007R

IN THE

HON’BLE SUPREME COURT OF NIRVANA

AT RAHMANPUR

IN THE MATTER OF

WRIT PETITION NO. 2345/2021

ELLIOT ANDERSON (REPRESENTED BY HIMSELF) ………………………………

PETITIONER

V.

STATE OF RANISTHAN (REPRESENTED BY THE GOVERNOR OF

RANISTHAN) .....RESPONDENT

[UNDER ARTICLE 32(1) OF THE CONSTITUTION OF NIRVANA READ WITH ORDER XXXVIII,

RULE I AND VII OF THE SUPREME COURT RULES,2013]

Clubbed with

CIVIL APPEAL NO. 4997/2021

JASON COTTON TEXTILE MILLS (REPRESENTED BY THE MANAGING DIRECTOR, JASON

COTTON TEXTILE MILLS) ………………………………………………………APPELLANT

V.

PRACTERS AGROS TRADERS (REPRESENTED BY THE CHIEF EXECUTIVE OFFICER,

PRACTERS AGROS TRADERS)

…………………………………………………....RESPONDENT
[UNDER ARTICLE 139(A) OF THE CONSTITUTION OF NIRVANA READ WITH ORDER XL, RULE

V OF THE SUPREME COURT RULES,2013]

[THE ABOVE-MENTIONED MATTERS HAVE BEEN CLUBBED UNDER ARTICLE 142, OF THE

CONSTITUTION OF NIRVANA, READ WITH ORDER LV, RULE III OF THE SUPREME COURT

RULES,2013]

ON BEHALF OF THE RESPONDENTS

 TABLE OF CONTENTS

INDEX OF AUTHORITIES.....................................................................................................iv

STATEMENT OF FACTS........................................................................................................v

STATEMENT OF JURISDICTION........................................................................................vii

ISSUES FOR CONSIDERATION.........................................................................................viii

SUMMARY OF ARGUMENTS..............................................................................................ix

ARGUMENTS ADVANCED.................................................................................................10

I. The Ranisthan SOP does not violate the Fundamental right to equality enshrined under

constitution of Nirvana,1950................................................................................................10

A. The Classification made under Ranisthan SOP is reasonable in nature and is of

intelligible differentia.......................................................................................................11

B. The classification made by the Ranisthan SOP has a nexus with its objective.....13

II. The Ranisthan SOP does not violate the Fundamental right to Life and Liberty

enshrined under The Constitution of Nirvana,1950.............................................................14

A. The restriction has been imposed under procedure established by law......................14

B. The Ranisthan SOP in some aspects strengthens the right to life..............................16

III. There is no discharge of the previous contract by novation and there is a breach of

the contract as well...............................................................................................................17

A. There exists no new contract between the two parties...........................................17

B. Breach of contract on the part of JCT....................................................................19

PRAYER FOR RELEIF...........................................................................................................21

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 INDEX OF AUTHORITIES

INDIAN CASES

A.K. Gopalan v. Government of India, (1966) 2 SCR 427 : AIR 1966 SC 816....................15

Bandhua Mukti Morcha v. Union of India, (1984) 3 SCC 161 : 1984 SCC (L&S) 389......17

Bhagwandas Goverdhandas Kedia v. Girdharilal Parshottamdas & Co., (1966) 1 SCR

656 : AIR 1966 SC 543........................................................................................................19

Indrajit Barua v. State of Assam, AIR 1983 Del 513.............................................................16

Jhandoo Mal-Jagan Nath v. Phul Chand-Fateh Chand, AIR 1925 Lah 217......................20

Kartar Singh v. State of Punjab, (1994) 3 SCC 569 : 1994 SCC (Cri) 899...........................15

Ram Krishna Dalmia v. Justice S.R. Tendolkar, 1959 SCR 279 : AIR 1958 SC 538..........10

Union of India v. M.V. Valliappan, (1999) 6 SCC 259..........................................................13

STATUTES

The Indian Contract Act, 1872...............................................................................................18

TREATISES

Dr Avtar Singh, Contract and Specific Relief..................................................................19, 20

M.P Jain, Indian Constitutional Law (8th Edition),...............................................................15

CONSTITUTIONAL PROVISIONS

Article 21, Constitution of Nirvana,1950...............................................................................15

Article 47, Constitution of Nirvana,1950...............................................................................13

FOREIGN CASES

Associated Provincial Picture Houses Ltd. v Wednesbury Corporation [1948] 1 KB 223.10

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v
 STATEMENT OF FACTS

 ELLIOT ANDERSON v. STATE OF RANISTHAN

The country of Nirvana and the world had been ravaged by the covid pandemic forcing

schools and colleges to shut down. The disease was without a cure, but the scientists of

Nirvana with their hard work developed the Nirvaxin- Nirvana’s first covid vaccine.

