I, Raghuveer aged about 53 years son of Late Bhagole resident of Village – Allopur Bukhari, Post - Gotnati, Police Station – Kunda, District – Pratapgarh, Religion – Hindu, Qualification – Class 5th Pass, Occupation – Agriculture, the deponent do hereby solemnly affirm and  state on oath as under :- That the deponent is father 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 01.07.2021. 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 01.07.2021 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. 1551 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 11.08.2021 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 no criminal history except this false case, lodged by the informant for extraneous reasons. That the applicant is pursuing his B.A. 3rd years and due to false implication of the applicant in the case crime, his career is in dark. That it is further relevant to mention that prior to conduct the raid the informant has not made entry in the police genera diary, which is already creates doubts upon the prosecution story. 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, Nagendra Bahadur Singh alias Nagendra Singh aged about 63 years son of Shri Raghunandan Singh resident of Village – Dhema, Post – Narayanganj, Police Station – Mandhata, District - Raebareli, Religion – Hindu, Qualification – High School, Occupation – Former, the deponent do hereby solemnly affirm and  state on oath as under :- That the deponent is father/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 photo verification slip 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 affidavit have been explained in Hindi by the counsel of the applicant to him as such she conversant with the facts of the case. That this is first bail application on behalf of the applicant before this Hon'ble High 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. 216 of 2022 under Sections 323, 504, 506, 406 of I.P.C. at Police Station – Naseerabad, District – Raebareli on 04.07.2022 at 18.30 hours against the applicant/accused. The first information report is lodged by Nadeem son of Jaan Mohammad resident of Village – Udapur helmet of Virnawa, Police Station – Naseerabad, District – Raebareli (hereinafter referred to as ‘informant’). The photo/type copy of the first information report dated 04.07.2022 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 has given his truck having registration number UP 32 – AT 0053 to the applicant on rent of 1,10,000/- per month on 14.02.2022. The applicant has given one month rent advance to the informant later he not paid single penny to him even when he asked to return his truck then the applicant abused him and threaten for life. That the applicant is common man of society and has no concerned with the alleged allegation without any reason and falsely implicate in said case crime. That on 05.07.2022, the statement of the informant has recorded by the concerned police under Section 161 of Cr.P.C., in which he repeated averments of his first information report. The typed copy of the statement of the informant dated 05.07.2022 is being annexed herewith as Annexure No. 2 to this Affidavit. That on 21.08.2022, the investigating officer added Sections 420, 468, 471 of IPC in aforesaid case crime. That the real fact is that the applicant has no concerned with the alleged incident as alleged by the informant, which has been developed by the concerned police. That the applicant’s name is Vinay Singh while the first information report lodged against the Vivek Singh. That on 21.08.2022, when the applicant was at home, he was arrested by the concerned police and thereafter falsely implicate in the said case on basis of the Aadhar card. That the confessional statement of the applicant has been recorded by the concerned police on 21.08.2022 under the life threat, in which the applicant said everything as narrated by the concerned police. That here it is relevant to mention here that applicant has no concerned with alleged incident but the concerned police arrested the applicant and connected with the said offense for extraneous reason. 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 apart from instant case, in which this bail application being filed, against the applicant several false cases have been lodged, the details are as under:- The photocopies of the order passed by the Hon'ble High Court and well as the court below are annexed herewith as Annexure No. 3 to this affidavit. That the applicant had applied for bail before bearing No. 2372 of 2022 the Sessions Judge,  Raebareli but the same has been rejected on insufficient grounds vide order dated 24.09.2022. The free certified copy of bail rejection order dated 24.09.2022 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 has no concern. That all the sections, in which the applicant has been falsely implicated by the informant are triable by the first class magistrate. 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. 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. 216 of 2022 lodged under Sections 323, 504, 506, 406, 468, 471, 420 of I.P.C. at Police Station – Naseerabad, District – Raebareli, during pendency of trial.


