IN THE SUPREME COURT OF INDIA

CRIMINAL APPELLATE JURISDICTION

SPECIAL LEAVE PETITION (CRL.) NO.________ OF 2023

IN THE MATTER OF:-

ANKIT KUMAR @ CHANDAN ... PETITIONER

VERSUS

THE STATE OF BIHAR ... RESPONDENT

AFFIDAVIT
I
…………………………………………………………………………………………
…………………………………………………………………………………………
………………………………………………………………………………………,
do hereby solemnly affirm and state as under:-

1. That I am……………………………of the petitioners acting as pairokar of the

petitioners in the abovementioned Petition, and as such I am aware of the
facts and circumstances of the case, hence entitled to swear this affidavit.
2. That the contents of the accompanying Special Leave Petition consisting in
paragraph ..................... from pages ..................... accompanied with Synopsis
and List of Dates at Pages B to …. and Crl. M. Ps has been read over to me in
vernacular language I say that same are true and correct to the best of my
knowledge, belief and nothing material information has been concealed
therefrom.
3. That the Annexures P-1 to P- are true/translated copies of their respective
originals.
4. That no other Special Leave Petition against the order impugned has been
filed by the Petitioner before this Hon’ble Court.

DEPONENT

VERIFICATION:
 I, the above name deponent do hereby verify that the contents of the above
affidavit are true and correct to the best of my knowledge, belief and nothing material
information has been concealed therefrom. No part it is false.
Verified at New Delhi on this ..................day May, 2023.

DEPONENT

“APPENDIX”
The Indian peneal Code, 1860
Central Government Act
406. Punishment for criminal breach of trust.— Whoever
commits criminal breach of trust shall be punished with
imprisonment of either description for a term which may extend to
three years, or with fine, or with both.

420. Cheating and dishonestly inducing delivery of property.—

Whoever cheats and thereby dishonestly induces the person deceived
to deliver any property to any person, or to make, alter or destroy the
whole or any part of a valuable security, or anything which is signed
or sealed, and which is capable of being converted into a valuable
security, shall be punished with imprisonment of either description
for a term which may extend to seven years, and shall also be liable
to fine.

467. Forgery of valuable security, will, etc.— Whoever forges a

document which purports to be a valuable security or a will, or an
authority to adopt a son, or which purports to give authority to any
person to make or transfer any valuable security, or to receive the
principal, interest or dividends thereon, or to receive or deliver any
money, movable property, or valuable security, or any document
purporting to be an acquittance or receipt acknowledging the
payment of money, or an acquittance or receipt for the delivery of
any movable property or valuable security, shall be punished with
[imprisonment for life], or with imprisonment of either description
for a term which may extend to ten years, and shall also be liable to
fine.

468. Forgery for purpose of cheating.— Whoever commits

forgery, intending that the document or electronic record forged]
shall be used for the purpose of cheating, shall be punished with
imprisonment of either description for a term which may extend to
seven years, and shall also be liable to fine.

471. Using as genuine a forged [document or electronic record].

— Whoever fraudulently or dishonestly uses as genuine any
[document or electronic record] which he knows or has reason to
believe to be a forged [document or electronic record], shall be
punished in the same manner as if he had forged such [document or
electronic record].

34. Acts done by several persons in furtherance of common

intention.— When a criminal act is done by several persons in
furtherance of the common intention of all, each of such persons is
liable for that act in the same manner as if it were done by him alone.

ANNEXURES
 IN THE SUPREME COURT OF INDIA
(CRIMINAL APPELLATE JURISDICTION)
Crl M.P. NO………..OF 2021
IN
SPECIAL LEAVE PETITION (Crl) NO. OF 2021

IN THE MATTER OF:-

RAJKUMAR VASHUMAL

KISHNANI & ANR… ... PETITIONER

VERSUS

THE STATE OF MAHARASHTRA ... RESPONDENT

AN APPLICATION FOR EXEMPTION FROM FILING

CERTIFIED COPY OF THE IMPUGNED ORDER;

TO,
THE HON’BLE CHIEF JUSTICE OF INDIA

AND HIS COMPANION JUSTICES OF THE

SUPREME COURT OF INDIA AT NEW DELHI;

THE HUMBLE PETITION OF THE

ABOVE NAMED PETITIONER;

MOST RESPECTFULLY SUBMITS AS UNDER:-

1. The Petitioner is filing the present Petition under Article 136 of the

constitution of India for seeking Special Leave to appeal against interim

order dated 01.12.2021, passed by the Hon'ble High Court of Judicature

at Bombay in Anticipatory Bail Application No. 2726 of 2021, where

the Hon’ble High Court has rejected the Application filed by the

Petitioners and granted Ad-interim protection of Two weeks from the

order pronounced by way of last chance. The said order passed by the

Hon’ble High Court is erroneous and bad in law and is liable to be set

aside. No Writ or LPA lies against the impugned order.

