Team: 23

Moot Court Competition Organized by City Law College, Jankipuram

before

THE HON’BLE SUPREME COURT OF REPUBLIC OF STAN

UNDER ARTICLE 136 OF THE CONSTITUTION OF THE

REPUBLIC OF STAN Criminal Appeal No. /2023

IN THE MATTERS OF
TANVIR AHMAD & ANR..........................................................................APPELLANTS

VERSUS

REPUBLIC OF STAN & ANR................................................................RESPONDENTS

UPON SUBMISSION TO
THE HON’BLE CHIEF JUSTICE AND HIS COMPANION JUSTICES
OF
THE HON'BLE SUPREME COURT OF THE REPUBLIC OF STAN

MEMORIAL ON BEHALF OF THE APPELLANTS

INDEX
1. INDEX OF AUTHORITIES 3-4
A. TABLE OF CASES 3
B. BOOKS 4
C. LEGISLATIONS, ORDINANCES, NOTIFICATIONS & CIRCULARS 4
D. WEB SOURCES 4
2. INDEX OF ABBRIVIATION 5
3. STATEMENT OF JURISDICTION 6
4. STATEMENT OF FACTS 7-8
5. ISSUES RAISED 9
6. SUMMARY OF ARGUMENTS 10-11
7. ARGUMENTS ADVANCED 12-18
A. Whether the appeal filed by Tanvir Ahmad and Ramendra Singhal is maintainable before
the Hon’ble Supreme Court of Stan? 12
B. Whether the judgement of the Hon’ble High Court erroneous? 13 - 14
C. Whether Tanvir Ahmed and Ramendar Singhal are liable Under Sections 66, 66F of the
Information Technology Act, 2000 and Section 441 of the Stanian Penal Code? 14 – 17
8. PRAYER 18

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 LIST OF ABBREVIATIONS

Abbreviation Corresponding Expansion

& And

AIR All India Reporter

Acc. According

All Allahabad

Anr. Another

Art. Article

B/w Between

Bom Bombay

SLP Special Leave Petition

Del Delhi

Dtd. Dated

Ed. Edition

Eg. Exempli Gratia (Latin)

Etc. Et Cetera

Govt. Government

HC High Court

Hon’ble Honourable

IT ACT Information and Technology Act, 2000

Sec. Section

Vol. Volume

Imp. Important

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Mad Madras

Mys Mysore

No. Number

Ori Orissa

Ors. Others.

P&H Punjab and Haryana

Para. Paragraph

Pg. Page

Pt. Point

R/w Read with

SC Supreme Court

SCC Supreme Court Cases

SCR Supreme Court Reporter

Sec. Section

Supdt. Superintendent

Supp Supplementary

UOI Union of India

U. P Uttar Pradesh

U/s Under section

V. Versus

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 INDEX OF AUTHORITIES
STATUTES

1. The Indian Penal Code ,1860

2. Information and Technology Act, 2000

INDIAN CASES

1. B.V. Padmanabha Rao, In re, 1969 SCC OnLine Kar 161 : 1970 Cri LJ 1502;
………………………………………………….03
2. Bachan Singh v. State of Punjab, (1980) SCC 84 (India).........02
3. Basdev v. State of Pepsu AIR 1956 SC 488..............................05
4. E.V. Chinnaiah v. State of Andhra Pradesh, (2005) 1 SCC
394;…………………………………………………………...01
5. Francis Coralie Mullin v. Adm'r Union Territory of Delhi, (1981) 1 SCC 608
(India);........................................................02
6. Gobind v. State of Madhya Pradesh, (1975) 2 SCC 148…….02
7. K.N. Mehra v. State of Rajasthan, AIR 1957 SC 369..............03
8. Kanwal Sood v. Nawal Kishore (1983) 3 SCC 25...................06
9. Keso Sahu v. Saligram Shah 1977 CriLJ 1725.........................07
10. Kharak Singh v. State of Uttar Pradesh, (1964) 1 SCR 332;
.................................................................................................02
11. Mahesh Chandra Jain v. Uttar Pradesh Financial Corp., (1993) 2 SCC279;
……………………………………………………01
12. Maneka Gandhi v. Union of India, (1978) 1 SCC 248..............02
13. Meera Santosh Pal v. Union of India, (2017) 3 SCC 462;……02
14. R.K. CHAUBEY, AN INTRODUCTION TO CYBER CRIME AND CYBER
LAW 372 (2nd ed., 2012).................................02
15. Raghunathro Ganpatrao v. Union of India, 1994 Supp (1) SCC 191.
…………………………………………………………..01
16. Rajinder V State of Haryana (1955) 5 SCC 187.......................04
17. Ramjan Misrty v Emperor(1978) 4 SCC 645............................05
18. S.D. Bandi v. Karnataka SRTC (2013) 12 SCC
631……………………………………………………………….04

