Application for Anticipatory Bail before High Court

Updated atMarch 2010

Application for Anticipatory Bail before High Court

In the High Court at Mumbai

(Criminal Miscellaneous Jurisdiction)

In the matter of an Application for anticipatory bail under section 439, Cr PC

Keshav Bharati son of Manoj Bharati residing at ....................., ............................... Petitioner

versus

The State .................. Respondent

To

The Hon''ble Mr. .................................Chief Justice and His Companion Justices of the said Hon''ble Court

The humble petition of Keshav Bharati, the petitioner above-named

MOST RESPECTFULLY SHEWETH:

  1. That the petitioner is a reputed businessman having a long-standing business in Mumbai and is an income-tax and sales-tax assessee.

  2. That the petitioner has his permanent residence in Mumbai.

  3. That due to business rivalry, his business rival, Tubular Co. Ltd., lodged a false complaint against the petitioner before the police alleging cheating and forgery.

  4. That the intention of the de facto complaint is only to harass and humiliate the applicant and to tarnish his clean image in business circle.

  5. Your petitioner apprehends that pursuant to the said complaint the police may arrest your petitioner and thereby put the petitioner to harassment and mental agony and physical inconvenience.

  6. That the petitioner undertakes to abide by all the terms and conditions that may be imposed upon him in the order of bail.

  7. That if the anticipatory bail is not granted the petitioner shall suffer irreparable injury.

  8. That the application is made bona fide and in the interest of justice.

    In the circumstances the petitioner humbly prays that Your Lordships may be graciously pleased to direct that in the event of the petitioner being arrested in connection of this case the petitioner will be released on bail forthwith and/or may pass such other order or orders as Your Lordships may...

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