SAMPLE FORMAT FOR  BAIL APPLICATION WITH HYPOTHETICAL FACTS FOR BETTER UNDERSTANDING

 

IN THE COURT OF SH…………….., ASJ,       ……………COURTS, DELHI

 

IN THE MATTER OF:

 

State                          versus            ……………………

 

FIR No. …….

U/s 307 IPC

PS: ………….

APPLICATION ON BEHALF OF THE ACCUSED TARUN DUA FOR GRANT OF BAIL – SECOND BAIL APPLICATION.

 

Respectfully Showeth

  1. That the applicant/accused is in judicial custody in the aforesaid matter since………….. That the applicant/accused earlier moved bail application which was rejected on ……………………..

 

  1. That after framing of the charges, the prosecution was directed to lead evidence and the two witnesses PW-1 ………and PW-2 …………… has already been cross examined.

 

  1. That the aforesaid PW-1 and PW-2 namely ………………………..respectively were allegedly injured in the incident / occurrence. The PW-1 ……………..was allegedly the complainant in the aforesaid case.

 

  1. That in their respective testimonies, the said witnesses have categorically denied the presence and involvements of the applicant/accused………………….. The applicant/accused seeks liberty of the Hon’ble Court refer to the testimonies of the said witnesses during the course of hearing of the bail application, to show that the applicant/accused is innocent person and falsely implicated in the aforesaid matter.

 

  1. That the applicant/accused is a law abiding citizen and he has been falsely implicated in the aforesaid matter by the police with some ulterior considerations.

 

  1. That there has been no legal admissible evidence against the applicant/accused connecting him to the offence alleged.

 

  1. That since main eye witnesses/injured have already been examined and cross examined, the evidence of the remaining witness is somewhat formal in nature.

 

  1. That the applicant/accused is already in judicial custody for the last more than eight months. The prosecution evidence of main witnesses has already been recorded, as such there is no apprehension of the applicant/accused influencing the witnesses or tampering with the evidence.

 

  1. That the applicant/accused has always cooperated during investigation and there is no possibility of the applicant/accused not attending the Hon’ble Court during further trial.

 

  1. That applicant/accused undertakes to abide by the conditions as may be imposed by this Hon’ble Court, while granting bail.

 

It is therefore prayed, that this Hon’ble Court in the facts and circumstances of the case may graciously be pleased to grant the bail to the applicant/accused on the terms as may be deemed fit and proper by this Hon’ble Court.

 

Delhi                                                                                                     Applicant/Accused

Dated:                                                                                   (Through his wife/parokar)

Through

                                                                                   Counsel

 

SAMPLE-2

IN THE COURT OF MS. …………………, M.M. MAHILA COURT, ……………………………, DELHI

F.I.R. NO. ……….

U/S 498A/406/34 IPC & SECTION 4 DP ACT

P.S. …………………

STATE                        VS.                  ………………………………………….

APPLICATION ON BEHALF OF THE ACCUSED PANKAJ ARORA FOR GRANT OF BAIL

Respectfully showeth:

  1. That the accused/applicant is the husband of the complainant, who has been falsely implicated in the aforesaid matter.
  2. That the accused/applicant is a law-abiding citizen with clean record.
  3. That the accused/applicant has been cooperating with the police during the course of investigation and has not in any manner tampered with the evidence.
  4. That there is no legal evidence against the applicant/accused, having committed the offences complained of.
  5. That the applicant/accused undertakes that he would never misuse the liberty, hold out any threat to the witnesses or tamper with the evidence in any manner whatsoever.
  6. That the applicant/accused deserves to be admitted to bail, as his past conduct is clean, just and proper. The applicant/accused is willing to furnish surety to the satisfaction of this Hon’ble Court.
  7. That it is prayed that the accused/applicant be granted bail on the conditions as may be deemed fit and proper.

Dated:                                                                                                                                                                                                                             Through

                                                                                                       Counsel