CRIMINAL APPEAL MOOT COURT PREPOSITION
CRIMINAL APPEAL NO. /2024
SAMEERA ............................................................................ APPELLANT
vs
STATE .................................................................................... RESPONDENT
On Submission To The Registry Of The Court Of The Hon'ble Supreme Court Of India
STATEMENT OF JUSRISDICTION
THE COUNSEL ON BEHALF OF THE RESPONDENT, IN THE MATTER, HEREBY, MOST HUMBLY AND RESPECTFULLY SUBMITS TO THE JURISDICTION OF THE HON’BLE SUPREME COURT OF INDIA UNDER ARTICLE 134 OF THE CONSTITUTION OF INDIA, SECTION 374(1) AND SECTION 379 OF THE CODE OF CRIMINAL PROCEDURE, 1973.
STATEMENT OF FACTS
- On 23.10.2016, Jay and Sameera got married in South Mumbai in an arrange marriage system.
- Within two years, Sameera gave birth to a boy with special need which led to increase their expenses because of the treatment of the child.
- Due to mismanagement in financial expenditure of the family, Jay due to the stress started drinking alcohol which led to quarrels and arguments every day.
- Sameera hid this situation for almost 6 months after conceiving baby from her parents and in – laws in the hope of improvement.
- On 02.01.2019, Jay after drinking too much came home and started beating Sameera leaving her with several injuries.
- After that Sameera told everything to her parents and in – laws about the situation and they made Jay to promise to quit drinking and focus on his family.
- But Jay again started drinking in 2021 which led to the fights, aggressive arguments and physical quarrels between the couple again.
- On 21.03.2022, Jay when came back home as usual started beating Sameera and continued till 11:00 pm and after that he went to sleep in his bedroom. But Sameera was not to sleep and she wept whole night on her situation.
- On 22.03.2022, around 4 am in the morning, she took an iron rod and inflicted some injuries on Jay’s head and vital parts which result in death of Jay.
- On the same day, around 8:00 am, her maid came and called the police. The police arrested Sameera and case filed against her.
- The Sessions Court held Sameera liable for culpable homicide due to her act under grave and sudden provocation. But the High Court convicted Sameera for murder.
ISSUES RAISED
- ISSUE 1 - WHETHER THE APPELLANT IS LIABLE FOR MURDER OR CULPABLE HOMICIDE?
- ISSUE 2 - WHETHER THE APPELLANT’S ACTIONS TO CAUSE DEATH OF THE DECEASED QUALIFY AS GRAVE AND SUDDEN PROVOCATION UNDER SECTION 300 OF IPC?
- ISSUE 3 - WHETHER THE APPELLANT ACTED IN SELF-DEFENCE, OR IN THE DEFENCE OF HER CHILD WHICH WOULD MITIGATE HER LIABILITY?
- ISSUE 4 - WHETHER THE ONGOING ABUSE, TRAUMA, AND PSYCHOLOGICAL STRESS IMPAIR THE APPELLANT’S JUDGEMENT TO THE EXTENT THAT IT NEGATED INTENT TO KILL?
SUMMARY OF ARGUMENTS
ISSUE –I: WHETHER THE APPELLANT IS LIABLE FOR MURDER OR CULPABLE HOMICIDE?
It is humbly submitted before the Hon’ble Supreme Court of India that the actions taken by the appellant were premeditated given the time taken to procure the iron rod and inflict fatal injuries on the head and vital parts of the body of the deceased which resulted in the death of the deceased falls under Section 302 or not be considered as a matter of culpable homicide.
ISSUE-II: WHETHER THE APPELLANT’S ACTIONS TO CAUSE DEATH OF THE DECEASED QUALIFY AS GRAVE AND SUDDEN PROVOCATION UNDER SECTION 300 OF IPC?
It is humbly submitted before the Hon’ble Supreme Court of India that the level of provocation was not sufficient to justify the extreme response of murder. The actions taken by the appellant were premeditated given the time taken to procure the iron rod and inflict fatal injuries which resulted in the death of the deceased falls under Section 302; not under grave and sudden provocation under Section 300 of Indian Penal Code, 1860.
ISSUE-III: WHETHER THE APPELLANT ACTED IN SELF-DEFENCE, OR IN THE DEFENCE OF HER CHILD WHICH WOULD MITIGATE HER LIABILITY?
