Bail Application

IN THE COURT OF THE SESSIONS JUDGE, DISTRICT DELHI
BAIL APPLICATION NO. [TO BE FILLED] OF 2016
IN CRIME NO. 33432/2016
BETWEEN:
1. KISHAN,
Son of Sh. Ram Kumar,
Aged about 25 Years,
Residing at
House No. 123, Main Street, Vikaspuri, Delhi-110018
2. BISHAAN,
Residing at
3. DISHAM,
Residing at
PETITIONERS
AND
STATE OF DELHI,
Through PS Sonia Vihar
RESPONDENT
PETITION UNDER SECTION 439 OF THE CODE OF CRIMINAL PROCEDURE:
The Petitioners above-named humbly submit as follows:

I. That the address of the Petitioners for the purpose of service of Court Processes, Summons,
and Notices is as shown above.
II. That the Respondent may be served notice at PS Sonia Vihar, Delhi.
III. BRIEF FACTS OF THE CASE:
1. On the night of 23/24 January 2016, an incident occurred involving the unfortunate demise
of Mr. Lallan Prasad, brother of the victim, due to grievous injuries inflicted upon him with a
sharp-edged weapon.
2. The Petitioners, along with co-accused Kishan, Bishaan, and Disham, have been implicated
in this matter and charged under Sections 302/201/34 of the Indian Penal Code.
3. It is pertinent to note that the accused have been in custody since their arrest, cooperating
fully with the investigation.
GROUNDS FOR BAIL:
a) The accused deny any involvement in the alleged crime and maintain their innocence
throughout the proceedings. The charges against them are vehemently contested.
b) The Petitioners and co-accused have no history of criminal activities and are law-abiding
citizens with roots in the community.
c) Bail is a constitutional right, and the continued detention of the accused serves no purpose
as they pose no flight risk and have abided by all legal proceedings thus far.
d) The accused are willing to adhere to any conditions set forth by this Hon'ble Court,
ensuring their presence for trial and refraining from tampering with evidence or influencing
witnesses.
e) There exists no substantial evidence directly linking the accused to the alleged offense, and
their continued incarceration would amount to undue hardship and injustice.
f) The accused have strong familial and community ties, further guaranteeing their
compliance with any conditions imposed by the Court.
WHEREFORE, it is most respectfully prayed that this Hon'ble Court may graciously be
pleased to grant bail to the Petitioners and co-accused, Kishan, Bishaan, and Disham, in the
interest of justice and equity.
Place: Delhi Advocate for Petitioners

Adv. Monalisa
M.G.C & Co.,
Advocates & Solicitors
#66, 4th Cross, Xavier Layout
Delhi- 420010
Date: February 25, 2016
IN CRIME NO. 33432/2016
BETWEEN:
1. KISHAN,
Residing at
2. BISHAAN,
Residing at
3. DISHAM,
Residing at
PETITIONERS
AND
STATE OF DELHI,
RESPONDENT
MEMO OF APPEARANCE
The undersigned Advocate submits that the Petitioners being Accused had given the
instructions to appear on his behalf in the above said case. The same may be taken on record
in the interest of justice and equity.
Place: DELHI Advocate

Advocate for Petitioners
Adv. Monalisa
M.G.C & Co.,
Delhi- 420010
Date:
IN CRIME NO. 33432/2016
BETWEEN:
1. KISHAN,
Residing at
2. BISHAAN,
Residing at
3. DISHAM,
Residing at
PETITIONERS
AND
STATE OF DELHI,
LIST OF DOCUMENTS
Undersigned herewith produces copies of the following documents:-
1. Copy of the Complaint Annexure - A

And FIR
The same may be taken on record, in the interest of justice.
Place: Delhi Adv. For Petitioner

Adv. Monalisa
M.G.C & Co.,
Delhi- 420010
Date:
INDEX
SL.NO DISCRIPTION PAGE NO COURT FEE PAID

1 Petition U/Sn.439 of Code of
Criminal Procedure, 1973
2 List of Documents
3 Memo of Appearance
4 Process Memo
5 Interim Application for Bail
U/Sn.439 of Code of Criminal
Procedure
Place: Delhi Advocates for Petitioner

Adv. Monalisa
Date:
M.G.C & Co.,
Delhi- 420010
IN CRIME NO. 33432/2016
BETWEEN:
1. KISHAN,
Residing at
2. BISHAAN,
Residing at
3. DISHAM,
Residing at
PETITIONERS
AND
STATE OF DELHI,
RESPONDENT
MEMO
The Petitioner submits that I have filed the above Bail Application on 25-02-2016,
after filing of the above Petition, I came to know that earlier to my Application some other
Advocate had filed Bail Application and this Hon'ble Court was pleased to grant Bail on 25-
02-2016 in Cril. Misc. No.1007 / 2016. Wherefore, I may be permitted to withdrawn the
above Petition as not pressed.
Place: Delhi Advocates for Petitioner

Adv. Monalisa
M.G.C & Co.,
Delhi- 420010
Date:

Bail Application

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IN THE COURT OF THE SESSIONS JUDGE, DISTRICT DELHI