India's Abused Law 498a Perjury Petition Format

India's abused law 498a <http://sagittarius498a.blogspot.
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Saturday, October 27, 2012
Perjury petition format
IN THE COURT OF A.C.J Magistrate

__TH COURT AT Fatehpur, U.P.
C.C. NO. ______/2010
Mrs. Anuradha ...Applicant

Versus
_________________ .Respondent[ Present Applicant ]
RESPONDENT'S APPLICATION U/S 340(1) of Cr.P.C, 1973. FOR THE ACT OF

PERJURY COMITTED BY THE APPLICANT UNDER AFFIDAVIT AND SOLEMN AFFIRMATION
UNDER OATH SUBMITTED BY THE MAIN APPLICANT IN Fatehpur COURTS.
MAY IT PLEASE YOUR HONOUR:
I, Mr. _____________________, respondent above named, do hereby state on

solemn affirmation as under:-
1. Present petitioner is father in law of main applicant
2. Main applicant is well qualified lady, having completed B.A and

currently doing M.A and registered with employment exchange, and is
educated and literate, and knowingly and willfully has been filing
multiple cases against respondent applicant, being a educated lady has
armored self-same with tool and weapons of criminal procedures to harass
respondents by way of different ways.
3. It is most respectfully submitted by the Respondent that the couple

stayed not more than __ days, i.e.______________.
4. The facts mentioned and maintained by applicant wife are contrary to

applicant wife's father in different litigations about same event on
same date, i.e. on the date of marriage; The applicants self same
submissions are contrary to her own self substantiate facts, made to
mislead the Ld Court.
5. That present applicant respondent knew the complainant and her family
members before marriage since more than 20 years and knowing about them
the respondent without any demand of dowry directly/indirectly, without
giving or taking any dowry of whatsoever nature married main applicant
wife since both families knew one another since long.
6. It is admitted fact that main applicant including 2 sisters have

filed 498a matter against their respective families, and in trial main
applicant wife also has accepted this very fact, the alleged facts of
all complaints by all sisters in their own 498a cases is same that they
were assaulted and demand of 50,000 Rs was made and they were kicked out
of the matrimonial home
7. That is it submitted on affidavit that the main applicants

allegations are that she was assaulted and demand of 50,000 Rs and
motorcycle was made. Affidavit filed 26-10-2010 states that she went to
police station on 13th July to kotwali Fatehpur, her complaint was not
taken is alleged. Hence she forwarded the written complaint to SP
Fatehpur by way of registry the same information was given, the same can
be observed in ____/____ under affidavit and substantiated evidence,
annexed as Annexure "A1"
8. That in witness box the self-same complainant has substantiated the

fact, in the matter of 53/06, it is material on record and substantiated
that on 12-07-2005, self-same applicant wife went to kotwali Fatehpur
and 498a case was registered in the kotwali and the final report of that
matter has been reported by Kotwali Fatehpur.
9. In clear view and plain reading the applicant complainant is educated

person and literate lady, and has willfully with clear oblique
intentions to harass the present applicant and to mislead the court of
law in different courts, in the imaginary notion that one court of law
cannot come to know what she has substantiated in another court of law,
and there by misleading the court of law and playing pranks of judicial
institution and false statements, from one court to another court of
law, and harassing innocents, and interfering in the administration of
justice. And is using court of law as a tool. Heavy fine should be
levied and stern action and punishment should be provided to restrain
other such litigants from making such false allegations and complaints
against entire family, and this litigant has tried to break the family
system, If such litigants are not punished others will gain confidence
and the family system will start to destroy in Indian Society.
10. It is admitted fact that father of complainant has also been tried
for murder case; this fact is also admitted by the father of complainant
and main applicant and is on material on record.
11. That Respondent stays in ________ since he was 17 years of age and
continues to stay there, these above facts in paragraph 3 and paragraph
4 were not known and were kept hidden from the respondent and family,
this amount to cruelty upon the present applicant respondent and his
family members.
12. It is most respectfully submitted by the Respondent that the main

