IN THE COURT OF THE HON’BLE XIX METROPOLITAN MAGISTRATE,

CYBERABAD, AT KUKATPALLY

Crl.M.P.No………………of 2017

IN
Crime No. xxxx of 2017

BETWEEN:

xxxxxxxxxxxxxxxxx S/o xxxxxxxxxxxxxxx,

Aged about: 28 years, Occu: Self Employed,
R/o. 15-25-890/10/CS (13/MIG), Rushi Complex,
KPHB Colony, Kukatpally, Hyderabad – 500 072

....Petitioner/Accused No.1
AND

The State of Telangana,

Rep. by the Station House Officer,
P.S. KPHB Colony,
Hyderabad
.... Respondent

Offence: Under Section 385 & 506 IPC

PETITION FILED UNDER SECTION 436 OF CRIMINAL

PROCEDURE CODE

May it please your honour,

1. It is respectfully submitted that the present complaint is filed

by the complainant purely to harass the accused to make him
vacate his shop premises even though there is a lease which is
existent till late next year.

2. It is respectfully submitted that with due respect for law, the

petitioner has surrendered before this Hon’ble Court and
undertakes to cooperate with the investigation to clear his
name and also to demonstrate in categorical terms that the
present case is a clear case of abuse of process and a scare
tactic to threaten the accused and make him give up his shop
due to the illegal contract of eviction taken by the defacto
complainant.

3. It is respectfully submitted that the petitioner is the only bread

winner and the shop is the only source of income and thus he
is unable to vacate the same before the expiry of lease.
4. It is respectfully submitted that from aforesaid circumstances
and facts as well as material contents of the complaint, the
desirability of this bail petition for the following among other
grounds:

GROUNDS

1. The offence as alleged is a bailable offence and the petitioner

undertakes to fully cooperate with the Police in the
investigation.

2. The complaint is a case of abuse of process to terrorize the

petitioner to force him to vacate and leave his only source of
livelihood.

3. The complaint clearly shows the ulterior motives of the defacto

complainant and not due to any crime committed by the
petitioner/accused.

Prayer:-

It is therefore, prayed that this Hon'ble court may be pleased to

enlarge the petitioner on bail in considerate terms taking into
consideration his financial difficulties and pass any such order(s) as
deemed fit by this Hon’ble Court in the interest of justice.

Dated:……………….
Kukatpally Petitioner

Counsel for Petitioner

 FIR No. xxxxx /2017

IN THE COURT OF THE

HON’BLE XIX METROPOLITAN
MAGISTRATE, CYBERABAD, AT
KUKATPALLY
Crl.M.P.No………………of 2017

IN
Crime No. xxxxx of 2017

BETWEEN:

xxxxxxxxxxxxxxxxxxxxx
.... Petitioner/Accused

AND

The State of Telangana, Rep by

SHO, P.S. KPHB Colony,
Hyderabad
....Respondent/Complainant

BAIL PETITION

Filed on:

Filed by:
Counsel for Petitioner

Address:
M/s Vankina, Allu & Parasaram
Advocates
Jyothisri Vankina,
Midhun Kumar Allu,
Anupama Maganti, Ramya Satyam
Pothireddi

O/o VAP Advocates, Flat no.301,

Plot no. 450, 100 Feet Road,
Ayyappa Society, Madhapur,
Hi-Tech city, Hyderabad 500081

Cell: 98494 20969 / 95815 76977