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In The High Court Of Delhi At New Delhi
Bail Application No. 1129 of 2017
In The Matter Of:-
Jaswant Singh …….Petitioner
V E R S U S
The State …… Respondent
[In the Case arising out of the FIR No: 0040 of 2015 (Dated: 14/01/2015), PS: Kalyanpuri, U/S: 186/308/332/353/34 OF IPC, District-East Delhi, currently pending in the Court of Shri N K Laka, CMM, Karkardooma Court, New Delhi]
INDEX
Srl. No.
Particulars Page No.
1 Court Fees (Total)
2 Notice of Motion
3 Urgent Application
4 Certificate to the effect that the documents filed with this Petition are part of Trial Court record.
5 Brief synopsis & List of Dates and Events
6 Memo Of Parties
7 Petition for grant of Bail, U/S-439 R/W S- 482 of the Code Of Criminal Procedure Code, 1973.
8 Annexure -P-1 (Colly) Copy of the FIR, along with English translation.
9 Annexure -P-2. Copy of the Order Dated 29.05.2017, passed by Shri Pulatsya Paramachala, ASJ, Karkardooma Courts, Delhi, On The First bail Application of the Petitioner.
10 Annexure- P- 3. Copy of the Order Dated 01.06.2017, passed by Ms. Ravinder Bedi, ASJ, Karkardooma Courts, Delhi, On The Second bail Application of the Petitioner.
11. Annexure -P-2. Copy of the Order Dated 02.06.2017, passed by Shri Pulatsya Paramachala, ASJ, Karkardooma Courts, Delhi , On The Third bail Application of the Petitioner.
12
Annexure- P- 4. Copy of the Order dated 31.05.2017, passed by Hon’ble Mr. Justice A K Chawla, in the Bail Application of the Co-Accused in the Bail Appln. No.1083 of 2017, titled as Rajender Singh Versus The State of NCT of Delhi.
13 Application seeking exemption from filing certified copies of the documents/ Annexures, along with Affidavit.
14 Vakalatnama
Certified that no Petition of this nature is pending before this Hon’ble Court or any other Court including the Hon’ble Supreme Court of India.
Petitioner
Through
Sushil Kr. Sharma & Shahar Alam Beg, Advocates, (Counsel For The Petitioner)
877, Lawyers’ Chambers, Saket Courts, New Delhi- 110017
[email protected] Mob. No.:-9818165785
PLACE: New Delhi DATED: 05.06.2017
In The High Court Of Delhi At New Delhi
Bail Application No. ______ of 2017
In The Matter Of:-
Jaswant Singh …….Petitioner
V E R S U S
The State …… Respondent
Notice Of Motion
To,
The Standing Counsel, Delhi Police. Delhi High Court Lawyers Chambers, Sher Shah Suri Road, New Delhi. Dear Sir, Kindly find attached the copy of the Bail Application, which is most likely to be listed before the Hon’ble High Court of Delhi on _________________. This is for your kind notice and necessary action.
Petitioner
THROUGH
Sushil Kr. Sharma & Shahar Alam Beg, Advocates,
(Counsel For The Petitioner) 877, Lawyers’ Chambers,
Saket Courts, New Delhi- 110017 [email protected]
Mob. No.:-9818165785 PLACE: New Delhi DATED: 05.06.2017
In The High Court Of Delhi At New Delhi
Bail Application No. ______ of 2017
In The Matter Of:-
Jaswant Singh …….Petitioner
V E R S U S
The State …… Respondent
To,
The Registrar, High Court of Delhi. Sher Shah Suri Road, New Delhi.
Urgent Application Sir, Would you kindly treat the accompanying Revision as an urgent matter in terms of Delhi High Court Rules? The urgency is that:
The Petitioner has sought Bail U/S- 439 R/W S- 482 of the Code of Criminal Procedure Code, in the Case arising out of the FIR No: 0040 of 2015 (Dated: 14/01/2015), PS: Kalyanpuri, U/S: 186/308/332/353/34 OF IPC, District-East, currently pending in the Court of Shri N K Laka, CMM, Karkardooma Court, New Delhi. It is prayed accordingly.
