IN THE COURT OF THE HON’BLE PRINCIPAL DISTRICT JUDGE

AT Malkajgiri
Crl.M.P No. of 2022
IN
Crime No. 450 of 2019
(P.S.Kushaiguda, Rachakonda)
Between:-
Pathlavath Arjun Naik, S/o P.Tilak Naik,
Aged about 23 years, Occ: Auto Driver,
R/o EC Nagar, Cherlapally,
Kapra Mandal of Medchal Dist
…Petitioner/Accused
AND
The State of Telangana State
Through P.S. Kushaiguda, Rachakonda
Rep by its Addl. Public Prosecutor
…Respondent/Complainant

BAIL PETITION FILED U/S 439 Cr.P.C ON BEHALF OF PEITITONER/

ACCUSED

Offence: U/s: 366 IPC & Sec 12 of POCSO Act - 2012

Date of Remand: 13-07-2019

Police: Kushaiguda

May it please your Honour,

1. That the present petition is the First bail petition filed seeking
enlargement of bail in connection with the above crime on the file of P.S
Kushaiguda, Rachakonda registered for the offence under section U/s:
366 IPC & Sec 12 of POCSO Act – 2012.

2. The case of the prosecution is that on 13-07-2019 at 09:30 hrs, near

Kushaiguda received a petition from Smt.Gangalam Balamani, stated
that on 10-07-2019, at about 18:00hours,her daughter Kum. Gangalam
Shivani,age 14 years, who is a student went out along with her younger
brother,and after a few minutes, son returned to house and disclosed her
that one person namely Arjun,Auto Driver took away her daughter on
his bike,immediately they searched surrounding areas, but her daughter
was not traced out,she stated that previously also the same person
kidnapped her daughter, upon which lodged a complaint at Police
Station,as a result registered a case in Cr.no.898/2018, he was
remanded and later he was released on bail and he again took her
daughter forcibly kidnapped her. As such the P.S. Kushaiguda registered
a case in Crime No: 450 of 2019, U/s: 366 IPC & Sec 12 of POCSO Act
– 2012. That the police brought him to PS and was taken into custody
and produced before The Hon’ble Court, Malkajgiri on 13-07-2019.

Facts of the Case:

1. It is submitted that the Petitioner /Accused’s house is far away

from victim’s house. It is false that the Petitioner /Accused kidnapped
the victim, where as he is an auto Driver who goes to his work early
morning and reaches home late at night.

2. It is submitted that the petitioner was falsely implicated in the

case as he is well disciplined man and residing with old aged mother and
wife and his family. He is no way concerned with the allegations
mentioned in the complaint. He further submits that they have lodged a
complaint with false allegations may be due to grudge or any other
intentions.

3. It is pertinent to mention over here that the statements of the

witnesses is already recorded and the entire investigation is completed
charge sheet filed as the question of tampering the evidence or
influencing the prosecution witnesses does not arise.

4. The Petitioner/Accused herein is a permanent resident as such there

is no scope of leaving away anywhere. That Accused being falsely
implicated in this case and is ready to prove his innocence at the time of
trail. The custody of the petitioner/Accused is not required for any other
purpose.

5. The Petitioner/Accused is in jail since long, and he is the only

bread earner and should look after his old aged parents with ailments
and family, no one to take care of them. The petitioner is ready to prove
his innocence at the time of trial and ready to appear before court as and
when directed by this Hon’ble Court.

6. The Petitioner is ready to abide by any condition imposed by this

Hon’ble Court and further ready to furnish sureties to the satisfaction of
this Hon’ble Court.
7. It is therefore prayed that this Hon’ble Court may be pleased to
enlarge the accused on bail in connection with the above sited crime and
pass such other orders as this Hon’ble Court may think deem fit and
proper in the circumstance of the case and in the interest of justice.

Place: Malkajgiri

Date: 28-10-2022 Counsel for Petitioner

 IN THE COURT OF THE HON’BLE
PRINCIPAL DISTRICT JUDGE

AT Malkajgiri
Crl.M.P No. of 2022

IN

Crime No. 450 of 2019

(P.S.Kushaiguda, Rachakonda)

Between:-
Pathlavath Arjun Naik,

…Petitioner/Accused

AND

The State of Telangana State

Through P.S. Kushaiguda,
Rachakonda

…Respondent/Complainant

BAIL PETITION FILED U/S 439

Cr.P.C ON BEHALF OF
PEITITONER/ ACCUSED

Filed on: 28-10-2022

Filed by: - Complainant/Accused

ADDRESS FOR SERVICE:

G.JALAJA

ADVOCATE/Legal Aid

8008628595