IN THE COURT OF SESSIONS JUDGE (DISTRICT __________), DELHI
TIS HAZARI COURTS, DELHI

ANTICIPATORY BAIL APPLICATION NO. ______ OF 20__

IN THE MATTER OF:
X _______ S/o _______
R/o __________

…APPLICANT

VERSUS

STATE

…RESPONDENT

FIR No. ______ of 20__
Under Section(s): ______________________
Police Station: ______________________

APPLICATION FOR GRANT OF ANTICIPATORY BAIL UNDER SECTION 438 OF THE CODE OF CRIMINAL PROCEDURE, 1973

MOST RESPECTFULLY SHOWETH:

1. That the Applicant is a young man aged ______ years residing at ________, Delhi. He is the Director of M/s. ABC Ltd., a leading company engaged in the manufacture of electrical appliances.

2. That the Applicant is a respected individual in his locality, enjoys an unblemished reputation, and is a peace-loving citizen.

3. That the Applicant was on amicable and friendly terms with Miss Y, the major daughter of the Complainant. However, their relationship was not approved by her family members, who disapproved of their association. They had repeatedly warned Miss Y and threatened that if she continued to interact with the Applicant, they would implicate him in false criminal charges.

4. That Miss Y had written several letters to the Applicant expressing her apprehensions that her family might take adverse actions against their association. These letters reveal that her family harbored animosity toward the Applicant and sought to pressurize him into severing ties with Miss Y. True copies of these letters are annexed herewith for the kind perusal of this Hon’ble Court.

5. That on _________, the Applicant had gone to visit his friend, who resides in the neighborhood of Miss Y. During his visit, the Applicant was suddenly attacked by the Complainant’s family members, including the father, uncle, and brother of Miss Y, causing him to sustain injuries. The incident was witnessed by the Applicant’s friend and passersby, who intervened and saved him from further harm.

6. That the Complainant’s family, in collusion with the police, has registered a false and fabricated FIR against the Applicant. A bare reading of the FIR shows contradictions and highlights that the aggressors are the Complainant’s family members, while the Applicant is the victim.

7. That the allegations made in the FIR are baseless, and the Applicant has been falsely implicated in the matter. He has no involvement in the alleged offenses.

8. That the Applicant apprehends that he may be arrested based on the said false and fictitious FIR.

9. That the police officials have already visited the Applicant’s premises in his absence, and there is a reasonable apprehension of his arrest.

10. That the Applicant undertakes to cooperate with the investigation and will appear before the Investigating Officer/SHO whenever required.

11. That the Applicant is a permanent resident of Delhi, has deep roots in society, and there is no likelihood of him absconding or tampering with evidence if granted anticipatory bail.

12. That the Applicant has a clean antecedent and has never been involved in any criminal case, except for the present false allegation.

13. That this application is bona fide and filed in the interest of justice.

PRAYER

In light of the aforementioned facts and circumstances, it is most respectfully prayed that this Hon’ble Court may graciously be pleased to:

1. Grant anticipatory bail to the Applicant in the event of his arrest in connection with FIR No. ______ dated ______ under Section(s) ______ of the Indian Penal Code, registered at Police Station ______.

2. Direct the Investigating Officer/SHO concerned to release the Applicant on bail in the event of his arrest.

3. Pass such other and further orders as this Hon’ble Court may deem fit and proper in the interest of justice.

AND FOR THIS ACT OF KINDNESS, THE APPLICANT SHALL EVER PRAY.

APPLICANT THROUGH
_____________________
ADVOCATE FOR THE APPLICANT

Place: New Delhi
Date: ___________

(Note: To be supported by an affidavit as per procedure.)