Before

THE HON’BLE SUPREME COURT OF INDIA

AT NEW DELHI

Under Article 32 of the Constitution of India

W.P. (C) No._________ of 2020

IN THE MATTER OF:

MR.X…....…………..………………………………………………………………PETITIONER

Versus

THE UNION OF INDIA ………...…………………………………………………...

RESPONDENT

WRITTEN SUBMISSIONS ON BEHALF OF THE RESPONDENT

Drawn and filed by

Counsel on behalf of the Respondent

COUNSEL FOR THE RESPONDENT

SHIVANI JALUKA
SEMESTER: 10TH - B
ROLL: 595
MEMORIAL for RESPONDENT

TABLE OF CONTENTS

TABLE OF CONTENTS................................................................................................................2
INDEX OF ABBREVIATIONS........................................................................................................3
INDEX OF AUTHORITIES............................................................................................................4
i. Table of Cases 4
ii. Statues and Rules 4
iii. Books and Commentaries 4
iv. Online Resources 5
STATEMENT OF JURISDICTION.................................................................................................6
STATEMENT OF FACTS..............................................................................................................7
QUESTIONS PRESENTED............................................................................................................9
Issue 1: Wh eth er th e Petition is Main tain ab le? 9
Issue 2: Wh eth er th ere is violation of an y Fun d amen tal R igh ts of th e
Petition er? 9
SUMMARY OF PLEADINGS.......................................................................................................10
Issue 1: That the Petition is not Maintainab l e 10
Issue 2: That there is no violation of any Fundamental Rights of the Petitioner 10
PLEADINGS...............................................................................................................................11
Issue 1: That the Petition is not Maintainab l e. 11
1. It is most humbly and respectfully submitted before this Hon’ble Court that the
petition filed under Article 32 of the Constitution is not maintainable as there is no
violation of the fundamental rights by the Respondents. 11
1.1 Petitioner has no Locus Standi................................................................................11
1.2 No Violation of Fundament Rights.........................................................................11
1.3 Article 32 cannot be invoked to adjudge the validity of any Legislation................12
Issue 2: That there is no violatio n of the Fund amenta l
Rig hts of the Petitio ner 13
2.1 No Violation of Article 14 of the Constitution........................................................13
2.2 No Violation of Article 25 of the Constitution........................................................16
PRAYER....................................................................................................................................18

pg. 2
MEMORIAL for RESPONDENT

INDEX OF ABBREVIATIONS

& : And
AIR : All India Reporter
Art. : Article
Ed. : Edition
Hon’ble : Honorable
i.e. : That is
Ltd. : Limited
Mad : Madras
Ors. : Others
s. : Section
SC : Supreme Court
SCC : Supreme Court Cases
SCR : Supreme Court Reporter
U.P. : Uttar Pradesh
UOI : Union of India
v. : Versus

pg. 3
 MEMORIAL for RESPONDENT

INDEX OF AUTHORITIES

I. TABLE OF CASES

1. Ashutosh Gupta v. State of Rajasthan, (2002) 4 SCC 34 .......................................14, 15

2. BALCO Employees’ Union v. Union of India, (2002) 2 SCC 333............................... 12
3. Chiranjit Lal Chowdhury v. Union of India, AIR 1951 SC 41 …………………………..12
4. David John Hopkins v. Union of India, AIR 1997 Mad 366........................................ 16
5. Gauri Shankar v. Union of India, AIR 1995 SC 55...................................................... 14
6. Hindi Hitrakshak Samiti v. Union of India, AIR 1990 SC 851
…………………………..12
7. In Re Special Reference No.1 of 2012, (2012) 10 SCC 1............................................. 13
8. Janata Dal v. H.S. Chowdhary, AIR 1993 SC 892.......................................................11
9. K. Thimmappa v. Chairman, Central Board of Director, AIR 2001 SC 467 ………….14
10. Laxmi Khandsari v. State of Uttar Pradesh, AIR 1981 SC 873....................................14
11. M.G. Badappanavar v. State of Karnataka, AIR 2001 SC 260.....................................13
12. Maganbhai Ishwarbhai Patel v. Union of India, AIR 1969 SC 783..............................12
13. Parents’ Association v. Union of India, (2000) 2 SCC 657..........................................15
14. Parisons Agrotech (P) Ltd. v. Union of India, (2015) 9 SCC 6157..............................15
15. Ram Krishna Dalmia v. Justice S R Tendolkar, 1959 SCR 279...............................14,15
16. S.P. Gupta v. President of India, AIR 1982 SC 149......................................................11
17. S.R. Bommai v. Union of India, (1994) 3 SCC 1
…………………………………………..16
18. Shantabai v. State of Maharashtra, AIR 1958 SC 532..................................................12
19. State of Orissa v. Radheyshyam Meher & Ors., (1995) 1 SCC 652..............................12
20. Ugar Sugar Works Ltd. v. Delhi Administration, (2001) 3 SCC 635 …………………..12

