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438 Bail Application

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IN THE COURT OF THE DISTRICT AND

SESSIONS JUDGE AT CHITRADURGA


CR MIS ________ OF 2022
BETWEEN :

PETITIONER
MALLESH
Son of Lakshmanappa,
aged about 47 years, Agriculturist,
Resident at Kalgere Village,
Chitradurga Taluk and Districct

The Petitioner is the accused No.1


in Crime No.213/2022
of Bharmasagara Police.

AND

RESPONDENT

The State by Sub-Inspector of Police,


Bharmasagara Police Station,
Represented by Respected
Public Prosecutor, Chitradurga

ANTICIPATORY BAIL APPLICATION FILED ON


BEHALF OF THE PETITIONER UNDER SECTION 438
OF CRIMINAL PROCEDURE CODE.

It is humbly submitted as follows:-


The Sub Inspector of Police, Chitradurga Rural
Police Station, has registered a case against the
petitioner in Crime No. 213/2022 for the offence
punishable under section 504, 323, 324, 354 read with
34 of IPC, on a complaint said to have been lodged by
one Naseer on 17.07.2022. ….2
BRIEF FACTS OF THE CASE
The content of the statement of complaint is in
Kannada version. To avoid the true translation and
conclusion from word to word for detail explanation,
the certified copy of the F.I.R along with complaint and
Remand application is produced as it is herewith. The
same may kindly be pleased to treat as part and parcel
of this anticipatory bail application.

Therefore the petitioner prefers this anticipatory


bail application for one among the following other:
GROUNDS

1. The Petitioner is innocent and peace loving citizen


and he have not committed any offences
punishable under section 504, 323, 324, 354 read
with 34 of IPC.
2. That the above Petitioner is innocents and peace
loving citizen and he is not committed any of the
offences as alleged against him.
3. The Petitioner is a Agriculturist. He is residing at
above said address with his family members and
he is deep root and respectable person in the
society.
4. That the Petitioner having large members of family,
he is also taken care of his family and he is the
only earning in the family.

….3
5. That the Petitioner is hereby undertakes that he
will appear before this Honorable Court on all the
dates of hearing without fail.
6. That the Petitioner is ready to furnish surety for
his due release on bail. Further he is ready to
abide the conditions that may be imposed by this
Honorable Court. He has friends and relatives and
as such they have got deep root in the society.
7. The Punishment for the alleged offences is not
death or capital punishment nor life imprisonment
and alleged offences are exclusively triable by this
Honorable JMFC Court.
8. The above Petitioner is falsely implicated in the
above case. The alleged complaint allegations are
all totally created story by the complainant.
9. Vakalath of the Petitioner filed with list with
documents.
PRAYER

Therefore, it is humbly prayed that this Honorable


court may kindly be pleased to grant Anticipatory Bail
in Crime No.213/2022 and favour of the petitioner and
kindly direct the concerned police or jurisdictional
Honorable Court, to release the above petitioner on bail
in the event of being arrested by them in the above case
by allowing this petition in the interest of justice.

Place: Chitradurga

Date: 25-07-2022 Advocate for Petitioner


IN THE COURT OF THE DISTRICT AND
SESSIONS JUDGE AT CHITRADURGA
CR MIS ________ OF 2022

PETITIONER V/s RESPONDENT


Mallesh State by
Bharamasagara
Police,
Represented by
Public Prosecutor,
Chitradurga

INDEX

1. Application under section 438 Cr.P.C

2. Vakalathnama.

3. Certified Copy of FIR & Complaint.

4. Aadhar Card of the Petitioner.

5. Process Memo.

6. Respondent Copy.

Place: Chitradurga

Date: 25-07-2022 Advocate for Petitioner


IN THE COURT OF THE DISTRICT AND SESSION
JUDGE AT DAVANAGERE

Cr Mis ________ of 2022

PETITIONER V/s RESPONDENT


Mallesh State by
Bharamasagara
Police,
Represented by
Public Prosecutor,
Chitradurga

PROCESS MEMO

In the above said case, the process fee of Rs.2/- will be

paid

Place: Chitradurga

Date: 25-07-2022 Advocate for Petitioner


IN THE COURT OF THE PRINCIPAL DISTRICT
AND SESSIONS JUDGE AT CHITRADURGA
CR MIS ________ OF 2022
BETWEEN :

PETITIONER
SAGAR.K
Son of Krishnamurthy.C.G,
aged about 20 years, Student,
Resident at Burujanahatti,
Chitradurga Town

The Petitioner is the accused No.2


in Crime No.318/2022
of Chitradurga Rural Police.

AND

RESPONDENT

The State by Sub-Inspector of Police,


Chitradurga Rural Police Station,
Represented by Respected
Public Prosecutor, Chitradurga

ANTICIPATORY BAIL APPLICATION FILED ON


BEHALF OF THE PETITIONER UNDER SECTION 438
OF CRIMINAL PROCEDURE CODE.

