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2
n d

YEAR B.A LL. B Semester-IV (2020-2025)

2ND -INTERNAL ASSESSMENT: PUBLIC LAW SKILL

PIL DRAFTING

NAME: SOMYA SHIVANI

DIVISION: E

PRN: 20010125419

COURSE: BA LL.B. (H)

BATCH: 2020-2025

BEFORE THE HIGH COURT OF SAPOTA

(EXTRA- ORDINARY CIVIL WRIT JURISDICTION)

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PIL No. XXXXXXXX OF: XXXX

PUBLIC INTEREST LITIGATION

(UNDER ARTICLE 226 OF THE INDIAN CONSTITUTION)

IN THE MATTER OF:

PROTECT KINDIA …..…………..PETITIONER

VERSUS

STATE OF SAPOTA AND OTHERS …..…………..RESPONDENT 1

(Through the ministry of Environment and Forest)

THE RUBANI INDUSTRIES LIMITED …………….…….RESPONDENT 2

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TO,

THE HON’BLE CHIEF JUSTICE AND OTHER

HONBLE PUISNE JUDGES OF THE HIGH COURT OF JUDICATURE OF
SAPOTA, BENCH AT KINDIA

HUMBLE PETITION OF
THE PETITIONERS ABOVE
NAMED

THE PETITIONERS MOST RESPECTFULLY SHOWETH:-

1. PARTICULARS OF THE CASE / SUBJECT MATTER IN BRIEF-

It is submitted by the petitioners in this case that, the State of Sapota withing the territorial
boundaries of the State of Kindia. The State is facing climate changes due to which it is
facing scarcity of water. Due to this issue the state of Sapota, the respondents has taken a
decision that damns would be built so that rain water could be accumulated so that water
needs of the state could be met with and for there could be an improvement in the ground
water level so that the State does not face this issue in the future. A number of dams were
supposed to be built in the State of Sapota, the focus of this petition is on one such area
namely the district of Fardapur which is a severely affected area. However the complication
with the building of this dam is that it would submerge the agricultural fields adjoining the
location of the dam.

For the purpose of building this dam, the State had floated global tenders out of which
Rubani Industries limited has been given the contract for the construction of the dam. Moving
forward, Rubani Industries had applied for an environmental clearance to the Ministry of
Environment and Forest and all clearances for the same was granted to them by the
government as it is viewed to be in the greater of the public interest. There were a number of
bodies which were not in favour of the building of the dam such as agriculturists and nearby
villagers. However the dam was being built in public interest and hence they went forward
with the idea of building the dam. To oppose this building of the dam an NGO named,
“Protect Kindia” has filed a petition under Article 226 and 227 of the Constitution of Kindia.
They also said that the building of the dam was a violation of article 21 of the Constitution of
Kindia and many other statutory provisions of the environmental laws.

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2. PARTICULARS OF THE PETITIONER

Petitioner says and submits that they are involved in various organizations fighting for
protecting farmers rights. They have been working very eagerly for the protection of the
environment in this fast pace developing world. The petitioners have filed a number of
petitions for the protection of agriculturists and the environment on a larger scale for a long
time. “Protect Kindia” NGOs has played a crucial role in helping to plug gaps by conducting
research to facilitate policy development, building institutional capacity, and facilitating
independent dialogue with civil society to help people live more sustainable lifestyles.

As the building of the dam in the district of Fardapur would seriously affect the livelihood of
a large number of people of the State of Sapota, they would be affected economically,
socially and the most importantly their life would be affected due to the submerging of their
agricultural fields and well as their homes. To prevent the people of the state from facing
such an issue the petitioner i.e. “Protect Kindia” NGO has filed the petition number
XXXXXXXXXX in the High Court of Judicature of SAPOTA.

3. DECLERATION AND UNDERTAKING OF PETITIONER

A. That the present petition is filed by way of public interest litigation. The petitioner does
not have any personal interest in the matter.

