IN THE COURT OF THE DISTRICT AND SESSIONS JUDGE OF

ERODE
CMP NO /2024

1. Ajithkumar (27)
S/o Murugan,
59, Kadappanallur,
Bhavani, Erode Dt

2. Sakthivel (27)
S/o Govinthan
103A, Kuppichipalayam,
Kesarimangalam, Bhavani,
Erode Dt.

... Petitioners / Accused (A1 – A2)

Vs
State by Forest range of Police,
Bhavani PS,
Cr No 42/2024
JM I Bhavani
…. Respondent/Complainant

PETITION U/S 438 OF Cr.P.C FILED ON BEHALF OF THE PETITIONERS /

ACCUSED

The above petitioners most humbly beg to submit that they came to know that the
above respondent had filed a FIR under Section 294(b), 323, 324, 506(1) of Indian
Penal Code on 18.01.2024 in Crime No 42/2024.

The case of the respondent is that the petitioners had been involved in assault with
iron rod and threatening of the informant one Basker and his friends following a prior
enmity between the families. It is alleged that the familes of the informant and first
petitioner are related and have political and property related prior disputes. It is further
alleged that the 1st petitioner had wordily abused the informant’s father and a quarrel
ensued between them.
 Therefore petitioners apprehend arrest and torture at the hands of respondent.
Therefore the petitioners pray that this Honourable court may be pleased to enlarge
them on anticipatory bail on the event of their arrest for the following among other
grounds namely:-

1. The date of occurrence is 17.01.2024; The date of FIR is on 18.01.2024

2. The offence u/s 506(1) of IPC is non bailable one.

3. The accused is not likely to abscond or run away.

4. The case of the respondent is totally false and frivolous. The 2 nd petitioner has
filed a case in counter against the informant and his son in Cr No 41/2024 with
the respondent police u/s 294(b), 323, 324, 506(1) of IPC.

5. The petitioners are having permanent residence and are law-abiding citizens.

6. The entire investigation in this case is over. The petitioners are prepared to
appear before the investigating authority whenever called for.

7. The petitioners have not filed any bail application in any other court or in the
High Court of Judicature at Chennai.

Advocate for Petitioners

Sureties to be produced to the satisfaction of Judicial Magistrate No I, Bhavani
 IN THE COURT OF THE DISTRICT AND SESSIONS JUDGE OF
ERODE

CMP NO /2024

1. Ajithkumar
2. Sakthivel

... Petitioners / Accused (A1 – A2)

Vs
State by Forest range of Police,
Bhavani PS,
Cr No 42/2024
JM I Bhavani

…. Respondent/Complainant

PETITION U/S 438 OF Cr.P.C FILED ON BEHALF OF THE PETITIONERS/

ACCUSED

Pre on :23.01.2024

Address For Service:

M.Dhanraj, B.A., B.L.,
(MS No 50/2002)
M Mathiyazhagan, B.A., B.L.,
R Arulkumar, B.A., L.L.B.,
S Poojith Venkatesan, B.A., L.L.B.,
Advocates,
15, Tiruveni Nagar,
Thindal PO, Erode – 638 012
Ph: 9443071979