In The Court Of Ld. District & Sessions Judge, Comilla.
Criminal Appeal Case No.................. of 2015.
Ref:-
S.T Case No.-1363/2011.
U/S:-138 of the Negotiable
Instrument Act, 1881/.
Judgment & Order Dated:-
13/03/2013.
Sentenced the accused to
suffer rigorous imprisonment
for 1 (One) year and to pay
Tk. 5,61,354/-.
-:In The Matter Of:-
An application for Bail under section 426 of the
code of criminal procedure 1898.
-:AND:-
-:In The Matter Of:-
Judgment and order dated 13/03/2013 passed by
Ms. Jesmin Ara Begum, ld. Joint Sessions judge,
3rd Court of Comilla in the Session Case No.
1363 of 2013, Convicted the accused Appellant
under Section 138(1) of the Negotiable
Instrument Act. 1881 and Sentenced him to suffer
rigorous imprisonment for 1 (One) year and to
pay Tk. 5,61,354/-.
-:AND:-
-:In The Matter Of:-
A.B.M Jahangir Alam (50),
S/O:-Abdul Jabbar,
Propitor:-M/S G.M Enterprise,
Village:-Alompur, P.O:-Halima Nagar,
P.S:-Kotwali, Dist:-Comilla.
.........Accused Appellant.
(In Jail).
-:VERSUS:
The State.
...............Respondent.
The humble petition of appeal of the
appellant above named most respectfully
 -:GROUNDS:-
1. For that, the accused appellant is quite innocent and had no
knowledge about the occurrence of the instant case.

2. For that, the accused appellant came from a respectable Muslim

family of his locality & is a law abiding people of the country.

3. For that, the complainant falsely & intentionally implicated the

accused appellant in the instant case.

4. For that, the prosecution couldn’t able to prove the allegation

beyond reasonable doubt against the accused appellant.

5. For that the P.Ws didn’t corroborate the prosecution case.

6. For that the ld. trail court didn’t apply it’s judicial mind.

7. For that, the ld. trail court without considering the facts & evidences
on record sentenced the accused appellant to suffer rigorous
imprisonment for 1 (One) year and to pay the sum of Tk. 5,61,354/-
which was fully illegal and as such the order of sentenced is liable to
be set aside.

8. For that, the accused appellant voluntarily surrendered before the ld.
trail court on 02/09/2015.

10. For that, the rest will be stated at the time of hearing.

Wherefore, your honor would be graciously be

pleased to enlarge the accused appellant on ad-
interim bail and the realization of fine may kindly
be stayed.

And for this act of kindness, your humble

accused appellant in duty bound shall ever pray.

Dated:-23/11/2015.