Shekhar Sudam Bhalerao

IN THE COURT OF HON'BLE J. M. F. C.
CANTONMENT
COURT, AT KHADKI.
Crime Reg. No. 801/2023

Bhosari Police Station
STATE OF MAHARASHTRA
(Through Bhosari Police Station) …Complainant.
V/s
SHEKHAR SUDAM BHALERAO.

Age - 19 yrs., Occ. - Student,
Residing at – Attar Vit Bhatti, Dapodi,
Pune – 411012. …Accused.
APPLICATION FOR BAIL U/S. 437
OF CRIMINAL PROSEDURE
CODE, 1973 IN CR NO.
801/2023, FILED U/S. 326, 504
OF INDIAN PENAL CODE, 1860
OF BHOSARI POLICE STATION.
MAY IT PLEASE YOUR WORSHIP -
The above-named Applicant most respectfully submits

as under -
1. That the Accused has been arrested on /10/2023 and

was produced before this Hon’ble JMFC Court by Bhosari
Police Station in Crime Registration no.801/2023 for the
offences punishable u/s. 326, 504 of Indian Penal Code,
1860 and remanded PCR time to time and subsequently
granted judicial custody and now the Applicant/Accused
is in Magistrate Custody in Central Prison, Yerwada, Pune.
2. Prosecution story in brief is as under –
On the basis of complaint lodged by Ajay Devidas Kharat,

Age – 19 years it is alleged that on 16/10/2023 around
14:30 in the afternoon, while the informant was going
home, a little ahead of Jai Bhawani Mitra Mandal, he
came to the open ground of Attar Vit Bhatti, Dapodi, Pune
near Tower, for no reason the Accused came behind the
informant and abused him and stabbed him on the back
with a blade. So, when the informant put his hands
behind his neck, the Accused stabbed him with the blade
on his hands and neck as well, injuring the informant
severely. So, the informant had filed police complaint
against the Applicant/Accused.
3. That, this applicant/accused submits that he has been

falsely involved and no overt act has been attributed to
this applicant/accused. This applicant submits that the
name of the applicant has been falsely implicated in the
said case.
4. This applicant submits that he has been falsely implicated

in the said case and no weapon has been recovered in the
said offence at the hands of this applicant and no direct
role is attributed to this applicant or no over act has been
attributed to this applicant/accused. No other criminal
cases are pending against this applicant and he has been
falsely implicated in the said crime and even during
investigation, nothing has been recovered at the hands of
this applicant.
5. That, there is no other application pending before any
other court of the present Accused regarding the present
subject matter. Hence, this applicant/accused has moved
this Hon'ble Court praying to be released on bail on the
following amongst other grounds thereto:
6. Grounds -
a) That the Applicant is a permanent resident of Dapodi,

Pune and is staying along with his family members. His
family is deeply rooted in the society. Hence chances of
absconding are very remote.
b) That the Applicant has not committed any offence as

alleged by the Police and this Applicant has been falsely
implicated in the said case. That the allegations against
the Applicant stand fallacious and are baseless.
c) That the detention of this Applicant is not at all necessary

for the investigation of the said offence. The investigation
of the offence is Practically over.
d) That no incriminating articles has been seized by the

Police to implicate this Applicant in the said offence. That,
there is no overt act at the hands of this Applicant.
e) That the Applicant is falsely implicated without any

material evidence whatsoever against the Applicant and
deny that he has ever committed any offence as alleged by
the Investigation Officer.
f) That the Accused has been arrested in the present matter

only on the basis of suspicion and the applicant has been
deliberately implicated in the said crime out of animosity.
g) That this Applicant will not misuse the liberty if he is
released on bail.
h) That all the material investigation by the police machinery

in the present matter is completed and mere formality of
filing of charge-sheet has remained.
i) That the Accused is ready and willing to furnish surety to

the satisfaction of this Hon'ble Court.
j) That the Accused undertakes that he will not tamper with

the prosecution witnesses and he will not abuse the
process of law in any manner.
k) No previous bail application has been filed in any other

Court.
 It is therefore prayed that -
A. The applicant/accused may kindly be released on bail

on such terms as Hon'ble Court deems to be fit owing
to the wide discretionary powers vested with this
Hon'ble Court in CR No.801/2023, filed u/sec. 326,
504 of Indian Penal Code, 1860 of Bhosari police
station.
B. Any other order in the interest of justice be kindly be

passed.
Dated this 02nd day of November 2023.
Place - Pune.
Counsel for the Accused.

ADV. AKSHAY CHOUDHARY.

Shekhar Sudam Bhalerao

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IN THE COURT OF HON'BLE J. M. F. C.

Crime Reg. No. 801/2023

SHEKHAR SUDAM BHALERAO.

MAY IT PLEASE YOUR WORSHIP -

The above-named Applicant most respectfully submits

1. That the Accused has been arrested on /10/2023 and

On the basis of complaint lodged by Ajay Devidas Kharat,

3. That, this applicant/accused submits that he has been

4. This applicant submits that he has been falsely implicated

a) That the Applicant is a permanent resident of Dapodi,

b) That the Applicant has not committed any offence as

c) That the detention of this Applicant is not at all necessary

d) That no incriminating articles has been seized by the

e) That the Applicant is falsely implicated without any

f) That the Accused has been arrested in the present matter

h) That all the material investigation by the police machinery

i) That the Accused is ready and willing to furnish surety to

j) That the Accused undertakes that he will not tamper with

k) No previous bail application has been filed in any other

 It is therefore prayed that -

A. The applicant/accused may kindly be released on bail

B. Any other order in the interest of justice be kindly be

Dated this 02nd day of November 2023.

Counsel for the Accused.

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