In,
The Court of the Munsif 11,

Munger, Bihar.

Title Suit No. 57 of 1997.

1. Shree Narayan Singh, s/o Late Raghubar Narayan Singh,

2. Kashyap Sagar Narayan Singh, s/o Shree Narayan Singh and Harbeet Singh, under the guardianship of his father Shree Narayan Singh,

All residents of 'Uddiyana', Dalip Mahal, Mo. Purabsarai, P S. Kotwali, Town,

P. O.& Municipality and Dist. Munger, Bihar. ..... Plaintiffs.

Versus

• Tenzing Gyatso @ the Dalai Lama, correctly spelt as Taalai Lama, s/o not

known, r/o Thekchen Choling, P 0. McLeodganj, P S. Dharamsala-McLeodganj, Dist. Kangra, Himachal Pradesh;

2. Tashi Wangdi, s/o not known, Minister, Bureau of the Dalai Lama, r/o Thekchen Choling, P.0. McLeodganj, P S. McLeodganj-Dharamsala, Dist. Kangra, Himachal Pradesh.

3. Tai Situ Rinpoche, s/o Not known, Headquarters at Sherab Ling, P 0. Sansal,

Dist. Kangra, H. P.

4. Goshir Gyaltsap Rinpoche, s/o Not Known, r/o Dharma Chakra Centre, V. & P.0. Rumtek Monastery,P. S. Ranipool, Dist. Gangtok 737 135 Sikkim.

5. Thrangu Rinpoche, s/o not known, Vajra Vidya Mandir, Khajuhi, P. S. & P. 0. Sarnath, Dist. Varanasi, U. P.

6. Bokar Rinpoche, s/o not known, r/o Bokar Ngedon Chokhor Ling, Deosy Dhara, P S. & P.0. Mirik 734 214, Dist. Darjeeling, W. B.

• Kunsang Sherab, s/o not known, Member, Joint Action Committee, P S. & P 0.

Gangtok, Dist. Gangtok, Sikkim.

The plaintiffs above named beg to state as

follows : -

1. That plaintiff no. I is a patriotic Indian who has spent almost twenty five years in close association with Tibetan refugees living in various parts of this sub-continent and through extensive research has found to his amazement that the defendants are severally and jointly engaged in a wide range of illegal acitivities, some of which are deterimental to the national security of India, including sorcery and black magic.

2. That defendant no. 1, the Dalai Lama, the erstwhile God King of Tibet, had been deposed by the Communist Chinese Government, and compelled to flee his country incognito, crossing over into India in what was then NEFA, March 31, 1959.

3. That subsequntly, Pt. Jawaharlal Nehru, the then Prime Minister of India, had granted the Taalai Lama, Defendant No. 1, political asylum in India, concerning which no document was ever ex-ecuted.

4. That around this period, approx. 1 lakh Tibetans had fled the Chinese takeover of their country and sought asylum in this country.

5. That Pt. Nehru in his magnanimity, permitted them all to enter this country unconditionally and a vast operation was undertaken for the rehabilitation of these Tibetan refugees in India, distributed through various states, and with some international aid.

6. That amongst these refugees were defendant nos. 2-6. Dfdt. # 7 is a Sikkim Subject who is closely related to Tibetan families both in India as also in the Tibetan Autonomous Region of the Peoples' Republic of China.

7. That contrary to the image projected of Tibetans internationally, as 'a simple, peace-loving people who merely want their country back', Tibetans are an extremely violent and wily people who stop at absolutely nothing to further their own interests, even though these may compromise the national security of India, the country which gave them refgue, land, residence, food, clothing, health, education and so on, so that they may continue to lead lives as normal human beings with dignity.

8. That in response to the above, defendant nos. 1-7, have made an issue of international intrigue, based on a forged 'Prediction Letter', the recognition and instatement of His Holiness the XVIIth. Gyalwang Karmapa, Sri Jinendra Karmapad in Sanskrit, and have thus compromised the national security of this country.

