IN THE COURT OF ———————, —————–, DELHI
IN THE MATTER OF –
STATE. VS. XYZ
U/S – ______
APPLICATION U/S 438 CRPC FOR GRANT OF ANTICIPATORY BAIL ON BEHALF OF THE __________
Most Respectfully Submitted As Under –
- That the present FIR has been registered on false allegations and bogus facts. All the facts mentioned in the FIR are fabricated and are baseless.
- That the XYZ is a respected citizen of the society and there is no criminal history of him or his family member and police have falsely implicated him in this case. There is no involvement of XYZ in any type of criminal offence
- That the fact stated by complainant against XYZ is false allegation and it does not constitute any kind of criminal offence.
- That there is no such judicial custody required for applicant as far as he is concerned.
- That XYZ is citizen of this country and he is residing here only so for the sake of justice also he will not abscond from India.
- That the XYZ after getting bail won’t do any wrong thing to complainant nor will he abuse him or force him to take back the case.
- The XYZ will take following measures after bail –
- That Xyz will present himself to the police / court whenever he is called to be presented.
- That He will not temper any evidence or witnesses related to this case, and won’t add any evidence in his own favor.
- That he will not induce, or make any promise, to any person who is involved in this case, which could trouble the court or police in their procedure.
- That he shall not leave India without the previous permission of court.
That XYZ will accept all the condition that court / police will mentioned as required in this case, in order to release him.
- The applicant therefore, prays –That the court may direct the release of the XYZ on the bail in the event of his arrest by the police.
And any order which the court may dim fit for him related to this case, may also passed in favor of XYZ.