In the court of sh.

Rajvinder Singh, JMIC, Ludhiana

Pawan Kumar s/o Sh. Banarsi Dass r/o H.No.1533, Mohalla

Bandayan, Daresi Road, Ludhiana.

Versus

Smt. Jasvir Kaur D/o Sh. Surjit Singh w/o of Sh.

Harvinder Singh r/o Mohalla Reru Sahib, Lohara, Tehsil
and Distt. Ludhiana.

1
In the court of sh. Rajvinder Singh, JMIC, Ludhiana

Pawan Kumar s/o Sh. Banarsi Dass r/o H.No.1533, Mohalla

Bandayan, Daresi Road, Ludhiana.

Versus

Smt. Jasvir Kaur D/o Sh. Surjit Singh w/o of Sh.

Harvinder Singh r/o Mohalla Reru Sahib, Lohara, Tehsil
and Distt. Ludhiana.

Application for suspension of sentence till

the filing of appeal and for bail.

Respectfully Showeth;

1. That this Hon'ble Court vide its order dated 9/11/2010

is pleased to convict the accused to undergo imprisonment
for two years and fine to the tune of Rs.5,000/-.

2. That the applicant wants to file appeal against the

said order before the Hon'ble Sessions Court and is ready to
pay fine.

It is, therefore, respectfully prayed that sentence may

please be suspended till filing of appeal and the
applicant may please be released on bail, in the
interest of justice.

applicant
Through Counsel

Place:- Ludhiana Ravinder Singh Rana

Date:-09/11/2010 Advocate

2
In the court of Sessions Judge, Ludhiana.

State Vs. Harjinder Singh

S/o Amarjit Singh R/o
Dhalipatti, Attiana Road,
Sudhar, Distt. Ludhiana

FIR No. 121 dt. 27/9/2009,

U/s. 406/498-A/120-B IPC,
P.S. Sudhar, Ldh.

Note:-1. This is the first bail

Application and no such bail
Application is pending or decided
by any competent court of law.

Application u/s 438 of Cr.P.C. for grant of

Anticipatory bail.

Respectfully Showeth;

1. That the petitioner is peace-loving and law abiding

citizen of India.

2. That the petitioner was married to Ramandeep Kaur D/o

Sh. Jagtar Singh R/o Chhanna Gate, Ahmadgarh, Sangrur on
30/12/2006 and no child was born out of this wedlock.

3. That soon after the marriage the behaviour of the said

Ramandeep towards the petitioner and his family members was
not cordial and good rather it was cruel and un-adjustable
because she started picking up quarrels on petty matters and
she several times left matrimonial house at the instance of
her parents and every time the matter got reconciled with
the intervention of respectables and relatives. Due to her
behaviour and pressure he started living separate from his
parents even his parents also disowned him. Even her father
misbehaved with the petitioner and ultimately she left her
matrimonial house on 8-12-2008 after taking all her jewelry
items and other valuable articles. since then she never came
back. Her father demanded that the petitioner must purchase
3
a plot on his daughter's name only then she will go to her
matrimonial house as the petitioner was unable to do so, so
he filed suit u/s 9 of HMA which is pending in the court of
Smt. M.K.Bedi, ACJSD, Jagraon for 5-10-2009.

4. That now the said Ramandeep Kaur and her parents

lodged a false complaint/FIR against the petitioner, his
parents and even against his maternal uncle and aunty. His
parents have already been taken in the custody by concerned
police on 02-10-2009 and the police is raiding the house of
the petitioner to arrest him in the above said false FIR. So
the petitioner is having apprehension that the police may
arrest him in non-bailable offences.

5. That even the perusal of the FIR shows that no offence

is made out against the petitioner.

6. That the alleged recovery of alleged dowry articles has

already been effected by the police. So custodial
interrogation of the petitioner is not required at all.

7. That the petitioner undertakes to abide by all the

terms and conditions as may be imposed by this Hon’ble court
while granting him bail.

8. That the petitioner undertakes not to directly or

indirectly make any inducement, threats, or promise to any
person acquainted with the facts of the case so as to
dissuade him from disclosing such facts of the court or to
any police officer.

9. That the petitioner undertakes not to leave India

without the prior permission of this Hon'ble court and there
is no likelihood of absconding of the petitioner.

10. That the petitioner undertakes to make himself

available for interrogation by the police officer as and
when the same is required.

It is, therefore, respectfully prayed that the

petitioner may please be granted anticipatory bail and in
4
the meantime arrest of the petitioner may kindly be stayed
in the interest of justice.

Petitioner
Through Counsel

Place:- Ludhiana K. M. Sethi

Date:-03/10/2009 Advocate

5
In the court of Sessions Judge, Ludhiana.

State Vs. Harjinder Singh

AFFIDAVIT

I, Harjinder Singh S/o Amarjit Singh R/o Dhalipatti,

Attiana Road, Sudhar, Distt. Ludhiana do hereby solemnly

affirm and declare as under:-

1. That this is first bail application of the deponent for

the grant of anticipatory bail. No such bail application is

either pending or has been decided by any court of competent

jurisdiction.

Deponent
Verification:-
Verified that above contents of this are true and

correct to the best of my knowledge and belief and nothing

has been concealed therein.

Place: Ludhiana.
Date:- 03/10/2009 Deponent

6
In the court of Sessions Judge, Ludhiana.

State Vs. 1. Harpal Singh

S/o Modan Singh,
2. Sinderpal Kaur
w/o Harpal Singh
Both rs/o Sihra,
PS Basti Jodhewal,
Ludhiana

FIR No. 121 dt. 27/9/2009,

U/s. 406/498-A/120-B IPC,
P.S. Sudhar, Ldh.

Note:-1. This is the first bail

Application and no such bail
Application is pending or decided
by any competent court of law.

Application u/s 438 of Cr.P.C. for grant of

Anticipatory bail.

Respectfully showeth;

1. That the petitioners are peace-loving and law abiding

citizen of India.

2. That the petitioner no. 1 is the maternal uncle(mama)

and petitioner no. 2 is maternal aunti(mami) of the husband
of the complainant and both are staying away at village
Sihra which is about 60 kms. away from the village Sudhar,
the matrimonial place of the complainant and they have
nothing to do with the marital life of the complainant or
his husband.

3. That the petitioner no.1 is a labourer working with

some mason and he is so engrossed in earning his bread and
butter that he has no time even to visit the matrimonial
house of complainant hence the question of his or his wife's
interference in the matrimonial life the complaint does not
arise at all. They have been falsely implicated just to
harass them and just to put a pressure upon them.

7
4. That at the instance of the complainant the police
concerned is raiding the house of the petitioners to arrest
them in the above said false and frivolous FIR and due to
raid the petitioners are hampered in their livelihood. So
the petitioner are having apprehension that the police may
arrest them in non-bailable offences for no reason.

5. That even the perusal of the FIR shows that no offence

is made out against the petitioners.

6. That the petitioners undertake to abide by all the

terms and conditions as may be imposed by this Hon’ble court
while granting them bail.

7. That the petitioners undertake not to directly or

indirectly make any inducement, threats, or promise to any
person acquainted with the facts of the case so as to
dissuade him from disclosing such facts of the court or to
any police officer.

8. That the petitioners undertakes not to leave India

without the prior permission of this Hon'ble court and there
is no likelihood of absconding of the petitioners.

9. That the petitioner undertakes to make themselves

available for interrogation by the police officer as and
when the same is required.

It is, therefore, respectfully prayed that the

petitioners may please be granted anticipatory bail and in
the meantime the directions be passed on to the concerned
police to stay their arrest, in the interest of justice.

Petitioners

Through Counsel

Place:- Ludhiana K. M. Sethi

Date:-03/10/2009 Advocate

8
In the court of Sessions Judge, Ludhiana.

State Vs. Harpal Singh & another.

AFFIDAVIT

I, Harpal Singh S/o Modan Singh, R/o Sihra, PS Basti

Jodhewal, Ludhiana do hereby solemnly affirm and declare as

under:-

1. That this is first bail application of the deponent and

his wife for the grant of anticipatory bail. No such bail

application is either pending or has been decided by any

court of competent jurisdiction.

Deponent
Verification:-
Verified that above contents of this are true and

correct to the best of my knowledge and belief and nothing

has been concealed therein.

Place: Ludhiana.
Date:- 03/10/2009 Deponent

9
In the court of Sessions Judge, Ludhiana

State Vs. Sanjay Kumar.

FIR No. 224/3-11-2006,
U/s. 279/304A IPC,
P.S. Div.No.7, Ldh.

Application u/s 438 Cr.P.C.

for grant of Anticipatory bail.
Sir,
The petitioner respectfully submits as under:-

1. That the above noted case is pending in the

court of Sh. K.K.Bansal, JMIC, Ludhiana and is now
fixed for 9-01-2009.

2. That the petitioner is law abiding and peace

loving citizen of India and he has never been
involved in any criminal activity.

3. That earlier the above said case was fixed on

5/12/2007 in the above said court and the accused
was present come before the Ld. Court of Sh. K.K.
Bansal, JMIC, Ludhiana and thereafter the case was
adjourned to 28-5-2008 but untowardly the
petitioner fell and he was undergoing medical
treatment and that is the reason he could not come
present before the Ld. Court of K.K. Bansal, JMIC,
Ludhiana and Ld. Court issued non-bailable warrant
against the petitioner. Thereafter the petitioner
went away to home to restore his long illness and
could not come present on 16-9-2008 as he could not
be informed regarding the date of case. When the

10
petitioner returned from home to Ludhiana, he came
to know about the non-bailable warrant issued by
the Ld. Court against him and he immediately moved
this application for the grant of anticipatory
bail.

4. That the absence of the accused/applicant was

neither willful nor intentional rather
circumstantial as stated above.

5. That Applicant undertakes that he will abide

by all the terms and conditions imposed by this
Hon’ble Court while granting him bail.

It is therefore, respectfully prayed that the

applicant/accused may kindly be granted
anticipatory and in the event of arrest, necessary
direction may also please be given to the concerned
police officer to release him on bail in the
interest of justice.

Applicant/accused

Through counsel

Place: -Ludhiana A.K.Giri,

Date:-18-12-2008 (Advocate)

11
In the court of Sessions Judge, Ludhiana

State Vs. Sanjay Kumar

AFFIDAVIT

I, Sanjay Kumar s/o Ram Saj Shah, R/o Vishkarma

Colony, Gali No.5, Moti Nagar, Ludhiana

Ludhiana, do hereby solemnly affirm and

declare as under:-

1. That this is first bail application of the

deponent for the grant of anticipatory bail. No

such bail application is either pending or has been

decided by any court of competent jurisdiction.

Deponent
Verification:-
Verified that above contents of this are true

and correct to the best of my knowledge and belief

and nothing has been concealed therein.

Place: Ludhiana.
Date:18/12/2008 Deponent

12
Sir

In ref:-Your letter no. 2148 dated 25-10-1983

regarding copy of Birth of Sh. Satnam Singh s/o
Sardara singh s/o Jawala Singh, Community,
village Faizulla Chak of the year 1948,49, 50,
P.S. Dhariwal, the Birth record of this office
had been searched but the Birth Entry is not
available in the record.
Sd/ in English
(Data assistant)

Office of District Registrar, Birth and Death,

Gurdaspur and the report regarding Non-availability
of Birth record is being sent to Satnam Singh r/o
Ludhiana.
Sd/-
(Sign and seal)
Additional District
Registrar of Birth & Deaths
Gurdaspur.

(True translation from original Punjabi to English)

13
In the court of Sessions Judge, Ludhiana

State Vs. 1. Balbir Singh

2. Maru @ Dalbir Singh
both sons of Gurnam Singh
Rs/o village Hathur,
Distt. Ludhiana

FIR No. 112/17-5-08,

U/s. 452/323/354/506/34 IPC,
P.S. Jagraon, Ludhiana (R)

Application u/s 438 Cr.P.C.

for grant of Anticipatory bail.

Most respectfully showeth;

1. That the petitioners are law abiding and peace

loving citizens of India.

2. That the petitioners have committed no offence

and are being implicated in a false case.

3. That the above said FIR was lodge at the

instance of Jasbir Kaur w/o Gurmukh Singh who is
daughter in law of the sister of the petitioners.
She was having some dispute regarding passage/Rasta
with the other brothers of her husband and a
Panchayat was called to resolve the dispute between
the complainant and other brothers of her husband
and the petitioners which are maternal uncles of
the husband of the complainant went there as
mediators to resolve the matter between the
families of the Bhanjas, as most of the men of the
family including the husband of the complainant are
living abroad i.e. in Muskat and they are not
involved in any type of brawl with the complainant

14
and they are being falsely implicated due political
reasons.

4. That there is a sufficient delay in lodging of

the FIR which shows that the matter is just a
deliberate attempt to falsely implicate the
petitioners on false and frivolous grounds.

5. That at the instance of the complainant the

police of P.s. Jagraon is raiding the house of the
petitioners to arrest them.

6. That the petitioners have reason to believe

that the police may arrest them at any time on the
basis of false FIR.

7. That petitioners undertake that they will abide

by all the terms and conditions imposed by this
Hon’ble Court while granting them bail.

8. That the petitioners undertake to make

themselves available for interrogation by the
police officer as and when the same is required.

9. That the petitioners undertake not to directly

or indirectly make any inducement, threats, or
promise to any person acquainted with the facts of
the case so as to dissuade him from disclosing such
facts to the court or to any police officer.

10. That the petitioners undertake that they shall

not leave India without previous permission of the
court.

15
 It is therefore, respectfully prayed that the
applicant/accused may kindly be granted
anticipatory bail and in the event of arrest,
necessary direction may also please be given to the
concerned police officer to release them on bail in
the interest of justice.

Applicant/accused

Through counsel

Place: -Ludhiana K.M.Sethi,

Date:-20-05-2008 Advocate

16
In the court of Sessions Judge, Ludhiana

State Vs. Balbir Singh & another

AFFIDAVIT

I, Balbir Singh aged 56 years s/o Gurnam Singh r/o

village Hathur, Distt. Ludhiana, do hereby
solemnly affirm and declare as under:-

1. That this is first bail application of the

deponent and co-applicant. No such bail application

is either pending or has been decided by any court

of competent jurisdiction.

Deponent
Verification:-
Verified that above contents of this are true
and correct to the best of my knowledge and belief
and nothing has been concealed therein.

Place: Ludhiana.
Date:20/05/2008 Deponent

17
18
 IN THE COURT OF HON'BLE SESSIONS JUDGE; LUDHIANA

Gurpreet Singh, Partner, United Machine Tools Corporation,

Kalsi Nagar, Dholewal, Ludhiana

…Applicant
Versus

Ganesh Foundry, village Nandpur, Tehsil and Distt. Ludhiana

through its partner sh.

Respondent

In Re:-Complaint u/s 138 of N.I.Act pending in the court of

sh. Kawaljit Singh, JMIC, Ludhiana for 21-5-2008.

Application U/S 438 of Cr.P.C. for the grant

of Anticipatory Bail

Note: This is the

first bail application.

Sir,
The applicant respectfully submits as under:-

1. That respondent has filed a compliant u/s 138 N.I.Act

against the applicant in which the court of sh. Kawaljit
Singh, JMIC, Ludhiana has issued Arrest Warrants of the
applicant for 21-05-2008 and as such the applicant
apprehends his arrest in this compliant when he will appear
before the said court.

2. That admittedly no summons or bailable warrants were

ever served upon the applicant but in spite of that the

19
Ld. Magistrate directly issued Arrest Warrants of the
applicant. Even otherwise the applicant has committed no
offence and he has been falsely implicated in the said
complaint.

3. That the offence u/s 138 of N.I. Act is even otherwise

bailable one.

4. That the petitioner undertakes that he will abide all

the terms and conditions imposed by this Hon’ble court while
releasing him on bail.

It is, therefore, respectfully prayed that the arrest

of the petitioner/accused may kindly be stayed during the
pendency of the present bail application and direction may
be given to the Trial Court/arresting officer to release the
petitioner on bail in the event of his arrest in the above
noted complaint.

Applicant

Through Counsel

Place:- Ludhiana Ravinder Singh Rana

Date:- 28/04/2008 Advocate

20
21
IN THE COURT OF HON'BLE SESSIONS JUDGE;
LUDHIANA

United Machine Tools Vs Ganesh Foundry

AFFIDAVIT

I, Gurpreet Singh aged 32 years partner United

Machines Tools Corporation, Kalsi Nagar,
Dholewal, Ludhiana, do hereby solemnly
affirm and declare as under:-

1. That this is first bail application of the

deponent. No such bail application is either

pending or has been decided by any court of

competent jurisdiction.

Deponent
Verification:-
Verified that above contents of this are true
and correct to the best of my knowledge and belief
and nothing has been concealed therein.

Place: Ludhiana.
Date:28/04/2008 Deponent

22
In the court of Sessions Judge, Ludhiana.

State Versus Tariloki Chobey

s/o Surinder Chobey,
r/o H.No.458/4/486/10-A,
St. No.4, New Ram Nagar,
Makkar Colony, giaspura,
Ludhiana

FIR. No. 36/20-4-2008,

U/s. 420/467/468/471/120-B IPC,
P.S. Shimlapuri,
Ludhiana.

Sir,
The Applicant respectfully submits as under:-

1. That the Applicant is peace preferring and law abiding

citizen of India and is never indulged in any criminal
activity.

2. That the applicant is innocent and is being falsely

implicated in some false and frivolous case.

3. That the at the instance of one Harish Kumar S/o

Sidhnath Yadav, R/o H.No. 2349, New Kuldeep Nagar, Jodhewal
Basti, Ludhiana, the police of P.S. Focal Point is bent upon
to arrest the applicant in some false and frivolous case.
4. That the complainant Harish Kumar is running a dental
clinic at which oncee the applicant had approached for some
medicine purpose but the prescribed medicine did not prove
efficacious for the applicant, and the applicant went to
him with this grouse, on this the said Harish Kumar turned
sour and moved application to SSP, against the applicant
with an intent to implicate him in cognizable offence.
5. That on the false and frivolous application moved by
the said Harish Kumar the police of P.S. Focal Point also
raided the house of the petitioner to arrest him but luckily
the applicant saved due to non-presence of him at home.

6. That the petitioner has every apprehension the police

of P. S. Focal Point may apprehend him on false and
frivolous grounds.
23
7. That the petitioner undertakes to be restrained and is
ready to abide by all the terms and conditions as may be
imposed by this Hon’ble court while granting him bail.

8. That the petitioner undertakes to make himself

available for interrogation by the police officer as and
when the same is required.

9. That the applicant undertakes not to directly or

indirectly make any inducement, threats, or promise to any
person acquainted with the facts of the case so as to
dissuade them from disclosing such facts of the court or to
any police officer.

10. That the petitioners undertake not to leave India

without previous permission of the court.

It is, therefore, respectfully prayed that the

petitioner may please be granted anticipatory bail and in
the meantime the directions may please be passed on to the
concerned police official to release the petitioner on bail
in case of his arrest, in the interest of justice.

Applicant

Through Counsel

Place:- Ludhiana A.K.Giri,

Date:-13/07/2007 Advocate

24
IN THE COURT OF SESSIONS JUDGE, LUDHIANA

State Vs. Sugriv Mishra & Ors.

AFFIDAVIT

I, Sugriv Mishra S/o Narayan Mishra, R/o 440, Jamalpur,

Focal Point, Ldh, do hereby solemnly affirm and declare as

under:-

1. That the accompanying application for the grant of

anticipatory bail has been drafted by the counsel on the

instructions of the Deponent/applicant and the same may be

read as part and parcel of this affidavit.

3. That the deponent is competent to swear this affidavit.

Deponent
Verification:-
Verified that above contents of this are true and
correct to the best of my knowledge and belief and nothing
has been concealed therein.
Place: Ludhiana.
Date:13/07/2007

Deponent

25
26
In the court of Sessions Judge, Ludhiana

State V/s Sugriv Mishra & Ors.

S/o Narayan Mishra,
R/o 440, Jamalpur,
Focal Point, Ldh.

FIR No. 205/11-07-2007

U/s 457/380/381/411 IPC,
P/S Focal Point
Ludhiana

Application u/s 438 of Cr.P.C. for the grant

of anticipatory bail.

Sir,
The Applicant respectfully submits as under:-

1. That the Applicant is peace-loving and law abiding

citizen of India.

2. That Applicant is innocent and has been falsely

implicated in the above noted case on statement of accused
which in no case can be trustworthy.

3. That nothing is to be recovered from the petitioner as

his name has been involved just to harass him maliciously.

4. That there is no direct or ocular evidence against the

applicant and his implication is based on conjecture and
surmises.

5. That on the statement of the accused of the police of

P.S. Focal Point is raiding the house of the petitioner to
arrest him.

6. That the petitioner has every apprehension the police

of P. S. Focal Point may apprehend him on false and
frivolous grounds for which he is no case liable.

7. That the petitioner undertakes to be restrained and is

ready to abide by all the terms and conditions as may be
imposed by this Hon’ble court while granting him bail.

27
8. That the petitioner undertakes to make himself
available for interrogation by the police officer as and
when the same is required.

9. That the applicant undertakes not to directly or

indirectly make any inducement, threats, or promise to any
person acquainted with the facts of the case so as to
dissuade them from disclosing such facts of the court or to
any police officer.

10. That the petitioners undertake not to leave India

without previous permission of the court.

It is, therefore, respectfully prayed that the

petitioner may please be granted anticipatory bail and in
the meantime the directions may please be passed on to the
concerned police official to release the petitioner on bail
in case of his arrest, in the interest of justice.

Applicant

Through Counsel

Place:- Ludhiana A.K.Giri,

Date:-13/07/2007 Advocate

28
29
In the court of Sessions Judge, Amritsar.

State Vs. Gulsan Kumar aged 38 yrs.

S/o Sant Singh R/o 1804,
B-14, Islam Ganj,
Ludhiana

FIR No. not known,

U/s. Not known but non-
bailable and cognizable,
P.S.
Amritsar

Note:- This is the first bail Application .

Application u/s 438 of Cr.P.C. for grant of

Anticipatory bail.

Respectfully showeth;

1. That the petitioner is peace-loving and law abiding

citizen of India.

2. That the petitioner was married to Kiran Bala D/o Sh.

Tara Chand R/o 5285/19, Gali No. 28, Meharpura, Nawakot,
Amritsar on 12/05/1998 and two children were born out of
this wedlock namely Khusboo(daughter) aged 7 years and
Hritik aged 5 years.

3. That soon after the marriage the behaviour of the said

Kiran Bala towards the petitioner and his family members was
not cordial and good rather it was cruel and un-adjustable
because she started picking up quarrels on petty matters in
order to put pressure upon the petitioner to live separately
from his parents to which the petitioner did not agree at
which she became annoyed. She also used to beat the
petitioner on trivial matters. So many times she has slapped
the petitioner/applicant. Even her parents used to interfere
in her matrimonial affairs and also used to instigate Kiran
Bala, wife of the petitioner to pressurize petitioner to

30
have a separate residence after getting share from the
property of his father.

4. That after sometime of marriage Smt. Kiran Bala started

to do private job without the consent of the applicant
Gulsan Kumar besides the fact that the applicant/husband
namely Gulsan Kumar is already in service under Govt. of
Punjab which is sufficient for their maintenance. But the
said Kiran Bala neither took notice of old aged parents to
service and lookafter them nor she cared for the little
children of her.

5. That thereafter the petitioner called the parents of

Kiran Bala namely Tarachans (father), Smt. Swarna (mother of
Kiran Bala) to his residence and made his best efforts to
sort out the matter. The applicant and his family member
also tried to understand them/parents of Kiran Bala that
petitioner cannot live separate from his parents.

6. The parents of the said Kiran Bala and she herself are
compelling the applicant to live as Ghar Jamai at Amritsar,
but it is impossible for the applicant to do so. The
petitioner expressed his inability to do so as he was the
sole recourse of his old-aged (father aged 80, mother 75
years) parents to look after them.

7. That the said Kiran Bala never proved a devoted wife

and she never obeyed her husband and his family members. She
off and on used to go anywhere as she liked. She left the
house of the petitioner so many times without rhyme or
reason and consent of him and in all this her parents were
supporter of her; that is why she became insolent.

8. That now the said Smt. Kiran Bala in collusion and

connivance with her parents are bent upon to compel the
applicant to obey them but the applicant always followed the
norms and circumstances of his family and did not pay any
heed to the mis-attempt of the said Smt. Kiran Bala and her
parents as it was impossible for him to always follow them
in every step of life. The said Kiran Bala threats the
petitioner that she will commit suicide by setting fire and

31
will falsely implicate the applicant and his family members
and she left the house of the petitioner giving threats that
she will falsely implicate the petitioner in some non-
bailable cognizable offence.

