TABLE OF CONTENTS

Table of Contents.............................................................................................2

List of Abbreviation........................................................................................3

Index of Authorities.........................................................................................4

Statement of Jurisdiction................................................................................6

Statement of Facts............................................................................................7

Statement of Issues..........................................................................................8

Summary of Arguments..................................................................................9

Arguments Advanced

I. Whether this Special Leave Petition is maintainable before the Hon'ble

Supreme Court of India? ......................................................................... 10

II. Whether the respondent is punishable for rape

not? .......................................................................................... 14

III. Whether the respondent is punishable for cheating or not? 19

Prayer.............................................................................................................. 21

MEMORIAL ON THE BEHALF OF PETITIONER

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2
 LIST OF ABBREVIATION

AIR ALL INDIA REPORTER

CRI CRIMINAL

CRILJ CRIMINAL LAW JOURNAL

ORS. OTHERS

ORI. ORISSA

R.I. RIGOROUS IMPRISIONMENT

SC SUPREME COURT

SCC SUPREME COURT CASES

SLP SPECIAL LEAVE PETITION

V. VERSES

COI CONSTITUTION OF INDIA

IPC INDIAN PENAL CODE

MEMORIAL ON THE BEHALF OF PETITIONER

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"IP

INDEX OF AUTHORITIES

_CASES:-

1. Aruncrhoicrn vs P. S. R Socha-mg-Ian 1979 AIR 1284

2. Delhi Judicial SErvice A sscriation vs. Si-deaf G ujorot 1991 AIR 2176, 1991 SCR (3) 93 3,
Ghanshyam Mishratts. State AIR 1951 OR! 78, 1957 CRIU 469
4. Hari path vs. State of West engal 1956 AIR 757, 1956 SCR 639
5. Indira Kaur And Ors. vs Shea Lal Kapoor (1988) 2 5CC 488, 499:AIR 1988 SC 1074
6. Mohd. Hussain Umar Kochra Etc vs K. S. Dalipsinghji & Anr AIR 1970 SC 45, 1969
SCC (3) 429
7 M.V. "Vali Pero" V. Fernanedo Lopez (1989) 4 SCC 671, 675:AIR 1989 SC 2206
8. Pandirang Whale vs. Stateaf Mohcrashra 11FEB, 2004
9. P.13hanurrothy vs. Premladia,(1978) 2 Andh LT 358 (367)
Rents Yocibvvs, Mactrusudag E toNcdi 2002 (4) MPHT 437
11. Saieho Khatoan vs. Stete cf Bi ha- 1989 CRIU 202
12 tiljayon Filial vs. State(f Kada SEPTEMBER 27Th 2010

BOOKS

1. Commentary on IPC by Ratanlal & Dheerajlal /.

Constitution of India by V.N. Shukla
3. Constitution of India by P.M. Bakshi
4. Indian Evidence Act by Ratanlal & Dheerajlal.
5. Text book on IPC by K.D. Gaur

MEMORIAL ON THE BEHALF OF PETITIONER

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 Links

1. manupatra.corn
2. highcourt.nic.in
3. supremecourtofindia.nic.in
4. indiatoday.in
5. timesofmdia.indiatimes.com
6. indiankanoon.org
7. advocatekhoj.com
8. indpaedia.com

MEMORIAL ON THE BEHALF OF PETITIONER

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 STATEMENT OF JURISDICTION

The Hon'ble Supreme Court of India has the jurisdiction in this matter under Article 136 of the
Constitution of India as follows:

136. Special leave to appeal by the Supreme Court —

(I) 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 (I ) 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.

The Supreme Court has a jurisdiction to entertain and hear appeals by granting special leave
against any kind of judgment or order made by any Court or Tribunal in any proceedings and the
exercise of this power is left entirely to the discretion of the Supreme Court.

MEMORIAL ON THE BEHALF OF PETITIONER

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 STATEMENT OF FACTS

I . The appellant, Manesh and the respondent Smita worked at Virodhi Stationery Shop,
Mumbai. The respondent left the job. Then the appellant also quit. They started working
at Balaji DTP Xerox Centre.

