Draft of bail application under Section 437 of Criminal Procedure Code.

IN THE COURT OF SH.SUMIT SAURABH, M.M.    PATIALA HOUSE COURTS, NEW DELHI

            Bail Application No.          of 2022

STATE              VERSUS               VIKASH

FIR NO. 112/21

U/S. 379 IPC

P.S. Sagar Pur

APPLICATION UNDER SECTION 437, CRIMINAL PROCEDURE CODE, 1973 FOR BAIL ON BEHALF OF ACCUSED VIKASH.

The Accused above- named most respectfully showeth :-

1. That the accused/applicant was arrested by the police on 30.11.2021 and was produced before the Hon’ble Court on 01.12.2021 and was remanded to police custody for one day. Thereafter the accused/ applicant was sent to judicial custody on 02.12.2021 and is in jail since then.
2. That on the basis of the statements of the complainant, an FIR NO. 112/21 dated 11.11.2021 was registered at  Sagar Pur Police Station U/s. 379 IPC against the two unknown persons. As per FIR, the complainant resides at House no. EC-1, Inder Puri New Delhi. On 11.11.2021 his following articles were stolen by two unknown persons from his car. 1. Briefcase 2. Rs. 1,25,000/- (Old Note of Rs.1000/- and Rs 500/- 3. Registration certificate Car No. DL 8CAN 9927 4. C Five Nos. of C Form.) at Dev Prakash Shastri Marg in front of International Guest House Pusa, New Delhi.
3. That the Applicant/Accused has been falsely implicated in the instant case as he has nothing to do with the alleged offence.
4. That it is pertinent to mention here that the complainant/accused was called to police station and when he reached there he was shocked to know that he had been involved in a case alongwith other accused persons.
5. That in this case after the gap of 20 days from the incident, police have arrested three persons including the Applicant /Accused whereas FIR shows the involvement of only two unknown persons which makes the story of the prosecution  against the Applicant/Accused  false and doubtful.
6. That the Applicant/Accused is an young boy of 20 years of age and helps his parents in earning the livelihood by pulling a Thela Gari (Rikshaw) on rent for last 2-3 years. He has two younger unmarried sisters. That the Accused belongs to a poor but respectable family originating from Andhra Pradesh and has never indulged in any illegal activities or case.
7. That the accused is a resident of B-2,  Inder Puri, South West Delhi and there is no chance of his absconding in case  if he is released on bail.
8. That the Accused is prepared to join the investigation as and when he is directed to do so.
9. That the Accused has clean antecedent and has never been involved earlier in any crime of any nature.
10. That the Accused from all account is an innocent person.

PRAYER

It is, therefore, most respectfully prayed that the Accused may kindly be released on bail during the pendency of this case in the interest of justice.

Accused

Through

( Avinash Nandan Sharma)

Advocate

Delhi                                                Ch.No.671, Patiala House Court

Date:                                                 New Delhi, Mob: 8800794128