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We want Live India with our Family? As Per NCRP Report our Brothers more than 65000 marital men committed sucide in 2012.because ???

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26 Indian Constitution.(Article)  violated me today. I don’t want happen to your family. In Total population in India 130 Million  plus out of that 70 % are less than 35 years old  pls Ask, Spread, Read this and Signature my petition.  

 IN THE HIGH COURT OF JUDICATURE AT MADRAS

(APPELATE JURISDICTION)

MEMORANDAM OF WRIT APPEAL

UNDER CLAUSE 15 OF THE LETTERS PATENT

                                      W.A.NO-           /13

W.P.NO- 18077 /12

D.Mubarak (Age-32)

No.45.1st floor, 2nd street. N.S.K. Nagar.                               

Arumbakkam, Chennai-600106.                                ...Petitioner

                           VERSUS

1) The Sub-Inspector of Police,

W7- All Women Police Station.

Anna Nagar,Chennai600040.                                                                         

2) P.k.Aamirasamarin

D/o P.K.AbdulMathin

No 16/33, First floor.Thandavan Street.

Purasawalkam,

Chennai-600007                                                         ….Respondents

 

The Petitioner abovementioned begs to state as follows:-

 

A.)I am the Petitioner/Accused D.Mubarak s/o C.Dhastagir Muslim aged 32 years residing at No 45,First Floor, 2nd street, N.S.K Nagar Arumbakkam Chennai-600106.

B.) The address for The Service of All Notices and Processes of the Respondent/Petitioner is, The Sub-Inspector of Police, W7- All Women Police Station, Anna Nagar, Chennai-600 040.                                                                                 

C.) The address for The Service of All Notices and Processes of the Respondent/De-Facto complainant, Mrs P.K. AamiraSamarin D/o Abdul Mathin is No: 16/13.First floor,Thandavan Street, Purasawalkam, Chennai- 600007. The address for The Service of all Process and Notices of the Petitioner and the Respondent’s is same as the above.

For the Below premises and for the reasons stated in the accompanying, I humbly pray that this Hon'ble High Court may be pleased to set aside the order dated 18.07.2012 in W.P.No 18077/12 Hon’ble Justice K.CHANDHRU and Consequently allow the WRIT APPEAL  and to pass such further or other orders as this Hon'ble Court may deem fit and proper in the circumstances of the case and render justice.

GROUNDS

1.   Inter alia, the appellant abovementioned seeks to prefer this memorandum of writ appeal against the Judgement dated 18-07-2012 pronounced by Hon’ble Judge in W.P.No.18077/12 (Article 226 Read with 482 C.R.P.C) on the following   grounds. Petitioner/Accused Humbly Request allow this Judgement According to Press Act No 25/1867                to puplish.

2.   It is Submitted that the Petitioner/Accused and the Respondent/De-facto Complainant were married as per Islamic rites on 03.12.2006 at Princess Palace, Royapuram, Chennai 600 013. Out of this wedlock, there is a male child named M. Aaliyon aged about 5 years.

3.     The Appellant submits that the Learned Judge overlooked the interest of justice by not recognizing that that the Respondent/De-facto Complainant along with her Brothers  and her father were in habit of foisting frivolous and false complaints in Police Stations and also in The Hon’ble courts. The Respondent/De-facto Complainant and her brother P.K Akhil gave the first complaint C.S.R.No. 62/CSR/J4PS/2009 at The Kotturpuram Police Station on 19.06.2009. After the detailed enquiry on the compliant with C.S.R.No. 62/CSR/J4PS/2009, the complaint has been CLOSED. After the closure of this complaint, Respondent/De-facto Complainant  had filed various allegations in her subsequent complaints at different Police stations and also in The Hon’ble Courts. Hence it had been proved with evidence that the complaints were placed out of Brute Vengeance with Personal and Private Grudge to settle scores.  This act proves the CRUELTY committed by the Respondent/De-facto Complainant towards the Petitioner/Accused with false perjured affidavits at The Honorable Courts. The Petitioner/Accused humbly prays that Article 39A of the Indian Constitution be considered.

3A.   It is submitted that writ Petition S.R NO. 13517/13 was filed.   The Most Respectful   The Hon’ble Madras High court Order given ISSUE TODAY IN MY writ Petition S.R NO.  Judgments Para 6.

