The Supreme Court of India

New Delhi, India

The 2015 Amity Moot Court Competition

________________________________________

Civil Appeal No. ____2015

(Section 135 of the Trademarks Act, 1999 read with Section 38 of the Specific Relief Act,
1963)

Arnob Murgwala Appellant

v.

Arnab Murgawala and Zoozle GmBH Respondent

________________________________________

Civil Appeal No. ____2015

(Section 53T of the Competition Act, 2002)

Arnob Murgwala Appellant

v.

Zoozle GmBH Respondent

________________________________________

Memorial for the appellant, 2015.

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 TABLE OF CONTENTS
Table of Contents ........................................................................................................................ i
Index of Authorities ................................................................................................................. iii
Statement of Jurisdiction........................................................................................................... iv
Issues Involved....................................................................................................................... viii
Summary of Arguments ............................................................................................................ ix
Arguments Advanced................................................................................................................. 1
I. The accused are guilty of abduction and murder of Reema and Riya, and the High Court
of Arya Pradesh erred in acquitting them .................................................................................. 1
A. The use of the AdVerba advertising scheme by Arnab is intended to deceive
consumers ............................................................................ Error! Bookmark not defined.
B. The defendant through this act is attempting to obtain economic benefit through the
reputation of the plaintiff ..................................................... Error! Bookmark not defined.
C. By using the trademark of Arnob through AdVerba advertising scheme, Arnab has
damaged the goodwill of the plaintiff’s business ................ Error! Bookmark not defined.
D. There is sufficient trade connection between the products of the plaintiff and the
defendant .............................................................................. Error! Bookmark not defined.
II. The use of the impugned keywords by the respondent amounts to trademark
infringement ............................................................................. Error! Bookmark not defined.
A. Arnob’s trademark is not invalid............................... Error! Bookmark not defined.
a) The registered trade mark of the appellant is protected under the proviso
contained in section 9 of the Trade Marks Act, 1999 ...... Error! Bookmark not defined.
b) The registers trade mark of the appellant is valid under sections 31 and 32 of the
Trade Marks Act, 1999 .................................................... Error! Bookmark not defined.
c) The appellant is entitled to the exclusive use of the mark ‘Murgwala’ .........Error!
Bookmark not defined.
B. Arnab used this trademark in the course of trade ...... Error! Bookmark not defined.
a) The conditions for use are the same as the conditions for use in the course of trade
Error! Bookmark not defined.
b) Assuming that the fact that any use was in the course of trade has to be proven
separately ......................................................................... Error! Bookmark not defined.
C. Arnab cannot use the defence of having used only part of the trademark .........Error!
Bookmark not defined.
a) The respondent is using the entire trademark, not part of it . Error! Bookmark not
defined.

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 b) Even if the respondent is held to be using only a part of the trademark, it is still a
violation ........................................................................... Error! Bookmark not defined.
D. Zoozle cannot use its defence of being merely a search engine and performing the
functions of a directory ........................................................ Error! Bookmark not defined.
E. This infringement is likely to cause confusion or cause the consumer to believe that
there is an association with the registered trademark .......... Error! Bookmark not defined.
III. Zoozle has entered into anti competitive agreements with the users of the AdVerba
scheme...................................................................................... Error! Bookmark not defined.
A. The agreement between Zoozle and users of the AdVerba scheme has an appreciable
adverse effect on competition .............................................. Error! Bookmark not defined.
a) Driving Existing Competitors out of the market ... Error! Bookmark not defined.
b) Creation of barriers to new entrants in the market Error! Bookmark not defined.
c) Ameliorating factors .............................................. Error! Bookmark not defined.
B. The agreement results in unfair competition ............. Error! Bookmark not defined.
IV. Zoozle abused its dominant position in the market ...... Error! Bookmark not defined.
A. The relevant market ................................................... Error! Bookmark not defined.
B. abuse of dominant position by denying competitors market access to the informant
Error! Bookmark not defined.
a) The market in the particular case of the informant is unique ..... Error! Bookmark
not defined.
b) Denial of market access ......................................... Error! Bookmark not defined.
C. Abuse of dominant position to enter into another relevant market Error! Bookmark
not defined.
Prayer for Relief ......................................................................................................................... 5

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 INDEX OF AUTHORITIES

Cases

Bahadur Ali v King Emperor AIR 1923 Lah 158. ..................................................................... 1