2. The appellant on one fine day proposed the respondent and she accepted his proposal.

3. On 5.11.09 the appellant informed Smita that it was his birthday. Smita went to meet him
at the bus stop.

4. Then they both went to Gorai Beach. They checked into a guest house in Gorai village to
cut the cake on the occasion of his birthday.

5. The appellant allegedly informed Smita that he wanted to marry her and on that ground
he had solicited sexual favors from Smita.

6. When she refused to oblige, he forced her and had forcible sexual intercourse with her.
They did not meet for 2-3 days.

7. The appellant went to Manglore for I month. She called him on his cell phone and learnt
from the appellant's brother that he is married and has a son. However, the wife and son did
not reside with him.

8. The appellant met Smita accompanied by her mother at Boriwali and confirmed that he
was married and has a son and sought pardon from her.

9. On 8.3.2010 Smita realized that she is pregnant and informed the same to the appellant.
He promised her that he would obtain divorce after 3 months and then he would marry her.

10. Smita realized that he was ignoring her and lodged an FIR. against him under 376, 420
of IPC.

11. High Court has acquitted the appellant under section 376 of1PC and convicted him under
417 and the respondent has filed the special leave petition under article 136 of COI.

MEMORIAL ON THE BEHALF OF PETITIONER 7

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 STATEMENT OF ISSUES

ISSUE I

WHETHER THIS SPECIAL LEAVE PETITION IS

MAINTAINABLE BEFORE THIS HON'BLE

SUPREME COURT OF INDIA OR NOT?

ISSUE II

WHETHER THE RESPONDENT IS PUNISHABLE

FOR RAPE OR NOT?

ISSUE III

WHETHER THE RESPONDENT IS PUNISHABLE

FOR CHEATING OR NOT?

MEMORIAL ON THE BEHALF OF PETITIONER

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 SUMMARY OF ARGUMENTS

WHETHER THIS SPECIAL LEAVE PETITION IS MAINTAINABLE BEFORE THIS

HON'BLE SUPREME COURT OF INDIA OR NOT?

It is most humbly submitted before this Hon'ble Supreme Court of India that this special leave
petition is maintainable in this Court under Article 136 of the Constitution of India against or in-

a) any judgment, decree, determination, sentence or order,

b) in any case of matter,
c) passed or made by any Court or tribunal in the territory of India.
d) in special and exceptional circumstances
e) where there is grave injustice.

WHETHER THE RESPONDENT IS PUNISHABLE FOR RAPE OR NOT?

It is most humbly submitted before this Hon'ble Supreme Court of India that respondent had
forcible sexual intercourse with the petitioner. Slightest penetration is sufficient to constitute the
offence of rape. The respondent is also liable for sexual harassment as inclusive of-

i) physical contact and advances involving unwelcome and explicit sexual overtures; or
ii) a demand or request for sexual favors.

EATING OR NOT?
WHETHER THE RESPONDENT IS PUNISHABLE FOR CH
urt of India that the respondent is
It is most humbly submitted before this Hon'ble Supreme Co
ishonest concealment is a deception
punishable for punishment of cheating under Section 417.A d within
the meaning of this Section.

PETITIONER
MEMORIAL ON THE BEHALF OF

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 ARGUMENTS ADVANCED

ISSUE I

WHETHER THIS SPECIAL LEAVE PETITION IS MAINTAINABLE BEFORE THIS

HON'BLE SUPREME COURT OF INDIA OR NOT?

It is most humbly submitted before this Hon'ble Supreme Court of India that this special leave
petition is maintainable in this Court. Article 136 of the Constitution of India reads as follow:-

136. Special leave to appeal by the Supreme Court —

(I) 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 (I) 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.

The power of the Court to hear appeals in this article is much wider and general. It vests in the SC'
plenary jurisdiction in the matter of entertaining and hearing appeals by granting special leave
against:-

(i) any judgment, decree, determination or order,

(ii) in any cause or matter,
( ill) Passed or made by any court or tribunal.

The Petitioner in the present case has filed the SLP under article 136 as the High Court has
acquitted the accused (respondent) for the offense of rape and hence is maintainable.

