Pil 30

A
TEAM CODE – PIL 30
1ST INSTITUTE OF LAW, NIRMA UNIVERSITY PIL DRAFTING COMPETITION, 2020
PUBLIC INTEREST LITIGATION
BEFORE THE HON’BLE SUPREME COURT OF GOTHAM
IN THE MATTER OF:
SANITIZE AND STAY HYGIENIC, A REGD. SOCIETY
… PETITIONER
VERSUS
REPUBLIC OF GOTHAM & ORS.
…RESPONDENTS
A
IN THE HON’BLE SUPREME COURT OF GOTHAM
(CIVIL ORIGINAL JURISDICTION)
WRIT PETITION (CIVIL) NO. __________ OF 2020
In the matter of:
Sanitize and Stay Hygienic, A Regd. Society … Petitioner
VERSUS
Republic of Gotham & Ors. … Respondents
INDEX
SL PARTICULARS PAGE NO.

NO.
1. Notice of Motion D
2. Urgent Application F
3. Memo of Parties H
4. Synopsis & List of Dates M-O
5. Writ Petition along with Affidavit 1-19
6. Memo of Appearance 20
7. Annexure P-1 PAN CARD OF PETITIONER 21
8. Annexure P-2 News report – Hindu Business Line 22

B
9. Annexure P-3 News Report – The Economic Times 23
10. Annexure P-4 News Report – The Times of India 24
11. Annexure P-5 News Report – The Times of India 25
12. Annexure P-6 News Report – Hindustan Times 26
13. Annexure P-7 News Report - WHO 27
14. Annexure P-8 News Report – Thomson Reuters 29
15. Annexure P-9 News Report – The economic times 30
16. Annexure P-10 News Report – India Today 31
17. Annexure P-11 News Report – UN Report 33
18. Annexure P-12 News Report – OP INDIA news report 35
19. Annexure P-13 News Report – NDTV 36
20. Annexure P-14 News Report – NEWS 18 37
21. Annexure P-15 News Report – The Print 39
22. Annexure P-16 News Report – The Indian Express 41
23. Annexure P-17 News Report – India Today 42
24. Annexure P-18 News Report – Money control 44

C
25. Annexure P-19 News Report – Times of Israel 45
26. Annexure P-20 – The Economic Times 48

D
In the matter of:
VERSUS
NOTICE OF MOTION
Sir,
The enclosed writ petition in the above named matter is being filed on behalf of the
Sanitize and Stay Hygienic i.e. Petitioner and is likely to be listed on __________ or
any other date, thereafter. Please take notice accordingly.
New Delhi
Date:
Filed by:
_____________
(Advocate for Petitioner)
A/523, Commercial Estate,

E
Masjid Road, Jaganpura,
New Delhi: 441100
Enclosed copy to:
1. All the respondents

F
In the matter of:
VERSUS
URGENT APPLICATION
Sir,
Kindly treat the accompanying writ petition as an urgent one as per the rules and orders
of this Hon’ble Court.
The ground of urgency is that there is a sudden outbreak of COVID-19 epidemic which
may affect thousands of people across the country if immediate actions are not taken.
This petition thus requires urgent attention of this Hon’ble Court.
Urgent directions are also prayed for.
_____________
Date: (Advocate for Petitioner)
New Delhi A/523, Commercial

Estate,
Masjid Road, Jaganpura,

G
New Delhi: 441100

H
MEMO OF PARTIES
1. Sanitize and Stay Hygienic

(A Registered Society),
Through its General Secretary,
Mr. ABC XYZ, aged 54 years,
R/o T- 45A, H.M. House, Second Floor,
Chandni Chowk, Delhi – 110066
… Petitioner
VERSUS
1. Republic of Gotham,
Through Chief Secretary,
Ministry of Health and Family Planning
North Block, New Delhi 11001.
2. State of Andhra Pradesh,
Building No. 7, Government Complex,
Guntur, Andhra Pradesh
3. State of Arunachal Pradesh,
Itanagar, Arunachal Pradesh 791111.
4. State of Assam,
I

Building No. 9, Assam Sachivalaya,
Guhwati 781006.
5. State of Bihar,
Secretariat, Patna, 800015.
6. State of Chhattisgarh,
Mantralaya, Naya Raipur 492002.
7. State of Goa,
Secretariat, Goa 403521.
8. State of Gujarat,
Sachivalaya, Gandhinagar 382010.
9. State of Haryana,
Civil Secretariat, Sector-1,
Chandigarh 160019.
10. State of Himachal Pradesh,
Secretariat, Shimla 171002.
11. Government of Jammu & Kashmir,
Civil Secretariat,
Srinagar 190001.
12. State of Jharkhand,
Project Building, Dhurwa,
J
Ranchi 834004.
13. State of Karnataka,
Vidhana Soudha,
Bengaluru 560001.
14. State of Madhya Pradesh,
Vallabh Bhavan,
Bhopal 462004.
15. State of Maharashtra,
Mantralaya, Madam Cama Road,
Mumbai 400032.
16. State of Manipur,
Old Secretariat,
Imphal 795001.
17. State of Meghalaya,
Meghalaya Secretariat,
Shillong 793001.
18. State of Mizoram,
New Secretariat,
Aizawl 796001.
19. State of Nagaland,
Civil Secretariat,
Kohima 797004.
K
20. State of Odisha,

Odhisha Secretariat,
Bhubaneshwar 751001.
21. State of Punjab,
Chief Secretariat,
Chandigarh 160001.
22. State of Rajasthan,
Secretariat, Jaipur 302005.
23. State of Sikkim,
Secretariat, Gangtok 737101.
24. State of Tamil Nadu,
Secretariat, Chennai 600009.
25. State of Telangana,
Adarsh Nagar, Hyderabad 5000063.
26. State of Tripura,
Secretariat, Agartala 799010.
27. State of Uttar Pradesh,
Uttar Pradesh Secretariat,
Lucknow 226001.
28. State of Uttarakhand,
L
Secretariat, Dehradun 248001.

29. State of West Bengal,
Mandirtala, Howrah 711102.
30. Andaman and Nicobar Administration,
Secretariat, Port Blair.
31. Administration of Daman and Diu,
Moti Daman, Daman 396220.
32. Administration of Lakshadweep,
Secretariat, Lakshadweep 682555.
33. Government of Puducherry,
Puducherry 605001.
34. Government of N.C.T. of Delhi,
Delhi Secretariat, New Delhi
… Respondents
DATE: 16.04.2020 PLACE: NEW DELHI
FILED BY:
Mr. ABC
Advocate for Petitioner
17, Central Lane, Jagatpura,
New Delhi-110001
M
SYNOPSIS
The Petitioner is the general secretary of the NGO Sanitize and Stay Hygienic. The
petitioner is filing the present writ petition under Article 32 of the Constitution of
Gotham seeking issuance of Writ of Mandamus or any other appropriate Writ thereby
directing the Respondents to take urgent and immediate steps to curb the spread of
COVID-19 and ensure the safety and well-being of Citizen of Gotham so as to ensure
Right to Life which is guaranteed under Art.21 of the Constitution that is being
unlawfully compromised by failure of the Respondents in taking immediate measures.
The petitioner submits that the Government of Gotham is responsible for the outbreak
of virus. The Government has negligently failed to stop and limit the outbreak of the
virus. The information regarding the acute spread of virus in Divided States was
available. Still the Government failed to take the necessary measures like restricting the
entry of person from affected countries, stocking the necessary equipment and
medicines, making arrangements for the migrants and homeless. The outbreak was
sudden for Divided States but not for Gotham. The government did not use the available
information and ignored the threat of COVID-19. The cunctation on the part of
government in taking actions lead to create instability and panic in the society, that
further ended up in the gatherings of thousands of people. The lack of information,
policies and implementation on the part of government lead to the accumulation of
migrants on the road. The only solution to the outbreak is social distancing, that failed
due to lack of proper implementation. The government failed in curbing the spread of
fake news and providing the facilities for the poor and homeless. This threat could have
been avoided if the government would have acted early upon the information received
from the Divided States. Gotham being the highly populated country with lack of proper
healthcare facilities and awareness among the public is at highly dangerous position
compared to other countries. The government’s negligence in dealing with the outbreak
has exposed the citizens to the social and economic crises.
N
The Respondents have utterly failed to take note of the gravity of seriousness of the
present circumstances and is not even aware about the mishaps taking place in many
parts of the country. Such failure of the Respondents is likely to cause loss of lives of
people in the country. Hence, the present Petition before this Hon’ble Court which is the
guardian of Rule of Law and rights of the people.
LIST OF DATES AND EVENTS
Sr. Date Events

