IN THE COURT OF DISTRICT & SESSIONS JUDGE, RAJKOT

BAIL APPLICATION NO. 106 OF 2019

IN THE MATTER OF:

NIKUNJ. SAHI ....... APPLICANT/ACCUSED

VERSUS

THE STATE
(GOVT. OF GUJARAT) ........ RESPONDENT

FIR NO. : 063/2018 DATED 17.11.2018

U/S : 363/366/376/114; 4,6 POCSO
P.S. : LODHIKA POLICE STATION
DISTT. : RAJKOT

FIRST APPLICATION UNDER THE SECTION 438 OF CODE OF CRIMINAL

PROCEDURE FOR GRANT OF ANTICIPATORY BAIL; FOR AND ON
BEHALF OF APPLICANT/ ACCUSED NAMELY NIKUNJ SAHI

MOST RESPECTFULLY SHOWETH:

The present case FIR was registered on the complaining statement of Victim
S who stated that Applicant/Accused used to hit her and touch her
inappropriately. True copy of FIR is annexed herewith and marked as
Annexure-A.

THE APPLICANTS/ACCUSED IS SEEKING HIS RELEASE ON BAIL ON

THE FOLLOWING AMONGST OTHER GROUNDS:

a. The Applicant/Accused is a young boy aged merely 23 years, and is

currently pursuing his studies, and is also gainfully employed. The
Applicant is a permanent resident of Rajkot, residing at the address as
mentioned in the memo of parties since more than two decades. The
Applicant is a law abiding and peace loving citizen of this country, who has
never been found of guilty for violating the law of the land.

b. The Applicant has been falsely implicated in the above noted case by the
Victim child at the instance of some interested persons. The Applicant is a
working individual and his working hours are from 9 AM to 9 PM each day.

c. It is humbly submitted that the family of the victim child comprises of her
mother namely Naliniben, who is a widow, one younger brother and one
sister.

d. Approximately a month back from the registration of the present case

FIR, mother of the victim child had to travel back to Jamnagar to attend