Regular bail application under Section 439 CrPC in FIR under Essential Commodities Act and IPC
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IN THE COURT OF THE LD. DISTRICT & SESSIONS JUDGE, SAKET COURTS, SOUTH DISTRICT, NEW DELHI
BAIL APPLICATION NO. Bail application number OF 2021
IN THE MATTER OF:
Applicant's name (cause title)Versus Respondent/State name
INDEX
| S.NO. | PARTICULARS OF DOCUMENTS | PAGES |
|---|---|---|
| 1. | Bail Application under Section 439 Cr.P.C. by the Applicant/Petitioner |
| 2. | ANNEXURE-A; Order dated Date of bail dismissal order dismissing the bail application, passed by Ms. Name of Ld. CMM, Ld. CMM, Saket Courts, Delhi. |
| 3. | ANNEXURE-B; Copy of FIR No. FIR number dated FIR date registered at Crime Branch Police Station, Chanakyapuri, New Delhi. |
| 4. | ANNEXURE-C (Colly); Copies of police complaints sent by the brother of the Applicant, namely Applicant's brother's name, and the complaint sent by the Counsel to the Commissioner of Police, Delhi and Gurugram. |
| 5. | ANNEXURE-D (Colly); Copies of Licence documents (Form 20B/21B) and the licence renewal letter of Name of firm for licence renewal letter issued by the Assistant Commissioner, Food & Drug Administration, Jalgaon. |
| 6. | ANNEXURE-E (Colly); Copy of Licence (Form-D) of M/s. Name of Ayurveda firm dated Date of Form-D licence. |
| 7. | ANNEXURE-F; Copies of the Sale-Purchase Agreement dated Date of sale-purchase agreement between M/s. Name of first firm and M/s. Name of second firm, along with bank statements (showing transfers of amounts on First bank transfer date, Second bank transfer date and Third bank transfer date). |
| 8. | ANNEXURE-G (Colly); Copies of the identity proof of the Applicant. |
| 9. | Vakalatnama |
APPLICANT
Through
Date:
New Delhi
COUNSEL
Law firm name & ASSOCIATES
Office No.: Counsel's office number
Mob.: Counsel's mobile number
Email: Counsel's email address
IN THE COURT OF THE LD. DISTRICT & SESSIONS JUDGE, SAKET COURTS, SOUTH DISTRICT, NEW DELHI
BAIL APPLICATION NO. Bail application number OF 2021
IN THE MATTER OF:
Applicant's name (cause title)
Versus
Respondent/State name
Applicant's name
S/o Father's name
Age: Applicant's age, Occupation: Applicant's occupation,
R/o Applicant's address
Aadhaar Card No.: Aadhaar card number
FIR No. FIR number dated FIR date
PS: Police station
Under Sections 3/7 Essential Commodities Act, 1955, Section 3 of the Epidemic Diseases Act, 1897,
Sections 420/468/471/188/120B/34 IPC
The APPLICANT is in custody since Date since in custody
FIRST BAIL APPLICATION ON BEHALF OF THE APPLICANT/PETITIONER UNDER SECTION 439 Cr.P.C. IN FIR NO. FIR number, PS: Police station
MOST RESPECTFULLY SHOWETH:-
1.That the Applicant is a law-abiding citizen of India, residing at the address stated above. By way of the present criminal bail application under Section 439 Cr.P.C., the Applicant seeks regular bail in respect of his arrest in FIR No. FIR number dated FIR date, registered at Crime Branch Police Station, Police station, on the facts and circumstances set out hereinafter.
2.That the Applicant approached the Ld. Chief Metropolitan Magistrate seeking regular bail, and the Ld. CMM was pleased to dismiss the bail application on Date of dismissal of bail by CMM. A copy of the dismissal order is annexed hereto as Annexure-A.
3.That the Applicant submits that he was falsely implicated and apprehended from Name of hotel, Location of Hotel Lemon Tree. On Date of complaint, his younger brother, Applicant's brother's name, sent a complaint to the higher authorities regarding the illegal arrest of the Applicant from the said hotel. The Counsel for the Applicant also made a complaint regarding the illegal arrest to the Commissioner of Police, Delhi, and to the Commissioner of Police, City of Commissioner of Police (Gurugram). The said FIR is annexed herewith as ANNEXURE-B, and copies of the police complaints are annexed herewith as ANNEXURE-C (Colly).
