Bail Application In The Court Of Judicial Magistrate Of First Class, Patna

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BAIL APPLICATION IN THE COURT OF JUDICIAL MAGISTRATE OF FIRST CLASS, PATNA Criminal Misc Application No. 1045 of 2020 In Crime No.....of 2020 of Police Station, Danapur, Patna Crime Case No......of 2020

Saket Rao, S/o Shri Sudhanshu Rao, aged about 25 years, R/o A-45/345, Shree Raj Complex, Shaguna Mod, Danapur, Patna. ....................Applicant vs. State of U.P .................Prosecution Application for Bail Under Section 437 (1) of Cr.P.C. Most Respectfully Submitted As Under: 1. That the applicant is a freelance journalist and engages in the work of writing articles and blogs for various newspapers and online magazines and websites. 2. That the present FIR has been registered on false and bogus facts. The facts stated in the FIR are fabricated, concocted and without any basis.

3. That the police has falsely implicated the applicant and arrested him in the present case, the applicant is a respectable citizen of the society and is not involved any criminal case. 4. That the state government has been particularly against the work done by the applicant and has used police force as state machinery in the present case to suppress the voice of dissent in the state. 5. That the applicant is not required in any kind of investigation nor any kind of custodial interrogation is required, nor any recovery is to be made at the instance of the applicant and thus the arrest is not valid. 6. That the applicant is having very good antecedents, he belongs to good family and there is no criminal case pending against them. On the other side, the applicant has been constantly doing social work of some nature or the other. 7. That the applicant is a permanent resident and there are no chances of his absconding from the course of justice. 8. That the applicant undertakes to present himself before the police/court as and when directed. 9. That the applicant undertakes that he will not, directly or indirectly make any inducement, threat or promise to any person acquainted with the facts of the case so as to dissuade him from disclosing such facts to the Court or to any police officer. 10. That the applicant further undertakes not to tamper with the evidence or the witnesses in any manner. That the applicant shall not leave India without the previous permission of the Court. 11. That the applicant is ready and willing to accept any other conditions as may be imposed by the Court or the police in connection with the case.

Prayer It is, therefore, most respectfully prayed that this Hon’ble Court may be pleased to allow this application and release the applicant on bail during the pendency of trial. Any other order which the court may deem fit and proper in the facts and circumstances of the case may be also passed in favour of the applicant. Place- Patna Date – 17/08/2020 .................................. Signature of Applicant .................................... Signature of Advocate

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