Memorial for Respondent

TEAM CODE: SIM 03

SANDIP UNIVERSITY INTRA MOOT COURT COMPETITION, 2023

MEMORIAL FROM SIDE OF RESPONDENT

Before

THE HON’BLE SUPREME COURT OF INDUS

SPECIAL LEAVE PETITION

(UNDER ARTICLE 136 OF CONSTITUTION OF INDUS)

IN THE MATTER OF

ALIZA FIRDOS & ORS. …PETITIONER

Vs.

UNION OF INDUS …RESPONDENT

ON THE SUBMISSION OF THE HON’BLE COURT MEMORIAL FILED ON THE

BEHALF OF THE RESPONDENT

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 Memorial for Respondent

TABLE OF CONTENTS

1)……………………………………………… LIST OF ABBREVIATIONS

2)……………………………………………… INDEX OF AUTHORITIES

3)……………………………………………… BOOKS AND WEBSITES REFERRED

4)……………………………………………… STATEMENT OF JURISDICTION

5)……………………………………………… STATEMENT OF FACTS

6)……………………………………………… STATEMENT OF ISSUES RAISED

7)……………………………………………… SUMMARY OF ARGUMENTS

8)……………………………………………… PLEADINGS/ARGUMENTS ADVANCED

9)……………………………………………… PRAYER

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 Memorial for Respondent

LIST OF ABBREVIATIONS

• AIR - All India Reporter

• & - And

• Art. – Article

• CBSE – Central Board of Secondary Education

• Govt. – Government

• HC – High Court

• Hon’ble – Honourable

• IJP – Indus Janta Party

• ICP – Indus Congress Party

• ISP – Indus Samaj Party

• KER – Kerala High Court

• M.P. – Madhya Pradesh

• Ors. – Others

• SC – Supreme Court

• SCC – Supreme Court Cases

• SCR – Supreme Court Records

• Sec. – Section

• SLP – Special Leave Petition

• U.P. – Uttar Pradesh

• Vs. – Versus

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 Memorial for Respondent

INDEX OF AUTHORITIES

CASE LAWS CITATION PAGE NO.

1. Dinesh Kumar Goel Vs. Sushil AIR 2001 SC 1579 14

Kumar Modi

2. M. L. Sethi Vs. R. P. Kapur AIR 1967 SC 1827 14

3. Ajmer Vs. Syed Hussain Ali AIR 1952 SC 10 16

4. Sri Venkataramana Devaru Vs. AIR 1958 SC 255 16

State of Mysore.

5. Sardar Syedna Taher Saifuddin AIR 1962 SC 853 16 & 21

Saheb Vs. State of Bombay

6. D.A.V. College Trust and (2017) 8 SCC 636 18

Management Society Vs.

Director of Public Instruction

7. Ahmedabad St. Xavier's College AIR 1975 SC 2139 19

Society Vs. State of Gujarat

8. S. Mahendran Vs. State of AIR 1990 SC 1480 19

Karnataka

9. Chandmal Chopra Vs. State of AIR 1959 RAJ 467 20

Rajasthan

10. M. Siddiq Vs. Mahant Suresh (2019) 8 SCC 716 21

Das

11. Commissioner of Police Vs. AIR 1984 SC 512 21

Acharya Jagadishwarananda

Avadhuta

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STATUTES REFERRED:

• Constitution of Indus, 1950

• Karnata Education Act, 1983

BOOKS REFERRED:

• P.M. BAKSHI, THE CONSTITUTION OF INDIA (Thirteenth Edition, LexisNexis

Butterworth Wadhwa, 2015);

• DR. MAMTA RAO, CONSTITUTIONAL LAW (First Edition, Eastern Book

Company, Lucknow, 2013);

• DR. J. N. PANDEY, CONSTITUTIONAL LAW OF INDIA (Fifty Fourth Edition,

Central Law Agency, Allahabad, 2017)

WEBSITES REFERRED:

• www.livelaw.in

• www.scconline.com

• www.manupatrafast.com

• www.lexisnexis.com

• www.indiankanoon.org

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 Memorial for Respondent

STATEMENT OF JURISDICTION

THE PETITONER HAS FILED A SPECIAL LEAVE PETITION & HUMBLY

APPROACHES THE HON’BLE SUPREME COURT UNDER THE ART. 136.

