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Team Code:
Team Code: FY- 01

COVID-19 INTRA-BATCH VIRTUAL MOOT COURT COMPETITION 2020

IN THE HON’BLE SUPREME COURT OF HINDUSTAN

PUBLIC INTEREST LITIGATION NO. ______/2019

MR. KALIKHO LAMA VS THE STATE OF MANTHANIR

(PETITIONER) (RESPONDENT)

AND

MINORITY COMMUNITIES VS REPUBLIC OF HINDUSTAN

(PETITIONER) (RESPONDENT)

PETITIONS FILED UNDER ARTICLE 136 AND 32

OF THE CONSTITUTION AND OTHER STATUTORY LAWS

OF THE REPUBLIC OF HINDUSTAN, 1950

HUMBLE SUBMISSION BEFORE THE HON’BLE CHIEF JUSTICE

AND HIS COMPANION JUDGES OF THE HON’BLE SUPREME COURT OF HINDUSTAN

MEMORIAL ON BEHALF OF THE RESPONDENT

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Table of Contents

List of Abbreviations 3

Index of Authorities 4-5

• Table of Contents 4

• Books, Websites, Statutes 5

Statement of Jurisdiction 6

Statement of Facts 7-8

Issues raised 9

Summary Of Arguments 10

Arguments Advanced : 11-14

Issue 01: whether the PIL filed by Mr. Kalikho Lama valid and maintainable before the 11-13
hon’ble apex court of Hindustan?

➢ [1.A] No exceptional and special circumstances exist and substantial justice has
been done in the present case
➢ [1.B] The Supreme Court should restrict itself to interfere in the decisions of the
High Court.
➢ [1.C] Article 14 is only applied when invidious discrimination is meted out.

Issue 02: Mandating a compulsory paper on Hindi language for all educational 14
institutions is a violation of the constitutional rights of the minority communities.

➢ [2.A] Government can regulate minority institutions:

➢ [2.B] Art. 351 is a reasonable regulation exercised by the govt. of Hindustan.

Prayer 15

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LIST OF ABBREVIATIONS

& And

A.P. Andhra Pradesh

AIR All India Report

Anr. Another

Art. Article

Corp. Corporation

Current LJ Current Law Journal

Ed. Edition

Govt. Government

HC High Court

Hon’ble Honorable

No. Number

Ors. Others

PIL Public Interest Litigation

SC Supreme Court

SCC Supreme Court Cases

Supp Supplementary

UP Uttar Pradesh

Vs. Versus

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INDEX OF AUTHORITIES

TABLE OF CASES:

1. T.M.A.Pai Foundation & Ors vs State Of Karnataka & Ors AIR 2002
2. The Ahmedabad St. Xaviers College ... vs State Of Gujarat & Anr AIR 1974
3. T.M.A. Pai Foundation & Ors vs State Of Karnataka & Ors AIR, 2002
4. T.M.A.Pai Foundation & ... vs State Of Karnataka & Ors.Etc.Etc AIR, 2002
5. Gaya Din (DEAD) through LR’s & Ors vs. Hanuman Prasad (DEAD) through LR’s
& Ors. (2001) 1 SCC 501.
6. Parry’s (Calcutta) Employees’ Union vs. Parry & Co. Ltd. & Ors., Air 1966 Cal. 31.
7. M.S. Narayanagouda v. Girijamma & Anr., AIR 1977 Kr. 58.
8. Kuldeep Singh v. The Commissioner of Police & Others, (1999) 2 SCC 10.
9. Ghurey Lal v. State of Uttar Pradesh, (2008) 10 SCC 450.
10. N. Suriyakala v. A. Mohandoss and Ors., (2007) 9 SCC 196.
11. Mathai & Joby v. George and Anr., (2010) 4 SCC 358: JT 2010 (3) SC 160: 2010 (2)
KLJ 382: 2010 (2) SCALE 172.
12. Kunhayammed v. State of Orissa, 2000 (6) SCC 359.
13. Chandra Singh v. State of Rajasthan, AIR 2003 SC 2889.
14. AIR 1950 SC 169.
15. Shivanand Gaurishankar Baswanti v. Laxmi Vishnu Textile Mills, (2008) 13 SCC
323, at page 347.
16. Pritam Singh v. State, AIR 1950 SC 169.
17. Council of Scientific and Industrial Research v. K. G. S. Bhatt, AIR 1989 SC 1972.
18. State of H. P. V. Kailash Chand Mahajan, AIR1992 SC 1277;
19. A.V. Papayya Sastry v. Government of Andhra Pradesh, AIR 2007 SC 1546.
20. Zahira Habibullah Sheikh v. State of Gujarat, AIR 2004 SC 3467.
21. AIR 2004 SC 4618.
22. AIR 2005 SC 15.
23. Union of India v. Era Educational Trust, AIR 2000 SC 1573.
24. DCM v. Union of India, AIR 1987 SC 2414.
25. Mehar Singh v. Shri Moni Gurudwara Prabandhak Committee, AIR 2000 SC 492.
26. Panchanan Misra v. Digambar Mishra, AIR 2005 SC 129.
27. Delhi Transport Corp. vs. D.T.C. Mazdoor Congress AIR 1990.
28. Bahadur Singh and Anr. vs Jaswant Raj Mehta And Ors. On 1 May, 1952.
29. Bhaiyalal v. Harikrishen singh, AIR 1965 SC 1557, 1560: (1965) 2SCR 877.
30. Abdul Rehman v. Pinto, AIR 1951 Hyd 11.
31. St. Xavier College vs. State of Gujrat, AIR 1974 SC 1389.
32. re Kerela Education Bill, Sidhrajbhai Vs. State Of Gujrat.
33. Uni Krishnan vs. State Of A.P.

