Strict proof in corrupt practice and undue influence claims governs election disputes; volunteer canvassers are not agents without authority.

Corrupt practice allegations in election matters are quasi-criminal and must be pleaded with clarity, specificity, and strict proof by the petitioner; the burden does not shift to the returned candidate. An election tribunal may insist on particulars and may refuse late amendment after limitation. A volunteer canvasser is not an agent of a candidate unless authority or consent is shown, and false-publication liability depends on proving agency and the requisite falsity or prejudice. Undue influence requires coercion, restraint, or domination, not mere advice or persuasion. On these principles, the proposed grounds were treated as factual, settled, or academic, and no substantial question was fit for certification.

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Issues: (i) whether allegations of corrupt practice in an election petition are quasi-criminal and require proof to a high standard; (ii) whether the Election Tribunal could refuse amendment or furnishing of particulars after the limitation period; (iii) whether a volunteer canvasser can be treated as an agent of a candidate for fastening liability for corrupt practice; (iv) whether the impugned publication and related conduct amounted to corrupt practice under the provisions dealing with false statements and prejudicial publication; and (v) whether the request made to a rival candidate to withdraw from the contest amounted to undue influence.

Issue (i): whether allegations of corrupt practice in an election petition are quasi-criminal and require proof to a high standard.

Analysis: Charges of corrupt practice were treated as quasi-criminal in character, requiring allegations to be clear and precise and the ingredients of the charge to be proved by the petitioner. The burden did not shift to the returned candidate to disprove the ingredients, and a mere insufficiency of evidence could not justify certification for appeal.

Conclusion: The issue was answered against the petitioner.

Issue (ii): whether the Election Tribunal could refuse amendment or furnishing of particulars after the limitation period.

Analysis: The Tribunal was held justified in insisting on clear and specific particulars before inquiry into corrupt practice could proceed. Since the request to supply particulars came after the limitation period for election petitions, refusal to permit amendment was treated as a proper exercise of discretion.

Conclusion: The issue was answered against the petitioner.

Issue (iii): whether a volunteer canvasser can be treated as an agent of a candidate for fastening liability for corrupt practice.

Analysis: Agency in election law was held to require some authority or consent from the candidate or authorised election agent. A mere volunteer supporter or canvasser, without such authority, could not make the candidate liable for the volunteer's acts. On the facts, the alleged person was found not to be an agent, and the finding was one of fact unsupported by evidence for purposes of leave.

Conclusion: The issue was answered against the petitioner.

Issue (iv): whether the impugned publication and related conduct amounted to corrupt practice under the provisions dealing with false statements and prejudicial publication.

Analysis: The petitioner failed to establish that the editor concerned was the candidate's agent or that the statement was believed to be false in the relevant sense. The further factual finding was that no prejudicial corrupt practice was proved on the evidence, including the alleged effect on the election result.

Conclusion: The issue was answered against the petitioner.

Issue (v): whether the request made to a rival candidate to withdraw from the contest amounted to undue influence.

Analysis: Undue influence was explained as conduct that overbears free agency by restraint, domination, or coercion. Advice, persuasion, or solicitation, even if earnest, was distinguished from legally undue influence. The evidence showed that no threat or pressure was applied, no inducement was offered, and the candidate withdrew after consulting her workers and acting on her own volition.

Conclusion: The issue was answered against the petitioner.

Final Conclusion: No substantial question fit for certification to the Supreme Court was shown, as the proposed questions were either concluded against the petitioner on merits, dependent on factual findings, or merely academic.

Ratio Decidendi: For leave under Article 133(1)(c), questions based on settled principles or pure findings of fact do not justify certification, and in election matters corrupt practice and undue influence must be strictly proved by clear, specific, and legally sufficient evidence.

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