TMV, LOKMANYA TILAK LAW COLLEGE

Moot court Problem 1

BEFORE THE HON’BLE SUPREME COURT OF INDIVA

UNDER ART.32 OF THE CONSTITUTION

IN THE MATTER OF:

DRISHTI FOUNDATION … ……………..PETITIONER

versus

UNIONOF INDIA………………………….RESPONDENT

MEMORIAL ON BEHALF OF THE RESPONDENT

NAME : PRIYA PRAKASH NAIK

CLASS : L.L.B 3 YEAR (SEM -6 )

PRN NO: 21221000942

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 SR. NOS CONTENTS PAGE NOS.

1 Title Page 1

2 Table of Contents 2

3 List of Abbreviations 3

4 Index of Authorities 4

5 Statement of Jurisdiction 5

6 Statement of facts 6

7 Issues Raised 8

8 Summary of Arguments 9

9 Arguments Advanced 10

10 Prayer 17

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 LIST OF ABBREVIATIONS

& And

AIR All India Reporter

Anr. Another

Art. Article

Constitution Constitution of India, 1949

Hon’ble Honorable

No. Number

Ors. Others

PIL Public Interest Litigation

SC Supreme Court

SCC Supreme Court Cases

Sec. Section

SCR Supreme court Reports

SCOR Supply Chain operation reference

SLP Special Leave Petition

Spl. Special

V/S or vs. Versus

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 INDEX OF AUTHORITIES
Legislation referred

1 The constitution of India, 1949

.

2 The Indian penal code,1860

.

3 Protection of women against domestic violence act, 2005…

.

4 The Maharashtra prevention and eradication human sacrifice and

. other Inhuman, Evil and Aghori Practice’s and black magic Act,
2013

5 THE PROTECTION OF CIVIL RIGHTS ACT, 1955

.

6. THE PROTECTION OF CHILDREN AGAINST SEXUAL OFFENCES ACT, 2012

7. DRUGS AND MAGIC REMEDIES ACT, 1954

Cases cited.

Name of the cases

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 1. A S Narayan V/s Sttae of Andhra Pradesh
2. Ravishnkar @ Baba Vishwakarma V/s State of Madhya Pradesh
3. The State of Maharashtra vs. Dnyaneshwar Haribhau Kulal on 11th
January, 2008.
4. S R Bommaia V/s Union of India
5. Sant Shri Asharam Bapu V/s State of Rajasthan
6. Sakshi V/s Union of India
7. Shri Nityananda Swami V/s S. Arathi Rao

STATEMENT OF JURISDICTION

The Appellant Submits This PIL For The Petition Filed Before The Hon’’ble
Court. The Petition Invokes Its Jurisdiction Before The Honorable SC Of
India Under Art.32, 25 & 26 Of The Constitution Of India. It Set Froths the
Facts. Contentions, Argument and the Laws on Which the Claims Are
Based.

Art.32 : REMEDIES FOR ENFORCEMENT OF RIGHTS CONFERRED BY THIS PART

a) The right to move the SC by appropriate proceedings for the enforcement of

the right conferred by this part is guaranteed.
b) The SC 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 right conferred by this part?
c) Without prejudice to the powers conferred on the SC by clauses(1) and
(2),parliament may by law empower any other court to exercise within the

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 local limits to its jurisdiction all or any of the power exercise by the SC
under clause(2)
d) The right guaranteed by this art shall not be suspended except otherwise
provided for by this constitution.

Art.32 of the Indian constitution gives the right to individual to move to the
SC to seek the justice when they feel that their right has been ‘unduly
deprived’. The apex court is given the authority to issue direction or orders
for the execution of any of the rights bestowed by the constitution as it
considered ‘the protector and guarantor of fundamental rights’.

The case was filed by the Drishti Foundation which is NGO working against
the exploitation of the religious feeling of the people by such so called
godman Babaram (‘’defendant’’) through pil before the Hon’ble SC of India.

The case deals with challenging the activities of exploitation of being carried
out by so called babas in math’s and the ashrams and the religious
sentiments of the people. Exploits illiterate and poor women and children
and employed youths. He uses their energy by providing them training to
play with the rifles and arms for his own protection and to prevent govt.
‘authorities to take any action against him. He poses himself has god or
supernatural power to attract women has sexually abused many women’s
too.

The exclusionary practice is based on domestic violence against women and

violates art.32, 25 and 26 of the constitution and protection of children from
sexual offences.

Article 142 (‘’Inherent Powers of SC”)

Can be defined as the SC orders and decrees being carried out in the
exercise of the jurisdiction in such way that it complete justice can be done.
The federal court had no apparatus for carrying out its decision under the
government of India act, 1935. Therefore, the petitioner states and submit

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 that this hon’ble apex court, has jurisdiction to deal and entertain the
present PIL.

