MEMO OF THE APPEARANCE

IN THE COURT OF JUDICIAL MAGISTRATE, SHURE, at KALKAZI

Cr.M.P. Np................. of 2010

Crime No............... of 2010

(on the file of the FIR No, police station at Shure)

Rakesh Kumar, aged 28, son of Rajesh Kumar residing in housing unit of teachers colony,
Janpath Nagar, Shure…………………………………………………………Petitioner/Accused

Versus

The State of Kalnar, represented by Station House Officer, Janpath Nagar, Police
Station…………………………………………………………………... Respondent/Respondent

MEMO OF APPEARANCE

I have been duly instructed from the Petitioner/Accused to proceed with the case

Advocate for the Petitioner/ Accused

 MEMO OF THE APPEARANCE

IN THE COURT OF JUDICIAL MAGISTRATE, SHURE, at KALKAZI

Cr.M.P. Np................. of 2010

Crime No............... of 2010

(on the file of the FIR No, police station at Janpath Nagar)

Rakesh Kumar, aged 28, son of Rajesh Kumar residing in housing unit of teachers colony,
Janpath Nagar, Shure…………………………………………………………Petitioner/Accused

Versus

The State of Kalnar, represented by Station House Officer, Janpath Nagar, Police
Station…………………………………………………………………... Respondent/Respondent

BAIL APPLICATION/PETITION FILED UNDER SECTION 436 OF CRPC

1. That the petitioner is a resident of Janpath Nagar. He is a paid lorry driver. On 4-5-2010 at
4.00 p.m. while the petitioner was driving his lorry from Janpath Nagar to kalkazi, an accident
occurred near NSTL at Vasulipatnam. When XY suddenly crossed the road without regard to the
traffic, the petitioner's lorry dashed against XY despite the best efforts of the petitioner to avoid
the accident. It resulted in the death of XY. Though the petitioner was not at fault, he informed
police about the accident.

2. That the Police registered a case under Section 304-A IPC and arrested the petitioner on the
evening of 4-5-2010. This Honourable Court was pleased to remand the petitioner for fourteen
days when he was produced before the Court on 5-5-2010.

3. That the petitioner is an innocent person. He is a poor man, with driving as his only means of
livelihood and has to maintain himself, his wife and two children at present. The petitioner's wife
is carrying now. The petitioner has a fixed place of abode at Janpath Nagar. There is no intention
or scope for the petitioner to escape from the jurisdiction of the Court if the petitioner is released
on bail. The offence alleged against the petitioner is a bailable offence.

4. That in the aforementioned circumstances, the petitioner begs to submit that the petitioner may
be enlarged on bail during the pendency of the case.
 MEMO OF THE APPEARANCE

5. The petitioner also submits that he did not file any bail application in any other Court.

Therefore it is prayed that the petitioner be enlarged on bail on terms and conditions this Hon'ble
Court deems fit and proper.

Kalkazi.

Dt.: 25-5-'10 Counsel for petitioner