YASHWANTRAO CHAVAN LAW COLLEGE ,MOOT PROBLEM –I

IN THE SUPREME COURT OF INDIA

___________________________________________________________________________

CIVIL ORIGINAL JURISDICATION

PUBLIC INTEREST LITIGATION NO.__ OF 2021

___________________________________________________________________________

ASSOCIATION OF LIBERTIES AND FREE SPEECH ………Petitioner

V.

PRESS COUNSIL OF INDIA ………Respondent

___________________________________________________________________________

WRITTEN SUBMISSION ON BEHALF OF THE PETITIONER

MOHAN ANANT VISHNU

B.A.LL.B.-5
ID NO. 426751

WRIITEN SUBMISSIONS ON BEHALF OF PETITIONER

 YASHWANTRAO CHAVAN LAW COLLEGE ,MOOT PROBLEM –I

TABLE OF CONTENTS
___________________________________________________________________________

SR.NO. PARTICULARS PAGE NO.

1. List of Abbreviation 3

2. References 4

3. Statement of Jurisdictions 5

4. Statement of facts 6

5. Statement of Issues 7

6. Summary of Pleadings 8

7. Arguments Advanced 9

8. Prayer 12

WRIITEN SUBMISSIONS ON BEHALF OF PETITIONER

 YASHWANTRAO CHAVAN LAW COLLEGE ,MOOT PROBLEM –I

ABBREVATIONS
___________________________________________________________________________

AIR ALL INDIA REPORTER

SCC SUPREME COURT CASES

ALL ALLAHABAD

Art. ARTICLE

SC SUPREME COURT

Sec SECTION

UOI UNION OF INDIA

v. VERSUS

GOVT. GOVERNMENT

HC HIGH COURT

Ors. OTHERS

CoC Contempt of Court

& AND

Pg. PAGE

WRIITEN SUBMISSIONS ON BEHALF OF PETITIONER

 YASHWANTRAO CHAVAN LAW COLLEGE ,MOOT PROBLEM –I

REFERENCES
___________________________________________________________________________

1. CASES :

1. Bangalore Medical Trustv. B.S. Muddappa, (1991) 4 SCC 54

2. Biswas v. Union of India, (2002) 5 SCC 111
3. Saibal Kumar Gupta vs. B.K. Sen, reported in AIR 1961 SC 633
4. A.K. Gopalan vs. Noordeen,reported in(1969) 2 SCC 734
5. Justice K.S. Puttaswamy vs. Union of India, reported in(2018) 1 SCC 809
6. Subramaniam Swamy vs. Union of India, reported in(2015) 13 SCC 353
7. Sahara India Real Estate Corporation Ltd vs SEBI, reported in(2012) 10 SCC 603
8. Sidhartha Vashist @ Manu Sharma vs.State (NCT of Delhi),reported in(2010) 6 SCC 1
9. R.K. Anand vs.Delhi High Court,reported in (2009) 8 SCC 106
10. M.P Lohia vs.State of West Bengal,reported in(2005) 2 SCC 686

2. BOOKS :

A. MP JAIN, “INDIAN CONSTITUTIONAL LAW” 7TH EDITION REPRINT 2005, LEXIS NEXIS
B. DR. S. P. GUPTA, “PROFESSIONAL ETHICS, ACCOUNTANCY FOR LAWYERS
TH
AND BENCH-BAR RELATIONS, 5 EDITION, CENTRAL LAW AGENCY
TH
C. B. R. AGARWALA’S , “SUPREME COURT PRACTICE AND PROCEDURE, 6 EDITION,

EASTERN BOOK COMPANY.”

3. STATUTORY COMPILATIONS :

A. The Constitution Of India, 1950

B. The Contempt of Court Act, 1971
C. The Supreme Court Rules, 2013
D. Indian Penal Code,1860
E. Press Council Act, 1978
F. Cable Television Networks ( Regulation ) Act,1995

WRIITEN SUBMISSIONS ON BEHALF OF PETITIONER

 YASHWANTRAO CHAVAN LAW COLLEGE ,MOOT PROBLEM –I

4. INTERNET SITES :

1. http://www.findlaw.com
2. http://www.judis.nic.in
3. http://www.lawsofindia.org
4. http://www.supremecourtcaselaw.com

5. REPORTS
200th Report of Law commission of India

WRIITEN SUBMISSIONS ON BEHALF OF PETITIONER

 YASHWANTRAO CHAVAN LAW COLLEGE ,MOOT PROBLEM –I

STATEMENT OF JURISDICTION
___________________________________________________________________________
The petitioner has mentioned the jurisdiction of the honourable Supreme Court by virtue of article
32 of the constitution of India.
Art. 32 – Remedies for enforcement of rights conferred by this Part –

1. The right to move to the Supreme Court 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
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 be 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 suspend except as otherwise provided for the
constitution.
Therefore ,This Hon’ble court has Jurisdsiction to entertain this PIL.

