TEAM CODE # P - 16

BEFORE THE HON’BLE SUPREME COURT OF THE REPUBLIC OF ZEUS

YOUNG FIGHTERS FOR JUSTICE (YFFJ)

V
GOVERNMENT OF THE REPUBLIC OF ZEUS
2023

MEMORIAL FOR RESPONDENT

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 TABLE OF CONTENT

Sr. No Particulars Page No.

1 Table of contents 1

2 Table of abbreviations 2

3 Index of Authorities 3

4 Statement of jurisdiction 4

5 Statement of facts 5

6 Issues raised 9

7 Summary pleadings 10

8 Advance pleadings 12

i. Issue (A) 12
ii. Issue (B) 19
iii. Issue (C) 23
iv. Issue (D) 26
9 Prayer 29

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 TABLE OF ABBREVIATIONS

SECTION §

CODE OF CRIMINAL PROCEDURE CrP.C

CODE OF CIVIL PROCEDURE CPC

PAKISTAN PENAL CODE PPC

CONSTITUTION Cons

SUPREME COURT SC

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 INDEX OF AUTHORITIES

Statutes referred

1. CONSTITUTION OF PAKISTAN
2. CRIMINAL PROCEDURAL CODE
3. CIVIL PROCEDURAL CODE
4. PAKISTAN PENAL CODE
5. PREVENTION OF ELECTRONIC CRIMES ACT
6. PAKISTAN TELECOMMUNICATION ACT

Case laws referred

1. PLD 2010 SC 61
2. PLD 2016 SC 2691
3. PLD 2007 SC 642
4. PLD 2004 SC 1
5. PLD 2004 SC 5831
6. 2004 SCMR 354
7. 2011 SCMR 1688
8. PLD 2005 SC 11
9. PLD 2009 SC 217
10. PLD 2004 SC 955

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 STATEMENT OF JURISDICTION

1. The Hon'ble Supreme Court of Zeus exercises jurisdiction to hear and adjudicate the
present matter under the provisions of Article 184 (3) of the Constitution of Zeus, 1973.

2. The prosecution has approached the Hon'ble Court under the relevant provisions of the
law, which are hereby restated as follows

ARTICLE 184 (3) OF THE CONSTITUTION OF ZEUS

 Sub § (3) Without prejudice to the provisions of Article 199, Supreme Court shall, if it
considers that a question of public importance with reference to the enforcement of any
of the Fundamental Rights conferred by Chapter 1 of Part II is involved, have the power
to make an order of the nature mentioned in the said Article.

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 STATEMENT OF FACTS

I. The Republic of Zeus, situated in the continent of Olympus, was previously a colony of
the Hades Empire. Comprising four provinces—Apollo (40% of the total population), Ares
(32% of the population), Artemis (20% of the population), and Athena (08% of the
population)—the Republic boasts a youthful demographic, with 40% of its people below
the age of 21. After a protracted struggle led by Mr. Augustus, independence was achieved
in 1960. However, internal power struggles among provincial leaders ensued, culminating
in the civil war of 1965. The military subsequently intervened, stabilizing the situation, and
an interim government of technocrats was formed in 1968, entrusted solely with organizing
general elections. Despite reservations, all political parties participated in the elections held
in 1970. In 1973, the Republic adopted a Constitution that reflects legislative competence,
upholds the rule of law, and commits to safeguarding human rights.

II. Over the years, the Republic of Zeus experienced multiple shifts in governance as various
political parties assumed power while enduring persistent political and economic crises.
Each successive government attributed the challenges to the preceding administrations and
external interference. In the 2017 general elections, the Kronos Political Party emerged as
the leading party and formed the government. Preceding this, economic difficulties arose
as the COVID-19 pandemic swept globally. Economic issues intensified due to COVID-
19's impact, resulting in a lockdown and a surge in cases. In response, several countries
imposed sanctions, restricting trade and travel with the Republic of Zeus.

III. The government of the Republic of Zeus confronted a dire food crisis due to its non-
agricultural status. Relying on imports for essential food products from neighboring
countries, non-functional trade routes hampered supplies. Consequently, a scarcity of basic
food items aggravated the crisis, presenting significant challenges for the populace.

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IV. The Republic of Zeus faced an escalating economic and food crisis, causing considerable
hardship for its citizens. Regrettably, the government failed to implement relief measures,
leaving the suffering population without respite. During this period, the Hades Group of
Democrats, a prominent opposition political party, organized nationwide protests,
including processions, rallies, and road blockades, demanding the government's resignation
and immediate general elections.

V. On June 2nd, 2022, a deeply troubling incident occurred involving workers allegedly
associated with the Hades Group of Democrats attacking state buildings and
infrastructures, and destroying state-owned properties. International media covered the
events extensively, reporting on alleged human rights violations. The gravity of the
incident elicited widespread concern and scrutiny from the international community.

