THE 18TH NALSAR- JUSTICE B.R.

SAWHNY MEMORIAL MOOT COURT COMPETITION

2025
TEAM CODE: 10R

18TH NALSAR – JUSTICE B. R. SAWHNY MEMORIAL MOOT COURT

COMPETITION, 2025

BEFORE,

THE SUPREME COURT OF BHARTHIPURA

IN THE MATTER OF
CONSTITUTION BENCH JURISDICTION

W.P. No._____/2024

KHUSHIM AND NARMERA.............................................................................................. APPLICANT

v.
BETA BANK & ORS. ............................................................................................................. RESPONDENT

W.P. No._____/2025
KHUSHIM AND NARMERA................................................................................................ APPLICANT

v.
STATE OF KENARIA & ORS. .......................................................................................... RESPONDENT

ABOVE MENTIONED PETITIONS HAVE BEEN CLUBBED ON DIRECTIVE OF THE HON’BLE

SUPREME COURT OF BHARATHIPURA

WRITTEN SUBMISSION ON BEHALF OF THE RESPONDENT

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TABLE OF CONTENTS

LIST OF ABBREVIATIONS..................................................................................................3
INDEX OF AUTHORITIES....................................................................................................
STATEMENT OF JURISDICTION....................................................................................4
STATEMENT OF FACTS....................................................................................................5
ISSUES RAISED....................................................................................................................7
SUMMARY OF ARGUMENTS...........................................................................................8
ARGUMENTS ADVANCED................................................................................................9
I. Did the Legislative Assembly of Ghormania have the legislative competence to enact the
FLRA?
A. The FLRA is repugnant to central law and unconstitutional for want of Presidential
assent.

B. The FLRA constitutes a colourable exercise of legislative power under the guise of social
reform, undermining the constitutional scheme for marriage.

C. A State law cannot have extra-territorial application to bind other States.

•
PRAYER.................................................................................................................................20

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LIST OF ABBREVIATIONS

AIR All India Reporter

Anr. Another
art. Article
BSA Bharathipura Succession Act, 1975
BSMA Bharathipura Special Marriage Act, 1953
Etc. Et Cetera
FLRA Family Law (Reform) Act, 2023
Hon’ble Honourable
i.e., That is
ISMA Indian Special Marriage Act, 1954
ISA Indian Succession Act, 1925
Ors. Others
para Paragraph
S. Section
SC Supreme Court
SCC Supreme Court Cases
UOI Union of India
UP Uttar Pradesh
v./vs Versus
Vol. Volume

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STATEMENT OF JURISDICTION

e counsel for the respondents, the union of Bharathipura, the state of Kenaria, and beta bank,
most humbly and respectfully submits to the jurisdiction of this hon'ble court. The appellants have
invoked the jurisdiction of this hon'ble court under Article 136 of the constitution of
Bharathipura. The respondents reserve the right to contest the maintainability of the said
petitions. All of which is most humbly and respectfully submitted.

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STATEMENT OF FACTS

BACKGROUND
The Republic of Bharathipura follows a federal structure similar to India, with states having
defined legislative powers. Each major religious community has its own codified personal laws,
while inter-community marriages are governed by the Bharathipura Special Marriage Act, 1953
(BSMA). Recognition of queer marriages is limited, with only Pandaren personal law allowing
such unions for devout followers.

ENACTMENT OF FLRA

In 2023, the State of Ghormania passed the Family Law (Reform) Act (FLRA), permitting
registration of same-sex relationships and granting them the same legal status as marriages under
BSMA. The Act was enacted with only the Governor’s assent and without Presidential approval,
despite its potential inter-state implications.

TRANSFER DISPUTE

Kushim and Narmera, originally from other states, registered their relationship under FLRA in
Ghormania. In 2024, Kushim was transferred to Kenaria. Narmera sought a transfer under Beta
Bank’s HR policy for spouses, which applied only to marriages recognized under BSMA or
personal laws. Beta Bank, a private entity regulated by the Reserve Bank of Bharathipura, denied
her request.

FIRST LITIGATION

Narmera challenged the decision before the Ghormania High Court under Article 226, claiming
discrimination. The court dismissed the writ, holding that Beta Bank was not an “authority” under
Article 12. The Supreme Court granted interim relief for transfer, subject to conditions.

ADOPTION DISPUTE

In 2025, the couple applied to adopt a child in Kenaria under the Bharathipura Juvenile Justice
Act, 2002 and the Adoption Regulations, 2023. Regulation 5.3 requires couples to have two years
of stable marital relationship. The Kenaria Adoption Resource Agency rejected their application,
stating their FLRA registration had no legal effect in Kenaria.

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SECOND LITIGATION

The couple filed a writ in the Kenaria High Court, challenging Section 57 of the JJ Act and
Regulation 5.3 as discriminatory. The court upheld the provisions, finding a rational basis for the
restriction and affirming that FLRA relationships are not equivalent to legally recognized
marriages in Kenaria.

AFTERMATH

Both matters reached the Supreme Court, which clubbed the petitions and impleaded the Union of
Bharathipura and the State of Ghormania. The Union argued lack of legislative competence for
FLRA without Presidential assent and denied its extra-territorial validity. The case is now before a
Constitution Bench to decide on legislative competence, inter-state recognition, adoption rights,
and Beta Bank’s policy.

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ISSUES RAISED

~I~

DID THE LEGISLATIVE ASSEMBLY OF GHORMANIA HAVE THE LEGISLATIVE

COMPETENCE TO ENACT THE FLRA?

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SUMMARY OF ARGUMENTS

ISSUE 1: THE LEGISLATIVE ASSEMBLY OF GHORMANIA DID NOT HAD THE LEGISLATIVE

COMPETENCE TO ENACT THE FLRA

The Respondent(s) have challenged the legislative competence the legislative assembly of
ghormania to enact the FLRA on the following grounds:

A. The FLRA is repugnant to central law and unconstitutional for want of Presidential
assent.

B. The FLRA constitutes a colourable exercise of legislative power under the guise of social
reform, undermining the constitutional scheme for marriage.

C. A State law cannot have extra-territorial application to bind other States.

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ARGUMENTS ADVANCED

[ISSUE-I] The Legislative Assembly of Ghormania Lacked the Competence to Enact the
Family Law (Reform) Act, 2023 (FLRA).

1. The counsel for the respondents, representing the Union of Bharathipura, humbly and
respectfully submits before the Hon’ble Supreme Court that the Legislative Assembly of
Ghormania was not legislatively competent to enact the Family Law (Reform) Act, 2023
(FLRA). The law is, therefore, invalid because firstly, the FLRA is Repugnant to Central
Law and Void for Lack of Presidential Assent [A]; secondly, the FLRA is a Colorable
Exercise of Legislative Power Under the Guise of Social Reform and Undermines the
Constitutional Scheme for Marriage; and [B]; and lastly, a state law cannot have extra-
territorial application to bind other states [C]. A state's power to legislate on matters
within the Concurrent List is not absolute and is subject to the supremacy of Union laws.
The FLRA, in its attempt to create a new category of legally recognized relationships,
oversteps these constitutional boundaries. The law’s inherent procedural and substantive
flaws render it unconstitutional and, therefore, void.

A. THE FLRA IS REPUGNANT TO CENTRAL LAW AND VOID FOR LACK OF PRESIDENTIAL

ASSENT

2. The respondents humbly and respectfully submits that the enactment of the FLRA by the
Legislative Assembly of Ghormania is invalid and unconstitutional because it directly
conflicts with a Parliamentary enactment, namely the Bharathipura Special Marriage Act,
1953 which occupies the same field under the Concurrent List, and it was enacted without
obtaining the mandatory Presidential assent as required under Article 254(2)1 of the Indian
Constitution.

3. Entry 5 of List III of the Seventh Schedule 2 specifically includes “marriage and divorce;
infants and minors; adoption; wills, intestacy and succession; joint family and partition; all
matters in respect of which parties in judicial proceedings were immediately before the
commencement of this Constitution subject to their personal law.” Parliament, acting
within its legislative competence under Entry 5, enacted the BSMA to provide a uniform
and exhaustive code for solemnisation, recognition and legal consequences of inter-faith

1
INDIA CONST. art. 254, § 2.
2
INDIA CONST. sched. VII, List III, Entry 5.

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and inter-community marriages in Bharathipura. The BSMA deliberately refrains from
recognising same-sex marriages, reflecting a conscious legislative policy decision. The
FLRA, by purporting to confer the same legal status on same-sex unions as marriages
under BSMA, fundamentally alters this framework.

