Exclusive HOLI Discounts!
Get Courses and Combos at Upto 50% OFF!
Upgrad
LCI Learning

Share on Facebook

Share on Twitter

Share on LinkedIn

Share on Email

Share More

Kiran Kumar (Software)     21 August 2013

Qeustion on crpc 125 and prejury

 

My Wife filed crpc 125 by putting all false allegations. Can I file prejure for any of below,

 

a) My wife mentioned, I have purchased house property with dowry amount and it belongs to her. But I have taken Loan from LIC and paid through my salary account using EMIs, Can prejury apply here

b) She mentioned her parents spend 2,00,000/- for her medical treatment, and I made medical claim enchased same without providing any medical treatment with a cheating intention to employer and insureance company.

but  the hospitalization is cahless and I requrested insurance company to provide detials, they sent me email that all the bills are paid to hospital and not to me.

Thanks,
Kiran.

 

 



Learning

 4 Replies

stanley (Freedom)     21 August 2013

Has she filed an affidivat for the same , if so than you can file for pre-jury under crpc 340 .

Raja_498a Victim (Manager)     21 August 2013

First, you get all proofs against her and if she is working and no kids then you need not pay any maintenance. However burden is on you to prove.

Ask her to provide affidavit which will be useful later to file perjusry etc.

First important thing in 125, is to give maintenance amount, you need to get proofs on her source of income.


(Guest)
Yes you can file prejury case u/s 340 crpc if she had filled affidavit and solemn affirmation under oath.

(Guest)

Just read this draft to clear your doubts:

 

Sample/Draft S.340 CrPC Application for perjury 

IN THE COURT OF A.C.J Magistrate __TH COURT AT Fatehpur, U.P. C.C. NO. ______/2010 Mrs. Anuradha ..….Applicant Versus _________________ ….Respondent[ Present Applicant ]

RESPONDENT’S APPLICATION U/S 340(1) of Cr.P.C, 1973. FOR THE ACT OF PERJURY COMITTED BY THE APPLICANT UNDER AFFIDAVIT AND SOLEMN AFFIRMATION UNDER OATH SUBMITTED BY THE MAIN APPLICANT IN Fatehpur COURTS.

MAY IT PLEASE YOUR HONOUR: I, Mr. _____________________, respondent above named, do hereby state on solemn affirmation as under:- 1. Present petitioner is father in law of main applicant

2. Main applicant is well qualified lady, having completed B.A and currently doing M.A and registered with employment exchange, and is educated and literate, and knowingly and willfully has been filing multiple cases against respondent applicant, being a educated lady has armored self-same with tool and weapons of criminal procedures to harass respondents by way of different ways.

3. It is most respectfully submitted by the Respondent that the couple stayed not more than __ days, i.e.______________.

4. The facts mentioned and maintained by applicant wife are contrary to applicant wife’s father in different litigations about same event on same date, i.e. on the date of marriage; The applicants self same submissions are contrary to her own self substantiate facts, made to mislead the Ld Court.

5. That present applicant respondent knew the complainant and her family members before marriage since more than 20 years and knowing about them the respondent without any demand of dowry directly/indirectly, without giving or taking any dowry of whatsoever nature married main applicant wife since both families knew one another since long.

6. It is admitted fact that main applicant including 2 sisters have filed 498a matter against their respective families, and in trial main applicant wife also has accepted this very fact, the alleged facts of all complaints by all sisters in their own 498a cases is same that they were assaulted and demand of 50,000 Rs was made and they were kicked out of the matrimonial home

7. That is it submitted on affidavit that the main applicants allegations are that she was assaulted and demand of 50,000 Rs and motorcycle was made. Affidavit filed 26-10-2010 states that she went to police station on 13th July to kotwali Fatehpur, her complaint was not taken is alleged. Hence she forwarded the written complaint to SP Fatehpur by way of registry the same information was given, the same can be observed in ____/____ under affidavit and substantiated evidence, annexed as Annexure “A1″

8. That in witness box the self-same complainant has substantiated the fact, in the matter of 53/06, it is material on record and substantiated that on 12-07-2005, self-same applicant wife went to kotwali Fatehpur and 498a case was registered in the kotwali and the final report of that matter has been reported by Kotwali Fatehpur.

9. In clear view and plain reading the applicant complainant is educated person and literate lady, and has willfully with clear oblique intentions to harass the present applicant and to mislead the court of law in different courts, in the imaginary notion that one court of law cannot come to know what she has substantiated in another court of law, and there by misleading the court of law and playing pranks of judicial institution and false statements, from one court to another court of law, and harassing innocents, and interfering in the administration of justice. And is using court of law as a tool. Heavy fine should be levied and stern action and punishment should be provided to restrain other such litigants from making such false allegations and complaints against entire family, and this litigant has tried to break the family system, If such litigants are not punished others will gain confidence and the family system will start to destroy in Indian Society.

10. It is admitted fact that father of complainant has also been tried for murder case; this fact is also admitted by the father of complainant and main applicant and is on material on record.

11. That Respondent stays in ________ since he was 17 years of age and continues to stay there, these above facts in paragraph 3 and paragraph 4 were not known and were kept hidden from the respondent and family, this amount to cruelty upon the present applicant respondent and his family members.

12. It is most respectfully submitted by the Respondent that the main applicant wife has filed for the reliefs u/s 498A, 406, 323, 504, and 506 of IPC by way of 156(3) on oath on 07.09.2005, which was received as 65/05 in the court of C.J.M Fatehpur; with allegations that she was assaulted and demand of 50,000 Rs and motorcycle were made by respondents and other members within 21 hours of marriage and she left thereafter.

13. Respondent had to move Honorable High court of Allahabad for relief u/s 482 Cr.P.C and Stay Arrest until filing of Charge sheet was granted by Honorable High Court of Allahabad.

14. Main Applicant wife filed one more private complaint dated 23.08.2006 with J.M Court Number 13 again u/s 498a, 323, 504, 506 and 34 of IPC and u/s ¾ of The Dowry Prohibition Act, on same grounds and same facts which should be null and void as per 300(1) Cr.P.C and to avoid double jeopardy.

15. Respondent again moved Honorable High court of Allahabad for relief u/s 482 Cr.P.C. and Honorable High Court of Allahabad directed for consolidation of both cases of 498a and directed to submit report under 173 Cr.P.C. in consolidation, the said Order from Honorable High Court of Allahabad is annexed as Annexure “A”.

16. Executive machinery police has filed a final “B Summary” report u/s 173 Cr.P.C on 14.02.2007. Main applicant wife has filed a protest application the order is passed, and upon which 1477/10 is initiated.

17. That Main applicant wife has filed false Maintenance Case u/s 125 Cr.P.C, Case No. ____/05 on __.__.2005, in J.M Court Fatehpur. Against husband who is otherwise a student, and is allegedly stated that he earns 20,000 Rs, which is false and imaginary to which no proof could be established and is unnecessary tactics used by applicant who is well aware of court procedures; And 125 Cr.P.C proceedings, relief to the wife were prohibited and application by applicant wife was dismissed at the outset.

18. The Maintenance case 125 Cr.P.C beyond doubt was dismissed by way of long and lengthy speaking order; as per Order Annexed as Annexure “B”.

19. Father of complainant wife , during Trial of 125 Cr.P.C, In the facts substantiated stated that he did not visit Respondents home until his daughter came back home when she was demanded dowry, only then he came to know about demand of dowry and assault on her. Annexure “C” green shaded region on page number 4 in ____/05 case. Adding that he was not even aware by any sorts of communication or by phone or by some person or by any other means, Shri Satyanarayan Awasthi was not at all aware that his daughter was demanded dowry or was assaulted by respondent/family members.

