Moot Memo Faizan

TEAM CODE – AE
1ST JAMIA HAMDARD UNIVERSITY

INTRA MOOT COURT
COMPETITION,2022 1ST -4TH FEBRUARY
BEFORE THE HON’BLE

SUPREME COURT OF SELEXA
UNDER ARTICLE 32 OF THE CONSTITUTION OF SELEXA
IN THE MATTER OF:

RIGHT OF PEOPLE (NGO) (PETITIONER)
V.
UNION OF SELEXA AND ORS. (RESPONDENT)
ON SUBMISSION TO THE HON’BLE COURT OF SELEXA

WRITTEN SUBMISSION ON BEHALF OF
PETITONER
MEMORIAL ON BEHALF OF THE PETITIONER
1st JAMIA HAMDARD INTRA MOOT COMPETITION 2022
MEMORIAL ON BEHALF OF THE PETITIONERS

TABLE OF CONTENT
INDEX OF AUTHORIITIES-------------------------------------------------------------------3-4
STATEMENT OF JURISDICTION------------------------------------------------------------5
STATEMENTS OF FACTS---------------------------------------------------------------------6-7
SUMMARY OF ARGUMENTS----------------------------------------------------------------8-9
ARGUMENTS ADVANCED-------------------------------------------------------------------10-18
PRAYER--------------------------------------------------------------------------------------------19
INDEX OF AUTHORITIES
*LEGISLATION REFERRED
1.THE EPIDEMIC DISEASE ACT, 1897
2.DISASTER MANAGEMENT ACT,2005
*BOOKS REFERRED
1.INDIAN CONSTITUTIONAL LAW – MP JAIN
2. LAW AND MEDICINE -NANDITA ADHIKARI
3. PUBLIC HEALTH POLICY AND LAW; - SAROJ KUMAR CHOUDHARY
*ARTICLES
1. VIDHI CENTRE FOR LEGAL POLICY- AN ANALYSIS OF THE CURRENT STATUS
AND LEGAL CHALLENGES
2.BAR & BENCH- COMPULSORY VACCINATION FOR COVID-19 LEGAL POSSIBILITY
OR VIOLATION OF FUNDAMENTAL RIGHTS?
3.THE INDIAN EXPRESS - RIGHT TO FREE VACCINE- A CONSTITUTIONAL
MANDATE
4. THE PRINT- GUJARAT HC RESTRAIN IAF
5. IPLEADERS- VIOLATION OF ARTICLE 21 OF MIGRANT WORKER DURING COVID
*WEBSITES
1. SCC ONLINE – WWW.SCCONLINE.CO.IN
*CASE REFERRED
1.K.S PUTTUSWAMY V.S UNION OF INDIA, SC (2017)
2.REGISTRAR GENERAL V MEGHALAYA HC (23.06.2020)
3.MANEKA GANDHI VS UNION OF INDIA, SC (25 JAN 1978)
4.YOGENDER KUMAR VS INDIAN AIRFOCE & 1 OTHER, GUJARAT HC (22/06/2021)
STATEMENT OF JURISDICTION
THE PETITIONER HUMBLY SUBMITS TO THE JURISDICTION OF THIS HONOURABLE