Hanuman Prasad v State of Rajasthan (2009) 1 SCC 507. ........................................................ 4
Kaini Rajan v State of Kerala (2013) 9 SCC 113. ..................................................................... 4
Madan Gopal Kakkad v Naval Dubey (1992) 3 SCC 204. ........................................................ 4
R v. Foster (1834) 6 C& c 325; 172 ER 1261. .......................................................................... 2
State of Uttar Pradesh v Chhoteylal (2011) 2 SCC 550............................................................. 4
Vishnu Narayan Moger V. State of Karnataka 1996 Cr. L.J 1121. ........................................... 1
Wahid Khan v State of Madhya Pradesh (2007) 11 SCC 265. .................................................. 4
Yogesh v State of Maharashtra AIR 2008 SC 2991. ................................................................. 3
Statutes

Indian Penal Code, 1860, Section 362. ...................................................................................... 1

The Indian Evidence Act, 1872, Section 3. ........................................................................... 2, 3
The Indian Penal Code, 1860, Section 34. ................................................................................. 4

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 STATEMENT OF JURISDICTION

I. Civil Appeal No. ____2015

The Appellant has approached this Honourable Court under Section 135 of the Trademarks
Act, 1999 read with Section 38 of the Specific Relief Act, 1963.

II. Civil Appeal No. ____/2015

The Appellant has approached this Honourable Court under Section 53T of the Competition
Act, 2002.

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 Statement of Facts

BACKGROUND

ZOOZLE GMBH

Zoozle GmBH is a multinational company headquartered in Berlin that operates an internet

search engine “http://www.zoozle.com”. The website enjoys great international presence and
is used by more than 80% of Indian internet users on a daily basis. The website works by
automatically generating an organic search list on the basis of queries entered into the search
toolbox by users. Zoozle claims to have no human interface in the generation of these search
results, and that they are arranged in order of relevance based on an algorithm.

THE RESTAURANTS

Murgwala’s Best Butter Chicken (MBBC) was established by Mr. Arvind Kejru Murgwala in
Delhi in 1959. In 1988, Mr. Arvind Kejru Murgwala passed away and left all his property to
his sons Mr. Arnob Murgwala and Mr. Arnab Murgwala. The amicable division of property
saw Mr. Arnob Murgwala taking control of the restaurant business. Its trademark was
registered in 1993, although it had been in use since 1959. Mr. Arnob also created a website
for MBBC “www.bestbutterchicken.com” which allowed prospective consumers to place
online orders for home delivery. He engaged in extensive offline advertising that was
recorded in the company’s financial statements for the year 2012-2013 as Rs. 1,00,00,000/-.
Mr. Arnab Murgwala founded the restaurant “Arnab’s Butter Chicken” (ABC) in the year
1990 in Kolkata, creating the website “www.arnabbutterchicken.com”. It too allows
customers to place orders for home delivery. Mr. Arnab opened an outlet of ABC in Delhi in
2007. He registered the trademark used by ABC in the year 2000.

THE DISPUTE

ADVERBA SCHEME

Zoozle developed a scheme of online advertising in the year 2011 for businesses or persons,
called “AdVerba”. This scheme involved the auction of certain keywords that when entered
as search queries by internet users on the website yielded hyperlinks and a description
thereof; which were chosen by the highest bidder. These hyperlinks were triggered in

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addition to the organic search list, and are separated from the same by being placed above the
same, separated by being highlighted in a light yellow colour having the words “Sponsored
Ads” being written alongside them. One of the terms of this agreement was that trademarks
cannot be used as keywords and that any such use would, pursuant to an investigation; result
in suspension of that keyword.

ALLEGED TRADEMARK INFRINGEMENT

Mr. Arnab entered into an agreement with Zoozle under its AdVerba scheme in 2012. He
bought certain keywords for use within Delhi and Kolkata, among which were “Arnab”,
“Best”, “Butter”, “Chicken” and frequently misspelt versions of the same. The suggested post
linked to Mr. Arnab’s website and the description added along with the link was “Better than
the Best Butter Chicken”. Aggrieved, Mr. Arnob wrote to the head office of Zoozle GmBH at
Berlin in July, 2012 and asked them to remove certain keywords that were his registered
trademarks. Zoozle responded by saying that they believed that the keywords belonging to
Arnob were simply part of the commons of the English language and hence could not be
regarded as his trademarks.

