I, Manoj Kumar Kori aged about 35 years son of Shri Moti Lal Kori resident of Dharu Shahpur, Laxmikant Ganj, Police Station – Sangipur, District – Pratapgarh, Religion – Hindu, Education– Literate, Occupation – Tailor, do hereby solemnly affirm and state on oath as under:- That the deponent is the brother/pariokar of applicant No. 1 and relative of another applicant and duly authorized by the applicants to swear this affidavit on their behalf and as such he is fully conversant with the facts of the case and deposed as under. The ID Proof of the deponent is enclosed and his photograph is affixed to the affidavit. That the deponent further declares that the contents of the affidavit have been explained in Hindi by the counsel of the applicant to him as such he conversant with the facts of the case. That this is the first bail application of the applicant before this Hon'ble Court.  No other bail application is pending before this  or rejected by this . That brief fact of the case is that a first information report has been lodged against the applicants on 21.12.2021 based on false and fabricated grounds, by the informant with regard to her rape bearing Case Crime No. 330 of 2021, under Sections 376D, 452, 354-B, 506 of IPC at Police Station – Sangipur, District – Pratapgarh. The certified/ typed copy of the first information report dated 21.12.2021 is being annexed as Annexure No. 01 to this application. That according to the first information report lodged by one Seema Devi wife of Phool Chandra Kori resident of Village – Dharu Shahpur, Police Station – Sangipur, District – Pratapgarh (hereinafter referred to as ‘informant’), on 22.09.2021 around 18.00 hours, when the informant was at her home alone at that time the applicants entered their house and both have raped her. That the alleged incident which was occurred on 22.09.2021 around 18.00 hours but the first information report has been lodged on 21.12.2021 after about three months, without giving any explanation with regard to the delay caused in lodging the first information report, which is already questionable and doubtful as the informant and her family lodged aforesaid first information after legal advice. That the first information report has been lodged by the informant against the applicants on the wrong and incorrect facts in counterblast to save her husband in retaliation of the first information report lodged against her husband and two others on 05.12.2021 by the daughter-in-law of the applicant No. 1 bearing Case Crime No. 315 of 2021 under Sections 376D, 504, 506, 452 of IPC and 3(i)Da, 3(i)Dha, 3(2)V of S. C. & S. T. Act registered at Police Station – Sangipur, District – Pratapgarh, in which concerned police also submitted the charge sheet No. 26 of 2022 dated 17.02.2022 against the husband of the husband of the informant and others under Sections 376D, 504, 506, 452 of IPC and 3(i)Da, 3(i)Dha, 3(2)V of S. C. & S. T. Act. The photocopy of the first information report dated 05.12.2021 lodged by the daughter-in-law of the applicant No. 1 against the husband of the informant is being annexed herewith as Annexure No. 2 to this affidavit. That after lodging the first information report, the statement of the informant has been recorded on 25.12.2021 under Section 161 of Cr.P.C., in which the informant almost repeated her version of the first information report. The typed copy of the statement of the informant dated 25.12.2021 is being annexed herewith as Annexure No. 03 to this affidavit. That the medical of the informant was conducted on 28.12.2021 at C.H.C. Sangipur, Pratapgarh by the doctor, in which nothing has been found with regard to the rape as alleged by the informant. Here it is also relevant that according to the medical report, the informant has sustained no injuries. The photocopy of the medical report dated 28.12.2021 of the informant is being annexed herewith as Annexure No. 04 to this affidavit. That the medical report of the informant has not collaborated with the allegations as nothing has been found in medical. That on 10.01.2022, the statement of the informant under Section 164 of Cr.P.C. before the concerned Magistrate under the influence of her family. The informant her prosecution story stated that when the applicants have runway after the commission of the crime then immediately she told the entire story to her grandfather-in-law & grandmother-in-law and when her husband returned home after three days then she told her.  The typed copy of the statement of the informant under Section 164 of Cr.P.C. dated 10.01.2022 is being annexed herewith as Annexure No. 05 to this affidavit. That the investigation of the case crime was not done properly and the statement of the informant under Section 164 of Cr.P.C. after 20 days of lodging the first information report, by which the investigation officer has not complied with the provisions of Section 164(5)A of Cr.P.C.. That the statement of the informant under 161 & 164 Cr.P.C. is under having several contradictions as such the above statement has no legal validity. That on a bare perusal of the first information report, the statements of the informant, there are several differences, which create doubt upon the prosecution story. That the aforesaid first information report has lodged by the informant after taking legal advice to falsely implicate the applicants in said case crime for purpose of taking revenge to the applicants, as the first information report lodged against her husband, the applicants are witnesses and also getting money from the state, which will be given to the rape victims. That the real story of the case is in a nutshell that the informant and applicants are residents of the same village. That the husband of the informant and two others have been raped with the daughter-in-law of the applicant No. 1 on 18.09.2021 against them a first information report bearing Case Crime No. 315 of 2021 under Sections 376D, 504, 506, 452 of IPC and 3(i)Da, 3(i)Dha, 3(2)V of S. C. & S. T. Act registered at Police Station – Sangipur, District – Pratapgarh on 05.12.2021. That the informant, when came to know that a first information report would be lodged against her husband and others then all have on basis of legal advice, filed an application under Section 156(3) of Cr.P.C. before the court concerned for the safeguarding of offenders. That in compliance with the order passed by the learned court below, the said first information report against the applicants. That without proper investigation and appreciation of the evidence relating to the allegations made against the applicant No. 1, the investigating officer submitted the charge sheet No. 195 of 2022 under Sections 376D, 452, 354-B, 504, 506 of IPC on 12.08.2022 and against the applicant No. 2 on 23.09.2022 bearing charge sheet No. 195A of 2022. That the whole story was cooked by the informant and her husband along with culprits of the Case Crime No. 315 of 2021, against the applicants and explained by the concerned police. That the informant has no ocular witness and prosecution story as narrated therein highly improbable, improper and unnatural and unbelievable for a prudent man, especially when he herself gives contradictive statements. That the informant never raises any alarm with regard to the incident in any manner, if she was raped by the applicants and the explanation given by the informant regarding not raising of alarm, is not possible in any manner. That the medical report of the informant is also not collaborating with the story of the prosecution, as per the medical of informant nothing has been found. That since the applicants have not committed any offence as alleged but he has been falsely implicated in the case by the informant and her husband in malafide intention. That the false story cooked up by the concerned police and the informant/informant and her husband for obtaining money from the state government, which is given to the rapped informant and taking revenge from the applicants. That there is no evidence against the applicant to connect him with the aforesaid case crime. That the prosecution story as narrated in the first information report is highly improbable, improper and unnatural and unbelievable for a prudent man. That the applicant moved bail application bearing No. 400 of 2023 before Additional Sessions Judge, Room No. 6, Pratapgarh and their bail application has been rejected by the court concerned on 23.02.2023 without considering the fact of the case. The free certified copy of the order dated 23.02.2023 passed by the court concerned is being annexed as Annexure No. 06 to this application. That the applicant No. 1 in jail since 09.08.2022 and applicant No. 2 since 13.09.2022 without committing any offense as alleged against them. That the applicants have no criminal history except the aforesaid false case and are not likely to hope in the future to commit any offence. That there is no chance of the applicants absconding or tempering with the prosecution witnesses. That the applicants are 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 applicants be enlarged on bail in connection with Case Crime No. 330 of 2021, under Sections 376D, 452, 354-B, 504, 506 of IPC at Police Station – Sangipur, District – Pratapgarh, during the pendency of the case, in the interest of justice.


