IN THE COURT OF LEARNED SESSIONS JUDGE: PANCHKULA.

Devender Pal s/o Sh. Lajja Ram, age about 33 years R/o

Village Badona Kalan, District Panchkula

---Petitioner

Versus

State of Haryana.
---Respondent

F.I.R. No. 152 Dated: 05.12.2018, Under Section: 395, 397,

Police Station: Raipur Rani, District Panchkula.

First Petition under Section 438 Cr.P.C. for the

grant of anticipatory bail.

Sir,

The petitioner respectfully submit as under: -

1. That the petitioner is a permanent resident of

Village Badona Kalan, District Panchkula and is law

abiding citizen.

2. That brief facts of present anticipatory application

are that complainant namely Bhajan Lal s/o Sh.

Surjit Singh in connivance with police of P.S.

Raipurani is unnecessary harassing the petitioner.

On dated 05.12.2018, complainant lodged one FIR

against Goldy R/O Kheri, Santy R/O Garhi, Binu R/O

Garhi, Deba R/O Badona & Nisar R/O Garhi and other

unknown persons with the allegations that all these

 persons while carrying swords, Iron rods & rods came

at the Dhaba of complainant and committed and rob

Rs.20,000/- which complainant brought from his

tractor company and also gave beatings with their

respective weapons and also cause harm to the scooty

and Canter standing there. It is further alleged

that when the complainant went for conducting MLR

than the aforesaid accused again came there and

caused injuries to their worker and one Sukhbir and

broke down the scooty and canter. Thereafter,

petitioner has received call from P.S Raipurani that

one F.I.R has been registered against you by Bhajan

lal and further asked petitioner to come present P.S

Raipurani. That again petitioner received

threatening calls from P.S Raipurani.

3. That as a matter of fact the complainant and Goldy

was having some dispute and earlier matter was

settled between them. The petitioner was neither

named in the FIR nor any specific allegations are

there against the petitioner. The petitioner on

inquiry came to know that the complainant in

connivance with police is trying to implicate in the

matter on the pretext of one named mentioned in FIR

as Deba R/O Badona.

4. That now on the false allegation of the complainant

police in connivance is unnecessary putting pressure

upon the petitioner to come present in the police

 station. That petitioner has apprehension that

complainant in connivance with local police can

arrest him and can implicate petitioner in false

case.

5. That the petitioner neither called by this name

since his birth nor he is resident of Village Badona

as he is resident of Village Badona Kalan. It is

necessary to submit here that the Village Badona &

Badona Kalan are two separate Villages in District

Panchkula. The complainant has lodged the present

false and fabricated F.I.R by levelling false

allegation in connivance with police of Raipurani

police station.

6. That on the evening of 03.02.2019 some police

officials of Police Station-Raipurani came at the

residence of the petitioner in his absence and

wanted to arrest the petitioner in the above said

F.I.R. which has been recorded on false and

frivolous complaint. However, the said police

official had not disclosed about the details of the

F.I.R

7. That no recovery is to be effected from the

petitioner nor the petitioner is required for any

investigation or interrogation. It is necessary to

submit here that the petitioner on inquiry came to

know that alleged recovery of Rs.20,000/- was

 already been effected from the co-accused Goldy and

injuries suffered are simple in nature which clearly

creates doubt in complainant version.

8. That the petitioner is ready to join the

investigation and undertake to abide by all the

terms and conditions that may be imposed upon them

and further undertake not to abuse the concession of

bail.

9. That no offence whatsoever has been committed by the

petitioner and the complainant has filed false and

frivolous complaint in order to humiliate the

petitioner and further to extort money from the

petitioner.

10. That the petitioner is local resident and ready to

furnish the bail bonds/surety bonds to the entire

satisfaction of this Hon’ble Court/Ilaqa

Magistrate/Duty Magistrate/Chief Judicial

Magistrate, Panchkula.

11. That the petitioner has not filed such type of bail

application either in the court of Sessions Judge,

Panchkula or before the Hon’ble High Court of Punjab

& Haryana at Chandigarh.

12. That it is a fit case where the concession of

anticipatory bail can be granted to the petitioner.

 It is, therefore, prayed that the

present petition may kindly be accepted and necessary

directions may kindly be issued to the S.H.O., Police

Station Raipurani, Panchkula/Arresting Officer/

Investigating Officer Ilaqa Magistrate/Duty

Magistrate/Chief Judicial Magistrate, Panchkula to

release the petitioner on bail in the event of their

arrest.

And

It is further prayed that till the decision

of petition, the interim bail may be granted to the

petitioner.

Place: Panchkula
Dated:
Devender Pal s/o Sh. Lajja Ram R/o
Village Badona Kalan, Panchkula

Petitioner

Through Counsel:

SANDEEP SHARMA, Advocate

District Courts, Panchkula
IN THE COURT OF LEARNED SESSIONS JUDGE: PANCHKULA.
---

Devender Pal
- --Petitioner
Versus

State of Haryana.
---Respondent

In Re: First Petition under Section 438 Cr.P.C.

for grant of anticipatory bail
---

AFFIDAVIT

I, Devender Pal s/o Sh. Lajja Ram, age about 33 years

R/o Village Badona Kalan, District Panchkula do hereby
solemnly affirm and declare as under:-

1.That the deponent has read over and understood the

contents of the accompanied petition under section 438

Cr.P.C. The same are true and correct. The contents of the

accompanied petition may be read as part and parcel of this

affidavit.

2.That the deponent has not filed any such or similar

petition in the present case either before the Hon’ble Court

or before the Hon’ble Punjab and Haryana High Court at

Chandigarh and for the first time the above titled petition

is being filed by the deponent.

Place: Panchkula DEPONENT

Dated:
Verification:

Verified that the contents of the above affidavit are

true and correct to the best of my knowledge and belief and

nothing has been concealed therein. No part of it is false.

Place: Panchkula
Dated: DEPONENT

IN THE COURT OF LEARNED SESSIONS JUDGE: PANCHKULA.

---

Devender Pal
- --Petitioner
Versus

State of Haryana.
---Respondent
F.I.R. No. 152 Dated: 05.12.2018, Under Section: 395, 397,
Police Station: Raipur Rani, District Panchkula.

First Petition under Section 438 Cr.P.C. for grant of

anticipatory bail
---

INDEX

Place: Panchkula
Dated:

---Petitioner
Through Counsel:

SANDEEP SHARMA, Advocate

District Courts, Panchkula