BEFORE THE HON’BLE SUPREME

COURT OF CAMELOT

SPECIAL LEAVE PETITION NO.*****/2019

UNDER THE ARTICLE 136 OF THE CONSTITUTION OF CAMELOT, 1947

IN THE MATTER OF

THE GOVERNMENT OF EREHWON………………………. APPELLANT

VS

ELIZABETH BENNET………………………………………….RESPONDENT

MEMORIAL ON BEHALF OF APPELLANT

 TABLE OF CONTENTS

LIST OF ABBREVIATIONS………………………………………………………………………

INDEX OF AUTHORITIES…………………………………………………………….………….

STATEMENT OF JURISDICTION………………………………………………..………………

STATEMENT OF FACTS………………………………………………………..………………..

STATEMENT OF ISSUES…………………………………………………...……………………

SUMMARY OF ARGUMENTS………………………………………...…………………………

ARGUMENTS ADVANCED……………………………………………………………………...
 LIST OF ABBREVIATIONS

Govt . - Government
IPC - Indian Penal Code
Const. -Constitution
Vs - Versus
Pp - Papers
SC - Supreme court
INDEX OF AUTHORITIES
 STATEMENT OF JURISDICTION

The appellant has the honor to submit this memorandum on

behalf to this Hon’ble Supreme court of Camelot, under of the
Constitution of Camelot.
The Hon’ble Supreme Court has the jurisdiction to adjudicate
the present matter.
 STATEMENT OF FACTS

1) The assembly elections of Erehwon were held in April, 2015 and were won
by the Crouching Tiger party and the general elections of Camelot were held
on March,2014 which were won by the Vanity Fair party. The relationship
between the leaders of these three political parties was not cordial on
account of personal ideological differences.

2) The Hogwarts Party is a largely student-dominated Party under the

leadership of Ms. Elizabeth Bennet. Ms. Bennet was successful in the
elections of Camelot and was elected a Member of Parliament.

3) Ms. Bennet in April 2016 started a campaign to strike a chord with the
young citizens of Camelot under the banner of Dawn of Justice. This
movement analyzed good qualities of various developing and developed
countries, with a view to imbibing those qualities in the Camelot way of life,
for the betterment of its citizens. However, when certain good qualities of
Genghiztan were publicly listed by Ms. Bennet at press conference in
Erehwon, it caused a political uproar in the country. Ms. Bennet, however,
stuck to her stand and soon posted a selfie of herself on twitter with the flag
of Genghiztan in the background and a globe in her hand. She also tweeted,
“we have a rich and unique geo-political history and our principles demand
that we treat other countries with respect and non-aggression’.

4) This photograph of Ms. Bennet enraged some people in Camelot and began
a debate on the extent to which such activities could be tolerated, Mr. K.F.
Panda, the chief minister of Erehwon, took exception to these actions of Ms.
Bennet, and demanded a public apology. And as a response to a tweet made
by Mr. K.F Panda in early May 2015,Ms. Bennet an the Hogwarts Party
reacted to this by starting a new campaign ‘Mock and shame the Pseudo-
Nationalist Government’ in late May,2015. It was recorded that, A
 supporter of Ms. Bennet called the current government of Erehwon as well
as Camelot ‘a bunch of useless war-mongers seeking to cover up their incept
governance under a charade of pseudo-nationalism’. When Ms. Bennet was
confronted with the statement, she said she supported the sentiment
underlying the remark.

5) On 01 June 2015, Ms. Bennet subsequently called a public rally, in the

famous grounds of Erehwon and gave a speech, in which she was quoted
saying,

a) “the government that has come to power has got drunk on its new-found
power. it has taken upon itself to wreak vengeance on anybody who
holds an opinion against it. We have no choice but to strike at the very
root of this evil and effectuate a fundamental overhaul.”
b) “We must rise in rebellion against these dirty leeches on our mind and its
thinking process. These corrupt people who have sold our country now
want us to pawn our minds. This will not happen, brothers and sisters!
Together we will overthrow the government! Break the government to
pieces, if it need be, to uphold the ideals contained in our beloved
constitution. We will be the divine destruction which shall vaporize the
deep seated rot and ensure our beloved country has a more refreshing
start! I am ready to lay down my life for you my beloved fatherland! Are
you ready too?”
6) The rally was attended by 30,000 people, including about 3000 party
members of the Hogwarts party. Soon thereafter the members of the
Hogwarts party mobilized the public to protest against the outlook and
demeanor of the current government, some shouted slogans while some
attacked, destroyed an burned public property.

