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TEAM CODE: J

BEFORE THE HON’BLE SUPREME COURT OF LONG DISTANCES.

IN THE MATTER OF:

UNOHU ...
PETITIONER

V.

STATE OF SKYRABBIT AND ORS. ... RESPONDENT

PUBLIC INTEREST LITIGATION NO. ___ OF 2024

ON SUBMISSION TO THE HON’BLE SUPREME COURT OF LONG DISTANCES

UNDER ARTICLE 32 OF THE CONSTITUTION OF LONG DISTANCES

WRITTEN SUBMISSIONS ON BEHALF OF THE PETITIONER

COUNSEL APPEARING ON BEHALF OF THE PETITIONER

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TABLE OF CONTENTS

TABLE OF CONTENTS
INDEX OF AUTHORITIES……………………………………………………………….....V
STATEMENT OF JURISDICTION XI

STATEMENT OF FACTS XII

STATEMENT OF ISSUES XIV

SUMMARY OF ARGUMENTS XV

ARGUMENTS ADVANCED 1
A. That the writ petition filed with before the supreme court is maintainable 1
b. That the order dated december 1, 2024, ordering the hunting of six identified ren wolves,
ought to be quashed. 5
C: That the order dated December 2, 2024, ordering the shutdown of internet services in 4
districts in Skyrabbit, ought to be quashed?
D. Assuming that the order dated December 1, 2024, is quashed, what alternative measures
could the State Government employ to prevent animal attacks and capture the wild animals
responsible? . 16
PRAYER 22

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LIST OF ABBREVIATIONS

AIR All India Reporter

Anr. Another
App Appeal
Art. Article
Ibid Ibidium
Const. Constitutional
Cl. Clause
CRI LJ Criminal Law Journal
Ed. Edition
EIA Environment Impact Assessment
Hon'ble Honourable
SCC Supreme Court Cases
SC Supreme Court
HC High Court
PIl Public Interest Litigation
Ors. Others
Sec. Section
SCR Supreme Court Reporter
u/s Under Section
WPA Wildlife Protection Act,1972
EIA Environment Impact Assessment
EMP Environmental Management Plan
CWLW Chief Wild Life Warden
i.e. That is
X Tenth
No. Number

WSAN WolfSafe Alert Network

GPS Global Positioning System
IUCN Internation Union for Conservation of Nature
ICCPR International Covenant On Civil And Political
Rights
SDG Sustainable Development Goals
NGO Non- governmenta organisation
WCCB Wildlife Crime Control Bureau
Ors Others
Anr Another
V Versus

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Vol Volume
& And
¶ Paragraph
§ Section
FIR First Information Report
J. Justice

Legal Terminology and Legal Maxims

1. Actio Popularis - right to take legal action to protect the public interest or general
interest
2. Bona fide- in good faith
3. chilling effect-inhibition of legitimate exercise of legal rights by the threat of legal
sanction
4. conditio sine qua non- cause without which not
5. de facto - in fact or in reality
6. intelligible differentia-difference capable of being understood
7. legitimatio ad causam - capacity to be a party in the case
8. Locus Standi - Place of Standing
9. nemo judex in causa sua- no one should be judge in their own casue
10. parens patriae - parent of the nation
11. Sine qua non-without which not
12. ultra vires - beyond the powers

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INDEX OF AUTHORITIES

STATUTES

Constitution of Long Distances, 1950, Art. 19(1)(a) to 19(1)(g)

Constitution of Long Distances, Art. 14: Equality before law
Constitution of Long Distances, Art. 21: Right to Life and Personal Liberty

Constitution of Long Distances, Art. 32: Remedies for enforcement of rights conferred by
this Part
LEGISLATIONS AND RULES
Environment Impact Assessment Notification, 2006
Temporary Suspension of Telecommunication Services Rules, 2024
The Environment (Protection) Act, 1986
The Indian Forest Act, 1927
The Telecommunications Act, 1885
The Wildlife (Protection) Act,1972

INTERNATIONAL CONVENTIONS

Convention on Biological Diversity (CBD)

Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES)
Internation Union for Conservation of Nature (IUCN)

International Covenant On Civil And Political Rights (ICCPR)

United Nations Convention on Biological Diversity’s post-2020 global biodiversity
framework

BOOKS, ARTICLES, JOURNALS & WORKING PAPERS

A. ROSENCRANZ& S. RUSTOMJEE, CITIZENS’ RIGHT TO A HEALTHY ENVIRONMENT, 1995,

25 Envir. Pol. & Law 28
ARVIND P. DATAR, DATAR ON CONSTITUTION OF INDIA, Wadhwa & Company, ed.2001 25
Baxter, L. A., & Babbie, E. R. (2004). The basics of communication research.
Wadsworth/Thomson Learning.

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Benkler, Y. (2006). The wealth of networks: How social production transforms markets and
freedom. Yale University Press.

CAMERON, J., & ABOUCHAR, THE PRECAUTIONARY PRINCIPLE: A FUNDAMENTAL PRINCIPLE

OF LAW AND POLICY FOR THE PROTECTION OF THE GLOBAL ENVIRONMENT, Boston College
International And Comparative Law Review, 2001 30
CHARMIAN BARTON, PRECAUTIONARY PRINCIPLE IN AUSTRALIA, Vol. 22, 1988, Harv. Env.
L. Rev. 28
D.D. BASU, COMMENTARY ON THE CONSTITUTION OF INDIA, C.K. Thakker & S.S.
Subramani & T. S. Doabia & B. P. Banerjee eds., Vol. 6, 8th ed. 2012 11
D.D. BASU, COMMENTARY ON THE CONSTITUTION OF INDIA, C.K. Thakker & S.S.
Subramani& T. S. Doabia & B. P. Banerjee eds., Vol. 8, 8th ed. 2012 15
Dien, N. A. L. (2022). A Study of Vietnam’s Control over Online Anti-state Content.
ISEAS–Yusof Ishak Institute Singapore. (remove link)
Dijck, J. van, & Poell, T. (2013). Understanding Social Media Logic. Media and
Communication, 1(1), 2–14.
DURGA DAS BASU, COMMENTARY ON CONSTITUTION OF INDIA, Vol. 2, 2007 21
th
DURGA DAS BASU, COMMENTARY ON THE CONSTITUTION OF INDIA, Vol. 3, 8 ed., 2008 24
G.P. SINGH, PRINCIPLES OF STATUTORY INTERPRETATION, 13th ed. 2012 27
Herman, E. S., & Chomsky, N. (2010). Manufacturing Consent: The Political Economy of
the Mass Media. Pantheon Book.
Hintz, A., & Milan, S. (2018). Authoritarian Practices in the Digital Age| “Through a Glass,
Darkly”: Everyday Acts of Authoritarianism in the Liberal West. International Journal of
Communication, 12(0), Article 0.
H. M. SEERVAI, CONSTITUTIONAL LAW OF INDIA, 4th ed., vol. 2, 2007 11
IND. CONST. 14
JONATHAN NASH, STANDING AND THE PRECAUTIONARY PRINCIPLE, Columbia Law Review,
Vol. 108, 2008 30
JOSEPH LAX, PUBLIC TRUST DOCTRINE IN NATURAL RESOURCE LAW: EFFECTIVE JUDICIAL
INTERVENTION, Michigan Law Review, Vol. 68, Part I 31
JUSTICE FAZIL KARIM, JUDICIAL REVIEW OF PUBLIC ACTION, Vol.1 24
JUSTICE T. S. DOABIA, ENVIRONMENTAL & POLLUTION LAWS IN INDIA, Wadhwa Nagpur,
Volume 1, 1st ed. 2005 14
JUSTICE TS DOABIA, ENVIRONMENTAL & POLLUTION LAWS IN INDIA, Wadhwa Nagpur,
Vol.1, 1sted., 2005 31
Kathuria, R., Kedia, M., Varma, G., Bagchi, K., & Sekhani, R. (2018). The Anatomy of an
internet Blackout: Measuring the Economic Impact of internet Shutdowns in India. Indian
Council for Research on International Economic Relations.

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Krithivasan, R¹, Athreya V.R.², Odden M³. 2009. Human-Wolf conflict in human dominated
landscapes of Ahmednagar District, Maharashtra, India & Possible Mitigation Measures
K. JANAKIKUTTYAMMA, FUNDAMENTAL RIGHTS IN RELATION TO THE INDIAN
CONSTITUTION, The Indian Journal of Political Science, Vol. 9, No. 2/3 (April—
September, 1948) 19
M.P. JAIN INDIAN CONSTITUTIONAL LAW, Justice Ruma Pal, Samaraditya Pal, eds., 6th ed.
2010 17
M.P. JAIN, INDIAN CONSTITUTIONAL LAW, Vol. 1, 5th ed., 2003 24
MITTAL, RIGHT TO EQUALITY AND THE INDIAN SUPREME COURT, The American Journal of
Comparative Law, Vol. 14, 1965 21
N. JAYAPALAN, INDIAN SOCIETY AND SOCIAL INSTITUTIONS, Atlantic Publishers &
Distributors, 2001 20
NARAIN, VRINDA, WATER AS A FUNADAMENTAL RIGHT: PERSPECTIVE FROM INDIA, 2009,
Vermont Law Review 23
O. McIntyre, & T Mosedale,.THE PRECAUTIONARY PRINCIPLE AS A NORM OF CUSTOMARY
INTERNATIONAL LAW, Journal of Environmental Law, 9(2) (1997) 30
R. STECH,A CARROT AND STICK APPROACH? AN ANALYSIS OF THE UK GOVERNMENT'S
PROPOSALS ON ENVIRONMENTAL JUDICIAL REVIEW, Journal of Environmental Review,
Vol. 15 (2), 2013 11
ROSE MARY, RIGHT TO WATER: THEORETICAL CONCERNS AND PRACTICAL ISSUES, The
Indian Journal of Political Science, Vol. 67, No. 4 (OCT. - DEC., 2006) 24
15
SHYAM DIVAN & ARMIN ROSENCRANZ, ENVIRONMENTAL LAW AND POLICY IN INDIA, 2nd
ed., Oxford India Paperback 27
CASES, DECISIONS AND ADVISORY OPINIONS