4. The doctrine of pith and substance is decisive in determining legislative competence. In

Union of India v. Harbhajan Singh Dhillon (1972) 2 SCC 779,3 the Hon’ble Supreme
Court observed that if the true nature and character of legislation falls within an entry
already legislated upon by Parliament, the State Legislature cannot enact a law on that
matter unless expressly authorised by the Constitution. Applying this principle, the pith and
substance of the FLRA lies squarely in the domain of marriage recognition, a subject
already legislated upon by Parliament in the BSMA. The FLRA is therefore an attempt to
legislate within an occupied field, which is impermissible under the constitutional
distribution of powers.

5. It is contended that he primary legal challenge to the FLRA stems from the doctrine of
repugnancy, as outlined in Article 254 of the Constitution of Bharathipura. Article 254(1)4
of the Indian Constitution provides that in the event of any inconsistency between State law
and Parliamentary law on a Concurrent List subject, the Parliamentary law shall prevail,
and the State law shall, to the extent of the repugnancy, be void. In M. Karunanidhi v.
Union of India (1979)5, the Court laid down three tests for determining repugnancy:
firstly, whether there is a direct conflict between the two enactments; secondly, whether
Parliament intended to occupy the entire legislative field; and thirdly, whether the two laws
are so inconsistent that they cannot stand together.

6. It was also contended that “Repugnancy between two statutes arises when there is direct
conflict between the two enactments, when Parliament intends to cover the whole field, or
when the two laws are so inconsistent that they cannot stand together.” 6

7. The FLRA fails all three tests. It creates a direct conflict by granting marital status to
relationships which BSMA does not recognize. It interferes with Parliament’s manifest
intention to create a uniform national framework for civil marriage. It also leads to a
situation where compliance with one enactment results in disobedience to the other, since a
couple validly married under FLRA would be treated as unmarried under BSMA. This is
not a mere procedural divergence; it is a substantive and irreconcilable policy conflict.
3
Union of India v. Harbhajan Singh Dhillon, (1972) 2 SCC 779.
4
INDIA CONST. art. 254, § 1.
5
M. Karunanidhi v. Union of India, (1979) 3 SCC 431.
6
Id.

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8. Even if it is contended that there is no direct contradiction, the doctrine of occupied field,
as explained in Deep Chand v. State of Uttar Pradesh 7 the court observed: “If Parliament
has made a law which is exhaustive on a subject in the Concurrent List, the States are
denuded of their legislative power on that subject, even though there is no direct conflict.”

9. The Hon’ble Court held that if Parliament has made a law that is exhaustive on a subject in
the Concurrent List, the States are denuded of the power to legislate on that subject even
without a specific contradiction. The BSMA is a comprehensive code covering every
aspect of solemnisation, registration and legal consequences of marriage. By extending
equivalent recognition to same-sex unions, the FLRA undermines the uniformity and
completeness of the BSMA, thereby disturbing the legislative balance that Parliament
intended to achieve.

10. The constitutional safeguard against such inconsistency is contained in Article 254(2)8,
which allows a state law inconsistent with a Parliamentary law on a Concurrent List subject
to prevail in that State only if it has received Presidential assent. The Legislative Assembly
of Ghormania obtained only the Governor’s assent under Article 200, and not the
President’s assent under Article 254(2).

11. In Hoechst Pharmaceuticals Ltd. v. State of Bihar,9 this Court held that “where a central
law occupies the field, a State law on the same subject is void unless it has obtained
Presidential assent under Article 254(2”). Similarly, in T. Barai v. Henry Ah Hoe,10 the
Court observed: “Presidential assent is a substantive constitutional requirement, not a
mere formality, and ensures that State departures from national policy in concurrent
matters are subject to Union scrutiny.” The omission to obtain Presidential assent in the
present case is fatal to the validity of the FLRA.

12. Attempts to save the FLRA by invoking the doctrine of harmonious construction are
untenable. Harmonious construction is applicable only where two statutes can be read
together without nullifying the effect of either. In Tika Ramji v. State of Uttar Pradesh,11 it
was contended that “Repugnancy may arise even though the two legislations do not
operate in the same field if both deal with the same subject matter and Parliament’s law is
intended to be exhaustive.” Therefore, the laws cannot co-exist without one undermining
the other. Recognition under FLRA and non-recognition under BSMA are mutually

7
Deep Chand v. State of Uttar Pradesh, (1959) Supp (2) SCC 8.
8
INDIA CONST. art. 254, § 2.
9
Hoechst Pharmaceuticals Ltd. v. State of Bihar, (1983) 4 SCC 45, 72.
10
T. Barai v. Henry Ah Hoe, (1983) 1 SCC 177.
11
Tika Ramji v. State of Uttar Pradesh, AIR 1956 SC 676.