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In Deihl Jucicici Service Assodation Stcte cf Gujarat it was contended by the Supreme
Court that:-

"Under Article 136 there is no room for any doubt that this Court has wide power to interfere and
correct the Judgment and orders passed by any court or Tribunal in the country. In addition to the
appellate power, the Court has special residuary power to entertain appeal against any order of any
court in the country. The plenary jurisdiction of this Court to grant leave and hear appeals against
ally order of a court or Tribunal, confers power ofj udicial superintendence over all the courts and
Tribunals in the territory of India including subordinate courts of Magistrate and District Judge. This
Court has, therefore, supervisory jurisdiction over all courts in India."

In an another case of Arunachalam vs P. S. R. Sadhanantham2, it was again contended by the SC

that:-

"Article 136 of the Constitution of India invests the Supreme Court with a plentitude ofp lenary,
appellate power over all courts and Tribunals in India. The power is plenary in the sense that there
are no words in Article 136 itself qualifi,ing that power. But. the very nature of the power has led the
court to set limits to itself tvithin which to exercise such power. It is now the well-
established practice of this Court to permit the invocation of the power under article 136 only in very
exceptional circumstances, as when a question of law of general public importance arises or a
decision shocks the conscience of the Court. But, within the restrictions imposed by itself this Court
has the undoubted power to interfere even with findings off act, making no distinction between
judgments of acquittal and conviction, if the High Court, in arriving at those ,findings. has acted
"perversely or otherwise improperly"."

Here there has been forcible sexual intercourse with the petitioner and then also the respondent has
been acquitted from the offence of rape committed by him. This reckless behavior of High Court
clearly proves that the decision was given perversely or improperly. And therefore this petition is
maintainable before the Supreme Court of India.

Decided cases, however, establish that the Supreme Court will grant special leave appeal in
exceptional cases which are:-

1991 AIR 2176, 1991 SCR (3) 936 1979

NR 1284

MEMORIAL ON THE BEHALF OF PETITIONER

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 • Where grave and substantial injustice has been done by disregard to the forms of legal
process, or

• Violation of the principles of natural justice or otherwise.

Thus, it is crystal clear from the above mentioned facts that the SC will not grant special leave to appeal
tea 136 of the COI unless it is shown that special and exceptional circumstances exist, that
substantial and grave injustice has been done and the case in question presents features of
sufficient gravity to warrant a review of the decision appealed against.

Further, in the exercise of its special leave appellate jurisdiction, the Supreme Co urt will not
interfere with the concurrent findings of the Courts below, unless, of course, the findings are
perverse or vitiated by error of law, or if there is gross miscarriage of justice.

The same contention is held in the case of Mohd. Hussain Uniar Kochra Etc N's K. S.
Dalipsinghji & Anrj which is:-

"This Court does not reappraise the evidence unless the findings are perverse or are vitiated by

any error of law or there is a grave miscarriage ofj ustice ".

In this case there has been a miscarriage of justice as the accused was acquitted by the High
Court despite of the commission of rape. This petition cannot be dismissed and hence is
maintainable in this Hon'ble court.

The Supreme Court is duty bound to interfere with the findings of fact even if they have been
affirmed thrice.

In case of Indira Kaur And Ors. vs Shen Ltd }Capone', it was held as following:-

If and when the Court is satisfied that great injustice has been done it is not only the 'right' but

also the 'duty' of this Court to reverse the error and the injustice and to upset the finding

notwithstanding the fact that it has been affirmed thrice."

'AIR 1970 SC 45 , 1969 5CC (3) 429

4(1988) 2 5CC 488, 499:AIR 1988 SC 1074

MEMORIAL ON THE BEHALF OF PETITIONER

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In this case also this Hon'ble Court has not only but it is also the duty of the SC to reverse the error

and injustice and pass an appropriate, just and equitable order.

In exceptional cases the Court admits appeals under Article 136 even though the appellant has

not exhausted all the other remedies. if there are exceptionally sound reasons for such admission.