WRIITEN SUBMISSIONS ON BEHALF OF PETITIONER

 YASHWANTRAO CHAVAN LAW COLLEGE ,MOOT PROBLEM –I

STATEMENT OF FACTS

Media was once a boon that enlightened people and made them aware of what is going around the world.
The indian media has to follow the principals laid down in the Constitution of India. There are essentially
three pillers of democracy that are the legislature,executive and Judiciary and now the media has become
the fourth pillar of democracy. It highlights the social,legal,econon=mic and cultural problems of the
society.
Media has now transformed itself into a Janta Adalats or ‘Public Courts’ and started intervining in the
proceedings of the court. The vital gap between the convict and princials of ‘presumption of innocence
until proven guilty’ and guilt beyond reasonable doubt’. Now what is being observed is a separate
investigation done by the media itself which is called a media trial. Along with investigation, it includes
forming public opinion a result of this,the public is prejudiced due to which the accused who should have
been innocent is presumed to be a criminal, abandoning all his rights and liberty unrepressed.

WRIITEN SUBMISSIONS ON BEHALF OF PETITIONER

 YASHWANTRAO CHAVAN LAW COLLEGE ,MOOT PROBLEM –I

STATEMENT OF ISSUES

That the Counsel raises the following issues before the Hon’ble Supreme Court;
1. WHETHER THIS PETITION IS MAINTAINABLE WITHIN THE EYES OF LAW?
2. WHETHER THE PRESS COUNSIL OF INDIA IS “STATE” WITHIN THE DEFINATION OF
ARTICLE 12 OF INDIAN CONSTITUTUION?
3. WHETHER THE CONTEMPT PROCEEDINGS BE INITITATED AGAINST THE RESPONDENT
FOR NOT OBILYSING THEIR STATUTORY DUTIES?

WRIITEN SUBMISSIONS ON BEHALF OF PETITIONER

 YASHWANTRAO CHAVAN LAW COLLEGE ,MOOT PROBLEM –I

Summary of Pleading

1. WHETHER THIS PETITION IS MAINTAINABLE WITHIN THE EYES OF LAW?

As the press counsil of India is a statutory body constituted under Indian press act and it has power to
frame its own rules and regulations to control the media in India so, It is a state constituted under section
12 of the constitution of India and the fundamental right of the accused is to be allegedly infringed by he
media houses in india therefore this petition is maintainable under Article 32 of the Constitution of India.
2. WHETHER THE PRESS COUNSIL OF INDIA IS “STATE” WITHIN THE DEFINATION OF
ARTICLE 12 OF INDIAN CONSTITUTUION?
The Press Council functions under the Press Council Act, 1978. It is a statutory, quasi judicial authority
functioning as a watchdog of the press, for the press and by the press. It adjudicates the complaints
against and by the press for violation of ethics and for violation of the freedom of the press respectively.
That is why the Press counsil of India is state within the Defination of Article 12 and the writ may be
issued against it.
3. WHETHER THE CONTEMPT PROCEEDINGS BE INITITATED AGAINST THE RESPONDENT
FOR NOT OBILYSING THEIR STATUTORY DUTIES?
The Press Council of India is a statutory, quasi judicial authority functioning as a watchdog of the press,
for the press and by the press. It adjudicates the complaints against and by the press for violation of ethics
and for violation of the freedom of the press respectively and though there is proper ode of conduct has
been framed by the Bombay high Court for avoidance of media trail no steps has been taken by the
counsil ad therefore there is continuation in the act of interference of media in the judicial process is
going on therefore this act amounts to contempt of the court.

WRIITEN SUBMISSIONS ON BEHALF OF PETITIONER

 YASHWANTRAO CHAVAN LAW COLLEGE ,MOOT PROBLEM –I

ARGUMENTS ADVANCED

1.WHETHER THIS PETITION IS MAINTAINABLE WITHIN THE EYES OF LAW?

