TABLE OF CONTENT

LIST OF ABBREVIATIONS..................................................................................................3

LIST OF AUTHORITIES.......................................................................................................4-5

 CONSTITUTUION.....................................................................................................4
 ACTS AND STATUTES.............................................................................................4
 BOOKS REFERRED...................................................................................................4
 WEBSITE REFERRED...............................................................................................4
 CASES CITED...........................................................................................................5

STATEMENT OF JURISDICTION..................................................................................... 6

STATEMENT OF FACTS.....................................................................................................7-9

STATEMENT OF ISSUE.......................................................................................................10

SUMMARY OF ARGUMENTS............................................................................................11

ARGUMENTS ADVANCED............................................................................................12-14

I. WHETHER THE PETITION FILED IS MAINTAINABLE? ........................................ 12

A. THAT THE PETITIONER HAS NO RIGHT TO APPROACH THE SC.........................12

B. THAT THERE IS NO SUBSTANTIAL QUESTION OF LAW IN THE MATTER...........13
C. THAT THE APRECIATION OF EVIDENCE IS PROPER........................................….......13
D. THAT GRAVE INJUSTICE HAS NOT BEEN DONE..........................................................14

II. WHETHER THE RESPONDENT IS LIABLE UNDER SECTION 498A IPC.........15-17

A. RESPONDENTS ARE NOT GUILTY OF OFFENCE U/S 498A ……................................15

B. CIRCUMSTANCES ARE NOT OF CONCLUSIVE NATURE............................................16
C. REASONABLE DOUBT EXISTS..........................................................................................17

PRAYER..................................................................................................................................18

1
 LIST OF ABBREVIATIONS

& And
AIR All India Reporter
Anr. Another
Art. Article
CA Criminal Appeal
Cr.LJ Criminal Law Journal
Cr. PC Code of Criminal Procedure
DV Domestic Violence
FIR First Information Report i
HC High Court
i.e. That is
IPC Indian Penal Code
IEA Indian Evidence Act
NCT National Capital Territory
Ors Others
PC Privy Council
PMR Post Mortem Report
SC Supreme Court
SCC Supreme Court Cases
SCR Supreme Court Record
SLP Special Leave Petition
UOI Union of India .
Y/O Year old

LIST OF AUTHORITY

2
CONSTITUTION

1. CONSTITUTION OF INDIA, 1950

ACTS AND STATUTES

2. THE DOWRY PROHIBITION ACT, 1961.

3. THE CODE OF CRIMINAL PROCEDURE, 1973
4. THE INDIAN EVIDENCE ACT, 1872
5. THE INDIAN PENAL CODE, 1860
6. HINDU MARRIAGE ACT, 1955
7. MEDICAL TERMINATION OF PREGNANCY ACT, 1971

BOOKS REFERED

1. P S A Pillai‟s Criminal law by Prof(Dr) K.N Chandrashekharan Pillai

2. Criminal law, KD Gaur
3. P.M Bakshi- The Constitution Of India 13th Edition
4. Indian Constitution Law 7th Edition- MP Jain
5. Women and rights in India
6. 2 V.N Shukla, Constitution of India, (11th Ed., Eastern Book Company

ARTICLES AND REPORTS

1. Right of women in termination of pregnancy.

2. False Cruelty Cases under section 498A ruining marriages: SC (TOI)
3. Section 498A, dowery: Most FIRs, Least convictions, The Indian Express
4. 243rd report of the Law Commission of India

WEBSITES AND OTHER SOURCES

1. Manupatra
2. Law Finder
3. Casemine
4. scconline

3
CASES CITED

1. Mohd. Hussain Umar Kochra v. K.S. Dalipstng1, (1969) 3S4

2. Mahendra saree emporium v G V srinivasamurthy 2005:
3. P H Muranjan Vs Mumbai MRDA 2009
4. Shivanand Gaurishankar Baswati v. Laxmi Vishnu Textile Mills, (2008) 13 SCC 323
5. R.J. Singh Ahuluwalia v. State of Delhi, AIR 1971 SC 1552
6. Mahendra saree emporium v G V srinivasamurthy 2005
7. Shobha Rani v. Medhukar Reddi, 1988 SCR(1) 1010
8. Noorjahan v. State [(2008) 11 SCC 55
9. Samar Ghosh v Jaya Ghosh
10. Dastane v Dastane 1975 AIR 1534, 1975 SCR (3) 96
11. R.P Bidlan vs State of Maharashtra

4
 STATEMENT OF JURISDICTION

The Petitioner has filed a Special Leave Petition before the Hon’ble Supreme Court of India
in the matter of Mr. Arjun & Ors. v. NCT of Delhi., under Article 136 of the Constitution of
India against the judgment and Order of the Hon’ble High Court of NCT Of Delhi.

