Shikha Mukesh Meena, 1239, Section B

Bail Application 1 (for accused No. 1- Mr. Ranjeet)

IN THE DISTRICT AND SESSION COURT JYOTIBA PHULE NAGAR

Ranjeet Sharma S/O Raj Sharma R/O 654, Mayuri Colony, Jyotibha Phule Nagar, UP…….
……………………………………………………………….Petitioner-Accused No. 1

Versus

State…………………………………………………………………………………Respondent

FIR No.: 26/14

Under Sections 120B, 392, 397 of the Indian Penal Code, Section 25 of the Arms Act

Police Station: Gajraula, District Jyotiba Phule Nagar

APPPLICATION UNDER SECTION 437,

CRIMINAL PRODECURE CODE 1973 FOR BAIL

The Accused No. 1 above-named most respectfully SHOWETH: -

1. That the accused subsequent to information received By ASI Akhilesh Kumar was arrested
by the police of Gajraula police station on 12th June 2014 for offence under sections 120B,
395 and 397 of the IPC and section 25 of Arms act and is in judicial custody since then.
2. That the accused has been falsely implicated in the instant case and he has nothing to do
with the alleged offence.
3. That the accused is a law abiding citizen and belongs to a respectable family and has never
indulged in any illegal activities and command respect and admiration in his locality.
4. That on 10.06.2014, the complainants were carrying a sum of Rs. 1, 50,000 (One Lakh Fifty
Thousand) with them to purchase a piece of land. Around 10 A.M they were near a farm in
Gajraula, Jyotiba Phule Nagar District of Uttar Pradesh. Around which Accused No. 1 along
with accused No. 2 allegedly came in a Maruti (registered under the name of accused No. 1),
stopped the Complainants and brandished a pistol, demanding all money they had.

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 Shikha Mukesh Meena, 1239, Section B

5. That according to the FIR, the Accused were allegedly informed of such money being with
the Complainants by accused 3 & 4 (i.e. a Mr. Rajesh and Mr. Raman), who are employees
at the firm of the Complainant. And that also, the petitioner-accused and the employees of
the firm made confessional and disclosure statement to the police, leading them to recover
Rs 56,000 from accused 1’s house & the remaining 94,000 (out of 1,50,000) were spent by
Accused 1 & 2.
6. That due to the vested and nefarious intention of the complainants, the Accused have been
wrongfully named as accused in the said FIR.
7. That the Accused No.1 along with Accused No.2 were not even present in the Gajraula at the
time of such events. That from 1st June 2014 to 15th June 2014, Accused No.1 along with
accused No. 2 were on a camping trip in Himachal Pradesh within a group of 20 people. The
same has been shown through their registration forms to the camp, pictures taken at the camp
by various members of group which are date stamped and written affidavits attesting to the
both the accused’s presence in the camp by the same members. The same can be shown by
tracking their locations with the help of Global System for Mobile Communications (GSM),
the reports of which has been submitted under Exhibit “A” & the forms & pictures taken
under Exhibit “B”, affidavits under Exhibit “C”.
8. That the accused was not in possession of his car as he had rented it out for the duration of
his trip to a Mr. Amit Trivedi who runs a taxi service. The same can be shown by the papers
drawn by Mr. Amit Trivedi under Exhibit “D”.
9. That the amount of Rs 56,000 recovered from the accused No. 1’s house was his, received
after selling their old family tractor. The papers for which are provided under Exhibit “E”.
10. That the Accused never carried any such pistol nor robbed the Complainants.
11. That the Accused No. 1 has been falsely implicated in the instant case and they have nothing
to do with the alleged offence, and the police is adopting a partisan approach by supporting
the alleged disclosure statement, which was never made.
12. It was falsely written in the FIR that the Accused made confessional statements.
13. That as per the version of the FIR, the recovery has already been affected upon which
further elaborates the fact that it made no sense for the Accused to be left in jail for the
duration of the trial.

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 Shikha Mukesh Meena, 1239, Section B

14. That it is important for the accused to gather evidence in their favor and uncover the truth
which will be only feasible if they are granted bail during the pendency of the trail against
them.
15. The accused is also willing to join the investigations and bind himself by the terms and
conditions laid down by the law or by this Hon'ble court.
16. That the accused have a very good antecedents, he is not a previous convict and has not been
involved in any crime except the present case.
17. That the accused is a permanent resident of Gajraula and there are no chances of his
absconding from the course of justice in case he is released on bail.
18. That the accused undertakes to present himself before the police/court as and when directed.
19. That there is no chance of the Accused No. 1 tampering with the prosecution evidence in the
event of release on bail.
20. That the accused is ready and willing to accept any other conditions as may be imposed by
the Court or the police in connection with the case.
21. That the present case is a result of clear manipulation by the police.
22. That the Accused No. 1, on all accounts is innocent.

