IN THE HON’BLE COURT OF MS.

NITI PHUTELA, SPECIAL JUDGE

(POCSO), DISTRICT NORTH EAST, KARKARDOOMA COURT,
DELHI

IN THE MATTER OF:

STATE …COMPLAINANT

Versus

BURAHNUDDIN …ACCUSED

F.I.R. No :- 0417/23

P.S.:- JAFRABAD
U/S 376/506 of I.P.C.
And U/S 4 of POCSO
ACT
J.C.D- 14.08.2023

BAIL APPLICATION ON BEHALF OF ACCUSED BHRAHNUDDIN

S/O RIYAZUDDIN U\S 439 OF THE CrPC

The above applicant most respectfully submit as follow:-

1. Applicant is a peace loving and abiding citizen of India and his aged
about 39 years having wife alongwith four minor children.
2. That applicant is innocent and he has been falsely implicated in this
case.
3. The applicant has been running Bakery shop namely ‘Zam Zam
Bakery” for about more than __ years at C-218/6, Gali No. 8, Chauhan
Banger, Delhi , North East Delhi -110053. Applicant has engaged Raja
@ M. Istiyak S/O Mustak Ahmad R/O Bijnor Uttar-Pradesh India for
his assistance at shop as daily wager.
4. That victim “V” used to visit his shop to purchase bakery items along
with her sister who is the daughter of her Mausi / Aunt and might have
developed intimacy with his servant Raja in his absent. Raja used to
give her bakery items without charging anything and the said fact came
to knowledge of applicant on 14.08.2023 when the victim visit his shop.
5. That the applicant scolded both Raja as well as victim for their relation
and bakery item taking without paying anything. After which the
applicant asked Raja not to come to his shop.
6. That Raja as well as the victim V got annoyed with the applicant
behavior and conspired to falsely implicate the Applicant and after
which the Victim came to the shop after few days and called the
applicant upstairs in the room on which firstly the applicant denied but
then the applicant went upstairs and in utter shock when the applicant
reached inside the room Victim started shouting and ran down stairs.
7. That after this the victim after reaching her house made a call to the
police station by her Mausi’s Daughter and logged the present F.I.R. by
laving false allegations against Applicant on 14.08.2023.
8. That the applicant was arrested by the police on 14-08-2023 i.e., the
same day of the complaint, and since then, Applicant has been in
Judicial Custody.
9. That the applicant has not committed any crime against the victim and
has been falsely implicated in the crime.
10.That The applicant has a family to take care of them and due to false
allegation the applicant have not seen their family. The applicant is the
permanent resident of Delhi and has deep route in his society.
The applicant is ready to abide any terms imposed by this court.

PRAYER

A. It is therefore prayed In light of the above submissions that he be

granted regular bail by this Hon’ble Court.
B. Any other or further relief in the favour of accused deemed fit and
proper in facts and circumstances of the present case may also be passed in
the interest of justice.

Applicant /Accused
Burahunddin
THROUGH

NAGHMA SARFARAZ
(ADVOCATE)
139 B Block Tis Hazari Court Delhi
DELHI

DATED: 04.09.2023
IN THE HON’BLE COURT OF MS. NITI PHUTELA, SPECIAL JUDGE (POCSO),
DISTRICT NORTH EAST, KARKARDOOMA COURT, DELHI

IN THE MATTER OF:

STATE …COMPLAINANT

Versus

BURAHNUDDIN …ACCUSED

AFFIDAVIT
I, FAYAZUDDIN S/O RIZUDDIN, R/O QAZIZADGAAN CHANDPUR BIJNOR,
UTTAR PARDESH-246725, do hereby solemnly affirm and declare as under:

1. That the accused Burahnuddin is my brother in relation and I am signing this

affidavit in capacity of parokar thus I am aware of the facts of the case and
competent to swear the present affidavit.
2. That the accompanying application for bail filed under Section 439 of the CrPC
has been drafted and filed by the advocate upon my instructions. The same has
has been read over to me in my vernacular and has been understood by be and I
attest the same to be true to the best of my knowledge.

DEPONENT

VERIFICATION :-
Verified at Delhi on this ___ Day of July, 2023 that the contents of the above
affidavit are correct and true to my knowledge, no part of it is false and nothing
material has been concealed there from.
DEPONENT