Haveri Lokayukta PS Crime No: 12/2023

IN THE COURT OF THE PRL DISTRICT AND SESSIONS

JUDGE HAVERI AT HAVERI.

Complainant : State of Karnataka

By Haveri Lokayukta Police
V/s

Accused : 1] Andaneppa S/o Malagirayappa Vadageri

Age: 59 Years, Occ: Govt Servant
DDPI Haveri, R/o: Ijarilakamapur
Haveri.

2] Dattatraya Hanumantappa Kunte

Age: 29 Years, Occ: Govt Servant
SDC in DDPI Office R/o: Gourishankar
Nagar Ranebennru Dist: Haveri.

INTERIAM BAIL APPLICATION UNDER SECTION 439 OF

Cr.P.C.

Herein the advocate for Accused beg to file as under,

1] That the Lokayukta Police Haveri have registered a case

against the above Accused persons on their crime No:
12/2023, dated 21-07-2023 for offence punishable U/s 7(A)
(B), 13(1)(a) an 13(2) of PC Act and Now the police have
arrested the accused persons and produce before This Hon’ble
court hence the above accused have filed this Interim bail
application for their release on Bail. on following among other
grounds.

2] BRIEF FACTS OF THE CASE : -

 ~2~

That, one Mohammedgouse has filed a false complainant

against above accused persons alleging that, the above
accused persons are demanding the bribe amount for
settlement the pension records and the complainant has
approached the Lokyukta Police with false intention and filed a
false complaint against the above accused persons and same
is and same is registered as crime No: 12/2023, dated 21-07-
2023 for offence punishable U/s 7(A)(B), 13(1)(a) an 13(2) of
PC Act and Now the police have arrested the accused persons
and produce before This Hon’ble court hence the above
accused have filed this Interim bail application for their
release on Bail. on following among other grounds.

GROUNDS FOR BAIL

a] That the above accused persons are innocent and peace

loving persons in the society. That the above accused No: 1
suffered from serious illhealth and acuused No: 2 is also
suffered illhealth for this ground the above accused may
kindly be release on Interim bail.

b] That, the above accused No-1 is working as DDPI in

Haveri District and accused No- 2 is working as a SDC in
DDPI Office Haveri, and the above accused persons are never
demanded the bribe amount from the complainant and never
received the bribe amount as alleged in the complaint.

c] That, complainant has filed false complaint to harass the

accused persons and so far accused have never demanded the
any bribe amount for the complainant works and complainant
work is not pending before the accused office.

d) Complainant has filed a false complaint against the above

accused persons on the instigation of ill-wishers of the
accused persons.
 ~3~

e) That, looking to the FIR and complaint there is vague and

baseless allegation made in the complaint and filed a false
complaint against the present accused persons.

f) That the above accused persons not at all committed any of

offence as alleged by the complainant, the complainant. filed a
false complaint against the above accused only to harass the
accused persons.

g) That, there is no involvement or participation in the alleged

incident, participation is also highly doubtful and imaginary
one.

h) That, the above accused persons are having deep roots in

the society and they are having movable and immovable
properties within the jurisdiction of this Hon'ble court, and
they are Govi employees hence there is no fear of abscondance
in fact they will not abscond also.

i) That looking to averment made in FIR and complaint there is

no ingredients were attracted for offence alleged and there are
number of material contradictions were appeared in the FIR,
and complaint as they are not tallied to each other.

j) That, the above accused persons are ready to give adequate

surety and security for their release on bail.

k) That, the accused persons are undertake that, not to

tamper the prosecution witnesses and false cock and bull
story created against the present accused persons.

l) That the present accused persons are ready to co-operate

with I.O. for investigating agency for further investigation and
ready to abide any conditions imposed by this Hon'ble court
for their release on bail.
 ~4~

m) If the bail is denied to the above accused persons, the

above accused persons are put to great hardship and
irreparable loss and their defense also.

n) That the alleged offences are not punishable with death or

imprisonment for life hence, there is no impediment to grant
bail to the accused persons.

o) The both above accused have never touch the alleged

amount and the police have created a false intrest
Panchanama and Trape panchanama to suit their case, hence
the accused have liable to release on bail.

On these among other grounds that are to be urged at

the time of hearing, it is most humbly prayed that, the above
accused persons may kindly be released on Interim bail in
connection with Haveri Lokayukta Police crime No: 12/2023,
dated 21-07-2023 for offence punishable U/s 7(A)(B), 13(1)(a)
an 13(2) of PC Act in the interest of justice and equity.