In case M.V. "Vail Pero" V. Fernanedo Lopez5 it was held that:-

"This academic exercise is unnecessary in the present case since it cannot be doubted that
irrespective of the question of res judicata. earlier decision on the same point by a Division
Bench of the High Court will at least be a binding precedent when the matter is reagitated before the
Division Bench hearing the appeal against the.final decision in the suit. In such a situation directing
the resort to the remedy of an appeal under the Letters Patent against the final decision in the suit will
needlessly delay decision of the point by this Court. We are, therefore, of the
opinion that, in the present case, it is neither necessary to decide the question of res judicata argued
before us nor would it be appropriate to refuse leave and direct the petitioner to.first exhaust the
remedy of an appeal under the Letters Patent in the High Court. We, accordingly, proceed to decide the
point involved on merits. Leave granted."

In Haripach v& Stateof West 5' ens al6 Supreme Court held that:-

"No High Court has the jurisdiction to pass on mere questions of fact for firther consideration by this
Court under the relevant articles of the Constitution. We no doubt possess that power and in proper
cases have exercised it under article 136(1). If there has been a gross miscarriage of justice or a
departure from legal procedure such as vitiates the whole trial we would certainly
intervene and we would also intervene if even the +findings of fact were such as were shocking to our
judicial conscience and grant in such cases special leave to appeal under article 136(1)".

In the present case there has been injustice with the petitioner and the petitioner being the
aggrieved party seeks justice. Therefore she has approached the Hon'ble Supreme Court of India.
Since the case is very sensitive, the petitioner has approached the Supreme Court in order to
obtain justice.

5 (1989) 4 5CC 671, 675:AIR 1989 SC 2206

6 1956 AIR 757, 1956 SCR 639

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 ISSUE II

WHETHER THE RESPONDENT IS PUNISHABLE FOR RAPE OR NOT?

It is most humbly submitted before this Hon'ble Supreme Court of India that respondent
(Manesh) is punishable for rape as he had forcible sexual intercourse with the petitioner (Smita).

The accused allegedly informed the petitioner that he wanted to marty her and on that ground he
had solicited sexual favors from Smita. Initially when she refused to oblige, he forced her and had
sexual intercourse with her. Under Penal law Rape has been defined under "section 375" which
reads as follow:-

"A man is said to commit "rape" who, except in the case hereinafter excepted, has sexual
intercourse with a woman under circumstances falling under any of the six following
descriptions:-

First: Against her will.

Secondly: Without her consent.

Thirdly: With her consent, i'ben her consent has been obtained by putting her or any person in whom

she is interested in fear of death or of hurt.

Fourthly: With her consent, when the man knows that he is not her husband, and that her

consent is given because she believes that he is another man to whom she is or believes herself to be

lawfully married.

Fifthly: With her consent, when, at the time of giving such consent, by reason of unsoundness of

mind or intoxication or the administration by him personally or through another of any

stupefring or unwholesome substance, she is unable to understand the nature and consequences of

that to which she gives consent.

Sixthly.. With or without her consent, when sixteen years of age.

MEMORIAL ON THE BEHALF OF PETITIONER 14

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Explanation: Penetration is sufficient to constitute the sexual intercourse necessary to the

offence of rape,

Exception: Sexual intercourse by a man with his own wife, the wife not being under fifteen years of

age, is not rape."

In GharishycinMishro vs. Std-J, it was held that: -

"Even partial penetration leading to the rupture of the hymen is sufficient to constitute rape,
even though there might not be deep penetration into the vaginal canal. The girl's evidence was
to the effect that she felt severe pain and raised a cry, after which the petitioner desistedfrom the
act. Consequently, from the mere fact that there was no dilation of the vaginal canal it cannot be
assumed that the offence was not committed when the injury to the hymen showed clearly that
hi
there was penetration , the male organ. The depth of the penetration is immaterial so far as the
offence under Section 3761.. P. C. is concerned."

It is that if consent be obtained by intimidation, force, mediated imposition, circumvention, and

surprise it is so to be treated as a delusion, and not as a deliberate or free act of mind.

It is to be noted by the Hon'ble Supreme Court of India that in the present case, the accused
wanted to cut the cake on the occasion of his birthday and checked into a guest house which was a
surprise for Smita. She was unaware of this fact. After this, the respondent solicited sexual favors
from the petitioner on the ground that he wanted to marry her.

Therefore, it is pertinent to note that there was an element surprise in the mind of the petitioner and
so her consent was delusional and it cannot be considered as a free consent.