20. On the contrary, Main Applicant wife in her sworn affidavit and submissions in Case of u/s 9 of Hindu Marriage Act, Case Number __/06 in the J.M. Court Number 1 on page number 6 “dafa no. 8″ , states that she was being assaulted by respondent and family members during such time the servant who also worked in Main Applicants home also, saw this and went and informed family of Main applicant wife, and the same was communicated to family of main applicant by the applicant over telephone that there was nothing , But hearing this , since the distance between Main Applicant and Respondent is very negligible and can be reached in less than 5 minutes by walk; Father, Mother, Brother and some relatives came to respondent home and after discussing the matter was resolved, but that continued and then thereafter main applicant was forced to leave Matrimonial home and go to parental home.

21. These prima facie facts of the submissions of main applicants and her family members as per paragraph 13 and 14 of this application above, who have moved the court of law and initiated process that is otherwise, abuse the law, that is otherwise for destitute women application but is utilized for harassment making use of law as a weapon and tool to make innocent family members face criminal trial, which amounts to a very serious nature, The application moved by main applicant wife being not maintainable and she has suppressed the relevant facts and application being false , baseless, vexatious, imaginary. And hence do not make out any prima facie case against the respondents so as to summon the respondents to face trial and in this circumstances taking cognizance against the respondents is bad in law and is untenable in the court of law, cannot be sustained, that it amounts to abuse of the process of Hon’ble court.

22. The facts mentioned and maintained by applicant wife are contrary to applicant wife’s father in different litigations about same event on same date ; The applicants self same submissions are contrary to her own self substantiate facts

23. That the application filed by main applicant wife during various times have changed the facts according to the need of context and sense of urgency and has manipulated facts with willful intention, while submitting information to the Ld Court, in various court of law, in cases filed by main applicant wife; the facts are imaginary and false, and this amounts to grave misuse of court of law and interference in the administration of justice and denying the liberty to the real victims, here respondent and family members.

24. The changing facts and misuse by main applicant wife, amount to disturbing the purity of law and damaging the serenity of the stream of justice and interferes in the administration of justice thereby performing acts of perjury in every application in the notion of applicant wife that law is meant for harassment and since the applicant is a female will be exempted for her cruelty and using judicial system for her barbaric acts upon the respondent and his family members and destroying image and reputation.

25. The persons who use the court of law for their private and personal vendetta should be punished severely so as to curb the menace of misusing and harassing the innocent families, such cases should become the highlight cases and offenders should be sternly dealt with, without looking at the gender or caste or creed, which are not exempted from Article 15(3) of Constitution Of India.

26. The main applicant wife has willfully and with malafide intentions has filed the instant application, which is devoid of any merit and is interference in the administration of justice.

27. The Main Applicant wife has also filed Application u/s 12 of “The Protection of women from Domestic violence, Act”. U/s 18/19 of the said Act, On 30.05.2009, case number __/09, in the CJ.M Court Fatehpur.

28. The Main Applicant has filed the matter against Respondent, his ____________, ______________, also has roped and implicated brother Of respondent ______________________without any cause of action, again fabricating evidence that she was assaulted on false and fabricated grounds.

29. It is on material record that the Domestic Incident Report, In Domestic Violence Application, created as per procedure, by probation officer stated that no police officials are aware of the facts mentioned in the mentioned domestic violence application, where the incident allegedly had took place in domestic violence application, and that even after inquiry made by probation officers enquiry, and sequences of findings and observations made by probation officer came to conclusion that such facts as claimed by applicant wife were found false in the knowledge of people at alleged scene and scenarios mentioned in domestic violence application, and hence the same were false, the probation officer during such probe also came to know that applicant wife has filed 498a two times and that her 125 Cr.P.C and revision of 125 Cr.P.C were rejected by honorable court, when wide probe inquiries were made by the probation officer.

30. That clearly the domestic violence application was also moved with the willful intention to injure and harass the respondent and family members and using court of law as a weapon for harassment.

31. That the domestic violence application is also dismissed on the meritorious grounds by way of lengthy speaking order, by the magistrate.

