Legal Desire Online Workshop on ‘Legal Drafting’ BAIL APPLICATION UNDER SEC. 436 OF CRPC MEMO OF THE APPEARANCE
IN THE COURT OF JUDICIAL MAGISTRATE, ERODE
Cr. M. P. No 4343/ 2014 Crime No 1234/ 2014 (on the file of the FIR No, police station at Erode)
Prem kumar, aged 28, son of Periya samy residing in housing unit of teachers colony, Sampath Nagar, Erode.
…………………………Petitioner/Accused
Versus Respondent State through Erode Police Station, P. S. Park, Erode.
…………………………Respondent/Complainant
MEMO OF APPEARANCE I have been duly instructed from the Petitioner/Accused to proceed with the case
Advocate for the Petitioner/ Accused
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Legal Desire Online Workshop on ‘Legal Drafting’ BAIL APPLICATION
IN THE COURT OF SESSIONS JUDGE, ERODE Cr. M. P. No 4343/ 2014 Crime No 1234/ 2014 (on the file of the FIR No, police station at Erode) Prem kumar, aged 28, son of Periya samy residing in housing unit of teachers colony, Sampath Nagar, Erode. …………………………Petitioner/Accused Versus Respondent State through Erode Police Station, P. S. Park, Erode. ………… Respondent/Complainant BAIL APPLICATION/PETITION FILED UNDER SECTION 439 OF CRPC
1. It is humbly submitted that the present application under Section 439 of Crpc is being filed by the Petitioner/Accused for seeking grant of bail in the FIR 1234/ 2014 in connection with the offence under Section 506 Part II registered at Police Station, Erode. The present petition is being moved as the Petitioner/Accused has been arrested on 01/07/2014 in connection with the said FIR. The Petitioner/Accused is now in judicial/police custody. 2. The Petitioner/ Accused is the only breadwinner of the family. He/She has a wife and younger child and elders in his family and they are entirely dependent on the Petitioner/Accused.
3. The Petitioner/Accused is an innocent person and has not committed any offences as alleged by the Complainant/Respondent no useful purpose would be served by keeping him under custody and this is a fit case for grant of bail. 4. The Petitioner/Accused, if a law abiding citizens and so he/she will not abscond. 5. The Petitioner/Accused is prepared to furnish substantial sureties for his/her due appearance. © Copyright Legal Desire 2014
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Legal Desire Online Workshop on ‘Legal Drafting’ 6. That the Petitioner has not filed any other similar petition before this or any other Honorable Court for grant of bail in case of the present FIR. (Or give details and results of earlier applications – if it has already been filed and dismissed means mention the details of application and the reason that the judge has not properly applied his mind while dismissing his/ her bail application). 7. Therefore, it is humbly prayed that this Honorable Court may be pleased to analyze the Petitioner/Accused to release on bail and thus render justice.
Advocate for the Petitioner/ Accused
© Copyright Legal Desire 2014
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Legal Desire Online Workshop on ‘Legal Drafting’ BAIL APPLICATION UNDER SEC. 437 OF CRPC MEMO OF THE APPEARANCE
IN THE COURT OF JUDICIAL MAGISTRATE, ERODE
Cr. M. P. No 4343/ 2014 Crime No 1234/ 2014 (on the file of the FIR No, police station at Erode)
Prem kumar, aged 28, son of Periya samy residing in housing unit of teachers colony, Sampath Nagar, Erode.
…………………………Petitioner/Accused
Versus Respondent State through Erode Police Station, P. S. Park, Erode.
…………………………Respondent/Complainant
MEMO OF APPEARANCE
I have been duly instructed from the Petitioner/Accused to proceed with the case
Advocate for the Petitioner/ Accused
© Copyright Legal Desire 2014
www.legaldesire.com
Legal Desire Online Workshop on ‘Legal Drafting’ BAIL APPLICATION
IN THE COURT OF JUDICIAL MAGISTRATE, ERODE
Cr. M. P. No 4343/ 2014 Crime No 1234/ 2014 (on the file of the FIR No, police station at Erode)
Prem kumar, aged 28, son of Periya samy residing in housing unit of teachers colony, Sampath Nagar, Erode.
…………………………Petitioner/Accused
Versus Respondent State through Erode Police Station, P. S. Park, Erode.
…………………………Respondent/Complainant
BAIL APPLICATION/PETITION FILED UNDER SECTION 437 OF CRPC
1. It is humbly submitted that the respondent police has registered a case against the Petitioner/Accused for an alleged offence under Section 506 Part II IPC and remanded by the Court on 01/07/2014. 2. The Petitioner/ Accused is the only breadwinner of the family. He/She has a wife and younger child and elders in his/her family and they are entirely dependent on the Petitioner/Accused. 3. The Petitioner/Accused is an innocent person and has not committed any offences as alleged by the Respondent/Complainant.
© Copyright Legal Desire 2014
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Legal Desire Online Workshop on ‘Legal Drafting’ 4. The Petitioner/Accused is a law abiding citizens and so he/she will not abscond. 5. The Petitioner/Accused is prepared to furnish substantial sureties for his/her due appearance. 6. Therefore, it is humbly prayed that this Honorable Court may be pleased to analyze the Petitioner/Accused to release on bail and thus render justice. Advocate for the Petitioner/ Accused
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Legal Desire Online Workshop on ‘Legal Drafting’ BAIL APPLICATION UNDER SEC. 438 OF CRPC AFFIDAVIT
IN THE COURT OF SESSIONS JUDGE, ERODE
Cr. M. P. No 4343/ 2014 Crime No 1234/ 2014 (on the file of the FIR No, police station at Erode) Prem kumar, aged 28, son of Periya samy residing in housing unit of teachers colony, Sampath Nagar, Erode.
