I, Girija Devi aged about 65 years wife of Shri Shitla Prasad Tiwari resident of Village - Phoolpur, Police Station - Jethwara, District- Pratapgarh, Religion – Hindu, Qualification – Illiterate, Occupation – Housewife, the deponent do hereby solemnly affirm and  state on oath as under :- That the deponent is mother of the applicant and doing pairvi in the above noted case and also duly authorized by the applicant. The deponent further declares that the contents of this instant application explained by the counsel of the applicant as such she is fully conversant with the facts of the case deposed herein under. That the deponent further declares that the contents of the affidavit have been explained in Hindi by the counsel of the applicant to her as such she conversant with the facts of the case. That this is second bail application of the applicant. The First bail application of the applicant beraing No. 760 of 2020 has been rejected by Hon'ble Alok Mathur “J” on 20.07.2021. No any other bail application is pending before this Hon'ble High Court or any other competent court. The photocopy of the order dated 20.07.2021 passed by this Hon'ble High Court is being annexed herewith as Annexure No. 1 to this affidavit. That the applicant in jail in relation to the first information report lodged by Smt. Sudama Devi wife of Shri Ram Samujh resident of Village- Phoolpur, Police Station - Jethwara, District- Pratapgarh (hereinafter referred to as ‘informant’) on 31.05.2018 at 13.13 hours against the 4 persons including the applicant, who are all family members, vide case crime No. 213 of 2018 under Sections 352, 323, 452, 504, 308 of I.P.C. at Police Station – Jethwara, District – Pratapgarh. The photo/ typed copy of the first information report dated 31.05.2018 is being annexed herewith as Annexure No. 2 to this affidavit. That according to the prosecution story, it was alleged in the first information report dated 31.05.2018 by the informant that the applicant is pattidar of the informant and due to enmity with each other, on 30.05.2018 at 08.30 hours the applicant and other accused of case crime for the purpose of the killing the husband of the informant, with lathi, danda, katta and axe, entered in her house and started beaten to her husband, in which he sustanined several injuries and they also given life threat. The injured brought to the hospital at District – Prayagraj for treatment. That the injured brought to hospital, where the medical report prepared by the doctor, in which 5 injuries shown. The photo/typed copy of the medical report of the injred dated 30.05.2018 is being annexed herewith as Annexure No. 3 to this affidavit. That as a matter of fact the applicant is innocent and he has been falsely implicated by the Informant due to malafide intension of the Informant and on the ill advice. That the first information report lodged after about 30 hours delay without giving any reason, which creates doubt upon the prosection story. That the statement of the informant was recorded under Section 161 Cr.P.C. by the concerned police on 31.05.2018, in which she almost repeated her first informant report. The informant also said that her daughter has also sustained injury while she has not produced any medical report. The type copy of the statement of the informant dated 31.05.2018 is being annexed herewith as Annexure No. 4 to this affidavit. That during the treatment of the injured i.e. husband of the informant has died on 13.06.2018. That the post mortem was conducted on 13.06.2018 at District Hospital, Pratapgarh by the concenred docutor and as per post mortem report the casue of death of deceased “Asphysia as a result of anti-mortem injuries”. Here it is also relevant to mentioned that there is no any firearm injury found. The photo/ typed copy of the post mortem report dated 13.06.2018 is being annexed herewith as Annexure No. 5 to this affidavit. That after the death of the injured the Section 304 of IPC has been added in the said case crime. That thereafter on 17.06.2018, the statement of the daughter of the informant has been recorded under Section 161 of Cr.P.C., in which she repeated the version of the first information report lodged by her mother. The typed copy of the statement of the daughter of the informant dated 17.06.2018 is being annexed herewith as Annexure No. 6 to this affidavit. That thereafter without proper investigation of the case crime, the investigating officer submitted the charge sheet against the applicant, while nothing has been done by the applicant as alleged against him and his family members. That there is no credible evidence on record, which could show that the applicant is guilty or committed this crime in question and the evidence available on record, itself shows that no prima facie offence under Sections 352, 323, 452, 504, 308 of I.P.C. is made out against the applicant. That the applicant is in jail since 30.05.2018 without any of his fault. That no crime made out against the applicant as alleged in the impugned first information report lodged by the informant. That neither any evidence was found against the applicant nor has any motive been assigned to the applicant in the present case. That entire allegations as alleged in the first information report is false and frivolous. That the real fact of the case is that the applicant and informant are pattidar and having dispute rearding the land and others. That on 30.05.2018, the husband of the informant came to the house of the applicant and complaint that why the plough his land while nothing has been done by his family. That without listining anything, the husband of the informant started beaten him with lathi then on alarm of the applicant his family members came to save the applicant then the husband of the informant runaway. During running to his house, the husband of the informant fallen and sustained head injuries. That as per allegations of the informant, the incident took place in her house while the investigating officer not found blood stain in her house despite that the charge sheet has been filed against the applicant. That when the husband of the informant sustained head injuries then he brought to the hospital and on ill advise, with malafide intension, having found golden chance, the first information lodged aginst the applicant his family members after 30 hours of the alleged incident. That according to the prosecution story it clearly reveals that story of the prosecution is false and incorrect and concerned police avoiding the truth of case and there is no an evidence against the applicant. That neither the applicant has motive nor has any motive been assigned to him to commit the crime in question. That the first information report has been lodged afterthought and after consultation, in order to falsely implicate the applicant and other accused persons. That the trial of the case has been initiated and statements and cross of the informant have recorded by the court concerned in which there are several condradictions in her statement and she tried with malafide intension to prove guilty the applicant. The photocopy of the statement and cross of the informant of the trial are being annexed herewith collectively as Annexure No. 7 to this affidavit. That in aforesaid trial the informant/ PW – 1 chaged her statement and stated that the applicant had Katta while he came to her house while in first information report and in statement of 161 of Cr.P.C. stated that the applicant had axe, knife and danda. That on bare perusal of the aforesaid statements of the witnesses of the ongoing trail, there are several contradiction in the all statements, which are not collobrated with the prosecution story. That all are the interested witnesses as such merely on basis of their statements and testimony, the applicant would not be pleaded guilty. That there is no possibility of the applicant’s conviction because he has not committed the crime in question as alleged by the informant. That this Hon'ble High Court vide its order dated 20.07.2021 directed the learned trial court to expedite the trial. The copy of the aforesaid order has been given to the counsel for serving the same to the court concerned but after passing of about one year, the trial is not conculed yet. That there is no chance to conclude the trial of the applicant sooner as such in the interest of justice that the applicant be enlarged on bail during pendency of his trial. That the applicant has falsely implicated in in three other criminal cases apart from the instant case, which are as under: - Case Crime No. 41 of 2013 under Section 457, 380, 411 of IPC registered at Police Station – Jethwara, District – Pratapgarh, in which the applicant has granted bail on 16.04.2013 passed by the court below. Case Crime No. 225 of 2013 under Section 18/20 of N.D.P.S Act registered at Police Station – Jethwara, District – Pratapgarh, in which charge sheet submitted under Section 22 of NDPS Act and the applicant has granted bail on 27.03.2014 passed by the court below. Case Crime No. 211 of 2018 under Section 10 of U.P. Hooliganjism Control Act registered at Police Station – Jethwara, District – Pratapgarh, in which the applicant has granted bail on 29.08.2019 passed by the court below. The photocopies of the orders passed by the court below are being annexed herewith collectively as Annexure No. 8 to this affidavit. That the brother of the applicant, who has also named in the first information report, has granted bail by this Hon'ble High Court vide order dated 25.02.2020 passed in Crl. Misc. Case No. 9434 of (B) 2019 (Mohit Tiwari Vs State of U.P.). The photocopy of the order dated 25.02.2020 passed by this Hon'ble High Court is being annexed herewith as Annexure No. 9 to this affidavit. That the bail application of the applicant has been rejected by learned Additional District & Session Judge, Pratapgarh in bail application No. 1743 of 2019 vide order dated 24.09.2019. The photocopy of the bail rejection order dated 24.09.2019 passed by the court concerned is being annexed herewith as Annexure No. 10 to this affidavit. That the applicant undertakes that he will not misuse the liberty of bail if so granted by this Court. That there is no chance of the applicant absconding or tempering with the prosecution witnesses. That the applicant is ready to furnish personal bond and sureties to the entire satisfaction before the court, if the bail is granted to him. That in view of the above noted fact, it is clear that the applicant is innocent and his is in jail since 30.05.2018 as such it is expedient and necessary in the interest of justice that the applicant be enlarged on bail during pendency of his trial.


