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LRTLAW005

BEFORE THE HON’BLE SUPREME COURT OF INDIA

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SPECIAL LEAVE PETITION NO : _____ OF 2023

(CIVIL APPELLATE JURIDICTION)

UNDER ARTICLE OF 136 OF CONSTITUTION OF MEDISTHAN

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IN THE MATTER OF:

IN SUPREME COURT

ZAHIRA………………………………………………………………………….….PETITIONER

V/S

1. UNION OF MEDISTHAN

2. STATE OF
TARKASTHAN…………………………………………………………………….RESPONDENT

UPON SUBMISSION TO THE HON’BLE CHIEF JUSTICE OF THE SUPREME COURT OF

MEDISTHAN

MEMORANDUM ON BEHALF OF THE RESPONDENT

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 TABLE OF CONTENT

SR. NO. CONTENT PAGE NUMBER

1. LIST OF ABBREVIATION 3

2. INDEX OF AUTHORITIES 4

3. STATEMENT OF 5
JURISDICTION

4. STATEMENT OF FACTS 6

5. ISSUES RAISED 8

6. SUMMARY OF 9
ARGUMENTS

7. ARGUMENT ADVANCED 10

8. PRAYER 18

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 LIST OF ABBREVIATION
1. &- and
2. v/s – versus
3. SCC – Supreme Court Case
4. SCR- Supreme Court Report
5. A.I.R –All India Report
6. Hon’ble – Honorable
7. Ors – Others
8. i.e – that is
9. Retd. – Retired
10. SA- Second Appeal
11. CC –Calendar Case
12. DPSP – Directive Principle Of State Policy
13. Etc. – et cetra
14. Nos. - Numbers

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 INDEX OF AUTHORITIES

➢ WOMEN’S VOICE V/S STATE OF KARNATAKA & ORS SLP NO. (C) 15403
OF 2022
➢ A. SRI VENKATARAMAN DEVARU V/S STATE OF MYSORE 1958 AIR
255,1958 SCR 895
➢ AMNAH BINT BASHEER V/S CENTRAL BOARD OF SECONDARY
EDUCATION,2016
➢ AMNAH BINT BASHEER V/S CENTRAL BOARD OF SECONDARY
EDUCATION,2016
➢ TIRATH RAM RAJIDRANATH, LUCKNOW V/S STATE OF U.P. &
ANOTHER,DECEMBER 5,1972
➢ LILA DHAR V/S STATE OF RAJASTHAN AND OTHERS , 17 DECEMBER, 1973
➢ STATE OF KERALA & OTHERS V/S TRAVANCORE CHEMICALS AND
MANUFACTURING & OTHERS
➢ INDIAN YOUNG LAWYER ASSOCIATION & ORS. VS. STATE OF
KERALA & ORS. CITATION: 2018 SCC ONLINE SC 1690
➢ BIJOE EMMANUEL & ORS VS STATE OF KERALA & ORS ON 11 AUGUST,
1986 AIR 748, 1986 SCR (3) 518
➢ NATIONAL LEGAL SERVICES AUTHORITY VS. UNION OF INDIA, AIR
2014 SC 1863; (2014) 5 SCC 438
➢ JUSTICE K.S. PUTTASWAMY (RETD.) & ANR. VS. UNION OF INDIA & ORS,
(2017) 10 SCC 1, AIR 2017 SC 4161
➢ CHRISTIAN EDUCATION SOUTH AFRICA V MINISTER OF EDUCATION
(2000) (4) SA 757 (CC)
➢ SUGANMAL VS STATE OF MADHYA PRADESH AND ORS. 4 NOVEMBER,
1964 AIR 1965 SC 1740
➢ SRI. D.L CHOWDA REDD... V. THE STATE OF KARNATAKA,NOV 26, 2012
➢ P.R MURLIDHARAN AND OTHERS V. SWAMI DHARMANANDA THEERTHA
PADAR AND OTHERS ,MAR 10, 2006

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 STATEMENT OF JURISDICTION

Hon’ble Supreme Court of India has the Civil Appellate Jurisdiction of this matter which is
submitted by Zahira & Ors reviewing petition against state of Tarkasthan under Article 136 of
Constitution of Medisthan.