1. Animal Welfare Board of India v. A. Nagaraja (2014) 7 SCC 547

2. Anuradha Bhasin v Union of India, (2020) 3 SCC 637
3. Anuradha Bhasin v. UOI (2020) 3 SCC 637
4. Arup Bhuyan v State of Assam, (2011) 3 SCC 377
5. Bennett Coleman & Co. v. Union of India (1972 2 SCC 788)
6. Bombay Dyeing & Mfg. Co. Ltd. v. Bombay Environmental Action Group, (2006) 3
SCC 434
7. Centre for Environmental Law v. Union of India (2013) 8 SCC 234
8. Centre for Environmental Law, World Wide Fund Vs. Union of India (2013) 8 SCC
234
9. Centre for Environmental Law, WWF-India v. Union of India (2013) 8 SCC 234
10. Centre for Environmental Law, WWF-India v. UOI (2013) 8 SCC 234
11. CPIO v. Subhash Chandra Aggarwal, (2019) SCC OnLine SC 1459
12. Gujarat Mazdoor Sabha v. State of Gujarat, (2020) 10 SCC 459
13. Hunting Down the Man Eater Leopard in the Village Bhimtal Area v. State, 2023
SCC OnLine Utt 2218
14. Indian Council for Enviro-Legal Action v. Union of India 1996 AIR 1446

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15. K.K. Kochunni v. State of Madras AIR 1959 SC 725
16. K.S. Puttaswamy vs. Union of India (2017) 10 SCC 9
17. Kinkeri Devi v. State AIR1988HP4
18. L.K Koolwal v. State of Rajasthan and Ors AIR 1988 Raj 2
19. M.C. Mehta v. Kamal Nath [(1997) 1 SCC 388
20. M.C. Mehta v. Union of India
21. M.K. Ranjit Singh v. UOI (2021) 15 SCC 1
22. Maneka Gandhi v. Union of India (1978) 1 SCC 248
23. Maneka Gandhi v. UOI (1978) 1 SCC 248
24. Modern Dental College and Research Centre v. State of Madhya Pradesh, (2016) 7
SCC 353
25. Olga Tellis v. Bombay Municipal Corporation (1985) 3 SCC 545
26. PUCL v Union of India (AIR 1997 SC 568)
27. Rashid Ahmad v. Municipal Board, Kairana AIR 1950 SC 163
28. Research Foundation for Science, Technology and Natural Resource Policy v. Union
of India, (2007) 15 SCC 193
29. Romesh Thappar v. State of Madras AIR 1950 SC 124
30. S. Rangarajan v P. Jagjeevan Ram and Ors 1989 (2) SCC 574
31. S.P. Gupta v. Union of India (1977) 2 SCC 148
32. Shreya Singhal v Union of India (AIR 2015 SC 1523)
33. Shreya Singhal v. Union of India (2015) 5 SCC 1
34. Sohan Lal v. Union of India 1957 AIR 529
35. State of West Bengal v. Anwar Ali Sarkar, AIR 1952 SC 75
36. Orissa Mining Corpn. Ltd. v. Ministry of Environment & Forests, (2013) 6 SCC 476
37. Subhash Kumar v. State of Bihar (1991) 1 SCC 598
38. T.N. Godavarman Thirumulpad Vs. Union of India & Ors. (2012) 3 SCC 277
39. Vellore Citizens Welfare Forum v. Union of India 1996 (5) SCC 647

DATABASE REFFERED:
WEBSITES:
1. http://www.lexisnexisacademic.com
2. http://www.indiankanoon.com
3. http://www.manupatra.com
4. http://www.livelaw.com
5. http://www.thebluebook.com
6. http://www.thehindu.com
7. http://www.indconlawphil.wordpress.com
8. http://www.barandbench.com
9. http://www.judis.nic.in
10. http://www.uidai.gov.in

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11. http://www.westlaw.com
12. http://www.scconline.co

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STATEMENT OF JURISDICTION

UNOHU, the Petitioner herein, has approached this Hon'ble Court by filing a Public Interest
Litigation under Article 32 of the Constitution of Long Distances. Article 32 reads as follows;

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 clause (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.
The Counsels for the Petitioner most respectfully submit to this jurisdiction of the Hon'ble
Supreme Court of Indiana.

This memorandum sets forth the facts, contentions and arguments

for the petitioner in the given case.

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STATEMENT OF FACTS

1. Introduction:
The Union of Long Distances (“Long Distances”) is an ecologically diverse country
with a primarily agrarian economy, where the expansion of agriculture has led to the
gradual depletion of its rich forest lands. Agriculture, being a focal policy point for
the Government, often takes precedence over environmental concerns. The State of
Skyrabbit is one of the most affected regions, where agriculture has led to the
formation of small villages, replacing once-dense forests.
2. Incident of Animal Attacks:
In July 2024, a report emerged from Lightyears, a village in Skyrabbit, where a child
was allegedly fatally attacked by a wolf, identified as a ‘Ren Wolf,’ a species listed
under Schedule I of the Wildlife Protection Act, with only around 3000 wolves left in
the wild. Villagers reported that a wolf was responsible for the attack. This sparked
widespread concern, although no concrete evidence, such as camera footage or DNA
evidence, could be gathered to substantiate the claim.
3. Viral Post and Escalation:
A viral post emerged on social media, warning about “man-eating wolves” attacking
children in Skyrabbit. The post called for action against Ren Wolves, alleging
multiple incidents of fatal attacks. This message, combined with several similar
reports from surrounding villages, led to mass panic.
4. Wildlife Vigilantism and Animal Killings:
As a result of the growing fear, villagers began taking matters into their own hands,
forming makeshift hunting groups. These groups targeted any wild canines spotted
near their villages, killing dozens of wild dogs and coyotes in September and October
2024.
5. Intervention by Unohu:
In response to the escalating violence against animals, Unohu, a non-profit
organization dedicated to wildlife protection, intervened. Unohu educated villagers
about the differences between wild dogs, coyotes, and wolves, and emphasized the
endangered status of Ren Wolves. Despite Unohu's efforts, the killing of wild animals
continued, and three more deaths were reported in November 2024.
6. State Government's Actions:

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Facing mounting pressure due to upcoming elections, the State Government of
Skyrabbit issued two key orders in December 2024:

a. Order dated December 1, 2024: Authorized the hunting of six Ren Wolves,
allegedly responsible for the attacks, based on eyewitness reports and drone
footage.

b. Order dated December 2, 2024: Imposed an internet shutdown across four

districts in Skyrabbit where previous attacks had occurred to prevent further
killing of wild animals.

7. Impact on Unohu's Operations:

The internet shutdown severely impacted Unohu’s efforts to educate the public and
counter misinformation about the wolf killings. Without access to the internet, Unohu
could no longer run its educational programs or effectively combat the viral
campaigns calling for the killing of wolves.
8. Unohu's Concerns:
Unohu expressed serious concerns about the State Government’s actions, particularly
the hunting order, which it believed was based on insufficient evidence. Additionally,
Unohu feared that the internet shutdown would exacerbate the situation, as it would
prevent the dissemination of factual information and increase the likelihood of
continued vigilante killings.
9. Petitioner's Actions:
As a result of these developments, Unohu filed a Public Interest Litigation (PIL)
before the Supreme Court of Long Distances, challenging both the hunting order and
the internet shutdown order. Unohu seeks the quashing of these orders on the grounds
that they were issued arbitrarily, lacked sufficient evidence, and violated fundamental
rights under the Constitution.
10. State Government's Response:
In response, the State Government filed a counter-affidavit, asserting that the PIL was
not maintainable and justifying its actions as necessary to protect public safety.

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STATEMENT OF ISSUES

1. Whether the PIL filed before the Supreme Court is maintainable.

2. Whether the order dated December 1, 2024, permitting the hunting of six Ren
Wolves, should be quashed, and if so, on what grounds.

3. Whether the order dated December 2, 2024, directing the internet shutdown in four
districts of Skyrabbit, should be quashed, and if so, on what grounds.

4. Assuming the order dated December 1, 2024, is quashed, what alternative measures
can the State Government implement to prevent animal attacks and capture the wild
animals responsible?

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SUMMARY OF ARGUMENTS

I. THAT THE PIL FILED BEFORE THE SUPREME COURT OF IS MAINTAINABLE

It is most respectfully submitted that the present PIL filed before this hon’ble
Supreme Court is maintainable under Article 32 primarily on three grounds:
[1.1] the petitioner has locus standi as the grievance involves a violation of
constitutional rights affecting the larger public interest, justifying judicial
intervention.
[1.2] The orders dated December 1 and December 2, 2024, violate Articles 21,
19(1)(a), and 14 by curtailing the right to free speech, ensuring equality, and
protecting life and liberty arbitrarily. Furthermore,
[1.3] A Public Interest Litigation is the most appropriate remedy as it
addresses systemic issues affecting fundamental rights beyond individual
grievances.
[1.4] That the actions taken by the government are politically motivated as
they were issued ahead of the 2025 elections to appease the electorate without
scientific backing.

