It is humbly submitted by the Respondent that by enacting and subsequently penalizing

individuals including the Petitioner, the State has not violated any Fundamental right including
the Right to life and personal liberty as enshrined under Article 21, as the penalty is in
furtherance to the procedure established by law.1 In reference to the impugned legislation
enacted by the state, certain societal safeguards are brought to force by protecting a vulnerable
section of the society from harmful and corrupting influence. The state in furtherance to such a
policy has not violated the livelihood of any individual.2
The provisions of the impugned legislation are just, fair and reasonable.3 The reasonable
restrictions imposed by the state fall squarely under the exceptions as laid down in Article 19(2)
of the Constitution of India.4

1
The State of Bombay vs. Atma Ram Sridhar Vaidya, AIR 1951 SC 157.
2
State of Punjab v. Ajaib Singh State of Madhya Pradesh, AIR 1953 SC 10.
3
Satwant Singh v. A.P.O. New Delhi, [1967] 3 SCR 525.
4
A.K. Goapalan v. The State, AIR 1950 SC 27.