BEFORE THE HON’BLE HIGH COURT OF INDIA

P.(CIVIL)
CIVIL. NO.__/20

Maratha Butcher’s
Association……………………………………………Petitioner

V.

STATE OF MARATHA AND

ORS.…………………………………………Respondent

MOST RESPECTFULLY SUBMITTED TO THE HON’BLE CHIEF

JUSTICE OF HIGH COURT OF INDIA AND HIS COMPANION
JUSTICE OF THE SAID COURT.

1
 TABLE OF CONTENTS

List Of Abbreviations 3
Index of Authorities 4-5
Statement of Jurisdiction 6
Statement of Facts 7-8
Statement of Issues 9
Summary of Arguments 10-11
Arguments Advanced 12-24
Prayer 25

2
 LIST OF ABBREVIATION

SC Supreme Court
HC High Court
SCC Supreme Court Cases
SCJ Supreme Court Journal
SCR Supreme Court Reporter
AIR All India Reporter
LJ Law Journal
Sec Section
Art Article
u/s Under Section
V. Versus
Ors. Others
Anr. Another
IC Indian Cases
Hon’ble Honourable
Edn/Ed Edition
Etc. Etcetera
Id IBID

3
 INDEX OF AUTHORITIES

a. BOOKS

• Interpretations of Statues

1. JUSTICE G.P. SINGH, PRINCIPLES OF STATUTORY

INTERPRETATION, 12TH EDITION, 2010, LEXIS
NEXIS
2. MAXWELL, INTERPRETATION OF STATUTES, 12
EDITION, 2006, LEXIS NEXIS
3. N.S.BINDRA, INTERPRETATION OF STATUTES 9
EDITION, 2004, LEXIS NEXIS
4. N.S.BINDRA, INTERPRETATION OF STATUTES 9
EDITION, 2004, LEXIS NEXIS

• Constitution

1. M.P. JAIN, INDIAN CONSTITUTIONAL LAW,8

EDITION, 2018, LEXIS, NEXIS
2. DR. J.N. PANDEY. CONSTITUTIONAL LAW OF INDIA,
56 EDITION, 2009, CENTRAL LAW AGENCY
3. D.D. BASU, COMMENTARY ON THE CONSTITUTION
OF INDIA. VOL. 6 & 7, 8 EDITION, 2010, LEXIS NEXIS

4
 b. ONLINE RESOURCES

• Website Referred

o www.lexisnexisacademic.com

o www.manupatra.com

o www.vakilnel.com

o www.legalservices.com

• Legal Databases

❖ Lexis Nexis
❖ JSTOR
❖ SCC Online

c. STATUES
The Constitution of India, 1950

Maharastra Animal Preservation Act, 1978.

Maharastra Animal Preservation (Amendment) Act, 1995

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 STATEMENT OF JURISDICTION

The Hon'ble High Court of Maratha has the jurisdiction to hear the
instant matter under Article 226 of the Constitution of Indica, 1950.

Under Article 226 the High Courts are granted power, throughout the
territories in relation to which it exercise jurisdiction, to issue to any
person or authority, including in appropriate cases, any Government,
within those territories directions, orders or writs.

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 STATEMENT OF FACT

The Republic of Hindus ("The Republic") is located in the South

Asian Region of Asia. Hindus was a British Colony for about 150
Years. It achieved Independence in the year 1947. Now the Republic
of Hindus has its own Constitution, Parliament and Independent
Judiciary. Although, majority of the population belongs to Hindu
Religion, many other religions like Islam, Buddhism, Sikhism,
Jainism and Christianity are followed by the people of the Republic.
The Republic is characterized by a diversity of beliefs, practices,
dressing, cultural outlook and food habits. The food habits and the
emotions associated therewith are so strong and deep in the people
that it paved the way for the first war of independence against British.
The Constitution of the Republic, declared itself to be a Secular
Nation, has conferred on all persons the fundamental right to freely
Profess, Practice and Propagate any religion of his/her choice. The
Apex Court of the Republic expanded the meaning of 'Right to Life
and Personal Liberty' to include every aspect that has connection with
the person's meaningful life including religious faith and food habits.
The Republic has enacted the Hindus Animal Protection Act, 2018.
The salient features of the Act are as under:-
1. It bans the slaughter of Cow, Calves, Bulls and Bullocks.
2. It prohibits the Purchase, Sale, Disposal or Transport of Cows,
Calves, Bulls and Bullocks for the purpose of slaughter.
3. It prohibits the possession of the flesh of the Cow, Calves, Bulls
and Bullocks.
4. It criminalizes the possession of beef per se.
5. Presumption of law as to guilt is against accused. In the meanwhile,
there was a political turmoil throughout the Republic. Various
religious organizations started large scale mobilization against ban on
eating /preserving beef in the name of Prevention of Cow Slaughter.

