SYNOPSIS AND LIST OF DATES

The Petitioner Association is constrained to approach this

Honble Court by invoking Article 32 of the Constitution of India for the
protection of the fundamental rights guaranteed under Articles 14 and
21 of the Constitution of India of women lawyers practicing in the
Supreme Court of India to work at the Supreme Court of India with
dignity and without any gender bias. The present Petition is
necessitated due to the ignominy and the direct attack on the dignity
of women, especially women lawyers practicing in the Supreme Court
of India who have suffered due to the statements made and
publicized by two male lawyers, and specially the Respondent No. 1,
who regularly practice in the Supreme Court of India. The comments
made in the Documentary, Indias Daughter presented by BBC are
inhumane, scandalous, unjustifiable, biased, outrageous,

ill-minded

and are a direct affront to and in violation of the dignity of women,

especially the women practicing in the Supreme court of India. These
comments have caused a sense of insecurity, indignation and fear
amongst the female lawyers practicing in the Supreme Court of India.
LIST OF DATES
That on the dreadful night of 16 th of

16.12.2012
December

2012 the whole country went in shock when a

heinous incident of rape shook the entire
nation and raised a question on security and
safety of the women of this country.

7-8-2013

The Petitioner Association was registered

under the Societies Registration Act with
Registration No.S/ND/301/2013 with an aim
and object to promote the rights and welfare
of women and to support, protect and uphold
the status, interest, prestige and dignity of
women lawyers and to secure for them just
rights, privileges and status.

2015

That the documentary titled Indias Daughter

was

aired

by the

BBC

which

showed

interviews with the family members, friends of

the victim, accused and lawyers related to the
one of the most heinous crime this country
has witnessed till date which is popularly
known as Nirbhayas Case.

Respondent No.1 M L Sharma made the

following statements:
A female is just like a flower. It
gives good lookingvery softness
performance, pleasant. But on the
other hand, a man is like a thorn.
Strong, tough enough. The flower
always need(s) protection. If you put
that flower in a gutter, it is spoilt. If
you put that flower in a temple, it
will be worshipped.
.In our society we never allow our
girls to come out from the house after
6:30 or 7:30 or 8:30 in the evening
with any unknown person.
.They left our Indian culture. They
were under the imagination of the
film culture, in which they can do
anything.

.She should not be put on the

streets just like food. The lady, on
the other hand, you can say the girl
or woman, are more precious than a
gem, than a diamond. It is up to you
how you want to keep that diamond
in your hand. If you put your
diamond on the street, certainly the
dog will take it out. You cant stop
it.
..You are talking about man and
woman as friends. Sorry, that does
not have any place in our society. A
woman means, I immediately put the
sex in his eyes..

.We have the best culture. In our

culture, there is no place for a
woman.

Respondent No.2 A P Singh made the

following statements
.That

girl

was

with

some

unknown boy who took her on a

date.
.If

very

importantvery

necessary... She should go outside.

But she should go with their family
members like uncle, father, mother,
grandfather, grandmother, etc. etc.
She should not go in night hours with
her boyfriend.
.Singh is shown saying: If my
daughter or sister engaged in premarital

activities

and

disgraced

herself and allowed herself to lose

face and character by doing such
things, I would most certainly take
this sort of sister or daughter to my
farmhouse, and in front of my entire

family, I would put petrol on her and

set her alight. When asked at a later
point in the film if he stands by those
comments,

he

replies

that

he

Association

sent

does..
16-3-2015

The

Petitioner

representation to the Honble The Chief

Justice of India praying to take immediate
action in the matter

18-3-2015

Present Writ Petition filed.

IN THE SUPREME COURT OF INDIA

CIVIL ORIGINAL JURISDICTION
WRIT PETITION (CIVIL) NO.

OF 2015

[Under Article 32 of the Constitution of India]

BETWEEN:
Supreme Court Women Lawyer Association
Represented by its Secretary, having office at
47, Old Lawyers Chambers, Supreme Court
New Delhi
Petitioner

Versus
1 Manohar Lal Sharma, Advocate
Son of not known,
SCBA Member ship number S-0054
Residing at 31st Gyangudery
Vrindaben, Mathura, U.P.
Also having office at Library I, SCBA,
Supreme Court of India, New Delhi - 110001
2

A.P. Singh, Advocate

370, Deepali, Pitampuram
New Delhi
2 Chairperson, Gender Sensitization Committee
Supreme Court of India, New Delhi -110001
3 Registrar, Supreme Court of India
Supreme Court of India, New Delhi -110001
Contesting Respondents
WRIT PETITION UNDER ARTICLE 32 OF

THE CONSTITUTION OF INDIA

TO,
THE HONBLE CHIEF JUSTICE OF INDIA
AND HIS OTHER COMPANION JUDGES
OF THE HONBLE SUPREME COURT OF INDIA

THE HUMBLE PETITION OF PETITIONER ABOVE NAMED

MOST RESPECTFULLY SHOWETH:
1.

The Petitioner is an association registered under the Societies

Registration

Act,

1860.

The

Petitioner

Association

is

constrained to approach this Honble Court by invoking Article

32 of the Constitution of India for the protection of the
fundamental rights guaranteed under Articles 14 and 21 of the
Constitution of India of women lawyers practicing in the
Supreme Court of India to work at the Supreme Court of India
with dignity and without any gender bias. The present Petition is
necessitated due to the ignominy and the direct attack on the
dignity of women, especially women lawyers practicing in the
Supreme Court of India who have suffered due to the
statements made and publicized by two male lawyers, and

specially the Respondent No. 1, who regularly practice in the

Supreme Court of India. The comments made in the
Documentary, Indias Daughter presented by BBC are
inhumane,

scandalous,

unjustifiable,

biased,

outrageous,

ill-minded and are a direct affront to and in violation of the

dignity of women, especially the women practicing in the
Supreme court of India. These comments have caused a sense
of insecurity, indignation and fear amongst the female lawyers
practicing in the Supreme Court of India.
2.

The present Writ Petition under Article 32 of the Constitution of

India is being filed by the Petitioner Association above named.
The Petitioner is an Association registered under the Societies
Registration Act, 1860 on 07.08.2013 with an aim and object to
promote the rights and welfare of women and to support,
protect and uphold the status, interest, prestige and dignity of
women lawyers and to secure for them just rights, privileges
and status.

That Petitioner Association is represented by its

Secretary Ms. Prerna Kumari who is duly authorized by the

Petitioner No.1 Association

to swear the affidavit and

Vakalatnama on behalf of the Petitioner and to file the present

Writ Petition. That the Registration Certificate as well as the
Authorization Letter are placed along with the vakalatnama.
That the Petitioner states that they have not approached any

other authority seeking similar relief as has been sought in the

present Writ Petition. A true copy of the Rules and Regulations
of the Petitioner Association is annexed hereto as Annexure A
1 (pp.
2.

That the facts leading to the filing of the present Writ Petition before
this Honble Court are as follows:
a. That the documentary titled Indias Daughter was aired by
the BBC which showed interviews with the family
members,

friends of the victim, accused and lawyers

related to the one of the most heinous crime this country

has witnessed till date which is popularly known as
Nirbhayas Case.
b. That on the dreadful night of 16 th of December 2012 the
whole country went in shock when a heinous incident of
rape shook the entire nation and raised a question on
security and safety of the women of this country.
c. It is submitted that in the documentary the counsels
appearing for the accused persons have made various
unethical, inhumane and ill minded remarks towards the
female community as a whole. While making such
statements these counsels have completely forgotten that
they are the protectors of the justice and when law itself

doesnt differentiate between the male and female then

the ill remarks made by the Respondent No. 1 and
Respondent No. 2 shows that these respondents do not
have respect for any women of the society and do not see
them more than an object.
d. It is submitted that the Respondent No. 1 has made
following remarks towards the female society of the
country:i.

A female is just like a flower. It gives good looking

very softness performance, pleasant. But on the
other hand, a man is like a thorn. Strong, tough
enough. The flowers always need protection. If you
put that flower in a gutter, it is spoilt. If you put that
flower in a temple, it will be worshipped.

ii.

In our society we never allow our girls to come out

from the house after 6.30 or 7.30 or 8.30 in the
evening with any unknown person.

iii.

They left our Indian culture. They were under the

imagination of the film culture, in which they can do
anything.

iv.

She should not be put on the streets just like food.

The lady, on the other hand, you can say the girl
or woman, are precious than a gem, than a
diamond. It is up to you how you want to keep that
diamond in your hand. If you put your diamond on
the street, certainly the dog will take it out. You cant
stop it.

v.

You are talking about man and woman as friends.

