I, Ravendra Pratap Singh aged about 29 years son of Sri Dal Bahadur Singh resident of Dadauli, Post – Raghauli, Police Station – Manikpur, District – Pratapgarh, Religion – Hindu, Qualification – Graduate, Occupation – Government Servant, the deponent do hereby solemnly affirm and  state on oath as under :- That the deponent is relative of the applicant and doing pairvi of applicant in the above noted case duly authorized by him and as such he is fully conversant with the facts of the case deposed herein under. That the photograph of the deponent is being pated on the first page of this affidavit and photocopy of Voter ID of the deponent is being annexed with this affidavit. That this is first bail application on behalf of the applicant before the  and not other bail application is pending before in any court of law on his behalf. That the facts giving rise to the present case are being stated in brief hereinafter. That the applicant have falsely been implicated in case crime No. 07 of 2014 under section 302 I.P.C. registered at Police Station – Manikpur, District – Pratapgarh on 25.01.2014. The first information report is lodged by the brother of deceased namely Dev Prasad Patel. The true photo/type copy of the first information report dated 25.01.2014 is being annexed herewith as Annexure No. 1 to this Affidavit. That the according the First Information Report the prosecution story is, the deceased has Tata Magic registration No. UP 32 DN – 3659 and same was operated by the deceased. When on 24.01.2014 the deceased was not come to home then the complainant start searching him. Next morning i.e. 25.01.2014 at 05.30 AM the body of complainant’s brother was found on the seat of driver of his own vehicle at Bhadchak – Dandauli road near Mahauta. There were multiple gun shots injuries shown on the body of the deceased and blood was oozing and some gun shots are also found on front of vehicle. That the complainant lodge the first information report on the suspicious ground due to old enmity with the father of another accused namely Vivek and another person namely Kamlesh. That the first information report lodge against the applicant and three other persons on the suspicious and baseless ground. That the statement of complainant recorded under section 161 Cr.P.C. on the same day.  The compliant supported the first information report version. The type copy of the statement of the complainnat under section 161 Cr.P.c. is being annexed herewith as Annexure No. 2 to this Affidavit. That the post mortem of the deceased done on 26.01.2014 at , Pratapgarh. As per post mortem report the cause of death of the deceased is comuama and hammarage and shock as a reamly of Antimortem fire arms injury. The true photo/type copy of the post mortem report dated 26.01.2014 is being annexed herewith as Annexure No. 3 to this Affidavit. That after two days on 27.01.2014, after lodging the first information and giving the statement under section 161 Cr.P.C., the complainant recorded his further statement (Mazeed Bayan) before the investigation officer and build a new prosecution story and stated, time of the incident, one witness namely Dinesh Kumar alias Babloo (brother-in-law of the brother of deceased namely Krishna Kumar Patel) is present and see the incident. That as per information given by the Dinesh Kumar alias Babloo the compliant stated in his further statement that at the time of incident, when the multiple gun shots are fired by the accused persons, at the same time one accused had also injured by the gun shot during the firing but the Dinesh Kumar alias Babloo not identified the injured accused, while the Dinesh Kumar alias Baloo indentified the all four accused by name. The type copy of the further statement (Mazeed Bayan) dated 27.01.2014 is being annexed herewith as Annexure No. 4 to this Affidavit. That the brother of the deceased namely Krishna Kumar Patel also recorded his statement under section 161 Cr.P.C. before the authority concerned on 27.01.2014 and stated on 24.01.2014 at the incident place, the deceased and all four accused person are chatting with together and when he ask to the deceased about the meeting then the deceased replies everything is fine and supporting the further statement of the complainant.  The type copy of the statement of brother of the deceased dated 27.01.2014 is being annexed herewith as Annexure No. 5 to this Affidavit. That the son of the deceased namely Amarjeet Patel also recorded his statement before the investigating officer on 27.01.2014 under section 161 Cr.P.C. and also supported the statement of his uncle statement namely Krishna Kumar Patel. There was no any change in the both statements except style of stating his statements. The type copy of the statement of son of the deceased Krishna Kumar dated 27.01.2014 is being annexed herewith as Annexure No. 6 to this Affidavit. That the so called eye witness namely Dinesh Kumar alias Babloo recorded his statement before the investigation officer on 29.01.2014 under section 161 Cr.P.C.. The so called eye witness stated in his statement, he was present at the time of the incident i.e. 08.30 PM of 24.01.2014. The so called eye witness identified the accused persons. The type copy of the statement so called eye witness dated 29.01.2014 is being annexed herewith as Annexure No. 7 to this Affidavit. That the applicant is surrendered before the C.J.M., Pratapgarh on 24.03.2014 and applicant sent to jail. That the concerned police take the remand of the applicant granted by the court concerned.  Thereafter the police was recovered on the pointing of the applicant one country made Katta (Tamancha) on 03.04.2014. The recovery of the aforesaid Katta (Tamancha) is totally false and baseless; the nothing was recovered from and pointing of the applicant. The photo copy/typed copy of the recovery memo dated 03.04.2014 is being annexed herewith as Annexure No. 8 to this Affidavit. That the first information report lodged against the four persons. After the investigation, the investigation officer filed the charge sheet against the applicant and two other persons in court concerned on 05.05.2014. That the no any specific roll was assigned by the prosecution against the applicant or any accused. That a contradiction in the statement of the so called eyewitness and informant’s statement, according the eyewitness he was seeing the incident at the time of occurrence and he was not informed to police or the informant at that time. That the so called eyewitness has seen the incident at the dark and foggy night of the cold weather, which is highly suspicious. That the so called eyewitness is not disclose the about the incident to anyone till the crimination of the deceased, this is also highly suspicious and same is planted eyewitness after the post mortem of the deceased. That the investigation officer recovered the Katta (Tamancha) only showing the good work of the police department. That the so called eyewitness is stated in his statement he identified the accused persons and during the firing the one accused was injured. But all accused presently in District Jail, Pratapgarh and has not received any fire arm injury. This is unbelievable as the eyewitness stated in his statement. That the so called eyewitness stated in his statement he saw the incident in the front light of the Tata Magic but he not reveal which accused fired his fire arm on the deceased. That according to the prosecution story it clearly reveals that no one saw the occurrence and there is no any eye witness of the case and it is a case of forged and planted eyewitness and evidence and there is no an evidence against the applicant/accused. That the applicant has not committed any crime as alleged in the first information report and he has no concern. That there is no possibility of the applicant conviction because he has not committed the crime in question, as alleged by the prosecution. That the applicant is respectable person of the society. He has never involved in any criminal activities and has no any criminal history. That there is no chance of applicant absconding or tampering with the prosecution witnesses and they are willing to offer bail to the satisfaction of this Hon’ble Court. That the applicant is in Jail since 24.03.2014. That the applicant will cooperate with the trial and will not tamper the prosecution witnesses. That the applicant undertakes that they will not misuse the liberty of bail if so granted by this Hon’ble Court. That the applicant is ready and willing to file adequate surety as the Hon’ble Court may deems fit and proper in the circumstances of the case. That the applicant had applied for bail before the Additional Sessions Judge, Court No. 2 Pratapgarh but the same has been rejected on insufficient grounds vide order dated 19.09.2014. The certified copy of bail rejection order dated 19.09.2014 is annexed herewith as Annexure No. 9 to this affidavit. That the co-accused namely Vivek Singh alias Vivek Pratap Singh has enlarged on bail by the Hon'ble Court order dated 05.09.2014 in  Criminal Misc. Case No. 3908 (B) of 2014. That the co-accused namely Sonu Singh alias Shashank Pratap Singh has also enlarge on bail by the Hon'ble Court order dated 08.10.2014 in Criminal Misc. Case No. 4742 (B) of 2014. The photocopy of the order dated 08.10.2014 passed by Hon'ble Court is annexed herewith as Annexure No. 10 to this affidavit. That in view of the above, it would be expedient and necessary in the interest of justice that the applicants be enlarged on bail during pendency of trial.