I, Vijay Kumar aged about 30 years, son of Shri Radheyshyam Shukla, resident of Village - Wakar Ali Ka purwa, Hamelet of Bishariya, Police Station - Hathigawan, District- Pratapgarh, Religion – Hindu, Qualification – Literate, Occupation – Agriculture, the deponent do hereby solemnly affirm and  state on oath as under :- That the deponent is brother of the applicant and doing pairvi in the above noted case and also duly authorized by him. The deponent further declares that the contents of this instant application explained by the counsel of the applicant as such he is fully conversant with the facts of the case deposed herein under. That this is third bail application of the applicant. The First bail application of the applicant bearing No. 2913 (B) of 2015 has been rejected by Hon’ble Shri Mahendra Dayal “J” on 23.09.2016 and Second Bail application beraing No. 10291 (B) of 2018 has also been rejected by Hon'ble Shri Dinesh Kumar Singh “J” on 04.12.2018. That the applicant in jail on the basis of first information report lodged by Shiv Bhawan Tiwari son of Late Ram Abhilash Tiwari resident of Village – Sariyawan, Police Station – Kunda, District – Pratapgarh (hereinafter referred to as ‘informant’) on 31.05.2014 at 10.30 hours against the six persons including the applicant vide case crime No. 117 of 2014 under Sections 498A, 304B IPC and 3/4 of The Dowry Prohibition Act, 1961 at Police Station – Hathigawan, District – Pratapgarh. The photo/ typed copy of the first information report dated 31.05.2014 is being annexed herewith as Annexure No. 1 to this affidavit. That it is relevant to mention that the certified copy of the first information report dated 31.05.2014 is already on record as same has been filed with the first bail application moved by the applicant. That according to the prosecution story, it was alleged in the first information report dated 31.05.2014 by the informant that the informant solemnized the marriage of his daughter namely Sadhna (hereinafter referred as to ‘deceased’) with the applicant with lot of dowry. But the all accused of the case crime demanded Rs. 1 Lacs and LCD TV from the daughter of the informant and for same they were tortured her. In night of the 30/31.05.2014, the accused have brutally beaten the deceased due to which has died. That as a matter of fact the applicant is innocent and he has been falsely implicated by the Informant due to malafide intension of the Informant and on the ill advice of his relative. That as a matter of fact the applicant or his family had never demanded any dowry nor had tortured the deceased for the alleged demand of dowry. That the applicant never demanded any dowry from the deceased or her family members and after this unfortunate incident’s information was given to the family members of the deceased as well as Informant and his other relatives were present at the time of preparing inquest by the concerned police. The photo/ typed copy of the inquest report dated 31.05.2014 is being annexed herewith as Annexure No. 2 to this affidavit. That the post mortem was conducted on 01.06.2014 about 03.00 PM at District Hospital, Pratapgarh by the concenred docutor and as per post mortem report the casue of death is shock and come due to ante mortem injuries. The photo/ typed copy of the post mortem report is being annexed herewith as Annexure No. 3 to this affidavit. That the statement of the several independent witnesses were recorded by the investigating officer under Section 161 of Cr.P.C., in which they stated that the deceased committed suicide at railway track. That without proper investigation of the case crime, the investigating officer of the case crime, the charge sheet was filed against the accused applicant and Radhe Shyam bearing charge sheet No. 15 of 2014 under Sections 498A, 304B I.P.C. and 3/4 The Dowry Prohibition Act, 1961 on 25.08.2014. The first information report was lodged against the 6 persons and only 2 persons including the applicant charge sheeted. The photo/ typed copy of the charge sheet dated 25.08.2014 filed by the concerned police is being annexed herewith as Annexure No. 4 to this affidavit. That it is further relevant to mention that the concerned police prepared 2 site plans fisrt is related to house of the applicant, where the applicant his family members brought the dead body of the deceased. The photo/typed copy of the site plan - I prepared by the investigating officer is being annexed herewith as Annexure No. 5 to this affidavit. That the second site plan is related to railway track, where the deceased committed suicide. The investigation officer found several stones at incident place and blood stains from the incident place, which is fully supported the version of the applicant and fully against the prosecution story. The photo/typed copy of the site plan - II prepared by the investigating officer is being annexed herewith as Annexure No. 6 to this affidavit. That on perusal of the charge sheet, it is clear that the informant has named the accused persons in alleged case crime, in a very casual manner and without ascertaining the facts. That prior to the date of incident neither deceased nor informant has filed any complaint or police report was never filed either with the police or any other competent authority for any cruelty or demand of dowry, which creates doubts upon the prosecution story. That there is no credible evidence on record, which could show that the applicant is guilty or committed this crime in question and the evidence available on record, itself shows that no prima facie offence under Sections 498A, 304B IPC and 3/4 of The Dowry Prohibition Act, 1961 is made out against the applicant. That the applicant is in jail since 02.06.2014 without any of his fault. That no crime made out against the applicant as alleged in the impugned first information report lodged by the informant. That neither any evidence was found against the applicant nor has any motive been assigned to the applicant in the present case. That the applicant has no criminal history at all except to this present case. That entire allegations as alleged in the first information report is false and frivolous. There was neither any demand of dowry nor the deceased was harassed in any manner. That the real fact of the case is that the deceased was suffering from several disease prior to the marriage and after marriage with the applicant, she has been provided the medical treatment by the applicant as per his financial position. The informant concealed the said fact with the applicant and his family prior to marriage. That on 11.01.2014, the deceased Sadhna Shukla has delivered one baby namely Yash Shukla but the son was also very much ill. The applicant has also provided the medical treatment to the mother and son to his label best. That the deceased requested his father i.e. the informant to help in treatment of her son but the informant denied very roudly due to which the deceased was also tensionised. That by time, the sadness of the deceased was increased day by day due illness of her son and she gone in deep depression. On mid-night of the 30/21.05.2014m when the all family members were sleeping at home and deceased leave the house and went to nearby the railway track and she hit herself with train and died due to several deadly injuries. That the informant was informed immediately after said unfortunate incident but the informant due to extraneous reasons lodged the first information against the applicant and his family members. That according to the prosecution story it clearly reveals that story of the prosecution is based on only presumption and concerned police avoiding the truth of case and there is no an evidence against the applicant/accused. That the family members of the applicant are common persons and hardly earn sufficient for their livelihood at this stage allegation regarding demand of one lac rupee, LCD TV are not sustained. That, the applicant has moved his bail application before Sessions Judge Pratapgarh and which has rejected on 15.09.2014  by the Session Judge, Pratapgarh. The certified copy of bail rejection order passed by the court concerned has already filed along with first bail application before this Hon’ble Court. That the applicant has filed First bail application bearing No. 2913 (B) of 2015 has been rejected by Hon’ble Shri Mahendra Dayal “J” on 23.09.2016 and Second Bail application beraing No. 10291 (B) of 2018 has also been rejected by Hon'ble Shri Dinesh Kumar Singh “J” on 04.12.2018. The