BEFORE THE DISTRICT AND SESSIONS COURT,

AT BHIWANI (HARYANA)
CRM-M _________ OF 2022
MEMO OF PARTIES
SHRI ROHTASH MOR
S/O SHRI _____________
AGED _______YEARS
ADD- ______________
PETITIONER
VERSUS
STATE OF HARYANA
THROUGH POLICE STATION BHIWANI,
HARYANA
RESPONDENT NO. 1
VED PRAKASH (COMPLAINANT)
S/O SHRI JAGANNATH
II HATTA LOHAR BAZAR, BHIWANI CITY,
BHIWANI, HARYANA.
RESPONDENT NO. 2

BHIWANI
DATED
COUNSEL FOR THE PETITIONER
 BEFORE THE DISTRICT AND SESSIONS COURT,
AT BHIWANI (HARYANA)
CRM-M _________ OF 2022
IN THE MATTER OF

SHRI ROHTASH MOR

PETITIONER
V.
STATE OF HARYANA & ANR.
RESPONDENTS
INDEX

Sr. Particulars Annexure Pg. No.

No.
1 Memo of the Petition under
Section 438 of the Code of
Criminal Procedure, 1973 with
affidavit in support thereof.

2 A Copy of the subject FIR P/1

dated 31.12.2021

3 A Copy each of the certificates P/2

of registration of subject co- (Colly.)
operative societies, as issued by
the Government of India,
Ministry of Agriculture, New
Delhi.

4 Copies of the Orders dated P/3

22.07.2020, 24.09.2020 and (Colly.)
19.11.2020 passed by the
Government of India, Ministry
of Agriculture, New Delhi

5 A Copy of the Order dated P/4

03.08.2016 passed by the
Hon’ble Supreme Court of
India

6 A Copy of the Order dated P/5

 07.02.2018 passed by the
Hon’ble Supreme Court of
India

Petitioner

Date
Place
Counsel for the Petitioner
 BEFORE THE DISTRICT AND SESSIONS COURT,
AT BHIWANI (HARYANA)
CRM-M _________ OF 2022
IN THE MATTER OF

SHRI ROHTASH MOR

PETITIONER
V.
STATE OF HARYANA & ANR.
RESPONDENTS

FIRST APPLICATION UNDER SECTION 438 OF THE CODE OF

CRIMINAL PROCEDURE, 1973 FOR THE GRANT OF
ANTICIPATORY BAIL TO THE PETITIONER IN FIR NO. 288/ 2021
DATED 31.12.2021 REGISTERED BY POLICE STATION BHIWANI
CIVIL LINES, BHIWANI, HARYANA UNDER SECTION 406, 420, AND
506 OF THE INDIAN PENAL CODE, 1860 (IPC) AND SECTION 3 OF
THE HARYANA PROTECTION OF INTEREST OF THE DEPOSITORS
IN FINANCIAL ESTABLISHMENT ACT, 2013.

MOST RESPECTFULLY SHOWETH:-

1. That the Petitioner is an Indian inhabitant, having his permanent

residence at ________.

2. That the present Petition is being preferred by the Petitioner under

Section 438 of the Code of Criminal Procedure, 1973 (in short, “CrPC”),

praying for directions from this Hon'ble Court to allow the Petitioner to

be enlarged on bail in the event of his arrest in First Information Report

(FIR) No. 0288/ 2021 registered by PS: Bhiwani, Haryana (hereinafter,

 “subject FIR”) on 31.12.2021. Vide the subject FIR, the present

Petitioner has been implicated as one of the accused and allegations have

been made against him of committing offences punishable Section 406,

420, and 506 of the Indian Penal Code, 1860 (in short, “IPC”) and

Section 3 of the Haryana Protection of Interest of the Depositors in the

Financial Establishment Act, 2013.

True copy of the subject FIR No. 0288/ 2021 dated 31.12.2021 is

annexed herewith as ANNEXURE P/1.

3. It is submitted that this is the first anticipatory bail application of the

Petitioner. No other bail application in respect of the subject FIR No.

