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In The High Court Of Delhi At New Delhi

Bail Application No. 1129 of 2017

In The Matter Of:-


Jaswant Singh …….Petitioner
VERSUS

The State …… Respondent

[In the Case arising out of the FIR No: 0040 of 2015 (Dated: 14/01/2015),
PS: Kalyanpuri, U/S: 186/308/332/353/34 OF IPC, District-East Delhi, currently
pending in the Court of Shri N K Laka, CMM, Karkardooma Court, New Delhi]

INDEX

Srl. Particulars Page


No. No.

1 Court Fees (Total)

2 Notice of Motion

3 Urgent Application

4 Certificate to the effect that the


documents filed with this Petition are
part of Trial Court record.

5 Brief synopsis & List of Dates and Events

6 Memo Of Parties

7 Petition for grant of Bail, U/S-439 R/W


S- 482 of the Code Of Criminal Procedure
Code, 1973.

8 Annexure -P-1 (Colly)


Copy of the FIR, along with English
translation.

9 Annexure -P-2.
Copy of the Order Dated 29.05.2017,
passed by Shri Pulatsya Paramachala,
ASJ, Karkardooma Courts, Delhi, On The
First bail Application of the Petitioner.
10 Annexure- P- 3.
Copy of the Order Dated 01.06.2017,
passed by Ms. Ravinder Bedi, ASJ,
Karkardooma Courts, Delhi, On The
Second bail Application of the Petitioner.

11. Annexure -P-2.


Copy of the Order Dated 02.06.2017,
passed by Shri Pulatsya Paramachala,
ASJ, Karkardooma Courts, Delhi , On The
Third bail Application of the Petitioner.

12 Annexure- P- 4.
Copy of the Order dated 31.05.2017,
passed by Hon’ble Mr. Justice A K
Chawla, in the Bail Application of the Co-
Accused in the Bail Appln. No.1083 of
2017, titled as Rajender Singh Versus
The State of NCT of Delhi.

13 Application seeking exemption from filing


certified copies of the documents/
Annexures, along with Affidavit.

14 Vakalatnama

Certified that no Petition of this nature is pending before this


Hon’ble Court or any other Court including the Hon’ble Supreme
Court of India.

Petitioner

Through

Sushil Kr. Sharma & Shahar Alam Beg, Advocates,


(Counsel For The Petitioner)
877, Lawyers’ Chambers,
Saket Courts, New Delhi- 110017
E-mail-hellocounsel@gmail.com
Mob. No.:-9818165785
PLACE: New Delhi
DATED: 05.06.2017
In The High Court Of Delhi At New Delhi
Bail Application No. ______ of 2017

In The Matter Of:-


Jaswant Singh …….Petitioner
VERSUS

The State …… Respondent

Notice Of Motion
To,
The Standing Counsel,
Delhi Police.
Delhi High Court Lawyers Chambers,
Sher Shah Suri Road,
New Delhi.

Dear Sir,

Kindly find attached the copy of the Bail Application, which is


most likely to be listed before the Hon’ble High Court of Delhi on
_________________.

This is for your kind notice and necessary action.

Petitioner

THROUGH

Sushil Kr. Sharma & Shahar Alam Beg,


Advocates,
(Counsel For The Petitioner)
877, Lawyers’ Chambers,
Saket Courts, New Delhi- 110017
E-mail-hellocounsel@gmail.com
Mob. No.:-9818165785
PLACE: New Delhi
DATED: 05.06.2017
In The High Court Of Delhi At New Delhi
Bail Application No. ______ of 2017

In The Matter Of:-


Jaswant Singh …….Petitioner
VERSUS

The State …… Respondent

To,
The Registrar,
High Court of Delhi.
Sher Shah Suri Road,
New Delhi.

Urgent Application
Sir,

Would you kindly treat the accompanying Revision as an


urgent matter in terms of Delhi High Court Rules? The urgency is
that:

The Petitioner has sought Bail U/S- 439 R/W S- 482 of


the Code of Criminal Procedure Code, in the Case arising out
of the FIR No: 0040 of 2015 (Dated: 14/01/2015), PS: Kalyanpuri,
U/S: 186/308/332/353/34 OF IPC, District-East, currently pending
in the Court of Shri N K Laka, CMM, Karkardooma Court, New
Delhi.

It is prayed accordingly.

