IN THE COURT OF SH.DHEERAJ MITTAL, LD.

METROPOLITAN

MAGISTRATE, PATIALA HOUSE COURTS, NEW DELHI

IN THE MATTER OF:

State Versus Sushil
s/o
R/o H.No.B-50, Gali No.4.
Nasirpur, New Delhi.

FIR No.710/10-09-2015.
U/s 380/406/34 IPC
P.S. Sagarpur,
New Delhi

Application 437 Cr.P.C.for Bail.

Sir,

The applicant/accused respectfully as under:-

1. That the applicant/accused is peace-loving and

law abiding citizens of India. He is totally

innocent and has been falsely implicated in the

above said FIR/case.

2. That the applicant was arrested from his house

on 09-09-2015 at about_______and was to be

produced before this Hob’ble Court on 11/9/2015

whereas relatives of the applicant his counsel

were remained present before this Hon’ble Court

 on 11-09-2015 from 1.00 pm to 5.00pm but the

accused was not produced for the reason best

known to IO. However, none of the relatives of

applicant was informed regarding the offence

and arrest of the applicant. Thereafter,

relatives of the applicant reached at PS.

Sagarpur in the evening as to know the under

which case/offence the applicant was arrested

and for what reason the applicant was not

produced on 11-09-2015. Thereafter, the

relatives of the applicant was informed about

the above said FIR and arrest of the applicant

and thereafter, the applicant was produced on

12/09/2015 before the Ld. Duty M.M. and was

sent in J/C.

3. That in fact father of the applicant was

suffering from Dengu fever and the doctor had

prescribed him to various test and the

applicant had gone to bring the investigation

report of his father namely Sheeshpal on 09-09-

2015 and return very soon with report. So

 absolutely the applicant, never tried to flee.

Photocopy of reort

4. That the informant never came to the house of

the applicant at any point of time as alleged

in the FIR.

5. That above said FIR has been got registered on

the basis of civil transaction and the

applicant has not committed any offence.

6. That nothing has been recovered from the

accused and nothing is to be recovered from the

accused person, as no offence has taken place.

The FIR has been registered under a hatched up

plan in collusion with police official.

7. That applicant is not required for further

investigation.

8. That presentation of Challan and thereafter

trial will take long time and no useful purpose

will be served by detaining the applicant behind

the bar for such a long time.

9. That the accused is sole bread earner of his

family and no other adult male person is to feed

the family.

10. That applicant undertakes to abide by all the

terms and conditions as may be imposed by this

Hon’ble Court while granting him bail.

11. That the applicant/accused undertakes to appear

before this Hon'ble court on each and every date

of hearing.

It is therefore, respectfully prayed that the

accused may kindly be granted bail in the interest

of justice.

Applicant/accused
(In J/C)

Through counsel

N/Delhi Sharad Chandra Jha & J.K.Mishra

Date:__/__/2015 Advocates