2nd Bail Application under section 439 of Cr.P.C.

In The Court Of Hon’ble Sessions Judge, Narnaul

Mohit Kumar S/o Sh. Chandan Singh, aged 19 years R/o vill. Rajpura Tehsil
Ateli and Distt Mahendargarh, Haryana.

…Petitioner

Versus

State of Haryana

…Respondent

FIR No. 216

Dated – 13/08/2019
Under Section- Section 4 of POCSO Act and
Section 3 of SC/ST Act.
P.S.- Ateli

2nd Bail Application under section 439 of Cr.P.C.

Hon’ble Sir,

The petitioner submits as under:

1. That a false case has been got registered by the police against the

accused/petitioner after concocting a story in collusion with the

 complainant, whereas the petitioner is innocent and is confined in jail

since 18/08/2019 in the present case.

2. That the above noted case is pending in the Hon’ble court of Ms. Mona

Singh, Ld. Additional Sessions Judge, Narnaul and is fixed for …………… for

recording the statement of prosecution witnesses.

3. That the accused had filed his first bail application under section 439 of

Cr.P.C. in the Hon’ble Court of Ms. Mona Singh Ld. Add. Sessions Judge,

Narnaul and the same was dismissed as withdrawn vide order dated

12/06/2020.

4. That due to the COVID-19 pandemic the trial of the case is being delayed

and there are very chances that the conclusion of trial and final decision

of the case may take sufficient long time.

5. That the accused is languishing in jail and due to summer season and heat

wave, the accused is regularly suffering from fever.

6. That it is requested that an interim bail for the period of six weeks may

kindly be granted to the accused/petitioner.

7. That the petitioner has deep roots in the society and as such there is no

apprehension of absconding of the petitioner/accused or tampering with

the prosecution witnesses and incriminating articles in the event of his

release on bail.
8. That petitioner is ready to furnish sound surety as per the orders of the

Hon’ble court.

9. That the petitioner shall appear before the Hon’ble Court as and when

ordered by the court.

10.That the petitioner shall abide by all the terms and conditions to be

imposed by the Hon’ble court in the event of release of petitioner on bail.

Therefore, it is submitted that the present

application for bail may kindly be allowed and petitioner may please be

released on bail and in the alternative it is further submitted that looking

into the present scenario arising due to the COVID-19 pandemic any

other appropriate relief which the Hon’ble court deems appropriate may

kindly be granted.

Date:

Submitted by:
Mohit Kumar
S/o Sh. Chandan Singh,
aged 19 years R/o vill. Rajpura
Tehsil Ateli and Distt Mahendargarh,
Haryana.

Through counsel