BEFORE THE HON’BLE MOOT COURT OF SESSION JUDGE, AT CNLU,

PATNA

ABP NO.- 01/2021

RAJ KARAN DAFTARI…………. ACCUSED PERSON

V/S

THE STATE OF BIHAR …………………... Prosecution

Most respectfully sheweth,

1. That bail objection filed before the court by the state for cancellation of
anticipatory bail petition filed by accused, who has been charged under Economic
offenses Case No. 19 of 2021 lodged U/S 406, 420, 465, 467, 468, 471 & 34 of
The Indian Penal Code of 1860 along with Section – 81 of Bihar Value Added
Tax Act of 2005 and Section- 10A of Central Sales Tax Act of 1956.
2. That in reply to statement made in paragraph 2,3 and 4 it is stated that it is a
matter of fact and needs no comment.
3. That his past reputation is of no relevance in the present case.
4. That the offence of forgery and cheating among other offences have been
committed by the accused, which are non-compoundable in nature and are penal
offences for which liability of the accused persons exists apart from the liability
under Section 81 of Bihar Value Added Tax Act 2005 and Section 10A of Central
Tax Act 1956.
5. That the petitioner is not a law-abiding person, which is apparent from his
company’s (accused company) action of forging challan. Security and sureties
should be taken from the accused to ensure his presence in the trial.
6. That accused may try to tamper the evidence to mislead the court.
7. That the petitioner may directly or indirectly make any inducement, threat or
promise to any person acquainted with the facts of this case so as to dissuade him
from disclosing such facts to the court or police.
8. That the petitioner being a wealthy person and a person of means can elope to
other country to escape criminal charges pending against him.

It is therefore prayed your Honour maybe pleased to

reject the application made by the accused to secure
anticipatory bail and pass any such order as it deems fit.