Scribd
Upload
32 views3 pages

ANTICIPATORY BAIL Project

hc

Uploaded by

Binit kumar
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
32 views3 pages

ANTICIPATORY BAIL Project

hc

Uploaded by

Binit kumar
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
You are on page 1/ 3

1

DISTRICT – SOUTH 24 PARGANAS

IN THE COURT OF THE LEARNED DISTRICT & SESSION JUDGE AT


ALIPORE

Criminal Misc (bail) Petition no. 69 of 2024

In re: Apprehension of arrest Bhangore P.S Case No./F. I. R No. 483


lodged at Bhangore Police Station Under Section
86/117(2)/316(2)/351(2)/3(5) B.N.S, 2023 dated 01.09.2024

Binit Kumar, son of Santosh Kumar,


residing Baghajatin, Kolkata – 700092.
…… Accused/Applicant
vs-
State of West Bengal
….. Complainant
An application for Pre – arrest bail under Section 438 Criminal Procedure
Code, 1973
The humble petition on behalf of the
accused/petitioner/applicant above-
named
Most respectfully sheweth:-

1. That the accused/petitioner/applicant herein is a government employee


serving as a Motor Vehicle Inspector currently posted at Jadavpur in Motor
Vehicle Department under the Government of West Bengal.

2 That the F.I.R bearing no. 483 of 2023 dated 01.09.2024 has been
registered against the petitioner/accused/applicant under sections
86/117(2)/316(2)/351(2)/3(5) of the Bharatiya Nyaya Sanhita, 2023 at
Bhangore police Station banking upon vague, wild and omnibus allegations.

3. That your petitioner/accused/applicant is a law abiding, peace loving,


responsible and respectable citizen of India, having deep root in the society
and permanently residing at given as cause tittle.

A Photostat copy of the Aadhaar Card standing in the name of the


petitioner/accused/applicant is being annexed to the instant pre-arrest bail
plea and marked as Annexure ‘A-1’.

4. That your petitioner/accused/applicant is totally an innocent person and


has been arrayed as an accused and falsely implicated in the above-
mentioned case.

5. That your petitioner/accused/applicant does have clean antecedent.

6. That petitioner/accused/applicant is the husband of the defecto


complainant and their marriage was solemnized on 20.07.2024 but the said
F.I.R has been registered after a gap of so many years. Still the petitioner/
accused/applicant herein very much dutiful towards his wife and child.

7. That the petitioner/accused/applicant met the investigation officer by


visiting the Bhangore Police Station as to comply in terms of the 35 BNSS
1973 notice issued by the investigation officer pertains to the afore-
mentioned case.

A photostat copy of the compliance in terms of 35 BNSS 1973 is being


annexed to the instant bail plea and marked as Annexure ‘A-2’.
2

8. That the afore-mentioned case was registered on 01.09.2024 under


Section 86/117(2)/316(2)/351(2)/3(5) of the Bharatiya Nyaya Sanhita, 2023
but no notice was served upon the petitioner/accused/applicant till
02.11.2024.

9. That there is no possibility/or scope of fleeing/absconsion from the course


of justice and no scope of tampering with the evidence or inducement to the
witnesses on the part of the petitioner/accused/applicant herein. The
petitioner/accused/applicant herein are ever willing to render co- operation
to the fullest with the investigative agency as and when required.

10. The accused/petitioner/applicant do have apprehension of arrest even


after compliance of Section 35 BNSS 2023 notice. The accused/
petitioner/applicant further fear that his liberty may be curtailed/or curved by
way of arbitrary arrest.

11. The accused/petitioner/applicant herein state that no such pre arrest bail
application is neither pending nor disposed of before the Honorable High
Court, Calcutta.

12. That the accused/petitioner/applicant hereby undertake to abide by


terms and conditions to be imposed by this Learned Court while grant of the
bail plea.

13. That this Learned Court does have jurisdiction to entertain and disposed
of the instant pre-arrest bail plea.

14. That the instant bail plea is made bonafide and for the securing the ends
of justice.

In the light of the above


conspectus, it is therefore most
humbly prayed that your Honour
may graciously be pleased to
grant/ release/ enlarge on bail the
accused person/ petitioner/
applicant herein in connection with
Bhangore P.S. Case no
86/117(2)/316(2)/351(2)/3(5) of
the Bharatiya Nyaya Sanhita, 2023
now pending before the Learned
Additional Chief Judicial Magistrate
at Baruipur and to pass such order
or orders as your Honour may
deem fit and proper in the interest
of justice.

And for this act of kindness your petitioners as in duty bound shall ever pray.

VERIFICATION
I, Binit Kumar, the accused/applicant herein, do hereby declare and say that
the statements made in paragraphs 01 to 12 of the foregoing application are
true to my knowledge and rest is my submission before the Learned Court.

I signed this verification on this the 01 day of March, 2024 at our Court
premises.

Prepared at my Office
3

Advocate

AFFIDAVIT

I, Binit Kumar, son of Santosh Kumar, aged about 25 years, by faith Hindu, by
occupation-business, residing at Baghajatin, Kolkata- 700092 do hereby solemnly
affirm and say as follows: -

1. That I am the petitioner and well conversant with the facts and
circumstances of this case and competent to swear this affidavit.

2. That the statements made in paragraphs no. 1 to 11 are true to my


knowledge and the rest is my humble submission before the Ld. Court.

Identified by me

Advocate DEPONENT

You might also like