Ongoing Case- De-Seat President and Vice President of India like Kenya has Done

IN THE SUPREME COURT OF INDIA, NEW DELHI
ORIGINAL JURISDICTION

DE NOVO CIVIL WRIT PETITION NO. WP(C) OF 2017
[Under Article 32 of the Constitution of India]

DR. LEO REBELLO … The Petitioner (in Person)
People’s Presidential Candidate
Residing at: 28 / 552 Samata Nagar,
Kandivali (East), Mumbai 400101.

Versus

ELECTION COMMISSION OF INDIA
Statutory Body to conduct Free and Fair Elections
Office at: Nirvachan Sadan, Ashoka Road, New Delhi.

UNION OF INDIA
Ministry of Law and Justice,, 401, A-Wing, Shastri Bhavan, New Delhi.

MAJOR POLITICAL PARTIES … Respondents
AAP, BJP, CONGRESS, CPI, CPM, NCP, SHIV SENA

• In the matter of Presidential elections being held against the spirit of the Constitution of India.
• In the matter of violation of Articles 14, 21, 54, 55(3), 58, 71(3) & 324 of the Constitution of India.
• In the matter of ‘undue influence’ –an offense u/s 171C/171F of the IPC.
• In the matter of unjust rules made under the Presidential & Vice Presidential Elections Rules 1974
• To enforce powers vested, inter alia, in Articles 32 and 142 of the Constitution of India.

PETITION UNDER ARTICLE 32 OF THE CONSTITUTION OF INDIA FOR ISSUANCE OF A WRIT IN THE NATURE OF PROHIBITION

TO: THE HON’BLE CHIEF JUSTICE AND OTHER JUDGES OF THE SUPREME COURT OF INDIA, NEW DELHI.

MOST RESPECTFULLY SHEWETH

1.. The petitioner is a highly qualified Holistic Healer, Holistic Development and Possibilica Management Expert. He has delivered over 15,000 lectures in 65 countries, written 52 books and several articles, poems, reports. He is also a very well known blogger, founder of All India Letter-Writers Association [NGO of conscience-keepers of the nation founded in 1980, entered as a World Record in the Limca Book of Records], the President of Litigants Welfare Forum, since 1990, Founder of All India Voters’ Panchayat, and a prominent leader active in public life. Dr. Leo Rebello takes keen interest in Peace, Nuclear Disarmament, Environment and Education, Holistic Development, Human Rights, Health Freedom and Clean Politics, nationally and internationally.

2.. The petitioner does not wish to flaunt his achievements, but emphasizes that at 67 years of age and with his all round exposure and expertise he is wise enough and eminently qualified to serve the country as the President of India, and as such has been nominated by the People to contest the Presidential Elections 2012. But the wily and corrupt politicians, aided and abetted by the ECI, the statutory authority meant to conduct free and fair elections, has been denied the opportunity. It is a tragedy that in a country of over a billion people, we narrow our search, be it Sports, National Awards or Presidential elections, to a select few, for obvious reasons.

3.. The petitioner does not toe the money, muscle and media line of political parties. As such, in spite of numerous recommendations, he has not been nominated to Rajya Sabha under Article 80(3) of the Constitution. Likewise, his name has been nominated for Padma Award since 1990 continuously by prominent persons and/or institutions, for his outstanding contribution to Natural Medicine. But everywhere because of corrupt practices and partisanship, he has been discriminated. The same corrupt practices have also denigrated the Presidential and Vice Presidential elections. He has been trying to become the President of Vice President since 1998, 2002, 2007, 2012 and last try in 2017. See the campaign card below which explains at one glance my suitability for the august posts.

4.. To question the fraud every citizen has a locus standi, as held in the Dr. D.C.Wadhwa v/s State of Bihar case. Dr. Wadhwa, a professor of political science working in Pune, helped Bihar’s people in the preservation and promotion of constitutional functioning of the administration by filing a PIL (412 of 1984). Likewise, the petitioner feels that the manner in which Presidents and Vice-Presidents are elected, rather selected, have become a fraud on the Constitution, and this Urgent Petition is moved to Right the Wrong since the Respondents have failed in their duties.