In the light of the above orders passed, it is open to the petitioner to approach the appropriate Court for appropriate relief and certainly this writ petition is not the right remedy for the relief sought for.

The Petitioner/Accused humbly makes a prayer in respect of  above Paras 1 to 3, that The Honorable Court may consider Article  44 of the Indian Constitution and the fact that the Subordinate Court has followed the Apex Court’s direction in the case of M/S. Pepsi Foods Ltd. & Anr vs Special Judicial Magistrate & Ors on 4 November, 1997 Author: D Wadhwa Bench: S V Manohar, D Wadhwa   the extract of which is given below:

 

Delhi High Court GovindAndOrs. vs The State (Govt. Of NctOf Delhi) on 7 April, 2003 Equivalent citations: 2003 IIIAD Delhi 525, 104 (2003) DLT 510 Author: D BhandariBench: D Bhandari, H Malhotra JUDGMENT DalveerBhandari, J.

 

 

73. When an aggrieved person approaches the court in a petition under Article 226 read with Section 482 of the Code of Criminal Procedure then the court is possessed with enormous powers to do justice or remove injustice. The Court's vast powers are meant to prevent any abuse of the process or to secure the ends of justice, both under Section 482 Cr.P.C and Article 226 of the Constitution. These powers must be exercised for the advancement of justice. Ends of justice are always higher than the ends of mere law and for accomplishing that noble goal the courts have rightly been invested with adequate powers.

 

4.   The Appellant hereby submits that the Learned Judge overlooked the interest of justice by not recognizing that the Respondent/De-facto Complainant had pre-planned intentions to desert the Petitioner/Accused from the matrimonial home. The Respondent / De-facto Complainant left the matrimonial home on 19.06.2009. The very next day of the desertion from the matrimonial home i.e., on 20.06.2009 they lodged a complaint against the Petitioner/Accused at the Kotturpuram Police Station by C.S.R.No.62/CSR/J4PS/2009.  The Respondent/De-facto Complainant had conveniently opened the Joint Locker in INDIAN OVERSEAS BANK (Locker No: 3580341) which was operated by both the Respondent/De-facto Complainant and Petitioner/Accused. The Respondent/De-facto Complainant took away all the Jewels belonging to Respondent/De-facto Complainant and ransacked all the Jewels of Petitioner/Accused also. The Respondent/De-facto Complainant had the audacity to commit perjury before The Hon’ble courts. It is submitted that the Complainant voluntarily on of her own WILL ONLY left the matrimonial home to her parental home by stating that she has to take treatment for  chickenpox (verisulazoster).  The Respondent/De-facto Complainant, with a malafide intention, and without notifying or alerting the joint applicant of the locker (D.MUBARAK) Petitioner/Accused operated the Locker as stated supra. The Respondent/De-facto Complainant has admitted the fact that her father was under heavy financial duress and hence the Respondent/De-facto Complainant has utilised all these Jewels for the same.   There has  always been continuous and unnecessary intervention by Respondent/De-facto Complainant’s  parents in all our family affairs. They did not allow the Respondent/De-facto Complainant and the Petitioner/Accused to lead  their own life, and interfered in their personal boundaries  to talk freely or to take any independent decisions on  family matters. The Respondent/De-facto Complainant’s family’s intervention has only disturbed the daily  life of the Respondent/De-facto Complainant and  the Petitioner/Accused which has to be sorted  out  only by them.

5.    The Appellant submits that the Learned Judge overlooked the interest of justice by not recognizing that the Respondent/De-facto Complainant failed to return to the matrimonial home at Kottivakkam, where we (D.Mubarak, P.K.AmiraSamarin, and child) were staying as a nuclear family. Since the Respondent/De-facto Complainant was not participating in any family affairs as a family member  of the  Petitioner / Accused and having difference of opinion in all family matters and was creating big  family issues in all  the family events. The Petitioner / Accused family members were deeply disturbed by her attitude and behavior towards them and they have requested Petitioner/Accused to have a nuclear family.