It is humbly submitted as follows:-


The Sub Inspector of Police, Chitradurga Rural
Police Station, has registered a case against the
petitioner in Crime No. 318/2022 for the offence
punishable under section 399 and 402 of IPC, on a
complaint said to have been lodged by one
Manjunatha.N.K on 12.07.2022. ….2
BRIEF FACTS OF THE CASE
The content of the statement of complaint is in
Kannada version. To avoid the true translation and
conclusion from word to word for detail explanation,
the certified copy of the F.I.R along with complaint and
Remand application is produced as it is herewith. The
same may kindly be pleased to treat as part and parcel
of this anticipatory bail application.

Therefore the petitioner prefers this anticipatory


bail application for one among the following other:
GROUNDS

10. The Petitioner is innocent and peace loving citizen


and he have not committed any offences
punishable under section 399 and 402 of IPC.
11. That the above Petitioner is innocents and peace
loving citizen and he is not committed any of the
offences as alleged against him.
12. The Petitioner is a Student of B.com studying in
SJM Collage of Arts, Science and Commerce,
Holalkere Road, Chitradurga. He is residing at
above said address with his family members and
he is deep root and respectable person in the
society.
13. That the Petitioner having large members of family,
he is also taken care of his family.

….3
14. That the Petitioner is hereby undertakes that he
will appear before this Honorable Court on all the
dates of hearing without fail.
15. That the Petitioner is ready to furnish surety for
his due release on bail. Further he is ready to
abide the conditions that may be imposed by this
Honorable Court. He has friends and relatives and
as such they have got deep root in the society.
16. The Punishment for the alleged offences is not
death or capital punishment nor life imprisonment
and alleged offences are exclusively triable by this
Honorable Court.
17. The above Petitioner is falsely implicated in the
above case. The alleged complaint allegations are
all totally created story by the complainant.
18. Vakalath of the Petitioner filed with list with
documents.
PRAYER

Therefore, it is humbly prayed that this Honorable


court may kindly be pleased to grant Anticipatory Bail
in Crime No.318/2022 and favour of the petitioner and
kindly direct the concerned police or jurisdictional
Honorable Court, to release the above petitioner on bail
in the event of being arrested by them in the above case
by allowing this petition in the interest of justice.

Place: Chitradurga

Date: 20-07-2022 Advocate for Petitioner


IN THE COURT OF THE PRINCIPAL DISTRICT
AND SESSIONS JUDGE AT CHITRADURGA
CR MIS ________ OF 2022

PETITIONER V/s RESPONDENT


Sagar.K State by
Chitradurga Rural
Police,
Represented by
Public Prosecutor,
Chitradurga

INDEX

7. Application under section 438 Cr.P.C

8. Vakalathnama.

9. Certified Copy of FIR & Complaint.

10. Process Memo.

11. Aadhar Card of The Petitioners.

12. Respondent Copy.

Place: Chitradurga

Date: 20-07-2022 Advocate for Petitioner


IN THE COURT OF THE DISTRICT AND SESSION
JUDGE AT DAVANAGERE

Cr Mis ________ of 2022

PETITIONER V/s RESPONDENT


Sagar.K State by
Chitradurga Rural
Police,
Represented by
Public Prosecutor,
Chitradurga

PROCESS MEMO

In the above said case, the process fee of Rs.2/- will be

paid

Place: Chitradurga

Date: 20-07-2022 Advocate for Petitioner


IN THE COURT OF THE DISTRICT AND SESSION
JUDGE AT DAVANAGERE

Cr Mis ________ of 2022


BETWEEN :

PETITIONER
Srimathi Anuradha Care of C.Shanmukhappa, aged
about 35 years, FDA at Revenu Deportment, Taluku
Office, Shahapura, Resident at #0-1, Doranahalli
Village, Yadagiri Taluku and District.
The Petitioner is the accused No.5 in Crime
No.73/2022 of Santhebennuru Police.

AND
RESPONDENT

The State by Sub-Inspector of Police,


Santhebennuru Police Station,
Represented by Respected Public Prosecutor,
Davanagere

ANTICIPATORY BAIL APPLICATION FILED ON


BEHALF OF THE PETITIONER UNDER SECTION 438
OF CRIMINAL PROCEDURE CODE.

It is humbly submitted as follows:-

The Sub Inspector of Police, Santhebennuru Police


Station, has registered a case against the petitioner in
Crime No. 73/2022 for the offence punishable under
section 323, 114, 504, 506, 498 (A) Read with section
149 of IPC and under section 3 & 4 Dowry Prohibition
Act, on a complaint said to have been lodged by one
Srimathi Rekha on 30.04.2022.

…2
BRIEF FACTS OF THE CASE
The contents of the statement of complaint is in
Kannada version. To avoid the true translation and
conclusion from word to word for detail explanation,
the certified copy of the F.I.R, complaint and Charge
sheet is produced as it is herewith. The same may
kindly be pleased to treat as part and parcel of this
anticipatory bail application.