STATEMENT OF FACTS

Drishti foundation ………………Appellant

Vs.
Union of India ……………Defendant

1) Shivrashtra is a state in the Union of Indiva. The population of the state on

the basis of religious faith comprises of 40% Hindu, 25% Muslim, 15%
Christians and the remaining 20% belong to various smaller group like
Paris, Triabals and Non-Triabals and Non-believers. The State is
Predominately a hilly area with four holy rivers flowing through it and the
people are very religious by nature. A large Number of population being
illiterate, carriers out primitive occupations. Religious practices,
Superstitions and rituals, take much of their time and money which has
greatly affected the development of the state.

2) The state is known all over the world for its religious centers. The various
religious institutions in the state are imparting only religious education,
putting the secular education into oblivion which has reduced drastically

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 the people’s employment avenues. As the state is a pilgrimage center, the
religious leaders, Gurus and Prophets of various religious in the state are
vying with one another because of huge donations offered by the pilgrims.
3) Accordingly, mass prayers, retreats, yagnas, penance services etc. are
conducted very frequently. The religious leaders, so called God men in order
to continue their hold, have created a kind of fear in the mind of their
followers by way of fundamentalist practices and attitudes, which further
created divisions in the society and often with the families too.
4) The youths of the state, who were boiling with anger and frustration looking
at the economic progress of other states, often revolted against those
oppressive and suppressive religious practices that prevailed in their states.
There were many protests by many groups headed by moderates,
intellectuals and non-believers on various occasions in different parts of the
state.
5) Dr. Virendra Panhalkar, the 70 years old social activist, who was shot dead
on 20th August, 2020 in one city of the state of shivrashtra, had wages a
long and lonely battle for an Anti-Superstition law.
6) Within a week after the vicious assassination of Dr. Panhalkar, the governor
of shivrashtra signed the ‘Black Magic Prohibition’ Ordinance. It came
into force from 26th August, 2020 all over the state of shivrashtra.

7) The ordinance is aimed at banning superstitious practices, inhuman rituals

and black magic that have been the used to exploit people in the name of
religious beliefs. This law is against fraudulent and exploitative practices,
such practices have no place in enlightened society. In the entire text there
is not single word about God or Religious. The essential purpose of this law
is to bring social awakening and awareness in the society and to create a
healthy and safe social environment with a view to protect the common
people in the society against the evil and sinister practices thriving on
ignorance.
8) The draft clearly specifies 12 such practices. These includes, claiming to
perform surgery with just fingers or to change the sex of the fetus in the
womb, sexual exploitation under the guise of claims of supernatural power,
branding women as witches and causing them physical harm, human
sacrifices and other Aghori practices.
9) Inspite of coming into force of the above legislation the superstition activities
are no rise. The people of the state of shivrashtra are being exploited by the
self- declared god like babaram Maharaj, who has amassed huge wealth by
exploiting the religious sentiments of the people. Under the garb of religious
practices he started to exploit illiterate and poor women and children and
employed youths. He uses their energy by providing them training to play
with rifles and arms for his own protection and to prevent government
authorities to take action against him. He poses him as God or supernatural
power to attract women and he sexually abused many women’s too. To ban
his activities the government of shivrashtra tried to enter his ashram but
could not succeed.

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10) In the backdrop of above facts and circumstances, Drishti Foundation which
is NGO working against the exploitation of the religious feelings of the people
by such so called Godman Babaram, has filed an PIL before the supreme
court under Art. 32 of the constitution of indiva challenging the activities of
exploitation being carried out by the so called Babas in their maths an
ashrams and has prayed therein that all the maths and ashrams which are
carrying out the activities of the exploiting of the religious feeling of the
people should be closed and all these assets acquired by these Babas be
confiscated and added to the national wealth of the indiva.

STATEMENT OF ISSUES

I. Whether the PIL is maintainable before the Supreme Court of Indiva

for hearing and admission?

II. Whether the activities exploiting the religious sentiments of the people
amount to infringement of fundamental rights of the people of indiva?
III. Whether the alleged activities are contrary to the secular structure of
union of indiva as enshrined in the preamble of the constitution of
indiva?
IV. Whether the ban on such math’s /Ashrams would violate the
fundamental rights of the people to follow the religious faith of their
choice?

