Honourable bench, it is humbly submitted in front of the you that the

charges framed against the accused named,

1. Mr. Sudhanshu Pandu
2. Mr. Rajesh
3. Mr. Raju
4. Mr. Amit
5. Mrs. Rukmani Devi
Are valid on the basis of facts of the case, various evidences, and
statements presented in front of the court as the essentials of various
sections are adequately fulfilled as per the circumstances.

Section 322 and 326 which has been instituted against Mr. Sudhanshu,
Mr. Rajesh and Mr. Raju aptly holds true here, as they are liable to
voluntarily cause grievous hurt, and they had also used an instrument as
a weapon to do so..
The essential of these sections are particular fulfilled as -
1. The three of them had the requisite intention to specifically cause
grievous hurt,
2. They had the required knowledge that their act can likely cause
grievous hurt to her and they deliberately did it in order to take
revenge of the self assumed insults
3. The nature of the injuries are itself evident enough that an
instrument had been used as a weapon to cause those injuries.

In the present case, even though the three accused were in a drunken
state but they were very well aware about their intentions, they had the
knowledge of their act and its nature which is very well reflected from the
confession made by Raju.

Section 323 is applicable on rukmani devi as she must be punished

even after knowing the medically unstable condition of Niharika she
intentionally kicked her several times which aggravated her griefs even
more and added to the reason for her death.

Section 506 of IPC is also applicable in the present case as the named
accused are liable for causing criminal intimidation. Because their
actions were grave enough that they must have caused a feeling of
threat in the mind of the deceased as she was tied and her face was
covered, during the whole time the accused managed to hide their
identity from her and also attacked her chastity and outraged her
modesty brutality.

Section 37 of IPC which relates to cooperating in commission of an

offence by doing some acts which eventually leads to its commission.
Read with section 34 of IPC which relates to common intention are also
applicable in this case as all three of them planned together and
intentionally did several of the acts in order to outrage her modesty, they
caused grievous hurt with full intention and knowledge which eventually
led to Niharika’s death also

there was a prior meeting of minds of the accused as they planed to

rape Niharika and while doing so they also applied criminal force and
assaulted her. It is clearly indicated from the medical report of the
deceased that her body was fully blood stained which shows the brutality
of the assault. The similarities of facts and numbers mentioned in the
dying declaration by Niharika and the confession of Raju indicates the
reality of the allegations made hence section 354 is aptly applicable in
this case.

Absence of semen and injuries in her private parts are not enough to
question the validity of the application of these charges because use of
protection while penetration is a fair possibility and the fact that she was
tied actually restricted her movement due to which her resistance to the
acts was inhibited.

Section 299 of IPC relating to culpable homicide is also applicable in this

case as the bodily injuries which were caused, were intentional and they
were capable enough to understand its nature and consequence and
had full knowledge of the same. And by the same reasoning it can also
be termed as a murder hence appication of section 302 of IPC is drawn
here.

Section 498 A, 504 B of IPC, AND 113a OF IEA

which has been instituted against Sudhanshu, Rukmani and Amit are
justified because as per the facts and very strong circumstantial
evidences present it has been brought in the knowledge of the court that
Niharika’s husband Sudhanshu then his mother Mrs. rukkmani devi and
his brother Amit Pandu who come under the ambit of husband’s relative
were from a long period of time were harassing her for not bringing in
enough dowry with her and were constantly putting forward various
demands like a new car. The reality of the statements of witnesses can
be corroborated from the striking similarities between them.
The fact that both Mrs. Sharda and Ms. Tina had mentioned that
Sudhanshu and his family were demanding a new car and were regularly
subjecting her to cruelty and physical harassment corroborated the
reality of allegations made.

The nail marks found indicate that she regularly became bait of
harassment for not fulfilling the demands of her marital family.

Hence in the light of the facts stated, issues raised, authorities cited
arguments advanced, it is most humbly prayed and implored before the
honourable court that it may graciously adjudicate in the present case
what it deems fit in the eyes of law.