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Bail Application

The bail application has been filed by Rajan Batra and Neeraj Batra under Section 437 of the CrPC, seeking regular bail in a case related to the Negotiable Instrument Act, 1881, where they are accused of non-payment for textile products. Both applicants are currently in police custody, have no prior criminal records, and cite health issues as reasons for their absence during court proceedings. They have pledged to comply with court conditions and not tamper with evidence if granted bail.

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0% found this document useful (0 votes)
226 views12 pages

Bail Application

The bail application has been filed by Rajan Batra and Neeraj Batra under Section 437 of the CrPC, seeking regular bail in a case related to the Negotiable Instrument Act, 1881, where they are accused of non-payment for textile products. Both applicants are currently in police custody, have no prior criminal records, and cite health issues as reasons for their absence during court proceedings. They have pledged to comply with court conditions and not tamper with evidence if granted bail.

Uploaded by

rahuladhana0077
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd

IN THE COURT LEARNED METROPOLITAN MAGISTRATE, SOUTH

EAST SAKET DELHI

CC No. 7101/2022

IN THE MATTER OF

Hukumchand Fabrics Private Limited. …. Complainant

Vs.

M/s Bee K Bee Prints Private Limited and Ors. …. Accused

BAIL APPLICATION

RAJAN BATRA …APPLICANT

VERSUS
STATE …RESPONDENT

APPLICATION UNDER SECTION 437 CRPC SEEKING GRANT OF


REGULAR BAIL IN THE CAPTIONED MATTER ON BEHALF OF THE
APPLICANT

MOST RESPECTFULL SHOWETH:

1. That the present bail application has been filed by the above

named Applicant u/s 437 of CrPC seeking grant of regular bail in

the captioned matter filed under Section 138 of the Negotiable

Instrument Act, 1881 by the Complainant. It is pertinent to

mention that the applicant is currently in Police custody.


2. It is pertinent to mention here that the above mentioned
Applicant is resident of Delhi and has no criminal antecedents
and comes from a well-known family in Delhi.

3. It is submitted that the subject matter of the present case is that

the Complainant Company is dealing in the supply of

textile/fabric products. Allegedly, M/s Bee K Bee Private Limited

Company (hereinafter referred as “accused Company”)

purchased material from the Complainant Company.

4. The Accused have been arrested in the captioned matter by the

Police Officer today i.e. 23.03.2024 as the Non-Bailable warrants

are issued in the captioned matter (filed under Section 138 of the

Negotiable Instrument Act, 1881) against the Applicant vide

order dated 23.02.2024. It is pertinent to mention that the

captioned matter were called and the accused were marked

absent and Non Bailable Warrant were issued against the

Applicant by this Hon'ble Court on account of their non-

appearance.

5. That the absence on the part of the accused on the said dates

was thus neither willful nor intentional but only due major health

issues being faced by Applicant as detailed below:-


a. Mr. Rajan Batra having age 69 years: Major Heart Patience,

Admitted in hospital thrice due to heart attacks and

undergone multiple angiographies.

Copy of medical documents of the Applicant are marked and

annexed herewith as ANNEXURE -1.

6. That the Applicant further undertakes to furnish the bail

bonds/surety bonds to the entire satisfaction of this Hon’ble

Court and to abide by the conditions, if any, that this Hon’ble

Court be pleased to impose in the event of grant of regular bail.

7. That the petitioner undertakes not to tamper with the evidence

of the prosecution and to appear on each and every date in the

trial as well as not to leave the territorial jurisdiction of this

Hon’ble Court without permission.

8. That the Applicant craves leave of this Hon’ble Court to raise any

other additional ground at the time of hearing of the present

application.

9. That the Applicant undertake to abide by all the conditions laid

down by the Hon’ble Court while granting regular bail to the

Applicant.
10. That the Applicant has not filed any other similar

application/petition in this Hon’ble Court or any other Court and

this is his first bail application in the present case.

PRAYER

In the facts and circumstances of the case and in the interest of

justice, it is most respectfully prayed that this Hon’ble Court may

graciously be pleased to:

a) Grant the Applicant regular bail in the captioned matter;

b) Pass any other or further orders as this Hon’ble Court may

deem fit in the interest of justice.

APPLICANT

(VARUN TANDON, ZORAWAR SINGH, HITESH MANKAR DEEPAK


SHARMA)
T&T LAW
Advocate(s) for the Applicant
R-89, Greater Kailash Part 1,
New Delhi – 110048
T: 011-40860000

PLACE: NEW DELHI


DATE: 23.03.2024
IN THE COURT LEARNED METROPOLITAN MAGISTRATE, SOUTH EAST
SAKET DELHI

CC No. 7101/2022

IN THE MATTER OF

Hukumchand Fabrics Private Limited. …. Complainant

Vs.

M/s Bee K Bee Prints Private Limited and Ors. …. Accused

BAIL APPLICATION

RAJAN BATRA …APPLICANT

VERSUS
STATE …RESPONDENT
INDEX

S.No Particulars Pages


.
1. Applicant u/s 437 of CrPC seeking grant of 1–
regular bail in captioned matter.

