IN THE COURT OF THE HON’BLE XVI ADDL DISTRICT JUDGE

AT Malkajgiri
Crl.M.P No. of 2021
IN
Crime No. 497 of 2021
(P.S.Malkajgiri, Rachakonda)
Between:-
Bhupathi Venkatesh
H.No.3-5-24/K/91,
HB Colony, Moula Ali, Malkajgiri,
Hyderabad, Telangana …Petitioner/Accused
AND
The State of Telangana State
Through P.S. Malkajgiri, 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: 420,336,328 r/w 511 IPC

Date of Remand: 07-08-2021

Police: Malkajgiri

May it please your Honour,

1. That the present petition is the Second bail petition filed seeking
enlargement of bail in connection with the above crime on the file of P.S
Malkajgiri, Rachakonda registered for the offence under section
420,336,328 r/w 511 IPC

2. The case of the prosecution is that on 06-08-2021 at 15:30 hrs, near

Malkajgiri received a information from one person B. Govind Singh,
Drugs Inspector, Malkajgiri (Sales) stated that one person namely
Bhupathi Venkatesh,who is a store incharge is selling drug injections
illegally at Mediplus Pharmacy, Near Raghavendra Theater, Malkajgiri X
road at higher rates without sale bills and prescriptions and tablets to
the same needy customers besides his routine medical business and he
is earning huge benefits and causing hurt by means of poison to
common public. As such the P.S. Malkajgiri registered a case in Crime
No: 420,336,328 r/w 511 IPC That the police brought him to PS and
produced the Petitioner/Accused was taken into custody and produced
before XVII Metropolitan Magistrate, Malkajgiri on 07-08-2021.

3. It is submitted that the petitioner was falsely implicated in the case as

he is just an employee (store in-charge) for Mediplus and no way
concerned with the allegations mentioned in the complaint. He further
submits that he strictly follows the Medical rules and never sold any
medicines without prescription or sale bills.

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

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

5. 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.

6. The Petitioner/Accused is the only bread earner and should look after
his wife, infant daughter and old aged parents with ailments and 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.

7. 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.

8. 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: 26-08-2021 Counsel for Petitioner

 IN THE COURT OF THE HON’BLE
XVI ADDL DISTIRCT JUDGE:

AT Malkajgiri

Crl.M.P.No. Of 2021
IN
Crime No.497 of 2021
(P.S.Malkajgiri, Rachakonda)

Between:-
Bhupathi Venkatesh

…Petitioner/Accused

AND

The State of Telangana State

Through P.S. Malkajgiri,
Rachakonda
…Respondent/Complainant

BAIL PETITION FILED U/S 439

OF Cr.P.C ON BEHALF OF
PETITIONER/ACCUSED
OFFENCE U/S 420,336,328 r/w
511 IPC

Filed on: 26-08-2021

Filed by: -
Complainant/Accused

ADDRESS FOR SERVICE:

G.JALAJA

G.ANITHA

ADVOCATES

8008628595