Place: Haveri

Date: -07-2023

Umesh N.Gouli
Advocate for accused No-1&2
 ~5~

Haveri Lokayukta PS Crime No: 12/2023

IN THE COURT OF THE PRL DISTRICT AND SESSIONS

JUDGE HAVERI AT HAVERI.

Complainant : State of Karnataka

By Haveri Lokayukta Police
V/s

Accused : 1] Andaneppa S/o Malagirayappa Vadageri

Age: 59 Years, Occ: Govt Servant
DDPI Haveri, R/o: Ijarilakamapur
Haveri.

2] Dattatraya Hanumantappa Kunte

Age: 29 Years, Occ: Govt Servant
SDC in DDPI Office R/o: Gourishankar
Nagar Ranebennru Dist: Haveri.

BAIL APPLICATION UNDER SECTION 439 OF Cr.P.C.

Herein the advocate for Accused beg to file as under,

1] That the Lokayukta Police Haveri have registered a case

against the above Accused persons on their crime No:
12/2023, dated 21-07-2023 for offence punishable U/s 7(A)
(B), 13(1)(a) an 13(2) of PC Act and Now the police have
arrested the accused persons and produce before This Hon’ble
court hence the above accused have filed this bail application
for their release on Bail. on following among other grounds.

2] BRIEF FACTS OF THE CASE : -

That, one Mohammedgouse has filed a false complainant

against above accused persons alleging that, the above
accused persons are demanding the bribe amount for
 ~6~

settlement the pension records and the complainant has

approached the Lokyukta Police with false intention and filed a
false complaint against the above accused persons and same
is and same is registered as crime No: 12/2023, dated 21-07-
2023 for offence punishable U/s 7(A)(B), 13(1)(a) an 13(2) of
PC Act and Now the police have arrested the accused persons
and produce before This Hon’ble court hence the above
accused have filed this bail application for their release on
Bail. on following among other grounds.

GROUNDS FOR BAIL

a] That the above accused persons are innocent and peace

loving persons in the society.

b] That, the above accused No-1 is working as DDPI in

Haveri District and accused No- 2 is working as a SDC in
DDPI Office Haveri, and the above accused persons are never
demanded the bribe amount from the complainant and never
received the bribe amount as alleged in the complaint.

c] That, complainant has filed false complaint to harass the

accused persons and so far accused have never demanded the
any bribe amount for the complainant works and complainant
work is not pending before the accused office.

d) Complainant has filed a false complaint against the above

accused persons on the instigation of ill-wishers of the
accused persons.

e) That, looking to the FIR and complaint there is vague and

baseless allegation made in the complaint and filed a false
complaint against the present accused persons.

f) That the above accused persons not at all committed any of

offence as alleged by the complainant, the complainant. filed a
false complaint against the above accused only to harass the
accused persons.
 ~7~

g) That, there is no involvement or participation in the alleged

incident, participation is also highly doubtful and imaginary
one.

h) That, the above accused persons are having deep roots in

the society and they are having movable and immovable
properties within the jurisdiction of this Hon'ble court, and
they are Govi employees hence there is no fear of abscondance
in fact they will not abscond also.

i) That looking to averment made in FIR and complaint there is

no ingredients were attracted for offence alleged and there are
number of material contradictions were appeared in the FIR,
and complaint as they are not tallied to each other.

j) That, the above accused persons are ready to give adequate

surety and security for their release on bail.

k) That, the accused persons are undertake that, not to

tamper the prosecution witnesses and false cock and bull
story created against the present accused persons.

l) That the present accused persons are ready to co-operate

with I.O. for investigating agency for further investigation and
ready to abide any conditions imposed by this Hon'ble court
for their release on bail.

m) If the bail is denied to the above accused persons, the

above accused persons are put to great hardship and
irreparable loss and their defense also.

n) That the alleged offences are not punishable with death or

imprisonment for life hence, there is no impediment to grant
bail to the accused persons.

o) The both above accused have never touch the alleged

amount and the police have created a false intrest
 ~8~

Panchanama and Trape panchanama to suit their case, hence

the accused have liable to release on bail.

On these among other grounds that are to be urged at

the time of hearing, it is most humbly prayed that, the above
accused persons may kindly be released on bail in connection
with Haveri Lokayukta Police crime No: 12/2023, dated 21-07-
2023 for offence punishable U/s 7(A)(B), 13(1)(a) an 13(2) of
PC Act in the interest of justice and equity.

Place: Haveri

Date: 21-07-2023

Umesh N.Gouli
Advocate for accused No-1 &
2