I, Dhananjay Singh aged about 52 years son of Shri Sudeshwar Prasad Singh resident of Village – Takkarganj, Police Station – Kotwali Nagar, District – Pratapgarh, Education – Intermediate, Occupation – Agriculture, do hereby solemnly affirm and state on oath as under :- That the deponent is the father/ pairokar of the applicant and duly authorized by the applicant to file the aforesaid application before this Hon'ble Court and as such he is fully conversant with the facts of the case and deposed as under. The ID Proof of the deponent is enclosed and his photograph is affixed on the affidavit. That this is the first bail application before this Hon'ble Court. No any other bail application is pending before this Hon'ble Court or rejected by this Hon'ble Court. That the instant matter is not related to CBI/ prevention of Corruption Act/ Enforcement Directorate /matters relating to NRHM Scam / GPF Scam/matters of MP/MLA etc. That brief facts of the case is that a first information report has been lodged against the applicant and his brother on 04.04.2024 at 21.31 hours by the informant namely Smt. Shabina Bano wife of Abdul Rahman resident of Village – Takkarganj, Police Station – Kotwali Nagar, District – Pratapgarh (hereinafter referred to as ‘informant’) bearing Case Crime No. 180 of 2024 under Sections 323, 504, 506, 308 I.P.C. at Police Station – Kotwali Nagar, District – Pratapgarh regarding the incident dated 25.03.2024. The certified/ typed copy of the first information report dated 04.04.2024 is being annexed as Annexure No. 01 to this affidavit. That according to the first information report lodged on 04.04.2024, the husband of the informant namely was working in the shop of the applicant and due to certain reasons he left the shop of the applicant and started working in another shop due to which the applicant and his brother has enmity with him. On 25.03.2024 aroun 11.30 hours, the applicant and his brother came to nearby the house of the informant and abusing, when the applicant and his brother was restrained by the husband of the informant, the applicant provocked his brother to assult the husband of the informant. That the alleged incident took place on 25.03.2024 while the informant lodged the first information report against the applicant and his brother on 04.04.2024 i.e. after 10 days, which creates doubt upon the prosecution story. That the injured was brought to the hospital, where the medical was conducted on 25.03.2024 and only one injury shown. The photo/typed copy of the injury report of the injured dated 25.03.2024 is being annexed as Annexure No. 02 to this affidavit. That the Investigating Officer recorded the statement of the informant under Section 161  Cr.P.C. on 10.04.2024 in which the informant repeated her first information report version and tried to implicate the applicant in said case crime, which itself false, incorrect and on the basis of presumption. The type copy of the statement of the informant dated 10.04.2024 is being annexed as Annexure No. 03 to this affidavit. That the concerned police also recorded the statements of the sons of the informant under Section 161 of Cr.P.C., who also reapted the version of the first information report and on the basis of the same, the Section 323, 308 of I.P.C. deleted by the Investigating Officer and Section 307 of I.P.C. added on 17.04.2024. That later on, the husband of the informant died on 26.04.2024 thereafter the Investigating Officer started the investigation of the case crime under Section 302 of I.P.C. only vide CD No. 8 dated 01.05.2024. That the inquest report was prepared by the concerned police of the District – Prayagraj on 27.04.2024. That the body of deceased was brought for conducting post mortem on 27.04.2024 at S.R.N. Hospital, Prayagraj, where the post mortem was conducted and the cause of the death ascertained as ‘Infection in both lungs”. The photocopy of the post mortem report dated 27.04.2024 is being annexed as Annexure No. 04 to this affidavit. That the death of the deceased not collobrated with the injury report as well as the statements of the informant and witnesses. The deceased died due to lungs infection not from the head injury. That the version of the first information report is totally false and baseless and same depends upon concocted story as such nothing happened as alleged by the informant in her first informant report. That the applicant surrendered before the learned court below in connection with the said case crime and the confessional statement of the applicant has been recorded by the concerned police under the life threat, in which the applicant said everything as narrated by the concerned police. That it is also unbelievable as stated by the concerned police regarding the recovery of the alleged brick, which was used in the alleged murder, was recovered from the pointing of the brother of the applicant on 16.05.2024 after 42 days of the alleged incident. The photo/typed copy of the recovery memo dated 16.05.2024 is being annexed as Annexure No. 05 to this affidavit. That the real story is that the applicant and his brother were running a shop in the name of Vansh Art, where the deceased was working. That the deceased was ill as such he asked the applicant and his brother for inhancement of his salary and when the same was not inhanced, the deceased leave the work from the applicant’s shop. That after leaving the shop of the applicant, the relation of the applicant & his brother was very good with the deceased, however, the informant and other family members were no happy with the applicant and his brother. That on 25.03.2024, the Holi festival was being celebrated during the said celebration, the deceased was met with an accident with a bike and sustained injuries on his head. That on call, the applicant was also went to the hospital with the deceased from the village to District Prayagraj. That the deceased was died during his treatment due to accident but the applicant has been falsely implicated in the case crime. That due to malafide intention, the informant for her self-satisfaction lodged the first information report against the applicant and his brother after knowing everything about the incident, while they have not committed any offense as alleged against them. That the applicant has no concerned with the murder of the deceased in any manner as alleged by the concerned police and allegation against the applicant and also the prosecution story is totally against truth and same is not reliable in manner. That neither the applicant has motive nor has any reasonable motive been assigned to him to commit the crime in question. That there is no credible evidence on record which could show that the applicant is guilty or committed the crime in question and the evidence available on record itself show that no prima-facie offence under Sections 302 of I.P.C. at Police Station – Kotwali Nagar, District – Pratapgarh is made out against the applicant. That the applicant has been falsely implicated in another case bearing Case Crime No. 268 of 2023 lodged under Sections 419, 420, 467, 468, 471 of I.P.c. at Police Station – Amethi, District – Amethi, in which the applicant has been granted bail by this Hon'ble High Court vide its order dated 24.11.2023. The photocopy of the order dated 24.11.2023 passed by this Hon'ble High Court is being annexed as Annexure No. 06 to this affidavit. That the co-accused of the case crime namely Rishabh Singh moved an application bearing Crl. Misc. Case No. 8135 (B) 2024 before this Hon'ble High Court, which has been allowed by this Hon'ble High Court vide order dated 29.07.2024. The photocopy of the order dated 29.07.2024 passed by this Hon'ble High Court is being annexed as Annexure No. 07 to this affidavit. That the applicant moved bail application No. 2294 of 2024 before the learned Sessions Judge, Pratapgarh and his bail application has been rejected by the court concerned on 23.08.2024. The free certified copy of the bail rejection order dated 23.08.2024 passed by the learned court below is being annexed as Annexure No. 08 to this affidavit. That the applicant is in jail since 29.07.2024 without committing any offense. That apart of the abovementioned case, the applicant has no criminal history ever. That there is no chance of the applicant absconding or tempering with the prosecution witnesses. That the applicant is ready to furnished the security and bond and also undertake that he will be never misused liberty of bail. That in view of the above, it would be expedient and necessary in the interest of justice that the applicant be enlarged on bail, in relation to Case Crime No. 180 of 2024 under Section of I.P.C. relating to the Police Station – Kotwali Nagar, District – Pratapgarh, during pendency of his trial.


I, Ram Khelawan aged about 32 years son of Shri Rameshwar resident of House No. 153, Mohalla – Nariyawaan, Police Station - Maheshganj, District – Pratapgarh, Religion – Hindu, Qualification – Graduate, Occupation – Agriculture, the deponent do hereby solemnly affirm and  state on oath as under :- That the deponent is relative of applicant and doing pairvi of applicant in the above noted case duly authorized by him and as such he is fully conversant with the facts of the case deposed herein under. That the photograph of the deponent is being pated on the first page of this affidavit and photocopy of ID proof of the deponent is being annexed with this affidavit. That this is first bail application on behalf of the applicant before the  and not other bail application is pending before in any court of law on his behalf. That the facts giving rise to the present case are being stated in brief hereinafter. That the applicant have falsely been implicated in case crime No. 256 of 2013 under section 147, 148, 149, 307, 302, 201 I.P.C. registered at Police Station – Jethwara, District – Pratapgarh on 27.08.2013 at 15:30 hours against the applicant/accused and 5 named & 3 unknown persons. The first information report is lodged by Smt. Mehrunnisha first wife of the deceased. The incident took place on 26.08.2013. The true photo/type copy of the first information report dated 27.08.2013 is being annexed herewith as Annexure No. 1 to this Affidavit. That according to the First Information Report the prosecution story is, on 26.08.2013 at about 06.30 P.M., the applicant/accused along with other accused of aforesaid case crime number have committed the murder of Mushaaq. She has further alleged in the first information report that the applicant/accused and other accused persons are be armed with Gun, Addhi, Katta, Kulhari, Farsa and Ballam. She has also alleged in the first information report, three unknown persons have also participated in the aforesaid crime. That in the first information report the informant further alleged that in order to save his life the deceased ran away towards southern side and the accused persons of the case crime have fired upon the deceased as a result of which, the deceased fell down. The informant/wife of deceased and her brother-in-law namely Maksood have raised the alarm as result of which, the accused persons have taken the deceased towards southern side. That in the morning on the search, the body of the deceased was found in a pond near by the machine of Jai Ram. That the inquest on the body of the deceased was conducted on 27.08.2013. The photo/typed copy of the inquest report dated 27.08.2013 is being annexed herewith as Annexure No. 2 to this Affidavit. That the post mortem on the body of the deceased was done on 27.08.2013 at 10:30 P.M. in District Hospital, Pratapgarh. According to the post mortem examination report, the deceased has received lacerated wound along with abraded contusion and two fire arm injuries with one incised wound. It is further submitted that the no punctured wound has been found on the body of the deceased. The photo/typed copy of the post mortem report dated 27.08.2013 is being annexed herewith as Annexure No. 3 to this Affidavit. That the challan lash was also prepared in the form No. 13 and from the perusal of the challan lash it is evidently clear that the time of lodging of the first information report is not mentioned. The photo/typed copy of the challan lash prepared by the investigating officer is being annexed herewith as Annexure No. 4 to this Affidavit. That the site plan was also prepared by the investigating officer on 27.08.2013 and from the perusal of the site plan it is evident that while the informant was present at the place ‘A’ her husband/deceased was surrounded by the accused persons at the place ‘B’. It is further said that at place of ‘B’ the deceased has got the injuries and his body has been found at the place of ‘X’. The distance between the place ‘A’ and ‘B’ is said to the 85 stem while from the place ‘B’ to place ‘X’, where the body of the deceased was found, is measured as 20 steps. The photo/typed copy of the site plan prepared by the investigating officer is being annexed herewith as Annexure No. 5 to this Affidavit. That on 27.08.2013, the same day of occurrence, the statement of the informant Mehrunnisha was recorded by the investigating officer and she has not specified any weapon in the hand of the applicant/accused. The typed copy of the statement of the informant dated 27.08.2013 is being annexed herewith as Annexure No. 6 to this Affidavit. That later on 05.10.2013 the subsequent statement of the informant was again recorded by the next investigating officer and she has stated therein almost similar fact without specifying any weapon in the hand and roll of the applicant/accused. The typed copy of the subsequent statement of the informant dated 05.10.2013 is being annexed herewith as Annexure No. 7 to this Affidavit. That on 28.08.2013, the statement of the brother of the deceased namely Mohd. Maqsood son of Mustqeem has been recorded by the investigating officer. The typed copy of the