TEAM CODE :04

KL UNIVERSITY, VADDESWARAM

EXTERNAL MOOT COURT COMPETITION , 2019

IN THE SUPREME COURT OF THE REPUBLIC OF HINDUS

IN THE MATTER OF :

MR.X ……………...………………………. PETITIONER

Verses

UNION OF INDIA……………………………………………RESPONDENT

SUBMISSION ON BEHALF OF RESPONDENT

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 TABLE OF CONTENTS
CONTENTS
LIST OF ABBREVIATIONS ………………………………………………………………… 3
INDEX OF AUTHORITIES …………………………………………………………………. 4
CASES CITED…………………………………………………………………………………….5
STATEMENT OF JURISDICTION ………………………………………………………. 6
STATEMENT OF FACTS ……………………………………………………………………7
STATEMENT OF ISSUES ……………………………………………………………….. 8
SUMMARY OF ARGUMENTS .……………………………………………………….. 9
ARGUMENTS ADVANCED……………………………………………………………… 10
PRAYER ……………………………………………………………………………………….. 20

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 List of Abbrievations
SCC - Supreme Court Cases
SC - Supreme Court
CO - Company
LTD - Limited
ORS - Others
DPSP - Directive Principles of State Policy
FR - Fundamental Rights
ART - Article
MFG - Manufacturing
& - And

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 INDEX OF AUTHORITIES

LEGISLATIONS CITED: -

THE CONSTITUTIONAL LAW OF INDIA- 1950

BOOKS REFERRED:
JN PANDEY
MC MEHTA

LEGAL DATA: -

 Manupatra
 Indian kanoon

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 CASES REFERRED
1. Narendra v. Union of India
2. state of Gujarat v. Mirazpur Moti Kureshi Kassab Jamat
3. shankari Prasad Singh Deo v. Union Of India AIR 1951 SC 458
4. Golak nath & ors v. State of Punjab AIR 1643,1967 SCR(2)
7(2)
5. Kesawananda Bharati v. State of Kerala AIR 1973SC1481
6. Minerva Mills v. Union of India AIR 1980 SC 1789
7. Wamana Rao v. Union of India AIR 1981 SC 271
8. A.K.Gopalan V.State of Madras  1950 AIR 27, 1950 SCR 88
9. Maneka Gandhi v. Union of India  1978 AIR 597, 1978 SCR (2) 621
10. Central Inland Water Transport corporation v. Bojo Nath
Gangualy 1986 AIR 1571, 1986 SCR (2) 278
11. Champakam Dorairajan v.State of Madras (AIR 1951 SC
226)
12. Sanjeev Coke Mfg . co. v. Bharat Coaking Coal Ltd 1983 I
SCC147
13. I.R. Coelho(dead)LR v. State of Tamil Nadu 2007 (1) SC
137

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 STATEMENT OF JURISDICTION
THE HONOURABLE SUPREME COURT HAS EXCLUSIVE
JURISDICTION TO TRY AND ENTERTAIN THIS APPEAL UNDER
ARTICLE 32 OF THE INDIAN CONSTITUTION

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 STATEMENT OF FACTS

The Republic of Hindus (“The Republic”) is located in the South Asian Region
of Asia. Hindus was a British Colony for about 150 Years. It achieved
Independence in the year 1947. Now the Republic of Hindus has its own
Constitution, Parliament and Independent Judiciary. Although, majority of the
population belongs to Hindu Religion, many other religions like Islam,
Buddhism, Sikhism, Jainism and Christianity are followed by the people of the
Republic.
The Republic is characterized by a diversity of beliefs, practices, dressing,
cultural outlook and food habits. The food habits and the emotions associated
therewith are so strong and deep in the people that it paved the way for thefirst
war of independence against British. The Constitution of the Republic, declared
itself to be a Secular Nation, has conferred on all persons the fundamental right
to freely Profess, Practice and Propagate any religion of his/her choice. The
Apex Court of the Republic expanded the meaning of ‘Right to Life and
Personal Liberty’ to include every aspect that has connection with the person’s
meaningful life including religious faith and food habits.
The Republic has enacted the Hindus Animal Protection Act, 2018. The salient
features of the Act are as under:-
1. It bans the slaughter of Cow, Calves, Bulls and Bullocks.
2. It prohibits the Purchase, Sale, Disposal or Transport of Cows, Calves, Bulls
and Bullocks for the purpose of slaughter.
3. It prohibits the possession of the flesh of the Cow, Calves, Bulls and
Bullocks.
4. It criminalises the possession of beef per se.
5. Presumption of law as to guilt is against accused. In the meanwhile, there was
a political turmoil throughout the Republic. Various religious organisations
started large scale mobilization against ban on eating /preserving beef in the
name of Prevention of Cow Slaughter. For some of the minority communities,
eating beef is a common food habit. Moreover, beef is cheap when compared to
other non-vegetarian food. For poor masses, beef eating is one of the easy
sources of protein. In this background, a writ petition was filed before Supreme
Court under Article 32 of the Constitution challenging the constitutional validity
of the Act.