4.That it is clarified at the outset that the father of the Applicant, Father's name (holding the qualification of D.Pharmacy), holds a licence in Form-21C under Rule 63A, issued by the Assistant Commissioner, Food & Drug Administration, City of Food & Drug Administration (Jalgaon), with effect from Licence effective date, in the name of "Name of licensed firm" at Address of licensed firm, and the same is still operational.
5.That another licence in Form-20B and Form-21B in the name of "Name of licensed firm" was obtained by Name of licensee from the Assistant Commissioner, Food & Drug Administration, in respect of the premises at Address of licence premises (Underground), Plot No. Plot number. Admittedly, the said licence was last renewed on Date of last licence renewal and is valid up to Licence validity end date. Copies of the licence of "Name of licensed firm" and the licence renewal letter of "Name of licensed firm" issued by the Assistant Commissioner, Food & Drug Administration, Jalgaon, are annexed herewith as ANNEXURE-D (Colly).
6.That the Applicant, after completing his B.Pharmacy course, joined his father's business in Year of joining father's business. Thereafter, he also obtained a licence in Form-D under Rule 6 with effect from Form-D licence effective date in the name of "Name of Ayurveda firm", through which he supplies Ayurvedic products to various ashrams. A copy of the licence (Form-D) of Name of Ayurveda firm dated Date of Form-D licence is annexed herewith as ANNEXURE-E.
7.That the Applicant, Applicant's name, also carries on the business of procuring and supplying masks and medical gloves under "First business name" as well as under "Second business name", wherein he was assisted by Name of assistant (Rajesh Indulkar). In the course of the said business of masks and medical gloves, the Applicant came into contact with Name of business contact of Contact's firm or city. It is pertinent to mention that a Sale-Purchase Agreement dated Date of sale-purchase agreement was executed between M/s. Name of first firm and M/s. Name of second firm, and consequential transfers of amounts were made through banking channels on First bank transfer date (Rs. First transfer amount (₹)/-), Second bank transfer date (Rs. Second transfer amount (₹)/-) and Third bank transfer date (Rs. Third transfer amount (₹)/-) by M/s. Name of paying firm to M/s. Name of receiving firm, which clearly shows that the Applicant was engaged in the lawful business of masks and medical gloves, and for that purpose alone he had come to City of business visit (Delhi) along with Name of companion. Copies of the Sale-Purchase Agreement dated Date of sale-purchase agreement between M/s. Name of first firm and M/s. Name of second firm, along with the bank statements (showing transfers of amounts on First bank transfer date, Second bank transfer date and Third bank transfer date), are annexed herewith as ANNEXURE-F.
8.That it is pertinent to mention that, armed with the valid and existing licence of M/s. Name of licensed firm, the Applicant herein also held a Purchase Order dated Purchase order date for Remdesivir injections, and for that purpose, as well as for the purpose of completing the transaction with M/s. Name of counterparty firm, the Applicant and Name of companion (Rajesh Indulkar) came together to City of visit (Delhi) on Date of visit to Delhi. A copy of the Purchase Order dated Purchase order date of M/s. Name of firm on purchase order (for Remdesivir injections) is annexed herewith as ANNEXURE-G.
9.That on Date of stay at hotel, the Applicant was staying with Name of companion (Rajesh Indulkar) in Room No. Hotel room number, when at about Time of police arrival pm, the investigation team of Crime Branch Police Station arrived there on the pretext that the arrested accused, Name of co-accused, in FIR No. FIR number had disclosed the names of Applicant's name and Name of companion (Rajesh Indulkar). It is stated with utmost honesty and accountability that during the personal interrogation as well as the search of Room No. Hotel room number, no incriminating material was found. Even so, from Time custody began on Date of taking into custody, both Applicant's name and Name of companion (Rajesh Indulkar) were taken into custody by the investigation team of Crime Branch Police Station. They were initially taken to Initial place of detention and were thereafter brought to Crime Branch Police Station, Police station, where they were badly beaten, physically tortured and mentally harassed. Shockingly, until Date of illegal detention end, Applicant's name was illegally detained in the police lock-up without his arrest being shown, whereas Name of companion was released from illegal detention on Date of release of Rajesh Indulkar.
