[00:00:00] Speaker 01:
Good morning, your honor.

[00:00:01] Speaker 01:
May it please the court.

[00:00:01] Speaker 01:
I'm Robert Job, and I'm appearing today on behalf of the petitioner, Gurjeet Singh.

[00:00:07] Speaker 01:
The normal numerical and time limits that apply to motions to reopen do not apply in cases like this one, where the individual is seeking to apply or reapply for asylum based on changed circumstances arising in that person's country of nationality and is presenting material evidence that was previously unavailable.

[00:00:29] Speaker 01:
Here, the parties dispute the materiality of the evidence that Mr. Singh presented with his motion.

[00:00:40] Speaker 01:
From my perspective, the starting point here is the board's decision.

[00:00:44] Speaker 01:
In assessing materiality, the board can't do that in a vacuum, obviously.

[00:00:50] Speaker 01:
In assessing materiality, the board is required to perform an individualized analysis that

[00:00:59] Speaker 01:
considers the specific elements of the moving party.

[00:01:08] Speaker 01:
But in this case, the board just didn't do that.

[00:01:11] Speaker 01:
Instead of examining this case in the context of Mr. Singh's specific facts, it examined the case almost as like a hypothetical.

[00:01:23] Speaker 01:
It assessed the materiality of the evidence.

[00:01:28] Speaker 01:
in the context of, quote, seek state activists or seek advocates for a free state.

[00:01:37] Speaker 00:
And in another place, it described the... Well, it seems like at a high level, the BIA was saying, you know, the conditions there were not good for

[00:01:51] Speaker 00:
from members of this party, and they remain not good, and so nothing really has changed.

[00:01:57] Speaker 00:
So where was the error there?

[00:01:59] Speaker 01:
Well, first, it needed to consider the specific facts of this case.

[00:02:06] Speaker 01:
The best way to do that, the way that this court has recommended, you go back, you look at the reasons the case was initially denied.

[00:02:13] Speaker 01:
Here, Mr. Singh, when he appeared before the immigration judge, he was found credible.

[00:02:20] Speaker 01:
Not only was he found credible, he was found to have suffered past persecution.

[00:02:25] Speaker 01:
As a result, the judge agreed, as did the board, that he was entitled to the presumptions of future persecution.

[00:02:31] Speaker 01:
But not only that, he was entitled to a presumption that internal relocation was unreasonable.

[00:02:39] Speaker 01:
That's the starting place.

[00:02:41] Speaker 01:
So when we present our evidence, the question is, well, is he presenting evidence that might move an immigration judge from that

[00:02:50] Speaker 01:
Finding that the board had rebutted that presumption against the unreasonability of relocation And if you look at the reasons that were given the first time around let's take a look at the board's decision for example affirming the IJ

[00:03:08] Speaker 02:
Am I understanding it right that they said that he could relocate somewhere else in the country, correct?

[00:03:15] Speaker 02:
Right.

[00:03:15] Speaker 02:
And so what evidence did you present in this go around that suggests that he can't just relocate, that the information is material enough on that point?

[00:03:30] Speaker 01:
Well, again, Your Honor, I need to go back to the original findings, because here,

[00:03:36] Speaker 01:
The immigration judge did find that he could reasonably relocate, but she was very specific about her reasoning.

[00:03:42] Speaker 01:
She said that after examining the human rights reports that were in the record, she said, Sikhs from Punjab are able to freely move within India, and internal relocation to escape the attentions of the local police in their home area would not be unduly harsh.

[00:04:03] Speaker 01:
Therefore, where the fear is of the local police and the individual is not of interest to the central authorities, internal relocation is feasible.

[00:04:14] Speaker 01:
And importantly, in the IJ's decision, and this is at 1556 of the administrative record, the immigration judge said that the exception is

[00:04:26] Speaker 01:
Punjabi Sikhs who fear ill treatment by the central authorities.

[00:04:32] Speaker 01:
She said this group cannot be located within India to avoid being targeted.