photocopy of the order dated 23.06.2016 & 04.12.2018 passed by this Hon'ble High Court are being annexed herewith as Annexure No. 7 to this affidavit. That the trial of the case has been initiated and statements and cross of the informant and other witnesses have recorded by the court concerned in which they all are stand with their statements under Sections 161 of Cr.P.C., with malafide intension to prove guilty the applicant. The photocopies of the statement and cross of the witnesses Shiv Bhavan Tiwari and Sandeep Kumar Tiwari of the trial are being annexed herewith as Annexure No. 8 to this affidavit. That the then Sub Divisional Magistrate, who was present at time of inquest of the deceased namely Pradeep Kumar Singh, has been exmined by the trial court, who also state the family of the deceased were also present at time of inquest. The photocopy of the statement and cross of the witness Pradeep Kumar Singh of the trial is being annexed herewith as Annexure No. 9 to this affidavit. That the informant of the case again examined by the trial court on 07.01.2019, in which he change his statement, which was given earlier before the trial court and given several contradictive statements and adduced new facts and averment, which are never came in light earlier. The photocopy of the further statement and cross of the witness Shiv Bhanvan Tiwari of the trial is being annexed herewith as Annexure No. 10 to this affidavit. That on bare perusal of the aforesaid statements of the witnesses of the ongoing trail, there are several contradiction in the all statements, which are not collobrated with the prosecution story. That all are the interested witnesses as such merely on basis of their statements and testimony, the applicant would not be pleaded guilty. That the deceased committed suicide for her own reasons, which has been discussed hereinabove but the informant and his family members falsely implecated the applicant and his family in said case with malafide intension. That there is no possibility of the applicant’s conviction because he has not committed the crime in question as alleged by the Informant. That this Hon'ble High Court vide its order dated 04.12.2018 directed the learned trial court to expedite the trial and conclude the same within one year. The certified copy of the aforesaid order has been served to the court concerned but but after more than one and half year, the trial is not conculed yet. That the applicant is suffering from the piles since long back and due to excessive bleeding from piles he was reffered fron Jail Hospital to District Hospital, Pratapgarh. The applicant is diagnosed as ‘severe anemia” and his haemoglobin is just 5.2 insted of 13-17 g/dL. And due to seriousness of the applicant’s piles, he has been referred to the S.R.N. Hospital, Prayagraj by the District Hospital, Pratapgarh on 16.07.2020. Now the applicant is under treatment at Prayagraj and his operation was scheduled but due to unavibilety of the bed his operation is postponed as the patients of Covid-19 are under treatment in S.R.N. Hospital. The photocopy of the medical reports of the applicant is being annexed herewith as Annexure No. 11 to this affidavit. That now these days due to Covid-19, the trial court is not properly working therefore there is no chance to conclude the trial of the applicant as directed by this Hon'ble High Court as such in the interest of justice that the applicant be enlarged on bail during pendency of his trial. That the applicant undertakes that he will not misuse the liberty of bail if so granted by this Court. That there is no chance of the applicant absconding or tempering with the prosecution witnesses. That the applicant is ready to furnish personal bond and sureties to the entire satisfaction before the court, if the bail is granted to him. That in view of the above noted fact, it is clear that the applicant is innocent and his is in jail since 02.06.2014 as such it is expedient and necessary in the interest of justice that the applicant be enlarged on bail during pendency of his trial.


I, Sanjay Kumar Singh aged about 32 years son of Shri Raj Bux Singh resident of 741/16, New Rana Nagar, District – Rae Bareilly , Religion – Hindu, Qualification – B.A., Occupation – Agriculture, the deponent do hereby solemnly affirm and  state on oath as under :- That the deponent is pairokar 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  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. 15 of 2016 under Sections 420, 467, 468, 471, 272, 273 I.P.C., 60, 63, 72 Excise Act, 3/4 Copyright Act and 103/104 Trade Mark Act registered at Police Station – Maheshganj, District – Pratapgarh on 01.02.2016 at 14:00 hours against the applicant/accused and along with other 14 named persons. The first information report is lodged by Shri Sunil Kumar Dubey, In-charge, Surveillance Cell. The true photo/type copy of the first information report dated 01.02.2016 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 one Shri Sunil Kumar Dubey, In-charge, Surveillance Cell recovered some illicit country made liquor within the limits of Police Station – Shivkuti, District – Allahabad on 31.01.2016 in a surprised raid conducted by him and a first information report was registered at Police Station – Shivkuti, District – Allahabad bearing case crime No. 35 of 2016 under Sections 420, 467, 471, 272, 273 I.P.C. and under Sections 60, 72 of the U.P. Excise Act and under Section 62 Copy Right Act, 1957. One accused person at Police Station – Shivkuti, District – Allahabad told that the illicit liquor was being prepared at the old rice mill of the Sudhakar Singh & Diwakar Singh sons of Shri Kunj Bihari Singh resident of Village – Purmai Sultanpur, Police Station – Maheshganj, District – Pratapgarh and it is supplied from there by certain other persons. That on 01.02.2016, Shri Sunil Kumar Dubey, In-charge, Surveillance Cell and his team (other police personnel) got information in regard of huge Adulterated liquor, rapper and equipment for packaging/making liquor in rice mill of said Sudhakar Singh & Diwakar Singh and his team raid at said rice mill where the 15 persons are arrested on the spot including the applicant, they were working with the adulterated liquor. That the applicant is poor person and belongs came from West Bengal for livelihood he was working as labor at Mineral Water Plant which was beside of the said rice mill and during the raid, the concerned police arrested the applicant without any reason and falsely implicate in said case crime for showing good work of the police. That there is no concerned with recovered illegal liquor in any manner with the applicant as he was not arrested on the crime spot as stated by the concerned police in first information report, the police concerned falsely implicated in said case crime. That it is very strange as till 04.03.2016, the recovered liquor has neither sent for the Tanki test nor is forensic test, this fact admitted by the investigating officer of the said case crime by his parcha No. 9 dated 04.03.2016 of the case diary of the case crime. The photocopy of the parcha No. 9 dated 04.03.2016 of the case diary of the case crime is being annexed herewith as Annexure No. 2 to this Affidavit. That thereafter on 23.03.2016, the Tanki test has been conducted by the Excise Inspector, Circle – III, Kunda, Pratapgarh on the both liquor i.e. country made and foreign and nothing has been found in recovered liquor which was obnoxious or spurious for human consumption. The photocopy of the Tanki test dated 23.03.2016 is being annexed herewith as Annexure No. 3 to this Affidavit. That thereafter on 06.04.2016, the sample of the alleged illicit liquor has been sent to the forensic lab for testing and till date the report is awaiting from the forensic lab. That without proper investigation of the case crime, the investigating officer filed charge sheet No. 09 of 2016 dated 08.04.2016 under Sections 420, 467, 468, 471, 272, 273 I.P.C., 60, 63, 72 Excise Act, 3/4 Copyright Act and 103/104 Trade Mark Act against the applicant/accused and others 14 persons. That the applicant/accused in jail from 01.02.2016. That according to the prosecution story it clearly reveals that no one saw the occurrence and there is no any independent eye witness of the said recovery and it is a case of forge, fabricated and false and there is no any evidence against the applicant/accused. That the applicant/accused has no concerned with recovered illicit liquor in any manner as such the Sections 420, 467, 468, 471, 272, 273 I.P.C., 60, 63, 72 Excise Act, 3/4 Copyright Act and 103/104 Trade Mark Act have not followed him. 