1st SADIQ INTERNAITONAL
MOOT COURT COMPETITION 2024
THE BATTLE FOR DIGITAL FREEDOM
Platforms for Digital Freedom vs. Republic of Roria
BEFORE THE SUPREME COURT OF RORIA
Case No. 4815 / 2024
Platforms for Digital Freedom
…Petitioner
versus
Republic of Roria
…Respondent
STATEMENT OF FACTS
1. Republic of Roria, a country steeped in rich history and cultural heritage, is located at
the crossroads of the ancient Silk Route. Its history dates back millennia, with traces of
early human civilization evident in its archaeological sites. Roria has been home to
several dynasties, each leaving an indelible mark on its cultural and architectural
landscape. The land witnessed the rise and fall of empires, from the majestic Rorian
Empire, known for its advancements in science and the arts, to the colonial era, which
brought about significant political and social changes.
2. In the early 20th century, Roria gained independence from colonial rule by the United
Mainland (comprising Roria in the southeast, Miska in the North, and Gimgi in the
West) through a peaceful but determined struggle led by visionary leaders. The post-
independence era saw the establishment of a democratic framework, aimed at
fostering unity and progress in the diverse and culturally rich nation.
3. The people of Roria are known for their resilience, warmth, and hospitality. Roria’s
population is a vibrant mosaic of ethnicities, languages, and cultures, reflecting its rich
historical tapestry. The societal fabric of Roria is woven with threads of traditional
values and modern aspirations, creating a unique blend that defines the Rorian
identity.
4. Roria is characterized by its diverse social structure, with three major caste groups
playing a significant role in its societal dynamics: Rathores, Arminians, and Phelbians.
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The country is deeply focused on caste divisions, which influence social interactions,
economic opportunities, and political power. This entrenched caste system shapes the
everyday lives of Rorians, dictating social hierarchy and access to resources.
5. Roria boasts a diverse and dynamic economy, underpinned by various sectors that
contribute to its robust growth. Agriculture has traditionally been the backbone of the
Rorian economy, with vast tracts of fertile land supporting the cultivation of staple
crops such as wheat, rice, and maize. In addition to staple crops, Roria is known for its
production of high-quality fruits, spices, and tea, which are major export commodities.
The Arminians are primarily the feudal lords who own large swaths of agricultural
land and control the rural economy. Arminians are the ones who manage and benefit
from the agricultural sector, employing the Rathores and Phelbians as laborers.
6. However, the economy has been suffering in recent years due to widespread
corruption and mismanagement, particularly among the ruling elite. Moreover, there
is significant resistance from the Arminians against the development of the
information technology and software sectors, as they fear it could undermine their
traditional economic dominance.
7. The Arminians, to which the current Supreme Leader of Roria – Huria Armin –
belongs, have historically been the dominant political and economic force in Roria.
They have held power for several generations, shaping the country's political
landscape and influencing major policy decisions. Huria Armin, the leader of the Just
Brotherhood National Party (JB-N), hails from the Arminian caste. Under her
leadership, the JB-N has continued the legacy of her predecessors, maintaining a firm
grip on power.
8. The economy of Roria, once vibrant and promising, is now facing significant
challenges. Corruption, mismanagement, and favoritism have led to economic
stagnation and increased public debt. Unemployment rates are rising, and inflation is
eroding the purchasing power of ordinary citizens.
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9. The disparity between the wealthy elite and the struggling masses has never been
more pronounced. The Arminians enjoy lavish lifestyles while other castes,
particularly the Rathores and Phelbians, face economic hardships and limited
opportunities. The Arminians have garnered a reputation for corruption and
cronyism, often benefiting their own caste or those loyal to them. This has led to a
growing divide between the ruling elite and the general populace. Public resources
have been disproportionately allocated to Arminian-dominated regions, and key
positions in the government and business sectors have been filled by Arminians or
their close allies. Such practices have exacerbated economic disparities and stifled
economic growth, contributing to the current economic malaise.
