TC:R127

THE 3rd DME NATIONAL MOOT COURT COMPETITION 2019

Before

THE HON’BLE SUPREME COURT OF

PISHACHU
Filed under ARTICLE 32(2) of the Constitution of India

HUMAN SOUL & Others …Petitioner

V.

STATE OF ALOKAM & Others …Respondent

Humbly submitted by the

Counsels appearing on the
behalf of the Respondent

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 TABLE OF CONTENTS

1. Statement of Jurisdiction……………………………………Page 3

2. Summary of Arguments………………………………..…...Page 4-5

3. Arguments Advanced………………………………………Page 6-18
1) Whether the implementation of 15% reservation for Economically Backward Classes
(EBC) by the Central Government is unconstitutional?
2) Whether the restrictions imposed by the University curbs the rights of free speech and
expression?
3) Whether the State Government can be held liable for their failure to discharge
constitutional duties?
4) Whether the arrest and criminal charges brought against the individual student and the
professor is justified?

4. Prayer………………………………………………………Page 19

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 STATEMENT OF JURISDICTION
The counsel humbly submits to the Remedies for enforcement of rights conferred by this part of
the supreme court under article 32(2) of the Constitution of India. This article states that-

The Supreme Court shall have power to issue directions or orders or writs, including writs in the
nature of habeas corpus, mandamus, prohibition, quo warranto and certiorari, whichever may be
appropriate, for the enforcement of any of the rights conferred by this Part.

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 SUMMARY OF ARGUMENTS

1. Whether the implementation of 15% reservation for Economically Backward Class

(EBC) by the Central Government is unconstitutional?

This argument completely focuses upon Whether the implementation of 15% reservation
for Economically Backward Class (EBC) by the Central Government is unconstitutional.
The counsel will clear with these sections in furtherance under advance argument.
Focusing on all the above mentioned points, the counsel submits that this appeal should
be valid in the court of law.

2. Whether the restriction imposed by the university curbs the rights of free speech
and expression?

This argument completely focuses upon Whether the restriction imposed by the
university curbs the rights of free speech and expression. The counsel will clear with
these sections in furtherance under advance argument. Focusing on all the above
mentioned points, the counsel submits that this appeal should be valid in the court of
law.

3. Whether the State government can be held liable for their failure to discharge
constitutional duties?

This argument completely focuses upon Whether the State government can be held liable
for their failure to discharge constitutional duties The counsel will clear with these
sections in furtherance under advance argument. Focusing on all the above mentioned
points, the counsel submits that this appeal should not be valid in the court of law.

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4. Whether the arrest and criminal charges brought against the individual student and
the professor is justified?

This argument completely focuses upon Whether the arrest and criminal charges briught
against the individual student and professor is justified.The counsel will clear with these
sections in furtherance under advance argument. Focusing on all the above mentioned
points, the counsel submits that this appeal should be valid in the court of law.

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 Arguments ADVANCED

1.Whether the implementation of 15% reservation for Economically Backward Class

(EBC) by the Central Government is unconstitutional?

No, the implementation for Economically Backward class was not unconstitutional because
government can enact or present any policy which is helping the different class of the society to
change there standard of living or to uplift them. Here the government is giving 15% reservation
to economically backward class. here government is not involoving any caste and providing the
reservation to the sect that is economically backward.

Government has earlier provided reservation to SEBC but it is nowhere written that government
cannot make policies for the upliftment of the society.

As it is clearly mentioned in article 15(3) nothing in this article shall prevent the state from
making any special provision for women and children

CASE: State of Madras v. Smt. Champakan Dorairajan1

In the case by virtue of certain orders issued prior to coming into force of the Constitution,
popularly known as ‘Communal G.O.’ seats were apportioned in the Medical and Engineering
Colleges in the State of Madras.

Even after the advent of the Constitution, the G.O. was being acted upon which was challenged
by the Respondent as violative of the fundamental rights guaranteed to her by Articles 15(1) and
29(2) of the Constitution of India.

A Special Bench of Seven Judges heard the matter and came to the unanimous conclusion that
the allocation of seats in the manner aforesaid is violative of Articles 15(1) and 29(2) inasmuch

1
[1951] S.C.R. 525

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as the refusal to admit the respondent notwithstanding her higher marks, was based only on the
ground of caste.

