GROUNDS:

1. The petitioner/accused is an innocent of the alleged offence and he did not commit
any offence what-so-ever.

2. The petitioner belongs to the respectable family and he never involved in any case at
any point of time.

3. There is delay in giving FIR.

5. There is no prima facie case to show that the accused has committed the alleged
offence.

6. He is falsely implicated in this case due to animosity and Village church politics.
7. He is a law abiding citizen and he is not likely to abscond if he released on bail.

8. The alleged offence is u/s. 436, of I.P.C. which is a Non-Bailable one.

9. The parents of the Petitioner have died and he has to look after his old maternal
Grand Mother who is depending upon him. The petitioner is a daily Labour and the
sole bread winner of the family.

10. The Respondent police has already examined L.W’s1 to 5 and deleted U/S. 480 of I.P.C the
investigation is almost all completed and the charge sheet is yet to be filed.

11. So, at this stage there is no question of tampering with the evidence.

12. The petitioner is ready and willing to offer security to the satisfaction of the Hon'ble
Court.

13. There is no similar bail application is pending before any other court.

Therefore, the petitioner/accused prays t:iat this Hon'ble Court may be pleased to
enlarge him on bail pending disposal of the case and to pass necessary orders which are
deemed fit and proper under the circumstances of the case and in the interest of justice.

Place:Guntur Be Pleased to Consider

Dt. 19 -07-2022.

Advocate for the Petitioner/accused.

 VERIFICATION
I,B. Srjuana Rao s/o Devaraju, aged 45 years, r/o Dasu Nagar,
Karlapalem Village & Mandal, Bapatla district, do hereby declare that
I am the only authorized person to appoint Sri Bonigala Vijay Kumar,
B.Prabhkar Rao a d v o c a t e s , G u n t u r t o p l e a d a n d a c t o n b e h a l f
of the above named accused I N CRIME NO. 143/2022 of
KarlapalemPS. Realtionship of B.Srujana Rao with
Accused is Paternal uncle.

No other person has been authorized to appoint my advocate in

the above case.

Signature of the accused /

person interested

Verified in my Presence/Advocate

Note: The Petitioner/Accused filed by the earlier bail application U/S.437 & 439 of
Cr.P.C in Crl.M.P.No.1123/2022 the Hon’ble III Addl.District judge dismissed on 14-07-
2022. This is the 2nd Bail application.
 IN
THE
COU
RT
OF
THE
DIST
RICT
AND
SESSI
ONS
JUDG
E:
AT GUNTUR.
Crl.M.P.No.
/2022
In
Cr.
No.143/202
2 of
Karlapalem
P.S.