Subsequently, mass vaccination campaigns were organized around the country and with a

drop in the number of cases and keeping in mind the need of the students, the State of

Ranisthan on advice of the education ministry framed guidelines for reopening of schools and

colleges. Under these guidelines vaccinated students were allowed to attend college classes

offline whereas unvaccinated students were not allowed to do so.

Moreover, an exception for students allergic to the vaccine’s ingredients was also carved out

and they were allowed to attend classes offline. These guidelines were framed accordingly, so

that another uptick in covid cases could be prevented but students misunderstood it as a form

of arbitrary discrimination and filed a writ petition in the honourable supreme court.

 JASON COTTON TEXTILE MILLS v. PRACTERS AGROS TRADERS

Jason Cotton Textile Mills (JCT) and Practers Agros Traders (PAT) had entered into a

contract for the sale of 800 bales of cotton (each containing 40 bundles of 10lbs) wherein

JCT was the seller and PAT was the buyer.

JCT due to various reasons of their own had realized that they would not be able to

perform the contract and intimated it to PAT on 30 th of November saying that

performance on their part would be impossible. Subsequently, JCT themselves thought of

an alternative compensation scheme which was out of the purview of the agreed upon

contract and sent it to PAT.

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PAT did not want to accept these terms because of the higher prices and a later delivery

date and decided to not reply. JCT incorrectly presumed it to be an indication of

acquiescence and when PAT moved court following which the district court ordered

payment of damages to PAT, JCT appealed against the order in the high court of

Ranisthan believing that there existed a valid and enforceable contract consisting of the

new terms they had communicated to PAT.

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 STATEMENT OF JURISDICTION

The respondents most humbly submit that this Hon’ble Supreme Court of Nirvana has

jurisdiction to hear and adjudicate upon the matters of:

 WRIT PETITION NO. 2345/2021 filed under Article 32(1) of the Constitution of

Nirvana read with Order XXXVIII, rule I and VII of the Supreme Court Rules,2013.

 CIVIL APPEAL NO. 4997/2021 filed under Article 139(A) of the constitution of

Nirvana read with order XL, rule V of the Supreme Court Rules,2013.

The above-mentioned matters have been clubbed under Article 142, of the

constitution of Nirvana, read with Order LV, Rule III of the Supreme Court

Rules,2013

All of which is urged in detail in the written submission and submitted most

respectfully.

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 ISSUES FOR CONSIDERATION

I. IS THE “RANISTHAN STANDARD OPERATING PROCEDURE FOR RE-OPENING

COLLEGE / UNIVERSITIES AND HOSTELS” (RANISTHAN SOP) VIOLATIVE OF RIGHT

TO EQUALITY GUARANTEED UNDER THE CONSTITUTION OF NIRVANA, 1950?

II. IS THE RANISTHAN SOP VIOLATIVE OF FUNDAMENTAL RIGHT TO LIFE AND

LIBERTY GUARANTEED UNDER THE CONSTITUTION OF NIRVANA, 1950?

III. IS THERE A DISCHARGE OF THE CONTRACT ENTERED INTO BY JCT AND PAT BY

WAY OF NOVATION OR IS THERE A BREACH OF THE SAID CONTRACT?

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 SUMMARY OF ARGUMENTS

I. THE RANISTHAN SOP DOES NOT VIOLATE THE FUNDAMENTAL RIGHT TO

EQUALITY ENSHRINED UNDER CONSTITUTION OF NIRVANA,1950.

 The differentiation made under the Ranisthan SOP is reasonable

and well within the limits of the constitution of Nirvana and has a

reasonable nexus with its goal of containing the spread of

COVID-19.

II. THE RANISTHAN SOP DOES NOT VIOLATE THE FUNDAMENTAL RIGHT TO LIFE AND

LIBERTY ENSHRINED UNDER CONSTITUTION OF NIRVANA,1950

 The Ranisthan SOP is in interest of the general public and furthers

the cause of public health by making some reasonable

classifications. Moreover, it strengthens the students’ rights to life

and personal liberty by allowing them to study in a safe

environment and study from the safety of their homes online if

they have any inhibitions or an incapability to get vaccinated.

