IN,

The Court of Sessions Judge

MUZAFFARPUR
A.B.P. No. 1666 of 2017

Amit Kumar Sinha ------------------------------ Petitioner

Versus
The State Of Bihar------------------- Opposite Party

The humble rejoinder-cum-objection on

behalf of the Complainant Abhiruchi to the

abovementioned Anticipatory Bail

Petition:----

Most Respectfully Sheweth:--------------

1. That the instant Anticipatory Bail Petition is not maintainable

either on Law or on facts and the same is fit to be dismissed in

limini.

2. That all the allegations made in the complaint petition are

absolutely true and correct.

3. That the complainant’s father was forced to pay a hefty sum of Rs.

Sixteen lacks cash and gold ornaments worth Rs. Four and half

lacks as dowry to petitioner’s father Anil Kumar Sinha. But the

present petitioner and his parents were not satisfied with the said

dowry and were demanding a Scorpio car and 10 bhar more gold

ornaments.

4. That the complainant was tortured for dowry by her in-laws and

specially by her husband on regular basis.

5. That on 08-05-2015 the complainant was beaten up and was

divested of her belongings by the petitioner Amit Kumar Sinha and

was ousted from her sasural. The complainant was rescued from

her sasural by her parents on 09-05-2015 and was taken to

Muzaffarpur and since then she is forced to live with her parents.

6. That the complainant was not ready to disclose her sufferings in

public and was avoiding legal recourse in hope of reconciliation

but the petitioner dragged her to Court in Matrimonial Case No.

235 0f 2016 for so called restitution of conjugal rights and leveled

 false and fabricated charges against the complainant. Forced by the

attitude of her husband and in-laws the complainant approached

the court and filed this complaint case disclosing her sufferings.

This fact has clearly been mentioned in paragraph 20 of the

complaint petition.

7. The petitioner has committed a serious crime as he has mercilessly

tortured the complainant and has persistently demanded dowry. He

deserves to be punished and his A.B.P. is fit to be dismissed.

8. That the petitioner works in Merchant Navy and regularly goes on

ship to foreign countries. The complainant has come to know that

the petitioner had gone on ship duty from 25-06-2017 to 03-08-

2017 on Yusho Ship of Wilhemsen Ship management Company. If

the petitioner is granted bail he will abscond, tamper with the

evidence and will not come to the court for trial of this case.

9. That in view of the circumstances mentioned above it is submitted

most humbly that the instant bail petition has no merits and is fit to

be dismissed. It is further submitted that the petitioner be directed

 to submit his Passport and CDC in original and he may not be

allowed to go on ship and leave India without prior permission the

Court.

It is, therefore, prayed that Your Honour

may graciously be pleased to dismiss this

Anticipatory bail petition and direct the

petitioner to submit his Passport and CDC

in original and he may be directed further

not to go on ship or leave India without

prior permission of the Court.

And for this the Complainant shall ever pray.

PETITIONER