Petitioner

Through

Sushil Kr. Sharma & Shahar Alam Beg, Advocates,


(Counsel For The Petitioner)
877, Lawyers’ Chambers,
Saket Courts, New Delhi- 110017
E-mail-hellocounsel@gmail.com
Mob. No.:-9818165785
PLACE: New Delhi
DATED: 05.06.2017
In The High Court Of Delhi At New Delhi
Bail Application No. ______ of 2017

In The Matter Of:-


Jaswant Singh …….Petitioner
VERSUS

The State …… Respondent

CERTIFICATE
To,
The Registrar,
High Court of Delhi.
Sher Shah Suri Road,
New Delhi.

Sir,

This is to certify that entire material/ document/ annexures, relied


upon and placed on the record are the part of the trial court
record and nothing additional has been filed.

Petitioner

Through

Sushil Kr. Sharma & Shahar Alam Beg, Advocates,


(Counsel For The Petitioner)
877, Lawyers’ Chambers,
Saket Courts, New Delhi- 110017
E-mail-hellocounsel@gmail.com
Mob. No.:-9818165785
PLACE: New Delhi
DATED: 05.06.2017
BRIEF SYNOPSIS & LIST OF DATES & EVENTS

The Petitioner/ Accused was apprehended/ arrested in this Case

on 25.05.2017. The Case arises out of the FIR No: 0040 of 2015

(Dated: 14/01/2015), PS: Kalyanpuri, U/S: 186/308/332/353/34 OF

IPC, District-East. The Charge Sheet has been filed by the Police

in this Case, and the case is currently pending adjudication in the

Court of Shri N K Laka, CMM, Karkardooma Court, New Delhi, the

same being at the stage of scrutiny of documents. The list of

dates and events forming part of this case are as follows:

LIST OF DATES & EVENTS

14.01.2015 An FIR was registered against the Petitioner/

Accused and his whole family. Five family

members were named in the FIR itself, namely,

(1) Jaswant Singh [(43 years) (Petitioner/

Accused himself)], (2) Rahul [(34 years)

(Brother of the Petitioner/ Accused)], (3)

Rajender Singh [(38 years) (Brother of the

Petitioner/ Accused)], (4) Mahendra Kaur (W/O

Ashoki) [(52 years) (Sister of the Petitioner/

Accused)] and (5) Bhag Singh [(75 years)

(Father of the Petitioner/ Accused)]. Two

neighbors of the Petitioner/ Accused have also


been implicated in this case, namely, (1) Sunny

and (2) Arjun.

The particulars of the FIR are as follows: FIR No:

0040 of 2015 (Dated: 14/01/2015), PS:

Kalyanpuri, U/S: 186/308/332/353/34 OF IPC,

District-East.

25.05.2017 The Applicant/ Accused was arrested by the

Police on 25.05.2017. His Police Custody (PC)

was however not sought by the Police.

26.05.2017 The Applicant/ Accused is in the judicial custody

(JC) since 26.05.2017.

29.05.2017 The Petitioner/ Accused filed his first bail

Application. The Court of Sh. Pulatsya

Paramachala, ASJ, Karkardooma Courts, Delhi,

disposed off the First Bail Application of the

Petitioner/ Accused vide Order dated 29.05.2017

by observing that since the main charge sheet is

pending adjudication before Ms. Ravinder Bedi,

ASJ, therefore the Application/ Accused should

move the Trial Court/ Sessions Court for regular

Bail.

31.05.2017 In this Case, this Hon’ble Court has been

pleased to grant Bail to the co-Accused,


Rajender Singh vide its Order dated 31.05.2017,

as passed by Hon’ble Mr. Justice A K Chawla, in

the Bail Application No.1083 of 2017, titled as

Rajender Singh Versus The State of NCT of

Delhi.

01.06.2017 The Petitioner/ Accused filed his Second bail

Application. The Court of Ms. Ravinder Bedi,

ASJ, Karkardooma Courts, Delhi expressed her

inability to hear the Bail Plea of the Petitioner/

Applicant in the absence of the Charge sheet

qua the Petitioner/ Accused. The Ld. ASJ

disposed off the Second Bail Application of the

Petitioner/ Accused observing that the Case qua

the Petitioner/ Accused was not yet allocated to

her Court.

