IN THE COURT OF HON’BLE SESSIONS JUDGE, Dheradun

Cr MP (M) No:______ 2019

Application under Section 438 CrPC

Nitin Singh s/o Kuldeep Singh,

Versus

State of uttrakhand

First Application under Section 438 C.R.P.C For Grant of Anticipatory Bail in Case FIR No. ____Under
Section 412 IPC
Sir,

The applicant/petitioner most respectfully submits as under:-

1- That the complainant has registered the above mentioned case against the applicant/petitioner.
2- That the applicant/petitioner has no nexus or connection with the above-mentioned offence.
3- That the applicant/accused is a resident of India as is aged about 37 years.
4- That the applicant/petitioners have not dishonestly received any stolen property.
5- That the allegations in the FIR as alleged by the complainant are wrong, incorrect and concocted story
made by the complainant.
6- That the applicant/petitioner was unaware of the fact that the property which he was received were
obtained by the dacoity and also the applicant/petitioner was not received that property dishonestly.
7- That the applicant/petitioner undertakes to join the investigation as and when required by the police
of police Station premnagar.
8- That there is no apprehension for absconding or evading of taking trial.
9- That the applicant/petitioner undertakes not to temper with the evidence or witnesses.
10- That the applicant/petitioner undertakes to abide by all the terms and conditions as imposed by the
Hon’ble court in the event of bail.
11- That the applicant/petitioner undertakes for not to hamper the bail and ready to furnish the bail
bonds of sound amount for the satisfaction of the Hon’ble court.
12- That in such type of false cases the bail is rule and refusal of the bail will not serve any purpose.

PRAYER:
It is, therefore prayed that the applicant/petitioner may kindly be released/granted anticipatory bail and
the court concerned of concerned police station may kindly be directed to release the
applicant/petitioner on bail in the event of their arrest

Dated: 04/03/2019

Nitin Singh

Through counsel:
Rishab Kumar