2nd Deo Mangal Memorial National Moot Court Competition, 2023

Team Code- NSL08

2ND DEO MANGAL MEMORIAL NATIONAL MOOT COURT COMPETITION, 2023

12 - 14TH OCTOBER, 2023
_________________________________________________________________________________________

BEFORE THE HON’BLE SUPREME COURT OF ARYAVRAT

ORIGINAL WRIT JURISDICTION

PUBLIC INTEREST LITIGATION

UNDER ARTICLE 32 OF THE CONSTITUTION OF ARYAVRAT

WRIT PETITION NO. ______________ OF 2023

IN THE MATTER OF –

SAMRIDHI & Anr …. PETITIONERS

V.

UNION OF ARYAVRAT …...RESPONDENT

UPON SUBMISSION TO

THE HON’BLE CHIEF JUSTICE AND HIS COMPANION JUDGES

OF

THE HONOURABLE SUPREME COURT OF ARYAVRAT

________________________________________________________________

[MEMORANDUM ON BEHALF OF THE PETITIONERS]

________________________________________________________________

[MEMORIAL ON BEHALF OF THE PETITIONERS] I

 2nd Deo Mangal Memorial National Moot Court Competition, 2023

_________________________________________________________________________________________
TABLE OF CONTENTS
_________________________________________________________________________________________

INDEX OF AUTHORITIES ........................................................................................................... III

LIST OF ABBREVIATIONS ............................................................................................................ IV
STATEMENT OF JURISDICTION ................................................................................................. V
STATEMENT OF FACTS ................................................................................................................. VI, VII
ISSUES RAISED ............................................................................................................................... VIII
SUMMARY OF ARGUMENTS .......................................................................................................... IX, X
ARGUMENTS ADVANCED ............................................................................................................... 1–5
PRAYER……………………………………………………………………………………………...... 6

[MEMORIAL ON BEHALF OF THE PETITIONERS] II

 2nd Deo Mangal Memorial National Moot Court Competition, 2023

_________________________________________________________________________________________
INDEX OF AUTHORITIES
_________________________________________________________________________________________
◆ CASE LAWS:
Sl. CASE CITATION PAGE
No.
1 “Bhagwan Dutt v. Smt. Kamala Devi and Anr” 1975 AIR 83, 1975 2
SCR (2) 483

2. “Sarala Mudgal & Others v. Union of India” 1995 AIR 1531, 3

1995 SCC (3) 635
3. “Shah Bano v. Union of India & Ors” AIR 2017 9 SCC 1 3
(SC)

◆ STATUTES:
1. The Constitution of India, 1950
2. The Special Marriage Act, 1954
3. The Registration Of Births And Deaths Act, 1969

◆ BOOKS:
1. Commentary on the Constitution of India, Durga Das Basu, Lexis Nexis (8th edition, 2008).
2. Constitutional Law of India, Dr. Narendra Kumar, Allahabad Law Agency (10th edition,2018)

[MEMORIAL ON BEHALF OF THE PETITIONERS] III

 2nd Deo Mangal Memorial National Moot Court Competition, 2023

________________________________________________________________________________________
LIST OF ABBREVIATIONS
_________________________________________________________________________________________

ABBREVIATIONS EXPANSION

& And

AIR All India Reporter

Art. Article

Anr. Another

Cr. P.C. The Code of Criminal

Procedure, 1973
LGBTQIA+ Lesbian, Gay, Bisexual,
Transgender, Queer, Intersex,
and Asexual and all other
Communities
No. Number

Ors. Others

Sec. Section

SC Supreme Court

SCC Supreme Court Cases

SCR Supreme Court Reports

v. Versus

UCC Uniform Civil Code.

[MEMORIAL ON BEHALF OF THE PETITIONERS] IV

 2nd Deo Mangal Memorial National Moot Court Competition, 2023

_________________________________________________________________________________________
STATEMENTS OF JURISDICTION
_________________________________________________________________________________________
THE PETITIONERS HEREIN HAVE INVOKED THE WRIT JURISDICTION OF THIS
HONORABLE COURT UNDER ARTICLE 32 OF THE CONSTITUTION OF ARYAVRAT.

