IN THE COURT OF THE HON’BLE XIV METROPOLITAIN MAGISTRATE CYBERABAD

AT: RAJENDRANAGAR
Crl.M.P...... /2023
in Crime of 20
Between:
Petitioner/Accused
AND
STATE .REP BY PS Rajendranagar Respondent/complainant

COUNTER FILED ON BEHALF OF RESPONDENT/COMPLAINANT

1. It is humbly submitted that the petitioner is accused in crime no. of 20 U/S IPC in PS
. and arrested and remanded judicial custody. It is humbly submitted that the petition for
bail filed by the petitioner is neither maintainable under law or on facts and the same is liable to be
dismissed in limini.
2. It is further humbly submit that this respondent denies all the adverse allegations contained in the
petition under reply and nothing contained therein should be deemed to have been admitted by this
respondent, unless done so specifically herein.

3. It is further submitted that the respondent craves leave of this Hon’ble court to read the RCD in this case
as part and parcel of this counter. In addition to the grounds mentioned in the Remand case Dairy, it is
further submitted that the petitioners is not entitled for grant to of bail on the following grounds.
a. As per the investigation done so far by the investigation agency, there is prima facie and reasonable
ground to believe that the accused had committed the offence.
b. The nature and gravity of the offence committed by the petitioner disentitles him for the relief of bail.
It is therefore prayed that this Hon’ble Court be pleased to dismiss the petition under reply as devoid
of merits, in the interests of justice.
c. The allegation against petitioners will attract greater punishment, severity of the punishment in the
event of convection also does not approve the enlarging the petitioner on bail. The danger of the
petitioners absconding or fleeing, if released on bail would make the situation rampant.
d. The previous character, behaviour, means, position and standing of the accused also goes against the
Petitioner/accused from being set free on bail.
e. The likelihood of the offence being repeated by the accused is also apprehended and hence the
petitioner/accused cannot be enlarged on bail.
f. There is also a reasonable apprehension of the witnesses being influenced by the accused if enlarged
on bail and also the accused may also tamper the investigation and hamper the investigation, there is
danger to justice being thwarted by grant of bail.
4. It is submitted that the granting bail to accused could lead to his trying to tamper with the prosecution
evidence by giving threat or inducement to the prosecution witnesses or even to abscond to delay the trial.
There was probability of his taking to the path of crime again, resulting in a rise in the crime graph in the
area.
5. It is submitted that the established fact that a crime though committed against an individual, in all cases it
does not retain an individual character. It, on occasions and in certain offences, accentuates and causes
harm to the society. The victim may be an individual, but in the ultimate eventuate, it is the society which
is the victim. A crime, as is understood, creates a dent in the law and order situation. In a civilized
society, a crime disturbs orderliness. It affects the peaceful life of the society. Hence the
petitioner/accused cannot be dealt with leniently.
Hence, it is therefore praying the Honourable Court be pleased to kindly dismiss the petition under
reply as devoid of merits, in the interest of justice.
ASST PUBLIC PROSECUTOR