UNIVERSITY SCHOOL OF LAW RAYAT

BAHRA UNIVERSITY
SAHAURAN, MOHALI

MOOT COURT FILE

SUBMITTED BY: - Nikhil Thakur

Ba.LLB
Semester-8th
1507001112
 IN THE HON’BLE SESSION COURT

MEMORIAL FILED ON BEHALF OF THE DEFENCE

Case no. : 256/2021_

IN THE MATTER OF
PriyaPandya
PROSECUTION

VERSUS

Amit Shabbir DEFENCE

IN THE MATTER OF CASE FILED UNDER SECTION 354-A,354-B 354-C

354-D,350,351,376 OF THE INDIAN PENAL CODE, 66A,66C,66E

Most Respectfully Submitted to the Hon’ble Judges of the Session Court COUNSEL
APPEARING ON BEHALF OF DEFENCE

M
 Table of Contents

Abbreviations ...................................................................................................................... III

Index of Authorities ............................................................................................................ III

Statement of Jurisdiction ...................................................................................................... V

Statement of Facts ............................................................................................................... VI

Statement of Issues............................................................................................................. VII

Summary Arguments........................................................................................................... IX

Prayer........................................................................................................................

Memorial for Denfence 3

 ABBREVATIONS

A.I.R. All India Reporter

S.C. Supreme Court

Vs. Versus

H.C. High Court

Sec. Section

Memorial for Denfence 4

 INDEX OF AUTHORITIES

STATUTORY COMPILATIONS

1) The Indian Penal Code, 1860

2) The Code of Criminal Procedure,1973
3) The Indian Evidence Act, 1872

BOOKS

1) Prof. S.N. Mishra, INDIAN PENAL CODE

2) Criminal Law Manual (Universal Law Publishing)

3) INDIAN PENAL CODE (P.N.PARANJAPE)

4) H.S GOUR, PENAL LAW OF INDIA (Law Publishers Allahabad,2006)

5) M.L SAWHNEY, SUPREME COURT CRIMINAL CASES DIGEST, (Universal

Printing Press Jaipur, 2005)
6) P S A PILLAI, CRIMINAL LAW (Lexis Nexis Butter words New Delhi,2007)
7) Debarati Halder and Karuppannan, Cyber Crime Against in India
8) Talat Fatima, Cyber Law in India

DICTIONARIES

1) BLACK’S LAW DICTIONARY, (11thEd.1999)

2) OXFORD ENGLISH DICTIONARYOUP

3) WEBSTER’S NEW ENCYCLOPEDIA DICTIONARY, (2002)

WEBSITES
1) www.supremecourtofindia.nic.in
2) www.judis.nic.in
3) www.manupatra.co.in/AdvancedLegalSearch.aspx
4) www.findlaw.com
5) www.indiankanoon.org

Memorial for Denfence 5

 Cases

State of Haryana v. Bhajan Lal

Nikhil Merchant v. Central Bureau Of Investigation &Anr
Manoj Sharma v. State & Ors.2 the Apex Court
State v. Khempal
State v. Jagjeet Singh @ Jaga @ Lucky
Maheshwar Tigga v. The state of jharkhand
State v. Sanjay and Others
Hem Raj v. State of Haryana
Udit Gupta v. State of Rajasthan
Naval Kishore Singh v. State of Bihar.
Neena Shad vs Mcd
Mr Sunil Menon vs Mr. Ramesh Chelliah

Memorial for Denfence 6

 STATEMENT OF JURISDICTION

The respondent humbly submits this memorandum for a case filed before this Hon’ble
Session Court. The defense has approached the Hon’ble Court of Session.

