(ACCUSED IN CUSTODY)

In
The court of Dist & session judge, supaul
B.A. NO...................../2020
BIRPUR P.S CASE NO-85/20
U/S-341,342,307,302,120(B)379/34 IPC and 27 Arms Act
Pending in the court of ACJM I, Birpur
1. Karan Yadav@ Laddu Yadav aged about of 19 yrs
s/o- Bindeshwar Yadav, of village Kamat Aeraigi,Koshikhapur, ward
no- 12, P.S-Birpur, Dist.- Supaul
Mobile no-9060643463
......................................................Petitioner
Vrs.
State of Bihar..................................................O.P
The humble petition for bail filed on behalf
of the accused petitioner named above.
MOST RESPECTFULLY SUBMITTED AS UNDER:
1. That the prosecution case as alleged in short is that on the alleged date
and time of the occurrence ,the husband of the informant namely Ganesh
Yadav as usual coming back to his home with his nephew namely Pradeep
Kumar Yadav from godam and when they reached near the flood place,
the accused persons as named in the FIR, were armed with rod, desi Katta
and pistol and the accused Jagdish korgia fired on which the husband of
the informant Ganesh Yadav sustained injuries and fell down.it is also
alleged that the accused Kundan Kumar assaulted his nephew ,Pradeep
Kumar Yadav(driver of the motorcycle)by a bamboo and the nephew fell
down, on which Manish Yadav fired with his desi Katta on the chest of
Pradeep Yadav and as a result , the nephew of the informant Pradeep
Yadav died on the spot.It has also been alleged that the accused person
snatched Rs. 50,000/- from the husband of the informant and after
hearing about this incident, the informant lost her consciousness and
when the informant regained her consciousness, she submitted a written
petition to this effect.

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 2. That the petitioner accused has not filed any bail application in this case
either before this court or before the apex court prior to it.
3. That the petitioner accused has been arrested on 25-6-2020 and
remanded to judicial custody on 27-06-2020 and the bail prayer for the
petitioner has been rejected on 06-07-2020 by the learned ACJM Birpur.
Being aggrieved and dissatisfied with the above order
the petitioner begs to file this bail application before your
honour on amongst others the following grounds: - 1.For that
the petitioner accused is quite innocent and has committed no offence at all.
2.For that the petitioner accused has been falsely implicated
into this case out of grudge, malice and due to local party politics.
3. For that the co-accused Manish Yadav defeated the husband of
the informant namely Ganesh Yadav in the co-operative pax
chairman election from Banailipatti held in December 2019 and due
to this annoyance and enmity, the petitioner being the supporter and
relative of the co-accused Manish Yadav has been falsely
Implicated into this case.
4.For that the secs. as alleged have got no application against
the petitioner accused.
5.For that the FIR has been lodged after a long lapse of time .
6.For that the petitioner accused is in no manner concerned with the
alleged occurrence.
7. For that the informant is not the eyewitness of this case which
is evident from the FIR.
8.For that the petitioner accused has not been named in the FIR.
9.For that there is no criminal history of the petitioner.
10. For that there is no recovery of any incriminating articles from
the possession of the petitioner.
11.For that the petitioner has been made accused on the basis of
confessional statement made in the police custody, which has been
taken by the police using sheer force and torture.

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 12.For that the applicant is of very good antecedents, he belongs to a
good family and there is no chance of his absconding or
tampering with the evidence in this case.
13.For that the petitioner has not been arrested on the spot.
14.For that the petitioner accused is rotting in jail since 27-06-2020 for
no fault of the petitioner.
15.For that the petitioner is ready to furnish sound sureties to the full
satisfaction of the court.
16.For that the petitioner accused undertake to submit power, affidavit,
court fees etc. after fully opening of the court.
17.That one copy of this petition has been sent to the PP, Supaul to his
email/WhatsApp.
It is therefore prayed to enlarge the
petitioner on bail and for this petitioner accused
shall ever pray .
Petitioner Accused
THROUGH ADVOCATE{LAKSHMI NARAYAN RAN}
CIVIL COURT, BIRPUR

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