(Petitioner in Custody)

In
The Court of Chief Judicial Magistrate
Bhagalpur
Kotwali (Tilkamanjhi) Police Station Case No.422/2021
385, 387 of Indian Penal Code.
State of Bihar
Versus
Durga Yadav & Others ----------- Accused
The humble petition for bail
filed on behalf of the accused
petitioner namely Indradeo
Yadav, Aged about 30 years, S/O
Late Jagdish Yadav, R/O Village:
Uksi, P.S: Karande, District:
Shekhpura, Most Respectfully
1. That the prosecution story in brief is that the
informant namely Banti Yadav S/O Late Abhay Kumar
Yadav, R/O Gautam Niwas, Nawabbag Colony, P.S:
Tilkamanjhi, District: Bhagalpur has given a written
statement before the S.H.O Tilkamanjhi, P.S, alleging
therein that he received a call on his mobile no.
7529579941 at 03.56 Minute and 04.02 Minute from the
mobile number 9144970657. It is alleged by the
informant that the Caller told him that I Pintu Rana is
speaking. He told informant that I belong from MCC
Group. He again told him do you think that you are a
big leader of BJP. It is again alleged by the informant
that Pintu Rana told him none of your bodyguards will
work as and when my group of MCC will go there. Pintu
Rana told informant to give two carores rupees within
 eight otherwise he will shoot him at his house. The
informant writes in his written statement that this
recording has already been sent to SSP Madam and it is
also provided to S.H.O Tilkamanjhi. The informant
requested from to S.H.O Tilkamanjhi make an
investigation of the fact and to take an appropriate
stern legal action against the concerned group. And for
this act of kindness, he will remain grateful to S.H.O
Tilkamanjhi. On the basis of the written report, FIR
was registered and the investigation was taken up by
the police.
2. That the petitioner has not filed any application for
bail earlier before your honour. The petitioner has not
filed any application for Regular/Anticipatory bail
earlier either before the learned court of District &
Sessions Judge, Bhagalpur or before the Hon’ble High
Court, Patna.
3. That the petitioner is quite innocent and he has been
falsely implicated in this case.
4. That it was way back to twenty five years ago when
Durga Yadav was happened to be the friend of Indradeo
Yadav but now Indradeo Yadav is nowhere related with
Durga Yadav. But both belong to the same village Uksi,
P.S: Karande, District: Shekhpura.
5. That the Sim card belongs to Rekha Devi. Indradeo Yadav
has nothing to do with Rekha Devi.
6. That Indradeo Yadav neither knows Rekha Devi nor has he
ever met her.
7. That Mobile Number of Indradeo Yadav is 8809266549.
This mobile is in police custody. The petitioner has
been arrested by the police only on the basis of mere
conjecture and surmises. The police have not gathered
 any such evidence which co-relates the involvement of
the petitioner in this case. The petitioner’s arrest is
only on the basis of his being co-villager of Durga
Yadav.
8. That Indradeo Yadav is a cultivator. He has got no
criminal antecedent whatsoever.
9. That the petitioner has been arrested by the police and
forwarded to judicial custody on 08.07.2021.
10. That the petitioner is ready to submit sound
sureties as per the direction of your honour.
11. That the petitioner is a man of ample means having
no chance of his absconding or tempering with the
evidence.
It is therefore prayed that your
honour would be graciously be pleased
to enlarge the petitioner on bail on
any term or terms as your honour
thinks just and proper. And for this
the petitioner shall ever pray.
Petitioner

Through

Advocate