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IN THE COURT OF THE DISTRICT SESSIONS JUDGE AT
KOLAR
Crl.Mis.No. /2017
Petitioner: 1. Gangireddy S/o Ramachandra Reddy ,
Aged about 55 years, Agriculturist.
2. Shravana Kumar S/o Gangireddy,
Aged about 23 years, Agriculturist,
Both are R/o Channaiahgaripalli Village,
Ronur hobli, Srinivasapur taluk.
(Accused No.1 and 3 in Cr.No.7/2017)
V/s
Respondent: The State of Karnataka,
Represented by its Sub- Inspector
of police, Srinivasapura Police Station,
Srinivasapur.
UNDER SECTION 438 OF Cr.P.C.
The petitioners above named beg to submit as follows:
1. That the address of the petitioners for the purpose of service
of summons, court notices, etc., as furnished in the cause
title of the petition is correct.
2. The address of the respondent for the purpose of service of
summons, Court notices, process, etc., as furnished in the
cause title of the petition is correct.
3. The respondent/Police have registered a false case against the
petitioners and others in Cr.No.7/2017 for the offences
punishable under section 143, 147, 148, 448, 323, 324 and 307
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R/w Sec. 149 of IPC and Sec.3(1)(10)(11) SC/ST (POA) Act.
On the basis of written complaint lodged by the complainant
Anjalappa S/o Venkatappa R/o Channaiahgaripalli village. It is
alleged in his complaint on 14.1.2017 there is a APMC Election
counting work was held in the said Election result one Ramesh
who is supporter of congress party was elected and further
alleged in his complaint at about 8 P.M. there was a pooja at
Maramma temple of his village the said pooja performed by one
Nagaraja Reddy and others of his village they belongs to
Vakkaliga community. The said information came to know by
the complainant and he intend to attend the said pooja at that
time the complainant present in his house at that time the
petitioners and other accused Shivareddy, Munirathnareddy,
Changareddy and Shankar Reddy they have formed unlawfully
assembly and illegally tress passed to the complainant house and
abusing him in filthy language stating that why you went to
Maramma temple and further alleged in his complaint the
petitioner No.1 assaulted him on his lips and beard and
petitioner No.2 and other accused are also assaulted the
complainant through their hands and legs and further in alleged
in his complaint the petitioners and others have threatened the
dare consequences of his life. In the mean time the witness
Ashok Reddy and Venkatamanareddy intervened and pacify the
galata and they have phone call to 108 Ambulance and shifted to
the complainant to General hospital, Srinivasapur for treatment.
These are the brief facts of the case.
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GROUNDS
1. The petitioners are apprehension of their arrest by the
respondent/police in Cr.No.7/2017 for the offence punishable
Under Section Sections 143, 147, 148, 448, 323, 324 and 307
R/w Sec. 149 of IPC and Sec.3(1)(10)(11) SC/ST (POA) Act.
The petitioners are arrayed as accused No.1 and 3.
2. The petitioners are permanent resident of
Channaiahgaripalli village, Ronur hobli, Srinivasapur
Taluk and they agriculturist by profession and they have
possessed movable and immovable properties and they have
a deep roots in the society. The petitioners are the innocent
of the alleged offence leveled against them. Per contra SC/ST
Atrocity Act under Sec.3(1)(10)(11) SC/ST (POA) Act is not
attract the case on hand.
3. The petitioners submit that the accused No.2 and 4 to 6
already granted regular bail on 2.2.2017 on the ground of
parity the petitioners are also entitled an anticipatory bail.
4. The petitioners submit that their village is a politically
fractious village and some of the persons are against the
petitioners and other accused with their instigation the
respondent/police colluding with complainant Anjappa
implicating the innocent petitioners in the heinous offences.
Even though the petitioners have no any role in the said
crime.
5. The petitioners are undertakes to assist the investigation and
they have not tamper or terrorize the prosecution witnesses, if
grants on anticipatory bail to them.
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6. The petitioners are abiding any terms and conditions imposed
by this Hon’ble Court if grants on anticipatory bail.
7. The petitioners seek the leave of this Hon’ble Court to urge
any other grounds at the time of arguments.
8. The petitioners are herein producing the Xerox copy of the
FIR with enclose along with bail order of the accused No.2 ,
4 to 6 for kind perusal of this Hon’ble Court.
WHEREFORE, the petitioners prays this Hon’ble Court may
pleased to grant an anticipatory bail and directing the
respondent/police to release them in the event of their arrest in
Cr.No.7/2017 for the offences punishable under section 143, 147, 148,
448, 323, 324 and 307 R/w Sec. 149 of IPC and Sec.3(1)(10)(11)
SC/ST (POA) Act in the interest of Justice and Equity.
Place: Kolar
Dated: .2.2017 Advocate for petitioners
