IN THE COURT OF SH. G.P.SINGH, A.C.M.

M :
DELHI.

IN RE: -

STATE VS. PRAVEEN KUMAR AHUJA

S/o Shri Sita

Ram Ahuja
R/o; B-452,Gali No . 5
Majlis Park
Delhi 110033

FIR NO.
U/S.
P.S.

2nd APPLICATION FOR BAIL UNDER SECTION 437 OF

Cr.P.C.MOVED ON BEHALF OF THE APPLICANT
SH.PRAVIN KUMAR AHUJA

RESPECTFULLY SHOWETH: -

1. That the applicant/accused above noted has been falsely

implicated in the above said case and the accused/applicant
has past clean antecedent and has never been involved in
any criminal case whatsoever and has never been convicted
by any Court of law.

2. That the accused / applicant is a law-abiding citizen and is

an income tax payee belonging to a respectable family and
earns his livelihood in a lawful manner and is maintaining
his wife and minor children who are completely dependent
upon the accused/applicant and there is no one to look after
his wife and the minor children apart from the
accused/applicant himself.

3. That the applicant/ accused is an innocent person and has

nothing to do with the commission of present offence as
alleged by the prosecution.
4. That the applicant / accused are the bonafide purchasers of
the Shop No. 2,4,6,8&10 situated at A-1, Kewal Park
Extension, Delhi and the said property was purchased from
Sh. Manohar Lal Sethi and Smt Raj Sethi vide Registered
Sale Deed executed and registered on 2.12.2005 before the
office of sub –Registrar, PitamPura, Delhi And the
photocopy of the said sale deed is filed herewith as
ANNEXURE A/1.

5. That even otherwise there are two civil suits pending

adjudication one in the Court of Sh. Sanjeev Kr Singh ,
Civil Judge , Delhi titled as Kuldeep Chand Bedi and ors Vs
Smt . Raj Sethi and ors in which the present Accused/
applicant is Defendant no 3 and has already filed his W.S
and the matter is now fixed for 27.05.2006, and the second
case is titled as Sh .Manjeet Singh and Ors. Vs Sh .
Manohar Lal Sethi and Ors. in which the present
accused/applicant has already moved an application under
Order 1 Rule 10 ,C.P.C and the matter is pending before
the Court of Sh. Manish Gupta , Civil Judge , Delhi.

6. That even otherwise the question as to title of a property

can only be decided by a Civil Court and in the instant case
there is no dispute regarding title of the property and this
case has only been framed at the instructions of some of
unscrupulous elements with a view to extort money from
the present accused/applicant.

7. That even otherwise the accused / applicant is a law abiding

citizen and is not shying from joining investigations before
any agency and this fact can also be ascertained by the fact
that the accused / applicant who was called by the ACP,
Vigilance, Sh . Gurdeep Singh at Asaf Ali Road had already
appeared before him and has replied all the questions put
forth by him and apart from him the accused/applicant has
also appeared before the D.I.U.(North West District)
whenever asked to appear and even in the instant case it
was the accused / applicant who went to the office of the
Crime Cell with the entire documents relating to the
property and where even after seeing the entire file of
property documents the Police arrested the accused/
applicant, which was not at all required

8. That nothing incriminating has been recovered from the

possession of the accused person or at his instance and the
police has falsely implicated the present accused person and
even the police have not verified the truth of the
complainant’s version.
 9. That the bare reading of the FIR does not make out any case
against the accused person who have never been involved in
any criminal antecedents whatsoever.

10.That the petitioner/applicant has past clean antecedent and

has never been convicted by any Court of law.

11.That the accused is not required for any investigation

whatsoever by the police officials and no purpose would be
served if the accused is not released on Bail and the 1 st
application was dismissed in default on 8.05.06

12.That the accused undertakes to join the investigation as and

when directed to do so and further undertakes to comply
each and every direction of this Hon’ble Court.

13.That the accused undertakes neither to tamper with the

evidence nor to hamper any witness if released on Bail.

PRAYER
In the facts and circumstances above mentioned, it
is, therefore, most respectfully prayed that the
accused may be ordered to be released on Bail in the
interest of justice.

APPLICANT/A
CCUSED

DELHI.
DATED: ____________
THROUGH;

(R.K. TARUN & ASSOCIATES)

ADVOCATE
S
 IN THE COURT OF ADDITIONAL SESSIONS
JUDGE: DELHI.

IN RE: -

STATE VS. PRAVEEN KUMAR AHUJA

S/o Shri Sita Ram Ahuja
R/o; B-452,Gali No . 5
Majlis Park
Delhi 110033

FIR NO.101/06
U/S. 448/380 I.P.C.

P.S. Adarsh Nagar, Delhi.

Date of arrest: 3.5.2006.

Sent to J.C on : 08/05/06

APPLICATION FOR BAIL UNDER SECTION 439 OF

Cr.P.C. MOVED ON BEHALF OF THE APPLICANT
SH.PRAVIN KUMAR AHUJA

RESPECTFULLY SHOWETH: -

1. That the applicant/accused above noted has been falsely

implicated in the above said case and the accused/applicant
has past clean antecedent and has never been involved in
any criminal case whatsoever and has never been convicted
by any Court of law.

2. That the accused / applicant is a law-abiding citizen and is

an income tax payee belonging to a respectable family and
earns his livelihood in a lawful manner and is maintaining
his wife and minor children who are completely dependent
upon the accused/applicant and there is no one to look after
 his wife and the minor children apart from the
accused/applicant himself.

3. That the applicant/ accused is an innocent person and has

nothing to do with the commission of present offence as
alleged by the prosecution.

4. That the applicant / accused is the bonafide purchaser of the

Shop No. 2,4,6,8 &10 situated at A-1, Kewal Park
Extension, Delhi and the said property was purchased from
Sh. Manohar Lal Sethi and Smt Raj Sethi vide Registered
Sale Deed executed and registered on 2.12.2005 before the
office of sub –Registrar, PitamPura, Delhi And the
photocopy of the said sale deed is filed herewith as
ANNEXURE A/1.

