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BEFORE THE HON’BLE SUPREME COURT OF INDIA

IN THE MATTER OF

CRIMINAL APPEAL OF 2017

(UNDER ARTICLE 136 OF THE INDIAN CONSTITUTION)

THE STATE OF PALLAKA …APPELLANT

vs.

MICHAEL ...RESPONDENT

UPON WRITTEN SUBMISSIONS ON BEHALF OF THE

RESPONDENTS TO THE HON’BLE CHIEF JUSTICE AND HIS
COMPANION JUSTICES OF THE HON’BLE SUPREME COURT OF
INDIA
 MEMORANDUM ON BEHALF OF RESPONDENTS

TABLE OF CONTENTS

LIST OF ABBREVIATIONS…………………………………………………………….….3

INDEX OF AUTHORITIES………………………………………………………………4

STATUTES…………………………………………………………………………….4

INDIAN CASES……………………………………………………………………....4

STATEMENT OFJURISDICTION………………………………………………………...5

STATEMENT OF FACTS………………………………………………………………...6-7

STATEMENT OF ISSUES…………………………………………………………….……8

SUMMARY ARGUMENTS.………………………………………………………….…….9

1. WHETHER SUFFICIENT GROUND OF LEGAL INSANITY EXISTS SO AS TO

EXONERATE THE ACCUSED FROM LIABILITY OF MURDER.

2. WHETHER THE BURDEN OF PROOF OF LEGAL INSANITY ON THE PART OF

DEFENCE IS AT PAR WITH BURDEN OF PROOF ON PART OF
PROSECUTION.

ADVANCED ARGUMENTS.…………………………………………………….…...10-15

PRAYER...........................................................................................................................16

LIST OF ABBREVIATIONS

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 MEMORANDUM ON BEHALF OF RESPONDENTS

1 & AND
2 AIR ALL INDIA REPORTER
3 AM ANTEMERIDIAN
4 ART. ARTICLE
5 CRPC CODE OF CRIMINAL PROCEDURE
6 DW DEFENCE WITNESS
7 EDN. EDITION
8 FIR FIRST INFORMATION REPORT
9 HON’BLE HONORABLE
10 IEA INDIAN EVIDENCE ACT
11 IPC INDIAN PENAL CODE
12 NO. NUMBER
13 ORS. OTHERS
14 PG. PAGE
15 PW PROSECUTION WITNESS
16 REPT. REPORT
17 S. SECTION
18 SCC SUPREME COURT CASES
19 SCR SUPREME COURT REPORTS
20 SD/- SIGNED
21 SHO STATION HOUSE OFFICER
22 ST SESSION TRIAL
23 U.P. UTTAR PRADESH
24 V / VS. VERSUS

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 MEMORANDUM ON BEHALF OF RESPONDENTS

STATUTES

1. Indian Penal Code (1860)

2. Code of Civil Procedure (1973)

3. Constitution of India (1950)

4. Indian Evidences Act (1872)

INDIAN CASES
SR. NO. CASES PG. NO

1 Vijayee Singh v. State of U.P. (1990) 9

2 T.N. Lakshmaiah v. State of Karnataka (2001) 9

3 Kamla Singh v. The State (1954) 9

9,11 & 14
4 Surendra Mishra v. State of Jharkhand (2011)

5 Dahyabhai Chhaganbhai Thakkar v. State of Gujarat (1964) 10

6 State of Rajasthan v. Shera Ram (2012) 12

7 Hari Singh Gond v. State of Madhya Pradesh (2008) 13

8 Bapu @ Gajraj Singh v. State of Rajasthan (2007) 14

9 Sharad Birdhichand Sarda v. State of Maharashtra (1984) 15

10 Virsa Singh v. State of Punjab (1958) 15

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 MEMORANDUM ON BEHALF OF RESPONDENTS

STATEMENT OF JURISDICTION

THE COUNSELS REPRESENTING THE RESPONDENTS HAVE ENDORSED THEIR

ARGUMENTS ADVANCED BEFORE THE HON’BLE SUPREME COURT OF INDIA

INVOKING ITS JURISDICTION UNDER:

In the matter of

(The State of Pallaka v Michael )

Section 302 of the Indian Penal Code (1860)

Section 302 - The Punishment of Murder

1. Notwithstanding anything in this Chapter, the Supreme Court may, in its discretion, grant

special leave to appeal from any judgment, decree, determination, sentence or order in any

cause or matter passed or made by any court or tribunal in the territory of India.