9. That besides above said facts, the said Kiran Bala and
her parents are bent upon to falsely implicate the
petitioner in some non-bailable cognizable offence, and as
such the applicant is under apprehension of his arrest in
some false and frivolous case.

10. That the applicant is Govt. employee and he has to

remain duty bound but due to intense air created by Kiran
Bala he is under stiff pressure and as such he is
languishing his health also.

11. That petitioner apprehends his arrest at the hands of

the police at the instance of the said Kiran Bala.

12. That the petitioner undertakes to abide by all the

terms and conditions as may be imposed by this Hon’ble court
while granting him bail.

13. That the petitioner undertakes not to directly or

indirectly make any inducement, threats, or promise to any

person acquainted with the facts of the case so as to

dissuade him from disclosing such facts of the court or to

any police officer.

14. That the petitioner undertakes not to leave India

without the prior permission of this Hon'ble court and there
is no likelihood of absconding of the petitioner.

15. That the petitioner undertakes to make himself

available for interrogation by the police officer as and
when the same is required.

It is, therefore, respectfully prayed that the

petitioner may please be granted anticipatory bail and in
the meantime the directions be passed on to the concerned

32
police officials to release the petitioner on bail in case
of his arrest, in the interest of justice.

Petitioner

Through Counsel

Place:- Amritsar
Date:- /07/2007 Advocate

33
In the court of Sessions Judge, Ludhiana.

State Vs. Gulsan Kumar aged 38 yrs.

S/o Sant Singh R/o 1804,
B-14, Islam Ganj,
Ludhiana

FIR No. not known,

U/s. 406/498-A IPC,
P.S. Div. No.2, Ldh.

Note:-1. This is the first bail

Application and no such bail
Application is pending or decided
by any competent court of law.

Application u/s 438 of Cr.P.C. for grant of

Anticipatory bail.

Respectfully showeth;

1. That the petitioner is peace-loving and law abiding

citizen of India.

2. That the petitioner was married to Kiran Bala D/o Sh.

Tara Chand R/o 5285/19, Gali No. 28, Meharpura, Nawakot,
Amritsar on 12/05/1998 and two children were born out of
this wedlock namely Khusboo(daughter) aged 7 years and
Hritik aged 5 years.

3. That soon after the marriage the behaviour of the said

Kiran Bala towards the petitioner and his family members was
not cordial and good rather it was cruel and un-adjustable
because she started picking up quarrels on petty matters in
order to put pressure upon the petitioner to live separately
from his parents to which the petitioner did not agree at
which she became annoyed. She also used to beat the
petitioner on trivial matters. So many times she has slapped
the petitioner/applicant. Even her parents used to interfere
in her matrimonial affairs and also used to instigate Kiran
Bala, wife of the petitioner to pressurize petitioner to

34
have a separate residence after getting share from the
property of his father.

4. That after sometime of marriage Smt. Kiran Bala started

to do private job without the consent of the applicant
Gulsan Kumar besides the fact that the applicant/husband
namely Gulsan Kumar is already in service under Govt. of
Punjab which is sufficient for their maintenance. But the
said Kiran Bala neither took notice of old aged parents to
service and lookafter them nor she cared for the little
children of her.

5. That thereafter the petitioner called the parents of

Kiran Bala namely Tarachans (father), Smt. Swarna (mother of
Kiran Bala) to his residence and made his best efforts to
sort out the matter. The applicant and his family member
also tried to understand them/parents of Kiran Bala that
petitioner cannot live separate from his parents. The
petitioner expressed his inability to do so as he was the
sole recourse of his old-aged parents to look after them.

6. That the said Kiran Bala never proved a devoted wife

and she never obeyed her husband and his family members. She
off and on used to go anywhere as she liked. She left the
house of the petitioner so many times without rhyme or
reason and consent of him and in all this her parents were
supporter of her; that is why she became insolent.

7. That now the said Smt. Kiran Bala in collusion and

connivance with her parents are bent upon to compel the
applicant to obey them but the applicant always followed the
norms and circumstances of his family and did not pay any
heed to the mis-attempt of the said Smt. Kiran Bala and her
parents as it was impossible for him to always follow them
in every step of life. The said Kiran Bala threats the
petitioner that she will commit suicide by setting fire and
will falsely implicate the applicant and his family members.

8. That besides above said facts, the said Kiran Bala and
her parents are bent upon to falsely implicate the

35
petitioner in some non-bailable cognizable offence, and as
such the applicant is under apprehension of his arrest in
some false and frivolous case.

9. That not only this, the parents of the said Kiran Bala
and she herself are compelling the applicant to live as Ghar
Jamai at Amritsar, but it is impossible for the applicant to
do so.

10. That the applicant is Govt. employee and he has to

remain duty bound but due to intense air created by Kiran
Bala he is under stiff pressure and as such he is
languishing his health also.

11. That the petitioner is innocent and is likely to be

implicated falsely.

12. That the petitioner undertakes to abide by all the

terms and conditions as may be imposed by this Hon’ble court
while granting him bail.

13. That the petitioner undertakes not to directly or

indirectly make any inducement, threats, or promise to any
person acquainted with the facts of the case so as to
dissuade him from disclosing such facts of the court or to
any police officer.

14. That the petitioner undertakes not to leave India

without the prior permission of this Hon'ble court and there

is no likelihood of absconding of the petitioner.

. That the petitioner undertakes to make himself

available for interrogation by the police officer as and
when the same is required.

It is, therefore, respectfully prayed that the

petitioner may please be granted anticipatory bail and in
the meantime the directions be passed on to the concerned
police officials to release the petitioner on bail in case
of his arrest, in the interest of justice.
36
 Petitioner

Through Counsel

P.K.Wadhera & D.P. Bali

Place:- Ludhiana
Date:-06/11/2007 Advocates

37
In the court of Sessions Judge, Amritsar

State Vs. Gulsan Kumar

AFFIDAVIT

I, Gulsan Kumar aged 38 yrs. S/o Sant Singh R/o 1804, P-14,
Islam Ganj, Ludhiana do hereby solemnly affirm and declare
as under:-

1. That the accompanying application for the grant of

anticipatory bail has been drafted by the counsel on the

instructions of the Deponent/applicant and the same may be

read as part and parcel of this affidavit.

3. That the deponent is competent to swear this affidavit.

Deponent

Verification:-
Verified that above contents of this are true and
correct to the best of my knowledge and belief and nothing
has been concealed therein.

Place: Ludhiana.
Date:11/07/2007 Deponent

38
39
In The Court Of Hon'ble Sessions Judge, Ludhiana

State Versus Mohinder Chaudhary

S/o Sh. Ramphal Chaudhary
R/o Jhuggi,
Backside Dushara Grounds,
Jamalpur Colony, Ludhiana

FIR. No. Not Known,

U/s. Not Known,
P.S. Focal Point,
Ludhiana.

Application u/s 438 of Cr.P.C. for the grant of

anticipatory bail.

Sir,
The Applicant respectfully submits as under:-

1. That the Applicant is senior citizen having aged about

62 years and as such is peace preferring and law abiding
citizen of India and is never indulged in any criminal
activity.

2. That the applicant is labour in profession hardly meets

his both ends.

3. That at the instance of some unknown person the police

of P.S. Focal Point is hunting for the Applicant to arrest
him.

4. That yesterday the police of P.S. Focal Point also

raided the house of the applicant to arrest him but the
applicant saved due to his absence at his home, but while
leaving the spot the police informed the other family
members to arrest the applicant in some non-bailable and
cognizable offence.

5. That applicant, therefore, apprehends his arrest in

some false and frivolous non-bailable and cognizable offence
without rhyme or reason.
40
6. That the Applicant is ready to cooperate with the
investigation authority.

7. That the applicant further undertakes that he will not

tamper with the prosecution evidence.

8. That the applicant undertakes that he will abide all

the terms and conditions to be imposed by this hon’ble court
while granting him bail.

9. That the Applicant/Accused undertakes that he will not

leave India without the prior permission of this Hon'ble
court.

It is, therefore, respectfully prayed that the

necessary direction may please be given to the concerned
police officer to stay his arrest and in the event of
arrest, the Applicant be released on the basis of
anticipatory bail in the interest of justice.

Applicant

Through Counsel
Place:- Ludhiana
Date:- 11/7/2007 Subhash Thakur
Advocate

41
The Court Of Hon'ble Sessions Judge, Ludhiana

State Versus Mohinder Chaudhary

S/o Sh. Ramphal Chaudhary
R/o Jhuggi,
Backside Dushara Grounds,
Jamalpur Colony, Ludhiana

FIR. No. Not Known,

U/s. Not Known,
P.S. Focal Point,
Ludhiana.

AFFIDAVIT

I, Mohinder Chaudhary S/o Sh. Ramphal Chaudhary R/o Jhuggi,

Backside Dushara Grounds, Jamalpur Colony, Ludhiana do
hereby solemnly affirm and declare as under:-

1. That the accompanying application for the grant of

anticipatory bail has been drafted by the counsel on the
instructions of the Deponent/ applicant and the same can be
read as part and parcel of this affidavit.

3. That the deponent is competent to swear this affidavit.

Deponent
Verification:-
Verified that above contents of this are true and
correct to the best of my knowledge and belief and nothing
has been concealed therein.

Place: Ludhiana.
Date:11/07/2007 Deponent

42
 In The Court Of Hon'ble Sessions Judge, Ludhiana

HSBC Versus Kamal Partap Singh

Chhattarpal Singh
R/o H.No. 50,
New Punjab Mata Nagar,
Near Jawaddi Kalan,
Ludhiana.
In Re:- Complaint u/s 138 of N.I.Act.

Application U/S 438 of Cr.P.C. for the grant of

Anticipatory Bail

Sir,
The applicant respectfully submits as under:-

1. That the applicant is law abiding and peace

loving citizen of India and never involved himself
in any unlawful activities.

2. That one criminal complaint u/s 138 of

Negotiable Instruments Act, is pending in the court
of Sh. Shatin Goel, JMIC, Ludhiana and is now fixed
for 02/06/2007, and non-bailable warrants has been
issued against the petitioner. It all has been done
quite hastily and unreasonably since the Ld. Court
had issued summons on first date and alleged report
of refusal, the Ld. Court issued bailable warrants.

3. That it can be well understood that there can

never be practically any refusal in case of
bailable warrants and the reports of refusal on the
summons as also on the bailable warrants are
wrongfully managed by the complainant.

43
4. That the offence u/s 138 of N.I. Act is even
otherwise bailable one.

5. That the petitioner undertakes that he will

abide all the terms and conditions imposed by this
Hon’ble court while releasing him on bail.

It is, therefore, respectfully prayed that the

arrest of the petitioner/accused may kindly be
stayed during the pendency of the present bail
application and direction may be given to the Trial
Court to release the petitioner on bail in the
event of his surrender in the court in the interest
of justice.

Applicant

Through Counsel

Place:- Ludhiana Subhash Thakur

Date:- 02/05/2007 Advocate

44
 In the court of Hon'ble Sessions Judge,
Ludhiana

State Vs. Jagroop Singh aged 27 years

S/o Sh. Ajaib Singh r/o
Damdama Sthan, Baba Sahib
Singh Bedi, Village
Mansuran, Pakhowal Road,
Ludhiana

FIR. No. Not Known,

U/s. Not Known,
P.S. Basti Jodhewal,
Ludhiana.

Application u/s 438 of Cr.P.C. for the grant

of anticipatory bail.

Respectfully showeth;

1. That the applicant is peace loving, law abiding

and god-fearing citizen of India. He is Ragi by
profession and off and on remains out of India.

2. That due to frequent absence of the applicant out

of Ludhiana, his wife Simranjit Kaur is completely in
control of her father Kishan Singh and one Jatinder
Kanda S/o of not known. Soon after the marriage of the
applicant, Simranjit Kaur and her father Kishan Singh
borrowed heavy amount from the applicant to purchase a
house on the undertaking that the house will get
registered in the joint names of the applicant and said
Kishan Singh. For this purpose a loan was also got
sanctioned from the bank. Later on Kishan Singh wanted
to encroach the entire house and leave the liability of
the bank loan on the shoulders of the applicant. The
dispute was settled in Panchayat. Due to interference
in married life of the applicant from Kishan Singh and
Jatinder Kanda, the behaviour of the Simranjit Kaur
towards the applicant became from bad to worse.
Simranjit Kaur insisted that the applicant should

45
handover the earnings to her and her father otherwise
she will get him falsely implicated in false criminal
case of the Dowry etc. It is pertinent to mention that
the applicant never demanded of dowry nor he is
interested in dowry because the applicant I s a god-
fearing man.
3. That on 06-11-2006 Simranjit Kaur called her
father Kishan Singh and Jatinder Kanda to her
matrimonial home while the applicant was sleeping in
bedroom, he was attacked by all of them and was injured
in the said attack of the attackers as well as the
Harmoniam of the petitioner and forcibly took away the
passport bearing No A-8342987. The complaint was lodged
to the police of P.S. Basti Jodhewal, Ludhiana but the
police did not take any action against the culprits and
rather they have started threatening to the applicant
to implicate him in some false cognizable and non-
bailable offence.
4. That at the behest of the Simranjit Kaur and her
father Kishan Singh and Jatinder Kanda the police of
the of P.S. Basti Jodhewal is out to arrest the
applicant in a false criminal case.

5. That the applicant undertakes to abide by all the

terms and conditions as may be imposed by this Hon’ble
court while granting them on bail.

6. That the petitioner undertakes to make himself

available for interrogation by the police officer as
and when the same is required.

7. That the applicant undertakes not to directly or

indirectly make any inducement, threats, or promise to
any person acquainted with the facts of the case so as
to dissuade him from disclosing such facts of the court
or to any police officer.

46
 In the court of Hon'ble Sessions Judge,
Ludhiana

State Vs. Sarabjit Singh aged 22 years

S/o Sh. Harbhajan Singh r/o
H.No.434/33, Saroop Nagar,
Salem Tabri, Ludhiana

FIR. No. Not Known,

U/s. Not Known,
P.S. Salem Tabri,
Ludhiana.

Application u/s 438 of Cr.P.C. for the grant

of anticipatory bail.

Respectfully showeth;

1. That the applicant is peace loving, law abiding

citizen of India.

2. That the marriage of the applicant was solenised

with the complainant Amarjit Kaur @ Asha D/o Jasbir
Singh R/o H. No. 771, Old Sabzi Mandi, Back Hotel
Dophine, Jallandhar, on December 2005 as per Sikh Rites
and customs by way of Anand Karaj.

3. That after the marriage the wife/complainant

started pressurized and compelled the applicant to live
separate from his parents and started to disregarding
the parents of the applicant.

4. That the dissensions raised between the applicant

and complainant did not subdued and on 10-02-2007 she
left the house of the applicant and went to the house
of parent, Jalandhar, wherefrom she is now advancing
threats to implicate the applicant in some false and
frivolous case on the pretext of dowry.
5. That applicant, therefore, apprehends his arrest
in some non-bailable and cognizable offence without any
rime and reason at the instance of the complainant.
47
6. That yesterday the police of Salem Tabri also
raided the house of the applicant to arrest him at late
night but the applicant saved due his absence at his
home.
7. That the applicant undertakes to abide by all the
terms and conditions as may be imposed by this Hon’ble
court while granting them on bail.
8. That the petitioner undertakes to make himself
available for interrogation by the police officer as
and when the same is required.
9. That the applicant undertakes not to directly or
indirectly make any inducement, threats, or promise to
any person acquainted with the facts of the case so as
to dissuade him from disclosing such facts of the court
or to any police officer.
10. That the petitioner undertakes that he shall not
leave India without previous permission of the
court.
It is, therefore, respectfully prayed that the
petitioner may please be granted anticipatory bail and
in the meantime the directions be passed on to the
concerned police official to release the petitioner on
bail in case of his arrest, in the interest of justice.

Applicant

Through Counsel

Place:- Ludhiana
Date:-14/02/2007 Advocate

48
49
8. That the petitioner undertakes that he shall not

leave India without previous permission of the court.

It is, therefore, respectfully prayed that the

petitioner may please be granted anticipatory bail and

in the meantime the directions be passed on to the

concerned police official to release the petitioner on

bail in case of his arrest, in the interest of justice.

Applicant

Through Counsel

Place:- Ludhiana
Date:-14/02/2007 Advocate

50
 IN THE COURT OF HON'BLE SESSIONS JUDGE;
LUDHIANA

State Versus Jagroop Singh

AFFIDAVIT

I, Jagroop Singh aged 27 years S/o Sh. Ajaib Singh

r/o Damdama Sthan, Baba Sahib Singh Bedi,
Village Mansuran, Pakhowal Road, Ludhiana,
do hereby solemnly affirm and declare as
under:-

1. That this is first bail application.

2. That the accompanying application for the grant

of anticipatory bail has been drafted by the
counsel on the instructions of the Deponent/
applicant and the same can be read as part and
parcel of this affidavit.

3. That the deponent is competent to swear this

affidavit.

Deponent
Verification:-
Verified that above contents of this are true
and correct to the best of my knowledge and belief
and nothing has been concealed therein.

Place: Ludhiana.
Date:14/02/2007 Deponent

51
In the court of Hon'ble Sessions Judge, Ludhiana

State Vs. Mewa Lal and Ors.

AFFIDAVIT
I, Mewa Lal aged about years S/o Sh. Bhag R/o
St. No. 3, Shanti Nagar, Giaspura, Ludhiana, do
hereby solemnly affirm and declare as under:-

1. That this is first bail application.

2. That the accompanying application for the grant

of anticipatory bail has been drafted on the

instructions of the Deponent/applicant and the same

can be read as part and parcel of this affidavit.

3. That the deponent is competent to swear this

affidavit.

Deponent
Verification:-
Verified that above contents of this are true
and correct to the best of my knowledge and belief
and nothing has been concealed therein.
Place: Ludhiana.
Date: / /2007 Deponent

52
 In the court of Hon'ble Sessions Judge,
Ludhiana

State Vs. Anup Singh S/o Sh. Pal

Singh R/o Dua Karyana
Store, St. No. 7, Field
Ganj, Ludhiana

FIR. No. Now Known,

U/s. Not Known,
P.S. Division No. 2,
Ludhiana.

Application u/s 438 of Cr.P.C. for the grant

of anticipatory bail.

Respectfully showeth;

1. That the applicant is law abiding and peace loving

citizen of India and is innocent and has been falsely
implicated in the above titled case.

2. That the applicant had taken the Tractor-Trolley

on a monthly hire of Rs.5,000/-from the complaint
Kirpal Singh S/o S. Harkirat Singh R/o H.No. 230/4,
Gali No.3, Muradpura, Gill Road, Ludhiana, and has been
paying the hire to the complainant on regular basis but
now the intention of the complainant has turned
dishonest and he is leveling false allegation on the
applicant that the applicant is not paying hire/monthly
rent to the complainant

3. That in the light of above said circumstances, on

the basis of false allegation and at the instance of
the complainant the police of the P/s Division No. 2 is
inclined to arrest the applicant in some false
cognizable offence case. The applicant, therefore,
apprehends his arrest in some non-bailable and
cognizable offence without any rime and reason.

53
4. That the applicant hails of respectable family and
is deep rooted in the society and in the event of his
arrest, his image may be lowered in the eyes of his
society.

5. That the applicant undertakes to abide by all the

terms and conditions as may be imposed by this Hon’ble
court while granting them on bail.

6. That the petitioner undertakes to make himself

available for interrogation by the police officer as
and when the same is required.
7. That the applicant undertakes not to directly or
indirectly make any inducement, threats, or promise to
any person acquainted with the facts of the case so as
to dissuade him from disclosing such facts of the court
or to any police officer.
8. That the petitioner undertakes that he shall not
leave India without previous permission of the court.

It is, therefore, respectfully prayed that the

petitioner may please be granted anticipatory bail and
in the meantime the directions be passed on to the
concerned police official to release the petitioner on
bail in case of his arrest, in the interest of justice.

Applicant

Through Counsel

Place:- Ludhiana
Date:-14/02/2007 Advocate

54
 In the court of Hon'ble Sessions Judge,
Ludhiana

State Vs. Anup Singh S/o Sh. Pal

Singh R/o Dua Karyana
Store, St. No. 7, Field
Ganj, Ludhiana

FIR. No. Now Known,

U/s. Not Known,
P.S. Division No. 2,
Ludhiana.

Application u/s 438 of Cr.P.C. for the grant

of anticipatory bail.

Respectfully showeth;

1. That the applicant is law abiding and peace loving

citizen of India and is innocent and has been falsely
implicated in the above titled case.

2. That the applicant had taken the Tractor-Trolley

on a monthly hire of Rs.5,000/-from the complaint
Kirpal Singh S/o S. Harkirat Singh R/o H.No. 230/4,
Gali No.3, Muradpura, Gill Road, Ludhiana, and has been
paying the hire to the complainant on regular basis but
now the intention of the complainant has turned
dishonest and he is leveling false allegation on the
applicant that the applicant is not paying hire/monthly
rent to the complainant

3. That in the light of above said circumstances, on

the basis of false allegation and at the instance of
the complainant the police of the P/s Division No. 2 is
inclined to arrest the applicant in some false
cognizable offence case. The applicant, therefore,
apprehends his arrest in some non-bailable and
cognizable offence without any rime and reason.

55
4. That the applicant hails of respectable family and
is deep rooted in the society and in the event of his
arrest, his image may be lowered in the eyes of his
society.

5. That the applicant undertakes to abide by all the

terms and conditions as may be imposed by this Hon’ble
court while granting them on bail.

6. That the petitioner undertakes to make himself

available for interrogation by the police officer as
and when the same is required.

7. That the applicant undertakes not to directly or

indirectly make any inducement, threats, or promise to
any person acquainted with the facts of the case so as
to dissuade him from disclosing such facts of the court
or to any police officer.

8. That the petitioner undertakes that he shall not

leave India without previous permission of the court.
It is, therefore, respectfully prayed that the
petitioner may please be granted anticipatory bail and
in the meantime the directions be passed on to the
concerned police official to release the petitioner on
bail in case of his arrest, in the interest of justice.

Applicant
Through Counsel
Place:- Ludhiana A.K.Giri,
Date:-01/02/2007 Advocate

56
In the court of Hon'ble Sessions Judge, Ludhiana

State Vs. 1.Ashwani Kumar aged 45 yrs.

2.Ashok Kumar aged about 41 Yrs.
3.Pawan Kumar aged about 27 Yrs
All sons of Sh. Baldev Raj
Verma, Residents of H.No. 650,
Labour Colony, Double Storey,
Pahwa Hospital Road, Near Gill
Chowk, Ludhiana.

FIR. No. Now Known,

U/s. Not Known,
P.S. Shimlapuri,
Ludhiana.
Application u/s 438 of Cr.P.C. for the grant
of anticipatory bail.

Respectfully showeth;

1. That the petitioners are law abiding and peace

loving citizens of India and are innocent and have been
falsely implicated in the above titled case. They are
not previous offenders.

2. That complainant Baldev Raj Verma is the father of

the petitioner and the petitioners and the complainant
have some land dispute and due to this reasons the
petitioners have to file suit for permanent injunction
which is pending in the court of Sh.
Ludhiana, and is fixed for .

3. That as a counterblast of the above said suit, the

complainant is threatening the petitioners to
incriminate them in some false, frivolous and non-
cognizable offence.

4. That at the instance of the complainant the police

of P.S. Shimlapuri is raiding the house of the
petitioners to arrest them in some cognizable offence.
57
5. That the petitioners have every apprehension to be
apprehended on false and frivolous grounds.

6. That the petitioners are deep-rooted persons in

the society and in the event of his arrest their image
in the locality my be lowered in the eyes of society.

7. That the petitioners undertake to be restrained

and are ready to abide by all the terms and conditions
as may be imposed by this Hon’ble court while granting
them on bail.

8. That the petitioners undertake not to leave India

without the prior permission of this Hon'ble court and
there is no likelihood of absconding of the
petitioners.

9. That the petitioners undertake to join the

investigation as and when the same is required.

It is, therefore, respectfully prayed that the

petitioners may please be granted anticipatory bail and
in the meantime the directions be passed on to the
concerned police to release the petitioner on bail in
case of their arrest, in the interest of justice.

Petitioners

Through Counsel
Place:- Ludhiana Subhash Thakur
Date:17/01/2007 Advocate

In the court of Hon'ble Sessions Judge, Ludhiana

State Vs. Ashwani Kumar and ors.