5.. THIS PETITION IS THE FIRST OF ITS KIND and can be solely decided on its merit under articles 32 and 142 of the Constitution of India. Hence, the petitioner has limited the citations as he urges that this petition of national importance is NOT to be lost in the rigmarole of case laws. The petitioner will argue this case in-person. If the Hon’ble Supreme Court feels it necessary, it may appoint and amicus curiae in consultation with the Petitioner.

6.. In the present political setup, Presidential and Vice-Presidential elections do not offer a level-playing field. Only political heavy-weights, moneyed persons, senior politicians become eligible due to “undue influence” – an offense u/s 171C/171F of the IPC. Also violative of Articles 14, 21, 54, 55(3), 58, 71(3) and 324 of the Constitution of India. Our Constitution promotes good governance and according to former CJI J.S.Verma, “Article 32 of the Constitution, together with Article 142 is an effective tool with the Supreme Court to enforce the fundamental rights of citizens. The Supreme Court can make any order necessary for doing complete justice.”

7.. The reasons why Presidential and Vice Presidential Elections are not a level playing field are:
(i) A Presidential aspirant has to secure 100 signatures of proposers and seconders on his nomination form within 14 days of the notification, from an electorate spread all over India. This is impossible, unreasonable and unconstitutional to prescribe such a high number making it difficult for honest, good and competant professionals, visionaries and the statesmen, like the petitioner, to contest.

(ii) The nomination form and returning officer is available only in New Delhi, when the electorate is spread all over India. It means that the aspirant has to run to Delhi from his home state to collect the form and submit the same after getting the desired number of signatures of proposers and seconders, within 14 days. This is extremely difficult for a candidate without sufficient funds or resources of big political parties. Therefore, violative of the Equality principle in the Constitution.

8.. Even though the Constitution mandates that the President should be above party lines, the political parties announce the names of the candidates and issue direct and indirect whips to MPs and MLAs to sign the form of only their chosen candidates and strictly vote for their chosen candidate. This practice is blatantly against the equality principle and democratic norms, as it defeats the very purpose of free, fair and independent elections.

9.. This amounts to undue influence, threat, coercion and arm-twisting the voters, namely, the MPs/MLAs – a serious offense u/s 171C and 171F of the IPC. Voters are instructed, threatened that they will be disqualified; eventhough the Anti-Defection Law is not applicable in the Presidential or Vice Presidential Elections, since these elections are not party or symbol based elections. If one looks at the List of Voters published in June 2017 by the ECI under Article 54 of the Constitution of India and Rule 40 of the Presidential and Vice-Presidential Elections Rules, 1974, it becomes obvious that no party affiliation is shown.

1. It may further be noted that once the MP or MLA is elected, he belongs to the Nation or to the State. But when whips are issued to vote on party lines, it vitiates the atmosphere and negates the very principles of democracy, namely, justice, liberty, equality and fraternity. When whips are issued, the “sovereign representatives” of the people become “slaves of the political parties” and hence they cannot vote according to their conscience, free will or in nation’s interest and consequently, the Nation cannot progress. Whip goes against civility and tampers democracy and natural justice and should be done away with, per se, and those who violate the same knowingly in the Elections to the highest office of the President of India, should be debarred from doing so u/s 171C by the ECI by registering FIRs like they do u/s 171I, during election when it is not applicable.

2. Under Article 53, the President of India is referred to as the Executive President, and consequently, he is supposed to rise above political manipulations to guard the nation’s interests. H.E. the President, ipso facto, is supposed to be a statesman, free thinker, a learned and balanced man to guide the destiny of the nation by correcting the waywardness of the wily politicians in power.

3. As India’s first President Dr. Rajendra Prasad pointed out, the President cannot be equated with the British monarch, a hereditary post. “India’s President”, according to Rajen Babu, “is not bound hand and foot by the advice of his Council of Ministers”. He has the power to withhold assent to Bills in his discretion. The Rashtrapati can even dismiss a ministry or a minister and order a general election. As the Supreme Commander of the Defense Forces, the President can send for the Service Chiefs and ask for information about Defense matters. These powers, Rajen Babu argued, flowed from the President’s oath of affirmation under Article 60 of the Constitution, which is as follows: “I solemnly do affirm that I will to the best of my ability preserve, protect and defend the Constitution and the law and that I will devote myself to the service and well-being of the people of India”. On the face of it, the oath sounds innocuous. But, carefully read, it gives the President certain inherent powers to “preserve, protect and defend the Constitution.” It needs to be noted that he is expected to do this “to the best of my ability”. This ability has to be his own and not that of the Council of Ministers. The President has unfettered right to information. It is he who decides who shall become the Prime Minister. The choice is based on his ability and judgment. The Head of State thus becomes vital to the smooth running of our parliamentary democracy, especially in today’s era of fragmented coalition politics.

