Aman New 307

August 19, 2022 | Author: Anonymous | Category: N/A
Share Embed Donate


Short Description

Download Aman New 307...

Description

 

IN THE COURT OF DISTRICT & SESSION JUDGE DISTRICT SOUTH EAST, SAKET COURT, DELHI Bail Application No………….of 2021

IN THE MATTER OF:

AMAN(In J.C.)

………. APPLICANT ……….  APPLICANT VERSUS

STATE (Govt.of NCT of Delhi)

……..RESPONDENT   ……..RESPONDENT

INDEX

S.NO.

PARTICULARS

1. 2.

PAGE NO.

Memo of Parties Second Regular Bail Application on  behalf of Pairokar for Applicant under Section 439 of The Criminal Procedure Code, 1973 along with Affidavit of Pairokar

3.

Annexure A:  True Copy of FIR No.

dated

U/s. 307,506,34 of The Indian

Penal Code, 1860 registered at P.S. Lajpat  Nagar 4.

Annexure B:  True Copy of Order dated

24.05.2021 passed by Hon’ble ASJ Saket Court 5.

Annexure C: True Copy of Complaint

dated 10.04.2021 filed by Applicant’s Sister in law 6.

Application

seeking

Exemption

from

filing Sworn/Affirmed Affidavit 7.

Application on behalf of PAIROKAR for exemption from filing copy of First regular bail

 

application applicati on order dated 04.03.2021 8.

True Copy of I.D. Proof of the Pairokar

9.

Vakalatnama

Pairokar for Applicant Date:  Place:

Through Counsel

MUKESH NARAYAN & SAHIL JAIN CHAMBER NO.421, LAWYER’S CHAMBER, 

DWARKA COURTS COMPLEX, SECTOR-10, NEW DELHI-110075

M: 8168396161; 9910108137 [email protected]

 

  IN THE COURT OF DISTRICT & SESSION JUDGE DISTRICT SOUTH EAST, SAKET COURT, DELHI Bail Application No………….of 2021

IN THE MATTER OF: AMAN(In J.C.)

………. APPLICANT ……….  APPLICANT

VERSUS STATE (Govt.of NCT of Delhi)

……..RESPONDENT   ……..RESPONDENT P.S. LAJPAT NAGAR FIR

NO.

42/2021

Dated 14.02.2021 U/s. 307/308/324 /506/34

IPC, 1860

MEMO OF PARTIES

AMAN S/o. Sh. Manoj Through Megha (Pairokar) D/o. Sh. Manoj R/o. 60/201, jal Vihar Laj Lajpat pat Nagar Delhi

….Applicant …. Applicant

Versus State Govt. NCT of Delhi

… Respondent  Respondent  Pairokar for Applicant

Date:  Place:

Through Counsel MUKESH NARAYAN & SAHIL JAIN CHAMBER NO.421, LAWYER’S CHAMBER,  DWARKA COURTS COMPLEX, SECTOR-10, NEW DELHI-110075 M: 8168396161; 9910108137 [email protected]

 

 

IN THE COURT OF DISTRICT & SESSION JUDGE DISTRICT SOUTH EAST, SAKET COURT, DELHI Bail Application No………….of 2021

IN THE MATTER OF:

AMAN(In J.C.)

……….   APPLICANT ………. VERSUS

STATE (Govt.of NCT of Delhi)

……..RESPONDENT   ……..RESPONDENT P.S. LAJPAT NAGAR   FIR

42/2021

NO.

Dated 14.02.2021  U/s.307/308/324/506/34

IPC, 1860

SECOND REGULAR BAIL APPLICATION U/S 439 OF THE CRIMINAL PROCEDURE CODE, 1973 FOR GRANT OF

REGULAR

BAIL

APPLICANT/ACCUSED

ON

AMAN

BEHALF IN

THE

OF

ABOVE

MENTIONED FIR (IN JC SINCE 15.02.2021 i.e. ABOUT 3 MONTHS )

Most Respectfully Showeth:

1. That the abovementioned FIR got lodged against the Applicant and his relatives on 14.02.2021 and the Applicant was arrested on 15.02.02021 and since then he is in J.C.

