Memorandum of Crl. Misc. Petition Under Section - 439 of The Code of Ciminal Procedure, 1973.

IN THE COURT OF THE PRINCIPAL CITY CIVIL AND SESSIONS
JUDGE [MAYO HALL] AT: BANGALORE

CRL. MISC. NO: ________________ O F 2019
In the case of:
PETITIONER: KOMBA MARIA MENANSI
RESPONDENT : THE STATE OF KARNATAKA BY

BANASWADI POLICE STATION
BANGALORE.
PETITION PRESENTED BY
ALLIANCE LAW ASSOCIATES
Mr. YAHATHESHAM,
Mr. HASANULLAH,
Ms. RAVILA GOWDA,
Advocates,
# 124, 3rd Floor, Hennur Main
Road, Kacharakanahalli Bus
Stop, St Thomas Town Post,
Kacharakanahalli, Bangalore-
560084.
Mobile: 9900775439
INDEX
Sl. C.F.
Description Pages
No. Paid
1. Memorandum of Bail Petition Under
Section – 439 , Cr.P.C
2. List of Documents and Documents
3. Vakalath Nama / Memo of Appearance
4. Process Memo
5. Other Side Copies
Bangalore.
Date: 17-09-2019 Advocate for Petitioner.
IN THE COURT OF THE PRINCIPAL CITY CIVIL AND SESSIONS JUDGE
[MAYO HALL] AT: BANGALORE
CRL. MISC. NO: ________________ O F 2019
In the case of:

BANGALORE.
LIST OF DOCUMENTS
The undersigned counsel for the petitioner in the above case

herewith produces following documents for the kind perusal of
this Hon’ble Court.
Document Pag
Sl. Description of Documents Presented referred in
No e
Petition as No’s
.
1. Certified Copy of F.I.R. Annexure – 1
2. Certified Copy of Complaint. Annexure – 2
3. Certified Copy of Remand. Annexure – 3
4. Certified Copy of bail order passed by the Annexure – 4

MMTC 1.
Bangalore
Dated: 17/09/2019 ADVOCATE FOR PETITIONER
CRL. MISC. NO: ________________ O F 2019
In the case of:

KAMMANAHALLI ,
BANGALORE CITY
KARNATAKA 560084

BANGALORE.
MEMORANDUM OF CRL. MISC. PETITION UNDER SECTION –

439 OF THE CODE OF CIMINAL PROCEDURE, 1973.
The Petitioner above named most respectfully submits as

follows.
1. The address of the Petitioner for the purpose of service of

court notices, summons etc., from this Hon’ble Court is as
shown in the above cause title and that of their counsels at
ALLIANCE LAW ASSOCIATES, represented by Shree.
Yahathesham, Hasanullah, Ravila Gowda, Advocates, # 124,
3rd Floor, Hennur Main Road, Opposite Kacharakanahalli
Bus Stop, St Thomas Town Post, Kacharakanahalli,
Bangalore 560084.
2. The address of the Respondents for the similar purpose is as

shown above in the cause title.
BRIEF FACTS OF THE CASE
1. The complainant police sub inspector Banaswadi police station

has lodged a complaint before respondent police, in that he
alleged that on 30/08/2019 morning around 10 AM while
crossing the Parivar showroom near Kammanahalli she saw a
one foreigner and examined the passports, visa, and other
documents from that foreigner she noticed that her passport no
AB754435 and visa no VJ8938395 and on 02/04/2016 her
visa was expire.
2. The complainant further alleged that on examination of the

above said documents the petitioner in this case has furnished
the above said document, there after arrested the above said
petitioner, on that basses the respondent police have registered
a complaint against above named petitioner in Cr. 506/2019,
for the offences punishable Under Section 14 of FOREIGNERS
ACT, 1946, the above named petitioner arrayed as a accused No
1 Respectively and produced before the Hon’ble Metropolitan
Magistrate (Traffic Court -1), Mayohall, Bangalore. The Hon’ble
court was pleased to remanded them to the judicial custody,
the petitioner were filed bail application before Hon’ble
Metropolitan Magistrate (Traffic Court -1), Mayohall, Bangalore.
The Hon’ble Was pleased to rejected the said bail application,
Hence this petition.
GROUNDS FOR THE BAIL
1. That the Petitioner submit that she have not committed

any offence alleged in the complaint and FIR, she is
innocent of alleged offences under section 14 (1) of
FOREIGNERS ACT, 1946,
2. Petitioner submit that the alleged offences are not

punishable with death or life imprisonment they Triable
by magistrate.
3. Petitioner submits that the Respondent police have falsely

implicated them though they have not committed any
offence.
4. Petitioner further submits that there is no single
documents to show this petitioner have committed the
offences alleged in the complaint and FIR.
5. There are no reasonable grounds to believe that the