It is humbly submitted before the Hon’ble Supreme Court of India that the immediate threat had subsided once the deceased fell asleep, thereby negating her claim of self – defence. The actions of the appellant clearly postulate her intention to kill the victim and were all premeditated rather than reactive.
ISSUE IV: WHETHER THE ONGOING ABUSE, TRAUMA, AND PSYCHOLOGICAL STRESS IMPAIR THE APPELLANT’S JUDGEMENT TO THE EXTENT THAT IT NEGATED INTENT TO KILL?
It is humbly submitted before the Hon’ble Supreme Court of India that there was a gap between the last incident of violence and the fatal act, that the appellant had time to cool off and consider her actions. While the appellant experienced domestic violence, it does not legally justify the act of murder. The law must maintain a standard against taking the law into one’s own hands.
ARGUMENTS ADVANCED
ISSUE–I: WHETHER THE APPELLANT IS LIABLE FOR MURDER OR
CULPABLE HOMICIDE?
It is humbly submitted before the Hon’ble Supreme Court of India that the actions taken by
the appellant were premeditated given the time taken to procure the iron rod and inflict fatal
injuries on the head and vital parts of the body of the deceased which resulted in the death of
the deceased falls under Section 302 of the Indian Penal Code, 1860 or not be considered as a
matter of culpable homicide.
Section 300.Murder – Except in the case hereinafter excepted, culpable homicide is
murder, if the act by which the death is caused is done with the intention of causing death,
or –
Secondly – If it is done with the intention of causing such bodily injury as the offender
knows to be likely to cause the death of the person to whom the harm is caused, or –
Thirdly – If it is done with the intention of causing bodily injury to any person and the
bodily injury intended to be inflicted is sufficient in the ordinary course of nature to cause
death, or –
Fourthly – If the person committing the act knows that it is so imminently dangerous that
it must, in all probability, cause death or such bodily injury as is likely to cause death, and
commits such act without any excuse for incurring the risk of causing death or such injury
as aforesaid.
Exception 1 – When culpable homicide is not murder – Culpable homicide is not murder if
the offender, whilst deprived of the power of self-control by grave and sudden provocation,
causes the death of any other person who gave the provocation or causes the death of any
other person by mistake or accident.
The above exception is subject to the following provisos:-
First – That the provocation is not sought or voluntarily provoked by the offender as an
excuse for killing or doing harm to any person.
Secondly – That the provocation is not given by anything done in obedience to the law, or
by a public servant in the lawful exercise of the powers of such public servant.
Thirdly – That the provocation is not given by anything done in the lawful exercise of the
right of private defence.
Explanation – Whether the provocation was grave and sudden enough to prevent the
offence from amounting to murder is a question of fact.
Exception 2 – Culpable homicide is not murder if the offender, in the exercise in good faith
of the right of private defence of person or property, exceeds the power given to him by law
and causes the death of the person against whom he is exercising such right of defence
without premeditation, and without any intention of doing more harm than is necessary for
the purpose of such defence.
Exception 3 – Culpable homicide is not murder if the offender, being a public servant or
aiding a public servant acting for the advancement of public justice, exceeds the powers
given to him by law, and causes death by doing an act which he, in good faith, believes to
be lawful and necessary for the due discharge of his duty as such public servant and
without ill-well towards the person whose death is caused.
Exception 4 – Culpable homicide is not murder if it is committed without premeditation in
a sudden fight in the heal of passion upon a sudden quarrel and without the offender
having taken undue advantage or acted in a cruel or unusual manner.
Explanation – It is immaterial in such cases which party offers the provocation or commits
the first assault.
Exception 5 – Culpable homicide is not murder when the person whose death is caused,
being above the age of eighteen years, suffers death or takes the risk of death with his own
consent.
The first clause of Section 300 stipulates that when an act (including legal omission) is done
with the intention of causing death, then it is culpable homicide amounting to murder.
Intention to cause death can be inferred from the act.
CHAHAT KHAN v. STATE OF HARYANA (AIR 1972 SC 2574)
“In this case, it was stated that since intention is always a state of mind, it can be
proved only by its external manifestations. When injuries are inflicted on vital parts of
the body, then the intention to kill can be attributed to the offender.”
Therefore, in the present case, the appellant inflicted injuries on the head and vital parts of the
body of the deceased with an iron rod which resulted in the on the spot death of the deceased.
