Disclaimer: The moot proposition is a work of fiction and created only for academic purposes.

Names, characters, businesses, places,

events, locales, and incidents are either the products of the author’s imagination or are manifested in a fictitious manner. Any resemblance
to actual persons, living or dead, or actual events is purely coincidental.

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 BEFORE THE SUPREME COURT OF PENNSYLVANIANA
(Civil Appellate Jurisdiction)
SPECIAL LEAVE PETITION
Special Leave Petition (Civil) No. 15324 of 2022

JAMES (JIM) HALPERT

MICHAEL GARY SCOTT
DUNDER MIFFLIN TRAVEL COMPANY………..…………………………………………………Appellants

v.

SCHRUTE FARMS INC…………………....…………………………………………………………Respondents

STATEMENT OF AGREED FACTS

1. Agrotourism refers to the agriculturally based operation which entails people visiting a farm or a ranch for
personal, leisure or recreational purposes. ‘Schrute Farms’, a small bed and breakfast on the outskirts of a rural
town called Scranton in Pennsylvaniana, besides being a popular agritourist attraction, is also the residence of
Dwight and Mose Schrute (collectively referred as the “Schrute Brothers”). Surrounded by pristine lagoons
and scenic beaches topped with rich cultural history, specifically pertaining to the famous battle of ‘farm lands
of the Schrute Dynasty’, makes Schrute Farms a quintessential choice for an enjoyable, laidback
vacation/staycation.

2. Worried by the burgeoning infiltration of multi-national giants having the likes of Airbnb and Homeaway, the
Schrute Brothers attempted to customize their offerings and distinguished Schrute Farms basis ‘homely
experience, personalized cuisines, tractor tour of the blueberry fields, goat-milking lessons, beet-farming
demonstrations and bedtime story requirements’. Quite naturally, Schrute Farms made a name for itself fairly
quickly and allured a large number of beet enthusiasts. A satisfied couple posted the following review on
TripAdvisor:

“The architecture mirrored the quaint Tuscan beet farms and the natural aroma of beets reminded us of simpler times. We did
not want to leave our rooms. The informative lecture delivered by Dwight satisfied our beet curiosity. Plenty of parking! Schrute
Brothers’ attention to detail and devotion to cleanliness was limitless. Fresh food was prepared using meat skinned, cleaned and
cut in the humongous slaughterhouse. From their enthusiastic welcome to the last wave good-bye, Schrute Farms delivered.”

3. In December 2019, Schrute Farms witnessed an influx of guests after being featured on TripAdvisor and Yelp.
As a result, Schrute Farms’ only chef, Ryan Howard was unable to keep up with the demand for food. It was
at this point that Mose looked to his closest neighbour, Jim Halpert, for help. Jim Halpert, a resident of
Scranton, was a seasoned local. He has previously worked as a salesman at a sports marketing company, Athlead
in a big city as well as a wilderness guide. Much before his association with Schrute Farms, he took guests of
Schrute Farms on wildlife spotting trips for free. Accordingly, when Mose approached Jim to cook for Schrute

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 Farms during the harvest season, he promptly agreed to help. Although there was no formal or written
contract, it was agreed that Jim would work as a fixed-term contractor from March 01, 2020 until April 30,
2020 and Schrute Brothers would pay PNR1 25,000 to Jim for every 10 meals prepared. While Jim was
expected to work with Ryan, it was agreed that he would take culinary instructions from Ryan and Ryan would
decide the dishes that were to be served to the guests.

4. Jim and Ryan have not been on the best of terms, ever since Ryan’s brief stint with Athlead as the cafeteria
manager and chef. Jim had once complained to the office manager about the quality of food being served in
the office cafeteria. It was also rumoured that Ryan used to spit on ‘Big Tuna Sandwich’, Jim’s favourite meal.
The tension between the two never quite dissipated. When Ryan gave Jim the recipe for the Chicken Beet
Salad, Jim deliberately and consciously ignored the instructions labelled ‘DO NOT MIX TUNA’. He assumed
that the instructions were Ryan’s way of establishing authority and added Tuna to improve the salad.

5. Unfortunately for Jim, the Chicken Beet Salad was consumed by Drake, a guest at Schrute Farms, who was
severely allergic to Tuna. Drake suffered from anaphylactic shock and was immediately rushed to the nearest
hospital, where he regrettably died. Bewildered by this conspicuous development, Jim was laid off pre-
maturely, Ryan was sent on a garden leave and Michael Gary Scott was hired as a full-time employee.