Therefore the petitioner– accused is preferring this


anticipatory bail application for one among the
following other:
GROUNDS FOR BAIL
19. That the above Petitioner / Accused is innocents
and peace loving citizen and she is not committed
any of the offences as alleged against him.
20. The Petitioner is the working women, she is
residing at above said address and she is deep root
and respect persons in the society.
21. The Petitioner have no relationship between
Complainant and also other accused persons.
22. That the Petitioner having 2 children, she is the
only take care of them.
23. That the Petitioner is hereby undertakes that she
will appear before this Honorable Court on all the
dates of hearing without fail.
24. That the Petitioner is ready to furnish surety for
her due release on bail. Further she is ready to
abide the conditions that may be imposed by this
Honorable Court.
….3
25. Above Petitioner having both moveable and
immovable properties and have friends and relatives
and as such she have got deep root in the society.

26. The punishment for the alleged offences is not


death or capital punishment nor life imprisonment
and alleged offences are exclusively triable by JMFC
Court.
27. The above petitioner is falsely implicated in the
above case. The alleged complaint allegations are all
totally created story by the complainant.
28. Vakalath of the Petitioner filed with list with
documents.
PRAYER

Therefore, it is humbly prayed that this Honorable


court may kindly be pleased to grant Anticipatory Bail
in Crime No.73/2022 and favour of the petitioner and
kindly direct the concerned police that is
Santhebennur Police or concerned jurisdiction
Honorable Court, to release the above Petitioner on bail
in the event of being arrested by them in the above case
by allowing this petition in the interest of justice.

Place: Davanagere

Date: 29-06-2022 Advocate for Petitioner


1. The entire complaint is false, concocted by the
complainant, at the instance of the busy bodies who
are inimical disposed towards the petitioners.

2. There is a in ordinate delay in lodging the


complaint. As per the contents of the FIR Column 3 A
the place of occurrence showed as 19.05.2019 but this
complaint came to be registered on 24.05.2019.
Though the police station only at a distance of 12 kms
away from the place of incident, this itself throws lot of
doubts and suspicion in registering the case against
the innocent petitioners.

3. The petitioner – accused No. 1 is the husband


of the complainant and the petitioners No. 2 is the
mother of the petitioner No.1 and the petitioner No. 3 &
4 are the sisters of petitioner – accused No.1, the
petitioner No. 5 to 7 are uncles of the petitioner No.1.
The entire family members have been implicated with
false and untenable allegations for their no fault.

4. It is important to submit that, the


complainant’s marriage solemnized on 02.12.2018 and
she joined with the petitioners and lead a happy
marital life. The complainant almost all stayed in her
parents house during that period. Therefore the
question of demanding additional dowry within a
period of 4 months does not arise. Only in order to
register a false case against the innocent petitioners
the same has been created, concocted, fabricated and
register a false case, except this the petitioners never
demanded any additional dowry from the complainant
or they have not given any mental or physical
harassment to the complainant. Only to harass the
innocent petitioners a false story has been created and
foisted the false case against the innocent petitioners.

5. Further it is important to submit that, the


complainant has no interest to perform her marriage
with the petitioner No.1. The complainant at the force
her parents she agreed for the marriage. The
complainant herself has intimated the said fact to the
petitioner No.1 and there no co-habitation in between
the complainant and petitioner No.1. Further the
complainant herself demanded the petitioner No.1 to
give divorce. When the petitioner No.1 refused for the
same she foisted this false complaint in order to harass
the entire family members and to full fill her demand.
Except this the petitioners are not at all committed any
offence as alleged by the complainant.

6. On perusal of the entire contents of the


complaint, no where it is stated that, when the
petitioners have assaulted or when they were giving
any mental and physical harassment or when they
were demanded additional dowry, the date, time or
month is also not forthcoming in the instant complaint
to show that these petitioners are directly or indirectly
responsible for the alleged commission of offence.
7. Though the said offences are non bailable, but
not exclusively punishable either with death or
imprisonment for life.

9. The petitioners are permanent resident of


the above said address, owns substantial movable and
immovable properties and they are deep rooted in the
society and they undertake to furnish surety to the
satisfaction of this Honourable court, undertaking to
appear on all dates of hearing whenever called upon to
do so.

10. The petitioners undertake to abide by the


conditions that may be imposed by this Honourable
Court and they further undertake not to tamper with
the prosecution witnesses or the police investigation
and undertake to appear before the I.O. whenever
called upon to do so to assist the investigation.

11. The petitioners undertake not to flee away


from the jurisdiction of the court or the country
pending disposal of the main case.

12. Hence it is prayed that the Honourable Court


may be pleased to direct the respondent police to
release the petitioners/accused No. 1 to 7 on bail in the
event of their arrest, in Crime NO. 52 of 2019 of
Parasurampura Police station, in the interest of
Justice.
Place:
Date: Advocate for Petitioners/
Accused No. 1 to 7

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