I, Mahabeer aged about 68 years son of Shri Samjhawan resident of Atardasha, Shukul Dulacha, Deara, District - Sultanpur, Religion – Hindu, Education – Literate, Occupation – ____________, do hereby solemnly affirm and state on oath as under:- That the deponent is the father/ pairokar of the applicant and duly authorized by the applicant to file the aforesaid application before this Hon'ble Court and as such he is fully conversant with the facts of the case and deposed as under. The ID Proof of the deponent is enclosed and his photograph is affixed to the affidavit. That this is the first bail application before this Hon'ble Court. No any other bail application is pending before this Hon'ble Court or rejected by this Hon'ble Court. That the instant matter is not related to CBI/Prevention of Corruption Act/ Enforcement Directorate /matters relating to NRHM Scam / GPF Scam/matters of MP/MLA etc. That brief fact of the case is that a first information report was lodged against the applicant and his wife on 31.12.2023 at 11.54 hours by the informant namely Sonu Yadav son of Suryabali Yadav resident of Village - Bhartipur, Police Station - Motigarpur, District - Sultanpur (hereinafter referred to as ‘informant’) bearing Case Crime No. 388 of 2023 under Section 308, 504 I.P.C. at Police Station – Motigarpur, District – Sultanpur regarding the incident dated 30.12.2023. The certified copy of the first information report dated 31.12.2023 is being annexed herewith as Annexure No. 01 to this affidavit. That according to the first information report lodged on 31.12.2023, the prosecution story is in a nutshell that due to a land dispute the applicant and his wife were abused and beaten the nephew of the informant namely Pramod Yadav (hereinafter referred to as ‘deceased’) due to which he sustained the injuries, who is under treatment. That the version of the first information report is totally false and baseless and the same depends upon the concocted story as such nothing happened as alleged by the informant in his first informant report. That the first information report dated 31.12.2023 lodged by the informant to save the deceased and his brother, who were themselves attacked upon the applicant and his wife in retaliation as a counterblast to the first information report lodged by the applicant against the deceased and his brother regarding the same incident bearing Case Crime No. 5 of 2024 under Sections 323, 504, 506, of I.P.C. registered at Police Station – Motigarpur, District – Sultanpur. The photocopy of the first information report lodged by the applicant against the deceased and another is being annexed herewith as Annexure No. 02 to this affidavit. That the Investigating Officer recorded the statement of the informant under Section 161  Cr.P.C. on 01.01.2024 in which the informant repeated his first information report version. The typed copy of the statement of the informant dated 01.01.2024 is being annexed herewith as Annexure No. 03 to this affidavit. That on 09.01.2024, during the treatment, the deceased died and the informant moved an application for taking action against the applicant and his wife thereafter the Investigating Officer added Section 323 & 304 of I.P.C. and deleted Section 308 of I.P.C. on 10.01.2024. That the body of the deceased was brought to the KGMU Mortuary, Lucknow for conducting the post-mortem on 10.01.2024, where the post-mortem was conducted and the cause of the death was ascertained as ‘antemortem head injury as noted”. The photocopy of the post-mortem report of the deceased dated 10.01.2024 is being annexed herewith as Annexure No. 04 to this affidavit. That the Investigating Officer recorded the further statement of the informant under Section 161  Cr.P.C. on 11.01.2024 in which the informant changed the version of his first information report version and tried to put gravity in his statement for falsely implicating the applicant and his wife. The typed copy of the further statement of the informant dated 11.01.2024 is being annexed herewith as Annexure No. 05 to this affidavit. That it was very strange that when the Investigating Officer asked the names of the witnesses, then he denied it on the ground that he was sad and not able to tell the names of the witnesses, whereas, after the death of the deceased, he moved an application on 10.01.2024 and gave a further statement on 11.01.2024. That the applicant and his wife were arrested by the concerned police on 11.01.2024 from their home but for showing his good work, their arrest was shown from another place in a forged and fabricated arresting cum recovery memo dated 11.01.2024. That thereafter, the confessional statements of the applicant and his wife have been written/ prepared by the Investigating Officer on 11.01.2024 as per his wish and tried their best to collaborate with the alleged incident and witnesses under section 161 Cr.P.C. only to prove the offense against the applicant whereas the applicant has not committed any offense. The typed copy of the confessional statement of the applicant and his wife dated 11.01.2024 is being annexed herewith as Annexure No. 06 to this affidavit. That it is most humbly submitted that the applicant is innocent and she has falsely been implicated by the informant in the instant case and there is no evidentiary value in the eye of the law relating to the confessional statements given by the applicant and his wife. That the real story is that the applicant’s fife has two sisters and no brother and their mother also expired. That the sister-in-law of the applicant resides at her marital house and not taking care of her father. That the father of the applicant’s mother executed a WILL deed of his entire movable and immovable properties in favour of the applicant on 26.05.2023. The photo/typed copy of the WILL deed dated 26.05.2023 is being annexed herewith as Annexure No. 07 to this affidavit. That after the execution of the WILL deed in favour of the applicant’s wife, her sister & her sons were not happy with the applicant and her family members. That the sister of the applicant’s wife and her sons, on several occasions, fought with her father to get half share in the property but the same was not given to her by the father of the applicant’s wife. That thereafter, the sister and her sons had enmity with the applicant’s wife and his wife and were given the threat to face consequences of the same. As a result of the same, on 30.12.2023, the deceased and his brother beat the applicant & his wife. That during the manhandling, both parties were injured, in which the applicant and his wife sustained the injuries. The photo/typed copy of the injury report of the applicant and his wife are being annexed herewith as Annexure No. 08 to this affidavit. That 09.01.2024 the deceased died thereafter, the gravity of the case has been shifted to the applicant and his wife due to extraneous reasons, best known by the informant and concerned police, the applicant has been falsely implicated in said case crime. That the prosecution's story is unbelievable and beyond the imagination as the informant and other witnesses have explained the story of the police informar. That the post-mortem report also did not collaborate with the prosecution's story, which clearly shows that the applicant is falsely implicated in this case crime. That due to malafide intention, the informant for extraneous reasons, was falsely implicated in the first information report after knowing everything about the incident, while she has not committed any offense as alleged against her. That the applicant has no concern with the murder of the deceased in any manner as alleged by the informant and the allegation against the applicant along with the prosecution story is totally against truth and is not reliable in manner. That neither the applicant has a motive nor has any reasonable motive been assigned to him to commit the crime in question. That neither nothing has been recovered from the application possession nor pointing of him, which shows that the applicant has not committed the case crime as alleged against him. That there is no credible evidence on record that could show that the applicant is guilty or committed the crime in question and the evidence available on the record itself shows that no prima-facie offense under Sections 323, 304, 504 of I.P.C. at Police Station – Motigarpur, District – Sultanpur is made out against the applicant. That the only general allegations have been assigned against the applicant and no any role has been assigned to the applicant regarding the accident. That the deceased and his brother themselves had a strong motive and with the intention of murder the applicant attacked upon the applicant and in saving the applicant, the deceased also sustained injuries. That the co-accused i.e. wife of the applicant, moved a bail application before this Hon'ble High Court bearing Crl. Misc. Case No. 3190 (B) 2024 (Reetu Yadav Versus State of U.P.), in which the wife of the applicant was granted bail by this Hon'ble High Court vide its order dated 21.03.2024. The photocopy of the order dated 21.03.2024 passed by this Hon'ble High Court is being annexed herewith as Annexure No. 9 to this affidavit. That the applicant moved bail application No. 861 of 2024 before the learned Sessions Judge, Sultanpur and her bail application was rejected by the court concerned on 06.04.2024. The free certified copy of the bail rejection order dated 06.04.2024 passed by the learned court below is being annexed herewith as Annexure No. 10 to this affidavit. That the applicant has been in jail since 11.01.2024 without committing any offense. That the applicant is the mother of the one and half year child and without the applicant, no one in her house to take care. That apart from the above, there is no criminal history against the applicant. That there is no chance of the applicant absconding or tempering with the prosecution witnesses. That the applicant is ready to furnish the security and bond and also undertakes that he will never misuse the liberty of bail. That in view of the above, it would be expedient and necessary in the interest of justice that the applicant be enlarged on bail, in relation to Case Crime No. 388 of 2023 under Sections 323, 304, 504 of I.P.C. relating to the Police Station – Motigarpur, District – Sultanpur, in the interest of justice.