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exclusive legal outcomes. Furthermore, the doctrine of severability cannot rescue the
FLRA because its provisions recognising same-sex marriages are not ancillary but are the
very core and object of the Act. As held in R.M.D.C. v. Union of India,12 when the
offending provision is inseparable from the rest of the statute, the entire enactment must
fall.

13. It is also contended that Article 254(2) also reveals its role in preserving federal harmony.
The Presidential assent serves not only as a procedural checkpoint but as a policy
reconciliation mechanism. In a matter like marriage, where personal status carries inter-
state legal consequences, allowing a State to unilaterally create conflicting status categories
without Union approval risks fragmenting the legal unity of the Republic. this conflict
could only have been resolved by Presidential Assent. As per Article 254(2), a state law on
a concurrent subject that is repugnant to a central law can still be valid if it receives the
assent of the President. However, the FLRA received only the Governor's approval. Since
this mandatory requirement was not fulfilled, the FLRA's repugnancy to the central law
cannot be cured. The absence of such assent in this case demonstrates the constitutional
necessity of central oversight in concurrent matters of national significance. For these
reasons, the FLRA stands incurably repugnant to the BSMA and is void ab initio to the
extent of such inconsistency.

B. THE FLRA IS A COLORABLE EXERCISE OF LEGISLATIVE POWER UNDER THE GUISE OF SOCIAL
REFORM AND UNDERMINES THE CONSTITUTIONAL SCHEME FOR MARRIAGE

14. The respondents humbly submit that the enactment of FLRA is unconstitutional and falls
outside the scope of Legislative Assembly of Ghormania and. Entry 5 of the Concurrent List
(List III) in the Seventh Schedule of the Indian Constitution 13 deals with marriage and
divorce; infants and minors; adoption; wills, intestacy and succession; joint family and
partition; all matters in respect of which parties in judicial proceedings were immediately
before the commencement of this Constitution subject to their personal law. Article 246 (2)14
of the Indian Constitution states that both the Parliament and the state legislatures have the
power to make laws on subjects listed in the Concurrent List (List III of the Seventh
Schedule). It means that the state of State of Ghormania has also capacity to frame laws on
subjects like marriage, adoption and succession.
15. However, sometimes, questions arise about whether the legislature has exceeded its
constitutional powers in a statute’s subject matter or method of enactment. Such transgressions
12
R.M.D.C. v. Union of India, AIR 1957 SC 628.
13
INDIA CONST. sched. VII, List III, Entry 5.
14
INDIA CONST. art. 246, § 2.

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may be obvious or hidden, with the latter often referred to as "colourable legislation" in
judicial rulings.15 The idea conveyed by the expression is that although a legislature in passing
a statute purports to act within the limits of its powers, yet in substance and in reality it
transgresses those powers, the transgression being veiled by what appears on proper
examination to be a mere pretence or disguise. 16 The legislature cannot violate the
constitutional prohibition by employing an indirect method. 17 The doctrine of colorable
legislation, as settled by this Hon’ble Court in K.C. Gajapati Narayan Deo v. State of
Orissa,18 rests on the principle that “what cannot be done directly, cannot be done indirectly”
and that the legislature’s true character must be assessed by looking beyond the form and into
the substance, object and effect of the enactment.

16. In the case of State of Bihar v. Kameshwar Singh,19 five-judge Bench of the Supreme
Court of India held “when a legislature has enacted a law under a particular entry, if it is
really outside it, it would be void.” If the legislature has the power to legislate on the
subject in its apparent form but in substance it legislates on a subject outside its
competence, the law is void.
17. It is also contended that this is not a case of incidental encroachment, which is permissible
under the pith and substance doctrine, but a substantial invasion into prohibited territory. In
Zameer Ahmed Latifur Rehman Sheikh v. State of Maharashtra 20, the Court clarified that
incidental encroachment is excusable only when it is inevitable for implementing a valid
law; here, the intrusion into Union List matters is deliberate and avoidable, showing a
colorable purpose.
18. In the present case, although, the legislative assembly of Ghormania has the authority to
frame laws regarding marriage and succession, it has transgressed its authority by
registering same-sex relationships under FLRA and granting same legal status and
consequences as a marriage between heterosexual couples under the BSMA marriages. 21
The BSMA does not recognises same sex marriage. Besides this, Section 17 of the FLRA
(annexure) makes the Bharathipura Succession Act applicable to all relationships registered
under the FLRA, thereby altering the operation of the BSA. This masks an attempt to

