents over the outsiders and may even
completely exclude them from State services and this will not amount to violation of
provisions of Part-III of the Constitution of India”

PRAYER

In the light of the Issues Raised, Argument Advanced and Authorities Cited, the

Hon’ble Supreme Court may be pleased to:

1. Dismiss the Petition.

8
Prakash V. Mst. Shahni [Air 1965 J&K 83: 1965 Kash Lj 85]

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2. Grant the recommendation of the Governor of Bshmir does not amounts to violation
of Art. 370.
3. Declare that Omission of Article 35A is constitutionally valid.

AND/OR

Pass any other order, direction or relief that it deems fit in the interest of Justice, Equity and
Good Conscience.

Sd/-

(Counsel for the Respondent)

BIBLIOGRAPHY

1. M.P JAIN, “INDIAN CONSTITUTIONAL LAW”, 7TH EDITION, 1406

2. J.N PANDEY, “INDIAN CONSTITUTIONAL LAW”, 49TH EDITION,

3. PROF. S.K. SHARMA “THE CONSTITUTION OF J & K”

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