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 poor 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 the applicant had applied for bail before the Additional Sessions Judge, Room No. 5, Pratapgarh but the same has been rejected on insufficient grounds vide order dated 14.04.2016. The certified copy of bail rejection order dated 14.04.2016 is annexed herewith as Annexure No. 4 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, Ashok Kumar aged about 42 years son of Shri Ram Swaroop resident of Village – Kanikamau, Police Station – Gangaghat, District - Unnao, Religion – Hindu, Qualification – Illiterate, Occupation – Agriculture, the deponent do hereby solemnly affirm and  state on oath as under :- That the deponent is brother of the 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. 17 of 2021 under Sections 323, 308, 427, 506 of IPC at Police Station – Gangaghat, District – Unnao on 20.01.2021 at 19.0 hours against the applicant and three other accused persons with regard to incident dated 19.01.2021. The certified copy/ typed copy of the first information report dated 20.01.2021 is being annexed herewith as Annexure No. 1 to this Affidavit. That according to the First Information Report, which has been lodged by Shri Govind son of late Maiku Kori (hereinafter referred to as ‘informant’), the prosecution story is in nutshell, that on 19.01.2021, the son of the informant was returning to his home by his motorcycle on which one Surendra was also with his son. When the son of the informant blow the horn for pass then applicant and other accused of the case crime brutally assaulted upon the son of the informant, in which he sustained several severe injuries. The informant further alleged that the mobile of his son and Rs. 4000/- also misplaced during said incident. That the first information report lodged after one day without giving explanation of the delay, which is creates doubt upon the prosecution story. That the applicant is common man of society and has no concerned with the alleged incident as stated by the informant in his first information report. That the injured was brought to the District Hospital, Unnao for the treatment by the concerned police. The medical of the injured conducted on 20.01.2021, in which the four injuries shown. According to the medical report, two injuries were fresh and one was recorded as one day old. The photo/typed copy of the medical report of injured dated 20.01.2021 is being annexed herewith as Annexure No. 2 to this Affidavit. That the statement of the informant has been recorded by the concerned police under Section 161 of Cr.P.C. on 21.01.2021, in which he almost repeated his first information report and also stated that his son was driving his own motorcycle and stated that one accused Ram Lakhan son of Lakhan not involved in the alleged crime. The typed copy of the statement of the informant dated 21.01.2021 is being annexed herewith as Annexure No. 3 to this Affidavit. That it is very strange that after the incident the informant known about all accused and lodged the first information report by name and very next of lodging first information report he also investigate the matter and found that one accused was not involved in the case crime. That the son of the informant has recorded his statement before the concerned police under Section 161 of Cr.P.C. on 28.01.2021, in which he also repeated version of the first information report in his own words and also stated that after his investigation he found that Ram Lakhan was not present at time of incident. The typed copy of the statement of the injured dated 28.01.2021 is being annexed herewith as Annexure No. 4 to this Affidavit. That after one month the statement of the Surendra, who was on the motorcycle of the informant’s son on alleged incident dated 19.01.2021, recorded by the concerned police on 20.02.2021, in which he stated that his motorcycle was driving by the son of the informant and after blowing the horn, the applicant and others accused annoyed and assaulted upon the injured and he runaway from the incident. The typed copy of the statement of the alleged eyewitness Surendra dated 20.02.2021 is being annexed herewith as Annexure No. 5 to this Affidavit. That there is contradiction between the statement of the informant and alleged eyewitness that they both claimed that motorcycle belongs to him. That the real fact is that the applicant are falsely implicated in the case crime without any rhyme and reason due to village party bandi, which has been explained by the concerned police for the ulterior motive. That on 19.01.2021, the son of informant, when returning to his home, driving very negligently due to which the applicant scolded him. That the after few meter away from the village of the applicant, the son of the informant hit someone then he was beaten by the unknown person and then the enemy of the applicant found golden chance to implicate the applicant in said case crime. That due to enmity with the applicant’s family the informant for taking revenge from the applicant, lodged a first information report against the him. That in result thereof, the informant ultimately falsely implicates the applicant, in the said crime, which is baseless and illegal due to enmity with family members of the applicant. That on bare perusal of the first information report, it is also evident that there were no witnesses of alleged incident, however, the several eyewitness have been produced by the concerned police but no one helped the son of the informant, which also creates doubts upon the story of the informant, which itself concocted and false. That the applicant is in jail since 23.01.2021 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 incident and it is a case of forge, fabricated and false and there is no any evidence against the applicant. That the applicant was arrested by the concerned police on 23.01.2021 and without proper investigation of the case crime, the investigating officer submitted the charge sheet against the applicant and others accused bearing No. 60 of 2021 on 10.03.2021. 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:- Criminal Case No. 1246 of 2012 under Sections 323, 504, 506 of I.P.C., related to Police Station – Ganga Ghat, District – Unnao, in which the applicant has been granted bail on 03.01.2019 by the court below. Case Crime No. 382 of 2018 under Sections 323, 504, 427 of I.P.C., registered at Police Station – Ganga Ghat, District – Unnao, in which the applicant has been granted bail on 29.11.2021 by the court below. Case Crime No. 2154 of 2012 under Sections 323, 504, 506 of I.P.C., registered at Police Station – Ganga Ghat, District – Unnao, in which the applicant has been granted bail on 26.11.2021 by the court below. Criminal Case No. 9245 of 2010 under Sections 323, 504, 506 of I.P.C., related to Police Station – Ganga Ghat, District – Unnao, in which the applicant has been granted bail on 15.03.2016 by the court below. Case Crime No. 2963 of 2010 under Sections 3/25 Arms Act, registered at Police Station – Ganga Ghat, District – Unnao, in which the applicant has been granted bail on 10.11.2010 by the court below. The photocopies of the bail orders passed by the court below are being annexed herewith as Annexure No. 6 to this application. That during the Covid-19, in compliance of the Hon'ble Apex Court passed in Suo Moto Writ Petition No. 1 of 2020, the applicant was released on payroll on 12.05.2021 and he surrendered before the court concerned on 05.10.2021. That the applicant had applied for bail before the Sessions Judge, Unnao bearing Bail Application No. 187 of 2021 is rejected by the court concerned without going to fact and records. The free copy of bail rejection order dated 26.03.2021 passed by the court concerned is annexed herewith as Annexure No. 7 to this affidavit. That the applicant is the father of the two small children and during this global pandemic they are left alone and the life of the applicant is also in danger in jail as the Covid-19 spreading is too high in jails. 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’s conviction because he has not committed the crime in question, as alleged by the prosecution. 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. 17 of 2021 under Sections 323, 308, 427, 506 of IPC registered at Police Station – Gangaghat, District – Unnao during pendency of trial.