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For some of the minority communities, eating beef is a common food
habit. Moreover, beef is cheap when compared to other non-
vegetarian food. For poor masses, beef eating is one of the easy
sources of protein.
In this background, a writ petition was filed before Supreme Court
under Article 32 of the Constitution challenging the constitutional
validity of the Act.

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 STATEMENT OF ISSUES

1. WHETHER THE WRIT PETITION BEFORE THE HON BLE

HIGH COURT OF STATE OF MARATHA IS MAINTAINABLE?

2. WHETHER THE MARATHA ANIMAL PRESERVATION

(AMENDMENT) ACT, 1995 VIOLATES THE FUNDAMENTAL
RIGHTS GUARANTEED UNDER ARTICLE 19 (1) (g) AND 21 OF
THE CONSTITUTION OF REPUBLIC OF INDICA?

3. WHETHER THE IMPUGNED STATUTE IS VIOLATIVE OF

ARTICLE 301 OF THE CONSTITUTION OF REPUBLIC OF
INDICA?

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 SUMMARY OF ARGUMENTS

A. THE WRIT PETITION BEFORE THE HON BLE HIGH COURT

OF STATE OF MARATHA IS MAINTAINABLE.

The counsel on behalf of the petitioner most humbly submits before

the Hon'ble High Court of State of Maratha that the writ petition is
maintainable under Article 226 of the Constitution of Republic of
Indica.

B. THE MARATHA ANIMAL PRESERVATION (AMENDMENT)

ACT, 1995 IS VIOLATIVE OF ARTICLE 19 (1) (g) AND 21 OF
THE CONSTITUTION OF REPUBLIC OF INDICA.

The counsel on behalf of the petitioner most humbly submits before

the Hon'ble High Court of State of Maratha that the Maratha Animal
Preservation (Amendment) Act, 1995 is violative of the right to
freedom of profession, occupation, trade or business secured under
Article 19 (1) (g) of the Constitution of Republic of Indica..

The Maratha Animal Preservation (Amendment) Act, 1995 is

violative of the right to livelihood and right to privacy secured under
Article 21. The right of a citizen to eat food of his/her choice is a part
of right to privacy as envisaged under Article 21.

C. THE IMPUGNED STATUTE IS VIOLATIVE OF ARTICLE 301

OF THE CONSTITUTION OF THE REPUBLIC OF INDICA.

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The counsel on behalf of the petitioner most humbly submits before
the Hon'ble High Court of State of Maratha that the impugned statute
is unconstitutional, ultra vires and Republic of Indica is violated.

The Amendment Act of 1995 is extraneous with the aims and objects
of the parent Act and has no nexus with the protection of cows, bulls
and bullocks. The impugned statute is not protected by Art 304(b) of
the constitution.

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 ARGUMENTS ADVANCED

A.THE WRIT PETITION BEFORE THE HON'BLE HIGH COURT

OF STATE OF MARATHA IS MAINTAINABLE

It is most humbly submitted before the Hon'ble court that the writ
petition in the instant case is maintainable.

Article 226 of the Constitution empowers the Hon'ble High Court to

exercise power through issuance of writ. The exercise of jurisdiction
is discretionary in nature and subject to availability and exhaustion of
the alternative remedy by the petitioner. The high court is conferred
with this power under Article 226 of the Constitution for the
enforcement of any of the fundamental rights conferred by part III of
the Constitution or for any other purpose. A writ petition can be filed
by any person whose fundamental have been infringed or under
public interest, a public spirited person can file a writ petition for the
enforcement of constitutional rights of any other person or a class, if
that person or a class is unable to invoke the jurisdiction of the High
Court due to any social or economic disability.

i. The amendment of 1995 violates Article 19(1) (g) of the

Constitution of Republic of Indica by imposing restrictions by way of
total prohibition on the petitioner's fundamental rights to practice any
trade or business.

In Chintaman Rao case, an Act of Madhya Pradesh Government

empowered the Deputy Commissioner to prohibit the manufacturing
of bidis during the agricultural season in such villages as he might
specify in his orders.