II. THAT THE ORDER DATED DECEMBER 1, 2024 ORDERING THE HUNTING OF SIX

IDENTIFIED REN WOLVES OUGHT TO BE QUASHED

It is most respectfully submitted that the order dated December 1, 2024, allowing the
hunting of six Ren Wolves should be quashed for several reasons. It violates the
Wildlife (Protection) Act, 1972, as it fails to meet conditions under Section 11(1)(a)
for hunting endangered species. The decision was based on unreliable eyewitness
accounts, lacking forensic evidence linking the wolves to alleged attacks. No
authorized personnel were specified for the hunting, and alternative non-lethal
measures were not considered. The order undermines the Act’s objective to protect
endangered species and violates constitutional rights under Article 21. Additionally,
the ecological role of the Ren Wolf and principles of procedural fairness were
disregarded, making the order illegal and arbitrary.

III. THAT THE ORDER DATED DECEMBER 2, 2024, ORDERING THE SHUTDOWN OF

INTERNET SERVICES, OUGHT TO BE QUASHED.

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It is most respectfully submitted that the order to shut down internet services in
Skyrabbit’s four districts is challenged on multiple grounds. Firstly, there is no
"public emergency" as defined by law, since disturbances in the area had already de-
escalated. Secondly, the order violates the Telecommunications Act by not meeting
the necessity and proportionality requirements. Thirdly, it infringes upon the
fundamental right to freedom of speech under Article 19(1)(a), as it disrupts
communication essential for public safety and wildlife conservation efforts. The order
is also ultra vires, unconstitutional, and fails to provide adequate safeguards against
executive overreach. Therefore, the order should be quashed.

IV. THAT ALTERNATIVE REMEDIES THE STATE COULD EMPLOY TO PREVENT ANIMAL

ATTACKS.

The petitioner proposes several measures to address human-wildlife conflict in

Skyrabbit, focusing on both immediate actions and long-term strategies. Immediate
measures include compensating victims, strengthening awareness programs,
implementing curfews, and using modern surveillance technologies like drones and
GPS tracking to monitor Ren Wolves. Long-term goals involve balancing agricultural
growth with ecological preservation and aligning policies with sustainable
development goals. The petitioner also suggests forming a high-level committee,
utilizing the Wildlife Crime Control Bureau, and deploying unconventional capture
techniques, including tranquilization and relocation of wolves, to prevent further
attacks.

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ARGUMENTS ADVANCED

ISSUE A: WHETHER THE PIL FILED BEFORE THE SUPREME COURT IS

MAINTAINABLE?
It is most respectfully submitted before this Hon'ble Supreme Court that the Public Interest
Litigation filed by the petitioner is maintainable under Article 32 of the Constitution as [1.1]
the petitioner has locus standi to bring this petition addressing issues of public interest and
the infringement of fundamental rights 1, and [1.2] the State’s orders have violated the
constitutional guarantee of the right to life under Article 21, along with the duty to protect
and preserve the environment.2 Furthermore, [1.3] this Public Interest Litigation serves as the
most appropriate adequate remedy to address the breach of public rights and ensure the
effective enforcement of constitutional safeguards.
[1.1] THAT THE PETITIONER HAS LOCUS STANDI TO BRING THIS
PETITION BEFORE THE COURT
[1.1.1] Locus Standi of the Petitioner in the present Public Interest
Litigation
It is humbly contended that the petitioner has locus standi under the
liberalized concept of standing as laid down in S.P. Gupta v. Union of India,
wherein this Hon’ble Court departed from the traditional doctrine of standing
(legitimatio ad causam) and held that:
“in public interest litigation, any litigation undertaken for the purpose of
redressing public injury, enforcing public duty, protecting social,
collective, 'diffused' rights and interests or vindicating public interest, any
citizen who is acting bona fide and who has sufficient interest has to be
accorded standing…”3
It is submitted that in the case at hand, the petitioner, a non- profit organisation
dedicated to conservation of wildlife, stepped in to address the failure of the
State Government in preventing the indiscriminate killing of endangered
species. The petitioner conducted village educational programs distinguishing
wolves from wild dogs and coyotes, emphasized the ecological significance of

1 Article 32 of the Constitution

2 Article 21 of the Constitution
3 S.P. Gupta v. Union of India (1977) 2 SCC 148
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endangered species, and launched a counter-campaign on social media to
dispel misinformation. This concerted effort led to a measurable reduction in
animal deaths in November 2024, reflecting the petitioner’s bona fide
intention to protect public interest and uphold the ecological balance. Thus,
the petitioner’s bona fide efforts and sufficient interest establish their standing
to uphold public interest before this Hon’ble Court.
In Centre for Environmental Law, WWF-India v. Union of India, the Supreme
Court reaffirmed the principle that non-governmental organizations (NGOs)
engaged in environmental protection have locus standi to approach the Court. 4
The decision emphasized that the concept of Actio popularis, allowing any
member of the public with a legitimate interest to bring a matter before the
Court, is vital to ensuring effective access to justice in environmental matters.
In the present case, the petitioner, Unohu, a non-profit organization committed
to wildlife conservation, fits squarely within this framework. It has
consistently worked to protect endangered species and raise awareness
regarding wildlife preservation.
[1.1.2] Public Interest in protecting Endangered Species
The Ren Wolf, with only approximately 3000 left in the wild, is a Schedule I species
under wildlife protection Act. Its conservation is not only a national but a global
concern. Unohu’s actions aim to protect this species from extinction, which aligns
with the larger public interest. The threat posed to the ecosystem by the indiscriminate
killing of these wolves necessitates urgent judicial intervention. In L.K Koolwal v.
State of Rajasthan and Ors, the Rajasthan High Court explained that Article 51-A is
not only a duty, but also a right created in favour of citizens to have the locus standi to
petition the court to have a check on the conduct of state activities, whether the
authorities are performing their duties in accordance with the fundamental law of the
land.5 The PIL is therefore maintainable as it seeks to protect the environment and
prevent ecological degradation, which is of public concern.
[1.1.3] Maintainabilty of the PIL under Article 32
It is respectfully submitted that the Public Interest Litigation (PIL) filed by the petitioner is
maintainable under Article 32 of the Constitution, as it addresses matters of significant public
importance concerning environmental protection and wildlife conservation. As laid down by

4 Centre for Environmental Law, WWF-India v. Union of India (2013) 8 SCC 234
5 L.K Koolwal v. State of Rajasthan and Ors(cite- AIR 1988 Raj 2)
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this Hon’ble Court in the Compilation of Guidelines to be Followed for Entertaining
Letters/Petitions Received (Public Interest Litigations):
"Petitions pertaining to environmental pollution, disturbance of ecological balance, drugs,
food adulteration, maintenance of heritage and culture, antiques, forests, and wildlife and
other matters of public importance will ordinarily be entertained as Public Interest
Litigation."
It is also pertinent to note that in this case, In M.C. Mehta v. UOI, the Supreme Court
emphasized that PILs addressing environmental degradation must be entertained to safeguard
public interest. Similarly, the present petition concerning the protection of the Ren Wolf, an
endangered species, aligns with these precedents, making it appropriate for adjudication
under Article 32.
[1.2] THAT THE ORDERS DATED DECEMBER 1, 2024 AND DECEMBER 2, 2024
VIOLATES FUNDAMENTAL RIGHTS ENSHRINED IN THE CONSTITUTION OF
LONG DISTANCES
[1.2.1] Violation of Article 21: Right to Life and a Clean Environment
It is respectfully contended that the orders dated December 1, 2024, and December 2, 2024,
violate the fundamental rights guaranteed under Article 21 of the Constitution of Long
Distances, particularly the right to life and the right to a clean environment. In Subhash
Kumar v. State of Bihar (1991) 1 SCC 598, the Supreme Court recognized that the right to
life under Article 21 includes the right to a clean and healthy environment. Wildlife
conservation is intrinsically connected to the right to a clean and healthy environment as it
helps maintain the ecological balance.

In the instant case, The Ren Wolf, a Schedule I species under the Wildlife Protection Act, is
critically endangered, with only approximately 3000 individuals left in the wild. The
indiscriminate hunting of these wolves, as permitted by the order of the State government, not
only threatens the survival of the species but also disrupts the ecological balance, which in
turn endangers the right to a clean and healthy environment.

In Centre for Environmental Law, WWF v. UOI (2013) 8 SCC 234, the Court emphasized that
Article 21 not only protects human rights but also places an obligation on citizens to protect
wildlife. By allowing the hunting of Ren Wolves, the State has violated this constitutional
mandate. The Supreme Court also reiterated in M.K. Ranjit Singh v. UOI (2021) 15 SCC 1
that the protection of endangered species is an essential part of the right to life under Art. 21.
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Therefore, the order violates the fundamental rights of the public by threatening ecological
balance and contributing to the potential extinction of a protected species.
[1.2.2] VIOLATION OF DUTY OF STATE TO PROTECT WILDLIFE AND
ENVIRONMENT
It is humbly contended that the orders allowing the hunting of Ren Wolves directly
contravene the constitutional directives set forth in Articles 48A and 51A(g) of the
Constitution, which are part of the Directive Principles and Fundamental Duties respectively.
Article 48A directs that the State shall endeavour to protect and improve the environment and
to safeguard the forests and wildlife of the country, while Article 51A(g) emphasizes the duty
of citizens to show compassion for living creatures and improve the natural environment. The
failure of the State to prevent the hunting of the Ren Wolves, an endangered species,
represents a clear violation of these constitutional provisions.
In Kinkeri Devi v. State, the Himachal High Court held that it is both a constitutional pointer
to the state and a constitutional duty of citizens to not only protect but also improve the
environment, and to preserve and safeguard the forests, flora and fauna, rivers and lakes, and
all other water resources of the country in Article 48-A and Article 51-A(g). The State’s
failure to follow the direction or complete the duty is essentially a direct violation of the
fundamental law of the state.