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BOOKS:

1. Constitutional Law Of India, Dr. J.N. Pandey [2019 edition].

2. M P Jain Indian Constitutional Law [2018 edition].

3. The Indian Constitution: Cornerstone Of A Nation, Austin Granville [ 1999 edition].

4. Constitution Of India, V. N. Shukla [2019 edition].

5. Introduction To The Constitution Of India, Dr. D. D. Basu [2011 edition].

WEBSITES:

1. http://www.scconline.com

2. http://www.manupatrafast.com

3. http://www.findlaw.com

4. http://www.judis.nic.in

5. http://www.indiankanoon.com

STATUTES:

1. The Constitution of India, 1949.

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STATEMENT OF JURISDICTION

The petitioners have approached this Hon’ble Supreme Court of Hindustan under article 136¹

of the Indian Constitution Act, 1950 against the order of annulling the appointment of

teachers of Mordijas effective retrospectively since 15th may 2014 of the learned high court

of Manthanir under article 226² of the constitution of Hindustan and under article 32 against

the order of the govt. to mandate a compulsory paper of Hindi language in all the primary and

secondary educational institutions.

The Counsels for the Respondent most respectfully submit to this jurisdiction of the

Hon’ble Supreme Court.

1. Article 136: 136. Special leave to appeal by the Supreme Court

(1) Notwithstanding anything in this Chapter, the Supreme Court may, in its discretion, grant special leave to appeal from any judgment,
decree, determination, sentence or order in any cause or matter passed or made by any court or tribunal in the territory of India
(2) Nothing in clause ( 1 ) shall apply to any judgment, determination, sentence or order passed or made by any court or tribunal constituted
by or under any law relating to the Armed Forces
2. Article 226- Power of High Courts to issue certain writs
(1) Notwithstanding anything in Article 32 every High Court shall have powers, throughout the territories in relation to which it exercise
jurisdiction, to issue to any person or authority, including in appropriate cases, any Government, within those territories d irections, orders or
writs, including writs in the nature of habeas corpus, mandamus, prohibitions, quo warranto and certiorari, or any of them, for the
enforcement of any of the rights conferred by Part III and for any other purpose
(2) The power conferred by clause ( 1 ) to issue directions, orders or writs to any Government, authority or person may also be e xercised by
any High Court exercising jurisdiction in relation to the territories within which the cause of action, wholly or in part, arises for the exercise
of such power, notwithstanding that the seat of such Government or authority or the residence of such person is not within th ose territories
(3) Where any party against whom an interim order, whether by way of injunction or stay or in any other manner, is made on, or in any
proceedings relating to, a petition under clause ( 1 ), without
(a) Furnishing to such party copies of such petition and all documents in support of the plea for such interim order; and
(b) giving such party an opportunity of being heard, makes an application to the High Court for the vacation of such order and furnishes a
copy of such application to the party in whose favor such order has been made or the counsel of such party, the High Court sh all dispose of
the application within a period of two weeks from the date on which it is received or from the date on which the copy of such application is
so furnished, whichever is later, or where the High Court is closed on the last day of that period, before the expiry of the next day afterwards
on which the High Court is open; and if the application is not so disposed of, the interim order shall, on the expiry of that period, or, as the
case may be, the expiry of the aid next day, stand vacated
(4) The power conferred on a High Court by this article shall not be in derogation of the power conferred on the Supreme court by clause (
2 ) of Article 32

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STATEMENT OF FACTS

1) The Republic of Hindustan is a Union of States which has adopted its Constitution on
26th November 1949. The Constitution, being the supreme law of the land, seeks to
provide a proper amalgamation of provisions which makes it a sui generis.