The Supreme Court in the case pointed out that while in the case of employment under the State,
Article 16(4) provides for reservations in favour of backward class of citizens, no such provision
was made in Article 15.

Pursuant to Supreme Court’s order in the case the Parliament intervened amended Article 15 by
inserting Clause (4), which reads:

Nothing in this article or in clause (2) of article 29 shall prevent the State from making any
special provision for the advancement of any socially and educationally backward classes of
citizens or for the Scheduled Castes and the Scheduled Tribes.

CASE:M.R Balaji And Others v. State Of Mysore And Others 2 Article 15(4). Article 15(4)
authorises the State to make any special provision for the advancement of the Backward Classes
of citizens or for the ...improvement special provision is contemplated by Article15(4)
are in the matter of there backwardness comparable to Scheduled Castes and Scheduled Tribes.
...Government proceeded to make its impugned order. 17. Article 15(4) provides that nothing in
this article or in clause (2) of article 29 shall prevent

CASE: S.A Partha v. State Of Mysore And Others…

of Article 29 shall prevent the State from making any special provision for the advancement of
any socially and educationally backward classes of citizens or for the Scheduled Castes ...that
part of reservation in favour of Scheduled Castes and Scheduled Tribes not actually taken up
by the latter. This, it is contended, will amount to a clear infringement of fundamental ...cent of
the total population of the State excluding the Scheduled Castes and Scheduled Tribes.

CASE: V. Raghuramulu And Another v. State Of Andhra Pradesh And Another

2
1963 AIR 649, 1962 SCR Supl. (1) 439

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Arts. 15 and 29 of the Constitution of India. The respondent issued an order prescribing a scheme
for the selection of candidates for the Medical Colleges in the.Article 29:(2) No citizen shall be
denied admission into any educational institution maintained by the State or receiving aid out of
State funds of grounds only o...religion, race, caste, language or any of them.

2.Whether the restrictions imposed by the University curbs the rights of free speech and
expression?

Restriction imposed by university authority will not come in the meaning of curb the right of free
speech and expression as prescribed in Article 19 (1) (a) if Indian constitution but university
authority rightly directed to organize the cultural event that was participated by student and
professor but it was specifically stated that there should be no discussion on current reservation
policy given by central government.

University authority discharges his duty under the provision of Article 19 (2) and no illegality
has been done by the university authority because maintains of peace and normality of campus of
the university is aduty of university authority as such university authority rightly discharges his
duty. Since Kalikrati University (Central University) and it is an autonomous institution and it
has power and duty to frame rules and regulations to maintain peace in campus and also maintain
a studious atmosphere in the university campus and university authority also imposed restriction
which was a reasonable restriction in the interest of student and university.

Imposing of restrictions on cultural events was looking aggressive atmosphere of the student and
people against the imposition of 15% reservation of Economically Backward Classes (EBC)
weaker section by the Central government which in the criteria of 19(2) of the constitution of
India.

However, Article 19(2) of the Constitution provides that this right is not absolute and ‘reasonable
restrictions’ may be imposed on the exercise of this right for certain purposes. The right to
freedom of expression includes the right to express one's views and opinions on any issue and
through any medium whether it be in writing or by word of mouth.

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According to our constitution freedom of speech is subject to permissible restrictions under
Article 19(2) of the Constitution. The SC has ruled this fact, time and again, thro’ no. of judicial
pronouncements.

The Restriction imposed by the University is valid under Article19 (2) of the Indian constitution.

It is necessary to maintain and preserve freedom of speech and expression in a democracy, so

also it is necessary to place some restrictions on this freedom for the maintenance of social order
because no freedom can be absolute or completely unrestricted. Accordingly, under Article 19(2)
of the Constitution of India, the State may make a law imposing “reasonable restrictions” on the
exercise of the right to freedom of speech and expression “in the interest of” the public on the
following grounds: Clause (2) of Article 19 of the Indian constitution contains the grounds on
which restrictions on the freedom of speech and expression can be imposed:-

a) Sovereignty and integrity of India.

b) Security of the state

c) Friendly Relations with the Foreign States.

d) Public Order

e) Decency or Morality

f) Contempt of court

g) Defamation

h) Incitement of an offense

The restriction which may be imposed under any of the clauses must be Reasonable restriction.
The restriction cannot be Arbitrary.

