IN THE COURT OF DISTRICT & SESSION JUDGE
PATIALA HOUSE COURT DELHI
BAIL APPLICATION NO. OF 2023
IN THE MATTER OF:-
AZAM …..PETITIONER
VERSUS
THE STATE (NCT OF DELHI) .......... RESPONDENT
S. PARTICULARS PAGE
NO
NO.
1. MEMO OF PARTIES 1
2. BAIL APPLICATION U/S 438 CR.P.C 2-7
ON BEHALF OF PETITIONER
SALMAN
3. ANNEXURE P1. COPY OF FIR NO. 8-
10
621/21
4.
ANNEXUR P2. COPY OF MARRIAGE
CARD
5. CHARGE SHEET HAS
ALREADY BEEN
FILED BY THE IO OF THE
CASE.
6. VAKALATNAMA ON
RECOR
D
PETITIONER (IN JC)
Through
Md. Muddassir
Advocate
Ch. No. K-160,
Tis Hazari Court
(M):9716571176
Email:[email protected]
I IN THE COURT OF DISTRICT & SESSION JUDGE
PATIALA HOUSE COURT DELHI
BAIL APPLICATION NO. OF 2024
MEMO OF PARTIES
IN THE MATTER OF:-
AZAM S/O
SHABBIR
R/O H.NO. 156, NEAR
PRADHAN KA MAKAAN
CHANDANHOLLA DELHI,
NEW DELHI PETITIONER
VERSUS
THE STATE (NCT OF DELHI) RESPONDENT
Petitioner (in JC)
Through
Md. Muddassir
Advocate
Ch. No. K160
Tis Hazari court
(M):9716571176
Email:[email protected]
IN THE COURT OF DISTRICT & SESSION JUDGE
I
PATIALA HOUSE COURT DELHI
BAIL APPLICATION NO. OF 2024
IN THE MATTER OF:-
AZAM PETITIONER
VERSUS
THE STATE (NCT OF DELHI) RESPONDENT
BAIL APPLICATION U/S 438
CR.P.C. ON BEHALF OF AZAM S/O
SHABBIR IN FIR 46/2024 U/S 506
IPC & 25 ARMS ACT. P.S. VASANT
VIHAR.
MOST RESPECTFULLY SHOWETH:-
1. That the petitioner is the resident of
India and he has been residing at
Chandanholla from last several years.
2. That the petitioner is an innocent
person and he has full faith in the
Indian law and administration of
justice.
3. The petitioner has been falsely
implicated in this case. However, there
is no intrinsic evidence to prove
complicity of the petitioner in the
present case.
4. That the prosecution alleged that the
petitioner was involved in a threatening
case which was committed on dated
13.03.2024 at the jurisdiction of vasant
vihar police station.
5. That according to the story made by
the police that the complainant runs a
business and dated on 13.03.2024 at
about 4:30 PM when he and his wife
returned from lunch, he noticed a red
carry bag outside of the main gate. The
police further submitted that the
complainant did not pick up the
mentioned bag believing that the
sweeper will come in morning and
remove it. Thereafter dated on
14.03.2024 when he took the
newspaper, the red bag was there. The
police further submitted that when he
returned at his accommodation on
14.03.2024 at about 6 pm so he
noticed that the said red carry bag was
stored on the table inside the gate.
Dated on 15.03.2024 when the
gardener namely sonu handed over the
red carry bag at the third floor and the
same was opened so he say that there
was a box of sweets in which he got the
menacing handwritten note and two
live cartridges thereafter he made a call
to police and on the statement of
complainant a FIR was registered.
6. That at the place of incident the CCTV
cameras were installed and the incident
was captured and in the CCTV footage
of incident is very clear there is no
involvement of petitioner in the
mentioned crime.
7. That the petitioner is an innocent
person and did not commit any crime
as alleged in the present case and the
CCTV footage is supporting him and it
is the only evidence which shows the
innocence of petitioner. On the day of
lodging FIR an unknown person was
sent by the police to give a massage to
the petitioner that they want to get his
help to arrest the real accused but he
replied that he is not well as he is on
fast (Roza) and on the same day when
he was praying in mosque, some police
persons entered in the house of
petitioner and his mother was beaten
by them and the petitioner’s bike was
taken in possession without permission.
It is necessary to mention here that
everything has been recorded in the
CCTV cameras which are installed near
the petitioner’s house and while leaving
house of petitioner they threatened
that the petitioner will be falsely
implicated in the present case.
8. That the petitioner is the only person
who bears the responsibilities of his
family and the petitioner undertakes to
join the investigation as and when
required by the police station of vasant
vihar.
9. That there is no apprehension of his
absconding or tempering with the
prosecution evidence, in case of his
release because the petitioner is ready
to mark his appearance in the
concerned police station till the
setisfection of this Hon’ble court.
10. That the petitioner undertakes not to
temper with the evidence, threat the
prosecution witnesses.
11. That the petitioner undertakes to abide
by all conditions which this Hon'ble
Court may deem fit and proper to
impose upon him.
12. That no similar petition was filed or
pending before this Hon’ble Court or in
any other court of law except present
petition.
PRAYER: -
it is therefore most respectfully prayed that
the applicant be released on bail in the event
of his arrest by the police and any other
order which the court deem fit and proper in
the facts and circumstances of the case may
be also pass in favor of the petitioner in the
interest of justice.
Through
Md. Muddassir
Advocate
Ch. No. K160
Tis Hazari court
(M):9716571176
Email:[email protected]