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 19. Satwant Singh Sawhney v. D. Ramarathnam, (1967) 3 SCR 525 (India);
……………………………………………………….02
20. State of Maharashtra v. Mayer Hans George AIR 1965 SC
722……………………………………………………………05
21. State of Orissa v. Khora Ghasi, 1978 CrLJ 1305
(Orissa)........................................................................................07
22. Suresh Chandra Bahri v. State (Bihar AIR 1994 SC 2420)
………………………………………………………………...04
23. T.V. Vatheeswaran v. State of Tamil Nadu, (1983) 2 SCC
68……………………………………………………………...02
24. Utkal Contractors & Joinery Pub. Ltd. v. State of Orissa, (1987) 3 SCC 279;
…………………………………………………...01
25. Vimla v. Delhi Admn., AIR 1963 SC 1572...............................03
26. Virsa Singh v. State of Punjab AIR 1958 SC 465 at 467…….06
27. Wipro Ltd. v. Collector of Customs, (2015) 14 SCC 161.........01
28. Farrell v. State, 32 Ohio St. 456, 459
(877)…………………………………………………………06
29. Francis Bowes Sayre, Mens Rea, 45 HARV. L. REV. 974
(1932)………………………………………………………..02.

ARTICLES
1. https://hbr.org/1998/03/making-business-sense-of-the-internet
............................................................................................................06
2. https://www.nationalcrimeagency.gov.uk/what-we-do/crime-threats/cyber-
crime.....................................................................................................06
3. https://www.unodc.org/lpo-brazil/en/frontpage/2018/04/article_-acting-to-stop
.............................................................................................................06

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 STATEMENT OF JURISDICTION

CRIMINAL APPEAL NO. /2023

FROM SPECIAL LEAVE PETITION (CRIMINAL) NO. OF 2023
The Petitioner has approached this Hon’ble Court under Art. 136 of the Constitution of India,
1950. Subsequent leave has been granted by this court.

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 STATEMENT OF FACTS
In the southern part of Asia, there is a developing country called the Republic of Stan. SSRO
is the Stanian Space Research Organisation. The space agency of the Government of The
Republic of Stan is based in the southern state of Periyana and has the mission to "harness
space technology for national development" while pursuing planetary exploration and space
science research.
Following recent cyberattacks on numerous websites of national significance, the SSRO
made the decision in March 2021 to take considerable steps to defend its own cyber
networks. Consequently, following a significant increase to its current cyber security, it
released a press statement offering a prize of 1,000,000 in its home currency to anyone who
could discover weaknesses in its security system. Those who were interested had to fill out an
online form on a third-party website, pay a fee of 500 in the local currency online, and then
wait to receive their Unique Participant Code (UPC), which would allow them to be
recognised and possibly claim the prize. After that, it was declared that the competition had
ended on August 31, 2021.
Tanvir Ahmad and Ramendra Singhal, first-year students at Stanian Institute of Cyber
Security, have also submitted an application for the competition in June 2021 to look for a
security flaw in SSRO. On the specified date, the duo was successful in their attack and got
access to SSRO's servers. Once the attack was effective, the virus started acting in a way that
the attackers had not anticipated. It began to copy the highly secret data that had been stored
inside the servers and affected several websites that the SSRO hosted. When they discovered
this virus's unusual behaviour while keeping an eye on the breach from their end, Tanvir
Ahmad and Ramendra Singhal became concerned.
Faced with an unexpected behaviour of their programme that they now knew would land
them in the midst of extremely dire circumstances, they sent an anonymous email to the
SSRO containing the virus's coding and any other information they thought would be useful
in terminating the attack. However, because SSRO's systems were overloaded, this warning
was not received until it was too late.
After the servers were restarted and order was restored, Tanvir Ahmad and Ramendra
Singhal's anonymously sent mail was received and tracked by the authorities using their IP
addresses. Both men were subsequently detained and charged under Sections 66 and 66F of
the Information Technology Act of 2000 and Section 441 of the Stanian Penal Code. After
reviewing the circumstances and the available evidence, the Ld. Sessions Court came to the
conclusion that the accused had no clear purpose to do anything wrong. As a result, they were
cleared of all charges.
The Ld. Sessions Court's decision was appealed by the State to the Periyana High Court.
According to the High Court's ruling, the two individuals' mere access constituted
unauthorised access, and the breach of the files' confidentially was found sufficient to convict
the two under the charged sections. Tanvir Ahmad and Ramendra Singhal were found
responsible for violating Sections 66 and 66F of the Information Technology Act of 2000 as
well as Section 441 of the Stanian Penal Code as a result of the Sessions Court's decision
being overturned. They have since appealed to The Republic of Stan's Supreme Court.