From the actions of appellant it can be gathered that it is done with the intention to kill the
deceased then and there.
Clause 3 of Section 300 consists of two parts. Under the first part, it has to be shown that
there was an intention to inflict the particular injury. The second part requires that the injury
intended to be inflicted was sufficient in the ordinary course of nature to cause death.
VIRSA SINGH v. STATE OF PUNJAB (1958 AIR 465, 1958 SCR)
The SC laid down that in order to bring a case within clause (3) of Section 300, the
prosecution must prove the following:
1) It must establish, quite objectively, that a bodily injury is present.
2) The nature of the injury must be proved.
3) It must be proved that there was an intention to inflict that particular bodily
injury, that is to say, it was not accidental or unintentional, or some other kind
of injury was intended.
4) It must be proved that the injury of the type just described made up of the
three elements set out above, is sufficient to cause death in the ordinary course
of nature.
In the present case, the appellant has inflicted injuries on the head and vital body parts which
are so serious and grave resulted in on the spot death of the deceased. So, it is sufficient to
know the intention of the appellant to kill the deceased by inflicting such kind of serious
injuries with an iron rod while the deceased was sleeping.
STATE OF ANDHRA PRADESH v. RAYAAVARAPU PUAYYA (1977 AIR 45)
In this case, the SC stated that the term “sufficiency” used in Clause 3 of Section 300
is the high probability of death in the ordinary course of nature, and if such
“sufficiency” exists and death is caused and the injury causing it is intentional, the
case falls under clause 3 of Section 300.
In the present case, the injuries inflicted on the head and vital body parts with an iron rod are
sufficient in the ordinary course of nature to cause the death of a person who was not in
senses at that time because the deceased was sleeping.
SHANKAR NARAYAN BHADOLKAR v. STATE OF MAHARASHTRA (AIR 2004 SC 1966)
The Supreme Court here stated that “For cases to fall within clause (3), it is not
necessary that the offender intended to cause death, so long as the death ensues from
the intentional bodily injury or injuries sufficient to cause death in the ordinary course
of nature.
Therefore, it can be stated that even if the appellant has no intention to cause the death of the
deceased, but the injuries inflicted on head and vital body parts of the deceased; also in the
condition that he cannot be able to safe himself can be considered as sufficient in the ordinary
course of nature to cause death.
ISSUE-II: WHETHER THE APPELLANT’S ACTIONS TO CAUSE DEATH OF
THE DECEASED QUALIFY AS GRAVE AND SUDDEN PROVOCATION
UNDER SECTION 300 OF IPC?
It is humbly submitted before the Hon’ble Supreme Court of India that the level of
provocation was not sufficient to justify the extreme response of murder. The actions taken
by the appellant were premeditated given the time taken to procure the iron rod and inflict
fatal injuries which resulted in the death of the deceased falls under Section 302; not under
grave and sudden provocation under Section 300 of Indian Penal Code, 1860.
Section 300.Murder
Exception1. – When culpable homicide is not murder. – Culpable homicide is not murder
if the offender, whilst deprived of the power of self – control by grave and sudden
provocation, causes the death of the person who gave the provocation or causes the death
of any other person by mistake or accident.
The above exception is subject to the following provisos:-
First – That the provocation is not sought or voluntarily provoked by the offender as an
excuse for killing or doing harm to any person.
Secondly – That the provocation is not given by anything done in obedience to the law, or
by a public servant in the lawful exercise of the powers of such public servant.
Thirdly – That the provocation is not given by anything done in the lawful exercise of the
right of private defence.
Explanation – Whether the provocation was grave and sudden enough to prevent the
offence from amounting to murder is a question of fact.
In order to apply this exception, the provocation should be both grave and sudden. If the
provocation is sudden but not grave, or grave but nor sudden, then the offender cannot avail
of the benefit of this exception. It should also be shown that the provocation was of such a
nature that the offender was deprived of the power of self – control.
BD KHUNTE v. UOI (AIR 1962 SC 605)
In this case, the SC stated that “Grave provocation” within the meaning of Exception
1 to Section 300 is a provocation where judgement and reason take leave of the
offender and violent passion takes over.
SUKHLAL SARKAR v. UOI (2012 SC)
In this case, the SC stated that the word “Sudden” in Exception 1 of Section 300
means an action which must be quick and unexpected so far as to provoke the
accused.
