APPLICATION FOR BAIL U/s. 437 OF Cr. P.C.  BEFORE METROPOLITAN MAGISTRATE’S

IN THE COURT OF METROPOLITAN MAGISTRATE’S 

26th COURT AT BORIVALI, MUMBAI

C. R. NO.  : ……………./2006

 

                                     DATE OF ARREST: 23/01/2007

                           R. A. DATED: 24/01/2007

 

STATE {KANDIVALI {W.} POLICE STATION} ……… Complainant

                       V/s

 

ISLAM ALI ABDUL HAMID KHAN ……..… Accused

 

Charge U/s: - 193, 196, 465, 468, 471 of IPC.

 

APPLICATION FOR BAIL U/s. 437 OF Cr. P.C.                                 

 

MAY IT PLEASE YOUR WORSHIP

 

It is most humbly and respectfully prayed and submitted by and on behalf of the  accused above named that he be ordered to be released on bail inter-alia on the following grounds:- 

 

  1. The accused has been thoroughly interrogated by the police since the day of arrest, and now no enquiries remain to be made, and no useful purpose will be served by keeping the accused in custody, as the alleged forged document has been recovered.
  2. Co-accused have been granted bail of Rs. 5000/- by this Hon’ble Court on 16/10/2006, 20th Dec. 2006, 28th December, 2006 and 11th January, 2007. Other accused have been granted bail of Rs. 10000/- with 1 or 2 sureties by the Honorable Sessions Court.     
  3. The accused has no adverse antecedents to his discredit to disentitle him bail. The accused hails from respectable family. He is permanent resident of Hindustan Naka, Charkop, Kandivali (West), Mumbai. 
  4. The accused undertake to abide by such terms and conditions that this Honorable Court may impose upon him while granting bail and he will face the trial. The alleged offences U/s. 193, 196, 465 are non cognizable, section 471                                              of IPC is bailable whereas sec. 468 of IPC is non-bailable, and the punishment prescribed is up to 7 years imprisonment.
  5. The accused is not likely to abscond, as he has firm roots in Mumbai. 
  6. The accused is gainfully employed. 
  7. The accused undertake not to hamper the police investigation and / or tamper with the prosecution witnesses, and shall attend the police station, if released on bail, and the accused shall co-operate with the police investigation, and abide by such terms and conditions that this Honorable Court may order.
  8. None of the alleged offences are punishable with life imprisonment                   or death. 
  9. This is first application for bail. No other application has been moved &/or pending before this honorable Court and/ or any other Court.
  10. Hence, the accused be ordered to be released on bail on such terms and conditions this Honorable Court may deem fit.

In the alternative cash security be allowed.

And for this Act of kindness the accused shall for ever pray.

 

…………………….., APPLICANT

  {ADVOCATE FOR ACCUSED}

Date: 24/01/ 2007.                                   

MUMBAI.

      

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