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 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)

MOST RESPECTFULLY SUBMITTED AS UNDER:

1. The petitioner has been framed up in the case because ______ daughter of ________ complainant was deeply in love with the petitioner and her marriage was ______solemnized with ______ son of ________ R/O House NO ._____against her wishes on _______. Even after Marriage _______ wanted the petitioner to continue friendly relationship with her due to attachment but the petitioner always advised her that since she has been married to another person, she should try to forget her past relationship with the petitioner.
2. 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.
3. 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.
4. That the facts stated in the complainant against the applicant are civil disputes and does not constitute any criminal offence at all.
5. That the applicant is not required in any kind of investigation or in any kind of custodial interrogation is required.
6. That the applicant is having very good antecedents, he belongs to good family and there is no criminal case pending against them.
7. That the applicant is a permanent resident and there are no chances of his absconding from the course of justice.
8. That the applicant undertakes to present himself before the police/court as and when directed.
9. 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.
10. That the applicant further undertakes not to tamper with the evidence or the witness in any manner.
11. That the applicant shall not leave India without the previous permission of the court.
12. 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