PRE ARREST BAIL PETITION

IN THE COURT OF SESSIONS JUDGE, (CITY)

(PETITONER WITH COMPLETE ADDRESS)

……………….Petitioner

Vs

1. The State
2. (COMPLAINANT AND FULL ADDRESS)

                                                                                        ……………Respondents 
                                             Case FIR No.00/0000 dated 00.00.000

Offence U/Ss 496-A, 380 PPC,

P.S.  ________________

PETITION U/S 498 Cr.P.C. FOR GRANT OF PRE-ARREST BAIL

Respectfully Sheweth:-

1.                 That the above said FIR has been lodged upon the complainant of respondent No.2/complainant against the petitioner while narrating the story mentioned in FIR. Copy of the FIR is attached herewith as Annex-A.

2.                 That the petitioner apprehends his arrest in the titled case; which has been maliciously got registered; just to humiliate, harass and blackmail the petitioner.

3.                 That the petitioner seeks his pre-arrest bail on the following amongst other

GROUNDS

1.                             That the involvement of the petitioner by the complainant in this case is false otherwise the petitioner has no concern whatsoever with the commission of offence.

2.                             That the petitioner is neither previously convicted nor desperate dangerous.

3.                             That the petitioner is ready to join the investigation and prove his innocent.

4.                             That there is nothing on record to incriminate the petitioner in the commission of offence.

5.                             That the story narrated in the FIR is highly doubtful and improbable.

6.                             That the petitioner is quite innocent and he has committed no offence but he has been falsely implicated in this case with malafide intention just to blackmail and harass the petitioner.

7.                             That the petitioner is a law abiding citizen and if he is arrested there is apprehension that the petitioner shall be humiliated.

8.                             That the case against the petitioner is one of further inquiry.

9.                             That the implication of the petitioner is based on grudge and malice.

10.                        That there is no apprehension of petitioner’s abscondance or tempering with the prosecution evidence; if he is allowed pre-arrest bail.

11.                        That the petitioner is ready to furnish bail bonds to the entire satisfaction of this Honourable Court.

12.                        That further available ground shall be expounded at the time of arguments.

Prayer:

It is, therefore, most respectfully and humbly prayed that while accepting this petition; the petitioner may kindly be granted pre-arrest bail till the final decision of the titled case.

In the meantime; ad-interim pre-arrest bail be also granted to the petitioner.

Petitioner

Through

                                                                        (Name)

Advocate High Court,

CERTIFICATE:-

              Certified that as per instruction provided by my client; this is the first bail petition on the subject before this Honourable Court.

Advocate

IN THE COURT OF SESSIONS JUDGE, (CITY)

(PETITONER WITH COMPLETE ADDRESS)

……………….Petitioner

Vs

3. The State
4. (COMPLAINANT AND FULL ADDRESS)

……………Respondents

Case FIR No.00/0000 dated 00.00.000

Offence U/Ss 496-A, 380 PPC,

P.S.  ________________

PETITION U/S 498 Cr.P.C. FOR GRANT OF PRE-ARREST BAIL

Affidavit of PETITONER WITH COMPLETE ADDRESS

I, the above deponent do hereby solemnly affirm and declare as under:-

That the contents of accompanying bail petition are true and correct to the best of my knowledge and nothing has been concealed therein.

Deponent

 VERIFICATION:-

              Verified on oath on this 00^th day of May, 0000 that the contents of above said affidavit are true and correct to the best of my knowledge and belief.

Deponent