Afsar (Bail) 439

IN THE HIGH COURT OF JUDICATURE FOR RAJASTHAN
AT JAIPUR BENCH, JAIPUR
S.B. CRIMINAL MISC. BAIL APPLICATION NO. ______/2003
Afsar S/o Sh. Ansar Ahmed by caste Muslim r/o Nagori Mohalla, Dausa.
....Accused Applicant
VERSUS
State of Rajasthan through P.P.

…..Respondent
S.B. CRIMINAL MISC. BAIL APPLICATION U/S 439

Cr.P.C. IN F.I.R. NO. 517/2002 REGISTERED AT
POLICE STATION DAUSA FOR OFFENCES U/S 147,
149, 346, 307 & 302 I.P.C. AND AGAINST THE
ORDER DATED 24.9.2003 PASSED BY SESSION
JUDGE, DAUSA DISTRICT DAUSA WHEREBY THE
BAIL APPLICATION NO. 278/2003 FILED BY THE
ACCUSED APPLICANT WAS DISMISSED.
To
The Hon’ble Chief Justice Sh. Anil Dev Singh and
his companion Judges of the High Court of
Judicature for Rajasthan, Bench at Jaipur.
MAY IT PLEASE YOUR LORDSHIPS :
The humble accused/applicants most respectfully submits as under:
1. That an FIR No. 517/2002 came to be registered at Police Station
Dausa which is reproduced as under :-
"egksn; fuosnu gS fd vkt fnukad 21-08-2002 dks le;

djhcu 9-00 ih-,e- jkf= dks eSa vius ?kj dh rjQ iSny iSny
tk jgk FkkA lkeus ls vUlkj iq= vuoj [kk¡ vQlkj b'R;kd
1
iq= vuoj [kk¡ lbZn iq= vuoj [kk¡ ;qlqQ iq= xqyQku [kk¡
vk jgs Fks tks nj;ku ds edku ds ckgj fny'kkn iq= xqyQku
[kk¡u ds vykmíhu iq= vuoj vQlkj iq= vUlkj [kk¡ us
pkdw ls tku ls ekjus dh fu;r ls isV nka;h vksj okj fd;k
ckdh yksxksa fny'kkn dks idM+ fy;k FkkA fny'kkn ds
iSj nks pksVsa vk;h gSA ;s yksx ekjihV djds Hkkx x;s
mu yksxksa us ;s geyk iqjkuh jaft'k dks ysdj tku ls ekjus
dh fu;r ls fd;k gSA fjiksVZ djrk gwa dk;Zokgh djsA
fny'kkn dks esjk yM+dk rkfgj vLirky ysdj x;k FkkA ftls
t;iqj jSQj dj fn;k x;kA"
Upon this information FIR No. 517/2002 u/s 147, 149, 346,
307 IPC was registered and investigation was started. During the
investigation offence u/s. 302 / 34 IPC more added. The accused
applicant was arrested by the police.
2. That the accused applicant moved a bail application u/s 439 before
the Sessions Judge Dausa The bail application of the accused
applicant has been dismissed vide order dated 24.9.2003.
3. That aggrieved of this the accused applicant is submitting this bail
application on the following amongst other grounds:-
A. That the accused applicant is absolutely innocent, he has been
falsely implicated in this case. He has not committed any
offence.
B. That the alleged offence is not at all made out against the
present accused applicant because accused applicant was
implicated in this case on account of earlier enmity which is
proved itself FIR. In these circumstances it clearly seems that
2
accused applicant has been falsely implicated therefore, the
accused applicant is entitled to be released on bail.
C. That first of all the deceased was taken Dausa Hospital but
injury report showed only one injury was found. Thereafter,
deceased was referred to SMS Hospital, Jaipur where
deceased was declared died and postmortem report was
prepared in which two injuries were found on stomach of the
decease. In these circumstances gross contradictions seems
between the injury report of the Dausa Hospital and SMS
Hospital.
D. That postmortem report was prepared on request of the C.I.
Ahmed Khan who is working in police headquarter in Jaipur
while postmortem report should have been prepared on
request of the police officer Dausa which is also suspicious.
E. There is no motive/intention establish against the accused
applicants.
F. That other grounds would be taken up at the time of
arguments.
PRAYER
It is therefore, prayed that your lordships may very graciously
be pleased to accept this Criminal Bail Application and may be
pleased to release the petitioner on bail.
HUMBLE APPLICANT
THROUGH COUNSEL
PLACE : JAIPUR
DATE :
[Swadeep Singh Hora / L.P. Singhal /
3
Govind Singh / Sandeep Hora]
Advocates
NOTES :
1. This is Bail Application. No such application has been filed before
this Hon'ble Court.
2. That as pie papers were not readily available hence stout papers have
been used.
3. That one spare copy of this bail application has been given to the
counsel for the opposite party.
4. That it has been typed by my private steno.
5. Challan has been submitted.
ADVOCATE

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IN THE HIGH COURT OF JUDICATURE FOR RAJASTHAN

AT JAIPUR BENCH, JAIPUR

S.B. CRIMINAL MISC. BAIL APPLICATION NO. ______/2003

State of Rajasthan through P.P.

S.B. CRIMINAL MISC. BAIL APPLICATION U/S 439

MAY IT PLEASE YOUR LORDSHIPS :

The humble accused/applicants most respectfully submits as under:

1. That an FIR No. 517/2002 came to be registered at Police Station

Dausa which is reproduced as under :-

"egksn; fuosnu gS fd vkt fnukad 21-08-2002 dks le;

investigation offence u/s. 302 / 34 IPC more added. The accused

applicant was arrested by the police.

the Sessions Judge Dausa The bail application of the accused

applicant has been dismissed vide order dated 24.9.2003.

3. That aggrieved of this the accused applicant is submitting this bail

application on the following amongst other grounds:-

A. That the accused applicant is absolutely innocent, he has been

falsely implicated in this case. He has not committed any

present accused applicant because accused applicant was

implicated in this case on account of earlier enmity which is

proved itself FIR. In these circumstances it clearly seems that

accused applicant is entitled to be released on bail.

injury report showed only one injury was found. Thereafter,

deceased was referred to SMS Hospital, Jaipur where

deceased was declared died and postmortem report was

prepared in which two injuries were found on stomach of the

decease. In these circumstances gross contradictions seems

between the injury report of the Dausa Hospital and SMS

D. That postmortem report was prepared on request of the C.I.

Ahmed Khan who is working in police headquarter in Jaipur

while postmortem report should have been prepared on

request of the police officer Dausa which is also suspicious.

E. There is no motive/intention establish against the accused

F. That other grounds would be taken up at the time of

It is therefore, prayed that your lordships may very graciously

be pleased to accept this Criminal Bail Application and may be

pleased to release the petitioner on bail.

1. This is Bail Application. No such application has been filed before

this Hon'ble Court.

counsel for the opposite party.

4. That it has been typed by my private steno.

5. Challan has been submitted.

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