I, Sandeep Singh aged about 21 years son of Shri Kanhaiya Bux Singh resident of Tikiriya Bujurg Kanava, Police Station - Kunda, District – Pratapgarh, Religion – Hindu, Qualification – Literate, Occupation – Student, 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 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 initially treated at Gossainganj, later on he referred to Lucknow but during travelling to Lucknow, the son of the informant died. That the name of the applicant was told by the arrested accused namely Ravi Verma and on basis of which the applicant is named in the first information report. 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 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, Mohd. Vaish and Kuwanr Mahendra Pratap Singh alias Chandan Singh but no anyone named the applicant in said case crime. That later on 02.09.2021, the statement of co-accused Ravi Verma has been recorded by the concerned police, in which he stated that Kuwanr Mahendra Pratap Singh alias Chandan Singh told him that the applicant and Guddu Singh are involved in business of adulterated liquor. The typed copy of the statement of the co-accused Ravi Verma is being annexed herewith as Annexure No. 3 to this Affidavit. That here it is relevant to mention that the Kuwanr Mahendra Pratap Singh alias Chandan Singh has not named the applicant, in his statement dated 26.08.2021 but the concerned police named the applicant due to extraneous reasons in said case crime. The photo/typed copy of the statement of the accused Kuwanr Mahendra Pratap Singh alias Chandan Singh is being annexed herewith as Annexure No. 4 to this Affidavit. That the applicant is named in the case crime after five months due to extraneous reasons, while there no any concrete evidences against the applicant. 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 applicant named in said case crime only for reason that another accused Sanjay Pratap Singh alias Guddu Singh, who have political enmity with the local Member of Parliament (i.e. ruling party), who is cousin brother. That the concerned police building the pressure upon co-accused Sanjay Pratap Singh alias Guddu Singh falsely implicate the applicant in said case crime due to ulterior motive under the political pressure. 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 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 investigating officer of the case crime, falsely implicates the applicant, in the said crime, on the instructions of the present Member of Parliament, which is baseless and illegal due to ulterior motive. 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 11.11.2021 after surrender in connection with Case Crime No. 50 of 2021, Police Station – Hathigawan, District – Pratapgarh 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, 60A of U.P. Excise Act, 1910 at Police Station – Hathigawan, District – Pratapgarh have not applicable against him. 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. 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 granted bail on 13.12.2021 passed by court below. Case Crime No. 50 of 2021 under Sections 302, 307, 419, 420, 467, 468, 471, 272, 34 of I.P.C., 60, 60A of U.P. Excise Act, 1910 registered at Police Station – Hathigawan, District – Pratapgarh, in which bail application is pending before court below. Case Crime No. 122 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60 of U.P. Excise Act, 1910, at Police Station – Kunda, District – Pratapgarh, in which the applicant granted bail on 20.07.2021 passed by the court below. 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 – Kunda, District – Pratapgarh, in which the applicant granted bail on 16.08.2021 passed by the court below. 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 – Kunda, District – Pratapgarh, in which the applicant granted bail on 16.08.2021 passed by the court below. Case Crime No. 208 of 2021 under Sections 419, 420, 467, 468, 471, 486, 487, 272, 273 of I.P.C., 60, 60A, 63 of U.P. Excise Act, 1910, 63 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 granted bail on 15.12.2021 passed by the court below. Case Crime No. 412 of 2021 under Sections 2/3 of U.P. Gangster and Anti-Social Activities (Prevention) Act, 1986 registered at Police Station – Hathigawan, District – Pratapgarh, in which is bail application is pending before the court below. Case Crime No. 107 of 2021 under Sections 302, 307, 120B, 34, 272, 419, 420, 467, 468, 471 of IPC and 60A, 60 U.P. Excise Act registered Police Station – Gossainganj, District – Ayodhya, this is present case, in which the applicant is being filed before 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. 5 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. 6 to this Affidavit. That the applicant had applied for bail before the Additional Sessions Judge, Room No. 3, Faizabad bearing Bail Application No. 2158 of 2021 under Sections 302, 307, 419, 420, 467, 468, 471, 272, 34 of I.P.C., 60, 60A of U.P. Excise Act, 1910 at Police Station – Hathigawan, District – Pratapgarh which is rejected by the court concerned without going to fact and records. The free copy of bail rejection order dated 04.01.2022 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. 48 of 2021 under Sections 302, 307, 419, 420, 467, 468, 471, 272, 34 of I.P.C., 60, 60A of U.P. Excise Act, 1910 at Police Station – Hathigawan, District – Pratapgarh during pendency of trial.


I, Rikki Singh aged about 20 years son of Shri Kanhaiya Baks Singh resident of Tikariya Bujurg, Post - Kanava, Police Station - Kunda, District – Pratapgarh, Religion – Hindu, Qualification – Literate, Occupation – Student, 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 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 on 13.05.2022 at about 22.59 Hours, the informant Shri Krishna Kumar Mishra Station House Officer, Police Station – Gossainganj, District – Ayodhya lodged a first information report against 6 persons including the applicant at Case Crime No. 128 of 2021 under section 3(1) of U.P. Gangster and Anti-Social Activities (Prevention) Act, 1986 (hereinafter referred to ‘Gangster Act’) in Police Station – Gossainganj, District – Ayodhya. The certified and typed copy of the first information report dated 13.05.2022 is being annexed herewith as Annexure No. 1 to this affidavit. That according to the First Information Report, the applicant is member of a gang and he used to committing the offences in organized manner regularly as they are habitual, for their economic benefit and due to their terror no one can dare to speak against them. That prior to lodging the aforesaid case crime against the applicant, the gang chart has been approved by the District Magistrate, Ayodhya on 11.05.2022. The photocopy of the gang chart dated 11.05.2022 is being annexed herewith as Annexure No. 2 to this affidavit. That for proper adjudication of the case it is submitted that the applicant is totally innocent and does not commit any offence as alleged in the first information report by the informant. That here it is also relevant to mention that the aforesaid case crime has been lodged on the basis of the Case Crime No. 107 of 2021 under Sections 302, 307, 419, 420, 467, 468, 471, 272, 34 of I.P.C., 60, 60A of U.P. Excise Act, 1910 registered at Police Station – Gosainganj, District – Ayodhya, in which the applicant has been granted bail on 24.12.2021 passed by this Hon'ble High Court. The photocopy of the order dated 24.12.2021 passed by this Hon'ble High Court is being annexed herewith as Annexure No. 3 to this affidavit. That during the investigation of the Case Crime No. 107 of 2021, 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 applicants in said case crime. That later on 02.09.2021, the statement of co-accused Ravi Verma of Case Crime 107 of 2021 has been recorded by the concerned police, in which he stated that Kuwanr Mahendra Pratap Singh alias Chandan Singh told him that the applicant is involved in business of adulterated liquor. That later on basis of the statements of witnesses of the Case Crime No. 107 of 2021, the investigating officer of the Case Crime No. 107 of 2021, named the applicant in case crime only on presumption basis in illegal manner for extraneous reasons. That the concerned police of the Police Station – Gosainganj, earlier also lodged a first information report bearing Case Crime No. 217 of 2021 under Section 3(1) of U.P. Gangster and Anti-Social Activities (Prevention) Act, 1986 on 27.07.2021 against the 10 person in relation to the Case Crime No. 107 of 2021 registered at Police Station – Gossainganj, District – Ayodhya. The photocopy of the first information report dated 27.07.2021 lodged at Police Station – Gosainganj, District – Ayodhya is being annexed herewith as Annexure No. 4 to this affidavit. That after lodging the first information report against the applicant, he challenged the same before this Hon'ble High Court bearing Writ Petition No. 3843 (CRLP) of 2022, which is still pending. 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 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 investigating officer of the case crime, falsely implicates the applicant, in the said crime, on the instructions of the present Member of Parliament, which is baseless and illegal due to ulterior motive. That the applicant is in jail since 17.01.2023 after surrender, without committing any offense as alleged against him. 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. 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 granted bail on 13.12.2021 passed by court below. Case Crime No. 50 of 2021 under Sections 302, 307, 419, 420, 467, 468, 471, 272, 34 of I.P.C., 60, 60A of U.P. Excise Act, 1910 registered at Police Station – Hathigawan, District – Pratapgarh, in which bail application is pending before court below. Case Crime No. 122 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60 of U.P. Excise Act, 1910, at Police Station – Kunda, District – Pratapgarh, in which the applicant granted bail on 20.07.2021 passed by the court below. 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 – Kunda, District – Pratapgarh, in which the applicant granted bail on 16.08.2021 passed by the court below. 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 – Kunda, District – Pratapgarh, in which the applicant granted bail on 16.08.2021 passed by the court below. Case Crime No. 208 of 2021 under Sections 419, 420, 467, 468, 471, 486, 487, 272, 273 of I.P.C., 60, 60A, 63 of U.P. Excise Act, 1910, 63 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 granted bail on 15.12.2021 passed by the court below. Case Crime No. 412 of 2021 under Sections 2/3 of U.P. Gangster and Anti-Social Activities (Prevention) Act, 1986 registered at Police Station – Hathigawan, District – Pratapgarh, in which the applicant has been granted bail on 05.03.2022 by this Hon'ble High Court. Case Crime No. 107 of 2021 under Sections 302, 307, 120B, 34, 272, 419, 420, 467, 468, 471 of IPC and 60A, 60 U.P. Excise Act registered Police Station – Gossainganj, District – Ayodhya, in which the applicant has been granted bail on 10.02.2022 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. 5 to this application. That apart of abovementioned cases, there no criminal history against the applicant. That the applicant had moved his bail application bearing number 141 of 2023 before the Special Judge (Gangster) Additional Session judge, Ayodhya and same has been rejected on 31.01.2023. The free certified copy of the bail rejection order dated 31.01.2023 passed by the court below is annexed herewith as Annexure No. 6 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. 128 of 2022 under Section 3(1) of U.P. Gangster and Anti-Social Activities (Prevention) Act, 1986 registered at Police Station – Gossainganj, District– Ayodhya, during pendency of trial, in the interest of justice.