Memorial For Defence 7

 STATEMENT OF FACTS

1. That there is this case of a young manager Amit Shabbir who claims to be 26 years old
now based on ossification test and who is alleged to have committed various offences
against one Ms. Priya Pandya who is presently a college student studying in the fourth year
of Bachelor of Dental Surgery (B.D.S.), in a college in the city.
2. That Ms. Priya used to visit a Restaurant-cum-Bar in Mumbai along with her friends,
where she came across this Amit Shabbir who was a Manager in one Hotel-cum-
Restaurant at Chembur, Mumbai. Amit claims that, Ms. Priya and he were friends for more
than four years since 2013 and they visited some places outside the city on their own on a
couple of occasions and spent time together.
3. That Ms. Priya alleges that Amit used to follow her up to her college and had approached
her on several occasions to have friendship with him.
4. That she states that she did not like Amit following her and trying to track her on
Facebook, and that she had even tried to change her timings of going to college.
5. That Her further allegations are that Amit stared at her continuously with ulterior motives
during her visits to he said Restaurant cum-Bar whenever she visited along with her
friends and made her feel uncomfortable and that she had told these facts to her friends as
well.
6. That she further alleges that once Amit had pulled her dupatta in the Restaurant-cum-Bar
and had tried to molest her.
7. That Ms. Priya added that she was going through psychological and emotional trauma
because of the behavior of Amit as she was about 18 years old at that time.
8. That Ms. Priya further states that Amit had requested her to meet him once to whom she
agreed just to tell him not to follow her and to leave her alone.
9. That however, she states that she actually met him more than once and that Amit promised
to marry her but had taken advantage of her against her will and had physical relations
with her which he now claims to be consensual relationship. Ms. Priya states that she was
forced to have alcohol during one of their meetings and was asked inappropriate questions
about her sex life after showing her some videos on pornography against her will.
10. That she further adds that Amit had also taken photos of intimate relations with her and
had sent her those photos on her WhatsApp asking for further sexual favours. Ms. Priya
contends that she did not show any interest in him and had refused to meet him.
11. That Her further allegations are that Amit actually did not care for her feelings and had an

Memorial For Defence 8

 affair with another girl Ms. Amrita from her group after courtship of two years with her
(Ms. Priya). Ms. Priya also says that one of her close friends (Sandhya Patil) who had
some experience of going to court to attend court proceedings on account of her (Sandhya
Patil) domestic violence against her, advised her (Ms. Priya) not to lodge complaint against
Amit.
12. That Ms. Priya has lodged an F.I.R. bearing No. 23 dated 12/11/2018, under Sections 345-
A, 354 B, 354 C, 354 D, 350, 351, 376 of the I.P.C. 1860 and Sections 66 A, 66 C, 66 E of
the I. T. Act, 2000 with the Chembur Police Station, alleging that Amit had committed
various offenses against her in the year 2013 and did not marry her inspite of promising
her.
13. That Ms. Priya further alleged that her engagement with another boy Piyush Shah broke
off when he learnt about her affair with Amit. Also she contends that her chat with Amit
on Facebook was leaked and she alleges to have exchanged messages with him on
WhatsApp also.
14. That further, she alleges that Amit had sent dirty pictures and pornographic videos to her
on WhatsApp during their relationship even though she objected to the same. Ms. Priya
states that she also blamed Amit in one of the chats on Facebook, when her
fiancée Piyush Shah questioned her about her previous affair.
15. That the police had recovered black colored Nokia phone with IMEI No.
242070251622411 from Amit, pursuant to the F.I.R. No. 23 dated 12/11/2018 lodged by
her against Amit under Sections 345 A, 354 B, 354 C, 354 D, 350, 351, 376 of the I.P.C.
1860 and Sections 66 A, 66 C, 66 E of the I.T. Act, 2000 lodged by Ms. Priya but the
memory could not be fully recovered and the result was inconclusive. So also the
Facebook account was investigated but it did not advance the case of Ms. Priya. Ms. Priya
had stated that Amit had given her 3 (three) gms. ring on one of her birthdays, which she
had shown to the police.
16. That the Police had made enquiries with some hotels outside the city but there were no
entries found with their names. Ms. Priya had alleged that Amit would take her on his
motorcycle to one particular hotel called “Feel Free (FF)” and they would spent time
together. Police had enquired with the panwala near by the said hotel who had stated
thathe had only seen them there on some occasions but had not given any more
information. The Doctor at the medical clinic where she claims to have aborted two
months old fetus had not confirmed to the police, that the abortion had taken place at his