7) From 02 June to 03 June 2015,almost 2,00,000 people gathered near the

Parliament of Camelot and near the iconic Camelot Gate. Thousands of
people including members of the Hogwarts party, visited the officials of the
government, by tracking government quarters in Erehwon, and ‘gifted’ them
teddy bear toys and asked them to play with them in view of their naïve and
childish support for the current government of Erehwon.
8) 0n 05 June 2015, Me. K. F Panda at a press conference said, “when the
unity and the integrity of the country is so carelessly thrown into the winds,
when the bravery of the armed forces and their families is so mercilessly
rendered pointless, and when the international policy is rendered to slavish
pandering, we cannot sit and watch idly by.

9) On 05 June 2015 a First Information Report, bearing crime no. AB-1331-

2015 was registered and a complaint under section 421-A/ 351-A/ and 210-B
was filed against Ms. Bennet and other unknown persons. For which the
approval was given under section 196 of the Camelot Criminal Procedure
Statute by the Government of Erehwon in the name of the Lieutenant
Governor to prosecute Ms. Bennet for the offence of sedition under section
421-A and 351-A of the penal code.
The final report was filed against Ms. Bennet, Mr. fun Toosh and Mr.
Rebello Gonsalves, and the magistrate took cognizance and issued summons
to all the accused. The trial was subsequently conducted, and all the accused
were held guilty for the offences under section 421-A/ 351-A/ and 210-B of
the Penal Code of Camelot. Ms. Bennet was awarded the death sentence
under section 421-A of the Penal code.

10) Ms. Bennet appealed against the said judgement before the High
Court of Erehwon, and was acquitted of all charges.

11) The State of Erehwon preferred an appeal before the Supreme Court of
Camelot by way of Petition by Special Leave, seeking reversal of the
acquittal and imposition of the death sentence. Leave was granted in the
Petition by Special Leave, henceforth the following submissions are
presented by the Counsel for the State on behalf of the complainan t.
 STATEMENT OF ISSUES

1) Whether the Death sentence as sought by the government of Erehwon is an

appropriate punishment for the offence of sedition as made out by the facts
of the present case?

a) That Miss. Bennet’s actions amount to sedition as per sec 421-A of the
Penal Code of Camelot, and is she punishable under the same.

b) That there was requisite Mens-Rea on the part of Miss. Bennet.

c) That there was requisite Actus- Reus on the part of Miss. Bennet.

2) Without prejudice to the above, whether the offences under sections 421-A/
351-A/ 210-B of the Penal Code of Camelot have been made out against Ms.
Elizabeth in the instant case.
 SUMMARY OF ARGUMENTS

1) Whether the Death sentence as sought by the government of Erehwon is

an appropriate punishment for the offence of sedition as made out by the
facts of the present case?

Sec 421-A of the Penal Code of Camelot, punishes anyone who brings or attempts
to bring into hatred or contempt, or excites or attempts to excite disaffection
towards the Government established by law in Camelot. with death or
imprisonment for life.

i) Miss. Elizabeth’s actions along with her intents are wrongful, prohibited,
and is punishable under law, as per sec 421-A of the Penal Code of
Camelot.
Miss. Elizabeth had undertaken a series of campaigns on her social media
account and public events, in which she has brought hatred, and excite
disaffection towards the Government established by law. The statements
she made, the material of pursuance are all centered around bringing
about radical changes by toppling the current government and also
preaches undemocratic and rebellious methods of achieving as such.

ii) There is requisite Mens-Rea on the part of Miss, Elizabeth Bennet.