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 ISSUES OF THE CASE
1. Whether the Act is constitutionally valid or not?
2. To what extent State can interfere with the fundamental rights of Individuals?
3. Can a petitioner seek remedy for violation of his fundamental rights while
legislation seeks to achieve ‘compelling public interest’?
4. For implementation of Directive Principles of State Policy, can a
Fundamental Right be restricted?

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 SUMMERY OF ARGUMENTS
1. Whether the Act is constitutionally valid or not?
It is humbly submitted before the hon’ble Supreme court that Act passed is
constitutionally valid and is in the best interest of the welfare of the state.
2.To what extent State can interfere with the fundamental rights of
Individuals?
It is humbly submitted before the hon’ble Supreme Court the State can interfere
with the fundamental rights of individuals to certain extent
3. Can a petitioner seek remedy for violation of his fundamental rights
while legislation seeks to achieve ‘compelling public interest’?
It is humbly submitted before the hon’ble Supreme Court petitioner can seek
remedy for violation of his fundamental rights under Article 32 of the
Constitution
4. For implementation of Directive Principles of State Policy, can a
Fundamental Right be restricted?
It is humbly submitted before the hon’ble Supreme Court for implementation of
Directive Principles of State Policy Fundamental rights can be restricted.

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ISSUE:1
Whether the Act is constitutionally valid or not?
The Directive Principles contained in Part IV of the Constitution set out the
aims and objectives to be taken up by the states in the governance of the
country. The idea of welfare State envisaged by our constitution can only be
achieved if the States endeavour to implement them with a High sense of
moral duty. The Directives Principles are the ideals which the Union and
State Governments must keep in mid while they formulate policy or pass a
law. They lay down certain economic, social and political principles, suitable
to peculiar conditions prevailing in India.
38(1)- provides that the State shall strive to promote the welfare of the people
by securing and protecting as effectively as it aims ,a social order in which
justice- social, economic and political- shall inform all the institutions of
national life.
The Constitution (44th Amendment) Act, 1978 inserted clause (2)in Article
38. It provides- The State shall, in particular, strive to minimize the
inequalities in income, and endeavour to eliminate inequalities in status,
facilities and opportunities, not only amongst individuals but also amongst
groups of people residing in different areas or engaged in different
vocations

The State which conferred Fundamental Rights also imposed certain

Fundamental Duties to follow. The fundamental duties, are, therefore,
Intended to serve as a constant reminder to every citizen that while the
constitution specifically conferred on them certain fundamental rights, it also
requires citizen school observe certain basic norms of democratic conduct
and democratic behaviour. The preamble emphasises the duties, justice,
social, economical and political. In addition to this, the fundamental rights
guaranteed by the constitution are not absolute rights. The state is empowered
to impose reasonable restrictions and curtail these rights in the interest of
society. Restrictions may sometimes amount to prohibition.It was held in the
case of Narendra v. Union of India(1960).

