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Answer 1) The case, People’s Union for Democratic Rights v.

Union of India, provides and reflects upon


some serious socio-economic realities of the country. Rule of law, though contended by various sections,
basically means that the law rules over everyone and no is one above the law. It is mostly concerned with
the officials of the state. The use of power by the Government should be done in accordance with the law
and through the procedure prescribed by it, within the legal limits. Various issues and concerns are raised
in the case pertaining to the rule of law which shall be discussed hereafter.

The case shows that how rule of law just exists on paper and the processes in the real world are actually
quite deviated from this concept. One of the principles of the theory of Joseph Raz is that courts should be
easily accessible. But as shown in the case and presented in the judgement, there seems to be existing two
parallel societies in the same country. One consisting of the rich, the resourceful, and the other consisting
of the poor, with the socio-economic barriers. The dual standards of justice as reflected by the behavior of
the judges, who champion themselves as warriors of justice when dealing with a claim to enforce
fundamental rights by a rich person with a team of lawyers while at the same time negating the PILs by the
poor and considering them a burden on the judiciary. The courts under the rule of law should give the
same opportunity to each person and have the same perspective to the nature of PIL be it by the poor or
the rich.

Power is one of the features of the society. These powers are vested in some authorities by the rule of law
and are used in accordance with it. Raz’s principle include that the discretionary use of these powers by
the officials or the court should not be allowed to pervert the law. The discretion shown by the magistrates
while deciding cases against violation of labour laws such as paying less than the minimum wage, and in
the end putting a meagre amount of fine for the violations which the violators don’t mind as the amount
earned because of the violation is way more than the fine. This in a way nullifies the purpose of the labour
law which was to improve the conditions of the work men. The magistrates are indifferent to the labour
violations and consider it too trivial a matter for serious punishment. This results in a privileged class of
people who are in a way above the law.

Ronald Dworkin saw rule of law as requiring substantive justice. It should encapsulate certain moral rights.
The content of the law is also important and not just the legality of the system. Rule of law act as a
principal of statutory interpretation. The court in the case gave new interpretations on its own when it
came to deciding for certain contentions. Justice Bhagwati interpreting the laws and articles keeping in
mind the purpose and the intent behind the laws. These laws were enacted to achieve certain purpose and
abolish the exploitation and hardship faced by many and to provide a just system. The rights conceptions
were kept in mind for making various decisions in the judgement. The respondents raised the question of
locus standi of the petitioners with respect to the PIL stating that it was not the petitioners’ rights whose
violations were being claimed and hence the redressal should not be available to them. But the court
giving due regard to the peculiar socio-economic conditions prevailing in the country due to poverty,
illiteracy and ignorance obstructing and impeding access to justice, made a decision to uphold the locus or
else it would have resulted in closure of the doors of justice for the needy and deprived a whole
community from getting the required treatment as laid down under the rule of law. The petitioners also
had the contention that Article 23 was not being violated as at least some amount of remuneration was
being given. But the court used the intent, purpose and the history behind the article to describe how the
Article did not only restrict itself to ‘begar’ and saw a person working and getting less than minimum wage
as forced labour and hence violative of the Article and taking away their basic human rights and
participation in the arrears of freedom and liberty in an egalitarian social and economic framework.

According to Lon fuller there should be an inner morality in the system and it should promote welfare of
the society. The government should provide a conducive environment for the citizen to reach its maximum
potential and have free society, directed to the good of each member. The situation as described in the
case reveals quite the opposite picture in reality. The conditions being provided to the workers do not even
provide the required dignity. What is even more horrifying is the fact that the principal employer in the
case is the Government itself which has the duty to look after the rights of the people and sets the
standard of dignity and rights to be provided to a person. The law in the situation prevails normatively and
lacks the implementation. A number of Acts are mentioned in the case which safeguard the rights of the
workmen such as the Inter-State Migrant Workmen (Regulation of Employment and Conditions of Service)
Act, 1979 but in reality the law is being violated and they are being deprived of their rights.

Three ombudsmen were appointed by the court to look see if the implementation of the Act is being
followed and the Government is making sure of it according to the directions of the court. This signifies
how even the government has to work under the law and Act according to it no matter working in a
sovereign function or not, describing one the few instances in the case where concept of rule of law is
being followed and even the government has to act accordingly.