applicant wife has filed for the reliefs u/s 498A, 406, 323, 504, and
506 of IPC by way of 156(3) on oath on 07.09.2005, which was received as
65/05 in the court of C.J.M Fatehpur; with allegations that she was
assaulted and demand of 50,000 Rs and motorcycle were made by
respondents and other members within 21 hours of marriage and she left
thereafter.
13. Respondent had to move Honorable High court of Allahabad for relief
u/s 482 Cr.P.C and Stay Arrest until filing of Charge sheet was granted
by Honorable High Court of Allahabad.
14. Main Applicant wife filed one more private complaint dated
23.08.2006 with J.M Court Number 13 again u/s 498a, 323, 504, 506 and 34
of IPC and u/s of The Dowry Prohibition Act, on same grounds and same
facts which should be null and void as per 300(1) Cr.P.C and to avoid
double jeopardy.
15. Respondent again moved Honorable High court of Allahabad for relief
u/s 482 Cr.P.C. and Honorable High Court of Allahabad directed for
consolidation of both cases of 498a and directed to submit report under
173 Cr.P.C. in consolidation, the said Order from Honorable High Court
of Allahabad is annexed as Annexure "A".
16. Executive machinery police has filed a final "B Summary" report u/s
173 Cr.P.C on 14.02.2007. Main applicant wife has filed a protest
application the order is passed, and upon which 1477/10 is initiated.
17. That Main applicant wife has filed false Maintenance Case u/s 125
Cr.P.C, Case No. ____/05 on __.__.2005, in J.M Court Fatehpur. Against
husband who is otherwise a student, and is allegedly stated that he
earns 20,000 Rs, which is false and imaginary to which no proof could be
established and is unnecessary tactics used by applicant who is well
aware of court procedures; And 125 Cr.P.C proceedings, relief to the
wife were prohibited and application by applicant wife was dismissed at
the outset.
18. The Maintenance case 125 Cr.P.C beyond doubt was dismissed by way of
long and lengthy speaking order; as per Order Annexed as Annexure "B".
19. Father of complainant wife , during Trial of 125 Cr.P.C, In the

facts substantiated stated that he did not visit Respondents home until
his daughter came back home when she was demanded dowry, only then he
came to know about demand of dowry and assault on her. Annexure "C"
green shaded region on page number 4 in ____/05 case. Adding that he was
not even aware by any sorts of communication or by phone or by some
person or by any other means, Shri Satyanarayan Awasthi was not at all
aware that his daughter was demanded dowry or was assaulted by
respondent/family members.
20. On the contrary, Main Applicant wife in her sworn affidavit and
submissions in Case of u/s 9 of Hindu Marriage Act, Case Number __/06 in
the J.M. Court Number 1 on page number 6 "dafa no. 8" , states that she
was being assaulted by respondent and family members during such time
the servant who also worked in Main Applicants home also, saw this and
went and informed family of Main applicant wife, and the same was
communicated to family of main applicant by the applicant over telephone
that there was nothing , But hearing this , since the distance between
Main Applicant and Respondent is very negligible and can be reached in
less than 5 minutes by walk; Father, Mother, Brother and some relatives
came to respondent home and after discussing the matter was resolved,
but that continued and then thereafter main applicant was forced to
leave Matrimonial home and go to parental home.
21. These prima facie facts of the submissions of main applicants and
her family members as per paragraph 13 and 14 of this application above,
who have moved the court of law and initiated process that is otherwise,
abuse the law, that is otherwise for destitute women application but is
utilized for harassment making use of law as a weapon and tool to make
innocent family members face criminal trial, which amounts to a very
serious nature, The application moved by main applicant wife being not
maintainable and she has suppressed the relevant facts and application
being false , baseless, vexatious, imaginary. And hence do not make out
any prima facie case against the respondents so as to summon the
respondents to face trial and in this circumstances taking cognizance
against the respondents is bad in law and is untenable in the court of
law, cannot be sustained, that it amounts to abuse of the process of
Hon'ble court.
same date ; The applicants self same submissions are contrary to her own
self substantiate facts
23. That the application filed by main applicant wife during various
times have changed the facts according to the need of context and sense
of urgency and has manipulated facts with willful intention, while
submitting information to the Ld Court, in various court of law, in
cases filed by main applicant wife; the facts are imaginary and false,
and this amounts to grave misuse of court of law and interference in the
administration of justice and denying the liberty to the real victims,
here respondent and family members.
24. The changing facts and misuse by main applicant wife, amount to
disturbing the purity of law and damaging the serenity of the stream of
justice and interferes in the administration of justice thereby
performing acts of perjury in every application in the notion of
applicant wife that law is meant for harassment and since the applicant
is a female will be exempted for her cruelty and using judicial system
for her barbaric acts upon the respondent and his family members and
destroying image and reputation.
25. The persons who use the court of law for their private and personal
vendetta should be punished severely so as to curb the menace of
misusing and harassing the innocent families, such cases should become
the highlight cases and offenders should be sternly dealt with, without
looking at the gender or caste or creed, which are not exempted from
Article 15(3) of Constitution Of India.
26. The main applicant wife has willfully and with malafide intentions
has filed the instant application, which is devoid of any merit and is
interference in the administration of justice.
27. The Main Applicant wife has also filed Application u/s 12 of "The
Protection of women from Domestic violence, Act". U/s 18/19 of the said
Act, On 30.05.2009, case number __/09, in the CJ.M Court Fatehpur.
28. The Main Applicant has filed the matter against Respondent, his
____________, ______________, also has roped and implicated brother Of
respondent ______________________without any cause of action, again
fabricating evidence that she was assaulted on false and fabricated grounds.
29. It is on material record that the Domestic Incident Report, In

Domestic Violence Application, created as per procedure, by probation
officer stated that no police officials are aware of the facts mentioned
in the mentioned domestic violence application, where the incident
allegedly had took place in domestic violence application, and that even
after inquiry made by probation officers enquiry, and sequences of
findings and observations made by probation officer came to conclusion
that such facts as claimed by applicant wife were found false in the
knowledge of people at alleged scene and scenarios mentioned in domestic
violence application, and hence the same were false, the probation
officer during such probe also came to know that applicant wife has
filed 498a two times and that her 125 Cr.P.C and revision of 125 Cr.P.C
were rejected by honorable court, when wide probe inquiries were made by
the probation officer.
30. That clearly the domestic violence application was also moved with
the willful intention to injure and harass the respondent and family
members and using court of law as a weapon for harassment.
31. That the domestic violence application is also dismissed on the

meritorious grounds by way of lengthy speaking order, by the magistrate.
32. The main applicant has also fabricated medical report in the
domestic violence to prima facie prove Domestic Violence, and the
incidents alleged. The facts mentioned by main applicant wife are
absolutely ambiguous and imaginary has suppressed the relevant facts and
application being false, baseless, vexatious, and imaginary. And hence
do not make out any prima facie case against the respondents so as to
summon the respondents to face trial and in this circumstances taking
cognizance against the respondents is bad in law and cannot be sustained
it amounts to abuse of the process of Hon'ble court if without prima
case having being made out a person is summoned to face trial.
33. The application of main applicant's wife under section 125 Cr.P.C
that was rejected and dismissed by Ld Court. The order was challenged by
wife and the same was again rejected in session's court while under
revision, Revision Order is annexed as Annexure "D".
34. The Main Applicant wife has concealed and suppressed true facts,
submitted under oath has false submissions under oath, and more so are
contrary to the submissions to this honorable court, which are
perjurious in nature.
35. The main applicant wife in her complaints / applications until year
April 2011, made no whisper of any Bengali girl with whom
_______________had any intimation relation, In Application under
affidavit filed by applicant wife u/s 9 of Hindu Marriage Act it is
alleged that photo of Bengali girl was with ___________________
displayed to applicant wife and he started kissing the photo in front of
Applicant wife. That the facts are baseless and imaginary and are false
and fabricated and such cruel acts are performed since year 2005 where
she didn't even spend more than 21 hours.
36. Such allegations were not present in any previous applications of