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 SUMMARY OF ARGUMENTS

ISSUE 1: Whether the PIL is maintainable before the supreme court of

indiva for hearing and admission?
The respondent humbly contends that this court has the jurisdiction to
entertain this PIL were group of people filed this under the Art.32, Art. 25-
28 and Art.21 of the constitution of India as grave injustice has been
experienced by the respondent. Under Article 32, the constitution has vested
special power that right to move the Supreme Court by appropriate
proceedings for the enforcement of the rights conferred by this part III of the
constitution of India.
ISSUE 2: Whether the activities exploiting the religious sentiments of
the people amount to infringement of fundamental rights of the people
of indiva?
The Constitution of India confers on all the fundamental rights to promote
and preach their own religious beliefs and follow the guidance of their
religious. Articles 25,26,27,28 under Part III of the Indian constitution
mentions the ambit of the right to freedom of religion.
ISSUE 3: Whether the alleged activities are contrary to the secular
structure of union of Indiva as enshrined in the preamble of the
constitution of Indiva?
The 42nd Constitutional (Amendment) Act of 1976 stated that ‘secular’
means a republic in which there is equal respect for all religious.
Despite the clear letters of the law, the Hon’ble Supreme Court interpreted it
on various occasions vai various judgements.
ISSUE4: Whether the ban on such Matts/ Ashrams would violate the
fundamental rights of the people to follow the religious faith of their
choice?
Under Article 25 of the constitution guarantees freedom of religious to all
persons in India. Thus, the ban on such Maths/Ashrams does violate the
fundamental rights of the people to follow the religious faith of their choice
as these maths and Ashrams have been a place for religious and for people
to pray.

ADVANCED ARGUMENT

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ISSUE 1: Whether the PIL is maintainable before the supreme
court of indiva for hearing and admission?

1. In the present case, there has been no violation of the fundamental rights
since, the action taken by the baba did not affect any legal right of the
people and wanted people to protect themselves.
2. A PIL can be filed under Art. 32 of the Constitution of the Indiva for the
enforcement of Fundamental Rights as guaranteed by the Part III of the
Constitution.
3. PIL means a legal action initiated in a court of law for enforcement in which
the public have some interest by which their legal rights are affected. A PIL
can be filed against the state for the violation of fundamentals rights under
Art.32 of the constitution: therefore, the present PIL is maintainable against
the Union of Indiva.
4. PIL is referred to litigation undertaken to secure public interest and
demonstrates the availability of justice to socially-disadvantaged parties and
introduced by justice P.N.Bhagwati on the traditional rule of locus standi.
Before 1980s the judiciary and SC of India entertained litigation only from
the parties affected directly or indirectly by the defendant, heard and
decided only under its original and appellate jurisdictions. However, the SC
began permitting cases on the ground of PIL, which means that even people
who are directly involved in the case may bring matters of public interest to
the court. It is courts discretionary power of the courts to entertain the
application for the PIL.
5. The petition claimed by the petitioner is not maintainable in the court of
law. The honorable judge of the SC of India does not have inherent
jurisdiction to they, and entertain the present case by virtue of its writ
jurisdiction; the petitioner has filed the pil before the honorable SC of India,
in the matter under Art. 32, Art.25-28 and Art.21 of constitution of India.
6. It respectably and humbly contends that baba is not guilty for committing
the offence of insulting religious belief under Section 295A of the Indian
Penal Code.
7. According to Article 21:- ‘’Protection of life and Personal Liberty: No
person shall deprived of his life or personal liberty except according to
procedure established by law.” This fundamental rights is available to every
person, citizens and foreigners alike Art. 21 provides two rights to life and
right to personal liberty.
8. Article 25 of the constitution guarantees freedom of religion to all persons in
India. It provides that all persons in India, subject to public order, morality,
health, and to the other provision of this part, are equally entitled to
freedom of conscience and have the right to freely profess, practice and
propagate religion. It further provides that this article shall not affect the
operation of any existing law and shall not prevent the state from making
any law relating to the regulation or restriction of any economic practice.
Providing for social welfare and reform or the throwing open of Hindu

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 religious institution of public character for all the classes and sections of the
Hindus.
9. Article 26 (subject to public order, morality, and health) confers a right on
every religious denomination or any section of the religious and charitable
purposes, managing its affair with regard to religion, owing and acquiring
property (movable and immovable), administering the property in
accordance with the law.
10. Math’s and Ashram follow the tradition and religious belief as per the
culture of shivrashtra which are according to Art. 25-28, the fundamental
Rights given by the constitution of India. The list of Math’s and Ashrams are
prepared by Drishti foundation on their own which can be animus against
this math’s and Ashrams.
11. The interest of public is not harmed by the baba of shivrashtra, a
state that is know all over the world for its religious centers. Accordingly,
mass prayers, retreats, yagnus, penance services etc. are conducted very
frequently for imparting religious education.