15
V.N. Shukla, V.N. Shukla's Constitution of India 799 (12th ed. 2016).
16
Ashok Kumar v. Union of India, (1991) 3 SCC 498.
17
K.C. Gajapati Narayan Deo vs. State of Orissa, AIR 1953 SC 375 : Anil Kumar Bhattacharjee and Ors. vs Deputy
Commissioner and Collector, AIR 1959 Assam 147 : The Collector of Customs, Calcutta and ... vs G. Dass and Co.,
AIR 1966 SC 1577.
18
K.C. Gajapati Narayan Deo v. State of Orissa, AIR 1953 SC 375.
19
State of Bihar v. Kameshwar Singh, AIR 1952 SC 252.
20
Zameer Ahmed Latifur Rehman Sheikh v. State of Maharashtra, (2010) 5 SCC 246.
21
Moot proposition, para 18.

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amend the BSMA, a central law, which Parliament alone can fully reform. By recognising
such unions as marriages, the FLRA necessarily alters legal consequences in domains such
as adoption, succession, inheritance, and certain service benefits out of which many are
regulated by central legislation under the Union List or by uniform national codes under the
Concurrent List. It extends Central law consequences (succession, divorce, maintenance) to
these unions, thereby amending Central statutes without openly stating it. It would also
create a dangerous precedent where States could selectively amend the applicability of
central laws under the guise of exercising concurrent powers. it is an attack on the
nation’s federal system.
19. It is also contended that, the FLRA’s claim of being a social reform measure cannot shield
it from judicial scrutiny. The Constitution indeed permits social reform in personal law
under Article 25(2)(b) and legislative entries such as Entry 5 of List III, but such reform
must operate within the boundaries of legislative competence. In State of Rajasthan v.
Union of India22, the Court emphasized “In a federal Constitution, the distribution of
legislative powers is not a matter of mere procedure; it is fundamental and cannot be
eroded even in the name of policy expediency.” Social reform, however laudable, does not
empower a State to unilaterally override a Parliamentary statute of national application
without following the constitutional mechanism.
20. Thus, its substance reveals it to be colourable legislation, making the act unconstitutional.
Therefore, the FLRA falls outside the legislative competence of Ghormania. It encroaches
upon a domain governed by Central laws (BSMA, BSA).

C. A STATE LAW CANNOT HAVE EXTRA-TERRITORIAL APPLICATION AND BIND OTHER

STATES.

21. The respondent's argument is further bolstered by the principle of territoriality, which limits a
state's legislative competence to its own geographical boundaries. It is most respectfully
submitted that the FLRA is constitutionally invalid to the extent that it seeks to confer legal
recognition of same-sex marriages in a manner that produces binding consequences beyond
the territorial limits of the State of Ghormania. Article 245(1) of the Constitution expressly
restricts the legislative competence of a State Legislature to the territory of that State, as State
can make laws "for the whole or any part of the State." While a state law may have incidental
extra-territorial operation if it possesses a real and substantial territorial nexus with the State, it
cannot directly regulate rights, obligations, or legal statuses in other States. This principle was

22
State of Rajasthan v. Union of India, (1977) 3 SCC 592.
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affirmed in GVK Industries Ltd. v. Income Tax Officer 23, where this Hon’ble Court held:
“124. Parliament, and more particularly, the State Legislatures, cannot legislate on extra-
territorial aspects or causes that have no nexus whatsoever with India or the State
concerned.”

22. In the present case, marital status is not confined in its effects to the territory where it is
granted. Once a marriage is solemnised or recognised in Ghormania, the parties to it will
naturally assert that status in dealings with authorities, institutions, and courts in other States.
For example, under the Central Adoption Resource Authority (CARA) guidelines, eligibility
for adoption depends on the marital status of applicants as recognised under national law. If
FLRA grants “married” status to couples that BSMA does not recognise, it forces central
agencies and other States to either accept that status or face administrative and legal disputes.
This creates an impermissible extra-territorial effect, as the law’s operation extends beyond the
borders of Ghormania without the consent of other States or Parliament.

