In the court of Ld.

District and sessions Judge, Balurghat, Dakshin

Dinajpur.

Cri.Mise Case No……………/2023

In the matter of a petition for anticipatory bail U/S 438 Cr.P.C in connection
with G.R. case No. 505/2023, arising out of Banshihari P.S. case No.
119/2023,dated – 19/05/2023, U/S 341/323/307/379/506/34 I.P.C. Which is now
pending before the Ld. A.C.J.M. Gangarampur at Buniadpur in G.R.O. file.

AND

In the matter of :- 1. Jayanta Roy, aged about 29 years.

S/O- Swapan Roy
2. Gobinda Mahato, aged about 26 years.
S/O- Srimanta Mahato.
3. Sukumar Das, aged about 49 years.
S/O- Late Naresh Das,
All of Vill- Panjaripara(Patharghata),
P.O-Sudarshannagar,P.S.- Banshihari,
Dist- Dakshin Dinajpur.
…………………………. Petitioner

V/S.

The State …………………………………………..O.P.

The above named petitioner is beg most respectfully states as follows :-

That one defacto complainant Saikat Ali lodged a written complaint

against your accused Petitioners. On that basis the present case was
started. Your accused Petitioners are named in the F.I.R. They apprehend
that they may be arrested by the police of Banshihari P.S. and so that
your accused Petitioners prefers this anticipatory bail petition before your
honours court on the following grounds:-

P.T.O.
 Page – 2

GROUNDS

1. For that your accused Petitioner is the Bona Fide Indian citizen having
his own dwelling house at the above given address.
2. For that the I.O. of this case yet not submitted the charge sheet against
your accused petitioners.
3. That there is a counter case of this present case registered on the same
date vide G.R Case No- 506/2023, Banshihari P.S case no-117/2023,
Date-19/05/2023,U/S- 341/323/354/307/506/34 of I.P.C. where two of
the relatives of the complainant are alleged by petitioner no. 1 and so that
they could create pressure on him to withdraw the case, the complainant
made this false present complain.
4. For that your accused petitioner no. 3 is a businessman and accused
petitioner 1 and 2 work in his company and they all are peace loving and
responsible citizens. On the other hand the complainant and the accused
persons of the counter case are known as most dangerous and antisocial
people.
5. For that your accused Petitioners are totally innocent and they have
falsely been implicated in this case, and the allegations leveled against
them are totally false and fabricated.
6. For that there is no chance of absconding or disappearing of your accused
petitioners if the accused petitioners are granted bail.
7. For that there is no bail petition U/S -438 and 439 Cr.P.C is pending or
filed or rejected before the Hon’ble High Court, or in any court in favour
of your accused Petitioners.

Under the above circumstances your

honour would be pleased to admit this petition,
call for the L.C.R. and C.D. and hear the party and
allow the anticipatory bail application or pass such
other order or orders as your honour may deem fit
and proper.

And for this act of kindness your accused Petitioners are in duty bound shall
ever pray.