32. The main applicant has also fabricated medical report in the domestic violence to prima facie prove Domestic Violence, and the incidents alleged. The facts mentioned by main applicant wife are absolutely ambiguous and imaginary has suppressed the relevant facts and application being false, baseless, vexatious, and imaginary. And hence do not make out any prima facie case against the respondents so as to summon the respondents to face trial and in this circumstances taking cognizance against the respondents is bad in law and cannot be sustained it amounts to abuse of the process of Hon’ble court if without prima case having being made out a person is summoned to face trial.

33. The application of main applicant’s wife under section 125 Cr.P.C that was rejected and dismissed by Ld Court. The order was challenged by wife and the same was again rejected in session’s court while under revision, Revision Order is annexed as Annexure “D”.

34. The Main Applicant wife has concealed and suppressed true facts, submitted under oath has false submissions under oath, and more so are contrary to the submissions to this honorable court, which are perjurious in nature.

35. The main applicant wife in her complaints / applications until year April 2011, made no whisper of any Bengali girl with whom _______________had any intimation relation, In Application under affidavit filed by applicant wife u/s 9 of Hindu Marriage Act it is alleged that photo of Bengali girl was with ___________________ displayed to applicant wife and he started kissing the photo in front of Applicant wife. That the facts are baseless and imaginary and are false and fabricated and such cruel acts are performed since year 2005 where she didn’t even spend more than 21 hours.

36. Such allegations were not present in any previous applications of 498a matter or 125 matter, or revision under 125 , even Domestic Violence application was filed and the reliefs are dismissed by way of wide speaking order, and such new facts have landed on the legal grounds, this clearly and loudly entails that applicant is a habitual litigant in fabricating evidences and infringing rights and injuring the rights of other people, without due consideration about the grave injury caused by willful intention with imaginary illusions, thereby causing grave hurt and character assassination and injecting mental agony in the hearts and soul of respondent and his family members. Thereby not only infringing rights of applicant but also willful interference in the administration of justice and disturbing the serenity of the stream of justice.

37. From above instances and admitted facts and arising facts after long and more than 5 years. That main applicant wife is a habitual offender and having two sisters who have filed 498a against upon their respective in-laws, and father being tried for murder case, is continuously over the years since marriage of one single day, has filed application after application using courts as weapon to dominate the family of in-laws and to grab the land and money of in-laws, to satisfy her needs and her individual principles, she has been attempting to interfere the administration of justice, it is imperative to punish such litigants, who are using heavy hands in the name of weaker section and destroying the very purpose of legislations provided to weaker sections of the society.

38. The applicant wife has filed an application , This new application that was meant to delay and prevent her substantiation of submissions, which stands rejected, In this application she demanded that she will not appear in the court of law until 40 Lakhs Bond was not filled, in matter of Restitution of conjugal rights u/s 9 Of Hindu Marriage Act.

39. There by denying early relief to respondents and interference in the interest of justice to innocent victims. Thereby interfering in the administration of justice.

40. In the Trial of 125 Cr.P.C, PW1 The complainant wife substantiated that my father is poor and she has two sisters and father cannot maintain her, In-laws are rich, And PW2, the father of complainant wife in his substantiating evidences, under oath stated that he is poor and he cannot fulfill the maintenance required to his daughter and his daughter also cannot maintain herself.

41. On the contrary, in the party witness 3, Sister of complainant wife, in the matter of __/06 u/s 9 of Hindu Marriage Act, under sworn affidavit, named Tilak, in her affidavit Tilak has maintained under oath that her father has ample amount of land of 50 to 60 Bighas of the agricultural land.

42. It is pertinent to note that, This is clear voice of fabrications and contrary statements which lead to the interference in the administration of justice and destroying the image of innocent victims respondents and his family members who are undergoing mental agony, character assassination, loss of reputation, being defamed in application after application by family of all three daughters who have filed 498a cases against their in-laws and father who has been also tried for murder case and also stands witness in cases.