Petitioner is the guilty of the alleged offences.
6. That the Petitioner has no antecedents and criminal

records whatsoever.
7. That the Petitioner is ready and willing to abide by any of

the terms and conditions that may be imposed by this
Hon’ble Court and he is ready to offer surety as may be
ordered by this Hon’ble Court.
8. That the petitioner is ready to obey all the terms and

conditions that may be imposed at the time of granting
the bail as sort for.
PRAYER:
WHEREFORE, The above named petitioner prays that this

Hon’ble court may be pleased to enlarge the above named
petitioner on bail in Crime No. 506/2019 Registered by the
respondent Police (Banaswadi PS) for the offences punishable
Under section 14 (1) of FOREIGNERS ACT, 1946,.
Place: Bangalore
Date: 17/09/2019 Advocate for Petitioner
CRL. MISC. NO: ________________ O F 2019
PETITIONER. RESPONDENT .
KOMBA MARIA MENANSI, THE STATE OF KARNATAKA BY

KAMMANAHALLI , BANASAWADI POLICE STATION,
BANGALORE CITY BANGALORE.
KARNATAKA 560084 REPRESENTED BY PUBLIC PROSECUTOR.
MEMO OF APPEARANCE
Herein the memo of the appearance on behalf of the advocate for

the Petitioner submits as under:
The family members / Friends of the Petitioner has
requested me to file a memo of appearance on behalf of Petitioner
as she is the judicial custody from 30/08/2019 in Crime No
506/2019 of Banasawadi P.S, as such she cannot sign the
vakalat, so it is most respectfully prayed to this Hon’ble court may
kindly consider this memo of appearance as the Vakalatanama of
Petitioner in the interest of justice and equity.
MR. YAHATHESHAM
KAR/2111/2014
ALLIANCE LAW ASSOCIATES
# 124, 3rd Floor, Hennur Main
Road, Kacharakanahalli Bus
Stop, St Thomas Town Post,
Kacharakanahalli, Bangalore-
560084. Mobile : 9900775439
Bangalore.
Date: 17/09/2019 Advocate for Petitioner.

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IN THE COURT OF THE PRINCIPAL CITY CIVIL AND SESSIONS

JUDGE [MAYO HALL] AT: BANGALORE

In the case of:

PETITIONER: KOMBA MARIA MENANSI

RESPONDENT : THE STATE OF KARNATAKA BY

2. List of Documents and Documents

3. Vakalath Nama / Memo of Appearance

5. Other Side Copies

In the case of:

PETITIONER: KOMBA MARIA MENANSI

RESPONDENT : THE STATE OF KARNATAKA BY

The undersigned counsel for the petitioner in the above case

1. Certified Copy of F.I.R. Annexure – 1

2. Certified Copy of Complaint. Annexure – 2

3. Certified Copy of Remand. Annexure – 3

4. Certified Copy of bail order passed by the Annexure – 4

In the case of:

PETITIONER: KOMBA MARIA MENANSI

RESPONDENT : THE STATE OF KARNATAKA BY

MEMORANDUM OF CRL. MISC. PETITION UNDER SECTION –

The Petitioner above named most respectfully submits as

1. The address of the Petitioner for the purpose of service of

2. The address of the Respondents for the similar purpose is as

BRIEF FACTS OF THE CASE

1. The complainant police sub inspector Banaswadi police station

2. The complainant further alleged that on examination of the

GROUNDS FOR THE BAIL

1. That the Petitioner submit that she have not committed

2. Petitioner submit that the alleged offences are not

3. Petitioner submits that the Respondent police have falsely

5. There are no reasonable grounds to believe that the

6. That the Petitioner has no antecedents and criminal

7. That the Petitioner is ready and willing to abide by any of

8. That the petitioner is ready to obey all the terms and

WHEREFORE, The above named petitioner prays that this

KOMBA MARIA MENANSI, THE STATE OF KARNATAKA BY

Herein the memo of the appearance on behalf of the advocate for

The family members / Friends of the Petitioner has

requested me to file a memo of appearance on behalf of Petitioner

as she is the judicial custody from 30/08/2019 in Crime No

506/2019 of Banasawadi P.S, as such she cannot sign the

vakalat, so it is most respectfully prayed to this Hon’ble court may

kindly consider this memo of appearance as the Vakalatanama of

Petitioner in the interest of justice and equity.

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