Bail Petition For Ajay Chouhan 1

(Accused in Jail)
In Re.
The Court of the Addl. District and Session Judge –
IX Cum Spl. Judge P.O.C.S.O ACT Dhanbad.
SPL P.O.C.S.O Case No-140/2021
(Arising out of Tetulmari P.S case no. 31/21 and U/Ss 366(A),323,376
of I.P.C and 4/8 POCSO Act)
M.C.A N0- /2022
Ajay Chouhan ---- -------------------Petitioner
-Vrs-
State
Petition for Bail(Regular)
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The Humble Bail petition on behalf of the
Petitioner namely Ajay Kumar Chouhan s/o
Late Prahlad Chouhan R/o Tetulmari
Township, Tetulmari P.S.+P.O-Tetulmari
Dist.-Dhanbad.
Adhar No:2340 3301 8780
Mob.No:9308491241
Most Respectfully Sheweth:-
1. That the petitioner has been falsely made an accused in the above
noted case and petitioner has been arrested and in Jail since 08.09.2021
2. That the no regular Bail petition was filed on behalf of the petitioner
in your Honour’s court Or Hon’ble Jharkhand High court,Ranchi.
3. That the prosecution story as alleged by the informant namely Ranjit
Rawat father of the victim.As per his statement his girl aged about 16
years namely xxxxxxxx goes for Latrin at approx 8:30 P.M out side of
her home.But not returned at night .Both husband and wife searching at
night but she returned At next morning at 8.30 A.M and said Ajay
Kumar Chouhan forcefully kidnapped her and at unknown place he rape
me and threatened to face dare consequences if disclosed the incident to
any one.Ajay again threatened victims mother on her mobile.Hence this
case.
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Grounds
4. That F.I.R is against unknown and nothing incriminating has been
recovered from the position on of the petitioner and petitioner is in
custody since 14.06.2019.with out Charge -Frame.
5. That the name of the petitioner has come up from the confessional
statement of Co-accused and the alleged co-accused namely Raja Khan
got Anticipatory Bail from hon’ble Jharkhand high court and the another
co-accused namely Aashish Kumar vishwakarma got the regular bail.
6. That in police story a Motorcycle was used and deceased was carried
in Drum along with the two accused on same motorcycle is highly
improbable through very busy main road and no one noticed.
7. That the mother of petitioner ANWARI KHATOON wife of Late
Md.Jamil Shah is suffering from deadly disease of BRAIN CALCIFIED
GRANULOMA (A type of Brain Tumor)and under treatment but needs
better treatment & no one able to arrange financial support for that as
petitioner is the elder son and one son is minor(unemployed)along with
three minor daughter 1.Nikhat Praveen (15 years) 2).Sabana Praveen(12
years)3).Sabnam Praveen(07 years).
8. That the petitioner has no any criminal Antecedent.
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9. That the Charge Sheet submitted in your honour’s court so there is no
any chance to temper the evidence at all.
10. That the deceased was regular staff of International Lubricant and
was on duty to collect money but no any complain/information
submitted from company side till date created genuine doubt arises
present police story.
11. That the only CDR is not a substantial evidence as neither C.C.T.V
footage of road side of lodna More or any Ocular evidence submitted to
support the prosecution story.
12. That the petitioner is man of means having house and land within the
jurisdiction of this court and having good behavior in Jail and
cooperative in jail Authorities also.
13. That there is no chance of either absconding or tampering with the
prosecution evidence.As petitioner co-operate with police in
investigation.
14. That your petitioner is ready to furnish bail bound of any reasonable
amount or any term which the court thinks fit and proper in the
circumstances of the case.
15. That ,other and further grounds will be urged at the time of hearing.
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It is therefore prayed that your honour
may be graciously pleased to enlarge the
petitioner on Bail.
And for this your petitioner shall ever prayed.
The Court of the principal District and Session Judge –VIII Dhanbad.
B.P Case No /2021
I Tulsi Oraon s/o Late Somara Oraon by faith-Hindu, Aged about-63 years. By
occupation-business R/o-Chiragora,Hirapur P.S-Dhanbad P.O-Dhanbad Dist-Dhanbad-
826001.
I do hereby Solemnly affirm on oath and declare as follows:
1.That I am the Parvikar of the present case.
2. That I am aware of this case is read over me and explained in simple hindi and I found
correct as I believe and knowledge.
3. That the averment made above are true and best of my knowledge, faith and belief.
VERIFICATION
The statement made in above are true to best of my knowledge and

belief.I signed this verification at Dhanbad on 30.11.2021
DEPONENT
ADVOCATE
5|Page

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(Accused in Jail)

The Court of the Addl. District and Session Judge –

IX Cum Spl. Judge P.O.C.S.O ACT Dhanbad.

SPL P.O.C.S.O Case No-140/2021

of I.P.C and 4/8 POCSO Act)

M.C.A N0- /2022

Ajay Chouhan ---- -------------------Petitioner

Petition for Bail(Regular)

Petitioner namely Ajay Kumar Chouhan s/o

Late Prahlad Chouhan R/o Tetulmari

Township, Tetulmari P.S.+P.O-Tetulmari

Adhar No:2340 3301 8780

Most Respectfully Sheweth:-

in your Honour’s court Or Hon’ble Jharkhand High court,Ranchi.

3. That the prosecution story as alleged by the informant namely Ranjit

Kumar Chouhan forcefully kidnapped her and at unknown place he rape

me and threatened to face dare consequences if disclosed the incident to

any one.Ajay again threatened victims mother on her mobile.Hence this

4. That F.I.R is against unknown and nothing incriminating has been

recovered from the position on of the petitioner and petitioner is in

custody since 14.06.2019.with out Charge -Frame.

statement of Co-accused and the alleged co-accused namely Raja Khan

co-accused namely Aashish Kumar vishwakarma got the regular bail.

in Drum along with the two accused on same motorcycle is highly

improbable through very busy main road and no one noticed.

7. That the mother of petitioner ANWARI KHATOON wife of Late

Md.Jamil Shah is suffering from deadly disease of BRAIN CALCIFIED

GRANULOMA (A type of Brain Tumor)and under treatment but needs

petitioner is the elder son and one son is minor(unemployed)along with

three minor daughter 1.Nikhat Praveen (15 years) 2).Sabana Praveen(12

years)3).Sabnam Praveen(07 years).

8. That the petitioner has no any criminal Antecedent.

any chance to temper the evidence at all.

was on duty to collect money but no any complain/information

present police story.

footage of road side of lodna More or any Ocular evidence submitted to

support the prosecution story.

jurisdiction of this court and having good behavior in Jail and

cooperative in jail Authorities also.

13. That there is no chance of either absconding or tampering with the

prosecution evidence.As petitioner co-operate with police in

circumstances of the case.

may be graciously pleased to enlarge the

And for this your petitioner shall ever prayed.

B.P Case No /2021

I do hereby Solemnly affirm on oath and declare as follows:

1.That I am the Parvikar of the present case.

The statement made in above are true to best of my knowledge and

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