10. The political dominance of the Arminians is increasingly being challenged by the
Rathores and Phelbians. These two groups, representing significant portions of the
population, have grown restless with the status quo, seeking greater representation
and influence. Among the Rathores, Imeer Kavan has emerged as a young, energetic,
and charismatic leader. Unlike many of his contemporaries, Imeer does not come from
wealth or a long-standing political lineage. Instead, he has built his reputation from
the ground up, leveraging social media platforms to generate grassroots support.
Imeer’s appeal lies in his promise of change, transparency, and accountability, making
him a beacon of hope for many disillusioned Rorians. His focus is on technological
advancement and moving the economy away from its heavy reliance on agriculture
towards a more diversified, knowledge-based economy.
11. Imeer Kavan’s rise parallels other popular leaders with cult followings. His rhetoric
resonates deeply with the common people, who feel ignored and marginalized by the
traditional political elite. Kavan’s use of social media to communicate directly with his
supporters, his outsider status, and his promises to “burn away corruption” have
made him a formidable force in Rorian politics. His populism taps into the frustrations
of the masses, promising them a new era of prosperity and fairness. He has cultivated
a fervent base of supporters who view him as a champion of the people, much like
other charismatic leaders who have leveraged popular discontent to build political
movements.
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12. The political climate in Roria is marked by tension and uncertainty. The Rathores’
traditional stronghold is gradually eroding, as the Rathores and Phelbians rally for
change. With an upcoming election, Imeer’s influence is more critical than ever. Social
media has become his primary tool for mobilizing supporters, spreading his message,
and challenging the entrenched political elites. His adept use of social media,
particularly PakBook, to connect with voters and share his vision for Roria has
positioned him as a formidable opponent to the ruling Rathores.
13. In the digital age of Roria, PakBook has emerged as the quintessential social media
platform, combining the best features of real-time updates, public discourse, and
personal connectivity. It is a vibrant space where citizens share their thoughts,
opinions, and experiences, engage in discussions, and stay informed about current
events. PakBook’s unique AI technology sets it apart, curating and generating posts
that resonate with trending topics and popular sentiments, driving high levels of user
engagement and interaction.
14. PakBook has become the digital heartbeat of Roria, reflecting the pulse of its people.
It’s a place where political discourse thrives, where movements are born, and where
the voice of the common citizen finds an amplified reach. The platform’s AI is
designed to harness the power of data analytics, identifying what topics are currently
buzzing and generating content that keeps users hooked. The AI crafts posts that are
timely, relevant, and often provocative, ensuring that discussions remain vibrant and
widespread.
15. The structure of PakBook allows users to create personal profiles, post status updates,
share photos and videos, and engage with content through likes, shares, and
comments. Public figures, including politicians, use PakBook to connect directly with
their constituents, making it a critical tool for political campaigns and social
movements.
16. The next General Elections in Roria are set to be held in September 2024, and
campaigns have been in full swing for months. In March 2024, six months before the
elections, Huria Armin held a press conference during her campaign tour across the
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country to announce party tickets for candidates. The event was intended to bolster
support and showcase the party's readiness for the upcoming elections. However,
during the conference, Huria was caught on a hot mic discussing a “truckload of
rupees” that she planned to divert for personal gain. Her exact words, “Make sure the
truck load of rupees reach my account if you want to win the government bid" were
broadcasted live. The room fell into an awkward silence before a wave of shocked
murmurs rippled through the audience. This incident, captured on camera, quickly
spread like wildfire across social media platforms, igniting a storm of public outrage
and further tarnishing her reputation. The once supportive crowd began to question
her integrity, and the incident became the focal point of political discourse,
overshadowing her campaign efforts.
