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Bail Petition Copy

IN THE COURT OF HON' BLE METROPOLITAN SESSIONS

JUDGE. MEDCHAL DISTRICT AT MEDCHAL
Crl. M.P.NO: of 2024
In
(In Crime No 362/2024 at PS Dundigal)

Between:
Besta Chinthala Kashiram S/o Narayana,
age. 35 Yrs, Caste. BC (Bestha), Occ. Labour work,
R/o Back side of Santhosh Dhaba,
Gandimaisamma, GM-Dundigal Mandal,
Medchal Dist N/o H. No. 11-100/1,
Ailapur Village, Lingampet Mandal,
Kamareddy Dist
Petitioner/Accused 2
And
The State Of Telangana through
SHO, PS Dundigal Respondent/Complainant

The address for service of all notices and process on the

above named Appellant is that of his counsels M/S HARSHEET
REDDY LAW FIRM, Rep by: Y ARAVIND, P DURGA RAO, MA
ISMAIL ZABEULLAH,CH.VIGNESH Advocates, Office #101,
Ushodaya Towers, Shapur Nagar, IDA Jeedimetla, Hyderabad- 55,
Phone : 7997475050.

PETITION FILED FOR UNDER SECTION 439 OF Cr.P.C

Date of Offence : 21.04.2024

Date of Arrest : 23.04.2024

Date of Remand : 23.04.2024

Offence under Sections : U/Sec 302,201 IPC,

r/w 34 IPC & 3(2)(v) of SC/ST
Prevention of Atrocities Act
Place of Offence : Within the jurisdiction of
Dundigal PS
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Bail Petition Copy

GROUNDS TO GRANT BAIL:

1. The police have falsely implicated the accused in this case;

the complainant and the Police have suspected the
Petitioners/Accused and there is no Prima-facie to prove the
guilty of the petitioners/accused.

2. There are no Criminal Antecedents against Petitioner.

The complainant filed this false case to harass the accused.
The police have not even explained Reason for Arrest of the
Accused. The police have not given any chance for the
Accused to submit his version. The Police wrote their own
Story in Remand Case Dairy.

3. The police have recorded 161 Statements of Complainant

and others. The Maximum part of Investigation is
completed. All the accused are ready to Co-Operate with
the Investigation Officer in the course of investigation.

4. The Petitioner/Accused No. 2 submit that the allegation

mentioned in the remand case diary are totally false and
created one and accused No. 2 never involved in any
offences as alleged by the respondent police and police
without any enquiry and investigation they falsely registered
Accused No. 2 name in the above said case with false and
fabricated allegations the allegations mentioned in the
Remand case diary are totally false, baseless and denied by
the above petitioner/Accused No. 2 in toto.
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Bail Petition Copy

5. The Petitioner/Accused No. 2 submits that he no way

concerned nor connected the above said alleged offences,
since the de facto- complainant created a false story and
lodged the above false complaint against the accused No. 2
in order to harass him.

6. The Petitioner/Accused No. 2 submit that as per the

allegations of de facto-complainant no specific base or
events of alleged death are narrated in the complaint all are
omnibus allegations and further the police has not given
any explanation for remanding the petitioner/Accused No. 2
as what is the evidence to be collected by them. The
allegation of the prosecution is false and baseless there is no
iota of legally valid evidence against the petitioner /accused.

7. The Accused is ready to Co-Operate with the Investigation

Officer. The Accused is ready to the terms and conditions
which are being imposed by the Hon’ble Court in order to
secure his presence for investigation if any. That the
accused is ready to furnish sufficient sureties to the
satisfaction of this Hon’ble Court and also abide any terms
& conditions imposed by this Hon’ble Court.

8. This is the First bail Application. It is further submit that

there is no bail petitions are pending before any other court
of law, including the High Courts of Law.

9. The other grounds will be argued at the time of hearing.

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Bail Petition Copy

PRAYER:

Hence, the Hon'ble Court may be pleased to grant the BAIL to

the Petitioner/Accused in Crime No 362/2024 of Dundigal PS and

pass such other order or orders may deem fit and proper in the

circumstances of the case.

Date: 05.06.2024

Place: L.B.Nagar

COUNSEL FOR THE PETITIONER

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Bail Petition Copy

VERIFICATION

I, Errola Srinivas S/o Poshaiah, Age 33 Years, Occupation :

PVT EMP, R/o 6-19/3, Vellutlapeta, Mandal Yallareddy, Vellutla,
Nizamabad, Telangana-503122., do hereby verify that I am
the friend of the petitioner/Accused and duly authorized/
instructed by Accused relating to Crime No 362/2024, at
Dundigal PS to appoint M/S HARSHEETH REDDY LAW FIRM,
Rep by: Y ARAVIND, P DURGA RAO, MA ISMAIL ZABEULLAH,
Office : Flat No. 101, Ushodaya Towers, Shapur Nagar, IDA
Jeedimetla, Hyderabad-500055; Phone: 7997475050 &
8885111125 to act on his behalf and to defend them in the above
case and no other person have been instructed to appoint any
Advocate.
I also verify that this is the Bail Petition, no similar petition is

filed or pending before any court of law, including the High courts

of law.

Place : L.B.Nagar
DATE: 05.06.2024

Signature of Person Interested

Verified In My Presence

Advocate:: L.B.Nagar
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Bail Petition Copy

IN THE COURT OF HON’BLE

METROPOLITAN SESSIONS
JUDGE. MEDCHAL DISTRICT AT
L.B.NAGAR

Crl. M.P.NO: of 2024

In
(In Crime No 362/2024 at PS
Dundigal)

Between:
Besta Chinthala Kashiram
…Petitioner/Accused

And

The State Of Telangana through

SHO, PS Dundigal
…Respondent/Complainant

BAIL APPLICATION UNDER

SECTION 439 OF CR.P.C

Filed On: 05.04.2024

Filed by:

Counsel for Petitioner/Accused No.2

Address:

M/s HARSHEET REDDY LAW FIRM,

Rep by :
Y.ARAVIND
P.DURGA RAO,
MA.ISMAIL ZABEULLAH,
CH.VIGNESH
Advocates
Phone : 7997475050