43. Applicant being legally bound by oath in this Hon’ble Court to state truth in her affidavit but the applicant and her witness has with knowledge and willful intention have deposed false in their affidavit and substantiated evidences. Applicant has being knowingly and intentionally given false statements in judicial proceedings.

44. From above facts and instances, it is clear and loud, that this main application by wife is false, fabricate, contrary to statements maintained in the honorable court by the self-same applicant wife, That it is proven on material record, the statements made under oath are contrary and injurious to respondents in the instant complaint made by applicant wife.

45. Respondent states that the applicant wife is a guilty of the Act of perjury by making false statements, on oath solemnly affirming, willfully and knowingly that those Statements are false, in “AFFIDAVITs” on various dates submitted by her in this Hon’ble court with oblique motive to misguide and mislead this Hon’ble court with a view to extort money where as she is not entitled for any relief under the said Act.

46. The facts mentioned and maintained by applicant wife are contrary to applicant wife’s father in different litigations about same event on same date ; The applicants self same submissions are contrary to her own self substantiate facts

47. Respondent states that the material on record before this Hon’ble Court prima facie proves that the applicant has committed the act of perjury in her submission and the same has been described in detail.

48. It is most respectfully submitted that Orders by the Judiciary branch under proceedings have clearly and loudly mentioned that petitioner should come to the court in clean hands and Injunction Temporary as well as permanent Injunctions of petitioner was prohibited and rejected. As, her averment were not reliable based on documentary evidences presented by respondent, and It can be loudly and strongly observed that without strict proof petitioner applicants any averment is unsafe and unreliable, and are changing facts like air on earth.

49. It is most respectfully submitted that paragraphs and facts in instant application by applicant wife are self-submitted facts under oath by the main petitioner wife in more than two different courts having different legal stands as pointed out above, thereby playing fraud with the court and prejudice the Ld. Court to allow relief and harassing the real innocent victims, and thereby committing the act of perjury under oath and solemn affirmation, and with willful intention to injure, and to interfere administration of justice and harass the respondents. {B} The petitioner has comitted an act of perjury in her following submissions in view of her submission given above:

50. Respondent states that, the applicant has made the following willfully perjurious, intentionally deposed false and misleading statements on oath solemnly affirming, in her aforesaid “AFFIDAVITs” submitted by herself in this Hon’ble court with oblique motives and are verified and Prohibitory Orders also have recognized as false by the respective Ld. Court. Which clearly proves that the main applicant wife is deposing false on affidavit in reply in this Hon’ble Court on her whims and fancies thereby committing the act of perjury by giving false evidence during the judicial proceedings in this Hon’ble court? Hence applicant wife is punishable for the act of perjury, which adversely affects the administration of justice.

51. Respondent states that, Applicant filed the Affidavit filed by main applicant wife in applications submitted an Application under this instant Ld Court. are false, vexatious, concocted and misconceived to harass the Respondents and make him/them to run from pillar to post, Respondent states that applicant has not come with clean hands before this Hon’ble Court and suppressed material facts intentionally, creating new facts as delaying tactics and denying early justice, thereby interfering in the administration of justice. It is pertinent to note that applicant is only interested in making ambiguous and vexatious allegation against the respondent without any iota of evidence in support of her submissions and trying to mislead and misguide this Hon’ble court by making vague allegation against the respondent. Respondent states that petitioner has not come to the court in clean hands and this material fact have been intentionally suppressed and concealed or created on self-imaginations knowingly from this Hon’ble Court in the main application to mislead this Hon’ble Court, this is very clear and has been proved with substantial evidence by the respondent.