Petitioner
Through
Sushil Kr. Sharma & Shahar Alam Beg, Advocates, (Counsel For The Petitioner)
877, Lawyers’ Chambers, Saket Courts, New Delhi- 110017
[email protected] Mob. No.:-9818165785
PLACE: New Delhi DATED: 05.06.2017
In The High Court Of Delhi At New Delhi
Bail Application No. ______ of 2017
In The Matter Of:-
Jaswant Singh …….Petitioner
V E R S U S
The State …… Respondent
CERTIFICATE
To,
The Registrar, High Court of Delhi. Sher Shah Suri Road, New Delhi. Sir, This is to certify that entire material/ document/ annexures, relied upon and placed on the record are the part of the trial court record and nothing additional has been filed.
Petitioner
Through
Sushil Kr. Sharma & Shahar Alam Beg, Advocates, (Counsel For The Petitioner)
877, Lawyers’ Chambers, Saket Courts, New Delhi- 110017
[email protected] Mob. No.:-9818165785
PLACE: New Delhi DATED: 05.06.2017
BRIEF SYNOPSIS & LIST OF DATES & EVENTS
The Petitioner/ Accused was apprehended/ arrested in this Case
on 25.05.2017. The Case arises out of the FIR No: 0040 of 2015
(Dated: 14/01/2015), PS: Kalyanpuri, U/S: 186/308/332/353/34 OF
IPC, District-East. The Charge Sheet has been filed by the Police
in this Case, and the case is currently pending adjudication in the
Court of Shri N K Laka, CMM, Karkardooma Court, New Delhi, the
same being at the stage of scrutiny of documents. The list of
dates and events forming part of this case are as follows:
LIST OF DATES & EVENTS
14.01.2015 An FIR was registered against the Petitioner/
Accused and his whole family. Five family
members were named in the FIR itself, namely,
(1) Jaswant Singh [(43 years) (Petitioner/
Accused himself)], (2) Rahul [(34 years)
(Brother of the Petitioner/ Accused)], (3)
Rajender Singh [(38 years) (Brother of the
Petitioner/ Accused)], (4) Mahendra Kaur (W/O
Ashoki) [(52 years) (Sister of the Petitioner/
Accused)] and (5) Bhag Singh [(75 years)
(Father of the Petitioner/ Accused)]. Two
neighbors of the Petitioner/ Accused have also
been implicated in this case, namely, (1) Sunny
and (2) Arjun.
The particulars of the FIR are as follows: FIR No:
0040 of 2015 (Dated: 14/01/2015), PS:
Kalyanpuri, U/S: 186/308/332/353/34 OF IPC,
District-East.
25.05.2017 The Applicant/ Accused was arrested by the
Police on 25.05.2017. His Police Custody (PC)
was however not sought by the Police.
26.05.2017 The Applicant/ Accused is in the judicial custody
(JC) since 26.05.2017.
29.05.2017 The Petitioner/ Accused filed his first bail
Application. The Court of Sh. Pulatsya
Paramachala, ASJ, Karkardooma Courts, Delhi,
disposed off the First Bail Application of the
Petitioner/ Accused vide Order dated 29.05.2017
by observing that since the main charge sheet is
pending adjudication before Ms. Ravinder Bedi,
ASJ, therefore the Application/ Accused should
move the Trial Court/ Sessions Court for regular
Bail.
31.05.2017 In this Case, this Hon’ble Court has been
pleased to grant Bail to the co-Accused,
Rajender Singh vide its Order dated 31.05.2017,
as passed by Hon’ble Mr. Justice A K Chawla, in
the Bail Application No.1083 of 2017, titled as
Rajender Singh Versus The State of NCT of
Delhi.
01.06.2017 The Petitioner/ Accused filed his Second bail
Application. The Court of Ms. Ravinder Bedi,
ASJ, Karkardooma Courts, Delhi expressed her
inability to hear the Bail Plea of the Petitioner/
Applicant in the absence of the Charge sheet
qua the Petitioner/ Accused. The Ld. ASJ
disposed off the Second Bail Application of the
Petitioner/ Accused observing that the Case qua
the Petitioner/ Accused was not yet allocated to
her Court.
02.06.2017 The Petitioner/ Accused filed his Third bail
Application. The Court of Sh. Pulatsya
Paramachala, ASJ, Karkardooma Courts, Delhi
disposed off the Third Bail Application vide its
Order dated 02.06.2017, reiterating its
observations, as made in the order dated
29.05.2017.
