IN THE COURT OF HON’BLE LD.
DISTRICT & SESSION
JUDGE, DISTT. SHD KKD DELHI.
IN THE MATTER OF: -
STATE VERSUS MOSIN@BHURA
S/O- Sh. ZAHIR
FIR-0394/23
PS-SEEMAPURI
U/S – 307,506,
IPC & 27 ARMS ACT
2nd APPLICATION U/S 439 CR.P.C. FOR GRANT OF BAIL
ON BEHALF OF THE ABOVE-NAMED
APPLICANT/ACCUSED.
It is most respectfully submitted as under: -
1. That the applicant/accused is a peace loving and law-
abiding citizen of India, and residing at the above
given address.
2. That the applicant/accused has been falsely implicated
by the police officials of P.S. Seemapuri, Delhi, with the
connivance of complainant.
3. That the applicant/accused was arrested by the
concern police officials of P.S. Seemapuri, Delhi and
was produced before the concern court. he was sent
J.C on___________, since he is in J.C.
4. That it is second Bail Application and First bail
application was withdrawal due to the pendency of the
chargesheet, Now the chargesheet has been filed in
this present matter.
5. That complainant’s son namely Mayur, has a history of
misconduct In society and lack of respect towards
woman. Before the incident on dated 25.05.2023 the
above said person namely Mayur molested a girl
(known to the applicant/accused). When the
Applicant/Accused went to the complainant’s house
along with the Girl to report the incident, Mayur
behaved aggressively instead of apologizing. He
verbally abused, physically assaulted, and threatened
to falsely implicate the applicant/accused in in a case.
Eventually, the applicant/accused forcibly removed
from the house. Subsequently, Mayur’s father falsely
implicated the applicant/accused in the above
mentioned, case/FIR on dated 25.05.2023 due to prior
enmity.
6. That the applicant/accused was not arrested at the
scene of the alleged incident, and he was not present
there. There are no independent witnesses to
corroborate police official version of events.
7. The applicant/accused is known to be related to the
complainant, and it is evident that the complainant
falsely implicated him due to previous enmity.
8. The applicant/accused is innocent and has not
committed any offense as alleged by the police
officials. Nothing incriminating has been recovered
from him or at his instance; if anything has been
shown, it is likely to be planted.
9. The applicant/accused is not required for the purpose
of custodial interrogation, and there is no valid reason
to keep him behind bars.
10. The applicant/ accused assures the court of their
commitment to attend all court proceedings punctually
and without fail. They are also prepared to provide a
sound surety to the satisfaction of this Hon'ble Court.
PRAYER
It is, therefore, most humbly respectfully prayed that
this Hon’ble court may kindly be pleased to release the
applicant/accused on bail, in the interest of justice.
IN J.C.
DELHI APPLICANT/ACCUSED
DATED:01.12.2023
THROUGH COUNSEL