0288/2021 has been previously filed by the Petitioner before any Court of

law.

4. By way of background, it is stated that the subject FIR has come to be

filed at the behest of members/ account holders of three multi-state co-

operative societies, namely (i) Sahara Credit Co-operative Society Ltd.

(ii) Humara India Credit Co-operative Society Ltd. (iii) Saharayn

Universal Multipurpose Society Ltd. (collectively referred to as “subject

co-operative societies”, hereinafter). The subject co-operative societies

have been formed and registered under the provisions of Multi-state Co-

operative Societies Act, 2002.

5. From a perusal of the subject FIR, it appears that the Complainant, Shri

Ved Prakash (Respondent No. 2 herein) had originally addressed his

complaint to the Home Minister of the State of Haryana, wherein he had

expressed his anguish in respect of the delay in payment of account-

holders money by the subject co-operative societies.

6. Interestingly, without identifying any aggrieved/ victim party, the

Complainant has asserted that in the city of Bhiwani there are around

2000 account holders/ depositors in the Sahara India Company. The said

depositors have cumulatively deposited around 30 crores with Sahara

India. However, for the last few years, the said Company has stopped

returning the maturity amount along with accrued interest. Alleging

inaction on the part of officer-bearers of the said Company in disbursing

the maturity amount to the unidentified account holders/ depositors, the

Complainant has urged for the intervention of the of state machinery in

securing the refund of money belonging to the depositors. At this

juncture, it would be apposite to note that no information/ particulars qua

the aggrieved/ victim persons have been mentioned by the Complainant.

Further, the Complaint is principally directed against “Sahara India

Company” which does not have any juristic or legal existence.

7. From the contents of the subject FIR, it appears that acting upon the

information received from the Complainant, the subject FIR has been

lodged under Section 406, 420 and 506 of the IPC along with Section 3 of

the Haryana Protection of the Interest of the Depositors in Financial

Institution Act, 2013 on 31.12.2021.

8. In this connection, it is stated that Complainants herein had admittedly

invested their money in three co-operative societies namely “Sahara

Credit Cooperative Society Limited”, “Saharayan Universal Multipurpose

Society Limited” and “Hamara Credit Co-operative Society Limited”.

(Collectively referred to as “subject co-operative societies”, hereinafter).

The subject co-operative societies have been formed and registered under

the provisions of Multi-state Co-operative Societies Act, 2002.

Copy of Certificate of Registration of “Sahara Credit Cooperative Society

Limited”, “Saharayan Universal Multipurpose Society Limited” and

“Hamara Credit Co-operative Society Limited” are bearing registration

no. MSCS/CR/333/2010 dated 05.03.2010, MSCS/CR/935/2014 dated

21.01.2014 and MSCS/CR/594/2012 dated 30.07.2012 respectively as

issued by the Central Registrar/Joint Secretary to Government of India,

Ministry of Agriculture, New Delhi, is collectively annexed herewith and

marked as ANNEXURE P/2 (Colly).

9. Notably, the subject co-operative societies have neither denied their

liability nor committed the offence of cheating against the Complainants

or any other person. The Petitioner most respectfully submits that– had

there been any dishonest intention on part of the subject co-operative

societies, investors and account holders would have never deposited their

money in the schemes of the subject co-operative societies. Per contra,

the societies in the question have been successfully operating for the last

so many years to help their members/ depositors in achieving their

financial goals. Mere delay in refund of the money alone cannot be a

basis for invocation of the penal provisions under the IPC. The present

controversy is of civil nature and an unjustified attempt is being made by

persons with vested interests to provide it with a criminal colour.

10. It is stated that the maturity payment of account holders in subject co-

operative societies has been delayed on account of Orders dated

22.07.2020, 24.09.2020 and 19.11.2020 as passed by the Central

Registrar of Agriculture. It is notable that vide the said orders, the subject

societies were prohibited from taking any new deposits from their

existing members as well as barred from enrolling any new member.

