The petition by the 62-year-old woman, a former public servant who worked in a regional passport office at Bengaluru, has sought quashing of the charges of cheating, forgery, criminal conspiracy under the IPC and Prevention of Corruption Act framed against her by a trial court here on June 8.
Similar charges have also been framed against two other public servants -- Jayashree Dattatray Rahate and Deepak Natvarlal Shah -- who have also been accused of helping Rajan procure a fake passport in the name of Mohan Kumar.
While Rajan is lodged in Tihar Jail here, the other three accused are out on bail.
Lalitha Lakshmanan has said in her plea that the incident of alleged issuance of fake passport to Rajan occurred in Bangalore in 1998-99 and hence the trial court in Delhi does not have the jurisdiction to try the case.
In her petition filed through advocate Satya Narayan Vashisth, she also contended that no sanction for prosecution was obtained under the Passports Act and Criminal Procedure Code prior to initiation of the proceedings against her.
The woman has claimed that back in 1998-99, checking of applications for passport renewal was done manually and she used to handle over 300 such applications every day between 2.30 pm to 4.30 pm, and at the most, she could only be accused of oversight.
She has also claimed that under the Passports Act, she has "protection of good faith".
According to CBI, Rajan had got his first fake passport issued from Bengaluru on January 1, 1998 allegedly in connivance with the other accused persons.
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