Memorial for Petitioner

-MEMORIAL ON BEHALF OF PETITIONERROLL NO. R230208048

Before HON’BLE

SUPREME COURT OF INDIA

Constitutional Writ Jurisdiction U/Art.32 W.P. No 2006/2025 Young Leaders Collective ………….……………………Petitioner v. President of India.......………………...........................Respondent 1 Union of India.......…………………..….........………..Respondent 2

With W.P. No 2007/2025 Chulbul Choudhary ……………………………..………Petitioner v. President of India .......……………............................ Respondent 1 Union of India.........………………............................. Respondent 2

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THE TABLE OF CONTENTS

1. INDEX OF AUTHORITIES.................................................................................3

2. STATEMENT OF JURISDICTION....................................................................5

3. STATEMENT OF FACTS...................................................................................6

4. ISSUES RAISED...................................................................................................8

5. SUMMARY OF ARGUMENTS.........................................................................9

6. ARGUMENTS ADVANCED.............................................................................10

7. PRAYER..............................................................................................................18

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THE INDEX OF AUTHORITIES CASES: •

Zee Telefilms Ltd. v. Union of India, AIR 2005 SC 2677.

•

Director of Endowments v. Akram Ali, AIR 1956 SC 60

•

State of U.P. v. Raj Narain, AIR 1975 SC 865

•

S. P. Gupta v. Union of India, AIR 1982 SC 149

•

People’s Union for Civil Liberties v. Union of India, (2003) 4 SCC 399.

•

R.K. Jain v. Union of India, (1993) 4 SCC 119 at ¶27.

•

Mukti Morcha v. Union of India, AIR 1984 SC 802;

•

BALCO Employees’ Union (Regd.) v. Union of India, (2002) 2 SCC 333.

•

Charanjit Lal Chowdhary v. Union of India, AIR 1951 SC 41 at ¶81.

•

Gulabrao Keshavrao Dhole v. Pandurang, AIR 1957 Bombay 266.

•

Ram Jawaya Kapur v. The State of Punjab, AIR 1955 SC 549 at ¶13

•

Manual of Parliamentary Procedures in the Government of India, ¶9.5 (2004).

•

Secretary, Ministry of Information and Broadcasting, Govt. of India v. Cricket Association of Bengal, AIR 1995 SC 1236.

•

Bhanumati v. State of Uttar Pradesh through its Principal Secretary, AIR 2010 SC 3796.

•

People’s Union for Civil Liberties v. Union of India, (2003) 4 SCC 399

•

Centre for Public Interest Litigation v. Union of India, AIR 2011 SC 1267

RULES: •

Manual of Parliamentary Procedures in the Government of India, ¶9.5 (2004)

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BOOKS: •

H.M. Seervai, Constitutional Law of India, 2145 (4th ed. 1993)

•

M.P.Jain, INDIAN CONSTITUTIONAL LAW(5th Reprint 2007)

•

Basu, D.D, Shorter Constitution of india (12th Edition, Wadhwa & Co. Nagpur, 1999)

•

Durga Das Basu, Commentary on the Constitution of India, 4496 (8th ed. 2008)

•

V. N Shukla’s Constitution of India, by MP Singh, Eastern Book Company, Reprinted, March 2007 with supplement.

CONSTITUTION:

•

Constitution of India

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THE STATEMENT OF JURISDICTION

The Petitioners humbly submit before the Hon’ble Supreme Court the memorandum for the Petitioners in the case of W.P. 2006/2025 and W.P. 2007/2025 filed by Young Leaders Collective and Mr. Chulbul Choudhary respectively under Article 32 of the Constitution of India, 1950. The present memorandum sets forth the facts, contentions and arguments in the present case.

