The Department of Laws, Panjab University, Chandigarh

Memorial Moot Court, 2021

BEFORE THE SUPREME COURT OF INDUS

Robert Petitioner 1

Ozan Petitioner 2

Civil Rights Society (CRS). Petitioner 3

Vs

State of Indus Respondent

Memorandum for the respondent

 TABLE OF CONTENTS

I. List of Abbreviations 3

II. Index of Authorities… 4

III. Case laws… 4

IV. Legislations… 5

V. Journals… 5

VI. Websites… 5

VII. Statement of Jurisdiction 6

VIII. Facts… 7, 10

IX. Issues… 11

X. Summary of Arguments 12,13

XI. Arguments Advanced… 14,20

XII. Prayer… 21
 LIST OF ABBREVIATIONS

Abbreviation Expansion

AIR All India Reporter

art. Article

cl. Clause

ed. Edition

SCC Supreme Court Cases

sec. Section

v. Versus

Ltd. Limited

Ors. Others

SC Supreme Court

IPC Indus penal code

IPC Indian penal code

¶ Paragraph

HC high court

u/art under article

vol. Volume

r/w read with

 INDEX OF AUTHORITIES

a. CASE LAWS

S. No. Case title Citation P. No.

1. IN AMARINDER SINGH VS. PUNJAB
LEGISLATURE ASSEMBLY, THE HINDU, APRIL,
27,2010.

2. IN MOHD. SIDDIQUI VS. STATE OF U.P., AIR 2014 SC 2051

3. AIR 2007 SCC 184

IN RAJA RAM PAL VS. HON’BLE SPEAKER LOK
SABHA,

4. GANPATI K REDDY v STATE OF U.P. AIR 2014 SC 2051

5. P V NARSIMHA ROA v. STATE AIR 1998 SC 2120

6. KESHAV SINGH v. SPEAKER LEGISLATIVE

ASSEMBLY

7. SALDHANA

8. BABUBHAI vs. STATE OF GUJARAT

9. AMISH DEVGAN VS. UNION OF INDIA, WRIT PETITION

NO. 160 OF 2020
SC.
 b. LEGISLATIONS

S. No. Title of legislation PP

1. The Constitution of India , 1950 Passim

2. The Punjab Prevention of Defacement of Property Act, 1997 Passim

Punjab Act No. 7 of 1998

3. The prevention of corruption Act, 1988 Passim

4. The Representation of the People Act, 1951 Passim

c. JOURNALS

S. No. Title of Journal Pp

1. All India Reporter (AIR) Passim

2. Supreme Court Cases (SCC) Passim

d. WEBSITES

S. No. Website link PP

1. www.scc.online Passim

2. www.legalbites.com Passim

3. www.judis.nic.in Passim

4. www.Indian kanoon.org Passim

5. www.legalserviceindia.com Passim
 STATEMENT OF JURISDICTION

A special leave petition u/art 136 of the constitution of Indus 1950

and Two writ petitions u/art 32 of the constitution of Indus 1950

The three petitions have been clubbed together and the Supreme Court has admitted the petitions
as maintainable.

The memorandum sets forth the facts and the laws and the corresponding arguments on which
the claims are based in the instant case, the appellants confirm they shall accept any judgment
of this honourable court will be final and binding upon itself and shall execute it in it’s entirety
and in good faith.
 STATEMENT OF FACTS

For the sake of brevity, the material facts are placed herewith in the chronological order.

1. Mr. Robert is a veteran legislator, who has the distinction of having been elected
consecutively 6th times to the parliament of Indus. He had the distinction of serving
as Prime Minister of the previous government and currently as Leader of Opposition
in the Upper House of the Parliament.

2. The new Govt. in Indus decided to investigate the expenses claimed by Mr.
Robert as Prime Minister (2015-2020) with respect to reimbursement claimed
on account of expenses incurred by family members on traveling and IT
services. The civil society, various NGOs, and other organizations seeking
transparency and accountability in the expenditure of public money sought a
judicial inquiry into the scandal.

3. The system for payment of members of Parliament’s allowances and expenses,

as it existed at the relevant time, was created by the joint resolution of both the
houses of parliament and overseen by the Public Accounts Committee. The
individual members used to fill the claim forms and the finance office of the
respective Houses used to consider the same and make payments in relation to
claims. The claim forms as submitted by the members contained a declaration,
signed by the Member, confirming that the costs were exclusively incurred in
course of the purpose of performing duties as a Member of the Parliament.

