MEMORANDUM OF CRIMINAL ORIGINAL PETITION
(Under Section 438 of Crl.Pro.Code)
IN THE HIGH COURT OF JUDICATURE AT MADRAS
Crl.O.P.No. of 2023
In
Crime No. 311 of 2023
(On the file of the respondent)
Sennerappan, M/45 yrs,
S/o.Angappa,
D.No.3-5, Arulalam Ward 3,
Salivaram – (P),
Krishnagiri District -635107 ...Petitioner/Accused No.2
-Vs-
State rep. by
Inspector of Police,
Denkanikottai Police Station,
Krishnagiri District
Cr.No.311/2023 …Respondent/Complainant
PETITION FOR ANTICIPATORY BAIL
It is most respectfully submitted as follows;
1. That, the petitioner is apprehending arrest of the respondent
for alleged offences under section 4(1)(a) & 4(1-A) of
Tamilnadu Prohibition Act in Crime No.311/2023 dated
29.07.2023.
2. The prosecution case is that upon reliable information on
29.07.2023 at 18.00 pm the police party was on duty, one
person, who was standing in suspected manner and the
police party intercepted him, while he disclosed his name
and address and he was having one yellow colour urea bag
and it was opened and they found that it was contained “Old
Secret strong XXX Rum 180 ml, 41 karnataka liquor packets,
Old secret strong XXX Rum 90 ml, 192 karnataka liquor
packets, Topstar Brandy 180 ml, 45 karnataka liquor packets
wherein the labels were removed and emanating foul smell
and they realized that those are poisonous liquor and on
continuous enquiry on him they found that the A1’s father
purchased liquor packets from wine shop, Karnataka State
on cheaper rate and subsequently, they will mix the
poisonous plant’s syrup (oomathan kaai) and then, they will
sell to the customers. Hence the FIR was registered against
them in Crime No.311 of 2023 on 29.07.2023 under section
4(1)(a) & 4(1-A) of Tamilnadu Prohibition Act.
3. The defence case is that the Petitioner/Accused is nothing to
do with offences alleged by the prosecution. The Petitioner is
a law abiding citizen.
4. The Petitioner/Accused is innocent and he is falsely
implicated in this case, he is no way connected with alleged
offence.
5. It is submitted that the Petitioner/Accused is hailing with
permanent residence in the above said address and he is
obedient to law, he will not abscond and ready to cooperate
with the investigation and he is ready to furnish substantial
sureties for his due appearance.
6. It is submitted that if the Petitioner/Accused is released on
bail, he will not meddle with investigation nor persuade or
threat the witnesses.
7. It is further submitted that this is the first anticipatory bail
petition before this Hon’ble court and there is no similar
petition is pending or filed before this Hon’ble court or any
other court.
Therefore, it is humbly prayed that this Hon’ble
Court may be graciously pleased to enlarge the
Petitioner/Accused on Anticipatory Bail in the event of arrest
by the respondent in Crime No.311/2023, dated 29.07.2023
and thus render justice.
Dated at Chennai, this is the 15th day of August, 2023.
[[[[
Counsel for petitioner
NOTE:
1) The bail is to the satisfaction of the Learned Judicial
Magistrate, Denkanikottai.
2) No similar petition is pending or filed before this Hon’ble
court or any other court.
3) This is the first Anticipatory Bail application.
IN THE HIGH COURT OF
JUDICATURE AT
MADRAS
Crl.O.P.No. of
2023
In
Crime No. 311 of 2023
(On the file of the
respondent)
Chennaveeran, M/ 45 yrs,
S/o.Angappa,
...Petitioner/Accused
-Vs-
State rep. by
Special Sub-Inspector of
Police,
Denkanikottai Police
Station,
Krishnagiri District
…Respondent/Complainant
PETITION FOR
ANTICIPATORY BAIL
R.RADHA PANDIAN
[81/02]
B.ARAVINTHAN (3411/13)
S.RAGHUMAN [1241/15]
M.KAVIRAJ [2947/2016]
COUNSEL FOR PETITIONER
9789290538
IN THE HIGH COURT OF
JUDICATURE AT
MADRAS
Crl.O.P.No. of
2023
In
Crime No. 311 of 2023
(On the file of the
respondent)
Chennaveeran, M/ 45 yrs,
S/o.Angappa,
...Petitioner/Accused
-Vs-
State rep. by
Special Sub-Inspector of
Police,
Denkanikottai Police
Station,
Krishnagiri District
…Respondent/Complainant
FIR
R.RADHA PANDIAN
[81/02]
B.ARAVINTHAN (3411/13)
S.RAGHUMAN [1241/15]
M.KAVIRAJ [2947/2016]
COUNSEL FOR PETITIONER
9789290538