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STATEMENT OF FACTS

1. The 2022 General Elections brought the All India Democratic Alliance to power with a slender majority and Mr. Khamosh Singh was sworn in as Prime Minister. One of the major coalition partners, the Janta Democratic Party, obtained three crucial cabinet berths and was allowed to field their party leader as candidate for the Presidential elections due in 2023. In the Presidential elections that followed, Mr. Aiyyoabba was sworn in as the next President of India. 2. On 25.08.2025, the Comptroller and Auditor General (“CAG”), in a press communiqué

stated that the Union of India’s policies illegally benefitted M/s. Shady Interests Ltd., a company predominantly owned by JDP leaders. He alleged that most of the loss to the exchequer was due to the President’s use of his discretionary power in granting tax exemption and other benefits to three ports being developed by M/s. Shady Interests Ltd. The Minister of Surface Transport and Shipping, Mr.Katpadi, was also stated to be involved in the alleged scam. The release though was not supplemented with any evidence. 3. In light of the corruption allegation, Mr. Chulbul Choudhary, a social activist, declared

he would begin a „fast unto death‟ unless his version of the anti-corruption legislation, the Jan Pal Bill, was tabled in the Monsoon session of the Parliament. Young Lawyer’s Collective, an opposition party, having reservations with the Jan Lokpal Bill started consultation with other opposition party to enact an anti-corruption legislation. 4. On 27.08.2025, the Cabinet Meeting decided that no civil society draft will be considered; that the government would formulate its own anti-corruption law in consultation with all political parties; and that the next session of the Parliament will be deferred. 5. On 30.08.2025, the CAG submitted its report on the Port’s scam to the President and

decided to not make the contents of the report public. 6. The Young Lawyer’s Collective, Mr. Chulbul Choudhary and 6 other opposition

political parties addressed a joint letter to the President, demanding that the Parliament session be summoned immediately and the CAG report be made public and tabled in 6|Page

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the Parliament. Mr. Chulbul Choudhary, vide a separate letter to the President, demanded that Jan Pal Bill be considered by the Cabinet, and in case it is rejected, the same be tabled in the Lok Sabha for consideration. 7. The President vide a press release on 02.09.2025 rejected all the demands and consequently the Young Lawyers Collective and Mr. Chulbul Choudhary filed separate writ petitions before the Supreme Court under Article 32, commonly asking for, firstly, suitable directions to the President to summon the Parliament urgently and table the CAG report therein; and secondly, appropriate proceedings against the President. Mr. Choudhary, separately prayed for suitable directions to be issued to the Union Cabinet to consider his version of the Jan Pal Bill and in the event it does not accept it, to place it before the Lok Sabha for consideration. Both petitions were accepted.

ISSUES RAISED

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-MEMORIAL ON BEHALF OF PETITIONER1. Whether the Writ Petitions WP 2006/20025 & WP 2007/2025 are maintainable before this

Hon’ble Court 2.

Whether the Hon’ble Supreme Court has the power to direct the summoning of the Parliament.

3. Whether the Hon’ble Supreme Court can direct the Union Cabinet to consider the Jan Pal

Bill or in the alternative, place it before the Lok Sabha

SUMMARY OF ARGUMENTS 8|Page

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1. WRIT PETITIONS WP 2006/2025 & WP 2007/2025 ARE MAINTAINABLE BEFORE THIS COURT. The Petitioner humbly submits that W.P. 2006/2025 is maintainable before this court. The enforcement of rights vide Article 32 of the Constitution of India is contingent upon the fact that violations should be by the State. The Petitioner submits that in the instant petition the President may be considered as „State‟ under Article 12 of the Constitution. Any immunity vested in the President by virtue of Article 361 does not apply to the instant case. Alternatively, even if the President is immune by virtue of Article 361, the Government of India would still be accountable for the actions of the President. 2. THE PRESIDENT OF INDIA SHOULD BE DIRECTED TO SUMMON THE PARLIAMENT AT THE EARLIEST AND THE REPORT OF THE C.A.G. SHOULD BE TABLED. The Petitioner in W.P. 2006/2025 requests the Hon’ble Court to direct the President of India to summon the Parliament at the earliest and table the C.A.G. Report in relation to the Port’s Scam. The basis of this request is firstly, that the deferral of the Parliament substantially violates the right to know of the Petitioner established above. Secondly, under Article 151 the President is bound to produce the report in the Parliament and; lastly, it is within the power of this Hon’ble Court to issue directions to the President. 3. THE UNION CABINET MAY BE DIRECTED TO CONSIDER THE JANPAL BILL AND IF IT IS NOT ACCEPTED THEN IT MAY BE PLACED BEFORE THE PARLIAMENT. The Union Cabinet should be directed to consider the Jan Pal Bill and in the event it is not accepted, the Bill should be placed before the Lok Sabha. Firstly, the drafting of a bill by the Government and its subsequent deliberation by the Cabinet is not a legislative function. Secondly, the Union Cabinet’s decision to not consider the Jan Pal Bill proposed by the Petitioner violates the principles of participatory democracy that have been read into the Constitution.

