UIDAI Writ Petition

IN THE HIGH COURT OF DELHI AT NEW DELHI
EXTRAORDINARY ORIGINAL JURISDICTION

PUBLIC INTEREST LITIGATION
WRIT PETITION (CIVIL) NO. ____________ OF 2021
IN THE MATTER OF
ABHIJIT MISHRA PETITIONER
VERSES
UIDAI AND OTHER’S RESPONDENTS
INDEX
S. NO. PARTICULAR PAGE NO.
1. Urgent Application 1–2
2. Notice of Motion 3–4
3. Memo of Parties 5–6
4. Synopsis, Dates and Events 7–9
Writ Petition under Article 226 of the

5. Constitution of India along with Affidavit in 10 – 32
Support
Civil Miscellaneous Application u/s 151 of the

6. Code of Civil Procedure 1908 for seeking 33 – 37
exemption along with affidavit in support.
ANNEXURE P1
The true copy of the response from Respondent
No. 2 i.e. Reserve Bank of India that under the
7. Right to Information Act 2005 Respondent No. 38 – 41
3 – Google Pay is not registered / licensed
under the aegis of the Payments and Settlement
Systems Act 2007.
ANNEXURE P2
8. The true copy of the Respondent No. 2 Google 42 – 65
Pay’s Terms and Conditions.
ANNEXURE P3
The true copy of the respondent from
9. 66 – 67
Respondent No. 1 i.e. UIDAI under Right to
Information Act 2005.
ANNEXURE P4
The true copy of the Notification No. G.S.R.
538(E) in the Extra-Ordinary Gazette of India
10. published in PART II—Section 3—Sub- 68 – 77
section (i) as issued by Department of Revenue,
Ministry of Finance, Government of India
Dated 1st June 2017.
ANNEXURE P5
The true copy of the public notification Dated
11. 78
21st October 2017 as issued by the Respondent
No. 2 i.e. Reserve Bank of India.
ANNEXURE P6
12. The true copies of the representations made 79 – 89
before the authorities.
ANNEXURE P7
13. The true copies of the Email service of the 90 – 91
Advance copy of the Writ Petition.
14. VAKALATNAMA and Welfare Fee 92 – 94
FILED BY: PETITIONER-THROUGH ADVOCATE
DATE: 1st JANUARY 2021 ABHIJIT MISHRA

PLACE: NEW DELHI PETITIONER
THROUGH -
PAYAL BAHL
ADVOCATE
7, PRIYA ENCLAVE
NEW DELHI – 110092
MOBILE #09891578108
[email protected]
PAGE NO. 1

IN THE MATTER OF
VERSES
URGENT APPLICATION
To,
The Honourable Registrar,
High Court of Delhi,
Sher Shah Suri Marg,
New Delhi – 110001.
Respected Sir,
The present public interest litigation is filed in accordance and compliance to

the High Court of Delhi rules (PIL Rules Notification No. 451/ Rules/ DHC |
Dated November 25th, 2010) for issuance of writ, order or direction in nature
of mandamus or any other appropriate writ under Article 226 of the
Constitution of India for directions to the Respondent No. 1 i.e. UIDAI to take
appropriate initiatives under the aegis of Aadhar Act, 2016 for the protection
of the Aadhar information and privacy of the Citizens of India from
unauthorized access to the third party such as Respondent No. 3 i.e. Google
Pay. Thereby seeking directions to the respondents by way of Writ of
Mandamus or any other writ deems fit and proper on urgent basis.
It is submitted that the urgent mentioning vide reference no. reference No :

1609300058391_57693 was made before the Honourable High Court of Delhi
on 30th December 2020, which is duly accepted for hearing by the Honourable
Court.
PAGE NO. 2

THROUGH -
PAYAL BAHL
ADVOCATE
7, PRIYA ENCLAVE
MOBILE #09891578108
[email protected]
PAGE NO. 3

IN THE MATTER OF
VERSES
NOTICE OF MOTION
To,
Unique Identification Authority Of India,
Through the Honourable Chief Executive Officer,
Government of India,
Bangla Sahib Rd, Behind Kali Mandir,
Gole Market, New Delhi – 110001
Email [email protected]
Through
Advocate Mr. Mohd. Muqeem,
The Honourable Counsel,
High Court of Delhi.
Mobile 09999864964
[email protected]
Honourable Sir,
Please find the paper book for the purpose of advance service in the Public
Interest Litigation by the way of Writ Petition (Civil) with title "Abhijit
Mishra v/s UIDAI and Others" for your kind perusal and necessary actions. It
is submitted that the Writ Petition is likely to be listed for hearing on or before
11th January 2021. This is for your kind information and necessary action.
PAGE NO. 4

THROUGH -
PAYAL BAHL
ADVOCATE
7, PRIYA ENCLAVE
MOBILE #09891578108
[email protected]
PAGE NO. 5

IN THE MATTER OF
VERSES
IN THE MATTER OF PUBLIC INTEREST LITIGATION

MEMO OF PARTIES
Abhijit Mishra Writ Petitioner

S/O (Late) Mr. Om Prakash Mishra
R/O – 7, Priya Enclave,
[email protected]
Versus
Unique Identification Authority Of India, Respondent - 1

Through the Honourable Chief Executive Officer,
Government of India,
Bangla Sahib Rd, Behind Kali Mandir,
Gole Market, New Delhi – 110001
Email [email protected]
Reserve Bank of India, Respondent - 2

Through, The Honorable Governor,
6, Sansad Marg,
Email- [email protected]
PAGE NO. 6
Google India Digital Services Private Limited Respondents – 3

Doing business as “Google Pay”,
Through the Honourable Directors,
Unit 207, 2nd Floor Signature Tower-II Tower A,
Sector 15 Part II Silokhera,
Gurgaon, Haryana, India, 122001.
CIN No. U74999HR2017PTC067218
Email - [email protected]

THROUGH -
PAYAL BAHL
ADVOCATE
7, PRIYA ENCLAVE
MOBILE #09891578108
[email protected]
Note: For the sake of brevity and avoiding prolixity.

