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BAIL

The document details a bail application filed by Joginder Singh who has been in jail since May 2013 in relation to an FIR from that year under sections 302, 323, and 34 of the IPC. The application includes various annexures such as copies of the FIR, previous bail orders, medical and educational records in support of the application.

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Ritesh Chauhan
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100% found this document useful (1 vote)
97 views28 pages

BAIL

The document details a bail application filed by Joginder Singh who has been in jail since May 2013 in relation to an FIR from that year under sections 302, 323, and 34 of the IPC. The application includes various annexures such as copies of the FIR, previous bail orders, medical and educational records in support of the application.

Uploaded by

Ritesh Chauhan
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
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IN THE HIGH COURT OF DELHI AT NEW DELHI

(CRIMINAL JURISDICTION)

CRL.M. (BAIL) NO. /2023

IN THE MATTER OF:

JOGINDER SINGH
… APPLICANT
VERSUS
THE STATE OF NCT OF
DELHI …RESPONDENT

FIR no. 225/2013 dated 09.05.2013


Under sections 302/ 323/34 IPC
P.S.: Samaypur Badli
District: North
S.C. No. 59001/2016
INDEX

S. NO. PARTICULARS PAGE.NO


1. Notice of motion.
2. Court Fees.
3. Urgent Application.
4. Memo of Parties.
5. List of dates and events.
6. Application under Section 389(1) read
with Section 482 of the Code of
Criminal Procedure, 1973, for seeking
Interim Suspension of Sentence and for
Grant of Bail on behalf of
Appellant/Applicant, Namely Joginder
Singh, along with affidavit in support.
7. Annexure P-1
True copy of FIR bearing no 225 of
2013 dated 09.05.2013, P.S Samaypur
Badli, outer Delhi U/S 302, 201, 323, 34
of IPC.
8. Annexure P-2
True copy of bail order dated
08.12.2022 in Crl.M (Bail) no.
8071/2020
9. Annexure P-3:
True copy of bail order dated 04.10.2021
in Crl.M. (Bail) no 1129/202.
10. Annexure P-4:
True copy of bail order dated
06.05.2022 in Crl.M. (Bail) no
415/2022.
11. Annexure P-5:
True copy of medical records.
12. Annexure P-6:
True copy of educational records
13. Application U/S 482 Cr.Pc for
exemption from filling the true typed
copies and certified copies of the
annexures and orders, a l o n g with
supporting affidavit.
14. Vakalatnama

DATE:
NEW DELHI

Filed by:
Appellant/Applicant
(In JC)
(Through Pairokaar)
R/o A-29, Mandir Mohalla,
Samaypur, Libaspur, Delhi-110042

Through
N.S BISHT (ENROL.NO D/108E /2000
HITESH KUMAR (ENROL. NO. D/2661/13)
NITESH KUMAR SINGH (ENROL. NO. D/2741/13)
ABHISHEK BHARDWAJ (ENROL. NO. D/2488/13)
YATIKA CHOUDHARY (ENROL.NO D/552/2018
SURAJ RAWAT (ENROL.NO D/12023/2022)
COUNSELS FOR THE APPLICANT
C-180A, DEFENCE COLONY,
NEW DELHI-24.
MOB. 9650619671 / 9968779099
IN THE HIGH COURT OF DELHI AT NEW DELHI
(CRIMINAL JURISDICTION)
CRL.M. (BAIL) NO. /2023

IN THE MATTER OF:

JOGINDER SINGH … APPLICANT

VERSUS
THE STATE OF NCT OF
DELHI …RESPONDENT

FIR no. 225/2013 dated 09.05.2013


Under sections 302/ 323/34 IPC
P.S.: Samaypur Badli
District: North
S.C. No. 59001/2016

NOTICE OF MOTION

Please take notice that this Miscellaneous Bail Application be listed


before this Hon’ble High Court on July 2023, or so soon thereafter as
may be convenient to the Hon’ble Court.

