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ANTICIPATORY BAIL UNDER SECTION 438 OF CrPC MEMORANDUM OF CRIMINAL PETITION (FILED UNDER SECTION 438 OF CrPC) IN THE

HIGH COURT OF PUNJAB AND HARYANA, CHANDIGARH Criminal Petition No. ---- of 2011 IN CRIME No. --- of 2010. ON THE FILE OF --- POLICE STATION Between ABC son of ---Aged About --- Years Resident of And The State of Punjab Rep. by its Public Prosecutor High Court of Punjab and Haryana Chandigarh Respondent/ Complainant Petitioner/Accused

The Address for Service of all Notices and process upon the above named petitioner is that of his counsel m/s Goyal and associates, advocates, Patiala. (State Brief Facts of the Case) 1. 2. 3.

4. It is humbly submitted that the petitioner hails from a respectable family having high reputation among the society. 5. It is humbly submitted that the petitioner is an innocent not guilty of any offences charged with. 6. The petitioner is ready and willing to furnish the necessary securities as may be directed by this honble court. It is therefore prayed that this honble court may be pleased to direct release of the petitioner on anticipatory bail in the event of his arrest in crime number -----. On the file of the police station ---- and to pass such order as this honble court may deem fit and proper in circumstances of the case. Place Date Counsel for the petitioner

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