The Petitioner/Accused is interested to lead matrimonial life with Respondent/De-facto Complainant on greater interest to safeguard the values of family life, but Respondent/De-facto Complainant does not  show any improvement in living together with Petitioner/Accused after various reconciliations efforts were taken by the elders of the family to restitute the matrimonial life, the Respondent/De-facto Complainant HAVE NOT RETURNED BACK FOR RESTITUTION OF MATRIMONIAL LIFE, for the reasons best known to her. The Petitioner/Accused also called the Respondent/De-facto Complainant for Reconciliation through the Chief Kazi of the Government of Tamil Nadu through  a representation NO: 129/2009 dated 20.07.2009 to return to her matrimonial home as per Mohamed Laws. The good offices of the Tamilnadu Chief Kazi had summoned Respondent 7 (seven) times (Dates of Summon are (i)29.09.09, (ii)15.10.09, (iii) 12.01.10, (iv)27.01.10, (v)16.01.10 )FOR THE REUNION OF MATRIMONIAL LIFE, BUT ALL THE EFFORTS ENDED IN VAIN because the Respondent/De-facto Complainant was ADAMANT AND WITH BRUTE Vengeance with Petitioner/Accused and with his family NOT TO RESTITUTE THE MATRIMONIAL LIFE.  By her Reckless attitude  and behaviour the Respondent/De-facto Complainant has destroyed the life of an innocent juvenile and made him MOTHERLESS, and as well ruined the  life of Petitioner/Accused and had given unwanted torture to him and his entire family with false allegations and spoiled the peace and harmony of the Petitioner/Accused’s entire family. No words could describe such inhumane and reckless behavior. This by itself shows that Respondent/de facto complainant came with tainted hands to The Honorable Court to further ruin the peace and harmony in the Petitioner/Accused’s life and his family member’s with her filthy attitude and behavior. Respondent/de facto complainant’s only intension was to misuse the laws which is against Indian Constitution Article 25, Article 26.

6.    The Learned Judge failed to appreciate the interest of justice. Submitted that Respondent/De-facto Complainant father forget the basic religious ritual i.e., Kannikathanam. The Petitioner/Accused was completely ignored for the child naming ritual. This clearly proved the domination and harassment motive of Respondent/De-facto Complainant’s family members. He made his daughter as A DANCING DOLL FOR HIS COMMANDS. The Respondent/De-facto Complainant father is not at all a good father since he is in the motive of destroying his own daughter’s life; his act clearly shows he is not a good human being. It is only in the interest of justice submitted that Respondent/De-facto Complainant’s father is under heavy financial needs. He used court as a tool with malicious intention to extort huge money by posing false legal threat. He wanted to teach the Petitioner/Accused Hon’ble Courts have more power than Cheaf Kazi (This one line) by the way the Petitioner/Accused’s entire family has been ruined which is against  Indian Constitution Article 25, Article 26.

7.      The Learned Judge has failed to appreciate the interest of justice. Painfully submitted that the Respondent/De-facto Complainant, upon the instigation of her parents and other family members foisted false complaints against the Petitioner/Accused and his family members; which is shocking and surprising. The RESPONDENT/DE-FACTO COMPLAINTANT IS MISLEADING THE HON’BLE COURT BY SEEKING TWO REMEDIES FOR A SAME PROBLEM WITH TWO DIFFERENT LEGAL ENTITIES WHICH CAUSES DOUBLE JEOPARDY FOR THE HON’BLE COURTS. This is forbidden in the constitution of law.  The Respondent/De-Facto Complainant filed a false complaint on me and my family members at Vepery Police Station Ref NO: 15/AC (V)/CAMP/GENL/10, dated on 07.02.2010, this is confirmed by RTI No.RC.No.48/AC.Vepery/RTI/2010.   Yet the Complaint is NOT CLOSED at Vepery Police Station due to NON-COPERATION OF RESPONDENT/DE-FACTO COMPLAINTANT, whereas by suppressing this true fact the RESPONDENT/DE-FACTO COMPLAINTANT has sought the direction from Hon’ble V (Fifth) Metropolitan Magistrate dated 21.05.2010 and filed another false allegation with CC No: 287/2011 against me and my family members. Hence I would like to bring to the attention of this court that the Respondent/De-Facto Complainant has committed a Double jeopardy which is forbidden in the law. This is also against the Article 20(1) & Article 20(2) of Constitution of Indian Law.

