IN THE COURT OF LD. CMM, PATIALA HOUSE COURT, NEW DELHI
FIR Number: 82/2021 U/S: 14 FOREIGNERS ACT ,1946 Police Station: SPECIAL CELL Date of Arrest: 20/03/2021 IN THE MATTER OF: NALAUZZE SHAKIRA
…………….PETITIONER VS
STATE
…………….RESPONDENT
I N D E X ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ SL.NO. PARTICULARS C.FEES PAGES ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 1.
MEMO OF PARTIES
2.
APPLI PPLICA CATI TION ON U/S U/S 44 445 CR CRPC ON BE BEHALF HALF OF THE ABOVE- NAMED PETITIONER TO ALLOW FOR CASH SURETY INSTEAD OF LOCAL SURETY FOR HIS RELEASE FROM JAIL.
3.
LIST LIST OF DOCU DOCUME MENT NTS S ALON ALONG G WITH WITH DOCU DOCUME MENT NTS. S.
ANNEXURE A
4.
COPY OF BAIL ORDER DATED 29.06.2021 PASSED BY SH. PANKAJ SHARMA, CMM PATIALA HOUSE COURT, NEW DELHI IN THE FIR NO. 82/2021, P.S.-SPECIAL CELL. 5.
ANNEXURE B COPY OF JUDGEMENT IN THE MATTER OF “ZORO
DANIEL Vs STATE” PASSED BY HON’BLE HIGH COURT OF DELHI ON 22.02.2012. 06.
VAKALATNAMA ON RECORD.
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
NEW DELHI DATED: 19.07.2021
FILED BY:
ADV. S.S. AGGARWAL ENROL.NO. D-2107/18 CHAMBER NO. 476, PATIALA HOUSE COURT, NEW DELHI-11000 DELHI-110001. 1. MOB: - 9810415987 Email:
[email protected]
IN THE COURT OF LD. CMM, PATIALA HOUSE COURT, NEW DELHI
FIR Number: 82/2021 U/S: 14 FOREIGNERS ACT ,1946 Police Station: SPECIAL CELL Date of Arrest: 20/03/2021 IN THE MATTER OF: NALAUZZE SHAKIRA
…………….PETITIONER VS
STATE
…………….RESPONDENT
MEMO OF PARTIES ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ NALAUZZE SHAKIRA
D/O MOHAMMAD R/O MENGO CITY, UGANDA, ALSO, AT FLAT NO.2, DHANI RAM COLONY MAIDANGARHI, DELHI
…………………PETITIONER Versus
STATE …………………….RESPONDENT ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ IN J.C.
NEW DELHI
PETITIONER
DATED: 19.07.2021
THROUGH: S.S. AGGARWAL (ADVOCATE)
IN THE COURT OF LD. CMM, PATIALA HOUSE COURT, NEW DELHI
FIR Number: 82/2021 U/S: 14 FOREIGNERS ACT ,1946 Police Station: SPECIAL CELL Date of Arrest: 20/03/2021 IN THE MATTER OF: NALAUZZE SHAKIRA
…………….PETITIONER VS
STATE
…………….RESPONDENT
APPLICATION U/S 445 CRPC ON ON BEHALF OF THE ABOVE NAMED PETITIONER TO ALLOW FOR CASH SURETY INSTEAD OF LOCAL SURETY FOR HIS RELEASE FROM JAIL.
MOST RESPECTFULLY SHOWETH: -
1. That in the above-mentioned case the petitioner / Accused was granted bail on 29.06.2021 by the Hon’ble court and was directed to furnish personal bond of Rs 25000/- along with one local surety of the like amount.
2. That the petitioner is a foreign national, and has tried his best to arrange one local surety for his release from jail.
3. In th this is Ep Epid idem emic ic, ,
no
In Indi dian an
pe pers rson on
is
re read ady y
to
stand as a surety for the applicant otherwise also he ha has s
no fr frie iend nd an and d
re rela lati tive ve in In Indi dia a
wh who o
ca can n
stand as Surety for him before the Hon’ble court.
4. That he has not been able to find any surety till date, hence he is unnecessarily suffering in jail for the want of one local surety.
5. Th That at
th the e
Ho Hon’ n’bl ble e
co cour urt t
ha has s
al allo lowe wed d
th the e
fo fore reig ign n
national to furnish cash surety instead of local sure su rety ty on peti pe titi tion oner er
th the e
pr prev evio ious us
pr pray ays s
oc occa casi sion ons s
to th this is
Ho Hon’ n’bl ble e
to too. o. He Henc nce e Co Cour urt t
to
th the e
al allo low w
him to furnish cash surety instead of local surety for procuring his release from jail. As he is not able to arrange for the same.
PRAYER: In view of the above stated facts and circumstances it is most respectfully prayed that this Hon’ble Court may be pleased to
a). Al Allo low w
th the e
ab abov ovee-me ment ntio ione ned d
ap appl plic icat atio ion n
U/ U/s s
44 445 5
Cr.P.C. and grant permission to the petitioner to file cash surety instead of local surety for his release from jail.
b). Pass any other such order as this Hon’ble court may deem de em
fi fit t
an and d
pr prop oper er
in
th the e
in inte tere rest st
of
ju just stic ice. e.
It is prayed accordingly.
NEW DELHI DATED: 19.07.2021
PETITIONER THROUGH
S.S AGGARWAL (ADVOCATE)
IN THE COURT OF LD. CMM, PATIALA HOUSE COURT, NEW DELHI
FIR Number: 82/2021 U/S: 14 FOREIGNERS ACT ,1946 Police Station: SPECIAL CELL Date of Arrest: 20/03/2021 IN THE MATTER OF: NALAUZZE SHAKIRA
…………….PETITIONER VS
STATE
…………….RESPONDENT
LIST OF DOCUMENTS
1.
ANNEXURE A COPY OF BAIL ORDER DATED 29.06.2021 PASSED BY SH. PANKAJ SHARMA, CMM PATIALA HOUSE COURT, NEW DELHI IN THE FIR NO. 82/2021, P.S.-SPECIAL CELL.
2.
ANNEXURE B COPY OF JUDGEMENT IN THE MATTER OF “ZORO
DANIEL Vs STATE” PASSED BY HON’BLE HIGH COURT OF DELHI ON 22.02.2012.
NEW DELHI DATED: 19.07.2021
PETITIONER THROUGH
S.S AGGARWAL (ADVOCATE)
