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IN THE HON’BLE HIGH COURT OF MADHYA PRADESH

BENCH AT GWALIOR

Misc. Criminal Case No. : /2018

//Cause Title//

Applicant : Tarun Kushwah

Versus

Respondent : The State of Madhya

Pradesh

Index

Sr. Description of Annexure No. Page No. of

No. Documents (if Any) the
Document

1. Memo of Application

2. Order of lower court Annexure A/1

3. Documents

4. Power

Place:- Gwalior Humble Applicant

Date:-
through counsel

Anil Mishra
(Advocates)
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(Applicant is in Jail)
IN THE HON’BLE HIGH COURT OF MADHYA PRADESH
BENCH AT GWALIOR
Misc. Criminal Case No. : /2018

//Cause Title//

Applicant:- Tarun Kushwah S/o Sh. Rajesh

Kushwah, Age: 20 Years, R/o:
Nai Sadak, Lashkar, Gwalior,
District Gwalior (M.P.)

-Versus-

Respondent:- The State of Madhya Pradesh,

Through Police Station Indarganj
Distt. Gwalior (M.P.)

(FIRST BAIL APPLICATION UNDER SECTION 439 OF

THE CODE OF CRIMINAL PROCEDURE, 1973)

Whether any Bail

application is Particulars of Bail Application
pending before or
already disposed of
by (if yes , give Number Date of Result
particulars) Order
Hon'ble Supreme Nil Nil Nil
Court of India
Hon'ble High Court Nil Nil Nil

Court subordinate to 122/18 28/03/2018 Dismissed

High Court

Particulars of Crime Particulars of Impugned order

Crime No. 122/2018
Police Station: Indarganj,
District Gwalior (M.P.)
Offence u/s 8/15 of
N.D.P.S. Act
Date of Arrest: 27.03.18
Application No.: 122/18
Bandal
Name of the Judge: Shri A.K.
Sohane
Designation of the Court:
XIth Additional Session Judge,
and Special Judge(NDPS)
Gwalior
Place : Gwalior (M.P.)
Date of the Order: 28/03/18
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The applicant named above respectfully begs to submit as

under :-

1. That, this is applicant’ FIRST BAIL APPLICATION for

bail before the Hon'ble High Court of Madhya
Pradesh.

2. That, there is no application under section 439

of the Code of Criminal Procedure for bail of
the applicant is pending before or decided by
the Supreme Court, any High Court or any
Court Subordinate to a High Court, the
particulars thereof.

3. That the co-accused persons have not filed any

bail application.

4. That, the copy of the order of the Lower

Learned Court is also annexed herewith and
mark as Annexure A/1.

5. Facts of the case in brief :

That, as per the prosecution story, on 27.03.18

on the information given by the informant the
police Indarganj Distt. Gwalior reached at the
spot at Nirdhan Nagar a shop of Emron Battery
and Inverter, Shinde Ki Chhawani , Gwalior
and during the searching illegal substance
(Chura Doda) quantity 2 Kg and 50 gram had
been seized from the possession of present
applicant. On the basis of aforesaid the crime
has been registered against the present
applicant and he has been taken into custody.
Hence the present application.
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6. Grounds:

A. That, the applicant has not committed any

offence he has been falsely implicated. A
false case has been got registered by the
police though he has not committed any
offence.

B. That, it is alleged against the applicant

that he was having illegal substance
(Chura Doda) total quantity 2 kg. 50 gram
but it is required to mention here that the
present applicant having not any illegal
substance; he has not committed any
offence; he has falsely been implicated in
the crime. He is an innocent person.

C. That, applicant only the person who can

look after the family affairs as entire male
members of the family is behind the bars
and sufficient period has been over
therefore, applicant deserves to be granted
bail.

D. That it is required to mention here that

the present applicant is student; the
document is being submitted alongwith
this application.

E. That, the applicant has been involved in

the case in falsify manner, therefore , he
deserves to be granted bail in the interest
of Justice.

F. That, it is submitted before this Hon'ble

High Court that the applicant is innocent,
law abiding and peace loving citizen of
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society and there is no evidence against

the present applicant.

G. That, the applicant will not temper the

prosecution witnesses nor he will try to
absconding.

H. That, applicant shall abide all the

condition which shall be imposed by the
Hon'ble High Court.

I. That, the other grounds if any will be

submitted at the time of final arg ument.

7. That, the applicant is the permanent resident

of Nai Sadak, Lashkar, Gwalior, District Gwalior
(M.P.) and in case of his bail there is no chance
of his absconding.

8. That, the applicant is ready to furnish

adequate amount of surety and shall abide by
all the direction and conditions which may be
imposed by the court.

PRAYER

It is, therefore, most humbly and respectfully

prayed that this present bail application may kindly
be allowed and further present applicant kindly be
enlarged on bail.

Place:- Gwalior Humble Applicant

Date:-
through counsel

Anil Mishra
(Advocate)