In the Court of the ______________

At Bangalore

Criminal Miscellaneous Petition no. 619 /2011

1. __________, s/o __________,

Aged about _______ yrs

2. _________, s/o ____________,

Aged about __________ yrs

Both residing at ________,

…Petitioners

v.

State of _______________,

represented by ______________ Police Station

…Respondent

Under Section 438, Code of Criminal Procedure, the Petitioners above named
respectfully submit as follows:

1. That on a first information report dated ___ lodged by

__________alleging___________________________________________, the
Respondent police have registered a case, Crime no. 619/2011, and have taken
up investigation of the case. Certified copy of the FIR is herewith produced.

2. The Petitioners are law-abiding citizens and reside together

at______________________, with the
_____________________________________.Petitioner no. 1 is a
 well-respected industrialist who is the________________. Petitioner no. 2
graduated from ____________________with _____________and has been
working as a_________________________________. Both the Petitioners enjoy
a strong standing in the community and have never been convicted of any
offence previously.

3. The Petitioners now apprehend that they will be arrested by the Respondent
police in connection with Crime no. 619/2011. The crime relates to
________________________________. The police have questioned the
petitioners on several occasions in pursuance of the investigation of the crime.
Further, the petitioners have come to know that
_______________________________ ( Mention who gave petitioner’s name to
police).

4. The deceased became known to the petitioners in__________________ [Insert

details how the daughter of petitioners met the deceased and what opinion they
had about the deceased, why petitioners opposed the marriage of daughter of
petitioner no 1 with the deceased, how were the relations of daughter of petitioner
no 1 after her marriage with her family, what opinion did the daughter of petitioner
no 1 had about her family after her marriage]

5. The deceased was murdered on__________________________ [Insert details

about the murder how and when the murder of deceased took place]

6. The petitioners have every reason to believe that ______________ [Insert

information about the anticipation of petitioners of being arrested ]

7. The allegations made by the daughter of Petitioner no. 1 are false and baseless.

8. The petitioners submit that their names have been brought up

by____________________________ [Insert information on who has complained
against the petitioners and the reasons for the complaint]
9. The petitioners submit that_____________________ [Mention about when and
how the incident took place]

10. Given the history and antecedents of the

deceased__________________________ [Mention why the accused was
murdered because of his past]

11. The petitioners were both ________________ [Mention details where the
petitioners were at the time of murder]

12. The petitioners are_____________ [Mention about the reputation and character
which the petitioners hold in the society, how the family of petitioners will be
affected on their arrest, how the business of the petitioners will be affected and
how the reputation of the petitioner will be affected]

13. The petitioners undertake to appear for investigation as and when required by the
police, in Court for trial whenever required, not to leave the jurisdiction of the
Court, and not to tamper with evidence or intimidate witnesses. Further, they are
willing to execute a bail bond with or without solvent sureties, and to pay any
amount fixed by the Court. They will abide by any and all conditions as may be
laid down by the Court in the bail order.

14. Wherefore, in light of these circumstances and the interest of justice, the
Petitioners pray that this Hon’ble Court may be pleased to
___________________________________

Place : _________ xxx

Date : Advocate for petitioners

Address for service: _____

Bangalore