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This memorandum is an application for anticipatory bail filed by K. Venkatesan (petitioner/accused no. 4) before the Madurai Bench of the Madras High Court. The petitioner fears arrest and torture by the Thirumayam police (respondent/complainant) in connection with an alleged offense under sections 341, 322, 324, 364 and 507 IPC reported on May 27, 2009. The prosecution claims the petitioner attacked the complainant Elangovan, who is the brother of a man who cheated the petitioner's sister-in-law, causing injuries during a dispute over repayment of a loan. The petitioner claims innocence and requests bail, offering sureties, as it is

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Karthik Kanna
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216 views3 pages

Ab Upcoming

This memorandum is an application for anticipatory bail filed by K. Venkatesan (petitioner/accused no. 4) before the Madurai Bench of the Madras High Court. The petitioner fears arrest and torture by the Thirumayam police (respondent/complainant) in connection with an alleged offense under sections 341, 322, 324, 364 and 507 IPC reported on May 27, 2009. The prosecution claims the petitioner attacked the complainant Elangovan, who is the brother of a man who cheated the petitioner's sister-in-law, causing injuries during a dispute over repayment of a loan. The petitioner claims innocence and requests bail, offering sureties, as it is

Uploaded by

Karthik Kanna
Copyright
© Attribution Non-Commercial (BY-NC)
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOC, PDF, TXT or read online on Scribd
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MEMORANDUM OF CRIMINAL ORIGINAL PETITION


(Under Sec 438 of Cr.P.C)

BEFORE THE MADURAI BENCH OF MADRAS HIGH COURT

Crl.O.P No. /2011

In
Crime No.382/09
(On the file of the Inspector of Police, Thirumayam Police Station,
Sivagangai District)

K. Venkatesan
age 36 years
S/o. Kathirvel
Nadaveeraipudur,
Velayudapattinam post,
Devakottai Taluk,
Sivagangai District. …Petitioner/Accused No.4.

Vs.

State rep.by the Inspector of Police,


Thirumayam Police Station,
Sivagangai District. …Respondent/Complainant.

ANTICIPATORY BAIL APPLICATION

The address for service of all notices and processes on the petitioner is
that of his counsel M/s N.Karthik kanna & K.Ramanathan Advocates at No.38,
Lawyers chamber, Madurai Bench of the Madras High Court Madurai -625 023.

1. The petitioner is apprehending arrest and torture at the hands of the


respondent police for the alleged offences punishable U/s 341, 322, 324, 364
and 507 IPC.

2. The alleged occurrence is said to have taken place on 27.05.09 at


11.00pm at Mahamayeepuram.

3. The prosecution case is that one Elangovan Son of Alagu Servai


lodged a complaint before the respondent police that one Alagu the husband of
the first accused Selvi borrowed money from one Kasi Viswanathan. The
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complainant along with Kasi Viswanathan asked money from the accused, the
accused attacked the complainant and caused injury.

4. The petitioner submits that he is innocent and has not committed any
offence much less than the offence alleged against him.

5. The petitioner submits that he is working in SUN Travels at Karaikudi.


He constructed a new house at his native village, Naduveerapudur and
performed house worming ceremony of 20.05.09. He is nothing to do with the
offence however he is implicated since he happened to be one of the Son in-law
of the first accused Selvi.

6. The petitioner submits that the first accused Selvi is having two sons
and two daughters. Her husband Alagu was working as Assistant Manager in
Central Co-operative Bank and died in the year 2007. The petitioner married the
first daughter of Selvi. The second daughter Ramadevi was in love with one
Karthikeyan Son of Kasi Viswanathan. The said Karthikeyan cheated Ramadevi
by promising to marry her and made her pregnant. On the complaint of
Ramadevi a case was registered as against said Karthikeyan in Crime No.----- /
09 on the file of the Pudukottai police station. The complainant Elango is the
brother of Karthikeyan father Kasi Viswanathan.

7. The petitioner submits that on 27.05.09 the second accused


Kumaresan asked Kasi Viswanathan why they are preventing the marriage, and
more was a scuffle. The complainant and Kasi Viswanathan seems to have
attacked the accused Kumaresan, the Kumaresan pushed the complainant and
the complainant also said to have sustained injuries in the incident.

8. The petitioner submits that the complainant sustained simple injury


and was also discharged from the hospital.

9. The petitioner submits that he is having permanent residence in the


above mentioned address and he is ready to furnish substantial sureties for his
release on bail.
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10. The petitioner submits that this is the first Anticipatory bail
application filed before this Hon’ble Court and no other similar application is
pending before the court of sessions.

Therefore it is prayed that this Hon’ble Court may be pleased to grant


anticipatory bail to the petitioner in the event of his arrest in Crime No.111/09
on the file of the respondent police and thus render Justice.

Dated at Madurai on this the 3rd day of May 2011.

Counsel for the Petitioner.

Note: Bail to the Satisfaction of


Judicial Magistrate, Thirumayam.

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