I, Prem Tiwari aged about 37 years son of Shri Ram Sajeevan Tiwari resident of Pure Lautan Tiwari, Katawan, Police Station - Kurwar, District - Sultanpur, Religion – Hindu, Qualification – Lliterate, Occupation – Agriculture, the deponent do hereby solemnly affirm and  state on oath as under :- That the deponent is brother of applicant and doing pairvi of Applicant in the above noted case and duly authorized by him for filing instant application before the Hon'ble Court and as such he is fully conversant with the facts of the case deposed herein under. That the photo verification issued by the Awadh Bar Association, of the deponent is being pasted on the first page of this affidavit and photocopy of ID proof of the deponent is being annexed with this affidavit. That the deponent further declares that the contents of the application as well as this affidavit have been explained in Hindi by the counsel of the applicant as such he is fully conversant with the same. That this is first bail application on behalf of the Applicant before the Hon'ble Court and no other bail application is pending before in any court of law on his behalf. That the facts giving rise to the present case are being stated in brief hereinafter. That the applicant has falsely been implicated in case crime No. 111 of 2023 under Sections 420, 467, 468, 471 of IPC and 63, 72 of U.P. Excise Act, 1910, at Police Station – Aalapur, District – Ambedkar Nagar on 26.03.2023 at 06.16 hours against the applicant and another. The certified/ typed copy of the first information report dated 26.03.2023 is being annexed herewith as Annexure No. 1 to this Affidavit. That according to the First Information Report, which has been lodged by Shri Bechu Singh Yadav, Staton House Officer, Police Station - Aalapur, District – Ambedkar Nagar (hereinafter referred to as ‘informant’),  the prosecution story is in a nutshell that the informant and his team (other police personnel) were on patrolling of the area and at that time the informant got information from his informer (eq[kfcj) in regard of huge adulterated liquor is transporting through tanker No. UP 42 BT 9710. That the raid has been conducted by the informant along with his team on 26.03.2023 and arrested the applicant and another from the spot and also seized a lot of adulterated liquor from inside of the tanker. That the applicant is a common man of society and has no concerns with the adulterated liquor and during the raid the applicant was not present at the place of the alleged incident, the concerned police arrested the applicant from his house without any reason and falsely implicate in said case crime for showing good work of the police. That the real fact is that the applicant are falsely implicated by the informant himself due to their own personal revenge, which has been explained by the concerned police as the ulterior motive. That the informant had personal revenge on the applicant. When the informant was posted as Station House Officer at Police Station - Jaisinghpur, District - Sultanpur, he was randomly checking the papers of the vehicles on the road along with the police team. That the applicant was stopped by a constable and brought to the informant to show his papers. The applicant had all the requisite papers but the informant demanded money from the applicant, which was denied by the applicant. That the informant and his team misbehaved and abused then the applicant strongly opposed, due to which several people gathered and raised their voices against the informant for his illegal demand. That before leaving the place of said incident, the informant had threatened the applicant to face the consequences of said opposition. That the informant had enmity with the applicant and was searching for a chance to falsely implicate the applicant in crime. That when the informant posted at another Police Station i.e. at Police Station - Aalapur then on 26.03.2023, the applicant was in his village, at the time the applicant was arrested by the informant from his house and he has been falsely implicated in the case crime by him due to his self-satisfaction due to old enmity. That it is further relevant to mention that the Tanki test of alleged adulterated liquor has not been conducted by the Excise Officer concerned and even prior to information regarding said liquor, while the Excise Inspector was present at the time of the alleged raid, even the informant and Excise Inspector were themselves not assured that the recovered liquor is adulterated. That on a bare perusal of the first information report, it is also evident that there were no witnesses of the raid conducted by the informant, which also creates doubts upon the story of the informant, which itself concocted and false. That according to the prosecution story, it is clearly revealed that no one saw the occurrence and there are no independent eyewitnesses of the said recovery, it is a case of the forge, fabricated and false and there is no evidence against the applicant. That the applicant has no concerns with the vehicle i.e. UP 42 BT 9710, in which the alleged adulterated liquor was recovered/seized by the informant but it was showing that the in the first information report that the applicant said, the applicant is the owner of the vehicle, who had purchased the said vehicle in the name of another person. That the informant has not arrested the applicant at the alleged place of recovery or even not found anything from the applicant’s possession. That till date there is no chemical report stating therein that the recovered liquor was obnoxious or spurious for human consumption. That on 26.03.2023, a first information report has been lodged by the concerned police due to extraneous consideration; the applicant has been falsely implicated in the case crime. That the applicant is in jail since 26.03.2023 without committing any offense as alleged against them. That nothing has been recovered from the applicant’s possession by the informant and if any recovery is made, the applicant has no concern with recovered adulterated liquor in any manner as such the Sections 420, 467, 468, 471 of IPC and 63, 72 of U.P. Excise Act, 1910 made against him. That the applicant had applied for bail before the Sessions Judge, Ambedkar Nagar bearing Bail Application No. 319 of 2023, which has been rejected by the court concerned without going into the fact and records of the case. The free certified copy of the bail rejection order dated 20.05.2023 passed by the court concerned is annexed herewith as Annexure No. 2 to this affidavit. That the applicant has no criminal history except this false case, lodged by the informant for extraneous reasons. That due to the false implication of the applicant in the case crime, his business has been ruined and his family is coming on the road. That the applicant has not committed any crime as alleged in the first information report by the informant and he has no concerns. That there is no possibility of the applicant’s conviction because he has not committed the crime in question, as alleged by the prosecution. That the applicant is the common man of the society. He has never been convicted in any case and has not been involved in any criminal activities ever. There is no criminal history against the applicant except in this present case. That there is no chance of the applicant’s absconding or tampering with the prosecution witnesses and they are willing to offer bail to the satisfaction of this Hon’ble Court. That the applicant will cooperate with the trial and will not tamper with the prosecution witnesses. That the applicant undertakes that he will not misuse the liberty of bail if so granted by this Hon’ble Court. That the applicant is ready and willing to file adequate surety as the Hon’ble Court may deem fit and proper in the circumstances of the case. That in view of the above, it would be expedient and necessary in the interest of justice that the Applicant be enlarged on bail in connection with Case Crime No. 111 of 2023 under Sections 420, 467, 468, 471 of IPC and 63, 72 of U.P. Excise Act, 1910 registered at Police Station – Aalapur, District – Ambedkar Nagar, in the interest of justice.


I, Narendra Bahadur Singh aged about 45 years son of Shri Anand Bahadur Singh resident of Sarai Khande, Dughvan, Sarai Khande Mu, District - Hardoi, Education – Literate, Occupation – Self-employed, do hereby solemnly affirm and state on oath as under:- That the deponent is the uncle/ pairokar of the applicant and duly authorized by the applicant to file the aforesaid application before this Hon'ble Court and as such he is fully conversant with the facts of the case and deposed as under. The ID Proof of the deponent is enclosed and his photograph is affixed to the affidavit. That the counsel of the applicants has explained the contents of the application as well as this affidavit in Hindi to the deponent and he understands the same in his language. That this is the first bail application before this Hon'ble Court. No any other bail application is pending before this Hon'ble Court or rejected by this Hon'ble Court. That the instant matter is not related to CBI/Prevention of Corruption Act/ Enforcement Directorate /matters relating to NRHM Scam / GPF Scam/matters of MP/MLA etc. That brief fact of the case is that a first information report was lodged against the unknown person on 13.11.2023 at 08.30 hours by Shri Vishram son of Late Kallu, Police Station – Kheron, District - Hardoi resident of Village - Pahadpur hamlet of Ahiri, Police Station - Baghauli, District – Hardoi (hereinafter referred to as ‘informant’) under Section 304 of IPC at Police Station – Baghauli District – Hardoi. The photo/typed copy of the first information report dated 13.11.2023 is being annexed as Annexure No. 01 to this affidavit. That according to the first information report lodged on 13.11.2023 by the informant alleged therein that on 13.11.2023 around 5.00 AM, the grandson of the informant namely Anurag (hereinafter referred to as ‘deceased’), who was the son of the applicant, was crying for going to his grandmother. When the grandson of the informant came out at that time the applicant hit the deceased with a stick. The deceased was brought to the CHC, Ahirori but he died on the way. That on a bare perusal of the first information report, it is clear that there is no reason or intention assigned for committing the murder of the deceased, who was the 7-year-old son of the applicant, which creates doubt about the prosecution story. That the version of the first information report is totally false and baseless and the same is depends upon the concocted story and nothing has been done by the applicant as alleged by the informant in his first informant report. That on 13.11.2023, the inquest report was prepared by the concerned police in the presence of several persons, who repeated the version of the first information report. The photo/typed copy of the inquest report dated 13.11.2023 is being annexed as Annexure No. 02 to this affidavit. That the post-mortem of the deceased was conducted at _____________, in which only injury was shown and the cause of death was ascertained as ‘_____________________’. The photo/typed copy of the post-mortem report dated ……………….. is being annexed as Annexure No. 03 to this affidavit. That the concerned police recovered the murder weapon of the alleged murder on pointing at the applicant on 14.11.2023, after his arrest from his house. The photo/typed copy of the recovery memo dated 14.11.2023 is being annexed as Annexure No. 04 to this affidavit. That the concerned police recorded the statement of the informant under Section 161 of Cr.P.C. on 13.11.2023 in which the informant gave approximately the same statement as mentioned in the first information report. The typed copy of the statement of the informant dated 13.11.2023 is being annexed as Annexure No. 05 to this affidavit. That several statements of the witnesses, who are the grandmother and cousin brother of the deceased have been recorded by the investigating officer on _____________ under Section 161 of Cr.P.C., in which they said they also repeated the statement of the informant in their own words. The typed copies of the statements of the grandmother and cousin brother of the deceased are being annexed as Annexure No. 06 to this affidavit. That thereafter on ___________, the statements of the mother and aunt of the deceased, in which they stated that the mental status of the applicant was not well and became short-tempered and when the deceased was crying, the applicant hit but his intention was not for the murder of the deceased. The typed copies of the statements of the mother and aunt of the deceased are being annexed as Annexure No. 07 to this affidavit. That the real fact of the case is that the applicant has no concern with the alleged incident in any manner. That the applicant was indeed present at his potato field from 11.00 PM of 12.11.2023  for guarding the same against the cattle. That the son of the applicant i.e. deceased was sleeping with his cousin brother Sachin and on the morning of 13.11.2023 around 05.00 AM, suddenly after waking, he ran outside of the house, where he fell and sustained a head injury. That after getting information regarding the accident of his son, he reached his house and went with the deceased for his treatment but unfortunately his son died. That the father of the applicant i.e. the informant went to the concerned police to give information regarding the unfortunate incident. Along with the informant, some villagers, who have enmity with the applicant’s family went with his father and as the informant was an illiterate person, someone wrote the applicant, in which named the applicant for the murder of his 7-year-old son. That the concerned police charge sheet against and the trial has been initiated in which the statements of the P.W. - 1 to 3 have been recorded by the concerned trial court on 22.02.2024, 05.03.2024 and 02.04.2024 respectively, in which they all have told the truth before the court concerned as such they have been declared hostile by the concerned trial court. The photo/typed copy of the statements of the P.W. - 1 to 3 recorded by the trial court are being annexed as Annexure No. 08 to this affidavit. That neither the applicant has any motive nor has any reasonable motive been assigned to him to commit the crime in question. Merely village party bandi, the applicant has been framed in the said case crime. 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 304 of IPC at Police Station – Baghauli, District – Hardoi is made out against the applicant. That the applicant has no motive to commit the alleged crime and a false motive which was given in the case, is cooked and fabricated by the concerned police and enemies of the applicant. That since the applicant has not committed any offense as alleged but he has been falsely implicated in the case by the informant with malafide intention. That the applicant moved bail application bearing Bail Application No. 700 of 2024 before Sessions Judge, Hardoi, and his bail application has been rejected by the court concerned on 27.03.2024 without considering the grounds in his bail application. The free certified copy of the bail rejection order dated 27.03.2024 passed by the court below is being annexed as Annexure No. 09 to this affidavit. That the applicant in jail since 14.11.2023 without the commission of any offense. That the applicant has no any previous criminal history. That there is no chance of the applicant absconding or tempering with the prosecution witnesses. That the applicant is ready to furnish the security and bond and also undertakes that he will never misuse the liberty of bail. That in view of the above, it would be expedient and necessary in the interest of justice that the applicant be enlarged on bail in connection with the Case Crime No. 402 of 2023 under Section 304 of IPC registered at Police Station – Baghauli, District – Hardoi during the pendency of the case.