JUDICIAL TREATMENT

PETITION TO THE HIGH COURT

Mr. Arnob subsequently filed a suit in the Delhi High Court seeking permanent injunction
restraining Zoozle GmBH from using the words contained in his trademark as keywords, and
claiming infringement of his trademark and action for passing off. He also claimed that the
mark “Murgwala” and the goodwill associated with it belonged exclusively to him, with the
actions of Mr. Arnab amounted to an infringement of his trademark. In response, Mr. Arnab
claimed that the impugned keywords ought not to have been registered in the first place as
they were merely descriptive and counter sued for revocation of the mark. The Delhi High
Court clubbed the two cases filed together and in January 2014, found in favour of Mr. Arnab
through a common judgement. Mr. Arnob’s appeal before the Division Bench of the High
Court was dismissed at the admission stage itself.

COMPETITION COMMISSION

In November 2012, Mr. Arnob also filed an information in the Competition Commission of
India, alleging that the AdVerba advertisement scheme was an abuse of dominant position

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and that it entered into anti competitive agreements with the users of the programme, also
denying market access and restricting provision of services; resulting in the violation of
intellectual property rights, as had taken place in the case of the informant. In January 2012,
the CCI found that there was no contravention of the Competition Act and directed the matter
to be closed under Section 26(6) of the Act. In an appeal by Mr. Arnob before the
Competition Appellate Tribunal (COMPAT), the decision of the CCI was affirmed.

Mr. Arnob appealed the decision of the High Court before the Supreme Court of India, and
preferred to file a Statutory Appeal against the order of the COMPAT as well. The two
appeals were clubbed together and have been admitted. They have been listed for final
hearing. Hence the current appeal.

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 ISSUES INVOLVED

I.

Whether the use of the impugned keywords by Arnab under the AdVerba advertising scheme
amount to the tort of passing off?

II.

Whether Arnab and Zoozle through the use of the AdVerba scheme have infringed the
registered trade mark of the appellant?

III.

Whether the agreement entered into under the AdVerba scheme has an appreciable adverse
effect on competition?

IV.

Whether Zoozle abused its dominant position in the relevant market?

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 SUMMARY OF ARGUMENTS

I. THE USE OF THE IMPUGNED KEYWORDS BY THE RESPONDENT AMOUNTS TO THE TORT OF
PASSING OFF

For the tort of passing off four things need to be established, (i) intention to deceive, (ii)
attempt to obtain undue economic benefit and a misrepresentation which (iii) damages the
goodwill of the plaintiff. The purchase of the exact same words of the appellant’s registered
trade mark as keywords by the respondent indicate his intention to deceive consumers
regarding the origin of services. There also exists a high probability of confusion since both
of them are brothers. Through the use of the AdVerba advertising scheme the respondent has
tried to earn undue economic benefit by misrepresenting his services to be that of the
appellant and exploiting the goodwill of MBBC, which over a period of 56 years has become
extremely popular in Delhi, opened twenty five outlets, as well as undertaken extensive
promotional efforts within the city. Both parties also share sufficient trade connection, since
they provide similar services; which increases the likelihood of confusion.

II. THE USE OF THE IMPUGNED KEYWORDS BY THE RESPONDENT AMOUNTS TO TRADEMARK
INFRINGEMENT

A. Arnob’s trademark is not invalid

According to section 9, which lays down the grounds for refusal of registration of trademarks,
a trade mark cannot be refused registration if it has acquired a distinctive character as a result
of the use made of it. Mr. Arvind Kejru Murgwala established the fast food restaurant called
‘Murgwala’s Best Butter Chicken’ in Delhi in the year 1959 at Connaught place. It soon
became a very popular restaurant amongst the people of Delhi. Today it is not just a single
restaurant, but a chain with over twenty five outlets within Delhi. Though the expression
“Best Butter Chicken” can be construed as being generic and descriptive, the trade mark is not
limited to it. The surname of the appellant when used in the trade mark acts as the
distinguishing element which helps people to identify it solely with the business of the
appellant and not think of it as a generic term covering all restaurants which provide similar
services. The registered trade mark of the appellant is an arbitrary combination of seemingly
generic words, which has become distinctive. Also the length and manner of use, nature and
extent of advertising and promotion, efforts made to promote conscious connection in the
public's mind between the trademark and the business helps in establishing the distinctive

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character. The advertisement expenditure incurred by the appellant shows that this has also
been fulfilled.