B. That the entire litigation including the advocate fees is borne by the petitioner. They are
an NGO registered under the Trust under Indian Trusts Act, 1882.

C. The petitioner has conducted thorough research in the matter. They are conversant with all
the facts and circumstances of the case. They have received the information on their own.
Petitioner has also given representation to respondent authorities regarding subject matter.

D. That to the best of the petitioner’s knowledge and research, the issue raised was not dealt
with or decided and that a similar or identical petition was not filed earlier by him/it (in case,
such an issue was dealt with or a similar or identical petition was filed earlier, state its status
or the result).

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E. That the petitioner understand that in the course of hearing of this petition the Court may
require any security to be furnished toward costs or any other charges and the
petitioner/petitioners shall have to comply with such requirements.

F. That, sole purpose of the Petitioner for filing this Petition is only for a greater good and in
the interest of the public, and for the safeguard of the environment, degradation of which
would have grave and serious backlash on the lives of the people if the State of Sapota,
furthermore, the petitioner has no personal axe to grind in this issue.

4. FACTS IN BRIEF CONSTITUTING THE CAUSE

4.1 Petitioner says and submits that they are citizens of Kindia and is therefore entitles to
enjoy all the rights given in the Constitution of India including the right to file the petition
under Articles 226 & 227 and to raise their voice against the violation of their fundamental
right in this case, Article 21 and for seeking indulgence of this Hon’ble High Court in public
interest. Petitioner says and submits they are an NGO registered under the Trust under Indian
Trusts Act, 1882 and have been working very actively for the betterment of the environment.
Annexed Hereto are copies of their registration certificate.

4.2 Petitioner has filed PIL No. XXXXXX 2022 titled as Protect Kindia Vs State of
Sapota and Ors. raising the issue of establishment of dams encroaching the livelihood of the
innocent villagers. Petitioner says and submits that the Respondent No. 1 is the State of
Sapota, has violated Article 21 of the Constitution of Kindia, by unilaterally granting
permission to Respondent No. 2 i.e. Rubani Industries Ltd. to establish dams and thereby
encroaching the livelihood of the innocent villagers of the Fardapur district. Respondent
No.’s 4 to 29 are the Sugar Factories. All are proper and necessary parties and are amenable
to writ jurisdiction of this Hon’ble High Court.

4.3 Petitioner says and submits that the petition is maintainable under Article 226 of the
Constitution of Kindia. Article 226, empowers the high courts to issue, to any person or
authority, including the government (in appropriate cases), directions, orders or writs,
including writs in the nature of habeas corpus, mandamus, prohibition, quo warranto,
certiorari or any of them. Additionally, Article 227 determines that every High Court shall
have superintendence over all courts and tribunals throughout the territories in relation to
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which it exercises jurisdiction (except a court formed under a law related to armed forces).
The petitioner has substantiated the same by placing reliance on the case of Umaji Keshao
Meshram and Ors. vs. Smt. Radhikabai and Anr reported in 1986 AIR 1272. The High Court
has held as under:

“ The power to issue directions, orders and writs under Art. 226 is modelled upon the
prerogative writ jurisdiction possessed by the three Chartered High Courts in the exercise
of their original jurisdiction immediately prior to the commencement of the Constitution,
though under the Constitution that power has been made wider and more extensive and
conferred upon every High Court to enable them to reach injustice wherever found and
mould the reliefs accordingly. Article 227 derives its origin from s.15 of the Indian High
Courts Act, 1861, s.107 of the Government of India Act, 1915-1919 And s.224 of the
Government of India Act, 1935 which conferred upon each of the Chartered High Court the
power of superintendence over all courts subject to its appellate jurisdiction.”

