CONCOURS, 2024

Participation Code- C65

DR. RAM MANOHAR LOHIYA NATIONAL LAW UNIVERSITY, LUCKNOW

CONCOURS, 2024
Before,
THE HON’BLE SUPREME COURT OF CHEEKU REPUBLIC

WRIT PETITION UNDER ARTICLE 32 OF THE CONSTITUTION OF CHEEKU

REPUBLIC

WRIT PETITION NO. 1/2024

XX….……………………..……………………………………………………APPELLANT
V
CHEEKU REPUBLIC………………………………………………………RESPONDENT
CLUBBED WITH

WRIT PETITION UNDER ARTICLE 32 OF THE CONSTITUTION OF CHEEKU

REPUBLIC

WRIT PETION NO. 2/2024

MR. DUMBPUN.TRIVEDI…..………………………………………………PETITIONER
V
CHEEKU REPUBLIC AND OTHERS…………………………………..RESPONDENT
CLUBBED WITH

APPEAL UNDER ARTICLE 134 OF THE CONSTITUTION OF CHEEKU

REPUBLIC

APPEAL NO 10/2023
MR. DEDBUL RANJAN…..………………………………………………PETITIONER
V
CHEEKU REPUBLIC.……………..…………………………………..RESPONDENT

ON SUBMISSION TO THE SUPREME COURT OF CHEEKU REPUBLIC

WRITTEN SUBMISSION ON BEHALF OF THE RESPONDENT

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TABLE OF CONTENT

INDEX OF AUTHORITIES......................................................................................................
LIST OF ABBREVIATIONS ...................................................................................................
STATEMENT OF JURISDICTION..........................................................................................
STATEMENT OF FACTS ........................................................................................................
ISSUES RAISED .....................................................................................................................
SUMMARY OF ARGUMENTS .............................................................................................
A. MR. ARYAN M.’S STATEMENTS MADE IN PARLIAMENT WERE NOT
VIOLATIVE OF THE RIGHT TO DIGNITY OF THE X UNDER ARTICLE 21 OF
THE CONSTITUTION……………………………………………………………….
B. PRIVILEGES AND IMMUNITIES OF THE HOUSE OF THE LEGISLATURES
ENSHRINED UNDER ARTICLE 105 OF THE CONSTITUTION CAN OVERRIDE
THE FREEDOM OF PRESS PROVIDED UNDER ARTICLE 19(1)(A) OF THE
CONSTITUTION OF CHEEKU REPUBLIC………………………………………….
C. ADDITIONAL EVIDENCE CAN NOT BE ADMISSIBLE BEFORE THE HIGH
COURT WHILE DEALING WITH THE ISSUE OF DISCHARGE………………….
D. DISCHARGE SHOULD NOT GIVEN TO MR. DEDBULL RANJAN IN THE
IMMEDIATE CASE……………………………………………………………………
ARGUMENTS ADVANCED .................................................................................................
A. MR. ARYAN M.’S STATEMENTS MADE IN PARLIAMENT WERE NOT VIOLATIVE
OF THE RIGHT TO DIGNITY OF THE X UNDER ARTICLE 21 OF THE
CONSTITUTION……………………………………………………………………………….
A1. MR. ARYAN M.'S STATEMENTS WERE MADE WITHIN THE PARLIAMENTARY
SETTING DURING A DEBATE ON AN IMPORTANT ISSUE, AND AS SUCH, THEY
FALL UNDER THE PROTECTION OF PARLIAMENTARY PRIVILEGE………………
A2. MR. ARYAN M.'S REMARKS, WHILE POSSIBLY CONTROVERSIAL, WERE NOT
DIRECTED AT UNDERMINING THE DIGNITY OF THE VICTIM BUT RATHER
FOCUSED ON BROADER POLICY ISSUES RELATED TO LAW ENFORCEMENT……
A3. MR. ARYAN M.'S STATEMENTS IN PARLIAMENT ARE PROTECTED BY THE
PRINCIPLE OF SEPARATION OF POWERS, AND ANY ATTEMPT TO PENALIZE HIM
FOR EXPRESSING HIS VIEWS WOULD INFRINGE UPON THE AUTONOMY OF THE
LEGISLATIVE BRANCH……………………………………………………………….

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A4. FREEDOM OF SPEECH AND EXPRESSION IS GRANTED UNDER ARTICLE 19 OF

THE CHEEKU REPUBLIC, AND ARTICLE 19 CAN’T BE UNDERMINED BY THE
RIGHT TO DIGNITY UNDER ARTICLE 21…………………………………………………
B. PRIVILEGES AND IMMUNITIES OF THE HOUSE OF THE LEGISLATURES
ENSHRINED UNDER ARTICLE 105 OF THE CONSTITUTION CAN OVERRIDE THE
FREEDOM OF PRESS PROVIDED UNDER ARTICLE 19(1)(A) OF THE CONSTITUTION
OF THE CHEEKU REPUBLIC……………………………………………
B1. FREEDOM PRESS UNDER ARTICLE 19(1)(A) IS SUBJECT TO ARTICLE 105,
WHICH TALKS ABOUT THE PRIVILEGES OF PARLIAMENT…………………………..
B2. MR. DUMBPUN TRIVEDI, THE FOUNDING EDITOR OF DUMBPUN PRESS,
UNDERMINED THE DIGNITY OF THE LEGISLATURE BY HIS CONTENT……………
C. ADDITIONAL EVIDENCE CAN NOT BE ADMISSIBLE BEFORE THE HIGH COURT
WHILE DEALING WITH THE ISSUE OF DISCHARGE………………………….
C1. HIGH COURTS ARE NOT THE TRIAL COURT THE HIGH COURT SHOULD NOT
ALLOW TO ADMISSION OF ADDITIONAL EVIDENCE WHILE DEALING WITH
DISCHARGE…………………………………………………………………………………..
C2. HIGH COURT, WHILE DEALING WITH THE ISSUE OF DISCHARGE, SHOULD
REFRAIN FROM ADMITTING ADDITIONAL EVIDENCE AND THIS APPROACH
ENSURES A FAIR AND EXPEDITIOUS DETERMINATION OF THE ACCUSED'S
CULPABILITY AND ALSO SAVES JUDICIARY RESOURCES WHILE UPHOLDING
THE PRINCIPLES OF LEGAL CONSISTENCY AND FINALITY………………………….
C3. THERE IS LIMITED SCOPE OF THE HIGH COURT'S REVIEW DURING THE
DISCHARGE STAGE………………………………………………………………………….
D. DISCHARGE SHOULD NOT BE GIVEN TO MR. DEDBULL RANJAN IN THE
IMMEDIATE CASE……………………………………………………………………………
D1. WHILE GIVING DISCHARGE, THE COURT SHOULD CONSIDER NOT ONLY
EVIDENCE BUT ALSO THE ENTIRE MATERIAL RECORD AND MENS REA OF THE
ACCUSED……………………………………………………………………………………..
D2. MR. DEDBULL RANJAN CAUSED GRIVIOUS HARM TO MR. GAURAV SAMAI
RANA, EYEWITNESS TESTIMONY MEDICAL EVIDENCE SUPPORT THIS………….

PRAYER…………………………………………………………………………………….

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INDEX OF AUTHORITIES

PAGE NO
1. Article 105 of the Indian Constitution. 13
2. P V Narasimha Rao v. State, 1998 4 SCC 626. 13
3. Article 50 of the Indian Constitution. 15
4. Kaushal Kishore v. State of Uttar Pradesh, 2023 4 SCC 1. 16
5. Article 19(1)(a) of the Indian Constitution. 17
6. M.S.M Sharma vs. Krishna Sinha, AIR 1959 SC 395. 17
7. Parliamentary Proceedings (Protection of Publication) Act, 1977. 17
8. Article 105(3) of the Constitution of India. 17
9. Article 194(3) of the Constitution of India. 17
10. S.P. Sampathkumar v. Union of India 1987 AIR SC 386. 18
11. Surendra Singh v. Indian Express, AIR 1975 SC 1030. 20
12. Raj Narain v. Durga Das Bhargava, AIR 1970 SC 1469 20
13. Tamil Nadu vs. N. Suresh Rajan and Others, (2014) 11 SCC 709. 21
14. Chavi Lal and Others vs. State of U.P. and Another, Application u/s 482 No. 2180 of
2018. 21
15. Somnath Thapa vs. State of Maharashtra, 1996 AIR 1744. 25
16. Section 227 of the CRPC. 25
17. Section 239 of the CRPC. 25

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LIST OF ABBREVIATIONS

SC SUPREME COURT
HC HIGH COURT
X SEXUAL ASSAULT VICTIM
CNS CHEEKU NYAYA SANHITA
BBP BASU BELLI BHAAT PARTY
CRPC CODE OF CRIMINAL PROCEDURE
ANR ANOTHER
ORS OTHER
SCC SUPREME COURT CASES
Hon’ble HONORABLE
SEC SECTION
AIR ALL INDIA REPORTER
SCR SUPREME COURT REPORTS

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STATEMENT OF JURISDICTION

Writ Petition by the Sexual Assault Victim:

This Hon'ble Court possesses jurisdiction to entertain and adjudicate upon the Writ Petition
filed by X seeking redress for the alleged violation of her rights under Article 21 of the
Constitution.

The Supreme Court, being the apex judicial authority, is vested with the jurisdiction to enforce
fundamental rights guaranteed under the Constitution.

Article 32 of the Constitution confers upon this Hon'ble Court the power to entertain writ
petitions to enforce fundamental rights.

Writ Petition by DumbPun Press:

The Writ Petition filed by DumbPun Press invokes the jurisdiction of this Hon'ble Court to
protect and uphold the fundamental right to freedom of the press under Article 19(1)(a) of the
Constitution.

Article 32 empowers the Supreme Court to entertain writ petitions for the protection of
fundamental rights, including freedom of the press.

The Parliamentary Proceedings (Protection of Publication) Act, 1977 is a statute that is

relevant to the issues raised in the petition, and the Supreme Court has jurisdiction to interpret
and apply the said legislation.

Criminal Appeal by Mr. DedBull Ranjan:

This Hon'ble Court possesses jurisdiction to hear the Criminal Appeal filed by Mr. DedBull
Ranjan, challenging the orders of lower courts, on matters relating to criminal law and
constitutional rights.

The Supreme Court, as the court of last resort, holds appellate jurisdiction over decisions of
lower courts in criminal matters. The Criminal Appellate jurisdiction of Supreme Court
mentioned in Article 134 of the Constitution.

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STATEMENT OF FACTS

• The Republic of Cheeku is a diverse nation of over 1.3 billion people with a rich
historical tapestry shaped by a significant colonial era under British rule. The framers
of Cheeku's constitution drew inspiration from English legal traditions, creating a
constitutional framework that reflects a fusion of colonial influences and the nation's
aspirations for sovereignty.
• Cheeku Republic operates as the world's largest democracy with a Parliamentary
System of Governance, embodying the principles of representative democracy and the
separation of powers among the Executive, Legislature, and Judiciary. However, recent
years have witnessed a rise in intolerant politics marked by polarization, religious and
ethnic tensions, and curtailed freedom of expression.
• The emergence of charismatic yet controversial leaders, exemplified by Daddy Dixit of
the Basu-Belli Bhaat Party (BBP), has further intensified political divisions. The BBP,
accused of employing intolerant politics, came to power in 2011, leading to increased
polarization along religious and ethnic lines.
• This situation culminated in a brutal sexual assault incident in the Cheeku Republic,
specifically in Bubu Pradesh in October, triggering widespread protests and demands
for legislative reforms.
• The parliamentary discussion on revisiting sexual offense provisions in CNS 1860
AND CRPC 1973 led to a heated confrontation between Mr. Aryan M., a polarizing
cabinet minister, and opposition members. Mr. Aryan's statement, alleging a conspiracy
between the victim and the opposition, resulted in chaos, leading to the adjournment of
the parliamentary session.
• Proceedings of the parliament were being live reported by DumbPun Press, a large
media house notorious for publishing anti-government content live reporting of these
events by DumbPun Press, fueled the fire, The statement along with DumbPun Press’s
piece added to the public outcry and there were violent clashes between supporters of
the BBP and lower-caste student political leaders the next day
• In response to the incident, the BBP, in the majority in the lower house, initiated a
breach of privilege motion against Mr. DumbPun Trivedi, the founding editor of
DumbPun Press.

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• Simultaneously, the sexual assault victim approached the Supreme Court, filing a Writ
Petition against Mr. Aryan M., alleging a violation of her Right to Dignity under Article
21 of the Constitution.
• Mr. DumbPun also filed a writ petition against the summons notice, arguing that
privileges under Article 105 cannot override the Fundamental Right to Freedom of the
press provided under Article 19(1). He also believed the live-reporting piece was well-
protected under Article 361-A of the Constitution and the Parliamentary Proceedings
(Protection of Publication) Act, 1977.

