Best Team Memorial Petitioner Nmims National Virtual Moot Muzzamil212393 Hnluacin 20221009 195144 1 9

SCC Online Web Edition, © 2022 EBC Publishing Pvt. Ltd.
Page 1 Sunday, October 09, 2022

Printed For: Md Muzzamil Ibrahim, Hidayatullah National Law University
SCC Online Web Edition: http://www.scconline.com
© 2022 EBC Publishing Pvt.Ltd., Lucknow.
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2nd NMIMS National Virtual Moot, 2021

Best Team Memorial - Petitioner
Before the Supreme Court of Incia

In the Matter of:
Gossip Box LLC and Another … Petitioner;
v.
Union of Inida … Respondent.
MEMORIAL OF THE PETITIONERS
TABLE OF CONTENTS
STATEMENT OF FACTS 3
STATEMENT OF JURISDICTION 5
ISSUES 6
SUMMARY OF ARGUMENTS 7
ARGUMENTS ADVANCED 9
I. The Writ petition before the Supreme Court is maintainable 9
II. Gossip Box as an intermediary and the Grievance officer Mr. Jhandu 10
are protected under Section 79(1) of the Information Technology Act,
2000 therefore, blanket ban on Gossip Box and arrest of Mr. Jhandu is
invalid and illegal
III. The Information Technology (Intermediary Guidelines and Digital 11
Media Ethics Code) Rules, 2021 are unconstitutional
IV. The new rules are ultra-vires of the parent, IT Act 13
PRAYER 17
STATEMENT OF FACTS
GossipBox is an audio-based social media application where users can communicate
in different voice chat rooms. To sign up for the app a person needs an invitation from
an existing Gossip Box user to get the access to the app. The users after signing up
could link their other social media accounts like their Ultragram account with
GossipBox and create open voice chat rooms where anyone from all over the globe
would be able to join them and communicate with them.
On February 25, 2021, the Ministry of Information, Government of Incia enacted the
Information Technology (Intermediary Guidelines and Digital Media Ethics Code)
Rules, 2021 under the parent act Information Technology Act, 2000. A few of the
cardinal rules of which are mentioned as under:
a. Establish Grievance Redressal Mechanism to resolve the complaint within the
stipulated time.
b. Follow due diligence and appoint a Chief Compliance Officer, Nodal Contact
Person and Resident Grievance Officer.
c. Removing or disabling access to objectionable content within 24 hours of receipt
of complaints.
d. Publishing a monthly compliance report containing status of the complaints.
e. Identification of the first originator of the information.
f. Removal of content prohibited under law, after receiving information in the form
of an order by a court or being notified by the government or its agencies.
As per Rule 7 of the said rules, if a social media intermediary violates the said Rules
then its safe harbour immunity granted under Section 79 (1) of the Information
Technology Act, 2000 will be removed and it shall be liable for punishment under any
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applicable law including the Information Technology Act, 2000 and Penal Code, 1860.
On June 01, 2021, a voice chat room with over 2500 users created by the Mr.
Pansu, a famous Ultragram influencer and a member of ruling party PJP as well as
socio-political group namely ShisaSena faced a heated debate where all the 2500
users started abusing each other. The situation got out of the hands as one of the
member of the voice chat room made certain remarks against the members of
ShisaSena and theistic women. The user then made communal remarks against a
religion which made things worse. Thereafter, the user left the voice chat room
immediately and his identity and user id could not be recognized by the members as
there were more than 2500 users active in that voice chat room.
The Government of Incia had issued notice to GossipBox to identify the user id and
demanded the details of the first originator of the audio clip being shared on various
social media platforms. The Grievance Officer of GossipBox after his investigation
replied to Government of Incia and stated that he or any of the member of that voice
chat room could not identify the user id as more than 2500 people were speaking in
that voice chat room. The Grievance Officer of the GossipBox also refused to give the
details of the first originator of the audio clip with the reason that there existed an end
to end encryption between the users of the voice chat room and owing to various
privacy concerns.