VI. Recently, the Ministry of Science & Technology introduced an AI program known as
"Social-BOT," designed to regulate social media interactions and combat the dissemination
of fake news. By scanning specific keywords associated with an anti-state narrative, the AI
aims to monitor and target users actively engaged on social media platforms. Despite
concerns about its implications for privacy and human rights, the government implemented
the "Social-BOT" for mass-surveillance purposes, echoing international initiatives such as
the Pegasus Project and Carnivore Project.

VII. The "Social-BOT" AI wields substantial control over user interactions on major social
media platforms like Facebook, Instagram, and Twitter. It possesses the capability to
remove posts and tweets, and even block users. Additionally, the AI can track real-time
locations through mobile phone access, facilitating government agencies in locating and
apprehending individuals. The AI's testing phase revealed the potential targeting of
innocent users, raising ethical and human rights concerns.

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VIII. Despite the concerns, the government justified the deployment of the "Social-BOT" AI as
essential for countering fake rumors and maintaining public order during protests.
However, the potential misuse and lack of transparency surrounding AI's operation
intensify apprehensions. Balancing security concerns with safeguarding fundamental rights
becomes imperative, necessitating robust oversight mechanisms, adherence to due process,
and transparent AI functioning to protect citizens' rights in the Republic of Zeus.

IX. The Interior Ministry instructed intelligence agencies to apply laws on preventive detention
if individuals, directly or indirectly involved in the June 2nd, 2022 incident, are identified
through surveillance reports generated by the "Social-BOT" AI.

X. Following the June 2nd, 2022 incident, the Interior Ministry directed intelligence agencies
to utilize preventive detention laws against individuals linked directly or indirectly to the
events. The basis for such action stems from surveillance reports generated by the "Social-
BOT" AI, deployed to monitor social media activities and investigate potential connections
to the incident. Concerns arise over possible abuse of preventive detention laws and
reliance solely on AI-generated reports as grounds for apprehension. Upholding legal
safeguards and due process during investigations is crucial to protect citizens' rights in the
aftermath of the incident.

XI. The NGO, Young Fighters for Justice (YFFJ), has filed a Petition invoking Article 184(3)
of the Constitution of 1973 before the Supreme Court of the Republic of Zeus. The Petition
seeks judicial intervention against alleged mass arrests, detentions, and surveillance
activities conducted by the government. Article 184(3) confers upon the Supreme Court
the original jurisdiction to hear matters of public importance involving the enforcement of
fundamental rights. YFFJ contends that the government's actions infringe upon individuals'
rights and liberties on a widespread scale, thereby qualifying as a matter of public
significance. Through the invocation of Article 184(3), YFFJ seeks the Court's intervention
to address and redress the alleged human rights violations arising from the mass arrests,
detentions, and surveillance activities.

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XII. The Hon'ble Supreme Court of the Republic of Zeus has acknowledged the Petition filed
by the Young Fighters for Justice (YFFJ) and issued a notice to the Ministry of Interior,
Government of Zeus, in response to the allegations of mass arrests, detentions, and
surveillance.

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 Issues raised

1. Does the Apex Court of the Republic of Zeus have jurisdiction to hear the matter under Article
184(3) of the Constitution?

2. Whether the mass surveillance through Social-BOT AI carried on by the Government a

legitimate exercise of state authority and by the Constitution and under international obligations?

3. Does the removal of social media posts and blocking accounts by Social-BOT AI amount to an
infringement of freedom of expression and speech, under the Constitution of Republic of Zeus,
1973, and the law?

4. Whether the arrests and detentions made after 2nd June 2023 by the Constitution of the Republic
of Zeus, 1973?

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 Summary pleadings

Issue 1

No, the apex court does not have the jurisdiction to hear the matter under Article 184(3) because
there is no involvement of public importance and enforcement of fundamental rights in the petition.
The court may not exercise its jurisdiction as these two criteria are lacking. The petition filed
against the mass arrest, detention, and surveillance does not fall under the ambit of fundamental
rights and public importance it is somehow a matter of public importance in terms of preserving
national security, as the government's actions were legal and were in accordance to the national
action plan so no breach of human rights is done.

Issue 2

The mass surveillance conducted by the government is lawfully justified, undertaken in pursuit of
safeguarding national security and preserving the welfare of the state. The implementation of
surveillance measures represents a legitimate and necessary action aimed at protecting citizens
from potential threats and ensuring the integrity of the nation's security apparatus. The
government's actions are firmly grounded within the framework of legal provisions and established
protocols, adhering to the due process of law. The primary objective of these surveillance measures
is to uphold the paramount interest of state security and safeguard the rights and well-being of the
populace. Furthermore, the surveillance measures are in full compliance with pertinent
international and domestic laws, attesting to the government's commitment to upholding legal
norms and obligations while addressing critical security imperatives.

Issue 3

Yes such detentions were fully in accordance with the constitution of the Republic of Zeus. As in
that case the protestors blocked tha main road of one major city and later on they blocked the
motorway also due to which many other human rights were violated such as right of movement or
right of trade. Moreover the protesters attacked government and private properties that were
against the integrity of the state. As it was mentioned in article 16 of the constitution of state that

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the protest must be peaceful and without arms, subject to any reasonable restriction imposed by
law in the interest of public order.