4. Therefore, the President of India should be a man of worldly wisdom, all round experience, absolute integrity, and scrupulous honesty and, above all, a patriot who has the ability and foresight to steer India through the difficult times like we are now passing through. The President’s august office should not get mired in political one-upmanship, ego clashes, wheels within wheels and deals, side deals, underhand deals should stop forthwith. Hence, in Presidential and Vice Presidential elections whip must go, political parties should not announce, support or campaign for any candidate for the posts of the President and Vice President of India. Only then a true democracy will be ushered in India and this petition is moved with that avowed purpose in mind.

5. For the last over 70 years Presidential and Vice Presidential Elections are not being conducted fairly, and unless the Supreme Court of India issues a proper writ or treats this as a Constitutional Petition, this wanton violation of constitutional provisions will go on and our great nation will go down the path of no return.

6. In 1998, 2002, 2007, 2012 and in 2017 the petitioner himself [and other aspirants] could not get a single proposer or seconder even though he met several MPs and MLAs cutting across the party lines. All of them said, “Since our leaders have decided and whip has been issued we cannot sign your form even though you are an eminent and brilliant person”. Practically all prominent political leaders and several members of the electoral college know me well. All of them are not only abysmally ignorant of their rights, duties, obligations, but also slave of their party heads. And less said the better about their corrupt, communal, criminal or dictatorial party bosses.

7. I am afraid, if this constitutional aberration is NOT corrected, there is absolutely NO chance for any talented, honest, motivated, deserving, meritorious candidate to get elected to the Highest Post. This amounts to discrimination and the Supreme Court in its wisdom has rightly said that discrimination is bad in law. Can we afford to indulge in such an anti-constitutional act ad nauseam? Hence, the petitioner repeats that political parties shall not announce, support or campaign for any candidate in the Presidential and Vice Presidential elections, shall not issue a whip in any form and allow the voters to vote as per conscience in a secret ballot. At Annexure I – a copy of the Statutory Notice dated 6th April 2012 served on the ECI to which the petitioner has not received a satisfactory reply.

8. The Seven-Judges Bench of the Supreme Court of India unanimously held in 1974 in the case of Presidential election that “the electoral college as mentioned in Article 54 is independent of the Legislatures ….. to act as independent electors”. If they are to act as independent electors, then how Electors can be prevented from signing the nomination paper and vote ONLY a party promoted candidate? Law and simple logic says that President or Vice Presidential candidate cannot be put up/sponsored by political parties by issuing whips and spending for his election. Thereby we are reducing a statesman into a politician, a rubber stamp and degrading the highest office – and this has been going on for so long, in spite of the fact that we have a reasonably good watch dog in Supreme Court of India, which has even taken suo motu action in many matters, but surprisingly has failed in this most important matter of national importance and gravity.

9. Presidential elections as per Constitutional spirit should be above party lines. When a political party sponsors a Presidential or Vice Presidential candidate, he continues to function as a politician favoring the party that gave him the opportunity. For example, Mr. Pranab Mukherjee and Mr. Mohamed Ansari, elected as the President and Vice President by the Congress (the party in power) were selected and elected in contravention of the articles mentioned above, when better options were available. Similarly, the BJP (the party in power) this time has selected President Mr. Ramnath Kovind and Vice President Mr. M Venkaiah Naidu, both from the RSS Cadre in preparation for piloting the Hindu Constitution, which will destroy our secular polity. This prevents the President from becoming an Elected Executive Head of the State in true sense of the word, thereby defeating the letter and spirit of Article 53. The Constitution makers did NOT want professional politicians to be the President or Vice President. What they wished was that independent persons of eminence, learning, wisdom – in short statesmen – to guide the nation’s destiny through these two premier positions. But the pygmy politicians have sabotaged the very far-reaching principle and that explains why our country is not progressing in spite of having the best of talent and resources.