COURT UNDER ART 32 OF THE CONSTITUTION.THE PETITIONER HAS APPROACHED
THIS HONOURABLE COURT IN APPREHENSION OF THE VIOLATION OF RIGHTS
THAT SUDDENLY IMPOSED LOCKDOWN IN THE COUNTRY AND MADE VACCINE
COMPULSORY FOR EVERYONE IN THE COUNTRY VIOLATES THE FUNDAMENTAL
RIGHTS. THEREFORE, THE PETITIONER MAINTAINS THAT THE JURISDICTION OF
ART 32 OF THE CONSTITUTION, WHICH PROTECTS THE CITIZENS OF SELEXA FROM
ANY VIOLATION OF THEIR FUNDAMENTAL RIGHTS, IS APPLICABLE IN THE
PRESENT CASE.
STATEMENT OF FACTS
1. The country of Salexa is located in South Asia. It has the second largest population and the sixth
largest economy in world. It has been categorized as a developing country. It has trade networks
with a number of countries across the world. In the year 2019, a deadly, highly transmissible virus
called Rovid-19 struck the world. It initially began in the Buhan, a state in the country of Shina.
2. As time passed, by Mid-January 2020, the virus had reached various parts of the world. On 30th
January 2020, Salexa reported its first case of the virus. Slowly and gradually by April 2020, the
virus had spread rapidly across the country with approximately 5500 infections and 150 deaths.
Keeping in mind the nature and behaviour of the virus, World Health Organization (WHO)
declared Rovid-19 as a pandemic in March 2020.
3. On 24th March 2020, the Prime Minister of Salexa announced that the country would be put
under a nationwide lockdown for a period of 21 days starting from 25th March 2020. Ministry of
Home Affairs (MHA) issued the relevant order to this effect. As a result, a number of hardships
had to be faced by the people of the country, especially the migrant workers who were seen walking
long distances back to their hometowns and villages. A number of migrant workers were reported
to have died.
4. As the infections continued to surge, the lockdown had to be extended until 30th May 2020
through orders passed by the MHA to the effect. The phased and gradual reopening and unlocking
began from 1st June 2020. Worried by the surge in cases, various countries starting working on
vaccines to combat the virus.
5. Two influential pharmaceutical companies in Salexa developed one indigenous vaccine each.
After getting the Emergency Use Authorization by the Drug Regulator of Salexa on 16th January
2021, Salexa kick-started the vaccine administering process for front line workers and doctors.
This was later extended to voluntary vaccination of those above 60 years of age and those aged
45 and above with specified co- morbidities. Subsequently, the government announced that from
May 1, 2021 anyone above 18 years of age would now be vaccinated. After a rough patch with a
shortage of vaccine for the initial few months, the government streamlined the production and
distribution. Pertinent to mention, the government targets to vaccinate the eligible population by
December 2021.
6. Even after data about the efficacy of the vaccine emerged, many people are still reluctant to take
the vaccine. This prompted the central government to emphasize the need to get vaccinated for
protection from the virus. In view of this, many states and UTs made the vaccine mandatory for
office staff, teachers, audience in cinema halls in order to check the spread of the virus. One such
state is the State of Kaya.
7. A teacher working in one of the schools in Kaya did not want to take the vaccine due to his
beliefs. Due to his reluctance of not taking the vaccine, the school suspended him. Moreover, many
reports of people being denied entry into their workplaces and movie halls started to emerge.
Similar incidents were reported in other states of the country and the same gained widespread
media attention.
SUMMARY OF ARGUMENTS
1. WHETHER THE PIL IS MAINTAINABLE.
The present Public Interest Litigation (PIL) is maintainable under Article 32 of the constitution.
Article 32 affirms the right to move the supreme court if a fundamental Rights is violated. And in
this Present PIL it violated a myriad of fundamental rights including the right to privacy, right to
work, and right to livelihood. The order imposing Mandatory Vaccination do not give a rational
choice to an individual to take a vaccine. This violates this their right to decisional autonomy and
self-determination. With the provisons of article 14,19, &21 of the constitution.
2. WHETHER THE DECISION BY STATES TO MAKE VACCINES MANDATORY FOR

VARIOUS ACTIVITIES /PROVISION OF SERVICES IS LEGITIMATE.
By Linking Vaccinations to essential services these orders have a chilling effect on the right to
life, right to livelihood and the right to carry on any trade, Profession or business. Many High
courts have recently dealt with this issue in the individual cases concerning Rovid-19 vaccination.
State government’s order that made vaccination compulsory for various activities / provision /
services like local vendors, taxi drivers etc are violative of the right to livelihood and the right to
practice a trade.
3. WHETHER THE MHA ORDER THAT LED TO THE MIGRANT CRISIS WAS
ARBITRARY, DISPROPORTIONATE AND VIOLATIVE OF THEIR FUNDAMENTAL
RIGHTS.
This Sudden Lockdown order has been deprived these migrant workers of their right to life &
liberty, which is against article 21. As a result, the nation witnessed mass exodus, of these migrant
workers going back to their native places. And this led to the migrant crisis due to the lack of
transport facility they have to walk thousands of kilometres, without food and shelter and many
Have succumbed to death in the process. If the government-imposed curfew for some time and
arrange transportation for the migrant worker and help in returning to their native city or villages
we have saved so many lives.
4.WHETHER THE TEACHER IN KAYA CAN LEGITIMATELY REFUSE TO BE

ADMINISTERED WITH THE VACCINE ON THE CONSTITUTIONAL GROUNDS.
Teacher in kaya can legitimately refuses to be administered with the vaccine on the basis of article
14 and 21 of the constitution. If administrated force to take vaccine was not only contrary to the
guidelines of the union of selexa but also Article 14 and 21. While forcing to take vaccine
Administered have other option to give Ayurvedic medicines to boost immunity against rovid-19.
ARGUMENT ADVANCED
1. WHETHER THE PIL IS MAINTAINABLE.

