IN THE COURT OF SH. PUNEET PAHWA, LD. CMM, SOUTH SAKET COURTS, NEW DELHI

Bail Application No.______of 2023

IN THE MATTER OF;

      State                                                                                   Vs                                              Abcd

FIR No:1234/2023

U/s:379/411/34IPC

PS: Ambedkar Nagar

DOA-18.08.2023

APPLICATION FOR GRANT OF BAIL UNDER SECTION 437 CR.P.C ON BEHALF OF THE APPLICANT/ACCUSED NAMELY ABCD

 MOST RESPECTFULLY SHOWETH:

1. That the applicant/accused is peace loving and law abiding citizen of India and having deep roots in the society and belongs to a respectable family.
2. That on 18.08.2023, the applicant/accused has been apprehended by the police official of PS- Ambedkar Nagar from his house and falsely been implicated in abovementioned FIR and thereafter he has been produced before this Hon’ble Court and thereby he has been sent to the judicial custody as per direction/order of this Hon’ble court vide dated 21.08.2023 and since then he is in judicial custody. copy of FIR is annexed herewith for kind perusal of this Hon’ble Court.
3. That the applicant/accused is innocent and he has nothing to do with the alleged offence. He has falsely been implicated in the present case by the police officials of PS Ambedkar Nagar and there is no such recovery has been affected from the applicant/accused and same has been planted by the police official.
4. That the applicant/accused is a family member and he has responsibility to maintain his family as he is sole bread earner of his family.
5. That nothing incriminating has been recovered from the possession of the applicant/accused or at his instance, and applicant/accused was arrested on suspicious grounds by the police officials.
6. That the applicant/accused is having his past clean antecedents and he has not been previously involved or convicted in any case.
7. That the applicant/accused is ready to abide by all the terms and conditions imposed by this Hon’ble court at the time of grant of bail.
8. That the applicant/accused shall not misuse the liberty of bail provided by this Hon’ble Court and he will appear in the court on each and every date of hearing.
9. That the applicant/accused shall not temper with the prosecution witnesses and moreover the accused undertakes to abide by the order/direction of this Hon’ble Court.
10. That the applicant/accused shall furnish a sound surety to satisfaction of this Hon’ble Court.
11. That the applicant/accused is permanent resident of New Delhi as such there is no apprehension of his absconding or fleeing from the process of law. Moreover, the applicant/accused shall not temper with the prosecution witnesses at the time of trial.
12. That the applicant/accused belongs to respectable family and has been booked by the police official in the present false and fabricated case with anulteri or motive just to harass him.
13. That the investigation of the case has been completed and there is no purpose will be served by keeping the applicant/accused behind the bar.
14. That the applicant/accused further undertakes not to misuse the concession of bail in case he is enlarge on bail by this Hon’ble Court.

PRAYER

It is, therefore, most respectfully, prayed that this Hon’ble Court may kindly be pleased to release the applicant/accused on bail till the final disposal of this case, in the interest of justice.

    New Delhi

APPLICANT/ACCUSED

    Dated:10.08.2023

(IN J.C.)

THROUGH

Vikas Pandey & Associates

Advocates

Chamber No. _____, Lawyers Block

Saket Courts

New Delhi-110017

Mobile No. 9717832755

Email-id- lawyervikaspandey@gmail.com