Fundamental duties are enshrined in Article 51-A. As per Articles

51-A (f) to value and preserve the right heritage of our composite culture,

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 51-A(g) to protect and improve the natural environment including forests,
lakes, rivers and wild life and to have compassion for living creature.,
it is the duty of every individual to value and preserve the heritage and show
compassion to living creatures.
As cows calves, bulls and bullocks form the heritage of our composite
culture.
So it is the duty of individuals to preserve them and to show compassion for
them
The State which conferred Fundamental Rights also imposed certain
Fundamental Duties to follow. The fundamental duties, are, Therefore,
Intended to serve as a constant reminder to every citizen that while the
constitution specifically conferred on them certain fundamental rights, it also
requires citizen school observe certain basic norms of democratic conduct
and democratic behaviour. The preamble emphasises the duties, justice,
social, economical and political. In addition to this, The fundamental rights
guaranteed by the constitution are not absolute rights. The state is empowered
to impose reasonable restrictions and curtail these rights in the interest of
society. Restrictions may sometimes amount to prohibition.It was held in the
case of Narendra v. Union of India(1960).
They are enshrined in Article 51-A. As per Articles
51-A (f) to value and preserve the right heritage of our composite culture,
51-A(g) to protect and improve the natural environment including forests,
lakes, rivers and wild life and to have compassion for living creature.,
it is the duty of every individual to value and preserve the heritage and show
compassion to living creatures.
1. As cows calves, bulls and bullocks form the heritage of our composite
culture.
2. So it is the duty of individuals to preserve them and to show compassion
for them

In State of Gujarat v. Mirazpur Moti Kureshi Kassab Jamat,The petitioners who

were butchers, had challenged the constitutional validity of the Bombay
animal(preservation of Gujarat) Act, 1994 on the ground that it was violative of
their fundamental right to carry on trade and business under article 19 1 (g) of
the Constitution. Under the above legislation the Gujarat state had imposed a
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total ban on the slaughter of cows and calves and its progeny. The 7 Judge
Constitutional Bench of the Supreme Court by 6-1 majority, following its
number of decisions held that directive principles are relevant in considering the
reasonability of restrictions imposed on fundamental rights it is a constitutional
mandate under article 37 of the constitution which provides that in making laws
the state shall apply the directive principles. Restriction placed on fundamental
rights will be held to be reasonable and hence valid subject only two limitations.
1. It does not conflict with the fundamental rights and
2. The concerned legislature is competent to enact it.
The court held that the prohibition does not amount to a total ban on business
activity of butchers. They are left free to slaughter cattle other than those
specified in the act and carry on their business activity. The banning is not a
prohibition but only a restriction. Only a part of their activity has been
prohibited. The cow and her progeny constituted the backbone of Indian
Agricuture and rural economy as the cattle products and drought animal power
in the field of nutrition and health, agriculture and energy. In view of this the
government felt that it is necessary to formulate measures for their development
in all possible way as to prevent their slaughter. The ban on slaughter of cow
progeny imposed by the Act is, Therefore, In the interest of general public
within the meaning of clause (6) of the Article 19 of the constitution.
By virtue of these provisions and case it is contended that Act is
Constitutionally valid.
ISSUE:2
To what extent State can interfere with the fundamental rights of
Individuals?
State is the sovereign body and individuals are to be subjected to its laws. In
that context it may frame laws which individuals are to be bound of. In that
cases certain rights are given to individuals to protect from the arbitrary power
of state, and those rights are called Fundamental Rights.The Fundamental
Rights are individual rights that are enforced against the arbitrary invasion by
the state.
Fundamental Rights form the basic structure of the Constitution. They cannot be
taken away by framing laws.
According to Article 368 Power of Parliament to amend the Constitution and
Procedure there of

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1)Notwithstanding anything in this Constitution, Parliament may in exercise of
its constituent power amend by way of addition, variation or repeal any
provision of this Constitution in accordance with the procedure laid down in this
article
But this was a question whether Fundamental Rights can be amended by the
Parliament under Article 368 came for consideration of the Supreme
Court within a year of the Constitution coming into force. In the Shankari
Prasad case (1951), the constitutional validity of the First Amendment Act
(1951), which curtailed the right to property, was challenged. The Supreme
Court ruled that the power of the Parliament to amend the Constitution under
Article 368 also includes the power to amend Fundamental Rights. The word
‘law’ in Article 13 includes only ordinary laws and not the constitutional
amendment acts (constituent laws). Therefore, the Parliament can abridge or
take away any of the Fundamental Rights by enacting a constitutional
amendment act and such a law will not be void under Article 13.
But in the Golak Nath case(1967), the Supreme Court reversed its earlier
stand. In that case, the constitutional validity of the Seventeenth Amendment
Act (1964), which inserted certain state acts in the Ninth Schedule, was
challenged. The Supreme Court ruled that the Fundamental Rights are given
a ‘transcendental and immutable’ position and hence, the Parliament cannot
abridge or take away any of these rights. A constitutional amendment act is
also a law within the meaning of Article 13 and hence, would be void for
violating any of the Fundamental Rights.
The Parliament reacted to the Supreme Court’s judgement in the Golak
Nath case (1967) by enacting the 24th Amendment Act (1971). This Act
amended Articles 13 and 368. It declared that the Parliament has the power to
abridge or take away any of the Fundamental Rights under Article 368 and
such an act will not be a law under the meaning of Article 13.
However, in the Kesavananda Bharati case (1973), the Supreme Court
overruled its judgement in the Golak Nath case (1967). It upheld the validity
of the 24th Amendment Act (1971) and stated that Parliament is empowered
to abridge or take away any of the Fundamental Rights. At the same time, it
laid down a new doctrine of the ‘basic structure’ (or ‘basic features’) of the
Constitution. It ruled that the constituent power of Parliament under Article
368 does not enable it to alter the ‘basic structure’ of the Constitution. This
means that the Parliament cannot abridge or take away a Fundamental Right
that forms a part of the ‘basic structure’ of the Constitution.
The doctrine of basic structure of the constitution was reaffirmed and
applied by the Supreme Court in the Indira Nehru Gandhi case (1975). In

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this case, the Supreme Court invalidated a provision of the 39th Amendment
Act (1975) which kept the election disputes involving the Prime Minister and
the Speaker of Lok Sabha outside the jurisdiction of all courts. The court said
that this provision was beyond the amending power of Parliament as it
affected the basic structure of the constitution.
Again, the Parliament reacted to this judicially innovated doctrine of ‘basic
structure’ by enacting the 42nd Amendment Act (1976). This Act amended
Article 368 and declared that there is no limitation on the constituent power
of Parliament and no amendment can be questioned in any court on any
ground including that of the contravention of any of the Fundamental Rights.
However, the Supreme Court in the Minerva Mills case4 (1980) invalidated
this provision as it excluded judicial review which is a ‘basic feature’ of the
Constitution. Applying the doctrine of ‘basic structure’ with respect to Article
368,thecourtheldthat:
“Since the Constitution had conferred a limited amending power on the
Parliament, the Parliament cannot under the exercise of that limited power
enlarge that very power into an absolute power. Indeed, a limited amending
power is one of the basic features of the Constitution and, therefore, the
limitations on that power cannot be destroyed. In other words, Parliament
cannot, under article 368, expand its amending power so as to acquire for
itself the right to repeal or abrogate the Constitution or to destroy its basic
features. The donee of a limited power cannot by the exercise of that power
convert the limited power into an unlimited one”.
Again in the Waman Rao case5 (1981), the Supreme Court adhered to the
doctrine of the ‘basic structure’ and further clarified that it would apply to
constitutional amendments enacted after April 24, 1973 (i.e., the date of the
judgement in the Kesavananda Bharati case)
The present position is that the Parliament under Article 368 can amend any
part of the Constitution including the Fundamental Rights but without
affecting the ‘basic structure’ of the Constitution. However, the Supreme
Court is yet to define or clarify as to what constitutes the ‘basic structure’ of the
Constitution. From the various judgements, the following have emerged as
‘basic features’ of the Constitution or elements / components / ingredients of the
‘basic structure’ of the constitution:
1. Supremacy of the Constitution
2. Sovereign, democratic and republican nature of the Indian polity
3. Secular character of the Constitution
4. Separation of powers between the legislature, the executive and the
judiciary

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5. Federal character of the Constitution
6. Unity and integrity of the nation
7. Welfare state (socio-economic justice)
8. Judicial review
9. Freedom and dignity of the individual
10. Parliamentary system
11. Rule of law
12. Harmony and balance between Fundamental Rights and Directive
Principles
13. Principle of equality
14. Free and fair elections
15. Independence of Judiciary
16. Limited power of Parliament to amend the Constitution
17. Effective access to justice
18. Principles (or essence) underlying fundamental rights.
19. Powers of the Supreme Court under Articles 32, 136, 141 and 1426
20. Powers of the High Courts under Articles 226 and 227
The State can interfere with the fundamental rights of individuals to an extent
that interference does not effect these elements of Basic Structure.
ISSUE: 3
Can a petitioner seek remedy for violation of his fundamental rights while
legislation seeks to acheieve ‘compelling public interest’?
The Directive Principles contained in Part IV of the Constitution set out the
aims and objectives to be taken up by the states in the governance of the
country. The idea of welfare State envisaged by our constitution can only be
achieved if the States endeavour to implement them with a High sense of moral
duty. The Directives Principles are the ideals which the Union and State
Governments must keep in mind while they formulate policy or pass a law.
They lay down certain economic, social and political principles, suitable to
peculiar conditions prevailing in India.
The Fundamental Rights are individual rights that are enforced against the
state. The object behind the inclusion of the Chapter of Fundamental Rights in
Indian Constitution is to establish ‘a Government of Law and not of man’ a
governmental system where the tyranny of majority does not oppress the
minority. In short, the object is to establish Rule of Law and it would not be
wrong to say that the Indian Constitution in this respect goes much ahead than
any other constitutions of the world. The object is not merely to provide security