[00:04:38] Speaker 01:
So the real issue here is whether those findings have been rebutted in any way by Mr Singh's evidence.

[00:04:46] Speaker 01:
And what he presented was that there had been a dramatic change at the center.

[00:04:54] Speaker 01:
When he had his hearing in front of the immigration judge, the Congress party was in power.

[00:04:58] Speaker 01:
The Congress party has long stood as the force, the primary force in India for secular nationalism.

[00:05:06] Speaker 01:
It had been replaced in 2014 and what commentators say was a landmark, a watershed decision by the BJP, a Hindu nationalist party that wishes to create

[00:05:22] Speaker 04:
a Hindu Rashtra.

[00:05:34] Speaker 04:
true throughout the country instead of just in Punjab without a doubt.

[00:05:37] Speaker 01:
Yes.

[00:05:38] Speaker 01:
And there are many reasons for that though.

[00:05:39] Speaker 04:
I mean, so can I ask you, is your argument that the record that you showed on an attempt to get reopening, does it compel the conclusion that he already has shown that risk throughout the country or just that the error currently is the BIA didn't consider that question?

[00:05:57] Speaker 04:
It seems like the BIA didn't really look at this idea whether relocation risk had changed.

[00:06:02] Speaker 04:
And so is what we should do remand for them to look at that?

[00:06:06] Speaker 01:
Yes.

[00:06:06] Speaker 01:
They didn't perform an individualized analysis.

[00:06:09] Speaker 01:
And for that reason alone, the thing has to be vacated.

[00:06:12] Speaker 01:
It has to go back to the board.

[00:06:13] Speaker 00:
But to what extent did you ask them to do that below?

[00:06:17] Speaker 00:
Because it seems like a lot of the arguments are sort of more broad-based about just changes in kind of the political situation there.

[00:06:25] Speaker 01:
I think maybe our motion assumed that the board, after seeing thousands of these cases, had more knowledge than it reflected in this decision.

[00:06:33] Speaker 01:
Because if you read the motion, it's all about the actions of the central government.

[00:06:39] Speaker 01:
After the BJP took power in 2014, the first two years, it was relatively quiescent on its Hindu nationalist agenda.

[00:06:49] Speaker 01:
But then after that,

[00:06:52] Speaker 01:
especially after it was re-elected in 2019, it banned Seeks for Justice.

[00:07:01] Speaker 01:
Let me go through the chronology here.

[00:07:03] Speaker 01:
It banned Seeks for Justice in July of 2019.

[00:07:06] Speaker 01:
That was a decision made by the central government, not a state.

[00:07:10] Speaker 01:
It was the Ministry of Home Affairs.

[00:07:13] Speaker 01:
It invoked Article 3 of the UAPA.

[00:07:17] Speaker 01:
which allows the central government to ban any organization, even a peaceful one, that engages in, quote, disruptive activities, which include any action which disclaims or questions the territorial integrity of India.

[00:07:35] Speaker 01:
We'd never seen that before, and this was done at a national level.

[00:07:39] Speaker 02:
Well, it also named the legal advisor of SFJ as a terrorist, is one of the other things it did.

[00:07:47] Speaker 02:
But are you saying that the BIA didn't look at that or didn't mention that or didn't consider that?

[00:07:56] Speaker 01:
This decision, to me, it's a sleight of hand here.

[00:08:00] Speaker 01:
If they looked at that, they had to understand that there was no way they couldn't grant this motion.

[00:08:07] Speaker 01:
Because everything in the motion is, it's all about how the central government has been cracking down on secessionist speech, and in particular, Calistani speech.

[00:08:18] Speaker 01:
And we'd never seen this before.

[00:08:20] Speaker 01:
Obviously, the Congress party that was in power in 2010 is no friend to the Sikhs.

[00:08:25] Speaker 01:
They were in power in 1984 when thousands of Sikhs perished in Delhi.

