Rajpal Kasana & Associates Chamber No. 618, Lawyers Block Saket Court, New Delhi CONTACT NO. 9319105989

IN THE COURT OF LD.
DISTRICT & SESSION’S JUDGE, SOUTH

DISTRICT, SAKET COURT, NEW DELHI
In the matter of:
STATE VS AKASH @ BHURA

FIR No: 595/21
U/s: 394/34 IPC
PS: AMBEDKAR NAGAR
Accused in JC since 23.11.2021
URGENT HEARING OF BAIL APPLICATION UNDER SECTION 439

CR.P.C FOR GRANT OF REGULAR BAIL BEHALF OF
APPLICANT/ACCUSED NAMELY AKASH @ BHURA
Most Respectfully Showeth;
1. That the applicant/accused was arrested on 22.11.2021 and is in JC since
23.11.2021 and needs urgent hearing of bail application for grant of regular bail
under section 439 Cr.P.C.
2. That the applicant/accused is innocent and his bail application needs to be heard
urgently.
PRAYER:
It is most respectfully prayed before this Hon’ble Court to consider the bail applica-
tion on behalf of the applicant/accused in the interest of justice.
New Delhi Applicant/ Accused

Dated: (IN JC)
Through:
RAJPAL KASANA & ASSOCIATES
EMAIL: [email protected]
Chamber No. 618 , Lawyers Block
Saket Court, New Delhi
CONTACT NO. 9319105989
IN THE COURT OF LD. DISTRICT & SESSION’S JUDGE,
SOUTH DISTRICT, SAKET COURTS, NEW DELHI
In the matter of:

FIR No: 595/21
U/s: 394/34 IPC
PS: AMBEDKAR NAGAR
INDEX
S.No. Particulars Page no.
1. Bail applications under section 439

CRPC for regular bail
2. Copy Of FIR
3. Copy of Order of Ld. Duty MM dated

23.11.2021
4. Dismissed Anticipatory Bail order of

applicant/accused dated 10.11.2021
5 Bail order of main accused Rajkumar

@ Saurabh dated 02.11.2021
New Delhi Applicant/ Accused

Dated: (IN JC)
Through:
ADVOCATE
Chamber No. 618 , Lawyers Block
CONTECT NO. 9319105989
IN THE COURT OF LD. DISTRICT & SESSION’S JUDGE,
SOUTH DISTRICT, SAKET COURTS, NEW DELHI
In the matter of:

FIR No: 595/21
U/S: 394/34 IPC
PS: AMBEDKAR NAGAR
BAIL APPLICATION UNDER SECTION 439 CR.P.C FOR GRANT OF

REGULAR BAIL ON BEHALF OF APPLICANT/ACCUSED NAMELY
AKASH @ BHURA.
MOST RESPECTFULLY SHOWETH:

1. That the applicant/accused was arrested in the present FIR on
22.11.2021 . Copy of the FIR is annexed herein as Annexure-A.
2. That the applicant/accused was produced before the Court of Smt. Neha
Barupal , Ld. Duty MM, South, Saket Court on 23.11.2021 from where
he was sent to judicial custody and has been in the same since 23.11.2021
for the present case. Copy of the order is annexed herein as Annexure-B.
3. That the anticipatory bail of the applicant/accused was dismissed as with-
drawn on 10.11.2021 by the Hon’ble Court of Sh. Sandeep Yadav, Ld.
ASJ, South, Saket Court, New Delhi. Copy of the bail order is annexed
herein as Annexure-C.
4. That the main accused in the present FIR Rajkumar @ Saurabh has been
granted bail on 02.11.2021 by the court of Sh. Sandeep Yadav, Ld. ASJ,
South, Saket Court, New Delhi. Copy of the bail order is annexed herein
as Annexure-D.
5. That the applicant/accused prays before this Hon’ble Court for grant of
regular bail on the following grounds amongst others:
GROUNDS
A. BECAUSE the present FIR was registered on completely false,
concocted and bogus facts and the applicant/accused has been
falsely implicated in a false and vexatious FIR.
B. BECAUSE there is an unexplainable delay of more than 2 days in
lodging of the FIR which clearly shows that the present FIR is a
product of well conserved afterthought of the complainant.
C. BECAUSE the fact, that the complainant refused to give his
statement to the police on the day of the alleged incident and did
not even disclose the names of the persons involved in the alleged
incident, supports the view that the present FIR is the brainchild
of the complainant and has been lodged by the complainant for
the sole purpose of harassing, intimidating and falsely accusing
the applicant.
D. BECAUSE the main accused in the present FIR, Rajkumar @
Saurabh has been granted bail by the court of Sh. Sandeep Yadav,
Ld. ASJ, South, Saket Court, New Delhi, therefore, the
applicant/accused is entitled to the relief of regular bail on the
ground of parity.
E. BECAUSE nothing incriminating has to be recovered at the in-
stance of the applicant/accused.
F. BECAUSE the fact, that the complainant had fought with un-
known persons and was therefore not able to name the persons in-
volved in the alleged fight and later falsely implicated applicant/
accused out of personal grudges and animosity.
G. BECAUSE there is no CCTV footage or any other electronic evi-
dence to prove that applicant/accused was present on the alleged
spot at the time of the alleged incident or was involved in any
fight/argument/interaction with the complainant.
H. BECAUSE the applicant/accused is out on bail in all other mat-
ters pending against him and is not wanted in any other cases and
no fruitful purpose will be served by allowing him to languish in
jail anymore.
I. BECAUSE the applicant/accused has never been convicted in any
other FIR of similar nature.
J. BECAUSE the applicant/accused is the sole bread earner of his
family, therefore continuing him to remain in jail will only de-
stroy his career and also adversely affect his family which is de-
pendent on him, the family is already in hardships and anguish
due to the arrest of the accused/applicant.
K. BECAUSE the applicant/accused is a permanent resident of

Delhi and there are no chances of him absconding from the
course of justice.
L. BECAUSE the applicant/accused undertakes to present himself
before the police/court as and when directed.
M. BECAUSE the applicant/accused undertakes that he will not, di-
rectly or indirectly, make any inducement, threat or promise to
any person acquainted with the facts of the case so as to dissuade
him from disclosing such facts to the Court or to any police offi-
cer.
N. BECAUSE the applicant/accused further undertakes not to tam-
per with the evidence or the witnesses in any manner.
O. BECAUSE the applicant/accused is ready and willing to accept
any conditions as may be imposed by this Hon’ble Court in con-
nection with the present case.
PRAYER:
It is humbly prayed before this Hon’ble Court to allow the
present application and applicant/accused be granted regular bail,
in the interest of justice.
New Delhi Applicant/accused

Dated :

Through
ADVOCATE
Chamber No. 618 , Lawyers’ Block
CONTACT NO. 9319105989

Rajpal Kasana & Associates Chamber No. 618, Lawyers Block Saket Court, New Delhi CONTACT NO. 9319105989

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IN THE COURT OF LD.

DISTRICT & SESSION’S JUDGE, SOUTH

In the matter of:

STATE VS AKASH @ BHURA

Accused in JC since 23.11.2021

URGENT HEARING OF BAIL APPLICATION UNDER SECTION 439

New Delhi Applicant/ Accused

In the matter of:

STATE VS AKASH @ BHURA

S.No. Particulars Page no.

1. Bail applications under section 439

3. Copy of Order of Ld. Duty MM dated

4. Dismissed Anticipatory Bail order of

5 Bail order of main accused Rajkumar

New Delhi Applicant/ Accused

IN THE COURT OF LD. DISTRICT & SESSION’S JUDGE,

SOUTH DISTRICT, SAKET COURTS, NEW DELHI

In the matter of:

STATE VS AKASH @ BHURA

Accused in JC since 23.11.2021

BAIL APPLICATION UNDER SECTION 439 CR.P.C FOR GRANT OF

MOST RESPECTFULLY SHOWETH:

K. BECAUSE the applicant/accused is a permanent resident of

New Delhi Applicant/accused

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