PRAYER

It is therefore respectfully prayed that the Accused may kindly be released on bail during the
pendency of this case.

Accused
Place: Jyotiba Phule Nagar
Date: 13.06.2014
Through
Sd/-
Shikha Mukesh Meena

(Advocate)

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 Shikha Mukesh Meena, 1239, Section B

Bail Application 2 (for accused No. 2- Mr. Rajender)

IN THE DISTRICT AND SESSION COURT JYOTIBA PHULE NAGAR

Rajender Khatana S/O Manvir Khatana R/O 22, HVK Colony, Jyotibha Phule Nagar, UP…….
……………………………………………………………….Petitioner-Accused No. 2

Versus

State…………………………………………………………………………………Respondent

FIR No.: 21/14

Under Sections 120B, 392, 397 of the Indian Penal Code, Section 24 of the Arms Act

Police Station: Gajraula, District Jyotiba Phule Nagar

APPPLICATION UNDER SECTION 437,

CRIMINAL PRODECURE CODE 1973 FOR BAIL

The Accused No. 2 above-named most respectfully SHOWETH: -

1. That the accused subsequent to information received By ASI Akhilesh Kumar was arrested
by the police of Gajraula police station on 12 th June 2014 for offence under sections 120B,
395 and 397 of the IPC and section 25 of Arms act and is in judicial custody since then.
2. That the accused has been falsely implicated in the instant case and he has nothing to do
with the alleged offence.
3. That the accused is a law abiding citizen and belongs to a respectable family and has never
indulged in any illegal activities and command respect and admiration in his locality.
4. That on 10.06.2014, the complainants were carrying a sum of Rs. 1, 50,000 (One Lakh Fifty
Thousand) with them to purchase a piece of land. Around 10 A.M they were near a farm in
Gajraula, Jyotiba Phule Nagar District of Uttar Pradesh. Around which Accused No. 1 along
with Accused No. 2 allegedly came in a Maruti (registered under the name of accused No.
1), stopped the Complainants and brandished a pistol, demanding all money they had.

4
 Shikha Mukesh Meena, 1239, Section B

5. That according to the FIR, the Accused were allegedly informed of such money being with
the Complainants by accused 3 & 4 (i.e. a Mr. Rajesh and Mr. Raman), who are employees
at the firm of the Complainant. And that also, the petitioner-accused and the employees of
the firm made confessional and disclosure statement to the police, leading them to recover
Rs 56,000 from accused 1’s house & the remaining 94,000 (out of 1,50,000) were spent by
accused 1 & 2.
6. That due to the vested and nefarious intention of the complainants, the Accused have been
wrongfully named as accused in the said FIR.
7. That the Accused No.2 along with Accused No.1 were not even present in the Gajraula at the
time of such events. That from 1st June 2014 to 15th June 2014, Accused No.2 along with
accused No. 1 were on a camping trip in Himachal Pradesh within a group of 20 people. The
same has been shown through their registration forms to the camp, pictures taken at the camp
by various members of group which are date stamped and written affidavits attesting to the
both the accused’s presence in the camp by the same members. The same can be shown by
tracking their locations with the help of Global System for Mobile Communications (GSM),
the reports of which has been submitted under Exhibit “A” & the forms & pictures taken
under Exhibit “B”, affidavits under Exhibit “C”.
8. That the Accused never carried any such pistol nor robbed the Complainants.
9. That the Accused No. 2 has been falsely implicated in the instant case and they have nothing
to do with the alleged offence, and the police is adopting a partisan approach by supporting
the alleged disclosure statement, which was never made.
10. It was falsely written in the FIR that the Accused made confessional statements.
11. That as per the version of the FIR, the recovery has already been affected upon which
further elaborates the fact that it made no sense for the Accused to be left in jail for the
duration of the trial.
12. That it is important for the accused to gather evidence in their favor and uncover the truth
which will be only feasible if they are granted bail during the pendency of the trail against
them.
13. The accused is also willing to join the investigations and bind himself by the terms and
conditions laid down by the law or by this Hon'ble court.

5
 Shikha Mukesh Meena, 1239, Section B

14. That the accused have a very good antecedents, he is not a previous convict and has not been
involved in any crime except the present case.
15. That the accused is a permanent resident of Gajraula and there are no chances of his
absconding from the course of justice in case he is released on bail.
16. That the accused undertakes to present himself before the police/court as and when directed.
17. That there is no chance of the Accused No. 2 tampering with the prosecution evidence in the
event of release on bail.
18. That the accused is ready and willing to accept any other conditions as may be imposed by
the Court or the police in connection with the case.
19. That the present case is a result of clear manipulation by the police.
20. That the Accused No. 2, on all accounts is innocent.

PRAYER

It is therefore respectfully prayed that the Accused may kindly be released on bail during the
pendency of this case.

Accused
Place: Jyotiba Phule Nagar
Date: 13.06.2014.
Through
Sd/-
Shikha Mukesh Meena
(Advocate)

6
 Shikha Mukesh Meena, 1239, Section B

Bail Application 3 (for accused No. 3- Mr. Rajesh)

IN THE DISTRICT AND SESSION COURT JYOTIBA PHULE NAGAR

Rajesh Khanna S/O Anand Khanna R/O 765, Sector E, Jyotibha Phule Nagar, UP…….
……………………………………………………………….Petitioner-Accused No. 3

Versus

State…………………………………………………………………………………Respondent

FIR No.: 21/14

Under Sections 120B, 392, 397 of the Indian Penal Code, Section 25 of the Arms Act

Police Station: Gajraula, District Jyotiba Phule Nagar

APPPLICATION UNDER SECTION 437,

CRIMINAL PRODECURE CODE 1973 FOR BAIL

The Accused No. 3 above-named most respectfully SHOWETH: -

1. That the accused subsequent to information received By ASI Akhilesh Kumar was arrested
by the police of Gajraula police station on 12 th June 2014 for offence under sections 120B,
395 and 397 of the IPC and section 25 of Arms act and is in judicial custody since then.
2. That the accused has been falsely implicated in the instant case and he has nothing to do
with the alleged offence.
3. That the accused is a law abiding citizen and belongs to a respectable family and has never
indulged in any illegal activities and command respect and admiration in his locality.
4. That on 10.06.2014, the complainants were carrying a sum of Rs. 1, 50,000 (One Lakh Fifty
Thousand) with them to purchase a piece of land. Around 10 A.M they were near a farm in
Gajraula, Jyotiba Phule Nagar District of Uttar Pradesh. Around which Accused No. 1 & 2
allegedly came in a Maruti (registered under the name of accused No. 1), stopped the
Complainants and brandished a pistol, demanding all money they had.

7
 Shikha Mukesh Meena, 1239, Section B

5. That according to the FIR, Accused 1 & 2 were allegedly informed of such money being
with the Complainants by accused 3 & 4 (i.e. a Mr. Rajesh and Mr. Raman), who are
employees at the firm of the Complainant. And that also, the petitioner-accused and the
employees of the firm made confessional and disclosure statement to the police, according to
which Accused 3 & 4 each received Rs 10,000, leading the police to recover Rs 5,000 from
Accused 3’s premises.
6. That the alleged disclosure that accused has received Rs. 10000 for the information is false
and is fabricated by the Police. The Accused has not received any such amount.
7. That nothing is recovered from the possession of the accused and the so called recovery of
the alleged unspent amount i. e. Rs 5000 by the police is the money that the Accused
received, is his additional agricultural income that he receives every month as can be shown
by his monthly bank deposits, provided under Exhibit “A”.
8. That due to the vested and nefarious intention of the complainants, the Accused 3 have been
wrongfully named as accused in the said FIR.
9. That the Accused No. 3 has been falsely implicated in the instant case and they have nothing
to do with the alleged offence, and the police is adopting a partisan approach by supporting
the alleged disclosure statement, which was never made.
10. That as per the version of the FIR, the recovery has already been affected upon which
further elaborates the fact that it made no sense for the Accused to be left in jail for the
duration of the trial.
11. That it is important for the accused to gather evidence in their favor and uncover the truth
which will be only feasible if they are granted bail during the pendency of the trail against
them.
12. The accused is also willing to join the investigations and bind himself by the terms and
conditions laid down by the law or by this Hon'ble court.
13. That the accused have a very good antecedents, he is not a previous convict and has not been
involved in any crime except the present case.
14. That the accused is a permanent resident of Gajraula and there are no chances of his
absconding from the course of justice in case he is released on bail.
15. That the accused undertakes to present himself before the police/court as and when directed.

8
 Shikha Mukesh Meena, 1239, Section B

16. That there is no chance of the Accused No. 3 tampering with the prosecution evidence in the
event of release on bail.
17. That the accused is ready and willing to accept any other conditions as may be imposed by
the Court or the police in connection with the case.
18. That the present case is a result of clear manipulation by the police.
19. That the Accused No. 3, on all accounts is innocent.

PRAYER

It is therefore respectfully prayed that the Accused No. 3 may kindly be released on bail during
the pendency of this case.

Accused

Place: Jyotiba Phule Nagar

Date: 13.06.2014

Through

Sd/-

Shikha Mukesh Meena

(Advocate)

9
 Shikha Mukesh Meena, 1239, Section B

Bail Application 4 (for accused No. 4- Mr. Raman)

IN THE DISTRICT AND SESSION COURT JYOTIBA PHULE NAGAR

Raman Patel S/O Ashish Patel R/O 743, Sector 11, Jyotibha Phule Nagar, UP…….
……………………………………………………………….Petitioner-Accused No. 4

Versus

State…………………………………………………………………………………Respondent

FIR No.: 21/14

Under Sections 120B, 392, 397 of the Indian Penal Code, Section 25 of the Arms Act

Police Station: Gajraula, District Jyotiba Phule Nagar

APPPLICATION UNDER SECTION 437,

CRIMINAL PRODECURE CODE 1973 FOR BAIL

The Accused No. 4 above-named most respectfully SHOWETH: -

1. That the accused subsequent to information received By ASI Akhilesh Kumar was arrested
by the police of Gajraula police station on 12 th June 2014 for offence under sections 120B,
395 and 397 of the IPC and section 25 of Arms act and is in judicial custody since then.
2. That the accused has been falsely implicated in the instant case and he has nothing to do
with the alleged offence.
3. That the accused is a law abiding citizen and belongs to a respectable family and has never
indulged in any illegal activities and command respect and admiration in his locality.
4. That on 10.06.2014, the complainants were carrying a sum of Rs. 1, 50,000 (One Lakh Fifty
Thousand) with them to purchase a piece of land. Around 10 A.M they were near a farm in
Gajraula, Jyotiba Phule Nagar District of Uttar Pradesh. Around which Accused No. 1 & 2
allegedly came in a Maruti (registered under the name of accused No. 1), stopped the
Complainants and brandished a pistol, demanding all money they had.

10
 Shikha Mukesh Meena, 1239, Section B

5. That according to the FIR, Accused 1 & 2 were allegedly informed of such money being
with the Complainants by accused 3 & 4 (i.e. a Mr. Rajesh and Mr. Raman), who are
employees at the firm of the Complainant. And that also, the petitioner-accused and the
employees of the firm made confessional and disclosure statement to the police, according to
which Accused 3 & 4 each received Rs 10,000, leading the police to recover Rs 4,000 from
Accused 4’s premises.
6. That the alleged disclosure that accused has received Rs. 10000 for the information is false
and is fabricated by the Police. The Accused has not received any such amount.
7. That nothing is recovered from the possession of the accused and the so called recovery of
the alleged unspent amount i. e. Rs 4000 by the police is the money that the Accused
received, as rent for his shop, as shown by the agreement of lease under Exhibit “A”.
8. That due to the vested and nefarious intention of the complainants, the Accused 4 have been
wrongfully named as accused in the said FIR.
9. That the Accused No. 4 has been falsely implicated in the instant case and they have nothing
to do with the alleged offence, and the police is adopting a partisan approach by supporting
the alleged disclosure statement, which was never made.
10. That as per the version of the FIR, the recovery has already been affected upon which
further elaborates the fact that it made no sense for the Accused to be left in jail for the
duration of the trial.
11. That it is important for the accused to gather evidence in their favor and uncover the truth
which will be only feasible if they are granted bail during the pendency of the trail against
them.
12. The accused is also willing to join the investigations and bind himself by the terms and
conditions laid down by the law or by this Hon'ble court.
13. That the accused have a very good antecedents, he is not a previous convict and has not been
involved in any crime except the present case.
14. That the accused is a permanent resident of Gajraula and there are no chances of his
absconding from the course of justice in case he is released on bail.
15. That the accused undertakes to present himself before the police/court as and when directed.
16. That there is no chance of the Accused No. 4 tampering with the prosecution evidence in the
event of release on bail.

11
 Shikha Mukesh Meena, 1239, Section B

17. That the accused is ready and willing to accept any other conditions as may be imposed by
the Court or the police in connection with the case.
18. That the present case is a result of clear manipulation by the police.
19. That the Accused No. 4, on all accounts is innocent.

PRAYER

It is therefore respectfully prayed that the Accused No. 4 may kindly be released on bail during
the pendency of this case.

Accused

Place: Jyotiba Phule Nagar

Date: 13.06.2014

Through

Sd/-

Shikha Mukesh Meena

(Advocate)

12