In,

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

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

In the matter of an application U/S- 438 CRPC in Giriak P.S

case no.- 251/20

U/S- 279, 337, 338, 341, 323, 324, 326, 307/34 IPC

And,

In the matter of Bablu yadav @ Bablu kumar S/o- Pyare

yadav of village- Bigbanpar, P.S- Deepnagar , Dist.- Nalanda
-Petitioner

Vs.

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

The humble petition of anticipatory bail

on behalf of the petitioner above
named:_

Most Respectfully Showeth

1. That, one Binda Devi W/o- Ramlakhan Prasad of

village- Raiter , P.S- Giriak , Dist.- Nalanda has
given a written petition to S.H.O Giriak on
19/07/20 then this case has been lodged .
2. That, on behalf of petitioner earlier no bail
application either anticipatory or regular has ever
been moved either before this court or before any
superior court.
3. That, the prosecution story in brief is that on
19/07/20 at 7:00 am when the informant Binda
 Devi came out from the house on road when Bablu
yadav dashing from the motorcycle the right hand
of the informant was broken then informant son
Dinesh Prasad and grand son Prem kumar came
for rescue and taken away the key of motorcycle
then Bablu yadav called to his father in law Lakhan
yadav along with Chandrika yadav, Jodendra
yadav , Shiv Shanker yadav armed with weapon
they have came and assaulted the grandson of
informant causing injury on the right shoulder.
Shiv Shanker yadav assaulted to Dinesh causing
injury on Shoulder of the Dinesh . the accused
persons given threatening and lastly flew away
then injured was brought to Sadar hospital
Biharsharif.
4. That, admittedly the petitioner is named in the FIR
and case is non-bailable section so petitioner has
apprehension that he may be arrested by the police
at any moment and hence this bail application.
5. That, petitioner is quite innocent has not
committed any offence and he has falsely been
implicated in this case due to save his skin from the
counter case that is Giriak P.S case no.- 252/20
U/S- 341, 323, 379, 307, 504, 506 IPC in which
Rukmini Devi mother in law of the petitioner is
informant and Dinesh Prasad , Manoj Prasad ,
Bambam kumar @ Prem kumar and others are the
accused.
6. That, all the sections are bailable except 307 IPC
and this section is not attracted in this case.
7. That, admittedly petitioner is the rider of the
motorcycle due t o neglance there was some injury
on Binda Devi and the sons of Binda devi have
bruetly assaulted the petitioner Bablu yadav for
which Rukmini Devi has lodged case and this
petitioner has sustained head injury, inspite of that
he had made an accused.
8. That, the petitioner is man of respectable family
and there is no criminal anticident at all.
9. That, the petitioner is ready to abide all the
conditions of the court for anticipatory bail.
It is therefore prayed that the
petitioner may kindly be
released on bail.

Certificate

Certified That, on behalf of

petitioner earlier no bail application
either anticipatory or regular has
ever been moved either before this
court or before any superior court.

Advocate – Mahesh Singh Yadav

E.R No. - 1055/89

Email Id – Maheshsinghyadv89@gmail.com

Mobile No. - 7209320815