Under article 32, a person has a fundamental right to move the Supreme Court for the enforcement
of the fundamental rights, and the Court has the power to enforce such rights by issuing writs. For
enforcing fundamental rights by filing a writ petition under article 32, the existence of any
alternative remedy is no bar to the Supreme Court because article 32 is in itself a fundamental
right. The emergence an enlargement of the public interest litigation (PIL) jurisprudence has
further advanced the enforcement of fundamental rights and public interest. It is also to be noted
that for exercising the jurisdiction under article 32, it is not essential that the person who is the
victim of infringement of his fundamental right should personally move the Court, for the Court
can, on its own, take cognizance of the matter and proceed Suo motu or in a PIL filed by any
public-spirited person. The Supreme Court, in particular, has to be credited for laying down
guidelines having the force of law till the time the legislature enacts a law in that area and fills-in
the gap, and also for issuing necessary directions in the case of inaction on the part of the executive,
so as to uphold and protect the rights and interests of the people. Through the PIL jurisprudence,
the Supreme Court has brought forth positive changes in India by issuing necessary directions for
protecting fundamental rights of the marginalised sections of the society, for protecting and
preserving the ecology and environment, and also for maintaining the probity, transparency and
integrity in governance. This has been the sublime stature of the Supreme Court of Selexa.
This section of the paper analyses the approach of the Supreme Court of Selexa while dealing with
the issues concerning migrant workers during the first wave of the Rovid-19 crisis. The mass
exodus of migrant workers in the wake of nationwide lockdown raised quite a few questions.
Legally speaking, the mass movement of migrant workers was a violation of the lockdown
measures to contain Rovid-19. At the same time, it also raised questions relating to their
fundamental rights. Under article 32 of the Constitution, also a petition was filed by Portioner
for the enforcement of the fundamental right, under article 21 of the Constitution, of migrant
workers who were sternly affected by the 21-day nationwide lockdown ordered by the Government
of Salexa, without any prior intimation
Article 21 of the Constitution manifests that the State has a solemn duty to ensure the well-being
with dignified life and liberty of every person.
Through a catena of judgments, the Supreme Court has given a very wide meaning to the
expression life or personal liberty after the famous Maneka Gandhi judgment. Right to life under
article 21 means the right to live with human dignity, free from exploitation. Today, right to life
and personal liberty includes a host of rights necessary for ensuring dignified life with liberty. All
the way through its various judgments, the Supreme Court has played a mammoth role in exploring
and expanding the frontiers and new dimensions of article 21, and it is left to the ingenuity of the
Courts to explore this concept to the extent they can in the Indian social context
2. WHETHER THE DECISION BY STATES TO MAKE VACCINES MANDATORY FOR

