Before the Court of Hon’ble Shri Vaibhav Mandloi Ji Additional District and session

Judge, District Court Indore, Indore

In the Matter of

Mr. Nikhilesh Chouhan, S/o Shri R.K. Chouhan, 23, Indrapuri Colony Bhawarkuan
Square Indore (petitioner)

Versus

State Of Madhya Pradesh through Shri R.K. Singh S/0 late Shri S.K. Singh.

(Respondent)

FIR Number 202/2016

Under Section 420 & 120B of the Indian Penal Code 1860

Police Station Bhawarkuan Police station

Accused Under Custody Since last one day

APPLICATION UNDER SECTION 439 OF THE CODE OF CRIMINAL PROCEDURE FOR

THE GRANT OF BAIL ON BEHALF OF MR NIKHILESH CHOUHAN

Most respectfully shows that

1. That the present FIR has been registered on false and bogus facts. The facts
stated in the FIR are fabricated, concocted and without any bias.
2. The police has falsely implicated the applicant in the present case and arrested
him although the applicant is a respectable citizen of the society and is not
involved in any criminal case.
3. That the facts stated in the complaint against the applicant are civil dispute and
does not constitute any criminal offence.
4. That the applicant is not required in any type of investigation nor any type of
custodial interrogation is required.
5. That the applicant is having very good antecedents, he belongs to good family
and there is no criminal case pending against them.
 6. That the applicant is a permanent resident and there are no chances of his
absconding from the course of justice.
7. That the applicant undertakes that he will not directly or indirectly make any
inducement threat or promise to any person acquainted with the facts of the case
so as to dissuade him from disclosing such facts.
8. That the applicant is ready and willing to accept any other conditions as may be
imposed by the court or the police in the connection with this case.
9. That the applicant most humbly prayed before this honorable court to be released
on bail. Any the court may pass any other order which the court may deemed fit
in the interest of justice.

Applicant Mr. Nikhilesh Chouhan

Through

Council Advocate Jalaj Sarmandal.

MP/1572/2015