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 ISSUES RAISED

ISSUE 1

WHETHER THERE HAS BEEN A VIOLATION OF THE FUNDAMENTAL RIGHTS OF

THE ACCUSSED VIS-À-VIS PRESENCE OF GUILT UNDER THE PROVISIONS OF
THE INFORMATION TECHNOLOGY ACT, 2000?

ISSUE 2

WHETHER OR NOT THERE HAS BEEN A VIOLATION OF SECTION 441 OF IPC?

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 SUMMARY OF ARGUMENTS

1. WHETHER THERE HAS BEEN A VIOLATION OF THE FUNDAMENTAL

RIGHTS OF THE ACCUSSED VIS-À-VIS PRESENCE OF GUILT UNDER
THE PROVISIONS OF THE INFORMATION TECHNOLOGY ACT, 2000?

The appellant's fundamental rights have been flagrantly violated. The requirements of
Sections 66 and 66F of the IT Act, 2000 also prohibit a conviction for the accused In this
instance, the SSRO independently invited individuals to learn about security holes in its
system through a public announcement which the defendant has applied, acquired a UPC
code in addition for the same. The accused began looking for weaknesses in the system at
that point, and eventually succeeded. Through this notification, the SSRO demonstrated its
readiness to accept and launch an attack in response to their open offer. Later, when they were
unable to stop the attack or retract the system.

The appellants were given full responsibility by the authorities in an effort to avoid
culpability. therefore, the action of the authorities is irrational, arbitrary, and unjust owing to
which it grossly violates the fundamental rights of the accused.

In the present case because there is absence of dishonest and fraudulent intention coupled
with the fact that SSRO had permitted the accused to actually access the system.

2. WHETHER OR NOT THERE HAS BEEN A VIOLATION OF SECTION 441

OF IPC?

There is no infringement of section 441 of the IPC21, which addresses criminal trespass,
in the current instance. It is clear from section 441 of the IPC that unauthorised entry into
or upon property in the possession of another person, or unlawfully remaining there after
lawful entry, can satisfy the definition of criminal trespass if, and only if, such entry or
unlawful remaining is done with the intent to commit an offence, or to intimidate, insult,
or annoy the person in possession of the property. However, in this instance, SSRO was
the one who granted the accused authorization and made a reward guarantee if they

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 discovered weaknesses in the system; as a result, the objective was to obtain the payment
rather than cause harm.

The petitioner may also invoke section 79 of the IPC, which states that nothing done by a
person who is justified by law, or who mistakenly thinks themselves to be so because of
an error in fact rather than a mistake in law, is unlawful

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 ARGUMENTS ADVANCED

1. WHETHER THERE HAS BEEN A VIOLATION OF THE FUNDAMENTAL

RIGHTS OF THE ACCUSSED VIS-À-VIS PRESENCE OF GUILT UNDER
THE PROVISIONS OF THE INFORMATION TECHNOLOGY ACT, 2000?
2. It is humbly submitted before this hon’ble court that there has been a gross violation
of the fundamental rights of the appellant. Additionally, also, the accused cannot be
found guilty under the provisions of Section 66 and 66F of the IT ACT, 2000.
The same shall be substantiated based on the following grounds:

A. VIOLATION OF FUNDAMENTAL RIGHTS OF THE ACCUSED

(ARTICLE 14 & 21)

3. If an act is arbitrary, it is implicit that the act is antithetic to equality and thus violative
of Art. 141. Manifest arbitrariness, therefore, must be something done by the
legislature capriciously, irrationally and/or without adequate determining principle.
Also, when something is done which is excessive and disproportionate, such act
would be manifestly arbitrary.2

4. The Supreme Court has recurrently held that vague provisions must be struck down as
being arbitrary and unreasonable.3 An analysis of cyber terrorism as defined under
Section 66 (F) reveals that the impugned definition is ambiguous, unreasonable and
broad enough to cover any act concerning to internet within the ambit of Cyber
Terrorism. Such a loose definition opens the floodgate for arbitrary and selective
application by the state machinery (Mohanty, 2011). It provides state agencies with
ample opportunity to harass and exploit any person.

