Thanks to visit codestin.com
Credit goes to www.scribd.com

Scribd
Upload
2K views4 pages

Written Notes of Argument

The document is an application on behalf of an intervener (Valjibhai Khetabhai Sandhu) seeking permission to intervene and oppose the anticipatory bail application of the accused (Raju Pundlik Deshpande). The intervener states that the accused cheated him of Rs. 2.15 Cr and that the accused's story is baseless and illogical. The intervener wants to intervene to ensure justice and bring relevant facts before the court. The intervener cites legal precedents establishing the locus standi of the original complainant in such matters. The intervener requests the court to allow him to intervene and oppose the anticipatory bail application of the accused.

Uploaded by

Sabiha Ansari
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
2K views4 pages

Written Notes of Argument

The document is an application on behalf of an intervener (Valjibhai Khetabhai Sandhu) seeking permission to intervene and oppose the anticipatory bail application of the accused (Raju Pundlik Deshpande). The intervener states that the accused cheated him of Rs. 2.15 Cr and that the accused's story is baseless and illogical. The intervener wants to intervene to ensure justice and bring relevant facts before the court. The intervener cites legal precedents establishing the locus standi of the original complainant in such matters. The intervener requests the court to allow him to intervene and oppose the anticipatory bail application of the accused.

Uploaded by

Sabiha Ansari
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
You are on page 1/ 4

IN THE COURT OF HON’BLE SESSIONS JUDGE, PANVEL

AT RAIGAD

ANTICIPATORY BAIL APPLICATION NO. 586 OF 2022

Valjibhai Khetabhai Sandhu …Ori. Complainant/

Intervener

IN THE MATTER OF:

Raju Pundlik Deshpande …Applicant/Accused

Versus

The State of Maharashtra …Respondent

APPLICATION ON BEHALF OF THE INTERVENER


SEEKING PERMISSION TO INTERVENE AND OPPOSE
BAIL APPLICATON OF THE ACCUSED/APPLICANT.

MAY IT PLEASE THIS HON'BLE COURT:

It is humbly submitted on behalf of the intervener above named as under:

1. That, the present application has been filed by the Applicant/Accused


under section 438 of the Code of Criminal Procedure for an anticipatory
bail in connection with the of FIR being No. 176 of 2022 registered with
NRI Sagari Police Station, under section 406, 420 of Indian Penal Code.
2. That, the intervener is the victim, the Applicant cheated him for the tune
of Rs. 2.15 Cr.
3. It is pertinent to note herein that the applicant is still moving the present

application on a malafide basis. The applicant is putting forward a totally

baseless and illogical story.

4. the Accused / applicant had every likelihood and means to cause harm to

the intervener and to further digest the money swindled away by him

from the intervener. That as such, the applicant does not deserve to be

enlarged in bail since he has not followed the cardinal principal of law

that he has to approach the court with clean hands.

5. The intervener states and submits that having come to know of the instant

application for bail preferred by the applicant, the intervener desires to

intervene in the matter to ensure that no injustice is done him and hence,

by filing the present application, the intervener seeking permission to

intervene in the aforesaid bail application filed by the applicant/accused,

so as to enable him to bring facts before this Hon’ble Court and on the

basis thereof this Hon’ble Court can pass appropriate order thereon and it

is under these circumstances, the present application has been filed.

6. It is most respectfully submitted on behalf of the intervener that law with

regard to the locus of the complainant in the matter of bail/anticipatory

bail to the accused is clear and the Hon’ble Apex Court in its various
decisions has held that it is essential to pursue an offender in the event of

commission of an offence, otherwise, it would effect on the society badly.

So far as locus of the intervener/original complainant in the matter is

concerned, the attention of this Hon’ble Court is invited to the following

judgments of the Apex Court:

6.1BrijNandan Jaiswal Vs. MunnaJaiswal & Anr. – CDJ 2008 SC 1982

6.2Puran Vs. Rambilas – CDJ 2001 SC 318

7. The intervener most humbly states and submits that it is necessary,

expedient, in the interest of justice, good conscience and fair play that this

that this Hon’ble Court may be pleased to permit the intervener to

intervene in the matter and oppose the bail application of the accused and

may be further pleased to grant him to file his written notes of arguments

to the captioned bail application so as to enable the intervener to oppose

bail application of the applicant, if necessary, as the applicant/accused

while filing the captioned bail application, suppressed and distorted

material facts from this Hon’ble Court and come before this Hon’ble

Court with unclean hands, which needs to be brought before this Hon’ble

Court.
8. Under these facts and circumstances, this Hon’ble Court may be pleased

to allow the intervener to intervene in the matter and may be further

pleased to reject anticipatory bail application filed by the

applicant/accused.

AND FOR THIS ACT OF KINDNESS, THE INTERVENR SHALL BE

DUTY BOUND AND SHALL EVER PRAY.

At Panvel

Date. 21.07.2021

Adv. for the Complainant

Adv. Subhash Hulyalkar

You might also like