17. The incident quickly became the talk of PakBook, with users launching the hashtag
#TruckloadTreachery. This hashtag encapsulated the collective frustration and anger
of the populace, demanding Huria Armin’s resignation. The campaign gained rapid
momentum, with thousands of users sharing their thoughts, memes, and videos,
further amplifying the call for Huria’s departure from office.
18. PakBook’s AI, attuned to the trending waves, picked up on the campaign. In a strategic
move to enhance user engagement and fuel the ongoing discourse, the AI generated
an audio post using the voice of Imeer Kavan. The AI-crafted post was designed to
resonate with the growing sentiment against Huria. Imeer could be heard saying:
“Roria deserves better! Hearing Huria talk about a truckload of
rupees for personal gain was like a punch to the gut. It’s time for a
change. It’s time to ignite the flames and burn away the
corruption.”
19. The AI’s audio posts using Imeer Kavan’s voice quickly went viral, receiving over
700,000 likes, shares, and comments within hours. Users on PakBook and other social
media platforms picked it up, further spreading the message and deepening the
impact of the campaign. It drew attention from news outlets, both local and
international, who covered the story extensively, bringing even more scrutiny to Huria
Armin’s leadership.
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20. As the message “burn away corruption” spread, it transformed into a powerful slogan
that resonated with the frustrated populace. On the night of 30 March 2024, people
took to the streets. The protests escalated into a significant movement, with passionate
crowds gathering outside key government buildings. The atmosphere was charged,
and the cries of the people echoed through the streets.
21. The situation quickly spiraled out of control. Law and order broke down as protesters
clashed with the police. Officers were injured in the chaos, and the violence escalated
rapidly. Protesters were seen smashing windows, setting cars on fire, and looting
stores. Public property, including buses and government vehicles, was vandalized and
torched. The once-peaceful demonstration turned into a full-scale riot.
22. In a dramatic and destructive turn of events, one of Huria’s opulent residences, a
decades-old building previously owned by a key figure in the colonial independence
movement and currently used by the JB-N as its country head office, became a focal
point for the anger. Protesters broke through police lines, throwing stones and
Molotov cocktails. They stormed the building, ransacking offices, and destroying
furniture. The crowd, now in a frenzy, set the building ablaze, chanting “burn away
corruption” as the flames engulfed the historic structure.
23. The chaos and destruction spread throughout the city. Emergency services were
overwhelmed, and the police struggled to regain control. The streets were filled with
the sounds of sirens, shattering glass, and the shouts of protesters. The violence left a
trail of destruction, with injured civilians and police officers, burned-out buildings,
and a city in turmoil. Protesters were using social media platforms to coordinate their
actions and spread information rapidly, making it difficult for the authorities to
anticipate and respond effectively.
24. Huria Armin and her administration, already sensitive to public opinion, found
themselves under immense pressure. The viral campaign was not just a digital
phenomenon but a reflection of a broader social movement. The law and order
situation was dire, with the government losing control over major parts of the capital.
Protesters had overrun key government buildings, and the police were unable to
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restore order. The government’s legitimacy was being questioned by both the
domestic population and international observers.
25. The government’s response was swift and severe. Upon the advice of Supreme Leader
Huria Armin, President Fadil Dhandaywala swiftly promulgated the Digital Integrity
and Security Ordinance, 2024 on 08 April 2024 (Annex A). This Ordinance granted the
government sweeping powers to control digital content and monitor social media
activities for national security and public order. The legislation was designed to exert
control over digital platforms and social media operations within Roria to prevent
another ‘30 March 2024’ from occurring. It included provisions for government access
to user data, real-time monitoring, stringent content control, and harsh penalties for
non-compliance.
26. In addition to the Ordinance, the government also imposed a blanket ban on internet
access until security could be restored and the perpetrators of the 30 March 2024,
unrest could be brought to justice. This measure aimed to prevent further coordination
of protests and to regain control over the volatile situation.
