DISTRICT: NAGAON

IN THE GAUHATI HIGH COURT

(THE HIGH COURT OF ASSAM, NAGALAND, MIZORAM AND ARUNACHAL PRADESH)
(CIVIL EXTRA ORDINARY JURISDICTION)

W.P. (C) No. /2020

Category Code:
Category No:

To,
The Hon’ble Mr. Justice Ajai Lamba, B. A. (Hons. in Eng.), LL. B., the Chief
Justice of the Hon’ble Gauhati High Court and His Lordship’s other companion Judges
of the said Hon’ble Court.

IN THE MATTER OF:-

A petition under Article 226 of the Constitution
of India for issuance of a Writ in the nature of
Certiorari and/or Mandamus and/or any other
appropriate Writ, Order or Direction for
enforcement of legal and fundamental rights
of the petitioner.

-AND-

IN THE MATTER OF:-

Impugned Order/Opinion dated 27-03-2019
passed in F. T. Case No. 94/2016 arbitrarily
declaring the petitioner a foreigner by the
learned Foreigner’s Tribunal- 4th, Nagaon
without properly considering the case of the
petitioner amounting to violation of the
provisions of Articles 21 and 14 of the
Constitution of India.
 -AND-
IN THE MATTER OF:-
Dulal Uddin, aged about 54 years,
Son of Late Sahur Uddin,
Resident of Village- Dakhin Koladuba,
P.O.: Jengani, P. S.: Juria,
District: Nagaon, Assam,
PIN: 782122.
............. PETITIONER

-VERSUS-
1. The Union of India,
Represented by Home Secretary,
Ministry of Home Affairs,
North Block, New Delhi- 110001.

2. The State of Assam,

Represented by Commissioner and Secretary to
the Government of Assam, Home and Political
Department, CM Block (Third Floor),
Assam Secretariat, Guwahati,
District: Kamrup (Metro), Assam,
PIN: 781006.

3. The Deputy Commissioner, Nagaon,

District: Nagaon, Assam. PIN: 782001.

4. The Superintendent of Police (B), Nagaon,

Dist.: Nagaon, Assam, PIN: 782001.

5. The Electoral Registration Officer,

83 No. Dhing Legislative Assembly
Constituency,
C/o- Office of the Circle Officer, Dhing
P.O.- Dhing, Dist.: Nagaon, Assam,
PIN: 782123.
 6. The State Coordinator of National
Registration (NRC), Assam,
1st Floor, Achyut Plaza,
G.S. Road, Bhangagarh,
Guwahati, Assam, PIN: 781005.
... .... .. RESPONDENTS

The humble petition of the petitioner above named

MOST RESPECTFULLY SHEWETH:

1. That the petitioner is a citizen of India and a resident of the abovementioned
locality and as such he is entitled to enjoy all the rights and privileges guaranteed
under the Constitution of India and other laws framed there under.

2. That the petitioner belongs to the most deprived and dispossessed section of
the society having no land of his own and no means of livelihood. He supports
himself and his family by working as a farm labourer in other peoples’ farmlands
and sometimes as a daily wage labourer. He often finds it very hard to provide for
the family enough so that they do not have to go to bed in empty stomachs. He is
illiterate, uneducated and ignorant of the intricacies of legal procedure and
processes.

3. That the petitioner is a citizen of India by birth being born and brought up at
village Dakhin Koladuba under Juria Police Station in the district of Nogaon in Assam
around 1966. He is also a citizen through his parents and ancestors. The names of
his paternal grandfather and grandmother as well as the names of his father and
mother appeared in relevant electoral rolls including those of 1965, 1970, 1977 etc.
(Annexure- 2). His grandfather Medar Ali had two sons, namely, his father Sahur
Uddin and his uncle Meher Ali. Including the petitioner, his parents had 8 (eight)
children. 5 (five) sons and 3 (three) daughters. No question has ever arisen about
the citizenship of any other sibling and family member of the petitioner.

