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[Cites 14, Cited by 0]

Andhra Pradesh High Court - Amravati

Sri Modugala Venugopala Reddy vs Jayadev Galla on 20 March, 2024

Author: R Raghunandan Rao

Bench: R Raghunandan Rao

APHC010199472019
                       IN THE HIGH COURT OF ANDHRA
                                   PRADESH
                                                           [3206]
                                AT AMARAVATI
                         (Special Original Jurisdiction)
            FRIDAY, THE TWENTIETH DAY OF MARCH
              TWO THOUSAND AND TWENTY FOUR

                              PRESENT

    THE HONOURABLE SRI JUSTICE R RAGHUNANDAN RAO

               ELECTION PETITION NO: 2 of 2019

Between:

Sri Modugala Venugopala Reddy                      ...PETITIONER

                                AND

Jayadev Galla and Others                        ...RESPONDENTS

Counsel for the Petitioner:

  1. SRI V.R.N. PRASANTH

Counsel for the Respondent(S):

  1. SRI B. ADINARAYANA RAO, LEARNED SENIOR COUNSEL
     APPEARING FOR SRI M. BALAJI
  2. SHAIK UMAR BASHA
  3. G V S MEHAR KUMAR
  4. NAGESWARA RAO CHAVA
  5. SHAIK UMAR BASHA
  6. SHAIK UMAR BASHA
  7. SHAIK UMAR BASHA
  8. SHAIK UMAR BASHA

The Court made the following:

      As part of the General Elections, 2019, elections were

conducted for No.13 Guntur Parliamentary Constituency. It may also
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be noted that there were simultaneous elections to the Legislative

Assembly           for   the   State    of    Andhra     Pradesh   also.    Guntur

Parliamentary            Constituency        contained    seven    (7)     Assembly

Constituency             segments      namely,     No.86     Tadikonda,       No.87

Mangalagiri, No.86 Ponnur, No.91 Tenali, No.93 Prattipadu, No.94

Guntur West and No.95 Guntur East. Polling was conducted on

11.04.2019 and the votes were counted on 23.05.2019. The

petitioner along with respondents 1 to 18 had contested this election.

After the votes had been counted, the 1st respondent was declared

elected with a majority of 4,205 votes over the petitioner herein.

      2.           The petitioner herein, being aggrieved by the said result,

has filed the present Election Petition under Section 100(1)(d)(iii) and

(iv) of the Representation of the Peoples Act, 1951 (hereinafter

referred to as „The Act‟). The said provision reads as follows:

      100. Grounds for declaring election to be void. (1) Subject
      to the provisions of sub-section (2) if (the High Court) is of
      opinion--


      (a) .....

      (b) .....

      (c) ....

      (d) that the result of the election, in so far as it concerns a
      returned candidate, has been materially affected__

      (i) ......
                                      3
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                                                                 E.P.2 OF 2019


     (ii) .....

     (iii).....

     (iv) by any non-compliance with the provisions of the
     Constitution or of this Act or of any rules or orders made
     under this Act, (the High Court) shall declare the election of
     the returned candidate to be void.


3.       The relief sought in the Election Petition is as follows:

        A) Declare the election of respondent No.1 as Member

              of parliament from No.13 Guntur Parliament

              Constituency, as null and void;

        B) Pass an order for summoning all 9,782 postal

              ballot papers including ETPBS in No.13 Guntur

              Parliamentary Constituency and to declare the

              result after counting them;

        C) Pass an order for recounting of the votes in No.13

              Guntur Parliament Constituency and to declare the

              result after counting them;

        D) Award costs of the Election Petition;

        E) Pass such other order or direction which the

              Hon‟ble Court may deem fit and proper in the facts

              of the case.
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      4.      The grounds on which the election petitioner relies upon,

in support of the reliefs sought by him are as follows:

      1) 16,977 postal ballots had been issued and 15,084

           postal ballots were polled and counted. Out of these

           ballots, 9,782 postal ballots were rejected and only

           5,317 votes were counted as valid votes. The rejection

           of the aforesaid 9,782 postal ballots is not in

           accordance with Act or the conduct of Election Rules,

           1961 (herein after referred to as „the Rules‟). In view

           of the improper rejection of these ballots, there

           should be a direction to validate these ballots and to

           count them;

      2) About     4,252    employees      of   private   educational

           institutions were originally drafted for election duty

           and had been issued postal ballots as they would not

           be able to exercise their franchise on the day of

           polling. These persons were removed from election

           duty by proceedings dated 02.04.2019. However, the

           postal ballots issued to these employees were not

           taken back nor proper steps taken to ensure that

           these persons do not vote again in the polling held on

           11.04.2019.     Since   these   persons    were   able     to
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exercise their vote twice, the election process has

become vitiated.

