Anticipatry Bail Kailashben Harshabhai Ramani

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IN THE COURT OF HON’BLE DISTRICT AND SESSION JUDGE

KARKARDOOMA COURTS, DELHI

IN RE:

STATE VERSUS NISHU


S/O SH. SURENDER SINGH
R/O. 3/16, MAIN ROAD,
MOUJPUR, DELHI-110053

FIR NO. 0661/2018


U/S 308/34 IPC
P.S. JAFRABAD

APPLICATION ON BEHALF OF APPLCIANT FOR GRANT OF


ANTICIPATRY BAIL U/S. 438 Cr.P.C. TO THE
APPLCIANT/ACCUSED.

MOST RESPECTFULLY SHOWETH:

1.That the applicant/accused is residing above

mentioned address and have clean antecedent

and nothing involve any criminal activity.

2.That the said FIR has been registered on the

bases of complaint made by the younger brother

of father of accused and both the complainant

and accused belongs to the same family and

residing together in the same locality.

3.That the complainant and his son beaten to the

father of accused and accused made a 100

number call and concerned police registered an

FIR bearing no. 0660/2018 dated 11.11.2018

U/s. 323/341/506/34 IPC against the


complainant Sanjay and complainant son namely

Aman and during the course of quarreling

between both the parties complainant also made

a complaint before concerned police station

and another FIR registered against the present

applicant and his father and his younger

brother. Copy of both the FIR attached with

this application.

4.That as per the content of the FIR bearing no.

0661/2018 the complainant Sanjya, got an

injuries during the course of quarreling

between both the parties, and concerned police

station registered an FIR U/s. 308/34 IPC

whereas the injury got by the Sanjay during

the course of quarrelling between the parties

is simple which is clearly reflected in MLC

No. C/6016/46/18 and MLC No. B-5767/37/18 in

the name of Aman.

5.That as per the both the MLCs the injuries are

simple and the offence U/s. 308 is not made

out against the present applicant.

6.That there are more then one month has been

gone neither the present applicant nor any

accused person temper the evidence or


investigation conducted by the concerned

police.

7.That the police officials of P.S. Jafrabad

were falsely implicated the applicant in the

present case as the applicant has no concerned

with the alleged.

8.That the applicant undertakes to appear on

each and every date of hearing in future.

9.That the applicant/accused is law abiding and

peace loving citizen of his locality and

residing at the above said address since long.

10. That the applicant is never involve in any

case and is ready to furnished the reliable

surety for satisfaction of this Hon’ble Court.

PRAYER

It is, therefore, most respectfully prayed

that this Hon’ble Court may kindly be pleased to

grant the anticipatory Bail of the

applicant/accused, in the interest of justice.

It is prayed accordingly.

DELHI APPLICANT/ACCUSED
DATED:21.12.2018
THROUGH

(SUNIL PRASAD)
ADVOCATE
IN THE COURT OF HON’BLE DISTRICT AND SESSION JUDGE
KARKARDOOMA COURTS, DELHI

IN RE:

STATE VERSUS NISHU

MEMO OF PARTIES

NISHU
S/O SH. SURENDER SINGH
R/O. 3/16, MAIN ROAD,
MOUJPUR, DELHI-110053 APPLICANT

VERSUS

STATE OF N.C.T OF DELHI RESPONDENT

DELHI APPLICANT/ACCUSED

DATED-21.12.2018 THROUGH

SUNIL PRASAD

ADVOCATE
IN THE COURT OF HON’BLE DISTRICT AND SESSION JUDGE
KARKARDOOMA COURTS, DELHI

IN RE:

STATE VERSUS NISHU

INDEX

S.NO. PARTICULAR PAGE NO.

1. MEMO OF PARTIES

2.

APPLICATION ON BEHALF OF

APPLCIANT FOR GRANT OF

ANTICIPATRY BAIL U/S. 438

Cr.P.C. TO THE

APPLCIANT/ACCUSED.

3. COPY OF BOTH THE FIR.

4. VAKALATNAMA
DELHI APPLICANT/ACCUSED
DATED THROUGH

SUNIL PRASAD

ADVOCATE

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