58
 AFFIDAVIT
I, Ashwani Kumar aged 45 yrs son of Sh. Baldev Raj
Verma, Residents of H.No. 650, Labour Colony, Double
Storey, Pahwa Hospital Road, Near Gill Chowk, Ludhiana,
do hereby solemnly affirm and declare as under:-

1. That the present application for grant of

anticipatory bail has been drafted on the
instructions of the Deponent/applicant and the same
can be read as part and parcel of this affidavit.

2. This is first bail application.

3. That the deponent is competent to swear this

affidavit.

Deponent
Verification:-
Verified that above contents of this are true and
correct to the best of my knowledge and belief and
nothing has been concealed therein.

Place: Ludhiana.
Date:17/01/2007
Deponent

59
60
In the court of Sessions Judge, Ludhiana

State Vs. Bagga

S/o Jagat Ram
VPO. Karabara,
Tehsil and Distt.
Ludhiana.

FIR No. 247/7-12-2006,

U/s. 365 IPC
P.S. Sadar,
Ludhiana.

Note:-

1. That this is the first bail application and no

such or similar bail application either is pending
or has been decided by any competent court of law.

2. That the bail application of co-accused

Paramjit Singh S/o Jagat Ram is pending in the
court of Sh. H.P.S. Mahal, ASJ, Ludhiana, for 18-
01-2007.

Application u/s 438 of Cr.P.C. for grant of

Anticipatory bail.

Respectfully showeth;
1. That the petitioner is law abiding and peace
loving citizen of India and is innocent and has
been falsely implicated in the above titled case.

2. That the applicant has not committed any

offence as alleged in the FIR. Infact the present

61
FIR has been lost against the applicant to extort
money from the applicant. The complaint to the
police was made more than four months after alleged
date of occurrence, which shows that the story
contained in FIR is concocted to extort money from
the applicant.

3. That the police of P.S. Sadar is raiding the

house of the petitioner to arrest him.

4. That the petitioner undertakes to abide by all

the terms and conditions as may be imposed by this
Hon’ble court while granting her on bail.

5. That the petitioner undertakes not to leave

India without the prior permission of this Hon'ble
court and there is no likelihood of absconding of
the petitioner.

6. That the petitioner undertakes to join the

investigation as and when the same is required.

It is, therefore, respectfully prayed that the

petitioner may please be granted anticipatory bail
and in the meantime the directions be passed on to
the concerned police to release the petitioner on
bail in case of his arrest, in the interest of
justice.

Petitioner

62
 Through Counsel

Place:- Ludhiana
Date:13/12/2006 Advocate

63
In the court of Sessions Judge, Ludhiana

State Vs. Khushpal Singh aged 32 yrs.

S/o S. Raghbir Singh
R/o village Harnampura,
P.O.Natt,
Distt. Ludhiana.

FIR No. complaint filed by Charanjit Singh s/o S.

Ujjagar Singh
U/s. not known,
P.S. Dakha,
Distt. Ludhiana.

AFFIDAVIT
I, Khushpal Singh aged 32 yrs. S/o S. Raghbir Singh
R/o village Harnampura, P.O.Natt, Distt. Ludhiana,
do hereby Solemnly affirm and declare as under:-

1. That this is second bail application and first

bail application was decided by the court of Sh.
Sanjeev Berry, ASJ, Ludhiana on 21/10/2005.

2. That the bail application has been drafted on

the instructions of the petitioner and the same may
be read as part and parcel of this affidavit.

Deponent
Verification:-
Verified that above noted contents are true and
correct to the best of my knowledge and belief and
nothing has been concealed therein.
Place: Ludhiana,
Date:11/11/2006
Deponent

64
In the court of Sessions Judge, Ludhiana

State Vs. Khushpal Singh aged 32 yrs.

S/o S. Raghbir Singh
R/o village Harnampura,
P.O.Natt,
Distt. Ludhiana.

FIR No. complaint filed by Charanjit Singh s/o S.

Ujjagar Singh
U/s. not known,
P.S. Dakha,
Distt. Ludhiana.

Note:- That this is second

bail application and first
bail application was decided
by the court of Sh. Sanjeev
Berry, ASJ, Ludhiana on 21/10/2005

Application u/s 438 of Cr.P.C. for grant of

Anticipatory bail.

Respectfully showeth;
1. That the petitioner is law abiding and peace
loving citizens of India.

2. That one Charajit Singh s/o Ujjalgar Singh r/o

village Gujjarwal,Distt. Ludhiana, who is running a
Dera in the above said village and having good

65
relation with police officials, has moved false
complaint against the petitioner.

3. That earlier the complainant had also filed

several applications against the petitioner by
himself or through his followers at P.S. Dehlon,
P.S. Hambra and P.S. Salem Tabri, Ludhiana just to
harass the petitioner. The petitioner sent
telegrams to the higher authorities on 25/10//2005,
27/10/2005, 4/12/2005 and on 8/11/2006 for
intervening the matter.

4. That the petitioner earlier got the

anticipatory bail from the court of Sh. Sanjeev
Berry, ASJ, Ludhiana vide order dated 21/10/2005.
Now the complainant has moved a false application
to the Police of P.S. Dakha and at the instance of
the complainant, the police of P.S. Dakha
continuously raiding the house of the petitioner to
arrest him in a non-bailable and cognizable offence
and the same raid was conducted on yesterday but
the applicant was not there at home and therefore,
he could not be arrested. The applicant apprehends
arrest at the hands of the police of P.S. Dakha.

5. That the petitioner is innocent and is likely

to be implicated falsely.

6. That the petitioner undertakes to abide by all

the terms and conditions as may be imposed by this
Hon’ble court while granting him on bail.
7. That the petitioner undertakes not to leave
India without the prior permission of this Hon'ble

66
court and there is no likelihood of absconding of
the petitioner.
8. That the petitioner undertakes to join the
investigation as and when the same is required.

It is, therefore, respectfully prayed that the

petitioner may please be granted anticipatory bail
and in the meantime the directions be passed on to
the concerned police to release the petitioner on
bail in case of his arrest, in the interest of
justice.

Petitioner

Through Counsel

Place:- Ludhiana G.S. Arora.

Date:11/11/2006 Advocate

67
In the court of Sessions Judge, Ludhiana

State Vs. Neelam Rani

W/o Late Jai Narayan
R/o New Karamsar Colony,
St. No.2, Tibba Raod,
Ludhiana.

FIR No. 280/7-11-2006,

U/s. 411/379/420/467/468/471/120-B IPC,
P.S. Basti Jodhewal,
Distt. Ludhiana.

AFFIDAVIT

I, Neelam Rani W/o Late Jai Narayan R/o New

Karamsar Colony, St. No.2, Tibba Road, Ludhiana, do
hereby Solemnly affirm and declare as under:-

1. That this is first bail application and no such

or similar bail application either is pending or
has been decided by any competent court of law.

2. That the bail application has been drafted on

the instructions of the petitioner and the same may
be read as part and parcel of this affidavit.

Deponent
Verification:-

68
Verified that above noted contents are true and
correct to the best of my knowledge and belief and
nothing has been concealed therein.
Place: Ludhiana,
Date:10/11/2006
Deponent

69
In the court of Sessions Judge, Ludhiana

State Vs. Mandip Kaur @ Bagga

R/o village Sikanderpur,

Tehsil Samrala,
Distt. Ludhiana.

FIR No. 78/7-11-2006,

U/s. 307/323/341/498-A/34 IPC,
P.S. Koomkalan,
Distt. Ludhiana.

AFFIDAVIT

I, Mandip Kaur @ Bagga w/o R/o village

Sikanderpura, Tehsil Samrala, Distt. Ludhiana do
hereby Solemnly affirm and declare as under:-

1. That this is first bail application and no such

or similar bail application either is pending or
has been decided by any competent court of law.

2. That the bail application has been drafted on

the instructions of the petitioner and the same may
be read as part and parcel of this affidavit.

Deponent

70
Verification:-
Verified that above noted contents are true and
correct to the best of my knowledge and belief and
nothing has been concealed therein.
Place: Ludhiana,
Date:10/11/2006
Deponent

71
In the court of Sessions Judge, Ludhiana

State Vs. Arvind Kumar

S/o Sh. Shivjee
Parsad, R/o House No. 6825,
Street No.01, Near Masjid,
Muslim Colony, Ludhiana.

FIR No. Not known,

U/s. Not known ,
P.S. Focal Point,
Ludhiana.

Application u/s 438 of Cr.P.C. for grant of

Anticipatory bail.

Respectfully showeth;

1. That the applicant is law abiding and peace

loving citizens of India.

2. That the applicant had moved an application to

the HDFC Bank Ltd. Ludhiana and the bank had
directed to the applicant to furnish required
documents for the grant of loan facility.

3. That according to the bank direction the

applicant the applicant submitted the required
documents for the loan with the bank but the bank
is not satisfied with the documents submitted by
the applicant and the bank has threatened the
applicant to get arrested at the hands of the
police.

72
4. That the instance of the said bank the police
of P.S. Focal Point is raiding the house of the
applicant to arrest him in cognizable offence.
5. That the applicant has every apprehension to be
arrested on false and frivolous grounds.
6. That the petitioner undertakes to abide by all
the terms and conditions as may be imposed by this
Hon’ble court while granting him bail.
7. That the petitioner undertakes not to leave
India without the prior permission of this Hon'ble
court and there is no likelihood of absconding of
the petitioner.
8. That the petitioner undertakes to make himself
available for interrogation by the police officer
as and when the same is required.

It is, therefore, respectfully prayed that the

petitioner may please be granted anticipatory bail
and in the meantime the directions be passed on to
the concerned police to release the petitioner on
bail in case of her arrest, in the interest of
justice.

Applicant
Through counsel

Place:- Ludhiana
Date:-16/12/2006 Advocate

73
74
In the court of Sessions Judge, Ludhiana

State Vs. Amandeep Kaur aged 28

yrs.

FIR No. not known,

U/s. 406/498-A IPC,
P.S. City Khanna,
P.P. Moti Nagar,Ldh.

AFFIDAVIT

I, Amandeep Kaur aged 28 yrs. Wife of Jasvinder

Singh D/o Jagjit Singh R/o Baba Deep Singh Colony,
Amritsar, do hereby Solemnly affirm and declare as
under:-

1. That this is first bail application and no such

or similar bail application either is pending or
has been decided by any competent court of law.

2. That the bail application has been drafted on

the instructions of the petitioner and the same may
be read as part and parcel of this affidavit.

Deponent
Verification:-

75
Verified that above noted contents are true and
correct to the best of my knowledge and belief and
nothing has been concealed therein.

Place: Ludhiana,
Date:01/11/2006
Deponent

76
In the court of Sessions Judge, Ludhiana

State Vs. Amandeep Kaur aged 28 yrs.

Wife of Jasvinder Singh D/o Jagjit Singh R/o Baba
Deep Singh Colony, Amritsar,

FIR No. not known,

U/s. 406/498-A IPC,
P.S. City Khanna,
P.P. Moti Nagar,Ldh.

Note:-1. This is the first bail

Application and no such bail
Application is pending or decided
by any competent court of law.

2. The co-accused has already been

granted bail by the court of
Sh. Sanjeev Berry, ASJ, Ludhiana,
vide order dated 26/10/2006,

Application u/s 438 of Cr.P.C. for grant of

Anticipatory bail.

Respectfully showeth;
1. That the petitioner is law abiding and peace
loving citizens of India.

2. That the younger brother of the petitioner was

married to Rajbir Kaur D/o Swaran Singh on 3/3/2006
at Khanna, Distt. Ludhiana.

3. That the petitioner visited her parental home

only twice after the marriage of her brother was

77
solennised with the said Rajbir Kaur. The first
time was in the month of August on the occasion
Rakshabandhan and the second time was in the month
of October,2006, when the father of the petitioner
met with a road accident and was admitted into
Apollo Hospital, Ludhiana. On both the occasions
the petitioner arrived in the morning and left in
the evening and on both the occasions Rajbir Kaur
was not present.

4. That the petitioner is happily married and is

busy and occupied in the affairs of her own family
and she gets no time or occasion to interfere in
the married life of her brother. Rajbir Kaur is
trying to falsely implicate the petitioner in false
and frivolous dowry case by filing a false
complaint with the police of P.S. City Khanna. The
petitioner is innocent and is likely to be
implicated falsely and she apprehends her arrest at
the hand of police of P.S. City Khanna, Ludhiana.

5. That the petitioner undertakes to abide by all

the terms and conditions as may be imposed by this
Hon’ble court while granting her bail.

6. That the petitioner undertakes not to directly

or indirectly make any inducement, threats, or
promise to any person acquainted with the facts of
the case so as to dissuade her from disclosing such
facts of the court or to any police officer.

7. That the petitioner undertakes not to leave

India without the prior permission of this Hon'ble

78
court and there is no likelihood of absconding of
the petitioner.

8. That the petitioner undertakes to make herself

available for interrogation by the police officer
as and when the same is required.

It is, therefore, respectfully prayed that the

petitioner may please be granted anticipatory bail
and in the meantime the directions be passed on to
the concerned police to release the petitioner on
bail in case of her arrest, in the interest of
justice.

Petitioner

Through Counsel

Place:- Ludhiana
Date:-01/11/2006 Advocate

79
In the court of Sessions Judge, Ludhiana

State Vs. Supinder Kaur aged 26

yrs.

FIR No. not known,

U/s. 406/498-A IPC,
P.S. City Khanna,
P.P. Moti Nagar,Ldh.

AFFIDAVIT

I, Supinder Kaur aged 26 yrs. Wife of Avtar Singh

D/o Jagjit Singh R/o Hindu Mohalla, Kadian, Distt.
Gurdaspur, do hereby Solemnly affirm and declare as
under:-

1. That this is first bail application and no such

or similar bail application either is pending or
has been decided by any competent court of law.

2. That the bail application has been drafted on

the instructions of the petitioner and the same may
be read as part and parcel of this affidavit.

Deponent
Verification:-
Verified that above noted contents are true and
correct to the best of my knowledge and belief and
nothing has been concealed therein.

80
Place: Ludhiana,
Date:01/11/2006
Deponent

81
In the court of Sessions Judge, Ludhiana

State Vs. Supinder Kaur aged 26

yrs. Wife
of Avtar Singh D/o Jagjit Singh R/o Hindu Mohalla,
Kadian, Distt. Gurdaspur

FIR No. not known,

U/s. 406/498-A IPC,
P.S. City Khanna,
P.P. Moti Nagar,Ldh.

Note:-1. This is the first bail

Application and no such bail
Application is pending or decided
by any competent court of law.

2. The co-accused has already been

granted bail by the court of
Sh. Sanjeev Berry, ASJ, Ludhiana,
vide order dated 26/10/2006,

Application u/s 438 of Cr.P.C. for grant of

Anticipatory bail.

Respectfully showeth;
1. That the petitioner is law abiding and peace
loving citizens of India.

2. That the younger brother of the petitioner was

married to Rajbir Kaur D/o Swaran Singh on 3/3/2006
at Khanna, Distt. Ludhiana.

82
3. That the petitioner visited her parental home
only twice after the marriage of her brother was
solemnized with the said Rajbir Kaur. The first
time was in the month of August on the occasion
Rakshabandhan and the second time was in the month
of October,2006, when the father of the petitioner
met with a road accident and was admitted into
Apollo Hospital, Ludhiana. On both the occasions
the petitioner arrived in the morning and left in
the evening and on both the occasions Rajbir Kaur
was not present.

4. That the petitioner is happily married and is

busy and occupied in the affairs of her own family
and she gets no time or occasion to interfere in
the married life of her brother. Rajbir Kaur is
trying to falsely implicate the petitioner in false
and frivolous dowry case by filing a false
complaint with the police of P.S. City Khanna. The
petitioner is innocent and is likely to be
implicated falsely and she apprehends her arrest at
the hand of police of P.S. City Khanna, Ludhiana.

5. That the petitioner undertakes to abide by all

the terms and conditions as may be imposed by this
Hon’ble court while granting her bail.

6. That the petitioner undertakes not to directly

or indirectly make any inducement, threats, or
promise to any person acquainted with the facts of
the case so as to dissuade her from disclosing such
facts of the court or to any police officer.

83
7. That the petitioner undertakes not to leave
India without the prior permission of this Hon'ble
court and there is no likelihood of absconding of
the petitioner.

8. That the petitioner undertakes to make herself

available for interrogation by the police officer
as and when the same is required.

It is, therefore, respectfully prayed that the

petitioner may please be granted anticipatory bail
and in the meantime the directions be passed on to
the concerned police to release the petitioner on
bail in case of her arrest, in the interest of
justice.

Petitioner

Through Counsel

Place:- Ludhiana
Date:-01/11/2006 Advocate

84
3. That the said Parminder Kaur 38 years old and
having three children i.e. two sons aged about
20,16 years and daughter aged about 14 years.
4. That the said Parminder Kaur demanded money
from the petitioner but the petitioner showed
inability to give her any money. On showing
inability by the petitioner the Parminder Kaur
turned sour and is bent upon to embroil the
petitioner as such she is threatening to implicate
the applicant in some false, non-bailable,
cognizable offence.
5. That at the instance of Parminder Kaur the
police of P.S. is out to arrest the applicant
in some false and frivolous grounds. The police
raided the house of the applicant yesterday but the
applicant was not there at home and therefore, he
could not be arrested. The applicant apprehends
arrest at the hands of the police of P.S.

6. That the petitioner is innocent and is likely

to be implicated falsely.

7. That the petitioner undertakes to abide by all

the terms and conditions as may be imposed by this
Hon’ble court while granting him on bail.
8. That the petitioner undertakes not to leave
India without the prior permission of this Hon'ble
court and there is no likelihood of absconding of
the petitioner.
9. That the petitioner undertakes to join the
investigation as and when the same is required.
It is, therefore, respectfully prayed that the
petitioner may please be granted anticipatory bail
and in the meantime the directions be passed on to

85
the concerned police to release the petitioner on
bail in case of his arrest, in the interest of
justice.

Petitioner

Through Counsel

Place:- Ludhiana Advocate

Date: / /2006

86
IN THE COURT OF HON'BLE SESSIONS JUDGE, LUDHIANA

STATE VS. VINOD KUMAR

S/O LATE RAM PARKASH
R/O H.NO.79,
GURU GOBIND SINGH NAGAR,
NOORWALA ROAD,LDH.

FIR NO.270/26-10-2006
U/S 306 IPC
P.S. BASTI JODHEWAL,
LUDHIANA

AFFIDAVIT

I, VINOD KUMAR S/O LATE RAM PARKASH R/O H.NO.79,

GURU GOBIND SINGH NAGAR, NOORWALA ROAD, Ludhiana do
hereby solemnly affirm and declare as under:-

1. That deponent had filed the first bail

application on and the second bail
application on 27/9/2006.

2. That in the both above said bail applications

no records were produced in this Hon'ble court and
both the applications were rejected by the Hon'ble
court of sh Satwinder Singh, ASJ, Ludhiana.

87
3. That now this third bail application is hereby
by filed.

Deponent
Verification:-

Verified that above noted contents are true and

correct to the best of my knowledge and belief and
nothing has been concealed therein.

Place:- Ludhiana,
Date: Deponent

88
In the court of Sessions Judge, Ludhiana

State Vs. Satnam Singh aged 30 yrs.

FIR No. 50/2002,

U/s. 323/325,452,34 IPC,
P.S. Basti Jodhewal, Ldh.

AFFIDAVIT

I, Satnam Singh aged 30 yrs. S/o Jit Singh, R/o

Booth Garh, Jodhewal, Ludhiana do hereby Solemnly
affirm and declare as under:-

1. That this is first bail application and no such

or similar bail application either is pending or
has been decided by any competent court of law.

Deponent
Verification:-

Verified that above noted contents are true and

correct to the best of my knowledge and belief and
nothing has been concealed therein.

Place: Ludhiana,
Date:24/10/2006 Deponent

89
In the court of Sessions Judge, Ludhiana

State Vs. Satnam Singh aged 30 yrs.

S/o Jit Singh,
R/o Booth Garh, Jodhewal,
Ludhiana
FIR No. 50/2002,
U/s. 323/325,452,34 IPC,
P.S. Basti Jodhewal, Ldh.
Note: Bail application of
Co-accused was decided
by the court of Sh.
Sanjeev Berry, ASJ, Ludhiana

Application u/s 438 Cr.P.C.

for grant of Anticipatory bail.

1. That the petitioner is law abiding and peace

loving citizens of India.

2. That earlier the above said case was fixed on

3/01/2005 in the court of Smt Ravinder Kaur, JMIC,
Ludhiana and the applicant/accused on same day
could not come present in the said court and
subsequently the case had been transferred from one
court to another and the applicant could not know
actually in which court the case was fixed that is
why the applicant could not present none of the
dates of hearing now the applicant has come to know
that the case is pending in the Hon'ble court of
Sh. Kuldip Singh, JMIC, Ludhiana and has also come
to know that warrants have been issued against the
accused/applicant.

90
3. That the co-accused Surinder Singh has already
been granted bail by the Court of Sh. Sanjeev
Berry, ASJ, Ludhiana.

4. That the reason of absence was

misunderstanding of the courts in which the case
was pending and the applicant was in dilemma.

5. That the absence of the accused/applicant was

neither willful nor intentional rather
circumstantial as stated above.

6. That Applicant undertakes that he will abide

by all the terms and conditions imposed by this
Hon’ble Court while granting him bail.

7. That the petitioner undertakes to make himself

available for interrogation by the police officer
as and when the same is required.

8. That the petitioner undertakes not to directly

or indirectly make any inducement, threats, or
promise to any person acquainted with the facts of
the case so as to dissuade him from disclosing such
facts of the court or to any police officer.

9. That the petitioner undertakes that he shall

not leave India without previous permission of the
court and also undertakes to present before this
Hon'ble court each and every date of hearing.
It is therefore, respectfully prayed that the
applicant/accused may kindly be granted
anticipatory and in the event of arrest, necessary

91
direction may also please be given to the concerned
police officer to release him on bail in the
interest of justice.

Applicant/accused

Through counsel

Place: -Ludhiana Naginder Singh,

Date:-24-10-2006 (Advocate)

92
93
 In The Court Of Hon'ble Distt. & Sessions Judge,
Ludhiana

Raja Singh Versus Sukhjinder Kaur

In Re: complaints u/s 138 of N.I.Act.

Application U/S 438 of Cr.P.C. for the grant of

Anticipatory Bail

Sir,
The petitioner respectfully submits as under:-

1. That the petitioner is law abiding and peace

loving citizen of India and never involved himself
in any unlawful activities.

2. That the two criminal complaints u/s 138 of

Negotiable Instruments Act, are pending in the
court of Ms. Palwinderjit Kaur, JMIC, Ludhiana and
are now fixed for 28/10/2006, titled as “Sukhjinder
Kaur Vs. G.R.D. Academy & its chairman Raja Singh”

3. That the petitioner is innocent person and is

Chairman of Educational Institutions like G.R.D.
Academy here and also others at Deheradoon.

4. That the police official came with non-

bailable warrants to arrest the petitioner but the
petitioner is away to Deheradoon, and from this
fact it has been learned that the Ld. Court of Ms.

94
Palwinderjit Kaur, JMIC, Ludhiana has ordered for
non-bailable warrants against the petitioner and
the G.R.D. Academy. It has all been done quite
hastily and unreasonably since the Ld. Court had
issued summons on First date and alleged report of
refusal, the Ld. Court issued bailable warrants and
again on the alleged report of refusal, the Ld.
Court issued the non-bailable warrants.

5. That it can be well understood that there can

never be practically any refusal in case of
bailable warrants and the reports of refusal on the
summons as also on the bailable warrants are
wrongfully managed by the complainant.

6. That in view of the above circumstances, it is

well apprehended that the prestige and position of
the petitioner are at stake and his image may be
badly spoiled in the society apart from the fact
that the unfairly procured reports of his refusal
are only a table work managed through malpractice
and undue influence.

7. That the offence u/s 138 of N.I. Act is even

otherwise bailable one.

8. That the petitioner undertakes that he will

abide all the terms and conditions imposed by this
Hon’ble court while releasing him on bail.

It is, therefore, respectfully prayed that the

arrest of the petitioner/accused may kindly be
stayed during the pendency of the present bail
application and direction may be given to the Trial

95
Court to release the petitioner on bail in the
event of his surrender in the court in the interest
of justice.

Petitioner

Through Counsel
Place:- Ludhiana
Date:- 23/10/2006 J.K.Tiwari,
Advocate

AFFIDAVIT

I, Vir Bhan Devgun aged years r/o G.R.D. Academy,

Hambra Road, Ludhiana, authorized representative of
the petitioner, do hereby Solemnly affirm and
declare as under:-

1. That this is first bail application and no such

or similar bail application either is pending or
has been decided by any competent court of law.

