TEAM CODE: IM005

BEFORE

THE HONOURABLE HIGH COURT OF SHENOY

W. P. No. _____ OF 2022

IN THE MATTER BETWEEN

NEWSBOOK ________________PETITIONER

v.

STATE OF SHENOY___________________________________RESPONDENT

MEMORIAL FOR THE PETITIONER

TABLE OF CONTENTS
 INTERNAL MOOTING COMPETITION - 2022

SL. NO. CONTENTS PAGE NO.

1. TABLE OF CONTENTS 2

2. LIST OF ABBREVIATIONS 3

3. INDEX OF AUTHORITIES 4

4. STATEMENT OF JURISDICTION 5

5. STATEMENT OF FACTS 6

6. STATEMENT OF ISSUES 7

7. SUMMARY OF ARGUMENTS 8

8. ARGUMENTS ADVANCED 9

9. PRAYER 18

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INTERNAL MOOTING COMPETITION - 2022

LIST OF ABBREVIATIONS

& And

AIR All India Reporter

Art. Article

Ors Others

SC Supreme court

SCC Supreme Court Cases

UOI Union of India

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 INTERNAL MOOTING COMPETITION - 2022

INDEX OF AUTHORITIES

I. CASES

S. No. CASE NAME CITATIONS

1. Agij Promotion of Nineteenonea Media (P) Ltd. v. 2021 SCC OnLine Bom
Union of India, 2938

2. L. Chandra Kumar v. Union of India, (1997) 3 SCC 261 : AIR

1997 SC 1125 (India).
3. Shreya Singhal v. Union of India, (2015) 5 SCC 1 ¶10

4. Khushboo v. Kanniammal, (2010) 5 SCC 600 ¶45

5. Sakal Papers Ltd v. Union of India, (1962) 3 SCR 842

6. P. Krishnamoorthy v. Union of India, 2015 SCC OnLine Mad

1171
7. A DM Jabalpur v, Shivakant Shukla (1976) 2 SCC 521

8. Union of India v. Naveen Jindal, (2004) 2 SCC 510

II. STATUTES

S. No. STATUTE

1. Information Technology Act, 2000

2. Constitution of India

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 INTERNAL MOOTING COMPETITION - 2022

STATEMENT OF JURISDICTION

THE PETITIONER HEREBY SUBMITS THIS MEMORANDUM BEFORE THE

HONOURABLE HIGH COURT OF SHENOY INVOKING THE WRIT JURISDICTION
UNDER ARTICLE 226 IN APPREHENSION OF THE VIOLATION OF FUNDAMENTAL
RIGHTS ENUMERATED IN PART III OF THE CONSTITUTION. THEREFORE, THE
PETITIONERS MAINTAIN THAT THE JURSIDICTION OF ART.226, WHICH
PROTECTS THE CITIZENS OF SINDICA FROM ANY VIOLATION OF THEIR
FUNDAMENTAL RIGHTS ARE APPLICABLE IN THE PRESENT CASE.

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STATEMENT OF FACTS

1. Sindica is a country situated in the South-Asian region which adopted a constitution

that makes the country sovereign, socialist, secular, democratic and republic.
2. Part III of the Constitution of Sindica provides certain freedoms and fundamental
rights to its citizens which included the right to freedom of speech and expression. The
constitution also protects and promotes the fundamental rights of cultural and
linguistic minorities of the country.
3. Due to the rapid rise in the technological development, the government of Sindica
found the need to regulate the information exchanged electronically and therefore
enacted an act to provide legal recognition for transaction relating to electronic data
interchange and electronic communication, namely The Sindica Information
Technology Act, 2000.
4. A huge number of complaints were being received by the Government against various
social media companies. The central government raised concerns on the transparency,
disinformation and misuse of such technologies.
5. The government decided to address these issues in order to bring accountability to
social and digital media platforms under the Information Technology (Intermediary
Guidelines and Digital Media Ethics Code) Rules, 2021 (―Rules‖), which was made
under and by the powers conferred by the Information Technology Act, 2000.
6. News Book is a digital media entity which publishes articles, opinion pieces and
reportage pertaining to various social and political issues, including news and current
affairs related content. In particular, Rule 9 of the Rules (included in Schedule I of this
moot proposition) which proposes a three-tier oversight structure for handling
complaints made in respect to publishers and the third tier of such mechanism is
"Oversight mechanism by the Central Government" aggrieved News Book.
7. In this background News book has filed a writ petition before the High Court of
Shenoy challenging the constitutionality of the Information Technology (Intermediary
Guidelines and Digital Media Ethics Code) Rules, 2021 (―Rules‖), which was made
under Information Technology Act, 2000. The High Court of Shenoy has admitted the
petition and framed relevant issues for consideration.

