In the court OF Hon’ble Illaqa magistrate / Duty Megistrate
Sahabad
…………….
STATE OF HARYANA VERSUS Pardeep Raghav son of shri
Desh Raj resident of village
bhatta kaithal , haryana pin
code 136117
FIR NO 73 of 2019
U.S – 406 ,420IPC
P.S -Sahabad
Application to put up case file
with the permission to
surrender and grant bail in the
present matter .
Respectfully showeth -
1. That the petitioner hails from the reputed family
and is permanent resident of the above
mentioned address and there is no likely hood of
his being absconding or jumping over the bail.
2. That the accused applicant declared proclaimed
offender vide order dated 04.08.2023 .
3. That the accused / applicant
4. That the bail is rule of law and the custody of the -
applicant is an exception as in State of
Rajasthan v. Bal chand ,AIR 1977SC 2447:
(1977) 4 SCC 308 :(1978) 1 SCR 535, the
supreme court observed that “ the normal rule is
bail and not jail”. In Datta Ram Singh v. State
of U.P reported as 2018 (2)RCR (criminal),
page 131 hon’ble supreme court held that grant
of bail is general
5. rule and putting a person behind jail is an
exception . Also in Arnab M.Goswami V.State
of Maharastra &ors.2021 (2) SCC 427 it has
been held that “basic rule of our criminal justice
system is “bail not jail” all court must enforce this
principal.
6. That mere allegation does not amount the guilt of
any person, as the same requires evidence which
would be taken during the course of the trial. It is
also settled law that bail is a rule and jail is an
exception.
7. That the trial of the case will take a sufficient long
time and no purpose will be served by detaining
the petitioner in the judicial custody.
8. That the petitioner is ready to furnish the
surety/bail bonds as per the entire satisfaction of
this Hon’ble Court.
9. That it is a fit case for bail.
PRAYER
It is therefore prayed that the petitioner may
kindly be ordered to be release on the bail till
pending decision of the case, in the interest of
justice, law and equity.
Dated. – 18th may 2024
Place – Ambala
Petitioner
Pardeep Raghav Bhatta
Through Counsel :Shubham Rana @ Bhanu partap