9. That to explain this further, all the defendants have recognised one UrgyenThrinlay Dorje, a minor boy under the tutelage of the Chinese Govt., resident at Tshurphu Monastery. Near Lhasa, Tibet, as the XVIIth. Gyalwang Karmapa, and have applied to the Govt. of India for permission for this boy to enter India and be enthroned at his seat in India, the Dharma Chakra Centre, Rumtek Monastery, Sikkim, whilst three candidates of Indian origin have purposely not been considered for the status of the XVIIth. Gyawlang Karmapa, even though they are authentic, simply because they are 'racially inferior'.

10. That with the tacit approval of defendant nos. 1 & 2, the other defendants have defiantly staged the capture of Dharma Chakra Centre, Rumtek, which was reported in the New Delhi edition of The Hindustan Times, in Aug. 1993, as a 'Chinese Coup'.

11. That these defendants have in all probability removed most of the personal possessions of the late XVIth. Gyalwang Karmapa, which he had brought with him from Tibet on over 150 mule and yak loads in 1958, into Sikkim, through Bhutan, and where they had remained since, effectively having become 'National Treasures'. Currently it is not known as to whether the Black Vajra Crown and other precious sacred articles of the Jinendra Karmapad, have been removed physically from Sikkim, India, and spirited off surreptitiously into Tibet.

12. That for this impoverishment of India's national treasures, these defendants are directly responsible.

13. That strange as it may seem, defendant no. 1, not content with having lost his own country, Tibet, to the Communist Chinese, 1972 onwards attempted to destabilise Bhutan through a meticulously planned coup d'etat which mercifully failed, and now unable to sit still, has focussed on destabilising India, their host country, which gave them refuge and returned to them their human dignity.

14. That religion and politics have been irretrevably intertwined in the feudal and revisionist polity of Tibetans, with religious persecution of fellow-Buddhists, a peculiar characteristic of the Taala’i Lamas and their Govts. since 1642 C. E., when defendant no. I was instated as the king of Tibet in his preceding Fifth incarnation, by a petty Mongol chieftain, Goshir Khan, who shed an inordinate amount of blood and destroyed over 150 Buddhist monasteries in the name of Buddhism to do so.

15. That thus, the Taala’i Lamas enjoy the dubious distinction of being supposed saints whose hands, feet and body are stained with the blood of countless innocent Buddhists, making them unique in the history of human civilisation, and him most certainly an appropriate recipient of the Nobel Peace Prize for 1989.

16. That compared to the most nobel person in independent India, Mother Teresa, who was also awarded the Nobel Peace Prize in 1979, our illustrious Taalai Lama, Defendant No. 1, has done absolutely nothing for the country of his refuge, and its residents.

17. That this single incidence speaks volumes of the chasm between the message of the Buddha which these defendants profess and practice, which is to 'Make holes in the very platter from which they eat', to quote a Hindi adage.

18. That besides, these defendants have been either directly involved in Child Slavery, or condone it by their passive acquiescence, of Bihari Children from Body Gaya.

19. That these defendants also condone and/or indulge in the sexual abuse of young novice monks in their monasteries.

20. That if one were to list all the illegal activities such as drugs and so on of these defendants, either committed directly or condoned through passive acquiescence, it would run into a thick volume.

21. That suffice it to state that murder motivated through political considerations, is an integral part of their modus opearandi. One East Tibetan leader, Gungthang Tshulthrim, was shot dead at 9 p.m. mid 1978 in his backyard at Clement Town, Dehra Doon, U. P It is said that the assasin was apprehended and while in jail in Lucknow, he openly confessed that defendant no. I and his pseudo Govt. of Tibet in Exile, were directly behind this. Moreover, bounties had been placed by these noble people on the lives of other Tibetan Buddhist Religious Leaders, such as H. H. Dudjom Rimpoche, H. H. the XVIth. Gyalwang Karmapa H. H. Dhilgo Khyentse Rinpoche, later Rajaguru of Bhutan, of Rupees one lakh each in 1978. Amazingly, H. H. Penor Rinpoche survived three attempts to poison him.

22. That similarly His Eminence Jamgon Kongtrul Rinpoche was assasinated through sabotage in what was made to appear as a car accident involving a 1991 white BMW, April 24, 1992, near Siliguri, West Bengal.