The principles of AV Dicey envisages the supremacy of regular law and the absence of arbitrary power. But
the situation shows that even though the regular law prescribes the rights of the workmen but the actions
of the jamadars and the contractors deprive them of that. Even the Union of India accepts that the
workmen are receiving less wages because of the middlemen and are being exploited in this manner and
yet doesn’t care to take the actions for providing them with necessary. The principle also talks about
equality but even with the Act for equal wages yet the women are receiving even less money than the
male workers, describing how even though rule of law exists as a prominent concept yet not being applied
in the day-to-day life of a person.
Answer 2) The case highlights various characteristics of the crisis in the Indian legal system providing some
stark realities and describing how theories don’t work in real life because the vision is of the ideal and the
experience of the reality.

One of the biggest issues depicted and raised in the case is pertaining to the legitimation of law. Truly
“legality is not legitimacy” anymore for the people of the country. But what is even worse is that this
negation of law is not only by the ordinary citizens but also by the law makers and enforcers themselves.
As seen in the case a number of laws and rights of the workmen were being violated and the principal
employer in the case was the government itself. The Government did not play any active role to see if the
laws were being followed by the contractors and neglected the conditions of workmen. The Government
itself has a low level of commitment to the rule of law. This disregard by the lawmaker itself presents an
idea that law should be followed as far as it does not affect the pursuit of individual or group interests and
that generally rule following is unjustified and countervailing to these interests. This also has an effect of
reducing the regard shown by the people to the legitimacy of government and reduces the trust in the
lawmakers and the system as a whole. Also, even the magistrates when hearing labour violation cases, on
finding the accused guilty impose a partly fine on the violator even though the violations themselves have
earned him/her a huge profit. This provides an incentive instead of a punishment and further leads to the
depreciation of the stature of law in the eyes of the people. Hence, these rules are seen as occasions of
discretionary manipulation in a
complex process and this power to bend the law is perceived as the real power.

The case talks about the difference between the rich and the poor with respect to the access to courts. The
rich having all the resource can access courts easily and ask for remedy to enforce his rights using a team of
lawyers. On the other hand, the poor doesn’t have any resources. They cannot fight injustice or any abuse
of power. As shown in the case they can’t even enforce their fundamental rights and have the basic dignity
they are entitled to as workers. This divide between the people of the same society shows the lack in the
judicial system. The judges’ views towards the poor enforcing their rights through PIL, considering it a
burdening of the already over burdened courts also do not present a positive picture of the Indian legal
system. They are not served with formal legal equality and calculable adjudication. Systematic
discriminatory law enforcement practices and policies are leaving people with less options and fewer
possibilities for improving their situation and depriving them of their normal sovereignty, reflecting the
‘crisis’ in the judicial and administrative system. These dual standards of justice for the rich and poor
further widen the socio-economic differences between the two. The unequal distribution of rights
ultimately leads to the questioning of a legitimacy of the law.
One of the reasons for this divide is that the poor doesn’t posses superior countervailing power and the
‘cautious crisis management’ of the authorities due to which their demands are not taken as seriously. This
leads to neglect of “vital areas, categories of needs and social groups that are incapable of producing
danger to the system.” This is the reason why there is lack of adequate radical legislation in the legal
system and as shown by the case lack of adequate implementation of laws which concern groups of people
who are unable to produce a threat of Instability.

The case also shows the nature of the Government towards the implementation of their statutory
obligations. The Government does not have an effective and efficiently working system to look over the
implementation and enforcement of the laws and also does not put in the required resources to do the
same and plays a passive role even though having the rights and duties for doing the same. The power
holders try to maintain status quo in the system. Even though the constitution provided for a revolutionary
break with the chains of the past, the actions of the powerful seek to maintain the status quo or does not
play any active role in achieving a just system. The discretionary power to bring certain legislation into
force is abused by the executive. In the case, the Government took 18 months to delegate the power to
the administrator to enforce the Inter State Migrant Workmen Act, 1979. The court couldn’t find any
reason for justifying the delay and even though the Government new a huge number of people who will be
affected by the act and will be granted certain rights were working and yet didn’t take any initiative. This
shows how even the people responsible for change in the society prevent the constitutional aspirations
and actions required in its accordance for a just society.

