Surrender Petition

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IN THE COURT OF THE HON’BLE VII ADDL.

DISTRICT AND
SESSIONS JUDGE, AT guduru, Nellore DISTRICT

CRL.M.P.NO. OF 2019
IN
Crime .NO. 123 OF 2018
Of podalakur P.S.

Between
1) Polaiah Bommi, --
S.C Madiga, male,
aged about 44 years,
Arundathiawada,
Mudigedu Village,
Podalakur Mandal,
SPSR Nellore Dist.

2) Penchalaiah Bommi, --
S.C Madiga, male,
Aged about 48 years,
Arundathiawada,
Mudigedu Village,
Podalakur Mandal,
SPSR Nellore Dist.

3) Vara Lakshmi Bommi,


S.C Madiga, male,
Aged about 45 years,
Arundathiawada,
Mudigedu Village,
Podalakur Mandal,
SPSR Nellore Dist. --- petitioner/Accused( A.2 to A.4)

And

The State SHO, L&O


Podalkur P.S.
..Respondent/Complainant

petition FILED ON BEHALF OF THE PETITIONERS/ACCUSED Nos.2,3 and


4 UNDER SECTION 44(2) OF CRIMINAL PROCEDURE CODE 1973.
1. It is humbly submitted that the petitioners were shown as accused No.s
2,3 and 4 in crime no.123/2018 for the alleged offence u/s 307, 324 r/w
34. Of IPC.
2. It is submitted the petitioners apprehend immense danger in the hands of
respondents as they are trying to arrest them and for getting confessional
statements the police might apply 3rd degree methods.
3. It is further submitted that the petitioners/accused No.s2,3 and 4 had
nothing to do with the alleged offence and they are very innocent in the
above crime. All the allegations made aginst them are not true and
correct and are only created to harss the petitioners/accused No.s 2,3 and
4.
4. It is submitted as per the direction of Hon’ble High court in crl.p
161/2019 the petitioners were directed to surrender before the Hon’ble
Trial court and to apply for regular bail, and Hon’ble High court has also
directed the Trial court to dispose of the bail application on the same day
of its filing upon merits.
5. It is further submitted that as per the direction of Hon’ble High court, the
petitioners/accused 2 to 4 are surrendering before this court and they are
ready to face the prosecution case.
6. Hence, it is prayed that this Hon’ble Court may be pleased to accept their
surrender and send the petitioners/accused No.s2,3 and 4 to judicial
custody in the interests of justice and equity

Filed by : Be pleased to consider,

A. 2.

A. 3.

A.4.

Advocate for petitioners/accused 2 to 4. Petitioners/Accused 2 to 4

Guduru,

Date: 12-03-2019.

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