I, Nirmla Devi aged about 28 years wife of Basant Lal resident of Bhojpur Ashik, Police Station – Sangipur, District – Pratapgarh, Religion – Hindu, Education – Illiterate , Occupation – Housewife, do hereby solemnly affirm and state on oath as under :- That the deponent is the wife of the applicant duly authorized by the applicant to file the aforesaid application before this Hon'ble Court and as such she is fully conversant with the facts of the case and deposed as under. That this is the first bail application before this Hon'ble Court.  No any other bail application pending before this Hon'ble Court or rejected by this Hon'ble Court. That brief facts of the case is that a F.I.R.  has been lodged on 12.07.2013 against the Sarvesh Kumar under section 363/366/376/506 I.P.C. and  Section 9(L) The Protection of Children from Sexual Offences Act, 2012 by the mother of victim namely Nirmla Devi.  A copy of the F.I.R. dated 12.07.2013 is being annexed as Annexure No. 01 to this application. That it is also relevant to mention here that the F.I.R. has been lodged 19 day delays without proper explanation of delay. That the statement of 161 Cr.P.C. of complainant recorded on 12.07.2013 and in her statement the complainant nothing says about the applicant. A copy of the statement of 161 Cr.P.C. of complainant is being annexed as Annexure No. 02 to this application. That after the recording of statement of the complainant police recorded the statement of the victim, who is present at her house. A copy of the statement of 161 Cr.P.C. of victim dated 12.07.2013 is being annexed as Annexure No. 03 to this application. That the victim sends for medical examination by the police to District Women Hospital, Pratapgarh at 04.05 PM on 13.07.2013 and medical report & supplementary medical report submitted. A copy of the medical report & supplementary medical report are being annexed as Annexure No. 04 collectively to this application. That according to the medical report no external & internal injury seen in body of victim and sexual character is well developed. The radiological age of victim 19 nineteen years. That the statement of 164 Cr.P.C. recorded on 19.07.2013 after seven days of statement of 161 Cr.P.C. of victim in meantime the victim residing with her mother and the statement of victim is well thoughtful against the applicant. A copy of the statement of 164 Cr.P.C. of victim is being annexed as Annexure No. 05 to this application. That the complainant and victim have nothing stated against the applicant in her statements under section 161 Cr.P.C.. But victim has stated in her statement 164 Cr.P.C., the applicant was pressurized to give statement in favour of accused Sarvesh and threatened to life if she can’t give statement in favour of accused Sarvesh. That the accused Sarvesh and victim Lalti Pal are in love since long time. The victim is stated in her statement 164 Cr.P.C., accused Sarvesh give a mobile phone to victim for chatting. That the applicant not named in F.I.R. after investigation, the investigation officer submitted charge sheet against the applicant bearing 196A of 2013 under section 212/120B/363/366/376/506 I.P.C. and Section 9(L) The Protection of Children from Sexual Offences Act, 2012,  Police Station – Lalganj, District –Pratapgarh on 12.08.2013. That the arrested on 12.08.2013 and his bail rejected by the Additional Session Judge, Pratapgarh on 31.08.2013. A copy of the order dated 31.08.2013 is being annexed as Annexure No. 06 to this application. That no any involvement in said case and no any evidence against the applicant. That the applicant is Mausa of accused Sarvesh. That the applicant in jail since 12.08.2013  and has no criminal history. That the applicant is innocent and informant falsely implicated in the aforesaid case crime. 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.


I, Jamal aka Jamal Ahmad aged about 46 years son of Girau Shah, resident of Village - Bhagosar (Bhagwatpur), Koyalkhar, Itai, Police Station - Gaura Chauraha, District - Balrampur, Education – Intermediate, Occupation – Agriculture, do hereby solemnly affirm and state on oath as under :- That the deponent is the father/pariokar of the applicant and duly authorized by the applicant to file the aforesaid application before this Hon'ble Court and as such he is fully conversant with the facts of the case and deposed as under. The ID Proof of the deponent is enclosed and a photo affidavit slip issued by the Oudh Bar Association is affixed to the affidavit. That the deponent further declares that the contents of the affidavit have been explained in Hindi by the counsel of the applicant to him as such she conversant with the facts of the case. That this is the first bail application of the applicant before this Hon'ble Court.  No any other bail application is pending before this Hon'ble High Court or rejected by this Hon'ble High Court. That the instant matter is not related to CBI/Prevention of Corruption Act/ Enforcement Directorate /matters relating to NRHM Scam / GPF Scam/matters of MP/MLA etc. That brief facts of the case are that a first information report was lodged against the applicant on 21.04.2024 by opposite party No. 2 bearing Case Crime No. 58 of 2024 under Sections 363 of I.P.C. at Police Station – Gaura Chauraha, District – Balrampur.  The certified copy of the first information report dated 21.04.2024 is being annexed herewith as Annexure No. 01 to this affidavit. That according to the first information report the opposite party No. 2 stated in her first information report that on 20.04.2022, the applicant allured her minor daughter (hereinafter referred to as ‘victim’) and took her away anywhere and she tried her best to find the victim but not find. That on the very same day i.e. on 21.04.2024, the statement of the victim was recorded by the concerned police under Section 161 of Cr.P.C., in which she stated that the applicant had given his mobile number and given a life threat to call him. On 20.04.2024, the applicant forcefully brought her and after committing rape, a runaway from the place of incident. The typed copy of the statement of the victim under Section 161 of Cr.P.C. dated 21.04.2024 is being annexed herewith as Annexure No. 02 to this affidavit. That on 22.04.2024, the statement of the opposite party No. 2 under Section 161 Cr.P.C. was recorded by the concerned police, in which she changed the version of the first information report and also tried to develop his prosecution story. The typed copy of the statement of the opposite party No. 2 under Section 161 Cr.P.C. dated 22.04.2024 is being annexed herewith as Annexure No. 03 to this affidavit. That the medical of the victim was conducted on 22.04.2024 at District Women Hospital, Balrampur by the doctor concerned, in which nothing has been found with regard to the allegations of the opposite party No. 2 and the victim also. Even though, the victim herself stated during her medical that she went with the applicant with her own WILL and had a sexual relationship with her WILL.  The photo/ typed copy of the medical report dated 22.04.2024 of the victim is being annexed herewith collectively as Annexure No. 04 to this affidavit. That the investigating officer added Section 376 (3) of I.P.C., (2)V of The Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act, 1989, and 3/4  of The Protection of Children from Sexual Offences Act, 2012, in the aforesaid case crime on 22.04.2024. That the statement of the victim under Section 164 Cr.P.C. was recorded before the concerned court on 24.04.2024, in which the victim almost repeated her statement under Section 161 of Cr.P.C. and also tried her best to falsely implicate the applicant in said case for extraneous reasons. The typed copy of the statement of the victim under Section 164 of Cr.P.C. dated 24.04.2024 is being annexed herewith as Annexure No. 05 to this affidavit. That the real story of the case is that the applicant is the common man of the society and has not committed any offense as alleged against him. That the victim and applicant have fallen in love since long back and they met regularly with each other. When this fact came to the knowledge of the victim and her family then they came to the applicant’s house and restrained the applicant and victim to continue their love relationship. That the victim stated that she is more than 18 years hence the applicant and victim decided to solemnize their marriage with their own WILL as both are major in age. That on 20.04.2024, the opposite party No. 2 scolded her daughter i.e. the victim thereafter the victim called the applicant to meet. That the applicant met with the victim on 20.04.2024 at the alleged place of the incident, where they were physically active. That the opposite party No. 2 is well aware that her daughter i.e. victim is major in age but he has lodged the first information report saying therein that the victim is a minor. That there is no genuine ground found by the concerned police against the applicant and for extraneous reasons, the charge sheet has been filed against the applicant in said case crime. That the prosecution story as narrated therein is highly improbable, improper unnatural, and unbelievable for a prudent man. The victim herself admitted that the applicant did not rape her and she went with the applicant with her own free WILL. That without proper investigation of the case, the investigating officer submitted the charge sheet under Sections 363, 376 (3) of I.P.C., 3/4 of The Protection of Children from Sexual Offences Act, 2012, and 3(2)V of The Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act, 1989 on 04.05.2024 against the applicant. The photocopy of the charge sheet dated 04.05.2024 submitted by the concerned police is being annexed herewith as Annexure No. 06 to this affidavit. That there is no evidence against the applicant to connect him with the aforesaid case crime. That since the applicant has not committed any offense as alleged but he has been falsely implicated in the case by the opposite party No. 2 and their family members with malafide intentions. That in the present case there is sufficient evidence on record to show that the applicant did not commit the offence. That the applicant moved bail application bearing No. 880 of 2024 before Sessions Judge, Balrampur, and his bail application was rejected by the Special Judge (Protection of Children from Sexual Offences Act, 2012) Act, Balrampur on 16.07.2024. The free certified copy of the order dated 16.07.2024 passed by the learned court concerned is being annexed herewith as Annexure No. 07 to this affidavit. That the applicant has been languishing in jail since 25.04.2024 without committing any offense as alleged against the applicant. That the applicant has no criminal history except the aforesaid false case and is not likely to hope in the future to commit any offence. That there is no chance of the applicant absconding or tempering with the prosecution witnesses. That the applicant is ready to furnish the security and bond and also 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 connection with Case Crime No. 58 of 2024 under Sections 363, 376 (3) of I.P.C., 3/4 of The Protection of Children from Sexual Offences Act, 2012 and 3(2)V of The Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act, 1989 registered at Police Station – Gaura Chauraha, District – Balrampur, in the interest of justice.