II. STATUES AND RULES

 The Citizenship (Amendment) Act, 2019.

 The Citizenship Act, 1955
 The Constitution of India, 1950.

pg. 4
 MEMORIAL for RESPONDENT

III. BOOKS AND COMMENTARIES

 1 ARVIND P DATAR, COMMENTARY ON THE CONSTITUTION OF INDIA (2nd ed. 2010).

 1 DURGA DAS BASU, COMMENTARY ON THE CONSTITUTION OF INDIA (8th ed. 2007).
 2 DURGA DAS BASU, COMMENTARY ON THE CONSTITUTION OF INDIA (8th ed. 2007).
 M. P. JAIN, INDIAN CONSTITUTIONAL LAW (7th ed. 2016).

IV. ONLINE RESOURCES

1. www.manupatra.com
2. www.scconline.com

pg. 5
MEMORIAL for RESPONDENT

STATEMENT OF JURISDICTION

THE RESPONDENT MOST HUMBLY AND RESPECTFULLY SUBMITS THIS MEMORANDUM IN

RESPONSE TO THE PETITION FILED UNDER ARTICLE 321 OF THE CONSTITUTION OF INDIA.

1
Remedies for enforcement of rights conferred by this Part
(1) The right to move the Supreme Court by appropriate proceedings for the enforcement of the rights conferred
by this Part is guaranteed.
(2) The Supreme Court shall have power to issue directions or orders or writs, including writs in the nature of
habeas corpus, mandamus, prohibition, quo warranto and certiorari, whichever may be appropriate, for the
enforcement of any of the rights conferred by this Part
(3) Without prejudice to the powers conferred on the Supreme Court by clause ( 1 ) and ( 2 ), Parliament may
by law empower any other court to exercise within the local limits of its jurisdiction all or any of the powers
exercisable by the Supreme Court under clause ( 2 )
(4) The right guaranteed by this article shall not be suspended except as otherwise provided for by this
Constitution.

pg. 6
MEMORIAL for RESPONDENT

STATEMENT OF FACTS

1. In the exercise of power conferred under Section 18 of the Citizenship Act, 1955 the
respondent have promulgated the “Citizenship (Registration of Citizens and Issue of
National Identity Cards) Rules, 2003”. The Rule 3 and 4 of the Citizenship Rules,
2003 provides outline for the maintenance and preparation of National Register of
Citizens throughout the country.
2. During the verification process, particulars of such individuals, whose Citizenship is
doubtful, shall be entered by the Local Registrar with appropriate remark in the
Population Register for further enquiry and in case of doubtful Citizenship, the
individual or the family shall be informed in a specified proforma immediately after
the verification process is over.
3. The persons excluded from the National Register of Citizens in pursuant to Rule 4 of
the Citizenship Rules, 2003, have to finally represent the proceedings before the
Foreigner Tribunal in order to establish Citizenship of the person. A person declared
as Foreigner by the Tribunal shall result in detention at the detention center.
4. The Ministry Home Affairs, on 08.09.2015 published notification dated 07.09.2015
bearing number GSR 685(E) and GSR 686(E) and made an amendment in the
Passport (Entry into India) Rules, 1950 and Foreigners Order, 1948 and allowed entry
to persons belonging to minority communities in Bangladesh and Pakistan, namely,
Hindus, Sikhs, Buddhists, Jains, Parsis and Christians who were compelled to seek
shelter in India due to religious persecution or fear of religious persecution, who
entered into India on or before the 31st December, 2014 without valid documents.
5. Further on 18.07.2016, the Ministry of Home Affairs vide Notification No.GSR 702
(E) and 703(E) dated 18.07.2016 published in Gazette No. 495 and made an
amendment in the Passport (Entry into India) Rules, 1950 and Foreigners Order, 1948
substituted the word “Bangladesh”, for words “Afghanistan, Bangladesh”. 31.07.2019
6. The office of the Register of General Citizens and Registration issued notification in
pursuant to Rule 3(4) of Citizenship (Registration of Citizens and Issue of National
Identity Cards) Rules 2003, wherein the Central Government decided to prepare and
update the population Register between 1st April to 30th September 2020. 12.12.2019