1. The Respondent No. 1 i.e. Unique Identification Authority Of India is
referred and abbreviated as UIDAI in the present Writ Petition.
2. The Respondent No. 2 i.e. Google India Digital Services Private
Limited is referred as Google Pay in the present Writ Petition.
PAGE NO. 7

IN THE MATTER OF
VERSES
SYNOPSIS, DATES AND EVENTS
The present public interest litigation highlights the grave issue of the
unauthorized access, use and storing of the Aadhar and banking information
of the Citizens of India by the Respondent No. 3 i.e. Google Pay in sheer
violation of the Article 21 of the Constitution of India, Aadhar Act 2016,
Payments and Settlement Systems Act 2007 and Banking Regulations Act
1949. It is submitted that the Respondent No. 3 i.e. Google Pay in their terms
and conditions have specially and explicitly mentioned that Google Pay will
collect, store and share the Bank Account or Aadhar details.
Terms and Conditions of Google Pay
You, hereby expressly consent to and permit Google or its group
companies to collect, store and share such information including
but not limited to your or user personal information such as your
name, address, Google Account or payment instructions details,
all transactions carried out by Google Pay or information with
respect to the third parties including Bank Account or Aadhar
details for the purposes mentioned in the combined Google Pay
for Business Terms.
This public interest litigation voices against the unconstitutional conduct and
seeks for the Writ of Mandamus to the State to address such violation.
HENCE, THE PRESENT WRIT PETITION

AS A PUBLIC INTEREST LITIGATION
PAGE NO. 8
DATES AND EVENTS

DATES EVENTS
The Writ Petitioner made representation to the

office of the following authorities against the
unauthorized operations of the Google Pay in
29th March 2019 violation of the banking laws.
1. Honourable Chief Justice of Delhi
2. Respondent No. 2 i.e. Honourable Governor,
Reserve Bank of India

31st March 2019 Respondent No. 3 i.e. Google Pay against its
unauthorized operations under the banking laws.
The Writ Petitioner received the response under

Right to Information Act 2005 from the Respondent
9th September 2019
No. 2 i.e. Honourable Governor, Reserve Bank of
India that Respondent No. 3 i.e. Google Pay is not
registered or licensed under the banking laws.
The Writ Petitioner received the response under

Right to Information Act 2005 from the Respondent
4th March 2020 No. 1 i.e. UIDAI that Respondent No. 3 i.e. Google
Pay is not permitted to collect, use and store the
Aadhar details the under the Aadhar Act 2016.

11th March 2020 office of the Chief Executive Officer, UIDAI against
the unauthorized operations of the Google Pay in
violation of the banking laws and Aadhar Act 2016
PAGE NO. 9
The petitioner made endeavor to list the Public

Interest Litigation, but the matter was not selected
April 2020
for urgent listing.
To
December 2020
The Honourable High Court of Delhi allowed the
listing of the Writ Petition on 30th December 2020.
HENCE, THE PRESENT WRIT PETITION

AS A PUBLIC INTEREST LITIGATION
PAGE NO. 10

IN THE MATTER OF
VERSES
THE PRESENT PUBLIC INTEREST LITIGATION IS FILED UNDER

THE AEGIS OF ARTICLE 226 OF THE CONSTITUTION OF INDIA FOR
THE ISSUANCE OF WRIT, ORDER OR DIRECTION IN NATURE OF
MANDAMUS OR ANY OTHER APPROPRIATE WRIT FOR THE
DIRECTIONS TO THE UIDAI (RESPONDENT NO. 1) TO TAKE
APPROPRIATE INITIATIVES UNDER THE AEGIS OF AADHAR ACT,
2016 FOR THE PROTECTION OF THE AADHAR DETAILS AND
PRIVACY OF THE CITIZENS OF INDIA UNDER THE AEGIS OF
ARTICLE 21 OF THE CONSTITUTION OF INDIA FROM
UNAUTHORIZED ACCESS TO THE THIRD PARTY I.E. GOOGLE PAY
(RESPONDENT NO. 3). ALSO TO ISSUE DIRECTION TO UIDAI
(RESPONDENT NO. 1) AND RESERVE BANK OF INDIA
(RESPONDENT NO. 2)TO JOINTLY MAKE REGULATIONS AGAINST
UNAUTHORIZED ACCESS OF BANKING DATA OF THE CITIZENS TO
THE THIRD PARTY I.E. GOOGLE PAY (RESPONDENT NO. 3).
TO,
THE HONOURABLE CHIEF JUSTICE,
AND HIS LORDSHIP’S COMPANION JUSTICES OF THE,
HIGH COURT OF DELHI AT NEW DELHI
A HUMBLE WRIT PETITION

OF THE PETITIONER
PAGE NO. 11
MOST RESPECTFULLY SHOWETH:
1. It is respectfully submitted that the Writ Petitioner has no personal interest

in the litigation and that the petition is not guided by self- gain or for gain
of any person / institution / body and that there is no motive other than of
public interest in filing of the present Writ Petition. It is submitted that the
Writ Petitioner is indebted to the great nation - India and deemed duty
bound for the welfare of the Nation under the aegis of the Article 51A of
the Constitution of India.
2. It is respectfully submitted that Writ Petitioner has gathered all the relevant
information through various RTI applications and letters filed before the
Honourable Chief Executive Officer, Unique Identification Authority Of
India - Government of India and Honourable Governor, Reserve Bank of
India who are entrusted of implementing, administrating and managing the
Aadhar Act, 2016, Payments and Settlement Systems Act 2007 and
Banking Regulations Act 1949 respectively.
3. It is respectfully submitted that the questions of public importance are

being raised in the present Public Interest Litigation that illuminates the
unauthorized access of the Aadhar and Banking information of the Citizen
in sheer violation of the Aadhar Act 2016, Payments and Settlement
Systems Act 2007 and Banking Regulations Act 1949. It is submitted that
the unauthorized / unlicensed / unregistered entity Respondent No. 3 i.e.
Google Pay is collecting the Aadhar and banking transaction details of the
citizens of India which is sheer violation of the above-mentioned act along
with Article 21 of the Constitution of India.
4. That the Persons affected by such acts of the respondents are numerous
and are not in a position to approach the Honorable Court, hence the
Petitioner is filing on behalf of such affected Persons and except for the
Present Respondent no other parties are affected by the present Public
Interest Litigation.
5. It is submitted that the Writ Petitioner is a financial economist and has

earned Master of Science in Public Policy and Management from Carnegie
PAGE NO. 12
Mellon University, United States of America and has global experience in

the matters of Public Policy and Economics. The Writ Petitioner
undertakes to pay the costs if any imposed by the court on this Writ Petition
at any stage of the proceedings.
6. That the writ petitioner has done various representation before the
Honourable Chief Justice of Delhi- High Court of Delhi, Honourable Chief
Executive Officer, Unique Identification Authority Of India - Government
of India and Honourable Governor, Reserve Bank of India for the
unauthorized access of the Aadhar and Banking information of the Citizen
in sheer violation of the Article 21 of the Constitution of India, Aadhar Act
2016, Payments and Settlement Systems Act 2007 and Banking
Regulations Act 1949.
FACTS OF THE CASE
7. It is respectfully submitted that the Respondent No. 2 i.e. Reserve Bank of