09.06.2017 The matter before the trial Court (Chief
Metropolitan Magistrate (CMM) is at the stage of
scrutiny of documents and the same is being
listed for 09.06.2017 for the said purpose. The
matter is likely to take its own time before it was
actually committed for trial to the Court of
Additional Sessions Judge (ASJ).
05.06.2017 Hence the present Revision.
In The High Court Of Delhi At New Delhi
Bail Application No. ______ of 2017
In The Matter Of:-
Jaswant Singh …….Petitioner
V E R S U S
The State …… Respondent
Memo of Parties
[In the Case arising out of the FIR No: 0040 of 2015 (Dated: 14/01/2015), PS: Kalyanpuri, U/S: 186/308/332/353/34 OF IPC, District-East, currently pending in the Court of Shri N K Laka, CMM, Karkardooma Court, New Delhi]
Petitioner:-
Mr. Jaswant Singh [Aged Nearly 47 years]
S/o Shri Bhag Singh
R/o House No. 20/80,
Kalyanpuri,
Delhi- 110091
And
Respondent:- The State Through The SHO, PS-Kalyanpuri (District- East) New Delhi
Petitioner
Through
Sushil Kr. Sharma & Shahar Alam Beg, Advocates, (Counsel For The Petitioner)
PLACE: New Delhi DATED: 05.06.2017.
In The High Court Of Delhi At New Delhi
Bail Application No. ______ of 2017
In The Matter Of:-
Jaswant Singh …….Petitioner
V E R S U S
The State …… Respondent
District- East Delhi
PETITION, UNDER SECTION-439, READ WITH SECTION-482 OF
THE CODE OF CRIMINAL PROCEDURE, 1973, FOR GRANT OF BAIL, IN THE CASE ARISING OUT OF THE FIR NO: 0040 OF 2015 (DATED: 14/01/2015), PS: KALYANPURI, U/S: 186/308/332/353/34 OF IPC, DISTRICT- EAST DELHI, CURRENTLY PENDING ADJUDICTION IN THE COURT OF SHRI N. K. LAKA, CMM, KARKARDOOMA COURT, NEW DELHI.
TO,
THE CHIEF JUSTICE AND HIS COMPANION JUSTICES OF HON’BLE HIGH COURT OF DELHI, AT NEW DELHI
THE PETITIONER ABOVENAMED MOST RESPECTFULLY
SHEWETH:
1. That the present Petition has been filed seeking bail in the
Case arising out of the FIR No: 0040 of 2015 (Dated:
14/01/2015), PS: Kalyanpuri, U/S: 186/308/332/353/34 OF
IPC, District-East Delhi, currently pending in the Court of Shri
N. K. Laka, CMM, Karkardooma Court, New Delhi. The copy of
the FIR, along with its English translation is annexed herewith
as ANNEXURE-P-1 (Colly.).
2. That the brief facts of the case leading to the filing of this
Petition are as follows:
3. That the Applicant/ Accused is a law abiding Citizen. He
however, has been falsely implicated by the Police by lodging
against him completely vexatious, false, frivolous and
baseless FIR.
4. That the FIR in question was registered against the
Petitioner/ Accused and his whole family. Five family
members were named in the FIR itself, namely, (1) Jaswant
Singh [(43 years) (Petitioner/ Accused himself)], (2) Rahul
[(34 years) (Brother of the Petitioner/ Accused)], (3)
Rajender Singh [(38 years) (Brother of the Petitioner/
Accused)], (4) Mahendra Kaur (W/O Ashoki) [(52 years)
(Sister of the Petitioner/ Accused)] and (5) Bhag Singh [(75
years) (Father of the Petitioner/ Accused)]. Two neighbors of
the Petitioner/ Accused have also been implicated in this
case, namely, (1) Sunny and (2) Arjun.
5. That the Police did not seek the arrest of the Petitioner/
Accused at any point in time, ever since the date of the
registration of the FIR and till the date he was actually
arrested on 25.05.2017. The fact remains, the house of the
Petitioner/ Accused is at stone’s throw distance from the
Police Station- Kalyanpuri where the FIR stands lodged and
the Petitioner/ Accused earns his living by driving an Auto in
the same locality where the Police Station- Kalyanpuri is
situated.