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ARGUMENTS ADVANCED 1.

WRIT

PETITIONS

WP

2006/2025

&

WP

2007/2025

ARE

MAINTAINABLE BEFORE THIS COURT. WRIT PETITION, W.P. 2006/2025 DIRECTING THE PRESIDENT TO SUMMON THE PARLIAMENT IS MAINTAINABLE. The Petitioner humbly submits that W.P. 2006/2025 is maintainable before this court. The enforcement of rights vide Article 32 of the Constitution of India is contingent upon the fact that violations should be by the State.1 The Petitioner submits that in the instant petition the President may be considered as “State” under Article 12 of the Constitution. Any immunity vested in the President by virtue of Article 361 does not apply to the instant case. Alternatively, even if the President is immune by virtue of Article 361, the Government of India would still be accountable for the actions of the President. The President for the purposes of the present writ petition comes within the purview of ‘State’ However, the Parliament of India is not answerable for violations of Article 19(1) (a) of the Constitution on account of parliamentary privileges that constitutionally vest with the Parliament. The rationale of the court in such cases has been based on preserving the autonomy of the Parliament as an institution in relation to its powers, privileges and immunities. With the exception of provisions relating to parliamentary privilege, any other function carried out by the Parliament would be deemed to come under the purview of “State” action. It is a principle of statutory interpretation that headings within a statute serve the purpose of placing similar groups of provisions in exclusive categories. The President of India is vested with the executive power of the Union.2 However, vide separate headings, the Constitution clearly separates the role of the Executive from that of the Parliament. With respect to the Parliament, the President acts as the third wing besides the two houses. 3 Under the heading “Parliament” in Part V, Chapter II of the Constitution, a further distinction exists in the form of general and specific provisions. Summoning of the Parliament, 4 is a part of the general 1

The term “State” has been understood in the terms of art.12. Zee Telefilms Ltd. v. Union of India, AIR 2005 SC 2677. 2 Constitution of India, art.53. 3 Constitution of India, art.79. 4 Constitution of India, art.85.

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provisions in the context of the Parliament. Further, “Privileges and Immunities” of the Parliament are dealt with under a separate head, as a specific provision.5 In light of principles mentioned above, a twofold assertion is made. Firstly, it is asserted that the role of the President in relation to the Executive is separate from him being a wing of the Parliament. Secondly, the summoning of Parliament by the President would not be construed as having been exercised as a privileged power of the Parliament but as a general administrative action. Thus, it is submitted that the President’s functions should be considered within the purview of “State” under Article 12 of the Constitution. The immunity under Article 361 does not apply to this petition. The President of India is immune from being answerable to any court in exercise of his official duties and functions as prescribed in law.6 The rationale being that such immunity does not extend beyond executive powers of the President under the Constitution, to actions made by him under a different capacity held by him ex officio. A distinction has to be drawn between the exercise of powers of the President under Part V, Chapter II and Part V, Chapter I of the Constitution.7 The former deals with the powers of the President to summon the Parliament in his capacity as the third wing of the Parliament.8 On the other hand, the latter deals with powers of the President in exercise of his functions as the Head of State of the Union of India. In light of the arguments advanced, it is urged that this immunity conferred vests only in relation to the executive acts of the President as the head of state and not as a wing of Parliament. Thus, in the instant matter the indefinite suspension of the Parliament would not be immune under Article 361(1) and liable to judicial scrutiny.

The Petitioners, Young Leaders Collective have locus standi to file this writ petition.

