Exercise 1

IN THE COURT OF DISTRICT AND SESSION JUDGE,HYDERABAD

HYDERABAD DIVISION AT HYDERABAD
AT COURT NO.20, AT HYDERABAD
CRIMINAL BAIL APPLICATION NO.222/2021
IN
C.R. No. 501 of 2021

Prashant Yadav …..Applicant

Versus

STATE OF TELANGANA …Complainant

(Through Bahadurpura Police Station)

ROZNAMA

IN THE COURT OF District and SESSION JUDGE, HYDERABAD

HYDERABAD DIVISION AT HYDERABAD
AT COURT NO.20, AT HYDERABAD
CRIMINAL BAIL APPLICATION NO.222/2021
IN
C.R. No. 502 of 2021

Prasant Yadav …. Applicant

Versus

STATE OF TELANGANA
(Through Bahadurpur Police Station) …Complainant

INDEX
Sr. No Particular Page no.
1 Roznama
2 Bail Application
 3 List of Documents
4 Annexure“A” – Copy of
Aadhar Card of the
Applicant
5 Annexure- “B” Copy of FIR
date 10/9/2021)
6 Annexure“C” Copy of
Chargesheet)

7 AFFIDAVIT
8 VERIFICATION
9 VAKALATNAMA

Advocate for Applicant

IN THE COURT OF District and SESSION JUDGE, HYDERABAD.

HYDERABAD DIVISION AT HYDERABAD
AT COURT NO.20, AT HYDERABAD
CRIMINAL BAIL APPLICATION NO. 222/2021
IN
C.R. No. 502 of 2021

Prashant Yadav } …Applicant

16-4-30/1, Warangal - Fort Rd, }
Mandal, Warangal, }
Telangana 506002 }

Versus

STATE OF TELANGANA Thru }

Central Unit, Crime Branch, }
Hyderabad, Thru }
(Bahadurpur Police Station) ....Complainant

APPLICATION FOR BAIL U/S 437 OF CRI. PROC. CODE. for

Offence U/s. 302,34,120B,(ON BEHALF OF THE ACCUSED
 (Prashant Yadav, S/O- RAMDHESHWAR YADAV, R/O-
MANDAL, WARANGAL)

MOST RESPECTFULLY SUBMITTED AS UNDER:

On behalf of Applicant/ Org. Accused, I beg to state and submit on solemn affirmation as under:-

1.The Applicant approach this Hon’Ble Court with the prayer that this Hon’Ble Court may be
pleased to exercised its jurisdiction under section 437 of Cr.P.C. and this Hon’Ble court may be
pleased to release the Applicant above named on bail on any suitable terms and conditions, as
this Hon’Ble Court may deem fit and proper after taking into consideration the fact and
surrounding circumstances of the case in hand.

2..That the present FIR has been registered under false and bogus facts. The facts stated in the
FIR are fabricated, concocted and manipulated.

3.That the police have falsely implicated the applicant, The Applicants reside at the address
mentioned hereinabove at the cause title. The Applicant hails from a respectable family having
deep roots in society and he has no criminal antecedents.(Here annexed and marked as
Annexure– “A” is the copy of the Aadhar Card of the Applicant.)

PROSECUTION STORY IN BRIEF IS AS FOLLOWS:-

4.That the Complaint i.e., C.R. No. 502/2021 came to be registered at Bahadurpur Police Station
on 12th October 2021 against the Applicant for the offence punishable U/s 302, 34 and 120B of
the Indian Penal Code at the instances of the Complainant namely Police Constable Rupesh
Waghmare of Bahadurpur Police Station. (Hereto is annexed and marked as Annexure– “B” is
the copy of the FIR dated 10/9/2021).
5.The Applicant was arrested on 12th October 2021 and is presently in Judicial Custody.
6.The Investigation Officer (“IO”) of this instant case filed chargesheet against the applicant for
the offence punishable under section 302, 34, 120B of the Indian Penal Code (Here to annex
and marked as Annexure– “C” is the copy of Chargesheet).
7.As per the chargesheet, Ramesh and Swathi are in love and they wanted to get married but
they do not belong to the same caste. Swathi was the Daughter of (Accused 1) both wanted to get
married but their families were against marriage. However, on 08/04/2015 the couple got married
against their parents wishes and escaped the confines of their small town of warangal to
hyderabad after several years later, Swathi called her parents to their new home in Hyderabad.
On the next day, her father Accused 1 and Accused 2 visited them in Hyderabad in an apparent
reconciliation. While they were having a conversation, her father, Accused No. 1 took out a gun
and shot both of them, leaving them dead on the spot. Hence, police have registered an F.I.R
against both the accused.
5.That the Applicant accused therefore most respectfully submits that Bail may be granted to
him on terms and conditions as the Hon’ble Court deems fit and proper as the investigation is
complete and no further custody is required and the interest of the parties will not be prejudiced
as the Sections applied are not applicable to the present cases and on perusal of the entire FIR the
Applicant has got no role play and nothing remains to be investigated and nothing has to be
recovered.
6.Being aggrieved the Applicant has approached this Honorable Court seeking bail in connection
with the offences registered under F.I.R No. 502 of 2021 punishable U/s 302, 34 and 120B of the
Indian Penal Code on the following amongst other grounds which may be urged at the time of
hearing of this application. The grounds are set forth without prejudice to one another.

