Problem-1, Accused, Model-1.

IN THE COURT OF THE VIII METROPOLITAN MAGISTRATE:

VISAKHAPATNAM:A.P

C.C.NO.12/2016
BETWEEN:
Mr. Ravi,
S/o.sri .Kumar
Aged above 55 years,
Govt.servent,
Address: Plot no-225
Sector -5, M.V.P.COLONY,
Visakhapatnam -17.A.P
COMPLAINANT
AND
Mr.Kiran ,
S/O.Sri.Appa Rao,
Aged 50 years,
Occupation: proprietor,
Mahalakshmi jewellery shop,
Dwarakanagar,
Visakhapatnam -25 .A.P
..Accused

PETITION FILED ON BEHALF OF THE ACCUSED UNDER SECTION 437 CR.P.C

OFFENCES UNDER SECTIONS 148,149,355,356 AND 418 OF I P C.

The address for services of summons, notices and processes

etc. on the above named Petitioner/Accused is the same as that of his
counsel Shri Ram Kumar, Advocate, Advocate Association, and
Visakhapatnam.

The address for service of summons, notices and process of the above
named Complainant is the same as that mentioned in the above cause title
THE ABOVE NAMED PETITIONER/ACCUSED HUMBLY SUBMITS AS
FOLLOWS:
1. The Petitioner is accused in C.C.No.12of 2016 on the file of
this Honble Court, and is alleged to have committed the
offence under Sections 148,149,355,356 and 418 of IPC.
2. The Petitioner humbly submits that he is the owner and
Proprietor of the Mahalakshmi Jewellery Shop and running the
same since 25 years. The present investment value in the
shop is about Rs. 20 crores. He hails from a good and
respectable family without having any criminal background.
3. It is submitted that a complainant has been made against the
Petitioner and the same is pending for enquiry before the
Court of the VIII Metropolitan Magistrate, Visakhapatnam.A.P.
4. The petitioner/Accused humbly submits that he is not guilty of
the offences alleged by the respondent/Complainant. He is an
innocent person.
5. The petitioner is remanded to judicial custody on 25- 1-2016.
6. The present petition is the first, and no other similar petition is
either filed or pending before any other court including the
Honble Court of A.P.
7. The petitioner /Accused submits that he is ready and willing to
furnish any sureties as may be directed by this Honble court,
it he is released on bail.

PRAY
For the reasons mentioned above it is humbly prayed that this
Honble Court may be pleased to release /enlarge the
petitioner/accused on bail in C.C.No.12/2016 on the file of the
Honble Court pending trial on such terms and conditions and
with or without any surety of security as this Honble Court
may deem fit and proper in the interest of justice and fair play.

Place: Visakhapatnam SD/-

Date: Petitioner/Accused
 SD/-

Counsel for the

Petitioner