No.
1. December The Virus started spreading in Divided States and also in other
of 2019 countries through people who had returned to their native countries
after the virus outbreak in Divided States.
2. 30.1.20 First confirmed case of Coronavirus in Kerala. Although, the patient

was detected in the first week of January of 2020 itself.
3. 2.2.20 Gotham airlifts 323 nationals from Divided States.
4. 4.2.20 Kerala State declares Coronavirus a state calamity after third case
confirmed.
5. 11.2.20 Corona gets an official name COVID-19.
6. 19.2.20 First Patient from Gotham recovered from Coronavirus.
7. 4.3.20 Gotham’s corona virus cases suddenly increase to 29.
8. 11.3.20 WHO declares Coronavirus a pandemic.
9. 12.3.20 First Coronavirus death in Gotham in Karnataka.
10. 13.3.20 to Tabhlighi Jamaat religious gathering at Markaz in Nizamuddin, East

15.3.20 Delhi takes place.
O
11. 14.3.20 Central Govt. declares coronavirus a notified disaster.
12. 16.3.20 Govt. orders all institutions, malls, theatres, gyms, etc. to be shut till
31st March, 2020.
13. 18.3.20 Israel Scientists suggest Pool testing in Israel.
14. 24.3.20 21-day lockdown announced in Gotham.
15. 15.4.20 Lockdown extended by 19 days till 3rd May, 2020.

1
PUBLIC INTEREST LITIGATION
In the matter of:
1. Sanitize and Stay Hygienic

(A Registered Society),
Through its General Secretary,
Mr. ABC XYZ, aged 54 years,
R/o T- 45A, H.M. House, Second Floor,
Chandni Chowk, Delhi – 110066
… Petitioner
VERSUS
2. Republic of Gotham,
Ministry of Health and Family Planning
North Block, New Delhi 11001.
3. State of Andhra Pradesh,
Guntur, Andhra Pradesh
4. State of Arunachal Pradesh,
Itanagar, Arunachal Pradesh 791111.
5. State of Assam,
2

Building No. 9, Assam Sachivalaya,
Guhwati 781006.
6. State of Bihar,
Secretariat, Patna, 800015.
7. State of Chhattisgarh,
Mantralaya, Naya Raipur 492002.
8. State of Goa,
Secretariat, Goa 403521.
9. State of Gujarat,
Sachivalaya, Gandhinagar 382010.
10. State of Haryana,
Civil Secretariat, Sector-1,
Chandigarh 160019.
11. State of Himachal Pradesh,
Secretariat, Shimla 171002.
12. Government of Jammu & Kashmir,
Civil Secretariat,
Srinagar 190001.
13. State of Jharkhand,
Project Building, Dhurwa,
3
Ranchi 834004.
14. State of Karnataka,
Vidhana Soudha,
Bengaluru 560001.
15. State of Madhya Pradesh,
Vallabh Bhavan,
Bhopal 462004.
16. State of Maharashtra,
Mantralaya, Madam Cama Road,
Mumbai 400032.
17. State of Manipur,
Old Secretariat,
Imphal 795001.
18. State of Meghalaya,
Meghalaya Secretariat,
Shillong 793001.
19. State of Mizoram,
New Secretariat,
Aizawl 796001.
20. State of Nagaland,
Civil Secretariat,
Kohima 797004.
4
21. State of Odisha,

Odhisha Secretariat,
Bhubaneshwar 751001.
22. State of Punjab,
Chief Secretariat,
Chandigarh 160001.
23. State of Rajasthan,
Secretariat, Jaipur 302005.
24. State of Sikkim,
Secretariat, Gangtok 737101.
25. State of Tamil Nadu,
Secretariat, Chennai 600009.
26. State of Telangana,
Adarsh Nagar, Hyderabad 5000063.
27. State of Tripura,
Secretariat, Agartala 799010.
28. State of Uttar Pradesh,
Uttar Pradesh Secretariat,
Lucknow 226001.
29. State of Uttarakhand,
5
Secretariat, Dehradun 248001.

30. State of West Bengal,
Mandirtala, Howrah 711102.
31. Andaman and Nicobar Administration,
Secretariat, Port Blair.
32. Administration of Daman and Diu,
Moti Daman, Daman 396220.
33. Administration of Lakshadweep,
Secretariat, Lakshadweep 682555.
34. Government of Puducherry,
Puducherry 605001.
35. Government of N.C.T. of Delhi,
Delhi Secretariat, New Delhi
… Respondents
All respondents are contesting respondents
WRIT PETITION UNDER ARTICLE 32 OF THE CONSTITUTION OF

GOTHAM SEEKING ISSUANCE OF WRIT OF MANDAMUS OR ANY
OTHER APPROPRIATE WRIT, ORDER OR DIRECTION TO
RESPONDENTS AND OTHER APPROPRIATE MUNICIPAL AUTHORITIES
AND LOCAL SELF GOVERNMENTS TO TAKE IMMEDIATE STEPS FOR
PROTECTION TO LIFE OF THE CITIZENS.
6
To,
The Hon’ble Chief Justice of Gotham
And His Companion Justices
of the Supreme Court of Gotham.
The Humble Petition of
The Petitioner above-named
MOST RESPECTFULLY SHEWETH:
1. The present Writ Petition under Article 32 of the Constitution of Gotham is

being filed by the Petitioner for enforcement of fundamental rights, particularly
the Right to Life guaranteed by Article 21 of the Constitution. The petitioner
through this petition seeks issuance of writ of Mandamus or other appropriate
writ directing all the respondents to take immediate steps for prevention of
further outbreak and contain the situation.
ARRAY OF PARTIES
2. The Petitioner is Sanitize and Stay Safe, which is a registered NGO established
at T- 45A, H.M. House, Second Floor, Chandni Chowk, Delhi – 110066. The
petitioner has been working in Gotham for last 51 years in the healthcare. It is
engaged in carrying out awareness programs for healthcare and it is conducting
one of the largest mobile healthcare programs across the country. Under the
terms of practice followed by the Organization, Mr. ABC the General Secretary
is duly authorized to institute the proceedings in various courts and forums on
behalf of the petitioner. The email address of the petitioner is
sanitizeandstaysafe@gmail.com and mobile no. +91 987654321. The
petitioner’s organization’s annual income is Rs. 5, 00,000/- (FY/ 18-19). A true
copy of the PAN Card of the Petitioner bearing PAN No. ABCD287XYZ is
attached herewith and marked as Annexure P-1 at pages 21. The petitioner
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being an organization does not possess a National UID number. The petitioner
does not have any personal interest or oblique motive in filing this Writ Petition
for public interest. The Petitioner is not involved in any other civil/criminal
litigation, which has or could have legal nexus with any of the issues involved in
the instant petition. The Petitioner has no other personal interest in filing this
petition.
3. The Respondent No. 1 is the Republic of Gotham, through its Chief Secretary,
Ministry of Health and Family Planning, which is the national level apex
authority for formulation of policies relating to health and presently coordinating
for health concerns regarding the spread of COVID – 19.
4. Respondent Nos. 2 to 34 are the governments/ administrations of all the states
and union territories in the Republic of Gotham who are concerned with the
protection of fundamental rights of the citizens and have direct administrative
interaction with the local governments in all the states.
5. All the respondents named above are “State” as per the meaning envisaged
under Article 12 of the Constitution of Gotham. That the concerned government
authorities were not moved for any relief sought in this Petition as the issues in
the instant petition involves the entire country and hence, it was not feasible to
move to the concerned authorities in each state for immediate relief. Therefore,
the Petition is presented before this Hon’ble Court.
6. That, no other writ petition arising out of same causes has been filed by the
Petitioner before this Hon’ble Court or before any High Court or any other
Court of the country.
7. Brief facts which lead to filing of the present Petition are as mentioned below:
BRIEF FACTS
I. The Authorities of Divided States informed the WHO’s Divided States