Petitioner is the Association Registered Under the Societies Act,1860 registered within India and
therefore is a legal person representing body of person in the larger public Interest having the Interest in
the present matter as there being the violation of the fundamental rights of the accused in the cases as
there are many media trails are going on in the country and as the petitioner is the vigillent towards the
rights of the accused hence filling this petition. the electronic media in derogation of their legitimate
media rights are broadcasting irresponsible and unethical news programmes of a nature amounting to
slander as also amounting to a direct interference in the course of investigation, as undertaken by the
investigating agencies, of a highly prejudicial nature. The petitioners contend that some of the television
channels have televised interviews with material witnesses and infact indulged in cross-examining these
witnesses. They have taken upon themselves the role of the investigating agencies, prosecutors and
adjudicators in pronouncing persons guilty of committing an offence, even before the lawful investigation
is completed by the investigating agencies. It is claimed that the news channels have also resorted to a
reckless reporting against the State agencies on whom the powers of investigation are conferred by law.
That such interference by the electronic media in the course of lawful investigation of any alleged crime
defies all cannons of legal legitimacy.
In Bangalore Medical Trustv. B.S. Muddappa, (1991) 4 SCC 54,the Court held that the restricted
meaning of aggrieved person and the narrow outlook of a specific injury has yielded in favour of a broad
and wide construction in the wake of public interest litigation. The Court further observed that public-
spirited citizens having faith in the rule of law are rendering great social and legal service by espousing
causes of public nature. They cannot be ignored or overlooked on a technical or conservative yardstick of
the rule of locus standi or the absence of personal loss or injury. There has, thus, been a spectacular
expansion of the concept of locus standi. The concept is much wider and it takes in its stride anyone who
is not a mere ‘busybody’.

2.WHETHER THE PRESS COUNSIL OF INDIA IS “STATE” WITHIN THE DEFINATION OF

ARTICLE 12 OF INDIAN CONSTITUTUION?
The Press Council functions under the Press Council Act, 1978. It is a statutory, quasi judicial authority
functioning as a watchdog of the press, for the press and by the press. It adjudicates the complaints
against and by the press for violation of ethics and for violation of the freedom of the press respectively.
That is why the Press counsil of India is a ‘Authority’ and therefore state within the Defination of Article
12 and the writ may be issued against it.
In the case of Rajasthan State Electtricity Board v. Mohal Lal, AIR 1967 SC 1857 Supreme court has
held that “Authority” means a public administrative agency or corporation having quasi-governmental
powers and authorized to administer a revenue producing public enterprise. It is wide enough to include
all bodies created by a statute on which powers are conferred to carry out governmental or quasi-
governmental functions
Ujjain Bai v. State of U.P. , AIR 1962 SC 1621, The word “State” is of wide amplitude and capable of
comprehending every authority created under the statute and functioning within the territory of India.
There is no characterization of the nature of authority set up under a statute for the purpose of

WRIITEN SUBMISSIONS ON BEHALF OF PETITIONER

 YASHWANTRAO CHAVAN LAW COLLEGE ,MOOT PROBLEM –I

administering laws enacted by the Parliament or by the State including those vested with the duty to make
decisions in order to implement those laws.

Pradeep Kumar Biswas v. Union of India, (2002) 5 SCC 111 “Authority” in law belongs to the province
of power. The word “State” and “Authority” used in Article 12 remain among “the great generalities of
the Constitution” the content of which has been and continues to be applied by Courts from time to time.
The expression ‘other authorities’ will include all constitutional or statutory authorities on whom powers
are conferred for the purpose of promoting economic activities. It is not only confined to statutory
corporations alone but may include a government company, a registered society, or bodies which have
some nexus with the government [Dr. J.N. Pandey’s The Constitution of India, 48th Edn., Central Law
Agency, Pg. No. 62-63]
Hence, from the above discussion it can be concluded that the Press Counsil is the State within the
definition of Article 12 of the Constitution of India.

3.WHETHER THE CONTEMPT PROCEEDINGS BE INITITATED AGAINST THE

RESPONDENT FOR NOT OBILYSING THEIR STATUTORY DUTIES?
The Press Council of India is a statutory, quasi judicial authority functioning as a watchdog of the press,
for the press and by the press. It adjudicates the complaints against and by the press for violation of ethics
and for violation of the freedom of the press respectively and though there is proper ode of conduct has
been framed by the Bombay high Court for avoidance of media trail no steps has been taken by the
counsil ad therefore there is continuation in the act of interference of media in the judicial process is
going on therefore this act amounts to contempt of the court.

