BEFORE THE DISTRICT AND SESSIONS COURT AT BEGUSARAI
IN THE MATTER OF
STATE
Versus
ABHISHEK SINGH
FIR NUMBER: 5510/2020
UNDER SECTION: 302/326/420 OF IPC
POLICE STATION: MATIHANI, BEGUSARAI
ACCUSED UNDER CUSTODY SINCE 20TH MARCH, 2020
Application Under Section 437 Of Code Of Criminal Procedure Code On Behalf
Of The Accused
MOST RESPECTFULLY SUBMITTED AS UNDER:
1. That the present FIR has been registered under false and bogus
facts. The facts stated in the FIR are fabricated, concocted and
manipulated.
2. That the police have falsely implicated the applicant, the applicant is
the respectable citizen of the society and he has no criminal
antecedents.
3. That the applicant is having good antecedents, he belongs from a
good family, and there are no criminal cases pending against them.
4. 3. That the applicant/accused is a permanent resident of _____ and earning
livelihood by _____. The applicant has his old parents dependent upon him and
the applicant is the only bread earner for the family.
5. That the applicant is a permanent resident and there is no chance of
absconding from the course of justice.
6. That the applicant undertakes to present before the court or police
whenever required to.
7. That the applicant undertakes that he will not, directly or indirectly,
make any inducement, threat or any promise to any person
acquainted with the facts of the case so as to dissuade him to
disclose any such facts to the court or the police officer.
8. That the applicant further undertakes not to tamper with the
evidence or witness of the case in any manner.
9. That the applicant shall not leave India without the previous
permission of the court.
10. That by getting the applicant/accused arrested the applicant has
been deprived of his valuable fundamental right of liberty by abuse
of powers and process of law by the complainant. _____
11. That the applicant is willing to furnish surety and bail bonds to
the satisfaction of this learned court in case he is ordered to be
released on bail.
12. That the applicant is ready and willing to accept any other
condition the court or police officer willing to impose in relation with
the case.
PRAYER
It is therefore prayed that the court may order for the release of the applicant
in the order of the justice. And the other order which the court may deem fit
and proper in the facts and circumstances of the case may be also passed in
the favour of the applicant.
APPLICANT
THROUGH
COUNSEL