That on

04.03.2021, first Regular Bail Application preferred by Applicant was dismissed by Hon’ble ASJ, Saket Court. That the Pairokar Pairokar Megha i.e. Sister of Abovementioned Accused Aman had applied for one Regular/Default Bail U/s 439 r/w 167(2) of the Criminal Procedure Code, 1973 and same was

 

listed on 24.05.2021 before Hon’ble ASJ, Saket Court Court.. That at the time of hearing,

the Pairokar aass w well ell as Counsel for the

Applicant came to know vide Reply of the I.O. against the said Bail Application, that the charge sheet in the above captioned FIR has already been filed on 15.05.2021 i.e. last day of  prescribed 90 days mandatory period as envisaged by Section 167(2) of the Crpc, 1973

and pursuant to w which hich the said

default bail needs to be withdrawn and the said application was disposed off as withdrawn by Hon’ble ASJ, Saket Court vide order dated 24.05.2021. That the true Copy of the abovementioned FIR and order dated 24.05.2021 has been annexed as Annexure A and Annexure B respectively. 2. That the Applicant is a law abiding and peace loving citizen of India. 3. That the Complainant in the abovementioned FIR is the relative of Applicant’s Applicant’s neighbour.  neighbour.  4. That by virtue of abovementioned FIR, Applicant has been falsely roped in the matter just to satisfy the personal grudge of Complainant brother ’s ’s family with family with Applicant’s Applicant’s relatives. relatives. 5. That the brief facts giving rise to the abovementioned FIR are that the Complainant, a resident of Sarai Kale Khan, Delhi alongwith her cousin Brother Honey went to her brother Rakesh Chaudhary’s house at Lajpat Nagar on 14.02.2021 at 14.30 hrs to celebrate her niece Tania’s birthday. It was alleged that she along with her brother and his family were sitting outside and discussing birthday party plan wherein Binni i.e. Cousin of Applicant arrived and there was alleged to have some verbal altercations in between Binni (Applicant’s (Applicant ’s Cousin) and Honey (Complainant’s (Complainant ’s Cousin). It was further

 

alleged that on hearing the sudden altercations Vishal( Applicant’s Applicant ’s Cousin), Rakesh(Applicant Rakesh(Applicant’s ’s Uncle and father of Vishal and Binni) and Applicant came out of house. It was further alleged that Vishal and Complainant were armed with knife and Rakesh was holding a stick in his hand and they all attacked Complainant, her cousin brother and her brother ’s ’s son and wife. That the abovementioned FIR was lodged against the Applicant and his relatives over the false and frivolous allegations of the Complainant. 6. That it is most humbly submitted that the Complainant Complainant’s ’s  brother and all the accused persons are neighbours as they reside in same locality as the applicant is a resident of 60/201, Jal Vihar, Lajpat Nagar, Delhi while his Uncle Rakesh alongwith his cousins Vishal and Binni all 3 are residents of 60/202,

Jal

Vihar,

Lajpat

Nagar,

Delhi

while

the

Complainant’s Complainant ’s brother Rakesh Chaudhary is a resident of 60/80, Jal Vihar, Lajpat Nagar, Delhi and the Complainant herself is a resident of T-70, Sarai Kale Khan, New Delhi. 7. That it is most humbly submitted that the Complainant has hidden, moulded and manipulated certain crucial facts and got lodged the present FIR out of ulterior motive at the behest of her brother Rakesh Chaudhary.

That it is most humbly

submitted, that Rakesh Chaudhary being a habitual drunkard and quarrelsome person is in the habit of picking up quarrels with his neighbours. That on earlier occasions also Rakesh Chaudhary had under influence of alcohol wilfully undertaken certain quarrels and has acrimonious relations with the Applicant’s Applicant ’s Uncle  Uncle  i.e. Rakesh over trivial issues but the Applicant’s Applicant ’s Uncle and his family being family being a peace loving and law

 

abiding citizens have always forgiven the Rakesh Chaudhary hoping god sense will prevail pr evail over him with time. 8. That it is most humbly submitted that on 13.02.2021 Rakesh Chaudhary just Chaudhary  just to take revenge with Applicant’s Uncle filed a false and frivolous case against Binni i. i.e. e. Applica Applicant’s nt’s cousin in the name of his daughter Tania. That on 14.02.2021 while Binni was passing by, Complainant, Honey, Rakesh chaudhary and his family who all were sitting outside their house after spotting Binni pick up a quarrel with him and started hurling vulgar and indecent abuses to him to which Binni vehemently objected. That Rakesh Chaudhary and Honey started pushing Binni threatened him to be ready to face the heat of their revenge. That thereafter Binnni asked all of them to behave in a sincere and civilised manner and not to hurl vulgar and indecent abuses. That after hearing the commotion Applicant came out of his house. That subsequently Rakesh and Vi Vishal shal also came out of the house. That the Applicant witnessed that the Complainant Complainant

and her brother Rakesh were armed with

knife and Honey and Sonia were holding lathi and were continuously threatening Binni. That when the Applicant, his uncle and his cousin tried to intervene, Com Complainant plainant and her relatives now turn towards the Applicant and his relatives resulting in scuffle/brawl which brought up on grave and sudden provocation of Complainant and her relatives. That in such altercation Applicant Uncle got a blow on his head also. That the Applicant and his relatives somehow managed to run from the scuffle and save themselves from the hands of Complainant and her brother. 9. That it is most humbly submitted that the in the said altercation/scuffle/brawl not only the Complainant or her

 

relatives  but also the Applicant’s relatives have also  also   suffered some injuries. That the said injury to the Complainant couldn’t  be imputed to have been caused by the Applicant as it was the Complainant and her relatives who were armed with knife and gave grave and sudden provocation to the Applicant and his relatives and the said injury is actually a result of scuffle which erupt between the parties on the spur of the moment. That it is most humbly submitted that as per Section 307 of the IPC, 1860 there must be knowledge and intention to cause the hurt to the victim but in the case at hand no such knowledge or intention was attributable to the Applicant as the Applicant was unarmed at the time of incident and the said injury which was inflicted on the Complainant is out of accident in the  brawl and no overt act could be attributed to the Applicant as the Complainant has falsely named the Applicant in the FIR with a malafide intention just to rope in as many relatives of opposite party as possible. 10. That the Complainant, her cousin Honey, her nephew harsh and her Sister in law Sonia all equivocally have alleged that Binni i.e. Applicant’s cousin came there and start doing Gali Galoch with them. That it is most humbly submitted that there was no mention in the present FIR that Binni and his family came there to pressurise them so that they take back complaint dated 13.02.2021 lodged at behest of Tania against Binni i.e. Applicant’s Cousin but the said improvised version of   the Complainant came came long time after lodging of present FIR as an

afterthought.

This

contradictory

stand/version

of

Complainant itself prima facie shows the malafide intention of the Complainant in falsely implicating the Applicant and his relatives.

 

 

11. That the alleged incident occurred in broad daylight but no independent witnesses are named in charge sheet as keeping in mind the dense population density of jhuggi houses which are closely packed adjacent to each other and if the said incident have otherwise occurred, other neighbours must have surely witnessed the same but not even a single independent witness have been named in list of witnesses and the present Applicant has been falsely implicated just to satisfy the Complainant’s Complainant ’s ulterior motives on the statement of Complainant and her relatives. 12. That as per the FIR at the time of incident 5 persons were  present i.e. Complainant Asha, her brother Rakesh Chaudhary, Her cousin Honey, nephew Harsh, Sister in law Sonia. That as  per FIR leave alone Rakesh Chaudhary only 4 persons have sustained injuries. That it is highly improbable that in the alleged attack only 4 members sustains injuries and that too simple one but the fifth present person escaped without any casualty and that too where the Complainant attributed the intention of Applicant and his relatives to kill them. That it is further questionable that Rakesh Chaudhary should also be made the eye witness of the incident but no single statement has been recorded by the concerned I.O. till date. This clearly shows there is no fair investigation on the part of the I.O. as totally shoddy/maladroit investigation has been carried out by the Concerned Investigation agency at the sole behest and according to whims and fancies of Complainant and her  br other’s other’s family and the present Applicant has been booked under wrong provisions totally defying the jurisprudence of fair investigation.  