Garikapatti Veeraya v. N. Subbiah Choudhury, [1957] S.C.R. 488; and Ahmedabad Mfg.
& Calico Ptg. Co. Ltd. v. Ram Tahel Ramnand & Ors., [1973] 1 S.C.R. 185: The powers
conferred by Arts. 226 and 227 are separate and distinct and operate in different fields.
Their source and origin are different and the models upon which they are patterned are
also different. The power to issue a writ in the nature of habeas corpus or mandamus or
quo warranto or prohibition or certiorari under Art. 226 cannot be equated with the
power of superintendence over the subordinate courts and tribunals under Art. 227. In
a proceeding under Art. 226 the person, authority or the State against whom the direction,
order or writ is sought is a necessary party. Under Art. 227, however, what comes up
before the High Court is the order of ascertaining whether in giving such judgment or
order that subordinate court or tribunal has acted within the authority and according to law.

4.4 The petitioner says and submits that the High Court of Sapota can interfere in policy
decisions made by the State of Sapota, as it is a well-established doctrine that the High Courts
can interfere in policy decisions made by the state if such policy decisions are grossly
arbitrary, irrational, unilateral, or in violation of the Fundamental Rights guaranteed by the
Constitution. The petitioner has substantiated the same by placing reliance on the case of
Ugar Sugar Works Ltd vs Delhi Administration And Ors:

“The challenge, thus, in effect, is to the executive policy regulating trade in liquor in Delhi. It
is well settled that the Courts, in exercise of their power of judicial review, do not ordinarily
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interfere with the policy decisions of the executive unless the policy can be faulted on
grounds of mala fide, unreasonableness, arbitrariness or unfairness etc. Indeed,
arbitrariness, irrationality, perversity and mala fide will render the policy unconstitutional.
However, if the policy cannot be faulted on any of these grounds, the mere fact that it would
hurt business interests of a party, does not justify invalidating the policy. In tax and
economic regulation cases, there are good reasons for judicial restraint, if not judicial
deference, to judgment of the executive. The Courts are not expected to express their opinion
as to whether at a particular point of time or in a particular situation any such policy should
have been adopted or not. It is best left to the discretion of the State”

Sunitha Krishnan v. The State of Telangana WRIT PETITION (PIL).No.118 of 2020: “The
court observed that while dealing with petitions under Article 226 which deals with the
extraordinary jurisdiction of the court, its jurisdiction is limited when it comes to interfering
with the State’s policy decisions. It further stated that, while relaxing the lockdown the State
must have taken various factors into account such as the livelihood of the worker class,
economic restrictions, movement restrictions, etc. Moreover, it also stated that the public is
under no obligation to visit religious places or any other public place. Furthermore, the
government also issues health bulletins cautioning people about the dos and don’ts to follow
during the pandemic. The court further observed that the policymaking is the executive’s
domain and it shall not interfere with it unless such decisions are made with “malafide, or in
gross abuse of power”.

Ira Munn v. State of Ellinois [1876 (94) US (SR) 113]: “The Courts cannot be called
upon to undertake the Government duties and functions. The Court shall not ordinarily
interfere with a policy decision of the State. Social and economic belief of a Judge should
not be invoked as a substitute for the judgment of the legislative bodies. Merely because
another view is possible, the courts would not ordinarily interfere with a policy decision,
unless there is a violation of fundamental rights, or violation of provision of law.
Otherwise, it would amount to transgressing into the areas that are specifically
earmarked for the Executive authorities; same would run contrary to the theory of
separation of powers as enshrined in the constitution of India.”