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STATEMENT OF ISSUES

I. Whether the writ petition is maintainable before the Hon‘ble High Court Of Shenoy?
II. Whether Rule 9 of the Information Technology (Intermediary Guidelines And Digital
Media Ethics Code) Rules, 2021 is ultra vires Article 19 (1) (a) of the Constitution of
Sindica?

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 INTERNAL MOOTING COMPETITION - 2022

SUMMARY OF ARGUMENTS

ISSUE 1
I. THAT THE WRIT PETITION IS MAINTAINABLE UNDER THE
HONOURABLE HIGH COURT OF SHENOY.
A) There is a violation of freedom of speech and expression guaranteed by
Article 19 (1) (a) of publishers mentioned under the rule 9 of Information
Technology Rules, 2021, thus it is maintainable under the High Court of
Shenoy.

ISSUE 2

I. THAT THE RULE 9 OF THE INFORMATION TECHNOLOGY

(INTERMEDIARY GUIDELINES AND DIGITAL MEDIA ETHICS
CODE) RULES, 2021 ULTRA VIRES ARTICLE 19 (1) (a) OF THE
CONSTITUTION OF SINDICA?
a) The rule 9 of the Information Technology (Intermediary guidelines and Digital
Media Ethics Code) Rules, 2021 patently ultra vires the provisions of
Information Technology Act, 2000
b) Rule 9 of the Information Technology (Intermediary Guidelines and Digital
Media Ethics Code) Rules, 2021 is ultra vires Article 19 (2) of the
Constitution of Sindica.

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ARGUMENTS ADVANCED

I. THE WRIT PETITION IS MAINTAINABLE UNDER THE HONOURABLE

HIGH COURT OF SHNEOY.
1. The petitioner humbly submits before the Honourable High Court of Shenoy that the
writ petition is maintainable as The Information Technology (Intermediary Guidelines
and Digital Media Ethics Code) Rules, 2021 clearly violates the fundamental rights
guaranteed under Part III of the Constitution of India.
A. The Information Technology (Intermediary Guidelines and Digital
Media Ethics Code) Rules, 2021 violates Article 19 of the constitution of
Sindica.
2. The Information Technology Rules, 2021 violates Art.19 of the constitution of
Sindica and does not fall within the reasonable restrictions imposed under Art.19 (2).
3. The Rule 9 of The Information Technology (Intermediary Guidelines and Digital
Media Ethics Code) Rules,2021 violates the fundamental rights mentioned in
i. Art.19 provides the right to freedom of speech and expression to all the
citizens of Sindica subject to reasonable restrictions stated under Art.19 (2).
4. With the development of technology in Sindica, government decided to regulate the
exchange of information through electronic media. To address the concerns of
transparency, disinformation, and misuse the government of Sindica formed The
Information Technology (Intermediary Guidelines and Digital Media Ethics Code)
Rules, 20211 . The aforementioned rules directly caused agony to ―News book‖ Digital
Media entity as it violated the fundamental rights guaranteed under Art.19.
5. The Rule 9 of the Information Technology (Intermediary Guidelines and Digital
Media Ethics Code) Rules, 2021 impose additional inconvenience to the affected
party in terms of restrictions2 .
6. The petitioner is aware about the need to regulate digital information, but the
petitioner is primarily aggrieved by Rule 9 which read as:-
Observance and adherence to the Code.—(1) a publisher referred to in rule 8 shall
observe and adhere to the Code of Ethics laid down in the Appendix annexed to these
rules.