This Special Leave Petition has been filed by Aliza Firdos against the judgment and order

of the Hon’ble High Court of Karnata, which was passed in Aliza Firdos & Ors. Vs. State

of Karanata

The present case involves a question of law of general importance and therefore this

Hon'ble Court has the jurisdiction to hear and decide this matter under Article 136 of the

Constitution of Indus.

There is no challenge to the jurisdiction of this Hon'ble Court, either by the petitioner or

any other party to the case.

The petitioner has raised several issues in the present petition, including the violation of

the Fundamental rights and religious sentiments. However, none of these issues affect the

jurisdiction of this Hon'ble Court to hear and decide the case.

Accordingly, it is respectfully submitted that this Hon'ble Court has the jurisdiction to

hear and decide the present Special Leave Petition

The respondent further undertakes to pay all costs and abide by all orders of this Hon'ble

Court

Place: Indus Counsels for the respondent

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 Memorial for Respondent

STATEMENT OF FACTS

1. The state of Karnata is an exceptional state within Indus, with a higher literacy rate and

per capita income compared to the rest of the country, which demonstrates its

significant contribution to the nation's GDP.

2. The Constitution of Indus guarantees fundamental rights to both citizens and non-

citizens, making it a living document that adapts to the country's changing needs.

3. Indus values its diverse, multicultural, and multi-religious identity, and provides

freedom of religion to all its people, including non-citizens. The state's non-interference

policy in religious matters demonstrates its commitment to preserving and protecting

communities with a distinct culture, language, or script.

4. The Parliament of Indus introduced the 106th Constitutional Amendment Bill, 2020,

which gave states the right to propose seceding from the Union, thus maintaining the

principles of democracy and self-determination.

5. The state of Karnata is unique in its religious makeup, with a significant population

practicing the Ibrahimi religion. Due to this, conflicts of interest between the state and

central government can arise, especially since the regional party ISP holds a majority

in the state government while the IJP holds power at the national level.

6. A private school in Karnata banned girls from the Ibrahimi religion from entering the

school while wearing a Hijab, which led to student protests against such discriminatory

policies.

7. The State Government of Karnata issued a notification under the Karnata Education

Act, 1983, stating that students who do not follow the prescribed uniform, including

wearing a Hijab, would not be allowed to attend classes.

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8. The notification led to protests and communal tension among the people of Karnata,

with some arguing that wearing a Hijab is their cultural and religious right protected

under Article 19(1) and Article 25 of the Constitution of Indus.

9. The petitioners contended that wearing Hijab is an essential religious practice of their

religion, Ibrahimi, based on the Quran and Hadith, and that what one wears and how

one dresses is a matter of individual choice and privacy.

10. The petitioners further argued that the State Government's action in prohibiting the

Hijab without exploring alternative solutions violates the Doctrine of Proportionality.

11. The High Court of Karnata held that the State Government's notification is valid and

falls under reasonable restrictions of fundamental rights. The court also stated that

wearing Hijab is not an essential religious practice of Ibrahimi religion but a cultural

right.

12. A group of young advocates from the Indus Young Lawyers Association approached

the President of Indus, arguing that the 106th Constitutional Amendment Act, 2022,

allowing for the right to secede from the Union, is against the Constitution's objectives.

The President transferred the dispute to the Supreme Court of Indus for adjudication

under Article 143 of the Constitution of Indus.

13. The President's rule was imposed in the State of Karnata due to the pernicious protest.

The people of Karnata were unanimously protesting and making a demand that they

didn't want unreasonable restrictions on the right to freedom of religion. Meanwhile,

President's rule imposed in the State of Karnata, the former Deputy Chief Minister of

Kaloshia named, Akhandanand Tripathi, filed a writ petition before the Supreme Court

of Indus stating that the Act of the Central Government was arbitrary.

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14. Additionally, other students have filed a Special Leave Petition (SLP) before the

Supreme Court of Indus. All the petitions have been accepted by the Honourable Apex

Court of Indus for hearing.

