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IN THE HON,BLE COURT OF MADAM MADHUBALA ,ACJM , YAMUNA NAGAR
State Versus. Rahul etc.
FIR No.: 466/27.11.19
Next Dated : 7.03.20
U/s: 193/209/420/467/465/468/471/120B
P.S: Model Town
1ST APPLICATION FOR BAIL
Hon,ble Madam,
The petitioner most respectfully submits as under:-
Facts in Brief:-
That a FIR under section 363/366A IPC was resisted against the
accused /Applicant on dated 20.7.14. In this case the Applicant/ accused is in
jail since his arrest from dated 3.9.14.During the trial of this case a migration
certificate was produced on behalf of the Applicant/ accused to take benefit
under Juvenile Act .The counsel of the applicant had produced the photocopy
of the migration certificate. The Birbal Ram had handed over this photocopy of
migration certificate to the counsel of the Applicant. The hon,ble trial court had
send this certificate for verification and it was found false one.
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So on this basis a case i.e. the present was registered against the Rahul and
Birbal Ram. The applicant was in judicial custody so it is not possible to prepare
that documents. He is falsely impleaded in this case.
That the applicant/accused is acquitted from that case of FIR No.
523 of dated 20.7.14 by the hon,ble court of Madam Shashi ASJ, karkarduma on
dated 12.2.16.[ Certified copy of order is attached]
1- That the petitioner is a respected person of the society and having a permanent
abode at the above noted address.
2- That the petitioner is in judicial custody more than 5 and1/2 months and no
fruit full purpose will be served to keep him behind the bars.
3- That it is not possible to the applicant to prepared a forged copy of migration
certificate in jail.
4- That the perusal of contents of FIR reveals that no substantive offence under
sections 420 and 406 IPC made out against the applicant. Even the allegations of
any criminal conspiracy by the petitioner with accused Birbal are not mentioned
in the FIR.
5- That the local police have falsely involved the petitioner in the present case
without any basis.
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6- That the applicant is a young boy and bread winner of his family.
7- That the applicant has no concerned with the forged migration certificate.
8- That nothing is required to be recovered from the person of the applicant.
9- That the petitioner undertakes to join the investigation as and when required by
the Police and shall not tamper with the prosecution witnesses.
10- That the petitioner shall abide by all the terms and conditions of the bail as
imposed by this Hon’ble Court.
11- That this is the first bail application and no such bail application was neither filed
nor pending in any other Courts.
PRAYER:-
It is, therefore, prayed that the bail application of the petitioner/Applicant
may kindly be accepted and enlarged the petitioner on bail during the trial of
the case.
PLACE: YAMUNA NAGAR
DATE:- Petitioner
Rahul son of Ram Gopal R/o Vill
Mohanpur , Distt Bhojpur,[ Bihar].
THROUGH COUNSEL :
