Please suggest corrert ammendment in self reply of respondent in quashing plea in high court
manojkumar
(Querist) 30 September 2014
This query is : Resolved
Dear sir please suggest corrert ammendment in self reply of respondent in quashing plea in high court please corret the legal format of reply and translation of english i can not pay fees of advocate being a poor man you can demand all papers by mail from me
THANKX
In The Court of Honorable justice smt sabina Punjab and Haryana High Court Chandigarh.
Rahul Jain & other Vs State of Haryana - &
Res No 2 Manoj kumar complainant of Fir 247
Dated October 6, 2014
Case No 32007/2014
The lawsuit claims the complainant Manoj Kumar Reply of Respondent No. 2 and complainant of main case FIR No. 247 Dated 18/05/13 p.s City fatehabad
Today present at the court . That as per the police record Rahul Jain s/o Anil Jain Religion Christian R/o Government quarters civil Hospital compound patti mehar, Baraut District Baghpat U.P. and Punjab Singh r/o Bhatia colony fatehabad Haryana and Rahul both the Nominated charges in the Fir no 247 dated 18/5/13 u/s 363.366 A, 120B And also both are involved accused in the Section under 174-A declared proclaimed offender in the criminal cases.
These all process can not be dismissed but very custodial interrogation of said accused is very important in this case.
1-it's that Rahul has suit file in the High Court appeal which First Information Report No. 247 dated 18/5/13 P.S Fatehabad has with regard to cancel them completely non-result in severe civil and Court of Constabulary is officially founded is misleading to dismiss baseless, and have since the day my 16.7 year old minor daughter was Kidnapped by him, from that day until today minor girl is in the illegal custody of accused petitioners.
So far none of the wedding my daughter accused not occurred if they lie and then she claims it Bay-Foundation, based on the fake documents and mislead to the honorable court by fake & False Documents.
Accused Petitioner and his accused Uncle Punjab Singh and aunt meena has Try by this that way of fake and false documents for the approval of illegal marriage with minor girl They sent some documents to date 20/05/2013 on the istam paper as Viwahbndh patar Istam paper number - 90 AB 556799 was drawn on paper and affidavit (sapath patar) stamp paper number - 90 AB 635377 was prepared (copy also attached as P.W 1)
for the misguide to law and makes fool to police for getting the police protection by illegal way they produced an fake legal affidavit with Notary attested to the S.P fatehabad for PURPOSE OF getting police protection by correspondence letters but after the our on demand investigation of said documents all marriage affidavit and all stamp paper, witness of advocate and notary public all thing found fake and false (Reports is Available in the police record)
After investigation of above papers found that there are no vendor was found in the Meerut from where it has vivahbandh letters &Affidavit (sapthaptra)
ware makes and purchased out & there are no vendor found stamp papers was saled out and released also found not be released from the Meerut tahsil,Fake notary public also does not found in the complete tahsil nor Fake jitendra Malik advocate who attested these papers dose not found in the meerut.
It may also be able to be trying to honourable High Court as per the above incident of misleading with fake documentary papers
Respondent no 2 manoj kumar have been filed a suit against the police in the said F.i.r no 247 in the honorable lokayukta haryana court for the close relation of police officers with the petitioner accused case. No. = 907/2013 to put toward the Constabulary is officially founded summons has been issued to the police officers
In the first view police involved with the illegal activaties of accused and found that the investigation officer was not acting as per law (Notice of lokayukta enclosed as p.w2)
Petitioner and associate persons has filed present application for the quashing of Fir without any legal right to so for
they are accused under section 363,366 a,120b i.p.c
they are is declared proclaimed offender under section 174a
from the trial court
that is possible rahul had been get marry with minor girl by illegal way through fake documents becouse these group is mastermind of the illegal paperwork
but court of law can not provide the permit to the this types marry with the minor girl illegal or fake document .
eligible Important case are;-
Truth is that if Plaintiff has unlawful married to minor girl yet this is all fake story. they kidnapped minor girl from 18/5/13 and police cooperate him illegally by out way. Police was not want to trace the minor girl due to helping to the accused
ii), Petitioner and associate persons was declared proclaimed offender form the court and these all is involve in the serious allegation us 363,366a,120b and 174 A ..
