Application under Section 438 of C.r.P.C. for Anticipatory Bail

IN THE COURT OF DISTRICT JUDGE: SOUTH EAST: SAKET COURTS: NEW DELHI

 

In re:-

 

Sachin @ Chander Prakash, Son of Late Sh. Kalicharan, R/o Mohalla Pathanan, Sarna Wali Gali, Muradnagar, Distt- Ghaziabad, U.P.

…..Petitioner

 

Versus

 

The State (NCT of Delhi)

…..Respondent

 

FIR No.: 0656/2015

 

P.S.: Sangam Vihar

 

U.S. 379 I.P.C

 

1st APPLICATION UNDER SECTION 438 OF CR. P.C. ON BEHALF OF THE PETITIONER FOR GRANT OF ANTICIPATORY BAIL

 

 

MOST RESPECTFULLY SHOWETH:-

 

  1. That the petitioner is a law abiding and peace loving citizen of India and is a permanent resident of Muradnagar, District Ghaziabad and residing at the above given address with his family.

 

  1. That the petitioner was working as technician in e-fusion Communication System, which is vendor to the Reliance Jio Infocom Ltd.

 

  1. That the e-fusion Communication System, did not pay salary to the petitioner, and when petitioner asks for his salary the owner of the company snubbed petitioner and threatened him if again he asks for his salary, he will falsely implicate the petitioner in the false case.

 

  1. That now a days the police of P.S. Sangam Vihar visited the house of the petitioner in his absence, and told the family members of the petitioner that he is wanted in the above case F.I.R. As such, the petitioner has grave apprehension of his arrest in the above noted case FIR.

 

  1. That the complainant has falsely implicate the petitioner in the above said F.I.R in collusion with his vendor i.e. e-Fusion Communication System to deprive the petitioner from his legitimate claim pertaining to his salary and other service benefits, due on his employer i.e. e-Fusion Communication System.

 

  1. That the petitioner shall abide by all the terms and conditions imposed by this Hon’ble Court, while admitting him on anticipatory bail.
  2. That there is no chance of absconding the bail or tampering with the prosecution evidence, if the petitioner is admitted on anticipatory bail.

 

  1. That the petitioner shall join the investigation as and when called by the I.O. concerned.

 

It is, therefore, prayed that this Hon’ble Court may graciously be pleased to issue the directions to the I.O./S.H.O./Arresting Officer concerned to release the petitioner on bail, at the event of his arrest, in the interest of justice.

 

Delhi.

Dated:

Petitioner

 

Through

(VIMARSH SINGH)

ADVOCATE

COUNSEL FOR THE PETITIONER

 

 

 

 

 

 

 

IN THE COURT OF DISTRICT JUDGE: SOUTH EAST: SAKET COURTS: NEW DELHI

In re:-

 

Sachin @ Chander Prakash      …..Petitioner

 

Versus

 

The State (NCT of Delhi)      …..Respondent

FIR No.: 0656/2015

P.S.: Sangam Vihar

U.S. 379 I.P.C

 

INDEX

 

SL. NO.

PARTICULARS

PAGES

 

 

1. 1st application under Section 438 of Cr. P.C.

 

  1 – 3
2. Copy of the FIR No. 0656/2015, P.S. Sangam Vihar, U.S. 379 I.P.C.  4 – 5

 

 

 

3. Vakalatnama 6

Delhi.

Dated:

(VIMARSH SINGH)

ADVOCATE

COUNSEL FOR THE PETITIONER

CHAMBER NO. T-13-A,

TEHSIL LANE,

TIS HAZARI COURTS,

DELHI-110054

 

 

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