In,

The court of Dist. & Session judge, Nalanda at Biharsharif.

B.P No.-......................................./20

In the matter an application on U/S- 439 CRPC in Noorsarai

P.S case no. – 230/20

U/S- 147, 148, 149, 341, 323, 307,354(B), 504 IPC and 27 of
arms act.

And

In the matter of:-

(1) Raju yadav age – 25 yrs.

(2) Pyare yadav S/o- Bhola yadav age- 60 yrs of village –

Milki par P.S- Noorsarai, Dist.- Nalanda .
.Petitioners.

Vs.

The state of Bihar........................O.P

The humble petition of regular on behalf

of the petitioner above named:-

Most Respectfully Showeth

1. That, one Pramod kumar of village- Milkipar has

given a written petition to S.H.O Noorsarai on the
basis of which this case has been lodged against the
petitioners and his family members and case is
pending for awaiting chargesheet before A.C.J.M-
VII.
2. That, on behalf of petitioner this regular bail
application is being filed for the first time earlier no
bail application either anticipatory or regular has
ever been moved before this superior court.
3. That, the prosecution case in brief is on 26/07/20 at
7 Pm informant Pramod kumar was sitting at his
home with his father in the mean time Maruti
kumar, Alok kumar , Pyare yadav , Raju kumar
came there and started abusing and throwing piece
of bricks and stoneand opening fire also and
suruchi kumari cousin sister of informant came
there for rescue then she has been assaulted
catching hair , this is the story of the case.
4. That, the petitioner is in custody since 27/07/20
and bail application was moved before the court of
A.C.J.M –VII which has been rejected on 17/-8/20
and hence this bail application .
5. That, the petitioners has been arrested by the
police on 27/07/20 since then he is in judicial
custody.
6. That, the petitioner are quite innocent and they
have falsely implicated in this case by the police at
the instance of informant Pramod kumar only to
save his skin from the counter case that is P.S
Noorsarai case- 231/20, U/S- 147, 148, 149, 341,
323,307, 504 IPC and 27 of arms act in which
petitioner Pyare yadav is the informant and
Pramod yadav and others are the accused.
7. That, there is a case and counter case both these
party are co-villagers next door neighbour and both
the parties do not want to proceed the case
8. That, 307 is not applicable and 354(B) is super
addition and in specific overtact has been alleged
against the petitioner and pyare yadav is an old
man aged about 60 yrs.
9. That, the petitioners are ready to offer the
substantial securities to the satisfacation of the
court.
It is therefore prayed that the
petitioner may be released on bail.

Advocate – Mahesh Singh Yadav

E.R No. - 1055/89

Email Id – Maheshsinghyadv89@gmail.com

Mobile No. - 7209320815