The law has been reduced to just a symbolic concept in the various situations. The social change sort to be
achieved is not achieved and this leads to false assurances and promises with nearly no change in the
conditions. The various Acts enacted by the parliament to safeguard the rights and provide basic amenities
to the workers as applicable in the case are in reality as submitted by the petitioners not being followed
and hence violating their rights. Even thought the Acts sets out to achieve a just work environment and
policies, the lack of compliance of these Acts show how they are just present in writing and not in reality.
Be it the Act for providing equal wages to men and women or providing basic working conditions, no Act is
being followed because of lack of oversight, reporting and punitive actions for violations.

The constitutional values are being overrun by the culture of the society. Most change-oriented laws are
ineffective because of the prevalent behaviour in the system as a whole. The value of equality even though
perceived by the constitution is in reality not being followed. The women workers receive less wages than
the male wages who themselves are receiving wage less than the minimum wage prescribed. The jamadars
receiving commission from the minimum wages is perceived to be normal and hence concerns are not
raised against it. Those who have concerns don’t know what course of action to take as the socio-economic
barriers limit their knowledge and hence the ideals perceived in the constitution are never really achieved
in reality. The crisis of the Indian legal system is not restricted to some part but instead it prevails
throughout the system, at each and every step.

Answer 3) After looking at the judgement of the given case, we find that Sociological approach towards law
is dominant in the judgement. It is this approach that is used throughout the case for deciding most of the
contended points. The sociological approach is more concerned with the working of the law rather than
the content of the law. The sociological approach considers law as a social fact or reality to shape, mould
and change society to sub-serve its needs, expectations and goals through law. Instead of regarding laws
abstract content of authoritative principles, it regards law as authoritative guides for decision making and
administrative processes. In the case, even though the rights of the workers, and not that of the
petitioners, were being violated and as a principle the petitioners couldn’t have had a locus standi in the
case. But the court decided, keeping in mind the prevailing socio-economic conditions, that the petitioner
had locus standi and transformed PILs into an instrument of social change. The decision by the traditional
approach would have restricted a whole class because of poverty, illiteracy and ignorance from getting
justice. Sociological approach believes in social goals, purposes and expectations of laws rather than the
hard character of law. When the respondents contended that the Article 23 is in context of ‘begar’ and
similar other forms which means if any remuneration is being given it is not part of forced labour. But the
court purposively interpreting the Article keeping in mind the intent behind it held that remuneration less
than the wage is forced labour keeping in mind the social conditions associated and the Article wouldn’t
have any real purpose if meagre remuneration would exclude the acts from this article. Also, the court
interpreted Article 14 to include equal pay and even though the Employment of Children Act didn’t include
construction industry as a harmful industry, making the act not applicable to the industry yet the court
using Article 24 interpreted that child employment in the industry would be a violation.

The Other approach that could be used to decide the case is the positivist approach to law. This approach
emphasis on the conventional nature of law and does not take decisions with concepts like humanity and
justice. The approach follows literal interpretation of law and is not concerned with reason or purpose. It
does not apply ethical justification of law and is merely concerned with the authoritative principle. If this
approach had been used in the current case, the biggest implication would have been that the petitioners
won’t have any locus standi for the PIL keeping mind that it was not their rights that were being violated
and hence they cannot ask for the remedy. The case wouldn’t have even been argued upon and the
workers would have continued to face injustice. The approach not concerned with reason or purpose
wouldn’t look over the socio-economic conditions and rather stick to the law. Also, the court won’t include
remuneration less than minimum wage as violative of Article 23 as literal interpretation would have
restricted the scope of the article to cases including no remuneration as a fact. This would allow the
exploitation of the article as anyone could avoid liability with respect to the article by paying a meagre
amount and hence pushing the workers of the country into forced labour contrary to the constitutional
aspirations.

Answer 4 A) There are various provisions of different acts under the current legal framework, under which
Armaan’s decision can be challenged in a superior court.