136. Special leave to appeal by the Supreme Court

(1) Notwithstanding anything in this Chapter, the Supreme Court may, in its discretion, grant

special leave to appeal from any judgment, decree, determination, sentence or order in any

cause or matter passed or made by any court or tribunal in the territory of India

(2) Nothing in clause ( 1 ) shall apply to any judgment, determination, sentence or order

passed or made by any court or tribunal constituted by or under any law relating to the Armed

Forces

5
 STATEMENT OF FACTS

1. Priyanka and Arjun, who reside in NCT of Delhi, got married on 1st August 2018
under the HMA, 1955 after Priyanka’s father’s sudden illness. At the time of
marriage, Arjun, 26, was working as a bank manager at a private bank and 19-y/o
Priyanka was in her 2nd year, pursuing Psychology from DU. Even though Priyanka
was not mentally prepared, she gave in to her father’s wishes and consented to marry
Arjun in her very first meeting with him.
2. Before marriage, it was decided that Priyanka will continue her studies. However,
Soon after their marriage, Tanisha’s (Arjun’s sister) marriage was fixed and The
burden of executing the preparations for the marriage were put on Arjun and Priyanka
entirely due to which Priyanka was unable to attend her lectures for about 2 months.
Tanisha got married and moved to Hyderabad with her husband.
3. Priyanka was not able to manage the housework alone with her studies and
Subsequently, she was expelled from college for lack of attendance. She complained
to Arjun about being overburdened with the household work, which was contrary to
what was decided before marriage. Arjun suggested that settling in the marriage was
more important and that she could always resume/restart her course in the manner of
open learning. Priyanka was disheartened but she gave in and started thinking about
alternatives.
4. Despite all her efforts, Her in-laws were always critical of her work and started
ridiculing her. There were many instances of tussle b/w Priyanka and her In-Laws. In
another instance, when Tanisha came to visit her parents, Priyanka’s father-in-law
simply threw the tea that, saying that “Chai banani Tanisha se seekh!” (Learn to make
tea from Tanisha). Priyanka picked up the broken pieces and cleaned the tea stains.
Tanisha asked her father to apologise to Priyanka. Even though her father-in-law
apologized to her, her in-laws returned to their former ways of criticising her every
now and then.
5. Arjun tried helping Priyanka and talk to his parents to make things cordial but Things
would be okay for a couple of days but eventually would get back to where they were
This led to regular arguments between the couple who would sometimes sleep
separately.

6
6. Priyanka often talked about all this to her mother who suggested that a child would
solve problems in the house. Arjun agreed too.
7. On 15th Feburary, 2019 Priyanka announced her pregnancy. Everybody was very
happy, and treated her with love and care for some days. Arjun told her that he would
convert his study room to a baby room. However, this treatment subsided after a
couple of weeks. Being from an orthodox background her in-laws were expecting to
have a boy
8. Priyanka made all the arrangements and prepared dishes for
the guests of her mother-in-law in a party but she was again ridiculed by that the food
was tasteless and inedible. Priyanka in anger, started crying and threw the plates in
everyone’s presence. Shouting at her mother-in-law, went out of the house. She
returned to the house around 8:00 PM. Arjun lashed out at her for her behaviour and
there was a verbal spat. The mother-in-law then went and tightly held Priyanka by her
hair telling her to shut up. Arjun tried to mediate. Priyanka. pushed her mother-in-law
away who then fell on the ground.. Arjun helped his mother get up and threatened
Priyanka to back off.
9. To normalise things, Arjun tried to consoled and apologised to Priyanka. He asked her
to apologise to his mother, Priyanka refused. Priyanka was stubborn and refused to
apologise. Priyanka later apologized to which no heed was paid. On her friend’s
suggestion she went to a psychologist and was diogonosed with early stage of
depression and was given medication gor the same of which no one knew.
10. Arjun got tired of the everyday complaints and ignored her. He also came home drunk
once to the house. One day Arjun and Priyanka got into a heated abusive argument.
Arjun smashed the mirror with his hand which scared Priyanka. was also howling,
angrily broke her mangalsutra and threw it on the ground.
11. On 12th April 2019 she overheard her in-law’s conversation. She heard them saying
that Priyanka has always been a burden and they are dealing with her only for the
child. Hearing this, Priyanka became so upset that she decided to aborted the child on
14th April 2019 without informing the family. She then left the house leaving behind a
letter for Arjun, explaining everything to him and also informing him about the
abortion.
12. She then registered FIR was against the three of them under Section 498A, IPC,and
they were arrested. After being released on bail, Arjun filed a petition for divorce
under Section 13 of the HMA praying for a divorce on the ground of cruelty by

