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Moot Problem- 1
CRL MISC BAIL APPLICATION NO. /2017

IN THE COURT OF JUDICIAL


MAGISTRATE AT JODHPUR
CRL MISC BAIL APPLICATION NO. /2017

ACCUSED PETITIONERS
1. Anil S/o Ram Singh Age 28 years R/o
Ratanada, District Jodhpur
2. Ajay S/o Gopal Singh Age 27 years R/o
Ratanda, District Jodhpur

- VERSUS -

RESPODENT
The State Of Rajasthan

CRIMINAL BAIL APPLICATION u/s 437 Cr.P.C IN THE


F.I.R NO. 190/2017 DATED 25.02.2017 REGISTERED AT
POLICE STATION RATANADA, DISTRICT JODHPUR
FOR OFFENCE u/s 323,324,325 AND 341 OF INDIAN
PENAL CODE.

To,
The Hon’ble Magistrate and other companion
Judge of this Hon’ble court of Judicature at
Jodhpur.
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Moot Problem- 1
CRL MISC BAIL APPLICATION NO. /2017

MAY IT PLEASE YOUR SIR;


For and on behalf of the Petitioner above named, it is
most respectfully and humbly submitted as under –

1. That the Complainant-respondent has filed an FIR


No. 190/2017 at police station Ratanada Dist.
Jodhpur against the petitioners.
2. That the brief facts given rise to the present bail
application are that on 25.02.17 AMUL filed a
written report before the Police Station ratanada,
Stated that he was walking on the street when
suddenly he was stopped by the both accused Anil
& Ajay and later they entered into a heated
argument with the Complainant which lead to a
small fight between the three. In the end of the
fight, Ajay pushed Amul to ground which caused a
fracture on his hand & Anil caused him injury with
a dagger, thereafter F.I.R was lodged for the
offences u/s 323,324,325 & 341.
3. That an F.I.R was registered on 25.02.17 by the
P.S. Ratanada Offence u/s 323,324,325 & 341.
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CRL MISC BAIL APPLICATION NO. /2017

4. That thereafter police stared the investigation in


said F.I.R and arrested both the accused.
The applicant prefers this bail application on the
following grounds amongst others:

GROUNDS
A. That the Petitioners have not committed any offence as
alleged against him. The Petitioners have been falsely
implicated due to personal enmity towards him.
B. That the F.I.R has been lodged is absolutely fake and
false story was made and no such incident took place
and only in order to harass the petitioners due to his
personal enmity with both the petitioners such serious
allegations have been leveled against both the petitioner
in the F.I.R.
C. That in the present case, both the petitioners deserve to
be allowed Bail because both of them have a family
with children and they are the only earning men in the
family.
D. That in this complainant only in order to harass the
petitioner the present F.I.R has been lodged. The story
in the F.I.R is absolutely false and concocted and the
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Moot Problem- 1
CRL MISC BAIL APPLICATION NO. /2017

same is lodged due to personal enmity towards both the


petitioners. A cross F.I.R was lodged by the petitioners
against the complainant on 26.02.17 which is registered
on number 192/2017 at P.S. Ratanada.
E. That the applicant will make himself available for the
every date of hearing in front of the court.
F. That the applicant will not leave India without the
previous permission of the court.
G. That the applicant is ready to abide conditions, which
this Hon’ble court deems fit and proper to impose upon
him.
H. That the alleged offence are not punishable with life
imprisonment under Indian Penal Code & is triable by
the Hon’ble Court.
I. That in the instant case, the applicant is permanent
resident of aforesaid address and having movable and
immovable property over there, thus there is no chance
for the applicants to abscond or tampering with the
prosecution.
J. That other grounds shall be raised at the time of
arguments.
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CRL MISC BAIL APPLICATION NO. /2017

PRAYER

It is therefore prayed that this bail application u/s 437


Cr.P.C. May kindly be allowed. And the petitioner
may kindly be ordered to be released on bail in F.I.R
no. 190/2017 for the offence u/s 323,324,324 & 341
of Indian Penal Code registered at P.S. Ratanada.

Kuldeep Bishnoi
Counsel for the Petitioner

Dated: 03/03/2017

NOTES:
1. No Such Bail application has been filed prior to it on
the F.I.R.
2. APP has been served.
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CRL MISC BAIL APPLICATION NO. /2017