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IN THE COURT OF HON’BLE C. J. M.

AT LATUR

Bail Application No. /2021

Ismail S/o. Hamaj Sayyad

Age-30 years, Occu- Labor,

R/o. Babhalgao Tq. & Dist. Latur.

…Applicant/Accused.

Versus

The State of Maharashtra,

Through,

P.I. Vivekanand Chowk Police Station, Latur.

Tq. & District Latur.

…Respondent.

Offence :- U/S. 354, 506 of I. P. C.

Crime No. :- 82/2021

Date of Offence :- 01/02/2021.

Date of F.I.R. :- 02/02/2021 At or about 17.05.

Police Station :- Vivekanand Chowk Police Station,

Latur.

Date of Arrest :- 02/02/2021.

Date of M.C.R. :- 02/02/2021.

Application for Regular Bail U/S. 437 of CR.P.C.

MAY IT PELASE YOUR HONOUR

The above named Applicant most respectfully submits his bail


Application as follows –
Police Case :-

1. That on 02/02/2021 one Jainbee W/o Ismail Shaikh hailing


from Vaishali Nagar, Latur lodged complaint with the Vivekanand
Chowk Police Station Latur with the allegations that on
01/02/2021 at or about 5.00 p.m. applicant outrage her modesty.

2. That on the receipt of such information the Vivekanaand


Chowk Police Station Latur authority registered crime No.82/2021
dated 02/02/2021 against the applicant of U/S. 354, 506 of I. P. C.

3. Thereafter, on 02/02/2021 the I.O. of said crime arrested the


applicant/accused and produced the Applicant before this Hon’ble
Court with request of M.C.R.

4. Previously no such bail application was ever presented either


before this Hon’ble Court or before Hon’ble High Court.

Grounds for Bail :-

1. That, the applicant has not committed any offence as alleged


by the complainant. The applicant is innocent and he will prove his
innocence at the end of trial.

2. That, the I.O. of said crime arrested the applicant on


02/02/2021 and produced before this Hon’ble Court with request
of M.C.R. it means that the I.O. of concern crime has completed
entire custodial investigation and interrogation with the present
Applicant.

3. That, the I.O. of said crime near about completed entire


investigation i.e. drawn spot panchanama, recorded the statements
of witnesses. Therefore now there is no need to keep the present
Applicant behind the bar till the final disposal of said crime and if
Applicant kept behind bar till the final disposal of said crime then it
will amounts to pretrial punishment.

4. That as per the allegations in F.I.R prima facie no offence U/s


354 of I.P. C made out.

5. That, the entire allegations alleged in F.I.R. are vague.


Complainant has lodged false report only with intend to harass the
Applicant and his family members.
6. That, the Applicant is labor and only the bread winner of his
family and if Applicant kept behind the bar till the end of trial then
entire family of the Applicant will suffer from starvation.

7. That, the Applicant undertake that he will co-operate


investigating authority during the further investigation of said
crime and he will not misuse the liberty granted by this Hon’ble
Court.

8. The Applicant will not hamper and tamper any prosecution


witnesses and its evidence.

9. That, the Applicant will abide any condition if imposed by this


Hon’ble Court.

10. That, the Applicant is ready to furnish solvent surety as per


the direction of this Hon’ble Court.

11. That, any grounds which are not specifically mentioned in


this bail petition will be argued at the time of final hearing with
prior permission of this Hon’ble Court.

HENCE IT IS PRAYED

That, the bail application of Applicant may kindly


be allowed and the Applicant may kindly be
released on bail in crime No.82/2021
Dt.02/02/2021 registered U/s.354 of I. P. C. with
Vivekanand Chowk Police Station, Latur, Tq. &
Dist. Latur.

Date : 03/02/2021 Applicant

(Accused is in jail)

Through,

Advocate for Applicant.

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