[1.2.3] THAT THE ORDER DATED DECEMBER 2, 2024 VIOLATES ARTICLE

19(1)(A): RIGHT TO FREEDOM OF SPEECH AND EXPRESSION
It is humbly submitted that the petitioner has approached this Hon'ble Court by way of Public
Interest Litigation (PIL) seeking the quashing of the order suspending internet services, as
issued by the State. The suspension of internet services in the present case represents a grave
violation of the fundamental rights guaranteed under the Constitution, particularly the right to
freedom of speech and expression under Article 19(1)(a) and the right to access and
disseminate information
It is humbly submitted that the order dated December 2, 2024 imposing a blanket internet
shutdown violates Article 19(1)(a), which guarantees the right to freedom of speech and
expression. This Court, in Shreya Singhal v. UOI (2015) 5 SCC 1, emphasized that the
Internet is a key medium for the exercise of this right. The internet shutdown in Skyrabbit
directly affects the ability of citizens, including the petitioner, to communicate, disseminate
information, and conduct their programs. The blanket suspension of internet services fails the

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test of proportionality and reasonableness and fails to meet the standards of necessity and
proportionality as laid down in Anuradha Bhasin v. UOI (2020) 3 SCC 637.
[1.2.4] Violation of Article 14: Right to Equality
It is humbly submitted that the state of Skyrabbit passed the orders without giving Petitioner
an opportunity to make representations, violating Article 14 of the Constitution. Rules of
natural justice apply as much to administrative action which entails civil consequences as to
quasi-judicial or judicial functions. The principles of fairness and natural justice require that
affected parties be heard before such drastic measures are taken. The denial of this
opportunity constitutes a violation of the right to equality and non-arbitrariness, as held in
Maneka Gandhi v. UOI (1978) 1 SCC 248.
[1.3] THAT THE PUBLIC INTEREST LITIGATION BEFORE THE HON’BLE
COURT IS THE MOST APPROPRIATE REMEDY
It is humbly submitted that there are strong legal and practical grounds for filing this petition
under Article 32 in this Hon’ble court.
In Romesh Thappar v. State of Madras AIR 1950 SC 124, this Hon'ble Court held that Article
32 is a fundamental right in itself, offering a "guaranteed" remedy for the enforcement of
fundamental rights. The Court clarified that Article 32 serves as the ultimate protector and
guarantor of fundamental rights. Unlike Article 226, which grants discretionary powers to the
High Courts, Article 32 provides a remedial right that cannot be refused when fundamental
rights are threatened. The Court observed:
"It is not possible to accept the preliminary objection raised on behalf of
the respondents that as a matter of orderly procedure, the petitioner
should have first resorted to the High Court while under Article 226 of
the Constitution has concurrent jurisdiction to deal with the matter."
While alternative remedies, such as approaching the High Court under Article 226, may be
available, it does not bar the jurisdiction of the Supreme Court under Article 32.
Therefore, the filing of the petition directly in the Supreme Court under Article 32 is
constitutionally valid and maintainable.
Also, In Rashid Ahmad v. Municipal Board, Kairana AIR 1950 SC 163, the Supreme Court
observed "There can be no question that the existence of an adequate legal remedy is a thing
to be taken into consideration in the matter of granting writs, but the powers given to this
Court under Article 32 are much wider and are not confined to issuing prerogative writs
only."

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This principle was reiterated in K.K. Kochunni v. State of Madras AIR 1959 SC 725, where
the Supreme Court held:
"The mere existence of an adequate alternative legal remedy cannot per se be a good and
sufficient ground for throwing out a petition under Article 32 if the existence of a
fundamental right and a breach, actual or threatened, of such right is alleged and is prima
facie established on the petition."
Therefore, in matters involving fundamental rights, the Supreme Court has the authority to
entertain petitions directly, without requiring the petitioner to first approach the High Court
under Article 226.
As held in Sohan Lal v. Union of India, "Whether the alternate remedy is equally efficient
and adequate is a question of fact to be decided in each case, the onus being on the applicant
to show that it is not adequate."
In this case, approaching the High Court may lead to further delays due to the possibility of
appeals, which would be detrimental given the urgency of the matter. Protecting the Ren
Wolf, a Schedule I species under the Wildlife Protection Act, 1972, is a national concern, not
confined to any single state. Therefore, the Supreme Court is the most appropriate forum for
expeditious relief.
It is thus submitted with respect that the Public Interest Litigation filed by the petitioner is
maintainable under Article 32, addressing significant violations of fundamental rights,
wildlife protection, and arbitrary state actions. With no adequate alternative remedy, the
Supreme Court's intervention is essential to protect constitutional rights and prevent further
environmental harm.
[1.4] THAT THE ACTIONS TAKEN BY THE GOVERNMENT ARE POLITICALLY
MOTIVATED
It is most respectfully contended that that the impugned orders passed by the State
Government of Skyrabbit, dated December 1, 2024, allowing the hunting of six Ren Wolves
and the order dated December 2, 2024, shutting down internet services in four districts, are
not only arbitrary but politically influenced, driven by an urgency to appease the electorate
ahead of the 2025 elections.
[1.4.1] ISSUE OF TIMING OF THE ORDERS

It is humbly contended that the concerns raised relate to the orders issued by the State
Government of Skyrabbit on December 1, 2024, and December 2, 2024. In the instant case,
the timing of issuance of orders seems more than coincidental that these directives have been
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issued ahead of the 2025 elections when the administration is facing increased scrutiny from
constituents regarding the reported animal attacks. It is alleged that the government's
decisions appear reactive, aimed at appeasing the public rather than originating from accurate
environmental or scientific analysis.

[1.4.2] QUESTIONING THE EVIDENCE FOR PERMITTING REN WOLVES

HUNTING
It is humbly contended that, order dated December 1, 2024, permitting the hunting of Ren
Wolves raises issues about the validity of the evidence. There are no definitive DNA samples
or paw impressions connecting the wolves to the fatal attacks. These assertions, made solely
based on eye witness reports, lack a thorough scientific investigation and suggest a hasty
approach by the government. Such actions imply a potential prioritization of political agenda
over the protection of fauna and protocol adherence.

[1.4.3] IMPACT ANALYSIS OF INTERNET SHUTDOWN

It is pertinent to note that the order, dated December 2, 2024, of internet suspension in four
districts, its implications are also questionable. Before the shutdown, there were ongoing
efforts aimed at counteracting misinformation raising awareness about the role of Ren
Wolves in the ecosystem. This shutdown order stalled such initiatives, curbing peaceful
attempts to resolve the issue through knowledge and dialogue. In Arguendo, the suspension
appears to be more about suppressing alternative voices than averting lawlessness, generating
concerns of narrative control during a politically sensitive period.
It is thus submitted with respect that the immediate and comprehensive nature of these
issuance of orders implies that they have been instituted under substantial political influences,
aimed at securing electoral leverage. Such tendencies indicate that these measures might have
been less about thoughtful actions for the long-term ecological stability of the state and more
about political expediencies. Therefore, it becomes necessary for judicial intervention to
render these orders ineffective and liable to be quashed.

ISSUE (B): WHETHER THE ORDER DATED DECEMBER 1, 2024, ORDERING

THE HUNTING OF SIX IDENTIFIED REN WOLVES, OUGHT TO BE QUASHED.
It is most respectfully contended before this Hon’ble Supreme Court that the order dated
December 1, 2024, issued by the Office of Chief Minister, allowing the hunting of six wolves
which were apparently spotted on drone footage near the site of one of the villages where an
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attack had taken place, [2.1] is Illegal, [2.2] Unconstitutional and [2.3] not in conformity with
the International obligations.
[2.1] THAT THE ORDER VIOLATES THE WILDLIFE (PROTECTION) ACT, 1972
It is humbly contended that the order issued by the Office of Chief Minister is ultra vires The
Wildlife (Protection) Act,1972 (hereinafter referred to Wildlife (Protection) Act). For
foundational reference, clause (a) of sub-section (1) of section 11 of the Wildlife Protection
Act is relied upon.
11. Hunting of wild animals to be permitted in certain cases.—(1) Notwithstanding anything
contained in any other law for the time being in force and subject to the provisions of
Chapter IV,—
(a) the Chief Wild Life Warden may, if he is satisfied that any wild animal specified in
Schedule I has become dangerous to human life or is so disabled or diseased as to be beyond
recovery, by Order in writing and stating the reasons therefor, permit any person to hunt
such animal or cause such animal to be hunted;
[Provided that no wild animal shall be ordered to be killed unless the Chief Wild Life
Warden is satisfied that such animal cannot be captured, tranquilised or translocated:
Provided further that no such captured animal shall be kept in captivity unless the Chief Wild
Life Warden is satisfied that such animal cannot be rehabilitated in the wild and the reasons
for the same are recorded in writing.
It is submitted, that from a perusal of the said provision it is observed that the essential
ingredients of the offense include
i. The Chief Wildlife Warden must be satisfied that the Schedule I wild animal has
become dangerous to human life, or is so disabled or diseased as to be beyond
recovery.
ii. The Chief Wildlife Warden must issue a written order, stating reasons, permitting a
specific person to hunt or cause the animal to be hunted.
iii. The Chief Wildlife Warden must explicitly permit hunting of the animal, provided all
conditions under Section 11(1)(a) are met.