pg. 7
MEMORIAL for RESPONDENT

7. The President gave its assent to the Citizenship (Amendment) Act, 2019 No.47 of
2019, wherein it amended the Section 2(1)(b) and amended clause is as follows:
“Provided that persons belonging to minority communities, namely, Hindus, Sikhs,
Buddhists, Jains, Parsis and Christians from Afghanistan, Bangladesh and Pakistan,
who have been exempted by the Central Government by or under clause (c) of sub-
section (2) of section 3 of the Passport (Entry into India) Act, 1920 or from the
application of the provisions of the Foreigners Act, 1946 or any order made
thereunder, shall not be treated as illegal migrants for the purposes of that Act.”

Hence, aggrieved by the Citizenship (Amendment) Act, 2019, the Petitioner moved
the Hon’ble Court on the ground that the Amending Act is arbitrary and biased against
the Muslim community.

pg. 8
MEMORIAL for RESPONDENT

QUESTIONS PRESENTED

ISSUE 1: W H E T H E R THE Petition is Main tain ab le?

ISSUE 2: W H E T H E R THERE IS VIOLATION OF ANY FUNDAMENTAL RIGHTS OF

THE PETITIONER?

pg. 9
MEMORIAL for RESPONDENT

SUMMARY OF PLEADINGS

ISSUE 1: T hat the Petitio n is not Maintai nab le

It is most humbly and respectfully submitted before the Hon’ble Court that the instant petition
is not maintainable. The violation of fundamental right is the sine qua non of the exercise of
the right under Article 32. The Petitioner’s fundamental right has not been violated at all by
the State as there is no fundamental right to claim citizenship of India. Furthermore, the
Petitioner have no locus standi in order to invoke Article 32 of the Constitution of India.

ISSUE 2: THAT THERE IS NO VIOLATION OF ANY FUNDAMENTAL RIGHTS OF THE

PETITIONER

It is most humbly and respectfully submitted before the Hon’ble Court that there has been no
violation of the Fundamental Rights by the Respondent. The classification made by the
Respondent is based upon intelligible differentia and has a reasonable nexus with the objects
of the Citizenship (Amendment) Act, 2019. Therefore the Amendment in no way violates
Article 14 of the Constitution of India. Furthermore, Article 25 guarantees the right to freely
profess, propagate and practice their religion. However, the enabling Act in no way violate
the intent and spirit of Article 25 of the Constitution.

pg. 10
MEMORIAL for RESPONDENT

PLEADINGS

ISSUE 1: T hat the Petitio n is not Maintai nab le.

1. It is most humbly and respectfully submitted before this Hon’ble Court that the petition
filed under Article 32 of the Constitution is not maintainable as there is no violation of
the fundamental rights by the Respondents.

1.1 PETITIONER HAS NO LOCUS STANDI.

2. In order to file a writ petition under Article 32 for violation of Fundamental Rights, one
should have a locus standi. The Supreme Court has observed that the requirement of
locus standi of a party to litigation is mandatory; because the legal capacity of the party
of any litigation whether in private or public action in relation to any specific remedy
sought for has to be primarily ascertained at the threshold. 2 Until the Petitioner shows
that his legal rights are adversely affected, or that breach is likely to be committed, he is
not entitled to file the petition.
3. The Supreme Court has laid down the principle in the case of S.P. Gupta v. President
of India.3 It observed that the traditional rule in regard to locus standi is that judicial
redress is available only to a person who has suffered a legal injury by reason of
violation of his legal rights or legally protected interest by the impugned action of the
state or a public authority or any other person who is likely to suffer a legal injury by
reason of threatened violation of his legal right or legally protected interest by any such
action. The basis of entitlement to judicial redress is personal injury to property, body,
mind or reputation arising from violation, actual or threatened, of legal right or legally
protected interest of the person seeking such redress.
4. In the present case the petitioner has no locus standi as no fundamental rights of the
Petitioner has been violated by the enactment of the Citizenship (Amendment) Act,
2019.

