IN THE COURT OF Sh. NAVJEET BUDHIRAJA LD.ADDITIONAL SESSION JUDGE, SOUTH,

SAKET COURT, NEW DELHI

      IN THE MATTER OF:

      STATE

                                                -VERSUS-                      ABCDEF

                                                                              FIR NO-123/2019

                                                                                U/S– 302/120B/34

                                                                                       IPC & 25/27 Arms Act

P.S– TIGRI

INTERIM BAIL APPLICATION UNDER SECTION 439 CR.P.C. FOR A PERIOD OF 45 DAYS ON BEHALF OF ACCUSED ABCDEF

Most Respectfully Showeth:

1. That the applicant/accused is law abiding citizen and was permanently residing at Block-________, Sangam Vihar New Delhi with his mother namely  __________and Sister namely _________, applicant herein &was arrested in connection with the present FIR NO- 123/2
2. That the applicant/accused was arrested on 10/05/2019 in the aforementioned FIR  and he is currently in JC since May 2019 and facing ongoing trial ,awaiting the completion of his trial.
3. That During the ongoing trial , all eye witnessess and the complainant has been examined , leaving only the police witnesses pending.
4. That it is worth nothing that applicant/accused has diligently cooperated with the legal proceedings throughout this period.
5. That the primary reason for this interim bail application  is the upcoming Marriage of applicant/accused Mr. ___________`s sister namely ____________ scheduled for 10,Oct 2023. The copy of marriage card annexed herewith as annexure A.
6. That the applicant /accused father left home since Feb 2016, placing additional responsibilities on him to support his sister and mother and the mother of the accused /applicant lives with his sister without any help and financial support to survive.
7. That all the arrangements for marriage lie on the shoulder of the applicant/ accused and, as a brother, he has duties  towards his family which need to be fulfilled by him, as he is the only one to take care of and support his  old aged mother and sister.
8. That the applicant accused has served more than 4 years in JC and the behaviour of applicant /accused is unquestionable for the whole period of trial.
9. That the applicant /accused would be residing at block-__________, Sangam vihar New Delhi if this Hon`ble Court is pleased to release the applicant for availing his right to inetrim bail.
10. That the applicant /accused has not filed any other similar  petition before this or any other Hon`ble Court for granting of interim bail in case of present FIR.
11. That the applicant/accused belongs to a respectable family and has deep roots in society. The applicant is a permanent resident of Delhi and therefore, there are no chances of his absconding and/or fleeing from justice.
12. That the applicant /accused undertakes to appear before this Hon’ble Court or investigation officer as and when directed to do so. He further undertakes not to tamper with the prosecution evidence. He also undertakes not to misuse the concession of interim bail, if granted to him on any manner whatsoever.
13. That the applicant/accused undertakes to abide with the conditions as imposed by this Hon’ble Court while granting interim bail to him.
14. That the applicant/accused is ready to furnish sound surety to the satisfaction of this Hon’ble Court.
15. That the applicant/accused mother and sister are totally dependent upon the applicant/accused and the trail will take a long a time.

P R A Y E R

It is therefore, most respectfully prayed that this Hon’ble Court be pleased to

(i) grant interim bail for 45 days to the applicant; and

(ii) pass such other and further order as this Hon’ble Court may deem fit  and proper.

NEW DELHI

27.08.2023

APPLICANT/ACCUSED

               Through

Vikas Pandey & Asssociates (ADVOCATE)

NO. – _______, LAWYERS BLOCK, SAKET DISTRICT COURTS,

NEW DELHI – 110017

09717832755

E-MAIL ID – lawyervikaspandey@gmail.com