8. It was submitted that the Petitioner/Accused and his Parents apprehensive of an arrest situation out of these false complaints by Respondent/De-Facto Complainant and her family members even tried to procure Anticipatory Bail Order vide Criminal original petition which was filed as No. 6834 of 2010 on 05.04.2010 in the Honourable High Court. The Hon’ble High court Justice S.NAGAMUTHU dismissed this application, as the F.I.R was not yet filed and it was only a complaint since no case was registered by the Police. 

9.  The Learned Judge failed to appreciate the interest of justice. Submitted that in view of the above Character and Conduct of Respondent/De-facto Complainant the Petitioner/Accused with a broken heart understood the known facts that the marriage with Respondent/De-facto Complainant cannot be continued further and it has broken irretrievably (IRMB)because of the Respondent/De-facto Complainant and their family members ruthless behaviour, hence the Petitioner/Accused pronounced Talaq (Divorce) on 27.01.2010 as per Mohammad Laws in front of the Tamil Nadu Chief Kazi after the Tamil Nadu Chief Kazi’s validation Petitioner/Accused letter. The Petitioner/Accused hereby humbly request the Hon’ble Court consider Indian Constitution Article 29.

10. The Learned Judge failed to appreciate the interest of justice. Submitted that the Respondent/De-facto Complainant asked the Petitioner/Accused in the police station to return all her belongings, the Petitioner/Accused responded that he is ready to return all her belongings But Respondent/De-facto Complainant did not come to the Vepery police station to collect her belongings after giving a police complaint. The Petitioner/Accused lost his reputation in society, sent a single Talak dated 12.04.2010, Mehar dated 22.04.2010, in which It was clearly mentioned to take back her belonging and give back Petitioner/Accused belongings. The Respondent/De-facto Complainant  also know that after receiving Talak and Maher letters from Petitioner/Accused, the Respondent/De-facto Complainant  has a sent legal notice. 

11.    The Learned judge failed to appreciate the interest of justice. Submitted that the Respondent/De-facto Complainant as to counter blast with private and personal grudge with the Petitioner/Accused, since she has been given Talaq, Respondent/De-facto Complainant obtained the Direction u/s 156(3) Cr.P.C of Criminal Procedure Code from Vth Metropolitan Magistrate, Egmore, Chennai -600008 within 29(26.04.2010) days of Talaq against the Petitioner/Accused and his entire family. The K3 Police station has filed FIR in the following sections 498a, and 406 as per the directions and allegations given by the Vth Metropolitan Magistrate and later transferred to K4 Police station where charge sheet were filed.  The VthMetropolitan Magistrate had taken the complaint without understanding the face value and truths of the complaint given by Respondent/ De-facto Complainant and accepted it in entirety, and this case does not have any prima facie or no offence was made against the Petitioner/Accused. 

12. The Learned Judge failed SUPERINTENDENCE Legal Responsibility I the interest of justice. Respectfully submitted that the Honourable VthMetropolitan Magistrate erred in taking cognizance of the case against the Petitioner/Accused without any prima facie or evidence in support of the allegations made the Respondent/De-facto complainant, the learned magistrate did not apply his mind even when senior citizens and ladies were made as the party to the false and frivolous allegations made in the complaint by Respondent/De-facto complainant. The Complaint is so absurd and inherently improbable on the basis of which no prudent person can ever reach a just conclusion and that there is NO SUFFICIENT GROUND FOR PROCEEDING THE CASE AGAINST THE PETITIONER/ACCUSED. It was submitted that before the EYE Of LAW that the Petitioner/Accused were provided the Document of CHARGES FRAMED  Type set paper…………..