DATE:
NEW DELHI

Filed by:

Appellant/Applicant
(In JC)
(Through Pairokaar)

Through
N.S BISHT ( ENROL.NO D 108E/2000
HITESH KUMAR (ENROL. NO. D/2661/13)
NITESH KUMAR SINGH (ENROL. NO. D/2741/13)
ABHISHEK BHARDWAJ (ENROL. NO. D/2488/13)
YATIKA CHOUDHARY (ENROL.NO D/552/2018
SURAJ RAWAT (ENROL.NO D/12023/2022)
COUNSELS FOR THE APPLICANT
C-180A, DEFENCE COLONY,
NEW DELHI-24.
MOB. 9650619671 / 9968779099
IN THE HIGH COURT OF DELHI AT NEW DELHI
(CRIMINAL JURISDICTION)

CRL.M. (BAIL) NO. /2023

IN THE MATTER OF:

JOGINDER SINGH … APPLICANT


VERSUS
THE STATE OF NCT OF
DELHI …RESPONDENT

FIR no. 225/2013 dated 09.05.2013


Under sections 302/ 323/34 IPC
P.S.: Samaypur Badli
District: North
S.C. No. 59001/2016
URGENT APPLICATION
To
The Registrar,
High Court of Delhi,
New Delhi.

Sir,

Kindly treat the accompanying petition as an urgent one under the rules
and regulations of the Hon’ble High Court of Delhi.
Grounds of urgency are: -

The accused is a simple law-abiding citizen and is languishing in jail in the


present case since 09.05.2013. Thus, urgent Bail has been prayed for.
Filed by:

Appellant/Applicant
(In JC)
(Through Pairokaar)
R/o A-29, Mandir Mohalla,
Samaypur, Libaspur, Delhi-110042

Through
N.S BISHT ( ENROL.NO D 108E/2000
HITESH KUMAR (ENROL. NO. D/2661/13)
NITESH KUMAR SINGH (ENROL. NO. D/2741/13)
ABHISHEK BHARDWAJ (ENROL. NO. D/2488/13)
YATIKA CHOUDHARY (ENROL.NO
D/552/2018 SURAJ RAWAT
(ENROL.NO D/12023/2022)
COUNSELS FOR THE
APPLICANT C-180A,
DEFENCE COLONY,
NEW DELHI-
24. MOB. 9650619671 / 9968779099
IN THE HIGH COURT OF DELHI AT NEW DELHI
(CRIMINAL JURISDICTION)

CRL.M. (BAIL) NO. /2023

IN THE MATTER OF:

JOGINDER SINGH
… APPLICANT
VERSUS
THE STATE OF NCT OF DELHI …RESPONDENT
COURT FEES

Appellant/Applicant
(In JC)
(Through Pairokaar)
R/o A-29, Mandir Mohalla,
Samaypur, Libaspur, Delhi-110042

THROUGH
COUNSELS
N.S BISHT, HITESH KUMAR,
NITESH KUMAR SINGH
ABHISHEK BHARDWAJ,
SURAJ RAWAT, YATIKA CHOUDHARY
IN THE HIGH COURT OF DELHI AT NEW DELHI
(CRIMINAL JURISDICTION)

CRL.M. (BAIL) NO. /2023

IN THE MATTER OF:

JOGINDER SINGH
… APPLICANT
VERSUS
THE STATE OF NCT OF
DELHI …RESPONDENT

FIR no. 225/2013 dated 09.05.2013


Under sections 302/ 323/34 IPC
P.S.: Samaypur Badli
District: North
S.C. No. 59001/2016

MEMO OF PARTIES

1. JOGINDER SINGH
S/o Sh. Attar Singh R/o
Village Dheegal Dist.
Jhajjar, Haryana
…APPELLANT/APPLICANT

VERSUS

1. THE STATE
(Govt. of NCT of Delhi)
THROUGH SHO PS- SAMAYPUR BADLI
EMAIL:- [email protected]
… RESPONDENT
DATE:
NEW DELHI

Filed by:
Appellant/Applicant
(In JC)
(Through Pairokaar)
R/o A-29, Mandir Mohalla,
Samaypur, Libaspur, Delhi-110042

Through
N.S BISHT ( ENROL.NO D/108E/2000
HITESH KUMAR (ENROL. NO. D/2661/13)
NITESH KUMAR SINGH (ENROL. NO. D/2741/13)
ABHISHEK BHARDWAJ (ENROL. NO. D/2488/13)
YATIKA CHOUDHARY (ENROL.NO
D/552/2018 SURAJ RAWAT
(ENROL.NO D/12023/2022)
COUNSELS FOR THE
APPLICANT C-180A,
DEFENCE COLONY,
NEW DELHI-
24. MOB. 9650619671 / 9968779099
IN THE HIGH COURT OF DELHI AT NEW DELHI
(CRIMINAL JURISDICTION)

CRL.M. (BAIL) NO. /2023

IN THE MATTER OF:

JOGINDER SINGH
… APPLICANT
VERSUS
THE STATE OF NCT OF DELHI …RESPONDENT

FIR no. 225/2013 dated 09.05.2013


Under sections 302/ 323/34 IPC
P.S.: Samaypur Badli
District: North
S.C. No. 59001/2016

DATES AND EVENTS

9.5.2013 at 3:22:01 AM

A call was received at Delhi Police Control Room from one Nitin Kumar
alleging, “yahan par 2 admiyon ke sath bahut jyada maarpeet ho rhi hai".

9.5.13 AT 3.30 AM
The same was forwarded to PS S.P. Badli at 3.30 am and was recorded as
DD N0.8A. The information was telephonically brought to the knowledge
of HC Jagat who left for the spot.

3.55. AM
Having thus reached the spot HC Jagat Singh at 3.55 am requested that
senior officers be sent to the spot and the information was recorded as DD
No.9A. SI Jhabbu Ram was accordingly apprised and sent to the spot.
On receipt of DD No.9A when SI Jhabbu Ram reached the spot i.eCW-
544, Top Floor, Sanjay Gandhi Transport Nagar, he met the accused
persons there i.e Vinod, Rohtash and the present appellant. On enquiry SI
Jhabbu Ram came to know that the PGR van had already removed the
injured to BSA Hospital. SI Jhabbu Ram, having left beat constable Prem
Singh at the spot, left for BSA Hospital, where he obtained the MLC of
Bhola bearing No.47545/23 and that of Jasbir bearing No.47546/13.The
MLC of Bhola recorded alleged history of physical assault at around12.30
am on 9.5.13 and the patient declared brought dead. Vide the other MLC
Jasbir was found undertreatment whereupon the 10 recorded his statement.
Briefly stated, the injured Jasbir alleged in his statement that for the last
10-12 days he was working as Khalasi i.e helper/conduction truck bearing
No.HR 63-B-5007of Delhi Raipur Road Lines, CW-544, SGT Nagar,
Delhi owned by Vinod and Jogender; the deceased Bhola was driver on the
said truck. He further alleged that Bhola had left with the truck for Raipur,
Chhatisgarh alongwith the conductor Jasbir and the material was unloaded
there from the aforesaid truck on 1.5. 2013.On the instructions of the
owner, Bhola loaded the truck with iron rods to be transported to
Faridabad and Naraina.They reached Faridabad on 7.5.2013at about 9,00
pm, where they unloaded the goods. On 8.5.2013, Bhola made a call to
accused Vinod Kumar that the truck had run out of diesel and they were
not left with any money. On 8.5.2013 at about 8.00 pm, the
appellant,Vinod and Rohtash reached Faridabad in a Santro Car
bearingNo.HR 77 4627 and scolded and slapped Bhola and Jasbir alleging
that they had sold out the diesel and misappropriated the money given to
them for bearing the transit expenses. The accused persons got the truck-
tank refilled with diesel worth Rs.3000and asked Bhola to follow the car;
Bhola obeyed. It was further alleged that when they reached Delhi, the
accused persons forcibly took the deceased out of the truck; assaulted him;
made him sit in the above said car and forcibly brought him to their office
situated at CW-544, 2"^" Floor Sanjay Gandhi Transport Nagar, Delhi at
about 12.00 midnight. At the office, having raised the volume of the
TV,the accused persons inflicted several injuries on the person of the
deceased, besides himself In the meanwhile someone called the
PCR ;Bhola died on the way while being removed to the hospital.

9.5.13, 6.30 AM
On the above statement, ruqqa was sent to PS S.P. Badli through Ct.Ajay,
at 6.30 am on 9.5.13 whereupon vide DD No.11A FIR No.225/13, under
sections 302/323/201 was registered at PS S.P.Badli, and Inspector Rajesh
Kumar alongwith Ct.Surender left for the spot.