2. That the contents of para No. 1 to 8 of the

accompanying petition are true and correct to the
best of my knowledge and belief.

Deponent
Verification:-

Verified that above noted contents are true and

correct to the best of my knowledge and belief and
nothing has been concealed therein.

96
Place: Ludhiana,
Date:23/10/2006 Deponent

97
98
99
IN THE COURT OF SESSIONS JUDGE, LUDHIANA

State Versus Amarjit Singh

etc.

FIR No. Not Known

U/ss Not Known but cognizable and Non-bailable.
P.S. Div. No. 7,
Ludhiana

AFFIDAVIT

I, Amarji Singh aged 59 years S/o Sh. Jagat Singh

resident of H.No. 5827, Plot No. 6, Main Road,
Sarpanch Colony, Jamalpur, Ludhiana do hereby
Solemnly affirm and declare as under:-

1. That this is first bail application and no such

or similar bail application either is pending or
has been decided by any competent court of law.

Deponent
Verification:-

100
Verified that above noted contents are true and
correct to the best of my knowledge and belief and
nothing has been concealed therein.

Place: Ludhiana,
Date:12/10/2006 Deponent

101
IN THE COURT OF SESSIONS JUDGE, LUDHIANA

State Versus 1. Amarji Singh aged 59

years
S/o Sh. Jagat Singh

2. Jagdip Singh
s/o Amarjit Singh
Both residents of H.No. 5827, Plot No. 6, Main
Road, Sarpanch Colony, Jamalpur, Ludhiana

FIR No. Not Known

U/s Not Known,
P.S. Div. No. 7,
Ludhiana

Application u/s 438 Cr.P.C.for the grant of

Anticipatory Bail
Sir,

The applicant/accused respectfully submits as

under:-

1. That the petitioners are law abiding and peace

loving citizens of India.

2. That earlier the above said case was fixed on

3/01/2005 in the court of Smt Ravinder Kaur, JMIC,
Ludhiana and the applicant/accused on same day
could not come present in the said court and

102
subsequently the case had been transferred from one
court to another and the applicant could not know
actually in which court the case was fixed that is
why the applicant could not present none of the
dates of hearing now the applicant has come to know
that the case is pending in the Hon'ble court of
Sh. Kuldip Singh, JMIC, Ludhiana and has also come
to know that warrants have been issued against the
accused/applicant.

3. That the co-accused Surinder Singh has

already been granted bail by the Court of Sh.
Sanjeev Berry, ASJ,Ludhiana.

4. That the reason of absence was

misunderstanding of the courts in which the case
was pending and the applicant was in dilemma.

5. That the absence of the accused/applicant was

neither willful nor intentional rather
circumstantial as stated above.

6. That Applicant undertakes that he will abide

by all the terms and conditions imposed by this
Hon’ble Court while granting him bail.

7. That the Accused/Applicant is ready to furnish

bail/surety bond as may be imposed by this Hon'ble
Court.

8. That the applicant/accused undertakes to

present before this Hon'ble court each and every
date of hearing and also undertakes not to leave

103
India without prior permission of the Hon'ble
Court.

It is therefore, respectfully prayed that the

applicant/accused may kindly be granted
anticipatory bail in the interest of justice.

Applicant/accused

Through counsel

Place: -Ludhiana Naginder Singh,

Date:-12-10-2006 (Advocate)

104
105
106
4. That petitioners have been falsely implicated
in this case and they have not committed any
offence much less offence under section 409 IPC.
The allegations made in the FIR are totally false
and frivolous.

5. That the petitioners are peace loving citizen

and they have already joined the investigation and
the alleged recovery has already been effected as
the petitioner was granted regular bail after his
police custody and judicial lock up and as such he
is no more required by the police for further
investigation of the case. The Challan has already
been presented in the Trial Court.
6. That the applicants/Accused undertake that they
will abide all the terms and conditions imposed by
this Hon’ble court while releasing him on bail and
shall not tamper with the evidence of the
prosecution in any manner.
Keeping in view of the above said circumstances, it
is, therefore, respectfully prayed that the
Applicants/accused may kindly be granted
Anticipatory Bail as provided under section 438
Cr.P.C.
It is further prayed that the arrest of the
petitioners/applicants/accused may kindly be stayed
during the pendency of the present bail application
and direction may be given to the Trial Court to
release the petitioners on bail in the event of
their surrender in the court in the interest of
justice.

107
 Petitioners
Through Counsel
Place:- Ludhiana

Date:- 15 /10/2005 Bikram Pal

Binder,
Advocate

108
1. That the petitioner is a law abiding retired
defense persons as well as retired person from
Education Deptt.(NCC Cardre).

2. That the applicant is having civil litigation

in the nature of eviction petition against one
Manjit Singh s/o Ram Singh which is pending in
the court of Sh. Kuldip Singh, Rent Controller,
Ludhiana, in which the applicant has prayed for
evicting said Manjit Singh on the basis of personal
necessity.

3. That in order to pressurize the applicant to

withdraw the said eviction petition Manjit Singh is
filing false and frivolous complaints against the
applicant in P.S. Sarabha Nagar, in collusion with
the police officials. Manjit Singh also abuses and
calls bad name to the applicant. On 2/10/2006 said
Manjit Singh called the applicant a “Chura” which
is a derogatory word and is otherwise punishable
under the law. When the applicant approached the
said Manjit Singh not to use such words, the said
Manjit Singh threatened to implicate the applicant
in some false, non-bailable, cognizable offence.

4. That the police of p.s. Sarabha Nagar is out to

arrest the applicant in some false and frivolous
complaint filed by said Manjit Singh. IN fact, the
police raided the house of the applicant yesterday
but the applicant was not there at home and
therefore, he could not be arrested. The applicant
apprehends arrest at the hands of the police of
P.S. Sarabha Nagar.

109
5. That the petitioner undertakes to abide by all
the terms and conditions as may be imposed by this
Hon’ble court while granting him on bail.

6. That the petitioner undertakes not to leave

India without the prior permission of this Hon'ble
court and there is no likelihood of absconding of
the petitioner.

7. That the petitioner undertakes to join the

investigation as and when the same is required.

It is, therefore, respectfully prayed that the

petitioner may please be granted anticipatory bail
and in the meantime the directions be passed on to
the concerned police to release the petitioner on
bail in case of his arrest, in the interest of
justice.

Petitioner

Through Counsel

Place:- Ludhiana Advocate

Date:5/10/2006

110
IN THE COURT OF SESSIONS JUDGE, NAWANSHAHAR

State Versus Surinder Kaur

etc.

Affidavit

I, Surinder Kaur aged 45 years Wd/o Sh. Sucha Singh

r/o Raju Colony, gali No.2, Grewal Road, New
Subhash Nagar, Rahon Road, P.S. Basti Jodhewal,
Ludhiana do hereby Solemnly affirm and declare as
under:-

1. That this is first bail application and no such

or similar bail application either is pending or
has been decided by any competent court of law.

Deponent
Verification:-
Verified that above noted contents are true and
correct to the best of my knowledge and belief and
nothing has been concealed therein.
Place: Nawanshahar,
Date: /10/2006 Deponent

111
IN THE COURT OF SESSIONS JUDGE, NAWANSHAHAR

State Versus 1. Surinder Kaur aged

45 yrs.
Wd/o Sucha Singh,
2.Satpal Singh aged 23 yrs
s/o Sucha Singh,
3. Amarjit Kaur aged 20 yrs.
D/o Sucha Singh,
All residents of Raju Colony, gali No.2, Grewal
Road, New Subhash Nagar, Rahon Road, P.S. Basti
Jodhewal, Ludhiana

FIR No. Not known,

U/s 406/498-A/34 IPC,
P.S. Rahon,
Distt.Nawanshar,

Note:-This is the first Bail Application.

Application u/s 438 Cr.P.C.for the grant of

Anticipatory Bail

Sir,

The Petitioners respectfully submits as under:-

112
1. That the petitioners are totally innocent and
have been falsely implicated in the said FIR.

2. That the above said FIR has been lodged at the

instance of the complainant namely Balwinder Kaur
w/o Gurpal Singh d/o Charat Singh r/o Dugla
Mohalla, Khas Rahon,P.S. Rahon, Nawanshahar.

3. That petitioner No.1 is mother-in-law of the

complainant, petitioner No.2 is brother in-law of
the complainant and petitioner No.3 is sister-in-
law of the complainant.

4. That at the time of the marriage nothing was

taken nor was demanded in terms of any dowry by the
petitioner side. The marriage was performed very
simple.

5. That the allegations leveled against the

petitioners are totally false and frivolous and as
such no demand as has been alleged has never took
place.

6. That the FIR has been lodged with an ulterior

motive and with malafide intention just to harass
the petitioners.

7. That the petitioners undertake to abide by all

the terms and conditions as may be imposed by this
Hon’ble court while granting them on bail.

8. That the petitioners undertake not to leave

India without the prior permission of this Hon'ble

113
court and there is no likelihood of absconding of
the petitioners.

9. That the petitioners undertake to join the

investigation as and when the same is required.

It is, therefore, respectfully prayed that the

petitioners may please be granted anticipatory bail
and in the meantime the directions be passed to the
concerned police of P.S. Rahon, Distt. Nawanshahar,
to release the petitioners on bail in case of their
arrest, in the interest of justice.

Petitioners

Through Counsel

Avtar Mallan,

Place:- Nawanshahar Advocate

Date: /10/2006

114
115
IN THE COURT OF SESSIONS JUDGE, LUDHIANA

State Versus Killi@ Karnail

Singh

Affidavit

I,Sanjeev Kumar Sharma s/o Late Brij Lal Sharma,

R/o 32-33B, Shastri Nagar, Ludhiana, do hereby
Solemnly affirm and declare as under:-

1. That this is first bail application and no such

or similar bail application either is pending or
has been decided by any competent court of law.

Deponent
Verification:-
Verified that above noted contents are true and
correct to the best of my knowledge and belief and
nothing has been concealed therein.
Place: Ludhiana
Date: 18/09/2006 Deponent

116
IN THE COURT OF SESSIONS JUDGE, LUDHIANA

State Versus Sanjeev Kumar

Sharma
s/o
Late Brij Lal Sharma,
R/o 32-33B, Shastri
Nagar,
Ludhiana,

FIR. No. 151/16/9/2006,

U/s. 341/323/427/509/506/384/511/34 IPC,
P/s. Model Town,
Ludhiana

Note:This is the first Bail Application of the

accused and no such bail application has ever been
filed or rejected by any court.

Application u/s 438 Cr.P.C.for the grant of

Anticipatory Bail

Sir,

The Petitioner respectfully submits as under:-

1. That the applicant is peace-loving citizen of

India and doing business of contractor ship.

117
2. That at the instance of complainant Jaspreet
Kaur an FIR has been lodged against the applicant
on false and frivolous grounds.
3. That the applicant had move an application
against the acts and conduct of complainant
Jaspreet Kaur, before the S.S.P Ludhiana and D.I.G.
Ludhiana and clearly stating the apprehension of
false implications but despite the application
moved by the applicant regarding acts and conducts
of Jaspreet Kaur, the police in collusion with
Jaspreet Kaur has registered has lodged FIR against
the applicant, which is totally false, frivolous
and baseless. Carbon Copy of the application moved
before good-office is attached herewith.

4. That the said Jaspreet Kaur had leveled

allegations in her F.I.R. regarding removing of the
front bumper and the front headlight of her car
against the applicant and one more person in the
broad day light after stopping her in the busy
market area. The said allegations are malafide and
not sustainable in the light of the fact that the
applicant has number of cars and other moveable
property and is Income tax payee and Bank balance
worth lakhs of Rupees and further the applicant has
property worth more than 5 crores in the name of
his family and he is a respectable citizen. It
cannot be taken that the applicant shall steal the
above said goods worth not more than Rs.1500/- and
further that to in broad daylight. The said FIR is
in fact counterblast to the FIR No., 177 of 2006
registered at P.S. Sadar, Ludhiana. In which
applicant was being pressurized to withdraw the
said FIR and to not to demand the amount from

118
Jaspreet kaur, who had taken the loan from the
applicant and who owe the applicant the said
amount. The application for re-inquiry in the
matter has been moved and the applicant wants to
join the investigation and make the police aware of
true facts.
5. That the allegations leveled in the said FIR
are totally false, frivolous and baseless. In fact
no such occurrence ever took place as mentioned in
the said FIR.
6. That the petitioner is totally innocent and
has been falsely implicated in the said FIR.
7. That the petitioner undertakes to abide by all
the terms and conditions as may be imposed by this
Hon’ble court while granting her on bail.

8. That the petitioner undertakes not to leave

India without the prior permission of this Hon'ble
court and there is no likelihood of absconding of
the petitioner.

9. That the petitioner undertakes to join the

investigation as and when the same is required.

It is, therefore, respectfully prayed that the

petitioner may please be granted anticipatory bail
and in the meantime the directions be passed to
police to release the petitioner on bail in case of
his arrest, in the interest of justice.

Petitioner

Through Counsel

119
Place:- Ludhiana P.S. Ghumman,
Harmohinder singh Karamvir singh,
Puneet kaur
Date:18/09/2006 Advocates

120
IN THE COURT OF SESSIONS JUDGE, LUDHIANA

State Versus Manmohan Aggarwal

etc.

Affidavit

I, Manmohan Aggarwal S/o residents of B-

I-204, Pashchim Vihar, New Delhi, at present
do hereby Solemnly affirm and declare as
under:-

1. That the petition has been drafted on the

instructions of the petitioners and the same can be
read as part of this affidavit.

2. That this is first bail application and no such

or similar bail application either is pending or
has been decided by any competent court of law.

Deponent
Verification:-
Verified that above noted contents are true and
correct to the best of my knowledge and belief and
nothing has been concealed therein.
Place: Ludhiana
Date: 18/09/2006 Deponent

121
IN THE COURT OF SESSIONS JUDGE, LUDHIANA

State

Versus

1. Manmohan Aggarwal S/o

2. Kavita Aggarwal w/o Manmohan Aggarwal,
3.Nitin Aggarwal,
4.Rohit Aggarwal,
5.Rahul Aggarwal,
All sons of Manmohan Aggarwal,
6.Shikha Aggarwal w/o Nitin Aggarwal,
All residents of B-I-204, Pashchim Vihar,
New Delhi,

FIR. No. 248/06-9-2006,

U/s. 406/498-A/120-B IPC,
P/s. Division No.5,
Ludhiana

Note:This is the first Bail Application of the

accused and no such bail application has ever been
filed or rejected by any court.

Application u/s 438 Cr.P.C.for the grant of

Anticipatory Bail

Sir,

122
The Petitioners respectfully submit as under:-

1. That the applicants are peace-loving citizens

of India.

2. That the applicant Rahul Aggarwal got married

to the complainant at Delhi on 02-09-2004 and even
other ceremonies as alleged in the FIR took place
in Delhi. No ceremony of marriage as per the
allegations leveled in the FIR, took place at
Ludhiana. The applicant No. 1 is father-in-law,
applicant No. 2 is mother-in-law, applicant No.3
and 4 are the brother-in-laws and applicant No. 5
is the husband and applicant No.6 is the sister-
in-law of the complainant. The Ludhiana police
has got the present FIR lodged against the
applicants by based on false and frivolous facts.
The Ludhiana police is out to harass the
applicants. In fact during the course of
investigation, the Ludhiana police had made
applicants sign some documents pertaining to be the
compromise and affidavits and Divorce petition,
under pressure, for Rs. 11 lac towards the full and
final settlement and when the applicants resisted
then the applicants were given threats of false
implications and now the applicants came to know
that FIR based on false and frivolous facts has
been lodged against them. In fact earlier the
Police of Ludhiana had ordered the applicants to
get the demand draft of Rs. 4,00,000/- prepared,
which the applicants did under pressure but the
greed of complainant and the Ludhiana Police
crossed all barriers and subsequently they started
demanding Rs. 11,00,000/-.

123
3. That the true facts are that complainant
Manisha Gupta was having illicit relations with
some persons in Ludhiana and as such she never
wanted to live with applicant Rahul Aggarwal and
the marriage was the outcome of the pressure having
been built by the father of Manisha Gupta. The
allegations leveled in the FIR are palpably false.
The allegation leveled are general in nature and no
specific allegation has been attributed to the
applicant. Even otherwise the complainant while
coming from her matrimonial home brought all the
gold ornaments which have been given by the
applicants to her in the marriage alongwith her.
The complainant had roped in all the members of the
family of Rahul Aggarwal, applicant. Despite the
fact that the complainant and Rahul Aggarwal were
living separately and were separate in mess from
the very beginning. The business of Rahul Aggarwal
too is separate from the other member of the
family. Similarly Nitin Aggarwal and Rohit Aggarwal
are having separate business and are separate in
mess and are further having separate portion in
residence.

4. That the applicants have already joined the

investigation and have even offered Manisha Gupta
to live with them and further applicant Rahul
Aggarwal had already filed Petition u/s 9 of HMA,
thereby requesting Manisha Gupta to join his
company. Even other wise the Ludhiana Police has no
jurisdiction to lodge the FIR as no part of the
cause of action had arisen in Ludhiana. The lodging

124
of present FIR against the applicants is nothing
but the abuse of the process of law.

5. That the allegations leveled in the said FIR

are totally false, frivolous and baseless. In fact
no such occurrence ever took place as mentioned in
the said FIR.

6. That the petitioners are totally innocent and

have been falsely implicated in the said FIR.

7. That the petitioners undertake to abide by all

the terms and conditions as may be imposed by this
Hon’ble court while granting them on bail.

8. That the petitioners undertake not to live

India without the prior permission of this Hon'ble
court and there is no likelihood of absconding of
the petitioners.

9. That the petitioners undertake to join the

investigation as and when the same is required.

It is, therefore, respectfully prayed that the

petitioners may please be granted anticipatory bail
and in the meantime the directions be passed to
police to release the petitioners on bail in case
of their arrest, in the interest of justice.

Petitioners

Through Counsel

125
Place:- Ludhiana P.S. Ghumman,
Harmohinder singh Karamveer singh,
Puneet kaur
Date:18/09/2006 Advocates

126
IN THE COURT OF SESSIONS JUDGE, LUDHIANA

State Versus Sanjeev Kumar

Sharma

Affidavit

I,Sanjeev Kumar Sharma s/o Late Brij Lal Sharma,

R/o 32-33B, Shastri Nagar, Ludhiana, do hereby
Solemnly affirm and declare as under:-

1. That this is first bail application and no such

or similar bail application either is pending or
has been decided by any competent court of law.

Deponent
Verification:-
Verified that above noted contents are true and
correct to the best of my knowledge and belief and
nothing has been concealed therein.
Place: Ludhiana
Date: 18/09/2006 Deponent

127
IN THE COURT OF SESSIONS JUDGE, LUDHIANA

State Versus Sanjeev Kumar

Sharma
s/o
Late Brij Lal Sharma,
R/o 32-33B, Shastri
Nagar,
Ludhiana,

FIR. No. 151/16/9/2006,

U/s. 341/323/427/509/506/384/511/34 IPC,
P/s. Model Town,
Ludhiana

Note:This is the first Bail Application of the

accused and no such bail application has ever been
filed or rejected by any court.

Application u/s 438 Cr.P.C.for the grant of

Anticipatory Bail

Sir,

The Petitioner respectfully submits as under:-

1. That the applicant is peace-loving citizen of

India and doing business of contractor ship.

128
2. That at the instance of complainant Jaspreet
Kaur an FIR has been lodged against the applicant
on false and frivolous grounds.
3. That the applicant had move an application
against the acts and conduct of complainant
Jaspreet Kaur, before the S.S.P Ludhiana and D.I.G.
Ludhiana and clearly stating the apprehension of
false implications but despite the application
moved by the applicant regarding acts and conducts
of Jaspreet Kaur, the police in collusion with
Jaspreet Kaur has registered has lodged FIR against
the applicant, which is totally false, frivolous
and baseless. Carbon Copy of the application moved
before good-office is attached herewith.

4. That the said Jaspreet Kaur had leveled

allegations in her F.I.R. regarding removing of the
front bumper and the front headlight of her car
against the applicant and one more person in the
broad day light after stopping her in the busy
market area. The said allegations are malafide and
not sustainable in the light of the fact that the
applicant has number of cars and other moveable
property and is Income tax payee and Bank balance
worth lakhs of Rupees and further the applicant has
property worth more than 5 crores in the name of
his family and he is a respectable citizen. It
cannot be taken that the applicant shall steal the
above said goods worth not more than Rs.1500/- and
further that to in broad daylight. The said FIR is
in fact counterblast to the FIR No., 177 of 2006
registered at P.S. Sadar, Ludhiana. In which
applicant was being pressurized to withdraw the
said FIR and to not to demand the amount from

129
Jaspreet kaur, who had taken the loan from the
applicant and who owe the applicant the said
amount. The application for re-inquiry in the
matter has been moved and the applicant wants to
join the investigation and make the police aware of
true facts.
5. That the allegations leveled in the said FIR
are totally false, frivolous and baseless. In fact
no such occurrence ever took place as mentioned in
the said FIR.
6. That the petitioner is totally innocent and
has been falsely implicated in the said FIR.
7. That the petitioner undertakes to abide by all
the terms and conditions as may be imposed by this
Hon’ble court while granting her on bail.

8. That the petitioner undertakes not to live

India without the prior permission of this Hon'ble
court and there is no likelihood of absconding of
the petitioner.

9. That the petitioner undertakes to join the

investigation as and when the same is required.

It is, therefore, respectfully prayed that the

petitioner may please be granted anticipatory bail
and in the meantime the directions be passed to
police to release the petitioner on bail in case of
his arrest, in the interest of justice.

Petitioner

Through Counsel

130
Place:- Ludhiana P.S. Ghumman,
Harmohinder singh Karamvir singh,
Puneet kaur
Date:18/09/2006 Advocates

131
 3. That Ajit Singh who is husband of missing
Amarjit Kaur, Kamaljit Singh S/o Ajit Singh and
Baghel Singh, brother-in-law of Ajit Singh are
threatening the petitioner to implicate him in any
false criminal case in collusion with the police
officials. They have been blackmailing the
petitioner into paying of huge amount of money
otherwise they have threatening that the petitioner
will be implicated in false alleged disappearance
of Mrs. Amarjit Kaur.

4. That the petition has not committed any offence

and is totally innocent.

5. That the petitioner has been fully co-operative

with the police officials in proper investigation
of the case and the petitioner is innocent even to
the knowledge of the police officials.

6. That there is no likelihood of the petitioner

of absconding.

7. That the petitioner undertakes to join the

investigation as and when called by the
investigating agency.
8. That the applicant/petitioner undertakes to
abide by all the terms and conditions as may be
imposed by this hon’ble court while granting him on
bail.

132
 It is, therefore, prayed that the petitioner
may please be released on bail pending
investigation and in the meantime the arrest of the
petitioner may please be stayed in the interest of
justice.
Petitioner
Mohinder Singh

Through Counsel
Place:- Ludhiana P.K. Wadhera
Date:01/06/2006 Advocate

133
IN THE COURT OF SESSIONS JUDGE, LUDHIANA

State Versus Gurmeet Singh

S/o Sh. Jiwan Singh
resident of
188-A, Model Town Ext.
Ludhiana.

FIR. No. Not known

U/s. Not Known
P/S. Model Town,
Ludhiana

Note:-That this is first bail application.

Application u/s 438 Cr.P.C.for the grant of

Anticipatory Bail

Sir,

The Petitioners respectfully submit as under:-

1. That the petitioner is peace loving and

law abiding citizen of India and has never indulged
in any offence.

2. That the petitioner Gurmeet Singh was

prop. Of M/s Friends Collections, Opp. Mehak
Restraurant, near Mintgumri Chowk, Ludhiana. He was

134
cloth a merchant. He left this business in the year
2003

3. That the complainant Rakesh Sachdeva prop. M/s

Sunny Textiles shop No. 63, to 97, Guru Nanak
Complex, Dr. Gujjar Mal Road, Ludhiana and is
employee Amarjit Singh was also dealing with the
petitioner for the purchase of the clothes.

4. That at that time some documents were relating

to the business in the possession of the
complainants. In fact several time petitioner
requested to return all the relevant documents to
the petitioner, but they refused to do so and are
giving threats to the petitioner to implicate him
in some non-bailable offence.

5. That yesterday Rakesh Sachdea and said Amarjit

Singh visited the house of the petitioner
alongwith some persons in civil dress to arrest
petitioner, luckily the petitioner was not present
at the house.

6. That the petitioner has apprehension that the

complainant Rakesh Sachdeva and Amarjit Singh may
involve him in some non-bailabe offence.

7. That the complainant with mense rea wants to

lower the image in the society of the petitioner
and also wants to involve him in some non-bailable
offence.

135
8. That the petitioner comes of respectable
family and the image of him may be lowered by the
above said activities.

9. That the applicant/petitioner undertakes

to abide by all the terms and conditions as may be
imposed by this hon’ble court while granting him on
bail.

It is, therefore, prayed that the petitioner may be

granted anticipatory bail and in the meantime the
arrest of the petitioner may be stayed in the
interest of justice.

Petitioner

Gurmeet Singh

Through Counsel

Place:- Ludhiana Har Parkash Singh

Date:31/05/2006 Advocate

136
In The Court Of Sessions Judge, Ludhiana

State Versus 1. Sabir

S/o Nazir

2. Anzar
S/o Mazhar
Both residents of
Captain Colony,
Meharban,
Rahon Road,
Basti Jodhewal,
Ludhiana

FIR. No. Not known

U/s. No Known,
P/P. Meharban
P.S. Basti Jodhewal,
Ludhiana,

Application u/s 438 Cr.P.C.for the grant of

Anticipatory Bail

Sir,

The petitioners respectfully submit as under:-

1. That the petitioners are peace-loving

citizen of India and has never been involved in any
criminal activities.

137
2. That the petitioners are working in factory
i.e. Spot King India Ltd. at Meherban, Rahon Road,
Basti Joodhewal, Ludhiana, and in the same factory
one another girl namely Kiran D/o Satish Kumar r/o
Harkishan Vihar, Rahon Road, Ludhiana, is working
in the same Factory for long time. Recently the
father of said Kiran says to the petitioners to
leave the company and not to work with the company.
The petitioners asked for the reasons for the same,
but Satish Kumar said nothing, and on 24-5-2006 at
about 9.00 P.M. Satish Kumar alongwith some other
persons came to the house of the petitioners and
gave push and blow to them and gave threatening to
the petitioners to involve them in some non-
bailable offence.

3. That the petitioners are innocent and they have

apprehension to be falsely implicated by Satish
Kumar.

4. That the petitioners have apprehension that

they can be involved unnecessarily with malice
while they are innocent.

5. That Applicants/petitioners undertake to abide

by all the terms and conditions imposed by this
Hon’ble Court while granting them bail.

It is, therefore, prayed that the petitioners may

be granted anticipatory bail and in the meantime
the arrest of the petitioners be stayed in the
interest of justice.

138
 Petitioners
Through Counsel

Place:- Ludhiana A.K.Giri,

Date: /05/2006 Advocate

139
IN THE COURT OF SESSIONS JUDGE, LUDHIANA

State Versus 1. Gurmeet Singh

Affidavit

I, Anzar S/o Mazhar Both residents of Captain

Colony, Meharban, Rahon Road, Basti Jodhewal,
Ludhiana, do hereby solemnly affirm and declare
as under:-

1. That the present Petition for grant of the

anticipatory bail, has been drafted on the
instructions of the Deponent/petitioner.

2. That this is first bail application and no such

or similar bail application either is pending or
has been decided by any competent court of law.

Deponent
Verification:-

It is verified that above noted contents of para

no. 1 to 2 is true and correct to the best of my
knowledge and belief and nothing has been concealed
therein.

140
Place: Ludhiana
Date: 29/5/2006
Deponent

141
In The Court Of Sessions Judge, Jallandhar

State Versus Pankaj Mishra

S/o Mahadev Mishra
C/o Somnath Inderpal
Mandi Frentan Ganj,
Jallandhar City,

FIR. No. Not known

U/s. No Known,
P/S. Division No.3,
Jallandhar,

Application u/s 438 Cr.P.C.for the grant of

Anticipatory Bail

Sir,

The petitioners respectfully submit as under:-

1. That the petitioner is peace-loving

citizen of India and has never been involved in any
criminal activities.

2. That one Vinod Kumar and the petitioner are

working with Somnath Inderpal, Mandi Frentan Ganj,
Jallandhar, for long time and due to some trifle
matter arose between them, Vinod Kumar is extending
threats with dire consequences to the petitioner

142
and he also threats the petitioner to involve him
in some non-bailable offence.

3. That the petitioner is innocent and he has

apprehension to be falsely implicated by Vinod
Kumar.

4. That the petitioner is outsider and Vinod Kumar

is local so he is taking advantage of situation and
extending threats against the petitioner.

5. That Applicant undertakes to abide by all the

terms and conditions imposed by this Hon’ble Court
while granting them bail.

It is, therefore, prayed that the petitioner may be

granted anticipatory bail and in the meantime the
arrest of the petitioner be stayed in the interest
of justice.

Petitioners
Through Counsel

Place:- Ludhiana A.K.Giri,

Date: /05/2006 Advocate

143
In The Court Of Sessions Judge, Jallandhar

State Versus Pankaj Mishra

S/o Mahadev Mishra
C/o Somnath Inderpal
Mandi Frentan Ganj,
Jallandhar City,

Affidavit

I, Pankaj Mishra S/o Mahadev Mishra C/o Somnath

Inderpal Mandi Frentan Ganj, Jallandhar City, do
hereby solemnly affirm and declare as under:-

1. That the present Petition for grant of the

anticipatory bail, has been drafted on the
instructions of the Deponent/petitioner.

2. That this is first bail application and no such

or similar bail application either is pending or
has been decided by any competent court of law.

144
 Deponent
Verification:-

It is verified that above noted contents of para

no. 1 to 2 is true and correct to the best of my
knowledge and belief and nothing has been concealed
therein.
Place: Ludhiana
Date: /5/2006
Deponent

145
In the court of Sh. K.K. Jain, JMIC, Ludhiana

State Vs. 1. Swaran Singh

2. Gurmukh Singh
Both sons of Sh. Dhani Ram,
3. Satpal Singh
s/o Sh. Swaran Singh
All residents of
Village Lohara,
Tehsil & Distt. Ludhiana.

FIR No. 93/12-5-2006

U/s 325/323/427/34 IPC,
P/S. Shimlapuri,
Ludhiana.

Application for seeking direction to SHO of Police

station Shimlapuri, Ludhiana, to effect the
arrest of accused No. 3 Satpal Singh.

Sir,
The applicant/complainant respectfully submits
as under:-

1. That the above noted FIR was registered at the

instance of Nirmal Singh s/o Sh. Labh Singh R/o
village Lohara, Police Station Shimlapuri,
Ludhiana, as all the accused persons committed
aforesaid offence.

146
2. That the accused No. 3 Satpal Singh s/o Sh.
Swaran Singh who is an army personnel and is having
influence over the local police and due to the
influence of the accused No. 3, the officials of
police station Shimlapuri, are hand in glove with
the accused persons and due to close proximity
with the accused, Satpal Singh with police
officials, the police officials are not effecting
the arrest of said Satpal Singh who is openly
proclaiming that police officials are in his pocket
and nobody on the earth can effect his arrest. It
is pertinent to mention here that Satpal Singh is
extending threats to the complainant/applicant
Nirmal Singh either to withdraw aforesaid FIR or to
ready to face the dire consequences.

It is, therefore, accordingly prayed that

the SHO of Police station Shimlapuri, Ludhiana may
kindly be directed to effect the arrest of the
accused Satpal Singh s/o swaran Singh and necessary
direction may also please be given to safeguard the
life and liberty of the applicant as well as his
family.

Applicant/complainant
Nirmal Singh
S/o Sh. Labh Singh,
Village Lohara,
P.S. Shimlapuri,
Ludhiana

147
148
In The Court Of Sessions Judge, Jallandhar

State Versus Pankaj Mishra

S/o Mahadev Mishra
C/o Somnath Inderpal
Mandi Frentan Ganj,
Jallandhar City,

FIR. No. Not known

U/s. No Known,
P/S. Division No.3,
Jallandhar,

Application u/s 438 Cr.P.C.for the grant of

Anticipatory Bail

Sir,

The petitioners respectfully submit as under:-

1. That the petitioner is peace-loving

citizen of India and has never been involved in any
criminal activities.

2. That one Vinod Kumar and the petitioner are

working with Somnath Inderpal for long time and due
to some trifle matter arose between them, Vinod
Kumar is extending threats with dire consequences
to the petitioner and he also threats the

149
petitioner to involve him in some non-bailable
offence.

3. That the petitioner is innocent and he has

apprehension to be falsely implicated by Vinod
Kumar.

4. That the petitioner is outsider and Vinod Kumar

is local so he is taking advantage of situation and
extending threats against the petitioner.

5. That Applicant undertakes to abide by all the

terms and conditions imposed by this Hon’ble Court
while granting them bail.

It is, therefore, prayed that the petitioner may be

granted anticipatory bail and in the meantime the
arrest of the petitioner be stayed in the interest
of justice.

Petitioners
Through Counsel

Place:- Ludhiana A.K.Giri,

Date: /05/2006 Advocate

150
In The Court Of Sessions Judge, Ludhiana

Harminder Kaur

Versus

Anokh Singh s/o Karam Singh,

Affidavit

I, Anokh Singh s/o Karam Singh, village Chando

Kalan, Tehsil Ratia, Distt.Fathiyabad, Haryana, do
hereby solemnly affirm and declare as under:-

1. That the present Petition for grant of the

anticipatory bail, has been drafted on the
instructions of the Deponent/petitioner.

2. That this is first bail application and no such

or similar bail application either is pending or
has been decided by any competent court of law.

Deponent
Verification:-

It is verified that above noted contents of para

no. 1 to 2 is true and correct to the best of my

151
knowledge and belief and nothing has been concealed
therein.

Place: Ludhiana
Date: 23/5/2006
Deponent

152
In The Court Of Sessions Judge, Ludhiana

Harminder Kaur d/o Balbir Singhw/o Mandip Singh s/o

Anokh Singh Village Chando Kalan, Tehsil Ratia,
Distt. Fatiabad, Haryana, at present: Village
Saphipura, Tehsil Jagraon, Distt. Ludhiana.

Complainant

Versus

1. Anokh Singh s/o Karam Singh,

2. Kulwant Kaur @ Narinder Kaur w/o Anokh Singh
s/o Karam Singh,
3. Karamjit Kaur d/o Anokh Singh s/o Karam Singh,
All residents of village Chando Kalan, Tehsil
Ratia, Distt.Fathiyabad, Haryana.

4. Baljit Kaur w/o Amarjit Singh s/o Harjinder

Singh village Slamepura, Tehsil Jagraon, Distt.
Ludhiana. At present resident of Sidhwan Bet,
Tehsil Jagraon, Distt. Ludhiana.

Petitioners
Note: This is the first bail application.

Bail application u/s 438 Cr. P. C.

Sir,

The petitioners respectfully submit as under:-

153
1. That the petitioners are peace-loving
citizen of India and he has never been indulged in
any nefarious activities. The petitioners have been
summoned to face the trial by the court of Sh.
GOPAL ARORA, PCS, JMIC, JAGRAON, IN THE TITLE CASE
“ HARMINDER KAUR VS. MANDIP SINGH ETC.” COMPLAINT
U/S 406/498A/323/34 IPC, WHICH IS PENDING FOR 29-5-
2006.

2. That petitioner No.1 is father-in-law,

petitioner No. 2 is mother-in-law, petitioners No.
3 and 4 are sister-in-law of the complainant.

2. That the petitioners are innocent persons and

have not committed any offence. There was no
specific entrustment of dowry to the petitioners.
Rather the complainant is a hot-tempered lady and
she used to quarrel with petitioners and causing
harassment on petty matters at the instance of her
parents. The petitioners tried their level best to
persuade to join matrimonial home and even convened
the Panchayat but the she refused to do so.

3. That the offence u/s 406/498-A/323/34 IPC are

not made out against he petitioners but as these
offences are no-bailable, thus the petitioners have
apprehension and reason to believe that they will
be sent to judicial by the Ld. Trial Court on their
appearance in the said court and if they arrested
would suffer undue humiliation and harassment for
no fault of them. Thus the grant of anticipatory
bail to the petitioners is interest of law, justice
and equity.

154
4. That the petitioners come of respectable
family and the image of them may be lowered by the
above said activities.

5. That Applicants undertake that they will abide

by all the terms and conditions imposed by this
Hon’ble Court while granting them anticipatory
bail.

It is, therefore, prayed that the petitioners be

allowed anticipatory bail and the court of Sh.
Gopal Arora, JMIC, Jagraon, be directed to release
the petitioners on bail in the event of their
appearance in the court. It is further prayed that
till the final disposal of this application the
arrest of the petitioners may kindly be stayed in
the interest of justice.

Petitioners
Through Counsel

Place:- Ludhiana Bikram Pal Binder

Date:23/05/2006 Advocate

155
In The Court Of Sessions Judge, Ludhiana

State Versus Jyoti Bansal

FIR. No. Not known

U/s.406/498-A IPC,
P/S. Haibowal
Ludhiana

Affidavit

I, Jyoti Bansal w/o Sh. Lalit Bansal s/o Sh. Suresh

Bansal r/o Backside Aggarwal Dharamsala, Handia
Bazar, Barnala, do hereby solemnly affirm and
declare as under:-

1. That the present Petition for grant of the

anticipatory bail, has been drafted on the
instructions of the Deponent/petitioner.

2. That this is first bail application and no such

or similar bail application either is pending or
has been decided by any competent court of law.

Deponent
Verification:-

It is verified that above noted contents of para

no. 1 to 2 is true and correct to the best of my

156
knowledge and belief and nothing has been concealed
therein.

Place: Ludhiana
Date:
Deponent

157
In The Court Of Sessions Judge, Ludhiana

State Versus Sangeeta Bansal

FIR. No. Not known

U/s.406/498-A IPC,
P/S. Haibowal
Ludhiana

Affidavit

I, Sangeeta Bansal w/o Rakesh Bansal r/o 9623/1

Gali No.9, Joshi Nagar, Haibowal, Ludhiana do
hereby solemnly affirm and declare as under:-

1. That the present Petition for grant of the

anticipatory bail, has been drafted on the
instructions of the Deponent/petitioner.

2. That this is first bail application and no such

or similar bail application either is pending or
has been decided by any competent court of law.

Deponent
Verification:-

It is verified that above noted contents of para

no. 1 to 2 is true and correct to the best of my

158
knowledge and belief and nothing has been concealed
therein.

Place: Ludhiana
Date:
Deponent

159
In The Court Of Sessions Judge, Ludhiana

State Versus Asha Rani & Another

W/o Surinder Pal Gupta

FIR. No. Not known

U/s.406/498-A IPC,
P/S. Haibowal
Ludhiana

Affidavit

I, Asha Rani w/o Later Surinder Pal Gupta r/o B-

XXXIV-4418, Durgapuri, Haibowal, Ludhiana do
hereby solemnly affirm and declare as under:-

1. That the present Petition for grant of the

anticipatory bail, has been drafted on the
instructions of the Deponent/petitioner.

2. That this is first bail application and no such

or similar bail application either is pending or
has been decided by any competent court of law.

Deponent
Verification:-

It is verified that above noted contents of para

no. 1 to 2 is true and correct to the best of my

160
knowledge and belief and nothing has been concealed
therein.

Place: Ludhiana
Date:
Deponent

161
In The Court Of Sessions Judge, Ludhiana

State Versus 1. Asha Rani

w/o Late Surinder Pal Gupta

2.Atul Gupta
s/o Late Sh. Surinder Pal Gupta,
residents of B-XXXIV-4418, Durgapuri, Haibowal,
Ludhiana

FIR. No. Not known

U/s.406/498-A,
P/S. Haibowal,
Ludhiana

Application u/s 438 Cr.P.C.for the grant of

Anticipatory Bail

Sir,

The petitioners respectfully submit as under:-

1. That the petitioners are peace-loving

citizen of India.

2. That the son of the petitioner No. 1 and

brother of petitioner No. 2 namely Rohit Gupta was
married with one Bindia d/o Sh. Subhash Chander of
Durgapuri, Haibowal, Ludhiana on 29-10-2004 as per
Hindu Rites and Ceremonies.

162
3. That the petitioner No. 1 has 3 daughters in
which 2 are married and one is mentally retarded
and living with both the petitioners.

4. That due to the different temperaments and

nature and due to the interference of the mother of
Bindia, Rohit and Bindia could not adjust with each
other and used to quarrel with each other. On 21-8-
2005 the petitioner No. 1 disinherited both them
and on 31-8-2005 the petitioner No. 1 moved a
complaint against his son Rohit, daughter-in-law
Bindia, Neelam Rani, mother of Bindia, Lalit Kumar
and Shyam Gupta sons of Subhash Chander. Copy of
the same is attached herewith.

5. That now said Bindia has moved a false

compliant against the petitioners, just for
grabbing the property of the petitioners.

6. That on the said complaint the police of P.S.

Haibowal is raiding on the house of the petitioners
and searching for the petitioners to arrest them in
a non-bailable and cognizable offence.

7. That the petitioners come of respectable

family and the image of them may be lowered by the
above said activities.

8. That Applicants undertake that they will abide

by all the terms and conditions imposed by this
Hon’ble Court while granting them bail.

It is, therefore, prayed that the petitioners may

be granted anticipatory bail and in the meantime

163
the arrest of the petitioners may be stayed in the
interest of justice.

Petitioners
Through Counsel

Place:- Ludhiana G.S. Arora,

Date:20/05/2006 Advocate

164
In The Court Of Ld. Sessions Judge, Ludhiana

State Versus Kajal

W/o Surinder Singh
R/o New Jagdev Nagar,
Near Siyal Vidyala School
Giaspura, Ludhiana at
Present Gali No.8, Sangat
Wali Gali,Baba Deep Singh
Nagar, Ludhiana

FIR. No. 5/2004

U/s.323/341/506 IPC,
P/S. Shimlapur,
Ludhiana

Affidavit

I, Kajal W/o Surinder Singh R/o New Jagdev Nagar,

Near Siyal Vidyala School Giaspura, Ludhiana at
Present Gali No.8, Sangat Wali Gali,Baba Deep Singh
Nagar, Ludhiana do hereby solemnly affirm and
declare as under:-

1. That the present Petition for grant of the

anticipatory bail, has been drafted on the
instructions of the Deponent/petitioner.

2. That this is first bail application and no such

or similar bail application either is pending or
has been decided by any competent court of law.

165
 Deponent
Verification:-

It is verified that above noted contents of para

no. 1 to 2 is true and correct to the best of my
knowledge and belief and nothing has been concealed
therein.

Place: Ludhiana
Date: 12/05/2006
Deponent

166
167
3. That the absence of applicant was neither will
for nor intentional rather due the reason stated
above.

4. That the father-in-law of the petitioner is

threatening him to register a case against the
petitioner as he wants involve the petitioner in
some non-bailable offence by going against the wish
of the bride Ruchikal Rawat.

5. That the petitioner has apprehension that

police may arrest him at any time at the instance
of the Jagat Singh Rawat.

6. That the applicant/petitioner undertake to

abide by all the terms and conditions as may be
imposed by this hon’ble court while granting them
on bail.

It is, therefore, prayed that the petitioner may be

granted anticipatory bail and in the meantime the
arrest of the petitioner be stayed in the interest
of justice.

Petitioner

Through Counsel

Place:- Ludhiana A.K.Giri,

Date:11/05/2006 Advocate

168
169
In The Court Of Sessions Judge, Ludhiana

State Versus Gurvinder Singh

S/o Surjit Singh
R/o H.No. 482,
Street No. 1,
Karamsar Colony,
Tibba Road,
Ludhiana

FIR. No. Not known

U/s. Not Known
P/S. Basti Jodhewal
Ludhiana

Affidavit

I, Gurvinder Singh S/o Surjit Singh R/o H.No. 482,

Street No. 1, Karamsar Colony, Tibba Road, Ludhiana
Ludhiana do hereby solemnly affirm and declare
as under:-

1. That the present Petition for grant of the

anticipatory bail, has been drafted on the
instructions of the Deponent/petitioner.

2. That this is first bail application and no such

or similar bail application either is pending or
has been decided by any competent court of law.
Deponent

170
Verification:-
It is verified that above noted contents of para
no. 1 to 2 is true and correct to the best of my
knowledge and belief and nothing has been concealed
therein.

Place: Ludhiana
Date: 11/05/2006
Deponent

171
In The Court Of Sessions Judge, Ludhiana

State Versus Gurvinder Singh

S/o Surjit Singh
R/o H.No. 482,
Street No. 1,
Karamsar Colony,
Tibba Road,
Ludhiana

FIR. No. Not known

U/s. Not Known
P/S. Basti Jodhewal
Ludhiana

Note: That this is first bail application.

Application u/s 438 Cr.P.C.for the grant of

Anticipatory Bail

Sir,

The Petitioner respectfully submit as under:-

1. That the petitioner law abiding citizen of

India.

2. That the petition is matured being of

about 24 years of age and he has married with
Ruchika Rawat (aged 24 years) D/o Jagat Singh Rawat

172
r/o Distt. Udham Singh, Nagar, Uttranchal.
Photocopies of School Certificates of both
supporting age is attached herewith.

3. That marriage has been solemnized as per Sikh

Rites and tradition with full consent from both
sides at Dhadari Kalan, Gurudwara, Ludhiana on 7-5-
2006.

4. That the father-in-law of the petitioner is

threatening him to register a case against the
petitioner as he wants involve the petitioner in
some non-bailable offence by going against the wish
of the bride Ruchikal Rawat.

5. That the petitioner has apprehension that

police may arrest him at any time at the instance
of the Jagat Singh Rawat.

6. That the applicant/petitioner undertake to

abide by all the terms and conditions as may be
imposed by this hon’ble court while granting them
on bail.

It is, therefore, prayed that the petitioner may be

granted anticipatory bail and in the meantime the
arrest of the petitioner be stayed in the interest
of justice.

Petitioner

Through Counsel

173
Place:- Ludhiana A.K.Giri,
Date:11/05/2006 Advocate

174
In The Court Of Sessions Judge, Ludhiana

State Versus Sukhminder Singh etc.

.

FIR. No. Not known

U/s. Not Known
P/S. Division No. 7,
Police Post Khasi
Kalan,
Tajpur Road,
Ludhiana

Affidavit

I,Balraj Singh S/o Sukhminder Singh, resident of

VPO. Khasi Kalan, Ludhiana do hereby solemnly
affirm and declare as under:-

1. That the present Petition for grant of the

anticipatory bail, has been drafted on the
instructions of the Deponent/petitioner.

2. That this is first bail application and no such

or similar bail application either is pending or
has been decided by any competent court of law.
Deponent
Verification:-

175
It is verified that above noted contents of para
no. 1 to 2 is true and correct to the best of my
knowledge and belief and nothing has been concealed
therein.

Place: Ludhiana
Date: 08/05/2006
Deponent

176
IN THE COURT OF SH. GURBIR SINGH, ADDL.SESSIONS
JUDGE, LUDHIANA

B.A. 488/10-5-2006

State Versus 1. Sukhminder Singh

S/o Late Sh. Sucha Singh

2. Paramjit Kaur
W/o Sukhmider Singh

3. Balraj Singh
S/o Sukhminder Singh,

All residents of
VPO. Khasi Kalan,
Ludhiana.

FIR. No. Not known

U/s. Not Known
P/S. Division No. 7,
Police Post Khasi Kalan,
Tajpur Road,
Ludhiana

The order was passed by the Hon'ble court as

below:-
“ This application received by the entrustment it
be registered. Notice be issued to the State from
23-5-2006. Police Record be also produced on said
date. In the meantime in the event of arrest all

177
the applicants in this case they be given three day
advance notice.

Sd/-

Gurbir Singh
A.S.J.
10-5-2006.
Attested to be true copy.

Har Parkash Singh, Advocate

178
In The Court Of Hon'ble Distt. & Sessions Judge,
Ludhiana

State Versus Gagandeep Singh

S/o Hakam Singh
R/o Basant Nagar,
Gali No. 10,
New Shimlapuri,
Ludhiana

FIR. No. 38/ 28-1-06,

U/s. 498-A, 506 IPC,
P/S. Sadar (khanna),
Ludhiana

Affidavit

I, Gagandeep Singh S/o Hakam Singh R/o Basant

Nagar, Gali No. 10, New Shimlapuri, Ludhiana, do
hereby solemnly affirm and declare as under:-

1. That the present Petition for grant of the

anticipatory bail, has been drafted on the
instructions of the Deponent/petitioner.

2. That this is first bail application and no such

or similar bail application either is pending or
has been decided by any competent court of law.

179
 Deponent
Verification:-
It is verified that above noted contents of para
no. 1 to 2 is true and correct to the best of my
knowledge and belief and nothing has been concealed
therein.

Place: Ludhiana
Date: 01/05/2006
Deponent

180
In The Court Of Hon'ble Distt. & Sessions Judge,
Ludhiana

State Versus Gagandeep Singh

S/o Hakam Singh
R/o Basant Nagar,
Gali No. 10,
New Shimlapuri,
Ludhiana

FIR. No. 38/ 28-1-06,

U/s. 498-A, 506 IPC,
P/S. Sadar (khanna),
Ludhiana

Application u/s 438 Cr.P.C.for the grant of

Anticipatory Bail

Sir,

The Petitioner respectfully submits as under:-

1. That the petition is peace loving and law

abiding citizen of India and is never indulged in
any criminal activity.

2. That the applicant is innocent and has been

falsely implicated in the above noted case.

3. That at the instance of the wife of the

petitioner i.e. Mandeep Kaur and her father Baldev

181
Singh, in collusion with each registered the above
said FIR, and accordingly the police of P.S. Sadar
(Khanna) is running after the applicant/petitioner
to arrest him. The police is also raiding the house
of the applicant and threatening his other family
members to arrest the petitioner.

4. That the said FIR has been registered by Maneep

Kaur and her father only to harass the petitioner
and with an intention to involve him in non-
bailable offence as nothing has been ever demanded
by the petitioner side ever and both the petitioner
and his wife have been living with mutual consents
and no disharmony has ever been arose between them.

5. That the petitioner comes of respectable family

and the image of him may be lowered by the above
said activities.

6. That the other accused has already been granted

bail by the Hon'ble court of Sh. B.S. Sodhi, ASJ,
Ludhiana.

7. That the applicant/petitioner undertakes to

abide by all the terms and conditions as may be
imposed by this hon’ble court while granting him
bail.

It is, therefore, prayed that the petitioner may be

granted anticipatory bail and in the meantime the
arrest of the petitioner may be stayed in the
interest of justice.

182
 Petitioner

Through Counsel

Place:- Ludhiana Subhash Thakur

Date: 01/05/2006 Advocate

183
184
In The Court Of Hon'ble Distt. & Sessions Judge,
Ludhiana

State Versus Balbir Singh

S/o S. Partap Singh
R/o 98, Gurunanak Nagar,
St. No. 1, Daba Lohara Road,
Ludhiana

FIR. No. 86/23-3-2006,

U/s. 420/467/468/471/120-B
IPC,
P/S. Division No. 5,
Ludhiana

Note:-That this is first bail application

and no such or similar bail application
either is pending or has been decided
by any other competent court of law.

Application u/s 438 Cr.P.C.for the grant of

Anticipatory Bail
Sir,
The Applicant/accused respectfully submits as
under:-
1. That the petition is peace loving and law
abiding citizen of India and is never indulged in
any criminal activity.

2. That the applicant/accused is innocent and has

been falsely implicated in the above noted case.

185
3. That the applicant had purchased a plot No.
1116, situated at Sector-38/39 Samrala Road,
Ludhiana by way of executed General Power of
Attorney from Bhupinder Singh S/o Mukand Singh in
the year 2005. As the allotment of that property
was in the name of Bhupinder Singh and some
installments are due towards the Bhupinder Singh
from the PUDA.
4. That the applicant sold that property to one
Sukhwinder Singh who was also sold that property to
Sham Lal and Vivek Bedi.

5. That now the applicant came to know that the

said Bhupinder Singh has been expired on 27-6-1996
and one forged person executed the General Power of
Attorney in the name of the applicant by showing
himself as Bhupinder Singh.

6. That now the plot is vested in the hand of PUDA

who delivered the possession of the plot to the
Harinder Kaur w/o Bhupinder Singh who was the real
allottee of that plot. As applicant is innocent and
have nothing to do with the above said offences,
but the above said case was registered against the
applicant and the police of P.S. Division No. 5 is
raiding on the house of the applicant to arrest him
and the above said FIR.
7. That the applicant/Accused undertakes to abide
by all the terms and conditions imposed by this
hon’ble court while releasing him on bail.
8. That the Applicant/Accused undertakes that he
will not leave India without the prior permission
of this Hon'ble court.

186
9. That the accused/applicant further undertakes
that he will not tamper with the prosecution
evidence.

It is, therefore, prayed that the applicant/accused

may be granted anticipatory bail and in the
meantime the arrest of the applicant may be stayed.

Applicant/accused
Through Counsel
Place:- Ludhiana G.S.Arora,
Date: 27/2/2006 Advocate

187
In The Court Of Hon'ble Distt. & Sessions Judge,
Ludhiana

State Versus Balbir Singh

FIR. No. 86/23-3-2006,

U/s. 420/467/468/471/120-B
IPC,
P/S. Division No. 5,
Ludhiana

Affidavit

I, Balbir Singh S/o S. Partap Singh R/o 98,

Gurunanak Nagar, St. No. 1, Daba Lohara Road,
Ludhiana do hereby solemnly affirm and declare
as under:-

1. That the present Petition for grant of the

anticipatory bail, has been drafted on the
instructions of the Deponent/petitioner.

2. That this is first bail application and no such

or similar bail application either is pending or
has been decided by any competent court of law.

Deponent
Verification:-
It is verified that above noted contents of para
no. 1 to 2 is true and correct to the best of my

188
knowledge and belief and nothing has been concealed
therein.
Place: Ludhiana
Date: 27/3/2006
Deponent

189
190
In The Court Of Hon'ble Distt. & Sessions Judge,
Ludhiana

State Versus Anju Devi W/o Late

R/o Sarpanch Colony, Mundian Kalan, Ludhiana

FIR. No. 170/26-9-2004,

U/s. 304B/34 IPC,
P/S. Div. No. 7,
Ludhiana

Note:-That this is first bail application

and no such or similar bail application
either is pending or has been decided
by any other competent court of law.

Application u/s 438 Cr.P.C.for the grant of

Anticipatory Bail

Sir,

The Petitioner respectfully submits as under:-

1. That the petition is peace loving and law

abiding citizen of India and is never indulged in
any criminal activity.

2. That the applicant/accused is innocent and has

been falsely implicated in the above noted case.

191
3. That the applicant/accused is widow having a
female issue, is a daily wage worker in a factory
and at the time of alleged occurrence she was on
duty and she has nothing to do with the event.

4. That the name of her was got recorded only to

involved her and she apprehends that if she is
arrested by the police her minor child will get
orphan because none is to take care of her minor
child.
5. That the applicant/petitioner undertakes to
abide by all the terms and conditions as may be
imposed by this hon’ble court while granting him
bail.

6. That the Applicant/Accused undertakes that he

will not leave India without the prior permission
of this Hon'ble court.

It is, therefore, prayed that the applicant/accused

may be granted anticipatory bail and in the
meantime the arrest of the applicant may be stayed.

Applicant/accused

Through Counsel

Place:- Ludhiana
Date: 14/2/2006 Advocate

192
In the court Distt.& Session Judge, Ludhiana.

State Versus Nand Lal Singh S/o Vidya

Singh,
R/o H.No. K-II-478,
Gali No. 2, Guru Teg Bahadur
Nagar, New Bari Mundian (Kalan), Ludhiana.

FIR.222/dt 12-12-2005.
U/s 323/354/506/34 IPC &
452 IPc
P.S. Div. No. 7,
Ludhiana

Application u/s 438 of Cr.P.C. for the grant of

Anticipatory Bail
Sir,

The petitioner/applicant respectfully prays as

under:-

1. That the Petitioners are peace loving and law

abiding citizens of India as they have never been
indulged in any criminal activity.

2. That the complainant who is also resident of

the same Mohalla was indulged in immoral activities
with someone in the same mohalla. The mohallawalas
picked up to that lady with some unknown person and
they reported the matter to the police of p.s.
Division No. 7, and the police reached the spot and
arrested both of them in suspicious condition, but

193
the complainant felt sorry before the whole
Mohallawalas and matter got patched up.

3. That petitioner is the respected person in the

Mohalla, unfortunately he involved into the above
said matter in the mahalla. The complainant, due to
above said incident became inimical towards the
petitioner and she lodged a false report against
the petitioner on 24-11-2005 under bailable
offence, but after sometime the police of p.s. Div.
No. 7 in connivance with complainant subsequently
added the section 452 IPC to make the offence non-
bailable and since then the police of division no.
7 is raiding on the hose of the petitioner to
arrest him.

194
In The Court Of Hon'ble Distt. & Session Judge,
Ludhiana

State Versus 1. Gurdeep Lal

S/o Parmanand
2. Sudesh Rani
W/o Gurdeep Lal,
3. Rajinder Kumar
S/o Gurdeep Lal
4. Poonam
All R/o Baba Namdev Colony,
Main Gali, Jagirpur,
Ludhiana

FIR No. 20/28-1-2006

U/s 406/498-A/323/34 IPC
P.S. Basti Jodhewal,
Ludhiana.

Application u/s 438 Cr.P.C. for Anticipatory Bail

Most respectfully Showeth,

The petitioners respectfully submit as under:-

1. That the Petitioners are peace loving and law

abiding citizens of India as they have never been
indulged in any criminal activity.

2. That at the instance of petitioner Rajinder

Kumar’s wife namely Jyoti the police of P.S. Basti
Jodhewal, are unnecessarily raiding on the house of

195
the Applicants/petitioners and wants to arrest them
in any cognizable offence.

3. That earlier all the applicants/accused persons

were granted anticipatory bail by three days notice
to be given in advance by the court of Sh. Sanjeev
Berry, Addl. Sessions Judge, Ludhiana on 6-1-2006,
but at that time no FIR was lodged and subsequently
above said FIR was lodged u/s 406/498-A/323/34 IPC.

4. That the applicants are innocent and have been

falsely implicated in the above said case /FIR.
5. That the said 3 days notice has been give to
the applicants about the lodged FIR.
6. That the petitioners are ready to join the
investigation if any or as may be directed by this
Hon'ble court while granting him bail
7. That the applicants/petitioners undertake to
abide by all the terms and conditions as may be
imposed by this hon’ble court while granting him
bail.
8. That the Applicants/Accuseds undertake that
they will not leave India without the prior
permission of this Hon'ble court.

It is, therefore, respectfully prayed that

necessary direction may kindly be given to the
concerned police to stay their arrest and in the
event of their arrest petitioner may kindly be
released on bail in the interest of justice

Applicants/Accused

196
Place:- Ludhiana Through Counsel
Date: 30/1/2006 A.K. Giri,
Advocate

197
In The Court Of Hon'ble Distt. & Session Judge,
Ludhiana

State Versus 1. Gurdeep Lal

S/o Parmanand
2. Sudesh Rani
W/o Gurdeep Lal,
3. Rajinder Kumar
S/o Gurdeep Lal
4. Poonam
All R/o Baba Namdev Colony,
Main Gali, Jagirpur,
Ludhiana

FIR No. 20/28-1-2006

U/s 406/498-A/323/34 IPC
P.S. Basti Jodhewal,
Ludhiana.

Affidavit

I, 3. Rajinder Kumar S/o Gurdeep Lal, R/o All

R/o Baba Namdev Colony, Main Gali, Jagirpur,
Ludhiana, do hereby solemnly affirm and declare as
under:-

1. That the present Petition for grant of the

anticipatory bail, has been drafted on the
instructions of the Deponents/petitioners.

Deponent

198
Verification:-
It is verified that above said affidavit is true
and correct to the best of my knowledge and belief
and nothing has been concealed therein.

Place: Ludhiana
Date: 30/1/2006 Deponent

199
In The Court Of Hon'ble Distt. & Session Judge,
Ludhiana

State Versus Angrej Kaur

W/o Col. Karnail Singh Sekhon, R/o H.No.78/22,
Guru Amardass Nagar,
Near Village Sunet,
Ludhiana.

FIR. No.: 8/12-01-2005

U/s.420/468/471/120-B IPC.
P/S- Sarabha Nagar,
Ludhiana.

Bail Application U/S 438 of Cr.P.C. for grant of

Anticipatory Bail.

Respectfully Showeth,

1. That this the above titled case is pending in

the court of Sh. K.K. ,JMIC, Ludhiana, and is
fixed for

2. That earlier the above noted case was fixed for

15.10.2005 and on same day the accused Iqbal Singh
could not come present in the said court due to his
serious illness as he was suffering from Rhumatic
fever and was advised to take bed rest for al least
2 weeks i.e. from 12-10-2005 to onward under the
medical supervision. A photocopy of Medical
Certificate is attached herewith.

200
3. That due to the reason as stated above the
accused could not present in the court of Sh. K.K.
JMIC, Ludhiana and the court issued warrant against
the accused.

4. That the absence of accused was neither

intentional nor willful rather due to the reason as
stated above.

5. That the petitioner undertakes to be restrained

and is ready to abide by all the terms and
conditions imposed by this Hon’ble court while
granted bail to him.

It is, therefore, respectfully prayed that the

petitioner may kindly be granted anticipatory bail
and his arrest may be stayed in the interest of
justice.

Petitioner/Accused

Through Counsel
Place:- Ludhiana Subhash Thakur
Date:-10/11/2005 Advocate

201
In The Court Of Hon'ble Session Judge, Ludhiana

State Versus Geeta Devi,

W/o Sh. Saryug Parsad,
R/o H.No. 3708,
EWS Colony,
Sector-32
Chandigarh Road,
Ludhiana.
FIR. No.: unknown
U/s. Unknown.
P/S-Division No. 7,
Ludhiana.

Affidavit

I, Geeta Devi W/o Sh. Saryug Parsad,R/o H.No. 3708,

EWS Colony,Sector-32, Chandigarh Road,Ludhiana do
hereby solemnly affirm and declare as under: -

1. That the present Petition/application for grant

of anticipatory bail has been drafted on the
instructions of the Deponent/
accused/applicant.

2. This is first bail application and no such or

similar bail application either has been filed or
has been decided by any other court of law.

Deponent
Verification:-

Verified at Ludhiana on this 24th day of October

2005, that above noted content given by me is truce

202
and correct to the best of my knowledge and belief
and nothing has been concealed therein.

Deponent

203
In The Court Of Hon'ble Session Judge, Ludhiana

State Versus Geeta Devi,

W/o Sh. Saryug Parsad,
R/o H.No. 3708,
EWS Colony,
Sector-32
Chandigarh Road,
Ludhiana.

FIR. No.: unknown

U/s. Unknown.
. P/S-Division No. 7,
Ludhiana.

Bail Application U/S 438 of Cr.P.C. for grant of

Anticipatory Bail.

Respectfully Showeth,

1. That the petitioner is peace-loving and

innocent citizen of India and has been falsely
implicated in the above noted case.

2. That about more than two years back my husband

Saryug Parsad age 40 and daughter Kanchan Kumari
aged 18 years had been kidnapped and the petitioner
had been requesting the police of division no.7 to
find out of the kidnapped persons. But it is the
police of the Division No.7 are taking no notice of
the requests of the petitioner and on the contrary

204
of this the police of Division No.7, persecuting
the petitioner and her family members and the
police of Division No. 7 have been unnecessarily
raiding on the house of the petitioner and
threatening the petitioner and her other family
members to arrest in some non-bailable offence to
be registered against the petitioner. And, thus,
the petitioner as well as her family apprehend
their arrest and needs protection.

3. That the petitioner undertakes to be restrained

and is ready to abide by all the terms and
conditions imposed by this Hon’ble court while
granted bail to them.

It is, therefore, respectfully prayed that the

petitioner may kindly be granted anticipatory bail
and during the pendency of bail application their
arrest may be stayed in the interest of justice.

Applicant/Accused

Through Counsel
Place:- Ludhiana Subhash Thakur
Date:-24/10/2005 Advocate

205
In The Court Of Hon'ble Session Judge, Ludhiana

Jeetendera Anthony Fernandes

Versus

M/s Hathway Cable and Datacom Pvt. Ltd.

In Re: Complaint u/s 138 N.I. Act.

Affidavit

I, Jeetendra Anthony Fernandes S/o Anthony Rafel

Fernandes

R/o 2, Yogita Niwas, Datta Takdi, Majaswadi, New

Jogeshwari Vikroli Link Road, Jogeshwari East,
Mumbai -400060 do hereby solemnly affirm and
declare as under: -

1. That the present Petition/application for grant

of anticipatory bail has been drafted on the
instructions of the Deponent/accused/applicant.

2. This is first bail application and no such or

similar bail application either has been filed or
has been decided by any other court of law.

Deponent
Verification:-

206
Verified at Ludhiana on this 2 th day of October
2005, that above noted content given by me is truce
and correct to the best of my knowledge and belief
and nothing has been concealed therein.

Deponent

207
In The Court Of Hon'ble Session Judge, Ludhiana

State Versus Paramjit Singh @ Pamma.

S/o Kehar Singh
R/o V. Bhinder Kalan,
P.S. Dharmkot,
Distt. Ludhiana.

FIR. No.50/18-5-05
U/s. 15/25/29/60/61/85/ NDPS. Act.
. P/S- Sudar, Distt. Ludhiana.

Affidavit
I, Paramjit Singh @ Pamma S/o Kehar Singh R/o V.
Bhinder Kalan, P.S. Dharmkot, Distt. Ludhiana,
do hereby solemnly affirm and declare as under:-

1. This is first bail application and no such or

similar bail application either has been filed or
has been decided by any other court of law.

Deponent
Verification:-

Verified at Ludhiana on this 18th day of October

2005, that above noted content given by me is truce
and correct to the best of my knowledge and belief
and nothing has been concealed therein.

208
Deponent

209
In The Court Of Hon'ble Distt. & Session Judge,
Ludhiana

State Versus 1. Gulwant Singh

S/o Sh. Mastu Singh,
2. Rupinder Singh
S/o Sh. Gulwant Singh
Both residents of
Village Leela Megh Singh,
Tehsil Jagraon,
Distt. Ludhiana.
FIR. No.13/15-1-2004,
U/s. 406/420/506/409/34 IPC.
P/S Sidhwan Bet,
Distt. Ludhiana.

Note: This is second bail application, first bail

Bail application was withdrawn by the court
Of Sh. D.R. Arora,on 19.3.2005.

Application U/S 438 of Cr.P.C. for the grant of

Anticipatory Bail
Sir,
The petitioners respectfully submit as under:-

1. That the petitioners are law abiding and peace

loving citizens of India and never involved
themselves in any unlawful activities.
2. That the above said case is pending in the
court of Smt. Jatinder Kaur Walia, SDJM and is now
fixed for 12.11.2005.
Initially this FIR was registered under section
406/420/506/34 IPC and the petitioners were

210
arrested in this case and later on they were sent
to judicial lock up and were granted regular bail
by the Court.
3. That now the police have presented the Challan
in the court of Illaqa Magistrate and has added an
additional section 409 IPC. The said offence is
non-bailable. Now the police on the basis of
addition of the said non-bailable section 409 IPC
is out to arrest the petitioners. The petitioners
therefore, apprehend their arrest in this case
again. As section 409 IPC is non-bailable and as
such in case the petitioners surrendered in the
Trial Court then they will not be granted bail and
will rather be sent to judicial lock-up.
4. That petitioners have been falsely implicated
in this case and they have not committed any
offence much less offence under section 409 IPC.
The allegations made in the FIR are totally false
and frivolous.
5. That the petitioners are peace loving citizen
and they have already joined the investigation and
the alleged recovery has already been effected as
the petitioner was granted regular bail after his
police custody and judicial lock up and as such he
is no more required by the police for further
investigation of the case. The Challan has already
been presented in the Trial Court.
6. That the applicants/Accused undertake that they
will abide all the terms and conditions imposed by
this Hon’ble court while releasing him on bail and
shall not tamper with the evidence of the
prosecution in any manner.
Keeping in view of the above said circumstances, it
is, therefore, respectfully prayed that the

211
Applicants/accused may kindly be granted
Anticipatory Bail as provided under section 438
Cr.P.C.
It is further prayed that the arrest of the
petitioners/applicants/accused may kindly be stayed
during the pendency of the present bail application
and direction may be given to the Trial Court to
release the petitioners on bail in the event of
their surrender in the court in the interest of
justice.

Petitioners
Through Counsel
Place:- Ludhiana

Date:- 15 /10/2005 Bikram Pal

Binder,
Advocate

212
In The Court Of Hon'ble Distt. & Session Judge,
Ludhiana

State Versus 1. Gulwant Singh

S/o Sh. Mastu Singh,
2. Rupinder Singh
S/o Sh. Gulwant Singh
Both residents of
Village Leela Megh Singh,
Tehsil Jagraon,
Distt. Ludhiana.
FIR. No.7/8-1-2004,
U/s. 406/420/409 IPC.
P/S Sidhwan Bet,
Distt. Ludhiana.

Note: This is second bail application, first bail

Bail application was withdrawn by the court
Of Sh. D.R. Arora,on 19.3.2005.

Application U/S 438 of Cr.P.C. for the grant of

Anticipatory Bail
Sir,
The petitioners respectfully submit as under:-

1. That the petitioners are law abiding and peace

loving citizens of India and never involved
themselves in any unlawful activities.
2. That the above said case is pending in the
court of Smt. Jatinder Kaur Walia, SDJM and is now
fixed for 12.11.2005.
Initially this FIR was registered under section
406/420 IPC and the petitioners were arrested in
this case and later on they were sent to judicial

213
lock up and were granted regular bail by the
Court.
3. That now the police have presented the Challan
in the court of Illaqa Magistrate and has added an
additional section 409 IPC. The said offence is
non-bailable. Now the police on the basis of
addition of the said non-bailable section 409 IPC
is out to arrest the petitioners. The petitioners
therefore, apprehend their arrest in this case
again. As section 409 IPC is non-bailable and as
such in case the petitioners surrendered in the
Trial Court then they will not be granted bail and
will rather be sent to judicial lock-up.
4. That petitioners have been falsely implicated
in this case and they have not committed any
offence much less offence under section 409 IPC.
The allegations made in the FIR are totally false
and frivolous.
5. That the petitioners are peace loving citizen
and they have already joined the investigation and
the alleged recovery has already been effected as
the petitioner was granted regular bail after his
police custody and judicial lock up and as such he
is no more required by the police for further
investigation of the case. The Challan has already
been presented in the Trial Court.
6. That the applicants/Accused undertake that they
will abide all the terms and conditions imposed by
this Hon’ble court while releasing him on bail and
shall not tamper with the evidence of the
prosecution in any manner.
Keeping in view of the above said circumstances, it
is, therefore, respectfully prayed that the
Applicants/accused may kindly be granted

214
Anticipatory Bail as provided under section 438
Cr.P.C.
It is further prayed that the arrest of the
petitioners/applicants/accused may kindly be stayed
during the pendency of the present bail application
and direction may be given to the Trial Court to
release the petitioners on bail in the event of
their surrender in the court in the interest of
justice.

Petitioners
Through Counsel
Place:- Ludhiana

Date:- 15 /10/2005 Bikram Pal

Binder,
Advocate

215
In The Court Of Hon'ble Distt. & Session Judge,
Ludhiana

State Versus Gulwant Singh & others

Note: This is second bail application, first bail

Bail application was withdrawn by the court
Of Sh. D.R. Arora,on 19.3.2005.

AFFIDAVIT
I, Rupinder Singh S/o Gulwant Singh, Village
Leela Megh Singh,Tehsil Jagraon, Distt. Ludhiana,
do hereby solemnly
affirm and declare as under:-

1. That the present Petition/application for grant

of anticipatory bail has been drafted on the
instructions of the Deponent/accused/applicant.

2. This is second bail application and the first

bail application was withdrawn By the court of Sh.
D.R.Arora, Addl.D.J. Ludhiana On 19.3.2005.

3. That the deponent is competent to swear this

affidavit.

Deponent
Verification:-

216
Verified at Ludhiana on this 15th day of October
2005, that above noted content given by me is truce
and correct to the best of my knowledge and belief
and nothing has been concealed therein.

Deponent

217
 In The Court Of Hon'ble Distt. & Session Judge,
Ludhiana

State Versus 1. Gulwant Singh & others

AFFIDAVIT
I, Rupinder Singh S/o Gulwant Singh, Village
Leela Megh Singh, Tehsil Jagraon, Distt. Ludhiana,
do hereby solemnly
affirm and declare as under:-

1. That the present Petition/application for grant

of anticipatory bail has been drafted on the
instructions of the Deponent/accused/applicant.

2. This is second bail application and the first

bail application was withdrawn By the court of Sh.
D.R.Arora, Addl.D.J. Ludhiana On 19.3.2005.

3. That the deponent is competent to swear this

affidavit.

. . Deponent

Verification:-

218
Verified at Ludhiana on this 15th day of October
2005, that above noted content given by me is truce
and correct to the best of my knowledge and belief
and nothing has been concealed therein.

Deponent

219
In The Court Of Hon'ble Distt. & Session Judge,
Ludhiana

State Versus 1. Gulwant Singh

S/o Sh. Mastu Singh,
2. Rupinder Singh
S/o Sh. Gulwant Singh
Both residents of
Village Leela Megh Singh,
Tehsil Jagraon,
Distt. Ludhiana.
FIR. No.13/15-1-2004,
U/s. 406/420/506/409/34 IPC.
P/S Sidhwan Bet,
Distt. Ludhiana.

Note: This is second bail application, first bail

Bail application was withdrawn by the court
Of Sh. D.R. Arora,on 19.3.2005.

Application U/S 438 of Cr.P.C. for the grant of

Anticipatory Bail
Sir,
The petitioners respectfully submit as under:-

1. That the petitioners are law abiding and peace

loving citizens of India and never involved
themselves in any unlawful activities.
2. That the above said case is pending in the
court of Smt. Jatinder Kaur Walia, SDJM and is now
fixed for 12.11.2005.
Initially this FIR was registered under section
406/420/506/34 IPC and the petitioners were
arrested in this case and later on they were sent

220
to judicial lock up and were granted regular bail
by the Court.
3. That now the police have presented the Challan
in the court of Illaqa Magistrate and has added an
additional section 409 IPC. The said offence is
non-bailable. Now the police on the basis of
addition of the said non-bailable section 409 IPC
is out to arrest the petitioners. The petitioners
therefore, apprehend their arrest in this case
again. As section 409 IPC is non-bailable and as
such in case the petitioners surrendered in the
Trial Court then they will not be granted bail and
will rather be sent to judicial lock-up.
4. That petitioners have been falsely implicated
in this case and they have not committed any
offence much less offence under section 409 IPC.
The allegations made in the FIR are totally false
and frivolous.
5. That the petitioners are peace loving citizen
and they have already joined the investigation and
the alleged recovery has already been effected as
the petitioner was granted regular bail after his
police custody and judicial lock up and as such he
is no more required by the police for further
investigation of the case. The Challan has already
been presented in the Trial Court.
6. That the applicants/Accused undertake that they
will abide all the terms and conditions imposed by
this Hon’ble court while releasing him on bail and
shall not tamper with the evidence of the
prosecution in any manner.
Keeping in view of the above said circumstances, it
is, therefore, respectfully prayed that the
Applicants/accused may kindly be granted

221
Anticipatory Bail as provided under section 438
Cr.P.C.
It is further prayed that the arrest of the
petitioners/applicants/accused may kindly be stayed
during the pendency of the present bail application
and direction may be given to the Trial Court to
release the petitioners on bail in the event of
their surrender in the court in the interest of
justice.

Petitioners

Through Counsel
Place:- Ludhiana

Date:- / /2005 Bikram Pal

Binder,
Advocate

222
In The Court Of Hon'ble Distt. & Session Judge,
Ludhiana

State Versus Visheshwar Thekadar

S/o Mahavir Yadav,
R/o Durga Colony,
St. No.1,
Focal Point,
Ludhiana.

FIR. No.225/12-9-2005,
U/s. 452/323/324/148/149 &
326 IPC.
P/S Focal Point,
Ludhiana.

Application for Anticipatory Bail U/S 438 of

Cr.P.C.

AFFIDAVIT
I, Visheshwar Thekadar S/o Mahavir Yadav, R/o
Durga
Colony, St. No.1, Focal Point, Ludhiana., do hereby
solemnly
affirm and declare as under:-

1. That the present Petition/application for grant

of anticipatory bail has been drafted on the
instructions of the Deponent/accused/applicant.

223
2. This is second bail application and the first
bail application was withdrawn By the court of Sh.
Sanjeev Berry, ASJ, Ludhiana On 30.9.2005.

3. That the deponent is competent to swear this

affidavit.

Deponent
Verification:-

Verified at Ludhiana on this day of

2005, that above noted content given by me is truce
and correct to the best of my knowledge and belief
and nothing has been concealed therein.

Deponent

224
In The Court Of Hon'ble Distt. & Session Judge,
Ludhiana

State Versus Kuldeep Singh

S/o Sadhu Singh
R/o Vallage Rasulpur Jandhi,
Tehsil Jagraon,
Ludhiana.

FIR. No. Not Known

U/s. Not known,
P/S. Sadar Ludhiana. &
P.S. Sidhwan Bet,
Ludhiana

Application for Anticipatory Bail U/S 438 of

Cr.P.C.

Sir,
The Petitioner respectfully submits as under:-

1. That the petition is peace loving and law

abiding citizen of India and is never indulged in
any criminal activity.

2. That at the instance of someone else the police

of P/S. Sadar Ludhiana. & P.S. Sidhwan Bet, is
hunting for the petitioner and raiding on the house
of the petitioner threatening the petitioner to
arrest him in some non-bailing offence.

225
3. That the petitioner comes of a respectable
family and he has apprehension of arrest by the
said police and by doing so his status may be
lowered in the eyes of the society.
7. That the offence u/s 326 has been added by the
police to make the offence non-bailable.
8. That the Applicant/Accused is ready to
cooperate with the investigation authority.
9. That the accused/applicant further undertakes
that he will not tamper with the prosecution
evidence.
11. That the applicant/Accused undertakes that he
will abide all the terms and conditions imposed by
this hon’ble court while releasing him on bail.
12. That the Applicant/Accused undertakes that he
will not leave India without the prior permission
of this Hon'ble court.
It is, therefore, respectfully prayed that the
necessary direction may please be given to the
concerned police officer to stint his arrest and in
the event of arrest, the Applicant/accused be
released on Anticipatory bail in the interest of
justice.

Applicant/Accused

Through Counsel
Place:- Ludhiana

Date:- / /2005 A.K.Giri,

Advocate

226
It is, therefore, respectfully prayed that the
necessary direction may please be given to the
concerned police officer and in the event of arrest
the Applicant/accused be released on Anticipatory
bail in the interest of justice.

Applicant/Accused
Rachpal Singh @ Jaspal Singh
R/o Khalsa Tansport Co., Maglana Road, Makrana,
Distt. Naggor, Rajasthan.

Through Counsel
Place:- Ludhiana Raj Kumar Kaushal,
Date: 22/9/2005 Advocate

227
In The Court Of Hon'ble Distt. & Session Judge,
Ludhiana

State of Punjab Versus Gurmeet Singh

S/o Sh. Harchand Singh,
R/o Vill. Bhainishalu,
P.S. Koomkalan,
Ludhiana.

FIR No.- Unknown,

U/s:- Unknown,
P.S. :- Koomkalan,
Ludhiana.

AFFIDAVIT
I, Gurmeet Singh S/o Sh. Harchand Singh, R/o
Vill.
Bhainishalu, P.S. Koomkalan, Ludhiana, do hereby
solemnly affirm and declare as under:-

1. That the present Petition/application for grant

of anticipatory bail has been drafted on the
instructions of the Deponent/accused/applicant.

2. That this is first Anticipatory bail

application and no such or similar bail application
either has been pending or has been decided by any
other court of law.

3. That the deponent is competent to swear this

affidavit.

228
 Deponent
Verification:-

th
Verified on this day of September 2005, that
above noted content given by me is truce and
correct to the best of my knowledge and belief and
nothing has been concealed therein.

DEPONENT

229
In The Court Of Hon'ble Distt. & Session Judge,
Ludhiana

Mohinder Singh Versus Balram & etc.

In Re: Complaint Case u/s 407/506/34 IPC.

AFFIDAVIT

I, Raj Kumar, Advocate, Distt. court Ludhiana, do

hereby
Solemnly affirm and declare as under:-

1 That this is first Anticipatory bail

application in this case and no such or similar
bail application either is pending or has been
decided by any competent court of law.

Deponent
Verification:-

Verified on this 22nd day of September 2005, that

above noted content given by me is truce and
correct to the best of my knowledge and belief and
nothing has been concealed therein.

DEPONENT

230
In The Court Of Hon'ble Distt. & Session Judge,
Ludhiana

State Versus Datjit Kaur D/o Jagjit Singh,

R/o Atam Nagar,St. No. 7,
Jagraon.

FIR No. 239/29.7.2004

U/s 452/342/186/353/149/120-B IPC
P.S. Jagroan.

AFFIDAVIT
I, Raj Kumar, Advocate, Distt. court Ludhiana, do
hereby
Solemnly affirm and declare as under:-

1 That this is first Anticipatory bail

application and no such or similar bail application
either is pending or has been decided by any
competent court of law.

Deponent
Verification:-

Verified on this 22nd day of September 2005, that

above noted content given by me is truce and
correct to the best of my knowledge and belief and
nothing has been concealed therein.

231
DEPONENT

232
In The Court Of Hon'ble Distt. & Session Judge,
Ludhiana

State Versus Datjit Kaur D/o Jagjit Singh,

R/o Atam Nagar,St. No. 7,
Jagraon.

FIR No. 239/29.7.2004

U/s 452/342/186/353/149/120-B IPC
P.S. Jagroan.

Note: This is first bail application in this

Case and no such or similar application
is pending or has been decided by any
competent Court of law.

Application for Anticipatory Bail U/S 438 of

Cr.P.C.

Sir,
The Applicant/Accused respectfully submits as
under:-

1. That the above noted case is pending before the

Ld. Trial Court of Smt. Jatinder Walia, SDJM,
Jagraon and is fixed for 29.10.2005.

2. That the concession of bail u/s 438 was granted

to the accused/applicant by the Hon'ble court of
Sh. J.S. Bhatia, ASJ, Ludhiana, vide order dated
10.9.2004.

233
3. That in this case, the Ld. Trial Court of Smt.
J.S. Walia, SDJM, Jagraon has issued a non-bailable
warrant against the accused/applicant due to cause
of non-appearance on fixed date i.e. 30.8.2005
before the Ld. Trial Court.

4. That the absence of the accused/applicant on

the fixed date i.e. 30.8.2005 was neither willful
nor intentional rather due to her serious pain in
her backbone as she was bed ridden.

5. That no opportunity was given by the Ld. Trial

Court, Jagroan to the accused/applicant before
canceling her bail/surety bond

6. That the all alleged offences is bailable

except section 452 IPC.

7. That the applicant/Accused undertakes to abide

by all the terms and conditions imposed by this
hon’ble court while releasing her on bail.

8. That the Applicant/Accused undertakes that she

will not leave India without the prior permission
of this Hon'ble court.

9. That the accused/applicant further undertakes

that she will not tamper with the prosecution
evidence.

It is, therefore, respectfully prayed that the

necessary direction may please be given to the Ld.
Trial Court, Jagraon, and P.S. Jagraon, and in the

234
event of arrest, the Applicant/accused be released
on bail in the interest of justice.

Applicant/Accused

Through Counsel
Place:- Ludhiana Raj Kumar Kaushal,
Date: 22/9/2005 Advocate

235
In The Court Of Hon'ble Distt. & Session Judge,
Ludhiana

Mohinder Singh Versus Balram & etc.

In Re: Complaint Case u/s 407/506/34 IPC.

Application for Anticipatory Bail U/S 438 of

Cr.P.C.

Sir,
The Applicant/Accused respectfully submits as
under:-

1. That the above noted complaint is pending

before the Court of Smt. Jatinder Walia, SDJM,
Jagraon and is fixed for 13.10.2005.

2. That the concession of bail u/s 438 was granted

to the accused/applicant by the Hon'ble court of
Sh. B.S. Sodhi, ASJ, Ludhiana in this case, vide
order dated 18.5.2005.

3. That in the above noted case, the Ld. Trial

Court/Duty Magistrate, Jagraon has issued a non-
bailable warrant against the accused/applicant i.e.
Rachpal Singh @ Jaspal Singh, due to cause of non-
appearance before the Ld. Trial Court/Duty
Magistrate on fixed date i.e. 4.7.2005.

4. That on dated 4.7.2005, Ld. Presiding Officer

of the court was also on leave so, the Duty

236
Magistrate has issued a non-bailable warrant
against the accused/applicant.

5. That the absence of the accused/applicant on

the fixed date i.e. 4.7.2005 was neither willful
nor intentional rather due to appearance before the
Hon’ble court of ACJM, Makrana, Distt. Naggor,
Rajasthan on the same date i.e. 4.7.2005.

6. That the accused/applicant is permanently

living and doing his transportation business at
Makrana, Distt. Naggor, Rajathan, so he could not
be able to give any intimation to the Ld. Trial
Court/Duty Magistrate, Jagroan, in lack of proper
communication with his counsel on the very same
date i.e. 4.7.2005.

7. That no opportunity was given to the

accused/applicant before canceling his bail/surety
bond.

8. That the alleged offence is bailable being a

complaint case and law regarding bail in complaint
case is very much clear and the bail is warranted
by law.

9. That the applicant/Accused undertakes to abide

by all the terms and conditions imposed by this
hon’ble court while releasing him on bail.

10. That the Applicant/Accused undertakes that he

will not leave India without the prior permission
of this Hon'ble court.

237
It is, therefore, respectfully prayed that the
necessary direction may please be given to the
concerned police officer and in the event of arrest
the Applicant/accused be released on Anticipatory
bail in the interest of justice.

Applicant/Accused
Rachpal Singh @ Jaspal Singh
R/o Khalsa Tansport Co., Maglana Road, Makrana,
Distt. Naggor, Rajasthan.

Through Counsel
Place:- Ludhiana Raj Kumar Kaushal,
Date: 22/9/2005 Advocate

238
In The Court Of Hon'ble Distt. & Session Judge,
Ludhiana

State of Punjab Versus Gurmeet Singh

S/o Sh. Harchand Singh,
R/o Vill. Bhainishalu,
P.S. Koomkalan,
Ludhiana.

FIR No.- Unknown,

U/s:- Unknown,
P.S. :- Koomkalan,
Ludhiana.

AFFIDAVIT
I, Gurmeet Singh S/o Sh. Harchand Singh, R/o
Vill.
Bhainishalu, P.S. Koomkalan, Ludhiana, do hereby
solemnly affirm and declare as under:-

1. That the present Petition/application for grant

of anticipatory bail has been drafted on the
instructions of the Deponent/accused/applicant.

2. That this is first Anticipatory bail

application and no such or similar bail application
either has been pending or has been decided by any
other court of law.

3. That the deponent is competent to swear this

affidavit.

239
 Deponent
Verification:-

th
Verified on this day of September 2005, that
above noted content given by me is truce and
correct to the best of my knowledge and belief and
nothing has been concealed therein.

DEPONENT

240
In The Court Of Hon'ble Distt. & Session Judge,
Ludhiana

State of Punjab Versus Gurmeet Singh

S/o Sh. Harchand Singh,
R/o Vill. Bhainishalu,
P.S. Koomkalan,
Ludhiana.

FIR No. Unknown

U/s:- Unknown,
P.S. Koomkalan,
Ludhiana.

Application U/S 438 of Cr.P.C. for Anticipatory

Bail

Sir,
The Applicant/Accused respectfully submits as
under:-

1. That the Petitioner is peace loving and law

abiding citizen of India.

2. That one Balbir Singh, Head Constable, in P.S.

Koomkalan, alongwith with other police officials
Paramjit Singh, Harbans Singh of the same P. S.
Koomkalan, at the instance of S.H.O. came to the
residence of the petitioner on 13.8.2005 and took

241
the petitioner to the police Station Koomkalan, in
the presence of Village Sarpanch and some other
respectable persons of the village by saying that
some inquiry is pending against the petitioner.

3. That after bringing to the police station

Koomkalan, the S.H.O. and other above said police
officials physically tortured the petitioner and
demanded illegal gratification from the
petitioner,

242
 otherwise the petitioner would be involved in some
criminal cases registered against him. During his
stay in the police station the above said police
officials forcibly took his signature on some blank
papers.
4. That after intervention of Sarpanch and other
respectable members of the village, the petitioner
got freed from the clutches of the above said
police officials of Koomkalan.
6. That again on 7.9.2005 the above said police
officials of P.S. Koomkalan, raided on the house
of the petitioner but fortunately the petitioner
was not available at his residence. While leaving
the house of the petitioner, the police officials
of Koomkalan threatened the mother of the
petitioner for illegal gratification otherwise her
son would be involved in some criminal case.
7. That the Applicant/Accused is ready to
cooperate with the investigation authority.
8. That the accused/applicant further undertakes
that he will not tamper with the prosecution
evidence.
9. That the applicant/Accused undertakes that he
will abide all the terms and conditions imposed by
this Hon’ble court while releasing him on bail.
10. That the Applicant/Accused undertakes that he
will not leave India without the prior permission
of this Hon'ble court.

It is, therefore, respectfully prayed that the

petitioner be granted anticipatory bail as provided
u/s 438 Cr.P.C. and in the mean time arrest of the
petitioner be stayed in the interest of justice.

243
 Petitioner

Through Counsel
Place:- Ludhiana
Date:- 9/8/2005 Naginder Singh
Advocate

244
In The Court Of Hon'ble Distt. & Session Judge,
Ludhiana

State of Punjab Versus Gurmeet Singh

S/o Sh. Harchand Singh,
R/o Vill. Bhainishalu,
P.S. Koomkalan,
Ludhiana.

FIR No.:-Unknown,
U/s:- Unknown,
P.S. :- Koomkalan,
Ludhiana.

AFFIDAVIT
I, Gurmeet Singh S/o Sh. Harchand Singh, R/o
Village
Bhainishalu, P.S. Koomkalan, Ludhiana, do hereby
solemnly
affirm and declare as under:-

1. That the present Petition/application for grant

of anticipatory bail has been drafted on the
instructions of the eponent/accused/applicant.

2. That this is first Anticipatory bail

application and no such or similar bail application
either has been pending or has been decided by any
other court of law.

3. That the deponent is competent to swear this

affidavit.

245
 Deponent
Verification:-

th
Verified on this day of September 2005, that
above noted content given by me is truce and
correct to the best of my knowledge and belief and
nothing has been concealed therein.

DEPONENT

246
In The Court Of Hon'ble Distt. & Session Judge,
Ludhiana

State of Punjab Versus Gurmeet Singh

S/o Sh. Harchand Singh,
R/o Vill. Bhainishalu,
P.S. Koomkalan,
Ludhiana.

FIR No. Unknown

U/s:- Unknown,
P.S. Koomkalan,
Ludhiana.

Application U/S 438 of Cr.P.C. for Anticipatory

Bail
Sir,
The Applicant/Accused respectfully submits as
under:-

1. That the Petitioner is peace loving and law

abiding citizen of India.

2. That one Balbir Singh, Head Constable, in P.S.

Koomkalan, alongwith with other police officials
Paramjit Singh, Harbans Singh of the same P. S.
Koomkalan, at the instance of S.H.O. came to the
residence of the petitioner on 13.8.2005 and took
the petitioner to the police Station Koomkalan, in
the presence of Village Sarpanch and some other
respectable persons of the village by saying that
some inquiry is pending against the petitioner.

247
3. That after bringing to the police station
Koomkalan, the S.H.O. and other above said police
officials physically tortured the petitioner and
demanded illegal gratification from the
petitioner, otherwise the petitioner would be
involved in some criminal cases registered against
him. During his stay in the police station the
above said police officials forcibly took his
signature on some blank papers.
4. That after intervention of Sarpanch and other
respectable members of the village, the petitioner
got freed from the clutches of the above said
police officials of Koomkalan.
6. That again on 7.9.2005 the above said police
officials of P.S. Koomkalan, raided on the house
of the petitioner but fortunately the petitioner
was not available at his residence. While leaving
the house of the petitioner, the police officials
of Koomkalan threatened the mother of the
petitioner for illegal gratification otherwise her
son would be involved in some criminal case.
7. That the Applicant/Accused is ready to
cooperate with the investigation authority.
8. That the accused/applicant further undertakes
that he will not tamper with the prosecution
evidence.
9. That the applicant/Accused undertakes that he
will abide all the terms and conditions imposed by
this hon’ble court while releasing him on bail.
10. That the Applicant/Accused undertakes that he
will not leave India without the prior permission
of this Hon'ble court.

248
It is, therefore, respectfully prayed that the
petitioner be granted anticipatory bail as provided
u/s 438 Cr.P.C. and in the mean time arrest of the
petitioner be stayed in the interest of justice.

Petitioner

Through Counsel
Place:- Ludhiana
Date:- 9/8/2005 Naginder Singh
Advocate

249
In The Court Of Hon'ble Distt. & Session Judge,
Ludhiana

State Versus Amar Singh

S/o Sh.Babu Lal Singh,
R/o J.P. Colony,
M.S. Nagar,
Tajpur,
Ludhiana.

FIR No. 167/31-8-2005

U/s:- 307/34/120-B IPC,
P.S. Division No. 7,
Ludhiana.

AFFIDAVIT
I, Amar Singh S/o Sh.Babu Lal Singh, R/o J.P.
Colony, M.S.
Nagar, Tajpur, Ludhiana do hereby solemnly affirm
and declare as
under:-

1. That the present application for grant of

anticipatory bail has been drafted on the
instructions of the Deponent/accused/
applicant.

2. That this is first Anticipatory bail

application and no such or similar bail application
either has been pending or has been decided by any
other court of law.

3. That the deponent is competent to swear this

affidavit.

250
 Deponent
Verification:-

Verified on this 8th day of September 2005, that

above noted content given by me is truce and
correct to the best of my knowledge and belief and
nothing has been concealed therein.

DEPONENT

251
In The Court Of Hon'ble Distt. & Session Judge,
Ludhiana

State Versus Amar Singh

S/o Sh.Babu Lal Singh,
R/o J.P. Colony,
M.S. Nagar,
Tajpur,
Ludhiana.

FIR No. 167/31-8-2005

U/s:- 307/34/120-B IPC,
P.S. Division No. 7,
Ludhiana.

Application U/S 438 of Cr.P.C. for Anticipatory

Bail

Sir,
The Applicant/Accused respectfully submits as
under:-

1. That Applicant/Accused is innocent and has

been falsely implicated in the above noted case.

2. That the Applicant/Accused law abiding citizen

of India and is never indulged in any criminal
activity.

3. That at the instance of some unknown person the

police of Division No. 7 is hunting for the
Applicant/accused and raiding on the house of the
Applicant/Accused.

252
4. That there is no legal/ocular evidence against
the Applicant and the police is raiding on
conjectures and surmises. Even after not being the
name of Applicant and the FIR, the Applicant has
apprehension to be arrested by the said police.

5. That the Applicant/Accused is ready to

cooperate with the investigation authority.
6. That the accused/applicant further undertakes
that he will not tamper with the prosecution
evidence.

7. That the applicant/Accused undertakes that he

will abide all the terms and conditions imposed by
this hon’ble court while releasing him on bail.

8. That the Applicant/Accused undertakes that he

will not leave India without the prior permission
of this Hon'ble court.

It is, therefore, respectfully prayed that the

necessary direction may please be given to the
concerned police officer to stint his arrest and in
the event of arrest, the Applicant/accused be
released on Anticipatory bail in the interest of
justice.

Applicant/Accused

Through Counsel
Place:- Ludhiana
Date:- 8/8/2005 Subhash Thakur

253
Advocate

254
In The Court Of Hon'ble Distt. & Session Judge,
Ludhiana

State Versus Amandeep Singh

S/o Sh. Swaran Singh,
R/o H.No. 4042
St. No. 5,
Gobind Colony, Jamalpur,
Ludhiana.

FIR No. unknown,

U/s:- unknown,
P.S. Chowkiman,
Tehsil Jagrona,
Distt. Ludhiana.

AFFIDAVIT
I, Amandeep Singh S/o Sh. Swaran Singh R/o H.No.
4042, St. No. 5, Gobind Colony, Jamalpur, Ludhiana,
do hereby solemnly affirm and declare as under:-

1. That the present application for grant of

anticipatory bail has been drafted on the
instructions of the deponent/accused/applicant.

2. That this is first Anticipatory bail

application and no such or similar bail application
either has been pending or has been decided by any
other court of law.

Deponent
Verification:-

255
Verified on this 9th day of 2005, that above noted
content given by me is truce and correct to the
best of my knowledge and belief and nothing has
been concealed therein.

DEPONENT

256
In The Court Of Hon'ble Distt. & Session Judge,
Ludhiana

State Versus Bhajan Singh

S/o Kashmir Singh,
R/o Vill. Sherpur Pewa,
Tehsil Dharamkot,
Distt. Moga.

FIR No. 98/21.4.2005,

U/s:- 307/324/323/148/
149/353/1
86//333 IPC,
P.S. Sidhwan Bet,
Distt. Ludhiana.

AFFIDAVIT
I, S/o ,
R/o
Distt. Ludhiana, do
hereby solemnly affirm and declare as under:-

1. That this is first Anticipatory bail

application and no such or similar bail application
either has been pending or has been decided by any
other court of law.

