IN THE COURT OF THE VIII ADDL CHIEF METROPOLITAN
MAGISTRATE: AT BANGALORE
C.C. No. _________/____
State by Sheshadripuram Police … Complainant
- Vs
Uday Kumar & Anr … Accused
APPLICATION UNDER SECTION 436 OF THE CODE OF CRIMINAL
PROCEDURE, 1973
The Accused No. 1 and 2 beg to submit as under:
1. The complainant police have registered the above case against the
accused for the offences punishable under Section 323, 341 & 504 of
IPC. The accused are innocent of the alleged offences. They have not
committed the alleged offence and the Complainant police have falsely
implicated the accused in the above case.
2. That both the accused are permanent residents of Bangalore and
law abiding citizens. The Accused are authorized railway porters in
the Bangalore City Railway Station. The accused are daily wagers.
3. The accused persons hail from respectable family and have deep
roots in the society and they are only male earning members in their
respective families. If the accused are not enlarged on bail, the accused
and their family members will be thrown on streets and it will cause
great damage to their reputation and leave them deeply pained and
agonised. If the accused are enlarged on bail the complainant will not
suffer any loss or injury.
4. Both the accused undertake to co-operate with the investigation
agencies and not to tamper with the prosecution witnesses.
5. The accused further undertake to abide by the conditions
that may be imposed for their enlargement on bail and further
undertakes to appear before this Honble Court on all dates of hearing or
as and when directed by this Honble Court.
6. That the accused are ready and willing to furnish the solvent
surety for their enlargement on bail.
WHEREFORE, the accused most humbly prays that this Hon ble
Court be pleased to allow the application by enlarging the accused
persons on bail, in the interest of justice and equity.
Bangalore
Date: 7-9-2004 Advocate for Accused No.1 & 2
IN THE COURT OF THE VIII ADDL CHIEF METROPOLITAN
MAGISTRATE: AT BANGALORE
C.C.No. _____/___
State by Sheshadripuram Police … Complainant
- Vs
Uday Kumar & Anr … Accused
SURETYS AFFIDAVIT
I, K.Manukumar, aged 28 years, S/o Late Manjappa, residing at
No.34-D, Railway Quarters, Bangalore – 560 023, do hereby solemnly
affirm and state on oath as follows:
1. I submit that the accused are well known to me and both of them
are friends. I am willing to stand surety to the accused persons and
undertake to cause their regular presence before this Honble Court on
all dates of hearing.
2. I am permanent resident of Bangalore and working as Helper in
Southern Railway, Bangalore and I am drawing a monthly salary of
Rs.3350/-. The copies of the Identity Card and Pay Slip for the month
of August 2004 are herewith enclosed for the kind perusal of this Hon ble
Court.
3. I am solvent and I shall abide by the conditions that may be
imposed by this Honble Court in accepting my surety for the
enlargement of the accused in the above case.
VERIFICATION
I, K.Manukumar, solemnly affirm that this is my true name and
signature and the contents of this affidavit are true to the best of my
knowledge and belief.
Identified by me
Deponent
Sworn to Before Me
Advocate
Bangalore
Date: 7-9-2004
No. of corrections:
Assignment No.11 (Problem) Regular Bail U/S.436
Mr.Majnu Bhai and Shakeel Ahmad were residents of Bangalore. They were
working as porters in Bangalore Railway station and they were childhood
friends. The Sheshadripuram Police, Bangaluru have registered the complaint
against these two for the offences punishable under Section 323, 341 & 504
of IPC. The accused are innocent of the alleged offences.
Both are the male earning members of the family and if they were arrested the
family will be put great agony. Because of the criminal case there is a clear
apprehension to their reputation in the society. So, to seek the preliminary
justice in the form of Bail they want to approach the court of law. Draft a
Regular Bail U/S 436 of Cr.P.C.