In divorce case can dismissal petition (barred by law) be filed together with 340 CRPC

An Indian man marries a foreign (non hindu) woman under foreign law in the foreign country. The foreign wife only visits india from time to time after that using OCI card. Marriage is not registered under any Indian marriage act. Husband filed a divorce petition in India under special marriage act for cruelty, secretly with intention to get ex parte divorce, after doing many frauds against the wife whom he had married only to extort money. He prevented summons to wife by sending summons to a wrong address and case was proceeded ex parte against wife. But luckily just before judgement the wife comes to know about the matter and enters in the case in India. After setting aside ex-parte proceedings (order ix rule 7). now she wants to file two applications. To dismiss case due to lack of statutory jurisdiction in india (barred by law order vii rule 11(d)) and another application under 340 CRPC (379 BNSS) for perjury and false evidence and preventing summons etc. I have two questions. can both applications be given together in same hearing at the family court?. or one after other. Which to give first? If dismissal application is given first then how to give the other if case is dismissed? Can other offenses such as cheating, forgery etc by husband against wife that are not reported in the divorce petition of the husband be included in 340 CRPC application?