1
Para 4, MOOT PROPOSITION.
2
X. Information Technology Rules 2021: Are we Heading Towards a Draconian Rule?, 8.2 RFMLR (2021) 247

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(2) Notwithstanding anything contained in these rules, a publisher referred to in rule

8 who contravenes any law for the time being in force, shall also be liable for
consequential action as provided in such law which has so been contravened.
(3) For ensuring observance and adherence to the Code of Ethics by publishers
operating in the territory of Sindica, and for addressing the grievances made in
relation to publishers under this Part, there shall be a three-tier structure as under—
(a) Level I - Self-regulation by the publishers;
(b) Level II – Self-regulation by the self-regulating bodies of the publishers;
c) Level III - Oversight mechanism by the Central Government3 .
7. In Agij Promotion of Nineteenonea Media (P) Ltd. v. Union of India 4 , It is argued
that the 2021 Rules have a serious chilling impact when applied to the internet since
they establish a regime that is obviously arbitrary and unreasonable, which is an
affront to the fundamental guarantee of citizens' freedom of expression.
8. It is well known that Article 226 of the Constitution empowers every High Court in
the country to issue orders or writs to any person or authority including Government
for the enforcement of the fundamental rights guaranteed under Part III of the
Constitution or for any other purpose5 . According to the Supreme Court's decision in
L. Chandra Kumar v. Union of India6 , which stated that the judicial review
authority granted to High Courts by Article 226 is a part of the fundamental
framework of the Constitution, Article 226 of the Constitution is regarded as sacred to
the Constitution. This demonstrates the significance of the role High Courts play in
defending citizens' rights under the Indian constitutional system.
9. Freedom of speech and expression ensures a vibrant and responsible democracy7 .
People tend to make better decisions when they are properly informed. Proper
information can be passed only when there are few fetters on the dissemination of
information8 . Too many obstacles and restrictions distort the truth behind every
information and the citizens will be unaware about the true events. In Shreya Singhal

3
Schedule 1, MOOT PREPOSITION.
4
Agij Promotion of Nineteenonea Media (P) Ltd. v. Union of India, 2021 SCC OnLine Bom 2938
5
India Const. art. 226:―Power of High Courts to issue certain writs -(1) Notwithstanding anything
in Article 32 every High Court shall have powers, throughout the territories in relation to which it exercise
jurisdiction, to issue to any person or authority, including in appropriate cases, any Government, within those
territories directions, orders or writs, including writs in the nature of habeas corpus, mandamus, prohibitions,
quo warranto and certiorari, or any of them, for the enforcement of any of the rights conferred by Part III and
for any other purpose‖ (emphasis added).
6
L. Chandra Kumar v. Union of India, (1997) 3 SCC 261 : AIR 1997 SC 1125 (India).
7
Shreya Singhal v. Union of India, (2015) 5 SCC 1 ¶10
8
Khushboo v. Kanniammal, (2010) 5 SCC 600 ¶45

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v. UOI9 , the words of J.Brandeis of the US SC 10 was quoted which reads as follows:
According to him, ―the greatest menace to freedom is an inert people‖, and hence,
―public discussion is a political duty‖11 . Linked to this are two ideas: (1) that public
criticism of institutions is crucial to the good functioning of a democracy; and (2) that
a ―culture of open dialogue‖12 is needed to ―sustain the collective life of the
citizenry‖13 .
10. Freedom of speech and expression of opinion is of paramount importance under a
democratic constitution that envisages changes in the constitution of legislatures and
governments and must be preserved14 .
11. In this petition the petitioner respectfully submits that restriction imposed on the
publishers for the online curated content will result in closing their creative mind in a
box. A democratic country have to be properly criticised, media is the watchdog of
democracy. Respondents may feel that this dog is barking at every shadow seen or
every voice heard, but it‘s the duty of this dog because this is the watchdog of
democracy.
12. Democracy does not give absolute powers to the respondents under the shade of an
unprecedented social disorder. It is the right of the people to access the real time
issues even in cases of social security. In the shade of an imminent threat to the
security of a nation, there are chances of corruption which is evident from different
nation‘s experience. When tight restrictions are imposed there are chances for
corruptions behind the curtains of those restrictions, this theory of shock doctrine was
beautifully brought down by Naomi Klein in her book Disaster capitalism. This
theory was very famous during the time of pandemic. Media was the only transparent
source for citizens to know the truth behind the shades. But when bridles are imposed
on media or news publishers there are no other sources for discovering the events that
may destroy a nation
13. Publishers should be free to express their opinions and facts for and against the ruling
government. It is the right of the citizens to get information from the publishers. But
the three tier system clearly eliminates these rights making the citizens available with
the information that the government needs to be injected on them.
9
Supra Note 5
10
Whitney v. California, 274 U.S. 357 (Brandeis, J., Concurring).
11
id
12
Supra Note 6
13
Supra Note 6
14
Sakal Papers Ltd v. Union of India, (1962) 3 SCR 842

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14. In a democracy, dissension is essential. However, a democracy only functions when

there are checks and balances in place. There can be no disagreement over the fact
that a healthy democracy is one that has grown through criticism and acceptance of
opposing viewpoints. An opinion's acceptance in a democratic society is strengthened
by criticism of that opinion. With the 2021 Rules in place, one would have to think
twice before criticising any such personality, even if the writer/editor/publisher may
have good reasons to do so without resorting to defamation and without inviting
action under any other provision of law15 . The indeterminate and wide terms of the
Rules bring about a chilling effect qua the right of freedom of speech and expression
of writers/editors/publishers because they can be hauled up for anything if such
committee so wishes. The 2021 Rules are, thus, manifestly unreasonable and go
beyond the IT Act, its aims and provisions. 16
15. The petitioner humbly request before the Court for the acceptance of writ under
Art.226 of the constitution of Sindica.

ISSUE 2

II. THE RULE 9 OF THE INFORMATION TECHNOLOGY (INTERMEDIARY

GUIDELINES AND DIGITAL MEDIA ETHICS CODE) RULES, 2021 ULTRA
VIRES ARTICLE 19 (1) (a) OF THE CONSTITUTION OF SINDICA.
The petitioner humbly submits before the Honourable High Court of Shenoy that THE
RULE 9 OF THE INFORMATION TECHNOLOGY (INTERMEDIARY
GUIDELINES AND DIGITAL MEDIA ETHICS CODE) RULES, 2021 ULTRA
VIRES ARTICLE 19 (1) (a) OF THE CONSTITUTION OF SINDICA.
A. The rule 9 of the Information Technology (Intermediary guidelines and Digital
Media Ethics Code) Rules, 2021 patently ultra vires the provisions of
Information Technology Act, 2000
1. The Rule 9 of the Information Technology (Intermediary guidelines and Digital
Media Ethics Code) Rules, 2021 states that,
Observance and adherence to the Code.—(1) A publisher referred to in rule 8 shall
observe and adhere to the Code of Ethics laid down in the Appendix annexed to these
rules. (2) Notwithstanding anything contained in these rules, a publisher referred to in

15
Agij Promotion of Nineteenonea Media (P) Ltd. v. Union of India , 2021 SCC OnLine Bom 2938
16
Agij Promotion of Nineteenonea Media (P) Ltd. v. Union of India , 2021 SCC OnLine Bom 2938

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rule 8 who contravenes any law for the time being in force, shall also be liable for
consequential action as provided in such law which has so been contravened. (3) For
ensuring observance and adherence to the Code of Ethics by publishers operating in
the territory of Sindica, and for addressing the grievances made in relation to
publishers under this Part, there shall be a three-tier structure as under— (a) Level I -
Self-regulation by the publishers; (b) Level II – Self-regulation by the self-regulating
bodies of the publishers; (c) Level III - Oversight mechanism by the Central
Government.17
2. Rule 9 provides restrictions which travel beyond Sec. 69(A) of the IT Act. Sec 69(A)
reads as follows: 69. Power to issue directions for interception or monitoring or
decryption of any information through any computer resource.–(1) Where the Central
Government or a State Government or any of its officers specially authorised by the
Central Government or the State Government, as the case may be, in this behalf may,
if satisfied that it is necessary or expedient so to do, in the interest of the sovereignty
or integrity of India, defence of India, security of the State, friendly relations with
foreign States or public order or for preventing incitement to the commission of any
cognizable offence relating to above or for investigation of any offence, it may
subject to the provisions of sub-section (2), for reasons to be recorded in writing, by
order, direct any agency of the appropriate Government to intercept, monitor or
decrypt or cause to be intercepted or monitored or decrypted any information
generated, transmitted, received or stored in any computer resource. (2) The
procedure and safeguards subject to which such interception or monitoring or
decryption may be carried out, shall be such as may be prescribed. (3) The subscriber
or intermediary or any person in-charge of the computer resource shall, when called
upon by any agency referred to in sub-section (1), extend all facilities and technical
assistance to– (a) provide access to or secure access to the computer resource
generating, transmitting, receiving or storing such information; or (b) intercept,
monitor, or decrypt the information, as the case may be; or (c) provide information
stored in computer resource. (4) The subscriber or intermediary or any person who
fails to assist the agency referred to in sub section (3) shall be punished with
imprisonment for a term which may extend to seven years and shall also be liable to
fine. It is clear from Sec. 69 (A) that it imposes restrictions subject to the restrictions

