IN THE COURT OF HON’BLE SH.

AMIT
GAUTAM(ACJM)GURUGRAM

STATE V/s AKHTAR ALI

FIR 0162/2024
No/Year

U/S 380,457 IPC

P.S. Sushant Lok, GGM

PESHI 19-12-2024
1st Application for Bail U/S 483 BNSS

INDEX

Sr.No Particulars Page

1 APPLICATION FOR BAIL U/S-483 BNSS 2-4
2 AFFIDAVIT 5
3 AADHAR CARD 6
4 VAKALATNAMA 7

Dated:-04th September 2024 Applicant / Accused

Nagma Khatun
Kerki Daula
Gurugram Haryana-122001

Through Counsel: Usha Khera,GGM

Enrol No:- P/3942/17

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 IN THE COURT OF HON’BLE SH. AMIT GAUTAM(ACJM)GURUGRAM

Pramod Singh S/O-Mr.Madho Singh R/O- Vill-Unch,P.S.Nadbai Post

Office-Unch Distt-Bharatpur Rajasthan India.
…..Applicant/Accused

State

…….Respondent
FIR NO:- 0162

U/S:- 380,457 IPC

P.S:-Sushant Lok
Peshi:-20.12.2024

1St APPLICATION FOR BAIL U/S 483 BNSS

Respected Sir/Madam,

The Applicant/Accused most humbly prays for being released on bail on the
following grounds: -

1. That the above-noted case is pending before this Hon’ble Court and
will have been fixed for 20.12.2024.
2. That the present application under section 483 of the Code of
BHARTIYA NAGRIK SURAKSHA ADHINIYAM is being filed by
the Applicants for seeking a grant of bail in FIR No.0162, U/S-
380,457 IPC registered at Police Station:-Sushant Lock, Gurugram.
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 The present petition is being moved as the Applicant has been arrested
on 16.11.2021 from ..............M.P. as mentioned in FIR and the
Applicant is now in Police Custody in Bhondsi, Gurugram Haryana.

Main Grounds for Bail application

i. That the applicant detained from........ while he is studying with

his cousin brother at apartment because of he is applying 12 th
standard form from Bharatpur Rajasthan privately and his house
is not familiar for study that’s why he went to Mausi home
(Indore) for studying and want to get good marks.
ii. That the applicant is returned boy is his family and all family
members depend on his earning and he is working in gas agency
and supplier of domestic gas to his customers.
iii. That the applicant is not involve in this type of activities and
police officer tried to search any chat such as dealing client (sex
chat) through whatsapp application in his cell phone.
iv. That the applicant visited to Indore first time only 4 days. How
can involve in this type of activities.
v. That the applicant is belong to decent family and never such
type of doing activities.
vi. That the applicant’s books and study materials at cousin
apartment but police officers did not hold this type of evidence.
vii. That the petitioner’s mother while listening this news she was
admitted in hospital because of she socked and scared so much in
this phenomena.
viii. That is the main thing it’s a total conspiracy against that applicant.
This is not crime to sitting with accused who was doing this type of

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 activities when he did not know about this sex racket operating by
their cousin brother or another accused.
ix. That the petitioners are belonging to reputed and well culture
family in that village and their career are spoiling now.
x. That the applicant of mother is old age and ailing for some years
and her health is deteriorating day by day after happened this
incident.
xi. That the Applicants should be getting a chance for bail therefore,
they can defend these allegation and can be proof their innocent.
xii. That the Applicants are innocent and is being falsely implicated in
the above said case as he has nothing to do with the matter.
xiii. That the Applicants are a law abiding citizen of India. The
applicants are gainfully carrying on day to day worker and family
members depend upon him.
xiv. That the Applicant is a responsible person and is living at the
above mentioned address.
xv. That the Applicants is innocent and no useful purpose would be
served by keeping him under custody and this is a fit case for grant
of bail.
xvi. That the Applicants undertakes to abide by the conditions that this
Hon’ble Court may impose at the time of granting bail to the
Applicant and further undertakes to attend the trial on every date of
hearing.
xvii. That the Applicants are not filed any other similar petition before
this or any other Hon’ble Court for grant of bail in case of the
present FIR.

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 xviii. That the applicants have never been involved in any type of
criminal activities and belong to a very reputed family and has
been falsely implicated by the prosecution in the present case.
xix. That the applicant/accused is ready to produce sound surety to the
entire satisfaction of this Hon’ble Court.
xx. That applicant/ accused shall not hum per or temper with evidence
of prosecution in any manner in this case of admitted to bail.
xxi. That the applicant has deep roots in the society and he will not flee
away from court of law, in case of he admitted to bail and trail of
the case will take sufficient long time.

PRAYER:

In view of the above stated facts and circumstances it is most

respectfully prayed that this Hon’ble Court may be pleased to

A. Grant bail to the Application connection with FIR No. 162, registered
under section -380,457 IPC Police Station- Sushant Lock, Gurugram
Haryana.

B. Pass any other such order as this Hon’ble Court may deem fit and proper in
the interest of justice.

Date:-4th September,2024 Applicant/Accused

Place:-Gurugram Nagma Khatun

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Through Counsel:-Usha (Advocate), Gurugram Haryana
Enrol.No.P/3942/17, Mob.No…………………………………

IN THE COURT OF HON’BLE JUVENILE COURT,INDORE MP

PRAMOD SINGH V/s STATE

FIR NO:- 162/2024

U/S:-380,457 IPC
P.S:-Sushant Lock
Peshi:-20.12.2024

1st APPLICATION FOR BAIL U/S 483 BNSS

AFFIDAVIT
I,Nagma Khaton (Father of the Petitioners), aged....
years old, S/O..... Singh, Permanent Address: -Vill-Unch P.S.-
Sushant Lock, Gurugram Haryana India, do hereby solemnly
affirm and declare as under:-

1. That the deponent has filed the 2nd Bail application U/s-
483 BNSS and no other bail application in this regard is
decided or pending in any Court of law.
2. That the contents of the bail application have been
drafted on the facts and circumstances finished by the
deponent which are true and correct. The same may kindly
be read as part and parcel of this affidavit.

….DEPONENT

VERIFICATION: -Verified at Gurugram on this 4th September,2024

that the contents of May above said affidavit are true and

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correct to the best of my knowledge and belief and nothing has
been concealed therein.

……DEPONENT