UNIVERSITY LAW COLLEGE ALL INDIA MOOT COURT COMPETITION

31-P

IN THE HIGH COURT OF KAMAGRUHA

WP No. __________/2019

(Under Art. 226 of the Constitution of Raas Nagar)

STREE………………………………………………………………….…………….Petitioner

Versus

Union of Raas Nagar……………………………………………………………… Respondent

Clubbed with

WP No. __________/2019

(Under Art. 226 of the Constitution of Raas Nagar)

Maverick………………………………………………………………...……………Petitioner

Versus

Union of Raas Nagar……………………………………………………...…….. Respondent 1

State of Kamagruha………………………………………………………..……. Respondent 2

MEMORIAL SUBMITTED AND APPEARING ON BEHALF OF THE PETITIONER

 TABLE OF CONTENTS

TABLE OF CONTENTS………………………………………………………………….….I

TABLE OF ABBREVIATIONS…………………………………………………...………III

INDEX OF AUTHORITIES……………………………………………………….………IV

STATEMENT OF JURISDICTION…………………………………………………….VIII

STATEMENT OF FACTS……………………………………………………………...….IX

STATEMENT OF ISSUES……………………………………………………………….....X

SUMMARY OF ISSUES…………………………………………………………………...XI

ARGUMENTS ADVANCED………………………………………………………………..1

I. WHETHER THE PETITIONS ARE MAINTAINABLE……………..…………………..1

A. The Regulation of Prostitution Act, 2019, is violative of the Fundamental Rights…...1

B. Alternative remedy is no bar…………………………………………………………..2

C. The petitioner has Locus Standi to approach the court………………………………..3

II. WHETHER THE PROCEDURES PRESCRIBED IN THE ACT ARE

CONSTITUTIONAL (CONTENTIONS OF MAVERICK)………………………………3

A. The obligation to register as provided for in s. 11 of the Act violates Art. 19(1)(g) of

the Constitution as the restriction is not reasonable…………………………………….3

B. The provision relating to compulsory CCTV Surveillance is violative of the right to

personal liberty as provided for in Art 21 of the Constitution…………………………..5

C. The blanket ban of advertisement of commercial sexual services on Radio, Cinema and

Print media is violative of Art 14 of the Constitution…………………………………..6

I
 D. Seeking certain guidelines regarding working conditions, minimum wage and working

hours…………………………………………………………………………………...8

III. WHETHER THE REGULATION OF PROSTITUTION ACT 2019 IS

CONSTITUTIONAL (CONTENTIONS OF STREE)………………………………….....9

A. The Act violates Art. 14 of the Constitution……………………………………………9

B. The Act violates Art. 21 of the Constitution…………………………………………..11

C. The Act violates Art. 25 of the Constitution…………………………………………..14

PRAYER…………………………………………………………………………………...XII

II
 TABLE OF ABBREVIATIONS

1. &……………………………………………………………………..……………..And
2. AIR…………………………………………………………………. All India Reporter
3. Art……………………………………………………………………………… Article
4. Commr………………………………………………………………….. Commissioner
5. Edn …………………………………………………………………………….. Edition
6. Ors ……………………………………………………………………………….. Other
7. P ………………………………………………………………………………….. Page
8. SC ……………………………………………………………………... Supreme Court
9. SCC ………………………………………………………..……. Supreme Court Cases
10. SCR ………………………………………………………….. Supreme Court Reporter
11. Sec, S……………………………………………………………………...…… Section
12. V ………………………………………………………………………………...Versus
13. Vol ………………………………………………………………………..…… Volume

III
 INDEX OF AUTHORITIES

CASES

A.V. Venkateshwaran v. Ramchand Sobhraj Wadhwani, AIR 1961 SC 1506 ......................... 2

Abbas K.A. v. Union of India, AIR 1971 SC 481 .................................................................... 5

Ashok Lenka v. Rishi Dikshit, AIR 2006 SC 2382 ................................................................. 13

Atulya Kumar De v. Director, AIR 1953 CAL 548 ................................................................... 2

Bandhua Mukti Morcha v. Union of India, (1997) 10 SCC 549 ............................................. 13

Budhadev Karmakar v. State of West Bengal, (2013) 1 SCC 294 .......................................... 11

Chiranjit Lal v. Union of India, (1950) SCR 869 (879)........................................................... 10

Commr. Hindu Religious Endowment v. Sri Lakshmindra Thirtha Swamiar of Sri Shirur Mutt
AIR 1954 SC 282 ................................................................................................................. 14

Dist. Registrar and Collector v. Canara Bank, AIR 2005 SC 186 ............................................. 5

Dwarka Prasad v. State of UP, AIR 1954 SC 224 ..................................................................... 4

Francis Coralie Mullin v. Union Territory, AIR 1981 SC 746 .................................................. 5

Gaurav Jain v. Union of India, AIR 1997 SC 3021 ................................................................. 15

Harbansal Sahnia v. Indian Oil Corpn. Ltd, (2003) 2 SCC 107 ................................................ 2

Harishankar Bagla v. State of MP, AIR 1954 SC 465 ............................................................... 4

Himmatlal v. State of Madhya Pradesh, AIR 1954 SC 403....................................................... 2

Hyde v. Hyde, (1866) 1 P&M ................................................................................................. 15

Inderjeet v. State of UP, AIR 1979 SC 1867 ............................................................................. 5

Ismail Farooqui v. Union of India, (1994) 6 SCC 360 ............................................................ 13

John Vallamattom v. Union of India, AIR 2003 SC 611 ........................................................... 6

K S Puttaswamy v. Union of India, (2017) 10 SCC 1 ......................................................... 5, 12

Kallakkurichi Taluk Retired Officials Assn. v. State of T.N, (2013) 2 SCC 772...................... 9

Karimbil Kunhikonam v. State of Kerala, AIR 1962 SC 723 ................................................... 6

IV
Kedar Nath Bajoria v. State of W.B, AIR 1953 SC 404. ........................................................... 9

Kharak Singh v. State of UP, AIR 1963 SC 2178 ..................................................................... 6

Krishan Kumar Narula v. State of Jammu and Kashmir, AIR 1967 SC 1368, 1371 ................. 4

M.R.F. Ltd. v. Inspector, Kerala Govt, (1998) 3 SCC 709 ........................................................ 7

M/s Baburam Prakash Chandra Maheshwari v. Antarim Zila Parishad, AIR 1969 SC 556 ..... 2