5. That even otherwise there are two civil suits pending

adjudication one in the Court of Sh. Sanjeev Kr Singh, Civil
Judge, Delhi titled as Kuldeep Chand Bedi and ors Vs Smt.
Raj Sethi and ors in which the present Accused/ applicant is
Defendant no 3 and has already filed his W.S and the matter
is now fixed for 27.05.2006, and the second case is titled as
Sh .Manjeet Singh and Ors. Vs Sh . Manohar Lal Sethi and
Ors. in which the present accused/applicant has already
moved an application under Order 1 Rule 10 ,C.P.C and
the matter is pending before the Court of Sh. Manish Gupta,
Civil Judge , Delhi.

6. That even otherwise the question as to title of a property

can only be decided by a Civil Court and in the instant case
there is no dispute regarding title of the property and this
case has only been framed at the instructions of some of
unscrupulous elements with a view to extort money from
the present accused/applicant.
7. That even otherwise the accused / applicant is a law abiding
citizen and is not shying from joining investigations before
any agency and this fact can also be ascertained by the fact
that the accused / applicant who was called by the ACP,
Vigilance, Sh . Gurdeep Singh at Asaf Ali Road had already
appeared before him and has replied all the questions put
forth by him and apart from him the accused/applicant has
also appeared before the D.I.U.(North West District)
whenever asked to appear and even in the instant case it
was the accused / applicant who went to the office of the
Crime Cell with the entire documents relating to the
property and where even after seeing the entire file of
property documents the Police arrested the accused/
applicant, which was not at all required

8. That nothing incriminating has been recovered from the

possession of the accused person or at his instance rather
one compressor which was alleged to be stolen was
recovered at the instance of the complainant only and the
police has falsely implicated the present accused person and
even the police have not verified the truth of the
complainant’s version, and moreover the complainant has
not described the so called stolen articles anywhere in his
complaint dated 23.2.2006 and the copy of the said FIR is
annexed at Annexure A-2.

9. That the bare reading of the above mentioned FIRs does not
make out any case against the accused person who have
never been involved in any criminal case whatsoever, and
moreover in the FIR No. 101/06 the complainant says that
he was informed by his servant Vijay Kumar that the above
named accused was there on 11.2.2006 but the said Vijay
Kumar in his complaint dated 11.2.2006 does not mention
 the name of the present applicant and the copy of the said
FIR No.83/2006 is Annexed as ANNEXURE A-3 and this
very fact falsifies the very truth of the complainant’s
version.

10.That the petitioner/applicant has past clean antecedent and

has never been convicted by any Court of law and a co
accused Smt Raj Sethi who was also named in the FIR has
already been given a clean chit by the police.

11.That the accused/applicant is in custody since 3.5.2006 and

is not required for any investigation whatsoever by the
police officials and no purpose would be served if the
accused is not released on Bail and the Ld. A.C.M.M. was
pleased to dismiss the bail application of the
accused/applicant on 10.5.2006.

12.That the accused/applicant undertakes to join the

investigation as and when directed to do so and further
undertakes to comply each and every direction of this
Hon’ble Court.

13.That the accused/applicant undertakes neither to tamper

with the evidence nor to hamper any witness if released on
Bail.

PRAYER
In the facts and circumstances above mentioned, it
is, therefore, most respectfully prayed that the
accused/applicant may be ordered to be released on
Bail in the interest of justice.
 APPLICANT/A
CCUSED

DELHI.
DATED: ____________
Through,

(R.K. TARUN & ASSOCIATES)

ADVOCATES
 IN THE COURT OF ADDITIONAL SESSIONS
JUDGE : DELHI.

IN RE: -

STATE VS. PRAVEEN KUMAR AHUJA

S/o Shri Sita Ram Ahuja
R/o; B-452,Gali No . 5
Majlis Park
Delhi 110033

FIR NO. 255/06

U/S. 448/511/506/34 I.P.C.

P.S. Adarsh Nagar, Delhi.

Date of arrest: 3.5.2006.

Sent to J.C on : 08/05/06

APPLICATION FOR BAIL UNDER SECTION 439 OF

Cr.P.C.MOVED ON BEHALF OF THE APPLICANT
SH.PRAVIN KUMAR AHUJA

RESPECTFULLY SHOWETH: -

1. That the applicant/accused above noted has been falsely

arrested in the above said case on 03/05/06 and was sent to
police remand till 08/05/06 and then to J.C though the
accused/applicant has never been involved in any criminal
case whatsoever and has never been convicted by any Court
of law and the copy of the F.I.R is annexed as
ANNEXURE A-1.

2. That the other co-accused who has also been attributed the
same role by the prosecution has already been granted bail
 by this Hon’ble Court and the true typed copy of the bail
order of the co-accused are annexed as ANNEXURE -A-2.

3. That the accused / applicant is a law-abiding citizen and is

an income tax payee belonging to a respectable family and
earns his livelihood in a lawful manner and is maintaining
his wife and minor children who are completely dependent
upon the accused/applicant and there is no one to look after
his wife and the minor children apart from the
accused/applicant himself.

4. That the applicant/ accused is an innocent person and has

nothing to do with the commission of present offence as
alleged by the prosecution and even otherwise his name
does not find any mention in the said F.I.R.

5. That the applicant is the bonafide purchaser of the Shop No.

2,4,6,8 &10 situated at A-1, Kewal Park Extension, Delhi
and the said property was purchased from Sh. Manohar Lal
Sethi and Smt Raj Sethi vide Registered Sale Deed
executed and registered on 2.12.2005 before the office of
sub–Registrar, PitamPura, Delhi And the photocopy of the
said sale deed is filed as ANNEXURE A-3.

6. That even otherwise there are two civil suits pending

adjudication one in the Court of Sh. Sanjeev Kr Singh,
Civil Judge, Delhi titled as Kuldeep Chand Bedi and ors Vs
Smt. Raj Sethi and ors in which the present Accused/
applicant is Defendant no 3 and has already filed his W.S
and the matter is now fixed for 27.05.2006, and the second
case is titled as Sh .Manjeet Singh and Ors. Vs Sh .
Manohar Lal Sethi and Ors. in which the present
accused/applicant has already moved an application under
 Order 1 Rule 10 ,C.P.C and the matter is pending before
the Court of Sh. Manish Gupta , Civil Judge , Delhi.

7. That even otherwise the question as to title of a property

can only be decided by a Civil Court and in the instant case
there is no dispute regarding title of the property and this
case has only been framed at the instructions of some of
unscrupulous elements with a view to extort money from
the present accused/applicant.

8. That even otherwise the accused / applicant is a law abiding

citizen and is not shying from joining investigations before
any agency and this fact can also be ascertained by the fact
that the accused / applicant who was called by the ACP,
Vigilance, Sh . Gurdeep Singh at Asaf Ali Road had already
appeared before him and has replied all the questions put
forth by him and apart from him the accused/applicant has
also appeared before the D.I.U.(North West District)
whenever asked to appear and even in the instant case it
was the accused / applicant who went to the office of the
Crime Cell with the entire documents relating to the
property and where even after seeing the entire file of
property documents the Police arrested the accused/
applicant, which was not at all required

9. That nothing incriminating has been recovered from the

possession of the accused person or at his instance rather
one compressor which was alleged to be stolen was
recovered at the instance of the complainant only and the
police has falsely implicated the present accused person and
even the police have not verified the truth of the
complainant’s version, and moreover the complainant has
not described the so called stolen articles anywhere in his
 complaint dated 23.2.2006 and the copy of the said FIR is
annexed at Annexure A-4.

10.That the bare reading of the above mentioned FIRs does not
make out any case against the accused person who have
never been involved in any criminal case whatsoever, and
moreover in the FIR No. 101/06 the complainant says that
he was informed by his servant Vijay Kumar that the above
named accused was there on 11.2.2006 but the said Vijay
Kumar in his complaint dated 11.2.2006 does not mention
the name of the present applicant and the copy of the said
FIR No.83/2006 is Annexed as ANNEXURE A-5 and this
very fact falsifies the very truth of the complainant’s
version.

11.That the petitioner/applicant has past clean antecedent and

has never been convicted by any Court of law and a co
accused Smt Raj Sethi who was also named in the FIR has
already been given a clean chit by the police.

12.That the accused/applicant is in custody since 3.5.2006 and

is not required for any investigation whatsoever by the
police officials and no purpose would be served if the
accused is not released on Bail and the Ld. A.C.M.M. was
pleased to dismiss the bail application of the
accused/applicant on 12.5.2006 and thereafter one bail
application was dismissed in default on 15.5.2006.

13.That the accused/applicant undertakes to join the

investigation as and when directed to do so and further
undertakes to comply with each and every direction of this
Hon’ble Court.
 14.That the accused/applicant undertakes neither to tamper
with the evidence nor to hamper any witness if released on
Bail.

PRAYER
In the facts and circumstances above mentioned, it
is, therefore, most respectfully prayed that the
accused/applicant may be ordered to be released on
Bail in the interest of justice.

APPLICANT/A
CCUSED

DELHI.
DATED: ____________
Through,

(R.K. TARUN & ASSOCIATES)

ADVOCATE
S

IN THE COURT OF ADDITIONAL SESSIONS

JUDGE : DELHI.

IN RE: -
STATE VS. PRAVEEN KUMAR AHUJA
S/o Shri Sita Ram Ahuja
R/o; B-452,Gali No . 5
Majlis Park
Delhi 110033

FIR NO. 83/06

U/S. 506/34 I.P.C.

P.S. Adarsh Nagar, Delhi.

Date of arrest: 3.5.2006.

Sent to J.C on : 08/05/06

APPLICATION FOR BAIL UNDER SECTION 439 OF

Cr.P.C.MOVED ON BEHALF OF THE APPLICANT
SH.PRAVIN KUMAR AHUJA

RESPECTFULLY SHOWETH: -

1. That the applicant/accused above noted has been falsely

arrested in the above said case on 03/05/06 and was sent to
police remand till 08/05/06 and then to J.C though the
accused/applicant has never been involved in any criminal
case whatsoever and has never been convicted by any Court
of law and the copy of the above said F.I.R is annexed as
ANNEXURE A-1.

2. That the accused / applicant is a law-abiding citizen and is

an income tax payee belonging to a respectable family and
earns his livelihood in a lawful manner and is maintaining
his wife and minor children who are completely dependent
upon the accused/applicant and there is no one to look after
his wife and the minor children apart from the
accused/applicant himself.
3. That the applicant/ accused is an innocent person and has
nothing to do with the commission of present offence as
alleged by the prosecution and even otherwise his name
does not find any mention in the said F.I.R.

4. That the applicant / accused is the bonafide purchaser of the

Shop No. 2,4,6,8 &10 situated at A-1, Kewal Park
Extension, Delhi and the said property was purchased from
Sh. Manohar Lal Sethi and Smt Raj Sethi vide Registered
Sale Deed executed and registered on 2.12.2005 before the
office of sub –Registrar, PitamPura, Delhi And the
photocopy of the said sale deed is filed herewith as
ANNEXURE A/2.

5. That even otherwise there are two civil suits pending

adjudication one in the Court of Sh. Sanjeev Kr Singh,
Civil Judge, Delhi titled as Kuldeep Chand Bedi and ors Vs
Smt. Raj Sethi and ors in which the present Accused/
applicant is Defendant no 3 and has already filed his W.S
and the matter is now fixed for 27.05.2006, and the second
case is titled as Sh .Manjeet Singh and Ors. Vs Sh .
Manohar Lal Sethi and Ors. in which the present
accused/applicant has already moved an application under
Order 1 Rule 10 ,C.P.C and the matter is pending before
the Court of Sh. Manish Gupta , Civil Judge , Delhi.