02.06.2017 The Petitioner/ Accused filed his Third bail

Application. The Court of Sh. Pulatsya

Paramachala, ASJ, Karkardooma Courts, Delhi

disposed off the Third Bail Application vide its

Order dated 02.06.2017, reiterating its

observations, as made in the order dated

29.05.2017.
09.06.2017 The matter before the trial Court (Chief

Metropolitan Magistrate (CMM) is at the stage of

scrutiny of documents and the same is being

listed for 09.06.2017 for the said purpose. The

matter is likely to take its own time before it was

actually committed for trial to the Court of

Additional Sessions Judge (ASJ).

05.06.2017 Hence the present Revision.


In The High Court Of Delhi At New Delhi
Bail Application No. ______ of 2017

In The Matter Of:-


Jaswant Singh …….Petitioner
VERSUS

The State …… Respondent


Memo of Parties
[In the Case arising out of the FIR No: 0040 of 2015 (Dated: 14/01/2015),
PS: Kalyanpuri, U/S: 186/308/332/353/34 OF IPC, District-East, currently
pending in the Court of Shri N K Laka, CMM, Karkardooma Court, New Delhi]

Petitioner:-
Mr. Jaswant Singh [Aged Nearly 47 years]
S/o Shri Bhag Singh
R/o House No. 20/80,
Kalyanpuri,
Delhi- 110091
And

Respondent:-
The State
Through
The SHO,
PS-Kalyanpuri (District- East)
New Delhi

Petitioner

Through

Sushil Kr. Sharma & Shahar Alam Beg, Advocates,


(Counsel For The Petitioner)
PLACE: New Delhi
DATED: 05.06.2017.
In The High Court Of Delhi At New Delhi
Bail Application No. ______ of 2017

In The Matter Of:-


Jaswant Singh …….Petitioner
VERSUS

The State …… Respondent

District- East Delhi

PETITION, UNDER SECTION-439, READ WITH SECTION-482 OF


THE CODE OF CRIMINAL PROCEDURE, 1973, FOR GRANT OF
BAIL, IN THE CASE ARISING OUT OF THE FIR NO: 0040 OF 2015
(DATED: 14/01/2015), PS: KALYANPURI, U/S:
186/308/332/353/34 OF IPC, DISTRICT- EAST DELHI,
CURRENTLY PENDING ADJUDICTION IN THE COURT OF SHRI
N. K. LAKA, CMM, KARKARDOOMA COURT, NEW DELHI.

TO,
THE CHIEF JUSTICE
AND HIS COMPANION JUSTICES OF HON’BLE
HIGH COURT OF DELHI, AT NEW DELHI

THE PETITIONER ABOVENAMED MOST RESPECTFULLY


SHEWETH:

1. That the present Petition has been filed seeking bail in the

Case arising out of the FIR No: 0040 of 2015 (Dated:

14/01/2015), PS: Kalyanpuri, U/S: 186/308/332/353/34 OF

IPC, District-East Delhi, currently pending in the Court of Shri

N. K. Laka, CMM, Karkardooma Court, New Delhi. The copy of

the FIR, along with its English translation is annexed herewith

as ANNEXURE-P-1 (Colly.).
2. That the brief facts of the case leading to the filing of this

Petition are as follows:

3. That the Applicant/ Accused is a law abiding Citizen. He

however, has been falsely implicated by the Police by lodging

against him completely vexatious, false, frivolous and

baseless FIR.

4. That the FIR in question was registered against the

Petitioner/ Accused and his whole family. Five family

members were named in the FIR itself, namely, (1) Jaswant

Singh [(43 years) (Petitioner/ Accused himself)], (2) Rahul

[(34 years) (Brother of the Petitioner/ Accused)], (3)

Rajender Singh [(38 years) (Brother of the Petitioner/

Accused)], (4) Mahendra Kaur (W/O Ashoki) [(52 years)

(Sister of the Petitioner/ Accused)] and (5) Bhag Singh [(75

years) (Father of the Petitioner/ Accused)]. Two neighbors of

the Petitioner/ Accused have also been implicated in this

case, namely, (1) Sunny and (2) Arjun.

5. That the Police did not seek the arrest of the Petitioner/

Accused at any point in time, ever since the date of the

registration of the FIR and till the date he was actually

arrested on 25.05.2017. The fact remains, the house of the

Petitioner/ Accused is at stone’s throw distance from the

Police Station- Kalyanpuri where the FIR stands lodged and


the Petitioner/ Accused earns his living by driving an Auto in

the same locality where the Police Station- Kalyanpuri is

situated.