Memorial For Defence 9

 clinic.
17. That Amit is now working for a multinational Pharmaceutical company in Mumbai (which
employ many women) and has a secured job as Manager (Administration). However, his
employer has given him a show cause notice for terminating his employment on the
grounds that he had not disclosed about his previous employment as a Manager in the
Hotelcum-Restaurant at Chembur and besides that he was alleged to have had asked one
lady office colleague out on a date which she had refused to oblige.
18. That Amit suspects that the employer was bent on sacking him because Ms. Priya had
written to his employer regarding their earlier affair and the employer had learnt about the
said F.I.R. lodged against him which contained the above allegations.
19. That the management is contemplating suspending him till the enquiry is completed and
Internal Complaints Committee is also constituted for the purpose of taking cognizance of
the allegations leveled against Amit. Amit vehemently denied the allegations citing them
as false accusations and claimed that Ms. Priya was willfully, deliberately, intentionally
and maliciously defaming him and ruining his career.
20. That Amit even demanded a written apology from her and threatened to file a defamation
case against her as she was maligning his image and destroying his career. Amit claimed
that he was pained and dismayed over the allegations against him and would perhaps take
the extreme step of ending his life as his image was lowered in the estimation of his friends
and relatives and his company was now shunned by them.
21. That Ms. Priya had lodged an F.I.R. bearing No 23 dated 12/11/2018 against Amit
under Sections 345 A, 354-B, 354-C, 354 D, 350, 351, 376 of the I.P.C. 1860 and
Sections 66 A, 66 C, 66 E of the I T Act, 2000 and Amit who is already on Anticipatory
Bail granted by the Honorable Sessions Court, has filed a Criminal Application An. 226
of the Constitution and U/s. 482 of the Criminal Procedure Code, 1973 in the Bombay
High Court for quashing of the said F.I.R. filed against him while the matter is pending in
the trial court and charge-sheet is not yet filed.

Memorial For Defence 10

 STATEMENT OF ISSUES

1. Whether the case is valid or the FIR should be quashed under Section 482 of Criminal
Procedure 1973 ?
2. Whether the accused is liable u/s 376 IPC or not ?
3. Whether the accused is liable u/s 354A, r/w 354B,354C, 354D IPC or not?
4. Whether the accused is liable u/s 66A r/w, 66C, 66E IT Act?

Memorial For Defence 11

 SUMMARY ARGUMENTS

Whether the case is valid or the FIR should be quashed under Section 482 of Criminal
Procedure 1973 ?
The facts of the case prove that there is no commission of offence, neither the prosecution could
prove that, the life of the accused and his social reputation has already been torted, there is no
reason why the accused should suffer the agony of legal proceedings.

Whether the accused is liable u/s 376 IPC or not ?

Rape charges are not appropriately framed because from the facts its seen that sexual
intercourse was consensual, Priya herself agreed that she had meet him more than once, they
have meet on various occasions in hotel FF as confirmed by the police and panvala and she had
received many expensive gifts from Amit such as gold ring etc.

Whether the accused is liable u/s 354A, r/w 354B,354C, 354D IPC or not ?

The allegations made against Amit of sexual harassment are completely untrue because as per
the story of Priya she was forced to drink alcohol and was shown pornography but it is
practically impossible that pornography can be shown against a person’s wish nobody can open
your eyes when you want them to be closed, Priya stated that he watched her with ulterior
motives, why would a woman meet a man personally whom she claims to be a stalker.

Priya alleged that Amittried to disrobe her at the place of his employment, Managers of a
restaurant come running if a hair comes out of the dish, and she claims that she has been
molested by the manager of that restaurant, moreover she herself visited the restaurant and its
logically impossible that friends of a women would force her to go to a place which makes her
uncomfortable.

Priya alleged false charges of Voyeurism are also inappropriate because the picture of Priya as
stated in the FIR, was not recovered from Amit’s computer neither Priya could provide the
same Priya was never been staked by Amit, which is confirmed from the fact that she herself
meet him outside the Restaurant and that she never complained about her so called staking from
Amit to his family or friends either.

Memorial For Defence 12

Whether the accused is liable u/s 66A r/w ,66C,66E IT Act?
It was confirmed that she herself without any threat from anyone use to talk to Amit on various
social media platforms, sending offensive pictures of Priya to herself is just an allegation and
nothing could be proved as the computer recourse of Amit was checked nothing could come out
of it and if Amit had any malignity he would have shared it with others so he never took any
offensive pictures of Priya neither send it to her.

