BEFORE THE HIGH COURT AT
__________________________________
IN
THE MATTER OF:
STATE
VS
_____________________
(FIR Number: _________)
Under Section: (_____________________)
Police Station: (______________________)
APPLICATION U/S 438 CRPC FOR GRANT OF ANTICIPATORY
BAIL ON BEHALF OF THE ACCUSED (name of the applicant of the bail)
MOST
RESPECTFULLY SUBMITTED AS UNDER:
1. That the present FIR has been registered
on false and bogus facts. The facts stated in the FIR are fabricated, concocted
and without any basis.
2. That the police has falsely implicated
the applicant in the present case, the applicant is a respectable citizen of
the society and is not involved in any criminal case.
3. That the facts stated in the complainant
against the applicant are civil disputes and does not constitute any criminal
offense at all.
4. That the applicant is not required in
any kind of investigation nor any kind of custodial interrogation is required.
5. That the applicant is having very good
antecedents, he belongs to a good family and there is no criminal case pending
against them.
6. That the applicant is a permanent
resident and there are no chances of his absconding from the course of justice.
7. That the applicant undertakes to present
himself before the police/court as and when directed.
8. That the applicant undertakes that he
will not, directly or indirectly make any inducement, threat or promise to any
person acquainted with the facts of the case so as to dissuade him from
disclosing such facts to the Court or to any police officer.
9. That the applicant further undertakes
not to tamper with the evidence or the witnesses in any manner.
10. That the applicant shall not leave
India without the previous permission of the Court.
11. That the applicant is ready and willing
to accept any other conditions as may be imposed by the Court or the police in
connection with the case.
12. That the Court below has failed to
consider all the facts and circumstances of the case and has wrongly dismissed
the anticipatory bail application.
PRAYER
It is therefore prayed that the court may
direct the release the applicant on bail in the event of his arrest by the
police.
Any other order which the court may deem
fit and proper in the facts and circumstances of the case may be also passed in
favor of the applicant.
APPLICANT
THROUGH
COUNSEL