As a first step, an appeal should be filled in the Hight Court for judicial review of the magistrate’s decision.
The appeal can be filled under section 397 of the Criminal Procedure Code. The case can be argued for the
reversal of the decision made by the magistrate under section 125 of the Criminal Procedure Code, herein
after referred to as CrPC. Evolution of law is a continuous process which is changing through various court
judgements and legislations quite regularly. One such change creating legislation is Maintenance and
Welfare of Parents and Senior Citizens Act, 2007. Section 125 of CrPC doesn’t provide for reconciliation
between the aggrieved parties and is strictly restriced to deciding the monetary matter in the issue.
However, Maintenance and Welfare of Parents and Senior Citizens Act, 2007 through its section 6(6)
provides for reconciliation if sought by the parties. It states various tribunals with a conciliation officer who
can guide through the conciliation process and help the parties achieve a result. This development took
place keeping in mind interests of both the parties and the decision is just for both the parties without
having to go through the legal trouble. Therefore, Armaan can state in the appeal that the case be heard
keeping in mind the Maintenance and Welfare of Parents and Senior Citizens Act, 2007 while at the same
time file for an alternative dispute resolution method, namely the reconciliation process as stated above.

Judgement

Law should a protect the welfare of the people and help them enforce their rights by due process. But also,
law is a medium for solving social problems and hence evolving with the change in society. The facts of the
case shows that the parties other than the case itself had a dispute over the marriage. Even though the
parties became distant, yet Armaan kept sending them money, which shows that the parties still had
regard for each other. With time, Armaan stopped sending money which made the parents destitute and
the reason for filing a case. As mentioned in the appeal for filing in an application in the reconciliation
tribunal, both the parties if agreeing can go through with the process. In the meanwhile, interim stay
cannot be granted as Section 125 of CrPC provides the parents the right to maintenance and no matter the
existence of the Maintenance and Welfare of Parents and Senior Citizens Act, 2007 the right to ask for
maintenance under section 125 of CrPC cannot be curtailed. Armaan will have to continue paying the
maintenance even with the filing in the tribunal. If the parties cannot agree on filing for reconciliation or if
the result is not fruitful this appeal will be dismissed having no legal backing for asking for the reversal of
the decision.
Answer 4 B) If I had been approached by the parents of Armaan pertaining to this issue of maintenance, I
would have recommended them filing the case under Maintenance and Welfare of Parents Act, 2007
which provides advantages especially to the parents. As their attorney I would have not recommend filing
under Section 125 of CrPC because the section is a criminal provision and would take more time and
money in fighting the case through the process. While proceedings under Maintenance and Welfare of
Parents Act, 2007 filed in a Maintenance tribunal would be a better option as it is set up for such matters
and is a civil tribunal. Filing under the Maintenance and Welfare of Parents Act, 2007 provides advantages
to the parents giving them relief in a shorter period of time as under section 5(4) of the act the case shall
be decided within 90 days from the date of filling. Section 125 doesn’t provide any such time limit and
hence the relief is provided in a longer period of time with less use of resources. Section 17 of
Maintenance and Welfare of Parents Act, 2007, states that the legal practitioner representing the party
shall provide representation in such a way as to attract less litigation cost and non-ambiguity in the
decision. Considering the emergency of the situation, the parents already being destitute, an interim
monthly maintenance could be asked for under section 5(6) of the Maintenance and Welfare of Parents
Act, 2007 to be paid by Armaan during the course of the proceedings of the case. Keeping in mind the
familial nature of the relation between the parties, a settlement could be looked as an option for speedy
decision. So the Court might give directions to the parties as to start reconciliation proceeding with a
reconciliation officer appointed by the court. The act also provides for time limit within which the
maintenance if granted shall be deposited, ensuring justice in a fixed time. Armaan would have to deposit
the maintenance within 30 days as prescribed by the act. Also, if Armaan fails to deposit the maintenance
within the fixed time limit, the mechanism under the act will come into play according to which he will be
issued a levy warrant with a time, failing to pay the maintenance within that time period he would be
imprisoned for one month or until he pays the fine. Also if remedy is not granted by the decision, an appeal
can be filled in separate appellate tribunal which have to decide the appeal within 30 days from the filing
of appeal. This system provides the parents a timely and efficient recourse for enforcing their rights.
Answer 5) According to the facts of the case, Sofia is an intern with an organization conducting Vietnam
veterans’ study which is defined written in the section 3 sub-section 1 of the Epidemiological Studies
(Confidentiality) Act 1981, hereinafter referred to as the act. According to section 3 sub-section 2 of the
act, Sofia can be termed to be assisting in conduct of the epidemiological study and by section 9 and 9(b)
she was an employee of the organization conducting the research and her receiving or not receiving any
remuneration by the organization doesn’t change the applicability of this act. Hence this act is applicable to
her. The daily diary she was maintaining for keeping the record of the study was in the capacity of an
employee of the organization and for the purpose of the conduct of the study. After she lost the diary in
the café and couldn’t find it, she noted all the facts she could remember through her memory. Her act of
noting down the facts is in her capacity for assisting in the study is not violative of section 4 of the act as it
was for the conduct of the study. Hence, no offence can be made out of her above stated actions.

