I, Virendra Kumar aged about 26 years son of Ram Pratap, resident of Village – Asthan, Abdul Wahidganj, Police Station – Nawabaganj, District – Pratapgarh, Religion – Hindu, Education – Literate, Occupation – Lobour, do hereby solemnly affirm and state on oath as under :- That the deponent is the son/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 her photograph is affixed on 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 brief facts of the case is that a first information report has been lodged against the 25 named persons including the applicant and 500-600 unknown persons on 23.06.2012 at 20.20 hours by the informant namely Fayyaj Ahmad son of Jaleel Ahmad resident of Village - Asthan, Police Station – Nawabganj, District – Pratapgarh (hereinafter referred to as ‘informant’) bearing Case Crime No. 88 of 2012 under Sections 147, 148, 149, 307, 452, 436, 382, 295, 506, 435, 395 of IPC and 7 of Criminal Law Amendment Act at Police Station – Nawabganj, District – Pratapgarh regarding beating, fireborn, looting only on basis of wrong, false and presumption. The certified/ typed copy of the first information report dated 23.06.2012 is being annexed as Annexure No. 01 to this affidavit. That according to the first information report lodged on 23.06.2012, he stated that on 23.06.2012 he was at home, he heard hubbub outside, when he came out then saw that several villagers have armed with lathi danda and other sharped weapons and they have looted all house and put on fire each and every house of the area and also giving life threat to the informant and his family members. That here it is relevant to mention that as per allegation of the informant has not said what the reason of said incident. That it is pertinent to mention that the applicant was not the part of the said mob as alleged by the informant, he named the all persons of the nearby his house or who have well known by him and area. That the version of the first information report is totally false and baseless and same depends upon concocted story as such nothing done by the applicant as alleged by the informant in his first informant report. That the investigating officer recorded the statement of the informant under Section 161  Cr.P.C. on 26.06.2012 in which the informant repeated his first information report version and tried to implicate the applicant in said case crime, which itself false, incorrect and on the basis of presumption. The type copy of the statement of the informant dated 26.06.2012 is being annexed as Annexure No. 02 to this affidavit. That the informant also stated the mob carrying the petoral can but further stated that the mob sprayed the petrol, diesel and kerocein oil on the houses and put on fire and also given some other named on basis of the hearsay evidences. That on 26.06.2012, the several statement of other persons have been recorded they also given similar statements to the concerned police under Section 161 of Cr.P.C. and it is very strange that almost all witnesses stated same story, as someone narrated to all of them. That the confessional statements of the several accused of the case crime have recorded by the investigating officer on various dates under the pressure of the then rulling party and under life threat, in which the accused given ditto similar statements as narrated by the concerned police. That it is also unbelievable at time of alleged incident the informant and others were only looking the mob and not participated in the communal riots. That thereafter without proper investigation and without considering the fact and reality of the case, the investigating officer of the case crime under pressure filed 4 charge sheets bearing No. 33, 33A, 33B and 33C on 07.08.2012, 29.11.2012, 15.12.2012 and 12.01.2013 respectively. The applicant charge sheeted in charge sheet No. 33C dated 12.01.2013. That the real story is that on 20.06.2012 a rape has been committed by the four local resident of the muslim community with a 11 years Hindu girl and after commission of the rape with said girl, they have brutally murdered the girl. That the concerned police was not lodging the first information report regarding the murder and rape of minor girl but after lot of effort a first information report lodged on 21.06.2012 bearing Case Crime No. 87 of 2012 under Sections 376, 302 of IPC at Police Station – Nawabganj, District – Pratapgarh. The photo/typed copy of the first information report dated 21.06.2012 is being annexed as Annexure No. 03 to this affidavit. That during investigation of case crime No. 87 of 2012, the Section 376(2) F & G of IPC and 3(2)5 of SC & ST Act added by the investigating officer and charge sheet was filed against the three accused under 376(2) F & G, 302, 34 of IPC and 3(2)5 of SC & ST Act. That here it is relevant to mention that the accused of the case crime No. 87 of 2012 have been convicted for life impresionment and fine vide order dated 01.10.2016 passed by the Additional Sesseion Judge, Court No. 1, Pratapgarh. Against said conviction order, the two criminal appeal has been filed and is pending before this Hon'ble High Court. That after lodging of the first information report, the several persons i.e. relatives of the accused moking the Hindu comminting and they were saying that they are in power and they have to committed such offense with other girls due to which there was full chance of communal riots. That later on 23.06.2012, the Hindu comminuty heared tha the after feduping of the other community persons as they following the informant of the Case Crime No. 87 of 2012 to murder him then the several persons have gathered moved to the residential area of the other community, where they both community fight with each other. That thereafter under the political pressure the case crime in question has been lodged against the 500-600 unknown persons and 25 known persons including the applicant. That the aforesaid incident became a political tool for the all state and national political parties hence under the pressure of the then rulling party, only one community i.e. Hindu targeted for accusing while in the communal riots both community were involved. That the applicant has no concerned with the incident took place on 23.06.2012 in any manner as alleged by the concerned police and allegation against the applicant and also the prosecution story is totally against truth and same is not reliable in manner. That neither the applicant has motive nor has any reasonable motive been assigned to him to commit the crime in question. That the informant only basis of the presumption that all villagers are involve in incident named the applicant without seeing him. That there is no credible evidence on record which could show that the applicant is guilty or committed the crime in question and the evidence available on record itself show that no prima-facie offence under Sections 147, 148, 149, 307, 452, 435, 382, 436, 395, 295, 323, 506 of IPC and 7 of Criminal Law Amendment Act registered at Police Station – Nawabganj, District – Pratapgarh is made out against the applicant. That the applicant was not awared about the said first information report and no summon or warrant severed ever upon the applicant but he has arrested on 12.05.2022 in furtherance of Non Bailable Warrant issued by the trial court by the concerned police. That the applicant moved bail application No. 1423 of 2022 before the learned Sessions Judge, Pratapgarh and his bail application has been rejected by the court concerned on 31.05.2022. The free certified copy of the bail rejection order dated 31.05.2022 passed by court below is being annexed as Annexure No. 04 to this application. That the applicant is in jail since 12.05.2022 without committing any offense. That the applicant has no criminal history ever. That there is no chance of the applicant absconding or tempering with the prosecution witnesses. That the applicant is ready to furnished the security and bond and also undertake that he will be never misused 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. 88 of 2012 under Sections 147, 148, 149, 307, 452, 435, 382, 436, 395, 295, 323, 506 of IPC and 7 of Criminal Law Amendment Act relating to the Police Station – Nawabganj, District – Pratapgarh, during pendency of his trial.


