BEFORE THE COURT OF DISTRICT AND SESSIONS JUDGE, AT DHANBAD.

A.B.A. No. --------------/2016.

(Arising out of C.P.Case No-1141which was latter converted to Bank More P.S Case No.-
255/2018 under section 156(3) pending before the Court of Ld.Chief Judicial
Magistrate,Dhanbad).

APPLICATION U/S 438 Cr.P.C FOR GRANT OF ANTICIPATORY BAIL ON BEHALF OF THE
ABOVE SAID PETITIONER.

( U/s 406,420,467,460,120(B) of I.P.C)

IN THE MATTER OF:-
Bank More P.S Case No.-255/2018
AND

1.PINKI SINGH (Aged-40years)

Wife of Dr.Manish Singh.
R/O Tapovan Colony,Near T.V.S
Show Room,Sabalpur,Dhanbad
Jharkhand Pin code-8460032.
Ph No. -9835106414

Adhar No.-764466947531

……….
……….Petitioner
-VS-

1. The State of Jharkhand.

 2. Jageshwar singh
S/o Kashi Singh
R/o Mangrudih,P.O+P.S-Giridih
District-Giridih
Adhar No-90049339
Giridih,Jharkhand

……….……….Opp. Party

The humble petition on behalf of the aboved

named accused person,

Most Respectfully Sheweth:-

(1) That this is an application for grant of anticipatory bail to the petitioner who is
apprehending her arrest in connection with Bank More P.S Case No.-255/2018 for
the offence under sections U/s 406,420,467,460,120(B) of the Indian Penal Code
,pending in the court of Learned Chief Judicial Magistrate Dhanbad.

(2) That the petitioner had not moved before this Hon’ble court for his Anticipatory bail
or Regular bail in concern court for instant case. Neither moved Anticipatory bail
application in Hon’ble Jharkhand High Court and Neither any process under section
82 and 83 of Cr.P.C issued by Ld. Court of Chief Judicial Magistrate, Dhanbad.

(3) That the in short the prosecution concoted story is one Mr.Jageshwar Singh opened the
DEMAT ACCOUNT in S.M.C GLOBAL SECURITY LTD. having its registered
office at 11/6B,Shanti chamber,New Delhi-110005.And its Sub-Broker Office 422/
Shriram Plaza Bank More,Dhanbad on dated 22.05.2008 for investment in share
registered in N.S.E & B.S.E Exchanges.The complainant invested rupees 38,100
/-through his DEMAT ACCOUNT.
But due to loss in share market his shares and equity also
redeem its value.As on dated 03.05.2017 the amount left in his Dmate account is Rs
 69.15/-only after downfall of share prize and maintains charges applicable as per term
conditions.
(4) That the aggrieved from service of S.M.C Global Security Limited this present case is
registered under section 200 of Cr.P.C and Ld. C.G.M pleased to sent the petition for
inquiry and investigation.The Bank More police registered the case having registration
No.255/2018.

(5)That the applicants is not required in any kind of investigation nor any kind of
custodial interrogation is required.

Grounds

(1)That the petitioner is through out innocent and applicant having very good antecedents,
She belongs to good family and there is no criminal case pending against her except this
one.

(3)That the under the jurisdiction of S.E.B.I honourable court is not proper plateform for
such type of cases.

(4) That your honours petitioner is Authorized Agent/Sub-Broker of S.E.B.I under Stock
Brokers And Sub-Brokers regulation,1992 having her Cerificate no-0036504 and
Registration No.-INB233599617/23-07714 issued by SECURITY AND EXCHANGE
BOARD OF INDIA.

(Photo copy of Certificate annexed here as Annexture-01)

(5) That the S.M.C Global Security Limited is Authorized Stock Broker of National
Stock Exchange of India having its registration No.-INB011343937 And member of
Bombay Stock exchange Limited.
(6) That the Complainant is a businessman and aware of the risk factor related to Share
and Equity market. Previously the complainant accepted the term conditions of
Account.

(A blank Dmate Account for of the company attached for

kind perusal of your honours court.)

(7)That the petitioner was unmarried unemployed girl after the death of her father and
she started the Sub-Brokerage work with taking the required essential papers.
(8) That your petitioner having good social status .Presently she is working as teacher after
marriage with Doctor Manish Singh.Her In-Law Doctor Suresh Kumar Singh is also the
famous Doctor of Dhanbad City. Complainant filed this petition with ulterior motives
,making money using hook & crook methods.

(9)That your honours petitioner sent all the amount through Bank DD or deposited the
Account of companies Headquarter account No.-207010200010900 Axix Bank ,New
Delhi. Your petitioner have all original counter foil and made available as per order of the
honourable court as and when required.

(Photo copy of all transactions annexed here as

Annexture 3A,3B,3C,3D,3E,3F,3G……)

(9) That the applicant is a permanent resident and there are no chances of his absconding
from the course of justice.

(10)That,your petitioner is ready to furnished the bound as the ld.Court desired.

(11)That the other and further grounds shall be urged at the time of hearing

of the bail application.

It is, therefore, prayed that Your

Honour may graciously be pleased to

allow this application and enlarge

the petitioner on Anticipatory bail.

And for this, the petitioner shall ever pay.