17
Schedule 1, MOOT PREPOSITION

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given in Art. 19(2) of the Constitution being interests of the sovereignty and integrity
of India, the security of the State, friendly relations with foreign States, public order,
decency or morality, or in relation to contempt of court, defamation or incitement to
an offence.
3. The petitioners have contended that the IT Act does not seek to censor the content on
internet; secondly, it is impermissible for the Central Government to have a
subordinate legislation in the form of Rule 9 inasmuch as it provides for restrictions
which travel beyond the provisions of Section 69A of the IT Act; and thirdly, the rule
making power itself, as exercised in framing the impugned rules, namely, the power
under Section 87 sub-section (1) and clauses (z) and (z g) of subsection (2) itself does
not provide for imposition of such restrictions.
4. The provision of Section 87(2)(z) and (z g) of the IT Act which is invoked to frame
the 2021 Rules speaks of rules that could be framed in regard to the procedure and
safeguards for blocking of access by the public under sub-section (2) of Section 69-
A. Subsection (z g) provides for framing rules in the nature of guidelines to be
observed by the intermediaries under sub-section (2) of Section 79.
5. When taking into account the impact of such substantive provisions of the parent Act,
in our opinion, Rule 9 has two apparent legal flaws. First, it requires publishers of
news and current affairs content and publishers of online curated content to adhere to
the Code of Ethics under a completely different legal framework than the IT Act,
namely by using standards of journalistic conduct established by the Press Council of
India under the PC Act and Programme. Additionally, Section 87 does not grant the
Central Government any authority to create rules that would take into account the
clauses (z) and (z g) of Subsection (2)18 .
6. Thus, petitioner humbly pleads before the court that Rule 9 clearly ultra vires Sec. 69
(A) of the Information Technology Act, 2000.
B. Rule 9 of the Information Technology (Intermediary Guidelines and
Digital Media Ethics Code) Rules, 2021 is ultra vires the restrictions
imposed under Article 19 (2) of the Constitution of Sindica.
1. Rule 9 also prima facie appears to be infringing the constitutional guarantee of
Freedom of Speech and Expression as conferred by Article 19(1) (a) in subjecting the
publishers of news and current affairs content and publishers of online curated

18
Agij Promotion of Nineteenonea Media (P) Ltd. v. Union of India, 2021 SCC OnLine Bom 2938

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content subject to action under the statutory regime of the PC Act and the CTVN Act,
which provides for an independent mechanism for any violation of the provisions of
such legislation. We prima facie find much substance in the contentions as urged on
behalf of the petitioner that such transgression of powers occupied by different
legislations cannot be disrupted by a subordinate legislation. 19
2. The court held in Agij Promotion of Nineteenonea Media (P) Ltd. v. Union of
India20 that the first consideration of the Court would always be to preserve the
statutory provision when its constitutionality is challenged. However, if there are
exceptions and the Court finds that the provision is ex-facie ultra vires, unreasonable
or illegal, it may strike it down.
3. By taking into consideration the Supreme Court case of State of Tamilnadu v. P.
Krishnamurthy21 the court held that even though there is a presumption in favour
of constitutionality or validity of subordinate legislation, it is well recognized that a
subordinate legislation can be challenged on the ground of lack of legislative
competence to make the subordinate legislation, violation of fundamental rights
guaranteed under the Constitution of India, violation of any provisions of the
Constitution of India, failure to conform to the statute under which it is made or
exceeding the limits of authority conferred by the enabling enactment and on the
ground of manifest arbitrariness/unreasonableness. The Court has held that when the
rules are directly inconsistent with a mandatory provision of the statute, then, the task
of the Court is simple and easy.
4. In the precedent case of High court,with persuasive value the court held that Rule 9
does not conform to the statute, namely, of the Information Technology Act as also it
is an intrusion into the fundamental rights guaranteed under Article 19(1)(a) of the
Constitution of the publishers.