I, Kr. Laxmi aged about 18 years daughter of Shri Rajjanlal resident of Village – Kushlikheda hamlet of Khairhani, Police Station – Bachhrawan, District – Raiberelly, Religion – Hindu, Education – Literate, Occupation – Student, do hereby solemnly affirm and state on oath as under :- That the deponent is the daughter 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 photo verification slip is affixed on the affidavit. That this is the first bail application before this .  No any other bail application pending before this  or rejected by this . That brief facts of the case is that a first information report has been lodged by the applicant herself against three named and 4 unnamed persons on 10.02.2021 on 00.10 hours under Sections 363, 366 of I.P.C. mentioning the incident took place on 09.02.2021. The photocopy of the first information report dated 10.02.2021 lodged by the applicant is being annexed as Annexure No. 01 to this affidavit. That the applicant stated in her first information report that the accused of the first information report have kidnapped her son namely Shivansh aged about 14 years, when he was irrigating the field. The said incident took place on 09.02.2021 around 03.30 PM. That after moving the application for lodging the first information on 09.02.2021, the applicant was stayed at concerned Police Station as stated by the police personnel of the concerned police. That later on, night of the 10.02.2021 around 00.10 AM first information lodged by the concerned police. That the applicant was in Police Station – Bachhrawan as the concerned police were assuring the applicant they will informed with regard to development of the case. That meanwhile the son of the applicant was recovered by the concerned police from the custody of the accused persons of the case crime but due to extraneous reasons, the applicant has been falsely implicated in the case crime by the concerned police and accused of the case crime on false allegations. That the concerned police for showing their good work, while they were working for the accused persons, prepare a false recovery memo on 10.02.2021 stating therein that the applicant herself hide her son in a room for falsely implicate the accused of the case crime. The typed copy of the recovery memo dated 10.02.2021 is being annexed as Annexure No. 02 to this affidavit. That statement of the son of the applicant has been recorded by the concerned police under Section 161 of Cr.P.C. dated 10.02.2021 in which he stated that his mother locked him. The typed copy of the statement of the Shivansh dated 10.02.2021 is being annexed as Annexure No. 03 to this affidavit. That the concerned police also recorded the statement of the accused of the case crime namely Vijay Kumar under Section 161 of Cr.P.C. on 10.02.2021 in which he stated that the applicant lodged false first information report against him and others. The typed copy of the statement of Vijay Kumar dated 10.02.2021 is being annexed as Annexure No. 04 to this affidavit. That the concerned police recorded the statement of the father-in-law of the applicant namely Ahorideen, who was the alleged eyewitness of the recovery memo. The typed copy of the statement of the Ahorideen dated 10.02.2021 is being annexed as Annexure No. 05 to this affidavit. That the real fact of the case is that husband of the applicant is residing in State of Kerala and the applicant is residing with her three children in Village – Kushlikheda hamlet of Khairhani, Police Station – Bachhrawan, District – Raiberelly. That the applicant has three children, 1. Laxmi aged about 18 years, 2.  Shivansh aged about 14 years and 3. Priyansh aged about 8 years. The applicant is poor lady and having responsibility of her children. That the applicant has dispute relating to the property with her father-in-law. And whenever the applicant demanded share of her husband in the property then her father & brother-in-laws of the applicant have beaten and threaten for life to the applicant. That the applicant lodged a first information report against her father & brother-in-laws on 15.07.2020 bearing Case Crime No. 400 of 2020 under Section 323, 504, 506, 325 of IPC at Police Station – Bachhrawan, District – Raiberelly regarding beaten and life threat. The photocopy of the first information report dated 15.07.2020 lodged by the applicant is being annexed as Annexure No. 06 to this affidavit. That the concerned police has not taken any action against the father & brother-in-laws of the applicant due to which again they all have beaten and threaten to the applicant on 18.07.2020. That again the applicant lodged a first information report against her father-in-law and son-in-law on 18.07.2020 bearing Case Crime No. 402 of 2020 under Section 323, 506, 427 of IPC at Police Station – Bachhrawan, District – Raiberelly regarding beaten and life threat. The photocopy of the first information report dated 18.07.2020 lodged by the applicant is being annexed as Annexure No. 07 to this affidavit. That it is further relevant to mention that the son of the accused Vijay Kumar namely Ravi owned a bike repairing shop in front of the applicant’s house and he was regularly visited the house of the applicant. That Ravi always helping the applicant in several agricultural works, this is not acceptable by father of Ravi i.e. Vijay Kumar. That due to aforesaid reason, the accused Vijay alongwith others kidnapped the son of the applicant on 09.02.2021 therefore the applicant lodged the first information report against accused persons. That the accused having good political approach and also having muscle and money power due to which the concerned police for the extraneous reasons trapped the applicant in her first information report with the help of the brother & father-in-law of the applicant, who become eyewitnesses of the alleged recovery memo. That the applicant was stayed in the Police Station – Bachhrawan till recovery and false accusation, which would be clear by CDR of the applicant’s mobile No. 9936494278 and her son Shivansh’s mobile No. 9044072138. The CDR of the applicant clearly reveals that she had not hide her son in a room as alleged against her. That the applicant has been moved a bail application before the court concerned bearing Bail Application No. 397 of 2021, which has been rejected by the court concerned without considering grounds raised by the applicant on 03.03.2021. The free copy of the order dated 03.03.2021 passed by court concerned is being annexed as Annexure No. 08 to this application. That the applicant in jail since 12.02.2021 without committing any offense. That investigating officer has not found any evidence against the other accused on the basis of statements of the witnesses. That there is no any evidence found by the investigating officer in regard of false accusation but she has been falsely implicated by the concerned police for extraneous reasons. That the applicant is innocent and due to take revenge with informant falsely implicated in the aforesaid case crime. That there is no any evidence against the applicant to connect her with the aforesaid case crime and the only evidence against the applicant in regard of alleged offence is only false story and baseless recovery and statement of the father-in-law of 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 no any involvement in the said case as alleged in first information report, the applicant has no reason to murder the deceased. That a false story cooked up by the concerned police and informant as the applicant committing the aforesaid case crime. That the applicant has no criminal history except this false case. That there is no chance of the applicant absconding or tempering with the prosecution witnesses. That the applicant is ready to furnished the security and bond and also undertake that he will be never misused 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 during pendency of case.


I, Karunesh Prasad aged about 49 years son of Shri Ganesh Prasad resident of Village & Post – Bhadari, Police Station – Kunda, District – Pratapgarh, Religion – Hindu, Qualification – Post Graduate, Occupation – Teacher, the deponent do hereby solemnly affirm and  state on oath as under :- That the deponent is brother-in-law of applicant and doing pairvi of Applicant in the above noted case and duly authorized by him for filing instant application before the Hon'ble Court and as such he is fully conversant with the facts of the case deposed herein under. That the photo verification slip of the deponent issued by the Awadh Bar Association, Lucknow is being pated on the first page of this affidavit and photocopy of ID proof of the deponent is being annexed with this affidavit. That this is first bail application on behalf of the Applicant before the Hon'ble Court and not 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. 48 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C. and 60, 63 of U.P. Excise Act, 1910 at Police Station – Hathigawan, District – Pratapgarh on 01.04.2021 at 05.32 hours against the applicant, another known and several other unknown persons. The certified copy/ typed copy of the first information report dated 01.04.2021 is being annexed herewith as Annexure No. 1 to this Affidavit. That according to the First Information Report, which has been lodged by Shri Doodhnath Singh Yadav, Station House Officer, Police Station - Hathigawan, District – Pratapgarh (hereinafter referred to as ‘informant’) the prosecution story is in nutshell that the informant and his team on patrolling of area on 31.03.2021 and that time the informant got information in regard of huge adulterated liquor is being prepared by the applicant and other persons and they are selling the same. That the raid has been conducted by the informant along with his team on 31.03.2021 at alleged place of the applicant and seized lot of adulterated liquor. That the name of the applicant was told by the informer (eq[kfcj) of the concerned police prior to raid and on basis of which the applicant is named in the first information report. That the applicant is common man of society and has no concerned with the adulterated liquor but due to political vendetta, the applicant named by the concerned police due to extraneous reasons. When the applicant came into knowledge that the concerned police searching the applicant in aforesaid case crime, then the applicant has surrendered before the court concerned on 17.06.2021. That the real fact is that the applicant are falsely implicated in the case crime due to political reasons by the some villagers, which has been explained by the concerned police for the ulterior motive. That the applicant and his family members were not supporting to a candidate of the Village Pradhan, who has good political approach, who has money & men power. That the applicant was threatened by the village pradhan candidate to give his support alongwith his family but the applicant has denied for the same. That therefore the applicant has threatened by the village Pradhan candidate to face consequences for his denial and said that he will ensured that the applicant send to  jail soon. That the wife of the applicant is elected as member kshetra panchayat due to which, the several villager are not happy with the applicant as the applicant is belonging the S.C. category. That on 01.04.2021, a first information report has been lodged by the concerned police due extraneous consideration, the applicant has been falsely implicated in the case crime. That it further relevant to mention that the Tanki test of alleged adulterated liquor has not been conducted by the Excise Officer concerned. While the Excise Inspector was present at time of alleged raid, even the informant and Excise Inspector were themselves not assured that the recovered liquor is adulterated. That on bare perusal of the first information report, it is also evident that there were no witnesses of raid conducted by the informant, which also creates doubts upon the story of the informant, which itself concocted and false. That the applicant is in jail since 17.06.2021 without committing any offense as alleged against them. That according to the prosecution story it clearly reveals that no one saw the occurrence and there are no any independent eye witnesses 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 applicant has no concerned with recovered adulterated liquor in any manner as such the Sections 420, 467, 468, 471, 272, 273 of I.P.C. and 60, 63 of U.P. Excise Act, 1910 at Police Station – Hathigawan, District – Pratapgarh have not followed him. That the sample of the alleged adulterated liquor for chemical report had sent on 13.04.2021 as mentioned in the CD No. 35 dated 30.07.2021, while there is no entry made in the CD dated 13.04.2021 mentioning that the samples have been send for forensic test. However, till date there is no any chemical report stating therein that the recovered liquor was obnoxious or spurious for human consumption. That as per recovery report, the concerned police recovered a container of adulterated liquor, which has not been sent for the forensic test by the investigating officer due to ulterior motive. The photocopy of the letter dated 11.04.2021, which has been sent for forensic test to concerned lab on 13.04.2021 is annexed herewith as Annexure No. 2 to this affidavit That the applicant has no criminal history except this false case, lodged by the informant for extraneous reasons. That the applicant is Safaikarmi and was discharging his duties in Village Panchayat – Shahpur, Block – Kunda, District – Pratapgarh. That it is further relevant to mention that under construction house, where the adulterated liquor recovered, is neither owned by the applicant nor having any connection with said house. That the investigating officer allegedly recorded the confessional statement of the applicant under Section 161 of Cr.P.C. in which he stated that the petitioner owned the house, where the concerned police recovered the adulterated liquor. The applicant knew that Sudhakar Singh and Guddu Singh is doing business of adulterated liquor due to which the applicant given the said under construction house to them for using it as storage. The typed copy of the confessional statement of the applicant is annexed herewith as Annexure No. 3 to this affidavit. That the statement of another accused Guddu Singh alias Sanjay Pratap Singh surrendered before the court concerned and his statement under Section 161 of Cr.P.C. has been recorded by the concerned police. In which he never said that the applicant gave his under construction house for purpose of storage of the adulterated liquor. The typed copy of the statement of the another accused of the case crime is annexed herewith as Annexure No. 4 to this affidavit That without proper investigation of the case crime, the investigating officer submitted the charge sheet against the applicant and other on 09.08.2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C. and 60, 63 of U.P. Excise Act, 1910. That as nothing has been recovered from the possession of the applicant as such the Section 60 of the U.P. Excise Act, 1910 not attract so far concerned to the applicant. That the applicant has not committed any crime as alleged in the first information report by the informant and he has no concern. That there is no possibility of the applicant’s conviction because he has not committed the crime in question, as alleged by the prosecution. That the applicant is common man of the society. He has never convicted in any case and not involved in any criminal activities ever. That the applicant had applied for bail before the Sessions Judge, Pratapgarh bearing Bail Application No. 1672 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C. and 60, 63 of U.P. Excise Act, 1910. The free certified copy of bail rejection order dated 02.09.2021 passed by the court concerned is annexed herewith as Annexure No. 5 to this affidavit. That another accused Rahul Singh and Kamlesh Singh of aforesaid case crime have been granted bail by the learned court below on 26.05.2021 and 28.05.2021 respectively in similar sections. The photocopy of the order dated 26.05.2021 passed by the court concerned is annexed herewith as Annexure No. 6 to this affidavit. That there is no chance of applicant’s 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 will cooperate with the trial and will not tamper the prosecution witnesses. That the applicant undertakes that he 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 deems fit and proper in the circumstances of the case. 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. 48 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C. and 60, 63 of U.P. Excise Act, 1910 registered at Police Station – Hathigawan, District – Pratapgarh during pendency of trial.