I, Neeraj Kesharvani aged about 34 years son of Shri Rajendra Prasad resident of 27/6B/10/1, Bhulai Ka Pura, Teliyarganj, Police Station – Shivkuti, District - Pryagraj, Religion – Hindu, Qualification – 10th pass, Occupation – Glossary Shop , 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. 19 of 2022 under Sections 419, 420 of IPC and 3/9 of U.P. Public Examination Act, 1998 at Police Station – Akbarpur, District – Ambedkar Nagar on 23.01.2022 at 13.10 hours against one named accused Jhinku. The certified copy/ typed copy of the first information report dated 23.01.2022 is being annexed herewith as Annexure No. 1 to this Affidavit. That the First Information Report has been lodged by Shri Rahul Mishra, Proctor son of Shri Ram Achal Mishra (hereinafter referred to as ‘informant’). The prosecution story is in nutshell, that on 23.01.2022 the UPTET examination was scheduled and going on. The informant came to know that in the morning shift i.e. 10.00-12.30, a proxy candidate i.e. Jhiknu was present in place of examinee and was caught during checking. That the statement of the accuse Jhinku was recorded by the concerned police on very same day i.e. 23.01.2022 in which is stated that he was giving examination in place of examinee Sandeep Kumar along with other proxies and also stated that one Sandeep Yadav son of Ram Shringar is managing the entire proxy group. Other arrested accused of the case crime namely Akhilesh Nishad & Monika Rathaur have given their statements but not named the applicant. The typed copy of the statement of the accused Jhinku, Akhilesh Nishad and Monika Rathaur dated 23.01.2022 are being annexed herewith as Annexure No. 2 to this Affidavit. That the applicant is not named in the first information report. That the name of the applicant was not came in light till recording of the statement of the Jhinku and other arrested accused of the case crime. That on basis of the statement of the accused Jhinku and another, the Sections 467, 468, 471 of IPC has been adduced in the said case crime by the investigating officer on 23.01.2022. That the statement of the informant has been recorded by the concerned police under Section 161 of Cr.P.C. on 23.01.2022, in which he almost repeated his first information report. The typed copy of the statement of the informant dated 23.01.2022 is being annexed herewith as Annexure No. 3 to this Affidavit. That as per recovery memo dated 24.01.2022, the investigating officer arrested the applicant and another accused Sandeep Yadav at Bus Stand Akabarpur, Ambedkar Nagar, along with his CPU, which was carrying by the applicant. The typed copy of the arresting-cum-recovery memo of the applicant and another dated 24.01.2022 is being annexed herewith as Annexure No. 4 to this Affidavit. That on bare perusal of the arresting-cum-recovery memo it is clear that the applicant has been endorse by the informer of the concerned police as friend of the accused Sandeep Yadav but he has been arrested by the concerned police and produced of the CPU of the applicant, which was brought his home by the concerned police on 23.01.2022. That the statement of the accused Sandeep Yadav has been recorded by the concerned police on 24.01.2022 in which he stated that the applicant was working for him and manipulating the images on the Aadhar Card & Admit Card of the examinee for the proxy examinees/persons. The typed copy of the statement of the accused Sandeep Yadav dated 24.01.2022 is being annexed herewith as Annexure No. 5 to this Affidavit. That the confessional statement of the confessional statement of the applicant has been written/ prepared by the investigating officer on 24.01.2022 tallying with the statement another accused under section 161 Cr.P.C. only to prove the offence against the applicant whereas the applicant has not given any confessional statement. Thereafter, the applicant has been implicated in the instant case. The typed copy of the confessional statement of the applicant dated 24.01.2022 is being annexed herewith as Annexure No. 6 to this Affidavit. 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 real fact is that the applicant is falsely implicated in the case crime without any rhyme and reason by the concerned police for the ulterior motive. That the applicant was running a shop in Prayagraj, where the accused of the case crime i.e. Sandeep Yadav visited but they are not friend and not indulged in any criminal actively as alleged by him against the applicant. That the investigating officer, on 23.01.2022 around 20.00 hours arrested the applicant from his house and also taken his CPU forcefully and brought him to District Ambedkar Nagar without any reason. That next day i.e. on 24.01.2022 at 13.35 hours, the investigating officer of the case crime prepared false and fabricated arresting memo, which there is no independent witness while as the applicant was allegedly arrested from the Bus Stand, Akbarpur. That in overexcitement, the investigating officer stated in the arresting memo that the applicant was has poly-bag, in which carrying the CPU on which his name was painted. It is very strange that the applicant has nothing except the CPU and which was carried itself in poly-bag, which is practically not possible. It is also relevant to mention that there is no reason to carry his CPU to the Ambedkar Nagar but at time of alleging against the applicant, the investigating officer overlooked it. That till date there is no forensic report is submitted by the concerned police, so far concerned to the alleged CPU, in support of their story as the applicant has not involved in any criminal activity as alleged by the concerned police and accused Sandeep Yadav. That on bare perusal of the arresting memo dated 24.01.2022, which is false and fabricated, it is also evident that there were no witnesses of alleged arresting of the applicant, which also creates doubts upon the story of the informant, which itself concocted and false. That the applicant is in jail since 24.01.2022 without committing any offense as alleged against him. That the applicant had applied for bail before the Sessions Judge, Ambedkar Nagar bearing Bail Application No. 78 of 2022 is rejected by the court concerned without going to fact and records. The free copy of bail rejection order dated 02.03.2022 passed by the court concerned is annexed herewith as Annexure No. 7 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 by the co-accused of the case crime and he has no concern with the said crime. That there is no credible evidence on record which could show that the applicant has committed the crime in question and the evidence available on record itself show that no prima-facie offence under 419, 420, 467, 468, 471 of IPC and 3/9 of U.P. Public Examination Act, 1998 at Police Station – Akbarpur, District – Ambedkar Nagar is made out against the applicant. 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. 19 of 2022 under Sections 419, 420, 467, 468, 471 of IPC and 3/9 of U.P. Public Examination Act, 1998 registered at Police Station – Akbarpur, District – Ambedkar Nagar during pendency of trial.


