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SIRSA
In re:-
P.S. Sirsa
D.O.H: 22.02.2020
Sirsa
Date: 22/02/2020,
(SIMANT PRIYADARSHI)
ADVOCATE
Counsel for the Applicant
LEGAL SHEBANG
GATE NO 6 VIKRAM VIHAR,
LAJPAT NAGAR, NEW DELHI
ACCUSED IN J.C.
SIRSA
In re: -
P.S. Sirsa
D.O.H: 22.02.2020
1. That the charge sheet in the captioned matter has already been filed by the state. That the
applicant/accused is in the custody for more than 145 days.
2. That applicant/accused is law abiding citizen and has utmost respect for law but has been
falsely implicated under section 376/ 506/509 of IPC.
3. That the applicant/accused has not committed the offences alleged and has been falsely
implicated in this case.
4. That the police had already filed the charge sheet in the present case, which means the
investigation by the police is now over. Therefore, no purpose would be served to keep
the applicant/accused in the judicial custody.
5. That the applicant/accused must be given an opportunity to set out and stand on his feet
and to give proper direction to his life, occupation and future. He must be given a chance
to continue to earn his livelihood.
6. That it is humbly submitted that if the applicant/accused continues to remain in custody
he is likely to be filled with hopelessness and the future may appear dark to him.
7. That there is nothing on record to show that the applicant/accused is likely to commit any
offence while on Bail.
8. That the applicant/accused is also not likely to engage n any activities of criminal nature.
9. That the applicant/accused is not likely to influence prosecution witness in any manner
whatsoever while on Bail.
10. That the applicant/accused peace loving and law-abiding citizen and has no desire to
evade the process of law. The applicant/accused is innocent and ready to face trial and
defend himself.
11. That the applicant/accused is not likely to jump Bail as there is no likelihood of him
absconding while trial is pending.
12. That the applicant/accused under text to abide by all the conditions that may be imposed
on him by learned court while granting him Bail in the above said case.
13. That the applicant/accused is having permanent resident and having a good image in the
society so there is no chance of absconding.
PRAYER
It is therefore, in the facts and circumstances of the case and in the interest of
justice it is humbly prayed before this learned court that this learned court may graciously
be pleased to:
a) Release the applicant/accused on Bail till the final disposal of the Case.
b) Pass any other order that is learned court may deemed fit in the interest of Justice.
Sirsa
Dated: 22/02/2020
APPLICANT ARRESTED
(IN J.C.)
Through
(SIMANT PRIYADARSHI)
ADVOCATE
Counsel for the Applicant
ACCUSED IN J.C.
IN THE COURT OF SHRI DEVENDRA KUMAR UPADHYAY
SIRSA
In re: -
P.S. Sirsa
D.O.H: 22.02.2020
AFFIDAVIT
I Mayank S/o Late. Sukhbir Singh R/o Kartarpur, Sirsa, do hereby solemnly affirm and
declare as under: -
1. That, the accompanying application has prepared under my instructions.
2. That, I am the Pairokar of the arrested, he is my elder brother and I am aware about
all the facts and circumstances of the case.
3. That, no other suit is filed in any other court for the same.
Deponent
VERIFICATION
Verified that the contents of my above affidavit are true to best of my knowledge and
behalf and nothing concealed therein.