4. Mr. Robert’s party claimed it was Mr. Ryan – who headed the Public Accounts
Committee and his committee approved all the bills, expenditure, and
appropriation-related issues of the Parliament of the year 2019.. Moreover, the
audit has been done by the Comptroller and Auditor General of Indus and the
report has been duly tabled, presented, and passed in terms of Rules of the
respective House for the financial year of 2019-2020.
5. Since Mr. Robert is a member of the Upper House in 2021, the entire issue was
referred to a sub-committee composed of 5 distinguished members of the Upper
House and requested them to submit directly to the Chairman of Upper House.
Surprisingly, the sub-committee in its report indicted Mr. Robert for financial
irregularity and recommended FIR to be registered in the present case. The
chairman of the Upper House accepted the recommendation and ordered an FIR
to be registered at the Police Station at Parliament Street, Indus.

6. Mr. Robert immediately challenged the decision of the Chairman of the Upper
House of the Parliament by way of a Writ Petition under Article 32 violative of
his fundamental rights and other constitutional rights which he had as a member
of parliament. He sought to claim immunity from investigation and quashing of
FIR in the present case on strength of parliamentary privileges which are
available under the constitutional scheme.

7. The Supreme Court had issued the notice in the writ petition filed by Mr. Robert
and ordered no coercive action against Mr. Robert.

8. Mr. Ozan is another distinguished member of the Parliament in Lower House

who belonged to the same political party to which Mr. Robert belongs.he
challenged the ruling party and establishment to order an FIR against him for any
act or consequential act of his inside the Parliament. As a member of the lower
house, he prepared a speech titled “Give Me Freedom”.

9. Mr. Ozan during his speech criticized the action and decision of the Chairman of
the Upper House of the Parliament, he sought the reclamation of parliamentary
sovereignty and freedom to its members to raise their voice and conduct
themselves without fear and favor. He highlighted the importance of
parliamentary privileges, institutional autonomy & independence essential for
constitutional democracy. The speech was such that two other first-time
parliamentarians of the Lower House (one from the political party to which Mr.
Robert belongs and another independent candidate) took out the paint spray from
their respective pockets and scribbled “Give me Freedom” towards the end of
 Mr. Ozan's speech. Thereafter, there was a ruckus on the floor of the House and
the Speaker adjourned the House for the day.

10. The speech of Mr. Ozan got live telecasted – as a response – there were several
graffiti in the name and style of “Give me freedom” that came up at various public
places and public spaces of the capital city. By the next morning, all the important
public places and walls of the government. buildings in the capital city had the
writing “Give me Freedom”. The media and newspapers reported it as the “Give
Me Freedom” moment of the Indus. The Civil society hailed it as reclaiming basic
civil and political liberty.

11. On the recommendation of the Ethics Committee of the House, the Hon’ble
Speaker suspended Mr. Ozan for six weeks to which he replied that he did not
deface the property nor carried out any illegal activities as defined under any law
rather he had all the right to make the speech on the floor of the House. He further
submitted that as his ‘speech got Live’ through the official TV channel of the
Lower House (which is run and managed by the authority of Speaker of this House)
could have been censured if it was so inflammatory in nature. He also stated that
the consequential reaction by the ordinary public on the streets of the capital city
only shows the public anger against squeezing freedoms and over- regulation of
basic rights of the citizenry in disguised mode by the present ruling Govt.

12. He further sought a review of the decision of the Hon’ble Speaker i.e. ‘suspension
of Six weeks from Assembly’ and disqualification of two other members (who
scribbled inside the Lower House) and requested to revoke the same. The Hon’ble
Speaker disposed of the review petition and retained his previous decision in the
case of Mr. Ozan and the other two parliamentarians.

13. Mr. Ozan along with the other two parliamentarians challenged the decision of
Hon’ble Speaker as violative of Fundamental Rights and constitutional norms in
the modern governance in a Writ Petition before the Supreme Court of Indus and
 also sought the writ declaring the entire State legislation which made unauthorized
defacement of property as a punishable offense.

14. The State legislation making defacement of property as an offense is pari materia to
the Punjab Prevention of Defacement of Property Act, 1997.An NGO named Civil
Rights Society (CRS) filed a Writ Petition before the High Court of NCT of Indus
challenging the constitutionality of applicable Act which sought to restrict and
regulate the defacement of public property and public places on the ground of
violative of the basic right enshrined under Part III of the Constitution of Indus.
The NGO also contended that it violates the constitutional protection afforded to
the members of the House in form of ‘Legislative Privileges’ beside the safeguards
in part III of the Constitution of Indus.