498a matter or 125 matter, or revision under 125 , even Domestic
Violence application was filed and the reliefs are dismissed by way of
wide speaking order, and such new facts have landed on the legal
grounds, this clearly and loudly entails that applicant is a habitual
litigant in fabricating evidences and infringing rights and injuring the
rights of other people, without due consideration about the grave injury
caused by willful intention with imaginary illusions, thereby causing
grave hurt and character assassination and injecting mental agony in the
hearts and soul of respondent and his family members. Thereby not only
infringing rights of applicant but also willful interference in the
administration of justice and disturbing the serenity of the stream of
justice.
37. From above instances and admitted facts and arising facts after long
and more than 5 years. That main applicant wife is a habitual offender
and having two sisters who have filed 498a against upon their respective
in-laws, and father being tried for murder case, is continuously over
the years since marriage of one single day, has filed application after
application using courts as weapon to dominate the family of in-laws and
to grab the land and money of in-laws, to satisfy her needs and her
individual principles, she has been attempting to interfere the
administration of justice, it is imperative to punish such litigants,
who are using heavy hands in the name of weaker section and destroying
the very purpose of legislations provided to weaker sections of the society.
38. The applicant wife has filed an application , This new application
that was meant to delay and prevent her substantiation of submissions,
which stands rejected, In this application she demanded that she will
not appear in the court of law until 40 Lakhs Bond was not filled, in
matter of Restitution of conjugal rights u/s 9 Of Hindu Marriage Act.
39. There by denying early relief to respondents and interference in the

interest of justice to innocent victims. Thereby interfering in the
administration of justice.
40. In the Trial of 125 Cr.P.C, PW1 The complainant wife substantiated
that my father is poor and she has two sisters and father cannot
maintain her, In-laws are rich, And PW2, the father of complainant wife
in his substantiating evidences, under oath stated that he is poor and
he cannot fulfill the maintenance required to his daughter and his
daughter also cannot maintain herself.
41. On the contrary, in the party witness 3, Sister of complainant wife,

in the matter of __/06 u/s 9 of Hindu Marriage Act, under sworn
affidavit, named Tilak, in her affidavit Tilak has maintained under oath
that her father has ample amount of land of 50 to 60 Bighas of the
agricultural land.
42. It is pertinent to note that, This is clear voice of fabrications

and contrary statements which lead to the interference in the
administration of justice and destroying the image of innocent victims
respondents and his family members who are undergoing mental agony,
character assassination, loss of reputation, being defamed in
application after application by family of all three daughters who have
filed 498a cases against their in-laws and father who has been also
tried for murder case and also stands witness in cases.
43. Applicant being legally bound by oath in this Hon'ble Court to state
truth in her affidavit but the applicant and her witness has with
knowledge and willful intention have deposed false in their affidavit
and substantiated evidences. Applicant has being knowingly and
intentionally given false statements in judicial proceedings.
44. From above facts and instances, it is clear and loud, that this main
application by wife is false, fabricate, contrary to statements
maintained in the honorable court by the self-same applicant wife, That
it is proven on material record, the statements made under oath are
contrary and injurious to respondents in the instant complaint made by
applicant wife.
45. Respondent states that the applicant wife is a guilty of the Act of
perjury by making false statements, on oath solemnly affirming,
willfully and knowingly that those Statements are false, in "AFFIDAVITs"
on various dates submitted by her in this Hon'ble court with oblique
motive to misguide and mislead this Hon'ble court with a view to extort
money where as she is not entitled for any relief under the said Act.
same date ; The applicants self same submissions are contrary to her own
self substantiate facts
47. Respondent states that the material on record before this Hon'ble
Court prima facie proves that the applicant has committed the act of
perjury in her submission and the same has been described in detail.
48. It is most respectfully submitted that Orders by the Judiciary