I, Nagendra Singh aged about 48 years son Shri Surendra Bahadur Singh resident of Shitalamau, District – Pratapgarh, Religion – Hindu, Qualification – Post Graduate, Occupation – Private Job, the deponent do hereby solemnly affirm and  state on oath as under :- That the deponent is brother-in-law of the applicant and doing pairvi of applicant in the above noted case and duly authorized by him and as such he is fully conversant with the facts of the case deposed herein under. That the photo 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 have falsely been implicated in case crime No. 322 of 2021 under Sections 8/21 of The Narcotic Drugs and Psychotropic Substances Act, 1985 registered at Police Station – Kotwali Nagar, District – Pratapgarh on 12.04.2021 at 08.33 hours. The first information report has lodged by Shri Ravindra Nath Rai, Station House Officer, Kotwali Nagar, District – Pratapgarh. It is further relevant to mention that the aforesaid first information report is related to the incident dated 11.04.2021 and lodged against the applicant. The photo/type copy of the first information report dated 12.04.2021 is being annexed herewith as Annexure No. 1 to this Affidavit. That the informant lodged the first information report after several hours of the incident without giving any explanation with regard to delay cause in lodging first information report. That the informant stated in his first information report dated 12.04.2021 that on 11.04.2021 the informant alongwith his team on patrolling of the area. At that moment an informer has given information that a person is selling the smack, who is working for the applicant. That the informant has raided the alleged place where he found a person who was selling the smack and he informed that he is working for the applicant, who paid the commission on sale of each packet of smack. That on spotting of the another accused, the informant has raided at the house of the applicant, where the informant has found narcotic and psychotropic substance i.e. smack around 365 grams at applicant’s house. That it is relevant to mention here that the contents of the first information report is beyond the truth as well as imagination. The story of the informant is not collaborated with the fact and circumstances of the alleged case crime. That the applicant is common man of society and has no concerned with the Narcotic Drugs & Psychotropic Substance and the concerned police arrested anther from incident place but without any reason and falsely implicate in said case crime for showing his good work. That there is no concerned with recovered Narcotic Drugs & Psychotropic Substance in any manner with the applicant as he was involved in such type act and the police concerned falsely implicated in said case crime on statement of the arrested accused namely Gauri Shankar Verma. That according to the prosecution story it clearly reveals that no one saw the occurrence and there is no any independent eye witness of the said recovery and it is a case of forge, fabricated and false and there is no any evidence against the applicant. That the informant stated in his first information report that the Circle Officer, City has been informed for compliance of the Section 50 Section of The Narcotic Drugs and Psychotropic Substances Act, 1985, while Circle Officer was not present at time of arrest of the applicant, which is duly cleared from the perusal of the recovery memo, which is the part and parcel of the first information report. There is no signature of the Circle Officer, City on the recovery memo, which is not supported the version of the prosecution. That the real fact of the case is that the applicant has no concerned any type of the act as mentioned in the first information report. The informant for the purpose of getting the reward from the state government, falsely implicate the applicant in said case through the co-accused. That it is most relevant to mention here that the applicant has not committed any offense as alleged by the informant in his first information report dated 12.04.2021. That the applicant has no concerned with the recovered smack as alleged by the informant and also the statement of the co-accused totally baseless and same is not reliable in manner. That the informant has no any independent witnesses of the alleged recovery because of the applicant has not committed any offence. The informant concocted the story and stated the wife of the applicant was present at time of raid and she denied to sign the recovery memo. That the concerned police having no sufficient information and evidence against the applicant, even after knowing the first information report, the applicant surrendered before concerned police, in which the applicant was falsely implicated by the informant. That till date the concerned police has not produced any sufficient evidence against the applicant to prove involvement of the applicant is case crime. That till date there is no forensic report (chemical report) of the recovered substance has been received by the informant to established their story that the applicant is involve in business of the Narcotic Drugs and Psychotropic Substances. 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 8/21 of The Narcotic Drugs and Psychotropic Substances Act, 1985 is made out against the applicant. That since the applicant has not committed any offence as alleged but he has been falsely implicated in the case by the informant in malafide intention. That it is very strange that the informant has not named another accused Gauri Shankar Verma in the first information report, even he has lodged the separate first information report bearing Case Crime No. 323 of 2021 under Sections 8/21 of The Narcotic Drugs and Psychotropic Substances Act, 1985, while as per the informant, the crime of the applicant and another accused are related to one incident. That the informant for the extraneous reasons lodged separate the first information report against another accused to giving benefit and resulting of same, another accused has been released on bail by the court below. That despite false implication of the applicant in said case crime, some other cases have been lodged against the applicant. Except present case crime, which are as under,:- Case Crime No. 627 of 2014 under Sections 8/20 of The Narcotic Drugs and Psychotropic Substances Act, 1985 related to Police Station – Kotwali Nagar, District – Pratapgarh, in which the applicant has been enlarged on bail by Court below on ……….. Case Crime No. 485 of 2015 under Sections 8/20 of The Narcotic Drugs and Psychotropic Substances Act, 1985 related to Police Station – Kotwali Nagar, District – Pratapgarh, in which the applicant has been enlarged on bail by court below on ……………. Case Crime No. 485 of 2015 under Sections 8/20 of The Narcotic Drugs and Psychotropic Substances Act, 1985 related to Police Station – Kotwali Nagar, District – Pratapgarh, in which the applicant has been enlarged on bail by court below on 22.08.2015. Case Crime No. 461 of 2014 under Sections 8/20 of The Narcotic Drugs and Psychotropic Substances Act, 1985 related to Police Station – Kotwali Nagar, District – Pratapgarh, in which the applicant has been enlarged on bail by court below on 12.08.2014. Case Crime No. 593 of 2017 under Sections 8/20 of The Narcotic Drugs and Psychotropic Substances Act, 1985 related to Police Station – Kotwali Nagar, District – Pratapgarh, in which the applicant has been enlarged on bail by court below on 04.10.2017. Case Crime No. 214 of 2017 under Sections 8/20 of The Narcotic Drugs and Psychotropic Substances Act, 1985 related to Police Station – Kotwali Nagar, District – Pratapgarh, in which the applicant has been enlarged on bail by court below on 18.04.2017. Case Crime No. NIL of 2015 under Sections 41, 411 of I.P.C. related to Police Station – Kotwali Nagar, District – Pratapgarh, in which the applicant has been enlarged on bail by court below on 22.08.2015. The photocopies of the bail orders passed by the court concerned are being annexed herewith as Annexure No. 5 to this Affidavit. 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 is in jail since   12.04.2021 without committing any offense. 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 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 the applicant had applied for bail application bearing number 1171 of 2021 but the same has been rejected by the Sessions Judge, Pratapgarh on insufficient grounds vide order dated 10.06.2021. The free certified copy of bail rejection order dated 10.06.2021 passed by the court below is annexed herewith as Annexure No. 6 to this affidavit. That in view of the above, it would be expedient and necessary in the interest of justice that the applicant be enlarged on bail in relation to case crime No. 322 of 2021 under Sections 8/21 of The Narcotic Drugs and Psychotropic Substances Act, 1985 registered at Police Station – Kotwali Nagar, District – Pratapgarh, during pendency of case.


I, Amarjeet Singh aged about 66 years son of Narayan Singh resident of Village – Amarkot, Police Station – Talwandi Chaudhariyan, District – Kapoorthala, Punjab, Religion – Sikh, Qualification – Literate, Occupation – Agriculture, the deponent do hereby solemnly affirm and  state on oath as under :- That the deponent is father of the applicant No. 1 and duly authorized by another application for doing pairvi on his behalf in the above noted case and as such he is fully conversant with the facts of the case deposed herein under. That the photo 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 have falsely been implicated in case crime No. 523 of 2021 under Sections 419, 420 of IPC and 8/20 of The Narcotic Drugs and Psychotropic Substances Act, 1985 registered at Police Station – Lalganj, District – Pratapgarh on 13.08.2021 at 22.19 hours. The first information report has lodged by Shri Ranjeet Singh Bhadauriya, Inspector, Lalganj, District – Pratapgarh (hereinafter referred to as ‘informant’) and the applicants and another. The certified/ type copy of the first information report dated 13.08.2021 is being annexed herewith as Annexure No. 1 to this Affidavit. That the informant stated in his first information report dated 13.08.2021 that on 13.08.2021 the informant alongwith his team on patrolling of the area. At that moment an informer has given information that a truck coming from Pratapgarh, in which hudge amount of ganja is loaded between the paint. That when the informant and his team stopped the suspected truck then the applicants has jumped from truck and runaway and also open fire upon the informant and his team. The informant has arrested the applicants along with huge amount of ganja, which is one quintal one Kg and 600 grams. That the here it is relevant to mention that the recovery cum arresting memo prepared by informant and a copy has been given to the applicant No. 1, on which there are no signature of the team of the informant. That it is relevant to mention here that the contents of the first information report is beyond the truth as well as imagination. The story of the informant is not collaborated with the fact and circumstances of the alleged case crime. That the applicants are common man of society and have no concerned with the Narcotic Drugs & Psychotropic Substance and the concerned police arrested but without any reason and falsely implicate in said case crime for showing his good work. That there is no concerned with recovered Narcotic Drugs & Psychotropic Substance in any manner with the applicants as they have not involved in such type act. That according to the prosecution story it clearly reveals that no one saw the occurrence and there is no any independent eye witness of the said recovery and it is a case of forge, fabricated and false and there is no any evidence against the applicants. That the informant stated in his first information report that the Circle Officer, Lalganj has been informed for compliance of the Section 50 Section of The Narcotic Drugs and Psychotropic Substances Act, 1985, while Circle Officer was not present at time of arrest of the applicants, which is duly cleared from the perusal of the recovery memo, which is the part and parcel of the first information report. There is no signature of the Circle Officer, Lalganj on the recovery memo, which is not supported the version of the prosecution. That the informant has lodged four first information reports at one, related to the one incident, which is clear violation of the judgments and orders passed by the Hon'ble Apex Court as well as this Hon'ble High Court. There is no reason for lodging four first information reports for one incident, it has been done by the informant only for reason that he may show his hard work and also for crating the criminal history of the applicants in concerned Police Station. The cases lodged against the applicants from one incidents are as under: That the real fact of the case is that the applicant has no concerned any type of the act as mentioned in the first information report. When the applicants were carrying the Asian paints from Vishakhapatnam to Ludhiana. The photocopy of the invoice of the Asian paints and transportation papers are being annexed herewith as Annexure No. 2 to this Affidavit. That when the applicants have ready to leave at that moment a person namely Dharmendra Pandit came to the applicants and offered to load the some items, which are food grains to his truck and drop the same in Ludhiana. That the applicants for the extra fare loaded the packets given Dharmendra Pandit and they were unaware that the Dharmendra has loaded the ganja in the truck. That when the truck was stopped by the concerned police, the applicants have fully cooperated the police and they neither runaway nor open fire upon the informant and his team as stated by the informant. That the applicants were assured that Dharmendra loaded food grains but at time of raid the applicants came to know that the same was ganja. That the applicants have not committed the offense, they were carrying the alleged ganja in bonafide manner on presumption of food grain. That the informant has offered to the applicants, if they pay one lack and leave the ganja then they have been released by them but the applicants have no money then they have been arrested and also the informant leveled false allegation of firing upon him and his team. That it is most relevant to mention here that the applicants have not committed any offense as alleged by the informant in his first information report dated 13.08.2021. That the applicants have no concerned with the recovered ganja as alleged by the informant and also the statement of the co-accused totally baseless and same is not reliable in manner. That the informant has no any independent witnesses of the alleged recovery because of the applicants have not committed any offence. The informant concocted the story and stated that the applicants have confessed their guilty during the recovery of the alleged ganja. That the informant has not complied the provisions of the Section 50 of The Narcotic Drugs and Psychotropic Substances Act, 1985 as the Circle Officer is not a Gazette Officer, according to the Section 42 of The Narcotic Drugs and Psychotropic Substances Act, 1985 as such entire raid conducted is null and void. That there is no special or general order has been passed by the Central or State government to empowered the Circle Officer of the police department to entry, search, seizure and arrest without warrant or authorization. That till date the concerned police has not produced any sufficient evidence against the applicants to prove involvement of the applicant is case crime. That till date there is no forensic report (chemical report) of the recovered substance has been received by the informant to established their story that the applicants are involve in business of the Narcotic Drugs and Psychotropic Substances. That there is no credible evidence on record which could show that the applicants are guilty or committed the crime in question and the evidence available on record itself show that no prima-facie offence under Sections 420 of IPC and 8/20 of The Narcotic Drugs and Psychotropic Substances Act, 1985 is made out against the applicants. That till date the informant has not produced the copy of the first information report of Case Crime No. 322 of 2021 registered under Section 307 of IPC which create doubts upon the act of the informant. The photocopy of the questioner dated 08.09.2021 is being annexed herewith as Annexure No. 3 to this Affidavit. That the at time of arresting the copy of the arresting cum recovery memo has been given to the applicant No. 1, on which there were no signatures of the team of the informant. Later on the signatures have been put on the said memo in back dated. The photo/ typed copy of the both recovery cum arresting memo dated 13.08.2021 are being annexed herewith as Annexure No. 4 to this Affidavit. That the applicants have moved the bail application in case crime No. 522 of 2021, 524 of 2021 and 525 of 2021 lodged against the applicants, in which the court below granted the bail vide its order dated 15.09.2021 and 08.10.2021. The photocopies of the orders dated 15.09.2021 and 08.10.2021 passed by the court below are being annexed herewith as Annexure No. 5 to this Affidavit. That since the applicants have not committed any offence as alleged but they have been falsely implicated in the case by the informant in malafide intention. That the applicants had applied for bail application bearing number 2076 of 2021 but the same has been rejected by the Special Judge (N.D.P.S.)/ Additional Sessions Judge (F.T.C.), Pratapgarh on insufficient grounds vide order dated 21.09.2021. The free certified copy of bail rejection order dated 21.09.2021 passed by the court below is annexed herewith as Annexure No. 6 to this affidavit. That there is no chance of applicants absconding or tampering with the prosecution witnesses and they are willing to offer bail to the satisfaction of this Hon’ble Court. That the applicants are in jail since   14.08.2021 without committing any offense. That the applicants have no criminal history except present case crime. That the applicants will cooperate with the trial and will not tamper the prosecution witnesses. That the applicants undertake that they will not misuse the liberty of bail if so granted by this Hon’ble Court. That the applicants are 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 relation to case crime No. 523 of 2021 under Sections 420 of IPC and 8/20 of The Narcotic Drugs and Psychotropic Substances Act, 1985 registered at Police Station – Lalganj, District – Pratapgarh, during pendency of case.