23. The FLRA's attempt to create a legal relationship that is meant to be recognized in all other
states of Bharathipura directly contravenes this principle. The principle against impermissible
extra-territorial operation was applied in State of Bombay v. R.M.D. Chamarbaugwala 24,
where the Court held: “Legislation enacted by a State must be confined to its territory and
cannot purport to impose liabilities or confer rights on persons outside its boundaries unless
there is a sufficient territorial nexus.”

24. The case of Kushim and Narmera demonstrates this flaw: their relationship, registered in
Ghormania, was not recognized in Kenaria. The High Court of Kenaria's decision to dismiss
their petition on the ground that the FLRA certificate had no legal sanctity in Kenaria was a
correct application of the law. A state cannot compel other states to recognize its laws,
especially on a subject where there is a uniform central law (the BSMA). The FLRA, by trying
to establish a universal legal status for relationships outside of its territory, oversteps its
constitutional mandate.

25. In that case, even though the legislation sought to regulate prize competitions, its provisions
were struck down to the extent they applied to competitions conducted outside the State
without a substantial nexus. Similarly, the FLRA has no legitimate nexus to events or legal
relationships wholly situated outside Ghormania, yet it attempts to impose its recognition of
23
GVK Industries Ltd. v. Income Tax Officer (2011) 4 SCC 36.
24
State of Bombay v. R.M.D. Chamarbaugwala, AIR 1957 SC 699.

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marriages in all interactions involving those parties across the Republic.

26. It is also contended that recognition of marital status inherently implicates the principle of
inter-State comity. In federal systems, such as India’s, personal status determinations are
expected to operate uniformly across the country to ensure stability in civil obligations. While
the United States Constitution contains a “Full Faith and Credit” clause to compel mutual
recognition of such statuses among States, the Indian Constitution contains no equivalent. In
the absence of such a mandate, it is impermissible for one State to unilaterally confer a
personal status that effectively compels recognition elsewhere. As observed in GVK
Industries25 “the constitutional design is to ensure that legislative powers at different levels
operate within their assigned fields, respecting the territorial boundaries of their authority.”

27. An additional constitutional concern arises from the possibility of conflicting statuses. Under
FLRA, a same-sex couple could be “married” in Ghormania but “unmarried” in Kenaria or any
other State applying BSMA. This legal uncertainty undermines the rule of law, which, as held
in K.T. Plantation Pvt. Ltd. v. State of Karnataka,26 is a basic feature of the Constitution. Civil
rights and obligations, such as succession rights, maintenance, tax benefits, and adoption
eligibility, would vary dramatically across State lines, creating a fragmented and unstable
national legal order.

28. Furthermore, such legislative overreach disturbs the federal balance which is itself part of the
basic structure. In State of West Bengal v. Kesoram Industries Ltd.27, the Court emphasised
that “31. in a federal Constitution, one level of government cannot arrogate to itself the
powers vested in another.” By enacting a law with inevitable and substantial extra-territorial
consequences in the domain of personal status, Ghormania has exceeded its legislative
competence and encroached upon the Union’s role in maintaining uniformity in personal laws
of national application.

29. In conclusion, the FLRA, in purporting to recognise marriages whose legal consequences
inevitably spill over into other States and central domains, violates the territorial limitations on
State legislative competence under Article 245(1). The lack of a constitutional mechanism
compelling other States to recognise such marriages, coupled with the unavoidable extra-
territorial impact on central agencies and interstate dealings, renders the Act invalid in this
respect. The principle that a state law cannot bind other States is well-settled, and this Hon’ble
25
GVK Industries Ltd. & Anr. vs. Income Tax Officer & Anr., (2011) 4 SCC 36.
26
K.T. Plantation Pvt. Ltd. v. State of Karnataka, (2011) 9 SCC 1.
27
West Bengal v. Kesoram Industries Ltd. (2004) 10 SCC 201.

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Court should reaffirm that the Ghormania Legislature has acted beyond its powers.

PRAYER

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

1. FIND and DECLARE that the Legislative Assembly of Ghormania lacked the legislative
competence to enact the Family Law (Reform) Act, 2023 (FLRA), and that the said Act is
void and unconstitutional.

And pass any other order that it may deem fit in the ends of justice, equity, and good
conscience. All of which are respectfully submitted.

Place: S/d
Date: (Counsel on behalf of the Respondent)

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