I, Jai Prakash Pushapar aged about 48 years son of Shri Chiraunhi Lal resident of Village – Gayaspur, Police Station – Kunda, District – Pratapgarh, Religion – Hindu, Qualification – Literate, Occupation – Gardner, the deponent do hereby solemnly affirm and  state on oath as under :- That the deponent is brother-in-law (sala) of applicant and doing pairvi of Applicant in the above noted case and duly authorized by him for filing instant application before the Hon'ble Court and as such he is fully conversant with the facts of the case deposed herein under. That the photograph of the deponent is being pated on the first page of this affidavit and photocopy of ID proof of the deponent is being annexed with this affidavit. That this is first bail application on behalf of the Applicant before the Hon'ble Court and not 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. 50 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60(2), 63 of U.P. Excise Act, 1910, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 at Police Station – Hathigawan, District – Pratapgarh on 03.04.2021 at 23.52 hours against the applicant and several other accused persons. The certified copy/ typed copy of the first information report dated 03.04.2021 is being annexed herewith as Annexure No. 1 to this Affidavit. That according to the First Information Report, which has been lodged by Shri Doodhnath Singh Yadav, Station House Officer, Police Station - Hathigawan, District – Pratapgarh (hereinafter referred to as ‘informant’),  the prosecution story is in nutshell that the informant lodged a first information report against the applicant and several other persons on 03.04.2021 about 23.52 hours and stated that the informant and his team was on patrolling of area on 02.04.2021 and that time the team of Surveillance Cell, Prayagraj Zone met with the informant and informed that his team got information from his informant (eq[kfcj), who told the all 19 names of the accused and stated that from Parsipur Cowshed they are involved in the smuggling the adulterated liquor. That the raid has been conducted by the informant along with his team on 02.04.2021 around 16.40 hours at alleged place of occurrence and seized lot of adulterated liquor and no anyone arrested by the concerned police at time raid. That the name of the applicant was told by the informer (eq[kfcj) of the concerned police prior to the raid and he was not present there and on basis of which the applicant is named in the first information report. That the name of the applicant is shown at serial No. 14 in the accused column impugned first information report dated 03.04.2021. That the impugned first information report dated 03.04.2021 is lodged after one day delayed i.e. on 03.04.2021 by the concerned police without giving any reason for delay. That the applicant is common man of society and has no concerned with the adulterated liquor and during the raid the applicant were not present at the place of incident. When the applicant came into knowledge that the concerned police searching the applicant in aforesaid case crime, then the applicant has surrendered before the court concerned on 24.06.2021. That the real fact is that the applicant are falsely implicated in the case crime due to political reasons by the some villagers, which has been explained by the concerned police for the ulterior motive. That the applicant and his family members were not supporting to a candidate of the Village Pradhan, who has good political approach, who has money & men power. That the applicant was threatened by the village pradhan candidate to give his support alongwith his family but the applicant has denied for the same. That therefore the applicant has threatened by the village Pradhan candidate to face consequences of the denial and said that he will ensured that the applicant send to  jail soon. That on 03.04.2021, a first information report has been lodged by the concerned police due extraneous consideration, the applicant has been falsely implicated in the case crime. That it further relevant to mention that the Tanki test of alleged adulterated liquor has not been conducted by the Excise Officer concerned and even prior to information regarding said liquor, while the Excise Inspector was present at time of alleged raid, even the informant and Excise Inspector were themselves not assured that the recovered liquor is adulterated. That on bare perusal of the first information report, it is also evident that there were no witnesses of raid conducted by the informant, which also creates doubts upon the story of the informant, which itself concocted and false. That the applicant is in jail since 24.06.2021 without committing any offense as alleged against them. That according to the prosecution story it clearly reveals that no one saw the occurrence and there are no any independent eye witnesses 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 applicant has no concerned with recovered adulterated liquor in any manner as such the Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60A, 60(2), 63 of U.P. Excise Act, 1910, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 at Police Station – Hathigawan, District – Pratapgarh have not followed him. That the applicant had applied for bail before the Sessions Judge, Pratapgarh bearing Bail Application No. 1552 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60(2), 63 of U.P. Excise Act, 1910, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 and when Section 60A of U.P. Excise Act, 1910, which has been rejected by the court concerned without going to fact and records. The free certified copy of bail rejection order dated 17.08.2021 passed by the court concerned is annexed herewith as Annexure No. 2 to this affidavit. That another accused Anoop Singh of aforesaid case crime has been granted bail by the learned court below on 14.07.2021 in similar sections. The photocopy of the order dated 14.07.2021 passed by the court concerned is annexed herewith as Annexure No. 3 to this affidavit. That till date there is no any chemical report stating therein that the recovered liquor was obnoxious or spurious for human consumption. That the applicant has a criminal history except this false case and detail of the said case is as under: Case No. RC-2 (S) 2013/C.B.I./SC-1/New Delhi under Section 302, 147, 148, 149, 323, 332, 353, 506 and 201 of IPC read with 149 of IPC and 27 Arms Act, in which nothing has been found against applicant and he has been exonerated from the charges. The photocopy of the supplementary charge sheet filed by CBI is annexed herewith as Annexure No. 4 to this affidavit. That the applicant has not committed any crime as alleged in the first information report by the informant and he has no concern. That there is no possibility of the applicant’s conviction because he has not committed the crime in question, as alleged by the prosecution. That the applicant is common man of the society. He has never convicted in any case and not involved in any criminal activities ever. That there is no chance of applicant’s 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 will cooperate with the trial and will not tamper the prosecution witnesses. That the applicant undertakes that he 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 deems fit and proper in the circumstances of the case. 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. 50 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60A, 60(2), 63 of U.P. Excise Act, 1910, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 registered at Police Station – Hathigawan, District – Pratapgarh during pendency of trial.