5

Constitution of India, arts. 105-106. Constitution of India, art.361. 7 Part V, Chapter I of the Constitution deals with the Executive, while Part V, Chapter II deals with the Parliament thereby, clearly demarcating their respective roles. 8 H.M. Seervai, Constitutional Law of India, 2145 (4th ed. 1993) - “We have adopted a model , for the President and the two houses to constitute the parliament. Other provisions to be noticed presently emphasize the fact that the functions discharged by the queen as a part of the legislature, are discharged by the president as the part of the legislature.” 6

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Locus standi demands that the fundamental right that has been allegedly violated must be vested with the Petitioner.9 The right of the citizen to know and receive information in matters of public concern has been read as a part of the right to freedom of speech and expression.10 There is a right to know vested in citizens qua affairs of determination of policy by the Government elected by them. The right has been given wider amplitude in relation to a Member of Parliament as Article 105(1) is not subject to limitations under Article 19(2).11 The Petitioners in W.P. 2006/2025 are members of Parliament in whom the right to know vests. Since they are members of parliament, such a right extends to the actions taken by the government in relation to the Port’s scam. This right has been violated by the indefinite deferral of the Parliament session. This right has to be considered of utmost importance as these members of Parliament are elected representatives who in turn have a responsibility towards the citizens that have elected them. Hence, it is asserted that the Petitioners have locus standi to file the present petition.

A WRIT DIRECTING THE CABINET TO CONSIDER THE JAN PAL BILL IS MAINTAINABLE The Union Cabinet is ‘State’ under Article 12. The Council of Ministers is established under the Constitution as a part of the Union of India.12 The Union Cabinet consists of ministers of Cabinet Rank appointed under Article 75 of the Constitution.13 It assumes central position of governance in a constitutional democracy because, it is the place where: (a) the final determination of the policy to be submitted to the Parliament is undertaken; (b) the supreme control of the national executive lies; (c) the balance of forces emerge if there is agreement.14 Therefore, the Cabinet exercises authority in the name of Government of India which is State for the purposes of Article 12. The Petitioner in the instant case has locus standi to file this writ petition 9

Director of Endowments v. Akram Ali, AIR 1956 SC 60. See Art.19(1) (a), Constitution of India; See State of U.P. v. Raj Narain, AIR 1975 SC 865; See also S. P. Gupta v. Union of India, AIR 1982 SC 149; People’s Union for Civil Liberties v. Union of India, (2003) 4 SCC 399. 11 See P.V.Narsimha Rao v. State (C.B.I./S.P.E), AIR 1998 SC 2120 at ¶26. 12 See Part V, Constitution of India. 13 See Constitution of India, art. 352(3). 14 R.K. Jain v. Union of India, (1993) 4 SCC 119 at ¶27. 10

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Any member of the public having sufficient interest can maintain an action for judicial redress for public injury arising from the breach of public duty or from violation of some provision of the Constitution or the law and seek enforcement of such public duty and observance of such constitutional or legal provision.15 In the instances related to corruption, the SC has stated that there exists locus standi keeping in mind that corruption does touch upon public interest. Corruption per se violates the principles enshrined as fundamental rights guaranteed by the Constitution of India. The Petitioner here seeks bona fide redressal from the Court as a public spirited citizen against the actions of the President and the Union Cabinet which prima facie indicate poor governance against corruption. This is tantamount to violation of Fundamental Rights. Thus, the Petitioner has locus standi in the present case.

2. THE PRESIDENT OF INDIA SHOULD BE DIRECTED TO SUMMON THE PARLIAMENTAT THE EARLIEST AND THE REPORT OF THE C.A.G. SHOULD BE TABLED. The Petitioner in W.P. 2006/2025 requests the Hon’ble Court to direct the President of India to summon the Parliament at the earliest and table the C.A.G. Report in relation to the Port’s Scam. The basis of this request is firstly, that the deferral of the Parliament substantially violates the right to know of the Petitioner established above. Secondly, under Article 151 the President is bound to produce the report in the Parliament and lastly, it is within the power of this Hon’ble Court to issue directions to the President.

FUNDAMENTAL RIGHTS OF THE YOUNG LEADERS COLLECTIVE HAS BEEN VIOLATED For seeking directions under Article 32, the Petitioner must possess the right allegedly infringed and have a direct and tangible interest.16 It has been established above that a greater 15

See S.P. Gupta v. Union of India, AIR 1982 SC 149; See also Bandhua Mukti Morcha v. Union of India, AIR 1984 SC 802; BALCO Employees‟ Union (Regd.) v. Union of India, (2002) 2 SCC 333. 16 Charanjit Lal Chowdhary v. Union of India, AIR 1951 SC 41 at ¶81.

