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Application under Section 436 of CrPC for the grant of

Bail

BEFORE THE HON`BLE COURT OF SPECIAL EXECUTIVE


MAGISTRATE CHAWANI, KANPUR NAGAR

Bail Application No. of 2023

IN THE CASE OF:


NADIR NAFEES …PETITIONER

VERSUS

SHAHAB ANWAR … RESPONDENT

Date: 05.04.2023
PS – JAJMAU
Offence u/s 151 of CrPC

Application under Section 436 of CrPC for the grant of Bail

Respectfully Showeth:

1. That the applicant has been involved in a false and frivolous case by

Mr. Shahab Anwar by lodging a complaint with the SHO, PS Jajmau

on __________ . The applicant/accused has been called by the Police

of Jajmau PS subsequent to the above complaint.

2. That it is submitted that the allegations made against the

applicant/accused are false, frivolous and vexatious and lack in

material substance. The applicant belongs to a very reputed family in

his locality. The allegations are that the applicant/accused is

threatening to the Respondent in order to evict the Respondent from

the flats which were agreed to sell to the Respondent. However, the

registered owner of the said flats is the father of the Applicant namely

Mr. Sohail Nafees. Further, the Respondent has not paid the agreed

price of the said flats and when the father of the applicant went to the

Respondent for paying the required amount then the Respondent

himself made the threatening remarks to the family and took the

illegal possession on the said flats situated at Araji Number 680,

Gajjupurwa, Jajmau, Kanpur Nagar.


3. That the Applicant is a permanent resident of said address and

earning livelihood by _________________________________________. The

applicant has his old parents’ dependent upon him on whose name

the said flats are registered.

4. That the applicant is innocent and has been involved falsely owing to

have in Respondents` possession of the said flats. It is submitted that

the Respondent is an influential and high-handed person as his job is

to take illegal possession of the said flats.

5. That the Applicant is willing to furnish surety and bail bonds to the

satisfaction of this Hon`ble Court in case he is ordered to be released

on bail. The applicant is also willing to join the investigations and

bind himself by the terms and conditions laid down by the law or by

this Hon`ble Court. It is further submitted that the applicant is not at

all required for the investigations. However, if the applicant is

required for investigation, the applicant undertakes to be present as

and when required in accordance with the law.

6. That neither any recovery is to be affected from the applicant nor the

applicant is in position to temper with the prosecution evidence. The

applicant will associate with the investigation whenever required to

so.

PRAYER

IN THE PREMISES, IT IS MOST RESPECTFULLY PRAYED THAT THIS

HON’BLE COURT MAY KINDLY BE PLEASED TO:

(a) That the applicant may be ordered to be released on bail and this

application for bail may kindly be allowed;

(b) That till the decision of this application interim bail may be granted to the

applicant;
(c) Such other orders be also passed in favour of the applicant as deemed fit

and proper in the facts and circumstances of the case and in the interest of

justice.

AND FOR THIS ACT OF KINDNESS, THE APPLICANT, AS IN DUTY

BOUND, SHALL EVER PRAY

Applicant/Accused

Naadir Nafees s/o Mr. Naadir Nafees,


Aged ___ Years,
R/o 680/40, Gajju Purwa Jajmau,
PS Jajmau, Kanpur Nagar – 208010.

Through:
MOHIT SINGH
ADVOCATE FOR THE COMPLAINANT
CHAMBAR NO. 7, BESIDE ELECTION OFFICE,
KANPUR COURT
EMAIL: mohitsingh170895@gmail.com
MOB: 9455533129

Date: 05.04.2023
Place: Kanpur Nagar.
BEFORE THE HON`BLE COURT OF SPECIAL EXECUTIVE
MAGISTRATE CHAWANI, KANPUR NAGAR

Bail Application No. of 2023

IN THE CASE OF:


NADIR NAFEES …PETITIONER

VERSUS

SHAHAB ANWAR … RESPONDENT

AFFIDAVIT IN SUPPORT OF THE APPLICATION UNDER


SECTION 436 OF CrPC

I, Naadir Nafees s/o Mr. Sohail Nafees, aged about ___


years, resident of 680/40, Gajju Purwa Jajmau, PS
Jajmau, Kanpur Nagar - 208010 do hereby solemnly affirm
and declare as under:-

1. That I am applicant/accused in the above case, thoroughly


conversant with the facts and circumstances of the present
case and am competent to swear this affidavit.

2. That the facts contained in my accompanying application,


the contents of which have not been repeated herein for
the sake of brevity may be read as an integral part of this
affidavit and are correct to my knowledge.

DEPONENT
VERIFICATION:

I verify that the contents of this affidavit are true and correct to

my knowledge and information derived from the record of this

case. No part of it is false and nothing relevant has been

concealed therein. Verified at Kanpur Nagar on 05th day of

April, 2023.

DEPONENT
BEFORE THE HON`BLE COURT OF SPECIAL EXECUTIVE
MAGISTRATE CHAWANI, KANPUR NAGAR

Misc. Application of 2023

MEMO OF PARTIES
NAADIR NAFEES
S/O MR.________________,
R/O 680/40, GAJJU PURWA JAJMAU,
PS JAJMAU, KANPUR NAGAR - 208010
…APPLICANT/ ACCUSED

VERSUS

SHAHAB LARRI
(ADDRESS) ..ACCUSED

APPLICANT/ACCUSED

THROUGH
MOHIT SINGH
ADVOCATE FOR THE COMPLAINANT
CHAMBAR NO. 7, BESIDE ELECTION OFFICE,
KANPUR COURT
EMAIL: mohitsingh170895@gmail.com
MOB: 9455533129

Date: 05.04.2023
Place: Kanpur Nagar.

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