[2.1.1] THAT THE ORDER RELIED SOLELY ON EYE WITNESS REPORTS FOR
THREAT ASSESMENT
It is contended that in the case at hand, the State Government relied on eyewitness accounts
from villagers who could not reliably distinguish between Ren Wolves, wild dogs, and
coyotes. This lack of accurate identification is evident from the villagers' actions, as they

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indiscriminately hunted and killed dozens of wild dogs and coyotes in September and
October 2024 under the belief that these animals were the typically-referred ‘Killer Wolves.’
Such reliance on unverified and indiscriminate accounts to justify hunting a Schedule I
species, which is afforded the highest degree of protection under Indian wildlife law, is
deeply flawed.
In Hunting Down the Man Eater Leopard in Bhimtal Area v. State, 2023 SCC OnLine Utt
2218, the court stressed that a Chief Wildlife Warden's decision under Section 11(1)(a) must
rely on credible evidence, rationality, and exhaustive attempts to use non-lethal methods. The
decision to hunt the Ren Wolves lacks evidence, ignores non-lethal measures, is ecologically
unsound, and appears politically motivated due to due to election proximity.

It is humbly submitted that the Schedule I species enjoy the highest degree of protection
under Long Distances wildlife law. In the case at hand, no forensic evidence, such as DNA
analysis, scat examination, or corroborated photographic proof, was presented to link the six
identified Ren Wolves to the attacks. The inception of the order based on such unconfirmed
and imprecise accounts prompting the hunting of an endangered species is profoundly
defective, and thus, liable to be quashed.
It is also pertinent to note that in the case, Centre for Environmental Law v. Union of India
(2013) 8 SCC 234, this Hon’ble Court emphasized on standard to be applied is the 'Species
Best Interest,' the need for eco-centric approach and protection of endangered species for
long-term conservation. Similarly, in Animal Welfare Board of India v. A. Nagaraja (2014) 7
SCC 547, recognizes that animals have statutory rights under the Prevention of Cruelty to
Animals Act, 1960 and constitutional protection through Article 21 and Article 51A(g),
protecting animals from unnecessary pain and suffering, asserting that any law conflicting
with animal welfare is invalid. The judgment highlights the State’s responsibility as a
guardian (Parens Patriae) to safeguard animals and emphasizes the international standards
like the Five Freedoms of Animal Welfare.
[2.1.2] THAT THE ORDER FAILED TO SPECIFY THE AUTHORIZED PERSON
FOR HUNTING
It is humbly contended that Section 11 of the Act stipulates that the Chief Wildlife Warden
must specify who is authorized to hunt the dangerous animal. The order issued on December
1, 2024, fails to specify any individual or agency responsible for the hunting of the wolves.
By permitting “any person” to hunt, the order creates a dangerous precedent where
unqualified individuals could take matters into their own hands, leading to further risks to
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other wild canines, including endangered species or harmless animals that could be mistaken
for wolves.
[2.1.3] THAT THE ORDER FAILED TO SPECIFY PERMITTED HUNTING
ACTIVITIES
It is humbly contended that the order issued by the Chief Wildlife Warden fails to specify the
type of hunting that is permitted, which is a critical oversight.
As per Section 2(16) of the Wildlife (Protection) Act, 1972,
2(16) “hunting”, with its grammatical variations and cognate expressions, includes,—
[(a) killing or poisoning of any wild animal or captive animal and every attempt to do so;
(b) capturing, coursing, snaring, trapping, driving or baiting any wild or captive animal and
every attempt to do so;]
(c) injuring or destroying or taking any part of the body of any such animal or, in the case of
wild birds or reptiles, damaging the eggs of such birds or reptiles, or disturbing the eggs or
nests of such birds or reptiles;
This negligence in failing to specify the nature of the hunting allowed is egregious, especially
given the endangered status of the Ren Wolf species. Such an imprecise and hasty decision
undermines the principles of conservation and ecological balance, posing a severe threat to
the species' survival.
It is thus submitted with respect, the failure to substantiate the threat posed by the six wolves
violates Section 11, rendering the order illegal. Moreover, the endangered status of the Ren
Wolf means that even a single killing could have long-term ecological repercussions. Hence,
the order is liable to be quashed.
[2.1.4] THAT THE ORDER VIOLATED THE OBJECTIVES OF THE WILDLIFE
(PROTECTION) ACT, 1972
It is pertinent to note that the Statement Of Object And Reasons of the Wildlife (Protection)
Act, 1972 states that “Some wild animals and birds have already become extinct in this
country and others are in the danger of being so and the object of this act is to provide for the
protection of the country's endangered wild animals and other species and prevent them from
hunting, killing and illegal trading” The order issued herein fundamentally contravenes the
objectives for which this Act was enacted, as it employs the same provisions to facilitate
actions that are directly opposed to the intended protective measures.

[2.2] THAT THE ORDER IS UNCONSTITUTIONAL

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It is humbly submitted that the order passed by the Chief Wildlife Warden is unconstitutional
as it violates fundamental rights enshrined in the Constitution of Long Distances, particularly
under Article 21. The protection and conservation of endangered species are essential to
ensuring environmental justice, and the failure to consider the long-term ecological impact of
the order undermines these constitutional protections.
[2.2.1] THAT THE ORDER VIOLATES ARTICLE 21 OF THE CONSTITUTION OF
LONG DISTANCES
It is pertinent to note that this Court in the case of Centre for Environmental Law, World
Wide Fund Vs. UOI (2013) 8 SCC 234 while considering the protection and conservation of
endangered species has observed that Article 21 of the Constitution protects not only the
human rights but also casts an obligation on human beings to protect and preserve a species
becoming extinct, conservation and protection of environment is an inseparable part of right
to life.
T.N. Godavarman Thirumulpad Vs. UOI & Ors. (2012) 3 SCC 277 has observed that
Environmental justice could be achieved only if we drift away from the principles of
anthropocentric to ecocentric. The state, as a custodian of the natural resources, has a duty to
maintain them not merely for the benefit of the public, but for the best interest of flora and
fauna, wildlife and so on. The doctrine of “public trust” has to be addressed in that
perspective [M.C. Mehta v. Kamal Nath [(1997) 1 SCC 388]
In light of the principles, it is submitted that the order in question violates Article 21, as it
fails to account for the constitutional obligation to protect and preserve endangered species,
particularly the Ren Wolf, which is a Schedule I species under the Wildlife Protection Act,
1972.
[2.2.2] THAT THE ORDER DISREGARDS PRINCIPLES OF PROPORTIONALITY
It is humbly submitted that the requirement of balancing various considerations brings to the
principle of proportionality. In the case of K.S. Puttaswamy vs. UOI (2017) 10 SCC 9, this
Court observed that the Proportionality is an essential facet of the guarantee against arbitrary
State action because it ensures that the nature and quality of the encroachment on the right is
not disproportionate to the purpose of the law. Further, in the case of CPIO v. Subhash
Chandra Aggarwal, (2019) SCC OnLine SC 1459, the meaning of proportionality was
explained as:
“It is also crucial for the standard of proportionality to be applied to
ensure that neither right is restricted to a greater extent than necessary to
fulfil the legitimate interest of the countervailing interest in question”
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Thus, applying this principle to wildlife conservation, any action must be the least intrusive
means to achieve the desired objective. Hunting, being the most extreme measure, should be
adopted only after all alternative and less harmful options have been explored and exhausted.
In the present case, alternative measures such as tranquilization, relocation, and enhanced
monitoring were available under Section 11 of the Wildlife Protection Act, 1972 but were not
considered or implemented by the State Government. The order’s immediate recourse to
hunting indicates a failure to comply with the proportionality standard.
It is pertinent to note that in Bombay Dyeing & Mfg. Co. Ltd. v. Bombay Environmental
Action Group, (2006) 3 SCC 434, the principles concerning biodiversity and environmental
protection are interwoven with the considerations for sustainable development and public
interest. The State Government’s action in this case, driven by public pressure rather than
scientific rationale, violates this principle.

It is humbly submitted that the ecological significance of the Ren Wolf as a keystone species
cannot be overstated. These wolves play a vital role in maintaining the health of the
ecosystem by controlling prey populations and ensuring ecological balance. The loss of even
a few individuals could have cascading effects, disrupting the food chain and degrading the
habitat. The failure to account for these ecological considerations in the present case
contravenes the State’s constitutional obligation under Article 48A.
In Indian Council for Enviro-Legal Action v. Union of India (1996), the Supreme Court
emphasized that state actions affecting biodiversity must be sustainable and scientifically
justified. In the present case, the lack of scientific evidence and the disproportionate response
to the alleged threat posed by the wolves make the order untenable.
[2.2.3] THE ORDER LACKS PROCEDURAL FAIRNESS AND DUE PROCESS
It is humbly submitted that Procedural fairness and adherence to natural justice are
fundamental principles governing administrative decisions, particularly those affecting
constitutional and statutory rights. In the case at hand, the orders issued by State Government
infringe upon the principles of natural justice and procedural fairness. They precluded the
opportunity for consultation by deliberately refusing to entertain representation from Unohu,
an organisation directly affected in the subject matter. Such an omission not only impairs the
credibility of the procedural mechanism but also tantamount to an explicit violation of
constitutional rights and statutory duties.
In Maneka Gandhi v. Union of India (1978) 1 SCC 248, the Supreme Court held that the
principles of natural justice, including the right to be heard, are integral to any administrative
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action. In Orissa Mining Corpn. Ltd. v. Ministry of Environment & Forests, (2013) 6 SCC
476, the Supreme Court underscored the need for consulting indigenous groups, emphasizing
their representation in decisions affecting their lands. This case highlights the legal obligation
to balance conservation with community rights.
[2.3] THE ORDER UNDERMINES INTERNATIONAL OBLIGATIONS AND
CONSERVATION EFFORTS
It is humbly submitted that Long Distances is a signatory to the Convention on Biological
Diversity (CBD). This convention imposes an obligation on the country to take proactive
measures to conserve endangered species and their habitats. By authorizing the hunting of an
endangered species without exhausting all non-lethal options, the State Government has
failed to honour these international commitments.
In Vellore Citizens Welfare Forum v. Union of India 1996 (5) SCC 647, the Supreme Court
recognized the importance of adhering to international environmental obligations and
incorporating them into domestic law. Similarly, in Research Foundation for Science,
Technology and Natural Resource Policy v. Union of India, (2007) 15 SCC 193: (2007) SCC
OnLine SC 1105, the Court emphasized the need to balance development objectives with
environmental conservation in line with international standards. The State Government’s
order in the present case contravenes these principles and undermines India’s global
reputation as a leader in wildlife conservation.
It is thus most respectfully contended before this Hon’ble Supreme Court that the order dated
December 1, 2024, issued by the Office of the Chief Minister, allowing the hunting of six
wolves, is illegal, unconstitutional, and not in conformity with international obligations, and
is therefore liable to be quashed.