6. Michael, although a fantastic cook, spent most of his time procrastinating and distracting others. His laid-back
approach more often resulted in lower than expected productivity and he fundamentally subscribed to the
idea that if one really wants to impress the boss, one has to go in there and do mediocre work, half-heartedly.
On account of sporadic meal orders between lunch and supper, he frequently took naps in the kitchen and
empty bedrooms. As guests were not permitted to enter the kitchen, nobody really complained and the Schrute
Brothers had no clue about Michael sleeping on the job. They were under the impression that Michael was
available and serving per needs and requests of the guests.

7. On Pretzel Day, which is always busier than usual, after cooking over 27 different dishes, Michael fell asleep
at the swimming pool, situated right behind the kitchen. On hearing a strange noise in the kitchen, Michael
abruptly woke up and without gaining full control of his senses, he grabbed the frying pan and bashed the
head of the person, believing them to be an intruder. As it turned out, the alleged intruder was Meredith
Palmer, a guest at Schrute Farms who entered the kitchen looking for peanuts and salt. The alleged intruder
collapsed on the floor and had to be rushed to the hospital.

8. Occurrence of such ill-omened incidences compelled the Schrute Brothers to re-evaluate their business
strategy. On account of difficulties in managing the overwhelming demand and to ensure a hazard-free
environment for the guests, Dwight shut down the slaughter-house and restricted the number of guests by
instituting a pre-booking travel system. Prospective guests were required to pre-book through a limited

1 PNR refers to Pennsylvanian Rupees, the official currency of the Republic of Pennsylvaniana.

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 number of travel agents. The effect of this new policy was that until and unless a guest had actually booked
through a designated contractor, they could not stay at Schrute Farms.

9. On August 2020, Dunder Mifflin Travel Company (“Dunder Mifflin”), a private company incorporated in
Scranton was awarded the contract for the exclusive sale of Schrute Farms packages for certain selected cities
of Pennsylvaniana. Dunder Mifflin was a small, family-run company started by Pam Beesly and her children
Cecelia and Phillip. Pam and Mose were engaged to be married for three years until they called it off for
unknown reasons. The word through the grapevine is that they still have feelings for each other but it is
unlikely to be pursued by either of them. The quantum of work that Dunder Mifflin secured from Schrute
Farms was sizeable, so much so that almost immediately after the commencement of its relationship with
Schrute Farms, Dunder Mifflin closed down its other operations and solely focused on Schrute Farms.

10. The contract (“Old Contract”) between Dunder Mifflin and Schrute Farms (collectively “Parties”) inter alia
contained the following terms:

a) The contract was executed on 17 August 2020 for a period of 1 (one) year. Neither Party was under an obligation to
renew the contract;

b) The reservation fees shall be paid directly to Schrute Farms without any deduction;

c) At the end of each month, Dunder Mifflin shall issue an invoice in favour of Schrute Farms for the Commission (defined
hereinafter) based on the preceding month’s reservation fees. Dunder Mifflin’s invoices shall be paid within 7 (seven)
days from the date of issuance of such invoice; and

d) Commission shall refer to 6.5% (six point five per cent) of the reservation fees payable by the guests to Schrute Farms.

11. For the initial 6 months, business ran smoothly for both the Parties. In the last 6 months of the Old Contract,
the payment of Commission was delayed. In April 2021, no Commission was paid to Dunder Mifflin and
from thereon, Commission was either significantly low or not paid at all.

12. In July 2021 as the contract neared the end of its term, Schrute Farms laid down the following two choices
for Dunder Mifflin:

a) The Old Contract would be terminated in accordance with its terms, and Schrute Farms would find
an alternative travel agency for the designated cities; or

b) The Parties would execute a new contract (“New Contract”) on the same terms as the Old contract,
with two revisions as set out below:

1. The Commission payable to Dunder Mifflin would be increased to 9.5% (nine point five per cent); and

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 2. Dunder Mifflin hereby and in consideration of this New Contract, agrees to irrevocably waive any and all
claims, including but not limited to any claims vis-a-vis any unpaid Commission, that it has or may have
against Schrute Farms (the “Waiver & Release”).

13. Given Dunder Mifflin’s dependency on Schrute Farms, its precarious financial position and Pam’s conflicted
feelings, Pam felt that her hands were tied. Had Pam lost the Schrute Farms’ contract, Dunder Mifflin may
have to be wound up and that Pam, personally, may have faced imminent bankruptcy. On 27 July 2021, Pam
agreed to the revised terms and signed the New Contract.

