BAIL APPLICATION MEMORANDUM OF CRIMINAL PETITION UNDER SECTION 437 Cr PC

In the High Court of Punjab and Haryana, Chandigarh In the Court of Session, Patiala Cr P No. Between Mr, Rajinder Singh s/o Mr. Gurmeet Singh aged 67 years r/o 23 Model Town Patiala AND The State of Punjab Rep by its P.P. High Court of Punjab and Haryana Respondent/Complainant Petitioner/Accused of 2011

The address for service to the petitioner is that of his counsel M/s. D. N. Goyal & Associates, Advocates, Patiala The above named petitioner begs to present this memorandum of criminal petition to this Honble Court against the orders passed in Cr. M. P. in Crime Number of. Police Station,.. passed by the Sessions judge,. for the following among other grounds. GROUNDS 1) The petitioner is falsely implicated in Crime No.. for charges that are leveled under section of the .. Act. 2) The petitioner is innocent. He has nothing to do with the alleged offence. 3) Mention the facts on which he was convicted by the trial court 4) Facts 5) It is submitted that the petitioner was remanded to the judicial custody on .

6) It is submitted that prosecution has completed the entire investigation and filed a charge sheet on. 7) It is submitted that the petitioner/accused is sixty seven years old man. 8) It is submitted that the petitioner is ready and willing to furnish sureties to the satisfaction of this Honble Court. 9) The petitioner is a law abiding citizen, and he has a permanent residence. 10) The petitioner is ready and willing to abide by any such condition that may be imposed by this Honble Court. 11) Under the above circumstances the petitioner herein most humbly prays that this Honble Court may be pleased to enlarge the petitioner on bail in Crime No in. P.S. and pass such other order or orders as this Honble Court may deem fit in the circumstances of the case. Place: Date: Verification Mr, Baljinder Singh s/o Mr. Sajjan Singh aged 55 years r/o Village Sidhuwal, distt Patiala do hereby authorized by the accused to appoint M/s. D. N. Goyal & Associates, Advocates to act on his behalf and that no other person has been authorized to appoint any advocate. Signature of the person interested. Signature of the Advocate. Counsel for the petitioner