Issue 4

Yes such detentions were fully in accordance with the constitution of the Republic of Zeus.As in
that case the protestors blocked tha main road of one major city and later on they blocked the
motorway also due to which many other human rights were violated such as right of movement or
right of trade. Moreover the protesters attacked government and private properties that were
against the integrity of the state. As it was mentioned in article 16 of the constitution of state that
the protest must be peaceful and without arms, subject to any reasonable restriction imposed by
law in the interest of public order.

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 Advance pleadings

Issue 1
1. Definition of “JURISDICTION”
Jurisdiction is a legal principle that determines the authority of a court to hear and decide particular
cases. In this context, Article 184(3) confers special or original jurisdiction upon the Supreme
Court to take up cases that meet the criteria of public importance and the enforcement of
fundamental rights.
While the term "jurisdiction" itself may not be mentioned in this specific provision, the concept
is implicit in the phrase "the Supreme Court shall have the power" to address matters of public
importance involving the enforcement of fundamental rights.
2. Conditions to have the jurisdiction to hear the matter
Supreme Court to have the jurisdiction to hear the matter under Article 184 (3), the matter should
meet the following criteria.
I. Public Importance
II. Enforcement of fundamental rights
The term “public importance” refers to something to be shared, participated in, or enjoyed by the
public at large and is not limited to a specific individual or a particular community.
3. Explanation
In the instant matter, it is respectfully submitted that the court lacks the requisite jurisdiction to
entertain the present case under the ambit of Article 184(3) of the Constitution of ZEUS. The crux
of the contention lies in the absence of both public importance and the enforcement of fundamental
rights, prerequisites mandated by the aforementioned constitutional provision. The subject matter
under consideration fails to pertain to issues of pronounced public concern or significance, thereby
precluding the application of the court's exceptional jurisdiction as envisaged by Article 184(3).
Furthermore, there is no evident transgression or infringement of the fundamental rights enshrined
within Chapter I of Part II of the Constitution of ZEUS. Consequently, it is urged that the present
petition does not fall within the purview of Article 184(3).

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  Relevant case laws
 PLD 2012 SC 2921
To qualify the test of "question of public importance the issue involved must be long and should
concern the public at large the State or the nation alleged violation of the Fundamental Rights of
an individual how so large it might be, has no concern and effect on the public then it cannot be
termed a "question of public importance

 PLD 2010 SC 61

The essential element for the exercise of jurisdiction by the Supreme Court under Article 184 c is
that it must involve the question of public importance concerning the enforcement of fundamental
rights and if the matter relating to fundamental rights is not publicly important then the court may
refuse to entertain the petition and exercise the jurisdiction.

 [PLD 2016 SC 2691]

Supreme Court, while invoking its jurisdiction under Article 184(3) of the Constitution is always
very careful both ways i.e. efforts are made to exercise its jurisdiction wherever it finds a question
of law of public importance concerning the enforcement of any of the Fundamental Rights under
the Constitution, but the Court also remained careful not to exercise such jurisdiction where it finds
that either the question involved is not of public importance or it has no reference to the
enforcement of any of the Fundamental Rights.

4. Petition filed against mass arrest, detention, and surveillance, not of public
importance.

In determining whether a case involves a question of public importance, it is essential to assess the
impact of the issues raised. If the decision on the issues affects solely the rights of an individual or
a specific group of individuals, without any broader implications for the rights and liberties of the
general public, the matter cannot be considered as having public importance. For an issue to attain
the character of public importance, its resolution must significantly affect the rights and liberties
of the larger population, the nation, the State, or the community as a whole. The term "public"
inherently denotes ownership or belonging to people at large. Thus, if a dispute pertains only to
the interests of a particular group, without any relevance to the welfare of the entire community or
the broader public, it cannot be regarded as a case of public importance.

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  Relevant case laws
 [PLD 2007 SC 642; PLD 2004 SC 1; PLD 2004 SC 5831]
If a controversy is raised in which only a particular group of people is interested and the body of
the people as a whole or the entire community has no interest, it cannot be treated as a case of
public importance.

 [2004 SCMR 354]

Jurisdiction of the Supreme Court under Article 184(3) cannot be invoked for redressal of a
grievance that affects only the rights of an individual and not the public at large.

 [2011 SCMR 1688]

184(3) of the Constitution can be exercised only where a question of public importance concerning
the enforcement of any of the fundamental rights is involved, meaning thereby that the question of
public importance is the sine qua non for the exercise of jurisdiction under Article 184(3) of the
Constitution.

 [PLD 2005 SC 11]

To acquire public importance, the case must raise a question, which is of interest to or affects the
whole body of people or an entire community.