Memorial For Defence 13

 ARGUMENTS ADVANCED

Whether the case is valid or the FIR should be quashed under Section 482 of Criminal
Procedure 1973?
Priya Pandya voluntarily visited the Restaurant where Amit Shabbir use to work, they meet
more than once as confirmed by Priya Pandya, they use to spend time together outside the city,
they use to meet in a hotel, which was confirmed by the panvala, they were in a relationship and
the sexual intercourse was consensual and not by any compulsion Priya has received expensive
gifts from Amit this case is just to harass Amit as Priya’s reputation has be tarnished because of
her relation she seem to have no interest in Amit and just want to just want to defame him so
that her reputation is refined and she could marry a richer person than Amit. The facts of the
case prove that there is no commission of offence, neither the prosecution could prove that, the
life of the accused and his social reputation has already been torted, there is no reason why the
accused should suffer the agony of legal proceedings. The defence submits that the FIR is
baseless and should be quashed at the first instance.

In State of Haryana v. Bhajan Lal,1

the Apex Court has laid down the following Guidelines for exercise of extraordinary
power under Article 226 of the Constitution or inherent power under Section 482 Cr. P.C. by
High Court in quashing FIR or complaint during the stage of investigation:

(i) Where the allegations made in the first information report or the complaint, even if they
are taken at their face value and accepted in their entirety do not prima facie constitute any
offence or make out a case against the accused;
(ii) Where the allegations in the first information report and other materials, if
any, accompanying the FIR do not disclose a cognizable offence, justifying an investig
ation by Police Officers under Section 156 (1) of the Code except under an order of a Magistrate
within the purview of Section 155(2) Cr. P.C;

(iii) Where the uncontroverted allegations made in the FIR or complaint and the evidence
collected in support of the same do not disclose the commission of any offence and make out a
case against the accused;
1
AIR 1992 SC 604, see also First Information Report (F.I.R.)- by RajenderMangari, Asia Law House,
Hyderabad, 2nd Edition 2005-2006, p. 118-119.

Memorial For Defence 14

(iv) Where, the allegations in the FIR do not constitute a cognizable offence, no investigation
is permitted by a police officer without an order of a Magistrate as contemplated under Section
155(2) of the Code;

Where the allegations made in the FIR or complaint are so absurd and inherently
improbable on the basis of which no prudent person can ever reach
a just conclusion that there is sufficient ground for proceeding against the accused.

Nikhil Merchant V. Central Bureau Of Investigation &Anr.2

the Apex court held that High Court in exercise of its inherent powers can quash criminal
proceedings or a FIR or complaint and Section 320 Cr.PC does not limit or affect the power of
the High Court under Section 482 of the Code.

In Manoj Sharma V. State & Ors.2 the Apex Court 3

held that Where continuing with the proceeding would be a futility, quashing should not be
refused.
Whether the accused is liable u/s 376 IPC or not ?
The facts of the case are such that it is clear that no force or compulsion have been used, even if
we go by the facts of the case it can be case of misconception of fact but absolutely not rape.
Rape charges are not appropriately framed because from the facts its seen that sexual intercourse
was consensual, Priya herself agreed that she had meet him more than once, they have meet on
various occasions in hotel FF as confirmed by the police and panvala and she had received many
expensive gifts from Amit such as gold ring etc. if there was any case why it was not reported at
the first instance.
In State v. Khempal

The testimony of the prosecutrix is not of trustworthy and is not of a sterling quality inasmuch
as she has specifically stated that accused had not raped her. That, initially, the call was made by
some other person and the call was of quarrel and there was no call made either by the
prosecutrix or by her husband of sexual harassment alleged to have been committed by the
accused. Had it been the offence alleged to have been committed rape by the accused with the
prosecutrix then the prosecutrix or her husband or her other family member would have made a
complaint of rape. Therefore, the prosecution has not been able to prove its case against the

2
AIR 2008
3
AIR 2008 SC 1619
Memorial For Defence 15
accused in respect of making physical relation forcibly alleged to have been made by the
accused with the prosecutrix.

In State Versus Jagjeet Singh 4

No explanation has been tendered by the prosecutrix for the delay in lodging the FIR against
the first incident of physical relationship which allegedly had taken place under
the threat of making the video viral. Since no video has been recovered or taken nor any such
video has been placed on record, therefore, it cannot be appreciated that under the threat of
existence of any video, the prosecutrix was forced by the accused to establish physical relations
with him. Even if for the sake of the argument, it is presumed that the prosecutrix
was sexually assaulted by the accused somewhere, during the period of two years prior to
15/11/2014, then the question arises as to why this incident has not been disclosed by the
prosecutrix to her family, her husband or to police? There is absolutely no explanation given by
the prosecutrix, of not narrating these facts.

