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AD-INTERIM BAIL APPLICATION
IN THE COURT OF HON’BLE SESSION COURT,
AT BHOOM
Criminal Bail Appl. No. ….…….. / 2024
Bhoom Police Station C. R. No. 0049/2024
Mr. Nana Ishwar Kamble
Age. 27 Years, Occ- Farmer,
R/ at :- Bhavanwadi, Post. Jamb,
Tq. Bhoom, Dist. Dharashiv …. Applicant /Accused
Versus,
THE STATE OF MAHARASHTRA
Through AGP Bhoom, Dist. Osmanabad …. Respondent /Complainant
AD-INTERIM BAIL APPLICATION IN CRIME
REGISTERED AT BHOOM POLICE STATION i.e. C. R.
No. 0049/2024, UNDER SECTION 306, 34 OF INDIAN
PENAL CODE.
Delay in FIR Near About 4 Hours
Date of Offence Dated 21/02/2024
Date of Registration of FIR Dated 21/02/2024
Spot of offence House of Informant, Bavi,
Tq. Bhoom, Dist. Dharashiv
Name of Informant Mr. Avinash Bapu Kamble, R/at :-
Bavi, Tq. Bhoom, Dist. Dharashiv
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MOST RESPECTFULLY SHEWETH
MAY IT PLEASE AT YOUR HONOR
That the present applicants/accused submitting this Ad- Interim
Bail application, and applicant having apprehension of arrest in
concern of C.R. No. 0049/2024 of Bhoom Police Station. This bail
application filed by applicants/accused amongst other grounds thereto
is as under :-
GROUNDS
A) 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.
B) That, the police has falsely implicated the applicant in the
present case, the applicant is a respectable citizen of the society and is
not involved any criminal case.
C) That the complaint filed and FIR lodged by Complainant is
false, baseless, and after thought and does not constitute any criminal
offence at all.
D) That the applicant is not required in any kind of investigation or
any kind of custodial interrogation is not warranted.
E) That the applicant/accused has been falsely implicated in this
crime and has nothing to do with the alleged offence. The
applicant/accused is totally innocent.
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F) That the prosecution had miserably failed to find the reliable
motive for the commission of the said offence by the applicant except
the aforesaid false and baseless story.
G) That the alleged incident stated by complainant itself false and
fabricated and does not constitute any abetment as per the provisions of
law for abetment to commit suicide. And the complainant has lodged
this complaint with Bhoom Police Station only with ill intention and
due to Political rivalry with sway of counter persons.
H) The applicant/accused are innocent and he had not committed
any crime as alleged by the police machinery. That accused is falsely
involved in connection with the alleged crime.
I) That the applicant/accused had neither abet nor threatened
informant’s father, and informant or his deceased father had not lodged
any post dated complaint against the applicant/accused stating
abetment for alleged offence. And entire FIR and statement of
informant is based on single alleged incident, and said alleged incident
prima facie might not be fall within the four corners for abetment to
commit suicide, which might be constitute abetment for alleged
offence. Therefore, the alleged incident might not be constitute
abetment as alleged by police machinery.
J) That, the informant in her entire statement neither stated any
word, sentence, or commission of any act by applicant/accused which
caused abetment to commit suicide as alleged by police machinery.
Therefore, FIR and statement of informant is false, concocted, and
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fabricated. And prima facie does not constitute any abetment to
commit suicide by her deceased father. The FIR has been lodged by the
informant only with sway of Political persons who are having political
rivalry with accused persons.
As per the alleged statement of informant regarding the
borrowed loan prior to alleged incident is itself doubtful and vague as
the informant neither mentioned specific details of harassment by the
applicant/accused.
K) That the applicant is permanent resident and there is no chance
of his absconding from the course of justice.
L) That, the applicant undertakes to present himself before the
police/court as and when directed.
M) The Applicant had not any connection with this
crime/allegations, and he is not aware of the said crime.
N) That the applicant undertakes that he 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.
O) That the applicant further undertakes not to tamper with the
evidence or the witnesses in any manner.
P) That the applicant has not committed any offences much less on
offence punishable with death or life imprisonment.
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Q) The practical investigation of this crime is completed and there
is no further interrogation required.
R) There is no criminal antecedent against the Applicant and there
is no identification parade required to be taken.
S) That the Applicant if released on the bail will not tamper with
prosecution evidence in any manner or cause any hindrance in Police
investigation.
T) That the Applicant is ready and willing to accept and abide with
all the terms and conditions as may be imposed by the Honourable
court or the police in connection with the case.
U) That the Applicant will not misuse the process of law and the
applicant shall not leave India without the previous permission of the
court.
V) There is no other bail application pending before any other court
in respect of above said matter/subject.
W) That, neither any recovery is to be effected from the applicant,
nor applicant in a position to tamper with the prosecution evidence.
The applicant will associate with the investigation whenever required
to do so.
UNDER THE ABOVE STATED CIRCUMSTANCES, IT IS
THEREFORE PRAYED THAT :-
a) That the Application may kindly be allowed.
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b) That till the decision of main anticipatory bail application Ad-
interim bail may be granted on such terms and conditions as this
Honourable Court deems fit.
c) That any other just and equitable orders may kindly be passed in
the interest of justice & be obliged.
AND FOR THIS ACT OF KINDNESS AND EQUITY THE
APPLICANT/ACCUSED SHALL EVER PRAY AS ON DUTY
BOUND.
Place :- Bhoom Advocate For Applicant/Accused
Date :- 07/03/2024 Adv. A. N. Chavan, Bhoom