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ISSUES RAISED

1. WHETHER THE PRESENT SPECIAL LEAVE PETITION FILED BY THE

PETITIONER IS MAINTAINABLE

2. WHETHER WEARING OF HIJAB IS AN ESSENTIAL RELIGIOUS

PRACTICE OF IBRAHIMI RELIGION

3. WHETHER DISALLOWING WEARING OF HIJAB WITHIN THE COLLEGE

VIOLATES FREEDOM OF RELIGION OF THE IBRAHIMI GIRLS

4. WHETHER THE RESTRICTIONS IMPOSED BY THE NOTIFICATION

UNDER SECTION 133(2) OF THE KARNATA EDUCATION ACT, 1983 ARE

REASONABLE

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 Memorial for Respondent

SUMMARY OF ARGUMENTS

1. WHETHER THE PRESENT SPECIAL LEAVE PETITION FILED BY THE

PETITIONER IS MAINTAINABLE

It is humbly submitted before the court that the Special Leave Petition filed by the Petitioner

is not maintainable before the hon’ble Supreme court as there is no form of substantial question

of law is involved or gross injustice has been done. The order passed by the High Court of

Karnata is fully constitutional declaring that uniform code must be followed by all the students

regardless of the community and their identity as stated in Aliza Firdos & Ors. Vs. State of

Karanata.

2. WHETHER WEARING OF HIJAB IS AN ESSENTIAL RELIGIOUS PRACTICE

OF IBRAHIMI RELIGION

The wearing of hijabs/headscarves by Ibrahimi women does not constitutes the essential

religious practice As for an act to be essential religious practice it should follow several

indicia that have been laid down by the Supreme Court in various cases precedent to the

current case. The act of covering of their head by Ibrahimi women is not mandatory as it is

not even mentioned in the Holy Quran. Something that is recommendatory in the Holy Quran

cannot be metamorphosed into a mandatory religious practice.

3. WHETHER DISALLOWING WEARING OF HIJAB WITHIN THE COLLEGE

VIOLATES FUNDAMENTAL RIGHTS OF THE IBRAHIMI GIRLS?

Prohibition of wearing Hijab in schools and colleges is a reasonable restriction on the

fundamental rights of individuals, as it is necessary to maintain the uniformity of the dress

code within educational institutions. The State Government has the power to make such laws

under the Karnata Education Act, 1983, and that wearing a Hijab is not an essential religious

practice in the Ibrahimi religion.

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4. WHETHER THE RESTRICTIONS IMPOSED BY THE NOTIFICATION UNDER

SECTION 133(2) OF THE KARNATA EDUCATION ACT, 1983 ARE

REASONABLE?

Hijab is not an essential religious practice of Ibrahimi religion and thus the notification under

Section 133(2) of the Karnata Education Act, 1983 is a reasonable restriction on the freedom

of speech and expression and the right to practice any religion freely, granted by Articles

19(1) and 25 of the Constitution of Indus.

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 Memorial for Respondent

ARGUMENTS ADVANCED

WHETHER THE PRESENT SPECIAL LEAVE PETITION FILED BY THE

PETITIONER IS MAINTAINABLE

1. It is humbly submitted that the present Special Leave Petition filed by the Petitioner

before the Hon'ble Supreme Court is not maintainable as there is no substantial

question of law involved or gross injustice has been done. The High Court of Karnata

passed an order declaring that a uniform code must be followed by all students,

regardless of their community or identity, as stated in Aliza Firdos & Ors. Vs. State

of Karanata.

2. The notification issued by the State Government of Karnata, under Section 133 2 of

the Karnata Education Act, 1983, is constitutionally valid as it falls under reasonable

restrictions of respective fundamental rights. The High Court of Karnata rightly

observed that wearing Hijab is not an essential religious practice of Ibrahimi religion

but a cultural right. The State Government's action of prohibiting the Hijab within the

campus is proportionate to the objective of maintaining a uniform code for all

students.

3. Although the Constitution of Indus grants the right to preserve and protect

communities with a distinct culture, language, or script, it also provides freedom of

religion to its citizens and non-citizens. However, this freedom is subject to

reasonable restrictions in the interest of public order, morality, and health. The State

Government's notification aims to maintain discipline and uniformity among all

students, irrespective of their religious beliefs. Therefore, the right to freedom of

religion cannot be claimed as an absolute right to wear any religious attire in schools

or colleges.