The Government of Incia accused GossipBox of spreading false information and
violating the new Rules of not providing the first originator of the information leading
to various complaints being made to police against the GossipBox and its Grievance
Officer namely Mr. Jhandu, the moderator/creator of the group namely Mr. Pansu as he
had created the group and allowed the accused user to speak. Thereafter, the
Government of Incia banned the GossipBox app in Incia for not complying with the
new Rules, spreading false information leading against the integrity, sovereignty and
public order of Incia leading to Riots and loss of life and property. The Government of
Incia further ordered arrest of the Grievance Officer of the GossipBox Mr. Jhandu as
safe harbour immunity Section 79(1) of the Information Technology Act, 2000 would
not be applicable. GossipBox aggrieved by the above, has approached the Hon'ble
Supreme Court.
STATEMENT OF JURISDICTION
The Counsel for the Petitioners has filed this present writ petition before the Hon'ble
Supreme Court of Incia under Article 32 of the Incian Constitution, impleading the
Government of Incia as Respondent. The Counsel for the Petitioners hereby submit to
the jurisdiction of this Hon'ble Court.
ISSUES
The issues before the Hon'ble Supreme Court, are as follows:
I. The Writ petition before the Supreme Court is maintainable.
II. Gossip Box as an intermediary and the Grievance officer Mr. Jhandu are
protected under Section 79(1) of the Information Technology Act, 2000
therefore, blanket ban on Gossip Box and arrest of Mr. Jhandu is invalid and
illegal.
III. The Information Technology (Intermediary Guidelines and Digital Media Ethics
Code) Rules, 2021 are unconstitutional.
IV. The new rules are ultra-vires of the parent, IT Act.
SUMMARY OF ARGUMENTS
I. The Writ petition before the Supreme Court is maintainable.
This Hon'ble Court has the power to entertain the present Writ petition as Article 32
is applicable in cases where there is a question of enforcement of fundamental rights.
The court has the power under Article 32 (2) to issue directions or orders for the
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enforcement of any rights conferred under Part III. The current actions of the
Government in providing the blanket bank on Gossip Box and arrest of the Grievance
officer Mr. Jhandu are against the principles enshrined under Part III of the
Constitution of Incia, namely the freedom against arbitrary state action in Article 14
and the Right to life under Article 21. The Petitioner has no alternative remedy, much
less an equally efficacious remedy, with respect to the subject matter of the present
Writ Petition.
illegal.
Section 79 of the Information Technology Act, 2000 (hereinafter referred to as “IT
Act”) provides an exemption to intermediaries from liability in certain instances. It
states that intermediaries will not be liable for any third party information, data or
communication link made available by them. The Act extends “safe harbour
protection” to those intermediaries that act as a facilitator and does not play any part
in creation or modification of the data or information. Gossip Box does not have control
over the voice chat rooms and only a moderator can control who can speak and who
cannot. Further, Gossip Box does not have the means to listen to communications of
the users on the app, as the encryption and decryption of information shared between
users occurs entirely on the device of such users. Thus there is an apparent technical
limitation in complying with the orders of the Government. The Government has failed
to understand this technicality and diluted the protection guaranteed to Gossip Box
and the Grievance Officer, Mr. Jhandu. The ban on Gossip Box and the arrest of Mr.
Jhandu is also on the basis of colorable exercise of legislation.
III. The new the Information Technology (Intermediary Guidelines and Digital
Media Ethics Code) Rules, 2021 rules are unconstitutional.
The rule provides an unusually onerous obligation on the intermediary. Any
requirement of traceability will lead to breaking of end to end encryption. Such a
requirement can affect user experience in Incia, by exposing users to cyber security
threats and cybercrimes and violating their fundamental rights guaranteed under
Articles 14, 19 and 21 of the Constitution. The new rules requires Gossip Box to store
additional data for every voice note sent on the platform which is contrary to the data
minimization principles. Test of proportionality was introduced to be taken in account
while invading fundamental right of privacy which guarantees that the objects and the
means adopted to achieve them should have a rational nexus however, Rule 4(2) of
the said Rules does not meet this requirement.
Section 79(2) read with Section 87(2)(zg) makes it clear that the power of the
Central Government is limited to prescribing guidelines related to the due diligence to
be observed by the intermediaries while discharging its duties under the IT Act.
However, the 2021 guidelines have imposed additional requirements and widened the
ambit of requirements to be fulfilled by the intermediary.
The rule making power envisaged under section 79(2) only provides the power of
the Government to provide guidelines for the observation of due diligence. It has not
enabled the rule-making authority to provide additional guidelines. Furthermore, the
rule-making authority has not been delegated with the power to envisage situations
where the safe harbour immunity would not apply (Rule 7 of the IT Rules).