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 STATEMENT OF FACTS

1. Medisthan is a sovereign, socialist, democratic, republic country which consists of 28

constituent states and 9 union territories which is located in Sule continent region of Bisa
Medisthan is second world’s largest populated nation with demography of 138 crore
individuals. Its strong constitution is a safe guard which protects people with diverse
culture, traditions, languages and religions. It seeks to protect interest of all communities
and their aim is to treat everyone at par with each other.
2. Majority of population of Medisthan practice the Medi religion that is 79.80%. Along with
them several religious minorities are prevelant. After Medi, Barun is the most followed
religion. Those who follow Barun wear purdah or any other head gear or garment covering
the head as a part of their practice.
3. Tarkastan is one of the constituent state of Medisthan situated in southern region. In
December 2021, one of the educational institutions by name. Bambipur Collge in Tarkastan,
issued a direction that banned students from wearing purdah or any other head gear or
garment covering the head. Those students who practiced purdah or any other head gear or
garment were insisted by college to remove the purdah before entering the class.
The directives read as:
Within the campus all students shall wear the uniform dress code as prescribed.
a. Navy blue trousers and white shirt of male students
b. Navy blue kurta, white salwar and white waist coat for female students.
c. Trans-genders may choose between (a) and (b) as per their gender identity.
4. The circular created a disturbed environment among the students community due to sudden
imposition of uniform on the students. A few members of faculty were deputed at college
entry to only permit there students who abide by the code to insure that students follow
dress code. Some girls wearing purdah were denied entry campus as it violated the dress
code. A student by name Zahira filed a writ petition before the high court Tarkastan in
January 2022.
5. Another college by the name of Saraswati Education Excellence, through its college
development cell issued a directive in March 2022 stating that no students shall display any
religious or cultural symbols inside the college premises. Some students were wearing
Purdah and were stopped at the entrance and were ordered to before it before attending the
class. The students raised concern with the cell as according to them wearing purdah is a
long standing tradition as part of their religion. On this the college stated the students were
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 free to practice their religious tradition outside the premises of the college. Removing it for
few hour does not violates the loyalty of their religion.
6. The government issued order under Tarkastan Education ACT, 1983 on 15th June 2022
confirming the rule that students shall attend classes without wearing Purdah. A writ petition
was
preferred by the students approached the High court of Tarkastan in August 2022. The
petitioner prayed that appropriate writ in nature of mandamus and that Impugned Directive
shall be squashed.
7. The High Court clubbed these and other Writ petition of dress code which is issued by
various Education institutions and listed them together to hear on September 2022. Looking
at the merits of the case, High Court in December 2022 declared in Zahira & Ors v/s State
of Tarkastan that regulations used by Education Institution of Dress Code for Students seek
to consider them as one Homogeneous class and to serve constitutional Secularis. School
uniform promote Harmony and spirit of common brotherhood transcending religious or
sectional diversities hence, the writ petition filed as PIL was rejected and disposed oft.
When Aggrieved by decision of High court ,the petitioners have approached the Hon’ble
supreme court of medisthan with special leave to appeal. The matter listed is to be Argued
on 10th March 2023.

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 STATEMENT OF ISSUES

➢ Whether Special Petitioner Leave filed by the Petitioner maintainable before supreme
court of Medisthan?
➢ Whether practice of Purdah or Other head garment is protectionable under Article 25 of
Constitution of Medisthan constituting essential religious practice?
➢ Whether order issued by the government of Tarkasthan arbitrary in nature?
➢ Whether instruction given by educational institution violates the Part III of the constitution?
➢ Whether the order derogates the International Convention of Women’s Right?
➢ Whether order issued by Government violates Part IV of Constitution?
➢ Whether rules are acceptable as per public orders under the Mandamus?

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 SUMMARY OF ARGUEMENTS

1. Petitioners or the students wear purdah or the headgear as their belief in their religion.
And practicing it has been the part of their essential religious belief. The action taken
by the Respondent over the removal of the purdah is impermissible as it violates the
basic rights of citizen under Article 25 of the constitution. Hence, it is pleaded to take
action against the Impugned Government and the Educational Institution.
2. The orders narrated by the State Government was structured in a wrong pattern stating
it as not being relevant part of their religion whereas the decision violates the freedom
of conscience and right to practice their religious faith under Article 25 of the
Constitution.
3. Their decision also violates the ‘doctrine of proportionality ‘because administrative
actions should not be more drastic than it ought to be for obtaining the desired results.
Hence, such action would be proven wrong for its people.
4. One’s dressing choice is preserved under freedom of expression by our constitution.
Hence the issue of not allowing them to practice their faith is repugnant to Article 19(1)
(a) & 21.
5. The order of the state government is believe to be arbitrary in nature, so as to forcefully
imposing the law which is contrary to its nature of working as per Democratic
Government norms.
6. The rules promulgated under the state act, do not authorize prescription of dress code or
uniform at all. It is the matter of ‘police power’ which does not avail in the absence of
statutory enablement and is therefore is incompetent to be tapped.
7. The orders given by the state government or the development committee or the
educational institutional, as per the ground of ‘public order’ is not acceptable as it also
derogates the gender based rights of an individual which goes beyond their authority as
an institution. Hence they are liable under the writ of Mandamus and decision should
be given as to preserve the rights of citizens of Medisthan.

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 ARGUREMENTS ADVANCED

1. Whether Special Petitioner Leave filed by the Petitioner maintainable

before supreme court of Medisthan?

The present petition is maintainable under Article 136 of Constitution of Medisthan, since
this case falls in the Appellate jurisdiction of Supreme Court of Medisthan as Enlisted by
the Constitution. The previous decision given by the state of Tarkastan is unjustifiable
and hence the petitioner can claim for its right under the jurisdiction of civil Appellate.

CITATION- WOMEN’S VOICE V/S STATE OF KARNATAKA & ORS SLP NO. (C)
15403 OF 2022
Due to the instruction of the said state, women were held not to wear veil in the institution
as the essential part of their religious practice which violated their Fundamental rights.
Hence, SLP was filed to challenge the decision of hon’ble High court.

ARTICLE 136- Special leave to appeal by the Supreme Court

(1) Notwithstanding anything in this Chapter, the Supreme Court may, in its discretion,
grant special leave to appeal from any judgment, decree, determination, sentence or order
in any cause or matter passed or made by any court or tribunal in the territory of India
(2) Nothing in clause (1) shall apply to any judgment, determination, and sentence or
order passed or made by any court or tribunal constituted by or under any law relating to
the Armed Forces.

2. Whether practice of Purdah or Other head garment is protectionable under

Article 25 of Constitution of Medisthan constituting essential religious practice?
One has the right to appear in the Way they want because dressing is a protected zone
within Freedom of Conscience. Whichever society you belong, you can never separate
social life with religious life. Practise of different belief of one’s individual is protected
by our constitution of Medisthan. Article 25 gives the freedom to all the people of our
country to practice different religious belief in one’s good faith and has been preserved
in freedom of Conscience. Hence, practicing of purdah or any other headgear is protected
by our Article 25 of our constitution. The order passed by the High Court infringes the
Fundamental Right of the petitioner to follow their faith and not only to follow but also
to propagate the ideas.

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 CITATION-
A. SRI VENKATARAMAN DEVARU V/S STATE OF MYSORE 1958 AIR 255,1958
SCR 895
The Supreme Court decision held that not merely temples dedicated to thee pulic as a
whole but also those founded some benefits of some sections are contemplated in article
25 which provides throwing open the religious places to all the classes an sections of
Hindus.
B. AMNAH BINT BASHEER V/S CENTRAL BOARD OF SECONDARY
EDUCATION 2016.
It was held that it is right of women to have choices of dresses based on the religious
injunction is a fundamental right protected under article 25(1) when such prescription of
dress is an essential part of the religion .
C.AMNAH BINT BASHEER V/S CENTRAL BOARD OF SECONDARY
EDUCATION 2016
It was held that there is almost unanimity amongst religious scholars that Purdah is not
essentials but covering of head gear is obligatory.
Article 25 - (Freedom of conscience and free profession, practice and propagation of
religion) Article 25 guarantees the freedom of conscience, the freedom to profess,
practice and propagate religion to all citizens.
• The above-mentioned freedoms are subject to public order, health and morality.
• This article also gives a provision that the State can make laws:
• That regulates and restricts any financial, economic, political or other secular activity
associated with any religious practice.
• That provides for the social welfare and reform or opening up of Hindu religious
institutions of a public character to all sections and classes of Hindus. Under this
provision, Hindus are construed as including the people professing the Sikh, Jain or
Buddhist religions and Hindu institutions shall also be construed accordingly.
• People of the Sikh faith wearing & carrying thekirpan shall be considered as included
in the profession of the Sikh religion.
3. Whether order issued by the government of Tarkastan arbitrary in nature?
The order which was given by the state of Tarkastan manifests the arbitrariness of the
state to impose such orders which is enforceable beyond the acceptance of its people.
Such powers of the state government violates the basic fundamental rights if the citizens.
Under this case, the arbitrariness of the state to impose restriction on the wearing of the

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purdah or headgear violates the right to equal treatment and freedom to profess their
religious belief.
CITATION-
A. TIRATH RAM RAJIDRANATH, LUCKNOW V/S STATE OF U.P. &
ANOTHER,DECEMBER 5,1972
Government and further the power conferred under Section 3-A to the Government was
an arbitrary power and consequently it was violative of Article 14 of the
Constitution...conferred on the Government . That question no more arises for
consideration. It is well settled that the Legislature has wide powers of classification in
the case of taxing statutes...discretion conferred on the Government is
an arbitrary discretion. As seen earlier, the Legislature has now incorporated the
impugned notifications as part of Section 3-AB.
B. LILA DHAR V/S STATE OF RAJASTHAN AND OTHERS , 17 DECEMBER, 1973
It was stated that using arbitrary power for selection of the candidate in civil
examination violates the fundamental rights of other candidates. Hence, decision was
given against the respondent preserving the rights and questioned the arbitrary power of
the organisation.
C. STATE OF KERALA & OTHERS V/S TRAVANCORE CHEMICALS AND
MANUFACTURING & OTHERS
The made provisions of the state of Karnataka gave arbitrary to the companies for its
manufacturing violating Article 14. Hence, the Act was strike down and the Appeal was
dismissed with the effective cost.
4. Whether instruction given by educational institution violates the Part III of the
constitution?
1 The action of the respondent over the removal of the purdah or the headgear in the
educational Institution is impermissible as it violated the Fundamental right under
Article 25 of the Constitution,
2 The wrongful narrative of essential religious practice by the Institution violates the
Freedom Of Conscience and right to Practice their religious Faith.
3 What one wears and how one dresses is a matter of individual choice protected under
‘privacy jurisprudence’ violating the Article 19(1) (a) & 21.
4 Stopping the students to enter the institution for taking education due to some
arbitrary rules violates their Right to Education.
5 Proscribing Purdah in the Educational Institution apart from offending women’s
That a practice claimed to be essential to the religion has been carried on since time
immemorial or is grounded in religious texts per se does not lend to it the

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 constitutional protection unless it passes the test of essentiality as is adjudged by the
Courts in their role as the guardians of the Constitution. autonomy is violative of
Article 14 which amounts to Gender based discrimination which Article 15 does not
permits.

CITATION-
A. INDIAN YOUNG LAWYER ASSOCIATION & ORS. VS. STATE OF KERALA
& ORS. 2018 SCC Online SC 1690
The decision was held that a practice claimed to be essential to the religion has been
carried on since time immemorial or is grounded in religious texts per se does not lend to
it the constitutional protection unless it passes the test of essentiality as is adjudged by
the Courts in their role as the guardians of the Constitution.

B. BIJOE EMMANUEL & ORS VS STATE OF KERALA & ORS ON 11

AUGUST, 1986 AIR 748, 1986 SCR (3) 518
The decision turned out to be more on the right to religion than freedom of conscience,
although there is some reference to the conscience. The court recognized the negative of
a fundamental right i.e., the freedom of speech & expression guaranteed under Article 19
as including right to remain silent. What weighed with the court was the fact ‘the children
were well behaved, they respectfully stood up when the National Anthem was sung and
would continue to do so respectfully in the future’. Besides, Court found that their refusal
to sing was not confined to Indian National Anthem but extended to the Songs of every
other country.
C. NATIONAL LEGAL SERVICES AUTHORITY VS. UNION OF INDIA, AIR 2014
SC 1863; (2014) 5 SCC 438
The Court held that the recognition of one’s gender identity lay at the heart of the right to
dignity, and that gender identity was a fundamental aspect of life. The Court also noted
several international instruments supporting this proposition, including the Yogyakarta
Principles on the Application of International Human Rights Law in relation to Sexual
Orientation and Gender Identity (Yogyakarta Principles) as well as cases from various
foreign courts. The Court further recognised the interrelationship of the right to privacy
and the right to gender identity, and imposed a positive duty on the State to protect and
recognise such rights.
D. JUSTICE K.S. PUTTASWAMY (RETD.) & ANR. VS. UNION OF INDIA & ORS, (2017)
10 SCC 1, AIR 2017 SC 4161
The Supreme Court, through six separate opinions, pronounced privacy to be a distinct
and independent fundamental right under Article 21 of the Constitution. The crux of the
decision spelled out an expansive interpretation of the right to privacy - it was not a
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 narrow right against physical invasion, or a derivative right under Article 21, but one that
covered the body and mind, including decisions, choices, information and freedom.
Privacy was held to be an overarching right of Part III of the Constitution which was
enforceable and multifaceted. The

judgement held informational privacy to be a part of the right to privacy. The Court while
noting the need for a data protection law left it in the domain of Parliament to legislate on
the subject.