I, Bharat Singh aged about 55 years son of Shri Jagdish Bahadur Singh, resident of Village – Kandhai Ka Purwa, Mohaddipur Balipur, Police Station – Hathigawan, District – Pratapgarh, Religion – Hindu, Qualification – Literate, Occupation – IV Class Government Employee, the deponent do hereby solemnly affirm and  state on oath as under :- That the deponent is father of applicants and doing pairvi of applicants in the above noted case and duly authorized by them 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 applicants 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 applicants have falsely been implicated in 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 at Police Station – Hathigawan, District – Pratapgarh on 02.04.2021 at 12.23 hours against the applicants and several other accused persons. The certified copy/ typed copy of the first information report dated 02.04.2021 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 (other police personnel) were on patrolling of the area vide GD entry No. 21 dated 02.04.2021 at 20.48 hours. At that time the informant got information from his informant (eq[kfcj) in regard of huge adulterated liquor and manufacturing equipments are stored in house of one Shiv Murti Yadav situated at Mohaddinagar and the applicants and other accused are doing business of the adulterated liquor. That the raid has been conducted by the informant along with his team on 02.04.2021 and arrested 7 accused from the spot and also seized lot of adulterated liquor. That the name of the applicants were told by the informer (eq[kfcj) of the concerned police prior to the raid, and on basis which the applicants are named in the impugned first information report. That the names of the applicants are shown at serial No. 1 and 2 respectively in the accused column in the impugned first information report dated 02.04.2021. That the applicants are common man of society and has no concerned with the adulterated liquor and during the raid the applicants were not present at the place of incident, the concerned police arrested the applicants from their village (nearby their house) without any reason and falsely implicate in said case crime for showing good work of the police. That the real fact is that the applicants are falsely implicated in the case crime due to political reasons by the some villagers, which has been explained by the concerned police for ulterior motive. That the applicants and his family members were not supported to one candidate of the Village Pradhan, who has good political approach and money & men power. That the applicants’ father was threatened by the village pradhan candidate to give his support along with his family but the father of the applicants has denied for the same. That therefore the father of the applicants has threatened by the candidate to face consequences of the denial and he ensured that the applicants and his father will send jail soon. That on 01.04.2021, the applicants were in their village and discussing the election of his village pradhan candidate alongwith other persons nearby their house, at time the applicants were arrested by the concerned police and they have been falsely implicated in the 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, 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 it is further relevant to mention here that on bare perusal of the first information report it is clear that the first information report has been lodged on 02.04.2021 at 12.23 hours while in the 7th to 9th line of the contents of the first information mentioned that the informant leaved the police station vide GD entry No. 21 dated 02.04.2021 at 20.48 hours. In this situation it is clear that the informant has lied in recovery memo, on which basis the first information report has been lodged. That the first information report lodged prior to the raid and preparation of the recovery memo, on basis which the first information report lodged against the applicants and others. That initially the first information report has been lodged 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 on 02.04.2021 and after moving the bail application before the court concerned in aforesaid Sections thereafter the concerned police added the Section 60A of U.P. Excise Act, 1910 and moved the application for taking the remand of the applicants and other accused on 14.04.2021. The typed of the remand application moved by the concerned police on 14.04.2021 is being annexed herewith as Annexure No. 2 to this Affidavit. That at time of alleged raid and preparation of recovery and arresting of the memo, the signatures of the applicants and all accused have not taken on the recovery memo, on basis of that ground four other accused have been released on bail by the court concerned. The photocopies of the bail orders passed by the court concerned in said case crime are being annexed herewith as Annexure No. 3 to this Affidavit. That the court concerned specifically stated in its orders that “tekur ds fcUnq ij vkosfndk@vfHk;qDrk ds fo)ku vf/koDrk ,oa ftyk “kkldh; vf/koDrk QkStnkjh dks lquus rFkk miyC/k izi=ksa ds lE;d :is.k ifj”khyuksijkUr fofnr gksrk gS fd QnZ cjkenxh esa fdlh Hkh vfHk;qDrksa ds gLrk{kj ugha gS] fof/k foKku iz;ksx”kkyk ls vis;dj ds ckor dksbZ fjiksVZ vHkh rd izkIr ugha gS rFkk dksbZ rfLdjk lh0Mh0 esa vaafdr ugha gSA” That when the four accused have been released on bail on said ground thereafter the concerned police prepared fake, fabricated and duplicate recovery memo dated 02.04.2021 and also took the signatures of the accused persons from jail. The photo/ typed copy of the forged and fabricated recovery memo dated 02.04.2021 prepared by the concerned police is being annexed herewith as Annexure No. 4 to this Affidavit. That in forged and fabricated recovery memo an endorsement has been made by the concerned police personnel mentioning that “QnZ ds vk/kkj ij eq0v0la0 49@21 /kkjk 420] 467] 468] 471] 272] 273 vkbZ0ih0lh0 60¼2½] 63] 60¼,½] 103@104 O;kikj ,oa i.; oLrq fpUg vf/k0 iaft0 djk;k x;kA” The concerned police person has signed there and mentioned date 02.04.2021. That initially the first information report lodged on the basis of the recovery memo 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 on 02.04.2021 but during preparation of the forged and fabricated recovery memo, it has been mentioned that the on basis of the recovery memo Case Crime No. 49 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. That