10. May it be noted that to select a ‘party candidate’ for the august office, foisting him on the electorate, then getting him elected by issuing a direct or indirect whip, is a fraud on the Indian Constitution, its egalitarian spirit and hence some provisions of the Presidential and Vice Presidential Elections Rules 1974 are hereby challenged being ultra vires to the Constitution of India.

11. Now let us look at Section 5B(a) and Section 5C(1) of the Presidential and Vice Presidential Elections Act, 1952 (Act 31 of 1952) and Rules 1974 dealing with the numbers of proposers and seconders and election deposit. All of a sudden the number of proposers and seconders was raised to 100 making it impossible for non-party and honest candidates to contest. This is not only against democracy but also against the constitutional provisions. In other words, we do not have a Govt of the people, by the people and for the people, but a Govt of the mediocre, manipulators and the corrupt.

12. In 1952, when the Presidential and Vice Presidential Election Act was enacted, there was NO security deposit. The candidate himself, with two electors as proposer and seconder, could file the nomination. In 1974, when the Act was amended and rules were framed, the deposit of Rs.2500 was introduced and from one proposer and one seconder the figure was raised to 10 proposers and 10 seconders to make the application valid. Then, vide Presidential and Vice Presidential (Amendment) Ordinance 1997 (no.13 of 1997) this amount was raised to Rs.15,000 with 50 proposers and 50 seconders required, ostensibly to keep away the frivolous candidates. Can one really keep frivolous candidates away by raising the deposit amount? Is it the contention of the Govt. or the EC that moneyed candidates are not frivolous? In a country of over a billion people, why a hegemony of a select few should be allowed to continue? Whether the Ordinance 13 of 1997 has been ratified by the parliament, or made into a law is not known. Like in Bihar one Ordinance was kept alive for 11 years until the SCI came down heavily on the Bihar Govt.

13. Under Article 324, the Election Commission is mandated to ensure that the election to the office of the President of India must be a free and fair election and accordingly it must take necessary steps to discharge its responsibility. Superintendence, direction and control, which are vested in it, should not willy-nilly defeat the very principles of democracy (which is the rule of the people, by the people and for the people). The EC, at all times, must function within its jurisdiction. But the credible conductor and monitor of the poll process seems to have forgotten its responsibility and left behind a legacy of institutional over-reach by several half-measures. The ECI has become a vassal of the corrupt governments in power because even the Chief Election Commissioner and two other Election Commissioners are appointed on the basis of their compromising psychology or pliability principle.

14. As per Article 54, the President is elected by the members of an electoral college consisting of (a) the elected members of both houses of Parliament; and (b) the elected members of the Legislative Assemblies of the States. But when candidates are selected and foisted and when tacit instructions are issued to vote in favour of a particular party-nominated or sponsored candidate, this amounts to an indirect whip, which is not permissible and, as such, goes against the letter and spirit of the Constitution – the reason why the Supreme Court cannot turn a blind eye to this any more. Otherwise, the SCI itself will be failing in its sacred duty.

15. Article 58 mandates that the qualifications for election as President will be that the aspirant will be (a) a citizen of India, (b) who has completed the age of thirty-five, and (c) is qualified for election as a member of the House of the People.

16. Why then people always beyond retirement age are selected as President or Vice President and foisted on the nation by the party in power? Does not that amount to manipulation? In recommending 35 years as the minimum age, the founding fathers wanted talented young blood to guide the destiny of the young nation. This is all the more necessary in technologically advanced 21st Century when India’s 65% population is below 35. Consequently, the rules made should be in consonance with Article 58(b). Therefore, the Supreme Court may also think of prescribing the retirement age for politicians, especially since Article 58(b) is routinely violated in the reverse. Instead of selecting candidates of 35 entry age, candidates are selected of exit age. There is also a sound rationale behind this request for retirement age for politicians. If a Govt. servant can be retired at 60, the high court judge at 62 and the Supreme Court Judge at 65, no matter how brilliant that person may be, then how is it that old politicians are appointed to be at the helm of affairs when even our age old culture talks of Vanaprasth and Sanyas? With due respect, the important question that emerges from the above discussion is: Is the Rashtrapati Bhavan an Old Age Home or a vibrant Watch Dog over puny politicians and their antics leading to polarization of the country?

