In,

The Court of District & Session Judge

Gaya.

A.B.P. No._________/2020

(Arising out Chandauti P.S. Case no. 96/2020, State verses Ravi Kewat
& Others, U/S 341,504,506,323,307/34, of I.P.C. and 27 Arms Act,
pending in the court of C.J.M. Gaya).

1. Ravi Kewat alies Ravi Kumar

2. Govind Kewat alias Abhishek Kumar

Both s/o of Pappu Kewat r/o Village Kandi P.S. Chandauti, District
Gaya .....................................................................................Petitioners

Versus

The State of Bihar...........................................................Opposite

Party

The humble anticipatory bail

petition on behalf of
petitioners namely aforesaid
under section 438(2) of Cr.P.C.

Most respectfully showeth:-

1. That the petitioners have apprehension of arrest from the
hands of police for no fault hence petitioners have preferred
anticipatory bail before your honour’s court.
2. That earlier no anticipatory nor any regular bail petition has
been filed on behalf of the petitioners either before this
learned court or before any other superior court.

3. That the petitioners having no criminal antecedent.

4. That the prosecution story in brief is that on 31.05.2020 at

about 7: 20 hrs the informant of the case was returning home
from Kandi Nawada by-pass mod, when suddenly four persons
on two motorcycle came and started abusing the informant
and they even assaulted upon the informant by fists and slaps.

5. That the informant further states that upon the protest of the
informant petitioner no. 1 and 2 and two unknown persons
started assaulting the informant and thereafter petitioner no. 2
i.e., Goving Kewat fired pistol which passed away from besides
the informant and thereafter the informant fell down on the
ground, then accused no. 1 started firing bullets upon the
informant.

6. That the informant further states that thereafter the cousin

brother of the informant namely Satyendra Kumar S/o Sitaram
Yadav heard the firing sound and came on the spot and seeing
Satyendra Kumar on the spot the unknown co-accused persons
of the case started firing bullets at him. It is further mentioned
by the informant in his written report that accused persons of
this case have also fired bullets near Suresh Prasad and Pintoo
 Prasad Houses in New By-Pass colony due to which the said
colony people are very frightened.

7. That the petitioners are innocent and have been falsely

implicated into this case.

8. That no incriminating article or no any fire arm has been

recovered by police from the physical possession of the
petitioners.

9. That on the alleged date from about 4:00 PM to 8:00 PM the

petitioners were at Khizersarai Police Station, as they had gone
to meet ASI Ashok Chaudhary and the same has been recorded
in cctv camera of Khizersarai Police station.

10. That on the alleged day at about 8:40 PM when the

petitioners were returning home from Khizersarai police
station, the police officers of Buniyadganj had stopped the
petitioner and checked his vehicle and even took a picture of
him in the course of vehicle checking.

11. That there is a dispute of land between the informant’s

brother and the petitioners and hence the instant case has
been lodged by the informant just with a viw to put pressure
upon the petitioners.

12. That the informant’s cousin brother namely Satyendra

Kumar s/o Sitaram Yadav has blocked the passage/ pathway of
the petitioners land and are trying to forcefully acquire the land
belonging to the petitioners.
13. That the informant’s cousin brother Satyender Yadav is in
collusion with anti-social persons and in the past he has several
times threatened the petitioners to implicate them in false case
and the instant case is the result of said threat.

14. That the informant in his written report has stated that
several bullets have been shot on place of occurrence by
petitioners and co-accused persons of this case but as a matter
of fact the seizure list states that only 1 khoka has been
recovered by police.

15. That the seizure list witness namely Suresh Prasad has
presented an affidavit before Learned C.J.M. Gaya stating
therein that no incident took place in front of him and hence
there is every chance of manipulation in this case.

16. That there is no chance for the petitioners to abscond or

to tamper the evidences of the case.

17. That the petitioners being law abiding citizen are ready to
obey all conditions as laid down u/s 438(2) of Cr.P.C.

18. That the petitioners are ready to furnish bail bond of any
reasonable amount.

It is, therefore, prayed that your

honour may kindly be pleased to
 enlarge the petitioners on
anticipatory bail.

And for this the petitioners shall ever pray.