15. The Hon’ble High Court dismissed the Writ Petition and opined that it is a valid
piece of legislation and FIRs registered against unknown persons for painting the
public space as “Give Me Freedom” does not violate any liberty and constitutional
rights thereto.

16. The NGO i.e. Civil Rights Society (CRS) preferred a Special Leave Petition (SLP)
against the same before the Supreme Court of Indus. The Hon’ble Supreme Court
of Indus has issued notice and clubbed the matter along with the Writ Petition of
Mr. Ozan and Mr. Robert.
 ISSUSES RAISED

i. Whether the power of the legislature to punish for contempt including the breach of
its privilege is essentially a judicial function or not? If yes, whether it is in tune with
the modern constitutional principle to entrust such powers with respective
legislatures or not?

ii. Whether the action of Speaker/ Chairman of the respective Houses against Mr. Ozan
and Mr. Robert respectively is violative of constitutional rights namely legislative
privileges, freedom of speech or not?

iii. Whether the Punjab Prevention of Defacement of Property Act, 1997 is

constitutional or not? Whether the registration of FIRs against unknown and
members of Parliament under the Act is legal or not?
 SUMMARY OF ARGUMENTS

i. Whether the power of the legislature to punish for contempt including the breach of its
privilege is essentially a judicial function or not? If yes, whether it is in tune with the
modern constitutional principle to entrust such powers with respective legislatures or
not?
It is humbly submitted that :
1. The parliamentary privileges connote “ certain rights accruing to each houses of
parliament collectively and also to members individually without which it would
not be possible to maintain either dependence of action or the dignity and
efficiency of a sovereign nation”. It is enshrined in the articles 105 and 194 of the
Indus Constitution. They expressly mention two privileges namely freedom of
speech and freedom of expression and freedom of publication of proceedings.
2. That although the power of the legislature to punish for contempt including the
breach of its privileges is the right of every house of legislature to punish its
members or non-members but it cannot exercise judicial power and hold a
member guilty of criminal charges and which function is vested with trial court.
3. That the parliamentary proceedings which may be tainted on account of
substantive or gross irregularity or unconstitutionality are not protected from
judicial scrutiny.

ii. Whether the action of Speaker/ Chairman of the respective Houses against Mr. Ozan
and Mr. Robert respectively is violative of constitutional rights namely legislative
privileges, freedom of speech or not?

It is humbly submitted before this Hon’ble Court that:

1. That Right to freedom is an important and crucial privilege which enables a
member to speak freely and fearlessly, on the floor of the House. It is the essence
of the parliamentary system of government that peoples’ representatives should be
 free to express themselves without fear of legal consequences.
2. That the action of the speaker/ chairman of the respective houses against Mr.
Roberts and Mr. Ozan is purely is violative of constitutional rights namely
legislative privileges, freedom of speech. The freedom of speech is subjected to
the disciplines of the rules of parliament, the good sense of the members and the
control of proceedings by the Speaker, as the case may be.

iii. Whether the Punjab Prevention of Defacement of Property Act, 1997 is constitutional
or not? Whether the registration of FIRs against unknown and members of Parliament
under the Act is legal or not?
It is most humbly submitted before the honorable court that:
1. The Punjab Defacement Act deals with the offence of defacing any public
property by writing, or marking with ink, chalk, paint or any other material or by
erecting staffs, banners or by pasting notices or any other slogans, without the
permission of the owner of the property. It enforces that it is mandatory to prove
mens rea of the offender or consent which is necessary to commit such offence.
2. That it was illegal to register FIR against unknown members of the Parliament as
they had no intention to deface any public property nor did they gave the consen to
any parties to commit such an offence.
 ARGUMENT ADVANCED
1. The power of the legislature to punish for contempt is essentially a legislative

function since it comes under the penal powers of the house but but it cannot
exercise judicial power and hold a member guilty of criminal charges and which
function is vested with trial court.

2. Failing to maintain the standards of accountability and disrupting and delaying the

Parliamentary proceedings in one way or the other not only indicates a lack of
accountability but also the lack of fear against the punishment for offences
constituting a breach of privilege or contempt of the Parliament House.
3. .Imposition of fines and stricter punishments are therefore to ensure accountability
and smooth proceedings in Parliament which should be done by a judicial action to
ensure prevention of unnecessary power fights between the leading and opposition
parties.
4. That consideration of contempt could be done by the parliamentary procedure but it
must not be the duty of a parliamentarian to declare punishments. It must not deal
with the work that it is never meant to handle.

