IN THE COURT OF THE CITY CIVIL & SESSIONS

JUDGE AT BANGALORE

Crl. Misc. No. of 2011

Petitioners : ALAPATI BABUJEE

-versus-

Respondent : State of Karnataka

By Ulsoor Gate Women Police
Station, Bangalore City.

INDEX

SL DESCRIPTION OF THE DOCUMENTS PAGE

NO NO

1 Memorandum of Criminal Miscellaneous

Petition u/s 438 of Cr Pc.

2 List of Documents
i. Copy of the FIR
ii. Copy of the complaint

3 Vakalath

……..………………………………
Advocate for petitioners.
R.L.N.MURTHY & ASSOCIATES
Place: Bangalore.
Date: 18/7/11.
 IN THE COURT OF THE CITY CIVIL & SESSIONS JUDGE
AT BANGALORE

Crl.Misc.No………………….of 2011

1. ALAPATI BABUJEE
S/o.Govind Raja Rao,
Aged about 52 Years,
R/at No.12-13-708,
Kimtee Colony,
Tranaka, Secunderabad-500 01. Petitioners.

-/versus/-

State of Karnataka
by ulsoor Gate Women Police,
Bangalore. Respondent.

MEMORANDUM OF CRIMINAL MISCELLANEOUS PETITION

UNDER SECTION 438 OF THE CODE OF CRIMINAL
PROCEDURE

The petitioners above named begs to submit as follows:-

1. That for the purpose of services of Notice summons etc.,

the address of the petitioners is shown in the cause title and

they can also be served on their counsels

R.L.N.MURTHY & ASSOCIATES, Advocates, No.401/1, Ground

Floor, Swastik Complex, Swastik Circle, S.C. Road,

Seshadripuram, Bangalore-560 020. The address the

complainant is also shown in the cause title.

2. The petitioner submit that, the Ulsoor gate women police have

registered criminal case against the petitioners in Crime

No.81/2011 on 01.07.2011 for the offences punishable under

section 498A, 506 of IPC and under section 3 and 4 of Dowry

Prohibition Act based on the written complaint given by one Mrs.

Anusha w/o. Alapati Ranjeet kumar. The complaint is the

daughter in law of the petitioners, Alapati Ranjeeth kumar is the

only son of the petitioners. Anushar and Ranjeet kumar married

on June 2nd 2010 at Bangalore, and both ware residing at

Vasanth nagar, Bangalore after their marriage.

3. The petitioners are permanent residents of the secunderbad,

Andrapradesh state, they deny all the allegation made against

them in the complaint and they not have committed any offence,

the complainant have falsely impleaded as accused in the

criminal case just to harass them.

4. The petitioners submit that, immediately after having

knowledge of the above said criminal case, the petitioner are

approaching this Hon’ble court seeking prayer of anticipatory bail

in the event of the their arrest, among the following amongst

other grounds;-

5. The petitioners submit that, that they are the permanent

residents of above address.

6. The petitioners submit that, they all are innocent.

7. That the petitioners are most respect for the laws and all

are law-abiding citizens and having deep roots in the society and

have no bad antecedents.

8. That the complainant has filed the above case falsely just

to harass the petitioners and complainant has bad motive

against the petitioners has filed the above false complaint.

9. That the alleged offences leveled against the petitioners is

neither punishable with death or imprisonment for life, hence

there is no legal embargo for this Hon’ble Court to enlarge the

petitioners on anticipatory bail in the event of arrest of these

petitioners.

10. That the petitioners further submitted that all are ready

and willing to join and assist investigation officer whenever

summoned and also willing to abide by all the terms and

conditions that may be imposed by this Hon’ble Court and they

are ready and willing to furnish solvent surety for ensuring their

regular appearance before the Hon’ble Court up to the conclusion

of trial. However.

11. That the Petitioners are innocent and no useful purpose

would be served by arresting them and keeping them under

custody and this is a fit case for grant of anticipatory bail as the

Petitioners are being needlessly harassed by the respondent and

apprehends arrest.

12. It is further submitted that the petitioners would neither

abscond nor delay the proceedings and would not tamper with

the prosecution witnesses.

13. That the petitioners may be permitted to urge any

additional grounds at the time of advancing arguments.

14. That the petitioners submit that no harm or injury will be

caused to other side if this application is allowed and on the

other hand if this application is not allowed the petitioners will be

put to hardship and injury.

15. That the Petitioners have not filed any other similar

petition before this or any other Hon’ble Court for grant of

anticipatory bail in connection with above criminal case.

PRAYER

Wherefore, the petitioners above named most humbly prays

that, this Hon’ble Court be pleased to enlarge them on

anticipatory bail in the event of their arrest in Crime No.81 of

2011 of Ulsoor Gate Police Station, pending before the

Hon’ble 6th ACMM court Bangalore City in the interest of justice.

……..………………………………
Advocate for petitioners.
R.L.N.MURTHY & ASSOCIATES
Place: Bangalore.
Date: 18/7/11.
 IN THE COURT OF THE CITY CIVIL & SESSIONS
JUDGE AT BANGALORE

Crl. Misc. No. of 2011

Petitioners : ALAPATI BABUJEE

-versus-

Respondent : State of Karnataka

By Ulsoor Gate Women Police
Station, Bangalore City.

LIST OF DOCUMENTS

Sl.
No. Description Page No.

1. Copy of the FIR

2. Copy of the complaint

……..………………………………
Advocate for petitioners.
R.L.N.MURTHY & ASSOCIATES
Place: Bangalore,
Date: 18/7/11.