IN THE COURT OF HON'BLE COURT DISTRICT AND
SESSION JUDGE: NEW DELHI.
IN THE MATTER OF: -
STATE VERSUS 1 AJAY SWROOP
S/O SH. GHANSHYAM SWROOP
2. GHANSHYAM SWROOP
R/O D-8/10, FF DLF ENCLAVE,
DLF FACE-V, GURGAON,
HARYANA
FIR NO. NOT KNOWN
U/S. NOT KNOWN
P.S. CAW CELL, NANAK PURA
APPLICATION FOR ANTICIPATORY BAIL U/S 438 Cr.P.C.
ON BEHALF OF APPLICANTS/ACCUSED.
MOST RESPECTFULLY SHOWETH: -
1. That the applicant was married with the complainant
and the marriage was solemnized according to Hindu
rites and ceremonies. This marriage was simply
performed between the respectable relatives of the both
families.
2. That the complainant is a doctor by profession was
living peacefully with her husband after the marriage in
her matrimonial house but due to some personal
disputes she started to raise quarrel with the applicant
because the complainant is a doctor and the husband of
the complainant is engineer and M.B.A. The
complainant also said to the applicant that there is no
match between you and me because I want to marry
with a doctor but this marriage was solemnized under
the pressure of my parents.
3. That after some time of the marriage the complainant
pressured to the husband that she cannot living with
the parents of him and she want to live separately but
the husband is elder son of his parents and the sole
bread earner of his family and he is not able to maintain
the expenses of two families and he refused to do so. In
this way due to this reason the complainant threatened
to the applicant’s family that if he will not live
separately then she will implicate them in a false and
frivolous dowry and cruelty case.
4. That the applicant is ready to return back the
complainant to their house and undertakes that they
will live happily and peacefully.
5. That the complainant had filed a false complaint against
the applicant before the CAW CELL Nanak Pura, Delhi.
The applicant had tried to settle the matter with the
complainant but she did not want to settle the same
and she was adamant that she will not live with them at
any cost in her matrimonial house. The applicants had
also tried in the Panchayat to solved the matter but in
vain the father of the complainant said that I am not
interested in the compromised I want 25 lacs rupees for
the expenses of my daughter’s marriage and also told
that we will teach you a lesson and will meet in the
court by next time, in this way both parties could not
reach at the point of compromise.
6. That the applicants tried their best and requested to the
father of the complainant in respect of to sent back her
daughter to her matrimonial house but he refused to do
so and sent and demanded 25 lacs rupees for the
expenses of the marriage of her daughter.
7. That the applicant is the law abiding citizen and belongs
to a respectable family and having deep roots in the
society.
8. That the applicants had joined the proceedings of
investigation before the I.O. of the case. They have great
apprehension for their arrest.
9. That the applicant is ready to join the investigation as
and when required by the I.O.
10. That the applicant has no Criminal antecedents and will
abide by such terms and conditions as imposed by this
Hon'ble Court.
11. That the applicant undertakes not to hamper/tamper to
the prosecution evidence if he will be granted bail.
12. That the applicants are the innocent persons and there
is no fruitful purpose to be solved to send them behind
the bar with the hardened criminals.
13. That the applicant is ready to furnish sound surety as
per the entire satisfaction of this Hon'ble Court as well
as the I.O. if they grant bail.
14. That the applicants are undertaking to compliance all
the terms and conditions which will be imposed upon
them by this Hon'ble Court.
15. That the applicants ready to take back to the
complainant to their house.
PRAYER : -
It is therefore most humbly prayed that this Hon'ble Court
may kindly be granted anticipatory bail to the applicants in the
event of their arrest or alternative seven days notice may kindly
be granted to the applicants before their arrest, in the interest of
justice.
Any other order/direction/relief which this Hon'ble Court
may deem fit and proper may kindly be passed in favour of the
applicants.
APPLICANTS
THROUGH
COUNSEL
DELHI.
DATED: