IN THE COURT OF SH. SATISH KUMAR LD.
ASJ ROHINI COURT
DELHI
IN THE MATTER OF:
STATE VS MOHIT AND ORS
FIR NO. 167/2022
US/302,307,149,120-B,34 IPC
24,27,54,59 ARMS ACT
P.S MAHINDRA PARK
IN J.C - 01.05.2019
APPLICATION FOR GRANT OF BAIL U/S 439 OF CR.P.C. ON
BEHALF OF THE APPLICANT/ ACCUSED NAMELY SRI RAM @
PAPPU SON OF BABBU LAL R/o 123/ N 83 LAL BAGH AZAD PUR
DELHI -33
MOST RESPECTFULLY SHOWETH:
1. That the Applicant/accused is the law binding citizen of India.
2. That the applicant/ accused is an innocent person and has deep
roots in society.
3. That the applicant/accused has clean and clear antecedents now
and he is acquittal in all previous cases.
4. That no recovery has been affected from the applicant/accused, if
any has been planted by the concerned police officials.
5. That the applicant/accused is not in J.C. from 22.09.2022 he is on
interim bail he surrendered in front of hon’ble court on 01. 05. 2019
and the same he surrendered on 14.3. 2021 in Tihar jail applicant
/accused never misused the liberty.
[Link] the hon’ble session court has granted extension of interim
application from 22.10.2022 to till now at 4 times but the
applicant/accused has never misused the liberty The applicant/
accused has gone through a hernia operation in Anand Maya Multi-
specialty hospital few days ago and recently he has been gone
through surgery again in Hindu Rao hospital due to reason of poor
condition applicant /accused and his family are unable to take
treatment in private hospital even wife of applicant/accused is
suffering from many diseases no body is available for proper
upbringing of applicant/accused family .
7. That applicant/accused has been facing health issued from last
many years all medical document of applicant/accused and his wife
are annexed as an annexure 1
8. That the applicant/accused is falsely implicated in the present case
and he has not committed the above offence as alleged by him.
10. That applicant/accused was working as a fruit vegetable
commission agent in azadpur mandi Delhi 33.
12. That the applicant/accused is ready to abide by all terms and
conditions imposed by this hon’ble court.
13. That the investigation has been completed and there is no fruitful
purpose would be served by keeping the applicant/accused behind
the bars.
14. That the applicant/accused conduct is positive in freedom till now
neither he temperament any evidence nor he threaten anyone of the
witnesses.
[Link] the applicant/accused is ready to furnish reliable surety for
the entire satisfaction of this hon’ble court.
PRAYER:
It is therefore under the above said facts and circumstances, most
respectfully prayed that the hon’ble court may kindly be pleased to
grant regular bail to the applicant/ accused in the interest of
justice.
Delhi: APPLICANT
Through
COUNSEL
Dated: