IN THE HON’BLE HIGH COURT JUDICATURE AT ALLAHABAD

LUCKNOW BENCH, LUCKNOW

ABAIL ( U/S 438 Cr.P.C.) No. of 2024

Dilip S/O Sahaj Ram,Resident of V-8 raja ram mohanrai marg, in

front of parag dairy ,Lucknow,UP, Pin Code:226001
……..Applicant
VERSUS
Vinod Kumar
…….Opposite Party

Crime no-0461/2023
U/S:406,419,420,467,468,471,504,506 IPC
Police Station-Wazirganj
District:Gonda
 APPLICATION FOR INTERIM RELIEF

The above named Petitioner/Accused most respectfully submits as

under :- For the facts, reasons and circumstances stated in the
accompanying affidavit which forms inseparable part of this
application, it is most respectfully prayed that this Hon'ble Court
may kindly be pleased to release the Petitioner on interim
anticipatory bail vide case Crime
No.406,419,420,467,468,471,504,506 IPC related to Police Station
Wazirganj District Gonda, during the pendency of preferred
Anticipatory Bail Application, in interest of Justice.

Lucknow:
Date: 31/12/2023
Vidushi(Advocate)
AOR : B/M 1227
(Counsel for the Petitioner)
 IN THE HON’BLE HIGH COURT JUDICATURE AT ALLAHABAD
LUCKNOW BENCH, LUCKNOW
A BAIL ( U/S 438 Cr.P.C.) No. of 2024

Dilip S/O Sahaj Ram,Resident of V-8 raja ram mohanrai marg, in

front of parag dairy ,Lucknow,UP, Pin Code:226001
……..Applicant
VERSUS
Vinod Kumar
…….Opposite Party

Crime no-0461/2023
U/S:406,419,420,467,468,471,504,506 IPC
Police Station-Wazirganj
District:Gonda
FIRST APPLICATION FOR ANTICIPATORY BAIL U/S 438 Cr.P.C

The above named Petitioner/Accused most respectfully submits as

under :- For the facts, reasons and circumstances stated in the
accompanying affidavit which forms inseparable part of this
application, it is most respectfully prayed that this Hon'ble Court
may kindly be pleased to release the Petitioner on anticipatory bail
vide Case Crime No. 0461/2023
U/S:406,419,420,467,468,471,504,506 IPC related to Police Station
Wazirganj, District Gonda, during the pendency of trial of the
aforesaid case, in interest of Justice.

Lucknow:
Date: 31/12/2023

Vidushi(Advocate)
AOR : B/M 1227
(Counsel for the Petitioner)
 IN THE HON’BLE HIGH COURT JUDICATURE AT ALLAHABAD
LUCKNOW BENCH, LUCKNOW
A BAIL ( U/S 438 Cr.P.C.) No. of 2024

Dilip S/O Sahaj Ram,Resident of V-8 raja ram mohanrai marg, in

front of parag dairy ,Lucknow,UP, Pin Code:226001
……..Applicant
VERSUS
Vinod Kumar
…….Opposite Party

Crime no-0461/2023
U/S:406,419,420,467,468,471,504,506 IPC
Police Station-Wazirganj
District:Gonda
 AFFIDAVIT
(In Support of first anticipatory bail application U/S 438
Cr.P.C.)