in view of aforesaid mentioned facts it is crystal clear that the concerned police is manipulating/ creating the evidences against the applicants by preparation of the forged and fabricated i.e. duplicate papers to prove guilty of the applicants before the trial court. That statement of the applicants never recorded by the investigating officer but the applicants came to know that the statements of the applicants initially recorded on 02.04.2021 at 15.00 hours, in which they both have denied their involvement in case crime and willing to give their statement before the court concerned. The typed copies of the alleged statements of the applicants recorded on 02.04.2021 at 15.00 hours are being annexed herewith as Annexure No. 5 to this Affidavit. That thereafter the investigating officer recorded the statements of the applicants as he wanted to record, while the applicants have never given their statements, on 02.04.2021 at 21.00 hours in which the applicants have confessed their guilt and stated they are labors of the main accused of the case crime. The typed copies of the alleged statements of the applicants recorded on 02.04.2021 at 21.00 hours are being annexed herewith as Annexure No. 6 to this Affidavit. That the applicants are in jail since 02.04.2021 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 applicants. That the applicants have 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 informant has not arrested the applicants at alleged place of recovery even not found anything from the applicants’ possession. That the applicants had applied for bail before the Sessions Judge, Pratapgarh bearing Bail Application No. 1034 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 then filed another Bail Application No. 1134 of 2021. The free certified copy of bail rejection order dated 19.05.2021 passed by the court concerned is annexed herewith as Annexure No. 7 to this affidavit. That till date there is no any chemical report stating that the recovered liquor was obnoxious or spurious for human consumption. That the applicants have no criminal history except this false case, lodged by the informant for extraneous reasons. That the applicants have not committed any crime as alleged in the first information report by the informant and they have no concern. That there is no possibility of the applicants’ conviction because they have not committed the crime in question, as alleged by the prosecution. That the applicants are common man of the society. They have never convicted in any case and not involved in any criminal activities ever. 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 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 applicants be enlarged on bail in connection with Case Crime No. 49 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, Dharendra Pratap Singh aged about 37 years son of Shri Jagdish Babadur Singh resident of Pure Gauran, Rautapur, District – Raebareli, Religion – Hindu, Qualification – Literate, Occupation – Agriculture, 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 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 Riyaz Ahmad 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 and Mohd. Vaish but no anyone named the applicant in said case crime. That on 26.08.2021, the investigating officer recorded the statement of the accused of the case crime namely Kuwanr Mahendra Pratap Singh alias Chandan Singh, who first time named the applicant in his statement. The photo/typed copy of the statement of the accused Kuwanr Mahendra Pratap Singh alias Chandan Singh is being annexed herewith as Annexure No. 3 to this Affidavit. 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 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 a common man of the society and running his own business and also managing the business of his wife. The business of the wife of the applicant is in the name of Sarvto Bhadra Traders, which is dealing in house building material and also have a brick field. 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 wife of the applicant was elected as Village Pradhan in last local body election held in year 2015. That it is further relevant to mention that in year 2017 during the State Legislation election the applicant opposed the present local Member of Parliament (i.e. ruling party) due to which he has enmity with the applicant. That the applicant was threatened by the present Member of Parliament to support his candidate, who was contesting for post of Chairman, Zila Panchyat, in local body elections otherwise he would be suffer a lot but the applicant denied for the same as he is follower/ supporter of the other political party, who is contesting against the present ruling party. That due to aforesaid reasons for building pressure upon the applicant and his family, the present Member of Parliament is misusing the District Administration/ authorities against the applicant and lodged the impugned first information report. 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 04.06.2021 in connection with Case Crime No. 48 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 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 having severe Chronic Liver Disease (70% liver is infected) and high diabetic & also suffering from heart disease and was under treatment. After surrender of the applicant, there is no proper treatment is being given to the applicant due to which his life is in danger. The photocopy of the medical prescription of the applicant is being annexed herewith as Annexure No. 4 to this Affidavit. 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 granted bail on 22.11.2021 passed by this Hon'ble High Court. 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. Case Crime No. 51 of 2021 under section 60, 63 of U.P. Excise Act, 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 – Kunda, District – Pratapgarh, in which the applicant granted bail on 24.11.2021 passed by this Hon'ble High Court. 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. 