India is the esteemed regulator of the Banking laws (Banking Regulations
Act 1949) and Payments laws (Payments and Settlements Systems Act
2007) in India. It is submitted that the Respondent No. 3 – Google Pay is
not registered / licensed under the aegis of the Payments and Settlement
Systems Act 2007 to conduct the business of payments and transactions. It
is further submitted that the Respondent No. 3 – Google Pay is also not
registered / licensed as a Bank / Co-Operative Bank / Financial Institution
/ Non-Banking Finance Company under the aegis of the Banking
Regulations Act 1949 to conduct the business of payments and processing
the transactions. The information obtained under Right to Information Act
2005 from the Reserve Bank of India. The true copy of the response from
Respondent No. 2 i.e. Reserve Bank of India that under the Right to
Information Act 2005 Respondent No. 3 – Google Pay is not registered /
licensed under the aegis of the Payments and Settlement Systems Act 2007
is herewith annexed and marked as ANNEXURE P1.
8. It is respectfully submitted that contrary to the provisions Banking laws

(Banking Regulations Act 1949) and Payments laws (Payments and
Settlements Systems Act 2007) in India, the Respondent No. 3 – Google
PAGE NO. 13
Pay is conducting the business of payment transfers and transactions

processing. It is respectfully submitted that the Petitioner craves to seek
leave of the Honourable Court to kindly refer to the Terms and Conditions
of Respondent No. 3 i.e. Google Pay which explicitly states that the
company will be storing the payment instruction details of the Parties
including Bank Accounts and Aadhar details. The true copy of the
Respondent No. 2 Google Pay’s Terms and Conditions are herewith
annexed and marked as ANNEXURE P2.
Terms and Conditions of Google Pay

You, hereby expressly consent to and permit Google or its group
companies to collect, store and share such information including
but not limited to your or user personal information such as your
name, address, Google Account or payment instructions details,
all transactions carried out by Google Pay or information with
respect to the third parties including Bank Account or Aadhar
details for the purposes mentioned in the combined Google Pay
for Business Terms.
9. It is respectfully submitted that the Petitioner craves to seek leave of the

Honourable Court to kindly refer to the response of the Respondent No. 1
i.e. UIDAI under the aegis of Right to Information Act 2005. The true copy
of the respondent from Respondent No. 1 i.e. UIDAI under Right to
Information Act 2005 is herewith annexed and marked as ANNEXURE
P3.
The salient conclusion from the response of the UIDAI response

I. It is submitted that the Respondent No. 1 i.e. UIDAI has not
issued permission to the Respondent No. 3 i.e. Google Pay to
access, use and store the citizens AADHAR details or the
database.
II. It is submitted that the Respondent No. 1 i.e. UIDAI has not
received information from Respondent No. 2 i.e. Reserve Bank
of India such that it has given permission to the Respondent No.
3 i.e. Google Pay for access, use and store the citizens AADHAR
details or the database.
PAGE NO. 14
III. The Respondent No. 1 i.e. UIDAI has not received an application
from Respondent No. 3 i.e. Google Pay for access, use and store
the citizens AADHAR details or the database.
X-------------------------------X---------------------------X
Right to Information Response is as follows:-
Question 1. Has the Unique Identification Authority of India

permitted Google India Digital Services Private Limited doing
business as Google Pay (Mobile Payments Application) to
access and use citizens AADHAR database / platform for
processing and authentication of payments using BHIM Aadhar
platform as on 7 February 2020. If yes then please provide the
details of the permission issued by Unique Identification
Authority of India.
UIDAI Answer: NO

received information from Reserve Bank of India that, Reserve
Bank of India has given permission to the Google India Digital
Services Private Limited doing business as Google Pay (Mobile
Payments Application) is accessing and using AADHAR
database / platform for processing and authentication of
payments via BHIM Aadhar platform as on 7 February 2020. If
yes then please provide the details.
UIDAI Answer: NO

received application from Google India Digital Services Private
Limited doing business as Google Pay (Mobile Payments
Application) for accessing and using AADHAR database /
platform for processing and authentication of payments via
PAGE NO. 15
BHIM Aadhar platform as on 7 February 2020. If yes then please

provide the details.
UIDAI Answer: NO
X-------------------------------X---------------------------X
Honourable Court to kindly refer to the Notification No. G.S.R. 538(E) in
the Extra-Ordinary Gazette of India published in PART II—Section 3—
Sub-section (i) as issued by Department of Revenue, Ministry of Finance,
Government of India Dated 1st June 2017. It is submitted that the
Government of India (Department of Revenue, Ministry of Finance) in
consultation, aid and advise of the Respondent No. 2 i.e. Reserve Bank of
India has brought the amendments to the Prevention of Money-laundering
(Maintenance of Records) Rules, 2005 in exercise of the powers conferred
under the aegis Section 73 of the Prevention of Money-laundering Act,
2002 (15 of 2003). It is submitted that by the virtue of the said rules the
AADHAR number seeding of the banking information is there made
mandatory and statutory. Hence, it is submitted that the banking details of
the Citizen has an essential information element of the Aadhar details. The
true copy of the Notification No. G.S.R. 538(E) in the Extra-Ordinary
Gazette of India published in PART II—Section 3—Sub-section (i) as
issued by Department of Revenue, Ministry of Finance, Government of
India Dated 1st June 2017 is herewith annexed and marked as ANNEXURE
P4.
Honourable Court to kindly refer to the public notification as issued by the
Respondent No. 2 i.e. Reserve Bank of India that the Aadhar seeding in
the banking information / details is a mandatory for every citizen of India.
It is respectfully submitted that the Respondent No. 2 i.e. Reserve Bank of
India has duly linkage of Aadhaar number to bank account is mandatory
under the Prevention of Money-laundering (Maintenance of Records)
Second Amendment Rules, 2017 and these rules have statutory force. The
true copy of the public notification Dated 21st October 2017 as issued by
PAGE NO. 16
the Respondent No. 2 i.e. Reserve Bank of India is herewith annexed and
marked as ANNEXURE P5.
12. It is submitted that the Respondent No. 3 i.e. Google Pay has unauthorized
access to the banking details and Aadhar details by the virtue of its
operations by the of banking transfers and transactions which is not
licensed and authorized by the Respondent No. 2 i.e. Reserve Bank of
India under the aegis of Payments and Settlement Systems Act 2007 and
Banking Regulations Act 1949. It is respectfully submitted that the
Respondent No. 3 i.e. Google Pay under its “Terms and Conditions” under
mechanics of payment transaction clearly mentions that “We create a link
between the Sender, the Recipient and the respective Payments System
Providers to facilitate sending and/or receiving payments using Payments
System Provider Services. It is submitted that it is deemed admission on
the part of the Respondent No. 3 i.e. Google Pay that by the virtue of its
involvement as a link between respective of Payments System Providers
to facilitate sending and/or receiving payments it has complete access to
the banking information which includes Aadhar information as well.
“Mechanics of Payment Transaction. The Payment Transactions