VARIOUS ACTIVITIES /PROVISION OF SERVICES IS LEGITIMATE.
Decision of state to make vaccine mandatory for various Activities/Provision/ of services is not
legitimate Such coercive vaccination orders are not immuned by the following legal challenges:
Violation of Fundamental Rights:
Violation of Right to Privacy
The orders imposing mandatory vaccination do not give a rational choice to an individual to take
a vaccine. This violates their right to decisional autonomy and self-determination as articulated in
KS Puttaswamy vs. Union of India. The Supreme Court in Puttaswamy recognised that the right
to privacy not only includes a person’s rights relatable to her physical body but also protects an
individual’s autonomy over fundamental personal choices.
While refusing the vaccine falls within the scope of the right to privacy, the Madras High Court
had doubted whether it could be exercised in the interest of public health. To determine the
restrictions that might be placed on this right in the public interest, the questions of legal validity
of such restrictions and proportionality with respect to their objective will also have to be looked
at in addition to a legitimate aim.
Violation of Right to livelihood and right to carry on trade or profession
By linking vaccinations to essential services, these orders have a chilling effect on the right to life,
right to livelihood and the right to carry on any trade, profession or business. Many High Courts
have recently dealt with this issue in individual cases concerning ROVID-19 vaccination. For
instance, the Meghalaya High Court recently observed that the state government’s order that made
vaccination compulsory for shopkeepers, local vendors, taxi drivers, etc. are violative of the right
to livelihood and the right to practice a trade. The court further stated that vaccination cannot be
mandatory especially when there exists no reasonable nexus between vaccination and prohibition
of the continuance of occupation and/or profession in the present case.
The Gauhati High Court relied on the Meghalaya High Court’s order declaring the Standard
Operating Procedure (SoP) issued by the State of Mizoram restricting unvaccinated people from
leaving houses, opening/managing shops, or operating public transport as arbitrary and not in
consonance with the provisions of Articles 14,19 & 21 of the Indian Constitution.
The Manipur High Court also recently observed that orders denying people their livelihood vis-a-
vis vaccination status would be illegal on part of the State, if not unconstitutional.
The Nagaland bench of the Gauhati High Court had also directed the State to modify a SoP
regarding mandatory vaccination of teaching and non-teaching staff as a precondition to opening
schools and colleges on the ground that vaccination cannot be made compulsory.
As seen above, in most such cases, the Courts believe that coercive vaccination orders which
violate the fundamental rights of people are invalid.
Inadequate legal route:
The Supreme Court in Puttaswamy held that there is a three-fold requirement for the breach of
personal liberty. They are the existence of a valid law, a legitimate state aim, and proportionality.
The orders concerning coercive vaccination can qualify for legitimate state aim as they have a
larger public health interest. However, these orders do not qualify for the other two requirements.
Absence of a valid law
In the current situation, coercive vaccination restricting the fundamental rights of people is being
carried out through executive orders by state or local governments. This poses the question: Can
these executive orders be qualified as valid law in the present context? The Gauhati High Court,
while striking down the Mizoram government’s SoP discussed above, observed that given the
prevailing conditions, the fundamental right to practise any profession, or to carry on any
occupation, trade or business under Article 19(6) can be restricted by law and not by way of an
executive instruction.
Disproportionate state actions
Going by the three-fold requirement laid down in Puttaswamy, the restriction should be
proportionate to the purpose it seeks to achieve. However, state actions to vaccinate people in this
manner are disproportionate as the benefits of vaccination cannot be justified to deprive people of
their food and livelihood.
While the purpose of coercive vaccination is in the larger public interest, it cannot be continued in
this form as it is not being done proportionately under a valid law.
Against the principle of equity:

Lack of access to vaccines
The orders of forced vaccination come at a time when the vaccine shortage is still prevalent in the
country, especially in remote and rural areas. In this situation, penalising individuals by cutting
their rations and salaries goes against the principle of equity as it is not fully accessible. In the
Mizoram SoP case, the Gauhati High Court observed that the unvaccinated citizens of the State
cannot be faulted due to the States’ failure in not completing the vaccination of the targeted
population.
Unreasonable discrimination between vaccinated and unvaccinated people
Coercive vaccination orders cause unreasonable discrimination against the unvaccinated