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 this case the name of the applicant came in light from the statements of the accused persons. Case Crime No. 201 of 2021 under Sections 2/3 of U.P. Gangster and Anti-Social Activities (Prevention) Act, 1986 lodged on 09.10.2021 at Police Station – Hathigawan, District – Pratapgarh. Another case has been lodged against the applicant, when he is jail, under the influence of the local politician on 01.04.2021 bearing 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. The aforesaid 9 cases are recently lodged under the political pressure of the local politician against the applicant. Case Crime No. 53 of 2004 under Sections 323, 504, 506, 343 of IPC registered at Police Station – Hathigawan, District – Pratapgarh, in which the applicant has been acquitted by the court concerned. Case Crime No. 685 of 2009 under Sections 147, 148, 504, 506, 323, 363, 120 of IPC and 3(1)10 of S.C. and S.T. Act registered at Police Station – Saurawan, District – Allahabad, in which the concerned police filed submitted final report in favour of the applicant. Case Crime No. 513 of 2010 under Sections 395, 397, 307, 323, 504 of IPC registered at Police Station – Kunda, District – Pratapgarh, in which the applicant has been granted bail by the court concerned. Case Crime No. 302 of 2011 under Section 110G of Cr.P.C. registered at Police Station – Hathigawan, District – Pratapgarh. The applicant has no knowledge about said case. Case Crime No. 19 of 2012 under Section 3(1) Gunda Act registered at Police Station – Hathigawan, District – Pratapgarh. The applicant has no knowledge about said case. Case Crime No. 18 of 2013 under Sections 302 of IPC registered at Police Station – Hathigawan, District – Pratapgarh, in which the applicant has been granted bail by the court concerned. Case Crime No. 20 of 2013 under Sections 302, 504, 506, 120B of IPC registered at Police Station – Hathigawan, District – Pratapgarh, in which the final report has been submitted in favour of the applicant. Case Crime No. 21 of 2013 under Sections 147, 148, 149, 302, 504, 506, 120B of IPC registered at Police Station – Hathigawan, District – Pratapgarh, in which the final report has been submitted in favour of the applicant. 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 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 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. 1893 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 02.12.2021 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. 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, Dharendra Pratap Singh aged about 37 years son of Shri Jagdish Babadur Singh resident of Pure Gauran, Rautapur, District – Raebareli, Religion – Hindu, Qualification – Literate, Occupation – Agriculture, 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 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. 01 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 real fact is that the applicant is a common man of the society and running his own business and also managing the business of his wife. The business of the wife of the applicant is in the name of Sarvto Bhadra Traders, which is dealing in house building material and also have a brick field. 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 wife of the applicant was elected as Village Pradhan in last local body election held in year 2015. That it is further relevant to mention that in year 2017 during the State Legislation election the applicant opposed the present local Member of Parliament (i.e. ruling party) due to which he has enmity with the applicant. That the applicant was threatened by the present Member of Parliament to support his candidate contesting for Zila Panchyat in local body elections otherwise he would be suffer a lot but the applicant denied for the same as he is follower of the other party, which is not ruling and contesting against the present ruling party. That due to aforesaid reasons for building pressure upon the applicant and his family, the present Member of Parliament is misusing the District Administration/ authorities against the applicant and lodged the impugned first information report. 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 informant 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 nothing was recovered in the regard of Adulterated liquor from the applicant’s possession and place in any manner by the informant. 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 has surrendered before the court concerned on 04.06.2021 in case crime No. 48 of 2021 registered at Police Station – Hathigawan, District – Pratapgarh. That after 12 days of the surrender of the applicant, the investigating officer of the aforesaid case crime moved an application on 16.06.2021 for taking judicial custody of the applicant in case crime 124 of 2021, which was allowed. That the investigating officer recorded the statement of the applicant under Section 161 of Cr.P.C. in jail on 18.06.2021, while the investigating officer has not recorded statement as given by the applicant. The type copy of the alleged statement of the applicant recorded on 18.06.2021 is being annexed herewith as Annexure No. 2 to this Affidavit. That thereafter the investigating officer of the case crime No. 124 of 2021 has moved an application before the court concerned to take police custody remand on 28.06.2021. The police custody remand application has been allowed by the court concerned on 29.06.2021 and the applicant sent to police custody remand on 30.06.2021 from 10.00 AM to 06.00 PM. That after taking in police custody remand by the investigating officer on 30.06.2021, a false and fabricated recovery memo has been prepared by the concerned police mentioning therein that on pointing out of the applicant, 33 bottles of 750ml English liquor was recovered from an open place near his house. The typed copy of the recovery memo dated 30.06.2021 is being annexed herewith as Annexure No. 3 to this Affidavit. 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 for the extraneous reasons, the applicant falsely implicated in said case crime for showing good work of the police and while as per best knowledge of the applicant till date the Forensic Science Lab report not received by the investigating officer. 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 in jail since 04.06.2021 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 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 have not applicable against him. That till date there is no any chemical report received from the alleged recovery dated 30.06.2021 stating therein that the recovered liquor was obnoxious or spurious for human consumption. 