IN THE COURT HONBLE A.C.J.M.

/DUTY MAGISTRATE,
MANSA
State
Versus
Jagsir Singh @ Laogo s/o Mittu Singh, S.C. r/o Burj Hrike, now confined in
District Jail Mansa.

Accused/Applicant

FIR NO. 66, Dt. 07-06-2014, offence u/s 61/1/14 P.S. Sadar
Mansa.
First Bail Application u/s 437 Cr.P.C.
Date of Arrest = 07-06-2014
Alleged Recovery = 180 bottles of County made Liquor
Respected Sir,
It is submitted as under:
(1) That this is the First Bail application ever filed by the accused in the present
case.
(2) That accused has been involved in the present case on the basis of enmity
with the Wine Contractor and Suspicion.
(3) That it is highly impossible to purchase such quantity of county made liquor
and police is unable to investigate and disclose the origin of the liquor. This
shows that this is a planted case in connivance with the Wine Contractor.
(4) That investigation is complete and recovery has been affected, so accused is
no more required for any further investigation as such no useful purpose will
be solved by detaining the accused anymore.
(5) That accused is bread winner of his family and is labour by profession, so
there is nobody to save the family of the accused from hunger.
(6) That accused undertakes to abide by all the conditions imposed by this
honble court.

(7) That the Power of Attorney of accused to contest the Bail is already attached
with the remand papers.
It is therefore prayed that accused may kindly be released on bail.

Dt.

Submitted by:
Jagsir Singh @ Laogo s/o Mittu
Singh, S.C. r/o Burj Hrike, now
confined in District Jail Mansa.
(Accused)

Through Counsel:
Mr. Vikram Gupta, Advocate

IN THE COURT HONBLE SESSION JUDGE, MANSA

State

Versus
Bharat Bhushan s/o Darshan Kumar r/o Tibba Basti, Near Durga Mandir Patran,
District Patiala, Now confined in Judicial Lock-up District Jail Mansa.
.Accused/Applicant

FIR No. 46, Dt. 07-06-2014, offence u/s 420/467/471/120-B

I.P.C. P.S. City-I Mansa.
First Bail Application u/s 439 Cr.P.C.
Date of Arrest = 07-06-2014
Respected Sir,
It is submitted as under:
(1) That this is first bail application u/s 439 Cr. P.C. ever filed by the accused in
the present case. One bail application filed u/s 437 Cr.P.C. was dismissed on
12-06-2014 by honble C.J.M. Mansa. So, this is only the Bail application
being filed under 439 Cr.P.C.
(2) That accused never committed any crime as alleged by the Complainant.
(3) That the name of the accused has been dragged in the present case by
making imagination and to settle the score against the accused regarding the
litigation pending between the co-accused and complainant and his family,
so accused is entitled for bail.
(4) That as per the allegation of the Complainant, some changes were made in
the Certificates of the Punjab School Education Board by changing the
fathers name of Diksha Bansal and Gurinder Bansal from Parvinder
Kumarto Hem Raj. Parinder Kumar was the brother of the Complainant,
who died after leaving two children along with co-accused; Sunita Rani
(widow), who solemnized the Marriage with Hem Raj (Co-accused). The
complainant further alleged that the age of the Diksha Bansal was lowered
by 1 year, so if any crime was committed as alleged that is not by accused
but by the educational authorities.
(5) That no person was ever cheated and no monetary gain was obtained, so no
offence u/s 420/467/471 of I.P.C. is made out. Only offence u/s 464/120-B of

I.P.C. is made out as per the allegation. Sections 464 and 120-B of I.P.C. are
bailable, hence accused is entitled for bail.
(6) That Complainant is misusing the process of the Law in connivance with the
Police authorities by framing the accused under such serious offences of the
I.P.C. in order to cause the hindrance to release the accused on bail, which is
evident from the fact that complainant; Suresh Kumar, filed one Complaint
u/s 420/406/465/467/468/471/120-B of I.P.C. through his minor children i.e.
Jasvinder Bansal and Manak Shah, against Sunita Rani and Hem Raj
alongwith the Principal of Mai Nikko Devi School, Mansa in the Court of
S.D.J.M. Sunam and S.D.J.M. Sunam passed order of 17-07-2013 by
dismissing the allegations in the complaint by observing that no offence u/s
420/465/467/468/471of I.P.C. is made out. He observed that if possible only
offence comes under the offence u/s 464 of I.P.C. He further observe that as
the Civil Litigations are pending between the parties and directed the
concerned Civil court to entertain the matter u/s 340 of Cr.P.C. It is pertinent
to mention here that Bharat Bhushan was never impleaded as accused in that
complaint, the Photo Copy of such order is attached herewith. Moreover,
Suresh Kumar went in revision against such order, which is pending in the
Court of Honble Session Judge Sangrur, so the registration of present FIR is
clear cut misuse of process of law and accused is entitled for bail.
(7) That

