IN THE COURT OF THE HON’BLE METROPOLITAN SESSIONS

JUDGE AT : HYDERABAD

Crl.M.P. NO. OF 2018

In
Cr.No. 89 of 2018
(P.S. Dabeerpura)

Between:
Abdull Aziz Mohd, S/o. Syeed Mohd Ataf,
Aged about 29 years, Occ: Real Estate (Business)
R/o. H.No. Razi Millath Colony,
Falaknuma, Hyderabad.
…Petitioner/Accused No. 5.
AND

The State of Telangana

Through P.S. Dabeerpura.
…Respondent/Complainant

PETITION FILED U/S.439 OF Cr.P.C.

Offence U/s. 307, 109, 120(b) of IPC R/w. 34 IPC

Date of Offence : 18.07.2018

Date of FIR : 19.07.2018
Date of Remand : 21.07.2018

May it please your Honour,

The above named petitioner humbly begs to submit as follows:

1. It is submitted that, petitioner herein is shown as Accused in

the above case and he was falsely implicated by the Respondent
police.

2. The allegation of the prosecution is that on 19-07-2018 at 01-

30 hours received a statement of LW-1 recorded by the LW-13 in
which the LW-1 stated that his occupation is waste paper business
that shop and godam is situated at near New Life Hospital,
Chadarghat yesterday night i.e. 18-07-2018 at 22-20 hours after
closing his godam he started to his home at Edi Bazar, Yakutpura
on his two wheeler Honda Activa on the way to his house when he
was reached between Owisi bridge and seven temple there unknown
persons came on motor bike from back side at about 22-30 hours
stabbed him on his left side below the neck and over taken him
from the left side and ran way. Due to which he received bleeding
injury. And his scared and take U turn used to away to go to
Dabeerpura Police Station via Owisi bridge, Dabeerpura PS shifted
to OGH for treatment. He requested to take necessary action in this
matter.

Basing on the contents of the statement the police Dabeerpura

registered the above crime for the offence U/sec. 307 of IPC R/w.
34 IPC.

It is submitted that the petitioner / Accused No. 5 is innocent

and he is nothing to do with the alleged offence and entire
allegations made against him are false, baseless, the petitioner
prefer the following grounds:-

GROUNDS

1. It is submitted that the petitioner / Accused No. 5 has never

committed the alleged offence and falsely implicated him in the
above alleged offences.

2. It is submitted that the petitioner herein is having good

reputation among the society and permanent resident of above
address and having clean antecedents.
3. It is submitted that the petitioner is an innocent and he is
eking his livelihood by doing business and nothing to do with
the alleged offence.

4. It is submitted that the de-facto is having family disputes with

the accused no.1 in regarding the financial matter to evade the
debt he was falsely concocted story that some unknown
persons attacks on him and basing on the false story he was
falsely implicated in the above case.
5. It is submitted that the police Dabeerpura already completed
the total investigation and examined the all the material
witnesses and there is no investigation is pending.

6. It is submitted that the petitioner is ready to cooperate with

the investigation if any pending and abide any conditions
imposed by this Hon’ble court and ready to furnish sureties to
the satisfaction of this Hon’ble court.

7. It is submitted that after the arrest of the petitioner / Accused,

the petitioner’s mother become very sick and undergoing for
high B.P., and Sugar.

8. That this is the Second bail petition filed before this Hon’ble
court and first bail petition was dismissed on 08.08.2018 vide
Crl.Mp.No. 2338 of 2018 and no similar petition is filed or
pending before any other court of law for the similar relief.

9. It is submitted that the Hon’ble court while dismissing the first

bail petition on the ground that “there is every likelihood of his
interfering with the investigation or absconding from the
jurisdiction of the court”. The petitioner/A5 undertakes that
he will not interfere in the investigation or he will not abscond
from the jurisdiction of the court till disposal of the case.

10. The other grounds will be urged at the time of arguments.

It is therefore prayed that this Hon’ble court may be pleased to

enlarge the petitioner / Accusedno.5 on bail on such terms and
conditions which may deems fit and proper in the interest of
Justice.

Place: Hyderabad
Date: 13.08.2018 Counsel for the Petitioner/
Accused
 IN THE COURT OF THE HON’BLE
METROPOLITAN SESSIONS JUDGE
AT : HYDERABAD

Crl.M.P. NO. OF 2018

In
Cr.No. 89 of 2018
(P.S. Dabeerpura )

BETWEEN:
Abdull Aziz

…Petitioner/
AccusedNo.5
AND

The State of Telangana

Through P.S. ADabeerpura.
…Respondent/
Complainant

PETITION FILED U/S.439 OF Cr.P.C.

Filed on: 13.08.2018

Filed by:
____________________________________
B NACHIKETH
Advocates & Associates
Hyderabad
____________________________________

COUNSEL FOR PETITIONER /

ACCUSEDNO.5