population without a reasonable nexus because people who have been vaccinated with the first
dose of the vaccine are allowed to earn their livelihood while their unvaccinated counterparts
cannot. again, the Gauhati High Court in the Mizoram SoP case observed that “there is nothing to
show that vaccinated persons (first dose) cannot be infected with the coronavirus or that they
cannot be spreaders. If both unvaccinated and vaccinated people with the first dose have to follow
COVID-appropriate behaviour, there is no reason to discriminate only against unvaccinated
persons and deprive them of their livelihood.”
WHETHER THE MHA ORDER THAT LED TO THE MIGRANT CRISIS WAS
ARBITRARY, DISPROPORTIONATE AND VIOLATIVE OF THEIR FUNDAMENTAL
RIGHTS
the lockdown situation in the country because of the outbreak of coronavirus, has put them in a
precarious condition. On one hand, they have lost their jobs, while on the other, they don’t have
money to survive at their native place. This sudden lockdown has deprived these migrant workers
of their right to life & liberty, which is against article 21. As a result, the nation witnessed mass
exodus, of these migrant workers going back to their native places. Due to the lack of transport
facility they have to walk thousands of kilometres, without food & shelter and many have
succumbed to death in the process. Though the lockdown was inevitable step by the government,
in order to check the spread of the coronavirus but had it been done keeping in mind the situation
of these migrant workers, we would have saved lives of many migrant workers who died last year.
Many migrant workers lost their jobs during the lockdown, which was their only source of income.
Due to lack of job these distressed workers have to come back to their hometown without any job,
shelter, food & transportation. Around 1.14 crores migrant workers migrated to their hometown
since 25th March 2020. During their travel many have faced the brutality of police, in one incident
a migrant worker from Orissa succumbed to death, being beaten by the police on account of
violating social distancing norms. Another major challenge faced by the migrant worker is
unemployment. On May 29th, 2020, a 50-year-old man, working in a hotel in Shahjahanpur district
(UP) allegedly committed suicide by jumping in front of a train, leaving behind his wife, mother
& four children. He mentioned in his suicide note that he was left penniless after losing his job due
to lockdown and was unable to buy other essential commodities, such as sugar, salt and milk. In
another incident two young men aged 22 and 20, working in Delhi & Mumbai respectively
committed suicide on May 27th.
Reports show that the migrants were not able to leave the city and had to struggle to get food and
shelter. As many as 16000 people filled 220 shelter homes in Delhi last year. The number kept on
increasing but these shelter homes didn’t have enough space to accommodate them. All shelter
homes were overcrowded, breaking the protocol of social distancing norm. Article 21 of the Indian
Constitution states Right to Life and Liberty is one of the fundamental rights given to every human
being in the country and it has to be protected especially in case of these migrant workers who are
socially and economically weak to fight for their own rights
As per section 23, of the Inter-State Migrant Workmen (Regulation of Employment and Conditions
of Service) Act, 1979, all the inter-State migrant workers are required to be registered with the
Government and the principal employer and the contractors have to maintain a register for the
same. Had this act been implemented properly we could have the details of these migrant workers
coming from different states. Rather the government accepted their failure to maintain
this data in the parliament. Having this data would have been a crucial precursor in planning the
lockdown as it would have greatly helped the state governments to smoothly plan the movement
of these migrant workers to their respective states. Not only the government can track the
movement of these workers but also plan for adequate shelter homes & arrange food for them even
before the implementation of lockdown, at the same time maintaining the protocol of social
distancing.
Considering the fact that the lockdown was necessary, and such chaos was expected, but it can be
controlled to a lot extent if we had proper data of these migrant workers. The government has to
make strict laws to ensure that this data is maintained by the employers and the contractors.
Unfortunately, the reality is many employers do not maintain this data, in order to avoid the
compliance burden. Though the new code on wages, 2019 has made the compliances simpler for
the employer and also introduced a new concept of Inspector cum facilitator who will not only
ensure the implementation of the compliances but also advice the employer in maintaining them.
Hope the government will learn a lesson from last year’s chaos & avoid it to repeat again
4.WHETHER THE TEACHER IN KAYA CAN LEGITIMATELY REFUSE TO BE

