IN THE COURT OF THE HON’BLE XI METROPOLITAIN MAGISTRATE CYBERABAD

AT: RAJENDRANAGAR
Crl.M.P...... /2022
in Crime 1072 of 2022
Between:
Adugolu Vamshikrishna Petitioner/Accused
AND
STATE .REP BY PS Rajendranagar Respondent/complainant
COUNTER FILED ON BEHALF OF RESPONDENT/COMPLAINANT
1. It is humbly submitted that the petitioner is accused in crime no. 1072 of 2022 U/s
379 in PS Rajendranagar and arrested and remanded on 30.06.2022 to judicial custody. It is humbly
submitted that the petition for bail filed by the petitioner is neither maintainable under law or on facts
and the same is liable to be dismissed in limini.
2. It is further submitted that the present bail application being a successive one moved within a week
of the rejection of the earlier bail application on 8.07.2022 before this Hon’ble Court without any
changed circumstances and after its rejection the petitioners has rushed to this Court once again and
needs to be rejected this application.
3. It is further submitted that the while entertaining such subsequent bail applications, the Court has a
duty to consider the reasons and grounds on which the earlier bail application was rejected and what
are the fresh grounds which persuade it warranting the evaluation and consideration of the bail
application afresh and to take a view different from the one taken in the earlier application.
4. It is further submitted that the respondent craves leave of this Hon’ble court to read the RCD in
this case as part and parcel of this counter. In addition to the grounds mentioned in the Remand case
Dairy, it is further submitted that the petitioners is not entitled for grant to of bail on the following
grounds.
a. As per the investigation done so far by the investigation agency, there is prima facie and
reasonable ground to believe that the accused had committed the offence.
b. The nature and gravity of the offence committed by the petitioner disentitles him for the relief
of bail. It is therefore prayed that this Hon’ble Court be pleased to dismiss the petition under
reply as devoid of merits, in the interests of justice.
c. The allegation against petitioners will attract greater punishment, severity of the punishment in
the event of convection also does not approve the enlarging the petitioner on bail. The danger
of the petitioners absconding or fleeing, if released on bail would make the situation rampant.
d. The previous character, behaviour, means, position and standing of the accused also goes
against the Petitioner/accused from being set free on bail.
e. The likelihood of the offence being repeated by the accused is also apprehended and hence the
petitioner/accused cannot be enlarged on bail.
f. There is also a reasonable apprehension of the witnesses being influenced by the accused if
enlarged on bail and also the accused may also tamper the investigation and hamper the
investigation, there is danger to justice being thwarted by grant of bail.
g. In most of the crimes, charge sheets have been filed by respondent, so that kindly commence
the trail in those case.
4. It is submitted that the granting bail to accused could lead to his trying to tamper with the
prosecution evidence by giving threat or inducement to the prosecution witnesses or even to
abscond to delay the trial. There was probability of his taking to the path of crime again, resulting
in a rise in the crime graph in the area.
Hence, it is therefore praying the Honourable Court be pleased to kindly dismiss the petition
under reply as devoid of merits, in the interest of justice.

ASST PUBLIC PROSECUTOR