I, Shyam Bahadur Singh aged about 56 years son of Shri Ram Kewal Singh resident of Village - Madhuban, Post - Bansgaon, Police Station - Akbarpur, District – Ambedkar Nagar, Religion – Hindu, Education – Literate, Occupation – Agriculture, do hereby solemnly affirm and state on oath as under:- That the deponent is the uncle/pairokar of the applicant and duly authorized by the applicant to file the aforesaid application before this Hon'ble Court and as such he is fully conversant with the facts of the case and deposed as under. The photo verification slip issued by the Awadh Bar Association, Lucknow of the deponent is affixed on the affidavit and his ID proof is enclosed with the affidavit. That the deponent further declared that the contents of the bail application have been explained by the counsel of the applicant in Hindi and as such he is fully conversant with the facts of the case deposed as under. That this is the first bail application before this Hon'ble Court. No any other bail application is pending before this Hon'ble Court or rejected by this Hon'ble Court. That brief fact of the case is that a first information report was lodged against unknown persons on 27.10.2023 at 23.30 hours by Sushant Pandey son of Shri Dilip Pandey resident of Village - Mahuval, Post-Tandwa Maulai, Police Station - Jalalpur, District - Ambedkar Nagar, (hereinafter referred to as ‘informant’) under Sections 302, 211 of I.P.C. at Police Station – Akbarpur, District – Ambedkar Nagar regarding incident dated 20.10.2023. The certified typed copy of the first information report dated 27.10.2023 is being annexed as Annexure No. 01 to this affidavit. That according to the first information report lodged on 27.10.2023 by the informant, on 20.10.2023 the informant found his uncle namely Hemant Pandey (hereinafter referred to as ‘deceased’) dead and his post-mortem was conducted. He also stated that he had doubts that his uncle had been murdered by unknown persons. That the alleged incident which was taken place on 20.10.2023 but the first information report was lodged on 27.10.2023, without giving any explanation with regard to the 7-day delay caused in lodging the first information report, which is already questionable and doubtful as the informant lodged aforesaid first information after legal advice. That the inquest report of the deceased body was prepared by the concerned police on 21.10.2023 in the presence of several villagers including the informant and his father. That the body of the deceased was brought for conducting a post-mortem on 21.10.2023, where the post-mortem was conducted and the cause of the death was ascertained as ‘Asphyxia & shock due to antemortem strangulation & injury”. The photo/ typed copy of the post-mortem report dated 21.10.2023 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 his first informant report. Here it is relevant to mention that the applicant was not named in the first information report. That the investigating officer recorded the statement of the informant under Section 161 of Cr.P.C. on 30.10.2023 in which the informant almost repeated her first information report. The typed copy of the statement of the informant dated 30.10.2023 is being annexed as Annexure No. 03 to this affidavit. That first-ever, the police informer named the applicant on 17.11.2023 and stated that on 19.10.2023, the applicant, the deceased and another drank together and after a dispute, the applicant and another murdered the deceased. The typed copy of the endorsement made in CD-15 dated 17.11.2023  is being annexed as Annexure No. 04 to this affidavit. That the investigating officer has no any concrete evidences and merely on the statement of his informer, obtained the CDR of the applicant and related that the applicant had murdered the deceased. That later on, the applicant was arrested by the concerned police on 19.11.2023 from his home but for showing his good work, his arrest was shown in a forged and fabricated arresting memo dated 19.11.2023. Another accused was also arrested by the concerned police on the same day. That thereafter, the confessional statements of the co-accused and applicant have been written/ prepared by the Investigating Officer on 19.11.2023 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 applicant whereas the applicant has not committed any offense. The typed copy of the confessional statement of the applicant and co-accused dated 19.11.2023 is being annexed as Annexure No. 05 to this affidavit. That the confessional statements of the other accused were recorded by the concerned police on 19.11.2023 under the life threat, in which he stated that the murder of the deceased was planned by all the accused as the named accused fought with the deceased on 13.10.2023. However, the applicant was reached at the time of the commission of the alleged offense. That the confessional statements of the arrested co-accused and applicant were recorded by the concerned police on 19.11.2023 under the life threat, in which the applicant said everything as narrated by the concerned police. That it is most humbly submitted that the applicant is innocent and he has falsely been implicated by the 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 investigating officer further prepared a false recovery memo on 19.11.2023 by which recovered the murder weapon and a broken mobile phone on pointing of the applicant and another accused. The photo/typed copy of the recovery memo dated 19.11.2023 is being annexed as Annexure No. 06 to this affidavit. That on the basis of such a story, which was narrated by the investigating officer himself, without proper investigation of the case crime, submitted the charge sheet against the applicant and another accused bearing charge sheet No. 521 of 2023 on 3.11.2023. That the real story is that the applicant has no concern with the alleged offense and he has been falsely implicated by the informant due to false and incorrect facts merely on presumption. That it is true that the deceased and applicant were known to each other and on several occasions they have drunk together. That the deceased was not a good person, even though after taking liquor, he started misbehaving & abusing to anyone and also had criminal records due to which he had several enemies, who wanted to kill her, it was admitted by the deceased himself, when he was last time met with the applicant. That on 19.10.2023, the deceased was fully drunk and as per his nature, in the drunken stage, the deceased fought someone and was murdered by anonymous persons but due to an old relation with the deceased, he has been falsely implicated in the said case crime. That the applicant has no concern with the murder of the deceased in any manner as alleged by the concerned police and the allegation against the applicant and also the prosecution story is totally against truth and is not reliable in manner. That neither the applicant has a motive nor has any reasonable motive been assigned to 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 Sections 302, 211 of I.P.C. at Police Station – Akbarpur, District – Ambedkar Nagar is made out against the applicant. That the applicant is in jail since 19.11.2023 without committing any offense. That apart from the abovementioned case, as per the best knowledge of the applicant, he has no criminal history. That the deceased was himself a criminal and had several enemies, however, as per the best knowledge of the applicant, against the deceased below mentioned cases were lodged:- Case Crime No. 355 of 2020 lodged under Sections 302, 201 of I.P.C. and 3(2)(V) of S. C. & S. T. (Prevention of Atrocities) Act, 1989 (Amendment, 2005) registered at Police Station - Baskhari, District - Ambedkar Nagar, in which the charge sheet No. 316 of 2020 filed against the deceased and others on 13.12.2020. Case Crime No. 148 of 2023 lodged under Sections 3/25 Arms Act registered at Police Station - Jalalpur, District - Ambedkar Nagar. The photocopies of the first information report and charge sheet in which the deceased the named are being annexed as Annexure No. 07 to this affidavit. That the applicant moved bail application No. 3631 of 2024 before the learned Sessions Judge, Ambedkar Nagar and his bail application was rejected by the court concerned on 02.02.2024. The free certified copy of the bail rejection order dated 02.02.2024 passed by the court below is being annexed as Annexure No. 08 to this affidavit. 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 be never misuse the liberty of bail. That in view of the above, it would be expedient and necessary in the interest of justice that the applicant be enlarged on bail in connection with Case Crime No. 608 of 2023 under Sections 302, 211 of I.P.C. registered at Police Station – Akbarpur, District – Ambedkar Nagar, in the interest of justice.