GROUNDS OF THE PETITION

1. It is submitted that the Offices of the President and Vice President of India are apolitical offices. It is further submitted that the office of the President of India being the Chief Arbiter of the Nation cannot be politicized. To issue an indirect or direct whip, to sponsor a candidate and get him elected as President and Vice President is to ensure that he becomes a puppet of the regime in power. This, according to the Constitution of India and Presidential and Vice Presidential Election Act 1952 and Rules of 1974 is not just, fair and proper. In fact, these are unfair electoral practices or offenses. Strictly speaking the Party president or the person issuing a whip should be debarred for a period of 5 years from contesting elections and also prosecuted under section 171C-171F of the IPC.

2. The term of the President is for a period of five years. Consequently, if the President is elected on the basis of fraudulent practices, whatever Ordinances he is made to sign or the laws that he signs during his five year term become fraudulent leading to degeneration rather than progress. Like for example, President Ramnath Kovind and Vice President M.Venkaiah Naidu, both RSS cadre men, who are posted their to usher in a Hindu Constitution which will balkanise our country destroying its secular polity.

3. The qualifications for election as President do not speak of the 100 signatures. Consequently the election commission laying down its own unjust criteria amounts to altering the Constitution. In fact it appears that the EC is adding its own sub clause (d) to Article 58, namely, “No person shall be eligible for election as President unless he obtains the endorsement of 100 MPs and MLAs from the electoral college”. Nowhere in the Constitution has any Article or sub clause allowed the EC to decide such qualifications. Therefore the EC has crossed its brief and its action amounts to “amending the Constitution, which cannot be allowed”. This is nothing but “procedural discrimination” as held in State of WB v. Anwar Ali Sarkar. [AIR 1952 SC page 75].

4. This process does not offer a level playing field and is against the basic Preamble of the Constitution of India, which talks of a goal to secure to all citizens “Equality of status and of opportunity”. The preamble, as we all know, is the face of the Constitution. If the face itself is defaced, and fundamental rights are thrown to the wind and directive principles are lynched by the globalisation juggernaut and ‘bloody Corporates’, will India emerge as a Giant or a polio affected cripple with President and Vice President of India too being cut to size and controlled by the pygmy politicians?

5. “Article 14 guarantees equal treatment to persons who are equally situated” as held in Government of Andhra Pradesh v/s Maharshi Publishers Pvt. Ltd. 2003. SC 296. There are many who are neither politically, financially nor geographically equally situated but who are far superior to the persons consolidating power in their hands by chicanery and deceit. Preventing such talented persons by deliberate intent amounts to manipulation of the Constitution, which ought not to be allowed.

6. Excessive Delegation: The criteria to decide the minimum number of signatures is an essential legislative function beyond the scope of one authority. Delegated legislation is usually for day-to-day matters where the Parliament may not have enough time to legislate on the issue. In this case, neither Presidential nor Vice-Presidential elections are day-to-day matters, but matters that come up once in every five years.

7. Therefore, the EC by laying down unjust rules, as outlined above, is creating a parallel legislation. If the Parliament under Article 71(3) “under the right to regulate any matter relating to or connected with the election of a President or Vice President” has made or recommended these rules, then the constitutional validity of such rules itself should be gone into. Because, as held in Dr. D.C. Wadhwa case, “The Constitution cannot be perverted to serve political ends” to the detriment of the Citizens.

8. Mr. Justice J. S. Verma, former CJI, commenting on the basic structure of the Constitution of India writes: “According to the decision of the Supreme Court in Keshavananda Bharti case, the Constitution has a basic structure which cannot be violated by any legislation made by legislators. The decision of the Supreme Court on 12/01/2007 reiterates this old position”. Writing on the worth of our Constitution, Justice Verma adds: “According to Dr. Rajendra Prasad, the worth of our Constitution will depend ultimately on the worth of the persons who work with it. The need is or a renaissance of values to realize the full constitutional promise of a democratic republic.” [Legal News and Views (Vol.21 No.4) April 2007].

9. The petitioner submits that he has already sent enough Memorandums/Notices to the Election Commission of India, various political leaders and the media, without any result or any change in the system. Therefore, he has no alternative, efficacious remedy to redress this grievance, except to approach this Hon’ble Court.

10. This is the ONLY court under the Presidential and Vice Presidential Elections Act 1952 where such a petition can be taken up. Hence, this petition is moved before this apex court for expedited hearing and disposal. Save this there is no other petition.

