IN THE COURT OF THE HON’BLE IV ADDL.

JUNIOR CIVIL JUDGE:: GUNTUR

Crl.M.P No: / 2022
IN
CC No. 1157/2022
Cr. no. 04/ 2022 of Lalapet P.S.
Between:
SHAIK IMRAN,
S/o Shaik Rasheed, 27 years,
Muslim by Religion,
D.No. 18-6-11B, Ahmad Nagar,
1st line, Lalapet, Guntur town,
Guntur District- 522003 .... PETITIONER/ ACCUSED-2
AND
THE STATE
SUB-INSPECTOR OF POLICE,
LALAPET P.S. ....RESPONDENT/COMPLAINANT

NOTICE MEMO FILED ON BEHALF OF THE PETITIONER

It is to inform you that in above Crl.M.P. No. /2022 bail petition, on behalf of
the accused-2 is going to be filed before this Hon’ble Court. So kindly take notice
regarding bail petitions in Cr. no. 04 / 2022 of Lalapet P.S.

Hence this memo filed.

TO

PUBLIC PROSECUTOR,
ADDL. DISTRICT JUDGE
GUNTUR

ADVOCATE FOR PETITIONER

 S. A.R. & PS
ADVOCATE FOR
PETITIONER/ACCUSED-2

IN THE COURT OF THE IV

ADDL. JUNIOR CIVIL
JUDGE:: GUNTUR

Crl.M.P No: / 2022

IN
CC No. 1157/2022
Cr. no. 04 / 2022 of Lalapet P.S.

NOTICE MEMO

FILED BY:

SHAIK AMEENA REHAMANI

P. SWATHI
ADVOCATES, GUNTUR
ameenask21@gmail.com
8341906508
9492088609
 IN THE COURT OF THE HON’BLE IV Addl. JUNIOR CIVIL JUDGE:: GUNTUR
Crl.M.P No: / 2022
IN
CC No. 1157/2022
Cr. no. 04/ 2022 of Lalapet P.S.
Between:
SHAIK IMRAN,
S/o Shaik Rasheed, 27 years,
Muslim by Religion,
D.No. 18-6-11B, Ahmad Nagar,
1st line, Lalapet, Guntur town,
Guntur District- 522003 .... PETITIONER/ ACCUSED-2
AND
THE STATE
SUB-INSPECTOR OF POLICE,
LALAPET P.S. ....RESPONDENT/COMPLAINANT

PETITION FILED ON BEHALF OF PETITIONER / ACCUSED-2,

U/S. 437 & 439 OF CR.P.C.

1. Address of the petitioner for the purpose of the process is that of Superintendent,
District-Jail:: Guntur.

2. Address of the Respondent for the purpose of the process is that of the Public
Prosecutor, Guntur.

3. It is submitted that Respondent registered the case as Cr. No.4/2022, U/s. 379 or 411
IPC of Lalapet P.S. against the petitioner/ Accused-2.

4. It is also falsely alleged that offence Occurred in between on 01.01.2022 at 22.00hrs to

02.01.2022 at 06.00hrs at 4th lane, R.Agraharam, Guntur Town and reported in the Police
Station on 03.01.2022 at 17.30hrs, in which the complainant Allamalla Surendra S/o
Satyanarayana, 27yrs, Telaga, 4th lane, R.Agraharam, Guntur Town gave a report stating
that he is working as assistant at one lawyer and he is using his lawyer¿s Glamour Motor
cycle bearing no. AP07EB4343 for his needs. On 01.01.2021 at about 22.00hrs he parked
said motor cycle in front of his house and after he was slept, next day morning he came
outside and found that the said motor cycle was missing. He searched for motor cycle in
surroundings area but in vain. Total worh of motor cycle about Rs. 10,000/-.So he
requested to take action. Hence FIR filed.

5. It is submitted that petitioner/accused-2 name was not mentioned in FIR.

6. The petitioner/ accused submit that he is innocent of the offence and is a respectable
person in the town. The allegation filed on the accused are not correct and does not have
any materialistic evidences to prove that he committed any offence (charge he is accused)
Further I would like to bring to your notice that the accused is a self earning person and
 does not need any of such acts to earn money. He is innocent and he was framed into this
act of offence due to some other personal grudge in between the accused. It is submitted
that the respondent is an influential and high-handed person.