Maneka Gandhi v. Union of India, AIR 1978 SC 597............................................................... 5

National Legal Services Authority v. Union of India, (2014) 5 SCC 438 ................................. 9

Occupational Health & Safety Association v. Union of India, AIR 2014 SC 1469 ................ 12

Olga Tellis v. Bombay Municipal Corporation, AIR 1986 SC 180........................................... 8

Parkash Singh and others v. Union of India, (2006) 8 SCC 1 ................................................... 8

Railway Board v. Chandrima Das, AIR 2000 SC 988 ............................................................... 2

Raj Bahadur v. Legal Remembrancer, AIR 1953 CAL 522 .................................................... 10

Ram Prasad v. State of Bihar, (1953) SCR 1129 ..................................................................... 10

Rustom Cavasjee Cooper v. Union of India, AIR 1970 SC 564................................................ 5

Salil Sabhlok v. Union of India, 2011 SCCOnline P&H 10362 ................................................ 8

Seema Silks and Sarees v. Directorate of Enforcement, AIR 2008 SC 2564 ............................ 9

Seshammal v. State of T.N., AIR 1972 SC 1586 ..................................................................... 14

SMD Kiran Pasha v. Govt of AP, (1990) 1 SCC 328 ................................................................ 3

Sodan Singh v. New Delhi Municipal Committee, AIR 1989 SC 1988, 1999 .......................... 4

State of Bihar v. Bihar State Plus-2 Lecturers’ Association, AIR 2007 SC 1948 .................... 9

State of Bombay v. RMD Chamarbaugwala, AIR 1957 SC 699 ............................................... 4

State of Maharashtra v. Indian Hotel and Restaurant Association, (2013) 8 SCC 519 ............. 7

State of Maharashtra v. Madhukar Narayan Mardikar, AIR 1991 SC 207.............................. 12

State of Maharashtra v. Nagpur Distillers, Nagpur, AIR 2006 SC 1987 ................................. 13

State of MP v. Baldeo Prasad, AIR 1961 SC 293 ...................................................................... 5

V
State of Orissa v. Ram Chandra Dev, AIR 1964 SC 685 .......................................................... 3

State of UP v. Indian Hume Pipe Co., AIR 1977 SC 1132 ....................................................... 2

State of UP v. Kartar Singh, AIR 1964 SC 1135 ....................................................................... 4

State of Uttaranchal v. Balwant Singh Chaufal, (2010) 3 SCC 402 .......................................... 8

State of West Bengal v. Anwar Ali Sarkar, AIR 1952 SC 75 ............................................. 6, 10

Suraj Mall Mohta & Co. v. A.V. Vishvanath Sastri, AIR 1954 SC 545 .................................. 6

Syedna Taher Saifuddin Saheb v. State of Bombay, AIR 1962 SC 853 ................................. 14

T.N. Electricity Board v. Sumathi, AIR 2000 SC 1603 ............................................................. 2

Tata Press Ltd. v. Mahanagar Telephone Nigam Ltd, AIR 1995 SC 2438 ............................... 7

Vishakha v. State of Rajasthan, (1997) 6 SCC 241 ................................................................... 8

BOOKS REFERRED

1. Commentary on the Constitution of India, 10th Edition by P.K. Majumdar and R.P. Kataria

2. Commentary on the Constitution of India, 9th Edition by Durga Das Basu

3. Hindu Law, 22nd Edition by Sir Dinshaw Fardunji Mulla

4. Laws Relating to Woman and Children, 4th Edition by Mamta Rao

5. Mayne’s Hindu Law and Usage, 15th Edition

6. Modern Hindu Law by Dr. Paras Diwan

7. Muslim Law in Modern India by Dr. Paras Diwan

8. Principles of Mahomedan Law, 20th Edition by Sir Dinshaw Fardunji Mulla

9. Shorter Constitution of India by Durga Das Basu, Volume 1 (15th Edition, 2018)

10. V.N. Shukla’s Constitution of India, 13th Edition

VI
 ARTICLES REFERRED

1. 64th Report of the Law Commission of India on the Suppression of Immoral Traffic in

Woman and Girls Act, 1956.

2. Anita Shenoy and Elizabeth Thomas, Prostitution, sex work and law reform, 6 Stud Adv

(1994) 25

3. Ashray Behura. Decriminalization of Sex work: An international Human Rights Law

Appraisal, 4th KIIT Law Review, 2017

4. Joint United Nations Programme on HIV/AIDS (UNAIDS) 2009-2012

5. Kavitha Kumar and Gunjan Ghosh, Prostitution and Human Rights, 7 Stud Adv (1995) 106

6. Violations faced by Sex Workers in India Joint Stakeholders Submission Special

Rapporteur on Violence Against Women (SR-VAW) on Conflation of Sex Work and

Trafficking

WEBSITES REFERRED

1. Manupatra Online Resources, http://www.manupatra.com.

2. Lexis Nexis Academica, http://www.lexisnexis.com/academica.

3. Lexis Nexis Legal, http://www.lexisnexis.com/in/legal.

4. SCC Online, http://www.scconline.co.in.

VII
 STATEMENT OF JURISDICTION

The Petitioners have approached the Hon’ble High Court of Kamagruha under Article 226 of
the Constitution of Raas Nagar.

VIII
 STATEMENT OF FACTS

Raas Nagar is a Union of States which is structured similarly to the Union of India. From 1950
onwards 60% of the population was staying below poverty wherein bonded labour, immoral
trafficking and prostitution were rampant. The society was infested with various sexual
diseases and violence against women was rampant.

Ms. Aahalaya, the Union Minister of Law and Justice, tabled a private member bill before the
Lok Sabha of Raas Nagar, which was subsequently passed by Parliament without any
deliberation and culminated in the enactment of the Regulation of Prostitution Act, 2019. The
said Act regulated prostitution in the Union of Raas Nagar by regularising prostitution as a
vocation having legal sanctions. It provided for health care facilities to sex workers, protection
against immoral trafficking, social benefits etc.

The Act salvaged the economy of Raas Nagar as there was a surge in collection of tax. The Act
also provided for video recording of sexual acts with consent, which opened the flood gates of
the porn industry. It further provided for unrestricted advertisement between 12 AM to 2 AM.
The Act also provided for medical screening of sex workers prior to sexual intercourse, separate
areas were earmarked outside the territorial limits of municipalities as “pleasure houses” which
had to provide protection to sex workers and their clients with surveillance of CCTVs.