That, such media trial,which has resulted into parallel investigation being undertaken by private
individuals, amountsto gross violation of the rights of the accused and the witnesses guaranteed under
Articles 14 and 21 of the Constitution, as right to a fair trial including a fair investigation is a
Fundamental Right of an accused in the Indian criminal justice system.

That media in our country enjoys extreme privileges; however, the same cannot be allowed to undermine
the authoritative investigation being undertaken by the authorities. The right to freedom of speech and
expression guaranteed under Article 19(1)(a) is not absolute and as Article 19(2) ordains, can be restricted
by law, inter-alia, in the interests of public order, decency or morality or in relation to contempt of court,
defamation or incitement to an offence. It is submitted that such an action on the part of the electronic
media is brazenly illegal, apart from being grossly unfair and an irresponsible conduct on the part of the
media house.

It is contended that the constitutional protection under Article 21 protecting the right of an accused of a
fair trial is in the nature of a valid restriction operating on the right of free speech under Article 19(1)(a)
by the very force of the former being a constitutional provision. According to the petitioner, the media has
publicly tried and convicted the alleged accused and has even proceeded to attribute a number of acts to
the accused person(s) portraying the accused as a murderer, abettor, a drug addict,etc. The media has in
fact declared that number of persons are involved in the suicide of the actor, alleging it to be murder case,
inter-alia, on the basis of -(i) statement to the CBI of a potential witness (a house manager)has been put
up in the media; (ii) Whatsapp chats between potential witnesses have been broadcast; (iii) death, rape,
etc. threats to the alleged accused; (iv) reaction of investigation agency to the statements given by certain
accused has been published in the media; (v) statements of hospital staff members reported/published in
the media; (vi) the forensic specialist who carried out the autopsy onthe body of the actor has also been
interviewed on a national TV channel; (vii) statements of investigating officers, and purported statements

WRIITEN SUBMISSIONS ON BEHALF OF PETITIONER

 YASHWANTRAO CHAVAN LAW COLLEGE ,MOOT PROBLEM –I

of certain witnesses have also been commented upon; (viii) IPS officers of Bihar Police havealso
appeared in TV debates on the said issue; (ix) private chats of the alleged accused were also published in
media; and(x) abusing and tarnishing the reputation as well as calling into question, the character of the
accused/suspect for not answering the questions posed by the media.

It is contended that such acts on the part of the electronic media would amount to a relentless intrusion in
the private lives of the victims and the witnesses. In addition to this, the reputation of the State police was
tarnished portraying it to be incompetent and complacent in screening the concerned accused. Also, the
potential witnesses have been exposed by identifying them, interviewing them and by bringing them in
the public eye, asking them to make statements on TV channels and terming their statements as
confessions. This crosses all boundaries of legitimacy.

The Supreme Court in Saibal Kumar Gupta vs. B.K. Sen, reported in AIR 1961 SC 633,in the context of
parallel investigation at the hands of the media to contend that the Supreme Court held that “it would be
mischievous for a newspaper to systematically conduct an independent investigation into a crime and to
publish the results of such investigation, and that such trial by media must be prevented as it tends to
adversely interfere with the course of justice”.

That the issue of trial by media or prejudice to a fair trial on account of pre-trial publication is directly
linked with Article 19(1)(a) of the Constitution as well as section 3 of the CoC Act. The issue is about
balancing the freedom of speech and expression on the one hand and undue interference with
administration of justice within the framework of the CoC Act as permitted by Article 19(2)on the other.

The petitioners next contend that the provisions of section 3 of the CoCAct restricts the freedom of
speech and expression including the freedom of the media to report, if anysuch publication obstructs the
course of justice in connection with any civil or criminal proceeding which is pending. According to the
petitioner, section 3(1) of the CoC Act affords protection, to the person, if the person who publishes has
no reasonable grounds to believe that a proceeding is pending before a court of law. The petitioner
saysthat as per the present law, the starting point of pendency of criminal proceedings is from the stage
when the court actually gets involved on submission of a final report by the investigating agency under
section 173 of the Cr.P.C. there by meaning that any publication prior to filing of such report is not
contempt.

