Please suggest few lines to the below draft to get ‘Call Data Record (CDR) with Cell tower information’ of the respondent (present applicant)
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IN THE COURT OF ………MAGISTRATE,
AT ………...
Crl.Misc.No. XX/XXXX
Between:
Smt. XXXXX . . . . . Petitioner
And
XXXX . . . . . Respondent
APPLICATION UNDER SECTION 91 OF THE CODE OF CRIMINAL PROCEDURE:
The respondent above named most respectfully submits as hereunder:
1. The petitioner has lied on oath before this Hon’ble court that she was harassed by the respondent after the marriage at his native place whereas the respondent was not there. The respondent also further submits that he went to Pune after the marriage and attending his duties since XX-XX-XXXX.
2. The respondent further submits that his mobile call data records with cell tower info for XX-XX-XXXX to XX-XX-XXXX will expose her false claims as she intentionally making false statements.
3. It is further submitted that as the petitioner has made false claims in her affidavit and if not proven wrong could put the respondent in a disadvantage position in this case.
PRAYER
WHEREFORE, the respondent in the above matter most respectfully prays that this Hon’ble court be pleased to direct XXX MOBILE SERVICE PROVIDER to provide CDR with Cell tower Information in the interest of Justice.
Place: Advocate for respondent
Date: XX-XX-XXXX
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