The PIL was filed by Tamil Nadu resident PK Subramanian through lawyer Naresh Kumar, and the apex court had voiced displeasure over Advocates on Record (AoRs) unmindfully appending their signature to such petitions. While Article 20 deals with protection in respect of conviction for offences, Article 22 pertains to protection against arrest and detention in certain cases. Both are included in Part III of the Constitution that deals with fundamental rights.