Therefore, from the above stated points and cases cited, it is clear that the exception of grave
and sudden provocation claimed by the appellant is not correct. As the meaning of grave and
sudden provocation does not fit in the actions taken by the appellant in the present case.
K.M. NANAVATI v. STATE OF MAHARASHTRA (1962 AIR)
In this case, the SC laid down the following postulates relating to grave and sudden
provocation:
1) The test of “grave and sudden” provocation is whether a reasonable man,
belonging to the same class of society as the accused, placed in the situation in
which the accused was placed, would be so provoked as to lose his self –
control.
2) In India, words and gestures may also, under certain circumstances, cause
grave and sudden provocation to an accused, so as to bring his act within the
first exception to section 300, IPC.
3) The mental background created by the previous act of the victim may be taken
into consideration in ascertaining whether the subsequent act caused grave and
sudden provocation for committing the offence.
4) The fatal blow should be clearly traced to the influence of passion arising from
that provocation and not after the passion has cooled down by lapse of time, or
otherwise giving room and scope for premeditation and calculation.
The Supreme Court held that the accused, after his wife confessed to her illicit
relationship with the deceased, may momentarily lost control. He had thereafter
dropped his wife and children at a cinema, went to the ship, collected the revolver, did some official business there, and drove his car to the office of the deceased
and later to his home. Three hours had lapsed by then and therefore, there was
sufficient time for him to regain his self – control. In view of this, the court held
that the provisions of Exception 1 to section 300 were not attracted. The accused
was convicted for murder and sentenced to life imprisonment.
Thus, it is evident from the landmark judgement cited that when there is a cooling period in
which there is sufficient time for the accused to regain self – control. Therefore, the appellant
in the present case also has the time around 4 – 5 hours to gain self – control because the
beating ended at 11:00 pm and the appellant killed the deceased at 4:00 am the next morning.
R v. DUFFY (1965)
In this case, the test was laid down by Lord Devlin that the requirement of ‘sudden
and grave’ does not allow for the defence to succeed if there is a lapse of time
between the provocation and killing.
Therefore, in the present case there is enough lapse of time between the provocation given by
beating of appellant and killing of the deceased. So, according to the case cited above, the
present case does not fall under the exception of grave and sudden provocation.
R v. AHLUWALIA (1992)
In this case, the Court rejected the defence of provocation because there was a cooling
period, lapse in time between provocation and killing.
So, as per the above cited case also, when there is a time gap between provocation and killing
that is considered as cooling period, then it does not comes under the purview of grave and
sudden provocation. And in the present case, there is also a cooling period between the
provocation and killing, so the appellant is not liable for culpable homicide but murder of the
deceased under Section 300 of IPC.
YATENDRASINGH AJABSINGH v. STATE OF MAHARASHTRA (2022)
In this case, the SC reiterated that to determine whether or not a certain act constitutes
provocation of the requisite nature, the facts and circumstances of each case must be analyzed. It is essential to note that the graveness and suddenness of the provocation
must both be simultaneous. This implies that –
Firstly, the provocation must not only be grave but also sudden, and that it must be
uninvited and unforeseen;
Secondly, the act of the accused must be derived from the provocation of such nature.
So, from the judgement cited above and taking in consideration the present case; it can be
stated that the act of the appellant was not derived from the provocation as it can be grave but
not sudden; graveness and suddenness must be simultaneous; which does not fit in this case.
ISSUE-III: WHETHER THE APPELLANT ACTED IN SELF – DEFENCE, OR IN
THE DEFENCE OF HER CHILD WHICH WOULD MITIGATE HER
LIABILITY?
It is humbly submitted before the Hon’ble Supreme Court of India that the immediate threat
had subsided once the deceased fell asleep, thereby negating her claim of self – defence. The
actions of the appellant clearly postulate her intention to kill the deceased and were all premeditated rather than reactive.
SECTION 300.MURDER
EXCEPTION 2 – Culpable homicide is not murder if the offender, in the exercise in good
faith of the right of private defence of person or property, exceeds the power given to him
by law and causes the death of the person against whom he is exercising such right of
defence without premeditation, and without any intention of doing more harm than is
necessary for the purpose of such defence.