Article 32 read as-

“32. Remedies for enforcement of rights conferred by this Part:

(1) The right to move the Supreme Court by appropriate proceedings for the enforcement of the rights
conferred by this Part is guaranteed

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

(3) Without prejudice to the powers conferred on the Supreme Court by clauses (1) and (2), Parliament
may by law empower any other court to exercise within the local limits of its jurisdiction all or any
of the powers exercisable by the Supreme Court under clause (2)

(4) The right guaranteed by this article shall not be suspended except as otherwise provided for by this
Constitution”

[MEMORIAL ON BEHALF OF THE PETITIONERS] V

 2nd Deo Mangal Memorial National Moot Court Competition, 2023

_________________________________________________________________________________________
STATEMENTS OF FACTS
_________________________________________________________________________________________
1. Aryavrat, a Sovereign Country in Asiana continent, consisting of 28 States and 8 Union territories,
has the population of around 140 crores where 70% people belong to Hinduism, i.e., in majority
religion, other 20% are from Islam, and the rest 10% practice other religions. Out of the 28 states
only the State of Kankan which was a Portuguese colony has successfully implemented Uniform
Civil Code in the country.

2. An adult Hindu Trans-man, namely Mrinal, having relationship with One Akram, an adult Muslim
Trans-woman since 2010, both are residents of Avanti State which does not have Uniform Civil
Code (hereinafter referred as UCC). After 2018 both of them revealed their relationship publicly as
because the hon’ble Supreme Court of Aryavrat decriminalized homosexuality on the same year.

3. Although, the Supreme Court of Aryavrat by decriminalizing homosexuality, ensured a special

position of the members of LGBTQIA community, but they still face discriminations and stigmas
in the society as the societal norm had only male and female stratum. One of the discriminations is
the couples from the LGBTQIA communities do not have their marriage certificates, if they marry.

4. Despite of being customarily married to disclose their relationship with respecting each other’s
faith and respective customs, the trans couple were unable to get their marriage officially registered
as neither of them fall under the definitions of ‘bride’ and ‘groom’ and belonged to different
religion.
5. After the customary marriage Mrinal gave birth to a baby boy for whom they were unable to get
the birth certificate as the same required for the name of father and mother and the marriage
certificate of them. Their problem got complicated when inspite of being gave birth to a baby boy,
Mrinal desired to be the father of that baby.

6. They also tried to get their marriage registered when applications for getting the birth certificate
was rejected previously by the authorities in the State of Avanti, the same was also rejected by the
respective authorities as the lack of UCC. As there is no way to solve their problems, they finally
approached before the hon’ble Supreme Court of Aryavrat vide filing a writ petition under Article
32 of the Constitution of Aryavrat for the issuance of the birth certificate, recognition of their
marriage and the implementation of UCC which recognizes same sex marriage and inter-religious
marriage.

[MEMORIAL ON BEHALF OF THE PETITIONERS] VI

 2nd Deo Mangal Memorial National Moot Court Competition, 2023

7. Meanwhile, an NGO- Samridhi, working for the welfare of Muslim women, had filed Public
Interest Litigation (PIL) before the Hon’ble Supreme Court, seeking to implement UCC throughout
the country of Aryavrat.

8. The Hon’ble Supreme Court has clubbed the Writ Petition and the PIL as both of that petitions
mainly aim to the implementation of UCC throughout the country.

9. The All-Indus Muslim Personal Law Board has filed an Impleading Petition in both the Public
Interest Litigations filed by the NGO and the Trans-couple in respect of violation of secular
structure of the Aryavrat, as they opposed Implementation of Uniform Civil Code by stating that it
infringes their personal right and the same is in violation of the rights granted under the
Constitution.

10. Despite of being an election agenda of the government of Aryavrat to impose Uniform Civil Code,
the Government is opposing a Uniform Civil Code which recognizes LGBTQIA Community as
well as opposing the PIL filed by the Trans-couple on the ground of maintainability as they have an
alternative remedy.

11. As the Trans-Couple find them not to be a necessary party to the proceedings, they are opposing
the Impleading Petition filed by All Indus Muslim Personal Law Board. The Supreme Court
recognizing the importance of the case had permitted live telecast of the hearings and posted all
applications together along with the question of maintainability of PIL and necessity of impleading
Indus Muslim Personal Law Board for hearing.

