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INTRA CLASS MOOT COURT COMPETITION

st
1 Prof.(Dr.) Basant K. Sharma Memorial National Moot Court
Competition

R-*XX*

Intra Class Moot Court Competition

IN THE HON’BLE HIGH COURT OF UTTRAKHAND

Appeal No. ****/ ****

IN THE MATTER OF
SANJANA

(APPELLANT)

Versus

ASHOK
(RESPONDENT)

(UNDER SECTION 96(2) OF CIVIL PROCEDURE CODE)

UPON SUBMISSION TO
THE HONOURABLE CHIEFJUSTICE AND HIS COMPANION JUSTICES OF
THE HONOURABLE HIGH COURT
OF
UTTRAKHAND

MEMORIAL ON BEHALF OF THE RESPONDENT

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TABLE OF CONTENTS

PAGE NO.
1.LIST OF ABBREVIATIONS..............................................................3

2.INDEX OF AUTHORITIES …………………………………….4-5

• CASES CITED
• BOOKS REFERRED
• STATUTES
• LEGAL DATABASE

3. STATEMENT OF JURISDICTION.............................................6

4. STATEMENT OF FACTS............................................................7-8

5.STATEMENT OF ISSUES…………………………………………9

6. SUMMARY OF PLEADING.................................................10-12

7. ARGUMENTS ADVANCED.......................................................13-20

8. PRAYER.....................................................................................21

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LIST OF ABBREVIATIONS

1. & And

2. AIR All India Reporter

3. All. Allahabad High Court

4. Art. Article

5. Bom. Bombay High Court

6. Anr. Another

7. DLR Delhi Law Review

8. Ed. Edition

9. HON’BLE Honourable

10. i.e., That Is

11. ILR Indian Law Reports

12. Ors. Others

13. RAJ Rajasthan

14. SC Supreme Court

15. SCC Supreme Court Cases

16. SCR Supreme Court Reporter

17. UOI Union Of India

18. V. Versus

19. Vol Volume

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INDEX OF AUTHORITIESCASES :-
 Shobha Rani Madhukar Reddi, AIR 1988 SC 121(India)
 V. Bhagat v. D. Bhagat AIR 1994 SCC 710
 Parveen Mehta v. Inderjit Mehta AIR 2002 SCC 706 (India)
 A. Jyachandra v. Aneel Kaur AIR 2005 SCW 163(India)
 Vinita Saxena v. Pankaj Pandit (2006) 3 SCC 778
 Samar Ghosh v. Jaya Ghosh (2007) 4 SCC 511
 Hardeep Singh v. Dalip 2016 SCC OnLine SC 1114
 R. Natarajan v. Sujatha Vasudevan
 Narendra vs. K. Meena
 Puwada Venkateswara vs. Chidamana Venkata 1976 2 SCC 409
 Gauhati University v. Niharalal Bhattacharjee (1995) 6 SCC 731

BOOKS REFERRED :-
• Mulla and Mulla, Family Law (Central Law Agency)
• Dr. Paras Diwan, Modern Hindu Law (Allahabad Law Agency)
• Sir DinshawFardunjiMulla, Mulla Hindi Law(LexisNexis, 23rd Ed.)
• Universal’s Criminal Manual (LexisNexis, 2021)

STATUTES AND RULES :-

1. The Hindu Marriage Act, No.25 of 1955(India).

2. Civil Procedure Code, No. 05 05 1908.

LEGAL DATABASE :-

1. Manupatra
2. SCC Online
3. Lexisnexis
4. Indian Kanoon

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STATEMENT OF JURISDICTION

The Hon’ble High Court is vested with jurisdiction, to hear the present matter under Section
96(2) r.w. Order XLV Rule-3A of Civil Procedure Code, 1908.

Section 96(2):- Appeal from original decree.

(2) An appeal may lie from an original decree passed ex parte.