2) As, per the demography of the nation Bindu Community is the majority community.

3) In the south-west region of Hindustan, Manthanir province is located, Jeroba being a

minority community of Manthanir province.

4) Jeroba community: It is a minority community of Manthanir province whose language is

BIHU. BIHU is written in devnagiri script as it does not have a script of its own. Jeroba
community curtailed the modern educational system and established their own institution
called Mordija [under article 30(1)¹]. For administration of these institutions “Mordija
Education Board” was constructed.

5) Mordija Education Board: - This being an educational institution based on minority

community receives aids from the govt. as per the law of the nation. This board
administers the functioning of Mordijas throughout the state of Manthanir. This board is
provided with high-degree of autonomy in the matters of appointment and administration
including the authority to decide the syllabus.

6) 23rd September 2019 :- The govt. of Manthanir passed an order, wherein it mandated
that teachers of all government funded educational institutions or the institutions which
receive financial aids or grants, are to be appointed by the government and have to meet
such criteria of appointment as govt. from time to time decides for maintaining the
standard of education. It contained a clause which was made effective retrospectively
from 15th May 2014, to annul the appointment of teachers of Mordijas which were made
without having regard for the qualifications prescribed by the govt.

¹Article 30(1): Rights of minorities to establish and administer educational institutions:

(1) All the minorities, whether based on religion or language, shall have the right to establish and administer
educational institutions of their choice.

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7) Mr Kalikho Lama (Petitioner):- He was appointed on 20th October 2016 as a teacher

of Mordija filed a Writ Petition in the nature of PIL in the Hon’ble HC of Manthanir,
claiming egregious violation of fundamental rights of the minority community by
providing 15th May 2014 as the cut-off date for giving the order retrospective effect is
horrendous and blatant violation of right to equality. The petitioner argued that giving
retrospective effect to govt. orders stipulating service rules is a disregard of the
judgments of Hon’ble Apex Court.

8) State of Manthanir (Respondent):- The Advocate General, while representing the State
contended that minority institutions cannot be given complete autonomy and the rights of
minorities ought not be secured at the cost of the quality of education. Mordijas being
government funded institutions; government has all the authority to regulate the
appointments to such institutions. Thus, govt. order enjoys a presumption of
constitutionality in its favor making the order valid. After hearing both the sides, the
High Court reserved its judgment.

9) Development of Hindi Language: - The Union govt. of Hindustan issued a slew of

directions under Article 351² of the Constitution mandating a compulsory paper on Hindi
language for all the primary and secondary educational institutions of the country so as to
promote and develop Hindi. This event witnessed a huge hullabaloo over the entire
nation.

10) Epilogue: Several minority communities filed PILs alleging severe violation of their
autonomy and constitutional rights. The Hon’ble Court clubbed all the petitions and
transferred the PIL of Mr Lama to itself and tagged it with all the clubbed matters as it
involved similar questions of law.

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ISSUES RAISED

»«»«»«»«»«»«»«»« Issue 01 »«»«»«»«»«»«»«»«

WHETHER THE PIL FILED BY MR. KALIKHO LAMA VALID AND
MAINTAINABLE BEFORE THE HON’BLE APEX COURT OF
HINDUSTAN?

»«»«»«»«»«»«»«»« Issue 02 »«»«»«»«»«»«»«»«

WHETHER MANDATING A COMPULSORY PAPER ON HINDI
LANGUAGE FOR ALL EDUCATIONAL INSTITUTIONS IS A
VIOLATION OF THE CONSTITUTIONAL RIGHTS OF THE MINORITY
COMMUNITIES?

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SUMMARY OF ARGUMENTS

ISSUE 01: WHETHER THE PIL FILED BY MR KALIKHO LAMA VALID AND
MAINTAINABLE BEFORE THE HON’BLE APEX COURT OF HINDUSTAN?