GROUNDS
1.The Applicant Accused is a PHD holder and professor at Kalsekar college in their village.
2.The Applicant Accused family has an excellent reputation in their village.
3.The Applicant Accused has never fought with anyone or done any mischief and does not have
any criminal record.
4.The Applicant Accused is suffering from a very rare disease. This disease can be cured only.
The City hospital, which is in Delhi, and no other hospital has special equipment and means to
cure this disease.
5.That the Applicant/Accused have a fixed place of residence and have roots in the society and
therefore shall not abscond in the event of granting bail to him.
6.That the Applicant is a reputed citizen and in the event of further delay in getting bail would
tarnish his image further in the eyes of society.

Legal Submission

1. It is submitted that the Accused has already spent 50 days in judicial custody.
Hence, by imposing reasonable conditions, the Applicant may be granted bail.

2.The Applicant is PHD holder and professor in college and has a clean record and
is not named as an accused in any other case. The Applicant is suffering from a
very rare disease and required proper treatment in a Delhi AIIMS hospital. The
Applicant has maintained good behaviour in jail and no complaint about his
conduct has been made.

3. The Applicant has been suffering from a very rare disease since 2016 and
requires further treatment and therefore, would face tremendous hardships if he
was sent to custody. (Here to annex a market as Exhibit – “D” is the copy of the
Medical Report of the Applicant). The Applicant undertakes that he will not
either directly or indirectly make any inducements, threats or promises to any
person who is a witness in the case so as to dissuade them from disclosing such
facts to the Hon’ble Court or to any other investigation authority or tamper with or
destroy any evidence.

4.It is humbly submitted that the Applicant is a permanent residence of the

aforesaid locality and has deep roots in society and that is no chance of her
absconding or evading bail.

5.It is further submitted that the Accused will abide by any condition imposed on
him by this Hon’ble Court and undertakes to present himself before the Court as
and when directed.

6.That the Applicant is ready and willing to furnish to the satisfaction of this
Hon’ble Court at the time of granting bail by this Hon’ble Court by exercising
powers vested with this Hon'ble Court under Section 439 of Code of Criminal
Procedure.

7.That this petition is made bona fide for the ends of justice. No prejudice would
be caused to the Investigation Agency if the present Petition is not allowed.
However, grave prejudice would be caused if the present petition is not allowed.

8.The Applicant reserves the right to raise additional grounds and address
additional arguments at the stage of oral arguments.

PRAYER

In the Circumstances stated hereinabove the Applicant/Accused prays that :-

A.That he be granted bail on the terms and conditions as the Hon’ble Court deems fit and proper.

B.Any other order by the Hon’ble Court in the interest of Justice be granted to the
Applicant/Accused.

C.Accused be granted Cash Bail in lieu of Surety.

 For this Act of Kindness the Applicants are always obligated to pray.