10.That at this very stage, it becomes a matter of great importance to place before this Hon'ble Court that the guidelines laid down in paragraph 35 of D.K. Basu vs. State of West Bengal : (1997) 1 SCC 416 were violated completely. It is further submitted that, in the same manner, the Hon'ble Supreme Court in Arnesh Kumar vs. State of Maharashtra : (2014) 8 SCC 273 has clearly laid down as under:-
"As per section 41(1)(b)(ii) of Cr.P.C., when offence is punishable upto 7 years imprisonment; Police officer can only arrest a person,
(a)If he is satisfied that person has committed offence;
(b)Further he should be satisfied that arrest is necessary
(i)to prevent commission of further offence OR
(ii)for proper investigation of offence OR
(iii)to prevent accused from tampering evidence OR
(iv)to prevent accused from threatening witnesses OR
(v)to ensure presence of accused in Court
Police officer has to record reasons in writing.
As per Article 22(2) of the Constitution of India & section 57 of Cr.P.C., within 24 hours of arrest, accused must be produced before Magistrate. If Magistrate is satisfied that arrest is legal [i.e. satisfying requirement u/s.41(1)] then Magistrate authorizes further detention u/s.167 Cr.P.C.. Magistrate has to record his satisfaction in writing. But if Magistrate feels that 'arrest does not satisfy requirement u/s.41(1) then Magistrate cannot authorize further detention u/s.167 Cr.P.C. and has to release accused.
As per section 41A of Cr.P.C. when arrest of person is not required u/s.41(1), then Police Officer has to give him notice for appearance, then accused is obliged to appear before him. If accused complies with the said notice, then accused cannot be arrested. But, if police officer thinks that "arrest is necessary". Then by recording reasons in writing, Police Officer can arrest him. Then also conditions in section 41(1)(b)(ii) will apply and it shall be subject to same scrutiny by Magistrate."
That in the present case of the applicant, the aforesaid decision of the Hon'ble Supreme Court has been clearly violated, thereby infringing his fundamental rights under Articles 14, 19(1)(d), (g), 21 and 22 of the Constitution of India.
11.That it is again pertinent to mention here that on Date of extortion demand, the concerned police machinery commenced demanding an amount of Rs. Amount demanded by police (₹)/- for letting off the applicant/Applicant's name and Name of companion (Rajesh Indulkar). That the police machinery, on Date of taking applicant to hotel, took only the applicant/Applicant's name back to Room No. Hotel room number, and from the locker inside the cupboard of the said room, cash amounting to Rs. Total cash amount (₹)/- was taken out, out of which Rs. Amount for hotel bill (₹)/- was handed over to Name of person paid hotel bill for clearing the hotel bill, whereas cash of Rs. Amount retained by police (₹)/- was retained by the police personnel, even without conducting a seizure panchanama. It is pertinent to mention that the said amount of money was not referable to the crime in question and hence could not possibly have been seized. It is further pertinent to mention that, in addition, the police personnel at that time found two boxes of medical hand gloves, which were taken away by them. That this clearly shows that the applicant Applicant's name and Name of companion (Rajesh Indulkar) had come to Delhi only for dealings relating to medical hand gloves. It is further pertinent to mention that, on the same day, by threatening the applicants with dire consequences of false implication in a fake Remdesivir racket, the said investigation machinery demanded Rs. Amount demanded by police (₹)/- for letting off Applicant's name and Name of companion (Rajesh Indulkar). That it is clarified with utmost honesty and accountability that Applicant's name and Name of companion (Rajesh Indulkar) were in touch with Name of supplier contact regarding the procurement of masks and medical hand gloves as well as genuine vials of Remdesivir injections.
12.That it is pertinent to mention here that the applicant Applicant's name is not at all aware of (i) Name of unknown person (i); (ii) Name of unknown person (ii); (iii) Name of unknown person (iii); and (iv) Name of unknown person (iv). That the applicant is absolutely unaware of these four persons and never met them at any point of time. That on Date of brother's visit to police station, when the applicant's brother, namely Applicant's brother's name, came to Delhi and rushed to the Crime Branch Police Station at Police station, the applicant disclosed to his brother that he had been badly beaten up by the police machinery, and that at that time also the police machinery demanded an additional amount. To save the applicant from false implication, Applicant's brother's name had to borrow the amount from a friend of his, namely Name of friend who lent money, residing at City of friend, and thereafter paid an additional amount of Rs. Additional amount paid to police (₹)/- to the police machinery at the Crime Branch Police Station, Police station.