The Exception 2 to Section 300 stipulates that the exceeding of the right of private defence
should be without pre-meditation, and without any intention of doing more harm than
necessary for the purpose of coverage by the exception. In other words, the exceeding of
private defence by the accused should be done unintentionally. Only then can the accused
avail of the exception provided under this clause.
ONKARNATH SINGH v. STATE OF UTTAR PRADESH (1974 AIR)
In this case, the deceased party has initially attempted to attack the accused party.
There was an incident of grappling between the parties. When the deceased party was
fleeing, the accused party made a murderous assault. It was held that in this case that
since the murder was committed when the deceased were fleeing, the right of private
defence ended with that, since the right is co-terminus with the commencement and
existence of a reasonable apprehension of danger to body or property and not after the
threat has ceased to exist.
The Supreme Court held that the accused were guilty of vindictive and maliciously
excessive act. The force used was out of all proportion to the supposed danger, which no longer existed from the deceased party. Under the circumstances, it was held that
the accused were neither entitled to a right of private defence, not to the benefit of
Exception 2 to section 300 IPC.
Keeping in view the judgement cited above and the facts of the present case, it can stated that
the killing of deceased by the appellant cannot be considered as an act of private defence
because it was time when the deceased was sleeping peacefully and appellant approached
him with an iron rod and started hitting him on the head directly and vital body parts, it
clearly shows her ill-will to kill the deceased and not any act of self-defence.
KATTU SURENDRA v. STATE OF ANDHRA PRADESH (2008 AIR)
The SC ruled in this case that death caused by a person after his right to private
defence ceases to exist falls outside the ambit of the exception.
Therefore, in the present case, when the deceased went to sleep the right of private defence
ceases to exist for the appellant, therefore the act of the appellant causing death of the
deceased falls outside the ambit of Exception 2 to section 300 IPC.
RAJ SINGH v. STATE OF HARYANA (2015 AIR)
The SC in this case has beautifully articulated the manner of judicial determination of
claim of the accused that he has caused homicide by exceeding his lawful right of
private defence. It observed:
Absence of good faith in the exercise of the right of private defence, premeditation for
the exercise of such right and acts done with the intention of causing more than harm
than is necessary for the purpose of such defence would deny to the offender the
benefit of Exception 2 to section 300.
Considering the present case and judgement above, it can be stated that the appellant had
sufficient time for gaining self-control and the act of causing death of the deceased in the
morning after the time gap of 4-5 hours when he was sleeping. So, it is clear that the actions
of the appellant were premeditated and there was a clear intention of killing the deceased
rather than acting in self-defence.
SINGH & ORS v. STATE OF HARYANA (CRM 2022)
In this case, the SC observed that the exception of good faith is a must before the
accused claims benefit of the Exception 2 to section 300. While acting in good faith,
if the accused has exceeded the right of self-defence and caused death of a person
without pre-meditation and further he had no intention to causing more than was
necessary for the purpose of the defence although in fact more harm was caused, the
benefit of Exception 2 to section 300 may be available if the accused was not the
aggressor.
In the present case, the appellant had not acted in good faith which can be understand from
the actions of appellant to hit and inflict injuries to the deceased on his head first and then
vital body parts which shows that the appellant had full intention to kill the deceased and not
only hurt him. The right of private defence taken by the appellant also cannot be supported as
the act done by her was during the sleeping of deceased. Therefore, while sleeping of the
deceased how the appellant can claim the right of self-defence here and also the deceased had
never cause any kind of hurt to his child. So, the appellant is wrong in taking the right to selfdefence of her and her child.
ISSUE IV: WHETHER THE ONGOING ABUSE, TRAUMA, AND
PSYCHOLOGICAL STRESS IMPAIR THE APPELLANT’S JUDGEMENT TO
THE EXTENT THAT IT NEGATED INTENT TO KILL?
It is humbly submitted before the Hon’ble Supreme Court of India that there was a gap
between the last incident of violence and the fatal act, that the appellant had time to cool off
and consider her actions. While the appellant experienced domestic violence, it does not
legally justify the act of murder. The law must maintain a standard against taking the law into
one’s own hands.
