Legal Desire Online Workshop on Legal Drafting

BAIL APPLICATION UNDER SEC. 436 OF CRPC

MEMO OF THE APPEARANCE

IN THE COURT OF JUDICIAL MAGISTRATE, ERODE

Cr. M. P. No 4343/ 2014

Crime No 1234/ 2014
(on the file of the FIR No, police station at Erode)

Prem kumar, aged 28,

son of Periya samy residing in housing unit of teachers colony,
Sampath Nagar, Erode.

Petitioner/Accused

Versus
Respondent State through Erode Police Station, P. S. Park,
Erode.

Respondent/Complainant

MEMO OF APPEARANCE
I have been duly instructed from the Petitioner/Accused to proceed with the case

Advocate for the Petitioner/ Accused

Copyright Legal Desire 2014

www.legaldesire.com

Legal Desire Online Workshop on Legal Drafting

BAIL APPLICATION

IN THE COURT OF SESSIONS JUDGE, ERODE

Cr. M. P. No 4343/ 2014
Crime No 1234/ 2014
(on the file of the FIR No, police station at Erode)
Prem kumar, aged 28, son of Periya samy residing in housing unit of teachers
colony, Sampath Nagar, Erode.
Petitioner/Accused
Versus
Respondent State through Erode Police Station, P. S. Park, Erode.
Respondent/Complainant
BAIL APPLICATION/PETITION FILED UNDER SECTION 439 OF CRPC

1. It is humbly submitted that the present application under Section 439 of Crpc
is being filed by the Petitioner/Accused for seeking grant of bail in the FIR
1234/ 2014 in connection with the offence under Section 506 Part II registered
at Police Station, Erode. The present petition is being moved as the
Petitioner/Accused has been arrested on 01/07/2014 in connection with the
said FIR. The Petitioner/Accused is now in judicial/police custody.
2. The Petitioner/ Accused is the only breadwinner of the family. He/She has a
wife and younger child and elders in his family and they are entirely
dependent on the Petitioner/Accused.

3. The Petitioner/Accused is an innocent person and has not committed any

offences as alleged by the Complainant/Respondent no useful purpose would
be served by keeping him under custody and this is a fit case for grant of bail.
4. The Petitioner/Accused, if a law abiding citizens and so he/she will not
abscond.
5. The Petitioner/Accused is prepared to furnish substantial sureties for his/her
due appearance.
Copyright Legal Desire 2014

www.legaldesire.com

Legal Desire Online Workshop on Legal Drafting

6. That the Petitioner has not filed any other similar petition before this or any
other Honorable Court for grant of bail in case of the present FIR. (Or give
details and results of earlier applications if it has already been filed and
dismissed means mention the details of application and the reason that the
judge has not properly applied his mind while dismissing his/ her bail
application).
7. Therefore, it is humbly prayed that this Honorable Court may be pleased to
analyze the Petitioner/Accused to release on bail and thus render justice.

Advocate for the Petitioner/ Accused

Copyright Legal Desire 2014

www.legaldesire.com

Legal Desire Online Workshop on Legal Drafting

BAIL APPLICATION UNDER SEC. 437 OF CRPC
MEMO OF THE APPEARANCE

IN THE COURT OF JUDICIAL MAGISTRATE, ERODE

Cr. M. P. No 4343/ 2014

Crime No 1234/ 2014
(on the file of the FIR No, police station at Erode)

Prem kumar, aged 28,

son of Periya samy residing in housing unit of teachers colony,
Sampath Nagar, Erode.

Petitioner/Accused

Versus
Respondent State through Erode Police Station,
P. S. Park, Erode.

Respondent/Complainant

MEMO OF APPEARANCE

I have been duly instructed from the Petitioner/Accused to proceed with the case

Advocate for the Petitioner/ Accused

Copyright Legal Desire 2014

www.legaldesire.com

Legal Desire Online Workshop on Legal Drafting

BAIL APPLICATION

IN THE COURT OF JUDICIAL MAGISTRATE, ERODE

Cr. M. P. No 4343/ 2014

Crime No 1234/ 2014
(on the file of the FIR No, police station at Erode)

Prem kumar, aged 28,

son of Periya samy residing in housing unit of teachers colony,
Sampath Nagar, Erode.

Petitioner/Accused

Versus
Respondent State through Erode Police Station, P. S. Park,
Erode.

Respondent/Complainant

BAIL APPLICATION/PETITION FILED UNDER SECTION 437 OF CRPC

1. It is humbly submitted that the respondent police has registered a case

against the Petitioner/Accused for an alleged offence under Section 506 Part II
IPC and remanded by the Court on 01/07/2014.
2. The Petitioner/ Accused is the only breadwinner of the family. He/She has a
wife and younger child and elders in his/her family and they are entirely
dependent on the Petitioner/Accused.
3. The Petitioner/Accused is an innocent person and has not committed any
offences as alleged by the Respondent/Complainant.

Copyright Legal Desire 2014

www.legaldesire.com

Legal Desire Online Workshop on Legal Drafting

4. The Petitioner/Accused is a law abiding citizens and so he/she will not
abscond.
5. The Petitioner/Accused is prepared to furnish substantial sureties for his/her
due appearance.
6. Therefore, it is humbly prayed that this Honorable Court may be pleased to
analyze the Petitioner/Accused to release on bail and thus render justice.
Advocate for the Petitioner/ Accused

Copyright Legal Desire 2014

www.legaldesire.com

Legal Desire Online Workshop on Legal Drafting

BAIL APPLICATION UNDER SEC. 438 OF CRPC
AFFIDAVIT

IN THE COURT OF SESSIONS JUDGE, ERODE

Cr. M. P. No 4343/ 2014

Crime No 1234/ 2014
(on the file of the FIR No, police station at Erode)
Prem kumar, aged 28,
son of Periya samy residing in housing unit of teachers colony,
Sampath Nagar, Erode.

