Every Indian reasonably expects that not only Military but also Judiciary must be 'Patriotic' & Prompt when National Security is in Danger. Jai Hind!

SYNOPSIS

This Writ Petition under Article 226 of the Constitution of India (a Public Interest Litigation) exposes a very serious Breach of National Security and also Potential Threat to our Country’s Integrity & Sovereignty -- a threat which has apparently gone unnoticed by the Security Agencies because of a very clever & cunning set of tactics adopted by Wikimedia Foundation’s Wikipedia to hoodwink the Law Enforcing Authorities.

It is pertinent to mention here that Ms. Carolyn Doran (a former Chief Operating Officer of Wikimedia Foundation Inc.) is said to have criminal records in at least four U.S. States, viz. Texas, Maryland, Virginia & Florida. Source:-

https://en.wikinews.org/wiki/Former_Chief_Operating_Officer_of_Wikimedia_Foundation_is_convicted_felon

This is not for the first time that suspicious or unlawful activities of any Wiki have come under the scanner -- Julian Paul Assange (Owner of WikiLeaks) is already on the run.

A private person’s investigation -- which started on the basis of a libellous entry, has led to the unearthing of a potential espionage network that needs in-depth public investigation by the Security Agencies. Details are given at Pages ‘5’ onwards of the List of Dates & Events. 

LIST OF DATES & EVENTS

06.04.2019 While browsing through the Internet, the Petitioner [the authorised signatory of ‘In-Trust Foundation’ (Registered)] came across the following URL -- wherein against the name ‘xxxxxx xxxxx xxxxx’ it was written as "involved in corruption" [Emphasis added]: 

https://en.wikipedia.org/wiki/Hindu_College,_Delhi  

07.04.2019 A screenshot of the relevant portion of the said libellous entry was emailed by the Petitioner to email ID ‘[email protected]’ -- which is the Address given by Wikipedia on its website for reporting libellous contents published on Wikipedia. It was stated in the said email-Report that:-

“From 'View History' Tab, I found that the said entry was made by a User named 'Dl2000'. Kindly BLOCK the said User immediately & permanently.” 

Ticket#2019040710002791 was assigned to the above ‘Report’ by Wikipedia.

24.04.2019 Stephen Philbrick (on behalf of Wikipedia’s Volunteer Response Team) replied to the same -- relevant extracts from the same are reproduced below:-

“Dear xxxxxxxxx,

I think you are referring to this edit:

https://en.wikipedia.org/w/index.php?title=Hindu_College,_Delhi&diff=next&oldid=891125587

*xxxxxx xxxxx xxxxx, [[Commissioned Officer]], involved in corruption cases ... 

... I don't see any need to take any action.” [Emphasis added] 

03.05.2019 Rachel Stallman (a Paralegal at Wikimedia Foundation Inc) also sent an email reply to the Petitioner saying, inter alia, that: 

“Your message has been forwarded to the Wikimedia legal department. ... It is a Wikipedia policy to block user accounts for making legal threats to other users. It does not appear that the article of your concern currently contains the content you were concerned about. ...” [Emphasis added]

On the other hand, the culprit who had posted the above libellous entry on Wikipedia was not blocked. And it was ‘concluded’ by both of the aforesaid Agents of Wikimedia/ Wikipedia that just by currently removing the libellous entry (Post) the offence of libel abates -- notwithstanding the grave damage that it has already caused to the reputation of the aggrieved person.  

06.05.2019 Thereafter, Stephen Philbrick emailed a further reply -- wherein he mocked at the Laws of Criminal & Civil Defamation and the Law of Torts, especially the well-known Principle that if the owner of a property permits a 3rd person to bring the latter’s dog onto the said property and that dog bites another person on that property, then both the Owners (owner of property and owner of dog) are equally liable to pay damages in torts in addition to facing appropriate criminal proceedings under the applicable Laws:-

“Dear xxxxxxxxxx,

> Firstly, the libellous publication that was twice publically made by the same errant Editor was seen by many persons all over the World -- before it was finally removed; and it was also seen in Lucknow (India). 

I am starting to wonder if I'm the victim of a hoax. I find it difficult to believe that anyone, much less someone trained professionally, could be unaware that inappropriate material is added to Wikipedia hundreds of times every day. most (sic) of those instances are removed by other editors promptly without outside notification, and on the rare is where an outside party notifies us before an editor seasonsees (sic) it, then it is removed. If it is libelous, it is removed from history. 

> Yet the said Editor has not yet publically (visibly) apologised for the same

it's a fools errand to ask for apologies. 

> nor has any action been taken by Wikimedia to block the said Editor.

We have well-developed policies for how and when to block editors. It is extremely rare to block an editor for a first offense.”

[Emphasis & parentheses added. Moreso, it appears that by prefixing the symbol ‘>’ Stephen Philbrick is referring to certain portions of Petitioner’s aforesaid email ‘Report’; therefore, for ease of reading the Petitioner has italicised the portions immediately following ‘>’, and the normal text in the paragraph below the same is the Reply made by Stephen to the said portions.] 

It is amply clear from the aforesaid Replies by Agents of Wikipedia that despite being aware that Municipal Laws are being breached by Wikipedia’s Users, its Agents are so callous as to refuse to take any action against the culprit -- who posted on Wikipedia with latter’s implied permission, and Wikipedia itself published the contents of the said unlawful Posts; on the other hand, the said Agents not only harass the complaining aggrieved party by ‘blocking’ him, but also screen the offenders by not disclosing their true Identities. Nor does Wikipedia take any preventive action -- despite admittedly knowing that Municipal Laws are being unlawfully breached by its Users “hundreds of times every day” (supra).

On the same date, Rachel Stallman of Wikimedia Foundation (wrote on behalf of Wikimedia Legal ([email protected]) as under:-

“Dear xxxxxxxxxx,

In order to provide nonpublic user information, the Wikimedia legal department requires a US court order or letter rogatory based on any court documents that may originate outside of the US. Please see the Requests for nonpublic user information procedures and guidelines for more information. Again, please direct any further legal queries to [email protected] ...”

Since the aforesaid acts and the accompanying attitude of Wikimedia (the Publisher of Wikipedia) are apparently wholly inconsistent with the Municipal Laws of India, the Petitioner was forced to carry out an informal investigation into the workings & finances of Wikipedia -- the aforesaid libellous entry (Post) published by Wikipedia was just the starting point for private person’s investigation; what matters the most in this PIL are the results of the said investigation -- which will shock the conscience of this Hon’ble Court and Government of India:- 

It is pertinent to mention at the very beginning that Ms. Carolyn Doran (a former Chief Operating Officer of Wikimedia Foundation Inc.) is said to have criminal records in at least four U.S. States, viz. Texas, Maryland, Virginia & Florida; Source:-

https://en.wikinews.org/wiki/Former_Chief_Operating_Officer_of_Wikimedia_Foundation_is_convicted_felon

A screenshot of the relevant portion of the said web-page is annexed herewith as Annexure-P/1 (Page 19). 

Some of the most visible unlawful acts of Wikimedia/ Wikipedia are given below:-  

Firstly, Wikipedia’s Logo (above) falsely and unfairly claims it to be an “Encylopedia”. Whereas, admittedly the ‘Editors’ of Wikipedia are not ‘subject-experts’ -- this material & crucial information has, however, been cleverly & cunningly placed on an obscure Page so as to evade ‘general public knowledge’ but, at the same time, it is an attempt to hoodwink the Law Enforcement Agencies & Hon’ble Courts IF the issue of mens rea of the persons managing the said Foundation & Wikipedia comes up for determination:

https://en.wikipedia.org/wiki/Wikipedia:Wikipedia_is_not_a_reliable_source

It is pertinent to quote a few excerpts from the above-mentioned web-page:

“Wikipedia is not a reliable source. Wikipedia can be edited by anyone at any time. This means that any information it contains at any particular time could be vandalism, a work in progress, or just plain wrong. Biographies of living persons, subjects that happen to be in the news, and politically or culturally contentious topics are especially vulnerable to these issues. Edits on Wikipedia that are in error may eventually be fixed. However, because Wikipedia is a volunteer run project, it cannot monitor every contribution all of the time. There are many errors that remain unnoticed for days, weeks, months, or even years. Therefore, Wikipedia should not be considered a definitive source in and of itself.” [Emphasis added]

A screenshot of the above-mentioned web-page (complete with its URL) is annexed herewith as Annexure-P/2 (Colly) (Pages 20-21). 

It is also found that at least one of the ‘Editors’ of Wikia.org (a Wiki started by Jimmy Wales -- who had co-founded Wikipedia alongwith Larry Sanger) had not even passed High School. Moreso, the True Identities, Educational Qualifications and Experience of ‘Editors’ are not generally displayed -- nay, these essential details were not even disclosed to a User of Wikipedia when he specifically requested Wikimedia to do so (the relevant documents will be produced at the time of Arguments); thus, even the statutory ‘Right to Information’ under the Right to Information Act 2005 is totally denied to those Indians who interact with Wikipedia from the Indian soil. On the other hand, the User is asked to obtain the requested information through a ‘Letter Rogatory’ (supra).        

Since Wikipedia fails to prominently display on its each & every web-page the admitted fact (supra) that it is not a reliable source [on the other hand, it suppresses this important & material fact on all its pages except the one cited above] and it falsely proclaims itself as Encyclopaedia, many students & others are wrongfully induced to rely upon Wikipedia’s contents in nearly the same way as one might rely upon the contents of Encyclopaedia Britannica. 

Secondly, Wikimedia (Publisher of Wikipedia) claims that it runs entirely upon Donations. The Petitioner put the following Questions to himself:-

Which rational person will ever pay (or donate) for such information as is admittedly unreliable, and is authored by those who have not even passed High School (supra)? So, what are the direct/ indirect services that Wikipedia may be rendering to attract payments or donations worth millions every year? 

To find the probable Answers to the above Questions, the Petitioner carried out experimental research by posting an Article titled ‘Pay & Allowances...’ on the Wikipedia. And it came to light that Wikipedia gives such detailed information about Indian Military Installations, Equipments, Squadrons, Secret Establishments etc that Pakistan’s ISI does not need to send its under-cover spies to India for covert operations -- to collect such Information.

When the Petitioner was posted at HQ xxxxxx in the year 1979, he was co-opted to set up an Intelligence Room in that HQ on the basis of printed classified material super-scribed as ‘Secret’; and Leader of that Project was ‘flagging’ (marking) with drawing pins on Pakistan’s map its airfields like ‘Sargodha’ etc. The Petitioner suggested that the Project must display ‘information’ that transcends what would be common knowledge to anyone in Pakistan -- for example, the length of the airfield, its structural strength to support landing & take-off by certain types of aircraft, etc. But blank spaces stared at the Petitioner in the said classified material on these important issues. 

Shockingly, Wikipedia shows not only the above information but also the Name(s) of Squadron(s) operating from the Indian Air Force Stations, the Types of Aircraft flown by these Squadrons, the Length & Direction of Runway(s), its Coordinates, its structure, and even detailed photographs -- the clarity & detail of a picture of Air Force Station Hindon (an important airfield which is assigned the duty to ensure air-safety of our National Capital, viz. New Delhi) uploaded on Wikipedia is such that it is doubtful whether the said Station itself has such a detailed aerial view of itself; it is common knowledge that photography of Military Installations is prohibited. Then how did Wikipedia acquire this picture, from whom, at what price, and for whose benefit -- without the same being ‘censored’ by our Military Intelligence? 

Cleverly & cunningly Wikipedia has created, in advance, a planned strategy -- that is to say, a ready-made alibi on this issue, viz. 

