IN THE COURT OF MS SEEMA KAROL, LD.

ACJM, RINGAS,
RAJASTHAN

IN THE MATTER OF:

STATE V/s HASEEBUR REHMAN

FIR NO. – 0074/2020

U/S – 420/467/468/471/34/120-B IPC
P.S – RINGAS

PETITION FOR INTERIM BAIL FOR 3 MONTHS FOR THE DATE OF

RELEASE ON THE GROUND THAT PETITIONER YOUNGER BROTHER
WITH HIS FAMILY VISITED HIS NATIVE VILLAGE AND CONFINED IN
LOCKDOWN IN HIS NATIVE PLACE NEHTAUR, DISTRICT BIJNOR
WITH HIS FAMILY, THE PETITIONER WIFE PINKY WITH HER
DAUGHTER AGE ABOUT 2 YEARS FOLLOWING LOCKDOWN AT
PETITIONER RENTED HOUSE ALONGWITH HER DAUGHTER
SUFFERING SYMPTOMS OF FEVER THOUGHT INFECTION,
BODYACHE, AND RUNNING NOSE AND NOBODY IS AVAILABLE TO
PROVIDE THEM FOR CORONA TESTING HENCE THE PRESENT
PETITION FOR INTERIM BAIL ON THE EMINENT URGENCY

MOST RESPECTFULY SHOWETH:

1. That the petitioner family consisting of husband and wife with a daughter
age about 2 years the brother of the petitioner live separately in Delhi
with his family but had gone with his family at the native place at
Nehtaur, District Bijnor and confined there owing to Corona epidemic at
his native village.

2. That the petitioner is in Judicial Custody in the above mentioned case

since his arrest police obtained 14 days PC in fraction but nothing
incriminating was recovered pertaining to alleged allegations in the FIR
two cases petitioner got brought to the police station in the PC remand
period but no evidence is available connecting the case with the
commission of crime, one Arun Sharma is committed crime and police
 falsely implicated the petitioner on the instance of Arun Sharma,
keeping Arun Sharma aside.

3. That the Judicial Custody of the petitioner is at the pre-trial stage and
established law is that under trial is innocent under the grab of strong
presumption of innocence prevails for the under trial till the verdict
pronounce by the court in the case.

4. That the Article 21 of the Constitution of India provides as a fundamental

right protection of his/her life, as the country is waging war with the
Crorona/COVID 19 and in the Arthur Road jail in Bombay 80 prisoners
found positive of Corona Virus struggling for their life, this is well known
news and the petitioner apprehend life danger for infection of Corona
Virus and right to petitioner is given vide Article 21 of Constitution of
India to protect his life, hence petitioner is praying for interim bail to
protect his life as yet the petitioner is not found guilty by this Hon’ble
Court.

5. That as the petitioner came to know that his wife is alone in lockdown
alongwith his small daughter age about 2 years also the difficulty for
ration and food is strictly prevailing and his wife and daughter suffering
from the same, I came to know that as my bail application is rejected by
this Hon’ble Court after arguments made by my counsel, I also came to
know that my wife Pinky is having fever, bodyache and running nose in
the period of COVID 19 epidemic nobody in the house or in vicinity due
to Corona Virus fear available to provide medical help to my wife for the
test of Corona Virus and the petitioner is the only person to take care of
my wife and small daughter to prevail medical help and subjected to test
of corona to my wife, hence the present petition is preferred for interim
bail.

6. That the petitioner undertake to abide any condition imposed by this

Hon’ble Court after grant of interim bail.
 Therefore, it is prayed that the petitioner may kindly be granted
interim bail in urgency as mentioned above and be release on interim
bail for 3 months from the date of his release in the interest of Justice.

Petitioner
Through

Counsel
Place :
Date :