3)   After   removing   the    aforesaid   4,252   private

employees from election duty, 1,763 government

employees     were   drafted    for   election   duty    on

09.04.2019 and due to the paucity of time between

09.04.2019 and 11.04.2019, these persons were not

given the option of exercising their franchise by

postal ballots and as such, they could not vote and

the denial of such voting rights materially affects the

election which requires to be set aside;

4) The Act and the Rules provide for certain

procedures to be followed to ensure that all the votes

polled are accounted for and counted on the

counting day and to ensure that there are no

discrepancies between the actual votes polled and

the votes counted. For this purpose, the Act and

Rules have provided for forms known as Form-17A

to Form-17C. The Form 17C consists of two parts. In

the first part, the Polling Officer incharge of every

polling station has to record the number of votes

polled in his polling station and certify the same.
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Copies of part-I of Form 17C has to be given to all

the polling agents of the candidates who are present

in the polling station irrespective of the fact whether

they have asked for such copy or not. Subsequently,

at the time of counting, the person incharge of such

counting has to verify the number of votes counted

in relation to each of the polling stations and record

the number of votes counted against each polling

station. These statistics are to be recorded in part-II

of Form-17C. The Returning Officer, on the basis of

part-II of the Form-17C forms prepares the round

wise statements in the proper proforma known as

Form 20. The statistics in part-I of form-I have to be

in total accord with the statistics in part-II of Form

17C as well as the round wise counting figures in

Form 20. Any variation or any discrepancy either in

the recording of the number of votes polled or

counted or any discrepancy between part-I and part-

II of Form 17C or Form 20 would result in

invalidation of the election process. In the present

case,   there   have   been   various    discrepancies

including, fabrication of Form-17C part-I, incorrect
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            filling   up   of   part-I    of   Form-17C,      absence     of

            signatures     of   polling    officers   etc.,   apart   from

            variation in the figures between part-I and part-II of

            Form 17C. On account of these lacunae, the election

            would have to be declared invalid.

      5.       The 1st respondent filed his counter affidavit denying all

these allegations.     The 1st respondent contended that the rejection of

9,782 postal ballots is strictly in accordance with the provisions of

the Act and the Rules and that the remaining grounds raised by the

petitioner are not tenable for various reasons and that the 1st

respondent had no control over any of the grounds raised by the

petitioner due to which the 1st respondent cannot be held responsible

for such alleged lacunae in the election process.

           6. This Court, after considering the pleadings in the

Election Petition and the counter affidavit of the 1st respondent and

after hearing both sides, by an order dated 27.04.2023, framed the

following issues.

           1) Whether the rejection of postal ballots by the

              Returning     Officer,      on   the    ground    of    non-

              compliance of Rule 54 of the Conduct of Election

              Rules, 1961, is invalid and liable to be set aside?
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2) Whether the issue of alleged non-exercise of

  franchise of 1763 government employees who had

  been drafted for election duty could be gone into,

  without any relief in this regard, being sought in

  the election petition?

3) Whether the issue relating to alleged dual exercise

  of franchise of 4252 private employees, who had

  been initially drafted for election duty, and issued

  postal ballots, after which they had been removed

  from election duty, can be adjudicated without any

  relief being sought in this regard?

4) Whether the question of discrepancy in Form 17

  and Form 20 would vitiate the election of the 1st

  respondent, could be gone into without any such

  relief being sought in the election petition?

5) Whether the discrepancy in Form 17 and Form 20

  would vitiate the election of the 1st respondent as

  pleaded by the election petitioner, in the event of

  the earlier issue being decided in favour of the

  petitioner?
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       6) If the issues in 3 and 5 are held in the affirmative,

          whether the petitioner is entitled for the relief for

          setting aside the election of the 1st respondent

          without seeking such a consequential relief?

       7) Whether the election petitioner was entitled for

          relief of recounting of votes on the grounds pleaded

          by him in the election petition.

       7. The petitioner herein, examined himself as P.W.1 and

marked Exs.P.1 to P.17. The marking of Exhibits P.6 and P8 to P17

were objected on the ground that Ex.P6 is a photo copy and cannot

be marked as primary evidence, Exs.P.8 to P.17 are unattested photo

copies and cannot be marked as primary evidence without a proper

endorsement that they are true copies. The same were marked

subject to objection. No other witnesses were examined by the

petitioner. After cross examination of P.W.1 and closure of the

evidence of the petitioner, the 1st respondent reported that he was

not examining any witnesses. None of the other parties to the

Election Petition have participated in the trial nor sought any

opportunity of cross examination of P.W.1 nor sought to examine

themselves or any other witnesses.
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          8. Sri V.R.N. Prasanth, learned counsel for the petitioner, at

the outset of his arguments, had submitted that the petitioner was

not pressing ground Nos.2 and 3. In view of this submission, issues

2 and 3 do not arise for consideration.

ISSUE NO.1:        "Whether the rejection of postal ballots by the

Returning Officer, on the ground of non-compliance of Rule 54 of the

Conduct of Election Rules, 1961, is invalid and liable to be set

aside"?