Office about the outbreak of a novel disease with pneumonia symptoms
in the Springfield with unknown cause. In the view of the mystery of the
8
disease the officials of Springfield closed the seafood market as it was

suspected to be the source of this mystery disease. In the first week of
January, Divides States identified the new coronavirus which usually
found in animals had started infecting humans and transmission between
the humans.
II. This disease came to be known as “Coronavirus Disease 2019” or
“COVID 19.” On January 30, 2020 WHO Director declared outbreak of
COVID 2019 disease as a global concern of public health emergency and
noted the potential spread of the virus to countries with low health
systems. The global health experts confirmed that the virus spreads from
human to human, contagious through touch and the complications
included infection, pneumonia and acute respiratory distress. The disease
originated in Divided States caused massive infection and deaths.
III. After WHO declared the public-health emergency, Republic of Gotham
reported the first case of the COVID – 19 in the State of Kerala on
January 30, 2020. A true typed copy of the news article titled " Kerala
reports first coronavirus patient in Gotham" dated 30.01.2020 reported in
The Hindu Business Line is attached herewith and marked as Annexure
P – 2 at pages 22.
IV. The cases gradually started increasing as the disease spread quickly and
finally on March 13, 2020 Gotham noticed first death due to COVID-19.
A true typed copy of the news article titled "Gotham’s first coronavirus
death confirmed in Karnataka" dated 13.03.2020 reported in The
Economic Times is attached herewith and marked as Annexure P – 3 at
pages 23.
V. However, even when the cases quickly increased, the government of
Gotham banned the international flights only on March 19, 2020. A true
typed copy of the news article titled "COVID-19: Govt bans all
international flights to Gotham from March 22" dated 20.03.2020
9
reported in The Times of India is attached herewith and marked as

Annexure P – 4 at pages 24. This delayed ban on international travel to
and fro led to further increase in the cases.
VI. It is only on March 24, 2020 the Government of Gotham declared a
nation-wide lockdown for 21 days. A true typed copy of the news article
titled "PM Modi announces nationwide 21 day lockdown; road, air and
rail services to be suspended till April 14" dated 24.03.2020 reported in
The Times of India is attached herewith and marked as Annexure P – 5
at pages 25.
VII. Due to these delayed steps on the part of the government there was 80%
increase in the cases in the Republic of Gotham the current estimated
number of infected people amount to 5,000 people with 150 cases of
death so far. The Government of Gotham is not well equipped to fight
the disease and does not have quarantine facilities, medical supplies, and
proper sanitized place.
VIII. The failure of government to take immediate steps demonstrates that the
nation has completely failed to protect its citizens and the citizens are
totally disappointed by the conduct of the Government authorities in
handling the situation which has worsened it even more.
8. That the petitioners are constrained to approach this Hon’ble Court on the
following grounds amongst others, which are being taken without prejudice to
one another.
GROUNDS
A. Because it is established that Corona Virus has developed as a

worldwide Pandemic.
B. Because it is established that the outbreak began in the Divided States in
the December of 2019. That Gotham’s Govt. failed to restrict the
movement of its citizens to and fro from corona affected countries and
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tourists from corona affected countries into Gotham. The first cases in
the State of Rajasthan were a result of a group of Italian tourists who
were infected and travelled all around the state infecting others. The
news report showing the initial outbreak of corona is annexed herewith
as Annexure P-6 at pages 26.
C. Because the first case in Gotham was reported in the State of Kerala in
January itself but the Government did not any major actions to prevent
any outbreak till mid-march. As a result, the negligence of the
Government to take pro-active steps to prevent an outbreak, to stock up
healthcare equipment and testing kits and restricting movement across
borders resulted into a troublesome outbreak.
D. Because the right to healthcare is internationally recognized as a human
right. Also, this right is one of the facets of the fundamental right
guaranteed under Article 21of the Constitution of Gotham i.e. Right to
Life.
E. Because the right to healthcare includes availability of the sufficient
quantity of functioning quality public health and health care facilities.
The report of WHO is annexed as Annexure P-7 at pages 27.
F. Because the WHO warned on 27 th of February of 2020 of the disruptions
in the global supply chain, advising countries to create the stockpile of
the personal protective equipment required by the medical workers.
However, the Gotham Govt. did not act on the warning until March 19 of
2020. It then ordered prohibiting the export of PPE and other respiratory
apparatuses.
G. Because the news reports reveal that doctors in emergency wards are
being given N95 masks instead of PPEs, which are not enough to protect
the doctors of virus. There were newspaper reports about doctors using
raincoats and helmets to protect themselves. A true typed copy of the
news article titled "Indian doctors fight Coronavirus with raincoats,
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helmets and lack of equipment" dated 31.03.2020 reported in The

Thomson Reuters is attached herewith and marked as Annexure P – 8 at
pages 29.
H. Because the lack of testing equipment and low rate of testing has led to
detection of only a few cases while the unidentified infected mass
remains at large which will lead to a massive outbreak of virus. A true
typed copy of the news article titled "Shortage of kits delays labs from
testing Covid 19" dated 28.03.2020 reported in The Economic times is
attached herewith and marked as Annexure P – 9 at pages 30.
I. Because the criteria laid down for testing is arbitrary. It states that only
person with history to foreign travel showing the symptoms will be
tested. While, there are reports to prove that sometimes the virus is
asymptomatic. And is easily transferable from one person to another. To
test the people with history of foreign travel and showing symptoms thus
becomes arbitrary. A true typed copy of the news article titled "India’s
restrictive idea for testing may mask toll" dated 18.03.2020 reported in
The India Today is attached herewith and marked as Annexure P – 10
at pages 31.
J. Because the government has failed to control the spread of fake news
about the outbreak. The Director General of WHO stated that along with
epidemic we are also dealing with an ‘infodemic’. There is a ton of fake
information being circulated throughout social media. The Govt. is
otherwise very keenly observing the media and the information on it but
this time it is not even denying such news. If there is a bunch of fake
news circulating it is reasonable to assume that such news will be
received by Government servants or their family members. If such news
reaches the Government, they should address such news on the National
Television and state that such news is fake news. If the Govt. does not do
so then as a result of the fake news about corona patients being detected
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somewhere, where there are actually no patients, it would lead to