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 Memorial for Respondent

4. The High Court of Karnata's order is based on the precedent set in Aliza Firdos &

Ors. Vs. State of Karanata, where the court upheld the constitutionality of the

notification prohibiting the Hijab within the campus. The court observed that wearing

Hijab is not an essential religious practice but a cultural right, and the State

Government's notification aims to maintain uniformity and discipline among all

students. Therefore, this precedent should be followed by the Hon'ble Supreme Court,

and the High Court's order should be upheld.

5. In the case of Dinesh Kumar Goel Vs. Sushil Kumar Modi, the Supreme Court held

that the Special Leave Petition was not maintainable as the High Court had already

disposed of the matter and the Special Leave Petition was not maintainable.

6. In the case of M. L. Sethi Vs. R. P. Kapur1, the Supreme Court held that an SLP

cannot be maintained against an interlocutory order passed by a High Court, unless

the High Court certifies that the case involves a substantial question of law of general

importance.

7. The High Court of Karnata's order is constitutionally valid, and the State

Government's notification prohibiting the Hijab within the campus is proportionate to

the objective of maintaining discipline and uniformity among all students. The right to

freedom of religion is subject to reasonable restrictions in the interest of public order,

morality, and health, and the High Court's order upholding the notification should be

followed by the Hon'ble Supreme Court.

1
M. L. Sethi Vs. R. P. Kapur AIR 1967 SC 1827

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WHETHER WEARING OF HIJAB IS AN ESSENTIAL RELIGIOUS PRACTICE OF

IBRAHIMI RELIGION

8. It is humbly submitted to the Hon’ble Supreme court that the wearing of

hijabs/headscarves by Ibrahimi women is not an essential religious practice as per the

guidelines laid down by the Supreme Court in various cases. For an act to be

considered an essential religious practice, it must fulfill certain indicia:

9. Not every activity associated with the religion is essential to such religion. Practice

should be fundamental to religion and it should be from the time immemorial.

10. Foundation of the practice must precede the religion itself or should be co-founded at

the origin of the religion.

11. Such practice must form the cornerstone of religion itself. If that practice is not

observed or followed, it would result in the change of religion itself and,

a. Such practice must be binding nature of the religion itself and it must be

compelling. That a practice claimed to be essential to the religion has been

carried on since time immemorial or is grounded in religious texts per se does

not lend to it the constitutional protection unless it passes the test of

essentiality as is adjudged by the Courts in their role as the guardians of the

Constitution.

12. The act of covering the head by Ibrahimi women is not mandatory, as it is not even

mentioned in the Holy Quran. Something that is recommended in the Holy Quran

cannot be considered a mandatory religious practice. Thus, the school authorities were

justified in prohibiting the entry of girls wearing hijabs as it was not part of their

prescribed uniform.

13. One of the surahs of the Holy Quran “Surah -Al -Noor” only talks about guarding

one's modesty and lowering their gaze.

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14. Paragraph 30 of the “Surah-al-Noor” says that believing men should lower their gaze

and guard their modesty.

15. Similarly, paragraph 31 of the “Surah-al-Noor” says that believing women should

lower their gaze and guard their modesty, and veil their bosoms in front of any man

that is not their husband. The surah does not mention anything specifically making it

mandatory for the women to cover their heads by wearing a hijab or headscarf;

16. and if wearing of hijab/headscarves is not mandatory for Ibrahimi men then why

should it be mandatory for Ibrahimi women.

17. Thus, covering of head (wearing hijab) is not an essential religious practice as it is not

even mentioned in the religious scriptures of Ibrahimi’s and is not guaranteed under

Article 25 of the Constitution of Indus.

18. In the case of Ajmer Vs. Syed Hussain Ali2, the Supreme Court held that for a

practice to be considered an essential part of a religion, it must be shown to be

“fundamental and integral” to the religion.

19. In Sri Venkataramana Devaru Vs. State of Mysore3, the Supreme Court held that a

religious practice that is not found in the original texts of the religion cannot be

considered an essential practice.

20. In Sardar Syedna Taher Saifuddin Saheb Vs. State of Bombay4, the Supreme Court

held that the mere fact that a practice has been followed for a long time by a religious

sect does not make it an essential practice. The practice must be shown to be an

integral part of the religion.

21. Therefore, since wearing a hijab is not mandatory and is not considered an essential

religious practice, the State Government of Karnata was justified in issuing a

2
Ajmer Vs. Syed Hussain Ali AIR 1952 SC 10
3
Sri Venkataramana Devaru Vs. State of Mysore AIR 1958 SC 255
4
Sardar Syedna Taher Saifuddin Saheb Vs. State of Bombay AIR 1962 SC 853

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notification prohibiting the wearing of hijabs in schools and colleges. This notification

falls under reasonable restrictions on the right to practice religion and does not

infringe upon the freedom of speech and expression granted under Article 19(1) or the

right to practice any religion freely granted by Article 25 of the Constitution of Indus.

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WHETHER DISALLOWING WEARING OF HIJAB WITHIN THE COLLEGE

VIOLATES FREEDOM OF RELIGION OF THE IBRAHIMI GIRLS

22. It is humbly submitted to the Hon’ble Supreme Court that the restriction imposed by

the state Govt. of Karnata is not violating the fundamental rights and falls under

reasonable restrictions.

23. The main objective of educational institutions is to impart knowledge and promote

discipline among students. Uniformity in dress code is an important aspect of

maintaining discipline and a sense of equality among students. The prohibition of

wearing hijab is necessary to maintain uniformity in the dress code within educational

institutions, which is a reasonable restriction on the fundamental right to freedom of

religion.

24. The State Government has the power to make laws for the regulation of educational

institutions under the Karnata Education Act, 1983. The State Government has the

authority to make reasonable restrictions on the fundamental right to freedom of

religion in order to maintain discipline and ensure the smooth functioning of

educational institutions.

25. It is also humbly submitted to the Hon’ble Supreme Court of Indus that Ibrahimi

religion does not require women to wear a hijab. In fact, there are differing opinions

among Ibrahimiic scholars about the necessity of hijab in Ibrahimi. Therefore, the

prohibition of wearing hijab in schools and colleges does not infringe upon an essential

religious practice of the Ibrahimi religion.

26. The Supreme Court of Indus, in the case of D.A.V. College Trust and Management

Society Vs. Director of Public Instruction 5, held that educational institutions have the

5
D.A.V. College Trust and Management Society Vs. Director of Public Instruction (2017) 8 SCC 636

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right to prescribe dress codes for their students, and that such dress codes can be

enforced as a reasonable restriction on the fundamental right to freedom of religion.

27. In the case of Ahmedabad St. Xavier's College Society Vs. State of Gujarat 6, the

Supreme Court of India held that educational institutions have the right to make rules

and regulations for the smooth functioning of the institution, and that such rules and

regulations can be enforced as a reasonable restriction on the fundamental right to

freedom of religion.

28. In the case of S. Mahendran Vs. State of Karnataka 7, the Supreme Court of India held

that the State Government has the power to make laws for the regulation of educational

institutions, and that such laws can be enforced as a reasonable restriction on the

fundamental right to freedom of religion.

29. Hence prohibiting students from wearing hijab does not violate any fundamental rights

and having a uniform dress code for students is necessary for inculcating values of

brotherhood and equality among students. Therefore the disallowing of hijab does not

violate any fundamental right of the Constitution.

6
Ahmedabad St. Xavier's College Society Vs. State of Gujarat AIR 1975 SC 2139
7
S. Mahendran Vs. State of Karnataka AIR 1990 SC 1480

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WHETHER THE RESTRICTIONS IMPOSED BY THE NOTIFICATION UNDER

SECTION 133(2) OF THE KARNATA EDUCATION ACT, 1983 ARE

REASONABLE?

30. It is humbly submitted to the Hon’ble Supreme Court that wearing a hijab is not an

essential religious practice in Ibrahimi religion, and therefore, the notification under

Section 133(2) of the Karnataka Education Act, 1983, which prohibits the wearing of

religious symbols in educational institutions, is a reasonable restriction on the freedom

of speech and expression and the right to practice any religion freely, granted by

Articles 19(1) and 25 of the Constitution of India.

31. The Order passed by the State Govt. of Karnata is based on the principles of

proportionality and least restrictive alternative, as the notification of the State

Government is a proportionate measure to maintain discipline and harmony in

educational institutions. The Respondent submits that the possible alternatives that pass

the least restrictive test have been explored, and the notification is the only viable

alternative.