{{

 

13. That the Complainant’s Complainant’s brother out of animosity has got lodged a false and frivolous complaint on behalf of his daughter Tania against Binni under Section 354 and Section 8 of POCSO Act. That

Ashia, w wife ife of Binni has also filed filed

complaint dated 10.04.2021 against Tania, her aunty Rita and other members of Rakesh Chaudhary’s family with P.S. Lajpat  Nagar and same is pending investigation wherein all the members

of

Rakesh’s

family

including

Tania

have

misbehaved, abused, quarreled and threatened Ashia to face dire consequences just to satisfy their vengeance. That the true copy of said Complaint is annexed as Annexure C. 14. That Complainant has got lodged this false and frivolous case  by implicating all the members of Applicant and his relatives and in the fit of rage just to rope in as many members possible named the Present Applicant in the FIR. 15. That it is most humbly submitted that it is a clear cut case of  planting of evidences by investigating agency under the influence of Complainant and her brother and falsely implicating the Applicant, as is evident from the trend of alleged recoveries of weapons i.e. Knives used in committal of offence vide Disclosure dated 16.02.2021 of Applicant and his cousins. That the said knives were alleged to be recovered from the pillow side of the bed of all the accused persons. That it is most humbly submitted that as per the recoveries noted by the I.O. one knife is recovered from beneath the mattress of Bed(in case of Binni), Second knife is recovered from inside the bed(in case of Vishal) and third knife is alleged to be recovered from under the bed(in case of Aman) which is alleged to be used in the commission of offence of inflicting

 

injury over the left lateral thigh of Complainant by the Applicant can by far no stretch of imagination be attributed to have

caused

by

Applicant.

That

it

is

highly

improbable/doubtfull that all the 3 knives were allegedly recovered at sole behest of disclosure m made ade by 3 Accused including the applicant. That the recovery of said knives by the I.O. from the pillow sides of bed in case of 3 accused  persons itself made the said recovery highly suspicious and further strengthen the theory of planting the evidence. 16. That section 307 of IPC, 1860 states that: There are basically 2 ingredients of Section 307 : (a)  Intention or knowledge to commit murder (b)  Act is done by accused That it is most humbly submitted that the injury as alleged to be caused by Applicant to the Complainant is on the lateral thigh of the Complainant and that too as  per her MLC is of simple nature. That by no stretch of imagination can the said injury be said to be inflicted to commit murder of the Complainant. As Hon’ble Supreme court  court  in State of Maharashtra v Balram Bama Patil (1983) 2 SCC 28 held that: “  What the Court has to see is whether the act,

irrespective of its result, was done with the intention or knowledge and under circumstances mentioned in this  section. An attempt in order to be criminal need not be the penultimate act. It is sufficient in law, if there is  present an intent coupled with some overt act in execution thereof.”  thereof.”   Also Hon’ble Supreme Court in  J age R am V s Stat State of

H ar yana yana ( 2015) 2015) 11 SCC SC C 366 366 has held that:

 

