Application for anticipatory Bail before the High Court
In the High Court at Mumbai (Criminal Miscellaneous Jurisdiction)
In the matter of: An application for anticipatory bail under Section 439 of Criminal Procedure Code.
R s/o M residing at 72, Bora Bazar, Mumbai Petitioner
Versus
State of Maharashtra Respondent
To,
The Hon’ble Mr. Chief Justice and
His Companion Justices of the said
Hon’ble Court.
The Humble petition of Raju Ramchandra the petitioner above named most respectfully sheweth as under:
(1) That the petitioner is a reputed person being in service of Mittal Iron and Steel Co. Ltd. and having being an assessee under the Income Tax Act, 1961.
(2) That the petitioner is residing in house No. 72, Bora Bazar, Mumbai
(3) That due to some enmity his rival D.Kumar, s/o C.N. Kumar has lodged a complaint against the petitioner for the alleged offence of cheat and forgery.
(4) That the intention of the complaint is only to harass the applicant and to tarnish his image in the society and in the Mittal Iron and Steel Company Ltd. particularly.
(5) That your petitioner has every apprehension that the police may arrest and put him in jail to harass and cause mental torture and physical inconvenience in connection with the said complaint.
(6) That in the interest of justice the Petitioner's plea for anticipatory bail should be allowed and the petitioner undertakes to abide by all the terms and conditions of the bail.
(7) That if the anticipatory bail is not granted to the petitioner, he shall suffer irreparable loss or injury.
(8) That the application is made bona fide in the interest of justice.
In the circumstances the petitioner humbly prays:
That your Lordship may be pleased to direct that in case the petitioner is arrested in connection with the above noted complaint he shall be forthwith released on bail.
Your Lordship may pass such other order or orders as may be deemed fit and proper.
And your petitioner as in duty bound shall ever pray.
Signature of Advocate
Signature of the petitioner
Verification
I, R s/o M the petitioner abovenamed by occupation service residing at 72, Bora Bazar, Mumbai, do hereby solemnly affirm and state as follows:
(1) That I am the petitioner abovenamed and I am fully acquainted with the facts and circumstances of the case deposed thereto.
(2) That the statement in paragraph 1 to 8 in the foregoing petitions are true to my knowledge and belief.
(3) That I have signed this verification on this 26th day of Feb, 2010 in Mumbai.
Solemnly affirmed by the said Raja Ram on 26th day of Feb, 2010 in the Court House at Mumbai
Before Commissioner Signature of petitioner