• After 5 days after the date of publication in the DumbPun Press, The panel Debate
was organized on Apne log News Channel by Mr. Gaurav Samay Raina (Speaker,
BBP) and Mr. DedBull Ranjan (Founder, FloodConnect Foundation). During the
panel debate, heated arguments and threats were exchanged between Mr. Gaurav and
Mr. DedBull
• Mr. Gaurav, a supporter of Mr. Aryan, was assaulted by Mr. DedBull during a public
gathering organised on 01/11/2023. Mr. Gaurav filed a police complaint on 03/11/2023
and Mr. DedBull was arrested. The case went through several stages:
• In the Initial investigation Police filed an FIR and investigated the case. On 12/11/2023
Assistant Chief Judicial Magistrate committed the case to trial under Sections 320, 322,
325 and 335 of the CNS. On 22/11/2023 Mr. DedBull filed a discharge application in
High Court, but it was dismissed. On 26/11/2023 Chief Judicial Magistrate found
insufficient evidence for grievous hurt and referred the case for reinvestigation. A new
application for discharge was filed based on the Chief Judicial Magistrate's order but
rejected by the Trial Court on 02/12/2023 then Mr. Dedbull Ranjan applied again in the
High Court under section 482 against the order of trial court passed by 02/12/2023 but
his appeal is rejected and Honarable HC says at this stage he cant accept additional
evidence other than that mentioned in section 239 and 240 of CRPC. Against This Mr.
DedBull appealed to the Supreme Court, which admitted the appeal
• The Supreme Court, recognizing the interconnectedness of these issues, has scheduled
a joint hearing before a 7-Judge Bench on January 7th, 2024, to address crucial
constitutional questions arising from these complex circumstances.

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ISSUE RAISED

1. Whether Mr. Aryan M.’s statements made in Parliament were violative of the Right to
Dignity of the victim under Article 21 of the Constitution?
2. Whether privileges and immunities of the House of the Legislatures enshrined under
Article 105 of the Constitution override the freedom of press provided under Article
19(1)(a) in the present case?
3. Is additional evidence admissible before the High Court while dealing with the
discharge issue?
4. In the instant case, can Mr. DedBull Ranjan be discharged or not?

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SUMMARY OF ARGUMENT

MR. ARYAN M.’S STATEMENTS MADE IN PARLIAMENT WERE NOT

VIOLATIVE OF THE RIGHT TO DIGNITY OF THE X UNDER ARTICLE 21 OF
THE CONSTITUTION

It is Humbly submitted by counsel of Respondent that statement made by Minister Mr. Aryan
is not violative of X Right to dignity under Article 21 ,it is well protected under article 105 of
Constitution of Cheeku Republic which talks about parliamentary privileges which every
member of parliament enjoys parliamentary privileges grants Parliament members Immunity
against the prosecution for the things they said in parliament Mr. Aryan m.'s remarks, while
possibly controversial, were not directed at undermining the dignity of the victim but rather
focused on broader policy issues related to law enforcement,mr. Aryan m.'s statements in
parliament are protected by the principle of separation of powers, and any attempt to penalize
him for expressing his views would infringe upon the autonomy of the legislative
branch.Freedom of speech and expression is granted under article 19 of the cheeku republic,
and article 19 can’t be undermined by the right to dignity under article 21.

PRIVILEGES AND IMMUNITIES OF THE HOUSE OF THE LEGISLATURES

ENSHRINED UNDER ARTICLE 105 OF THE CONSTITUTION CAN OVERRIDE
THE FREEDOM OF PRESS PROVIDED UNDER ARTICLE 19(1)(A) OF THE
CONSTITUTION OF CHEEKU REPUBLIC

The counsel for Respondent Humbly submits that the Privileges and immunities of the house
of the legislatures enshrined under article 105 of the constitution can override the freedom of
press provided under article 19(1)(a) of the constitution of cheeku republicFreedom Press under
article 19(1)(a) is subject to article 105, which talks about the privileges of parliament, Mr.
Dumbpun trivedi, the founding editor of dumbpun press, undermined the dignity of the
legislature by his content and parliament was right in initiating contempt of court proceeding
against mr . Dumbpun trividi and 3.Parliamentary proceedings (protection of publication) act,
1977 act provides certain protections to the publication of parliamentary proceedings.
However, it does not grant absolute immunity,

ADDITIONAL EVIDENCE CAN NOT BE ADMISSIBLE BEFORE THE HIGH

COURT WHILE DEALING WITH THE ISSUE OF DISCHARGE

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Counsel of Respondent Humbly submits that Additional evidence can not be admissible before
the high court while dealing with the issue of discharge,high courts are not the trial court the
high court should not allow to addmission of additional evidence while dealing with
discharge,high court, while dealing with the issue of discharge, should refrain from admitting
additional evidence and this approach ensures a fair and expeditious determination of the
accused's culpability and also saves judiciary resources while upholding the principles of legal
consistency and finality and there is limited scope of the high court's review during the
discharge stage

DISCHARGE SHOULD NOR GIVEN TO MR. DEDBULL RANJAN IN THE

IMMEDIATE CASE

The counsel for Respondent Humbly submits that discharge should not be given to mr. Dedbull
ranjan in the immediate case , while giving discharge, the court should consider not only
evidence but also the entire material record and mens rea of the accused and mr. Dedbull ranjan
caused grivious harm to mr. Gaurav samai rana, eyewitness testimony medical evidence
support this.

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ARGUMENTS ADVANCED

A. MR. ARYAN M.’S STATEMENTS MADE IN PARLIAMENT WERE NOT

VIOLATIVE OF THE RIGHT TO DIGNITY OF THE X UNDER ARTICLE 21 OF
THE CONSTITUTION

The Counsel for Respondent Submit before this Honorable Court that the Statement made by
Minister Aryan M in parliament is part of an active Discussion process that happening inside
the Parliament regarding amendments in criminal law and sexual assault laws and also is was
well protected under the Parliamentary privileges that Member of Parliament enjoys Under
Article 105 of the Constitution of Cheeku Republic and thus, it was violative of Right to dignity
of X under Article 21 of the Constitution of Cheeku Republic.