23. That plaintiff no. I has been systematically drawing the attention of various authorities in India to these extra legal excesses being committed by the defendants.

24. That in March 1997, plaintiff no., I had filed a PIL at the hon'ble High Court, Patna, No. 2378 of 1997, in which various of these acts of sedition against the Govt. of India and so on had been highlighted.

25. That the hon'ble High Court, Patna, had in its order dtd. 31-3-97 directed ‘that plaintiff no. I should move the appropriate authority of the Central Govt.' which he has done, but to no avail.

26. That during his travels through various parts of this country, plaintiff no. I has been highlighting these very same issues, making Indian Buddhists and the public at large, aware of the threat to the Union of India, created and being nurtured by these defendants.

27. That in so doing, the plaintiff is exposing himself and his family to direct threat to their lives and it is highly probable that the defendants will contrive to harass them in various ways, thus violating the very principles of the Right to Life and so on as enshrined in the Constitution of India, through various illegal means, and may even go so far as to have them liquidated to silence the voice of a truly patriotic Indian and his family.

28. That on Sep. 19, 1997, Ven. Topga Rinpoche, Gen. Secy. of the Karmapa Charitable Trust, Gangtok, Sikkim, and a national of the Kingdom of Bhutan, died prematurely in New Delhi after a protracted and peculiar illness, induced by the various defendants through black magic.

29. That Ven. Topga Rinpoche had been an outspoken loyalist of the late XVIth. Gyalwang Karmapa of Rumtek Monastery, and had tried his level best to foil the pro-Chinese and anti-Indian conspiracy being hatched by the defendants in order to protect the national security of India and the property both sacred and temporal of the Gyalwang Karmapa from being surreptitiously taken out of India into Tibet.

30. That this petition is being filed under the provisions of the Specific Relief Act 1963, Sec. 38, titled 'Nuisance'.

31. That this court has the territorial jurisdiction to deal with this matter as the pliantiffs reside within its jurisdiction.

32. That the cause of action arose between Ist and 3rd. of August 1997 when the plaintiffs and family had visited Gangtok, Sikkim on a fact finding mission concerning Tibetan and Chinese involvement in Sikkim and the free flow of Chinese money into Sikkim, where he was warned by his friends to be careful otherwise they could be physically assaulted; on Aug. 30, 1997, when the plaintiff raised these issues at a Buddhist Conference in New Delhi and lastly on 19-9-1997 when Ven. Topga Rinpoche, General Secy. of the Karmapa Charitable Trust, Gangtok Sikkim, died prematurely in New Delhi.

33. That the value of this suit is fixed at Rs. 1,300/- over which ad valorem court fees Rs. 248/is filed herewith.

That the plaintiffs pray for the following reliefs

(a) That this learned court after adjudication may be pleased to pass an order permanently restraining the defendants from creating the said nuisance and from disturbing the peaceful life of the plaintiffs as provided in the Constitution of India.

(b) That the suit may be decreed with cost against the defendants in favour of the plaintiffs.

(c) That the court may be please to allow other relief or relief which may deem fit and proper in the eyes of the court and in favour of the plaintiffs against the defendants.

Filed through,

Advocate.

Verification.

1, Shree Narayan Singh, plaintiff no. 1, do hereby solemnly affirm and declare that the contents of the plaint are true and correct to the best of my knowledge, information and belief.

Verified and signed on this 4th. day of Oct. 1997, in the court premises, Munger, Bihar.

Filed through,

Advocate.

SUMMONS FOR SETTLEMENT OF ISSUES (0.5, Rules 1, 5)

In

The Court of Munsif II,

Munger, Bihar.

Title Suit # 57 of 1997.

1. Shree Narayan Singh, s/o Late Raghubar Narayan Singh and another, both residents of ’Uddiyana', Dalip Mahal, Mo. Purabsarai, P S. Kotwali, P O., Town, Municipality & Dist. Munger, Bihar.

..... Plaintiffs.

versus

1. Tenzing Gyatso, @ Dalai Lama, correctly spelt Taalai Lama and ors.

..... Defendants.