I, Sabhajit aged about 48 years son of Shri Sampati resident of Village - Marui, Kishun Daspur, Police Station - Akhand Nagar, District - Sultanpur , District - Sultanpur, Religion – Hindu, Education –Lliterate, Occupation – Housewife, do hereby solemnly affirm and state on oath as under:- That the deponent is the uncle/ pairokar of the applicant and duly authorized by the applicant to file the aforesaid application before this Hon'ble Court and as such she is fully conversant with the facts of the case and deposed as under. The ID Proof of the deponent is enclosed and her photograph is affixed to the affidavit. That this is the first bail application before this Hon'ble Court. No any other bail application is pending before this Hon'ble Court or rejected by this Hon'ble Court. That the instant matter is not related to CBI/Prevention of Corruption Act/ Enforcement Directorate /matters relating to NRHM Scam / GPF Scam/matters of MP/MLA etc. That brief fact of the case is that a first information report was lodged against the unknown persons on 04.07.2023 at 10.29 hours by the informant namely Tilakraj son of Shri Teeju Rajbhar resident of Village - Marui, Kishundaspur, Police Station - Akhand Nagar, District - Sultanpur (hereinafter referred to as ‘informant’) bearing Case Crime No. 202 of 2023 under Section 302 I.P.C. at Police Station – Akhand Nagar, District – Sultanpur regarding the incident dated 03.07.2023. The certified copy of the first information report dated 04.07.2023 is being annexed as Annexure No. 01 to this affidavit. That according to the first information report lodged on 04.07.2023, the prosecution story is in a nutshell that the younger brother of the informant namely Vijay Rajbhar (hereinafter referred to as ‘deceased’) along with irrigating field on 03.07.2023 around 23.00 hours at that time they were murdered by unknown persons. That here it is relevant to mention that the applicant is not named in the first information report. That the inquest reports of both deceased were prepared by the concerned police on 04.07.2023 in the presence of several persons. That the body of the deceased and another were brought to the P. M., Sultanpur for conducting the post-mortem on 04.07.2023, where the post-mortem was conducted and the cause of the death was ascertained as ‘hemorrhage and shock” due to firearm injury. The photo/ typed copy of the post-mortem reports of the deceased persons dated 04.07.2023 are being annexed as Annexure No. 02 to this affidavit. That the version of the first information report is totally false and baseless and the same depends upon the concocted story as such nothing happened as alleged by the informant in her first informant report. That the investigating officer recorded the statement of the informant under Section 161  Cr.P.C. on 04.07.2023 in which the informant repeated his first information report version and he did not name the applicant or anyone. The typed copy of the statement of the informant dated 04.07.2023 is being annexed as Annexure No. 03 to this affidavit. That the statement of the son of another deceased was also recorded by the concerned police on 04.07.2023, in which he also repeated the version of the first information report. The typed copy of the statement of the son of another deceased dated 04.07.2023 is being annexed as Annexure No. 04 to this affidavit. That on 14.07.2023, the alleged police informant informed the investigating officer regarding the murder of the deceased and first time named the applicant and others and narrated a false story against the applicant for extraneous reasons. The typed copy of the CD-8 dated 14.07.2023 is being annexed as Annexure No. 05 to this affidavit. That on 23.07.2023, the statements of three witnesses were recorded by the investigating officer, in which they stated that the applicant was not present at the time alleged incident at the place of occurrence. The typed copies of the statement of three witnesses dated 23.07.2023 are being annexed as Annexure No. 06 to this affidavit. That thereafter, the statement of the wife of the deceased and also further statement of the informant were recorded by the concerned police on 25.07.2023, in which they both explained the story, which was stated by the police informer and tried to falsely implicate the applicant. The typed copy of the statement of the wife of the deceased and informant of the case crime are being annexed as Annexure No. 07 to this affidavit. That the story of the police informer, the wife of the deceased, and further statements of the informant are not trustworthy as well as not digestible by the prudent person. That the applicant has been arrested by the investigating officer from his house but for showing his good showed that the applicant arrested from another place. That thereafter, the confessional statements of the co-accused and applicant have been written/ prepared by the Investigating Officer on 12.08.2023 as per his wish and tried their best to collaborate with the alleged incident and witnesses under section 161 Cr.P.C. only to prove the offense against the arrested accused and applicant whereas the applicant has not committed any offense. The typed copy of the confessional statement of the applicant dated 12.08.2023 is being annexed as Annexure No. 08 to this affidavit. That the confessional statements of the arrested co-accused and applicant were recorded by the concerned police on 12.08.2023 under the life threat, in which the applicant said everything as narrated by the concerned police and the statement of the co-accused changed in comparison to the arresting memo. That it is most humbly submitted that the applicant is innocent and he has falsely been implicated by the informant in the instant case and there is no evidentiary value in the eye of the law relating to the confessional statements given by the arrested accused. That the 12.08.2023, the alleged murder weapon was recovered from the pointing of other accused and the recovery memo was prepared by the concerned police. The photocopy of the recovery memo dated 12.08.2023 is being annexed as Annexure No. 09 to this affidavit. That the real story is that the applicant, informant & deceased are residents of the same village and they know each other. That here it is relevant to mention that around 6 years back, the applicant took a tractor from the deceased and when he failed to repay the money to the deceased then the applicant sold his 2 biswa land to the son of the deceased. That there was no dispute after the execution of the sale deed in the favour of the deceased’s son. That the applicant was present with the deceased persons on 03.07.2023 but he was returned to his house with Rajman Pal around 10.30 PM. That on 03.07.2023 the deceased was murdered by some unknown persons due to their enmity but due to extraneous reasons, best known by the informant and concerned police, the applicant has been falsely implicated in said case crime. That the prosecution's story is unbelievable and beyond the imagination as the informant and other witnesses have explained the story of the police informar. That the concerned police on the basis of the phone location of the applicant, created the false story for extraneous reasons and the same has been repeated by the witnesses of the case crime in a similar manner. That the post mortem report also did not collaborate with the prosecution's story, which cleary shows that the applicant is falsely implicated in this case crime. That the deceased was murdered by unknown persons but the applicant has been falsely implicated in the case crime. That due to malafide intention, the informant for extraneous reasons, was falsely implicated in the first information report after knowing everything about the incident, while he has not committed any offense as alleged against him. That the applicant has no concern with the murder of the deceased in any manner as alleged by the informant and the allegation against the applicant along with the prosecution story is totally against truth and is not reliable in manner. That neither the applicant has a motive nor has any reasonable motive been assigned to him to commit the crime in question. That neither nothing has been recovered from the application possession nor pointing of him, which shows that the applicant has not committed the case crime as alleged against him. That there is no credible evidence on record that could show that the applicant is guilty or committed the crime in question and the evidence available on the record itself shows that no prima-facie offense under Sections 302, 120-B of I.P.C. at Police Station – Akhand Nagar, District – Sultanpur is made out against the applicant. That the applicant moved bail application No. 2688 of 2023 before the learned Additional District & Sessions Judge, Court No. 1, Sultanpur and his bail application was rejected by the court concerned on 05.10.2023. The free certified copy of the bail rejection order dated 05.10.2023 passed by the learned court below is being annexed as Annexure No. 10 to this application. That the applicant is in jail since 12.08.2023 without committing any offense. That apart from the above, there is no criminal history against the applicant. That there is no chance of the applicant absconding or tempering with the prosecution witnesses. That the applicant is ready to furnish the security and bond and also undertakes that he will never misuse the liberty of bail. That in view of the above, it would be expedient and necessary in the interest of justice that the applicant be enlarged on bail, in relation to Case Crime No. 202 of 2023 under Sections 302, 120-B of I.P.C. relating to the Police Station – Akhand Nagar, District – Sultanpur, in the interest of justice.


I, Mahabeer aged about 68 years son of Shri Samjhawan resident of Atardasha, Shukul Dulacha, Deara, District - Sultanpur, Religion – Hindu, Education –Lliterate, Occupation – Housewife, do hereby solemnly affirm and state on oath as under:- That the deponent is the father-in-law/ pairokar of the applicant and duly authorized by the applicant to file the aforesaid application before this Hon'ble Court and as such he is fully conversant with the facts of the case and deposed as under. The ID Proof of the deponent is enclosed and his photograph is affixed to the affidavit. That this is the first bail application before this Hon'ble Court. No any other bail application is pending before this Hon'ble Court or rejected by this Hon'ble Court. That the instant matter is not related to CBI/Prevention of Corruption Act/ Enforcement Directorate /matters relating to NRHM Scam / GPF Scam/matters of MP/MLA etc. That brief fact of the case is that a first information report was lodged against the applicant and her husband on 31.12.2023 at 11.54 hours by the informant namely Sonu Yadav son of Suryabali Yadav resident of Village - Bhartipur, Police Station - Motigarpur, District - Sultanpur (hereinafter referred to as ‘informant’) bearing Case Crime No. 388 of 2023 under Section 308, 504 I.P.C. at Police Station – Motigarpur, District – Sultanpur regarding the incident dated 30.01.2023. The certified copy of the first information report dated 31.12.2023 is being annexed as Annexure No. 01 to this affidavit. That according to the first information report lodged on 31.12.2023, the prosecution story is in a nutshell that due to a land dispute the applicant and her husband were abused and beaten the nephew of the informant namely Pramod Yadav (hereinafter referred to as ‘deceased’) due to which he sustained the injuries, who is under treatment. That the version of the first information report is totally false and baseless and the same depends upon the concocted story as such nothing happened as alleged by the informant in his first informant report. That the first information report dated 31.12.2023 lodged by the informant to save the deceased and his brother, who were themselves attacked upon the applicant and her husband in retaliation as a counterblast to the first information report lodged by the applicant against the deceased and his brother regarding the same incident bearing Case Crime No. 5 of 2024 under Sections 323, 504, 506, of I.P.C. registered at Police Station – Motigarpur, District – Sultanpur. The photocopy of the first information report lodged by the applicant against the deceased and another is being annexed as Annexure No. 02 to this affidavit. That the investigating officer recorded the statement of the informant under Section 161  Cr.P.C. on 01.01.2024 in which the informant repeated his first information report version. The typed copy of the statement of the informant dated 01.01.2024 is being annexed as Annexure No. 03 to this affidavit. That on 09.01.2024, during the treatment, the deceased died and the informant moved an application for taking action against the applicant and her husband thereafter the Investigating Officer added Section 323 & 304 of I.P.C. and deleted Section 308 of I.P.C. on 10.01.2024. That the body of the deceased was brought to the KGMU Mortuary, Lucknow for conducting the post-mortem on 10.01.2024, where the post-mortem was conducted and the cause of the death was ascertained as ‘antemortem head injury as noted”. The photocopy of the post-mortem report of the deceased dated 10.01.2024 is being annexed as Annexure No. 04 to this affidavit. That the investigating officer recorded the further statement of the informant under Section 161  Cr.P.C. on 11.01.2024 in which the informant changed the version of his first information report version and tried to put gravity in his statement for falsely implicating the applicant and her husband. The typed copy of the further statement of the informant dated 11.01.2024 is being annexed as Annexure No. 05 to this affidavit. That it was very strange that when the Investigating Officer asked the names of the witnesses, then he denied on the ground that he was sad, whereas, after the death of the deceased he moved an application on 10.01.2024 and gave a further statement on 11.01.2024. That the applicant and her husband were arrested by the concerned police on 11.01.2024 from their home but for showing his good work, their arrest was shown from another place in a forged and fabricated arresting cum recovery memo dated 11.01.2024. That thereafter, the confessional statements of the applicant and her husband have been written/ prepared by the Investigating Officer on 11.01.2024 as per his wish and tried their best to collaborate with the alleged incident and witnesses under section 161 Cr.P.C. only to prove the offense against the applicant whereas the applicant has not committed any offense. The typed copy of the confessional statement of the applicant and her husband dated 11.01.2024 is being annexed as Annexure No. 06 to this affidavit. That it is most humbly submitted that the applicant is innocent and she has falsely been implicated by the informant in the instant case and there is no evidentiary value in the eye of the law relating to the confessional statements given by the applicant and her husband. That the real story is that the applicant is two sisters and no brother and their mother also expired. That the sister of the applicant resides at her marital house and not taking care of her father. That the father of the applicant executed a WILL deed of his entire movable and immovable properties in favour of the applicant on 26.05.2023. The photo/typed copy of the WILL deed dated 26.05.2023 is being annexed as Annexure No. 07 to this affidavit. That after the execution of the WILL deed in favour of the applicant, her sister & her sons were not happy with the applicant and her family members. That the sister of the applicant and her sons, on several occasions, fought with her father to get half share in the property but the same was not given to her by the father of the applicant. That thereafter, the sister and her sons had enmity with the applicant and her husband and given the threat to face consequences of the same. As a result of the same, on 30.12.2023, the deceased and his brother beat the applicant & her husband. That during the manhandling, both parties were injured, in which the applicant and her husband sustaind the injuries. The photo/typed copy of the injury report of the applicant and her husband are being annexed as Annexure No. 08 to this affidavit. That 09.01.2024 the deceased died thereafter, the gravity of the case has been shifted to the applicant and her husband due to extraneous reasons, best known by the informant and concerned police, the applicant has been falsely implicated in said case crime. That the prosecution's story is unbelievable and beyond the imagination as the informant and other witnesses have explained the story of the police informar. That the post-mortem report also did not collaborate with the prosecution's story, which clearly shows that the applicant is falsely implicated in this case crime. That due to malafide intention, the informant for extraneous reasons, was falsely implicated in the first information report after knowing everything about the incident, while she has not committed any offense as alleged against her. That the applicant has no concern with the murder of the deceased in any manner as alleged by the informant and the allegation against the applicant along with the prosecution story is totally against truth and is not reliable in manner. That neither the applicant has a motive nor has any reasonable motive been assigned to him to commit the crime in question. That neither nothing has been recovered from the application possession nor pointing of him, which shows that the applicant has not committed the case crime as alleged against him. That there is no credible evidence on record that could show that the applicant is guilty or committed the crime in question and the evidence available on the record itself shows that no prima-facie offense under Sections 323, 304, 504 of I.P.C. at Police Station – Motigarpur, District – Sultanpur is made out against the applicant. That the only general allegations have been assigned against the applicant and no any role has been assigned to the applicant regarding the accident. That the deceased and his brother themselves had a strong motive and with the intention of murder the applicant attacked upon the applicant and in saving the applicant, the deceased also sustained injuries. That the applicant moved bail application No. 497 of 2024 before the learned Sessions Judge, Sultanpur and her bail application was rejected by the court concerned on 02.03.2024. The free certified copy of the bail rejection order dated 02.03.2024 passed by the learned court below is being annexed as Annexure No. 9 to this application. That the applicant is in jail since 11.01.2024 without committing any offense. That the applicant is the mother of the one and half year child and without the applicant, no one in her house to take care. That apart from the above, there is no criminal history against the applicant. That there is no chance of the applicant absconding or tempering with the prosecution witnesses. That the applicant is ready to furnish the security and bond and also undertakes that he will never misuse the liberty of bail. That in view of the above, it would be expedient and necessary in the interest of justice that the applicant be enlarged on bail, in relation to Case Crime No. 388 of 2023 under Sections 323, 304, 504 of I.P.C. relating to the Police Station – Motigarpur, District – Sultanpur, in the interest of justice.


I, Smt. Shikha Pandey aged about 30 years wife of Shri Ved Prakash Pandey resident of 33/500, Block - 33, Trilok Puri, East Delhi, Delhi, Education –Literate, Occupation – Housewife, do hereby solemnly affirm and state on oath as under:- That the deponent is the Bua/ pairokar of the applicant and duly authorized by the applicant to file the aforesaid application before this Hon'ble Court and as such she is fully conversant with the facts of the case and deposed as under. That the photo verification slip issued by the Awadh Bar Association of the deponent is being pasted on the first page of this affidavit and a photocopy of the ID proof of the deponent is being annexed with this affidavit. That this is the first bail application before this Hon'ble Court. No any other bail application is pending before this Hon'ble Court or rejected by this Hon'ble Court. That the instant matter is not related to CBI/Prevention of Corruption Act/ Enforcement Directorate /matters relating to NRHM Scam / GPF Scam/matters of MP/MLA etc. That brief fact of the case is that a first information report was lodged against the applicant and three others on 19.07.2024 at 16.45 hours by the informant namely Smt. Sangeeta Maurya wife of Shri Mahesh Maurya resident of Village - Pahadpur Kalan, Police Station - Karaundikalan, District - Sultanpur (hereinafter referred to as ‘informant’) bearing Case Crime No. 153 of 2024 under Section 140(2) of B.N.S.,2023 at Police Station – Karaundikalan, District – Sultanpur. The certified copy of the first information report dated 19.07.2024 is being annexed as Annexure No. 01 to this affidavit. That according to the first information report lodged on 19.07.2024, the prosecution story is in a nutshell that on 18.07.2024 the applicant and others called the informant’s husband namely Mahesh (hereinafter referred to as ‘victim’), and later the applicant called the informant and demanded a ransom of Rs. 3 lacks. That the version of the first information report is totally false and baseless and the same depends upon the concocted story as such nothing happened as alleged by the informant in her first informant report. That the investigating officer recorded the statement of the informant under Section 180 of B.N.S.S., 2023 on 19.07.2024 in which the informant repeated her first information report version with additional facts by which she tried her best to improve his prosecution story to the applicant behind bars. The typed copy of the statement of the informant dated 19.07.2024 is being annexed as Annexure No. 02 to this affidavit. That the applicant has been arrested by the investigating officer from his house but for showing his good work stated that the applicant was arrested from another place along with other accused. That on 20.07.2024, the victim was recovered and his statement under Section 180 of B.N.S.S., 2023 was recorded by the investigating officer, in which he almost repeated the statement of the informant and added that the applicant and other accused had beaten him. The typed copy of the statement of the victim dated 20.07.2024 is being annexed as Annexure No. 03 to this affidavit. That it is most humbly submitted that the applicant is innocent and he has falsely been implicated by the informant in the instant case and there is no evidentiary value in the eye of the law relating to the confessional statements given by the arrested accused. That the real story is that the applicant and the victim are well-known to each other and on several occasions, the victim has taken a loan from the applicant and his wife. That when the loan was not returned by the victim on time then on several demands, he had given a cheque of Rs. 4,00,000/- in the name of the applicant’s wife. The photocopy of the cheque given by the victim is being annexed as Annexure No. 04 to this affidavit. That the victim requested the applicant not to present the cheque until he said and when several requests were made for payment then the victim denied for payment and was given the threat to falsely implicate him in a criminal case. That thereafter, in well planned manner, the applicant has been falsely implicated in said case crime. That the prosecution's story is unbelievable and beyond the imagination as the informant and other witnesses have explained the story of the informant. That due to malafide intention, the informant for extraneous reasons, was falsely implicated in the first information report after knowing everything about the incident, while he has not committed any offense as alleged against him. That the applicant has no concern with the kidnapping and demand of ransom in any manner as alleged by the informant and the allegation against the applicant along with the prosecution story is totally against truth and is not reliable in manner. That neither the applicant has a motive nor has any reasonable motive been assigned to him to commit the crime in question. That neither nothing has been recovered from the application possession nor pointing of him, which shows that the applicant has not committed the case crime as alleged against him. That there is no credible evidence on record that could show that the applicant is guilty or committed the crime in question and the evidence available on the record itself shows that no prima-facie offense under Section 140 (2) of B.N.S., 2023 at Police Station – Karaundikalan, District – Sultanpur is made out against the applicant. That the applicant moved bail application No. 2149 of 2024 before the learned District Judge, Sultanpur, and his bail application was rejected by the court concerned on 27.08.2024. The free certified copy of the bail rejection order dated 27.08.2024 passed by the learned court below is being annexed as Annexure No. 05 to this application. That the applicant has been in jail since 19.07.2024 without committing any offense. That apart from the above, there is no criminal history against the applicant. That there is no chance of the applicant absconding or tempering with the prosecution witnesses. That the applicant is ready to furnish the security and bond and also undertakes that he will never misuse the liberty of bail. That in view of the above, it would be expedient and necessary in the interest of justice that the applicant be enlarged on bail, in relation to Case Crime No. 153 of 2024 under Section 140 (2) of B.N.S., 2023 relating to the Police Station – Karaundikalan, District – Sultanpur, in the interest of justice.