1.2 NO VIOLATION OF FUNDAMENT RIGHTS.

5. Art. 32 can be invoked only when there is an infringement of Fundamental Right. The
Supreme Court has laid emphasis on this aspect of Art. 32 as follows:
2
Janata Dal v. H.S. Chowdhary, AIR 1993 SC 892.
3
S.P. Gupta v. President of India, AIR 1982 SC 149.

pg. 11
MEMORIAL for RESPONDENT

“It is well settled that, jurisdiction conferred on the Supreme Court under Art. 32 is
an important and integral part of the Indian Constitution but violation of a Fundamental
Right is the sine qua non for seeking enforcement of those right by the Supreme Court. In
order to establish the violation of a Fundamental Right, the Court has to consider the
direct and inevitable consequences of the action which is sought to be remedied or the
guarantee of which is sought to be enforced.”4
6. The Supreme Court will issue a writ only at the instance of the party whose
fundamental rights are directly or substantially invaded or are in eminent danger of
being invaded.5 The original jurisdiction of the Supreme Court can be invoked in any
case of violation of fundamental rights guaranteed by Part II of the Constitution as has
been observed in the case of Chiranjit Lal Chowdhury v. Union of India6 amongst
many other.
7. However, in the present case there has been no violation of the fundamental rights of
the Petitioner as the distinction made by the legislation is based upon a reasonable
intelligible differentia and therefore does not violate Article 14 of the Constitution.

1.3 A R T I C L E 32 CANNOT BE INVOKED TO ADJUDGE THE VALIDITY

OF ANY LEGISLATION

8. In order to enforce a fundamental right, judicial review of administrative, legislative

and governmental action or non-action is permissible. But Article 32 cannot be invoked
simply to adjudge the validity of any legislation or any administrative action unless it
adversely affects Petitioner’s Fundamental Rights.7
9. Furthermore, Government policy in public interest overrides individual interest. 8 In the
case of Ugar Sugar Works Ltd. v. Delhi Administration,9 the court held that the courts
in exercise of their power of judicial review do not ordinarily interfere with the policy
decisions unless such policy framed could be faulted on the grounds of mala fide,
unreasonableness, arbitrariness, and unfairness etc. The courts are not expected to
express their opinion as to whether at a particular point of time or in a particular
situation any such policy should have been adopted or not.

4
Hindi Hitrakshak Samiti v. Union of India, AIR 1990 SC 851.
5
Maganbhai Ishwarbhai Patel v. Union of India, AIR 1969 SC 783.
6
Chiranjit Lal Chowdhury v. Union of India, AIR 1951 SC 41.
7
Shantabai v. State of Maharashtra, AIR 1958 SC 532.
8
State of Orissa v. Radheyshyam Meher & Ors., (1995) 1 SCC 652.
9
Ugar Sugar Works Ltd. v. Delhi Administration, (2001) 3 SCC 635.

pg. 12
MEMORIAL for RESPONDENT

10. In the case of BALCO Employees’ Union v. Union of India,10 it was held that it is
neither within the domain of the Courts nor the scope of the judicial review to embark
upon an enquiry as to whether a particular public policy is wise or whether a better
public policy can be evolved as suggested by the petitioner. Therefore the courts cannot
strike down a policy at the behest of the Petitioner merely because it has been urged that
a different policy would have been fairer or wiser or more scientific or more logical.
11. In the present case the Government by way of Section 2 of the Citizenship
(Amendment) Act, 2019 have included that the persons belonging to Hindu, Sikh,
Buddhist, Jain, Parsi or Christian community from Afghanistan, Bangladesh or Pakistan
who entered India before 31st of December 2014 and have suffered religious persecution
in these countries shall not be treated as illegal immigrants. This is a policy matter and
cannot be struck down by the court as unconstitutional merely because the Petitioners
contend that there may have been inclusion of more persecuted minorities or more
countries could have been made within the ambit of this Act.

ISSUE 2: T H A T THERE IS NO VIOLATION OF THE FUNDAMENTAL RIGHTS

OF THE PETITIONER

12. It is most humbly and respectfully submitted before this Hon’ble Court that the
Citizenship (Amendment) Act, 2019 does not violate any of the Fundamental Rights
provided under the Part III of the Constitution of India.

2. 1 NO VIOLATION OF A R T I C L E 14 OF THE CONSTITUTION.

13. It is humbly submitted before this Hon’ble Court that no discrimination has been caused
by the enactment of the Citizenship (Amendment) Act, 2019 and therefore it does not
violate Article 14 of the Constitution of India11.
14. Article 14 of the Constitution provides to all persons, citizens or non-citizens the
equality of status and opportunity referred to in the Preamble of our Constitution. 12
Equality is a basic feature of the Constitution of India and any treatment of equals
unequally or unequals as equal will be violation of the basic structure of the
Constitution of India.13 However, all persons are not equal by nature, attainment or
circumstances, and, therefore, a mechanical equality before the law may result in
10
BALCO Employees’ Union v. Union of India, (2002) 2 SCC 333.
11
Equality Before Law- The State shall not deny to any person equality before the law or the equal protection
of law within the territory of India.
12
In Re Special Reference No.1 of 2012, (2012) 10 SCC 1.
13
M.G. Badappanavar v. State of Karnataka, AIR 2001 SC 260.

pg. 13
MEMORIAL for RESPONDENT

injustice. The varying needs of different classes or sections of people require

differential and separate treatment. The Legislature therefore has the power to make
laws for separate sections of people, which are considered to be equal for the specified
purpose.
15. The principle of equality of law thus means not that the same law should apply to
everyone but that a law should deal alike with all in one class. The equals should not be
treated unlike, and unlikes should not be treated alike. Likes should be treated alike. 14
to apply the principle of equality in a practical manner, the courts have evolved the
principle that if the law in question is based on rational classification it is not regarded
as discriminatory.15 The courts have laid down the twin tests to determine whether a
classification is reasonable or not. These two tests are:
a. It should not be arbitrary, artificial or evasive. It should be based on an
intelligible differentia, some real and substantial distinction, which distinguishes
persons or things grouped together in the class from others left out of it;
b. The differentia adopted as the basis of classification must have a rational or
reasonable nexus with the object sought to be achieved by the statute in
question.16
16. There should be substantial basis for making the classification and that there should be
a nexus between the basis of classification and the object of the statute under
consideration. The Supreme Court in the case of K. Thimmappa v. Chairman, Central
Board of Directors,17 has observed as under:
“When a law is challenged to be discriminatory essentially on the ground that it
denies equal treatment or protection, the question for determination by the court is
not whether it has resulted in inequality but whether there is some difference which
bears a just and reasonable relation to the object of the legislation. Mere
differentiation or inequality of treatment does not per se amount to discrimination
within the inhibition of equal protection clause. To attract the operation of the clause
it is necessary to show that the selection or differentiation is unreasonable or
arbitrary, that it does not rest on any rational basis having regard to the object which
the legislature has in view.”

14
Gauri Shankar v. Union of India, AIR 1995 SC 55.
15
Ashutosh Gupta v. State of Rajasthan, (2002) 4 SCC 34.
16
Laxmi Khandsari v. State of Uttar Pradesh, AIR 1981 SC 873.
17
K. Thimmappa v. Chairman, Central Board of Director, AIR 2001 SC 467.

pg. 14
MEMORIAL for RESPONDENT

17. In the case of Ram Krishna Dalmia v. Justice S R Tendolkar,18the court laid down that
while Article 14 forbids class legislation, it does not forbid reasonable classification for
the purpose of legislation. Article 14 condemns discrimination not only by a substantive
law but also by a law of procedure.
18. Furthermore, when a person seeks to impeach the validity of a law on the ground that it
offends Article 14, the onus is on him to plead and prove the infirmity. The initial
presumption is in the favour of the validity of the law and the burden is upon him who
attacks it to show that there has been a clear transgression of the constitutional
principles. The presumption of constitutionality stems from the vide power of
classification which the legislature must, of necessity possess in making laws operating
differently as regards different groups of persons in order to give effect to policies.19
19. The Citizenship (Amendment) Act, 2019 has a historical background to it. The trans-
border migration of population has been happening continuously between the territories
of India and the areas presently comprised in Pakistan, Afghanistan and Bangladesh.
The constitutions of Pakistan, Bangladesh and Afghanistan provide for a specific state
religion. As a result, many persons belonging to Hindu, Sikh, Buddhist, Jain, Parsi and
Christian communities have faced persecution on grounds of religion in those countries.
The Citizenship (Amendment) Act, 2019 exempted the migrants from Hindu, Sikh,
Buddhist, Jain, Parsi or Christian Communities from Afghanistan, Pakistan and
Bangladesh who entered India before 31st of December 2014 and shall not be treated as
illegal immigrants under the Citizenship Act, 1955. The purpose of such amendment is
to enable acquisition of Indian Citizenship by members of minority communities
namely Hindus, Sikhs, Buddhists, Jains, Parsi and Christian from Afghanistan, Pakistan
and Bangladesh.
20. The classification made by the Government may be founded on different bases, namely,
geographical, or according to objects or occupations or the like.20 In the case of
Parents’ Association v. Union of India,21 the Supreme Court upheld the distinction
drawn between treatment of pre-1942 settlers and post-1942 settlers in Andaman &
Nicobar Islands by the Central Government on consideration of the historical
background. The same was held to be constitutional and not violative of Article 14.

18
Ram Krishna Dalmia v. Justice S R Tendolkar, 1959 SCR 279.
19
Supra note 15.
20
Supra note 18.
21
Parents’ Association v. Union of India, (2000) 2 SCC 657.

pg. 15
MEMORIAL for RESPONDENT

21. Further, in the case of Parisons Agrotech (P) Ltd. v. Union of India,22 the Court held
that once it is found that there is sufficient material for taking a particular policy
decision, bringing it within the four corners of Article 14 of the Constitution, power of
judicial review would not extend to determine the correctness of such a policy decision
or to indulge into the exercise of finding out whether there could be more appropriate or
better alternatives. It was held that the equality clause does not forbid geographical
units have a reasonable relation to the object sought to be achieved.
22. In the present case the Act have the reasonable object of facilitating the minor
communities who have faced religious persecution in the countries of Afghanistan,
Bangladesh and Pakistan and therefore reasonable nexus exists and the said
classification cannot be said to be violative of Article 14 of the Constitution.
Furthermore, in the case of David John Hopkins v. Union of India,23 the court has held
that the Government of India has “unrestricted power” to refuse citizenship without
assigning any reason whatsoever, as stated in Section 14(1) of the Citizenship Act, 1955
and that the illegal immigrants have no fundamental rights guaranteed for the grant of
citizenship of India. Citizenship cannot be given as a matter of right. It is not anybody’s
fundamental right. It is something that the nation and the country as a whole has to
decide based on the Constitution and other Acts made in pursuance of the power given
by the Constitution.

2. 2 NO VIOLATION OF A R T I C L E 25 OF THE CONSTITUTION

23. The framers of Constitution introduced the concept of secularism, meaning state
neutrality in the matters of religion. The Constitution seeks to ensure state neutrality in
the area of religion. In the case of S.R. Bommai v. Union of India,24 the Supreme Court
has held that secularism is a basic feature of the Constitution. Article 25 of the
Constitution guarantees to every person the freedom of conscience and the right to
freely profess, practice and propagate religion. However, the rights under Article 25 of
the Constitution is not absolute and subject to public order, moraity and health. The said
article only provides the protection of all persons or religious groups without any favour
or discrimination. The enabling provisions in the Act seeks to facilitate the specified
class of people to acquire citizenship and does not appear to violate the intent and spirit
of the Article.
22
Parisons Agrotech (P) Ltd. v. Union of India, (2015) 9 SCC 6157.
23
David John Hopkins v. Union of India, AIR 1997 Mad 366.
24
S.R. Bommai v. Union of India, (1994) 3 SCC 1.

pg. 16
MEMORIAL for RESPONDENT

24. The Citizenship (Amendment) Act, 2019 in no way affect the right of any person to
freely profess, practice and propagate any religion in the Country. The enabling
provisions of the Amending Act seeks to facilitate the specified class of people to
acquire citizenship and does not appear to violate the intent and spirit of Article 25.

pg. 17
MEMORIAL for RESPONDENT

PRAYER

Wherefore in the lights of facts stated, issues raised, arguments advanced and authorities
cited, this Hon’ble Court may graciously be pleased to adjudge and declare that:

1. THAT THE INSTANT PETITION IS NOT MAINTAINABLE.

2. THAT THE CITIZENSHIP (AMENDMENT) ACT, 2019 IS CONSTITUTIONALL VALID.

3. THAT THE PRESENT PUBLIC INTEREST LITIGATION BE DISMISSED.

And to pass any order that the Court may deem fit in the best interests of justice, equity
and good conscience.

All of which is respectfully submitted.

Counsel for the Respondent

S/D

pg. 18