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4.5 The petitioner says and submits that the displacement of the agriculturists from nearby
villages of the district Fardapur results in violation of Art. 21 of the Constitution of Kindia,
reason being that the Article itself states that, No person shall be deprived of his life or
personal liberty except according to procedure established by law, nor shall any person be
denied equality before the law or the equal protection of the laws within the territory of
Kindia. By the building of this dam the livelihood of the people of the area of Fardapur
district is being disrupted. It is also evident that in the present case the procedure prescribed
by law for the deprivation of the right conferred by Article 21 is neither fair, just nor
reasonable. The court has placed reliance on the case of Kharak Singh v. The State of U.P.,
[1964] 1 S.C.R. 332: “As we have stated while summing up the petitioners' case, the main
plank of their argument is that the right to life which is guaranteed by Article 21 includes the
right to livelihood and since, they will be deprived of their livelihood if they are evicted from
their slum and pavement dwellings, their eviction is tantamount to deprivation of their life
and is hence unconstitutional. Upon that assumption, the question which we have to consider
is whether the right to life includes the right to livelihood. We see only one answer to that
question, namely, that it does. The sweep of the right to life conferred by Article 21 is wide
and far reaching. It does not mean merely that life cannot be extinguished or taken away as,
for example, by the imposition and execution of the death sentence, except according to
procedure established by law. That is but one aspect of the right to life. An equally important
facet of that right is the right to livelihood because, no person can live without the means of
living, that is, the means of livelihood. If the right to livelihood is not treated as a part of the
constitutional right to life, the easiest way of depriving a person his right to life would be to
deprive him of his means of livelihood to the point of abrogation. Such deprivation would not
only denude the life of its effective content and meaningfulness but it would make life
impossible to live. And yet, such deprivation would not have to be in accordance with the
procedure established by law, if the right to livelihood is not regarded as a part of the right
to life. The motive force which people their desertion of their hearths and homes in the
village s that struggle for survival, that is, the struggle for life. So unimpeachable is the
evidence of the nexus between life and the means of livelihood. They have to eat to live: Only
a handful can afford the luxury of living to eat. That they can do, namely, eat, only if they
have the means of livelihood.
E.P.Royappa v. State of Tamil Nadu, [1974] 2 S.C.R. 348; Maneka Gandhi v. Union of India,
[1978] 2 S.C.R. 621; M.O.Hoscot v. State of Maharashtra, [1979] 1 S.C.R. 192; Sunil Batra,

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I v. Delhi Administration, [1979] 1 S.C.R. 392; Sita Ram v. State of U.P., [1979] 2 S.C.R.
1085; Hussainara Khatoon, I v. Home Secretary, State of Bihar, Patna, [1979] 3 S.C.R.
532,537; Hussainara Khatoon, II v. Home Secretary, State of Bihar, Patna, [1980] 1 S.C.C.
81; Sunil Batra, II v. Delhi Administration, [1980] 2 S.C.R. 557; Jolly George Verghese v.
The Bank of Cochin, [1980] 2 S.C.R. 913,921-922; Kasturi Lal Lakshmi Keddy v. State of
Jammu & Kashmir, [1980] 3 S.C.R. 1338,1356; and Francis Coralie Mullin v. The
Administrator, Union Territory of Delhi, [1981] 2 S.C.R. 516,523-24: Just as a mala fide act
has no existence in the eye of law, even so, unreasonableness vitiates law and procedure
alike. It is therefore essential that the procedure prescribed by law for depriving a person of
his fundamental right, in this case the right to life, must confirm to the norms of justice and
fairplay. Procedure, which is unjust or unfair in the circumstances of a case, attracts the vice
of unreasonableness, thereby vitiating the law which prescribes that procedure and
consequently, the action taken under it. Any action taken by a public authority which is
invested with statutory powers has, therefore, to be tested by the application of two
standards: The action must be within the scope of the authority conferred by law and
secondly, it must be reasonable. If any action, within the scope of the authority conferred by
law, is found to be unreasonable it must mean that the procedure established by law under
which that action is taken is itself unreasonable. He will tend to form his judgment of the
excellence or otherwise of the legal system from his personal knowledge and experience in
seeing the legal machine at work"