B. Arnab used this trademark in the course of trade

There is no difference for the purposes of the Act between using a mark and using a mark in
the course of trade as per section 29. Section 29(6) speaks of the fact that a person uses a
trademark in the course of trade when he uses the registered trade mark on business papers or
in advertising. It is the appellant’s submission that this is the case. Even if we assume that
course of trade needs to be defined separately, we can use the definition given by Black’s
Law Dictionary – ‘what is customarily or ordinarily done in the management of trade or
business’. Moreover, cases have held that use of a trademark as a keyword is use in course of
trade.

C. Arnab cannot use the defence of having used only part of the trademark

The respondent is using the entire trademark, not part of it. Arnob’s trademark is being
infringed. ‘Murgwala’s Best Butter Chicken’ is the entire trademark of the appellant –
therefore, when a user enters that into Zoozle and gets Arnab’s website as a result, it isn’t a
part of Arnab’s trademark being infringed, but his entire trademark. The purchase of these
four keywords is without a doubt causing an infringement of Arnob’s complete trademark.
Even if the respondent is held to be using only a part of the trademark, it is still a violation.
This is because the separate parts of the keyword have each attained distinctive character.

D. Zoozle cannot use its defence of being merely a search engine and performing the
functions of a directory

Zoozle is not in this case performing merely the functions of a directory i.e. an entity with the
legal status of the intermediary. While intermediaries are exempt from liability, Zoozle is
voiding this exemption under multiple subsections of the IT Amendment Act.

E. This infringement is likely to cause confusion or cause the consumer to believe that
there is an association with the registered trademark

The mark of Arnab which because of its similarity to the registered trade mark of Arnob and
the identity or similarity of the goods or services covered by such registered trade mark is
likely to cause confusion on the part of the public, or which is likely to have an association
with the registered trade mark.

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 III. ZOOZLE HAS ENTERED INTO ANTI COMPETITIVE AGREEMENTS WITH THE USERS OF THE

ADVERBA SCHEME

Zoozle has entered into anti competitive agreements with users of its AdVerba scheme as
they have an appreciable adverse effect on competition; and they result in unfair competition
in the market. Firstly, agreements entered under this scheme have the effect of driving
existing competitors out of the market and crate barriers to new entrants in the same. As there
is no benefit accruing to consumers and there is no improvement in the provision of services
or promotion of technical and scientific development as a result of agreements under the
scheme, cannot avail the defence of ameliorating factors under Section 19(3) of the
Competition Act and is hence regarded to have an appreciable adverse effect on competition.
Hence, it is submitted that they are in violation of Section 3(4) of the same. Secondly, the
agreement results in unfair competition the action of exploiting the goodwill of a competitor
to further ones ends amounts to commercial immorality and is regarded as an unfair free
riding on the fame of well known works. Consequently, agreements entered into under the
scheme have deleterious effects on competition and are hence in contravention of the
Competition Act.

IV. ZOOZLE ABUSED ITS DOMINANT POSITION IN THE MARKET

It is submitted that Zoozle is dominant in the online search engine market and abuses this
position by attempting to enter another relevant market by leveraging its dominance, and by
denying access to the market to competitors. Firstly, Zoozle denied the informant market
access as it is in a unique position to provide access to the online market of home delivery of
food. The AdVerba scheme exploits this position to ensure that it is only the website of the
highest bidder that is most readily accessible by being placed at the top of the search result
list, effectively disallowing competitors in the same market from being visible as an option to
the customers. Secondly, Zoozle abuses this dominant position to enter another market, which
is that of online search advertising. Having entered into this market recently in 2011, Zoozle
is not a dominant player but is exploiting its position of dominance in the closely related
internet search engine market to attaining the same.

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 ARGUMENTS ADVANCED

II. THE ACCUSED ARE GUILTY OF ABDUCTION AND MURDER OF REEMA

AND RIYA, AND THE HIGH COURT OF ARYA PRADESH ERRED IN

ACQUITTING THEM.

