In the Court of Judicial First Class Magistrate, Gorakadhanda, at Jalsazi.,

Cr.M.P. Np…………….. of 1997

in

Crime No…………… of 1997

ADVERTISEMENTS:

(Of the Police Station Dhandagali).

Between:

Chalbaz Khan son of Nityanand Khan, aged about 50 years, Occupation Business, resident of 8-2-840,

Dhandagali, Gorakadhanda…. Petitioner/Accused

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and

The State of Anarkali, represented by Station House

Officer, Dhandaali, Police Station…. Respondent/Respondent

BAIL PETITION FOR THE OFFENCE UNDER 304-A., I.P.C. May it please your honour.

ADVERTISEMENTS:

1. That the petitioner is a resident of Dhandagali. He is a paid lorry driver under Sri Shatam and of Dhundagali. On 4-5-1997 at 4.00 p.m. while the petitioner was driving his lorry from Dhundagali to Jalsazi, an accident occurred near NSTL at Visakhapatnam. When XY suddenly crossed the road without regard to the traffic, the petitioner’s lorry dashed against XY despite the best efforts of the petitioner to avoid the accident. It resulted in the death of XY. Though the petitioner was not at fault, he informed police about the accident.

2. That the Police registered a case under Section 304-A IPC and arrested the petitioner on the evening of 4-5-1997. This Honourable Court was pleased to remand the petitioner for fourteen days when he was produced before the Court on 5-5-1997.

3. That the petitioner is an innocent person. He is a poor man, with driving as his only means of livelihood and has to maintain himself, his wife and two children at present. The petitioner’s wife is carrying now. The petitioner has a fixed place of abode at Dhundagali. There is no intention or scope for the petitioner to escape from the jurisdiction of the Court if the petitioner is released on bail. The offence alleged against the petitioner is a bailable offence.

4. That in the aforementioned circumstances, the petitioner begs to submit that the petitioner may be enlarged on bail during the pendency of the case.

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5. The petitioner also submits that he did not file any bail application in any other Court.

Therefore it is prayed that the petitioner be enlarged on bail on terms and conditions this Hon’ble Court deems fit and proper.

Jalsazi.

Dt.: 25-5-’97 Counsel for petitioner

ADVERTISEMENTS:

It is desirable to incorporate the name and description of the petitioner as given in the F.I.R.; and to follow the Circular orders of the High Court in these regards.