IN THE COURT OF JUDICIAL MAGISTRATE, JAIPUR

Criminal Miscellaneous Application No.2341 /2024

In the Matter of

State of Rajasthan……………………………………….Complainant

V/s

Shubhendu s/o Suresh, age 30 years …………………..……..Respondent

R/O 408, Galaxy Apartments,

Raja Park, Jaipur - 302004

FIR No. 118 /2023

Dated: 11/11/2023

Under section: 306 IPC

Police station: Puliya No.1,

Jawahar Nagar, Jaipur

Sir,

It is most respectfully submitted as under-:

1. That the applicant was arrested by the Police on date 11/11/2023 for an alleged offence and he
has been in detention since then.

2. That the applicant is innocent as he was loving and caring husband who always saved the life
of his Loving wife Sarita.
3. That the FIR has been registered under false and bogus facts, the facts stated in FIR are
fabricated and manipulated.

4. That the police have falsely implicated the applicant, and the applicant is the respectable
citizen of the society and he had no past criminal records.

5. That the accused was induced/threatened to make involuntary statement by the Police.

6. That the applicant is not required in any kind of investigation or any custodial interrogation,
no recovery can be made out at the instance of applicant.

7. That the police have completed their investigation and charge sheet has already been
submitted which does not prosecute the Applicant.

8. That the applicant is having good antecedents, he belongs from a good family and there is no
criminal cases pending against him.

9. That the applicant is a permanent resident and there is no chance of absconding from the court
of justice and the applicant is ready to fill bail bonds if ordered by the Court.

10. That the applicant undertakes to be present before the court or police whenever required.

11. That the applicant further undertakes not to tamper with the evidence or witness of the case
in any manner.

12. That the applicant is ready and willing to accept any other condition the court or police
officer willing to impose in relation to the case.

13. That the applicant is traumatized due to sudden suicide committed by his wife and he has
also the responsibility to take care his child i.e. Anup as he is the only one in his family to take
care of anup.

14. That the cause of death was determined to be due to injuries sustained from high-impact collision
with the ground, consistent with a fall from a considerable height of (approx. 40 ft.). Hence, it is also
proved that the applicant has no role in sarita’s death.
 PRAYER

It is therefore prayed that the court may order for the release of the applicant in the order of
justice and the other order which the court may deem fit and proper in the facts and
circumstances of the case may be also passes in the favor of applicant which deems fit and
proper in the interest of justice.

Place:

Date: APPLICANT

Through

Advocate Council