BEFORE THE LEARNED METROPOLITAN MAGISTRATE

RAILWAY COURT, ANDHERI, AT MUMBAI

CASE NO. PW / 127 / 2016

1. Adil Aneez Siddiqui

2. Farah Adil Siddiqui …Applicant
/Accused No. 4 & 5

In the matter between

OSHIWARA POLICE STATION …Complainant

Vs

FAHAD ABBASI & Ors. …Accused

APPLICATION TO TAKE PERMISSION TO TRAVEL ABROAD

MAY IT PLEASE YOUR HONOR:

1. The Applicants are arraigned as Accused No. 4 and 5 in the above

mentioned case. The Applicants are husband and wife and Brother in
Law and Sister in Law of the First Informant i.e Mrs. Huma Fahad
Abbasi. The Applicants are residents of Delhi.

2. The Applicant states that the First Informant viz. Mrs. Huma Fahad
Abbasi lodged an alleged First Information Report bearing No. ___
of_____ with the Oshiwara Police Station under Section 498A of the
Indian Penal Code against her Husband Mr. Fahad Abbasi, Father in
Law, Mr. __________,Mother in Law Mrs. _________ and the
Applicants herein. Thereafter, upon getting knowledge of the same, the
Applicants herein immediately preferred Anticipatory Bail Application
No. 627 of 2015 before the Hon’ble Sessions Court, Bombay.

3. The Applicant states and submits that by an Order dated __________the

Hon’ble Sessions Court, Bombay was pleased to allow the aforesaid
Anticipatory Bail Application No. 627 of 2015 and granted Anticipatory
Bail to the Applicant on such terms and conditions mentioned therein.
Hereto annexed and marked as Exhibit “A” is the copy of the Order
dated ______ passed by the Hon’ble Sessions Court, Bombay in
Anticipatory Bail Application No. 627 of 2015.
4. The Applicants state and submit that the Applicants have always adhere
to the conditions imposed by the Hon’ble Sessions Court.

5. The Applicants states that the Applicants have a daughter namely, Zaina
Adil Siddiqui age _______ presently residing with the Applicants in
Delhi. The Applicants’ daughter is scholar and a bright student. On the
basis of her academic aptitude and progress, she desired to peruse her
undergraduate studies at University of Victoria in Canada. The
University of Canada has also appreciated her education profile and
allowed her Study Permit Information. Hereto annexed and marked as
Exhibit “B” is the copy of the Study Permit Information issued by
University of Victoria, Canada to the Applicants’ daughter.

6. The Applicants most respectfully state and submit that for the purpose
of supporting their daughter to settle initially in a new place, they are
desirous of travelling along with their daughter from the period of
___months. Hereto annexed and marked as Exhibit “C” is the copy of
the Applicants’ Aadhar Card and Passport.

7. The Applicant states that

It is submitted that the Respondents / Accused have discharged their earlier

advocate on record and have engaged the present Advocate to plead and act
on behalf of them. The present Advocate has tendered his Vakalatnama
today i.e. on 23rd October 2019 before this Hon’ble Court.

The Respondents/Accused are in personal difficulty and therefore cannot

remain present before this Hon’ble Court today. It is therefore prayed that
the Respondents be exempted for the day and the matter be adjourned for a
period of 3 weeks.

Mumbai
23rd October, 2019

Advocate for the Respondents