Moot Proposition

Bhim & Others …... Petitioners

vs.
State of Goktal and Others …... Respondent 

1. The Republic of Indraprastha, (RI) is a country, located in the South of Asia. It is one of the most
ancient civilizations in the world. The majority of the population of the country belongs to the Zoro
religion. Locaz, Jingas, Winz, are the other religions followed by the people of Republic of
Indraprastha. The Republic of Indraprastha (is characterized by a diversity of religious beliefs and
practices, attires, cultural outlook, languages, food-habits etc) is unique for its multicultural character.
RI was ruled by foreign invaders and ultimately secured its independence from colonial rule in 1947
leading to a sovereign country and became a republic with its own written Constitution.
2. Today the Republic of Indraprastha is a democratic country with a written Constitution which came
into force in 1950. It has 29 States and 7 Union Territories. The Constitution has adopted a
Parliamentary system wherein the President is the executive Head of the government. There is a
federal form of Government.
3. Throughout Indraprastha’s history, Zoro religion has been part and parcel of the country’s tradition
and culture. Majority of the population are followers of Zoro religion. The Republic of Indraprastha
has witnessed several instances of religious disharmony between various religious denominations and
groups. The Zoro Religion is based on a wide variety of customs and rituals and Mandirs are their
place of worship. Zoro believers contributed to the betterment of the Mandirs and the multiple Gods
they worship. Many Mandirs were constructed by the rulers of the erstwhile princely states and the
previous sovereigns. Many properties were bestowed in the form of gift called "danam" on the
mandirs for the purpose of their upkeep and the conduct of daily rituals and for specific religious
activities by the Sovereigns.
In course of time, the administration and management of a few of the said Mandirs and their
properties and endowments were allegedly deteriorated and a situation had arisen rendering it
expedient to reorganize, in the interests of the general public, the scheme of Management of the affairs
of the Mandir.
In some states of Indraprastha, the Mandirs are managed by private trusts and private persons while in
others the State governments constitute Mandir Boards to manage the affairs, including appointments
and management of funds related to the Mandirs. 
4. The State of Goktal situated in the Eastern region is the second most populous state of the Republic of
Indraprastha. All places of worship, except Zoro Mandirs in the state are managed by the community
heads of the respective faiths, based on lineage, nomination, or by their own elected leaders. The Zoro
Mandir at Goktal was a very ancient Mandir of unique importance which owns extensive properties
and endowments and in which millions of devotees from all over Indraprastha repose their faith and
belief. Goktal Zoro Mandir was a hub of many cultural activities and social development, with
pilgrim rest houses, cow shelters and community halls.
5. The Goktal Mandir Board Act, 1978 was enacted to provide better management and administration of
the Mandir in supersession of the then existing scheme. Goktal Mandir Board includes Chairman,
Vice Chairman and other members appointed by the State Government. The Board consisted of
members nominated by the State Government. Most of the rich Mandirs in the state of Goktal are
managed by the Goktal Mandir Board with elected members nominated by the State Government.
There are also some private mandirs were managed by private people/trusts/ Shebait as per the
traditions and customary practices. It is the Mandir Board that appoints priests, workers, managers of
the Mandirs. 
6. The government of State of Goktal on a secularism agenda decided to do away with superstitions and
supposedly irrational customs of the Zoro people. There were several changes brought in the function
of Mandir Board by this Government which annoyed the Zoros at large. At the same time the State
Government did not interfere at all in the religious affairs or beliefs of any other religious groups.
7. Locaz are the declared minority in the Republic of Indraprastha. Locaz Endowment Board was
established for each state of Indraprastha including the state Goktal. The Locaz Endowment Board
(LEB) is a charitable trust that manages and oversees property of Locaz that have been donated for use
by the poor. The Govt constituted a committee headed by Mr. Jojo for the Minorities Commission.
The Commission report by Mr. Jojo, the State Secretary, Goktal Minorities Commission, submitted
the report stating that the LEB had allowed almost 40% of its land to be misappropriated by politicians
and board members, in collusion with the real estate mafia for a fraction of its market value. It was
