Legal Drafiing

ANTICIPATORY
BAIIL
APPLICATION FOR
CRIMINAL PROCEDURE
CODE 191
US 438
OF THE
SESSIONS JUDGE, PUN
IN THE
COURT OF TIIE DSTRICT K
Misc.Application No. /20

Shri AB_C. Applicant

Age 36 years, occupation social worker,
Resident of 175 Deccan Gymkhana,
PUNE411 004.
Versus
The State of Maharashtra Opponent

AN APPLICATION FOR THE GRANT OF BAIL

U/S 438 OF THE CRIMINAL PROCEDURE CODE 1973

The applicant abovenamed submits this application, praying to state as follows:

. That the applicant is a social worker and active member of the Shiv Sena Party.
2. That the applicant has been serving the cause of society for the last more than
twentyfive years.
3 That during the recent by-election to the Pune Municipal Corporation in Ward No.
50,the applicant got elected with a large number of votes against his rival candidate,
Shri XYZ, who belongs to the Congress-I Party.
4.
4. That during the election campaign, there were a great many allegations made by
the members of both the parties, and the said Congress-I candidate tried his best
to make all the malicious attempts with a sole intention to defeat the candidature
of this applicant.
5. That the said Congress-I candidate could not withstand his defeat in the election,
and since the date of the declaration of the election result on the situation as
a whole has gone bad to worse.
6. That on or about, ,aperson alleged to have been an active member of the
Congress-I Party was stabbed, and he died the following day.
 7. That the Legal Drafting
applicant believes that
on account of such unhealthy
indulged
have been
into by the said defeated
candidate, some maliCIOUs
political.
plans an
political activities
ate this
worked out with an intention so as to implicate this n and desvgw
COmmitted or concerned with such a non-bailable ofrenC. applicant fo
for having
8. That the applicant submits that since the date of the
declaration of of the.
the election
result _this applicant had gone to Tirupati Balaji on
on on aa pilgrimao
pilgrimage
when he returned back to the headquarters only yesterday night, he
he cama tour, and
came to
about such an accusation against him, and hence, this application.
know
9. That the applicant states and submits that he had no concerned with
offence, if committed by some miscreants, and the contention of this any s
this appli
applicant Such
wi
be explicit from the very fact that this applicant was out of
headquarter
rters througho
and thus, he is innocent, too0.
10 That the applicant apprehends that he may be arrested on such an accusatin
hence, this application. ion
11. That thisapplicant furthermore submits that if this application is not grantad
the Hon'ble Court,
flagrant injustice will be done to him for no fault on
12. That the his noart.
applicant also believes that he will not be deprived of his
fundamental right. legitimate
ate and as

13. That the proper court-fee is

paid herewith.
14. That the
applicant, therefore, prays that this application be
orders granting an kindly allowed a
anticipatory bail be issued in favour of this
Pune, applicant.
Sd/-ABC
Dated: APPLICANT

Sd/- x XKx
ADVOCATE FOR APPLICANT
VERIFICATION
1, Shri ABC, the present
the contents
of applicant, do hereby ionto
this application in paras 1 to 14 are truestate on solemn affirinabest ofm
knowledge and belief, so I have and correct to
Ue
signed hereunder.
Sdi-ABC

APPLICAN