1.

DRAFTING, PLEADING AND CONVEYANCING

CIVIL PLEADINGS
EXERCISE-I PLAINT
PLAINT
ORDER-6, RULE-17, SECTION-26
In the court of the Junior Civil Judge at Varanasi
O.S No. ____/2018
Shri Rohit Singh s/o Shri Rajendra Singh, aged 40 years, r/o A-20, Laxmi Nagar, Sundarpur,
Varanasi-221005 …………..Plaintiff
Vs.
Shri Jatin Yadav s/o Jayant Yadav, aged 43 years, r/o A-19, Laxmi Nagar, Sundarpur, Varanasi-
221005 ………..Defendant
Suit for recovery of Rs. 500 as compensation for trespass
The plaintiff begs to submit as under:
1. That the defendant is residing in House No- A-19 which is adjoining the plaintiff’s House no. A-
20 situated in Sundarpur in the city of Varanasi. There is a House no. A-21 which is adjoining the
plaintiff’s house on its northern side.
2. That the defendant, without the permission of the plaintiff, stepped in, and trespassed on the roof
of plaintiff’s house from his house no A-19 on 18 TH April ,2018 at about 11 pm and in spite of
remonstrance by the plaintiff’s son, crossed the roof of the plaintiff and went to House no B-21.
3. That the defendant has committed an act of trespass on the immovable property of the plaintiff and
is liable to pay compensation for his such wanton act to thee plaintiff, which the plaintiff claims at
Rs. 500. As the defendant threatens to repeat the act and as the plaintiff’s family members privacy is
disturbed thereby, the at of the defendant becomes still more reprehensible.
2. DRAFTING, PLEADING AND CONVEYANCING
4. That the cause of action arose on 18 th April 2018 at Varanasi. Hence this court has jurisdiction.
5. The Plaintiff values this suit for the purpose of Court Fee and Jurisdiction at Rs.500/- and pays
Court Fee of Rs.151/-
6. That the plaintiff prays:
 That the honourable court may be pleaded to pass a judgment and decree against the defendant
and in favour of the plaintiff.
 Directing the plaint defendant to pay the plaintiff the sum of Rs. 500.
 Awarding the plaintiff, the cost of the suit.
 Passing such further or other order as the honourable court may deem fit and proper in the
circumstances of the case.

Counsel for Plaintiff Plaintiff

VERIFICATION
I, Rohit Singh, son of Shri Rajendra Singh, the plaintiff above named do hereby declare that what is
stated in the above paragraphs are true to the best of my knowledge and belief.
Verified at Varanasi on the 23rd day of April 2018.
Plaintiff 3. DRAFTING, PLEADING AND CONVEYANCING
IN THE COURT OF THE JUNIOR CIVIL JUDGE AT VARANASI
O.S. No …………………/2018
Shri Rohit Singh s/o Shri Rajendra Singh, aged 40 years, r/o A-20, Laxmi Nagar, Sundarpur,
Varanasi-221005 …………..Plaintiff
Vs.
Shri Jatin Yadav s/o Jayant Yadav, aged 43 years, r/o A-19, Laxmi Nagar, Sundarpur, Varanasi-
221005 ………..Defendant
AFFIDAVIT
I. Rohit Singh do hereby solemnly affirm and state as under that: -
That I am the deponent in the captioned suit. I am fully conversant with the facts of the plaint and
competent to swear this affidavit on my behalf.
That the present appeal has been drafted by my counsel under my instructions and guidance and the
contents of the same are true and correct and are not being repeated herein for the sake of brevity and
to avoid repetition and prolixity.
That the contents of the plaint may kindly be read as part and parcel of this Affidavit also.
DEPONENT
VERIFICATION:
Verified by me at Sundarpur, Varanasi on 23rd April, 2018 4. DRAFTING, PLEADING AND
CONVEYANCING
EXERCISE-II
WRITTEN STATEMENT
IN THE COURT OF THE JUNIOR CIVIL JUDGE AT VARANASI
Civil suit no. ____/2018
Shri Rohit Singh s/o Shri Rajendra Singh, aged 40 years, r/o A-20, Laxmi Nagar, Sundarpur,
Varanasi-221005 …………..Plaintiff
Vs.
