MEMORANDUM OF CRIMINAL ORIGINAL PETITION

(Under section 439 of CrPC)

IN THE HIGH COURT OF JUDICATURE, CHENNAI

Crl.O.P.No. of 2024
In
Crl.O.P.No. 513 of 2024
In
Crime No. 181/2022
(On the file of the respondent)

M.Sabari (M/21 yrs)

S/o.Muthumani
No.3/54, Ramasami Devar Compound,
Kottai Medu,Kamuthi,
Ramanathapuram-623604
... Petitioner / Accused No.3
vs
State, Rep. by
The Inspector of Police,
Thirumuruganpoondi Police Station,
Crime No.181/2022.
…Respondent/Complaint

PETITION FOR BAIL

It is most respectfully submitted as follows;

1. That, the above Respondent/Complainant has registered a case on

14.03.2022 in Crime No. 181/2022 for alleged offences U/s.394,397of
IPC and the Petitioner/Accused was arrested and remanded into
judicial custody on .

2. The prosecution case is that on 13.03.2022 while the defacto

complainant was on his way to home the petitioner/accused No.3
along with other two accused assaulted the defacto complainant and
threatened him and took his phone and while the defacto complainant
tried to escape the petitioner/accused No.3 also caused blood injury.
Hence the FIR was registered in Crime No.181/2022 on 14.03.2022.

3. The petitioner/accused is no way connected with the said alleged

offences and he has not committed any offence as alleged by the
prosecution and he has been falsely implicated in the above said
criminal case and he is in Jail for more than days.

4. It is submitted that the petitioner is law abiding citizen and he is

hailing with permanent residence in the above said address and he
will not abscond and ready to cooperate with the investigation and he
is ready to furnish substantial sureties for his due appearance.

5. It is submitted that if he is released on bail, he will not meddle with

investigation nor persuade or threat the witnesses.

6. It is respectfully submitted that the earlier bail petition was filed

before this Hon’ble Court in Crl.O.P.No.513 of 2024, which was
dismissed on 05.02.2024. In the Said FIR case has been filed which
has been numbered as S.C.No.220/2024 and the same is pending
before the Hon’ble Principal District Court, Tiruppur. No other Petition
has been filed for seeking Bail before this Hon’ble court or any other
Court and this is the 2nd bail application before this Hon’ble court.

Therefore it is humbly prayed that this Hon’ble Court may

graciously be pleased to grant Bail to the Petitioner/Accused No.3 in
Crime No. 181 of 2024 pending on the file of the Respondent Police
and thus render Justice.

Dated at Chennai, this is the 26th day of March, 2024

COUNSEL FOR PETITIONER

1. The bail is satisfaction to The Hon'ble Judicial Magistrate Court,

Avinashi

2. The petitioner is confined in Prison

3. This is the 2nd Bail Application filed before this Hon'ble Court.

4. No other similar Petition is pending before any other court.

 IN THE HIGH COURT OF
JUDICATURE, CHENNAI
Crl.O.P.No. of 2024
In
Crl.O.P.No. 513 of 2023
In
Crime No. 181/2022
(On the file of the respondent)

M.Sabari (M/21yrs)
S.o.Muthumani
…Petitioner/ Accused No.3
-VS-
State rep by its,
The Inspector of Police,
Thirumuruganpoondi Police
Station,
Tiruppur District
Crime No. 181/2022
…Respondent/Complainant

PETITION FOR BAIL

K.MADHUMITHA [7610/21]
J.SHAHITH AHAMED [4522/2021]
COUNSEL FOR PETITIONER