The submission made before Justice Pratibha Rani against accused Joseph Palanivel Jeyapaul also states that the present "petition being without merits and deserves to be dismissed at the threshold".
"The contention raised by the fugitive criminal (FC) that the requesting state (USA) has sought extradition of the FC on the basis of second amended complaint and the first complaint is not there, so it is irrelevant for the purpose of present proceedings...
Jeyapaul, 59, had approached the High Court after his representation to the Centre challenging a trial court order recommending his extradition was rejected by the Ministry of External Affairs (MEA) on October 30 and an order to extradite him issued on October 31.
However, the High Court had November 3 restrained the Centre from extraditing the accused till today.
The reply also states "the complaint as well as the victim's affidavit clearly describe the manner in which the offence was committed and that too repeatedly.
"Even here in India, the apex court has time and again reiterated the principle of law in respect of rape cases that conviction can be done on the sole testimony of the victim.