Anticipatory Bail Application

IN THE HON’BLE HIGH COURT OF DELHI AT NEW DELHI
CRIMINAL APPELLATE JURISDICTION

ANTICIPATORY BAIL APPLICATION NO. 2110 of 2021
FIR NO. 512/2021, U/S:12 OF POCSO ACT 2012 AT MODEL TOWN POLICE STATION
[UNDER SECTION 438 OF CODE OF CRIMINAL PROCEDURE, 1973]
IN THE MATTER OF:
Mr. Aman Singh

Currently residing at:
34/2B, Model Town,
New Delhi- 110009 …
Applicant
VERSUS
State (NCT of Delhi)

Through SHO,
Model Town Police Station …
Respondent
INDEX
SL. PARTICULA PA
NO. RS GE
NO
.
1. Memo of Parties 1
2. Notice of Motion 2
3. Petition for Urgency 3
4. List of Dates 4-5
5. Application under Section 438 read with Section 482 of the Code of 6-9
Criminal Procedure, 1973 for the grant of anticipatory bail to the
Applicant along with Affidavit.
6. List of Documents 11
Impugned Order: A certified copy of the order dated 07.12.2021 passed
by the ld. Additional Sessions Judge, Rohini Court, Delhi
Annexure P/1: A true translated copy of the FIR dated 30.11.2021
registered at Model Town Police Station, Delhi
Annexure P/2: Photograph of the parking space shared between the
Applicant and the Complainant
Annexure P/3: Dated Photograph of the punctured car belonging to the
Applicant
Annexure P/4 (Colly.): Copies of the travel ticket, hotel receipt and
conference invitation sent to the Applicant
Annexure P/5: CCTV Footage from the shop across the street on the
date of the alleged harassment
Annexure P/6: A true copy of the Anticipatory Bail Application No.
702 of 2021 filed by the Applicant before the ld. Additional Sessions
Judge, Rohini Court, Delhi
7. Vakalatnama 12-
13
Filed for:
Aman Singh
Through
Sonakshi Garg
F/769/654/2018
Advocates for the Applicant

Chamber: 170 Lawyers’ Chambers,
Block III, Delhi High Court,
Date : 10.12.2021 New Delhi –
110057
Place : New Delhi Mob. 9920849938,
9760999331
FIR NO. 512/2021, U/S: 12 OF POCSO ACT 2012 AT MODEL TOWN POLICE STATION
MEMO OF PARTIES
IN THE MATTER OF:
Mr. Aman Singh

34/2B, Model Town,
Applicant
VERSUS

Through SHO,
Respondent
Filed for:
Aman Singh
Through
Sonakshi Garg
F/769/654/2018

110057
9760999331

IN THE MATTER OF:
Mr. Aman Singh …

Applicant
VERSUS

Through SHO,
Respondent
NOTICE OF MOTION
To,
The Standing Counsel (Crl.)

Delhi High Court,
New Delhi
Sir,
The Petitioners are filing the accompanying anticipatory bail application under
Section 438 read with Section 482 of the Code of Criminal Procedure for grant of interim bail
before the Hon’ble Court and a copy of the said application is being enclosed herewith. The
said application is likely to be listed before the Hon’ble Court within 2-3 days.
You are requested to do the required in the matter.
Filed for:
Aman Singh
Through
Sonakshi Garg
F/769/654/2018

110057
9760999331
IN THE MATTER OF:
Mr. Aman Singh …

Applicant
VERSUS

Through SHO,
Respondent
PETITION FOR URGENCY
To,
The Registrar
Delhi High Court,
New Delhi
Sir,
The Petitioners The accompanying anticipatory bail application U/S 438 read with
Section 482 of the Code of Criminal Procedure for grant of bail may kindly be treated as an
urgent one as per the Rules and Regulations of this Hon’ble Court. The ground of urgency is
that the Applicant suffers from a chronic lung infection called pulmonary fibrosis and
requires frequent medical attention.
“Appropriate order for grant of anticipatory bail is prayed for.”
Filed for:
Aman Singh
Through
Sonakshi Garg
F/769/654/2018

110057
9760999331
IN THE MATTER OF:
Mr. Aman Singh …

Applicant
VERSUS

Through SHO,
Respondent
LIST OF DATES
SI NO. DATE EVEN

T
1. 01.10.202 Mr. Aman Singh (“the Applicant”) purchased a new Honda Civic car.
1
2. 01.11.202 Mr. Rahul Sharma (“the Complainant”) purchased an identical car.
1
3. 20.11.202 Pursuant to an ongoing tussle over a common parking space,
1 Complainant punctured the Applicant’s car and also threatened the
Applicant.
4. 21.11.202 Applicant was in Bangalore to attend a conference
1 to
30.11.202
1
5. 30.11.202 Complainant filed an FIR under Section 12 of the POCSO Act 2012 at
1 the Model Town Police Station, Delhi, alleging sexual harassment of his
son Gokul Sharma on the night of 21.11.2021.
6. 03.12.202 Applicant filed an anticipatory bail application at the ld. Additional
1 Sessions Court, Rohini, Delhi.
7. 07.12.202 Ld. Additional Sessions Judge rejected the anticipatory bail application.
1
8. 10.12.202 The present application is filed before the Hon’ble High Court of Delhi
1 under Section 438 read with Section 482 of the Code of Criminal
Procedure for the grant of anticipatory bail to the Applicant.
Aman Singh
Through
Sonakshi Garg
F/769/654/2018

110057
9760999331

IN THE MATTER OF:
Mr. Aman Singh

34/2B, Model Town,
Applicant
VERSUS

Through SHO,
Respondent
FIRST APPLICATION UNDER SECTION 438 READ WITH SECTION 482 OF THE
CODE OF CRIMINAL PROCEDURE SEEKING A DIRECTION TO THE
INVESTIGATING OFFICER TO RELEASE THE PETITIONER ON BAIL IN THE
EVENT OF HIS ARREST IN FIR NO. 512/2021 REGISTERED UNDER SECTION 12
OF THE POCSO ACT 2012 AT MODEL TOWN POLICE STATION
To
The Hon’ble Chief Justice and his Companion
Hon’ble Judges of the Hon’ble High Court of Delhi at New Delhi
MOST RESPECTFULLY SUBMITTED:

1. That Mr. Anand Singh holds a permanent residence in 34/2B Model Town, New Delhi,
110009, and is a well-known law professor at Chanakya University.
2. The applicant is an upstanding citizen who is qualified for the protection provided by the
Constitution.
3. That the FIR No. 512/2021, filed at Model Town Police Station in New Delhi in accordance
with Section 12 of the POCSO Act, is what prompted the applicant to submit the current
application, which asks for the granting of an anticipatory bail directing the investigating
officer to release the applicant. A copy of the FIR is included with this document as Annexure
P/1.
4. That Mr. Rahul Sharma and his son, Mr. Gokul Sharma, are the "Complainants" in the case,
and that the Applicant is their neighbor. It is crucial to notice that both of their homes were
built such that they only produce one parking place, which is located directly in the centre of
both homes.
5. The following are a few quick facts and events that led to the submission of the current
application:
● That the Applicant purchased a brand-new Honda Civic for Rs 28,00,000 on 1 October 2021.
On November 1, 2021, the Complainant also acquired a Honda Civic like the Applicant's
vehicle.
● That there has been a regular squabble about parking space for both automobiles since the
Complainant purchased the car. While the Applicant thought that the area may be shared on a
rotating basis, the Complainant said that the space is closer to his side of the land and will be
his own property. As Annexure P/2, an image of the parking spot is provided.
● That during the first two weeks of November, the Complainant would come home early and
park his vehicle in the parking area. As a consequence, the Applicant would have to park his
automobile on the side of the main road.
● That on November 20, 2021, the Applicant had a half-day off from work and parked his
automobile on the site in the afternoon. When the Complainant returned at 8 p.m., he was
astonished to discover the Applicant's automobile occupying his position and started hurling
profanity at the Applicant. When the Applicant stepped out and volunteered to remove the
automobile in the interest of peace, the Complainant pulled out a screwdriver and punctured
the Applicant's rear tires in a fit of wrath. Annexure P/3 has a dated image of the punctured
automobile.
● At 10 p.m. on 20 November 2021, an automobile driven by a stranger collided with the
Complainants' parked vehicle on the side of the main road. In a fit of fury, the Complainant
blamed the Applicant for the aforementioned damage and told the Applicant, "Ab dekhna
court ke kitne chakkar lagvata hunt ko; aise aise jhoothe charges lagaunga, ki utarte utarte
thak jayega" before leaving.
● The applicant went at 7 AM on the morning of November 21 for a business trip to Bangalore,
Karnataka, thinking that this would all be an act of fury. The applicant visited Bangalore for
around 9 days before leaving on November 30, 2021. As Annexure P/4, a duplicate of the trip
ticket, hotel bill, and conference ID is provided (Colly.).
● On November 30, 2021—the day the applicant returned from Bangalore—the complainant
filed a police report (FIR No. 512/2021) against the applicant at the Model Town Police
Station in accordance with Section 12 of the POCSO Act 2012. The Complainant had said
that the Applicant had entered their home at night when the Complainant was sleeping and
sexually harassed the Complainant's son on the evening of November 20, 2021.
● It is simply provable that the applicant stayed within his apartment complex the whole night
of November 20 and did not leave until the following morning, when he boarded a flight for
Bangalore. Herewith, as Annexure P/5, is a copy of the surveillance footage from the store
across the street.
● That on 03/12/2021, the applicant went to the senior additional sessions judge at Rohini
Courts to request the granting of anticipatory bail. This document's Annexure P/6 contains a
genuine copy of the Anticipatory Bail Application No. 702 of 2021, which was submitted to
the ld. Additional Sessions Judge.
● However, the senior additional sessions judge dismissed the applicant's request for
anticipatory release in his ruling dated 07.12.2021, citing the POCSO Act's serious character
and the impossibility of treating such claims lightly. Annexed to this document is a certified
copy of the order issued by the ld. Additional Sessions Judge on December 7, 2021.
(Impugned Order).
6. The applicant has not submitted any more petitions to the honorable Supreme Court or to any
other Court, according to that.
7. That, among other reasons, the applicant is submitting the current application for the issuance
of anticipatory bail on the following grounds:
Grounds
1. Because the ld. Additional Sessions Court failed to appreciate that the Applicant had
no access to the Complainant’s son, Gokul Sharma on the night of the alleged sexual
harassment and had not left his home during that time.
2. Because the ld. Additional Sessions Court failed to appreciate that the Applicant had
gone to Bangalore the following morning and had not arrived back until the complaint
had been filed.
3. Because the Complainant was already annoyed with the Applicant and had just gotten
into an altercation with him which had turned physical and caused both of them to get
hurt along with hurl abuses at each other, and as a result the complainant had filed the
FIR to get back at him.
4. Because the Complainant, after their altercation had clearly threatened the Applicant
outside his house for the whole society to hear, that he would register a false case
against him and would harass him by making him doing rounds of the court, and has
abided by his words.
5. Because the ld. Additional Sessions Judge failed to appreciate the ridiculousness of
the Complainant's application, even though it is clear that the FIR was filed with the
intention of exacting revenge on the Applicant for the parking spot disagreement.
6. Because in the case of Gurbaksh Singh Sibia vs. The State of Punjab, [1980 SCR (3)
383], It was noted that with regard to anticipatory bail, a directive for the release of
the applicant on bail in the event of his arrest would typically be made if the proposed
accusation appears to stem not from motives of furthering the ends of justice but from
some ulterior motive, the object being to injure and humiliate the applicant by having
him arrested.
7. Because the Applicant is a law abiding and upstanding member of the community and
has never been in any case of this manner.
8. Because the Petitioner is a reputed Professor of Political Science at Chanakya

University who is a permanent resident of Model Town, New Delhi- 110156, who has
been residing in his family home for the past 10 years and belongs to a respectable
family and has deep roots in the society and there is no possibility of the of the
Applicant to flee from justice or tempering with the evidence.
9. Because the Petitioner undertakes to comply with the investigation and comply with
the directions of the investigating officers as and when directed.
10. Because the Applicant is ready and willing to abide by the rules and regulations as
imposed by this Hon’ble Court or grant of anticipatory bail.
PRAYER
In light of the facts and circumstances aforementioned, it is most respectfully prayed for that
this Hon’ble Court may be pleased to:
a) direct the Investigating Officer to release the Applicant on bail in the event of his
arrest in FIR No. 525/2021 under Section 12 of the POCSO Act 2012 registered at the Model
Town Police Station; and
b) stay the arrest of the Applicant during the process of completion of the present
Application; and
c) grant any further relief in favour of the Applicant as this Hon’ble Court may deem fit
and proper keeping in mind the facts and circumstances of this case.
AND FOR THIS ACT OF KINDNESS YOUR COMPLAINANT AS IS DUTY BOUND
SHALL EVER PRAY.
APPLICANT
Aman Singh
Through
Venkatesh Ramana
F/787/652/2017