Sorry that does not have place in our society. A
woman means, I immediately put the sex in his
eyes.

vi.

We have best culture. In our culture there is no

place for a woman.

The transcript of the Documentary is annexed herewith

and marked as Annexure A-2.
e.

It is submitted that the Respondent No. 2 has made the

following remarks against the female society of the
country:i.

That the girl was with some unknown boy who took her
on a date.

ii.

If very important... very necessary... she should go

outside. But she should go with their family members

like uncle, father, mother, grandfather, grandmother,
etc. etc. She should not go in night hours with her
boyfriend.
iii.

Singh is shown saying: If my daughter or sister

engaged in pre-marital activities and disgraced herself
and allowed herself to lose face and character

by

doing such things, I would most certainly take this sort

of sister or daughter to my farmhouse, and in front of
my entire family, I would put petrol on her and set her
alight. When asked at a later point in the film if he
stands by those comments, he replies that he does.
The excerpts from the documentary are annexed herewith
and marked as Annexure A-3
f.

That the Respondent No. 1 has made a remark that A

woman means, I immediately put the sex in his eyes
these ill words coming out from the so called savior of
justice unveils his real face and thoughts which he holds
for daughters, women and every citizen of our country.
The statement made by the Respondent No. 1 not only
shows that the respondent no. 1 is a man who has no
respect for the women of the country and treats them

nothing more than a piece of enjoyment for the men.

Such statements made by the respondent no. 1 are
atrocious,

mala

fide,

insensitive,

ill

minded

and

disrespectful towards every woman of the society.

g.

That the Respondent No. 1 in an interview to the news

channel named NewsLaundry has showed his true colors
and his ill mentality towards the female community. To
dismay of this noble profession where it is inculcated
inside every lawyer that every human being is equal
before the eyes of law and no discrimination shall be
made on the basis of gender, caste and creed, but the
respondent no. 1 forgetting all his legal knowledge and in
complete disregard for the constitutional safeguards and
protections given to the females has gone to extent
saying that the rape actually happens because of the
consent of the woman. The respondent no. 1 has
compared women to a box of sweets which when put
outside, every dog of the society is going to jump upon it.
He has even gone to the extent saying that every man
can commit rape if given opportunity. The statements
made by the Respondent No. 1 creates an atmosphere of
terror and insecurity among the female lawyers as they
apprehends that a person with such mentality freely

roams in the premises of Supreme Court. The transcript

of the interview conducted by the news channel
Newslaundry

is

hereby

annexed

and

marked

as

Annexure A-4.
h.

It is submitted that it is imperative to cull out the

unguarded and ill thoughts of Respondent No. 1 from his
above statements about women of our country which
unveils his real character in public. If one refers to the
derogatory and insulting words used by Mr. Sharma in his
statements to the international news agency it is clear that
according to him women should not be allowed to go out
after the time specified by him, they should have no
choice of choosing persons with whom they want to
spend time, they should not be allowed to be friends with
men, they should not be allowed live their life as per their
wish, i.e., women of our country shall be restrained from
even thinking of the word independent and individuality.
The statements coming from the practicing lawyer of the
highest Court of Country aired by international news
channel has maligned reputation of not only women in our
Country but has brought disrepute to the nation.

i.

It is submitted that `India is known for its rich heritage

culture and throughout the times women have been given

respect above all in the society. When giving an interview

to such a news agency Respondent No. 1 should have
discussed the real problems which women in our country
is facing due to bad law and order in some states and
with no stretch he should have blamed women for what
they are being subjected to by antisocial elements of our
society. Respondent No. 1 has not only humiliated the
dignity of women but has also stated that if occasion
arises every men of the country will commit rape. This ill
mentality of the protector of law and order shall be curbed
and a healthy and safe environment shall be made for the
women lawyers of the Honble Supreme Court.
j.

It is submitted that there is no doubt that we are in the

midst of a great revolution in the history of women. The
evidence is

everywhere;

the

voice

of

women

is

increasingly heard in Parliament, courts and in the

streets. While women in the West had to fight for over a
century to get some of their basic rights, like the right to
vote, the Constitution of India gave women equal rights
with men from the beginning.
k.

