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IN THE HIGH COURT OF DELHI, AT NEW DELHI

BAIL APPLICATION NO. Of 2019

Ravi Yadav S/o Dulichand Yadav aged about 30 years R/o Dinanathpuri,
Puthi Dasna, Dehat, Ghaziabad, Hindan Nagar, U.P.201302

……….Petitioner/Accused

V/S

STATE through NCT of Delhi

……….Respondent

FIR

No.332/13.2.2019
Under Section 392,397,365,341/34 IPC, 25 ARMS Act
PS, Mandawali, New Delhi

Second application for bail under section 439 CRPC for release of
above petitioner on bail.

Sir/Madam,

The petitioner/accused above name submit as follows:

1. That the above noted case is pending for 6.5 2019 in the court
of Shri S.K Sharma, ASJ Karkardooma for appearance.

2. That the Petitioner has been falsely involved in the above noted
case and on unfounded suspicion and only on the basis of
disclosure statement of the co-accused and now he is in
custody for more than 6 months as per the case of prosecution
3. That according to the allegation in the FIR on 12.9.2018 at
about
2.30 p.m. complainant Piyush Virmani had come to Delhi
from Faridabad for receiving his friend and when he reached
on Akshardham Road then his friend had sent the location. At
about 1.30 a.m. one Silver Colour Vehicle came and stopped
his vehicle out of which 4 boys have been alighted and
entered in his car and put him on the rear seat thereafter
they asked him to transfer the money in his account from his
friend and he called his friend Latesh Shah and amount was
transferred in his bank account. During this he called his
parents after some time they asked to get filled the petrol
from his Paytm and asked about the PIN of his ATM and
withdrew Rs.52,000/- his watch and sim card were also
taken by them. They made his got down at Neelam Ajronda
Metro Station at about 5.15 a.m. and took away his vehicle
bearing Registration No. HR51 BE 0999.

4. That admittedly the petitioner has not named in the FIR nor any
description i.e. age, height, colour etc. were given and that even
in the test identification parade the complainant did not identified
the petitioner.

5. That there is no recovery of any vehicle from the petitioner.

6. That the first bail application has been rejected by the Mrs.
Nisha, then ASJ, Karkardooma Courts without appreciating the
merits of the application and without proper reasoning.
7. That no other case is pending against the petitioner/accused and
there is no legal and admissible evidence to connect the
petitioner with the present case.

8. That the trial of the case will take a long time. No useful purpose
will be served by keeping the Petitioner in Judicial Lock Up as a
measure of punishment before trial.

PRAYER

It is therefore prayer that the Petitioner may be ordered to be


released on bail pending trial of the case.

Dated:

Through counsel Petitioner/Accused


Sanjeev Jain Ravi Yadav S/o
Peeyush Jain Dulichand Yadav
Advocates – Delhi High Court R/o
Deenanathpuri,
Ghaziabad – U.P.
201302
IN THE HIGH COURT OF DELHI, AT NEW DELHI
BAIL APPLICATION NO. Of 2019

Ravi Yadav S/o Dulichand Yadav aged about 30 years R/o Dinanathpuri,
Puthi Dasna, Dehat, Ghaziabad, Hindan Nagar, U.P.201302
……….Petitioner/Accused

V/S

STATE through NCT of Delhi

……….Respondent

FIR

No.332/13.2.2019
Under Section 392,397,365,341/34 IPC, 25 ARMS Act
PS, Mandawali, New Delhi

Second application for bail under section 439 CRPC for release of
above petitioner on bail.

INDEX

S.No. Particulars Page Nos.

1. Application for bail

2. Supporting Affidavit

3. Addhar Card

NOTE: Vakalatnama already attached with the main case

file. Dated:
Through counsel Petitioner/Accused

Sanjeev Jain Ravi Yadav S/o


Peeyush Jain Dulichand Yadav
Advocates – Delhi High Court R/o Deenanathpuri,
Ghaziabad –
U.P.201302
IN THE HIGH COURT OF DELHI, AT NEW DELHI
BAIL APPLICATION NO. Of 2019

Ravi Yadav S/o Dulichand Yadav aged about 30 years R/o Dinanathpuri,
Puthi Dasna, Dehat, Ghaziabad, Hindan Nagar, U.P.201302
……….Petitioner/Accused

V/S

STATE through NCT of Delhi

……….Respondent

Application Under Section 439 CRPC for release of Petitioner on bail


AFFIDAVIT

1. Affidavit of Mohd. Imran, S/o Akbar Ali, do hereby solemnly


affirm and declare as under:

2. That this is the Second application of bail under Section 439


CRPC filed by the counsel of Ravi Yadav as per my instance
and document provided to the counsel and no other bail
application is pending in any Court of Law.

DEPONENT
VERIFICATION
Verified that the contents of the Affidavit are true and correct to
the best of my knowledge and nothing has been concealed therein at
all.

Dated:
Place : Anand Vihar, New Delhi DEPONENT

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