Template-BailPetitionlyst1599

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IN THE COURT OF THE LD. SESSIONS JUDGE, PQRST ,HYDERABAD IN THE MATTER OF: Prashant PQR ............... ACCUSED Age:54 years, Occ. Professor 34, Mahaveer Road, Samasti Nagar,Panchal Village ,Warangal ,Hyderabad AND Mahesh PQR..........ACCUSED Age:53 years, Occ Buisnessman 33,Mahaveer Road, Samasti Nagar,Panchal Village, Warangal,Hyderabad -VERSUS- STATE OF TELANGNA ............. PETITIONER BAIL APPLICATION NO.______/2016 IN CRIMINAL CASE NO. .... OF 2022.... P.S. ............. P.S. No. ..../2016 Under Sec.300, 307 IPC An application under Sec. 439 of Code of Criminal Procedure, 1973, prayer for the release of Accused ,Prashant PQR on bail. The humble Petition on behalf of the above named Respondent. MOST RESPECTFULLY SHOWETH :- Prashant PQR ("Accused No. 1" )respondent in the present case has been arrested by the police and has been charged of murdering two people. Accused No. is a Professor at XYZ 1
College,Warangal currently living in Panchal Village, Warangal, Hyderabad. Respondent's wife Prashanti Devi, residing at : 34, Mahaveer Road, Samasti Nagar,Panchal Village ,Warangal ,Hyderabad is filing this bail application on behalf of Accused No.1 who is her husband. Factual Background 1. Accused No.1 approaches this Hon'ble court with the prayer that this Hon'ble Court may be pleased to exercised its jurisdiction under the section 438 of the Cr.P.C and this Hon'ble Court may be pleased to release Accused No.1 on bail on any suitable terms and conditions , as this Hon'ble Court may deem fit and proper, in the event of his arrest in connection with the Hawaldar West Police Station C.R No.222/2022 registered under Section 300 and 307 of the IPC . Facts are as follows: 2. A 25-year-old boy named Ramesh fell in love with Swathi, a 24 year old girl. Both were living in Hyderabad. They both wanted to get married. Ramesh was a Dalit and Swathi belonged to a Brahmin family, due to which the families were against their marriage. 3. However, on 08.04.2015 the couple got married against their parent's wishes and escaped the confines of their small town of Warangal, to Hyderabad. 4. Several years later, they were better off financially and living in a better place. On 23 rd December 2015 Swathi called her parents to share the joy. On the very next day, her father (Mahesh, also accused of murdering) and Accused No. 1. visited them in Hyderabad in an apparent reconciliation. 5. While they were having a conversation, Swathi's father(Mahesh) took out a gun and shot both of them on the left part of their chests , leaving them dead on the spot. Police of the Hawaldar Police Station arrested her father and Accused 1. On 11th Jan 2016 after the neighbours (who were living 3 blocks away from the place of the incident) filed an FIR( a copy of which is attached with this application) on 31 st Dec 2015 against them. Legal Submissions: 1. That the Accused No.1 is innocent and is falsely implicated in the alleged offence. The Accused wasn't aware of Mahesh's(who performed the actual crime and who accompanied Accused No.1 ) intentions , otherwise, he wouldn't have accompanied 2
him to Hyderabad. Neither, till now, there hasn't been any solid evidence found of the Accused killing any of the two persons. 2. That assuming the allegations made by the prosecution true for the sake of argument, the incident eoccuoured in such situation that it can be seen that there was neither any motive nor intention to kill the complainant and as such the present Accused (No.1) cannot said to have committed an offence punishable under section 300 and 307 of the IPC. 3. That the Accused No.1 is the only earning member of his family and if he remained in jail, then every member of the family would get into a survival crisis. The Accused does not have past criminal record( no such evidences could be found against him) and their family has an excellent reputation in their village. 4. Accused No.1 is suffering from a very rare disease. This disease can be cured only in XYZ hospital, which is in Delhi, and no other hospital has special equipment and means to cure this disease. 5. That taking in to consideration the totality of the circumstance by no stretch of imagination it can be said that Accused No.1 can be held guilty of the offence punishable u/s 300 or 307 of the I.P.C. 6. Accused No.1 undertakes that he will not either directly or indirectly make any inducements, threats or promises to any person who is a witness in the case so as to dissuade them from disclosing such facts to the Hon'ble Court or to any other investigative authority or tamper with or destroy any evidence. 7. It is humbly submitted that Accused No.1 is a permanent resident of the aforesaid locality and has deep roots in society and that there is no chance of his absconding or evading trial. 8. It is further submitted that Accused No.1 will abide by any condition imposed on her by this Hon'ble Court and undertakes to present himself before the Court as and when directed. 9. Accused No.1 is ready and willing to furnish adequate surety in case of her bail and has been granted bail on .............. on one surety of Rs. 20,000/-. 3
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