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Chances of bail where the offence is registeed u/s 328, 379,411 & 34 IPC

(Querist) 01 January 2011 This query is : Resolved 
Dear Ld. Advocates

First of all Happy New Year to You All!

My query is like this: One of my client has been arrested by crime branch in pursuance of 3 different FIR registered 3 different police station of NCT of Delhi under same section i.e. 328,379,411,& 34 IPC.

One of the comlainant has identified him.Even one Mobile of the accused has been recovered from her possession. He has been remanded very badly. his legs has been fractured and now same has been plastered. But despite this police action he did not disclose anything about remaining 46 items of complainant.

Now he is lying in JC since 20 days.HE has previous conviction record also.

What should i include in bail petition so that strong chances of bail may arise.
also help me in providing some case laws supporting my bail applications.

I am eagerly waiting your response.

Thanks.
SAANJAAY GUPTAA (Expert) 01 January 2011
Mr. Ansari, include that there is no further recovery inspite of full term PC by the i.o. alongwith other grounds.
DEFENSE ADVOCATE.-firmaction@g (Expert) 03 January 2011
Read the latest SC citation for bails dt 2.12.2010 Mehtre case available in files section.
Ajay Bansal (Expert) 03 January 2011
BAIL WILL BE GRANTED EVEN ON A SIMPLE APPLICATION.


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