ARGUMENTS ADVANCED
I. The present Writ petition filed by Gossip box is maintainable.
a) It is a well settled law that procedure should not stand in the way of justice to all
the sections of society. The Hon'ble Supreme Court in Bandhua Mukti Morcha
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has held that, “While interpreting Article 32, it must be borne in mind that our
approach must be guided not by any verbal or formalistic canons of construction
but by the paramount object and purpose for which this article has been enacted
as a fundamental right in the Constitution and its interpretation must receive
illumination from the trinity of provisions which permeate and engage the entire
Constitution, namely, the preamble, the Fundamental Rights and the Directive
Principles of State policy”1 .
b) The Hon'ble Supreme Court in Ramadas Athawale v. Union of Incia2 has held that
Article 32 is applicable in cases where there is a question of enforcement of
fundamental rights. The court has the power under Article 32 (2) to issue
directions or orders for the enforcement of any rights conferred under Part III.
This ensures that justice is done to those who approach the court under this
jurisdiction.
c) The current actions of the Government in providing the blanket bank on Gossip
Box and arrest of the Grievance officer Mr. Jhandu are against the principles
enshrined under Part III of the Constitution of Incia, namely the freedom against
arbitrary state action in Article 14 and the Right to life under Article 21.
Furthermore, the right to privacy under Article 21 of the Constitution is at stake
of all users of social media and social platforms in Incia due to the enactment of
the Information Technology (Intermediary Guidelines and Digital Media Ethics
Code) Rules, 2021(hereinafter mentioned as the “IT Rules”).
d) The present Writ has been filed under the Writ of mandamus or any other Writ as
this Hon'ble Court may deem fit, requesting this Hon'ble Court to direct the
appropriate authority to restrain the Respondent from imposing a criminal
liability on Mr. Jhandu and lift the blanket ban on Gossip Box.
e) The Petitioner has no alternative remedy, much less an equally efficacious
remedy, with respect to the subject matter of the present Writ Petition. Further,
adjudication by this Hon'ble Court in exercise of its powers under Article 32 of
the Constitution is warranted because, the Impugned Rule 4(2) of the IT Rules:
(i) violates the fundamental rights to privacy and freedom of speech and
expression;
(ii) is ultra vires the parent statute under which it was prescribed;
illegal.
a) Section 79 of the Information Technology Act, 2000 (hereinafter referred to as
“IT Act”) provides an exemption to intermediaries from liability in certain
instances. It states that intermediaries will not be liable for any third party
information, data or communication link made available by them. The Act
extends “safe harbour protection” only to those instances where the intermediary
merely acts a facilitator and does not play any part in creation or modification of
the data or information.
b) Section 79(1) of the IT Act grants intermediaries a conditional immunity with
regard to any third party information, data or communication link made available
or hosted by them. This immunity is subject to section 79 (2) and 79 (3) of the
IT Act.
c) Section 79(2) of the IT Act essentially covers cases where the activity
undertaken by the intermediary is of a technical, automatic and passive nature.
Thus, for section 79(2) of the IT Act to be applicable, intermediaries are to have
neither knowledge nor control over the information which is transmitted or
stored.
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d) Gossip Box does not have control over the voice chat rooms and only a
moderator can control who can speak and who cannot. Further, Gossip Box does
not have the means to listen to communications of the users on the app, as the
encryption and decryption of information shared between users occurs entirely on
the device of such users.
e) Thus there is apparent technical limitation in complying with the orders of the
Government. The Government has failed to understand this technicality and thus
diluted the protection guaranteed to Gossip Box and the Grievance Officer, Mr.
Jhandu.
f) Since the compliance of the Government notification is an impossibility, diluting
the safe harbour provisions is an arbitrary action by the Government. No other
Country has forced Gossip Box to trace the first originator of a message by
breaking the end-to-end encryption therefore, the said requirement by
Government contravenes the intent of the IT Act to achieve “uniformity of the
law” as per its preamble.
g) The Government must consider the question fairly and reasonably before taking
action. The term “unreasonable” may mean that the authority has acted
according to law but in a wrong manner. The Hon'ble Supreme Court in
Chandeshwari Parsad v. State of Bihar3 , the administrative authority had
cancelled certain grants of property made to the Petitioner by the previous owner
on the ground that the transfer was made with a view to defeat the provisions of
the Bihar Land Reforms Act, 1950. The court found that there was no evidence to
support the findings of the authority. The Government has wrongly accused
Gossip Box of spreading false information which has led to the communal riots.
However and as stated above, Gossip Box is a mere intermediary on which the
users transfer information from each other. The blanket ban and the arrest of Mr.
Jhandu is justified by the Government owing to the spread of false information,
which is an unreasonable exercise of its discretionary power hence, invalid and
illegal.
h) The ban on Gossip Box and the arrest of Mr. Jhandu is on the basis of colourable
exercise of legislation - Colourable exercise means that under the “colour” or
“guise” of power conferred for one purpose, the authority is seeking to achieve
something else which it is not authorized to do under the law in question. In
such a scenario the action of the authority shall be invalid and illegal. The
Hon'ble Supreme Court in Somawanti v. State of Punjab4 , the Supreme Court has
stated that he term “colourable exercise of power” is used in the sense of using a
power for a purpose not authorized by the Act conferring the power on the
authority concerned. It is submitted that the Government wishes to protect a
member of its political party, Mr. Pansu of PJP who had the authority and the
control over the voice chat room. Adding on, Mr. Pansu seems exonerated from
any blame and degree of control for the spread of the information, while
Government has arrested the Grievance officer and banned Gossip Box on the
justification that they have instrumental in the spread of false information.
III. The new the Information Technology (Intermediary Guidelines and Digital
Media Ethics Code) Rules, 2021 rules are unconstitutional.
a) Gossip Box does not record communications in the voice chat room as the
conversations between the users are encrypted and even the Gossip Box cannot
listen to the conversations.
b) As per Rule 3 sub rule (j) of the IT Rules, the intermediary is required to as soon
as possible, but not later than seventy two hours of the receipt of an order,
provide information under its control or possession, or assistance to the
Government agency which is lawfully authorized for investigative or protective or
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cyber security activities, for the purposes of verification of identity, or for the
prevention, detection, investigation, or prosecution, of offences under any law for
the time being in force, or for cyber security incidents.
c) Furthermore, Rule 4(2) of the IT Rules, requires the first originator of a message
to be disclosed to the Government by the intermediary.
d) This rule provides an unusually onerous obligation on the intermediary. Any
requirement of traceability will lead to breaking of end to end encryption. Such a
requirement can affect user experience in Incia, by exposing users to cyber
security threats and cybercrimes and violating their fundamental rights
guaranteed under Articles 14, 19 and 21 of the Constitution.
e) The right to privacy which is an intrinsic part of the right to life under Article 21
of the Constitution is at stake of all its users in Incia as Gossip Box would have to
build a mechanism that would permit tracing of every communication sent in
Incia on Gossip box in order to identify the first originator of information.
Furthermore, there is no way to predict which message will be the subject of
such an order seeking information of the first originator.
f) The Hon'ble Supreme Court in K.S Puttaswamy v. Union of Incia5 , has stated that
the right to privacy is protected as an intrinsic part of the right to life and
personal liberty under Article 21and an integral part to Part III of the
Constitution. In that case, informational privacy was held to be a vital aspect of
the fundamental right to privacy. Test of proportionality was introduced to be
taken in account while invading fundamental right of privacy which guarantees
that the objects and the means adopted to achieve them should have a rational
nexus however, Rule 4(2) of the said Rules does not meet this requirement. Thus
for any order under this rule to withstand the scrutiny of the Courts, it will have
to meet the requirements of the three pronged test set out in, i.e. of legality,
necessity and proportionality:
i. Legality: There is no statute requiring intermediaries to enable the
identification of the first originator of information in Incia on end-to-end
encrypted messaging services upon Government or court order. Nor is there
any statute that allows the imposition of such a requirement through
subordinate legislation like the Intermediary Rules. The said IT Rules are
putting the fundamental right of privacy of the citizens in grave danger and
hence is not legal.
ii. Necessity: The Hon'ble Supreme Court in the case mentioned above has
emphasized the importance of judicial review before the invasion of privacy
occurs to guarantee against arbitrary State action. However, under the said IT
Rules there is no necessity and there is now judicial check of the arbitrary
actions of the Government under the said IT Rules.
iii. Proportionality: To satisfy the proportionality requirement, the infringement of
fundamental rights must “be through the least restrictive alternatives”. The
Government can follow proper course of action as mentioned in the IT laws
and criminal laws of the Country instead of violating the fundamental rights of
the citizens.
g) Further, the Apex Court in the case mentioned above has stated that the State
which is discharging the test of proportionality while affecting the privacy rights
of its citizens, must observe the principles of data minimization and storage
limitation with strict scrutiny. The new rules requires Gossip Box to store
additional data for every voice note sent on the platform which is contrary to the
data minimization principles explained above
a) The IT Rules requires modifications to the design of encrypted platforms to
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enable traceability, it is beyond the scope of the parent provision that is Section
79 of the IT Act. Here, it is important to note that the power to prescribe
encryption standards and methods originates from Section 84A of the IT Act, and
not Section 79 of the IT Act, which is a safe harbour provision. Even Section 84A
empowers the Central Government to prescribe modes and methods of
encryption for the purpose of “secure use of the electronic medium and for
promotion of e-governance and e-commerce.” Any attempts to weaken
encryption to enable traceability would not satisfy the objective of ensuring
secure use of the electronic medium.
b) Section 79(1) of the IT Act states that the intermediary will not be held liable for
any third-party information if the intermediary complies with the conditions laid
out in Section 79(2) of the IT Act. One of these conditions is that the
intermediary observe “due diligence while discharging his duties under this Act
and also observe such other guidelines as the Central Government may prescribe
in this behalf.” Further, Section 87(2) (zg) empowers the Central Government to
prescribe “guidelines to be observed by the intermediaries under sub-section (2)
of section 79.”
c) It has been held by the Hon'ble Supreme Court in State of Karnataka v. Ganesh
Kamath6 that:“It is a well settled principle of interpretation of statutes that
conferment of rulemaking power by an Act does not enable the rule making
authority to make a rule which travels beyond the scope of the enabling Act or
which is inconsistent therewith or repugnant thereto.” A combined reading of
Section 79(2) read with Section 87(2)(zg) makes it clear that the power of the
Central Government is limited to prescribing guidelines related to the due
diligence to be observed by the intermediaries while discharging its duties under
the IT Act. However, the 2021 guidelines have imposed additional requirements
and widened the ambit of requirements to be fulfilled by the intermediary.
d) The Hon'ble Supreme Court in Dwarkanath v. Municipal Corp.7 . Section 23(1) of
the Prevention of Food Adulteration Act, 1954, authorized the Central
Government to make rules for restricting the packing and labelling of any article
of food, with a view to preventing the public from being deceived or misled as to
quantity or quality of the article. Rule 32 framed there under by the Government
provided that there would be specified on every label name and business address
of the manufacturer, as also batch number or code number in Hindi or English.
The appellant, the manufacturers of Mohan Ghee sold in tins labelled Mohan
Ghee Laboratories, Delhi challenged Rule 32 as beyond the power of the
Government conferred under Section 23(1) of the Act, 1954. They contended
that the requirement of address under Rule 32 was in excess of the power
conferred, which was restricted to “quantity and quality” only. Accepting the
contention of the appellants, the Hon'ble Supreme Court held Rule 32 ultra vires
the as it was beyond the power conferred on the Government.
e) Similarly, the rule making power envisaged under Section 79(2) only provides
the power of the Government to provide guidelines for the observation of due
diligence. It has not enabled the rule-making authority to provide additional
guidelines. Furthermore, the rule-making authority has not been delegated with
the power to envisage situations where the safe harbour immunity would not
apply (Rule 7 of the IT Rules).
f) Adding on, Sections 69 and 69B of the Act read with their respective subordinate
legislations provide the procedure for access by law enforcement agencies to
information available with the intermediary. In the present case, parts of the
proposed Rule 3(5) that are in conflict with Sections 69 and 69B and rules
framed under those. Rule 3(5) is beyond the mandate of the parent provision i.e.
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Section 79(2) and thus void.