1
Utkal Contractors & Joinery Pub. Ltd. v. State of Orissa, (1987) 3 SCC 279; See also Wipro Ltd. v. Collector
of Customs, (2015) 14 SCC 161.
2
8E.V. Chinnaiah v. State of Andhra Pradesh, (2005) 1 SCC 394; See also Mahesh Chandra Jain v. Uttar
Pradesh Financial Corp., (1993) 2 SCC 279; RaghunathroGanpatrao v. Union of India, 1994 Supp (1) SCC 191.
3
State of Madhya Pradesh v. Baldeo Prasad, (1961) 1 S.C.R. 970; A.K. Roy & Ors. v. Union of India & Ors.,
(1982) 2 S.C.R. 272; See Shreya Singhal v. Union of Indra, (2015) 5 S.C.C. 1, ¶¶ 67-7

1|Page
 5. In the present case the SSRO, on its own invited people to find out vulnerabilities in
its system, through a public notification.4 To which the accused has applied and
further received a UPC code for the same.5 It was then that the accused started
working on finding vulnerabilities in the system, and ended up succeeding.6

6. The SSRO, through this notification showed its preparedness towards being willing to
accept and attack as a part of the open offer made by them.7 Later, when they were
unable to retract the system, or stop the attack. The authorities to evade liability
pinned the entire blame on the appellants.8

7. It is therefore submitted that the action of the authorities is irrational, arbitrary, and
unjust owing to which it grossly violates the fundamental rights of the accused.

8. Art. 219 guarantees to every person fundamental right to life and personal
liberty.10The expression ‘personal liberty’ in Art. 21 is of the widest amplitude.11 and
it covers a variety of rights which go to constitute the personal liberty of a person.12
Such personal liberty cannot be deprived in an unjust and unfair manner. Contrary to
what has happened in the present case.

B. ABSENCE OF GUILT UNDER THE PROVISIONS OF SECTION 66 &

66F OF THE IT ACT, 2000

9. The general provision with respect to “computer related offences” 13 in the IT Act, i.e.,
Section 66 of the IT Act, which is a criminal provision, punishes acts, falling under
Section 43 of the IT Act when done “fraudulently or dishonestly”.

4
Para 2, Moot Proposition.
5
Id.
6
Para 3, Moot Proposition
7
Para 2, Moot Proposition
8
Para 4, Moot Proposition
9
INDIA CONST. art 21
10
Francis Coralie Mullin v. Adm'r Union Territory of Delhi, (1981) 1 SCC 608 (India); Meera Santosh Pal v.
Union
of India, (2017) 3 SCC 462; Maneka Gandhi v. Union of India, (1978) 1 SCC 248.
11
T.V. Vatheeswaran v. State of Tamil Nadu, (1983) 2 SCC 68 (India); Bachan Singh v. State of Punjab, (1980)
2 SCC 84 (India).
12
Satwant Singh Sawhney v. D. Ramarathnam, (1967) 3 SCR 525 (India); Kharak Singh v. State of Uttar
Pradesh, (1964) 1 SCR 332; Gobind v. State of Madhya Pradesh, (1975) 2 SCC 148.
13
R.K. CHAUBEY, AN INTRODUCTION TO CYBER CRIME AND CYBER LAW 372 (2nd ed., 2012).

2|Page
 10. Essentially, two broad ingredients must be satisfied to bring an act within the ambit of
Section 66 of the IT Act.14 First, the act should come within the ambit of Section 43,
and second, the act must be done either fraudulently or dishonestly, i.e., the intention. 15
As regards the first ingredient, Section 43 of the IT Act, in its relevant part, covers the
act of accessing a computer16, downloading, copying, or extracting any data or
information from such a computer.17

11. The analysis undertaken, however, has little to do with the first ingredient. For our
purposes, it is the required intention which is pertinent to highlight. Briefly, the two
degrees of intention mentioned in the provision, could be understood as follows:
12. Fraudulently - An act is done fraudulently when done with an intention to
defraud.18 Where there is a benefit or advantage or even the likelihood of advantage
to the deceiver as a result of the deceit, he is said to have an intention to “defraud.”19

13. Dishonestly - An intention to gain wrongfully by getting what one does not have
amounts to a dishonest intention.20 To gain wrongfully simply indicates towards
gaining unlawfully.21

14. In the present case because there is absence of dishonest and fraudulent intention
coupled with the fact that SSRO had permitted the accused to actually access the
system.