I, Smt. Shikha Pandey aged about 30 years wife of Shri Ved Prakash Pandey resident of 33/500, Block - 33, Trilok Puri, East Delhi, Delhi, Education –Literate, Occupation – Housewife, do hereby solemnly affirm and state on oath as under:- That the deponent is the sister/ pairokar of the applicant and duly authorized by the applicant to file the aforesaid application before this Hon'ble Court and as such she is fully conversant with the facts of the case and deposed as under. That the photo verification slip issued by the Awadh Bar Association of the deponent is being pasted on the first page of this affidavit and a photocopy of the ID proof of the deponent is being annexed with this affidavit. That this is the first bail application before this Hon'ble Court. No any other bail application is pending before this Hon'ble Court or rejected by this Hon'ble Court. That the instant matter is not related to CBI/Prevention of Corruption Act/ Enforcement Directorate /matters relating to NRHM Scam / GPF Scam/matters of MP/MLA etc. That brief fact of the case is that a first information report was lodged against the applicant and three others on 19.07.2024 at 16.45 hours by the informant namely Smt. Sangeeta Maurya wife of Shri Mahesh Maurya resident of Village - Pahadpur Kalan, Police Station - Karaundikalan, District - Sultanpur (hereinafter referred to as ‘informant’) bearing Case Crime No. 153 of 2024 under Section 140(2) of B.N.S.,2023 at Police Station – Karaundikalan, District – Sultanpur. The certified copy of the first information report dated 19.07.2024 is being annexed as Annexure No. 01 to this affidavit. That according to the first information report lodged on 19.07.2024, the prosecution story is in a nutshell that on 18.07.2024 the applicant and others called the informant’s husband namely Mahesh (hereinafter referred to as ‘victim’), and later the applicant called the informant and demanded a ransom of Rs. 3 lacks. That the version of the first information report is totally false and baseless and the same depends upon the concocted story as such nothing happened as alleged by the informant in her first informant report. That the investigating officer recorded the statement of the informant under Section 180 of B.N.S.S., 2023 on 19.07.2024 in which the informant repeated her first information report version with additional facts by which she tried her best to improve his prosecution story to the applicant behind bars. The typed copy of the statement of the informant dated 19.07.2024 is being annexed as Annexure No. 02 to this affidavit. That the applicant has been arrested by the investigating officer from his house but for showing his good work stated that the applicant was arrested from another place along with other accused. That on 20.07.2024, the victim was recovered and his statement under Section 180 of B.N.S.S., 2023 was recorded by the investigating officer, in which he almost repeated the statement of the informant and added that the applicant and other accused had beaten him. The typed copy of the statement of the victim dated 20.07.2024 is being annexed as Annexure No. 03 to this affidavit. That it is most humbly submitted that the applicant is innocent and he has falsely been implicated by the informant in the instant case and there is no evidentiary value in the eye of the law relating to the confessional statements given by the arrested accused. That the real story is that the applicant and the victim are well-known to each other and on several occasions, the victim has taken a loan from the applicant and his wife. That when the loan was not returned by the victim on time then on several demands, he had given a cheque of Rs. 4,39,000/- in the name of the applicant’s wife on 25.05.2024. The photocopy of the cheque dated 25.05.2024 given by the victim is being annexed as Annexure No. 04 to this affidavit. That the victim requested the applicant not to present the cheque until he said and when several requests were made for payment then the victim denied for payment and was given the threat to falsely implicate him in a criminal case. That thereafter, in well planned manner, the applicant has been falsely implicated in said case crime. That the prosecution's story is unbelievable and beyond the imagination as the informant and other witnesses have explained the story of the informant. That due to malafide intention, the informant for extraneous reasons, was falsely implicated in the first information report after knowing everything about the incident, while he has not committed any offense as alleged against him. That the applicant has no concern with the kidnapping and demand of ransom in any manner as alleged by the informant and the allegation against the applicant along with the prosecution story is totally against truth and is not reliable in manner. That neither the applicant has a motive nor has any reasonable motive been assigned to him to commit the crime in question. That neither nothing has been recovered from the application possession nor pointing of him, which shows that the applicant has not committed the case crime as alleged against him. That there is no credible evidence on record that could show that the applicant is guilty or committed the crime in question and the evidence available on the record itself shows that no prima-facie offense under Section 140 (2) of B.N.S., 2023 at Police Station – Karaundikalan, District – Sultanpur is made out against the applicant. That the applicant moved bail application No. 2050 of 2024 before the learned District Judge, Sultanpur, and his bail application was rejected by the court concerned on 27.08.2024. The free certified copy of the bail rejection order dated 27.08.2024 passed by the learned court below is being annexed as Annexure No. 05 to this application. That the applicant has been in jail since 19.07.2024 without committing any offense. That apart from the above, there is no criminal history against the applicant. That there is no chance of the applicant absconding or tempering with the prosecution witnesses. That the applicant is ready to furnish the security and bond and also undertakes that he will never misuse the liberty of bail. That in view of the above, it would be expedient and necessary in the interest of justice that the applicant be enlarged on bail, in relation to Case Crime No. 153 of 2024 under Section 140 (2) of B.N.S., 2023 relating to the Police Station – Karaundikalan, District – Sultanpur, in the interest of justice.


I, Pradeep Kumar Yadav aged about 38 years son of Shri Mata Prasad resident of 16 A, Devkali Kotwa, Lahanganj, District - Sultanpur, Education –Literate, Occupation – Agriculture, do hereby solemnly affirm and state on oath as under:- That the deponent is the uncle/ pairokar of the applicant and duly authorized by the applicant to file the aforesaid application before this Hon'ble Court and as such he is fully conversant with the facts of the case and deposed as under. That the photo verification slip issued by the Awadh Bar Association of the deponent is being pasted on the first page of this affidavit and a photocopy of the ID proof of the deponent is being annexed with this affidavit. That this is the first bail application before this Hon'ble Court. No any other bail application is pending before this Hon'ble Court or rejected by this Hon'ble Court. That the instant matter is not related to CBI/Prevention of Corruption Act/ Enforcement Directorate /matters relating to NRHM Scam / GPF Scam/matters of MP/MLA etc. That brief fact of the case is that a first information report was lodged against the applicant on 08.08.2024 at 22.31 hours by the informant namely Smt. Sumirta wife of Late Jagdeen resident of Village - Bhiti Bubane Ka Pura, Police Station - Bhiti, District - Ambedkar Nagar (hereinafter referred to as ‘informant’) bearing Case Crime No. 230 of 2024 under Sections 85, 108 of B.N.S., 2023 at Police Station – Jaisinghpur, District – Sultanpur with regard to incident dated 01.08.2024. The certified/typed copy of the first information report dated 08.08.2024 is being annexed as Annexure No. 01 to this affidavit. That according to the first information report lodged on 08.08.2024, the prosecution story is in a nutshell that the marriage of the daughter of the informant namely Roshni (hereinafter referred to as ‘deceased’) with the applicant in the year 2008 and the applicant has illicit relation with someone. On 01.08.2024, the deceased caught the applicant and recorded a video, for which the applicant beat the deceased and stated her to commit suicide. Thereafter the deceased committed suicide and when the informant reached at the place of inicident, the police were there. That according to the first information report, the deceased committed suicide on 01.08.2024 but the the first information report was lodged by the informant after seven days, after getting legal advice, when the applicant did not fulfill the illegal demands of the informant. That it is relevant to mention here that the informant planned and falsely implicated the applicant to get financial benefits. Thereafter on the basis of legal advice, the first information report has been lodged against the applicant on wrong and baseless facts. That the inquest report was prepared by the concerned police in the presence of the Panchan and also in the presence of the applicant himself and other persons on 01.08.2024. That the body of the deceased was sent for the post-mortem on 02.08.2024 at District Hospital, Sultanpur wherein the post-mortem was done by doctors, and the cause of death was ascertained as ‘Asphysia’ due to ‘Anti-mortem hanging”. The photo/type copy of the post-mortem report dated 02.08.2024 is being annexed herewith as Annexure No. 2 to this affidavit. That according to the post-mortem report, the time of death of the deceased was about one and half day back, which is also not collaborated with the prosecution story. That the version of the first information report is totally false and baseless and the same depends upon the concocted story as such nothing happened as alleged by the informant in her first informant report. That the investigating officer recorded the statement of the informant under Section 180 of B.N.S.S., 2023 on 09.08.2024 in which the informant repeated her first information report version with additional facts by which she tried her best to improve her prosecution story to send the applicant behind bars. The typed copy of the statement of the informant dated 09.08.2024 is being annexed as Annexure No. 03 to this affidavit. That the statement of the sisters of the deceased were also recorded by the concerned police under section 180 of B.N.S.S., 2023 on 09.08.2024 in which they repeated the version of the informant in their own words and tried their best to falsely implicate the applicant in said case crime. That on the basis of the false first information report, the applicant was arrested by the concerned police from his house on 09.08.2024. That the real fact of the case is that the marriage of the applicant and the deceased was solemnized according to the Hindu rituals in the year 2008. That nothing has been demanded from the applicant and his family from the informant and her family as dowry prior to and after the marriage. That initially the relationship between the applicant and the deceased was good enough and there was no dispute between the applicant and the deceased and the deceased and applicant were blessed with two sons namely Dev Kumar and Diyansh. That the applicant was residing at Surat, Gujarat with the deceased and his sons, where they studied. That thereafter, the financial position of the applicant was not good as a result of the same, he was returned to his native place and he admitted his sons to school at his native place. That later on, as the deceased was a dominant and ambitious lady as such she wanted to live separately from the other family members of the applicant and as such created a regular nuisance in the family to reside at Surat. That the applicant called the informant and requested to convince the deceased to stay at his native place until he was not in a position to bring her to Surat but despite convincing the deceased, the informant accelerated the demands of the deceased. That due to the denial of leaving the village, the deceased was annoyed and stopped talking with the applicant and also did not properly take care of the little sons. That prior to that incident, the deceased several times locked herself in the room but always opened the door within a couple of hours. The applicant and other family members of the applicant were well aware of the short-tempered nature of the deceased thus the applicant was rest assured that the door would open soon. That due to her shot-tempered nature, the deceased committed suicide on 01.08.2024 due to her own reasons but the informant has lodged the first information report against the applicant when the applicant denied fulfilling the demand of the informant, which was for Rs. 3 lakhs for not lodging the first information report against him. That here it is relevant to mention that the applicant was not at home, when the deceased committed suicide, and when he returned home after the incident, he himself moved an application before the concerned Police Station regarding the incident on 01.08.2024the applicant himself regarding the unfortunate incident. The said application has been brought on record by the concerned police on 01.08.2024. The typed copy of the General Diary No. 61 dated 01.08.2024 is being annexed as Annexure No. 04 to this affidavit. That the concerned police came to the incident place and entered the room, where the deceased committed suicide after breaking the door of the room. That the applicant never beaten the deceased as alleged by the informant and others. The investigating officer recorded the statements of the sons of the applicant under Section 180 of B.N.S.S., 2023 on 29.08.2024, in which they said that the applicant never beat the deceased. The typed copies of the statements of the sons of the applicant is being annexed as Annexure No. 05 to this affidavit. That here it is relevant to mention that the deceased was a short-tempered lady and she became more aggressive and also not in a position to make good decisions due to her anger and committed suicide. That the informant due to extraneous reasons lodged the first information against the applicant after getting legal advice just for her satisfaction while she is well aware that her daughter herself committed suicide for her own reasons. That Pratibha against the informant alleged that the applicant has illicit relations with her, is the sister of the applicant and she also opposed the illegal demands of the informant as such the informant annoyed and levelled false allegations. That so far video recording, which has been stated by the informant and others, has not been recovered by the concerned police till date, which shows that the informant is telling a lie regarding the character of the applicant. That according to the prosecution story, it clearly reveals that the story of the prosecution is based on only presumption and concerned police avoiding the truth of the case and there is no evidence against the applicant. That the applicant is being the husband of the deceased falsely implicated in the said case crime by the informant while the deceased committed suicide for her own reasons. That the applicant has no motive to commit the alleged crime and a false motive which was given in the case, is cooked and fabricated by the concerned police. That there is no credible evidence on record that could show that the applicant is guilty or committed the crime in question and the evidence available on the record itself shows that no prima-facie offense under Sections 85, 108 of B.N.S., 2023 at Police Station – Jaisinghpur, District – Sultanpur is made out against the applicant. That the applicant moved bail application No. 2155 of 2024 before the learned District Judge, Sultanpur, and his bail application was rejected by the court concerned on 05.09.2024. The free certified copy of the bail rejection order dated 05.09.2024 passed by the learned court below is being annexed as Annexure No. 06 to this affidavit. That the applicant has been in jail since 09.08.2024 without committing any offense. That apart from the above, there is no criminal history against the applicant. That there is no chance of the applicant absconding or tempering with the prosecution witnesses. That the applicant is ready to furnish the security and bond and also undertakes that he will never misuse the liberty of bail. That in view of the above, it would be expedient and necessary in the interest of justice that the applicant be enlarged on bail, in relation to Case Crime No. 230 of 2024 under Sections 85, 108 of B.N.S., 2023 relating to the Police Station – Jaisinghpur, District – Sultanpur, in the interest of justice.


I, Gulsher aged about 19 years son of Alisher resident of Village – Balbhaddarpur, Police Station - Jamo, District - Amthi Religion – Muslim, Qualification – Literate, Occupation – _________, the deponent do hereby solemnly affirm and  state on oath as under :- That the deponent is ________ of the applicant and doing pairvi of the applicant in the above-noted case and duly authorized by him and as such he is fully conversant with the facts of the case deposed herein under. That the photo verification slip issued by the Oudh Bar Association of the deponent is being pasted on the first page of this affidavit and a photocopy of ID proof of the deponent is being annexed with this affidavit. That the deponent further declares that the contents of the application, as well as this affidavit, have been explained in Hindi by the counsel of the applicant as such he is fully conversant with the same. That this is the first bail application on behalf of the applicant before the Hon'ble Court and no other bail application is pending before in any court of law on his behalf. That the facts giving rise to the present case are being stated in brief hereinafter. That the applicant has falsely been implicated in case crime No. 78 of 2023 under Sections 8/21 of The Narcotic Drugs and Psychotropic Substances Act, 1985 registered at Police Station – Jamo, District – Amethi on 25.03.2023 at 12.32 hours against the applicant. The first information report has lodged by Shri Hardev Bahadur Singh, Sub Inspector, Police Station - Jamo, District – Amethi (hereinafter referred to as ‘informant’). The certified/ type copy of the first information report dated 25.03.2023 is being annexed herewith as Annexure No. 1 to this Affidavit. That the informant stated in his first information report dated 25.03.2023 that on 25.03.2023 the informant along with his team on patrolling the area. When the informant reached about 400 meters ahead of Uday Bhan Singh's rice mill in Balabhadra village, a man was seen walking from the front.  As soon as he saw the policemen, all of a sudden he turned backward and started to escape. And thereafter the applicant was arrested by them and admitted that he was bringing smack from Shahmau.  That's why I ran away after seeing you guys. That the informant recovered 55 grams of smack from the possession of the applicant by the informant and his team. That reality is that nothing has been found by the informant or his team from the applicant’s possession but contrary to the provisions and established rules, the informant shows the recovery from the applicant’s possession. That here it is relevant to mention that the recovery cum arresting memo was prepared by the informant and a copy has been given to the applicant, on which there are no signatures of the team of the informant. That it is relevant to mention here that the contents of the first information report are beyond the truth as well as imagination. The story of the informant does not collaborate with the fact and circumstances of the alleged case crime. That the applicant is the common person of society and has no concern with the Narcotic Drugs & Psychotropic Substance and the concerned police arrested the applicant from Jamo market but without any reason and falsely implicate in said case crime for showing his good work. That there is no concern with recovered Narcotic Drugs & Psychotropic Substance in any manner with the applicant as he is not involved in such type act and the police concerned falsely implicated in said case crime for extraneous reasons, which is itself wrong and incorrect. That according to the prosecution story, it clearly reveals that no one saw the occurrence while the applicant was arrested about 10.15 hours and there is no any independent eye witness of the said recovery and it is a case of forge, fabricated and false and there is no any evidence against the applicant. That the informant stated in his first information report that he has complied the provisions of the Section 50 Section of The Narcotic Drugs and Psychotropic Substances Act, 1985, while no any gazetted officer was not present at the time of arrest of the applicant, which is duly cleared from the perusal of the recovery memo, which is the part and parcel of the first information report. There is no signature of any gazetted officer on the recovery memo, which is not supported by the version of the prosecution. That the real fact of the case is that the applicant has no concerns about any type of the act as mentioned in the first information report. The informant for the purpose of getting the reward from the state government, falsely implicates the applicant in said case. That it is most relevant to mention here that the applicant has not committed any offense as alleged by the informant in his first information report dated 25.03.2023. That the applicant has not concerned with the recovered smack as alleged by the informant and also the statement of the informant totally baseless and same is not reliable in manner. That the informant has no any independent witnesses of the alleged recovery because the applicant has not committed any offence. The informant concocted the story and stated that the applicant has confessed his guilty during the recovery of the alleged smack. That the informant has not complied with the provisions of Section 50 of The Narcotic Drugs and Psychotropic Substances Act, 1985 as the Circle Officer is not a Gazette Officer, according to Section 42 of The Narcotic Drugs and Psychotropic Substances Act, 1985 as such entire raid conducted is null and void. That there is no special or general order has been passed by the Central or State government to empower the sub-inspector of the police department to enter, search, seizure, and arrest without warrant or authorization. That till date the concerned police have not produced any sufficient evidence against the applicant to prove the involvement of the applicant in the case crime. That till date there is no forensic report (chemical report) of the recovered substance has been received by the informant to establish their story that the applicant is involved in the business of the Narcotic Drugs and Psychotropic Substances. That there is no credible evidence on record that could show that the applicant is guilty or committed the crime in question and the evidence available on the record itself show that no prima-facie offence under Sections 8/21 of The Narcotic Drugs and Psychotropic Substances Act, 1985 is made out against the applicant. That since the applicant has not committed any offence as alleged but she has been falsely implicated in the case by the informant in malafide intention. That there is no chance of the applicant absconding or tampering with the prosecution witnesses and they are willing to offer bail to the satisfaction of this Hon’ble Court. That the applicant has no criminal history apart from the instant criminal case, in which he has been falsely implicated by the informant for extraneous reasons. That the applicant is in jail since   25.03.2023 without committing any offense. That the applicant will cooperate with the trial and will not tamper with the prosecution witnesses. That the applicant undertakes that they will not misuse the liberty of bail if so granted by this Hon’ble Court. That the applicant is ready and willing to file adequate surety as the Hon’ble Court may deem fit and proper in the circumstances of the case. That the applicant had applied for bail application bearing number 1421 of 2023 but the same has been rejected by the Additional Sessions Judge/ Special Judge N.D.P.S. Act, Room No. 7, Sultanpur on insufficient grounds vide order dated 12.05.2023. Here it is relevant to mention that the free certified copy of the order dated 12.05.2023 was misplaced with the deponent hence the certified copy of the order is annexed with the bail application. The certified copy of bail rejection order dated 12.05.2023 passed by the court below is annexed herewith as Annexure No. 2 to this affidavit. That in view of the above, it would be expedient and necessary in the interest of justice that the applicant be enlarged on bail in relation to case crime No. 78 of 2023 under Sections 8/21 of The Narcotic Drugs and Psychotropic Substances Act, 1985 registered at Police Station – Jamo, District – Amethi, during the pendency of the case.


I, Ram Bali Singh aged about 64 years son of Shri Ram Lakhan Singh resident of 66/A, Railway Colony Talkatora Road, Near Balak Paan Bhandar, V. G. Tikait Garden, Alambagh, Bakshi Ka Talab, District - Lucknow, Religion – Hindu, Education – Literate, Occupation – Ex-Serviceman, do hereby solemnly affirm and state on oath as under :- That the deponent is the uncle/ pairokar of the applicant and duly authorized by the applicant to file the aforesaid application before this Hon'ble Court and as such she is fully conversant with the facts of the case and deposed as under. The ID Proof of the deponent is enclosed and his photograph is affixed on the affidavit. That the deponent further declared that the contents of the bail application have been explained by the counsel of the appellant in Hindi and as such he is fully conversant with the facts of the case deposed as under. That the instant matter is not related to CBI/Prevention of Corruption Act/ Enforcement Directorate /matters relating to NRHM Scam / GPF Scam/matters of MP/MLA etc. That this is the first bail application before this Hon'ble Court. No any other bail application is pending before this Hon'ble Court or rejected by this Hon'ble Court. That brief facts of the case are that a First Information Report has been lodged against the applicant and five other persons, on 03.01.2023 at 10.56 hours by the informant namely Smt. Maya Singh wife of Shri Indrasen Singh resident of Village - Mudaha, Police Station - Motigarpur, District - Sultanpur (hereinafter referred to as ‘informant’) under Sections 147, 307, 323, 324, 504, 506 of I.P.C. at Police Station – Motigarpur, District – Sultanpur regarding incident dated 30.12.2022 only on basis of wrong, false and presumption. The certified/photocopy of the First Information Report dated 03.01.2023 is being annexed as Annexure No. 01 to this affidavit. That according to the First Information Report lodged by the informant alleged therein that on 30.12.2022 at around 07.30 PM, Vipin Singh, son of the informant was returning home and when he reached the Mudaha Minor bridge, the applicant and other accused beat her son with lathi, hockey sticks, iron rod, and sharp weapons and threw her into the canal. After hearing the commotion and seeing the family members coming, the applicant and the other accused ran away thinking that the son of the informant was dead. The informant further alleged that the applicant and others were abusing them, when her son was brought to CHC Motigarpur in an unconscious state, from where he was referred to District Hospital Sultanpur. That the alleged incident which was occurred on 30.12.2022 at 19.30 hours but the first information report has been lodged around four days delay i.e. on 03.01.2023 at 10.56 hours without giving any explanation with regard to the delay caused in lodging the first information report, which is already questionable and doubtful as the informant and her family lodged aforesaid first information after legal advice. That the son of the informant was brought to the hospital where his treatment was done, in which several injuries were noted by the doctor concerned. The photo/type copy of the medical of the informant’s son along with the endorsement made in the case diary are being annexed herewith as Annexure No. 02 to this affidavit. That on a bare perusal of the medical records of the son of the informant, it is clear that Section 307 of I.P.C. is not attracted as there are no any grievous injuries to the son of the informant. That here it is relevant to mention that the aforesaid First Information Report has been lodged by the informant on false, incorrect, and baseless grounds in a counterblast attack in retaliation as the mother of the namely Vijay Laxmi has lodged a First Information Report on 05.01.2023 against the son of the informant and 8 others bearing Case Crime No. 6 of 2023 under Sections 147, 307, 323, 452, 504, 506 of I.P.C. registered at Police Station – Motigarpur, District – Sultanpur. The photocopy of the First Information Report dated 05.01.2023 lodged by the applicant’s mother is being annexed herewith as Annexure No. 03 to this affidavit. That the informant, on the basis of legal advice lodged the said First Information Report against the applicant and other accused for his son’s safeguard as the son of the informant himself along with companions tried to murder the applicant’s father but he failed and during said manhandling between the applicant and son of the informant and his companions, four persons applicant’s side, sustained the injuries. That the allegations leveled against the applicant are very superficial, vague, indefinite, and of such nature that the applicant cannot be held guilty. That it is most relevant to mention here that the applicant has not committed any offense as alleged by the informant in her first information report dated 03.01.2023. That on 04.01.2023, the statement of the informant was recorded by the concerned police under Section 161 of Cr.P.C., in which she almost repeated her First Information Report but she stated that due to enmity the applicant and others committed the case crime. The typed copy of the statement of the informant dated 04.01.2023 is being annexed as Annexure No. 04 to this affidavit. That the two eyewitnesses of the case crime has been recorded their statements under Section 161 of Cr.P.C. on 08.02.2023, in which they repeated the version of the informant however, they have not assigned any specific role to the applicant. The typed copies of the statement of the eyewitnesses of the case crime dated 08.02.2023 are being annexed as Annexure No. 05 to this affidavit. That the investigating officer of the case crime, recorded statements of several independent witnesses of the case crime under Section 161 of Cr.P.C. on 22.02.2023, in which they all again repeat the statement of the informant in their own words. The typed copies of the statements of the independent witnesses of the case crime dated 22.02.2023 are being annexed as Annexure No. 06 to this affidavit. That the version of the First Information Report is totally false and baseless and same depends upon the concocted story as such nothing happened as alleged by the informant in her First Information Report so far concerned to the applicant, which has been revealed from the perusal of the statements of the eyewitness and independent witnesses of the case crime. That the applicant was arrested by the concerned police on 21.04.2023 without any basis merely on the basis of the statement of the informant, who was named by the applicant for saving her son from the commissioning of the case crime No. 06 of 2023 while the applicant was not involved in the commission of the crime as alleged against him. That without proper investigation of the case crime, the investigating officer submitted the Charge Sheet on 24.04.2023 under Sections 147, 307, 323, 324, 325, 504, 506 of I.P.C. against the applicant and another for extraneous reasons. That the real fact of the case is that the applicant is innocent and has not committed any offence as alleged against him by the informant. That the applicant and informant are residents of the same village and are pattidar but the son of the informant and his companions are hardened criminals against them several criminal cases have been lodged. That including the applicant and his family members as well as several villagers, who have been facing the inconvenience from the illegal activities of the son of the informant and his companions. The applicant and his father boldly opposed the son of the informant due to the applicant’s family being on target of the son of the informant. That on 30.12.2022 around 18.45 hours, the informant’s son and his companions assaulted the father of the applicant and his family members including his uncle and others with lathi, danda, and iron rod, and the applicant and his family members saved their life anyhow, however, they have sustained the injuries. The photo/ typed copies medical of the applicant and his family members are being annexed as Annexure No. 07 to this affidavit. That thereafter the mother of the applicant moved an application for lodging the FIR against the informant’s sons and others but due to man, muscle, and money power of them, her FIR was not lodged by the concerned police even when the application was moved by the mother of the applicant prior to the application moved by the informant before the concerned police. That for the extraneous reason, after lodging the first information report against the applicant and others, the concerned police lodged the first information report on 05.01.2023 against the son of the informant and 8 others bearing Case Crime No. 6 of 2023 under Sections 147, 307, 323, 452, 504, 506 of I.P.C. registered at Police Station – Motigarpur, District – Sultanpur. That here it is relevant to mention that the first information report was lodged by the mother of the applicant, the concerned police for extraneous reasons, not concluding the investigation of the same. That the applicant has no concern with the allegations of the informant in any manner and also the prosecution story is totally against the truth and same is not reliable in manner. That neither the applicant has any motive nor has any reasonable motive been assigned to him to commit the crime in question. Merely on the basis of extraneous reason, the applicant has been framed in the said case crime. That there is no credible evidence on record that could show that the applicant has committed the crime in question and the evidence available on the record itself show that no prima-facie offense under Sections 147, 307, 323, 324, 325, 504, 506 of I.P.C. at Police Station – Motigarpur, District – Sultanpur is made out against the applicant. That since the applicant has not committed any offence as alleged but he has been falsely implicated in the case by the informant with malafide intention with the collusion of the concerned police for an ulterior motive. That the applicant moved bail application No. 1477 of 2023 before the learned Session Judge, Sultanpur and his bail application has been rejected by the court concerned on 08.05.2023 without considering the fact of the case. Here it is relevant to mention that the free certified copy of the order dated 08.05.2023 has been misplaced by the deponent due to which another certified copy of the order has been prepared for filing this bail application. The certified copy of the bail rejection order dated 08.05.2023 passed by the court below is being annexed as Annexure No. 08 to this application. That the applicant is in jail since 21.04.2023. The applicant categorically submits that he has no any criminal history nor he has ever been convicted by any court of law. That there is no chance of the applicant absconding or tempering with the prosecution witnesses. That the applicant is ready to furnish the security and bond and also undertake that he will never misuse the liberty of bail. That in view of the above, it would be expedient and necessary in the interest of justice that grant bail to the applicant in relation to Case Crime No. 02 of 2023 under Sections 147, 307, 323, 324, 325, 504, 506 of I.P.C. registered at Police Station – Motigarpur, District – Sultanpur, in the interest of justice.


I, Ram Raj Pal aged about 57 years son of Shri Ram Bachan resident of Payag Patti, Paigapur, Palahipur, District - Sultanpur, Education – Literate, Occupation – _________, do hereby solemnly affirm and state on oath as under :- That the deponent is the _________/ pairokar of the applicant and duly authorized by the applicant to file the aforesaid application before this Hon'ble Court and as such she is fully conversant with the facts of the case and deposed as under. The ID Proof of the deponent is enclosed and his photograph is affixed on the affidavit. That the deponent further declared that the contents of the bail application have been explained by the counsel of the appellant in Hindi and as such he is fully conversant with the facts of the case deposed as under. That the instant matter is not related to CBI/Prevention of Corruption Act/ Enforcement Directorate /matters relating to NRHM Scam / GPF Scam/matters of MP/MLA etc. That in Case Crime No. 28 of 2023 under Sections 308, 323, 504, 506 of I.P.C. registered at Police Station – Bandhua Kalan, District – Sultanpur, another bail application bearing Crl. Misc. Case No. 12662 (B) of 2023 (Sadhuram Pal Vs State of U.P.) has been allowed by Hon'ble Justice Shri Subhash Vidyarthi ‘J’ vide its order dated 30.10.2023. That this is the first bail application before this Hon'ble Court. No any other bail application is pending before this Hon'ble Court or rejected by this Hon'ble Court. That brief facts of the case are that a First Information Report has been lodged against the applicant and three other persons, on 23.02.2023 at 11.56 hours by the informant namely Shri Nanhe Lal son of Shri Ram Prasad resident of Village - Narharpur hamlet of Pikaura, Police Station - Bandhua Kalan, District - Sultanpur (hereinafter referred to as ‘informant’) under Sections 323, 504, 506 of I.P.C. at Police Station – Bandhua Kalan, District – Sultanpur. The certified/photocopy of the First Information Report dated 23.02.2023 is being annexed as Annexure No. 01 to this affidavit. That according to the First Information Report lodged by the informant alleged therein that on 23.02.2023 at about 7.00 A.M., the village pradhan Nandlal Pal (accused of the case crime) called the informant's son Amit Kumar at temple through mobile, as his son reached near to the temple then Nandlal Pal, Sadhuram Pal, Salikram Pal and Sachin Pal, who are already sitting there started hurling abuses and hitting him with lathi-danda and hand, legs-punches, when the son of the informant raised the alarm to his rescue and then informant's wife Gudiya came in rescue for her son. Then, they beat his wife also, and his son Amit sustained many serious injuries. That the injured were brought to the hospital where their treatment was done, in which several injuries were noted by the doctor concerned. The photo/type copies of the medical reports of the injured persons are being annexed herewith as Annexure No. 02 to this affidavit. That on a bare perusal of the medical records of the son of the informant, it is clear that Section 308 of I.P.C. is not attracted as there are no any grievous injuries to the son of the informant. That here it is relevant to mention that the aforesaid First Information Report has been lodged by the informant on false, incorrect, and baseless grounds. That the allegations leveled against the applicant are very superficial, vague, indefinite, and of such nature that the applicant cannot be held guilty. Only general allegations have been made by the informant and no role has been assigned to the applicant. That it is most relevant to mention here that the applicant has not committed any offense as alleged by the informant in his first information report dated 23.02.2023. That on 24.02.2023, the statement of the informant was recorded by the concerned police under Section 161 of Cr.P.C., in which she almost repeated her First Information Report but she stated that due to enmity the applicant and others committed the case crime. The typed copy of the statement of the informant dated 24.02.2023 is being annexed as Annexure No. 03 to this affidavit. That the statements of the son & wife of the informant were recorded under Section 161 of Cr.P.C. on 12.03.2023, in which they repeated the version of the informant however, they have also not assigned any specific role to the applicant. The typed copies of the statements of the son & wife of the informant dated 12.03.2023 are being annexed as Annexure No. 04 to this affidavit. That here it is relevant to mention that neither the informant nor his son & wife assigned any reason or motive for the commission of the aforesaid case crime. That the version of the First Information Report is totally false and baseless and the same depends upon the concocted story as such nothing happened as alleged by the informant in her First Information Report so far concerned to the applicant. That the applicant was arrested by the concerned police on     without any basis merely on the basis of the statement of the informant, who was named by the applicant, his son & wife, while the applicant was not involved in the commission of the crime as alleged against him. That without proper investigation of the case crime, the investigating officer submitted the Charge Sheet on 14.03.2023 under Sections 308, 323, 504, 506 of I.P.C. against the applicant and 3 others for extraneous reasons. That the real fact of the case is that the applicant is innocent and has not committed any offense as alleged against him by the informant. That the applicant and informant are residents of the same village and the informant’s family members opposed the present Village Pradhan in the Village Pradhan election, due to which they have enmity with each other. However, the applicant and other named accused are supporters of the village pradhan. That the informant had several works from the village pradhan but due to political enmity the informant had a dispute with the village pradhan. That on 23.02.2023, the son of the informant was met with the village pradhan, where they fought with each other. The applicant and others were present and they tried to stop the fight but the son of the informant threatened the applicant and others to face consequences of the same. That thereafter, the informant lodged the first information report against the applicant and others on the basis of the wrong and incorrect facts. That the applicant has no concern with the allegations of the informant in any manner and also the prosecution story is totally against the truth and same is not reliable in manner. That neither the applicant has any motive nor has any reasonable motive been assigned to him to commit the crime in question. Merely on the basis of extraneous reason, the applicant has been framed in the said case crime. That there is no credible evidence on record that could show that the applicant has committed the crime in question and the evidence available on the record itself shows that no prima-facie offense under Sections 308, 323, 504, 506 of I.P.C. at Police Station – Bandhua Kalan, District – Sultanpur is made out against the applicant. That since the applicant has not committed any offence as alleged but he has been falsely implicated in the case by the informant with malafide intention with the collusion of the concerned police for an ulterior motive. That the applicant moved bail application No. 153 of 2024 before the learned Additional Sessions Judge, Court No. 1, Sultanpur and his bail application was rejected by the court concerned on 08.02.2024 without considering the facts of the case. Here it is relevant to mention that the free certified copy of the order dated 08.02.2024 has been misplaced by the deponent due to which another certified copy of the order has been prepared for filing this bail application. The certified copy of the bail rejection order dated 08.02.2024 passed by the court below is being annexed as Annexure No. 05 to this application. That the applicant is in jail since ___.___.______. The applicant categorically submits that he has no any criminal history nor he has ever been convicted by any court of law. That there is no chance of the applicant absconding or tempering with the prosecution witnesses. That the applicant is ready to furnish the security and bond and also undertakes that he will never misuse the liberty of bail. That in view of the above, it would be expedient and necessary in the interest of justice that grant bail to the applicant in relation to Case Crime No. 28 of 2023 under Sections 308, 323, 504, 506 of I.P.C. registered at Police Station – Bandhua Kalan, District – Sultanpur, in the interest of justice.


I, Shivam Singh aged about 26 years son of Shri Brijesh Kumar Singh resident of Village - Pure Belkhariyan Gauripur, Chhota, Post - Bishundaspur, District - Amethi, Religion – Hindu, Education – Literate, Occupation – ___________, do hereby solemnly affirm and state on oath as under :- That the deponent is the nephew/ pairokar of the applicant and duly authorized by the applicant to file the aforesaid application before this Hon'ble Court and as such she is fully conversant with the facts of the case and deposed as under. The ID Proof of the deponent is enclosed and his photograph is affixed on the affidavit. That the deponent further declared that the contents of the bail application have been explained by the counsel of the appellant in Hindi and as such he is fully conversant with the facts of the case deposed as under. That the instant matter is not related to CBI/Prevention of Corruption Act/ Enforcement Directorate /matters relating to NRHM Scam / GPF Scam/matters of MP/MLA etc. That this is the first bail application before this Hon'ble Court. No any other bail application is pending before this Hon'ble Court or rejected by this Hon'ble Court. That brief facts of the case are that a First Information Report has been lodged against three persons, on 21.08.2023 at 14.40 hours by Shri Amit Kumar (hereinafter referred to as ‘informant’) under Sections 409, 420 of I.P.C. at Police Station – Chinhat, District – Lucknow. The certified/photocopy of the First Information Report dated 21.08.2023 is being annexed as Annexure No. 01 to this affidavit. That according to the First Information Report lodged by the informant alleged that he ordered 25 Ton Sariya from Patna, Bihar on 17.08.2023, which was sent to him by the seller through transport i.e. vehicle No. UP44-T6023. The informant was regularly in touch of the driver of vehicle No. UP44-T6023 namely Ramji Upadhayay and Transporter, but on 21.08.2023, the mobile of the driver switched off and his material was not delivered to him. That the applicant is not named in the said first information report. That meanwhile, Case Crime No. 223 of 2023 under Section 411 of I.P.C. registered at Police Station - Jamon, District - Amethi on 28.08.2023, in which the applicant has been arrested along with two other persons. The photocopy of the first information report dated 28.08.2023 is being annexed herewith as Annexure No. 02 to this affidavit. That nothing has been recovered from the possession of the applicant at the time of his arrest with regard to stolen material of Case Crime No. 375 of 2023, however, the recovery of Rs. 48,000/- has been mentioned in the recovery-cum-arresting memo. That the Investigating Officer of Case Crime 223 of 2023, has written/ prepared and recorded the same as per his wish and tried their best to collaborate with the alleged incident and witnesses under section 161 Cr.P.C. only to prove the offense against the applicant whereas the applicant has not committed any offense. That the confessional statements of the applicant and other accused were recorded by the concerned police under the life threat, in which the applicant said everything as narrated by the concerned police. That it is most humbly submitted that the applicant is innocent and he has falsely been implicated by the co-accused of Case Crime No. 375 of 20223 in the instant case and there is no evidentiary value in the eye of the law relating to the confessional statements given by the arrested accused along with the applicant. That the name of the applicant came to light in Case Crime No. 375 of 2023 from the statement of the accused of the case crime namely Ramji Upadhyaya i.e. driver of vehicle No. UP44-T6023. That here it is relevant to mention that the aforesaid First Information Report has been lodged by the informant on false, incorrect, and baseless grounds merely on the basis of the presumption and under the life threat of the concerned police the applicant has been named in impugned case crime. That the allegations leveled against the applicant are very superficial, vague, indefinite, and of such nature that the applicant cannot be held guilty. That it is most relevant to mention here that the applicant has not committed any offense as alleged by the informant in his first information report dated 21.08.2023. That the version of the First Information Report is totally false and baseless and the same depends upon the concocted story as such nothing happened as alleged by the informant in his First Information Report so far concerned to the applicant. That the applicant was arrested by the concerned police of District - Amethi on 28.08.2023 without any basis and leveled allegations against him regarding stolen material while the applicant was not involved in the commission of the crime as alleged against him. That the real fact of the case is that the applicant is innocent and has not committed any offence as alleged against him by the informant. That on perusal of the arresting-cum-recovery memo dated 28.08.2023 prepared by the concerned police of the District - Amethi, stated that on 28.08.2023 around 17.12 hours when the applicant was allegedly arrested, the concerned police used the torch to stop the tractor, while in the month of August around 17.12 hours, there is no need of torch. That the applicant has no concern with the allegations of the informant and co-accused in any manner and also the prosecution story is totally against the truth and is not reliable in manner. That neither the applicant has any motive nor has any reasonable motive been assigned to him to commit the crime in question. Merely on the basis of extraneous reason, the applicant has been framed in the said case crime. That there is no credible evidence on record that could show that the applicant has committed the crime in question and the evidence available on the record itself shows that no prima-facie offense under Sections 409, 420 of I.P.C. at Police Station – Chinhat, District – Lucknow is made out against the applicant. That since the applicant has not committed any offense as alleged but he has been falsely implicated in the case by the informant with malafide intention with the collusion of the concerned police for an ulterior motive. That apart from above above case, against the applicant a false case has been lodged bearing Case Crime No. 223 of 2023 under Section 411 of I.P.C., registered at Police Station - Jamon, District - Amethi, in which the applicant has been granted bail by the court below on 02.09.2023. The photocopy of the order dated 02.09.2023 passed by the learned court below is being annexed herewith as Annexure No. 03 to this affidavit. That the applicant has never been convicted by any court of law. That the applicant moved bail application No. 8035 of 2023 before the learned Special Judge, C.B.I. Court No. 3, Lucknow, and his bail application was rejected by the court concerned on 20.10.2023 without considering the facts of the case. The free certified copy of the bail rejection order dated 20.10.2023 passed by the court below is being annexed herewith as Annexure No. 04 to this affidavit. That the applicant is in jail since 28.08.2023 without committing the offense. That there is no chance of the applicant absconding or tempering with the prosecution witnesses. That the applicant is ready to furnish the security and bond and also undertakes that he will never misuse the liberty of bail. That in view of the above, it would be expedient and necessary in the interest of justice that grant bail to the applicant in relation to Case Crime No. 375 of 2023 under Sections 409, 420 of I.P.C. registered at Police Station – Chinhat, District – Lucknow, in the interest of justice.


I, Kallu aged about 58 years son of Jalim resident of Pure Atbal Purwa, Rajapur, District – Gonda, Education – Illiterate, Occupation – Agriculture, do hereby solemnly affirm and state on oath as under:- That the deponent is the father/pariokar of the applicant and duly authorized by the applicant to file the aforesaid application before this Hon'ble Court and as such he is fully conversant with the facts of the case and deposed as under. The ID Proof of the deponent is enclosed and a photo affidavit slip issued by the Oudh Bar Association is affixed to the affidavit. That the deponent further declares that the contents of the affidavit have been explained in Hindi by the counsel of the applicant to him as such she conversant with the facts of the case. That this is the first bail application of the applicant before this Hon'ble Court.  No any other bail application is pending before this Hon'ble High Court or rejected by this Hon'ble High Court. That the instant matter is not related to CBI/Prevention of Corruption Act/ Enforcement Directorate /matters relating to NRHM Scam / GPF Scam/matters of MP/MLA etc. That brief facts of the case are that a first information report was lodged against the applicant on 22.07.2024 by opposite party No. 2 bearing Case Crime No. 333 of 2024 under Section 137(2) of B.N.S., 2023 at Police Station – Paraspur, District – Gonda regarding incident dated 16.07.2024. The certified copy of the first information report dated 22.07.2024 is being annexed herewith as Annexure No. 01 to this affidavit. That according to the first information report the opposite party No. 2 stated in his first information report that on 16.07.2024, the applicant lured away the sister of the opposite party No. 2 (hereinafter referred to as ‘victim’), in which co-accused Muskan helped the applicant. That the first information report was lodged around 6 days from the date of the alleged incident without giving any sufficient reason for delay, which creates doubt upon the prosecution story. That the statement of the victim under Section 180 of B.N.S.S., 2023 has been recorded by the concerned police, in which she changed the version of the first information report and stated another story. That the investigating officer added Section 65(1) of B.N.S., 2023 and 3/4 of The Protection of Children from Sexual Offences Act, 2012 during the investigation. That the statement of the victim under Section 183 of B.N.S.S., 2023 was recorded before the concerned court, in which she changed her statement and also tried to develop his prosecution story to send the applicant behind bars. That the real story of the case is that the applicant and opposite party No. 2 are residents of the same area. That the applicant had not committed any offense as alleged by the opposite party No. 2 but he was falsely implicated in the case crime due to village party bandi. That thereafter, the opposite party No. 2 in well-planned manner, lodged the first information report saying therein that the applicant abducted his sister, and later the applicant has been charged a commission of the rape. That the prosecution story as narrated therein is highly improbable, improper unnatural, and unbelievable for a prudent man. That there is no evidence against the applicant to connect him with the aforesaid case crime. That the statement of the victim under Section 180 & 183 of B.N.S.S., 2023 Cr.P.C. has not collaborated with each other, which clearly shows that the applicant has not committed offence as alleged against him. That in the present case there is sufficient evidence on record to show that the applicant did not commit the offence. That since the applicant has not committed any offence as alleged but he has been falsely implicated in the case by the opposite party No. 2 and their family members with malafide intentions. That the applicant moved bail application bearing No. 1621 of 2024 before Sessions Judge, Gonda, and his bail application has been rejected by the Additional Sessions Judge/ Special Judge (POCSO) Act, Gonda on 12.08.2024. The free certified copy of the order dated 12.08.2024 passed by the learned court concerned is being annexed herewith as Annexure No. 02 to this affidavit. That the applicant has been languishing in jail since 29.07.2024 without committing any offense as alleged against the applicant. That the applicant has no criminal history except the aforesaid false case and is not likely to hope in the future to commit any offence. That there is no chance of the applicant absconding or tempering with the prosecution witnesses. That the applicant is ready to furnish the security and bond and also undertakes that he will never misuse the liberty of bail. That in view of the above, it would be expedient and necessary in the interest of justice that the applicant be enlarged on bail in connection with Case Crime No. 333 of 2024 under Sections 137(2), 65(1) of B.N.S., 2023 and 3/4 of The Protection of Children from Sexual Offences Act, 2012 registered at Police Station – Paraspur, District – Gonda, in the interest of justice.