6. That it would be relevant to mention here in that the
Petitioner/ Accused had his Auto employed in the Election
duty in the recently concluded elections for the Municipal
Corporation in the same area where the Police Station-
Kalyanpuri is situated.
7. That the Police showed in its record the Petitioner/ Accused
an absconder, and procured the necessary Orders under
Sections-82/83 of the Code of Criminal procedure, 1973, just
with malafide intentions and ulterior motives.
8. That the Applicant/Accused was arrested by the Police on
25.05.2017 and he is in the judicial custody since 26.05.2017.
It would be relevant to mention herein that no police custody
(PC) was sought of the Petitioner/ Accused by the Police in
this case.
9. That on 28.05.2017, the Petitioner/ Applicant moved First Bail
Application, U/S- 439 0f the Code of Criminal Procedure,
1973, to the District & Sessions Judge, Karkardooma, Delhi,
which was assigned in due course to the Court of
Sh. Pulatsya Paramachala, ASJ, Karkardooma Courts, Delhi.
After hearing, the Ld. ASJ however disposed off the bail
Application vide Order dated 29.05.2017 by observing that
since the main charge sheet is pending adjudication before
Ms. Ravinder Bedi, ASJ, therefore the Application/ Accused
should move the Trial Court/ Sessions Court for regular Bail.
The copy of the Order dated 29.05.2017 is annexed herewith
as ANNEXURE-P-2 (Colly.).
10. That consequently, the Petitioner/ Accused moved the
Second Bail Application, U/S- 439 0f the Code of Criminal
Procedure, 1973, before the Court of Ms. Ravinder Bedi, ASJ,
Karkardooma Courts, Delhi. However, it transpired before the
Trail Court that the supplementary Charge Sheet qua the
Petitioner/ Accused has been filed before the Chief
Metropolitan Magistrate (CMM), Karkardooma, Delhi and the
matter will next come up for hearing before the Ld. CMM for
the scrutiny of documents on 09.06.2017.
11. That in its Order dated 01.06.2017, the Court of Ms. Ravinder
Bedi, ASJ, Karkardooma Courts, Delhi, while observing that
the Case qua the Petitioner/ Accused was not yet allocated to
her Court, expressed her inability to hear the Bail Plea of the
Petitioner/ Applicant in the absence of the Charge sheet qua
the Petitioner/ Accused. Resultantly, fearing further delay in
the matter, the Counsel for the Petitioner/ Accused opted to
withdraw the Bail Application so as to file the same before
the Court of District & Sessions Judge again, which is the only
Court of competent jurisdiction. The copy of the Order dated
01.06.2017 is annexed herewith as ANNEXURE-P-3.
12. That on 01.06.2017, the Petitioner/ Accused moved the Third
Bail Application to the District & Sessions Judge,
Karkardooma, Delhi, which was again assigned to the Court
of Sh. Pulatsya Paramachala, ASJ, Karkardooma Courts,
Delhi. After hearing, the Court however disposed off the bail
Application vide its Order dated 02.06.2017, reiterating its
observations, as made in the order dated 29.05.2017. The
copy of the Order dated 02.06.2017 is annexed herewith as
ANNEXURE-P-3.
13. That in the meanwhile in the same Case, this Hon’ble Court
has been pleased to grant Bail to the co-Accused, Rajender
Singh vide its Order dated 31.05.2017, as passed by Hon’ble
Mr. Justice A K Chawla, in the Bail Application No.1083 of
2017, titled as Rajender Singh Versus The State of NCT of
Delhi. The copy of the Order dated 31.05.2017 is annexed
herewith as ANNEXURE-P-4.
14. That the fact remains, the matter before the trial Court (Chief
Metropolitan Magistrate (CMM) is at the stage of scrutiny of
documents and the same is being listed for 09.06.2017 for
the said purpose. The matter is likely to take its own time
before it was actually committed for trial to the Court of
Additional Sessions Judge (ASJ).
15. That the investigation in this case is complete, as the Charge
Sheet has already been filed in this matter. Currently the
matter is at the stage of scrutiny of documents and the same
is listed for the same on 09.06.2017.