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“right to know” vests in the Petitioners in the present case. 17 Non-summoning of the parliament in light of the present exigencies persisting in the country as well as the non-tabling of the CAG report are prima facie indicative of shirking off accountability before the Parliament. The allegations herein are against the President of India and a Union Cabinet Minister, who by virtue of the Constitution are accountable to the Parliament. Good governance principles empower Members of Parliament to seek reasons behind governmental actions. The deferral of the Parliamentary session is violative of the right to know of these Members which itself is the violation of the Constitution. THE PRESIDENT HAS ESCAPED FROM HIS DUTY TO TABLED CAG REPORT The Article 151 (1) states that “The reports of the Comptroller and Auditor-General of India relating to the accounts of the Union shall be submitted to the President, who shall cause them to be laid before each House of Parliament. As the Article clearly states that the reports relating to the accounts of Union is to be submitted to the President, who must place the same before each House of Parliament. In the present case the President has escaped from his duty as he did not presented the report before either House of Parliament which leads to the violation of the Constitution. THE SUPREME COURT CAN ISSUE A MANDMUS THE PRESIDENT TO SUMMON THE PARLIAMENT The President is constitutionally mandated to take an oath in the prescribed format. Under the said oath, a person, while assuming Presidency, swears to “preserve, protect and defend the Constitution and the law”.18 Therefore, non-summoning and non-tabling of the CAG report by the President is a direct contravention of this oath by which the Constitution binds the President. In the present fact situation the C.A.G. has alleged that losses have occurred due to misuse of discretionary powers bestowed upon the President to grant tax exemptions. The allegations also implicated a Union Minister. Moreover, the political parties sought impeachment proceedings against the President. Consequently, within two days of the revelations made by the C.A.G. the government indefinitely deferred the Parliament session due. The circumstances were sufficient for deliberations on accountability by the legislature. 17 18

See supra note 11 at p. 13 Constitution of India, art.60.

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Thus, a reasonable probability exists that the act of deferring the parliamentary session was done mala fide. Thus, in the present case, since there is dereliction of duty by the president as well as violation of fundamental rights, there exists necessary grounds for invoking the writ jurisdiction of the Supreme Court under Article 32 and appropriate directions may be given to the office of the President.

3. THE UNION CABINET MAY BE DIRECTED TO CONSIDER THE JAN PAL BILL AND IF IT IS NOT ACCEPTED THEN IT MAY BE PLACED BEFORE THE PARLIAMENT. The Union Cabinet should be directed to consider the Jan Pal Bill and in the event it is not accepted, the Bill should be placed before the Lok Sabha. Firstly, the drafting of a bill by the Government and its subsequent deliberation by the Cabinet is not a legislative function. Secondly, the Union Cabinet’s decision to not consider the Jan Pal Bill proposed by the Petitioner violates the principles of participatory democracy that have been read into the Constitution.

THE ‘CONSIDERATION’ OF A BILL BY THE UNION CABINET CONSTITUTES AN ‘EXECUTIVE FUNCTION’ THEREFORE, DIRECTIONS MAY BE ISSUED BY THE COURT. The term “legislative function” indicates the function of the legislature in laying down the law which will govern parties and transactions.19 It is a clear position of law that under its writ jurisdiction, the Supreme Court cannot issue directions to either the executive or the legislature while they perform legislative functions. However, regarding the introduction of bills, the legislative procedure is said to commence from the moment when the bill originates in either house of the parliament.20 Executive function on the other hand comprises the determination of governmental policy and then, the execution of the same. Inter alia, executive functions are

19 20

Gulabrao Keshavrao Dhole v. Pandurang, AIR 1957 Bombay 266. See Constitution of India, Part V.