branch under proceedings have clearly and loudly mentioned that
petitioner should come to the court in clean hands and Injunction
Temporary as well as permanent Injunctions of petitioner was prohibited
and rejected. As, her averment were not reliable based on documentary
evidences presented by respondent, and It can be loudly and strongly
observed that without strict proof petitioner applicants any averment is
unsafe and unreliable, and are changing facts like air on earth.
49. It is most respectfully submitted that paragraphs and facts in

instant application by applicant wife are self-submitted facts under
oath by the main petitioner wife in more than two different courts
having different legal stands as pointed out above, thereby playing
fraud with the court and prejudice the Ld. Court to allow relief and
harassing the real innocent victims, and thereby committing the act of
perjury under oath and solemn affirmation, and with willful intention to
injure, and to interfere administration of justice and harass the
respondents.
{B} The petitioner has comitted an act of perjury in her following

submissions
in view of her submission given above:
50. Respondent states that, the applicant has made the following
willfully perjurious, intentionally deposed false and misleading
statements on oath solemnly affirming, in her aforesaid "AFFIDAVITs"
submitted by herself in this Hon'ble court with oblique motives and are
verified and Prohibitory Orders also have recognized as false by the
respective Ld. Court. Which clearly proves that the main applicant wife
is deposing false on affidavit in reply in this Hon'ble Court on her
whims and fancies thereby committing the act of perjury by giving false
evidence during the judicial proceedings in this Hon'ble court? Hence
applicant wife is punishable for the act of perjury, which adversely
affects the administration of justice.
51. Respondent states that, Applicant filed the Affidavit filed by main
applicant wife in applications submitted an Application under this
instant Ld Court. are false, vexatious, concocted and misconceived to
harass the Respondents and make him/them to run from pillar to post,
Respondent states that applicant has not come with clean hands before
this Hon'ble Court and suppressed material facts intentionally, creating
new facts as delaying tactics and denying early justice, thereby
interfering in the administration of justice. It is pertinent to note
that applicant is only interested in making ambiguous and vexatious
allegation against the respondent without any iota of evidence in
support of her submissions and trying to mislead and misguide this
Hon'ble court by making vague allegation against the respondent.
Respondent states that petitioner has not come to the court in clean
hands and this material fact have been intentionally suppressed and
concealed or created on self-imaginations knowingly from this Hon'ble
Court in the main application to mislead this Hon'ble Court, this is
very clear and has been proved with substantial evidence by the respondent.
52. In order to appreciate the aforesaid aspect, I deem it necessary to
reproduce the relevant provisions of the Cr.P.C.:
340. Procedure in cases mentioned in Section 195.
(1) When upon an application made to it in this behalf or otherwise any

court is of opinion that it is expedient in the interest of justice that
an inquiry should be made into any offence referred to in Clause (b) of
Sub-section (1) of Section 195, which appears to have been committed in
or in relation to a proceeding in that court or, as the case may be, in
respect of a document produced or given in evidence in a proceeding in
that court, such court may, after such preliminary inquiry, if any, as
it thinks necessary,-
(a) Record a finding to that effect;
(b) Make a complaint thereof in writing;
(c) Send it to a Magistrate of the first class having jurisdiction;
(d) Take sufficient security for the appearance for the accused before
such Magistrate, or if the alleged offence is non-bailable and the court
thinks it necessary so to do send the accused in custody to such
Magistrate; and
(e) Bind over any person to appear and give evidence before such Magistrate
...
195. Prosecution for contempt of lawful authority of public servants,

for offences against public justice and for offences relating to
documents given in evidence.
(1) No court shall take cognizance-
...
(b) (i) Of any offence punishable under any of the following sections of
the Indian Penal Code (45 of 1860), namely, Sections 193 to 196 (both
inclusive), 199, 200, 205 to 211 (both inclusive) and 228, when such
offence is alleged to have been committed in, or in relation to, any
proceeding in any court, or
(ii) Of any offence described in Section 463, or punishable under