A1. MR. ARYAN M.'S STATEMENTS WERE MADE WITHIN THE

PARLIAMENTARY SETTING DURING A DEBATE ON AN IMPORTANT ISSUE,
AND AS SUCH, THEY FALL UNDER THE PROTECTION OF PARLIAMENTARY
PRIVILEGE.

1. The counsel Humbly Submit before the Honorable Supreme Court that Mr. Aryan M. did
not intend to violate the victim's right to dignity. His statements were made in the context
of a more extensive discussion on legislative amendments, and any strong language used
should be viewed as part of the parliamentary discourse rather than a deliberate attack on
the victim.
2. Parliamentary privilege is a legal immunity granted to members of the legislature to ensure
the independent functioning of the legislative branch without fear of legal consequences
for statements made during official proceedings. In the context of Cheeku Republic, this
privilege is enshrined under Article 105 of the Constitution, which provides immunity to
parliamentarians for anything said or any vote given by them in Parliament.
3. Mr. Aryan M.'s statements were made within the specific context of a parliamentary debate
on amendments to the Cheeku Nyaya Sanhita, 1860 and the Code of Criminal Procedure,
1973. Parliamentary debates are forums for robust discussions on matters of public interest,
and members must be free to express their opinions without fear of legal repercussions.
4. The concept of parliamentary privilege is rooted in the need to protect the independence of
the legislative branch. Members must feel free to express diverse and, at times, dissenting
views without the fear of being hauled to court for their statements. This privilege is crucial

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for maintaining the separation of powers and preventing interference with the functioning
of the legislature.
5. Any limitation on the freedom of speech within parliamentary proceedings could lead to a
chilling effect, where members may become hesitant to express their opinions openly. This
could undermine the quality of debates and hinder the legislature's ability to scrutinize and
challenge the executive's actions.
6. Freedom of speech within Parliament includes the freedom to criticize policies, individuals,
and government actions. It is essential for holding the government accountable and
ensuring transparency. Mr. Aryan M.'s statements, though strong, were made in the spirit
of critiquing the opposition and advocating for specific legislative measures.
7. Parliamentary privilege, when applicable, is often considered absolute. This means that
members of Parliament are protected from legal consequences for their statements,
regardless of the content, as long as those statements are made within the scope of
parliamentary proceedings. The Counsel submits that Mr. Aryan M.'s remarks fall within
the ambit of parliamentary privilege.
8. 1
Article 105, clause (1), expressly safeguards freedom of speech in parliament. It says: there
shall be freedom of speech in parliament. Clause (2) further provides that no member of
Parliament shall be liable to any proceedings in any court in respect of anything said or any
vote given by him in Parliament or any committee thereof. No action, civil or criminal, will
therefore lie against a member for defamation or the like in respect of things said in
parliament or its committees. The immunity is not limited to mere spoken words; it extends
to votes
9. In 1998, the landmark case of 2P V Narasimha Rao v State held that parliamentarians
enjoyed immunity from prosecution for any speech made or vote cast inside the House
under Article 105(2) and Article 194(2) of the Constitution.
A2. MR. ARYAN M.'S REMARKS, WHILE POSSIBLY CONTROVERSIAL,
WERE NOT DIRECTED AT UNDERMINING THE DIGNITY OF THE
VICTIM BUT RATHER FOCUSED ON BROADER POLICY ISSUES
RELATED TO LAW ENFORCEMENT.
10. The Counsel Humbly Submit before the Honarable SC that Mr. Aryan M.'s statements were
part of a larger policy debate on sexual offense laws and law enforcement. His focus on

1
Article 105 of the Indian Constitution.
2
P V Narasimha Rao v. State, 1998 4 SCC 626.

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increased funding for law enforcement and fast-track trial courts indicates a genuine
concern for addressing societal issues rather than a deliberate attempt to harm the victim's
dignity.Mr. Aryan M.'s statements, as reported, do not appear to involve personal attacks
on the victim. The Counsel submit that his remarks were directed towards the opposition's
stance and the broader legislative context rather than targeting the individual involved in
the sexual assault incident.
11. Mr. Aryan M.'s statements should be analyzed in the context of a parliamentary debate on
amendments to sexual offense laws. The heat of parliamentary debates often involves
passionate arguments and counterarguments. Mr. Aryan M.'s comments should be viewed
as part of the larger debate rather than isolated statements, considering the emotionally
charged atmosphere surrounding the discussion on a sensitive issue like sexual assault.
12. . Mr. Aryan M.'s comments can be interpreted as political rhetoric rather than a deliberate
attempt to violate the victim's dignity. Counsel submits that such rhetorical flourishes are
typical in political discourse and should be viewed in light of their political context.
13. Lawmakers can critique legislation and propose alternative solutions. Mr. Aryan M.'s focus
on the inadequacy of existing legal provisions and the need for increased funding for law
enforcement falls within the realm of legitimate parliamentary discussions. These
comments were made in the interest of legislative improvement rather than to violate
Article 21.
14. There is no evidence to suggest that Mr. Aryan M. made his statements maliciously to harm
the victim's dignity. The statement was part of a larger discussion on law enforcement and
legislative measures, and any emotional outburst was not directed at undermining the
victim's dignity but rather at countering opposition arguments.
15. In summary, Counsel aims to establish that Mr. Aryan M.'s statements were made within
the bounds of legitimate policy debate, focusing on systemic issues rather than targeting
the dignity of the victim, and should therefore be considered as constitutionally protected
speech.
A3. MR. ARYAN M.'S STATEMENTS IN PARLIAMENT ARE PROTECTED
BY THE PRINCIPLE OF SEPARATION OF POWERS, AND ANY ATTEMPT
TO PENALIZE HIM FOR EXPRESSING HIS VIEWS WOULD INFRINGE
UPON THE AUTONOMY OF THE LEGISLATIVE BRANCH.
16. The counsel Humbly Submit before the Honorable Supreme Court that Separating powers
is a foundational principle in constitutional democracies, including the Cheeku Republic.