14. It was common knowledge (and is not denied) that Schrute Farms (a) failed to pay Commission to other
agents/contractors; and (b) offered similar choices as that given to Dunder Mifflin. Some accepted these
allegedly ridiculous terms and some negotiated out of the Waiver & Release.

15. As expected, Schrute Farms slipped back into its pattern of failing to pay the revised Commission under the
New Contract. On December 2021, Dunder Mifflin brought a claim for the Commission it believed it was
owed from April 2021 onwards (“Mifflin Claims”). Schrute Farms settled the claims it believed it owed under
the New Contract (i.e. 27 July onwards) but refused to pay anything under the Old Contract. Under the Old
Contract, according to Pam Beesly, PNR 375,000 plus interest was payable by Schrute Farms to Dunder
Mifflin.

16. Dunder Mifflin claimed that one of the primary reasons why it executed the New Contract was the threat of
withdrawal of business brought in by Schrute Farms. The threat deliberately imposed by Schrute Farms created
pressure on Dunder Mifflin so much so that it had no feasible choice, and was pressured, to agree to the New
Contract. It further alleged that Schrute Farms never intended to actually part ways with Dunder Mifflin - All
it ever wanted to achieve and obtain was Waiver & Release.

17. Schrute Farms fiercely refuted the Mifflin Claims and argued that there was nothing unlawful about Schrute
Farms’ conduct and it had every right to terminate the Old Contract and offer new and amended terms. It
was the contention of Schrute Farms that the doctrine of lawful economic duress does not extend to situations
where a person acted in good faith believing that it was entitled to behave in the manner it did. Accordingly,
the Waiver & Release Clause should be enforced.

18. Simultaneous with the Mifflin Claims, Drake’s legal heirs and Meredith initiated proceedings against Schrute
Farms for inter alia negligence and battery and sought the following:

a) Drake’s legal heirs demanded PNR 10,000,000 alleging that Schrute Farms had a duty of care vis-a-vis
Drake when it knew about his allergies, and that it failed in its duty, leading to Drake’s wrongful death.

b) Meredith demanded PNR 100,000 in damages for medical and hospital fees.

(The claim of PNR 10,000,000 and PNR 100,000 is hereinafter collectively referred to as “Food Claims”).

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19. In connection with the Food Claims, Schrute Farms commenced proceedings against Jim Halpert and Michael
Scott. Schrute Farms argued that they are not responsible for Jim and Michael’s actions, and that Jim and
Michael should be held liable and responsible towards satisfaction of the Food Claims.

20. In relation to both Food Claims as well as Mifflin Claims, the appropriate judicial authorities ruled in favour
of Schrute Farms. The lower courts (including the jurisdictional High Court) inter alia held that the Schrute
Farms was not vicariously liable for (a) Jim’s actions that resulted in Drake’s allergic reaction and the act of
mixing Tuna was unwarranted; (b) Michael’s actions, as his conduct was neither authorised, nor was under the
scope of employment. Consequently, in July 2022, special leave petitions (“SLP”) were filed before the
Hon’ble Supreme Court of Pennsylvaniana. The parties have expressly submitted to the apex court’s authority
and jurisdiction to entertain these appeals. On August 20, 2022, the Supreme Court passed an order tagging
these SLPs and directed that these be listed for final hearing on a non-miscellaneous day in September 2022.

21. The following issues were identified by the Supreme Court of Pennsylvaniana:

a) Whether Schrute Farms is liable to pay damages in relation to the Food Claims under the law of torts;
and

b) Whether Schrute Farms is liable to pay the remaining Commission in relation to the Mifflin Claims
under the law of contracts.

22. The laws of Pennsylvaniana are pari materia with that of India. The Hon’ble Supreme Court of Pennsylvaniana
also relies heavily on common law concepts and judicial precedents.

***

Note: Participants are free to explore other issues and may make arguments on creative lines. Resolution of disputes between Schrute
Farms & Drake/Meredith is outside the scope of this moot proposition. Employment related concepts only to the extent necessary to
argue the issues should be utilised. Questions under India’s new labour codes are outside the scope of this moot proposition. For any
questions/clarifications, please reach out to the Moot Court Committee at sol.mcc2022@gmail.com.

*This Moot Proposition is drafted by Pranjal Doshi.