I, Durga Bux Singh aged about 50 years son of Shri Satya Dev Singh resident of 3/344, Vishwash Khand – 3, Police Station - Gomti Nagar, Lucknow, Religion – Hindu, Occupation – Business, Education – Graduate, do hereby solemnly affirm and states on oath as under :- That the deponent is cousin brother of applicant and doing pairvi of Applicant in the above noted case and duly authorized by him for filing instant application before the Hon'ble Court and as such he is fully conversant with the facts of the case deposed herein under. That the photocopy of ID proof of the deponent is being annexed with this affidavit and the application for waiver of the filing affidavit is being filed separately with bail application. That this is first bail application on behalf of the Applicant before the Hon'ble Court and not other bail application is pending before in any court of law on his behalf. That the facts giving rise to the present case are being stated in brief hereinafter. That the applicant has falsely been implicated in Case Crime No. 125 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C. and 60, 60A, 63 of U.P. Excise Act, 1910 at Police Station – Kunda, District – Pratapgarh on 05.04.2021 at 20.43 hours against the applicant and 12 other named and unknown persons. The certified copy/ typed copy of the first information report dated 05.04.2021 is being annexed herewith as Annexure No. 1 to this Affidavit. That according to the First Information Report, which has been lodged by Shri Devendra Pratap Singh, Station House Officer, Police Station - Kunda, District – Pratapgarh (hereinafter referred to as ‘informant’) stated therein that the informant and his team on patrolling of area on 05.04.2021 and that time the informant got information from his informer (eq[kfcj) in regard of huge adulterated liquor stored in shop situated between Babuganj Highway and railway line. That the raid has been conducted by the informant alongwith his team on 05.04.2021 at alleged place of occurrence and seized lot of adulterated liquor and no anyone arrested by the concerned police at the time raid. That the name of the applicant was told by the informer (eq[kfcj) of the concerned police prior to raid and on basis which the applicant is named in the case crime. That the name of the applicant is shown at serial No. 02 in the accused column in the first information report dated 05.04.2021. That the applicant is common man of society and has no concerned with the adulterated liquor and during the raid the applicant was not present at the place of incident and even he has no concerned with said alleged recovery. That the real fact is that the applicant is innocent and belongs to a respected family and has good reputation being national player of volleyball. That the applicant was serving to the Central Government and was posted as Point-man, at Northern Railways, District – Sultanpur. The photo/type copy of the certificate issued by the railway authority on 15.04.2021 is being annexed herewith as Annexure No. 02 to this application. That the applicant had shifted to Lucknow along with his family since long back and he rarely visits his village. That the children of the applicant are studying in class VIII & III City Montessori School, Indira Nagar, Lucknow and due to false implication in said case crime, the career of the children gone in dark. That the applicant was National Player of Volleyball and won several awards and lastly he was participated in 31st National Games, Punjab – 2001, in which he secured Silver Medal. The photocopies of the certificates related to the volleyball are being annexed herewith as Annexure No. 03 to this application. That the entire case has been made and based against the applicant only on information of the police informer, which is not reliable as nothing is supported to prosecution story. That there is no concerned with the said allegation regarding illegal adulterated liquor as alleged by the informant. The informant working for the present local Member of the Parliament of the ruling party due to political vendetta, he has been falsely implicated in the case crime. That in result of the above, the informant falsely implicates the applicant, in the said crime for ulterior motive, which is baseless and illegal as the applicant is not involved in any criminal activity as alleged against him. That the nothing was recovered in the regard of Adulterated liquor from the applicant’s possession and place in any manner, by the informant and the applicant has no concerned with said recovery in any manner. That on bare perusal of the first information report, it is also evident that there were no independent witnesses of raid conducted by the informant, which also creates doubts upon the story of the informant, which itself concocted and false. That the applicant is in jail since 08.09.2021 without committing any offense as alleged against him. That the applicant has no concerned with recovered adulterated liquor in any manner as such the Sections 420, 467, 468, 471, 272, 273 of I.P.C. and 60, 60A, 63 of U.P. Excise Act, 1910 at Police Station – Hathigawan, District – Pratapgarh have not applicable against him. That the informant has not arrested the applicant at alleged place of recovery even not found anything from the applicant’ possession on 05.04.2021. That the concerned police without proper investigation and under the pressure of the local politician against 12 accused persons including the applicant, filed the charge sheet on 11.09.2021 without receiving the Forensic Science Lab report. That till date there is no any chemical report received from the alleged recovery stating therein that the recovered liquor was obnoxious or spurious for human consumption. That under the political influence, after alleged raid on 05.04.2021, two first information reports lodged i.e. 125 of 2021 and Case Crime No. 124 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60A, 60 of U.P. Excise Act, 1910, 63, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 at Police Station – Kunda, District – Pratapgarh by the SHO, Kunda against the applicant and other named and unknown persons, for preparing the criminal history against the applicant. That the applicant is falsely implicated in several cases lodged against the applicant, which the applicant has not committed any offense. The details of the case, which are lodged against the applicant, as per best knowledge of the applicant are as under:- Case Crime No. 48 of 2021 under section 420, 467, 468, 471, 272, 273 of I.P.C., 60, 63 of U.P. Excise Act, Police Station - Hathigawan District – Pratapgarh, in which the applicant granted bail on 15.11.2021 passed by this Hon'ble High Court. Case Crime No. 49 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60(2), 63 of U.P. Excise Act, 1910, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 registered at Police Station – Hathigawan, District – Pratapgarh, in which the applicant has been granted bail on 06.12.2021 by this Hon'ble High Court. Case Crime No. 50 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60(2), 60A, 63 of U.P. Excise Act, 1910, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 registered at Police Station – Hathigawan, District – Pratapgarh, in which the applicant has been granted bail on 07.12.2021 by this Hon'ble High Court. Case Crime No. 124 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60A, 60 of U.P. Excise Act, 1910, 63, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 at Police Station – Hathigawan, District – Pratapgarh. Case Crime No. 125 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60A, 60 of U.P. Excise Act, 1910, 63, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 at Police Station – Hathigawan, District – Pratapgarh. Case Crime No. 107 of 2021 under Sections 302, 307, 120B, 34, 272, 419, 420, 467, 468, 471 of IPC and 60 of U.P. Excise Act registered at Police Station – Gossainganj, District – Ayodhya, in which the name of the applicant came in the light from the accused person. Case Crime No. 121 of 2021 under Sections 3/25 Arms Act registered at Police Station – Maheshganj, District – Pratapgarh. Case Crime No. 208 of 2021 under Sections 419, 420, 467, 468, 471, 486, 487, 272 of I.P.C., 60, 60A, 63 of U.P. Excise Act, 1910, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 registered at Police Station – Hathigawan, District – Pratapgarh, which has been lodged by the concerned police, when the applicant is in jail, in which the applicant has been granted bail on 07.12.2021 by this Hon'ble High Court. That the aforesaid 8 cases are recently lodged against the applicant under the political pressure. Case Crime No. 15 of 2016 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., registered at Police Station – Maheshganj, District – Pratapgarh, in which the investigation is going on. Case Crime No. 517 of 2016 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60, 63 of U.P. Excise Act, 1910, 63A of Copyright Act, 1957 registered at Police Station – Mil Area, District – Raebareli, in which the applicant released on bail. Case Crime No. 17 of 2016 under Section 135 The Electricity Act registered at Police Station – Maheshganj, District – Pratapgarh, in which the applicant has paid the bill but the concerned police in malafide manner submitted the charge sheet against the applicant. Case Crime No. 178 of 2014 under Sections 420, 467, 468, 471, 272, 273, 427 of I.P.C., 60, 63 of U.P. Excise Act, 1910, 3/4 of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 registered at Police Station – Maheshganj, District – Pratapgarh, in which the charge sheet has been submitted by concerned police and the applicant is exonerated from the said case crime as he was falsely implicated in case. Case Crime No. 44 of 2018 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60, 63 of U.P. Excise Act, 1910 registered at Police Station – Nawabganj, District – Pratapgarh, in which the charge sheet has been submitted by concerned police and the applicant is exonerated from the said case crime as he was falsely implicated in case. Case Crime No. 513 of 2010 under Sections 307, 323, 325, 364, 395, 427 of I.P.C. and 7 of Criminal Law Amendment Act registered at Police Station – Kunda, District – Pratapgarh, in which the applicant is released on bail by this Hon'ble High Court. The photocopies of the bail order passed by the court below and this Hon'ble High Court alongwith other related documents of the applicant are being annexed herewith as Annexure No. 4 to this application. That apart of abovementioned cases, there no criminal history against the applicant. That the maximum named accused of the case crime No. 125 of 2021 alongwith other accused, whose name came in light during the investigation, have been granted bail by the court below. The photocopies of the bail order passed by the court below are being annexed herewith as Annexure No. 5 to this application. That the several co-accused of the case crime has been approached to this Hon'ble High Court for anticipatory bail, which has been granted by this Hon'ble High Court to the co-accused of the case crime. That the applicant had applied for bail before the Sessions Judge, Pratapgarh bearing Bail Application No. 2801 of 2021 in Case Crime No. 125 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C. and 60, 60A, 63 of U.P. Excise Act, 1910 at Police Station – Kunda, District – Pratapgarh which is rejected by the court concerned without going to fact and records. The free copy of bail rejection order dated 07.12.2021 passed by the court concerned is annexed herewith as Annexure No. 6 to this affidavit. That the applicant has not committed any crime as alleged in the first information report by the informant and he has no concern. That there is no possibility of the applicant’s conviction because he has not committed the crime in question, as alleged by the prosecution. That the applicant is common man of the society. He has never convicted in any case and not involved in any criminal activities ever. That there is no chance of applicant’s absconding or tampering with the prosecution witnesses and they are willing to offer bail to the satisfaction of this Hon’ble Court. That the applicant will cooperate with the trial and will not tamper the prosecution witnesses. That the applicant undertakes that he will not misuse the liberty of bail if so granted by this Hon’ble Court. That the applicant is ready and willing to file adequate surety as the Hon’ble Court may deems fit and proper in the circumstances of the case. That in view of the above, it would be expedient and necessary in the interest of justice that the Applicant be enlarged on bail in connection with Case Crime No. 125 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C. and 60, 60A, 63 of U.P. Excise Act, 1910 at Police Station – Kunda, District – Pratapgarh during pendency of trial.


