MEMORANDUM OF CRIMINAL PETITION

(Under Sec. 438 of Cr.P.C)

IN THE HIGH COURT OF JUDICATURE OF ANDHRA PRADESH AND
TELANGANA
AT
HYDERABAD
Crl.P.No.

of 2016

In
(Crime No.85 of 2015 on the file of P.S. Ongole I Twon, Prakasham District)

Between:
1. Smt. Bellam Margaret Jayamani, W/o Chandra Sekhar Raju
Age about: 50 years, OCC: Home Maker, H.No. 25-037-316,
Kabadipalem, Baker Gardends, Ongole Prakasham District
PETITIONER /ACCUSED No.2
AND
The State of Andhra Pradesh,
Rep.by its Public Prosecutor.
Nandivargam, Prakasham District
RESPONDENT
PETITION FOR ANTICIPATORY BAIL
The address for service of summons for the above named petitioners is as
mentioned in the above cause title and that of his counsel is Sri R.SAMEER
AHMED (15786), Zubair Fazal Advocates, Plot No.6-2-656, Flat No.105, Chintal
Basti, Hyderabad 500004.
1.

The Petitioner respectfully submits that she has been falsely implicated as
accused no.2 in Crime No./FIR No. 85 of 2015 on the file of PS Ongole I
Twon, Prakasham District under Section 387, 389, 34, of IPC Dated 17/April /
2015.

2.

The Petitioner respectfully submits that the petitioner herein got introduced to
the de-facto through the accussed No.1 in the present case. In due course after
gaining my confidence the de-facto complainant has lured me to invest in
granite business and beliving on the words of the de-facto complainant the
petitioner herein has given her precious savings to the de-facto complaiant

under the impression that the de-facto complainant will use the amount for the
initiation of granitite business.
3.

The petitioner respectfully submit that the de-facto complainant has deceived
the petitioner herein never returned the money which he is liable to pay to pay
to the petitioner. When the petitioner herein has warned the de-facto
complainant about taking appropriate legal action against him.

4.

The petitioner respectfully submit that the de-facto complainant filed the
present criminal case against the petitioner herein with an concocted story inorder to escape from the financial liability.

5.

The Petitioner respectfully submits that the de-facto complainant is my partner

in a business and the said de-facto complainant has been pressurizing the
petitioner herein to relinquish her rights failing which the de-facto complainant
has threatened of filing a criminal cases against the petitioner herein.

6.

It is respectfully submitted that a perusal of the complaint does not disclose

any specific material particulars.

Only vague and bald allegations have been

made against the Petitioner herein.

7.

It is respectfully submitted that the petitioner herein is completely innocent

and she has nothing to do with the present crime. The allegations made against
the

petitioner herein are concocted with an intention to humiliate the

petitioner herein with the rig morale of criminal prosecution

8.

That the Petitioners are ready to abide by the conditions that may be imposed
by this Honble Court while granting anticipatory bail. The Petitioners is ready
to cooperate with the prosecution in the process of investigation.

For the reasons stated above it is prayed that this Honble Court may be pleased to
enlarge the Petitioner herein on Bail in the event of her arrest in. Crime No.85 of
2015 Dated 17/4/2015.on the file of PS Ongole I Twon, Prakasham District under
section 387, 389, 34of IPC and pass such other order or orders as may deem fit and
proper in the circumstances of the cases.

COUNSEL FOR THE PETITIONER

Hyderabad
Dt. . .2016

Prakasham District
HIGH COURT :: HYDERABAD

Crl.P. No.

OF 2016

PETITION
FOR ANTICIPATORY BAIL

M/s. R.SAMEER AHMED (15786)

M/s Zubair Fazal
ADVOCATES
COUNSEL FOR THE PETITIONER