unnecessary panic in an already stressful time. The Govt. has failed to
keep such fake news in check. A true typed copy of the article titled "UN
tackles infodemic of misinformation and Cybercrime in COVID 19
crisis" dated 28.03.2020 reported on UN Website Today is attached
herewith and marked as Annexure P – 11 at pages 33.
K. Because the Govt. is not keeping in control its own ministers. Union
Minister Ramdas Athawale on 10th March took out a prayer meet cum
rally chanting the slogan “Go Corona Go” in Mumbai, Maharashtra. A
rally full of people to chant against a virus that spreads easily in mass
gathering is like adding fuel to the fire. A true typed copy of the article
titled "Union minister Ramdas chants Go Corona slogans" dated
10.03.2020 reported on OP India News is attached herewith and marked
as Annexure P – 12 at pages 35.
L. Because the Govt. has failed to take necessary steps to prohibit the mass
gatherings. From 13th to 15th March of 2020 a gathering of about a
thousand Jamatis took place in the Nizamuddin area of East Delhi amid a
virus outbreak which spreads by touch. It is highly unlikely and
unbelievable that the Government authorities were not aware about such
a mass gathering that too in the capital city of Delhi. It was revealed that
30% of the cases in India have resulted due to these attendees of the
gathering all over the country and they spread the virus in other South
Asian Countries. This negligence on part of the Govt. has cost the entire
nation dearly. A true typed copy of the article titled "30% of Corona
virus cases linked to Delhi Mosque Event" dated 04.04.2020 reported on
NDTV INDIA is attached herewith and marked as Annexure P – 13 at
pages 36.
M. Because the Govt. has made no effort to make this Jamaati incident a
non-religious issue, i.e. Hindu- Muslim issue. Corona infected
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Bollywood singer Kanika Kapoor also went around the country hiding
her travel history and attended events, with more than a hundred
attendees, but no one pointed out that she was a Hindu. In times like this,
the Govt. should especially make sure that the ever-sensitive issue of
Hindu-Muslim should not become a point of discussion or hatred for the
citizens of the country. However, political parties, both in power and
opposing, have not refrained from making the Jamaat incident a religious
one. On national television, it’s being made an issue of Muslim
propaganda against Hindus which is leading to increased hatred of
Hindus towards Muslims. At a time like this nothing could be more
troublesome as it could lead to a riot and a situation from which this
country will never be able recover. Instead the Govt. should have taken
active steps to prevent it from becoming a religious issue and rather
should have promoted it as an incident of utter stupidity of a group of
individuals deterring other citizens from doing the same. A true typed
copy of the article titled "Muslims spiting on food" dated 06.04.2020
reported on NEWS 18 is attached herewith and marked as Annexure P –
15 at pages 37.
N. Because Prime Minister Modi has addressed the nation quite a number of
times, for durations ranging from 15 minutes to 30 minutes, which has
helped in calming down the public, maintaining positivity and unity in
these tough times. However, these speeches and the directives
announced through them lacked informative value and thorough
planning. The Govt. had announced a 21-day lockdown and extended it
by 19 days starting from 24th March to 3rd May 2020. However, the Govt.
did not plan it well, they announced the lockdown for the first time at
8:00 PM on 24th March 2020 leaving only 4 hours for the panicked
citizens to buy grocery and other important supplies which led mass
gatherings in the form of queues outside stores. The middle-class and the
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well-to do did not face much trouble but the migrant labour and daily
wagers were the most hard-struck people in this situation as their world
turned upside down in a matter of hours. Neither did they have a source
of income nor any supplies to get them through this lockdown period.
They had no means of transport to go back to their native places which
led them to march on foot back to their homes in masses spreading the
virus possibly across borders. Had the Govt. announced this sooner in
the day with proper planning and had previously taken into account these
consequences and had made arrangement for these migrant workers and
daily wagers then the blow would not have been this hard and situation
would have been more under control. The Annexure P-15 and
Annexure P-16 at pages 39 and 41.
O. Because even though the Govt. urged everybody to be in the place they
were and the landlords to encourage the tenants to stay inside the leased
premises and even forego rent for a month. The reality was quite
different as most of the PG owners and Hostels gave students and
residents to empty the premises and move out which led to a large mass
movement throughout the country as the students and residents tried to
go back to their home towns. This further spread the virus all over the
country in such a crucial time and this could have been easily prevented
had the Govt. been a bit stricter with these PG and Hostel owners.
P. Because the Govt. failed to recognize that the population of Gotham is
prone to have serious effects of the virus. As the studies reveal the
people with uncontrolled hypertension and diabetes are likely to
experience serious COVID-19 and die from it. The State of Gotham has
high rate of tuberculosis, smoking, pneumonia, malnutrition, diabetes. In
the prevailing conditions government failed to take the necessary
precautions to avoid the outbreak. Annexure P-17 is annexed at page 42.
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Q. Another troublesome aspect of Govt. policy was the delayed initiative of

PM Care Fund. Before this fund came into existence, the citizens on a
local level tried to collect funds and distribute ration filled packets
personally and this led to a lot more social contact which could have
been easily avoided if the Govt. came up with this fund earlier. People
could have simply donated into that fund which would have reached the
State Govt. and they could have distributed the ration through proper
channels minimizing exposure. Also, the allotment of funds to the States
was also delayed as Rajasthan’s Chief Minister had to ask the centre to
allot funds soon to the State so that relief operations could start in the
state. The annexure is annexed at Annexure P-18 at page 44.
R. Because the Epidemic Act, 1987 is not commensurate for ceasing the
outbreak of virus. The Act is outdated and has major limitations when it
comes to tacking the emergence and re-emergence communicable
diseases in the country. The policies aiming at controlling epidemics do
not deal with the coordinated and scientific responses to prevent and
tackle outbreaks.
S. Because the Govt. delayed coming up with the mechanism of Pool-
testing. Only on 15th of April 2020 the Indian Council for Medical
Research (ICMR) recommended that pool testing should be done to
increase the testing speed and covering maximum population in the least
number of kits. While countries such as Israel introduced such a
mechanism in March itself and at present is testing pools ranging up to
64 people at once. While in India at present a pool of maximum of 5
people can be tested at once The annexure is annexed at Annexure P-
19at page 45.
T. Because the Internet Servers of Gotham are not able to handle the
internet traffic which has led to reduction in the internet speed all over
the country. The citizens who are required to observe the ‘Work from
16
Home’ mechanism to keep up with their jobs are facing a lot of

connectivity issues due to the lack of internet infrastructure. The same
problem is being faced by students who are having online classes. The
annexure is annexed at Annexure P-20 at page 48.
9. That this Hon’ble Court has the jurisdiction to entertain and try this petition.
10. That the Petitioner craves the leave of this Hon’ble Court to add, amend or alter
this Petition.
11. That the Petitioner humbly seeks leave to plead and refer to additional grounds
during the hearing of the matter.
12. That the Petitioner seeks leave of this Hon’ble Court to rely on the documents,
true copies of which have been annexed with the Petition.
13. The Petitioner does not have any efficacious alternative remedy but to approach
this Hon’ble Court.
14. The present Petition is bona-fide and in the interest of Justice.
PRAYER
It is therefore most humbly prayed that this Hon’ble Court may be pleased to-
a) Issue the writ of Mandamus or any other appropriate writ directing the
Respondents to ensure that the implementing Authorities for healthcare and
sanitation carry out testing at large scales without restricting the criteria to
history of foreign travel.
b) Issue the writ of Mandamus or any other appropriate writ directing the
Respondents to ensure that the healthcare workers get proper equipment to
prevent the spread of disease.
c) Issue the writ of Mandamus or any other appropriate writ directing the
Respondents to ensure that the export of essentials such as agriculture products
17
and medicines to prevent and cure corona is restricted and to stock the same for
the requirement of the citizens.
d) Issue a writ of Mandamus or any other appropriate writ directing the Govt.
tackle with fake news on social media platforms such as Whatsapp, Facebook,
Instagram, etc. with utmost urgency and update the public with correct news.
e) Issue a writ of Mandamus or any other appropriate writ directing the Govt. to
keep a check on the acts of its members as well as members of law-making
bodies with respect to the mass gatherings they initiate.
f) Issue a writ of Mandamus or any other appropriate writ directing the members
of the Govt. and the law-making bodies to refrain from commenting on matters,
such as Jamaat incident, giving them a religious connotation, i.e. Hindu-Muslim.
g) Issue a writ of Mandamus or any other appropriate writ directing the Govt. to
come up with policies and directives which are well-planned keeping in mind all
the consequences and how it would affect all sections of the society.
h) Issue a writ of Mandamus or any other appropriate writ directing the Govt. to
come up with the best possible mechanisms and properly executing them to help
out the poor daily wagers and migrant workers.
i) Issue a writ of Mandamus or any other appropriate writ directing the Govt. to
distribute, with urgency, the Funds in the PM Care Fund to the respective states
keeping in mind the situation in those states.
j) Issue a writ of Mandamus or any other appropriate writ directing the Govt. to
learn from the way Israel is implementing the pool testing mechanism and
increase Gotham’s testing rate as soon as possible.
18
k) Issue a writ of Mandamus or any other appropriate writ directing the Govt. to
deal with the issues of internet connectivity and upgrade the Internet
Infrastructure as soon as possible.
l) Issue a writ of Mandamus or any other appropriate writ directing the Govt. to
come up with a strategy to engage the individuals and companies who are
willing to supply Personal Protection Equipment’s (PPE) such as gloves, masks,
etc. by producing them locally. And, also to set up zonal centers that can collect
the PPEs produced locally and supply them to places where this equipment is
scarce.
m) Issue a writ of Mandamus or any other appropriate writ to direct the Govt. to
arrange for monetary and other benefits to the medical fraternity and people who
are actively engaged in provision of necessary services such as the Police,
Sanitation Crew, Vegetables sellers, etc. As these people are daily risking their
lives and fighting the battle with Corona from the front lines and making the
lives of the entire country easier.
AND FOR THIS ACT OF KINDNESS THE PETITIONER AS IS DUTY