Shri Jatin Yadav s/o Jayant Yadav, aged 43 years, r/o A-19, Laxmi Nagar, Sundarpur, Varanasi-
221005 ………..Defendant
Written Statement on behalf of the defendant
The defendant most respectfully- Showeth:
1. Para 1 is admitted.

2. Para 2 is admitted. The defendant heard a shout from house No. 21 saying “Fire!, Fire!” The
defendant accordingly rushed to render aid to the occupant of house No. 21 on account of neighborly
feeling.
3. It was a trespass, it was so on account of sheer necessity. The defendant has never threatened to
trespass into or onto the house of the plaintiff. The insinuation mentioned in the last part of this
paragraph is uncalled for. The defendant is not liable to pay any compensation. In any event a
nominal compensation of one paisa would meet the ends of justice.

4. Para 4 is legal.

5. Para 5 is legal.
6. The suit is dismissed. In the circumstances of the case the defendant forgoes his costs.
5. DRAFTING, PLEADING AND CONVEYANCING
Defendant
VERIFICATION:
I, Jatin Yadav, do hereby verify that the contents from paras 1 to 6 are correct and true to the best of
my knowledge and personal belief and no part of it is false and nothing material has been concealed
therein.
Place: Varanasi Defendant
Date:18-04-2018
. 6. DRAFTING, PLEADING AND CONVEYANCING
EXERCISE III
INTERLOCUTORY APPLICATION
Application under order 39 Rule 1 and 2
IN THE COURT OF THE JUNIOR CIVIL JUDGE AT VARANASI
Application No: ______ of 2018
Shri Rohit Singh s/o Shri Rajendra Singh, aged 40 years, r/o A-20, Laxmi Nagar, Sundarpur,
Varanasi …………………………………………………..Applicant
Versus
Shri Jatin Yadav s/o Jayant Yadav, aged 43 years, r/o A-19, Laxmi Nagar, Sundarpur,
Varanasi ............................................................................Respondent
Application under order 39 Rule 1 and 2 of the Civil Procedure Code
Respectfully Sheweth: 1. That the applicant/plaintiff has filed a case before this honorable court
hearing where of will take some time. 2. That it is apparent from perusal of grounds and documents
attached therewith that the applicant has prima facie a very good case in his favour and the case is
likely to succeeds. The balance of convenience is in favour of the applicant. The grounds of the case
may be read as part of this application to save the repetition. 3. That the interest of justice demands
that the respondent is restrained from constructing any kind of construction or building whatsoever
interfering and disturbing the peaceful enjoyment usage and possession of the common pathways in
the area in any manner. In case the respondents are not restraining that the applicant will suffer
irreparable loss and injury which cannot be compensated in terms of money and filing of this case
will become infructuous. 4. It is therefore most respectfully prayed that the respondents be restrained
from constructing any kind of construction or building whatsoever interfering and disturbing the
peaceful enjoyment, usage and possession of the common pathways in the area in any manner in the
interest of justice. Such other orders be also passed in favour of the applicant as deemed fit in facts
and circumstances of the case. 7. DRAFTING, PLEADING AND CONVEYANCING
Varanasi
Applicant ______ Through, Advocate
IN THE COURT OF THE JUNIOR CIVIL JUDGE AT VARANASI
Application No:______ of 2018
Shri Rohit Singh s/o Shri Rajendra Singh, aged 40 years, r/o A-20, Laxmi Nagar, Sundarpur,
Varanasi …………………………………………………..Applicant
Versus
Shri Jatin Yadav s/o Jayant Yadav, aged 43 years, r/o A-19, Laxmi Nagar, Sundarpur,
Varanasi ............................................................................Respondent
Affidavit in support of application under order 39 Rule 1 and 2 of the Civil Procedure Code.