 [PLD 2009 SC 217, PLD 2004 SC 955]

It cannot be said that a case brought by a large number of people should always be considered a
case of "public importance" because a large body of persons is interested in the case.
5. Direct approach to the SC is against the Law.
According to § 37 of PECA 2016.
Subsection 1
(1) The Authority shall have the power to remove or block or issue directions for removal or
blocking of access to information through any information system if it considers it necessary in
the interest of the glory of Islam or the integrity, security, or defense of Pakistan or any part thereof,
public order, decency or morality, or about contempt of court or commission of or incitement to
an offense under this Act.

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(4) Any person aggrieved from any order passed by the Authority under sub-section (1), may file
an application with the Authority for review of the order within thirty days from the date of passing
of the order.

(5) An appeal against the decision of the Authority in review shall lie before the High Court within
thirty days of the order of the Authority in review.

6. "Establishing Compliance: The Legality of Mass Arrests and Surveillance in the

Republic of Zeus as Not Violating Fundamental Rights or Constituting Public
Importance"
In the Republic of Zeus, the arrests of more than 500 protestors who engaged in organizing rallies,
blocking major roads in a significant city, and demanding the government's resignation warrant
examination to determine whether these actions comply with the law and whether they constitute
a violation of fundamental rights or involve matters of public importance.
The government of the Republic of Zeus holds the lawful authority and obligation to maintain
public order, safeguard public safety, and protect critical infrastructures. The protestors' conduct,
causing road blockades and disruptions, potentially posed risks to public safety and societal
functioning. Consequently, the government's decision to arrest the protestors can be perceived as
a legitimate measure taken to restore order and protect the interests of the general public.

While the right to peaceful protest is a fundamental human right, it is not absolute. If proven to
cause significant disruptions to public life and endanger public safety, the protestors' actions have
surpassed the boundaries of peaceful protest. Consequently, the government is entrusted with the
duty to strike a balance between upholding the right to protest and ensuring the overall welfare of
society.
Moreover, the number of arrested protestors, exceeding 500, does not automatically bestow the
case with public importance. The arrests seem to directly stem from the protestors' actions and
demands, rather than being related to issues of broader national significance. Thus, the absence of
wider implications may limit the case's classification as a matter of public importance, as per
Article 184(3) of the Constitution.
The mass surveillance was undertaken in response to the incident on 2nd June 2022, wherein members
of the Hades Group of Democrats attacked state buildings and infrastructures, and set state-owned

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properties on fire, presenting questions concerning human rights violations and warrants scrutiny
regarding its compliance with legal and constitutional provisions.
The severity of the incident, which resulted in damages to state properties and the alleged violation
of human rights, attracted international media attention. In light of such events, the government of
the Republic of Zeus invoked the necessity of surveillance to identify and track individuals
responsible for the attacks and those engaged in spreading anti-state narratives and fake news.
The pivotal concern in this matter is to ensure that the mass surveillance conducted was by the law
and did not encroach upon fundamental rights guaranteed under the Constitution of the Republic
of Zeus. While the government's intentions to apprehend and prevent further incidents may be
well-founded, it is essential to strike a delicate balance between security measures and
safeguarding individual liberties.
The implementation of mass surveillance requires stringent adherence to legal frameworks,
ensuring that it does not become an instrument for unwarranted intrusions into citizens' privacy
and freedom of expression. As the government sought to identify individuals involved in criminal
acts and spreading disinformation, it must demonstrate that the surveillance was carried out
through appropriate legal channels, with proper authorization and judicial oversight.

Furthermore, the accuracy and reliability of the surveillance technology employed, such as the
"Social-BOT" AI, demand critical examination. The potential targeting of innocent individuals
due to the complexity of algorithms and keywords raises concerns about inadvertent infringements
on the rights of law-abiding citizens.
In conclusion, while the rationale behind the mass surveillance was to address the security
challenges arising from the 2nd June 2022 incident and curb the dissemination of anti-state
narratives and fake news, it is imperative to ascertain that the surveillance activities were
conducted within the confines of the law, respecting fundamental rights and privacy protections.
Proper judicial oversight, transparency, and adherence to due process must be upheld to ensure the
legality and legitimacy of the surveillance measures implemented in the Republic of Zeus.
7. The legal aspect of the unlawful acts.
In Pakistan, the punishment for engaging in an unlawful or violent protest can vary depending on
the specific circumstances and applicable laws. The relevant laws that address protests and their

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consequences include the Pakistan Penal Code (PPC) and the Code of Criminal Procedure (CrP.C).
Here are some provisions that may be relevant:

 (§) 141 of the Pakistan Penal Code (PPC) deals with "Unlawful Assembly." According to
this (§), an assembly of five or more persons is designated as unlawful if the common
object of the assembly is to commit any illegal act or any act that causes a disturbance of
public peace. Those found guilty of being part of an unlawful assembly can be punished
with imprisonment for up to six months, a fine, or both.
 (§) 142 of the PPC deals with "Being a Member of an Unlawful Assembly." This (§) states
that anyone who, at the time of being arrested, is a member of an unlawful assembly, can
be punished with imprisonment for up to six months, a fine, or both.
 (§) 148 of the PPC pertains to "Rioting, armed with a deadly weapon." This (§) states that
if a riot is committed by an assembly of five or more persons armed with deadly weapons,
the participants can be punished with imprisonment for up to three years, a fine, or both.
 (§) 149 of the PPC addresses "Every member of unlawful assembly guilty of the offense
committed in prosecution of the common object." According to this (§), every member of
an unlawful assembly can be held criminally liable for the offenses committed by any
member of the assembly in furtherance of the common object. They can be punished in the
same manner as if they had committed the offense themselves.
 In addition to the PPC, the Code of Criminal Procedure (CrP.C) contains provisions related
to the maintenance of public order during protests. For instance, (§) 144 of the CrP.C
empowers the local government or magistrate to issue an order to prevent the assembly of
people and maintain public tranquility in specific areas. Violating such orders can lead to
arrest and punishment.
 Under the provisions of the Code of Criminal Procedure (CrP.C) in Pakistan, arrests
without a warrant can be made for cognizable offenses. A cognizable offense is one for
which a police officer has the authority to arrest a person without obtaining a warrant from
the court.
Section 54 of the CrP.C empowers a police officer to make such an arrest if there exists
reasonable suspicion that the individual has committed the offense and there are grounds

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to believe that the arrest is necessary to prevent the person from committing further
offenses, obstructing the course of justice, or evading the jurisdiction of the court.

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 Issue 2

1. Definition

Surveillance, within the confines of legal definitions, entails a methodical and deliberate
monitoring process carried out by governmental authorities or duly authorized entities. This
process encompasses the systematic collection, observation, recording, and analysis of information
about individuals, groups, or activities. The overarching objectives of surveillance encompass the
prevention and investigation of criminal activities, ensuring the preservation of national security,
and safeguarding public interests. The gathering of information through surveillance mechanisms
serves as a critical tool in addressing security concerns and preserving the welfare of the state.
However, it is essential to underscore that such surveillance activities must be conducted in strict
accordance with the law, adhering to constitutional safeguards and principles of due process,
thereby safeguarding the right to privacy and upholding fundamental human rights.

2. Acts that trigger the agencies for retaliation

The actions of the Hades group of democrats, involving the blocking of major roads and the
subsequent attack on state buildings, infrastructures, and state-owned properties, constitute serious
illegal acts under the legal framework of the Republic of Zeus. These actions may be deemed as
disruptions to public order and acts of violence, which violate the principles of law and order
enshrined in the nation's legal system. The blocking of major roads hinders the right to freedom of
movement of other citizens and interferes with the normal functioning of public life. Such conduct,
beyond the bounds of peaceful assembly, may be considered unlawful and disruptive to public
peace and tranquility.

Additionally, the attack on state buildings and properties not only undermines the stability and
security of the state but also presents a threat to public safety and welfare. These actions may be
seen as acts of vandalism, destruction of public property, and an affront to the rule of law. Any
violence directed towards state institutions can be seen as an illegal attempt to destabilize the
government and impede the functioning of vital state mechanisms.

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The actions of the Hades group of democrats are likely to violate various provisions of the law,
including those related to public order, criminal offenses, and protection of state property. Such
acts may attract legal consequences, leading to charges and prosecutions by the laws of the
Republic of Zeus. The nation's legal system aims to uphold the principles of justice, and those
Individuals who engage in illegal activities will be subject to appropriate legal proceedings.

3. Reason for the mass arrest

In light of the events that unfolded on 2nd June, the mass surveillance undertaken by the
government stands as a resolute and authoritative measure to ensure paramount national security
and unwavering protection of the state from potential threats. The audacious attack on state
buildings, infrastructures, and state-owned properties by the Hades group of democrats invoked
unwarranted attention from the international media and drew grave concerns regarding potential
human rights violations. Responding with utmost gravity to this substantial breach of security and
the alarming risks posed to public safety and the state's stability, the government decisively
deployed comprehensive surveillance mechanisms to meticulously track and monitor individuals
associated with the Hades group and those actively involved in the disruptive unrest.

The mass surveillance exudes the unmistakable aura of a legitimate exercise of unwavering state
authority, unequivocally aimed at safeguarding the sacred integrity of the Republic of Zeus and its
cherished citizens from malevolent forces of violence and unrestrained anarchy. The government's
actions stemmed from an unwavering resolve to prevent any further acts of violence, to identify
and apprehend the malefactors responsible for the brazen attack, and to fortify the bastions of state
institutions and the venerated rule of law.

Moreover, the targeted surveillance efforts were executed with unfaltering precision, focusing on
individuals who deliberately propagated seditious anti-state narratives and propagated maliciously
contrived falsehoods, thereby catalyzing the unrest and spurring the fiery embers of chaos. This
unyielding resolve to surveil such activities was instrumental in curbing the dissemination of
deceptive misinformation, which, if unchecked, had the potential to incite further public disorder
and plunge the nation into a state of catastrophic tumult.

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It must be emphatically asserted that the mass surveillance meticulously adhered to the supremacy
of the law, as enshrined in the hallowed corridors of the constitution, and diligently safeguarded
the sacrosanct principles of human rights. The government demonstrated unwavering dedication
to maintaining a delicate balance, adeptly harmonizing the imperatives of national security with
the preservation of citizens' inviolable rights to privacy and unrestrained freedom of expression.
The surveillance activities were conducted with an unwavering commitment to unwavering
transparency, stringent accountability, and an unflinching reverence for justice to ensure that
innocent individuals were held sacrosanct and protected from the slightest infringement of their
rightful liberties.

In resolute conclusion, the mass surveillance undertaken by the government in response to the
momentous events of 2nd June stands as an unwaveringly authoritative and essential action, an
indomitable bulwark meticulously constructed to shield the sovereignty and honor of the Republic
of Zeus. The government's unwavering determination, underscored by the indomitable spirit of
unyielding resolve, resonates with a sacred mission to uphold the unassailable fabric of public
order, safeguard the time-honored sanctity of state institutions, and shield the nation from the
ominous shadows of potential threats, while resolutely upholding the pillars of constitutional and
human rights principles.

4. Legalization of mass-surveillance
 Pakistan Telecommunication (Re-organization) Act, 1996
§ 54. National Security.—(1) Notwithstanding anything contained in any law for the time being
in force, in the interest of national security or the apprehension of any offense, the Federal
Government may authorize any person or persons to intercept calls and messages or to trace calls
through any telecommunication system.

 Prevention of Electronic Crimes Act, 2016

29. Establishment of an investigation agency.

(1) The Federal Government may establish or designate a law enforcement agency as the
investigation agency for the investigation of offenses under this Act.

(4) Notwithstanding provisions of any other law, the Federal government shall make rules for
appointment and promotion in the investigation agency including the undertaking of space-led

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courses in digital forensics, information technology, computer science, and other related matters
for the training of the officers and staff of the investigation agency.

§ 30. Power to investigate. Only an authorized officer of the investigation agency shall have the
powers to investigate an offense under this Act: Provided that the Federal Government or the
Provincial Government may, as the case may be, constitute one or more joint investigation teams
comprising of an authorized officer of the investigation agency and any other law enforcement
agency for investigation of an offense under this Act and any other law for the time being in force.

§ 37. Unlawful online content.

(1) The Authority shall have the power to remove or block or issue directions for removal or
blocking of access to information through any information system if it considers it necessary in
the interest of the glory of Islam or the integrity, security, or defense of Pakistan or any part thereof,
public order, decency or morality, or about contempt of court or commission of or incitement to
an offense under this Act.

(2) The Authority shall, with the approval of the Federal Government, prescribe rules providing
for, among other matters, safeguards, transparent processes, and effective oversight mechanisms
for the exercise of powers under sub-section (1).

(3) Until such rules are prescribed under sub-section (2), the Authority shall exercise its powers
under this Act or any other law for the time being in force by the directions issued by the Federal
Government not inconsistent with the provisions of this Act.

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 Issue 3

 Definition:

According to the constitution of Zeus the definition of freedom of expression and speech. Article
19 of this Declaration relates to press freedom: 'Everyone has the right to freedom of opinion and
expression; this right includes freedom to hold opinions without interference and to seek, receive
and impart information and ideas through any media and regardless of frontiers.

 Statement:

No, the removal of social media posts and blocking accounts by social-BOT AI is not an
infringement of freedom of expression and speech because the government did this for targeting
people who spread false news and to keep surveillance just like pegasus projects carried out by
other states. Arguments-related issue:

(1) According to article 19 the freedom of speech and expression are not absolute rights given
to civilians by the constitution of the state. The government must have the right to apply
restrictions on freedom of speech and expression when it goes against the integrity of
islam,integrity of state, security or defense of state, morality or contempt of court. Hence
in that case the people use their right against the integrity of the state by spreading wrong
news and hate speech on social media that also affect the security of the state, so that is
why the government applies restrictions on them by removing their post and blocking their
accounts on social media by using SOCIAL-BOT.

(2004 SCMR 164=2004 PLC(C.S)130) Freedom speech and expression and press are
essential requirements of democracy and democracy cannot survive without such freedom.
Such right is not absolute, but reasonable restrictions can be imposed upon the same on
reasonable grounds. Hence according to article 19 the government of Zeus did not infringe the
freedom of speech and expression by any illegal way because the constitution of Zeus give
authority to Government to apply restrictions on it when it was used against the integrity and
security of the state.