5. A contempt of the Parliament House can be defined as any act

that:

a. Causes an obstruction in the conduct of proceedings of the House

b. Causes an obstruction in the performance of functions by any officer or member

of the House.
c. Any other act that directly or indirectly has such an effect.

d. Proceedings against contempt are very important because the nation cannot
function properly if the Parliament or its members/officers are unable to perform
their duties in an efficient manner.

6. Article 105 and 194 expressly mention in the constitution rule making power and
internal autonomy , which is required to work effectively without any interference
from outside and the right to maintain their own internal issues to deal among
themselves.
 CaASE LAWS

1) IN AMARINDER SINGH VS. PUNJAB LEGISLATURE ASSEMBLY, THE HINDU,

APRIL, 27,2010.

The Supreme Court held that it was improper for the legislature to act in respect of
subject-matter which was pending adjudication, thereby violating the norm of not interefering in
sub judice matters. It was further argued that even though legislative privileges are exercised to
ensure the dignity and discipline of the House, the same cannot encroach into the judicial domain
by recording a finding of guilt and recommending punitive action in respect of the alleged
misconduct.
2) IN MOHD. SIDDIQUI VS. STATE OF U.P., AIR 2014 SC 2051

The Supreme Court pointed out that proceedings which may be tainted on account of
substantive or gross irregularity or unconstitutionality are not protected from judicial scrutiny.

3) IN RAJA RAM PAL VS. HON’BLE SPEAKER LOK SABHA, AIR 2007 SCC 184:
It was observed by the majority of the Court that the Supreme Court had the authority and the
jurisdiction to examine on grievance being brought before it, to find out if the particular power or
privilege that had been claimed or asserted by the Legislature was one that was contemplated by
Article 105(3) or Article 194(3). The power of expulsion could be claimed by Indian Legislature
as one of the privileges inherited from the British H.O.C. But the final arbiter on whether such
power is contained under Article 105(3) and 194(3) was the Supreme Court and not the
parliament. The exercise of power or privilege by the Legislature ought not to be tested on the
traditional parameters as applicable to administrative action, and the Court would confine itself
to the acknowledged parameters of judicial review and within the judicially discoverable and
manageable standards, such as on grounds of lack of jurisdiction, or the impugned, irrationality,
violation of constitutional mandate, mala fides, non-compliance with rules of natural justice and
perversity.
 (ii)

1. In case of Mr. Robert, he being a true leader, utilized the allotted money that was passed by
the Public Accounts Commmittee headed by the opposition. Scritinising him in the
parliament was a mere attempt by the opposition to harm his reputation and retaliate
against him to uplift the status of their own party.
2. The writ petition filed by Mr. Roberts was maintainable and without any malafide
intentions as the whole prupose of the present ase was to defame him and his party. The
fact that the opposition was the head of Publlic Accounts Commiitte is evident to the truth
that they had the hold of the accounts and expenditure and they conspired a whole chain of
irregularities to pull down Mr. Roberts.
3. The fact that the opposition pointed out the irriegularities after the defeat of Mr. Roberts
clearly shows that the opposition was untrue and insincere as the Public Accounts
Committee. Had there been any irregularity, they should have told it in the very beginning
when the money allocated was going into the wrong channels.
4. In case of Mr. Ozan, he understood the scenario created by the opposition and with the
spirit of a true member of Robert’s party, he attempted to save the reputation of Mr.
Roberts and their party. He highlighted the importance of parliamentary privileges,
institutional autonomy and independence which are essential for democracy. In his speech
there was nothing controversial.
5. The fact the Mr. Ozan’s speech was being aired by the opposition clearly shows the
malafide intention of the opposition to enrage people sitting outside the parliament so as ro
create outrageous scenarios. It is a well known fact that a well-versed speech in such
delicate situations could outrage the people. The telecasting of Mr. Ozan’s speech was a
clear violation of the rights onherited in him by virtue of Article 105 of the Indus
Constitution.
6. Moreover, the suspension of Mr. Ozan and other two members was completely irrational
and a cunning move by the opposition to weaken the other paerty. It is mere a show of
power and revenge.
 CASE LAWS :

1) GANPATI K REDDY v STATE OF U.P. AIR 2014 SC 2051

In this case the Apex Court held that according to the facts and the data of the case, it is binding
on the court to find the correct decision and the court is decisive of the refrences. The Supreme
Court accepted the arguments and ordered the release of the petitioner. According to Article
22(2), he was not presented before the magistrate before 24 hours of his arrest or detention. Not
presenting him before the magistrate resulted in the violation of his fundamental right under
Article 22(2). In this case it was opined that Article 105 and 194 cannot supersede the
fundamental rights.