For the purpose of conviction under Section 307 IPC, the prosecution has to establish (i ( i) the intention to commit murder; and (ii (ii)) the act done by the accused. Although the nature of injury actually caused may be of assistance in coming to a finding as to the intention of the accused, such intention may also be adduced from other circumstances. The intention of the accused is to  be gathered from the circumstances like the nature of the weapon used, words used by the accused at the time of the incident, motive of the accused, parts of the body where the injury was caused and the nature of injury and severity of the blows given, etc.” etc.”   17. That it iiss most humbly submitted that the Investigative agency has filed the charge sheet against the applicant U/s 307/308/324/506/34 of the IPC, 1860 but as per the MLC of Complainant, injury inflicted is of simple in nature and  just 1 injury is alleged to be caused by the applicant to the Complainant and that too over her left lateral thigh and said Complainant had been discharged from the Hospital after a day or two. That it is further submitted that the act of inflicting simple injury over left lateral thigh of the Complainant cannot be termed as an act caused by applicant with knowledge or intention to cause the death of Complainant that warrants inviting Section 307,308,324 of the IPC, 1860. That injury is not alleged to be inflicted over the vital part of the Complainant which in remote  possibility could have caused death of the Complainant. That all the allegations levelled by the Complainant arose out of catena of cross cases/acrimony between cases/acrimony  between Applicant’s relatives and Complainant’s Complainant’s relatives. relatives. That it is further

 

submitted that act of infliction of alleged single blow that results in simple injury only could not be imputed as intention to cause death. 1. That Hon’ble Apex Court in Dataram Singh Vs. State of Uttar

P r adesh and and Ors. Or s. re r epor te ted d as MA M A N U/S U/SC /0085/ 0085/201 2018: 8: A I R  2018  20 18 SC 980 980 the Hon’ble Supreme Court held : “2. A  A  fundamental postulate of criminal jurisprudence is the presumption of innocence, meaning thereby that a  person is believed to be innocent until found guilty.  However, there are instances in our criminal law where a reverse onus has been placed on an Accused with regard to some specific offences but that is another matter and does not detract from the fundamental postulate in respect of other offences. Yet another important facet of our criminal jurisprudence is that the grant of bail is the  general Rule and putting a person in jail or in a prison or in a correction home (whichever expression one may wish to use) is an exception. Unfortunately, some of these basic  principles appear to have b been een lost sight of with the result that more and more persons are being incarcerated and  for longer periods. This does not do any good to our criminal jurisprudence or to our society.” 2.  Also in  Sa  Sanja njayy C hand handrr a v C B I M A N U/SC U/SC//1375 1375//2011 2011 :

( 2012 2012)) 1 SC SCC C 40 Hon’ble Supreme Court held : “14. In bail applications, generally, it has h as been laid down  from the earliest times that the object of bail is to secure the appearance of the accused person at his trial by reasonable amount of bail. The object of bail is neither  punitive nor preventative. Deprivation of liberty must be considered a punishment, unless it can be required to

 

ensure that an accused person will stand his trial when called upon. The courts owe more than verbal respect to the principle that punishment begins after conviction, and that every man is deemed to be innocent until duly tried and duly found guilty. From the earliest times, it was appreciated that detention in custody pending completion of trial could be a cause of great hardship. From time to time, necessity demands that some un-convicted persons  should be held in custody pending trial to secure their attendance at the trial but in such cases, 'necessity' is the operative test. In this country, it would be quite contrary to the concept of personal liberty enshrined in the Constitution that any person should be punished in respect of any matter, upon which, he has not been convicted or that in any circumstances, he should be deprived of his liberty upon only the belief that he will tamper with the witnesses if left at liberty, save in the most extraordinary circumstances. Apart from the question of prevention being the object of a refusal of bail, one must not lose  sight of the fact that any imprisonment before conviction has a substantial punitive content and it would be improper for any Court to refuse bail as a mark of disapproval of former conduct whether the accused has been convicted for it or not or to refuse bail to an unconvicted person for the purpose of giving him a taste of imprisonment as a lesson.”