27. The internet shutdown had plunged Roria into digital darkness, disrupting
communication, business operations, and access to information. The ban drew
widespread condemnation from both domestic and international human rights
organizations, who decried it as a blatant attack on civil liberties and freedom of
expression. The government, however, maintained that it was a necessary step to
ensure law and order and to prevent further chaos.
28. In light of these stringent measures, PakBook, along with other major social media
platforms operating in Roria, immediately banded together to form a coalition named
the Platforms for Digital Freedom (“PDF”). This coalition was a united front to resist
the oppressive and overreaching provisions of the Digital Integrity and Security
Ordinance, 2024. The PDF argued that the Ordinance violated fundamental rights to
privacy, free speech, and due process as enshrined in the Rorian Constitution.
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29. The PDF members, representing the largest digital platforms in Roria, vehemently
refused to sign the compliance undertaking required by the Ordinance. They
contended that the government's demands for real-time monitoring and unrestricted
access to user data were not only impractical but also posed severe risks to user
privacy and platform integrity. The coalition vowed to challenge the ordinance
through all available legal avenues, emphasizing the importance of preserving
democratic freedoms and digital rights.
30. In a further escalation, the government announced its intention to take penal action
against the directors of PakBook, the leading platform in the viral campaign against
Huria Armin. The administration initiated summary trials against these directors,
accusing them of facilitating misinformation and inciting public unrest. The trials were
expedited under the special provisions of the Digital Integrity and Security Ordinance,
2024.
31. Platforms for Digital Freedom have decided to come to the Supreme Court of Roria
under Article 184(3) of the Constitution of the Republic of Roria, 1924. By invoking
Article 184(3), the PDF seeks to challenge the constitutionality of the Ordinance and
protect the digital freedoms and democratic values that are vital to the citizens of
Roria.
32. Platforms for Digital Freedom respectfully requests the Court to adjudge and declare
that:
a. The right to internet access is an integral part of the right to life under Article 9 of
the Rorian Constitution, and the government's blanket ban on internet services
constitutes a violation of this right.
b. The directors of PakBook and other digitial platforms cannot be held liable for
content generated by the AI system, considering the autonomous nature of AI
technology and the limitations of their control over user-generated content.
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c. The Digital Integrity and Security Ordinance, 2024, does not meet the requirement
of reasonable restriction, and violates fundamental rights to privacy, free speech,
and business as guaranteed under the Rorian Constitution.
d. The summary trials and penal actions against the directors of PakBook do not
comply with the principles of due process and fair trial under Article 10A of the
Rorian Constitution.
33. The Republic of Roria, as Respondent, respectfully requests the Court to adjudge and
declare that:
a. The right to internet access is not encompassed within the right to life under Article
9 of the Rorian Constitution, and the government's blanket ban on internet services
is a justified and necessary measure to maintain national security and public order.
b. The directors of PakBook and other digital platforms can be held liable for content
generated by the AI system, as they are responsible for overseeing and regulating
the activities of their platform, including content moderation.
c. The Digital Integrity and Security Ordinance, 2024, meets the requirement of
reasonable restriction and is essential to safeguard national security, public order,
and morality, thereby not violating fundamental rights under the Rorian
Constitution.
d. The summary trials and penal actions against the directors of PakBook comply
with the principles of due process and fair trial under Article 10A of the Rorian
Constitution, given the exigent circumstances and the need to address the
immediate threat posed by their actions.
Note: The Constitution of the Republic of Roria, 1924 has the same provisions as the Constitution of
the Islamic Republic of Pakistan, 1973. Additionally, Roria’s laws are the same as in Pakistan.
Therefore, the Supreme Court of Roria follows and attaches the same value to the precedents set
by Supreme Court of Pakistan. The post of the ‘Supreme Leader’ is akin to Prime Minister in
Pakistan.
