Pravin Dada 1
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IN THE COURT OF HON’BLE SESSIONS JUDGE RAIGAD, AT. ALIBAG. Cri. Misc. Application No.
/2008.
Kawaljeetsing Tirlochansing Gell Age : 22 years, Occupation – Business, Resident of Sai Nagar Co-operative, Housing Society, Room No. A-206, Sector No. 4, Kalamboli Colony, Taluka Panvel, District Raigad Versues The State of Maharashtra First Application for grant of Bail under Section 439 of Cr. P.C. in connection with Kalamboli, Navi Mumbai Police Station bearing C.R. No. I 420/2008 for the alleged offence under Section 407, 411, 34 of IPC
May It Please Your Honour : The above named Applicant most respectfully submit as under :That the complaint is lodged by one Mr. Indrakant Gulab Za who is manager of Kavita Goods Transport Company alleging that their company got tender of transporting the containers of Appar Industries to Uran. So complainant transport those containers from Silvasa to Uran, he engaged trailor of Geel Transport Company, Trailor No. HR 38/E-808 and container No MEBU2708429 from Silvasa to J.N.P.T. It is alleged that applicant with the help of one Mr. Vikas Chaudhari who is the cleaner and Ramesh who is the Driver on the said trailor make breach of trust by misappropriating goods of Rs. 2,50,000/- from the container. Pursuant to the above complaint the applicant was arrested on 03.10.2008 and he was remanded to P.C.R. till 05.10.2008 and now h is in MCR. Therefore the above named applicant most respectfully pray for grant of Bail on the following amongst other grounds :1.
That the applicant is innocent and has not committed any offence.
2.
That the applicant is no way concerned with this alleged offence.
3.
The name of the applicant is not at all mentioned in the F.I.R. as few days before this incident, there was a murder of colleague of this applicant and at that time he marched to the police station as the police have not arrested the accused, to take the revenge of that incidence, the police implicate this applicant falsely in this offence.
4.
The applicant is permanent resident of his address given in title clause.
5.
That the main co-accused in this offence was already released on bail by this Hon,ble Court in Criminal Misc. Application No.
/2008. Hence this applicant is also
entitled for bail on the ground of parity. 6.
The applicant is ready to co-operate with process of investigation and to ebide by any reasonable conditions that this Hon,able Court may impose.
7.
That nothing is to be recovered form the custody of the present applicant.
8.
That a false and concocted case has been filed against the present applicant.
9.
That the applicant has not committed any offence. He is innocent and law abiding citizen.
10.
That the alleged offence is not punishable with death or imprisonment for life.
11.
That the offence is exclusively triable by learned J.M.F.C.
12.
That the application for bail was given in the court of J.M.F.C. Panvel but the same was rejected as the offence is of serious nature ant property involved is huge.
13.
That no other application for grant of Bail is pending before this Hon’able Court or Hon’able High Court.
14.
That the charge sheet is not filed. It is therefore most respectfully prayed that the applicant may kindly be released on Bail
And concerned Police Station may be directed accordingly. And for which act of kindness, the applicant as in his duty bound shall ever pray.
Alibag Date :
/
/2008
Advocate for Applicant
/2008.
Kawaljeetsing Tirlochansing Gell Age : 22 years, Occupation – Business, Resident of Sai Nagar Co-operative, Housing Society, Room No. A-206, Sector No. 4, Kalamboli Colony, Taluka Panvel, District Raigad Versues The State of Maharashtra First Application for grant of Bail under Section 439 of Cr. P.C. in connection with Kalamboli, Navi Mumbai Police Station bearing C.R. No. I 420/2008 for the alleged offence under Section 407, 411, 34 of IPC
May It Please Your Honour : The above named Applicant most respectfully submit as under :That the complaint is lodged by one Mr. Indrakant Gulab Za who is manager of Kavita Goods Transport Company alleging that their company got tender of transporting the containers of Appar Industries to Uran. So complainant transport those containers from Silvasa to Uran, he engaged trailor of Geel Transport Company, Trailor No. HR 38/E-808 and container No MEBU2708429 from Silvasa to J.N.P.T. It is alleged that applicant with the help of one Mr. Vikas Chaudhari who is the cleaner and Ramesh who is the Driver on the said trailor make breach of trust by misappropriating goods of Rs. 2,50,000/- from the container. Pursuant to the above complaint the applicant was arrested on 03.10.2008 and he was remanded to P.C.R. till 05.10.2008 and now h is in MCR. Therefore the above named applicant most respectfully pray for grant of Bail on the following amongst other grounds :1.
That the applicant is innocent and has not committed any offence.
2.
That the applicant is no way concerned with this alleged offence.
3.
The name of the applicant is not at all mentioned in the F.I.R. as few days before this incident, there was a murder of colleague of this applicant and at that time he marched to the police station as the police have not arrested the accused, to take the revenge of that incidence, the police implicate this applicant falsely in this offence.
4.
The applicant is permanent resident of his address given in title clause.
5.
That the main co-accused in this offence was already released on bail by this Hon,ble Court in Criminal Misc. Application No.
/2008. Hence this applicant is also
entitled for bail on the ground of parity. 6.
The applicant is ready to co-operate with process of investigation and to ebide by any reasonable conditions that this Hon,able Court may impose.
7.
That nothing is to be recovered form the custody of the present applicant.
8.
That a false and concocted case has been filed against the present applicant.
9.
That the applicant has not committed any offence. He is innocent and law abiding citizen.
10.
That the alleged offence is not punishable with death or imprisonment for life.
11.
That the offence is exclusively triable by learned J.M.F.C.
12.
That the application for bail was given in the court of J.M.F.C. Panvel but the same was rejected as the offence is of serious nature ant property involved is huge.
13.
That no other application for grant of Bail is pending before this Hon’able Court or Hon’able High Court.
14.
That the charge sheet is not filed. It is therefore most respectfully prayed that the applicant may kindly be released on Bail
And concerned Police Station may be directed accordingly. And for which act of kindness, the applicant as in his duty bound shall ever pray.
Alibag Date :
/
/2008
Advocate for Applicant
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