I, Durga Bux Singh aged about 50 years son of Shri Satya Dev Singh resident of 3/344, Vishwash Khand – 3, Police Station - Gomti Nagar, Lucknow, Religion – Hindu, Occupation – Business, Education – Graduate, do hereby solemnly affirm and states on oath as under,:- That the deponent is cousin brother of applicant and doing pairvi of Applicant in the above noted case and duly authorized by him for filing instant application before the Hon'ble Court and as such he is fully conversant with the facts of the case deposed herein under. That the photocopy of ID proof of the deponent is being annexed with this affidavit and the application for waiver of the filing affidavit is being filed separately with bail application. That this is first bail application on behalf of the Applicant before the Hon'ble Court and not other bail application is pending before in any court of law on his behalf. That the facts giving rise to the present case are being stated in brief hereinafter. That the applicant has falsely been implicated in Case Crime No. 208 of 2021 under Sections 419, 420, 467, 468, 471, 486, 487, 272 of I.P.C., 60, 60A, 63 of U.P. Excise Act, 1910, 63 of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 at Police Station – Hathigawan, District – Pratapgarh on 14.10.2021 at 12.45 hours against the applicant and 5 other persons. The certified copy/ typed copy of the first information report dated 14.10.2021 is being annexed herewith as Annexure No. 1 to this Affidavit. That according to the First Information Report, which has been lodged by Shri Ram Adhar Singh Yadav, Sub Inspector, Police Station - Hathigawan, District – Pratapgarh (hereinafter referred to as ‘informant’). The prosecution story is in nutshell that on 13.10.2021 the informant and his team was on patrolling of area and that time he got information from his informant (eq[kfcj), who told that behind the varsiya chicken shop situated at nearby Purnemau crossing, Hathigawan road, huge adulterated liquor has been stored. That the raid has been conducted by the informant along with his team on 13.10.2021 at alleged place of occurrence and seized lot of adulterated liquor, which was buried  and arrested one accused by the concerned police at time raid. That the name of the applicant was told by the arrested accused namely Riyaz Ahmad and on basis of which the applicant is named in the first information report. That the name of the applicant is shown at serial No. 02 in the accused column impugned first information report dated 14.10.2021. That the alleged raid/recovery made by the informant on 13.10.2021 and first information report dated 14.10.2021 is lodged after one day delayed by the concerned police without giving any reason for delay. That the applicant is common man of society and has no concerned with the adulterated liquor and during the raid the applicant is in jail since 08.09.2021. That due to political reasons, the name of the applicant has been falsely implicated in the present case crime on 14.10.2021, even when he is jail since 08.09.2021. That the real fact is that the applicant is innocent and belongs to a respected family and has good reputation being national player of volleyball. That the applicant was serving to the Central Government and was posted as Point-man, at Northern Railways, District – Sultanpur. The photo/type copy of the certificate issued by the railway authority on 15.04.2021 is being annexed herewith as Annexure No. 02 to this application. That the applicant had shifted to Lucknow along with his family since long back and he rarely visits his village. That the children of the applicant are studying in class VIII & III City Montessori School, Indira Nagar, Lucknow. The photocopies of the fee receipts of the applicant’s children are being annexed herewith as Annexure No. 03 to this application. That the applicant was National Player of Volleyball and won several awards and lastly he was participated in 31st National Games, Punjab – 2001, in which he secured Silver Medal. The photocopies of the certificates related to the volleyball are being annexed herewith as Annexure No. 04 to this application. That the entire case has been made and based against the applicant only on information of the police informer, which is not reliable as nothing is supported to prosecution story. That in result of the above, the informant falsely implicates the applicant, in the said crime for ulterior motive, which is baseless and illegal as the applicant is not involved in any criminal activity as alleged against him. That the nothing was recovered in the regard of Adulterated liquor from the applicant’s possession and place in any manner, by the informant and the applicant has no concerned with said recovery in any manner as he is jail since 08.09.2021. That on bare perusal of the first information report, it is also evident that there were no independent witnesses of raid conducted by the informant, which also creates doubts upon the story of the informant, which itself concocted and false. That the applicant is in jail since 08.09.2021 without committing any offense as alleged against him. That the applicant has no concerned with recovered adulterated liquor in any manner as such the under Sections 419, 420, 467, 468, 471, 486, 487, 272 of I.P.C., 60, 60A, 63 of U.P. Excise Act, 1910, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 at Police Station – Hathigawan, District – Pratapgarh have not applicable against him. That till date there is no any chemical report received from the alleged recovery dated 14.10.2021 stating therein that the recovered liquor was obnoxious or spurious for human consumption. That the applicant is falsely implicated in several cases lodged against the applicant, which the applicant has not committed any offense. The details of the case, which are lodged against the applicant, as per best knowledge of the applicant are as under:- Case Crime No. 48 of 2021 under section 420, 467, 468, 471, 272, 273 of I.P.C., 60, 63 of U.P. Excise Act, Police Station - Hathigawan District – Pratapgarh, in which the applicant granted bail on 15.11.2021 passed by this Hon'ble High Court. Case Crime No. 49 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60(2), 63 of U.P. Excise Act, 1910, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 registered at Police Station – Hathigawan, District – Pratapgarh,. Case Crime No. 50 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60(2), 60A, 63 of U.P. Excise Act, 1910, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 registered at Police Station – Hathigawan, District – Pratapgarh. Case Crime No. 124 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60A, 60 of U.P. Excise Act, 1910, 63, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 at Police Station – Hathigawan, District – Pratapgarh. Case Crime No. 125 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60A, 60 of U.P. Excise Act, 1910, 63, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 at Police Station – Hathigawan, District – Pratapgarh. Case Crime No. 107 of 2021 under Sections 302, 307, 120B, 34, 272, 419, 420, 467, 468, 471 of IPC and 60 of U.P. Excise Act registered at Police Station – Gossainganj, District – Ayodhya, in which the name of the applicant came in the light from the accused person. Case Crime No. 121 of 2021 under Sections 3/25 Arms Act registered at Police Station – Maheshganj, District – Pratapgarh. Case Crime No. 208 of 2021 under Sections 419, 420, 467, 468, 471, 486, 487, 272 of I.P.C., 60, 60A, 63 of U.P. Excise Act, 1910, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 registered at Police Station – Hathigawan, District – Pratapgarh. That the aforesaid 8 cases are recently lodged against the applicant under the political pressure. Case Crime No. 15 of 2016 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., registered at Police Station – Maheshganj, District – Pratapgarh, in which the investigation is going on. Case Crime No. 517 of 2016 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60, 63 of U.P. Excise Act, 1910, 63A of Copyright Act, 1957 registered at Police Station – Mil Area, District – Raebareli, in which the applicant released on bail. Case Crime No. 17 of 2016 under Section 135 The Electricity Act registered at Police Station – Maheshganj, District – Pratapgarh, in which the applicant has paid the bill but the concerned police in malafide manner submitted the charge sheet against the applicant. Case Crime No. 178 of 2014 under Sections 420, 467, 468, 471, 272, 273, 427 of I.P.C., 60, 63 of U.P. Excise Act, 1910, 3/4 of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 registered at Police Station – Maheshganj, District – Pratapgarh, in which the charge sheet has been submitted by concerned police and the applicant is exonerated from the said case crime as he was falsely implicated in case. Case Crime No. 44 of 2018 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60, 63 of U.P. Excise Act, 1910 registered at Police Station – Nawabganj, District – Pratapgarh, in which the charge sheet has been submitted by concerned police and the applicant is exonerated from the said case crime as he was falsely implicated in case. Case Crime No. 513 of 2010 under Sections 307, 323, 325, 364, 395, 427 of I.P.C. and 7 of Criminal Law Amendment Act registered at Police Station – Kunda, District – Pratapgarh, in which the applicant is released on bail by this Hon'ble High Court. The photocopies of the bail order and other related documents of the applicant are being annexed herewith as Annexure No. 5 to this application. That apart of abovementioned cases, there no criminal history against the applicant. That the co-accused of the case crime namely Riyaz Ahmad and Bachcha Yadav have been granted bail by the court below vide its order dated 09.11.2021. The photocopy of the order dated 09.11.2021 passed by the court below is being annexed herewith as Annexure No. 6 to this application. That the applicant had applied for bail before the Sessions Judge, Pratapgarh bearing Bail Application No. 2752 of 2021 under Sections 419, 420, 467, 468, 471, 486, 487, 272 of I.P.C., 60, 60A, 63 of U.P. Excise Act, 1910, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 at Police Station – Hathigawan, District – Pratapgarh which is rejected by the court concerned without going to fact and records. The free copy of bail rejection order dated 30.11.2021 passed by the court concerned is annexed herewith as Annexure No. 7 to this affidavit. That the applicant has not committed any crime as alleged in the first information report by the informant and he has no concern. That there is no possibility of the applicant’s conviction because he has not committed the crime in question, as alleged by the prosecution. That the applicant is common man of the society. He has never convicted in any case and not involved in any criminal activities ever. That there is no chance of applicant’s absconding or tampering with the prosecution witnesses and they are willing to offer bail to the satisfaction of this Hon’ble Court. That the applicant will cooperate with the trial and will not tamper the prosecution witnesses. That the applicant undertakes that he will not misuse the liberty of bail if so granted by this Hon’ble Court. That the applicant is ready and willing to file adequate surety as the Hon’ble Court may deems fit and proper in the circumstances of the case. That in view of the above, it would be expedient and necessary in the interest of justice that the Applicant be enlarged on bail in connection with Case Crime No. 48 of 2021 under Sections 419, 420, 467, 468, 471, 486, 487, 272 of I.P.C., 60, 60A, 63 of U.P. Excise Act, 1910, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 at Police Station – Hathigawan, District – Pratapgarh during pendency of trial.