2. Nothing in clause ( 1 ) shall apply to any judgment, determination, sentence or order

passed

or made by any court or tribunal constituted by or under any law relating to the Armed
Forces.

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 MEMORANDUM ON BEHALF OF RESPONDENTS

STATEMENT OF FACTS

I. BACKGROUND

1. Michael (aged 29) and the deceased, Jenny (aged 24), were residents of Flemingo, a
small town in Pallaka. They were married on February 25, 2008, according to religious
rituals. For the initial years, their marital life was harmonious, with only minor verbal
quarrels that were swiftly reconciled.

2. Following the birth of their daughter, Jennifer, on September 4, 2010, Michael

underwent a drastic behavioural transformation. He exhibited involuntary rudeness and
sudden violence. Seeking professional help, he was treated by psychiatrist Dr. Alfered
(DW1), who diagnosed him with Stage 1 Bipolar Mood Disorder (chronic mental
health condition which causes unusual shifts in mood, energy, and activity). Despite
clinical intervention and medication, the disorder resulted in persistent and
uncontrollable violent episodes.

3. On December 5, 2010, at approximately 11:00 AM, a neighbour, Daniel (PW3),

entered the house after hearing cries and found Jenny unconscious and injured.
Michael was observed in the garden with a 7-inch iron axe. Jenny was immediately
hospitalized under the care of Dr. Andrew (PW2), while Michael was taken into police
custody.

4. Dying Declaration and Demise: On December 6, 2010, Jenny regained consciousness

and provided a statement to Jaison (PW1), SHO of Flemingo Police Station. In this
dying declaration, she stated that Michael had attacked her with an axe after she
resisted his violent behavior. Tragically, on December 8, 2010, Jenny succumbed to a
fatal injury in her lower abdomen. Their daughter Jennifer was subsequently placed in
Government Child Care.

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II. LITIGATION THAT FOLLOWED

1. Following the incident on December 5, 2010, and the subsequent demise of the victim
on December 8, 2010, the Flemingo Police Station initiated a formal investigation
under FIR No. 733/2010 The investigation recovered the weapon of offense, a seven-
inch iron axe from Michael’s garden. Forensic analysis confirmed the presence of the
Michael’s fingerprints on the weapon.

2. During interrogation, Michael consistently maintained that he was in a state of

unconsciousness during the attack. He stated that upon regaining his faculties, he
found himself holding the axe with no memory of how the axe appeared in his hand or
how Jenny died. Upon the completion of the investigation, Final Report was submitted
on 3 Feb 2011, in which Michael was charged for Murder of Jenny under Section 302
of IPC.

3. The case was tried by the Sessions Court vide Session Trial No.-57/2011. On
September 3, 2014, the Court found Michael guilty of Jenny’s murder. Finding a lack
of sufficient evidence for "legal insanity," the Court convicted Michael under Section
302 IPC and sentenced him to 10 years of Rigorous Imprisonment

4. Aggrieved, Michael appealed to the High Court of Pallaka vide Criminal Appeal No.
875/2014. On September 5, 2016, the High Court overturned the conviction. Relying
on the expert testimony of Dr. Alfered (DW1), the Court determined that Michael was
suffering from both medical and legal insanity at the time of the act, thereby qualifying
for protection under Section 84 of the IPC.

5. Seeking to reinstate the conviction, the State of Pallaka preferred an appeal before the
Hon’ble Supreme Court of Amphissa on November 17, 2016. The State challenges the
High Court’s acquittal, questioning the standard of proof required to establish legal
insanity and whether the Respondent’s behavior truly met the criteria under Section 84
of IPC.

6. The Issues laid down before the Hon’ble Supreme Court for further adjudication are:

1. Whether sufficient ground of legal insanity exists so as to exonerate the accused

from liability of murder.

2. Whether the burden of proof of legal insanity on the part of Defence is at par with
burden of proof on part of Prosecution

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 MEMORANDUM ON BEHALF OF RESPONDENTS

STATEMENT OF ISSUES

That the Hon’ble Supreme Court has agreed to hear the appeal and thus
has framed the following issues for adjudication:

ISSUE.1.

WHETHER SUFFICIENT GROUND OF LEGAL INSANITY EXISTS SO AS TO

EXONERATE THE ACCUSED FROM LIABILITY OF MURDER.

ISSUE.2

WHETHER THE BURDEN OF PROOF OF LEGAL INSANITY ON THE PART OF

DEFENCE IS AT PAR WITH BURDEN OF PROOF ON PART OF
PROSECUTION.

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SUMMARY OF ARGUMENTS

ISSUE 1: WHETHER SUFFICIENT GROUND OF LEGAL INSANITY EXISTS SO

AS TO EXONERATE THE ACCUSED FROM LIABILITY OF MURDER.

That it is most humbly submitted that the High Court of Pallaka was correct in its
determination that Michael’s cognitive faculties were entirely eclipsed by Bipolar Mood
Disorder at the time of the incident, satisfying the requirements of Section 84 IPC. While
determining legal insanity, the court must look at the conduct of the accused before, during,
and after the incident. Michael was clinically diagnosed with Bipolar Mood Disorder and was
on medication. Michael claims a state of "unconsciousness," a cognitive blackout consistent
with a severe manic or depressive episode. Michael remained at the scene, confused, without
the typical mens rea (guilty mind) seen in a cold-blooded murderer. The medical testimony of
DW1 (Dr. Alfered) confirms that the Respondent's disorder was "sufficient to enable a person
to do any violent act under its influence," bridging the gap between a medical diagnosis and
legal incapacity. Michael and Jenny’s marriage was "smooth" for years; the sudden violence
without a "petty issue" (as stated in the facts) points toward a diseased mind rather than a
criminal one.

ISSUE 2: WHETHER THE BURDEN OF PROOF OF LEGAL INSANITY ON THE

PART OF DEFENCE IS AT PAR WITH BURDEN OF PROOF ON PART OF
PROSECUTION.

The Respondent contends that the law creates a clear distinction between the "Standard of
Proof" required by the Prosecution and that required by the accused. The Respondent only
needs to prove his insanity through a "preponderance of probabilities." In Vijayee Singh v.
State of U.P. (1990)1 and T.N. Lakshmaiah v. State of Karnataka (2001)2, it was held that if
the evidence adduced by the accused is sufficient to create a reasonable doubt in the mind of
the judge as to the accused's state of mind, the accused is entitled to the benefit of the doubt.
The medical records and the testimony of DW1 (Dr. Alfred) and DW2(Matthew) more than
satisfy this "reasonable doubt" threshold. As noted in Kamla Singh v. The State (1954)3 and
Surendra Mishra v. State of Jharkhand (2011)4, an insane person may act on impulse or
exhibit disorganized behaviour that mimics "hiding" without actually understanding the legal
consequences of the act. Given the diagnosis of Bipolar Disorder, this act was a symptom of a
confused state, not a calculated criminal cover-up.

1
Vijayee Singh v. State of Uttar Pradesh, (1990) 3 SCC 190
2
T.N. Lakshmaiah v. State of Karnataka, (2002) 1 SCC 219
3
Kamla Singh v. The State, (1954) AIR 1992 SC 374
4
Surendra Mishra v. State of Jharkhand, (2011) 11 SCC 495

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 MEMORANDUM ON BEHALF OF RESPONDENTS

ADVANCED ARGUMENTS

I. WHETHER SUFFICIENT GROUND OF LEGAL INSANITY EXISTS SO

AS TO EXONERATE THE ACCUSED FROM LIABILITY OF MURDER

MOST RESPECTFULLY SHOWETH:

1. That it is most humbly submitted before this Hon’ble Court that the present case
constitutes a deeply compelling instance wherein the accused, Michael, was suffering
from a severe and clinically recognized mental disorder, namely Bipolar Mood
Disorder, which had, over a significant period of time, substantially impaired his
cognitive faculties, emotional stability, and volitional control, and such impairment
must not be assessed in isolation but rather in the broader factual matrix of his
progressively deteriorating mental condition following the birth of his daughter
Jennifer, during which period his personality underwent a profound and alarming
transformation from that of a rational, composed, and affectionate husband into an
individual marked by extreme emotional volatility, irrational aggression, and a
demonstrable inability to regulate his actions in accordance with reason or social
norms.

2. That it is further submitted that the legal standard embodied under Section 84 of the
Indian Penal Code does not necessitate a complete obliteration of reasoning capacity,
but rather requires such a degree of impairment wherein the accused is rendered
incapable of knowing either the nature of the act committed or that what he is doing is
wrong or contrary to law, and this principle has been authoritatively and consistently
upheld by the Hon’ble Supreme Court in Dahyabhai Chhaganbhai Thakkar v. State of
Gujarat(1964)5, wherein it was categorically held that if the evidence placed before
the Court gives rise to a reasonable doubt regarding the mental condition of the
accused at the time of the commission of the act, such doubt must necessarily enure to
the benefit of the accused.

3. That in the present case, the medical testimony of Dr. Alfred (DW1), who had been
treating Michael for a considerable duration, clearly establishes that Bipolar Mood
Disorder is not merely a superficial or mild psychological condition but is capable of
producing acute manic episodes characterized by heightened impulsivity, severe
disorientation, impaired judgment, and a significant loss of self-control, during which
the individual may act in a manner that is entirely disconnected from rational thought
and conscious awareness, thereby bringing the case squarely within the ambit of legal
insanity as contemplated under Section 84 IPC.

5
Dahyabhai Chhaganbhai Thakkar v. State of Gujarat, AIR 1964 SC 1563

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4. That the behavioral history of Michael, which has been consistently corroborated
through witness testimony, reveals a persistent and escalating pattern of abnormal
conduct, including sudden and unprovoked outbursts of violence, irrational anger over
trivial matters, and an inability to exercise restraint even in ordinary domestic
interactions, all of which represent a marked and undeniable deviation from his earlier
disposition, thereby strongly indicating that his actions at the relevant time were not
guided by conscious reasoning but were instead the product of a severely impaired
mental state.

5. That it is of utmost importance to appreciate that the incident dated 5th December
2010 cannot be viewed as an isolated occurrence detached from its psychological
context, but must instead be understood as the culmination of a prolonged period of
mental deterioration, and the fact that Michael has consistently maintained that he
regained awareness only after the incident, with no recollection of the events that
transpired, is entirely consistent with medically recognized dissociative states often
associated with severe bipolar episodes, wherein an individual may engage in acts
without conscious volition or subsequent memory, thereby fundamentally negating
the existence of mens rea.

6. That the Hon’ble Supreme Court in Surendra Mishra v. State of Jharkhand(2011)4,

has emphatically reiterated that the crucial point of determination in cases involving
the plea of insanity is the mental condition of the accused at the exact time of the
commission of the offence, and where the evidence, whether direct or circumstantial,
raises a reasonable doubt in this regard, the benefit must necessarily be extended to
the accused, which principle applies with full force to the present case.

II. WHETHER THE BURDEN OF PROOF OF LEGAL INSANITY ON THE

PART OF DEFENCE IS AT PAR WITH BURDEN OF PROOF ON PART
OF PROSECUTION

MOST RESPECTFULLY SHOWETH:

7. That it is most humbly submitted that the burden of proof resting upon the defence
under Section 105 of the Indian Evidence Act is fundamentally distinct from that
borne by the prosecution, inasmuch as while the prosecution is obligated to establish
the guilt of the accused beyond all reasonable doubt, the accused is merely required to
establish the existence of circumstances bringing his case within the ambit of Section
84 IPC on the touchstone of preponderance of probabilities, which represents a
significantly lower and more attainable standard of proof.

4
Surendra Mishra v. State of Jharkhand, (2011) 11 SCC 495

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8. That this well-settled principle has been authoritatively reaffirmed by the Hon’ble
Supreme Court in State of Rajasthan v. Shera Ram(2012)6, wherein it was held that
even if the accused succeeds in creating a reasonable doubt in the mind of the Court
regarding his mental condition at the time of the offence, such doubt must operate in
his favour, thereby entitling him to the protection under Section 84 IPC.

9. That in the present case, the defence has not merely created a speculative or
superficial doubt but has established, through cogent medical testimony and
corroborative evidence of abnormal behavior, a strong and compelling probability that
Michael was suffering from such a degree of mental impairment at the relevant time
as to render him incapable of understanding the nature or consequences of his actions.

III. WHETHER THE HIGH COURT RIGHTLY APPRECIATED THE

EVIDENCE AND ACQUITTED THE ACCUSED

MOST RESPECTFULLY SHOWETH:

10. That it is most respectfully submitted that the Hon’ble High Court of Pallaka acted
within the bounds of sound judicial reasoning and established legal principles in
acquitting Michael, as it correctly appreciated the nuanced distinction between
medical insanity and legal insanity and evaluated the evidence on record in a holistic
and context-sensitive manner.

