MOOT COURT MEMORIAL- NEHRU ACADEMY OF LAW

NEHRU ACADEMY OF LAW

Affiliated to University of Calicut

Approved by the Bar Council of India and Government of Kerala

Jawahar Gardens, Lakkidi, Mangalam (PO), Palakkad.

MOOT NO: 1

STATE OF DELTA PRADESH ...................................... PETITIONER

V.
UNION OF ARYAVARTA ......................................... RESPONDENT

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IN THE SUPREME COURT OF ARYAVARTA

CIVIL APPELLATE JURISDICTION

WRIT PETITION NO……… OF 2021

[UNDER ARTICLE 32 OF THE CONSTITUTION OF INDIA]

IN THE MATTER OF

STATE OF DELTA PRADESH ...................................... PETITIONER

V.
UNION OF ARYAVARTA........................................ RESPONDENT

Counsels Appearing On Behalf Of the Respondent,

Anisha c Alex, Archana B and Nithin AR

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TABLE OF CONTENTS

SL.NO. CONTENT PAGE NO.

1 Abbreviations 6

Index of Authorities 7
a) Case list 7
b) Books Referred 7
2
c) Statutory Compilations 7
d) Internet Sites 7

3 Statement of Jurisdiction 8

4 Statement of Facts 9

5 Statement of Issues 11

6 Summary of Arguments 12

Argument Advanced
13- 14
I. Whether the petition filed under Article 32 is maintainable

II. Whether non-holding of election amounts to constitutional 14- 17

7 breakdown?

III. Whether the President’s Rule under Article 356(1) can be 18-21
issued upon a State on the ground of failure of
Constitutional Machinery?

8 Prayer 22

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LIST OF ABBREVATIONS

AIR All India Report

SCC Supreme Court Cases
DPPP Delta Pradesh Peoples Party
APP Aryavata Peoples Party
ANP Aryavarta Nationalist Party
AIR ALL INDIA REPORT
GOVT. GOVERNMENT
HON’BLE HONOURABLE
NO. NUMBER
ORS. OTHERS
SC SUPREME COURT
SCC SUPREME COURT CASES
SCR SUPREME COURT REPORTER
UOI UNION OF INDIA
V. VERSUS

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INDEX OF AUTHORITIES

A. LIST OF CASES

1. Professor B.K. Chandrashekar and others v. State of Karnataka

2. Rameswar Prasad v. State of Bihar
3. S. R. Bommai v. Union of India
4. Sri M Shivaraju vs The State Of Karnataka
5. Sri M Shivaraju vs The State Of Karnataka

B. BOOKS
1. PROF- SR BHANSALI, CONSTITUTION OF INDIA –- VOLUME 1-
UNIVERSAL PUBLISHING CO.
2. NARENDER KUMAR - CONSTITUTION OF INDIA
3. V.N SHUKLA - CONSTITUION OF INDIA
4. PANDEY -CONSTITUTION

C. STATUTORY COMPILATIONS

1. CONSTITUTION OF INDIA

2. CODE OF CIVIL PROCEDURE (1908)

3. PUNJAB MUNCIPAL ACT, 1911

4. PUNJAB PANCHAYATI RAJ ACT, 1911

5. PUNJAB MUNCIPAL CORPORATION ACT, 1976

D. INTERNET SITES

1. www.indiankanoon.com
2. www.barandbench.com
3. www.blog.ipleader.com

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STATEMENT OF JURISDICTION

Article 32(1) provides for the right to move the Supreme Court by appropriate proceedings
for the enforcement of the fundamental rights. The Supreme Court under Article 32(2) is free
to devise any procedure for the enforcement of fundamental right and it has the power to
issue any process necessary in a given case.

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STATEMENT OF FACTS

1. Aryavarta is a Sovereign, Socialist, Secular, Democratic Republic having 28 states and 9

Union Territories. Constitution of Aryavarta provided a federal form of government
wherein powers were divided between the Union and States.

2. Directive Principles of State Policy Part IV of the Constitution of Aryavarta in Article 40

provided that State shall take step to organize Village Panchayats and endow them with
such powers and authority as may be necessary to enable them to function as units of self
government.

3. Local governments were in existence in different parts of the country but the elections were
not held regularly. The constitutional amendments provided in 243E that the duration of
Panchayats shall be five years.

