ABA Bano Yadav

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IN THE COURT OF DISTRICT AND SESSION JUDGE ,
SAHARSA.
A.B.A. NO.:-......./2022
Ref: - arising out of Saharsa Sadar P.S. Case No.-
420/2011 dated 05/09/2011 instituted under sections
147,148,149,323,307,384,427,448,504,506 of I.P.C., sec
27of Arms Act and 3/4 Explosive Act and is pending in
the court of Learned A.C.J.M.- IV, Saharsa.
IN THE MATTER OF:
1. Bhanu Yadav alias Bano Yadav aged about
years
S/O- Late Budhan Yadav
Resident of Mohalla – Gokul Chowk,Ward No.-18,
Saharsa, P.S. – Sadar Saharsa, Dist.-Saharsa.
...........Petitioners
Vs.
THE STATE OF BIHAR .............O.P.
The humble anticipatory
bail application on
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behalf of above named
petitioner under section
438 of Cr.P.C. (as
amended)
MOST RESPECTFULLY SHEWETH:
1. That this is application for grant of anticipatory bail
to the petitioner who apprehends his arrest in connection
with Saharsa Sadar P.S. Case no.- 420/2011 under
sections 147,148,149,323,307,384,427,448,504,506 of
I.P.C., sec 27of Arms Act and 3/4 Explosive Act and is
pending in the court of Learned A.C.J.M.- IV, Saharsa.
2. That the petitioners have not preferred such an
application for regular bail or anticipatory bail earlier
either before this court or The Hon'ble Patna High
Court.
3. That the petitioners have no criminal antecedents.
4. That the prosecution story, in brief that the informant
Rajan Kumar Singh is alleging that on 05/09/2011 about
05:35 P.M., he along with his friends was at the office
of Anand Mohan and in the meantime Golu Yadav with

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his hundred supporters reached there and threaten then
he was asked why have they threaten then they have
caught Md. Mahmood Ali Kaisar and he has escaped
from and Golu Yadav have fired and through bomb in
the office hata come and also alleged that Golu Yadav
has demanded extortion from the information.On the
basic of written statement Saharsa P.S. case no
420/2011 had been registered under sections
147,148,149,323,307,384,427,448,504,506 of I.P.C., sec
27 of Arms Act and 3/4 Explosive Act and is pending in
the court of Learned A.C.J.M.- IV, Saharsa.
Certified copy of F.I.R is
annexed with this
petition.
5. That the petitioner is quite innocent and has
committed no offence much less the offence alleged in
the F.I.R.
6. That the petitioner has been falsely implicated in
this case due to grudge, dirty party politics which is
prevailing in side of village.

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7. That the F.I.R. is malicious, false, fabricated,
concocted and has no leg to stand in the eye of law.
8. That there is no specific allegation against the
petitioner, but they are general and omnibus.
9. That the alleged sections of the F.I.R. are bailable
except sections 307,384 of IPC and sec. 27 Arms Act
and 3 /4 Explosive Act and is not applicable against the
petitioners and are super addition and ornamental and
add only with an intention to make the offence non-
bailable and graver and no alleged offence are made
out against the petitioners.
10. That there is no any injury has been sustained to
the person of the informant and other by this petitioner
and no any articles had been recovered from the
possession of the petitioner. The prosecution version as
alleged in the written statement of the informant, there
is no any intention for attempt to murder and extortion
by the petitioner. Hence intention is not clearly
mentioned in the written statement. So the sec. 307 and
384 IPC had not attracted in the present case.

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11. That the petitioner is law abiding, God Fearing and
having fullest faith in the rule of Law.
12. That the petitioner shall suffer irreparable loss and
injury to his goodwill, health and mental peace, if the
police arrest the petitioner in the false case filed against
him.
13. That the petitioner is not a previous convict and
the petitioner is permanent resident of Saharsa at the
above noted address and is having his roots in society.
There is no chance of petitioner tempering the evidence
or threatening the witness or to flee/abscond from
justice, if released on anticipatory bail.
14. That the petitioner is man of means having wealth
and home and are therefore not likely to abscond and
tempering or evading with the evidence if enlarge on
anticipatory bail.
15. That the petitioner is ready to furnish sound
sureties to the full satisfaction of the court and willing
to abide by your Honour for his enlargement on
anticipatory bail.
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16. That the application of anticipatory bail has made
bonafide and in the interest of justice.
17. That there are other grounds also which will be
raised at the time of hearing of bail application by
your honour's permission.
It is , therefore, prayed that your
honour may graciously be pleased to
grant anticipatory bail to the
petitioner in Saharsa Sadar P.S. case
no. 420/2011 to the satisfaction of
Learned A.C.J.M.- IV,Saharsa.
AND/OR
Pass such order(s) as Your Honour
may deem fit and proper.
And for this petitioner shall ever pray.
Petitioner,
Through advocate.