Miss. Elizabeth had undertaken a series of campaigns which were pre-
determined for achieving its ultimate objective. Her active participation
on social media platforms and her popular public events, were pre-
meditated plans to incite hatred and disaffection towards the government
and her ultimate objective was to ignite a socio-political crisis in order to
destabilized the Governments of Erehwon as well as Camelot. Hence,
there was Mens-Rea on the part of Miss. Elizabeth in this case.

iii) There was Actus-Reus on the part of Miss, Elizabeth Bennet.

Miss. Elizabeth had posted wildly provocative and politically charged
posts on her social media accounts, which had spurred political tensions,
 and incited to her followers to hate and oppose the current governments.
She also made multiple public speeches which incites hatred and
disaffection towards the government. The actions she took, on different
platforms, forms the physical act of her offence and thus establishes
Actus-Reus on her part.

2) Without prejudice to the above, whether the offences under sections 421-
A/ 351-A/ 210-B of the Penal Code of Camelot have been made out
against Ms. Elizabeth in the instant case?.

A) 421-A of the Penal Code of Camelot, punishes anyone who brings or

attempts to bring into hatred or contempt, or excites or attempts to excite
disaffection towards the Government established by law in Camelot. with
death or imprisonment for life.

Miss Elizabeth Bennet as a prominent political figure had exploited her

popular position, to incite hatred and disaffection towards the government.
Through her neo-liberal approach of political campaigns, she had
accumulated massive followers, mostly the youths, and has steered them into
hating and opposing the current Governments, and had called upon to rebel
against the government. Such acts come under the definition of sec 421-A of
the penal code, of “ anyone who brings or attempts to bring into hatred or
contempt, or excites or attempts to excite disaffection towards the
Government established by law in Camelot.” and is punishable by death. As
her actions align with that of the prohibited acts under sec 421-A, the
charges against her under the same is maintainable.

B) Sec 351-A of the Penal Code of Camelot, punishes anyone who promote
enmity between different groups on grounds of religion, race, place of birth,
residence, languages, etc, and dong acts prejudicial to maintenance of
harmony.
Miss. Elizabeth’s political campaign is popular amongst the youths, with her
neo-liberal approach towards bringing about radical changes in the nation,
serves as an appealing promise towards the youths. But the statements she
 made, which resonates anti-nationalist propagandas, have lacerated the
national sentiments of many, with many other political figures criticizing her
statements. She has driven a wedge between her supporters, which are
oriented around her political party, i.e., the Hogwarts Party a student
dominated party, and other political parties and their supporters. Her
supporters held massive protest which later turned violent, causing damages
to public properties, protested by storming government official’s quarters,
and ‘gifted’ them teddy bear toys and asked them to play with them in view
of their naïve and childish support for the current government of Erehwon,
such actions are not acceptable as a lawful civilian protest. Her campaigns
are prejudicial to the maintenance of harmony, and she herself had called
upon for radical and rebellious movement against the government. Thus, her
actions promotes enmity between groups with different political ideologies,
incites violent methods to be used for their political struggle, hence her
actions aligns with those actions defined under sec 351-A, thus the charges
against her under the same is maintainable.

C) Sec 210-B of the Penal Code of Camelot, punishes anyone who is a party to
a criminal conspiracy to commit an offence punishable, with death,
imprisonment for life, or rigorous imprisonment for a term of two years or
upwards, as if the person had abetted such offence.
Miss. Elizabeth along with the members of her Political party, The Hogwarts
party, had constructed a well shrouded and elaborate plan of, inciting the
citizens, mostly the youths to hate and show disaffection towards the
government. The pre-meditated plans she and her political party undertook,
is prohibited under sec 421-A of the Penal Code of Camelot as “sedition”
and is punishable with death or imprisonment for life. As Miss. Elizabeth
herself has been in the forefront of these seditious campaigns, she along with
her political party had conspired to promote agendas which denounce the
current governments, calling for rebellious movements against the current
governments. Therefore, as a co-conspirator to the pre-meditated and pre-
determined seditious campaigns, the charges against her under sec 210-B is
maintainable.
 ARGUMENTS ADVANCED

ISSUE 1

Whether the Death sentence sought by the government of Erehwon is an

appropriate punishment for the offence of sedition as made out by the facts of the
present case?