R v. AHLUWALIA (1992)
In this case, the Court stated that women who have been subjected frequently over a
period to violent treatment may react to the final act or words by what he calls a
“slow-burn” reaction rather than by an immediate loss of self-control. We accept that
the subjective element in the defence of provocation would not as a matter of law be
negative simply because of the delayed reaction in such cases, provided that there was
at the time of the killing a “sudden and temporary loss of self-control” caused by the
alleged provocation. However, the longer the delay and the stronger the evidence of
deliberation on the part of the defendant, the more likely it will be that the prosecution
will negative provocation.
So, it can be pointed out from the above judgement cited that when there is time gap between
the provocation and killing; the longer the delay, there are more chances to negate the
provocation. As per in the present case, there are almost 4-5 hours time lapse between the
provocation and killing of the deceased. The time period of 4-5 hours can be considered as
sufficient to re-gain self-control and effect of provocation in such time remains less.
SUSTAINED PROVOCATION
The concept of provocation works very differently in cases of battery as it is a long-term and
continuous process, and it is very difficult to analyse a specific trigger point that resulted in
the commission of the offence. This is a case of sustained provocation. That is why these
cases cannot be measured strictly by the objectivity test, as it goes against the principle of
equity, natural justice, and good conscience.
‘Sustained Provocation Principle’ doesn’t go away with the requirement of immediate or the
final provocative act, words or gesture, the Court noted that cumulative or sustained
provocation test was immediately preceded and precipitated by some sort of provocative
conduct, which would satisfy the requirement of sudden or immediate provocation.
This defence would not be available if there is evidence of reflection or planning as they
mirror exercise of calculation and premeditation, it added.
K.M. NANAVATI v. STATE OF MAHARASHTRA (1962 AIR 605)
The SC relied on a series of notable precedents to draw the inference and held that the
mental background created by the previous act(s) of the deceased may be taken into
consideration in ascertaining whether the subsequent act caused sudden and grave
provocation for committing the offence.
“It referred to wherein the conditions which have to be satisfied to invoke the
exception were defined. It was also held in the judgement that for determining
whether or not the provocation had temporarily deprived the offender from the power
of self-control, the test to be applied is that of a reasonable man and not that of an
unusually excitable and pugnacious individual. Further, it must be considered
whether there was sufficient interval and time to allow the passion to cool.”
In the present case, the appellant had acted after a sufficient time interval and there is enough
time available for her passion to cool down; which does not fall under the criteria provided
the above cited judgement; therefore, the appellant is not right to claim the defence of
sustained provocation in which she had been deprived from the power of self-control.
BUDDHI SINGH v. STATE OF H.P. (2012)
The SC observed that in the test for application of Exception 1 to Section 300 IPC, the
primary obligation of the court is to examine the circumstances from the point of view
of a person of reasonable prudence.
“The idea behind this exception is to exclude the acts of violence which are
premeditated, and not to deny consideration of circumstances such as prior animosity between the deceased and the accused, arising as a result of incidents in the past and
subsequently resulting in sudden and grave provocation.”
Taking in consideration the above cited judgement of the SC, it can be stated that in the
present case, there was not any denial of animosity, instances of domestic violence and abuse
by the deceased; but the final act of the appellant was clearly shown as premeditated which
excluded her from the purview to fall under Exception 1 to Section 300 IPC.
BHURA RAM & ORS. v. STATE OF RAJASTHAN & ANR. (AIR 2008)
The SC reaffirmed in this case that another aspect of the mental state of the accused is
the lack of preparation on their part. The provocation must come unexpectedly; hence,
the provision that the provocation must not be sought by the accused and must not be
expected in any manner.
In the present case, the appellant after the cooling period took an iron rod and hit the
deceased on his head firstly and after that on his vital body parts which resulted in on-the spot
death of the deceased; clearly shows that the provocation did not come unexpectedly and the
appellant had prepared on her part for such act.
PRAYER
WHEREFORE, in light of the facts presented, issues raised, arguments advanced and
authorities cited, the Counsel on Behalf of the Respondent humbly pay before the Hon’ble
Court that it may be pleased to adjudge and declare:
1. Uphold the conviction of the appellant.
2. Liable for the murder of the deceased.
And/Or
Pass any other Order, Direction, or Relief that it may deem fit in the best interests of
Justice, Fairness, Equity and Good Conscience.
FOR THIS ACT OF KINDNESS, THE RESPONDENT SHALL DUTY BOUND
FOREVER PRAY.
All of which is respectfully submitted.
Sd/-
On Behalf Of The Respondent
