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IN THE COURT OF THE HON’BLE SPECIAL JUDICIAL

FIRST CLASS MAGISTRATE FOR EXCISE CASES


AT: HYDERABAD

Crl. M.PNo. of 2019

In
CC. No. 340 of 2017

(P.S Bahadurpura, Hyderabad.)

BETWEEN:

Mohammed Aleem S/o, Mohammed Saleem


Aged About: 35 years, Occ: Driver,
R/o: 19-4-340/54/49/13/6,
Kishanbagh, Bahadurpura,
Hyderabad – 500064
Aadhaar No : 674927922893

……..Petitioner /
Accused

AND

The State of Telangana through


P.S. Bahadurpura, Hyderabad.

…….Respondent /
Complainant

PETITION FILED U/s 437 of Cr.P.C.


Offence u/s 304 A of IPC
Date of Arrest: 22-03-2019
Date of remand: 22-03-2019

May it please your Honour;

1. That the petitioner is shown as Accused in the above case.

2. It is submitted that, the petitioner herein is falsely implicated in


the above said case by the respondent police and petitioner was arrested
and produced before this Hon’ble court and this Hon’ble court remanded
the petitioner to judicial custody on 22-03-2019 since then he is
languished in jail

3. It is submitted that, the petitioner belongs to a very poor family


and he is a daily wage Labour and he has to look after his aged old
parents who are suffering from old aged diseases and they need medical
assistance time to time.
::2::

Also petitioner is suffering with white jaundice and he is taking herbal


medicines. It is submitted that the petitioner is in judicial custody since
4 days

4. That the petitioner is the permanent resident of Hyderabad and


there is no apprehension of petitioner absconding of tampering with the
prosecution evidence.

5. That the police has completed the investigation and examined all
the important witnesses and mere to file chagesheet in the above case
and the petitioner is no more required to the police for the purpose of
investigation.

6. It is submitted that, the petitioner is ready to abide by any


conditions imposed by this Hon’ble court also ready to furnish sufficient
sureties to the satisfaction of this Hon’ble court.

That this is the first bail petition filed, and no such petition is
pending before any other court of law.

It is therefore, prayed that this Honorable Court may be pleased


enlarge the petitioner/accused on bail, in the interest of justice.

Place: Hyderabad
Dated: 25 -03-2019

Counsel for the petitioner


IN THE COURT OF THE HON’BLE
SPECIAL JUDICIAL FIRST CLASS
MAGISTRATE FOR EXCISE CASES
AT: HYDERABAD

Crl. M.PNo. of 2019


In
Crime. No. 340 of 2017

(P.S Bahadurpura, Hyderabad.)

BETWEEN:

Mohammed Aleem

………Petitioner/
Accused

AND

The State of Telangana through


P.S. Bahadurpura, Hyderabad.

…….Respondent /
Complainant

PETITION FILED U/s.437 of Cr.P.C.


Offence u/s 304 A of IPC

Filed On: 25-03-2019

Filed by:

Counsel for Petitioner / Accused

G. RAMA KRISHNA CHARY (18640)


Advocate
Hyderabad

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