I, Shankar Lal Sah aged about 60 years son of Shri Jeeta Sah resident of Ward No. 15, Subhash Nagar, Kasba, Purnia, Kasba, Bihar, Education – Post Graduate, Occupation – Private Job, 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 photo verification slip issued by the Awadh Bar Association, Lucknow of the deponent is affixed on the affidavit and his ID proof is enclosed with the affidavit. That the deponent further declared that the contents of the bail application have been explained by the counsel of the applicant in Hindi and as such he is fully conversant with the facts of the case deposed as under. That this is the first bail application before this Hon'ble Court. No any other bail application is pending before this Hon'ble Court or rejected by this Hon'ble Court. That brief fact of the case is that a first information report was lodged against the applicant on 01.01.2024 at 23.20 hours by Piyush Sharma, Office Assistant, Prathama U.P. Gramin Bank, Branch - Itairampur, Gaindas Bujurg, Balrampur (hereinafter referred to as ‘informant’) under Section 409 of I.P.C. at Police Station – Gaindas Bujurg, District – Balrampur regarding incident dated 30.12.2023. The certified typed copy of the first information report dated 01.01.2024 is being annexed as Annexure No. 01 to this affidavit. That the informant stated in his first information report that being the Branch Manager of the Bank, the applicant did not come to the bank on 01.01.2024 without prior information. The mobile of the applicant was switched off and his house was also locked. The informant informed the regional office that on 30.12.2023, there was a delay in closing the cash due to the solar of the branch going off. After matching the cash and getting the Cash Balance Book signed, the applicant took the second key of the cash himself and asked the informant to leave saying that a recovery has to come in a loan account and said he will close the cash. On 01.01.2024, in front of the staff of the Regional Office, the cash was opened with the duplicate keys received from another branch and when the cash was counted, it was found that there was Rs. 18,47,500/- and the informant alleged that the said amount has been taken by the applicant. That the alleged incident which was taken place on 30.12.2023 but the first information report was lodged on 01.01.2024, without giving any explanation with regard to the 2 days delay caused in lodging the first information report, which is already questionable and doubtful as the informant lodged aforesaid first information after legal advice. That here it is relevant to mention that the allegations levelled against the applicant are false and incorrect as the applicant has not been involved in an offense alleged by the informant. That the informant lodged the first information report on the basis of a false and incorrect fact and the same depends upon the concocted story as such nothing happened as alleged by her in his first informant report. That the Investigating Officer recorded the statement of the informant under Section 161  Cr.P.C. on 03.01.2024 in which the informant repeated his first information report version. However, the applicant has not committed any offense as stated by him. The typed copy of the statement of the informant dated 03.01.2024 is being annexed herewith as Annexure No. 02 to this affidavit. That the Investigating Officer recorded the further statement of the informant under Section 161  Cr.P.C. on 08.01.2024 in which the informant repeated his first information report version with improved facts to build his case against the applicant while the applicant has not committed any offense as stated in the first information report. The typed copy of the further statement of the informant dated 08.01.2024 is being annexed herewith as Annexure No. 03 to this affidavit. That the applicant was arrested on 10.01.2024 by the concerned police and the confessional statement of the applicant was written/ prepared by the Investigating Officer on 11.01.2024 as per his wish and as narrated by the bank officials, by which he tried his best to collaborate with the alleged incident and witnesses under section 161 Cr.P.C. only to prove the offense against the applicant whereas the applicant has not committed any offense. The typed copy of the confessional statement of the applicant dated 11.01.2024 is being annexed as Annexure No. 04 to this affidavit. That it is most humbly submitted that the applicant is innocent and she has falsely been implicated by the informant in the instant case and there is no evidentiary value in the eye of the law relating to the confessional statement given by the applicant. That on 12.01.2024, the further statement of the applicant was recorded by the concerned police, and in furtherance of the same, a forged and fabricated recovery memo was prepared on 18.01.2024 by which the several keys of the bank were recovered by the concerned police. The photocopy of the further statement of the applicant dated 12.01.2024 and the recovery memo dated 18.01.2024 are being annexed as Annexure No. 05 to this affidavit. That the statement of the Guard namely Luddur Prasad, who was on duty on 30.12.2023 was recorded by the concerned police under Section 161 of Cr.P.C. on 26.02.2024, in which he stated that the bank was not opened on the night of 30.12.2023. The typed copy of the statement of the guard on duty dated 26.02.2024 is being annexed as Annexure No. 06 to this affidavit. That the Investigating Officer again recorded the second further statement of the informant on 13.03.2024, in which the informant again tried to improve his prosecution story and tried to fill the loopholes of allegations. However, when the Investigation Officer asked the questions from the informant, he gave doubtful answers to him. The typed copy of the second further statement of the informant dated 13.03.2024 is being annexed as Annexure No. 07 to this affidavit. That the Investigating Officer also recorded the second further statement of the applicant on 13.03.2024, in which he asked certain questions, which were replied by the applicant and nothing was found by the Investigating Officer against the applicant. The typed copy of the second further statement of the applicant dated 13.03.2024 is being annexed as Annexure No. 08 to this affidavit. That it is most humbly submitted that the applicant is innocent and he has falsely been implicated by the informant in the instant case and there is no evidentiary value in the eye of the law relating to the confessional statements given by the arrested accused. That so far allegations regarding the taking of the key of the locker from the informant, it is relevant to mention that as per GAD Circular 02/2020 dated 15.01.2020, a written record of the bank keys is to be maintained and in the bank records, there is no record that the petitioner kept the key from the informant. The photocopy of the GAD Circular dated 15.01.2020 of the concerned bank is being annexed as Annexure No. 09 to this affidavit. That it was also mentioned in the confessional statement of the applicant, that he has taken money several times from the bank, if it was true then the money was always found less on counting of the same. That here it is also relevant to mention that when the applicant being the Manager of the bank already had a key, then there is no need to take another key from the informant or other person. That in the statement of the applicant, it has been also written by the Investigating Officer that the applicant stole money for the marriage of his sister while the marriage of the applicant’s sister was solemnized on 06.06.2014. The photocopy of the marriage card of the applicant’s sister's marriage is being annexed herewith as Annexure No. 10 to this affidavit. That here it is also relevant to mention that nothing was recovered from the possession of the applicant and also the applicant has not taken any loan, which is pending for repayment as mentioned in the statement. That on the basis of such a story, which was narrated by the investigating officer himself, without proper investigation of the case crime, submitted the charge sheet against the applicant bearing charge sheet on 06.04.2024. That the real story is that the applicant has no concern with the alleged offense and he has been falsely implicated by the informant due to false and incorrect facts merely on presumption. That the applicant has been falsely implicated in the case crime by the informant due to office politics as he was very strict with the employees with regard to their work performance. That the wife of the applicant left him due to which he was in deep mental trauma as such he was absent from bank duty without any prior information and due to which the applicant has been falsely implicated in the said case crime while he has not committed any offense as alleged against him. That the applicant has no concern with the stolen money in any manner as alleged by the informant as well as concerned police and the allegation against the applicant and also the prosecution story is totally against truth and is not reliable in manner. That neither the applicant has a motive nor has any reasonable motive been assigned to 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 409 of I.P.C. at Police Station – Gaindas Bujurg, District – Balrampur is made out against the applicant. That the applicant has been in jail since 11.01.2024 without committing any offense. That apart from the abovementioned case, as per the best knowledge of the applicant, he has no criminal history. That the applicant moved bail application No. 3631 of 2024 before the learned Sessions Judge, Balrampur, and his bail application was rejected by the court concerned on 03.02.2024. The free certified copy of the bail rejection order dated 03.02.2024 passed by the court below is being annexed as Annexure No. 11 to this affidavit. 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 be never misuse the liberty of bail. That in view of the above, it would be expedient and necessary in the interest of justice that the applicant be enlarged on bail in connection with Case Crime No. 01 of 2024 under Section 409 of I.P.C. registered at Police Station – Gaindas Bujurg, District – Balrampur, in the interest of justice.