16. That there is no question of tampering with the evidence in
this case, as the witnesses and the victim in this case are the
Police personnel themselves. Besides, the Accused/Applicant
undertakes not to contact the said Victims/Complainant in
this Case.
17. That the Applicant/ Accused is a permanent resident of Delhi.
He has his family residing permanently in Delhi and has deep
roots in the society. There is no question of he fleeing from
justice or absconding by any stretch of the imagination.
18. That the antecedents of the Petitioner are clean. He belongs
to a respectable family. Prior to this, he has never been
convicted in any Case.
19. That on the top of it all, the Applicant/ Accused is the sole
bread earner of his family and earns his living on daily basis
by driving an auto.
20. That the Trial of the case would take a long time and keeping
the Applicant/Accused in Judicial Custody (JC) would not
serve any fruitful purpose. On the contrary, his whole family
will come on the road if his incarceration prolongs, he being
the sole bread earner of his family.
21. That the Petitioner undertakes to attend the proceedings
before the concerned Court regularly, as and when called
upon to do so, as also join further investigation, if any.
22. That the Accused / Applicant further undertakers to abide by
all the conditions which this Hon’ble court pleases to impose
to enlarge him on bail.
23. That the Petitioner has sought Bail on the following grounds
amongst others:
GROUNDS
A. BECAUSE the Petitioner/ Accused is behind the bars
since 25.05.2017, for nearly 12 days.
B. BECAUSE the Case of the Police is highly improbable
by its very nature, as the FIR in question was
registered against the Petitioner/ Accused, his whole
family and the neighbors.
C. BECAUSE the Police did not seek the arrest of the
Petitioner/ Accused at any point in time since the
date of the registration of the FIR and till the date
he was actually arrested on 25.05.2017 with
malafide intentions and ulterior motives.
D. BECAUSE the Court below, i.e. the Court of Sh.
Pulatsya Paramachala, ASJ, Karkardooma Courts,
Delhi gravely erred while directing the Petitioner/
Accused to move for bail the Trial Court/ Sessions
Court.
E. BECAUSE the Ld. ASJ (Sh. Pulatsya Paramachala,
ASJ, Karkardooma Courts, Delhi) disregarded the
observations, as made in the order dated
01.06.2017, as passed by Ms. Ravinder Bedi, ASJ,
wherein she had unambiguously noted that the
Case/ Charge sheet of the Petitioner/ Accused was
not allocated to her.
F. BECAUSE the Ld. ASJ (Sh. Pulatsya Paramachala,
ASJ, Karkardooma Courts, Delhi) further overlooked
the submission of the Counsel of the Petitioner/
Accused wherein he had highlighted the fact that
the matter/ Case of the Petitioner/ Accused was
listed before the concerned Court of Chief
Metropolitan Magistrate (CMM) on 09.06.2017 for
scrutiny of documents/ chargesheet.
G. BECAUSE the Court below, i.e. the Court of Sh.
Pulatsya Paramachala, ASJ, Karkardooma Courts,
Delhi has refused to exercise its jurisdiction, while
refusing to hear the Bail Plea of Petitioner/ Accused
on the merit of the Case.
H. BECAUSE the Court below, i.e. the Court of Sh.
Pulatsya Paramachala, ASJ, Karkardooma Courts,
Delhi has exceeded its jurisdiction, while directing
the Petitioner/ Accused to move for bail the Trial
Court/ Sessons Court.
I. BECAUSE this Hon’ble Court has been pleased to
grant Bail to the co-Accused, Rajender Singh vide its
Order dated 31.05.2017.
J. BECAUSE had the Ld. the Court of Sh. Pulatsya
Paramachala, ASJ, heard the Counsel for the
Petitioner on the merit of the Case, a very vital
factum of passing of order by this Hon’ble Court on
the Bail Application of the Co-Accused could also
have been pleaded. Needless to say, the Order of
this Hon’ble Court could have impacted the very
root of the whole matter before the Ld. ASJ.
K. BECAUSE the matter before the trial Court (Chief
Metropolitan Magistrate (CMM) is at the stage of
scrutiny of documents and the same is being listed
for 09.06.2017 for the said purpose. The matter is
likely to take its own time before it was actually
committed for trial to the Court of Additional
Sessions Judge (ASJ).