I, Raj Kumar Prajapati aged about 38 years son of Shri Ram Bahadur resident of Ilayatganj Gadi Manikpur, Police Station – Kunda, District – Pratapgarh, Religion – Hindu, Qualification – Class 8th passed, Occupation – Labor, the deponent do hereby solemnly affirm and  state on oath as under :- That the deponent is relative of applicant and doing pairvi of applicant in the above noted case duly authorized by him and as such he is fully conversant with the facts of the case deposed herein under. That the photograph of the deponent is being pated on the first page of this affidavit and photocopy of Voter ID of the deponent is being annexed with this affidavit. That this is first bail application on behalf of the applicant before the  and not 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 first information report lodged in case crime No. NIL of 2014 under section 395/397/328 I.P.C. Police Station – Salon, District – Raiberelly on 19.06.2014 at 09:30 hours. Thereafter aforesaid registered same day at 20:15 bearing G.D. No. 38 case Crime No. NIL of 2014 converted as case crime No. 396 of 2014 under section 395/397/328 I.P.C. registered at Police Station – Salon, District – Raiberelly. That the applicant have falsely been implicated in case crime No. 396 of 2014 under section 395/397/328 I.P.C. registered at Police Station – Salon, District – Raiberelly on 19.06.2014 for the incident dated 17.06.2014. The true photo/type copy of the first information report dated 19.06.2014 is being annexed herewith as Annexure No. 1 to this Affidavit. That the first information report is lodged by the one namely Arun Yadav who was the driver of the truck. According the First Information Report the prosecution story is, the driver Arun Yadav and helper Sonu Yadav was moved from East India Transport Agency, Vardhana to Lucknow with the 432 bori Supari weighted 28,500 KGs which was loaded in the truck MP 28-H-1070 on 14.06.2014. In midnight of 17.06.2014 on Raiberelly Road 6-7 persons are come with together with vehicle Boloro and stopped the truck forcefully and give the intoxicating substance to drink, thereafter they become unconscious and when they came in conscious they are at Risalpur, Near Manikpur road and half of loaded Supari, which is in truck, was looted by the aforesaid persons. That the applicant was not named in the first information report. His name comes in light in the statement of the helper namely Sonu Yadav of the aforesaid truck, being drive of the recovered vehicle. That the statement of the informant has been recorded by the investigation officer under section 161 of Cr.P.C. on 19.06.2014. The typed copy of the statement of the informant is being annexed herewith as Annexure No. 2 with this application. That the statement of the Sonu, the helper of the aforesaid truck has been recorded by the investigation officer on 19.06.2014 under section 161 Cr.P.C.. That thereafter on 20.06.2014 the Majeed Bayan of helper of the aforesaid truck has been recorded by the investigation officer therein the helper revealed the detailed story of the case and the name of the applicant name has came in light by the majeed bayan of the helper, only as driver of the recovered Innova. The typed copy of the statement of the helper of the aforesaid truck is being annexed herewith as Annexure No. 3 with this application. That the applicant arrested from his house with his motor cycle. Motor cycle of the applicant is ceased by the Police Station – Salon as Lawaris and arresting of the applicant shown from the recovered vehicle Innova for showing the good work of the concerned Police Station. That according to the recovery memo nothing was recovered from the applicant by the police. It is relevant to mention here that the applicant was driver of the recovered vehicle Innova, no any other concerned with the applicant and the applicant not drive the said recovered vehicle Innova at the time of arresting the other accused. That it is also relevant to mention here that nothing was recovered by the police on the pointing out of the applicant. That according the statement of the helper of the aforesaid truck, the applicant has no any roll assigning and involvement in aforesaid crime. The only two names reveals in involvement of the crime 1.  Raju and 2. Anil. That the recovered vehicle bearing registration No. MH -06 – AF - 1586 is vehicle Innova and same is evident from the registration certificate of the same. But in the first information report the vehicle is mentioned as Boloro. The photocopy of the registration certificate of the vehicle is being annexed as Annexure No. 4 to this application. That the applicant is only driver of the recovered vehicle. There is no any other concerned with the same and being a drive of the said vehicle as per direction of the owner of the vehicle, he was driving the vehicle. That the being driver of the recovered vehicle Innova, the applicant falsely implicated in the said crime. That the no any specific roll was assigned by the prosecution against the applicant nor innovation in the conspiracy of the case crime. That a contradiction in the statement of the helper and informant’s statement, according the helper he seeing the incident took on place in midnight of 18/19.06.2014 but the in the first information report the incident dated mention as midnight of 17.06.2014. That the investigation officer recovered the vehicle Innova only showing the good work of the police department. That the recovery of the vehicle Innova with the applicant, is highly suspicious and contradictory because of the applicant is only driver of the aforesaid vehicle Innova. That the applicant has not committed any crime as alleged in the first information report and he has no concern. That there is no possibility of the applicant conviction because he has not committed the crime in question, as alleged by the prosecution. That the applicant is respectable person of the society. He has never involved in any criminal activities and has no any criminal history. That there is no chance of applicant absconding or tampering with the prosecution witnesses and they are willing to offer bail to the satisfaction of this . That the applicant is in Jail since ……………………. That the applicant will cooperate with the trial and will not tamper the prosecution witnesses. That the applicant undertakes that they will not misuse the liberty of bail if so granted by this . That the applicant is ready and willing to file adequate surety as the  may deems fit and proper in the circumstances of the case. That the applicant had applied for bail before the Sessions Judge, Raiberelly but the same has been rejected on insufficient grounds vide order dated 23.07.2014. The certified copy of bail rejection order dated 23.07.2014 is annexed herewith as Annexure No. 5 to this affidavit. That in view of the above, it would be expedient and necessary in the interest of justice that the applicants be enlarged on bail during pendency of trial.


I, Shivsharan Yadav aged about 22 years son of Shri Amarpal Yadav, resident of Village – Raipur Maheva, Police Station – Salon, District – Raiberelly, Religion – Hindu, Qualification – Literate, Occupation – Business, the deponent do hereby solemnly affirm and  state on oath as under :- That the deponent is brother of applicant and doing pairvi of applicant in the above noted case and duly authorized by him for filing instant application before the Hon'ble Court and as such he is fully conversant with the facts of the case deposed herein under. That the photograph of the deponent is being pasted on the first page of this affidavit and photocopy of ID proof of the deponent is being annexed with this affidavit. That this is first bail application on behalf of the applicant before the  and not 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. 02 of 2021 under Sections 272, 419, 420 of IPC and 60, 72 of U.P. Excise Act, 1910 at Police Station – Unchahar, District – Raiberelly on 01.01.2021 at 04.40 hours against the applicant. The first information report is lodged by Sub Inspector, Unchahar, District – Raiberelly namely Shri Ramdas Verma. The certified copy of the first information report dated 01.01.2021 is being annexed herewith as Annexure No. 1 to this Affidavit. That according to the First Information Report the prosecution story is, in nutshell, that the informant and his team (other police personnel) were on patrolling of the area in the night of 31.12.2020 at that time the informant got information from his informer regarding of huge adulterated liquor is being transporting in area by the Mahindra Pick-up. Thereafter the informant and his team stopped the vehicle then the applicant was driving and he was arrested by them informant and his team with adulterated liquor. That it is further relevant to mention here that on bare perusal of the first information report it is clear that the informant himself stated that on scanning of the bar code of the alleged adulterated liquor, it was not confirmed that the liquor is adulterated but the informant arrested the applicant. That the applicant is common man of society and has no concerned with the adulterated liquor and during the checking the applicant was not there, the concerned police arrested the applicant from Batohi Restaurant, Unchahar, District – Raiberelly  without any reason and falsely implicate in said case crime for showing good work of the police. That the real fact is that the applicant is falsely implicated in the case crime for ulterior motive by the concerned police. That the applicant is respected person of the area and common man of the society and running a Building Material Shop in local market i.e. Raipur Maheva. That the applicant has no concerned with vehicle seized by the concerned police and recovered adulterated liquor in any manner as he was arrested from Batohi Restaurant, Unchahar, District – Raiberelly, where he was present with his friends for celebration of New Year, 2021 but the police concerned falsely implicated in said case crime. That the Tanki test of alleged adulterated liquor has not been conducted by the Excise Officer concerned and even prior to information regarding said liquor, the informant has not informed to the excise officer concerned, even the informant was himself not assured that the recovered liquor is adulterated but he has arrested the applicant from Batohi Restaurant, Unchahar, District – Raiberelly and falsely implicated in said case crime. That on bare perusal of the first information report, it is also evident that there were no witnesses of raid conducted by the informant even he has not endorsed any averment with said regard, which also creates doubts upon the story of the informant, which itself concocted and false. That the applicant/accused in jail since 01.01.2021 without committing any offense as alleged against him. That according to the prosecution story it clearly reveals that no one saw the occurrence and there are no any independent eye witnesses of the said recovery and it is a case of forge, fabricated and false and there is no any evidence against the applicant/accused. That the applicant/accused has no concerned with recovered adulterated liquor in any manner as such the Sections 272, 419, 420 of IPC and 60, 72 of U.P. Excise Act, 1910 at Police Station – Unchahar, District – Raiberelly have not followed him. That the informant arrested the applicant at alleged place of recovery but not found anything from the applicant except the liquor seized by him and vehicle. That it is not possible that the applicant was driving the seized vehicle from State of Madhya Pradesh but he was not carrying the any relevant papers, i.e. driving license, vehicle papers, money and etc. as such story of the informant is false and incorrect and so far from the reality. That the applicant had applied for bail before the Additional Sessions Judge, Raiberelly but the same has been rejected on insufficient grounds vide order dated 12.01.2021. The free certified copy of bail rejection order dated 12.01.2021 is annexed herewith as Annexure No. 2 to this affidavit. That the applicant has no criminal history except this false case, lodged by the informant for extraneous reasons. That the applicant has not committed any crime as alleged in the first information report by the informant and he has no concern. That there is no possibility of the applicant conviction because he has not committed the crime in question, as alleged by the prosecution. That the applicant is common man of the society. He has never convicted in any case and not involved in any criminal activities ever. That there is no chance of 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 will cooperate with the trial and will not tamper the prosecution witnesses. That the applicant undertakes that they will not misuse the liberty of bail if so granted by this . That the applicant is ready and willing to file adequate surety as the  may deems fit and proper in the circumstances of the case. 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. 02 of 2021 under Sections 272, 419, 420 of IPC and 60, 72 of U.P. Excise Act, 1910 registered at Police Station – Unchahar, District – Raiberelly during pendency of trial.


I, Shriram aged about 66 years son of Shri Ramdeen Verma resident of Village – Chandrabhanpur, Police Station – Kohndaur, District – Pratapgarh, Religion – Hindu, Qualification – Illiterate, Occupation – Agriculture, the deponent do hereby solemnly affirm and  state on oath as under :- That the deponent is brother of applicant and doing pairvi of Applicant in the above noted case and duly authorized by him for filing instant application before the Hon'ble Court and as such he is fully conversant with the facts of the case deposed herein under. That the photo verification issued by the Awadh Bar Association, of the deponent is being pasted on the first page of this affidavit and 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 first bail application on behalf of the Applicant before the Hon'ble Court and not 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. 08 of 2021 under Sections 304, 120B, 328, 272, 201 of I.P.C., 60A of U.P. Excise Act, 1910, at Police Station – Kohndaur, District – Pratapgarh on 23.01.2021 at 23.52 hours against the applicant and several other accused persons. The certified copy/ typed copy of the first information report dated 23.01.2021 is being annexed herewith as Annexure No. 1 to this Affidavit. That according to the First Information Report, which has been lodged by Shri Kaushalpati Yadav, Sub Instpector, Police Station - Kohndaur, District – Pratapgarh (hereinafter referred to as ‘informant’),  the prosecution story is in nutshell that the informant went to brick field on 21.01.2021 situated at Village – Chandrabhanpur, Police Station – Kahndaur, District – Pratapgarh for preparation of a inquest, then he came to know that apart from the deceased, another person has also died due to drinking of adulterated liquor on 21.01.2021 and his crimination has been done at Prayagraj. The informant, from initial investigation, he found that the applicant and other persons have involved in the supply and distribution of adulterated liquor. That the name of the applicant is shown at serial No. 4 in the accused column impugned first information report dated 23.01.2021. That the impugned first information report dated 23.01.2021 is lodged after two days delayed by the concerned police without giving any reason for delay, which is also creates doubt upon the prosecution story. That the applicant is common man of society and has no concerned with the adulterated liquor in any manner. That the real fact is that the applicant are falsely implicated in the case crime due to political reasons by the some villagers, which has been explained by the concerned police for the ulterior motive. That the applicant is milkman and running the business and earned sufficient movable and immovable properties due to which some villagers having enmity with the applicant. That here it is relevant to mention that the applicant was supplying the milk to the brick field situated at Village – Chandrabhanpur, Police Station – Kahndaur, District – Pratapgarh since long back. The informant said the applicant to record his statement against the owner of the brick field then the applicant denied for same as the applicant has no concerned with the owner of the brick field except milk supply to him. That the informant annoyed with the applicant and abused him and walk away from the applicant’s house but under the influence of the some villagers, the informant named the applicant in first information report dated 23.01.2021. That on 23.01.2021, a first information report has been lodged by the concerned police due extraneous consideration; the applicant has been falsely implicated in the case crime. That about after three months, the investigating officer, recorded the statements of the family members of the deceased, under Section 161 of Cr.P.C. on 17.04.2021 almost similar statements and revealed the name of the applicant. The typed copies of the statements of the deceased’s relative are being annexed herewith as Annexure No. 2 to this Affidavit. That just after two days of the statements of the deceased’s family members i.e. 20.04.2021, their further statements have been recorded by the investigating officer, in which they have repeated their statements. The typed copy of the further statements of the deceased’s family members are being annexed herewith as Annexure No. 3 to this Affidavit. That on 03.05.2021, the statements of the family members of the deceased persons, which have been given through affidavits, in they all have stated that the deceased neither consumed the liquor nor died due to adulterated liquor. The photocopy of the endorsement in the affidavit in the CD-28 dated 03.05.2021 is being annexed herewith as Annexure No. 4 to this Affidavit. That on bare perusal of the first information report, it is also evident that there were no witnesses of case crime, which also creates doubts upon the story of the informant, which itself concocted and false. That the applicant is in jail since 02.08.2021 without committing any offense as alleged against them. That the informant alleged in his first information report that the adulterated liquor has been supplied by the applicant and another person and also the deceased have been died due to drink of adulterated liquor. That nothing has been recovered from the applicant’s possession by the informant and if any recovery made, the applicant has no concerned with recovered adulterated liquor in any manner as such the Sections 272 of IPC and 60A of U.P. Excise Act, 1910 made against him. That the applicant had applied for bail before the Sessions Judge, Pratapgarh bearing Bail Application No. 1801 of 2021, which has been rejected by the court concerned without going into the fact and records of case. The free certified copy of bail rejection order dated 14.09.2021 passed by the court concerned is annexed herewith as Annexure No. 5 to this affidavit. That another accused Raju Singh Kithawar of aforesaid case crime has been granted bail by the learned court below. That another accused of the case crime namely Sanjay Sharma moved bail before this Hon'ble High Court, which has been granted by this Hon'ble High Court on 04.08.2021. The photocopy of the order dated 04.08.2021 passed by this Hon'ble High Court is being annexed herewith as Annexure No. 6 to this Affidavit. That till date there is no any chemical report stating therein that the recovered liquor was obnoxious or spurious for human consumption. That the applicant has no criminal history except this false case, lodged by the informant for extraneous reasons. That due to false implication of the applicant in the case crime, his business has been ruined and his family is came on road. That the applicant has not committed any crime as alleged in the first information report by the informant and he has no concern. That there is no possibility of the applicant’s conviction because he has not committed the crime in question, as alleged by the prosecution. That the applicant is common man of the society. He has never convicted in any case and not involved in any criminal activities ever. There is no criminal history against the applicant except this present case. That there is no chance of applicant’s 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 will cooperate with the trial and will not tamper the prosecution witnesses. That the applicant undertakes that he 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 deems fit and proper in the circumstances of the case. 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. 08 of 2021 under Sections 272 of IPC and 60A of U.P. Excise Act, 1910 registered at Police Station – Kohndaur, District – Pratapgarh, during pendency of trial.