4. Delta Pradesh is one of the 28 States of Aryavarta. Local governments were in existence in
the Delta Pradesh by virtue of Delta Pradesh Muncipal Act 1911 and 1976. Delta Pradesh
enacted Delta Pradesh Panchyati Raj Act 1994 to establish Panchayati Raj institution at
three level in Rural areas.

5. In Urban Areas, Delta Pradesh had 99 Municipal Councils and 10 Municipal Corporations
till 2017. On 2nd February 2017 issued a notification under section 3(1) of Delta Pradesh
Municipal Corporation Act, 1976 and notified three urban areas to have municipal
corporations. Earlier these areas had Municipal Councils under the Act of 1911. The tenure
of these Municipal Councils expired on 28th February 2017. The State Election
Commission took up the task of delimiting and revising the constituencies as per law but
the elections could not be held till 2019. The Provincial government claims that the
electoral rolls and records are being updated due to delimitation of constituencies and
therefore, it is not in a position to hold elections.
6. Delta Pradesh Peoples Party (DPPP) is in opposition in the State and Aryavarta Peoples
Party (APP) is the ruling party in the State. DPPP has alleged that since the party in power
apprehends that it will lose the elections, it is delaying elections is against constitutional
mandate.

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7. DPPP filed petition in the High Court claiming that the Provincial government was bound
to conduct elections before the expiry of the tenure of local government and that non-
holding of elections is against the constitutional mandate.

8. During the pendency of the petition in the High Court, President of Aryavarta issued a
direction to the State under Article 256 on 11th October 2019 to conduct elections to the
newly constituted Municipal Corporations on or before 31st January 2020 and to issue the
notification as soon as may be, for the holding the elections. Consequent to issuance
such notification, Delta Pradesh filed a Suit in the Supreme Court of Aryavarta claiming
that Union could not issue such a direction. Suit was filed in the month of November 2019
and the Supreme Court issued notice to the Union.

9. Governor of Delta Pradesh wrote to the President of Aryavarta on 01st January 2020 that
no tangible steps have been taken by the State till date to conduct elections in compliance
with the direction of the Union and that the state is using dill-delaying tactics under the
garb of preparation/revision of electoral rolls pursuance delimitation of constituencies.

10. In the meantime, on 01st February 2020, President of Union of Aryavarta issued a
Proclamation under Article 356(1) declaring that government of the State cannot be carried
on in accordance with the Constitution as the State has failed to comply with the
constitutional mandate and there is non-compliance with the directions of the Union. The
Proclamation has been approved by both House of Parliament of Aryavarta.

11. The Proclamation has been challenged by the chief Minister, Mr. Satya Prakash (who was
serving on the date of issuance of Proclamation) in the Supreme Court. He has also
challenged the constitutionality of the direction issued by the Union to the State on 11th
October 2019. He claims that after the Proclamation under Article 356(1), the State is under
President’s Rule and that there would be conflict of interest in the matter filed in November
2019 by Delta Pradesh against Union of Aryavarta owing to the fact that both the Union
and State would be governed/ruled by the Union (as President acts under the aid and advice
of council of Ministers).

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STATEMENT OF ISSUES

I. WHETHER THE PETITION FILED UNDER ARTICLE 32 IS

MAINTAINABLE?

II. WHETHER NON HOLDING OF ELECTION AMOUNTS TO

CONSTITUTIONAL BREAKDOWN?

III. WHETHER THE PRESIDENT’S RULE ISSUED UNDER ARTICLE

356(1) OF THE CONSTITUTION ON FAILURE OF
CONSTITUTIONAL MACHINERY IN THE STATE
MAINTAINABLE?

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SUMMARY OF ARGUMENTS

I. WHETHER THE PETITION FILED UNDER ARTICLE 32 IS

MAINTAINABLE?

Article 32 of the Constitution of India is meant to ensure observance of the rule

of law and prevent abuse or misuse of power
It is one of the fundamental rights listed in the Constitution that each citizen is entitled. ...
The Constituent Assembly debated whether fundamental rights including this one could be
suspended or limited during an Emergency. The Article cannot be suspended except during
the period of Emergency. And also it is not a violation of fundamental rights

II. WHETHER NON-HOLDING OF ELECTION AMOUNTS TO

CONSTITUTIONAL BREAKDOWN?