2. Annexure 1
Copy of medical documents of the Applicant.

3. Vakalatnama

THROUGH
(VARUN TANDON, ZORAWAR SINGH, HITESH MANKAR, DEEPAK
SHARMA)
T&T LAW
Advocate(s) for the Applicant
R-89, Greater Kailash Part 1,
New Delhi – 110048
T: 011-40860000
PLACE: NEW DELHI
DATE: 23.03.2024
IN THE COURT LEARNED METROPOLITAN MAGISTRATE, SOUTH
EAST SAKET DELHI

CC No. 7101/2022

IN THE MATTER OF

Hukumchand Fabrics Private Limited. …. Complainant

Vs.

M/s Bee K Bee Prints Private Limited and Ors. …. Accused

BAIL APPLICATION

NEERAJ BATRA …APPLICANT

VERSUS
STATE …RESPONDENT

APPLICATION UNDER SECTION 437 CRPC SEEKING GRANT OF


REGULAR BAIL IN THE CAPTIONED MATTER ON BEHALF OF THE
APPLICANT

MOST RESPECTFULL SHOWETH:

1. That the present bail application has been filed by the above

named Applicant u/s 437 of CrPC seeking grant of regular bail in

the captioned matter filed under Section 138 of the Negotiable

Instrument Act, 1881 by the Complainant. It is pertinent to

mention that the applicant is currently in Police custody.


2. It is pertinent to mention here that the above mentioned

Applicant is resident of Delhi and has no criminal antecedents

and comes from a well-known family in Delhi.

3. It is submitted that the subject matter of the present case is that

the Complainant Company is dealing in the supply of

textile/fabric products. Allegedly, M/s Bee K Bee Private Limited

Company (hereinafter referred as “accused Company”)

purchased material from the Complainant Company.

4. The Accused have been arrested in the captioned matter by the

Police Officer today i.e. 23.03.2024 as the Non-Bailable warrants

are issued in the captioned matter (filed under Section 138 of the

Negotiable Instrument Act, 1881) against the Applicant vide

order dated 23.02.2024. It is pertinent to mention that the

captioned matter were called and the accused were marked

absent and Non Bailable Warrant were issued against the

Applicant by this Hon'ble Court on account of their non-

appearance.

5. That the absence on the part of the accused on the said dates

was thus neither willful nor intentional but only due major health

issues being faced by Applicant as detailed below:-


a. Mrs. Neeraj Batra having age 66 years: Hyper Tension, High

Blood Pressue.

Copy of medical documents of the Applicant are marked and

annexed herewith as ANNEXURE -1.

11. That the Applicant further undertakes to furnish the bail

bonds/surety bonds to the entire satisfaction of this Hon’ble

Court and to abide by the conditions, if any, that this Hon’ble

Court be pleased to impose in the event of grant of regular bail.

12. That the petitioner undertakes not to tamper with the evidence

of the prosecution and to appear on each and every date in the

trial as well as not to leave the territorial jurisdiction of this

Hon’ble Court without permission.

13. That the Applicant craves leave of this Hon’ble Court to raise any

other additional ground at the time of hearing of the present

application.

14. That the Applicant undertake to abide by all the conditions laid

down by the Hon’ble Court while granting regular bail to the

Applicant.
15. That the Applicant has not filed any other similar

application/petition in this Hon’ble Court or any other Court and

this is his first bail application in the present case.

PRAYER

In the facts and circumstances of the case and in the interest of

justice, it is most respectfully prayed that this Hon’ble Court may

graciously be pleased to:

c) Grant the Applicant regular bail in the captioned matter;

d) Pass any other or further orders as this Hon’ble Court may

deem fit in the interest of justice.

APPLICANT

(VARUN TANDON, ZORAWAR SINGH, HITESH MANKAR DEEPAK


SHARMA)
T&T LAW
Advocate(s) for the Applicant
R-89, Greater Kailash Part 1,
New Delhi – 110048
T: 011-40860000

PLACE: NEW DELHI


DATE: 23.03.2024
IN THE COURT LEARNED METROPOLITAN MAGISTRATE, SOUTH
EAST SAKET DELHI

CC No. 7101/2022

IN THE MATTER OF

Hukumchand Fabrics Private Limited. …. Complainant

Vs.

M/s Bee K Bee Prints Private Limited and Ors. …. Accused


BAIL APPLICATION

NEERAJ BATRA …APPLICANT

VERSUS
STATE …RESPONDENT
INDEX

S.No Particulars Pages


.
1. Applicant u/s 437 of CrPC seeking grant of 1–
regular bail in captioned matter.

2. Annexure 1
Copy of medical documents of the Applicant.

3. Vakalatnama

THROUGH
(VARUN TANDON, ZORAWAR SINGH, HITESH MANKAR, DEEPAK
SHARMA)
T&T LAW
Advocate(s) for the Applicant
R-89, Greater Kailash Part 1,
New Delhi – 110048
T: 011-40860000
PLACE: NEW DELHI
DATE: 23.03.2024

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