6. That it would be relevant to mention here in that the

Petitioner/ Accused had his Auto employed in the Election

duty in the recently concluded elections for the Municipal

Corporation in the same area where the Police Station-

Kalyanpuri is situated.

7. That the Police showed in its record the Petitioner/ Accused

an absconder, and procured the necessary Orders under

Sections-82/83 of the Code of Criminal procedure, 1973, just

with malafide intentions and ulterior motives.

8. That the Applicant/Accused was arrested by the Police on

25.05.2017 and he is in the judicial custody since 26.05.2017.

It would be relevant to mention herein that no police custody

(PC) was sought of the Petitioner/ Accused by the Police in

this case.

9. That on 28.05.2017, the Petitioner/ Applicant moved First Bail

Application, U/S- 439 0f the Code of Criminal Procedure,

1973, to the District & Sessions Judge, Karkardooma, Delhi,

which was assigned in due course to the Court of

Sh. Pulatsya Paramachala, ASJ, Karkardooma Courts, Delhi.


After hearing, the Ld. ASJ however disposed off the bail

Application vide Order dated 29.05.2017 by observing that

since the main charge sheet is pending adjudication before

Ms. Ravinder Bedi, ASJ, therefore the Application/ Accused

should move the Trial Court/ Sessions Court for regular Bail.

The copy of the Order dated 29.05.2017 is annexed herewith

as ANNEXURE-P-2 (Colly.).

10. That consequently, the Petitioner/ Accused moved the

Second Bail Application, U/S- 439 0f the Code of Criminal

Procedure, 1973, before the Court of Ms. Ravinder Bedi, ASJ,

Karkardooma Courts, Delhi. However, it transpired before the

Trail Court that the supplementary Charge Sheet qua the

Petitioner/ Accused has been filed before the Chief

Metropolitan Magistrate (CMM), Karkardooma, Delhi and the

matter will next come up for hearing before the Ld. CMM for

the scrutiny of documents on 09.06.2017.

11. That in its Order dated 01.06.2017, the Court of Ms. Ravinder

Bedi, ASJ, Karkardooma Courts, Delhi, while observing that

the Case qua the Petitioner/ Accused was not yet allocated to

her Court, expressed her inability to hear the Bail Plea of the

Petitioner/ Applicant in the absence of the Charge sheet qua

the Petitioner/ Accused. Resultantly, fearing further delay in

the matter, the Counsel for the Petitioner/ Accused opted to


withdraw the Bail Application so as to file the same before

the Court of District & Sessions Judge again, which is the only

Court of competent jurisdiction. The copy of the Order dated

01.06.2017 is annexed herewith as ANNEXURE-P-3.

12. That on 01.06.2017, the Petitioner/ Accused moved the Third

Bail Application to the District & Sessions Judge,

Karkardooma, Delhi, which was again assigned to the Court

of Sh. Pulatsya Paramachala, ASJ, Karkardooma Courts,

Delhi. After hearing, the Court however disposed off the bail

Application vide its Order dated 02.06.2017, reiterating its

observations, as made in the order dated 29.05.2017. The

copy of the Order dated 02.06.2017 is annexed herewith as

ANNEXURE-P-3.

13. That in the meanwhile in the same Case, this Hon’ble Court

has been pleased to grant Bail to the co-Accused, Rajender

Singh vide its Order dated 31.05.2017, as passed by Hon’ble

Mr. Justice A K Chawla, in the Bail Application No.1083 of

2017, titled as Rajender Singh Versus The State of NCT of

Delhi. The copy of the Order dated 31.05.2017 is annexed

herewith as ANNEXURE-P-4.

14. That the fact remains, the matter before the trial Court (Chief

Metropolitan Magistrate (CMM) is at the stage of scrutiny of

documents and the same is being listed for 09.06.2017 for


the said purpose. The matter is likely to take its own time

before it was actually committed for trial to the Court of

Additional Sessions Judge (ASJ).

15. That the investigation in this case is complete, as the Charge

Sheet has already been filed in this matter. Currently the

matter is at the stage of scrutiny of documents and the same

is listed for the same on 09.06.2017.

16. That there is no question of tampering with the evidence in

this case, as the witnesses and the victim in this case are the

Police personnel themselves. Besides, the Accused/Applicant

undertakes not to contact the said Victims/Complainant in

this Case.

17. That the Applicant/ Accused is a permanent resident of Delhi.

He has his family residing permanently in Delhi and has deep

roots in the society. There is no question of he fleeing from

justice or absconding by any stretch of the imagination.

18. That the antecedents of the Petitioner are clean. He belongs

to a respectable family. Prior to this, he has never been

convicted in any Case.

19. That on the top of it all, the Applicant/ Accused is the sole

bread earner of his family and earns his living on daily basis

by driving an auto.
20. That the Trial of the case would take a long time and keeping

the Applicant/Accused in Judicial Custody (JC) would not

serve any fruitful purpose. On the contrary, his whole family

will come on the road if his incarceration prolongs, he being

the sole bread earner of his family.

21. That the Petitioner undertakes to attend the proceedings

before the concerned Court regularly, as and when called

upon to do so, as also join further investigation, if any.

22. That the Accused / Applicant further undertakers to abide by

all the conditions which this Hon’ble court pleases to impose

to enlarge him on bail.

23. That the Petitioner has sought Bail on the following grounds

amongst others:

GROUNDS

A. BECAUSE the Petitioner/ Accused is behind the bars

since 25.05.2017, for nearly 12 days.

B. BECAUSE the Case of the Police is highly improbable

by its very nature, as the FIR in question was

registered against the Petitioner/ Accused, his whole

family and the neighbors.


C. BECAUSE the Police did not seek the arrest of the

Petitioner/ Accused at any point in time since the

date of the registration of the FIR and till the date

he was actually arrested on 25.05.2017 with

malafide intentions and ulterior motives.

D. BECAUSE the Court below, i.e. the Court of Sh.

Pulatsya Paramachala, ASJ, Karkardooma Courts,

Delhi gravely erred while directing the Petitioner/

Accused to move for bail the Trial Court/ Sessions

Court.

E. BECAUSE the Ld. ASJ (Sh. Pulatsya Paramachala,

ASJ, Karkardooma Courts, Delhi) disregarded the

observations, as made in the order dated

01.06.2017, as passed by Ms. Ravinder Bedi, ASJ,

wherein she had unambiguously noted that the

Case/ Charge sheet of the Petitioner/ Accused was

not allocated to her.

F. BECAUSE the Ld. ASJ (Sh. Pulatsya Paramachala,

ASJ, Karkardooma Courts, Delhi) further overlooked

the submission of the Counsel of the Petitioner/

Accused wherein he had highlighted the fact that

the matter/ Case of the Petitioner/ Accused was


listed before the concerned Court of Chief

Metropolitan Magistrate (CMM) on 09.06.2017 for

scrutiny of documents/ chargesheet.

G. BECAUSE the Court below, i.e. the Court of Sh.

Pulatsya Paramachala, ASJ, Karkardooma Courts,

Delhi has refused to exercise its jurisdiction, while

refusing to hear the Bail Plea of Petitioner/ Accused

on the merit of the Case.

H. BECAUSE the Court below, i.e. the Court of Sh.

Pulatsya Paramachala, ASJ, Karkardooma Courts,

Delhi has exceeded its jurisdiction, while directing

the Petitioner/ Accused to move for bail the Trial

Court/ Sessons Court.

I. BECAUSE this Hon’ble Court has been pleased to

grant Bail to the co-Accused, Rajender Singh vide its

Order dated 31.05.2017.

J. BECAUSE had the Ld. the Court of Sh. Pulatsya

Paramachala, ASJ, heard the Counsel for the

Petitioner on the merit of the Case, a very vital

factum of passing of order by this Hon’ble Court on

the Bail Application of the Co-Accused could also


have been pleaded. Needless to say, the Order of

this Hon’ble Court could have impacted the very

root of the whole matter before the Ld. ASJ.

K. BECAUSE the matter before the trial Court (Chief

Metropolitan Magistrate (CMM) is at the stage of

scrutiny of documents and the same is being listed

for 09.06.2017 for the said purpose. The matter is

likely to take its own time before it was actually

committed for trial to the Court of Additional

Sessions Judge (ASJ).

L. BECAUSE the investigation in this case is complete,

as the Charge Sheet has already been filed in this

matter.

M. BECAUSE the Petitioner/ Accused is no longer

required in this Case, as no police custody (PC) was

sought of the Petitioner/ Accused by the Police in

this case.

N. BECAUSE there is no question of tampering with the

evidence in this case, as the witnesses and the

victims in this case are the Police personnel

themselves.
O. BECAUSE the Applicant/ Accused is a permanent

resident of Delhi. He has his family residing

permanently in Delhi and has deep roots in the

society. There is no question him fleeing from

justice or absconding by any stretch of the

imagination.

P. BECAUSE the antecedents of the Petitioner are

clean. He belongs to a respectable family. Prior to

this, he has never been convicted in any Case.

Q. BECAUSE on the top of it all, the Applicant/ Accused

is the sole bread earner of his family and earns his

living on daily basis by driving an auto. His whole

family of the Petitioner/Accused will come on the

road if his incarceration prolongs, he being the sole

bread earner of his family.

R. BECAUSE the Trial of the case would take a long

time and keeping the Petitioner/Accused in Judicial

Custody (JC) would not serve any fruitful purpose.

24. The petitioner craves leave to add, alter, amend, modify,

delete and/or substitute any of the contents/ grounds of

this Petition, as and when required.


25. That this Petition is maintainable, as this Hon’ble Court

solely commands the jurisdiction to adjudicate and decide

on the subject matter of this Petition.

26. That there is no efficacious and alternative remedy available

to the Petitioner/ Accused, except for the filing of this

Petition, in the given facts and circumstances of this case.

27. That this Petition is within the period of limitation, as

provided under the statute. There has been no delay in

filing the same.

28. That all the documents accompanying this Petiton forms

part and parcel of the Trial Court Record.

29. That no Petition of this nature is pending before this Hon’ble

Court or any other Court including the Hon’ble Supreme

Court of India.

PRAYER

It is therefore most respectfully prayed that this Hon’ble Court

may be pleased to;

a. Enlarge the Petitioner on bail, in the Case arising out of the

FIR No: 0040 of 2015 (Dated: 14/01/2015), PS: Kalyanpuri,

U/S: 186/308/332/353/34 OF IPC, District-East Delhi,


currently pending in the Court of Shri N. K. Laka, CMM,

Karkardooma Court, New Delhi, subject to whatever

conditions which this Hon’ble Court deemed fit in the facts

and circumstances of this Case.

b. Pass any other and / or further order(s) in favour of the

Petitioner, which this Hon’ble Court may deem fit and

proper in the interest of Justice and fair play.

Petitioner
[In Judicial Custody]
[Through Perokar]
Through

Sushil Kr. Sharma & Shahar Alam Beg, Advocates,


(Counsel For The Petitioner)
877, Lawyers’ Chambers,
Saket Courts, New Delhi- 110017
E-mail-hellocounsel@gmail.com
Mob. No.:-9818165785
PLACE: New Delhi
DATED: 05.06.2017
THE HIGH COURT OF DELHI AT NEW DELHI
Bail Application No. ______ of 2017
IN THE MATTER OF:
Jaswant Singh …….Petitioner
VERSUS

The State …… Respondent

AFFIDAVIT

AFFIDAVIT OF MR. SACHIN, S/O SHRI JASWANT SINGH, AGED


NEARLY ____ YEARS, HOUSE NO. 20/80, KALYANPURI, DELHI-
110091.

I, the Deponent, do hereby solemnly affirm and declare as


under:-

1. That I am the Son and a Perokar of the Petitioner/ Accused

in the above noted/ accompanying Bail Petition U/S- 439,

R/W S-482 of the Code of Criminal Procedure, 1973, and

therefore am competent to file this Affidavit in support of

the Petition.

2. That the accompanying Petition has been drafted by my

counsel as per joint instructions of mine and my father and

has been read over to me in a vernacular language. I have

fully understood the contents of the Petition. I also found

the contents of this Petition to be true and correct.

DEPONENT
VERIFICATION:-

Verified at Delhi on 05th day of June, 2017 that the contents of

the above noted affidavit are true and correct to my knowledge

and belief, based on what has been told about the case by my

father to me, and nothing material has been concealed there

from.

DEPONENT
THE HIGH COURT OF DELHI AT NEW DELHI
Bail Application No. ______ of 2017
IN THE MATTER OF:
Jaswant Singh …….Petitioner
VERSUS

The State …… Respondent

APPLICATION UNDER SECTION-482 OF THE CODE OF


CRIMINAL PROCEDURE, 1973, SEEKING EXEMPTION
FROM FILING CERTIFIED COPY OF THE DOCUMENTS/
ANNEXURES.

