IN THE COURT OF ILLAQUA MAGISTRATE, GURUGRAM

Bail Application No. ___ of 2023

IN THE MATTER OF:

Pankaj aged 34 years, S/o Babu Lal, R/o H.No. 229, Mundi (80),
Rewari, Haryana-123411 ….Applicant/accused
Versus
State of Haryana ……Respondent

INDEX
S.no Particulars Page No.
.
01 First Application for Bail under Sec 437
Cr.P.C after putting up the main case file

02 Affidavit in support of Bail application

03 ID Proof

04 Vakalatnama

Dated:
Gurugram

Applicant/ Accused
Pankaj

Through Counsel
Gunjan Bhardwaj
Advocate
 IN THE COURT OF ILLAQUA MAGISTRATE, GURUGRAM
Bail Application No. ___ of 2023

IN THE MATTER OF:

Pankaj aged 34 years, S/o Babu Lal, R/o H.No. 229, Mundi (80),
Rewari, Haryana-123411 … Applicant/
Accused
V/S
State of Haryana … Respondent

FIR No.159 /2023

Dated 14/03/2023
U/S- 354-A, 420,
506 of IPC
P.S.-Sec-10A, Ggm

FIRST APPLICATION FOR BAIL UNDER SECTION 437 CR.P.C.

AFTERR PUTTING UP THE MAIN CASE FILE

Hon’ble Sir,

The applicant/accused most respectfully submits as under:-

1. That the accused/applicant has been falsely implicated in

the above noted case though he has committed no offence

whatsoever by the police. The contents of the FIR are

totally false, frivolous, fabricated and concocted.

2. That no such occurrence whatsoever had taken place and

no role of the applicant/accused was attributed in the

present case FIR.

3. That the applicant/accused is not previous convicted in any

other offence and the applicant/accused belongs to a very

respectable family.

4. That nothing has been recovered or to be recovered from

the possession of the applicant/ accused.

5. That no fruitful purpose would be served upon, it is also

pertinent to mention here that the said offences (Sec 354-

A, 420, 506 of IPC) is a non-bailable offence provided

under IPC.

6. It is pertinent to mention here that in above-said case, the

date of registration of the said FIR is 14.03.2023 and the

Date of incident is not mentioned.

7. That the contents of the said FIR is totally false and

fabricated and self cooked by the respondent/ complainant ,

there is not a single ring of truth of the above said FIR.

8. That the true facts of this case are totally different, it is

pertinent to mention here that the complainant was having

love affair with the accused and during the same affair she

borrowed Rs. 2,50,000/- (Rupees Two lakhs and Fifty

thousand only) for her livelihood from the accused, and

when accused was in dire need of this money, he requested

the complainant to return this money back, after hearing

 this, the complainant got so frustrated and angry, and filled

this false and fabricated case against accused.

9. That it is also pertinent to mention here that complainant

was also pressurized accused to get married to her, and

repeatedly forced accused to divorce his wife. Also,

complainant threatening accused if he did not do so, she

would file false case against him.

10. That if the Hon’ble court is pleased to grant bail, the

applicant/accused shall abide by all the terms and

conditions imposed by this Hon’ble Court.

11. That the applicant/accused is ready to furnish bail bond

alongwith surety bonds to the entire satisfaction of this

Hon’ble court.

12. That the accused undertakes that He will appear on each

and every date of hearing.

PRAYER

It is therefore, most respectfully prayed that the applicant/ accused

may kindly be granted bail till the final disposal of the case, in the

interest of justice.

Date:
Gurugram

Applicant/ accused
 Pankaj aged 34 years, S/o Babu
Lal, R/o H.No. 229, Mundi (80),
Rewari, Haryana-123411

Through Counsel
Gunjan Bhardwaj
Advocate, Gurugram

IN THE COURT OF ILLAQUA MAGISTRATE, GURUGRAM

Bail Application No. ___ of 2023

IN THE MATTER OF:

Pankaj Versus State of Haryana

FIRST APPLICATION FOR BAIL UNDER SECTION 437 CR.P.C.

AFFIDAVIT

I, Babu Lal S/o Ramsawroop R/o Mundi (80), Rewari, Haryana-

123411, do hereby solemnly affirm and declare as under:

1. That the deponent is the applicant/accused in the above said

mentioned case, as such well versed with the facts of the case.

2. That this is the first bail application on behalf of the

applicant/accused.

3. That no other bail application of the applicant/accused is

pending in any other court in India, with regard to the present
matter.

4. That no other bail application of the applicant/accused has ever

been decided by any Hon’ble High Court or Hon’ble Supreme
Court.
 Deponent
Verification;
It is verified on this ____ day of ______, 2023 at Gurugram that the
contents of the above affidavit are true and correct to the best of my
knowledge and belief and nothing material has been concealed there
from.
Deponent