4.6 The petitioner says and submits that Article 39(a) of the Constitution, which is a
Directive Principle of State Policy, provides that the State shall, in particular, direct its policy
towards securing that the citizens, men and women equally, have the right to an adequate
means of livelihood. Article 41, which is another Directive Principle, provides, inter alia, that
the State shall, within the limits of its economic capacity and development, make effective
provision for securing the right to work in cases of unemployment and of undeserved want.
Article 37 provides that the Directive Principles, though not enforceable by any court, are
nevertheless fundamental in the governance of the country. The principles contained in
Articles 39 (a) and 41 must be regarded as equally fundamental in the understanding and
interpretation of the meaning and content of fundamental rights. If there is an obligation upon
the State to secure to the citizens an adequate means of livelihood and the right to work, it
would be sheer pedantry to exclude the right to livelihood from the content of the right to life.
The State may not, by affirmative action, be compellable to provide adequate means of

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livelihood or work to the citizens. But, any person, who is deprived of his right to livelihood
except according to just and fair procedure established by law, can challenge the deprivation
as offending the right to life conferred by Article 21.

4.7 The petitioner says and submits that, Environment Clearance Certificate granted by the
State is contrary to the provisions of environmental laws, as it is nowhere mentioned that any
public hearing was held before granting the environment clearance to Rubani industries Ltd
for building the dam in the area. There are a lot of ways in which public hearing is a very
important stage before granting and environmental clearance before building any structure or
making any landmark changes in specific areas. With the help of environment clearance
public hearings the people who would get affected by the building of the dam had a chance to
keep their say in front of the government and to expect a remedy from them. This fact is also
reiterated in the case of, Vedire Venkata Reddy And Ors. vs Union Of India (Uoi) And Ors.
on 17 November, 2004, 2005 (1) ALD 325: “The question, thus, remains to be decided is
about environmental clearance. As we have noticed above, it is not the stand of the State
Government that environmental clearance is not necessary before commencement of the
construction of the project. In any case, we would make reference on this point also to the
decision in State of Karnataka v. State of A.P. (supra). Two original suits were decided by
the Supreme Court - one filed by the State of Karnataka (O.S. No. 1 of 1997) and the other by
the State of Andhra Pradesh (O.S. No. 2 of 1997). In the suit filed by the State of Andhra
Pradesh, O.S. No. 2 of 1997, Issue No. 15 was whether Upper Krishna State II Multipurpose
Project could be executed without obtaining the environmental clearance under the
Environment (Protection) Act, 1986 and the notification issued by the Central Government in
1994 in exercise of its powers under the said Act and the rules made thereunder, which
mandatorily requires various analysis, including dam break analysis. Onus of this issue was
thus placed on the State of Andhra Pradesh. State of Andhra Pradesh had sought number of
reliefs in the suit, but essentially the reliefs related to the construction of Almatti Dam by the
State of Karnataka. Issue No. 15 had been framed on the plea raised by the State of Andhra
Pradesh that the State of Karnataka was likely to execute Upper Krishna Stage II
Multipurpose Project without getting environmental clearance under the Environment
(Protection) Act under the notification issued by the Central Government in exercise of
powers under the same Act and the Rules made thereunder”

5. GRIEVANCES:

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1. Petitioner says and submits that the petition is maintainable under Article 226 of the
Constitution of Kindia. Article 226, empowers the high courts to issue, to any person or
authority, including the government (in appropriate cases), directions, orders or writs,
including writs in the nature of habeas corpus, mandamus, prohibition, quo warranto,
certiorari or any of them.

2. Article 227 determines that every High Court shall have superintendence over all courts
and tribunals throughout the territories in relation to which it exercises jurisdiction (except a
court formed under a law related to armed forces).

3. The petitioner says and submits that the High Court of Sapota can interfere in policy
decisions made by the State of Sapota, as it is a well-established doctrine that the High Courts
can interfere in policy decisions made by the state if such policy decisions are grossly
arbitrary, irrational, unilateral, or in violation of the Fundamental Rights guaranteed by the
Constitution.

6. The petitioner raises the following GROUNDS:

1. The petition filed by “Protect Kindia” is maintainable in the court of law under article 226
and under article 227 of the constitution of Kindia.