[MEMORIAL ON BEHALF OF THE PETITIONERS] VII

 2nd Deo Mangal Memorial National Moot Court Competition, 2023

_________________________________________________________________________________________
ISSUES RAISED
_________________________________________________________________________________________

1. Whether the PIL is maintainable in the Supreme court of Aryavrat or not and is it feasible to implement
Uniform Civil Code in a Country like Aryavrat?

2. Whether UCC is violative of one’s’ Fundamental rights and other personal rights guaranteed under the
Constitution of Aryavrat and is it the States’s interference in the realm of the personal laws of the
subjects?

3. Whether the non-issuance of the Birth Certificate for the child born from a LGBTQIA couple is
violation of the Child’s right by the state?

4. Whether the Constitutional power of Court to frame laws has led to the scenario where Legislature have
become the Executive wing of the Judiciary?

[MEMORIAL ON BEHALF OF THE PETITIONERS] VIII

 2nd Deo Mangal Memorial National Moot Court Competition, 2023

_________________________________________________________________________________________
SUMMARY OF ARGUMENTS
_________________________________________________________________________________________
1. WHETHER THE PIL IS MAINTAINABLE IN THE SUPREME COURT OF ARYAVRAT OR NOT
AND IS IT FEASIBLE TO IMPLEMENT UNIFORM CIVIL CODE IN A COUNTRY LIKE
ARYAVRAT?

The Ld. Counsel for the Petitioners most humbly submit before the Hon’ble Court that
the PIL is maintainable under Article 32 of the Constitution of Aryavrat because
current legislations do not recognise the marriage between the members of LGBTQIA
community, which are violative of Article 21 of the constitution.

In the state of Kankan, the Uniform Civil Code has already been implemented a long
ago. Moreover, the Constitution of Aryavrat under Article 44 directs the states for the
implementation of Uniform Civil Code. So, if the Uniform Civil Code is implemented
throughout the country, it will guarantee ‘Equality before law’ and will also guarantee
the ‘prohibition of discriminations on ground of sex’ to the members of LGBTQIA
community.

2. WHETHER UCC IS VIOLATIVE OF ONE’S’ FUNDAMENTAL RIGHTS AND OTHER

PERSONAL RIGHTS GUARANTEED UNDER THE CONSTITUTION OF ARYAVRAT AND IS IT
THE STATES’S INTERFERENCE IN THE REALM OF THE PERSONAL LAWS OF THE
SUBJECTS?

The Ld. Counsel for the Petitioners humbly submit before the Hon’ble Court that UCC is
not violative of one’s’ fundamental rights and other personal rights guaranteed under the
constitution of Aryavrat as the implementation of UCC will promote humanity, equality,
modesty among the society and tackle the privileges based on religion or community
while the personal laws are gender biased and not promote the above-mentioned
principles.

The States’s interference is not in the realm of the personal laws of the subjects as the
UCC aims to provide the principles of universal development throughout the country to
extinguish the discrimination on the grounds of religion, race, caste, sex, or place of
birth.

[MEMORIAL ON BEHALF OF THE PETITIONERS] IX

 2nd Deo Mangal Memorial National Moot Court Competition, 2023

3. WHETHER THE NON-ISSUANCE OF THE BIRTH CERTIFICATE FOR THE CHILD BORN
FROM A LGBTQIA COUPLE IS VIOLATION OF THE CHILD’S RIGHT BY THE STATE?

The Counsel for the Petitioners humbly submit before the Hon’ble Court that the non-issuance of birth
certificate for the child born from a LGBTQIA couples is obviously violation of the child’s right by
the state as it itself broadly violates the rights to life and personal liberty under Article 21 of the
Constitution.

4. WHETHER THE CONSTITUTIONAL POWER OF COURT TO FRAME LAWS HAS LED TO THE
SCENARIO WHERE LEGISLATURE HAVE BECOME THE EXECUTIVE WING OF THE
JUDICIARY?

The Counsel for the Petitioners humbly submit before the Hon’ble Court that the
Supreme Court is considered as the watchdog of the Constitution of Aryavrat. As a
matter of fact, the court can frame laws where the loopholes, inadequacy, inefficiency of
existing legislations are discovered in a process of judicial review.

As a guardian of rights, the judiciary can restrain the action of the legislature and
executive where there infringing upon these rights provided under the Constitution of
Aryavrat.

