IN THE COURT OF SESSIONS JUDGE RAIGAD AT

ALIBAG

Cri. Misc. Application No.872 / 2012.

MR. PRAKASH SHIVRAM MORE, )

Age-47 years, Occupation –Nil, )

R/o-202, Balaji Prangan, Building No.5, )

Sect- 4, Kharghar, Taluka- Panvel, )

Dist- Raigad. ) Applicant.

Vs.

Senior Police Inspector, )

Crime branch, Panvel, Navi Mumbai. ) Opponent.

APPLICATION FOR GRANT OF BAIL BEFORE ARREST

IN PANVEL CITY POLICE STATION COMPLAINT
APPLICATION FILED AGAINST APPLICANT FOR
OFFENCE PUNISHABLE U/S 420 OF I.P.C.

MAY IT PLEASE YOUR HONOUR,

It is to submit most humbly on behalf of the applicant

that,

1)The Applicant is joint owner of flat no. 202, Balaji

Prangan, Building No.5 Sect- 4, Kharghar, Taluka-
Panvel, Dist- Raigad along with his wife, Mrs. Prajakta
Prakash More.

2) That, one Mr. Ramesh Vig has filed a complaint

application in Panvel City Police Station, making
allegations of cheating, which is based on totally false
story.
 ..2..

3) In fact, said Mr. Ramesh Vig, met the Applicant in

June 2012, at Kharghar, with intention to buy the said
flat of the Applicant. In the said meeting the
consideration price was fixed Rs. 52,00,000/-
between both the parties. Accordingly an agreement
was entered between the parties, but copy of which is
not furnished to the Applicant till date. Mr. Ramesh
Vig had paid Rs. 10,00,000/- to the Applicant, out of
sale price. However, subsequently, said Mr. Ramesh
Vig told to the Applicant that, he is not able to
complete the said deal because of shortage of money.
He also told to the Applicant that, this deal is
cancelled and you should return the money back. At
that time the Applicant informed to Mr. Ramesh Vig
that, he has no money as he incurred huge
expenditure, as he was sure about this deal, so he
should pay the balance sale price and complete the
deal.

4) However, Mr. Ramesh Vig, was not ready to

complete the said deal, hence he put up the another
proposal to the Applicant that, the money, received by
the Applicant, shall be treated as loan money at the
rate of 15 % per annam, to which the Applicant
agreed. But subsequently at the time of payment of
interest amount, Mr. Ramesh Vig, recovered interestat
the rate of 15 % per month from the Applicant.
Accordingly, till date Mr. Ramesh Vig has recovered
Rs. 5,50,000/- totally from the Applicant.

5) When Mr. Ramesh Vig cancelled the deal and

compelled to treat the money paid as loan money, at
that time as a security, he got executed another false
mou in respect of the said flat in the name of his
brother in law, Mr.Narendra H. Bemby. Not only had
this but he also obtained some cheques from the
Applicant towards the security. Thereafter, Mr.
Ramesh Vig and his brother in law both harassed the
Applicant for registration of the said mou and
signatures of wife of the Applicant etc. They
approached to Vashi police station and Kharghar
Police station also against the Applicant. However,

..3..

nothing happened there, hence now Mr. Ramesh Vig

and his brother in law both are approached to panvel
City Police station as mentioned above by filing
complaint application against the Applicant.

The Panvel City police are calling the Applicant in

the police station and they are about to register crime
against the Applicant and arrest him under section
420 of IPC.

6) Therefore, the Applicant has filed this application

for obtaining bail before arrest in the said matter on
following amongst many other grounds-

A. No offence is committed by the applicant.

B. The applicant is innocent person.

C. That, the dispute between the parties is of civil

in nature, so also there is no requirement of
arrest of the applicant.

D. The investigating officer Mr. Mulani has already

interrogated the Applicant in three visits of the
Applicant in Panvel City Police station.

E .The applicant is local resident of the Kharghar

and is having immovable property in his name,
so, there is no chance for any absconding of the
applicant.

F. The applicant is ready to furnish surety of

suitable amount abide by terms & conditions of
the order of this Hon. Court.

G . In fact, there is no any offence committed at the

hands of the Applicant.
 ..4..

So taking in to consideration the above

mentioned grounds and reasons, the application of
the applicants may please be allowed and bail
before arrest my please be granted to the applicants
and obliged.

ALIBAG

DATE: 19/12/2012 ADV. FOR APPLICANT

 IN THE COURT OF SESSIONS JUDGE RAIGAD AT
ALIBAG

Cri. Misc. Application No. / 2012.

MR. PRAKASH SHIVRAM MORE, …… Applicant

Vs.

Senior Police Inspector,

Panvel City Police Station, Panvel. …Opponent.

APPLICATION FOR INTERIM BAIL BEFPRE ARREST

MAY IT PLEASE YOUR HONOUR,

It is to submit most humbly on behalf of the applicant

that,

1)The Applicant is joint owner of flat no. 202, Balaji

Prangan, Building No.5 Sect- 4, Kharghar, Taluka-
Panvel, Dist- Raigad along with his wife, Mrs. Prajakta
Prakash More.

2) That, one Mr. Ramesh Vig has filed a complaint

application in Panvel City Police Station, making
allegations of cheating, which is based on totally false
story.

3) In fact, said Mr. Ramesh Vig, met the Applicant in

June 2012, at Kharghar, with intention to buy the said
flat of the Applicant. In the said meeting the
consideration price was fixed Rs. 52,00,000/-
between both the parties. Accordingly an agreement
was entered between the parties, but copy of which is
not furnished to the Applicant till date. Mr. Ramesh
Vig had paid Rs. 10,00,000/- to the Applicant, out of
sale price. However, subsequently, said Mr. Ramesh
Vig told to the Applicant that, he is not able to
complete

..2..

the said deal because of shortage of money. He also

told to the Applicant that, this deal is cancelled and
you should return the money back. At that time the
Applicant informed to Mr. Ramesh Vig that, he has no
money as he incurred huge expenditure, as he was
sure about this deal, so he should pay the balance sale
price and complete the deal.

4) However, Mr. Ramesh Vig, was not ready to

complete the said deal, hence he put up the another
proposal to the Applicant that, the money, received by
the Applicant, shall be treated as loan money at the
rate of 15 % per annam, to which the Applicant
agreed. But subsequently at the time of payment of
interest amount, Mr. Ramesh Vig, recovered interestat
the rate of 15 % per month from the Applicant.
Accordingly, till date Mr. Ramesh Vig has recovered
Rs. 5,50,000/- totally from the Applicant.

5) When Mr. Ramesh Vig cancelled the deal and

compelled to treat the money paid as loan money, at
that time as a security, he got executed another false
mou in respect of the said flat in the name of his
brother in law, Mr.Narendra H. Bemby. Not only had
this but he also obtained some cheques from the
Applicant towards the security. Thereafter, Mr.
Ramesh Vig and his brother in law both harassed the
Applicant for registration of the said mou and
signatures of wife of the Applicant etc. They
approached to Vashi police station and Kharghar
Police station also against the Applicant. However,
nothing happened there, hence now Mr. Ramesh Vig
and his brother in law both are approached to panvel
City Police station as mentioned above by filing
complaint application against the Applicant.
 The Panvel City police are calling the Applicant in
the police station and they are about to register crime

..3..

against the Applicant and arrest him under section

420 of IPC.

6) Therefore, the Applicant has filed this application

for obtaining bail before arrest in the said matter on
following amongst many other grounds-

7) Since last week, police are calling the applicant for

his arrest and to produce him before Court. Not only
this but police searching the applicant as he did not
appeared to police station for arrest. Police are visiting
the residence of the applicant frequently. So the
applicant is suffering grate inconvenience and
hardship.

8) Hence the applicant has filed an application for

grant of bail before arrest, which is pending for
decision. It will take time to decide the application, till
then interim protection by way of interim bail before
arrest is required to be granted to the applicant.

So, the applicant prays hereby that, interim bail

before arrest may please be granted to the applicant &
obliged.

ALIBAG

DATE: 19/12/2012 ADV. FOR APPLICANT

 IN THE COURT OF SESSIONS JUDGE RAIGAD AT
ALIBAG

Cri. Misc. Application No. / 2012.

MR. PRAKASH SHIVRAM MORE, …… Applicant

Vs.

Senior Police Inspector,

Panvel City Police Station, Panvel. …Opponent.

ADDRESS MEMO OF THE APPLICANTS

R/o-202, Balaji Prangan, Building No.5,

Sect- 4, Kharghar, Taluka- Panvel,

Dist- Raigad.

ALIBAG

DATE: 19/12/2012 ADV. FOR APPLICANT

 IN THE COURT OF SESSIONS JUDGE RAIGAD AT
ALIBAG

Cri. Misc. Application No. / 2012.

MR. PRAKASH SHIVRAM MORE, …… Applicant

Vs.

Senior Police Inspector,

Panvel City Police Station, Panvel. …Opponent.

LIST OF THE DOCUMENTS FILED ON BEHALF OF

THE APPLICANT.

1) Copy of mou prepared by the complainant.

2) Copy of the address proof of the Applicant.

ALIBAG

DATE: 19/12/2012 ADV. FOR APPLICANT