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inclusive of the process of initiation of legislation.21 The process of initiation of legislation comprises all stages involved before a bill is placed on the floor of any house of the Parliament. Approval and consideration by the Union Cabinet is involved in the process of the initiation of legislation.22 Therefore, any directions issued to the Union Cabinet would be within the power of the Hon’ble Supreme Court. THE REJECTION OF THE VERSION PLACED BY THE PETITIONER VIOLATES THE PRINCIPLES OF PARTICIPATORY DEMOCRACY. The Constitution has embodied the principle of democracy as of the people, by the people, for the people. True democracy cannot be said to exist unless all citizens have a right to participate in the affairs of the polity of the country.23 Furthermore, participatory democracy has been read to be a part of our constitution.24 The scope of interpretation of the principles enshrined in the constitution may be expanded as to the requirement. This becomes more important where the Constitution is silent with respect to a lacuna in the law.25 Initiatives from publicly spirited citizens/bodies in the legislative processes have been accepted with regard to change in statutes. Precedents in foreign positions of law may be adopted for guidance in principle to supplement the lacunae in law. For instance the European Commission allows its citizens to take the initiative of inviting the former to submit proposals on matters where citizens consider there is need for an EU act in order to implement the Treaties. This allows the political system to be more responsive towards individual. In the same context it may be said that the involvement of interest based organizations in policymaking is not a novelty in India.26 It is submitted further that the non-consideration of the Petitioner’s draft by the Government violates his participation in effective policy-making. The draft merely forms a suggestive policy and is in no way binding upon the government. The government should therefore, at least consider the draft and put forth its suggestions before the Parliament. In the instant case, neither is the suggestions being considered by the Union Cabinet nor has the draft been placed before the Parliament for its independent deliberation. It is submitted therefore that the stand of 21

Ram Jawaya Kapur v. The State of Punjab, AIR 1955 SC 549 at ¶13. Manual of Parliamentary Procedures in the Government of India, ¶9.5 (2004). 23 Secretary, Ministry of Information and Broadcasting, Govt. of India v. Cricket Association of Bengal, AIR 1995 SC 1236. 24 Bhanumati v. State of Uttar Pradesh through its Principal Secretary, AIR 2010 SC 3796. 25 Durga Das Basu, Commentary on the Constitution of India, 4496 (8th ed. 2008). 26 People‟s Union for Civil Liberties v. Union of India, (2003) 4 SCC 399 22

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the Union Cabinet that no suggestions would be considered from the civil society violates the principles of participatory democracy. Further, IF THE CABINET DOES NOT ACCEPT THE JAN PAL BILL, THEN THE SAID DRAFT MAY BE LAID BEFORE THE LOK SABHA. In the scenario that the Government does not accept the bill in the pre-legislative stages, the aforementioned violations of Constitutional principles would persist. The purpose behind placing the bill for consideration before the Union Cabinet is to allow for suggestions as the latter may deem fit. However, the end of effective parliamentary democracy in the instant case can only be achieved through deliberation before the Parliament. Any draft tabled by the Union Cabinet is merely reflective of the legislative policy of the incumbent government. In the instant case, aspersions have been cast on the integrity of members of the Union Cabinet and thus, any legislative policy without involving all participants would be violative of the principles of participatory democracy as submitted above. It is imperative that the suggestions brought forth by the civil society need to be placed before the Parliament. It is submitted that although such directions may be without precedent, the Hon’ble Court has observed that the menace of corruption cannot be permitted to be hidden under the carpet of legal technicalities. 27 Therefore, the petitioner humbly requests this court to issue directions to table the draft Jan Pal Bill before the Lok Sabha if the Union Cabinet refuses to make the Bill a part of its legislative policy.

PRAYER In the light of the arguments advanced and authorities cited, the Petitioners humbly submit that the Hon’ble Court be pleased to adjudge and declare that: 1. Both the writ petitions being heard before this Hon’ble Court are maintainable. 27

Centre for Public Interest Litigation v. Union of India, AIR 2011 SC 1267.

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-MEMORIAL ON BEHALF OF PETITIONER2. The President of India should be directed to summon the Parliament at the earliest and

the report of the C.A.G. should be tabled. 3. The Union Cabinet may be directed to consider the Jan Pal Bill and in the event the former is not accepted then it may be placed before the Parliament.

And any other order that the Court may deem fit in the interests of equity, fairness and justice. For this act of kindness, the Appellants shall duty bound forever pray.

Sd./(Counsels for the Petitioners)

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