Sec 421-A of the Penal Code of Camelot, punishes anyone who brings or attempts
to bring into hatred or contempt, or excites or attempts to excite disaffection
towards the Government established by law in Camelot. with death or
imprisonment for life.

A) Miss. Elizabeth’s series of actions along with her intents are wrongful,
prohibited, and is punishable under law, as per sec 421-A of the Penal Code
of Camelot.

Section 421-A reads as- whoever by words, either spoken or written, or by signs or
by visible representation, or otherwise,

(a) brings or attempts to bring into hatred or contempt, excites or attempts to

excite disaffection towards, the Government established by law in Camelot.
(b) or to show that the government has bee misled or mistaken in any of its
measures,
(c) excites any person attempt to procure in the territory of India, the alteration,
otherwise than by lawful means, of any matter as by law established.

shall be punishable with death or imprisonment for life, to which fine maybe
added.

The offence under S.421-A captioned as “Sedition” is closely considered to treason

– an offence against the state. Sedition in itself is a comprehensive term, and it
embraces all those practice, whether by word deed, or writing, which are calculated
to disturb the tranquility of the state, and lead ignorant persons to endeavor to
subvert the Government. The objects of sedition generally are to induce discontent
and insurrection, and stir up opposition to the government, and bring the
administration of justice into contempt; and the very tendency of sedition is to
incite the people into insurrection and rebellion.

Sedition was describes as by the court in the case of Nazir khan as:

“disloyalty in action, and the law considers as sedition all those practices which
have for their objective to excite discontent or dissatisfaction, to create public
disturbance, or to lead to civil war, to bring into hatred or contempt the
Government, and generally all endeavors to promote public dis-order.1”

Sedition was always included any series of actions or actions which incites violent
behavior of others, which results in harm or death of any other. This can be
understood when in close examination with the case of Bal G.Tilak, where the part
was charged with sedition for the instigation of violence amongst others which
ultimately led to the death two British officers. The colonial government filed a
case against the parties and also Tilak under the IPC, where Section 124A was
recognized and charged with.

“Incitement to violence and insurrection is existent in the eyes of the presiding

privy council in regards to the culpability of a person that’s been charged with
sedition.”

1 Nazir Khan v State Of Delhi, SC 2003-8-34

2 The queen empress v Bal Gangadar Tilak (1897)
In Balwant Sing V State of Punjab ,1995 case corresponding to sedition, it was
held that

“the application of this section would be attracted only when the accused brings or
attempts to bring into hatred or contempt, excites or attempts to excite disaffection
towards, the Government established by law in India, by words either written or
spoken or visible signs or representations etc.”

It is only when the words have the pernicious tendency or intention of creating
public disorder or disturbance of law and order that the law steps in. The
explanation to the section make it clear that criticism of public measures or
comment on government action, however strongly worded, within reasonable
limits and consistent with the fundamental right of freedom of speech and
expression is not affected.

For anyone to be charged under S.421-A, there are two ingredients which needs to
be satisfied :

1. Bringing or attempting to bring into hatred or contempt, excites or attempts

to excite disaffection towards, the Government established by law in
Camelot.
2. such act or attempt may be done
(i) by words, ether spoken or written or
(ii) by signs or
(iii) by visible representation.

In the case at hand, Miss. Elizabeth Bennet had undertaken a series of campaigns
on her social media account and public events, which has lacerated the national
sentiments for many citizens of this nation. It has spurred up political tension and
has brought her supporters to hate, and excite disaffection towards the Government
established by law, the threat of an impending socio-political crisis lurks in the
corner. The statements she made, the material of pursuance she made are all
centered around bringing about radical changes by toppling the current government
and also preaching undemocratic and rebellious methods of achieving as such, has
led to the developments of a series of protest and public disturbance, leaded by her
massive supporters of youth.
. Ms. Elizabeth Bennet presents herself as a bold, dynamic, popular female figure,
and is part of the reason why she is supported by our massive youth population,
she represents something “new”. She brings forward radical ideas for bringing
about a change in our nation. She has endorsed her personal list of qualities which
we can learn from Genzishtan, a Nation with whom our nation has had and still
has, a very volatile, and uncordial relation. The national sentiment, towards our
Army, the respect that we uphold for the soldiers that have died in armed-conflicts
with the nation which Ms. Bennet validates, are challenged by her statements and
actions.

