Name: Akash Warang

Institution Name- VPMs TMC Law College, Thane, Maharashtra

Registered email id akashwarang@ymail.com

WRIT OF HABEAS CORPUS (CRIMINAL)

THE ACCUSED WAS IN PRISON SO SIGNATURE OF THE PETITIONER
HAS NOT BEEN MENTIONED

IN THE HONBLE SUPREME COURT OF INDIA, NEW DELHI

(Original Criminal Jurisdiction)

Writ Petition No 15 of July 2014

Ram Sharma,
51-A Shanti Niwas, Thane, Maharashtra ------- Petitioner;

Versus

1. Investigating Officer, Mumbai Crime Branch, Maharashtra.

2. The Superintendent, Thane Jail, Maharashtra.
3. The State of Maharashtra ------- Respondents.

PETITION FOR THE ISSUE OF WRIT OF HABEAS CORPUS UNDER ARTICLE

32 OF THE CONSTITUTION OF INDIA
To The Honble the Chief Justice and his companion Judges of the Court aforesaid.
The humble petition of the above named Petitioner most respectfully sheweth:

1. That the petitioner is a resident of 51-A Shanti Niwas, Thane, Maharashtra.

2. That the petitioner has been charged with section 302 of the IPC under which
he has been arrested and put in judicial custody
3. That there was a delay in providing the petitioner with the relevant charge
sheet
4. That the Investigating officer has overlooked crucial evidence and this has
lead to the unreasonable detention of the petitioner
5. That the detention of the Petitioner is unreasonable, improper and without a
material cause.

GROUNDS

1. Because the petitioner was not present at the crime spot at the time of the
murder
2. Because the Investigating Officer has failed to reasonably appreciate and
present evidence thus wrongfully charging the petitioner.
3. Because there has been significant delay in filing the charges in the
Session court and thus the petitioner will have to undergo unfair
imprisonment until the trial actually starts
4. Because the Constitution gives the right to freedom and thus giving the
right to bail, as imprisonment will not serve to meet the ends of justice
5. Because the petitioner is ready to co-operate and furnish with the required
surety, and also satisfy the conditions for bail that the court may deem fit

PRAYER
Wherefore it is respectfully prayed that this Honble Court may be pleased to issue a
writ in the nature of Habeas Corpus to the opposite parties quashing the order of
detention and directing that the Petitioner be set at liberty with the conditions that the
Court may deem fit to impose.

ADVOCATE FOR THE PETITIONER.

DATE 05/04/2014