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  (2) The constitution of the state provides the freedom of press to all the news press of the
country on all kinds of platforms in article 19 (Freedom of speech and expression) and
19A(Right to information) but this freedom is also not absolute’. The government of the
state also has the right to apply restrictions on them if they spread news that is against the
integrity of the country, Public interest and the glory of islam. As some people within or
outside the country spread wrong news to defame people or to defame the state of Zeus in
desire to make things more critical for the government by forming anarchy among the
civilians of Zeus by spreading wrong news. That why the government of Zeus applied
restrictions on freedom of press and this authority guaranteed by the constitution of the
Zeus to the government.

(PLD 2002 SC 514) Press is not free to publish anything it desires, but its freedom is subjected
to such reasonable as may be legitimately imposed under law in the public interest and glory
of islam. Press must take due care and caution before publishing any material in the press,
Verify its correctness from the concerned quarters and keep themselves within the bounds and
ambit of the provisions of Art. !9 of the constitution.

(2) NO doubt that social media provides a platform to citizens to express their opinion,
demand, feelings etc, and the constitution of every democratic state assures the civilians
the right to express their opinion on social media but if the civilians use this right against
the law or constitution than government have authority to apply restriction on it. As in that
case some people violate the Law of Zeus by spreading hate speeches and fake news that
is against the public order with the intent to create anarchy among the civilians of Zeus. To
prevent these cyber crimes the government of Zeus uses SOCIAL_BOT AI that block the
account of such persons on social media and also track the location through access of
mobile phones to arrest them and apply law on them.

According to section 37 of Pecca Act 2016 The authority shall have the power to remove or block
or issue directions for removal or blocking of access to an information through any information
system if it considers it necessary in the interest of the glory of islam or the integrity,security or
defense of Zeus or any part thereof, public order , decent or morality or in relation to contempt of
court or commission of or incitement to an offense under this Act. 4)The Imperative Deployment

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of Social Bot Technology in a State of Anarchy: A Necessity for Preserving Order and Mitigating
Chaos.

 Reasoning In light of the prevailing state of anarchy within the country, the imperative
deployment of social bot technology by the government becomes a compelling argument
to avert potential chaos. This legal discourse contends that the exigency of the situation
necessitated the immediate utilization of social bot AI, as delaying its implementation
could have exacerbated the already precarious conditions prevailing in the nation.
 II. Contextual Background A. The Country in Turmoil The nation faced an unprecedented
state of anarchy characterized by widespread civil unrest, riots, and public disorder. The
fabric of law and order had been significantly compromised, jeopardizing the safety and
security of citizens and infrastructure. The escalating unrest posed a serious threat to the
country's stability, economy, and social cohesion. B. The Incompleteness of Social Bot AI
Development While the government acknowledged the potential benefits of deploying
Social bot AI, it was confronted with the reality that the technology was not yet fully
developed. Despite considerable progress, the AI's development remained ongoing, and
achieving perfection was uncertain due to the complexity of the task.
 III. Argument A. Preserving Order and Safety In the face of rampant anarchy, maintaining
public order and ensuring the safety of citizens are paramount. The deployment of Social
bot AI, even in its incomplete state, provided an additional tool for authorities to address
the unfolding crisis. The technology could help augment law enforcement efforts by
monitoring social media platforms, detecting disinformation, and identifying potential
sources of violence.
 B. Mitigating Potential Chaos Had the government opted to wait for the AI's complete
development, the nation could have spiraled into even greater chaos. During times of
anarchy, swift action is necessary to curtail the spread of violence and lawlessness. The
deployment of social bot technology, even in its nascent form, offered the possibility of
curbing the dissemination of inflammatory content and misinformation, thereby potentially
mitigating further unrest.
 C. Balancing Civil Liberties While it is essential to safeguard civil liberties, including
freedom of speech, the state's primary responsibility lies in preserving public safety and

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security. The government was cognizant of the delicate balance between deploying AI
technology and ensuring the protection of constitutional rights. Hence, measures were put
in place to ensure transparency, accountability, and oversight in the implementation of
social bot AI. IV. Conclusion In conclusion, the imperative deployment of social bot
technology in the midst of anarchy was a crucial measure taken by the government to
safeguard public order, mitigate potential chaos, and protect the well-being of citizens.
Acknowledging the incompleteness of the AI's development, the decision was not taken
lightly, but the urgency of the situation warranted swift action. The government's aim was
to strike a balance between ensuring civil liberties and employing technological
interventions to address the crisis effectively. As the nation seeks to rebuild and reconcile,
it is essential to learn from this experience and develop robust AI technologies that align
with legal and ethical standards, while remaining prepared to address future challenges to
national security and stability

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 Issue 4

Definition:

Arrest: Arrest refers to the act of taking an individual into custody, usually by law enforcement
officials, on the grounds of suspicion of having committed a crime or for investigation purposes.
In Pakistan, the law relating to arrest is primarily governed by the Code of Criminal Procedure
(CrPC) of 1898.

Detention: Detention refers to the act of holding someone in custody, typically by the state or its
authorities, for a prolonged period. Detention can be either as a preventive measure pending
investigation or as a punishment following a lawful conviction. The Constitution of Pakistan also
addresses the issue of detention and safeguards individual rights.