2) P V NARSIMHA ROA v. STATE AIR 1998 SC 2120

It was held by majority of the court that under Article 105(2) the members of the parliament will
get immunity and thus, the activity of taking bribe by the MP`s will get immunity despite
anything said by them or any vote given by them in the parliament. The court further explained
that the word “anything” here will be interpreted as a wider term. The court interpreted the term
“anything” in a wider sense and did not prosecute P.V. Narsimha Rao.

3) KESHAV SINGH v. SPEAKER LEGISLATIVE ASSEMBLY

The facts of the case-Keshav Singh, who was a non-legislative member of the assembly, printed
and published a pamphlet. Because of printing and publishing of the pamphlet, the Speaker of
U.P. Legislative assembly criticized him for contempt and breach of the privilege of one of the
members. On the same day he committed another breach by his conduct. As a result the speaker
directed him to be imprisoned, issued warrant for the same and ordered his detention in jail for 7
days. A writ of Habeas Corpus was applied in his petition. The petition claimed that the
detention in jail is illegal and is done with malafide intentions. The petition also stated that he
was not given any chance to explain or defend himself. The petition was heard by the 2 judges
who gave them interim bail.
As a result a new resolution was passed in which it was laid that the 2 judges entertained the writ
filed by the petitioner and his lawyer. In its resolution, the assembly issued a contempt notice to
present the two judges and the lawyer before the house and explain the reasons for their conduct.
It also ordered that Keshava should be taken into custody. Under this they moved petitions under
226 and filed a writ of mandamus before the Allahabad High Court to set aside the resolution
passed by the assembly. It was held by the majority of Supreme Court that the conduct of the
two judges does not amount to contempt. The court further explained that if in the matters of
privileges stated under Article 194(3) then the house will be considered as the sole and exclusive
judge provided that it should be stated in that. But if any such privilege is not mentioned in the
article then it’s the court who has to decide upon it.

This Court took note of the history of the parliamentary privileges, scheme and text of
the Constitution and opined that the power of expulsion is part of the privileges and
immunities of the Parliament. It is relevant to notice that Under Article 105(3), “the powers,
privileges and immunities of each house of Parliament” may be “defined by Parliament by
law”. This Court noticed and proceeded on the assumption that no such law existed. Yet it
was held by this Court that such power was part of the privileges of the Legislature.

It therefore follows clearly and a fortiori that at least in the context of expulsion of a
member of the LEGISLATURE, by a decision of that House, no statutory provision is
required for stipulating the grounds on which a member could be expelled or the procedure
which is required to be followed. Though Article 105 and 194 authorises the
LEGISLATURE to define the “powers and privileges and immunities”, the non-exercise of
that power to legislate, does not detract the power of the LEGISLATURE to expel a
member on the ground that a member resorted to some activity which does not meet the
approval of the House. A decision to expel a member would certainly have the same effect
as disqualifying a member on the grounds specified Under Articles 102 and 191.
This Court in Raja Ram Pal case highlighted the difference between “expulsions” and
“disqualification”. It may not answer the description of the expression 43 disqualified as
defined under the RP Act of 1951 or the grounds mentioned Under Article 102 and 191. The
disqualification brought about by expulsion is limited, of course, to the tenure of the member
 and does not disqualify him from seeking to become a member again by contesting an
election in accordance with law.

The next question to be examined is whether it is permissible for the Respondents to make
subordinate legislation stipulating that UNDUE ACCRETION OF ASSETS would render a
LEGISLATOR disqualified within the meaning of the expression Under Section 7(b) of the
RP Act of 1951 and to establish a body to undertake the regular monitoring of financial
affairs of the LEGISLATORS.
If a temporary disqualification, such as the one discussed above, could be imposed on a
LEGISLATOR even in the absence of any legislative prescription, in the light of the Scheme
and tenor of Articles 102(1)(e) and 191(1)(e) read with Section 169 of the RP Act of 1951,
the Government of India would undoubtedly be competent to make such a stipulation by
making appropriate Rules declaring that UNDUE ACCRETION OF ASSETS would render a
LEGISLATOR “disqualified”.