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STATEMENT OF FACTS

BACKGROUND: Ashok and Sanjana married each other on 17 th November, 2015

according to Hindu rituals. Thereafter they resided in the matrimonial home along with
parents of Ashok. Ashok’s mother was having very orthodox approach towards life. She
always wanted that her son Ashok must have a son for sacramental reasons. Sanjana
delivered a baby girl on 9th April 2017 due to which there arose a lot of difference
between Sanjana and her mother-in-law

ACTIONS AND HAPPENING: Ashok’s mother continuously passed insulting marks

upon Sanjana for the baby girl as she always wanted a grandson. She also threatened her
that if she will not bear a boy for their family, she will remarry her son to another girl.
Ashok also used to fight with his own mother that he is satisfied with birth of the girl.
Sanjana started persuading her husband to start living separately, to which, Ashok never
agreed. Frustrated, Sanjana decided to leave the matrimonial house along with her minor
daughter and returned to her parent's house on 22 nd December, 2017. Ashok visited
several time to her parent's house but he never found her there.

PROCEEDINGS: Then on 2nd January 2020, he filed a petition under section 13, of
HMA, 1955 alleging desertion by his wife. Summonses were issued to Sanjana at the
given address but same were returned and marked as ‘refused to accept’. The petition was
heard ex-parte and on the basis of the evidence produced by Ashok, the Family Court
granted divorce to husband on 16th September, 2020
The copy of the order set to its by Ashok on the address provided. Ch 25 March 2017, shall

remarried Pooja, Hindu Woman. Pooja conceived Ashok child and due date for delivery was

18 May, 2018 Meanwhile, Sanjana filed an application on 5th October, 2018, before Delhi

High Court for condonation of delay for filing appeal again the decree of the family count

granting ex parte decree to Ashok stating that he was aware the proceedings, as the most

served in the address where she was living. She came to know about all thongs through

some common friend. She also stated that be ever had intention to desented Ashok, but she

only wanted to teach a lesson to his mother in law the argued that she was deeply hurt by

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Ashok’s mother and arguments with Ashok also but never desired to serve matrimonial

bond. After due consideration of the reasons for delay in filing the appeal, the court

condoned the delay and accepted the application for appeal. The case is now before the

appellate count.

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SUMMARY OF ISSUES

ISSUE 1 WHETHER THERE WERE VALID GROUNDS FOR GRANTING THE

DIVOREE TO THE RESPONDENT OR NOT?

ISSUE 2 WHETHER THE SUMMONS WAS DULY SERVED OR NOT TO THE

APPELLANT?

ISSUE 3 WHETHER THE MARRIAGE SOLEMNIZED BY THE RESPONDENT ON

25th February, 2021AFTER THE DECREE OF DIVORCE PASSED BY THE FAMILY
COURT IS VALID OR NOT?

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SUMMARY OF ARGUMENTS

ISSUE 1 WHETHER THERE WERE VALID GROUNDS FOR GRANTING THE

DIVOREE TO THE RESPONDENT OR NOT?
It is humbly mitted before the Hon'ble your that the respondent was having sufficient
grounds to take divorce from the appellant. The respondent had sufficient grounds to file for
divorce from the appellant, it is humbly mitted before the Hon'ble Your. According to
Section 13(1)c) of the Hindu Marriage Act of 1955, the appellant's refusal to abide with the
court's order restoring his or her marital rights constitutes a sufficient reason for divorce.
Other grounds that the respondent have cited were mental abuse, which could have been
created in many different ways, such as convincing him to live apart from his parents or
ignoring family chores. The respondent's main objective in submitting application U/S 9 was
to resume his matrimonial rights with the appellant, but when the latter attempted to do so,
the respondent filed for divorce. The Apex court at its instances has established that a
husband may apply for divorce under the Hindu Marriage Act, 1999 if the wife forces him to
live separately from his parents.

ISSUE 2 WHETHER THE SUMMONS WAS DULY SERVED OR NOT TO THE

APPELLANT?

It is humbly submitted to the Honourable Court that the appellant was duly served with the
summons at the specified address. It was the appellant's responsibility, not that of the court or the
respondent, to notify the court of the change of address. The court proceeded according to the
code's procedure, but when the summons was returned undelivered and marked as "refused to
accept," the court proceeded ex-parte while taking the appellant's notice into consideration.
The Family Court regarded it as a constructive notice and on the basis of testimony from the
respondent, moved forward with the case on September 26, 2016. Under Section 28 of the HMA,
1995, there is a 90-day period in which to file an application challenging a divorce judgement,
and under the Limitation Act of 1963, there is a 30-day period.

ISSUE 3 WHETHER THE MARRIAGE SOLEMNIZED BY THE RESPONDENT ON

25th February, 2021AFTER THE DECREE OF DIVORCE PASSED BY THE FAMILY
COURT IS VALID OR NOT?