Wikipedia is an ‘encyclopaedia’; hence, ‘gathering of information’ is its legitimate activity. 

But the said alibi becomes untenable in view of the following additional facts:- 

Surprised by public-disclosure of such ‘sensitive’ information, the Petitioner investigated further as to who gathers such information, for what monetary or other reward, and how it is ‘accepted’ for publication by the Wikipedia. He found that there is a Network of ‘Editors’, ‘Reviewers’, ‘Admins’, ‘Clerks’ etc within Wikipedia -- who gather such information, determine the ‘rewards’ and publish the information; importantly, their Identities are kept hidden -- even if a Query is made through a ‘Letter Rogatory’, Wikimedia has purposely & mala fide created another alibi to screen its Agents who are involved in activities that may amount to espionage, e.g.:- 

Just about anyone can Create an ‘Account’ on Wikipedia and start Posting & Editing -- without disclosing his/ her Name, Educational Qualifications, Experience, email ID, Location etc; hence, it is not possible for the culprit -- who knowingly provides a platform for publishing the contents of Wikipedia, to assist any Law Enforcement Agency in booking the Criminal Offenders who directly commit a Crime under the IPC, I-T Act 2000, Official Secrets Act 1923, etc. 

Through the aforesaid elaborate and well-planned tactics, Wikipedia clandestinely & illegally attempts to screen those of its Agents who prima facie commit Criminal Offences in India -- although it is a Criminal Offence in India to ‘screen’ (hide, shield) any Offender.

Further investigations by the Petitioner revealed that key parameters/ guidelines set by Wikipedia for publishing ‘Posts’ on its website are as under:-

i) These should be written in neutral & formal manner; 

ii) These should be based upon “secondary” sources, not ‘primary’ or ‘original’ sources -- on the other hand, prestigious Research Journals demand ‘primary’ research, and even Hon’ble Courts prefer ‘primary’ evidence, instead of ‘secondary’ evidence;

iii) The subject-matter of the new Article (Post) should be ‘notable’-- that is to say, many persons should be interested in that Topic. 

But only 2 entities may perhaps be interested in ‘Air Force Station Suratgarh’, viz. IAF and the Pakistan’s ISI; if it is still ‘notable’ then why only 4-5 lines are written about it by Wikipedia? Moreso, Indian Air Force does not need to consult ‘Wikipedia’ to know about one of its own Stations/ Units; therefore, the only interested entity may be ISI -- which may even pay for such information as is material, timely & crucial for its clandestine Operations against India:

https://en.wikipedia.org/wiki/Suratgarh_Air_Force_Station

A screenshot of Wikipedia’s relevant page is annexed herewith as Annexure-P/3 (Page 22).

Moreso, a common surfer on the Net does not need Coordinates of any Military airfield; but the enemy country does need the same, e.g. IAF had used, inter alia, Coordinates & image(s) of Balakot for its recent surgical air-strike against Pakistani terrorists. The same goes for Wikipedia’s contents on ‘Air Force Station Hindon’:

https://en.wikipedia.org/wiki/Hindan_Air_Force_Station

https://en.wikipedia.org/wiki/Hindan_Air_Force_Station#/media/File:Delhi_and_surroundings_aerial_photo_08-2016_img7.jpg

Screenshots of Wikipedia’s relevant pages are annexed herewith as Annexure-P/4 (Colly) (Pages 23-24).  

In any case, when it is known that a Military Establishment has been accorded very ‘high security’ and is also ‘Out of Bounds’, then why should Wikipedia publish so many details about such Indian Military Establishments, e.g. ‘Establishment 22’, DRDO’s Establishment for War-Games &c in Metcalfe House, etc? The relevant URLs are:

https://en.wikipedia.org/wiki/Special_Frontier_Force

https://en.wikipedia.org/wiki/Metcalfe_House 

Screenshots of Wikipedia’s relevant pages are annexed herewith as Annexure-P/5 (Colly) (Pages 25-26).  

More importantly, how did Wikipedia get detailed Specifications of DRDO’s UAV-Project ‘Rustom’:

https://en.wikipedia.org/wiki/DRDO_Rustom

A screenshot of Wikipedia’s relevant page is annexed herewith as Annexure-P/6 (Page 27).  

Thirdly, the software used by Wikipedia is such that it is instantly possible to add any piece of information that is specifically requested by a client, and to promptly delete the same after reading it; moreso, the intended recipient can be ‘pinged’ while sending the information -- so that he/ she promptly notes it down and then deletes it before anyone else chances upon the same. And the Messages can even be encoded in such a way that only a certain ‘class’ of Users (e.g. ‘Admins’) can view the same. Moreso, Messages between Users appear on their ‘Talk’ Pages, and not within the body of an ‘Article’ (Post); therefore, even the Crawlers used by Search-Engines like Google are likely to miss such encoded Messages. If Google misses the same, then the less tech-savvy Security Agencies are more likely to miss the same, too. It is reliably learnt that Wikimedia has no inhibition in selling its software that allows, inter alia, the exchange of such encoded Messages.

May be, the information already displayed in its web-pages is only a teaser or advertisement or trailer to convey the message that more specific information can be collected and provided at an appropriate price by Wikipedia’s ‘screened’ operatives. 

Fourthly, Wikipedia has coined words & phrases like ‘legal threat’, ‘sock-puppetry’ etc -- which it loosely & vaguely defines, so that its aforesaid Agents may invoke the same to arbitrarily ‘block’ any User who appears to be investigating Wikipedia’s suspicious affairs. At times, even the IP Address of such a User or Group of Users is ‘blocked’ -- whereas taking recourse to Legal Remedies is a Basic Human Right under the Municipal Law & International Law. 

Despite Petitioner’s Legal Notice, Wikipedia committed another criminal offence punishable under the IPC and I-T Act 2000 by removing its following Webpage from its server and, thereby, ‘destroying evidence’, etc:

https://en.wikipedia.org/w/index.php?title=Hindu_College,_Delhi&diff=next&oldid=891125587

A copy of the screenshot is annexed herewith as Annexure-P/7 (Colly) (Pages 28-29).  

This is not for the first time that suspicious or unlawful activities of any ‘Wiki’ have come under the scanner -- Julian Paul Assange (Owner of WikiLeaks) is already on the run.

22.05.2019 Hence this Public Interest Litigation (Writ Petition) -- in the interests of National Security, Integrity & Sovereignty, and for Freedom of Indian Citizens.   

IN HON’BLE HIGH COURT OF ALLAHABAD (LUCKNOW BENCH)

(CRIMINAL ORIGINAL JURISDICTION)

WRIT PETITION (CRIMINAL) No. …………… /2019

 (Under Article 226 of the Constitution of India)

In-Trust Foundation (A Registered Charitable Trust) through xxxxx … Petitioner

IN THE MATTEROF:

In-Trust Foundation (A Registered Charitable Trust)

Through xxxxx Lucknow (India)    … Petitioner

Versus

1. Secretary, Ministry of Electronics and Information Technology

2. Secretary, Ministry of Home Affairs

3. Secretary, Ministry of Defence

4. Secretary, Telecom Regulatory Authority of India (TRAI)

5. Cyber Complaints Redressal Cell

Nodal Officer, Cyber Cell Agra, Agra Range 

7, Kutchery Road, Baluganj, Agra-232001 (Uttar Pradesh)

Through State of Uttar Pradesh

6. Wikimedia Foundation (Inc.)

Through Interim Legal Counsel

Email ID: [email protected]                        ... Respondents

A WRIT PETITION (PIL) UNDER ARTICLE 226 OF THE CONSTITUTION OF INDIA IN THE INTERESTS OF SECURITY, INTEGRITY & SOVEREIGNTY OF INDIA

To

Hon’ble the Chief Justice of High Court of Allahabad

and His Companion Judges of the

High Court of Allahabad (Lucknow Bench).