          9. Sri V.R.N. Prasanth, contends that postal ballots are

given along with three covers which are being referred to as Form-

13A, Form-13B and Form-13C. A declaration is also given, in Form

13 A, along with the postal ballots. The voter exercising his franchise

through a postal ballot, is expected to make the necessary marking

on the postal ballot and keep the same in the cover marked as Form-

13B. The voter is also required to make a declaration, in form 13 A,

which is to be attested/certified by an appropriate authority. This

declaration is to be kept in the cover marked as Form-13A. These two

covers are to be kept in a cover marked as Form-13C. The manner in

which these postal ballots are to be validated and counted are set out

in the Rules as well as the instructions/guidelines given to the

Returning Officer in the hand book for Returning Officer, issued in

February, 2019. The Rules as well as the guidelines state that Form-
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                                                              E.P.2 OF 2019


13C will be opened first and the two covers namely, Form-13A and

Form-13B are to be taken out at the time of counting of all the votes

polled in the election. Thereafter, the declaration in Form-13A is to

be taken out and checked if it is in accordance with the Rules

including the signature by the elector as well as due attestation by

an officer competent to do so. If the declaration is not found to be in

order, the cover-B, in Form-13B will not be opened and the postal

ballot will stand rejected. If the declaration is found to be in order,

the serial number of the ballot paper in the declaration in Form-13A

is compared with the serial number endorsed on the cover in which

form 13B has been placed. If there is no discrepancy between the

said numbers on Form-13A and Form-13B, the Form-13B cover

would be opened for taking the postal ballot into account and for

further verification of the validity of the postal ballot. However, in the

event of a discrepancy between the serial number of the ballot paper

inscribed on the cover in which form-13B is enclosed and the serial

number of the ballot paper appearing as declaration in Form 13B,

the cover containing Form-13B postal ballot will not be opened and

the postal ballot will stand rejected.

        10.      Sri   V.R.N.   Prasanth    would   contend    that    the

aforesaid 9,782 postal ballots were rejected on the ground that the

cover in which the postal ballot paper in Form-13B was placed did
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                                                            E.P.2 OF 2019


not have any serial number inscribed on the cover. He would

contend that such rejection is invalid in as much as the circular

issued by the Election Commission of India dated 04.10.2016

required the staff of the Returning Officer to fill up the ballot paper

numbers before sending the postal ballot papers to the elector. He

would submit that in such circumstances, the non filling of the serial

number of the ballot paper on the cover containing Form-13B is the

fault of the staff of the Returning Officer and as such, the covers

should have been opened and the ballots should have been counted.

        11.       Sri B. Adinarayana Rao, learned Senior Counsel

appearing for Sri M. Balaji, learned counsel for respondent No.1

would submit that the Rules are very clear in this regard and require

rejection of the postal ballots as the absence of any serial number of

the paper ballot, contained in Form-13B cover would automatically

mean there is a discrepancy between whatever number was available

on the Form-13A declaration. He would further submit that a closer

look at the circular relied upon by the petitioner, would show that

even the circular specifically stipulates that any discrepancy between

the serial number of the ballot paper on Form-13B cover and the

serial number of the ballot in Form-13A declaration would result in

invalidation of the postal ballot.

Consideration of the Court:
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                                                            E.P.2 OF 2019


        12.       The Rules relating to the manner in which postal

ballots are to be issued and counted are contained in Rules 23, 24,

27E and Rule 54-A of the Rules. Apart from this, certain instructions

issued to the Returning Officer, as contained in the hand book for

Returning Officer, issued in February 2019 would be relevant.

Instruction 11.12 and instruction 15.15 are relevant for the purpose

of this case. Rule 23 states that a postal ballot paper is given to the

elector together with a declaration in Form-13A, a cover in Form-

13B, a large cover addressed to the Returning Officer in Form-13C

and instructions to the elector in Form-13D. The elector, who

chooses to exercise his franchise, after receipt of these forms and

covers shall record his vote on the ballot paper, in accordance with

the directions contained in Form-13D and enclose it in a cover

marked as Form-13B. The elector shall also sign a declaration in

Form 13A, in the presence of the appropriate authority set out in

Rule 24(2) and the same would be attested by the said authority.

Rule 27 E and Rule 27 F prescribed the same procedure for notified

electoral personnel.

        13.       Rule 54-A sets out the procedure to be followed for

counting of votes received by post. Rule 54-A (4), which is extracted

below, is relevant for our purposes.

        Rule 54A:
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                                                              E.P.2 OF 2019


        (4) If the said declaration is not found, or has not been
        duly signed and attested, or is otherwise substantially
        defective, or if the serial number of the ballot paper as
        entered in it differs from the serial number endorsed on
        the cover in Form 13B, that cover shall not be opened, and
        after making an appropriate endorsement thereon, the
        returning officer shall reject the ballot paper therein
        contained.

      Instructions 15.15.4.14 reiterates Rule 54-A (4).

      14.          Ex.P3 is the representation of the petitioner, on

23.05.2019 protesting the rejection of the postal ballots. This protest

was rejected by the Returning Officer by an endorsement on Ex.P3.

This endorsement has been marked separately as Ex.P4. The

endorsement records that the postal ballots could not be accepted as

they did not have any serial number of the postal ballot on the Form-

13B cover.

      15.    In view of Rules 23, 24, 27E and Rule 54-A of the Rules

and the instructions contained in the hand book of Returning

Officer, the rejection of the postal ballots is in accord with the

aforesaid Rules.

      16.    It is the contention of the petitioner that the Circular

No.52/ECI/LET/FUNC/JUD/SDR/2016              issued   by   the   Election

Commission of India dated 04.10.2016 casts the duty of filling up of

ballot paper number on the staff of the Returning Officer and as
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                                                                  E.P.2 OF 2019


such, the postal ballots could not have been rejected. Paragraph

Nos.3 & 4 of the circular, which are extracted below are instructed.

           "3. On the aforesaid smaller envelope (Form 13 B), there
           is a column to write the serial number of the ballot
           paper. There are cases where this column is not filled
           up and as a result, the ballot contained in such envelop
           gets rejected at the time of counting of votes.

           4. In order to ensure that the ballot papers do not get
           rejected on this ground, the Commission has directed
           that the aforesaid column, for writing the serial number
           of ballot paper in Form 13B, shall be filled up by the
           returning Officer‟s staff itself before sending the postal
           ballot paper to the elector. The staff entrusted with this
           duty should be instructed to be very careful while filling
           up the serial number so that the serial number is
           entered correctly. In the case of polling staff voting in
           facilitation centre, they should be asked to make sure
           that the serial number of ballot paper is duly entered
           (on Form 13 B), so that rejection of ballot paper on this
           ground is avoided."


     17.     Paragraph No.3 of the circular further elucidates that

non mentioning of the serial number of the ballot paper on the Form-

13B cover would amount to creation of a discrepancy between the

serial number of the ballot paper given in the declaration in Form

13A and the ballot paper number that should have been recorded on

the Form 13B cover. Paragraph No.4 also states that such
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discrepancy would result in rejection of the ballot papers. The said

circular only strengthens the contention of the 1st respondent and

does not assist the petitioner in any manner.

      18.   Accordingly, this issue is answered against the petitioner

and in favour of the 1st respondent.

ISSUES 4 to 7:

      19. These issues are dependent on the question of whether the

said discrepancies in the statistics set out in part-I of Form 17C and

part-II of Form 17C have been demonstrated by the petitioner and

such discrepancies require the setting aside of the election of the 1st

respondent.

      20.   Sri V.R.N. Prasanth, learned counsel for the petitioner

would contend that the petitioner, had pleaded the details of

fabrication and discrepancies in part-I of Form 17C and part-II of

Form 17 C, in paras 24 to 26 of the Election Petition and had further

detailed and explained the discrepancies along with elaborate tables

in paragraph No.25 of the affidavit filed in lieu of chief examination of

P.W.1. He has taken this Court through various forms which have

been marked as Exs.P.11 to P.17 in both part-I and part-II of the

Form 17C as well as in Form 20 to contend that the variation in

these records show a variation of 10,959 votes which are more than
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the difference of 4,205 votes with which the 1st respondent had been

declared as a returned candidate.

      21.    Sri V.R.N. Prasanth, after taking this Court through the

record, relied upon the Judgments of K M. Shradha Devi vs.

Krishna Chandra Pant and Ors, 1A.C. Jose vs. Sivan Pillai and

Ors.,2 M. Chandregouda vs. J. Shantha3 and Ashwani Kumar

Sharma vs. Yaduvansh Singh and Ors.,4 to contend that once an

error is shown in the conduct of election, and especially in terms of

counting of votes, there has to be a recount of votes and further

elaborate proof of all errors is not needed.

      22.    Sri B. Adinarayana Rao, the learned Senior Counsel

appearing for Sri M. Balaji, learned counsel for respondent No.1

would submit that the pleadings in the election petition had pointed

out discrepancies only in relation to two polling stations in detail. He

would submit that there are no specific allegations in relation to any

of the alleged discrepancies in Form 27C part-I and part-II. He would

submit that a bald allegation that there are discrepancies and

dumping      of   all    Forms-27C   certificates   without   any   further

elaboration would not amount to necessary pleadings and statement



1 (1982) 3 SCC 389 (2)
2 (1984) 2 SCC 652
3 2012 SCC Online Kar 8572
4 (1998) 1 SCC 416
                                           18
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of     material    particulars       required   under   Section   83   of   the

Representation of the Peoples Act. He relies upon the Judgments in

Samant N. Balakrishna and another vs George Fernandez and

others5, Kalyan Singh Chouhan vs C.P. Joshi6 and Arikala Narasa

Reddy vs. Venkata Ram Reddy Reddygari and Another 7.