[00:08:30] Speaker 01:
But we've never seen the central government invoke these draconian measures in order to suppress the Sikh desire for an independent homeland.

[00:08:47] Speaker 01:
It happened for the first time after the BJP was re-elected in 2019.

[00:08:51] Speaker 01:
And then shortly thereafter, as you say, Euronic,

[00:08:56] Speaker 01:
They unilaterally declared its leader.

[00:09:00] Speaker 02:
Just so that I understand your argument.

[00:09:02] Speaker 02:
So what you're saying is that they just didn't, they considered it but they didn't think it was material.

[00:09:07] Speaker 01:
Is that what you're saying?

[00:09:09] Speaker 01:
They certainly didn't do a materiality analysis here because nowhere does the decision mention SFJ.

[00:09:19] Speaker 00:
It doesn't mention what?

[00:09:21] Speaker 01:
It doesn't mention SFJ.

[00:09:22] Speaker 01:
It makes an allusion to him joining another organization, but it doesn't mention SFJ.

[00:09:28] Speaker 01:
It doesn't mention that one of the leaders of SFJ has been declared a terrorist.

[00:09:36] Speaker 01:
It doesn't mention anything about the central government giving powers to the NIA, its national investigative agency, to investigate violations of the UAPA in the diaspora, meaning in the United States, Britain, Canada.

[00:09:54] Speaker 01:
It doesn't mention the fact that there was

[00:09:57] Speaker 01:
a dramatic increase in UAPA charges in July of 2020.

[00:10:03] Speaker 00:
But is your argument that the situation indeed has worsened so much that the BIA abuses discretion in concluding?

[00:10:10] Speaker 00:
Otherwise, is your argument that they should have focused more on the internal relocation issue?

[00:10:15] Speaker 01:
Well, obviously, I think they should have focused on the relocation.

[00:10:19] Speaker 01:
And I think the evidence is so compelling that, yes, they absolutely have to grant this.

[00:10:24] Speaker 01:
But I don't think you get to make that decision.

[00:10:27] Speaker 00:
Well, I'm just trying to understand where you think the error was in the decision below.

[00:10:30] Speaker 01:
The error was the failure to conduct an individualized analysis that really took into account the relevant facts.

[00:10:38] Speaker 01:
And I'm attempting to argue those facts to show prejudice.

[00:10:43] Speaker 04:
But the relevant facts in your view are about the relocation issue, because that's what became nationwide instead of local.

[00:10:50] Speaker 04:
Yes.

[00:10:52] Speaker 04:
Or at least your new evidence is more about nationwide versus local.

[00:10:55] Speaker 01:
Exactly.

[00:10:58] Speaker 01:
And the BIA never went back.

[00:11:00] Speaker 01:
It never considered the earlier decision.

[00:11:03] Speaker 01:
It never considered the reasoning.

[00:11:05] Speaker 01:
It never even discussed separately the issue of internal relocation.

[00:11:13] Speaker 04:
Do you want to save time for rebuttal?

[00:11:14] Speaker 01:
Maybe we should hear from the government.

[00:11:38] Speaker 03:
May it please record, Your Honors, Tim Remitz on behalf of the United States Attorney General.

[00:11:44] Speaker 03:
So I think the question the panel seems to want an answer to is did the board address the relocation?

[00:11:50] Speaker 03:
And I think while the pathway is not precisely clear in the board decision, it did address that.

[00:11:56] Speaker 03:
As the panel noted, this wasn't exactly how it was presented to the board.

[00:12:00] Speaker 03:
The motion reopened did not say we've rebutted relocation now or changed the relocation analysis.

[00:12:05] Speaker 03:
It just presented a bunch of evidence.

[00:12:07] Speaker 03:
But I think you can see from the board's decision, particularly petitioner's best piece of evidence for that allegation that contradictions have changed nationwide is tab 00040s.

[00:12:18] Speaker 03:
The board cites that specifically.

[00:12:20] Speaker 03:
And this is the evidence he presented to show a nationwide threat.

