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2nd Bail of Monu 302 IPC

1) Monu is applying for bail under section 439 of the CrPC for the second time, having withdrawn his first bail application. 2) He claims the case against him was falsely registered in collusion with the complainant and that the evidence is insufficient to prove his guilt. 3) Due to the ongoing COVID-19 pandemic, the trial is likely to be long delayed and continued detention serves no purpose. He offers to abide any conditions imposed by the court.

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Amandeep Dhillon
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643 views4 pages

2nd Bail of Monu 302 IPC

1) Monu is applying for bail under section 439 of the CrPC for the second time, having withdrawn his first bail application. 2) He claims the case against him was falsely registered in collusion with the complainant and that the evidence is insufficient to prove his guilt. 3) Due to the ongoing COVID-19 pandemic, the trial is likely to be long delayed and continued detention serves no purpose. He offers to abide any conditions imposed by the court.

Uploaded by

Amandeep Dhillon
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
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2nd Bail Application under section 439 of Cr.P.C.

In The Court Of Hon’ble Sessions Judge, Narnaul

Monu S/o Hawa Singh R/o Akoda Police Staion and District
Mahendargarh, Haryana.
…Petitioner

Versus

State of Haryana
…Respondent

FIR No. 161


Dated – 11/12/2019
Under Section- 302/201/34 IPC & Sec. 03 SC ST Act
P.S.- Satnali

2nd Bail Application under section 439 of Cr.P.C.

Hon’ble Sir,

The petitioner submits as under:

1. That a false case has been got registered by the police against the

accused/petitioner in collusion with the complainant after


concocting a story, whereas the petitioner is innocent and is

confined in jail since 26/12/2019 in the present case.

2. That now the case is fixed for 17/10/2020 for recording the

statement of prosecution witness in the Hon’ble court of Sh Ajay

Tewatiya, Hon’ble ASJ, Narnaul.

3. That this is the second bail application u/s 439 Cr.P.C. of the

accused/petitioner, whereas the first application for regular bail u/s

439 Cr.P.C. was dismissed as withdrawn vide order dated .

4. That the FIR was got registered on the basis of the application

given to the police by Krishan Singh, Sarpanch of Villaage Nawa

when he allegedly found the dead body of the deceased in the

forestry of his village. Whereas, there is no eyewitness of the

present case and the facts and evidences collected by the police as

submitted in the final report under section 173 of Cr.P.C. are also,

prima facie, not sufficient to intensely prove the guilt against the

accused/petitioner and whole of the case is based on

circumstantial evidence and the chain as per required by law to be


completed ruling out all the hypothesis of innocence of accused is

not complete and mere attribution of recovery to the petitioner

and it cannot be in any way sufficient to connect the

accused/petitioner in the present occurrence.

5. That looking into the circumstance due to COIVD-19 pandemic it is

quite possible that the recording of evidence and final decision of

the case may take sufficient long time and no useful purpose will be

served by keeping the petitioner behind the bars till the final

decision of the case

6. That the petitioner has deep roots in the society and as such, there

is no apprehension of absconding of the petitioner.

7. That petitioner is ready to give sound surety as per the orders of

the Hon’ble court.

8. That the petitioner is a law abiding person and therefore, there is

no apprehension of tempering with the prosecution witnesses or

its incriminating articles by the petitioner.


9. That the petitioner shall appear before the Hon’ble Court as and

when desired by the court.

10. That the petitioner shall abide by all the terms and conditions to

be imposed by the hon’ble court in the event of release of

petitioner on bail.

Therefore, it is submitted that the present application for

bail may kindly be allowed and petitioner may please be released

on bail and in the alternative it is further submitted that looking

into the present scenario arising due to the COVID-19 pandemic

any other appropriate relief which the Hon’ble court deems

appropriate may kindly be granted.

Date:

Submitted by:

Monu S/o Hawa Singh

R/o Akoda

Police Staion and District Mahendargarh,

Haryana.

Through counsel.

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