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The court held that such a provision is void, since a total prohibition
is an excessive restriction on lawful profession of making bidis..

ii. The right to livelihood under Article 21 of the constitution includes

the right to food, Right to health, medical care and shelter. The
amendment of 1995 violates The Right Of livelihood because beef
eating were common food habit of 'X' community and beef was less
costly as compared to other non vegetarian food. As the poverty in
community 'X' was high they used beef which was a easy source of
proteins which is necessary for their health.

In pavement dwellers case, a five-judge bench of the court implied

that 'right to life' as no person can live without the means of living,
that is the means of livelihood.

In an appropriate case, in spite of availability of the alternative

remedy, the High Court may still exercise its writ jurisdiction in at
least three contingencies:

Where the writ petition seeks enforcement of any of the fundamental

rights

Where there is failure of principle of natural justice

Where the orders or proceedings are wholly without jurisdiction

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Maratha Butchers Association has locus standi to file the present
petition as it is a registered society working for the protection of the
interest of minority community 'X' in the State of Maratha.
IN THE ΜΑRATHA ANIMAL PRESERVATION (AMENDMENT)
ACT, 1995 IS VIOLATIVE OF ARTICLE 19 (1) (g) AND 21 OF
THE CONSTITUTION OF REPUBLIC OF INDICA.

It is humbly submitted before this Hon'ble High Court of State of

Maratha that the Maratha Animal Preservation (Amendment) Act,
1995 is unconstitutional as it violates Article 19 (1) (g) and 21 of the
Constitution of the Republic of Indica.

B.1 The impugned statute is violative of Article 19 (1) (g).

It is respectfully submitted that the freedom of a citizen to practice

any profession or to carry on any occupation, trade or business
guaranteed under Article 19 (1) (g) has been violated. Under this
article every citizen has a right to choose any occupation or to take up
any trade or business subject only to the restrictions as may be
imposed by the State in the interest of public welfare.

B.1.1 The right to trade beef is secured under Article 19 (1) (g).

By virtue of Article 19 (1) (g), all citizens shall have the right to
practice any profession, or to carry on any occupation, trade or
business".

The word 'occupation' has a wide meaning such as any regular work,
profession, job, principal activity, employment, business, or calling in

14
which the individual is engaged. In a wider sense it includes any
vocation which engages one's time.

In T.M.A Pai Foundation v. State of Karnataka, it was held that Article

19 (1) (g) employees four expressions namely profession, occupation,
trade and business.
Article 19 (1) (g) uses the four expressions so as to cover all activity
of a citizen in respect of which income or profit is generated and
which can consequently be regulated under Article 19 (1) (g).

The trade, business, profession and occupation protected by Article 19

(1) (g) must be those which can be regarded as lawful. It must not be
anti-social.

Butchers and cattle dealers have suffered a great amount of losses

after the ban on cattle slaughter came into effect even when
constitution has provided them with then right to carry on any trade or
occupation of their calling. As many butchers and cattle traders earned
their income by the trade of beef it can be brought under the purview
of Article 19 (1) (g).

B.1.2 The impugned statute does not fall under the ambit of
reasonable restrictions in Article 19 (6).

The right to carry on a profession, occupation, trade or business can

be restricted and regulated by authority of law. Thus the State can
under clause (6) of the Article 19 make any law-

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(a) imposing reasonable restriction on this right in the interest of
public',

(b) prescribing professional or technical qualifications necessary for

practicing any profession or carrying on any occupation, trade or
business,

(c) enabling the State to carry on any trade or business to the

exclusion of citizens wholly or partially,

Any restriction imposed on the exercise of this right must be a

reasonable restriction. Here the restriction is not reasonable.

A law which arbitrarily or excessively invades the right of a person

cannot be said to contain the quality of reasonableness and unless it
strikes a proper balance between the right guaranteed in Article 19 (1)
and the social control in Article (6), it must be held to be wanting in
that quality. The phrase reasonable restriction indicates that the
limitation imposed on persons must not be arbitrary or excessive in
nature which is completely. beyond what is actually required". The
exercise of right under Article 19 (1) (g) is subject only to the
restrictions imposed in the interest of 'general public' and not that it
adversely affect others business. There must be reasonable and
rational relation between the restriction and the public interest. The
connection between the restriction and the public interest must be
direct and proximate 13.

