District: North 24 Parganas.

Before the Ld. Additional Chief Judicial Magistrate at Barasat.

Ref :- G.R. Case No. 2384 of 2018

(Arising out of Madhyamgram P.S. Case No-697 /2018)
[U/S 14(a) of Foreigners (Amendment) Act, 2004]

In the matter of: -

State
……. Complainant.
APPLICATION FOR
PLEA BARGAINING ----------Vs----------

Dip Saha
………… Accused.

The humble petition Under Section 265B (2),

Code of Criminal Procedure, 1973 on behalf
of the above named Accused Persons.

Most Respectfully Sheweth:-

1. That I have read/been read over the complaint/charge sheet filed against
me for the alleged offence (s) punishable under Section 14(a) of
Foreigners (Amendment) Act, 2004.
2. That I have also been read-over and explained the charge(s) against me.
3. That I have also been informed by the learned Magistrate that for the
alleged offences, the statutory minimum prescribed punishment on the
score.
4. That I have not been previously held guilty and convicted by any court
for the offences(s) with which I am now charged.
5. That in the circumstances I voluntarily wish to avail the benefit of plea
bargaining.
6. That the affidavit required under Section 265B (2) duly sworn by me is
appended to this application. Contd……..2

-2-
 7. That the Accused Persons will abide by all terms and conditions of this
Ld. Court.
8. That this Application/Petition is made bona-fide and for the ends of
Justice.
Hence it is respectfully prayed that the Ld.
Court would be graciously pleased to grant
this application and permit me to avail the
benefit of PLEA-BARGAINING, for the ends
of Justice and/or pass such other order / orders
as Your Honour may deem fit and proper.
And for this act of kindness your Petitioner as in duty bound shall ever pray.

VERIFICATION

Verified this by DIP SAHA, the accused herein this instant case No.
2384/2018, do hereby declare that I am well conversant with the statements
made in the above Petition, where the Paragraphs 1 to 8 are true to the best
of my knowledge and belief including the facts/information which are on
record and the rests are my humble submission before the Ld. Court. I am
signing this Verification on this ___ day of ___________________, 2019
after understand and verify the contents as I directed my Advocate for
preparing this PLEA BARGAINING Petition and accordingly he reduced to
writing the same in English according to my said direction and suggestion to
my satisfaction.

(DEPONENT)
Prepared in my Office Known to me, identified by me

Advocate
Advocate.

Contd……..3
-3-
 AFFIDAVIT

I, DIP SAHA, son of Late Himanshu Kumar Saha,

Petitioner/Accused, herein this instant Case, aged about 22 years, by
religion Hindu, by Nationality Bangladeshi, my Occupation Daily
Labour, residing at Village Katputty, Udhbodhan School Road, P.S. &
District Jhalokati, Country Bangladesh, do hereby solemnly affirm and
state as follows:-

a) I am as the Accused, herein, well conversant with

the facts and circumstances of this instant Case; and

b) the statements made in the above PLEA BARGAINING

Petition, where the Paragraphs 1 to 8 are true to the best of my
knowledge and belief including the facts/information which are
on record and the rests are my humble submission before the Ld.
Court.

(DEPONENT)
Identified by me and certified
that the contents of the
Affidavit has been read over
and also explained to the
Deponent and that the
Deponent has signed the same
after admitting that it has been
correctly drafted by me as per
his instructions.

Advocate.