IN THE COURT OF DISTRICT AND SESSIONS JUDGE,

CENTRAL, TIS HAZARI COURTS, DELHI

BAIL APP_____/2022

In re:

STATE Versus Akram

FIR No. 540/2016

U/s: 406/506/174A IPC
P.S: Kotwali
Accused in custody since
- 14.05.2022

APPLICATION UNDER SECTION 439 OF CODE OF

CRIMINAL PROCEDURE FOR GRANT OF BAIL ON
BEHALF OF THE APPLICANT/ACCUSED AKRAM.
Most Respectfully Showeth:
1. That the present FIR has been registered on false and bogus
facts. The facts stated therein are concocted, fabricated and
without any basis.
2. That the complainant in collusion with the Police has implicated
the present applicant/accused in the present case, and arrested
him although the applicant is highly reputed person in the
society.
3. That the complainant in this present matter has left no stone
unturned in implicating the present accused since 2008 and has
abused the process of law.
4. That the applicant/accused was arrested by the Police on
13.05.2022 from his hometown village Kithor Near Rihana
Masjid Distt. Meerut, U.P.
5. That it is pertinent to mention that the accused was never served
any notices/summons/warrants which were issued by the
Hon’ble M.M Court. That all the summons/warrants were
addressed for House no. 42, Sector 11 Shastri Nagar, P.S-
Noochandi, Meerut Distt., Meerut, U.P and same were not
executed following the due process of law. It is vehemently
mentioned here that the applicant has been living here for last 4
years and hence the sum and substance of the contention is that
the applicant had no clue about the lodging of the said case
against him.
6. That it is also stated that the said FIR has been registered under
section 156(3) Cr. P.C as per order passed by the court of Shri.
Rakesh Ram puri, Ld. MM, Delhi by distorting the real facts of
the case by the complainant.
7. That as per allegations, the complainant had given two buses to
the applicant/accused for service purpose and was
misappropriated by the applicant/accused and co-accused Jalis
Choudhary @Pappu but the Police did not even chargesheeted
the co-accused for the reason that no material was found against
the co-accused. It was also noted by the Hon’ble Court while
granting anticipatory bail to the co-accused that there is no
material present against him. It is crystal clear that the
complainant with all means wants to implicate the accused and
 keep him behind the bars. The applicant has been implicated by
him only for the reason that there is a family dispute for
property and hence for vengeance purpose he resorted to
unwarranted and unscrupulous tactics.
8. That the applicant/accused is an aged person in almost in his
sixties now and he is also married and has 3 sons, while the
applicant is the sole bread earning person and the family is
dependent on him only.
9. That the applicant/accused is suffering from old-age diseased
and ailments and requires constant care and protection. The
accused/applicant is a heart patient and having fluctuating high
and low Blood pressure and also having Sugar/diabetes and also
his wife is also suffering from heart diseases.
10.That the applicant/accused is not previous conduct or not
habitual offender.
11. That the applicant/accused is ready to give the local surety to
the satisfaction of this concerned court.
12. That the applicant/accused undertakes not to jump the bail after
being released on bail in this case.
13. That the chargesheet has been already filed by the I.O before
the concerned court on 14.07.2022 after completing the
investigation and now now fruitful purpose will be served by
keeping the applicant in Jail in this case as it has been held in
catena of landmark cases that the bail is the rule and jail is the
exception.
 14. That the applicant/accused is ready to abide all terms and
conditions imposed upon him for granting the bail by this
Hon’ble Court.

PRAYER

It is, therefore, most humbly prayed that the Hon’ble court may be
graciously pleased to release the applicant/accused on bail in the
interest of justice.

APPLICANT/ACCUSED

DELHI. Through

DATED CHETAN SINGH

(ADVOCATE)
CH.NO. 735-L, FF, WESTERN
WING,TIS HAZARI COURTS,
DELHI-110084
Mob. 9643418235
Email:chetansingh274@gmail.com