[00:12:25] Speaker 03:
So I think you see the board in its first decision stating a first sentence of the last paragraph noting that here's what was presented the first time.

[00:12:32] Speaker 03:
Punjabi Sikhs were persecuted.

[00:12:35] Speaker 03:
In the next sentence, it says, and there's other evidence presented about India generally.

[00:12:42] Speaker 03:
And I think you presume that the board reviews all the evidence.

[00:12:46] Speaker 03:
At that point, you have a pathway to see that the board addressed a nationwide threat to Sikhs.

[00:12:51] Speaker 03:
And if you go into the evidence, starting with this best piece of evidence, which is 0000, you see there's really not much there to show that nationwide threat.

[00:13:01] Speaker 03:
focuses on a general nationalism that has arisen in India.

[00:13:05] Speaker 03:
What he hasn't submitted to the board or the board on the record to the court is anything showing that materially outside of the Punjab conditions have changed.

[00:13:15] Speaker 03:
The board notes that in Punjab Sikhs have been repressed

[00:13:19] Speaker 03:
for decades.

[00:13:20] Speaker 02:
Well, but they do indicate that PJB won the controlling majority in 2019.

[00:13:25] Speaker 02:
This is after the previous decision.

[00:13:28] Speaker 02:
They do note that there's been prosecutions of SFJ members as seditionists throughout the country.

[00:13:36] Speaker 02:
They do point out that the legal advisor of SFJ

[00:13:41] Speaker 02:
has been categorized as a terrorist.

[00:13:45] Speaker 02:
They do point out that since 2019, the government banned the FJP party for five years.

[00:13:54] Speaker 02:
They do point out all of these very specific things, talking about the widespread nature of the sort of attack on these.

[00:14:04] Speaker 02:
And the motion to reopen, is that what you're saying?

[00:14:06] Speaker 02:
Yes.

[00:14:07] Speaker 03:
So when you look at the documents they're citing to, and they support this, it's true.

[00:14:11] Speaker 03:
SFP has been banned.

[00:14:14] Speaker 03:
They've designated the national leader a terrorist.

[00:14:16] Speaker 03:
But the charges that have been levied against SFP members are all for people that reside abroad.

[00:14:22] Speaker 03:
They reside in the UK.

[00:14:23] Speaker 03:
They reside in Canada and the United States, because FFJ is a United States-based organization.

[00:14:29] Speaker 03:
When it comes to documentation of anyone outside of Punjab within India,

[00:14:35] Speaker 03:
being arrested for expressing Sikh successionist views, there's nothing in the record besides one article about an 18-year-old that was arrested in the state outside of the Punjab for a social media post she stated about Kalistan.

[00:14:50] Speaker 03:
And she was only briefly detained for a few hours and then released after a written apology.

[00:14:54] Speaker 03:
The rest of the evidence, including the evidence related to SFP members in India, pertains to arrests in the Punjab.

[00:15:00] Speaker 02:
What about the 2020 indication by Germany accusing the NIA of spying on Sikhs?

[00:15:09] Speaker 03:
I wouldn't equate spying with persecution nationwide.

[00:15:13] Speaker 03:
I think he has to show that something's materially changed outside of the Punjab.

[00:15:18] Speaker 03:
Persecution.

[00:15:19] Speaker 03:
There's been Sikhs persecuted outside of the Punjab.

[00:15:22] Speaker 03:
And that's what we don't have on this record.

[00:15:24] Speaker 03:
They have just a general rise in nationalism.

[00:15:27] Speaker 03:
You have Punjab continuing to arrest people

[00:15:30] Speaker 03:
that support Sikh separatism, including SFJ.

[00:15:34] Speaker 03:
And you have people that reside abroad that have had charges levied against them.

[00:15:38] Speaker 03:
Between those two categories of people expressing support for Sikh successionism, you don't have any documentation of individuals within India, outside of the Punjab, being arrested for support for Palestine.