4. That, however, the then Electoral Registration Officer (ERO) of No. 83 Dhing
Legislative Assembly Constituency raised doubts about the citizenship of the
petitioner during intensive scrutiny of the electoral rolls undertaken by the Election
Commission of India in 1997 in Assam without conducting a proper inquiry. Based
on the report of ERO, the Superintendent of Police (Border), Nogaon, mechanically
and without proper inquiry, made a reference as to the question of citizenship of the
petitioner to the then Illegal Migrants (Determination) Tribunal, Nogaon for opinion.
After the IM(D)Ts were dismantled and Foreigners Tribunals under the Foreigners
(Tribunal) Order, 1964 were constituted the reference against the petitioner was
sent to the learned Foreigners Tribunal- I, Nogaon and then it was transferred to
the learned Foreigners Tribunal- IV, Nogaon. The reference was again registered as
F. T. Case No. 94/2016 in the learned Foreigners Tribunal- IV, Nagaon. All these
developments were unknown to the petitioner.

5. That the petitioner came to know about the reference against him after he
received notice dated 16-04-2016 on 24-04-2016 and accordingly he appeared
before the learned Tribunal and took part in the proceeding. He submitted his
representation/written statement dated 31-05-2016 making the following averments
among others that:
1) There is no reason for suspecting the petitioner as a foreign national.
2) The police officer without making proper investigation submitted a
false report implicating the petitioner in the case.
3) The allegation made against the petitioner as a foreign national is
fully baseless, motivated and concocted.
4) The petitioner’s correct name is Dulal Uddin, son of Sahur Uddin.
5) The petitioner was born at village Dakhin Koladuba under Mouza
Alitangani within the jurisdiction of Juria police station in the district of
Nogaon, Assam.
6) The petitioner married Mazida Khatun, daughter of Halim Uddin of
village No. 1 Boralimari (Uttar Boralimari) under Mouza Alitangani within
the jurisdiction of Juria police station in the district of Nogaon, Assam.
7) The petitioner is at present living temporarily with his family
members for livelihood at village Mikir Ati Howgaon under Doboka police
station in Nogaon, Assam.
8) The petitioner’s father’s name is enlisted in the voter lists of 1965
and 1970 for Rupahihat legislative assembly constituency, Assam.
9) The petitioner’s ancestors were residents of Dakhin Koladuba village.
10) That the petitioner is a citizen of India by birth and he has sufficient
documents to prove his nationality.
 A copy of the Written Statement dated 31-05-
2016 is annexed herewith and marked as
ANNEXURE- 1.

6. That to discharge his burden of proof under section 9 of the Foreigners Act,
1946 the petitioner examined witnesses and exhibited documents. He examined 4
(four) witnesses, namely, (i) himself, (ii) his uncle Abdur Rashid, (iii) Nobi Hussain
who is the Government Gaonburha for the village Dakhin Koladuba under Juria
police station in Nogaon and (iv) his younger brother Aktar Ali. He also exhibited 5
(five) documents to prove his citizenship.

7. That to substantiate the contentions and statements made in the written

statement and to establish his claim of Indian citizenship the petitioner examined
himself as a witness by filing evidence on affidavit dated 05-09-2016 in lieu of
examination in chief. He also exhibited 5 (five) documents as follows:

1. Exhibit- 1 is a certified copy of an extract from the voter list of the

year 1965 for village Dakhin Koladuba (East Part), P.S.- Rupahihat,
Mouza- Alitangani, Rupahihat legislative assembly constituency, Nogaon.
The document shows that the petitioner’s father’s name Sahur Uddin
features at Serial Number 143 against House Number 32 as son of
Medar Ali and aged about 50 years. His uncles’ name Meher Ali is
enrolled at Serial Number 144 against House Number 32 as Meher
Uddin, son of Medar Ali, and aged about 47 years. His aunt Fulbanu
Nesa’s name comes next at Serial Number 146 against House Number
32 as Fulban Nesa, wife of Meher Uddin and aged about 37. His
grandmother’s name features as Jeleha Nesa at Serial Number 147
against House No. 32 and shown as aged about 70 years.

2. Exhibit- 2 is a certified copy of an extract from the voter list of the

year 1970 for village Dakhin Koladuba (East Part), P.S.- Rupahihat,
Mouza- Alitangani, Rupahihat legislative assembly constituency, Nogaon.
The document shows that the petitioner’s father’s name Sahur Uddin
features at Serial Number 131 against House Number 32 as son of
Medar Ali and aged about 55 years. His uncles’ name Meher Ali is
enrolled at Serial Number 132 against House Number 32 as Meher, son
of Medar Ali, and aged about 52 years. His mother’s name features at
Serial Number 133 against House Number 32 as Saheda Khatun, wife of
Sahur and aged about 54 years. His aunt Fulbanu Nesa’s name comes
next at Serial Number 134 against House Number 32 as Fulbanu, wife of
Meher and aged about 42. His grandmother’s name features as Saleha
Khatun at Serial Number 135 against House No. 32 and shown as aged
about 75 years.

3. Exhibit- 3 is a certified copy of an extract from the voter list of the

year 1977 for village Dakhin Koladuba (East Part), P.S.- Rupahihat,
Mouza- Alitangani, Dhing legislative assembly constituency, Nogaon. The
document shows that the petitioner’s father’s name Sahur Uddin
features at Serial Number 170 against House Number 22 as son of
Metab, instead of Medar Ali, and aged about 70 years. His uncles’ name
Meher Ali is enrolled at Serial Number 171 against House Number 32 as
Meher, son of Metab, and aged about 65 years. His mother’s name
features at Serial Number 172 against House Number 22 as Saheda
Khatun, wife of Sahur and aged about 65 years. His aunt Fulbanu Nesa’s
name comes next at Serial Number 173 against House Number 22 as
Fulbanu, wife of Meher and aged about 60. His elder brother Moijuddin’s
name features as Moijuddin at Serial Number 174 against House No. 22
and shown as aged about 35 years.

4. Exhibit- 4 is a certificate dated 14-08-2016 issued by Government

Gaonburha stating that the petitioner, Dulal Uddin son of Late Sahur
Uddin is a resident of Village Dakhin Koladuba P.O.- Jengani, Mouza-
Alitangani, P.S.- Juria, Dist. Nagaon (Assam) and that he is an inhabitant
of Village- Dakhin Koladuba. The Gaonburha further stated that the
petitioner’s name is enlisted in the Electoral Roll of 2014 in Part No. 104
at SL. No. 899 Holding No. 175 under 83 No. Dhing Constituency as Md.
Dulal Uddin Son of Late Sahur Uddin.
5. Exhibit- 5 is a Revenue Receipt dated 07-07-2018 showing Aktar
Ali, witness No. 4 for the opposite party in the proceeding, as son of
Sahur Uddin, thus establishing his relationship with the petitioner as
brother.

6. The petitioner in his evidence on affidavit pointed out some minor

mismatches between spellings of names and ages given in different
documents exhibited by him as Exhibit- 1, Exhibit- 2 and Exhibit- 3 and
explained them. His grandmother’s name appears as Saleha Khatun in
the voter list of 1970 instead of Jeleha Nesa as appeared in the voter list
of 1965. In the voter list of 1977 his grandfather’s name appears as
Metab instead of Medar Ali and in several other names only the first
names are mentioned. The mismatches relating to age happened in only
the voter list of 1977. His father’s age is shown as 70 years instead of
62 years, his uncle’s age is shown as 65 years instead of 54 years, his
mother’s age is shown as 65 years instead of 61 years. The mismatches
are minor and happened due to clerical errors of the official responsible
for preparation of the electoral rolls.

7. The petitioner also deposed before the learned Tribunal. In his oral
deposition dated 20-06-2018 recorded by the learned Tribunal the
petitioner stated that his father’s name is Safaruddin. It is the name by
which his father is known in the village. He also confirmed that his
grandfather’s name is Medar Ali. He also gave the name of his brothers
including Aktar Ali and stated that his own name features in the voter
list of Koladuba village.
A copy of the petitioner’s evidence on
affidavit dated 05-09-2016 along with
the documents exhibited and a copy of
oral deposition dated 20-06-2018 as
recorded are annexed herewith and
marked as ANNEXURE- 2.
8. That as witness No. 2 for the opposite party in the proceeding, the
petitioner’s maternal uncle Abdul Rashid submitted evidence on affidavit dated 05-
09-2016 in lieu of examination in chief and also made oral deposition before the
learned Tribunal when the leaned Member examined him on oath and recorded his
statements. He stated that the petitioner’s mother, Saheda Khatun is his elder sister
and as such the petitioner is his nephew. He further confirmed that the petitioner’s
father’s name is Sahur Uddin and the name features in the voter list of 1965. In his
deposition before the learned Tribunal dated 20-10-2018 the witness made the
unequivocal statement that the petitioner Dulal Uddin is his nephew who was born
in village Boralimari near Puthimari village. It is to be mentioned that Boralimari is
the popular name of village Dakhin Koladuba.
A certified copy of the evidence on affidavit
dated 05-09-2016 submitted by witness No.
2 and a copy of his deposition dated 20-10-
2018 as recorded by the learned Tribunal
are annexed herewith and marked as
ANNEXURE-3.

