Anticipatory bail application, How do you write a petition for bail?

     (Anticipatory bail application is filed under Section 438 of the Code of Criminal Procedure by an accused person who is apprehending arrest by the police.पुलिस से बचने के लिए अग्रिम जमानत लिखने का तारीफ,सेम्पल)

            The court of Spl.Judge,Excise act

           Ref- Gandhi maidan p.s. case no 01/14

           Ram kumar S/o shyam kumar 
            R/o sabji bag p.s. gandhi maidan
             Dist patna__________Petitioner

          State of Bihar _______Opposite party

                            The humble Anticipatory
                             Bail Application/petition
                             On behalf of above named
                             Petitioner most respectfully


(1) That the petitioner is quite innocent and he has not committed any offence and been falsely implicated in this case due to local enmity.

(2) That on the behalf of petitioner no anticipatory Bail application/petition has filed before this court or high court earlier.

(3) That prosecution case as alleged in FIR is that S.I. sohan of gandhi maidan p.s. gave written information that on 25/11/2014 at 20:20hrs he departured by police vehicle for night patrolling and raid with other police force and reached sabji bag english wine is being kept hidenly by ram kumar when information reched lal bag some people started flying away neither and their to see the police vehicle. It is further alleged that when near naya tola a person filed away speedily ,who was followed by patrolling police but he fled away taking advantage of darkness and recognized ram kumar so not know ,chacha ramu when jhopri was searching then the wine as mentioned sized and seizure list was prepared.

(4) That the alleged  in FIR are totally false,wrong,baseless,concocted fabricated.

(5) That noting has been recovered from the possession of the petitioner.

(6) That it is evident from FIR that name of the person is not mentioned who was has disclosed the name of petitioner ram kumar because occurrence was took place at midnight .

(7) That it is also evident from the FIR the seizure witness are from village phatuha which 21 KM distance from place of occurrence.

(8) That antecedent of the petitioner is apprehending arrest by the police.

(9) That the petitioner is man of means as such there is no chance of his absconding.

(10) That on behalf of petitioner bailors are ready to stand as sureties.

(11) That petitioner is ready to give undertaking u/s 438(2) cr.p c.

                    It is therefore prayed that your honour be pleased to grant the petition anticipatory bail and in case of surrender or arrest by police be enlarged on bail. And for this petitioner shall ever pray.

               Neeraj kumar advocate

Post a Comment