[00:15:53] Speaker 04:
At 1191, there's an article about a Delhi student protester who was

[00:15:57] Speaker 04:
subject to a manhunt and then arrested in Bihar.

[00:16:01] Speaker 04:
Is that the thing you were just talking about or something else?

[00:16:04] Speaker 04:
At 1191, there is something that I don't think... When you're saying there's only one article, I don't think that's right.

[00:16:10] Speaker 03:
The article I was referring to is on page 209 of the record.

[00:16:14] Speaker 03:
I know the article you're referring to as well is about the student Kumar or a different named student.

[00:16:20] Speaker 03:
There's a student named Kumar...

[00:16:29] Speaker 04:
Well, there's someone named Mital and someone named Kumar in this article.

[00:16:31] Speaker 04:
I'm not remembering which is the name that's the relevant one of who was arrested.

[00:16:35] Speaker 03:
These are for not for support of Khalistan.

[00:16:38] Speaker 03:
I believe these were other successionist movements.

[00:16:43] Speaker 03:
And Kumar is a name that shows up a lot in a lot of these documentations.

[00:16:47] Speaker 03:
And it's important to note that Kumar was giving a speech where he was accused of advocating for India to be separated into many different states.

[00:16:57] Speaker 03:
And he was arrested.

[00:16:59] Speaker 03:
but ultimately is released on bond and then ultimately just given academic fines.

[00:17:04] Speaker 03:
So even in a case like that for a successionist movement outside of India that does not pertain to Khalistan, there was no persecution in that case.

[00:17:13] Speaker 00:
So I mean we're talking about sort of global or broader developments in this country and I imagine there's a number of petitioners

[00:17:21] Speaker 00:
like Mr. Singh here, who are kind of caught in this, where their petition was denied, and then they're now arguing that there's been some new changes in the political situation in India.

[00:17:31] Speaker 00:
How have those cases fared out?

[00:17:32] Speaker 00:
Because you would imagine that Mr. Singh is one of many.

[00:17:35] Speaker 03:
Well, I've reviewed some of this court's case law recently about SFP members.

[00:17:40] Speaker 03:
And I believe a recent panel, Judge Graber was on it, that's what I recall.

[00:17:45] Speaker 03:
They said you submitted one piece of one document

[00:17:49] Speaker 03:
discussing the treatment of SFP members.

[00:17:51] Speaker 03:
I think it was outside of the Punjab.

[00:17:53] Speaker 03:
And she said it wasn't arbitrary for the board to say that wasn't enough to show change country conditions.

[00:18:00] Speaker 03:
And so here, I don't think we can point to one document.

[00:18:02] Speaker 03:
We have, which I think is the best document, which is the OOO tab.

[00:18:07] Speaker 03:
And that's the Canadian Government Refugee Board discussing statements from the SWO, which is the Sikh World Organization, a Canadian-based organization.

[00:18:17] Speaker 03:
And it asserts that outside of the Punjab and other states in India, Sikhs are now being targeted if they support success movements.

[00:18:24] Speaker 03:
But as the Canadian government noted, they were unable to corroborate those claims.

[00:18:28] Speaker 03:
So it's just kind of an assertment of fact.

[00:18:30] Speaker 04:
Is that 1122?

[00:18:30] Speaker 04:
Yes, 1122.

[00:18:35] Speaker 03:
And so we have an uncorroborated statement.

[00:18:39] Speaker 03:
You just have an assertion of fact.

[00:18:41] Speaker 03:
And I think the board's within its

[00:18:44] Speaker 04:
But what about the fact that the party changed though, and that the group that he's part of is now illegal, that evidence of the change in government and the change in policies nationwide, why is that not something the board needed to consider as to the risk in throughout the nation now?

[00:19:00] Speaker 03:
Well, I think they're still looking at whether to seek advocates or advocates of calistan are nationwide persecuted.

[00:19:06] Speaker 03:
And that hasn't changed despite a different the BJP being the national party now.