9. That the Government Gaonburha for village Dakhin Koladuba Nobi Hussain
was examined as witness No. 3 for the opposite party in the proceeding. He
submitted his evidence on affidavit dated 01-10-2016 and also deposed before the
learned Tribunal. He stated that the petitioner was born in the village Dkhin
Koladuba. His father’s name is Sahur Uddin. His father’s name features in the voter
list of 1965. The witness also stated that he issued a certificate to the petitioner for
his identity which was exhibited as Exhibit- 4 in the proceeding and proved the
document. In his oral deposition recorded by the learned Tribunal on 20-10-2018 he
confirmed that the real name of Dulal Uddin’s father is Sahur Uddin and added that
in the village he is also called as Safiruddin.
A certified copy of the evidence on affidavit
dated 01-10-2016 submitted by witness No.
3 and a copy of his deposition dated 20-10-
2018 as recorded by the learned Tribunal
are annexed herewith and marked as
ANNEXURE- 4.
10. That the petitioner’s younger brother Aktar Ali also gave evidence on
affidavit dated 12-12-2018 as his examination in chief and made oral deposition
before the learned Tribunal on 13-02-2018 as witness No. 4 of the opposite party
in the proceeding. His statements corroborated the statements made by the
petitioner in his evidence. He further stated that his father’s name is Sahur Uddin
who was also popularly known as Safir Uddin and Safaruddin in the locality and his
mother’s name is Saheda Khatun. The witness confirmed that the petitioner Dulal
Uddin is his elder brother. In his deposition he reiterated what he stated in his
evidence on affidavit dated 12-12-2018.
A certified copy of the witness’s
evidence on affidavit dated 12-12-2018
along with a copy of his oral deposition
dated 13-02-2018 as recorded is
annexed herewith and marked as
ANNEXURE-5.

11. That, however, the learned Tribunal without taking into consideration the
evidence given by the other 3 (three) witnesses declared the petitioner a foreigner
by the impugned Opinion dated 27-03-2019. The learned Tribunal reached to this
opinion by discarding Government Gaonburha certificate dated 14-08-2016 on the
ground that it bears the National Emblem of India at the top. The learned Tribunal
also observed that such a certificate cannot be said to be a proof of citizenship.
Therefore, it is the finding of the Tribunal that the petitioner was not able to
establish his relationship with his father. Hence the reference is answered in
affirmative.
A copy of the impugned Opinion dated
27-03-2019 passed in FT 4th, Nogaon
Case No. 94/2016 is annexed herewith
and marked as ANNEXURE-6.

12. That the petitioner begs to state that it is pertinent to mention here that his
name appears, though marked with D, in all relevant voter lists including those of
2005, 2010, 2011, 2013, 2014, 2017 and 2018 for the village Dakhin Koladuba. All
these voter lists show Sahur Uddin as the father of the petitioner. However, he
could not exhibit copies of electoral rolls bearing his name because the authorities
refused to provide him with the certified copies when he applied for the same. The
petitioner was told by the authorities that they could not provide certified copy of
extract of voter list containing a name marked with D.
Copies of the voter lists of 2005, 2010,
2011, 2013, 2014, 2017 and 2018 for
the village Dakhin Koladuba are
annexed herewith and marked as
ANNEXURE- 7.

13. That the petitioner further begs to state that his brother, Aktar Ali who was
examined as witness No. 4 for the opposite party in the proceeding also has his
name in all relevant voter lists that show him as son of Sahur Uddin establishing his
relation with the petitioner as brother. This is apart from the other evidence on
record establishing their relations as siblings.
Certified copies of the extract of voter
list of 2005 and 2011 for Dakhin
Koladuba are annexed herewith and
marked as ANNEXURE- 8.

14. That the petitioner being extremely aggrieved at the impugned Opinion
dated 27-03-2019 for declaring him a foreigner arbitrarily without proper
consideration of evidence on record prefers this petition under Article 226 of the
Constitution of India for setting aside the same on the following amongst other
grounds:
1) For that, the learned Tribunal committed grave errors of both facts
and laws in affirming the reference against the petitioner and thus
declaring him a foreigner by the impugned Opinion dated 27-03-2019.

2) For that the learned Tribunal has completely failed to take note of
the facts that the reference itself was bad in law as it is not in accordance
with the rules established by law as well as procedure laid down by this
Hon’ble Court in its full bench decision in the case of the State of Assam
and others -Vs- Moslem Mondal and others reported in 2013 (1) GLT 809 in
as-much-as the inquiry required to be conducted before making a
reference to the Tribunal by the police is not conducted properly, fairly and
in accordance with the rules of natural justice. No notice was issued to the
petitioner for the enquiry and thus no opportunity was given to him to state
his case before the enquiring officer as is required under the directions of
the Hon’ble Supreme Court issued in Lal Babu Hussain and Others -Vs-
Electoral Registration Officer and Others, 1995 SCC (3) 100 before deleting
a name from the voter list or marking a name with “D” in the voter list.
Such complete disregard to the rules of law led the learned Tribunal to
arrive at an opinion which is arbitrary, perverse, illegal and void. Therefore,
the impugned Opinion is liable to be set aside.

3) For that, the learned Tribunal illegally discarded certificate dated 14-
08-2016 issued by the Government Gaonburha of village Dakhin Koladuba
entirely, which is contrary to the provisions of law, on the ground that the
certificate bears the National Emblem of India unauthorisedly ignoring that
an illegal document or document procured illegally is admissible in evidence
under Indian law. Even if, for the sake of argument, it is accepted for a
moment that a document bearing an unauthorised impression of the
national emblem becomes inadmissible in evidence, there is no reason to
ignore and not to consider the statement made by the Gaonburha in his
examination in chief dated 01-10-2016 and his deposition dated 20-10-
2018 where he clearly testified that the petitioner is the son of Sahur Uddin
whose name appears in voter list of 1965. Ignoring this evidence renders
the impugned Opinion arbitrary and illegal and hence liable to be set aside.

4) For that, the learned Tribunal also failed to take into consideration
the evidence given by the witness Nos. 2, 3 and 4 who were examined as
witnesses for the opposite party in the proceeding. They submitted
evidence on affidavit for their examination in chief as per Rule 4 of Order
XVII of the Code of Civil Procedure, 1908. They also deposed before the
learned Tribunal and learned Member examined them on oath and
recorded their statement in open court. They made themselves available
for cross-examination but the state chose not to cross-examine them.
There is no reason not to consider their evidence. There is not a single
whisper in the impugned Opinion about the evidence given by them and
taken in record. This non-consideration of the evidence adduced legally by
the petitioner makes the impugned Opinion perverse and illegal and hence
it is liable to be set aside.

5) For that, the learned Tribunal committed serious illegality by not

taking into consideration the evidence of the witnesses of the petitioner
who are his relatives. In view of section 50 of the Indian Evidence Act,
1872 that lays down that when the court has to form an opinion as to
relationship of one person to another the opinion as to the existence of
such relationship of any person who, as a member of the family or
otherwise, has special means of knowledge on the subject, is a relevant
fact, the evidence of opposite party’s witnesses are relevant since they are
his maternal uncle, neighbour and younger brother, respectively and as
such they have special knowledge as to the relationship of the petitioner to
his father. The complete lack of a whisper about their evidence makes the
impugned Opinion liable to be set aside.

6) For that, the learned Tribunal also committed serious errors by

taking a very narrow and technical view of the case of the petitioner. The
cumulative effect of all the evidence taken together and appreciated from a
proper perspective makes it abundantly clear that the petitioner was able
to prove his relationship with his father beyond reasonable doubt even
though the standard of proof under section 9 of the Foreigner’s Act, 1946 is
preponderance of probability. Therefore, the impugned Opinion is liable to
be interfered with.

7) For that, the question of citizenship of a person is a very grave

question having far reaching serious consequences. The consequence of an
affirmation of a reference by a tribunal under the Foreigners Act, 1946 and
the Foreigners (Tribunal) Order, 1964 is statelessness in case where the
person concerned has nowhere to go and no other countries are there to
accept him as a citizen. Statelessness is said to be akin to civil death. It is
worse than a civil death because it affects not only the person concerned
but also his descendents become stateless even before they are born. In
view of such seriousness of the matter, the learned Tribunal ought to have
taken into consideration all evidences and materials available on record and
to arrive a just conclusion after dealing with the evidence adduced by the
 petitioner adequately and properly. The failure of the learned Tribunal to
do so renders the impugned Opinion liable to be set aside.