14
§70(3), Information Technology Act, No. 21 of 2000, Acts of Parliament, 2000 (hereinafter “IT Act, 2000”)
15
Francis Bowes Sayre, Mens Rea, 45 HARV. L. REV. 974 (1932).
16
APARNA VISHWANATHAN, CYBER LAW 97 (1st ed., 2012).
17
§43, IT Act, 2000, supra note 7.
18
§25, IND. PEN CODE, 1860.
19
B.V. Padmanabha Rao, In re, 1969 SCC OnLine Kar 161 : 1970 Cri LJ 1502; Vimla v. Delhi Admn., AIR
1963 SC 1572.
20
§24, IND. PEN. CODE, 1860; §5(3), Ch. 6, The Fraud Act 2006 (Eng
21
.). K.N. Mehra v. State of Rajasthan, AIR 1957 SC 369.

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 MEMORIAL ON BEHALF OF THE APPELLANT

2. WHETHER OR NOT THERE HAS BEEN A VIOLATION OF SECTION 441 OF

IPC

15. It is humbly submitted before the hon’ble court that in the present case there is no
violation of section 441 of IPC22 which talks about criminal trespass.the same shall be
substantiated on the following grounds.
A. LACK OF CRIMINAL INTENTION

16. As per the section 441 of Indian Penal Code 1860 criminal trespass23 means, whoever
enters into or upon property in the possession of another with intent to commit an
offence or to intimidate, insult or annoy any person in possession of such property, or
having lawfully entered into or upon such property, unlawfully remains there with
intent thereby to intimidate, insult or annoy any such person, or with intent to commit
an offence, is said to commit “criminal trespass”.

17. It is evident from the provision of section 441 of IPC that unauthorised entry into or
upon property in the possession of another or unlawfully remaining there after lawful
entry can answer the definition of criminal trespass if, and only if, such entry or
unlawful remaining is with the intent to commit an offence or to intimidate, insult or
annoy the person in possession of the property.
18. In other words, unless any of the intentions referred in section 441 is proved no
offence of criminal trespass can be said to have been committed. Such intention must
be gathered from the facts and circumstances of a given case.24 Unauthorised
occupation -section 441 of IPC said that making unauthorised occupants (after due
notice) equivalent to criminal trespass said in case.25
A.1. INGREDIENTS OF CRIMINAL TRESPASS

Criminal trespass has two components

I. FIRST, ENTERING ANOTHER PERSON'S PROPERTY WITH THE INTENT TO

COMMIT A CRIME;

22
Indian Penal Code, 1860
23
Suresh Chandra Bahri v. State (Bihar AIR 1994 SC 2420)
24
Rajinder V State of Haryana (1955) 5 SCC 187
25
S.D. Bandi v. Karnataka SRTC (2013) 12 SCC 631

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 MEMORIAL ON BEHALF OF THE APPELLANT

II. SECOND, ENTERING A PROPERTY LEGALLY BUT STAYING THERE WITH

THE INTENTION TO DO DAMAGE OR CAUSE ANNOYANCE. THEREFORE,
THE FOLLOWING ARE NECESSARY ELEMENTS FOR PERPETRATING
CRIMINAL TRESPASS:
A.2. INTENTION

19. "actus non facit reum nisi mens sit rea" is a cardinal rule of criminal law. There are
two necessary element in a crime, namely, a physical element i.e "actus reus" and
secondly, a mental elements "mens rea".26

20. As stated earlier a leading doctrine of criminal law liability even in modern times is
actus non facit reum nisi men sit rea. It is a cardinal doctrine of the criminal law and
has been accepted not only by the courts in England but also Indian courts".27

21. There are two necessary elements in a crime namely, first a physical element, and
secondly, a mental element. Former is known technically as actus reus and the latter
as mens rea. The actus reus may be an act of omission or an act of commission28 but
in order that the actus reus may be punishable it must jointly be accompanied by a
guilty mind.

