IN THE COURT OF HON’BLE SESSIONS JUDGE, UTTAR PRADESH

Cr MP (M) No: 432 OF 2018

Application under Section 438 CrPC

Surendra kumar .............................................Applicants/Petitioners

Versus

State of Uttar Pradesh.........................................…..Respondent

First Application under Section 438 For Grant of Anticipatory Bail in Case
FIR No. 321 Under Section 302 of IPC
Sir,

The applicant/petitioner most respectfully submits as under:-

1- that this is an application for grant of anticipatory bail to the

petitioners who are apprehending their arrest in connection with for the
offence under section 302 of Indian Penal Code.

2- That the petitioners have not moved earlier before this Hon’ble Court
either for Anticipatory Bail or Regular Bail under this matter.
3 - That the applicant/petitioner has no nexus or connection with the
above-mentioned offence.
4- That the applicant/accused is a nationality of India as Hindu is aged
about 35 years.
5- That the applicant/petitioners have not caused any hurt/injury to any
one.
6- That the allegations in the FIR as alleged by the Respondents are
wrong, incorrect and concocted story made by the complainant.
7- That no recovery is pending in the above mentioned case and nothing
is to be recovered from the applicant/petitioner.
8- That the applicant/petitioner undertakes to join the investigation as
and when required by the police of police Station Ramganj road kakwa.
9- That there is no apprehension for absconding or evading of taking trial.
10- That the applicant/petitioner undertakes not to temper with the
evidence or witnesses.
11- That the applicant/petitioner undertakes to abide by all the terms and
conditions as imposed by the Hon’ble court in the event of bail.
12- That the applicant/petitioner undertakes for not to hamper the bail
and ready to furnish the bail bonds of sound amount for the satisfaction of
the Hon’ble court.
13- That in such type of false cases the bail is rule and refusal of the bail
will not serve any purpose.

PRAYER:
It is, therefore prayed that the applicant/petitioner may kindly be
released/granted anticipatory bail and the police concerned of concerned
police station Ramganj may kindly be directed to release the
applicant/petitioner on bail in the event of their arrest

Dated: 12/01/2018

Applicant/Petitioner

Through counsel:

Ghanshyam Singh(Advocate)