0% found this document useful (0 votes)
10 views9 pages

Anticipatory Bail Application for Raj Kumar

The document outlines a bail application for Raj Kumar, who is seeking anticipatory bail in connection with FIR No. 334/2025 under various sections of the Bharatiya Nagarik Suraksha Sanhita, 2023. The applicant claims to have been falsely implicated and has cooperated with the investigation, asserting that the alleged stolen property has been recovered. The application is submitted by his advocate, Rahul Mishra, and requests the court to grant bail in the interest of justice.

Uploaded by

Iftikhar Alam
Copyright
© All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as PDF, TXT or read online on Scribd
0% found this document useful (0 votes)
10 views9 pages

Anticipatory Bail Application for Raj Kumar

The document outlines a bail application for Raj Kumar, who is seeking anticipatory bail in connection with FIR No. 334/2025 under various sections of the Bharatiya Nagarik Suraksha Sanhita, 2023. The applicant claims to have been falsely implicated and has cooperated with the investigation, asserting that the alleged stolen property has been recovered. The application is submitted by his advocate, Rahul Mishra, and requests the court to grant bail in the interest of justice.

Uploaded by

Iftikhar Alam
Copyright
© All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as PDF, TXT or read online on Scribd

CASE INFORMATION FORMAT

CIVIL
CRIMINAL
DISTRICT : WEST
[Link] PLAINTIFF/PETITIONER/APPELLANT/DECREE HOLDER ETC.
(PLEASE FILL UP ALL THE RELEVANT FIELDS &(*) FIELDS ARE
MANDATORY)
1. *Name of plaintiff RAJ KUMAR

2. * D/o GHASI RAM

3. *Address khasra no 668 Block b Karan vihar phase 5 Kirari


Suleman Nagar Delhi 110086
4. Aadhar Card No. Aadhar Card No. Pin Code 1 1 0 0 8 6
7080-4410-2496

5. *Gender Male Female Others Nationality INDIAN


6. Date of DD MM YY *Age 55 Years
Birth/*Age
7. *Mobile --------------------------
No./*E-mail
8. *Act/Section

9. Valuation of Suit Court fees ascertained: N.A


Court Fee paid/deposited: N.A

10. *Police Station NEHAL VIHAR


11. *F.I.R. No.& 334/2024
Year

[Link] DEFENDANT/ACCUSED/RESPONDENT/JUDGEMENT DEBITOR ETC.


(PLEASE FILL UP ALL THE RELEVANT FIELD)
1. *Name of STATE
Defendant
2. * S/o, w/o, D/o
3. *Address P S NEHAL VIHAR

4. Aadhar Card No. Aadhar Card No. Pin Code

5. *Gender Male Female Others Nationality INDIAN


6. Date of Birth/*Age DD MM YYY *Age

7. *Mobile E-MAIL IN CAPITAL LETTERS


No./*E-mail

[Link] ADVOCATE FOR PLAINTIFF/COMPLAINANT/PETITIONER/DECREE


. HOLDER ETC.
1. *Name of Advocate RAHUL MISHRA *Bar Regn. No.
D/11963/2021

2. *Address 182, GAJANAND


BLOCK TIS HAZARI
COURTS DELHI
110054
3. *Mobile No/*E- mail 9868712771 ADVRAHULMISHRA3010@G
[Link]

Submitted by:

RAHUL MISHRA
ADVOCATES FOR PLAINTIFF

DELHI
DATED
IN THE COURT OF THE HON’BLE SESSION JUDGE DISTRICT WEST
TIS HAZARI COURTS DELHI
BAIL APPLICATION NO. /2025

In the matter of:


Raj Kumar ...Applicant

VERSUS

State ...Respondent

FIR No.: 334/2025


Dated: 26.04.202
U/s 304(2)/61(2)/3(5) BNS, 2023
Police Station: Nehal Vihar

INDEX

[Link] PARTICULARS PAGE NO

1. MEMO OF PARTY 1

2. ANTICIPATORY BAIL APPLICATION UNDER 2-3


SECTION 482 OF THE THE BHARATIYA
NAGARIK SURAKSHA SANHITA, 2023 ON
BEHALF OF ACCUSED RAJ KUMAR
3. COPY OF ADHAAR CARD OF APPLICANT 4

