Moot Court Memorial 2022-23

TEAM NO : 1

V. R KRISHNAN EZHUTHACHAN LAW COLLEGE ,

NEMMARA 9TH SEMESTER MOOT COURT MEMAORIAL
2022 – 23

IN THE HON'BLE COURT OF V. R KRISHNAN

EZHUTHACHAN LAW COLLEGE, ELEVANCHERRY,
NEMMARA

PIL NO. 1224/ 2023

IN THE MATTERS OF :
PRATAP SINGH ......... PETITIONER
V.
STATE ......... RESPONDENT

WRITTEN SUBMISSION ON BEHALF OF PETITIONER

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TABLE OF CONTENTS

1 LIST OF ABBREVIATIONS
2 INDEX OF AUTHORITIES
3 STATEMENT OF JURISDICTION
4 STATEMENT OF FACTS
5 ISSUES RAISED
6 SUMMARY OF ARGUMENTS
7 ARGUMENTS ADVANCED

a) WHETHER PIL FILED IS MAINTAINABLE OR NOT ?

• The pil has been filed appropriately.
• There is violation of fundamental right.
• No existence of alternate remedy
b) WHETHER THE FARMERS OCCUPATION OF PUBLIC SPACE TO PROTEST
IS VIOLATIVE OF RESIDENTS RIGHT TO MOVEMENT ?
• Freedom of movement is violated
• Freedom of movement and personal liberty is violated
• No violation of respondent’s right to form association
• Right to assembly in correlation to speech and expression

8 PRAYER

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LIST OF ABBREVIATIONS

& And

AIR All India Reporter

Anr. Another

HC High court

SC Supreme court

Hon'ble Honourable

Ors. Others

U. O. I Union of India

V. Versus

Ie. That is

Ltd Limited

ICCPR International convention on civil

and political rights

Govt. Government

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SCC Supreme court cases

INDEX OF AUTHORITIES

STATUTES
• The Constitution Of India, 1950

TREATIES
• International Covenant on Civil and Political Rights (Adopted by United
Nations)
BOOKS
• Seervai H.M., Constitutional Law Of India, 4th Edition 2002, Volume Universal Book
Traders.
• Shukla V.N., Constitution Of India 13th Edition ,Eastern Book Company.

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TABLE OF CASES

1. Kesavananda Bharati Sripadagalvaru & Ors. V. State of Kerala & Anr (1973) 4 SCC 225; AIR
1973 SC 1461
2. Bandhua Mukti Morcha vs Union Of India & Ors,1984 SCR (2) 67
3. Golaknath v. State of Punjab (1967) AIR 1643
4. Lachhman Dass v. State of Punjab AIR 1963 SC 222
5. Minerva Mills Ltd & Ors v. UOI & Ors AIR 1980 SC 1789
6. Dharam Dutt v. Union of India (2004) 1 SCC 712
7. Kharak Singh V. State of UP AIR 1963 SC 1295
8. State of Uttar Pradesh Vs. Kaushalya AIR 1964 SC 416
9. Manekha Gandhi v. Union of India AIR 1978 SC 597
10. Sunil Batra vs Delhi Administration 1978 AIR 1975
11. Chameli Singh vs State Of U.P SLP No.12122 of 1995
12. Olga Tellis v. Bombay Muncipal Corporation AIR 1986 SC 180
13. Ramlila Maidan Incident v. Home Secretary, Union of India & Others 2012 (2) SCALE 682.
14. Asha Ranjan v. State of Bihar and Ors 2017 (4) SCC 397
15. Railway Board, New Delhi v. Niranjan AIR 1969 SC 966
16. Madhu Limaye And Anr vs Ved Murti & Ors 1971 SCR (1) 145
17. Indian Express v. Union of India,(1985) 1 SCC 641
18. Union of India v. Assn. For Democratic Reforms AIR 2001 Delhi 126
19. State Of U.P vs Raj Narain & Ors 1975 AIR 865

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STATEMENT OF JURISDICTION

The petitioner have approached the Hon’ble supreme court of India under Article 32 of the
Indian Constitution , 19501.