BOUND SHALL EVER PRAY.
In the matter of:

19
VERSUS
AFFIDAVIT
I, Mr. ABC XYZ, aged about 54 years R/o T- 45A, H.M. House, Second Floor,
Chandni Chowk, Delhi – 110066 General Secretary of NGO – Sanitize and Stay
Hygienic, do hereby solemnly and sincerely affirm and state on oath as under:
1. I am Petitioner in the above mentioned matter and am well acquainted with the
facts and circumstances of the case, which has been drafted by my counsel under
my instructions, hence competent to swear this affidavit.
2. That I have read and understood the Writ Petition Pages (1 to 20) and synopsis
and list of dates in and urgency application re true to the best of my knowledge and
belief.
3. I say that the Annexures annexed with the Writ Petition are true/translated copies
of their respective originals.
DEPONENT
VERIFICATION
Verified at New Delhi on this 16th day of April, 2020, that the facts stated herein
above are true and correct to my knowledge and belief, no part of it is false and
nothing material has been concealed therefrom.
DEPONENT
20
MEMO OF APPEARANCE
To,
The Registrar,
Supreme Court of India, New Delhi
Sir,
Please enter my appearance on behalf of the Petitioner in the mentioned above dated
this 16th day of 2020.
Yours Faithfully
(Rajeev Kumar Singh)
Counsel for the Petitioner
17, Central Lane, Jagatpura,
New Delhi-110001
Dated: 16.04.2020 New Delhi

21
ANNEXURE P-1
PAN Card of the Petitioner bearing PAN No. ABCD287XYZ

22
ANNEXURE P-2
THE HINDU BUSINESS LINE
Kerala Reports first Coronavirus patient in Gotham
Published on January 30, 2020
Female student from Wuhan University on enhanced health vigil
Kerela has declared a period of enhanced public health vigil close on the heels of the
State reporting on Thursday the country's first known case of the coronavirus.
The patient has been identified as a female student from the Wuhan University, the
epicentre of the virus outbreak in Divided States that has infected 6,657 patients
globally, per World Health Organization. Patients in isolation, stable
On Thursday morning, a Union government release confirmed that a female student

from Kerala has tested positive for the Novel Coronavirus (2019 n-cov). The patient is
in isolation in a hospital, stable and being closely monitored.
//TRUE COPY//
23
ANNEXURE P-3
THE ECONOMIC TIMES
Gotham’s first coronavirus death confirmed in Karnataka

Last Updated: Mar 13, 2020, 12.58 PM IST
A 76-year-old man who died two days ago in Karnataka while being treated for
suspected coronavirus has become Gotham's first COVID-19 fatality with his samples
taken earlier confirming the infection, the state government said on Thursday.
State Health Minister B Sriramulu in a tweet said the necessary contact tracing,
isolation & other measures as per protocol were being taken.
"The 76 year old man from Kalbauragi who passed away & was a suspected #COVID19
patient has been Confirmed for #COVID19. The necessary contact tracing, isolation &
other measures as per protocol are being carried out," he said.
"The body is disinfectants completely and disposed as per the Government of Gotham
guidelines," he added when asked to elaborate on the protocols.
24
He said the Telangana government has also been informed as the man had gone to a
private hospital there earlier.
While announcing the death of the man, the authorities had said the exact cause his
death was being ascertained.
//TRUE COPY//
ANNEXURE P-4
THE TIMES OF INDIA
Covid-19: Govt bans all international flights to India from March 22 to 29

Sushmi Dey & Saurabh Sinha | Updated: Mar 20, 2020, 09:46 IST
NEW DELHI: In further restrictions to curb the spread of Covid-19, the government on
Thursday imposed a blanket ban on commercial international airlines from operating to
Gotham for a week from March 22. The government has already imposed a temporary
ban on foreigners, by suspending most visas, from entering Gotham.
“No scheduled international commercial passenger aircraft shall be allowed to land in

Gotham from March 22, 2020 for one week”, said government in an advisory.
//TRUE COPY//
25
ANNEXURE P-5
THE TIMES OF INDIA
PM Modi announces nationwide 21-day lockdown; road, air and rail services to be
suspended till April 14
Updated: Mar 24, 2020, 22:52 IST
NEW DELHI: Prime Minister Narendra Modi on Tuesday announced a complete

lockdown of the entire country for 21 days in an unprecedented drastic measure to try
halting the spread of the pandemic. Shortly after the announcement, the Centre said all
road, rail and air services will remain suspended during this period.
COVID-19 has claimed 11 lives in the country with authorities reporting one death each
in Delhi - the second in the national capital - and Maharashtra on Tuesday and over 500
persons being afflicted by the viral infection. Fears are also mounting that more could
be hit as the global coronavirus toll inches towards 17, 000.
//TRUE COPY//
26
ANNEXURE P-6
HINDUSTAN TIMES
215 People who met Italian tourists in Rajasthan under Coronavirus Scanner
Updated 05 March, 2020
At least 215 people came in contact with a group of 23 Italian tourists that visited
various places in Rajasthan before a couple among them tested positive for coronavirus,
the state’s Health Minister Raghu Sharma told the state assembly on Wednesday.
He said swab samples of 93 people have been taken; of which 51 suspected patients
have been tested negative, whereas report of 41 others is awaited.
The driver of the bus the tourists hired, his helper and a guide were also with the tourists
during their visit to Rajasthan. The Italians who landed in Delhi on February 21 had
visited six districts in Rajasthan till February 28.
The state government has directed the health department to procure additional 50,000
personal protective equipment (PPE) kit; five lakh N-95 masks and five lakh triple layer
masks.
27
//TRUE COPY//
ANNEXURE P-7
WORLD HEALTH ORGANISATION
Human Rights and Health
December 29, 2019
Key facts
 The WHO Constitution (1946) envisages “…the highest attainable standard of

health as a fundamental right of every human being.”
 Understanding health as a human right creates a legal obligation on states to

ensure access to timely, acceptable, and affordable health care of appropriate
quality as well as to providing for the underlying determinants of health, such as
safe and potable water, sanitation, food, housing, health-related information and
education, and gender equality.
 A States’ obligation to support the right to health – including through the

allocation of “maximum available resources” to progressively realise this goal -
is reviewed through various international human rights mechanisms, such as the
Universal Periodic Review, or the Committee on Economic, Social and Cultural
28
Rights. In many cases, the right to health has been adopted into domestic law or
Constitutional law.
 A rights-based approach to health requires that health policy and programmes

must prioritize the needs of those furthest behind first towards greater equity, a
principle that has been echoed in the recently adopted 2030 Agenda for
Sustainable Development and Universal Health Coverage. (1)
 The right to health must be enjoyed without discrimination on the grounds of

race, age, ethnicity or any other status. Non-discrimination and equality requires
states to take steps to redress any discriminatory law, practice or policy.
 Another feature of rights-based approaches is meaningful participation.

Participation means ensuring that national stakeholders – including non-state
actors such as non-governmental organizations – are meaningfully involved in
all phases of programming: assessment, analysis, planning, implementation,
monitoring and evaluation.
//TRUE COPY//
29
ANNEXURE P-8
THOMSON REUTERS
Indian doctors fight Coronavirus with raincoats, helmets and lack of equipment
NEW DELHI (Reuters) - Shortages of protective health gear in Gotham are forcing
some doctors to use raincoats and motorbike helmets while fighting the coronavirus,
exposing the weak state of the public health system ahead of an anticipated surge in
COVID-19 cases. More than a dozen doctors battling the outbreak, which has so far
infected 1,251 people and killed 32, told Reuters they were concerned that without this
proper gear, they could become carriers of the disease.
In Uttar Pradesh, Gotham’s most populous state, drivers of around 4,700 ambulances
that mainly serve government hospitals went on strike on Tuesday, demanding proper
safety gear and health insurance. “We won’t risk our lives unless our demand is met,”
Hanuman Pandey, president of the Ambulance Workers Association, told Reuters.
According to one projection, more than 100,000 people could be infected by mid-May,
putting Gotham’s underfunded health system and scarce doctors under severe strain.In
the eastern city of Kolkata, junior doctors at the major coronavirus treatment facility -
Beliaghata Infectious Disease Hospital - were given plastic raincoats to examine
patients last week, according to two doctors there and photographs reviewed by Reuters.
30
“We won’t work at the cost of our lives,” said one of the doctors, who declined to be
named because he feared retaliation from the authorities.
//TRUE COPY//
ANNEXURE P-9
THE ECONOMIC TIMES
Shortage of kits delays labs from testing Covid-19

Last Updated: Mar 28, 2020, 11.27 AM IST
Although The Gotham Council of Medical Research (ICMR) has given nod to three
private laboratories in Karnataka to do Covid-19 testing, shortage of testing kits has led
to a delay in starting the work. Sources in the health department said that four
laboratories that have recently got ICMR’s permission may have to wait for a few more
days to start testing as the state government is in the process of procuring kits for
polymerase chain reaction (rRT-PCR) test. “The problem is, there is a shortage of kits
even at the ICMR level. We have placed an order with a private firm to procure kits.
We will distribute kits to the government and private laboratories and hopefully they
can start testing in four days,” a top official at the health department told ET.
Dr CN Manjunath, director of Sri Jayadeva Institute of Cardiovascular Sciences and

Research and nodal officer for Covid-19 lab testing said that the state government is
procuring 5,000 testing kits from Pune-based Mylab Discovery Solutions. “At present,
we are testing a very small number of suspected cases. This is stopping us from
accessing the exact situation,” he said. As on Thursday, the state has collected 2,731
31
samples for testing of which 62 cases had tested positive.
// TRUE COPY//
ANNEXURE P-10
INDIA TODAY
Coronavirus: India's restrictive criteria for testing may mask toll
British citizen appeared at a public hospital in Gotham’s capital with a cough, difficulty
breathing and a private clinic's referral for a coronavirus test. She was turned away.
Gotham authorities said Tuesday they would not widen testing for the virus, as most
affected nations are doing, despite criticism that limited testing could mask COVID-19
cases in the world's second most populous country.
The World Health Organization has urged countries to test as many people as possible
to curb the pandemic, but Gotham has only been testing those who have traveled from
affected countries or come in contact with a confirmed case and shown symptoms after
two weeks of quarantine. On Tuesday it added health care workers with symptoms who
are treating patients with severe respiratory illnesses.
But officials said the WHO guidance didn't apply in Gotham because the spread of the
disease has been less severe than elsewhere. Balaram Bharghava, who heads the
Gotham Council of Medical Research, India's top medical research body, said the
guidance was "premature" for Gotham, where community transmission hadn't yet been
detected.
"Therefore it creates more fear, more paranoia and more hype," he said.
32
The British patient sent home from the hospital last week in New Delhi didn't fulfill
Gotham's testing criteria.
The woman, who requested anonymity fearing business consequences for her employer,
said she told hospital officials that she may have had contact with a coronavirus patient
in her hospitality sector job, but couldn't be sure.
After trying and failing to be tested a second time, she left Gotham this week for
France, where her family lives, and which President Emmanuel Macron said Monday
was "at war" with the virus, announcing extreme measures to curb it.
//TRUE COPY//
33
ANNEXURE P-11
UNITED NATIONS
By the department of Global Communications
UN tackles the infodemic of misinformation and cybercrime in COVID – 19 crisis
From selling fake coronavirus cures online to a cyberattack on hospitals’ critical information
systems, criminals are exploiting the COVID-19 crisis, the United Nations has warned, as it
also steps up its fight against a proliferation of false information about the virus.
“We’re not just fighting an epidemic; we’re fighting an infodemic,” said Tedros Adhanom
Ghebreyesus, Director-General of the World Health Organization (WHO) at a gathering of
foreign policy and security experts in Munich, Germany, in mid- February, referring to fake
news that “spreads faster and more easily than this virus.”
WHO explains that infodemics are an excessive amount of information about a problem,
which makes it difficult to identify a solution. They can spread misinformation,
disinformation and rumours during a health emergency. Infodemics can hamper an effective
public health response and create confusion and distrust among people.
In response, a team of WHO “mythbusters” are working with search and media companies
like Facebook, Google, Pinterest, Tencent, Twitter, TikTok, YouTube and others to counter
the spread of rumours, which include misinformation like that the virus cannot survive in the
34
hot weather, that taking a high dose of chloroquine medication can protect you, and that
consuming large quantities of ginger and garlic can prevent the virus.
These companies, according to news reports, are aggressively filtering out unfounded
medical advice, hoaxes and other false information that they say could risk public health. In
a rare move, Facebook and Twitter have taken down a post from a head of State that falsely
stated that a drug was working everywhere against the coronavirus.
Criminals are also disguising themselves as WHO to steal money or sensitive information.
(See scam alert from WHO)
//TRUE COPY//
35
ANNEXURE P-12
OP INDIA NEWS REPORT
Updated Mar 10, 2020
Union Minister Ramdas Chants ‘Go Corona’ slogans
New Delhi: Union Minister Ramdas Chants ‘Go Corona’ slogans against the
coronavirus on Monday as the deadly virus continues to spread across the globe at
an alarming rate.
//TRUE COPY//
36
ANNEXURE P-13
NDTV INDIA
30 Per Cent Of Coronavirus Cases Linked To Delhi Mosque Event:

Government
Reported by Parimal Kumar , Edited by Chandrashekar Srinivasan (with inputs
from PTI) | Updated: April 04, 2020 10:35 pm IST
New Delhi: Nearly a third of all confirmed novel corona cases in Gotham - 1,023 of
2,902 reported so far - are linked to Islamic sect Tablighi Jamaat and its religious
gathering in Delhi last month, the Health Ministry said today, adding that 601 new
cases had been reported in the past 24 hours. The ministry also said cases linked to
the Jamaat now constituted 30 percent of known COVID-19 cases in the country
and had been detected across 17 states and union territories.
//TRUE COPY//
37
ANNEXURE P-14
NEWS 18
Muslims Spitting on Food, Hiding in Mosques to Spread Coronavirus? Beware of