ADMINISTERED WITH THE VACCINE ON THE CONSTITUTIONAL GROUNDS.
Yes, The Teacher in Kaya can Refuse to take Vaccine on the constitutional ground are The
Meghalaya High Court Thursday held that forced vaccination violates fundamental rights as
mandated under Article 19(1)(g) of the Indian Constitution, Bar and Bench reported.
The Ministry of Health and Family Welfare recently released FAQs stating that COVID-19
vaccination is optional. Furthermore, no government law or notification has been issued that allows
employers to make it necessary for their employees. As a result, entities cannot make vaccination
mandatory for their employees on legal grounds. To protect its already existing and vaccinated
employees, the employer can include a term or condition in its new employment contract that
requires new employees to produce their vaccination certificate as an obligatory
document for employment. Employers cannot force employees to be vaccinated, but they may
always encourage and educate them to do so in order to enhance workplace health.
It is important to note that a company cannot fire employees for declining to take the vaccine.
Employers, on the other hand, have the authority to refuse such employees admission to the
workplace, as long as the employees’ rights and obligations under the employment agreement are
not jeopardised. Employers can also reward employees who have been vaccinated while refusing
to reward employees who refuse to acquire the vaccine. Walmart, for example, is rewarding
employees who can show proof of vaccination with a $75 bonus.
The Meghalaya High Court Thursday 24 June 2021 held that forced vaccination violates
fundamental rights as mandated under Article 19(1)(g) of the Indian Constitution, Bar and Bench
reported.
Moves Gujarat HC saying decision to dismiss him is contrary to Centre’s guidelines
The Gujarat High Court has issued a notice to the Indian Air Force on a petition filed by one of its
personnel posted in Jamnagar challenging the show-cause notice issued to him for termination of
service after he expressed his unwillingness to get vaccinated against COVID-19.
A Division Bench of Justices A.J. Desai and A.P. Thaker on Tuesday issued the notice to the IAF
and the Central government and also directed the IAF not to take any coercive action against the
petitioner till July 1.
Petitioner Yogender Kumar, an IAF corporal, had moved the court seeking a direction to quash
the May 10, 2021 show-cause notice, in which the IAF stated that his stand against vaccination
“verges to gross indiscipline, and his continuation in the service is likely to adversely impact the
health of other air warriors and AF civilians.
The IAF is of the opinion that your continuation in the disciplined force like Indian Air Force is
undesirable and you need to be separated from the service,” the petitioner said quoting the notice
issued to him.
The plea said the decision of respondent no. 1 (IAF) to dismiss the petitioner for refusing to take
vaccine was not only contrary to the guidelines of the Union of India, but also violative of Articles
14 and 21. “The termination from job due to unwillingness to take COVID-19 vaccine is
completely illegal, unconstitutional and arbitrary on part of respondent no.1,” Mr. Kumar said in
his plea, seeking the court to quash the notice and direct the IAF not to force him to get vaccinated.
The petitioner on February 26, 2021 wrote to the Commanding Officer of their squadron
expressing his unwillingness to take vaccination against COVID-19.
PRAYER
Wherefore, in the light of the issues raised, arguments advanced and authorities cited, it is most
humbly and respectfully requested that the Hon’ble Court adjudges and declares that:
1.To issue an order to the govt instead of suddenly lockdown-imposed curfew time to time and
make arrangement for the migrant workers for returning of their hometowns because suddenly
imposing lockdown create panic situation in between public.
2. To issue a prohibitary order restraining respondent in proceeding with this to made vaccination
compulsory for every citizen.
The Court may also be pleased to pass any other order, which this Hon’ble Court deem fit in the
interest of Justice, Equity and Good Conscience.
Sd/-
………………………………………………..
COUNCELS FOR THE
PETITIONER

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TEAM CODE – AE

1ST JAMIA HAMDARD UNIVERSITY

BEFORE THE HON’BLE

UNDER ARTICLE 32 OF THE CONSTITUTION OF SELEXA

IN THE MATTER OF:

ON SUBMISSION TO THE HON’BLE COURT OF SELEXA

MEMORIAL ON BEHALF OF THE PETITIONER

1st JAMIA HAMDARD INTRA MOOT COMPETITION 2022

MEMORIAL ON BEHALF OF THE PETITIONERS

THE PETITIONER HUMBLY SUBMITS TO THE JURISDICTION OF THIS HONOURABLE

1. WHETHER THE PIL IS MAINTAINABLE.

2. WHETHER THE DECISION BY STATES TO MAKE VACCINES MANDATORY FOR

MEMORIAL ON BEHALF OF THE PETITIONERS

4.WHETHER THE TEACHER IN KAYA CAN LEGITIMATELY REFUSE TO BE

1. WHETHER THE PIL IS MAINTAINABLE.

2. WHETHER THE DECISION BY STATES TO MAKE VACCINES MANDATORY FOR

Violation of Fundamental Rights:

Violation of Right to Privacy

Violation of Right to livelihood and right to carry on trade or profession

Inadequate legal route:

Absence of a valid law

Disproportionate state actions

Against the principle of equity:

Lack of access to vaccines

Unreasonable discrimination between vaccinated and unvaccinated people

Coercive vaccination orders cause unreasonable discrimination against the unvaccinated

4.WHETHER THE TEACHER IN KAYA CAN LEGITIMATELY REFUSE TO BE

MEMORIAL ON BEHALF OF THE PETITIONERS

Moves Gujarat HC saying decision to dismiss him is contrary to Centre’s guidelines

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