I, Durga Bux Singh aged about 50 years son of Shri Satya Dev Singh resident of 3/344, Vishwash Khand – 3, Police Station - Gomti Nagar, Lucknow, Religion – Hindu, Occupation – Business, Education – Graduate, do hereby solemnly affirm and states on oath as under :- That the deponent is cousin brother of applicant and doing pairvi of Applicant in the above noted case and duly authorized by him for filing instant application before the Hon'ble Court and as such he is fully conversant with the facts of the case deposed herein under. That the photocopy of ID proof of the deponent is being annexed with this affidavit and the application for waiver of the filing affidavit is being filed separately with bail application. That this is first bail application on behalf of the Applicant before the Hon'ble Court and not other bail application is pending before in any court of law on his behalf. That the facts giving rise to the present case are being stated in brief hereinafter. That the applicant has falsely been implicated in case crime No. 48 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C. and 60, 63 of U.P. Excise Act, 1910 at Police Station – Hathigawan, District – Pratapgarh on 01.04.2021 at 05.32 hours against the two known and several unknown persons. The certified copy/ typed copy of the first information report dated 01.04.2021 is being annexed herewith as Annexure No. 1 to this Affidavit. That according to the First Information Report, which has been lodged by Shri Doodhnath Singh Yadav, Station House Officer, Police Station - Hathigawan, District – Pratapgarh (hereinafter referred to as ‘informant’) the prosecution story is in nutshell that the informant and his team on patrolling of area on 31.03.2021 and that time the informant got information from his informer with regard of huge adulterated liquor is being prepared by the applicant and other persons and they are selling the same. That the raid has been conducted by the informant along with his team on 31.03.2021 at 22.10 hours at alleged recovery place and seized lot of adulterated liquor. That the co-accused of the case crime i.e. Sanjay Pratap Singh alias Guddu Singh has surrendered before the court concerned on 04.06.2021 in aforesaid case crime and according to the case diary, the investigating officer after getting the permission from the court concerned, recorded the statement of the co-accused under Section 161 of Cr.P.C. in jail on 07.06.2021, in which he said that the applicant is involve in said case crime alongwith him. The type copy of the statement of the co-accused of the case crime Sanjay Pratap Singh alias Guddu Singh recorded on 07.06.2021 is being annexed herewith as Annexure No. 2 to this Affidavit. That later on the investigating officer recorded another statement of the co-accused of the case crime namely Rajesh Saroj on 25.06.2021, in which he also stated that the applicant was involve in business of the adulterated liquor. The type copy of the statement of the co-accused Rajesh Saroj of the case crime recorded on 25.06.2021 is being annexed herewith as Annexure No. 3 to this Affidavit. That for the extraneous reasons, the applicant falsely implicated in said case crime for showing good work of the police and after more than 5 months the chemical report is received by the investigating officer of the case crime. On basis of the chemical report it has been found the alleged recovered liquor is not adulterated hence the Section 272 & 273 of IPC has been dropped by the investigating officer, which is mentioned in CD No. 39 dated 16.09.2021. The typed copy of the CD No. 39 dated 16.09.2021 of the case crime is being annexed herewith as Annexure No. - 4 to this affidavit. That the applicant is common man of society and has no concerned with the adulterated liquor and during the raid the applicant was not present at the place of incident and even he has no concerned with said alleged recovery. That the real fact is that the applicant is innocent and belongs to a respected family and has good reputation being national player of volleyball. That the applicant was serving to the Central Government and was posted as Point-man, at Northern Railways, District – Sultanpur. The photo/type copy of the certificate issued by the railway authority on 15.04.2021 is being annexed herewith as Annexure No. 5 to this application. That the applicant had shifted to Lucknow along with his family since long back and he rarely visits his village. That the children of the applicant are studying in class VIII & III City Montessori School, Indira Nagar, Lucknow and due to false implication in said case crime, the career of the children gone in dark. That the applicant was National Player of Volleyball and won several awards and lastly he was participated in 31st National Games, Punjab – 2001, in which he secured Silver Medal. The photocopies of the certificates related to the volleyball are being annexed herewith as Annexure No. 6 to this application. That the entire case has been made and based against the applicant only on information of the police informer, which is not reliable as nothing is supported to prosecution story. That there is no concerned with the said allegation regarding illegal adulterated liquor as alleged by the informant. The informant working for the present local Member of the Parliament of the ruling party due to political vendetta, he has been falsely implicated in the case crime. That in result of the above, the informant falsely implicates the applicant, in the said crime for ulterior motive, which is baseless and illegal as the applicant is not involved in any criminal activity as alleged against him. That the nothing was recovered in the regard of Adulterated liquor from the applicant’s possession and place in any manner, by the informant and the applicant has no concerned with said recovery in any manner. That on bare perusal of the first information report, it is also evident that there were no independent witnesses of raid conducted by the informant, which also creates doubts upon the story of the informant, which itself concocted and false. That the applicant is in jail since 08.09.2021 without committing any offense as alleged against him. That the applicant has no concerned with recovered adulterated liquor in any manner as such the under Sections 420, 467, 468, 471, 272, 273 of I.P.C. and 60, 63 of U.P. Excise Act, 1910 registered at Police Station – Hathigawan, District – Pratapgarh have not applicable against him. That the informant has not arrested the applicant at alleged place of recovery even not found anything from the applicant’ possession on 05.04.2021. That till date there is no any chemical report received from the alleged recovery stating therein that the recovered liquor was obnoxious or spurious for human consumption. That the applicant is falsely implicated in several cases lodged against the applicant, which the applicant has not committed any offense. The details of the case, which are lodged against the applicant, as per best knowledge of the applicant are as under:- Case Crime No. 48 of 2021 under section 420, 467, 468, 471, 272, 273 of I.P.C., 60, 63 of U.P. Excise Act, Police Station - Hathigawan District – Pratapgarh, in which the applicant granted bail on 15.11.2021 passed by this Hon'ble High Court. Case Crime No. 49 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60(2), 63 of U.P. Excise Act, 1910, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 registered at Police Station – Hathigawan, District – Pratapgarh, in which the applicant has been granted bail on 06.12.2021 by this Hon'ble High Court. Case Crime No. 50 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60(2), 60A, 63 of U.P. Excise Act, 1910, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 registered at Police Station – Hathigawan, District – Pratapgarh, in which the applicant has been granted bail on 07.12.2021 by this Hon'ble High Court. Case Crime No. 124 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60A, 60 of U.P. Excise Act, 1910, 63, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 at Police Station – Hathigawan, District – Pratapgarh. Case Crime No. 125 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60A, 60 of U.P. Excise Act, 1910, 63, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 at Police Station – Hathigawan, District – Pratapgarh. Case Crime No. 107 of 2021 under Sections 302, 307, 120B, 34, 272, 419, 420, 467, 468, 471 of IPC and 60 of U.P. Excise Act registered at Police Station – Gossainganj, District – Ayodhya, in which the name of the applicant came in the light from the accused person. Case Crime No. 121 of 2021 under Sections 3/25 Arms Act registered at Police Station – Maheshganj, District – Pratapgarh. Case Crime No. 208 of 2021 under Sections 419, 420, 467, 468, 471, 486, 487, 272 of I.P.C., 60, 60A, 63 of U.P. Excise Act, 1910, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 registered at Police Station – Hathigawan, District – Pratapgarh, which has been lodged by the concerned police, when the applicant is in jail, in which the applicant has been granted bail on 07.12.2021 by this Hon'ble High Court. That the aforesaid 8 cases are recently lodged against the applicant under the political pressure. Case Crime No. 15 of 2016 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., registered at Police Station – Maheshganj, District – Pratapgarh, in which the investigation is going on. Case Crime No. 517 of 2016 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60, 63 of U.P. Excise Act, 1910, 63A of Copyright Act, 1957 registered at Police Station – Mil Area, District – Raebareli, in which the applicant released on bail. Case Crime No. 17 of 2016 under Section 135 The Electricity Act registered at Police Station – Maheshganj, District – Pratapgarh, in which the applicant has paid the bill but the concerned police in malafide manner submitted the charge sheet against the applicant. Case Crime No. 178 of 2014 under Sections 420, 467, 468, 471, 272, 273, 427 of I.P.C., 60, 63 of U.P. Excise Act, 1910, 3/4 of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 registered at Police Station – Maheshganj, District – Pratapgarh, in which the charge sheet has been submitted by concerned police and the applicant is exonerated from the said case crime as he was falsely implicated in case. Case Crime No. 44 of 2018 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60, 63 of U.P. Excise Act, 1910 registered at Police Station – Nawabganj, District – Pratapgarh, in which the charge sheet has been submitted by concerned police and the applicant is exonerated from the said case crime as he was falsely implicated in case. Case Crime No. 513 of 2010 under Sections 307, 323, 325, 364, 395, 427 of I.P.C. and 7 of Criminal Law Amendment Act registered at Police Station – Kunda, District – Pratapgarh, in which the applicant is released on bail by this Hon'ble High Court. The photocopies of the bail order passed by the court below and this Hon'ble High Court alongwith other related documents of the applicant are being annexed herewith as Annexure No. 7 to this application. That apart of abovementioned cases, there no criminal history against the applicant. That after rejection of the bail from the learned court below, the co-accused also have been filed the bail application before this Hon'ble High Court in which the accused Sanjay Pratap Singh alias Guddu Singh and Rajesh Saroj have been granted bail to him by this Hon'ble High Court. The photocopy of the order passed by this Hon'ble High Court is being annexed herewith as Annexure No. 8 to this Affidavit. That the applicant had applied for bail before the Sessions Judge, Pratapgarh bearing Bail Application No. 0000 of 2021 in Case Crime No. 48 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C. and 60, 63 of U.P. Excise Act, 1910 registered at Police Station – Hathigawan, District – Pratapgarh which is rejected by the court concerned without going to fact and records. The free copy of bail rejection order dated 00.00.0000 passed by the court concerned is annexed herewith as Annexure No. 9 to this affidavit. That the applicant has not committed any crime as alleged in the first information report by the informant and he has no concern. That there is no possibility of the applicant’s conviction because he has not committed the crime in question, as alleged by the prosecution. That the applicant is common man of the society. He has never convicted in any case and not involved in any criminal activities ever. That there is no chance of applicant’s absconding or tampering with the prosecution witnesses and they are willing to offer bail to the satisfaction of this Hon’ble Court. That the applicant will cooperate with the trial and will not tamper the prosecution witnesses. That the applicant undertakes that he will not misuse the liberty of bail if so granted by this Hon’ble Court. That the applicant is ready and willing to file adequate surety as the Hon’ble Court may deems fit and proper in the circumstances of the case. That in view of the above, it would be expedient and necessary in the interest of justice that the Applicant be enlarged on bail in connection with Case Crime No. 48 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C. and 60, 63 of U.P. Excise Act, 1910 registered at Police Station – Hathigawan, District – Pratapgarh, during pendency of trial.


I, Durga Bux Singh aged about 50 years son of Shri Satya Dev Singh resident of 3/344, Vishwash Khand – 3, Police Station - Gomti Nagar, Lucknow, Religion – Hindu, Occupation – Business, Education – Graduate, do hereby solemnly affirm and states on oath as under :- That the deponent is cousin brother of applicant and doing pairvi of Applicant in the above noted case and duly authorized by him for filing instant application before the Hon'ble Court and as such he is fully conversant with the facts of the case deposed herein under. That the photocopy of ID proof of the deponent is being annexed with this affidavit and the application for waiver of the filing affidavit is being filed separately with bail application. That this is first bail application on behalf of the Applicant before the Hon'ble Court and not other bail application is pending before in any court of law on his behalf. That the facts giving rise to the present case are being stated in brief hereinafter. That the applicant has falsely been implicated in Case Crime No. 50 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60(2), 60A, 63 of U.P. Excise Act, 1910, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 at Police Station – Hathigawan, District – Pratapgarh on 03.04.2021 at 02.09 hours against the applicant and 12 other persons. The certified copy/ typed copy of the first information report dated 03.04.2021 is being annexed herewith as Annexure No. 1 to this Affidavit. That according to the First Information Report, which has been lodged by Shri Doodhnath Singh Yadav, Station House Officer, Police Station - Hathigawan, District – Pratapgarh (hereinafter referred to as ‘informant’),  the prosecution story is in nutshell that the informant lodged a first information report against the applicant and several other persons on 03.04.2021 about 23.52 hours and stated that the informant and his team was on patrolling of area on 02.04.2021 and that time the team of Surveillance Cell, Prayagraj Zone met with the informant and informed that his team got information from his informant (eq[kfcj), who told the all 19 names of the accused and stated that from Parsipur Cowshed they are involved in the smuggling the adulterated liquor and stored huge adulterated liquor. That the raid has been conducted by the informant along with his team on 02.04.2021 around 16.40 hours at alleged place of occurrence and seized lot of adulterated liquor and no anyone arrested by the concerned police at time raid. That the name of the applicant was told by the informer (eq[kfcj) of the concerned police prior to the raid and he was not present there and on basis of which the applicant is named in the first information report. That the name of the applicant is shown at serial No. 01 in the accused column impugned first information report dated 03.04.2021. That the alleged raid/recovery made by the informant on 02.04.2021 and first information report dated 03.04.2021 is lodged after one day delayed by the concerned police without giving any reason for delay. That the applicant is common man of society and has no concerned with the adulterated liquor and during the raid the applicant was not present at the place of incident. That the real fact is that the applicant is innocent and belongs to a respected family and has good reputation being national player of volleyball. That the applicant was serving to the Central Government and was posted as Point-man, at Northern Railways, District – Sultanpur. The photo/type copy of the certificate issued by the railway authority on 15.04.2021 is being annexed herewith as Annexure No. 02 to this application. That the applicant had shifted to Lucknow along with his family since long back and he rarely visits his village. That the children of the applicant are studying in class VIII & III City Montessori School, Indira Nagar, Lucknow and due to false implication in said case crime, the career of the children gone in dark. That the applicant was National Player of Volleyball and won several awards and lastly he was participated in 31st National Games, Punjab – 2001, in which he secured Silver Medal. The photocopies of the certificates related to the volleyball are being annexed herewith as Annexure No. 03 to this application. That the entire case has been made and based against the applicant only on information of the police informer, which is not reliable as nothing is supported to prosecution story. That there is no concerned with the said allegation regarding illegal adulterated liquor as alleged by the informant. The informant working for the present local Member of the Parliament of the ruling party due to political vendetta, he has been falsely implicated in the case crime. That in result of the above, the informant falsely implicates the applicant, in the said crime for ulterior motive, which is baseless and illegal as the applicant is not involved in any criminal activity as alleged against him. That the nothing was recovered in the regard of Adulterated liquor from the applicant’s possession and place in any manner, by the informant and the applicant has no concerned with said recovery in any manner. That on bare perusal of the first information report, it is also evident that there were no independent witnesses of raid conducted by the informant, which also creates doubts upon the story of the informant, which itself concocted and false. That the applicant was in jail in connection with case crime No. 124 of 2021 registered at Police Station – Kunda, District – Pratapgarh. That the investigating officer of case crime No. 50 of 2021 has moved an application before the court concerned to take the applicant in police custody remand on 21.09.2021. The police custody remand application has been allowed by the court concerned on 23.09.2021 and the applicant sent to police custody remand from 25.09.2021 at 08.00 AM to 08.00 PM in Case Crime No. 50 of 2021. That after taking in police custody remand, a false and fabricated recovery memo has been prepared by the concerned police. In which on pointing out of the applicant, the concerned police recovered huge amount of adulterated liquor and other related items on 25.09.2021. That the applicant is in jail since 08.09.2021 without committing any offense as alleged against him. That the applicant has no concerned with recovered adulterated liquor in any manner as such the under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60(2), 60A, 63 of U.P. Excise Act, 1910, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 at Police Station – Hathigawan, District – Pratapgarh have not applicable against him. That the informant has not arrested the applicant at alleged place of recovery even not found anything from the applicant’ possession on 02.04.2021. That till date there is no any chemical report received from the alleged recovery dated 25.09.2021 stating therein that the recovered liquor was obnoxious or spurious for human consumption. That the applicant is falsely implicated in several cases lodged against the applicant, which the applicant has not committed any offense. The details of the case, which are lodged against the applicant, as per best knowledge of the applicant are as under:- Case Crime No. 48 of 2021 under section 420, 467, 468, 471, 272, 273 of I.P.C., 60, 63 of U.P. Excise Act, Police Station - Hathigawan District – Pratapgarh, in which the applicant granted bail on 15.11.2021 passed by this Hon'ble High Court. Case Crime No. 49 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60(2), 63 of U.P. Excise Act, 1910, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 registered at Police Station – Hathigawan, District – Pratapgarh,. Case Crime No. 50 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60(2), 60A, 63 of U.P. Excise Act, 1910, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 registered at Police Station – Hathigawan, District – Pratapgarh. Case Crime No. 124 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60A, 60 of U.P. Excise Act, 1910, 63, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 at Police Station – Hathigawan, District – Pratapgarh. Case Crime No. 125 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60A, 60 of U.P. Excise Act, 1910, 63, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 at Police Station – Hathigawan, District – Pratapgarh. Case Crime No. 107 of 2021 under Sections 302, 307, 120B, 34, 272, 419, 420, 467, 468, 471 of IPC and 60 of U.P. Excise Act registered at Police Station – Gossainganj, District – Ayodhya, in which the name of the applicant came in the light from the accused person. Case Crime No. 121 of 2021 under Sections 3/25 Arms Act registered at Police Station – Maheshganj, District – Pratapgarh. Case Crime No. 208 of 2021 under Sections 419, 420, 467, 468, 471, 486, 487, 272 of I.P.C., 60, 60A, 63 of U.P. Excise Act, 1910, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 registered at Police Station – Hathigawan, District – Pratapgarh, which has been lodged by the concerned police, when the applicant is in jail. That the aforesaid 8 cases are recently lodged against the applicant under the political pressure. Case Crime No. 15 of 2016 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., registered at Police Station – Maheshganj, District – Pratapgarh, in which the