The restriction imposed by the university can be a valid restriction that falls under Article 19 (2)
of the Indian constitution. the restriction satisfied the following two condition i.e (a) the
restriction must be for the purpose mentioned in clause 2 to 6 of Article 19 ; (b) the restriction
must be a reasonable restriction.

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The freedom of speech and expression are however not absolute . Absolute individual rights
scannot be guaranteed by any modern state. An organized society is a precondition of civil
liberties. There cannot be any right which is injurious to the community as a whole. If people
were given complete and absolute liberty without any social control the result would be ruined.
Liberty has got to be limited in order to be effectively possessed. For liberty of one must not
offend the liberty of others. Patanjali Shastri, j., in A.K.Gopalan’s case, observed, “man as a
rational being desire to do many things, but in a civil society his desire has to be controlled,
regulated and reconciled with the exercise of similar desires by other individuals”.

The Supreme Court has lucidly explained the effect of the clause “in the interest of’ in

CASE: O.K. Ghosh vs. E.X. Joseph “This clause again cannot be interpreted to mean that even
if the connection between the restriction and the public order is remote and indirect, the
restriction can be said to be in the interests of public order. A restriction can be said to be in the
interests of public order only if the connection between the restriction and the public order is
proximate and direct.

CASE: Ramesh Thapper vs. State of Madras , the Supreme Court has occasion to interpret the
meaning of the words ‘security of the State’. The Court said that there are different grades of
offenses against ‘public order’. Every public disorder cannot amount to be regarded as
threatening the security of the State. The term ‘security of the State’ refers only to serious and
aggravated forms of the public disorder, e.g., rebellion, waging war against the State,
insurrection and not ordinary breaches of public order and public safety, e.g., unlawful assembly,
riot, affray. Thus speeches or expression on the part of an individual which incite to or encourage
the commission of violent crimes, such as, murder are matters which would undermine the
security of the State

CASE: Virendra v. State of Punjab in this case the constitutional validity of the Punjab
Special Powers (Press) Act 1956, was at stake. The law was enacted to prevent and combat any
activity prejudicial to the maintenance of communal harmony which was in jeopardy in the State
of Punjab as a result of serious tension between the Hindus and the Akalis. Sec. 2(1) (a) of the
Act empowered the State Government or any named authority to issue an order to a printer,
publisher or editor prohibiting the printing or publishing of any matter in any document or class

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of documents relating to a particular subject or class of subjects for a specified period or in a
particular issue or issues of a newspaper or periodical for the purpose of preventing and
combating any activity prejudicial to the maintenance of communal harmony affecting or likely
to affect public order.

Kedar Nath v. State of Bihar, the Court looks the position that when a provision of law is
capable of two interpretations, one of which makes it constitutional and the other
unconstitutional, the inter¬pretation which makes it constitutional should be preferred.
Accordingly, the Court ruled that mere criticism of government action, however strongly
worded, would be consistent with the Fundamental Right of freedom of speech and expression.
Only the words having the per¬nicious tendency, or intended to create a disturbance of law and
order would be penal in the interests of public order.

CASE: Kedar Nath v. State of Bihar, the Supreme Court held that Sec. 124-A was limited to
acts involving an intention or a tendency to create disorder or disturbance of law and order or
incitement to violence and was not violative of Art. 19(1)(a) read with Art. 19(2).

CASE: Niharendra vs. Emperor, the Federal Court held that mere criticism or even ridicule of
the Government was no offence unless it was calculated to undermine respect for the
Government in such a way as to make people cease to obey it an obey the law so that only
anarchy can follow. Public disorder is the gist of the offense. But the Privy Council overruled
this decision and held that the offense of sedition was not confined to only incitement to violence
or disorder.

3.Whether the state government can be held liable for their failure to discharge
constitutional duties?

No , the state government cannot held liable for their failure to discharge constitutional duties.
State is legally bound to maintain peace and normalcy among the people of state, and the state
government rightly discharge his legal duty to maintain law and order when march moving
towards the venue of event for protesting against the reservation policy imposed by the

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government. In between a girl name RIKA who is also protesting against policy of reservation

was molested and touched badly The same was also reported to the nearest police station which
led to the immediate arrest of REMO and RIKA along with a few others for offences under the
Penal Code of the Country for provoking citizens against the Government.
In a federal form of government, the state government is the government of a country’s
subdivisions and shares political power with the national government.

