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Shankar Ambaji Katekar,

Age 60 years Occ. agriculturists
And residing At Bhagarpada
Tal. Panvel, Dist. Raigad. ……….. Applicant


The State of Maharashtra ……….. Opponent.

Applicant for grant of Anticipatory Bail, in

connection with Panvel Town Police station CR
No. 357/08 for the office under sections 143, 146,
147, 148, 149, 307 of I.P. Code, and Under sec.
37(1), 135 of Bom. Police Act.


Complaint is lodged by one Tulshiram Gajanan Gade, resident of Bhangarpada, Post.

Kundevahal, Tal. Panvel, Dist. Raigad, alleging therein that Police have filed case of finding of
illcit liquor with one Kisan alias Krishna Shankar Katekar and others including the applicant
and it is alleged that the applicant ant other accused feel that the Police have raided them at the
instance of the complainant and as such it is alleged that the accused Kisan Shankar Katekar
etc. and applicant by forming unlawful assembly allegedly assaulted him with fist and kicks
and it is alleged that accused Kisan Shankar Katekar allegedly made fire shot in the air and
then by pointing towards complainant.
On the basis of said complaint offence at CR No. No. 357/2008 was registered at Panvel
Town Police station under sections 143, 146, 147, 148, 149, 307 of I.P. Code, and Under sec.
37(1), 135 of Bom. Police Act.
In fact the complainant and other witnesses assaulted the applicant and others for which
complaint is filed and applicant herein had sustained bullet injuries and admitted in the
Hospital. But since the name of the applicant is falsely implicated into the alleged offence, the
applicant approach this Honourable Court for grant of Anticipatory bail, on the following
amongst other grounds
1) : That the applicant is innocent and has not committed any offence.
1) There is absolutely no iota of evidence of alleged offence against the applicant.
2) That the applicant is falsely implicated into the alleged offence.
3) That no any incriminating article is to be recovered at the instance of applicant.
4) That investigation of the alleged offence is practically complete.

5) That the applicant is permanently residing at the address given herein abo
6) That the applicant and others herein initially had filed complaint against the
complainant and others which is registered as NC complaint.
7) That the applicant is old aged about 60 years and having good status in the
locality and having roots in the society.
8) That applicant is ready and willing to furnish reasonable surety and ready to
abide by terms and conditions.
9) That no any other anticipatory bail application was filed in this Honourable
Court or in Honourable High Court.
10) That charge-sheet is not yet filed.
For these and other grounds, it is prayed that in the event of his arrest the applicant may
kindly be released on bail.


Dated : / /2008 Advocate for Applicants/accused.