It is the humble submission of the Respondents that the Special Leave Petition against the
judgment of the Hon’ble High Court is not maintainable under Art. 136 empowers the
Supreme Court to grant in discretion Special Leave to Appeal from any judgment, decree,
determination, sentence or order in any cause or matter passed or made by any Court or
tribunal in the Union Of Hindustan¹. It is humbly submitted that the SLP is not maintainable
as Special Leave cannot be granted when [I.A] Substantial justice has been done and no
exceptional or special circumstances exist for case to be maintainable and [I.B] The Supreme
Court should restrict itself to interfere in the decisions of the High Court. [I.C] Article 14 is
only applied when invidious discrimination is meted out.

ISSUE 02:- WHETHER MANDATING A COMPULSORY PAPER ON HINDI

LANGUAGE FOR ALL EDUCATIONAL INSTITUTIONS IS A VIOLATION OF THE
CONSTITUTIONAL RIGHTS OF THE MINORITY COMMUNITIES?

It is most humbly contended by the counsel for the respondent that the slew of directions
passed by the Union Govt. of Hindustan under Art.351² of the Constitution mandating a
compulsory paper of Hindi language for all the primary and secondary educational
institutions of the country so as to promote and develop Hindi is not a patent error of law as it
does not violate the constitutional rights of the minority communities. As per the constitution
the rights enshrined gives the minority institutions³ full autonomy in running their institution
and mandating a compulsory paper of Hindi is valid and is not an unnecessary control
exercised by the govt. through various rules and regulations and hampering their progress of
quality education.

1. Art. 136 The Constitution Of Hindustan

2. Art. 351: Directive for development of the Hindi language It shall be the duty of the Union to promote the spread
of the Hindi language, to develop it so that it may serve as a medium of expression for all the elements of the
composite culture of India and to secure its enrichment by assimilating without interfering with its genius, the
forms, style and expressions used in Hindustani and in the other languages of India specified in the Eighth
Schedule, and by drawing, wherever necessary or desirable, for its vocabulary, primarily on Sanskrit and
secondarily on other languages PART XVIII EMERGENCY PROVISIONS
3. Art. 30 Right of minorities to establish and administer educational institutions
(1) All minorities, whether based on religion or language, shall have the right to establish and administer
educational institutions of their choice
(1A) In making any law providing for the compulsory acquisition of any property of an educational institution
established and administered by a minority, referred to in clause ( 1 ), the State shall ensure that the amount fixed
by or determined under such law for the acquisition of such property is such as would not restrict or abrogate the
right guaranteed under that clause
(2) The state shall not, in granting aid to educational institutions, discriminate against any educational institution
on the ground that it is under the management of a minority, whether based on religion or language
✓ T.M.A.Pai Foundation & Ors vs State Of Karnataka & Ors AIR 2002
✓ The Ahmedabad St. Xaviers College ... vs State Of Gujarat & Anr AIR 1974
✓ T.M.A. Pai Foundation & Ors vs State Of Karnataka & Ors AIR, 2002
✓ T.M.A.Pai Foundation & ... vs State Of Karnataka & Ors.Etc.Etc AIR, 2002

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ARGUMENTS ADVANCED

Issue 01: Whether the PIL filed by Mr Kalikho Lama valid and maintainable before the
Hon’ble Apex Court of Hindustan?

It is the humble submission of the Respondents that the Special Leave Petition against the
judgment of the Hon’ble High Court is not maintainable under Art. 136 empowers the
Supreme Court to grant in discretion Special Leave to Appeal from any judgment, decree,
determination, sentence or order in any cause or matter passed or made by any Court or
tribunal in the Union Of Hindustan. It is humbly submitted that the SLP is not maintainable
as Special Leave cannot be granted when [1.A] Substantial justice has been done and no
exceptional or special circumstances exist for case to be maintainable and [1.B] The Supreme
Court should restrict itself to interfere in the decisions of the High Court. [I.C] Article 14 is
only applied when invidious discrimination is meted out.

[1.A] No exceptional and special circumstances exist and substantial justice has been
done in the present case
It is most humbly submitted before this Hon’ble Court that the SC will not interfere with the
concurrent finding of the courts below unless of course the findings are perverse or vitiated
by error of law or there is gross miscarriage of justice¹. Art. 136 doesn’t confer a right of
appeal, but merely, a discretionary power to the SC to be exercised for satisfying the
demands of justice under exceptional circumstances².
The SC observed in the Pritam Singh v. State³,

In explaining how the discretion will be exercised generally in granting SLP. The wide
discretionary power with which this court is invested under it is to be exercised sparingly and
in exceptional cases only and as far as possible a more or less uniform standard should be
adopted in granting special leave in the wide range of matters which can come up before it
under Art. 1364. Circumspection and circumscription must induce the Court to interfere with
the decision under challenge only if the extraordinary flaws or grave injustice or other
recognized grounds are made out5.