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 having severe Chronic Liver Disease (70% liver is infected) and high diabetic & also suffering from heart disease and was under treatment. After surrender of the applicant, there is no proper treatment is being given to the applicant due to which his life is in danger. The photocopy of the medical prescription of the applicant is being annexed herewith as Annexure No. 4 to this Affidavit. 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. 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. 51 of 2021 under section 60, 63 of U.P. Excise Act, 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 – Kunda, 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 – Kunda, District – Pratapgarh. 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 this case the name of the applicant came in light from the statements of the accused persons. Case Crime No. 201 of 2021 under Sections 2/3 of U.P. Gangster and Anti-Social Activities (Prevention) Act, 1986 lodged on 09.10.2021 at Police Station – Hathigawan, District – Pratapgarh. Another case has been lodged against the applicant, when he is jail, under the influence of the local politician on 14.10.2021 bearing 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. The aforesaid 9 cases are recently lodged under the political pressure of the local politician against the applicant. Case Crime No. 53 of 2004 under Sections 323, 504, 506, 343 of IPC registered at Police Station – Hathigawan, District – Pratapgarh, in which the applicant has been acquitted by the court concerned. Case Crime No. 685 of 2009 under Sections 147, 148, 504, 506, 323, 363, 120 of IPC and 3(1)10 of S.C. and S.T. Act registered at Police Station – Saurawan, District – Allahabad, in which the concerned police filed submitted final report in favour of the applicant. Case Crime No. 513 of 2010 under Sections 395, 397, 307, 323, 504 of IPC registered at Police Station – Kunda, District – Pratapgarh, in which the applicant has been granted bail by the court concerned. Case Crime No. 302 of 2011 under Section 110G of Cr.P.C. registered at Police Station – Hathigawan, District – Pratapgarh. The applicant has no knowledge about said case. Case Crime No. 19 of 2012 under Section 3(1) Gunda Act registered at Police Station – Hathigawan, District – Pratapgarh. The applicant has no knowledge about said case. Case Crime No. 18 of 2013 under Sections 302 of IPC registered at Police Station – Hathigawan, District – Pratapgarh, in which the applicant has been granted bail by the court concerned. Case Crime No. 20 of 2013 under Sections 302, 504, 506, 120B of IPC registered at Police Station – Hathigawan, District – Pratapgarh, in which the final report has been submitted in favour of the applicant. Case Crime No. 21 of 2013 under Sections 147, 148, 149, 302, 504, 506, 120B of IPC registered at Police Station – Hathigawan, District – Pratapgarh, in which the final report has been submitted in favour of the applicant. The photocopies of the bail order granted by the court concerned and other related documents are being annexed herewith as Annexure No. 5 to this application. That apart of abovementioned cases, there is 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. The photocopies of the bail order passed by the court below are being annexed herewith as Annexure No. 6 to this application. That the applicant had applied for bail before the Sessions Judge, Pratapgarh bearing Bail Application No. 2058 of 2021 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 which is rejected by the court concerned without going to fact and records. The free copy of bail rejection order dated 30.09.2021 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.


I, Dharendra Pratap Singh aged about 37 years son of Shri Jagdish Babadur Singh resident of Pure Gauran, Rautapur, District – Raebareli, Religion – Hindu, Qualification – Literate, Occupation – Agriculture, 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 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. 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 on 05.04.2021 at 20.43 hours against the applicant and other named and unknown 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 Shri Devendra Pratap Singh, Station House Officer, Police Station - Kunda, District – Pratapgarh (hereinafter referred to as ‘informant’) stated therein that the informant and his team on patrolling of area on 05.04.2021 and that time the informant got information from his informer (eq[kfcj) in regard of huge adulterated liquor stored in shop situated between Babuganj Highway and railway line. That the raid has been conducted by the informant alongwith his team on 05.04.2021 at alleged place of occurrence and seized lot of adulterated liquor and no anyone arrested by the concerned police at the time raid. 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. 01 in the accused column in the first information report dated 05.04.2021. That the real fact is that the applicant is a common man of the society and running his own business and also managing the business of his wife. The business of the wife of the applicant is in the name of Sarvto Bhadra Traders, which is dealing in house building material and also have a brick field. 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 wife of the applicant was elected as Village Pradhan in last local body election held in year 2015. That it is further relevant to mention that in year 2017 during the State Legislation election the applicant opposed the present local Member of Parliament (i.e. ruling party) due to which he has enmity with the applicant. That the applicant was threatened by the present Member of Parliament to support his candidate contesting for Zila Panchyat in local body elections otherwise he would be suffer a lot but the applicant denied for the same as he is follower of the other party, which is not ruling and contesting against the present ruling party. That due to aforesaid reasons for building pressure upon the applicant and his family, the present Member of Parliament is misusing the District Administration/ authorities against the applicant and lodged the impugned first information report. 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 informant 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 nothing was recovered in the regard of Adulterated liquor from the applicant’s possession and place in any manner by the informant. 