Argument Notes (R):

 May it please this honourable court? This is council lekshmi appearing

along with my co council sreekutty and sona as the council for the in the
case of the society for virturous treatment of animals (SVTA) v. Union of
India before this honourable court.
 The council seeks permission to address the bench collectively as the
“lordship”.
 Much obliged your lordships.
 With your lordships kind permission may the council brief the facts of the
case.
 Much obliged your lordships.
 Samudranadu is a state in the Union of Kalinga. The State is known for
its rich cultural heritage and diversity. “Yeruparugu” or buffalo is a
practice very popular in coastal SamudranaduThey are organized under
the banner Yeruparugu Samithis (Associations).
 Yeruparugu involves series of races between two different pairs of
buffaloes jockeyed by enthusiastic and youthful farmers or sports
persons during the race jockeys whip the buffaloes with stick, thorny
objects and other forms of irritants.
 Many animal lovers resented the open display of cruelty to animals and
made several representations to the government to put an end to the
unnecessary sufferings of the buffaloes by banning Yeruparugu.
 The Union of Kalinga for the purpose of preventing cruelty to Animals
passed a Model Law for the whole of the Union of Kalinga called the
Prevention of Cruelty to Animals Act 2001 which prohibited cruelty to
Animals in any form including sports involving animals
 Despite the several plea for banning Yeruparugu by a society called
Society for Virtuous Treatment to Animals and the recommendations of
Animal Safety Panel of Kalinga constituted under the Act of 2001, to
discontinue Yeruparugu it continued violence against buffaloes
continued unabated.
 The ASPK directed both Deputy Commissioner of Yaksha Loka and the
Department of Animal Husbandry, Samudranadu to take steps to stop
Yeruparugu. Samudranadu passed a statute called The Samudranadu
Regulation of Yeruparugu Act 2009. But the Act was unable to contain
violence and cruelty associated with Yeruparugu. The Kalinga Ministry of
Environment and Forests banned Yeruparugu. The notification was
 challenged stating that it was inconsistent with fundamental rights of
the citizens The Supreme Court while upholding the said notification
observed that the arguments advanced to justify Yeruparagu nt cannot
stand before the Section 3 of the PCA Act 2001.
 An issuance of notification by Union of Kalinga under Section 22 of the
PCA Act 2001 superseding 2011 notification banning Yeruparugu The
notification permitted Yeruparugu subject to safety conditions and
without violating the Rights of Animals under PCA 2001. The SVTA
Kalinga, along with other Animal Rights activists challenged the
notification as being violative of various provisions of the Constitution of
Kalinga, the provisions of PCA of 2001 and several other laws, both
domestic and international
Thus, as part of the above stated appeal the council is present before this
honourable court.
 If the lordships are well versed with the facts of the case, may the council
move on to the contentions.
 Much Obliged your lordship.
 The council for the appellant has mainly 4 inevitable contentions to be
presented before this honourable court.
 firstly, THE WRIT PETITION FILED UNDER ARTICLE 32 OF THE
CONSTITUTION OF KALINGA IS MAINTAINABLE?
 Secondly THE RIGHTS OF ANIMALS IS BEING VIOLATED BY
SPORTING EVENTS SUCH AS YERUPARUGU?
 thirdly, THE SPORTS LIKE YERUPARUGU IS NOT PROTECTED AS A
CULTURAL RIGHT UNDER ART. 29(1) OF CONSTITTUION OF UNION OF
KALINGA?
 finally, THE NOTIFICATION OF MINISTRY OF ENVIRONMENT AND
FOREST REVOKING THE BANNING OF YERUPARUGU IS VIOLATION
OF PCA AND AGAINST THE CONSTITUTION OF KALINGA
 Of these the first 2 contentions shall be dealt in detail by this council and
the later merits of the case shall be dealt by my co council.

 With the lordships kind permission may the council move on to the
contentions.

 Much obliged your lordships.

 The council humbly submits the first and the foremost contention before
this honourable court which is the THE WRIT PETITION FILED UNDER
ARTICLE 32 OF THE CONSTITUTION OF KALINGA IS MAINTAINABLE.
 (arguments)

 The council seeks permission to move on to her 2nd contention

 Much obliged your lordships.

(ARGUMENTS)

 Your lordships that brings to the end of this councils contentions. If the
lordships does not have any further questions the council would like to
yield the floor to my co council.
 Much obliged your lordships.