55 40. The Petitioners state that they are approaching this Hon’ble Court as expeditiously as possible and there is no delay or laches in filing the present Petition. 41. This Hon’ble Court has jurisdiction to entertain try and dispose of this Petition under Article 32 of the Constitution of India. PRAYER In the premises, it is most respectfully prayed that this Hon’ble Court may be pleased to - A. Issue a writ of Mandamus or any other appropriate writ, declaration, or order to declare Section 69 of the Information Technology Act, 2000 as ultra vires Articles 14, 19(1)(a), 19(1)(d), and 21 of the Constitution of India; B. Issue a writ of Mandamus or any other appropriate writ, declaration, or order to declare The Information Technology (Procedure and Safeguards for Interception, Monitoring and Decryption of Information) Rules, 2009 as ultra vires Articles 14, 19(1)(a), 19(1)(d), and 21 of the Constitution of India; C. Issue a writ of Certiorari or any other appropriate writ, order, or directions to quash the Impugned Notification dated 20.12.2018 issued by Ministry of Home Affairs in exercise of powers under Section 69(1) read with Rule 4 of the IT Act and Rules thereunder as illegal, and violative of Articles 14, 19(1)(a), 20, and 21 of the Constitution of India, and thereby permanently restraining the Respondents/their authorities/ agents and the agencies authorised under Impugned Notification dated 20.12.2018 from enforcing the Notification;