7. The accused have a family who depends on him and on his income and no one is there to
take care of his old parents.

8. In addition to this there is a pandemic outbreak going on due to the spread of COVID-19,
there is no one to look after his family and he have an old aged parents to take care,
accused is poor and only person to earn money at home and in-addition to this there is a
great risk of being a victim to this dangerous virus COVID-19, which results in
irreparable loss to his family.

9. The offence charged are not punishable with life imprisonment or death penalty and the
quantity said to be carried by the accused does not constitute to the quantity of
commercial quantity as fore said by the act.

10. That the accused is willing to furnish surety and bail bonds to the satisfaction of this
Hon'ble court on being ordered to be released on bail. The accused is also willing to join
the Court proceedings and bind himself by the terms and conditions laid down by the law
or by this Hon'ble court. It is submitted that the applicant undertakes that the accused will
be present as and when required in accordance with the law.

11. The respondent shown the arrest as on 25-02-2022 and produced accused-2 before the
Hon’ble IV ADDL.JUNIOR CIVIL JUDGE, GUNTUR on 26-02-2022 and the
Hon’ble J.C.J. had passed order to remand the petitioner/accused-2 to judicial custody.

Hence, this application is filed for the following amongst, other grounds to be urged at the
time of hearing.

GROUNDS FOR REGULAR BAIL

1. Petitioner did not commit any offense and he was falsely implicated in this case due to
enmity.

2. It is submitted that by getting arrested the accused has been deprived of his valuable
fundamental right of liberty by abuse of legal provisions and process of law by the
complainant does not disclose any offense much less the offenses Cr. No.4/2022, U/s.
379 or 411 IPC.

3. It is submitted that the mandatory provisions of law that ought to be followed was not
followed by the Respondent in booking the case and after booking the case against the
 petitioner.

4. It is submitted that the accused is a responsible citizen with a family how depends on
him, so there is no chance of his jumping over the bail.

5. The Petitioner has Sureties.

6. Petitioner is a law-abiding citizen having ostensible means of livelihood.

7. Accused-1 and CICL are released on bail.

8. Investigation is completed and examined u/s 239 Cr.P.C is also completed in this case.

9. It is further submitted that Petitioner/Accused-2’s wife had given birth to child on

20/03/2022 and the presence of petitioner is very much necessary for taking care of  his
wife and new born child.

10. There is no cause to apprehend that the petitioner will either abscond or tamper with
the Prosecution evidence if he was released on bail.

The Petitioner, therefore prays that the Hon’ble court may please to release the
petitioner/Accused-2 on bail in Cr. No.4/2022, U/s. 379 or 411 IPC of Lalapet P.S.
against the petitioner/ Accused-2.

Guntur
Dt. 21/04/2022 Advocate for petitioner/Accused

N.B. No similar application was pending or filed before any court till today.
 VERIFICIATION

I SHAIK RASHEED ,S/o. Jabbar, Muslim, Aged 47 about years, father of the
petitioner/accused-2, R/o. D.No. 18-6-11B, Ahmad Nagar, 1st line, Lalapet, Guntur town,
Guntur District- 522003, Person interested in the above accused duly hereby authorize and to
appoint to SHAIK AMEENA REHAMANI AND P SWATHI, Advocates, Guntur, to
appear on behalf of accused and argue the above bail application.

No other person is authorizing on behalf of accused except this Advocate.

SIGNATURE OF THE PERSON INTERESTED

VERIFIED IN MY PRESENCE

ADVOCATE
 S. A.R. & PS
ADVOCATE FOR
PETITIONER/ACCUSED-2

IN THE COURT OF THE IV

ADDL. JUNIOR CIVIL
JUDGE :: GUNTUR

Crl.M.P No: / 2022

IN
CC No. 1157/2022
Cr. no. 04 / 2022 of Lalapet P.S.

PETITION FILED ON BEHALF

OF PETITIONER / ACCUSED-2,
U/S. 437 & 439 OF CR.P.C.

FILED BY:

SHAIK AMEENA REHAMANI

P. SWATHI
ADVOCATES, GUNTUR
ameenask21@gmail.com
8341906508
9492088609