52. In order to appreciate the aforesaid aspect, I deem it necessary to reproduce the relevant provisions of the Cr.P.C.: 340. Procedure in cases mentioned in Section 195. (1) When upon an application made to it in this behalf or otherwise any court is of opinion that it is expedient in the interest of justice that an inquiry should be made into any offence referred to in Clause (b) of Sub-section (1) of Section 195, which appears to have been committed in or in relation to a proceeding in that court or, as the case may be, in respect of a document produced or given in evidence in a proceeding in that court, such court may, after such preliminary inquiry, if any, as it thinks necessary,- (a) Record a finding to that effect; (b) Make a complaint thereof in writing; (c) Send it to a Magistrate of the first class having jurisdiction; (d) Take sufficient security for the appearance for the accused before such Magistrate, or if the alleged offence is non-bailable and the court thinks it necessary so to do send the accused in custody to such Magistrate; and (e) Bind over any person to appear and give evidence before such Magistrate … 195. Prosecution for contempt of lawful authority of public servants, for offences against public justice and for offences relating to documents given in evidence. (1) No court shall take cognizance- … (b) (i) Of any offence punishable under any of the following sections of the Indian Penal Code (45 of 1860), namely, Sections 193 to 196 (both inclusive), 199, 200, 205 to 211 (both inclusive) and 228, when such offence is alleged to have been committed in, or in relation to, any proceeding in any court, or (ii) Of any offence described in Section 463, or punishable under Section 471, Section 475 or Section 476, of the said Code, when such offence is alleged to have been committed in respect of a document produced or given in evidence in a proceeding in any court, or (iii) Of any criminal conspiracy to commit, or attempt to commit, or the abetment of, any offence specified in sub-clause (i) or sub-clause (ii), except on the complaint in writing of that court, or of some other court to which that court is subordinate. 40.

In the conspectus of the aforesaid provisions, if the relevant provisions of the Indian Penal Code, 1860 (hereinafter referred to as the IPC) are perused, it does appear that the provisions of Sections 193, 199, 200 and 209 are attracted. The said provisions read as under: IPC Section 193. Punishment for false evidence Whoever intentionally gives false evidence in any stage of a judicial proceeding, or fabricates false evidence for the purpose of being used in any stage of a judicial proceeding, shall be punished with imprisonment of either descripttion for a term which may extend to seven years, and shall also be liable to fine; and whoever intentionally gives or fabricates false evidence in any other case, shall be punished with imprisonment of either descripttion for a term which may extend to three years, and shall also be liable to fine. Explanation 1-A trial before a Court-martial; [* * *] is a judicial proceeding. Explanation 2-An investigation directed by law preliminary to a proceeding before a Court of Justice, is a stage of a judicial proceeding, though that investigation may not take place before a Court of Justice.

IPC Section 199. False statement made in declaration which is by law receivable as evidence Whoever, in any declaration made or subscribed by him, which declaration any Court of Justice, or any public servant or other person, is bound or authorized by law to receive as evidence of any fact, makes any statement which is false, and which he either knows or believes to be false or does not believe to be true, touching any point material to the object for which the declaration is made or used, shall be punished in the same manner as if he gave false evidence. IPC Section 200. Using as true such declaration knowing it to be false Whoever corruptly uses or attempts to use as true any such declaration, knowing the same to be false in any material point, shall be punished in the same manner as if he gave false evidence. Explanation-A declaration which is inadmissible merely upon the ground of some informality, is a declaration within the meaning of Sections 199 to 200…. … IPC Section 209. Dishonestly making false claim in Court Whoever fraudulently or dishonestly, or with intent to injure or any person, makes in a Court of Justice any claim which he knows to be false, shall be punished with imprisonment of either descripttion for a term which may extend to two years, and shall also be liable to fine.

53. 14. Respondent states that thus material on record before this Hon’ble court and perusual of detail aforesaid descripttion in this application clearly proves that applicant has committed act of perjury by intentionally giving enormous false and fabricated evidence during judicial proceeding in this Hon’ble court by submitting false in her “AFFIDAVITs”. Thus filing false affidavit in the court of law, causes obstruction in the course of justice and also adversely affecting the administration of justice. Also applicant cannot be permitted to take liberty of spoiling purity of justice. In this facts and circumstances, the respondent has filed this present application in this Hon’ble Court in exercise of jurisdiction of this Hon’ble court u/s 340(1) of thr Cr.P.C, 1973. Against the main applicant wife and it is to expedient in the interest of justice to prosecute the applicant as prima facie evidences are adduced in that behalf. Hence applicant is punishable for the act of perjury, adversely affecting the administration of justice.

