Memorial for Petitioner

-MEMORIAL ON BEHALF OF PETITIONER-

ROLL 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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-MEMORIAL ON BEHALF OF PETITIONER

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)

BOOKS:

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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

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Parliament session be summoned immediately and the CAG report be made public

and tabled in 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.

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ISSUES RAISED

1. 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

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SUMMARY OF ARGUMENTS

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

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.

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of general and specific provisions. Summoning of the Parliament,4 is a part of the general

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.

4 Constitution of India, art.85.5 Constitution of India, arts. 105-106.6 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.”

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

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.

9 Director of Endowments v. Akram Ali, AIR 1956 SC 60.10 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.

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The Petitioner in the instant case has locus standi to file this writ petition

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

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.

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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

“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

16 Charanjit Lal Chowdhary v. Union of India, AIR 1951 SC 41 at ¶81.17 See supra note 11 at p. 1318 Constitution of India, art.60.

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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.

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

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

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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 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, 20 See Constitution of India, Part V.21 Ram Jawaya Kapur v. The State of Punjab, AIR 1955 SC 549 at ¶13.22 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

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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 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:

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

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1. Both the writ petitions being heard before this Hon’ble Court are maintainable.

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.

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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Documents

Memorial for Petitioner