IN THE HON'BLE COURT OF DISTRICT SESSIONS JUDGE, MANSA
State
Versus
Mandeep singh aged about 31 years s/o Jatinder pal
Singh R/o Ward no 2 Near Gurudwara Sahib Budhlada,
Tehsil and District Mansa. now in judicial custody at
District Jail Mansa.
Aadhaar no-: 6080-0852-2058
Applicants/Accusd
FIR No. 107 Dated 03.06.2024 U/S
304,201,511 of I.P.C, 27,29,61,85
N.D.P.S ACT of Police Station City
Budhlada, District Mansa.
Bail Application U/S 439 of
Cr.P.C. for grant of regular bail
to the accused/applicants.
Respected Sir,
It is most respectfully submitted as under:
1.That this is the secound bail application of the
applicants/accused under section 439 of Cr.P.C.
2.That the appicant /accused is entitled to the
concession of bail, inter-alia, on the following
grounds: -
A.That the applicant/accused is an innocent
person and he has been falsely
implicated in the above noted case. The
applicant/ accused have no way concern with the
alleged occurrence. The applicant/ accused have
a good character and dosn't have such bad
record in the society ever before.
B.That the complainant got lodged the above noted
case with some ulterior motive.
C.That the police Falsely implicated applicant in
this case as it is pertains to mention that the
applicant and other person admitted him in the
hospital beaing a human and he is known person
to the applicant but surprisely police falsely
implicated in the present case reason batter
known to him.
3.That the applicant/accused are absolutely innocent
persons and they have been falsely involved in the in
and fact the present case by the police
applicants/accused have not committed any offence as
alleged by the police.
4. That the complainant got lodged the above noted case
with some ulterior motive.
5.That the applicants are absolutely law abiding and
peace loving citizen of India and is totally innocent
persons till today they never engaged in any criminal
whatsoever kind, applicants activity any committed
the alleged offence alleged by complainant.
6.That there is no direct evidence against the
applicants/accused and the other evidence has no
legal value in the eyes of law as it is very much
weak peace of evidence.
7.That there is unexplained delay in the registration
of the case. The complainant cooked up a false story
utilizing this long time to implicate innocent
persons in the above said false case.
8.That the applicants are in custody and the conclusion
of the trial will take a considerable time so no use
full purpose will be served by keeping the innocent
applicants behind the bars.
9.That the applicants are permanent resident of above.
given address and they have sufficient moveable and
immovable property, so there is no question of
runaway of the applicants.
10. That the applicants are ready to furnish the
sureties as desire by the Hon'ble Court or by the
Trail court.
11. That the applicants will not jump over the bail and
unhdertake to appear on each and every date of the
caste.
12. That the appliacants undertake to abide by all the
conditions as and when imposed by this Hon’ble Court.
It is, therefore respectfully prayed that in the
light and circumstances of the case the Hon’ble
Court be kind enough to order to release the
applicants/accused on bail till final decision
ofthe case in the interest of justice.
Dated:- Submitted by:-
Mandeep singh aged about 31
years s/o Jatinder pal Singh
R/o Ward no 2 Near Gurudwara
Sahib Budhlada, Tehsil and
District Mansa. now in
judicial custody at District
Jail Mansa.
Applicants/Accused
Through Councel