I, Ram Bahadur Tripathi aged about 52 years son of Shri Ram Bujhawan resident of Village – Beerpur, Mathura, District - Balrampur, Religion – Hindu, Education – Literate, Occupation – ___________, do hereby solemnly affirm and state on oath as under:- That the deponent is the friend/ pairokar of the applicant and duly authorized by the applicant to file the aforesaid application before this Hon'ble Court and as such he is fully conversant with the facts of the case and deposed as under. The ID Proof of the deponent is enclosed and his photograph is affixed to the affidavit. That this is the first bail application before this Hon'ble Court. No any other bail application is pending before this Hon'ble Court or rejected by this Hon'ble Court. That the instant matter is not related to CBI/Prevention of Corruption Act/ Enforcement Directorate /matters relating to NRHM Scam / GPF Scam/matters of MP/MLA etc. That brief facts of the case are that a first information report was lodged against the unknown persons on 21.09.2022 at 15.10 hours by Smt. Rekha Devi, Principal, Balrampur Balika Inter College, Balrampur (hereinafter referred to as ‘informant’) bearing Case Crime No. 266 of 2022 under Sections 419, 420, 467, 468, 471 of I.P.C. at Police Station – Kotwali Nagar, District – Balrampur. The certified copy of the first information report dated 21.09.2022 is being annexed herewith as Annexure No. 01 to this affidavit. That the first information report lodged by the informant against the applicant on 21.09.2022 on baseless and incorrect facts and grounds stating therein that the applicant applied for the vacant post of assistant teacher (Urdu) and she was selected on the said post and in pursuant to the appointment order dated 22.11.2021, joined on a very same day. The authority concerned received a verification report dated 11.07.2022 for B.Ed. certificate of the applicant from Didho Kanho Birsa University, Purulia, West Bengal, it was stated therein that the certificate of the applicant was fake and thereafter the first information report was lodged against the applicant That here it is relevant to mention that the allegations levelled against the applicant are false and incorrect as the applicant has not been involved in an offense alleged by the informant. That the informant lodged the first information report on the basis of a false and incorrect fact and the same depends upon the concocted story as such nothing happened as alleged by her in her first informant report. That the investigating officer recorded the statement of the informant under Section 161  Cr.P.C. on 30.10.2022 in which the informant repeated her first information report version. However, the applicant has not committed any offense as stated by her. The typed copy of the statement of the informant dated 30.10.2022 is being annexed herewith as Annexure No. 01 to this affidavit. That it is most humbly submitted that the applicant is innocent and he has been implicated in the instant case by the informant herself due to conspiracy of the office polictic. That the real story is that the applicant’s father died in the year 1991 and anyhow she completed her education by doing work and she is a good schooler. The photocopies of the educational documents of the applicant are being annexed herewith as Annexure No. 01 to this affidavit. That the applicant pursued her B.Ed. from Didho Kanho Birsa University, Purulia, West Bengal and passed in the year 2015 and presently after getting permission from the authority concerned she is pursuing her Ph.D. in Sociology. That the Uttar Pradesh Secondary Education Service Selection Board, Prayagraj issued an advertisement for the appointment of Assistant Teachers and the online application process started on 16.03.2021. That according to the said advertisement, the requisite qualification for the post of assistant teacher (Urdu) was B.A. (Urdu) & L.T. or B.T. or B.Ed. or another equivalent or degree or diploma. That the applicant has the requisite qualifications for the post hence she applied and after examination, the applicant was declared selected. That the District Inspector of Schools, Balrampur vide its order dated 11.11.2021 directed the Manager, Balrampur Balika Inter College, Balrampur to issue the appointment letter to the applicant. The photocopy of the order dated 11.11.2021 passed by the District Inspector of Schools, Balrampur is being annexed herewith as Annexure No. 01 to this affidavit. That thereafter, the Authorized Controller, Balrampur Balika Inter College, Balrampur issued an appointment letter to the applicant on 22.11.2021 and in pursuant to the same, the applicant joined on the very same day in the school on the post of assistant teacher (Urdu). The photocopy of the appointment letter dated 22.11.2021 and joining letter are being annexed herewith as Annexure No. 01 to this affidavit. That the applicant was initially appointed to the post in question on probation for one year. That after her appointment, the applicant has been continuing in service since then without any complaint to the full satisfaction of the higher authorities. The work and conduct of the applicant have always been found to be satisfactory by the superior officer of the department without any complaint from any corner. That thereafter as per standard procedure, the educational documents of the applicant were sent to the concerned Universities for verification and on 11.07.2022, the Principal, Balrampur Balika Inter College, Balrampur received a verification report from Didho Kanho Birsa University, Purulia, West Bengal, in which it has been stated the applicant’s certificate is fake. The photocopy of the verification report dated 11.07.2022 is being annexed herewith as Annexure No. 01 to this affidavit. That later on, vide letter dated 22.08.2022, the Didho Kanho Birsa University, Purulia, West Bengal sent another verification dated 22.08.2022 stating therein that the verification report dated 11.07.2022 has not been issued by the University and the certificate of the applicant is found correct. The photocopy of the verification report dated 22.08.2022 is being annexed herewith as Annexure No. 01 to this affidavit. That after another communication with the Didho Kanho Birsa University, Purulia, West Bengal, the District Inspector of Schools, Balrampur was informed that the verification report dated 22.08.2022 is also fake and fabricated. That the applicant applied for her B.Ed. from Didho Kanho Birsa University, Purulia, West Bengal through one Amar Kumar Singh along with several students. That after completing the same, the applicant has annexed the same at the time of selection to the post in question however, the appointment of the applicant was not based on her B.Ed. certificate, she was appointed to the post on the basis of Net (U.G.C.) and Urdu Graduation. That the applicant is herself a victim as the middleman of the Didho Kanho Birsa University, Purulia, West Bengal cheated the applicant and now the applicant has come to know that the college, from where the applicant completed her B.Ed. took excess admission as such for grabbing the fee of the lot of students, supplied the forged documents. That the applicant has no concern with the fabrication of the forged document and also she has not used the same with malafide intention to get an appointment to the post in question as such Sections 419, 420, 467, 468, 471 of I.P.C. are not applicable upon her. 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 Sections 419, 420, 467, 468, 471 of I.P.C. at Police Station – Kotwali Nagar, District – Balrampur is made out against the applicant. That without proper investigation of the case crime, even after knowing everything with regard to the incident, the Investigating Officer submitted a charge sheet against the applicant on 17.09.2023, in a very illegal manner. That the applicant moved bail application No. 1262 of 2023 before the learned Sessions Judge, Balrampur and his bail application has been rejected by the court concerned on 26.10.2023. The free certified copy of the bail rejection order dated 26.10.2023 passed by the court below is being annexed herewith as Annexure No. 01 to this affidavit. That the applicant has been in jail since 00.00.0000 without committing any offense. That apart from the present case crime, no any 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. 266 of 2022 under Sections 419, 420, 467, 468, 471 of I.P.C. relating to the Police Station – Kotwali Nagar, District – Balrampur, in the interest of justice.


I, Laukush Yadav aged about 27 years son of Shri Ram Naresh resident of Village – Madhwa Nagar Khdar, Kuti Ramtalaha, Police Station - Pachpedawa, District - Balrampur, Religion – Hindu, Education – Literate, Occupation – ___________, do hereby solemnly affirm and state on oath as under:- That the deponent is the husband/ pairokar of the applicant and duly authorized by the applicant to file the aforesaid application before this Hon'ble Court and as such he is fully conversant with the facts of the case and deposed as under. The ID Proof of the deponent is enclosed and his photograph is affixed to the affidavit. That this is the first bail application before this Hon'ble Court. No any other bail application is pending before this Hon'ble Court or rejected by this Hon'ble Court. That the instant matter is not related to CBI/Prevention of Corruption Act/ Enforcement Directorate /matters relating to NRHM Scam / GPF Scam/matters of MP/MLA etc. That brief facts of the case are that a first information report was lodged against the unknown persons on 13.09.2023 at 16.30 hours by the informant/deponent bearing Case Crime No. 328 of 2023 under Section 302 of I.P.C. at Police Station – Pachpedawa, District – Balrampur. The certified/ typed copy of the first information report dated 13.09.2023 is being annexed as Annexure No. 01 to this affidavit. That according to the first information report lodged on 13.09.2023 at 9 a.m., the deponent/informant's wife i.e. the applicant fought with him and went with both daughters near Dhadhia Nala on the north side of the village. On getting information, the deponent/informant reached Dhadhia Nala to convince him and was going back home with his elder daughter Roshni. The applicant in the same anger, threw younger daughter Ragini aged about 8 months, into Dhadhia Nala. After a lot of searching in the drain by the informant and other people of the village, Ragine was found lying dead in the drain. That the body of the deceased was brought to the P. M., Balrampur for conducting the post-mortem on 14.09.2023, where the post-mortem was conducted and the cause of the death was ascertained as ‘Antimortem drowing”. The photo/ typed copy of the post-mortem report dated 14.09.2023 is being annexed as Annexure No. 02 to this affidavit. That the deponent/informant lodged the first information report in the heat of the moment, which is totally false and baseless and the same depends upon the concocted story as such nothing happened as alleged by him in his first informant report. That the investigating officer recorded the statement of the informant under Section 161  Cr.P.C. on 13.09.2023 in which the deponent/informant repeated his first information report version. Here it is relevant to mention that the deponent/informant gave his statement when he was angry with the applicant and was not able to think in right manner. The typed copy of the statement of the informant dated 13.09.2023 is being annexed as Annexure No. 03 to this affidavit. That a forged and fabricated arresting-cum-recovery memo was prepared by the concerned police on 15.09.2023 and showed that the applicant was arrested by them from far away from home, while the applicant was brought by the concerned police from the house of the deponent/informant for questioning and later on showed her arrest. The typed copy of the arresting/recovery memo dated 15.09.2023 is being annexed as Annexure No. 04 to this affidavit. That it is most humbly submitted that the applicant is innocent and he has been implicated in the instant case by the deponent/informant himself due to conspiracy of the village party bandi. That it is also unbelievable a mother would throw her 8-month-old daughter into the canal willfully. That the real story is that there was some conflict among the women at home of the deponent’s family i.e. applicant and her in-laws. The applicant has 8 months baby and has to do all household work and no one used to take the child. That on 13.09.2023, the applicant took her child alone to defecate and started defecating by sitting the child. Meanwhile, she slipped and went into the canal. That the applicant does not know how to swim, yet she tries to save the child by entering the water. On the alarm of the applicant, the people of the village also entered the canal and searched and found the body of the girl. The child died due to drowning. That thereafter the Village Pradhan, who had enmity with the deponent/informant stated to him that his signature was required for the post-mortem of his daughter. That the applicant signed the blank paper and an application for lodging the first information report was moved by the Village Pradhan due to political enmity. That here it is relevant to mention that if the applicant’s child was thrown away by her, she would have sustained injuries in the canal, but there was no injury to the child. That the applicant has no concern with the death of her daughter in any manner and her daughter slipped in the canal. 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 304 of I.P.C. at Police Station – Pachpedawa, District – Balrampur is made out against the applicant. That without proper investigation of the case crime, even after knowing everything with regard to the incident, the Investigating Officer submitted a charge sheet against the applicant on 24.09.2023, in a very illegal manner. That the applicant moved bail application No. 1186of 2023 before the learned Sessions Judge, Balrampur and his bail application has been rejected by the court concerned on 10.10.2023. The free certified copy of the bail rejection order dated 10.10.2023 passed by court below is being annexed as Annexure No. 05 to this application. That the applicant has been in jail since 15.09.2023 without committing any offense. That apart from the present case crime, no any 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. 328 of 2023 under Section 304 of I.P.C. relating to the Police Station – Pachpedawa, District – Balrampur, in the interest of justice.