         23.    Sri B. Adinarayana Rao, the learned Senior Counsel

submits that the 17 C forms produced by the petitioner are not

certified copies, as required under Section 65 of the Evidence Act

read with Section 74 and 77 of the Evidence Act. He would further

submit that the contention of the petitioner that these are

documents obtained under the R.T.I. Act would not assist the

petitioner in getting the said documents marked as proper exhibits.

In such circumstances, these cannot be looked into and would have

to be eschewed. He would rely upon Section 2(f) of the R.T.I Act and

Rule 93 of the Election Rules, to contend that Form 17C produced by

the petitioners are not certified copies which can be marked as

exhibits. He also relies upon the judgment of Chief Information

Commissioner vs. High Court of Gujarat and Another8.




5    1969 3 SCC Page 238 (para 29)
6 (2011) 11 SCC 786
7 (2014) 5 SCC 312
8 (2020) 4 SCC 702
                                   19
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     24.   Sri B. Adinarayana Rao, the learned Senior Counsel

would submit that the documents referred to in paragraph 25 of the

Election Petition relate to alleged fabrication of records for polling

stations No.102 and 103 situated in the Zilla Parishad High School,

Etukuru. The discrepancies pointed out in relation to these polling

station is that the part-I of Form 17C register recorded for polling

station No.102 and part-I of Form-17C register recorded for polling

station No.103 are one and the same with no difference except that

the number of the polling station has been corrected from 102 to 103

in the 2nd form. However, no polling officer or agent has been

examined as to the circumstances in which the same presiding

officer is said to have signed both forms in relation to these polling

stations. He would submit that there can be various circumstances

due to which one presiding officer may have been allotted to both the

polling stations especially as they were both situated in the same

premises. He would submit that in the absence of any further

elucidation in relation to these two polling stations nothing further

can be made out on account of this issue.

     25.   Prior to the reply given by Sri V.R.N. Prasanth, Sri Balaji

Medamalli, appearing for the 1st respondent, had also drawn the

attention of this court to the Form 20 prepared by the Returning

Officer which showed that the petitioner had got 242 votes in polling
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                                                             E.P.2 OF 2019


station No.102 while the 1st respondent had only got 155 votes and

that in polling station No.103 the petitioner had polled 76 votes,

while the 1st respondent had polled 87 votes. He would submit that

the voting in these two polling stations was in favour of the petitioner

and no advantage accrued to the 1st respondent on account of any

alleged fabrication of Form 17C, in either of these polling stations.

      26.   Sri V.R.N. Prasanth, in reply to the aforesaid contentions

submits that all the Form 17, marked by P.W.1 had been filed along

with the Election Petition and specific pleadings in relation to these

Form 17C had been set out in para No.24 of the Election Petition. He

would submit that such mention in para No.24 fulfils all the

requirement of necessary pleadings under Section 83 of the Act. He

would further submit that the 1st respondent was fully aware of all

the documents relied upon by the petitioner and was not taken by

surprise to contend that such documents cannot be taken into

account or that they cannot be marked. He would further contend

that the 1st respondent had not disputed the genuineness of these

forms and cannot now seek to challenge the consequences of these

documents by contending that they are not admissible in evidence.

He would also rely upon the Judgments in Dahiben vs Arvindbhai
                                    21
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                                                             E.P.2 OF 2019


Kalyanji Bhanusali9 and Shri Balwan Singh vs. Lakshmi Narain10

to contend that all documents filed with the plaint would have to be

treated to be the part of the plaint and as such would amount to

pleadings by themselves. He would also contend that relying upon

R.M. Seshadri vs. G. Vasantha Pai11 that the 1st respondent was

aware of the forms and the question of the authenticity of documents

would not arise.

Consideration of the Court:

      27.        The question whether the petitioner has been able to

demonstrate various discrepancies between the different forms would

be dependant upon whether such documents are held to be

admissible and proved. Sri B. Adinarayana Rao raises two objections

on this. He contends that the documents are inadmissible as

necessary pleadings have not been set out and secondly, the

documents cannot be admitted as they are not primary or secondary

evidence under the provisions of the Evidence Act,

      28.       It is settled law, that there can be no evidence without

pleading. This requires a decision as to whether necessary facts, for

the purposes of marking and considering the 17C forms, have been

pleaded.

9 (2020) 7 SCC 366 (para 23.8)
10 (1982) 3 SCC 389 (2)
11 (1969) 1 SCC 27
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      29.      The pleadings, in the election petition, in this regard,

are contained in paras 24 to 27. Paragraph 25 and 26 contain

specific pleadings relating to discrepancies in polling station 06, in

Tadikonda assembly constituency and polling stations 102 and 103

in Prathipadu Constituency. The remaining paragraphs 24 and 27

read as follows:

       "24. I submit that in addition to above, on the basis Form
       17C duly completed by counting supervisor, Returning
       Officer will get prepared a round wise statement in the
       following proforma. A copy of the detailed polling station-wise
       breakup of the votes as shown in the said proforma will be
       kept by the Observer in his folder. In addition, on the
       computer installed in the Counting Hall here parallel
       tabulation work will be done in an Excel Sheet to counter
       check any human error. This date entry will also be done
       polling station wise and Round wise. Even though computer
       tabulation will not substitute the manual tabulation being
       done for obtaining final result of the counting of votes, the
       Computer based parallel tabulation/totalling will be helpful
       as a double check on the accuracy of manual tabulation. The
       said date shall be entered in the excel sheet in the computer
       and a print out of the same shall be taken out and compared
       by the observer and also be signed by the officer. Both
       Returning Officer and the Observer should be satisfied after
       due checking that the number of votes posted against the
       name of leach candidate in respect of every counting table
       tally with the figures as shown in Part-II of Form 17C (result
       of counting) pertaining to that counting table. Then it should
       be signed by Returning Officer and Observer. Thereafter
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                                                                E.P.2 OF 2019


       Returning Officer should announce the result of that round
       loudly or using loudspeaker for every body‟s information. The
       total etc. Done manually may be tallied by entering all the
       counting date in an Excel sheet and computing the total.


       27. It is respectfully submitted that in respect of Mandadam
       Village of Tadikonda Constituency, which falls under Guntur
       Parliament Constituency, at Polling Station No.06, the
       Presiding Officer, in Form 17 C, justifies the difference
       between Column No.1, 2 and 6 by stating that mistake 5
       voters have left without voting. This is not possible for the
       reason that once the slip is given for voting, the EVM opens
       up for casting the vote and only when the vote is cast, the
       EVM would be ready for the next voter. As such, 5 voters
       leaving by mistake does not arise."



30.   Section 83 of the Act, which is relevant, reads as follows:

      83. Contents of petition.-- (1) An election petition--

       (a) shall contain a concise statement of the material facts on
       which the petitioner relies;

       (b) shall set forth full particulars of any corrupt practice
       that the petitioner alleges including as full a statement as
       possible of the names of the parties alleged to have
       committed such corrupt practice and the date and place of
       the commission of each such practice; and

       (c) shall be signed by the petitioner and verified in the
       manner laid down in the Code of Civil Procedure, 1908 (5 of
       1908) for the verification of pleadings:
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           Provided that where the petitioner alleges any corrupt
           practice, the petition shall also be accompanied by an
           affidavit in the prescribed form in support of the allegation
           of such corrupt practice and the particulars thereof.

           (2) Any schedule or annexure to the petition shall also be
           signed by the petitioner and verified in the same manner as
           the petition.


     31.       The present petition is not on the basis of any corrupt

practices, alleged against the 1st respondent. Therefore, the pleadings

in the petition would have to meet the requirement of section 83 (1)

(a) of the Act. The Hon‟ble Supreme Court, while dealing with the

scope of this section, in Samant N. Balakrishna and another vs

George Fernandez and others12, had held as follows:

        29.     Having dealt with the substantive law on the subject of
        election petitions we may now turn to the procedural
        provisions in the Representation of Peoples Act. Here we have
        to consider Sections 81, 83 and 84 of the Act. The first
        provides the procedure for the presentation of election
        petitions. The proviso to sub-section alone is material here. It
        provides that an election petition may be presented on one or
        more of the grounds specified in sub-section (1) of Section
        100 and Section 101. That as we have shown above creates
        the substantive right. Section 83 then provides that the
        election-petition must contain a concise statement of the
        material facts on which the petitioner relies and further that
        he must also set forth full particulars of any corrupt practice

12   1969 3 SCC Page 238 (para 29)
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that the petitioner alleges including as full a statement as
possible of the names of the parties alleged to have
committed such corrupt practice and the date and place of
the commission of each such practice. The section is
mandatory and requires first a concise statement of material
facts and then requires the fullest possible particulars. What
is the difference between material facts and particulars? The
word "material" shows that the facts necessary to formulate a
complete cause of action must be stated. Omission of a single
material fact leads to an incomplete cause of action and the
statement of claim becomes bad. The function of particulars
is to present as full a picture of the cause of action with such
further information in detail as to make the opposite party
understand the case he will have to meet. There may be some
overlapping between material facts and particulars but the
two are quite distinct. Thus material facts will mention that a
statement of fact (which must be set out) was made and it
must be alleged that it refers to the character and conduct of
the candidate that it is false or which the returned candidate
believes to be false or does not believe to be true and that it is
calculated to prejudice the chances of the petitioner. In the
particulars the name of the person making the statement,
with the date, time and place will be mentioned. The material
facts thus will show the ground of corrupt practice and the
complete cause of action and the particulars will give the
necessary information to present a full picture of the cause of
action. In stating the material facts it will not do merely to
quote the words of the section because then the efficiency of
the words "material facts" will be lost. The fact which
constitutes the corrupt practice must be stated and the fact
must be co-related to one of the heads of corrupt practice.
Just as a plaint without disclosing a proper cause of action
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                                                             E.P.2 OF 2019


