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DPC 1

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Mahek Rathod
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27 views3 pages

DPC 1

Uploaded by

Mahek Rathod
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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COVER PAGE

NAME: MAHEK JAYESH RATHOD


G.R. NO.: LLB1356
DPC CERTIFICATE COURSE
IN THE COURT OF THE CHIEF JUDICIAL MAGISTRATE, MUMBAI
BAIL APPLICATION NO. 580 of 2023

In the matter of:


Rajesh Sharma
S/o Shri Ram Lal Sharma
R/o Vasant Kunj, S.v. Road,
Malad West,
Mumbai- 400067. ...Applicant/Accused

Versus

State of Maharashtra ...Respondent

APPLICATION U/S 438 OF THE CRIMINAL PROCEDURE CODE, 1973 FOR GRANT OF
ANTICIPATORY BAIL

MOST RESPECTFULLY SHOWETH:

1. That the present application is being filed by the Applicant under Section 438 of the Code of
Criminal Procedure seeking anticipatory bail in FIR No. 5010/20203 registered at Police Station
Borivali, Mumbai for offences punishable under Section 378 of the Indian Penal Code.

2. That the allegations against the Applicant are false and baseless. The Applicant has been falsely
implicated in the present case and he has not committed any offence as alleged by the police.

3. That the Applicant is an innocent person and has clean antecedents. There is no criminal case
pending against the Applicant in the past and he has never been convicted for any offence.
4. That the Petitioner is innocent and has been falsely implicated in this case. As per the FIR, it is
alleged that the Petitioner committed theft of cash Rs. 5 lakhs and jewellery from the complainant's
house. However, the Petitioner has not committed the said offences.

5. That the recovery shown from the Petitioner has been planted by police. The disclosure statement
of the Petitioner recorded under Section 27 of the Evidence Act cannot be solely relied upon to
implicate him in this case.

6. That the Applicant is ready and willing to abide by all conditions as may be imposed by this
Hon'ble Court while granting anticipatory bail. The Applicant undertakes to appear before the
Investigation Officer as and when required during the course of investigation.

5. That the Applicant apprehends his arrest in the present case which will cause irreparable loss,
damage and injury to his dignity and reputation in society.

6. That the Applicant is ready to furnish reliable surety for his release on bail.

PRAYER
In the light of facts and circumstances stated above, it is most humbly prayed that this Hon'ble Court
may graciously be pleased to:
a) Grant anticipatory bail to the Applicant and direct that in the event of his arrest, he shall be released
on bail during the pendency of the FIR/case on such terms and conditions as this Hon'ble Court deems
fit;

b) Pass such other order(s) as this Hon'ble Court may deem fit in the facts and circumstances of the
present case.

Applicant
Through Counsel

Advocate Mahek Rathod,


Bombay High Court,
Maharashtra.

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