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 has surrendered before the court concerned on 04.06.2021 in case crime No. 48 of 2021 registered at Police Station – Hathigawan, District – Pratapgarh. That after 12 days of the surrender of the applicant, the investigating officer of the aforesaid case crime moved an application on 16.06.2021 for taking judicial custody of the applicant in case crime 125 of 2021, which was allowed. That the investigating officer recorded the statement of the applicant under Section 161 of Cr.P.C. in jail on 18.06.2021, while the investigating officer has not recorded statement as given by the applicant. The type copy of the alleged statement of the applicant recorded on 18.06.2021 is being annexed herewith as Annexure No. 2 to this Affidavit. That thereafter the investigating officer of the case crime has moved an application before the court concerned to take police custody remand on 28.06.2021. The police custody remand application has been allowed by the court concerned on 29.06.2021 and the applicant sent to police custody remand on 30.06.2021 from 10.00 AM to 06.00 PM. That after taking in police custody remand by the investigating officer on 30.06.2021, a false and fabricated recovery memo has been prepared by the concerned police mentioning therein that on pointing out of the applicant, 33 bottles of 750ml English liquor was recovered from an open place near his house. The typed copy of the recovery memo dated 30.06.2021 is being annexed herewith as Annexure No. 3 to this Affidavit. That the concerned police without proper investigation and under the pressure of the local politician against several accused persons including the applicant, filed the charge sheet without receiving the Forensic Science Lab report. That for the extraneous reasons, the applicant falsely implicated in said case crime for showing good work of the police and while as per best knowledge of the applicant till date the Forensic Science Lab report not received by the investigating officer. That under the political influence, after alleged raid dated 03.04.2021 conducted by the SWAT Team, two first information reports lodged i.e. 125 of 2021 and 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 by SWAT Team against the applicant and 12 other persons, for preparing the criminal history against the applicant. That the applicant is in jail since 04.06.2021 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 under Sections 420, 467, 468, 471, 272, 273 of I.P.C. and 60, 60A, 63 of U.P. Excise Act, 1910 have not applicable against him. That till date there is no any chemical report received from the alleged recovery dated 30.06.2021 stating therein that the recovered liquor was obnoxious or spurious for human consumption. 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 having severe Chronic Liver Disease (70% liver is infected) and high diabetic & also suffering from heart disease and was under treatment. After surrender of the applicant, there is no proper treatment is being given to the applicant due to which his life is in danger. The photocopy of the medical prescription of the applicant is being annexed herewith as Annexure No. 4 to this Affidavit. 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. 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. 51 of 2021 under section 60, 63 of U.P. Excise Act, 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 – Kunda, 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 – Kunda, District – Pratapgarh. 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 this case the name of the applicant came in light from the statements of the accused persons. Case Crime No. 201 of 2021 under Sections 2/3 of U.P. Gangster and Anti-Social Activities (Prevention) Act, 1986 lodged on 09.10.2021 at Police Station – Hathigawan, District – Pratapgarh. Another case has been lodged against the applicant, when he is jail, under the influence of the local politician on 14.10.2021 bearing 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. The aforesaid 9 cases are recently lodged under the political pressure of the local politician against the applicant. Case Crime No. 53 of 2004 under Sections 323, 504, 506, 343 of IPC registered at Police Station – Hathigawan, District – Pratapgarh, in which the applicant has been acquitted by the court concerned. Case Crime No. 685 of 2009 under Sections 147, 148, 504, 506, 323, 363, 120 of IPC and 3(1)10 of S.C. and S.T. Act registered at Police Station – Saurawan, District – Allahabad, in which the concerned police filed submitted final report in favour of the applicant. Case Crime No. 513 of 2010 under Sections 395, 397, 307, 323, 504 of IPC registered at Police Station – Kunda, District – Pratapgarh, in which the applicant has been granted bail by the court concerned. Case Crime No. 302 of 2011 under Section 110G of Cr.P.C. registered at Police Station – Hathigawan, District – Pratapgarh. The applicant has no knowledge about said case. Case Crime No. 19 of 2012 under Section 3(1) Gunda Act registered at Police Station – Hathigawan, District – Pratapgarh. The applicant has no knowledge about said case. Case Crime No. 18 of 2013 under Sections 302 of IPC registered at Police Station – Hathigawan, District – Pratapgarh, in which the applicant has been granted bail by the court concerned. Case Crime No. 20 of 2013 under Sections 302, 504, 506, 120B of IPC registered at Police Station – Hathigawan, District – Pratapgarh, in which the final report has been submitted in favour of the applicant. Case Crime No. 21 of 2013 under Sections 147, 148, 149, 302, 504, 506, 120B of IPC registered at Police Station – Hathigawan, District – Pratapgarh, in which the final report has been submitted in favour of the applicant. The photocopies of the bail order granted by the court concerned and other related documents are being annexed herewith as Annexure No. 5 to this application. That apart of abovementioned cases, there is 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. The photocopies of the bail order passed by the court below are being annexed herewith as Annexure No. 6 to this application. That the applicant had applied for bail before the Sessions Judge, Pratapgarh bearing Bail Application No. 2057 of 2021 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 which is rejected by the court concerned without going to fact and records. The free copy of bail rejection order dated 30.09.2021 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. 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 during pendency of trial.