The Apex Court in Sivani v. State of Maharashtra 14, had laid down
the criteria to evaluate the reasonableness of a restriction under
Article 19 (6) as follows: "In applying the test of reasonableness, the
broad criterion is whether the law strikes a proper balance between
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social control on the one hand and the right of the individual on the
other hand. The court must take into account factors like nature of the
right enshrined, underlying purpose of the restriction imposed, evil
sought to be remedied by the law, its extend and urgency, how far the
restriction is or is not proportionate to the evil and the prevailing
conditions at that time'.

State of Maratha already had legislation Maratha Animal Preservation

Act, 1978 that banned the slaughter of cows which were fit for
agricultural purposes. This restriction was reasonable. But when the
Amendment Act of 1995 was brought into force, it imposed a
complete ban on slaughter, it is not only unfair to the butcher
community but also affects. the farmers putting a burden on them to
continue maintaining cattle which is no longer of use to them.

A total ban on the slaughter of useless cattle" which involves a

wasteful drain on the nation's cattle feed which is itself in short supply
and which would deprive the useful cattle of much needed
nourishment, cannot be justified as being in the interests of the
general public

In Mohammed Faruk v. State of Madhya Pradesh & Ors, the State

Government issued a notification whereby the earlier notification
issued by the Jabalpur Municipality which permitted the slaughter of
bulls and ballocks along with other animals was recalled. It was held
that when the exercise of a fundamental right is prohibited, the burden
of proving that a total ban on the exercise of the right alone would
ensure the maintenance of the general public interest lies heavily upon
the State. As the State Govt, failed in discharging that burden, the
notification was held liable to be struck down as imposing an
unreasonable restriction on the fundamental right of the petitioners

17
Where the restrictions imposed are so stringent that the business
cannot be carried on, the court will regard the imposition of restriction
as unreasonable. In the instant case impugned legislation fails to
maintain a balance between public interest and the freedom of
profession, trade or business the restriction becomes arbitrary and
unreasonable. Therefore the Act cannot be given the protection under
Article 19 (6).
It is humbly submitted before the Hon'ble High Court of State of
Maratha that the Maratha Animal Preservation (Amendment) Act,
1995 violates article 21 of the Constitution of Republic of Indica.

By virtue of Article 21, "No person shall be deprived of his life or

personal liberty except according to procedure established by law

Article 21 protects the right to life and personal liberty of citizen not
only from the executive action but from the legislative action abso".
By the term life as used here something more is meant than mere
animal existence, B.2.1 The impugned statute violates the right to
livelihood secured under right to life.

Article 21 protects the right to livelihood as an integral facet of right

to life.

In Olga Tellis v. Bombay Municipal Corporation", a five Judges

Bench of the Court has finally ruled that the word "life" in Article 21
includes the right to livelihood also The court said. It does not mean
merely that life cannot be extinguished or taken away as, for example,
by the imposition and execution of death sentence, except according
to the procedure established by law. That is but one aspect of the right
to life. An equally important facet of that right is the right to
livelihood because no person can live without the means of

18
livelihood. If the right livelihood is not treated as a part of the
constitutional right to life, the easiest ways of depriving a person of
his right to life would be to deprive him of his means of livelihood. In
view of the fact that Articles 39 (a) and 41 require the State to secure
to the citizen an adequate means of livelihood and the right to work, it
would be sheer pendentary to exclude the right to livelihood from the
content of the right to life.

In D.K. Yadav v. J.MA Industries, the Supreme Court held that the
right to life enshrined in Article 21 clubs life with liberty, dignity of
person with means of livelihood without which the glorious content of
dignity of person would be reduced to animal existence. In Board of
Trustees of the Port of Bombay v. Dilip Kumar Ragavendra Nath
Nadkami & in, D.T.C v. D.T.C Mazdoor Congress the Court came to
hold that "the right to life guaranteed by Article 21 includes "the right
to livelihood

The commplete ban on the slaughter of cows, bulls and bullocks and
prohibition on the transport, purchase, sale and disposal of cows, bulls
and bullocks for the purpose of slaughter has been imposed by
amending Section 5 of the Maratha Animal Preservation Act, 1978.
As the result of this Amendment, the butchers and cattle dealers have
been. deprived of their means of livelihood. So the impugned
legislation is violative of right to livelihood envisaged under Article
21.