Copies of the Order dated 22.07.2020, 24.09.2020 and 19.11.2020 are

annexed herewith as ANNEXURE P/3 (Colly).

11. Apart from the aforesaid action taken by the Central Registrar-Ministry of

Agriculture, the delay in disbursal of invested amount to the Complainant

and others has also occasioned on account of the following facts and

circumstances:-

(a) Sahara Credit Co-operative Society Limited had, with the

approval of its board, invested Rs.13,747.76 crores, in the equity
shares of M/s Ambey Valley Limited. The society has acquired
and holds about 40% equity shares of the said company - M/s
Ambey Valley Limited.

(b) Similarly, Hamara Credit Co-operative Society Limited had, with

the approval of its board, invested Rs.10,085 crores in the equity
shares and Rs. 170 crores in preferential shares of M/s Ambey
Valley Limited.

(c) M/s Ambey Valley Limited owns and operates a very Ultra-
Modern Hi-Tech Hill City, in the name and style - "Ambey
Valley" near Bombay, in District Pune. The project "Ambey
Valley’ has a very high potential revenue yield and its market
value is over One Lakh Crore and the societies have invested
their money in the said company for the better return to its
members.

(d) That the Ambey Valley Limited is a company of Sahara Group,

which was though not a party to SEBI Sahara Dispute but
Hon'ble Supreme Court has, vide its order dated 21.11.2013,
 restrained all Sahara Group of Companies from parting with their
any movable or immovable properties, until further orders.

(e) That the said order dated 21.11.2013 is still continuing, subject to
a slight modification made by Hon'ble Supreme Court, vide its
order dated 03.08.2016, providing that Sahara Group shall also be
entitled to sell their movable and immovable properties, subject
to condition that the entire sale consideration received by them is
to be deposited in SEBI Sahara Account and the list of properties
so sold and the consideration received against the same is filed in
the Hon'ble Supreme Court. The Copy of the order dated
03.08.2016 is annexed herewith and marked as ANNEXURE
P/4.

(f) That the Hon'ble Supreme Court was also pleased to direct sale of
Ambey Valley and for that purpose appointed official liquidator
to act in the supervision of the Hon'ble Company Judge, Bombay
High Court and issued various directions, vide its order dated
07.02.2018, inter-alia directing that since the court is ceased with
the matter, no other court in the country shall entertain any
litigation pertaining to Ambey Valley City. A copy of the order
dated 07.02.2018 is annexed herewith and marked as
ANNEXURE P/5.

12. It is stated that criminal proceedings must not be used as a means to

harass a party or to seek quick relief in civil disputes– as recently held by

the Hon’ble Supreme Court of India in the case of Mitesh Kumar Sha v.
 State of Karnataka (Civil Appeal No. 1285/2021). For the resolution of

the present dispute, the Multi-State Co-operative Societies Act, 2002 is

already in place. The said act is a special enactment passed with the

objective of administration of Co-operative Societies. Section 84 of the

Act of 2002- provides for dispute resolution of disputes between societies

and their members and bars the applicability of any other law. It is stated

that the complainants have filed the Complaint to create undue pressure

on the Petitioner and as such, there is no truth or substance in the

allegations in the complaint on the basis of which, the present FIR has

been lodged. The present dispute is based on a civil liability which is

being given a criminal colour. The fact of causing pressure is specifically

mentioned in the FIR itself.

13. As stated hereinbefore, due to pending litigation and other unavoidable

circumstances beyond the control of the subject co-operative societies,

there has been a delay in payment of the due and payable amount to the

account-holders of the subject co-operative societies. Nevertheless, the

subject societies herein have neither denied their liability nor are trying to

run away from their obligations towards their account holders/ members.

As such, there is also no shred of substance in the proposition that the

said delay has been deliberate or intentional. The subject cooperative

societies have been diligently working to address the grievances of

 account-holders and in this connection; an online complaint grievance

settlement process has also been introduced.

