In

The court of Dist and session judge,

Buxar
A.B.P. No----------2022
Arising out from Nawanagar Basudewa O.P Case No – 105 /2022
U/S – 147.148.149.341.323.307.504.379 i.p.c and 27 Arms Act
In the matter of an application under
sec 438 Cr.P.C.

And
Also in the matter of:
Nandjee Singh S/o Shribhagwan Singh Age—46 years
res-Chakoudha, P.S-Basudewa O.P( Navanagar), Dist-Buxar
Petitioner
VRS
THE STATE OF BIHAR,
Opp.
The humble petition for Anticipatory
bail in above noted case on behalf of
above named petitioner is as follows:

1. That your petitioner is a law abiding citizen, who is seriously apprehending

his arrest in connection with Arising out from Nawanagar Basudewa O.P
Case No – 105 /2022

2. For that earlier no any regular or A.B.P have been filed on behalf of your
petitioner either before the learned court or before the hon High Court nor
is pending in any other Court also.

3. That the prosecution story in brief is that one Ramjee singh files a case in
Nawanagar P.S. In which he alleged that on dated 01/04/22 when he was
returning in way of his village. All accused persons surrounded him, who
were carrying sticks, Iron Road, Bhala and Pistols, started beating him. He
fell down on land. Then one co-accused withdrawn 9500 Rs from him. After
that all person left their Motorcycles and flew away. After that police lodge
 Nawanagar 105/2022 under above mention section and investigation
started.

4. That as soon as your petitioner could learnt about his false implication, is
moving his anticipatory bail on following amongst others:
GROUNDS

1. That the Applicant is innocent and he is falsely implicated in the alleged

offence. He has nothing to do with the alleged offence.

2. That assuming the allegations made by the Informant true, the incident
occurred in such situation that it can be seen that there was neither any
motive nor intention to kill the complainant and as such the present
applicant cannot said to have committed an offence as mention is F.I.R

3. That the Complainant is residing at Chaukaudha Village and where as the

accused Applicant in the time of alleged incident residing in the campus of
his Bricks Manufacturing industries that is situated 2 K.M away from the
Place of occurrence and considering the distance, it show the mala fide
intentions of the complainant. That he make a false allegation on this
applicant because informant and his sons are engaged in illegal wine supply
and distributation for which her sons are under custody in Central Jail.

4. It is also submitted that if your honor perusal the f.i.r then find out that
Even if presence of the applicant was assumed at the scene of occurrence,
then also evidently, he did not play any active part in the entire incident.

5. For that no case under any section is made out against your petitioner,
because your petitioner was not committed and participated in any offence
as alleged by the informant of this case and what so ever allegation has
been assigned against your petitioner is false and factually incorrect.

6. It is submitted that nothing has been recovered from the place of

occurrence that related with your petitioner.

7. That no overt act what so ever has been attributed by the present applicant
 8. That taking in to consideration the totality of the F.I.R and allegation it
cannot be said that the applicant have participate any active role to attract
the alleged Section of F.I.R.

9. That the Applicant is residing at the address mentioned herein above, along
with his family and as such he will not abscond anywhere if he is released
on bail.

10.The Applicant undertakes that he shall make himself available for

interrogation by the police officer, in connection with this offence as and
when required.

11.That the Applicant is ready and willing to abide by the terms and conditions
put by this Hon’ble court, if he is released on anticipatory bail.

12.That the accused Applicant will not misuse the liberty and will not tamper
the evidence.

13.It is also submitted that your petitioner have a criminal case Nawanagar P.S
Case No – 139/2019 and Dumroan P.S case no - .

14.For that your applicant is also ready to furnished sureties as per your
honor’s satisfaction.
Hence therefore it is request that
your honor would be pleased to
Kindly order to release your
petitioner on bail.
Verification

I Ramnarayan Singh S/o late Bhagwan Singh ,

Res: Vill- Atgar Bintoli, Po- Athar. PETITIONER

P.S- Nawanagar, Dist-Buxar does

dereby verify that all the content
of this A.B.P are true to the best
of my Knowledge and believe.

Place………………..
Date………………..