18. That there is no apprehension of misuse of privilege of bail and also there are no chances of tampering with evidences or influencing the witnesses if the present Applicant be

 

released on bail as charge sheet in the matter has already  been filed f iled on 15.05.2021 and the investigation is complete in all aspects. 19. That it is most humbly submitted that the Applicant Applicant’s ’s father  being dead few years ago therefore he is the sole bread earner of his family as he has one grandfather besides one sister Megha i.e. Pairokar to look after and iin n this tim timee of Covid situation it is further causing them unnecessary hardship due to incarceration of Applicant in jail for   20.

offence which he has not committed.

[[[[[

That the Applicant has been falsely implicated in this case as he has not committed any offence as mentioned in the

21.

FIR. That it is most humbly submitted that foremost principle of Bail

jurisprudence

is

release

on

bail

if

custodial

interrogation is not necessary. That it is further submitted that charge sheet in the present matter has already been filed on 15.05.2021 and investigation is complete in all aspects therefore there is no need to put an innocent person  behind bars as it is the most important rule of  jurisprudence that everyone is innocent until proven guilty and even Apex Court has held that said presumption continues till the final disposal of Appeal. 22. That the Applicant has clean antecedents and has no previous criminal record. 23. That the Applicant undertakes to abide by all the reasonable terms and conditions imposed upon him while releasing him on bail.

 

  24. That the trial of the present FIR will take time and in this situation languishing a 26 year old sole bread earner of family in jail will unnecessary and seriously detriment the further career aspects of the Applicant.   25. That the Applicant is ready to furnish the sound surety to the [

satisfaction of this Hon’ble Court.  Court.  PRAYER :

It is most respectfully prayed that: (a) Hon’ble Court may be pleased to grant Bail U/s 439 Cr.P.C., 1973 in FIR no.: 42/2021 U/s: 307/308/324/506/34 IPC registered at P.S. Lajpat Nagar to the Applicant/accused Aman; (b) Any other/further order in the interest of justice.

Pairokar for Date: Place:

APPLICANT/ACCUSED( IN JC) Through Counsel

MUKESH NARAYAN & SAHIL JAIN CHAMBER NO.421, LAWYER’S CHAMBER,  DWARKA COURTS COMPLEX, SECTOR-10, NEW DELHI-110075

M: 8168396161; 9910108137 [email protected]

 

IN THE COURT OF DISTRICT & SESSION JUDGE DISTRICT SOUTH EAST, SAKET COURT, DELHI Bail Application No………….of 2021

IN THE MATTER OF:

AMAN(In J.C.)

……….   APPLICANT ………. VERSUS

STATE (Govt.of NCT of Delhi)

……..RESPONDENT   ……..RESPONDENT P.S. LAJPAT NAGAR   FIR

NO.

42/2021

Dated 14.02.2021 U/s.307/308/324/ 506/34

IPC, 1860

AFFIDAVIT OF PAIROKAR

I, Megha D/o Shri Manoj, aged 22 years, R/o S 60/201, Jal Viahr Camp, Lajpat Nagar S.O, South Delhi, Delhi- 110024 , presently at New Delhi, do hereby solemnly affirm and declare as under:1. 

That I am the Pairokar in the above noted case as I am the sister of the Applicant Aman and am fully conversant with the facts and circumstances of

2. 

the

case,

affidavit. That the

hence

competent

accompanying

to

swear

application

U/s

this

439

Cr.P.C., 1973 for grant of regular bail has been drafted by my counsel under my instructions, contents of the same have been read over and explained to me in vernacular, I have understood the same, I state the same to be true and correct, the same be read as part and parcel of this affidavit as the same are not being repeated herein for the sake of brevity.

 

  Deponent

Verification: Verified at New Delhi on this … … day of June, 2021, that the contents of my above affidavit are true and correct to my knowledge and belief.

Deponent

 

IN THE COURT OF DISTRICT & SESSION JUDGE DISTRICT SOUTH EAST, SAKET COURT, DELHI Misc.App. no…….. of 2021 

IN Bail Application No………….of 2021

IN THE MATTER OF:

AMAN(In J.C.)