I, Ankit Pandey aged about 22 years son of Shri Sunil Kumar resident of Village – Bandhi, Chhiton, District – Chitrakoot, Education – Literate, Occupation – Private Job, 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 the photo verification slip issued by the Awadh Bar Association is affixed to the affidavit. That this is the first bail application before this Hon'ble Court. No any other bail application is pending before this Hon'ble Court or rejected by this Hon'ble Court. That the instant matter is not related to CBI/Prevention of Corruption Act/ Enforcement Directorate /matters relating to NRHM Scam / GPF Scam/matters of MP/MLA etc. That brief facts of the case are that a first information report was lodged against unknown persons on 06.07.2024 at 14.29 hours by Chhotelal Gautam son of Shri Shivbalak Gautam resident of Village - Gayaspur, Police Station – Kunda, District – Pratapgarh (hereinafter referred to as ‘informant’) bearing Case Crime No. 191 of 2024 under Sections 309(6) of B.N.S., 2023 at Police Station – Kunda, District – Pratapgarh. The certified/ typed copy of the first information report dated 06.07.2024 is being annexed as Annexure No. 01 to this affidavit. That according to the first information report lodged on 06.07.2024, it has been stated by the informant that on 06.07.2024 around 02.15 hours, when the informant was sleeping, some persons entered his house and stole Rs. 3,000/- from the informant’s pant, a mobile phone and also bringing the bags of rice and wheat. On the alarm of the informant, the unknown persons beat the son, daughter, and wife of the informant and also fired. The informant further stated that three males and one female committed the case crime. That the Investigating Officer recorded the statement of the informant under Section 180  of B.N.S.S., 2023 on 07.07.2024 in which the informant repeated his first information report version with additional facts stating that one accused fired to the leg of his daughter namely Sunita. The type copy of the statement of the informant dated 07.07.2024 is being annexed as Annexure No. 02 to this affidavit. That the concerned police arrested two persons on 11.07.2024 namely Shubham Dubey and Chandika. The concerned also recovered Rs. 9,000/- and 315 bore Tamancha from them and also lodged a first information report bearing Case Crime No. 198 of 2024 under Sections 109 of B.N.S., 2023 and 3/25 of Arms Act, 1959 on 11.07.2024. The photocopy of the first information report dated 11.07.2024 is being annexed as Annexure No. 03 to this affidavit. That during the questioning of the arrested accused, no one named the applicant regarding the commission of the alleged case crime. That on 11.07.2024, the police informer of the Investigating Office revealed the name of the applicant to the Investigating Officer first time. That on 18.07.2024, the applicant was arrested by the concerned police, when the applicant was in the office of the Superintendent of Police, Pratapgarh for moving an application regarding inaction of the concerned police relating to Case Crime No. 44 of 2024 under Section 307 of IPC at Police Station – Hathigawan, District – Pratapgarh and also recovered Rs. 3,000/- from the possession of the applicant. The photocopy of the arresting memo dated 18.07.2024 is being annexed as Annexure No. 04 to this affidavit. That the Investigating Officer on the basis of the alleged mobile No. 7052245053, which is not the applicant’s mobile number, came to the conclusion that the applicant committed the case crime. That on the very same day i.e. 18.07.2024, the confessional statement of the applicant was recorded by the Investigating Officer, which was written by him as per his wish to falsely implicate the applicant in said case crime for extraneous reasons. That the story of the police and informant do not collaborate with each other as the informant said only Rs. 3,000/- was stolen on 06.07.2024 whereas in the statement of the applicant, it was stated by the Investigation Officer that the applicant found Rs. 5,000/- as his share after commission of alleged incident. That the version of the first information report is totally false and baseless and the same depends upon the concocted story as such nothing happened as alleged by the informant in her first informant report. That the real story is that the applicant lodged a first information report against two persons bearing Case Crime No. 117 of 2022 under Section 376-D of IPC at Police Station – Kunda, District – Pratapgarh. That when nothing was done by the concerned police of the Police Station – Kunda thereafter the applicant filed a Writ Petition No. 5161 (CRLP) of 2022 (Smt. Neelam Pandey Versus State of U.P. and others) for arresting accused persons and for fair investigation of the case crime. That in said case crime the concerned police without proper investigation, submitted the final report No. 46 of 2022 in favour of the accused persons of the Case Crime No. 117 of 2022 on 11.06.2022, which was challenged by the applicant and the final report dated 11.06.2022 was set aside by the learned court below vide its order dated 11.07.2023 and the concerned police directed to further investigate the matter. The photocopy of the order dated 11.07.2023 passed by the learned court below is being annexed herewith as Annexure No. 05 to this affidavit. That later on, under the pressure, influence along with money power of the accused persons, the concerned police again, without further investigation of the matter submitted his report on 19.09.2023 by which said that the final report dated 11.06.2022 had affirmed, which was set aside by the learned court below on 11.07.2023. That the applicant was doing pairvi against the accused persons of Case Crime No. 117 of 2022 as such they have enmity with the applicant and threatened her to face consequences of the same. That on 08.03.2024, when the applicant was going to the temple at that time one accused of Case Crime No. 117 of 2022 along with two others stopped her and one accused opened fire, which shot in her left hand. On call to 112, the police came and the applicant was brought to C.H.C., Kunda thereafter referred to the S.R.N. Hospital, Prayagraj. That later on, a First Information Report was registered on 09.03.2024 bearing Case Crime No. 44 of 2024 under Section 307 of IPC at Police Station – Hathigawan, District – Pratapgarh against the accused persons. That it is further relevant to mention here that the Investigating Officer has not started the investigation of Case Crime No. 44 of 2024 and not doing anything in the matter against the accused person and the Investigating Officer advised the applicant to keep silent in the matter otherwise the accused person may kill her as well. That when nothing was done by the Investigating Officer of Case Crime No. 44 of 2024 then the applicant filed another Writ Petition No. 4697 (CRLP) of 2024 (Smt. Neelam Pandey Versus State of U.P. and others) for arresting the accused of the Case Crime No. 44 of 2024 as well as fair investigation of said case. That this Hon'ble High Court vide order dated _______ directed to file an affidavit in said writ petition thereafter the concerned police annoyed and with the collaboration of the accused of Case Crime No. 117 of 2022 & 44 of 2024, in a well-planned manner falsely implicates the applicant in present case and she was named in the Case Crime No. 44 of 2024 along with another person Arvind Mishra under the influence of the accused persons of Case Crime No. 117 of 2022 & 44 of 2024 and for extraneous reasons offered by them. That the aforesaid writ petition is pending before this Hon'ble High Court for consideration and for building pressure upon the applicant, she has named in a case crime and also she was made accused in her own case by the concerned police. That due to malafide intention, the Investigating Officer named the applicant knowing everything about the incident i.e. the applicant not commit any offense as alleged against her. That the applicant is not concerned with the alleged incident in any manner as alleged by the concerned police and the allegation against the applicant and also the prosecution story is totally against truth and is not reliable in manner. That neither the applicant has a motive nor has any reasonable motive been assigned to her to commit the crime in question. 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 the record itself shows that no prima-facie offence under Sections 310(2), 311, 317(3) of B.N.S., 2023 at Police Station – Kunda, District – Pratapgarh is made out against the applicant. That the applicant has been falsely implicated in another case bearing Case Crime No. 44 of 2024 under Section 307 of IPC at Police Station – Hathigawan, District – Pratapgarh, which was herself lodged. That the applicant moved bail application No. 2205 of 2024 before the learned Additional Sessions Judge/ F.T.C. - 1, Pratapgarh, and her bail application was rejected by the court concerned on 04.09.2024. The free certified copy of the bail rejection order dated 04.09.2024 passed by the learned court below is being annexed as Annexure No. 06 to this affidavit. That the applicant is in jail since 19.07.2024 without committing any offense. That apart of the abovementioned case, 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 furnish the security and bond and also undertakes that he will never misuse the liberty of bail. That in view of the above, it would be expedient and necessary in the interest of justice that the applicant be enlarged on bail, in relation to Case Crime No. 191 of 2024 under Sections 310(2), 311, 317(3) of B.N.S., 2023 relating to the Police Station – Kunda, District – Pratapgarh, during the pendency of his trial, in the interest of justice.