APPLICATION UNDER SECTION 436 CRPC
IN THE HON’BLE COURT OF ____________ AT __________
Cr.Misc.Application no __________ 2018
IN THE MATTER OF
STATE
VS
(APPLICANT)
FIR NO___________
DATED___________
UNDER SECTION___________
POLICE STATION__________
Accused under custody since___________
APPLICATION UNDER SECTION 436 CRPC FOR GRANT OF BAIL ON BEHALF OF THE ACCUSED (name of the applicant of the bail along with his father’s name, address and other details)
BRIEF FACT OF THE CASE:
- The accused was arrested on ________ by the_______ Police on a charge U/Sec 409 I.P.C. the main complaint against him being that he being the V.A.O. of P_______ village and as such being a public servant failed to maintain and show accounts for a sum of Rs. ________ to the Government Treasury.
- Though offence is non-bailable taking into consideration the fact that, the amount involved is only Rs. _______ it is highly probable that there must be some honest mistake on the part of the accused for no one would think of Misappropriating such a small amount as _____.
- The accused is a respectable old man of ____ and is certainly not going to abscond. Moreover his family is resident in the village for over 40 years. His pensions and provident fund all came to more than Rs. ________ and the missed amount will be compensate by the accused soon.
MOST RESPECTFULLY SUBMITTED AS UNDER:
- That the present FIR has been registered on false and bogus facts. The facts stated in the FIR are fabricated, concocted and without any basis.
- That the police has falsely implicated the applicant and arrested him in the present case, the applicant is a respectable citizen of the society and is not involved any criminal case.
- That the facts stated in the complainant against the applicant are civil disputes and does not constitute any criminal offence at all.
- That the applicant is not required in any kind of investigation nor any kind of custodial interrogation is required, nor any recovery is to be made at the instance of the applicant.
- That the applicant is having very good antecedents, he belongs to good family and there is no criminal case pending against them.
- That the applicant is a permanent resident and there are no chances of his absconding from the course of justice.
- That the applicant undertakes to present himself before the police/court as and when directed.
- That the applicant undertakes that he will not, directly or indirectly make any inducement, threat or promise to any person acquainted with the facts of the case so as to dissuade him from disclosing such facts to the Court or to any police officer.
- That the applicant further undertakes not to tamper with the evidence or the witnesses in any manner.
- That the applicant shall not leave India without the previous permission of the Court.
- That the applicant is ready and willing to accept any other conditions as may be imposed by the Court or the police in connection with the case.
PRAYER
It is therefore prayed that the court may order for the release of the applicant on bail in the interest of justice.
Any other order which the court may deem fit and proper in the facts and circumstances of the case may be also passed in favor of the applicant.
APPLICANT
THROUGH
COUNSEL