7
 Priyanka. He alleged that Priyanka used to disrespect him and his parents and would
always abuse them. He also alleged that Priyanka’s actions of breaking the
mangalsutra, getting the child aborted without his consent or even informing him, and
filing of the FIR amounted to cruelty.
13. In the criminal case filed by Priyanka, the Trial Court dismissed the allegations
holding that thethree accused were not guilty under Section 498A, of IPC. The appeal
filed before the High Court, challenging the Trial court’s judgment, was dismissed
and the order of the Trial Court was upheld. Subsequently, a Special Leave Petition
was filed before the Hon’ble Supreme Court challenging this judgment of the High
Court. In the divorce petition filed by Arjun, the Family Court decreed the divorce
petition in Arjun’s favour and the divorce was granted. Priyanka appealed against it
before the High Court where she prayed that the allegations of cruelty raised against
her were false and baseless, and such a decree should not be upheld because she was
the victim of all the harassment by the family. The decision of the High Court in this
case is pending.

8
 STATEMENT OF ISSUES

ISSUE No. 1: WHETHER THE PETITION FILED IS MAINTAINABLE?

ISSUE No. 2: WHETHER THE RESPONDENTS ARE LIABLE UNDER SECTION 498A
IPC?

9
 SUMMARY OF ARGUMENTS

ISSUE No. 1: WHETHER THE PETITION FILED IS MAINTAINABLE?

It is humbly submitted before this Hon’ble SC that the petitioner has no right or capacity to
approach the Hon’ble SC. The present petition for special leave to appeal, under Art. 1361
does not involve any merit or substantial question of law as the legal position of the issue
raised is crystallized by a number of cases of this Court and other Courts. The HC and the
Lower Court have considered the entire spectrum of evidence due diligence and there has
been no grave injustice. It is established in law that the SC will not interfere with the
concurrent finding of the courts below unless of course the findings are perverse or vitiated
by error of law or there is gross miscarriage of justice2. Moreover, Criminal appeals may not
be brought to the SC by the appellant when they are not covered by its jurisdiction as they are
not the right of the appellant but a mercy of the court. Allowing appeals such as the present
one, where there is no question of Law or departure from justice the court will only elevate
the burden on the justice system. Therefore in the present case, present petition filed by the
State & Ms. Priyanka is not maintainable.

ISSUE No. 2: WHETHER THE RESPONDENTS ARE LIABLE UNDER SECTION 498A
IPC?

It is submitted before this hon’ble SC that the alleged liability of the accused/respondent u/s
498A IPC does not arise as the prosecution has failed miserably to prove their case of cruelty
as explained the the section 498A, in the Lower court or the HC, beyond reasonable doubt.
Even after careful scrutiny of the evidences presented by the prosecution, It could not be
pointed out that it is a case of grave harassment or cruelty. Cruelty is a relative term 3 and law
says that harassment simplicitor does not amounts to mental cruelty and the petitioner in the
present case has tried to establish the trifles of matrimonial relationship as cruelty towards the
spouse. Thus, acquittal order given by the Lower Court as well as the HC is justifiable and
should be upheld by the Hon’ble SC as well.

1
Constitution of India
2
Mohd. Hussain Umar Kochra v. K.S. Dalipstng1, (1969) 3S4
3
Samar Ghosh v Jaya Ghosh

10
 ARGUMENTS ADVANCED

I. WHETHER THE PETITION FILED IS MAINTAINABLE?

That the petition filed before this hon’ble court under art. 136 of the Indian Constitution is
not maintainable on grounds that are established by the law and the guidelines that our justice
system follows. In the present matter the role of the apex court has come into question with as
to when can a criminal appeal be accepted and decided by the Hon’ble SC. And in what cases
does its jurisdiction expands to take up such appeals.