14. The Petitioner also submits that under Section 38 (2) of the Act, the

general body of society is the ultimate decision-making authority. Section

41 talks about the Board of Directors and inter alia provides that subject

to provisions of the Act, the Board shall consist of such numbers of

directors as may be specified in the bye-laws. The Board is also

empowered to appoint a chief executive under Section 51 of the Act.

Further, the Act provides for the constitution of committees of the Board

under Section 53. No individual person is authorized to undertake or is

involved in any policy decision by the cooperative societies. Admittedly,

the Petitioner herein is not involved in any of the decision-making

processes of the subject societies in his individual capacity and has no

independent role to play in the delay caused in disbursal of the money

deposited by the account holders of the subject co-operative societies. It

is accordingly submitted that none of the offences invoked in the subject

FIR has been committed by the Petitioner. In fact, a bare perusal of the

complaint would reveal that no case is made out against the Petitioner and

the name of the Petitioner has been dragged in the subject FIR on the

mere ipse dixit of the Complainants herein.

15. In light of the above, the Petitioner most respectfully submits that the

present case is fit for the exercise of powers granted to this Hon’ble Court

under Section 438 of the CrPC. Accordingly, this Hon’ble Court may

kindly be pleased to allow the relief of pre-arrest bail to the present

Petitioner in connection with the subject FIR, on the following grounds

amongst others– which are in alternative and without prejudice to each

other:-

GROUNDS

A. Because, there is no recovery is to be effected from the Petitioner and as

such no custodial interrogation is required. This is a fit case for exercising

the jurisdiction for the grant of the anticipatory bail to the Petitioner, who

is ready to abide by any of the conditions so imposed by the Hon’ble

Court while granting the relief of anticipatory bail to the Petitioner.

B. Because, the Petitioner is ready and willing to cooperate in the

investigation as and when he is required by the Investigation Officer.

C. Because, Petitioner’s name in the subject FIR has been included without

any rhyme or reason. As stated supra, the Petitioner has no role to play in

the day-to-day affairs of the subject societies and delay in disbursal of the

maturity amount to the account holders has not been caused on account of
 any fault on the part of the Petitioner. Hence, the filing of the subject FIR

against the Petitioner is nothing but an abuse of the process of law.

D. Because, the subject societies have been executing their work legally and

efficiently as per provisions of the Multi-State Co-operative Societies

Act, 2002 and the rules made thereunder; and the investments made by

the subject societies are also in terms of Section 64 of Act of 2002 and

respective by-laws of the societies.

E. Because, the contents, as alleged in the subject FIR, even if taken at their

face value, do not disclose the commission of an offence under Section

406, 420 or 506 by the Petitioner.

F. Because, a careful reading of Section 405 would show that the ingredients

of a criminal breach of trust are: i) A person should have been entrusted

with property, or entrusted with dominion over property; ii) That person

should dishonestly misappropriate or convert to their own use that

property, or dishonestly use or dispose of that property or willfully suffer

any other person to do so; and iii) That such misappropriation,

conversion, use or disposal should be in violation of any direction of law

prescribing the mode in which such trust is to be discharged, or of any

legal contract which the person has made, touching the discharge of such

trust.
 In view of the above, it would become evidently clear that Entrustment is

an essential ingredient of the offence. A person who dishonestly

misappropriates property entrusted to them contrary to the terms of an

obligation imposed is liable for a criminal breach of trust and is punished

under Section 406 of the Penal Code. Per contra, in the present case, there

is nothing on record to even remotely suggest that the said ingredients

under section 405/406 have been satisfied.

G. Because, the contents of the FIR also do not prima facie attract the

ingredients of the offence of cheating as provided in section 420 IPC. In

this connection, it would be relevant to note that the Hon’ble Supreme

Court of India has made following observations in Rajesh Bajaj vs. State

of NCT of Delhi (1999) 3 SCC 259 qua Section 420 of the IPC;

"A bare reading of the definition of cheating would suggest that

there are two elements thereof, namely, deception and dishonest
intention to do or omit to do something. In order to bring a case
within the first part of Section 415, it is essential, in the first place,
that the person, who delivers the property should have been
deceived before he makes the delivery; and in the second place that
he should have been induced to do so fraudulently or dishonestly.
Where property is fraudulently or dishonestly obtained, Section
415 would bring the said act within the ambit of cheating provided
the property is to be obtained by deception."

