IN THE SUPREME COURT OF INDIA

WRIT PETITION NO.

MS. NEHA LALITHA / GOOGLE,

YAHOO,
THE MINISTRY OF
ELECTRONICS AND
INFORMATION
AND THE UNION OF
INDIA

(Petitioner) (Respondent)

MEMORANDUM ON BEHALF OF THE PETITIONER

LIST OF ABBREVIATIONS
INDEX OF AUTHORITY
 STATEMENT OF JURISDICTION

The Petitioner has approached the Hon’ble Supreme Court under its jurisdiction as per
Article 32 of the Constitution of India.
Clauses 1),2) and 3) of the Article states that:
1) The right to move the Supreme Court by appropriate proceedings for the enforcement
of the rights conferred by this Part is guaranteed.
2) The Supreme Court shall have power to issue directions or orders or writs, including
writs in the nature of habeas corpus, mandamus, prohibition, quo warranto and
certiorari, whichever may be appropriate, for the enforcement of any of the rights
conferred by this Part.
3) Without prejudice to the powers conferred on the Supreme Court by clauses 1) and 2),
Parliament may by law empower any other court to exercise within local limits of its
jurisdiction all or any of the powers exercisable by the Supreme Court under clause2).

Therefore, it is humbly submitted that the writ petition under the Hon’ble Supreme
Court is maintainable.
 STATEMENT OF FACTS

1) A game called ‘LIFE IS RISK’ is available on search engines and social media
groups/ platforms/ apps.

2) This game has a ‘Controlling Manager’ who gives self harming tasks to the player.

3) These tasks involve like getting up at unusual hours of the night, watching horror
movies, walking on parapet walls of the buildings, taking overdoses of fatal drugs,
etc. which get more horrific and challenging as the game progresses.

4) There are general warnings and terms and conditions, which flash on the Computer
system before one hits the game which are as follows:
i) Participant may enter the game of his/her own free choice, however once the
participant starts the game, then he/she cannot chicken out, without the
permission of the Controlling Manager.
ii) Participant has to keep the instructions of this game confidential and not share
with anyone.
iii) The tasks are for those participants who want to prove themselves and be
rewarded at the end.
iv) Participant cannot assign the task(s) to any person and all the task(s) are to be
performed by the participant himself /herself only.
v) Participant has to remember to be focused on the task and aim to complete all
the tasks successfully.
vi) Participant is not allowed to share his/ her experience with his friends,
relatives or any other person(s).
vii) Participant is free to take any drugs or supplements that will help him/ her to
complete the tasks(s).
viii) Participant has to remain in touch with the ‘Controlling Manager’.
ix) Participant has to follow all the instructions of the ‘Controlling Manager’
scrupulously.
x) Participant is likely to feel unsafe or scared or crazy but he/she has to continue
to keep his mission/ task(s) confidential till it is accomplished.

5) The ultimate instruction on the 50th day is to end one’s life.

6) The people who are involved in this game especially young persons are ending their
lives leaving a note behind on their social media page stating ‘end’ with a picture of
‘Life is risk’.

7) The game is suspected to be initiated by some non-Indian person.

8) However, there is no cogent evidence either under the Information technology Act,
2000 or otherwise against any particular person or association or group or search
engine or App(s).

9) Cops are said to have launched a probe into the suicide incidents but till date no arrest
have been made and they are alleged to be ill equipped and unsuccessful.

10) Police believe that one young person alleged to be ring leader has been arrested in a
foreign country and charged with organizing about eight groups between 2013 to
2016 which “promote suicide”.
 ISSUES RAISED

1) Whether the Art. 19(1)(a), would be infringed, if nay directions are issued to
Respondent(s), to curb/stop/arrest such games?

2) Whether search engines and social media platforms/groups/Apps like Google,

WhatsApp, Instagram, Yahoo, etc. can be directed to stop providing services?

3) Whether Ministry of Home Affairs, Ministry of Electronics and Information

Technology and Ministry of Women & Child Development, can be directed to
arrange to arrest/ stop such games, to prevent further recurrence of such unwarranted
incidents, and if they fail to do so can they be made to face contempt proceedings?

4) Whether those who survive the attempt to commit suicide can be held liable under the
Indian Penal Code for ‘Attempt to commit suicide’ and can Information Technology
Act, 2000 be invoked in this matter?
SUMMARY OF ARGUMENTS
CONTENTION - 1