III. ISSUE C: WHETHER THE ORDER DATED DECEMBER 2, 2024,

ORDERING THE SHUTDOWN OF INTERNET SERVICES IN 4
DISTRICTS IN SKYRABBIT, OUGHT TO BE QUASHED?
It is most respectfully submitted that the impugned order dated December 2, 2024, issued by
the Office of Chief Minister, directing the shutdown of internet services in four districts of
Skyrabbit, is [3.1] illegal, [3.2] unconstitutional, and its [3.3] impact has been detrimental to
both public safety and wildlife conservation. The order, thus, ought to be quashed.
[3.1] THAT THE ORDER IS ULTRA VIRES THE TELECOMMUNICATIONS
ACT, 2023.
Firstly, it is humbly submitted to this Hon’ble Court that the impugned order is ultra vires The
Telecommunications Act, 1885 and the Temporary Suspension of Telecommunication Services

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Rules, 2024 (hereinafter referred to as “The Temporary Suspension Rules”). For foundational
reference, sub-section (2) of section 20 of the Telecommunications Act, 2023 is relied upon.
20. Provisions for public emergency or public safety.— (CITATION OF SECTION 20
HERE)
(2) On the occurrence of any public emergency or in the interest of public safety, the Central
Government or a State Government or any officer specially authorised in this behalf by the
Central Government or a State Government, may, if satisfied that it is necessary or expedient
so to do, in the interest of the sovereignty and integrity of India, defence and security of the
State, friendly relations with foreign States, public order, or for preventing incitement to the
commission of any offence, subject to such procedure and safeguards as may be prescribed,
and for reasons to be recorded in writing, by order-
The requirements for suspending telecom services are as follows

a.) Telecom services can only be suspended on the occurrence of any public emergency,
or in the interest of the public safety;
b.) Before the services are shut down, the Central Government or a State Government
or any officer specially authorised in this behalf by the Central Government or a State
Government must be satisfied that it is necessary or expedient to shut down the
services
● in the interests of the sovereignty and integrity of
India, or the security of the State, or friendly relations with foreign
States, or public order, or for preventing incitement to the
commission of an offence.
c.) The reasons for issuing the suspension order must be recorded in writing.

[3.1.1] THAT THERE EXISTS NO PUBLIC EMERGENCY

It is humbly submitted that the occurrence of any public emergency or interest of public
safety is the sine qua non for the application of Section 20(2) of the Act. The word
“Public Emergency” has various connotations.
In Gujarat Mazdoor Sabha v. State of Gujarat, (2020) 10 SCC 459, this Hon’ble Court
held that a situation qualifies as a public emergency only when:
i. There exists a grave emergency; ii. The security of India or any part of its territory is
“threatened” by such emergency; and iii. The cause of such threat is war, external aggression
or internal disturbance.
It is pertinent to note that in Article 4 of the International Covenant On Civil And Political
Rights, notes that
‘In time of public emergency which threatens the life of the
nation and the existence of which is officially proclaimed…’.
(cite article 4 of iccpr)
In the instant case, the alleged unlawful killings of wildlife do not constitute a Public

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Emergency under the above criteria. It is an admitted fact that violence in the State of
Skyrabbit (hereinafter referred to as “State”), particularly in Village of Lightyears, had
already subsided before the issuance of the impugned order. The State has failed to bring any
evidence demonstrating ongoing or escalating disturbances. An emergency cannot
retroactively arise once the situation is already under control.
In S. Rangarajan v P. Jagjeevan Ram and Ors [Citation- 1989 (2) SCC 574], this Court
made it clear that the anticipated danger from transmission of information via the Internet
should not be remote, conjectural or far-fetched. It should have a proximate and direct nexus
with the speech or expression. In the present case, the grounds asserted for imposing the
internet shutdown appear to be fundamentally speculative, rooted in abstract fears based on
the viral social media post warning of "man- eating wolves," (cited here in paragraph no.4)
which are unfounded and specuative. The apprehension based on the posts are de facto
speculative and lack a conditio sine qua non; therefore, they do not meet the threshold for a
“public emergency,” as the concern does not manifest in any discernible, imminent threat.
It is humbly contended that the State has sought to justify the internet shutdown under
Section 20(2) of the Telecommunications Act, 2023, citing the need to prevent incitement to
the commission of an offence, particularly in relation to the killings allegedly caused by
hunting groups. It is respectfully submitted that this justification is tenuous, speculative, and
unsubstantiated. Moreover, the State has failed to substantiate its claims with any specific
incidents, data or intelligence to justify its claims as no specific posts have been identified as
capable of inciting the commission of an offence. An emergency without supporting
evidence is a fiction, not a fact.

It is humbly contended that the State erroneously attributed the actions of hunting groups
killing wild dogs and coyotes to internet access. However, the killings are independent of
online activities, as there is no evidence to show that such groups relied on the internet to
coordinate their activities or that their actions were influenced by social media posts. Mere
apprehension or the possibility of misuse cannot justify such a blanket shutdown.

[3.1.2] THAT THERE IS NO NECESSITY OR EXPEDIENCY TO PASS SUCH

ORDER

The second requirement of Section 5(2) of the Telecommunications Act, is for the Competent
Authority to be satisfied that it is ‘necessary’ or ‘expedient’ to pass the orders in the interest
of the sovereignty and integrity of India. The terms ‘necessary’ and ‘expedient’ imply that the
Government of Skyrabbit is liable to triangulate the necessity/expediency of imposition of an
internet shutdown, after satisfying the four prongs of the proportionality test. It is submitted
that the internet shutdown fails the proportionality test, as laid down in Modern Dental
College and Research Centre v. State of Madhya Pradesh, (2016) 7 SCC 353: To meet the
test of proportionality;
(a) a measure restricting a right must have a legitimate goal;
The purported objective of the State to address wildlife killings does not constitute a
legitimate justification for imposing a statewide internet shutdown. Notably, the alleged
incidents had significantly diminished by December 2024, thereby undermining the necessity
of such an extraordinary measure.

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(b) the measure must constitute a suitable means of furthering this goal;
The Respondents have failed to demonstrate how the suspension of internet services, which
hampers Unohu’s educational campaigns and anti-poaching efforts, furthers their stated
objective.
(c) there must not be any less restrictive but equally effective alternative;
The State failed to consider or adopt less intrusive measures to address its concerns.
Technological tools such as geo-blocking, content filtering, or targeted website restrictions
were available and could have addressed any purported risk without resorting to a blanket
shutdown. In Anuradha Bhasin v Union of India, (2020) 3 SCC 637, this Hon’ble Court held
that an internet shutdown should be a measure of last resort.

(d) the measure must not have a disproportionate impact on the right holder.
The adverse impact of the shutdown on Unohu’s conservation efforts and public access to
essential services far outweighs the purported benefits. A blanket internet ban affecting an
entire population cannot be justified where the disturbances were localized and had already
de-escalated. The response is grossly disproportionate to the ground reality.

[3.1.3] THAT THE ORDER VIOLATES PRINCIPLE OF NEMO JUDEX IN CAUSA

SUA
The third requirement under Section 20 (2) of the Telecommunications Act, 2023, read
with the Suspension Rules, 2024, mandates that any suspension order must be reviewed by
a Review Committee. As per Rule 2(5) of the Telecommunication Suspension Rules, the
Committee comprises of Chief Secretary (Chairman), Secretary, Law or Legal
Remembrancer In-Charge of Legal Affairs (Member), and Secretary to the State
Government (other than the Home Secretary) (Member).
It is most respectfully contended that this composition, however, violates the fundamental
principle of nemo judex in causa sua. The Committee is composed solely of executive
members, creating an inherent conflict of interest, as the executive is simultaneously tasked
with authorizing, enforcing, and reviewing the suspension orders. Such overlap undermines
the very object of independent review and procedural fairness.
Moreover, under Rule 2(5)(3), the role of the Review Committee is limited to merely
recording findings within five working days, without any power to revoke illegal or arbitrary
orders. This renders the Review Committee a toothless body, incapable of exercising
meaningful oversight or protecting against executive overreach. It is therefore submitted that
the approval of the order by such a Committee fails to meet the constitutional standard of
checks and balances and procedural safeguards envisioned and hence liable to be quashed.
It is pertinent to note that in the case this Hon’ble Court in Shreya Singhal v Union of India
(AIR 2015 SC 1523) held that mere advocacy or expression cannot amount to incitement
unless it leads to imminent lawless action. Here, the State has failed to meet this standard.
Additionally, The Supreme Court in PUCL v Union of India (AIR 1997 SC 568) held that
public order cannot be maintained by indiscriminately curtailing rights. Targeted
investigation and action against the perpetrators are the correct means to prevent further
killings, not a blanket shutdown that penalizes the larger population.