4. VAKALATNAMA 5

Place: Delhi
Date: 15.04.2025
Applicant
Through

Counsel
Rahul Mishra & Associates
182 Gajanand Block Tis Hazari Court Delhi
9868712771
Advrahulmishra3010@[Link]
1

IN THE COURT OF THE HON’BLE SESSION JUDGE DISTRICT WEST


TIS HAZARI COURTS DELHI
BAIL APPLICATION NO. /2025

In the matter of:


Raj Kumar ...Applicant

VERSUS

State ...Respondent

MEMO OF PARTIES

Raj Kumar
S/o Ghasi Ram,
R/o khasra no 668 Block b
Karan vihar phase 5
Kirari Suleman Nagar
Delhi 110086 ...Applicant

VERSUS

State
(Through S.H.O PS NEHAL VIHAR)
...Respondent

Place: Delhi
Date: 15.04.2025
Applicant
Through

Counsel
Rahul Mishra & Associates
182 Gajanand Block Tis Hazari Court Delhi
9868712771
Advrahulmishra3010@[Link]
2

IN THE COURT OF THE HON’BLE SESSION JUDGE DISTRICT WEST


TIS HAZARI COURTS DELHI
BAIL APPLICATION NO. /2025

In the matter of:


Raj Kumar
S/o Ghasi Ram,
R/o khasra no 668 Block b
Karan vihar phase 5
Kirari Suleman Nagar
Delhi 110086 ...Applicant

VERSUS

State
...Respondent

FIR No.: 334/2025


Dated: 26.04.202
U/s 304(2)/61(2)/3(5) BNS, 2023
Police Station: Nehal Vihar

ANTICIPATORY BAIL APPLICATION UNDER SECTION 482 OF THE


THE BHARATIYA NAGARIK SURAKSHA SANHITA, 2023 ON BEHALF
OF ACCUSED RAJ KUMAR

MOST RESPECTFULLY SHOWETH:-

1. That the applicant is a law-abiding citizen having no criminal antecedents and


is filing this application seeking anticipatory bail in connection with the
above-mentioned FIR. The applicant is voluntarily surrendering before this
Hon’ble Court to show his bona fide and willingness to cooperate with the
investigation.
2. That the applicant has been prima facie falsely implicated in the present case.
He had no role, knowledge, or intention to participate in the alleged incident.
3

3. That the alleged stolen property, i.e., a gold chain, has already been recovered.
A video recording clearly indicating the applicant’s innocence has been
submitted to the Investigating Officer and forms part of the investigation
record.
4. That there is no purpose of keeping the applicant in judicial or police custody
especially when the recovery has been effected and he has cooperated with
the investigation. No further custodial interrogation is necessary.
5. That the IO is attempting to falsely implicate the applicant in pending cases
merely on the disclosure of a co accused which has no corroboration or direct
evidence. The applicant has not committed any offence and is being used as a
scapegoat to close multiple pending cases.
6. That the applicant has fully cooperated with the investigation, and no further
custodial interrogation is warranted. The continued incarceration of the
applicant serves no purpose and would be a violation of his fundamental rights
under Article 21 of the Constitution of India.
7. That the applicant has no prior involvement in any criminal case and has never
been convicted by any court of law.
8. That there is no chance of absconding of the applicant from the jurisdiction of
the court or in any way tempering with the evidence or intimidating the
witness by the applicant
9. That the applicant undertakes to cooperate with the investigation and abide by
any conditions imposed by this Hon’ble Court. The applicant is ready and
willing to furnish surety to the satisfaction of this Hon’ble Court.
4

PRAYER
In view of the foregoing facts and circumstances, it is most respectfully
prayed that this Hon’ble Court may kindly be pleased to:

a. Grant anticipatory bail to the applicant in connection with FIR No.


334/2025 dated 26.04.2025, under Sections 304(2)/61(2)/3(5) BNS,
2023, Police Station Nehal Vihar, District West Delhi, in the interest of
justice;

b. Pass any other or further order(s) as this Hon’ble Court may deem fit and
proper in the facts and circumstances of the present case.

AND FOR THIS ACT OF KINDNESS, THE APPLICANT AS IN DUTY


BOUND SHALL EVER PRAY.

