IN THE HIGH COURT OFJUDICATURE

AT MADRAS

Crl.O.P.No. of 2024

in

Crime No.526 of 2024

(On the file of the Sub-Inspector of police, DusiPolice Station.
Tiruvannamalai District)

K.Kumar M46 years

So Kodhandan No.312Vinayagar Koil Street.
Chinna Ezhacheri Post.
Ezhacheri Tiruvannamalai Dist.
Tamil Nadu.
...Petitioner/Accused

-Vs

State by:
Sub-Inspector of Police,
DusiPolice Station,
Thiruvannamalai District
Crime No.526 of 2024 ..Respondent/Complainant

INDEX TO PAPER BOOK

S1.No. Date Description Page No

1 O8.i 2024Coding Sheet

08.11.2024 Anticipatory Bail Petition 2

3 08.11.2024 Vakalat S-b
Certified that the above copies are true from their extract originals
Dated at Chennai on this 8th day of November 2024

Counsel for Petitioner

 Single/DB
Senior Citizen
CODING SHEET
High Court of Judicaure at Madras Age

CRIMINAL SIDE
(to be filled by the Registry)
d d m m YY
Case Type k-op No of24| Date of Filing
S.RNo. Date of Presentation

(To be flled by the Appellant/ Petitioner in Black Ink)

Previously filcd Application,
If any and Date of Disposal
Appellant / Petitioner
Respondent / Respondent Stae
Duiphnvonouali0t.
Counsel for Appellant /
Pctitioncr s A hrbhar
Counsel for Respondent
Adincluding provision (s) of law
involved in the case
Subject Matter / Brief
Subject / Category Code
Connectcd / Previous /
Covered case, if any Type No of

Appellant in Jail Bail

Lower Court Case Type No of

d m m y
Date of Judgement
Name of the Lower Court
and District

Crime No. of of Police Station

In Cases of HCP
Name of the Detaining Authority: District Collector /Commissioner of Police
H.C.P. NonStatutory Statutory

Passing Officer Counsel for Petitioner/Appellant

(To be filed by the CourtOffice/ PA Concerned in Courtitself in Red In)
Nature of Disposal By.
d d m m y

Date of Disposal

Court Offcer /PA -

CHSS-81
Ser
 MEMORANDUM OFCRIMINAL ORIGINAL PETITION
Uls 482 of B.N.S.S.,2023
INTHE HIGHCOURT OF JUDICATURE AT MADRAS
Crl.0.P.No. of 2024
In
Crime No. 526/2024
(On the file of Sub-Inspector of Police , Dusi Police Station,
ThiruvannamalaiDistrict )

K.Kumar M/46 years

Slo Kodhandan
No.312 Vinayagar Koil Street,
Chinna Ezhacheri Post, Ezhacheri
TiruvannamalaiDistrict.
Tamilnadu- 631702
..Petitioner/Accused

-Vs

State by:
Sub-Inspector of Police,
DusiPolice Station,
Thiruvannamalai District
Crime No.526 of 2024 ...Respondent/Complainant

PETITION FOR ANTICIPATORY BAIL UNDER SEC. 482 of B.N.S.S.

The address for service of all notices and process on the Petitioners is that
of their counsel M/S A.ANBHARASU (1853/2021) and S.VISHAL
(9477/2022), Advocates, having office at No. 59, Varadharajan Street ,Vetri
Nagar, Chennai - 600 082.
The Petitioners above named begs to submit as follows:
1. This is the first Anticipatory bail filed by the petitioner before this Hon'ble
court. The petitioner has not moved any other petition seeking similar relief
before any other Court.
 alleged
2. The petitioner apprehends arrest at the hands of the respondent for the
and
offences Under section 303(2), 326a) of Bharatiya Nyaya Snhita(BNS)
section 21(5) of Mines and Minerals(Development & Regulation) Act, 1957 in
relation to the above Crime No.526 of 2024 by the respondent police and the
petitioner is the only accused in the aforesaid crime number.

3. The petitioners submit that the case of the prosecution is that while the
respondent police patrolling near dusi village, the police officials stopped a
bullock cart and found the petitioner/accused who transported 1/4 unit sand, this
was found at the place of occurrence. Hence the prosecution had filed the above
case against the petitioner. Factually the petitioner had not committed any
offence as alleged by the prosecution. The petitioner had been falsely implicated
in the above case based on the false information.

4. The petitioner submits that he is innocent and he had not committed any
offence as alleged by the respondent, the FlR is not available in the Portal. The
petitioner also states that he has nothing to do with the alleged offence.

5. The petitioner submits that the respondent falsely registered a case against the
petitioner suo moto at the time of patrolling.

6. The Petitioner is an innocent, law abiding citizen, he did not commit any
offence and he had been falsely implicated in this case. The Respondent police
want to arrest the Petitioner and he apprehends arrest in the hands of respondent
police. Unless this Hon'ble Court grants Anticipatory Bail to the Petitioner he
willbe put to great hardship.
7. The petitioner submits hat no previous case apainst him and he is ready to
abide by any condition imposed on them by this Hon'ble Court and execute
suflicient sureties as directed.

