(Petitioner is in custody)

In,
The Court of Aftab Alam,
J.M. Ist Class, Muzaffarpur.

Ref:- Bela Ps. Case No. 45/2019

U/S 392 I.P.C.

State
V/S
Unknown ------------------------------- Accused
The humble petition for bail
on behalf of petitioner
(1) Sawan Kumar most
respectfully.
Shweth:-
1. That petitioner is innocent and has been falsely implicated in this
case on the instance of his enemies.
2. That Petitioner has not moved for bail before this court or before
any Superior Court earlier in any form.
3. That the case is against unknown and nothing incriminating
articles have been recovered to implicate the name of this
petitioner.
4. That the name of this petitioner came in this case in the
confessional statement of a co-accused Prashant Gaurav which
mentioned in the Para 57 of the C.D.
5. That after the perusal of entire C.D. there is no material against the
petitioner except confessional statement of the co-accused and
confession leading to no recovery has evidential value in the eyes
of Law.
6. That the real fact is that police could not searched the real culprits
after two years of the occurrence and the name of this petitioner
has been falsely implicated to save their own skin.
7. That petitioner is in custody since and has been
sufficiently punished.
8. That Local bailers are ready to stand sureties for him.
9. That petitioner is man of means hence there is no chance of their
absconding.

It is, therefore, prayed that

petitioner be enlarged on bail
and for which petitioner shall
ever pray.