I, Rohit Singh, do hereby solemnly affirm and declare as under:- 1. That the accompanying
application has been prepared under my instructions. 2. That the contents of paras 1 to 4 are true and
correct to the best of my knowledge. 3. That I further solemnly affirm and declare that the contents of
this affidavit of mine are correct and true to the best of my knowledge and no part of it is false and
nothing material has been concealed therewith. Affirmed at Varanasi this ______. Deponent. 8.
DRAFTING, PLEADING AND CONVEYANCING
EXERCISE- VI
MEMORANDUM OF APPEAL
Memorandum of Appeal
In the Court of District Judge, Jabalpur
Civil Appeal No. ... / 2010 Under Section 96 of CPC, 1908.
Amrit Bhushan. S/o Birendra Bhushan. 12, Main Road, Rewa, MP .........................................
Plaintiff/Appellant Vs. Manju Nath S/o OP Nath. 46, Main Road, Rewa,
MP .................................... Defendant/Respondent
Memorandum of Appeal
Sir, The aforementioned plaintiff-appellant appeals against the judgement and decree of the
Court of Civil Judge Class II, at Jabalpur, passed in Original Suit No 9687 of 2010 between
Amrit Bhushan S/o Birendra Bhushan vs Manju Nath S/o OP Nath., dated 01/02/2010, and
sets forth the following grounds of objection to the decree appealed from :- Value of the suit:
Value of appeal: Court Fee Paid: (1) That the orders passed by the Learned Lower Court are
contrary to the provisions of law and the principles of natural justice. (2) That the findings
arrived by the Learned Lower Court are not supported by the evidence on record. (3) That
the Learned Lower Court committed an error in holding that the house premises are not
required by the plaintiff/appellant for his personal bonafide occupation. (4) That the copy of
the Judgment and the Decree against which this appeal 14. DRAFTING, PLEADING AND
CONVEYANCING
has been preferred is attached along with. (5) That the Learned Lower Court has having
answered the first issue in the negative decided the rest of the issues against the appellant,
which itself is improper and illegal. (6) That the necessary court fee is paid herewith. Prayer:
(7) That the appellant, therefore, prays that for the reasons stated above and as may be argued
at the time of hearing, the record and proceedings be called for, this appeal be allowed, the
orders under appeal be set aside and quashed, and orders deemed just and proper be kindly
passed. Further that the cost of this petition be awarded in favor of plaintiff-appellant. Place:
Jabalpur (Signature of Date: 01/02/2010 Plaintiff/Appellant) Advocate for Plaintiff-
Appellant
Verification
I, Amrit Bhushan, do hereby verify that the contents from paras 1 to 5 are correct and true to
the best of my knowledge and personal belief and no part of it is false and nothing material
has been concealed therein. Affirmed at Jabalpur this 1st Day of February 2010. (Signature)
Plaintiff-Appellant 15. DRAFTING, PLEADING AND CONVEYANCING
EXERCISE VII
MEMORANDUM OF REVISION
(MEMORANDUM OF REVISION)
IN THE HIGH COURT OF JUDICATURE AT ALLAHABAD
Civil Revision Application No.......2017
A, S/o Z aged about 62 years
R/o Civil Lines, Allahabad ...........Applicant/Defendant
Versus
B, S/o Y aged about 40 years
R/o Sangam, Allahabad ........Opponent/Plaintiff
Civil Revision u/s 115 of C.P.C
To,
The Honourable Chief Justice
And the other Judges of the
Honourable Court.
The applicant named above humbly submits:
1) That the opponent had instituted a suit bearing No 71 of 2010 in the court of Civil judge, Senior
Division, Varanasi for recovery of Rs. 80000. On the ground of a promissory note said to be due on
the applicant after selling opponents shop at Sigra at Varanasi road.
2) That the applicant submits that he had already paid Rs 700000 to the opponent as a cost of the
shop and no cost was due with regard to the said shop.
3) That the court decreed the said suit in the opponent on 28-04-2015 and ordered the applicant to
pay the amount of the decree to the opponent.