It is submitted that in the judgment of the Supreme Court

in Medha Kotwal Lele v. Union ofIndia & Others, rendered
by the Supreme Court on 19 October 2012 reported in

(2013) 1 SCC 297, the necessity of protecting women

from any form of indecency, indignity and disrespect in all
places (in their homes as well as outside), is emphasized
and it has been directed to provide new initiatives of
education and advancement of women and girls in all
spheres of life and the liberty was also granted in the said
judgment to approach the courts and the directions was
also given to the courts to effectively consider the
grievances raised in this regard.
l.

It is submitted that Regulation 7(2) of the Gender

Sensitization and Sexual Harassment of Women at the
Supreme Court of India (Prevention, Prohibition and
Redressal) Regulations, 2013 which apply to the
Supreme Court of India, also provides that gender
sensitization and orientation policies must be framed and
programmes be organized with these objectives. So, it is
imperative that the GSSH Committee must immediately
address this issue and take action against Mr. M. L.
Sharma and sensitize him towards the dignity and rights
of women.

m.

It is submitted that he has to scrupulously observe the

fundamental duty mandated in Article 51A (e) which cast
duty upon the citizen to desist from indulging in any act

which is derogatory to the dignity of women. Even a minor

misconduct militates against the fundamental foundation
of the public justice system.
n.

It is submitted that the Preamble to Chapter II of Bar

Council

of

India

Rules

regarding

Standards

of

Professional Conduct and Etiquette which states that "An

advocate shall, at all times, comport himself in a manner
befitting his status as an officer of the Court, a privileged
member of the community, and a gentleman, bearing in
mind that what may be lawful and moral for a person who
is not a member of the Bar, or for a member of the Bar in
his non-professional capacity may still be improper for an
advocate. Without prejudice to the generality of the
foregoing obligation, an advocate shall fearlessly uphold
the interests of his client and in his conduct conform to
the rules hereinafter mentioned both in letter and in spirit.
The rules hereinafter mentioned contain canons of
conduct and etiquette adopted as general guides; yet the
specific mention thereof shall not be construed as a
denial of the existence of others equally imperative
though not specifically mentioned. Therefore, social duty
is cast upon the legal profession to show the people the
light by his conduct and actions rather than being

adamant on an unwarranted and uncalled for issue. The

exploited masses of the people need a helping hand from
the legal profession, admittedly, acknowledged as a most
respectable profession. Advocates ought not to allow any
act by which a citizen could be deprived of his rights,
statutory as well as constitutional, only on account of their
exalted position conferred by law in the legal system
prevalent in the country. But the conduct of these lawyers
shows complete absence of any concern for society on
the one hand and utter disregard of the Constitutional
values and human rights of women besides the ethics
and etiquette of the Bar. It is much more than a crime.

We the women lawyers have every right to complain

about these abjectly degrading views and opinions which
enrage the women lawyers and defile the dignity of
women at our workplace. The Petitioner Association sent
a representation dated 16-3-2015 to the Honble CJI
requesting to take appropriate action. A true copy of the
representation dated 16-3-2015 sent by the Petitioner
Association is annexed hereto as Annexure A 5
2.

That the Petitioner has not filed any other similar Writ

Petition seeking similar reliefs before this Honble Court or

any other High Courts.
3.

That the Petitioner has got no other alternate or

efficacious remedy except to file the present Writ Petition
before this Hon'ble Court, by invoking Article 32 of the
Constitution of India. Petitioners are filing the present Writ
Petition, on the following amongst other Grounds without
prejudice to each other.
GROUNDS
A Because the Petitioner Association invokes the jurisdiction
of this Honble Court by invoking Article 32 of the
Constitution of India for the protection of the fundamental
rights guaranteed under Articles 14 and 21 of the
Constitution of India to women lawyers practicing in the
Supreme Court of India to work at the Supreme Court of
India with dignity and without any gender bias.
B Because the rights of the Petitioner and its constituent
members are directly violated due to the ignominy faced
by them, and the direct attack on the dignity of women,
especially women lawyers practicing in the Supreme Court
of India who have suffered due to the statements made
and publicized by two male lawyers, and specially the