The above ingredients are completely absent in the present case as the

complainants have neither been induced nor deceived by the Petitioner in

a fraudulent manner to make deposits with the subject societies.

H. Because, the Hon'ble Supreme Court in V.Y.Jose and another vs. State of

Gujarat and Anr. (2009)3 SCC 78 has held that– for the purpose of

constituting an offence of cheating, the complainant is required to show

that the accused had fraudulently or dishonest intention at the time of

making a promise or representation. Even in a case where allegations are

made in regard to failure on the part of the accused to keep his promise,

in the absence of culpable intention at the time of making the initial

promise being absent, no offence under section 420 of the Penal Code can

be said to have been made out.

I. Because, for ironing out the disputes arising out of delayed payment in

some cases, the subject co-operative societies have made a Grievance

Settlement Portal for settlement of grievances of their members/

investors, customers, agents etc. The said members have already

approached the office of the societies along with requisite documents

seeking repayment nor made any grievance on the Grievance Settlement

Portal.

J. Because, in respect of the invaluable right to liberty, the Constitution

Bench of the Hon’ble Allahabad High Court in Amarawati and Anr. Vs.

State of U.P. 2005 CriLJ 755 held as follows:

“34. It may be mentioned that a person's reputation and esteem in

society is a valuable asset, just as in civil law it is an established
principle that goodwill of a firm is an intangible asset. In practice,
 if a person applies for bail he has to surrender in Court, and
normally the bail application is put up for hearing after a few days
and in the meantime he has to go to jail. Even if he is subsequently
granted bail or is acquitted, his reputation is irreparably tarnished
in society. Often false and frivolous FIRs arc filed yet the innocent
person has to go to jail, and this greatly damages his reputation in
society. For instance, as observed by the Supreme Court in Karis
Raj v. State of Punjab, 2000 Cr LJ 2993 (vide Para 5), a tendency
has developed of roping in all relations of the in-laws of the
deceased wife in matters of dowry death. All these factors must be
kept in mind by the Court particularly after the promulgation of the
Constitution, which has embodied the right to liberty as a valuable
fundamental right in Article 21 of the Constitution of India.”

K. Because, the Hon’ble Supreme Court in Arnab Manoranjan Goswami

vs. State of Maharashtra and Others 2020 SCC OnLine SC 964 has

observed that the writ of liberty runs through the fabric of the

Constitution. The Supreme Court held as follows:-

“74 XXX…. “Courts must be alive to the need to safeguard the

public interest in ensuring that DTU enforcement of criminal law is
not obstructed. The fair investigation of crime is an aid to it.
Equally it is the duty of the courts across the spectrum. -The
district judiciary, the High Court and the Supreme Court-to ensure
that the criminal law does not become a weapon for the selective
harassment of citizens. Courts should be alive to both ends of the
spectrum – the need to ensure the proper enforcement of criminal
law on the one hand and the need, on the other hand, of ensuring
that the law does not become a ruse for targeted harassment.
Liberty across human errors is as teeniest as teenagers can be.
Liberty survives by the vigilance of our citizens, on the cacophony
of the media and in the dusty corridors of courts alive to the rule of
(and not by) law. Yet, much too often, liberty is a casualty when
one of these components is found wanting.”
L. Because, the allegations in the subject FIR are general and non-specific in

nature without any supporting evidence. Even otherwise, there is no

specific allegation made against the Petitioner. That considering the

quantum of punishment the Petitioner may be released on anticipatory

bail.

M. Because, Section 3 of the Haryana Protection of Interest of Depositors in

Financial Establishment Act, 2013 has been wrongly invoked in the

present case against the Petitioner, inasmuch as he is neither a promoter,

nor partner, director, manager or any other person or an employee

responsible for the management of or conducting of the business or

affairs of a financial establishment under the said Act.

