Bail Petition before a Magistrate during Police Enquiry under sec 437, CrPC

Bail Petition before a Magistrate during Police Enquiry under sec 437, CrPC

In the Court of Bombay
……………………….The State
versus
………………………Accused AB son of TZ, Village: Thana
In the matter of petition for bail of accused AB, during police enquiry
The humble petition of AB the accused above-named
MOST RESPECTFULLY SHEWETH:

1. That your petitioner was arrested by the police on 5th March 2010 on mere suspicion. That
   nearly a month has passed after the arrest but still the Investigating Police Officer has not
   submitted a charge-sheet.
2. That your petitioner was not identified by any inmate of the house of CM where the burglary is
   alleged to have taken place, nor was any incriminating article found in his house.
3. That your petitioner has reason to believe that one GS with whom your petitioner is on bad
   terms and who is looking after the case for the complainant has falsely implicated your petitioner
   in the case out of grudge.
4. That your petitioner shall fully co-operate with the police.
5. That your petitioner is not likely to abscond or leave the country.

Prayer

Your petitioner prays that your Honour may be pleased to call for police papers and after
perusing the same be pleased to direct the release of your petitioner on bail.
And your petitioner, as in duty bound, shall ever pray.
Advocate
AB

Verification

I, AB, son of TZ, residing at………..by occupation business, do hereby solemnly affirm and say
as follows:

1. I am the petitioner above-named. I know and I have made myself acquainted with the facts
   and circumstances of the case and I am able to depose thereto.
2. The statements in paragraphs 1 to 5 of the foregoing petition are true and correct to my
   knowledge and belief.
3. I sign this verification on the 6th day of May 2010.
   Solemnly affirmed by the said AB
   on 6th May 2010 at the Court
   House at……………….AB
   Before me Notary/Magistrate.