2. That the facts and circumstances of the case have been fully described

in the synopsis cum list of dates and in the here for the sake of brevity

and in order to avoid repetition. The petitioner craves the leave of this
 Hon’ble Court to refer to and rely upon the same for the purpose of

deciding the present application.

3. The Petitioner is filing the instant application requesting for grant of an

exemption from filing certified copy of the impugned judgment and

common interim order dated 01.12.2021, passed by the Hon'ble High

Court of Judicature at Bombay in Anticipatory Bail Application No.

2726 of 2021.

4. That the present application is made bona fide and is in the interest of

justice and the petitioner will suffer irreparable loss and injury if the

prayer made herein below is not allowed.

PRAYER
It is most respectfully prayed that this Hon’ble Court may be pleased to:

a. Exempt the petitioner from filing certified copy of the impugned

judgment and common interim order dated 01.12.2021, passed by

the Hon'ble High Court of Judicature at Bombay in Anticipatory

Bail Application No. 2726 of 2021and/or;

b. Pass such order or further orders as this Hon’ble Court may deem

fit and proper in the facts and circumstances of the present case.

AND FOR THIS THE PETITIONER SHALL EVER PRAY

FILED BY

( MANJU SHARMA JETELEY )

ADVOCATE FOR THE PETITIONER
NEW DELHI
DATE: .12.2021
 IN THE SUPREME COURT OF INDIA
(CRIMINAL APPELLATE JURISDICTION)
Crl M.P. NO………..OF 2021
IN
SPECIAL LEAVE PETITION (Crl) NO. OF 2021

IN THE MATTER OF:-

RAJKUMAR VASHUMAL

KISHNANI & ANR… ... PETITIONER

VERSUS

THE STATE OF MAHARASHTRA ... RESPONDENT

APPLICATION FOR EXEMPTION FROM FILING TRUE

TRANSLATED COPIES OF THE ANNEXURES

TO,
THE HON’BLE CHIEF JUSTICE OF INDIA

AND HIS COMPANION JUSTICES OF THE

SUPREME COURT OF INDIA AT NEW DELHI

THE HUMBLE PETITION OF THE

ABOVE NAMED PETITIONER

MOST RESPECTFULLY SUBMITS AS UNDER:-

1. The Petitioner is filing the present Petition under Article 136 of the

constitution of India for seeking Special Leave to appeal against interim

order dated 01.12.2021, passed by the Hon'ble High Court of Judicature

at Bombay in Anticipatory Bail Application No. 2726 of 2021, where the

Hon’ble High Court has rejected the Application filed by the Petitioners

and granted Ad-interim protection of Two weeks from the order

pronounced by way of last chance. The said order passed by the Hon’ble

High Court is erroneous and bad in law and is liable to be set aside. No

Writ or LPA lies against the impugned order.

2. That the facts and circumstances of the case have been fully described in

the synopsis cum list of dates and in the here for the sake of brevity and in

order to avoid repetition. The petitioner craves the leave of this Hon’ble
 Court to refer to and rely upon the same for the purpose of deciding the

present application.

3. The Petitioner is filing the instant application for exemption from filing

True typed copies of the Annexures P- _____________

___________________________, attached and annexed to the present

Special Leave Petition. The impugned order was pronounced on

01.12.2021 and considering the urgency of the matter, the Petitioner is

seeking the said relief.

4. That the present application is made bona fide and is in the interest of

justice and the petitioner will suffer irreparable loss and injury if the

prayer made herein below is not allowed.

PRAYER
It is most respectfully prayed that this Hon’ble Court may be pleased to:

a. Exempt the petitioner from filing True typed copies of the

Annexures P- _________________ and/or;

b. Pass such order or further orders as this Hon’ble Court may

deem fit and proper in the facts and circumstances of the

present case.

AND FOR THIS THE PETITIONER SHALL EVER PRAY

FILED BY

( MANJU SHARMA JETELEY )

ADVOCATE FOR THE PETITIONER
NEW DELHI
DATE: .12.2021