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IN THE COURT OF DISTRICT AND SESSION JUDGE ,
SAHARSA.
A.B.A. NO.:-......./2022
In the matter of:
Bhanu Yadav @ Bano Yadav Vs. The State of Bihar
AFFIDAVIT
I, Bhanu Yadav alias Bano Yadav aged about

years S/O- Late Budhan Yadav , resident of Mohalla-
Gokul Chowk Ward No.- 18, Saharsa, P.S.– Sadar,
Dist.– Saharsa do hereby and solemnly affirm and state
as follows:
1. That I am the Petitioner and also well acquainted
with this facts and circumstances of the case.
2. That I am competent to swear this affidavit.
3. That I am gone through the contents of the bail
petition bearing above case no. and heard translate into
Hindi and have understood the same.
4. That the statements made in the application are
true to the best of my knowledge and based on
information derived from the records of the case,
which I believe to be true.

Deponent.

ABA Bano Yadav

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IN THE COURT OF DISTRICT AND SESSION JUDGE ,

Ref: - arising out of Saharsa Sadar P.S. Case No.-

420/2011 dated 05/09/2011 instituted under sections

147,148,149,323,307,384,427,448,504,506 of I.P.C., sec

27of Arms Act and 3/4 Explosive Act and is pending in

the court of Learned A.C.J.M.- IV, Saharsa.

IN THE MATTER OF:

1. Bhanu Yadav alias Bano Yadav aged about

S/O- Late Budhan Yadav

Resident of Mohalla – Gokul Chowk,Ward No.-18,

Saharsa, P.S. – Sadar Saharsa, Dist.-Saharsa.

THE STATE OF BIHAR .............O.P.

The humble anticipatory

behalf of above named

petitioner under section

438 of Cr.P.C. (as

MOST RESPECTFULLY SHEWETH:

1. That this is application for grant of anticipatory bail

to the petitioner who apprehends his arrest in connection

with Saharsa Sadar P.S. Case no.- 420/2011 under

pending in the court of Learned A.C.J.M.- IV, Saharsa.

2. That the petitioners have not preferred such an

application for regular bail or anticipatory bail earlier

either before this court or The Hon'ble Patna High

3. That the petitioners have no criminal antecedents.

4. That the prosecution story, in brief that the informant

Rajan Kumar Singh is alleging that on 05/09/2011 about

05:35 P.M., he along with his friends was at the office

of Anand Mohan and in the meantime Golu Yadav with

his hundred supporters reached there and threaten then

he was asked why have they threaten then they have

caught Md. Mahmood Ali Kaisar and he has escaped

from and Golu Yadav have fired and through bomb in

has demanded extortion from the information.On the

basic of written statement Saharsa P.S. case no

420/2011 had been registered under sections

147,148,149,323,307,384,427,448,504,506 of I.P.C., sec

27 of Arms Act and 3/4 Explosive Act and is pending in

the court of Learned A.C.J.M.- IV, Saharsa.

Certified copy of F.I.R is

annexed with this

5. That the petitioner is quite innocent and has

committed no offence much less the offence alleged in

6. That the petitioner has been falsely implicated in

this case due to grudge, dirty party politics which is

prevailing in side of village.

7. That the F.I.R. is malicious, false, fabricated,

concocted and has no leg to stand in the eye of law.

8. That there is no specific allegation against the

petitioner, but they are general and omnibus.

9. That the alleged sections of the F.I.R. are bailable

except sections 307,384 of IPC and sec. 27 Arms Act

and 3 /4 Explosive Act and is not applicable against the

petitioners and are super addition and ornamental and

add only with an intention to make the offence non-

bailable and graver and no alleged offence are made

out against the petitioners.

10. That there is no any injury has been sustained to

the person of the informant and other by this petitioner