Arguments advanced:

2. Whether the notification or the address by Prime Minister dated

18th june 2016 ultra vires with provisions of chapter 2 sections 7 and 17
and chapter 3 sections 26(2),23,24,29 and 42 of the reserve bank of
indicata act,1934

It is humbly submitted before the Hon’ble Court that the notification or

the address by pm dated 18th june 2016 are not ultra vires with provisions
of chapter 2 sections 7 and 17 and chapter 3 sections 26(2),23,24,29 and
42 of the Reserve Bank of Indicata Act,1934. The Goverment of Indicata
demonetized currency in accordance with the provisions of Reserve Bank
of Indicata Act, 1934. Herein the arguments have been delt in twofold
manner i.e [2.1] the act of demonetization did'nt contravene the provisions
of Chapter II Sections 7 and 17 of the Reserve Bank of Indicta Act,1934
[2.2] the act of demonetization did'nt contravene the provisions of Chapter
III Sections 26(6), 23, 24, 29 and 42 of the Reserve Bank of Indicta
Act,1934.

2.2 The act of demonetization did'nt contravene the provisions of Chapter

III Sections 26(6), 23, 24, 29 and 42 of the Reserve Bank of Indicta
Act,1934.

2.2.1 It is submitted that the word “any series” in section 26(2) 1 should be read as
“all series” of bank notes not “any specific series” of bank notes. 3. It is submitted
that the contention made by the petitioner that the word "any series" in Section 26(2)
should be read as "any specific series" of bank notes and not "all series" of banknotes
is erroneous in nature because if it assents, then the central government has to issue
distinct notifications for each series of bank notes rather than a common notification
for all series of bank notes. 4. It is further submitted that the word "any" has appeared
two times in Section 26(2) of the RBI Act. Hence, the word "any" coming before the
word "series of bank notes" should be read as "all." On the other hand, the word
"any" coming before the word "denomination" may be read as either way.

2.2.2 It is submitted that the RBI has been established to "control the issuing of bank
notes," according to the RBI Act's preamble 2. It is argued that the Preamble's word
1 RESERVE BANK OF INDIA ACT, 1934, s 26(2) On recommendation of the Central Board the 4 [Central
Government] may, by notification in the Gazette of India, declare that, with effect from such date as may be
specified in the notification, any series of bank notes of any denomination shall cease to be legal tender 5 [save at
such office or agency of the Bank and to such extent as may be specified in the notification]
2 Whereas it is expedient to constitute a Reserve Bank for India to regulate the issue of Bank notes and the keeping of
reserves with a view to securing monetary stability in 2 [India]
"regulate" and Section 3 of the RBI Act's phrase "taking over the management of the
currency"3 need the broadest interpretations conceivable. A narrower interpretation, it
is argued, would undermine the RBI Act's fundamental goals, the term "regulate" also
includes the word "prohibit."

3 A bank to be called the Reserve Bank of India shall be constituted for the purposes of taking over the management
of the currency from the [Central Government] and of carrying on the business of banking in accordance with the
provisions of this Act.