Section 471, Section 475 or Section 476, of the said Code, when such
offence is alleged to have been committed in respect of a document
produced or given in evidence in a proceeding in any court, or
(iii) Of any criminal conspiracy to commit, or attempt to commit, or the

abetment of, any offence specified in sub-clause (i) or sub-clause (ii),
except on the complaint in writing of that court, or of some other court
to which that court is subordinate.
40. In the conspectus of the aforesaid provisions, if the relevant

provisions of the Indian Penal Code, 1860 (hereinafter referred to as
the IPC) are perused, it does appear that the provisions of Sections
193, 199, 200 and 209 are attracted. The said provisions read as under:
IPC Section 193. Punishment for false evidence
Whoever intentionally gives false evidence in any stage of a judicial

proceeding, or fabricates false evidence for the purpose of being used
in any stage of a judicial proceeding, shall be punished with
imprisonment of either description for a term which may extend to seven
years, and shall also be liable to fine; and whoever intentionally gives
or fabricates false evidence in any other case, shall be punished with
imprisonment of either description for a term which may extend to three
years, and shall also be liable to fine.
Explanation 1-A trial before a Court-martial; [* * *] is a judicial

proceeding.
Explanation 2-An investigation directed by law preliminary to a

proceeding before a Court of Justice, is a stage of a judicial
proceeding, though that investigation may not take place before a Court
of Justice.
IPC Section 199. False statement made in declaration which is by law

receivable as evidence
Whoever, in any declaration made or subscribed by him, which declaration

any Court of Justice, or any public servant or other person, is bound or
authorized by law to receive as evidence of any fact, makes any
statement which is false, and which he either knows or believes to be
false or does not believe to be true, touching any point material to the
object for which the declaration is made or used, shall be punished in
the same manner as if he gave false evidence.
IPC Section 200. Using as true such declaration knowing it to be false
Whoever corruptly uses or attempts to use as true any such declaration,

knowing the same to be false in any material point, shall be punished in
the same manner as if he gave false evidence.
Explanation-A declaration which is inadmissible merely upon the ground
of some informality, is a declaration within the meaning of Sections 199
to 200....
...
IPC Section 209. Dishonestly making false claim in Court
Whoever fraudulently or dishonestly, or with intent to injure or any