I, Dharendra Pratap Singh aged about 37 years son of Shri Jagdish Babadur Singh resident of Pure Gauran, Rautapur, District – Raebareli, Religion – Hindu, Qualification – Literate, Occupation – Agriculture, 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 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. 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, 63 of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 at Police Station – Hathigawan, District – Pratapgarh on 14.10.2021 at 12.45 hours against the applicant and 5 other persons. The certified copy/ typed copy of the first information report dated 14.10.2021 is being annexed herewith as Annexure No. 1 to this Affidavit. That according to the First Information Report, which has been lodged by Shri Ram Adhar Singh Yadav, Sub Inspector, Police Station - Hathigawan, District – Pratapgarh (hereinafter referred to as ‘informant’). The prosecution story is in nutshell that on 13.10.2021 the informant and his team was on patrolling of area and that time he got information from his informant (eq[kfcj), who told that behind the varsiya chicken shop situated at nearby Purnemau crossing, Hathigawan road, huge adulterated liquor has been stored. That the raid has been conducted by the informant along with his team on 13.10.2021 at alleged place of occurrence and seized lot of adulterated liquor, which was buried  and arrested one accused by the concerned police at time raid. That the name of the applicant was told by the arrested accused namely Riyaz Ahmad 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. 01 in the accused column impugned first information report dated 14.10.2021. That the alleged raid/recovery made by the informant on 13.10.2021 and first information report dated 14.10.2021 is lodged after one day delayed 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 is in jail since 04.06.2021, when the applicant has surrendered before the court concerned on 04.06.2021 in Case Crime No. 48 of 2021. That due to political reasons, the name of the applicant has been falsely implicated in the present case crime on 14.10.2021, even when he is jail since 04.06.2021. That the real fact is that the applicant is a common man of the society and running his own business and also managing the business of his wife. The business of the wife of the applicant is in the name of Sarvto Bhadra Traders, which is dealing in house building material and also have a brick field. 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 wife of the applicant was elected as Village Pradhan in last local body election held in year 2015. That it is further relevant to mention that in year 2017 during the State Legislation election the applicant opposed the present local Member of Parliament (i.e. ruling party) due to which he has enmity with the applicant. That the applicant was threatened by the present Member of Parliament to support his candidate, who was contesting for post of Chairman, Zila Panchyat, in local body elections otherwise he would be suffer a lot but the applicant denied for the same as he is follower/ supporter of the other political party, who is contesting against the present ruling party. That due to aforesaid reasons for building pressure upon the applicant and his family, the present Member of Parliament is misusing the District Administration/ authorities against the applicant and lodged the impugned first information report. 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 informant 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 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 as he is jail since 04.06.2021. 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 04.06.2021 in connection with Case Crime No. 48 of 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 419, 420, 467, 468, 471, 486, 487, 272 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 at Police Station – Hathigawan, District – Pratapgarh have not applicable against him. That till date there is no any chemical report received from the alleged recovery dated 14.10.2021 stating therein that the recovered liquor was obnoxious or spurious for human consumption. 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 having severe Chronic Liver Disease (70% liver is infected) and high diabetic & also suffering from heart disease and was under treatment. After surrender of the applicant, there is no proper treatment is being given to the applicant due to which his life is in danger. The photocopy of the medical prescription of the applicant is being annexed herewith as Annexure No. 2 to this Affidavit. 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 granted bail on 22.11.2021 passed by this Hon'ble High Court. 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, 63 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. 51 of 2021 under section 60, 63 of U.P. Excise Act, 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 – Kunda, District – Pratapgarh, in which the applicant granted bail on 24.11.2021 passed by this Hon'ble High Court. 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. 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 this case the name of the applicant came in light from the statements of the accused persons. Case Crime No. 201 of 2021 under Sections 2/3 of U.P. Gangster and Anti-Social Activities (Prevention) Act, 1986 lodged on 09.10.2021 at Police Station – Hathigawan, District – Pratapgarh. Another case has been lodged against the applicant, when he is jail, under the influence of the local politician on 14.10.2021 bearing 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. The aforesaid 9 cases are recently lodged under the political pressure of the local politician against the applicant. Case Crime No. 53 of 2004 under Sections 323, 504, 506, 343 of IPC registered at Police Station – Hathigawan, District – Pratapgarh, in which the applicant has been acquitted by the court concerned. Case Crime No. 685 of 2009 under Sections 147, 148, 504, 506, 323, 363, 120 of IPC and 3(1)10 of S.C. and S.T. Act registered at Police Station – Saurawan, District – Allahabad, in which the concerned police filed submitted final report in favour of the applicant. Case Crime No. 513 of 2010 under Sections 395, 397, 307, 323, 504 of IPC registered at Police Station – Kunda, District – Pratapgarh, in which the applicant has been granted bail by the court concerned. Case Crime No. 302 of 2011 under Section 110G of Cr.P.C. registered at Police Station – Hathigawan, District – Pratapgarh. The applicant has no knowledge about said case. Case Crime No. 19 of 2012 under Section 3(1) Gunda Act registered at Police Station – Hathigawan, District – Pratapgarh. The applicant has no knowledge about said case. Case Crime No. 18 of 2013 under Sections 302 of IPC registered at Police Station – Hathigawan, District – Pratapgarh, in which the applicant has been granted bail by the court concerned. Case Crime No. 20 of 2013 under Sections 302, 504, 506, 120B of IPC registered at Police Station – Hathigawan, District – Pratapgarh, in which the final report has been submitted in favour of the applicant. Case Crime No. 21 of 2013 under Sections 147, 148, 149, 302, 504, 506, 120B of IPC registered at Police Station – Hathigawan, District – Pratapgarh, in which the final report has been submitted in favour of the applicant. The photocopies of the bail order and other related documents of the applicant are being annexed herewith as Annexure No. 3 to this application. That apart of abovementioned cases, there no criminal history against the applicant. That the applicant had applied for bail before the Sessions Judge, Pratapgarh bearing Bail Application No. 2780 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, 63 of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 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 25.11.2021 passed by the court concerned 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. 48 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, 63 of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 at Police Station – Hathigawan, District – Pratapgarh during pendency of trial.