The Petitioner/Accused humbly requests the Honorable Court to consider the Indian Constitution Article 44 and following Apex court rule for my above Para 4 to 12:-

The Honorable Apex Court in   Bench: Arijit Pasayat, LokeshSingh Panta, P. Sathasivam in Criminal Appeal 773/2003 ruled in Sundar Babu & Ors. vs. State Of Tamil Nadu on 19 February, 2009

 “civil or criminal possess, in the absence of any express provision, as inherent in their constitution, all such powers as are necessary to do the right and to undo a wrong in course of administration of justice on the principle "quando lex aliquid alicui concedit, concedere videtur et id sine quo res ipsae esse non potest" (when the law gives a person anything it gives him that without which it cannot exist). While exercising powers under the section, the court does not function as a court of appeal or revision. Inherent jurisdiction under the section though wide has to be exercised sparingly, carefully and with caution and only when such exercise is justified by the tests specifically laid down in the section itself. It is to be exercised ex debito justitiae to do real and substantial justice for the administration of which alone courts exist. Authority of the court exists for advancement of justice and if any attempt is made to abuse that authority so as to produce injustice, the court has power to prevent abuse. It would be an abuse of process of the court to allow any action which would result in injustice and prevent promotion of justice. In exercise 

 

13.    The Learned Judge overlooked the interest of justice. Submitted that after recording the FIR, the Charge Sheet should be filed with in 30 days but it was not followed in this case where as more than 180 days passed after the FIR.  The Petitioner/Accused filed a complaint to The Honourable Chief Justice and Director General of Police under Human Rights, after which the charge sheet was filed (17.01.2011).The Investigation officer has filed the charge sheet with lot of clerical errors where there is NO PRIMA FACIE or proper charges where framed. This is clear fact that it is an influenced charge sheet by the Respondent and it has been prepared MECHANICALLY WITHOUT ANY PROPER INVESTIGATION MADE ON THIS CASE.It is against the Indian COSTITUTION Article 44. AND THE CASE 287/2011 WHICH IS RUNNING OUT OF THIS IS NOT A VALID CASE ACCORDING TO INDIAN CONSTITUTION. In Prime Witness List of Document following mistakes were found.

a)     In General while filing a charge sheet the Investigation officer will make the Husband ie the Petitioner/ Accused should be the A1 (Accused No: 1) but whereas in my case my Father who had been made as A1 in the Charge Sheet by the Investigation Officer and every time of hearing they are relating my father as my wife’s husband in the Hon’ble Courts.  But the Police have mentioned it as a Clerical error. This by itself is clear evidence that Police has not understood or made any investigation about the case with the Respondent / De-facto Complaint came with the tainted hands and given a false complaint about the Petitioner / Accused and his family members.  Also this clerical error has spoiled the Senior Citizen’s social status, in the charge sheet it is stated that the A1 (Petitioner / Accused Father) lived a matrimonial life with Respondent/De-facto complainant (the Respondent /De-facto complainant is my wife).

b)      In the allegation made by the Respondent/De-Facto Complainant P.K.AmiraSamarin daughter of Abdul Mathin it is mentioned that her father name is Abdul Lathif instead of his name as Abdul Mathin whereas in the same page her father name appears as Abdul Lathif  against P.W.2 in the witness statement thereby the Investigation Officer again made a mistake of mentioning P.W.3 father’s name.

c)       Hence it proved the charge sheet is filed with an erroneous attitude and NO EVIDENCE or NO TRUTHS were analyzed and NO INVESTIGATION was made on Respondent/De-facto complainant Complaint.

 The Investigation Officer had failed to collect prima-facia evidence for the     Respondent/Petition controversial allegations made in the complaint, evidence collected in support of the same do not disclose the commission of any offence and make out a case against the Petitioner/Accused. The gift items given to the husband by in laws should be segregated by the IO’s form the list of stri-dhan and the complainant has not informed this to IO while preparing it. The Petitioner/Accused makes and humble request to call for the record Under Section Article 136, 50 of the Act Vested power and C.R.P.C 397,C.R.P.C 396.

The Petitioner/Accused humbly requests the Honorable Court to consider the Indian Constitution Article 136 and the following Apex Court’s rule for my above Para 13:-

Supreme Court of India Sri ChampaLalvs Sri ShaikNajmuddin Alias ... on 1 May,2002 Equivalent citations: AIR 2002 SC 2076, JT 2002 (4)   SC478,2002(4)SCALE277Author:DMohapatraBench:DMohapatra,
10. A finding of fact recorded ignoring material evidence on record is unsustainable in law.