Statement:

Yes, the detention and arrest that was made after 2 june of 2022 were totally according to the
constitution of Republic of Zeus because the protestors of hades group of democrats blocked tha
main road of one major city and later on they blocked the motorway also due to which other people
right were Violated. Moreover the article 10 clause 4 (preventive detention) applies on protest
because they do act against the integrity and security of the state. Argument related issue:

1 The constitution of zeus provides the right of protest to civilians against the government but in
certain circumstances the constitution also gives authority to the government of state to apply some
restriction on freedom of expression and speech. As in that case the state of zeus was already
suffering from very bad economic crises and at that time the protest of hades group of Democrats
block the main road of one major city and later on they also block motorway due to which the
transport of the state of zeus disturb very badly ant the situation become more critical for
government , so in that case the government of Zeus made mass arrestation to handle such situation
to regulate the transport system of the country. As according to

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(AIR 1969 SC 502) The citizen does not confer any right to hold meetings anywhere they please
e.g on private or government property.

Benazir Bhutto v. Federation of Pakistan (PLD 1988 SC 416): In this case, the Supreme Court
of Pakistan held that the right to peaceful protest is a fundamental right protected under Article 16
of the Constitution. The court emphasized the importance of balancing the right to protest with
public order, and it ruled that restrictions on protests must be reasonable, necessary, and
proportionate.

2 The government arrested the protesters who were involved in the incident of 02 June 2022. The
citizen must have the right to protest against the bad policies of the government but if this protest
violates the right of others then in that case it becomes the responsibility of the government to
apply some restriction on it. As in that case the workers of hades group of democrats found to be
involved in the incident in which they attack on government and private buildings and the workers
of hades group of democrats also block the roads such activity was against to the integrity of state
that why the government apply restriction and proceeded them against in accordance with the law
and held accountable.

2019 PLD 318 SUPREME-COURT In that case it was mentioned that the right of assembly and
protest was circumscribed only to the extent that it infringed on the fundamental right of others,
including their right to free movement and to hold and enjoy property. Protestors who obstructed
people's right to use roads and damage or destroy property must be proceeded against in
accordance with the law and held accountable.

3 The government of Zeus uses SOCIAL-BOT AI to prevent the social media users from spreading
fake news by removing post and blocking account of social media users who spreading fake news
on social media about Zeus with intention to degrade it reputation in front of other countries just
like the Pegasus or Carnivore project carried out by other states internationally. Moreover the
SOCIAL-BOT AI tracks the location of persons who were involved in the incident of 02 june
2022. Actually the government of Zeus have authority to remove post and block account on social
media of those people who spread hate speech on social media with intention to degrade the
reputation of state in front of other states and the government also have right to track the location
of people who violate the law by doing any illegal act like the people who were involved in the
incident of 02 june 2022. According to section 37 of Pecca Act 2016 The authority shall have the

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power to remove or block or issue directions for removal or blocking of access to an information
through any information system if it considers it necessary in the interest of the glory of islam or
the integrity,security or defense of Zeus or any part thereof, public order , decent or morality or in
relation to contempt of court or commission of or incitement to an offense under this Act.

4 In some situations, law enforcement officers may have the authority to make arrests without a
warrant under certain circumstances. Common examples include: In-flagrante delicto: If law
enforcement witnesses someone committing a crime in progress, they may be able to make an
arrest without a warrant. Probable cause: When police have sufficient evidence or a reasonable
belief that a person has committed a crime, they may make an arrest without a warrant. Hot pursuit:
If a suspect is fleeing from the scene of a crime, law enforcement may be allowed to make an arrest
without a warrant. Emergency situations: In cases where immediate action is required to prevent
harm to others or protect public safety, police may be able to make arrests without a warrant. under
Section 157 of the Code of Criminal Procedure (Cr.P.C) The Government of Zeus has authority
to arrest the people without warrant who were involved in the incident of 2 june 2022. The police
can arrest a person without a warrant if they have reason to suspect that the person has committed
a cognizable offense. Hence the people who were involved in the incident of 2 june 2022 they
committed cognizable offense by attacking private and government properties and by setting them
on fire.

5 The government of Zeus has authority to arrest or detain the protestor without informing them
charges against them because the constitution of Zeus under article 10 clause 4 allow the
government to apply preventive detention on person who commit any act against the integrity,
security, defense of Zeus or any part of thereof, or external affair of Zeus, or public order.

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 Plea

1. In light of the facts stated, arguments advanced and authorities cited, the Respondents
respectfully submit before the Honorable Court that it should not exercise its jurisdiction
to stop the government to exercise mass surveillance because it is done for the sake of the
national security and integrity of the state.
2. The Prosecution also submits that the removal of social media posts was according to the law
and the arrests done subsequent to 2nd June were legal and the honorable court should allow
the government to exercise the punishment that should be awarded cording to the law.

RESPECTFULLY SUBMITTED,

COUNSEL(s) FOR RESPONDENT

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