BEFORE THE HON`BLE JUVENILE JUSTICE BOARD-II,
DISTRICT SOUTH-EAST, DELHI
IN THE MATTER OF: -
STATE Vs. JITU KUMAR
S/o Binit Kumar Singh
FIR No – 427/2025
U/s – 109(1)/115(2)/126(2)/351(3)/3(5) BNS &
27 Arms Act
PS – OIA
BAIL APPLICTAION U/s – 12 OF THE JUVENILE
JUSTICE (CARE AND PROTECTION OF CHILDREN)
ACT, 2015, FOR GRANT OF REGULAR BAIL TO CCL
NAMELY JITU KUMAR ON BEHALF OF HIS FATHER
BINIT KUMAR SINGH
MOST RESPECTFULLY SHOWETH: -
1. That the above-mentioned matter is pending for adjudication
before this Hon`ble and the NDOH is 06/06/2025.
2. That succinctly, the story of the prosecution is that on dated
10/05/2025 around 12:15 AM, the complainant was returning
home along with his friend namely Anuj Kumar and they reached
Kargil Chowk, Indira Kalyan Vihar.
3. That at the same time, persons namely Durganand along with his
friend namely Krishan Mandal and their friends were also standing
there. That it is necessary to mention that approximately 3-4
months back, there was a dispute involving Durganand and
Krishan Mandal regarding a tearing of Durga Puja Poster, which
led to a quarrel. Since then, they have been harassing the
complainant with abusive language and threats.
4. That on dated 10/05/2025, when the complainant was standing
with his friend namely Anuj then suddenly Durganand along with
Krishan Mandal and their friends came and started abusing the
complainant when the complainant resisted to their abusive
language then they threatened the complainant of dire
consequences.
5. That, the complainant along with his friend namely Anuj went to
the house of Krishan Mandal and they complain about the incident
and rude behaviour of the persons to the father of Krishan Mandal.
Thereafter, during the mean time while they were talking to the
Father of Krishan Mandal, the person namely Durganand came on
a scooty along with their friends who had sticks and rods in their
hands.
6. Thereafter, heated arguments started between them, Durganand
along with Krishan Mandal and their friends started beating the
complainant with sticks and roads. Furthermore, during the fight
the person namely Durganand took out pistol and fired upon the
complainant which hit the pellets of bullet on the person namely
Anuj.
7. Thereafter, the complainant dialled PCR, then PCR vehicle came
and taken the complainant and his friend namely Anuj to the
AIIMS Trauma Centre where they were admitted and treated.
After that upon the statement of the complainant, the present FIR
lodged. (Copy of the FIR is hereby annexed as ANNEXURE -
A).
GROUNDS
i. That the CCL is young and innocent and have deep-roots in
the society.
ii. That it is pertinent to mention herein that the CCL is
presently on protective custody of this Hon`ble Board since
11.05.2025.
iii. That the CCL is a juvenile within the meaning the J.J. Act,
2015 and as such this Hon`ble Board has jurisdiction in the
instant case. That the date of birth as per school record of
the CCL is 20/03/2008. (Copy of the Marksheet of the
School is hereby annexed as ANNEXURE - B).
iv. That the CCL has not come into conflict with law earlier and
there is no antecedent against him.
v. That it is pertinent to mention that there is nothing in the
instant case which connects the CCL with the alleged
incident. Furthermore, it is necessary to mention that the
FIR itself does not have his name and he is falsely
implicated by the police officials in the present case.
vi. That the applicant is father of the CCL and states that the
child has been under his custody, as such he has full control
over the CCL. The juvenile has been falsely implicated by
the police and the complaint in this case as he has nothing
to do with the present case.
vii. That it apposite to mention that the CCL was not present
there at the time of incident and he was falsely implicated
by the police officials.
viii. That the applicant undertakes to abide by all terms and
conditions imposed by this Hon`ble Board and will not
hamper with any prosecution evidence and try to put
pressure on any witnesses. Furthermore, the applicant
ensures that the CCL shall be present, when his presence
shall be required by this Hon`ble Board.
ix. That the applicant undertakes that he shall ensures that the
CCL shall not go in negative peer group and further the CCL
shall continue on his studies.
PRAYER
Therefore, keeping in view the said facts and circumstances
stated herein above in the interest of juvenile, it is most
respectfully prayed before this Hon`ble Board may
graciously grant Regular Bail to the CCL namely Jitu
Kumar S/o Bipin Kumar Singh or pass any order in the
interest of justice.
Applicant/Father of CCL
THROUGH
FAIZ ALAM & ASSOCIATES
Ch. No – 429, PHC, New Delhi
Mobile No – 7291886591
Date: 06/06/2025