6. That even otherwise the question as to title of a property

can only be decided by a Civil Court and in the instant case
there is no dispute regarding title of the property and this
case has only been framed at the instructions of some of
unscrupulous elements with a view to extort money from
the present accused/applicant.
7. That even otherwise the accused / applicant is a law abiding
citizen and is not shying from joining investigations before
any agency and this fact can also be ascertained by the fact
that the accused / applicant who was called by the ACP,
Vigilance, Sh . Gurdeep Singh at Asaf Ali Road had already
appeared before him and has replied all the questions put
forth by him and apart from him the accused/applicant has
also appeared before the D.I.U.(North West District)
whenever asked to appear and even in the instant case it
was the accused / applicant who went to the office of the
Crime Cell with the entire documents relating to the
property and where even after seeing the entire file of
property documents the Police arrested the accused/
applicant, which was not at all required

8. That nothing incriminating has been recovered from the

possession of the accused person or at his instance rather
one compressor which was alleged to be stolen was
recovered at the instance of the complainant only and the
police has falsely implicated the present accused person and
even the police have not verified the truth of the
complainant’s version, and moreover the complainant has
not described the so called stolen articles anywhere in his
complaint dated 23.2.2006 and the copy of the said FIR is
annexed at Annexure A-3.

9. That the bare reading of the above mentioned FIR does not
make out any case against the accused person who have
never been involved in any criminal case whatsoever, and
moreover in the FIR No. 101/06 the complainant says that
he was informed by his servant Vijay Kumar that the above
named accused was there on 11.2.2006 but the said Vijay
Kumar in his complaint dated 11.2.2006 does not mention
 the name of the present applicant and the copy of the said
FIR No.83/2006 is Annexed as ANNEXURE A-4 and this
very fact falsifies the very truth of the complainant’s
version.

10.That the petitioner/applicant has past clean antecedent and

has never been convicted by any Court of law and a co
accused Smt Raj Sethi who was also named in the FIR has
already been given a clean chit by the police.

11.That the accused/applicant is in custody since 3.5.2006 and

is not required for any investigation whatsoever by the
police officials and no purpose would be served if the
accused is not released on Bail and the Ld. A.C.M.M. was
pleased to dismiss the bail application of the
accused/applicant on 12.5.2006.

12.That the accused/applicant undertakes to join the

investigation as and when directed to do so and further
undertakes to comply with each and every direction of this
Hon’ble Court.

13.That the accused/applicant undertakes neither to tamper

with the evidence nor to hamper any witness if released on
Bail.

PRAYER
In the facts and circumstances above mentioned, it
is, therefore, most respectfully prayed that the
accused/applicant may be ordered to be released on
Bail in the interest of justice.
 APPLICANT/A
CCUSED

DELHI.
DATED: ____________
Through,

(R.K. TARUN & ASSOCIATES)

ADVOCATE
S

TRUE TYPED COPY OF BAIL ORDER DATED 19.5.2006

State Vs. A.K. Aggarwal.

FIR NO. 255/2006

U/S 448/506/511/34 IPC.

P.S. Adarsh Nagar.

19.05.2006.

Present : Shri R.S.Yadav, APP for the state along with IO

ASI Rajbir.

Counsel Shri C.L. Gupta for the applicant/accused.

Complainant is also present.

 This is an application for bail of above-mentioned

applicant. The applicant is stated to be a property dealer. The

dispute arose between landlord and a tenant as the landlord of

some property is stated to have sold the said property to some

buyer with the active agency of the partner of the applicant. The

incident pertained to 2.12.2005 for which the present FIR was

registered after a gap of about five months.

The complainant present in the court submits that in

addition to take forcible possession of the shop, certain tyres etc.

were also alleged to have been stolen.

On a querry from the court the IO replied that neither the

forcible possession of the shop was taken on 2.12.2005 and

neither any articles were stolen. However, the forcible possession

of the shop was attempted to be taken later on for which FIR has

been registered. He has further clarified that in the present FIR,

attempts to take forcible possession was made by the landlord and

buyers. As per IO though the name of the applicant has also

figured in the FIR.

Since the FIR was registered after a gap of about five

months and further since there was only an attempt to take

forcible possession of the shop which is supplemented with

criminal intimidation, as such I find that there are no serious

allegations against the present applicant who happens to be the

property dealer. Neither any specific role has been assigned to the

present application in the said FIR. He is not stated to be

beneficiary to the deal. He has stated to have no interest except

his commission in transaction, if any. The applicant is in judicial

custody since 3.5.2006.

Keeping in view the facts and circumstances of the case and

taking into account the role assigned to him by the prosecution, no

useful purpose will be served by keeping the accused more in

judicial custody pending trial. Hence accused is admitted to bail

on his furnishing a personal bond in the sum of Rs.10,000/- with

one surety of the like amount to the satisfaction of the concerned

MM/Duty Magistrate.

Sd/-

A. S. J. /DELHI.
 It is submitted that the above-mentioned accused has

been arrested in case F.I.R. No.72/05

U/s.395/34/120-B/412 I.P.C. and presently in J.C.

On 03.02.2005 Vishwakarma Chain Gold shop was looted

at gunpoint by four young man and they decamped with gold

jewellery worth Rs.12,00,000/-. The case was registered and

during the course of investigation it was revealed that Ram Singh

and Prem planned to loot the jewellery shop, so that they can live

comfortably. As both were planning to loot a huge amount of

gold, they wanted a person who could give them information

about the market of gold. They both used GOPAL and assigned

the job of identification of a suitable target. Who identified the

shop of the complainant Vishwakarma Chain Gold, as he knew

them. On 03.02.2005 all the gang members collected in a room at

41, Beadon Pura, Karol Bagh, and Gopal was sent to check the

movement at Vishwakarma Chain Gold shop. After getting

clearance from Gopal, the plan was executed and Gold jewellery

worth Rs.12,00,000/- were looted and a gold jewellery of 55 g was

given to Gopal by Ram Singh as booty, which has been recovered

from the shop at his instance.

Sir, total 9 accused have been arrested in this case and four

accused are still absconding. It is therefore requested that Bail of

the accused may not be granted please.

SI/IO

TRUE TYPED COPY OF THE BAIL ORDER DT.

18.02.2005 PASSED BY SH. S.M. CHOPRA: A.S.J.;
DELHI.

State VERSUS Sachin Verma @ Ashu.

F.I.R. No.72/05.
U/s. 394/395/412/120-B/34 I.P.C.
P.S. Karol Bagh.

18.02.2005

Present: Sh. Suresh Tomar, Counsel for the applicant.

Sh. R.S. Yadav, Add. P.P. for the state with
S.I. Baljeet Singh, I.O. of the case.

