Ground 1:

The Grounds are the reasons due to which the  petitioner, Shived Saxena  interfere in earlier order. Due to the grounds , question of law arises.  Thus, the grounds are being mentioned in this Special petition leave based on law of nature and lex fori:

Part A: Grounds to corroborate false allegations on petitioner, Shri Sived Saxena by respondent, Smt. Megha Khare on the basis of law of nature and lex fori:

Allegation on petitioner: The  respondent, Smt. Megha Khare was beaten on account of domestic violence and dowry harassment and driven out of her matrimonial home on 24.08.2018.

Facts to rebut the allegation by petitioner, Shri Shived Saxena: 

1. The petitioner, Shri Shived Saxena in his original written statement has produced the air ticket on which the respondent travelled on 24.08.2018 .He has shared a path breaking finding that the air ticket on which respondent travelled was booked 39 days in advance. 

2. She also carried a total of 47 kgs of luggage along with her .The permissible limit by the airlines is a total of 22 kgs (15kgs of checkin baggage and 7kgs of hand baggage). That means she carried an excess baggage of 25kgs for which she has also paid an excess baggage allowance of Rs 2000 visible through her travel certificate and air ticket and icici bank account statement. 

3. If the respondent was subjected to domestic violence and dowry harassment in the morning of 24.08.2018 (flight timing from Delhi to Jabalpur being 10.10 am), then when did she get the time to pack 47 kgs of luggage.

Law of nature: 

Because of learned court has erred to consider the true fact that not every man is wrong and not every woman is innocent.

The truth always comes out in the end no matter how hard anyone tries to hide it. The petitioner Shri Shived Saxena tried his best to reveal the facts that were given false by respondent, Smt. Megha Khare but the learned court has ignored the facts and evidences.

Lex fori: 

1. Because of learned court has erred to consider that to allege falsely in contemplation of getting unfair maintenance is an offence under section 120B of IPC and wrong FIR by police being tempered is an offence u/s 167 of IPC and petitioner has been defamed by false allegations which is an offence u/s 500 of IPC and an offence of perjury under section 340 of Cr.P.C R/W section 191 and section 193 of IPC.

2.Because of Hon’ble High Court has ignored to consider that in this case, the respondent, Smt. Megha Khare refuses to live without any sufficient reason and she booked air ticket 39 days in advance alleging petitioner falsely for dowry and hence not entitled for maintenance in compliance with section 125(5) of Cr.P.C  if it is proved that the respondent, Smt. Megha Khare has put false allegations on petitioner Shri Shived Saxena Revision to live separately and also in compliance of Criminal Revision No. 467 of 3017, Smt Khushi @Samiksha V. Ankit.

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