or any communication/offers carried out through Google Pay
are solely between the Sender and Recipient of the payment. We
create a link between the Sender, the Recipient and the respective
Payments System Providers to facilitate sending and/or
receiving payments using Payments System Provider Services.
Once a Payment Transaction has been authenticated, authorised
and processed through the Payments System Provider Services-
(i) the payment may be settled directly with the Recipient

by the respective Payments Participants; or
(ii) in certain scenarios, we may act as an intermediary

and receive funds pertaining to the Payment Transaction
on behalf of the Recipient. In such scenarios, Google
would operate purely as the Recipient’s payment
PAGE NO. 17
collection agent for the limited purpose of accepting funds

from Users.”
Honourable Court to kindly appreciate the core provision of the Article 21
of the Constitution of India. It is respectfully submitted that reads as: “No
person shall be deprived of his life or personal liberty except according to
procedure established by law”. It is respectfully submitted that as the
Respondent No. 3 i.e. Google Pay is neither registered or authorized or
licensed or permitted by either Respondent No. 1 i.e. UIDAI and/or
Respondent No. 2 i.e. Reserve Bank of India. Hence, the payment link
activities of Respondent No. 3 i.e. Google Pay are prima facie violative of
the core aspect i.e. “according to procedure established by law” of the
Article 21 of the Constitution of India.
Honourable Court to kindly refer to the Section 28 of the Aadhar Act 2016.
It is respectfully submitted that it is the responsibility of the Respondent
No. 1 i.e. UIDAI towards ensuing the security of AADHAR information,
identity and confidentiality of the individuals. It is submitted that the
Respondent No. 1 i.e. UIDAI turned blind eyes to the complaint towards
complaint against authorized access, use and storing of the Aadhar /
Banking information by the Respondent No. 3 i.e. Google Pay.
Section 28 of the Aadhaar Act, 2016

Security and confidentiality of information.—
(1) The Authority shall ensure the security of identity information
and authentication records of individuals.
(2) Subject to the provisions of this Act, the Authority shall
ensure confidentiality of identity information and authentication
records of individuals.
(3) The Authority shall take all necessary measures to ensure that
the information in the possession or control of the Authority,
including information stored in the Central Identities Data
Repository, is secured and protected against access, use or
disclosure not permitted under this Act or regulations made
PAGE NO. 18
thereunder, and against accidental or intentional destruction,

loss or damage.
(4) Without prejudice to sub-sections (1) and (2), the Authority
shall—
(a) adopt and implement appropriate technical and
organisational security measures;
(b) ensure that the agencies, consultants, advisors or other
persons appointed or engaged for performing any function
of the Authority under this Act, have in place appropriate
technical and organisational security measures for the
information; and
(c) ensure that the agreements or arrangements entered
into with such agencies, consultants, advisors or other
persons, impose obligations equivalent to those imposed
on the Authority under this Act, and require such agencies,
consultants, advisors and other persons to act only on
instructions from the Authority.
(5) Notwithstanding anything contained in any other law for the
time being in force, and save as otherwise provided in this Act,
the Authority or any of its officers or other employees or any
agency that maintains the Central Identities Data Repository
shall not, whether during his service or thereafter, reveal any
information stored in the Central Identities Data Repository or
authentication record to anyone:
Provided that an Aadhaar number holder may request the
Authority to provide access to his identity information excluding
his core biometric information in such manner as may be
specified by regulations.
It is respectfully submitted that by the virtue of the statue itself That
Aadhar identity information can be shared only in accordance with the
provisions of this Aadhar Act 2016. It is submitted that as the Respondent
No. 3 i.e. Google Pay is collecting the banking and Aadhar details, thus it
PAGE NO. 19
is in prima facie violation on the part of the Respondent No. 3 i.e. Google
Pay of the Section 29 (2) and (4) of the Aadhar Act 2016.
Section 29. of the Aadhaar Act, 2016

Restriction on sharing information.—
(1) No core biometric information, collected or created
under this Act, shall be—
(a) shared with anyone for any reason whatsoever; or
(b) used for any purpose other than generation of Aadhaar
numbers and authentication under this Act.
(2) The identity information, other than core biometric
information, collected or created under this Act may be shared
only in accordance with the provisions of this Act and in such
manner as may be specified by regulations.
(3) No identity information available with a requesting entity or
offline verification-seeking entity shall be—
(a) used for any purpose, other than the purposes informed
in writing to the individual at the time of submitting any
information for authentication or offline verification; or
(b) disclosed for any purpose, other than purposes
informed in writing to the individual at the time of
submitting any information for authentication or offline
verification:
Provided that the purposes under clauses (a) and (b) shall
be in clear and precise language understandable to the
individual.
(4) No Aadhaar number demographic information or
photograph collected or created under this Act in respect of an
Aadhaar number holder shall be published, displayed or posted
publicly, except for the purposes as may be specified by
regulations.
It is respectfully submitted that Respondent No. 3 i.e. Google Pay is
PAGE NO. 20
collecting the banking and Aadhar details, thus it is in prima facie violation
of the Section 38 (g) and (i) of the Aadhar Act 2016.
Section 38 of the Aadhar Act, 2016

Penalty for unauthorised access to the Central Identities Data
Repository.—Whoever, not being authorised by the Authority,
intentionally,—
(a) accesses or secures access to the Central Identities
Data Repository;
(b) downloads, copies or extracts any data from the
Central Identities Data Repository or stored in any
removable storage medium;
(c) introduces or causes to be introduced any virus or
other computer contaminant in the Central Identities Data
Repository;
(d) damages or causes to be damaged the data in the
Central Identities Data Repository;
(e) disrupts or causes disruption of the access to the
Central Identities Data Repository;
(f) denies or causes a denial of access to any person who
is authorised to access the Central Identities Data
Repository;
(g) reveals any information in contravention of sub-
section (5) of section 28, or shares, uses or displays
information in contravention of section 29 or assists any
person in any of the aforementioned acts;
(h) destroys, deletes or alters any information stored in
any removable storage media or in the Central Identities
Data Repository or diminishes its value or utility or affects
it injuriously by any means; or
(i) steals, conceals, destroys or alters or causes any person
to steal, conceal, destroy or alter any computer source
code used by the Authority with an intention to cause
damage,
PAGE NO. 21
shall be punishable with imprisonment for a term which may

extend to three years ten years and shall also be liable to a fine
which shall not be less than ten lakh rupees.
It is respectfully submitted that Respondent No. 3 i.e. Google Pay is a
registered private limited company by the Registrar of Companies (Delhi
and Haryana) having Corporate Identification Number as
U74999HR2017PTC067218. Thus, the Section 43 of the Aadhar Act 2016
is duly applicable on them by the virtue of their activities against the
objects of the Aadhar Act 2016.
Section 43 of the Aadhar Act, 2016

Offences by companies.—
(1) Where an offence under this Act has been committed by a
company, every person who at the time the offence was
committed was in charge of, and was responsible to, the company
for the conduct of the business of the company, as well as the
company, shall be deemed to be guilty of the offence and shall be
liable to be proceeded against and punished accordingly:
Provided that nothing contained in this sub-section shall render
any such person liable to any punishment provided in this Act if
he proves that the offence was committed without his knowledge
or that he had exercised all due diligence to prevent the
commission of such offence.
(2) Notwithstanding anything contained in sub-section (1),

where any offence under this Act has been committed by a
company and it is proved that the offence has been committed
with the consent or connivance of, or is attributable to, any
neglect on the part of any director, manager, secretary or other
officer of the company, such director, manager, secretary or
other officer shall also be deemed to be guilty of the offence and
shall be liable to be proceeded against and punished
accordingly.
PAGE NO. 22
18. It is submitted that such heinous, unpardonable and unconstitutional

conduct of Respondents – 3 i.e. Google Pay of collecting, storing, and
using of the citizens Aadhar, banking personal data and any
communications routed through its servers is in complete contravention of
the Aadhar Act 2016 and is a deemed compromise and violation of the
“Fundamental Right of Privacy” as enshrined under the provisions of
Article 21 of the Constitution of India. It is pertinent to note that
Respondents – 3 i.e. Google Pay is neither licensed and/or registered with
Respondents – 2 i.e. Reserve Bank of India to conduct the business of
payments and transactions using banking channel. This act of Respondents
– 3 i.e. Google Pay is strictly against the Article 21 of the Constitution of
India and violative of the fundamental “Right to Privacy” of the Citizens.
The petitioner pleads before the Honourable Court to kindly refer to the
following landmark judgments of the Honourable Supreme Court of India
in the matter of “Ram Jethmalani v/s Union of India” (As cited in (2011)
8 SCC 1:JT 2011 (7) SC 104: (2011) 6 SCALE 691). The Honourable
Supreme Court of India has duly stated that “Right to Privacy is an integral
part of life. This is a cherished constitutional value, and it is important that
human being be allowed domains of freedom that are free of public
scrutiny unless they act in unlawful manner”
19. It is most respectfully submitted that the Petitioner craves for the leave of
the Honourable Court to kindly refer to the judgement of the Honourable
Supreme Court of India in the matter of “Justice K S Puttaswamy v/s Union
of India” (Writ Petition (Civil) No. 494 of 2012 | (2017) 10 SCC 1). It is
submitted that the Honourable Supreme Court has duly held that Right to
Privacy is a fundamental right as enshrined under Article 21 of the
Constitution of India which reads as: “No person shall be deprived of his
life or personal liberty except according to procedure established by law”.
It is submitted that the judgment of the Honourable Court has established
that the privacy is a fundamental inalienable right, intrinsic to human
dignity and liberty under article 21 of the constitution of India. It is
submitted that the heinous act by the Respondent No. 3 i.e. Google Pay of
accessing, storing and using the banking and Aadhar information without
PAGE NO. 23
the permission, knowledge, authorization and consent of the Respondent

No. 1 UIDAI and Respondent No. 2 i.e. Reserve Bank of India is in
violation of the Right to Privacy as enshrined under the aegis of the Article
21 of the Constitution of India.
Excerpts of the Judgement

CONCLUSION
Para 3
(A) Life and personal liberty are inalienable rights. These
are rights which are inseparable from a dignified human
existence. The dignity of the individual, equality between
human beings and the quest for liberty are the
foundational pillars of the Indian Constitution;
(B) Life and personal liberty are not creations of the

Constitution. These rights are recognised by the
Constitution as inhering in each individual as an intrinsic
and inseparable part of the human element which dwells
within;
(C) Privacy is a constitutionally protected right which

emerges primarily from the guarantee of life and personal
liberty in Article 21 of the Constitution. Elements of
privacy also arise in varying contexts from the other facets
of freedom and dignity recognised and guaranteed by the
fundamental rights contained in Part III;
(D) Judicial recognition of the existence of a

constitutional right of privacy is not an exercise in the
nature of amending the Constitution nor is the Court
embarking on a constitutional function of that nature
which is entrusted to Parliament;
(E) Privacy is the constitutional core of human dignity.

Privacy has both a normative and descriptive function. At
a normative level privacy sub-serves those eternal values
PAGE NO. 24
upon which the guarantees of life, liberty and freedom are

founded. At a descriptive level, privacy postulates a
bundle of entitlements and interests which lie at the
foundation of ordered liberty;
(F) Privacy includes at its core the preservation of

personal intimacies, the sanctity of family life, marriage,
procreation, the home and sexual orientation. Privacy
also connotes a right to be left alone. Privacy safeguards
individual autonomy and recognises the ability of the
individual to control vital aspects of his or her life.
Personal choices governing a way of life are intrinsic to
privacy. Privacy protects heterogeneity and recognises
the plurality and diversity of our culture. While the
legitimate expectation of privacy may vary from the
intimate zone to the private zone and from the private to
the public arenas, it is important to underscore that
privacy is not lost or surrendered merely because the
individual is in a public place. Privacy attaches to the
person since it is an essential facet of the dignity of the
human being;
(G) This Court has not embarked upon an exhaustive

enumeration or a catalogue of entitlements or interests
comprised in the right to privacy. The Constitution must
evolve with the felt necessities of time to meet the
challenges thrown up in a democratic order governed by
the rule of law. The meaning of the Constitution cannot be
frozen on the perspectives present when it was adopted.
Technological change has given rise to concerns which
were not present seven decades ago and the rapid growth
of technology may render obsolescent many notions of the
present. Hence the interpretation of the Constitution must
be resilient and flexible to allow future generations to
adapt its content bearing in mind its basic or essential
features;
PAGE NO. 25
(H) Like other rights which form part of the fundamental