Iii) plaintiff can not perform marry with this minor girl
becouse plaintiff is belong to the Christian religion and girl is belong to the hindu religion H.M act not allow to marry with two different religion
V) 1 Hindu Marriage Act "5. Conditions for a Hindu marriage.-A marriage may be solemnized between any two Hindus, if the following conditions are fulfilled, namely- (not allowd any other religious as ) in this case plaintiff is not hindu
2 (iii) the bridegroom has completed the age of [twenty-one years] and the bride, the age of [eighteen years] at the time of the marriage;"
Law Reference In this case the following cases order of Honorable High Court according to proclaimed offender
i)- In the High Court or Punjab And Haryana
Crl.Misc.No m-24612 of 2012 (o & m ) date of decision April 03 ,2013
Baljit singh alias Raju and others Vs State of Punjab
( The present petition has been filed under Section 482 Cr.P.C. for quashing of FIR No.266 dated 13.12.2011, registered at Police Station City Tarn Taran, District Patiala, under Sections 363, 366-A, 120-B IPC. Counsel for the State, after seeking instructions from the Investigating Officer, submits that petitioner Baljit Singh has been declared a proclaimed offender. In this view of the matter, no ground for quashing of the impugned FIR is made out. Dismissed.) (Downloaded copy nathi e. x 3)
ii)Jagdish Kumar vs State Of Punjab & Anr on 29 July, 2011
CRM No. M-26019 of 2009 (O&M),Date of decision: 29.07.2011
(Court is made out under Section 482 Cr.PC for quashing of FIR in question is made as the petitioner has been declared a proclaimed offender. Dismissed. ) (Downloaded copy pw 4)
Delhi High Court case la shame .order According to a minor State vs. married according to Hindu marriage palaces might not see sakti-Act
( IN THE HIGH COURT OF DELHI AT NEW DELHI
+W.P. (Crl.) No.338/2008, Crl.M.C. No.1001/2011 & Crl.M.A. No.3737/2011,
W.P. (Crl.) No.821/2008 and Crl.M.A. No.8765/2008, WP (Crl.) No.566/2010
1) W.P. (Crl.) No.338/2008
COURT ON ITS OWN MOTION (LAJJA DEVI) Petitioner VERSUS STATE minor girl would neither be void nor voidable under the Hindu Marriage Act, 1955 (hereinafter referred to as the HM Act {Page no 5 of said order })
(Downloaded copy of order enclosed as pe.5)
Daily News danik bhaskar appeared in akhbar of 27/9/14 according to news, Rahul Jain, Punjab singh and meena has been changed the name of minor girl changed according to put the name as Christians also Sonam Jain on the place of Sonam Rani
(Copy of the newspaper cutting enclosed asPw.6)
Respondent No. 2 in this case and complainant of this Fir Manoj Kumar has been files a suit in the honorable high Court habeas corpus /direction case number-Crl. Misc No. M-17882 of 2014 (O & M) Manoj kumar Vs State of Haryana that that is pending doe next hearing 16 October 2014 issued notice to the haryana police for filing affidavit
(Copy of said daily order enclosed as Pw.7)
Prayer
Respondent No. 2 pray to the honorable court that in the view of the the above all point petition of the accused plaintiff keeping artworks in the said by dint of vicious criminals and fake documents laws/misleading to try to put the plea by Rahul to be dismissed as economic penalties and making to the order to the police arrest to the all accused immediately for the produce potential threat on the process of the trial court ,
Respondent No. 2
Place:Chandigarh Manoj Kumar s/o Mr. kirpa Ram
Date:06/10/2014 Bhatia colony fatehabad
ajay sethi
(Expert) 30 September 2014
we dont correct drafts . get it settled by a local lawyer
R.K Nanda
(Expert) 30 September 2014
take help of lawyer.
BAALASUBRAMANNYAMM
(Expert) 30 September 2014
I think, no expert in this forum have time to read such a too long matter and made corrections.
T. Kalaiselvan, Advocate
(Expert) 05 October 2014
It is better you discuss the issues with some of your known accomplices who are well versed with such issues. The experts here will be able to guide you only on some critical legal issues and not to draft the legal pleadings.