Criminal Appellate jurisdiction in SC can arise only through Article 134 or 136 of the
Constitution of India. A limited Criminal Appellate jurisdiction is conferred upon the SC by
Article 134. It is limited in the sense that the SC has been constituted as a Court of criminal
appeal in exceptional cases where the demand of justice requires interference by the highest
court of the land.4

However an appeal under art.134 requires a certificate as to the nature of conflict that needs
the decision and views of the highest court. The second options that remains with the
aggrieved party is to file a petition for special leave under art. 136 when the HC does not
grant the certificate of fitness for the case to be heard in the SC.

What forms the most significant aspect of the SLP under art.136 is that being an
extraordinary jurisdiction it is meant to be exercised by the consideration of justice with care
and caution5.

Especially a case like the present one where the prayer was concurrently refused by two
competent courts, the SC will be very slow and cautious before it can take different view6 .
SC can only do it if it finds that the judgement of the lower court is perverse (corrupt)where
as in the case. In the exercise of special leave appellate jurisdiction, the Supreme Court will

4
2 V.N Shukla, Constitution of India, (11th Ed., Eastern Book Company at Pg. 497)
5
Tirupati balaji developers. V State of Bihar 2004
6
P H Muranjan Vs Mumbai MRDA 2009

11
not interfere the concurrent findings of the courts below unless, of course, the findings are
perverse or vitiated by error of law, or there is gross miscarriage of justice.7

The SC observed in the Pritam Singh v. State8 in explaining how the discretion will be
exercised generally in granting SLP: The wide discretionary power with which this court is
invested under it is to be exercised sparingly9 and in exceptional cases only and as far as
possible a more or less uniform standard should be adopted in granting special leave in the
wide range of matters which can come up before it under article 13610. Circumspection and
circumscription must induce the Court to interfere with the decision under challenge only if
the extraordinary flaws or grave injustice or other recognised grounds are made out.11

Also the SC does not allow a point not raised before the courts below to be raised before
itself for the first time12 Every error, even of law, does not justify interference under article
13613 In the present case there is no error of law.

As far as the Substantial Question of Law is concerned the case does not seem to find any
relevant question of law or facts that could be answered by entertaining the present petition.
Presently, in the arena of section 498A of the IPC, plethora of landmark judgements have
been passed and amendments and reports are still being made and published to guide the
courts at every level14.

It is regarded that the findings of the HC have to be judged by the yardstick of reason to
ascertain whether such findings were erroneous, perverse and resulted in miscarriage of
justice, if the conclusion of the court below can be supported by acceptable evidence, the SC
will not exercise the discretion to interfere with the decision and if the two views are
possible, the view in the favour of the accused has been accepted. In such a situation the
petition does not pose any benefit to the issue of creating anything except delayed decision
and additional burden for the justice system.

8
AIR 1950 SC 169
9
Mahendra saree emporium v G V srinivasamurthy 2005

10
idib
11
Shivanand Gaurishankar Baswati v. Laxmi Vishnu Textile Mills, (2008) 13 SCC 323
12
R.J. Singh Ahuluwalia v. State of Delhi, AIR 1971 SC 1552
13
idib
14
243rd report of the Law Commission of India

12
SLP does not concern itself with the weight of evidence, or the conflict of evidence or with
inferences drawn from evidence or with questions as to corroboration or contradictions of
testimony or as to whether there was sufficient evidence to satisfy the burden of proof.15 The
court does not allow facts to be reopened or act as a court to review evidence.16

As a normal rule, the Supreme Court does not proceed to review the evidence in criminal
appeals under Article 136, unless there is some serious legal defect or a grave irregularity by
the court below has been done in reading the evidence, and Such illegality or irregularity has
resulted in miscarriage ot justice.

The HC gave its decisions based on evidences; the principles of natural justice
were followed. there is no issue as to the interpretation of law. The order was passed keeping
in mind the evidences. It is a well settled practice of the SC that except where there has been
an illegality or an irregularity of procedure resulting in the absence of a fair trial or gross
miscarriage of justice, the SC does not permit a third review of evidence with regard to
questions of facts in cases in which two courts of fact have appreciated and assessed the
evidence with regard to such question.17

In the present case does not show any injustice being done as the hon’ble Lower Court and
HC have applied the principles of natural justice and the judicial minds in understanding the
case and its facts and evidences. Its has with due delegence and care, has examined the facts
and circumstances and passed the order in favour of the accused/respondents.

