IN THE COURT OF SH ……………………. METROPOLITAN MAGISTRATE, ……..

State

Versus

………………..                                                                                                                    Accused

FIR NO. _____

UNDER SECTION _____________ IPC,

APPLICATION FOR BAIL U/S 167 OF CrPC FILED BY THE COUNSEL FOR THE ACCUSED

1. That the accused in the above numbered case has been arrested by the ……….. police on ………… on charges of U/S ………. of IPC and he is in custody since then.
2. That the police has been reluctant to conduct investigation and submit its report in time. They have not filed the charge sheet in Court even after the completion of statutory time period of …………….. (60 or 90 as applicable) days.
3. The accused is not related to the above offences and he is ready to furnish bail.

Hence it is most respectfully prayed that this Hon’ble Court may be pleased to release the accused on bail.

Dated at ……….…..

Place ……………….

Counsel for Accused