III. THERE IS NO DISCHARGE OF THE PREVIOUS CONTRACT BY NOVATION AND THERE

IS A BREACH OF THE CONTRACT AS WELL.

 The earlier contract had not been fulfilled and the absence of a

reply cannot be thought of as an acceptance to the new terms.

Additionally, the new terms were outside the purview of the

earlier contract and PAT was not bound to accept any of the terms

proposed by JCT and had full right to ask for the performance of

the older contract or sue for its breach.

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 ARGUMENTS ADVANCED

I. THE RANISTHAN SOP DOES NOT VIOLATE THE FUNDAMENTAL RIGHT TO

EQUALITY ENSHRINED UNDER CONSTITUTION OF NIRVANA,1950.

The differentiation between students who are vaccinated and those who are not vaccinated

has been considered to be violative of article 14 of the constitution of Nirvana but with a

simple perusal of the various judgements given by the hon’ble Supreme Court of India one

can easily infer that

“It is now well established that while article 14 forbids class legislation, it does not forbid

reasonable classification for the purposes of legislation. In order, however, to pass the test of

permissible classification two conditions must be fulfilled, namely, (i) that the classification

must be founded on an intelligible differentia which distinguishes persons or things that are

grouped together from others left out of the group, and (ii) that that differentia must have a

rational relation to the object sought to be achieved by the statute in question.” (1)

The classification made by the government stands on both the requirements and is [A]based

on an intelligible differentia and [B] forms a nexus with the goal it sets out to achieve. The

classification is well warranted and proportionate in consideration of the circumstances at

hand while manifesting no arbitrariness and also finds support in the doctrine of

proportionality developed in the Wednesbury case. (2)

Therefore, on the basis of these

arguments it can be considered that the rule is well within the limits of the constitution and

does not infringe upon the right to equality.

(1) Ram Krishna Dalmia v. Justice S.R. Tendolkar, 1959 SCR 279 : AIR 1958 SC 538
(2) Associated Provincial Picture Houses Ltd. v Wednesbury Corporation [1948] 1
KB 223

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 A. THE CLASSIFICATION MADE UNDER RANISTHAN SOP IS REASONABLE IN NATURE AND IS OF

INTELLIGIBLE DIFFERENTIA

In the Ranisthan SOP the government has classified students into three categories, them being

the ones who are vaccinated, ones who are not vaccinated and not allergic to Nirvaxin and the

last category being of those who are not vaccinated but are allergic to the ingredients of the

vaccine.

The persons coming under the first and the third category have been allowed to attend

classes in colleges in an offline mode whereas persons falling under the second category have

been restricted to the online model of pedagogy while instructing colleges and universities to

make sure that such a facility is available for the said students.

This indeed is based on an intelligible differentia and therefore reasonable as [i] the

vaccination of a person affects his chances of death if infected by the coronavirus.

Additionally, [ii] persons who are allergic to the ingredients of Nirvaxin are at a risk of dying

if inoculated with the said vaccine according to reports by the Nirvana council of medical

research (NCMR). These significant differences between the above-mentioned individuals

forms the bedrock of the classification employed by the state in the impugned act.

(i) The vaccination affects the chances of an inoculated person dying from the

novel coronavirus

The NCMR has in its reports stated that “vaccination was 100% effective in preventing the

death of the individual” (3) These reports signify that a person not inoculated with the vaccine

is prone to death and hence points towards a significant difference between those not

inoculated and those who are inoculated.

(3) Proposition, at ¶3

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 The difference stated herein is grave and threatening in matters of life. Sending a non-

inoculated person to the offline mode would be similar to sending a soldier to a

battleground with a machete even when he can very effectively handle a gun.

(ii) Persons allergic to the ingredients of the vaccine are susceptible to death if

inoculated.

The NCMR has in its reports stated “There were vaccine-related deaths where the person

had medical contraindications, i.e., if someone is allergic to an ingredient in the vaccine.

Therefore, herd immunity, through significant coverage of the vaccine, must be attained to

protect the unvaccinated.” (4)

Therefore, it can be concluded that a person allergic to the ingredients of this vaccine can in

no state, without risk of death, be inoculated with the vaccine and such an imposition of

vaccination cannot be therefore imposed on them.