. Petitioner/Accused

Versus
Respondent State through Erode Police Station, P. S. Park,
Erode.

Respondent/Complainant

AFFIDAVIT IN SUPPORT OF THE APPLICATION/PETITION FILED UNDER

SECTION 438 OF CRPC

I, Prem Kumar, aged 28, son of Periyasamy, residing in housing unit of teachers
coloney, Sampath Nagar, Erode, do hereby solemnly affirms and sincerely states as
follows:1. That the accompanying application under section 438 CrPC has been drafted at
my instance and under my instructions.

2. That the case FIR No. 1222/2014 dated 20/07/2014 under section 506 part 11 IPC
has been registered by the police against me.
Copyright Legal Desire 2014

www.legaldesire.com

Legal Desire Online Workshop on Legal Drafting

3. The case is neither true nor correct to the best of my knowledge.

4. I am an innocent person and I have not committed any offence alleged.

4. I am a law abiding citizen and so I will not abscond.

Accused/ Petitioner
Verification
Verified that the contents of my above affidavit are true to best of my knowledge and
belief and nothing concealed therein.

Place - Erode.
Date - 20/07/2014

Copyright Legal Desire 2014

Signature of the Advocate

(other than counsel for advocate)

www.legaldesire.com

Legal Desire Online Workshop on Legal Drafting

BAIL APPLICATION

IN THE COURT OF SESSION JUDGE, ERODE

Cr. M. P. No 4343/ 2014

Crime No 1234/ 2014
(on the file of the FIR No, police station at Erode)

Prem kumar, aged 28,

son of Periya samy residing in housing unit of teachers colony,
Sampath Nagar, Erode.

Petitioner/Accused

Versus
Respondent State through Erode Police Station, P. S. Park,
Erode.

Respondent/Complainant

BAIL APPLICATION/PETITION FILED UNDER SECTION 438 OF CRPC

1. For the reasons stated in the accompanying affidavit, it is humbly submitted

that the Respondent Police has registered a case against the
petitioner/accused for an alleged offence under Section 506 Part II IPC.
2. The Petitioner/Accused is an innocent person and has not committed any
offences as alleged.
3. The Petitioner/Accused is a law abiding citizen and hence he/she will not
abscond.
4. The Petitioner/Accused is prepared to furnish substantial sureties for his/her
due appearance.
Copyright Legal Desire 2014

www.legaldesire.com

Legal Desire Online Workshop on Legal Drafting

5. Therefore, it is humbly prayed that this Honorable Court may be pleased to
analyze the Petitioner/Accused to release on bail and thus render justice.

Advocate for the Petitioner/ Accused

Copyright Legal Desire 2014

www.legaldesire.com

Legal Desire Online Workshop on Legal Drafting

BAIL APPLICATION UNDER SEC. 439 OF CRPC
MEMO OF APPEARANCE

IN THE COURT OF SESSIONS JUDGE, ERODE

Cr. M. P. No 4343/ 2014
Crime No 1234/ 2014
(on the file of the FIR No, police station at Erode)
Prem kumar, aged 28,
son of Periya samy residing in housing unit of teachers colony,
Sampath Nagar, Erode.

Petitioner/Accused

Versus
Respondent State through Erode Police Station, P. S. Park,
Erode.

Respondent/Complainant
MEMO OF APPEARANCE

I have been duly instructed from the Petitioner/Accused to proceed with the case

Advocate for the Petitioner/ Accused

Copyright Legal Desire 2014

www.legaldesire.com

Legal Desire Online Workshop on Legal Drafting

BAIL APPLICATION

IN THE COURT OF SESSIONS JUDGE, ERODE

Cr. M. P. No 4343/ 2014
Crime No 1234/ 2014
(on the file of the FIR No, police station at Erode)
Prem kumar, aged 28,
son of Periya samy residing in housing unit of teachers colony,
Sampath Nagar, Erode.

Petitioner/Accused

Versus
Respondent State through Erode Police Station, P. S. Park,
Erode.

Respondent/Complainant

BAIL APPLICATION/PETITION FILED UNDER SECTION 439 OF CRPC

1. It is humbly submitted that the present application under Section 439 of Crpc
is being filed by the Petitioner/Accused for seeking grant of bail in the FIR
1234/ 2014 in connection with the offence under Section 506 Part II registered
at Police Station, Erode. The present petition is being moved as the
Petitioner/Accused has been arrested on 01/07/2014 in connection with the
said FIR. The Petitioner/Accused is now in judicial/police custody.
2. The Petitioner/ Accused is the only breadwinner of the family. He/She has a
wife and younger child and elders in his family and they are entirely
dependent on the Petitioner/Accused.

Copyright Legal Desire 2014

www.legaldesire.com

Legal Desire Online Workshop on Legal Drafting

3. The Petitioner/Accused is an innocent person and has not committed any
offences as alleged by the Complainant/Respondent no useful purpose would
be served by keeping him under custody and this is a fit case for grant of bail.
4. The Petitioner/Accused, if a law abiding citizens and so he/she will not
abscond.
5. The Petitioner/Accused is prepared to furnish substantial sureties for his/her
due appearance.
6. That the Petitioner has not filed any other similar petition before this or any
other Honorable Court for grant of bail in case of the present FIR. (Or give
details and results of earlier applications if it has already been filed and
dismissed means mention the details of application and the reason that the
judge has not properly applied his mind while dismissing his/ her bail
application).
7. Therefore, it is humbly prayed that this Honorable Court may be pleased to
analyze the Petitioner/Accused to release on bail and thus render justice.

Advocate for the Petitioner/ Accused

Copyright Legal Desire 2014

www.legaldesire.com