SAMPLE DRAFT – ANTICIPATORY BAIL UNDER SECTION 438 OF CR. PC

IN THE COURT SESSIONS JUDGE (DISTRICT____________), DELHI

TIS HAZARI COURTS DELHI

 

ANTICIPATORY BAIL APPLICATION NO __________ OF   2021

 

IN THE MATTER OF;

X_______S/o_______R/o                                                                                                  APPLICANT

VERSUS

STATE                                                                                                                                   COMPLAINANT

 

FIR NO._________OF 2017

UNDER SECTION: ____________

POLICE STATION: _____________

 

APPLICATION FOR THE GRANT OF ANTICIPATORY BAIL UNDER SECTION 438 OF THE CODE OF CRIMINAL PROCEDURE, 1973

 

The Applicant above named most respectfully submits as under

  1. That the Applicant is a young man aged 20 years residing at_____________, Delhi. He is also a Director of M/s. ABC Ltd. which is a very leading company engaged manufacture of electrical appliances.
  2. The Applicant is a very respectable person of his locality and is a peace-loving citizen
  3. That the Applicant was on friendly terms with Miss Y major daughter of the Complainant. However, the relationship of the Applicant with Miss Y was not liked by her family members so much so that they had stopped Y from meeting the Applicant and had threatened her that in case she meets the Applicant, they will implicate the Applicant in some false criminal case.
  4. That Miss. Y had also written number of letters to the Applicant calling upon him to marry her as she had feared that her family members may sabotage her relationship with the Applicant, which shows that family members of Miss. Y were deadly against the Applicant and were looking for some opportunity to falsely implicated him in some false criminal case in order to pressurize him to severe his relationship with Y.
  5. That on 5 January, 2010, the Applicant had gone to meet his friend, who is residing in the neighborhood of Miss. Y. When the Applicant reached the house of his friend, he was suddenly attacked by father, uncle and brother of Miss. Y as a result of which he fell down and sustained abrasion injuries. The Applicant’s friend came to the rescue of the Applicant and with great difficulty, the Applicant was saved from the clutches of Miss. Y’s family members by other neighbors and passersby.
  6. That the police have registered a false FIR against the Applicant A bare on perusal of the said FIR reveals that the brother of Miss. Y attacked the Applicant and not vice versa. As a mater of fact, the aggressor has manipulated with the police and has falsely implicated the Applicant. The Applicant is in fact the victim at the hands of the Complainants who have conspired with the police and got this case registered against them. The Photostat copies of the letters written by Miss. Y to the Applicant are annexed herewith.
  7. That the FIR registered against the Applicant is absolutely false and incorrect. The Applicant is not at all involved in the alleged offence and has been falsely implicated by the police.
  8. That the Applicant apprehends that he may be arrested in pursuance of the aforesaid false and fictitious complaint.
  9. That the police officials have visited the premises of the Applicant in his absence and there is every likelihood of his being arrested in the instant case.
  10. That the Applicant undertakes to join the investigation as and when directed to do so.
  11. That the Applicant is a permanent resident of Delhi and there is no chance of his absconding in case he is granted anticipatory bail.
  12. That the Applicant has never been involved in any criminal case except the present one.

 

PRAYER

It is, therefore most respectfully prayed that the Applicant be released on bail in the event of his arrest and appropriate directions in this regard may please by sent to the concerned Investigating officer/S.H.O. Any other order/orders which this Hon’ble Court may be deem fit and proper on the facts and circumstances of this case may also be.

APPLICANT

 

THROUGH

New Delhi.

Dated:_____________

ADVOCATE

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