APPLICATION FOR ANTICIPATORY BAIL U/S 438 OF

THE CRIMINAL PROCEDURE CODE 1973

IN THE COURT OF THE DISTRICT & SESSIONS JUDGE, PUNE

CRIMINAL ANTICIPATORY BAIL APPLICATION NO.: -03 OF 2021

Shri. Vishwesh Kelkar, )

Age 59 years, Occ. Social worker, )

Address: 201, Krupa Sadan,

Mahatma Phule Marg, )

PUNE 411 004 ) Applicant

Versus

THE STATE OF MAHARASHTRA ) Respondent

MOST RESPECTIFULLY SHOWETH:

1. That the applicant is a social worker and active member of the Shiv Sena
Party and has been since 1995.

2. That the applicant has been serving the cause of society and aimed at
betterment of its citizens from all walks of life for the last thirty years.

3. That during the recent by-election to the Pune Municipal Corporation in

Ward No. 50, the applicant got elected with a large number of votes,
exceeding by almost 50 percent against his rival candidate, Shri
Devendra Joshi, who belongs to the Congress- I Party.
4. That during the election campaign, there were a great many allegations
made by the members of both the parties, and the said Congress- I
candidate tried his best to make extremely malicious attempts with the
sole intention to defeat the candidature of this applicant and damage his
reputation and goodwill in the society.

5. That the said Congress-I candidate could not withstand his defeat in the
election, and since the date of the declaration of the election result, the
situation as a whole has gone from bad to worse.

6. That on or about 22.12.2020, a person alleged to have been an active

member of the Congress-I Party was stabbed, and he died the following
day on 23.12.2020.

7. That the applicant believes that on account of such unhealthy political

activities indulged into by the said defeated candidate, some malicious
plans and designs have been worked out with an intention so as to
implicate this applicant for having committed or concerned with such a
non-bailable offence.

8. That the applicant submits that since the date of the declaration of the
election result on, this applicant had gone to Tirumala, Tirupati, Andhra
Pradesh on a pilgrimage tour, and when he returned back to the
headquarters only yesterday night on 28.12.2020, he came to know
about such an accusation against him, and hence felt compelled to seek
protection via this application.

9. That the applicant states and submits that he had no concern nr

connection with any such offence, if committed by some miscreants, and
the contention of this applicant will be explicitly clear of the very fact
that this applicant was out of the headquarters in Pune throughout, and
thus, he is innocent.
10. That the applicant apprehends that he may be arrested on such an
accusation, and hence, this application is being brought about in front of
this Hon’ble Court.

11. That this applicant furthermore submits that if this application is

not granted by the Hon'ble Court, flagrant injustice will be done to him
for no fault on his part.

12. That the applicant also believes that he will not be deprived of his
legitimate and fundamental right,

13. That the proper court-fee is paid herewith.

14. That the applicant, therefore, prays that this application be kindly
allowed and orders granting an anticipatory bail be issued in favour of
this applicant.

Pune,

Sd/-
Vishwesh Kelkar
APPLICANT
Dated: 01.01.2021

Sd/-
Archana Nair
ADVOCATE FOR APPLICANT
 VERIFICATION

I, Shri Vishwesh Kelkar, the present applicant, do hereby state on

solemn affirmation that the contents of this application in paras 1 to 14
are true and correct to the best of my knowledge and
belief, so I have signed hereunder.

Sd/-
Vishwesh Kelkar
APPLICANT