statement of the brother of the deceased dated 28.08.2013 is being annexed herewith as Annexure No. 8 to this Affidavit. That later on 05.10.2013, the statement of the second wife of the deceased namely Pinki was recorded by the investigating officer. The typed copy of the statement of the second wife of the deceased dated 05.10.2013 is being annexed herewith as Annexure No. 9 to this Affidavit. That the applicant/accused was also arrested by the concerned police on 31.08.2013 and sent to the jail. That during the course of the investigation, the investigating officer has recorded the statement of namely Nizam son Mohd. Ayyub and Qayyum son of Ehtesham Ali on 05.09.2013, in which, they have stated that the accused persons named in the first information have committed that offence with the help of firearms and danda. It is also submitted that the witnesses Nizam and Qayyum have not stated that any person was armed with Kulhari, Farsa and Ballam. The typed copy of the statement of the witnesses Nizam and Qayuum dated 05.09.2013 is being annexed herewith as Annexure No. 10 to this Affidavit. That it is also submitted that the during the course of the investigation, the investigating officer has recorded the statements of Smt. Tarawati wife of Harish Chandra, Shri Karan son of Bhagwan Das, Smt. Furkela wife of Late Ram Samujh, Shyam Lal son of Ram Autar and Ram Lal son of Sukal Das, in which, they have stated that co-accused Hari Lal has been falsely impleacted in the present case and he has not participated in the crime. The typed copies of the statement of the witnesses dated 05.09.2013 are being annexed herewith collectively as Annexure No. 11 to this Affidavit. That the deceased was hardened criminal and he had formed a gang of his own. He was also been challaned under the Gangster Act vide case crime No. 155 of 2002, under section 3(1) Gangster Act at Police Station - Jethwara and the case was going on. That the deceased was involved in numbers of cases. As per criminal history of the deceased was challenged in the following cases:- Case crime No. 361 of 1994 under section 302, 307, 504, 506 I.P.C. and 3(1)5 SC/ST Act, Police Station – Lalganj Case Crime 197 of 1985 under section 379, 323 I.P.C., Police Station – Jethwara Case Crime 169A of 1996 under section 379, 323 I.P.C., Police Station – Jethwara Case Crime 108 of 2000 under section 323, 504, 506 I.P.C., Police Station – Jethwara Case Crime 96 of 2001 under section 379, I.P.C., Police Station – Jethwara Case Crime 02 of 2002 under section 2/3 U.P. Gunda Act, Police Station – Jethwara Case Crime 92 of 2002 under section 147, 148, 149, 302, 452, 506 I.P.C., Police Station – Jethwara Case Crime 155 of 2002 under section 3 (1) U.P. Gangster Act, Police Station – Jethwara Case Crime 121 of 2003 under section 2/3 U.P. Gunda Act, Police Station – Jethwara Case Crime 62 of 2006 under section 394 I.P.C., Police Station – Jethwara Case Crime 273 of 1996 under section 353, 307 I.P.C., Police Station – Jethwara Case Crime 276 of 1996 under section 25 Arms Act, Police Station – Jethwara Case Crime 76 of 2008 under section 25 Arms Act, Police Station – Jethwara That the deceased was bully in the society and he used to have bad eyes upon the girls and ladies of his village and also of neighboring villages. That the deceased was also challaned in the case of Gangster Act along with other accused namely Munnu Singh, Chandra Bhusan and Mulla alias Kaleem and first information report lodged against the deceased and other accused persons on 17.09.2002 under 3 (1) U.P. Gangster Act. The typed copy of the first information report is being annexed herewith as Annexure No. 12 to this Affidavit. That from the facts and circumstances of the case it appears nobody has seen the occurrence and the deceased was done to death in the night. That the body of the deceased was found in the morning as alleged by the prosecution, but the first information was lodged on 27.08.2013 at 15:30 hours. The distance of the place of occurrence than that of Police Station is 9 KMs. This is crystal clearly shows that nobody has seen the occurrence and the deceased was done to death at some unknown place. Even the body of the deceased was taken from the place of occurrence and it was kept in the front of the house of the deceased on a cot. That no blood or any incriminate article has been found from the place of occurrence to suggest that the deceased was done to death near the tube well. That the part of the story has been found false in as much as, that the charge sheet has not been submitted against the Hari Lal Pal alongwith there is similar allegation in the first information report, as well as, in the statement of the witnesses. That the deceased was aged about 45 years of the aged as he has bad eyes upon the girls and ladies, he has forcefully solemnized the Nikah with a Hindu girl namely Pinki, who is aged about 25 years. That according to the prosecution story it clearly reveals that no one saw the occurrence and there is no any eye witness of the case and it is a case of forged and planted eyewitness and evidence and there is no an evidence against the applicant/accused. That the applicant has not committed any crime as alleged in the first information report and he has no concern. That there is no possibility of the applicant conviction because he has not committed the crime in question, as alleged by the prosecution. That the deceased was hardened criminal and have several enemies due to his bad habit because of the he had bad eyes upon the girls and ladies of his village and also of neighboring villages and as well as involve the several crimes, some unknown persons murdered the deceased but due to land dispute with the applicant-accused and his family member, the informant got a golden chance to falsely implicate the applicant/accused and his other family members in the aforesaid case crime. That the applicant is common man of the society. He has never involved in any criminal activities ever. That there is no chance of applicant absconding or tampering with the prosecution witnesses and they are willing to offer bail to the satisfaction of this . That the applicant/accused is in Jail since 31.08.2013. That the applicant will cooperate with the trial and will not tamper the prosecution witnesses. That the applicant undertakes that they will not misuse the liberty of bail if so granted by this . That the applicant is ready and willing to file adequate surety as the  may deems fit and proper in the circumstances of the case. That the applicant had applied for bail before the Additional Sessions Judge, Court No. 4, Pratapgarh but the same has been rejected on insufficient grounds vide order dated 20.08.2014. The certified copy of bail rejection order dated 20.08.2014 is annexed herewith as Annexure No. 13 to this affidavit. That in view of the above, it would be expedient and necessary in the interest of justice that the applicants be enlarged on bail during pendency of trial.


I, Triloki aged about 38 years son of Shri Radheshyam resident of Village – Pure Jodha, Police Station – Lalganj, District – Pratapgarh, Religion – Hindu, Qualification – Literate, Occupation – Agriculture, the deponent do hereby solemnly affirm and  state on oath as under :- That the deponent is cousin brother of applicant and doing pairvi of applicant in the above noted case duly authorized by him and as such he is fully conversant with the facts of the case deposed herein under. That the photograph of the deponent is being pated on the first page of this affidavit and photocopy of ID proof of the deponent is being annexed with this affidavit. That this is first bail application on behalf of the applicant before the  and not other bail application is pending before in any court of law on his behalf. That the facts giving rise to the present case are being stated in brief hereinafter. That the applicant have falsely been implicated in case crime No. 526 of 2014 under section 302 I.P.C. registered at Police Station – Lalganj, District – Pratapgarh on 19.10.2014 at 08:45 hours, in which the applicant is not named. The first information report is lodged by brother-in-law of the deceased namely Shri Rajaram. The true photo/type copy of the first information report dated 19.10.2014 is being annexed herewith as Annexure No. 1 to this Affidavit. That the informant stated in his first information report that the accused persons namely 1. Virendra Yadav son of Ramhesh Yadav and 2. Awadhesh son of Chhote Lal resident of Pure Jodha, Post – Janeshwarganj, Tahsil & Police Station – Lalganj, District – Pratapgarh having bad eye on deceased. On night of 18/19.10.2014 the accused persons murdered the deceased after rape of deceased. That the body of the deceased was send for the post mortem on 20.10.2014 at District Hospital, Pratapgarh wherein the post mortem was done by doctors. The photo/type copy of the post mortem report dated 20.10.2014 is being annexed herewith as Annexure No. 2 to this Affidavit. That according to the post mortem report the five injuries found on the body of the deceased as below: An abrasion of size 2.5X0.5 CM reddish blue in color in front of Rt. side of face 6.5 CM lateral to chin. An abrasion of size 0.5X0.5 CM reddish blue in color is     on Rt. side of chin. An abrasion of size 1.5X0.55 CM blue in color in     an left side of chin An Abrasion of size 3.5X0.5 CM reddish blue in color at left of neck. An abrasion of size 2.5X0.5 CM reddish blue in color on Rt. side of chin 7.5 CM lateral to neck. That the applicant is not named in first information, during the investigation the name of the applicant came in light, in statement of the Bihar Lal Yadav and Mohan Lal Yadav. The witnesses stated that the applicant was generally goes to the deceased home and called regularly, they also alleged the applicant having physical relation with the deceased. The type copy of the statements of the Bihar Lal Yadav and Mohan Lal Yadav are being annexed herewith collectively as Annexure No. 3 to this Affidavit. That the Awadhesh Yadav, who is named in first information report not charge sheeted on the basis of the statement of the Bihar Lal Yadav and Mohan Lal Yadav and they are relative and also have enmity with the family of the applicant, due to which the witnesses falsely implicated in the crime in question. That the deceased was auntie of the applicant and there has no any chance to have physical relation with deceased as alleged by the witnesses. That the statement of the informant has been recorded by the concerned police under section 161 Cr.P.C. therein he clearly stated that the accused persons, who is named in the first information report are committed the crime in question. The typed copy of the statement of the informant is being annexed herewith as Annexure No. 4 to this Affidavit. That two other witnesses namely Ramesh Chandra and Suresh Maurya have recorded their statement before the concerned police and both are also stated that on 19.10.2014, at early morning when they were going to his field for watering, they have seen the accused Virendra Yadav and Awadhesh Yadav, who is named in first information report, running from the house of the deceased after committing the crime in question. The typed copies of the statements of the witnesses namely Ramesh Chandra and Suresh Maurya are being annexed herewith collectively as Annexure No. 5 to this Affidavit. That the investing officer submitted the charge sheet before the court concerned on 30.03.2015 without considering the fact and reality of the case. That according to the prosecution story it clearly reveals that story of the prosecution is based on only presumption and concerned police avoiding the truth of case and there is no an evidence against the applicant/accused. That neither the applicant has motive nor has any motive been assigned to him to commit the crime in question. That there is no credible evidence on record which could show that the applicant is guilty or committed the crime in question and the evidence available on record itself show that no prima-facie offence under section 302 I.P.C. is made out against the applicant. That the applicant has no motive to commit the alleged crime and false motive which given in case, is cooked and fabricated by the concerned police. That since the applicant has not committed any offence as alleged but he has been falsely implicated in the case by the informant in malafide intention. That no any involvement in the said case as alleged in first information report, the applicant has no reason to murder the deceased. That there is no possibility of the applicant conviction because he has not committed the crime in question, as alleged by the prosecution. That the applicant is common man of the society. He has never involved in any criminal activities ever. That the applicant has no criminal history except the aforesaid false case and not likely to hope in future to commit any offence. That there is no chance of applicant absconding or tampering with the prosecution witnesses and they are willing to offer bail to the satisfaction of this . That the applicant/accused is in Jail since   …………………. That the applicant will cooperate with the trial and will not tamper the prosecution witnesses. That the applicant undertakes that they will not misuse the liberty of bail if so granted by this . That the applicant is ready and willing to file adequate surety as the  may deems fit and proper in the circumstances of the case. That the applicant had applied for bail before the Sessions Judge, Pratapgarh but the same has been rejected on insufficient grounds vide order dated 07.05.2015. The certified copy of bail rejection order dated 07.05.2015 is annexed herewith as Annexure No. 6 to this affidavit. That in view of the above, it would be expedient and necessary in the interest of justice that the applicant be enlarged on bail during pendency of case.


