1st Bail Application under section 437 of Cr.P.C.
In The Court Of Illaqua Magistrate/ Duty Magistrate,
Narnaul
State Of Haryana
Versus
1. Satender
2. Rajkumar
Both sons of Sultan Singh, residents of village Kalba, PS Nangal
Chaudhary, District Mahendargarh, Haryana.
3. Sumit S/o Ranjeet, resident of village Kalba, PS Nangal Chaudhary,
District Mahendargarh, Haryana.
…Accused/Petitioners
FIR No. 248
Dated – 16/09/2020
Under Section- 148/149/332/353/379B/506 IPC
P.S.- Nangla Chaudhary
1st Bail Application under section 437 of Cr.P.C. on behalf of Satender,
Rajkumar and Sumit accused.
Hon’ble Sir,
The petitioner submits as under:
1. That a false case has been got registered by the police against the
accused/petitioner after concocting a false story, whereas the petitioners
are innocent and are confined in jail since long in the present case.
2. That the perusal of the facts collected so far in the course of investigation
reveals that no offence u/s 379B is made out because if the case of the
prosecution is taken on the face of it even then there is no intention on
the part of the accused to snatch any article like vehicle or mobile phone
or any other article and prima facie section 379B is not made out and this
Hon’ble Court has got the jurisdiction to entertain the present bail
application.
3. That in this case the complainant party is the aggressor. The accused
petitioner Satender had deployed the JCB machine for leveling the ground
situated near the main road and the complainant party who claim
themselves to be the officers of forest department by chance and all of a
sudden they started grappling with the driver of the JCB machine and
thereafter, with accused Satender and they further tried to take him away
with them by putting forcibly in their vehicle then the farmers who were
worng in the nearby fields rushed to the spot in order to rescue Satender
Singh and in this process when the complainant employees were trying to
run away they might have sustained some injuries and the petitioners had
not caused any injury to the complainant party.
4. That the complaint party being government officials by taking
disadvantage of their post, got registered a false case against the
accused/petitioner and the police did not conduct the fair investigation.
5. That the accused/petitioners are not required for the purpose of
investigation and no useful purpose would be served by keeping the
petitioner behind the bars.
6. That the petitioners have deep roots in the society and therefore, there is
no apprehension of absconding of the petitioners.
7. That petitioner is ready to give sound surety and furnish the bond as per
the orders of the Hon’ble court.
8. That the petitioner is a law abiding person and therefore, there is no
apprehension of tempering with the prosecution witnesses or its
incriminating articles by the petitioner.
9. That the petitioners shall appear before the Hon’ble Court as and when
ordered by the court.
10.That the trial and the final decision of the case shall take considerable
long time and no useful purpose would be served by keeping the
petitioners behind the bars.
11.That the petitioners shall abide by all the terms and conditions to be
imposed by the hon’ble court in the event of release of petitioner on bail.
Therefore, it is submitted that the present
application for bail may kindly be allowed and petitioners may please be
released on bail.
Date:
Submitted by:
1. Satender
2. Rajkumar
both sons of Sultan Singh,
residents of village Kalba,
PS Nangal Chaudhary,
District Mahendargarh, Haryana.
3. Sumit S/o Ranjeet,
resident of village
Kalba, PS Nangal
Chaudhary, District
Mahendargarh,
Haryana.
Through counsel
