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I read an article in "The Hindu" which was titled as:

In 2015, SC had termed ‘frivolous’ plea on Rahul’s citizenship

Now, the article (source) talks about a plea filed by Rahul which was described by SC as "frivolous". So, it got me into thinking that the title should be more like

In 2015, SC had termed a plea on Rahul’s citizenship as "frivolous".

Am I right?

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Article headlines, often do not follow rules of grammar, that needs getting used to.

This is a sentence construct designed to be punchy, the fact that SC has called something frivolous was considered more important that was was insulted.

It is actually missing is the word 'the'

In 2015, SC had termed ‘frivolous’ the plea on Rahul’s citizenship

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