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It is, therefore, most respectfully submitted that the blanket internet shutdown, lacking a
clear causal link and failing to satisfy the test of necessity and proportionality, must be set
aside.

[3.2] THAT THE ORDER IS UNCONSTITUTIONAL AS IT VIOLATES

FUNDAMENTAL RIGHTS GUARANTEED BY THE CONSTITUTION OF INDIA.
It is respectfully submitted that the order imposing a blanket internet shutdown in the State
of Skyrabbit is unconstitutional, and constitutes a direct violation of the fundamental rights
guaranteed under the Constitution of India, specifically Articles 19(1)(a), Art.14 and Art.21.
The said order, purportedly issued in the interest of maintaining public order, fails to satisfy
the constitutional mandates of reasonableness, proportionality, and necessity, thereby
infringing upon the constitutional rights of the citizens, particularly those of the residents of
4 districts, who bear the brunt of this imposition.
[3.2.1] VIOLATION OF ARTICLE 19(1)(a)
Article 19(1)(a) of the Constitution of India guarantees the fundamental right to freedom of
speech and expression, which includes the right to seek, receive, and disseminate
information. This Court in Bennett Coleman & Co. v. Union of India (1972 2 SCC 788) has
emphasised the importance of freedom of speech and expression, giving it the title of “Arc of
the Covenant of democracy” and “Market place of ideas.”
Further, This Hon’ble Court in Shreya Singhal v Union of India (AIR 2015 SC 1523)
reiterated this view, emphasizing that the internet is now an integral medium for the exercise
of the right to free speech and expression. Therefore, the complete suspension of the internet
directly infringes upon this fundamental right. It is humbly submitted that the internet
shutdown severely restricts the ability of the citizens, particularly those engaged in wildlife
conservation, to access vital information, express opinions, and communicate freely. This
restriction goes beyond just limiting online communication. It curtails a platform for public
debate and the dissemination of factual information regarding the potential causes behind the
wolf attacks, which could significantly affect public perception of the situation.
Notwithstanding the State's power to impose reasonable restrictions on the right to free
speech and expression under Article 19(2) of the Constitution of India, such restrictions
ought to satisfy stipulated prerequisites and such measures must align with grounds like
sovereignty, public order, or morality. Prolonged internet suspension despite de-escalation of
clashes exceeds Article 19(2)'s scope (S. Rangarajan v. P. Jagjivan Ram, (1989) 2 SCC 574),
violating residents' constitutional right to internet access.

Furthermore, it was observed that not all types of speech constitute incitement. The Supreme
Court in Arup Bhuyan v State of Assam, (2011) 3 SCC 377 noted that three conditions need
to be satisfied to prove incitement- (i) Intent, that the speech must have the objective of
promoting violence; (ii) Imminence, that the speech must lead to imminent lawless action;
and (iii) Likelihood, that the speech was likely to create such lawless action. A complete ban
on communication is inimical to the central notion of article 19(2). An order which is in
excess of 19(2) is void under Article 13 of the Constitution.
[3.2.2] VIOLATION OF ARTICLE 14

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It is humbly submitted that the indiscriminate suspension of internet services affects all
citizens without distinction, thereby violating the principles of equality and fairness
enshrined under Article 14 of the Constitution of India. The facts indicate that no specific
post or individual has been identified as inciting violence. In the absence of concrete
evidence of misuse, a blanket ban on internet services punishes individuals who may have
been using the medium responsibly for legitimate expression, such as sharing news, opinion,
or constructive discourse. Denying a fundamental right without a clear and objective
rationale renders the suspension discriminatory and arbitrary under Article 14.

Furthermore, it is also contended that the rights under Articles 14 are breached inasmuch
there is no intelligible differentia between those who use the internet and those who by
words spoken or written use other mediums of communication. In State of West Bengal v.
Anwar Ali Sarkar, AIR 1952 SC 75, the Court held that classification must rest on a rational
basis and have a nexus to the object sought to be achieved, which the State has failed to
establish in the present case.

[3.2.2] VIOLATION OF ARTICLE 21

It is humbly submitted that Article 21 accords the right to life and personal liberty,
succinctly extending to the right to life with dignity. The imposition of an internet
blackout, while infringing upon the fundamental rights, obstructs access to basic
services, information, and their means of livelihood, thereby contravening Article
21 of the Constitution of India.
It is submitted, that on a bare perusal of the facts of the case that the media posts
have been preemptively blamed as potential triggers for violence. This leads to a
chilling effect where individuals are unable to access verified information about the
hunting incidents or surrounding events. The denial of access to factual information
prevents citizens from forming informed opinions, which is a foundational element
of democracy.
By denying internet access, the State effectively blocks access to news,
updates, and official communications thus violating Article 19(1)(a) read
with Article 21, as the right to access information is essential for
individual autonomy, safety, and the right to personal liberty. Ironically,
the internet shutdown, in fact, creates a greater risk of misinformation, as
citizens rely on unverified offline rumors and conjectures. Thus, the
suspension order not only violates fundamental rights but also contradicts
its own stated purpose of preventing unrest or further killings.
It is thus submitted with respect, the internet shutdown order in Skyrabbit State is
unconstitutional under the Indian Constitution, infringing on Articles 19(1)(a), 14,
and 21. It fails to ensure reasonableness, proportionality, and necessity, thus
violating citizens' rights, especially those residing in the affected districts, thereby
liable to be quashed.

[3.3] THAT THE ORDER IS DETRIMENTAL TO BOTH PUBLIC

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SAFETY AND WILDLIFE CONSERVATION

It is humbly submitted that the internet shutdown in the four districts of Skyrabbit,
has had a severe and detrimental impact on the citizens, particularly the villagers,
and on organizations like Unohu, which are dedicated to wildlife conservation and
education. Suspension of Internet causes incalculable damage, both in material
and human rights terms.

[3.3.1] THAT THE ORDER ADVERSELY IMPACTS VILLAGERS

It is humbly submitted that in wildlife-sensitive zones, real-time communication is

crucial for safety during emergencies. The inability to share or receive timely
updates due to the internet shutdown has intensified confusion and panic among
villagers. This disruption has heightened risks posed by wildlife encounters,
increasing both the danger to human lives and the likelihood of retaliatory harm to
wildlife.
The most important consequence of network disruptions is the creation of social
exclusion from other districts. Additionally, in the petition filed by Anuradha
Bhasin (cite Anuradha Bhasin here) regarding the constitutionality of internet
blackouts, mental health of citizens of Kashmir was stressed by stating that
“Communication blackouts result into anxiety, panic, alarm, insecurity and fear
amongst the people”.
It is most respectfully contended that the internet shutdown itself disrupted essential
services such as healthcare, education, and emergency communications, thereby
aggravating the hardships of innocent citizens. Far from protecting public safety, the
order directly endangered it.
[3.3.2] THAT THE ORDER ADVERSELY IMPACTS WILDLIFE
CONSERVATION
It is submitted that in the case at hand, The absence of effective communication systems has
not only endangered human lives but has also resulted in increased retaliatory attacks on
wildlife. It is submitted that the internet shutdown directly impairs the operation of
technologies such as drones, which are instrumental in tracking and monitoring wildlife
movement. Drones and other internet-based devices provide real time information necessary
for effective intervention and harm prevention. By shutting down internet services, the
Respondents have obstructed an effective tool for achieving the very objective they seek to
fulfill.

This contradicts the global and constitutional commitment to sustainable development under
Article 48-A
[3.3.3] THAT THE ORDER ADVERSELY IMPACTS CONSERVATIONS
EFFORTS OF UNOHU ORGANISATION
It is humbly submitted that, one of the key organizations impacted by this order is

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Unohu, which, due to the shutdown, cannot carry out its mission to educate the
public on the protection of endangered species, such as the Ren Wolves.
Unohu, relies on internet connectivity to conduct educational campaigns,
disseminate information, and engage with local communities. The shutdown has
paralyzed these efforts, depriving villagers of critical awareness programs aimed at
promoting coexistence and mitigating human-wildlife conflicts. This disruption
directly contradicts the Respondents’ stated objective of wildlife conservation.
The blanket assumption that internet use contributes to wildlife killings lacks
empirical support. In rural agrarian areas, the propagation of falsified information
predominantly transpires via word-of mouth rather than digital platforms.

It is thus submitted with respect, the internet shutdown has negatively impacted Unohu's
conservation activities and has impaired villagers' access to key education; this compromises
wildlife protection goals and is based on unvalidated assertions regarding internet misuse,
thereby liable to be quashed.

Issue D: Assuming that the order dated December 1, 2024, is quashed, what alternative
measures could the State Government employ to prevent animal attacks and capture
the wild animals responsible?
It is most respectfully submitted that the human-wildlife conflict in Skyrabbit is not merely a
local or national issue but a global concern, especially given the involvement of the
endangered Ren Wolves, with only 3,000 left worldwide. Human-wildlife conflict is
recognized as a critical global issue in the United Nations Convention on Biological
Diversity’s post-2020 global biodiversity framework. The measures suggested herein are
framed to balance the unique ecological, cultural, social, and economic characteristics of
Skyrabbit while addressing the immediate crisis and ensuring long-term sustainability.

