Bail Petition

IN THE HIGH COURT OF JUDICATURE FOR RAJASTHAN
AT JAIPUR BENCH JAIPUR
S.B. CRIMINAL MISC. BAIL APPLICATION NO. /2018
Mr. KRISHNA & ANR
VERSUS
STATE OF RAJASTHAN
INDEX
SR. NO. PARTICULARS PAGE NO.
1. BAIL APPLICATION U/S 439 CR.P.C
2. COPY OF F.I.R. NO. 525/2018
3. CERTIFIED COPY OF ORDER

DATED 31.01.2019
JAIPUR :
DATED :
COUNSEL FOR PETITIONERS

IN THE COURT OF JUDICATURE FOR RAJASTHAN
S.B. CRIMINAL MISC. BAIL APPLICATION NO. / 2019
MR. KRISHNA & ANR
VERSUS
STATE OF RAJASTHAN
SYNOPSIS
 That petitioner came to be arrested on 27.01.2019 in case of
F.I.R. No. 525/2018 registered at Police Station Bansur, District
Alwar on 29.10.2018 for offence under section 143, 451, 384, 34
of IPC regarding an incident that took place on 29.10.2018, on
the written report of complainant Hazari Lal which is being
submitted herewith. On the aforesaid report a case of F.I.R. No.

525/2018 for the offence under section 143, 451, 384, 34 of IPC
has been initiated.
 That the investigation is still going on and the charge sheet has
not been presented till now.
 That the petitioner is nowhere involved in the case as there is no
mention of him in the F.I.R. also.
 That the petition has been falsely implicated in this matter and he
is not required for any investigational.
 That the petitioner moved before the Court Of Additional
Session Judge, Bansur, District Alwar under provision of Section
439 Cr.P.C which was declined under order dated 31.01.2019.
 Hence this bail application is being filed by the petitioner.
COUNSEL FOR THE PETITIONER

IN THE HIGH COURT OF JUDICATURE FOR RAJASTHAN
S.B. CRIMINAL MISC. BAIL AAPLICATION NO.-----/2018
Mr. Krishna Gujjar S/O Shri Ramkaran Gujjar, by caste Gujjar, resident of
Dungariya, Tehsil and Police Station Bansur District Alwar.(At present
languishing in Central Jail, Alwar)
… ACCUSED-PETITIONER
VERSUS
THE STATE OF RAJASTHAN THROUGH P.P
… RESPONDENT
S.B. CRIMINAL MISC. BAIL APPLICATION UNDER
SECTION 439 CR.P.C. IN THE MATTER OF F.I.R. NO.
525/2018 REGISTERED AT POLICE STATION BANSUR,
DISTRICT ALWAR FOR THE OFFENCE UNDER SECTION
143, 451,384,34 I.P.C. ( LEARNED MANISH BHATNAGAR,
R.H.J.S. ADDITIONAL AND SESSION JUDGE, BANSUR
DISTRICT ALWAR DECLINED BAIL TO THE PETITIONER
UNDER ORDER DATED 31.01.2019.
TO
THE HON’BLE CHIEF JUSTICE AND HIS COMPANION
JUDGES OF THE HIGH COURT OF JUDICATURE FOR
RAJASTHAN AT JAIPUR BENCH, JAIPUR.
MAY IT PLEASE YOUR LORDSHIPS,
The humble accused-petitioner most respectfully submits
as under:
1. That the petitioners are persons having good repute in their locality and
they have not any conviction to their discredit.

2. That petitioner came to be arrested on 27.01.2019 in case of F.I.R. No.
525/2018 registered at Police Station Bansur, District Alwar on
29.10.2018 for offence under section 143, 451, 384, 34 of IPC
regarding an incident that took place on 29.10.2018, on the written
report of complainant Hazari Lal which is being submitted herewith.
On the aforesaid report a case of F.I.R. No. 525/2018 for the
offence under section 143, 451, 384, 34 of IPC has been initiated.
3. That the investigation is still going on and the charge sheet has not
been presented till now.
4. That the petitioner is nowhere involved in the case as there is no
mention of him in the F.I.R. also.
5. That the petition has been falsely implicated in this matter and he is
not required for any investigational.
6. That the petitioner moved before the Court Of Additional Session
Judge, Bansur, District Alwar under provision of Section 439 Cr.P.C
which was declined under order dated 31.01.2019.
7. That being aggrieved with the aforesaid situation this application
seeking bail in terms of the provision of Section 439 Cr.P.C. is being
preferred interalia on the following grounds

GROUNDS
A. That the petitioners have not committed any offence punishable with
death or life imprisonment.
B. That the petitioner are entitled for bail in view of the fact that he has
been falsely implicated in the case as in F.I.R. No. 525/2018 which
was registered on 29.10.2018 at Police Station Bansur District Alwar
under section 143, 451, 384, 34 of IPC the is no mention of petitioner
by the complainant.
C. That the petitioners are languishing in jail since 27.01.2019
continuously. No purpose would be solved to detain the petitioner in
custody for unlimited period because he is not main accused of the
case. Therefore, the petitioner is entitled to be released on bail.
D. That the petitioner have been falsely implicated in this criminal case
simply to harass his. Hence the petitioners are entitled to be released
on bail.
E. That there is no likelihood of the applicant felling from justice or
otherwise interfering with the investigation or proceedings of the case.
The petitioner is not likely to abscond, if enlarged on bail.
F. That the applicant is prepared and ready to furnish bail and surety
bonds to the entire satisfaction of this Hon’ble Court and also abide by
the conditions if any imposed by the Hon’ble Court.