13.That it is pertinent to mention that thereafter, on Date of release from detention, Applicant's name was freed from the illegal detention at the Crime Branch Police Station, Police station. That a question arises here: if Applicant's name and Name of companion (Rajesh Indulkar) were together and were picked up on Date of pick-up from hotel (at about Time of pick-up pm) from Room No. Hotel room number, then why was Name of released person freed (and that too after illegal detention for 48 hours)? It is again pertinent to mention that if Name of released person was freed, then the similarly placed Applicant's name too ought to have been freed, applying the doctrine of parity. However, treating Applicant's name as a milch cow, an amount of Rs. Total amount extracted by police (₹)/- has so far been extracted from him as illegal gratification for showing favour while discharging public duties. That the police machinery thereafter started insisting that the entire demand of Rs. Total demanded amount (₹)/- be complied with, failing which Applicant's name would be implicated in an illegal racket of COVIPRI, i.e., Remdesivir injections.
14.That it has been shown by the police that on Date of alleged recovery of injections, Name of unknown person (i) with 6 Remdesivir injections and Name of co-accused with 6 Remdesivir injections were arrested at Place and date of alleged arrest. It is submitted with utmost accountability and honesty that this is absolutely wrong, and that Applicant's name never knew (i) Name of unknown person (i); (ii) Name of unknown person (ii); (iii) Name of unknown person (iii); and (iv) Name of unknown person (iv). Further, Applicant's name was never in possession of 6 vials of COVIPRI, i.e., Remdesivir injections, and he was not at all with Name of co-accused at Place (Yamuna Vihar), New Delhi, on Date of alleged arrest. The investigation machinery has created a completely false record.
15.That the applicant had never been to Place (Yamuna Vihar) to meet Name of person allegedly to meet, Name of person allegedly to meet or Name of person allegedly to meet at any point of time.
16.That it is again pertinent to mention that from Start date of illegal detention to End date of illegal detention, the applicant was illegally detained and mercilessly beaten in police custody, in flagrant violation of his fundamental rights under Articles 14, 19(1)(d) and 21 of the Constitution of India, and directly in the teeth of the law laid down by the Hon'ble Supreme Court in D.K. Basu vs. State of West Bengal : (1997) 1 SCC 416 and Arnesh Kumar vs. State of Bihar : (2014) 8 SCC 273.
17.That thereafter, on Date of production before Duty MM, the applicant was produced before the Ld. Duty MM, along with a remand application by the IO, Crime Branch Police Station, Chanakyapuri, through video conference, when the accused was admittedly in their police custody, and the Ld. Duty MM was pleased to grant 3 days of police custody remand to the present applicant, i.e., upto End date of police custody remand.
18.That thereafter, through a video-conference hearing, the applicant Applicant's name was produced before the Ld. Duty MM for remand on Date of remand production, and it appears that he has been remanded to MCR for 14 days. It is clarified that on Date brother called to police station, the applicant's brother was called to the Crime Branch Police Station, Police station, and two boxes of medical hand gloves, as well as Applicant's name (possessive) cell-phone, were handed over to Applicant's brother's name.
19.That, at this juncture, it is clarified that the Applicant is seriously suffering from a life-long disease of Ulcerative Colitis (Ulcerative colitis is an inflammatory bowel disease (IBD) that causes inflammation and ulcers (sores) in the digestive tract. Ulcerative colitis affects the innermost lining of the large intestine (colon) and rectum. Symptoms usually develop over time, rather than suddenly). He is on continuous medication, and the Applicant's brother has received information that the Applicant is unwell and seriously ill owing to an IBD stroke while in jail.
20.That, in view of the facts and circumstances mentioned hereinabove, the present Applicant begs to file a regular bail application under Section 437 of Cr.P.C. in respect of his arrest in FIR No. FIR number dated FIR date registered with Crime Branch Police Station, Police station, on the following, amongst several other, grounds, which are without prejudice to one another.
21.That the guidelines laid down in paragraph 35 of D.K. Basu vs. State of West Bengal : (1997) 1 SCC 416 have been completely violated, and, in the same manner, the Supreme Court in Arnesh Kumar vs. State of Maharashtra : (2014) 8 SCC 273 clearly laid down as under:-
"As per section 41(1)(b)(ii) of Cr.P.C., when offence is punishable upto 7 years imprisonment; Police officer can only arrest a person
(a)If he is satisfied that person has committed offence;
(b)Further he should be satisfied that arrest is necessary
(i)to prevent commission of further offence OR
(ii)for proper investigation of offence OR
(iii)to prevent accused from tampering evidence OR
(iv)to prevent accused from threatening witnesses OR
(v)to ensure presence of accused in Court
Police officer has to record reasons in writing.