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It is humbly submitted before the Hon'ble Court that the marriage solemnized by the respond with
Pooja on 25 March, 2017 is valid .No questions arises to the validity of second marriage as it was
solemnized after the divorce decree obtained by the respondent. The husband and wife's marital
status ends at the entry of the divorce order, and they are then free to remarry in accordance with
Section 15 of the HMA 1955. Additionally, in the case at hand, the ex-parte divorce decree was
issued on September 26, 2016, and since the appellant failed to file an application within the 30-
day period required by Article 123 of the Limitation Act of 1963, the respondent is now free to
remarry after that time period has passed. The respondent married pooja on March 25, 2017,
about seven months after the ex-parte divorce was finalised. The respondent had good reason to
expect that no application to set aside the ex-parte divorce decision had been made because seven
months had passed.

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ARGUMENTS ADVANCED

ISSUE 1 WHETHER THERE WERE VALID GROUNDS FOR GRANTING THE

DIVOREE TO THE RESPONDENT OR NOT?

It is humbly submitted before the Hon'ble count that there were sufficient and reasonable
grounds with the family court to pass the divorce decree in favour of the respondent. The
major grounds for granting the divorce can be-
[1.1] Mental cruelty towards respondent and his family .
The highest level social institution determining a person's connection is marriage. Marriage
is referred to as a "religious sacrament" in Hindu law because it "binds a man and a woman
in a permanent connection for the physical, social, and spritual objectives of dharma,
procreation, and sexual pleasure."1 A legal marriage can only be ended via procedures that
are permitted by the law.2 Solemnizing or dissolving a marriage can only be done in
accordance with the guidelines established by the relevant Hindu Marriage Act, 1955. The
statute controls the solemnization and annulment of Hindu marriages in India.

Section 13 of the Hindu Marriage Act 1955 defines the grounds for divorce and Section
13(1) (i-a) specifically states that: "Any marriage solemnized, whether before or after the
commencement of this Act, may, on petition presented by either the husband or the wife, be
dissolved by a decree of divorce on the ground that the other party (i-a) has, after the
solemnization of the marriage, treated the petitioner with cruelty.3

The legal concept of cruelty and the kind of degree of cruelty necessary to amount to a
matrimonial offence has not been defined by any statute of the Indian Legislature relating
marriage and divorce.4 The accepted legal meaning in England as also in India of this
expression, which is whether difficult to define, has been 'conduct of such characters as to
have caused danger to life, limb or health (bodily or mental), or as to give rise to reasonable
apprehension of such damage.'5

1
Whiterosead, Hindu marriage: A sacrament or contact or both.
2
Jatina Samir Shah v. Samir Shah, AIR 2009 (NOC) 2114; Vishnu Kumar v. State of UP, 2006 65 ALR 888;
Bouramma v. Siddappa, AIR 2003
3
Hindu Marriage Act, 1955. Sec 13(1)(i-a)
4
Sir Dinshaw Fardunji Mulla, Mulla Hindu Law(21st ed.)
5
Russell v. Russell, (1897) AC 395; Kallan v. Kallan, AIR 1933 LAH 728
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In Shobha Rani Madhukar Reddi6, the Supreme Court observed that the word 'cruelty’ has
not been defined in the Act, the word is used in Section 13(1) (i-a) of the HMA with
reference to human conduct or behaviour in relation to or in respect of matrimonial duties
and obligations. It is a course of conduct of one which is adversely affecting the other. After
passing Marriage laws (Amendments) Act, 1976 cruelty has been a ground of divorce.

On the basis of the above-mentioned section cruelty can be a ground for divorce as anybody
who is suffering physical or mental torture or any other type of harassment by the other, than
he can approach to the court on this ground and claim for the divorce. In V. Bhagat v. D.
Bhagat 7, the Apex court observed that metal cruelty in Sec 13 (1) (i-a) can broadly be
defined as that conduct which inflicts upon the party such mental pain and suffering as
would make it not possible for that party to live with the other.

In Parveen Mehta v. Inderjit Mehta8, mental cruelty defined as:-

‘Mental cruelty is a state of mind and feeling with one of the spouses due to the behavior or
behavioural pattern by the other. Unlike the case of physical cruelty, the mental cruelty is
difficult to establish by direct evidence. It is necessarily a matter of inference to be drawn
from the facts and circumstances of the case.’ A feeling of anguish, disappointment and
frustration in one spouse caused by the conduct of the other can only be appreciated on
assessing the attending facts and circumstances in which the two partners of matrimonial life
have been living.