4) That the applicant being aggrieved by the said decree and judgement prefers this application on
the following ground:
a) That the decree and judgement passed by the learned judge is illegal and unjust.
b) That the judgement of the learned judge is erroneous in law that by passing the decree on a
promissory note which was not stamped.
c) That the learned judge erred in holding that the promissory note was executed by the applicant.
d) That the handwriting expert was not called inspite of the repeated request for the applicant. 16.
DRAFTING, PLEADING AND CONVEYANCING
e) That the learned judge erred in not appreciating the evidence of the applicant and his witnesses.
f) The in doing so, the learned judge in the exercise of the jurisdiction has acted with illegality and a
material irregularity.
g) That the said judgement is against justice, equity and good conscience and therefore not substance
in the court.
h) That in the aforesaid circumstances the applicant submits that the Hon'ble court be pleased to call
for the records of the trying court and revise its judgement and decree in the interest of justice.
Date: 5/12/2017 X
Place: Applicant
Allahabad XX
Counsel for Applicant 17. DRAFTING, PLEADING AND CONVEYANCING
EXERCISE VIII
WRIT PETITION UNDER ARTICLE 226
In the High Court of Judicature At Allahabad
Civil Original (Extra-ordinary) Jurisdiction
Civil Writ Petition No…………………… of 2018
In the matter of:
Rohit Singh S/o Rajendra Singh R/o A-21, Civil Lines, Allahabad, former employee (Inspector
Grade-I) in the Respondent Company ….Petitioner
1. XYZ Company Ltd., a company wholly owned by the Govt. of India and having its registered
office at Allahabad through its Chairman.
2. Managing Director of the above Company …Respondent
Civil Writ Petition against the order dated 12-02-2018 passed by the Managing Director, respondent
No. 2 herein, by which the services of the petitioner as an employee of the respondent-company have
been terminated.
May it please the Hon'ble Chief Justice of the High Court of Allahabad and His Lordship's
companion Judges.
The Petitioner
MOST RESPECTFULLY SHOWETH:
1. That the petitioner is a citizen of India and is therefore entitled to enjoy all the rights guaranteed by
the Constitution of India.
2. That respondent No. 1 is a company registered under the Companies Act, 1956 having its
registered office at Allahabad
The respondent-company is wholly owned by the Government of India and is, thus, an
instrumentality of state is given in Annexure 12 of the Constitution.
3. That the petitioner was an employee of the respondent-company, having been appointed as a Sub-
Inspector Grade-I on 21-08-1991 and he continued to work, earning one promotion also.
4. That on 11-07-2017 respondent No. 2 herein abruptly issued the impugned order dated 28-09-2017
terminating the services of the petitioner and the 18. DRAFTING, PLEADING AND CONVEYANCING
petitioner came to be relieved of his duties the same day. A copy of the impugned order is annexed
hereto and marked as ANNEXURE-1.
5. That on a bare reading of the impugned order it becomes clear that the order has been issued on the
basis of some alleged misconduct on the part of petitioner, but no inquiry under the relevant rules has
been held before the passing of the order.
6. That the petitioner has not committed any act that could be termed to be an act constituting
misconduct.
7. The impugned order is being assailed on the following, amongst other,
GROUNDS
7.1 That the petitioner being a permanent employee of the respondent-company his services could
not be terminating without holding an enquiry under the rules applicable to the employees of the
company.
7.2 That the principles of natural justice have been contravened by the respondents in not giving to
the petitioner any opportunity of being heard.
7.3 That the impugned order is otherwise also erroneous and unsustainable, as it does not contain any
reason and is a non-speaking order.
7.4 That the impugned order is arbitrary and contravenes Article 14 of the Constitution.
8. That the petitioner has not filed any petitioner other proceedings relating to the matter at this
petition in any other court.
PRAYER
In the facts and circumstances stated above the petitioner prays that a direction in the form of a writ
of quo warranto and mandamus or any other appropriate writ be issued quashing the impugned order
and reinstating the petitioner in service with all consequential benefits including back wages.
It is further prayed that the respondent be burdened with costs.
PETITIONER
THROUGH
DATED: 22-03-2018 COUNSEL MR………………….. 19. DRAFTING, PLEADING AND
CONVEYANCING
CRIMINAL PLEADING
EXERCISE IX
WRIT PETITION UNDER ARTICLE 32
IN THE HON’BLE SUPREME COURT OF INDIA, NEW DELHI
(Original Criminal Jurisdiction)
Writ Petition No. __________of _________20 _________
A ____ aged about ____ son of _____., resident _____ …Petitioner
Versus
1. Additional Secretary, Ministry of Finance, Government of____. 2. The Superintendent,
____Jail ____ 3. The State of_____ …Respondent
PETITION FOR THE ISSUE OF WRIT OF HABEAS CORPUS UNDER ARTICLE 32 OF
THE CONSTITUTION OF INDIA
To The Hon’ble the Chief Justice and his companion Judges of the Court aforesaid. The
humble petition of the above named Petitioner most respectfully sheweth: 1. That the
petitioner is a resident of _____. and he was living peacefully at his residence at the place
aforesaid. 2. That on _____. Respondent No. 1 made an order under Section 3 of the 20.
DRAFTING, PLEADING AND CONVEYANCING
Conservation of Foreign Exchange and Prevention of Smuggling Activities Act, 1974 by
which he directed that the Petitioner shall be arrested and detained for a period of three
months. A copy of the order is annexed herewith as Annexure ‘‘A’’. 3. That the Petitioner
was arrested the same day and was detained in _____Jail. The grounds of detention were not
supplied to the petitioner on that day. The grounds were actually supplied on_____. A copy
of the grounds supplied is annexed herewith as Annexure ‘‘B’’. 4. That on _____. the
Petitioner submitted a representation against his detention through Respondent No. 2 but the
same was considered by the Advisory Board after one month and was rejected on ____. 5.
That the grounds of detention supplied to the Petitioner were in English which language the
Petitioner does not know. 6. That the orders of detention of the Petitioner are illegal,
improper and without jurisdiction on the following:
GROUNDS
1. Because the Conservation of Foreign Exchange and Prevention of Smuggling Activities
Act, 1974, is unconstitutional and void as it is beyond the legislative competence of
Parliament. 2. Because the order has been passed by an officer not duly authorized. 3.
Because the grounds were supplied after undue delay. 4. Because the grounds are in English
which language the Petitioner does not know and this has prevented him from making an
effective representation. 5. Because the grounds are irrelevant to the object of the Act. 6.
Because the grounds are vague. 7. Because there was undue delay in the disposal of the
representation submitted by the petitioner. Wherefore it is respectfully prayed that this
Hon’ble Court may be pleased to issue a writ in the nature of Habeas Corpus to the opposite
parties quashing the order of detention and directing that the Petitioner be set at liberty
forthwith. 21. DRAFTING, PLEADING AND CONVEYANCING
Date _________ Advocate for the Petitioner. 22. DRAFTING, PLEADING AND CONVEYANCING
EXERCISE X
CRIMINAL COMPLAINT
CRIMINAL COMPLAINT U/S 494 R/W SEC. 34 OF THE INDIAN PENAL
CODE
IN THE COURT OF THE JUDICIAL MAGISTRATE, FIRST CLASS, (ANTI-
CORRUPTION COURT), PUNE AT PUNE
Criminal Complaint No. Smt. .... D .... A .... S...., )
age 25 years, occupation - service, ) Complainant
resident of C/[Link] DAD, 175 Kothrud, )
PUNE 411 029. ) Versus
[Link] .... D .... A .... M ...., )
■
age 30 years, occupation - business, )
2. Smt. .... D .... A .... B ...., ) Accused age 55 years, occupation - household, )
3. Smt. .... D .... A R , )
age 20 years, occupation - education, )
all residents of 320 Erandwana, )
PUNE 411 004. )
A COMPLAINT U/S 494 R/W SEC. 34 OF THE INDIAN PENAL CODE
The complainant above-named submits this complaint, praying to state as follows:
1. That the complainant is the legally wedded wife of the accused No. 1, while the accused No. 2 is
the mother and the accused No. 3 is the second wife of the accused No. 1.