Place: APPLICANT

Date: THROUGH

COUNSEL

IN THE COURT OF DISTRICT AND SESSION JUDGE,HYDERABAD

HYDERABAD DIVISION AT HYDERABAD
AT COURT NO.20, AT HYDERABAD
CRIMINAL BAIL APPLICATION NO.222/2021
IN
C.R. No. 501 of 2021

Prashant Yadav …..Applicant

Versus

STATE OF TELANGANA …Complainant

(Through Bahadurpura Police Station)

AFFIDAVIT

I, Prashant Yadav , s/o Rameshwar Yadav, r/o mandal walangar, aged about 46 years, do hereby
solemnly affirm and declare:

1.That I am the Petitioner in the instant case and I am competent to depose to the contents of the
present affidavit.
 2.That the accompanying Petition has been drafted by the counsel under my instructions. I have
read through the same and state that the contents thereof are through to my knowledge

3. The Annexures to the Accompanying Petition are true copies of the original.

Deponent

VERIFICATION

Verified at Hyderabad, on this 30th of December 2021, that the contents of the foregoing
affidavit are true and correct to my knowledge, no part of it false and nothing material has been
concealed therefrom.

Deponent

Exercise-2

IN THE COURT OF LD. SESSION JUDGE,HIMACHAL PRADESH

ANTICIPATORY BAIL APPLICATION NO. 153 OF 2021

IN THE MATTER OF:

Mrs. Leena Rawat …..APPLICANT

VERSUS

STATE OF HIMACHAL PRADESH ……INVESTIGATING AGENCY

(Through Chirgaon Police Station)

ROZNAMA
 IN THE COURT OF LD. SESSION JUDGE,HIMACHAL PRADESH
ANTICIPATORY BAIL APPLICATION NO. 153 OF 2021

IN THE MATTER OF:

Mrs. Leena Rawat

…..APPLICANT
VERSUS

STATE OF HIMACHAL PRADESH ……INVESTIGATING AGENCY

(Through Chirgaon Police Station)

INDEX
Sr. No Particulars Page no.
1 Roznama
2 Anticipatory Bail
Application
3 List of Documents
4 Exhibit – “A” is the copy
of Aadhar Card of
Applicant
5 Exhibit – “B” is the copy
of FIR.
6 Exhibit – “C” .is the copy
of FIR.of Accused 1

7 Verification
8 Vakalatnama

Advocate for Applicant

IN THE COURT OF LD. SESSION JUDGE,HIMACHAL PRADESH

ANTICIPATORY BAIL APPLICATION NO. 153 OF 2021

IN THE MATTER OF:

Mrs. Leena Rawat }
Jethalal Kumbhar Nagar } ... APPLICANT
Nr. Rakhial Post office, }
Himachal Pradesh 174103

VERSUS

STATE OF HIMACHAL PRADESH } ..INVESTIGATING AGENCY

Central Unit, Branch, Shimla }
(Through Chirgaon Police Station) }

FIR No: 243 of 2021

U/S 186, 189, 224, 225, 323, 352 AND 427 OF ipc, 1860

APPLICATION UNDER SECTION 438 OF THE CODE OF CRIMINAL PROCEDURE,

1973 ON BEHALF OF ACCUSED MRS. LEENA RAWAT SEEKING
PRE-ARREST/ANTICIPATORY BAIL WITH APPROPRIATE DIRECTIONS TO
INVESTIGATING OFFICER/ARRESTING OFFICER IN CASE FIR NO.243 OF 2021,
Chirgaon Police Station Himachal Pradesh , TO RELEASE APPLICANT ON BAIL IN
THE EVENT OF THEIR ARREST IN THE SAID CASE

MOST RESPECTFULLY SHOWETH:-

On behalf of Applicant/ Org. Accused I beg to state and submit on solemn affirmation as under:-

1. Applicant has approached this Court under Section 438 Criminal Procedure Code, seeking
anticipatory bail apprehending her arrest in case FIR No.243 of 2021, dated 20.09.2021,
registered in Police Station Chirgaon Himachal Pradesh under Sections 186,189,224,225,323,353
and 427 of the Indian Penal Code.

2.The Applicant resides at the address mentioned hereinabove at the cause title. The Applicant
hails from a respectable family having deep roots in society. (Here annexed and marked as
Annexure – “A” is the copy of the Aadhar Card of the Applicant).

3. The Applicant states that C.R. No.243 of 2021 came to be lodged at the Himachal Pradesh
Police Station, against the Applicant/Accused no. 2 on 20th November 2021 for alleged offences
punishable u/s 186,189,224,225,323,353 and 427 of Indian Penal Code at the instance of
complainant. (Here annexed and marked as Annexed – “B” is the copy of FIR.)