AIR 1951 OR 178, 1957 CRI U 469

MEMORIAL ON THE BEHALF OF PETITIONER

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In Supra /Odom vs. State cf-Bihar, it was held that-

"Consent always means. free will or voluntan' act. In this case consent was obtained on the basis of
some ,raud and allurment or practising deception upon the lady on the pretext that ultimately she
will be married and under that pretext she allowed opposite party No. 2 to have sexual
intercourse with her. Therefore, this tainted consent or consent of nature which is based on
deception and fraud, cannot be termed, prima facie, to conclude that it was 'with consent'. If was
a fraud that was practiced on her or she was deceived by giving false assurance. Such type of
consent must be termed to be consent obtained without her consent. Consent obtained by
deceitful means is no consent and comes within the ambit of ingredients of the definition of
rape.''

Here also the consent was obtained on the promise of marriage and on the same promise she had
allowed other party to have sexual intercourse with her. It must be noted that it was fraud that was
practiced on her and also she was deceived by giving false assurance of marriage.

In Renu Yocbvs, Moctiusudm E tawcrii9, it was contended that:-

"In the instant case the applicant gave her consent under a misconception and the non-applicant
No. I to whom it was given was aware of the existence of the misconception. As the non-
applicant No. I misrepresented the fact about his marital status and obtained the consent of the
applicant under a misconception off act, it amounted to no consent as per provisions of Section 90,
IPC. In the present case also, the accused had sexual intercourse under a misconception that
he would many her. The consent given under misconception is no consent. The applicant
succumbed to the lust of the non-applicant No. I on a misrepresentation that he was a bachelor
and that he would marry her. "

In instant case also, the respondent misrepresented the fact about his marital status and obtained the
consent of the petitioner under a misconception of fact. It amounts to no consent according to section
90 of IPC. It was a consent given under the misconception of fact and hence the respondent
must be punished under section 376 of IPC.

1989 CRIU 202

2002 (4) MFHT 437

MEMORIAL ON THE BEHALF OF PETITIONER 16

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In Vijaycn Pillai vs State of Keralal° it was held that:-

"Even. consent to act involves submission but it by no means follows that a mere submission involves
consent."

Here in this case, no doubt that the petitioner had accompanied with the respondent and checked into
a guest house but it doesn't mean that she consented him for having sexual intercourse with her. No
doubt she submitted herself but every submission is not consent. Hence, the respondent is punishable
for rape under section 376 of IPC, 1860.

It must also be noted by this Learned Court that the respondent had also harassed the petitioner.

As per Section 354A.A man committing any of the following acts-

!) physical antlx-tcridwivcnces invclang unKetcome and Explicit sexual overtures; cr ii) a

demand or requestf or sexual fotors,- or

iii) showing pornography against the will of a woman; or iv)

making sexually coloured remarks;

Shall be guilty of the offence of sexual harassment.

In the present case the respondent told the petitioner that he wanted to marry her and on that
ground he had solicited sexual favors from Smita. Initially when she refused to oblige, he forced her
and had forcible sexual intercourse with her.

In Pandurang Mohote vs. State of Maharashra11, S.C. held that:-

"The essence of a woman's modesty is her sex. The culpable intention of the accused is the crux of the
matter. The reaction of the woman is ►ery relevant, but its absence is not always decisive.

1c' SEPTEMBER 27T" 2010

1111FEB, 2004

MEMORIAL ON THE BEHALF OF PETITIONER

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Modesty in this Section is an attribute associated with female human beings as a class. It is a virtue
which attaches to a female owing to her sex. The act of pulling a women, removing her saree, coupled
with a request for sexual intercourse, is such as would be an outrage to the modesty of a woman;
and knowledge, that modesty is likely to be outraged, is sufficient to constitute the offence without
any deliberate intention having such outrage alone for its object. The word 'modesty' is not defined
in IPC But the act of pulling a woman. removing her saree, coupled with a request jr sexual
intercourse, is such as would outrage to the modesty of a woman; the knowledge. that the modesty
is likely to be outraged is sufficient to constitute the offence without any deliberate intention having
such outrage alone far its object."