MOST RESPECTFULLY SUBMITTED AS UNDER:

1. That the Petitioner has filed along with the Captioned

Petition uncertified copy of the documents.

2. That the Petitioner could not file the certified copy of the

Documents/ Annexures, annexed with the Petition due to

paucity of time.

3. That the Petitioner undertakes to file the certified copy on

the record of this Hon’ble court, in the event of any

opposition from the opposite party(ies) qua their contents

and/ or as and when directed by this Hon’ble Court to do

so.
4. That the Petitioner therefore humbly seek to be exempted

from filing the certified copy of the impugned Documents/

Annexures.

PRAYER

It is therefore most respectfully prayed that this Hon’ble Court


may be pleased to:-

a. Exempt the Petitioner from filing certified copy of the

Impugned documents/ annexures.

b. Pass any other and / or further order(s) in the favour of the

Petitioner, which this Hon’ble Court may deem fit and

proper in the interest of Justice and fair play.

Petitioner

Through

Sushil Kr. Sharma & Shahar Alam Beg, Advocates,


(Counsel For The Petitioner)
877, Lawyers’ Chambers,
Saket Courts, New Delhi- 110017
E-mail-hellocounsel@gmail.com
Mob. No.:-9818165785
PLACE: New Delhi
DATED: 05.06.2017
THE HIGH COURT OF DELHI AT NEW DELHI
Bail Application No. ______ of 2017
IN THE MATTER OF:
Jaswant Singh …….Petitioner
VERSUS

The State …… Respondent

AFFIDAVIT

AFFIDAVIT OF MR. SACHIN, S/O SHRI JASWANT SINGH, AGED


NEARLY ____ YEARS, HOUSE NO. 20/80, KALYANPURI, DELHI-
110091.

I, the Deponent, do hereby solemnly affirm and declare as


under:-

1. That I am the Son and a Perokar of the Petitioner/ Accused

in the above noted/ accompanying Bail Petition U/S- 439,

R/W S-482 of the Code of Criminal Procedure, 1973, and

therefore am competent to file this Affidavit in support of

the Petition.

2. That the accompanying Application, seeking exemption from

filing certified copy of the impugned documents/ annexures

has been drafted by my counsel as per joint instructions of

mine and my father and has been read over to me in a

vernacular language. I have fully understood the contents

of the Petition. I also found the contents of this Petition to

be true and correct.

DEPONENT
VERIFICATION:-

Verified at Delhi on 05th day of June, 2017 that the contents of

the above noted affidavit are true and correct to my knowledge

and belief, based on what has been told about the case by my

father to me, and nothing material has been concealed there

from.

DEPONENT
In The High Court Of Delhi At New Delhi
Bail Application No. ______ of 2017

In The Matter Of:-


Jaswant Singh …….Petitioner
VERSUS

The State …… Respondent

To,
The Registrar,
High Court of Delhi.
Sher Shah Suri Road,
New Delhi.

Letter of Authorisation
Sir,

I, the undersigned, hereby authorize my Clerk, Mukund


Narayan Sharma, whose signatures are encircled below, to collect
the copy of the Dasti Order in the captioned case.
Kindly oblise me by handing out the copy of the order to my
Clerk.

Petitioner

Through

Sushil Kr. Sharma & Shahar Alam Beg, Advocates,


(Counsel For The Petitioner)
877, Lawyers’ Chambers,
Saket Courts, New Delhi- 110017
E-mail-hellocounsel@gmail.com
Mob. No.:-9818165785
PLACE: New Delhi
DATED: 13.06.2017
CODE OF CRIMINAL PROCEDURE, 1973
CHAPTER XXXVII: MISCELLANEOUS
Section-482. Saving of inherent power of High Court.-
Nothing in this Code shall be deemed to limit or affect the
inherent powers of the High Court to make such orders as may be
necessary to give effect to any order under this Code, or to
prevent abuse of the process of any Court or otherwise to secure
the ends of justice.

_________@@@@@@___________

CHECK LIST OF THE WORK TO BE DONE

 Caveat Report
 Listing Performa
 Opening Sheet
 Sign- Each Page
 Ticket- Rs,20/-
 Annexures- Rs,75 Per Page.