Sunita

Rani

(co-accused)

420/465/467/468/471/120-B/34

of

had
I.P.C.

filed

one

against

complaint
Suresh

u/s

Kumar

(complainant) and other four persons, who got prepared a Forged Will,
which is pending in the Court of S.D.J.M. Sunam. So present case registered
against the accused is to pressurise Sunita Rani to get dismissed her
complaint. As being a brother, accused is supporting and helping his sister
Sunita Rani to get justice for his sister and her children.
(8) That no recovery has to be effected and investigation is complete as against
the accused.
(9) That this is the first case ever registered against the accused.
(10) That accused undertakes to abide by all the conditions imposed by this
honble court.
It is therefore prayed that accused may kindly be released on bail.

Dt.

Submitted by:
Bharat Bhushan s/o Darshan Kumar
r/o Tibba Basti, Near Durga Mandir
Patran, District Patiala, Now confined
in Judicial Lock-up District Jail
Mansa. (Accused/Applicant)

Through Counsel:
Mr. Vikram Gupta, Advocate

IN THE COURT HONBLE SESSION JUDGE, MANSA

State
Versus
Hem Raj s/o Puran Chand r/o Grewal Street, Cinema Road, Mansa, Now confined
in Judicial Lock-up District Jail Mansa.
.Accused/Applicant

FIR No. 46, Dt. 07-06-2014, offence u/s 420/467/471/120-B

I.P.C. P.S. City-I Mansa.
First Bail Application u/s 439 Cr.P.C.
Date of Arrest = 07-06-2014

Respected Sir,
It is submitted as under:
(1) That this is first bail application u/s 439 Cr. P.C. ever filed by the accused in
the present case. One bail application filed u/s 437 Cr.P.C. was dismissed on
12-06-2014 by honble C.J.M. Mansa. So, this is only the Bail application
being filed under 439 Cr.P.C.
(2) That accused never committed any crime as alleged by the Complainant.
(3) That the accused never forged any certificate of Diksha Bansal and Gurinder
Bansal as accused was considering both the Children as his own and got
admitted them in the School as his own children. Accused never directed the
Principal of the Mai Nikko Devi Model School to delete the Fathers name
of the children of Sunita Rani. But Principal of school himself recorded the
fathers name as Hem Raj as alleged, if any change was made in the year of
passing of 5th Class of Diksha Bansal from 2007-08, that is only a
inadvertent mistake committed by the school authorities, so accused is
entitled for bail.
(4) That as per the allegations no offence u/s 420/467/468/471 of I.P.C. is made
out, the perusal of the FIR shows that as per the allegation offence u/s
464/465 of I.P.C. is made out, which are bailable. So, accused cannot be
confined in the jail for the wring mentioning of the sections of I.P.C. by the
Police authorities.
(5) That complainant through his minor children filed one complaint on the
present facts and Honble S.D.J.M. Sunam, refused to summon the accused
u/s 420/465/467/471 of I.P.C. and the complainant went in Revision, which
is pending before Honble Session Judge, Sangrur.
(6) That all the allegations in the FIR are concocted one in connivance with the
police officials in order to force Sunita Rani to not to contest the cases filed
against Suresh Kumar and others.
(7) That registration of present FIR is clear cut misuse of process of law.
(8) That it is the first case ever registered against the accused.
(9) That the accused undertakes to follow all the conditions as imposed by this
Honble Court.

It is therefore prayed that accused may kindly be released on bail.

Dt.

Submitted by:
Hem Raj s/o Puran Chand r/o Grewal
Street, Cinema Road, Mansa, Now
confined in Judicial Lock-up District
Jail Mansa. (Accused)
Through Counsel:
Mr. Vikram Gupta, Advocate

IN THE COURT OF HONBLE SESSION JUDGE,

MANSA
State
Versus
Sunita Rani w/o Hem Raj r/o Grewal Street, Cinema Road, Masna
..Accused/Applicant
FIR No. 46, Dt. 07-06-2014, offence u/s 420/467/471/120-B
I.P.C. P.S. City-I Mansa.
First Bail Application u/s 438 Cr.P.C.
Co-accused; Bharat Bhushan & Hem Raj, has been arrested and
their Bail applications u/s 437 Cr.P.C. will be filed before
honble C.J.M. Masna.
Respected Sir,
It is submitted as under:
(1) That this is the first bail applications ever filed by the accused in the present
case.

