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IN THE COURT OF DISTRICT AND SESSION JUDGE ,

SAHARSA. 

     A.B.A. NO.:-......./2022 

Ref: - arising out of Saharsa Sadar P.S. Case No.-

420/2011 dated 05/09/2011 instituted under sections

147,148,149,323,307,384,427,448,504,506 of I.P.C., sec

27of Arms Act and 3/4 Explosive Act and is pending in

the court of Learned A.C.J.M.- IV, Saharsa. 

IN THE MATTER OF: 

1. Bhanu Yadav alias Bano Yadav  aged about

years 

S/O- Late Budhan Yadav

Resident of Mohalla – Gokul Chowk,Ward No.-18,

Saharsa, P.S. – Sadar Saharsa, Dist.-Saharsa.

...........Petitioners 

Vs. 

THE STATE OF BIHAR .............O.P. 

The humble anticipatory

bail application on
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behalf of above named

petitioner under section

438 of Cr.P.C. (as

amended) 

MOST RESPECTFULLY SHEWETH: 

1. That this is application for grant of anticipatory bail

to the petitioner who apprehends his arrest in connection

with Saharsa Sadar P.S. Case no.- 420/2011 under

sections 147,148,149,323,307,384,427,448,504,506 of

I.P.C., sec 27of Arms Act and 3/4 Explosive Act and is

pending in the court of Learned A.C.J.M.- IV, Saharsa.

2. That the petitioners have not preferred such an

application for regular bail or anticipatory bail earlier

either before this court or The Hon'ble Patna High

Court. 

3. That the petitioners have no criminal antecedents.  

4. That the prosecution story, in brief that the informant

Rajan Kumar Singh is alleging that on 05/09/2011 about

05:35 P.M., he along with his friends was at the office

of Anand Mohan and in the meantime Golu Yadav with

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his hundred supporters reached there and threaten then

he was asked why have they threaten then they have

caught Md. Mahmood Ali Kaisar and he has escaped

from and Golu Yadav have fired and through bomb in

the office hata come and also alleged that Golu Yadav

has demanded extortion from the information.On the

basic of written statement Saharsa P.S. case no

420/2011 had been registered under sections

147,148,149,323,307,384,427,448,504,506 of I.P.C., sec

27 of Arms Act and 3/4 Explosive Act and is pending in

the court of Learned A.C.J.M.- IV, Saharsa.

Certified copy of F.I.R is

annexed with this

petition.  

5. That the petitioner is quite innocent and has

committed no offence much less the offence alleged in

the F.I.R.  

6. That the petitioner has been falsely implicated in

this case due to grudge, dirty party politics which is

prevailing in side of village. 

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7. That the F.I.R. is malicious, false, fabricated,

concocted and has no leg to stand in the eye of law. 

8. That there is no specific allegation against the

petitioner, but they are general and omnibus. 

9. That the alleged sections of the F.I.R. are bailable

except sections 307,384 of IPC and sec. 27 Arms Act

and 3 /4 Explosive Act and is not applicable against the

petitioners and are super addition and ornamental and

add only with an intention to make the offence non-

bailable and graver and no alleged offence are made

out against the petitioners. 

10. That there is no any injury has been sustained to

the person of the informant and other by this petitioner

and no any articles had been recovered from the

possession of the petitioner. The prosecution version as

alleged in the written statement of the informant, there

is no any intention for attempt to murder and extortion

by the petitioner. Hence intention is not clearly

mentioned in the written statement. So the sec. 307 and

384 IPC had not attracted in the present case. 

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11. That the petitioner is law abiding, God Fearing and

having fullest faith in the rule of Law. 

12. That the petitioner shall suffer irreparable loss and

injury to his goodwill, health and mental peace, if the

police arrest the petitioner in the false case filed against

him. 

13. That the petitioner is not a previous convict and

the petitioner is permanent resident of Saharsa at the

above noted address and is having his roots in society.

There is no chance of petitioner tempering the evidence

or threatening the witness or to flee/abscond from

justice, if released on anticipatory bail.  

14. That the petitioner is man of means having wealth

and home and are therefore not likely to abscond and

tempering or evading with the evidence if enlarge on

anticipatory bail. 

15. That the petitioner is ready to furnish sound

sureties to the full satisfaction of the court and willing

to abide by your Honour for his enlargement on

anticipatory bail. 
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16. That the application of anticipatory bail has made

bonafide and in the interest of justice. 

17. That there are other grounds also which will be

raised at the time of hearing of bail application by

your honour's permission. 

It is , therefore, prayed that your

honour may graciously be pleased to

grant anticipatory bail to the

petitioner  in Saharsa Sadar P.S. case

no. 420/2011 to the satisfaction of

Learned A.C.J.M.- IV,Saharsa. 

AND/OR 

Pass such order(s) as Your Honour

may deem fit and proper. 

And for this petitioner shall ever pray. 

Petitioner, 

Through advocate.  

  

 
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IN THE COURT OF DISTRICT AND SESSION JUDGE ,

SAHARSA. 

     A.B.A. NO.:-......./2022 

In the matter of:

Bhanu Yadav @ Bano Yadav Vs. The State of Bihar

AFFIDAVIT 

I, Bhanu Yadav alias Bano Yadav  aged about

years S/O- Late Budhan Yadav , resident of Mohalla-
Gokul Chowk Ward No.- 18, Saharsa, P.S.– Sadar,
Dist.– Saharsa do hereby and solemnly affirm and state
as follows: 
1. That I am the Petitioner and also well acquainted
with this facts and circumstances of the case. 
2. That I am competent to swear this affidavit. 
3. That I am gone through the contents of the bail
petition bearing above case no. and heard translate into
Hindi and have understood the same. 
4. That the statements made in the application are
true to the best of my knowledge and based on
information derived from the records of the case,
which I believe to be true. 
 
Deponent.