Place: Delhi
Date: 15.04.2025
Applicant
Through

Counsel
Rahul Mishra & Associates
182 Gajanand Block Tis Hazari Court Delhi
9868712771
Advrahulmishra3010@[Link]
5

wrct srm R e enisnnid]


Senverrmant of e TSI 3 DIIC O ALIIGnY OF i
e
R
= R008 0203970
A
MOB 96676227,7
-
Rl &
7080 4410 2496 0 4410 2496
" 0806 4595
[
P e
—_—— N > (1s
)
2
€.[Link]. .. 1 6
FIR No. .234]’
us ...3,251&1:).(&.‘.&).‘. )5
[
INTHE COURTOF _Session Tudyy Disid Wesk 7o Harmy, Lot De L
Suit/ Appeal No.
! JURISDIC ION OF 202
Inre ;-

Plaintiff(s) o, Petitioner(s)
o4 -Hurtax Appellant(s) Complainant(s)
l VERSUS
Slale Defendant(s) /Respondent(s) / Accused
KNOW ALL to whom these present shall come that 1
__fi_&o_&_mgg_m__ we _&\_Kgmu
Lo W Ceb, Mok B Phrtecy vger oiot
The above name d,
he
A\;\‘)\ficq\,\% do hereby -ppolmk 2
LA T4
“Rihd Miskey Tk 000w V. frga i il
Nusha
Adiscare Avocie Boimie ‘\“V'q{
ez 202 S\apoy Y| sBusfaero
Dmshay N
Q2 Gejrad Blecke c- WA CLTosthh
“THe RN Nihawba%&‘9 h
Blocje THe selly
(herein after called the advocatels to be
my/our Advocate in the above-noted case -
authorize him:-q““kz(u‘
To act, appear and plead in the above -noted case this court of in any other court in which the same
or heard and aiso in the appellate court including High courtin subjec may be tried
To sign file, verify and present pleadings, appeals cross- t to payment of fees separately for each court by melus.
executions review, revision, withdrawal, compromise or objections or petitions for
ofher petiions or affidavits. o other i
gggg
documents as may be deemed necessary or
proper
stages subject to payment of fees for each stage. for the prosecution of the said case in all its
Tofile and take back documents, to admit and/or deny the docum
To withdraw or compromise the said case or submit to arbitr ents or opposite party.
disputes that may arise touching or in any manner relating to ation any differences or
To take execution proceedings on paying separate fee. the said case.
To deposit, draw and receive money, cheques, case and grant recei
do all other acts and things which may be necessary o be done pts hereof and to
course of the prosecution on the said case. forthe prog ress and in the

To appoint and instruct any other Legal Practitioner authorizing


conferred upon the Advocate whenever he
him to exercise the powe eby
may think fit to do so and t © sign the power of attorney on our behalf.
And I/ We the undersigned do hereby agres to ratify and conf irm all acts done by the Advocate or
his substiute in the matter as mylour own facts, as
And I'We undertake that I/ We or mylour duly authorised if done by melus to g intents and purpose.
andwillinformtheAdvocate for appearancewhen the case s called. agent would appear in court and all hearings
And I7We undersigned do hereby agree not o hold the advocate of his
the said case-The adjourment costs whenever ordored by the substitu responsible for the result of
andretainfor himself. court shall be of the Advocat wihich he shall receive
AndWe undersigned do hereby agree thatin the event of the
paid to the advocate remaining unpaid he
whole or part of the fae agreed by me/usto be
shall be entitled to withdraw from the Prose
same is paid up. The fee settle is only for the above case cution of the said case until the
paid./We wil not b enitied for the refun of the same and above Court , e hereb y agree that once the fee is
morethan3yearsthe original fee shallbe paiddagain by me/us
in any case whatsoover gy if the case prolo ngs for
INWITHNESS WHERE OF 1/We dohereuntosetmy/ourhand tothes
e Presentsthe contentsofwh ichhave
beenundertstood byme/usonthis .dayo,
Accepted subject to the terms of the fees
2028
\ A\ sla-N| 2
iz
Client
! 1dentity the Signature/Thumb Impression Client
of the Below Mentioned Person,
Who Has been Signed In my presen
ce. The Client .

You might also like