Heard. The allegations against the accused is that, he is a part of

conspiracy in regard to the offence as reported by Swaroop Santra in
respect of which, later on the statement of Gopi was also recorded. In
so far as this applicant is concerned at his instance a part of the
jewellery as per memo DT. 10.02.2005 was recovered. Looking into
the alleged circumstances of the case, date of arrest and stage of
investigation of the case, the applicant is admitted to bail on his
furnishing a personal bond in the sum of Rs.10,000/- with one surety of
the like amount to the satisfaction of the concerned Court.

Sd/-
(S.M. CHOPRA)
A.S.J.:
DELHI

IN THE COURT OF DISTT. & SESSIONS JUDGE: DELHI

IN RE: -

STATE VS SH. VIVEK

KUMAR
S/o Sh. Suresh
Chandra
R/o B-45 Lohia
Nagar,
Ghaziabad (U.P)

F.I.R NO.: 566/05

U/s.
420/468/471 I.P.C. P.S.:
I.P. ESTATE (DIU Darya Ganj).

2ND APPLICATION FOR THE GRANT OF

ANTICIPATORY BAIL UNDER SECTION 438 Cr.P.C.
MOVED ON BEHALF OF APPLICANT.

Respectfully Showeth: -

1. That the Police of P.S. I.P. Estate have registered the

captioned false and frivolous case vide F.I.R No: 566/05
against the applicant/accused which is annexed as
ANNEXURE P/1 and the applicant/accused has been
 served with a notice U/S 160 Cr.P.C from P.S. I.P.Estate
and is apprehending his arrest in the same.

2. That the Petitioner passed MBBS from Moscow and

then applied to Medical Council for Registration, and
MCI made a complaint to the Police that in support of
the application for Registration, the applicant had
annexed his Degree of MD (Physician) and the same
was sent for Verification and the M.C.I. was informed
that the same is forged.

3. That the document alleged to be forged i.e., MD

(Physician) degree along with other documents are not
verified in the manner as the Police has not even got it
verified from the concerned Dean of the Foreign
students , Russian State Medical University , Moscow
and even otherwise the applicant is ready and willing to
deposit the alleged document with any authority as
desired by this Hon’ble Court.

4. That the Police has nowhere alleged that the applicant

was not a student of Russian State Medical University
and even the passport authenticates the same that the
applicant was in Russia since 1993 and even the Dean of
Foreign students has issued various certificates of
excellence in respect of the applicant which are annexed
as ANNEXURE –P/2, P/3, & P/4.

5. That the applicant/accused has shown his original

Certificates Genuine to the best of his knowledge for
registration with Medical Council of India, being
qualified for the same as per the Schedules to the Indian
Medical Council Act, 1956.
6. That the captioned case is totally based on documentary
evidence only and custodial interrogation of the
applicant/accused is not required.

7. That there are more than 100 FIRs lodged by MCI

against the persons who had obtained MD Physician
Degree from Moscow and in most of the cases the MCI
has not properly verified the documents from the
concerned Dean of Foreign students, Russian State
Medical University.

8. That the case bearing F.I.R. No.313/04, 314/2004,

187/2002, 197/2002 and 196/2005 and also in many
other cases of the similar nature the accused persons
have already been granted an anticipatory bail, to whom
the prosecution has attributed the same role and the copy
of the Bail orders are annexed as ANNEXURE- P/5
(COLLY) hence in the present case also, the
accused/applicant deserves the bail atleast on the ground
of parity.

9. That the applicant/accused undertakes to participate in

the investigation as and when directed by this Hon’ble
Court before any Agency, and the first application was
dismissed on 29.03.06 when counsel for the applicant
did not appear before this Hon’ble court.

10. That the applicant/accused is a young qualified person

and has laboriously pursued his career as a Doctor and
has a bright future ahead.

11. That the applicant/accused has clean past antecedents.

 12. That the applicant/accused is a permanent resident of
U.P, and undertakes not to hamper the witness or tamper
with the evidence, if granted anticipatory Bail.

It is, therefore, most respectfully

prayed that this Hon’ble Court may kindly be pleased to direct the
S.H.O./I.O. to release the applicant on Bail forthwith in the event
of his arrest, in the interest of justice.

DELHI.
DATED: _________________

APPLICANT/ACCUSED
Through

(R.K. TARUN)
ADVOCATE
TRUE TYPED COPY OF THE BAIL ORDER DATED
14.07.2005, PASSED BY SH. B.B. CHAUDHARY, A.S.J,
DELHI

IN THE COURT OF SH. B.B CHAUDHARY, A.S.J, DELHI.

STATE Vs. Dr. GAURAV RAI

F.I.R No.: - 314/04
P.S. IP ESTATE (DIU Darya Ganj)
U/s 420/468/471 IPC

14.07.2005

Present: - Ms. Sindhu Vishwakarma, Counsel for the Applicant

Dr. Gaurav Rai

Sh. R.K. PANDEY, APP for state

Heard the prosecution has admitted that the Original

degree of MD (Physician) has been deposited with the
I.O of the case. Since the document, said to be forged is
already with the police, therefore the applicant is
allowed.

In case of arrest of the applicant, he be admitted to bail

on his furnishing personal bond in the sum of Rs.
10,000/- with one surety of the like amount to the
satisfaction of the concerned I.O/SHO. The applicant
shall, however, join the investigation as and when called
by the I.O.

Sd/-
B.B.
CHAUDHARY
ASJ, Delhi
 IN THE HIGH COURT OF DELHI, AT NEW DELHI

BAIL APPLICATION NO:____________OF 2006

IN RE

SH. SANJAY Kr. CHAUBEY

S/o Sh. Ram Ashish Chaubey

R/o B-45 Lohia Nagar,

Ghaziabad (U.P)

…………….APPLICANT

VERSUS

STATE ……………..RESPONDENT

F.I.R NO.: 196/05

 U/s.

420/468/471 I.P.C. P.S.:

I.P. ESTATE

(DIU. Darya Ganj).

APPLICATION FOR THE GRANT OF ANTICIPATORY

BAIL UNDER SECTION 438 READ WITH SECTION 482

Cr.P.C. MOVED ON BEHALF OF APPLICANT.