I, Smt. Suman Devi aged about 51 years daughter of Shri Amar Bahadur Singh wife of Shri Rajesh alias Lallu Singh resident of Mohanganj, Vikrampur, District - Pratapgarh, Religion – Hindu, Education –Illiterate, Occupation – Housewife, do hereby solemnly affirm and state on oath as under:- That the deponent is the wife/ pairokar of the applicant and duly authorized by the applicant to file the aforesaid application before this Hon'ble Court and as such she is fully conversant with the facts of the case and deposed as under. The ID Proof of the deponent is enclosed and her photograph is affixed to the affidavit. That this is the first bail application before this Hon'ble Court. No any other bail application is pending before this Hon'ble Court or rejected by this Hon'ble Court. That the instant matter is not related to CBI/Prevention of Corruption Act/ Enforcement Directorate /matters relating to NRHM Scam / GPF Scam/matters of MP/MLA etc. That brief facts of the case are that a first information report was lodged against the unknown persons on 11.05.2023 at 08.46 hours by the informant namely Phoolchandra Singh son of Ram Dular Singh resident of Village - Pure Khusai, Mohanlalganj, Police Station - Leelapur, District - Pratapgarh (hereinafter referred to as ‘informant’) bearing Case Crime No. 130 of 2023 under Section 302 I.P.C. at Police Station – Leelapur, District – Pratapgarh regarding the incident dated 10.05.2023. The certified copy of the first information report dated 11.05.2023 is being annexed as Annexure No. 01 to this affidavit. That according to the first information report lodged on 11.05.2023, the prosecution story is in a nutshell that the Mama of the informant namely Shiv Shankar Singh (hereinafter referred to as ‘deceased’) was murdered on the night of 10.05.2023 at a liquor shop by unknown persons. That here it is relevant to mention that the applicant is not named in the first information report. That the inquest report was prepared by the concerned police on 11.05.2023 in the presence of several persons. That the body of the deceased was brought to the P. M., Pratapgarh for conducting the post-mortem on 11.05.2023, where the post-mortem was conducted and the cause of the death was ascertained as ‘shock and hemorrhage”. The photo/ typed copy of the post-mortem report dated 11.05.2023 is being annexed as Annexure No. 02 to this affidavit. That the version of the first information report is totally false and baseless and the same depends upon the concocted story as such nothing happened as alleged by the informant in her first informant report. That the investigating officer recorded the statement of the informant under Section 161  Cr.P.C. on 11.05.2023 in which the informant repeated his first information report version and he did not name the applicant or anyone. The typed copy of the statement of the informant dated 11.05.2023 is being annexed as Annexure No. 03 to this affidavit. Tha just two days after the lodging of the first information report i.e. on 13.05.2023, the further statement of the informant was recorded by the concerned police, in which the informant named the applicant and another person. The informant himself admitted that there was no enmity with the applicant and he also did not know, why the applicant murdered his Mama as alleged by him. The typed copy of the further statement of the informant dated 13.05.2023 is being annexed as Annexure No. 04 to this affidavit. That on 14.05.2023, the applicant and another accused of the case crime were arrested by the concerned police, without any rhyme and reason in connection with the case crime and a recovery memo has been prepared. The typed copy of the arresting memo of the applicant and another dated 14.05.2023 is being annexed as Annexure No. 05 to this affidavit. That on a bare perusal of the arrest memo, the applicant and another were questioned by the concerned police and their statements have been recorded, in which another accused stated that he brutally beaten the deceased and on the night he went to confirm the death of the deceased. The co-accused did not say that the applicant was also involved in the commission of the case crime. That thereafter, the confessional statements of the co-accused and applicant have been written/ prepared by the Investigating Officer on 14.05.2023 as per his wish and tried their best to collaborate with the alleged incident and witnesses under section 161 Cr.P.C. only to prove the offense against the arrested accused and applicant whereas the applicant has not committed any offense. The typed copy of the confessional statement of the arrested co-accused and applicant dated 14.05.2023 is being annexed as Annexure No. 06 to this affidavit. That the confessional statements of the arrested co-accused and applicant were recorded by the concerned police on 14.05.2023 under the life threat, in which the applicant said everything as narrated by the concerned police and the statement of the co-accused changed in comparison to the arresting memo. That it is most humbly submitted that the applicant is innocent and he has falsely been implicated by the informant in the instant case and there is no evidentiary value in the eye of the law relating to the confessional statements given by the arrested accused. That the real story is that the applicant, informant & co-accused are residents of the same village and they known to each other. That here it is relevant to mention that the deceased was not a good person and he had a lot of enemies in the village and outside and he fought on several occasions with several known & unknown persons in a drunken stage. That on 10.05.2023, the deceased, the applicant and the co-accused were at the liquor shop along with several other persons but they were not together. However, they formally met with each other at that place. That the applicant and co-accused after having drinks left the liquor shop and thereafter, what happened at the liquor shop or anywhere else, the applicant has no concerns. That on 11.06.2023 the deceased was murdered by some unknown persons due to their enmity but due to extraneous reasons, best known by the informant, the applicant has been falsely implicated in said case crime. That the prosecution story is unbelievable and beyond the imagination that if the applicant and co-accused had beaten the deceased at the liquor shop and no one saw the said incident. That thereafter, the investigating officer of the case crime, submitted charge sheet No. 119 of 2023 against the applicant and another on 19.06.2023 under Section 302 of I.P.C.. That the deceased was murdered by unknown persons but the applicant has been falsely implicated in the case crime. That due to malafide intention, the informant for extraneous reasons, was falsely implicated in the first information report after knowing everything about the incident, while he has not committed any offense as alleged against him. That the applicant has no concern with the murder of the deceased in any manner as alleged by the informant and the allegation against the applicant along with the prosecution story is totally against truth and is not reliable in manner. That neither the applicant has a motive nor has any reasonable motive been assigned to him to commit the crime in question. That there is no credible evidence on record that could show that the applicant is guilty or committed the crime in question and the evidence available on the record itself shows that no prima-facie offense under Section 302 of I.P.C. at Police Station – Leelapur, District – Pratapgarh is made out against the applicant. That the applicant moved bail application No. 2672 of 2023 before the learned Additional District & Sessions Judge, Court No. 2, Pratapgarh and his bail application was rejected by the court concerned on 28.09.2023. The free certified copy of the bail rejection order dated 28.09.2023 passed by the learned court below is being annexed as Annexure No. 07 to this application. That the applicant is in jail since 14.05.2023 without committing any offense. That apart from the above, there is no criminal history against the applicant. That there is no chance of the applicant absconding or tempering with the prosecution witnesses. That the applicant is ready to furnish the security and bond and also undertakes that he will never misuse the liberty of bail. That in view of the above, it would be expedient and necessary in the interest of justice that the applicant be enlarged on bail, in relation to Case Crime No. 130 of 2023 under Section 302 of I.P.C. relating to the Police Station – Leelapur, District – Pratapgarh, in the interest of justice.