1. Gaya Din (DEAD) through LR’s & Ors. v. Hanuman Prasad (DEAD) through LR’s & Ors., (2001) 1 SCC 501;
Parry’s (Calcutta) Employees’ Union v. Parry & Co. Ltd. & Ors., Air 1966 Cal. 31; M.S. Narayanagouda v.
Girijamma & Anr., AIR 1977 Kr. 58; Kuldeep Singh v. The Commissioner of Police & Others, (1999) 2 SCC 10;
Ghurey Lal v. State of Uttar Pradesh, (2008) 10 SCC 450.
2. N. Suriyakala v. A. Mohandoss and Ors., (2007) 9 SCC 196; Mathai@Joby v. George and Anr., (2010) 4 SCC
358: JT 2010 (3) SC 160: 2010 (2) KLJ 382: 2010 (2) SCALE 172; Kunhayammed v. State of Orissa, 2000 (6)
SCC 359; Chandra Singh v. State of Rajasthan, AIR 2003 SC 2889.
3. AIR 1950 SC 169.
4. Shivanand Gaurishankar Baswanti v. Laxmi Vishnu Textile Mills, (2008) 13 SCC 323, at page 347; Pritam Singh
v. State, AIR 1950 SC 169.

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Special leave will not be granted when there is no failure of justice or when substantial justice
is done, though the decision suffers from some legal errors5 although the power has been held
to be plenary, limitless6, adjunctive, and unassailable7.
In M. C. Mehta v. Union of India8 and Aero Traders Private Limited v. Ravinder Kumar
Suri9,
It was held that the powers under Article 136 should be exercised with caution and in
accordance with law and set legal principles.

[1.B] The Supreme Court should restrict itself to interfere in the decisions of the High
Court.

If it appears prima facie that the order in question cannot be justified by any judicial standard,
the ends of justice and the need to maintain judicial discipline require the Supreme Court to
intervene¹º ; the Supreme Court in this case pointed out the errors of the High Court, but, did
not interfere in the decision of the High Court. The Supreme Court does not interfere with the
conclusion arrived at by the High Court if it has taken all the relevant factors into
consideration and there has been no misapplication of the principles of law¹¹.
Normally, in exercising its jurisdiction under Article 136, the Supreme Court does not
interfere with the findings of the fact concurrently arrived at by the tribunal and the High
Court unless there is a clear error of law or unless some important piece of evidence has been
omitted from consideration¹².

Though Article 136 is conceived in widest terms, the practice of the Supreme Court is not to
interfere on questions of fact except in exceptional cases when the finding is such that it
shocks the conscience of the court¹³.
In the instant case, the Hon’ble High Court Of Manthanir was in a better position to adjudge
and appreciate the material facts and pass the order and in the present circumstances, the
order of the High Court should be upheld and should not be interfered in to.

5. Council of Scientific and Industrial Research v. K. G. S. Bhatt, AIR 1989 SC 1972; State of H. P. V. Kailash
Chand Mahajan, AIR1992 SC 1277; Mathai Joby v. George, (2010) 4 SCC 358.
6. A.V. Papayya Sastry v. Government of Andhra Pradesh, AIR 2007 SC 1546.
7. Zahira Habibullah Sheikh v. State of Gujarat, AIR 2004 SC 3467.
8. AIR 2004 SC 4618.
9. AIR 2005 SC 15.
10. Union of India v. Era Educational Trust, AIR 2000 SC 1573.
11. DCM v. Union of India, AIR 1987 SC 2414.
12. Mehar Singh v. Shri Moni Gurudwara Prabandhak Committee, AIR 2000 SC 492.
13. Panchanan Misra v. Digambar Mishra, AIR 2005 SC 129.

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[1.C] Article 14 is only applied when invidious discrimination is meted out.

As humbly submitted by the counsel for the respondent,

Art.1414 guarantees “equality before law” and “equal protection of law”.

