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Issues: Whether an election petition seeking scrutiny and recount of ballot papers must plead material facts with sufficient precision, and whether recount can be ordered on the basis of vague or generalized allegations.
Analysis: A direction for inspection or recount of ballot papers is exceptional because secrecy of the ballot is a sacrosanct electoral principle. Such relief can be granted only when the petition contains an adequate statement of material facts, a prima facie case is made out, and the request is supported by proper contemporaneous material; recount cannot be used to embark on a roving or fishing inquiry. The distinction between material facts and particulars is important, but the petition must still disclose the core facts showing where, how, and in what manner the alleged irregularities occurred. Where the pleadings are vague, unsupported by particulars, and not matched by reliable proof, evidence beyond the pleadings cannot justify recount. Applying these principles, the allegations in the election petition were held to be too general and insufficient to sustain a direction for recount of the ballot papers.
Conclusion: The request for recount and inspection was not sustainable on the pleadings and evidence as presented, and the High Court's direction for recount could not stand.
Final Conclusion: The election petition did not satisfy the legal threshold for interference with ballot secrecy, and the impugned order directing recount was set aside.
Ratio Decidendi: Recount of ballot papers can be ordered only on a properly pleaded and prima facie substantiated case showing specific material facts and real necessity, and not on vague allegations that would amount to a fishing inquiry.