I, Prema Devi aged about 50 years wife of Sri Ram Badan resident of Village – Manau Ka Purva Hamlet of Mauli, Police Station - Kunda, District – Pratapgarh, Religion – Hindu, Qualification – Literate, Occupation – Agriculture, the deponent do hereby solemnly affirm and  state on oath as under :- That the deponent is mother of applicant and also doing pairvi of applicant in the above noted case duly authorized by him and as such she is fully conversant with the facts of the case deposed herein under. That the photograph of the deponent is being pated on the first page of this affidavit and photocopy of ID proof of the deponent is being annexed with this affidavit. That this is first bail application on behalf of the applicant before the  and not other bail application is pending before in any court of law on his behalf. That the facts giving rise to the present case are being stated in brief hereinafter. That the applicant have falsely been implicated in case crime No. 23 of 2015 under Sections 498A, 304B I.P.C. and 3/4 Dowry Prohibition Act, 1961 registered at Police Station – Kunda, District – Pratapgarh on 15.01.2015 at 18:30 hours, against the applicant and one other person namely Ram Badan, who is the father of the applicant. The first information report is lodged by father of the deceased namely Shri Shri Algu Ram. The true photo/type copy of the first information report dated 15.01.2015 is being annexed herewith as Annexure No. 1 to this Affidavit. That the informant stated in his first information report that the marriage of the applicant and his daughter Geeta Devi (hereinafter referred to as deceased) was solemnized around five years ago and the family members of the applicant were tortured on his daughter for dowry. Thereafter a compromise was taken place between the applicant and deceased on 11.01.2010 as they would live happily but on 12.01.2015, the applicant along with his father murdered his daughter and his body throw in well. That the informant also stated as the body of deceased was recovered in presence of him by the concerned police on 12.01.2015 but after three days after consultation with his well-wishers, he lodged a first information report against the applicant/accused and his father on 15.01.2015 on wrong and baseless facts, without giving any explanation for delay. That the informant was present at the time of the preparation of the inquest report, which was prepared by the concerned police on 13.01.2015 and all “Panchan” given their opinion as the deceased has been died due to drowning, in said inquest the informant himself present and appointed as “Panchan”. The photo/type copy of the inquest report dated 13.01.2015 is being annexed herewith as Annexure No. 2 to this Affidavit. That the applicant himself informed to the concerned police in regard to said incident on 13.01.2015 and also he was appointed as “Panchan”. That the body of the deceased was send for the post mortem on 13.01.2015 at District Hospital, Pratapgarh wherein the post mortem was done by doctors. The photo/type copy of the post mortem report dated 13.01.2015 is being annexed herewith as Annexure No. 3 to this Affidavit. That according to the post mortem report the three injuries found on the body of the deceased as below: Contusion of 1.5cmX1cm midline of fore head, 7cm above just of nose. Abrasion of .08cmX0.7cm I front of left knee joint. Multiple abrasion in area of 4cmX3cm in front of left leg, just below left …………. That as per post mortem report the cause of death is “asphyxia as a result of anti-mortem drowning.” By bare perusal of the post mortem report it is crystal clear that the nature of the injuries caused over the body of the deceased were simple and caused during falling in the well not by beaten as alleged by the informant. That the statement of the informant has been recorded by the concerned police under section 161 Cr.P.C. and therein the informant repeated his first information report version in another manner but soul of the first information report in his statement. That the photocopy of the statement of the informant is being annexed herewith collectively as Annexure No. 4 to this Affidavit. That the real fact is this, marriage of the applicant with deceased solemnized in year 2007 and after wedlock of both, the deceased born a child in year of 2009, thereafter some misunderstanding were arisen and same has been resolved and a compromised has been executed 11.01.2010 between the parties concerned. That after said compromise everything was good and life the of applicant and deceased smoothly running but on 12.01.2015 around 7-8PM the deceased went to well to drinking water when she took more time, then applicant came out then he saw, in meantime the deceased was fallen down in well when she was pulling the water from the well, when the alarm was raised by him then the villagers were come at incident spot and the after that the deceased was pullout from the well but there was too late, she was died. That informant was informed by the applicant in regard to misshaping and the informant along with other persons come at the house of the applicant and they are also present at time of inquest report and he was himself become “Panchan”. That the investigating officer submitted the charge sheet before the court concerned on 27.02.2015 bearing No. 05 of 2015 under Sections 498A, 304B I.P.C. and 3/4 Dowry Prohibition Act, 1961 without considering the fact and reality of the case. That according to the prosecution story it clearly reveals that story of the prosecution is based on only presumption and concerned police avoiding the truth of case and there is no an evidence against the applicant/accused. That neither the applicant has motive nor has any motive been assigned to him to commit the crime in question, when he was happy with the deceased and no any issue between the deceased and applicant in regard to dowry as alleged by the informant. That the first information report has been lodged by the informant after legal consultation in result of same the marriage of the deceased with applicant tried to established around 5 years old whereas the marriage of the applicant with deceased solemnized in year 2007. That there is no credible evidence on record which could show that the applicant is guilty or committed the crime in question and the evidence available on record itself show that no prima-facie offence under section 302 I.P.C. is made out against the applicant. That the applicant has no motive to commit the alleged crime and false motive which given in case, is cooked and fabricated by the concerned police. That since the applicant has not committed any offence as alleged but he has been falsely implicated in the case by the informant in malafide intention. That no any involvement in the said case as alleged in first information report, the applicant has no reason to murder the deceased. That there is no possibility of the applicant conviction because he has not committed the crime in question, as alleged by the prosecution. That the applicant is common man of the society. He has never involved in any criminal activities ever. That the applicant has no criminal history except the aforesaid false case and not likely to hope in future to commit any offence. That there is no chance of applicant absconding or tampering with the prosecution witnesses and they are willing to offer bail to the satisfaction of this . That the applicant/accused is in Jail since   17.01.2015. That the applicant will cooperate with the trial and will not tamper the prosecution witnesses. That the applicant undertakes that they will not misuse the liberty of bail if so granted by this . That the applicant is ready and willing to file adequate surety as the  may deems fit and proper in the circumstances of the case. That the applicant had applied for bail but the same has been rejected by the Additional Sessions Judge/F.T.C., Pratapgarh on insufficient grounds vide order dated 11.09.2015. The certified copy of bail rejection order dated 11.09.2015 is annexed herewith as Annexure No. 5 to this affidavit. That in view of the above, it would be expedient and necessary in the interest of justice that the applicant be enlarged on bail during pendency of case.


I, Kamlesh Kumar Yadav aged about 33 years son of Shri Gajadhar Prasad Yadav resident of Village – Salempur Dadaura, Police Station – Kunda, District – Pratapgarh, Religion – Hindu, Qualification – Intermediate, Occupation – Agriculture, the deponent do hereby solemnly affirm and  state on oath as under :- That the deponent is relative of applicant and doing pairvi of applicant in the above noted case duly authorized by him and as such he is fully conversant with the facts of the case deposed herein under. That the photograph of the deponent is being pated on the first page of this affidavit and photocopy of ID proof of the deponent is being annexed with this affidavit. That this is first bail application on behalf of the applicant before the  and not other bail application is pending before in any court of law on his behalf. That the facts giving rise to the present case are being stated in brief hereinafter. That the applicant have falsely been implicated in case crime No. 328 of 2014 under section 302 I.P.C. registered at Police Station – Salon, District – Raibareilly on 04.06.2014 against the accused and another one. The first information report is lodged by Shri Lal Ji Yadav. The incident took place on 03.06.2014. The true photo/type copy of the first information report dated 04.06.2014 is being annexed herewith as Annexure No. 1 to this Affidavit. That the according the First Information Report the prosecution story is, on 03.06.2014 near about 11:30 PM, the dispute arose between the applicant/accused persons and deceased Raj Bahadur, the both accused beaten the deceased, during this the Raj Bahadur died. That the first information report lodge by the ex village pradhan. That the statement of informant recorded under section 161 Cr.P.C. on 04.06.2014 by the investigating officer.  The informant repeat his first information report version in detailed and reveals the two eyewitnesses names. The type copy of the statement of the informant under section 161 Cr.P.C. is being annexed herewith as Annexure No. 2 to this Affidavit. That the statement of eyewitness namely Shri Mangal Dhobi recorded under section 161 Cr.P.C. on 04.06.2014 by the investigating officer. The type copy of the statement of the eyewitness under section 161 Cr.P.C. is being annexed herewith as Annexure No. 3 to this Affidavit. That the statement of eyewitness namely Smt. Premlata wife of Daya Ram Yadav recorded under section 161 Cr.P.C. on 04.06.2014 by the investigating officer. The type copy of the statement of the eyewitness under section 161 Cr.P.C. is being annexed herewith as Annexure No. 4 to this Affidavit. That the post mortem of the deceased done on 04.06.2014 at District Hospital, Raibareilly. As per post mortem report the cause of death of the deceased is shock and hemorrhage as Antimortem injuries. The true photo/type copy of the post mortem report dated 04.06.2014 is being annexed herewith as Annexure No. 5 to this Affidavit. That the first information report lodged against the two persons. After the investigation, the investigation officer filed the charge sheet against the applicant and another accused in court concerned on 27.06.2014. That the no any specific roll was assigned by the prosecution against the applicant or any accused. That the investigation officer recovered the murder weapon on 07.06.2014 only showing the good work of the police department. That according to the prosecution story it clearly reveals that no one saw the occurrence and there is no any eye witness of the case and it is a case of forged and planted eyewitness and evidence and there is no an evidence against the applicant/accused. That the applicant has not committed any crime as alleged in the first information report and he has no concern. That there is no possibility of the applicant conviction because he has not committed the crime in question, as alleged by the prosecution. That the deceased was heavy drinker and have several enemies due to this habit because of the he was borrowed the money from several persons and they are always demanding the money from the deceased. That the informant, who is the former village pradhan, was also have enmity with the applicant due to village peshbandi in the election of pradhan. Due to aforesaid reason he has falsely implicate the applicant in the aforesaid case crime. That the applicant is respectable person of the society. He has never involved in any criminal activities ever. That there is no chance of applicant absconding or tampering with the prosecution witnesses and they are willing to offer bail to the satisfaction of this . That the applicant is in Jail since 07.06.2014. That the applicant will cooperate with the trial and will not tamper the prosecution witnesses. That the applicant undertakes that they will not misuse the liberty of bail if so granted by this . That the applicant is ready and willing to file adequate surety as the  may deems fit and proper in the circumstances of the case. That the applicant had applied for bail before the Sessions Judge, Pratapgarh but the same has been rejected on insufficient grounds vide order dated 07.08.2014. The certified copy of bail rejection order dated 07.08.2014 is annexed herewith as Annexure No. 6 to this affidavit. That in view of the above, it would be expedient and necessary in the interest of justice that the applicants be enlarged on bail during pendency of trial.


I, Kamlesh Kumar Yadav aged about 33 years son of Shri Gajadhar Prasad Yadav resident of Village – Salempur Dadaura, Police Station – Kunda, District – Pratapgarh, Religion – Hindu, Qualification – Intermediate, Occupation – Agriculture, the deponent do hereby solemnly affirm and  state on oath as under :- That the deponent is relative of applicant and doing pairvi of applicant in the above noted case duly authorized by him and as such he is fully conversant with the facts of the case deposed herein under. That the photograph of the deponent is being pated on the first page of this affidavit and photocopy of ID proof of the deponent is being annexed with this affidavit. That this is first bail application on behalf of the applicant before the  and not other bail application is pending before in any court of law on his behalf. That the facts giving rise to the present case are being stated in brief hereinafter. That the applicant have falsely been implicated in case crime No. 328 of 2014 under section 302 I.P.C. registered at Police Station – Salon, District – Raiberelly on 04.06.2014. The first information report is lodged by the Lal Ji Yadav. The true photo/type copy of the first information report dated 04.06.2014 is being annexed herewith as Annexure No. 1 to this Affidavit. That the according the First Information Report the prosecution story is, the deceased has Tata Magic registration No. UP 32 DN – 3659 and same was operated by the deceased. When on 24.01.2014 the deceased was not come to home then the complaint start searching him. Next morning i.e. 25.01.2014 at 05.30 AM the body of complaint’s brother was found on the seat of driver of his own vehicle at Bhadchak – Dandauli road near Mahauta. There were multiple gun shots injuries shown on the body of the deceased and blood was oozing and some gun shots are also found on front of vehicle. That the complaint lodge the first information report on the suspicious ground due to old enmity with the father of applicant and another person namely Kamlesh. That the first information report lodge against the applicant and three other persons on the suspicious and baseless ground. That the statement of complaint recorded under section 161 Cr.P.C. on the same day.  The compliant supported the first information report version. The type copy of the statement of the complaint under section 161 Cr.P.c. is being annexed herewith as Annexure No. 2 to this Affidavit. That the post mortem of the deceased done on 26.01.2014 at , Pratapgarh. As per post mortem report the cause of death of the deceased is comuama and hammarage and shock as a reamly of Antimortem fire arms injury. The true photo/type copy of the post mortem report dated 26.01.2014 is being annexed herewith as Annexure No. 3 to this Affidavit. That after two days on 27.01.2014, after lodging the first information and giving the statement under section 161 Cr.P.C., the complaint recorded his further statement (Mazeed Bayan) before the investigation officer and build a new prosecution story and stated, time of the incident, one witness namely Dinesh Kumar alias Babloo (brother-in-law of the brother of deceased namely Krishna Kumar Patel) is present and see the incident. That as per information given by the Dinesh Kumar alias Babloo the compliant stated in his further statement that at the time of incident, when the multiple gun shots are fired by the accused persons, at the same time one accused had also injured by the gun shot during the firing but the Dinesh Kumar alias Babloo not identified the injured accused, while the Dinesh Kumar alias Baloo indentified the all four accused by name. The type copy of the further statement (Mazeed Bayan) dated 27.01.2014 is being annexed herewith as Annexure No. 4 to this Affidavit. That the brother of the deceased namely Krishna Kumar Patel also recorded his statement under section 161 Cr.P.C. before the authority concerned on 27.01.2014 and stated on 24.01.2014 at the incident place, the deceased and all four accused person are chatting with together and when he ask to the deceased about the meeting then the deceased replies everything is fine and supporting the further statement of the complaint.  The type copy of the statement of brother of the deceased dated 27.01.2014 is being annexed herewith as Annexure No. 5 to this Affidavit. That the son of the deceased namely Amarjeet Patel also recorded his statement before the investigating officer on 27.01.2014 under section 161 Cr.P.C. and also supported the statement of his uncle statement namely Krishna Kumar Patel. There was no any change in the both statements except style of stating his statements. The type copy of the statement of son of the deceased Krishna Kumar dated 27.01.2014 is being annexed herewith as Annexure No. 6 to this Affidavit. That the so called eye witness namely Dinesh Kumar alias Babloo recorded his statement before the investigation officer on 29.01.2014 under section 161 Cr.P.C.. The so called eye witness stated in his statement, he was present at the time of the incident i.e. 08.30 PM of 24.01.2014. The so called eye witness identified the accused persons. The type copy of the statement so called eye witness dated 29.01.2014 is being annexed herewith as Annexure No. 7 to this Affidavit. That the so called eye witness stated in his statement, the applicant has been shouting/encourage to other accused for killing to the deceased. That the applicant is surrendered before the C.J.M., Pratapgarh on 24.03.2014 and applicant sent to jail. That the first information report lodged against the four persons. After the investigation, the investigation officer filed the charge sheet against the applicant and two other persons in court concerned on 05.05.2014. That the no any specific roll was assigned by the prosecution against the applicant or any accused. That a contradiction in the statement of the so called eyewitness and informant’s statement, according the eyewitness he was seeing the incident at the time of occurrence and he was not informed to police or the informant at that time. That the so called eyewitness has seen the incident at the dark and foggy night of the cold weather, which is highly suspicious. That the so called eyewitness is not disclose the about the incident to anyone till the crimination of the deceased, this is also highly suspicious and same is planted eyewitness after the post mortem of the deceased. That the investigation officer recovered the Rifle only showing the good work of the police department. That the recovery of the Rifle is highly suspicious and contradictory because of the aforesaid Rifle is licensed to the mother of the applicant and the same was never used by the applicant. That the applicant is student and perusing his B.A.. That the so called eyewitness is stated in his statement he identified the accused persons and during the firing the one accused was injured. But all accused presently in District Jail, Pratapgarh and has not received any fire arm injury. This is unbelievable as the eyewitness stated in his statement. That the so called eyewitness stated in his statement he saw the incident in the front light of the Tata Magic but he not reveal which accused fired his fire arm on the deceased. That according to the prosecution story it clearly reveals that no one saw the occurrence and there is no any eye witness of the case and it is a case of forged and planted eyewitness and evidence and there is no an evidence against the applicant/accused. That the applicant has not committed any crime as alleged in the first information report and he has no concern. That there is no possibility of the applicant conviction because he has not committed the crime in question, as alleged by the prosecution. That the applicants are respectable persons of the society. He has never involved in any criminal activities and has no any criminal history. That there is no chance of applicant absconding or tampering with the prosecution witnesses and they are willing to offer bail to the satisfaction of this . That the applicants are in Jail since 13.02.2014. That the applicant will cooperate with the trial and will not tamper the prosecution witnesses. That the applicant undertakes that they will not misuse the liberty of bail if so granted by this . That the applicant is ready and willing to file adequate surety as the  may deems fit and proper in the circumstances of the case. That the applicant had applied for bail before the Sessions Judge, Pratapgarh but the same has been rejected on insufficient grounds vide order dated 17.05.2014. The certified copy of bail rejection order dated 29.05.2014 is annexed herewith as Annexure No. 8 to this affidavit. That in view of the above, it would be expedient and necessary in the interest of justice that the applicants be enlarged on bail during pendency of trial.