The order passed by the state of Manthanir dated 23rd September 2019, wherein it mandated
that teachers of all government funded educational institutions or the institutions which
receive financial aids or grants, are to be appointed by the government and have to meet
such criteria of appointment as government from time to time decides for maintaining the
standard of education. It contained a clause which was made effective retrospectively from
15th May 2014, to annul the appointment of teachers of Mordijas which were made without
having regard for the qualifications prescribed by the government.

This order doesn’t qualify for ‘invidious discrimination’ as to establish a uniform educational
system and the termination of the appointment of the teachers is one of the ways for
establishing a uniform educational system. As written in the order the govt. from time to time
will decide the criteria of appointment, which could allow the teachers to apply for the jobs
and get appointed as per the latest order of the govt.

14. Art. 14 Equality before law The State shall not deny to any person equality before the law or the equal protection
of the laws within the territory of India Prohibition of discrimination on grounds of religion, race, caste, sex or
place of birth.
✓ Delhi Transport Corp. Vs. D.T.C. Mazdoor Congress AIR 1990.
✓ Bahadur Singh And Anr. vs Jaswant Raj Mehta And Ors. On 1 May, 1952
✓ Bhaiyalal v. Harikrishen singh, AIR 1965 SC 1557, 1560: (1965) 2SCR 877.
✓ Abdul Rehman v. Pinto, AIR 1951 Hyd 11.

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Issue 02:- Whether mandating a compulsory paper on Hindi language for all
educational institutions is a violation of the constitutional rights of the minority
communities?

It is most humbly contended by the counsel for the respondent that the slew of directions
passed by the Union Govt. of Hindustan under Art.351 of the Constitution mandating a
compulsory paper of Hindi language for all the primary and secondary educational
institutions of the country so as to promote and develop Hindi is not a patent error of law as it
does not violate the constitutional rights of the minority communities. As per the constitution
the rights enshrined gives the minority institutions full autonomy in running their institution
and mandating a compulsory paper of Hindi is valid and is not an unnecessary control
exercised by the govt. through various rules and regulations and hampering their progress of
quality education.

[2.A] Government can regulate minority institutions:

The right conferred on the religious and linguistic minorities to administer educational
institutions of their choice is not an absolute right. This right is not free from regulation just
as regulatory measures are necessary for maintaining educational character and ensuring
orderly, efficient and sound administration. The right to administer is not the right to
maladministration. The right to administer implies a correlative duty to good
administration15.
The constitution provides “through a regulation can be made to prevent maladministration 16
in a minority run educational institution but at the same time it has to be ensured that under
regulatory power nothing is done that would destroy the character of the institution as
institution. Art. 30(1) is extended to be real and effective and note a mere pious and abstract
sentiment.

[2.B] Art. 351 is a reasonable regulation exercised by the govt. of Hindustan.

In the light of promotion and development of the national language of the nation, the govt.
order mandated a compulsory paper in Hindi language in all the primary and secondary
educational institutions. Hindi language uses the same script as BIHU i.e. devnagiri. Taking
the script into consideration, it is not difficult for the students to appear. In addition to that
promoting the national language is not at all the violation of the constitutional rights of any of
the minority community as the govt. just mandated Hindi language to be a compulsory paper
which in no sense destroys the minority character of an institution. The minority communities
have the full autonomy to preserve their culture, language and scripts, although addition of
one more language in the curriculum for maintaining a uniform standard of education in the
whole country cannot be treated as a violation of autonomy and constitutionality.

1. St. Xavier College Vs. State of Gujrat, AIR 1974 SC 1389; re Kerela Education Bill, Sidhrajbhai Vs. State Of
Gujrat, Uni Krishnan Vs. State Of A.P.

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PRAYER

Wherefore in the light of the issues raised, arguments advanced, and authorities
cited may this hon’ble apex court be pleased to adjudge and declare:

1. That the petition filed by the petitioners stands dismissed;

2. That the decision of hon’ble high court of Mordija sustains i.e. all the teachers of
govt. and govt. funded schools are to be appointed by govt. and annul the appointment
of teachers of Mordijas effective retrospectively from 15th May 2014.

3. To mandate a compulsory paper of Hindi language in all the primary and secondary
schools of the union in order to promote and develop Hindi.

AND/ OR
To grant any other order in favour of the respondents which the Hon’ble Apex Court may
deem think fit in the eyes of Justice, Equity and Good Conscience.

All of which is respectfully submitted and for such act of kindness the Respondent shall
be duty bound to ever pray.

Place: Hindustan
Date: 12th June 2020
S/d-
(Counsel on behalf of the Respondent)

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