investigation is going on. Case Crime No. 517 of 2016 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60, 63 of U.P. Excise Act, 1910, 63A of Copyright Act, 1957 registered at Police Station – Mil Area, District – Raebareli, in which the applicant released on bail. Case Crime No. 17 of 2016 under Section 135 The Electricity Act registered at Police Station – Maheshganj, District – Pratapgarh, in which the applicant has paid the bill but the concerned police in malafide manner submitted the charge sheet against the applicant. Case Crime No. 178 of 2014 under Sections 420, 467, 468, 471, 272, 273, 427 of I.P.C., 60, 63 of U.P. Excise Act, 1910, 3/4 of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 registered at Police Station – Maheshganj, District – Pratapgarh, in which the charge sheet has been submitted by concerned police and the applicant is exonerated from the said case crime as he was falsely implicated in case. Case Crime No. 44 of 2018 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60, 63 of U.P. Excise Act, 1910 registered at Police Station – Nawabganj, District – Pratapgarh, in which the charge sheet has been submitted by concerned police and the applicant is exonerated from the said case crime as he was falsely implicated in case. Case Crime No. 513 of 2010 under Sections 307, 323, 325, 364, 395, 427 of I.P.C. and 7 of Criminal Law Amendment Act registered at Police Station – Kunda, District – Pratapgarh, in which the applicant is released on bail by this Hon'ble High Court. The photocopies of the bail order and other related documents of the applicant are being annexed herewith as Annexure No. 4 to this application. That apart of abovementioned cases, there no criminal history against the applicant. That the several accused of the case crime have been filed bail before the learned court below in which one Anoop Singh, who have criminal history of 30 cases, granted bail by the court below on 14.07.2021. That after rejection of the bail from the learned court below, several accused also have been filed the bail application before this Hon'ble High Court in which 10 accused have been granted bail to them on various dates. The photocopies of the orders passed by this Hon'ble High Court are being annexed herewith as Annexure No. 5 to this Affidavit. That the applicant had applied for bail before the Sessions Judge, Pratapgarh bearing Bail Application No. 2822 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60(2), 60A, 63 of U.P. Excise Act, 1910, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 at Police Station – Hathigawan, District – Pratapgarh which is rejected by the court concerned without going to fact and records. The free copy of bail rejection order dated 30.11.2021 passed by the court concerned is annexed herewith as Annexure No. 6 to this affidavit. That the applicant has not committed any crime as alleged in the first information report by the informant and he has no concern. That there is no possibility of the applicant’s conviction because he has not committed the crime in question, as alleged by the prosecution. That the applicant is common man of the society. He has never convicted in any case and not involved in any criminal activities ever. That there is no chance of applicant’s absconding or tampering with the prosecution witnesses and they are willing to offer bail to the satisfaction of this Hon’ble Court. That the applicant will cooperate with the trial and will not tamper the prosecution witnesses. That the applicant undertakes that he will not misuse the liberty of bail if so granted by this Hon’ble Court. That the applicant is ready and willing to file adequate surety as the Hon’ble Court may deems fit and proper in the circumstances of the case. That in view of the above, it would be expedient and necessary in the interest of justice that the Applicant be enlarged on bail in connection with Case Crime No. 48 of 2021 under Sections 420, 467, 468, 471, 272, 273 of I.P.C., 60(2), 60A, 63 of U.P. Excise Act, 1910, 63A of Copyright Act, 1957 and 103, 104 of The Trade and Merchandise Marks Act, 1958 at Police Station – Hathigawan, District – Pratapgarh during pendency of trial.


I, Mohd. Faheem Ahmad aged about 20 years son of Ali Ahmad resident of Village - Khampur, Patti, Police Station – Dilippur, District – Pratapgarh, Qualification – Literate, Occupation – Self-employed, the deponent do hereby solemnly affirm and  state on oath as under:- That the deponent is the brother/pairokar of the applicant and doing pairvi of the applicant in the above-noted case and duly authorized by him for filing the instant application before the Hon'ble Court and as such he is fully conversant with the facts of the case deposed herein under. That the photo verification slip issued by the Awadh Bar Association of the deponent is being pasted on the first page of this affidavit and a photocopy of the ID proof of the deponent is being annexed with this affidavit. That the deponent further declares that the contents of the affidavit have been explained in Hindi by the counsel of the applicant to him as such she conversant with the facts of the case. That 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 the instant bail application is being filed during the summer vacation as urgent as the applicant is in jail since 06.04.2024 without committing any offense. That this is the first bail application on behalf of the applicant before this Hon'ble High 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. 42 of 2024 under Sections 147, 148, 149, 307, 504, 506, 323, 286, 427 of I.P.C. at Police Station – Dilippur, District – Pratapgarh on 05.04.2024 at 23.48 hours against the applicant/accused and 9 other named along with 6 unknown persons. The first information report is lodged by Nizam Ali son of Late Sher Ali resident of Village - Khampur, Police Station - Dilippur, District - Pratapgarh (hereinafter referred to as ‘informant’). The certified/type copy of the first information report dated 05.04.2024 lodged by the informant is being annexed herewith as Annexure No. 1 to this Affidavit. That according to the First Information Report, the prosecution's story is in a nutshell, that the informant was present in a Roza Iftar at his house along with other persons at that time due to old enmity, the applicant along with other accused reached to his house along with lathi, danda and stated to kill the informant and they assaulted upon the some persons, who sustained the injuries. That the applicant is a common man of society and has no concern with the alleged allegation without any reason and falsely implicate in said case crime. That the general allegations have been made by the informant and no any specific role assigned to the applicant or other. That the informant lodged the said first information report in the counterblast to save himself and his companions as one accused of the case crime namely Ishrat Ali lodged a first information report on 04.04.2024 bearing Case Crime No. 41 of 2024 under Sections 323, 504, 506, 427 at Police Station - Dilippur, District - Pratapgarh. The photocopy of the first information report lodged on 04.04.2024 against the informant and his companions is being annexed herewith as Annexure No. 2 to this Affidavit. That the injured were brought to the District Hospital on 05.04.2024 for treatment, where the injury reports were prepared, in which nothing was found serious. The photo/ typed copies of the medical of the injured are being annexed herewith as Annexure No. 3 to this Affidavit. That the statement of the informant was recorded by the Investigating Officer on 06.04.2024 under Section 161 of Cr.P.C., in which he almost repeated his version of the first information report. The typed copy of the statement of the informant dated 06.04.2024 is being annexed herewith as Annexure No. 4 to this Affidavit. That the two accused of the case crime were arrested by the concerned police on 06.04.2024 including the applicant and on pointing of them the concerned police recovered two lathi, which were allegedly used by the arrested accused at the time of the alleged incident. The photo/typed copy of the recovery memo dated 06.04.2024 is being annexed herewith as Annexure No. 5 to this Affidavit. That on 15.04.2024, the statements of the injured persons were recorded by the Investigating Officer under Section 161 of Cr.P.C., in which they almost repeated the first information report in their own words and tried to falsely implicate the applicant in the case crime. The typed copies of the statements of the injured persons dated 15.04.2024 are being annexed herewith as Annexure No. 6 to this Affidavit. That the real fact of the case is that the applicant has no concerns about any type of the act as mentioned in the first information report. The informant falsely implicates the applicant in said case. That it is most relevant to mention here that the applicant has not committed any offense as alleged by the informant in his first information report dated 05.04.2024. That another accused of the case crime namely Ishrat Ali contested the Village Pradhan election, which was held in 2021, in which the wife of the informant also contested the election. That the wife of the informant lost her election and due to which the informant and his well-wisher had enmity with him. That on 04.04.2024, the informant and his companions had beaten Ishrat Ali as such Ishrat Ali lodged a first information report on 04.04.2024 bearing Case Crime No. 41 of 2024 under Sections 323, 504, 506, 427 at Police Station - Dilippur, District - Pratapgarh. That after lodging the first information report against the informant and others, they planned to take revenge from Ishrat Ali and his well-wisher in the result of the same, on 05.04.2024, when Ishrat Ali invited the applicant and others on 05.04.2024 for Roza Iftar at his house then the informant and his companions assaulted upon Ishart Ali and the applicant also. That during the attack of the informant and his companions, the applicant and others for their defense fought with them thereafter when the concerned police reached at the incident place, brought the applicant and Ishrat Ali for medical treatment but for extraneous reasons, lodged the first information report against the applicant and others and they were challaned also. That later on, a forged and fabricated recovery memo was prepared by the concerned police on 06.04.2024 for extraneous reasons and showing that the applicant along with another accused tried to abscond. That the wife of Ishrat Ali moved an application for lodging the First Information Report against the informant and his companions but the same was not lodged by the concerned police as they were extending the protection to the information. That thereafter, the wife of Ishart Ali met with the Superintendent of Police, Pratapgarh to lodge the first information report, who directed the Station House Officer, Police Station - Dilippur to lodge the first information report on 10.04.2024. That thereafter the first information report was lodged against the informant and his companions on 19.04.2024 bearing Case Crime No. 50 of 2024 under Sections 147, 148, 149, 323, 352, 427, 504, 506, 286 of I.P.C. at Police Station - Dilippur, District - Pratapgarh regarding incident dated 05.04.2024. The photocopy of the first information report