(2) That the accused had never committed the offence as alleged by the
Complainant in the FIR.
(3) That as alleged by the complainant in the FIR, the Fathers Name in the
Certificates of Punjab School Education Board of Diksha Bansal and
Gurinder Bansal has been forged from Parvinder Kumar to Hem Raj.
Parvinder Kumar was the brother of the Complainant, who died after leaving
two children along with the accused, the accused thereafter solemnized the
Marriage with Hem Raj.
(4) That it was Hem Raj, who got admitted the children in the Mai Nikko Devi
School and it was the Principal, who himself recorded the co-accuseds
name as fathers name.
(5) That the complainant further alleged that the age of the Diksha Bansal was
lowered by 1 year, so if any crime was committed as alleged that is not by
accused but because of the mistake of Educational authorities.
(6) That no person was ever cheated or no monetary gain was obtained, so no
offence u/s 420/467/471 I.P.C. is made out. Only offence u/s 464/120-B is
made out as per the allegation. Section 464 and 120-B is bailable, hence
accused is entitled for bail.
(7) That the Complainant is misusing the process of the Law in connivance with
the Police authorities by framing the accused under such serious offences of
the I.P.C. in order to cause the hindrance to release the accused on bail,
which is evident from the fact that Complainant Suresh Kumar filed one
Complaint u/s 420/406/465/467/468/471/120-B of I.P.C. through his minor
children i.e. Jasvinder Bansal and Manak Shah against Sunita Rani
(Accused) and Hem Raj (Co-accused) alongwith the Principal of Mai Nikko
Devi School, Mansa in the Court of S.D.J.M. Sunam and S.D.J.M. Sunam
passed order of 17-07-2013 by dismissing the allegations in the complaint
by observing that no offence u/s 420/465/467/468/471of I.P.C. is made out.
He observed that if possible only offence comes under the offence u/s 464 of
I.P.C. He further observed that as the Civil Litigations are pending between
the parties and directed the concerned Civil court to entertain the matter u/s
340 of Cr.P.C. The Photo Copy of such order is attached herewith. Moreover,
Suresh Kumar went in revision against such order, which is pending in the

Court of Honble Session Judge Sangrur, so the registration of present FIR is

clear cut misuse of process of law and as such accused is entitled for bail.
(8) That accused had filed one complaint u/s 420/465/467/468/471/120-B/34 of
I.P.C. against Suresh Kumar; Complainant and other four persons, who got
prepared a Forged Will, which is pending in the Court of S.D.J.M. Sunam.
So present case registered against the accused is to pressurise the accused
(Sunita Rani) to get dismissed her complaint.
(9) That the both the co-accused i.e. Bharat Bhushan and Hem Raj had been
apprehended by the Police, so the accused has strong apprehension that
Police can apprehend her at any time and Police is raiding the house of the
accused to arrest her in connivance with the complainant. Moreover, the
relief of Anticipatory bail is necessary to the accused at this stage, otherwise
a stigma of Jail will attached to the accused, who is respectable person of
the society. Moreover, the children of the accused cannot remain alone
without the company of the accused, because the responsible person of
family of the accused named Bharat Bhushan (Maternal Uncle) and Hem Raj
are already in custody.
(10) That no recovery has to be effected as any record which Police wanted to
collect is either in the custody of Mai Nikko Devi School or with Punjab
School Education Board.
(11) That till today the Police had failed to pin-point the document which were
forged and they need to collect those documents
(12)That this is the first case ever registered against the accused.
(13) That accused undertakes to abide by all the conditions imposed by this
honble court.
(14) That the arrest of the accused Sunita Rani may kindly be stayed till the
decision of the present bail application.
It is therefore prayed that relief of Anticipatory bail may kindly be granted
to the accused by directing the Police to not to arrest the accused and release the
accused in the event of arrest of accused, as accused is ready to join the
investigation and co-operated with the Police.
Dt.

Submitted by:

Sunita Rani w/o Hem Raj r/o Grewal Street,

Cinema Road, Masna (Accused/Applicant)
Through Counsel:
Mr. Vikram Gupta, Advocate