[MEMORIAL ON BEHALF OF THE PETITIONERS] X

 2nd Deo Mangal Memorial National Moot Court Competition, 2023

_________________________________________________________________________________________
ARGUMENTS ADVANCED
_________________________________________________________________________________________

1. WHETHER THE PIL IS MAINTAINABLE IN THE SUPREME COURT OF ARYAVRAT OR NOT

AND IS IT FEASIBLE TO IMPLEMENT UNIFORM CIVIL CODE IN A COUNTRY LIKE
ARYAVRAT?
The Ld. Counsel for the Petitioners most humbly submit before the Hon’ble Court that
the Petition filed as PIL seeking to implement the Uniform Civil Code is at par with Art. 44 of the
Aryavrat Constitution and hence maintainable on the ground that Art. 44 itself requires the State to
strive to secure for its citizens a common civil code throughout the country. In view of the right to life
and personal liberty enshrined under Art. 21, it is feasible that right to freedom of religion guaranteed
under Art. 25 should not be given such a vast expansive jurisdiction so as to cover the whole of life and
to prevent the legislature from encroaching upon that field.

It is most respectfully submitted that every person regardless of his/her religion, race, caste, sex, or
place of birth is entitled to having this liberty in order to reform our social system, which is full of
inequalities, discriminations, and other things which conflict with our Fundamental Rights.
Undoubtedly, Aryavrat has multiplicity of family laws. It is to be noted here that personal laws are
communal to some extent insofar as each community or religious group has its own distinct law to
govern domestic relations. It is also personal insofar as each person carries his own law wherever he
goes. So, it is technically right that the family law is partly statutory and partly non-statutory. With a
view to achieve uniformity of law, its secularization, and making it equitable and non-discriminatory,
the implementation of UCC across the territory of Aryavrat is aptly feasible as per the provisions of the
Constitution provided in Art. 44 of the Directive Principles of State Policy (DPSPs).

It is respectfully submitted that implementation of UCC is a constitutional aspect because it is true spirit
of secularism as religion is a personal matter so laws should be common for all religions. Moreover, the
establishment of a Uniform Civil Code would pave way for greater unity among citizens on the ground
that Aryavrat is a “...secular democratic republic” as declared in the Preamble of the Constitution which
means there is no State religion. Therefore, the secular activities, such as inheritance, marriage & family
matters covered by personal laws should be separated from religion.

It is respectfully submitted that it is high time that a Uniform Civil Code be enacted and made
applicable to all. There are contentions that a Common Civil Code would infringe the Fundamental

[MEMORIAL ON BEHALF OF THE PETITIONERS] 1

 2nd Deo Mangal Memorial National Moot Court Competition, 2023

Right to freedom of religion as mentioned in Art. 25 and, Secondly, it would amount to a tyranny to
minority. The Ld. Counsel for Petitioners vehemently submits before this Hon’ble Court that the first
objection is misconceived because secular activity associated with religious practice is exempted from
this guarantee and since personal laws pertains to secular activities they fall within the regulatory power
of the State. Regarding the second point, there is no specific personal law for each minority which has
been recognise as so sacrosanct as to prevent the enactment of a Civil Code. The dangerous and ruinous
effect of discrimination should be done away with, possibly by introducing a Uniform Civil Code.

The Judiciary always tried to narrow the gap between the general provisions of law and the personal
law. It is crystal clear in Bhagwan Dutt v. Smt. Kamala Devi and Anr 1, wherein the Apex Court
ignored the personal laws and stressed that provisions under Cr. P.C. must be made applicable to all
irrespective of their religious beliefs.

2. WHETHER UCC IS VIOLATIVE OF ONE’S’ FUNDAMENTAL RIGHTS AND OTHER PERSONAL

RIGHTS GUARANTEED UNDER THE CONSTITUTION OF ARYAVRAT AND IS IT THE
STATES’S INTERFERENCE IN THE REALM OF THE PERSONAL LAWS OF THE SUBJECTS?