To :

Whereas the above-named plaintiffs have instituted a suit against you for 'nuisance' as defined in Secn. 38 of The Specific Relief Act 1963, you are hereby summoned to appear in this Court in person, or by a pleader duly instructed, and able to answer all material question relating to the suit, or who shall be accompanied by some person (s) able to answer all such questions, on the 4th day of Feb. 1998, at o'clock in the noon, to answer the claim; and further you are hereby directed to file on that day a written statement of your defence and to produce on the said day all documents in your possession or power upon which you base your defence or claim for set-off or counter-claim, and where you rely on any other document whether in your possession or power or not, as evidence in support of your defence or claim for set-off or counter-claim, and where you rely on any other document whether in your possession or power or not, as evidence in support of your defence or claim for set-off or counter-claim, you shall enter such documents in a list to be annexed to the written statement.

Take notice that in default of your appearance on the day before mentioned, the suit will be heard and determined in your absence.

Given under my hand and the seal of the Court, this day of 1997.

,d44V;L,R- -WI

IN 'Flil; F@IUNSIF 11, N-IUN(;I,-,R

Siiit No. 57 of 1997

Slit-t@c N,-irav-,iii S'ii(,Ii S/o l,ate IZ,,t,)Iitibei- S'ii,,I) Nirayall Siligli.

Kasliyil) SaLar. N;iraviii Siii,,Ii Sio Slirce Niirailvaii Siiioli aii(i I-latt.)eet

t- - t@ t7l

Slii(,@li Liii(lei- the of Iiis fiitlier Slirce Narayiii Sliigll,

f)alil.) Nialial, Mo. I)Lli-,it)sarai, ('I'owit)

All resi(leiit of'

[). 0. Nluiilcipalltv aii(i District N4uilc-,er (Biliai-).

LI

............. "I............ Plaiiitift's.

VerSLIS. lw

t . '-Feiiziiig (.'Yv@itso @ the Dalai Laiiia, correctly spelt

as I /o iiot kiiowii, R/o 'I'li@kciie;i

('Iioliilg. P.S. & 11.0. f)l)araiiisala, District Kaiigr-,i.

liiiii@iclial 1'radesli.

'1',tslii Wai)gdi, S/o iiit kiiowii, Miiiister, 13t-ireau of' the L),tlii Llaiii@i, l@/o 'I'liekciieil Clioliiig, ['.S. aiid 11.0. Dliaraiiisala, Distt. Kaiigra, IIiiii@iclial f'ra(lesli.

3. I'@Al SitLi Riiil)oclie, S/o Hot l@ilowii, Headqtiat-ters at Slierat) L,iil(,, 11.0. Saiisal, Dis(t. Kaii,,i-a,

Z7@

L-1

4. (iosliir (iy,-tlts@il) IZiill)oclie, S/o iiot kiiokn,ii, R/o

Dliarill ('Iiakri ('eiiti-e, Vil aii(i l@uiiltek Nioiiastery, Il.S. Raiiipo(,)I, Distt, (;atigtok, 737 135, Sikkiiii.

5 . 'I'llrailt'Ll Rijil)ocll(.@, Vaira Vidya Maii(lir, Klia'Llili,

'I

FI.S. aii(i 11.0. Stt-ilitili, 1)1,si@t. V,-iriiiasi, ll.IJ.

6. Bokar IZiilpoclic, S/() ilot ktiowti, IZ/o Bok@ir N,ledoii

t,

Cliokor Liiig, Deosy Dilara, P.S. ail(] I'.(). Nlirik

734 214, Distt. Da@leeliilg, W.B.

7. Kuilsaiig Slierab, S/o iiot kiiowil, Mciill)c-r lo' lilt Actioil ('otiiinittee, P.S. aild P.O. Gailgtok. Distt, Gaiigtok, Sikkiiii.

IVRI'l"I'EN STATEN/IEN,rON BEHALF OF ALL ].'HE I)EFENDAN't'S

A. ()IUECI'IONS'1'0 THE MAIN,rAINAi;it,i,rYOF THE SUI'F:

I . 'I'lie I)efeti(].tiits stil)iiiit that the suit is iiot iii,iiiit.iiii,il)le tit(] is litl)le to be (lisiiiisse(i ill Iiiiiiiie.