person, makes in a Court of Justice any claim which he knows to be
false, shall be punished with imprisonment of either description for a
term which may extend to two years, and shall also be liable to fine.
53. 14. Respondent states that thus material on record before this
Hon'ble court and perusual of detail aforesaid description in this
application clearly proves that applicant has committed act of perjury
by intentionally giving enormous false and fabricated evidence during
judicial proceeding in this Hon'ble court by submitting false in her
"AFFIDAVITs". Thus filing false affidavit in the court of law, causes
obstruction in the course of justice and also adversely affecting the
administration of justice. Also applicant cannot be permitted to take
liberty of spoiling purity of justice. In this facts and circumstances,
the respondent has filed this present application in this Hon'ble Court
in exercise of jurisdiction of this Hon'ble court u/s 340(1) of thr
Cr.P.C, 1973. against the main applicant wife and it is to expedient in
the interest of justice to prosecute the applicant as prima facie
evidences are adduced in that behalf. Hence applicant is punishable for
the act of perjury, adversely affecting the administration of justice.
54. Respondent further states that all adverse allegations and incidents
mentioned/deposed by the applicant in this Hon'ble court had never
happened and the same are false, baseless, malicious, vexatious,
concocted, futile and imaginary story made intentionally to harass
respondent from court to court across Uttar Pradesh states and put
respondents under pressure by misusing the provision of law conveniently
and cunningly in attempt to extort money from the respondent. it goes to
show that, the main applicant wife is only interested in making
ambiguous and vexatious allegations against the respondent without any
iota of evidence in support of her submissions and trying to misguide
the Hon'ble court by making vague allegations against respondent and
whatever allegations where sole testimony of main applicant. In fact
there is no proper allegation against the respondent. Respondent states
and submits that, the continuation of prosecution against the respondent
is not only the abuse of process of law, but also defeats the ends of
the justice. The Applicant 's application u/s 498a, 323, 504, 506, 34 of
IPC and of The Dowry Prohibition Acts devoid of merits and deserves to
be dismissed with exemplary costs and suitable punishment in the
interest of justice.
55. I say that therefore, it is clear from the above Para that the
petitioner is guilty of the act of perjury, as she has made the
aforesaid false statements on oath with solemn affirmation providing
false information to this Hon'ble court, willingly and knowingly that
the same are false and the respondent has submitted the documentary
evidences that those statements are false. In these circumstances, the
respondent has filed this present application in this Hon'ble court in
exercise of jurisdiction of this Hon'ble court u/s 340(1) of the cr.p.c,
1973. Against the petitioner and it is expedient in the interest of
justice to prosecute the petitioner as Prima Facie evidences are adduced
in that behalf.
56. Respondent adopt each and every statement, submission and averments
made in this application, that all statements are from applicant wife's
applications and are brought forth to the notice of the instant Ld. Court.
57. Respondent craves leave of this Hon'ble court to add, to alter and
amend this application. Respondent carves leave to add, alter and amend
this application.
58. Respondent had not filed any other application for the act of
perjury committed by the applicant in this Hon'ble court against the
applicant in any other Hon'ble court.
59. Respondent has not filed any other application for the act of
perjury against the petitioner, either in this Hon'ble court or any
other Hon'ble court for the subject matter hereto.
60. It is therefore, most humbly prayed by the respondent that;

a. By considering the aforesaid facts and circumstances, respondent most
humbly pray that this Hon'ble court be pleased to kindly charge the
petitioner and commit the matter to the concerned Metropolitan
Magistrate court to prosecute the petitioner for the act of perjury in
her application to implicate falsely to innocent victims.
b. In the peculiar facts and circumstances of the case. Your Honor may
Kindly dismiss the application filed by the applicant under 200 Cr.P.C
be dismissed with exemplary costs to meet the ends of justice
c. Costs of the proceedings may kindly be awarded to the Respondent from

the applicant.
d. Initiate the proceedings of perjury for infringement of rights and

harassment, using the sections which are for destitute women, the same
are misused and harassment of respondent and female party thereby
playing pranks with the modesty of women of the women party.
e. Kindly pass such other suitable orders as may deem fit and proper to
meet the ends of justice in the peculiar facts and circumstances of the
case.
AND FOR THIS ACT OF KINDNESS AND JUSTICE, THE ABOVENAMED RESPONDENT AS
IN DUTY BOUND SHALL EVER PRAY.
Solemnly affirmed at _________.
Dated; this ____day of December, 2010.
Respondent
V E R I F I C A T I O N
I, Mr. ____________________. ________Years of age, presently residing at

______________________________. The respondent above named do hereby
state and declare on solemn affirmation that whatever stated in the
above Application is true and correct as per my knowledge and belief;
that no part of it is false and nothing material has been concealed
there from.
Solemnly affirmed at ____________.
Dated; this _____day of May, 2011. Respondent
IN THE COURT OF A.C.J MAGISTRATE

__TH COURT AT Fatehpur, U.P.
C.C. NO. ____/2010
Mrs. Anuradha ...Applicant

Versus
_______________________ .Respondent[ Present Applicant ]
LIST OF DOCUMENTS
1. copy Of 125 CrPC application by Applicant in ______ Court (Exhibit-`A')

2. Copy of 125 Interim Order by ________Court ( Exhibit-`B')
3. copy of CRAN filed in High Court Of ________ by Applicant; dated
11.Aug.2010. ( Exhibit-`C')
4. Any other with permission of this Hon'ble Court.
Solemnly affirmed at ________________.
Dated this day of May, 2011. Respondent.

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India&#39;s Abused Law 498a Perjury Petition Format

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Saturday, October 27, 2012

Perjury petition format

IN THE COURT OF A.C.J Magistrate

Mrs. Anuradha ...Applicant

RESPONDENT'S APPLICATION U/S 340(1) of Cr.P.C, 1973. FOR THE ACT OF

MAY IT PLEASE YOUR HONOUR:

I, Mr. _____________________, respondent above named, do hereby state on

1. Present petitioner is father in law of main applicant

2. Main applicant is well qualified lady, having completed B.A and

3. It is most respectfully submitted by the Respondent that the couple

4. The facts mentioned and maintained by applicant wife are contrary to

6. It is admitted fact that main applicant including 2 sisters have

7. That is it submitted on affidavit that the main applicants

8. That in witness box the self-same complainant has substantiated the

9. In clear view and plain reading the applicant complainant is educated

12. It is most respectfully submitted by the Respondent that the main

19. Father of complainant wife , during Trial of 125 Cr.P.C, In the

29. It is on material record that the Domestic Incident Report, In

31. That the domestic violence application is also dismissed on the

36. Such allegations were not present in any previous applications of

39. There by denying early relief to respondents and interference in the

41. On the contrary, in the party witness 3, Sister of complainant wife,

42. It is pertinent to note that, This is clear voice of fabrications

48. It is most respectfully submitted that Orders by the Judiciary

49. It is most respectfully submitted that paragraphs and facts in

{B} The petitioner has comitted an act of perjury in her following

in view of her submission given above:

340. Procedure in cases mentioned in Section 195.

(1) When upon an application made to it in this behalf or otherwise any

(a) Record a finding to that effect;

(b) Make a complaint thereof in writing;

(c) Send it to a Magistrate of the first class having jurisdiction;

195. Prosecution for contempt of lawful authority of public servants,

(1) No court shall take cognizance-

(ii) Of any offence described in Section 463, or punishable under

(iii) Of any criminal conspiracy to commit, or attempt to commit, or the

40. In the conspectus of the aforesaid provisions, if the relevant

Whoever intentionally gives false evidence in any stage of a judicial

Explanation 1-A trial before a Court-martial; [* * *] is a judicial

Explanation 2-An investigation directed by law preliminary to a

IPC Section 199. False statement made in declaration which is by law

Whoever, in any declaration made or subscribed by him, which declaration

IPC Section 200. Using as true such declaration knowing it to be false

Whoever corruptly uses or attempts to use as true any such declaration,

IPC Section 209. Dishonestly making false claim in Court

Whoever fraudulently or dishonestly, or with intent to injure or any

60. It is therefore, most humbly prayed by the respondent that;

c. Costs of the proceedings may kindly be awarded to the Respondent from

d. Initiate the proceedings of perjury for infringement of rights and

I, Mr. ____________________. ________Years of age, presently residing at

Solemnly affirmed at ____________.

Dated; this _____day of May, 2011. Respondent

IN THE COURT OF A.C.J MAGISTRATE

Mrs. Anuradha ...Applicant

1. copy Of 125 CrPC application by Applicant in ______ Court (Exhibit-`A')

Solemnly affirmed at ________________.

Dated this day of May, 2011. Respondent.

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