Abduction says that if a person either by force compels a person or induces another person to go
from any place is said to abduct such person.1 Any person either by force has compelled or
induced any other person to go from any place irrespective of the age shall be booked with
abduction.2 [A]The accused are guilty of abduction in order to cause murder because they
used force and compulsion so as to abduct the person so that such persons may be murdered.
[B] The accused caused multifarious wounds and Mandibular fracture with the intention of
causing such bodily injury as is likely to cause death of the victims [C] The accused slit
throat and caused asphyxia due to manual strangulation which is so imminently dangerous
that it must in all probability cause death.

[A] THE ACCUSED ARE GUILTY OF ABDUCTION IN ORDER TO CAUSE

MURDER IN ORDER BECAUSE THEY USED FORCE AND COMPLUSION SO AS
TO ABDUCT PERSON SO THAT SUCH PERSONS MAY BE MURDERED.

The statement of the witness Mr. Krishna Das regarding the fateful night of the occurrence
clearly highlights the fact that there were four persons involved in the crime.3 As a matter of
fact all of them were wearing saffron dhotis, so it is reasonably deduced that were priests or
any other authority of a temple. Also the fact that there were two girls’ spreads light on the
issue that they were Reema and Riya. A witness is able to provide graphic account of the
attack on the deceased can be accepted as eye witness.4 As has been disposed by the witness
Mr. Krishna Das that he heard screams of two girls at night and saw four men wearing
saffron dhotis is a relevant fact because the fact though not in issue, are so connected with a

1
Indian Penal Code, 1860, Section 362.
2
Bahadur Ali v King Emperor AIR 1923 Lah 158.
3
Page 13, Annexure 4, Case Data.
4
Vishnu Narayan Moger V. State of Karnataka 1996 Cr. L.J 1121.

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fact in issue as to form part of the same transaction. And evidence can be given on a
relevant fact. Therefore this evidence is admissible as Res Gestae. 5 Therefore it can be
reasonably deduced that force and compulsion was used in order to take away the two
girls therefore attracting the liability of Abduction.

[B] THE ACCUSED CAUSED MULTIFARIOUS WOUNDS AND MANDIBULAR

FRACTURE WITH THE INTENTION OF CAUSING SUCH BODILY INJURY AS IS
LIKELY TO CAUSE DEATH OF THE VICTIMS.

The four accused that were present namely Pt. Bhanu s/o Pt. Kali Charan, Pt. Kalu s/o Pt.
Kali Charan, Pt. Bhawani s/o Shri Dhikari Chand Dubey, and Pt. Jagga brutally raped
Reema leading to her death and caused multifarious wounds with the help of Daraati which
was homicidal in nature.6 Also the Mandibular fracture, multiple fracture on both the arms of
Riya were caused by the two laathi’s which were recovered from the SUV, this is proved
because the blood stains on the laathi’s matches with those of the deceased. This SUV is
registered under the name of Jagga Ram.7 The doubt that the SUV of jagga ram was stolen is
just another part of the criminal conspiracy which was hatched by the five accused because
when the CBI came forward with its investigation report there were no evidences relating to
the whereabouts of Jagga Ram, so it is reasonable to infer that he was absconding. This being
a Fact in issue8 is admissible before the hon’ble court of law.

[C] THE ACCUSED SLIT THROAT AND CAUSED ASPHYXIA DUE TO MANUAL
STRANGULATION WHICH IS SO IMMINENTLY DANGEROUS THAT IT MUST
IN ALL PROBABILITY CAUSE DEATH.

The post mortem report of Riya reflects that the death was the result of asphyxia and the
cause of death shows manual strangulation which was fatal in nature.9 Also the post mortem
5
R v. Foster (1834) 6 C& c 325; 172 ER 1261.
6
Page 16, Annexure 6, Case Data.
7
Page 12, Annexure 3, Case Data.
8
The Indian Evidence Act, 1872, Section 3.
9
Page 2, Annexure 2-B, Case Data.

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report of Reema shows the cause of death as slitting of throat, multifarious stab wounds and
battering of face which are so imminently dangerous that they must in all probability would
have caused death. The fact that two Daraatis were recovered from the temple, they were
sufficient to cut a soft object like skin and a similar Daraati being recovered from pt. Kali
Charan is a relevant fact.10 These Facts highlight the criminal conspiracy that was hatched
between the mastermind Pt. Kali Charan and the other four accused. All the ingredients of
criminal conspiracy namely: There should be two or more persons, there should be an
agreement between themselves, the agreement should be to do an illegal act or a legal act by
illegal means is substantially fulfilled.11

Also the fact that Reema’s death was as a result of Intracranial Hematoma is a relevant fact
and therefore admissible. An intracranial hematoma is a collection of blood within the skull,
most commonly caused by rupture of a blood vessel within the brain or from trauma such as a
car accident or fall.12 This gives rise to a reasonable deduction as to how Reema’s body was
carried to the temple and was produced by Pt. Kali Charan so as to erase the suspicion of
doubt and in this carrying Reema suffered from Intracranial Hematoma.