G. That other grounds will be urged at the time of arguments.
PRAYER
It is, therefore, most humbly prayed that your Lordship may graciously
be pleased to accept and allow this bail application and may further be
pleased to release the petitioners on bail in the case of F.I.R. No.
525/2018 registered at Police Station Bansur, District Alwar.
JAIPUR:
DATED:
HUMBLE PETITIONER
THROUGH COUNSEL:
(KOUSHAL BHARDWAJ)
ADVOCATE
Notes :
1. That no bail application has been filed prior to it.
2. A copy of this has been given to P.P.
3. Pie- Paper are not readily available hence typed on stout paper.
4. This Misc. bail application has been typed by my steno who is not
the employee of the High Court.

5. That the matter pertains to the jurisdiction of Hon’ble Rajasthan
High Court, Jaipur Bench, Jaipur.
COUNSEL FOR PETITIONERS

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IN THE HIGH COURT OF JUDICATURE FOR RAJASTHAN

AT JAIPUR BENCH JAIPUR

S.B. CRIMINAL MISC. BAIL APPLICATION NO. /2018

Mr. KRISHNA & ANR

SR. NO. PARTICULARS PAGE NO.

1. BAIL APPLICATION U/S 439 CR.P.C

2. COPY OF F.I.R. NO. 525/2018

3. CERTIFIED COPY OF ORDER

COUNSEL FOR PETITIONERS

AT JAIPUR BENCH JAIPUR

S.B. CRIMINAL MISC. BAIL APPLICATION NO. / 2019

MR. KRISHNA & ANR

 That petitioner came to be arrested on 27.01.2019 in case of

F.I.R. No. 525/2018 registered at Police Station Bansur, District

Alwar on 29.10.2018 for offence under section 143, 451, 384, 34

of IPC regarding an incident that took place on 29.10.2018, on

the written report of complainant Hazari Lal which is being

submitted herewith. On the aforesaid report a case of F.I.R. No.

has been initiated.

not been presented till now.

 That the petitioner is nowhere involved in the case as there is no

mention of him in the F.I.R. also.

is not required for any investigational.

 That the petitioner moved before the Court Of Additional

Session Judge, Bansur, District Alwar under provision of Section

439 Cr.P.C which was declined under order dated 31.01.2019.

 Hence this bail application is being filed by the petitioner.

COUNSEL FOR THE PETITIONER

AT JAIPUR BENCH JAIPUR

S.B. CRIMINAL MISC. BAIL AAPLICATION NO.-----/2018

Dungariya, Tehsil and Police Station Bansur District Alwar.(At present

languishing in Central Jail, Alwar)

THE STATE OF RAJASTHAN THROUGH P.P

SECTION 439 CR.P.C. IN THE MATTER OF F.I.R. NO.

525/2018 REGISTERED AT POLICE STATION BANSUR,

DISTRICT ALWAR FOR THE OFFENCE UNDER SECTION

143, 451,384,34 I.P.C. ( LEARNED MANISH BHATNAGAR,

R.H.J.S. ADDITIONAL AND SESSION JUDGE, BANSUR

DISTRICT ALWAR DECLINED BAIL TO THE PETITIONER

UNDER ORDER DATED 31.01.2019.

THE HON’BLE CHIEF JUSTICE AND HIS COMPANION

JUDGES OF THE HIGH COURT OF JUDICATURE FOR

RAJASTHAN AT JAIPUR BENCH, JAIPUR.

MAY IT PLEASE YOUR LORDSHIPS,

The humble accused-petitioner most respectfully submits

they have not any conviction to their discredit.

525/2018 registered at Police Station Bansur, District Alwar on

29.10.2018 for offence under section 143, 451, 384, 34 of IPC

regarding an incident that took place on 29.10.2018, on the written

report of complainant Hazari Lal which is being submitted herewith.

On the aforesaid report a case of F.I.R. No. 525/2018 for the

been presented till now.

4. That the petitioner is nowhere involved in the case as there is no

mention of him in the F.I.R. also.

not required for any investigational.

6. That the petitioner moved before the Court Of Additional Session

Judge, Bansur, District Alwar under provision of Section 439 Cr.P.C

which was declined under order dated 31.01.2019.

7. That being aggrieved with the aforesaid situation this application