Further it must be noted that such an individual stands to benefit from the interaction with

other vaccinated individuals as through herd immunity the unvaccinated can also be protected

from the virus.

In continuation of the analogy mentioned above, an individual who is allergic to the

ingredients of the vaccine may be equated to a warrior unacquainted with a gun so much so

that the presence of a gun in his hands may prove to be an endangerment to his own life and

limb. It therefore seems prudent for him to be sent with a machete hoping that he at least is

able to defend himself and possibly is able to even inflict damage on the enemy without

endangering himself.

(4) Proposition, at ¶3

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 B. THE CLASSIFICATION MADE BY THE RANISTHAN SOP HAS A NEXUS WITH ITS OBJECTIVE

The Ranisthan SOP has the objective of ensuring that more and more students are able to

attend classes offline while ensuring that there is no uptick in the number of coronavirus

cases due to the reopening of colleges.

“It is settled law that differentiation is not always discriminatory. If there is a rational nexus

on the basis of which differentiation has been made with the object sought to be achieved by

particular provision, then such differentiation is not discriminatory and does not violate the

principles of Article 14 of the Constitution.” (5)

There is a reasonable nexus as (i)Vaccination brings herd immunity and reduces deaths and

(ii) the classification prevents the exposure of unvaccinated individuals to the virus.

(i) Vaccination brings herd immunity while eliminating any chances of death

As earlier stated, vaccination is very effective in eliminating chances of death from the

coronavirus, a disease due to which about 5 lakh people in Nirvana have already lost their

lives. The herd immunity which it brings would help the unvaccinated individuals protect

themselves and also may with some probability, although not proved by any conclusive

evidence, make the persons immune to the coronavirus. This represents the fact that the

classification is well woven with its objective of preventing an uptick in coronavirus cases

and improving public health.

(ii) The classification prevents exposure to the virus for unvaccinated students

The directive principles of state policy state that “The State shall regard the raising of the

level of nutrition and the standard of living of its people and the improvement of public

health

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 (5) Union of India v. M.V. Valliappan, (1999) 6 SCC 259 at pg. 269

as among its primary duties” (6)

The classification of students helps in the reduction of the congregation of a larger number of

people by allowing unvaccinated individuals to study from the security of their homes. It also

saves them for the possibility of death and infection altogether while encouraging them to get

vaccinated with a motivation for them; being able to attend classes offline.

These reasons represent why the classification has a reasonable nexus with it objective of

improving public health and reducing the number of cases of the coronavirus.

II. THE RANISTHAN SOP DOES NOT VIOLATE THE FUNDAMENTAL RIGHT TO LIFE

AND LIBERTY ENSHRINED UNDER THE CONSTITUTION OF NIRVANA,1950

The classification of students on the basis of vaccination is said to be violative of their right

to life and personal liberty but that does not hold true as it is [A] done within procedure

established by law. Moreover, [B]in some aspects it even strengthens their right to personal

life and liberty. Due to these conditions being fulfilled the Ranisthan SOP does not infringe

upon the right to life and liberty enshrined under the Nirvanian constitution.

A. THE RESTRICTION HAS BEEN IMPOSED UNDER PROCEDURE ESTABLISHED BY LAW

The restriction on the ability of students to attend classes is well warranted and(i) imposed

under provisions of “THE RANISTHAN EPIDEMIC DISEASES ACT, 2020”. (ii) The

Ranisthan epidemic diseases act, 2020 in itself is a reasonable act and therefore any powers

delegated towards making rules conferred by it are also within the limits of the constitution.

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 (6) Article 47, Constitution of Nirvana,1950
(i) Restrictions imposed under “THE RANISTHAN EPIDEMIC

DISEASES ACT, 2020”

The Ranisthan SOP has been brought under the provisions of Ranisthan epidemic diseases

act, 2020. The said act provides that “The Government may, by notification in the Official

Gazette, make rules either prospectively or retrospectively for the purpose of carrying into

effect the provisions of this Act.” (7) Hence the guidelines are procedure established by law.

