Drafting, Pleading and Conveyancing

424
Specimen No. III
HONBLE SESSIONS COURT
IN THE COURT OF AT

Cri. Misc. Application No./20

In C.R. No /20. registered with Police Station
under section 467, 468, 471, of I.P.C

Mr.
Age: Years,
Occupation: Accused /Applicant
RJAt:
V/s

1. State Of
2. Police Inspector, Opponents
Police Station,
At
First bail Application uade
section 439 of C:PC
The Applicant Imost respectfully submits as under:
(1) The Police station has registered the above mentioned case against thi
accused for the alleged offences punishable under section and
of the Indian Penal Code. The accused was arrested on date.
(2) It is submitted that this accused is not
guilty of any offence as alleged or
otherwise. The allegations made against the applicantaccused are talse, trnvou
vexatious and lack in the material substance.
(3) The accused is innocent and is a respectable member of the society. The actused
belongs to a very good and reputed family and there is no criminal case P
against him.
(4) That the applicant/accused is wrongly implicated due to enmity andfamily feud
(5) The applicant states that neither any recovery is to be effected fromthe applic
nor the applicant is in a prosecutionevidence.TN
position to tamper with the requirl
applicant undertakes to cooperate with the whenever he is
to do so. investigation at
parens
(6) The applicant states that he
is the only bread and his old
dependent on him. earner
placeandhence
(7) The applicant is a
permanent resident and is working at
there are no such chances of his absconding from the course of ju
 Chapter XV Draftingand Pleading under Criminal Law 425

(8) The applicant undertakes to present himself before the police/court as and when
directed. The applicant shall not leave India without the previous permission of
the court.
to accept any other conditions as may be imposed by the
(9) The applicant is willing
connection with the case.
court or the police in
he will be deprived of his fundamental right to
(10) If the applicant is not granted bail
liberty.
prays:
(11) The applicant therefore most humbly kindly be allowed and the accused may
bail may
i) That the application for
please be enlarged on bail. necessary proper in the interest of
ii) Pass any such other orders as deemed
justice.

Place
Advocate for Applicant/Accused
Date
Specimen No. IV
appeal]
accused who intends to present an
court convicting an
[Bail before the MAGISTRATE/SESSIONS COURTAT (PLACE)
HONBLE
IN THE |20_
Cri. Misc. P. No.

S.C. /C.C. No. of 20_

Petition/ Accused

Vs

Responden/Complainant

for grant
Pecition under section 389(3) CrPCconviction
of bailon

under:
t respectfully submits as offernce
states that this accused has been convicted of
The per ed
Indian Penal Code by the judgment and order dated