22. If it is proved that the intention of the accused parties was not to insult, harm or annoy
the owners or possessors of the property, then it would not amount to criminal
trespass. The Intention is the essence of this crime, and if there is no dominant motive
to commit the crime, no criminal trespass.

23. Further, it is to be proved that the intention of the accused was not probable but an
actual one, this principle was laid down in Ramjan Misrty v Emperor.29 Intent to
commit an offence essential condition for constituting offence under - Mere trespass
in absence of this condition would not amount to ‘criminal trespass’-Matter in a

26
Basdev v. State of Pepsu AIR 1956 SC 488.
27
State of Maharashtra v. Mayer Hans George AIR 1965 SC 722.
28
Sections 32 & 33 IPC
29
Ramjan Misrty v Emperor

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 MEMORIAL ON BEHALF OF THE APPELLANT

civil dispute regarding eviction cannot be adjudicated under offence under section
441.30

24. Currently, the two most popular sectors in the world are networking and cyber
security.31 Every nation on earth aspires to utilise the Internet to its fullest potential.
The Internet is used by businesses to operate and manage their activities.32 The
internet has made the work of these organisations easier, but it also puts them in
danger. Because of this, ethical hacking is a relatively new profession that is growing
quickly.33

25. Trespass is defined in Indian criminal law under section 441 of the Indian Penal Code
(IPC), 1860, and has a very broad definition. In a nutshell, it defines trespass as
accessing another’s property with malice with the aim to hurt or intimidate the owner
of the property in question.34 The type of property required to constitute the crime of
trespass is not mentioned here.

26. As, is evident from the above stated contentions intention is an extremely essential
facet to constitute liability under the provisions of the Indian Penal Code. In the
present case however, it was SSRO who gave the accused permission as well as the
promise of a reward if they would find vulnerabilities in the system, therefore the
intention was to win the reward and not to damage.
2. MISTAKE OF FACT A VALID DEFENCE

27. Section 79 of the Indian Penal Code35 - Act done by a person justified, or by
mistake of fact believing himself, justified, by law: Nothing is an offence which is
done by any person who is justified by law, or who by reason of a mistake of fact and
not by reason of a mistake of law in good faith, believes himself to be justified by
law, in doing it.36

30
Kanwal Sood v. Nawal Kishore (1983) 3 SCC 25
31
https://www.unodc.org/lpo-brazil/en/frontpage/2018/04/article_-acting-to-stop-cybercrime.html
32
https://hbr.org/1998/03/making-business-sense-of-the-internet
33
https://www.nationalcrimeagency.gov.uk/what-we-do/crime-threats/cyber-crime
34
Virsa Singh v. State of Punjab AIR 1958 SC 465 at 467.
35
Indian Penal Code, 1860
36
Farrell v. State, 32 Ohio St. 456, 459 (877)

6|Page
 28. In State of Orissa v. Khora Ghasi37 case, the accused while guarding is field short an
arrow at a moving object in the bona fide belief that it was a bear and, in the process,
caused a death of a man who was hiding there. The Court held that he could not be
held liable for the murder as his case was fully covered by Sections 79 and 80 of the
Code.

29. In Keso Sahu v. Saligram Shah38case, the accused showed that he in good faith and
believing that the offence of smuggling rice was going on in the plaintiff’s house and
thus he brings the cart and Cartman to the police station. The said suspicion was
proved to be wrong. The court held that the accused can take the defence of mistake
of fact as he is doing the act in good faith and believing it to be justified by law.

30. In the present case the learned opposing council may argue that the open offer was
retracted, but that being a mistake of fact in furtherance to the act of malware
committed to find vulnerabilities can be defended under the provision of Section 79.

37
State of Orissa v. Khora Ghasi, 1978 CrLJ 1305 (Orissa)
38
Keso Sahu v. Saligram Shah 1977 CriLJ 1725

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 PRAYER

Wherefore, in light of the issues raised, arguments advanced and authorities cited, it is humbly
prayed that this Honourable Court may be pleased to adjudge and declare that:

I. The appellants are no guilty under the provisions of Section 66 and 66F of the
Information and Technology Act, 2000.
II. The appellants are not guilty of Criminal Trespass .

And pass any other order that this Honourable Court may deem fit in the interests of justice,
equity, and good conscience.

All of which is humbly prayed,

Team, “TC-001”
Counsel for the Petitioner.

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