After a month, the organization has discovered a documentary with facts matching to the extent of 50% to
the facts registered under Sofia’s name under the organization. The question is if the documentary had any
relation to the diary of Sofia. The extent to which the facts match is truly surprising. Though it can’t be
clearly decided if the diary had anything to do with it, but by reasonable interpretation keeping in mind a
50% match can’t be a coincidence and the previous diary was also lost in the recent past it is believed that
it is in fact related to Sofia’s work. The purpose behind the statue as evident from various sections, such as
section 8 which states that the person shall not be required to submit the documents in the court of law, is
that the data being a highly classified and private information related to the persons the study is being
conducted on and the information being property of the organization should not be revealed to public or
any unauthorized person. Sofia’s negligent behaviour directly or indirectly resulted into the information
being revealed. Keeping in mind this negligent, Section 4 read with the criminal code chapter 2 makes her
liable for divulging information, Section 4 mentions divulge or communicate, which by the common
principle that interpretation should be done keeping in mind the words of the act shouldn’t be made
redundant means that they do not posses the same connotations and a positive act is not necessary in the
case to make out the offence. The act doesn’t emphasis on intent as the purpose is to protect the data and
safeguard the rights of the study subjects and the organization conducting the studies. Hence, Sofia being
liable for violating section 4 of the Epidemiological Studies (Confidentiality) Act 198,1 should be imprisoned
for 6 months or fined 10 units.
Answer 6)

The Government of Haryana enacted the Haryana Panchayati Raj Act, 1994. Section 175(1)(q) and 177(1)
disqualified persons having more than two living children after a certain date from holding certain public
offices in the Panchayat. The objective of these sections was to promote family welfare and planning.

Several writ petitions were filed in the Punjab and Haryana High court which were dismissed and appeals
by special leave have been filed in the Supreme Court against the decisions of the High Court. Writ
petitions had also been filed in the Supreme court under Article 32. The issue being, are the provisions of
the Haryana Panchayati Raj Act, 1994 stated above constitutionally valid or not?

The grounds of the petitioners were put into 5 categories. Firstly, the provisions being arbitrary are
violative of Article 14 of the constitution. Secondly, that the provision sought to be achieved by the
disqualification is not served as the number of children one has does not affect the capacity, competence
and quality of a person to serve on any office of a Panchayat. Thirdly, that the provision is discriminatory as
a similar provision is not found to have been enacted for disqualifying aspirants or holders of elective or
public offices in other institutions of local self-governance and also not in State Legislatures and
Parliament. Fourthly, that the provisions are violative of Article 21 as it adversely affects the liberty of
leading personal life in all its freedom and having as many children as one chooses to have. Lastly, that the
provisions violate Article 25 by interfering with the freedom of religion.

For the first three grounds the court found that the law was neither arbitrary nor unreasonable nor
discriminatory. The law is not arbitrary as the classification into the two groups, one having more than two
children and the other having less than two children, is well defined and the rationale behind the
provisions is served as it seeks to promote family welfare/planning consistent with the national policy by
providing a disincentive. Hence the law has a nexus with the objective to be achieved and therefore not
unreasonable. The court held that the provision can’t be held discriminatory on the basis that no such
provision is found as a requirement for elections to any other local self-governance institutions and any
other state or the parliament. The court held that right to contest election is not a fundamental right but a
statutory right and hence can be curtailed. The court didn’t find any violation of Article 21 as it should be
read with fundamental duties and directive policies which include promoting family welfare. The Court
didn’t find any violation of Article 25 as it is subjected to exceptions for public order, morality and health,
and permits limiting the right to religious freedom by means of social welfare legislation and religious
practices which doesn’t include everything permissible under the religion.

The court held the provisions of the Act to be constitutionally valid.


Answer 7A) Broadest Ratio Decedendi

The rights which are statutory creation can be subjected to statutory limitation, the rule being reasonable
and in accordance with the law.