ISSUE 2: Whether the activities exploiting the religious

sentiments of the people amount to infringement of
fundamental rights of the people of indiva?

1. No. The activities exploiting the religious sentiments of the people do

amount to infringement of fundamental rights of the people as per Art. 25
of the constitution of Indiva there is freedom of conscience and free
profession, practice and propagation of religion. The people has right to
check the right or wrong about their religion, and also the persons has
the faith in the religious activities. They are doing these religious activitirs
by their own willingness.
2. It harms my religious sentiment as well as infringes Fundamental Rights
which are guaranteed by Constitution of Indiva.
3. Under Article 25 of Indiva constitution, the constitution ensures equal
freedom to all religions. At the same time, it is declared that the religion of
a person has nothing to doing the matters relating to social and economic
welfare of the people, which matters can be regulated or restricted by the
state, by law. It is thus, held that the right to freedom of religion, its scope
and significance is to be studied in the view of secular Democracy
established under the constitution.

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Art. 25 of the constitution guarantees freedom of religion to all persons in
India. It provides that all persons in India, subject to public order, morality,
health, and other provisions:

 Are equally entitled to freedom of conscience, and

 Have the right to freely, practices and propagate religion.

This means that all citizens are entitled to the aforesaid rights provided
that these do not contradict a public order, morality, health and
other provisions.
It further provides that this article shall not affect any existing law
and shall not prevent the state from making any law relating to:

 Regulation or restriction of any economic, financial, political, or

any secular activity associated with religious practice.
 Providing social welfare and reform.
 Opening of Hindu religious institution of public character far all
the classes and sections of the Hindus.

This means that the state can either condition the wording of existing laws
or make new laws so as to regulate and restrict financial, political,
economical or other secular activities associated with faiths. It further
facilitates social welfare and reform or opening of Hindu religious institution
of a public character that is open to all sections and classes of Hindus.
# In Ali v. Mansoor Ali the Bombay high court held that Art. 25 and 26 not
only prevents doctrines or beliefs of religious but also the act done in
pursuance of religion. It thus guarantees ceremonies, modes of worship,
rituals, observances, etc. which are an integral part of religion has to be
determined in the light of the doctrines and practices that are regarded by
the community as a part of their religion and also must be included in them.
WHAT IS RELIGION?
The German philosopher Immanuel Kant defines religion as ‘’Religion is
the recognition of all our duties as divine commands’’.
Milton Yinger, American sociologist defines ‘’a system of beliefs and
practice by means of which a group of people struggles with the
ultimate problems of human life”
The constitution does not define the term ‘religion’ and ‘matters of religion’.
Hence =, it is left to the SC to determine the judicial meaning of these terms
Art.26 (subject to public order, morality, and health) confers a right on
every religious denomination or any section of such religious denomination
of:

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 Establishing and maintaining institution for religious and charitable
purposes;
 Managing its affair with regard to religion:
 Owing and acquiring property (movable and immovable);
 Administering the property in accordance with the law.

4. The apex court in Ratilal v. State of Bombay, explained that religious

practices or performances of acts in pursuance of religious beliefs
were as much a part of religion as faith or belief in particular
doctrines. It was further impressed that no outside authority had any
right to say that those were not essential parts of religion and it was
not open to the secular authority of the state to restrict or prohibit
them in any manner they liked under the guise of administering the
trust estate. Practices which are regarded by a religious community as
part of its religion are also matters of religion. For instance, right to
burry dead bodies in a particular manner with particular rites in
consecrated places is part and parcel of certain religions.

A.S. Narayan v. State of Andhra Pradesh

- In this case, Justice Hansaria observed that ‘’our constitution makers had
used the word ‘’religion’’ in these two are. (Art.25 and 26) in the sense
conveyed by the word “dharma”. He further explained the difference
between religion and dharma as religion is enriched by visionary
methodology and theology, whereas dharma blooms in the realm of direct
experience. Religion contributes to the changing phases of a culture;
dharma enhances the beauty of spirituality. Religion may inspire one to
build a fragile, mortal him for god; dharma helps one to recognize the
immortal shrine in the heart.
- Article 25 to article 28 of the Indian constitution puts forth the right to
freedom of religion. Article 25(1) guarantees to every person the ‘freedom
of conscience’ and the right to profess, practice and propagate any religion
of ones choice in compliance to public order, morality and health.’’ The
term conscience highlights the celestial and spiritual part of the of the
religion that is much ahead of the state’s control.
- People are free to choice their own religion, even as it lashed out at a
‘’very, very harmful kind’’ of ‘public interest’’ petition claiming there is
mass religious conversion happening ‘’by hook or by crook’’ across the
country

ISSUE 4: Whether the ban on such math’s/ Ashrams would

violate the fundamental rights of the people to follow the
religion faith of their choice?