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It ensures that the powers of the state are distributed among different branches – executive,
legislative, and judicial – to prevent the concentration of authority and safeguard against
potential abuses. It was mentioned in 3Article 50 of the constitution. The Counsel Reported
that Mr. Aryan M.'s statements fall within the purview of legislative functions.
17. As a distinct branch, Parliament enjoys autonomy in its proceedings and debates. The
counsel asserts that attempts to penalize Mr. Aryan M. for his statements would undermine
the legislature's independence, restricting its ability to engage in robust discussions on
matters of public interest.
18. The Constitution of Cheeku Republic reflects a deliberate design incorporating the
separation of powers. The council argues that any attempt to curtail the freedom of speech
within Parliament would disrupt this constitutional equilibrium and upset the delicate
balance between the executive, legislature, and judiciary.
19. Lawmakers play a crucial role in shaping laws and policies, and their ability to express
opinions freely is integral to the legislative process. The counsel contend that Mr. Aryan
M.'s statements were made in the context of parliamentary proceedings, and any
interference would hinder the effective functioning of the legislative branch.
20. The separation of powers is also linked to checks and balances. The council contends that
allowing external intervention in parliamentary debates would weaken the system of checks
and balances, as the legislature must be free to critique and scrutinize the executive's actions
without fear of reprisal.
21. Parliamentary proceedings are presumed regular, and members are expected to carry out
their duties within the established norms. The counsel argues that Mr. Aryan M.'s
statements, even if provocative or controversial, should be viewed within the parliamentary
setting, where robust debates and disagreements are inherent.
22. Upholding the separation of powers requires safeguarding parliamentary immunity.
Members must be shielded from legal repercussions for their statements made within the
legislative domain. The Council asserts that any challenge to Mr. Aryan M.'s immunity
would set a precedent detrimental to the separation of powers.
In conclusion, based on the separation of powers, there is a need to protect the
legislative branch's autonomy, asserting that Mr. Aryan M.'s statements are an integral
part of parliamentary functions and should be shielded from external interference.

3
Article 50 of the Indian Constitution.

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A4. FREEDOM OF SPEECH AND EXPRESSION IS GRANTED UNDER

ARTICLE 19 OF THE CHEEKU REPUBLIC, AND ARTICLE 19 CAN’T BE
UNDERMINED BY THE RIGHT TO DIGNITY UNDER ARTICLE 21.
23. The counsel Humbly Submits before this honorable Court that every Citizen of Cheeku has
Freedom of speech expression under article 19 of the constitution. Mr. Aryan, as a Citizen
of the Cheeku Republic, Also enjoys the same rights, and his statement in parliament is
well protected under Article 19 of the constitution.
24. In the case of 4Kaushal Kishore v State Of Uttar Pradesh Honorable Supreme Courts, five
judges' bench held that the right to freedom of speech and expression of an individual could
not be restricted for violating the dignity of another individual.
The majority judgment of the Court held that in cases where two or more fundamental
rights conflict, the Court must strike a balance or prioritize one over the other. The
Court considered that the grounds for restricting the freedom of speech and expression
were listed under Article 19(2) of the Constitution. They held that this was an
exhaustive list and that no new grounds could be added to the list to impose further
restrictions. Therefore, they held that the right to freedom of speech of a public
functionary could not be curtailed in order to protect the right to dignity of an
individual.
25. The Constitution Bench held that the Freedom of Speech of public officials cannot be
restricted in favour of another persons fundamental rights.
B. PRIVILEGES AND IMMUNITIES OF THE HOUSE OF THE LEGISLATURES
ENSHRINED UNDER ARTICLE 105 OF THE CONSTITUTION CAN OVERRIDE
THE FREEDOM OF PRESS PROVIDED UNDER ARTICLE 19(1)(A) OF THE
CONSTITUTION OF CHEEKU REPUBLIC
1. The Counsel for Respondent Submit before this Honorable Court that the Privileges
and immunities of the House of the Legislatures are absolute and even can override the
freedom of press under 5Article 19(1)(a) of the Constitution and Counsel further submit
that the breach of Privilege motion initiated by Parliament was right Dumbpun Press
committed a breach of privilege by lowering the dignity of the legislature and tarnishing
the image of a cabinet minister by publishing the live-reporting piece. It’s essential to
Preserve the Integrity of Parliament.

4
Kaushal Kishore v. State of Uttar Pradesh, 2023 4 SCC 1.
5
Article 19(1)(a) of the Indian Constitution.

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B1. FREEDOM PRESS UNDER ARTICLE 19(1)(A) IS SUBJECT TO ARTICLE 105,

WHICH TALKS ABOUT THE PRIVILEGES OF PARLIAMENT

2. The Counsel Humbly Submit before this honorable court that Freedom of the Press
under Article 19(1)(a) is subject to the privileges of parliament In the case of 6M.S.M
Sharma vs Krishna Sinha the Five Judges bench of Supreme Court upheld the
regulatory authority of a state legislative assembly to regulate the publication of its
debates or proceedings over the right to free speech. M. Sharma published an address
to the Bihar Legislative Assembly in its entirety, claiming that his right to free speech
protected this action, despite an order of the Speaker to expunge certain portions of the
address. The Court found that Sharma’s actions did not directly fall under the free
speech protections of Article 19 because it violated the authority reserved to the
Assembly in Article 194 over the publication of its proceedings.
3. 7
Parliamentary Proceedings (Protection of Publication) Act, 1977 Act provides certain
protections to the publication of parliamentary proceedings. However, it does not grant
absolute immunity, especially if the content goes beyond reporting and enters the realm
of opinion pieces that may be seen as disrespectful.The legislature in India enjoys the
power to punish for contempt by virtue of articles 8105(3) and 9194(3) if media house
by his content lower the dignity of house
4. Article 105 of the Constitution explicitly grants privileges and immunities to the
members of the Parliament to ensure the effective functioning of the legislature. The
framers of the Constitution, by enshrining these privileges, intended to create a
protective sphere around parliamentary proceedings, emphasizing the paramount
importance of legislative independence.
5. Upholding the privileges under Article 105 is essential for preserving the integrity and
autonomy of parliamentary proceedings. Any external interference, including from the
press, could compromise the legislative body's independence and hinder legislators' free
and uninhibited expression of views.
6. Article 105 is rooted in the principle of separation of powers, a fundamental feature of
the Constitution. Granting exclusive privileges to the legislature, including freedom of
speech within its walls, is a constitutional necessity to maintain the delicate balance

6
M.S.M Sharma vs. Krishna Sinha, AIR 1959 SC 395.
7
Parliamentary Proceedings (Protection of Publication) Act, 1977.
8
Article 105(3) of the Constitution of India.
9
Article 194(3) of the Constitution of India.