Respectfully Showeth: -

1. That the Police of P.S: I.P. Estate have registered the

captioned false and frivolous case against the applicant/accused

and the Copy of the F.I.R No. 196/05 is annexed as

ANNEXURE A-1, and true typed copy of the F.I.R. is annexed

as ANNEXURE A-2.

2. That the Applicant passed MBBS from Moscow and then

applied to Medical Council for Registration, and MCI made a

complaint to the Police that in support of the application for

Registration, the applicant had annexed his Degree of MD

(Physician) and the same was sent for Verification and the

M.C.I. was informed that the same is forged.

3. That the document alleged to be forged i.e., MD (Physician)

degree along with other documents are already deposited with

the Investigating officer and the same has been verified also by

the I.O.

4. That the applicant/accused has submitted his original

Certificate Genuine to the best of his knowledge for registration

with Medical Council of India, being qualified for the same as

per the Schedules to the Indian Medical Council Act, 1956.

5. That even otherwise the captioned case is totally based on

documentary evidence only and custodial interrogation of the

applicant/accused is not required.

6. That the case bearing F.I.R. No.313/04, 314/2004, 187/2002

and 197/2002 and also in many other cases of the similar nature

the accused persons have already been granted an anticipatory

bail, to whom the prosecution has attributed the same role and

the copy of the Bail order is annexed as ANNEXURE A-3,

hence in the present case also, the accused/applicant deserves

the bail atleast on the ground of parity.

 7. That the applicant/accused undertakes to participate in the

investigation as and when directed by this Hon’ble Court before

any Agency as he has done in the past.

8. That the applicant/accused is a young qualified person and

has laboriously pursued his career as a Doctor and has a bright

future ahead.

9. That the applicant/accused further undertakes not to hamper

the witness or tamper with the evidence, if granted anticipatory

Bail.

10. That the applicant/accused has filed Anticipatory Bail

Application before Hon’ble Sessions Court, Delhi, and the

same has been dismissed as withdrawn before the Hon’ble

Sessions Court on 07.10.2005 and again an application was

made and was dismissed in default for non-appearance on

02.02.2006 and the true typed copies of the same are annexed

as ANNEXURE A-4 and ANNEXRE A-5 respectively.

It is, therefore, most respectfully prayed that this Hon’ble Court

may kindly be pleased to direct the S.H.O./I.O. to release the

applicant on Bail forthwith in the event of his arrest, or atleast 15

days prior notice of arrest be given to the applicant before

effecting his arrest, in the interest of justice.

DELHI.

DATED: _________________

APPLICANT/ACCUSED

Through

(R.K.

TARUN

ADVO

CATE
TRUE TYPED COPY OF THE BAIL ORDER DATED

14.07.2005, PASSED BY SH. B.B. CHAUDHARY, A.S.J,

DELHI

IN THE COURT OF SH. B.B CHAUDHARY, A.S.J, DELHI.

STATE Vs. Dr. GAURAV RAI

F.I.R No.: - 314/04

P.S. IP ESTATE (DIU Darya Ganj)

U/s 420/468/471 IPC

14.07.2005

Present: - Ms. Sindhu Vishwakarma, Counsel for the Applicant

Dr. Gaurav Rai

Sh. R.K. PANDEY, APP for state

Heard the prosecution has admitted that the Original

degree of MD (Physician) has been deposited with the

I.O of the case. Since the document, said to be forged is

already with the police, therefore the applicant is

allowed.

In case of arrest of the applicant, he be admitted to bail

on his furnishing personal bond in the sum of Rs.

10,000/- with one surety of the like amount to the

satisfaction of the concerned I.O/SHO. The applicant

shall, however, join the investigation as and when called

by the I.O.
 Sd/-

B.B.

CHAUDHARY

ASJ, Delhi

IN THE HIGH COURT OF DELHI AT NEW DELHI

BAIL APPLICATION NO:__________OF 2006

IN RE: -

SH. SANJAY Kr. CHAUBEY

VERSUS

STATE

MEMO OF THE PARTIES

SH. SANJAY Kr. CHAUBEY

S/o Sh. Ram Ashish Chaubey

R/o B-45 Lohia Nagar,

Ghaziabad (U.P) …………….APPLICANT

VERSUS

STATE ………………RESPONDENT
DELHI

DATED_________

R.K.TARUN

COUNSEL FOR

THE APPLICANT

IN THE HIGH COURT OF DELHI AT NEW DELHI

BAIL APPLICATION NO:__________OF 2006

IN RE: -
SH. SANJAY Kr. CHAUBEY

VERSUS

STATE

AFFIDAVIT

Affidavit of Sh. Sanjay Kumar Chaubey S/o Sh. Ram Kumar

Chaubey, R/O B-45, Lohia Nagar, Gaziabad,(U.P),

I above named deponent do here by solemnly affirm and declare

as under:
1. That I am the applicant in the above noted case and as such

well conversant with the facts of the case and can depose to the

same.

2.That the accompanying bail application has been drafted under

my instruction and the contents of the same may be read as part

and parcel of this affidavit and the same are not being repeated

here for the sake of brevity.

DEPONENT

VERIFICATION

Verified at Delhi on this ______ day of _____________, that the

contents of the above affidavit are true and correct to my

knowledge and no part of it is false therein and nothing has been

concealed therefrom.

DEPONENT

NOTICE OF MOTION

IN THE HIGH COURT OF DELHI AT NEW DELHI

NO……………………………

Shri____________________________
Advocate.

IN THE MATTER OF: -

_____________________________________________Petitioner
/Plaintiff.
VERSUS

___________________________________________Defendant/
Respondent

Sir,

The enclosed application in the aforesaid matter as

being filed on behalf the _________________ and is likely to be

___________________ or any date, thereafter. Please take

notice accordingly.

NEW DELHI.

THROUGH
DATE:

ADVOCATE

ENCLOSED COPY OF APPLICATION

TRUE TYPED COPY OF THE F.I.R. NO. 196/05.

P.S.—I.P. ESTATE

DISTT.—CENTRAL
UNDER SECTIOS—420/468/471 OF I.P.C.