1
32. Remedies for enforcement of rights conferred by this Part

(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 clause ( 1 ) and ( 2 ), Parliament may
by law empower any other court to exercise within the local limits of its jurisdiction all or any of the
powers exercisable by the Supreme Court under clause ( 2 )
(4) The right guaranteed by this article shall not be suspended except as otherwise provided for by this
constitution

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STATEMENT OF FACTS

The Parliament passed three laws in September 2020 Farmers (Empowerment & Protection)
Agreement of Price Assurance & Farm Services Act, 2020, Farmers Produce Trade &
Commerce (Promotion & Facilitation) Act, 2020 and Essential Commodities (Amendment) Act,
2020 (‘farm laws’). The farmers, farmers’ rights groups and the opposition political parties have
severely contested the enactment of the farm laws. They suspect that the new legislative changes
would adversely impact the farmers and create a private market.
With allowing of trade outside of APMCs, the farmers assert that private and large companies
would be able to procure produce at incidental prices. Moreover, the proposed contract farming
framework might lead to the grabbing of agricultural land by corporate entities. The farmers
from several States started protest the laws implemented.
In December 2020, some residents of the National Capital Region Delhi filed petitions claiming
that the road blockade caused by prolonged protests was violating the residents’ right to free
movement. The Delhi Police filed an application on January 11th 2021 to restrict the protesting
farmers from disturbing the Republic Day celebrations at Delhi. The Police claim that the
proposed tractor parade would cause a massive law and order situation.
The petitioner filed writ under PIL in Supreme court on violation of fundamental rights. Supreme
court.

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ISSUES RAISED

1. Whether Pil Filed Is Maintainable Or Not?

2. Whether The Farmers’ Occupation Of Public Space To Protest Is Violative Of The

Residents’ Fundamental Rights?

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SUMMARY OF ARGUMENTS

1. WHETHER THE PIL FILED IS MAINTAINABLE ?

It is most humbly submitted before this hon’ble apex court of India that the
instant Public interest litigation is maintainable before this hon’ble court as the interest
litigation is filed at the garb of public interest. PIL is a legal tool. In this case of road
blockage if the roadblock is causing inconvenience or posing a threat to the safety and
security of the public then a PIL can be filed to seek relief. The PIL can be filed in the
High Court or the Supreme Court of India. Road blockage due to protest PIL can be filed
to remove road blockage if they cause inconvenience to the public.

2. WHETHER THE FARMERS’ OCCUPATION OF PUBLIC SPACE TO

PROTEST IS VIOLATIVE OF THE RESIDENTS’ FUNDAMENTAL RIGHTS ?

It is humbly contended that there is violation of fundamental right enumerated in the

Indian constitution. The petioner’s right guaranteed under Art. 19,21 of constitution is
infringed. There has bee encroachment on the freedom of movement and personal liberty.

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ARGUMENTS ADVANCED

It’s humbly submitted before The Hon’ble apex court that the PIL is maintainable in this
court and there is an infringement in the petitioner’s fundamental right.

1.1 PIL is maintainable

Public interest litigation refers to legal action taken to safeguard the interests of the
public. In India, this has been made possible through the use of public interest litigation (PIL) or
social action litigation (SAL). Such litigation can be initiated in a court of law to address issues
that affect the public, including pollution, terrorism, road safety, construction hazards, among
others. Any matter that impacts the interests of the public can be resolved through public interest
litigation.
The court can take up the matter suo motu or on the petition of an individual who is
motivated by public interest. Public interest litigation is a tool that empowers the public to take
legal action through judicial activism. However, the petitioner must demonstrate to the court that
the legal action is taken for the public good, and not for personal gain or out of frivolous
intentions1.
Public interest litigation is not defined in any statute or in any act. Judges have interpreted it to
consider the intent of the public at large. Although, the main and only focus of such litigation is
only Public Interest there are various areas where a Public interest litigation can be filed. For e.g.
- Violation of basic human rights of the poor

- Content or conduct of government policy

- Compel municipal authorities to perform a public duty.

- Violation of religious rights or other basic fundamental rights.