When she was immensely criticized for the list she brought forward, by other
prominent pol. figures, she posted a photo on her twitter account, with the flag of
Genghiztan in the background and a globe in her hand. Such devious actions are
condemned by the current Government, and is a part of her unjustifiable plan of
directly berating the national sentiments and respect for our army many the
Government holds, calling it as pseudo-nationalism, and its supporters as “war-
mongers”, to ignite socio-political tensions, between the population, in this case
the youth population, and the current government established by law.

She had been quoted saying “We must rise in rebellion against these dirty leeches
on our mind and its thinking process. These corrupt people who have sold our
country now want us to pawn our minds. This will not happen, brothers and
sisters! Together we will overthrow the government! Break the government to
pieces, if it need be”,

In Kedar Nath V State of Bihar [1962], it was held that

“ it is only when the words have the pernicious tendency or intention of creating
public disorder or disturbance of law and order that the law steps in”

In the present case, the statements of Ms. Bennet ,the words which she had written
on her social media posts, indeed has the pernicious tendency or intention of
creating public disorder, which is evident by the fact that it already has caused
socio-political tension and public disturbances and loss of public properties.

It is the humble appeal by this counsel, that Ms. Bennet through constructive and
intelligent methods of weaving words, to have a double face, and her neo-liberal
agendas has persuaded the youths of this nation into supporting her blindly, and
she as a prominent political figure, had wrongly used her position to induce her
supporters into hating and opposing their own Government. Very often, the
demarcating line between political criticism of the Government and those causing
disaffection against the government is thin and waiving. In the case at hand the
statements made by Ms. Bennet is sugar-coated to be appealing towards our young
and energetic youth population, but underneath all those facade, her pre-
determined objectives are skillfully hidden. Statements such as :-

“ the government that has come to power has got drunk on its new-found power. it
has taken upon itself to wreak vengeance on anybody who holds an opinion against
it. We have no choice but to strike at the very root of this evil and effectuate a
fundamental overhaul.”

“We must rise in rebellion against these dirty leeches on our mind and its thinking
process”,“Together we will overthrow the government!”.

“We will be the divine destruction which shall vaporize the deep seated rot and
ensure our beloved country has a more refreshing start! I am ready to lay down my
life for you my beloved fatherland! Are you ready too?”

are directly denouncing the present Government, giving the government a

character which is evil in its nature and arbitrary in exercise of its power. The line
of political opposition, political criticisms are well within Art 19 (1) of the
Constitution of Camelot. but her statements calls upon her massive supporters, to
rebel against the current Government, to overthrow the Government, by any means
necessary and her devotion to such a cause goes as far as giving up her life for it,
and calls for her supporters to do the same. These statements goes beyond the
acceptable political criticism and is aimed at igniting a socio-political crisis, in an
attempt to destabilize the present Government.

The Appellants humbly submits that such statements brings hatred and exciting
disaffection towards the present government. As the gist of the offence of sedition
is incitement to violence1, which the actions and the statements of the accused has
satisfied, it is as per the acceptable law of S.421-A of the Penal code that Ms.
Bennet is punished with the death sentence, as previously held by the verdict of the
magistrate court.
 B) There is requisite Mens-Rea on the part of Miss, Elizabeth Bennet.

Mens-Rea, isthe intention or knowledge of that constitutes part of a crime, as

opposed to the action or conduct of the accused. A person's awareness of the fact
that his or her conduct is criminal, is the mental element, upon which the principle
of Mens-Rea lays upon.In a criminal action, the general conditions of penal
liabilities are indicated in old maxim "actus non facitreum, nisi mens sit rea" i.e.
the act alone does not amount to guilt, it must be accompanied by a guilty mind.