B.2.2 Right to eat food of one's choice is a part of right to privacy as

envisaged under Article 21

Right to food which is inherent to Article 21 of the Constitution which

guarantees fundamental right to life and personal liberty should be

19
read with Article 39 (a) and 47 to comprehend the obligations of the
State in ensuring the realization of this right. Article 39 (a) of the
Constitution enunciated as one of the directive principles states that
the State shall direct its policy towards securing to its citizens
adequate means of livelihood and Article 47 provides the duty of the
State to raise the level of nutrition and standard of living and to
improve public health. Thus the Constitution makes the right to food,
a fundamental right.

In the case of National Legal Services Authority v. Union of India",

the Apex court held that Article 21 takes all those aspects which go to
make a citizen's life meaningful and it protects personal autonomy
and right of privacy. In R. Rajagopal v. State of TN", the Supreme
Court has expressly held the right to privacy or right to be let alone is
guaranteed by Article 21 of the Constitution.

Relaying on the decision of the Apex Court in the case of Kharak

Singh v. State of UP, the Bombay High Court in the judgment in
Shaikh Zahid Mukthar and Ors v. State of Maharashtra held:

"Article 21 includes the right to lead a meaningful life. It protects the

citizens from unnecessary State intruxion into his home. For leading a
meaningful life a citizen will have to eat food and preferably food of
his choice. If the State tells in not to eat a particular kind of food
though the same is not injurious to health, it will prevent the eitizen
leading a meaningful life. If the State starts making intrusion into the
personal life of an individual by preventing him from eating food of
his choice, such act may well affect his personal liberty. Hence, even
assuming that there may not be any right of privacy, such interference
will be a violation of personal liberty guaranteed by the State. In this
case the Bombay High Court had struck down Section 5D of the
Maharashtra Animal Preservation Act, 1976. The Bombay High Court

20
ruled that the law places an unreasonable restriction on a person's
privacy.

Section 5D of the Amendment Act of 1995 prohibits any person from

possessing flesh. of any cow, bull or bullock slaughtered outside the
State of Maratha. It is to be noted that even if a cow or bull or bullock
is slaughtered at a place outside the state where there is no prohibition
of slaughter, the possession of the meat of such cow, bull or bullock in
the state is made an offence. This section of the Maratha Animal
Preservation (Amendment) Act 1995 is an infringement of the right to
eat food of one's choice which is included in right. to privacy
guaranteed under Article 21 of the Constitution. Thus the impugned
legislation is violative of Article 21.

B.3 Fundamental rights are violated for the implementation of

Directive principle

By virtue of directive principle laid down in Article 48, the State shall
endeavor to organize agriculture and animal husbandry on modern
and scientific lines and shall, in particular, take steps for preserving
and improving the breeds, and prohibiting the slaughter of cows and
calves and other milch and draught cattle

Maratha Animal Preservation Act, 1978 was brought into force for the
effective implementation of the directive principle laid down in
Article 48. But the total ban on animal slaughter imposed by the
Amendment Act of 1995 is violative of the fundamental rights
guaranteed under the Constitution..

Fundamental rights and directive principles of state policy together

comprises the rights of an individual. Unlike fundamental rights
21
which are justiciable, Directive Principles of state policy are non-
justiciable which means they are not enforceable by the Courts.

According to Article 37, the Directive Principles of the State Policy,

though they are fundamental in the governance of the country and it
shall be the duty of the State to apply these principles in making law,
but they are expressly made non-justiciable. On the other hand,
fundamental rights are enforceable by the courts and the courts are
bound to declare as void any law that is inconsistent with the
fundamental rights. The Directive Principles are so enforceable by the
courts nor can the courts declare as void any law which is otherwise
valid on the ground that it contravenes any of the directives"

In State of Madras v. Champakam Dorairajan, the Supreme Court

observed as follows:

"The Directive Principles of the State Policy, which by Article 37 are

expressly made unenforceable by Courts cannot override the
provisions found in Part III which, notwithstanding other provisions,
are expressly made enforceable by appropriate writs, orders or
directions under Article 32. The Chapter on Fundamental Rights is
sacrosanct and not liable to be abridged by legislative or executive act
or orders, except to the extent provided in the appropriate article in
Part III. The Directive Principles of State Policy have to conform and
to run as subsidiary to the chapter on Fundamental Rights In our
opinion that is the correct approach in which the provision found in
Parts III and IV have to be understood. However, so long as there is
no infringement of any fundamental right to the extent conferred by
the provisions in Part III, there can be no objection the State Acting in
accordance with the directive principles set out in part IV. but subject
again to the legislative and executive powers and limitations
conferred on the State under different provision."