Public interest litigation is primarily based on Article 32 and Article 226 of the Constitution,
which empower the Supreme Court and High Courts, respectively, to protect fundamental rights
and issue writs for the enforcement of these rights. Public interest litigation in India has been
instrumental in promoting social justice, environmental protection, and accountability of public
authorities.
Article 32 of the Indian Constitution grants the right to constitutional remedies, allowing
individuals to directly approach the Supreme Court for the enforcement of fundamental rights. It

1
https://www.toppr.com/guides/legal-aptitude/jurisprudence/public-interest-litigation

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states that any person can move the Supreme Court for the enforcement of their fundamental
rights if they believe that these rights have been violated.
Article 226 of the Indian Constitution empowers the High Courts to issue writs, including writs
of habeas corpus, mandamus, prohibition, quo warranto, and certiorari. These writs are powerful
tools that enable the High Courts to protect the rights of individuals and address issues
concerning the public interest.
Thus the petitioner humbly contends that the required contents are satisfied in this case as it
violates the fundamental rights of the large population residing.PIL can be used to protect the
fundamental rights of citizens, including the right to freedom of movement. When riots lead to
road blockages, it hampers the ability of people to go about their daily lives, access essential
services, or reach their destinations. PIL can be filed to ensure that the rights of individuals are
safeguarded, and the obstruction is removed promptly.
Maintainability is mentioned in many cases such as
In a landmark case established the concept of PIL in India. The Supreme Court held that any
member of the public or social action group could file a petition seeking judicial redress in
matters of public interest. It broadened the locus standi (standing to sue) by allowing individuals
or organizations to file PIL petitions on behalf of others who may be unable to approach the
court themselves2.
In a case, the Supreme Court recognized the standing of social action groups or organizations to
file PIL petitions on behalf of marginalized and vulnerable sections of society. The court
emphasized that PIL should be used as an effective instrument for the enforcement of socio-
economic rights and the protection of the weak and disadvantaged.
In a PIL case highlighted the issue of air pollution in Delhi caused by vehicular emissions. The
Supreme Court, recognizing the significance of environmental protection, ordered several
measures to control pollution, including the introduction of compressed natural gas (CNG) as a
cleaner fuel for public transport3.
In a case dealt with the issue of sexual harassment of women in the workplace. The Supreme
Court, recognizing the lack of legislation on the matter, laid down guidelines and norms to be
followed by employers and institutions to prevent and address instances of sexual harassment,
thus providing a legal framework for women’s safety at workplaces4.
In a PIL case addressed the eviction and relocation of pavement dwellers in Mumbai. The
Supreme Court held that the right to livelihood is an integral part of the right to life under Article
21 of the Indian Constitution. It laid down guidelines that restrict forced evictions and
highlighted the obligation of the state to provide alternative arrangements for the displaced5 .

2
S.P. Gupta v. Union of India (1981)
3
MC Mehta v. Union of India (1986)
4
Vishaka v. State of Rajasthan (1997)
5
Olga Tellis v. Bombay Municipal Corporation (1985)

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Maintainability of PIL under Art 32

The maintainability of PIL under Article 32 depends on certain criteria and principles that have
been established through various judicial pronouncements.
Locus Standi: Under traditional legal principles, a person who is directly affected by a violation
of their rights has the standing to approach the court. However, in PIL cases, the concept of locus
standi has been expanded to allow any concerned citizen or organization to file a petition on
behalf of others who may be unable to approach the court themselves. The court has emphasized
the need for genuine public interest and the absence of personal gain or private grievance in PIL
petitions6
Public Interest Element: A PIL petition must involve a substantial public interest element. The
issue raised in the petition should go beyond the individual grievance and have a broader impact
on society or a significant segment of the population. The court examines the larger public
interest and the potential implications of the case in determining its maintainability. PIL
petitions7.
Constitutional or Legal Rights: PIL petitions under Article 32 must primarily concern the
violation or threatened violation of constitutional or legal rights. The petition should relate to the
enforcement of fundamental rights guaranteed under the Constitution or the interpretation and
application of constitutional provisions or statutes8.
Competence of the Petitioner: The petitioner filing the PIL must have the competence to raise the
issue and seek the relief sought. This means that the petitioner should have the requisite
knowledge, expertise, or experience in the relevant field to effectively represent the public
interest in the case9.
No Alternative Remedy: Generally, it is expected that the petitioner has exhausted other available
remedies before approaching the Supreme Court through a PIL. However, the court has
recognized that in certain exceptional cases, where there is a violation of fundamental rights or a
grave issue of public importance, it may waive the requirement of exhausting alternative
remedies
Overall, the Supreme Court has adopted a broad and inclusive approach in entertaining PIL
petitions under Article 32 to ensure access to justice and protect fundamental rights. The aim is to
strike a balance between expanding access to justice and preventing abuse of the process while
upholding the principles of public interest and constitutional remedie

6
https://legalstudymaterial.com/locus-standi-meaning-and-essential-ingredients-of-locus-standi
7
https://en.wikipedia.org/wiki/Public_interest
8
https://lawyersgyan.com/blog/difference-between-fundamental-rights-legal-rights-and-constitutional-rights
9
https://www.britannica.com/topic/competence-and-jurisdiction

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In a case is often referred to as the “Judge’s Transfer case” and is considered a landmark
judgment that recognized the concept of PIL in India. The Supreme Court held that any member
of the public having sufficient interest can approach the court for the enforcement of
fundamental rights through a PIL10.
In a case, the Supreme Court clarified that a PIL can be filed by any public-spirited person or
organization seeking relief for the enforcement of basic human rights, particularly the rights of
marginalized and vulnerable sections of society.
In a case, the Supreme Court addressed the issue of undertrial prisoners languishing in jails for
long periods without trial. The court emphasized that PIL can be filed on behalf of such prisoners
to secure their release and enforce their right to a speedy trial11.
In a case focused on prison reforms and the rights of prisoners. The Supreme Court recognized
the importance of PIL in addressing systemic issues affecting prisoners and improving the
conditions of prisons12
Public interest litigation provides an avenue for citizens to access justice, particularly in cases
where fundamental rights of individuals or the interests of society at large are at stake. The Apex
court has recognized the significance of PIL in ensuring access to justice for marginalized and
underprivileged sections of society who may not have the means or resources to approach the
court individually.
Article 32 of the Indian Constitution explicitly grants the right to constitutional remedies,
including the right to approach the Apex court for the enforcement of fundamental rights. Public
interest litigation serves as a vital mechanism to fulfill this constitutional mandate by allowing
concerned citizens or organizations to raise issues of public importance that require immediate
judicial intervention.

1.2 Fundamental Right Is Violated

Freedom of movement constitutionally guaranteed right in India under Article 19(1)(d) of the
Constitution. It ensures that citizens have the liberty to move freely throughout the territory of
India. Any restriction on this freedom must be reasonable and imposed in accordance with the
provisions of Article 19(5), which allows for reasonable restrictions in the interest of public
order, security, or public health.
Riots are disruptive events that can severely impede freedom of movement. The unlawful
assembly, violence, and chaos associated with riots can lead to road blockages, curfews, or
restrictions on movement imposed by the authorities to maintain public order and ensure the
safety of individuals.

10
S.P. Gupta v. Union of India (1981)
11
Hussainara Khatoon v. State of Bihar (1979)
12
Sunil Batra v. Delhi Administration (1978)

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The freedom of movement is unreasonably or unlawfully restricted in this case and it’s a
fundamental right that is violated here by the respondents.
The matter in question possesses a significant public interest element, as it affects the larger
fabric of society and the overall welfare of our nation. The repercussions of inaction on this issue
would extend beyond the individual grievance, impacting the very essence of justice and the
social fabric we hold dear.
In light of the urgency and importance of the matter, I kindly request this Honorable Court to
grant me permission to file the Public Interest Litigation and allow the case to be heard on its
merits. I am confident that with the court’s benevolent guidance and wisdom, justice will be
served, and the public interest will be upheld.

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ARGUMENTS ADVANCED

ISSUE NO. 2
1) Whether the farmers occupation of public space to protest is violative of residents'
fundamental right to movement?

It is humbly submitted before the Hon'ble apex court that there is violation of
petitioner's fundamental right.