Maheshwar Tigga V. The State Of Jharkhand5

The question for our consideration is whether the prosecutrix consented to the physical
relationship under any misconception of fact with regard to the promise of marriage by the
appellant or was her consent based on a fraudulent misrepresentation of marriage which the
appellant never intended to keep since the very inception of the relationship. If we reach the
conclusion that he intentionally made a fraudulent misrepresentation from the very inception and
the prosecutrix gave her consent on a misconception of fact, the offence of rape under Section
375 IPC is clearly made out. It is not possible to hold in the nature of evidence on record that the
appellant obtained her consent at the inception by putting her under any fear. Under Section 90
IPC a consent given under fear of injury is not a consent in the eyes of law. In the facts of the
present case

Under Section 90 IPC, a consent given under a misconception of fact is no consent in the eyes of
law. But the misconception of fact has to be in proximity of time to the occurrence and cannot
be spread over a period of four years. It hardly needs any elaboration that the consent by the
appellant was a conscious and informed choice made by her after due deliberation, it being
spread over a long period of time coupled with a conscious positive action not to protest. The

4
AIR 2005
5
AIR 2020
Memorial For Defence 16
prosecutrix in her letters to the appellant also mentions that there would often be quarrels at her
home with her family members with regard to the relationship, and beatings given to her.

Whether the accused is liable u/s 354A, r/w 354B, 354C, 354D IPC or not?

The allegations made against Amit of sexual harassment are completely untrue because as per
the story of Priya she was forced to drink alcohol and was shown pornography but it is
practically impossible that pornography can be shown against a person’s wish nobody can open
your eyes when you want them to be closed, Priya stated that he watched her with ulterior
motives, why would a woman meet a man personally whom she claims to be a stalker.
Priya alleged that Amit tried to disrobe her at the place of his employment, Managers of a
restaurant come running if a hair comes out of the dish, and she claims that she has been
molested by the manager of that restaurant, moreover she herself visited the restaurant and its
logically impossible that friends of a women would force her to go to a place which makes her
uncomfortable.
Priya alleged false charges of Voyeurism are also inappropriate because the picture of Priya as
stated in the FIR, was not recovered from Amit’s computer neither Priya could provide the the
same . Priya was never been staked by Amit, which is confirmed from the fact that she herself
meet him outside the Restaurant and that she never complained about her so called staking from
Amit to his family or friends either.

In State v. Sanjay and Others6

Another marked improvement made in her deposition is when she stated that the accused
persons had abused her and outraged her modesty. However, she did not explain as to how her
modesty was outraged by the accused persons and simply by saying her modesty was outraged,
the ingredients of the offence punishable under Section 354 IPC cannot be stated to be fulfilled.
She also did not support the allegation in her testimony before the court regarding the fact that
she was pushed to the ground by the accused persons.It is a cardinal principle of criminal
jurisprudence that prosecution is to prove the guilt of the accused beyond the possibility of any
reasonable doubt. It is also a settled principle that thought there may be an element of truth in
the prosecution story against the accused but considered as a whole there is invariably a long
distance to travel and whole of this distance must be covered by the prosecution by legal,
trustworthy and unimpeachable evidence before an accused can be convicted. This principle of
law has been reiterated by the Hon'ble apex court in the following cases

6
AIR 2014
Memorial For Defence 17
Hem Raj v. State of Haryana 7
it has been observed that: "The fact that no independent witness though available, was examined
and not even an explanation was sought to be given for not examining such witness is a serious
infirmity in the prosecution case. Amongst the independent witnesses one who was very much
in the know of things from the beginning was not examined by the prosecution. Non-
examination of independent witness by itself may not give rise to adverse inference against the
prosecution. However, when the evidence of the alleged eye- witnesses raise serious doubts on
the point of their presence at the time of actual occurrence, the unexplained omission to examine
the independent witness would assume significance.

Udit Gupta V. State Of Rajasthan8

Section354D of IPC. In the impugned FIR, respondent has alleged that the petitioner while
working as and thereafter had also visited her in-laws house where at present she is living. The
police have registered a case against the petitioner under Section 354D IPC. This criminal misc.
petition under Section 482 Cr.P.C. has been filed by the petitioner with a prayer for quashing of
FIR .

