MEMORANDOM OF CRIMINAL ORIGINAL PETITION (Under Section 439 of Criminal Procedure code) IN THE HIGHCOURT OF JUDICATURE AT CHENNAI.

(CRIMINAL JURISDICTION) CRL.OP.NO. in CRIME .NO. 310 OF 2011. OF 2011.

(on the file of the Respondent Police )

1. Nagoor Hanifa M/A 23 yrs, S/o. Sheik Mohammed, Aringar Anna Nagar, Cycle Shop Puzhal, Chennai-600 066.

Petitioner/Accused-1.

-VsState rep by The Inspector of Police , Puzhal Police Station, Chennai District. (crime 310 of 2011)

. Respondent /Complainant.

PETITON FILED UNDER SECTION 439 CR.P.C.

The Address for service of all notices and processes on the Petitioner is that of his counsel M/S.N.Venkatesan and K.Kayalvizhi at no. 387 Addl Law Chambers, High court Buildings, Chennai-600 104. 1. The Petitioner above named begs to prefer this petition before this Hon ble court praying for releasing him in Bail pending in crime No.310 of 2011 on the file of the Respondent here in and begs to submit as follows;

2. The Petitioner submit that the Petitioner charged for an offence under section 341, 336,294(b), 397, 506(ii) of I.P.C. 3. The Petitioner submits that the prosecution case is that one Mr.Johnson S/o Anthony lodged a complaint before the respondent police that the petitioner way laid the complainant and robbed Rs.200/-. 4. The Petitioner has been arrested and remanded to judicial custody by the respondent police on 24.04.2011 from the date onwards he was in central prison, Puzhal.For getting bail the petitioner herein approached the court of the Principal District and sessions vacation Judge,At Thiruvallur by way of

Crl.M.P.No.1005/2011.The same was dismissed on 18.05.2011.Hence the petitioner herein approached this Hon ble HighCourt by way of this petition. 5. The Petitioner submits that if he is not released on bail, will cause great prejudice and inconvenience to him and his family. 6. The Petitioner submits that he is no way connected with the facts of the case. No similar petition filed or pending in any other court. 7. The petitioner submits that the petitioner herein is ready and willing to cooperate with the respondent herein the investigation of the case and he undertake not to abscond and tamper any witness. He is also ready and willing to other substantial sureties and to abide any condition imposed by this Hon ble court. 8. This is the first Bail application filed before this Hon ble court and no similar petition is pending before any other court including Highcourt

Therefore it is humbly prayed that this Hon ble court may be pleased to release the petitioner on bail pending in crime no.310 of 2011 on the file of the Respondent herein and pass such further orders as this Hon ble court may deem fit and proper in the circumstances of the case and thus render justice. Dated at Chennai on this the 10th day of June 2011.

Counsel for petitioner.

Note: 1. Bail to the surety satisfaction at District cum Judicial Magistrate Thiruvottiyur . 2. The Petitioner now confined at Central Prison,Puzhal. 3. This the First Bail petition at this stage.

IN THE HIGHCOURT OF JUDICATURE AT CHENNAI. (CRIMINAL JURISDICTION) CRL.OP.NO. in CRIME NO. 310 OF 2011. OF 2011.

BAIL PETITON FILED U/S 439 Of Cr.P.C.

M/S.N.VENKATESAN. Counsel for Petitioner.