Arms Act Bail Gopal@Kaku 2024 Bail Application

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IN THE COURT OF MS. TANVI KHURANA LD.

CJM, SOUTH
SAKET COURT, NEW DELHI

IN THE MATTER OF:


State Vs Gopal@Kaku
FIR No. 465/2024
U/s 25/54/59 Arms Act
P.S. Ambedkar Nagar
DOA: 08.09.2024
APPLICATION U/S 480 BNSS FOR GRANT OF REGULAR BAIL ON
BEHALF OF THE APPLICANT/ACCUSED GOPAL@KAKU IN CASE FIR
NO. 465/2024 REGISTERED AT POLICE STATION AMBEDKAR NAGAR,
DELHI UNDER SECTION 25/54/59 ARMS ACT.

MOST RESPECTFULLY SHOWETH:-

1. That the applicant is the accused in the abovementioned case which is pending
before this Hon’ble Court for adjudication.
2. That the applicant is not involved in the present case in any manner and the
applicant/accused has been falsely implicated in the present case by the IO of this
case and he was lifted from his house.
3. That the applicant is neither required for any kind of investigation as the alleged
recovery has been already made by the IO and the applicant/accused is in judicial
custody since the date of arrest i.e. 08.09.2024.
4. That the applicant/accused undertakes not to misuse the concession of bail if
granted to him in any manner whatsoever; He further undertakes to appear before
the trial court on each and every date of hearing.
5. That the Hon’ble Supreme Court in State of Rajasthan, Jaipur v. Balchand @
Baliay, 1977 AIR 2447 has held that ‘the basic rule is bail, not jail’. There is no
circumstance suggestive of fleeing from justice or thwarting the course of justice
or creating other troubles in the shape of repeating offences or intimidating
witnesses.
6. That it is settled law that the applicant/accused is presumed to be innocent till
proven guilty and bail not jail is the essence of criminal jurisprudence.
7. That the applicant/accused is ready to abide all the term of condition imposed by
this Hon’ble Court and ready to furnish sound surety to the satisfaction of this
Hon’ble court.

It is therefore most respectfully prayed that this Hon’ble court may kindly
please to release the applicant/accused on bail, till the final conclusion of this
case, in the interest of justice, equity and good conscience.

Or

Hon’ble Court may release the applicant/accused on personal bond if he


has been already granted bail pass such other of further orders as this Hon’ble
Court may kindly be deemed fit, just and proper in the circumstances of the
above case.

New Delhi
Dated:19.09.2024 Applicant/Accused
Gopal Kaku
(In JC)
Through

Lalit Naagar
Legal Aid Counsel/Remand Advocate
Chamber No. 346, Lawyers Block,
Saket Court Complex New Delhi- 110074
+91- 9990303636

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