2 . Tile I)efeii(laiits submit that the Stiit discloses iio ci%,ii oi- iiiN, c,.ttise of actioii aii(I is liable to be (lisillisse(i ill liiiiiiie.

3. '['lie Defeii(laiits sui)iiiit that tile Suit pertallis to rel','ous @iii(]/or 1)ol'tical aiid/or iiti@rii@it'oiial iiiattei-s ail(]/or matters relatliio to Acts ol' St@ite ill

respect of \viilcii ilo Court lias 'LI 1-'S(I'Ct' Lliicier Scctioii 9 ol' the ('o(le of Civil ProcC(]Lire aii(i is liable to be (lisiiiisse(I ill Iiiiiiiie. The I)eteii(lailts submit tll@it the Stilt (loes iiot raise aily iiii(ter of a ' 'I ilature. 'I-lie I)efeii(l@iiits SLII)Illit tilit '(IIIV act Of civi

the (;o\,criiiiiciit Of' Iii(lii ill relation to I lis liolilless the 1);ilti 1,;t lilt -,iii(i the ('eiitriil '1'11)et@iii A(Iiiiiiiisti-@itioii ;it I)liiriiiisili as k%,ell is the (traiitlii(,, ot asvltiiii aii(i facilities to the 1)eople of 'Flt)et are Acts of' State ill exercise ot' tile Sovcreigiltv ot' lii(lia iii(i the saiiie call ii(.)t be (lealt ,A,Itii or iiitert'ere(i witli by aiiv Civil ('OLirt. ']'lie Stil)reiiie Court ot' lii(li@i lias liel(I repeite(il@, tliiit the iiiuiiicli)al Courts are flot coilipeteiit to (le-(tl witli tile ot- the Acts ot' St@tte. See for exaiiil)le, State ot' Sauritslitr@i \-. Neiiloii fla.ii lsiiiall AIR 1959 1383,

The SLIpreiiie ('otirt ol' liidia lias also liel(i repeatedly that Civil

Courts call iiot (10 ilito religious or (loctriiial matters. See for

L-

ex,iiiiple Siiilia IZtiiiiiiLi,',t V. lzaiiga Raiiiiiiti,'@i, Al IZ 1961 S(' 1720:

1 1

Advocate (iciier@il ot' 13oiilbay V. Yusul' All. AIR 1921 Boiilt)itv

338-, Devcliaild v. Gliaiislivaiii, AIR 1935 Boiiibay 361

4. Tile Defeiidailts subiiiit that iio allegations call be iiia(le agaiiist the Ceiitral Goveriiiiieiit without joliiijig the Ceiitral Goverilineiit as a 1)artv @iiid that the Ceiitral (ioveriiiiieiit call iiot be joiiied witliout coiiipilailce witli Sectioii 80 of the Code of Civil Procedure.

5 . I'lle Defeii(Iiiiits stibiilit that iieitlier His Floliiiess tile Dalai Laiiia ilor the Ceiltral Tibetaii Adiiiiiiistratioii at Dilaraiiis@tl@t call be proceeded agaiiist iii @t Civil Court except witli the coiiseiit of tii(,- ('eiitral Goveriiiiieiit certified by tile Secretary to tile Ceiitral Goveriiiiieiit iii-terins of Sectioii 86 of' tile Code of Civil Procedure.

6. His Holiiiess the Dalai Laiiia aiid tile Ceiitral Tibetail Adiiiiiiistratioii at Diiaraiiisala liave a special iiiteriiatioiial status uilder tile coiility of iiatioiis atid liave I)eeii awarded diplomatic iiiiiiiuiiity by the Miiiistry of Exteriial Affairs ot' the Goveriii-neiit of liidia aiid as sucil iieitiler His floliiiess the Dalai Laiiia iior iiiiy liitli t'LII)Ctioiiar),

ot' the 'I'it)et@iii Adiiiiiiistritioii at

Dliaraiiisala are aiiieiiable to the 'ur'sd'ct'oil of the

Civil Courts iii lii(lia.