ARTICLE 14: EQUALITY BEFORE LAW

The State shall not deny to any person equality before the law or the equal protection of
the laws within the territory of India.
ARTICLE 15 : PROHIBITION OF DISCRIMINATION ON GROUNDS OF
RELIGION, RACE, CASTE, SEX OR PLACE OF BIRTH
(1) The State shall not discriminate against any citizen on grounds only of religion, race,
caste, sex, place of birth or any of them.
(2) No citizen shall, on ground only of religion, race, caste, sex, place of birth or any
of them, be subject to any disability, liability, restriction or condition with regard to –
(a) access to shops, public restaurants, hotels and places of public entertainment; or
(b) the use of wells, tanks, bathing ghats, roads and places of public resort maintained
whole or partly out of State funds or dedicated to the use of general public.
(3) Nothing in this article shall prevent the State from making any special provision
for women and children.
(4) Nothing in this article or in clause (2) or article 29 shall prevent the State from
making and special provision for the advancement of any socially and educationally
backward classes of citizens or for the Scheduled Castes and the Scheduled Tribes.
ARTICLE 19 : PROTECTION OF CERTAIN RIGHTS REGARDING
FREEDOM OF SPEECH, ETC.
All citizens shall have the right –
(a) to freedom of speech and expression;
(b) to assemble peaceably and without arms;
(c) to form associations or unions;
(d) to move freely throughout the territory of India;
(e) to reside and settle in any part of the territory of India; and
(f) to practice any profession, or to carry on any occupation, trade or business.
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 ARTICLE 21 : PROTECTION OF LIFE AND PERSONAL LIBERTY

No person shall be deprived of his life or personal liberty except according

to procedure established by law.
Article 21A: Right to education
The State shall provide free and compulsory education to all children of the age of six
to fourteen years in such manner as the State may, by law, determine.

ARTICLE 25 : FREEDOM OF CONSCIENCE AND FREE PROFESSION, PRACTICE

AND PROPAGATION OF RELIGION
(1) Subject to public order, morality and health and to the other provisions of this Part, all
persons are equally entitled to freedom of conscience and the right freely to profess,
practice and propagate religion.
(2) Nothing in this article shall affect the operation of any existing law or prevent the
State from making any law –
(a) regulating or restricting any economic, financial, political or other secular activity
which may be associated with religious practice;
(b) providing for social welfare and reform or the throwing open of Hindu religious
institutions of a public character to all classes and sections of Hindus.
Explanation I: The wearing and carrying of kirpans shall be deemed to be included in
the profession of the Sikh religion.
Explanation II: In sub-Clause (b) of clause (2), the reference to Hindus shall be
construed as including a reference to persons professing the Sikh, Jaina or Buddhist
religion, and the reference to Hindu religious institutions shall be construed
accordingly.

5. Whether the order derogates the International Convention of Women’s Right?

Under our Constitutional Jurisprudence, owing to Article 51 which provides for
promotion of international peace & security, the International Conventions of the kind
assume a significant role in construing the welfare legislations and the statutes which have
kinship to the subject matter of such Conventions. In a sense, these instruments of
International Law permeate into our domestic law. Throughout, there has been both
legislative & judicial process to emancipate women from pernicious discrimination in all
its forms and means.
ARTICLE OF UNIVERSAL DECLARATION OF WOMEN’S RIGHT

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 Article 3-Women are entitled to the equal enjoyment and protection of all human rights
and fundamental freedoms in the political, economic, social, cultural, civil or any other
field. These rights include, inter alia :

a. The right to life;

b. The right to equality;
c. The right to liberty and security of person;
d. The right to equal protection under the law;
e. The right to be free from all forms of discrimination;
f. The right to the highest standard attainable of physical and mental health;
g. The right to just and favourable conditions of work;
h. The right not to be subjected to torture, or other cruel, inhuman or degrading treatment or
punishment.