1.1 Violation of fundamental Rights

Fundamental Rights in India enshrined in part III of the Constitution of India guarantee
civil liberties such that all Indians can lead their lives in peace and harmony as citizens of India.
These rights are known as “fundamental1” as they are the most essential for all-round development
i.e., material, intellectual, moral and spiritual and protected by fundamental law of the land i.e.
constitution2.
It is edged ahead of the court that the Fundamental Rights of the Indian Constitution are meant
for promoting the principle of political democracy by establishing the Doctrine of Limited
Government3. The fundamental idea of providing the Fundamental Rights to the citizen was to
prevent the establishment of arbitrary laws of the government and also protect the liberties and
freedom of the citizens. Establishment of Rule of Law instead of Rule of Men is the prime idea of
Fundamental Rights
These rights apply universally to all citizens of India, irrespective of their race, place of birth,
religion, caste or gender4. They are enforceable by the courts, subject to certain restrictions.
The Rights have their origins in many sources, including England's Bill of Rights5, the United
States Bill of Rights6 and France's Declaration of the Rights of Man7.Fundamental Rights can be
amended by the Parliament, however, such amendment should not contravene the basic structure
of the Constitution8.
In the instant case the petitioner politely Presented before the eminent court of law that they are
restricted from exercising their fundamental right by acts of the respondent.

1
Kesavananda Bharati Sripadagalvaru & Ors. V. State of Kerala & Anr (1973) 4 SCC 225; AIR 1973 SC 1461
2
Bandhua Mukti Morcha vs Union Of India & Ors,1984 SCR (2) 67
3
Golaknath v. State of Punjab (1967) AIR 1643
4
Lachhman Dass v. State of Punjab AIR 1963 SC 222
5
English Bill of Rights 1689
6
U.S Bill Of Rights, 1791
7
Declaration of the Rights of man and the Citizen 1791
8
Minerva Mills Ltd & Ors v. UOI & Ors AIR 1980 SC 1789

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1.1a. Freedom of movement is violated

Article 19(1)(d) under Part III of the Indian Constitution deals with the fundamental right
to freedom of movement.It guarantees the citizens of India the right to move9 freely throughout
the territory of India.The word “freely” connotes “without any absolute restriction”.
Australia is a party to seven core international human rights treaties. The right to freedom of
movement is contained in articles 12 and 13 of the International Covenant on Civil and Political
Rights (ICCPR10 ).Freedom of movement is closely intertwined with the preservation of other
human rights.
Act of restriction by authorities should be done after giving proper reason or conditions which
necessitated restricting the right11.
In the present case the denial of free movement are invoked by the respondents through a blockade
in the public road. By valuing and promoting freedom of movement, societies can unlock the
potential of individuals and foster a more inclusive and interconnected world. It is submissively
advanced before the hon'ble bar there is absolute violation of basic rights of the residents.
• Psychological constraint of free movement also amounts to the destruction of essence of
this article12.
*The reasonable restrictions that can be imposed by the state in the free movement of people either
in the interest of people13 or in the interest of scheduled tribes. In the constitutional realm, it is
important to take into account if the restrictions that are imposed are reasonable and proportional
to what is required to be achieved with them and as per the need of the hour.
It is politely advanced before the court of law such restriction must be reasonable and to promote
the security and security of people must be justified. In the instant case, the restriction upon free
movement are invoked not by an authority but people to impose their claim. So there is no legal
nexus between restrictions and social justice. The petitioner contends that it is clear indication of
infringement of their fundamental right to movement.

9
Section 13 of the Human Rights Act 2004
10
Adopted on 16 December 1966, BY General Assembly resolution 2200A (XXI)
11
Dharam Dutt v. Union of India (2004) 1 SCC 712
12
Kharak Singh V. State of UP AIR 1963 SC 1295
13
State of Uttar Pradesh Vs. Kaushalya AIR 1964 SC 416

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1.1b. Freedom of movement and personal liberty is violated

The liberty of the person is one of the oldest principles which was recognized at the time
of growth of mankind. It is a part of the Magna Karta14.
In India, the Protection of Life and Personal Liberty is a Fundamental Right granted to citizens
under Part III of the Constitution of India, 1950 15 . These Fundamental Rights represent the
foundational values cherished by the people and are granted against actions of the state, meaning
that no act of any state authority can violate any such right of a citizen except according to the
procedure established by law16.
It is to note that Life’ in Article 21 doesn’t merely mean the physical act of breathing or mere
animal existence17. It has a much wider scope including the right to live with human dignity, Right
to livelihood, Right to health, Right to pollution-free air18, etc.
The petitioner politely presented before the hon'ble law court that the respondent’s action
completely restrained from accessing their livelihood. As submitted earlier, the petioner’s basic
right to movement is violated due to the respondents action. It is to note that the constraint also
satisfy the meaning of denial of personal liberty to the petioner.
The Supreme Court ruled that homelessness and forced eviction would be in violation of the right
to life guaranteed under Article 21 and the right to movement under Article 19(1)(d)19. Article 21
of the Constitution shall not require the Indian courts to apply the due process of the standard of
law20.
Therefore most reverently submitted that there is unambiguous violation of petioner ‘s
fundamental Right.