The Election Commission is an autonomous constitutional authority responsible for

administering Union and State election processes. As per the provisions of section 151A
of the Representation of the People Act, 1951, the vacancies are required to be filled,
through bye-elections within six months from the date of occurrence of vacancy,
provided that the remainder of the term in relation to the vacancy is one year or more.

III. WHETHER THE PRESIDENT'S RULE ISSUED IN THE STATE UNDER

ARTICLE 356(1) ON THE GROUND OF FAILURE OF CONSTITUTIONAL
MACHINERY IS MAINTAINABLE?
It is humbly submitted before this Honorable Supreme Court that the President’s rule
can be issued upon a State on the ground of failure of Constitutional Machinery. Article
365 of the Constitution of Aryavarta gives a discretionary power to the President. It
can be invoked if ;

1) any direction is given by the Union the valid exercise of its powe Under any of
the provisions of the Constitution and

2) such direction has not been complied with or given effect to by the State.

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ARGUMENTS ADVANCED

I. WHETHER THE PETITION FILED UNDER ARTICLE 32 IS

MAINTAINABLE?
It Humbly Submitted That The Petition Filed Under Article 32 Is Not Maintainable It Had No
Jurisdiction To Entertain The Writ Petition Under Article 32

1. Can article 32 be suspended?

What is Article 32? It is one of the fundamental rights listed in the Constitution that each
citizen is entitled. ... The Constituent Assembly debated whether fundamental rights
including this one could be suspended or limited during an Emergency. The Article
cannot be suspended except during the period of Emergency. According to Article 356,
President's Rule can be imposed on any state of India on the grounds of failure of the
constitution machinery.

2. The ground of failure of constitution.

As per this Article, 365 President's Rule can be imposed if any state fails to comply
with all directions given by the union on matter it is empowered President's Rule is
when the state government is suspended and the central government directly administers
the state through the office of the governor centrally appointed. It’s called state
emergency Or constitutional emergency. President’s rule was imposed 63 times in 20
years between 1971 and 1990.The imposition of President's rule in states has varied
across various decades the Presidential Proclamation under Article 356 was justifiable
all the judges were unanimous in holding that the presidential proclamation was
justifiable.

3. power of parliament

The Supreme Court firmly held that there was no reason to make a distinction between
the Proclamation so approved and legislation enacted by the Parliament. If the
Proclamation is invalid, it does not stand validated merely because it is approved of by
the Parliament.

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It was used 20 times between 1950 and 1970. Between 1971 and 1990, it was used
63times, an average of 3 times a year. In fact, it was used 49 times between 1970and
1980, highlighting the polarized political atmosphere during those times. Article 356
was used as a political tool during those times. In the case S .R Bommai v union of
India1 grounds on which the president proclamation can be challenged. This case deals
with assessing the lawful mechanism and searching the whole area of constitutional
imperatives on Central-State relations and the contentions’.

The role of State Governors calling President’s rule. The fact that under the system does
not mean that the States are little appendices of the Centre. vis-a-vis the states does not
mean that the States are little appendices of the Centre. The States are the greatest
strength within the fields which are assigned to them. Here it concluded that the
supreme court has no jurisdiction to entertain the writ petition under article 32 of the
constitution of aryavarta . The article 32 cannot suspend except during the period of
emergency.

Hence it humbly submitted that the supreme court has not the jurisdiction to entertain
the writ petition under article 32 of constitution . Here it concluded that the petition
filed under article 32 is not maintainable .

II. WHETHER NON-HOLDING OF ELECTION AMOUNTS

TO CONSTITUTIONAL BREAKDOWN?

The Election Commission is an autonomous constitutional authority responsible for

administering Union and State election processes
Grounds for Election Postponement:
Article 172(1) states that, in case of a state of Emergency, an election can be
postponed for one year at a time in addition to a period of six months after the
Emergency is lifted.
There is no specific legal provision that specifies the circumstances under which
elections can be deferred in non-Emergency situations.
However, law and order, natural calamities like earthquakes and floods, or any other
compelling circumstances which are beyond EC’s control can be the grounds for
extension.