Therefore all the five accused are liable to be convicted under Section 302, 364/34, 120 B,
Section 376-D of the Indian Penal Code, 1860.

III. ALL ACCUSED ARE GUILTY FOR COMMITTING RAPE OF RIYA.

All the accused are guilty of committing the offence of rape of Riya as Mr. Krishna Das has
disposed as a witness that he saw four men wearing saffron dhotis. Also all the ingredients
have been satisfied so as to constitute the offence of rape. [A] The accused had sexual
intercourse with Riya by penetration of penis or any other object (in this case a rod). [B] The
sexual intercourse was against her will and without her consent.

10
The Indian Evidence Act, 1872, Section 3.
11
Yogesh v State of Maharashtra AIR 2008 SC 2991.
12
Mayo Clinic Staff, Intracranical Hematoma, https://www.mayoclinic.org/diseases-conditions/intracranial-
hematoma/symptoms-causes/syc-20356145.

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[A] THE ACCUSED HAD SEXUAL INTERCOURSE WITH RIYA BY
PENETRATION OF PENIS OR ANY OTHER OBJECT (IN THIS CASE A
CYLINDRICAL ROD).

Sexual intercourse implies penetration to any extent, of the penis into vagina, mouth, urethra
or anus of a female.13 The depth of the penetration of penis is immaterial.14 The post mortem
report of Riya clearly indicates vaginal injuries which proved to be homicidal in nature
caused due to forceful penetration by more than two persons.15 The fact that four people were
present at the scene of the crime corroborate to this fact. Also the fact that a cylindrical rod
was inserted into the private part of Riya which has caused the hymnal tear into 3’0clock to
8’oclock in position. This also amounts to penetration and hence satisfies the first ingredient
of rape.

[B] THE SEXUAL INTERCOURSE WAS AGAINST HER WILL AND WITHOUT
HER CONSENT.

Against her will denotes that the rape was committed in spite of opposition of the person. 16
Consent means a voluntary act. Consent is an act of reason accompanied by deliberation.17
Here in the present case the element of free will and voluntary participation is absent on the
part of the victim which can be inferred from her screams and also from the several bruises
present on the right side of the neck as well various nail abrasions present on the neck 18 of the
dead body which highlights that not only the rape was committed against her will and without
her consent but also in a highly brutal manner. Also the presence of ligature marks
corroborate to this fact. Section 376D of the Indian Penal Code is attracted as it was a
concerted act. It is a joint liability of the accused as common intention19 pre-supposes prior
concert and meeting of minds of all persons constituting the group.20

13
Madan Gopal Kakkad v Naval Dubey (1992) 3 SCC 204.
14
Wahid Khan v State of Madhya Pradesh (2007) 11 SCC 265.
15
Page 10, Annexure 2-B, Case Data.
16
State of Uttar Pradesh v Chhoteylal (2011) 2 SCC 550.
17
Kaini Rajan v State of Kerala (2013) 9 SCC 113.
18
Page 10, Annexure 2-B, Case Data.
19
The Indian Penal Code, 1860, Section 34.
20
Hanuman Prasad v State of Rajasthan (2009) 1 SCC 507.

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 PRAYER FOR RELIEF

Wherefore in light of the Facts stated, Issues Involved, Arguments advanced, and Authorities
cited, CBI the Appellant, respectfully requests the Court to adjudge and declare that:

1- Prohibiting women of a particular age group from entering Lord Jogeshwara Temple
is violative of the Fundamental Rights enshrined under the Constitution of Indiana,
and the claim for the exclusion of women from religious worship founded in
religious text, is subordinate to the Constitutional values of Liberty, Dignity and
Equality.
2- The accused as guilty of abduction and murder of Reema and Riya.
3- All accused as guilty for committing rape of Riya.

And pass any other order as it deems fit in the interest of equity, justice and good conscience.

All of which is respectfully affirmed and submitted.

On behalf of the Appellant,

CBI.

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