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between the executive, legislative, and judicial branches. Allowing the freedom of the
press to override these privileges would disrupt this constitutional equilibrium.
7. The privileges granted under Article 105 are inherent to the functioning of the
legislature and are necessary for its effective operation. These privileges, including
freedom of speech, are not absolute but are subject to the internal rules and regulations
of the legislature. External entities, including the press, should not be permitted to
challenge or undermine these inherent powers.
8. The same is held in 10S.P. Sampathkumar v. Union of India: This case deals with the
privileges and immunities of the House of Legislatures enshrined under Article 105 of
the Constitution. The Supreme Court ruled that the privileges and immunities of the
House of the Legislatures are sacrosanct and should not be interfered with by the
executive or the judiciary. The Court held that the freedom of press provided under
Article 19(1)(a) should be balanced with the privileges and immunities of the House of
the Legislatures.
9. Parliamentary privileges, including the privilege against the lowering of the dignity of
the legislature, exist to maintain the integrity and respectability of parliamentary
proceedings. Initiating a breach of privilege motion is a legitimate step to address
instances where media content is perceived to have violated the established decorum of
the legislative process.
B2. MR. DUMBPUN TRIVEDI, THE FOUNDING EDITOR OF DUMBPUN
PRESS, UNDERMINED THE DIGNITY OF THE LEGISLATURE BY HIS
CONTENT
10. The counsel Humbly Submit before the Honorable Supreme Court that The
"DhumbPun Says" opinion piece, as reported in Annexure A, contains statements that
can be perceived as disrespectful and damaging to the dignity of the legislature.
The statement, "Incidents like these predict a haunting reality where wives of
parliamentarians will not be safe walking on the streets of Bubu Pradesh," suggests
a lack of decorum and seriousness in addressing parliamentary affairs.
11. Such statements have the potential to influence public perception negatively by creating
a sensationalized and potentially inaccurate narrative about the safety of
parliamentarians' spouses.Public trust in the integrity and seriousness of parliamentary

10
S.P. Sampathkumar v. Union of India 1987 AIR SC 386.

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proceedings may be eroded if media outlets engage in sensationalism or use

inflammatory language.
12. The live-reporting piece by DumbPun Press, as presented in Annexure A, might be
perceived as selective in its reporting, focusing on heated arguments and threats without
providing a comprehensive context of the parliamentary debate. Selective reporting can
distort the true nature of events and potentially present a biased perspective to the
public.
13. The inclusion of phrases such as "rising lethal disregard for public morality and basic
decency among parliamentarians" in the "DhumbPun Says" opinion piece suggests a
strong bias and potentially inflammatory language. Inflammatory language can
contribute to the public's negative perception of parliamentary proceedings and the
individuals involved.
14. Media outlets play a crucial role in shaping public opinion, and any misrepresentation
or biased reporting can significantly impact public perception.If DumbPun Press, a
widely-read media house, portrays parliamentary proceedings in a negative light
without presenting a balanced view, it can contribute to a distorted public understanding
of the issues at hand.
15. Mr. Aryan M., a cabinet minister, is directly mentioned in the live-reporting piece,
accusing him of a "lethal disregard for public morality."Such accusations, if not backed
by substantial evidence or presented in a fair and unbiased manner, can be considered
as a form of maligning the character and reputation of a public figure.
16. Parliament is a revered institution that operates with certain decorum and respect for its
members. Any content that deviates from this decorum and uses provocative language
undermines the solemnity of the legislative process.If opinion pieces suggest that
parliamentarians' family members are not safe, it implies a lack of faith in the security
measures and the overall functioning of the parliamentary system.
17. While media outlets have the freedom to express opinions, they also bear the
responsibility to exercise this freedom judiciously.In this case, the opinion piece seems
to go beyond expressing a viewpoint and enters the realm of sensationalism, potentially
harming the reputation of the legislature and its members.Such opinion pieces,
predicting a grim future for parliamentarians' spouses, have the potential to create
unrest and unnecessary fear among the public.
18. This can be seen as an attempt to sensationalize parliamentary proceedings for the sake
of capturing attention, rather than contributing to a constructive and informed public

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discourse.While acknowledging the freedom of the press, it is essential to balance this

freedom with legal and ethical considerations. Content that may be interpreted as
disrespecting or undermining the dignity of the legislature should be subject to scrutiny.
19. In 11
Surendra Singh v. Indian Express journalist Surendra Singh published an article
criticizing a member of Parliament (MP) based on a letter the MP had written that was
leaked from a parliamentary committee. The court upheld the MP's complaint of breach
of privilege, arguing that the committee proceedings were confidential and should not
be published. This case was criticized for undermining press freedom and public access
to information.
20. In Raj Narain v. Durga Das Bhargava 12
a newspaper editor published an article
questioning the qualifications of an MP. The MP complained of breach of privilege,
and the editor was ultimately found guilty.
21. In conclusion, the counsel submits that to protect and preserve the dignity and
respectability of the legislature, emphasizing that media outlets, while expressing
opinions, should adhere to a standard of responsible journalism that respects the sanctity
of parliamentary proceedings. Initiating a breach of privilege motion in this context
becomes a means to address instances where the media's freedom may have crossed the
boundaries of responsible expression.
C. ADDITIONAL EVIDENCE CAN NOT BE ADMISSIBLE BEFORE THE HIGH
COURT WHILE DEALING WITH THE ISSUE OF DISCHARGE
The Counsel for respondent Humbly Submits before this honorable SC that The
discharge stage is intended to weed out cases lacking merit expeditiously. Allowing the
introduction of fresh evidence at this juncture would compromise the principle of
finality, which is crucial for the efficient administration of justice and High Court
Should adhere to the statutes and statues that don’t allow of admission of additional
evidence at the appellate stage .
C1. HIGH COURTS ARE NOT THE TRIAL COURT THE HIGH COURT
SHOULD NOT ALLOW TO ADDMISSION OF ADDITIONAL EVIDENCE
WHILE DEALING WITH DISCHARGE.
1. The Counsel For Respondent Humbly Submit Before This Honarable Supreme Court that
the trial court is the appropriate forum for a detailed examination of evidence and the