Roles and Responsibilities of the state governments

State governments have separate departments for proper functioning of the state. States have
jurisdiction over education, agriculture, public health, sanitation, hospitals and dispensaries and
many other departments.
Internal security: The state governments have to maintain the internal security, law and
order in the state. Internal security is managed through state police.
Public order: States have jurisdiction over police and public order
Education: Providing a public education system, maintaining school buildings and
colleges, employment of teachers, providing help to under privileged students all come
under the education department of the state.
The situation is very critical and sensitive and difficult to control the situation because the
agitation was become very aggressive therefore state government took very careful steps which
led to the arrest of REMO and RIKA along with a few others for offences under the Penal Code
of the Country for provoking citizens against the Government.
State government regularly made best effort to control the situation of protest which was become
very aggressive because after death of SHEILIA did, many other student unions at different
colleges came up protesting within ALOKAM and fifteen more suicides took place within a
week. RAHU along with his three friends AMKUL, VINASH and AVISHESH who were also
sitting with RAHU were arrested for abetment of suicide in all the cases. State government also
took very strong step by arresting Dr. BIJYUE he was also arrested under the charge of
abetment, sedition and criminal conspiracy for being a member of the same party to which some

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of the student protesters belonged. As such state government discharge his duty with full
devotion and no any deliberate mistake and negligence was committed on behalf of state
government in respect of protest done by student.
CASE: S.R Bommai And Others v. Union Of India And Others3
destructive of the constitutional philosophy as such functioning can never be in accordance with
the provisionsof the Constitution. But where a State Government is functioning in accordance
with, the President gives no prior warning or opportunity to the State Government to correct
itself. Such awarning can be dispensed with only in cases of extreme urgency where failure on
the Constitution or for its inability to discharge its basic constitutional duties and functions due
to political or economic crises which have led to complete paralysing ofthe State
Administration..

Constitutional Functions The learned judges in the

CASE: Bangalore Water Sevwerage Board v. A. Rajappa4 ,
the following observation by the Court in

CASE: Nagendra Rao and Co. v. The State of Andhra Pradesh5 ,

as to which function could be, and should be, took as regal or sovereign function. It
has been recently examined by the Bench of the Court, where in the words of Hansaria. J, the
old and archaic concept of sovereignty does not survive as sovereignty now vests in the people.
Looking overall position and facts and circumstances of the entire incident state government
done his duty with full devotion an no any dereliction was done on behalf of state government.

3
1994 AIR 1918, 1994 SCC (3)
.
4
1978 2 SCC 213

5
1994 AIR 2663, 1994 SCC (6) 205

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 4. Whether the arrest and criminal charges brought against the individual student and
the professor is justified?

Your lordship please read the 3rd line of 1st paragraph of 2nd page of preposition it was given that
“Rika who was protesting against the policy of reservation against the government” here Rika is
protesting where the march is going on protesting against the current reservation policy of the
government established by law in india and the according to the media reports also. the protest
was running with anti-national posters, slogans, and the quotes containing wording of a terrorist
julinialani which was seditious and enough to provoke citizens against the government
established by law in india a which was liable for Sedition under section 124 A of indian penal
codewhich states that “Whoever, by words, either spoken or written, or by signs, or by visible
representation, or otherwise, brings or attempts to to bring into hatred or contempt, or excites or
attempts to excites disaffection towards, the government established by law in (India), shall be
punished with (imprisonment for life), to which fine ,may be added, or with fine”and Rika is the
part of that assembly which is unlawful , they have a common object to resist the execution of
any law, or of any legal prrocess under section 141 of clause second .an unlawful assembly is
“An assembly of five or more persons is designated an unlawful assembly, if the common object
of the persons composing that assembly is based on there five conditions . So, and being the
part of an unlawful assembly Rika is laible for sedition under section 124A of IPC due to a
member of an unlawful assembly under section 149 which states that – If an offence is
committed by any member of an unlawful assembly in prosecution of the common object of that
assembly ,or such as the member of that assembly, or such as the members of that assembly
knew to be likely to be committed in prosecution of that object , every person who, at the time of
the committing of that offence , is a member of the same assembly, is guilty of that offence. Any
act within the meaning of section 124A which has the effect of subervating the government into
contempt or hatred or creating disaffection against it would be within the penal statute because
the feeling of disloyalty to the government established by law or enmity to it imports the idea of
tendency to public disorder by the use of actual violence or incitement to offence.