Persons irrespective of age, education or marital status sought to register themselves as licensed
prostitutes. It manifested in an unprecedented rise in debauchery, wreaking havoc on the
institution of marriage and mobility of young citizens. Unconfirmed data also claimed a surge
in sexually transmitted disease (HPV).

STREE, a registered NGO having office in the State of Kamagruha, espousing the rights of
women made a representation to Ms. Aahalaya as well as the President of AAMRAJ party,
which found no reply. Aggrieved by this, they have approached the High Court of Kamagruha.

Maverick, another NGO in Kamagruha proclaiming access to unrestricted fornication to

establish freewill in the Society approached the High Court too, praying for quashing sections
related to installation of CCTV, and to lay down guidelines for sex workers within the state of
Kamagruha, the extension of the definition of prostitute to include LGBT and ladyboys and
quashing the section which sought for registration of sex workers before the jurisdictional
police. Hence, the present petitions.

IX
 STATEMENT OF ISSUES

I. WHETHER THE PETITIONS ARE MAINTAINABLE

II. WHETHER THE PROCEDURES PRESCRIBED IN THE ACT ARE

CONSTITUTIONAL (CONTENTIONS OF MAVERICK)

III. WHETHER THE REGULATION OF PROSTITUTION ACT, 2019 IS

CONSTITUTIONAL (CONTENTIONS OF STREE)

X
 SUMMARY OF ARGUMENTS

I. It is a submission of the petitioners before this Hon’ble Court to entertain the petition filed
under Article 226 of the Constitution of Union of Raas Nagar. The Constitution of Raas
Nagar guarantees a set of fundamental rights to all its citizens and anyone whose right has
been infringed has the right to seek remedy. Therefore, the petitioner has Locus Standi in
initiating the Writ Petition. In the instant case Articles 14, 19, 21 and 25 have been
violated. When fundamental rights are being infringed it is not only the right but also the
duty to afford relief to the petitioner, and he need not establish either that he has no
alternative remedy, or that he has exhausted all the remedies provided by law. Therefore,
it is submitted that the instant petition is maintainable under Article 226 of the
Constitution.
II. Various provisions of the Regulation of Prostitution Act, 2019, suffer from the vices of
unreasonable classification, excessive and uncontrolled delegation and arbitrariness, and
have undue implications on the right of trade and occupation and the right to life and
personal liberty of prostitutes and customers alike. The impugned provisions are Section
11, which places an obligation upon Sex Workers to register, Section 22, which provides
for mandatory CCTV surveillance in Pleasure houses and thereby denies the right to
privacy to both sex workers and customers of pleasure houses in a manner which is
arbitrary and fanciful, and Section 4, which restricts advertisement of commercial sexual
services on only certain media but not another media despite the existence of no intelligible
differentia between the two groups rendering it unreasonable. Further, guidelines
regarding working conditions, minimum wages and working hours are sought in the
interest of the sex workers.
III. It is humbly submitted before this Hon’ble Court that the Regulation of Prostitution Act,
2019 is unconstitutional as it impinges on the fundamental rights guaranteed under Part
III of the Constitution. The differentiation made by the impugned legislation is illogical
and has no nexus to the object sought to be achieved, which per se is questionable, thus it
violates Article 14. Further, it infringes Article 21 by trampling upon the dignity, privacy
and personal liberty of persons engaged in the business of prostitution. It also violates
Article 25 by striking on the institution of marriage, which is an integral facet of all
religion

XI
 ARGUMENTS ADVANCED

I. WHETHER THE PETITIONS ARE MAINTAINABLE?

1. It is a submission that the petitions filed before the Hon’ble High Court are maintainable
under Article 226 of the Constitution. Under Article 226 the High courts have a power
parallel to that of Article 32 to enforce the fundamental rights. The act violates the
fundamental rights of the petitioners (A), Alternative remedy is no bar to approach this
Hon’ble Court (B), and that the petitioners possess the requisite locus standi (C).

A. That the act violates the fundamental rights

1. Article 14 of the Constitution guarantees the right to equality before law. The Act aims
at decriminalising prostitution and ensuring better protection of sex workers which
merely legitimises prostitution. It is to be noted that prostitution in India is per se not
illegal, it is only soliciting such services in public places, kerb calling, etc. have been
made illegal by the Immoral Traffic (Prevention) Act, 1956.1 Thus, prostitution carried
out in private is legal.
2. Article 19 of the Constitution ensures protection of certain rights regarding freedoms
including the freedom to practice any profession or occupation. The restrictions placed
on this right by the Act under s. 4 and s. 11 go against Art. 19 of the Constitution, and
hence infringe upon the fundamental right of the individual.
3. Article 21 of the constitution ensures protection of life and personal liberty which
includes the Right to Privacy.2 The Act, under s. 22 has made it compulsory for the
installation of CCTV cameras in the pleasure houses, which violates their Right to
Privacy. Thus, the enactment of this statute violates Article 21 of the Constitution.
4. Article 25 of the Constitution affords to ‘all persons’ the freedom of conscience and
free profession, practise and propagation of religion. It is submitted that the Act has
caused great damage to the institution of marriage, which is an essential facet of
religion. Citizens of Raas Nagar, disregarding their marital status have registered

1
Vide ss.3-8 of the Immoral Traffic (Prevention) Act, 1956
2
KS Puttaswamy v. Union of India. AIR (2017) 10 SCC 1.
1
 themselves as prostitutes.3 Thus, the enactment of the impugned Statute has violated
Article 25 of the Constitution.
5. Articles 32 and 226 of the Constitution have been provided specifically for the
enforcement of fundamental rights. With this in mind, it is difficult to visualize a
situation in which a court can refuse to admit a writ petition for that very purpose. In
M/s Baburam Prakash Chandra Maheshwari v. Antarim Zila Parishad4 it was held
that, once a violation of the fundamental right is established, it is not only the right and
the power but also the duty and obligation of the Court to see that the petitioner’s
fundamental right is protected and safe-guarded. The same principle is applicable to
Article 226 as well.5 Therefore, it is submitted that the petition must be admitted.