The Ld. Counsel for the Petitioners most humbly submit before the Hon’ble Court that the UCC is not
violative of one’s’ Fundamental Rights and other personal rights guaranteed under the constitution of
Aryavrat as the uniform civil code is a vision to contribute to a uniformly structured legislature that will
reserve all the aspects resolving around the personal religious and civil laws of every religion in
Aryavrat. The UCC will grant uniform personal laws to every religion to attain secularism but it does not
violate ones Fundamental Rights. The country of Aryavrat needs to implement the UCC because it
promotes:

I. Equality and non-discrimination: Aryavrat is a diverse country with people from various religions
and cultural backgrounds. A Uniform Civil Code would ensure that all citizens, regardless of their
religion, are treated equally under the law. It aims to eliminate gender bias and discrimination by
providing equal rights and opportunities to women in matters of marriage, divorce, inheritance, and
adoption.

II. Secularism and national integration: Aryavrat is a secular country that aims to treat all religions
equally. The existence of different personal laws for different religious communities can be seen as
divisive and can create barriers to national integration. A Uniform Civil Code would promote a
sense of unity and common identity among citizens.

1
Bhagwan Dutt v. Smt. Kamala Devi And Anr 1975 AIR 83, 1975 SCR (2) 483

[MEMORIAL ON BEHALF OF THE PETITIONERS] 2

 2nd Deo Mangal Memorial National Moot Court Competition, 2023

III. Women's rights and empowerment: Personal laws in Aryavrat often contain provisions that
discriminate against women. For example, practices such as triple talaq (instant divorce) in Muslim
personal law have been criticized for being unfair to women. Implementing a Uniform Civil Code
would help address these inequalities and promote gender justice and women's empowerment.

IV. Simplification and clarity: Currently, different personal laws govern various aspects of a person's
life, such as marriage, divorce, inheritance, and adoption, based on their religious affiliation. This
leads to complexity and confusion in legal matters. A Uniform Civil Code would simplify the legal
system, making it easier for citizens to understand and navigate the laws.

V. Harmonizing with international standards: Aryavrat is a signatory to various international

conventions and treaties that promote human rights and gender equality. Implementing a Uniform
Civil Code would bring Aryavrat's personal laws in line with these international standards and
demonstrate the country's commitment to upholding human rights principles.

The Hon’ble Supreme Court in its various judgments has called for the Implementation of UCC, most
famously in the Shah Bano Case2 and other judgments include Sarala Mudgal, & Others v. Union of India3.
This also indicates that the UCC is not violative of one’s’ Fundamental Rights and other personal rights
guaranteed under the Constitution of Aryavrat.

Lastly, the personal laws are not the sole makers of cultural identity so, UCC could not destroy the
cultural diversity. Moreover, personal laws have been reformed in the past without affecting cultural diversity.
The UCC is also seen as a means to ensure justice and fairness in civil matters.

3. WHETHER THE NON-ISSUANCE OF THE BIRTH CERTIFICATE FOR THE CHILD BORN FROM
A LGBTQIA COUPLE IS VIOLATION OF THE CHILD’S RIGHT BY THE STATE?

The Ld. Counsel for the Petitioners most humbly submit before the Hon’ble Court that the non-
issuance of the birth certificate for the child born from a LGBTQIA couple is absolutely violation of
the child’s right by the State. The Constitution under the Art. 21 guarantees right to life and personal
liberty to every citizen as well as to non-citizen of the country. The child was born in the territory of
Aryavrat and the parents of him are also the citizen of Aryavrat, so as a matter of fact, the child is
genuinely entitled to be treated as the Citizen of Aryavrat by born. The Child being, Aryavratian

2 Shah Bano v. Union of India & Ors. AIR 2017 9 SCC 1 (SC)
3 Sarala Mudgal, & Others v. Union of India 1995 AIR 1531, 1995 SCC (3) 635

[MEMORIAL ON BEHALF OF THE PETITIONERS] 3

 2nd Deo Mangal Memorial National Moot Court Competition, 2023

Citizen, is entitled to have the birth certificate, and the non-issuance of the same will be the violation
of constitution.

Furthermore, the child is now “live-born” as per meaning of the provisions of Sec. 2 (d) of
the Registration of Births and Deaths Act, 1969. For this, he is also entitled to get the birth
certificate issued by the competent authority.

If the birth certificate is not issued to a child born from a LGBTQIA couple on the grounds
that his parents are not merely ‘male’ or ‘female’ rather than ‘trans-man’ or ‘trans-woman’ or ‘trans-
gender’ or ‘homosexual’ is obviously a discrimination that prohibited under Art. 15 and thus
violation of that child’s rights.