It is a fundamental principle of criminal law that a person may not be convicted of

a crime unless the prosecution proves beyond reasonable doubt both

(a) that responsibility is attributed to the accused for a certain behavior or the
existence of a certain state of affairs, in circumstances forbidden by criminal law
and that the accused has caused the prescribed event and

(b) that the accused had a defined state of mind in relation to the behavior,
existence of a state of affairs or causing of the event.

In the case at hand, the accused is responsible for inciting widespread protest and
civil unrest, by her supporters. In one protest, multiple pub properties were
destroyed, and in one other instance, the protestors tracked down government
quarters of government officials and stormed inside, to conduct their actions of
denouncing them for supporting the current govt. the actions undertaken by the
accused, had directly resulted in the events mentioned, along with a defined state
of mind in relation to the state of affairs of the socio-political structure, and in
relation to the events which had unfolded.

There is a guilty conscience behind every brazen word and act and behind every
manifestation of self righteousness, upon observation of recent developments in the
soci-political scenarios, Ms. Bennet had undertook a series of pre-meditated
actions, of purposefully and knowingly committing the offence of sedition.Her
active participation on social media platforms and her popular public events, were
pre-meditated plans to incite hatred and disaffection towards the government. her
ill intention is validated as she,
 1) Acted Purposely:- The series of actions Ms. Bennet undertook, through her
social media account, and public gatherings, was a pre-meditated operation,
with a certain objective in mind, i,e to disrupt the public tranquility and
ignite a socio-political meltdown.
The statements she had made on multiple platforms and public events,
inciting violence, calling for radical and rebellious movements by the
youths, was part of the same objective.
2) Acted knowingly:- It is clear that she had the intention to commit the
offence, as a means for achieving her political objectives. And regarding her
political position, it would be hard to accept that she did not possessed the
requisite knowledge of the offence she had committed.

C) There was Actus-Reus on the part of Miss, Elizabeth Bennet.

The physical element of the crime that is the event, behavior or state of affairs
connected to the crime is called the actus reus. A person must participate in all the
acts necessary to constitute a particular crime in order to be guilty thereof. In the
present case, the accused was responsible for exciting hatred and disaffection
towards the govt, and advocating rebellious movements.

1)There had been excitement of hatred and disaffection towards the govt.

Miss. Elizabeth had posted wildly provocative and politically charged posts on her
social media accounts, which had spurred political tensions, and incited to her
followers to hate and oppose the current governments. She also made multiple
public speeches which incites hatred and disaffection towards the government,
such as“ the government that has come to power has got drunk on its new-found
power. it has taken upon itself to wreak vengeance on anybody who holds an
opinion against it. We have no choice but to strike at the very root of this evil and
effectuate a fundamental overhaul.”

Her statements had ignited a growing discontent amongst the youths, and has led
them to oppose the current govt, she herself initiated various public movements
under certain labels, which are aimed at presenting the current gov t as arbitrary,
and its officials as war mongers.
 3) The accused had incited radical and rebellious movements against the
current govt.

It is submitted that the accused has been quoted saying, “We must rise in rebellion
against these dirty leeches on our mind and its thinking process”,“Together we
will overthrow the government!”. The message the accused wants to deliver
through her statements, such as the ones mentioned above, is for her supporters to
rebel against the government, and to remove the current lawfully elected govt.

Such statements from a popular political figure, has the capacity to drive the socio-
political structure to collapse, leading to public disturbances and social unrest. The
accused has put the social tranquility at risk, for pushing her political agendas and
accomplishing political objectives.

4) There is co-incidence between actus reus and mens rea.

The accused had conducted multiple actions, in which she had expressed her
political agendas, which resonates with exciting hatred and disaffection towards
the govt, and inciting her supporters to rebel against the current govt. the accused
had a pre-meditated plan for achieving the objective in mind. The series of actions
she had undertook was to achieve the objective of causing socio-political
meltdown and driving the society into a state of unrest, as an attempt to dismantle
the current govt in power, Hence, there is concurrence of the two elements in the
present case.