In A. Jyachandra v. Aneel Kaur9, the SC expressed the view about cruelty. The expression
“cruelty” has been issued in relation to human conduct or human behaviour. It is a conduct
in relation of matrimonial duties and obligations. The cruelty may be mental or physical,
intentional or unintentional. In Vinita Saxena v. Pankaj Pandit10, regarding legal
proposition on aspect of cruelty has made the following observations: it is settled by a catena
of decisions that mental cruelty can cause even more serious injury than the physical harm
and create in the mind of the injured appellant such apprehension contemplated in the
section. To amount to cruelty, there must be such willful treatment of the party which cased
suffering in body or mind either as an actual factor by way of apprehension in such a manner
6
AIR 1988 SC 121 (India)
7
AIR 1994 SCC 710
8
AIR 2002 SCC 706 (India)
9
AIR 2005 SCW 163 (India)
10
(2006) 3 SCC 778
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as to render the continued living together of spouses harmful or injurious having regard to
the circumstances of case.
It is stated relying on the above judgments, cruelty can be mental or physical, intentional or
unintentional and if mental it is difficult to establish as it is feeling of disappointment or
frustration in one of the spouses.
In the instant case the acts of mental cruelty by appellant can be listed down from the facts
provided as:-
(i) Forcing respondent to live separately from his parents,
(ii) Desertion.
The Hon’ble SC in Samar Ghosh v. Jaya Ghosh11, took into account the parameters of
cruelty as a ground for divorce in various countries and than laid down illustrations, though
not exhaustive, which would amount to cruelty.

[1.2] Forcing respondent to live separately from his parents.

It is humbly submitted before this Hon’ble court that the respondent was satisfied with the
birth baby girl and even fought with his mother but then too the appellant persuaded
respondent to live separately from his parents to which the respondent never agreed12

In Hardeep Singh v Dalip13 Kaur15 where the husband does not agree to live separately from
his parents and wife’s insistence for a separate house persists as a result she chooses to be
away from the husband; The court decreed the petition of restitution of conjugal right filed by
the husband holding that there is no reasonable excuse for the wife to live separately on the
alleged grounds.

In R. Natarajan v. Sujatha Vasudevan, court held that if a wife is asking to live separately
from husband’s aged parents is not a reasonable excuse to withdrawn and rcr can be granted.
In the present case the appellant started persuading the respondent to leave his parents’ home
to which the respondent refused because he was adamant to stay with his parents. Appellant,
after continuous denial by the respondent to leave his parents’, started ignoring the all house
hold chores and his parents and also started refusing for sexual intercourse with the
respondent.17 Just to make the respondent agree to the terms of the appellant and leave the
matrimonial home. Respondent because of his love towards his parents never agreed with the
11
(2007) 4 SCC 511
12
⁋ 2 of moot court proposition
13
2016 SCC OnLine SC 1114
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appellant because of which she left the matrimonial house and the society of the respondent
and went back to her parents’ home. This justifies no reasonable ground for the wife to leave
the matrimonial home or the society of the husband.

The Supreme Court of India in Narendra vs. K. Meena has held no son would like to be
separated from his old parents and other family members, who are also dependent upon his
income, the Court also said that the persistent effort of the wife to constrain the husband to be
separated from the family would be torturous for the husband and will constitute as an act of
‘cruelty’ becoming a ground to grant divorce. In the present case the appellant started
persuading respondent to live separately from his parents on failing to which the appellant
started ignoring household activities and his parents.

In the recent case Prabir Kumar Das v. Papiya Das14, the Chhattisgarh High Court while
allowing husband’s appeal for divorce held that wife forcing the husband to get separated
from his family which includes his old aged ailing parents tantamount to cruelty under
Section 13(1) (ia) of the Hindu Marriage Act, 1955. The High Court again cited the Supreme
court case Narendra vs. K. Meena15, wherein it was held that if the wife forces and exerts
pressure on the husband to live separate from his old aged parents or from the joint family
without any reasonable excuse/ground, the same would amount to cruelty.

From the above cases cited it can be said that the act of the appellant i.e., persuading
respondent again and again to leave separately from his parents 16 caused mental cruelty and
also exerted pressure on the respondent. This gives respondent a reasonable ground for filing
a petition for divorce against the appellant so that they can dissolve their marriage and end
their marital life.

It is argued that from the cases cited above it can be inferred that noncompliance with the
decree of restitution of conjugal rights for one or more than one year in itself becomes a
ground for divorce as per law provide in sec. 13 (1A) (ii) of the HMA,1955.

14
January 29,2019
15
Supra
16
Moot court memorial
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ISSUE 2 WHETHER THE SUMMONS WAS DULY SERVED OR NOT TO THE

APPELLANT?

It is humbly submitted that the summon were served on the given address and on the basis of

considering the constructive notice the court proceeded the ex parte divorce decree.

That in the instance case, appellant returned to her parent’s home on 18th Oct. 2013. The

respondent kept visiting Sanjana’s house but plaintiff was never allowed to meet him and

respondent also tried to contact on phone call but all in vain. Then, respondent on 24th July 2014

filed a petition under Sec. 9 of HMA, 1955 for restitution of conjugal rights to save his marriage

and on 23rd Jan. 2015, court passed the decree of RCR according to which appellant was

supposed to resume her matrimonial home but she didn’t turn up and for the same the respondent

filed an application for execution of decree of RCR and summons were issued to appellant at the

given address but the same returned and marked “refused to accept”. On getting no reply the

respondent on 15th March 2016 (after one year and fifty days of passing the decree of RCR) filed

a petition for divorce u/s 13 of HMA, 1955.

It was considered as a constructive notice by the Family Court and on the basis of evidences

provided by the respondent in the court the Family Court proceeded with the matter and on 26th

Sept.,2016 passed an ex-parte divorce decree in favor of the respondent dissolving the marriage

between the appellant and the respondent. Here, the service of summons was made by the court

in accordance with the procedure given under Order 5, rule 9 of CPC. The court followed the

procedure properly and hence there was no negligence or mistake of the court while serving the

summonses to the plaintiff.

According to Order 5, rule 9(5)27 of CPC- “When an acknowledgement or any other receipt

purporting to be signed by the defendant or his agent is received by the court or postal article

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containing the summons is received back by the court with an endorsement purporting to have

been made by a postal employee or by any person authorized by the courier service to the effect

that the defendant or his agent had refused to take delivery of the postal article containing the

summons or had refused to accept the summons by any other means specified in sub-rule (3)

when tendered or transmitted to him- the court issuing the summons shall declare that the

summons had been duly served on the defendant.”

It is argued that in the instance case, the summonses were issued to the plaintiff at the given

address but the same returned and marked “refused to accept”. Therefore, it can be said that the

summonses were properly served by the court to the plaintiff at the given address but it was the

plaintiff who returned and refused to accept the summonses.

In Puwada Venkateswara vs. Chidamana Venkata 17, the court held that where the

acknowledgement or receipt purported to have been signed by the defendant (or his agent) is

received by the court that the defendant (or his agent) has refused to take the delivery of the

summons; the court will proceed treating the defendant as served. In the instance case also, the

summons was returned unserved marked as “refused to accept” and the court proceeded with

further proceedings on the basis of the evidence given by the respondent.

Limitation period for filing an application for setting aside an ex parte decree is 30 days from the

date of knowledge of the decree32. In Gauhati University v. Niharalal Bhattacharjee18, summon

was served to the petitioner on May 28th, 1990 for appearance on the next day. As per Rule 6 of

Order V as there was lack of sufficient time for appearance the suit was adjourned to July 19th,

1990 but the date was not communicated to the other party. The SC held that as the summons was

17
1976 2 SCC 409
18
(1995) 6 SCC 731
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not duly served the limitation began to run only when the petitioner had the knowledge of the

order. Hence, as the applicant filed within the 30-day period the decree was set aside.

In the instance case, question raised by the appellant in the appeal on the irregularity in the

service of summon, was unusual and the court also accepted that the summon was duly served

and the limitation period for filling the appeal or an application to set aside an ex parte decree

(i.e., 30 days) was expired. It is also argued that it was considered by the Family court as

constructive notice and then it proceeded with the ex-parte divorce decree. The respondent was

also unaware of the new address of the appellant as he visited last before filing an application for

divorce.19

ISSUE 3 WHETHER THE MARRIAGE SOLEMNIZED BY THE RESPONDENT ON

25th February, 2021AFTER THE DECREE OF DIVORCE PASSED BY THE FAMILY
COURT IS VALID OR NOT?

It is humbly submitted before the bench that the marriage solemnized by the respondent on 25th
February, 2021is valid as per the provisions given in the Hindu Marriage Act, 1955. Sec.15,
states that- ‘Divorced persons when may marry again’- “When a marriage has been dissolved by
a decree of divorce and either there is no right of appeal against the decree or, if there is such a
right of appeal, the time for appealing has expired without an appeal having been presented, or an
appeal has been presented but has been dismissed, it shall be lawful for either party to the
marriage to marry again.”20

In the present case the respondent filled a divorce petition in family court on 15th March, 2016
and the same was passed as ex-parte divorce decree against the appellant on 26th September,
2016 dissolving the marriage between the appellant and the respondent. The respondent on 25th
February, 2021 married Pooja as per Hindu law & sanskaar and the marriage solemnized is valid
as per Sec. 15 of the Act.

19
Moot court memorial.
20
The Hindu Marriage Act, 1955 Sec 28
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It is also submitted that the respondent has taken all the possible ways to bring appellant back to
matrimonial house and on failing to which he approached the court and duly followed the legal
process provided by the Act for dissolution of marriage and further proceeded for 2nd marriage. 4

It is also argued that after passing of the divorce decree the respondent didn’t immediately
remarried but he married on 25th February, 2021 almost after 6 months of passing the divorce
decree only after ensuring that no appeal has been preferred by his wife and that the timeframe
for appeal as provided in the Limitation Act has been exhausted.21

As per the provisions provide under Sec. 28 of HMA,1955 every appeal shall be preferred within
a period of ninety days from the date of the decree or order.39 The time for appealing against the
decree was also expired and the appellant filed the appeal after 2 years which cannot be termed as
reasonable. In Kuldip Kumar Lal v. Suman Rani 2240 the Rajasthan High Court held that if an
application under Order IX Rule 13 of CPC for setting aside an ex parte decree of divorce is not
filed within the period of 30 days as prescribed in Article 123 of the Limitation Act, the other
party in whose favor the ex parte decree is passed, has a right to remarry after the expiry of the
said period. This judgment was delivered in the light of Section 15 of the Hindu Marriage Act.
50. In the instance case the ex-parte divorce decree was passed on 26th September, 2016 to which
the period for filling an application for setting it aside is 30 days as prescribed in Art. 123 of the
Limitation Act,1963 and since the appellant failed in doing so the respondent has the right to
remarry after 37 The Hindu Marriage Act, 1955. Sec. 15. 38 Statement of facts 39 The Hindu
Marriage Act, 1955. Sec 28.

The respondent married Pooja on 25th February, 2021almost after seven months of passing the
ex-parte divorce decree. Since the time was of seven months the respondent had sufficient cause
to believe that no application has been filed for setting aside the ex-parte divorce decree.

It is humbly submitted that on the basis of the applicable provisions of law, judgments citied and
arguments advanced the second marriage solemnized by the husband is also valid as at the time
when marriage was solemnized no appeal was pending in the court and the limitation period is
exhausted and that when appeal was filed the respondent had already married & had conceived a
child from the second wife.
It is argued that the respondent neither acted with malice intention nor was having any intention
to dissolve the marriage but it was the appellant who had withdrawn from the respondent’s
society without any reasonable cause. The wish of mother of the respondent to have a boy child

21
Moot court memorial
22
2012 KHC 294
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for the sacramental reasons is not a reasonable ground to withdraw from the husband’s society. It
is also clear from the facts that the respondent was happy with his marital life and birth of girl
child till the appellant started to persuade him for leaving separately, ignoring household chores
and refuse to have sexual intercourse with the respondent.

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PRAYER

Wherefore, in light of the issues raised, arguments advanced and authorities cited, may this
Hon’ble Court be pleased:
1. That appeal against dismissal of divorce petition is not maintainable before theUK
HC
2. That divorce should be granted under section 13 on the grounds pleaded

AND/OR

Pass any other order it may deem fit, in the interest of Justice, Equity and Good Conscience.
All of which is most humbly and respectfully submitted.

(COUNSEL FOR THE RESPONDENT)

FOR THIS ACT OF KINDNESS, THE RESPONDENT FACTION SHALL BE DUTY

BOUND FOREVER.

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