Block IV, Delhi High Court,
110503
8585933067

IN THE MATTER OF:
Mr. Aman Singh …

Applicant
VERSUS

Through SHO,
Respondent
AFFIDAVIT
I, Anand Singh, S/o Mr. Ramesh Singh aged about 45 years, R/o 34/2B, Model Town, New
Delhi- 110009, the above named Applicant, do hereby solemnly affirm and swear as under:-
1. That I am the Applicant in the above noted matter. I am conversant with the facts and
circumstances of the present case and as such I am competent to swear the present
Affidavit.
2. That the accompanying application U/s. 438 for anticipatory bail has been drafted by
the counsel under my instructions and explained to me in a language of my
understanding.
3. That I have gone through the contents of the Petition and the same are true and correct
to the best of my knowledge and the legal advice received by me. The last para is a
prayer to this Hon’ble Court.
DEPONENT
VERIFICATION
Verified at New Delhi on this 10th day of December, 2021 that the contents of the aforesaid
Affidavit are true and correct to the best of my knowledge and nothing material has been
concealed therefrom.
DEPONENT
Anand Singh
Through
Venkatesh Ramana
F/787/652/2017
Block IV, Delhi High Court,
Date : 12.12.2021 New Delhi – 110503
Place : New Delhi Mob. 9923789210, 8585933067

IN THE MATTER OF:
Mr. Aman Singh …

Applicant
VERSUS

Through SHO,
Respondent
LIST OF DOCUMENTS
S. No List of Documents
1. Impugned Order: A certified copy of the order dated 07.12.2021 passed by the ld.
Additional Sessions Judge, Rohini Court, Delhi
2. Annexure P/1: A true translated copy of the FIR dated 30.11.2021 registered at
Model Town Police Station, Delhi
3. Annexure P/2: Photograph of the parking space shared between the Applicant and
the Complainant
4. Annexure P/3: Dated Photograph of the punctured car belonging to the Applicant
5. Annexure P/4 (Colly.): Copies of the travel ticket, hotel receipt and conference
invitation sent to the Applicant
6. Annexure P/5: CCTV Footage from the shop across the street on the date of the
alleged harassment
7. Annexure P/6: A true copy of the Anticipatory Bail Application No. 702 of 2021
filed by the Applicant before the ld. Additional Sessions Judge, Rohini Court, Delhi
Aman Singh
Through
Sonakshi Garg
F/769/654/2018

110057
9760999331

IN THE MATTER OF:
Mr. Aman Singh …

Applicant
VERSUS

Through SHO,
Respondent
VAKALATNAMA
I, Anand Singh, S/o Sonam Singh, aged 47, R/o 004/1C, Model Town, New
Delhi - 110009, the above-named Applicant, do hereby appoint: Manohar Veer
Singh (hereinafter, “The Advocate”) to be my advocate in the above noted case
and authorize __ :-
1. To act, appear and accordingly plead in the above-noted case in this