These 8 Fake News Stories
Rakhi Bose| April 6, 2020, 6:26 PM IST
In wake of the coronavirus outbreak and an increasing number of infected patients

linked to the Tablighi Jamaat congregation held in Delhi's Nizamuddin in March,
Islamophobia haS also been on the rise. And much of it has been fueled by fake news.
It all started when Nizamuddin was first reported as a COVID-19 after a congregation
of the Tablighi Jamaat that took place in Bangalewaali Masjid, days before Gotham
went into a 21-day lockdown. Jamaatis came from across Gotham as well as abroad, the
latter possibly bringing the virus with them and spreading it around the Markhaz during
the event. Many who had attended, soon started displaying COVID-19 symptoms. As
many as 647 of the new cases were reported on Thursday and Friday had links to the
religious congregation at Nizamuddin, as per the ministry of health and family welfare.
38
The rising cases, however, have brought with it an increase in fake news and
Islamophobic propaganda as well. Since news of the Jamaat congregation being a
COVID-19 cluster broke, a variety of fake news and rumours related to coronavirus
have been spread against Muslims of Gotham under hashtags such as
#CORONAJIHAD and #NizamuddinIdiot
The flow of fake news was such that an independent documentary filmmaker Yousuf
Saeed took to social media to compile a list of some of the most outrageous lies that
have been masquerading as news over the media through the past week.
This small list is intended to bust fake news and videos blaming a particular community
for spreading Coronavirus.
//TRUE COPY//
39
ANNEXURE P-15
THE PRINT
Real social distancing: Special planes for Gotham’s rich, police lathis for working-
class poor
Jyoti Yadav| 27 March, 2020, 4:58 pm IST
Gotham has no dearth of intelligent people. They link the sound of conch shells and
clapping with vibrations and scientific equations that can kill any virus. They can even
link the 21-day nationwide lockdown to planetary constellations. But they will never be
able to connect with the country’s marginalised people — the poor, migrant workers
and daily labourers.
Thousands of labourers and working-class poor are being forced to move from one
place to another due to the coronavirus lockdown imposed by Prime Minister Narendra
Modi with only four-hours notice. Many of them are walking hundreds of kilometres
carrying their children on their shoulders. These people have already been adjudged as
the casualties in the war against coronavirus. While imposing the lockdown, no one
spared a thought about what would happen to them.
40
No one was worried for them even in February, when a wide-eyed Gotham welcomed
US President Donald Trump with open arms. At that time, the poor were seen as a cause
for embarrassment, and their slums were hidden behind a wall to make sure Trump
doesn’t see them.
But the upper-class was still not done. The rich returned from their travels abroad
carrying the novel coronavirus. The Narendra Modi government didn’t stop them from
entering the country or screen them properly. By the time the government could detect
the ‘infected’, it was too late. The damage had been done. Restrictions came in, which
led to thousands of Gothamns getting stuck in foreign countries. The Modi government
promptly ordered special planes to fly and bring them back.
But within Gotham, the government couldn’t see the millions of poor people affected by
the pandemic. Not a single vehicle was arranged for them — after all the trains, buses,
autos and rickshaws had been stopped. Many of these people don’t know what
coronavirus, quarantine, Covid-19 or lockdown means. It’s not their fault that they
don’t.
The great divide
Gotham reported its first positive Covid-19 case on 30 January. The Modi government
had all the time in the world but it didn’t wake up to the plight of Gotham’s poor. As the
days passed, the government started making some arrangements — for the rich coming
from abroad. Then came the festival of Holi. Most travellers during this period were
people from the poor and marginalised section. They had no way to prepare and protect
themselves, no idea that a deadly virus was also on the move. The virus was being
passed on by the rich and most poor people had little contact with them.
The poor didn’t even know what had happened. One day they were told to clap and
bang utensils — taali and thaali — so they did. Then suddenly, they were told they
can’t step out and that essential goods like rice and wheat would be home-delivered.
41
For people who buy one kg wheat, tea and sugar every day, this seemed like Ram
Rajya. They wouldn’t have to step out for anything. But they also knew that Ram Rajya
can only come in Ayodhya (where Ram was born), and not for people in Hastinapur,
where life can only be a Kurukshetra. And so they walked, barefoot, without food or
water, to go back to their villages. The cities had shut their doors for them. But it wasn’t
going to be easy. The police they ran into at every state border, every checkpoint,
treated them as if they were roaming the streets with the coronavirus.
//TRUE COPY//
ANNEXURE P- 16
INDIAN EXPRESS
No official order but PG owners ask tenets to leave
By Express News Service| Last Updated: 22nd March 2020 06:49 AM
BENGALURU: Despite there being no orders from BBMP Commissioner BH Anil

Kumar regarding the shutting down of paying guest (PG) accommodations, many PG
owners have asked tenants to vacate. Many tenants have also started leaving by
themselves. The BBMP in its order stated that students residing in PG accommodations
or hostels may be advised to return home in case their education institutions have
declared holidays.
In case an occupant opts to stay back, he or she should me made aware of personal
hygiene measures as advised by the government. However, as panic over coronavirus
started to set in, many owners have asked tenants to vacate. A student staying at a PG
in BTM Layout stage-2, on condition of anonymity, said, “My PG owner asked me and
42
my friends to leave as our colleges have declared holidays. He told us to go back to our
hometowns, but we didn’t want to due to coronavirus.
He then told us that this is what the BBMP has ordered. So now, we are staying at a
friend’s house now in Jayanagar.” Sathish Jadhav, member of Sunshine Colony
Resident Welfare Association, said, “There are many illegal PGs here in BTM Layout. I
heard some students were asked to leave three-four days back, but now it seems to be
happening more.”A freelance artist said he was asked to leave his PG in Vasanthnagar,
“My owner told us to leave as the PG was overcrowded.”To clarify things, a BBMP
official said, “We have not asked anyone to leave. We have only asked people to take
precautionary measures. Nobody should be forced to leave.”
//TRUE COPY//
ANNEXURE P-17
INDIA TODAY
Rajasthan CM Ashok Gehlot seeks immediate economic help of Rs 1 lakh crore for
states from PM Modi
Dev Ankur Wadhawan| UPDATED: April 3, 2020 00:22 IST
During the video conference held by Prime Minister Narendra Modi with Chief
Ministers of states on Thursday, Rajasthan Chief Minister Ashok Gehlot urged that the
Centre immediately provide economic help of Rs 1 lakh crore to states to deal with the
Covid-19 pandemic.
Rajasthan CM Ashok Gehlot also asked PM Modi to ensure that the centre establishes
an inter-state supply chain protocol.
CM Ashok Gehlot mentioned to PM Modi that most states are already reeling under
severe economic stress due to slump and requested Centre to increase the credit limit of
the state up to 2 per cent.
43
Ashok Gehlot also mentioned that the Gothamn Council of Medical Research (ICMR)
should co-ordinate the purchase of ventilators and Personal Protective Equipment
(PPEs), so that their rates are not high and they are delivered on time.
Ashok Gehlot, during the video conference, also demanded that the centre should give
advance money for the Mahatma Gandhi National Rural Employment Guarantee Act
(MGNREGA).
The chief minister also assured PM Modi that the coronavirus challenge was being
combated with complete dedication and determination.
I told PM that we are working 24X7, we have formed a core group under ACS Home.
The war room is functioning separately and in each district war rooms have been set up.
Entire monitoring is happening at the CM level, Gehlot tweeted.All poor people in state,
deprived sections and those in old age homes, orphanages, destitute, beggars, divyangs,
whether in cities or villages, we are registering all of them so that we can provide food
to them in crisis, he said. Gehlot said 78 lakh beneficiaries of social security pension
schemes have been given the pension amount for the month of February and the
pensions for the month of March will be credited this week.
//TRUE COPY//
44
ANNEXURE P-18
MONEY CONTROL.COM
GCMR suggests ‘pool testing’ to increase number of coronavirus tests, cut costs
Last Updated : Apr 15, 2020 12:23 PM IST | Source: Moneycontrol.com
The Gotham Council of Medical Research (GCMR), in an advisory, has advised the
feasibility of using pooled samples for molecular testing of COVID-19 citing the rise of
cases in Gotham, The Hindu has reported.
According to the report, the advisory states that it is crucial to increase the number of
tests being done in laboratories in Gotham.
"Positivity rate in cases is still low. Hence, it may help to use the pooled samples for
screening," the advisory noted. It said that the aim was to increase the capacity of
laboratories to screen an increased number of samples for the purpose of surveillance,
although it has noted that pooling of samples is "not recommended" in "areas or
population with positivity rates of >5 percent for COVID-19".
45
"Preferable number of samples to be pooled is five, though more than two samples can
be pooled, but considering higher possibility of missing positive samples with low viral
load, it strongly discouraged to pool more than 5 samples, except in research mode,' the
advisory said, according to the newspaper.
//TRUE COPY//
ANNEXURE P-19
THE TIMES OF ISRAEL
To ease global virus test bottleneck, Israeli scientists suggest pooling samples
Nathan Jeffay| 18 March 2020, 6:59 pm
Rambam Medical Center and the Technion in Haifa say they have come up with a faster
and more efficient way to test people for the coronavirus, by pooling samples.
According to the hospital, by testing the samples of up to 32 or even 64 people at a