The constitution of Nirvana says that “No person shall be deprived of his life or personal

liberty except according to procedure established by law.” (8) The Supreme court of India

ruled in Gopalan (9) that in article 21, if there was a law stating a procedure and the procedure

mentioned was followed by the executive while depriving the individual of his life and liberty

then whether the law was fair or reasonable, or according to natural justice or not was not the

concern of the court. (10)

If the law was to be judged through this lens, then it may be suitably inferred that the

impugned restriction by virtue of it being a procedure established by law is not in violation of

the right to liberty and freedom enshrined under the constitution of Nirvana,1950.

(ii) Ranisthan SOP is a fair procedure established by law.

An alternative understanding opposed to the one cited above has been stated by the courts in

India when judging the procedure of law mentioned in article 21. In a leading case the

supreme court had stated that “The procedure contemplated by Article 21 is that the

procedure must be “right, just and fair” and not arbitrary, fanciful or oppressive.” (11) 

(7) Proposition, Annexure A at § 15

(8) Article 21, Constitution of Nirvana,1950
(9) A.K. Gopalan v. Government of India, (1966) 2 SCR 427 : AIR 1966 SC 816

16
 (10) M.P Jain, Indian Constitutional Law (8 th Edition), Chapter XXVI at pg.
1162
(11) Kartar Singh v. State of Punjab, (1994) 3 SCC 569 : 1994 SCC (Cri) 899 at
pg. 671
The Ranisthan SOP stands on that yard stick as well. It can be further justified by the

stand taken by the high court of Delhi who had in a case laid out what was fair under

article 21 and had said

  “If to save hundreds lives one life is put in peril or as Das, J. expounded or B.K. Mukherjee,

J. put it, if a law ensures and protects the greater social interest than such law will be a

wholesome and beneficial law although it may infringe the liberty of some individuals: it will

ensure for the liberty of the greater number of the members of the society at the cost of one

and a few. In any organised society, claiming to be civilised and governed by the rule of law,

social imperatives for the greater good must take precedence over individual rights” (12)

The Ranisthan SOP does infringe on the liberty of some students but does this to further

the goal of public health and the classification made is in public interest. It can be

therefore concluded that the classification done is a procedure established by law and that

procedure is itself justified, making this distinction not violative of the student’s right to

life and personal liberty in any circumstance.

B. THE RANISTHAN SOP IN SOME ASPECTS STRENGTHENS THE RIGHT TO LIFE

The Ranisthan SOP has been accused of infringing on the right to life and personal liberty but

the strides it makes in guaranteeing a right to health to the students has been ignored by the

petitioners.

“Article 21 derives its life breath from the Directive Principles of State Policy and

particularly clauses (e) and (f) of Article 39 and Articles 41 and 42 and at the least,

therefore, it must include protection of the health and strength of workers, men and

17
 women, and of the tender age of children against abuse, opportunities and facilities for

children to develop in a healthy manner and in conditions of freedom and dignity,

(12) Indrajit Barua v. State of Assam, AIR 1983 Del 513.

educational facilities, just and humane conditions of work and maternity relief.” (13)  

The Ranisthan SOP strives to improve public health and also provides the students a

chance to attend the classes from their homes if they are unvaccinated so that they are not

compulsorily exposed to the virus.

The SOP strengthen the right to life and in no way weakens it thereby, proving that it is in

no way violative of article 21.

III. THERE IS NO DISCHARGE OF THE PREVIOUS CONTRACT BY NOVATION AND

THERE IS A BREACH OF THE CONTRACT AS WELL.

The JCT claims that the contract had been discharged by novation. JCT comes to this

conclusion by assuming incorrectly that PAT had agreed to the contract by not replying to the

proposal communicated by JCT. These claims do not have any metal and [A] there exists no

new contract between the two parties. Additionally, [B] JCT is also liable for the breach of its

earlier contract. Keeping these arguments in mind the petition filed in the hon’ble Supreme

court should be laid to rest by upholding the decision given by the district court at Pallapura.

A. THERE EXISTS NO NEW CONTRACT BETWEEN THE TWO PARTIES

The first contract signed between JCT and PAT is the only one which existed and no new

contract exists between parties. No new contract exists because (i) PAT was not bound to

accept the new terms proposed by JCT and (ii)PAT had in no way expressed its acceptance of

them.

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 (13) Bandhua Mukti Morcha v. Union of India, (1984) 3 SCC 161 : 1984 SCC
(L&S) 389  at page 183
(i) PAT was not bound to accept the new terms proposed by JCT

The new terms proposed by JCT in the proposal were not under the purview of the earlier

contract meaning that the terms were not binding on PAT and they were under no obligation

to accept the new terms.