……………………………. Petitioner/Accused
Versus Respondent State through Erode Police Station, P. S. Park, Erode.
……………………………Respondent/Complainant
AFFIDAVIT IN SUPPORT OF THE APPLICATION/PETITION FILED UNDER SECTION 438 OF CRPC
I, Prem Kumar, aged 28, son of Periyasamy, residing in housing unit of teachers coloney, Sampath Nagar, Erode, do hereby solemnly affirms and sincerely states as follows:1. That the accompanying application under section 438 CrPC has been drafted at my instance and under my instructions.
2. That the case FIR No. 1222/2014 dated 20/07/2014 under section 506 part 11 IPC has been registered by the police against me. © Copyright Legal Desire 2014
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Legal Desire Online Workshop on ‘Legal Drafting’ 3. The case is neither true nor correct to the best of my knowledge.
4. I am an innocent person and I have not committed any offence alleged.
4. I am a law abiding citizen and so I will not abscond.
Accused/ Petitioner Verification Verified that the contents of my above affidavit are true to best of my knowledge and belief and nothing concealed therein.
Place - Erode. Date - 20/07/2014
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Signature of the Advocate (other than counsel for advocate)
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Legal Desire Online Workshop on ‘Legal Drafting’ BAIL APPLICATION
IN THE COURT OF SESSION JUDGE, ERODE
Cr. M. P. No 4343/ 2014 Crime No 1234/ 2014 (on the file of the FIR No, police station at Erode)
Prem kumar, aged 28, son of Periya samy residing in housing unit of teachers colony, Sampath Nagar, Erode.
…………………………Petitioner/Accused
Versus Respondent State through Erode Police Station, P. S. Park, Erode.
…………………………Respondent/Complainant
BAIL APPLICATION/PETITION FILED UNDER SECTION 438 OF CRPC
1. For the reasons stated in the accompanying affidavit, it is humbly submitted that the Respondent Police has registered a case against the petitioner/accused for an alleged offence under Section 506 Part II IPC. 2. The Petitioner/Accused is an innocent person and has not committed any offences as alleged. 3. The Petitioner/Accused is a law abiding citizen and hence he/she will not abscond. 4. The Petitioner/Accused is prepared to furnish substantial sureties for his/her due appearance. © Copyright Legal Desire 2014
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Legal Desire Online Workshop on ‘Legal Drafting’ 5. Therefore, it is humbly prayed that this Honorable Court may be pleased to analyze the Petitioner/Accused to release on bail and thus render justice.
Advocate for the Petitioner/ Accused
© Copyright Legal Desire 2014
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Legal Desire Online Workshop on ‘Legal Drafting’ BAIL APPLICATION UNDER SEC. 439 OF CRPC MEMO OF APPEARANCE
IN THE COURT OF SESSIONS JUDGE, ERODE Cr. M. P. No 4343/ 2014 Crime No 1234/ 2014 (on the file of the FIR No, police station at Erode) Prem kumar, aged 28, son of Periya samy residing in housing unit of teachers colony, Sampath Nagar, Erode.
…………………………Petitioner/Accused
Versus Respondent State through Erode Police Station, P. S. Park, Erode.
…………………………Respondent/Complainant MEMO OF APPEARANCE
I have been duly instructed from the Petitioner/Accused to proceed with the case
Advocate for the Petitioner/ Accused
© Copyright Legal Desire 2014
www.legaldesire.com
Legal Desire Online Workshop on ‘Legal Drafting’ BAIL APPLICATION
IN THE COURT OF SESSIONS JUDGE, ERODE Cr. M. P. No 4343/ 2014 Crime No 1234/ 2014 (on the file of the FIR No, police station at Erode) Prem kumar, aged 28, son of Periya samy residing in housing unit of teachers colony, Sampath Nagar, Erode.
…………………………Petitioner/Accused
Versus Respondent State through Erode Police Station, P. S. Park, Erode.
…………………………Respondent/Complainant
BAIL APPLICATION/PETITION FILED UNDER SECTION 439 OF CRPC
1. It is humbly submitted that the present application under Section 439 of Crpc is being filed by the Petitioner/Accused for seeking grant of bail in the FIR 1234/ 2014 in connection with the offence under Section 506 Part II registered at Police Station, Erode. The present petition is being moved as the Petitioner/Accused has been arrested on 01/07/2014 in connection with the said FIR. The Petitioner/Accused is now in judicial/police custody. 2. The Petitioner/ Accused is the only breadwinner of the family. He/She has a wife and younger child and elders in his family and they are entirely dependent on the Petitioner/Accused.
© Copyright Legal Desire 2014
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Legal Desire Online Workshop on ‘Legal Drafting’ 3. The Petitioner/Accused is an innocent person and has not committed any offences as alleged by the Complainant/Respondent no useful purpose would be served by keeping him under custody and this is a fit case for grant of bail. 4. The Petitioner/Accused, if a law abiding citizens and so he/she will not abscond. 5. The Petitioner/Accused is prepared to furnish substantial sureties for his/her due appearance. 6. That the Petitioner has not filed any other similar petition before this or any other Honorable Court for grant of bail in case of the present FIR. (Or give details and results of earlier applications – if it has already been filed and dismissed means mention the details of application and the reason that the judge has not properly applied his mind while dismissing his/ her bail application). 7. Therefore, it is humbly prayed that this Honorable Court may be pleased to analyze the Petitioner/Accused to release on bail and thus render justice.
Advocate for the Petitioner/ Accused
© Copyright Legal Desire 2014
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