IN THE COURT OF SH. CHANDER GUPT, A.S.J.

, KARKARDOOMA
COURT, DELHI
In Re:
State VERSUS Tej Singh @ Teja & others
F.I.R. No. 119/2004
U/S 364/328/392/302/201/120-B/
411/419 IPC
P.S. Shahdara
In Custody since 19th April 2004
N.D.O.H. 27-08-2004

BAIL APPLICATION U/S 437 Cr.P.C. ON BEHALF OF ACCUSED

VIJAY KUMAR, S/O SH. ANOKHEY LAL, R/O A-151/A/2, SOM
BAZAAR, MANSINGH MARKET, 4 ½ PUSHTA, GAMBRI, DELHI

Sir,
MOST RESPECTFULLY SHOWETH:-

1. That the applicant is the accused in the above

noted case pending trial before this Hon'ble
Court and fixed for framing of charge.

2. That the brief allegations as per prosecution

case against the applicant are as follows:-

a) Accused Tej Singh @ Teja was apprehended and he

gave a disclosure statement to the police on 18-
04-2004 that on the day next after the commission
of all offences he along with his co accused
Rajender came at the residence of the applicant
(which is also the residence of accused Rajender)
and Rajender gave Rs. 23,000/- out of the
proceeds of the offence to his brother/applicant
and told him to start his business.

Contd./2
 -: 2 :-

b) The police arrested the applicant and discovered

Rs. 23,000/- from the Chullah kept in Angan of
the house of the applicant. (which is also the
residence of accused Rajender).

3. That the bare perusal of the charge sheet

suggests that the applicant is not involved in
any case and he has been implicated falsely by
the police officials.

4. That the involvement of the applicant for the

alleged conspiracy to kill the deceased or to
abduct him/them or to administer him/them any
stupefying or intoxicating substance or drug or
to gain any property from deceased and to cause
any disappearance of the body of deceased is
neither proposed by the prosecution to be proved
nor any evidence to this effect is adduced here.

5. That the accused Rajender is real brother of the

applicant and has been residing at A-151/A/2, Som
Bazaar, Mansingh Market, 4½ Pushta, Gambri,
Delhi.

6. That it is the admitted case of the prosecution

that the place of alleged recovery i.e. A-
151/A/2, Som Bazaar, Mansingh Market, 4½ Pushta,
Gambri, Delhi, is in common possession, use and
enjoyment of the applicant and accused Rajender.

7. That the applicant was lifted by the police

officials of P.S. Shahdara on 16-04-2004 and
illegally detained him for 3 days just to harass,
torture and falsely implicating him in this case.
Contd./3
 -: 3 :-

8. That applicant has been falsely implicated in the

present case on the basis of disclosure/
confession statement made by the accused Tej
Singh on 18-04-2004.

9. That the applicant is the law abiding citizen and

is the sole earning member for his family which
consists of two minor sons. It is pertinent to
mention here that youngest son of the applicant
Master Suraj is Paralyzed and needs constant,
regular and permanent treatment from Safdarjung
Hospital.

10. That the applicant/accused is nothing to do with

the alleged offence, and is totally innocent.

11. That the applicant has earlier applied for the

grant of bail before the Hon'ble Court of
Additional District & Session judge before the
filing of charge sheet which was dismissed as
withdrawn vide the order passed by the Hon'ble
Court of Sh. R.K. Sharma, P.O.L.C., Karkardooma
courts, Delhi.

12. That the applicant/accused is no more required by

the police for any further investigation.

13. That the applicant/accused would neither temper

with any evidence nor influence any witness, if
released on bail.

14. That the applicant/accused has clean antecedents

and has been neither previously convicted nor any

Contd./4
 -: 4 :-

case is pending against him in any Court of

Criminal Law.

15. That the applicant is a young man who has to

fulfill all responsibility of his family and has
been languish in jail since 19th of April 2004 in
the company of hard criminals.

16. That the applicant/accused is ready to furnish

the reliable surety to the satisfaction of this
Hon’ble Court.

It is, therefore, most respectfully prayed

that the Hon’ble Court may kindly be pleased to
release the applicant/accused on bail, in the
interest of justice.

Delhi/Dated:13/08/04 APPLICANTS/ACCUSEDS

Through:
COUNSEL

AANCHAL
 IN THE COURT OF Ms. REENA SINGH NAG, C.M.M., TIS
HAZARI COURTS, DELHI
State VERSUS Raj Kumar
S/o Sh. Chiranji Lal
R/o Pind Longwal, Tehsil Longwal,
District Sangroor, Punjab.
F.I.R. No. 301/2004
U/S 201/202/203/222/223/224/225/
120-B IPC
P.S. Sabji Mandi
Under Investigation: Special Cell
In Custody since 03-09-2004

BAIL APPLICATION U/S 437 Cr.P.C. ON BEHALF OF ACCUSED

RAJ KUMAR
Sir,
MOST RESPECTFULLY SHOWETH:-

1. That the applicant is booked for the offences

punishable U/S 201/202/203/222/223/224/225/120-B
IPC.

2. That all the offences made out against the accused

Raj Kumar are bailable and he has been implicated
falsely in the above noted case.

3. That the applicant did not offer any resistance or

illegal obstruction to the apprehension of the
accused Guru Sewak Singh @ Babla. The applicant did
not rescue or attempt to rescue the accused Guru
Sewak Singh @ Babla from the custody.

4. That the applicant has been a dutiful and obedient

servant in Punjab Police for last more than 25 years
and he bears a very clean antecedents.
Contd./2
-: 2 :-
5. That the applicant is the law abiding and peace
loving citizen and the applicant/accused has nothing
to do with the alleged offence, and he is totally
innocent.

6. That the applicant/accused is no more required by

the police for any further investigation.

7. That the applicant/accused would neither temper with

any evidence nor influence any witness, if released
on bail.

8. That the applicant/accused has clean antecedents and

has been neither previously convicted nor any case
is pending against him in any Court of Criminal Law.

9. That the applicant/accused is ready to furnish the

reliable surety to the satisfaction of this Hon’ble
Court.

It is, therefore, most respectfully prayed

that the Hon’ble Court may kindly be pleased to
release the applicant/accused on bail, in the
interest of justice.

Delhi:
Dated:09/09/04 APPLICANT
(In J.C.)
Through:
COUNSEL
AANCHAL