                            This Petition of the Petitioner above-named

MOST RESPECTFULLY SHOWETH:

1. That the present Writ Petition (PIL) is being filed in the interests of National Security, Integrity & Sovereignty -- details are given at Pages ‘5-11’ of the List of Dates & Events; for the sake of brevity and to avoid repetition & verbosity, the Petitioner hereby adopts -- as a part & parcel of this paragraph, the entire contents of the ‘List of Dates & Events’. And the Supporting Affidavit affirms the veracity of the said contents.

DECLARATION AS TO NON-FILING OF SIMILAR PETITION

2. The Petitioner states that no other Writ Petition on the same cause-of-action has been filed by him or In-Trust Foundation (Registered) in this Hon’ble Court or Hon’ble Supreme Court. 

QUESTIONS OF LAW:

3. The following Questions of Law of great general public importance arise for the consideration of and determination by this Hon’ble Court:-

A) WHETHER a foreign website which is neither educationally nor academically helpful to Indian citizens (on the other hand, which may admittedly misinform &/ or dis-inform them for years to come) and which is potentially dangerous, as a possible medium for espionage, to the Security, Integrity & Sovereignty of India, ought to be permitted to be displayed in India -- when it is possible for Internet Service Providers in India to ‘block’ the same? 

B) WHETHER any website should be allowed to masquerade as Encyclopaedia in India if its Editors are not ‘Subject-Experts’ (on the other hand, some of whom may not have passed even High School) -- to the detriment of Indian students & others who might succumb to the false claims made by the said website?

C) WHETHER it is legally permissible in India for any website to publish a libellous entry (remarks) but, at the same time, ‘screen’ the prima facie criminal offender by either refusing to disclose the True Identity & Particulars of the person who was permitted by the said website to post the said libellous entry on its web-pages or, for that matter, to permit anyone to post just about anything on its web-pages -- without even ascertaining his/ her verified particulars?

D) WHETHER any website should be legally permitted in India to gather, publish or otherwise circulate sensitive &/or classified information about Indian Military Installations, Equipments, Research & Development Projects, Airfields, etc -- without first getting the said information/ documents ‘censored’ by the Ministry of Defence and, moreso, without disclosing the ‘sources’ of the said information & documents (especially when the ‘Notings’ in official files of Defence Ministry were photocopied and leaked to the Media in Rafale case, or sensitive details were leaked to WikiLeaks)?

4. That in view of the facts & circumstances -- enumerated in the ‘List of Dates’, the Petitioner has come before this Hon’ble Court on the following, amongst others, 

GROUNDS

A) FOR THAT, as shown in the List of Dates & Events, Wikipedia is not reliable source of information and, therefore, it is neither educationally nor academically helpful to Indian citizens -- on the other hand, it may admittedly misinform &/ or dis-inform them for years to come; moreso, it is potentially dangerous, as a possible medium for espionage, to the Security, Integrity & Sovereignty of India. Hence, it ought not to be permitted to be displayed in India -- it is technically feasible for Internet Service Providers (ISPs) in India to ‘block’ the same (such blocks are already being applied to pornographic websites)?

B) FOR THAT Wikipedia’s Logo falsely claims that Wikipedia is Encyclopaedia -- even one of Wikipedia’s web-pages lists it as an encyclopaedia (the said page will be produced at the time of Arguments); under the Consumer Protection Act 1986, this would have amounted to an ‘unfair trade practice’ and ‘deficiency in service’ if Wikimedia had charged any price to access its contents. Wikipedia’s ‘Editors’ are not ‘Subject-Experts’ (on the other hand, some of them may not have passed even High School) and, admittedly, the contents of Wikipedia may be erroneous and remain so for years; thus, reliance upon such contents may even harm (misinform/ disinform) Indian students & general public in the long run?

C) FOR THAT it is legally not permissible in India for any website to publish a libellous entry (remarks) and, at the same time, illegally ‘screen’ the prima facie criminal offender by either refusing to disclose the True Identity & Particulars of the person who was permitted by the said website to post the said libellous entry on its web-pages or, for that matter, to permit anyone to post just about anything on its web-pages -- without even ascertaining his/ her verified particulars.

D) FOR THAT in the interests of National Security, Integrity & Sovereignty, no website ought to be legally permitted in India to gather, publish or otherwise circulate sensitive &/or classified information about Indian Military Installations, Equipments, Research & Development Projects, Airfields, etc -- without first getting the said information/ documents ‘censored’ by the Ministry of Defence and, moreso, without disclosing the ‘sources’ of the said information &/or documents; however, Wikipedia has committed breach of these cardinal rules. Especially when ‘Notings’ in official files of Defence Ministry were photocopied and leaked to the Media in Rafale’s case and sensitive details were leaked to WikiLeaks, suitable checks ought to be placed forthwith. Hence this PIL.

GROUNDS FOR URGENCY

5. As already stated above, grave potential threat to National Security, Integrity & Sovereignty of India exists; hence, the above matter needs to be investigated by a ‘public’ Agency like NIA, CBI, IB etc, forthwith.

MANDATORY PARAGRAPH ON PIL

6. The Petitioner is a Permanent Commissioned Officer (Commissioned for Life) and he fought the 1971-War for this Country; moreso, he has more than 30 years standing at the Bar (including as Advocate-on-Record, Supreme Court of India), he is a product of Top-10 Educational Institutes in India/ Asia, and an awardee of prestigious Scholarships like UGC’s NET (JRF/ SRF) etc. National Security, Integrity & Sovereignty are the public causes he is seeking to espouse in this PIL; and he has no personal or private interest in the matter -- except that his private citizen’s investigation led to the exposure of a potential network of espionage (as stated above, his investigation started with a libellous entry made on Wikipedia). Further that there is no authoritative pronouncement by Hon’ble Supreme Court or High Court on the Questions raised herein; and that the result of the Litigation will not lead to any undue gain to the Petitioner or anyone associated with him.

PRAYERS

In view of the above premises, it is respectfully prayed that this Hon’ble Court may be graciously pleased to:-

a) Direct Respondents Nos.1-4 to investigate the aforesaid breaches of Security, and initiate remedial steps forthwith -- since Security, Integrity & Sovereignty of India is involved;

b) Direct Respondent No.5 to investigate the matter, obtain the particulars of the accused from Wikimedia, and register an FIR under the IPC, I-T Act 2000 and Official Secrets Act 1923 etc;

c) Direct the Registry of this Hon’ble High Court to effect service of Show-Cause Notice upon all the Respondents at State’s expense;

d) Pass such other Writ, Order or Direction as may be deemed fit & proper in the facts & circumstances of this case. 

Place: Lucknow                             (xxxxxxxxxxxxxxxxxxxxx)

Date: 22.05.2019                            PETITIONER IN-PERSON

                           for & on behalf of In-Trust Foundation (Regd.)

Note by Author: The above CRL WP (PIL) No.15367/2019 came up for hearing before Hon'ble Court No.1 in High Court of Allahabad (Lucknow Bench) on 31.05.2019 and, being a Criminal Writ on Cyber Crime, it was directed to be listed "before an appropriate Bench" after Summer Vacations, i.e. in July 2019 -- it is reasonable to presume that, being a matter involving National Security, 'Patriotism' & 'Rashtravaad' demand that such sensitive matters ought to be heard on the date on which the same are already listed; IF Armed Forces, too, start 'adjourning' their Duties at the Border (say, even for 10 minutes on a single day) then, in the current technological scenario, half of India might be over-run by the aliens. Every Indian Citizen, therefore, reasonably expects that not only Military Personnel but also every 'public servant' (including judiciary) must be 'Patriotic' & Prompt when National Security is at stake. Jai Hind!