IN THE COURT OF ______________, ASJ,
ROHINI DISTRICT COURT, DELHI,
IN THE MATTER OF:
Sakshatkaar, S/o Manoj Kumar, r/o B/502, Radhe Krishan Appt., Rajendra Nagar, Delhi …………Applicant
FIR No.: _______
U/s: 307 IPC
APPLICATION UNDER SECTION 437 OF THE CODE OF CRIMINAL PROCEDURE 1973 FOR GRANT OF BAIL ON BEHALF OF THE APPLICANT.
MOST RESPECTFULLY SUBMITTED:
Brief Facts of the case:
- That the Incident of attempt to murder took place on__/__/____ in front of __________________ Delhi around ______hrs when an attempt to murder Ramesh by Sakshatkaar was made because of which ____________ got injured.
- That FIR was filed Ramesh S/o Dharmendra, according to him the accused tried to shoot him but missed since it was midnight.
- That there was no pistol or bullets found from the place of the incident and neither there was any witness to prove the allegations.
- That the whole investigation was done only on the basis of statement given by the informant, the injured person.
Most Respectfully Showeth:
- That the present application under section 437 of the Code of Criminal Procedure 1973 is being filed by the Petitioner for seeking grant of bail in FIR No. ________ registered at Police Station _____________. The present petition is being moved as the Petitioner has been arrested on _______ in connection with the said FIR. The petitioner is now in judicial custody.
- That the Petitioner is innocent and is being falsely implicated in the above said matter as he has nothing to do with the matter.
- That there is no reasonable ground to believe the accused guilty of the offence.
- That no previous application for bail has been filed in any court.
- That no previous Conviction found against the applicant/accused. Annexure A-(Chargesheet)
- That Supreme Court in the case Gurucharan Singh v. State, held that while exercising discretion, the first and foremost thing to be remembered is that the object of detention pending criminal proceedings is not punishment and that law favors allowance of bail which is the rule, and the refusal of it is an exception.
- That the Petitioner is a responsible person and is living at the above-mentioned address which is his permanent address also from where he is living.
- That the Petitioner is innocent and no useful purpose would be served by keeping him in custody and this is a fit case for grant of bail.
- That the Petitioner undertakes to abide by the conditions that this Honorable Court may impose at the time of granting bail to the Petitioner and further undertakes to attend the trial on every date of hearing.
- That the Petitioner has not filed any other similar petition before this or any other Honorable Court for grant of bail in case of the present FIR.
In view of the above-stated facts and circumstances it is most respectfully prayed that this Honorable Court may be pleased to:
- Grant bail to the Petitioner in connection with FIR No. _________ registered under section 307, for the offence of attempt to murder at Police Station ________________.
- Pass any other such order as this Honorable Court may deem fit and proper in the interest of justice.
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