M.C.I.201(58)2002 Regn. 1735 15.02.2005 The Deputy

commissioner of Police Crime Police HQ. I.P.Estate New Delhi

110002.

Subject lodging of a F.I.R.

Sir,

The Medical Council Of India which is an autonomous body

established under the Act known as Indian Medical Council Act,

1956. is functioning under the administrative control of the

Ministry of Health & Family Welfare. Besides its important

function of maintenance of standard of Medical education in the

country and one of its function amongst others is to provide

registration to the individuals who qualify as a doctor from the

recognized institutions in India and abroad, the qualification of

which are included in the schedules to the Indian Council Act,

1956. As a matter of policy, documents submitted by such

candidates are subject to verification by concerned issuing

authorities. Accordingly a copy of degree issued in respect of Mr.

Sanjay Kumar Chaubey was sent for verification to the Embassy

of India, Moscow and on receipt of verification it is noted that

Diploma DIS 1100095 & Registration No: 179 has never been

issued to Shri Sanjay Kumar Chaubey and it is totally forged &

fake. Since the candidate Mr. Sanjay Kumar Chaubey has

submitted false /forged document, it has been decided to lodge a

F.I.R. with the law enforcing authorities. I am therefore directed to

request you to lodge formal FIR and take necessary immediate

action as provided under the IPC under intimation to this council.

Your co-operation in the matter and early is solicited. With

regards, yours sincerely Jagtar Singh, Asst. Secretary, Medical

Council of India. Address of the candidate Mr. Sanjay Kumar

Chaubey, B-45, Lohia Nagar, Ghaziabad, U.P. 1001 to the duty

officer Police Station, I.P. Estate please register a case U/s

420,468,471 IPC the investigation be in trusted to me Rukka send

through HC Dalbir Singh 120 7/c DIU/C Date & time of

occurrence

NOT KNOWN. Place of occurrence MCI Office Kotla Delhi.

Date & time sending Rukka 27.04.2005 at 3 pm Sd English Ganga

Sahai Insp DI/509 PIS NO-16770018 DIU/C

Sd/-
 IN THE HIGH COURT OF DELHI AT NEW DELHI

BAIL APPLICATION NO:__________OF 2006

IN RE: -

SH. SANJAY Kr. CHAUBEY

VERSUS

STATE

INDEX OF PAPERS

S.No. Particulars Page No. C.F.S.

1. Urgent Application

2. Memo of Parties

3. Application U/s 438 Cr.P.C.

4. Affidavit in support of above

5. Annexure-A-1: Copy of the

F.I.R.

6. Annexure-A-2: True typed copy

of the F.I.R.

7 Annexure-A-3: True typed copy

of the order dt.14.07.2005.

8. Annexure-A-4: True typed copy

of the order dt. 07.10.2005.

9. Annexure-A-5: True typed copy

of the order dt. 02.02.2006.

10. Application U/s 482 of Cr.P.C.

for exemption from filing

Certified copy of Annexures

along with Affidavit.

11. Notice of motion

12. Vakalatnama

Delhi

Dated: ________, 2006

R.K.Tarun,
Advocate for the
Applicant
 IN THE HIGH COURT OF DELHI AT NEW DELHI

BAIL APPLICATION NO:__________OF 2006.

IN RE: -

SH. SANJAY Kr. CHAUBEY

VERSUS

STATE

URGENT APPLICATION

RESPECTFULLY SHOWETH:-

Kindly treat the accompanying application as urgent.

The ground of urgency is that the police officials are

 harassing the applicant continuously directions are

sought for the notice of arrest from this Hon’ble.

Delhi

Dated : _________ 2006.

R.K.TARUN,
Advocate
(COUNSEL FOR THE
APPLICANT)

IN THE HIGH COURT OF DELHI AT NEW DELHI

BAIL APPLICATION. No._________ of 2006

IN THE MATTER OF: -

Shri Sanjay Kumar Chaubey ………...

Petitioner

Versus
The State ……

Respondent

APPLICATION ON BEHALF OF THE PETITIONER

UNDER SECTION 482 OF THE CODE OF CRIMINAL
PROCEDURE FOR EXEMPTION FROM FILING THE
CERTIFIED COPIES OF ANNEXURES ALONGWITH
THE ACCOMPANYING BAIL APPLICATION.

MOST RESPECTFULLY SHOWETH: -

1. That the petitioner has filed an accompanying Bail

Application under section 438 of the Code of Criminal

Procedure, a F.I.R. bearing No.196 of 2005, under

sections 420/468/471 of the Indian Penal Code,

registered by the police officials of P.S:- I. P. Estate,

Delhi, against the applicant, earlier bail applications

arising out of the same F.I.R, were dismissed by the

Sessions Courts, Delhi, and thereby this application is

before this Hon’ble court.

2. That the contents of the said Bail Application may

kindly be read as part and parcel of the present

application, as well as the same are not being repeated

herein for the sake of brevity.

 3. That the petitioner is filing the accompanying Bail

Application on the basis of true typed copies of

Annexures which pertain to the records of the Ld. Courts

below, as the certified copies of the same are not made

available to the petitioner herein by the Copying agency;

however, the petitioner has already applied for the

certified copies of the same and undertake to file the

same later on as and when the same would be made

available to the petitioner herein by the Copying

Agency. Moreover, the typed copies of Annexures are

the true copies of their respective originals.

PRAYER: -

In view of the aforesaid facts and circumstances, it is,

therefore, most respectfully prayed that this Hon’ble court may be

pleased to pass necessary orders in favour of the petitioner

whereby the petitioner may kindly be exempted from filing the

certified copies of Annexures alongwith the accompanying Bail

Application, in the interest of justice

Such other or further order as this Hon’ble Court may deem

fit and proper in the facts and circumstances of the present case be

also passed in favour of the petitioner to meet the ends of justice.

Delhi.

Dated: _________/2006.

PETITIONER

Through

(R.K. Tarun)
Advocate

TRUE TYPED COPY OF ORDER DATED 02.02.2006

State versus Sanjay Kumar Chaubey

F.I.R. 196/05

U/S 420/468/471 IPC

P.S I.P. ESTATE

Present –Ld. APP for the state

None for the acussed/applicant.

Since none has appeared on behalf of the accused/applicant,

application is dismissed in default.

S.N.Dhingra

ASJ/DELHI/02.02.06

TRUE TYPED COPY OF ORDER DATED 07.10.2005

Sanjay kumar chaubey

F.I.R NOT KNOWN

U/S NOT KNOWN

P.S DARYA GANJ

Present—APP for the state along with Inspector Ganga Sahai

Sh. P. C. Joshi, counsel for the applicant.

Learned counsel for the applicant seeks permission to

withdraw the bail application . Allowed. The bail application

is dismissed as withdrawn. Copy of the order be given to the

IO OF the case.

Rajnish Bhatnager

ASJ.
 IN THE HIGH COURT OF DELHI AT NEW DELHI

BAIL APPLICATION NO:__________OF 2006

IN RE: -

SH. SANJAY Kr. CHAUBEY

VERSUS

STATE

AFFIDAVIT

Affidavit of Sh. Sanjay Kumar Chaubey S/o Sh. Ram Kumar

Chaubey, R/O B-45, Lohia Nagar, Gaziabad, (U.P),

I above named deponent do here by solemnly affirm and declare

as under:

1. That I am the applicant in the above noted case and as such well

conversant with the facts of the case and can depose to the same.

2. That the accompanying application u/s 482 of Cr.P.C. has been

drafted under my instruction and the contents of the same may be

read as part and parcel of this affidavit and the same are not being

repeated here for the sake of brevity.

DEPONENT

VERIFICATION
Verified at Delhi on this ______ day of _____________, that the

contents of the above affidavit are true and correct to my

knowledge and no part of it is false therein and nothing has been

concealed therefrom.

DEPONENT
 IN THE COURT OF ADDITIONAL SESSIONS
JUDGE : DELHI.

IN RE: -

STATE VS. NEELAM BUDHIRAJA

W/O: -SH. SURINDER BUDDHIRAJA

R/o; C-584, Gali No .7

Majlis Park
Delhi 110033

FIR NO. 255/06

U/S. 448/511/506/34 I.P.C.

P.S. Adarsh Nagar, Delhi.

APPLICATION FOR BAIL UNDER SECTION 438 OF

Cr.P.C.MOVED ON BEHALF OF THE APPLICANT
Smt.NEELAM BUDHIRAJA.

RESPECTFULLY SHOWETH: -

1. That the applicant / accused is a lady of repute and is also

an income tax payee and commands respect in the entire
locality and she is falsely implicated in a false case vide
FIR NO. 255/2006 and the copy of the said FIR is annexed
as Annexure A-1

2. That the applicant is also involved in services for the

upliftment of weaker sections of the society and has also
been awarded various awards for her social activities by
various social groups.
3. That the applicant/accused is a peace loving and law
abiding citizen of India and has a clean past and is looking
after her children and is fully devoted for the cause of the
entire society.

4. That the applicant/accused has came to know that some of

the anti social elements who are scared of her popularity in
the locality are trying to implicate her in some false and
frivolous case and of late she was informed that one false
FIR has been registered against her at the behest of some
fictitious person, who never made any complaint against her
and this complaint is made against the applicant/accused
just to defame her so that her image could be maligned.

5. That the applicant/accused has neither been named in the

FIR above mentioned nor there is any allegation against the
applicant/accused and therefore in the absence of any
allegation against the applicant/accused the FIR above
noted needs no consideration.

6. That the applicant/accused undertakes to participate in the

investigation as and when directed by this Hon’ble Court
before any agency.

7. That the applicant/accused is a lady of repute and is also a

social worker and is an asset for the society.

8. That the applicant/accused has clean passed antecedents.

9. That the applicant/accused is a permanent resident of Delhi

and undertakes not to hamper the witness or tamper with the
evidence, if granted anticipatory bail.
 It is, therefore, most
respectfully prayed in the facts circumstances above mentioned
most respectfully prayed that this Hon’ble Court may be
pleased to direct the S.H.O/I.O to release the applicant on bail
forthwith in the event of her arrest, in the interest of justice of
justice.

DELHI.
DATED APPLICANT
Through

R.K.TARUN
Advocate
STATE Vs MANOHAR LAL SETHI.
FIR NO.101/06
PS Adarsh Nagar
U/S 448/380/34 IPC
14.6.06

PRESENT. Ms. Alka Goel. APP for state with I.O of the case.
Counsel for the accused/applicant.

Counsel for the accused/applicant states that the dispute is

between the landlord and tenant and civil suits are pending
between the parties. He has already sold the shops on 2.12.05
because he has to marry his daughter. The dispute is of civil
nature. Accused is a senior citizen aged 65 Years.
Under the facts and circumstances of the case the
applicant/accused is admitted to bail in the event of his arrest
on his furnishing a personal bond in the sum of Rs.10000/-.
With one surety of the like amount to the satisfaction of the
I.O/arresting officer /S.H.O concerned. However, he is directed
to join the investigation as and when directed by the I.O to join
the investigation as and when directed by the I.O to do so.
Dasti.

D.K.Malhotra
ASJ/Rohini/14.06.06
STATE Vs. 1.MANOHAR LAL SETHI 2.Smt. Raj sethi
FIR NO.255/06
PS Adarsh Nagar
U/S 448/ 511/506/34 IPC
14.6.06
Present. Ms. Alka Goel, APP For the state with I.O of the
case.
Counsel for both the accused/applicants.

Counsel for the accused/applicant states that the dispute is

between the landlord and tenant and civil suits are pending
between the parties. They have already sold the shops on
2.12.05 because they have to marry his daughter. The dispute
is of civil nature. Accused are senior citizens being in the age
group of 65and 62Years.

Under the facts and circumstances of the case, the

applicant/accused are admitted to bail in the event of their
arrest on their furnishing a personal bond in the sum of
Rs.10000/- each with one surety of the like amount to the
satisfaction of I.O/arresting officer/S.H.O concerned. However,
they are directed to join the investigation as and when directed
by the I.O to join the investigation as and when directed by the
I.O to do so. Dasti.

D.K.Malhotra
ASJ/Rohini/14.06.06