IN THE HIGH COURT OF DELHI AT DELHI
STATE (NCT OF DELHI) V/s MUSTAFA ANSARI And ANR.
FIR No/Year 042/2026
U/S 64(l), 103(1), 3(5), 117(2), 138,
127(2) of B.N.S. 2023
P.S. Modal City, Indraprastha
PESHI 16/04/2026
1st Application for Bail U/S 483 BNSS
INDEX
[Link] Particulars Page
1 APPLICATION FOR BAIL U/S-483 BNSS 2-4
2 AFFIDAVIT 5-6
Dated: 14th April 2026 Applicant / Accused
Rajesh Yadav
H-87, Shashtri puram, Model city,
Indraprastha, Delhi.
Through Counsel: Vivek Kumar
Enrol No:- LTAC/709/2026
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IN THE COURT OF THE DISTRICT AND SESSIONS JUDGE, INDRAPRASTHA
CRIMINAL MISCELLANEOUS APPLICATION NO. 88 OF 2026
IN THE MATTER OF:
Rajesh Yadav, S/o Mahendra Yadav, H-87, Shashtri Puram, Modal city, Indraprastha
.....Applicant/Accused
State (NCT OF DELHI)
.......Respondent
FIR NO:- 042
U/S:- 64(l), 103(1), 3(5), 117(2),
138, 127(2) of BNS 2023
P.S:- Modal City Indraprastha
Peshi:-16/04/2026
1st APPLICATION FOR BAIL U/S 483 BNSS
Respected Sir/Madam,
The Applicant/Accused most humbly prays for being released on bail on the following grounds: -
That the present application under Section 483 of the BHARATIYA NAGARIK SURAKSHA
SANHITA, 2023, is being filed by the Applicant for seeking a grant of bail in FIR No. 041, U/S 64(l),
103(1), 3(5), 117(2), 138, 127(2) of BNS 2023, registered at Police Station: Modal City,
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Indraprastha. The present petition is being moved as the Applicant has been arrested on 19.02.2026 at
H-87, Shashtri Puram, Modal city, Indraprastha.
Main Grounds for Bail Application
i. That the accused has to go for the election manifesto, as the elections of the Lok Sabha are from
next week, he has to join the election manifesto.
ii. That the Applicant is a bona fide Politician and his continued incarceration is causing irreparable
damage to his political career, and the Applicant is presumed innocent until proven guilty, and his
custody is destroying his professional future, amounting to pre-trial punishment.
iii. That in the present case, the investigation is completed and the chargesheet has been filed, and the
applicant is not required for investigation.
iv. That the Applicant is innocent and is being falsely implicated in the above-mentioned case, as he
has nothing to do with the matter.
v. That the Applicant belongs to a decent and reputable family and has never been involved in any
such type of activities before.
vi. That the Applicant is a law-abiding citizen of India and has no prior criminal record or antecedents
of any kind whatsoever.
vii. That in the Arvind Kejriwal v. Directorate of Enforcement (2024): The Supreme Court granted
bail specifically for election campaigning, noting that elections are the "lifeline of democracy."
viii. That the Applicant was arrested on 19.02.2026, which is 2 days after the registration of FIR on
18.02.2026. During this entire period, the Applicant was freely available and did not flee, tamper
with evidence or influence any witness.
ix. That the Applicant is a permanent resident of Indraprastha with deep roots in the community.
x. That the Applicant is a responsible person living at the above-mentioned addresses, which are
verifiable and on record.
xi. That the Hon'ble Supreme Court has categorically held that bail is the rule and jail is the exception.
xii. That the family members of the Applicant's family members are deeply distressed on account of
their incarceration, and his continued custody is causing irreparable harm to the family.
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xiii. That this is a total conspiracy against the Applicant. The allegations are fabricated, and the
Applicant has been falsely named as the entire investigation is flawed.
xiv. That no useful purpose would be served by keeping the Applicant under custody, and this is a fit
case for the grant of bail.
xv. That the Applicant undertakes to abide by the conditions that this Hon'ble Court may impose at the
time of granting bail and further undertake to attend the trial on every date of hearing.
xvi. That the Applicant has not filed any other similar petition before this or any other Hon'ble Court
for the grant of bail in case of the present FIR.
xvii. That the Applicant is ready to produce sound surety to the entire satisfaction of this Hon'ble Court.
[Link] the Applicant shall not hamper or tamper with the evidence of prosecution in any manner in
this case if admitted to bail.
xix. That the Applicant has deep roots in the society and he will not flee away from the court of law in
case he is admitted to bail and the trial of the case will take sufficient long time.
PRAYER:
In view of the above-stated facts and circumstances, it is most respectfully prayed that this Hon'ble Court
may be pleased to
Grant bail to the Applicant in connection with FIR No. 042, registered under Sections 64(l), 103(1), 3(5),
117(2), 138, 127(2) of B.N.S. 2023, Police Station Model City, Indraprastha.
A. Pass any other such order as this Hon'ble Court may deem fit and proper in the interest of
justice.
Date:- 14th April, 2026 Applicant/Accused
Place:-Indraprastha Imran Qureshi
Through Counsel: Vivek Kumar (Advocate), Indraprastha, Delhi
[Link]. LTAC/709/2026, Mob. No.9540561815
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IN THE COURT OF THE DISTRICT AND SESSIONS JUDGE, INDRAPRASTHA
STATE (NCT OF DELH) V/s MUSTAFA ANSARI AND ANR.
FIR NO:- 042/2026
U/S:- 64(l), 103(1), 3(5),
117(2), 138, 127(2) BNS 2023
P.S:- Modal City, Indraprastha
Peshi:-16/04/2026
1st APPLICATION FOR BAIL U/S 483 BNSS
AFFIDAVIT
I, Rajesh Yadav, aged 35 years, S/o Mahendra Yadav, Permanent Address: H-87, Shashtri puram, Model
city, Indraprastha, Delhi, do hereby solemnly affirm and declare as under:-
1. That the deponent has filed the 1st Bail application U/s 483 BNSS and no other bail application in this
regard is decided or pending in any Court of law.
2. That the contents of the bail application have been drafted on the facts and circumstances furnished by
the deponent which are true and correct. The same may kindly be read as part and parcel of this affidavit.
....DEPONENT
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VERIFICATION: -Verified at Indraprastha on this 14th April, 2026 that the contents of my above said
affidavit are true and correct to the best of my knowledge and belief and nothing has been concealed
therein.
......DEPONENT
Through Counsel: Vivek Kumar (Advocate), Indraprastha, Delhi
[Link]. LTAC/709/2026, Mob. No.9540561815