11. That the High Court accorded due weightage to the expert medical testimony of Dr.
Alfred, recognizing that mental disorders such as Bipolar Mood Disorder cannot be
assessed through rigid or mechanical legal standards, but require a sensitive and
informed understanding of psychiatric realities, particularly when the accused had a
documented history of treatment and exhibited clear symptoms of mental instability
prior to the incident.

12. That the absence of any discernible motive or evidence of premeditation on the part of
Michael further strengthens the conclusion that the act in question was not the result
of a conscious and deliberate intention to cause death, but rather occurred during an
uncontrollable episode of mental disturbance.

6
State of Rajasthan v. Shera Ram, (2012) 1 SCC 602
602
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 MEMORANDUM ON BEHALF OF RESPONDENTS

IV. WHETHER THE CONDUCT AND SURROUNDING

CIRCUMSTANCES NEGATE THE EXISTENCE OF MENS REA

MOST RESPECTFULLY SHOWETH:

13. That it is most humbly submitted that mens rea, being the foundational element of the
offence of murder under Section 300 IPC, is conspicuously absent in the present case,
as the actions of Michael were not guided by intention or knowledge but were instead
the direct consequence of a severe mental breakdown which had rendered him
incapable of understanding the nature and consequences of his actions.

14. That in Hari Singh Gond v. State of Madhya Pradesh(2008)7, the Hon’ble Supreme
Court categorically held that the mere commission of a violent or even brutal act does
not, in itself, negate the plea of insanity, provided that it is established that the
accused was incapable of understanding the nature of the act at the relevant time.

15. That the prosecution’s reliance on the alleged act of concealing the weapon as
indicative of a guilty mind is misplaced and legally unsustainable, as such conduct
can equally be attributed to confusion, panic, or disorientation, particularly in a person
suffering from a severe mental disorder, and cannot be conclusively interpreted as
evidence of conscious wrongdoing.

V. WHETHER THE PROXIMITY BETWEEN THE MENTAL DISORDER

AND THE ACT HAS BEEN ESTABLISHED

MOST RESPECTFULLY SHOWETH:

16. That it is most humbly submitted that the defence has successfully established a clear
and direct nexus between the mental disorder suffered by Michael and the act
committed, inasmuch as the incident occurred during a period when his condition had
significantly worsened and his behavior had become increasingly erratic and
uncontrollable.

17. That the absence of any rational or comprehensible motive for the sudden and
extreme nature of the violence further reinforces the inference that the act was not the
result of a conscious or deliberate decision, but was instead the product of an
uncontrolled mental episode.

7
Hari Singh Gond v. State of Madhya Pradesh, (2008) 16 SCC 109

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 MEMORANDUM ON BEHALF OF RESPONDENTS

18. That the principle that the existence of insanity must be assessed at the precise
moment of the act has been consistently reiterated by the Hon’ble Supreme Court,
including in Surendra Mishra v. State of Jharkhand(2011)4, and the facts of the
present case clearly satisfy this requirement.

VI. WHETHER THE DEFENCE OF INSANITY HAS BEEN RIGHTLY

INVOKED AND NOT MISUSED

MOST RESPECTFULLY SHOWETH:

19. That it is most humbly submitted that the defence of insanity raised by Michael is
genuine, bona fide, and supported by credible and substantive evidence, and cannot be
dismissed as a mere afterthought or a stratagem to evade criminal liability.

20. That in Bapu @ Gajraj Singh v. State of Rajasthan(2007)8, the Hon’ble Supreme
Court observed that where evidence indicates the possibility of insanity, the courts
must exercise caution and extend the benefit to the accused rather than adopt a rigid
or overly technical approach.

VII. WHETHER THE PROSECUTION HAS FAILED TO ESTABLISH AN

UNBROKEN CHAIN OF EVIDENCE EXCLUDING THE HYPOTHESIS
OF INSANITY

MOST RESPECTFULLY SHOWETH:

21. That it is most humbly submitted that while the prosecution may have succeeded in
establishing the physical act leading to the death of Jenny, it has failed to conclusively
establish that such act was accompanied by the requisite mens rea, and has further
failed to exclude the reasonable hypothesis that the act was committed under a state of
legal insanity.

4
Surendra Mishra v. State of Jharkhand, (2011) 11 SCC 495
8
Bapu @ Gajraj Singh v. State of Rajasthan, (2007) 8 SCC 66

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22. That in Sharad Birdhichand Sarda v. State of Maharashtra(1984)9, it was

authoritatively held that the chain of circumstantial evidence must be so complete as
to exclude every possible hypothesis except that of guilt, and in the present case, the
hypothesis of insanity remains not only plausible but strongly supported by evidence.

VIII. WHETHER THE INTERESTS OF JUSTICE SUPPORT THE

ACQUITTAL OF MICHAEL

MOST RESPECTFULLY SHOWETH:

23. That it is most humbly submitted that the acquittal of Michael by the Hon’ble High
Court is fully consistent with the fundamental principles of criminal jurisprudence,
which mandate that criminal liability must be predicated upon the existence of a
guilty mind, and where such mental element is absent due to insanity, the law must
necessarily extend its protection to the accused.

24. That punishing an individual who was incapable of understanding the nature or
consequences of his actions at the time of the offence would not only be contrary to
established legal principles but would also defeat the humanitarian and reformative
objectives underlying Section 84 IPC.

25. That even in cases involving grave and tragic consequences, such as the unfortunate
death of Jenny, the Hon’ble Supreme Court in Virsa Singh v. State of Punjab(1958)10,
has emphasized the indispensability of establishing intention, which in the present
case stands vitiated due to the mental condition of the accused.

26. That therefore, in light of the detailed factual matrix, the medical and behavioral
evidence on record, and the settled principles of law, it is most respectfully submitted
that the acquittal of Michael deserves to be upheld in the interest of justice, equity,
and good conscience.

9
Sharad Birdhichand Sarda v. State of Maharashtra, (1984) 4 SCC 116
10
Virsa Singh v. State of Punjab, AIR 1958 SC 465

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 MEMORANDUM ON BEHALF OF RESPONDENTS

PRAYER

IN LIGHT OF THE ISSUES RAISED, ARGUMENTS ADVANCED, REASONS

GIVEN AND AUTHORITIES CITED, THIS HONOURABLE COURT MAY BE
GRACIOUSLY PLEASED:

1. DISMISS THE PRESENT APPEAL FILED BY THE STATE OF PALLAKA, AND

UPHOLD THE WELL-REASONED JUDGMENT OF THE HON’BLE HIGH COURT
DATED SEPTEMBER 5, 2016, THEREBY MAINTAINING THE ACQUITTAL OF THE
RESPONDENT;

2. RECOGNIZE THAT THE RESPONDENT’S ACTIONS WERE THE

INVOLUNTARY MANIFESTATIONS OF A CLINICALLY PROVEN BIPOLAR MOOD
DISORDER, LACKING THE REQUISITE MENS REA (GUILTY MIND) TO
CONSTITUTE THE OFFENCE OF MURDER UNDER SECTION 300 OF THE INDIAN
PENAL CODE;

3. AFFIRM THAT THE STANDARD OF "PREPONDERANCE OF

PROBABILITIES" HAS BEEN DULY MET BY THE DEFENSE, AND THAT THE
PROTECTION OF SECTION 84 OF THE INDIAN PENAL CODE IS RIGHTFULLY
EXTENDED TO THE RESPONDENT TO PREVENT A MISCARRIAGE OF JUSTICE;

4. DIRECT, IF DEEMED NECESSARY BY THIS HON’BLE COURT, THAT THE

RESPONDENT CONTINUE TO RECEIVE APPROPRIATE PSYCHIATRIC
TREATMENT AND MEDICAL SUPERVISION TO ENSURE HIS REHABILITATION
AND THE SAFETY OF THE COMMUNITY.

AND/ OR

GRANT ANY OTHER RELIEF THAT THIS HON’BLE COURT MAY BE PLEASED

TO GRANT IN THE INTEREST OF JUSTICE, EQUITY AND GOOD CONSCIENCE.

ALL OF WHICH IS RESPECTFULLY PRAYED BEFORE YOUR LORDSHIPS

AND FOR THE KIND ACT OF WHICH THE RESPONDENTS WILL EVER BE

DUTYBOUND TO PRAY.
Sd/-

(Counsel on behalf of respondents)

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