IN THE HON’BLE COURT OF SH. HARSHAL NEGI, LD.

MM, DWARKA DISTRICT COURTS

IN THE MATTER OF:

STATE VERSUS MANISH JHA

FIR NO. 664/2023

U/S 420/411/379 IPC
PS. DABRI
IN JC SINCE 13.09.2023
INDEX
S. NO. PARTICULARS PAGE NO.
1. Bail application u/s 437 Cr.P.C.
for grant of Interim Bail on behalf
of Applicant/Accused
2. Vakalatnama

APPLICANT/ACCUSED
(IN J.C)
THROUGH
NEW DELHI
DATE: 08.11.2023
LOKESH KUMAR
D/4979/2022,
CH.NO.332 LAWYERS CHAMBER BLOCK
SEC-10, DWARKA, NEW DELHI-110075
Mob. 9999337894
IN THE HON’BLE COURT OF SH. HARSHAL NEGI, LD.
MM, DWARKA DISTRICT COURTS

IN THE MATTER OF:

STATE VERSUS MANISH JHA

FIR NO. 664/2023

U/S 420/411/379 IPC
PS. DABRI
IN JC SINCE 13.09.2023

APPLICATION U/S 437 CR.P.C. FOR GRANT OF

INTERIM BAIL ON BEHALF OF APPLICANT/ACCUSED
NAMELY MANISH JHA, S/O CHANDER KANT JHA, R/O
D1/34, GALI NO. 1, SITAPURI, DABRI, NEW DELHI.
MOST RESPECTFULLY SHOWETH:
1. That the Applicant/Accused is a peace loving and law-
abiding citizen of India and is the permanent resident of the
above-mentioned address having deep roots in the society.
2. That the applicant/accused is being falsely implicated in the
above-mentioned matter and has no role whatsoever in the
commission of any offence as levelled against him in the
present case being totally innocent.
3. That the applicant/accused was arrested on 13.09.2023 by
the police and is in Judicial Custody till date for a period of
almost 2 months.
4. That the Applicant/Accused has no prior antecedents and he
wishes to celebrate the pious occasion of Deepawali along
with his mother. It is pertinent to mention that the
Applicant/Accused lives along with his mother and it is
further submitted that the mother of the Applicant/Accused
is an old aged lady of 69 years who needs constant care and
attention owing to her weakness.
 5. That the above-mentioned FIR is concocted and false at the
instance of the complainant as no such incident took place
and the applicant/accused is implicated in the present matter
by the complainant with ulterior motives.
6. That the applicant/accused has no prior convictions in the
court of law and the investigation qua applicant/accused has
been completed.
7. That the applicant/accused is moving the present application
before the Hon’ble court on the ground that
applicant/accused has nothing to do with any offence as
alleged against him by the complainant and the
applicant/accused is ready to abide by the terms and
conditions imposed by the Hon’ble court upon the accused
while enlarging him on interim bail.
8. That the Applicant/Accused is ready to furnish a sound
surety to the entire satisfaction of this Hon’ble court and is
ready and willing to join any investigation as directed by the
Hon’ble court.

PRAYER:

In view of the above-mentioned facts and circumstances, it

is therefore, most respectfully prayed that this Hon’ble court may
kindly be pleased to grant interim bail of 15 days to the
Applicant/Accused on the stated grounds, in the interest of justice.

And any other relief, which this Hon’ble court, thinks fit and
proper, in the present circumstances.
 APPLICANT/ACCUSED
(IN J.C)

THROUGH
NEW DELHI
DATE: 08.11.2023
LOKESH KUMAR
D/4979/2022,
CH.NO.332 LAWYERS CHAMBER BLOCK
SEC-10, DWARKA, NEW DELHI-110075
Mob. 9999337894