In

The court of District & Session judge,

Gaya

A.B.P.no.-............................/2017

Neeraj Goswami S/o- Rajkumar Goswami, R/o- vill- Bahalpur ,

P.S.- Guraru, Dist.Gaya.................................................... Petitioner

Vs.

State of Bihar...................................................Opposite party

Subject –ABP

INDEX

SI.NO Particulars Page no.

1. Anticipatory Bail Petition 2-5

2. Certified copy of FIR
3. Photo copy of fee receipt
4. Photo copy of receipt of janta
darbar of S.S.P. of gaya
5. Web copy of Anticipatory
of Honarable High court Patna

1|Page
 In,

The court of District & Session judge,

Gaya

A.B.P.no.-............................/2017

(Arising out of Guraru P.S. case no. -78/15 state versus shyam
goswami and others U/S 147, 148, 149, 341, 342, 323, 324, 353,
333, 337,427,307, 188, 504, 109, 115 and 506/34 of IPC & 27
Arms act pending in the court of A.C.J.M. Vth, Gaya.)

Neeraj Goswami S/o- Rajkumar Goswami, R/o- vill- Bahalpur , P.S.-

Guraru, Dist.Gaya........................................................................ Petitioner

Vs.

State of Bihar........................................................................Opposite party

The humble petition

on behalf of the above
named petitioner for
granting Anticipatory
bail under sction 438
of Cr.P.C.

2|Page
Most respectfully showeth -:

1. That the petitioner are innocent and has been falsely implicated in this
case.

2. That the earlier no anticipatory or regular bail petition on behalf of the

petitioners has been filed either before this court or before any higher
court.

3. That the prosecution story in brief is that informant of this case Ranjan
Kumar S.H.O of Guraru P.s. recorded his self statement at 12:10 on
29/09/15 at sugar mill Guraru alleging their in that he received and
information that a dead body of person was lying on Guraru railway
station track.

4. That on this information he along with his police force proceeded towards
place of occurance regarding verification of the information. At last he
reached there and found that deceased was Subham Kumar alies Uttam
S/o- Binod Rajak , R/o vill- Akunpur, P.S.- Guraru. He seized the dead
body at A.N.M.M.C.H. Gaya for post-mortum.

5. That then accused petitioner and other 22 person were blocked the road
and used to slogan against the police. It is further relate that all the
accused person began to shut up the shops of the Guraru market. It is
further that they were in 200 in number and someone of them were
identified by Chokidar . it is further alleged that they were scuffing with
the police person and broken peace and destroyed the publice property.it
is further related that all the turbulent person were petting stones over the
police party.
(certified copy of FIR is annexed
herewith & marked as Annexture 1)

6. That petitioner was student of B.Sc. part (2) and he was not present at
place of occurenc on the alleged time of occurance because he was

3|Page
 present in his Anugrah Narayan Memorial College, Gaya and he has paid
his fee.
(photo copy of fee receipt is annexed
herewith this petition and mark as
annexture 2)

7. That petitioner college is 25 K.m. from the place of occurance, so itis

clear that he was not present on the place of occurance at the date &time
of the alleged date & occurance.

8. That the petitioner had written a letter regarding his innocence to the
S.S.P. Gaya in Janta Darbar but nothing has enquired about occurance by
the police.

(photo copy of receipt of janta darbar of S.S.P. of gaya

is annexed herewith this petition & make as
annexture-3)

9. That the petitioner shall not misuse the privilege of the bail and shall
abide by any terms which your honour would like to lay down.

10.That the learned counsel for the petitioner submits that similarly situated
co-accused Shyam Kumar Goswami in Cr. Misc. No. 11554 of 2016 on
01.04.2016, Jitendra Rajak in Cr. Misc. No.57384 of 2015 on 14.01.2016,
Shatrughan Prasad @ Shatrughna Prasad in Cr. Misc. No. 412 of 2016 on
07.01.2016 have already been granted anticipatory bail by different
Benches of this Court.

(web copy of Anticipatory bail copy of Humble High

court is annexed herewith this petition & make as
annexture-4)

It is therefore prayed
that your honour may

4|Page
 be pleased to enlarge
the petitioner on bail.

And for yhis your petitioner shall ever pray.

Place .............

Date...............

5|Page