Raghuvansh Bail Application

IN THE COURT OF Ld. MM, SAKET COURTS, DELHI.
BAIL APPLICATION NO. /2021
IN THE MATTER OF:-
State
Versus
RAGHUVANSHMANI SHUKLA
U/S : 376, 506,509 OF IPC
F.I.R NO.: 0111, dt. 24.02.2021
P.S. : AMBEDKAR NAGAR
APPLICATION UNDER SECTION 437 OF CR.P.C ON
BEHALF OF ACCUSED/APPLICANT-RAGHUVANSH
MANI SHUKLA FOR GRANT OF REGULAR BAIL
MOST RESPECTFULLY SHOWETH:
1. That the applicant herein the aforesaid matter has

been mistakenly implicated as an accused and is
arrested on 28.02.2021.
2. That the allegation of rape by a false promise to
marry has been made out against the present
applicant in the FIR, which is totally incorrect. A
copy of FIR has been appended hereto as
Annexure A-1.
3. That the present applicant never denied to marry
with the complainant and in fact he is always ready
to marry with the complainant.
4. That, the present FIR, is result of
miscommunication, as, the applicant went to his
hometown and in the meantime, complainant could
not established the communication with the present
applicant, she got angry and felt helpless and could
not control herself to register the present FIR.
5. That the applicant/accused is innocent and has been
involved mistakenly due to miscommunication with
the present applicant.
6. That by getting the applicant/accused arrested the
applicant has been deprived of his valuable
fundamental right of liberty by abuse of powers and
process of law.
7. That the applicant further undertakes to appear
before this Hon’ble Court or before the I.O. of the
case, as and when required or directed by this
Hon’ble Court.
8. That the applicant is the sole bread earner in the
family and because of this false case his entire
family has been subjected to all types of
harassment and torture in the society.
9. That it is submitted that the allegations made
against the applicant are false, frivolous and
vexatious and lack in the material substance. The
applicant belongs to a very reputed family in his
locality and no any other case has been registered
against him.
10. That the applicant is willing to furnish surety and

bail bonds to the satisfaction of this learned court in
case he is ordered to be released on bail. The
applicant is also willing to join the investigations
and bind himself by the terms and conditions laid
down by the law or by this Hon'ble court. It is
further submitted that the applicant is not at all
required for the investigations. However, if the
applicant is required for investigation, the
applicant/accused undertakes to be present as and
when required in accordance with the law.
11. That neither any recovery is to be effected from the

applicant nor the applicant is in a position to temper
with the prosecution evidence. The applicant will
associate with the investigation whenever required
to do so.
12. That since the FIR is result of miscommunication
and the applicant never denied to marry with the
complainant, no purpose would be served in further
keeping the applicant in jail.
PRAYER
It is therefore, most respectfully prayed that this Hon’ble
Court may graciously be pleased to:-
A. Grant regular bail to the applicant- Raghuvansh
Mani Shukla in F.I.R. No. 0111/2021 dated
24.02.2021 registered under section 376/506/509
IPC with Police Station- Ambedkar Nagar, New
Delhi, and
B. That till the decision of this application interim bail
may be granted to the applicant;
C. Pass an order or direction as this Hon’ble Court may
deem fit and proper in the interest of justice.
Filed By;- Applicant
RAGHUVANSH MANI SHUKLA
Though Counsel
Pramod Kumar
(Advocate)
323, M C Setalvad Chamber,
Supreme Court of India,
New Delhi-110001
IN THE COURT OF Ld. MM, SAKET COURTS, DELHI.
BAIL APPLICATION NO. /2021
IN THE MATTER OF:-
State
Versus
RAGHUVANSHMANI SHUKLA
U/S : 376, 506,509 OF IPC
F.I.R NO.: 0111, dt. 24.02.2021
P.S. : AMBEDKAR NAGAR
INDEX
SR.No. PARTICULARS PAGES
1 Bail Application with
Affidavit
2. Annexure A-1. True
Copy FIR
3. Vakalatnama
Filed By;- Applicant
RAGHUVANSH MANI SHUKLA
Though Counsel
Pramod Kumar
(Advocate)
323, M C Setalvad Chamber,
Supreme Court of India,
New Delhi-110001

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IN THE COURT OF Ld. MM, SAKET COURTS, DELHI.

BAIL APPLICATION NO. /2021

IN THE MATTER OF:-

U/S : 376, 506,509 OF IPC

F.I.R NO.: 0111, dt. 24.02.2021

P.S. : AMBEDKAR NAGAR

APPLICATION UNDER SECTION 437 OF CR.P.C ON

MANI SHUKLA FOR GRANT OF REGULAR BAIL

MOST RESPECTFULLY SHOWETH:

1. That the applicant herein the aforesaid matter has

10. That the applicant is willing to furnish surety and

11. That neither any recovery is to be effected from the

deem fit and proper in the interest of justice.

Filed By;- Applicant

RAGHUVANSH MANI SHUKLA

BAIL APPLICATION NO. /2021

IN THE MATTER OF:-

U/S : 376, 506,509 OF IPC

F.I.R NO.: 0111, dt. 24.02.2021

P.S. : AMBEDKAR NAGAR

SR.No. PARTICULARS PAGES

1 Bail Application with

RAGHUVANSH MANI SHUKLA

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