CITATION
A. CHRISTIAN EDUCATION SOUTH AFRICA V MINISTER OF EDUCATION
(2000) (4) SA 757 (CC)
Court held that while the relevant parents could no longer authorize teachers to apply
corporal punishment in their name pursuant to their beliefs, they were not being deprived
by law of their general right and capacity to bring up their children according to their
Christian beliefs.

6. Whether order issued by Government violates Part IV of Constitution

It is the state responsibility to perform the state duties guided under The Directive
Principle Of State Policy making them liable for all the injustice happening to their
citizens. Article 51 of DPSP of our constitution describes the role of the state to promote,
maintain and respect the international laws and treaty. Such convention has made norms
to preserve the rights which includes, no discrimination towards women, equal treatment
to all, right to life etc. therefore the orders stated by the institution as well as the state
were incapable for practising Article 51 as their responsibility.
Article 51- (3) foster respect for international law and treaty obligations in the
dealings of organised peoples with one another; and encourage settlement of
international disputes by arbitration PART IVA FUNDAMENTAL DUTIES.
7. Whether rules are acceptable as per public orders under the Mandamus?

It is rightly argues that the Government order cites ‘SARVAJANIKA SUVYAVASTHA’ i.e.
‘public order’ as one of the reasons for prescribing uniform to the removal of Purdah or
any headgear disruption of public order is not by those who wear it but those who oppose

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 it. The government as well as the institution should take action against the hooligan who
try to disrupt the harmony and peace. Being ‘Positive Secularism’ the state should create
congenial atmosphere for the exercise of rightful citizen’s right. Government Order such
as ‘public order’, etc., cannot be construed as the ones employed in the Constitution or
Statutes. There is a sea of difference in the textual structuring of legislation and in
promulgating a statutory order as the one at hands. Whereas Mandumus command is
used by courts of superior jurisdiction to compel the performance of a specific act refused
by a lower court, such as the hearing of a case falling within the latter's authority. Hence,
writ of mandamus is a justiciable decision used as a citizen.

CITATION

A. SUGANMAL VS STATE OF MADHYA PRADESH AND ORS. 4

NOVEMBER, 1964 AIR 1965 SC 1740
Constitution presented by the Appellate for the issue of a writ of mandamus against the
State of Madhya Bharat and its officers, the Special Tax Commissioner and the
Assessing Officer, praying for the issue of a writ of mandamus against the
State of Madhya Bharat and the other respondents, directing them to perform their
statutory duty and/or to refund or cause to be refunded to the statutory obligation on the
State to refund the amount, that the order of the Appellate.

B. SRI. D.L CHOWDA REDD... V. THE STATE OF KARNATAKA,NOV 26, 2012

the writ petitions is for a mandamus directing the respondents to take into account the
services of the petitioners from the date of their initial entry i.e. from the
date of appointment, instead ...writ of mandamus is to compel performance of a legal
duty. A mandamus will be issued to a person aggrieved who approaches the Court, if he
makes out (i) existence of a legal right in him and for the
issue of a Writ of Mandamus is concerned, it should always be preceded by a demand
and refusal.

C. P.R MURLIDHARAN AND OTHERS V. SWAMI DHARMANANDA THEERTHA

PADAR AND OTHERS ,MAR 10, 2006
Seeking a writ of mandamus directing the police authorities to give protection to
a writ petitioner, cannot be made a forum for adjudicating on civil rights. It is one thing
to approach the High Court is quite another thing to seek a writ of mandamus directing
protection in respect of property, status or right which remains to be adjudicated upon
and when such an adjudication can only be got done in a properly instituted civil suit.

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 Therefore, all the arguments advances for the judgement in favor of the Petitioner

PRAYER

In the light of the issues raised, argument advanced and authorities cited, may this Hon’ble court be
pleased to:

1. That the Special Leave petition of the applicant be accepted ;

2. Declare that Writ of Mandamus will be issued as there is violation of any fundamental right;
3. Declare that wearing of Purdah or any headgear is permissible as per the rights of the citizens.
4. Declare that there should be changes in the Public orders made by the Government;

AND/OR
Pass any order that it deems fit in the interest of Justice, Equality and Good Conscience. And for
this, the respondent as in duty bound, shall humbly pray.

MEMORIAL ON BEHALF OF THE PETITIONER

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