[00:19:12] Speaker 03:
hasn't changed despite the fact that they acknowledge he's joined this new advocacy group.

[00:19:17] Speaker 03:
There's been charges levied against people who live abroad, but again, it comes back to where's the evidence that anyone outside of the Punjab in India has been targeted in this manner?

[00:19:27] Speaker 04:
I think Petitioner's Council is acknowledging that we shouldn't say at this point that the claim succeeds, but that we should be saying that the BIA didn't consider the right question because

[00:19:41] Speaker 04:
He was entitled to a presumption of future persecution.

[00:19:44] Speaker 04:
In the last round, that's how we finished the last round, but there was this relocation issue.

[00:19:49] Speaker 04:
He's got all this new evidence about, you may think it's not enough, but there is new evidence about things happening throughout the country, one way or the other, at least at the political level.

[00:19:58] Speaker 04:
And there's nothing in the board's decision that makes very clear anyway that the board thought about whether that changed the relocation issue.

[00:20:07] Speaker 03:
I point the court to those first two sentences of the last paragraph, which

[00:20:11] Speaker 03:
I think you see the board citing new evidence, particularly this tab, LOO, where they discuss this new change.

[00:20:17] Speaker 03:
How they seek war organization in Canada has stated that now we believe that Kalistan advocates are persecuted nationwide.

[00:20:26] Speaker 03:
They specifically cite that document amongst many, many documents.

[00:20:29] Speaker 00:
But how much was this really positioned to the board as a relocation issue?

[00:20:33] Speaker 03:
Well, yes.

[00:20:34] Speaker 03:
I noted that as well earlier that I don't think it was teed up that way for the board.

[00:20:40] Speaker 03:
I think you have the board addressing their claims.

[00:20:42] Speaker 03:
What does this evidence show for this petitioner?

[00:20:45] Speaker 03:
It shows that in the Punjab arrests have continued, and that's including for SFP members.

[00:20:50] Speaker 03:
But it doesn't show outside of the Punjab people who advocate for Kalistan have been arrested within India.

[00:21:03] Speaker 03:
Does the panel have any further questions?

[00:21:06] Speaker 04:
Thank you.

[00:21:07] Speaker 04:
Let's hear from the other side for rebuttal.

[00:21:15] Speaker 01:
The government's argument confuses me because it's undisputed that the Indian government monitors activities on behalf of Seeks for Justice as far away as Canada, Britain, and the United States.

[00:21:31] Speaker 01:
But I guess they're suggesting that although it monitors the SFJ's activities outside India, it doesn't monitor their activities outside of Punjab.

[00:21:42] Speaker 01:
That makes little sense.

[00:21:44] Speaker 01:
The record reflects that in December of 2020, the NIA, again, an arm of the city.

[00:21:52] Speaker 04:
I guess, let me give what I think is his argument and see if you can respond to it.

[00:21:55] Speaker 04:
What I take to be his argument is the BIA seems to be saying there is some activity outside of Punjab, but it's just not that bad.

[00:22:05] Speaker 04:
And so nothing has changed enough.

[00:22:06] Speaker 04:
I think he's saying that that's what we should read the BIA to say.

[00:22:09] Speaker 04:
So what is your response to why we shouldn't read it that way?

[00:22:11] Speaker 01:
The record indicates that there is almost no activity on behalf of SFJ in India, period.

[00:22:18] Speaker 01:
And that's because you can't advocate on behalf of SFJ without risking arrest and detention without trial.

[00:22:28] Speaker 01:
So the activities on behalf of SFJ primarily take place in the diaspora.

[00:22:35] Speaker 01:
It's undisputed that the Indian government monitors those activities.

[00:22:39] Speaker 01:
It's undisputed that they filed charges against seven people in the U.S.

[00:22:45] Speaker 01:
for their activities on behalf of SFJ.