Vide DD No.l2A further investigation was marked to Inspector Rajesh


Johari, who was already present at the spot, and a copy of FIR was sent to
him through constable Ajay. Another copy of the FIR was sent to senior
officers as well as the concerned Magistrate through constable Pradeep. In
the meanwhile, mobile crime team reached the spot and carried out
inspection from 6.05 am to 6.40 am. A wooden bed (takhat) was found at
the spot, besides two blood-stained wooden sticks. No finger prints could
be lifted from the spot. Photographs of the spot were also taken. The 10
prepared rough site plan of the spot effected recoveries. In the evening the
accused persons were arrested and an iron rod at the instance of Vinod;
one danda with three broken pieces at the instance of Jogender and one
danda at the instance of Rohtash (all blood stained) were recovered. A
blood stained pocha/duster was also seized from the spot.
10.5.2013
The post mortem of the deceased was conducted

29.7.2013
Statement of Ajay Kumar who allegedly made the PGR call was recorded.

11.11.14
FSL report qua the exhibits lifted in the case was sent to the SHO
concerned.
On completion of the investigation the chargesheet was filed; after
compliance of the provisions of section 207 Cr.P.C. the case was
committed to the Court of Sessions, whereupon charge was framed against
the accused u/s 302/201/34IPC.

16.5.2019
The appellant and accused Vinod were convicted by the Ld.Trial Court.

17.5.2019
Order on sentence was passed qua the convicts.

18.07.2023
Hence the present bail application
IN THE HIGH COURT OF DELHI AT NEW DELHI
(CRIMINAL JURISDICTION)

CRL.M. (BAIL) NO. /2023

IN THE MATTER OF:

JOGINDER SINGH
… APPLICANT
VERSUS
THE STATE OF NCT OF
DELHI …RESPONDENT

FIR no. 225/2013 dated 09.05.2013


Under sections 302/ 323/34 IPC
P.S.: Samaypur Badli
District: North
S.C. No. 59001/2016

APPLICATION UNDER SECTION 389(1) READ WITH SECTION


482 OF THE CODE OF CRIMINAL PROCEDURE, 1973, FOR
SEEKING INTERIM SUSPENSION OF SENTENCE AND FOR
GRANT OF BAIL ON BEHALF OF APPELLANT/APPLICANT,
NAMELY JOGINDER SINGH

MOST RESPECTFULLY SHOWETH:

1. That the appellant has filed a criminal appeal, bearing no. “Crl.

Appeal no. 830/2019, in fir bearing no 225/2013 dated 09.05.2013

at PS. Samaypur Badli, pending before this Hon’ble Court. The

averments made in the appeal be read as part and parcel of the

application as the same or not being repeated hearing for the sake
of brevity, the appeal could not be heard due to suspension of work

considering pandemic in the country. The copy of fir bearing no

225/2013 dated 09.05.2013 at PS. Samaypur Badli is annexed as

herewith ANNEXURE P-1.

2. That the above-mentioned appeal was listed for final hearing

before Hon’ble Justice Mukta Gupta and Hon’ble Justice Poonam

A. Bamba on 22.12.2022, whereby the bench made the following

order:

“In the view of the presence of the counsel who has

appeared for the appellant Vinod Kumar during the

course of the trial, list these appeals before another

Bench of which Mukta Gupta, J. is not a member of,

subject to orders of Hon’ble the Chief Justice.”

3. That the matter has not been listed since the above order was made.

4. That there is no likelihood that it may be heard any time soon.

Hence this petition seeking interim suspension of sentence.

5. The appellant/applicant has a good prima facie case in his favour,

and there is all the likelihood that he would succeed in the

captioned appealed.

6. The appellant is languishing in jail in the present case since

09.05.2013, though he was admitted to interim bail by the Ld. trial

court for a brief period of time.


7. That the appellant/applicant was admitted to interim bail by this

Hon’ble court for 45 days, in Crl.M. (Bail) no. 8071/2020 vide

order dated 08.12.2020, which was kept on extending by the

Hon’ble High Court of Delhi as per the directions of the Hon’ble

Supreme Court of India due to the covid situation, and the

appellant/applicant duly surrendered after the extension period was

over. Copy of the bail order is annexed herewith as ANNEXURE

P-2.

8. That the appellant/applicant was admitted to interim bail by this

Hon’ble court for 4 weeks, in Crl.M. (Bail) no 1129/2021 vide

order dated 04.10.2021, and the appellant/applicant duly

surrendered after the said period. Copy of the bail order is annexed

herewith as ANNEXURE P-3.

9. That the appellant/applicant was admitted to interim bail by this

Hon’ble court for 4 weeks, in Crl.M.(Bail) no 415/2022 vide order

dated 06.05.2022, and the appellant/applicant duly surrendered

after the said period. Copy of the bail order is annexed herewith as

ANNEXURE P-4.

