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IN THE HIGH COURT OF JUDICATURE AT NEW DELHI

CRIMINAL APPELLATE JURISDICTION
BAIL APPLICATION
IN
SC No.70/13 & 100/13

Mr.SAURABH …..Applicant /Applicant No.1

Versus

The State of DELHI ……Respondents

(Police station)

Application for Bail and Suspension of Execution of sentence of Order

u/s 389(1) of CrPC, 1973.

MOST RESPECTFULLY SHOWETH:

1) That Mr.Saurabh (herein after ref. to as applicant) is a law abiding citizen

of India and a man of utmost respect and good character.

2) He is the owner of a 5 star Hotel; stakes of which are used to fund 2

NGOs which are working for the welfare of orphans in U.P &
Rajasthan which are governed by him.

3) The Applicant submits that the Trial Court has found the Applicant herein
as guilty of having committed an offence u/s 109,379,201,120(B), 302
read with section 34 of IPC by their Judgment.

4) That the applicant has been falsely implicated in the present case in order
to jeopardize his hard earned reputation, his market standings & to hinder
his business growth i.e. to cause financial discrepancies.
5) That the applicant is neither directly nor indirectly part or the mind
behind the mishappenings occurred with the deceased and his family and
further pass over his condolences to such activity.

6) The applicant was arrested on 25/09/2013 from the Majnu Ka Tila bus
stand & is in judicial custody since then. The arrest is on the basis of
F.I.R Cr no.415/2013 which was lodged on 23/09/2013 by Ms.Sujata who
is the wife of applicant’s Client Mr.Harjeet (herein after ref. to as
Deceased).

7) The allegations put up by Ms. Sujata are frivolous, false and totally
vague. Mr. Saurabh on the other hand provided the deceased’s family
with all the possible support & help to the best of his abilities in finding
& supporting Mr.Harjeet in his tough times.

8) After the cross examination of Ms.Sujata (P.W.1) u/s161 of Cr.P.C there

are certain discrepancies and omissions found in her statement which
was earlier recorded; this clearly points out the malice & fraudulent
motives in order to disrupt applicant’s name & abuse Hon’ble Court’s
procedure and time and to take undue advantage of the judicial system.

9) That the relationship b/w deceased and his wife was going through thin
time before the disappearance of Mr.Harjeet they had an exhaustive
quarrel. Also, to mention Ms.Sujata’s in-laws were not in all praise of
their daughter-in-law’s behavior, they were residing separately i.e.
Mr.Harjeet (deceased) and Ms.Sujata in one house and her in laws in
other.

10) Ms.Sujata admits that her husband Mr.Harjeet had not been in a
perfectly sound mind for quite some time and had a habit of putting his
things wherever. The recognizance of M.o’s 1-3 from Bala(accused no.2),
applicant’s assistant might not be in relation to such wrong deed as the
occurrences of their meet are not known to anyone. These things might
have been given by the deceased himself to keep it in C/o Mr.Saurabh.
Also, the information that Mr.Harjeet(deceased) had to attend a
function after the performance of puja was known to all and further
conveyed by the applicant to his family members.
 11) To the matter of court, there had been a delay of 53 days in lodging
the F.I.R i.e. on 23rd September, 2013 after the day Mr. Harjeet was
allegedly last seen i.e. on 1st August, 2013. Despite the fact that a report
of an unidentified dead body (Mr. Harjeet’s) appeared in the local
newspaper on 15 September, 2013.
And a further delay of 3 days after the report of her in laws murder
appeared in the local newspaper i.e. on 20th September, 2013 which in
fact was in the knowledge of Ms.Sujata.
The above facts highlight the misintention or an ulterior motive behind the
omissions and delay of proper and relevant information to be presented in
the hon’ble court that may be in order to disrupt or to destroy and gather
the relevant evidence.

12) That the applicant has a good name in the society and has created a
business value with his hard work. He is been an active participant of
social welfare and upliftment of the needy. With such character and
principles, the applicant could not be blamed of any wrong doings with
anyone by his known ones and associates.

13) And this conviction would not only be hindrance to his credibility
and reputation but also would cause disturbance in the smooth working of
the 2 orphans which are running by the stakes of his business.

PRAYER:

In view of above facts and circumstances, it is most respectfully prayed that this

Hon’ble Court may be pleased to grant bail to the applicant in the interest of justice.

That the applicant undertakes to co-operate with the investigation in every manner.

The applicant also undertakes to appear each and every date as and when directed

by this Hon’ble Court or I.O. Concerned.

Pass such other or further order as this Hon’ble Court may deem fit and proper

under the facts and circumstances in favor of the applicant.