freedoms protected by Part III, including the right to life
and personal liberty under Article 21, privacy is not an
absolute right. A law which encroaches upon privacy will
have to withstand the touchstone of permissible
restrictions on fundamental rights. In the context of Article
21 an invasion of privacy must be justified on the basis of
a law which stipulates a procedure which is fair, just and
reasonable. The law must also be valid with reference to
the encroachment on life and personal liberty under
Article 21. An invasion of life or personal liberty must
meet the three-fold requirement of (i) legality, which
postulates the existence of law; (ii) need, defined in terms
of a legitimate state aim; and (iii) proportionality which
ensures a rational nexus between the objects and the
means adopted to achieve them; and
(I) Privacy has both positive and negative content. The

negative content restrains the state from committing an
intrusion upon the life and personal liberty of a citizen. Its
positive content imposes an obligation on the state to take
all necessary measures to protect the privacy of the
individual.
Para 5 Informational privacy is a facet of the right to privacy.

The dangers to privacy in an age of information can originate
not only from the state but from non-state actors as well. We
commend to the Union Government the need to examine and put
into place a robust regime for data protection. The creation of
such a regime requires a careful and sensitive balance between
individual interests and legitimate concerns of the state. The
legitimate aims of the state would include for instance protecting
national security, preventing and investigating crime,
encouraging innovation and the spread of knowledge, and
preventing the dissipation of social welfare benefits. These are
PAGE NO. 26
matters of policy to be considered by the Union government

while designing a carefully structured regime for the protection
of the data. Since the Union government has informed the Court
that it has constituted a Committee chaired by Hon’ble Shri
Justice B N Srikrishna, former Judge of this Court, for that
purpose, the matter shall be dealt with appropriately by the
Union government having due regard to what has been set out in
this judgment.
Honorable Court to kindly refer to the Section 23 and Section 24 of the
Indian Contract Act 1872. The terms and conditions & contract of the
Respondent No. 3 i.e. Google Pay is void ab initio by the virtue of the
unlawful considerations which are forbidden by the law. It is submitted
that the Respondent No. 3 i.e. Google Pay is not competent to get into the
agreement with the public at large for being a facilitator of the payments
transactions as it is not a registered and licensed entity by the Respondent
No. 2 i.e. Reserve Bank of India under the aegis of Payments and
Settlement Systems Act 2007 and Banking Regulations Act 1949.
21. It is submitted that aggrieved by the aforesaid act, the Petitioner is before
the Hon’ble Court, inter-alia on the following grounds:-
a. BECAUSE – The Respondent No. 1 i.e. UIDAI and Respondent

No. 2 i.e. Reserve Bank of India have not provided any consent,
authorization, license and / or permission to collect, store and use
the banking and Aadhar Information of the citizens to the
Respondent No. 3 i.e. Google Pay.
b. BECAUSE - Respondent No. 3 i.e. Google Pay is operating in

violation of the Aadhar Act 2016 as it is collecting, using and
storing the Aadhar information of the Citizens without any
consent, authorization, license and / or permission Respondent
No. 1 i.e. UIDAI.
PAGE NO. 27
c. BECAUSE –The Respondent No. 1 i.e. UIDAI under the Aadhar

Act 2016 and Respondent No. 2 i.e. Reserve Bank of India under
Payments and Settlement Systems Act 2007 / Banking
Regulations Act 1949 are the regulator and under the fiduciary
responsibility to work according to the objects of the Act.
d. BECAUSE - Respondent No. 3 i.e. Google Pay being a private

company is not empowered to collect, use and store Aadhar and
Banking information of the citizens without being registered
under the provisions as established by the law.
e. BECAUSE – The Respondent No. 3 i.e. Google Pay has been

operating against the principles and objectives established by the
law under the aegis of Aadhar Act 2016, Payments and
Settlement Systems Act 2007 and Banking Regulations Act
1949.
22. It is respectfully submitted that by the virtue of the present petition, the
following questions of law are being raised
a. Whether an unregistered and unlicensed entity under Payments

and Settlement Systems Act 2007 and Banking Regulations Act
1949 by the Respondent No. 2 i.e. Reserve Bank of India can
collect, store and use the Aadhar and Banking information of the
citizens of India ?
b. Whether the Respondent No. 3 i.e. Google Pay can collect, store
and use the Aadhar and Banking information of the citizens of
India in violation of the Aadhar Act 2016, Payments and
Settlement Systems Act 2007 and Banking Regulations Act 1949
?
c. Whether the acts of the Respondent No. 3 i.e. Google Pay to

collect, store and use the Aadhar and Banking information of the
citizens of India in violation of the Right to Privacy of the
PAGE NO. 28
Citizens of India under the aegis of Article 21 of the Constitution

of India ?
d. Whether the existence of the Respondent No. 3 i.e. Google Pay

which are unregistered payments entity are ultra vires, against
the legal objects and framework of the Aadhar Act 2013,
Payments, Settlement Systems Act 2007 and Banking
Regulations Act 1949 ?
e. Whether the actions of the Respondent No. 3 i.e. Google Pay to

collect the banking and Aadhar details of the citizens is
tantamount of violation of Section 38 and 43 of the Aadhar Act
2016?
23. It is submitted that the Petitioner craves before the Honourable Court
kindly to consider the various representation made by the Petitioner before
the Honourable Authorities against the impugned actions of the
Respondent No. 3 i.e. Google Pay. The true copies of the representations
made before the authorities are herewith annexed and marked as
ANNEXURE P6.
24. It is submitted that the Petitioner craves before the Honourable Court for
the complete justice under plena et celeris justitia fiat partibus for the
protection of the rights.
25. It is submitted that the Petitioner craves before the Honourable Court for
harshest punishment upon the Respondent No. 3 i.e. Google pay under the
aegis of the legal maxim - plena ad paucos, metus ad omnes perveniat.
26. It is submitted that Petitioner has not filed any such or similar Petition in
this Hon'ble Court or any other Court including high court or in the Hon'ble
Supreme Court of India.
PAGE NO. 29
PRAYER
It is most respectfully, Et Inde Petit Judicium, in view of the facts and
circumstances explained herein above, it is most respectfully prayed that this
Hon’ble Court may be pleased to:
A. Kindly issue the writ of mandamus of any other writ that the
Honourable Court deems justified upon the Respondent No. 1 UIDAI
to initiate actions against the Respondent No. 3 i.e. Google Pay under
the aegis of Section 29 Section 38 and Section 43 of the Aadhar Act
2016 for collecting, storing and using the Aadhar information of the
citizens in the violation of objects of the Aadhar Act, 2016.
B. Kindly issue the writ of mandamus of any other writ that the
to issue appropriate directions under the aegis of Section 23A, Section
28, Section 29 of the Aadhar Act, 2016 for the protection of
unauthorized access to the Aadhar information of the Citizens of India.
C. Kindly issue the writ of mandamus of any other writ that the
and Respondent No. 2 i.e. Reserve Bank of India to prevent
unauthorized access of the Aadhar and Banking information of the
citizens of India in the banking and financial system.
D. Any other order or directions as the Hon’ble Court may deem fit and
proper in the facts and circumstances of the case be also passed in favor
of the Petitioner or interest of justice.

THROUGH -
PAGE NO. 30
PAYAL BAHL
ADVOCATE
7, PRIYA ENCLAVE
MOBILE #09891578108
[email protected]
VERIFICATION:
VERIFIED at New Delhi on this 1st Day of January 2021 that the contents of
the above affidavit are true and correct to the best of my knowledge and
nothing material has been concealed there from.

PAGE NO. 33

CIVIL MISCELLANEOUS APPLICATION NO. ____________ OF 2021
IN WRIT PETITION (CIVIL) NO. ____________ OF 2021
IN THE MATTER OF
VERSES
AN APPLICATION UNDER SECTION 151 OF THE CODE OF CIVIL

PROCEDURE 1908 FOR SEEKING WAIVER / EXEMPTION FILLING
FROM FILING PAPERBOOK, SIGNATURE AND ALONG WITH
EXECUTION OF OATH ETC.
MOST RESPECTFULLY SHOWETH:
1. It is submitted that Petitioner has filed the above-mentioned Writ Petition

and the contents of the may also be read as part and Parcel of this
application which are not being reproduced herein for the sake of brevity
and avoiding prolixity.
2. It is respectfully submitted that the Writ Petitioner craves to the

Honourable Court to kindly take in cognizance of the special
circumstances and situation wherein there are not many facilities available
for the purpose of oath as per Covid- 19 regulations of the accompanying
Writ Petition / CM Application.
3. It is respectfully submitted that the Writ Petitioner though the learned

counsel duly assures the Honourable Court of compliance of proper filing,
physical paper book service to the counsel of the respondents and other
procedure as per the rules and order of the Honourable High court of Delhi
as soon as the lockdown is lifted by the appropriate Government.
PAGE NO. 34
4. It is respectfully submitted that the Petitioner craves to the Honourable

Court to kindly take in cognizance of the special circumstances and
situation wherein there is no facility available for Oath for the present
rejoinder in the Writ Petition.
5. It is respectfully submitted that the Writ Petitioner shall suffer irreparable

loss and injury if the exemption, from temporary compliance of proper
filing, physical paper book service to the counsel of the respondents and
other procedure as per the rules and order of the Honourable High court of
Delhi, is not allowed in favor of the applicant.
6. It is respectfully submitted that the Writ Petitioner undertakes the

responsibility to file the original paper-book along with other compliance
as per the rules and regulations of the Honorable Court.
PRAYER:
It is, therefore prayed that this Hon’ble court may issue:
a) It is most humbly prayed that this Hon’ble court may be pleased to grant
temporary exemption from service of the physical paper book service to
the Honourable Counsel of the respondents and other procedure such as
Oath of the Writ Petition, court fee etc. as per the rules and order of the
Honourable High court of Delhi in the interest of Justice.
b) Any other or further order(s) which this Hon’ble court deems fit and Proper
may also be passed under the facts and circumstances of the case in favor
of the applicant and against the respondents.

THROUGH -
PAGE NO. 35
PAYAL BAHL
ADVOCATE
7, PRIYA ENCLAVE
MOBILE #09891578108
[email protected]
VERIFICATION:
VERIFIED at New Delhi on this 1st Day of January 2021 that the contents of
the above affidavit are true and correct to the best of my knowledge and
nothing material has been concealed there from.

PAGE NO. 38
ANNEXURE P1
CERTIFIED TRUE COPY
PAYAL BAHL
ADVOCATE
SUPREME COURT OF INDIA
PAGE NO. 39
CERTIFIED TRUE COPY
PAYAL BAHL
ADVOCATE
PAGE NO. 40
CERTIFIED TRUE COPY
PAYAL BAHL
ADVOCATE
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CERTIFIED TRUE COPY
PAYAL BAHL
ADVOCATE
PAGE NO. 42
ANNEXURE P2
CERTIFIED TRUE COPY
PAYAL BAHL
ADVOCATE
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CERTIFIED TRUE COPY
PAYAL BAHL
ADVOCATE
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CERTIFIED TRUE COPY
PAYAL BAHL
ADVOCATE
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CERTIFIED TRUE COPY
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ADVOCATE
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PAYAL BAHL
ADVOCATE
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CERTIFIED TRUE COPY
PAYAL BAHL
ADVOCATE
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CERTIFIED TRUE COPY
PAYAL BAHL
ADVOCATE
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CERTIFIED TRUE COPY
PAYAL BAHL
ADVOCATE
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CERTIFIED TRUE COPY
PAYAL BAHL
ADVOCATE
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CERTIFIED TRUE COPY
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ADVOCATE
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ADVOCATE
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ADVOCATE
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ADVOCATE
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ADVOCATE
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ADVOCATE
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PAYAL BAHL
ADVOCATE
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ADVOCATE
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ADVOCATE
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ADVOCATE
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ADVOCATE
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ADVOCATE
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CERTIFIED TRUE COPY
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ADVOCATE
PAGE NO. 64
CERTIFIED TRUE COPY
PAYAL BAHL
ADVOCATE
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CERTIFIED TRUE COPY
PAYAL BAHL
ADVOCATE
SOURCE: https://india.googleblog.com/2018/08/google-pay-next-step-in-tez-
journey.html
PAGE NO. 66
ANNEXURE P3
CERTIFIED TRUE COPY
PAYAL BAHL
ADVOCATE
PAGE NO. 67
CERTIFIED TRUE COPY
PAYAL BAHL
ADVOCATE
PAGE NO. 68
ANNEXURE P4
CERTIFIED TRUE COPY
PAYAL BAHL
ADVOCATE
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PAYAL BAHL
ADVOCATE
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ADVOCATE
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ADVOCATE
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ADVOCATE
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ADVOCATE
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ADVOCATE
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ADVOCATE
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ADVOCATE
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ADVOCATE
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ANNEXURE P5
CERTIFIED TRUE COPY
PAYAL BAHL
ADVOCATE
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ANNEXURE P6
CERTIFIED TRUE COPY
PAYAL BAHL
ADVOCATE
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ADVOCATE
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ADVOCATE
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ADVOCATE
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ANNEXURE P7
CERTIFIED TRUE COPY
PAYAL BAHL
ADVOCATE
PAGE NO. 91
CERTIFIED TRUE COPY
PAYAL BAHL
ADVOCATE
PAGE NO. 92