ISSUE II
Without prejudice to the above, whether the offences under sections 421-A/ 351-A/
210-B of the Penal Code of Camelot have been made out against Ms. Elizabeth in
the instant case?.

421-A of the Penal Code of Camelot, punishes anyone who brings or attempts to
bring into hatred or contempt, or excites or attempts to excite disaffection towards
the Government established by law in Camelot death or imprisonment for life.
Miss Elizabeth Bennet as a prominent political figure had exploited her popular
position, to incite hatred and disaffection towards the government. Through her
neo-liberal approach of political campaigns, she had accumulated massive
followers, mostly the youths, and has steered them into hating and opposing the
current Governments, and had called upon to rebel against the government. Such
acts come under the definition of sec 421-A of the penal code, of “ anyone who
brings or attempts to bring into hatred or contempt, or excites or attempts to excite
disaffection towards the Government established by law in Camelot.” and is
punishable by death. As her actions align with that of the prohibited acts under sec
421-A, the charges against her under the same is maintainable.

Sec 351-A of the Penal Code of Camelot, punishes anyone who promote enmity
between different groups on grounds of religion, race, place of birth, residence,
languages, etc, and dong acts prejudicial to maintenance of harmony.

Miss. Elizabeth’s political campaign is popular amongst the youths, with her neo-
liberal approach towards bringing about radical changes in the nation, serves as an
appealing promise towards the youths. But the statements she made, which
resonates anti-nationalist propagandas, have lacerated the national sentiments of
many, with many other political figures criticizing her statements. She has driven a
wedge between her supporters, which are oriented around her political party, i.e.,
the Hogwarts Party a student dominated party, and other political parties and their
supporters. Her supporters held massive protest which later turned violent, causing
damages to public properties, protested by storming government official’s quarters,
and ‘gifted’ them teddy bear toys and asked them to play with them in view of
their naïve and childish support for the current government of Erehwon, such
actions are not acceptable as a lawful civilian protest. Her campaigns are
prejudicial to the maintenance of harmony, and she herself had called upon for
radical and rebellious movement against the government. Thus, her actions
promotes enmity between groups with different political ideologies, incites violent
methods to be used for their political struggle, hence her actions aligns with those
actions defined under sec 351-A, thus the charges against her under the same is
maintainable.

Sec 210-B of the Penal Code of Camelot, punishes anyone who is a party to a
criminal conspiracy to commit an offence punishable, with death, imprisonment
for life, or rigorous imprisonment for a term of two years or upwards, as if the
person had abetted such offence.

Miss. Elizabeth along with the members of her Political party, The Hogwarts party,
had constructed a well shrouded and elaborate plan of, inciting the citizens, mostly
the youths to hate and show disaffection towards the government. The pre-
meditated plans she and her political party undertook, is prohibited under sec 421-
A of the Penal Code of Camelot as “sedition” and is punishable with death or
imprisonment for life. As Miss. Elizabeth herself has been in the forefront of these
seditious campaigns, she along with her political party had conspired to promote
agendas which denounce the current governments, calling for rebellious
movements against the current governments. Therefore, as a co-conspirator to the
pre-meditated and pre-determined seditious campaigns, the charges against
herunder sec 210-B is maintainable.
 PRAYER AND CONCLUSION

Wherefore in the light of the facts of the case, issues raised, arguments
advanced and authorities cited, this Hon’ble Supreme Court may be
pleased to declare that
1. The Death sentence as sought by the government of Erehwon is an appropriate
punishment for the offence of sedition.

2. The offences under sections 421-A/ 351-A/ 210-B of the Penal Code of Camelot
have been made out against Ms. Elizabeth.

And to pass any other order in favor of the petitioner that it may fit in
the interest of justice, equity and good conscience. All of which are
respectfully submitted.

PLACE: EREHWON S/D___________________

DATE: _____________ COUNSEL FOR APPELLANT