IN THE COURT OF JUDICIAL MAGISTRATE FIRST CLASS
PANVEL COURT
C.R. No - …… of 2021
State of Maharashtra …Complainant
V/s.
Namdeo Patil and 3 others …Accused
APPLICATION UNDER SECTION 436
CRPC FOR GRANT OF BAIL ON
BEHALF OF THE ACCUSED
IT IS MOST RESPECTFULLY SUBMITTED AS UNDER:
It is respectfully submitted on behalf of the Accused
above named as follows:
That the above named accused are alleged with offence/s
punishable u/s ……………………, read with section 34 of
IPC.
Application prefers this Bail Application for their release
on the following grounds:-
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 applicants
and arrested them in the present case, the applicants are
respectable citizens of the society and are not involved
any criminal case.
3. That the facts stated in the complainant against the
applicants are civil disputes and does not constitute any
criminal offence at all.
4. That the applicants are not required in any kind of
investigation or any kind of custodial interrogation is
required, nor is any recovery to be made at the instance
of the applicant.
5. That the applicants are having very good antecedents,
they belong to good family and there is no criminal case
pending against them.
6. That the applicants are permanent resident and there
are no chances of them absconding from the course of
justice.
7. That the applicants undertakes to present them self
before the police/court as and when directed.
8. That the applicants undertakes that they 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 applicants further undertakes not to tamper
with the evidence or the witnesses in any manner.
10. That the applicants shall not leave India without the
previous permission of the Court.
11. That the applicant are 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 the court may order for the
release of the applicants on bail in the interest of justice.
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 applicants.
Place: Panvel
Date: 22/03/2021 Adv. For Accused