dated 19.04.2024 lodged against the informant and others is being annexed herewith as Annexure No. 7 to this Affidavit. That the informant has no any independent witnesses of the alleged recovery because the applicant has not committed any offense. That till date the concerned police have not produced any sufficient evidence against the applicant to prove the involvement of the applicant in the case crime. That there is no credible evidence on record which could show that the applicant is guilty or committed the crime in question and the evidence available on the record itself show that no prima-facie offence under 147, 148, 149, 307, 504, 506, 323, 286, 427 of I.P.C. is made out against the applicant. That the according to the first information report, Section 307 of I.P.C. is not made out against the applicant. That on a bare perusal of the recovery-cum-arresting memo, it is clear that on 05.04.2024 at 23.48 hours, the Investigating Officer left the concerned Police Station to arrest the accused of the case crime and also stated that he was the Investigating Officer of the case crime while the first information report itself lodged on 05.04.2024 at 23.48 hours. That the promptness of the Investigation Officer of the case crime itself shows that he was working for the informant for extraneous reasons, as while the first information report was lodging by the concerned police persons at the same time the Investigating Officer left the Police Station to arrest the applicant and other accused of the case crime. That since the applicant has not committed any offence as alleged but he has been falsely implicated in the case by the informant with malafide intention. That here it is relevant to mention here that the applicant has no concerns with the alleged incident but the concerned police arrested the applicant and connected him with the said offense for extraneous reasons. That apart from the above as per the best knowledge of the applicant, no other criminal history against the applicant. That the applicant had applied for bail before bearing No. 1094 of 2024 the Sessions Judge,  Pratapgarh but the same has been rejected on insufficient grounds vide order dated 27.04.2024. The free copy of the bail rejection order dated 27.04.2024 passed by the court below is annexed herewith as Annexure No. 8 to this affidavit. That the applicant has not committed any crime as alleged in the first information report by the informant and has no concern. That the applicant has been in jail since 06.04.2024 without committing any offense as alleged against the applicant. That there is no possibility of the applicant's conviction because he has not committed the crime in question, as alleged by the prosecution. That the applicant is the common man of the society. That there is no chance of the applicant absconding or tampering with the prosecution witnesses and they are willing to offer bail to the satisfaction of this Hon’ble Court. That the applicant will cooperate with the trial and will not tamper with the prosecution witnesses. That the applicant undertakes that they will not misuse the liberty of bail if so granted by this . That the applicant is ready and willing to file adequate surety as the  may 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. 42 of 2024 lodged under Sections 147, 148, 149, 307, 504, 506, 323, 286, 427 of I.P.C. at Police Station – Dilippur, District – Pratapgarh, during the pendency of the trial, in the interest of justice.


I, Manoj Kumar aged about 38 years son of Late Dharmraj resident of 41, Police Line, District – Pratapgarh, Religion – Hindu, Qualification – LL.B., Occupation – Advocate, the deponent do hereby solemnly affirm and  state on oath as under :- That the deponent is uncle/pairokar of the applicant and doing pairvi of applicant in the above noted case and duly authorized by him for filing instant application before the Hon'ble Court and as such he is fully conversant with the facts of the case deposed herein under. That the photo verification slip issued by the Awadh Bar Association of the deponent is being pasted on the first page of this affidavit and photocopy of ID proof of the deponent is being annexed with this affidavit. That this is the first bail application on behalf of the applicant before this Hon'ble High 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. 21 of 2023 under Sections 386, 411 of I.P.C. at Police Station – Musafirkhana, District – Amethi on 12.02.2023 at 00.10 hours against three unknown persons regarding an incident dated 10.02.2023. The first information report is lodged by Shiv Charan son of Shri Heeralal resident of Village – Umamishra Purwa hamlet of Umapur, Police Station – Musafirkhana, District – Amethi (hereinafter referred to as ‘informant’). The certified/ type copy of the first information report dated 12.02.2023 lodged by the informant is being annexed herewith as Annexure No. 1 to this Affidavit. That according to the First Information Report, the prosecution story is in nutshell, that the informant and his two brothers were returning from their work on 10.02.2023. The informant was driving his motorcycle TVS Sport and his brothers were on another bike. Nearby Dadara, a bike overtake the informant and stopped his brothers, on which three persons. A person came to the informant and asked to give his bike, mobile and money otherwise his brothers have been killed by him. The informant was under the threat, hence the informant gave the things to him. That the alleged incident which was occurred on 10.02.2023 but the first information report has been lodged on 12.02.2023 after more than 2 days, 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 lodged aforesaid first information after legal advice. That the applicant is a common man of society and has no concern with the alleged allegation without any reason and falsely implicate in said case crime. That it is relevant to mention here that the contents of the first information report are beyond the truth as well as imagination. The story of the informant does not collaborate with the fact and circumstances of the alleged case crime. That the applicant is a student of class 12th and has no concerns with the allegations as alleged by the informant against the applicant and the concerned police arrested the applicant from his house on the basis of the false criminal case lodged and without any evidence, reason and falsely implicate in said case crime for showing his good work. The typed copy of the recovery cum arresting memo dated 12.02.2023 is being annexed herewith as Annexure No. 2 to this Affidavit. That after the alleged recovery of the motorcycle, the investigating officer added Section 411 of IPC in said case crime on 12.02.2023. That according to the prosecution story, clearly reveals that no one saw the occurrence while the applicant was arrested at about 13.25 hours and there is no independent eye-witness of the said recovery and it is a case of the forge, fabricated and false and there is no any evidence against the applicant. That on 12.02.2023, the statement of the informant has been recorded by the concerned police under Section 161 of Cr.P.C., in which almost repeated his version of the first information report, with slight improvement, as per directions of the concerned police, to falsely implicate the applicant. The typed copy of the statement of the informant dated 12.02.2023 is being annexed herewith as Annexure No. 3 to this Affidavit. That the real fact of the case is that the applicant has no concerns about any type of the act as mentioned in the first information report. The concerned police for the purpose of getting the reward from the state government, falsely implicated the applicant in said case. That it is most relevant to mention here that the applicant has not committed any offense as alleged by the informant in his first information report dated 12.02.2023. That the applicant was allegedly arrested by the concerned police from his house and showed that he has been arrested from another place and also recovered the Pulser bike having registration number UP 72 – BM – 5107, which is registered in the name of the applicant’s father. The photocopy of the registration certificate of the bike is being annexed herewith as Annexure No. 4 to this Affidavit. That the concerned police have no independent witnesses of the alleged recovery because the applicant has not committed any offence. The concerned police concocted the story and stated that the applicant has confessed his guilt at the time of his arrest. That till date the concerned police have not produced any sufficient evidence against the applicant to prove the involvement of the applicant is the 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 386, 411 of I.P.C. is made out against the applicant. That since the applicant has not committed any offence as alleged but he has been falsely implicated in the case by the informant in malafide intention. That the confessional statement of the applicant has been recorded by the concerned police at the time of recovery and arrest was under the life threat, in which the applicant said everything as narrated by the concerned police. That here it is relevant to mention here that applicant has no concerns with the alleged incident but the concerned police arrested the applicant and connected him with the said offense for an extraneous reason. That apart from the instant case, in which this bail application is being filed, another case is lodged against him bearing Case Crime No. 1047 of 2022 under Sections 323, 341, 354, 506 of IPC and 7/8 of The Protection of Children from Sexual Offences, Act, 2012 at Police Station – Kotwali City, District – Pratapgarh through Station House Officer, Police Station – Kotwali City, District – Pratapgarh, in which the as per the best knowledge of the applicant, the investigation is going on.:- That apart from the above as per the best knowledge of the applicant, no other criminal history against the applicant. That the applicant had applied for bail before bearing No. 628 of 2023 the Additional Sessions Judge, Court No. 07, Sultanpur but the same has been rejected on insufficient grounds vide order dated 22.02.2023. The free certified copy of the bail rejection order dated 22.02.2023 is annexed herewith as Annexure No. 5 to this affidavit. That the applicant has not committed any crime as alleged in the first information report by the informant and has no concerns. That the applicant is in jail since 12.02.2023 without committing any offense as alleged against the applicant. That there is no possibility of the applicant's conviction because he has not committed the crime in question, as alleged by the prosecution. That there is no chance of the applicant absconding or tampering with the prosecution witnesses and they are willing to offer bail to the satisfaction of this Hon’ble Court. That the applicant will cooperate with the trial and will not tamper with the prosecution witnesses. That the applicant undertakes that they will not misuse the liberty of bail if so granted by this . That the applicant is ready and willing to file adequate surety as the  may 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. 21 of 2023 lodged under Sections 386, 411 of I.P.C. at Police Station – Musafirkhana, District – Amethi, in the interest of justice.


