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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
……….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,
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.
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
Dated:
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
……….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
2. Supporting Affidavit
3. Addhar Card
file. Dated:
Through counsel Petitioner/Accused
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
……….Respondent
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