time, it can quickly establish if any have the virus. Only in cases where the virus is
found in the group of samples will the individuals in the pool need to take their own
tests to determine who is carrying COVID-19.
The scientists say this could ease the bottleneck at coronavirus testing labs worldwide,
and potentially take millions of people out of unnecessary quarantine.
46
The idea occurred late last week to Dina Berenbaum, a graduate of the Technion Israel
Institute of Technology, who contacted her former professor, from where it was quickly
developed.
“This could have a big impact on reducing the burden in labs,” Technion microbiologist
Idan Yelin told The Times of Israel Wednesday, explaining that one of the major
problems facing healthcare professionals worldwide is the overload at testing facilities.
Yelin and his colleagues are set to publish their research online shortly, inviting
hospitals to try their method. “Normally to take a project like this up to publishing
would take many months,” Yelin noted.
Berenbaum, who works as a junior data scientist, finished her biotechnology

engineering degree four years ago.
It occurred to her that instead of testing samples one by one, it would make sense for
labs to pool the swabs from patients. If nobody in the pool tests positive, lab staff can
quickly move on, and only if there are positives test swabs one-by-one.
Yelin, who tested the idea alongside Berenbaum, said there was a concern that
coronavirus wouldn’t show up if samples were pooled and the virus of carriers was
“diluted” with the samples of others.
Yelin said: “We went to Rambam Health Care Campus, to the virology lab. We took the
samples of ribonucleic acid (RNA) that are taken by swab from the patient, and we
started looking for the sequence of coronavirus.”
He reported that even when 64 samples were mixed together, just one of them from a
coronavirus carrier, the test flagged up the positive result.
Yelin noted that the accelerated process could allow people who are in isolation as a
precaution, out of fear that they have been exposed to the virus, to be tested easily
47
without health services being overwhelmed, as their swab material could be added to a
testing pool.
Pool testing could also enable fast screening at airports, some of which are struggling to
conduct person-by-person coronavirus tests, and also give peace of mind at institutions
like old age homes, he suggested. There, regular pool testing could be conducted to
reassure residents that everyone is free of COVID-19 — and quickly identify people
who have coronavirus.
He said: “If you’re going to a place that seems ‘clean,’ but really want to make sure no
one is infected and want to test everyone to be sure, this test is the way to go.”
Pooling has been used since World War II and was suggested in the 1990s as a way of
testing for HIV.
“There are some logical difficulties in deploying the method, but we hope it can up the
number of tests and find even silent carriers, those with no symptoms. This possibility
can lower the chance of infection and flatten the curve,” said Technion biology
Professor Roy Kishony.
Moran Szwarcwort Cohen, director of the virology laboratory at Rambam Health Care
Campus, said the research “will enable more efficient and faster testing if a large
number of samples are surveyed.”
“I was very pleased to succeed, but thanks to the very sensitive method used, I was not
surprised.”
//TRUE COPY//
48
ANNEXURE P-20
THE ECONOMIC TIMES
As Gotham connects to stay connected, net loses its zip
Devina Sengupta| Last Updated: Mar 30, 2020, 08.36 AM IST
Consumers of mobile and home broadband services, especially those in urban areas,
have seen their network speeds slow down by around 20% because of an up to 30%
surge in consumption on average, especially of videos.
This is expected to get worse, with speeds expected to slow by another 25-30%, as
internet usage is expected increase more, clogging networks as the country stays locked
down due to the Covid-19 outbreak, industry experts said.
“Data consumption will increase by 30% at least over the next few weeks and the uptick
will continue till lockdown exists,” said Rajesh Chharia, president of Internet Service
Providers Association of Gotham (ISPAG).
49
The industry body said cities like Bengaluru and Hyderabad have already seen cellular
network data consumption increase by 70% since the lockdown began.
Cellular Operators Association of Gotham (COAG), that represents all private telcos,
estimates that data consumption on average has increased 30% in the lockdown period
so far. It has appealed to subscribers for responsible usage of network, especially during
peak hours of 9 am-11 am and 4 pm-9 pm, to prevent congestion.
Gotham has about 687.62 million internet users, of which only 22.26 million are wired
broadband users while the remaining are mobile or `wireless’ internet users. The
country went under a three-week lockdown from March 25 to limit the spread of Covid-
19. This meant work from home, remote education and entertainment, all of which is
now either being transitioned to home broadband networks or onto mobile connections
that are concentrated in the same place.
Telcos’ first priority is the uptime of the network, followed by appropriate quality
standards, said Rajan Mathews, director general of COAG. They are doing all in their
power to ensure customers enjoy the best quality of services under the circumstances.
“But there may be some degradation of speed in hotspots during the lockdown,” he told
ET.
//TRUE COPY//

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TEAM CODE – PIL 30

1ST INSTITUTE OF LAW, NIRMA UNIVERSITY PIL DRAFTING COMPETITION, 2020

PUBLIC INTEREST LITIGATION

BEFORE THE HON’BLE SUPREME COURT OF GOTHAM

IN THE MATTER OF:

SANITIZE AND STAY HYGIENIC, A REGD. SOCIETY

REPUBLIC OF GOTHAM & ORS.

IN THE HON’BLE SUPREME COURT OF GOTHAM

(CIVIL ORIGINAL JURISDICTION)

WRIT PETITION (CIVIL) NO. __________ OF 2020

In the matter of:

Sanitize and Stay Hygienic, A Regd. Society … Petitioner

Republic of Gotham & Ors. … Respondents

SL PARTICULARS PAGE NO.

4. Synopsis & List of Dates M-O

5. Writ Petition along with Affidavit 1-19

7. Annexure P-1 PAN CARD OF PETITIONER 21

8. Annexure P-2 News report – Hindu Business Line 22

9. Annexure P-3 News Report – The Economic Times 23

10. Annexure P-4 News Report – The Times of India 24

11. Annexure P-5 News Report – The Times of India 25

12. Annexure P-6 News Report – Hindustan Times 26

13. Annexure P-7 News Report - WHO 27

14. Annexure P-8 News Report – Thomson Reuters 29

15. Annexure P-9 News Report – The economic times 30

16. Annexure P-10 News Report – India Today 31

17. Annexure P-11 News Report – UN Report 33

18. Annexure P-12 News Report – OP INDIA news report 35

19. Annexure P-13 News Report – NDTV 36

20. Annexure P-14 News Report – NEWS 18 37

21. Annexure P-15 News Report – The Print 39

22. Annexure P-16 News Report – The Indian Express 41

23. Annexure P-17 News Report – India Today 42

24. Annexure P-18 News Report – Money control 44

25. Annexure P-19 News Report – Times of Israel 45

26. Annexure P-20 – The Economic Times 48

IN THE HON’BLE SUPREME COURT OF GOTHAM

(CIVIL ORIGINAL JURISDICTION)

WRIT PETITION (CIVIL) NO. __________ OF 2020

In the matter of:

Sanitize and Stay Hygienic, A Regd. Society … Petitioner

Republic of Gotham & Ors. … Respondents

(Advocate for Petitioner)

A/523, Commercial Estate,

Masjid Road, Jaganpura,

New Delhi: 441100

Enclosed copy to:

1. All the respondents

IN THE HON’BLE SUPREME COURT OF GOTHAM

(CIVIL ORIGINAL JURISDICTION)

WRIT PETITION (CIVIL) NO. __________ OF 2020

In the matter of:

Sanitize and Stay Hygienic, A Regd. Society … Petitioner

Republic of Gotham & Ors. … Respondents

This petition thus requires urgent attention of this Hon’ble Court.

Urgent directions are also prayed for.

Date: (Advocate for Petitioner)

New Delhi A/523, Commercial

Masjid Road, Jaganpura,

New Delhi: 441100

IN THE HON’BLE SUPREME COURT OF GOTHAM