4. WHETHER THE CONSTITUTIONAL POWER OF COURT TO FRAME LAWS HAS LED TO THE
SCENARIO WHERE LEGISLATURE HAVE BECOME THE EXECUTIVE WING OF THE
JUDICIARY?
The Ld. Counsel for the Petitioners humbly submit before the Hon’ble Court that with the
changing needs, the legislature often fails to keep pace nor it is expected to realistic that it will
have provided for eventualities and contingencies. So, it is hence not only necessary but also
obligatory in nature upon the Judiciary to step in to feel the lacunae. To fill the vacuum, until
the substantive law is enacted by the legislature, the directions issued by the Higher Judiciary is
also a constitutional entitlement to meet the ends of Justice in such situations.

Judicial Legislation is nothing but law proclaimed, declared, and pronounced by the Judicial
body specifically by the Supreme Court also, known as ‘Judicial Law’ or ‘Judgment Law’.
Even, the legislations which are already enacted are the constitutional prerogatives of the
legislature, there may be certain circumstances in where the legislature have already made laws
are proved to be inadequate, ineffective in the process of Justice Administration. Though, the
parliament and the State Legislative body make legislations whole of the year, the quantum of
law cannot be sufficient to the changing needs for the present society in Aryavrat.

Montesquieu gave the idea of the Separation of powers, but in Aryavratian context that
principle is partially followed by giving the Judiciary a special position. That power of judicial
review is bestowed upon the Judiciary of Aryavrat.

[MEMORIAL ON BEHALF OF THE PETITIONERS] 4

 2nd Deo Mangal Memorial National Moot Court Competition, 2023

Judge made law or judicial law is also formally recognised under Art. 13 as
“13. Laws inconsistent with or in derogation of the fundamental rights. -
(1) All laws in force in the territory of India immediately before the commencement of this
Constitution, in so far as they are inconsistent with the provisions of this Part, shall, to the
extent of such inconsistency, be void
(2) The State shall not make any law which takes away or abridges the rights conferred by this
Part and any law made in contravention of this clause shall, to the extent of the contravention,
be void
(3) In this article, unless the context otherwise requires law includes any Ordinance, order, bye
law, rule, regulation, notification, custom or usages having in the territory of India the force of
law; laws in force includes laws passed or made by Legislature or other competent authority in
the territory of India before the commencement of this Constitution and not previously
repealed, notwithstanding that any such law or any part thereof may not be then in operation
either at all or in particular areas
(4) Nothing in this article shall apply to any amendment of this Constitution made under Article
368.”- ,
where legislature or “other competent authority” is inclusive of Judiciary and given considering
wide power of court under Articles 32, 226, 227, 141 and 144 of the Constitution of Aryavrat.

Thus, it is quite clear that the Constitution has bestowed the power on the courts to frame laws
wisely.

[MEMORIAL ON BEHALF OF THE PETITIONERS] 5

 2nd Deo Mangal Memorial National Moot Court Competition, 2023

_________________________________________________________________________________________
PRAYER
_________________________________________________________________________________________
Wherefore, in light of the issues raised, arguments advanced and authorities cited, may this Hon’ble Court
be pleased to:
A. declare that the Second, Third and Fourth Schedule to the Special Marriage Act, 1954, to the
extent that it restricts marriages only between a bridegroom and a bride, is unconstitutional and
void;

B. declare that any provision or words or phrases in Special Marriage Act, 1954, to the extent it
excludes or implies an intention to not recognize or solemnize or register marriage between
homosexual couples, is unconstitutional and void;

C. declare that the homosexual couples are entitled to solemnize and register their marriage under
the Special Marriage Act, 1954;

D. issue a writ of mandamus or any appropriate writ, order or direction, directing the Respondent
to pass appropriate orders and to issue a new birth certificate of the child of the petitioner
without showing specifically the name father and mother respectively, instead mentioning
"parents" of their child.

E. issue a writ of mandamus or any appropriate writ, order or direction, directing the Respondent
to pass appropriate orders to implementing the Uniform Civil Code.

AND/OR
Pass any order or relief which your Honour may deem fit, in the interest of Justice, Equity and Good
Conscience
All of which is most humbly and respectfully submitted

Sd/-
____________________________________
Ld. COUNSEL FOR THE PETITIONERS

[MEMORIAL ON BEHALF OF THE PETITIONERS] 6