2. That the complainant was married to the accused No. 1 at Pune on according to the Hindu religion,
vaidic rites and ceremonies.
3. That before the marriage, the complainant was known by her maiden name as Kumari Lata, and
likewise, the accused No. 3, before this second marriage, was also' known by her maiden name as
Pata. 23. DRAFTING, PLEADING AND CONVEYANCING
4. That after the marriage, the complainant and the accused No. 1 cohabited together for about three
years. However, during the existence of their marriage, this complainant could not beget a child, and
hence, on that count, the accused Nos. 1 and 2 were nervous and unnecessarily offended for no fault
on the part of this complainant.
5. That this complainant submits that last year, in the month of June, the accused No. 1 told this
complainant that she should better go to her parents', at least, for a few days for a medical check-up,
and under that pretext, she was sent to stay with her parents.
6. That, thereafter, the complainant No. 1 did not either come to take back for cohabitation, nor allow
her to do so, and thus, the accused No. 1 has deserted this complainant.
7. That this complainant learnt from very reliable sources that the accused No. 1 is going to contract
marriage on with the accused No. 3 at the remote place near Katraj, and the ceremony was fixed to be
carried out in a bungalow of one, Shri XYZ.
8. That accordingly, this complainant lodged a report with the Sahakarnagar Police Station,
requesting them to help this complainant, and the police did try to do so, but they could not register
the offence committed by the accused for the reason that the venue of the marriage was changed.
9. That, however, this complainant could know the changed venue, and she collected all the details
with a view to registering the said offence.
10. That this complainant states and submit that the said second marriage between the accused Nos. 1
and 3 was celebrated in the Ganesh Mandir, one km away from Katraj, which took place on ......at
6.00 p.m., and about 100 people were present for the said marriage.
11. hat while celebrating the said marriage between the accused Nos.1 and 3, all the religious
ceremonies and rites were performed.
12. That the cause of action for this complaint first arose on……. and hence, this complaint filed
today is well within limitation.
13. That the offence has been committed within the local limits of the 24. DRAFTING, PLEADING AND
CONVEYANCING
jurisdiction of this Court, and hence, this Hon'ble Court has jurisdiction to try and decide this
complaint.
14. That the necessary court-fee is paid herewith.
15. That the complainant, therefore, prays that the accused be kindly charged with and tried for the
offence punishable u/s 494 R/W Sec.34 of the Indian Penal Code and punished according to law.
Pune, Sd/- DAS
COMPLAINANT Dated :
Sd/- x X x
ADVOCATE FOR COMPLAINANT
VERIFICATION
I, Smt. DAS, the present complainant, do hereby state on solemn affirmation that the contents of this
complaint in paras 1 to 15 are true and correct to the best of my knowledge and belief, and so I have
signed hereunder.
Sd/- DAS COMPLAINANT 25. DRAFTING, PLEADING AND CONVEYANCING
EXERCISE XI
CRIMINAL MISCELLENEOUS PETITION
IN THE COURT OF SECOND ADDL. JUDICIAL MAGISTRATE OF SATNA
[Link]. OF 2012 [Link]. ____/2011
Dhanarekha …Petitioner
Vs.
Arun Kumar ... Respondent
Petition filed on behalf of the Petitioner U/Sec 128 Cr. P.C
(1) The petitioner submits that he filed the above M.C. for grant of separate maintenance on
31.12.2011 against the respondent seeking a sum of Rs. 500 per month to be awarded.
(2) The Honourable Court, after due contest, by order dated 06.01.2012 granted maintenance to the
petitioner directing the respondent to pay a sum of Rs. 400 per month to the petitioner from
01.01.2012 and keep praying in future.
(3) The petitioner submits that, the respondent has not paid any maintenance so far, and these
disobeyed the order of this honourable court.
(4) The petitioner further submits that the arrears of maintenance from 01.01.2011 to 31.03.2012 to
Rs. 6000/-
(5) It is therefore prayed that the honourable court may be pleased to commit the respondent to prison
for such kind has the law required or till he paid the arrears of maintenance.