I, Dhananjay Singh aged about 52 years son of Shri Sudeshwar Prasad Singh resident of Village – Takkarganj, Police Station – Kotwali Nagar, District – Pratapgarh, Education – Intermediate, Occupation – Agriculture, do hereby solemnly affirm and state on oath as under :- That the deponent is the father/ pairokar of the applicant and duly authorized by the applicant to file the aforesaid application before this Hon'ble Court and as such he is fully conversant with the facts of the case and deposed as under. The ID Proof of the deponent is enclosed and his photograph is affixed on the affidavit. That this is the first bail application before this Hon'ble Court. No any other bail application is pending before this Hon'ble Court or rejected by this Hon'ble Court. That the instant matter is not related to CBI/ prevention of Corruption Act/ Enforcement Directorate /matters relating to NRHM Scam / GPF Scam/matters of MP/MLA etc. That brief facts of the case is that a first information report has been lodged against the unknown persons on 04.04.2024 at 21.31 hours by the informant namely Smt. Shabina Bano wife of Abdul Rahman resident of Village – Takkarganj, Police Station – Kotwali Nagar, District – Pratapgarh (hereinafter referred to as ‘informant’) bearing Case Crime No. 180 of 2024 under Sections 323, 504, 506, 308 I.P.C. at Police Station – Kotwali Nagar, District – Pratapgarh regarding the incident dated 25.03.2024. The certified/ typed copy of the first information report dated 04.04.2024 is being annexed as Annexure No. 01 to this affidavit. That according to the first information report lodged on 04.04.2024, the husband of the informant namely was working in the shop of the applicant and due to certain reasons he left the shop of the applicant and started working in another shop due to which the applicant and his brother has enmity with him. On 25.03.2024 aroun 11.30 hours, the applicant and his brother came to nearby the house of the informant and abusing, when the applicant and his brother was restrained by the husband of the informant, the applicant assaulted by brick upon the husband of the informant. That the alleged incident took place on 25.03.2024 while the informant lodged the first information report against the applicant and his brother on 04.04.2024 i.e. after 10 days, which creates doubt upon the prosecution story. That the injured was brought to the hospital, where the medical was conducted on 25.03.2024 and only one injury shown. The photo/typed copy of the injury report of the injured dated 25.03.2024 is being annexed as Annexure No. 02 to this affidavit. That the Investigating Officer recorded the statement of the informant under Section 161  Cr.P.C. on 10.04.2024 in which the informant repeated her first information report version and tried to implicate the applicant in said case crime, which itself false, incorrect and on the basis of presumption. The type copy of the statement of the informant dated 10.04.2024 is being annexed as Annexure No. 03 to this affidavit. That the concerned police also recorded the statements of the sons of the informant under Section 161 of Cr.P.C., who also reapted the version of the first information report and on the basis of the same, the Section 323, 308 of I.P.C. deleted by the Investigating Officer and Section 307 of I.P.C. added on 17.04.2024. That later on, the husband of the informant died on 26.04.2024 thereafter the Investigating Officer started the investigation of the case crime under Section 302 of I.P.C. only vide CD No. 8 dated 01.05.2024. That the inquest report was prepared by the concerned police of the District – Prayagraj on 27.04.2024. That the body of deceased was brought for conducting post mortem on 27.04.2024 at S.R.N. Hospital, Prayagraj, where the post mortem was conducted and the cause of the death ascertained as ‘Infection in both lungs”. The photocopy of the post mortem report dated 27.04.2024 is being annexed as Annexure No. 04 to this affidavit. That the death of the deceased not collobrated with the injury report as well as the statements of the informant and witnesses. The deceased died due to lungs infection not from the head injury. That the version of the first information report is totally false and baseless and same depends upon concocted story as such nothing happened as alleged by the informant in her first informant report. That the applicant surrendered before the learned court below in connection with the said case crime and the confessional statement of the applicant has been recorded by the concerned police on 11.05.2024 under the life threat, in which the applicant said everything as narrated by the concerned police. That it is also unbelievable as stated by the concerned police regarding the recovery of the alleged brick, which was used in the alleged murder, was recovered from the pointing of the applicant on 16.05.2024 after 42 days of the alleged incident. The photo/typed copy of the recovery memo dated 16.05.2024 is being annexed as Annexure No. 05 to this affidavit. That the real story is that the applicant and his brother were running a shop in the name of Vansh Art, where the deceased was working. That the deceased was ill as such he asked the applicant and his brother for inhancement of his salary and when the same was not inhanced, the deceased leave the work from the applicant’s shop. That after leaving the shop of the applicant, the relation of the applicant & his brother was very good with the deceased, however, the informant and other family members were no happy with the applicant and his brother. That on 25.03.2024, the Holi festival was being celebrated during the said celebration, the deceased was met with an accident with a bike and sustained injuries on his head. That on call, the brother of the applicant namely Himanshu Singh was also went to the hospital with the deceased from the village to District Prayagraj. That the deceased was died during his treatment due to accident but the applicant has been falsely implicated in the case crime. That due to malafide intention, the informant for her self-satisfaction lodged the first information report against the applicant and his brother after knowing everything about the incident, while they have not committed any offense as alleged against them. That the applicant has no concerned with the murder of the deceased in any manner as alleged by the concerned police and allegation against the applicant and also the prosecution story is totally against truth and same is not reliable in manner. That neither the applicant has motive nor has any reasonable motive been assigned to him to commit the crime in question. That there is no credible evidence on record which could show that the applicant is guilty or committed the crime in question and the evidence available on record itself show that no prima-facie offence under Sections 302 of I.P.C. at Police Station – Kotwali Nagar, District – Pratapgarh is made out against the applicant. That the applicant moved bail application No. 1503 of 2024 before the learned Sessions Judge, Pratapgarh and his bail application has been rejected by the court concerned on 11.07.2024. The free certified copy of the bail rejection order dated 11.07.2024 passed by the learned court below is being annexed as Annexure No. 06 to this application. That the applicant is in jail since 03.05.2024 without committing any offense. That the applicant has no criminal history ever. That there is no chance of the applicant absconding or tempering with the prosecution witnesses. That the applicant is ready to furnished the security and bond and also undertake that he will be never misused liberty of bail. That in view of the above, it would be expedient and necessary in the interest of justice that the applicant be enlarged on bail, in relation to Case Crime No. 180 of 2024 under Section of I.P.C. relating to the Police Station – Kotwali Nagar, District – Pratapgarh, during pendency of his trial.


I, Babban Singh aged about 25 years son of Samar Bahadur Singh resident of Dadauli, Post – Raghauli, Police Station – Manikpur, District – Pratapgarh, Religion – Hindu, Qualification – High School, Occupation – Agriculture, the deponent do hereby solemnly affirm and  state on oath as under :- That the deponent is relative of applicant No. 2 and Pairokar of the applicant and doing pairvi of applicant in the above noted case duly authorized by him and as such he is fully conversant with the facts of the case deposed herein under. That the photograph of the deponent is being pated on the first page of this affidavit and photocopy of Voter ID of the deponent is being annexed with this affidavit. That this is first bail application on behalf of the applicant before the  and not other bail application is pending before in any court of law on his behalf. That the facts giving rise to the present case are being stated in brief hereinafter. That the applicant have falsely been implicated in case crime No. 07 of 2014 under section 302 I.P.C. registered at Police Station – Manikpur, District – Pratapgarh on 25.01.2014. The first information report is lodged by the brother of deceased namely Dev Prasad Patel. The true photo/type copy of the first information report dated 25.01.2014 is being annexed herewith as Annexure No. 1 to this Affidavit. That the according the First Information Report the prosecution story is, the deceased has Tata Magic registration No. UP 32 DN – 3659 and same was operated by the deceased. When on 24.01.2014 the deceased was not come to home then the complaint start searching him. Next morning i.e. 25.01.2014 at 05.30 AM the body of complaint’s brother was found on the seat of driver of his own vehicle at Bhadchak – Dandauli road near Mahauta. There were multiple gun shots injuries shown on the body of the deceased and blood was oozing and some gun shots are also found on front of vehicle. That the complaint lodge the first information report on the suspicious ground due to old enmity with the father of applicant and another person namely Kamlesh. That the first information report lodge against the applicant and three other persons on the suspicious and baseless ground. That the statement of complaint recorded under section 161 Cr.P.C. on the same day.  The compliant supported the first information report version. The type copy of the statement of the complaint under section 161 Cr.P.c. is being annexed herewith as Annexure No. 2 to this Affidavit. That the post mortem of the deceased done on 26.01.2014 at , Pratapgarh. As per post mortem report the cause of death of the deceased is comuama and hammarage and shock as a reamly of Antimortem fire arms injury. The true photo/type copy of the post mortem report dated 26.01.2014 is being annexed herewith as Annexure No. 3 to this Affidavit. That after two days on 27.01.2014, after lodging the first information and giving the statement under section 161 Cr.P.C., the complaint recorded his further statement (Mazeed Bayan) before the investigation officer and build a new prosecution story and stated, time of the incident, one witness namely Dinesh Kumar alias Babloo (brother-in-law of the brother of deceased namely Krishna Kumar Patel) is present and see the incident. That as per information given by the Dinesh Kumar alias Babloo the compliant stated in his further statement that at the time of incident, when the multiple gun shots are fired by the accused persons, at the same time one accused had also injured by the gun shot during the firing but the Dinesh Kumar alias Babloo not identified the injured accused, while the Dinesh Kumar alias Baloo indentified the all four accused by name. The type copy of the further statement (Mazeed Bayan) dated 27.01.2014 is being annexed herewith as Annexure No. 4 to this Affidavit. That the brother of the deceased namely Krishna Kumar Patel also recorded his statement under section 161 Cr.P.C. before the authority concerned on 27.01.2014 and stated on 24.01.2014 at the incident place, the deceased and all four accused person are chatting with together and when he ask to the deceased about the meeting then the deceased replies everything is fine and supporting the further statement of the complaint.  