g) The Government is trying to bring back Section 66A of the Act through backdoor
entry by enacting the ultra-virus and unconstitutional Rules. The Hon'ble
Supreme Court in Shreya Singhal v. Union of Incia8 , had declared Section 66A of
the IT Act, which provided for the imprisonment of a person for posting
objectionable comments on the Internet and social media, unconstitutional. The
said unconstitutional section was being used arbitrarily by the Government for
their political motives. The Government under the garb of regulating social media
intermediaries and brining certain checks and balances, wants to indirectly curb,
restrict and prevent the communication between certain person for their political
motives and thus is violating the fundamental right of privacy of the all the
citizens.
h) It is submitted further that the obligations upon the Grievance Officer and Gossip
Box under the IT Rules are Arbitrary and unreasonable. Rules 10 & 11 of the IT
Rules obligate every intermediary to appoint a grievance officer, set up a
grievance handling mechanism and redress all grievances within 15 days. Any
person may lodge a grievance with the publisher if they have any problem with
the content published, thereby equating the free press with any product or
service sold in the market. There is no definition of, or restriction on, what may
constitute a grievance, and hence no limitation on the nature of quibbles that
any person may bring against the intermediary.
i) The scope of such restrictions was made clear by the Hon'ble Supreme Court in
Shreya Singhal v. Union of Incia9 , which held that a law restricting free speech
could not pass muster merely by virtue of being in the ‘public interest’, but
instead, such restrictions had to be covered by one of the eight subject matters
listed in Article 19(2) of the Constitution. On this ground, Section 66A of the IT
Act — which criminalised the intentional publication (by anyone) of information
that caused annoyance, inconvenience, or insult — was struck down as
unconstitutional. Thus, it is untenable that social media intermediaries be
required to redress every annoyance, inconvenience or insult that their reporting
may cause and that the non-compliance of the said provisions would lead
criminal prosecution.
j) Proactive Monitoring of Content is arbitrary and unlawful: Intermediaries are
required to deploy technology based automated tools or appropriate mechanisms
with appropriate controls to proactively identify and remove access to unlawful
content. The rationale behind extending Safe Harbour protection to
intermediaries is that they are merely passive transmitters of information, which
is generated by third parties without interference or oversight of the
intermediaries. Proactive monitoring requirement means that intermediaries have
knowledge and oversight over information that is transmitted on their platform
and are as such no longer amenable to Safe Harbour protection.
k) Mandatory Assistance to State Agencies is unreasonable and arbitrary:
Intermediaries are required to provide assistance requested by “any government
agency”, within 72 hours of such request being made. This request may be for
the security of the State; cyber security; the purpose of investigation, detection,
prosecution or prevention of offence, or for protective or cyber security and
matters connected with or incidental thereto. Investigation and prosecution of
cyber offences requires the investigating body to have sophisticated technical
capabilities. Consequently, the IT Act has specific requirement as to the rank of
the officer who may investigate offences under the IT Act and the authorities
who may issue orders to block monitor or collect data. The IT Rules significantly
water down these requirements and oblige intermediaries to assist any
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government agency. There are no judicial checks and the Government can arrest
anyone upon their own discretion for fulfilling their political motives. Therefore,
the blanket ban of Gossip Box and arrest of Mr. Jhandu is arbitrary use of
Government’s powers for their own political motives and hence, unconstitutional.
PRAYER
It light of the abovementioned submissions, it is respectfully prayed that this
Hon'ble Court may be pleased to:
I. Allow the present Writ Petition in favour of the Petitioners;
II. Direct the Respondent to remove the unconstitutional blanket ban on GossipBox;
III. Direct the Respondent to release Mr. Jhandu illegally held in jail;
IV. Direct the Respondent to drop all false criminal charges against Mr. Jhandu;
V. Declare that the Information Technology (Intermediary Guidelines and Digital
Media Ethics Code) Rules, 2021 rules are unconstitutional and ultra-vires of the
parent, IT Act.
VI. Any other relief which the Hon'ble Court deems fit in the interest of justice in
the favor of the Petitioners.
Counsel on behalf of the Petitioners.
———
1 Bandhua Mukti Morcha v. Union of Incia, (1997) 10 SCC 549
2
(2010) 4 SCC 1 : AIR 2010 SC 1310
3
CWJC No. 7906 of 2010
4 AIR 1963 SC 151
5
(2018) 1 SCC 809
6
(1983) 2 SCC 402
7 (1971) 2 SCC 314
8 (2015) 5 SCC 1 : AIR 2015 SC 1523
9 (2015) 5 SCC 1 : AIR 2015 SC 1523
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rule/ regulation/ circular/ notification. All disputes will be subject exclusively to jurisdiction of courts, tribunals and forums at Lucknow only. The
authenticity of this text must be verified from the original source.

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Page 1 Sunday, October 09, 2022

2nd NMIMS National Virtual Moot, 2021

Before the Supreme Court of Incia

Section 79(2) and thus void.

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