In The Court of Ld. Distt. & Session Judge, Rohtak
In The Court of Ld. Distt. & Session Judge, Rohtak
In The Court of Ld. Distt. & Session Judge, Rohtak
Jasbir @ Jassu age 20 year son of Balbir, Resident of Village Kharawar, Distt. Rohtak.
Applicant
Vs.
State of Haryana.
Respondent
Sir,
That the applicants/accused humbly submits as under :-
1. That the above titled cazse is pending before this Hon’ble Court and is fixed for 06.10.2020
for evidence and the applicants/accused has been falsely involved in the above noted case by the
complainant in collusion with the local police, whereas, the applicant/accused is quite innocent
person and has nothing to do with the alleged offence.
2. That the applicant/accused is in custody since the day of his arrest i.e. 17.08.2018 and
Challan has already been filed and is not at all required by the police for any further investigation
and the further custody shall only be punitive to the applicant/accused and the same will hamper
the carrier of the applicant/accused.
3. That the accused/applicant is not required by the police for any purpose of investigation or
otherwise and no useful purpose will be served by keeping the applicant/accused in judicial
custody any more.
4. That nothing has been recovered from the applicant/accused and the recovery shown is
planted one upon the accused/applicant lateron and the accused/applicant has attributed no injury
at all to the deceased as alleged by the police. Police had got their signautures on many blank
papers also which are used illegally against the applicant/accused.
5. That all the witnesses in this case are interested and official witnesses and there is no
likelihood of tempering with the prosecution witnesses and the applicants/accused undertake that
he will not try to temper with the prosecution witnesses if granted bail.
6. That the applicant/accused is the law abiding citizen and have a fixed abode of living and
is earning member of the family.
7. That the applicant/accused is ready to abide by the terms and condition imposed if any by
this Hon’ble court in the event of his release on bail.
8. That the applicant/accused is also ready to furnish the bail bond and surety bond to the
extent of entire satisfaction of this Hon’ble court.
9. That the 1st bail application of the accused was ordered to be dismissed vide order dated
08.02.2019 by the Court of Sh. Fakhruddin, Ld. ASJ, Rohtak and 2nd bail application was ordered
to be dismissed by the Court of Smt. Ritu Y. K. Behl, Ld. ASJ, Rohtak vide order dated
13.09.2019 without considering the ground of parity to the accused Mohit Kumat and
Virender @ Bhander. Copy of order dated 13.9.2019 is attached herewith.
10. That the co-accused namely Mohit Kumar son of Ram Niwas has already been ordered to
be releaded on bail by this Hon’ble Court i.e Court of Smt. Ritu Y. K. Behl, Ld. ASJ, Rohtak
vide order dated 04.09.2019. It is pertinent to mention here that as per alleged story of
prosecution, sim card of deceased Naseeb and Danda/wooden bat used in alleged occurance was
recovered from the co-accused Rohit Kumar and the same allegation is levelled on the
applicant/accused.
That the co-accused namely Virender @ Bhander son of Lakhmi has also been ordered to
be releaded on bail by this Hon’ble Court i.e Court of Smt. Ritu Y. K. Behl, Ld. ASJ, Rohtak
vide order dated 09.09.2019. It is also pertinent to mention here that as per alleged story of
prosecution, Moble Phone of deceased Naseeb and Motor cycle used in alleged occurance was
recovered from the co-accused Virender @ Bhander.
Beside the above the co-accused Sumit son of Ravinder is alos on bail vide order dated
19.11.2018, passed by the Court of Sh. Fakhruddin, Ld. ASJ, Rohtak.
1. That the case of applicant/accused is identical to that of co-accused who have been released
on bail and as such vide order dated 04.09.2019 and 09.09.2019 and thus the applicant/accused is
also entitled to be released on bail on the ground of parity. Copy of orders is attached herewith.
It is, therefore, prayed that the applicant/accused may kindly be admitted to bail/interim
bail on the ground of parity during the pendency of the trial to satisfaction of this Hon’ble Court
and after taking sufficient surety applicant may kindly be released on bail to meet the ends of
justice.
Through
Virender Khatri,
Advocate, Sonepat.
In The Court of Ld. Distt. & Session Judge, Rohtak.
Jasbir @ Jassu
Applicant
Vs.
State of Haryana.
Respondent
AFFIDAVIT
I, Jasbir @ Jassu son of Balbir, Resident of Village Kharawar, Distt. Rohtak do hereby
solemnly affirm and declare as under ;-
2. This is the first bail application filed on behalf of the accused before the Hon’ble Session
Court as the offence alleged upon the applicant is tiable by the court of session and thus no
application was filed before lower court. The case is fixed for 05.06.2020 before the lower
court.
Deponent
Verification:- I, the above named deponent do hereby verify that the content affidavit are true
and correct to the best of my knowledge and nothing has been kept concealed therein.
Verified at Sonepat.
On : 03.06.2020.
Deponent