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    abp 368

    Uploaded by

    ajit kumar

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    © All Rights Reserved
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    abp 368

    Uploaded by

    ajit kumar
    6 views4 pages

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    © © All Rights Reserved

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    6 views4 pages

    abp 368

    Uploaded by

    ajit kumar

    Copyright:

    © All Rights Reserved
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    Download as docx, pdf, or txt
    of 4

    IN,

    THE COURT OF DISTRICT & SESSIONS JUDGE, PATNA

    ABP NO. /24

    In That the petitioner has never moved the matter of an application


    earlier for grant of Anticipatory bail
    or Regularbail before this Hon'ble
    Court or before the Hon’ble High Court. under section 438 of the Code

    of Criminal Procedure, 1973.

    And

    In the matter of :-

    1. Sudhir Kumar, Age about- years,


    2. Chandan Kumar, Age about- years,
    3. Vivek Ranjan Kumar, Age about- years,
    4. Sunil kumar, Age about- years all S/O- Subhdayal Paswan @ Sivdayal Paswan @
    Suryadayal Paswan, Resident of Narhi P.S.-Dulhin Bazar, District- Patna.
    … PETITIONERS
    VERSUS.
    The State of Bihar … OPP. PARTY

    The humble anticipatory bail petition on


    behalf of the petitioners named above;
    Most Respectfully Sheweth: -
    1. That the petitioners seek anticipatory bail in connection with Dulhin Bazar P.
    S.- case no. -368 of 23 registered under section
    341/342/323/324/326/307/325/379/34 of IPC.
    2. That the petitioners have never moved earlier for grant of Anticipatory bail or
    Regular bail before this Hon'ble Court or before the Hon’ble High Court.
    3. That the petitioners have no criminal antecedent.
    4. That the case of the prosecution is based on the written report of Sudama
    Paswan who said that the accused persons demanded the bike from the
    informant’s brother and on refusal all of them came into the house in the
    evening and attacked the informant brother with lathi, danda and knife and
    taken away the neck chain and Rupee 10,000/- from his pocket, they also
    attacked the mother of informant due to which her hand was broken.
    5. That on the basis of aforesaid facts, the police registered the instant case and
    took up the investigation.

    A copy of the FIR is annexed here

    with and marked as Annexure-1

    to this application.

    6. That the petitioners have not committed any such offence and has falsely

    been implicated in the alleged case.

    7. That there is general and omnibus allegation against the petitioners.


    8. That instant case is registered due to some misunderstanding over some

    trivial issue and the parties are no longer interest in proceeding with the

    case.

    9. That both the accused and informant are neighbors and compromise was

    entered into between informant and the petitioner including other

    accused persons and the said compromise petition is already on record of

    the concerned court.

    Copy of the compromise Petition is

    annexed here with and marked as

    Annexure-2 to this application.

    10. That there is a case and counter case vide Dulhin Bazar P. S.- case no. -367
    of 23 between the parties.
    Copy of the F.I.R of Dulhin Bazar P. S.-
    case no. -367 of 23 is annexed here
    with and marked as
    Annexure-3 to this application.
    11. That in the aforesaid facts, no fruitful purpose would be served to put the
    petitioners behind the bar.

    12. That the petitioners are the only bread earner of their family.
    13. That the petitioners are a law-abiding citizen having home and hearth within

    the jurisdiction of the Hon’ble Court and he is ready to abide by the directions

    and conditions, which may be given and imposed, while granting the prayer.

    It is, therefore, prayed that this Hon’ble Court be


    pleased to admit the petitioner to anticipatory bail in
    the event of arrest/surrender in connection with
    Dulhin Bazar P. S.- case no. -368 of 23 to the
    satisfaction of learned court below or his successor
    in office

    or

    be pleased to pass such other order/orders as may


    be deemed fit and proper.

    And for this, the petitioners shall ever pray.

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