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Issues: Whether an election petition alleging non-compliance with electoral procedure under Section 100(1)(d)(iv) of the Representation of the People Act, 1951, but failing to disclose material facts with specificity, could be rejected at the threshold.
Analysis: Material facts in an election petition mean the basic primary facts constituting a complete cause of action, while particulars are only supporting details. The statutory requirement under Section 83(1)(a) is mandatory, and omission of even a single material fact renders the petition defective. The provisions of the Code of Civil Procedure apply to election trials under Section 87, so the court may invoke Order VI Rule 16 and Order VII Rule 11 where the petition discloses no complete cause of action. On the pleadings, the alleged omission by the Returning Officer was not supported by specific averments explaining how the result of the election was materially affected, and the pleading remained vague.
Conclusion: The election petition was rightly rejected at the threshold for disclosure of material facts and failure to plead a complete cause of action.
Ratio Decidendi: An election petition that omits material facts necessary to constitute a complete cause of action is liable to be dismissed at the threshold, and the defect cannot be cured by vague or incomplete averments.