11
Surendra Singh v. Indian Express, AIR 1975 SC 1030.
12
Raj Narain v. Durga Das Bhargava, AIR 1970 SC 1469.

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determination of guilt or innocence. Allowing the High Court to admit additional evidence
would blur the lines between the functions of the trial court and the appellate court. The
trial court, with its fact-finding jurisdiction, is better equipped to weigh evidence and make
nuanced determinations.
2. In case of 13State of Tamil Nadu Vs. N. Suresh Rajan And Others (2014) 11 SCC 709 Court
in his judgement said that “True it is that at the time of consideration of the applications for
discharge, the court cannot act as a mouthpiece of the prosecution or act as a post office
and may sift evidence in order to find out whether or not the allegations made are
groundless so as to pass an order of discharge. It is trite that at the stage of consideration of
an application for discharge, the court has to proceed with an assumption that the materials
brought on record by the prosecution are true and evaluate the said materials and documents
with a view to find out whether the facts emerging therefrom taken at their face value
disclose the existence of all the ingredients constituting the alleged offence. At this stage,
probative value of the materials has to be gone into and the court is not expected to go deep
into the matter and hold that the materials would not warrant a conviction. In our
opinion,what needs to be considered is whether there is a ground for presuming that the
offence has been committed and not whether a ground for convicting the accused has been
made out. To put it differently, if the court thinks that the accused might have committed
the offence on the basis of the materials on record on its probative value, it can frame the
charge; though for conviction, the court has to come to the conclusion that the accused has
committed the offence. The law does not permit a mini trial at this stage.”
3. In 14Chavi Lal And Others vs State Of U.P. And Another UP High Court also said in there
judgement that “At the stage of charge the court is not required to consider pros and cons
of the case and to hold an enquiry to find out truth. Marshalling and appreciation of
evidence is not in the domain of the court at that point of time. What is required from the
court is to sift and weigh the materials for the limited purpose of finding out whether or not
a prima facie case for framing a charge against the accused has been made out,"
4. Justice Suresh Kumar Gupta observed.”The legal system is structured with a hierarchy of
courts, each with its designated functions. Trial courts, being the initial forums for legal
proceedings, are responsible for examining evidence, hearing witnesses, and making

13
Tamil Nadu vs. N. Suresh Rajan and Others, (2014) 11 SCC 709.
14
Chavi Lal and Others vs. State of U.P. and Another, Application u/s 482 No. 2180 of 2018.

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factual determinations. Their role is pivotal in ensuring a fair and thorough examination of
the case.
5. Trial judges possess a level of expertise and familiarity with the specific nuances of the
cases they preside over. They are in the best position to assess the relevance and
admissibility of evidence during the trial stage. Allowing the High Court to admit additional
evidence might disrupt the trial court's carefully considered decisions and evaluations.
6. The trial court's authority is crucial in preventing forum shopping, where parties might
attempt to present their case before a higher court with the hope of a more favorable
outcome. By respecting the trial court's role, the legal system ensures that disputes are
resolved at the appropriate level, maintaining consistency and stability in legal proceedings.
7. Trial courts are designed to handle a significant volume of cases efficiently. Allowing the
High Court to admit additional evidence at the discharge stage may lead to a flood of
appeals, increasing the workload of higher courts. This could hinder the efficient
functioning of the legal system and cause unnecessary delays.
8. Trial judges often specialize in specific areas of law, gaining insights and expertise relevant
to the cases they handle. Preserving the trial court's authority to decide on evidence ensures
that specialized knowledge is applied appropriately, contributing to well-informed and
nuanced decisions.
In conclusion, respecting the role of trial courts is essential for maintaining the integrity
of the legal system. It ensures that each court operates within its designated function,
prevents forum shopping, promotes efficiency, and upholds the specialized decision-
making and discretion exercised by trial judges.
C2. HIGH COURT, WHILE DEALING WITH THE ISSUE OF DISCHARGE,
SHOULD REFRAIN FROM ADMITTING ADDITIONAL EVIDENCE AND
THIS APPROACH ENSURES A FAIR AND EXPEDITIOUS
DETERMINATION OF THE ACCUSED'S CULPABILITY AND ALSO SAVES
JUDICIARY RESOURCES WHILE UPHOLDING THE PRINCIPLES OF
LEGAL CONSISTENCY AND FINALITY.
9. The counsel Humbly Submits before the Honorable Supreme Court that Legal systems seek
to prevent endless litigation and the continuous relitigation of matters. Certainty in legal
proceedings is crucial to discouraging parties from repeatedly introducing new evidence to
challenge earlier decisions. It encourages litigants to present their strongest case within
established procedural boundaries.

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10. By refraining from admitting additional evidence, high courts align their decisions with the
intended procedural framework. This ensures legal harmony and prevents deviations from
established legal norms.
11. The statutory framework provides a structured process for determining an accused's
culpability. By following this framework, high courts contribute to the efficiency of legal
proceedings. This is crucial for avoiding unnecessary delays and ensuring a timely
resolution of criminal cases.
12. The admission of additional evidence after the trial stage can lead to protracted litigation,
with parties engaging in continuous legal battles. Adhering to the statutory framework helps
avoid prolonged legal proceedings, promoting a more streamlined and effective justice
system.
13. Certainty in legal proceedings is vital for maintaining public confidence in the justice
system. When litigants and the public perceive legal processes as uncertain or subject to
constant revision, it erodes trust in the fairness and reliability of the legal system. Certainty
promotes confidence that legal decisions are robust and well-founded.
C3. THERE IS LIMITED SCOPE OF THE HIGH COURT'S REVIEW DURING
THE DISCHARGE STAGE
14. The counsel Humbly Submit before the Honorable Supreme Court that when the accused
appeals a discharge order to the high court, it generally confines its examination to the
evidence on record before the trial court. This limitation ensures that the high court does
not reevaluate the entire case but focuses on assessing whether the trial court's decision was
legally sound based on the available evidence. Here are the key aspects of this principle:
15. High courts exercise appellate jurisdiction when reviewing decisions of lower courts. In the
context of the discharge stage, the accused has the right to appeal the trial court's decision
to the high court.The high court's review primarily revolves around determining the legal
soundness of the trial court's decision. It assesses whether the trial court applied the correct
legal principles and procedures in arriving at its decision to discharge or not discharge the
accused.
16. The high court's scrutiny is generally limited to the evidence that was before the trial court
during the discharge proceedings. This includes witness statements, documents, and
materials presented during the investigation.