Further, it would be equally competent for the Government of India to establish a

permanent mechanism for monitoring the financial affairs of the LEGISLATORS and
their ASSOCIATES for periodically ascertaining the relevant facts. Because the
establishment of such a permanent mechanism would be a necessary incident of the
authority to declare a LEGISLATOR “disqualified”.

(iii)

1) The Hon’ble High Court has already dismissed the above Petition and opined that it is a
valid piece of legislation and FIRs registered against unknown persons for painting the
public space as “Give Me Freedom” does not violate any liberty and constitutional rights
thereto.

2) Defacement of walls/information boards by affixing posters/wall painting (advertisement)

Under Section 399(1) of the Punjab Municipal Corporation Act, 1976 & the Punjab
 Prevention of Defacement of Property Act, 1997. is punishable and can file cases against
the violators.

3) Here it is clearly mentioned the word ‘violators’ which means the one who is violting the
rules under this act. Now it is quite illegal to register FIR agaist those persons who are
unaware of the fact that there speech is being broadcasted to the common people. From the
veru beginning, Mr. Ozan had no motive or intention to outrage people and force them to
write slogans over walls of public property.

4) It a mere an overuse of the powers mentioned in this act. The registeration of FIR against
unknown parliamentarians regarding the wreck caused by people unknown to them is an
attempt to degrade the reputation of a parliamentarian and tarnish his parliamentarian
privileges.

CASE LAWS

1) In SALDHANA case, this court had held that the power conferred upon magistrate under Section
156(3) does not affect the power of the case even after submission of the report under Section 173(8).
In Upkar Singh, this Court noted that the decision in Ram Lal Narang is “in the same line” as the
judgement in Kari Choudhary and Saldhana and held that the decision in TT Antony does not preclude
the filing of a second complaint in regard to the same incident as a counter complaint nor is this corse
of action prohibited by the CrPC.

2) In BABUBHAI vs. STATE OF GUJARAT the court has to examine the facts and circumstances
giving rise to both the FIRs and the test of sameness is to be applied to find out whether both the FIRs
relate to the same incident incident in respect of the same occurance or are in regard to the incidents
which are two or more parts of the same transaction. If the answer is in same affirmative, the second
FIR is liable to be quashed. However, in case the contrary is proved where the version in the second
FIR is different and they are in respect of the two different incidents/crimes, the second FIR is
permissible. In case in respect of the same incident the accused in the first FIR comes forward with a
different version or counterclaim, investigation on both the FIRs has to be conducted.
3) AMISH DEVGAN VS. UNION OF INDIA, WRIT PETITION NO. 160 OF 2020 SC . The court
further held that the relevant enquiry is whether two or more FIRs relate to the same incident or relate
to incidents which form part of the same transactions. If the Court were to conclude in the affirmative,
the subsequent FIRs are liable to be quashed. However, where the subsequent FIR relates to different
incidents or crimes or is in the form of a counter-claim, investigation may proceed.

PRAYER

IN VIEW OF THE FACTS STATED, ARGUMENTS ADVANCED AND AUTHORITIES

CITED, THE PLAINTIFF, HUMBLY PRAYS BEFORE THE HONORABLE COURT, TO :

1. QUASH THE COMPLAINTS FILED AGAINST MR. ROBERTS BY THE OPPOSITION IN

THE LEGISLATURE AND THE SAME MATTER OF IRREGULARITIES IN ACCOUNTS
HANDED OVER TO THE JUDICIARY FOR FURTHER FRESH INVESTIGATIONS,
RESPECTING THE PARLIAMENTARY PRIVILEGES OF THE PETITIONER.
2. QUASH THE FIRS REGISTERED IN THE NAME OF MR. OZAN, RESPECTING THE
RIGHTS INFERRED TO HIM VIA ARTICLE 105 OF THE INDUS CONSTITUTION.
OR
PASS ANY OTHER ORDER, WHICH THIS HON’BLE COURT MAY DEEM FIT IN
LIGHT OF JUSTICE, EQUITY, FAIR PLAY AND GOOD CONSCIENCE.

ALL OF WHICH IS MOST HUMMBLY PRAYED,

COUNSEL FOR THE PLAINTIFF