10.The appellant/applicant is a married man having a family to

support comprising of his wife and children. He has deep roots in

society and there are no chances of his fleeing away. The

appellant/applicant being the sole bread earner of his family, the


entire family is undergoing severe financial hardship and finding it

very difficult to make their ends meet like educational expenses,

medical expenses, rent, daily household expenses, etc. They are

finding it difficult to pay for their daily household expenses as well

as school fees for the children.

11.That the Appellant/applicant has all so to look after her ailing wife

who is suffering for mental ailment and is getting treated for the

same. Due to the hearing mental condition of his wife, his children

also need their father to be with them for daily needs and as

support in these harsh circumstances. Copy of the medical records

is annexed herewith as ANNEXURE P-5.

12.That the children of the appellant/applicant are at critical stage of

their educational career, and are thus in extreme need of financial

as well as mental support from their father/applicant to pursue

education. Copy of the educational records is annexed herewith as

ANNEXURE P-6.

13. That the circumstances necessitate that the be granted bail till the

adjudication the pending appeal before this Hon’ble Court so that

he could financially support his family, daily household needs,

house rent and school fees of the children as well as to for proper

medical treatment of his wife.


14.That the appellant/applicant has never violated any bail conditions

imposed by this Hon’ble Court or by the Ld. Trial Court.

15. That the appellant/applicant undertakes to abide by such terms or

conditions as this Hon’ble Court may deem fit to impose upon him

in the event of suspension of his sentence.

16.That the Appellant/Applicant is a law-abiding citizen and

permanent residence of the address stated above. He has deep roots

in the society and there is no apprehension of his fleeing away

from justice. Should this Hon’ble court to release him on bail. The

Appellant/Applicant undertakes to follow the due process of Bail.

17.That the Appellant/Applicant is ready to submit himself to any

condition/conditions, which this Hon’ble court may impose to allay

the fears of the prosecution of any kind of likely absence from the

appeal. The Appellant/Applicant is ready to give sound surety to

the satisfaction of this Hon’ble court.

18. That the Appellant/Applicant seeks the kind permission of this

Hon’ble court to raise such further grounds as available to him

during the hearing of this bail application.

19. That no application seeking similar relief as sought in the present

application is pending before the Hon’ble Supreme Court, the

Hon’ble High Court or any other court.


PRAYER

It is, therefore, most respectfully prayed that in the light of aforesaid facts

and circumstances, this Hon’ble court be pleased to:

a) Grant suspension of sentence and bail to the Appellant/Applicant in

FIR no 225/2013, under sections 302, 323 and 34 of the Indian penal

code, P.S. Samaypur Badli; and/or

b) Pass any other order as this Hon’ble Court may deem fit and proper, in

the interest of justice.

Filed by:

Appellant/Applicant
(In JC)
(Through Pairokaar)
R/o A-29, Mandir Mohalla,
Samaypur, Libaspur, Delhi-110042

Through

N.S BISHT (ENROL.NO D/2000


HITESH KUMAR (ENROL. NO. D/2661/13)
NITESH KUMAR SINGH (ENROL. NO. D/2741/13)
ABHISHEK BHARDWAJ (ENROL. NO. D/2488/13)
YATIKA CHOUDHARY (ENROL.NO D/552/2018
SURAJ RAWAT (ENROL.NO D/12023/2022)
COUNSELS FOR THE APPLICANT
C-180A, DEFENCE COLONY,
NEW DELHI-24.
MOB. 9650619671 / 9968779099
IN THE HIGH COURT OF DELHI AT NEW DELHI
(CRIMINAL JURISDICTION)

CRL.M.(BAIL) NO. /2023


IN THE MATTER OF:

JOGINDER SINGH …APPLICANT


VERSUS
THE STATE OF NCT OF DELHI … RESPONDENT
AFFIDAVIT

Affidavit of Smt. Sonu (aged about 37 years) W/O Sh. Joginder Singh, R/O

A -29, Mandir Mohalla, Samaypur, libaspur, Delhi- 110042, Do hereby

solemnly affirm and declare as under.

1. That the deponent, is the wife of the appellant and pairokar and as such is
well conversant with the facts of the present case, also have undersigned,
as well as the grounds contained in the accompanying bail application, as
well as the application filed along with the it.
2. That accompanying bail application and the applications along with has
been drafted by the counsel for the appellant / applicant at the
instructions of the deponent and the contents of the same may kindly be
read as part and parcel of this affidavit which is not repeated here for the
sake of brevity.
3. That I am competent to swear this affidavit being well acquainted with
the facts and circumstances of the case.
DEPONENT
VERIFICATION
Verified at Delhi on this day of July, 2023, that the contents of the
above affidavit i.e para 1 to 3 are true and correct to the best of my knowledge.
Nothing material had been concealed therefrom. No part of it is false.