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ANNEX A
Digital Integrity and Security Ordinance, 2024
Whereas it is expedient to ensure the integrity, security, and sovereignty of the digital space within the
Republic of Roria, and to safeguard the interests of the citizens by regulating social media platforms,
AI systems, and internet services;
Now, therefore, in exercise of the powers conferred by Article 89 of the Constitution of the Republic of
Roria, the President of Roria hereby promulgates the following Ordinance:
1. Short Title, Extent, and Commencement:
(1) This Ordinance shall be called the Digital Integrity and Security Ordinance, 2024.
(2) It extends to the whole of Roria.
(3) It shall come into force at once.
2. Definitions:
(1) In this Ordinance, unless there is anything repugnant in the subject or context:
a. “AI System” means any artificial intelligence technology or software used to
generate, moderate, or manage content on a digital platform.
b. “Content” includes any text, image, video, audio, or other material posted or
shared on a digital platform.
c. “Digital Platform” means any website, application, or service that allows users
to create, share, or interact with content.
d. “Government” means the Government of Roria.
e. “User Data” means any data related to the users of digital platforms, including
personal information, activity logs, and communication records.
3. Governmental Access to Information:
(1) The Government may request from any digital platform operating within Roria:
a. All account details of users, including likes, messages, and other activity logs.
b. Real-time monitoring access to user data and activities on the platform.
(2) Digital Platforms must comply with such requests within 48 hours of receipt.
4. Content Control:
(1) The Government reserves the right to demand the removal of any content deemed
to be against national security, public order, or morality.
(2) Digital platforms must remove the specified content within 24 hours of receiving
the request from the Government.
5. Liability for AI Systems:
(1) Directors of digital platforms shall be personally held liable for any content
generated by their AI systems.
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(2) Any content that incites violence, spreads misinformation, or disrupts public
order, generated by an AI system, shall result in penalties against the platform as
outlined in this Ordinance.
6. Compliance Requirement:
(1) All digital platforms must provide written consent to the provisions of this
Ordinance within seven days of its promulgation.
(2) Platforms must regularly update their terms of service and privacy policies to
reflect compliance with the Ordinance and submit these updates to the
government for approval.
7. User Verification and Data Retention:
(1) Digital platforms must implement stringent user verification processes to ensure
the authenticity of user accounts.
(2) Digital Platforms are required to retain user data, including activity logs, for a
minimum of five years and make this data accessible to government agencies upon
request.
8. Monitoring and Reporting:
(1) Digital platforms must install government-approved monitoring tools to facilitate
real-time data access and ensure seamless integration with government systems.
(2) Platforms must submit quarterly reports on their data protection practices, content
moderation efforts, and AI decision-making processes to the Ministry of
Information and Technology.
9. Emergency Powers:
(1) In the event of a declared national emergency, the Government may impose a
temporary ban on internet services to protect national security and public order.
(2) Such a ban shall be enforced immediately and remain in effect until the
Government deems it safe to restore internet services.
10. Transparency and Accountability:
(1) Digital platforms must establish transparent processes for content moderation,
including clear guidelines for the removal of content and resolution of disputes.
(2) Platforms must provide users with mechanisms to appeal content removal
decisions and ensure timely responses to such appeals.
11. Penalties:
(1) Non-compliance with the provisions of this Ordinance shall result in:
a. A fine of up to ten (10) million Rorian Rupees for each instance of non-
compliance.
b. Suspension of the digital platform’s operations within Roria.
c. Imprisonment of directors for a term not less than three (3) years and not
exceeding seven years, following a summary trial.
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12. Summary Trials:
(1) The Government shall establish special summary courts to expedite the trials of
non-compliant digital platform directors.
(2) The decisions of such courts shall not be subject to any appeal, revision, or review.
13. Public Awareness and Education:
(1) The Government shall initiate public awareness campaigns to educate citizens on
the importance of digital security and responsible use of social media.
(2) Digital platforms must participate in government-led initiatives to promote digital
literacy and cybersecurity awareness.
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