Xxxx xxxx 26. DRAFTING, PLEADING AND CONVEYANCING
Advocate for the Petitioner Petitioner
VERIFICATION
I, the petitioner, to hereby declared that the facts stated above or true and correct to the facts stated
above or true and correct to the best of my knowledge information and belief.
Date: xxxxxx
Petitioner 27. DRAFTING, PLEADING AND CONVEYANCING
EXERCISE XIII
BAIL APPLICATION
Bail Application
IN THE COURT OF BASTI
Criminal Miscellaneous Application No...... of 2015
Devi Lal, D/o Sukhdev aged about 56 years, R/o N8/162 Rajendra vihar, Basti
……Applicant
Versus
Shyam Singh, S/o Ajay Singh aged about 60 years, R/o R-13/A, Rajendra vihar, Basti …Respondent
FIR No. : _____ Dated _____ Police Station:Mankapur Offence Under Sections: 323 and 325 of IPC
Application under Section 437 of CrPC for the grant of Bail Respectfully Showeth: 1. That the
applicant has been involved in a false and frivolous case by one Will Smith by lodging a complaint
with the SHOPS for offence under sections 323 and 325 of the IPC. The applicant/accused has been
arrested by the Police of Police Station: Mankapur subsequent to the above complaint. 2. That it is
submitted that the allegations made against the applicant/accused are false, frivolous and vexatious
and lack in the material substance. The applicant belongs to a very reputed family in his locality. 3.
That the applicant/accused is a permanent resident of Basti and earning livelihood by business. The
applicant has his old parents dependent upon him and the applicant is the only bread earner for the
family. 4. That the applicant/accused is innocent and has been involved falsely due to the personal
grudge to settle the score against the applicant/accused OR due to enmity and family feud. It is
submitted that the complainant is an influential and high-handed person. 31. DRAFTING,
PLEADING AND CONVEYANCING
5. That by getting the applicant/accused arrested the applicant has been deprived of his valuable
fundamental right of liberty by abuse of powers and process of law by the complainant. 6. That the
applicant is willing to furnish surety and bail bonds to the satisfaction of this learned court in case he
is ordered to be released on bail. The applicant is also willing to join the investigations and bind
himself by the terms and conditions laid down by the law or by this Hon'ble court. It is further
submitted that the applicant is not at all required for the investigations. However, if the applicant is
required for investigation, the applicant/accused undertakes to be present as and when required in
accordance with the law. 7. That neither any recovery is to be effected from the applicant nor the
applicant is in a position to temper with the prosecution evidence. The applicant will associate with
the investigation whenever required to do so. It is, therefore, most respectfully prayed that:- (a) That
the applicant may be ordered to be released on bail and this application for bail may kindly be
allowed; (b) That till the decision of this application interim bail may be granted to the applicant; (c)
That the directions may be issued to the police to get the applicant/accused medically examined at
the immediately; (d) Such other orders be also passed in favour of the applicant as deemed fit and
proper in the facts and circumstances of the case and in the interest of justice. Applicant Through,
Advocate
Dated: 31.10.2015 32. DRAFTING, PLEADING AND CONVEYANCING
Affidavit in Support
IN THE COURT OF BASTI
Devi Lal, D/o Sukhdev aged about 56 years, R/o N8/162 Rajendra vihar, Basti
……Applicant
Versus
Shyam Singh, S/o Ajay Singh aged about 60 years, R/o R-13/A, Rajendra vihar, Basti ……
Respondent
Affidavit in support of the application under Section 437 of CrPC I, ______, do hereby solemnly
affirm and declare as under:- 1. That the accompanying application under section 437 CrPC has been
drafted at my instance and under my instructions. 2. That the contents of paras 1 to 7 are true and
correct to the best of my knowledge. 3. That I further solemnly affirm and declare that this affidavit
of mine is correct and true, no part of it is false and nothing material has been concealed therein.
Affirmed here at Basti on 31.10.2015 33. DRAFTING, PLEADING AND CONVEYANCING