cannot be said to be a good plaint, so also an election
petition without the material facts relating to a corrupt
practice is no election petition at all. A petition which merely
cites the sections cannot be said to disclose a cause of action
where the allegation is the making of a false statement. That
statement must appear and the particulars must be full as to
the   person making the      statement and      the   necessary
information. Formerly the petition used to be in two parts.
The material facts had to be included in the petition and the
particulars in a schedule. It is inconceivable that a petition
could be filed without the material facts and the schedule by
merely citing the corrupt practice from the statute. Indeed
the penalty of dismissal summarily was enjoined for petitions
which did not comply with the requirement. Today the
particulars need not be separately included in a schedule but
the distinction remains. The entire and complete cause of
action must be in the petition in the shape of material facts,
the particulars being the further information to complete the
picture. This distinction is brought out by the provisions of
Section 86 although the penalty of dismissal is taken away.
Sub-section (5) of that section provides:

 "(5) The High Court may, upon such terms as to costs and
 otherwise as it may deem fit, allow the particulars of any
 corrupt practice alleged in the petition to be amended or
 amplified in such manner as may in its opinion be
 necessary for ensuring a fair and effective trial of the
 petition, but shall not allow any amendment of the petition
 which will have the effect of introducing particulars of a
 corrupt practice not previously alleged in the petition."
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                                                           E.P.2 OF 2019


The power of amendment is given in respect of particulars
but there is a prohibition against an amendment "which will
have the effect of introducing particulars of a corrupt
practice not previously alleged in the petition." One alleges
the corrupt practice in the material facts and they must
show a complete cause of action. If a petitioner has omitted
to allege a corrupt practice, he cannot be permitted to give
particulars of the corrupt practice. The argument that the
latter part of the fifth sub-section is directory only cannot
stand in view of the contract in the language of the two
parts. The first part is enabling and the second part creates
a positive bar. Therefore, if a corrupt practice is not alleged,
the particulars cannot be supplied. There is, however, a
difference   of   approach   between    the   several   corrupt
practices. If for example the charge is bribery of voters and
the particulars give a few instances, other instances can be
added; if the charge is use of vehicles for free carriage of
voters, the particulars of the cars employed may be
amplified. But if the charge is that an agent did something,
it cannot be amplified by giving particulars of acts on the
part of the candidate or vice versa. In the scheme of election
law there are separate corrupt practices which cannot be
said to grow out of the material facts related to another
person. Publication of false statements by an agent is one
cause of action, publication of false statements by the
candidate is quite a different cause of action. Such a cause
of action must be alleged in the material facts before
particulars may be given. One cannot under the cover of
particulars of one corrupt practice give particulars of a new
corrupt practice. They constitute different causes of action.
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                                                                  E.P.2 OF 2019


     32.        This principle was further elaborated in Kalyan Singh

Chouhan v. C.P. Joshi, 13which held as follows:


            17. During the trial of an election petition, it is not
            permissible for the court to permit a party to seek a
            roving enquiry. The party must plead the material fact
            and adduce evidence to substantiate the same so that
            the court may proceed to adjudicate upon that issue.
            Before the court permits the recounting, the following
            conditions must be satisfied:


            (i) The court must be satisfied that a prima facie case
            is established;


            (ii) The material facts and full particulars have been
            pleaded stating the irregularities in counting of votes;


            (iii) A roving and fishing inquiry should not be
            directed by way of an order to re-count the votes;


             (iv) An opportunity should be given to file objection; and


       (v) Secrecy of the ballot requires to be guarded.


           [Vide Jagjit Singh (Dr.) vs. Giani Kartar Singh 14, Suresh
           Prasad               Yadav vs. Jai                Prakash
           Mishra 15, M.Chinnasamy vs. K.C.Palanisamy 16,
           Chandrika Prasad Yadav vs. State of Bihar 17, Tanaji
           Ramchandra        Nimhan v. Swati          Vinayak
13
  (2011) 11 SCC 786 : (2011) 4 SCC (Civil) 656 : 2011 SCC OnLine SC 229 at page
794
14 AIR 1966 SC 773
15 (1975) 4 SCC 822: AIR 1975 SC 376
16 (2004) 6 SCC 341 : AIR 2004 SC 541
17 (2004) 6 SCC 331 : AIR 2004 SC 2036
                                         29
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                                                               E.P.2 OF 2019



       Nimhan 18, Gursewak Singh vs. Avtar Singh 19and Baldev
       Singh vs. Shinder Pal Singh 20]


         18.          In Gajanan        Krishnaji   Bapat v. Dattaji
         Raghobaji Meghe, 21 this Court held that the court
         cannot consider any fact which is beyond the pleadings
         of the parties. The parties have to take proper pleadings
         and establish by adducing evidence that by a particular
         irregularity/illegality the result of the election has been
         materially affected.