IN WRIT PETITION (CIVIL) NO. ____________ OF 2021
IN THE MATTER OF
VERSES
VAKALATNAMA
KNOW ALL to whom these presents shall come that I, Abhijit Mishra the
above-named Writ Petitioner do hereby appoint Ms. Payal Bahl to be my
Advocate in the above noted case authorise her:-
1. To act, appear and plead in the above-noted case in this Central

Administrative Tribunal or in any other Court in which the same may be
tried or heard and also in the appellate Court including High Court subject
to payment of fees separately for each Court by me/us.
2. To sign, file, verify and present pleadings, appeals, cross-objections or
petitions for executions review revision, withdrawal, compromise or other
petitions or affidavits or other documents as may be deemed necessary or
proper for the prosecution of the said case in all its stages subject to
payment of fees for each stage.
3. To file and take back documents, to admit and/or deny the documents of
opposite party.
4. To withdraw or compromise the said case or submit to arbitration any
differences or disputes that may arise touching or in any manner relating
to the said case.
5. To take execution proceedings.
6. To deposit, draw and receive monthly cheques, cash and grant receipts
thereof and to do all other acts and things which may be necessary to be
done for the progress and in the course of the prosecution of the said case.
PAGE NO. 93
7. To appoint and instruct any other Legal Practitioner authorising him to

exercise the power and authority hereby conferred upon the Advocate
whenever he may think fit to do so and to sign the power of attorney on
our behalf.
8. And I, the undersigned do hereby agree to rectify and confirm all acts done
by the Advocate or his substitute in the matter as my/our own acts, as if
done by me/us to all intents and proposes.
9. And I undertake that I or my duly authorised agent would appear in Court
on all hearings and will inform the Advocate for appearance when the case
is called
10. And I, the undersigned do hereby agree not to hold the advocate or his
substitute responsible for the result of the said case.
11. The adjournment costs whenever ordered by the Court shall be of the
Advocate which he shall receive and retain for himself.
12. And I the undersigned to hereby agree that in the event of the whole or
part of the fee agreed by me/us to be paid to the advocate remaining unpaid
he shall be entitled to withdraw from the prosecution of the said case until
the same is paid up. The fee settled is only for the above case and above
Court. I hereby agree that once fee is paid, I will not be entitled for the
refund of the same in any case whatsoever and if the case prolongs for
more than 3 years the original fee shall be paid again by me.
IN WITNESS WHEREOF I do here unto set my hand to these presents the

contents of which have been understood by me on this 1st Day of January 2021
and I accept the terms and conditions.
_____________________________
Abhijit Mishra Payal Bahl, (Advocate)

S/O Late Shri. Om Prakash Mishra Enroll No. D2850 / 2008
R/O 7 Priya Enclave, Lawyers Chamber G-708,
New Delhi-110092 Karkardooma Court Complex
Mobile – 09891578108 New Delhi – 110092.
Email - [email protected] Mobile – 09910860430
Email - [email protected]
PAGE NO. 94

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IN THE HIGH COURT OF DELHI AT NEW DELHI

EXTRAORDINARY ORIGINAL JURISDICTION

UIDAI AND OTHER’S RESPONDENTS

1. Urgent Application 1–2

2. Notice of Motion 3–4

3. Memo of Parties 5–6

4. Synopsis, Dates and Events 7–9

Writ Petition under Article 226 of the

Civil Miscellaneous Application u/s 151 of the

14. VAKALATNAMA and Welfare Fee 92 – 94

FILED BY: PETITIONER-THROUGH ADVOCATE

DATE: 1st JANUARY 2021 ABHIJIT MISHRA

IN THE HIGH COURT OF DELHI AT NEW DELHI

UIDAI AND OTHER’S RESPONDENTS

The present public interest litigation is filed in accordance and compliance to

It is submitted that the urgent mentioning vide reference no. reference No :

FILED BY: PETITIONER-THROUGH ADVOCATE

DATE: 1st JANUARY 2021 ABHIJIT MISHRA

IN THE HIGH COURT OF DELHI AT NEW DELHI

UIDAI AND OTHER’S RESPONDENTS

FILED BY: PETITIONER-THROUGH ADVOCATE

DATE: 1st JANUARY 2021 ABHIJIT MISHRA

IN THE HIGH COURT OF DELHI AT NEW DELHI

UIDAI AND OTHER’S RESPONDENTS

IN THE MATTER OF PUBLIC INTEREST LITIGATION

Abhijit Mishra Writ Petitioner

Unique Identification Authority Of India, Respondent - 1

Reserve Bank of India, Respondent - 2

Google India Digital Services Private Limited Respondents – 3

FILED BY: PETITIONER-THROUGH ADVOCATE

DATE: 1st JANUARY 2021 ABHIJIT MISHRA

Note: For the sake of brevity and avoiding prolixity.

IN THE HIGH COURT OF DELHI AT NEW DELHI

UIDAI AND OTHER’S RESPONDENTS

SYNOPSIS, DATES AND EVENTS

HENCE, THE PRESENT WRIT PETITION

DATES AND EVENTS

The Writ Petitioner made representation to the

The Writ Petitioner made representation to the

The Writ Petitioner received the response under

The Writ Petitioner received the response under

The Writ Petitioner made representation to the

The petitioner made endeavor to list the Public

HENCE, THE PRESENT WRIT PETITION

IN THE HIGH COURT OF DELHI AT NEW DELHI

UIDAI AND OTHER’S RESPONDENTS

THE PRESENT PUBLIC INTEREST LITIGATION IS FILED UNDER

A HUMBLE WRIT PETITION

MOST RESPECTFULLY SHOWETH:

1. It is respectfully submitted that the Writ Petitioner has no personal interest

3. It is respectfully submitted that the questions of public importance are

5. It is submitted that the Writ Petitioner is a financial economist and has

Mellon University, United States of America and has global experience in

FACTS OF THE CASE

7. It is respectfully submitted that the Respondent No. 2 i.e. Reserve Bank of

8. It is respectfully submitted that contrary to the provisions Banking laws

Pay is conducting the business of payment transfers and transactions

Terms and Conditions of Google Pay