The type copy of the statement of brother of the deceased dated 27.01.2014 is being annexed herewith as Annexure No. 5 to this Affidavit. That the son of the deceased namely Amarjeet Patel also recorded his statement before the investigating officer on 27.01.2014 under section 161 Cr.P.C. and also supported the statement of his uncle statement namely Krishna Kumar Patel. There was no any change in the both statements except style of stating his statements. The type copy of the statement of son of the deceased Krishna Kumar dated 27.01.2014 is being annexed herewith as Annexure No. 6 to this Affidavit. That the so called eye witness namely Dinesh Kumar alias Babloo recorded his statement before the investigation officer on 29.01.2014 under section 161 Cr.P.C.. The so called eye witness stated in his statement, he was present at the time of the incident i.e. 08.30 PM of 24.01.2014. The so called eye witness identified the accused persons. The type copy of the statement so called eye witness dated 29.01.2014 is being annexed herewith as Annexure No. 7 to this Affidavit. That the so called eye witness stated in his statement, the applicant has been shouting/encourage to other accused for killing to the deceased. That the applicant is surrendered before the C.J.M., Pratapgarh on 24.03.2014 and applicant sent to jail. That the first information report lodged against the four persons. After the investigation, the investigation officer filed the charge sheet against the applicant and two other persons in court concerned on 05.05.2014. That the no any specific roll was assigned by the prosecution against the applicant or any accused. That a contradiction in the statement of the so called eyewitness and informant’s statement, according the eyewitness he was seeing the incident at the time of occurrence and he was not informed to police or the informant at that time. That the so called eyewitness has seen the incident at the dark and foggy night of the cold weather, which is highly suspicious. That the so called eyewitness is not disclose the about the incident to anyone till the crimination of the deceased, this is also highly suspicious and same is planted eyewitness after the post mortem of the deceased. That the investigation officer recovered the Rifle only showing the good work of the police department. That the recovery of the Rifle is highly suspicious and contradictory because of the aforesaid Rifle is licensed to the mother of the applicant and the same was never used by the applicant. That the applicant is student and perusing his B.A.. That the so called eyewitness is stated in his statement he identified the accused persons and during the firing the one accused was injured. But all accused presently in District Jail, Pratapgarh and has not received any fire arm injury. This is unbelievable as the eyewitness stated in his statement. That the so called eyewitness stated in his statement he saw the incident in the front light of the Tata Magic but he not reveal which accused fired his fire arm on the deceased. That according to the prosecution story it clearly reveals that no one saw the occurrence and there is no any eye witness of the case and it is a case of forged and planted eyewitness and evidence and there is no an evidence against the applicant/accused. That the applicant has not committed any crime as alleged in the first information report and he has no concern. That there is no possibility of the applicant conviction because he has not committed the crime in question, as alleged by the prosecution. That the applicants are respectable persons of the society. He has never involved in any criminal activities and has no any criminal history. That there is no chance of applicant absconding or tampering with the prosecution witnesses and they are willing to offer bail to the satisfaction of this . That the applicants are in Jail since 13.02.2014. That the applicant will cooperate with the trial and will not tamper the prosecution witnesses. That the applicant undertakes that they will not misuse the liberty of bail if so granted by this . That the applicant is ready and willing to file adequate surety as the  may deems fit and proper in the circumstances of the case. That the applicant had applied for bail before the Sessions Judge, Pratapgarh but the same has been rejected on insufficient grounds vide order dated 17.05.2014. The certified copy of bail rejection order dated 29.05.2014 is annexed herewith as Annexure No. 8 to this affidavit. That in view of the above, it would be expedient and necessary in the interest of justice that the applicants be enlarged on bail during pendency of trial.


I, Anil Kumar Yadav aged about 32 years son of Shiv Kumar Yadav resident of Pachmahua deah Mahmadpur Bhav, Pratapgarh, Mahmadpur Bhaon, Police Station – Baghrai, District – Pratapgarh, Religion – Hindu, Qualification – Class 8th, Occupation – Private Job, the deponent do hereby solemnly affirm and  state on oath as under :- That the deponent is the Brother/Pairokar of the applicant and doing pairvi of the aforesaid case and as such he is fully conversant with the facts of the case deposed herein under. The photograph of the deponent is being pasted on the first page of this affidavit and photocopy of ID proof of the deponent is being annexed with this affidavit. That this is the first bail application accused/applicant before this Hon'ble Court & no any other bail application preferred by the of accused/applicant in same crime no is either by this Hon'ble Court of Hon'ble High Court at Allahabad That the First Information Report has been lodged on 20.11.2022 at 01:04 O' clock by the informant namely Ranjana Pal in Case Crime No./FIR No. 0302/2022, U/S-147/302/120-B/506 1.P.C. at Police Station- Baghrai District-Pratapgarh regarding the incident. dated 18.11.2022 at 20:000' clock against the  8  accused persons regarding murder of her father by shooting him with a pistol. The Certified/typed copy of First Information Report dated 20.11.2022 is being annexed herewith as Annexure No.1 to this affidavit. That according to prosecution story is that on 18.11.2022 at 8:00 pm. night the above named accused persons came to the house of the informant and when the father of the informant came out of the house, the said persons took him away saying that they were a party. In the morning the informant came to know that his father's dead body was lying on a canal 400 meter away from the village. The accused persons by shooting with pistols regarding the land dispute, there is a delay of approximately 2 days in filing the first information report. That during the course of investigation the investigating officer has recorded statement co-accused Ramesh Chandra Pal under section 161 Cr.P.C on 23/11/2022 at 19:26 clock. That the basis of statement of co-accused, applicant was implicated as accused on the basis of wrong evidence found of the above mentioned cases and on the basis of hearsay without proper investigation. That on 20.11.2022 the statement U/S-161 Cr.P.C. of informant namely Ranjana Pal was recorded by the investigating officer and in her statements she has. repeated the version of the prosecution story of the first information report. It is further mentioned here that the statement given by the informant name of the applicant/accused not mentioned. The typed copy of statement U/S-161 Cr.P.C. of informant dated 20.11.2022 is being annexed herewith as Annexure No.2 to this affidavit. That the statement of the co-accused namely Ramesh Chandra Pal was recorded by investigating officer U/S-161 Cr.P.C. on 23.11.2022 in which  role of firing has been assigned to  applicant and accused Pankaj mishra. The typed copy of Statement U/S-161 Cr.P.C. of co-accused namely Ramesh Chandra Pal dated 23.11.2022 is being annexed herewith as Annexure No.3 to this affidavit. That the Co-accused Ramesh Chandra Pal statement 161 Cr.P.C recorded by the investigation officer on 23.11.2022 CD No-2, Rapat No-62 at 19:26 clock. That the arrest of the applicant/accused and one other accused on 23.11.2022 at 23:30 clock. Recovery shown of 2 tamancha (katta) 315 bore applicant/accused and one other accused,no independent eye witness present at the time of recovery. That the recovery memo dated 23.11.2022 is being annexed herewith as Annexure No.4 to this affidavit. That the father of the informant was examined by the Dr. Rajendra Kumar Tripathi, M.O. CHC Kunda Pratapgarh, on 19.11.2022 at 1:00 P.M. and in the postmortem report as per X-Ray show 02 Bullet received from body (i) 01 Bullet (Rt.) side mid of (Rt.) ear and (Rt.) upper mandible. (ii) 2nd Bullet from lover end of (Rt.) chest just 10.0cm below to (Rt.) nipple and the cause of death has been mentioned as death due to shock and homerrage due to antimortem fire arm injury. The Photocopy/typed copy of P.M. report dated 19.11.2022 is being annexed herewith as Annexure No.5 to this affidavit. That as per F.I.R the alleged incidence relates to dated 18.11.2022, post mortem was conducted on 19.11.2022, while the first information report has been lodged on 20.11.2022. without any explanation 2 days delay lodging First Information Report. That thus, from the aforesaid facts, it becomes clear that the accused/applicant has been falsely implicated the alleged crime in question based on the botched-up investigation conducted by the investigating officer Stutents of blindly believing the false and fabricated statement of co-accused. That the above mentioned statements of the informant there is no any evidence against the accused/applicant and the accused/applicant in custody on basis of co-accused statement, as has been recorded by the investigating officer and the police have prepared false. Report against the accused/applicant for creating the gravity of the case. That the investigating officer has submitted the charge-sheet against applicant and 2 other accused U/S-302/120-B/506 I.P.C, 3/25 Arms act, and final report has been submitted against rest 6 accused persons, which itself creates whole prosecution story highly doubtful. That there is no material in the first information report to show or even any apprehension that the accused/ applicant would either try to abscond/evade during investigation or influence the witnesses in any manner. That the accused/applicant is,not named in the first information report and on the basis of,statement of co-accused false and fabricated story his name has been developed in the present case. That the applicant is law abiding person and he has movable and immovable property, there is no apprehension of expounding or tampering the witnesses. It is further submitted that there is no any criminal history against the present applicant. That the applicant has falsely implicated in aforesaid case crime and he has no criminal history ever. That the accused/applicant is innocent and without committing any offence he is in jail since 23.11.2022. That there is no possibility of the applicant conviction because he has not committed the crime in question, as alleged by the prosecution. 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 Hon’ble Court. That there are much contradiction between the allegation of the first information report, statement of the informant and other collected material of the evidences. That the accused/applicant has not committed any offence and without committing any offence he is in jail. That the accused/applicant is ready to furnish his bail bonds if bail is granted by this Hon'ble Court. That the accused/applicant will not misuse the liberty of bail if bail is granted by this Hon'ble Court. That the bail application of accused/applicant rejected on 31.05.2023 by the Learned Additional Sessions Judge room No- 6, Pratapgarh in vide Bail Application no. 1385/2022 without application of his judicial mind. The Free certified copy of bail rejection order dated 31.05.2023 is being annexed herewith as Annexure No.6 to this affidavit. That in view of the above noted fact, it is most respectfully prayed that this Hon’ble may kindly be pleased to enlarge the applicant on bail in relation to Case Crime No. 302 of 2022, under Sections 302, 506 of I.P.C. and 3/25 Arms act related to Police Station – Baghrai, District – Pratapgarh, during the pendency of his trial, in the interest of justice.