N. Because, an attempt has been made by the Complainants and the

concerned Police Station in the present case to cloak an otherwise civil

dispute with a criminal nature despite the conspicuous absence of

ingredients necessary to constitute a criminal offence.

O. Because, it is a trite law that criminal proceedings are not a shortcut for

other remedies. As stated supra, the subject FIR relates to civil liabilities

of the subject societies and as such, the dispute herein is purely civil in

nature. Section 84 of the Act of 2002, which is a special act- provides for

dispute resolution of disputes between societies and its members and bars
 the applicability of any other law. Further, the societies have already put a

grievance settlement portal for the settlement of grievances of its

members/ investors, customers, agents etc. Hence, the lodging of subject

FIR cannot be legally countenanced.

P. Because, the Hon’ble Supreme Court and several other High Court have

time and again reiterated in unison that arrest of an individual on the basis

of mere allegations has the potential to destroy the reputation of the said

individual. Therefore, it is necessary to apply great care and

circumspection while dealing with arrest at a pre-conviction stage

Q. Because, the law relating to the grant of anticipatory bail has been

succinctly laid down by the Supreme Court in Siddharam Satlingappa

Mhetre v. State of Maharashtra, (2011) 1 SCC 694, wherein it has been

observed as under:

"85. It is a matter of common knowledge that a large number of

undertrials are languishing in jail for a long time even for
allegedly committing very minor offences. This is because Section
438 CrPC has not been allowed its full play. The Constitution
Bench in Sibbia case [(1980) 2 SCC 565 : 1980 SCC (Cri) 465]
clearly mentioned that Section 438 CrPC is extraordinary because
it was incorporated in the Code of Criminal Procedure, 1973 and
before that other provisions for grant of bail were Sections 437 and
439 CrPC. It is not extraordinary in the sense that it should be
invoked only in exceptional or rare cases. Some Courts of smaller
strength have erroneously observed that Section 438 CrPC should
be invoked only in exceptional or rare cases. Those orders are
 contrary to the law laid down by the judgment of the Constitution
Bench in Sibbia case [(1980) 2 SCC 565 : 1980 SCC (Cri) 465] .
88. The gravity of charge and the exact role of the accused must be
properly comprehended. Before arrest, the arresting officer must
record the valid reasons which have led to the arrest of the
accused in the case diary. In exceptional cases the reasons could
be recorded immediately after the arrest, so that while dealing with
the bail application, the remarks and observations of the arresting
officer can also be properly evaluated by the court.
89. It is imperative for the courts to carefully and with meticulous
precision evaluate the facts of the case. The discretion must be
exercised on the basis of the available material and the facts of the
particular case. In cases where the court is of the considered view
that the accused has joined investigation and he is fully
cooperating with the investigating agency and is not likely to
abscond, in that event, custodial interrogation should be avoided.

90. A great ignominy, humiliation and disgrace is attached to the

arrest. Arrest leads to many serious consequences not only for the
accused but for the entire family and at times for the entire
community. Most people do not make any distinction between
arrest at a pre-conviction stage or post-conviction stage.
(emphasis supplied)

R. Because, in the case of Mitesh Kumar J. Sha v. State of Karnataka 2021

SCC Online SC 976, the Supreme Court has recently held that a criminal

color should not be given to an otherwise civil dispute merely to take

advantage of a relatively quick relief granted in a criminal case in contrast

to a civil dispute. Such an exercise is nothing but an abuse of the process

of law which must be discouraged in its entirety.

S. Because, in the case of Ravindranatha Bajpe v. Mangalore Special

Economic Zone Ltd. and Ors. Etc., 2021 SCC Online SC 806, the
 Hon’ble Supreme Court has recently held that the chairman, directors,

and other key managerial personnel of a company cannot be

automatically held vicariously liable for the offences committed by a

company unless specific allegations and averments against them are made

with respect to their individual role.