2. The High Court can interfere in the matters of policy decision taken by the government of
Sapota owing to the fact that the policy made in the case at hand that is about building the
dam is opposed to Fundamental Rights, i.e. right to life and personal liberty which constitutes
the right to livelihood, after building of the dam the agricultural lands will be submerged and
water will be clogged and the same will happen with the residential land of the residents of
Fardapur will too be submerged.

3. The displacement of the people from their land results in the violation of article 21 of the
Constitution of Kindia. This violates the right to life and personal liberty which constitutes
the right to livelihood, after building of the dam the agricultural lands will be submerged and
water will be clogged and the same will happen with the residential land of the residents of
Fardapur will be submerged.

4. That the environment clearance certificate should not have been granted been granted fpr
the. Building of the dam, there should have been a hearing relating to the granting of the
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environmental clearance where the people who would be severely affected by the building of
the dam could request the government for rehabilitation and re-arrangement.

7. DELAY IN FILING PETITION

Petitioner says and submits that there is no delay in filing petition. Petitioner got copies of
agreements on 9th May 2022. Immediately this petition is filed.

8. DOCUMENTS RELIED UPON

Petitioner says and submits that the documents sought to be relied upon are as per index to
this petition.

9. INTERIM RELIEF PRAYED FOR

Petitioner says and submits that having regard to nature of grievance, it is just and necessary
to direct the Respondent No. 2 to stop the building the dam without considering the
livelihood of the villagers of the Fardapur district as it would lead to their agricultural as well
as residential land being submerged and getting clogged additionally, the Respondent 1
should withdraw the environment clearance certificate granted to respondent 2 and first hold
a public hearing for the cause and taking into consideration the issues of the residents of that
area give the environmental clearance for the building of the dam.

10. CAVEAT:

Petitioner says and submits that they have not received a notice of caveat from any of the
respondents so far.

11. RELIEFS PRAYED FOR:

A. The present Public Interest Litigation may kindly be allowed;

B. By issuing appropriate writ in the nature of mandamus or of like nature, the Respondents 1
and 2 may kindly be ordered to scrupulously follow the provisions of the article 14, article 21
& article 39 of the constitution of Kindia. Furthermore, they must also be ordered to be in
accordance of the environment laws.

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C. The respondents may also be ordered to keep in mind the welfare and more importantly
the livelihood of the people of the Fardapur district, as a consequence of the building of the
dam they must grant the inhabitants of the area with proper rehabilitation.

AND/OR
D) Any other suitable relief for which the petitioner is entitled for, may kindly be granted;

AND FOR THIS ACT OF KINDNESS AND JUSTICE THE PETITIONERS AS IN

DUTY BOUND SHALL EVER PRAY.

PLACE: FARDAPUR (SOMYA SHIVANI)

Advocate for Petitioner
DATE: 10.05.2022

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VAKALATNAMA

IN THE HIGH COURT OF JUDICATURE AT SAPOTA

BENCH AT FARDAPUR
______________________________ No. ______________ of _____________ DISTRICT :
______________________

________________________________ Application(s)/Appellant(s)/
Petitioner(s)/Caveator(s)

V ER S U S

________________________________ Respondent(s)/Non-Caveator(s)
I/We, _____________________________________________________________

_____________________________________________________________________
_____________________________________________________________________
Resident/s of _______________________________________________________ Tq.
____________ Dist. _____________ in the said matter hereby appoint

SOMYA SHIVANI
to appear and act for me/us/ as my/our Advocates in the above said matter. Witness my/our
hand/s this _______________ day of ____________ 2020

Witness : ________________________ ________________________

Accepted : ________________________ ________________________

(Clients Signature ) _________________________________

_________________________________

_________________________________
_________________________________

(Signature of Advocate)
Filed in Court on _____________________ SOMYA SHIVANI

Flat No. 2, Shivkrupa Apartment, Bank Colony,

Agni, Fardapur-431 009.
Mob. No. XXXXXXXXX, E-mail ID : XXXXXXXX

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