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APPLICATION FOR REGULAR BAIL

Application under Section 436 of Cr PC for the grant of Bail

IN THE COURT OF Judicial Magistrate Ist Class . ADDITIONAL DISTRICT AND


SESSION JUDGE, COURTS,

Atul kumar

Son of Akhilesh singh

R/o 123, A B Road,

APPLICANT/PETITIONER.

VERSUS

State of uttar pradesh.

.RESPONDENT

IN THE MATTER OF:-

FIR NO. 1234 , DATED 25-05-2017 UNDER SECTION 323 and 325 of IPC, P.S- .

FIRST APPLILCATION FOR REGULAR BAIL

MOST RESPECTFULLY SHEWETH:-

1- That the petitioner belongs to a respectable family and he has clean antecedents.

2- That the petitioner has been framed up and falsely implicated in the above noted case by
the complainant on extraneous grounds and he is in custody since 21-05-2017 .

3- That the police does not require further custody of the petitioner for the purpose of
investigation in the case and the petitioner has therefore been remanded to judicial custody.
4- That the petitioner has been framed up in the case because amarjit kumar son of Sh. Ravi
kumar complainant was forcefully trying to take the possession of the house which belongs to
the applicant .The house is situated in abcd road , Varanasi . Applicant parents live in that
house . amarjit kumar was drunk and was not in his conscience he started throwing the
furniture of the house and abused his parents . applicant went to rescue his parents and tried
to stop him but he didnt stopped and started fighting with the applicant . After the separated
by the neighbours and everything got normal amarjit kumar filed a false complaint aganist
the applicant in lanka thana Varanasi and the applicant got arrested .

5. That the Petitioner is innocent and no useful purpose would be served by keeping him
under custody and this is a fit case for grant of bail. (It would be pertinent to mention as to
the stage of investigation or in case the charge sheet has been filed, whether charges have
been imposed, evidence has started, the length of the list of witnesses cited by the prosecution
etc. as these would all be mitigating circumstances)

6. That the Petitioner undertakes to abide by the conditions that this Honorable Court may
impose at the time of granting bail to the Petitioner and further undertakes to attend the trial
on every date of hearing.

7. That the Petitioner has not filed any other similar petition before this or any other
Honorable Court for grant of bail in case of the present FIR. (Or give details and results of
earlier applications)

PRAYER:

In view of the above stated facts and circumstances it is most respectfully prayed that this
Honorable Court may be pleased to
a. Grant bail to the Petitioner in connection with FIR No. 1234 registered under section
323 and 325 of ipc , at Police Station lanka thana varanasi.
b. Pass any other such order as this Honorable Court may deem fit and proper in the
interest of justice.
Atul kumar.Petitioner
Through
Dated: 23-05-2017

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