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-Your lordship Remo is guilty under sedition of section 124A for common intention under
section 34 of indian penal code, because as we can see the facts remo is the leader of youth
wing of kheyo kheyo party,which is in opposition in centre. and we can consider this that no
opposition want the welfare of the rulling party. as remo was also organizing the cultural
program for the discussion of policies of current government, if he want to oraganize a cultural
event for discussing policies of current government in which the current reservation was also
come and discuss , people in all over india knows that a current reservation policy is a sensitive
matter and caused civil disturbance on a very high level and remo want to discuss about
policies only after these problem facing by the country , infact after college give the permission
for cultural event but restrain to discuss about the current reservation policy because this a
sensitive matter , remo questioned why he was not permit to discuss about current reservation
policy after knowing the issues sensitiveness. please note this point after knowing the prone
condition of the nation that how much sensitive is the nation regarding the reservation policies,
still he raised a question. and when remo is organizing the cultural program than he has to keep
a check on the surrounding environment like keep a check on security, time-management etc
.when the march was start from the hostel consisting students, professors, and some
unauthorized people which was not authorized by hostel authorities as given in facts and going
towards the venue how is it possible that some unauthorized people also joined the group, in
the hostel in the campus. college authority is already been conscious that not to promote any
type of thig related to current reservation policy so as we can see that the college authority not
allow to Remo to discuss about the reservation policy of current government so why the college
authority allow the unauthorised people as they were enough conscious for that. so how these
unauthorized people entered the college hostel , and also your lordship the council would like
to clear that the unauthorized people come on the march is not a coincident and sudden
because they have anti national posters and slogans and quotes containing the words of a
terrorist , so the unauthorised people get include in the march is a part of a previously
planning and with the same intention they criticized the nation and government established by
law in india . so my lordship the council would like state that for the entry of unauthorized
people in the hostel of the campus and the people who joined the march in the middle way of
the venue , there is a requirement of information like the time of march ,the way of reaching
the venue and many other information and also need a person who help unathorised people to

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enter in hostel . so these things clealy states that remo is person who helped the unauthorise
people to enter in hostel and the people who joined the march in the middle way of the venue.
And thus, liable for sedition under section 124A of IPC due to member of a party in criminal act
with common intention which states that”when a criminal act is done by several persons in
furtherance of the common intention of all, each of such persons is liable for that act in the
same manner as if it wete done by him alone”.

Remo and rika is also liable for waging war against government of India which was given under
section 125 of ipc in which it was defined that whoever commits depredation, on the territories
of any power in alliance or at peace with the Governmemt of India.

4.1 Rahu and along with his three friends and Dr.bijyue is liable for arrest and
criminal charges brought against them?

A girl Sheila who was not active in any student political party is protesting against the
reservation policy , threatened the authorities and police that she would burn herself if if the
reservation policy on EBC is not taken back . it was come under threatened to commit suicide.
Rahu a friend of Remo along with his friends to protest,he pored kerosene himself and tookout a
match in his hand and threatened that he would also join Sheila if the demand were not fulfill in
next three days, he along with his friends is liable for threaten to commit suicide.

Now, on the third day when demand is not fulfill Sheila is burnt herself. But rahu can’t . He still
threat the authorities to sit with a matchstick to burn himself like Sheila and also gave a speech to
diffent media houses, now here,

Rahu can’t burnt himself and give speech to different media house . due to this provocation 15
more suicides took place and rahu can’t do suicide and still sit with their friends. Mow rahu
along with his friends is laible to abetment of suicide .because Sheila suicided but he can’t burn
himself and give a speech on media which abets the people to commit suicide and 15 more
suicide is taken place.and he still protesting by threating authority to commit suicide. Abetment
suicide is comes under section 306 of IPC which says if any person commits suicide,

