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AB
AB
Gopinath(aged 20 yrs),
S/o. Murugan …Petitioners/Accused
-Vs-
The Sub Inspector of Police,
Panamadanki Police Station,
Pallathur Rd,Panamadangi,
Vellore District,
Tamil Nadu 632202,
FIR No.110/2018 …Respondent
1. The address for service of notice and summons on the petitioners are
that of their counsel Ms.J.Masani Monisha, Mr.Damodharn at No.102,
Choudhary Nagar 11th Street, Valasaravakkam, Chennai – 600087.
2. The Petitioner approaches this Hon’ble Court with the prayer that this
Hon’ble Court may be pleased to exercised its jurisdiction under section
438 of Cr. P. C. and this Hon’ble court may be pleased to release the
Applicant above named on bail on any suitable terms and conditions, as
this Hon’ble Court may deem fit and proper, in the event of his arrest in
connection with the Panamadanki Police Station FIR No.110/2018,
registered under Section 294(b), 323, 324, 392 and 506(i) of I.P.C.
3. The petitioners humbly submit that the case of the prosecution is that
the petitioner had assaulted and abused the defacto complainant during
a quarrel between the petitioner and defacto complainant and committed
robbery of Rs.1000/-. The statement of complainant was recorded and
offence was registered against the petitioner in Panamadanki Police
Station FIR No.110/2018, registered under Section 294(b), 323, 324, 392
and 506(i) of I.P.C.
Here to annexed and marked as “Exhibit – A” is the Copy of the said
F.I.R. in Panamadanki Police Station.
5. The petitioner submits that the defacto complainant Selvam was friend
with petitioner’s minor brother one Gunashekar aged 17years and that
the defacto complainant constantly influenced petitioner’s minor brother
in playing prohibited gambling games with alcohol and smoking AND
that the petitioner many times previously had verbal quarrel with the
defacto complainant asking him not to corrupt and influence his minor
brother in illegal activities.
8. That the Court below has failed to consider all the facts and
circumstances of the case and has wrongly dismissed the anticipatory
bail application.
9. The petitioner submits that the petitioner is innocent and had not
committed any offence as alleged by the respondent police.
10. The petitioner submits that the petitioner is working as electrician and he
is the only bread winner of the family.
11. The petitioner submits that the petitioner apprehends arrest by the police
in the above said Non-Bailable case throwing the petitioner and his
family to mental harassment, trouble and physical inconvenience.
12. The petitioner submits that the petitioner belongs to good family and no
there are no criminal antecedents against the Petitioner.
13. The petitioner submits that neither any recovery is to be effected from the
petitioner nor the petitioner is in a position to temper with the
prosecution evidence. The petitioner will associate with the investigation
when ever required to do so and that there is no apprehension for
absconding or evading of taking trial.
14. The petitioner submits that the petitioner undertakes to abide by all the
terms and conditions as imposed by the Hon’ble court in the event of
bail.
15. The petitioner submits that the petitioner is ready and willing to accept
any other conditions as may be imposed by the Court or the police in
connection with the case
PRAYER
It is therefore prayed that this Hon’ble court may be pleased to enlarge the
petitioner herein on bail in the event of his arrest in FIR No. 110 of 2018 on
the file of respondent police and any other order which this Hon’ble court
may deem fit and proper in the facts and circumstances of the case may be
also passed in favor of the petitioner thus render justice..
Dated at Chennai on this the 30th day of August 2018 in Chennai.
VERIFICATION
Gopinath(aged 20 yrs),
S/o. Murugan …Petitioners/Accused
-Vs-
The Sub Inspector of Police,
Panamadanki Police Station,
Pallathur Rd,Panamadangi,
Vellore District,
Tamil Nadu 632202,
FIR No.110/2018 …Respondent
1. That the accompanying application under section 438 CrPC has been
drafted at my instance and under my instructions.
2. That the contents of paras 1 to 17 are true and correct to the best of
my knowledge.
3. That I further solemnly affirm and declare that this affidavit of mine
is correct and true, no part of it is false and nothing material has been
concealed therein.
Affirmed here at Chennai on 30th August, 2018.
VERIFICATION