The respondent in present case solicited sexual favors from her and had sexual intercourse with
her- In spite of her resistance he forced her and harassed her. This act of respondent also
outraged her modesty which is the most valuable part of any female. The accused must not be
acquitted and his act must be punished by this Hon'ble Supreme Court as all the acts by the
accused are fulfilling the criteria of the definition of Rape mentioned in section 376 of IPC.

MEMORIAL ON THE BEHALF OF PETITIONER

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 ISSUE III

WHETHER THE RESPONDENT IS PUNISHABLE FOR CHEATING OR NOT?

It is most humbly submitted before this Hon'ble Supreme Court of India that respondent is liable for
punishment for cheating under Section 417.

Cheating is defined in section 415 of IPC which reads as follow:-

415. Cheating— Whoever, by deceiving any person, fraudulently or dishonestly induces the person
so deceived to deliver any property to any person, or to consent that any person shall retain any
properly, or intentionally induces the person so deceived to do or omit to do anything
which he would not do or omit if he were not so deceived, and which act or omission causes or is likely
to cause damage or harm to that person in body, mind, reputation or property, is said to "cheat".

Explanation.—A dishonest concealment off actsis a deception within the meaning of this section. The

essentials ingredients of cheating are:-

(1) Deception of any person

(2) (a) Fraudulently or dishonestly inducing that person-
(i) To deliver any property to any person, or
(ii) To consent with any person any person relating to any property; or
(b) Intentionally inducing that person to do which he would not do or omit to do, and that
the act or omission causes or is likely to cause damage or harm. to that person in body,
mind, reputation or property.

In P. Bhanumatry VS. Prerniathd2,(1978) 2 Andh LT 358 (367) it was held that:-

"dishonest concealment is a deception".

12(1978) 2 Andh LT 358 (367)

MEMORIAL ON THE BEHALF OF PETITIONER 19

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In the present case, the respondent allegedly informed the petitioner that he wanted to marry her
and on that ground he had solicited sexual favors from Smita. Initially when she refused to
oblige, he forced her and had forcible sexual intercourse with her. Thereafter they did not see each
other for 2-3 days. The respondent had been to Manglore for one month.

When the petitioner tried to contact him on his cell phone, his brother received the phone and she
came to know from him that the respondent was a married man and having a son. However, the
wife and son of the respondent were not residing with him.

All the above facts point out clearly that the respondent kept the petitioner in dark as he had not
disclosed the truth of his marriage and that he had a son. The petitioner came to know about it
from the brother of the respondent. The respondent never disclosed the reality on his own,

This amounts to dishonest concealment on part of the respondent as when he was already
married and had a son and the divorce proceedings were going on. It was the same time during
which the respondent requested sexual favors from the petitioner.

He later assured the petitioner, that he would marry her only after 3 months, when he would
obtain divorce from his wife. She informed the respondent about her pregnancy. It must be noted
that divorce cases take time to be deposed off. Such a promise was not based on reality.

The behavior of the respondent shows that, he only gave mere assurances to the petitioner,
However he did nothing substantial to prove that he actually wanted to marry the petitioner. She
became anxious as she was pregnant and the ignorant attitude of the respondent was persistent.

So the reputation of the petitioner was at stake as she was not married. Also he ignored her calls and
gave evasive answers. So the intention of the respondent was not clear to the petitioner. He kept
her in delusion and is therefore liable for dishonest concealment, i.e. cheating.

MEMORIAL ON THE BEHALF OF PETITIONER 20

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 PRAYER

It is hereinafter most humbly prayed before this Hon'ble Supreme Court of India that in the light of
issues raised, arguments advanced, authorities cited and pleadings made the Hon'ble Court may
be pleased to;

1. Grant the Special Leave Petition (SLP) under Article 136 of the Constitution of India.
2. Respondent should be punishable for the commission of cheating and crime under section
417 and 376 respectively.

3. Any other just and equitable order may be passed in the favor of the petitioner.

AND/OR

Pass any other order that it deems Jit in the interest oPustice, Equity and Good Conscience.

For This Act of Kindness, the Petitioner Shall Duty Bound Forever Pray.

MEMORIAL ON THE BEHALF OF PETITIONER

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