.

Z ,
ADDL. SESSIONS JUDGE, PATIALA

Gaurav Kumar aged about 28 years S/o Bhushan Parkash

r/o 1192/1, Manji Sahib Gurudwara Kainth Majri Ambala
City

......Petitioner

Versus

1. State of Punjab

2. I.O/SHO/Arresting Officer of P.S. Tripuri.

Respondents

FIR No.1 dt.01/01/2016

U/S 419/420/465/467/468/471/120-B IPC
Police Station, Tripuri

1st Application for grant of Anticipatory bail U/S 438

Cr.P.C.

Sir,

It is respectfully submitted as under:

1. That the petitioners are resident of above mentioned

address in the State of Punjab and thus being the citizen of
India is seeking the indulgence of this Honble Court by
way of filing the present petition.

2. That the petitioner is not the author of any offence who

have been falsely implicated for extraneous reasons by
Bajaj Finance Ltd. in connivance of the police of police
 station Tripuri register a false case and the petitioner is
innocent person.

3. That the prima-facie no case is made out under Section

419/420/465/467/468/471/120-B IPC against the
petitioner/applicant.

4. That the bare reading of the FIR reveals that the present
case has been registered on the statement of one Sandeep
Sharma auth representative of Bajaj Finance. It is alleged
in the FIR that the petitioner along with other co-accused
after forgery some documents and disbursed a loan and
utilized the money on his own.

5. That it is worthy to mention here that moreover the

present case has been lodged after a long delay and this
long delay utilized by the complainant to involved
innocent person in this false case.

6. That the petitioner will not tamper with the prosecution

evidence. And also undertakes to abide by the directions
imposed by this Honble Court.

7. That the Petitioner has roots in society and has clean

antecedents. There is no danger of the petitioner fleeing
from justice. There is also no danger of the petitioner
tempering with the prosecution evidence.

8. That the petitioner undertakes not to leave the country

without prior permission of this Honble Court.

9. That the petitioner undertakes to appear on each and

every date of hearing and is ready to furnish surety/bail
bonds to the satisfaction of this Honble Court.
10. That all the relevant record is in the custody of police as
such the custodial interrogation of the petitioner is not
required and the petitioner is ready to join in the
investigation in this above noted case as when it is
directed by this Honble Court.

It is therefore prayed that the application may kindly

be accepted and the applicant may kindly ordered to be
released on anticipatory bail till the final decision of the
case.

It is further prayed that arrest of

petitioner/applicant may kindly be stayed till the final
decision of this bail application.

Dated:

Note: Submitted by:

..Petitioner/applicant

Through counsel:

Arun Bansal

Advocate, Patiala
 . Z ,
ADDL. SESSIONS JUDGE, PATIALA

Gaurav Kumar aged about 28 years S/o Bhushan Parkash

r/o 1192/1, Manji Sahib Gurudwara Kainth Majri Ambala
City

......Petitioner

Versus

State of Punjab
Respondents

In the matter of bail application u/s 438 Cr.P.C. (First)

Affidavit

I, Gaurav Kumar aged about 28 years S/o Bhushan

Parkash r/o 1192/1, Manji Sahib Gurudwara Kainth Majri
Ambala City , do hereby solemnly affirm and declare as under:
1. That the deponent has filed the above noted bail application along
with this affidavit, which is 1st bail application u/S 438 Cr.PC. no
other bail application of the petitioner is pending or decide by any
Court of Law.

Deponent

Verification:
Verified that the contents of the affidavit are true and
correct to the best of my knowledge and nothing has been
concealed therein.

Deponent
Verified at Patiala
Dated