IN THE COURT OF METROPOLITAN MAGISTRATE (DISTRICT __________), DELHI

BAIL APPLICATION NO. __________ OF 20XX

IN THE MATTER OF:
STATE – COMPLAINANT
VERSUS
X _______ S/o _______ R/o __________

…APPLICANT

FIR NO. ________ U/S_________________
POLICE STATION _____________________

APPLICATION FOR GRANT OF BAIL UNDER SECTION 437 OF Cr.P.C.

Note: This Legal Draft is merely illustrative and not exhaustive. It should only be used in consultation with a lawyer and with due edits to meet the ends of the user.

The applicant/accused above-named respectfully submits as follows:

1. That the accused was arrested on __________ and has been in judicial custody since then.
   It is alleged by the prosecution that on __________, the accused was suspiciously moving on __________ when the police apprehended him and conducted a search, which allegedly resulted in the recovery of ________ (mention case property).

2. That the accused is innocent and has been falsely implicated in the present case.
   The accused has no connection with the alleged offence, and the charges against him are baseless and fabricated.

3. That no incriminating material was recovered from the possession of the accused or at his instance.
   The alleged recovery of the case property is fabricated and planted to falsely implicate the accused in this case.

4. That the accused is a law-abiding citizen with a respectable background.
   He belongs to a respectable family and is well-regarded in his community. The accused has no prior history of engaging in unlawful activities.

5. That the accused has previously assisted law enforcement authorities.
   In __________, the accused had reported certain illegal activities involving the sale of contraband near __________. This led to the arrest of several individuals, who later threatened the accused with false implications. The accused made a complaint to the Deputy Commissioner of Police in this regard, a copy of which is annexed as Annexure-A.

6. That the Vigilance Department of Delhi Police conducted an inquiry into the accused’s complaint.
   The accused was called by the Vigilance Cell for further investigation into his complaint. A copy of the notice issued by the Vigilance Department is annexed as Annexure-B.

7. That the accused’s conduct is inconsistent with the allegations against him.
   It is improbable that a person who has actively reported illegal activities would himself indulge in the same.

8. That the accused is a permanent resident of Delhi with no intention of absconding.
   The accused has strong ties to the locality and is unlikely to flee or evade judicial proceedings.

9. That there is no risk of the accused tampering with evidence or influencing witnesses.
   The accused assures the Hon’ble Court of his full cooperation with the investigation.

10. That the accused undertakes to comply with all conditions imposed by the Court.
    The accused will participate in the investigation as and when required and will abide by any conditions imposed upon him during bail.

11. That the accused has no prior convictions.
    The accused has a clean criminal record and has never been involved in similar cases or any other criminal activities.

12. That the present case is motivated by extraneous factors.
    The accused is a victim of malafide actions and clear manipulation by certain vested interests in collusion with the investigating authorities.

13. That the accused is entitled to bail under the principles of criminal jurisprudence.
    It is a settled legal principle that bail is the rule and jail is the exception. The accused deserves the benefit of this principle given the lack of credible evidence against him.

PRAYER

In view of the above facts and circumstances, it is most respectfully prayed that this Hon’ble Court may kindly:

1. Grant bail to the accused during the pendency of the present case, and
2. Pass any other order(s) as may be deemed fit and proper in the interest of justice.

New Delhi
Dated: __________

APPLICANT THROUGH
[NAME OF ADVOCATE]
ADVOCATE FOR THE ACCUSED

Note:
This application must be supported by:

1. An affidavit of the Pairokar.
2. A Vakalatnama duly attested by Jail Authorities, wherever applicable.