14.  The Learned Judge overlooked Hon’ble High Court Superintendence Power in the interest of justice Painfully submitted that Petitioner/Accused has received written information from W7 All women police station through RTI RC.NO.104/DC AN/CAMP/RTI/11 Dated 12.10.2010 stating that Respondent/petition (police) do not have any cognizable evidence or eye witness other then 161 C.R.P.C statement provided by Here-say & vintage witnesses with respect to the complaint C.S.R NO.287/11, which evidently prove that this case does not has any face value or prima facie to continue in the Hon’ble Courts and it is direct fact of false case which is being conducted by the Hon’ble Courts without understanding the true value or Prima Facie of the Case. The direct motive behind this false allegation by the Respondent/De-facto Complainant is to unveil Legal Terrorism to extort huge money from the Innocent Petitioner / Accused and to harass legally and exhort Mental Torture to Petitioner / Accused family members. For Hon’ble High Court references Family Court Ex 18. Type Set Paper............

(I.) The Learned judge failed to appreciate that Right to Information Act 2005 had been promulgated with the intention of enabling the citizens to secure access to information under the control of public authority in order to promote transparency and accountability in the working of every public authority.

(II) The Learned judge overlooked that the provisions of the Act and contemplated a situation where attempts to obtain information under the Right to Information Act would be taken as 498a, 406 IPC.

(III)  The Learned Judge further overlooked that the Act had been enacted keeping in mind a situation where a women was subjected to cruelty by her husband or his relatives and was a victim of violence within the family then she can go for a complaint against her husband and with his family members to a police station or to Hon’ble courts.  But in the case of the Petitioner/Accused there is no such incident of any cruelty or violence against the Respondent / De-facto during her stay in her matrimonial home, She filed false complainants on brut vengeance and exhort physical and mental torture to Petitioner / Accused and his family members filing false cases.

(IV).  The Learned  Judge overlooked that nowhere in the complaint the Respondent/De-Facto complainant mentioned about DOWRY HARRSEMENT or any allegation related to dowry demand to the concerned Metropolitan Magistrate, seeking Protection as envisaged in the Act thus clearly indicating the total lack of bona fides at her end.

(V). The Learned Judge failed to appreciate the interest of justice.  Painfully submit that Petitioner/Accused had defended with the above set of  defensive document’s  which is unimpeachable in nature  by clearly  explaining and disproving  all  allegation paragraphs after paragraphs in the trial court, but the Vth Metropolitan Magistrate dismissed my entire family’s Discharge petition. U/s 239C.R.P.C even understanding that this case does not have any Prima Facie and should not proceed with any further trial in this case and it is against the Indian Constitution. For the Hon’ble Court Reference Charges Framed and U/S 239 C.R.P.C.type set paper……….

15. The Learned Judge failed to appreciate the interest of justice.  Submitted that the Respondent/De-facto Complainant, her father, her brother and their relatives agreed and prepared an M.O.U (Memorandum Of Understanding )  which were signed by both parties with an understanding to end the cold war and to settle their issues amicably with an Pre-Fixed amount of  Rs. 7, 00,000/- (Rupees Seven Lakhs only).

The M.O.U also states that

(i)           All the pending cases before the police stations and Honourable courts would be withdrawn immediately.

(ii)          Whereas no interference will occur on either side is also agreed upon in M.O.U dated 12.08.2010.

(iii)        The M.O.U also states that no case would be filled both sides in any civil or criminal cases against either side in future dates.

(iv)        As per M.O.U  the Petitioner/Accused  drew 2 Demand Drafts, ie.,

a.   First Demand Draft Number 007532 dated 11.08.2010 in favour of P.K.AAMIRA SAMAR IN for Rs. 4,00,000/- (Rupees Four Lakhs Only)IN INDIAN OVERSEAS BANK, PURSWALKKAM BRANCH, CHENNAI – 600007.(M.C 219/10 2nd Petitioner - Child ),  and

b.   Second Demand Draft Number 601956  dated 12.08.2010  in favour of P.K.AAMIRA SAMAR IN for RS 3,00,000/- (Rupees Three Lakhs only) IN INDIAN OVERSEAS BANK, PURSWALKKAM BRANCH, CHENNAI – 600007. (M.C.219/10 1st Petitioner- Wife ) and her Articles, and the two Demand Drafts were given to the mediator appointed by elders.

