IN THE COURT OF JUDICIAL MAGISTRATE
TILHAR (SHAHJAHANPUR)
Misc. Case No. ___ of 2025
Case Crime No.: 133 of 2025
Police Station: Khudaganj
District: Shahjahanpur
Under Sections: 64, 351(3), 333, 115(2) BNS, 2023
IN THE MATTER OF:
Altab S/o Shamsher
Resident of Mohalla Rathan, P.S. Khudaganj,
District Shahjahanpur
…Applicant/Accused
VERSUS
State of Uttar Pradesh
…Respondent
BAIL APPLICATION
(On behalf of accused Altab S/o Shamsher)
The humble application of the accused above named MOST RESPECTFULLY SUBMITTED:
1. That the accused has been falsely implicated in FIR No. 0133/2025, P.S. Khudaganj, District
Shahjahanpur, registered under Sections 64, 351(3), 333, and 115(2) BNS, which corresponds broadly
with Sections 376 (rape), 354 (assault to outrage modesty), 323 (voluntarily causing hurt), and 506
(criminal intimidation) of the IPC.
2. That the accused is in judicial custody, and his custodial interrogation is not required. The FIR is a
product of strained personal equations and motivated by financial demand, not supported by objective
medical or documentary evidence.
3. That the relationship, if any, between the applicant and the complainant was based on mutual respect
and communication. There was no force, threat, or criminal intent, and the applicant never made
any false promise of marriage or coerced the complainant in any way.
4. That the contents of the FIR are vague, exaggerated, and afterthought, as the alleged incident took
place on 20.05.2025, but the complaint was lodged only on 26.05.2025, after an unexplained delay of 6
days, which casts serious doubt on the genuineness of the allegations.
5. That it is most respectfully submitted that the accused has been residing in Mangal Bihar Colony,
Sanganer, Jaipur , Rajasthan, for the past 2.5 years, where he is employed as a tailor at a local
fashion shop named “Neelam Fashion” located at Sanganer –Jaipur. and only visits his native
village occasionally during festivals or family functions. This fact clearly shows that the applicant was
not regularly present at the location of the complainant, and the allegations of frequent threats or force
are completely fabricated and untenable.
6. That the complainant is a widow residing in the same neighborhood as the applicant, and the FIR has
been lodged due to personal grudge and on account of denying financial help.
7. That the applicant has no prior criminal antecedents, is a permanent resident of Mohalla Rathan,
P.S. Khudaganj, Shahjahanpur, and undertakes to fully cooperate in the investigation and to be available
for trial proceedings.
8. That at this stage custodial interrogation of the applicant is neither warranted nor necessary. The entire
FIR appears to be a result of malicious intent to settle personal scores, and no medical evidence or
corroboration has been placed on record as yet.
9. That the applicant is ready to furnish sureties to the satisfactionof this Hon’ble Court and undertakes
not to tamper with evidence or influence any witnesses.
10. That the applicant is the sole breadwinner for his aged parents and dependent family, and his
incarceration will result in irreparable hardship.
PRAYER
It is therefore most respectfully prayed that this Hon’ble Court may graciously be pleased to:
Enlarge the applicant/accused Altab on bail in connection with FIR No. 0133/2025, P.S. Khudaganj,
District Shahjahanpur, on such terms and conditions as the Hon’ble Court may deem fit and proper in
the interest of justice.
AND FOR THIS ACT OF KINDNESS, THE APPLICANT AS IN DUTY BOUND SHALL EVER
PRAY.
Place: Shahjahanpur
Date: __/06/2025
(Through Counsel)
[Virender Kumar]
Counsel for the Accused Altab
