IN THE COURT OF SESSIONS JUDGE PUNE AT

PUNE

Criminal Bail Application No.

Islam Alim Parkar

Age- Occ: ) …Applicants

Versus
The State of Maharashtra
(Through Ranjangaon MIDC Police Station) … Respondent
(First Bail Application)
In the matter of Section 439 of
Criminal Procedure Code

AND

In connection with C.R. No. 511 of

2023 registered with Ranjangaon
MIDC Police Station u/s. 427 of IPC
& S. 136 of Indian Electricity Act

THE HUMBLE APPLICATION OF THE APPLICANTS

ABOVE NAMED

MOST RESPECTFULLY SHEWETH:

1) Particulars of the case :

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 A) Name of police station : Rajangaon MIDC Police
Station
B) Crime No. : 511/23

C) Name of the informant : Luckychand Morsingh Rathod

D) Date of incident : 20/8/23

E) Date of FIR : 21/8/23

F) Offence U/S. : U/S 427 of IPC & 134 of

Indian Electricity Act
G) Date of Arrest :

H) Date of MCR :

2) The Prosecution Story in Brief Is as Under –

As per case of prosecution complainant luckychand morsingh rathod

filed a complaint on 21/8/23 around 11 pm at night the accused
persons committed the crime under U/S 427 of IPC & 134 of Indian
Electricity Act. On around 11 pm at night accused name Islam Alim
Parkar and other has Robbed the Copper Wire and by spilling oil on
the road ran away. The accused robbed the copper wire from the
farmer’s field named Anose Bandal & Deshmukh around 20000rs
copper wire material .

2.that the accused has filed first bail application before this Hon’ble
court. Investigation is completed and hence, this bail application
which is maintainable.

3. the present accused has not commited any offence and therefore the
accused approaches this Hon’ble for grant bail on the following
amongst the other grounds there to:

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 GROUNDS OF BAIL:

a. That, the applicant no. 1 was arrested on 21/8/2023.

b. On / /2023 granted MCR as they are not required for further

investigation. Onwards till today accused is in MCR.

c. That, the applicants states that, they are totally innocent having

nothing to do with the alleged offence.

d. That, the applicant is an innocent person and they have falsely

implicated in this case. The applicant has not committed any

offence as alleged in the F.I.R. by the informant.

e. That, nothing has to be recovered from the hands of the

applicants, under these facts and circumstances no purpose will

be served by keeping behind the bar applicants.

f. That, the statements of all the witnesses recorded. Hence further

custodial interrogation is not necessary with the police.

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g. That, the applicants will abide by any of the condition imposed

at the time of release on bail.

h. That, there is no directly or indirectly and circumstantial and

specific allegation and evidence against this present applicants

that he committed alleged offence.

i. That, the applicants have their permanent place of residence at

the address stated in the cause title of this application and by

way of present criminal application.

j. That, the applicants accused had never been convicted for any

offence punishable for fine or imprisonment. There is no any

criminal background or history of the applicants.

k. That, the applicants accused would remain present before the

investigating officer whenever they would be called for by

investigating officer for investigation purpose and they will

abide all the conditions imposed by the Hon’ble Court.

l. That, the applicants will not abscond during trial and they will

not leave India without prior permission of this court.

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m. That, the applicants are reputed person and if they have been

keep behind bars it will harm the social reputation of the

applicants.

n. That, the applicants are ready and willing to furnish the surety

for the like amount as this Hon’ble Court may be deem fit.

o. Thus on these and other similar grounds those would be argued

at the time of final hearing this application.

p. Considering allegations in the FIR the applicants are not

required for any sort of discovery or recovery.

q. The applicants will not misuse the liberty, if they enlarged on

regular bail.

r. The applicants will co-operate the police machinery.

s. The applicants will not tamper any witness in evidence, in

respect of the crime in question.

t. The applicants craves leave to add, alter or amend any of the

foregoing grounds as and when found necessary with the

permission of this Hon’ble Court.

u. The applicants states that, this is first bail application and they

have not filed any other application, revision and / or petition

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 either in this Hon’ble Court or in any Court with regard to the

same subject matter.

3) The applicants therefore prays that :

a) The application kindly may be allowed.

b) The applicants kindly may be enlarged on bail in C.R. No.

511/2023 registered with Ranjangaon Police Station on such

terms and conditions as this Court deems fit and proper.

c) The applicants craves to leave, to add, alter any of the forgoing

grounds of bail or contents of the application.

d) Any other order in the interest of justice kindly may be passed.

AND FOR THIS ACT OF KINDNESS AND

JUSTICE, THE APPLICANTS AS IN DUTY BOUND SHALL
EVER PRAY.
Pune
Date : /10/2023 Advocate for Applicants