This application has been filed by the applicant/first defendant to reject the plaint.

2. It is the contention of the applicant that as per the plaint averments, the main grievance of the plaintiff is that the rejection of their nomination by the Honourable Observer, (Retired Judge of this Court) appointed in W.P.No.12968 of 2018 is bad. It is the contention of the applicant that the nominations were scrutinized by the Honourable Observer and he has found that certain nominations were invalid on the ground that either the proposer district or the seconder district and in some cases both the districts were in arrears to the association as on March 15th, 2018. Therefore, as per Article X and XII (h)(iv) of Articles of Association, their nominations were rejected. It is the further contention of the applicant that as per Article X of the Articles of Association, only a District Association, who has no arrears and have paid their subscription on or before 15th of March of that year will alone be eligible to vote in the election. Similarly, the nominations will be valid only if the proposer and seconder are from two different district associations who are eligible to vote. Therefore, only the District Association who are not in arrears to the Association as on March 15th 2018 are alone eligible to vote and nominate in the election held on 27.05.2018. Since, the nomination of certain candidates including the nomination of the present plaintiff herein was not in accordance with Article X and XII (h) (4) of the Articles of Association, the Honourable Observer appointed by the Honourable Court has rejected the nominations. The plaintiff has challenged the said rejection of nomination in the present suit. However, the plaintiff has not filed any documents along with the plaint to show that the proposer and the seconder districts have paid their subscription fees before March 15th, 2018. In the absence of the said document, the plaint averments do not disclose any cause of action. Further, the plaintiff has filed a letter dated 27.05.2018 addressed to the Honourable Observer wherein she has categorically admitted that her nominations and certain other candidate's nomination are not in accordance with Article X and XII (h) (4). Therefore, in the light of the admission made by the plaintiff in her letter dated 27.05.2018, the plaint is liable to be rejected on the ground of non-disclosure of cause of action.

3. The respondent/plaintiff filed counter denying the entire allegations. It is the case of the plaintiff that the entire election process was erroneous and even the Order in W.P.No.12968 of 2018 has been obtained behind the back of the plaintiff by playing fraud on Court and by collusion. The further contention is that the sub Committee which was formed consisting of 5 members as per the Article XII(h)(i), the said members should issue the valid nomination list. But the Sub Committee got divided into two groups and Sub Committee published 2 different lists which itself goes against the Articles of Association. Various such vital grounds have been raised in the plaint and it is not as projected by the applicant. The plaintiff has also filed documents to show that her nomination and certain others have been duly accepted by the Sub-Committee which released the list of eligible voters in which the plaintiff name also figured. In fact the plaintiff has also filed documents to show that most of the voters and Association have protested before the Honourable Observer and the Observers, who were appointed by the parent body, i.e., TTFI, have also expressed their view before the Honourable Observer that the nomination list given by the Sub Committee consisting of 3 persons was valid. Therefore, the allegation that the plaintiff has filed no document is false and prayed for rejection of the application.

4. It is the contention of the learned counsel for the applicant/first defendant is that the main grievance of the plaintiff is that the r