7. Nc It lici- II is II() Iiiicss (lie 1),ili Iiiot- tiiy ()f'tllc

OtliCi- I )C I'c 11(lt I) (S IlilVe SLIt-rcii(ici-c(i to (lie

jurisdictioii of tlils lion'ble Court. 'I'Iiis written

statei-neiit is beiiit, filed witliout prejudice aiid to

L-

assert tilat this lloii'ble Court does ilot possess

.jurisdiction.

8. Tllls Hoii'ble Court lias iio jurisdiction as iioiie of the Defeiidaiit is resi(iiii,@ or carrying oil I)tisiiiess or

I"

I)ersoiially \vorkiiig tor ,aiii witliiii the local liiiiiis

L-

of tile 'tir'sdictioii ot' this floii'ble Court iii teriiis ot'

@j I

Sectioii 20 of the Code of Civil Procedure.

9. 'Flils Hoiloural)le Court lias iio jurisdicti(ii @is 110

3

allege(] civil or otlier cause of actioii ever arosc witliiii the local Iiiiiits of the jurisdiction ol' this lloii'l)le ('otirt ill teriiis of Sectioii 20 of' the ('o(le . of' Civil I)rocedut-e.

10. 'I'lic illc,,;Itioll's ill I-cg,,ii-tl to Iilege(l 11,11)1)Cllillgs

t-

outside the loc,@il Iiiillts of the 'urisdictioii ot' this @l

lioii'ble ('OLirt coilceril the years iiiucil aiiteric)r to the bar ot- the lilllit,111011 Llil(ler the litilititioii Act, 1963 ail(] e\,cii oil tllis sliort grouiid the Suit is ilot iiiaiiitaiiiable aiid liable to be disinisse(l.

li. I)AIZA(;RAI)FIWISII-l IZEIILY l'O

'['lie I)et,ell(l@ilits (Icily e;icli @iii(I every tvcriiiciit ill the fail)( CXCCI)( ill so far as it is expressly @idiilitte(I liereuiider ill tlils rei)l@, paragrapliwise:

Ilara I.

The Plaiiitiff No. I's description of Iiiinself is iiot admitted. All the averiliellis

ill relation to aiiy alleged research ail(] eacli aiid every allecatioii agaiiist the

"I

Defeildailts coiitaiiied ill the said para, wliicli ill aily eveilt relates to iioii-ci\.Il matters beyoiid tile iurisdictioii of aily civil court, are expressly all(] specifically (leiiied.

I-lara '-)

It is admitted that I-lis floiliiess the Dilai @\,@is aild is the spiritual aii(I temporal lzuler of 'ril)el aii(i ot' the 'I'il)etaii I)eol)le. 'I'lie allegation tile( lie ",,Is (reposed is deiiie(l. 'I'lic asyluiii giveil to liis lloliiiess the [)alai t.,tiiii ail(] (lic('eiitral 'I'il)etail A(iiiiiiiistratioii it 1-)Ilir@iiiisliil@i Is all Act ot' SLite ol' tile Goveriiiiieilt of lii(lia ail(] is beyoiid tile Iurisdictioii of' aily Civil ('otirt.

flara 3.

'I'lle averiiieiits ill relation to tlle 1-@itc f)ail(lit Iii",aiiirlal Neliru . . ['(riiier Priiiic

Miiiister of Iii(lia. or ill relation to tile @ille@),red 11011-eXeCLItiOll of a docuiiieiit, wliicl)

are ill @iilv e\,etit Acts ol' St@ite iii(I oti(si(le the 'uris(lictioii of aily (']\,if Court, Eric

- .1

iiot adiiiitte(l.

4

Para 4.

The averments in this paragraph.concerns the external -relations of India and exercise of sovereignty by the Government of India are,outside,tlie jurisdiction of any Civil Court, besides being vague and without particulars, and are not admitted.

Para 5.

The averi-neilt in relation to tile Late Paiidit Jawaharlal Nehru, fori-ner Prime Minister of India ' concerns tile external relations of India and the exercise the sovereignty by the Governi-neiit of India and are outside the jurisdiction of any Civil Court, besides being vague and without particulars, and are not admitted.