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whoever abets the commsion of such suicide, shall be punished with imprisonment of either
description for term which may extend to ten years, and shall also be laible to fine.and the three
friends of Rahu Amkul.Vinash,Avishesh is also laible to abetment of suicide due to common
intention unde section 34 of IPC which says when a criminal act is done by several persons in
furtherance of the common intention of all, each of sych persons is laible for that act in the same
manner as if it were done by him alone.
Dr. Bijiyue gives a speech on media which was abeting and seditious and he was guilty for the
offence of abetment which was define under section 107 of IPC and for sedition which was
define under section 124A of IPC . when Sheila and Rahu along with his friends is threaten the
authority to commit suicide as per the facts then Dr.Bijue supporting the illegal act of these
students on media. After that the 15 more suicides was taken place. Dr.Bijue is also laible for
abetment to suicide for that 15 more suicides which is deifine under section 306 of IPC which
says if any person commits suicide, whoever abets the commission of such suicide, shall be
punished with imprisonment of either description for a term which may extend to ten years, shall
also be liable to fine. Dr. Bijue is here also liable for criminal conspiracy of section 120A of IPC
for being the member of the same party to which some of the student professors belonged who
was involve in the protest which was going happen with the anti national posters, slogans and
provoking the citizens, because they for the common intention under section 34 of IPC which

says when a crimanl act is done by several persons in furtherance of the common intention of all,
each of such persons is liable for that act in the same manner as if it were done by him alone.
Charges of abetment to suicide cannot be leveled if a "person of weak
mentality"names
somebody in his suicide note but a subsequent investigation fails to establish the accused
person's guilt, the Punjab and Haryana High Court has ruled.
Allowing a Petition filed by six accused, Justice P.B. Bajanthri explained, "Merely because
a person has been so named in the suicide note one cannot immediately jump to the conclusion
that he is an offender under Section 306 I.P.C. The contents of the suicide note and other
attending circumstances have to be examined to find out whether it is abetment within the
meaning of Section 306 I.P.C. read with Section 107 I.P.C."

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The Judge in fact went on to assert that another person cannot be blamed "for the wrong
decision
taken by a coward, fool, idiot, a man of weak mentality, a man of frail mentality".
Case: Sanju alias Sanjay Singh v. State of Madhya Pradesh
in the case the Apex Court quashed the charge sheet for offence under Section 306 of IPC to
hold that the words uttered in a quarrel or on the spur of moment, such as “to go and die” cannot
be taken to be uttered with mens rea. It is in a fit of anger or emotion.
Case: S.S. Chheena vs. Vijay Kumar Mahajan and another
In this case, the Supreme Court made some remarkable observations on law pertaining to
abetment of suicide under Section 306 of IPC. The Court ruled that:
Abetment involves a mental process of instigating a person or intentionally aiding a person in
doing of a thing.
Without a positive act on the part of the accused to instigate or aid in committing suicide,
conviction cannot be sustained.
There has to be a clear mens rea to commit the offence.
It also requires an active act or direct act which led the deceased to
commit suicide seeing no option and that act must have been intended
to push the deceased into such a position that he committed suicide.

CASE: State of W.B. Vs. Orilal Jaiswal

The Supreme Court in the case observed that the courts should be extremely careful in assessing
the facts and circumstances of each case and the evidence adduced in the trial for the purpose of
finding whether the cruelty meted out to the victim had in fact induced her to end the life by
committing suicide. If it transpires to the court that a victim committing suicide was
hypersensitive to ordinary petulance, discord and differences in domestic life quite common to
the society to which the victim belonged and such petulance, discord and differences were not
expected to induce a similarly circumstanced individual in a given society to commit suicide, the
conscience of the court should not be satisfied for basing a finding that the accused charged of
abetting the offence of suicide should be found guilty.

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 PRAYER

Wherefore, in the light of facts stated, issues raised, arguments advanced and authorities cited,
the counsel humbly pleads before your lordship to dismiss this appeal and declare that:
1. The implementation of 15% reservation for Economically Backward Classes (EBC) by
the Central Government is constitutional.
2. The restrictions imposed by the University is not curbing the rights of free speech and
expression
3. The State Government is not held liable for their failure to discharge constitutional duties
4. The arrest and criminal charges brought against the individual student and the professor
is justified

And pass any order that this Hon’ble High Court may deem fit in interest of Equality,
justice and Good Conscience.

Sd/-

(Humbly submitted by the counsels

appearing on behalf of the

Respondent)

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