IN THE COURT OF HON’BLE SESSIONS JUDGE, _____
Application No.________
_____ S/o, D/o, W/o _____ R/o _____
………….Applicant /Petitioner
Versus
_____ S/o, D/o, W/o _____ R/o _____
………….…Respondent/Complainant
Criminal Complaint No. _____
Complaint Under Section ___ of _____
Police Station: _____
First Application Under Section __ For Grant of Anticipatory Bail
RESPECTFULLY SHOWETH:
1- That the respondent/complainant filed a Criminal complaint under Section _____ of the _____against the applicant/petitioner regarding _ bounced cheques amount to _____/- each in the court of _____ Magistrate and due to absence of the applicant/petitioner the Hon’ble Trial court of _____ passed an order on dated _____ and declared the applicant/petitioner proclaimed offender Under section _____ and also passed an order for attachment under Section _____
2- That the applicant/petitioner is an innocent and have not committed any offence as alleged by the complainant. The loan amount as alleged by the complainant was duly refund to the complainant but the complainant/respondent with ulterior motive to grab money misused the blank cheques of the applicant/petitioner which were taken by the complainant as security against the loan amount.
3- That on the wrong complaint filed by the complainant, the learned trial court of _____ declared the applicant/petitioner proclaimed offender and the police wants to arrest the petitioner. The applicant/petitioner is entitled for anticipatory bail on the following grounds:-
a) That the applicant/petitioner never received any legal notice or summons of the learned Trial court neither ever informed about the complaint/case. The above-mentioned complaint was not in the notice or knowledge of the applicant/petitioner.
a. That the applicant/petitioner came to know about the above noted case/complaint through _____ who told the applicant/petitioner that a police official came and told about the case but no notice or warrant was served. The applicant petitioner immediately on _____ engaged counsel and came to know about the above-mentioned complaint and proceedings.
b. That the proceedings for declare the applicant/petitioner proclaimed offender are illegal and defective as no notice was ever served on the applicant/petitioner nor any notice was pasted neither any person contacted the applicant/petitioner regarding the complaint or orders of the learned trial court.
c. That the applicant is _____ and serving at _____
d. That the absence of the applicant/petitioner was not intentional or malafide but due to lack of knowledge of the case/complaint or order
e. That there is no apprehension for absconding or evading of taking trial.
f. That the applicant/petitioner is well reputed and well educated and prestige of the applicant/petitioner will be reduced in the society if ___ is arrested.
g. That the applicant/petitioner undertakes for not to leave India without the prior permission and consent of the Hon’ble court or the trial court.
h. That the applicant/petitioner undertakes to abide by all the terms and conditions as imposed by the Hon’ble court in the event of bail.
i. That the applicant/petitioner undertakes for not to hamper the bail and ready to furnish the bail bonds of sound amount for the satisfaction of the Hon’ble court.
j. That in such type of false cases the bail is rule and refusal of the bail will not serve any purpose.
k. That the applicant/petitioner has apprehension and present to believe that _____ may be arrested and if the applicant/petitioner is arrested then there is likelihood that _____ may be harassed.
l. That the bail is rule and refusal of the bail will not serve any purpose.
PRAYER:
It is, therefore prayed that the applicant/petitioner may kindly be released/granted anticipatory bail and learned court Magistrate may kindly be directed to release the applicant/petitioner on bail in the event of _____ arrest
It is further prayed that interim bail may also kindly be granted to the applicant/petitioner till the final disposal of the application.
Dated:
Applicant/Petitioner
_____ S/o, D/o, W/o _____ R/o _____
Through counsel:
_____ Advocate, _____