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50. It is a fundamental rule of pleadings that "where the ground urged involves questions of fact, all relevant facts must be averred". In Narendra Bahadur Singh and Anr. V. State of UP., it has been held that where ground raised in the Writ Petition pertains to questions of fact, necessary averments in that regard has to be made in the Writ Petition.

51. That apart, this Court has in the case of J. ROBERT v. RAM JETHMALANI (supra) held after referring to the decision of Hon'ble Supreme Court in 1963 SC 458 that merely because there is a procedural lapse, the inclusion of the name of the person in the voters list will not become non-est. The relevant portion is extracted herein.