I the deponent Sahej Ram ,aged about 58 years ,Resident of V-8

raja ram mohanrai marg, in front of parag dairy ,Lucknow,UP, Pin
Code:226001, Religion – Hindu, Qualification – literate, Occupation
– Private Job, Deponant’s Aadhaar No. 5666 1159 7660 , do hereby
solemnly affirm and state on oath as under-
1. That the deponent is the father of the Applicant/Accused in
the above noted case, therefore, he is fully conversant with all
the facts and circumstances of the case deposed here under.
2. That this is the first bail application for bail is being moved by
and on behalf of the applicant, above named, in relation to
instant case i.e. Crime No.0461 /2023 U/S: 406, 419, 420,
467, 468, 471, 504, 506 IPC related to Police Station
Wazirganj District Gonda, Except Present Bail Application no
other bail application has been filed or pending before this
court or any other court in Gonda or at Wazirganj, nor has any
application, prior to present one has ever been rejected by the
Hon’ble Court, Either at Wazirganj or at Gonda.
3. That the applicant despite of being completely innocent, and
has committed no crime, still he has been falsely implicated in
this case by the complainant.
4. That for the perusal of this Hon’ble Court a true copy of First
Information Report Dated- 17.10.2023 Crime No.0461 /2023
U/S: 406, 419, 420, 467, 468, 471, 504, 506 IPC IPC, Police
Station - Wazirganj, District Gonda, is being annexed herewith
as Annexure No. 1.
5. That the applicant is one of the directors of Education
Consulting Services Company,Newing Educational Centre at
Mahanagar Vistar Khand,Lucknow.
6. That the applicant company provides services for consultation
in terms of education and is registered under the Registrar of
company,Lucknow,UP having its registered office at Lucknow.
7. That according to the First Information Report lodged by the
Complainant Vinod Kumar on 17.10.2023,alleging that the
applicant along with three other co-accused in the said crime
no. duped the complainant with 12,50,000 by giving the false
context that they would get complainant’s son Harshvikram’s
Singh admission in MBBS course at Dayanand
College,Ludhiana.
He further alleged that they were given a false belief on
reaching Ludhiana and made to stay in a hotel for three
months for which they had to pay extra money. Along with
this,he accused the accused of giving him fake admission and
fee payment receipts.
8. That as the matter of fact,the money which was transferred to
the accounts had no standing evidence of transaction receipts
to prove the transaction.A true photocopy of the bank
statement of Complainant is being attached herewith
Annexure no. 02.
9. That,further as the matter of fact,just after the lists were
announced for the college admission in MBBS course,the
complainant on finding his son’s name is not present in the
list,he lodged his FIR against the accused on 17.10.2023 to
recover his fees amount given for taking educational
consultation services at the accused Dilip’s company.
10. That before lodging the F.I.R by the complainant no Show
Cause notice was given to the Applicant by the complainant
for the full payment.
11. That the applicant clearly stated at the time of availing
services that there services do not guarantee admission
completely.
12. That the applicant and complainant had a form signed at
the time of availing services that this would not guarantee the
child admission and the applicant is not responsible if it is not
done.
13. That the complainant has given the repeated statement
as the content of F.I.R U/S 161 Cr.P.C. A true photocopy of
the statement of the complainant is being annexed herewith as
Annexure No. 3.
14. That the bare perusal of the FIR itself , would provide
specifically that the applicant has not forged any document.
15. That the allegations with respect to the Criminal Breach
of and cheating is devoid of any proof.
16. That all the sections imposed in the said FIR against the
applicant do not apply to him.
17. That the offenses alleged against the applicant are
exclusively triable by the court of Magistrate.
18. That the applicant is in jail since 18.12.2023 without
any offense.
19. That the applicant is ready to furnish the reliable
sureties for the release on bail.
20. That the applicant is the permanent of V-8 raja ram
mohanrai marg, in front of parag dairy ,Lucknow,UP, Pin
Code:226001. As such there is no chance of either absconding
away or tampering with the prosecution witness and the
complainant.
21. That the Petitioner/Accused will always appear before the
court concerned as and when summoned and will not misuse
the liberty of bail.
22. That the Petitioner/Accused is hereby undertaken to
obey the guidelines/directions/instructions of this Hon’ble
Court.
 23. That the Petitioner/Accused is ready to furnish the
sureties fixed by this Hon’ble Court.
24. That on considering the facts and circumstances of the
case, it is most respectfully prayed that this Hon’ble court may
graciously be pleased to grant the anticipatory bail to the
Petitioner in the said case.
LUCKNOW DEPONENT
DATE :31 /12/2024
 VERIFICATION
I, the above-named deponent, do hereby verify that the contents of
para 1 to 24 of this affidavit are true to my personal knowledge. No
part of it is false and nothing material has been concealed in it. So,
help me God.
LUCKNOW:
DATE: 31/12/2024 DEPONENT

I identify the above-named deponent who has signed before me on

the basis of records produced by him.
(VIDUSHI)
(Advocate)

Solemnly affirmed before me on /2023 at am/pm by the deponent,

who is identified by Sri Mohit Sharma, Advocate, Lucknow. I have
satisfied myself by examining the deponent that she has understood
the contents of the affidavit which have been read over and
explained to her by me.
(OATH COMMISSIONER)
 IN THE HON’BLE HIGH COURT JUDICATURE AT ALLAHABAD
LUCKNOW BENCH, LUCKNOW
ABAIL ( U/S 438 Cr.P.C.) No. of 2024

Dilip
……Applicant/Accused
VERSUS
Vinod Kumar
…..Opposite Party

INDEX

Sn Particulars Page
o no
01 Annexure no.1: FIR
02 Annexure no.2:Photocopy of bank transactions
03 Annexure no.3: Photocopy of statement of
complainant

LUCKNOW
DATED:17.12.2023

(COUNSEL FOR THE APPLICANT)

VIDUSHI(Advocate)
REG-UP 22983
MOB-8932432423