14
V. N. Shukla, 13th Edition, Constitution of India
15
Article 21 of Indian Constitution, 1950
16
Manekha Gandhi v. Union of India AIR 1978 SC 597
17
Sunil Batra vs Delhi Administration 1978 AIR 1975
18
Sunil Batra vs Delhi Administration 1978 AIR 1975
19
Chameli Singh vs State Of U.P SLP No.12122 of 1995
20
Olga Tellis v. Bombay Muncipal Corporation AIR 1986 SC 180

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1.1c) No violation of respondent’s basic right to assembly

The right to assembly is protected under the First Amendment 21 of the United States
Constitution. It grants individuals the freedom to peacefully gather and associate with others for a
common purpose or cause.
The object of holding an assembly or a meeting is the propagation of ideas and to educate the
public. Hence, the right to assemble is a necessary corollary of the right to free speech and
expression. Article 19(1)(b) provides for the right to assemble peaceably and without arms22. This
includes the right to hold public meetings, hunger strikes, and the right to take out processions.
However, the assembly must be peaceful and without arms23.
The First Amendment states: “Congress shall make no law respecting an establishment of religion,
or prohibiting the free exercise thereof; or abridging the freedom of speech, or of the press; or the
right of the people peaceably to assemble, and to petition the Government for a redress of
grievances.”
The petitioner submissively advanced before the hon’ble court that there is no infringement into
the respondents right to assembly guaranteed under constitution. It is contended that the
opponent’s gathering was riotous and disturbed the peace of the community. It effect badly the
soul of public order and justice24.
The right envisaged is not absolute and when protests or assemblies turn violent, governments
may respond with restrictions such as requiring permits, imposing time, place, or manner
restrictions, or even using force to disperse the assembly 25. It is humbly submitted before the
eminent court law that the assembly formed by the respondent is infraction of petitioners
fundamental right to move freely.
Right to assembly in correlation to speech and expression
The right to assembly is closely connected to other rights, such as freedom of speech and
association. It serves as a critical tool for citizens to express their opinions 26 , voice their
concerns 27 , seek redress for grievances, and demand change from their government or other
institutions and join together with like-minded individuals or groups to promote common causes28
or advocate for social, economic, or political change. The petioner proved from the fact that
respondent abused the tool to meet their vengeance.

21
Adopted on December 15, 1791
22
Ramlila Maidan Incident v. Home Secretary, Union of India & Others 2012 (2) SCALE 682.
23
Asha Ranjan v. State of Bihar and Ors 2017 (4) SCC 397
24
Railway Board, New Delhi v. Niranjan AIR 1969 SC 966
25
Madhu Limaye And Anr vs Ved Murti & Ors 1971 SCR (1) 145
26
Indian Express v. Union of India,(1985) 1 SCC 641
27
Union of India v. Assn. For Democratic Reforms AIR 2001 Delhi 126
28
State Of U.P vs Raj Narain & Ors 1975 AIR 865

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However, the petitioner vehemently contended that the respondents used the tool in abusive
manner to meet their demands and is unconstitutional. It is politely requested the court to make
legal action in favour of petitioner because the act of opponent seems illegal only to promote the
group interest or community interest. Respondent fail to consider the people who gets effected by
their action. The plaintiff faced serious harm or legal injury and there is clear contravention to the
fundamental right under art. 19(1)

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PRAYER

WHEREFORE in the light of the issues raised, arguments advanced and authorities cited, it is humbly
requested that this Hon’ble Court may be pleased to adjudge and declare:

• The writ petition is maintainable.

• The action of the respondent is violative of fundamental right.
• That the respondent has no right to form assembly in public road.
And pass any such order or other order that it deems fit in the interest of Justice, Equity and Good
Conscience.
And for this, the Petitioner as in duty bound, shall humbly pray.

Place:........, India s/d...........

COUNSEL ON BEHALF OF THE PETITIONER

Argument Note On Behalf Of Petitioner