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and equality of citizenship of the people living in this land and thereby helping
the process of nation building , but also and not less important to provide certain
standards of conduct, citizenship, justice and fairplay.
The importance of fundamental rights layed down in the historic judgement of
Maneka Gandhi v. Union of India, Bhagawati,J., observed: “These fundamental
rights represent the basic values cherished by the people of this country since
the Vedic times and they are calculated to protect the dignity of the individual
and create conditions in which every human being can develop his personality
to the fullest extent . They weave a ‘Pattern of guarantee’ on the basic structure
of human rights , and impose negative obligations on the State not to encroach
on individual liberty in its various dimensions.

By Article 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
Every person is entitled to seek remedy for violation of his fundamental rights
by Supreme Court.

ISSUE:4
For implementation of Directive Principles of State Policy, can a
Fundamental Right be restricted?
The Directive Principles contained in Part IV of the Constitution set out the
aims and objectives to be taken up by the states in the governance of the
country. The idea of welfare State envisaged by our constitution can only be
achieved if the States endeavour to implement them with a High sense of moral
duty. The Directives Principles are the ideals which the Union and State
Governments must keep in mid while they formulate policy or pass a law. They
lay down certain economic, social and political principles, suitable to peculiar
conditions prevailing in India.
Articles 38 and 39 embody the jurisprudential doctrine of ‘distributive justice”.
The Constitution permits and even directs the State to administer what may be
termed ‘distributive justice’. The concept of distributive justice in the sphere of
law making connote, inter alia, the removal of economic inequalities rectifying
the injustice resulting from dealings and transactions between unequals in
society is observed in the case of Central Inland Water Transport corporation
v. Brojo Nath Gangualy(1986).

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38(1)- provides that the State shall strive to promote the welfare of the people
by securing and protecting as effectively as it aims ,a social order in which
justice- social, economic and political- shall inform all the institutions of
national life.
The Constitution (44th Amendment) Act, 1978 inserted clause (2)in Article 38.
It provides- The State shall, in particular, strive to minimize the inequalities in
income, and endeavour to eliminate inequalities in status, facilities and
opportunities, not only amongst individuals but also amongst groups of people
residing in different areas or engaged in different vocations.
The new clause aims at equality in all spheres of life.
Directive Principles are non justiciable , that means they can’t be enforced by
courts. Where fundamental rights are justiciable which means they can be
enforced by courts. In Champakam Dorairajan case (1951) the Supreme Court
ruled that in case of any conflict between fundamental rights and Directives
Principles, the former would prevail. It declared that the Directive Principles
have to conform to and run as subsidiary to the Fundamental Rights. But,
it also held that the Fundamental Rights could be amended by the
Parliament by enacting constitutional amendment acts. As a result, the
Parliament mad the first Amendment Act (1951), the Fourth Amendment
Act (1955) and the Seventeenth Amendment Act (1964) to implement
some of the Directives.
The above situation underwent a major change in 1967 following the
Supreme Court’s judgement in the Golaknath case (1967). In that case, the
Supreme Court ruled that the Parliament cannot take away or abridge
anyof the Fundamental Rights, which are ‘sacrosanct’ in nature. In other
words,the Court held that the Fundamental Rights cannot be amended for
theimplementation of the Directive Principles.
The Parliament reacted to the Supreme Court’s judgement in the
Golaknath case (1967) by enacting the 24th Amendment Act (1971) and
the 25th Amendment Act (1971). The 24th Amendment Act declared that
the Parliament has the power to abridge or take away any of the
Fundamental Rights by enacting Constitutional Amendment Acts. The 25t
Amendment Act inserted a new Article 31C which contained the following
twoprovisions:
1. No law which seeks to implement the socialistic Directive Principles
specified in Article 39 (b) and (c) shall be void on the ground of
contravention of the Fundamental Rights conferred by Article 14

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(equality before law and equal protection of laws), Article 19 (protection
of six rights in respect of speech, assembly, movement, etc) or Article 31
(righttoProperty).
2. No law containing a declaration for giving effect to such policy shall be
questioned in any court on the ground that it does not give effect to such a
policy.
In the Kesavananda Bharati case (1973), the Supreme Court declared the
above second provision of Article 31C as unconstitutional and invalid on
the ground that judicial review is a basic feature of the Constitution and
hence, cannot be taken away. However, the above first provision of Article
31C was held to be constitutional and valid.
Later, the 42nd Amendment Act (1976) extended the scope of the above
first provision of Article 31C by including within its protection any law to
implement any of the Directive Principles and not merely those specified
in Article 39 (b) and (c). In other words, the 42nd Amendment Act
accorded the position of legal primacy and supremacy to the Directive
Principles over the Fundamental Rights conferred by Articles 14, 19 and
31.However,this extension was declared as unconstitutional and invalid by
the Supreme Court in the Minerva Mills case (1980). It means that the
Directive Principles were once again made subordinate to the Fundamental
Rights. But the Fundamental Rights conferred by Article 14 and Article 19
were accepted as subordinate to the Directive Principles specified in
Article39(b)and(c).
Further, Article 31 (right to property) was abolished by the 44th
AmendmentAct(1978).
In the Minerva Mills case (1980), the Supreme Court also held that ‘the
Indian Constitution is founded on the bedrock of the balance between the
Fundamental Rights and the Directive Principles. They together constitute
the core of commitment to social revolution. They are like two wheels of a
chariot, one no less than the other. To give absolute primacy to one over
the other is to disturb the harmony of the Constitution. This harmony and
balance between the two is an essential feature of the basic structure of the
Constitution. The goals set out by the Directive Principles have to be
achieved without the abrogation of the means provided by the
FundamentalRights’. The goal setout in part IV of the Constitution have to
be achieved without abrogating the means provided for by Part III. Held

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Art 31-C as originally introduced by the 25th amendement is
constitutionally valid.
IN Wamana Rao v. Union of India (1981), The Supreme Court reiterated
Article 31-C in its original form prior to 42 nd amendment was valid and all
the amendments to the constitution made prior to the decision of
keshavananda Bharathi case by which 9th schedule was amended and
several Acts and Regulations were include were valid but amendment
made on or after decision in the 9 th schedule would be open to challenge
on the ground that they were beyond the amending power of Parliament
for damaging the basic structure of the Constitution.
In Sanjeev Coke Mfg. Co v. Bharat Coking Coal Ltd(1983), the Supreme
Court expressed doubts on the validity of the decision in Minerva mills
case. A five Judge Bench of the Court , unanimously held- Since the
validity of section 4 of 42 nd Amendment which amended Art 31-c was not
directly at issue but was only an academic issue in Minerva mills case,
therefore, the determination of that question in that case was uncalled for
obiter and since validity of Art 31-c was upheld in Keshavananda Bharatis
case when its protection was confined to laws enacted to further the
directives under Art 39(b) and (c) “ the dialects, the logic and the rationale
involved in upholding the validity of Art 31-C “ should lead to the same
conclusion that Art 31-C with its extended protection is also
constitutionally valid.
In I.R.Coelho by LR v. State of Tamil Nadu (2007), a 9 Judge constitution
Bench headed by Chief Justice Y.K.Thakkar held – any law placed in the
Ninth schedule after April 24,1973 when keshavananda Bharati judgement
was delivered would be open to challenge on the ground that they destroy
or damage the basic feature, if the fundamental rights are taken away or
abrogated pertaining to the basic feature of the basic structure.
By judgements of the above cases it is contended that Article 31 c is wide and
confers more power on the State to implement Directive principles though they
effect Article 14 and 19 in view of rendering justice to the people at large.

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 Prayer
In light of the issues raised, arguments advanced, and authorities cited, counsil
requests this Hon’ble Court to
1. Reject the petition filed by the Petitioner
And Pass any other Order, Direction, or Relief that it may deem fit in the Best
Interests of Justice, Fairness, Equity and Good Conscience.
For This Act of Kindness, the petitioner Shall Duty Bound Forever
Pray.

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