I, Smt. Khurshida Bano aged about 35 years wife of Iqbal Ahmad resident of in front of Civil Court, Subhash Nagar, Kasba - Kunda, Police Station – Kunda, District – Pratapgarh, Religion – Muslim, Qualification – Literate, Occupation – Housewife, the deponent do hereby solemnly affirm and  state on oath as under :- That the deponent is wife of the applicant and doing pairvi of applicant in the above noted case and duly authorized by him and as such she is fully conversant with the facts of the case deposed herein under. That the photo of the deponent is being pasted on the first page of this affidavit and photocopy of ID proof of the deponent is being annexed with this affidavit. That this is first bail application on behalf of the applicant before the  and not other bail application is pending before in any court of law on his behalf. That the facts giving rise to the present case are being stated in brief hereinafter. That the applicant have falsely been implicated in case crime No. 112 of 2020 under Sections 307, 504, 506 of I.P.C. registered at Police Station – Kunda, District – Pratapgarh on 20.04.2020 at 03.27 hours. The first information report is lodged by Shri Pramod Patel, who is allegedly victim of the alleged case crime. It is further relevant to mention that the aforesaid first information report is related to the incident dated 19.04.2020 and lodged against the applicant and another. The photo/type copy of the first information report dated 20.04.2020 is being annexed herewith as Annexure No. 1 to this Affidavit. That the informant lodged the first information report after one days of the incident without giving any explanation with regard to delay cause in lodging first information report. That the informant stated in his first information report dated 20.04.2020 that on 19.04.2020 around 11.30 PM when he was at home alongwith his family at that moment the accused came at his house and demanded the Ganja from him. The informant denied for it then the applicant demanded the Ganja from the brother of the applicant. Later on the applicant abusing the informant and his brother and attacked with bomb upon the informant and his brother, in which they both were injured. That it is relevant to mention here that the contents of the first information report is beyond the truth as well as imagination. The story of the informant is not collaborated with the fact and circumstances of the alleged case crime. That after the aforesaid alleged incident the informant and his brother was brought to the hospital for initial treatment on next day of incident i.e. 20.04.2020. The photo/typed copy of the injury report of the informant and his brother is being annexed herewith as Annexure No. 2 to this Affidavit. That on very same day i.e. on 20.04.2020, the statement of the informant has been recorded by the concerned police under Section 161 of Cr.P.C. in which the informant almost repeated his averments of the first information report. The typed copy of the statement of the informant dated 20.04.2020 is being annexed herewith as Annexure No. 3 to this Affidavit. That the concerned police having no sufficient information and evidence against the applicant, even after knowing the first information report, the applicant surrendered before concerned police, in which the applicant was falsely implicated by the informant. That after surrender of the applicant and another accused, the concerned police added the Sections 4/5 of Explosive Substance Act, 1908 in said case crime. That after surrender of the applicant, the concerned police recorded the statement of the applicant under the threat of the life on 20.04.2020, in which he confessed his guilt. That without proper investigation of the case crime, the concerned police submitted charge sheet bearing number 172 of 2020 against the applicant and another accused persons under Sections 307, 504, 506 of IPC and 4/5 of Explosive Substance Act, 1908 on 14.07.2020 relating to Police Station – Kunda, District – Pratapgarh. That till date the concerned police has not produced any sufficient evidence against the applicant to prove involvement of the applicant is case crime. That according to the prosecution story it clearly reveals that story of the prosecution is based on only fake, fabricated and false story and concerned police avoiding the truth of case and there is no an evidence against the applicant/accused. That there is no credible evidence on record which could show that the applicant is guilty or committed the crime in question and the evidence available on record itself show that no prima-facie offence under Sections 307, 504, 506 of I.P.C. and 4/5 of Explosive Substance Act, 1908 is made out against the applicant. That since the applicant has not committed any offence as alleged but he has been falsely implicated in the case by the informant in malafide intention. That there is no possibility of the applicant conviction because he has not committed the crime in question, as alleged by the prosecution. That the applicant is common and peace loving man of the society and surviving anyhow due to Covid-19 alongwith his family. That as per prosecution there is no allegation of throwing the bomb by the applicant, which is duly confirmed by the informant and other witnesses of the case crime. That after false implication of the applicant in said case crime, the concerned police implicate the applicant in several other cases. Except present case crime, which are as under,:- Case Crime No. 817 of 2014 under Sections, 396, 302, 201, 412, 34 of IPC, related to Police Station – Munshiganj, District – Amethi, in which the applicant has been enlarged on bail by this Hon'ble High Court. The photocopy of the order dated 29.01.2016 passed by this Hon'ble High Court is being annexed herewith as Annexure No. 4 to this Affidavit. Case Crime No. 193 of 2014 under Sections, 2/3 of U.P. Gangster and Anti-Social Activities (Prevention) Act, 1986, related to Police Station – Kotwali, District – Sultanpur, in which the applicant has been enlarged on bail by this Hon'ble High Court. The photocopy of the order dated 08.03.2016 passed by this Hon'ble High Court is being annexed herewith as Annexure No. 5 to this Affidavit. Case Crime No. 175 of 2016 under Section 110G of Cr.P.C.. related to, Police Station – Kunda, District – Pratapgarh. The aforesaid case is not comes under the criminal history category. Case Crime No. 215 of 2016 under Sections 2/3 U.P. Gunda Act related to Police Station – Kunda, District – Pratapgarh. Case Crime No. 365 of 2019 under Sections Section 33/25 Arms Act, Police Station – Kunda, District – Pratapgarh, in which the applicant has enlarged on bail by the court below. That there is no chance of applicant absconding or tampering with the prosecution witnesses and they are willing to offer bail to the satisfaction of this Hon’ble Court. That the applicant is in Jail since   20.04.2020 without committing any offense. That the applicant will cooperate with the trial and will not tamper the prosecution witnesses. That the applicant undertakes that they will not misuse the liberty of bail if so granted by this Hon’ble Court. That the applicant is ready and willing to file adequate surety as the Hon’ble Court may deems fit and proper in the circumstances of the case. That the applicant had applied for bail application bearing number 183 of 2021 but the same has been rejected by the Sessions Judge, Pratapgarh on insufficient grounds vide order dated 05.02.2021. The free certified copy of bail rejection order dated 05.02.2021 passed by the court below is annexed herewith as Annexure No. 6 to this affidavit. That in view of the above, it would be expedient and necessary in the interest of justice that the applicant be enlarged on bail in relation to case crime No. 112 of 2020 under Sections 307, 504, 506 of I.P.C. and 4/5 of Explosive Substance Act, 1908 registered at Police Station – Kunda, District – Pratapgarh, during pendency of case.