A.K. Gopalan vs. Noordeen,reported in(1969) 2 SCC 734, to contend that the Supreme Court has held
that “a contempt of court may be committed by a person when he knows or has good reason to believe
that criminal proceedings are imminent”. According to the petitioner, the test is whether the
circumstances in which the alleged contemnor makes a statement are such that a person of ordinary
prudence would be of opinion that criminal proceedings would soon be launched.

Justice K.S. Puttaswamy vs. Union of India, reported in(2018) 1 SCC 809, to contend that it is law
declared that the right to privacy is an intrinsic part of right to life and personal liberty under Article 21
and forms part of the freedoms guaranteed under Part III of the Constitution. It is, thus, contended that the
relentless intrusion of the media in the personal and private life of the accused/suspect and the family and
friends of such person amounts to violation of such liberty.

Subramaniam Swamy vs. Union of India, reported in(2015) 13 SCC 353, to contend that the Supreme
Court has analyzed the meaning of the terms “defamation” and “reputation” and observed that the concept
of reputation is included in the protection of ‘dignity’ which is a part of the constitutional protection
provided under the right to life. The Court has ratified that restrictions on such freedom do not have an
undue chilling effect on the right and hence, the right to freedom of speech does not override the right to
reputation.

WRIITEN SUBMISSIONS ON BEHALF OF PETITIONER

 YASHWANTRAO CHAVAN LAW COLLEGE ,MOOT PROBLEM –I

The freedom of the media, especially of the TV channels, cannot be allowed to super stretch to a point
where, by outpouring reprobate information, begins to clog and cloud the pellucid comprehension of
‘facts/news’ in the people’s minds and impinges upon free and fair investigation. The actions of the media
in sensationalizing the actor’s death is not only adversely impacting the ongoing investigation by the CBI,
but was also in the teeth of the ‘doctrine of postponement’ propounded by a Constitution Bench of the
Supreme Court in the case of Sahara India Real Estate Corporation Ltd vs SEBI, reported in(2012) 10
SCC 603.
That such media coverage not only flouts and violates the mandate of the CTVNAct and the Rules there
under,but it is also in contravention of the Code of Ethics and Broadcasting Standards Regulations. The
further contention is that majority of the media of this country is Corporate Media, not owned and/or
controlled by the State/Government but by business houses which thrive upon and function upon the
TRP-driven and ratings and viewership oriented “business models” to generate profits for themselves by
attracting advertisements, sponsorships, investments, etc.

That media is plagued with the affliction of disproportionate reporting, which may be seen from the
undue coverage given to inconsequential and mindless matters, unrelated to the greater good of the people
of the country, as opposed to issues of national and international importance which the people are
grappling with such as the COVID 19 crisis, mass joblessness,economic downfall, starvation, medical and
healthcare structural problems, farmers issues, domestic violence,etc. These are the issues which hardly
ever get any substantial significant or considerable coverage in comparison to the TV time given to the
exaggerated and sensationalised non-issues.
That it is definitely not in the domain of the media to prove someone guilty, and there is no question of
guilt or innocence till the investigation and trial by competent authorities is complete;however,it is
apparent that the media is hellbent upon painting the accused persons named in the FIR as guilty and
culpable, through relentless repetitiveand reiterativerhetoric and emphasis.

Supreme Court in Sidhartha Vashist @ Manu Sharma vs.State (NCT of Delhi), reported in(2010) 6
SCC 1,wherein the Supreme Court has commented on the danger of serious risk of prejudice if the media
exercises an unrestricted and unregulated freedom, and that trial by media does not hamper fair
investigation by the investigating agency and more importantly does not prejudice the right of defence of
the accused in any manner whatsoever. The Supreme Court also observed that it will amount to a travesty
of justice if either of this causes impediments in the accepted judicious and fair investigation and trial. It
is held that the freedom of speech protected under Article 19(1)(a) of the Constitution has to be carefully
and cautiously used, so as to avoid interference with the administration of justice and leading to
undesirable results in matters sub judice before the courts.