15. That the petitioner begs to submit that from the facts and circumstances as
narrated hereinabove, the petitioner has been able to establish a prima facie case
calling for intervention of this Hon’ble Court under Article 226 of the Constitution of
India by way of issuing a writ in the nature of Certiorari or any other appropriate
writs, orders and/or directions to set aside the impugned Opinion dated 27-03-2019
passed in F. T. 4th, Nogaon Case No. 94/2016. In the interim, the operation of the
impugned Opinion dated 27-03-2019 (Annexure- 6) may be stayed and protection
from arrest and deportation and any other coercive actions against the petitioner
may be granted in view of the fact that the Opinion is prima facie illegal and non-
existent in the eye of law and that if protection is not accorded much injustice and
irreparable loss will be caused to the petitioner. It is a fit case wherein this Hon’ble
Court may be pleased to pass an effective interim order for the ends of justice.

16. That the petitioner did not make any wilful delay and laches in approaching
this Hon’ble Court. Since the petitioner is very poor and leading a hand to mouth
existence and supporting his family by working as a labourer, he has been going
through serious financial crisis. Therefore, it took him a while to approach this
Honourable Court for justice.

17. That the humble petitioner has no other adequate and alternative remedy
and the remedy sought for is complete and adequate.

18. That this petition is filed bonafide and for the ends of justice.

In the premises aforesaid your Lordships’ humble

petitioner most humbly prays that Your Lordships may be
pleased to admit this Petition, call for the records, issue
Rule to the Respondents to show cause as to why a writ
in the nature of Certiorari or any other appropriate writs,
orders and/or directions to set aside/quash the impugned
Opinion dated 27-03-2019 passed in Case No. 94/2016
by the learned F.T. 4th Nagaon may not be issued and
after cause or causes shown, if any, records perused and
parties are heard, Your Lordship may be pleased to make
the Rule absolute;
 Or, alternatively, issue Rule to the Respondents to show
cause as to why a writ in the nature of Certiorari or any
other appropriate writs, orders and/or directions to set
aside/quash the impugned Opinion dated 27-03-2019
passed in Case No. 94/2016 by the learned F.T. 4th
Nagaon may not be quashed/set aside and thereafter as
to why a writ in the nature of Mandamus, or any other
appropriate writs, orders and/ or directions remanding
the Case No. 94/2016 to the learned Foreigners Tribunal
4th Nagaon with a direction to hold fresh proceeding may
not be issued and after cause or causes shown, if any,
records perused and parties are heard, Your Lordships
may be pleased to make the Rule absolute and/or to pass
any other order/s as Your Lordships may deem fit and
proper.

Pending disposal of the Rule, Your Lordships may further

be pleased to stay/suspend the operation of the
impugned Opinion dated 27-03-2019 passed by the
learned F.T. 4th Nagaon in Case No. 94/2016 and grant
protection to the petitioner from arrest, detention and
deportation and any other coercive actions.

And for this act of your kindness the petitioner as is duty bound shall ever pray.
 AFFIDAVIT
I, Dulal Uddin, aged about 54 years, son of Late Sahur Uddin, resident of Village-
Dakhin Kaladuba, P. O.: Jengani, P. S.: Juria, in the district of Nagaon, Assam, PIN-
782122 do hereby solemnly affirm and declare as follows:-

1. That I am the petitioner of this instant Writ Petition and as such I am fully
acquainted with the facts and circumstances of the case and competent to swear
this affidavit.

2. That the statements made in this affidavit and those made in paragraphs 1,
2, 3, 4, 12, 13 and 15 of the petition are true to my knowledge and those made in
paragraphs 5, 6, 7, 8, 9, 10 and 11 being matters of record of the case are true to
my information derived therefrom which I believe to be true and the rest are my
humble submissions before this Hon’ble Court.

“Oath”
“I swear that this my declaration is true, that it conceals nothing, and that no part
of it is false, so help me God”.

And I sign this affidavit in this the 14th day of February, 2020 at Guwahati.

Identified by:-

Advocates’ clerk DEPONANT