The court in Javed v. State of Haryana held that right to contest election is provided by a statute and can be
curtailed by the authority having the authority to make the amendment. The right to contest elections is
not a fundamental right and can be curtailed by statute. The court did not find any violation of
fundamental rights by the amendment restricting right to contest election for certain offices in the
panchayat for people having more than two children. The court held the legislation to be in favour of
public policy and promoting welfare of the people. The governments derive the authority to make the
amendments with respect to these rights from the constitution and hence make decisions with respect to
various statutory rights, with these changes being valid in procedure and constitutional until and unless
violating the basic rights provided by the constitution of India.

Answer 7B) Narrowest Ratio Decedendi

Legislation restricting the right to contest election at the lowest level of self-governance cannot be held
violative if promoting family planning and welfare by disincentivizing having more than two children

The court in the case held that the legislation restricting elections to certain offices of the panchayat with
the purpose of promoting family wealth and welfare is constitutionally valid and follows due procedure.
The state government has the authority under Article 243-G to make such changes with respect to the
panchayats. The court held the legislation to be reasonable and not violating any of the fundamental
rights. The directive principles state family welfare and planning as one of the directives state should
strive to promote and by the disincentivizing having more than two children the state does the same.

Answer 8 A)

Issue: Whether the amendment made to the section 4 of the Representation of the People Act, 1951 is
constitutionally valid or invalid?

Rule: In Javed v. State of Haryana, it was held that reasonable qualifications could be made necessary for
contesting elections or holding an office. Right to contest election is not a fundamental right and could be
curtailed with statues.

Analysis: Javed v. State of Haryana stating Article 14 lays down that the rational such classification of
people into two groups one consisting of people having passed the Std. XII examination and the other
consisting of the people not having passed the Std. XII examination. If the rationale behind the amendment
is that certain level of education is required for achieving skills of good governance, then Ms. X herself is an
example contrary to this rationale. Her village has been declared India’s best governed village for the last 5
years by the Government of India, even though she has had no level of schooling whatsoever. This
rationale doesn’t find reason as literacy and governance skill have no strong connection. The amendment
is arbitrary and unreasonable. In Javed v. Haryana the amendment was held constitutional as it promoted
family welfare. But in that case the person had the power to decide how many kids he/she can have and
hence the amendment was reasonable. But the amendment in question in this case is completely different.
A person doesn’t have control over the socio-economic conditions he/she is born in and as a child it’s the
family keeping in mind the conditions decide for the child. The decision to have schooling from a younger
age is completely out of the hand of the person and he/she cannot have the right to contest election taken
away just because of these uncontrollable conditions. This amendment discriminates between people who
are rich and have the resources to study in schools and the poor whose conditions at times deprive
him/her of this opportunity. This amendment being related to the national parliament further creates the
barrier for the poor to be represented.

Conclusion: The act being arbitrary, unreasonable and discriminatory should be held unconstitutional.

Answer 8 B)

Issue: Whether the Whether the amendment made to the section 4 of the Representation of the People
Act, 1951 is constitutionally valid or invalid?

Rule: In Javed v. State of Haryana it was held that right to contest election is not a fundamental right and
could be curtailed by statutory action. Reasonable qualifications could be made neccesay for contesting
and election or holding the office,

Analysis: The amendment makes 12th standand and equivalent examination a requirement for contesting
the lok sabha elections. The classification is found on an intelligible differentia. Persons having successfully
passed the Std. XII examination of the Central Board of Secondary Education or any other equivalent
examination conducted by the state governments or other recognised boards and Persons who haven’t
passed the above mentioned examinations can be clearly distinguished from each other. As mentioned in
the Javed v. State of Haryana, Article 38 part of the directive principles states that the State should strive to
promote the welfare of the people and develop a distributive justice empowered social order.
Representatives having a certain level of education would help serve the people better. The requirements
for governance are different at the lok sabha level than the panchayat level. People at such a position
should possess the basic literacy skills and understanding of concepts for governing the country and its
people. This promotes literacy in the society and is a step towards the welfare of the society.

As stated in Javed v. State of Haryana, The Parliament is well within its rights to make these types of
amendments. Right to contest election being a statutory right can be curtailed by the statue and the
parliament has the power to bring in such amendments.

Conclusion: The amendments made to the Act are constitutionally valid.

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