DEPONENT
IN THE HIGH COURT OF DELHI AT NEW DELHI
(CRIMINAL JURISDICTION)

CRL.M. (BAIL) NO. /2023

IN THE MATTER OF:

JOGINDER SINGH
… APPLICANT
VERSUS
THE STATE OF NCT OF DELHI
…RESPONDENT

FIR no. 225/2013 dated 09.05.2013


Under sections 302/ 323/34 IPC
P.S.: Samaypur Badli
District: North
S.C. No. 59001/201

APPLICATION UNDER SECTION 482 CR.P.C. FOR EXEMPTION


FROM FILING OFFICIAL TRUE/CERTIFIED COPIES OF THE
DOCUMENTS.
MOST RESPECTFULLY SHOWETH:

A. That the applicant has filed the accompanying application under Section
389 R/W section 482 of the Cr.P.C. for Grant suspension of sentence and
bail to the Appellant/Applicant in FIR no 225/2013, under sections 302,
323 and 34 of the Indian penal code, P.S. Samaypur Badli. The contents
of the petition are not being repeated herein for the sake of brevity and
the same may please read as if forming part and parcel of the present
application.
1. That the applicant has preferred the accompanying application on
urgent basis and have annexed certain annexures, however, the copies
of the same are true copies of the annexures and the certified
copies/official true typed copies/official true typed copies are not
available for filing the same with the present application.
2. That the applicant undertakes to file the official true typed
copies/certified copies of the annexures as and when directed by this
Hon’ble Court or as and when the same is made available to the
petitioner.
3. That in case the present application is not allowed and the
accompanying application is not entertained without the official true
typed/certified copies of the Annexures, the applicant shall suffer
irreparable loss and injury.
PRAYER
It is therefore, most respectfully prayed that in the interest of
justice this Hon’ble Court may kindly be pleased to exempt the
Petitioner from filing the official true typed/certified copies of the
annexures annexed with the accompanying application, in the
interest and furtherance of justice.
Any other/further relief may also be granted in favour of the
applicant as this Hon’ble court may deem fit and proper in the facts
and circumstances of the case and in the interest of justice.
It is prayed accordingly.
Filed by:

Appellant/Applicant
(In JC)
(Through Pairokaar)
R/o A-29, Mandir Mohalla,
Samaypur, Libaspur, Delhi-110042

Through

N.S BISHT (ENROL.NO D/2000


HITESH KUMAR (ENROL. NO. D/2661/13)
NITESH KUMAR SINGH (ENROL. NO. D/2741/13)
ABHISHEK BHARDWAJ (ENROL. NO. D/2488/13)
YATIKA CHOUDHARY (ENROL.NO D/552/2018
SURAJ RAWAT (ENROL.NO D/12023/2022)
COUNSELS FOR THE APPLICANT
C-180A, DEFENCE COLONY,
NEW DELHI-24.
MOB. 9650619671 / 9968779099
IN THE HIGH COURT OF DELHI AT NEW DELHI
(CRIMINAL JURISDICTION)

CRL.M.(BAIL) NO. /2023


IN THE MATTER OF:

JOGINDER SINGH …APPLICANT


VERSUS
THE STATE OF NCT OF DELHI … RESPONDENT
AFFIDAVIT

Affidavit of Smt. Sonu (aged about 37 years) W/O Sh. Joginder Singh, R/O

A -29, Mandir Mohalla, Samaypur, libaspur, Delhi- 110042, Do hereby

solemnly affirm and declare as under.

1. That the deponent, is the wife of the appellant and pairokar and as such is
well conversant with the facts of the present case, also have undersigned,
as well as the grounds contained in the accompanying bail application, as
well as the application filed along with the it.
2. That accompanying bail application and the applications along with has
been drafted by the counsel for the appellant / applicant at the
instructions of the deponent and the contents of the same may kindly be
read as part and parcel of this affidavit which is not repeated here for the
sake of brevity.
3. That I am competent to swear this affidavit being well acquainted with
the facts and circumstances of the case.
DEPONENT
VERIFICATION
Verified at Delhi on this day of July, 2023, that the contents of the
above affidavit i.e para 1 to 3 are true and correct to the best of my knowledge.
Nothing material had been concealed therefrom. No part of it is false.

DEPONENT

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