As per Article 22(2) of the Constitution of India & section 57 of Cr.P.C., within 24 hours of arrest, accused must be produced before Magistrate. If Magistrate is satisfied that arrest is legal [i.e. satisfying requirement u/s.41(1)] then Magistrate authorizes further detention u/s.167 Cr.P.C.. Magistrate has to record his satisfaction in writing. But if Magistrate feels that 'arrest does not satisfy requirement u/s.41(1) then Magistrate cannot authorize further detention u/s.167 Cr.P.C. and has to release accused.
As per section 41A of Cr.P.C. when arrest of person is not required u/s.41(1), then Police Officer has to give him notice for appearance, then accused is obliged to appear before him. If accused complies with the said notice, then accused cannot be arrested. But, if police officer thinks that "arrest is necessary". Then by recording reasons in writing, Police Officer can arrest him. Then also conditions in section 41(1)(b)(ii) will apply and it shall be subject to same scrutiny by Magistrate."
In the present case of Applicant's name, the aforesaid decision of the Supreme Court has been clearly violated, thereby violating his fundamental rights under Articles 14, 19(1)(d), (g), 21 and 22 of the Constitution of India.
The investigating machinery has created a completely false record. Therefore, as per the parameters laid down by the Hon'ble Supreme Court in S.W. Palantikar vs. State of Bihar : (2002) 1 SCC 241, the provisions of Section 420 of the IPC are not attracted in the present case with regard to the Applicant.
20.That FIR No. FIR number dated FIR date does not mention the name of the present Applicant. Only because the accused Name of co-accused (Mohan Kumar Jha), after being arrested, has falsely implicated the present Applicant, and therefore, as per the provisions of Sections 25 and 26 of the Indian Evidence Act, the present Applicant has been illegally and falsely framed in the present FIR No. FIR number dated FIR date, and he needs to be released on bail.
21.That the guidelines laid down by the Hon'ble Supreme Court in Arnesh Kumar vs. State of Bihar : (2014) 8 SCC 273 have been clearly violated. When the present offences in question mentioned in FIR No. 70/2021 are punishable with imprisonment of less than 7 years, the police officer was bound to issue notice under Section 41 of Cr.P.C. and ought to have called the Applicant before directly resorting to his arrest. Therefore, his arrest is illegal per se and in gross violation of the mandate of Section 41 Cr.P.C. as well as the law laid down in (2014) 8 SCC 273.
22.That the parameters for grant of regular bail laid down by the Hon'ble Supreme Court in Sanjay Chandra vs. CBI : (2012) 1 SCC 40 are as under:-
"21. In bail applications, generally, it has been laid down from the earliest times that the object of bail is to secure the appearance of the accused person at his trial by reasonable amount of bail. The object of bail is neither punitive nor preventative. Deprivation of liberty must be considered a punishment, unless it can be required to ensure that an accused person will stand his trial when called upon. The courts owe more than verbal respect to the principle that punishment begins after conviction, and that every man is deemed to be innocent until duly tried and duly found guilty.
22.From the earliest times, it was appreciated that detention in custody pending completion of trial could be a cause of great hardship. From time to time, necessity demands that some un-convicted persons should be held in custody pending trial to secure their attendance at the trial but in such cases, `necessity' is the operative test. In this country, it would be quite contrary to the concept of personal liberty enshrined in the Constitution that any person should be punished in respect of any matter, upon which, he has not been convicted or that in any circumstances, he should be deprived of his liberty upon only the belief that he will tamper with the witnesses if left at liberty, save in the most extraordinary circumstances.
23.Apart from the question of prevention being the object of a refusal of bail, one must not lose sight of the fact that any imprisonment before conviction has a substantial punitive content and it would be improper for any Court to refuse bail as a mark of disapproval of former conduct whether the accused has been convicted for it or not or to refuse bail to an un-convicted person for the purpose of giving him a taste of imprisonment as a lesson."
Applying the said parameters laid down by the Hon'ble Supreme Court to the facts of the present case, it is most respectfully submitted that a clear case for grant of regular bail to the Applicant is made out.
Admittedly, the present Applicant satisfies those parameters on the facts of the present case and is therefore entitled to be released on bail by applying the parameters laid down by the Supreme Court in Sanjay Chandra vs. CBI : (2012) 1 SCC 40.
23.That the present Applicant has fully cooperated with the investigating machinery during his custodial interrogation right from the beginning.
24.That the Applicant is seriously suffering from a life-long disease of Ulcerative Colitis (Ulcerative colitis is an inflammatory bowel disease (IBD) that causes inflammation and ulcers (sores) in the digestive tract. Ulcerative colitis affects the innermost lining of the large intestine (colon) and rectum), and the medical report on record clearly shows that the Applicant is under continuous medical treatment for the same. On these medical grounds also, the present Applicant needs to be released on bail.
25.That the provisions of Section 3 and Section 7 of the Essential Commodities Act, 1955 are not at all attracted in the case of the present Applicant. It is clarified that the present Applicant, along with other members of his family, runs "Business name" at Address of business. The Applicant is carrying on the business of procuring medical gloves and supplying the same to authorized dealers in City of authorized dealers (Jalgaon). Since the Applicant is a pharmacist and his family operates a licensed Name of licensed concern, the Applicant had come to Delhi for placing certain orders for medical hand gloves. It is further clarified that the Applicant was never found selling Remdesivir vials at higher prices. It is furthermore submitted that, no order issued under Section 3 of the Essential Commodities Act, 1955 having been violated by the Applicant himself, the provisions of offence under Section 7 of the said Act are not attracted.
26.That Section 3 of the Epidemic Diseases Act, 1987 (1897) is not attracted to the present Applicant in any manner. It is respectfully clarified that the present Applicant had come to Delhi with the sole purpose of placing an order for medical gloves, and that he is in no way involved in the sale of Remdesivir vials at inflated prices. Furthermore, the present Applicant was never caught selling Remdesivir vials at inflated prices. Therefore, the present Applicant has not disobeyed any order issued under the said Act. The Applicant is a law-abiding citizen who had come to Delhi only to conduct a legitimate business activity, namely, relating to medical gloves, in respect of his licensed concern, "Name of licensed concern". Therefore, neither Section 3 of the Epidemic Diseases Act, 1897 nor Section 188 of the Indian Penal Code is attracted to the facts of the present case.
27.That the prosecution has no evidence to show that the present Applicant was involved in any pre-planned conspiracy to sell Remdesivir vials at inflated prices. Accordingly, in terms of the parameters laid down by the Hon'ble Supreme Court in Rajiv Kumar vs. State of UP: (2017) 8 SCC 791, the provisions of Section 120B of the Indian Penal Code are not attracted to the facts of the present case.
28.That in terms of the parameters laid down by the Hon'ble Supreme Court in Suresh vs. State of UP: (2001) 3 SCC 673, the ingredients of Section 34 of the Indian Penal Code are not attracted to the facts of the present case.
29.That the present Applicant has aged parents, a young wife and a three-year-old daughter to look after, all of whom are solely dependent upon him. Further, the Applicant himself requires continuous medication and attendance of doctors for the treatment of his Ulcerative Colitis. The family owns immovable properties, namely, a residential house (the address whereof is stated in the cause title) and shops (the address whereof is stated in the licence of Name of licensed firm). Therefore, there is no possibility of the Applicant absconding if he is released on bail. The Applicant is ready to furnish surety to the satisfaction of this Hon'ble Court. The Applicant undertakes not to tamper with the prosecution evidence and not to threaten or influence any prosecution witness. The Applicant is ready to abide by such conditions as may be imposed by this Hon'ble Court while releasing him on bail, including any condition of attendance before the investigating agency.
30.That the documents filed herewith are true copies of their respective originals.
31.That the Applicant undertakes to cooperate with the police investigation and to abide by the directions of this Hon'ble Court, and shall remain present before any authority as and when directed to do so. Copies of the identity proof of the Applicant are annexed herewith as ANNEXURE-H (Colly).
32.That the Applicant, therefore, prays as follows:-
PRAYER
It is, therefore, most respectfully prayed that this Hon'ble Court may, in the facts and circumstances stated above, be pleased to:-
a)release the Applicant, Applicant's name, on bail [in respect of his arrest in FIR No. FIR number dated FIR date, registered at Crime Branch Police Station, Police station], on such terms and conditions as this Hon'ble Court may deem fit in the interest of justice;
b)during the pendency and final disposal of the present regular bail application, grant interim bail for a period of 90 days to the Applicant, Applicant's name [in respect of his arrest in FIR No. FIR number dated FIR date, registered at Crime Branch Police Station, Police station], on such terms and conditions as this Hon'ble Court may deem fit in the interest of justice;
c)pass such other and further order(s) as this Hon'ble Court may deem fit and proper in the facts and circumstances of the present case.
Applicant's nameAPPLICANT
Through
Place of signingDate of filing
Counsel's nameCOUNSEL
Law firm name & ASSOCIATES
Office No.: Counsel's office number
Mob.: Counsel's mobile number
Email: Counsel's email address