Whether the accused is liable u/s 66A r/w , 66C, 66E IT Act?
It was confirmed that she herself without any threat from anyone use to talk to Amit on various
social media platforms, sending offensive pictures of Priya to herself is just an allegation and
nothing could be proved as the computer recourse of Amit was checked nothing could come out
of it and if Amit had any malignity he would have shared it with others so he never took any
offensive pictures of Priya neither send it to her.

Naval Kishore Singh v. State of Bihar.9,

It was held to an essential part of a fair trial observing as follows the accused should have been
given opportunity to explain any of the circumstances appearing in the evidence against him. At
least, the various items of evidence, which had been produced by the prosecution, should have
been put to the accused in the form of questions and he should have been given opportunity to
give his explanation. No such opportunity was given to the accused in the instant case. We
deprecate the practice of putting the entire evidence against the accused put together in a single
7
AIR 2005 SC 2110,
8
AIR 2018
9
(2004) 7 SCC 502
Memorial For Defence 18
question and giving an opportunity to explain the same, as the accused may not be in a position
to give a rational and intelligent explanation. The trial Judge should have kept in mind the
importance of giving an opportunity to the accused to explain the adverse circumstances in the
evidence and the Section 313 examination shall not be carried out as an empty formality. It is
only after the entire evidence is unfurled the accused would be in a position to articulate his
defence and to give explanation to the circumstances appearing in evidence against him. Such an
opportunity being given to the accused is part of a fair trial
10
DhruvaramMurlidhar Sonar vs. The State of Maharashtra and Others, and in
PramodSuryabhanPawar vs. State of Maharashtra11, arising out of an application under
Section 482 Cr.P.C. in similar circumstances where the relationship originated in a love affair,
developed over a period of time accompanied by physical relations, consensual in nature, but the
marriage could not fructify because the parties , quashed the proceedings.

Neena Shad vs Mcd12

False sexual harassment: judgments appears in the document, In his defence, Dr. Vidya Sagar
stated that on the directions of Chairman, Medical Relief and Public Health Committee he along
with Dr. Ashok Garg had gone to Nand Nagari dispensary to facilitate petitioner Neena Shad in
joining the said dispensary where petitioner Neena Shad was present along with her husband Dr.
Sunil Chaudhary. Petitioner Neena Shad and her husband unnecessarily picked up a fight with
him and thereafter called the police and falsely accused him of sexually harassing Neena Shad.
It came into notice that the officer who asked for her punctuality and behave properly to juniors,
she always leveled allegations of sexual harassment upon everyone. As many as three
complaints leveling sexual harassment allegations were filed by Neena Shad but not even an
iota of truth was found in any of the said complaints by the Committee.

Mr Sunil Menon vs Mr. Ramesh Chelliah13

False sexual harassment: judgments appears in the document

That when all efforts of the accused persons failed to expel this complainant all the accused
persons collectively instigated other female employees to initiate false sexual harassment
complaints with an intention to humiliate and defame this complainant and thereby expel this

10
AIR 2019 SC 327
11
(2019) 9 SCC 608
12
AIR 2010
13
AIR 2017
Memorial For Defence 19
complainant from the Company and to tarnish his image and goodwill in the industry instigating
them to file false complaints of sexual harassment. Learned counsel has pointed out that it is not
a sheer coincidence that three employees have resorted to file complaint
alleging sexual harassment by the respondent No.1 on the same day. That apart, the committee
members appointed by the Company to enquire into the allegations made by the female
employees are none other than the sub-ordinates of the petitioner. All these circumstances,
therefore, clearly indicate that the petitioners are vindictively pitted against the respondent No.1
and have committed the offences alleged against them and therefore, without these allegations
being investigated into, this court cannot exercise the jurisdiction at this stage and stifle the
prosecution as sought for by the petitioners.

Memorial For Defence 20

 PRAYER

In the light of the issues raised, arguments advanced and authorities cited it is humbly
prayed before the Hon’ble Court that;-

The FIR lodged should be quashed, as it is clear for the facts that the sexual
intercourse was consensual, the FIR is to just harass the defence

AND/OR

Pass any other order as it deems fit in the interest of Equity, Justice and
Good Conscience.

For This Act of Kindness, the defence Shall Duty Bound Forever Pray.

S/d

(Counsel for the Defence)

Memorial For Defence 21