I, Shriram aged about 66 years son of Shri Ramdeen Verma resident of Village – Chandrabhanpur, Police Station – Kohndaur, District – Pratapgarh, Religion – Hindu, Qualification – Illiterate, Occupation – Agriculture, the deponent do hereby solemnly affirm and  state on oath as under :- That the deponent is brother of applicant and doing pairvi of Applicant in the above noted case and duly authorized by him for filing instant application before the Hon'ble Court and as such he is fully conversant with the facts of the case deposed herein under. That the photo verification issued by the Awadh Bar Association, of the deponent is being pasted on the first page of this affidavit and 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 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. 08 of 2021 under Sections 304, 120B, 328, 272, 201 of I.P.C., 60A of U.P. Excise Act, 1910, at Police Station – Kohndaur, District – Pratapgarh on 23.01.2021 at 23.52 hours against the applicant and several other accused persons. The certified copy/ typed copy of the first information report dated 23.01.2021 is being annexed herewith as Annexure No. 1 to this Affidavit. That according to the First Information Report, which has been lodged by Shri Kaushalpati Yadav, Sub Inspector, Police Station - Kohndaur, District – Pratapgarh (hereinafter referred to as ‘informant’),  the prosecution story is in nutshell that the informant went to brick field on 21.01.2021 situated at Village – Chandrabhanpur, Police Station – Kahndaur, District – Pratapgarh for preparation of a inquest, then he came to know that apart from the deceased, another person has also died due to drinking of adulterated liquor on 21.01.2021 and his crimination has been done at Prayagraj. The informant, from initial investigation, he found that the applicant and other persons have involved in the supply and distribution of adulterated liquor. That the name of the applicant is shown at serial No. 4 in the accused column impugned first information report dated 23.01.2021. That the impugned first information report dated 23.01.2021 is lodged after two days delayed by the concerned police without giving any reason for delay, which is also creates doubt upon the prosecution story. That the applicant is common man of society and has no concerned with the adulterated liquor in any manner. That the real fact is that the applicant are falsely implicated in the case crime due to political reasons by the some villagers, which has been explained by the concerned police for the ulterior motive. That the applicant is milkman and running the business and earned sufficient movable and immovable properties due to which some villagers having enmity with the applicant. That here it is relevant to mention that the applicant was supplying the milk to the brick field situated at Village – Chandrabhanpur, Police Station – Kahndaur, District – Pratapgarh since long back. The informant said the applicant to record his statement against the owner of the brick field then the applicant denied for same as the applicant has no concerned with the owner of the brick field except milk supply to him. That the informant annoyed with the applicant and abused him and walk away from the applicant’s house but under the influence of the some villagers, the informant named the applicant in first information report dated 23.01.2021. That on 23.01.2021, a first information report has been lodged by the concerned police due extraneous consideration; the applicant has been falsely implicated in the case crime. That the statement of the sister of the deceased Lail has been recorded under Section 161 of Cr.P.C. by the investigating officer on 23.01.2021, in which she stated that the owner and munshi of the brick field have served the liquor. She not mentioned the name of the applicant in any manner. The photocopy of the statement of the sister of the deceased Lail being annexed herewith as Annexure No. 2 to this Affidavit. That about after three months, the investigating officer, recorded the statement of the family member of the deceased Rohit, under Section 161 of Cr.P.C. on 17.04.2021, in which wife of the deceased also given similar statement and revealed the name of the applicant after about three months of the incident. The typed copy of the statement of the wife of the deceased Rohit is being annexed herewith as Annexure No. 3 to this Affidavit. That just after two days of the statements of the deceased Lail’s sister on 20.04.2021, the further statement has been recorded by the investigating officer, in which she repeated her earlier statement but named the applicant. The typed copy of the further statement of the deceased Lail’s sister is being annexed herewith as Annexure No. 4 to this Affidavit. That on 03.05.2021, the statements of the family members of the deceased persons, which have been given through affidavits, in they all have stated that the deceased neither consumed the liquor nor died due to adulterated liquor. The photocopy of the endorsement of the affidavit in the CD-28 dated 03.05.2021 is being annexed herewith as Annexure No. 5 to this Affidavit. That so far allegation made by the informant that the deceased Lail died due to consumption of the adulterated liquor, it is relevant to mention the post mortem was conducted but nothing has been shown in post mortem report that the deceased died due consumption of the adulterated liquor. The photo/typed copy of the post mortem report of the deceased Lail is being annexed herewith as Annexure No. 6 to this Affidavit. That the statement of the brick field owner and his nephew have been recorded by the concerned police, who have also named in the first information report on 25.05.2021, in which both have given all details, against them the other witnesses stated that they were distributed the adulterated liquor, have not named the applicant themselves. The typed copy of the statement of the brick field owner and his nephew are being annexed herewith as Annexure No. 7 to this Affidavit. That the applicant has been arrested by the concerned police on 02.08.2021 and taken on remand under Sections 272 of IPC and 60A of U.P. Excise Act, 1910. That on bare perusal of the first information report, it is also evident that there were no witnesses of case crime, which also creates doubts upon the story of the informant, which itself concocted and false. That the applicant is in jail since 02.08.2021 without committing any offense as alleged against them. That the informant alleged in his first information report that the adulterated liquor has been supplied by the applicant and another person and also the deceased have been died due to drink of adulterated liquor. That nothing has been recovered from the applicant’s possession by the informant and if any recovery made, the applicant has no concerned with recovered adulterated liquor in any manner as such the Sections 272 of IPC and 60A of U.P. Excise Act, 1910 made against him. That another accused Raju Singh Kithawar of aforesaid case crime has been granted bail by the learned court below on 30.04.2021. That another accused of the case crime namely Sanjay Sharma moved bail before this Hon'ble High Court, which has been granted by this Hon'ble High Court on 04.08.2021. The photocopy of the order dated 04.08.2021 passed by this Hon'ble High Court is being annexed herewith as Annexure No. 8 to this Affidavit. That the applicant had applied for bail before the Sessions Judge, Pratapgarh bearing Bail Application No. 1801 of 2021, which has been rejected by the court concerned without going into the fact and records of case. The free certified copy of bail rejection order dated 14.09.2021 passed by the court concerned is annexed herewith as Annexure No. 9 to this affidavit. That till date there is no any chemical report stating therein that the recovered liquor was obnoxious or spurious for human consumption. That the applicant has no criminal history except this false case, lodged by the informant for extraneous reasons. That due to false implication of the applicant in the case crime, his business has been ruined and his family is came on road. That the applicant has not committed any crime as alleged in the first information report by the informant and he has no concern. That there is no possibility of the applicant’s conviction because he has not committed the crime in question, as alleged by the prosecution. That the applicant is common man of the society. He has never convicted in any case and not involved in any criminal activities ever. There is no criminal history against the applicant except this present case. That there is no chance of applicant’s 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 will cooperate with the trial and will not tamper the prosecution witnesses. That the applicant undertakes that he 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 deems fit and proper in the circumstances of the case. 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. 08 of 2021 under Sections 272 of IPC and 60A of U.P. Excise Act, 1910 registered at Police Station – Kohndaur, District – Pratapgarh, during pendency of trial.


I, Durga Bux Singh aged about 50 years son of Shri Satya Dev Singh resident of 3/344, Vishwash Khand – 3, Police Station - Gomti Nagar, Lucknow, Religion – Hindu, Occupation – Business, Education – Graduate, do hereby solemnly affirm and states on oath as under :- That the deponent is cousin brother of applicant and doing pairvi of Applicant in the above noted case and duly authorized by him for filing instant application before the Hon'ble Court and as such he is fully conversant with the facts of the case deposed herein under. That the photocopy of ID proof of the deponent is being annexed with this affidavit and the application for waiver of the filing affidavit is being filed separately with bail application. That this is first bail application on behalf of the Applicant before the Hon'ble Court and not 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. 107 of 2021 under Sections 60A of U.P. Excise Act, 1910, registered at Police Station – Gossainganj, District – Ayodhya on 01.04.2021 at 10.16 hours against the one person namely Rajnath Verma. The certified copy/ typed copy of the first information report dated 01.04.2021 is being annexed herewith as Annexure No. 1 to this Affidavit. That here it is relevant to mention that the applicant is not named in the first information report as he has committed any offence as alleged against the concerned police later on during the investigation by the investigating officer. That according to the First Information Report, which has been lodged by Shri Motilal Verma, resident of Village – Trilokpur, Daffarpur, Police Station – Gossainganj, District – Ayodhya (hereinafter referred to as ‘informant’).  The prosecution story is in nutshell that son of the informant consumed the adulterated liquor between 30.03.2021 to 01.04.2021 and become ill. He was treated in Gossainganj, later on he referred to Lucknow but during travelling to Lucknow, the son of the informant died. That the informant lodged the first information report against the accused Rajnath Verma. That the statement of the informant has been recorded by the investigating officer under Section 161 of Cr.P.C., in which he given detail of the incident and stated that due to political enmity, the named accused given a party on 29.03.2021, in which he served and distributed adulterated liquor and after consumption of same, the son of the informant died on 01.04.2021. The photo/ typed copy of the statement of the informant is being annexed herewith as Annexure No. 2 to this Affidavit. That further statement of the informant has been recorded by the concerned police, in which the informant changed his statement and reveal new names of other accused. That during the investigating officer recorded the several statements of the witnesses of the case crime under Section 161 of Cr.P.C. namely Ram Tirath, Pullu Kahar, Hriday Kumar Tiwari, Sanay Tiwari, Rakesh Verma, Bachcha Ram, Deepak Verma, Raju Verma and Mohd. Vaish but no anyone named the applicant in said case crime. That till submission of the CD No. 72, dated 02.09.2021 prepared by the investigating officer, the name of the applicant is not came in light. The photocopy of the CD-72 dated 02.09.2021 of the case crime is being annexed herewith as Annexure No. 3 to this Affidavit. That the investigating officer, during course of investigating officer went to the Police Station – Hathigawan, District – Pratapgarh on 03.09.2021 and met with the Doodhnath Singh Yadav, Station House Officer, who told the name of the applicant and stated that one accused Guddu Singh and the applicant alongwith other accused were operating the factory of adulterated liquor and several first information reports have been lodged against the said accused. The photo/typed copy of the CD-73 dated 03.09.2021 of the case crime is being annexed herewith as Annexure No. 3 to this Affidavit. That later the on basis of the statement of Doodhnath Singh Yadav, Station House Officer, Police Station – Hathigawan, District – Pratapgarh, the investigating officer, named the applicant in case crime only on presumption basis in illegal manner. That the applicant is common man of society and has no concerned with the adulterated liquor as alleged by investigating officer due to extraneous reasons. That the real fact is that the applicant is innocent and belongs to a respected family and has good reputation being national player of volleyball. That the applicant was serving to the Central Government and was posted as Point-man, at Northern Railways, District – Sultanpur. The photo/type copy of the certificate issued by the railway authority on 15.04.2021 is being annexed herewith as Annexure No. 4 to this application. That the applicant had shifted to Lucknow along with his family since long back and he rarely visits his village. That the children of the applicant are studying in class VIII & III City Montessori School, Indira Nagar, Lucknow and due to false implication in said case crime, the career of the children gone in dark. That the applicant was National Player of Volleyball and won several awards and lastly he was participated in 31st National Games, Punjab – 2001, in which he secured Silver Medal. The photocopies of the certificates related to the volleyball are being annexed herewith as Annexure No. 5 to this application. That the entire case has been made and based against the applicant only on basis of the statement of the Doodhnath Singh Yadav, Station House Officer, Police Station – Hathigawan, Police Station – Pratapgarh, whereas the applicant has no concerned with the illegal business as alleged by the investigating officer. That there is no concerned with the allegation regarding illegal adulterated liquor as alleged/concocted by the investigating officer under the political pressure. The investigating officer working for the present local Member of the Parliament of the ruling party due to political vendetta, he has been falsely implicated in the case crime. That the investigating officer falsely implicates the applicant, in the said crime for ulterior motive, which is baseless and illegal as the applicant is not involved in any criminal activity as alleged against him. That on bare perusal of the first information report, it is also evident that there were no independent witnesses of raid conducted by the informant, which also creates doubts upon the story of the informant, which itself concocted and false. That the applicant is named in the case crime about five months due to extraneous reasons, while there no any concrete evidences against the applicant. That the applicant is in jail in connection with case crime No. 124 of 2021 registered at Police Station – Kunda, District – Pratapgarh. That the applicant is in jail since 08.09.2021 without committing any offense as alleged against him. That the applicant has no concerned with adulterated liquor in any manner as such the under Sections 302, 307, 419, 420, 467, 468, 471, 272, 34 of I.P.C., 60, 60 of U.P. Excise Act, 1910, registered at Police Station – Gossainganj, District – Ayodhya have not applicable against him. That the applicant is falsely implicated in several cases lodged against the applicant, while the applicant has not committed any offense. The details of the case, which are lodged against the applicant, as per best knowledge of the applicant are as under:- Case Crime No. 48 of 2021 under section 420, 467, 468, 471, 272, 273 of I.P.C., 60, 63 of U.P. Excise Act, Police Station - Hathigawan District – Pratapgarh, in which the applicant granted bail on 15.11.2021 passed by this Hon'ble High Court. Case Crime No. 49 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60(2), 63 of U.P. Excise Act, 1910, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 registered at Police Station – Hathigawan, District – Pratapgarh,. Case Crime No. 50 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60(2), 60A, 63 of U.P. Excise Act, 1910, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 registered at Police Station – Hathigawan, District – Pratapgarh. Case Crime No. 124 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60A, 60 of U.P. Excise Act, 1910, 63, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 at Police Station – Hathigawan, District – Pratapgarh. Case Crime No. 125 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60A, 60 of U.P. Excise Act, 1910, 63, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 at Police Station – Hathigawan, District – Pratapgarh. Case Crime No. 107 of 2021 under Sections 302, 307, 120B, 34, 272, 419, 420, 467, 468, 471 of IPC and 60 of U.P. Excise Act registered at Police Station – Gossainganj, District – Ayodhya, in which the name of the applicant came in the light from the accused person. Case Crime No. 121 of 2021 under Sections 3/25 Arms Act registered at Police Station – Maheshganj, District – Pratapgarh. Case Crime No. 208 of 2021 under Sections 419, 420, 467, 468, 471, 486, 487, 272 of I.P.C., 60, 60A, 63 of U.P. Excise Act, 1910, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 registered at Police Station – Hathigawan, District – Pratapgarh, which has been lodged by the concerned police, when the applicant is in jail. That the aforesaid 8 cases are recently lodged against the applicant under the political pressure. Case Crime No. 15 of 2016 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., registered at Police Station – Maheshganj, District – Pratapgarh, in which the investigation is going on. Case Crime No. 517 of 2016 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60, 63 of U.P. Excise Act, 1910, 63A of Copyright Act, 1957 registered at Police Station – Mil Area, District – Raebareli, in which the applicant released on bail. Case Crime No. 17 of 2016 under Section 135 The Electricity Act registered at Police Station – Maheshganj, District – Pratapgarh, in which the applicant has paid the bill but the concerned police in malafide manner submitted the charge sheet against the applicant. Case Crime No. 178 of 2014 under Sections 420, 467, 468, 471, 272, 273, 427 of I.P.C., 60, 63 of U.P. Excise Act, 1910, 3/4 of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 registered at Police Station – Maheshganj, District – Pratapgarh, in which the charge sheet has been submitted by concerned police and the applicant is exonerated from the said case crime as he was falsely implicated in case. Case Crime No. 44 of 2018 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60, 63 of U.P. Excise Act, 1910 registered at Police Station – Nawabganj, District – Pratapgarh, in which the charge sheet has been submitted by concerned police and the applicant is exonerated from the said case crime as he was falsely implicated in case. Case Crime No. 513 of 2010 under Sections 307, 323, 325, 364, 395, 427 of I.P.C. and 7 of Criminal Law Amendment Act registered at Police Station – Kunda, District – Pratapgarh, in which the applicant is released on bail by this Hon'ble High Court. The photocopies of the bail order and other related documents of the applicant are being annexed herewith as Annexure No. 6 to this application. That apart of abovementioned cases, there no criminal history against the applicant. That after rejection of the bail from the learned court below, several accused also have been filed the bail application before this Hon'ble High Court in which almost all accused have been granted bail to them on various dates. The photocopies of the orders passed by this Hon'ble High Court are being annexed herewith as Annexure No. 7 to this Affidavit. That the applicant had applied for bail before the Additional Sessions Judge, Court No. 3, Faizabad bearing Bail Application No. 1856 of 2021 under Sections 302, 307, 419, 420, 467, 468, 471, 272, 34 of I.P.C., 60, 60 of U.P. Excise Act, 1910, registered at Police Station – Gossainganj, District – Ayodhya which is rejected by the court concerned without going to fact and records. The free copy of bail rejection order dated 02.12.2021 passed by the court concerned is annexed herewith as Annexure No. 8 to this affidavit. That the applicant has not committed any crime as alleged in the first information report by the informant and he has no concern. That there is no possibility of the applicant’s conviction because he has not committed the crime in question, as alleged by the prosecution. That the applicant is common man of the society. He has never convicted in any case ever. That there is no chance of applicant’s 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 will cooperate with the trial and will not tamper the prosecution witnesses. That the applicant undertakes that he 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 deems fit and proper in the circumstances of the case. 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. 107 of 2021 under Sections 302, 307, 419, 420, 467, 468, 471, 272, 34 of I.P.C., 60, 60 of U.P. Excise Act, 1910, registered at Police Station – Gossainganj, District – Ayodhya, during pendency of trial.