The petitioners refer to the decision of the Supreme Court in R.K. Anand vs.Delhi High Court,reported
in (2009) 8 SCC 106,wherethe Supreme Court observed that it would be a sad day for the court to employ
the media for setting its own house in order and the media too would not relish the role of being the
snoopers of the court. It was observed that the media should perform the acts of journalism and not as a
special agency for the court. It was also observed that the impact of television and newspaper coverage on
a person’s reputation by creating a widespread perception of guilt regardless of any verdict in a court of
law is most unfair.
Supreme Court in M.P Lohia vs.State of West Bengal,reported in(2005) 2 SCC 686,contend that the
Court reiterated its earlier view that freedom of speech and expression sometimes may amount to

WRIITEN SUBMISSIONS ON BEHALF OF PETITIONER

 YASHWANTRAO CHAVAN LAW COLLEGE ,MOOT PROBLEM –I

interference with the administration of justice, and that articles appearing in the media that could be
prejudicial should not be permitted.
Bombay High Court in the PUBLIC INTEREST LITIGATION (ST) NO. 92252 OF 2020 Nilesh
Navlakha Vs. Union of India issued some guidelines to be followed by the media houses ;
Accordingly, we direct the press/media to exercise restraint and refrain from printing/displaying any
news item and/or initiating any discussion/debate/interview of the nature, as indicated hereunder:
a.In relation to death by suicide, depicting the deceased as one having a weak character or intruding in
any manner on the privacy of the deceased;

b. That causes prejudice to an ongoing inquiry/investigation by:

(i) Referring to the character of the accused/victim and creating an atmosphere of prejudice for both;
(ii) Holding interviews with the victim, the witnesses and/or any of their family members and displaying it
on screen;
(iii) Analyzing versions of witnesses, whose evidence could be vital at the stage of trial;
(iv) Publishing a confession allegedly made to a police officer by an accused and trying to make the
public believe that the same is a piece of evidence which is admissible before a Court and there is no
reason for the Court not to act upon it, without letting the public know the nitty-gritty of the Evidence Act,
1872;
(v) Printing photographs of an accused and thereby facilitating his identification;
(vi) Criticizing the investigative agency based on half-baked information without proper research;
(vii) Pronouncing on the merits of the case, including pre-judging the guilt or innocence qua an accused
or an individual not yet wanted in a case, as the case may be;
(viii) Recreating/reconstructing a crime scene and depicting how the accused committed the crime;
(ix) Predicting the proposed/future course of action including steps that ought to be taken in a particular
direction to complete the investigation; and
(x) Leaking sensitive and confidential information from materials collected by the investigating agency;

WRIITEN SUBMISSIONS ON BEHALF OF PETITIONER

 YASHWANTRAO CHAVAN LAW COLLEGE ,MOOT PROBLEM –I

PRAYER

WHEREFORE IN LIGHT OF THE ISSUES RAISED, ARGUMENTS ADVANCED, REASONS

GIVEN AND AUTHORITIS CITED, THIS COURT MAY GRACIOUSLY BE PLEASED TO:

a) Issue a writ of mandamus or any other writ, order or direction upon respondent thereby issuing
instructions/guidelines to be followed by the Media Houses be it print, electronic, radio, internet or
television or any other form of Media, to refrain from publishing and circulating any false, derogatory and
scandalous comments, social media posts, news stories etc. which may jeopardize the reputation of the
Police and may cause the public to lose faith in the system and in Police administration or hinder the
cause of administration of Justice. and

b) Issue a writ of mandamus or any other writ, order or direction upon respondent nos. 1 to 4 issuing
instructions/guidelines to the Media Houses be it print, electronic, radio, internet or television or any other
form of Media, to refrain from conducting a “Media Trial” of any case which may cause serious prejudice
inter alia to the proper functioning of the Investigating agency; and

c) Issue Contempt proceedings against the Respondent for not complying the guildelines issued by the
Bombay High Court in the PUBLIC INTEREST LITIGATION (ST) NO. 92252 OF 2020 Nilesh
Navlakha Vs. Union of India. Along with Acting in any manner so as to violate the provisions of the
Programme Code as prescribed under section 5 of the CTVN Act read with rule 6 of the CTVN Rules and
thereby inviting contempt of court.

AND ANY OTHER RELIEF THAT THIS COURT MAY BE PLEASED TO GRANT IN
THE INTEREST OF JUSTICE, EQUITY AND GOOD CONSCIENCE.

ALL OF WHICH RESPECTFULLY SUBMITTED.

COUNSEL FOR THE PETITIONER

WRIITEN SUBMISSIONS ON BEHALF OF PETITIONER

 YASHWANTRAO CHAVAN LAW COLLEGE ,MOOT PROBLEM –I

WRIITEN SUBMISSIONS ON BEHALF OF PETITIONER