IN THE COURT OF LEARNED SESSION JUDGE ,FEROZPUR.
State
VERSUS
Xyzxyz Singh age about 32 years S/O Sh.Xyzxyz Singh R/O Village Sahiwala Tehsil Fazilka Distt Ferozpur.
------------- Applicant /Accused
Application for regular bail in case F I R No 25 dated 15-01-07 Police Station Sadar Fazilka U/S 326/325/324/323/452/148/149 I PC titled as State VS Xyzxyz Singh & others pending in the court of Sh. Jarnail singh , Judicial Magistrate First class Fazilka.
Note :- (1) This is first bail application filed before this hon’ble court.(2) Others accused Satnam singh released on bail by this hon’ble court (Sh. ----------- session judge Ferozpur) on 8-02-07 and accused Puran singh , Lakhbir Singh and Mukhtiar Singh released on 27-02-07 by this hon’ble Court.
Grounds of Bail:-
1. That the abovesaid state case titled as State VS Xyzxyz Singh & others is pending in the court of Sh. Jarnail Singh Judicial Magistrate 1st class Fazilka in which the applicant has also been arrayed as accused No 1 along with other accused.
2. That the accused is in judicial lock up at Fazilka since 16/17 –01-07 till today in the abovesaid case.
3. The applicant/ accused did not cause any injuries on the person of complainant Ashok Kumar or any other person with any weapon or Kappa nor entered in the house of the complainant with other accused as alleged in the prosecution story / or in the alleged accurance on dated 14-01-07 at about 6:30 P.M . The prosecution story is false and devoid of any truth & no recovery of any alleged weapon has been effected from the applicant / accused.
4. That the accused has been falsely involved/ implicated in the abovesaid case on account revengeful attitude of the complainant & his party Suresh Kumar etc towards the applicant /accused. The abovesaid persons Suresh kumar, Mangat Ram S/O Jawhara Lal , Ved Parkash, Kala Ram S/O Kashmir Lal, Hakam Chand S/O Harkrishan Lal & Kashmir Lal R/O Village Sahiwala, close associates on the night Diwali after illegally ,forcibly entering the home of the applicant male/ treated & threatened to murder/kill the applicant /accused. The applicant submitted the applications dated 25-10-06 & 28-10-06 before Police station sadar Fazilka & Chief Minister of Punjab and Chairman of Punjab Human rights commission Chandigarh. The complainant & abovesaid persons have formed an illegal group against the applicant /accused. The complainant & abovesaid persons had enmity/revengeful attitude against the accused because the applicant/ accused had purchased about 3 Marlas of vacant land/plot for construction of his house which the complainant party seriously intended to purchase & did not succeed in this object. The applicant/ accused has constructed one Kacha Room in the abovesaid plot & is residing in the same with his family.
5. That as per the prosecution story complainant party also caused injuries to Lakhmir Singh non applicant accused Lakhmir Singh , Jogindro bai and Gurdeep singh . Thus there is a cross version case. The complainant-injured party have already been discharged from the hospital. The accused /applicant is in judicial custody since about 50 days and is not required by the police.
6. That the applicant /accused is ready to furnish surety bond to the satisfaction of this Hon’ble court.
7. That the applicant/ accused will never misuse the concession of bail and under- takes to appear regularly in the abovesaid case in the lower court.
8. That there is no apprehension of absconding of the applicant/accused or tempering with the prosecution evidence/witnesses.
9. That it is first bail application filed by the applicant/accused before this hon’ble court and no such bail application on behalf of the applicant/accused is pending or decided by any other court of law.
10. That other accused namely Satnam Singh, Puran singh, Lakhbir Singh and Mukhitar Singh have already been released on bail by the Hon’ble court of Sh. U. S Gera LD session Judge Ferozpur vide its order dated 8-02-2007 and 27-02-2007.
It is , Therefore prayed that the applicant/accused may kindly be released on bail till decision of the case fully detailed above.
Date : 5-03-2007 Submitted:- Xyzxyz Singh
Applicant/accused
Through counsel
Rajesh Kasrija
Enrolment No.P/1181|2000