The prosecution/petitioner could not prove their allegations against the respondents under
section 498A if the IPC in the Lower or the HC.

Thus in the light of all the cases cited, we can conclude that the court must not allow this
petition for special leave to appeal as in these cases what the court has to see is “ interest of
justice “ and the interest of justice demands that the court should protect the respondent who
has been proven not guilty by previous decisions already. Therefore the present case does not
have the locus standi or the jurisdiction to be heard at the apex court.

15
M.P. Jain, Indian Constitutional Law (7th Ed. Lexis Nexis, 2016 at Pg. 174)
16
Mohinder Singh v. State of Punjab, AIR 1965 SC 79
17
Chikkarange Gowda v. State of Mysore, AIR 1956 SC 731

13
II: WHETHER THE RESPONDENTS ARE LIABLE UNDER SECTION 498A IPC?

It is submitted before the hon’ble SC that with the decision of the Lower Court and the HC
that the respondents are not guilty u/s 498A of the IPC their alleged liability did not exist
from the very beginning.

The allegations pointed by the petitioner in the present case do not meet the essential
ingredients to be liable under section 498A of the IPC providing remedy against cruelty by
the husband or his reletives.

For the purpose of this case the section reads

“Whoever, being the husband or the relative of the husband of a woman, subjects such
woman to cruelty shall be punished with imprisonment for a term which may extend to three
years and shall also be liable to fine.

Explanation 1: any willful conduct which is of such a nature as is likely to drive the woman
to cause grave injury or danger to life, limb or health (whether mental or physical) of the
woman’’.
The petitioner emphasized on the mental cruelty being inflicted on her as she lived with the
respondents. However, the petitioner failed to furnish any evidence or substantial fact that
coukd show that she was under immense mental pressure.

The principle of mental cruelty has been defined and given by the courts every now and then
as guidelines for future. The hon’ble court in the landmark case of Dastane v Dastane18

That trivial arguments of matrimonial life do not constitute cruelty.

The court in a judgement has pronounced that cruelty is a relative term and can not form the
same level in every case. The nature and the environment around the spouse, mainly the wife
effect her nature and Short tempere , poor financial condition.

The Supreme Court remarked that under Section 498A of IPC a new dimension has been
given to the concept of cruelty. Explanation to Section 498 A of IPC provides that any willful

18
1975 AIR 1534, 1975 SCR (3) 96

14
conduct which is of such a nature as is likely to drive a woman to commit suicide or likely to
cause grave injury or danger to life, limb or health (whether mental or physical of the
woman), and harassment of the woman with a view to coercing her or any person related to
her to meet any unlawful demand for any property or valuable security would constitute
cruelty In this case it was held that evidence as to harassment to the wife to meet any
unlawful demand for money is necessary to constitute cruelty in criminal law. This is the
requirement of the offence of cruelty defined under Section 498 A of IPC.19

The Supreme Court in this case attempted to explain the expression “cruelty” in the following
words:

“Consequences of cruelty which are likely to drive a woman to commit suicide or to cause
grave injury or danger to life, limb or health, whether mental or physical, of the woman is
required to be established in order to bring home the application of Section 498 A of IPC.”

The Court also elaborates on the legislative intent behind insertion of Section 498 A of IPC
i.e. As clearly stated therein the increase in the number of dowry deaths is a matter of serious
concern. The extent of the evil has been commented upon by the Joint Committee of the
Houses to examine the work of the Dowry Prohibition Act, 1961. In some cases, cruelty of
the husband and the relatives of the husband which culminate in suicide by or murder of the
helpless woman concerned, constitute only a small fraction involving such cruelty. Therefore,
it was proposed to amend IPC, Code of Criminal Procedure, 1973 and the Evidence Act
suitably to deal effectively not only with cases of dowry deaths but also cases of cruelty to
married women by the husband, in-laws and relatives. The avowed object is to combat the
menace of dowry death and cruelty.20

In this recent case, Mrs. Christine Lazarus Menezes v. Mr. Lazarus Peter Menezes (Bombay
High Court), the Appellant wife appealed against Family Court’s order whereby the Family
Court had granted Respondent’s prayer for dissolution of marriage.

The Bombay High Court dismissed the appeal and refused to interfere with the Family
Court’s order in allowing the Petition for divorce of the husband on the ground of ‘cruelty’.

19
Shobha Rani v. Medhukar Reddi, 1988 SCR(1) 1010
20
Noorjahan v. State [(2008) 11 SCC 55

15
The Court noted in the case that during examination, the wife had admitted in her affidavit
that she had lodged an FIR with the Kherwadi Police Station, Mumbai, against her husband
under sections 498-A and 406 of the Indian Penal Code, 1860. The Appellant wife had also
admitted in the case that she had filed the Criminal Complaint in order to bring back her
husband to their matrimonial home.21

In this recent case of Rajesh Sharma & Ors. v. State of U.P. the Supreme Court issued a
slew of directions to prevent misuse of Section 498A. The core issue that arose in the appeal
related to the need to check the alleged tendency of woman filing complaint under Section
498A to rope in all family members in settlement of matrimonial dispute.

In view of this concern, the Supreme Court appointed the Additional Solicitor General, Shri
A.S. Nadkarni and Senior Advocate Sri V.V. Giri as amicus to assist the Court in the matter.

Recommendations by the Amicus in the case

a) That the allegations against all relatives of the husband cannot be taken at face value when
in normal course it may only be the husband or at best his parents who may be accused of
demanding dowry or causing cruelty and in order to check abuse of over implication, clear
supporting material needs to be producedto proceed against other relatives of a husband.

b) That there has been a growing tendency to abuse the said provision to rope in all the
relatives including parents of advanced age, minor children, siblings, grand-parents and
uncles on the strength of vague and exaggerated allegations without there being any
verifiable evidence of physical or mental harm or injury which several times results in
harassment and even arrest of innocent family members, including women and senior
citizens.

The Court also observed that Section 498A was inserted in the statute with the object to
punish cruelty at the hands of husband or his relatives against a wife particularly when such
cruelty had potential to result in suicide or murder of a woman and it is a matter of serious
concern. The Court also recognized some areas for remedial steps. For instance uncalled for
implication of husband and his relatives and arrest, continuation of proceedings in spite of
settlement between the parties and facilitation of closure of proceedings where a genuine

21
Criminal Appeal 917 of 2011

16
settlement has been reached. In order to curb misuse of Law, the Court also suggested active
participation of civil society organizations in such matters

The present case gives the essence of a false case filed by the petitioner keeping in mind that
she has presented the trivial matters of her matrimonial life as mental torture the husband or
his relatives did not do any act of violence upon the petitioner.

Infact, in a divorce suit filed by the respondent u/s 13(1)(ia) in the family court which was
decreed22 in favour of the respondents show that they were subject to cruelty by the
petitioner. Her behaviour towards her in-laws, disrespecting them, aborting the child 23

Suffering of ignominy. Unfortunately, a large number Or these complaints have not only
Flooded the Courts but also have led to enormous social unrest artecung peace, harmony and
happiness of the society. It is high time that the legislature must take into consideration the
pragmatic realities and make suitable changes in the existing law. It is imperative for the
legislature to take into consideration the into formed public opinion and the pragmatic
realities in consideration and make necessary changes in the relevant provisions of law.
Pursuant to the direction of the Supreme Court, Law Commission of Even ultimate acquittal
in the trial may also not be able to wipe out the deep scars of For explanation (a) of 498A ,
there has to be a nexus between cruelty and suicide ,mere proof of cruelty or suicide is not
enough.24 The petitioner has failed miserably to establish the liabillty of the respondents.

Thus, the petition need not to be allowed.

22
Para. 15 of the moot prep.
23
Section 312, IPC, 1860
24
R.P Bidlan vs State of Maharashtra

17
 PRAYER

Wherefore, in the lights of facts stated, issues raised, authorities cited and arguments
advanced, it is most humbly prayed and implored before the Honourable Court, that it may
be graciously pleased to adjudge and -
1. Uphold the judgement of the High Court as Just and Valid.

2. Dismiss the present SLP filed by the Appellant.

And Pass any other Order, Direction, or Relief that it may deem fit in the Best
Interests of Justice, Fairness, Equity & Good Conscience.
For This Act of Kindness, the Appellant Shall Duty Bound Forever Pray.

18
Date: …………………… Sd/-

Place ………………… (Counsel for Respondent)

19