8.The petitioner submits that there is no similar bail petition pending before any
other Court. Unless this Hon'ble Court enlarges the Petitioners on Bail he will
be put to great hardship.

Hence, it is prayed that this Hon'ble Court may be pleased to grant anticipatory
bail to the petitioner in the event of the arrest of petitioner by police for the
reasons stated in the petition, in connection with the case in Crime No.526 of

2024 on the file of the respondent police andpass such further or other orders as
may be deemed fit and proper by this Hon'ble court in these circumstances of
this case and thus render justice.

Dated at Chennai on this 08th day of November 2024

Counsel for Petitioner/Accused

1. Bail satisfaction to Judicial Magistrate, Cheyyar

2. This is the first anticipatory petition before this Hon'ble court.
3. Nosimilar petition is pending before any other court.
4. P.P.Copy enclosed
 IN THE HIGH COURT OF
JUDICATURE AT MADRAS

Crl. O.P.No. of 2024

in

Crime No.526 of 2024

(On the file of the Sub-Inspector of police,
Dusi Police Station,
TiruvannamalaiDistrict)
K.Kumar M/46 years
S/o Kodhandan
No.312 Vinayagar Koil Street,
Chinna Ezhacheri Post,
Ezhacheri Tiruvannamalai District.
Tamilnadu- 631702 .Petitioner/Accused

-Vs
State by:
Sub-Inspector of Police,
Dusi Police Station,
Thiruvannamalai District
Crime No.526 of 2024
.Respondent/Complainant

PETITION FOR
ANTICIPATORY BAIL FILED
US 482 OF B.N.S.S.

Counsel for Petitioner/Accused

MIS A.ANBHARASU (1853/2021)
S.VISHAL (9477/2022)
No.59,Varadharajan Street, Vetri Nagar,
Chennai - 600 082.
Contact Nos:8925268223 || 7010262446
[email protected]
 INTHE HIGH COURT OF JUDICATURE AT MADRAS R
0807745
Crl.0.P.No. of 2024
in TAMILAU ADVOCATES
TAMI

THIRTY RUPEES
Crime No. 526 of 2024
(On the file of Inspector of Police , Dusi Police Station.
ThiruvannamalaiDistrict ) FO893001

K.Kumar M/46 years TAMIL NADU ADVOCATES CLERKS

40 WELFARE FUND STAMP

R10TEN RUPEES
A

S/oKodhandan No.3 12 Vinayagar Koil Street, 210

Chinna Ezhacheri Post,
Ezhacheri Tiruvannamalai District.
Tamilnadu- 631702 ...Petitioner/Accused

-Vs

State by:
Sub-Inspector of Police,
Dusi Police Station,
Thiruvannamalai District
Crime No.526 of 2024 ...Respondent/Complainant
IK.Kumar Slo Kodhandan in the above Appeal /Petition do hereby appoint and retainM/S
A.ANBHARASU (1853/202 1) and S.VISHAL (9477/2022) Advocates of the High Court to
appear for me/us in the above Appeal / Petition to conduct and to prosecute (or defend) the
same and all proceedings that may be taken in respect of any application connected with the
same or any decree or orders passed herein including all applications for return of documents
or the receipt of the money that may be payable to me/us in the said Appeal/Petition and also
in appeal under Section 15 of the Letters Patent and in applications for leave to Supreme Court
of India, and in all applications for review of Judgement.
Icertify that the contents of this
Vakalat were read out and
explained in TAMIL in my
presence to the Executant who
appeared perfectly to understand
4 S , a d d . l a

the same and signed his/her name

d a s e r
in my presence.

Dated at Chennai on this 08th day of November 2024

ACCEPTED : The Address for Service of the said Court is at No.59,Varadharajan

Street, VetriNagar, Chennai - 600 082. Contact Nos: 8925268223 || 7010262446
[email protected]

Counsel or Petitioner/Accused
 IN THE HIGH COURT OF
JUDICATURE AT MADRAS

Crl. O.P.No. of 2024

in

Crime No.52 6of 2024

(On the file of the Sub-Inspector of police,
DusiPolice Station,
Tiruvannamalai District)
K.Kumar M/46 years
Slo Kodhandan No.238
Mariamman Koil Street,
Chinna Ezhacherri Post.
Ezhacheri Tiruvannamalai District.
Tamilnadu- 631702 ...PetitionerAccused
-Vs
State by:
Sub-Inspector of Police,
Dusi Police Station,
Thiruvannamalai District
Crime No.526 of 2024
..Respondent Complainant

VAKALAT

Counsel for Petitioner/Accused

M/S A.ANBHARASU (1853/202 1)
S.VISHAL (9477/2022)
No.59,Varadharajan Street, Vetri Nagar,
Chennai - 600 082.
Contact Nos:8925268223 | 7010262446
[email protected]