Wednesday, 17 June 2015

PETITION FOR POST ARREST BAIL 489-F PPC (dishonoured cheque)



IN THE COURT OF AREA  MAGISTRATE,
POLICE STATION _______________, (NAME OF CITY).













(Name Of The Petitioner, Parentage, Caste And Address)

Petitioner

V E R S U S


The State                                                                                                                      Respondent

PETITION FOR POST ARREST BAIL


IN CASE F.I.R NO.________ DATED 00.00.0000

OFFENCE UNDER SECTION-489/F PPC,
POLICE STATION ___________, (NAME OF CITY).

Respectfully Sheweth:
1.            That the above case has been registered by the Local Police, Police Station                      ____________ (city) on the statement of the complainant  (name). 

2.            That the petitioner has been behind the bar since his arrest in the Local Police Station.

3.        That the aforesaid FIR has been registered by the Police inclusion with the complainant. The FIR is based on mala-fide and false. A copy of the FIR is annexed herewith as annexure “A”.

4.       That the complainant has registered the above mentioned case against the present petitioner after 11-months of alleged occurrence and also failed to explain the any plausible reason for this inordinate delay.

5.      That the present petitioner has paid off all outstanding amount against the consideration of Cheque No. 1001640050-B to the complainant of the FIR.

6.         That the petitioner has not involved in the above said offence the complainant with malafide intention collusively with the local police has nominated the petitioner in the aforesaid FIR.

7.      That the petitioner is belonging to the noble and respectable family and has not involved in the aforesaid offence in any manner, the local police has illegally against the facts involved the petitioner in the above said case, as the petitioner is innocent.   

8.            That the petitioner is law abiding and innocent citizen and has wrongly, falsely been implicated in the above false case only to damage and malign his goodwill and repute due to business rivalry.

9.            That no criminal case has ever been registered against the petitioner and he has never been convicted by any court of law. There is no likelihood to tamper with the prosecution evidence,  in case of granting the concession of bail.

10.        That if the post arrest bail is not granted to the petitioner, then obviously the petitioner would suffer immense and irreparable  loss and would be humiliated at the hands of the complainant as well as police.   

11.        That the petitioner undertakes  that he would appear in the court if so directed by this Learned Court.

12.        That the petitioner is ready and willing to submit surety bond to the entire satisfaction of this Learned Court for his appearance and compliance of the orders of this Learned Court.   

It is, therefore, most respectfully prayed that by accepting this petition, the petitioner may very kindly be admitted to post arrest bail  till the final decision of the case for the sake of justice.   


Petitioner






Through counsel




Dated: 00.00.0000

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