BEFORE THE HON’BLE HIGH COURT AT BILASPUR

(C.G.)

Cr.A. No. 1985 OF 2017

APPELLANT Naveen Sahu

VERSUS
RESPONDENT State of C.G.

Objection on behalf of the Objector/Complainant

Gokul Patel.

The following is most humbly and respectfully submitted

on behalf of the objector/complainant.

The appellant has moved an application for suspension of

sentence and grant of bail before this Hon’ble Court. The
complainant objects on the same as follows:

A. The appellant, Naveen Sahu is a professional Dacoit,

a habitual criminal and is a member of the Narayan
Bariha gang, which is a popular robbery/dacoity
team in the state of Chattisgarh, Odisha and other
neighbouring States. Many offences are registered in
the Police Sation of Saraipali, Basana, Mahasamund
and in the neighbouring area against the appellant.
So, if the appellant is released on bail it will be
 dangerous for the society. Hence he should not be
released on bail for the safety of the people.

B. The Co-accused in the instant matter of Dacoity,

Narayan Bariha, who is also the leader of the
appellant’s gang is still absconding with all the gold
and silver looted from the house of the complainant.
The police after all their efforts have not been able to
catch this professional dacoit till today. The appellant
being a member of the same gang as the leader
Narayan Bariha must be having similar contacts and
it would be difficult to catch him once he is released
on bail. So, it is most humbly prayed that the
appellant should not be released on bail.

C. The petition for enhancement of sentence of the

appellant in the instant matter is also pending before
the division bench of this Hon’ble Court, therefore the
appellant should not be released on bail till the
disposal of such petition.

D. The appellant if released on bail might try to abscond

as there is clear case against the appellant, the
prosecution has proved the case beyond reasonable
doubt and there is no chances of him getting
 acquitted in the instant appeal. Therefore it is most
humbly and respectfully prayed that the appellant
should not be released on bail.

PRAYER

It is therefore, prayed that the bail application of present

applicant/appellant be dismissed by this Hon’ble Court in
the interest of justice.

BILASPUR (Keshav Shankar Nande)

Date: /04/2018 COUNSEL FOR THE OBJECTOR