B. That alternative remedy is no bar

6. It is a submission that, in the instant case, alternative remedy is no bar. The rule that
when there is an adequate alternative remedy, the High Court will not interfere under
Article 226 is only a rule of discretion and not a rule of law.6 It is always a matter of
discretion of the Court and if the discretion has been exercised by the High Court
reasonably and not perversely, it is a settled practice of the Supreme Court not to
interfere with the exercise of the discretion of the High Court.7
7. The High Court will issue a writ, although an adequate alternative remedy exists, where
a party comes to the Court with an allegation that its fundamental right has been
infringed and seeks relief under Article 2268 even if the alternative remedy of a civil
suit for compensation is available.9
8. In Harbansal Sahnia v. Indian Oil Corpn. Ltd.,10 where the petitioners’ bread and butter
were involved, the court held that the High Courts could entertain petitions in the
following contingencies even if the alternative remedy was available. They are: (i)
where the enforcement of the fundamental rights is sought, (ii) where the principles of

3
Para 7, Moot Proposition.
4
AIR 1969 SC 556
5
Himmatlal v. State of Madhya Pradesh, AIR 1954 SC 403
6
A.V. Venkateshwaran v. Ramchand Sobhraj Wadhwani, AIR 1961 SC 1506: (1962) 1 SCR 753; Atulya Kumar
De v. Director, AIR 1953 Cal 548.
7
State of UP v. Indian Hume Pipe Co., (1977) 2 SCC 724: AIR 1977 SC 1132.
8
Supra 5.
9
Railway Board v. Chandrima Das, (2000) 2 SCC 465: AIR 2000 SC 988; T.N. Electricity Board v. Sumathi,
(2000) 4 SCC 543: AIR 2000 SC 1603.
10
(2003) 2 SCC 107; AIR 2003 SC 2120.
2
 natural justice have not been observed, and (iii) where the orders or proceedings are
wholly without the jurisdiction.

C. That the petitioner has locus standi to approach this Hon’ble Court

9. It is submitted that the jurisdiction under Article 226 can be in a proper case be invoked
against the legislature also. No legislature in India can claim immunity from the writ
jurisdiction of the High Court by issuing and unspeaking warrant.
10. Article 226 does not specify the persons who can approach the court under it. But as
this article provides a public law remedy similar to Art. 32, similar provisions of locus
standi apply to it as to Art. 32. Ordinarily, a person whose legal rights or other legally
protected interests are adversely affected should approach the Court for relief.11 The
petitioner need not wait till the actual infraction of his right; he can also approach the
court against imminent threat of such infraction.12

II. WHETHER THE PROCEDURES PRESCRIBED IN THE ACT ARE

CONSTITUTIONAL (CONTENTIONS OF MAVERICK)

1. It is submitted that various provisions of the Act suffer from the vices of unreasonable
classification, excessive and uncontrolled delegation and arbitrariness, and infringe upon
the right of trade and occupation and the right to life and personal liberty. The impugned
provisions are Section 11 (A), Section 22 (B), and Section 4 (C). Further, guidelines
regarding working conditions, minimum wages and working hours are sought in the
interest of the sex workers (D).

A. The obligation to register as provided for in s. 11 of the Act violates Art. 19(1)(g) of the
constitution as the restriction is not reasonable

2. It is submitted that the right to indulge in the business of prostitution is a Fundamental

right under Art. 19(1)(g) of the Constitution (a) and that the restriction placed upon it by
S. 11 of the Act is unreasonable and hence liable to be quashed (b)

11
State of Orissa v. Ram Chandra Dev, AIR 1964 SC 685.
12
SMD Kiran Pasha v. Govt of AP, (1990) 1 SCC 328.
3
a. The Right to indulge in the business of Prostitution is a Fundamental Right
3. It is submitted that Art. 19(1)(g) of the Constitution protects the rights of individuals to
practice any profession or carry on any occupation, trade or business. These terms were
defined in Sodan Singh v. New Delhi Municipal Committee13as “a very wide term and
would include anything which occupies the time, attention and labour of a man for the
purpose of profit”. Hence, any individual who is occupied in prostitution for the purpose of
profit is protected by Art. 19(1)(g) of the constitution.
4. The state can expressly prohibit certain businesses for they may be adverse to public health,
such as gambling14 and food adulteration15, however, it is submitted that such is not the
case presently. Further, in Krishan Kumar Narula v. State of Jammu and Kashmir16, it was
held that standards of morality can afford a guidance to impose restrictions but cannot limit
the scope of the right. Hence, immorality cannot be aground for exclusion. As such, it is
submitted that the right to indulge in the business of prostitution is indeed protected as a
fundamental right under 19(1)(g)
b. The obligation to register as under s. 11 of the Act is unreasonable and liable to be
struck down.
5. Requirement of licensing or registration is a restriction on the right to trade and profession
and hence, open to the test of reasonableness. It is submitted that a law or order which
confers arbitrary and uncontrolled power upon the executive is unreasonable17 unless the
policy according to which the discretion is to be exercised is provided by the law18.
6. It is provided that s. 11(g) of the Act allows the executive to demand details beyond those
mentioned in s. 11(a) to 11(f) by way of notification. This can be reasonable if the policy
by which such additional conditions can be imposed was prescribed by the law. However,
no such policy is found in the present case and is hence unreasonable and is liable to be
quashed.

13
AIR 1989 SC 1988, 1999
14
State of Bombay v. RMD Chamarbaugwala, AIR 1957 SC 699
15
State of UP v. Kartar Singh, AIR 1964 SC 1135
16
AIR 1967 SC 1368, 1371
17
Dwarka Prasad v. State of UP, AIR 1954 SC 224
18
HArishankar Bagla v. State of MP, AIR 1954 SC 465
4
 B. The provision relating to compulsory CCTV surveillance violates the right to personal
liberty

7. Section 22 of the Act provides that all pleasure houses must have CCTV surveillance and
that the same will be monitored by the police. It is submitted that the right to privacy is
included under the ambit of personal liberty under Art 21 (a) and the procedure established
to deny it is unfair, unjust and arbitrary (b) and is hence liable to be struck down.
a. The Right to Privacy is a Fundamental Right and is included under the term Personal
Liberty in Art 21 of the Constitution
8. It is submitted that in K.S. Puttaswamy v. Union of India19 it was held that the Right to
Privacy is a Fundamental Right included in the term personal liberty20. As such, any law
imposing a restriction on it must be just, fair and reasonable21 and may be challenged on
the grounds that it is vague22 and that it is unfair and unreasonable23 among others.
9. Further, those laws seeking to impose a restriction on the personal liberty of an individual
must pass a threefold test: i) It must prescribe a procedure, ii) it must withstand the test of
one of the freedoms enumerated in Art. 19 as the case may be and iii) it must also be liable
to be tested with reference to Art 1424.
b. The Procedure established under S. 22 of the Act is Unfair, Unjust and Arbitrary
10. As previously mentioned, a procedure which is vague is open to challenge as violative of
Art. 21 of the Constitution. In State of Madhya Pradesh v. Baldeo Prasad25, the Supreme
Court struck down the Central Provinces and Berar Goondas Act, 1946 as it failed to define
the word “Goonda” in an unambiguous manner. Similarly in the present case, the Act fails
to qualify any of the terms in s. 22. It simply provides for CCTV surveillance that is
monitored by the police but fails to give any guidance as to under what circumstances such
monitoring might be made. It is vague and ambiguous and hence liable to be struck down.
11. It is further submitted that any procedure prescribed to deprive a person of his life or
personal liberty must satisfy the test of reasonableness under Art 14 as well26. In the present
case, the act provides no qualifications such as Principle of Notice, Principle of Choice and

19
K.S. Puttaswamy v. Union of India, (2017) 10 SCC 1
20
Ibid 320, 375
21
Maneka Gandhi v. Union of India, AIR 1978 SC 597
22
Abbas K.A. v. Union of India AIR 1971 SC 481; State of MP v. Baldeo Prasad, AIR 1961 SC 293
23
Supra 21; Inderjeet v. State of UP, AIR 1979 SC 1867; Francis Coralie Mullin v. Union Territory, AIR 1981
SC 746
24
Dist. Registrar and Collector v. Canara Bank, AIR 2005 SC 186
25
AIR 1961 SC 293
26
Rustom Cavasjee Cooper v. Union of India, AIR 1970 SC 564
5
 Consent, Principle of Collection Limitation, Principle of Purpose Limitation, Principle of
Access and Correction, Principle of Disclosure of Information, Principle of Security,
Principle of Openness, Principle of Accountability27 etc. which are all essential tenets of
protecting privacy in instances of mass surveillance.
12. For instance, the Karnataka Public Safety (Measures) Enforcement Act, 201728, mandates
surveillance but provides that data shall not be retained for more than 30 days 29. Further, it
also makes provisions regarding who may conduct inspections etc. for the purposes of
compliance30. The impugned act makes no such provisions and qualifications and allows
any rank of police to monitor any pleasure house with no guidance, thereby violating the
right to privacy of the customers of the pleasure houses as it is not guided by a clear
procedure31. It hence suffers from the vice of unguided delegation, which renders it
violative of Art. 14. It is hence submitted that S. 22 is violative of Art 21 of the constitution.

C. The blanket ban on the advertisement of Commercial Sexual Services on Radio, Cinema
and Print media is Unconstitutional.

13. Section 4 of the Act provides that there shall be no advertisement of Commercial Sexual
Services on Radio, Cinema and print media. It does however allow for such advertisements
on Television between 12am and 2am. It is submitted such classification is unreasonable
(a) and infringes upon the right to speech and expression of sex workers and operators of
business of prostitution and the customers of such services (b)
a. The Classification made in Section 4 of the Act is unreasonable and hence, violative
of Art. 14
14. It is submitted that for a classification to pass the test of constitutionality under Art. 14, the
classification must be founded on an intelligible differentia and the differentia must have a
rational nexus with the object sought to be achieved by the statute in question32. Provisions
which classify without a reason or make classifications which are irrelevant to the object
of the act have historically been struck down.33 As regards intelligible differentia, there
must be some rational distinction between the objects included in the group and those which

27
Justice Ajit Prakash Shah, Former Chief Justice, High Court of Delhi, “Report of the Group of Experts on
Privacy”, Planning Commission (CIT&I Division), Government of India, 16 October 2012
28
Karnataka Act no. 44 of 2017
29
Ibid Statement of Objects and Reasons
30
Ibid S. 5
31
Kharak Singh v. State of UP, AIR 1963 SC 2178
32
State of West Bengal v. Anwar Ali Sarkar, AIR 1952 SC 75
33
Karimbil Kunhikonam v. State of Kerala AIR 1962 SC 723
6
 have been left out. In the absence of such difference, the classification is invalid34 It is
submitted that there is no intelligible differentia between television and other media for the
purposes of the Advertisement and hence, the classification cannot be valid.
15. It is also essential that there be a rational nexus between the differentia and the object sought
to be achieved35. Hence, even if it is argued that there is some intelligible differentia, it is
submitted that such differentia has no nexus with the object sought to be achieved by the
act, which is to protect moral values and protect children from exposure to commercial
sexual services. This can be sufficiently achieved by allowing advertisement on all media
in the same time frame and hence, the classification between television and other media
during the same time frame has no rational nexus with the object. As such, the provision is
violative of Art. 14.
b. The restrictions placed upon the Freedom of Speech and expression by S. 4 of the Act
are not reasonable.
16. It is submitted that in Tata Press Ltd. v. Mahanagar Telephone Nigam Ltd36. it was held
that a commercial advertisement is a form of speech. “Commercial Speech” is a part of
freedom of speech and expression guaranteed under Art 19(1)(a) and protects the rights of
an individual to listen, read and receive such speech. It is submitted that S. 4 abridges this
right by totally prohibiting the advertisement of Commercial Sexual Services on Radio,
Cinema and Print Media.
17. However it is conceded that this right may be reasonably restricted under 19(2), but for
such restriction to be reasonable, it must answer three questions in the affirmative; i)
whether the right claimed is a fundamental right, ii) whether the restriction is contemplated
under Art. 19(2) and iii) whether the restriction is reasonable. The first question is answered
in the affirmative in the preceding paragraph and the second question is also answered in
the affirmative as such restriction may be for the maintenance of public morality. However,
the third question is answered in the negative as it does not pass the test of reasonableness
as prescribed by M.R.F. Ltd. v. Inspector, Kerala Govt37 which laid down that the restriction
must not be arbitrary and excessive and go beyond the interests of the general public. In
the present case, a blanket ban on advertisement on Radio, Cinema and print media is
arbitrary and goes beyond the interests of the general public as public morality can be

34
Suraj Mall Mohta & Co. v. A.V. Vishvanath Sastri, AIR 1954 SC 545; John Vallamattom v. Union of India,
AIR 2003 SC 611
35
State of Maharashtra v. Indian Hotel and Restaurant Association (2013) 8 SCC 519
36
AIR 1995 SC 2438
37
(1998) 3 SCC 709 (Para 43)
7
 sufficiently maintained by allowing advertisements on all media between 12am and 2am
and on exclusively adult magazines.

D. Seeking certain guidelines regarding working conditions, minimum wages and working
hours are sought in the interest of the sex workers

18. It is submitted that courts have the competence to issue guidelines (a) and they are
essential in this case to give effect to the Fundamental Rights of the Prostitutes (b)
a. The High Courts have the competence to issue guidelines
19. It is submitted that Art. 226 of the Constitution confers upon the High Court the power to
issue to any person or authority, including any Government, directions, orders or writs. The
directions mentioned therein include those given in the form of guidelines. In State of
Uttaranchal v. Balwant Singh Chaufal38 and others the Supreme Court has approved the
issuance of guidelines and directions in the public interest litigation in exercise of powers
under Article 226 of the Constitution of India. Courts have issued guidelines in matters
relating to workplace sexual harassment in Vishakha v. State of Rajasthan39 and in matters
relating to police in Parkash Singh and others v. Union of India40. Further, the competence
of a High Court to give guidelines was pointed out in Salil Sabhlok v. Union of India41. It
is hence submitted that this court is competent to issue directions in the form of guidelines
b. Guidelines are required in the present matter to give effect to the Fundamental rights
20. It is submitted that prostitutes in the Union of Raas Nagar have historically faced certain
problems such as physical violence by clients, operators and police42, abysmal pay as a
result of unfair sharing between operator and sex worker43, widespread infections such as
HIV AIDS due to inability to insist on use of condoms44, deplorable, unhygienic working
conditions45 and are forced to service several customers in one day46. These are not
problems that cannot be addressed by the present act.

38
(2010) 3 SCC 402
39
(1997) 6 SCC 241
40
(2006) 8 SCC 1
41
2011 SCC Online P&H 10362
42
Violations faced by Sex Workers in India Joint Stakeholders Submission Special Rapporteur on Violence
Against Women (SR-VAW) on Conflation of Sex Work and Trafficking
43
http://factsanddetails.com/india/People_and_Life/sub7_3h/entry-4190.html Last accessed 23/1/2019
44
Joint United Nations Programme on HIV/AIDS (UNAIDS) 2009-2012
45
https://www.bbc.com/news/world-asia-india-24530198 Last accessed 23/1/2019
46
7 Stud Adv (1995) 106 Prostitution and Human Rights, Kavitha Kumar and Gunjan Shah
8
21. The right to live with dignity with basic human needs47, the right to compensation48 etc. are
all fundamental rights guaranteed under Art 21 of the Constitution and also by international
documents such as the UDHR. The state needs to take measures to ensure that these rights
are effective in the lives of the prostitutes. To do so, the petitioner submits that the
intervention of the court is necessary and hence prays for guidelines.

III. WHETHER THE REGULATION OF PROSTITUTION ACT, 2019 IS

CONSTITUTIONAL (CONTENTIONS OF STREE)

1. It is submitted before this Hon’ble Court that the Regulation of Prostitution Act, 2019 is
unconstitutional as it violates the fundamental rights guaranteed under the Constitution of
Raas Nagar. The Act violates Art. 14, which guarantees the right to equality (A). It also
infringes on the Right to life and personal liberty guaranteed under Art. 21(B), and it
violates Article 25 which affords to citizens the freedom to profess, practise and propagate
religion (C).

A. That the Act violates Article 14 of the Constitution.

2. Article 14 of the Constitution guarantees to every person, including non-citizens and

transgenders49 the right to equality before the law and the equal protection of the laws.
a. The legislation makes an unreasonable classification
3. Equality under Article 14 does not devoid the State from making permissible classifications
as all laws cannot be universal in application.50Permissible classification must satisfy two
conditions, namely: (1) it must be found on an intelligent differentia; and (2) the differentia
must have a rational relation to the object sought to be achieved by the statute in question
with the qualification that the differentia and the object are different. A law based on
permissible classification, fulfils the guarantee of the equal protection of laws and is valid.51
4. In the impugned legislation, the differentiation separates persons who have obtained
registration under the Act, and those who have not. Further, the criteria for registration is

47
Francis Coralie Mullin v. Union Territory AIR 1981 SC 746, People’s Union for Democratic Rights v. Union
of India (1982) 2 SCC 494
48
Olga Tellis v. Bombay Municipal Corporation AIR 1986 SC 180
49
National Legal Services Authority v. Union of India (2014) 5 SCC 438
50
Kedar Nath Bajoria v. State of W.B. AIR 1953 SC 404
51
State of Bihar v. Bihar State Plus-2 Lecturers’ Association AIR 2007 SC 1948; Seema Silks and Sarees v.
Directorate of Enforcement AIR 2008 SC 2564; Maneka Gandhi v. Union of India AIR 1978 SC 597;
Kallakkurichi Taluk Retired Officials Assn. v. State of T.N. (2013) 2 SCC 772
9
 solely based on the age of the person. It is submitted that this differentiation is illogical as
it does not take into consideration the marital status, sanity, literacy and other relevant
factors for the purpose of registration. It strikes at the institution of marriage.
5. The Preamble of the Act states that it is “An Act to provide for decriminalizing prostitution,
better protection of the interests of sex workers and for that purpose to make provision for
the establishment of prostitutes’ advisory board for safeguarding the rights of sex workers
and protect them from exploitation and for matters connected therewith.”52
6. It is submitted before this Hon’ble Court that the Act fails to make distinguish between
“legalization of prostitution” and “decriminalizing of prostitution”. Decriminalisation of
prostitution implies a removal of any legal hindrance leading to sex workers to desist from
providing services, while legalisation of prostitution implies introduction of any laws and
policies specific to sex work to formally regulate it. Such a view (against legalisation) is
ardently supported by a magnitude of prostitutes, who believe that legalization (which is
invasive in nature) would be akin to legalised abuse as it would be tightly curtailed and
regulated by the state, and in turn the police.53

b There is no presumption in favour of the legislation’s validity.

7. The presumption of constitutionality was enunciated by Fazal Ali J. in Chiranjit Lal’s

case:54- “The presumption is always in favour of the constitutionality of an enactment, and
the burden is upon him who attacks it to show that there has been a clear transgression of
the constitutional principles.”
8. The court cannot, however, make a fetish of the rule of presumption, for, as soon as a statute
is clearly shown to be in contravention of the supreme law of the land, it is the duty of the
Court to strike it down, uninfluenced by any extraneous consideration, such as utility or
desirability of such legislation.55 The presumption of constitutionality is of no avail when,
on the face of the statute, there is no classification at all, and no attempt has been made to
select any individual or group with reference to any differentiating attribute peculiar to that
individual or group.56

52
Moot Proposition P. 6
53
Anne McClintock, Sex Workers and Sex Work: Introduction, 37 Soc. Text 1-10 (1993)
54
Chiranjit Lal v. Union of India (1950) SCR 869 (879)
55
State of West Bengal v. Anwar Ali AIR 1952 SC 75
56
Ram Prasad v. State of Bihar (1953) SCR 1129
10
c. The Act is opposed to Article 23 of the Constitution.
9. The Act of 2019 is in contravention to Article 23 which prohibits traffic in human beings
and forced labour. The Court defined Traffic in human beings to mean to dealing in men
and women like goods, such as to sell or lease or otherwise dispose of. It would include
traffic in women and children for immoral or other purposes.57
10. Section 3 of the Act which states that provision of commercial sexual services is not void
contravenes Article 23 as provision of sexual services, whether contractual or otherwise is
mere commodifying of the body of a person, which comes within the scope of the term
‘traffic in human beings.’

B. The Act violates Article 21 of the Constitution

11. Article 21 of the Constitution guarantees to every person, whether citizen or not the right
to life and personal liberty. Under the canopy of Article 21, many rights have found shelter,
growth and nourishment.
a. The legislation is opposed to the right to lead a dignified life.
12. In Francis Coralie Mullin v. UT of Delhi58 the Court observed that the right to life includes
the right to live with human dignity and all that goes along with it, namely, the bare
necessaries of life such as adequate nutrition, clothing and shelter and facilities for reading,
writing and expressing oneself in diverse forms etc.
13. It is submitted that prostitution, in any form, is slavery. It objectifies women. Many women
choose it for money: their involvement in it is not voluntary but are trapped in most
instances. Prostitution in essence is violence – of the man over the woman. It involves sale
of the women’s body. It is manifestly opposed to the right to live with human dignity and
tramples on the personal liberty of women. The Act of 2019 has in the garb of championing
the cause of women condemned them to a life bereft of dignity, social status and reduced
them to the level of hawkers of their own flesh

b. The legislation is contrary to the jurisprudence evolved by the Supreme Court

14. The Supreme Court while dealing with the issue of plight of prostitutes placed emphasis on
the need to provide to prostitutes opportunities for education and training so as to facilitate
their rehabilitation.59Further, the Court held that the conditions conducive for sex workers

57
Raj Bahadur v. Legal Remembrancer AIR 1953 Cal 522
58
AIR 1981 SC 746
59
Gaurav Jain v. Union of India AIR 1997 SC 3021
11
 to live with dignity in accordance with the provisions of Article 21 of the Constitution
should be understood in its correct perspective i.e. they may be provided alternative source
of employment for their rehabilitation to live life with dignity.60
15. It is submitted that the Parliament in enacting the Act of 2019 has completely disregarded
the judicial directions given by the Supreme Court and in effect has given contrary
expression to the jurisprudence evolved by the Court. It is clear that the Court was not in
favour of legalising organised prostitution and its intent was only to educate, and
rehabilitate the oppressed sex workers in order to integrate them into the social mainstream.

c The legislation violates the right to privacy.

16. The right to privacy is protected as an intrinsic part of the right to life and personal liberty
under Article 21 and as a part of the freedoms guaranteed by Part III of the Constitution.it
permeates the core of preambular philosophy underlying “liberty” and “dignity” considered
essential for a meaningful human existence.61 Even a woman of easy virtue is entitled to
privacy and no one can evade her privacy as and when one likes.62
17. Section 3 of the Act makes provision of sexual services a contractual relation, while section
6 empowers parties to the contract rescind, cancel or recover damages for commercial
services that is not performed. The Act however does not take in to account other remedies
available in Civil Law, which if enforced would violate the right to privacy of the woman.
To illustrate, suppose a woman refuses to provide sexual services, would the intended
recipient be allowed to recourse to the Specific Relief Act, 1963 to seek specific
performance of the sexual service, or, seek an injunction, preventing the prostitute from
rendering sexual services to other clients till the adjudication of the suit. The above
illustration clearly exposes the lack of application of mind in enacting this legislation,
which is a given, due to the lack of deliberation or discussion in passing the bill, given the
brute majority enjoyed by AAM RAJ in parliament.63 It also exposes the inherent flaw in
giving contractual status to an arrangement concerning the sexual integrity and flesh of a
person.
d. The legislation is opposed to the right to health.
18. Article 21 guarantees the right to health which includes right to live in a clean, hygienic
and safe environment.64 The Court while emphasising on the need to protect children, also

60
Budhadev Karmakar v. State of West Bengal (2013) 1 SCC 294
61
K S Puttaswamy v. Union of India (2017) 10 SCC 1
62
State of Maharashtra v. Madhukar Narayan Mardikar AIR 1991 SC 207
63
Para 3, Moot Proposition
64
Occupational Health & Safety Association v. Union of India AIR 2014 SC 1469
12
 held that the right to live with human dignity enshrined in Article 21 derives its life breath
from the Directive Principles of State Policy. It therefore must include protection of health
and strength of the workers, men and women, and of the tender age of children against
abuse, opportunities and facilities for children to develop in a healthy manner and in
conditions of freedom and dignity.65The same is complemented by Article 47 of the
Constitution66 which imposes a duty on the State to raise the level of nutrition and the
standard of living and to improve public health. In this regard the Supreme Court taking
notice of the importance of liquor trade vis-à-vis public health noted that the State should
not treat its right of issuing licenses only as a means of earning more revenue.67 It also held
that Article 47 casts a clear duty on State to at least reduce liquor consumption,68 not
minding its effect on revenue generation.
19. With the enactment of the impugned Statute citizens of Raas Nagar irrespective of marital
status, age or literacy have opted to work as prostitutes and sex workers.69 The Act has also
wreaked havoc on the mobility of young citizens and there has been a surge in sexually
transmitted diseases (HPV).70
20. It is submitted that the Constitution envisages a socialist, positive, modern State, which
must advance the standard of living of citizens (including their social mobility) and also
ensure public health. The Act of 2019 enacted by the Parliament has recklessly abandoned
these duties of the State. Prostitution may be an easy way of making money, but the same
cannot be a lifelong profession, due to the inherent physical limitations of the human body.
As a positive State, it must envisage for its citizens greater social mobility and a higher
standard of living. The surge in HPV and susceptibility of juveniles to obscene content
brought about by the debauchery of the citizens is injurious to public health and also the
society’s morality.

65
Bandhua Mukti Morcha v. Union of India (1997) 10 SCC 549
66
Directive Principles of State Policy, Part IV of the Constitution
67
Ashok Lenka v. Rishi Dikshit AIR 2006 SC 2382
68
State of Maharashtra v. Nagpur Distillers, Nagpur AIR 2006 SC 1987
69
Para 7, moot proposition.
70
Para 11, moot proposition.
13
 C. The Act violates Article 25 of the Constitution.

21. Article 25 of the Constitution affords to ‘all persons’ the freedom of conscience and free
profession, practise and propagation of religion. Article 25 ensures equality of all religions,
thereby promoting secularism, which is a basic feature of our Constitution.71
22. The Hon’ble Supreme Court defined the term ‘Religion’ as follows – “Religion is certainly
a matter of faith with individuals or communities and it is not necessarily theistic. A religion
undoubtedly has its basis in a system of beliefs or doctrines which are regarded by those
who profess that religion as conducive to their spiritual well-being, but it would not be
correct to say that religion is nothing else but a doctrine or belief. A religion may not only
lay down a code of ethical rules for its followers to accept, it might prescribe rituals and
observances, ceremonies and modes of worship which are regarded as integral parts of
religion, and these forms and observations might extend even to the matters of food and
dress.”72
a. The legislation is detrimental to the institution of marriage.
23. In Syedna Taher Saifuddin Saheb v. State of Bombay73 the Court observed that Articles 25
and 26 protect matters of religious doctrine or belief as well as acts done in pursuance of
religion – rituals, observances, ceremonies and modes of worship. These articles embody
the principles of religious tolerance that has been one of the characteristic features of Indian
civilisation from the start of its history. What constitutes an integral and essential part of a
religion or a religious practise has to be decided by the Courts with reference to the doctrine
of a particular religion and includes practises regarded by the community as part of its
religion.74
24. In Hinduism, the institution of is conceived as a sacramental union implying a permanent
union which cannot be dissolved. Marriage, thus, is the samskara undergone by the women
when she is given by her relation and accepted by the man in the ceremony called
panigrahana.75 The intention of the sacrament is to make the husband and wife one, for
secular and spiritual purposes.76. In Islam, religion and law are indissolubly bound and it

71
Ismail Farooqui v. Union of India (1994) 6 SCC 360
72
Commr. Hindu Religious Endowment v. Sri Lakshmindra Thirtha Swamiar of Sri Shirur Mutt AIR 1954 SC
282
73
AIR 1962 SC 853
74
Seshammal v. State of T.N. AIR 1972 SC 1586
75
J. Duncan and M. Derrett, A Critique of Modern Hindu Law (N.M. Tripathi Pvt. Ltd., 1970)
76
Ibid.
14
 cannot be said that a Muslim marriage is not a religious rite. 77 Muslim jurists regard the
institution of marriage as partaking both of the nature of ibadat (devotion) and muamalat
(dealings among men).78 The Prophet observed, “Men marry for beauty, for rank, for
wealth, for piety: choose piety…marriage is my sunnat and those who do not obey it are
not my followers.”79The Prophet has also observed that “there is no monkery in Islam.”80
Marriage, as understood in the Christian world, means the voluntary union for life of one
man and one woman, to the exclusion of all other, entered into some form recognised by
the lex loci (law of the land).81
25. It submitted that the Act of 2019 has caused great damage to the institution of marriage,
which is an integral and inalienable facet of every religion. Citizens of Raas Nagar,
disregarding their marital status have registered themselves as prostitutes.82 Thus, the
enactment of the impugned Statute has violated Article 25 of the Constitution, and is liable
to be struck down as being ultra vires to the Constitution.

b. The legislation is not an affirmation of ancient religious practises.

26. Arguendo, if the State contends that the Act of 2019 is in consonance with Article 25 as it
gives legitimacy to certain ancient practices of the Hindu religion, such as the devadasi
system, the same is also untenable.
27. The Supreme Court clearly rejected the same in Gaurav Jain v. Union of India,83 and held
that “the customary initiation of women in the practice of Devadasi, Jogins and Venkatasins
is prevalent in Andhra Pradesh, Karnataka and Maharashtra areas; in particular the practice
of prostitution is notorious. It is an affront to human dignity and self-respect but the pursuit
of customary beliefs traps the fair sex into this glorified self-sacrifice and ultimately leads
to prostitution service in the temples and charitable institutions etc. which is a crime against
humanity, violation of human rights and obnoxious to the Constitution and the Human
Rights Act. They are void under Article 13 of the Constitution of India and punishable
under the law. They are antithetical to the constitutional scheme.”
28. Thus, the Act of 2019 is in clear violation of Articles 14, 21 and 25 of the Constitution. It
is an affront on the rights of women and society at large and is liable to be struck down.

77
Mamta Rao, Law Relating to Women and Children 325 (4 th ed. 2018)
78
Quoted in Aquil Ahmad, Text Book of Mohammedan Law.
79
Ibid.
80
Ibid.
81
Hyde v. Hyde (1866) 1 P&M
82
Para 7, Moot Proposition.
83
(1997) 8 SCC 114
15
 PRAYER

WHEREFORE In light of the facts stated, issues raised, authorities cited and arguments
advanced, it is most humbly prayed before this Hon’ble High Court, that it may be pleased to
adjudge and declare that:

1. The Regulation of Prostitution Act, 2019 is unconstitutional.

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

All of which is humbly prayed.

COUNSEL FOR STREE.

WHEREFORE In light of the facts stated, issues raised, authorities cited and arguments
advanced, it is most humbly prayed before this Hon’ble High Court, that it may be pleased to:

1. Strike down section 4 of the Regulation of Prostitution Act, 2019.

2. Section 11 of the Regulation of Prostitution Act, 2019.
3. Section 22 of the Regulation of Prostitution Act, 2019.
4. Issue guidelines in relation to the welfare of sex workers within the State of Kamagruha.

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

All of which is humbly prayed.

COUNSEL FOR MAVERICK.

XII