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1. Yes. It will affect my religious value and such ban would violate the
fundamental right of the people to follow the religious faith of their choice,
because under Article 25 to Article 27 it is the fundamental rights of
the people to follow their own choice of religion
2. The ban such Math’s/ Ashrams would violate the fundamental rights of
the people to follow the religious faith and discourage them to worship
god, visit temples or masjid. It will lead to people losing faith in God.
3. Religion is a matter of belief or faith. The constitution of India recognizes
the fact,how important religion is in the life of people of India and hence,
provides for theright to freedom of religion under Articles 25 to Article 28.
The Constitution of Indiaenvisages a secular model and provides that
every person has the right and freedom tochoose and practice his or her
religion.
4. This means that the state can either condition the working of existing law
or make new law so as to regulate and restrict financial, political,
economic, or other secular activities associated with faiths. It further
facilitates social welfare and reform or opening of Hindu religious
institution of a public character that is open to all sections and classes of
Hindus.
5. Matter of religion includes religious practices, rituals, observances,
ceremonies, modeand manner of worship, etc., regarded as the essential
and integral part of the religion.For instance, in Acharaj Singh v. State of
Bihar it was held that, if Bhog offered to thedeity is a well-established
practice of that religious institution, such a practice shouldbe regarded as
a part of that religion.
6. Thus, this ban on such Math’s/Ashrams does violate the fundamental
rights of the people to follow the religious faith of their choice as these
Math’s and Ashrams have been a place for religious and for people to
pray.
7. Bans on Math’s/Ashrams does lose faith in religious and in god.
Fundamental rights are subject to certain condition which the baba in the
present case has not violated and it is the choice of people that they
profess the teaching of the baba. The constitution of India provides the
people of India to profess and practice religion which they choose to
practice. The people of India who are following the baba have not made a
single complaint of fraud, miss-representation inducement and other
kinds of allegation. Therefore, the people of India are following the baba
with their own consent and conscience therefore to ban ashrams would be
an extreme step directly resulting on violating of fundamental rifts of the
people of India.
8. The people of shivrashtra, a state which is known all over the world for its
religious centers, have not raised a complaint or objection towards the
action taken by the baba. It is prejudice to ban the Math’s/Ashrams
based on a ‘’black magic prohibition act superstition’ are corrupt and
have violated the sentiments of the people.

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Religion is a matter of
belief or faith. The
constitution of India
recognizes the fact,
how important religion is
in the life of people of
India and hence,
provides for the
right to freedom of
religion under Articles 25
to Article 28. The
Constitution of India
envisages a secular
model and provides that
every person has the
right and freedom to
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choose and practice his
or her religion.
3. The Apex Court has
held that secularism is
the basic structure of the
Constitution, the
most important being the
Kesavananda Bharati
case. People in India
mainly practice
Islam, Hinduism,
Jainism, Buddhism,
Sikhism and,
Christianity. In India,
there are

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religion-specific laws and
Goa is the only state to
have a Uniform Civil
Code known
as the Goa Civil Code.
The Constitution
supports religious
harmony which means
the
people of India show love
and affection to different
religions of the country.

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 PRAYER

In the light of the issues raised, arguments presented, cases referred and
authorities cited, the counsel for the appellant humble pray this hon’ble
court to:

1. Shouldn’t allow the appeal filed;

2. The PIL filed under Art.32 of the constitution of India before the SC is not
maintainable;
3. The practice of activities baba’s which were supported by the Math’s and
Ashrams does not violate the Art.21, 32 and Art. 25-28 of the constitution of
India’;
4. Discharge the charges of sec 295A against the accused Godman babaram
since he is only following religious activities according to constitution.
5. That the defendant has not violate the fundamental rights of the indigenous
peoples and has not caused religious degradation;
6. Not to ban Math’s/Ashram as it neither harms the religious feeling of the
people nor affect the fundamental rights of the people nor affects the
fundamental rights of the citizen’;
7. Pass any other order, other order that it deems fit in the interest of justice,
equity and good conscience.
8. To grant any other relief which the Hon’ble court may deem think fit in the
eyes of justice, equity and good conscience.
9. Direct the centre and state to take appropriate steps to control black magic,
superstition and religious conversion by intimidating, threatening,
deceivingly luring through the gifts and monetary beliefs.

For this act of kindness, the respondent shall be duty bound Forever Pray.

Palace:

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Date:

(COUNSEL ON BEHALF OF THE RESPONDENT)

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