[4.1] THE ALTERNATIVE MEASURES THE STATE GOVERNMENT COULD

EMPLOY TO PREVENT ANIMAL ATTACKS.
[4.1.1] COMPENSATION FOR THE VICTIMS
It is humbly submitted that the tragic loss of seven or more children in Skyrabbit between
October and December 2024 necessitates the provision of compensation to the victims’
families, as the wildlife in question is deemed the property of the Government under Section
11(3) of the Wildlife (Protection) Act, 1972. In the case, Farooq Ahmad Shah v. Union
Territory of J&K, it was held that if a wild animal causes loss to any human life or any

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agriculturist, then it would be the duty and responsibility of the concerned government to
provide compensation to the victim.
[4.1.2] STRENGTHENING THE EDUCATION AND AWARENESS CAMPAIGNS
It is humbly submitted that, building upon the petitioner’s successful village educational
programs, the State Government should intensify efforts to educate the local population on
distinguishing Ren Wolves from other wild animals such as wild dogs and coyotes. This can
minimize the indiscriminate killing of wildlife, as evidenced by the petitioner’s initiative,
which significantly reduced animal deaths in November 2024. The State could collaborate
with organizations like Unohu to develop community-based conservation programs.
[ 4.1.3] IMMEDIATE ACTIONS NEED TO BE TAKEN TO PACIFY THE
SITUATION
It is humbly submitted that the primary victims of the Ren Wolf attacks have been children
and infants, as highlighted by the numerous fatal incidents reported in the villages of
Skyrabbit. In this context, the State Government can implement temporary curfews and
specific hotspots can be identified in the affected areas, particularly during the dusk and dawn
hours when wolves are most active. This curfew would restrict the movement of children and
the elderly, ensuring they are indoors during high-risk times. The petitioner urges this Court
to direct the state government to take measures to enhance safety in affected areas which
includes installing doors in houses that lack them and conducting night patrols across
villages.

Given that the movement of the wolves can be captured through modern surveillance
technology, the State Government has a range of non-lethal tools at its disposal to track and
manage the Ren Wolves. Drone surveillance has already proven effective in identifying the
presence of wolves in the area, as demonstrated by the footage used to justify the hunting
order. To enhance this, the Government can deploy geo-spatial mapping and GPS collars
on the Ren Wolves, enabling real-time tracking of their movements across vast stretches of
land.
The Petitioner humbly requests this Hon’ble Court to direct the State Government of
Skyrabbit to establish a program aimed at improving public safety and preventing human-
wolf conflicts, namely the WolfSafe Alert Network (WSAN). The WSAN should include a
toll-free tip-line and a web-based reporting service that will enable the public to report any
human-wolf interactions where safety may be at risk. Such a program would empower

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citizens to report sightings and encounters with wolves promptly, ensuring a swift response
from the authorities.
The Petitioner respectfully urges this Hon'ble Court to direct the State Government to
establish facilities for forest officials to stay in the affected villages until the human-wolf
conflict is controlled. As per the facts of the case, due to the isolated nature of these villages,
forest officials could only reach them days after the attacks, delaying timely intervention and
crucial evidence collection. Stationing officials on-site will allow for quicker responses to
threats, more effective monitoring of wildlife movements, and immediate action to prevent
further attacks.
The Petitioner urges the Court to direct the State Government to install turbo-fladry fencing
tool usually consisting of bright-red nylon flags that are sewn onto a long strand of woven
plastic and metal wire that is capable of conducting an electrical current. This type of
temporary electric fencing works because wolves are instinctively fearful of the motion of the
flags and will receive a shock if they eventually become bold enough to approach and touch
the electrified wire. When used correctly, turbo fladry is a highly effective tool for preventing
wolf predation.
The Petitioner urges the Court to direct the State Government to implement IUCN
(Internation Union for Conservation of Nature) recommended measures to which the
Long Distances is a signatory, including barriers (fences, nets), early-warning systems
(sirens, lights), deterrents, translocation of wildlife, and compensation for affected families.
These measures will help manage the human-wolf conflict while protecting both public safety
and the endangered Ren Wolves.
[4.1.4] LONG TERM GOALS
It is humbly submitted that Long Distances, an ecologically diverse nation with a
predominantly agrarian economy, has witnessed substantial agricultural expansion at the
expense of its rich forest lands. In the State of Skyrabbit, forests that were once dense and
thriving have been converted into small villages comprising individual farms, with
agriculture being prioritized over environmental conservation. This transformation, marked
by the encroachment of forest habitats, has likely disrupted the delicate ecological balance,
potentially contributing to incidents such as the recent human-wildlife conflict witnessed in
the region.
It is further submitted that agriculture, being a subject listed under Entry 14 of the State
List, necessitates an environmentally balanced approach. Encroachments into forest lands
and the rapid increase in cultivated areas around wildlife habitats have significantly
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contributed to the degradation of biodiversity. Therefore, reforms in agricultural policies
must consolidate the dual objectives of promoting agriculture while ensuring environmental
protection. Alignment with Sustainable Development Goals (SDGs), specifically SDG 14
(Life Below Water) and SDG 15 (Life on Land), is essential to achieve a sustainable
balance between agricultural growth and ecological preservation
It is submitted that the fragmentation of wildlife habitats caused by agricultural expansion
and developmental activities in Skyrabbit has severely impacted the ecological equilibrium.
The Environment (Protection) Act, 1986 mandates that all developmental projects undergo an
Environmental Impact Assessment (EIA) and, where necessary, the formulation of an
Environmental Management Plan (EMP) to evaluate and mitigate potential environmental
harm.

[4.2] THE ALTERNATIVE MEASURES THE STATE GOVERNMENT COULD

EMPLOY TO CAPTURE WILD ANIMALS RESPONSIBLE
[4.2.1] FORMATION OF A HIGH-LEVEL COMMITTEE
It is humbly submitted that the State Government should constitute a high-level committee
comprising the Principal Secretary of Forests and the Principal Chief Conservator of Forests,
as provided under the Indian Forest Act, 1927. This committee will ascertain the specific
threat posed by an individual animal or pack and recommend appropriate measures.
Community Collaboration:
a) The Forest Department must proactively engage with local communities to mitigate losses
and provide timely assistance.
b) The methods adopted should be tailored through consultation with field-level staff, often
local inhabitants familiar with the terrain and animal behavior, along with the local village
administration to ensure practical and effective implementation.
c) The approach should balance enforcement with empathy, recognizing the traditional
tolerance communities have shown toward carnivores and addressing the genuine hardships
arising from their presence.
[4.2.2] ROLE OF THE WILDLIFE CRIME CONTROL BUREAU (WCCB)
The Wildlife Crime Control Bureau (WCCB), established under Section 38Y of the
Wildlife Protection Act, 1972, should actively participate in reviewing and resolving human-
wolf conflicts. The WCCB must prepare a comprehensive review report detailing instances of
conflict between humans and wolves. This includes maintaining a conflict history for Ren

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Wolves, cataloging evidence such as witness accounts and physical traces of wolf activity,
along with analyzing human behaviors that may have contributed to these encounters.
[4.2.3] OPERATION REN WOLVES
It is crucial to recognize that wolves are highly social animals, living in packs with a
hierarchical structure typically led by a dominant breeding pair. Their opportunistic hunting
behavior, adaptability in diet, and varied hunting tactics demand intervention measures that
are tailored specifically to their species. Such characteristics necessitate a more nuanced and
scientific approach in capturing and managing wolves involved in conflicts with humans,
ensuring both effective resolution and adherence to conservation principles.
It is respectfully submitted that drone cameras and thermal imaging systems should be
deployed to monitor wolf movements and locate dens, while GPS tracking should be
employed to identify critical conflict zones. Furthermore, authorization for tranquilization of
the wolves must be obtained from the Chief Wildlife Warden, as mandated under Section
11 of the Wildlife Protection Act, 1972.

[4.2.4] UNCONVENTIONAL BAITING TECHNIQUES:

It is respectfully submitted that brightly colored teddy bears soaked in children's urine should
be strategically placed near riverbanks and known wolf dens to mimic human scent and
attract wolves into traps. Additionally, firecrackers and burning elephant dung should be
employed to guide wolves into designated capture zones, simulating the presence of predators
and deterring their return to human settlements.
[4.2.5] SAFE CAPTURE AND RELOCATION:
In accordance with established wildlife conservation protocols, tranquilized wolves must be
securely transported to zoological parks or wildlife rehabilitation centers to ensure their
safety and alignment with conservation objectives. Additionally, it is imperative that rigorous
quarantine procedures and veterinary evaluations are conducted to assess the wolves' health
and prevent the transmission of zoonotic diseases.

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PRAYER

Wherefore in the light of the issues raised, arguments advanced and authorities cited,
it is humbly requested that this Honourable Court may be pleased to adjudge and declare:

1. Hold that the present Public Interest Litigation (PIL) filed before this Honourable
Court is maintainable under Article 32 of the Constitution of Long Distances.
2. Quash the order dated December 1, 2024, issued by the State Government, directing
the hunting of the Ren Wolves in Skyrabbit, and declare the same as illegal, arbitrary,
and in violation of the provisions of the Wildlife (Protection) Act, 1972
3. Quash the order dated December 2, 2024, issued by the State Government shutting
down internet services in Skyrabbit’s four districts, as it violates Article 19(1)(a) of
the Constitution and fails to meet the necessity and proportionality requirements under
the Telecommunications Act, being unconstitutional and excessive
4. direct the State Government to provide compensation to the families of the victims of
the recent wolf attacks
5. Direct the State Government to implement immediate non-lethal measures, including
drone surveillance, GPS tracking, and installation of protective measures such as turbo-fladry
fencing, to prevent further human-wolf conflicts while ensuring the safety of the Ren Wolves
6. Order the establishment of the WolfSafe Alert Network (WSAN) for the public to
report human-wolf interactions, ensuring swift responses from authorities and improved
safety for the citizens of Skyrabbit.
And pass any such order, writ or direction as the Honourable Court deems fit and
proper, for this the Appellants shall duty bound pray.

ALL OF WHICH IS RESPECTFULLY SUBMITTED

COUNSEL FOR THE APPELLANTS

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