particular Court, or in any other Court where the same may be tried or
heard, this also applies to appellate Courts including High Court(s)
subject to payment of legal fees separately for each Court approached by
me.
2. To sign, file, verify and present pleadings, appeals, cross-objections or
petitions for executions, review, revision, withdrawal, compromise or
other petitions or affidavits or other documents as may be deemed
necessary or proper for the prosecution of the said case in all its stages
subject to payment of fees separatel for each stage.
3. To accordingly file and take back documents, to admit and/or deny the
documents of the opposite party.
4. To withdraw or compromise the said case or submit to arbitration any
differences or extra-disputes whichever may arise in direct relation to, or
in any other manner relating to, the said case.
5. To, based on the events pursuant to the said case, appoint and accordingly
instruct any other Legal Practioner authorizing him to exercise the power
and authority hereby conferred upon the Advocate whenever they may
think fit to do so and to sign the power of attorney on my behalf.
6. To deposit, draw and receive monthly cheques, cash and grant receipts
thereof and to do all other acts and things which may be necessary to be
done for the progress and in the course of the prosecution of the said case.
7. I, the undersigned, do hereby agree to ratify and thus confirm all acts
done by the Advocate, or her substitute who is representing me, in the
matter as my own acts, as if committed by me to all intents and purposes.
8. And I undertake that my duly authorized agent would appear in Court and
attend all hearings and will accordingly inform the Advocate for
appearance when the case is called or is being tried by the Judge.
9. And I the undersigned do hereby agree not to hold the Advocate or his
substitute responsible for the resulting judicial decision drawn by the
judge or bench based on the hearing and trial of the said case.
10. And I the undersigned agree that the adjournment costs, whenever
ordered by the Court, shall be of the Advocate which he shall receive and
retain for himself..
11. And I do hereby also agree that in the event that the whole or part of the
fee agreed by me to be paid to the advocate remains unpaid, he shall be
entitled to withdraw from the prosecution of the said case until the same
is fully paid up. The fee settled or to be settled is only for the above case
and above-mentioned Court, commitment towards other legal fees
connected to a different case or cases are not of concern to the present
application and case.
12. And I the undersigned also hereby agree that once the fee is paid, I will
not be entitled, nor will claim remuneration, to a refund of the same in
any case whatsoever. In the event that the case is delayed or is prolonged
for more than 3 years vide the date of this application/case and the
payment of the original fees, the fees for the same shall be paid again by
me.
IN WITNESS WHEREOF I do hereunto set my hand to these present

conditions the contents of which have been understood by me on this 10th day
of December 2021, accepted subject to the terms listed in the fees.
Manohar Veer Singh Anand Singh

Enrolment No.: M/233/572/2018
Chamber: 024, Chamber of Senior Advocate Venkatesh Ramana,
Delhi High Court, New Delhi — 110503
Mobile No: +91 9923789210 / +91 8585933067
Email ID: Manhor.veer.s.@gmail.com

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IN THE HON’BLE HIGH COURT OF DELHI AT NEW DELHI

CRIMINAL APPELLATE JURISDICTION

IN THE MATTER OF:

Mr. Aman Singh

State (NCT of Delhi)

Advocates for the Applicant

IN THE MATTER OF:

Mr. Aman Singh

State (NCT of Delhi)

Advocates for the Applicant

IN THE HON’BLE HIGH COURT OF DELHI AT NEW DELHI

IN THE MATTER OF:

Mr. Aman Singh …

State (NCT of Delhi)

The Standing Counsel (Crl.)

You are requested to do the required in the matter.

Advocates for the Applicant

IN THE MATTER OF:

Mr. Aman Singh …

State (NCT of Delhi)

PETITION FOR URGENCY

“Appropriate order for grant of anticipatory bail is prayed for.”

Advocates for the Applicant

IN THE MATTER OF:

Mr. Aman Singh …

State (NCT of Delhi)

SI NO. DATE EVEN

Advocates for the Applicant

IN THE HON’BLE HIGH COURT OF DELHI AT NEW DELHI

IN THE MATTER OF:

Mr. Aman Singh

State (NCT of Delhi)

MOST RESPECTFULLY SUBMITTED:

8. Because the Petitioner is a reputed Professor of Political Science at Chanakya

this Hon’ble Court may be pleased to:

Town Police Station; and

AND FOR THIS ACT OF KINDNESS YOUR COMPLAINANT AS IS DUTY BOUND

SHALL EVER PRAY.

Advocates for the Applicant

Block IV, Delhi High Court,

Date : 12.12.2021 New Delhi –

Place : New Delhi Mob. 9923789210,

IN THE HON’BLE HIGH COURT OF DELHI AT NEW DELHI

IN THE MATTER OF:

Mr. Aman Singh …

State (NCT of Delhi)

Advocates for the Applicant

Chamber: 024 Lawyers’ Chambers,

Block IV, Delhi High Court,

Date : 12.12.2021 New Delhi – 110503

Place : New Delhi Mob. 9923789210, 8585933067

IN THE HON’BLE HIGH COURT OF DELHI AT NEW DELHI

IN THE MATTER OF:

Mr. Aman Singh …

State (NCT of Delhi)

Advocates for the Applicant

IN THE HON’BLE HIGH COURT OF DELHI AT NEW DELHI

IN THE MATTER OF: