APPLICATION UNDER SECTION 439 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___________
SECTION OF IPC 376, 363, 366A
AND U/S 3,4,5,6 OF PROTECTION OF
CHILDREN FROM SEXUAL OFFENCES ACT,2012
APPLICATION UNDER SECTION 439 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 girl is 15 years old and accused is 20 years old. The father of the girl filled a FIR on ________ for missing of her daughter and put blame on the accused that he made her eloped with him. When both girl and accused returned on _____ accused was put straight behind the bars. Accused was charged for forcefully marrying the girl, forcing her to stay with him and for rape.
MOST RESPECTFULLY SUBMITTED AS UNDER:
- That the accused and girl were in love with each other and wanted to get married and live together and wanted to leave behind their families.
- That the accused did not take any advantage of the girl.
- That this is a usual case of a girl and boy having an affair getting eloped and got married.
- That the accused did not kidnapped her and sexually abused her.
- 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 have falsely implicated the applicant in the present case, the applicant is a respectable citizen of the society and is not involved in 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 or in any kind of custodial interrogation is required.
- 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 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 witness 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
