IN THE COURT OF METROPOLITAN MAGISTRATE DISTRICT
__________
BAIL APPLICATION NO. __________ OF 2023
IN THE MATTER OF :
STATE
COMPLAINANT
VERSUS
X _______ S/o _______ R/o __________
…..APPLICANT
FIR NO. ________
U/S_________________
POLICE
STATION _____________________
APPLICATION FOR GRANT OF BAIL UNDER SECTION 437 OF
CR.P.C.
The accused above named most respectfully showeth :-
1. That the accused above named was arrested by the police on
________, 20XX and is in judicial custody since then. It is alleged
that on _________, 20XX, the accused was suspiciously moving on
_______________ when the police apprehended him, conducted the
search and recovered ___ gms. of smack from his pocket.
2. That the accused has been falsely implicated in the instant
case and he has nothing to do with the alleged offence.
3. That nothing was recovered from the possession of the accused
or at his instance and the so called case property has been
planted upon the accused.
4. That the accused is a law abiding citizen and belongs to a very
respectable family. He has never indulged in any illegal activities
and commands respect and admiration his locality.
5. That in _________, 20XX, the accused found some persons
selling smack near______________. The accused immediately
reported the mater to police as the result of which police also
arrested some of the persons. Since that time, those persons who
were arrested at the instance of the accused, were threatening
the accused to falsely implicate him in a criminal case in collusion
with police. The accused made a complaint in this regard to the
Dy. Commissioner of Police, true copy of which is annexed hereto
as Annexure-A.
6. That after the said complaint, the accused was called by the
Vigilance Department, _____ Police who enquired into his
complaint. True copy of the said notice issued by the Vigilance
Cell is enclosed herewith as Annexure-B.
7. That it is unimaginable that the accused who made a complaint
against the sellers of smack, would himself indulge in such
activities.
8. That the accused is a permanent resident of ______ and there
are no chance of his absconding in case he is released on bail.
9. That there is no chance of the accused absconding or
tempering with the prosecution evidence in the event of release
on bail.
10. That the accused undertakes to join the investigation as and
when directed to do so.
11. That the accused is not a previous convict and has not been
involved in any case of this nature except the present case.
12. That the present case is a result of clear manipulation by the
police.
13. That the accused from all accounts is an innocent person. It is
therefore respectfully prayed that the accused may kindly be
released on bail during the pendency of this case.
APPLICANT
THROUGH
Dated : ……………..
ADVOCATE