also alleged that 7,000 acres of such land controlled by the Goktal Locaz Endowment Board (LEB)
had either been misappropriated or allocated illegally. The report has recommended that the
government establish a committee to investigate corrupt activities on the Locaz Endowment Board
and appoint a task force to recover properties that have been illegally sold by the Locaz Endowment
Board.
8. There were complaints that the revenue authority in some parts of Goktal asked the public to bring
NOC from LEB for property transfer. The mainstream media reported that a huge area of land in
Denran district of Goktal is shown in revenue records as that belonging to the LEB. The report
suggested that in connivance with the authorities of LEB, a large amount of property was alienated in
 dubious ways to individual persons on the basis of which the LEB Chairperson immediately made the
statement that any registration of such property be carried out with NOC of LeB. This came to light
only when Mr. Alen, a resident of Denran District, tried to get a housing loan for his property. When
he was about to register the memorandum of document (MOD) for a piece of land at the sub-registrar
office in Denran, for a bank loan, the officials said the property belonged to LEB and the transaction
can be carried out only after getting a No-Objection Certificate (NOC) from the Goktal LEB.
9. Then, the Minorities Welfare Department of the Goktal State issued Government order (GO) that has
instructed the Inspector-General of Registration to not register documents alienating LEB properties
based on No-Objection Certificates of the Chairman of LEB. The state government said they are not
intending to interfere in any property issues of Minority community. Mr. Alen preferred a writ petition
before the High Court of Goktal contending that the G.O. is arbitrary and unconstitutional.
10. In Goktal, a law was passed to provide pension and other benefits to Locaz Community teachers. They
required no qualification and taught only religious ideologies. The Act was called Goktal Locaz
Teachers Welfare Fund Act, 2019. The head of Winz religion of Indraprastha had made an appeal to
extend the benefits of this law to all Minority religions of Indraprastha. A petition was filed before the
High court of Goktal, by Mr.Jai , Secretary of Citizen Organisation for Democracy, Equality,
Tranquility and Secularism, seeking to quash the Act, which is passed for disbursing pension and
other benefits to only to Locaz teachers. The petitioner contended that the pumping of huge amounts
of public money for the said purposes is unconstitutional and against the principles of secularism
enshrined in the Constitution.
11. Meanwhile, a great flood occurred in the state of Goktal, hundreds of people were reported dead and
there was large-scale loss and destruction of property. The State Government of Goktal constituted a
Chief Minister’s Disaster Relief Fund (CMDRF) to pool donations for rebuilding the infrastructure
and rehabilitation. Chief Minister’s Distress Relief Fund is an emergency assistance release
mechanism providing immediate relief to families and individuals distressed by calamity, loss of life
due to accidents and chronic diseases. There were several donations from individuals and bodies
corporate to this fund. The Goktal Mandir Board (CMB) decided to contribute Rs. 10 crores to the
CMDRF from the offerings made to the Zoro Mandir, Goktal. In this background, many allegations
were raised against the Goktal Mandir Board citing abuse of power and the violation of equality. It
was felt that Zoros were treated differently since other religious institutions were not compelled to
contribute any funds to the CMDRF. A writ petition was filed before the Goktal High Court by Zoro
United Front, a Zoro nationalist organisation in the state of Goktal through its leader which claimed
that the Goktal Mandir board had no right to donate the money that was submitted as offerings to the
Zoro Mandir by its believers.
12. Several debates at academic, intellectual and political forums, highlighted the unequal and favourable
treatment of the Goktal Government to the Locaz. A citizen, Bhim from Goktal filed a writ petition
before the Supreme Court of Indrapratha challenging the discriminatory interferences by the
successive State Government in the affairs of Zoros and Locaz.

All the writ petitions were clubbed together by the Supreme Court and referred to the Constitution
bench.
Points to be considered by the Supreme Court:
1. Whether it is necessary to abolish the Mandir Boards in the State of Goktal? 
2. Whether the contribution of Rs. 10 crores to Goktal CMDRF is constitutionally valid?
3. Whether the need for NOC from LEB is unconstitutional?
4. Whether the Goktal Locaz Teachers Welfare Fund Act, 2019 is violative of Art. 14 of the
Constitution?
Note: The laws and culture of Indraprastha are in pari materia with the laws and culture of India.