         19.        Pleadings and particulars are required to
         enable the court to decide the rights of the parties in the
         trial. Thus, the pleadings are more to help the court in
         narrowing the controversy involved and to inform the
         parties concerned to the question in issue, so that the
         parties may adduce appropriate evidence on the said
         issue. It is settled legal proposition that "as a rule relief
         not founded on the pleadings should not be granted".
         Therefore, a decision of a case cannot be based on
         grounds outside the pleadings of the parties. The
         pleadings and issues are to ascertain the real dispute
         between the parties to narrow the area of conflict and to
         see just where the two sides differ. (Vide Sri Mahant
         Govind Rao v. Sita Ram Kesho [(1897-98) 25 IA
         195], Trojan & Co. v. Nagappa Chettiar 22, Raruha
         Singh v. Achal              Singh 23, Om           Prakash
         Gupta v. Ranbir B. Goyal 24, Ishwar Dutt v. Collector

18 (2006) 2 SCC 300 : AIR 2006 SC 1218
19 2006) 4 SCC 542 : AIR 2006 SC 1791
20 2007) 1 SCC 341
21 (1995) 5 SCC 347: AIR 1995 SC 2284
22 AIR 1953 SC 235
23 AIR 1961 SC 1097
24 (2002) 2 SCC 256 : AIR 2002 SC 665
                                        30
                                                                  RRR,J
                                                           E.P.2 OF 2019



         (L.A.) 25 and State of Maharashtra v. Hindustan
         Construction Co. Ltd. 26 )

         20.       This Court in Ram Sarup Gupta v. Bishun

         Narain Inter College 27held as under: (SCC pp. 562-63,

         para 6)



         "6. ... It is well settled that in the absence of pleading,
         evidence, if any, produced by the parties cannot be
         considered. It is also equally settled that no party
         should be permitted to travel beyond its pleading and
         that all necessary and material facts should be pleaded
         by the party in support of the case set up by it. The
         object and purpose of pleading is to enable the
         adversary party to know the case it has to meet. ... In
         such a case it is the duty of the court to ascertain the
         substance of the pleadings to determine the question."


         [




      33. These judgments are to the effect that, the details of how the

17C forms produced by the petitioner reveal discrepancies, which

would affect the outcome of the election have to be pleaded. Except in

the case of about 3 17C forms, no details of the discrepancies in the

other forms have been given. In the absence of these details, omnibus

allegations of improper form 17C would not answer the requirement of

furnishing material particulars, under section 83 of the Act. Even if the


25 (2005) 7 SCC 190 : AIR 2005 SC 3165
26 (2010) 4 SCC 518 : (2010) 2 SCC (Civ) 207
27 (1987) 2 SCC 555 : AIR 1987 SC 1242
                                        31
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                                                                    E.P.2 OF 2019


contention of the petitioner that the documents filed along with the

plaint or petition, have to be treated as part of pleadings, the same

would still not answer the requirement of setting out material

particulars, detailing how the 17C forms are not in proper order or how

such discrepancies, available in the forms would vitiate the election.
        [




        34.         In view of the above, the 17C forms marked as exhibits

P.11 to P.17 would have to be eschewed. In the circumstances, there

would not be any further need to go into the question of whether

these documents are to be treated as certified copies which are

admissible as evidence as opposed to true copies which, the learned

senior counsel contends, cannot be admitted in evidence, as

secondary evidence.


        35.          This would only leave the forms relating to polling

stations 6, 102 and 103.          The discrepancies pointed out in these

forms have not resulted in any damage to the interests of the

petitioner. In fact, the petitioner had obtained more votes in these

polling stations. Further, none of the appropriate persons who can

speak       about    these   documents      had   been   examined    and     the

evidentiary value of these documents is highly doubtful. In any

event, it would not be possible to extrapolate these discrepancies,
                                    32
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                                                            E.P.2 OF 2019


claimed by the petitioner, to the entire counting process, so as to

vitiate the entire election.


      36.         For all the aforesaid reasons, this Election Petition

must fail and is accordingly dismissed without costs.

      As a sequel, pending miscellaneous petitions, if any, shall

stand closed.

                                           ____________________________
                                           R. RAGHUNANDAN RAO, J.

RJS 33 RRR,J E.P.2 OF 2019 HON'BLE SRI JUSTICE R. RAGHUNANDAN RAO ELECTION PETITION No.2 of 2019 20-03-2024 RJS