16.       The Respondent / De-facto Complainant’s Father made a twist with a different statement against the M.O.U stating to Mediation arranged by Hon’ble Madras High Court’s Respectful Justice MR. Madivanan U/S Mediator Appointed under clause a, and clause b (i)  Rule 2004 of under section 89 of the civil Procedure Code. As per law Indian Constitution Article 215 It is Court of Record.  With a false statement that the Demand Drafts drawn for RS.7,00,000(Rupees Seven Lakhs Only) is only for the article and marriage expenses and not for settlement arranged as per MOU. The Petitioner/Accused were Surprised and shocked by the audacity of the Respondent/De-facto Complainant Father  the Petitioner/Accused   made stop payment for the  both the Demand Draft given, but cunningly De-complainant enchased   Draft bearing RS.4,00,000/- (Rupees Four Lakhs only)and   Petitioner/Accused had stopped the second demand draft bearing payment of RS.3,00,000/- (Rupees Three Lakhs only). This happened after bail was granted by Honourable Justice Mr. Devadas for the Respondent\Accused. The Respondent/De-facto Complainant and her relatives are trying to misuse the law with a clear malafide intention of using the Honorable Courts as tool for legal extortion. I would like to submit before the EYE of law this event clearly shows that Woman Desertions and Woman Protection Laws are used for Producing Single Biological Parents. The Tamilnadu Chief Kazi Validated my Talak and the time given as per Mohammed law lapsed as no information\objection was received from the Respondent/De-facto Complainant. Now with the tainted hands violating Indian Constitution Article 29.

16A.   It is submitted that writ Petition 18077/12 was filed. Subsequently a review petition 186/2012 was also filed.  The Most Respectful Hon’ble Court CONDONED my delay of 29 Days for filing the review petition

. The Hon’ble Madras High court Review judgments Para 2.

The petitioner once again filed several documents in support of his review application. He also raised grounds which were not part of the original proceedings. Even the grounds raised are in the form of grounds of appeal for filing an appeal. This court is not inclined to entertain the review application. In the light of   above,

16B.  It is submitted that writ Petition S.R NO. 13517/13 was filed.   The Most Respectful   The Hon’ble Madras High court Order given AS IT IS MY PRAYER ISSUE TODAY IN MY writ Petition S.R NO.  Judgments Para 7.

Therefore, this writ petition is not maintainable, The Registry is directed to return the papers to the petitioner to enable him to move the appropriate Court. In the Reason stated above.

 

The Petitioner/Accused humbly requests the Honorable Court to consider Article 132 and 134A of the Indian Constitution and makes an Humble Request to Transfer this Petition to Hon’ble Supreme Court of India and get the Opinions and Pronounces of the Natural Judgment.

·        I would like bring it to the attention of this Honourable Apex Court The SUPREME COURT OF INDIA that Article 132 of the Constitution Of India 1949, The 1st Petitioner understands the following the mighty myth of the SUPREME COURT OF INDIA in the following way that it is the independent constitutional judicial body with residuary power with extraordinary in its amplitude with wide discretionary power in its limits, when it chases injustice.

·        The Petitioner/Accused without perusing, selected the Wrong Life Partner in Life. The Respondent/De-facto complainant instigated by her faulty and cruel attitude of torturing the husband and his family members with legal tool, approached the Hon’ble Courts with tainted hands and not allowed the Hon’ble Courts to function according to Indian Constitution Article 375. (Two Directions from the Hon’ble Madras High Court lapsed and was getting dates totaling 72 days in trail court). The Petitioner/Accused is broadminded personality with patriotic social interest bringing it to the attention of the misuse of women favorable law to highest judicial powers.

·        The Petitioner / Accused already made a complaint with the Human Rights Commission Complaint    for violating the human rights by the Respondent / De-facto Complainant. The Respondent / De-facto Complainant. also committed Domestic Violence against The Petitioner/Accused’s Mother D.TharaBegam, an ailing senior citizen aged around  61 years (Accused No.2 in C.C.No 287/11). To save her family, filed a complaint with the Domestic Violence officer, subsequently a Summon No 3893/D.V/2010 DATED 11-10-2010 was sent. But yet there was NO FURTHER ACTION TAKEN ON THE COMPLAINT GIVEN BY PETITIONER/ACCUSED’S MOTHER. Since there was a CONDONE by BOTH<!--[



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