Foot notes:

1: 1994 AIR 1918, 1994 SCC (3) 1

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The Election Commission has held that the non- observance of the provisions of
Article 174(1) in the present situation would mean that the Government of the State
cannot be carried in accordance with the provisions of the Constitution within the
meaning of Article 356(1) of the Constitution and the President would then step in.
The state election commissioner will have to inform the government of its inability
to perform the election
As per the provisions of section 151A of the Representation of the People Act, 1951,
the vacancies are required to be filled, through bye-elections within six months from
the date of occurrence of vacancy, provided that the remainder of the term in relation
to the vacancy is one year or more. The Election Commission (EC) is mandated
under law to hold elections at any time within six months before the five-year term
of the Lok Sabha or Legislative Assembly expires. The polls are timed in a way that
the new Assembly or Lok Sabha is in place on the day of the dissolution of the
outgoing House. For instance, in the case of Bihar, the EC should normally conduct
Legislative Assembly elections before the end of its time.
In the case of early dissolution, EC has to ensure a new Lok Sabha or Assembly is in
place within six months of the dissolution. The six months is the constitutionally
defined limit between two sessions of the House/Assembly (Article 85(1) and
Article 174(1) of the Constitution, respectively
An election once called usually proceeds as per schedule. However, in some
exceptional cases, the process can be postponed or even scrapped after its
announcement under extraordinary circumstances.
Under Section 153 of the Representation of the People Act, 1951, read with Article
324 of the Constitution of India, the EC can extend the time for completing an
election,
but such extension:
• Should not go beyond the six months.
• Should not go beyond the date of the normal dissolution of the Lok Sabha or
the Assembly.
In 1991, the EC postponed the ongoing parliamentary elections for three weeks after
Rajiv Gandhi’s assassination during his campaign in Tamil Nadu.
73rd and 74th Constitutional Amendments were passed by Parliament in
December, 1992. Through these amendments local self-governance was introduced
in rural and urban India. ... The Local bodies–'Panchayats' and 'Municipalities' came
under Part IX and IXA of the Constitution after 43 years of India becoming a
republic.

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In 73 rd cons. Amendment the Panchayati Raj Institutions have been in existence for
a long time, it has been observed that these institutions have not been able to acquire
the status and dignity of viable and responsive people's bodies due to a number of
reasons including absence of regular elections, prolonged supersession, insufficient
representation of weaker sections like Scheduled Castes, Scheduled Tribes and
women, inadequate devolution of powers and lack of financial resources.2. Article
40 of the Constitution which enshrines one of the Directive Principles of State
Policy lays down that the State shall take steps to organize village panchayats and
endow them with such powers and authority as may be necessary to enable them to
function as units of self-government. In the light of the experience in the last forty
years and in view of the short-comings which have been observed, it is considered
that there is an imperative need to enshrine in the Constitution certain basic and
essential features of Panchayati Raj Institutions to impart certainty, continuity and
strength to them.
The 74th constitutional amendment act mandated the setting up and devolution of
powers to Urban local bodies (ULBs) or city governments as the lowest unit of
governance in cities and towns.
This Act prescribes institutional changes as well, with the setting up of Ward
Committees, District Planning Committees and Metropolitan Planning Committees
to coordinate planning across jurisdictions, as well as the setting up of State Election
Commissions and State Financial Commissions. Effectively, this act gives ULBs a
role much larger than just that of service providers that provide water, waste
management, electricity, and so on. Urban local bodies are known as municipal
corporation, municipal council and nagar panchayat based on population. The nagar
panchayat is for traditional areas, the municipal council or municipalities are for
smaller urban areas and municipal corporation are for larger urban areas. It is
constituted for a time period of 5 years.1/3 reservation for women these bodies have
been given the power to legislate and implement scheme for economic development
and social justice.The legislature of a state can assign specific taxes, duties, tolls,
etc. for the functioning of urban local bodies.
Sri M Shivaraju vs The State Of Karnataka2

Article 243U in The Constitution 243U. Duration of Municipalities, etc

FOOT NOTES:

2: WRIT PETITION NO. 10216 OF 2020

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(1) Every Municipality, unless sooner dissolved under any law for the time being in
force, shall continue for five years from the date appointed for its first meeting
and
(2) no longer: Provided that a Municipality shall be given a reasonable opportunity
of being heard before its dissolution
(2) No amendment of any law for the time being in force shall have the effect of causing
dissolution of a Municipality at any level, which is functioning immediately before
such amendment, till the expiration of its duration specified in clause ( 1 )
(3) An election to Constitute a Municipality shall be completed,
(a) before the expiry of its duration specified in clause ( 1 );
(b) before the expiration of a period of six months from the date of its dissolution:
Provided that where the remainder of the period for which the dissolved
Municipality would have continued is less than six months, it shall not be necessary
to hold any election under this clause for constituting the Municipality for such
period
(4) A Municipality constituted upon the dissolution of a Municipality before the
expiration of its duration shall continue only for the remainder of the period for
which the dissolved Municipality would leave continued under, clause ( 1 ) had it
not been so dissolved
Article 243U(1) in The Constitution Of India 1949(1) Every Municipality, unless
sooner dissolved under any law for the time being in force, shall continue for five
years from the date appointed for its first meeting and no longer: Provided that a
Municipality shall be given a reasonable opportunity of being heard before its
dissolution

Professor B.K. Chandrashekar and others v. State of Karnataka3

The election of BBMP was considerably delayed and an attempt is always made by
the State Government to delay the elections thereby defeating the mandate of Article
243U of the Constitution.

FOOT NOTES

3: AIR 1999 Kant 461, ILR 1999 KAR 2513, 1999 (6) KarLJ 394

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III. Whether the President’s Rule under Article 356(1) can be issued
upon a State on the ground of failure of Constitutional Machinery?

It is humbly submitted before this Honourable Supreme Court that the President’s rule
can be issued upon a State on the ground of failure of Constitutional Machinery.

1. The President’s rule can be imposed U/A 356

1.1 Article 356 of the Constitution of Aryavarta gives the President of Aryavarta, the
power to impose President's rule on State on the advice of Union, Council of Ministers.

1.2 If the President on receipt of report from the Governor of a State or otherwise satisfied
that a situation has arisen in which the Government of the State cannot be carried on in
accordance with the provisions of the Constitution, the President may by proclamation,

a) Assume to himself all or any of the functions of the Government of the State and
all or any of the powers vested in or exercisable by the Governor or anybody or
authority in the State other than the legislature of the State.
b) Declare that the powers of the Legislature of the State shall be exercisable by or
under the authority of Parliament.
c) Make such incidental or consequential provisions as to the President to be
necessary or desirable for giving effect to the objects of the Proclamation,
including provisions for suspending in whole or in part the operation of any
provisions of this Constitution relating to any body or authority in the state.

2. Failure of Constitutional Machinery

Article 365of the Constitution of Aryavarta deals with the break down of Constitutional
Machinery. According to Article 356 , Constitutional machinery is demarcated as the
situation in which a State cannot be carried on in accordance with the provisions laid
down in the Constitution.
As per Article 355 of the Constitution, it is the sole duty of the Union Government to
assure that the government of every State is carried on in accordance with the provisions
of the Constitution.
Failure of constitutional machinery in the States, a disaster in disguise, has proved to be
a mootable and alienating procedure for decades. The causes of the failure are described
below –
• Political crisis - crisis is deemed to be cynical changes in security when they are
an anticipated with little or no warning,

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• Internal Subversion
• physical break down
• Inability to maintain law and order.
Here in the instant case the State was unable to maintain law and order. Thus it is treated
as a failure of Constitutional machinery and the President's rule was issued.

3.3. Non-Compliance with the direction of the Union

1. Whenever any direction issued by the Union to any State, the State must be complied with
the direction of the Union. Otherwise, type President can invoke President’s rule.
2. Article 365 of the Constitution of Aryavarta gives a discretionary power to the President. It
can be invoked if ;
1) any direction is given by the Union the valid exercise of its power
Under any of the provisions of the Constitution and
2) such direction has not been complied with or given effect to by the State.
3. In the instant case, applicability of Article 365 lies. The petitioner did not comply with the
direction issued by the Union U/A 256 on 11th October 2019 to conduct elections to the newly
constituted municipal corporations on or before 31st January 2020 and to issue the notification
as soon as may be for the holding the elections.
4.After the non-compliance of direction by the Union , the Governor of Delta Pradesh wrote a
letter , The President of Aryavarta issued President’s rule with reference to Article 365 under
Article 356(1) of the Constitution of Aryavarta.
3.3.The President of Aryavarta issued the President’s rule after getting Governor's report
1. In this instant case, Governor of Delta Pradesh wrote a letter to the President of Aryavarta on
1st January 2020 that no tangible steps have been taken by the State till date to conduct
elections in compliance with the direction of the Union and that the State is using dill -delaying
tactics under the garb of preparation or revision of electoral rolls in pursuance delimitation of
constituencies. delimitation of constituencies. After getting this letter, President of Aryavarta
issued a Proclamation Under Article 356(1) of the Constitution of Aryavarta on 1st February
2020 declaring that Government of the State cannot be carried on in accordance with the
Constitution as the State has failed to comply with the Constitutional mandate and there is non-
compliance of the direction of the Union. The Proclamation has been approved by both House
of Parliament of Aryavarta.
2. In the case of S. R. Bommai v. Union of India4, the Court held that “the president
satisfaction has to be based on objective material, that material may be available in the report
Foot notes:

1: 1994 AIR 1918, 1994 SCC (3) 1

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Send it to him by the governor or otherwise or both from the report or and other sources.
Further, the objective material show available must indicate that the government of the state
cannot be carried on in accordance with the provisions of the Constitution. Thus come, the
Existence of the objective material showing that the government of the state cannot be carried
on in accordance with the provisions of the Constitution, the objective material is a condition
precedent before the president issues the proclamation . One such material is shown to exist the
satisfaction of the President based on the material is not open to question”.
3. While looking into the instant case with reference to the case of S.R. Bommai , the report
sent to the President of Aryavarta by the Governor of Delta Pradesh. The President is satisfied
with the objective material. In the letter wrote to the President impliedly says that the
Government of the State cannot be carried on in accordance with the provisions of the
Constitution.
4.In the case of Rameswar Prasad v. State of Bihar, the Court disqualified the proclamation of
President rule in the State after examining the report sent by the Governor. It was observed that
there was no objective material in the report that has the probability of gaining the satisfaction
of the President .Then, in such circumstances, where there is the absence of reasonable grounds
in the Governor’s report the court can question the President’s decision of imposing President's
rule.
3.4.The Proclamation was not passed in hurry.
1. On 2nd February 2017-Petitioner issued a notification under Section 3(1) of Delta Pradesh
Municipal Corporation Act, 1976 notified three urban area to have municipal corporations.
Tenure of the municipal councils expired on 28th February 2017.The state
election Commission took up the task of de- limiting and revising the constuencies as per law
but the elections could not be held till 2019.
2. On 11th October 2019,the respondent issued a direction to the State of Delta Pradesh U/A
256 to conduct elections to the newly constituted Municipal Corporations on or before 31st
January 2020 and to issue the notification as soon as may be for holding the elections.
3. After getting the letter from the Governor of Delta Pradesh, the Respondent took time to
present the Proclamation before the Houses of Parliament. Then the Proclamation has been
approved by both the Houses of Parliament of Aryavarta.
4. This respondent had given warnings to the Petitioner on non-holdings of elections. The
petitioner was bound to conduct the elections before the expiry of the Local Government. The
Non-holding of election is against Constitutional mandate which is clear laid down under
Article243 E and 243U of the Constitution.
5.The failure of Constitutional mandate had led to the issuance of President’s rule.
Hence in the light of aforesaid arguments, case laws and legal reasoning, it is humbly submitted
before this Honorable Supreme Court that the President's rule is issued upon the State of Delta

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Pradesh on the ground of failure of Constitutional machinery. The State of Delta Pradesh has
acted against the provisions of the Constitution of Aryavarta. Thus the Proclamation issued
under is valid and maintainable.

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PRAYER

Wherefore in the light of issues raised , arguments advanced and authorities cited, the Counsel
for the respondent humbly prayed before this Honourable Supreme Court to adjudge and
declare that –

1.THE WRIT PETITION FILED UNDER ARTICLE 32 BEFORE THIS HONOURABLE

COURT IS NOT MAINTAINABLE.

2.NON-HOLDING OF ELECTION AMOUNTS TO FAILURE OF CONSTITUTIONAL MACHINERY.

3. THE PRESIDENT’S RULE ISSUED IN THE STATE UNDER ARTICLE 356(1) ON THE GROUND OF
FAILURE OF CONSTITUTIONAL MACHINERY IS MAINTAINABLE.

4.DISMISS THIS PETITION.

And pass any order as the Court may deem fit in the interest of equity, justice and good
conscience.

And for this act of kindness the respondent in duty bound forever shall pray.

Counsel for Respondent

Place: sd/-

Date: Counsel for Respondent

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