IN THE COURT OF CITY CIVIL AND SESSIONS JUDGE AT

BANGALROE (CCH-71)

CRL.MISC.NO. /2020
BETWEEIN:

1. PRASANNA NS
S/o Siddalingaiah,
Aged about 38 years,
#60/61, 5th Cross, 5th Main,
Ullal Main Road,,
Jnanajyoti Nagar
Bangalore-560056… Petitioner

And

State of Karnataka
By Jnanabharati P.S.
Rep.by Public Prosecutor,
Bangalore

Memorandum of Criminal Petition U/s 438 of the code of Criminal

Procedure

The Petitioner above named humbly submits as follows:

1) That the address of the Petitioners for the purposes of issue of process
of law, as mentioned in the cause title and they may also serve
through their councils PRAMOD K B, Advocate, No. 209, 2nd Floor,
Midford House, MG Road, Bangalore-560001.

2) The address of the respondent for the said similar purpose is as

mentioned in the cause title.

3) The respondent police have registered a criminal case against these

petitioner for the offence punishable U/S 3(1)®, 3(1)(s), 3(2)(v-a),
3(1)(w)(i)(ii) of SC/St (PREVENTION OF ATTROCITIES) ACT,
1989 and U/s 427, 506, 323, 354 of IPC1860. Copy of the Complaint
and FIR are herewith produced for the kind perusal of this Hon’ble
Court as Document No. 1 and 2.
 BRIEF FACTS OF THE CASE

1) The Complainant has lodged a complaint alleging that the

Petitioner/accused is a neighbor, he was behaving indecently from
past 6 months and following the complainant wherever she go,
roaming around the Complainant Parlor, giving different hand signals,
watching the complainant when she doing cleaning of passage and
also had quarrel with her husband 3 to 4 times. On 18.012020 at
about 11.45 PM, the accused was damaged flower pots, same is
questioned by the Complainant by that time the accused starts quarrel
with Complainant, put his hands o Complainant Shoulder, pull the
clothes of the Complainant, and also started quarrel with Complainant
husband and with neighbors who came to rescue the Complainant, and
scolded the Complainant used words as Holeya, Madiga and
threatened to cause death. And complainant states in her complaint
this incident happened till 1.00 AM. Hence the complaint for the
suitable action against the accused person.

2) Upon the said Complaint, the respondent police have registered the
case against the accused person and arrested the petitioner herein as
accused and produced him before the Court along with Remand
Application and then he has been remanded to judicial custody, being
innocent of the alleged offence, the petitioner approached this Hon’ble
Court seeking grant of bail on the following grounds,

GROUNDS FOR BAIL

1) The petitioner is innocent and law abiding citizen and he has not
committed any offence as alleged against them.
2) The complainant is in the habit of filling false case against innocent
people dishonestly with an intention to extract money from them like
wise this petitioner become victim in the hands of complainant.

3) The complainant by taking the disadvantage of this caste filling false

case against the innocent’s people so has to have a dominance in the
locality and to have a control and command over the weaker section
like petitioner.

4) The petitioner is falsely implicated in the alleged crime with sole

intention of causing harassment and to put continuance threatens on
them so has to obey the words of complainant.

5) The petitioners are permanent resident of Kalalughatta Village,

Thyamagondalu Hobli, and Nelamangla Taluk. Petitioner doing
plumber work for his lovely hood in the Bangalore City, Petitioner
No.2 is agriculturalist in the above address only.

6) The Petitioner and Complainant are residing as neighbors in a same

building since from 8 years, they had good neighbor hood
relationships and respecting each other and also had wishing and
inviting for festivals from past 8 years without knowing their castes.

7) The Petitioner is having two daughters studying in 2nd and 4th standard
respectively, who are not well from the arrest of Petitioner.

8) The Petitioner is running a computer education institute providing

computer education to Poor eligible people and he has involved in a
social activities to serve the poor people.

9) The petitioner is ready and willing to furnish the solvent surety for
their bail and they are ready to abide any conditions.
 10) The petitioner are ready to and undertake to appear before the
I.O. as well as learned court of first instances and assist for smooth
investigation and trail.

11) The petitioner undertakes that they will not flee from justice
and they will not tamper or induce the prosecution witnesses in any
manner.

12) The petitioner with the leave of this Hon’ble court may urge
some other grounds, if any, at the time of arguments in the above case.

PRAYER

WHEREFORE the petitioner prays that this Hon’ble Court be pleased to

enlargethe Petitioner on bail t in Crime No.26/2020 for alleged offences
punishable U/S 3(1)®, 3(1)(s), 3(2)(v-a), 3(1)(w)(i)(ii) of SC/St
(PREVENTION OF ATTROCITIES) ACT, 1989 and U/s 427, 506, 323,
354 of IPC1860 registered by the Jnanabharati Police to meet the ends of
justice.

BANGALROE
DATE;23.01.2020 ADVOCATE FOR PETITIONER