Para 6.

Tile averiileilts made in this paragraph are not admitted.

Para 7.

All the allegations made against the. people of Tibet in this paragraph are false and scandalous. and scurrilous and defamatory and are specifically denied. '@ The constitute political defamation and denigration. of a race and clearly fall, outside tile jurisdiction of any Civil Court, besides being opposed to and iii'violatioil ()f tile basic teiiets of the Constitution of India,

Para 8.

The allegations in' this paragraph are in the nature of political defamation and denigration and outside the jurisdiction of any Civil Court and false and scandalous and scurrilous and defamatory and are specifically denied.

Para 9.

The averilients in relation to the Government of China and the Government of India and permission granted by the latter pertaiii to AcL@ of State and are outside the jurisdiction of any Civil Court. It is admitted that Rum'tek is in Sikkim and outside the local limits of the jurisdiction of this Hoii'ble Court. Each and every allegation against tile Defendants is specifically denied. The rest is not adi'Ditted.

I-lara I 0.

All the allegations 'ii tiiis I)iii-@igral)li at),tiiist [)ct'eil(ltiii Nos. I tii(i -' -,Ill(l tile otll(,l

I I-

Defeiidaiits are specifically (leiiied. It is admitted that Ruintek is Outside tile local

liinits of tilis Hoil'ble ('ourt's jurisdiction.

Para II.

There is ilo clear averiileiit iii tllis paragraph. No stateiiieiit lie tills paragraph is

admitted.

Para 12.

The tllegitioii igiiii-st the I)et'eil(laiiis iii tli's is specifically (leii'e(l.

I

Para 13.

The averiiieilts aild alleg@itioil iii tllis paragraph rel@ite to foreign countries all(]

pertaiii tile i-natters clearly Outside tile itiris(lictioii of aiiy ('Ivll ('OLirt.

Para 14.

The averiiieiits ail(] allegation relatiiig to "religion iii(i politics" ail(] " 1642 At)"

I

ail(] "Moiigol Ciiieftaiii (;osliir Kliaii" are iiot 'ust'c'al)le by aiiy Civil ('ourt. No

j I I I

averiileilt or allecatioil iii tllis paragraph is adiiiitte(l.

Ilara 15.

It is adiilltte(I tilat I)et'eii(laiit No. I lias received the Nobel 11'e@ice Prize. 'I-lie allegations agaiiist I)et'eiidaiit No. I are false, sc@iiidalous. scurrilous ail(] (let',Ciiiiatory ail(] ire sl)eclf'lcilly (leiiied.

Paras 16 & 17.

The alle(yatioiis i@,aiiist I)efeildaiit No I iii tiiese paratraplis are specifically cleiiied.

Para 18.

The allegations agaiiist tile Defeiidaiits iii this paragraph are specifically dellie(l.

P@tra 19.

The allegations agaiiist the Defeiidaiits iii tills para(yrapli are specifically (leiiie(l.

6

f-lara

'I'lic @illegit'oiis @igaiiist the t)et' ii(lailts

I c III tllis I)iir@igr@ti)li are sl)eclt'lcilly (leiiie(l.

L'ar,i.s 2 1 &@, 22.

All the alletatioiis i,,aiiist tile Defeiidailts iii tllese paragraphs are specifically

deiiie(l.

I)ara 23.

The allegation iii tilis paracrapli is iiot admitted.

I)aras 24 25.

It is admitted that the Hoii'ble Higii Court at Patiia dismissed tile proceed,,,., I)roti(ylit 1)), Plaiiitiff No. I agaiiist tile Defeiidaiits ajid lield that tile iiiatter wits iloii-j'usticiable aiid that It' at all Plaiiitiff No. I desired lie sliolild iiiove the ilil)ropriate aLlIlloritv of tile Ceiltral Goveriiiileiit. All tile allegations against the I)et'eti(laiit are (leiiie(i. 'I'lie averiileiit that I'l@iiiitit't' No. I illove(I the @il,)I)rol)ri@iic @tutlioritn, of tile ('eiltral (ioveriiiileiit but to ilo is iiot adiiilttc(i for waiit (il'

kiiowledc,e.