Clause 3.1 of the agreement between both the parties reads as follows:

“The buyer agrees to purchase the following goods & accept the seller’s proposition to

deliver the goods between the first and last day of the above-mentioned month and to pay the

full value for the same by September, 2020 and to accept the goods if any reasonable delay is

made for a reason intimated to the buyer by the seller.” (14)

Here the contract specifies that the buyer would be bound to accept the goods if there is a

reasonable delay, whereas in the case at hand there is a non-performance in entirety as JCT

has intimated their inability to perform the contract in time and the terms proposed are totally

new having no relevant antecedent to the previous contract.

This makes it clear that there is no obligation on PAT to accept the new terms.

(ii) The JCT’s interpretation of PAT’s silence as acceptance is problematic

PAT had stayed silent and did not reply to the notice of repudiation or to the new terms

proposed by JCT, but interpretation of this silence as acceptance is an invalid argument.

Section 2(b) defines acceptance as the following:

“When the person to whom the proposal is made signifies his assent thereto, the proposal is

said to be accepted. A proposal, when accepted, becomes a promise.” (15)

19
 (14) Proposition, at ¶15, cl. 3.1
(15) The Indian Contract Act, 1872 at §2, cl. (b)

The definition clearly requires that the assent should be signified or expressed by an act or

omission by which the party accepting intends to communicate his assent or has the effect of

communicating it. (16)

The Supreme court of India in 1966 had held that:

“The offeror cannot impose upon the offeree an obligation to accept, nor proclaim that

silence of the offeree shall be deemed consent. A contract being the result of an offer made by

one party and acceptance of that very offer by the other, acceptance of the offer and

intimation of acceptance by some external manifestation which the law regards as sufficient

is necessary.”(17)

PAT not replying to the terms was in no way a form of acceptance. In the case cited above

the hon’ble court has explicitly mentioned that an offeror can never proclaim the silence of

the offeree as deemed consent. This presents a circumstance wherein there was no acceptance

to the proposal hence negating the possibility of formation of any contract.

Without the existence of an obligation to accept and the absence of any acceptance to the

proposal it can be in a satisfiable manner concluded that there exists no new contract between

PAT and JCT based on the proposals communicated to PAT by JCT.

B. BREACH OF CONTRACT ON THE PART OF JCT

JCT has refused performance of the contract with PAT and there is a breach on its part.

Having established that no new contract existed for its discharge by novation, it can be

20
concluded that there is a breach of the contract and PAT had all the right to sue JCT for its

breach.

(16) Dr Avtar Singh, Contract and Specific Relief ,Acceptance at pg. 24

(17) Bhagwandas Goverdhandas Kedia v. Girdharilal Parshottamdas & Co.,
(1966) 1 SCR 656 : AIR 1966 SC 543, at ¶4

The appellants may argue that JCT had notified PAT of their inability to perform the contract

much before the filing of the suit or the date of delivery. But this cannot be held in the

circumstances at hand here. The Lahore High court in 1925 (18) held that “The promisee, if he

pleases, may treat the notice of intention as inoperative, and await the time when the

contract is to be executed, and then hold the other party responsible for all the consequences

of non-performance;” (19)

Therefore, the breach of contract by JCT does give PAT the right to sue JCT for the breach

when the arguments stated above are taken into consideration. In the end it can be concluded,

that there was a breach of the contract and PAT was well within their rights to sue JCT for a

breach of contract.

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(18) Jhandoo Mal-Jagan Nath v. Phul Chand-Fateh Chand, AIR 1925 Lah 217
(19) Dr Avtar Singh, supra, Discharge by Breach, at pg. 452-453

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 PRAYER FOR RELEIF

Wherefore in the light of facts stated, issues raised, authorities cited and arguments advanced,

it is most humbly and respectfully prayed that this Honourable Court may be pleased to:

 Uphold the validity and compatibility of Ranisthan Standard

Operating Procedure for re-opening College / Universities and

Hostels, with the constitution.

 Uphold the decision given by the district court at Pallapura and

declare any further compensation to be given to the respondents if

the court deems it fit.

And further pass any other order in favour of the Respondents, as this Court may so deem fit

in the ends of equity, justice and good conscience.

Date: 20 November, 2021. Counsel no. 007R

Place: Rahmanpur,Nirvana (Counsel for the Respondents)

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