………. APPLICANT ……….  APPLICANT VERSUS

STATE (Govt.of NCT of Delhi)

……..RESPONDENT   ……..RESPONDENT P.S. LAJPAT NAGAR   FIR

42/2021

NO.

Dated 14.02.2021 U/s. 307/308/324/506/34

IPC, 1860

APPLICATION ON BEHALF OF PAIROKAR FOR EXEMPTION FROM FILING SWORN/AFFIRMED AFFIDAVIT Most respectfully showeth: 1 .   That

the

Pairokar

is

the

sister

of

the

Applicant/Accused in the abovementioned matter and has filed the accompanying application under 439 of the Crpc, 1973 on behalf of her brother and the contents of the same may kindly be read as part and parcel of this applicati application. on.   2 .   That due to Covid-19 restrictions imposed by

Govt. of NCT of Delhi, the Pairokar is unable to file

the

sworn/Affirmed

affidavit

with

Accompanying Application.   3 .   That the Pairokar undertakes to abide by all the

conditions imposed by the Hon’ble Court.  

 

PRAYER:

(a) 

Kindly allow the Pairokar to file the present application without Affirmed/Sworn Affidavit in the interest of justice; ( b )   Any other or further order which this Hon’ble Court deems fit in the interest of justice. Date: Pairokar for Applicant

Place: Through

Counsel MUKESH NARAYAN & SAHIL JAIN CHAMBER NO.421, LAWYER’S CHAMBER,  DWARKA COURTS COMPLEX, SECTOR-10, NEW DELHI-110075

M: 8168396161; 9910108137 [email protected]

 

IN THE COURT OF DISTRICT & SESSION JUDGE DISTRICT SOUTH EAST, SAKET COURT, DELHI Misc.App. no…….. of 2021 

IN Bail Application No………….of 2021

IN THE MATTER OF:

AMAN(In J.C.)

………. APPLICANT ……….  APPLICANT VERSUS

STATE (Govt.of NCT of Delhi)

……..RESPONDENT   ……..RESPONDENT P.S. LAJPAT NAGAR   FIR

NO.

42/2021

Dated 14.02.2021  U/s.307/308/324/506/34

IPC, 1860

APPLICATION ON BEHALF OF PAIROKAR FOR EXEMPTION FROM FILING COPY OF FIRST REGULAR BAIL APPLICATION ORDER DATED 04.03.2021 Most respectfully showeth:

1 .   That

the

Pairokar

is

the

sister

of

the

Applicant/Accused in the abovementioned matter and has filed the accompanying application under 439 of the Crpc, 1973 on behalf of her brother and the contents of the same may kindly be read as part and parcel of this applicati application. on. 2 .   That the first regular bail application filed by

Applicant was dismissed by Hon’ble ASJ, Saket Court, Delhi vide order dated 04.03.2021. That said order is not available on the official website of Delhi district eCourts.  

 

3 .   That as the previous counsel is no longer in

contact with the Pairokar therefore the said order couldn’t

be

obtained

and

filed

with

this

accompanying accompanyi ng second bail applicati application. on.   4 .   That the Pairokar undertakes to abide by all the

conditions imposed by the Hon’ble Court .

PRAYER:

(a) 

Kindly allow the Pairokar to file the present application without annexing the first regular  b  baa i l a p p l i c a t i o n o r d e r d a t e d 0 4 . 0 3 . 2 0 2 1 i n t h e interest of justice; ( b )   Any other or further order which this Hon’ble Court deems fit in the interest of justice.

Date: Pairokar for Applicant

Place: Through

Counsel MUKESH NARAYAN & SAHIL JAIN CHAMBER NO.421, LAWYER’S CHAMBER,  DWARKA COURTS COMPLEX, SECTOR-10, NEW DELHI-110075

M: 8168396161; 9910108137 [email protected]

View more...

Comments

Copyright ©2017 KUPDF Inc.
SUPPORT KUPDF