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17. The high court, in its review, does not conduct a fresh examination of witnesses or admit
additional evidence. It relies on the record created before the trial court to make its
determination.
18. The limited scope of review prevents the high court from reevaluating the case as if it were
conducting a full-fledged trial. This is consistent with the purpose of the discharge stage,
which is to determine whether there is sufficient evidence to proceed to trial.
19. Recognizing the trial court's discretion in assessing evidence and determining whether to
discharge the accused, the high court aims to preserve and respect this discretion. The high
court does not substitute its judgment for that of the trial court unless there are compelling
reasons to do so.
20. By restricting the scope of review, the high court contributes to judicial efficiency. It
ensures that the appellate process focuses on legal issues rather than rehashing the entire
evidentiary record, allowing for a more streamlined and expeditious appeal process.
21. While the general principle is to limit the review to existing evidence, there may be
exceptional circumstances where the high court might consider additional evidence.
However, such circumstances would typically be rare and would require strong
justification.
22. In summary, the limited scope of the high court's review during the discharge stage is
designed to balance the rights of the accused with the need for judicial efficiency and
consistency. It promotes the finality of trial court decisions and ensures that the appeal
process focuses on legal principles rather than relitigating the entire case.
D. DISCHARGE SHOULD NOT BE GIVEN TO MR. DEDBULL RANJAN IN THE
IMMEDIATE CASE
The Counsel for the respondent humbly Submits before this honorable SC that
Considering the Nature of injury caused to Mr. Gaurav Samai Rana, Assault by
Mr.Dedbull Ranjan, Eyewitness testimony, Medical Evidence, Victim right , Lower
court and High Court decisions Mr. Dedbull Ranjan Should not be given discharge.
D1. WHILE GIVING DISCHARGE, THE COURT SHOULD CONSIDER NOT
ONLY EVIDENCE BUT ALSO THE ENTIRE MATERIAL RECORD AND
MEANS REA OF THE ACCUSED
1. The Counsel for Respondent humbly submits before this Supreme Court that Mr. Dedbull
Ranjan came into the gathering with men's rea to assault Mr. Gaurav samai Rana MR.

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Dedbull Ranjan has envied Mr.Gaurav since the Heated debate between them on Apne Log
News.
2. In case of 15
Somnath Thapa vs state of Maharashtra it was held that the Court while
discharging the accused not only rely on evidence on record but also considered mens rea
of the accused and entire material, and here in this case the Mr Dedbull Ranjan comes with
mens rea to assault Mr. Gaurav he has envy against Mr. Gaurav since debating
Incident.Maybe there is quite less evidence to prove the charges of assault, but his entire
motive to Coming at the gathering is to assault Mr. Gaurav.
3. 16
Section 227 of the CRPC says that its magistrate's choice to discharge the accused after
Considering entire material record and further section says - If, upon consideration of the
record of the case and the documents submitted therein, and after hearing the submissions
of the accused and the prosecution in this behalf, the Judge considers that there is not
sufficient ground for proceeding against the accused, he shall discharge the accused and
record his reasons for so doing.
4. Same says 17
Section 239: When accused shall be discharged - If, upon considering the
police report and the document sent with it under Section 173 and making such
examination, if any, of the accused as the Magistrate thinks necessary and after giving the
prosecution and the accused an opportunity of being heard, the Magistrate considers the
charge against the accused to be groundless, he shall discharge the accused, and record his
reasons for so doing.

Here in this case trial Court after considering of entire material of record and Mens rea of the
accused Court found that offences under Sections 320, 322, 325 and 335 CNS are made out
and established the liability of Mr.Dedbull Ranjan and the same is upheld By high court Now
the Counsel pleads before this Honorable Supreme court to Upheld the decision of High Court
and and not give discharge to Mr. Dedbull Ranjan

D2. MR. DEDBULL RANJAN CAUSED GRIVIOUS HARM TO MR. GAURAV

SAMAI RANA, EYEWITNESS TESTIMONY MEDICAL EVIDENCE
SUPPORT THIS
5. The counsel of Respondent Humbly submits before this honarable High Court thatOn
01.11.2023, Mr. Gaurav called for a Peaceful public gathering of the supporters of Mr.

15
Somnath Thapa vs. State of Maharashtra, 1996 AIR 1744.
16
Section 227 of the CRPC.
17
Section 239 of the CRPC.

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Aryan in Namanapatnam, the capital city of Bubu Pradesh. While the gathering had just
begun, several protestors led by Mr. DedBull came to the gathering site and started chanting
slogans against Mr. Aryan's statement. This led to a violent clash between the protestors
and the supporters of Mr. Aryan M. On meeting Mr. Gaurav during the clash, Mr. DedBull
allegedly assaulted him. The assault caused severe bodily pain to Mr. Gaurav and he was
unable to follow his ordinary pursuits.
6. Eyewitness testimony of PW1 Kanishka Pamnani, establishing that Mr. DedBull Ranjan
was observed moving aggressively towards Mr. Gaurav during the scuffle supports that it
was Mr Dedbull who first initiated violence.
7. Dr. Ananya Malik, the medical professional who examined Mr. Gaurav after the alleged
assault after examining he issued a medical certificate that is itself holds substantial weight
and is a valid piece of evidence. The medical certificate explicitly classifies the injuries
suffered by Mr. Gaurav as "grievous." the term "grievous hurt" under Section 320 of the
Cheeku Nyaya Sanhita emphasizes the severity and potential long-term consequences
associated with such injuries.
8. Substantial evidence, including eyewitness accounts and the injury certificate, supports the
gravity of the assault on Mr. Gaurav Samay Rana. The aggressive movement towards Mr.
Gaurav suggests intent, and while provocation may be considered, the disproportionate
force raises concerns. The consistent legal proceedings and rejection of discharge
applications by both the trial court and the High Court underscore the merit of the charges.
Granting discharge prematurely presumes innocence.
Finally Counsel on behalf of the Respondent pleads to this honorable court that the
discharge application of Mr.Dedbull Ranjan should be Rejected

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PRAYER FOR RELIEF

Wherefore in the light of the facts of the case, issues raised, arguments advanced, and
authorities cited, may this Hon’ble bench be pleased to adjudge and declare that:

1. For the dismissal of the petition seeking the quashing of actions and statements made by Mr.
Aryan M. in Parliament, as they are not violative of the Right to Dignity under Article 21 of
the Constitution.

2. For a declaration that the privileges and immunities of the House of the Legislatures under
Article 105 of the Constitution take precedence over the freedom of the press provided under
Article 19(1)(a) in the present case.

3. For a declaration that additional evidence is not admissible before the High Court while
dealing with the issue of discharge, and for an order restricting the presentation of such
evidence.

4. For the dismissal of the criminal appeal filed by Mr. DedBull Ranjan, and a determination
that he cannot be discharged in the instant case.

And/Or

Pass any other order that it may deem fit in the interest of justice, equality,

and good conscience.

s/d

On behalf of Respondent

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