IN THE COURT OF MS. MANSHI MALIK, M.M.

, (NORTH-WEST),
AT ROHINI COURTS, DELHI
C.C. No. …./2020
IN THE MATTER OF:
STATE VERSUS ANSHU & ANR.
FIR No.387/2016
U/s. 279/337/304-A
P.S. North Rohini

APPLICATION ON BEHALF OF THE APPLICANTS/

ACCUSED THEREBY SEEKING CANCELLATION OF
NBWs ISSUED ON 03.12.2021.

MOST RESPECTFULLY SHOWETH:-

1. That the above captioned matter is pending before this Hon’ble

Court and fixed for today i.e. 27.08.2022.

2. That, it is humbly submitted herein that on 03.12.2021 when the

above titled matter was listed before this Hon’ble Court, the
applicant/ accused was not able to reach this Hon’ble Court due to
the accident of his ________ and was out of station and therefore,
apprised the said fact to his counsel.

3. That, however, the counsel for the accused assured the applicant to
move an application and appraise the said fact to this Hon’ble Court,
however, it seems that the counsel for the applicant/accused did not
appraise the said fact to this Hon’ble Court and thus this Hon’ble
Court was pleased to issue the NBWs against the applicant/accused.

4. That, recently when a police official contacted the applicant and

informed that the NBWs was issued against the applicant/accused,
 the applicant shocked to know the said fact and therefore, tried to
contact his counsel. However, the counsel did not pick up the mobile
phone and therefore, the applicant has to engage new counsel.

5. That the new counsel so engaged by the applicant/accused gone

through the order-sheets of this Hon’ble Court and found that the
matter was also listed on 22.02.2022, virtually, however, neither the
said date was informed to the applicant nor the applicant able to join
the Hon’ble Court virtually and thus could not be appeared on the
last date of hearing

3. That, therefore, in the aforesaid circumstances, founding that the

accused persons could not appeared before this Hon’ble Court, this
Hon’ble Court was pleased to issue the BWs against him.

4. That, the non appearance of the applicants/ accused on the last date
of hearing is neither intentional nor deliberate but due to reasons
mentioned above.

5. That the applicants/accused undertakes to be careful in future.

Hence, the present application.

PRAYER:

In view of the above said facts stated and submission made

herein above, it is most respectfully prayed to this Hon’ble Court
that this Hon’ble Court may kindly be pleased to:

i. Cancel the NBWs issued against the applicants/ accused on

03.12.2021;
 ii. Pass such other or further order(s) which this Hon’ble Court may
deem fit and proper, in the above mentioned facts and
circumstances, in favour of the applicants and in the interest of
justice.

It is Prayed Accordingly.
Delhi
Dated: August, 2022
Applicant/ Accused

Through

(BIJENDRA KR. GAUTAM)

ADVOCATE
Ch No.9, Civil Supply Building
Tis Hazari Courts, Delhi -110054
9899205088 (M)

IN THE COURT OF SH. ABHILASH MALHOTRA, M.M., (CENT),

AT TIS HAZARI COURTS, DELHI

C.C. No. …./2020

IN THE MATTER OF:

STATE VERSUS ASHO SINGH &

ANR.

FIR No.0055/2019 U/s.

33 of Excise Act
P.S. Subzi Mandi, Delhi

BAIL APPLICATION UNDER SECTION 437 CR.P.C. ON

BEHALF OF ANIL KUMAR S/O. SH. DHANI RAM R/O.
 D-176, MAYA PURI, PHASE-2, INDUSTRIAL AREA,
DELHI- 110064

MOST RESPECTFULLY SUBMITTED:

1. That the above titled matter is pending before this Hon’ble

Court and the same is fixed for today i.e. 13.02.2020.

2. That the applicant/ accused has been falsely impleaded as

Accused No.2 in the above titled matter. The applicant,
thus, is submitting to the kind jurisdiction of this Hon’ble
Court.

3. That, the applicant is a law abiding citizen of India and has

been falsely implicated in the above said case. The applicant
is an innocent and only aged about 21 years and has never
been involved in any case except the present one.

4. That the applicant was never committed any offence which

is punishable by law. The applicant is also not involved in
any other Criminal Case.

5. That complainant has falsely implicated the applicant/

accused in the alleged FIR merely on the basis of hearsay
evidence in the capacity of owner of the alleged offending
vehicle to fulfill their ill design.

6. That, even, the applicant has joined the investigation as and

when called by the I.O. nothing incriminating has been
 recovered from the applicant. In fact, the Applicant/Accused
was not even present at the spot at the time of alleged
incident.

7. That the non-grant of bail to the applicant and consequent

detention of applicant will not fulfill any purpose of
prosecution, in any manner whatsoever as the investigation
in the present case has already been completed.

8. That the applicant is a resident of Delhi. The

Applicant/accused has deep roots in the society. There is no
apprehension of applicant fleeing from justice.

9. The applicant undertakes he will fulfill all the condition as

may be imposed by this Hon’ble Court while admitting the
applicant to the bail.

10. That the applicant undertakes that he shall not commit any
act or omission, which is forbidden by any law.

PRAYER:
In view of the facts stated and submission made herein
above it is most respectfully prayed to this Hon'ble Court
that this Hon'ble Court may kindly be pleased to:

I. Admit the accused/applicant to bail, in the interest of

justice;
 II. Pass any other or further orders that this Hon'ble Court
may deem fit and proper in the facts and circumstance of
the case in favour of accused/applicant.

DELHI
DATED: 13th February, 2020

APPLICANT/ACCUSED NO.2

THROUGH

(PARVINDER CHAUHAN, MUKESH BHARDWAJ &

BIJENDRA KR. GAUTAM)
ADVOCATES
COUNSELS FOR THE APPLICANT/ACCUSED
2148, LGF, OUTRAM LANES,
MUKHARJEE NAGAR, DELHI-110009
PHONES: 27607072 (M) 9899205088
ALSO AT:

CH. NO. 9, CIVIL SUPPLY BUILDING,

TIS HAZARI COURTS,
DELHI-110054
PH.-011-23980405