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28. A1 further stated that the alleged TA/DA bill had overwriting at two places and it did not contain the names of the passengers so the TA/DA form was not properly filled. He stated that in the present case there was a clear discrepancy in relation to the ticket numbers which allegedly was different from the alleged ticket number of the present case and that despite there being discrepancy especially in the ticket number Ex.PW5/A, no verification was got done. He stated that the name of the companions had to be mentioned in the TA/ DA form. He stated that the alleged weeding out of records was illegal and it caused great prejudice to him in defending his case before the Court. He stated that he had not signed the alleged form Ex.PW4/E. He had neither given Ex.PW4/E to be processed for reimbursement nor did he give any ticket and boarding passes. He stated that in the present case no proper verification of the signatures on the TA form was done from the specimen signatures. He stated that PW5 was not an expert to identify correct signatures and Ex.PW5/A was a manipulated document and was not admissible in the eyes of law. He stated that Ex.PW5/B did not bear his signatures and was manipulated and not admissible in the eyes of law in the absence of valid certificate under Section 65 B of the Indian Evidence Act, 1872. He stated that the entries regarding the bills in Ex.PW10/A had been manipulated. He stated that the cheque bearing No.343384 dated 06.11.2012 for Rs.10,33,836/- for a consolidated amount towards two different trips was not to his CBI Vs. Vinay Kumar Pandey & Anr. Page No.26 of 361 knowledge. No policy or guidelines existed for issuing a consolidated cheque for more than Rs.10 Lakhs nor had been shown by the prosecution therefore, it was clear that there was a manipulation and he had been falsely implicated.

29. A1 further stated that none of the alleged documents attributed to him by the prosecution produced before the Court bore any particular account number allegedly provided by him because of which the alleged consolidated cheque could be prepared. He stated that the certificate under Section 65 B of the Indian Evidence Act Ex.PW21/B was defective in the eyes of law. He stated that the duty register Ex.PW27/A was a manipulated document. He stated that as per PW27, it was only a computer generated list of passengers and not the check in history. PW27 did not say that D-21 was a flight manifest. He stated that D-54 was not admissible in the eyes of law. He stated that all the exhibits Ex.PW29/A to Ex.PW29G (colly) were computer generated electronic documents and were not admissible in the eyes of law without they being accompanied by a valid certificate under Section 65B of Indian Evidence Act, 1872. He stated that as per PW30, he was an employee of a company working for revenue accounting of Air India. However, no account statement or any document in relation to the revenue accounting was ever produced by him with regard to the revenue generation from the alleged flight. PW30 had stated in cross examination that the alleged flight manifests were received by his office in manual form and then digitized by his office. The alleged flight manifests were received in In and Out department of his company and the said department scanned the same with which he had no concern. Thus, the certificate issued under CBI Vs. Vinay Kumar Pandey & Anr. Page No.27 of 361 Section 65B of Indian Evidence Act, 1872 was defective in the eyes of law. He stated that the documents Ex.PW30/B and Ex.PW30/C (colly) and Ex.PW30/D were not admissible in the eyes of law. He stated that Ex.PW31/A was a manipulated document and Ex.PW31/B and Ex.PW31/C and Ex.PW31/E (colly) were not admissible in the eyes of law and Ex.PW31/D and Ex.PW31/F were manipulated documents. He stated that Ex.PW31/G (colly) were manipulated and were not admissible in the eyes of law. He stated that Ex.PW32/A, Ex.PW32/B, Ex.PW32/C, Ex.PW32/D and Ex.PW32/E were manipulated documents. He stated that the alleged flight manifests were inadmissible in the eyes of law. Vide the letter Ex.PW32/G, it was stated that Mr. Pirakalathan Sr. Manager (Commercial Admn.), Air India Ltd., Chennai had informed that the documents i.e. flight manifest requested were not available as the same were retained for two years only as per official procedure. In this regard, Mr. Pirakalathan had enclosed a copy (manual for passenger services at Airport). Vide the said letter, it was further stated that pertaining to PNR No.YKX5C, the Reservation Manager Air India Ltd, New Delhi had informed that the details could not be traced from the historical record for the flight/ sector mentioned in the letter as mentioned. He stated that the documents Ex.PW32/H and Ex.PW32/I (colly), Ex.PW32/K and Ex.PW32/L were manipulated and were not admissible in the eyes of law. He stated that Ex.PW33/A was a manipulated document.

30. A1 stated that in his cross examination PW34 had admitted giving statement to the IO vide Ex.PW34/P1 wherein he had stated that "in case of VIP/CIP, if the protocol is doing the CBI Vs. Vinay Kumar Pandey & Anr. Page No.28 of 361 check-in then the same would be in the knowledge of PRO and the person who collect the boarding card give his contact number and the same is filled in the check in system as remark. Such person from protocol has to present all valid documents e.g. ticket, passport etc". He stated that Ex.PW34/A was a manipulated document and the certificate Ex.PW34/B did not show that PW34 had himself taken the printout, apart from satisfying the other conditions as stipulated under Section 65 B of the Indian Evidence Act, 1872. He stated that Ex.PW34/C, Ex.PW34/D, Ex.PW34/E, Ex.PW34/F Ex.PW34/G, Ex.PW34/I, Ex.PW34/J (colly), Ex.PW34/K (colly), Ex.PW34/L (colly), Ex.PW34/M and Ex.PW34/N were manipulated and they were not admissible in the eyes of law. He stated that the certificates Ex.PW34/H and Ex.PW34/O did not show that PW34 had himself taken the printouts, apart from satisfying the other conditions as stipulated under Section 65B of Indian Evidence Act, 1872. He stated that no material or guideline had been placed on record that the check in history could be deleted from the system. He stated that the statement of PW48 was contrary to the statements of the other prosecution witnesses and PW44 and PW48 had deposed falsely in the present case. He stated that even as per the record of the Lok Sabha Secretariat i.e. Ex.PW37/C, his children did not use the surname Pandey rather used the surname 'Vatsa' which facts were also mentioned in the supplementary charge sheet. In fact the alleged TA/DA claim should have been returned by the MSA branch of the Lok Sabha Secretariat on the said ground alone.

31. A1 further stated that the documents Ex.PW34/R (colly) to R20 (colly) were manipulated and they were not CBI Vs. Vinay Kumar Pandey & Anr. Page No.29 of 361 admissible in the eyes of law. He denied that in the actual record of the Airport the hard copy was maintained for two years for their reference purpose and in the data base system it was maintained for 10 years as per the Air India Manual. He stated that the certificate filed under Section 65B of the Indian Evidence Act (Ex.PW41/C) was a defective certificate apart from not satisfying the other conditions as stipulated under Section 65B of the Indian Evidence Act, 1872. He stated that the report Ex.PW46/B was incorrect and inconclusive and was given under the influence of CBI against him. PW46 could not be said to be an expert as no material/documents were placed by her on record to show her expertise in the field. He stated that no fair investigation was conducted by PW56. During the investigation, documents were manipulated, statements of witnesses were influenced and no effort was made to prosecute the real culprits by the CBI. He stated that Ex.PW56/B, Ex.PW56/C, Ex.PW56/F (colly), Ex.PW56/G, Ex.PW56/H were manipulated documents and were not admissible in the eyes of law.