4.The Applicant states that On 15th Nov 2021, the police of Himachal Pradesh had registered
an FIR against Accused No. 1 and arrested him on charges of abetting the suicide of a woman
and her friend, along with charges of other relevant offences. (Here annexed and marked as
Annexed – “C” is the copy of FIR.)
5. THE PROSECUTION STORY IN BRIEF IS AS FOLLOWS:-

a.That the complaint i.e C.R.No. 243 came to be lodged against the applicants punishable U/s
186,189,224,225,323,353 and 427 of The Indian Penal Code 1860 at the instance of Mrs. Leena
Rawat on 20rd November 2021 at Chirgaon , Himachal Pradesh Police Station.

b. It is the case of the complainant Mrs. Leena Rawat(Accused no.2 ), who is a social worker
and the wife of Mr. Lakhan Rawat(Accused no.1),who is an ex-IPS officer. On 15.09.2021, the
police of Himachal Pradesh had registered an FIR against Mr. Lakhan (Accused no. 1) and
arrested him on charges of abetting the suicide of a woman and her friend, along with charges of
other relevant offences. After the arrest on 20.09.2021, Mr. Lakhan(Accused no. 1 ) was
remanded to Judicial Custody by the Court on 21.09.2021.

c. It is the case of the complainant that On 20.09.2021, while the police were at the residence of
the Rawat’s to arrest Mr. Lakhan,(Accused no.1) Mrs. Rawat(Accused no. 2) tried to resist her
husband’s arrest. The police registered an FIR for allegedly assaulting police officers and
obstructing Government work when police went to arrest Mr. Rawat(Accused no. 1) on charges
of abetting the suicide of a woman and her friend.

d. It is the case of the complainant that The FIR was registered on 20.09.2021 with charges under
sections 186, 189, 224,225, 323, 353, and 427 of IPC, 1860. The police officers in the FIR
alleged that when the police team was at the residence of the Rawat’s to arrest Mr. Rawat, Mrs.
Rawat became aggressive and tried to resist the arrest. It has also been alleged that during the
course, she injured the cops and also caused damage to the nameplate and whistle cord of the
informant and damaged spectacles of the SHO.

6. It is submitted that the FIR lodged by the complainant is absolutely false and concocted.

7.It is submitted that the custodial interrogation of the Applicants is not required and therefore,
there is no occasion to arrest the Applicants.

7.In the aforesaid circumstances, the applicant files this application for Anticipatory Bail u/s. 438
of Cr. P.C. and submit that on the following amongst other grounds which are without prejudice
to each other the Applicant may be granted Anticipatory bail.

GROUNDS
a. The Applicant/Accused is a respectable citizen of the society.
b.That the FIR in question has been registered in a clandestine manner, and it is intended to
falsely implicate the Applicant/Accused, as well as her husband, for their bonafide actions in the
recent past.

c.That Applicants/Accused are being targeted for their actions aimed at ensuring transparency
and accountability of highly placed officers of the State, whose improprieties are impacting
public interest at large.

d.That the police team had forcibly entered the Applicants/Accused house, and had dragged the
Applicant husband out of his house, beating him with fist-blows while constantly hurling abuses
at him.

E. The Applicant/Accused kept on asking the reason for her Husband’s arrest and sought a copy
of the FIR, but the same was refused and the police took away Applicant/Accused husband
forcibly dumping him in the SUV of the Police.

f.That Applicant/Accused have two children aged 12 and 10 years and have no one else to look
after them.

g. That Applicant/Accused is the face of several ongoing campaigning projects and is not a flight
risk.

PRAYER

In the Circumstances stated hereinabove the Applicant/Accused prays that this Hon’ble Court
may be pleased to:

A.Direct the Investigating Officer/Arresting Officer in case FIR no. 243 of 2021,filed at the
Police Station of Himachal Pradesh under Section.186, 189, 224,225, 323, 353, and 427 of IPC,
1860 to release the Applicant on Bail in the event of the arrest on such terms and condition as
this Hon’ble Court may direct; and

B.Pass the order as this Hon’ble Court deems fit.

For this Act of Kindness the Applicants are always obligated to pray.

Applicant

Through

Advocate

VERIFICATION
I the Applicant abovenamed (1)Mrs. Leena Rawat aged 44 Years an Individual Indian Inhabitant,
residing at the address mentioned in the Cause Title do hereby solemnly affirms that whatsoever
stated in the foregoing paragraphs are true and correct

Advocate for Applicant Applicant

Dated this 31st day of Dec ,2021