Application for anticipatory bail u/s 438 of the criminal procedure code 1973
IN THE COURT OF THE DISTRICT & SESSIONS JUDGE, AGRA
Misc. Application No…………../2010
Shri __ A__ B __ C __…………. )………….Applicant
Age 36 years, occupation – social worker,………….)
Resident of 235 Parsi Gymkhana,……………………….)
MUMBAI 400 021.
Versus
The State of Maharashtra……………………………………) _ Opponent
AN APPLICATION FOR THE GRANT OF BAIL U/S 438 OF THE CRIMINAL PROCEDURE CODE 1973
The applicant above-named submits this application, praying to state as follows:
1. That the applicant is a social worker and active member of the Shiv Sena Party.
2. That the applicant has been serving the cause of society for the last more than twenty-five years.
3. That during the recent by-election to the MUMBAI Municipal Corporation in Ward No. 50, the applicant got elected with a large number of votes against his rival candidate, Shri XYZ, who belongs to the Congress- I Party.
4. That during the election campaign, there were a great many allegations made by the members of both the parties, and the said Congress- I candidate tried his best to make all the malicious attempts with a sole intention to defeat the candidature of this applicant.
5. That the said Congress-I candidate could not withstand his defeat in the election, and since the date of the declaration of the election result on………….the situation as a whole has gone bad to worse.
6. That on or about…………, a person alleged to have been an active member of the Congress-I Party was stabbed, and he died the following day.
7. That the applicant believes that on account of such unhealthy political activities indulged into by the said defeated candidate, some malicious plans and designs have been worked out with an intention so as to implicate this applicant for having committed or concerned with such a non-bailable offence.
8. That the applicant submits that since the date of the declaration of the election result on…………., this applicant had gone to Tirupati Balaji on a pilgrimage tour, and when he returned back to the headquarters only yesterday night, he came to know about such an accusation against him, and hence, this application.
9. That the applicant states and submits that he had no concerned with any such offence, if committed by some miscreants, and the contention of this applicant will be explicit from the very fact that this applicant was out of headquarters throughout, and thus, he is innocent, too.
10. That the applicant apprehends that he may be arrested on such an accusation, and hence, this application.
11. That this applicant furthermore submits that if this application is not granted by the Hon'ble Court, flagrant injustice will be done to him for no fault on his part.
12. That the applicant also believes that he will not be deprived of his legitimate and fundamental right.
13. That the proper court-fee is paid herewith.
14. That the applicant, therefore, prays that this application be kindly allowed and orders granting an anticipatory bail be issued in favour of this applicant.
MUMBAI,………….Sd/- ABC
APPLICANT
Dated:……………
Sd/- xXx
ADVOCATE FOR APPLICANT
VERIFICATION
I, Shri ABC, the present applicant, do hereby state on solemn affirmation that the contents of this application in paras 1 to 14 are true and correct to the best of my knowledge and belief, so I have signed hereunder.
Sd/- ABC APPLICANT