11. This first of its kind WP/PIL should be heard by the full constitution bench on priority basis.

PRAYERS

1. In the above premises, it is prayed that this Hon’ble Court may be pleased to grant the following
   (a) The Presidential and Vice Presidential (Amendment) Ordinance 1997 (no.13 of 1997) be withdrawn as being unreasonable and anti-constitutional.

(b) To reduce the total number of signatures of 100 MPs/MLAs required on the nomination forms to a reasonable figure of say 20 proposers and 20 seconders for the President and 10 proposers and 10 seconders for the Vice President, respectively.

(c) To issue a Writ of Prohibition debarring political parties from selecting, nominating, imposing a candidate and/or issuing a whip overt or covert, canvassing for a particular Presidential or Vice Presidential candidate directly or indirectly, as being the violation of the Presidential and Vice Presidential Act and Rules and the Articles of the Constitution mentioned above.

(d) The Party presidents or the persons issuing a whip should be debarred for a period of 5 years from contesting elections and also prosecuted under section 171C-171F of the IPC.

(e) Those connected with party politics for long, or party nominated candidates should not be allowed to contest, because that is the mandate of the Constitution.

(f) Since both President Mr. Ramnath Kovind and Vice President Mr. M. Venkaiah Naidu, both RSS cadre candidates committed to a decadent ideology “elected” by dubious methods, in contravention of several articles, laws, rules and regulations, their election should be held invalid and de novo elections held under the strict supervision of the Supreme Court of India.

OTHER PRAYERS FOR CONSIDERATION

(i) To direct the ECI to accept the completed nomination forms for the Presidential election even at the State or Union Territory level, because Asst. Returning Officers are in any case appointed in all these places.

(ii) Reimbursements of Costs, if possible, because the Petitioner operates on a shoe-string budget and since this petition is moved in public interest in the exercise of fundamental duties as enshrined under article 51A this may be considered as a Special request. There is a precedent in Dr. D.C. Wadhwa case (412 of 1985) where the then CJI P.N.Bhagwati awarded Rs.10,000 to the Petitioner.

IN CONCLUSION

Though the truth is open to all, many do not feel any urge to seek.
Of those who have the urge, many suffer from doubt and vacillation.
Even if they do not have doubts, many are scared away by difficulties.
Only a few rare souls succeed in braving the perils and reaching the goal.
Bhagvadgita as quoted by S. Radhakrishnan, Learned President of India

Vide this timely and important Petition, the undersigned is performing his Duty of a Conscientious Citizen as aptly summarized in the above quote. The petitioner does this in the firm hope that the Hon’ble Apex Court too will not renege from performing its duty with alacrity since the ECI too has failed in spite of having been put on notice.

President’s office is the highest elective office. Therefore, wrong persons like President Ramnath Kovind or Vice President Venkaiah Naidu cannot be allowed to occupy such an august office. Because then the entire focus of the nation is shifted from Holistic Development to fragmented approach and even 70 years later teeming millions still live in abject poverty, die of malnutrition, bondage etc due to it. The Hon’ble Judges of this Apex Court must make sure that a level playing ground is prepared so that the talented and dedicated persons like the undersigned get to occupy this august office in consonance with the provisions of our Constitution. Rashtrapati Bhawan must continue to inspire national confidence and remain above all controversies and petty politicking. Anything less will be disastrous. Hence, this petition under article 32 of the Constitution.

Sd/-
Dr. Leo Rebello
Petitioner-in-Person
Bombay, 2nd October, 2017.

VERIFICATION

I, Dr. Leo Rebello, the Petitioner-in-Person, residing at 28/552 Samata Nagar, Kandivali East, Mumbai 400101, do hereby solemnly affirm and state that whatever stated in this Writ Petition challenging the grave irregularities in the Presidential and Vice Presidential Election Act 1992 and rules of 1974 is true.

I have filed the petition in the fact and circumstances mentioned therein and on the grounds set out in the body of the petition. I hereby repeat, reiterate, reaffirm and confirm whatever stated by me in my petition.

I submit that the petition is factual, there are no allegations and that I should be granted the prayers as prayed for in the petition expeditiously in Public Interest.

Solemnly declared on 2nd October, 2017. Dr. Leo Rebello
Petitioner-in-Person

 

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Dr. Leo Rebello

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