I, Pankaj Kumar Yadav aged about 23 years son of Shri Dadan Babu Yadav resident of Village – Paschim Ka Purwa, Sahjani, Police Station – Manikpur, District – Pratapgarh, Religion – Hindu, Qualification – Literate, Occupation – Agriculture, the deponent do hereby solemnly affirm and  state on oath as under :- That the deponent is brother of the applicant and doing pairvi in the above noted case and also duly authorized by him. The deponent further declares that the contents of this instant application explained by the counsel of the applicant as such he is fully conversant with the facts of the case deposed herein under. That this is second bail application. First bail application No. 6434 of 2018 has been rejected by Hon’ble Shri Anant Kumar “J” on 11.04.2019. No any other bail application pending before this Hon'ble Court or rejected by this Hon'ble Court. That the applicant in jail on the basis of first information report lodged by the Informant, Badelal Yadav on 30.07.2017 at 14.30 hours against the five persons including the applicant vide case crime No. 100 of 2017 under Sections 498A, 304B IPC and 3/4 of The Dowry Prohibition Act, 1961 at Police Station – Manikpur, District – Pratapgarh. The certified/ typed copy of the first information report dated 30.07.2017 is being annexed herewith as Annexure No. 1 to this affidavit. That according to the prosecution story, it was alleged in the impugned first information report dated 30.07.2017 that the informant solemnized the marriage of his daughter namely Manju (hereinafter referred as to ‘deceased’) with the applicant with lot of dowry. But the all accused of the case crime demanded Rs. 2 Lacs from the daughter of the informant and for same they were tortured her. On 27.07.2017, the informant visited her daughter’s house then he was informed that the accused of the case crime had set the deceased ablaze. When the informant reached hospital, he found dead body of the deceased in car. That as a matter of fact the applicant is innocent and he has been falsely implicated by the Informant due to malafide intension of the Informant and on the ill advice of his relative. That as a matter of fact the applicant or his family had never demanded any dowry nor had tortured the deceased for the alleged demand of dowry. That the applicant never demanded any dowry from the deceased or her family members and after this unfortunate incident’s information was given by this applicant to the family members of the deceased as well as Informant and they were present at the time of Panchayatnama. The photo/ typed copy of the panchayatnama is being annexed herewith as Annexure No. 2 to this affidavit. That it is relevant to mention that as the deceased was brought to the hospital by the family members of the applicant in imergent situation and when the deceased declared dead then the hospital authority informed to the concenred police and police authority came and stated proceeding of the inquest as such the inquest report has not contained the case crime. That the post mortem was conducted on 30.07.2017 about 04.48 PM and as per post mortem report the deceased was burned 95% and smell of kerosene oil was present. The death of deceased caused by shock as a result of ante mortem burn injuries. The photo/ typed copy of the post mortem report is being annexed herewith as Annexure No. 3 to this affidavit. That the statement of the informant was recorded under Section 161 Cr.P.C. by the concerned police on 30.07.2017, in which he almost repeated his first informant report. The type copy of the statement of the informant is being annexed herewith as Annexure No. 4 to this affidavit. That the statements of the uncle of the deceased Amrit Lal and her grandfather Chhedi Lal were also recorded under Section 161 Cr.P.C. by the concerned police, in which they have also supported the version of the first information report. The typed copies of the statements of the Amrit Lal and Chhedi Lal are being annexed herewith collectively as Annexure No. 5 to this affidavit. That some other statements have been recorded by the concerned police, who are the interested witnesses of the case i.e. the statements of the brother of the deceased Manoj Kumar, mother of deceased Smt. Rajkali, sister of the deceased Madhu Devi, brother-in-law of the deceased Shiv Bhavan Yadav and other relatives were recorded under Section 161 of Cr.P.C.. All the interested witnesses and unanimously stated that the marriage of the deceased and application was solemnized on 22.04.2015 and levelled general allegations of demand of dowry and stated that the applicants and his family members murdered the deceased. The typed copies of the statements of the relative of the deceased are being annexed herewith collectively as Annexure No. 6 to this affidavit. That on 07.09.2017, the investigation of the case crime recorded the statements of the some independent witnesses under Section 161 of Cr.P.C., in which they specifically stated that the brother & sister of the applicant namely Sachin & Sonam, who were named in the first information report, were not involved in the alleged incident. The type copies of the statements of the Bahubal and Chandrapal are being annexed herewith collectively as Annexure No. 7 to this affidavit. That on basis of the statements of the independent witnesses, the name of the brother & sister of the applicant namely Sachin & Sonam were dropped during the investigation and they were exonerated. That without proper investigation of the case crime, the investigating officer of the case crime, filed the charge sheet against the applicant and his mother & father on 23.10.2017 under Sections 498A, 304B IPC and 3/4 of The Dowry Prohibition Act, 1961. The photo/typed copy of the charge sheet dated 23.10.2017 is being annexed herewith as Annexure No. 8 to this affidavit. That on perusal of the charge sheet, it is clear that the informant has named the accused persons in alleged case crime, in a very casual manner and without ascertaining the facts. That prior to the date of incident neither deceased nor informant has filed any complaint or police report was never filed either with the police or any other competent authority for any cruelty or demand of dowry, which creates doubts upon the prosecution story. That there is no credible evidence on record, which could show that the applicant is guilty or committed this crime in question and the evidence available on record, itself shows that no prima facie offence under Sections 498A, 304B IPC and 3/4 of The Dowry Prohibition Act, 1961 is made out against the applicant. That the applicant is in jail since 15.07.2017 without any of his fault. That no crime made out against the applicant as alleged in the impugned first information report lodged by the Informant. That neither any evidence was found against the applicant nor has any motive been assigned to the applicant in the present case. That the applicant has no criminal history at all except to this present case. That entire allegations as alleged in the first information report is false and frivolous. There was neither any demand of dowry nor the deceased was harassed in any manner. That real fact of the case is that the relation between the applicant and his family members are very sweet with the deceased. That the deceased could not conceive due to medical reasons, due to which she was not happy. The deceased was under treatment with Dr. Ishar Ahmad at Maniikpur. On 27.07.2017 itself, the ultrasound scan was performed at Allahabad and in the report it revealed that the deceased never conceived even after her treatment. The photocopy of the medical report of the deceased dated 27.07.2017 is being annexed herewith as Annexure No. 9 to this affidavit. That the deceased was very upset by knowing the fact that she will never conceived even after her treatment. The deceased was in deep depression since then. The applicant and his family members tried their best to explain the deceased but being hypersensitive with regard to child. That on 30.07.2017, when no anyone at house of the applicant as the family member of the applicant went to paddy field for routine work of caring the crop at that time the deceased committed suicide by setting herself ablaze as she was too dipressed after knowing that she will never become mother even after treatment. That whent the family members of the applicant informed with regard to fire in their house by the villager then then returned to home and found that the deceased burned herself by using kerosene oil. That the applicant was also out of house and immediate incident the family member of the applicant brought the deceased the hospital and due to painic situation they have not informed to the concerned police with regard to said incident. That just after incident occurred, the in-laws of the deceased were informed and deceased brought to the hospital, where she was declared brought dead. Thereafter the informant and other persons were reached to the hospital and lodged the first information against the applicant and other persons on the basis of the incorrect facts. That the first information report has been lodged afterthought and after consultation, in order to falsely implicate the applicant and other accused persons. That the first information report has been lodged in connivance with the police personnel because as per the inquest report, the informant was at CHC during inquest proceeding from 13.45 to 14.45 hours of 30.07.2017, however as per the first information report dated 30.07.2017, it was lodged at 14.30 hours, which is not possible and creates doubt upon the prosecution. That the deceased committed suicide due to her own reasons i.e. after knowing that she will never become mother even after treatment. That the other co-accused of the case crime i.e. mother and father of the applicant have been enlarged on bail by this Hon'ble Court vide order dated 20.12.2017 & 31.05.2018. The case of the applicant is identical and he is languishing in jail on the ground of being husband only. The photocopy of the bail order of this Hon'ble Court on 20.12.2017 & 31.05.2018 are being annexed herewith as Annexure No. 10 to this affidavit. That the bail application of the applicant has been rejected by learned Session Judge/F.T.C., Pratapgarh in bail application No. 62 of 2018 vide order dated 09.02.2018. The photocopy of the bail rejection order dated 09.02.2018 passed by the court concerned is being annexed herewith as Annexure No. 11 to this affidavit. That the applicant has filed first bail application before this Hon'ble Court as Criminal Case No. 6434 (B) of 2018 has been rejected by Hon’ble Shri Anant Kumar “J” on 11.04.2019. The photocopy of the order dated 11.04.2019 passed by this Hon'ble High Court is being annexed herewith as Annexure No. 12 to this affidavit. That the trial of the case has been initiated and statements and cross of the informant and other witnesses have recorded by the court concerned in which they all are stand with their statements under Sections 161 of Cr.P.C., with malafide intension to prove guilty the applicant. The photocopies of the statement and cross of the witnesses of the trial are being annexed herewith collectively as Annexure No. 13 to this affidavit. That on bare perusal of the aforesaid statements of the witnesses of the ongoing trail, there are several contradiction in the all statements, which are not collobrated with the prosecution story. That all are the interested witnesses as such merely on basis of their statements and testimony, the applicant would not be pleaded guilty. That the deceased committed suicide for her own reasons, which has been discussed hereinabove but the informant and his family members falsely implecated the applicant and his family in said case with malafide intension. That state of the Doctor has also examined on 02.07.2019 by the court concerned in which he stated that there was no external and enternal injury found on the body of the deceased. The doctor further state that the soot particle found in the trachea of the deceased, which shows it is clear that the deceased burned herself and she was freely breating at time of burn. The photo/typed copy examination of the doctor conducted the post mortem of the deceased is being annexed herewith as Annexure No. 14 to this affidavit. That the during the argument of the first bail application, the government advocate opposed the bail by satying that the incident had taken place in inside of the house of the applicant and he had not informed to the police, so far this averment of the government counsel it is relevant to mention that when the deceased put her on ablaze then the applicant and his family brought the deceased to hospital in said imergent situation, the first priority was there the treatment of the deceased not the information given to the concerned police. That merely on basis of the said averment of the government counsel this Hon'ble High Court rejected the first bail application of the applicant while he is entitled to enlarge on bail in view of the aforesaid averments made in this affidavit. That there is no possibility of the applicant’s conviction because he has not committed the crime in question as alleged by the Informant. That the applicant undertakes that he will not misuse the liberty of bail if so granted by this Court. That there is no chance of the applicant absconding or tempering with the prosecution witnesses. That the applicant is ready to furnish personal bond and sureties to the entire satisfaction before the court, if the bail is granted to him. That in view of the above noted fact, it is clear that the applicant is innocent and his is in jail since 15.07.2017 as such it is expedient and necessary in the interest of justice that the applicant be enlarged on bail during pendency of his trial.