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In,

The court of District and Session Judge,

Gaya

Bail petition no. ................. 2019

(Arising out of Sherghati P.S. case no. 46/19, State vs. Pintu Paswan and others,
under section 304(B), 120(B) and 34 of the IPC, pending in the court of A.C.J.M.
Sherghati, Gaya.)

Archana Devi w/o- Surender Paswan resident of vill-Chhach, P.O. - Morataal,


P.S. - Bodhgaya................................ Petitioner

Vs.
State of Bihar................................Opposite Party

The humble petition for an


Anticipatory on behalf of
petitioner aforesaid.

Most respectfully showeth:

1. That the petitioner is innocent and she is falsely implicated in this case.
2. That the regular bail petition has been filed on behalf of petitioner either
before this court or before any higher court.
3. That the petitioner has not been any criminal antecedent.
4. That the prosecution story in short is that the deceased Kanchan Kumari
aged 20 years married by Hindu rituals in April with Pintu Paswan s/o
Bineshwer Paswan resident of vill-Chhach , P.O.-Morataal , P.S.-
Bodhgaya . Within a month they tortured that her height is tiny and beat
several times and demanded dowry of Rs 50 thousand
5. That deceased Kanchan’s Father alleged that on dated 10/02/2019 at
noon about 1 P.M. they burnt and murdered her. Deceases Kanchan’s
Father further alleged that whole family of in-law involve in the murder
of her daughter.

(The certified copy of F.I.R. is hereby


annexed with the bail petition and
marked as the annexure- A)

6. That the petitioner father Bineshwer Paswan bail is granted by the High
Court.

(The web copy of bail order is hereby


annexed with the bail petition and
marked as the annexure-B)

7. That the petitioner is languishing for no fault of their own.


8. That the accused petitioner is permanent residence within your honour
jurisdiction.
9. That there is no chance of absconding to the petitioner or tampering
with evidences.
10.That the accused petitioner is ready to furnish the bail bond of any
reasonable amount decided by this court.

It is therefore prayed that your


honour may be graciously pleased
to kindly enlarge the petitioner on
bail.

And for this petitioner shall ever pray.

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