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The document contains a reply to an amended application in a court case between Nand Lal and Ami Chand, where the respondent argues that the application is not maintainable and that the complainant is aware of all facts but has not acted on them. It also includes a request for exemption from personal appearance due to the accused's kidney problem, stating that the absence is not intentional and that the prosecution can proceed with witness examination. The respondent seeks dismissal of the application with special costs in the interest of justice.

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26 views3 pages

Reply

The document contains a reply to an amended application in a court case between Nand Lal and Ami Chand, where the respondent argues that the application is not maintainable and that the complainant is aware of all facts but has not acted on them. It also includes a request for exemption from personal appearance due to the accused's kidney problem, stating that the absence is not intentional and that the prosecution can proceed with witness examination. The respondent seeks dismissal of the application with special costs in the interest of justice.

Uploaded by

kait77
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
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In the Court of Ms. Sandeep Kaur Ld.

JMIC,
Kaithal

Nand Lal Verses Ami Chand

Reply of the Amended Application


R/Madam,
It is submitted as under:-
Pre-Objections:-
1. That the present application is not maintainable at
the present form.
2. That the respondent has no locus standi to file the
present application.
3. That the complainant has already been knowledge of
all the facts but no application has taken moved
regarding the defect. So the application is not
maintainable at this stage.
On Merits:-
1. That para no.1 of the application is a matter of
record and need no reply.
2. That para no.2 of the application is wrong and
denied. That complainant has been filed the
complaint against the accused Ami Chand and all fact
has been in the knowledge complainant. That at the
time of pre summoning consideration, the complainant
has not taken any attention regarding the defect of
the complainant.
3. That the complainant has already been knowledge of
all facts and not inadvertently, but intentionally
in the complaint and delay tactic. That there is no
provision to amend the material fact of complainant
at this stage and if amendment is allowed, the basic
nature is change of complaint.
4. That para no.4 of the application is wrong and
denied and replace of material fact of complaint at
this stage is change the basic nature of the
complaint and which is against the natural justice.
5. That para no.5 of the application is wrong and
denied and that mistake has been in the knowledge of
complainant and complainant is not take any
advantage/benefit at this stage.
6. That para no.6 of the application is wrong and
denied and this mistake is intentionally at this
stage.
So it is therefore, prayer the application of
the complainant may kindly be dismissed with special
costs, in the interest of justice.

Place: Kaithal` Submitted by:-


Dated: Ami Chand
Verification:
Verified that the
contents mentioned
above are true &
correct to the best
of my knowledge.

Through counsel
In the Court of Ms. Sandeep Kaur Ld. JMIC,
Kaithal

Nand Lal Verses Ami Chand

Application for exemption from personal appearance of


accused Ami Chand for today

Respectfully Showeth:-

1. That the above said case is pending before this Hon'ble


court and the same is fixed for today.

2. That the accused is suffering from kidney problem and


appointment(AIIMS Delhi)today, So due to the kidney
problem he is not able to attend the Hon'ble court
today.

3. That the absence of the accused is not intentional but


due to above said confide reason.

4. That the accused has no objection if prosecution will


examine any witness in this case.

5. That telephonic message received from the accused that he


has not come today and filed this application.

It is, therefore, prayed that the personal


appearance of accused may kindly be exempted for today
in the above said case, in the interest of justice.

Kaithal/- 20.02.2025 Applicant Accused.


Ami Chand

Through counsel

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