Application of Bail Under Section 437 CRPC

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IN THE COURT OF METROPOLITAN MAGISTRATE (DISTRICT __________),

DELHI

BAIL APPLICATION NO. __________ OF 2017

IN THE MATTER OF :

STATE COMPLAINANT

VERSUS

X _______ S/o _______ R/o __________ …..APPLICANT

FIR NO. ________

U/S_________________

POLICE STATION _____________________

APPLICATION FOR GRANT OF BAIL UNDER SECTION 437 OF CR.P.C.

The accused above named most respectfully showeth :-

1. That the accused above named was arrested by the police on ________, 20XX and is in judicial
custody since then. It is alleged that on _________, 20XX, the accused was suspiciously moving on
_______________ when the police apprehended him, conducted the search and recovered ___ gms.
of smack from his pocket.

2. That the accused has been falsely implicated in the instant case and he has nothing to do with the
alleged offence.

3. That nothing was recovered from the possession of the accused or at his instance and the so called
case property has been planted upon the accused.

4. That the accused is a law abiding citizen and belongs to a very respectable family. He has never
indulged in any illegal activities and commands respect and admiration his locality.

5. That in _________, 20XX, the accused found some persons selling smack near______________.
The accused immediately reported the mater to police as the result of which police also arrested
some of the persons. Since that time, those persons who were arrested at the instance of the
accused, were threatening the accused to falsely implicate him in a criminal case in collusion with
police. The accused made a complaint in this regard to the Dy. Commissioner of Police, true copy of
which is annexed hereto as Annexure-A.

6. That after the said complaint, the accused was called by the Vigilance Department, _____ Police
who enquired into his complaint. True copy of the said notice issued by the Vigilance Cell is enclosed
herewith as Annexure-B.

7. That it is unimaginable that the accused who made a complaint against the sellers of smack, would
himself indulge in such activities.

8. That the accused is a permanent resident of ______ and there are no chance of his absconding in
case he is released on bail.
9. That there is no chance of the accused absconding or tempering with the prosecution evidence in
the event of release on bail.

10. That the accused undertakes to join the investigation as and when directed to do so.

11. That the accused is not a previous convict and has not been involved in any case of this nature
except the present case.

12. That the present case is a result of clear manipulation by the police.

13. That the accused from all accounts is an innocent person. It is therefore respectfully prayed that
the accused may kindly be released on bail during the pendency of this case.

APPLICANT

THROUGH

Dated : ................. ADVOCATE

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