22
In the case of State of Madras v. Champakam Dorairajan", it was held
that if any law is in contravention to the provisions mentioned in Part
III of the Constitution of India, it would be held void but this is not
applicable in case of Directive Principles of State Policy. This shows
that Fundamental rights are on higher pedestal than Directive
Principles of State Policy as far as this case is concerned.

In Re Kerala Education Bill the Court said that if a conflict arises

between Fundamental Right and Directive Principles of State Policies,
the harmony between the two should not be disturbed, but if, even
after applying the doctrines of interpretation the conflict doesn't
resolves then the former should be upheld and given more importance
over the other.

In I C Golaknath & Ors v. State of Punjah & Anr, the Court was of the
view that fundamental rights cannot be curtailed by the Parliament. In
Venkataraman v. State of Madras, the Court gave more importance to
the Fundamental Rights over Directive Principles of State Policy.

In the case of Minerva Mills v. Union of India", the Court while

deciding the case the majority observed that the bed rock of the
balance between Part III and Part IV. To give absolute primacy to one
over the other is to disturb the harmony of the Constitution which is
the essential feature of the basic structure. The goals set out in Part IV
have to be achieved without the abrogation of the means provided for
by Part III. To destroy the guarantees given by Part III in order to
achieve the goals of Part IV is plainly to subvert the constitution. Both
are complementary to each other and they should be balanced for the
proper functioning of the State.
In Unni Krishnan v. State of A.P, the Supreme Court has reiterated the
same principle. that the fundamental rights and directive principles of
state policy are supplementary and complementary to each other.

23
In the instant case, Maratha Animal Preservation (Amendment) Act,
1995 failed to maintain the balance between the Fundamental Rights
and Directive Principles of State Policy. For the implementation of
directive principle laid down in Article 48, the impugned statute has
violated the fundamental rights guaranteed under article 19 (1) (g) and
21 of the Constitution.
The impugned statute violates the freedom of trade and commerce
secured under Art 301 of the constitution of Republic of Indica

C.L. The impugned statute is unconstitutional, ultra vires and void.

The freedom declared by Art 301 maybe defined as a right to free

movement of persons of thingy, tangible or intangible, commercial or
non-commercial, unobstructed by barriers. inter-state or intra-state or
any other impediments operating as such barriers. The object of this
article is to break down the border barriers between the constituent
states and to make the entire territory of the country as one unit with a
view to encouraging trade and commerce in the country.

In the instant case, the prohibitions imposed by the Maratha Animal

Preservation (Amendment) Act, 1995 on import and export of Cows,
Bulls or Bullocks as well as sale. purchase and disposal of them for
the purpose of slaughter is in contravention of Art 301 of the
constitution. So the impugned statute is unconstitutional, ultra vires
and void.

In Kala Miah and others v. SC Roy and others, it was held that since
the bill restricts the transport of cattle for slaughter within and outside
the state, it clearly violates the provisions of Art 301 of the
constitution and thus it is ultra vires,
24
PRAYER

Wherefore in the light of the issues raised, arguments advanced and

authorities cited the Petitioner most humbly and respectfully pray that
this Hon'ble High Court may kindly adjudge and declare that:

A. THE WRIT PETITION BEFORE THE HON'BLE HIGH COURT

OF STATE OF MARATHA IS MAINTAINABLE

B. THE MARATHA ANIMAL PRESERVATION (AMENDMENT)

ACT, 1995 IS ULTRAVIRES THE CONSTITUTION OF THE
REPUBLIC OF INDICA

C.THE AMENDMENT ACT OF 1995 VIOLATES THE

FUNDAMENTAL RIGHTS OF CITIZENS OF INDICA
GUARANTEED UNDER ARTICLE 19 (1)(g) AND 21 OF THE
CONSTITUTION OF THE REPUBLIC OF INDICA

D.THE AMENDMENT ACT OF 1995 IS VIOLATIVE OF ARTICLE

301 OF THE CONSTITUTION OF THE REPUBLIC OF INDICA
And may kindly pass any order that this Hon'ble High Court may
deem fit. And for this act of kindness the Counsel for the Petitioner
shall in duty bound for ever pray.

Date:
Counsel for Petitioner
Place:

25