I, Durga Bux Singh aged about 50 years son of Shri Satya Dev Singh resident of 3/344, Vishwash Khand – 3, Police Station - Gomti Nagar, Lucknow, Religion – Hindu, Occupation – Business, Education – Graduate, do hereby solemnly affirm and states on oath as under :- That the deponent is cousin brother of applicant and doing pairvi of Applicant in the above noted case and duly authorized by him for filing instant application before the Hon'ble Court and as such he is fully conversant with the facts of the case deposed herein under. That the photocopy of ID proof of the deponent is being annexed with this affidavit and the application for waiver of the filing affidavit is being filed separately with bail application. That this is first bail application on behalf of the Applicant before the Hon'ble Court and not 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. 124 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60, 60A, 63 of U.P. Excise Act, 1910, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 at Police Station – Kunda, District – Pratapgarh on 05.04.2021 at 02.09 hours against the applicant and 12 other persons. The certified copy/ typed copy of the first information report dated 05.04.2021 is being annexed herewith as Annexure No. 1 to this Affidavit. That according to the First Information Report, which has been lodged by Sub Inspector Shri Pramod Kumar Singh, Inchare SWAT Team, District – Pratapgarh (hereinafter referred to as ‘informant’) stated therein that the informant and his team was on patrolling of area on 03.04.2021 and that time the informant got information from his informer (eq[kfcj) with regard to huge adulterated liquor stored. That the raid has been conducted by the informant along with his team on 03.04.2021 at alleged place of the applicant and seized lot of adulterated liquor. That the name of the applicant was told by the informer (eq[kfcj) of the concerned police prior to raid and on basis which the applicant is named in the case crime. That the name of the applicant is shown at serial No. 02 in the accused column in the first information report dated 05.04.2021. That the first report dated 05.04.2021 is anti dated as the raid was conducted on 03.04.2021 but the first information report lodged on 05.04.2021 by the concerned police without giving any reason for delay, which creates doubt upon the prosecution story. That the applicant is common man of society and has no concerned with the adulterated liquor and during the raid the applicant was not present at the place of incident. That the real fact is that the applicant is innocent and belongs to a respected family and has good reputation being national player of volleyball. That the applicant was serving to the Central Government and was posted as Point-man, at Northern Railways, District – Sultanpur. The photo/type copy of the certificate issued by the railway authority on 15.04.2021 is being annexed herewith as Annexure No. 02 to this application. That the applicant had shifted to Lucknow along with his family since long back and he rarely visits his village. That the children of the applicant are studying in class VIII & III City Montessori School, Indira Nagar, Lucknow and due to false implication in said case crime, the career of the children gone in dark. That the applicant was National Player of Volleyball and won several awards and lastly he was participated in 31st National Games, Punjab – 2001, in which he secured Silver Medal. The photocopies of the certificates related to the volleyball are being annexed herewith as Annexure No. 03 to this application. That the entire case has been made and based against the applicant only on information of the police informer, which is not reliable as nothing is supported to prosecution story. That there is no concerned with the said allegation regarding illegal adulterated liquor as alleged by the informant. The informant working for the present local Member of the Parliament of the ruling party due to political vendetta, he has been falsely implicated in the case crime. That in result of the above, the informant falsely implicates the applicant, in the said crime for ulterior motive, which is baseless and illegal as the applicant is not involved in any criminal activity as alleged against him. That the nothing was recovered in the regard of Adulterated liquor from the applicant’s possession and place in any manner, by the informant and the applicant has no concerned with said recovery in any manner. That on bare perusal of the first information report, it is also evident that there were no independent witnesses of raid conducted by the informant, which also creates doubts upon the story of the informant, which itself concocted and false. That the applicant is in jail since 08.09.2021 without committing any offense as alleged against him. That the applicant has no concerned with recovered adulterated liquor in any manner as such the under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60(2), 60A, 63 of U.P. Excise Act, 1910, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 at Police Station – Hathigawan, District – Pratapgarh have not applicable against him. That the informant has not arrested the applicant at alleged place of recovery even not found anything from the applicant’ possession on 03.04.2021. That the concerned police without proper investigation and under the pressure of the local politician against 12 accused persons including the applicant, filed the charge sheet No. 228 of 2021 on 11.09.2021 without receiving the Forensic Science Lab report. That till date there is no any chemical report received from the alleged recovery stating therein that the recovered liquor was obnoxious or spurious for human consumption. That under the political influence, after alleged raid on 03.04.2021, two first information reports lodged i.e. 124 of 2021 and Case Crime No. 125 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C. and 60, 60A, 63 of U.P. Excise Act, 1910 at Police Station – Kunda, District – Pratapgarh by the SHO, Kunda against the applicant and other named and unknown persons, for preparing the criminal history against the applicant. That the applicant is falsely implicated in several cases lodged against the applicant, which the applicant has not committed any offense. The details of the case, which are lodged against the applicant, as per best knowledge of the applicant are as under:- Case Crime No. 48 of 2021 under section 420, 467, 468, 471, 272, 273 of I.P.C., 60, 63 of U.P. Excise Act, Police Station - Hathigawan District – Pratapgarh, in which the applicant granted bail on 15.11.2021 passed by this Hon'ble High Court. Case Crime No. 49 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60(2), 63 of U.P. Excise Act, 1910, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 registered at Police Station – Hathigawan, District – Pratapgarh, in which the applicant has been granted bail on 06.12.2021 by this Hon'ble High Court. Case Crime No. 50 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60(2), 60A, 63 of U.P. Excise Act, 1910, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 registered at Police Station – Hathigawan, District – Pratapgarh, in which the applicant has been granted bail on 07.12.2021 by this Hon'ble High Court. Case Crime No. 124 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60A, 60 of U.P. Excise Act, 1910, 63, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 at Police Station – Hathigawan, District – Pratapgarh. Case Crime No. 125 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60A, 60 of U.P. Excise Act, 1910, 63, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 at Police Station – Hathigawan, District – Pratapgarh. Case Crime No. 107 of 2021 under Sections 302, 307, 120B, 34, 272, 419, 420, 467, 468, 471 of IPC and 60 of U.P. Excise Act registered at Police Station – Gossainganj, District – Ayodhya, in which the name of the applicant came in the light from the accused person. Case Crime No. 121 of 2021 under Sections 3/25 Arms Act registered at Police Station – Maheshganj, District – Pratapgarh. Case Crime No. 208 of 2021 under Sections 419, 420, 467, 468, 471, 486, 487, 272 of I.P.C., 60, 60A, 63 of U.P. Excise Act, 1910, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 registered at Police Station – Hathigawan, District – Pratapgarh, which has been lodged by the concerned police, when the applicant is in jail, in which the applicant has been granted bail on 07.12.2021 by this Hon'ble High Court. That the aforesaid 8 cases are recently lodged against the applicant under the political pressure. Case Crime No. 15 of 2016 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., registered at Police Station – Maheshganj, District – Pratapgarh, in which the investigation is going on. Case Crime No. 517 of 2016 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60, 63 of U.P. Excise Act, 1910, 63A of Copyright Act, 1957 registered at Police Station – Mil Area, District – Raebareli, in which the applicant released on bail. Case Crime No. 17 of 2016 under Section 135 The Electricity Act registered at Police Station – Maheshganj, District – Pratapgarh, in which the applicant has paid the bill but the concerned police in malafide manner submitted the charge sheet against the applicant. Case Crime No. 178 of 2014 under Sections 420, 467, 468, 471, 272, 273, 427 of I.P.C., 60, 63 of U.P. Excise Act, 1910, 3/4 of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 registered at Police Station – Maheshganj, District – Pratapgarh, in which the charge sheet has been submitted by concerned police and the applicant is exonerated from the said case crime as he was falsely implicated in case. Case Crime No. 44 of 2018 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60, 63 of U.P. Excise Act, 1910 registered at Police Station – Nawabganj, District – Pratapgarh, in which the charge sheet has been submitted by concerned police and the applicant is exonerated from the said case crime as he was falsely implicated in case. Case Crime No. 513 of 2010 under Sections 307, 323, 325, 364, 395, 427 of I.P.C. and 7 of Criminal Law Amendment Act registered at Police Station – Kunda, District – Pratapgarh, in which the applicant is released on bail by this Hon'ble High Court. The photocopies of the bail order passed by the court below and this Hon'ble High Court alongwith other related documents of the applicant are being annexed herewith as Annexure No. 4 to this application. That apart of abovementioned cases, there no criminal history against the applicant. That the maximum accused of the case crime No. 124 of 2021 have been granted bail by the court below on various dates. The photocopy of the bail order passed by the court below is being annexed herewith as Annexure No. 5 to this application. That after rejection of the bail from the learned court below, the co-accused also have been filed the bail application before this Hon'ble High Court in which the accused Sanjay Pratap Singh alias Guddu Singh has been granted bail to him on 24.11.2021. The photocopy of the order dated 24.11.2021 passed by this Hon'ble High Court is being annexed herewith as Annexure No. 6 to this Affidavit. That the applicant had applied for bail before the Sessions Judge, Pratapgarh bearing Bail Application No. 2816 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60, 60A, 63 of U.P. Excise Act, 1910, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 at Police Station – Kunda, District – Pratapgarh which is rejected by the court concerned without going to fact and records. The free copy of bail rejection order dated 07.12.2021 passed by the court concerned is annexed herewith as Annexure No. 7 to this affidavit. That the applicant has not committed any crime as alleged in the first information report by the informant and he has no concern. That there is no possibility of the applicant’s conviction because he has not committed the crime in question, as alleged by the prosecution. That the applicant is common man of the society. He has never convicted in any case and not involved in any criminal activities ever. That there is no chance of applicant’s 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 will cooperate with the trial and will not tamper the prosecution witnesses. That the applicant undertakes that he 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 deems fit and proper in the circumstances of the case. 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. 124 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60, 60A, 63 of U.P. Excise Act, 1910, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 at Police Station – Kunda, District – Pratapgarh during pendency of trial.