Para 26.

'f'iie alleoatiolis i,@,aiiist the Defeiidatits iii this I)ara(,i-,il)li -,ire si)eclt'ic-tillv deilie(l.

t- -1 -

'riie, rest is iiot admitted for wailt of knowledge.

Para "@7.

'I'lic allegations a(,a'iist the L)et' ii(laiit 'II this pari,,rapli are spec'f"C!-,tily (leiiie(i

I e

Para 28.

The allegations against the Defeiidaiits are specifically (leilied. ]-lie rest is iiot admitted for waiit of knowledge.

Para 29.

The alleoatioiis a(,aiiist tile Defeiidaiits are specifically cleared. I'lie rest is il()t admitted for waiit of kilowledoe.

('. STJBMISSIONS:

1. It is sut)iiiltted that tile Suit is iiot iiiiiiitaiiiable uii(ler SeCLic)ii 38 ot'tlie Specific Relief Act, 1963 or uiider aiiy otlier I)rovisloiis of law. The I'laiiitiffs liave iio civil or otiler cause of actioii aiid tile Suit is liable to be disi-nissed iii Liiiiiiie.

it is subiii'tte(i tilat this Hoii'ble Court lias iio jurisdiction to deal witli iioil-civil matters. iii@itters of religious doctrine, political matters aiid matters coiiccriiiiig Act of' State. 'I'lle I)Ialiit disclose iio C@ILISC 01' lCtiOll Of' Civil iiature iii teriiis of' Sectioii 9 of the ('o(le of Civil Procedure aiid the Suit is liable to be dismissed iii liiiiiiie.

3 It is sut)iilitted that tilis Hoil'ble Court lias ilo territorial jLirisclictioii iii teriiis of Sectioii 20 of the Code of ('i\,Il Procedure as iloiie of the L)et'eii(lailts resi(le or carry oil business or personally work I-or ,,aiii wltlilii the local llinits of tile jurisdiction ot' this I-loii'l)le ('OLirt aii(i iio civil or otlier cause of' itcti(ii likes @triscii wltlilii tile local lfililts of, the tlr,s(l,ct, of' tlils lloii@t)le ('ourt aiid the Suit is liable to be (lisiiiissc.(] oil tlils sliort (,rouii(l.

L-

4. It is stibiiiltte(i tliit eveii according to tile I'l@ililtift' the @ille.2e(l ctuse of @ictioii arose iii (-;,iiigtok iii Sikkiiii -Iiii(i iii New Dellil I)otil of wlilcii places are

Outside the local limits of the I

I jurisd'ctioii of this

I-loil'ble ('OLirt.

5 . It is subiilltte(i tiiat the Suit is ilot prol)erin, valued.

6 . It is stil)iilitted that the Pialiltiffs are iiot entitled to Kelly relief iil(l it is PRAYED illat tll's Hoil'ble

I

Court iii@ty be 1)le,,ised to (lisiiiiss the Suit ail(] iwar(i exeiiiplarv costs to the Defeiidaiits iii view of the 1".@ilse,- sc@iii(i@tiotis, scurrilous @iii(I (ict'-Ctiii@itory statei,neilts iiiade by tile Plaiiitiffs.

1% I 1,

4 E. a- 5g- , -rt -

V I "I IZ I I-- I ('A'I'l () N

I . I ii(le(i , Soil (1,

t-

resi(iiii(I at

I-

aiid

a(,,ed soil of ---------------------

------------------------ resi(iiiig at ---------------------------------------------------------------------------------------------------------

lioldiiill @ILItiloritv to sl(,ii aiid verify tiiis writteii stateineilt oil behalf of the Defeiidaiits liereiii state that the stateineiits iiiade liereiiiabove a(ii-n'ttiiig or (Jellyiii(, or iiot adiilittiiig stateiiieiits iiiade iii the Plaiiit are base(] oil ii)v ktiowle(l(,e ail(] oil iiiforiiiatioii received aiid believed to be true aii(i tile rest is I)v

kN,a), of le(,al ot@jectioii aild subiiiissioils.

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9