[00:22:49] Speaker 01:
And if they're monitoring individuals' activities, our position would be this man has a reasonable fear that when he flies into Delhi, he will be arrested at the airport.

[00:23:03] Speaker 01:
There is every reason to believe that the government is tracking every single person that supports this organization.

[00:23:09] Speaker 01:
Any support for the organization is unlawful.

[00:23:12] Speaker 01:
And yet, the government believes he's going to be able to just walk free out of the airport.

[00:23:17] Speaker 00:
What's the specific record evidence that you would think is most powerful for this position?

[00:23:25] Speaker 01:
Probably the evidence showing that the Indian government granted the NIA the authority to investigate SFJ activities abroad in July of 2019.

[00:23:39] Speaker 01:
And that in December of 2020, it filed charges against 16 individuals outside of India, including seven here in the United States.

[00:23:55] Speaker 01:
And then obviously since then I don't it's not in the record, but it's been reported throughout the world

[00:24:03] Speaker 01:
The Justice Department filed charges indicating that the Indian government had conspired, a raw agent, Indian intelligence had conspired to assassinate Gurpatwant Singh Pannu right here in the United States.

[00:24:18] Speaker 01:
And the Canadian government expelled Indian diplomats after Hardeep Singh Najjar was murdered, according to the Indian government, according to the Canadian government, by the Indian government in Canada.

[00:24:35] Speaker 01:
The idea that the Indian government is willing to risk its international reputation to extraterritorially assassinate the leadership of this organization, but it doesn't care about seeks for justice in other parts of the country, it's just silly.

[00:24:52] Speaker 00:
In terms of this, if your client prevails here, is there something more unique about him or is this a ruling that would essentially

[00:25:02] Speaker 00:
apply to anybody who's straddling these time periods?

[00:25:06] Speaker 01:
I think you're going to be seeing more of these cases because the record is, this is the earliest record.

[00:25:15] Speaker 01:
The records that will be coming your way hopefully will be far stronger than this because the evidence at this point, it's just overwhelming.

[00:25:23] Speaker 01:
Again, it can hardly be disputed.

[00:25:26] Speaker 01:
The Indian government has murdered at least one individual in Canada

[00:25:32] Speaker 01:
and attempted to murder an individual here, Gurpantwant Singh Panoon, an immigration lawyer who's probably appeared before this court.

[00:25:43] Speaker 01:
I'd also like to point out that it's just not true that there are no instances where people outside the Punjab but in India have been targeted.

[00:25:54] Speaker 02:
At ER 209, there was a mention of an 18-year-old who liked a Facebook post.

[00:25:59] Speaker 02:
Is that an example?

[00:26:01] Speaker 01:
Well, in addition, this whole thing began back in 2017 or 18 when the BJP complained that there were posters being put up in these various places.

[00:26:12] Speaker 01:
But on page 30 of the record in our motion, we're citing to the situation in June of 2020 when pro-Khalistan posters were spotted in the markets of Haryana's Seersa district.

[00:26:28] Speaker 01:
Haryana is a neighboring state to Punjab.

[00:26:30] Speaker 01:
It's not Punjab.

[00:26:32] Speaker 01:
And then in addition, on page 32 of the motion, we talk about a situation involving this Lovepreet Singh, where the NIA arrested him for conducting subversive activities, pasting posters in Punjab and in New Delhi.

[00:26:54] Speaker 01:
In the following page, there's another Lovepreet Singh

[00:26:58] Speaker 01:
Same name, different guy, where the Delhi police file charges against him.

[00:27:11] Speaker 01:
I haven't gone through this to look for every citation, but without a doubt, there is evidence in this record and in the records that you'll be seeing in the future, I guarantee you, there's overwhelming evidence at this point.

[00:27:26] Speaker 04:
Thank you.

[00:27:27] Speaker 04:
We're taking your over your time.

[00:27:28] Speaker 04:
Thank you both sides for the helpful arguments.

[00:27:30] Speaker 04:
This case is submitted and we are adjourned for the day.