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BEFORE THE HONOURABLE .

COURT, PLACE
Crl. MC in . Police Station Crime .. /2012 /2012

1. Name , aged

years,

S/o. (. Police Station Limit)


2.

Name , aged years, (.. Police Station Limit) years,

Petitioners/ Accused No.1,2 &3

3. Name , aged

S/o. .. .. -P.O, (.. Police Station Limit)

State represented by S.I of Police Place

Respondent

Petition filed by, Advocates, Manjeri, for and on behalf of the above named petitioners/Accused No. 1, 2& 3 under section 438 of the Code of Criminal Procedure.

FACTS OF THE CASE The petitioners are accused No. 1,2 &3 in Crime No./2012 of .. Police Station. The alleged offences are u/s 498(a), 406 and 323 r/w 34 IPC.

The first petitioner is the husband of the defacto complainant and the second and the third petitioners are mother and father of the first petitioner .The allegation revealed as per the first information report is that the first accused and the defacto complainant were got married 5 years back and they are having four year old child also. The defacto complainant was living along with the petitioners. During the stay at the hunsbands house, the defacto complainant was being subjected to cruelty and harassment by the petioners in want of more money and ornaments. The allegation in the FIR is baseless. But a false case was cooked up by the father of the defacto complainant to wreck vengeance against the first petitioner. But the defacto complainant was living happily with the first petitioner for the last 4 years. The defacto complainants father was in bad terms with the first accused.

Now the respondent police regularly visiting the house of the petitioners/accused and threaten the inmates of the house with dire consequences. GROUNDS FOR BAIL 1. The petitioners are totally innocent to the charges leveled against them. 2. The petitioners are not at all involved in this incident. They were falsely implicated by the defacto complainant only to harass the petitioners. 3. The petitioners are having no criminal antecedence. 4. The material witnesses in this case are already questioned by the police. Custodial interrogation is not at all necessary for further investigation. 5. The petitioners, if released on bail, shall not interfere with the investigation, influence the witness and tamper the evidence. 6. The petitioners have got sufficient solvent sureties to their release. 7. The petitioners if released on bail, are ready to abide any conditions imposed by this Honourable court, they shall not abscond also. Hence, it is humbly prayed that this Honorable Court may be pleased to direct the respondent police to release the petitioners in the event of their arrest or direct the Chief Judicial Magistrate Court, . to release them in the event of their surrender.

Humbly submitted. Dated this the .. day of .. 2012

Name ADVOCATE,.

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