Respondent No. 1, who regularly practices in the Supreme

Court of India.
C Because the comments made in the Documentary, Indias
Daughter presented by BBC by Respondents 1 & 2 are
inhumane, scandalous, unjustifiable, biased, outrageous,
ill minded and are a direct affront to and in violation of the
dignity of women under Articles 14, and 21 of the
Constitution of India, specially the women practicing in the
Supreme Court of India.
D Because these comments have caused a sense of
insecurity, indignation and fear amongst the female
lawyers practicing in the Supreme Court of India.
E Because the judgment of the Hon'ble Supreme Court in
Medha Kotwal Lele v. Union of India & Others, (2013) 1
SCC 297, emphasized on the necessity of protecting
women from any form of indecency, indignity and
disrespect in all places (in their homes as well as outside),
and it has been directed to provide new initiatives of
education and advancement of women and girls in all
spheres of life and the liberty was also granted in the said
judgment to approach the courts and the directions was

also given to the courts to effectively consider the

grievances raised in this regard.
F Because besides addressing particular sexual harassment
incidents, Regulation 7(2) of the Gender Sensitization and
Sexual Harassment of Women at the Supreme Court of
India (Prevention, Prohibition and Redressal) Regulations,
2013 which apply to the Supreme Court of India, also
provides that gender sensitisation and orientation policies
must be framed and programmes be organized with these
objectives.
G Because it is imperative that the GSSH Committee must
immediately address this issue and take action against the
Respondent No. 1 & 2, and specially against Respondent
No. 1, Mr. M. L. Sharma who regularly practices in the
Supreme Court of India, and sensitize him towards the
dignity and rights of women. Further, he must be required
to apologise publicly for holding and making public views
which are absolutely derogatory to the dignity of women.
As a member of legal fraternity, it is incumbent on the said
Committee which has been set up for this very purpose, to
sensitize him to issues of gender equality, and the
unacceptability of his presence in a workplace where such

views create an unsuitable environment for women to work

alongside him.
H Because the statements made by the Respondent No. 1 and
Respondent No. 2 are unethical, inhumane and ill minded.
I

Because the Respondent No. 1 and 2 are the protectors of

justice and this noble profession of advocacy has bestowed a
noble duty upon them to protect the interests of people of this
country without being prejudiced on the basis of gender. But by
showing utter disregard for the constitutional safeguards and
protections, the respondent no. 1 and 2 have put the Nation to
shame by making such remarks and statements.

J Because the remarks made by the Respondent No. 1 and 2

creates an atmosphere of terror among the female lawyers of
the Supreme Court as there is always an apprehension of
misbehaviour when persons of such mentality roams among
them in the premises of the Supreme Court.
K Because this Writ Petition has been filed for the enforcement of
the fundamental rights of working women under Articles 14, 19
and 21 and Article 51 of the Constitution of India. With the
increasing awareness and emphasis on gender justice,

the

Petitioner prays this Honble Court to safeguard against such

violations as there is an immediate and urgent need to protect

the dignity of the women lawyers practicing in this Honble

Court.
L Because the Constitution of India bestows upon the Courts of
the Country to safeguard the rights of the female employees
and to make every possible efforts to create healthy and safe
environment for the working of the females in the country.
M Because to safeguard the rights of the female community in the
atmosphere of terror where every female of the country is under
a grave apprehension of mishap and misbehave which can
result into anything worse shall be provided with a healthy and
safe environment for working and to create this atmosphere
one of the step is to restrict the entry of such ill minded and
unehthical human beings like the Respondent No. 1 and 2 in
the premises of the Supreme Court.
N Because the Constitution of India guarantees right to gender
equality to every women of the country under Article 14 and
right to live and right to dignity under Article 21 and casts duty
upon the courts of the country to take necessary steps to
protect them and ensure safety of woman at every cost.
O Because a social duty is cast upon the legal profession to show
the people the light by his conduct and actions rather than
being adamant on an unwarranted and uncalled for issue. The

exploited masses of the people need a helping hand from the

legal

profession,

admittedly,

acknowledged

as

most

respectable profession.
P Because the conduct of these lawyers shows complete
absence of any concern for society on the one hand and utter
disregard of the Constitutional values and human rights of
women besides the ethics and etiquette of the Bar. It is much
more than a crime.
PRAYER
Therefore, the Petitioner humbly prays that this Honble Court
be pleased to call for the records of the proceedings from the
Respondents and be pleased to:

a.

issue an appropriate writ, order or direction in the nature of

Mandamus directing the Registrar of the Honble Supreme Court to
pass an appropriate order restricting the entry of Respondent No. 1
and 2 within the premises of the Supreme Court of India;
b. issue an appropriate writ, order or direction in the nature of
Mandamus directing the GSSH Committee to and take action
against the Respondent