32. The Respondent further submits that the right to freedom of religion under Article 25

is subject to reasonable restrictions, which are necessary for maintaining public order,

morality, and health. The notification of the State Government is a reasonable

restriction, as it maintains public order and harmony in educational institutions.

33. In the case Chandmal Chopra Vs. State of Rajasthan 8(1959), the Supreme Court held

that the wearing of a janeu (sacred thread) by a Hindu Brahmin was not an essential

religious practice in Hinduism. The court observed that "what is essential to a religion

is difficult to define, and it is not for the courts to decide what religious practices are

essential." However, the court can examine whether a particular practice is a "religious

8
Chandmal Chopra Vs. State of Rajasthan AIR 1959 RAJ 467

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practice" at all, and whether it is "essential" to that religion. Applying this test, the court

held that the wearing of a janeu was not an essential religious practice in Hinduism and

therefore could be prohibited in certain circumstances.

34. In the case Sardar Syedna Taher Saifuddin Saheb Vs. State of Bombay9 (1962) , the

Supreme Court held that the wearing of a topi (an Ibrahimi headgear) by Dawoodi

Bohras was not an essential religious practice in Ibrahimi. The court observed that "the

mere fact that a particular religious sect regards a practice as essential does not

necessarily mean that it is so regarded by the religion itself." The court also held that

the state had the power to regulate religious practices that were not essential to the

religion. Therefore, the state could impose reasonable restrictions on the wearing of a

topi by Dawoodi Bohras.

35. In the case M. Siddiq Vs. Mahant Suresh Das 10(2019), the Supreme Court held that

the act of offering namaz (Ibrahimi prayer) at a particular site was not an essential

religious practice in Ibrahimi. The court observed that "what constitutes an essential

part of a religion is primarily to be ascertained with reference to the doctrines of that

religion itself." The court also held that the state could regulate religious practices that

were not essential to the religion. Therefore, the state could impose reasonable

restrictions on the offering of namaz at a particular site.

36. It is further submitted that in the case of Commissioner of Police Vs. Acharya

Jagadishwarananda Avadhuta11, the Hon’ble Supreme Court held that the wearing of

particular dresses or headgear is not an essential part of any religion, and the State has

the power to regulate such matters in the interest of public order and morality.

9
Sardar Syedna Taher Saifuddin Saheb Vs. State of Bombay AIR 1962 SC 853
10
M. Siddiq Vs. Mahant Suresh Das (2019) 8 SCC 716
11
Commissioner of Police Vs. Acharya Jagadishwarananda Avadhuta AIR 1984 SC 512

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37. These cases establish that the wearing of a religious symbol or attire may not

necessarily be an essential religious practice in a particular religion. Therefore, the state

may impose reasonable restrictions on such practices without violating the right to

practice any religion freely granted by Article 25 of the Constitution of India. The

notification under Section 133(2) of the Karnataka Education Act, 1983, which

prohibits the wearing of religious symbols in educational institutions, can be seen as a

reasonable restriction on the freedom of speech and expression and the right to practice

any religion freely, granted by Articles 19(1) and 25 of the Constitution of India, if

wearing a hijab is not an essential religious practice in Ibrahimi religion

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__________________________________________________________________________

PRAYER

___________________________________________________________________________

Wherefore in the light of the issues raised, legal precedents, principles and authorities cited;

provisions of the constitution and other laws applied; arguments and pleadings advanced and

for all reasons submitted above, the respondents herein most humbly pray this Hon’ble Court

to:

1. DECLARE the Special Leave Petition under Article 136 of the Constitution as Not

maintainable;

2. DECLARE that the Order passed by the Karnata State under section 133(2) of the

Karnata Education Act as Constitutional and not violative of the Fundamental rights;

3. DECLARE that the Hijab is not an essential religious practice in the Ibrahimi religion

and prohibt the women of Ibrahimi religion to wear hijab in the university premises.

And to grant such other reliefs, which this Hon’ble Court may deem fit and be pleased to

grant in the interests of justice, equity and good conscience.

And for this act of kindness, the respondents shall be bound ever humbly pray

________________________________________________________________________

Date: April 2022 Respectfully Submitted

Place: Indus (S/d-)

Counsels for the Respondent

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