54. Respondent further states that all adverse allegations and incidents mentioned/deposed by the applicant in this Hon’ble court had never happened and the same are false, baseless, malicious, vexatious, concocted, futile and imaginary story made intentionally to harass respondent from court to court across Uttar Pradesh states and put respondents under pressure by misusing the provision of law conveniently and cunningly in attempt to extort money from the respondent. it goes to show that, the main applicant wife is only interested in making ambiguous and vexatious allegations against the respondent without any iota of evidence in support of her submissions and trying to misguide the Hon’ble court by making vague allegations against respondent and whatever allegations where sole testimony of main applicant. In fact there is no proper allegation against the respondent. Respondent states and submits that, the continuation of prosecution against the respondent is not only the abuse of process of law, but also defeats the ends of the justice. The Applicant ‘s application u/s 498a, 323, 504, 506, 34 of IPC and ¾ of The Dowry Prohibition Acts devoid of merits and deserves to be dismissed with exemplary costs and suitable punishment in the interest of justice.

55. I say that therefore, it is clear from the above Para that the petitioner is guilty of the act of perjury, as she has made the aforesaid false statements on oath with solemn affirmation providing false information to this Hon’ble court, willingly and knowingly that the same are false and the respondent has submitted the documentary evidences that those statements are false. In these circumstances, the respondent has filed this present application in this Hon’ble court in exercise of jurisdiction of this Hon’ble court u/s 340(1) of the cr.p.c, 1973. Against the petitioner and it is expedient in the interest of justice to prosecute the petitioner as Prima Facie evidences are adduced in that behalf.

56. Respondent adopt each and every statement, submission and averments made in this application, that all statements are from applicant wife’s applications and are brought forth to the notice of the instant Ld. Court.

57. Respondent craves leave of this Hon’ble court to add, to alter and amend this application. Respondent carves leave to add, alter and amend this application.

58. Respondent had not filed any other application for the act of perjury committed by the applicant in this Hon’ble court against the applicant in any other Hon’ble court.

59. Respondent has not filed any other application for the act of perjury against the petitioner, either in this Hon’ble court or any other Hon’ble court for the subject matter hereto. 60. It is therefore, most humbly prayed by the respondent that; a. By considering the aforesaid facts and circumstances, respondent most humbly pray that this Hon’ble court be pleased to kindly charge the petitioner and commit the matter to the concerned Metropolitan Magistrate court to prosecute the petitioner for the act of perjury in her application to implicate falsely to innocent victims. b. In the peculiar facts and circumstances of the case. Your Honor may Kindly dismiss the application filed by the applicant under 200 Cr.P.C be dismissed with exemplary costs to meet the ends of justice c. Costs of the proceedings may kindly be awarded to the Respondent from the applicant. d. Initiate the proceedings of perjury for infringement of rights and harassment, using the sections which are for destitute women, the same are misused and harassment of respondent and female party thereby playing pranks with the modesty of women of the women party. e. Kindly pass such other suitable orders as may deem fit and proper to meet the ends of justice in the peculiar facts and circumstances of the case. AND FOR THIS ACT OF KINDNESS AND JUSTICE, THE ABOVENAMED RESPONDENT AS IN DUTY BOUND SHALL EVER PRAY. Solemnly affirmed at _________. Dated; this ____day of December, 2010. Respondent V E R I F I C A T I O N I, Mr. ____________________. ________Years of age, presently residing at ______________________________. The respondent above named do hereby state and declare on solemn affirmation that whatever stated in the above Application is true and correct as per my knowledge and belief; that no part of it is false and nothing material has been concealed there from. Solemnly affirmed at ____________. Dated; this _____day of May, 2011. Respondent


Leave a reply

Your are not logged in . Please login to post replies

Click here to Login / Register