L. BECAUSE the investigation in this case is complete,
as the Charge Sheet has already been filed in this
matter.
M. BECAUSE the Petitioner/ Accused is no longer
required in this Case, as no police custody (PC) was
sought of the Petitioner/ Accused by the Police in
this case.
N. BECAUSE there is no question of tampering with the
evidence in this case, as the witnesses and the
victims in this case are the Police personnel
themselves.
O. BECAUSE the Applicant/ Accused is a permanent
resident of Delhi. He has his family residing
permanently in Delhi and has deep roots in the
society. There is no question him fleeing from
justice or absconding by any stretch of the
imagination.
P. BECAUSE the antecedents of the Petitioner are
clean. He belongs to a respectable family. Prior to
this, he has never been convicted in any Case.
Q. BECAUSE on the top of it all, the Applicant/ Accused
is the sole bread earner of his family and earns his
living on daily basis by driving an auto. His whole
family of the Petitioner/Accused will come on the
road if his incarceration prolongs, he being the sole
bread earner of his family.
R. BECAUSE the Trial of the case would take a long
time and keeping the Petitioner/Accused in Judicial
Custody (JC) would not serve any fruitful purpose.
24. The petitioner craves leave to add, alter, amend, modify,
delete and/or substitute any of the contents/ grounds of
this Petition, as and when required.
25. That this Petition is maintainable, as this Hon’ble Court
solely commands the jurisdiction to adjudicate and decide
on the subject matter of this Petition.
26. That there is no efficacious and alternative remedy available
to the Petitioner/ Accused, except for the filing of this
Petition, in the given facts and circumstances of this case.
27. That this Petition is within the period of limitation, as
provided under the statute. There has been no delay in
filing the same.
28. That all the documents accompanying this Petiton forms
part and parcel of the Trial Court Record.
29. That no Petition of this nature is pending before this Hon’ble
Court or any other Court including the Hon’ble Supreme
Court of India.
PRAYER
It is therefore most respectfully prayed that this Hon’ble Court
may be pleased to;
a. Enlarge the Petitioner on bail, in the Case arising out of the
FIR No: 0040 of 2015 (Dated: 14/01/2015), PS: Kalyanpuri,
U/S: 186/308/332/353/34 OF IPC, District-East Delhi,
currently pending in the Court of Shri N. K. Laka, CMM,
Karkardooma Court, New Delhi, subject to whatever
conditions which this Hon’ble Court deemed fit in the facts
and circumstances of this Case.
b. Pass any other and / or further order(s) in favour of the
Petitioner, which this Hon’ble Court may deem fit and
proper in the interest of Justice and fair play.
Petitioner [In Judicial Custody]
[Through Perokar] Through
Sushil Kr. Sharma & Shahar Alam Beg, Advocates, (Counsel For The Petitioner)
877, Lawyers’ Chambers, Saket Courts, New Delhi- 110017
[email protected] Mob. No.:-9818165785
PLACE: New Delhi DATED: 05.06.2017
THE HIGH COURT OF DELHI AT NEW DELHI
Bail Application No. ______ of 2017
IN THE MATTER OF:
Jaswant Singh …….Petitioner
V E R S U S
The State …… Respondent
AFFIDAVIT
AFFIDAVIT OF MR. SACHIN, S/O SHRI JASWANT SINGH, AGED NEARLY ____ YEARS, HOUSE NO. 20/80, KALYANPURI, DELHI- 110091. I, the Deponent, do hereby solemnly affirm and declare as under:-
1. That I am the Son and a Perokar of the Petitioner/ Accused
in the above noted/ accompanying Bail Petition U/S- 439,
R/W S-482 of the Code of Criminal Procedure, 1973, and
therefore am competent to file this Affidavit in support of
the Petition.
2. That the accompanying Petition has been drafted by my
counsel as per joint instructions of mine and my father and
has been read over to me in a vernacular language. I have
fully understood the contents of the Petition. I also found
the contents of this Petition to be true and correct.
DEPONENT
VERIFICATION:- Verified at Delhi on 05th day of June, 2017 that the contents of
the above noted affidavit are true and correct to my knowledge
and belief, based on what has been told about the case by my
father to me, and nothing material has been concealed there
from.