T. Because, the entire case of the prosecution rests on documentary

evidence. That the Petitioner herein does not have any control or any

interference in the day-to-day affairs of the society. The Petitioner is not

authorized to undertake any policy decision related to the society and the

arrest of the Petitioner in the present circumstances would amount to pre-

trial conviction, hence the Petitioner should be granted anticipatory bail

as laid down by Hon'ble Supreme Court in the case of State of Rajasthan

V/s Balchand reported in (1977)4 SCC 308.

U. That the Petitioner is the permanent resident of district ______ and has

deep roots in the society. He has no criminal antecedents and there is also

no fear that the Petitioner will abscond during the course of the

investigation and pending criminal case.

V. That the Petitioner is ready and willing to abide by any condition that

may be imposed by this Hon’ble Court while releasing the Petitioner on

anticipatory bail.
 16. That the Petitioner has sufficient sureties to furnish before this Hon’ble

Court to entitle him to be enlarged on anticipatory bail.

17. That the Petitioner seeks the kind permission of this Hon’ble Court to

raise such other or further grounds as may be available to him at the time

of hearing of the present petition.

That an affidavit is filed herewith in support of the Petition

PRAYER

It is therefore, respectfully prayed that;

(i) The present petition may kindly be allowed and the Petitioner may

kindly be granted anticipatory bail in case FIR No. 0288 of 2021

dated 31.12.2021 registered at PS: Bhiwani, Haryana.

(ii) It is further prayed that during the pendency of the present petition

in this Hon’ble Court, the arrest of the petitioner may kindly be

stayed.

(iii) Any other order or direction which this Hon’ble Court may deem

fit and proper under the facts and circumstances of the case may

also be passed in favour of the petitioner.

. Petitioner

Date
Place
Counsel for the Petitioner
 BEFORE THE DISTRICT AND SESSIONS COURT,
AT BHIWANI (HARYANA)
SHRI ROHTASH MOR
PETITIONER
V.
STATE OF HARYANA & ANR.
RESPONDENTS
LIST OF DOCUMENTS

Sr. Particulars Annexure Pg. No.

No.
1 A Copy of the subject FIR P/1
dated 31.12.2021

2 A Copy each of the certificates P/2

of registration of the Sahara (Colly.)
Credit Cooperative Society,
Star Multipurpose Society and
Saharayan Multipurpose
Society, as issued by the
Government of India, Ministry
of Agriculture, New Delhi.

3 Copies of the Order dated P/3

22.07.2020, 24.09.2020 and (Colly.)
19.11.2020 issued by the
Government of India, Ministry
of Agriculture, New Delhi

5 A Copy of the Order dated P/4

03.08.2016 passed by the
Hon’ble Supreme Court of
India

6 A Copy of the Order dated P/5

07.02.2018 passed by the
Hon’ble Supreme Court of
India
 Petitioner

Date
Place
Counsel for the Petitioner
 BEFORE THE DISTRICT AND SESSIONS COURT,
AT BHIWANI (HARYANA)
CRM________________OF 2022

SHRI ROHTASH MOR

PETITIONER
V.
STATE OF HARYANA & ANR.
RESPONDENTS
AFFIDAVIT OF
I, Shri Rohtash Mor, aged ___ Years, S/o Sh.
_____________________, Address-
________________.

****
I, the above named deponent, do hereby solemnly affirm and declare as
under:

1. That the deponent is the Petitioner in the subject Anticipatory Bail

Application and is conversant with the facts of the case and, as such, is
competent to depose with respect thereto.

2. That statement of facts contained in the accompanying Application for

the grant of anticipatory bail under Section 438 of the Code of Criminal
Procedure are true and correct to my knowledge and legal submissions
made therein are true on the information received and believed to be
correct.

3. That the annexure filed with the petition is true copy of the respective
original.

PLACE:
DATE:
DEPONENT
VERIFICATION:
Verified at _______________ on this day of December 2022, that the
contents of my aforesaid affidavit are true and correct to my knowledge. No part
of the same is false and nothing has been kept concealed therein.

PLACE:
DATE:
DEPONENT