IN THE COURT OF DISTRICT & PRINCIPAL SESSIONS JUDGE AT CHINGLEPUT Crl.M.P.No. 1) A.S.Thangam - M/A 58 S/o.D.

Antony Muthu, 59, Late View Road, West Mambalam, Chennai-600 033. C.Antony, S/o.Chinnakutty, 18, Kalaivani Street, Keelkattalai, Chennai-600 117. Vs State by : The Inspector of Police, Central Crime Branch, St.Thomas Mount, Chennai-600 016. of 2010

2)

Petitioners

Respondent

ANTICIPATORY BAIL PETITION FILED U/S 438 Cr.P.C. The petitioners submit as follows : Address for service of the petitioners is to that of their counsels M/s.V.GABRIAL & T.RAVI DEVAN Advocates office at No.18, Nehru Nagar, G.S.T. Road, West Tambaram, Chennai-600 0450. 1) The petitioners apprehend arrest by the respondent police for

the alleged offences u/s 420 I.P.C. They are innocent of the alleged offences and in no way connected with the case. 2) The case of the prosecution is that the defacto complainant

one Mr.Senthil Kumar S/o.Kondiah lodged a complaint before the respondent police against Mr.Chinnakutty and his son Mr.Rajendran with regard to a Sale Agreement dated 31.07.2008, wherein the petitioners are entered as witnesses when dispute arose the vendors failed to written the advance sum and hence the FIR.

2 3) It is submitted that Thiru.Chinnakutty and his son

Mr.C.Rajendran of Keelkattalai Village had entered into a sale agreement in respect of selling the schedule of property entered in agreement in Keelkattalai Village, Town Survey No:84, Patta No: 1946, door No: 18 after comprised of schedule of property, with the defacto complainant Senthil Kumar who paid an advance of 11 lakhs to the said Rejendran. 4) It is submitted that due to difference of opinion the sale was

not effected between the vendors and intending purchaser Senthil Kumar and the defacto complainant was attempted to trespass into the property an injunction suit was filed by Chinnakutty & Rajendran before the District Municif Court, Alandur, which is still pending. Since the said vendors failed to return the advance amount to the defacto complaint, he lodged a complaint before the Assistant Commissioner of Police, Madipakkam. Now, it is reliably learnt that the defacto complainant lodged another complainant before the Commissioner of Police, Thomas Mount, Chennai16 to initiate action against the said ChinnaKutty & Rajendran and the same was forwarded to the Inspector of Police (Crime). Team 1, Chennai16. 5) It is submitted that in the sale agreement the petitioners are

signed as witnesses and they are in no way connected with the money transaction and they are not binding upon the contractual obligations between the paid vendors and the defacto complainant. 6) It is submitted that the Honble High Court of Madras was

pleased to grant Anticipatory Bail to the said Chinnakutty & Rajendran in

3 Crl.O.P.No.23070 / 2010 on 1.10.2010 in Cr No. unknown / 2010, arraigned the A.C of Police and the Inspector of Police, Madipakkam P.S., Chennai-91. 7) The petitioners are the law abiding citizens and no bad they will be humiliated

antecedents of any kind. If they are arrested unnecessarily. 8)

It is submitted that they are permanent residence of Chennai

and ready to oblige any conditions imposed by this Honble Court in the event of Bail.
9) No similar bail petition is filed before the High Court of Madras or any other Court and this is the first Anticipatory bail petition filed by the petitioners before this Honble Court.

Therefore, it is humbly prayed that this Honble Court may be pleased to enlarge the petitioner on bail in the event of their arrest by the respondent police in Crime No unknown / 2010 on the file of the

respondent pending investigation and thus render justice.

Dated at Chinglepet on this 11th day of November, 2010

COUNSEL FOR PETITIONERS

N.B : Bail to the satisfaction of Judicial Megistrate Court Alandur

IN THE COURT OF THE HONBLE PRINCIPAL SESSIONS JUDGE AT CHENNAI Crl. M.P.No.10741of 2010 in CCB Crime No.286/ 2009 (on the file of the CCB, Egmore, Chennai) Ponraj S/o. Soundrapandian Vs State by Sub Inspector of Police C.C.B., Egmore, Chennai (Crime No. 286 of 2009)

Petitioner

Respondent

PETITION FOR EXTENSION OF TIME FOR EXECUTING THE SURETIES

Address for service of the petitioners is to that of their counsels M/s.N. GANESH KUMAR & S. KUOTHUNGAN & S. RAJA Advocates office at No.258, New Addl. Law Chambers, Highcourt Buildigs, Chennai600 104.

The petitioner above named humbly submit and begs to state as follows :

1. The petitioner submits that he had pleaded the Honble Court to grant him Anticipatory Bail apprehending his arrest in C.C.B. Crime No. 286 of 2009 of C.C.B., Egmore. The Honble Court considering the relevant facts and materials of the case has granted anticipatory bail in the Criminal M.P.No.10741 of 2010 on the 11th day of November 2010.

2 2. The Honble Court has granted the Anticipatory Bail with the condition that the petitioner should produce the two sureties to who shall execute a bond for Rs. 3000/- each and also to appear before the respondent police on Monday and Friday at 10.30 a.m. for one week and also to make him available before the respondent police as and when required and all the same should be done by 22.11.2010 by the petitioner surrendering himself before the Honble Chief Metropolitan Magistrate. 3. Due to some unforeseen circumstances the petitioner was not able to produce the adequate sureties as per the order of the Honble Court. 4. The delay in executing the sureties is neither willing or wanton. 5. Considering the pathetic condition of the petitioner we humbly pray this Honble Court to kindly condone the delay in executing the sureties. 6. Therefore, I humbly pray this Honble Court to kindly order for the grant of extension of time for executing the sureties and pass such further or other orders as this Honble Court may deem fit and proper in the circumstances of the case and thus render justice.

Dated at Chennai this the

th

day of November, 2010

COUNSEL FOR PETITIONER

IN THE COURT OF THE CHIEF METROPOLITAL MAGISTRATE, EGMORE AT CHENNAI

Crl. M.P.No. In Crl. M.P.No.3525 of 2010 in Crime No. 511 of 2010 of 2010

Abdul Kadhar Petitioner / Accused - 1 -VsThe State Rep. By its The Inspector of Police CCB, XI Wing, Egmore. Chennai. (Crime No. 511 of 2010) Respondent / Complainant

PETITION TO RELAX THE BAIL CONDITION

M/s. N. GANESH KUMAR & S.KULOTHUNGAN Counsel For Petitioner / Accused - 1

IN THE COURT OF THE JUDICIAL MAGISTRATE AT AMBATHUR Crl. M.P.No. Crime No. Thirunavukarasu Vs State by Inspector of Police V-3 Police Station (Crime No. 1058 of 2010 in 1058 of 2010 of 2010 Petitioner

Respondent

PETITION U/S 452 OF Cr.P.C. FOR RETURN OF PROPERTY

M/s. N. GANESH KUMAR & S.KULOTHUNGAN COUNSEL FOR PETITIONER