DEPONENT
THE HIGH COURT OF DELHI AT NEW DELHI
Bail Application No. ______ of 2017 IN THE MATTER OF:
Jaswant Singh …….Petitioner
V E R S U S
The State …… Respondent
APPLICATION UNDER SECTION-482 OF THE CODE OF
CRIMINAL PROCEDURE, 1973, SEEKING EXEMPTION
FROM FILING CERTIFIED COPY OF THE DOCUMENTS/
ANNEXURES.
MOST RESPECTFULLY SUBMITTED AS UNDER:
1. That the Petitioner has filed along with the Captioned
Petition uncertified copy of the documents.
2. That the Petitioner could not file the certified copy of the
Documents/ Annexures, annexed with the Petition due to
paucity of time.
3. That the Petitioner undertakes to file the certified copy on
the record of this Hon’ble court, in the event of any
opposition from the opposite party(ies) qua their contents
and/ or as and when directed by this Hon’ble Court to do
so.
4. That the Petitioner therefore humbly seek to be exempted
from filing the certified copy of the impugned Documents/
Annexures.
PRAYER It is therefore most respectfully prayed that this Hon’ble Court may be pleased to:- a. Exempt the Petitioner from filing certified copy of the
Impugned documents/ annexures.
b. Pass any other and / or further order(s) in the favour of the
Petitioner, which this Hon’ble Court may deem fit and
proper in the interest of Justice and fair play.
Petitioner
Through
Sushil Kr. Sharma & Shahar Alam Beg, Advocates, (Counsel For The Petitioner)
877, Lawyers’ Chambers, Saket Courts, New Delhi- 110017
[email protected] Mob. No.:-9818165785
PLACE: New Delhi DATED: 05.06.2017
THE HIGH COURT OF DELHI AT NEW DELHI
Bail Application No. ______ of 2017
IN THE MATTER OF:
Jaswant Singh …….Petitioner
V E R S U S
The State …… Respondent
AFFIDAVIT
AFFIDAVIT OF MR. SACHIN, S/O SHRI JASWANT SINGH, AGED NEARLY ____ YEARS, HOUSE NO. 20/80, KALYANPURI, DELHI- 110091. I, the Deponent, do hereby solemnly affirm and declare as under:-
1. That I am the Son and a Perokar of the Petitioner/ Accused
in the above noted/ accompanying Bail Petition U/S- 439,
R/W S-482 of the Code of Criminal Procedure, 1973, and
therefore am competent to file this Affidavit in support of
the Petition.
2. That the accompanying Application, seeking exemption from
filing certified copy of the impugned documents/ annexures
has been drafted by my counsel as per joint instructions of
mine and my father and has been read over to me in a
vernacular language. I have fully understood the contents
of the Petition. I also found the contents of this Petition to
be true and correct.
DEPONENT
VERIFICATION:- Verified at Delhi on 05th day of June, 2017 that the contents of
the above noted affidavit are true and correct to my knowledge
and belief, based on what has been told about the case by my
father to me, and nothing material has been concealed there
from.
DEPONENT
In The High Court Of Delhi At New Delhi
Bail Application No. ______ of 2017
In The Matter Of:-
Jaswant Singh …….Petitioner
V E R S U S
The State …… Respondent
To,
The Registrar, High Court of Delhi. Sher Shah Suri Road, New Delhi.
Letter of Authorisation Sir, I, the undersigned, hereby authorize my Clerk, Mukund Narayan Sharma, whose signatures are encircled below, to collect the copy of the Dasti Order in the captioned case.
Kindly oblise me by handing out the copy of the order to my Clerk.
Petitioner
Through
Sushil Kr. Sharma & Shahar Alam Beg, Advocates, (Counsel For The Petitioner)
877, Lawyers’ Chambers, Saket Courts, New Delhi- 110017
[email protected] Mob. No.:-9818165785
PLACE: New Delhi DATED: 13.06.2017
CODE OF CRIMINAL PROCEDURE, 1973 CHAPTER XXXVII: MISCELLANEOUS
Section-482. Saving of inherent power of High Court.- Nothing in this Code shall be deemed to limit or affect the inherent powers of the High Court to make such orders as may be necessary to give effect to any order under this Code, or to prevent abuse of the process of any Court or otherwise to secure the ends of justice.
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