5. In Health for Millions v. Union of India22 , the Supreme Court has observed that the
rules can be quashed if the same are found to be unconstitutional or ultra vires the
provisions of the Act, however, the operation of the statutory provision cannot be
stultified by granting an interim order except when the Court is fully convinced that
the parts under enactment or the rules are ex facie unconstitutional and the factors

19
Agij Promotion of Nineteenonea Media (P) Ltd. v. Union of India, 2021 SCC OnLine Bom 2938
20
Id
21
P. Krishnamoorthy v. Union of India, 2015 SCC OnLine Mad 1171
22
In Health for Millions v. Union of India, (2014) 14 SCC 496

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like balance of convenience, irreparable injury and public interest are in favour of
passing an interim order.
6. Reasonable restrictions on any law can be imposed only by law and not otherwise.
Any restriction imposed without the authority shall be declared unconstitutional23 .
The requirement of law which is specifically mentioned in Article 19 (2), would have
applied even in the absence of such mention because of the principle of the rule of
law which prohibits restrictions on the rights and freedoms of an individual without
the authority of law. Therefore, even during an emergency when rights in Article 19
(1) get suspended executive cannot restrict the freedoms of the individual without the
authority of law." This position has now been expressly stated in Article 358 (2)
(b)24 , but even before such statement the Supreme Court had clearly lain down:
"Every act done by the Government or by its officers must, if it is to operate to the
prejudice of any person, be supported by some legislative authority." This remains to
be the legal position even though the Supreme Court dithered from it in the infamous
ADM, Jabalpur v. Shivakant Shukla25 (Habeas Corpus case). Thus in Union of
India v. Naveen Jindal26 , the court held that the Flag Code which is neither made by
a competent legislature nor authorised by any law of such a legislature cannot restrict
the right of a citizen to fly the national flag guaranteed to him under Article 19(1) (a).
7. The restrictions imposed under Rule 9 of the Information Technology (Intermediary
guidelines and Digital Media Ethics Code) Rules, 2021 clearly falls beyond the
restriction given in Art. 19 (2). The three tier system of governance results in the
violation of freedom of speech and expression of the publishers. The third tier of
oversight mechanism by the central government put bridles on the publishers in such

24
Indian constitution Art.358 (1) While a Proclamation of Emergency declaring that the security of India or any
part of the territory thereof is threatened by war or by external aggression is in operation], nothing in article 19
shall restrict the power of the State as defined in Part III to make any law or to take any executive action which
the State would but for the provisions contained in that Part be competent to make or to take, but any law so
made shall, to the extent of the incompetency, cease to have effect as soon as the Proclamation ceases to
operate, except as respects things done or omitted to be done before the law so ceases to have effect:
Provided that where such Proclamation of Emergency is in operation only in any part of the territory of India,
any such law may be made, or any such executive action may be taken, under this article in relation to or in any
State or Union territory in which or in any part of which the Proclamation of Emergency is not in operation, if
and in so far as the security of India or any part of the territory thereof is threatened by activities in or in relation
to the part of the territory of India in which the Proclamation of Emergency is in operation.
(2) Nothing in clause (1) shall apply—
(a) to any law which does not contain a recital to the effect that such law is in relation to the Proclamation of
Emergency in operation when it is made; or
(b) to any executive action taken otherwise than under a law containing such a recital.
25
A DM Jabalpur v, Shivakant Shukla (1976) 2 SCC 521
26
Union of India v. Naveen Jindal, (2004) 2 SCC 510

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a way that transfer of facts and information is restricted and reviewed by the central
government and sanction is awarded or changes are forced on the published piece of
information making the restriction go beyond the powers of the Art. 19 (2) resulting
in the requirement of declaring Rule 9 to be unconstitutional.

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PRAYER
Wherefore in the light of issues raised, arguments advanced and authorities cited the counsel

for the petitioner humbly pray and implore before this Hon‗ble Court to kindly adjudge, hold

And declare:

i. The writ petition is maintainable as it violates Art. 19 (1) (a) of the

constitution of Sindica.

ii. Rule 9 of the Information Technology (Intermediary Guidelines And Digital

Media Ethics Code) Rules, 2021 is ultra vires Article 19 (1) (a) of the

Constitution of Sindica

Or pass any writ, order or direction which the court may deem fit in the end of equity,

justice, expediency and good conscience in favour of the Petitioner and for this act of

kindness the Petitioner as in duty bound shall forever remain obliged.

ALL OF WHICH IS HUMBLY PRAYED

COUNSEL FOR PETITIONER.

18