IN THE HIGH COURT OF STATES OF PUNJAB AND HARYANA AT

CHANDIGARH

CRM.M. /2022

Karan Kumar, aged 24 years son of Sh. Joginder Pal, a Resident of Village
Bohra, P.S Garshankar, District Hoshiarpur
……..Applicant

Versus
State of Punjab

………. Respondent
 The first petition under Section 439 of the Code of Criminal
Procedure, 1973 for grant of the concession Bail pending trial in
F.I.R. No. 63 dated 01.05.2019 u/s 302, 341, 145, 148 of I.P.C.
registered at PS Garshankar.

RESPECTFULLY SHOWETH:

1. That the petitioner law-abiding citizen of India and has been falsely
implied in the above-said F.I.R. The true translation of F.I.R. has been
annexed as Annexure P-1 for ready reference.
2. That no specific injury was inflicted by the petitioner. According to
M.L.R., the leading injury inflicted was done by co-accused Baljit Singh,
not the petitioner. The copy of M.L.R. has been annexed as ANNEXURE
P-2 for ready reference.
3. That the investigation is complete, the challan has been presented, and
nothing was discovered by the petitioner.
4. That the trial in the said matter will likely take a long time, and the
petitioner has been confined in custody for two years. The copy of the
challan has been annexed as Annexure P-5.
5. That accused surrendered himself to the custody of the Police on
02.09.2019.
6. That the Ld. The additional session judge has erred in dismissing the
regular application vide order dated 22.07.2020 as there is no specific
injury attributed to having been inflicted by the petitioner; this was a case
of false implication. The copy dated 22.07.2020 is annexed herewith as
Annexure P-6 for ready reference.
7. That the petitioner undertakes to abide by all the terms and conditions this
Hon’ble Court deems fit to impose while granting the concession of
regular bail.
8. That there is no apprehension of the petitioner misusing the concession of
bail and fleeing from justice. The petitioner undertakes not to make any
inducement or threat to any person acquainted with the present case.
9. That The petitioner has not filed any such or similar petition either in the
Hon’ble Sessions Court, this Hon’ble court, or the Supreme Court of
India.
10. That no such or similar petition for bail is pending before the Ld. Court of
Session at Hoshiarpur to the knowledge of counsel.
 11. That the petitioner is not accused in any other F.I.R. to the knowledge of
the Counsel.
12. That no such or similar petition has been filed by the petitioner either in
this Hon’ble Court or before the Hon’ble Supreme Court of India to the
knowledge of counsel.

It is, therefore, most respectfully prayed that this petition may be allowed, and
the petition may be granted the concession of bail pending trial F.I.R. no. 63
dated 01.05.2019 u/s 302, 341, 148, 149 IPC registered at Grahshanker, district
Hoshiarpur in the interest of Justice.