No. 1 & 2, and to sensitize him

towards the dignity and rights of women under Regulation 7(2)

of the Gender Sensitization and Sexual Harassment of Women

at the Supreme Court of India (Prevention, Prohibition and
Redressal) Regulations, 2013;
c. Direct the Respondent No. 1 & 2 to issue public apology to be
published widely in the media for holding and making public
views which are absolutely derogatory to the dignity of women,
and retracting the same;
d. Direct the Respondents No. 1 & 2 to retract the said statements
made and published in the documentary Indias Daughter and
intimating the Director and Producers of the same which must
be published at some prominent place in the said documentary;

e. Direct the Respondent No. 1 & 2 to refrain in future from issuing

any such public statement which is derogatory to women and is
a direct breach of their dignity ;

f. Direct the Registrar of the Honble Supreme Court to pass an

appropriate order restricting the entry of Respondent No. 1 and
2 within the premises of the Supreme Court of India under the
Regulation 7(2) of the Gender Sensitization and Sexual
Harassment of Women at the Supreme Court of India
(Prevention, Prohibition and Redressal) Regulations, 2013 ;

g.

Issue such other writ, Order or direction, as deemed fit by this

Hon'ble Court in the facts and the circumstances of the case in the
interest of justice.

AND FOR THIS ACT OF KINDNESS THE PETITIONER AS IN

DUTY BOUND SHALL EVER PRAY.
DRAWN & FILED BY

Mahalakshmi Pavani.
Advocate for the Petitioner
Drafted by Ms. Mahalakshmi Pavani
Advocate on Record
Settled by Ms. Vibha Datta Makhija
Senior Advocate
Supreme Court of India

DRAWN ON: 17.03.2015

FILED ON: 18.3.2015

IN THE SUPREME COURT OF INDIA

CIVIL ORIGINAL JURISDICTION
WRIT PETITION (CIVIL) NO.

OF 2015

[Under Article 32 of the Constitution of India]

IN THE MATTER OF :
Supreme Court Women Lawyer Association

Petitioner

Versus
Manohar Lal Sharma and ors

PAPER BOOK

Respondents

(For Detailed Index Kindly See Inside)

ADVOCATE FOR THE PETITIONER

MAHALAKSHMI PAVANI

INDEX
Sl.

Particulars

1. Listing Performa
2. Synopsis & List of Dates
3. Writ Petition with Affidavit
4. APPENDIX
Articles 14, 19, 21 and 51 of the Constitution of
India and Gender Sensitization and Sexual
Harassment of Women at the Supreme Court of
India (Prevention, Prohibition and Redressal)
Regulations, 2013 ;

5. Annexure P- 1

Page No.

A true copy of the Rules and Regulations

of the Petitioner Association

6. Annexure P- 2
A true copy of the Statement/Comments
made by Respondent No.1 dated nil

7. Annexure P- 3
A true copy of the Statement/Comments
made by Respondent No.2 dated nil

8. Annexure P- 4
A true copy of the representation dated
16-3-2015 sent by the Petitioner Association

IN THE SUPREME COURT OF INDIA

CIVIL ORIGINAL JURISDICTION
WP No.

of 2015

In the matter of
Supreme Court Women Lawyer Association

Petitioner

Versus
Manohar Lal Sharma and ors

Respondents

AFFIDAVIT
I Prerna Kumari, wife of Siddharth Singh, the Secretary of
the Petitioner Association having office at 47, Lawyers

Chambers Supreme Court of India, New Delhi 110 001, do

hereby solemnly affirm and sincerely state as follows:

I am the Secretary of the Petitioner Association in the

above Writ Petition and am well acquainted with the facts of

this case and as such competent to swear to this affidavit.
2

That I have read and understood the contents of the

accompanying List of Dates at pages

to

and paragraphs 1

of the Writ Petition and state that the facts stated therein

are true and correct to the best of my knowledge, belief and

information

obtained

from

social

networking

sites

and

documentary telecasted in BBC/youtube/TV channels and

Print media.

That the Annexures filed along with the Writ

Petition are true copies of the respective originals.

Verified at New Delhi on this the 18th day of March 2015

DEPONENT
VERIFICATION
I, Prerna Kumari, the Secretary of the Petitioner
Associationo.1 in the above Writ Petition do hereby declare

that the facts stated in paras 1 and 2 of this affidavit are true
and correct to the best of my knowledge and belief. No part of
it is false and nothing material has been concealed.
Verified at New Delhi on this the 18th day of March 2015

DEPONENT