I, Badam Singh aged about 53 years, Son of Shri Kamta Prasad, resident of Village School Ke Paas, Rajgarh, 33Bn PAC, District - Jhansi, the deponent do hereby solemnly affirm and state on oath as under:- That the deponent is himself the applicant/accused in the above-referred complaint case and as such is well conversant with the facts and circumstances of the case deposed hereunder. That this is the first Bail Application of the applicant in the above-referred criminal case, before this Hon'ble Court. The applicant has not preferred any other Bail Application with regard to the aforesaid criminal Case before this Hon'ble Court or any Higher Court of Law. That the complainant moved a complaint regarding the dishonor of check No. 618158 of Sarva U.P. Gramin Bank, Branch - Jhansi, District - Jhansi amounting to Rs. 1,47,613/-, which was allegedly given to him by the applicant, which has been registered as complaint No. 7736 of 2022. That the brief of the case is that the son of the applicant took a vehicle loan from the complainant amounting to Rs. 1,25,000/- in which the applicant was a guarantor and signed an agreement with the complainant on 26.04.2019. According to the agreement the loan will be repaid through 32 Equated Monthly Installments along with other charges. That the applicant was given a blank and undated cheque No. 618158 against the said loan at the time of processing of the loan as demanded by the complainant, which was as surety of the vehicle loan taken by the applicant’s son. That later on, after failing to pay EMIs by the son of the applicant to the complainant. Therefore the complainant mentioned Rs. 1,47,613/-  in the said cheque, and the same was presented to the bank by complainant without any information to the applicant. That the applicant is willing to ready pay the rest amount of the loan, as the applicant has liability for said amount only. That as a matter of fact the complaint of the complainant is based upon misconceived, baseless, and false facts. That the applicant is a respectable member of the society and is ready to furnish adequate and reliable sureties for his release on bail. That the allegation against the applicant is under Section 138 of NI Act, which is bailable offences. That the allegations against the applicant are not of heinous nature and he is not a previous convict. That the informant has further leveled totally absurd allegations against the applicant/accused in the above-referred case on the basis of wrong impression and presumption, which is totally unbelievable. That in view of what has been stated above, it becomes clear that the applicant is entitled to be enlarged on bail. Place:	Lucknow		 		                                      Deponent


I, Fatima Bano aged about 25 years daughter of Mohd. Muslim resident of House No. 103, Purani Divani, Dahilamau, District – Pratapgarh , Religion – Muslim, Education – Literate, Occupation – Studding, do hereby solemnly affirm and state on oath as under :- That the deponent is the daughter of the applicant and duly authorized by the applicant to file the aforesaid application before this Hon'ble Court and as such she is fully conversant with the facts of the case and deposed as under. The ID Proof of the deponent is enclosed and her photograph is affixed on the affidavit. That this is the first bail application before this . No any other bail application pending before this Hon'ble Court or rejected by this Hon'ble Court. That brief facts of the case is that a first information report has been lodged against the unknown persons on 30.10.2015 at 01:30 PM by the informant namely Smt. Kanchan Shukla under section 302 I.P.C. at Police Station – Kotwali Nagar, District – Pratapgarh as the husband of the informant namely Indramani Shukal (hereinafter referred to as deceased) has murdered by unknown persons on 29.10.2015 about 08.00 PM.  The photocopy of the first information report dated 30.10.2015 is being annexed as Annexure No. 01 to this application. That as per first information report, the alleged incident took place on 29.10.2015 about 08:00 P.M. and the first information report was lodged next day i.e. 30.10.2015 about 01:30 PM i.e. after 17:30 hours of the alleged incident without explanation of any delay while the distance between the incident place and police station is only 5 Kilometers and the deceased was famous lawyer of the District Pratapgarh. That according to the first information report on 29.10.2015 about 07:00 PM four came to the home of the deceased and asked from the informant about deceased. Thereafter about 08:15 the milkman of the informant informed her as about 200 miters of the home one injured person was therein in car and car is similar as yours. Then the informant and other residents run to the incident place where they found the deceased was injured. He was brought to the hospital but he was declared as dead. That the post mortem has been conducted on the deceased body on 30.10.2015 about 12.30PM in District Hospital, District – Pratapgarh. Photo/type copies of the post mortem report dated 30.10.2015 is being annexed as Annexure No. 02 to this application. That the concerned police recorded the statement of the informant under Section 161 of Cr.P.C. on 30.10.2015 in which the informant repeated the contents of the first information report in another manner but the sole of the first information report has not been changed ever. The type copy of the statement of the informant dated 30.10.2015 is being annexed as Annexure No. 03 to this application. 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 under section 120B IPC. That on 11.11.2015 the informant moved an application before the investigating officer to given information in regard to murder of deceased wherein she alleged against the applicant as being advocate the deceased charged free Rs. 50000/- for bail and due to failure of the obtaining bail order for sons of the applicant, the applicant demanded her money and also threatened for life to deceased. Similar to above application the junior of the deceased namely Tauseef Ahamad also given an application before the investigating officer on 12.11.2015. The photo/type copy of the application dated 11.11.2015 & 12.11.2015 are being annexed as Annexure No. 04 to this application. That on basis of the application dated 11.11.2015 of the informant the concerned police recorded her further statement on 12.11.2015 and on basis of the further statement of the informant the Section 120B has been added in said case crime. The type copy of the further statement of the informant is being annexed as Annexure No. 05 to this application. That in perusal of the further statement of the informant and another application dated 12.11.2015 moved by the junior of the deceased are pre-planned for showing implication of the applicant’s name in the said case crime. That if any life threats given by the applicant as alleged against her then why not deceased and anyone who knows that, not informed to the concerned police before the murder of the deceased. That neither the applicant has motive nor has any motive been assigned to him to commit the crime in question with which the applicant has no concerned in any manner. That the name of the applicant came in light in said case crime due undue influence of the local advocates of the District Pratapgarh and the concerned police also showing the good work after false implication of the applicant in the said case crime. That earlier the first information report was registered 4 unknown persons but later on, on the basis of the application dated 11.11.2015 of the informant the applicant has also been made accused in the present case. 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, 120B 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 the applicant moved bail application bearing No. 1760 of 2015 before Additional Sessions Judge, Court No. 4, Pratapgarh and his bail application has been rejected by the court concerned on 02.12.2015. Certified copy of the bail rejection order dated 02.12.2015 is being annexed as Annexure No. 06 to this application. That the applicant in jail since 14.11.2015. That there is no chance of the applicant absconding or tempering with the prosecution witnesses. That the applicant is ready to furnished the security and bond and also undertake that he will be never misused liberty of bail. That in view of the above, it would be expedient and necessary in the interest of justice that the applicant be enlarged on bail during pendency of case.


I, Sanjay Kumar aged about 35 years son of Shri Sant Lal resident of Room No. 11, Matadeen Yadav Chal No. 3, Tanaji Nagar, Kurar Village, Mumbai, Maharastra, Religion – Hindu, Education – Literate, Occupation – Self-employed, do hereby solemnly affirm and state on oath as under :- That the deponent is the brother/ 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 a photo affidavit slip issued by the Oudh Bar Association is affixed to the affidavit. That this is the first bail application before this Hon'ble Court. No any other bail application pending before this Hon'ble Court or rejected by this Hon'ble Court. That the deponent further declares that the contents of the affidavit have been explained in Hindi by the counsel of the applicant to him as such she conversant with the facts of the case. That 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 another on 29.05.2024 at 23.49 hours by Sonu Kumar Saroj son of Shri Ram Dulare Saroj resident of Umaraoganj, Lalgopalganj, Police Station – Nawabganj, District – Prayagraj (hereinafter referred to as ‘informant’) under Sections 302 of I.P.C. at Police Station – Hathigawan District – Pratapgarh. The certified/typed copy of the first information report dated 29.05.2024 is being annexed as Annexure No. 01 to this affidavit. That according to the first information report lodged on 29.05.2024 by the informant alleged therein that the marriage of the sister of the informant namely Reena Devi (hereinafter referred to as ‘deceased’) before 8 years ago. On 29.05.2024 due to the love relationship, the applicant, his mother, and sister-in-law (Bhabhi) murdered the deceased. The informant further alleged that the accused persons also beat the deceased for the dowery. That the informant has lodged the first information report only on a presumption basis, while he himself not clear that the applicant and other accused committed the crime as alleged by him. That the version of the first information report is totally false and baseless and the same depends upon the concocted story and nothing has been done by the applicant as alleged by the informant in his first informant report. That the concerned police recorded the statement of the informant under Section 161 of Cr.P.C. on 30.05.2024 in which the informant gave approximately the same statement as mentioned in the first information report but with improved facts to send the applicant behind bars. The typed copy of the statement of the informant dated 30.05.2024 is being annexed as Annexure No. 02 to this affidavit. That the inquest report was prepared by the concerned police on 30.05.2024 in the presence of Panchan as well as the informant. That the body of the deceased was brought for conducting a post-mortem on the very same day i.e. 30.05.2024, where the post-mortem was conducted by the doctor concerned and the cause of death ascertained as ‘anti-mortem head injury’. The photo/ type copy of the post-mortem report dated 30.05.2024 of the deceased is being annexed as Annexure No. 03 to this affidavit. That the some statements of the alleged eyewitnesses were recorded by the Investigating Officer on 30.05.2024, in which they all gave all most similar statements and stated that they saw that the applicant was beating the deceased after locking the door of his house from inside. The typed copies of the alleged eyewitnesses dated 30.05.2024 are being annexed as Annexure No. 04 to this affidavit. That the statements of the alleged eyewitnesses are beyond the imagination as when the door is locked from inside then there was no chance they saw anything, which was happened as alleged by the informant. That meanwhile a forged arresting memo was prepared by the concerned police on 04.06.2024 at around 16.45 PM showing the applicant was arrested when he was trying to abscond. That the confessional statement of the applicant was written/ prepared by the investigating officer on 04.06.2024 tallying with the statements of the informant and other witnesses only to prove the offence against the applicant whereas the applicant has not given any confessional statement. That thereafter, on 04.06.2024 again the Investigating Officer of the case crime, prepared false documents i.e. recovery memo, and showed therein that on pointing of the applicant the murder weapon had been recovered. The typed copy of the recovery memo dated 04.06.2024 is being annexed as Annexure No. 05 to this affidavit. That the charge sheet No. 128 of 2024 has been filed by the concerned police against the applicant on 03.08.2024 under Section 302 of I.P.C., in 14 out of 20 witnesses are the factual witnesses. That the applicant was arrested by the concerned police on 04.06.2024 merely on the basis being the husband of the deceased without rhyme and reason, while the applicant was not involved in the commission of the crime as alleged against him. That the real fact of the case is that the marriage of the applicant and deceased was solemnized around 13 years ago not 8 years as alleged by the informant and the applicant is the father of three minor children and the younger child of the applicant is aged about 3 years. That the applicant is working as a brickfield labour at  Bhivandi, Maharastra for the livelihood of his family meanwhile the deceased has an illicit relationship with one Premchandra Yadav. That when the mother of the applicant informed regarding the illicit relationship of the deceased then the applicant returned to his house and tried to convince the deceased for not doing the same, for which, the deceased agreed. That when the applicant again went to resume his work in Maharashtra, the deceased again started chatting with his lover and also called him at the house of the applicant thereafter on 29.05.2024, without any prior information of the deceased, he returned to the home and found that the deceased was chatting with her lover when she saw the applicant, she tried to run away and she sliped from the first floor and sustained injuries. That the applicant with the help of his cousin brother brought the deceased to the hospital, but she died and after getting information, the informant in the heat of the moment and also provocation of some villagers, who had enmity with the applicant, lodged the first information report on the basis of the wrong facts. That neither the applicant has any motive nor has any reasonable motive been assigned to him to commit the crime in question. Merely being the husband of the deceased, the applicant has been framed in the said case crime. That there is no credible evidence on record that could show that the applicant is guilty or committed the crime in question and the evidence available on the record itself show that no prima-facie offence under Sections 302 of I.P.C. at Police Station – Hathigawan, District – Pratapgarh 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 and informant. 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 the applicant moved bail application bearing No. 3458 of 2022 before Sessions Judge, Pratapgarh, and his bail application was rejected by the court concerned on 19.09.2024. The free certified copy of the bail rejection order dated 19.09.2024 passed by the court below is being annexed as Annexure No. 06 to this affidavit. That the applicant in jail since 29.05.2024 without the commission of any offense. That the applicant has no any criminal history nor previously been convict. That there is no chance of the applicant absconding or tempering with the prosecution witnesses. That the applicant is ready to furnish the security and bond and also undertakes that he will never misuse the liberty of bail. That in view of the above, it would be expedient and necessary in the interest of justice that the applicant be enlarged on bail in connection with the Case Crime No. 110 of 2024 under Sections 302 of I.P.C. registered at Police Station – Hathigawan, District – Pratapgarh during the pendency of the case, in the interest of justice.


I, Hazifur Rahman son of Arkhul Rahman, resident of Village – Bachhandamau, Police Station – Hathgawan, District – Pratapgarh Religion – Muslim, Education – Literate, Occupation – Agriculture, do hereby solemnly affirm and state on oath as under :- That the deponent is the brother 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 . No any other bail application pending before this Hon'ble Court or rejected by this Hon'ble Court. That brief facts of the case is that a first information report has been lodged against the 3 named and 3 unnamed persons on 25.02.2016 at 00.15 hours by the informant namely S.O., Police Station – Manikpur, Shri Pramod Kumar Singh under Sections 302, 307, 504, 506, 34 I.P.C. and 7, Criminal Law Amendment Act at Police Station – Manikpur, District – Pratapgarh with regard to murder of on duty Homeguard Mahadev Prasad   (hereinafter referred to as deceased). The alleged incident was took place on 24.02.2016 around 23.30 hours. The photocopy of the first information report dated 25.02.2016 is being annexed as Annexure No. 01 to this application. That it is relevant to mention here that the applicant is not named in the first information report. According to the first information report lodged on 25.02.2016 by informant, in which he alleged that around 23.30 hours the most wanted criminal of area along with others criminals fired and bombard on the Police Station – Manikpur and run away from incident place. The informant and his companions tried to catch him failed to do so. That the post mortem was conducted at District Hospital, Pratapgarh on 25.02.2016 by the doctor concerned. The cause of death ascertained as “Shock due to coma as a result of Anti-mortem firearm injury”. The photo/typed copy of the post mortem report dated 25.02.2016 is being annexed as Annexure No. 02 to this application. That the concerned police arrested the accused of the said case crime namely Shiva alias Shivmani Tiwari and Vikash Mishra and they were given their confessional statement before the concerned police but they have said the name of the applicant. The typed copy of the confessional statement of the accused Shiva alias Shivmani Tiwari is being annexed herewith collectively as Annexure No. 03 to this application. That the concerned police was called the applicant on 26.02.2016 for some queries with regard to incident and falsely implicate him in said crime case for ulterior motive. The concerned police forcefully taken confessional statement of the applicant and on said basis he was in jail. The typed copy of the confessional statement of the applicant is being annexed as Annexure No. 04 to this application. That the concerned police without proper investigation, the investigating officer submitted charge sheet bearing No. 48 of 2016 dated 19.05.2016 against the applicant and 3 others persons. That the real story is this; the applicant is common and law abiding citizen, on 26.02.2016, the applicant was called by the concerned police for the asking about the incident took place at Police Station – Manikpur but he was arrested by the concerned police and concerned police forcefully taken his confessional statement and falsely implicate. The applicant falsely implicate in several cased thereafter. That neither the applicant has motive nor any motive has been assigned to him to commit the crime in question and the motive to commit the crime in question has been assigned by the concerned police. 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 the evidence and same is not reliable in manner so far concerned to the applicant. That there is no credible evidence on record which could show that the applicant is guilty or committed the crime in question, except his confessional statement, which was taken forcefully by the concerned police and the evidence available on record itself show that no prima-facie offence under Section 302, 307, 504, 506, 34 I.P.C. and 7, Criminal Law Amendment Act at Police Station – Manikpur, District – Pratapgarh 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/concerned police in malafide intention. That the applicant moved bail application bearing No. 941 of 2017 before Special/ Additional Sessions Judge, Pratapgarh and his bail application has been rejected by the court concerned on 02.08.2017. Certified copy of the bail rejection order dated 02.08.2017 passed by the court below is being annexed as Annexure No. 05 to this application. That two other co-accused of the aforesaid case crime namely Pradeep Kumar Tiwari alias Rohit and Vipin Kumar Pandey, have been released on bail by this Hon'ble Court. The photocopy of the orders passed by this Hon'ble Court is being annexed as Annexure No. 06 to this application. That the applicant in jail since 26.02.2016 without committing any offence. The applicant has not convicted ever before. That after arresting the applicant the concerned police falsely implicate the applicant in several cases as under: Case Crime No. 36 of 2016 under Section 302, 307, 504, 506, 34 IPC, Police Station – Manikpur, District – Pratapgarh. Case Crime No. 37 of 2016 under Section 307 IPC, Police Station – Manikpur, District – Pratapgarh. Case Crime No. 38 of 2016 under Section 3/25 Arms Act, Police Station – Manikpur, District – Pratapgarh. Case Crime No. 41 of 2016 under Section 307, 504, 506 IPC and 7, Criminal Law Amendment Act, Police Station – Hathigawan, District – Pratapgarh. Case Crime No. 22 of 2016 under Section 396, 412 IPC, Police Station – Nawabganj, District – Pratapgarh. That there is no chance of the applicant absconding or tempering with the prosecution witnesses. That the applicant is ready to furnished the security and bond and also undertake that he will be never misused liberty of bail. That in view of the above, it would be expedient and necessary in the interest of justice that the applicant be enlarged on bail during pendency of case.