Deponent
Verification:-
Verified that above noted content given by me is
truce and correct to the best of my knowledge and
belief and nothing has been concealed therein.

257
 Deponent

In The Court Of Hon'ble Distt. & Session Judge,

Ludhiana

State Versus Sukhdev Singh

S/o Bachan Singh,
R/o Vill. Maddepur,
Distt. Ludhiana.

FIR No. 98/21.4.2005,

U/s:- 307/324/323/148/
149/353/1
86//333 IPC,
P.S. Sidhwan Bet,
Distt. Ludhiana.

Application for Anticipatory Bail U/S 438 of

Cr.P.C.

Sir,
The Applicants/Accused respectfully submits as
under:-

1. That the Applicant/Accused law abiding citizen

of India and is never indulged in any criminal
activity.

2. That Applicant/Accused is innocent and has

been falsely implicated in the above noted case on
statement of co-accused.

258
4. That the name of the applicant/accused is not
mentioned in the FIR inspite of this the police of
P.S. Sidhwan-Bet has been regularly raided the
house of the applicant to arrest him in this above
noted case.

5. That the arrest of the Applicant /Accused is

not required for further investigation in this
case.

6. That the applicant/Accused undertakes that he

will abide all the terms and conditions imposed by
this hon’ble court while releasing him on bail.

7. That the Applicant/Accused undertakes that he

will not leave India without the prior permission
of this Hon'ble court.

8. That the accused/applicant further undertakes

that he will not tamper with the prosecution
evidence.

It is, therefore, respectfully prayed that the

necessary direction may please be given to the
concerned police officer and in the event of arrest
the Applicant/accused be released on Anticipatory
bail in the interest of justice.

Applicant/Accused
Through Counsel
Place:- Ludhiana
Date:- Raj Kumar Kaushal,
Advocate

259
In The Court Of Hon'ble Distt. & Session Judge,
Ludhiana

State Versus Bhajan Singh

S/o Kashmir Singh,
R/o Vill. Sherpur Pewa,
Tehsil Dharamkot,
Distt. Moga.
FIR No. 98/21.4.2005,
U/s:- 307/324/323/148/
149/353/1
86//333 IPC,
P.S. Sidhwan Bet,
Distt. Ludhiana.
Application for Anticipatory Bail U/S 438 of
Cr.P.C.

Sir,
The Applicants/Accused respectfully submits as
under:-
1. That the Applicant/Accused law abiding citizen
of India and is never indulged in any criminal
activity.
2. That Applicant/Accused is innocent and has
been falsely implicated in the above noted case on
statement of co-accused.
4. That the name of the applicant/accused is not
mentioned in the FIR inspite of this the police of
P.S. Sidhwan-Bet has been regularly raided the
house of the applicant to arrest him in this above
noted case.

260
5. That the arrest of the Applicant /Accused is
not required for further investigation in this
case.
6. That the applicant/Accused undertakes that he
will abide all the terms and conditions imposed by
this hon’ble court while releasing him on bail.
7. That the Applicant/Accused undertakes that he
will not leave India without the prior permission
of this Hon'ble court.
8. That the accused/applicant further undertakes
that he will not tamper with the prosecution
evidence.
It is, therefore, respectfully prayed that the
necessary direction may please be given to the
concerned police officer and in the event of arrest
the Applicant/accused be released on Anticipatory
bail in the interest of justice.

Applicant/Accused
Through Counsel
Date:- Raj Kumar Kaushal,
Place:- Ludhiana Advocate

261
262
IN THE COURT OF VACATIONAL( SSESSTION JUDGE),
LUDHIANA

State Versus Rakesh Kumar S/o

Gurmeet Lal,
R/o H.No. 1, St. No.2
New Punjabi Bag,
Tibba Road, Ludhiana.

FIR No. Not Known,

U/s To be disclosed by the
Police,
P.S. Bast Jodhewal
Ludhiana.

Note: This is first bail application and no such

or similar bail application either has been filed
or has been decided by any other court of law.

BAI APPLICATION U/S 438 OF CR.P.C.

Sir,
The Applicant respectfully submits as under:-

1. That the Applicant/Accused is innocent and has

been falsely implicated in the above noted case.
2. That one Tarsem Kaur W/o Balbir Singh H. No.
1708, St. 1, New Punjabi Bag, Tibba Road, Ludhiana
and Rakesh Kumar R/o Gurmail Park, Tibba Road,
Mohalla Gulabi Bag, Ludhiana, one day came to the
house of Accused/Applicant to consult the Pan No.
and they also told him/accused/applicant for
filling the return. But the Accused/Applicant told
them that he has not knowledge about work of such

263
type. But they forcibly compelled the
Accused/Applicant. But the Accused /applicant
refused to do so, on this complainant forcibly
entered in the house of the Accused /Applicant and
started to abuse in the name of mother and sister.
They also gave a slaps on mouth of the wife the
Accused/Applicant. The accused/Applicant gave a
application against them to the S.S. P., Ludhiana.
But no action has been taken so far against the
complainant inspite of this the complainant gave a
false application against the accused /applicant in
P.S. Basti Jodhewal, to arrest the
accused/applicant in non-bailable offence on behalf
of the compliant the police of Basti Jodhewal,
raided the house of the accused/applicant to arrest
him in some non-bailable offece.

3. That the Accused/applicant undertakes that he

will abide all the terms and conditions imposed by
this hon’ble court which releasing her on bail.

It is, therefore, respectfully prayed that the

necessary direction may please be given to the
concerned police officer and in the event of arrest
the Applicant be released on Anticipatory bail in
the interest of justice.
Applicant/Accused
Through Counsel
Place:- Ludhiana
Date:- Avtar Mallan,
Advocate

264
IN THE COURT OF VACATIONAL( SSESSTION JUDGE),
LUDHIANA

State Versus Rakesh Kumar S/o

Gurmeet Lal,
R/o H.No. 1, St. No.2
New Punjabi Bag,
Tibba Road, Ludhiana.

FIR No. Not Known,

U/s To be disclosed by the
Police,
P.S. Bast Jodhewal
Ludhiana.

AFFIDAVIT
I, Rakesh Kumar S/o Gurmeet Lal, R/o H.No. 1, St.
No.2
New Punjabi Bag,Tibba Road, Ludhiana do hereby
solemnly affirm and declare as under:-

1. This first bail application and no such or

similar bail application either has been filed or
has been decided by any other court of law.
DEPONENT
Verification:-

Verified that all the contents of this

affidavit are true and correct to the best of my
knowledge and belief.

Verified at Ludhiana on this day of June 2005.

DEPONENT

265
IN THE COURT OF DISTT.&SESSION JUDGE, LUDHIANA.

CRIMINAL APPEAL N0.--------------OF

2004.

No. & Date Date of Date of the Value of

Suit & Appeal
Of Original Decision Insitutuion Appeal for
the pur filed
Original Suit Judge/ of Appeal pose of
Jurisdiction by
Crl. Case No. 17.11.04 19.11.04 N.A.
Accused
13/2
Through
Dated
Counsel
15.1.2004 Raj
Kumar

Advocate

Bittu Sharma son of Sh. Dharampal Sharma age 29

years, labourer, r/o Shastri Nagar, Jagraon.

State

State of Punjab
FIR NO.
137/16.6.2003

266
 U/S 13A, 3,67 OF
G.A.
P.S Jagroan.

Appeal filed by Appellant/Applicant through Counsel

Raj Kumar, Advocate, Ludhiana.

Appeal from the order of Mrs. Jitender Walia,

S.D.J.M., Jagroan dated 17.11.2004 passed in above
noted case.
Cont.2
:2:
CLAIM IN APPEAL

1. Suspension of sentence till pending the appeal

and be released to appellant/accused on bail u/s
389 of Cr.P.C.
2. To accept the appeal and acquital the
accused/appellant in this case.
3. To set aside /judgment passed on dated
17.11.2004 BY the court Mrs. Jatinder Walia,
S.D.J.M., Jagroan.

GROUNDS OF APPEAL

1. That the accused /appellant is presently in

judicial custody from dated 17.11.2004 in this
case.

2. That the Judgment passed by the Ld. Lower Court

is against the law and fact of the case and is not
sustainable in the eyes of law.

267
3. That the Ld. Lower Court has erred in
dismissing the bail to the accused /applicant u/s
389 for filing the appeal.

4. That the reasonable opportunity for defense is

not given to the accused /appellant in this case by
the Ld. Lower Court.

5. That the impugned judgment of conviction and

order of sentence recorded by the Ld. Trial court
are contrary to law and facts established on
record.

6. That there was no legal evidence against the

appellant /Accused for justifying his conviction.

7. That the Ld. Trial Judge erred in convicting

the appellant u/s 13A of Public Gambling Act.
Cont. 3.
:3:
8. That the learned courts have failed to
appreciate that prosecution has failed to bring
home the accused at least beyond reasonable doubt.

9. That the accused /applicant is ready to

furnish the bail bond to the satisfaction of this
Hon’ble Court and undertake that he will abide all
the terms and conditions as may be imposed by this
Hon’ble Court.

10. That at any rate the sentence awarded to the

appellant is unduly harsh.

268
11. That the appellant/accused is sole Bread
winner of his family so a lenient view be taken
with against the conviction.

12. That the opportunity in quantum of sentence is

not given to the appellant/accused by the Ld. Lower
Court.

13. That the appellant has not filed any appeal in

this case either in this Hon’ble court or before
any competent court of law.
Prayer
It is therefore respectfully prayed that the appeal
of the appellant may kindly be accepted and the
sentence be suspended and accused/appellant be
released on bail. The conviction and sentence of
the appellant kindly be Set Aside passed by the Ld.
Lower Court on dated 17.11.2004.
Any other and further order/relief, which this
Hon’ble court may deem fit and proper, may also be
passed in the facts and circumstances of the case
and accused be discharged in the interest of
justice.

… Appellant/Accused
Through Counsel
Raj Kumar Kaushal,
Place:- Ludhiana
Advocate,
Date:---/--/2004 New Court
Complex,
IN THE COURT OF DELHI: AT NEW DELHI
Criminal Appeal No.______of 2002

269
In the matter of:

Jaswant,

Ballco,

Kinnu,

Kanaiyha,
All s/o Sh. Deep Chand,
F/o H. No. 166, Janta Colony,
Circular Road, Shahadara
…. Petitioner
Versus

The state of Delhi. …

Respondent

U/s 147//148/149/302/34 IPC

P.S. Vivek Vihar
F.I.R No.39/2002
Court Con.Sh. O.P. Gupta
ASJ: Karkar Dooma Court, Delhi

PETITION UNDER SECTION 439 CR.P.C. FOR GRANT OF

BAIL ON BEHALF OF PETITIONER/ACCUSED NAME ABOVE.

Sir,
It is most respectfully submitted as under:

1. That the case State V/s Jaswant Singh and

others, is pending in the court Sh. O.P. Gupta:
ASJ: Kakardooma Court and on the last Date:- of

270
hearing, the charges were framed and now the case
is fixed for 3.10.2002.

2. That the prosecution case in brief is that on

29.3.02, Sh. Ganga Ram lodged a report at P.S.
Vivek Vihar, alleging therein that on 29.3.02 at
about 11. 17 pm, his dog was barking and this is
alleged that Devender, i.e., brother of the
petitioner shouted that the shall stop the barking
of the dog and that he shall also see the owner of
the said dog, i.e. “AAJ IS KUTTE KAA BHONKNA BAND
KAR DENGE BAAD MAIN KUTTE PALNE WALE KO BEE
DEKHNGE”. It is further alleged that Devender
brought a Rod from the house and in the meanwhile,
the petitioners along with their mother Smt.
Dayanti also reached there. It is further alleged
that Chandrawati wife of the complainant (Now
deceased) objected, on which the accused persons
started shouting and it is further alleged that all
the petitioners along with their mother shouted
that she should be finished and co-accused Devender
attacked the deceased Affidavit gave a blow which
struck on left hand and she feel and subsequently
died.

3. That the only allegations against the

petitioner and co-accused Smt. Dayawati who has
already seen admitted on bail, is that they
exhorted co-accused Devender.
That as per prosecution case, Devender allegedly
gave one blow, which struck on the left hand of the
deceased and even o the said hand, no fracture was
found.

271
4. That as per doctor, there is a rectangular
shape grouse in area 6*2 mm, Plate obliquely overt
dorsum on right hand and right wrist, near the base
of joint and there was superficial small abrasion
over left shoulder top and there was no external
injury on the body of the deceased.

5. That the doctor who conducted the post mortem,

opined that death was caused by Asphyxia, as a
result of checking of one by trachea by food
particles which could be precipitated by injury
over right hand. However, final opinion/report by
given after the receipt of chemical report of blood
and vista and analysis of heart pieces.
6. That the articles were sent for analysis to
show that deceased was suffering from heart problem
and no final report was given to cause death.

7. That as per the prosecution case, Devender

allegedly gave only one blow, which struck on the
left had of the deceased and that caused only
abrasion, so it can be safely presumed that
Devender had no intention to cause any grievous
injury o the body of the deceased.

8. That death in this case was due to Asphyxia and

can not be presumed that co-accused Devender had
any knowledge that the said blow could cause death
and he had no intention to cause death and at the
most, it can be inferred that co-accused Devender
had intention to cause bodily hurt only.

9. That the petitioner had no knowledge that

deceased shall die due to Heart Failure.

272
10. That prima facie no case is made out against
the petitioners U/s 302 IPC and at the most offence
falls within the ambit of 323/34 IPC, which is bail
able.

11. That the bail application moved on behalf of

the petitioner kanhaiya and Kinuu were rejected by
the Court, of Sh. J.P. Singh: ASJ. Karkardooma,
Court Delhi vide order dt.23.4.2002. (Copy of the
order are annexed herewith as Annexure A & B).
Second application for bail mo ed on behalf of
petitioner kinnu was rejected sh. J.P.Singh: ASJ:
kakardooma Court, vide order Dt. 9.5.02. (Copy of
the said order annexed herewith as Annexure A).

12. That the bail application moved on behalf of

the petitioner Jaswant was dismissed by Sh. J.P.
Singh: ASJ: Karkar dooma Court, Delhi vide order
Dt.23.5.02. (Copy of said order is annexed herewith
as Annexxed-D).

13. That co-accused Smt. Dayawati was admitted to

bail by Sh. J.P. Singh: ASJ: Karkardoom, Court
Delhi vide order Dt.12.4.2002. (Copy of the order
annexed herewith as Annexure-E).

14. That after filing of charge sheet, case has

been allocated to the court of Sh. O. P. Gupta: ASJ
Karkardoom Court Delhi and the petitioner moved the
application before the trial court but the same was
rejected on 1.8.2002. (Copy of the said order is
annexed herewith as Annexure-F).

273
15. That though the role attributed to the
petitioners is identical with co-accused Smt.
Dayawati, who had already/admitted to bail vide
order Dt. 12.4.02.

16. That the petitioners are in J/c since 30.3.2002

and they are no longer required for the purpose of
investigation or interrogation.

17. That the petitioners are the permanent

residents of the given address and there is no
chance of their absconding away or tampering with
the prosecuting evidence if released o bail.
18. That the petitioners are ready to come to the
terms, which this Hon’ble Court deems fit and
proper to impose upon them.
19. That the petitioner is ready to produce sound
and reliable surety to the complete satisfaction of
the trial court or this Hon’ble Court.
20. That the petitioners belong to a respectable
family with clean antecedent and all the
petitioners are married having small children to
look after and except the old aged parents of the
petitioners, there is no body else to look after
their children and wives.
21. That no similar petition for bail has ever been
moved before Delhi High Court nor such petition is
pending in this court. This is the first petition
before the Hon’ble Court and no such petition has
ever been filed before the Hon’ble Supreme Court of
India.

274
 It is, therefore, prayed that the Hon’ble Court
may kindly be pleased to admit the petitioner/
accused on bail, in the interest of justice.
…

275
 Grounds of Revision:-

1. That both the ejectment orders passed by Ld.

Rent Controller dated 12.3.2005 and that of the
Appellate Authority dated 28.5.2005 are against law
and facts.

2. That the Ld. Courts below erred in law and not

extending the time for tendering the rent amount on
the application dated 12.3.2005 to which the reply
has also not filed by the respondent landlord.
3. That by declining the said application the Ld.
Courts below erred in law and not appreciating and
interpreting the judgment passed by the Hon'ble
Apex court in Rakesh Wadhawan’s case in which it
has been clearly observed by the Hon'ble Apex
Court

“The question which stares us it : whether in

enacting section 13(2)(i) and proviso thereto can
we assume that the Legislature intended to place
the tenants in a situation worse than what it would
have been under the principles deducible from
section 114 of T.P. Act and even if this provision
would not have been there? We cannot attribute such
misplaced wisdom to the Legislature without being
uncharitable to it. We are definitely of the
opinion that by engrafting section 13(2)(i) and
proviso in the body of the Act the Legislature
intended to confer on the tenants a protection,
larger and more beneficial that what it would have
been if the provision was not enacted.”
It has also been observed by Hon'ble Aprex Court
that after having appointed a time for payment the

276
court still retains jurisdiction to extend the
time. It has been observed while referring to
section 114 of the Transfer of Property Act and
after going through the above observation
reproduced above it has been made clear that the
Lagislature by enacting the rent Act and the
provision of section 13(2) in the Rent Act has been
engrafted to confer on the tenants a protection
larger and more beneficial that what it would have
been if the provision was not enacted.

4. That while passing the said impugned ejectment

orders both the courts failed to take in to
consideration the said observations.

5. That the Hon'ble Apex Court has nowhere

restrained/stopped from granting/extending the
time for making of tender and there is no bar to
the same. Had it been so then the Hon'ble Apex
Court would not have observed as mentioned above
and there cannot be straitjacket formula. The law
is to be applied as per the facts and circumstances
of the case and that too judiciously.

6. That the Ld. courts below erred in law in

passing the ejectment orders as if the Petitioner
has declined to tender the rent. Though only
extension was prayed for since the Petitioner was
bedridden on account of Heart Ailment being an old
person about of seventy five (75) years of age. It
shows the bonafide on the part of petitioner to
tender the rent. So the first date of hearing would
be after the extension of the time for tendering
the rent.

277
7. That the Ld. Courts below erred in law in
assessing the rent which was not required since
twice the finding was returned in favour of the
petitioner that the rent has already been paid to
the respondents and the rent for latter period up
to 31.3.2004 is also lying deposited in the court.

8. That if the impugned orders would be allowed to

stand it would occasion a failure of justice .

9. That in the light of the grounds mentioned

above the petition liable to be accepted.

It is therefore, most respectfully prayed that

both the impugned order dated 12.3.2005 and date of
28.5.2005 passed by the Ld. Rent Controller and
Appellate Authority respectively may please be set
aside and the application u/s 13 of the Rent Act
for ejectment may please be dismissed by accepting
the Civil Revision with costs throughout.

A. K. Kalsy, (Advocate)

Counsel for the Petitioners

Place: Chandigarh
Dated : 6.7.2005.

278
In the High Court of Punjab and Haryana at
Chandigarh.

C.M No._______________of 2005

In

C.R. No. _____________of 2005

Tara Chand & Another Versus Ajit Singh

Application u/o 41 Rule 5 R/w 151 of the

C.P.C. with a prayer to stay the implementation/
execution of the impugned orders in the interest of
justice equity and good conscious.

Respectfully Showeth,

1. That the petitioner has filed the accompanying

Civil Revision vide which moot law points have been
raised for kind determination by the this Hon'ble
court.

2. That the applicants/Petitioners have prima

facie case in their favour.

3. That the balance of convenience also lies in

their favour.

4. That in case the impugned are not stayed then

the applicants/petitioners shall suffer irreparable
loss which can not be compensated in the terms of
money and there would be multiplicity of
litigation and the Revision shall become

279
infructuous.

It is therefore, most respectfully prayed that both

the impugned order dated 12.3.2005 and date of
28.5.2005 passed by the Ld. Rent Controller and
Appellate Authority respectively may please be set
aside and the application u/s 13 of the Rent Act
for ejectment may please be dismissed by accepting
the Civil Revision with costs throughout.

An affidavit is attached herewith.

A. K. Kalsy,( Advocate)

Counsel for the Petitioners

Place: Chandigarh
Dated : 6.7.2005.

280
In the High Court of Punjab and Haryana at
Chandigarh.

C.M No._______________of 2005

In

C.R. No. _____________of 2005

Tara Chand & Another Versus Ajit Singh

AFFIDAVIT

I, Tara Chand S/o Late Sh. Behari Lal R/o R/o

Maharishi Balmik Colony, Near Block-X, Suran Wali
Gali, Behind Kali Mata Mandir, Haibowal Khurd,
Ludhiana do hereby solemnly affirm and declare as
under:-

1. That the petitioner has filed the accompanying

Civil Revision vide which moot law points have been
raised for kind determination by the this Hon'ble
court.

2. That the applicants/Petitioners have prima

facie case in their favour.

3. That the balance of convenience also lies in

their favour.

4. That in case the impugned are not stayed then

the applicants/petitioners shall suffer irreparable

281
loss which can not be compensated in the terms of
money and there would be multiplicity of litigation
and the Revision shall become infructuous

Deponent
Verification:-

Verified on 6th day of July, 2005 at the Ludhiana

that all the contents of above said affidavit are
true and correct to the best my knowledge and
nothing has been concealed and misstated there.

Verified at Ludhiana.

Dated: 6/7/2005 Deponent

282
In the High Court of Punjab and Haryana
at Chandigarh.

C.R. No. _____________of 2005

Tara Chand & Another Versus Ajit Singh

Memo of Parties

1. Tara Chand S/o Sh. Behari Lal,

2. Chander Sekhar S/o Tara Chand,

Both R/o Maharishi Balmik Colony, Near Block-X,

Suran Wali Gali, Behind Kali Mata Mandir, Haibowal,
Ludhiana.

Petitioners,
Versus

Ajit Singh S/o Waryam Singh S/o Malla Singh, R/o

House No. B-I-590, Chowni Mohalla, Ludhiana.
Respondent

Place: Chandigarh,
Dated: 6.7.2005
A. K. Kalsy,( Advocate)
Counsel for the Petitioners
Place: Chandigarh
Dated : 6.7.2005.

283
In the High Court of Punjab and Haryana
at Chandigarh.

C.R. No. _____________of 2005

Tara Chand & Another Versus Ajit Singh

Index
___________________________________________________
_____
Sl. No. Description Dated Page
1. C.M. for stay 6.7.2005 1-2
2. Affidavit thereof6.7.2005 3-4
3. Grounds of
Revision 6.7.2005 5-7
4. Memo of parties 6/7/2005 8
5. Judgment of R.C. 12.3.2005 9-14
6. Judgement of
Appellate Authority 28.5.2005 15-22
7. Power of Attorney 6.7.2005 23

Note: No caveat has been received.

Any other similar case ____ Nil.

Place: Chandigarh,
Dated 6.7.2005
A. K. Kalsy,( Advocate)
Counsel for the Petitioners
Place: Chandigarh
Dated : 6.7.2005.

284
IN THE COURT OF SHRI -----, DISTRICT JUDGE,
LUDHIANA

In the matter of: -

Rajbir Singh …
Petitioner

Versus

State … Respondent

PETITIONER U/S 438 CR.P.C. FOR GRANT OF

ANTICIPATORY BAIL.

GROUNDS FOR ANTICIPATORY BAIL

That the impugned judgment of conviction and order

of sentence recorded by the Hon’ble Trial court are
contrary to law and facts established on record.

That there was no legal evidence against the

appellant justifying his conviction.

That the Ld. Trial Judge erred in convicting the

appellant u/s 7/13 (1) (d) read with section 1392)
of the Essential commodities Act.

That the Hon’ble courts have failed to appreciate

that prosecution has failed to bring home and
failed to the accused at least beyond reasonable
doubt.

285
That the judgments of the courts below are
otherwise based on conjectures and surmises.

That the appellant has undergone the ordeal of

trial for more than none years and the proceedings
against him may be quashed on this ground itself.

That at any rate the sentence awarded to the

appellant is unduly harsh.

That the appellant has not filed any appeal in this

case either in this Hon’ble court of the Hon’ble
Supreme Court.

Prayer

It is, therefore, respectfully prayed that the

appeal of the appellant may kindly be accepted and
the conviction and sentence of the appellant may be
Set Aside.

Any other and further order, which this Hon’ble

court may deem fit and proper may also be passed in
the facts and circumstances of the case

…
Petitioner

New Delhi Through

Nov. 8 2002

286
 Rajesh Mahajan
Advocate

287